NOTE TO FILE: Document Date 

DATE: December 9, 2009 

Name : Priya Yadav, Project Manager /RA/ 

Department: Materials Decommissions Branch

Division: DWMEP

Summary: The following documents are already in ADAMS as 33 different MLs and can be 

found under reference number 74FR30175 through an ADAMS search. This document should 

be added to ADAMS with a date of 12/09/2009. 

 
Page 1 of 1

PUBLIC SUBMISSION

As of: July 01, 2009

Received: June 24, 2009

Status: PendingPost

Tracking No. 809d905d

Comments Due: August 01, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshopon a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0001

Comment on FR Doc # E9-14820

Submitter Information A17

Name: John Stanford

Address:

698 Marquette Drive

Apartment 5

Kewaunee, WI, 54216

Submitter's Representative: none

Organization: retired

Government Agency Type: Federal

Government Agency: NRC

CD

General Comment

Depleted uranium disposal meetings to be conducted in two locations this year by

the NRC are my issue. I know that enrichment facilities process natural occurring

uranium to extract the valuable uranium 235 from the very predominant (99.3 %)

uranium 238 as the latter of the two is not a useful fissile isotope. The waste

stream is all that uranium 238, commonly referred to as tailings, but in this case,

as depleted uranium. Now all that uranium came from the ground or from a mine,

so why can't it go back to where it came from? There is a lot of uranium world

wide, just as there is a lot of thorium 232. Thorium 232 was everywhere when I

lived in Colorado. Shovel some dirt, and the shovel will include thorium 232. Half

lives: U-238 - 4.46 E9 years; U235 - 703.8 E6 years; Th-232 - 1.404 E 10 years.

We have had a fair amount of decay of U-235, but very little decay of the other

two, thus the uranium isotope percentage difference. They are all but stable, in

fact. Now they all finally decay to elements like radium and it is not only an alpha

emitter, like uranium and thorium are. If an organization tried to license a coal

fired plant as a nuclear plant, they couldn't, due to the 10CFR20 limits on radium

releases. Now how many people know that?

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https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPageCall=Print&Printld... 07/01/2009

Page 1 of 1 

As of: July 01, 2009 

Received: June 24, 2009 

PUBLIC SUBMISSI N Status: Pending_Post Tracking No. 809d905d 

Comments Due: August 01, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshopon a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Docu ment: NRC -2009-0257 -DRAFT -0001 

Comment on FR Doc # E9-14820 

Name: John Stanford 

Address: 

Submitter Information ~4)ZJ/ 

71'?X-3t!) 17o698 Marquette Drive 

Apartment 5 

Kewaunee, WI, 54216 

Submitter's Representative: none 

Organization: retired 

Government Agency Type: Federal 

Government Agency.: NRC 

General Comment 

Depleted uranium disposal meetings to be conducted in two locations this year by 

.JJ 

~TI 

the NRC are my issue. I know that enrichment facilities process natural occurring 

uranium to extract the valuable uranium 235 from the very predominant (99.3 %) 

uranium 238 as the latter of the two is 'not a useful fissile isotope. The waste-n 

stream is all that uranium 238, commonly referred to as tailings, but in this case, /" 

as depleted uranium. Now all that uranium came from the ground or from a mine,"::"--. 

so why can't it go back to where it came from? There is a lot of uranium world i-T""I 

I , ~ 

,-.~ ......... , \ 

'" ,I" 

wide, just as there is a lot of thorium 232. Thorium 232 was everywhere when I C~J 

lived in Colorado. Shovel some dirt, and the shovel will include thorium 232. Half 

lives: U-238 - 4.46 E9 years; U235 - 703.8 E6 years; Th-232 - 1.404 E 10 years. 

We have had a fair amount of decay of U-235, but very little decay of the other 

two, thus the uranium isotope percentage difference. They are all but stable, in 

fact. Now they all finally decay to elements like radium and it is not only an alpha 

emitter, like uranium and thorium are. If an organization tried to license a coal 

fired plant as a nuclear plant, they couldn't, due to the 10CFR20 limits on radium 

(] 

releases. Now how many people know that? /:- -;l"C.z'7)S'::::- /.73.J-t -05 

So)JS~ 8e-t/l~~r~, ~:=:- t·~adav (flY) " 

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Page 1 of 1

PUBLIC SUBMISSION

As of: September 25, 2009

Received: September 24, 2009

Status: Pending-Post

Tracking No. 80a2ab7c

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0002

Comment on FR Doc # E9-14820

Submitter Information

Name: Chuck McCown

Address:

2000 E Sunset Road 7,, -- 5 '/7

Lake Point, UT, 84074

Organization: Private Citizen

General Comment

I have absolutely no problem in storing DU at ANY location. I would hope that we can use DU for uses such as

forklift counterweights and other high mass uses. DU poses almost an undetectable risk. It is always amusing

to note that many of the detractors of low level waste such as HEAL in Utah, use CFL and florescent lamps as

well as mercury thermometers. It seems that the emotional reaction to all things radioactive blinds those

affected to rational, relative risk assesment.

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•2)A)52 2 ~5~2//&et~ 2Ay~

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https ://fdms. erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&PrintId... 09/25/2009

Page 1 of 1 

PUBLIC SUBMISSION 

Docket: NRC-2009,0257 

As of: September 25, 2009 

Received: September 24, 2009 

Status: Pending_Post 

Tracking No. 80a2ab7c 

Comments Due: October 30, 2009 

Submission Type: Web 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0002 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Chuck McCown 

Address: 

2000 E Sunset Road 

Lake Point, UT, 84074 

Organization: Private Citizen -

~~/oJ 

7f?f!- 3!}/ 7~ 

General Comment 

I have absolutely no problem in storing DU at ANY location. I would hope that we can use DU for uses such as 

forklift counterweights and other high mass uses. DU poses almost an undetectable risk. It is always amusing 

to note that many of the detractors of low level waste such as HEAL in Utah, use CFL and florescent lamps as 

well as mercury thermometers. It seems that the emotional reaction to all things radioactive blinds those 

affected to rational, relative risk assesment. 

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OF` mu" mEsh L I C ZS) Ou" B M I S S 10 N

As of: October 19, 2009

Received: October 18, 2009

Status: Pending-Post

Tracking No. 80a44998

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0005

Comment on FR Doc # N/A

Submitter Information

Name: phillip barr

Organization: private citizen

General Comment

i dont think the andrews county texas nuclear waste dump should be used for disposal of any kind of nuclear or

hazardous waste.

because of the earthquake history and sinkhole history the area has. and its over the aquifer as well

All information below has been placed in public domain

Attachments -'U

NRC-2009-0257-DRAFT-0005.1: Comment on FR Doc # N/A

NRC-2009-0257-DRAFT-0005.2: Comment on FR Doc # N/A

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PUBLIC SUBMISSI N 

Docket: NRC-2009-0257 

As of: October 19, 2009 

Received: October 18, 2009 

Status: Pending_Post 

Tracking No. 80a44998 

Comments Due: October 30, 2009 

Submission Type: Web 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0005 

Comment on FR Doc # N/A 

Name: phillip barr 

Organization: private citizen 

Submitter Information 

General Comment 

i dont think the andrews county texas nuclear waste dump should be used for disposal of any kind of nuclear or 

hazardous waste. ' 

because of the earthquake history and sinkhole history the area has. and its over the aquifer as well 

All information below has been placed in public domain 

Attachments 

NRC-2009-02S7-DRAFT-OOOS.l: Comment on FR Doc # N/A 

NRC-2009-02S7-DRAFT-OOOS.2: Comment on FR Doc # N/A 

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https:llfdms.erulemaking.net/fdms-web-agency/ component! submitter InfoCover Page ?Call = Print&PrintId... 10/19/2009 
----- Original Message -----

From: pharb2(@msn.com

To: David.levenstein(@em.doe.qov ; Gilrein.Stephen)epamail.epa.gov

Cc: JEFF BINGAMAN ; presidentcmessages.whitehouse.gov; jackson.lisac)epa.gov; Brozowski.George(ýepamail.epa.

goy; Miller.Gary(Thepamail.epa.gov ; Scott.Burnellýnrc.gov ; Starfield.Lawrence~cepamail.epa.gov The.Secretary@hq.doe.

cqov James Park ; wright.larrVy@epa.gov ; breen.barrycepa.gov

Sent: Thursday, August 20, 2009 6:18 PM

Subject: consolidated comment on storage safety at andrews county Texas waste site nbl

Its my belief that the geology at the Andrews county TX waste site area is not stable

enough for a nuclear/pcb/Mercury storage site.

1. I submit these news reports on the sinkhole activity in the area..

Sinkholes north and south of the nuclear waste site at Andrews county Texas and the

waste site area itself has an earthquake history that's on record.

2. Earthquake study 12a,12b, 12w-a on record.

The state of Texas and federal government's safety analysis on the andrews county dump

is hypothetical at best because :

The State of Texas and the Nrc, EPA and Doe can not guarantee there will not be another

earthquake at the Andrews county Texas waste site which would endanger the aquifer

which is under the site as determined by the epa:

News quote "But David Barry, spokesperson for the Environmental Protection Agency for

Region 6 says, "Yes, the facility does sit above the Ogallala aquifer. It sits on the southern

end of the aquifer."

The state of Texas, EPA,NRC,DOE also cannot guarantee that in an area with sinkholes,

one would not form under the waste site.

High winds and sandstorms blowing toxic particles offsite and over Eunice and Hobbs.

There is no way to prevent this and at no time has any government agency demonstrated

to the public how to do so.

I believe for the Federal Government and the State of Texas to open up a waste dump for

anything toxic at the andrews county nuclear waste site with this sinkhole and

earthquake history is highly irresponsible and a disaster waiting to happen.

Phillip Barr

Lea county, New Mexico

----- Original Message -----

From: pharb2@msn.com 

To: Oavid.levenstein@em.doe.gov ; Gilrein.Stephen@epamail.epa.gov 

Cc: JEFF BINGAMAN; president@messages.whitehouse.gov ; jackson.lisa@epa.gov ; Brozowski.George@epamail.epa. 

gOY ; Miller.Gary@epamail.epa.gov ; Scott.Burnell@nrc.gov ; Starfield.Lawrence@epamail.epa.gov ; The.Secretary@hq.doe. 

gOY ; James Park; wrighUarry@epa.gov ; breen.barry@epa.gov 

Sent: Thursday, August 20,20096:18 PM 

Subject: consolidated comment on storage safety at andrews county Texas waste site nb1 

Its my belief that the geology at the Andrews county TX waste site area is not stable 

enough for a nuclear/pcb/Mercury storage site. 

1. I submit th'ese news reports on the sinkhole activity in the area .. 

Sinkholes north and south of the nuclear waste site at Andrews county Texas and the 

waste site area itself has an earthquake history that's on record. 

2. Earthquake study 12a,12b, 12w-a on record. 

The state of Texas and federal government's safety analysis on the andrews county dump 

is hypothetical at best because: 

The State of Texas and the Nrc, EPA and Doe can not guarantee there will not be another 

earthquake at the Andrews county Texas waste site which would endanger the aquifer 

which is under the site as determined by the epa: 

--------------- ---------------

News quote "But David Barry, spokesperson for the Environmental Protection Agency for 

Region 6 says, "Yes, the facility does sit above the Ogallala aquifer. It sits on the southern 

end of the aquifer." 

--------------- ---------------

The state of Texas, EPA,NRC,DOE also cannot guarantee that in an area with sinkholes, 

one would not form under the waste site. 

High winds and sandstorms blowing toxic particles offsite and over Eunice and Hobbs. 

There is no way to prevent this and at no time has any government agency demonstrated 

to the public how to do so. 

I believe for the Federal Government and the State of Texas to open up a waste dump for 

anything toxic at the andrews county nuclear waste site with this sinkhole and 

earthquake history is highly irresponsible and a disaster waiting to happen. 

Phillip Barr 

Lea county, New Mexico 
Yoakum county north of the site

http://www. newswest9. com/GIobal/story.asp?S = 10811930

Giant Sinkhole Opens Near Denver City

Posted: July 29, 2009 11:43 AM MDT

DENVER CITY - Investigators from the Texas Railroad Commission spent Tuesday trying to figure out why land at a Denver

City oil company caved-in.

The sinkhole appeared just on the edge of Denver City on the Oxy site. Officials tell us no one was hurt and no water or power

lines were damaged.

The hole drops 50 feet and is 60 feet around.

Winkler county south of the site

http://www. kwes.com/Global/story.asp?S= 7936458

or www.kwes.com/Global/story.asp?S=7936458

Wink Sink Study Needs Funding

by Victor Lopez

NewsWest 9

WINKLER CO.-Local oil and gas producer, John Bell

believes, "We need to be cautious about where it is and

the understanding on how much area it could affect."

Whether you call it, the Kermit Crater or the Wink Sink,

residents say it's all the same place.

W . W r_-It measures approximately 300 feet across. Now, it

appears to be multiplying. And the newest member of the

U family is getting bigger.

According to Bell, "There is a new sink hole that is six or

seven times larger than this one, that has occurred in the

last three years."

The area around what is being called "Wink Sink 2", is still

very unstable. And it's the size of a 15 acre lake.

Yoakum county north of the site 

http://www.newswest9.com/Global/story.asp?S= 10811930 

Giant Sinkhole Opens Near Denver City 

Posted: July 29, 2009 11 :43 AM MDT 

DENVER CITY -Investigators from the Texas Railroad Commission spent Tuesday trying to figure out why land at a Denver 

City oil company caved-in. 

The sinkhole appeared just on the edge of Denver City on the Oxy site. Officials tell us no one was hurt and no water or power 

lines were damaged. 

The hole drops 50 feet and is 60 feet around. 

Winkler county south of the site 

http://www.kwes.com/Global/story.asp?S= 7936458 

or www.kwes.com/Global/story.asp?S= 7936458 

Wink Sink Study Needs Funding 

by Victor Lopez 

NewsWest 9 

WINKLER CO.-Local oil and gas producer, John Bell 

believes, "We need to be cautious about where it is and 

the understanding on how much area it could affect." 

Whether you call it, the Kermit Crater or the Wink Sink, 

residents say it's all the same place. 

It measures approximately 300 feet across. Now, it 

appears to be multiplying. And the newest member of the 

family is getting bigger. 

According to Bell, "There is a new sink hole that is six or 

seven times larger than this one, that has occurred in the 

last three years." 

The area around what is being called "Wink Sink 2", is still 

very unstable. And it's the size of a 15 acre lake. 
77 Random cracks in and around the sink holes are creating

-concern for safety and well being in Winkler County.

That's why John Bell is asking for support for "The Wink Sink Study", or as he calls it, a large scale science project,

"Right now, anything we're doing is personal theories. We

w: * have to come up with some science. This is just a big

j- science project to help us understand, how do we deal with

it, and what do we to avoid somebody having a

catastrophe that we don't see, and get somebody hurt or

killed."

Phase one of the study calls for about $730 thousand

dollars in funding, 200 thousand of which has already been

raised. Leaving a balance of about 1/2 a million dollars

left to collect.

Dr. Bob Trentham, Director of CEED, at UTPB, tells

NewsWest 9, The money will help provide some pretty high

tech study tools, "We are going to be using several state of

the art techniques, various types of radar and arial photos."

Since the new cracks and sags are popping up pretty much all over, the images these

study tools will provide, will be invaluable.

Trentham says, "We need to know where these are going to potentially develop in

the future so that we can help both the oil companies and the public service people to

know where the areas with lowest risks and the highest risks are."

The growing threat of these cracks not only affects Winkler County, but other parts of

the Permian Basin and even New Mexico.

Bell added, "This thing is large enough in scope, it extends past Monahans on down

towards Imperial. We know that this is going to get bigger than we are. There is one

at Jal, between Jal and Eunice, New Mexico."

Thus increasing the urgency of the study.

From: <pharb2@msn.com>

To: <.David.levenstein@em.doe. gov>,

<Gilrein.Step hen@epamaiI.epa.qov>

Cc: "JEFF BINGAMAN" <senator bingaman@bingaman.senate.qov>,

Random cracks in and around the sink holes are creating 

concern for safety and well being in Winkler County. 

That's why John Bell is asking for support for "The Wink 

Sink Study", or as he calls it, a large scale science project, 

"Right now, anything we're doing is personal theories. We 

have to come up with some science. This is just a big 

science project to help us understand, how do we deal with 

it, and what do we to avoid somebody having a 

catastrophe that we don't see, and get somebody hurt or 

killed." 

Phase one of the study calls for about $730 thousand 

dollars in funding, 200 thousand of which has already been 

raised. Leaving a balance of about 1./2 a million dollars 

left to collect. 

Dr. Bob Trentham, Director of CEED, at UTPB, tells 

NewsWest 9, The money will help provide some pretty high 

tech study tools, "We are going to be using several state of 

the art techniques, various types of radar and arial photos." 

Since the new cracks and sags are popping up pretty much all over, the images these 

study tools will provide, will be invaluable. 

Trentham says, "We need to know where these are going to potentially develop in 

the future so that we can help both the oil companies and the public service people to 

know where the areas with lowest risks and the highest risks are." 

The growing threat of these cracks not only affects Winkler County, but other parts of 

the Permian Basin and even New Mexico. 

Bell added, "This thing is large enough in scope, it extends past Monahans on down 

towards Imperial. We know that this is going to get bigger than we are. There is one 

at Jal, between Jal and Eunice, New Mexico." 

Thus increasing the urgency of the study. 

From: <pharb2@msn.com> 

To: <David.levenstein@em.doe.gov>, 

<Gilrein.Stephen@epamail.epa.qov> 

Cc: "JEFF BINGAMAN" <senator bingaman@bingaman.senate.qov>, 
<president@messages.whitehouse.gov>,

<jackson. Iisa @epa. gov>,

< Brozowski.Georq e@epamail .epa .gov>,

< Miller.Gary@epamail. epa.gov>,

<Scott. Burnell@nrc.gov>,

<Starfield. Lawrence@epamaiI.epa.gov>,

<The. Secreta ry@ hg. doe. cov >,

"James Park" <James. Park@nrc.gov>,

<wriqht.larry@epa.qov>,

<breen.barry@epa.gov>

Subject: consolidated comment on storage safety at andrews county Texas waste site

nbl

Date: Thu, 20 Aug 2009 18:18:50 -0600

MIME-Version: 1.0

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boundary="---- . NextPart_000_00A7_01CA21C3.37DF2270"

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X-MimeOLE: Produced By MSN MimeOLE V9.60.0053.2200

Seal-Send-Time: Thu, 20 Aug 2009 18:18:50 -0600

< president@messages.whitehouse.gov>, 

<jackson.lisa@epa.gov>, 

<BrozowskLGeorge@epamail.epa.gov>, 

< Mi Iler. Gary@epamail.epa.gov>, 

<Scott. Burnell@nrc.gov>, 

< Sta rfi e I d. La wren ce@epa m a i I. epa. 9 ov > , 

<The.Secretary@hq.doe.gov> , 

"James Park" <James. Park@nrc.gov>, 

<wright.larry@epa.gov>, 

< breen. barry@epa.gov> 

Subject: consolidated comment on storage safety at andrews county Texas waste site 

nb1 

Date: Thu, 20 Aug 2009 18:18:50 -0600 

MIME-Version: 1.0 

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WHMAT STARTS JUMEk CEA14GES THI WODALD

[H If UNIVERSITY OF TEXAS At' AJS r IN

EARTHQUAKE SEISMOLOGY

Chapter 12 of, State of Texas Hazards Analysis, by the Governor's Division of Emergency Management, Department of Public Safety,

Austin, Texas, 1998.

Introduction: Earthquakes in Texas

,n earthquake is a motion or trembling that occurs when there is a sudden breaking or shifting of rock material beneath the

aarth's surface. This breaking or shifting produces elastic waves which travel at the speed of sound in rock. These waves may

De felt or produce damage far away from the epicenter-the point on the earth's surface above where the breaking or shifting

3ctually occurred.

:or Texans, three essential facts about earthquakes are important to remember. First, earthquakes do occur in Texas (see

:igure 12A). Within the twentieth century there have been more than 100 earthquakes large enough to be felt; their

_picenters occur in 40 of Texas's 257 counties. Four of these earthquakes have had magnitudes between 5 and 6, making

:hem large enough to be felt over a wide area and produce significant damage near their epicenters.

3econd, in four regions within Texas there have been historical earthquakes which indicate potential earthquake hazard

:Figure 12B). Two regions, near El Paso and in the Panhandle, should expect earthquakes with magnitudes of about 5.5-6.0 to

)ccur every 50-100 years, and even larger earthquakes are possible. In northeastern Texas the greatest hazard is from very

arge earthquakes (magnitude 7 or above) which might occur outside of Texas, particularly in Oklahoma or Missourirennessee. In south-central Texas the hazard is generally low, but residents should be aware that small earthquakes can

)ccur there, including some which are triggered by oil or gas production. Elsewhere in Texas, earthquakes are exceedingly

EARTHQUAKE SEISMOLOGY 

Chapter 12 of, State afTexas Hazards Analysis, by the Governor's Division of Emergency Management, Department of Public Safety, 

Austin, Texas, 1998. 

Introduction: Earthquakes in Texas 

!!..n earthquake is a motion or trembling that occurs when there is a sudden breaking or shifting of rock material beneath the 

~arth's suii'ace. This breaking or shifting produces elastic waves which travel at the speed of sound in rock. These waves may 

Je felt or produce damage far away from the epicenter-the point on the earth's surface above where the breaking or shifting 

Ktually occurred. 

=or Texans, three essential facts about earthquakes are important to remember. First, earthquakes do occur in Texas (see 

=igure 12A). Within the twentieth century there have been more than 100 earthquakes large enough to be felt; their 

~picenters occur in 40 of Texas's 257 counties. Four of these earthquakes have had magnitudes between 5 and 6, making 

:hem large enough to be felt over a wide area and produce significant damage near their epicenters. 

3econd, in four regions within Texas there have been historical earthquakes which indicate potential earthquake hazard 

:Figure 12B). Two regions, near EI Paso and in the Panhandle, should expect earthquakes with magnitudes of about 5.5-6.0 to 

Jccur every 50-100 years, and even larger earthquakes are possible. In northeastern Texas the greatest hazard is from very 

arge earthquakes (magnitude 7 or above) which might occur outside of Texas, particularly in Oklahoma or Missourirennessee. In south-central Texas the hazard is generally low, but residents should be aware that small earthquakes can 

JCcur there, including some which are triggered by oil or gas production. Elsewhere in Texas, earthquakes are exceedingly 
-are. However, the hazard level is not zero anywhere in Texas; small earthquakes are possible almost anywhere, and all

-egions face possible ill effects from very large, distant earthquakes

rhird, while Texas does face some earthquake hazard, this hazard is very small in comparison to that in many other states,

ncluding California, Missouri, Montana, South Carolina, and Washington (Figure 12C). In most parts of Texas earthquake

iazard is also small compared to the hazard attributable from other natural phenomena, such as hurricanes, tornadoes, and

'loods. Thus there is no need for Texas to enact sweeping changes in construction practices, or take other drastic measures to

-nitigate earthquake hazard.

-lowever, Texans need to begin learning about earthquakes. Over the past 70 years Texas has changed from a sparsely

•opulated state with an economy dominated by agriculture to an economically diverse state with various large, technical

nanufacturing industries centered in a few densely populated urban regions. For reasons of safety, economy, and (in some

:ases) law, Texans need to consider earthquake hazard when designing or siting various structures which are essential for

,roviding medical or emergency management services, which house sensitive manufacturing processes, or which store

iazardous wastes.

1974-

197001L 8

1 ( 193666 1971

Amarllo dr 19,{- 01952

1951 1098.78

II 1925 1930

19M92

178,79,82 195 1997 1957

Figure 1 2A Locations of earthquakes and a% 19S2 D 13131103

earthquake sequences that have occurred in 11976.77 019e.

Texas, or that were felt by Texas residents. S E' 01 ,''c 191

19)23 01975 928g Numbers are the year of occurrence. (See a 0314.3 19lZ I 1984

larger version of this figure.) I 7I6.. •2 f•887 bn 

-are. However, the hazard level is not zero anywhere in Texas; small earthquakes are possible almost anywhere, and all 

-egions face possible ill effects from very large, distant earthquakes 

rhird, while Texas does face some earthquake hazard, this hazard is very small in comparison to that in many other states, 

ncluding California, Missouri, Montana, South Carolina, and Washington (Figure 12C). In most parts of Texas earthquake 

lazard is also small compared to the hazard attributable from other natural phenomena, such as hurricanes, tornadoes, and 

'Ioods. Thus there is no need for Texas to enact sweeping changes in construction practices, or take other drastic measures to 

nitigate earthquake hazard. 

-iowever, Texans need to begin learning about earthquakes. Over the past 70 years Texas has changed from a sparsely 

)opulated state with an economy dominated by agriculture to an economically diverse state with various large, technical 

nanufacturing industries centered in a few densely populated urban regions. For reasons of safety, economy, and (in some 

:ases) law, Texans need to cOnsider earthquake hazard when designing or siting various structures which are essential for 

Jroviding medical or emergency management services, which house sensitive manufacturing processes, or which store 

lazardous wastes. 

Figure 12A Locations of earthquakes and 

earthquake sequences that have occurred in 

Texas, or that were felt by Texas residents. 

Numbers are the year of occurrence. (See a 

larger version of this figure.) 

1982 

1971) 0 % 193-600 l~J 1948 001917,2' 1976 

Amorlilo ...tr:I1 n ~ 1907~ I.r'" .,~ 

2(:000 ~ 1951 111'98,97 

C 

1925 

<D1g78,79,82 

01952 

('} 

195B 

D 

® 18B2 '. Hl71 

19~O 19eQ 0 • 1997 19:57 

188ll 1992 . &-_____ ----. ..... 1965.66,71 

C"II"" 0 

19091 

1'J2S 

o 

. 1976.77 

01~75' 01978 

o 

6 

o I!l 

19:32 1891 

19~1 1ge1 

(Q19~ 

61995 

1996 

IS87 

Ausl:in 1 e.67 0 0 1 ~1 4-

187~ 0 01Q10 

1847 1Q02 

S"n Anum;". Q 0 

1I:l92.93 t99~ 

Earthquakes Felt in Texas 

1847 - 2001 

1964GOD 19tH 

1973,63,93 
106 101

Figure 12B Map indicating probable causes of

eartthquakes occurring in Texas. Solid lines show the four

regions of Texas where historical earthquake activity

indicates there is earthquake hazard. Light lines are county

boundaries.

PwAk Acedwolmi MW. W&t 10% Prambabi of M wie.r In Yom

obec NEHRP B-C bmm~wy

Figure 1 2C Earthquake hazard map for the

continental United States as prepared by the U.

S. Geological Survey. In the central and eastern

U. S., the regions expecting the highest

accelerations all correspond to the sites of known

historical earthquakes. These include: Montana,

1959; West Texas, 1931; Oklahoma, 1952;

Missouri-Tennessee, 1811-1812; and South

Carolina, 1886. In many places such as Texas,

the absence of detailed historical information

means that earthquake hazard may be higher

than indicated in this figure.

.1Qw 40'

U.S. Gfodq~84rW"

Roomn se~wsio wam lmapiIn Poj

Earthquake Magnitude, Intensity, and Damage

lhe nature and geographical extent of earthquake hazard depends strongly on the quake's size or magnitude. Because r

2arthquakes are rare, people are often confused about how risk depends on magnitude. Imagine that you were about to

-eturn from a vacation, and someone told you that animals had infested your property. Naturally, you would ask whether

:hese animal were mice, armadillos, or cattle, because each might cause a different kind and amount of damage. Similarly, if

/our neighborhood has an earthquake, the kind and amount of damage depends on the earthquake's size. A quake with

nagnitude 3 may do no more than startle people and rattle dishes within a one-square-mile region. However, a magnitude 7

36 

Jl 

101 

Eorlhquol«J Cause 

+ NatvraI 

• Probabb' MQrwnade 

• em... Urarl:aln 

figure 1218 Map indicating probable causes of 

.36 eartthquakes occurring in Texas. Solid lines show the four 

regions of Texas where historical earthquake activity . 

indicates there is earthquake hazard. Light lines are county 

boundaries. 

.}1 

2e~~============~========~==~======~2G .OS 101 9& 

figure 12C Earthquake hazard map for the 

continental United States as prepared by the U. 

S. Geological Survey. In the central and eastern 

U. S., the regions expecting the highest 

accelerations all correspond to the sites of known 

historical earthquakes. These include: Montana, 

1959; West Texas, 1931; Oklahoma, 1952; 

Missouri-Tennessee, 1811-1812; and South 

Carolina, 1886. In many places such as Texas, 

the absence of detailed historical information 

means that earthquake hazard may be higher 

than indicated in this figure. 

PGIIk At=caIaniiIan (%u) _itt tD'll. Prababllity rJf Ela:aada_ In !II "-

Ilk NllHRP B.c bllllllldalJ 

.100' ..;0' 

u.s. GooIOJJIOaI84.itY'01 

No1icnaI8eltmlo HaIatd ..,lilG PtojoOt 

Earthquake Magnitude, Intensity, and Damage 

rhe nature and geographical extent of earthquake hazard depends strongly on the quake's size or magnitude. Because 

~arthquakes are rare, people are often confused about how risk depends on magnitude. Imagine that you were about to 

-eturn from a vacation, and someone told you that animals had infested your property. Naturally, you would ask whether 

:hese animal were mice, armadillos, or cattle, because each might cause a different kind and amount of damage. Similarly, if 

{our neighborhood has an earthquake, the kind and amount of damage depends on the earthquake's size. A quake with 

nagnitude 3 may do no more than startle people and rattle dishes within a one-square-mile region. However, a magnitude 7 
Nould be felt by people over the entire state of Texas, and could do significant damage to buildings, bridges, and dams over a

-onsiderable region.

3cientists determine an earthquake's magnitude by measuring the amplitude of ground motion as recorded on a seismograph,

and then correcting the measurement to account for the effects of distance from the epicenter. The magnitude scale is a

power of ten' scale; thus if a magnitude 3.8 caused ground motion of 1/10 inch at a particular location, a 4.8 at the same

_picenter would cause ground motion of 1 inch, and a 5.8 would cause ground motion of 10 inches. This means that

-nagnitude 3 and magnitude 7 earthquakes are enormously different with respect to their ground motion and the size of and

;lip on the faults that produce them.

3cientists use the Modified Mercalli intensity (MMI) to describe how strong the motion is at a particular location. The MMI is a

iumber between one and twelve, expressed as a Roman numeral such as MMI IV or MMI IX so that the number won't be

:onfused with magnitude (see Figures 12D and 12E). While each earthquake has only one magnitude, it has many different

ntensities, since earthquake damage becomes less severe as one moves away from the epicenter. Usually, most of the

iamage done by an earthquake occurs in the regions nearest the epicenter which have the highest intensities. While intensity

lepends strongly on factors such as soil properties, in most cases earthquakes with larger magnitudes have higher maximum

ntensities (see Figure 12F).

3ecause damaging earthquakes are rare in Texas, it is tempting to ignore them. A more responsible approach is to be

3elective about mitigation efforts, focusing attention on structures or areas where potential hazard is greatest. The argument

.or earthquake mitigation is analogous to the argument for having seatbelts and airbags in automobiles-although any one

Jriver is unlikely to have an accident in any given day or year, over a person's lifetime there is a significant chance of having a

;erious accident. Even in West Texas and the Panhandle, at any particular place damaging earthquakes probably occur only

)nce per century, or less. However, with a little prior planning it is possible to ensure that their damage is minimal.

Earthquake felt intensity - the Modified Mercalli Intensity Scale

MMI What people feel, or what damage occurs.

Not felt except by a very few people under special

conditions. Detected mostly by instruments.

Felt by a few people, especially those on the upper floors

of buildings. Suspended objects may swing.

Felt noticeably indoors. Standing automobiles may rock

slightly.

Felt by many people indoors, by a few outdoors. At night,

IV. some people are awakened. Dishes, windows, and doors

rattle.

Felt by nearly everyone. Many people are awakened.

V. Some dishes and windows are broken. Unstable objects

are overturned.

Felt by everyone. Many people become frightened and

VI. run outdoors. Some heavy furniture is moved. Some

plaster falls.

Most people are alarmed and run outside. Damage is

VII. negligible in buildings of good construction, considerable

in buildings of poor construction.

Damage is slight in specially designed structures,

VIII. considerable in ordinary buildings, great in poorly built

structures. Heavy furniture is overturned.

Damage is considerable in specially designed buildings.

IX. Buildings shift from their foundations and partly collapse.

Underground pipes are broken.

Some well-built wooden structures are destroyed. Most

X. masonry structuresare destroyed. The ground is badly

cracked. Considerable landslides occur on steep slopes.

Nould be felt by people over the entire state of Texas, and could do significant damage to buildings, bridges, and dams over a 

:onsiderable region. . 

3cientists determine an earthquake's magnitude by measuring the amplitude of ground motion as recorded on a seismograph, 

3nd then correcting the measurement to account for the effects of distance from the epicenter. The magnitude scale is a 

power of ten' scale; thus if a magnitude 3.8 caused ground motion of 1/10 inch at a particular location, a 4.8 at the same 

=picenter would cause ground motion of 1 inch, and a 5.8 would cause ground motion of 10 inches. This means that 

nagnitude 3 and magnitude 7 earthquakes are enormously different with respect to their ground motion and the size of and 

;Iip on the faults that produce them. 

3cientists use the Modified Mercalli intensity (MMI) to describe how strong the motion is at a particular location. The MMI is a 

1umber between one and twelve, expressed as a Roman numeral such as MMI IV or MMI IX so that the number won't be 

:onfused with magnitude (see Figures 12D and 12E). While each earthquake has only one magnitude, it has many different 

ntensities, since earthquake damage becomes less severe as one moves away from the epicenter. Usually, most of the 

jamage done by an earthquake occurs in the regions nearest the epicenter which have the highest intensities. While intensity 

jepends strongly on factors such as soil properties, in most cases earthquakes with larger magnitudes have higher maximum 

ntensities (see Figure 12F). 

3ecause damaging earthquakes are rare in Texas, it is tempting to ignore them. A more responsible approach is to be 

;elective about mitigation efforts, focusing attention on structures or areas where potential hazard is greatest. The argument 

:or earthquake mitigation is analogous to the argument for having seatbelts and airbags in automobiles-although anyone 

jriver is unlikely to have an accident in any given day or year, over a person's lifetime there is a significant chance of having a 

;erious accident. Even in West Texas and the Panhandle, at any particular place damaging earthquakes probably occur only 

)nce per centurY,or less. However, with a little prior planning it is possible to ensure that their damage is minimal. 

Earthquake felt intensity - the Modified Mercalli Intensity Scale 

MMI What people feel, or what damage occurs. 

Not felt except by a very few people under special 

conditions. Detected mostly by instruments. 

Felt by a few people, especially those on the upper floors 

II. of buildings. Suspended objects may swing. 

Felt noticeably indoors. Standing automobiles may rock 

III. slightly. 

Felt by many people indoors, by a few outdoors. At night, 

IV. some people are awakened. Dishes, windows, and doors 

rattle. 

Felt by nearly everyone. Many people are awakened. 

V. Some dishes and windows are broken. Unstable objects 

are overturned. 

Felt by everyone. Many people become frightened and 

VI. run outdoors. Some heavy furniture is moved. Some 

plaster falls. 

Most people are alarmed and run outside. Damage is 

VII. negligible in buildings of good construction, considerable 

in buildings of poor construction. 

Damage is slight in specially designed structures, 

VIII. considerable in ordinary buildings, great in poorly built 

structures. Heavy furniture is overturned. 

Damage is considerable in specially designed buildings. 

IX. Buildings shift from their foundations and partly collapse. 

Underground pipes are broken. 

Some well-built wooden structures are destroyed. Most 

X. masonry structures are destroyed. The ground is badly 

cracked. Considerable landslides occur on steep slopes. 
Xl. Few, if any, masonry structures remain standing. Rails

are bent. Broad fissures appear in the ground.

XII. Virtually total destruction. Waves are seen on the ground surface. Objects are thrown into the air.

104 100

Figure 12D Felt area and Modified Mercalli Intensities

experienced by Texans from the magnitude 6.0 Valentine,

Texas, earthquake of 16 August, 1931. Dashed lines are

county boundaries; small square in south-central Texas

indicates region mapped in next figure.

29.0

Figure 1 2E: Felt area and Modified Mercallli

Intensities experienced by Texans from the magnitude 4.3

Fashing, Texas, earthquake of 9 April 1993. Dashed lines

are county boundaries; shaded regions indicate major oil

(dark shading) and gas (light shading) fields. Note how this

small earthquake is felt over a much smaller area than the

1931 magnitude 6.0 Valentine earthquake.

2B5,

Few, if any, masonry structures remain standing. Rails 

XI. are bent. Broad fissures appear in the ground. 

Virtually total destruction. Waves are seen on the ground 

XII. surface. Objects are thrown into the air. 

figure 1210 Felt area and Modified Mercalli Intensities 

experienced by Texans from the magnitude 6.0 Valentine, 

Texas, earthquake of 16 August, 1931. Dashed lines are 32 

county boundaries; small square in south-central Texas 

indicates region mapped in next figure. 

108 

1(}4- 100 

36 

32 

23 

104 100 98 

figure 1211:: Felt area and Modified Mercailli . 

Intensities experienced by Texans from the magnitude 4.3 

Fashing, Texas, earthquake of 9 April 1993. Dashed lines 

are county boundaries; shaded regions indicate major oil 

(dark shading) and gas (light shading) fields. Note how this 

small earthquake is felt over a much smaller area than the 

1931 magnitude 6.0 Valentine earthquake. 
Figure 12F

Relationship Between Earthquake Magnitude and Maximum Observed Modified

Mercalli Intensity (MMI).

Magnitude Maximum MMI

3.0

3.5

4.0

4.5

5.0

5.5

6.0

Ill-IV

IV-V

VIVI

V-Vl

VI

VI-Vll

VIII

Note that the table values are only approximate, as there is great variation for individual Texas earthquakes.

Approximate Relationship Between Earthquake's Magnitude and the Diameter

of and Slip Along the Fault that Produces It.

Magnitude

8

7

.6

5

4

3

2

1

Fault Diameter

45 miles

15 miles

4.5 miles

1.5 miles

800 yards

800 feet

240 feet

80 feet

Fault Slip

20 feet

7 feet

2 feet

8 inches

2.5 inches

1 inch

.25 inch

.1 inch

The Cause of Earthquakes

Just as changes in temperature or moisture content can produce cracks in the ground, various ongoing natural processes "

)roduce stresses that occasionally cause the underlying rock material to break or shift in an earthquake. Rock material is

-nost likely to break where it is highly stressed or where it has broken before, as along a preexisting fault. Earthquakes are

hnost common along very large, well-developed faults (such as the San Andreas Fault in California) which divide the Earth into

iuge, country-sized, relatively stable regions, called tectonic plates. The majority of the world's earthquakes, such as most

-eported in Mexico, California, Alaska, and Japan, occur along plate boundaries.

-lowever, not all earthquakes occur at plate boundaries; in regions like Texas many also occur far away from plate boundary

raults. Sometimes these 'plate interior' earthquakes are quite large; for example, in 1811-1812 three earthquakes with

-nagnitude above 8 occurred near the Missouri-Tennessee boundary (see Figure 12G). These quakes were as large as any

iistoric earthquakes that have occurred in California, or anywhere else in the U. S. outside of Alaska. While Texans haven't

2xperienced such large quakes in historic times, smaller quakes do occur naturally along faults in several regions of Texas.

Nhile all earthquakes occur on faults, not all faults have earthquakes. A fault is simply a fracture in rock material accompanied

)y displacement along the two sides of the fracture. If the displacement occurs slowly enough, no earthquake waves are

generated. And, often the displacement may have occurred millions of years ago, so that the fault remains but there is no

:resent earthquake threat. Finally, many faults go undiscovered because they lie far beneath the surface, covered by soil. It is

io accident that fault maps show the most faults in regions where bedrock is exposed at the surface (see Figure 12H).

-inally, some human activities are known to cause or trigger earthquakes. These include the injection of fluids into the earth

:or waste disposal or petroleum production, and the filling of deep lakes or reservoirs. In Texas, there have been earthquakes

Figure 12F 

Relationship Between Earthquake Magnitude and Maximum Observed Modified 

'Mercalli Intensity (MMI). 

Magnitude Maximum MMI 

3.0 III-IV 

3.5 IV-V 

4.0 V-VI 

4.5 V-VI 

5.0 VI 

5.5 VI-VII 

6.0 VIII 

Note that the table values are only approximate, as there is great variation for individual Texas earthquakes. 

Approximate Relationship Between Earthquake·s Magnitude and the Diameter 

of and Slip Along the Fault that Produces It. 

Magnitude Fault Diameter Fault Slip 

8 45 miles 20 feet 

7 15 miles 7 feet 

6 4.5 miles 2 feet 

5 1.5 miles 8 inches 

4 800 yards 2.5 inches 

3 800 feet 1 inch 

2 240 feet .25 inch 

80 feet .1 inch 

---~----~--¥ 

The Cause of Earthquakes 

Just as changes in temperature or moisture content can produce cracks in the ground, various ongoing natural processes 

Jroduce stresses that occasionally cause the underlying rock material to break or shift in an earthquake. Rock material is 

nost likely to break where it is highly stressed or where it has broken before, as along a preexisting fault. Earthquakes are 

nost common along very large, well-developed faults (such as the San Andreas Fault in California) which divide the Earth into 

luge, country-sized, relatively stable regions, called tectonic plates. The majority of the world's earthquakes, such as most 

-eported in Mexico, California, Alaska, and Japan, occur along plate boundaries. 

-lowever, not all earthquakes occur at plate boundaries; in regions like Texas many also occur far away from plate boundary 

:aults. Sometimes these 'plate interior' earthquakes are quite large; for example, in 1811-1812 three earthquakes with 

nagnitude above 8 occurred near the Missouri-Tennessee boundary (see Figure 12G). These quakes were as large as any 

listoric earthquakes that have occurred in California, or anywhere else in the U. S. outside of Alaska. While Texans haven't 

~xperienced such large quakes in historic times, smaller quakes do occur naturally along faults in several regions of Texas. 

Nhile all earthquakes occur on faults, not all faults have earthquakes. A fault is simply a fracture in rock material accompanied 

Jy displacement along the two sides of the fracture. If the displacement occurs slowly enough, no earthquake waves are 

~enerated. And, often the displacement may have occurred millions of years ago, so that the fault remains but there is no 

Jresent earthquake threat. Finally, many faults go undiscovered because they lie far beneath the surface, covered by soil. It is 

10 accident that fault maps show the most faults in regions where bedrock is exposed at the surface (see Figure 12H). 

=inally, some human activities are known to cause or trigger earthquakes. These include the inj~ction of fluids into the earth 

:or waste disposal or petroleum production, and the filling of deep lakes or reservoirs. In Texas, there have been earthquakes 
associated with oil and gas production at a number of fields. These include the Wortham field in Freestone County, the East

texas and Longview fields in Upshur and Gregg Counties, the Cogdell field in Scurry and Kent Counties, and the Fashing and

lourdanton fields in Atascosa County. None of these quakes have been very damaging or very large; the largest had

nagnitude 4.7. And, usually petroleum production does not cause earthquakes; in Texas there are more than two thousand oil

and gas fields but only about five seem to have generated earthquakes. Nevertheless, wherever there is considerable

Detroleum production, and especially when there is fluid injection to enhance recovery of to dispose of waste, people should

:e aware that induced earthquakes are possible.

35

Figure 1 2G Estimated felt area and Modified Mercalli Intensities for the

magnitude 8 Missouri-Tennessee earthquakes of 1811-1812. In much of Texas

there is greater earthquake hazard from rare, distant earthquakes such as these

than from any quakes with epicenters within Texas.

~35

30 30

Figure 1 2H. (Click on image to see full-size version.)

Assessing Earthquake Hazard

3ssociated with oil and gas production at a number of fields. These include the Wortham field in Freestone County, the East 

rexas and Longview fields in Upshur and Gregg Counties, the Cogdell field in Scurry and Kent Counties, and the Fashing and 

lourdanton fields in Atascosa County. None of these quakes have been very damaging or very large; the largest had 

nagnitude 4.7. And, usually petroleum production does not cause earthquakes; in Texas there are more than two thousand oil 

3nd gas fields but only about five seem to have generated earthquakes. Nevertheless, wherever there is considerable 

Jetroleum production, and especially when there is fluid injection to enhance recovery of to dispose of waste, people should 

Je aware that induced earthquakes are possible. 

Figure 12G Estimated felt area and Modified Mercalli Intensities for the 

magnitude 8 Missouri-Tennessee earthquakes of 1811-1812. In much ofTexas 

there is greater earthquake hazard from rare, distant earthquakes such as these 

than from any quakes with epicenters within Texas. 

Figure 12H. (Click on image to see full-size version.) 

A.ssessing Earthquake Hazard 
In any particular region, the level of earthquake hazard depends on many different factors. These include the size,

ocation, and frequency of earthquakes that may occur, as well as the population density, the topography, and the 4U.

iature of manmade improvements. In very steep, mountainous areas earthquakes might trigger landslides, for example. And,

3 nuclear power plant or waste disposal site might pose more potential hazard than a feed lot. For any particular earthquake

:he expected intensity also depends on the type of construction and the thickness and type of soil.

\Jevertheless, for any region the most important factor affecting scientific hazard estimation is the historical record of

2arthquake activity; regions which have had large earthquakes in the past will probably experience them again. Although

iazard estimates also include information about mapped faults, in practice this information isn't very influential since many

<nown faults are not seismically active, and since many damaging earthquakes have occurred on unmapped, unknown faults.

rhus, it is no accident that the regions of highest hazard in United States Geological Survey's (USGS) hazard analysis

:orrespond to the locations of known, large, historical earthquakes. In the central U. S., the USGS assesses the greatest

iazard in the Missouri-Tennessee area, where three earthquakes with magnitude of 8 or greater occurred in 1811 and 1812.

Jnfortunately, the very rarity of large earthquakes makes hazard analysis an inexact science. In the twentieth century, the

argest earthquake in the Missouri-Tennessee area only had a magnitude of about 5.5. If quakes like the 1811-1812 events

iad occurred in Texas a few hundred years ago, would scientists know that such large and damaging earthquakes were

)ossible here? Almost certainly not.

In Texas the regions at greatest risk are in West Texas, where earthquakes of magnitude about 6 occurred in 1931 and 1995,

3nd in the Panhandle, where at least six earthquakes with magnitude above 4 have occurred since 1900. Clearly, such

earthquakes will occur again. Unfortunately, what we cannot know is whether larger quakes--like the Missouri-Tennessee

quakes of 1811-1812--might possibly occur there. Geologically, some features of the Panhandle are similar to the MissouriFennessee area. Fortunately, large continental quakes are extraordinarily rare (occurring less often than once per 500 years in

3ny particular place), so for many Texans there is little reason to make special preparations for them. But, Texans should be

3ware that they are remotely possible.

Nhy is there concern about Texas earthquakes, given that historical events have done little damage? One reason is that the

:requency of small and large earthquakes are related in a predictable way-a rule of thumb called the Gutenberg-Richter

-elation states that for every 1000 magnitude 4 earthquakes there will be approximately 100 magnitude 5 events, 10

nagnitude 6 event, and one magnitude 7 event. Thus, the occurrence of two earthquakes with magnitude near 6 in the

-wentieth century suggests that a magnitude 7 may occur every few hundred years or so. Like many other rules of thumb, the

,redictions of the Gutenberg-Richter relation aren't always correct. For example, transportation experts use rules of thumb to

)redict the number of auto fatalities during a holiday weekend; these may be incorrect because of the influence of

inpredictable factors such as weather, safety campaigns, etc. Similarly, the predictions of the Gutenberg-Richter relation may

:e incorrect because of factors that scientists don't understand or didn't consider. Yet, the record indicates that magnitude 6

quakes do happen in Texas, and suggests that larger earthquakes are possible. These could be especially serious if they

)ccurred near a major population center.

-inally, there is some risk to Texans from earthquakes that may occur outside of Texas. If the 1811-1812 Missouri-Tennessee

earthquakes were to occur today, in the Dallas-Fort Worth area they would probably damage some structures that weren't

Jesigned to withstand earthquakes. There is also possible hazard to Texans in the Panhandle from earthquakes which may

)ccur in Oklahoma.

:ertain earthquake-related phenomena which affect some parts of the U. S. do not pose a hazard for Texans. These include:

" Liquefaction: For large buildings constructed on certain poorly consolidated soils, strong earthquake tremors can cause the soil to 'liquefy', producing

severe damage to large and apparently well-build structures. This is most common for structures built on landfill in lake or ocean regions. In Texas, the

regions along the Gulf Coast where this conceivably might occur are not subject to strong earthquake tremors.

" Tsunamis: Tsunamis are tidal waves generated when undersea earthquakes displace the sea surface or when extraordinarily large landslides dump large

volumes of material into the ocean. There is no historic record of any such events doing significant damage along the Gulf Coast.

* Volcanoes: Volcanic eruptions may produce ash falls over regions extending hundreds of miles from the eruption site. However, no active or dormant

volcanoes occur near Texas, and Mexican volcanoes are too far away to be hazardous to Texans.

Where is the Hazard Greatest?

lhere is an old saying among seismologists: "Earthquakes don't kill people, buildings kill people." This is because the i

-nost serious damage caused by nearby earthquakes often comes when heavy, unreinforced structures collapse. Adobe

3nd unreinforced masonry can be particularly dangerous, even in earthquakes with magnitudes as small as 5 or less. Ordinary

Nood-frame dwellings are surprisingly earthquake-resistant; in such structures the most serious damage often results from

[n any particular region, the level of earthquake hazard depends on many different factors. These include the size, 

ocation, and frequency of earthquakes that may occur, as well as the population density, the topography, and the 

lature of manmade improvements. In very steep, mountainous areas earthquakes might trigger landslides, for example. And, 

3 nuclear power plant or waste disposal site might pose more potential hazard than a feed lot. For any particular earthquake 

:he expected intensity also depends on the type of construction and the thickness and type of soil. 

\Jevertheless, for any region the most important factor affecting scientific hazard estimation is the historical record of 

:arthquake activity; regions which have had large earthquakes in the past will probably experience them again. Although 

lazard estimates also include information about mapped faults, in practice this information isn't very influential since many 

mown faults are not seismically active, and since many damaging earthquakes have occurred on unmapped, unknown faults. 

rhus, it is no accident that the regions of highest hazard in United States Geological Survey's (USGS) hazard analysis 

:orrespond to the locations of known, large, historical earthquakes. In the central U. S., the USGS assesses the greatest 

lazard in the Missouri-Tennessee area, where three earthquakes with magnitude of 8 or greater occurred in 1811 and 1812. 

Jnfortunately, the very rarity of large earthquakes makes hazard analysis an inexact science. In the twentieth century, the 

argest earthquake in the Missouri-Tennessee area only had a magnitude of about 5.5. If quakes like the 1811-1812 events 

lad occurred in Texas a few hundred years ago, would scientists know that such large and damaging earthquakes were 

Jossible here? Almost certainly not. 

[n Texas the regions at greatest risk are in West Texas, where earthquakes of magnitude about 6 occurred in 1931 and 1995, 

3nd in the Panhandle, where at least six earthquakes with magnitude above 4 have occurred since 1900. Clearly, such 

:arthquakes will occur again. Unfortunately, what we cannot know is whether larger quakes--like the Missouri-Tennessee 

~uakes of 1811-1812--might possibly occur there. Geologically, some features of the Panhandle are similar to the Missourirennessee area. Fortunately, large continental quakes are extraordinarily rare (occurring less often than once per 500 years in 

3ny particular place), so for many Texans there is little reason to make special preparations for them. But, Texans should be 

3ware that they are remotely possible. 

Nhy is there concern about Texas earthquakes, given that historical events have done little damage? One reason is that the 

:requency of small and large earthquakes are related in a predictable way-a rule of thumb called the Gutenberg-Richter 

-elation states that for every 1000 magnitude 4 earthquakes there will be approximately 100 magnitude 5 events, 10 

llagnitude 6 event, and one magnitude 7 event. Thus, the occurrence of two earthquakes with magnitude near 6 in the 

:wentieth century suggests that a magnitude 7 may occur every few hundred years or so. Like many other rules of thumb, the 

Jredictions of the Gutenberg-Richter relation aren't always correct. For example, transportation experts use rules of thumb to 

Jredict the number of auto fatalities during a holiday weekend; these may be incorrect because of the influence of 

Jnpredictable factors such as weather, safety campaigns, etc. Similarly, the predictions of the Gutenberg-Richter relation may 

Je incorrect because of factors that scientists don't understand or didn't consider. Yet, the record indicates that magnitude 6 

~uakes do happen in Texas, and suggests that larger earthquakes are possible. These could be especially serious if they 

Jecurred near a major population center. 

=inally, there is some risk to Texans from earthquakes that may occur outside of Texas. If the 1811-1812 Missouri-Tennessee 

:arthquakes were to occur today, in the Dallas-Fort Worth area they would probably damage some structures that weren't 

jesigned to withstand earthquakes. There is also possible hazard to Texans in the Panhandle from earthquakes which may 

Jecur in Oklahoma. 

:ertain earthquake-related phenomena which affect some parts of the U. S. do not pose a hazard for Texans. These include: 

• Liquefaction: For large buildings constructed on certain poorly consolidated soils, strong earthquake tremors can cause the soil to 'liquefy', producing 

severe damage to large and apparently well-build structures. This is most common for structures built on landfill in lake or ocean regions. In Texas, the 

. regions along the Gulf Coast where this conceivably might occur are not subject to strong earthquake tremors. 

• Tsunamis: Tsunamis are tidal waves generated when undersea earthquakes displace the sea surface or when extraordinarily large landslides dump large 

volumes of material into the ocean. There is no historic record of any such events doing significant damage along the Gulf Coast. 

• Volcanoes: Volcanic eruptions may produce ash falls over regions extending hundreds of miles from the eruption site. However, no active or dormant 

volcanoes occur near Texas, and Mexican volcanoes are too far away to be hazardous to Texans. 

Where is the Hazard Greatest? 

rhere is an old saying among seismologists: "Earthquakes don't kill people, buildings kill people." This is because the 

110St serious damage caused by nearby earthquakes often comes when heavy, unreinforced structures collapse. Adobe 

3nd unreinforced masonry can be particularly dangerous, even in earthquakes with magnitudes as small as 5 or less. Ordinary 

Nood-frame dwellings are surprisingly earthquake-resistant; in such structures the most serious damage often results from 
:he collapse of chimneys.

In the twentieth century hundreds of man-made lakes and reservoirs have been constructed in Texas; in some cases these

)ose a special hazard, particularly if there are population centers downstream. Large very distant earthquakes sometimes

iave surprising low-frequency effects. Seismic waves from the 1964 Alaskan earthquake, with a magnitude of 9.2, caused

3loshing in canals and rivers in Texas which damaged boats and docks. Earthen or earth-filled dams are of special concern

3ince intense shaking or sloshing could cause dam failure.

Monitoring Earthquakes as a Mitigation Strategy

It is important to remember that our knowledge of both past and present seismic activity in Texas is inc6mplete. Unlike

states along the east and west coast, much of Texas is sparsely populated and/or was only settled about a century ago.

,nd, even today Texas has only a few continuously recording seismograph stations (see Figure 12-I). This means that we

iave a much poorer knowledge of the earthquake hazard in Texas than in most other states. With the population of Texas

expanding rapidly, the potential for injury to people and damage to structures increases proportionately. To be effective,

attempts to assess potential risk must be based on long-term monitoring of seismic activity, so for accurate assessments we

-nust take steps today to ensure that adequate monitoring is performed.

Dver the past twenty years, there has been a revolution is the technology to monitor earthquakes. In the past, seismographs

-ecorded on paper or film, and were designed specifically to measure earthquake waves from events of a particular size in a

)articular, narrow frequency band. The equipment at these 'narrowband' stations had to be selected to be optimum for

mneasuring signals either from small nearby earthquakes (e.g., magnitude 3.5 earthquakes occurring within a few hundred

<m) or from large distant earthquakes (e.g., a magnitude 7.0 earthquake in Japan). Nowadays, so-called 'broadband' stations

-ecord digital information over a broad range of frequencies, and thus obtain information about both nearby and distant

2arthquakes. These broadband stations are advantageous because the data is useful both for regional hazard analysis as well

-or research by scientists throughout the world. For a state like Texas, a broadband network is desirable because it is useful

.or hazard assessment within Texas and for scientific researchers outside of Texas; over the long term this means that part of

:he support to run the network may come from science organizations outside of Texas.

Dresently, Texas has only two modern, broadband seismograph stations, one near Houston, and one in Brewster County in

Nest Texas (see Figure 121). In addition, there are several narrowband stations in operation near El Paso. To properly monitor

Texas earthquakes with magnitude of 3.5 and greater will require about ten additional stations. Currently various

Drganizations within Texas-including university scientists, emergency management personnel, and people concerned with dam

3afety-have begun to work towards making such a network a reality; however, at present its future is still uncertain.

.4.~ ~ 11W .0 -OW~ 4W ~

Stt

Figure 121 Nominal monitoring capability for magnitude 3.5 events for . 1k

for existing stations (dark shading and proposed stations (light shading).,9 8 *

Click on map to see full-size figure.

:he collapse of chimneys. 

[n the twentieth century hundreds of man-made lakes and reservoirs have been constructed in Texas; in some cases these 

Jose a special hazard, particularly if there are population centers downstream. Large very distant earthquakes sometimes 

lave surprising low-frequency effects. Seismic waves from the 1964 Alaskan earthquake, with a magnitude of 9.2, caused 

,Ioshing in canals and rivers in Texas which damaged boats and docks. Earthen or earth-filled dams are of special concern 

,ince intense shaking or sloshing could cause dam failure. 

Monitoring Earthquakes as a Mitigation Strategy 

[t is important to remember that our knowledge of both past and present seismic activity in Texas is incomplete. Unlike 

,tates along the east and west coast, much of Texas is sparsely populated and/or was only settled about a century ago. 

!\nd, even today Texas has only a few continuously recording seismograph stations (see Figure 12-1). This means that we 

lave a much poorer knowledge of the earthquake hazard in Texas than in most other states. With the population of Texas 

~xpanding rapidly, the potential for injury to people and damage to structures increases proportionately. To be effective, 

3ttempts to assess potential risk must be based on long-term monitoring of seismic activity, so for accurate assessments we 

llUSt take steps today to ensure that adequate monitoring is performed. 

)ver the past twenty years, there has been a revolution is the technology to monitor earthquakes. In the past, seismographs 

-ecorded on paper or film, and were designed specifically to measure earthquake waves from events of a particular size in a 

Jarticular, narrow frequency band. The equipment at these 'narrowband' stations had to be selected to be optimum for 

lleasuring signals either from small nearby earthquakes (e.g., magnitude 3.5 earthquakes occurring within a few hundred 

<m) or from large distant earthquakes (e.g., a magnitude 7.0 earthquake in Japan). Nowadays, so-called 'broadband' stations 

-ecord digital information over a broad range of frequencies, and thus obtain information about both nearby and distant 

~arthquakes. These broadband stations are advantageous because the data is useful both for regional hazard analysis as well 

:or research by scientists throughout the world. For a state like Texas, a broadband network is desirable because it is useful 

:or hazard assessment within Texas and for scientific researchers outside of Texas; over the long term this means that part of 

:he support to run the network may come from science organizations outside of Texas. 

Jresently, Texas has only two modern, broadband seismograph stations, one near Houston, and one in Brewster County in 

Nest Texas (see Figure 121). In addition, there are several narrowband stations in operation near EI Paso. To properly monitor 

rexas earthquakes with magnitude of 3.5 and greater will require about ten additional stations. Currently various 

xganizations within Texas-including university scientists, emergency management personnel, and people concerned with dam 

,afety-have begun to work towards making such a network a reality; however, at present its future is still uncertain. 

figure 12i Nominal monitoring capability for magnitude 3.5 events for 

for existing stations (dark shading and proposed stations (light shading). 

Click on map to see full-size figure. 

-----------
Regional Hazard Assessment

West Texas (Largest City - El Paso) I

:ounties Affected (22): Andrews, Brewster, Crane, Culberson, Dawson, Ector, El Paso, Gaines, Hudspeth, Jeff Davis, Kent,

_oving, Martin, Midland, Pecos, Presidio, Reeves, Scurry, Terrell, Upton, Ward, Winkler.

-lazard Level: Within this region several earthquakes with magnitudes 5 to 6 will probably occur each century. Moreover, the

iistorical earthquake record and regional geology suggest that even larger earthquakes are possible, with a probability of

)erhaps once per 500 years. In most of this region population density is low and earthquakes only pose a significant hazard

:or poorly built or very sensitive structures. However, an earthquake with magnitude of 5.5 or greater that occurred close to El

•aso would cause personal injury and significant economic losses. Also, people who live, work, or plan to build in hilly or

-nountainous places should be aware that historical earthquakes have produced landslides in various parts of this region.

Justification: Historical earthquakes have produced Modified Mercalli Intensities of VI and higher throughout this region.

Significant Historic Earthquakes Affecting West Texas

" There have been three historic earthquakes which have each been felt over all or a significant part of West Texas.

" The first, which occurred on 16 August 1931 and was centered near Valentine, had a magnitude of 6.0. Even though many buildings in Valentine were

constructed of adobe and brick and thus damaged severely, few were injured, probably because most people were sleeping outdoors because of the heat.

* The second, which occurred on 2 January.1992 along the Texas-New Mexico border near Andrews and Hobbs, had a magnitude of 4.6 (see Figure 12WA).

" The third, which occurred on 14 April 1995 near Alpine, had a magnitude of 5.7. Both the 1931 and the 1995 earthquake produced landslides in

mountainous areas. The amount of injury and damage from the 1931 and 1995 earthquakes was relatively small, mostly because of the relatively low

population density in West Texas.

" In addition, earthquakes with magnitudes between 3 and 4.7 were felt by El Paso residents in 1889, 1923, 1936, 1937, 1969, and 1972. Finally, a

magnitude 4.6 earthquake, probably induced by oil production, occurred in Scurry County near Snyder, Texas, in 1978.

Nhy is there such concern about earthquake hazard in West Texas? The occurrence of two magnitude 6 earthquakes in the

:wentieth century suggests that a magnitude 7 may occur every few hundred years or so. And, the record indicates that

iiagnitude 6 quakes are likely to happen within the lifetime of ordinary citizens.

106 106 104- 103 102 101

Figure 1 2W-A Areas in West Texas which experienced Modified 32 32

Mercalli Intensities of IV or V (light gray) and VI (dark gray) during the

earthquakes of 16 June 1978 (near Snyder in Scurry County - curved line

indicates intensity V region for this quake), 2 January 1992 (near Andrews

County - New Mexico border) or 14 April 1995 (near Alpine in Brewster 31 r1

County). Also, almost the entire area shown experienced intensities of VI .

during the earthquake of 16 August 1931.

29 21 29g

..... .....

Regional Hazard Assessment 

West Texas (Largest City - EI Paso) 

:ounties Affected (22): Andrews, Brewster, Crane, Culberson, Dawson, Ector, EI Paso, Gaines, Hudspeth, Jeff Davis, Kent, 

_oving, Martin, Midland, Pecos, Presidio, Reeves, Scurry, Terrell, Upton, Ward, Winkler. 

-lazard Level: Within this region several earthquakes with magnitudes 5 to 6 will probably occur each century. Moreover, the 

listorical earthquake record and regional geology suggest that even larger earthquakes are possible, with a probability of 

Jerhaps once per 500 years. In most of this region population density is low and earthquakes only pose a significant hazard 

:or poorly built or very sensitive structures. However, an earthquake with magnitude of 5.5 or greater that occurred close to EI 

)aso would cause personal injury and significant ecpnomic losses. Also, people who live, work, or plan to build in hilly or 

nountainous places should be aware that historical earthquakes have produced landslides in various parts of this region. 

Justification: Historical earthquakes have produced Modified Mercalli Intensities of VI and higher throughout this region. 

Significant Historic Earthquakes Affecting West Texas 

• There have been three historic earthquakes which have each been felt over all or a significant part of West Texas. 

• The first, which occurred on 16 August 1931 and was centered near Valentine, had a magnitude of 6.0. Even though many buildings in Valentine were 

constructed of adobe and brick and thus damaged severely, few were injured, probably because most people were sleeping outdoors because of the heat. 

• The second, which occurred on 2 January 1992 along the Texas-New Mexico border near Andrews and Hobbs, had a magnitude of 4.6 (see Figure 12WA). 

• The third, which occurred on 14 April 1995 near Alpine, had a magnitude of 5.7. Both the 1931 and the 1995 earthquake produced landslides in 

mountainous areas. The amount of injury and damage from the 1931 and 1995 earthquakes was relatively small, mostly because of the relatively low 

population density in West Texas. 

• In addition, earthquakes with magnitudes between 3 and 4.7 were felt by EI Paso residents in 1889, 1923, 1936, 1937, 1969, and 1972. Finally, a 

magnitude 4.6 earthquake, probably induced by oil production, occurred in Scurry County near Snyder, Texas, in 1978. 

Nhy is there such concern about earthquake hazard in West Texas? The occurrence of two magnitude 6 earthquakes in the 

:wentieth century suggests that a magnitude 7 may occur every few hundred years or so. And, the record indicates that 

nagnitude 6 quakes are likely to happen within the lifetime of ordinary citizens. 

33 

fig'ure 12W-A Areas in West Texas which experienced Modified 32 

Mercalli Intensities of IV or V (light gray) and VI (dark gray) during the 

earthquakes of 16 June 1978 (near Snyder in Scurry County - curved line 

indicates intensity V region for this quake), 2 January 1992 (near Andrews 

County - New Mexico border) or 14 April 1995 (near Alpine in Brewster 31 

County). Also, almost the entire area shown experienced intensities of VI 

during the earthquake of 16 August 1931. 

106 

r 

lOS 

tOO 104 

tOO 104 103 10:2 101 . \ ..... ~''' .. " ... ~. .. , 
Figure I 2P-A Areas in the Panhandle which experienced

Modified Mercalli Intensities of V (light gray) and VI (dark gray)

during the earthquakes of 1925 and 1936 (near Borger, in

Hutchison County), 1948 (near Dalhart, in Dallam County), 1952

(in Oklahoma), or 1974 (near Perryton, in Ochiltree County -

curved line indicates intensity V region for this quake).

, Iil ..... ........ ....

Mitigation Strategy

" Architects and planners should be informed that damaging earthquakes can affect structures in the Panhandle. Sensitive structures-including dams,

towers, very tall buildings, bridges, and highway overpasses-should be constructed with the possibility of earthquakes in mind. Institutions such as

hospitals, schools, public meeting places, emergency management organizations, etc. should not be housed in poorly constructed, unreinforced masonry

structures.

" Public officials and educators should inform Panhandle residents that earthquakes can and do occur in this region. Citizens should be encouraged to plan

for earthquakes; this includes taking steps at home and in the office to mitigate possible injury caused by falling objects such as bookcases or chimneys.

" Citizens should be aware that it is possible that some Panhandle earthquakes are induced by petroleum production.

rable of Texas Panhandle Earthquakes of Magnitude 3 or Greater

Regional Hazard Assessment

Northeast Texas (Largest Cities - Dallas-Fort Worth) I

-ounties Affected (41): Anderson, Bowie, Camp, Cass, Cherokee, Collin, Cooke, Dallas, Delta, Denton, Fannin, Franklin, --reestone, Grayson, Gregg, Harrison, Henderson, Hopkins, Hunt, Kaufman, Lamar, Limestone, Marion, Montague, Morris,

NJacogdoches, Panola, Rains, Red River, Rockwall, Rusk, Sabine, San Augustine, Shelby, Smith, Tarrant, Titus, Upshur, Van

Zandt, Wood, Wise

-lazard Level: This region is at risk from very large, distant earthquakes which might occur in Missouri-Tennessee or

Dklahoma; the earthquakes that pose such a hazard are rare, probably occurring only once per 500 years or less. Such distant

2arthquakes would be most likely to damage large buildings or poorly reinforced masonry structures. Earthquakes with

epicenters within this region are rare and small (see Figure 12N-A); several earthquakes with magnitudes 3 to 4.5 will

)robably occur each century. These pose little or no risk unless their epicenters are extremely close to poorly built or very

3ensitive structures.

Justification: Throughout this region the 1811-1812 Missouri-Tennessee earthquakes, although distant, probably produced

figure 121P-A Areas in the Panhandle which experienced 

Modified Mercalli Intensities of V (light gray) and VI (dark gray) 

during the earthquakes of 1925 and 1936 (near Borger, in 

Hutchison County), 1948 (near Dalhart, in Dallam County), 1952 

(in Oklahoma), or 1974 (near Perryton, in Ochiltree Countycurved line indicates intensity V region for this quake). 

Mitigation Strategy 

• Architects and planners should be informed that damaging earthquakes can affect structures in the Panhandle. Sensitive structures-including dams, 

towers, very tall buildings, bridges, and highway overpasses-should be constructed with the possibility of earthquakes in mind. Institutions such as 

hospitals, schools, public meeting places, emergency management organizations, etc. should not be housed in poorly constructed, unreinforced masonry 

structures. 

• Public officials and educators should inform Panhandle residents that earthquakes can and do occur in this region. Citizens should be encouraged to plan 

for earthquakes; this includes taking steps at home and in the office to mitigate possible injury caused by falling objects such as bookcases or chimneys. 

• Citizens should be aware that it is possible that some Panhandle earthquakes are induced by petroleum production. 

rable of Texas Panhandle Earthquakes of Magnitude 3 or Greater 

Regional Hazard Assessment 

Northeast Texas (Largest Cities - Dallas-Fort Worth) 

:ounties Affected (41): Anderson, Bowie, Camp, Cass, Cherokee, Collin, Cooke, Dallas, Delta, Denton, Fannin, Franklin, 

=reestone, Grayson, Gregg, Harrison, Henderson, Hopkins, Hunt, Kaufman, Lamar, Limestone, Marion, Montague, MorriS, 

\lacogdoches, Panola, Rains, Red River, Rockwall, Rusk, Sabine, San Augustine, Shelby, Smith, Tarrant, Titus, Upshur, Van 

Z:andt, Wood, Wise 

-iazard Level: This region is at risk from very large, distant earthquakes which might occur in Missouri-Tennessee or 

Jklahoma; the earthquakes that pose such a hazard are rare, probably occurring only once per 500 years or less. Such distant 

:!arthquakes would be most likely to damage large buildings or poorly reinforced masonry structures. Earthquakes with 

:!picenters within this region are rare and small (see Figure 12N-A); several earthquakes with magnitudes 3 to 4.5 will 

Jrobably occur each century. These pose little or no risk unless their epicenters are extremely close to poorly built or very 

;ensitive structures. 

Justification: Throughout this region the 1811-1812 Missouri-Tennessee earthquakes, although distant, probably produced 
Vlodified Mercalli Intensities of VI and higher.

Significant Historic Earthquakes Affecting Northeast Texas

Fhroughout most of this region, the most intense shaking experienced over the past two centuries originated from several

earthquakes with magnitude about 8 which occurred in Missouri-Tennessee in 1811-1812, or an earthquake with magnitude

3.6 which occurred in eastern Oklahoma in 1882. Although such distant earthquakes are unlikely to produce severe damage

:hey can cause failure in very large structures, or structures which are designed with absolutely no earthquake-resistant :eatures.

3mall earthquakes with epicenters in this region occasionally do occur-some of natural origin and some apparently induced by

)etroleum production. These include:

" A magnitude 4.0 earthquake with an epicenter near Mexia, probably induced by oil production, that occurred on 9 April 1932.

" A magnitude 4.2 earthquake centered in Lamar County north of Paris that occurred on 12 April 1934.

" A magnitude 3.0 earthquake that occurred in Gregg County near Gladewater on 19 March 1957. This quake may have been induced by petroleum

production in the East Texas Field.

" A series of earthquakes in 1964 with magnitudes of 4.0 and higher near Hemphill-Pineland in Sabine County.

98 94

34

Figure 1 2N-A: Felt areas of representative historical

earthquakes in northeastern Texas. Shaded regions indicate

areas of intensity V and above for earthquakes of 1932

(Limestone County), 1934 (northern Lamar County), 1957 (Gregg

County), and 1964 (Sabine County). Thick lines indicate

estimated boundaries of Modified Mercalli Intensities for the 1811-

1812 Missouri-Tennessee earthquakes.

32

94

" A magnitude 3.3 earthquake centered near Jacksonville in Cherokee County, which occurred on 6 November 1981.

" A magnitude 3.3 earthquake in Cooke and Denton County near Pilot Point an Valley View; this occurred on 18 September 1985.

* A magnitude 3.4 earthquake centered near Commerce in Hunt County; this occurred on 31 May 1997.

-vents of these magnitudes seldom produce damage further than about a few miles from the epicenter.

Mitigation Strategy

" Architects and planners should be informed that distant earthquakes can affect large and sensitive structures in the northeastern Texas. Sensitive

structures-including dams, towers, very tall buildings, bridges, and highway overpasses-should be constructed with the possibility of earthquakes in mind.

" Residents should understand that small earthquakes occasionally do occur in this region, including some induced by petroleum production. They should be

informed that the principal hazard is from rare, distant, but very large earthquakes occurring outside of Texas.

lIlodified Mercalli Intensities of VI and higher. 

Significant Historic Earthquakes Affecting Northeast Texas 

rhroughout most of this region, the most intense shaking experienced over the past two centuries originated from several 

O!arthquakes with magnitude about 8 which occurred in Missouri-Tennessee in 1811-1812, or an earthquake with magnitude 

5.6 which occurred in eastern Oklahoma in 1882. Although such distant earthquakes are unlikely to produce severe damage 

:hey can cause failure in very large structures, or structures which are designed with absolutely no earthquake-resistant 

:eatures. . 

:;mall earthquakes with epicenters in this region occasionally do occur-some of natural origin and some apparently induced by 

)etroleum production. These include: 

34 

• A magnitude 4.0 earthquake with an epicenter near Mexia, probably induced by oil production, that occurred on 9 April 1932. 

• A magnitude 4.2 earthquake centered in Lamar County north of Paris that occurred on 12 April 1934. 

• A magnitude 3.0 earthquake that occurred in Gregg County near Gladewater on 19 March 1957. This quake may have been induced by petroleum 

production in the East Texas Field. 

• A series of earthquakes in 1964 with magnitudes of 4.0 and higher near Hemphill-Pineland in Sabine County. 

98 

98 

96 94 

VII 34 

.32 

94 

figure 12N-A: Felt areas of representative historical 

earthquakes in northeastern Texas. Shaded regions indicate 

areas of intensity V and above for earthquakes of 1932 

(Limestone County), 1934 (northern Lamar County), 1957 (Gregg 

County), and 1964 (Sabine County). Thick lines indicate 

estimated boundaries of Modified Mercalli Intensities for the 1811-

1812 Missouri-Tennessee earthquakes . 

• A magnitude 3.3 earthquake centered near Jacksonville in Cherokee County, which occurred on 6 November 1981. 

• A magnitude 3.3 earthquake in Cooke and Denton County near Pilot Point an Valley View; this occurred on 18 September 1985. 

• A magnitude 3.4 earthquake centered near Commerce in Hunt County; this occurred on 31 May 1997. 

:vents of these magnitudes seldom produce damage further than about a few miles from the epicenter. 

Mitigation Strategy 

• Architects and planners should be informed that distant earthquakes can affect large and sensitive structures in the northeastern Texas. Sensitive 

structures-including dams, towers, very tall buildings, bridges, and highway overpasses-should be constructed with the possibility of earthquakes in mind. 

• Residents should understand that small earthquakes occasionally do occur in this region, including some induced by petroleum production. They should be 

informed that the principal hazard is from rare, distant, but very large earthquakes occurring outside of Texas. 
rable of Northeast Texas Earthquakes of Magnitude 3 or Greater

Regional Hazard Assessment

South-Central Texas (Largest City - San Antonio)

:ounties Included (19): Atascosa, Bastrop, Bexar, Brazos, Burleson, Caldwell, Comal, Gaudelupe, Grimes, Hayes, Jim Wells,

<ames, Lavaca, Lee, Live Oak, Travis, Waller, Washington, Wilson

-lazard Level: Earthquakes with epicenters within this region are rare and small; perhaps 10-20 earthquakes with magnitudes

Detween 3 and 4.5 will occur each century. A significant fraction of these earthquakes are induced by human activities,

iotably petroleum production. These events pose little or no risk unless their foci are extremely close to poorly built or very

3ensitive structures.

lustification: Many small earthquakes, some of natural origin and others induced by man's activities, have occurred in these

-ounties.

Significant Historic or Induced Earthquakes Affecting This Region

3mall earthquakes with epicenters in this region occasionally do occur-some of natural origin and some apparently induced by

Detroleum production (see Figure 12S-A). These include:

" A magnitude 3.9 earthquake centered in Travis County south of Austin which occurred on 9 October 1902. This earthquake is clearly of natural origin.

" A magnitude 4.2 earthquake near Fashing in Atascosa County on 9 April 1993. This earthquake is one of several in this region which may have been

induced by petroleum production.

" A magnitude 3.8 earthquake near Alice in Jim Wells County which occurred on 24 March 1997. This earthquake may have been induced by petroleum

production.

Mitigation Strategy

* Residents of this region should understand that small natural earthquakes occasionally do occur in this region. However, the most numerous earthquakes

are small events associated with petroleum production in some, but not all fields. These small earthquakes pose a hazard only in the immediate vicinity of

their epicenter; the occurrence of significantly larger earthquakes is unlikely.

Figure 1 2S-A: Felt areas of representative historical

earthquakes in South-Central Texas. Shaded regions indicate

areas of intensity IV and above for earthquakes of 1887 (Bastrop

County), 1902 (Travis County), 1910 (Waller County), 1993

(Atascosa County), and 1997 (Jim Wells County).

rable of Northeast Texas Earthquakes of Magnitude 3 or Greater 

Regional Hazard Assessment 

South~Central Texas (Largest City - San Antonio) 

:ounties Included (19): Atascosa, Bastrop, Bexar, Brazos, Burleson, Caldwell, Comal, Gaudelupe, Grimes, Hayes, Jim Wells, 

<arnes, Lavaca, Lee, Live Oak, Travis, Waller, Washington, Wilson 

-tazard Level: Earthquakes with epicenters within this region are rare and small; perhaps 10-20 earthquakes with magnitudes 

Jetween 3 and 4.5 will occur each century. A significant fraction of these earthquakes are induced by human activities, 

lotably petroleum production. These events pose little or no risk unless their foci are extremely close to poorly built or very 

,ensitive structures. 

Justification: Many small earthquakes, some of natural origin and others induced by man's activities, have occurred in these 

:ounties. 

Significant Historic or Induced Earthquakes Affecting This Region 

;mall earthquakes with epicenters in this region occasionally do occur-some of natural origin and some apparently induced by 

Jetroleum production (see Figure 12S-A). These include: 

• A magnitude 3.9 earthquake centered in Travis County south of Austin which occurred on 9 October 1902. This earthquake is clearly of natural origin. 

• A magnitude 4.2 earthquake near Fashing in Atascosa County on 9 April 1993. This earthquake is one of several in this region which may have been 

induced by petroleum production. 

• A magnitude 3.8 earthquake near Alice in Jim Wells County which occurred on 24 March 1997. This earthquake may have been induced by petroleum 

production. 

Mitigation Strategy 

• Residents of this region should understand that small natural earthquakes occasionally do occur in this region. However, the most numerous earthquakes 

are small events associated with petroleum production in some, but not all fields. These small earthquakes pose a hazard only in the immediate vicinity of 

their epicenter; the occurrence of Significantly larger earthquakes is unlikely. 

Figure 12S~A: Felt areas of representative historical 

earthquakes in South-Central Texas. Shaded regions indicate 

areas of intensity IV and above for earthquakes of 1887 (Bastrop 

County), 1902 (Travis County), 1910 (Waller County), 1993 

(Atascosa County), and 1997 (Jim Wells County). 
I I • .. -

L'.s Oak *

2 1997. ..... ' Gulf of 19 7 '-, 2 ,a." ac t/1 -.

Mexico

rable of South-Central Texas Earthquakes of Magnitude 3 or Greater

To TOP

Fo COMPENDIUM OF TEXAS EARTHQUAKES

re EARTHQUAKE SEISMOLOGY

nstitute for Geophysics; J.J. Pickle Research Campus, Bldg. 196; 10100 Burnet Rad (R 2200; A•tn TX 78758-4445

Phone, (512) 471-6156; FAX- (512) 471-8844

Last rrdified: 01 Feb 2002 15:53

@2006 Jackson Scooý of Geosriences, The University of Texas at Austin

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rable of South-Central Texas Earthquakes of Magnitude 3 or Greater 

ro TOP 

ro COMPENDIUM OF TEXAS EARTHQUAKES 

ro EARTHQUAKE SEISMOLOGY 

1:l7 "){" 

.,. -'" i /' I / :., r!\~ ('~n<l 

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f1stih.llte for Geophysics; J.J. Pickle Research Campus, Bldg. 196; 10100 Burnet Road (R2200); Austin TX 18158-4445 

Phone: {512} 411·6156; fAX: (512) 411·8844 

last rnodified: 01 Feb 2002 1553 

©2006 Jackson SCllOO! of Geosciences, Tile University of Texas at Austin 

ogin 
----- Original Message -----

From: pharb2@,msn.com

To: presidentomessages.whitehouse.gov ; jackson.lisa~cepa.gov ; Roger Vaughan The.Secretarvyhq.doe.gov ; radmat~tceq.state.

tx.us ; Robert Beleckis ; greg.abbottaoag.state.tx.us ; rick.perry(agovernor.state.tx.us; inspector.general(ausdoi.qov ; LGloyste(otceq.

state.tx.us ; Jackie Hardee ; auqurson.shirley(@epa.gov

Cc: SJABLONScatceq.state.tx.us ; Gilrein.Stephendepamail.epa.gov ; CKuharicctceg.state.tx.us ; PShaver(@tceq.state.tx.us;

SSimmons(tceq.state.tx.us ; GSmithDtceq.state.tx.us ; HWeger~tceq.state.tx.us ; Datelinetýnbcuni.com ; Jessica. FarrarR house.state.

tx.us ; 60mccbsnews.com ; David.levenstein em.doe.gov ; Kelly.Hancock(chouse.state.tx.us ; Jim.Dunnamrhouse.state.tx.us

Sent: Thursday, August 20, 2009 7:09 PM

Subject: consolidated comment on storage safety at andrews county Texas waste site nb2

Articles where EPA official says ogallala aquifer is under the Andrews county Texas, Waste site.

Since the EPA says the water is under the site, nothing toxic should be stored over the aquifer,

with the area of the waste site having a history of sinkholes and earthquakes.

regards

Phillip Barr

nm

ps forwarded to Eunice new mexico to some worried citizens

<<Back

4/27/09

NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 1

Posted: April 27, 2009 04:21 PM MDT

LUBBOCK, TX (KCBD) - It is the biggest clean-up effort in the

nation, and contaminants from New York's Hudson River will

soon make their way to West Texas to be buried for

good. The toxic substance could come through Lubbock by

railroad, but the bigger concern is your water supply.

NewsChannel 11's Nicole Pesecky is investigating what has

become a state-wide controversy.

More than a million pounds of PCB's, or poly chlorinated

biphenyls, will be dumped in a landfill in Andrews, Texas. The

carcinogen is linked to thyroid disease, learning, memory and

----- Original Message -----

From: pharb2@msn.com 

To: president@messages.whitehouse.gov ; jackson.lisa@epa.gov ; Roger Vaughan; The.Secretary@hq.doe.gov ; radmat@tceq.state. 

tx.us ; Robert Beleckis ; greg.abbott@oag.state.tx.us ; rick.perry@governor.state.tx.us ; inspector.general@usdoj.gov ; LGloyste@tceq. 

state.tx.us ; Jackie Hardee; augurson.shirley@epa.gov 

Cc: SJABLONS@tceq.state.tx.us ; Gilrein.Stephen@epamail.epa.gov ; CKuharic@tceq.state.tx.us ; PShaver@tceq.state.tx.us ; 

SSimmons@tceq.state.tx.us ; GSmith@tceq.state.tx.us ; HWeger@tceq.state.tx.us ; Dateline@nbcunLcom ; Jessica.Farrar@house.state. 

tx.us ; 60m@cbsnews.com ; David.levenstein@em.doe.gov ; Kelly.Hancock@house.state.tx.us ; Jim.Dunnam@house.state.tx.us 

Sent: Thursday, August 20,20097:09 PM 

Subject: c9nsolidated comment on storage safety at andrews county Texas waste site nb2 

Articles where EPA official says ogallala aquifer is under the Andrews county Texas, Waste site. 

Since the EPA says the. water is under the site, nothing toxic should be stored over the aquifer, 

with the area of the waste site having a history of sinkholes and earthquakes. 

regards 

Phillip Barr 

nm 

ps forwarded to Eunice new mexico to some worried citizens 

«Back 

4/27/09 

. NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 1 

Posted: April 27, 2009 04:21 PM MDT 

LUBBOCK, TX (KCBD) - It is the biggest clean-up effort in the 

nation, and contaminants from New York's Hudson River will 

soon make their way to West Texas to be buried for 

good. The toxic substance could come through Lubbock by 

railroad, but the bigger concern is your water supply. 

NewsChannel 11's Nicole Pesecky is investigating what has' 

become a state-wide controversy. 

More than a million pounds of PCB's, or poly chlorinated 

biphenyls, will be dumped in a landfill in Andrews, Texas. The 

carcinogen is linked to thyroid disease, learning, memory and 
______________________immune system disorders. For the last 30 years, high levels

4 ~ of PCB's were found in fish from the Hudson causing New

York to ban their consumption.

SIt's critical to keep PCBDs ouofw atrsure.l together,

butdurngour investigation we found out, the landfill in

Adrews is sitting on top of the Ogallala aquifer, which is

where many West Texas cities get their water including

Lubbock.

"It's really a foolish idea to want to ship all these massive

amounts of waste 2,000 miles to West Texas," said Dr. Neil

~, Carmen, the clean air director for the Lone Star Chapter of

the Sierra Club. Carmen is not the only one who believes

K ~ ~ these contaminates are going to the wrong place - it is a

- highly disputed topic.

General Electric is responsible for cleaning up 1.3 million

pounds of PCB's from the Hudson after they were dumped

back in the 1950's, and GE is forking over $750 million to do ~ ~ it. In the long run, Carmen says Lubbock will be paying the .. price. "The Ogallala aquifer and other water formations are

Tjust a matter of feet away," says Carmen.

Linda Beach, Vice President and G. M. of Waste Control

Specialists (WCS) in Andrews, disagrees. She claims there is ~ at least 500 feet between the dump and the aquifer, and S that's if there's even a water source there at all. "The aquifer

~ below it is not really the QAG aquifer that everyone is familiar

with - it's some water that is too salty to use for irrigation and

is not drinkable," Linda explains.

Andrews City Manager Glen Hackler is convinced the aquifer is not under this landfill. "The

community of Andrews did independent studies verified that the Ogallala aquifer does not

extend into remote western regions of the county," Hackler says. But David Barry, spokesperson for the Environmental Protection Agency for Region 6 says, "Yes, the facility

does sit above the Ogallala aquifer. It sits on the southern end of the aquifer."

We checked it out for ourselves, and it does cover part of the Andrews dump. So what are

the chances of this toxic substance getting into Lubbock and other West Texas water

sources? "In my opinion there's no chance," Beach states.

Waste specialists say the red bed clay is 100 times more resistant than concrete, so the

odds of water draining into the aquifer are very slim. Carmen says clay is not leak proof, and

it will inevitably become a problem. "It's just a bad idea to leave for future generations to

deal with," Carmen says.

Even the citizens of Andrews are skeptical about what the future holds. "It will probably be

after my lifetime, but I think it will eventually affect the water if they're not careful,"

explains one concerned Andrews resident. "If it's gonna bring jobs, great. If they're gonna

immune system disorders. For the last 30 years, high levels 

of PCB's were found in fish from the Hudson causing New 

York to ban their consumption. 

It's critical to keep PCB's out of water sources all together, 

but during our investigation we found out, the landfill in 

Andrews is sitting on top of the Ogallala aquifer, which is 

where many West Texas cities get their water including 

Lubbock. 

"It's really a foolish idea to want to ship all these massive 

amounts of waste 2,000 miles to West Texas," said Dr. Neil 

Carmen, the clean air director for the Lone Star Chapter of 

the Sierra Club. Carmen is not the only one who believes 

these contaminates are going to the wrong place - it is a 

highly disputed topic. 

General Electric is responsible for cleaning up 1.3 million 

pounds of PCB's from the Hudson after they were dumped 

back in the 1950's, and GE is forking over $750 million to do 

it. In the long run, Carmen says Lubbock will be paying the 

price. "The Ogallala aquifer and other water formations are 

just a matter of feet away," says Carmen. 

Linda Beach, Vice President and G. M. of Waste Control 

Specialists eWCS) in Andrews, disagrees. She claims there is 

at least 500 feet between the dump and the aquifer, and 

that's if there's even a water source there at all. "The aquifer 

below it is not really the OAG aquifer that everyone is familiar 

with - it's some water that is too salty to use for irrigation and 

is not drinkable," Linda explains. 

Andrews City Manager Glen Hackler is convinced the aquifer is not under this landfill. "The 

community of Andrews did independent studies verified that the Ogallala aquifer does not 

extend into remote western regions of the county," Hackler says. But David Barry, 

spokesperson for the Environmental Protection Agency for Region 6 says, "Yes, the facility 

does sit above the Ogallala aquifer. It sits on the southern end of the aquifer." 

We checked it out for ourselves, and it does cover part of the Andrews dump. So what are 

the chances of this toxic substance getting into Lubbock and other West Texas water 

sources? "In my opinion there's no chance," Beach states. 

Waste speCialists say the red bed clay is 100 times more resistant than concrete, so the 

odds of water draining into the aquifer are very slim. Carmen says clay is not leak proof, and 

it will inevitably become a problem. "It's just a bad idea to leave for future generations to 

deal with," Carmen says. 

Even the citizens of Andrews are skeptical about what the future holds. "It will probably be 

after my lifetime, but I think it will eventually affect the water if they're not careful," 

explains one concerned Andrews resident. "If it's gonna bring jobs, great. If they're gonna 
hurt our land then they need to find another way to do it," says another.

So why is Andrews so enthusiastic about getting dumped on? "They put a lot into our school

system. They put a lot into the community. WCS is good for Andrews," says this Andrews

resident.

"I think over time there's going to be tens of millions of dollars of economic impact to benefit

our community," says Hackler. He's confident this project won't taint their city or any

nearby, "We don't in any way feel like this is a danger to our water supply."

One man who spent four years investigating the WCS site says the danger is definitely there.

"All of our time has been wasted. We've all been played for suckers. We've all been pointless

impediments to a process that resulted in issuing this license from the first day," he says.

Coming up Tuesday night in Part 2 of our investigation, we will hear from a former employee

for the Texas Commission on Environmental Quality. He says, after 16 years, he quit his job

after permits were granted to Waste Control Specialists against his recommendation

<<Back

4/28/09

NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 2

Posted: April 28, 2009 07:20 PM MDT

S ~i~•> LUBBOCK, TX (KCBD) - NewsChannel 11 told you Monday

~Yabout a historical cleanup involving General Electric shipping

millions of pounds of toxic waste from the Hudson River and

burying it in West Texas. Tuesday we hear from a former

employee of Texas Commission on Environmental Quality. He

claims he quit his job after permits were granted to the

landfill against his recommendation.

Glen Lewis says he threw in the towel after TCEQ granted

these permits allowing hazardous waste to be buried at the

landfill site in Andrews, Texas. He says his reasoning is that

those toxic substances will inevitably contaminate the aquifer

sitting underneath that dump, which is one way Lubbock gets

its water.

hurt our land then they need to find another way to do it," says another. 

So why is Andrews so enthusiastic about getting dumped on? "They put a lot into our school 

system. They put a lot into the community. WCS is good for Andrews," says this Andrews 

resident. 

"I think over time there's going to be tens of millions of dollars of economic impact to benefit 

our community," says Hackler. He's confident this project won't taint their city or any 

nearby, "We don't in any way feel like this is a danger to our water supply." 

One man who spent four years investigating the WCS site says the danger is definitely there. 

"All of our time has been wasted. We've all been played for suckers. We've all been pointless 

impediments to a process that resulted in issuing this license from the first day," he says. 

Coming up Tuesday night in Part 2 of our investigation, we will hear from a former employee 

for the Texas Commission on Environmental Quality. He says, after 16 years, he quit his job 

after permits were granted to Waste Control Specialists against his recommendation 

«Back 

4/28/09 

NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 2 

Posted: April 28, 2009 07:20 PM MDT 

LUBBOCK, TX (KCBD) - NewsChannel 11 told you Monday 

about a historical cleanup involving General Electric shipping 

millions of pounds of toxic waste from the Hudson River and 

burying it in West Texas. Tuesday we hear from a former 

employee of Texas Commission on Environmental Quality. He 

claims he quit his job after permits were granted to the 

landfill against his recommendation. 

Glen Lewis says he threw in the towel after TCEQ granted 

these permits allowing hazardous waste to be buried at the 

landfill site in Andrews, Texas. He says his reasoning is that 

those toxic substances will inevitably contaminate the aquifer 

sitting underneath that dump, which is one way Lubbock gets 

its water. 
Lewis has been with TCEQ for 16 years. He spent nearly four

of those years investigating the Waste Control Specialists site

in Andrews, Texas for approval of certain toxic wastes. Lewis

says, "I resigned my position there, mainly because of

decisions made regarding the application submitted by WCS

for disposal of low level radioactive waste at a site in Andrews

County."

Lewis wasn't the only TCEQ employee who strongly felt

the WCS site was the wrong place for these contaminates. "There were two other people

who quit specifically because of this," Lewis says.

The permit was just granted to WCS on January 28th, 2009. "All of our time has been

wasted. We've all been played for suckers, we've all been pointless impediments to a

process that resulted in issuing this license from the first day," Lewis explains.

During Lewis' review with TCEQ, he found that the landfill site is threatened by dump water

draining into two water tables. One of those, the Ogallala aquifer which is water Lubbock

drinks. "It may be as close as 14 feet from the bottom of the proposed trench. We found

that those were unacceptable margins and were not the hundreds of feet of impermeable

red bed clay that the applicant originally claimed," Lewis says.

That is what WCS still claims. "At least 500 feet of red bed clay on the bottom of the landfill

between the nearest potential aquifer," Linda Beach, the Vice President with WSC says.

So why would TCEQ and the Environmental Protection Agency grant these permits to begin

with? Lewis chalks it up to inexperience. Neither organization has ever had to get rid of 1.3

million pounds of toxic waste and transport it to one location. "Nobody has really dealt with

this. We can't look into a crystal ball and say that this site is absolutely going to perform

satisfactory for 50,000 years," Lewis explains.

Rod Baltzer, president of WCS, says Lewis is wrong - the landfill is not over the Ogallala. "I

don't think they've got the latest information, and they don't understand what the facts are,"

says Baltzer.

Jim Conkwright with the High Plains Underground Water District says he didn't know at first

if the aquifer extends under the landfill, but did some checking and says, "It depends on

your definition of the aquifer," he continues to say, "Some say it is and some say it isn't."

WCS says according to maps by the Texas Water Development board in 2006, its disposal

site does not sit above the Ogallala aquifer. WCS states that after Lewis left the agency,

hundreds of additional wells were drilled to determine the subsurface properties at the site.

The company has had several consultants analyzing the ground water results. Also,

according to the company, as a result of meetings with TCEQ, they agreed to install long

term monitoring of the water at the site. Its analysis says the water at the site is puddled

and not connected to the aquifer.

Wednesday night, we'll have more from the president of WCS, and why he says the Ogallala

aquifer is not under his site.

Lewis has been with TCEQ for 16 years. He spent nearly four 

of those years investigating the Waste Control Specialists site 

in Andrews, Texas for approval of certain toxic wastes. Lewis 

says, III resigned my position there, mainly because of 

deCisions made regarding the application submitted by WCS 

for disposal of low level radioactive waste at a site in Andrews 

County.1I 

Lewis wasn't the only TCEQ employee who strongly felt 

the WCS site was the wrong place for these contaminates. IIThere were two other people 

who quit specifically because of this,ll Lewis says. 

The permit was just granted to WCS on January 28th, 2009. IIAII of our time has been 

wasted. W.e've all been played for suckers, we've all been pointless impediments to a 

process that resulted in issuing this license from the first day,1I Lewis explains. 

During Lewis' review with TCEQ, he found that the landfill site is threatened by dump yvater 

draining into. two water tables. One of those, the Ogallala aquifer which is water Lubbock 

drinks. IIIt may be as close as 14 feet from the bottom of the proposed trench. We found 

that those were unacceptable margins and were not the hundreds of feet of imperm'eable 

red bed clay that the applicant originally claimed, II Lewis says. 

That is what WCS still claims. IIAt least 500 feet of red bed clay on the bottom of the landfill 

between the nearest potential aquifer,1I Linda Beach, the Vice President with WSC says. 

So why would TCEQ and the Environmental Protection Agency grant these permits to begin 

with? Lewis chalks it up to inexperience. Neither organization has ever had to get rid of 1.3 

million pounds of toxic waste and transport it to one location. IINobody has really dealt with 

this. We can't look into a crystal ball and say that this site is absolutely going to perform 

satisfactory for 50,000 years, II Lewis explains. 

Rod Baltzer, president of WCS, says Lewis is wrong - the landfill is not over the Ogallala. III 

don't think they've got the latest information, and they don't understand what the facts are,1I 

says Baltzer. 

Jim Conkwright with the High Plains Underground Water District says he didn't know at first 

if the aquifer extends under the landfill, but did some checking and says, lilt depends on 

your definition of the aquifer, II he continues to say, IISome say it is and some say it isn't. II 

WCS says according to maps by the Texas Water Development board in 2006, its disposal 

site does not sit above the Ogallala aquifer. WCS states that after Lewis left the agency, 

hundreds of additional wells were drilled to determine the subsurface properties at the site. 

The company has had several consultants analyzing the ground water results. Also, 

according to the company, as a result of meetings with TCEQ, they agreed to install long 

term monitoring of the water at the site. Its analysis says the water at the site is puddled 

and not connected to the aquifer. 

Wednesday night, we'll have more from the president of WCS, and why he says the Ogallala 

aquifer is not under his site. 
<<Back

4/29/09

NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 3

Posted: April 29, 2009 05:48 PM MDT

LUBBOCK, TX (KCBD) - On Monday, we first told you about

millions of pounds of toxic waste being taken to the Waste

Control Specialists landfill in Andrews, Texas. David Barry,

with the Environmental Protection Agency says the Ogallala

VES, T1GATE" I aquifer is under that dump, but the president of Waste

i Control Specialists says he can prove otherwise.

Rod Baltzer is the president of Waste Control Specialists,

which is the landfill taking this toxic waste. Baltzer flew in for

an interview with NewsChannel 11 after our first story aired.

Si. He says the site is not on top of the Ogallala aquifer and he

can prove it. "The Ogallala aquifer is not under our site. But

just to be safe, the way we design our landfill is to dig into

the red bed clays and to ensure that nothing above it would

interfere with that wastes," said Baltzer.

Baltzer claims the hundreds of feet of red bed clay isn't the

only liner between the ground and these toxic contaminants.

"We've then got a three foot clay liner, we've got a

geomembrane plastic liner and then we've got a concrete

Sliner, he said.

Baltzer explains that, according to maps by the Texas Water

Development Board in 2006, the dump in Andrews does not

sit above the Ogallala. He also says Texas Tech University did

a study back in the 90's that found the same results. "This

site is probably the most studied analyzed and modeled site

in the history of the universe," Rod says. So why is this site so controversial?

We spoke with David Barry, the Environmental Protection

Agency spokesperson for Region 6, who once again states, "It

does appear that the Waste Control Specialist site is above

the Ogallala aquifer."

"I would love to be able to talk with EPA and see what they

were looking at. I don't know if they were looking at old maps

that have changed," Baltzer states in response.

«Back 

4/29/09 

NewsChannel 11 Investigates: Toxic Waste Coming to West Texas, Part 3 

Posted: April 29, 200905:48 PM MDT 

LUBBOCK, TX (KCBD) - On Monday, we first told you about 

millions of pounds of toxic waste being taken to the Waste 

Control Specialists landfill in Andrews, Texas. David Barry, 

with the Environmental Protection Agency says the Ogallala 

aquifer is under that dump, but the president of Waste 

Control Specialists says he can prove otherwise. 

Rod Baltzer is the president of Waste Control Specialists, 

which is the landfill taking this toxic waste. Baltzer flew in for 

an interview with NewsChannel 11 after our first story aired. 

He says the site is not on top of the Ogallala aquifer and he 

can prove it. "The Ogallala aquifer is not under our site. But 

just to be safe, the way we design our landfill is to dig into 

the red bed clays and to ensure that nothing above it would 

interfere with that wastes," said Baltzer. 

Baltzer claims the hundreds of feet of red bed clay isn't the 

only liner between the ground and these toxic contaminants. 

"We've then got a three foot clay liner, we've got a 

geomembrane plastic liner and then we've got a concrete 

liner," he said. 

Baltzer explains that, according to maps by the Texas Water 

Development Board in 2006, the dump in Andrews does not 

sit above the Ogallala. He also says Texas Tech University did 

a study back in the 90's that found the same results. "This 

site is probably the most studied analyzed and modeled site 

in the history of the universe," Rod says. So why is this site 

so controversial? 

We spoke with David Barry, the Environmental Protection 

Agency spokesperson for Region 6, who once again states, "It 

does appear that the Waste Control SpeCialist site is above 

the Ogallala aquife"r." 

"I would love to be able to talk with EPA and see what they 

were looking at. I don't know if they were looking at old maps 

that have changed," Baltzer states in response. 
Jim Conkwright with the High Plains Underground Water

District did some checking and says, "It depends on your

definition of the aquifer. Some say it is and some say it isn't."

Glen Hackler, the city manager of Andrews, says they profit

from WCS. "I think over time there's going to be tens of

1 millions of dollars of economic impact to benefit our

_ ........... community," Hackler explains.

So we know the possible economic benefit for Andrews, but it's still unknown how

much WCS will profit from this waste. Rod Baltzer says WCS is required to have financial

insurance. They're insured for over $8 million.

WCS issued a statement saying, "State and federal governments have determined on

8 separate occasions that the WCS facility does not pose a threat to the drinking water of

any person, city or entity in the Permian Basin or the South Plains, including Lubbock."

From: <pharb2@msn.com>

To: <ipresident@messagqes.whitehouse.qgov>,

<jackson. lisa@epa .qov>,

"Roger Vaughan" <RVaughan@tceq.state.tx.us>,

<The. Secretary@hq.doe.gov>,

<radmat@tceq.state.tx. us>,

"Robert Beleckis" <RBelecki@tceq.state.tx.us>,

<qreg.abbott@oaq.state.tx.us>,

< rick. perry@qovernor.state.tx. us>,

<inspector.qeneral@usdoj.cqov>,

<LGloyste@tceq.state.tx. us>,

"Jackie Hardee" <JHARDEE@tceq.state.tx.us>,

<auqurson.shirley@epa.qov>

Cc: <SJABLONS@tceq.state.tx.us>,

<Gilrein.Stephen@epamail.epa.qov>,

<CKuharic@tceq.state.tx.us>,

< PShaver@tceq .state.tx. us >,

<SSimmons@tceq .state.tx.us>,

<GSmith@tceq.state.tx.us>,

< HWeqer@tceq .state.tx. us>,

<Dateline@nbcuni.com>,

<Jessica. Farrar@ house. state.tx. us>,

<60m@cbsnews.com>,

<David. levenstei n@em. doe. qov >,

< Kelly. Hancock@ house. state.tx. us>,

<Jim.Dunnam@house.state.tx.us>

Subject: consolidated comment on storage safety at andrews county Texas waste site nb2

Jim Conkwright with the High Plains Underground Water . 

District did some checking and says, "It depends on your 

definition of the aquifer. Some say it is and some say it isn't." 

Glen Hackler, the city manager of Andrews, says they profit 

from WCS. "I think over time there's going to be tens of 

millions of dollars of economic impact to benefit our 

community," Hackler explains. 

So we know the possible economic benefit for Andrews, but it's still unknown how 

much WCS will profit from this waste. Rod Baltzer says WCS is required to have financial 

insurance. They're insured for over $8 million. 

WCS issued a statement saying, "State and federal governments have determined on 

8 separate occasions that the WCS facility does not pose a threat to the drinking water of 

any person, city or entity in the Permian Basin or the South Plains, including Lubbock." 

From: <pharb2@msn.com> 

To: < president@messages.whitehouse.gov>, 

<iackson.lisa@epa.gov>, 

"Roger Vaughan" <RVaughan@tceq.state.tx.us>, 

<The.Secretary@hq.doe.gov>, 

< rad mat@tceq.state. tx. us> , 

"Robert Beleckis" < RBelecki@tceq.state.tx.us>, 

<greg.abbott@oag.state.tx.us>, 

<rick. perry@governor.state.tx.us>, 

<inspector.general@usdoj.gov>, 

<LGloyste@tceq.state.tx.us>, 

"Jackie Hardee" <JHARDEE@tceq.state.tx.us>, 

<auqurson.shirley@epa.qov> 

Cc: <SJABLONS@tceq.state.tx.us>, 

<Gilrein .Stephen@epamail.epa.qov>, 

<CKuharic@tceq.state.tx.us>, 

<PShaver@tceq.state.tx.us>, 

<SSimmons@tceq.state.tx.us>, 

<GSmith@tceq.state.tx.us>, 

< HWeger@tceq.state.tx.us>, 

<Dateline@nbcuni.com>, 

<Jessica. Farrar@house.state.tx.us>, 

<60m@cbsnews.com>, 

< David.levenstein@em.doe.qov>, 

< Kelly.Hancock@house.state.tx.us>, 

<Jim.Dunnam@house.state.tx.us> 

Subject: consolidated comment on storage safety at andrews county Texas waste site nb2 
Date: Thu, 20 Aug 2009 19:09:16 -0600

MIME-Version: 1.0

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Page 1 of 1

7YF7LP 36/7•

I______

As of: October 20, 2009

Received: October 20, 2009

Status: Pending-Post PUBLIC SUBMISSION Tracking No. 80a45d12

Comments Due: October 30, 2009

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0006

Comment on FR Doc # E9-14820

Submitter Information

Name: Jason Ahmadi

General Comment

* The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU

grows more radioactive.

e The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU

disposal in a deep geologic repository.

* It is inappropriate to license any new uranium enrichment facility until regulations are in place governing

disposal of depleted uranium and disposal facilities have implemented those regulations.

• Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow

land burial is adequate for depleted uranium disposal.

e The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level

waste disposal facilities.

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(i) 

As of: October 20, 2009 

Received: October 20, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC SUB ISSI Tracking No. 80a45d12 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Docu ment: N RC-2009-0257 -DRAFT -0006 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Jason Ahmadi 

General Comment 

• The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste 

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU 

grows more radioactive. 

• The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU 

disposal in a deep geologic repository. 

• It is inappropriate to license any new uranium enrichment facility until regulations are in place governing 

disposal of depleted uranium and disposal facilities have implemented those regulations. 

• Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to 

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow 

land burial is adequate for depleted uranium disposal. 

• The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be 

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more 

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level 

waste disposal facilities. 

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PUBLIC SUBMISSION

As of: October 27, 2009

Received: October 27, 2009

Status: PendingPost

Tracking No. 80a4c6ea

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0008

Comment on FR Doc # E9-14820

Submitter Information

Name: Charles Reyes

Address:

444 North Capitol Street, N.W.

Suite 315

Washington, DC, 20001

Organization: Association of State and Territorial Solid Waste Management Officials

Government Agency Type: State

I'D rn

General Comment

Members of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Federal

Facilities Research Subcommittee and Radiation Focus Group developed these comments regarding the Nuclear

Regulatory Commission's (NRC's) "Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium" [NRC-2009-0257-0001]. The comments have not been reviewed or

adopted by ASTSWMO's Board of Directors, and therefore, the word "States" throughout this document refers

to the members of the ASTSWMO Radiation Focus Group. In addition, individual State programs may submit

comments directly to you conveying their own perspectives.

Please see attachment for full comments.

Attachments

NRC-2009-0257-DRAFT-0008.1: Comment on FR Doc # E9-14820

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As of: October 27, 2009 

Received: October 27, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC SUBMISSIO Tracking No. 80a4c6ea 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0008 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Charles Reyes 

Address: 

444 North Capitol Street, N,W. 

Suite 315 

Washington, DC, 20001 

Organization: Association of State and Territorial Solid Waste Management Officials 

Government Agency Type: State 

General Comment 

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Members of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Federal 

Facilities Research Subcommittee and Radiation Focus Group developed these comments regarding the Nuclear 

Regulatory Commission's (NRC's) "Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium" [NRC-2009-0257-0001], The comments have not been reviewed or 

adopted by ASTSWMO's Board of Directors, and therefore, the word "States" throughout this document refers 

to the members of the ASTSWMO Radiation Focus Group. In addition, individual State programs may submit 

comments directly to you conveying their own perspectives. 

Please see attachment for full comments. 

Attachments 

NRC-2009-0257-DRAFT-0008.1: Comment on FR Doc # E9-14820 

SUNJI (4.vfeL0 (1r'1fle~ 

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Association of State and Territorial

444 North Capitol Street, N.W., Suite 315

Washington, DC 20001

___.... ...... ... ....... ___ _ tel: (202) 624-5828 fax: (202) 624-7875

Solid Waste Management Officials astswxoorg

October 26, 2009

Chief, Rulemaking and Directives Branch

Division of Administrative Services, Office of Administration

U.S. Nuclear Regulatory Commission

Mail Stop TWB 5B01M

Washington, DC 20555-0001

RE: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium [NRC-2009-0257-0001]

Federal Register / Vol. 74, No. 120 / Wednesday, June 24, 2009 / Notices FR pg 30175

Dear Sir/Madam:

Members of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Federal

Facilities Research Subcommittee and Radiation Focus Group developed these comments regarding the

Nuclear Regulatory Commission's (NRC's) "Potential Rulemaking for Safe Disposal of Unique Waste Streams

Including Significant Quantities of Depleted Uranium" [NRC-2009-0257-0001 ]. The comments have not been

reviewed or adopted by ASTSWMO's Board of Directors, and therefore, the word "States" throughout this

document refers to the members of the ASTSWMO Radiation Focus Group. In addition, individual State

programs may submit comments directly to you conveying their own perspectives.

We agree that depleted uranium (DU) is a unique waste and that, due to its characteristics, should have

enhanced performance assessments as compared to typical low-level radiological solid wastes. Ideally the

process should discriminate out unsuitable sites for uranium disposal and enhance environmental protection on

remaining suitable sites. The in-growth of progeny and the "perpetual" half life of the uranium parents dictate

this process.

The renal toxicity of uranium should be considered in performance assessments. The Toxicological Profile for

Uranium states that "natural and depleted uranium are primarily chemical hazards" (ATSDR, 1999).

Modeling done thus far for disposal of large quantities of DU appears to be radiation dose focused for

all pathways modeled. The NRC's regulations in 10 CFR 20 Appendix B consider the chemical toxicity for

soluble uranium in an occupational exposure scenario, and the EPA's relatively new regulation for community

drinking water supplies limits uranium concentrations to 30 micrograms per liter (30 ug U/L). The Nuclear

Regulatory Commission (NRC), or an Agreement State, needs to ensure that long-term migration of DU from a

disposal cell and the potential impact of uranium on ground water are considered in light of chemical toxicity,

as well as radiation dose. Performance assessments should also include air dispersion and chemical toxicity of

uranium to intruders, as well as from groundwater ingestion. These are "out-year" considerations exceeding

current IOCFR61 performance assessments.

Long-term replacement of covering caps and radon barriers on DU shallow land disposal sites dictates the need

for perpetual care funding. Installation of radon barriers is needed only after significant in growth of radium

with potential for radon inhalation. Under current rules, this occurs after the typical period of control for a lowlevel waste disposal facility. Economy would dictate a graded engineering approach for the protective cap

since the radiological hazard from DU disposal is only magnified in "out years." Realize that, by mass, even

the residual amounts of U-234 in DU can generate radon earlier than much greater concentrations of U-238.

Association of State and Territorial 

October 26, 2009 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services, Office of Administration 

U.S. Nuclear Regulatory Commission 

Mail Stop TWB 5B01M 

Washington, DC 20555-0001 

444 North Capitol Street, N. W., Suite 315 

Washington. IX 2000! 

tel: (202) 624-5828 fax: (202) 624-7875 

\vww.astswmo.org 

RE: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium [NRC-2009~257-0001] 

Federal Register / Vol. 74, No. 120/ Wednesday, June 24, 2009 / Notices FR pg 30175 

Dear SirlMadam: 

Members of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Federal 

Facilities Research Subcommittee and Radiation Focus Group developed these comments regarding the 

Nuclear Regulatory Commission's (NRC's) "Potential Rulemaking for Safe Disposal of Unique Waste Streams 

Including Significant Quantities of Depleted Uranium" [NRC-2009"()257"()001]. The comments have not been 

reviewed or adopted by ASTSWMO's Board of Directors, and therefore, the word "States" throughout this 

document refers to the members of the ASTSWMO Radiation Focus Group. In addition, individual State 

programs may submit comments directly to you conveying their own perspectives. 

We agree that depleted uranium (DU) is a unique waste and that, due to its characteristics, should have 

enhanced performance assessments as compared to typical low-level radiological solid wastes. Ideally the 

process should discriminate out unsuitable sites for uranium disposal and enhance environmental protection on 

remaining suitable sites. The in-growth of progeny and the "perpetual" halflife of the uranium parents di~tate 

this process. 

The renal toxicity of uranium should be considered in performance assessments. The Toxicological Profile for 

Uranium states that "natural and depleted uranium are primarily chemical hazards" (A TSDR, 1999). 

Modeling done thus far for disposal of large quantities of DU appears to be radiation dose focused for 

all pathways modeled. The NRC's regulations in 10 CFR 20 Appendix B consider the chemical toxicity for 

soluble uranium in an occupational exposure scenario, and the EPA's relatively new regulation for community 

drinking water supplies limits uranium concentrations to 30 micrograms per liter (30 ug U/L). The Nuclear 

Regulatory Commission (NRC), or an Agreement State, needs to ensure that long-term migration ofDU from a 

disposal ceIl and the potential impaCt of uranium on ground water are considered in light of chemical toxicity, 

as well as radiation dose. Performance assessments should also include air dispersion and chemical toxicity of 

uranium to intruders, ,as well as from groundwater ingestion. These are "out-year" considerations exceeding 

current lOCFR61 performance assessments. 

Long-term replacement of covering caps and radon barriers on DU shallow land disposal sites dictates the need 

for perpetual care funding. Installation of radon barriers is needed only after significant in growth of radium 

with potential for radon inhalation. Under current rules, this occurs after the typical period of control for a lowlevel waste disposal facility. Economy would dictate a graded engineering approach for the protective cap 

since the radiological hazard from DU disposal is only magnified in "out years." Realize that, by mass, even 

the residual amounts ofU-234 in DU can generate radon earlier than much greater concentrations ofU-238. 
The need for long-term replacement of covering caps and radon barriers on DU shallow land disposal sites

dictates the need for perpetual care funding. The alternative is geologic disposal.

Some DU in the Department of Energy (DOE) system is the byproduct of recycled returns from reactors.

These DU wastes are potentially contaminated with transuranics and fission products. Deconversion of UF6

tails may filter out any contaminates. Any performance assessment should include anomalous DU

contaminants that remain. Thorough characterization of unique wastes for disposal is imperative.

If this progresses to rulemaking, the ASTSWMO Federal Facilities Research Subcommittee and Radiation

Focus Group desire to participate in related forums and discussions. The workshop transcripts illustrate the

complexity of related issues. We did not repeat the many substantive comments posted in the transcripts. If

there are questions, please call Dale Rector, Tennessee Department of Environment and Conservation,

ASTSWMO Radiation Focus Group Chair, at 865-483-4510 or dale.rector6kn. gov.

Sincerely,

Clarence L. h, Chair

ASTSWMO 10deral Facilities Research Subcommittee

CC: ASTSWMO Radiation Focus Group

Priya Yadav, U.S. Nuclear Regulatory Commission

Dan Schultheisz, U.S. Environmental Protection Agency

The need for long-term replacement of covering caps and radon barriers on DU shallow land disposal sites 

dictates the need for perpetual care funding. The alternative is geologic disposal. 

Some DU in the Department of Energy (DOE) system is the byproduct of recycled returns from reactors. 

These DU wastes are potentially contaminated with transuranics and fission products. Deconversion ofUF6 

tails may filter out any contaminates. Any performance assessment should include anomalous DU 

contaminants that remain. Thorough characterization of unique wastes for disposal is imperative. 

If this progresses to rulemaking, the ASTSWMO Federal Facilities Research Subcommittee and Radiation 

Focus Group desire to participate in related forums and discussions. The workshop transcripts illustrate the 

complexity of related issues. We did not repeat the many substantive comments posted in the transcripts. If 

there are questions, please call Dale Rector, Tennessee Department of Environment and Conservation, 

ASTSWMO Radiation Focus Group Chair, at 865-483-4510 or rtille.r~ctor@tn.gov. 

Sincerely, 

h, CHair 

deral Facilities Research Subcommittee 

cc: ASTSWMO Radiation Focus Group 

Priya Yadav, U.S. Nuclear Regulatory Commission 

Dan Schultheisz, U.S. Environmental Protection Agency 
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Page 1 of 1

PUBLIC SUBMISSION

As of: October 29, 2009

Received: October 29, 2009

Status: Pending-Post

Tracking No. 80a4da3f

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0015

Comment on FR Doc # E9-14820

Submitter Information

Name: Jim Sylva

General Comment

I urge you to not allow production of enriched uranium until a deep geological repository is built to store its

waste. Your legacy regarding the disposal of high-level radioactive waste has been less than wise. Sixty-five

years of producing high-level waste and still nodeep geological repository exists to store it. Classifying depleted

uranium as LLW does not make it so. It is one of most toxic heavy metals known to humankind and should be

treated with the upmost respect. Don't repeat your error of putting the horse before the cart. You now claim to

know better. Please be honest about the dangers of DU and build an appropriate (if possible) deep geological

waste disposal site before allowing the production of such waste by uranium enrichment plants.

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https ://fdms.erulemaking .net/fdms-web-agency/component/submitterlnfoC d/ei1⁄2a all=rn~. h 02920

& l)t( 10 1 Page 1 of 1 

PUBLIC SUBMISSION 

Docket: NRC-2009-0257 

'1 ~ f~ J l) 1 ( r 

As of: October 29, 2009 

Received: October 29, 2009 

Status: Pending_Post 

Tracking No. 80a4da3f 

Comments Due: October 30, 2009 

Submission Type: Web 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

" 

Document: NRC-2009-0257-DRAFT ~0015 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Jim Sylva 

General Comment 

I urge you to not allow production of enriched uranium until a deep geological repository is built to store its 

waste. Your legacy regarding the disposal of high-level radioactive waste has been less than wise. Sixty-five 

years of producing high-level waste and still no ,deep geological repository exists to store it. Classifying depleted 

uranium as LLW does not make it so. It is one of most toxic heavy metals known to humankind and should be 

treated with the upmost respect. Don't repeat your error of putting the horse before the cart. You now claim to 

know better. Please be honest about the dangers of DU and build an appropriate (if possible) deep geological 

waste disposal site before allowing the production of such waste by uranium enrichment plants. 

,--- .......... 

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UNITED STATES

NUCLEAR REGULATO0Y COMMISSION

WASHINGTON, D.C. 20555-0001

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6Page lof 2

As of: October 19, 2009

Received: October 16, 2009

Status: Pending-Post

ITracking No. 80a42ca6

Comments Due: October 30, 2009

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0003

Comment on FR Doc # E9-14820

Submitter Information

Name: John Hurd

Address: Clinton,

Organization: Whidbey Enviornmental Action Network

General Comment

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU

grows more radioactive.

NRC should focus on reevaluating its decision that shallow land burial is adequate for depleted uranium

disposal.

Out of sight out of mind but not out of the environment. Who will be testing during the 4.5 BILLION years of

DU's half life to measure the effects of this highly toxic form of particle radiation?

The fact that DU grows more radioactive over the many millennia prohibits DU disposal at any of the current or

pending low-level waste disposal facilities.

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU

disposal in a deep geologic repository.

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing

disposal of depleted uranium and disposal facilities have implemented those regulations.

Please read the attached document.

A•mn-tt a c h mnernt&s MAI0/]9/20

https ://fdms.erulemaking .net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 10/19/2009

t,ll~Lp1 

1 ~ fJ\ '3Pl7f 

As of: October 19, 2009 

Received: October 16, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC SUB·MISSI N Tracking No. 80a42ca6 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0003 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: John Hurd 

Address: Clinton, 

Organization: Whidbey Enviornmental Action Network 

General Comment 

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste 

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU 

grows more radioactive. 

NRC should focus on reevaluating its decision that shallow land burial is adequate for depleted uranium 

disposal 

Out of sight out of mind but not out of the environment. Who will be testing during the 4.5 BILLION years of 

DU's half life to measure the effects of this highly toxic form of particle radiation? 

The fact that DU grows more radioactive over the many millennia prohibits DU disposal at any of the current or 

pending low-level waste disposal facilities. 

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU 

disposal in a deep geologic repository. 

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing 

disposal of depleted uranium and disposal facilities have implemented those regulations. 

Please read the attached document. 

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Page 2 of 2

NRC-2009-0257-DRAFT-0003.1: Comment on FR Doc # E9-14820

NRC-2009-0257-DRAFT-0003.2: Comment on FR Doc # E9-14820

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 10/1'9/2009

NRC-2009-0257-DRAFT-0003.1: Comment on FR Doc # E9-14820 

NRC-2009-0257-DRAFT-0003.2: Comment on FR Doc # E9-14820 

Page 2 of2 

https:llfdms.erulemaking.net/fdms-web-agency/ componentl submitter InfoCover Page ?Cal1= Print&PrintId... 101 f 9/2009 
The NRC erred when it decided to formulate guidelines for

depleted uranium disposal in a low-level waste disposal facility.

That decision did not take into account the hundreds of thousands

of years over which DU grows more radioactive.

NRC should focus on reevaluating its decision that shallow land

burial is adequate for depleted uranium disposal.

The fact that DU grows more radioactive over the course of one

million years prohibits DU disposal at any of the current or

pending low-level waste disposal facilities.

The NRC must, as part of this rulemaking, prepare an

environmental impact statement that fully evaluates DU disposal

in a deep geologic repository.

It is inappropriate to license any new uranium enrichment facility

until regulations are in place governing disposal of depleted

uranium and disposal facilities have implemented those

regulations.

HERE'S WHY

Epidemiological studies and toxicological tests on laboratory

animals point to DU as being immunotoxic [65] teratogenic[66]

[67] neurotoxic [68] with carcinogenic and leukemogenic potential.

[69]. A 2005 report by epidemiologists concluded:

"the.. .epidemiological evidence is consistent with increased risk of

birth defects in offspring...exposed to DU." [11]

Uranium is a ... radioactive heavy metal... According to Hanson

(1974), uranium is soluble in oxygen-rich water, such as those

found in the surface of the ocean.... Where DU lodges in bottom

sediments, the electro-chemical conditions common in such layers

tends to change uranium to a form that has a high affinity for

organic material. "

According to the International Atomic Energy Agency:

"Plants will ... uptake DU present in soil and in water... The DU in

water and vegetation will be transferred to livestock through

The NRC erred when it decided to formulate guidelines for 

depleted uranium disposal in a low-level waste disposal facility. 

That decision did not take into account the hundreds of thousands 

of years over which DU grows more radioactive. 

NRC should focus on reevaluating its decision that shallow land 

burial is adequate for depleted uranium disposal. 

The fact that DU grows more radioactive over the course of one 

million years prohibits DU disposal at any of the current or 

pending low-level waste disposal facilities. 

The NRC must, as part of this rulemaking, prepare an 

environmental impact statement that fully evaluates DU disposal 

in a deep geologic repository. 

It is inappropriate to license any new uranium enrichment facility 

until regulations are in place governing disposal of depleted 

uranium and disposal facilities have implemented those 

regulations. 

HERE'S WHY 

Epidemiological studies and toxicological tests on laboratory 

animals point to DU as being immunotoxic [65] teratogenic[66] 

[67] neurotoxic [68] with carcinogenic and leukemogenic potential. 

[69]. A 2005 report by epidemiologists concluded: 

"the ... epidemiological evidence is consistent with increased risk of 

birth defects in offspring ... exposed to DU." [11] 

Uranium is a ... radioactive heavy metal... According to Hanson 

(1974), uranium is soluble in oxygen-rich water, such as those 

found in the surface of the ocean .... Where DU lodges in bottom 

sediments, the electro-chemical conditions common in such layers 

tends to change uranium to a form that has a high affinity for 

organic material. " 

According to the International Atomic Energy Agency: 

"Plants will ... uptake DU present in soil and in water ... The DU in 

water and vegetation will be transferred to livestock through 
ingestion of grass, soil, and water.

Depleted uranium in the soil will be in an oxidized, soluble

chemical form and migrate.. .and be incorporated into the food

chain. It is difficult to predict how long it would take for this to

occur. As a result of chemical weathering, DU buried under the

surface will corrode with time, slowly converting the metallic

uranium of the DU into uranium oxides... The specific soil

characteristics will determine the rate and chemical form of the

oxidation and the rate of migration and solubility of the depleted

uranium. This environmental pathway may result in the long term

(in the order of several years) in enhanced levels of depleted

uranium being dissolved in ground water and drinking water.

Consumption of water and food is a potential long term route of

intake of DU." (from

http://www.iaea.org/NewsCenter/Features/DU/duqaa.shtml)

Out of sight out of mind but not out of the environment. Who will

be testing during the 4.5 billion years of the DU's half life to

measure the effects of this highly toxic form of particle radiation?

Although 60% "less radioactive" than naturally occurring U-238,

DU, an alpha radiation particle emitter, compared to photo or beta

radiation, is more effective at causing certain biological effects,

notably either cancer or cell-death for equivalent radiation

exposure. It follows the same radioactive decay chain of uranium238. The daughter nuclide of a radioactive decay event may also be

unstable (radioactive). In this case, it will also decay, producing

radiation. The resulting second daughter nuclide may also be

radioactive. This can lead to a sequence of several decay events.

Eventually a stable nuclide is produced. This is called a decay

chain, which for uranium 238 and DU is as follows:

DU decays, through alpha-emission, with a half life of 4.5 billion

years to thorium-234

which decays, through beta-emission, with a half-life of 24 days to

protactinium-234

which decays, through beta-emission, with a half-life of 1.2 minutes

to uranium-234

ingestion of grass, soil, and water. 

Depleted uranium in the soil will be in an oxidized, soluble 

chemical form and migrate ... and be incorporated into the food 

chain. It is difficult to predict how long it would take for this to 

occur. As a result of chemical weathering, DU buried under the 

surface will corrode with time, slowly converting the metallic 

uranium of the DU into uranium oxides ... The specific soil 

characteristics will determine the rate and chemical form of the 

oxidation and the rate of migration and solubility of the depleted 

uranium. This environmental pathway may result in the long term 

(in the order of several years) in enhanced levels of depleted 

uranium being dissolved in ground water and drinking water. 

Consumption of water and food is a potential long term route of 

intake ofDU." (from 

http://www.iaea.orgiNewsCenterlFeatures/DU/du_qaa.shtml ) 

Out of sight out of mind but not out of the environment. Who will 

be testing during the 4.5 billion years of the DU's halflife to 

measure the effects of this highly toxic form of particle radiation? 

Although 60% "less radioactive" than naturally occurring U-238, 

DU, an alpha radiation particle emitter, compared to photo or beta 

radiation, is more effective at causing certain biological effects, 

notably either cancer or cell-death for equivalent radiation 

exposure. It follows the same radioactive decay chain of uranium238. The daughter nuclide of a radioactive decay event may also be 

unstable (radioactive). In this case, it will also decay, producing 

radiation. The resulting second daughter nuclide may also be 

radioactive. This can lead to a sequence of several decay events. 

Eventually a stable nuclide is produced. This is called a decay 

chain, which for uranium 238 and DU is as follows: 

DU decays, through alpha-emission, with a half life of 4.5 billion 

years to thorium-234 

which decays, through beta-emission, with a half-life of 24 days to 

protactinium-234 

which decays, through beta-emission, with a half-life of 1.2 minutes 

to uninium-234 
which decays, through alpha-emission, with a half-life of 240

thousand years to thorium-230

which decays, through alpha-emission, with a half-life of 77

thousand years to radium-226

which decays, through alpha-emission, with a half-life of 1.6

thousand years to radon-222

which decays, through alpha-emission, with a half-life of 3.8 days

to polonium-218

which decays, through alpha-emission, with a half-life of 3.1

minutes to lead-214

which decays, through beta-emission, with a half-life of 27 minutes

to bismuth-214

which decays, through alpha-emission, with a half-life of 20

minutes to polonium-2 10

which decays, through beta-emission, with a half-life of 160

microseconds to lead-2 10

which decays, through beta-emission, with a half-life of 22 years to

bismuth-2 10

which decays, through beta-emission, with a half-life of 5 days to

polonium-2 10

which decays, through alpha-emission, with a half-life of 140 days

to lead-206, which is a stable nuclide.

The alpha-particles emitted by DU consists of two protons and two

neutrons bound together (the equivalent of a Helium nucleus with

atomic mass of 4 amu) with a total energy of about 5 Million

electron Volts (MeV). They are a highly ionizing form of particle

radiation. They are relatively harmless until/unless ingested

(moving through many organisms up the food chain) or inhaled. In

contact with living tissue, the massive (compared to a beta particle

or gamma ray) alpha particle smashes through cellular DNA like a

wrecking ball through a building, inducing aberrant cell growth and

cancers.

which decays, through alpha-emission, with a half-life of240 

thousand years to thorium-230 

which decays, through alpha-emission, with a half-life of 77 

thousand years to radium-226 

which decays, through alpha-emission, with a half-life of 1.6 

thousand years to radon-222 

which decays, through alpha-emission, with a half-life of3.8 days 

to polonium-218 

which decays, through alpha-emission, with a half-life of3.1 

minutes to lead-214 

which decays, through beta-emission, with a half-life of 27 minutes 

to bismuth-214 

which decays, through alpha-emission, with a half-life of20 

minutes to polonium-210 

which decays, through beta-emission, with a half-life of 160 

microseconds to lead-210 

which decays, through beta-emission, with a half-life of 22 years to 

bismuth-210 

which decays, through beta-emission, with a half-life of 5 days to 

polonium-210 

which decays, through alpha-emission, with a half-life of 140 days 

to lead-206, which is a stable nuclide. 

The alpha-particles emitted by DU consists of two protons and two 

neutrons bound together (the equivalent of a Helium nucleus with 

atomic mass of 4 amu) with a total energy of about 5 Million 

electron Volts (Me V). They are a highly ionizing form of particle 

radiation. They are relatively harmless until/unless ingested 

(moving through many organisms up the food chain) or inhaled. In 

contact with living tissue, the massive (compared to a beta particle 

or gamma ray) alpha particle smashes through cellular DNA like a 

wrecking ball through a building, inducing aberrant cell growth and 

cancers. 
Being relatively heavy and positively charged, alpha particles

quickly lose kinetic energy within a short distance of their source.

This results in several MeV of destructive energy being deposited

in a relatively small volume of material. This increases the chance

of cellular damage in cases of internal contamination. In general,

external alpha radiation is not harmful since alpha particles are

effectively shielded by a few centimeters of air, a piece of paper, or

the thin layer of dead skin cells. Even touching an alpha source is

usually not harmful, though many alpha sources also are

accompanied by beta-emitting radio daughters, and alpha emission

is also accompanied by gamma photon emission which are harmful.

If substances emitting alpha particles are ingested, inhaled, injected

or introduced through the skin, then it could result in a measurable

damaging dose.

The Relative Biological Effectiveness (RBE) is a measure of the

fact that alpha radiation is more effective at causing certain

biological effects, notably either cancer or cell-death, compared to

photo or beta radiation, for equivalent radiation exposure. This is

generally attributable to the high Linear Energy Transfer (LET),

which is about one ionization of a chemical bond for every

Angstrom of travel by the alpha particle. The RBE has been set at

the value of 20 for alpha radiation (DU) by various government

regulations. The RBE is set at 10 for neutron irradiation, and at 1

for beta and ionizing photon radiation.

However, another component of DU's alpha radiation is the recoil

of the parent nucleus, due to the conservation of momentum

requiring the parent nucleus to recoil, much like the 'kick' of a rifle

butt when a bullet goes in the opposite direction. This gives a

significant amount of energy to the recoil nucleus, which also

causes ionization damage. The total energy of the recoil nucleus is

readily calculable, and is roughly the weight of the alpha (4 amu)

divided by the weight of the parent (typically about 200 amu) times

the total energy of the alpha. By some estimates, this might account

for most of the internal radiation damage, as the recoil nuclei are

typically heavy metals which preferentially collect on the

chromosomes. In some studies[2] this has resulted in a RBE

approaching 1,000 instead of the value used in governmental

regulations.

Being relatively heavy and positively charged, alpha particles 

quickly lose kinetic energy within a short distance of their source. 

This results in several Me V of destructive energy being deposited 

in a relatively small volume of material. This increases the chance 

of cellular damage in cases of internal contamination. In general, 

external alpha radiation is not harmful since alpha particles are 

effectively shielded by a few centimeters of air, a piece of paper, or 

the thin layer of dead skin cells. Even touching an alpha source is 

usually not harmful, though many alpha sources also are 

accompanied by beta-emitting radio daughters, and alpha emission 

is also accompanied by gamma photon emission which are harmful. 

If substances emitting alpha particles are ingested, inhaled, injected 

or introduced through the skin, then it could result in a measurable· 

damaging dose. 

The Relative Biological Effectiveness (RBE) is a measure of the 

fact that alpha radiation is more effective at causing certain 

biological effects, notably either cancer or cell-death, compared to 

photo or beta radiation, for equivalent radiation exposure. This is 

generally attributable to the high Linear Energy Transfer (LET), 

which is about one ionization of a chemical bond for every 

Angstrom of travel by the alpha particle. The RBE has been set at 

the value of 20 for alpha radiation (DU) by various government 

regulations. The RBE is set at 10 for neutron irradiation, and at 1 

for beta and ionizing photon radiation. 

However, another component ofDU's alpha radiation is the recoil 

of the parent nucleus, due to the conservation of momentum 

requiring the parent nucleus to recoil, much like the 'kick' of a rifle 

butt when a bullet goes in the opposite direction. This gives a 

significant amount of energy to the recoil nucleus, which also 

causes ionization damage. The total energy of the recoil nucleus is 

readily calculable, and is roughly the weight of the alpha (4 amu) 

divided by the weight of the parent (typically about 200 amu) times 

the total energy of the alpha. By some estimates, this might account 

for most of the internal radiation damage, as the recoil nuclei are 

typically heavy metals which preferentially collect on the 

chromosomes. In some studies[2] this has resulted in a RBE 

approaching 1,000 instead of the value used in governmental 

regulations. 
Normal functioning of mammalian kidney, brain, liver, heart, and

numerous other systems can be affected by uranium exposure,

because in addition to being radioactive, uranium is a toxic

metal.[5]

The Institute of Nuclear Technology-Radiation Protection of Attiki

Greece has noted that "depleted uranium munitions can potentially

contaminate wide areas around the impact sites or can be

inhaled... "16]

Studies using cultured cells and laboratory rodents continue to

suggest the possibility of leukeomgenic, genetic, reproductive, and

neurological effects from chronic exposure.[53] In addition, the UK

Pensions Appeal Tribunal Service in early 2004 attributed birth

defect claims from a February 1991 Gulf War combat veteran to

depleted uranium poisoning.154] [55]

DU is considered both a toxic and radioactive hazard. Its use in

incendiary ammunition is controversial because of potential adverse

health effects and its release into the environment .[56] [57] [58]

[59] [60 [61]

Besides it's residual radioactivity, DU is a heavy metal whose

compounds are know from laboratory studies to be toxic to mammals.

THAT'S WHY

References:

(1) www. ehj ournal.net/content/4/1 / 17

(2) Winters-TH, Franza-JR, Radioactivity in Cigarette Smoke, New England

Journal of Medicine, 1982; 306(6): 364-365

(5) E. S. Craft, A. W. Abu-Qare, M. M. Flaherty, M. C. Garofolo, H. L.

Rincavage, M. B. Abou-Donia (2004). "Depleted and natural uranium:

chemistry and toxicological effects". Journal of Toxicology and Environmental

Health Part B: Critical Reviews 7 (4): 297-317.

(6) Mitsakou C, Eleftheriadis K, Housiadas C, Lazaridis M Modeling of the

dispersion of depleted uranium aerosol.

<http://www.ncbi.nlm.nih.gov/pubmed/12705453> 2003 Apr, Retrieved

January 15, 2009

Normal functioning of mammalian kidney, brain, liver, heart, and 

numerous other systems can be affected by uranium exposure, 

because in addition to being radioactive, uranium is a toxic 

metal. [5] 

The Institute of Nuclear Technology-Radiation Protection of Attiki 

Greece has noted that "depleted uranium munitions can potentially 

contaminate wide areas around the impact sites or can be 

inhaled ... "16] 

Studies using cultured cells and laboratory rodents continue to 

suggest the possibility of leukeomgenic, genetic, reproductive, and 

neurological effects from chronic exposure.[53] In addition, the UK 

Pensions Appeal Tribunal Service in early 2004 attributed birth 

defect claims from a February 1991 Gulf War combat veteran to 

depleted uranium poisoning.154] [55] 

DU is considered both a toxiC and radioactive hazard. Its use in 

incendiary ammunition is controversial because of potential adverse 

health effects and its release into the environment .[56] [57] [58] 

[59] [60 [61] 

Besides it's residual radioactivity, DU is a heavy metal whose 

compounds are know from laboratory studies to be toxic to mammals. 

THAT'S WHY 

References: 

(1) www.ehjournal.netlcontentl4/1/17 

(2) Winters-TH, Franza-JR, Radioactivity in Cigarette Smoke, New England 

Journal of Medicine, 1982; 306(6): 364-365 

(5) E. S. Craft, A. W. Abu-Qare, M. M. Flaherty, M. C. Garofolo, H. L. 

Rincavage, M. B. Abou-Donia (2004). "Depleted and natural uranium: 

chemistry and toxicological effects". Journal of Toxicology and Environmental 

Health Part B: Critical Reviews 7 (4): 297-317. 

(6) Mitsakou C, Eleftheriadis K, Housiadas C, Lazaridis M Modeling of the· 

dispersion of depleted uranium aerosol. 

<http://www.ncbi.nlm.nih.gov/pubmed/12705453> 2003 Apr, Retrieved 

January 15,2009 
(11) Hindin, R. et al. (2005) "Teratogenicity of depleted uranium aerosols: A

review from an epidemiological perspective,"

<http://www.ehjournal.net/content/4/1 / 17> Environmental Health, vol. 4, pp.

17. at PubMed

<http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1242351>

(24) US Dept. of Energy Handbook, "Primer on Spontaneous Heating and

Pyrophoricity"

<http://hss.energy.gov/NuclearSafety/techstds/standard/hdbk 1081/hbk 1081 .ht

ml>, Chapter "Uranium"

<http://hss.energy.gov/NuclearSafety/techstds/standard/hdbk 1081/hbk 1081 e.ht

ml>

(53) Miller AC, McClain D. (2007 Jan-Mar). "A review of depleted uranium

biological effects: in vitro and in vivo studies". Rev Environ Health 22 (1): 75-

89. PMID 17508699 <http://www.ncbi.nlm.nih.gov/pubmed/17508699>.

(54) Williams, M. (February 9, 2004) "First Award for Depleted Uranium

Poisoning Claim," <http://vitw.org/archives/405> The Herald Online,

(Edinburgh: Herald Newspapers, Ltd.)

(55) Campaign Against Depleted Uranium (Spring, 2004) "MoD Forced to Pay

Pension for DU Contamination," <http://www.cadu.org.uk/news/17.htm>

CADU News 17)

(65) Wan B, Fleming J, Schultz T, Sayler G (2006). "In vitro immune toxicity

of depleted uranium: effects on murine macrophages, CD4+ T cells, and gene

expression profiles". Environ Health Perspect 114 (1): 85-91. PMID 16393663

<http://www.ncbi.nlm.nih.gov/pubmed/16393663>.

(66) Arfsten D. P., Still K. R., Ritchie G. D. (2001). "A review of the effects of

uranium and depleted uranium exposure on reproduction and fetal

development.". Toxicol Ind Health 17 (5-10): 180-91. doi

10.1 191/0748233701thl 1 loa

<http://dx.doi.org/10.1 191%2F0748233701thl 1 oa>. PMID 12539863

<http://www.ncbi.nlm.nih.gov/pubmed/12539863>.

(67) Domingo J. L. (2001). "Reproductive and developmental toxicity of

natural and depleted uranium: a review". Reprod Toxicol 15 (6): 603-9

<http://www.ncbi.nlm.nih.gov/pubmed/ 11738513>.

(68) Briner W., Murray J. (2005). "Effects of short-term and long-term

depleted uranium exposure on open-field behavior and brain lipid oxidation in

rats.". Neurotoxicolgy and Teratology 27 (1): 135-44.

<http://www.ncbi.nlm.nih.,gov/pubmed/1 5681127>.

(69) A.C.Miller, D.Beltran, R.Rivas, M.Stewart, R.J.Merlot and P.B. Lison

(June 2005) (PDF), Radiation- and Depleted Uranium-Induced Carcinogenesis

Studies. Characterization of the Carcinogenic Process and Development of

(11) Hindin, R. et al. (2005) "Teratogenicity of depleted uranium aerosols: A 

review from an epidemiological perspective," 

<http://www.ehjoumal.net/contentl411117> Environmental Health, vol. 4, pp. 

17. at PubMed 

<http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1242351> 

(24) US Dept. of Energy Handbook, "Primer on Spontaneous Heating and 

Pyrophoricity" 

<http://hss.energy.govlNuclearSafety/techstds/standardlhdbkl081/hbkl081.ht 

ml>, Chapter "Uranium" 

<http://hss.energy.govlNuclearSafety/techstds/standardlhdbkl081/hbkl081e.ht 

ml> 

(53) Miller AC, McClain D. (2007 Jan-Mar). "A review of depleted uranium 

biological effects: in vitro and in vivo studies". Rev Environ Health 22 (1): 75-

89. PMID 17508699 <http://www.ncbi.nlm.nih.gov/pubmedI17508699>. 

(54) Williams, M. (February 9, 2004) "First Award for Depleted Uranium 

Poisoning Claim," <http://vitw.org/archives/405> The Herald Online, 

(Edinburgh: Herald Newspapers, Ltd.) 

(55) Campaign Against Depleted Uranium (Spring, 2004) "MoD Forced to Pay 

Pension for DU Contamination," <http://www.cadu.org.uk/newsI17.htm> 

CADU News 17) 

(65) Wan B, Fleming J, Schultz T, Sayler G (2006). "In vitro immune toxicity 

of depleted uranium: effects on murine macrophages, CD4+ T cells, and gene 

expression profiles". Environ Health Perspect 114 (1): 85-91. PMID 16393663 

<http://www.ncbi.nlm.nih.gov/pubmedI16393663>. 

(66) Arfsten D. P., Still K. R., Ritchie G. D. (2001). "A review of the effects of 

uranium and depleted uranium exposure on reproduction and fetal 

development.". Toxicol Ind Health 17 (5-10): 180-91. doi 

10.11911074823370lthll10a 

<http://dx.doi.org/l0.1191%2F074823370lthl110a>.PMID 12539863 

<http://www.ncbi.nlm.nih.gov/pubmed/12539863>. 

(67) Domingo J. L. (2001). "Reproductive and developmental toxicity of 

natural and depleted uranium: a review". Reprod Toxicol15 (6): 603-9 

<http://www.ncbi.nlm.nih.gov/pubmedI11738513>. 

(68) Briner W., Murray J. (2005). "Effects of short-term and long-term 

depleted uranium exposure on open-field behavior and brain lipid oxidation in 

rats.". Neurotoxicolgy and Teratology 27 (1): 135-44. 

<http://www.ncbi.nlm.nih.gov/pubmedI15681127>. 

(69) A.C.Miller, D.Beltran, R.Rivas, M.Stewart, R.J.Merlot and P.B. Lison 

(June 2005) (PDF), Radiation- and Depleted Uranium-Induced Carcinogenesis 

Studies: Characterization ofthe Carcinogenic Process and Development of 
Medical Countermeasures

<http://www.afrri.usuhs.mil/www/outreach/pdf/miller NATO 2005.pdf>, CD

05-2, Armed Forces Radiobiology Research Institute, NATO RTG-099 2005

Medical Countermeasures 

<http://www.afrri.usuhs.millwwwloutreach/pdf/millerNAT02005.pdf>.CD 

05-2, Armed Forces Radiobiology Research Institute, NATO RTG-099 2005 

UNITED STATES

NUCLEAR114EGULATORY-COMMISSION

WASHINGTON, D.C. 20555-0001

495

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::; 2: 25 
)oý41 0 Page 1 of 2

As of: October 19, 2009

Received: October 16, 2009

Status: Pending-Post

ITracking No. 8Oa42cbd

Comments Due: October 30, 2009

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0004

Comment on FR Doc # E9-14820

Submitter Information

Name: John Hurd, D.C.

Address: WA

General Comment

Don't fool yourself about what you're dealing with in the context of this alpha emitting radioactive material (DU)

with a half life of 4.5 BILLION YEARS. This is Thalidomide (remember thalidomide?) only FOREVER!

It will have profound genetic repercussions when (not if) it finds it's way into human habitat over the thousands

of millennia it continues to emit alpha particles that smash through DNA like a wrecking ball through a brick

wall creating genetic anomalies, and genetic monsters (teratogenic effect). If you have the stomach for it then

view the attached photos of the effects of DU on the unborn.

Dr. John Hurd

the following is a quote:

"In September 2009, Fallujah General Hospital, Iraq, had 170 new born babies, 24% of whom were dead within

the first seven days, a staggering 75% of the dead babies were classified as deformed.

This can be compared with data from the month of August in 2002 where there were 530 new born babies of

whom six were dead within the first seven days and only one birth defect was reported.

Doctors in Fallujah have specifically pointed out that not only are they witnessing unprecedented numbers of

birth defects but what is more alarming is: "a significant number of babies that do survive begin to develop

severe disabilities at a. later stage."

from: http://www.thewe.cc/weplanet/news/depleted-uranium-iraq-afghanistanbalkans.html

Attachments

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print& Pr'iltd... 10/19/2009

~l~~ lD1 

'11.1 f ~ ,0 I') r 

As of: October 19, 2009 

Received: October 16, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC SUBMISSI Tracking No. 80a42cbd 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0004 

Comment on FR Doc # E9-14820 

Name: John Hurd, D.C. 

Address: WA 

Submitter Information 

General Comment 

Don't fool yourself about what you're dealing with in the context of this alpha emitting radioactive material (DU) 

with a half life of 4.5 BILLION YEARS. This is Thalidomide (remember thalidomide?) only FOREVER! 

It will have profound genetic repercussions when (not if) it finds it's way into human habitat over the thousands 

of millennia it continues to emit alpha particles that smash through DNA like a wrecking ball through a brick 

wall creating genetic anomalies, and genetic monsters (teratogenic effect). If you have the stomach for it then 

view the attached photos of the effects of DU on the unborn. 

Dr. John Hurd 

the following is a quote: 

lOIn September 2009, Fallujah General Hospital, Iraq, had 170 new born babies, 24% of whom were dead within 

the first seven days, a staggering 75% of the dead babies were classified as deformed. 

This can be compared with data from the month of August in 2002 where there were 530 new born babies of 

whom six were dead within the first seven days and only one birth defect was reported. ( 

Doctors in Fallujah have specifically pointed out that not only are they Witnessing unprecedented numbers of 

birth defects but what is more alarming is: lOa significant number of babies that do survive begin to develop 

severe disabilities at a later stage." 

from: http://www.thewe.cc/weplanet/news/depleted_uranium_iraq_afghanistan_balkans.html 
Page 2 of 2

NRC-2009-0257-DRAFT-0004.1:

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NRC-2009-0257-DRAFT-0004.5:

NRC-2009-0257-DRAFT-0004.6:

NRC-2009-0257-DRAFT-0004.7:

N RC-2009-025 7-DRA FT-0004 .8:

Comment on

Comment on

Comment on

Comment on

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Comment on

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Comment on

FR Doc # E9-14820

FR Doc # E9-14820

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https ://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 10/19/2009

NRC-2009-0257-DRAFT-0004.1: Comment on FR Doc # E9-14820 

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PUBLIC SUBMISSION

Page 1 of 1

As of: October 28, 2009

Received: October 28, 2009

Status: Pending-Post

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Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0014

Comment on FR Doc # E9-14820

Submitter Information

Name: Elise Lufkin

Address:

PO Box 2997

101 Greenhorn Loop

Ketchum, ID, 83340

General Comment

To the Nuclear Regulatory Commission:

Please do not license any new facilities for uranium enrichment until there is a clear and safe pathway for

depleted uranium.

Thank you for your consideration of this important issue.

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Page 1 of 1 

As of: October 28, 2009 

PUBLIC SUBMISSI N 

Received: October 28, 2009 

Status: Pending_Post 

Tracking No. 80a4d4d9 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0014 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Elise Lufkin 

Address: 

PO Box 2997 

101 Greenhorn Loop 

Ketchum, ID, 83340 

General Comment 

To the Nuclear Regulatory Commission: 

Please do not license any new facilities for uranium enrichment until there is a clear and safe pathway for 

depleted uranium. 

Thank you for your consideration of this important issue. 

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As of: October 28, 2009

Received: October 28, 2009

Status: Pending-Post

PTracking No. 80a4cabc

Comments Due: October 30, 2009 ,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0009

Comment on FR Doc # E9-14820

Submitter Information ,'

Name: Che' Gilliland

Address: ..-.

128 Keystone Ave.

Coupeville, WA, 98239 m

Submitter's Representative: Rick Larsen <9 CJ.

CD

General Comment

To Whom It May Concern;

I have deep concerns about the proposed rule-making in regard to disposal of Depleted Uranium (DU). Since

there is not a disposal pathway for depleted uranium, the NRC should not license any new enrichment facilities.

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing

disposal of depleted uranium and disposal facilities have implemented those regulations.

The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level

waste disposal facilities.

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU

grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU

disposal in a deep geologic repositor

Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow

land burial is adequate for depleted uranium disposal.

Thank you for your consideration. I hope that you will re-evaluate n cease the disposal and rule-making in

regard to DU until the issue is fully studied.

https://Fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&PrintId... 10/28/2009

As of: October 28, 2009 

Received: October 28, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC SUBMISSI Tracking No. 80a4cabc 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0009 

Comment on FR Doc # E9-14820 

Name: Che' Gilliland 

Address: 

128 Keystone Ave. 

Coupeville, WA, 98239 

Submitter Information 

Submitter's Representative: Rick Larsen 

General Comment 

To Whom It May Concern; 

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I have deep concerns about the proposed rule-making in regard to disposal of Depleted Uranium (DU). Since 

there is not a disposal pathway for depleted uranium, the NRC should not license any new enrichment facilities. 

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing 

disposal of depleted uranium and disposal facilities have implemented those regulations. 

The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be 

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more 

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level 

waste disposal facilities. 

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste 

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU 

grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU 

disposal in a deep geologic repositor 

Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to 

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow 

land burial is adequate for depleted uranium disposal. 

Thank you for your consideration. I hope that you will re-evaluate lnQ cease the disQosal and rule-making in 

regard to DU until th~l~ssue is fully studied. t:~ r~s ~ V\~ \I\\ .... Q~. 

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Page 2 of 2

Sincerely,

Che' Gilliland, Coupeville, WA

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Sincerely, 

Che' Gilliland, Coupeville, WA 

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Page 2 of2 

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Page 1 of 1

'301<

9qL

PUBLIC SUBMISSION

As of: October 28, 2009

Received: October 28, 2009

Status: Pending-Post

Tracking No. 8Oa4cac2

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0010

Comment on FR Doc # E9-14820

Submitter Information

Name: Sheila Plowman

General Comment

Please do not license any new enrichment facilities since there is not a disposal pathway for depleted uranium.

Please keep Idaho clean and free of any uranium contamination.

Sheila Plowman

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Page 1 of 1 

As of: October 28, 2009 

PUBLIC SUBMISSI 

Received: October 28, 2009 

Status: Pending_Post 

Tracking No. 80a4cac2 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: N RC- 2009-0257 -DRAFT -0010 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Sheila Plowman 

General Comment 

Please do not license any new enrichment facilities since there is not a disposal pathway for depleted uranium. 

Please keep Idaho clean and free of any uranium contamination. 

Sheila Plowman 

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Page 1 of 1

•1',X 3oi'75

As of: October 28, 2009

Received: October 28, 2009

Status: Pending-Post PUBLIC' BMISSION Tracking No. 80a4cc05

Comments Due: October 30, 2009

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0011

Comment on FR Doc # E9-14820

(7(

Submitter Information

Name: Mark M Giese

Address: .

1520 Bryn Mawr Ave

Racine, WI, 53403 , Government Agency Type: Federal 00

Government Agency: NRC

General Comment

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU

grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU

disposal in a deep geologic repository.

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing

disposal of depleted uranium and disposal facilities have implemented those regulations.

Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow

land burial is adequate for depleted uranium disposal.

The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level

waste disposal facilities.

e. " a v ( o, 6 I

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 10/28/2009

?/J- vlo '1 

'7Y t:::;( 3aJ'lS 

As of: October 28, 2009 

Received: October 28, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC S BMISSI N Tracking No. 80a4cc05 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0011 

Comment on FR Doc # E9-14820 

Name: Mark M Giese 

Address: 

1520 Bryn Mawr Ave 

Submitter Inform~tion 

Racine, WI, 53403 

Government Agency Type: Federal 

Government Agency: NRC 

General Comment 

•.. , .. ' 

. "'"'""'''' ,-rl 

:~ N 

CJ 

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste 

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU 

grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU 

disposal in a deep geologic repository. 

It is inappropriate to license any new uranium enrichment facility until regulations are in place governing 

disposal of depleted uranium and disposal facilities have implemented those regulations. 

Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to 

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow 

land burial is adequate for depleted uranium disposal. 

The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be 

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more 

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level 

waste disposal facilities. 

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Page 1 of 1

qq,

As of: October 28, 2009

Received: October 28, 2009

U ITracking Status: Pending-Post No. 80a4d408

Comments Due: October 30,

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0012

Comment on FR Doc # E9-14820

2009

I

Submitter Information

General Comment

My first message got lost in space, so I'm making this short and sweet. Please do NOT set rules for depleted

uranium that would weaken our present attempt to provide for safe waste disposal. Please do not license any

new enrichment facilities until we have clear, safe ways of disposing of our waste, long term.

Thanks,

Dori Glennon and Bill Hogan, Pocatello, IDaho

3 ... 

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t'/l-Y/09 

1 L{ F~ 301 rJ ~ 

As of: October 28, 2009 

Received: October 28, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC S BMISSION Tracking No. 80a4d408 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Docu ment: N RC- 2009-0257 -DRAFT -0012 

Comment on FR Doc # E9-14820 

Submitter Information 

General Comment 

My first message got lost in space, so I'm making this short and sweet. Please do NOT set rules for depleted 

uranium that would weaken our present attempt to provide for safe waste disposal. Please do not license any 

new enrichment facilities until we have clear, safe ways of disposing of our waste, long term. 

Thanks, 

Dori Glennon and Bill Hogan, Pocatello, IDaho 

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Page 1 of 1

ý/';? v1d V

As of: October 28, 2009

Received: October 28, 2009

Status: Pending-Post

ITracking No. 80a4cc59

Comments Due: October 30,

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0013

Comment on FR Doc # E9-14820

2009

Submitter Information ,T"

i:- !

Name: Sara Cohn

Address:

P.O. Box 844

Boise, 83701

Organization: Idaho Conservation League

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F1-1

General Comment

See attached file for Idaho Conservation League comments. If there is any problem opening the file, please

contact me at the address listed or at (208) 345-6942 or at scohn@idahoconservation.org.

Attachments

NRC-2009-0257-DRAFT-0013.1: Comment on FR Doc # E9-14820

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As of: October 28, 2009 

Received: October 28, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC SUBMISSI Tracking No. 80a4cc59 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0013 

Comment on FR Doc # E9-14820 

Name: Sara Cohn 

Address: 

P.O. Box 844 

Boise, 83701 

Submitter Information 

Organization: Idaho Conservation League 

General Comment 

t i I 1 

;-T', 

.-._-) .s::: 

. ) 

C) 

See attached file for Idaho Conservation League comments. If there is any problem opening the file, please 

contact me at the address listed or at (208) 345-6942 or at scohn@idahoconservation.org. 

Attachments 

NRC-2009-0257-DRAFT-0013.1: Comment on FR Doc # E9-14820 

s\AN~1 ~tJ~t~ CP\A1t(~( 

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https:llfdms.erulemaking.net/fdms-web-agency/ componentl submitter InfoCover Page ?Call = Print&PrintI d... 10/28/2009 
www.wildidaho.org

Ida Conservation League / /0 PO Box 844, Boise, ID 83701

' i' '~208.345.6933

Chief, Rulemaking and Directives Branch October 28, 2009

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Mail Stop TWB-05-BO1M

Washington, DC 20555-0001

RE: Federal Register June 24, 2009, pgs 30175-30179 - Notice of Public Workshop on a

Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

To Whom it May Concern;

Thank you for the opportunity to provide comments on the notice of public workshops

and potential rulemaking activities for the safe disposal of unique waste steams including

significant quantities of depleted uranium. Since 1973, the Idaho Conservation League

(ICL) has been Idaho's voice for clean water, clean air, and wilderness-values that are the

foundation to Idaho's extraordinary quality of life. As Idaho's largest state-based

conservation organization we represent over 9,800 members, many of whom have a deep

personal interest in protecting Idaho's natural resources and public health.

The ICL is aware the public workshops and proposed rulemaking will likely influence the

storage of significant amounts of depleted uranium produced by the proposed AREVA

Enrichment facility in Idaho Falls, Idaho (see Attachment A, Scoping Comments for

Proposed AREVA Enrichment Services, LLC Eagle Rock Enrichment, Idaho Falls, ID -

Docket No. 70-7015, June 18, 2009). Temporary or long-term storage of significant

amounts of depleted uranium may result in the release of pollutants to Idaho's natural

resources or may compromise public health. As the Nuclear Regulatory Commission

(NRC) proceeds with the public workshops and the proposed rulemaking, further analysis

and guidance must be provided to ensure that no adverse impacts occur to pollute Idaho's

clean water and clean air, or endanger public health.

Specifically, we suggest the following:

* More clarity is needed with regard to the scope of the potential rulemaking.

* Until regulations are in place governing disposal of depleted uranium and disposal

facilities have implemented those regulations, it is inappropriate to license any new

uranium enrichment facility.

* The NRC should coordinate with appropriate federal agencies, such as the U.S.

Environmental Protection Agency (EPA) and others, to ensure comprehensive

analysis of potential disposal sites and to protect natural resource, human health,

ICLCor~n~nt ;VC uhlc'wo;ksopsan o prpoed ulmakngdepleted uranium Fg PagelIof o'II

www.wildidaho.org 

Conservation League 

PO Box 844, Boise, 1083701 

208.345.6933 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Mail Stop TWB-05-BOIM 

Washington, DC 20555-0001 

October 28, 2009 

RE: Federal Register June 24,2009, pgs 30175-30179 - Notice of Public Workshop on a 

Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

To Whom it May Concern; 

Thank you for the opportunity to provide comments on the notice of public workshops 

and potential rulemaking activities for the safe disposal of unique waste steams including 

significant quantities of depleted uranium. Since 1973, the Idaho Conservation League 

(ICL) has been Idaho's voice for clean water, clean air, and wilderness-values that are the 

foundation to Idaho's extraordinary quality of life. As Idaho's largest state-based 

conservation organization we represent over 9,800 members, many of whom have a deep 

personal interest in protecting Idaho's natural resources and public health. 

The ICL is aware the public workshops and proposed rulemaking will likely influence the 

storage of significant amounts of depleted uranium produced by the proposed AREVA 

Enrichment facility in Idaho Falls, Idaho (see Attachment A, Scoping Comments for 

Proposed ARE VA Enrichment Services, LLC Eagle Rock Enrichment, Idaho Falls, ID -

Docket No. 70-7015, June 18,2009). Temporaryorlong-term storage of significant 

amounts of depleted uranium may result in the release of pollutants to Idaho's natural 

resources or may compromise public health. As the Nuclear Regulatory Commission 

(NRC) proceeds with the public workshops and the proposed rulemaking, further analysis 

and guidance must be provided to ensure that no adverse impacts occur to pollute Idaho's 

clean water and clean air, or endanger public health. 

Specifically, we suggest the following: 

• More clarity is needed with regard to the scope of the potential rulemaking. 

• Until regulations are in place governing disposal of depleted uranium and disposal 

facilities have implemented those regulations, it is inappropriate to license any new 

uranium enrichment facility. 

• The NRC should coordinate with appropriate federal agencies, such as the U.S. 

Environmental Protection Agency (EPA) and others, to ensure comprehensive 

analysis of potential disposal sites and to protect natural resource, human health, 

leL Comments 011 NRC puhliC workshops alld pl'Oposed rulemakillg - depleted uranium Page 10111 
and national security.

We look forward to working with the NRC, additional federal agencies and interested

parties to design rules that guide the storage of depleted uranium waste, preserve Idaho's

natural resources, and provide adequate assurances that storage will not adversely impact

public health. Please find my contact information below and keep us on the list to receive

additional public notices with regard to the workshops and proposed rulemaking.

Sincerely,

Sara Cohn

Community Conservation Associate

Idaho Conservation League

P.O. Box 844

Boise, Idaho 83701

(208) 345-6942 ex 23

ICL Comments on NRC public workshops and proposed rulemaking - depleted uranium Pagje 20]" I

and national security. 

We look forward to working with the NRC, additional federal agencies and interested 

parties to design rules that guide the storage of depleted uranium waste, preserve Idaho's 

natural resources, and provide adequate assurances that storage will not adversely impact 

public health. Please find my contact information below and keep us on the list to receive 

additional public notices with regard to the workshops and proposed rulemaking. 

Sincerely, 

Sara Cohn 

Community Conservation Associate 

Idaho Conservation League 

P.O. Box 844 

Boise, Idaho 83701 

(208) 345-6942 ex 23 

ICL Comments 011 NRC public workshops alld proposed rulemakinlJ - depleted uranium Page 20/'.11 
ICL Comment Regarding Public Workshops and Potential Rulemaking for Safe Disposal

of Unique Waste Streams Including Significant Quantities of Depleted Uranium

Scope of Workshops and Potential Rulemaking

The Federal Register Notice provided limited guidance with regard to the scope of the

proposed rulemaking. It is unclear what types of waste will be included in workshop

discussions or the potential rule. Based on the information provided, it is not possible to

conclude that is appropriate to combine the guidance for safe disposal of undefined "unique waste streams" and significant quantities of depleted uranium. NRC should

provide a definition for "other unique waste streams" to further inform workshop

discussions and ensure that any potential rule developed is appropriate for type of waste

slated for disposal. It is also unclear what type of facility would be considered a disposal

site. NRC should clarify whether workshops or potential rulemaking will address both the

temporary and long term storage/disposal of depleted uranium and other waste streams.

NRC should provide clarity regarding the definition of "disposal" in this context.

Permitting Enrichment Facilities

ICL has provided public comments on NEPA scoping analysis for the proposed AREVA

Enrichment facility in Idaho Falls, Idaho (see Attachment A). As the current Federal

Register announcement suggests, NRC does not currently provide adequate guidance for

the type of waste streams that will be created by the proposed AREVA enrichment facility.

Until regulations are in place governing disposal of depleted uranium and disposal facilities

have implemented those regulations, ICL believes it is inappropriate to license any new

uranium enrichment facility. NRC should consider the creation of adequate rules to guide

the safe disposal of depleted uranium as paramount to permitting individual facilities.

Coordination with Associated Federal Agencies

Depleted uranium and other unique waste streams pose as a threat to natural resources,

public health, and national security. As such, the NRC should coordinate with relevant

federal agencies during the workshop and potential rulemaking. Such agencies would

include the EPA, the National Security Agency (NSA), the Department of Energy, the

Department Homeland Security, the U.S. Department of Health and Human Services,

among others. NRC should consult and coordinate with these agencies to ensure that the

guidance for disposal of unique waste streams and depleted uranium is consistent with

existing regulations that protect natural resources, public health, and national security.

IC(L Comme*nts onl IRC public: tvfk5Th1.s and proiCposed rulemok/ing depletedl aroniumnPg P(?fj., 3of o I' I

ICL Comment Regarding Public Workshops and Potential Rulemaking for Safe Disposal 

of Unique Waste Streams Including Significant Quantities of Depleted Uranium 

Scope of Workshops and Potential Rulemaking 

The Federal Register Notice provided limited guidance with regard to the scope of the 

proposed rulemaking. It is unclear what types of waste will be included in workshop 

discussion~ or the potential rule. Based on the information provided, it is not possible to 

conclude that is appropriate to combine the guidance for safe disposal of undefined 

"unique waste streams" and significant quantities of depleted uranium. NRC should 

provide a definition for "other unique waste streams" to further inform workshop 

discussions and ensure that any potential rule developed is appropriate for type of waste 

slated for disposal. It is also unclear what type of facility would be considered a disposal 

site. NRC should clarify whether workshops or potential rulemaking will address both the 

temporary and long term storage/disposal of depleted uranium and other waste streams. 

NRC should provide clarity regarding the definition of "disposal" in this context. 

Permitting Enrichment Facilities 

ICL has provided public comments on NEPA scoping analysis for the proposed AREVA 

Enrichment facility in Idaho Falls, Idaho (see Attachment A). As the current Federal 

Register announcement suggests, NRC does not currently provide adequate guidance for 

the type of waste streams that will be created by the proposed AREV A enrichmen t facility. 

Until regulations are in place governing disposal of depleted uranium and disposal facilities 

have implemented those regulations, ICL believes it is inappropriate to license any new 

uranium enrichment facility. NRC should consider the creation of adequate rules to guide 

the safe disposal of depleted uranium as paramount to permitting individual facilities. 

Coordination with Associated Federal Agencies 

Depleted uranium and other unique waste streams pose as a threat to natural resources, 

public health, and national security. As such, the NRC should coordinate with relevant 

federal agencies during the workshop and potential rulemaking. Such agencies would 

include the EPA, the National Security Agency (NSA), the Department of Energy, the 

Department Homeland Security, the U.S. Department of Health and Human Services, 

among others. NRC should consult and coordinate with these agencies to ensure that the 

guidance for disposal of unique waste streams and depleted uranium is consistent with 

existing regulations that protect natural resources, public health, and national security. 

leL Comments on NRC puhlic workshops Imd ruiemo/{ing - depleted u['onium 
Attachment A

ICL Scoping Comments for Proposed AREVA Enrichment Services, LLC Eagle Rock

Enrichment, Idaho Falls, ID - Docket No. 70-7015

1CL Conmments on NRC public workshops and proposed rulemakinq - depleted uranium Puge, 4of 11

Attachment A 

ICL Scoping Comments for Proposed AREVA Enrichment Services, LLC Eagle Rock 

Enrichment, Idaho Falls, ID - Docket No. 70-7015 

TCL Comments 011 NRC puhlic workshops alla proposed rulemaking - deple/:ed Ilranillll' Page 40/11 
wwwwildidaho.org

V Idaho Conservation League

PO Box 844, Boise, ID 83701

208.345.6933

Chief, Rules and Directives Branch June 18, 2009

Mail Stop TWB-05-BO1

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

RE: Scoping Comments for Proposed AREVA Enrichment Services, LLC Eagle Rock

Enrichment, Idaho Falls, ID - Docket No. 70-7015

To Whom it May Concern;

Thank you for the opportunity to comment on the Notice of Intent and Environmental

Report for the proposed AREVA Enrichment facility in Idaho Falls, Idaho. Since 1973, the

Idaho Conservation League (ICL) has been Idaho's voice for clean water, clean air, and

wilderness-values that are the foundation to Idaho's extraordinary quality of life. The

Idaho Conservation League works to protect these values through citizen action, public

education, and professional advocacy. As Idaho's largest state-based conservation

organization we represent over 9,800 members, many of whom have a deep personal

interest in protecting Idaho's natural resources and public health.

The ICL has reviewed the Environmental Report for the Eagle Rock Enrichment facility

and is concerned that construction and operation of the facility will pollute Idaho's

natural resources and compromise public health. The Environmental Report does not

provide the level of detail that would ensure the reduction of impacts or appropriate

mitigation plans. More detailed analysis must be given in subsequent documents to ensure

that no adverse impacts occur that pollute Idaho's clean water and clean air, or endanger

public health.

Specifically, we request that further analysis and mitigations plans will be prepared to:

* reduce the risks associated with transport and storage of toxic, hazardous, and/or

radioactive materials;

* ensure no contamination of Idaho's waters;

* preserve Idaho's clean air;

* protect public health;

* analyze all potential risk associated with hazardous materials onsite, whether

existing or proposed for storage;

* adequately document and mitigate for wildlife and habitat disturbances;

* and, reduce the risk of accident and fire.

We look forward to working with the project proponent, the U.S. Nuclear Regulatory

Commission (NRC), additional federal agencies and interested parties to design a project

that preserves Idaho's natural resources and provides adequate assurances that the project

ICL Comments on NRC public workshops and proposed rulemaking - depleted uranium Palge 5o/"I11

r.rl,nc::".n.l::atinn League 

PO Box 844, Boise, 10 83701 

208.345.6933 

Chief, Rules and Directives Branch 

Mail Stop TWB-05-BO 1 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

June 18,2009 

RE: Scoping Comments for Proposed AREVA Enrichment Services, LLC Eagle Rock 

Enrichment, Idaho Falls, ID - Docket No. 70-7015 

To Whom it May Concern; 

Thank you for the opportunity to comment on the Notice of Intent and Environmental 

Report for the proposed AREVA Enrichment facility in Idaho Falls, Idaho. Since 1973, the 

Idaho Conservation League (ICL) has been Idaho's voice for clean water, clean air, and 

wilderness-values that are the foundation to Idaho's extraordinary quality of life. The 

Idaho Conservation League works to protect these values through citizen action, public 

education, and professional advocacy. As Idaho's largest state-based conservation 

organization we represent over 9,800 members, many of whom have a deep personal 

interest in protecting Idaho's natural resources and public health. 

The ICL has reviewed the Environmental Report for the Eagle Rock Enrichment facility 

and is concerned that construction and operation of the facility will pollute Idaho's 

natural resources and compromise public health. The Environmental Report does not 

provide the level of detail that would ensure the reduction of impacts or appropriate 

mitigation plans. More detailed analysis must be given in subsequent documents to ensure 

that no adverse impacts occur that pollute Idaho's clean water and clean air, or endanger 

public health. 

Specifically, we request that further analysis and mitigations plans will be prepared to: 

• reduce the risks associated with transport and storage of toxic, hazardous, and/or 

radioactive materials; 

• ensure no contamination of Idaho's waters; 

• preserve Idaho's clean air; 

• protect public health; 

• analyze all potential risk associated with hazardous materials onsite, whether 

existing or proposed for storage; 

• adequately document and mitigate for wildlife and habitat disturbances; 

• and, reduce the risk of accident and fire. 

We look forward to working with the project proponent, the U.S. Nuclear Regulatory 

Commission (NRC), additional federal agencies and interested parties to design a project 

that preserves Idaho's natural resources and provides adequate assurances that the project 

lCl. Comments 011 NRC public workshops and proposed rulemakillg - depleted uranium Page 50/11 
will not adversely impact public health. Please keep us on the list to receive both a hard

copy and an electronic copy of the Draft EIS.

Sincerely,

Sara Cohn

Community Conservation Associate

Idaho Conservation League

ICL Conm-ments on NRC purblic workshops amd proposed rulemaking - depleted uranium Poge 6of.1I

will not adversely impact public health. Please keep us on the list to receive both a hard 

copy and an electronic copy of the Draft EIS. 

Sincerely, 

Sara Cohn 

Community Conservation Associate 

Idaho Conservation League 

Ie£, Comments on NRC public workshops and proposed ru!emoking - depleted uranium Page 60f.11 
ICL Comments regarding AREVA Enrichment Services, Idaho Falls, Idaho

Transportation

The ICL is very concerned about the transportation of hazardous and toxic materials to

and from the project site. Based on the size of the facility and the number of trips

expected to transport hazardous and toxic materials, the possibility of accidental spills and

subsequent contamination is high. Further analysis will be needed to ensure that the

transport of hazardous materials to and from the site will not result in the pollution of

Idaho's waters and air, or endanger public health. More information is needed to

understand the size and scale of the enrichment facility, the amount of waste produced

and transported from the site, and the amount of hazardous and toxic materials imported

and exported from the site. We also request information regarding the methods of

transport and the. types of containment vessels that will be used to transport materials.

Detailed plans should be prepared to reduce contamination and public health risks in the

event of a spill or accident during transport.

The Environmental Report does not provide cumulative risk analysis regarding the amount

of hazardous or toxic materials to be imported and exported across state lines. The

documents provided do not appropriately consider methods to minimize risks associated

with transport routes options. Alternative transportation modes, such as rail, should be

further analyzed. Transportation routes and modes that present significant risk to public

health and natural resources should be avoided.

Permanent impacts associated with the project include the construction of two access

roads from Highway 20 to the project site. Further analysis of this impact must include

additional risk associated with fire and the spread of invasive weeds (for more detail on this

topic see subsection Environmental Resources - Invasive Weeds).

Water Resources

The ICL is very concerned that spillage or leakage of hazardous materials and waste from

the proposed facility will contaminate Idaho's surface or groundwater. We are concerned

that there will be large quantities of hazardous, toxic, and radioactive materials produced

and stored onsite and that these materials may contaminate Idaho's waters. The Snake

River Plain Aquifer is southern Idaho's primary source of drinking and irrigation water.

Should the facility operations result in the contamination of the aquifer, this pollution

would have wide reaching affects on public health and Idaho's agricultural economy. Toxic

and radioactive materials from enrichment facilities have been shown to leak through

detention basins and contaminate groundwater. We are very concerned the proposed

facility may contaminate Idaho's waters the way similar facilities have contaminated

groundwater in Paducah, KY and Portsmouth, OH.

Due to the amount of pollutants expected to be stored onsite, the extremely hazardous

nature of waste products like depleted uranium, the possibility of waste spills, the

possibility of leakage from proposed retention basins, and the importance of the Snake

River Plain Aquifer, much more information is needed to ensure no endangerment of

public health or contamination of precious water resources. We request more information

ICL Comments on NRC public workshotps and proposed rulemakinq - depleted ur'anium Pagqe 7of' 1 :

ICL Comments regarding AREVA Enrichment Services, Idaho Falls, Idaho 

Transportation 

The ICL is very concerned about the transportation of hazardous and toxic materials to 

and from the project site. Based on the size of the facility and the number of trips 

expected to transport hazardous and toxic materials, the possibility of accidental spills and 

subsequent contamination is high. Further analysis will be needed to ensure that the 

transport of hazardous materials to and from the site will not result in the pollution of 

Idaho's waters and air, or endanger public health. More information is needed to 

understand the size and scale of the enrichment facility, the amount of waste produced 

and transported from the site, and the amount of hazardous and toxic materials imported 

and exported from the site. We also request information regarding the methods of 

transport and the, types of containment vessels that will be used to transport materials. 

Detailed plans should be prepared to reduce con tamination and public health risks in the 

event of a spill or accident during transport. 

The Environmental Report does not provide cumulative risk analysis regarding the amount 

of hazardous or toxic materials to be imported and exported across state lines. The 

documents provided do not appropriately consider methods to minimize risks associated 

with transport routes options. Alternative transportation modes, such as rail, should be 

further analyzed. Transportation routes and modes that present significant risk to public 

health and natural resources should be avoided. 

Permanent impacts associated with the project include the construction of two access 

roads from Highway 20 to the project site. Further analysis of this impact must include 

additional risk associated with fire and the spread of invasive weeds (for more detail on this 

topic see subsection Environmental Resources - Invasive Weeds). 

Water Resources 

The ICL is very concerned that spillage or leakage of hazardous materials and waste from 

the proposed facility will contaminate Idaho's surface or groundwater. We are concerned 

that there will be large quantities of hazardous, toxic, and radioactive materials produced 

and stored onsite and that these materials may contaminate Idaho's waters. The Snake 

River Plain Aquifer is southern Idaho's primary source of drinking and irrigation water. 

Should the facility operations result in the contamination of the aquifer, this pollution 

would have wide reaching affects on public health and Idaho's agricultural economy. Toxic 

and radioactive materials from enrichment facilities have been shown to leak through 

detention basins and contaminate groundwater. We are very concerned the proposed 

facility may contaminate Idaho's waters the way similar facilities have contaminated 

groundwater in Paducah, KY and Portsmouth, OH. 

Due to the amount of pollutants expected to be stored onsite, the extremely hazardous 

nature of waste products like depleted uranium, the possibility of waste spills, the 

possibility of leakage from proposed retention basins, and the importance of the Snake 

River Plain Aquifer, much more information is needed to ensure no endangerment of 

public health or contamination of precious water resources. We request more information 

tCL Comments 011 NRC public workshops ([!ld pmposed rulemakil1{1 - depleted uranium Page 70/11 
with regard to the amount of waste and hazardous materials expected to be stored onsite,

the types of preventative measures that will be in place to ensure no contamination of

water, as well as plans outlining monitoring and reporting methods and responsible

parties. The applicant should also prepare reports and plans that detail the roles and

responsibilities of agencies and AREVA in the event of spillage or contamination from the

site. These plans should outline remediation, public alerts, public safety measures, and

clean up strategies, among all other necessary actions to protect environmental and public

health.

Nitrate contamination of groundwater is also of concern. Recent findings indicate that

long-term exposure to elevated concentrations of nitrate may contribute to the risk of

developing bladder and ovarian cancers1 and non-Hodgkin's lymphoma2.

Air Quality

The ICL is very concerned about the potential release of radioactive, hazardous and toxic

materials into the air. Potential air releases associated with operation of this facility should

be further analyzed, reported, and permitted though Idaho's Department of

Environmental Quality. The environmental documents mention the use of Gaseous

Effluent Ventilation Systems. We are concerned about the waste associated with the

ventilation system and would like more detail with regard to the use and disposal of any

filter-like product that may contain pollutants. We also concerned that hazardous

materials will be concentrated in retention basins prior to and after evaporation of any

water. These materials have the potential to settle in sediments and be released into the air

with other dust particles.

We request that the applicant include air monitoring and reporting plans that are specific

to the operations of the proposed facility. These plans should include guidance for public

alerts, immediate containment, responsible parties, etc., should air releases be detected.

Air pollution resulting from construction of the proposed facility should be avoided or

reduced using the best available management practices and control technology. To preserve

Idaho's clean air during construction operations, the NRC should include mitigation

measures for these pollutants. For example, fugitive dust emissions can be controlled

through the use of water trucks, provided the Storm Water Pollution Prevention Program

(SWPPP) ensures no discharge of sediment from the site. Additionally, diesel emissions

should be reduced using best management practices for construction including limited

idling of diesel equipment and the use of low-emitting fuels and low-emitting technology

for construction equipment.

Public Health

The ICL is concerned that operation of this facility may expose Idahoans to'toxic,

radioactive, and/or harmful pollutants. Further detail and analysis must investigate risks

'Weyer, P.J., Cerhan, J.R., Kross, B.C., Hallberg, G.R., Kantamneni, J., Breuer, G., Jones, M.P., Zheng, W., and

Lynch, C.F., 2001, Municipal drinking water nitrate level and cancer risk in older women: the Iowa women's

health study Epidemiology, v. 11, p. 32 7-338. 2 Ward, M.H., Mark, S.D., Cantor, K.P., Weisenburger, D.D., Correa-Villasenor, A., and Zahm, S.H., 1996,

Drinking water nitrate and the risk of non-Hodgkin's lymphoma: Epidemiology, v. 7, p. 465-471.

UCL Commentas omi NRC public workshops and proposed rulemokinsc - depletted uranium Pag~e 80f I1

with regard to the amount of waste and hazardous materials expected to be stored onsite, 

the types of preventative measures that will be in place to ensure no contamination of 

water, as well as plans outlining monitoring and reporting methods and responsible 

parties. The applicant should also prepare reports and plans that detail the roles and 

responsibilities of agencies and AREVA in the event of spillage or contamination from the 

site. These plans should outline remediation, public alerts, public safety measures, and 

clean up strategies, among all other necessary actions to protect environmental and public 

health. 

Nitr~te contamination of groundwater is also of concern. Recent findings indicate that 

long-term exposure to elevated concentrations of hitrate may contribute to the risk of 

developing bladder and ovarian cancersl and non-Hodgkin's lyrnphoma2

• 

Air Quality 

The ICL is very concerned about the potential release of radioactive, hazardous and toxic 

materials into the air. Potential air releases associated with operation of this facility should 

be further analyzed, reported, and permitted though Idaho's Department of 

Environmental Quality. The environmental documents mention the use of Gaseous 

Effluent Ventilation Systems. We are concerned about the waste associated with the 

ventilation system and would like more detail with regard to the use and disposal of any 

filter-like product that may contain pollutants. We also concerned that hazardous 

materials will be concentrated in retention basins prior to and after evaporation of any 

water. These materials have the potential to settle in sediments and be released into the air 

with other dust particles. 

We request that the applicant include air monitoring and reporting plans that are specific 

to the operations of the proposed facility. These plans should include guidance for public 

alerts, immediate containment, responsible parties, etc., should air releases be detected. 

Air pollution resulting from construction of the proposed facility should be avoided or 

reduced using the best available management practices and control technology. To preserve 

Idaho's clean air during construction operations, the NRC should include mitigation 

measures for these pollutants. For example, fugitive dust emissions can be controlled 

through the use of water trucks, provided the Storm Water Pollution Prevention Program 

(SWPPP) ensures no discharge of sediment from the site. Additionally, diesel emissions 

should be reduced using best management practices for construction including limited 

idling of diesel equipment and the use of low-emitting fuels and low-emitting technology 

for construction equipment. 

Public Health 

The ICL is concerned that operation of this facility may expose Idahoans to toxic, 

radioactive, and/or harmful pollutants. Further detail and analysis must investigate risks 

1 Weyer, P .J., Cerhan, J.R., Kross, B.C., Hallberg, G.R., Kantamneni, J., Breuer, G., Jones, M.P., Zheng, W., and 

Lynch, c.P., 2001, Municipal drinking water nitrate level and cancer risk in older women: the Iowa women's 

health study: Epidemiology, v. 11, p. 327 -338. 

2 Ward,M.H., Mark, S.D., Cantor, K.P., Weisenburger, D.D., Correa-Villasenor,A., and Zahm, S.H., 1996, 

Drinking water nitrate and the risk of non-Hodgkin's lymphoma: Epidemiology, v. 7, p. 465-471. 

10, Comments on NRC puhlic workshops and pl'Oposed rulemaking - depteted uranium Puge Bolli 
associated with water and air contamination from enrichment operations. We request

detailed information regarding the amounts and types of materials used, produced, and

stored onsite. We would like detailed information about how these materials may be

released and how releases may endanger public health. Detailed plans to contain releases as

well as alert and protect the public will, be essential. Additionally, further analysis must

ensure no air releases during transportation of both uranium product and waste to and

from the site. The health of Idahoans is of primary import and should not be compromised

by enrichment product, waste, or transport.

Hazardous Materials

The impact analysis did not contain any information regarding hazardous materials

existing onsite, or proposed for storage. The EIS must provide information with regard to

any hazardous materials existing or proposed for storage onsite and any cumulative risk

associated with the storage, transport, and use of hazardous materials during project

operations. Additionally, subsequent environmental documentation must include a

Management Plan for Toxic and Hazardous Materials. This plan should address health and

accident risks associated with toxic and hazardous materials onsite as well as accident

prevention and management strategies. This information is incredibly important to

protect the health and lives of emergency responders and communities such as Idaho Falls,

Pocatello, and others that would potentially be harmed by facility operations. The ICL is

concerned that a hazardous materials analysis was not included in the environmental

analysis and we look forward to evaluating information on this subject.

Ecological Resources

The Environmental Report does not adequately address impacts to ecological resources on

site. Due to pending sage-grouse and pygmy rabbit Endangered Species Act (ESA) listing,

we suggest the applicant prepare environmental documentation and pursue the

appropriate permits in anticipation of this ESA listing.

Avoid, Minimize, Mitigate

In terms of priorities, the NRC should first site facilities and infrastructure to avoid

impacts to wildlife and cultural resources. Ifimpacts cannot be entirely avoided, the NRC

should incorporate design features to minimize impacts. Lastly, a plan should be prepared

to mitigate for impacts that cannot be avoided or minimized.

Habitat, habitat fragmentation, and migration corridors

Portions of the project area contain habitat that is crucial to the sagebrush steppe obligate

species such as sage-grouse, pygmy rabbits, sage thrasher, sage sparrow, and others. Such

habitat has been severely fragmented and reduced through a variety of land management

practices, including road construction and development of rights of way corridors.

Although communities can't be listed under the endangered species act, sagebrush steppe

habitat is considered by federal agencies as "imperiled" and an area of primary concern.

The project should minimize negative impacts by avoiding areas of critical habitat for

species of concern, establishing siting criteria to minimize soil disturbance and erosion on

steep slopes, utilizing visual resource management guidelines, avoiding significant historic

and cultural resource sites, and mitigating any potential disturbance of this habitat.

1(1, C7ommentfus oni IRC p ublic workshlops and proposo,ýd ru lemaking - depleted uraniumPae9]1 Page 9of.1 I1

associated with water and air contamination from enrichment operations. We request 

detailed information regarding the amounts and types of materials used, produced, and 

stored onsite. We would like detailed information about how these materials may be 

released and how releases may endanger public health. Detailed plans to contain releases as 

well as alert and protect the public will be essential. Additionally, further analysis must 

ensure no air releases during transportation of both uranium product and waste to and 

from the site. The health of Idahoans is of primary import and should not be compromised 

by enrichment product, waste, or transport. 

Hazardous Materials 

The impact analysis did not contain any information regarding hazardous materials 

existing onsite, or proposed for storage. The EIS must provide information with regard to 

any hazardous materials existing or proposed for storage onsite and any cumulative risk 

associated with the storage, transport, and use of hazardous materials during project 

operations. Additionally, subsequent environmental documentation must inclllde a 

Management Plan for Toxic and Hazardous Materials. This plan should address health and 

accident risks associated with toxic and hazardous materials onsite as well as accident 

prevention and management strategies. This information is incredibly important to 

protect the health and lives of emergency responders and communities such as Idaho Falls, 

Pocatello, and others that would potentially be harmed by facility operations. The ICL is 

concerned that a hazardous materials analysis was not included in the environmental 

analysis and we look forward to evaluating information on this subject. 

Ecological Resources 

The Environmental Report does not adequately address impacts to ecological resources on 

site. Due to pending sage-grouse and pygmy rabbit Endangered Species Act (ESA) listing, 

we suggest the applicant prepare environmental documentation and pursue the 

appropriate permits in anticipation of this ESA listing. 

Avoid, Minimize, Mitigate 

In terms of priorities, the NRC should first site facilities and infrastructure to avoid 

impacts to wildlife and cultural resources. lfimpacts cannot be entirely avoided, the NRC 

should incorporate design features to minimize impacts. Lastly, a plan should be prepared 

to mitigate for impacts that cannot be avoided or minimized. 

Habitat, habitat fragmentation, and migration corridors 

Portions of the project area contain habitat that is crucial to the sagebrush steppe obligate 

species such as sage-grouse, pygmy rabbits, sage thrasher, sage sparrow, and others. Such 

habitat has been severely fragmented and reduced through a variety of land management 

practices, including road construction and development of rights of way corridors. 

Although communities can't be listed under the endangered speCies act, sagebrush steppe 

habitat is considered by federal agencies as "imperiled" and an area of primary concern. 

The project should minimize negative impacts by avoiding areas of critical habitat for 

species of concern, establishing siting criteria to minimize soil disturbance and erosion on 

steep slopes, utilizing visual resource management guidelines, avoiding significant historic 

and cultural resource sites, and mitigating any potential disturbance of this habitat. 

leI.. Comments 011 NRC puhlic workshops alld proposed rulemaking - depleted uranium Page 90f11 
Sage-grouse

There is significant concern regarding the long-term viability of greater sage-grouse

populations. The US Fish and Wildlife Service is currently conducting a finding of

determination whether greater sage-grouse deserve protections under the Endangered

Species Act. These protections could have far reaching effects on land management in

Idaho and in the region.

Greater sage-grouse suffer from the loss, degradation, and fragmentation of habitat

throughout the west. It's estimated that only 50-60% of the original sagebrush steppe

habitat remains in the west (West 2000), and in 2007, the American Bird Conservancy

listed sagebrush as the most threatened bird habitat in the continental United States. As

such, we cannot stress enough how important it is for agencies to consider impacts to sagegrouse, conserve existing habitat, and actively restore altered sagebrush steppe habitats due

to project-related impacts.

Depending on location and design specifics, the construction of additional roads within

sage-grouse habitat could constitute "nonlinear infrastructure" under the Conservation

Plan for the Greater Sage-grouse in Idaho (Idaho Sage-Grouse Advisory Committee 2006).

Nonlinear infrastructure is defined as "human-made features on the landscape that

provide or facilitate transportation, energy, and communications activities." 'The

Conservation Plan lists infrastructure such as this as the second greatest threat for sage

grouse, with wildfires as the greatest risk. Road construction and use associated with the

facility represents high risk for loss of lek areas, nesting locations, and brood-rearing

habitats (Braun 1986, Connelly et al. 2004). 5 6

Coordination with local stakeholder groups

We believe that an integral part of conserving and recovering sage-grouse will be relying on

the guidance from local stakeholder groups. As such, we recommend that the applicant

coordinate further efforts more closely with the US Fish and Wildlife Service, local Sagegrouse Working Groups, the Idaho State Sage Grouse Advisory Council, the Idaho

Department of Fish and Game, and the Governor's Office of Species Conservation.

Conservation groups to consult include the Audubon Society, the Idaho Chapter of the

North American Grouse Partnership, the Idaho Falconer's Association, the Nature

Conservancy, the Western Watersheds Project as well as the Idaho Conservation League.

Additional Wildlife

In addition to sage-grouse, other wildlife including pygmy rabbits, sage thrasher, sage

sparrow, and birds of prey, are of concern. New construction and infrastructure will also

change crucial habitat for these species and may inhibit the ability .of these species to

migrate. The project design should avoid construction in any designated areas or lands for

3 West, N.E. Synecology and disturbance regimes of sagebrush steppe ecosystems, p. 15-26. In P.G. Entwistle,

A.M. DeBolt, J.H. Kaltenecker, and K. Steenhoff, Proceedings: sagebrush steppe ecosystems symposium. USDI

Bureau of Land Management Publication BLM/ID/PT-00 1001+1150, Boise, ID.

Idaho Sage-Grouse Advisory Committee. 2006. Conservation Plan for the Greater Sage-grouse in Idaho. 5 Braun, C.E. 1986. Changes in sage-grouse lek counts with advent of surface coal mining. Proceedings, Issues

and technology in the management of impacted western wildlife. Thorne Ecological Institute 2:227-231. 6 Connelly, J.W., Knick, S.T., Schroeder, M.A., and S.J. Stiver. 2004. Conservation assessment of greater sagegrouse and sagebrush habitats. Western Association of Fish and Wildlife Agencies. Unpublished Report.

Cheyenne, Wyoming.

/. CL nomnients on NRC public workshops and propo.sed rulemokinyq - depleted uraniumor Paye 10o/f I I

Sage-grouse 

There is significant concern regarding the long-term viability of greater sage-grouse 

populations. The US Fish and Wildlife Service is currently conducting a finding of 

determination whether greater sage-grouse deserve protections under the Endangered 

Species Act. These protections could have far reaching effects on land management in 

Idaho and in the region. 

Greater sage-grouse suffer from the loss, degradation, and fragmentation of habitat 

throughout the west. It's estimated that only 50-60% of the original sagebrush steppe 

habitat remains in the west (West 2000), and in 2007, the American Bird Conservancy 

listed sagebrush as the most threatened bird habitat in the continental United States. 3 As 

such, we cannot stress enough how important it is for agencies to consider impacts to sagegrouse, conserve existing habitat, and actively restore altered sagebrush steppe habitats due 

to project-related impacts. 

Depending on location and design specifics, the construction of additional roads within 

sage-grouse habitat could constitute "nonlinear infrastructure" under the Conservation 

Plan for the Greater Sage-grouse in Idaho (Idaho Sage-Grouse Advisory Committee 2006). 

Nonlinear infrastructure is defined as "human-made features on the landscape that 

provide or facilitate transportation, energy, and communications activities." ~he 

Conservation Plan lists infrastructure such as this as the second greatest threat for sage 

grouse, with wildfires as the greatest risk. Road construction and use associated with the 

facility represents high risk for loss of lek areas, nesting locations, and brood-rearing 

habitats (Braun 1986, Connelly et al. 2004). 56 

Coordination with local stakeholder groups 

We believe that an integral part of conserving and recovering sage-grouse will be relying on 

the guidance from local stakeholder groups. As such, we recommend that the applicant 

coordinate further efforts more closely with the US Fish and Wildlife Service, local Sagegrouse Working Groups, the Idaho State Sage Grouse Advisory Council, the Idaho 

Department of Fish and Game, and the Governor's Office of Species Conservation. 

Conservation groups to consult include the Audubon Society, the Idaho Chapter of the 

North American Grouse Partnership, the Idaho Falconer's Association, the Nature 

Conservancy, the Western Watersheds Project as well as the Idaho Conservation League. 

Additional Wildlife 

In addition to sage-grouse, other wildlife including pygmy rabbits, sage thrasher, sage 

sparrow, and birds of prey, are of concern. New construction and infrastructure will also 

change crucial habitat for these species and may inhibit the ability of these species to 

migrate. The project design should avoid construction in any designated areas or lands for 

3 West, N.E. Synecology and disturbance regimes of sagebrush steppe ecosystems, p. 15-26. In P.G. Entwistle, 

A.M. DeBolt, J.H. Kaltenecker, and K. Steenhoff, Proceedings: sagebrush steppe ecosystems symposium. USDI 

Bureau of Land Management Publication BLM/ID/PT -001001 + 1150, Boise, ID. 

4 Idaho Sage-Grouse Advisory Committee. 2006. Conservation Plan for the Greater Sage-grouse in Idaho. 

S Braun, C.E. 1986. Changes in sage-grouse lek counts with advent of surface coal mining. Proceedings, Issues 

and technology in the management of impacted western wildlife. Thorne Ecoiogicallnstitute 2: 227-23l. 

6 Connelly, J.W., Knick, S.T., Schroeder, M.A., and S.J. Stiver. 2004. Conservation assessment of greater sagegrouse and sagebrush habitats. Western Association ofFish and Wildlife Agencies. Unpublished Report. 

Cheyenne, Wyoming. 

lel.. Comments on NRC puhlic workshops alld proposed rulemoking - depleted uranium Page 100fU 
special management of these species. There are also elk, mule deer, and pronghorn

antelope in the proposed project area.

The project should avoid and minimize all impact to big game winter habitat. The project

site contains good to excellent antelope and sage-grouse habitat. We are concerned how

the proposed project will impact this important habitat and the species that depend on it.

We are also greatly concerned the project will impact nesting habitat for migratory birds.

Invasive Weeds

The most cost-effective way to deal with noxious weeds is to protect strongholds of native

vegetation from activities that either spread noxious weeds directly or create suitable

habitat by removing native vegetation and disturbing the soil. Project activities should limit

road construction in areas that contain mineral soils where weeds may become established.

Roads serve as a primary route for noxious weed species expansion. Special care should be

taken to safeguard ecologically intact areas that are not currently infested. The EIS needs

to analyze the effects of noxious weeds and describe management of weeds in the project

area. For example, management strategies may include ensuring the tires and

undercarriage of access vehicles are hosed down prior to site access to dislodge noxious

weeds. Further documentation should analyze the effects of regular weed control activities

in previously undisturbed areas. For example, weed treatments may affect non-target

species and vehicle access may increase fire hazard and soil disturbance.

Public Comment Opportunities

Due to the nature and size of the proposed facility, we suggest the project proponent hold

additional public hearings throughout the EIS process in Boise, Idaho.

U1, Commnents onI NRC public w~orkshlops and proposed ruletnakinap depflet~ed uranium poge a& I lofl~l l

· . 

special management of these species. There are also elk, mule deer, and pronghorn 

antelope in the proposed project area. 

The project should avoid and minimize all impact to big game winter habitat. The project 

site contains good to excellent antelope and sage-grouse habitat. We are concerned how 

the proposed project will impact this important habitat and the species that depend on it. 

We are also greatly concerned the project will impact nesting habitat for migratory birds. 

Invasive Weeds 

The most cost-effective way to deal with noxious weeds is to protect strongholds of native 

vegetation from activities that either spread noxious weeds directly or create suitable 

habitat by removing native vegetation and disturbing the soil. Project activities should limit 

road construction in areas that contain mineral soils where weeds may become established. 

Roads serve as a primary route for noxious weed species expansion. Special care should be 

taken to safeguard ecologically intact areas that are not currently infested. The EIS needs 

to analyze the effects of noxious weeds and describe management of weeds in the project 

area. For example, management strategies may include ensuring the tires and 

undercarriage of access vehicles are hosed down prior to site access to dislodge noxious 

weeds. Further documentation should analyze the effects of regular weed control activities 

in previously undisturbed areas. For example, weed treatments may affect non-target 

species and vehicle access may increase fire hazard and soil disturbance. 

Public Comment Opportunities 

Due to the nature and size of the proposed facility, we suggest the project proponent hold 

additional public hearings throughout the EIS process in Boise, Idaho. 

Ie/., C()mments Oil NRC puhlic workshops and proposed f'ulemaking - depleted uranium Page 11 oIl! 
ENERGYSOLUTIONS

October 29, 2009

Michael Lesar, Chief

Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

CD09-0293

Subject: Comments on Potential Rulemaking for Safe Disposal of Unique Waste

Streams Including Significant Quantities of Depleted Uranium - 74 FR 30175

Dear Mr. Lesar:

EnergySolutions is submitting these comments in response to the subject notice. Our

comments are contained in the attachment. In general, we are supportive of not only the

proposed rulemaking to require a performance assessment for a site disposing of significant

quantities of depleted uranium, but also the NRC's approach in this matter. The workshop

process was very helpful in clarifying some of the major issues, for example, how, if at all, to

define unique waste streams other than depleted uranium.

We appreciate the opportunity afforded us to participate in the workshops held in Maryland

and Utah and we applaud the Staff on the professional manner in which the workshops were

conducted. The comments provided herein do not differ in substance from the comments we

provided verbally during the workshops. In addition to documenting our position on several

of the questions posed in the Federal Register notice, we have proposed specific regulatory

language to implement our views.

Finally, there is one overarching comment that deserves emphasis, which is that the NRC

should carefully balance the choice of what changes are made in its regulations vis a vis what

changes should be incorporated in guidance. We believe that minimal changes to regulations

are necessary to affect the desired outcome.

Thank you again for this opportunity to comment. Questions regarding these comments may

be directed to me at (301) 957-3770 or temagette energysolutions.com.

Sincerely,

Thomas E. Magett E.

Senior Vice Presi ent

Nuclear Regulatory Strategy

d /~/-2

6100 Chevy Chase Drive • Laurel, Maryland 20707

301.957.3800 * Fax: 301.776.3265 • www.energysolutions.com

7 

ENERGYSOLUTIONS 

October 29, 2009 

Michael Lesar, Chief 

Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

te/OZ-f/o t 

7yrJ<- StJ/ ;6-

@) 

CD09-0293 

,. -.'~-. 

, 

; 

1"":' 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

'\ \1.' 

Subject: Comments on Potential Rulemaking for Safe Disposal of Unique Wa~te 

Streams Including Significant Quantities of Depleted Uranium - 74 FR 30175 

Dear Mr. Lesar: 

EnergySolutions is submitting these comments in response to the subject notice. Our 

comments are contained in the attachment. In general, we are supportive of not only the 

proposed rulemaking to require a performance assessment for a site disposing of significant 

quantities of depleted uranium, but also the NRC's approach in this matter. The workshop 

process was very helpful in clarifying some of the major issues, for example, how, if at all, to 

define unique waste streams other than depleted uranium. 

We appreciate the opportunity afforded us to participate in the workshops held in Maryland 

and Utah and we applaud the Staff on the professional manner in which the workshops were 

conducted. The comments provided herein do not differ in substance from the comments we 

provided verbally during the workshops. In addition to documenting our position on several 

of the questions posed in the Federal Register notice, we have proposed specific regulatory 

language to implement our views. 

Finally, there is one overarching comment that deserves emphasis, which is that the NRC 

should carefully balance the choice of what changes are made in its regulations vis a vis what 

changes should be incorporated in guidance. We believe that minimal changes to regulations 

are necessary to affect the desired outcome. 

Thank you again for this opportunity to comment. Questions regarding these comments may 

be directed to me at (301) 957-3770 or temagette(@'energysolutions.com. 

Sincerely, 

T~tt,~ rlCFJ;Goc;j-flH-tJ:3 

Senior Vice Presi ent ( e... "S ~ 01.--) 

Nuclear Regulatory Strategy p.& ~ (!,,,ljA.<~ , 

5V-i/5J- lJu~ ~/edZ i'!J.7t"'Jn 'h .. ~ I ;:q V (1,;1/) 

~~ A'>.. 0 6100 Chevy Chase Drive· Laurel, Maryland 20707 If). '-;.-//..v/--l-')3 '/ 301.957.3800· Fax: 301.776.3265 • www.energysolutions.com 
Comments on Potential Rulemaking

Safe Disposal of Unique Waste Streams including

Significant Quantities of Depleted Uranium

1. Requirement to Perform a Site-Specific Assessment - EnergySolutions supports the

concept of a limited rulemaking to specify a requirement for a site-specific analysis and

associated technical requirements for the disposal of significant quantities of depleted

uranium as directed by the Commission in StaffRequirements-SECY-08-O147-Response to

Commission Order CLI-05-20 Regarding Depleted Uranium. We believe the changes to the

regulations to accomplish this direction are minimal and should include only:

a. Inclusion of the new requirement to prepare a site-specific performance assessment

b. Modification of 10 CFR 61 Subpart C to specify an intruder dose and a compliance

period using updated dose methodology

We provide specific language below to implement these changes, as well as to address other

issues raised either in the Federal Register notice or during the workshops. In our specific..

comments below, we also distinguish between items that should be addressed in regulations

and those that are more appropriately addressed in guidance.

2. Period of Performance - The period of performance for the site-specific analysis should

be addressed in NRC regulations. NRC regulations should establish a period of compliance

in order to assure consistency in the assessment of compliance by all parties.

EnergySolutions proposes the adoption of a compliance period of performance of 10,000

years. This is consistent with both existing NRC Guidance (e.g., NUREG-1573') and federal

regulations (40 CFR 191). In addition, recognizing that the peak dose may occur after this

period, we recommend that the rule require a qualitative analysis if the peak occurs beyond

10,000 years for input into the analysis. This also is consistent with existing guidance as

found in NUREG- 1573 and NUREG- 18542.

3. Intruder Dose - 10 CFR 61.42 currently requires "...protection of any individual

inadvertently intruding into the disposal site and occupying the site or contacting the waste;"

however, the regulations are silent on the specific dose standard to apply. A dose objective

would assure consistency in the assessment of compliance by all parties. We recommend the

inclusion of a dose standard for an intruder of 500 mrem/yr. This would formalize as a

regulatory requirement the dose standard that currently is stated in guidance.

We would note that 500 mrem was the standard proposed in Part 61 in 1981 (46 FR 38081,

July 24, 1981). The Statement of Considerations for the final rule identifies no objection to

this dose standard. It apparently was removed at the request of EPA because of their concern

regarding how one would monitor or demonstrate compliance with the standard, but not

because EPA disagreed with the proposed dose (47 FR 57446, 57449, December 27, 1982).

1 A Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities, U.S. Nuclear

Regulatory Commission, NUREG-1573, October 2000. 2 NRC Staff Guidance for Activities Related to U.S. Department of Energy Waste Determinations, U.S. Nuclear

Regulatory Commission, NUREG-1854, August 2007.

2

Comments on Potential Rulemaking 

Safe Disposal of Unique Waste Streams including 

Significant Quantities of Depleted Uranium 

1. Requirement to Perform a Site-Specific Assessment - EnergySolutions supports the 

concept of a limited rulemaking to specify a requirement for a site-specific analysis and 

associated technical requirements for the disposal of significant quantities of depleted 

uranium as directed by the Commission in Staff Requirements-SECY-08-0147-Response to 

Commission Order CLI-05-20 Regarding Depleted Uranium. We believe the changes to the 

regulations to accomplish this direction are minimal and should include only: 

a. Inclusion of the new requirement to prepare a site-specific performance assessment 

b. Modification of 10 CFR 61 Subpart C to specify an intruder dose and a compliance 

period using updated dose methodology 

We provide specific language below to implement these changes, as well as to address other 

issues raised either in the Federal Register notice or during the workshops. In our specific 

comments below, we also distinguish between items that should be addressed in regulations 

and those that are more appropriately addressed in guidance. 

2. Period of Performance - The period of performance for the site-specific analysis should 

be addressed in NRC regulations. NRC regulations should establish a period of compliance 

in order to assure consistency in the assessment of compliance by all parties. 

EnergySolutions proposes the adoption of a compliance period of performance of 10,000 

years. This is consistent with both existing NRC Guidance (e.g., NUREG-1573 1

) and federal 

regulations (40 CFR 191). In addition, recognizing that the peak dose may occur after this 

period, we recommend that the rule require a qualitative analysis if the peak occurs beyond 

10,000 years for input into the analysis. This also is consistent with existing guidance as 

found in NUREG-1573 and NUREG-18542

. 

3. Intruder Dose - 10 CFR 61.42 currently requires" ... protection of any individual 

inadvertently intruding into the disposal site and occupying the site or contacting the waste;" 

however, the regulations are silent on the specific dose standard to apply. A dose objective 

would assure consistency in the assessment of compliance by all parties. We recommend the 

inclusion of a dose standard for an intruder of 500 mremlyr. This would formalize as a 

regulatory requirement the dose standard that currently is stated in guidance. 

We would note that 500 mrem was the standard proposed in Part 61 in 1981 (46 FR 38081, 

July 24, 1981). The Statement of Considerations for the final rule identifies no objection to 

this dose standard. It apparently was removed at the request of EP A because of their concern 

regarding how one would monitor or demonstrate compliance with the standard, but not 

because EPA disagreed with the proposed dose (47 FR 57446,57449, December 27, 1982). 

1 A Performance Assessment Methodology for Low-Level Radioactive Waste Disposal Facilities, U.S. Nuclear 

Regulatory Commission, NUREG-1573, October 2000. 

2 NRC Staff Guidance for Activities Related to u.s. Department of Energy Waste Determinations, U.S. Nuclear 

Regulatory Commission, NUREG-1854, August 2007. 

2 
A dose standard of 500 mrem/yr is also used as part of the license termination rule dose

standard for intruders (10 CFR 20.1403).

We also recommend that the NRC further revise Subpart C, specifically Section 61.41, to

update the annual dose methodology to the newer methodology of ICRP 26 and 30 used in 10

CFR Part 20. This is consistent with the approach taken in more recent NRC guidance,

including NUREG-1 573 and NUREG-1 854.

4. Definition of Significant Quantity - The subject Federal Register notice sought input on

how the NRC should define a "significant quantity" of depleted uranium. EnergySolutions

does not believe it is necessary to define "significant quantity." This topic was the subject of

much discussion in both workshops and, as several participants observed, there is little if

anything to be gained by attempting to define a limit below which no site-specific assessment

is necessary. The quantity of uranium that the NRC relied upon in developing the tables in

Part 61.55 was approximately 60 tons. SECY-08-0147 refers to a lower limit of 1-10 tons

below which no site-specific assessment would be required. Either of these limits, or any

other the Commission is likely to adopt, would easily be exceeded at a facility that is

disposing of depleted uranium from an enrichment or deconversion facility.

The language we provide below regarding the requirement to prepare a site-specific

assessment is in our view sufficient to address how this issue should be addressed in the

regulations, which is to say that the requirement should include no threshold.

5. Identification of Scenarios - NRC regulations in Part 61 already contain requirements

regarding compliance with the performance objectives in Subpart C. 10 CFR 61.13,

Technical Analyses, and Subpart C, Performance Objectives, specify pathways to be

analyzed, require identification of disposal site characteristics and design features, and

require the analysis of inadvertent intrusion, routine operations, likely accidents, and longterm stability of the disposal site. Details regarding how to select potential exposure

scenarios are addressed in NRC guidance, e.g., NUREG-1573. EnergySolutions recommends

that the NRC continue to follow this approach.

NRC should permit disposal site operators to justify site-specific assumptions and exposure

scenarios based on reasonably foreseeable circumstances to evaluate the critical group that

could reasonably encounter material that may be released from the disposal cell after the

institutional control period. This could include residential use, farming, resident farming, or

some other reasonable use consistent with the current environment of the specific site. For

example, a site would not be expected or required to consider a groundwater pathway if the

groundwater was not useable for irrigation or human consumption. In addition, the

assumptions for the analyses would not need to project changes in society, the biosphere,

human biology, or increases or decreases of human knowledge or technology except for

foreseeable changes to the geology, hydrology, and climate based upon cautious, but

reasonable assumptions of the changes in these factors that could affect the disposal site. The

actual details for preparing performance assessments should be addressed in NRC guidance,

which can be updated periodically as necessary.

3

A dose standard of 500 mremlyr is also used as part of the license termination rule dose 

standard for intruders (10 CFR 20.1403). 

We also recommend that the NRC further revise Subpart C, specifically Section 61.41, to 

update the annual dose methodology to the newer methodology ofICRP 26 and 30 used in 10 

CFR Part 20. This is consistent with the approach taken in more recent NRC guidance, 

including NUREG-1573 and NUREG-1854. 

4. Definition of Significant Quantity - The subject Federal Register notice sought input on 

how the NRC should define a "significant quantity" of depleted uranium. EnergySolutions 

does not believe it is necessary to define "significant quantity." This topic was the subject of 

much discussion in both workshops and, as several participants observed, there is little if 

anything to be gained by attempting to define a limit below which no site-specific assessment 

is necessary. The quantity of uranium that the NRC relied upon in developing the tables in 

Part 61.55 was approximately 60 tons. SECY-08-0147 refers to a lower limit of 1-10 tons 

below which no site-specific assessment would be required. Either of these limits, or any 

other the Commission is likely to adopt, would easily be exceeded at a facility that is 

disposing of depleted uranium from an enrichment or deconversion facility. 

The language we provide below regarding the requirement to prepare a site-specific 

assessment is in our view sufficient to address how this issue should be addressed in the 

regulations, which is to say that the requirement should include no threshold. 

5. Identification of Scenarios - NRC regulations in Part 61 already contain requirements 

regarding compliance with the performance objectives in Subpart C. 10 CFR 61.13, 

Technical Analyses, and Subpart C, Performance Objectives, specify pathways to be 

analyzed, require identification of disposal site characteristics and design features, and 

require the analysis of inadvertent intrusion, routine operations, likely accidents, and longterm stability of the disposal site. Details regarding how to select potential exposure 

scenarios are addressed in NRC guidance, e.g., NUREG-1573. EnergySolutions recommends 

that the NRC continue to follow this approach. 

NRC should permit disposal site operators to justify site-specific assumptions and exposure 

scenarios based on reasonably foreseeable circumstances to evaluate the critical group that 

could reasonably encounter material that may be released from the disposal cell after the 

institutional control period. This could include residential use, farming, resident farming, or 

some other reasonable use consistent with the current environment of the specific site. For 

example, a site would not be expected or required to consider a groundwater pathway if the 

groundwater was not useable for irrigation or human consumption. In addition, the 

assumptions for the analyses would not need to project changes in society, the biosphere, 

human biology, or increases or decreases of human knowledge or technology except for 

foreseeable changes to the geology, hydrology, and climate based upon cautious, but 

reasonable assumptions of the changes in these factors that could affect the disposal site. The 

actual details for preparing performance assessments should be addressed in NRC guidance, 

which can be updated periodically as necessary. 

3 
6. Performance Assessment Update Frequency - EnergySolutions recommends that the

NRC include a requirement that the site-specific performance assessment be updated at a

frequency not to exceed once every 5 years. Updates may be more frequent as necessitated to

demonstrate compliance with changes at the site not previously analyzed, but in the event that

is not the case, the 5-year minimum would apply.

7. Definition of Unique Waste Streams - The subject Federal Register notice sought input

on whether the NRC should define "unique waste streams." EnergySolutions recommends

that the NRC not attempt to define unique waste streams. We believe that any attempt to

define unique waste streams would be elusive and thus merely serve to divert attention and

resources from more important activities. Over the course of four days of workshops, no

proposed definition was offered that garnered even mild support from panelists or members

of the public. More importantly, there is no need to define other unique waste streams. A

sufficiently broad requirement for the preparation of a site-specific performance assessment

will capture the suitability of a given site for the disposal of radioactive waste containing any

isotopes whether or not they are addressed in the tables in 10 CFR 61.55(a).

8. Guidance vs. Regulations - Regulations provide for certainty, consistency, and

enforceability. Guidance, while not directly enforceable, provides direction to disposal site

operators and has the advantage of being easier to change over time. It is EnergySolutions

view that fundamental objectives should be included in regulations and details addressed in

guidance. This allows the NRC to provide acceptable methods for implementation to the

industry as guidance and enables disposal site operators to defend other ways to satisfy the

fundamental objectives. As is the case with regulations, development of guidance should

provide for the opportunity for public comments on drafts before it is issued for use.

We have identified herein those changes to requirements necessary and sufficient to assess

the adequacy of a site for the disposal of depleted uranium:

" The basic requirement for the preparation of a performance assessment that

demonstrates compliance with the performance objectives of Subpart C

* Designation of compliance periods, dose standards, and a reasonableness standard for

scenarios and assumptions to be used in performance assessments

Any additional details for achieving compliance, particularly those that are site-specific,

should be addressed in guidance. The subject Federal Register notice addressed a number of

issues for consideration in this rulemaking, e.g., geochemical parameters, impacts of radon

gas releases, and details of performance assessments. These and any other issues apart from

the ones listed above should be addressed in NRC guidance.

9. Classification of Depleted Uranium - Although not the subject of this limited

rulemaking, EnergySolutions agrees with the determination by the Commission that depleted

uranium is and should remain Class A waste. We do not believe any change in waste

classification is warranted and recommend that the Commission not take any action in this or

subsequent rulemakings to change the classification of depleted uranium.

4

6. Performance Assessment Update Frequency - EnergySolutions recommends that the 

NRC include a requirement that the site-specific performance assessment be updated at a 

frequency not to exceed once every 5 years. Updates may be more frequent as necessitated to 

demonstrate compliance with changes at the site not previously analyzed, but in the event that 

is not the case, the 5-year minimum would apply. 

7. Definition of Unique Waste Streams - The subject Federal Register notice sought input 

on whether the NRC should define "unique waste streams." EnergySolutions recommends 

that the NRC not attempt to define unique waste streams. We believe that any attempt to 

define unique waste streams would be elusive and thus merely serve to divert attention and 

resources from more important activities. Over the course of four days of workshops, no 

proposed definition was offered that garnered even mild support from panelists or members 

of the public. More importantly, there is no need to define other unique waste streams. A 

sufficiently broad requirement for the preparation of a site-specific performance assessment 

will capture the suitability of a given site for the disposal of radioactive waste containing any 

isotopes whether or not they are addressed in the tables in 10 CFR 61.55(a). 

8. Guidance vs. Regulations - Regulations provide for certainty, consistency, and 

enforceability. Guidance, while not directly enforceable, provides direction to disposal site 

operators and has the advantage of being easier to change over time. It is EnergySolutions 

view that fundamental objectives should be included in regulations and details addressed in 

guidance. This allows the NRC to provide acceptable methods for implementation to the 

industry as guidance and enables disposal site operators to defend other ways to satisfy the 

fundamental objectives. As is the case with regulations, development of guidance should 

provide for the opportunity for public comments on drafts before it is issued for use. 

We have identified herein those changes to requirements necessary and sufficient to assess 

the adequacy of a site for the disposal of depleted uranium: 

• The basic requirement for the preparation of a performance assessment that 

demonstrates compliance with the performance objectives of Subpart C 

• Designation of compliance periods, dose standards, and a reasonableness standard for 

scenarios and assumptions to be used in performance assessments 

Any additional details for achieving compliance, particularly those that are site-specific, 

should be addressed in guidance. The subject Federal Register notice addressed a number of 

issues for consideration in this rulemaking, e.g., geochemical parameters, impacts of radon 

gas releases, and details of performance assessments. These and any other issues apart from 

the ones listed above should be addressed in NRC guidance. 

9. Classification of Depleted Uranium - Although not the subject of this limited 

rulemaking, EnergySolutions agrees with the determination by the Commission that depleted 

uranium is and should remain Class A waste. We do not believe any change in waste 

classification is warranted and recommend that the Commission not take any action in this or 

subsequent rulemakings to change the classification of depleted uranium. 

4 
10. Implementation - It is important that site operators have sufficient time to respond to the

new regulations; particularly given that they will directly affect ongoing activities and that the

preparation of a rigorous performance assessment is a nontrivial endeavor. EnergySolutions

proposes that the effective date of the new regulation be 12 months following publication in

the Federal Register. The 12-month time period should be requirement for the submittal of

the performance assessment and would not include NRC review and approval.

11. Proposed Language to Revise Regulations - EnergySolutions proposes the following

specific modifications to NRC regulations to implement the direction of the Commission

(proposed new language shown in underline and deletions in strketIfeugh).

Performance Assessment. In order to implement the basic requirement to prepare a sitespecific performance assessment, we propose that a new paragraph 10 CFR 61.55(a)(9) be

added to read:

Performance Assessment. Prior to the disposal of waste containing isotopes

not listed above in Table 1 or Table 2, a site-specific performance assessment

shall be prepared and submitted for Commission approval to demonstrate that

the performance objectives of Subpart C of this part will be met. The

performance assessment shall:

(i) Address isotopic content of all waste disposed, including but not

limited to the isotopes listed above in Table 1 and Table 2.

(ii) Be updated for Commission approval at least once in every five-year

period unless the disposal site operator justifies an alternative period.

(iii) Address the analyses listed in § 61.13 and be performed for a

compliance period of 10,000 years using reasonably foreseeable

assumptions and scenarios. If the peak dose occurs after 10,000 years,

a qualitative analysis shall be prepared up to the time of the peak dose

for consideration in the site's environmental evaluation.

The beauty of this approach is that it links the preparation of a performance assessment to

waste classification by imposing the new requirement only in the event of disposal of wastes

not listed in Tables 1 and 2. Thus it specifically addresses the intent of the limited

rulemaking to consider the disposal of significant quantities of depleted uranium and other

unique waste streams that may not have been contemplated in the development of existing

regulations. It also obviates any need to specifically define a unique waste stream.

Furthermore, it permits disposal site operators to limit the waste they accept and avoid the

burden of the new requirement.

A more global and technically elegant approach would be to add virtually the same language

(minus the opening clause referencing isotopes not listed in Tables 1 and 2) to 10 CFR, 61.13,

Technical Analyses, as a new § 61.13(e). This would have the net effect of requiring all

persons desiring a license under Part 61 to prepare a performance assessment. Although this

goes beyond the scope of the limited rulemaking, it would go far towards the larger objective

articulated by the Commission in the SRM of risk informing Part 61.

5

10. Implementation - It is important that site operators have sufficient time to respond to the 

new regulations; particularly given that they will directly affect ongoing activities and that the 

preparation of a rigorous performance assessment is a nontrivial endeavor. EnergySolutions 

proposes that the effective date of the new regulation be 12 months following publication in 

the Federal Register. The 12-month time period should be requirement for the submittal of 

the performance assessment and would not include NRC review and approval. 

11. Proposed Language to Revise Regulations - EnergySolutions proposes the following 

specific modifications to NRC regulations to implement the direction of the Commission 

(proposed new language shown in underline and deletions in strikethrough). 

Performance Assessment. In order to implement the basic requirement to prepare a sitespecific performance assessment, we propose that a new paragraph 10 CFR 61.55(a)(9) be 

added to read: 

Performance Assessment. Prior to the disposal of waste containing isotopes 

not listed above in Table 1 or Table 2, a site-specific performance assessment 

shall be prepared and submitted for Commission approval to demonstrate that . 

the performance objectives of Subpart C of this part will be met. The 

performance assessment shall: 

(i) Address isotopic content of all waste disposed, including but not 

limited to the isotopes listed above in Table 1 and Table 2. 

(ii) Be updated for Commission approval at least once in every five-year 

period unless the disposal site operator justifies an alternative period. 

(iii) Address the analyses listed in § 61.13 and be performed for a 

compliance period of 10,000 years using reasonably foreseeable 

assumptions and scenarios. If the peak dose occurs after 10,000 years, 

a qualitative analysis shall be prepared up to the time of the peak dose 

for consideration in the site's environmental evaluation. 

The beauty of this approach is that it links the preparation of a performance assessment to 

waste classification by imposing· the new requirement only in the event of disposal of wastes 

not listed in Tables 1 and 2. Thus it specifically addresses the intent of the limited 

rulemaking to consider the disposal of significant quantities of depleted uranium and other 

unique waste streams that may not have been contemplated in the development of existing 

regulations. It also obviates any need to specifically define a unique waste stream. 

Furthermore, it permits disposal site operators to limit the waste they accept and avoid the 

burden of the new requirement. 

A more global and technically elegant approach would be to add virtually the same language 

(minus the opening clause referencing isotopes not listed in Tables 1 and 2) to 10 CFR61.13, 

Technical Analyses, as a new § 61.13( e). This would have the net effect of requiring all 

persons desiring a license under Part 61 to prepare a performance assessment. Although this 

goes beyond the scope of the limited rulemaking, it would go far towards the larger objective 

articulated by the Commission in the SRM of risk informing Part 61. 

5 
Intruder Dose. In order to implement the proposed requirement that an intruder dose be

specified in regulation, we propose that 10 CFR 61.42 be modified to read:

Design, operation, and closure of the land disposal facility must ensure

protection of any individual inadvertently intruding into the disposal site and

occupying the site or contacting the waste at any time after active institutional

controls over the disposal site are removed. The annual dose to an intruder

must not exceed 500 millirems total effective dose equivalent for a compliance

period of 10,000 years.

Dose Methodology Update. In order to update Subpart C to incorporate more current dose

calculation methodology, we propose that 10 CFR 61.41 be modified to read:

Concentrations of radioactive material which may be released to the general

environment in ground water, surface water, air, soil, plants, or animals must not

result in an annual dose exceeding an equivalent of 25 millirems total effective dose

equivalent for a compliance period of 10,000 years to 25 millirems to the whole body,

75 millir-em: to the thyro.id, and 25 millir;em; to an, other or.gan ot any member of the

public. Reasonable effort should be made to maintain releases of radioactivity in

effluents to the general environment as low as is reasonably achievable.

6

· . 

Intruder Dose. In order to implement the proposed requirement that an intruder dose be 

specified in regulation, we propose that 10 CFR 61.42 be modified to read: 

Design, operation, and closure of the land disposal facility must ensure 

protection of any individual inadvertently intruding into the disposal site and 

occupying the site or contacting the waste at any time after active institutional 

controls over the disposal site are removed. The annual dose to an intruder 

must not exceed 500 millirems total effective dose equivalent for a compliance 

period of 10,000 years. 

Dose Methodology Update. In order to update Subpart C to incorporate more currentdose 

calculation methodology, we propose that 10 CFR 61.41 be modified to read: 

Concentrations of radioactive material which may be released to the general 

environment in ground water, surface water, air, soil, plants, or animals must not 

result in an annual dose exceeding an equivalent of 25 millirems total effective dose 

equivalent for a compliance period of 10,000 years to 25 millirems to the ",mole body, 

75 millirems to the thyroid, and 25 millirems to any other organ of any member of the 

public. Reasonable effort should be made to maintain releases of radioactivity in 

effluents to the general environment as low as is reasonably achievable. 

6 
NUCLEAR ENERGY INSIIIUTE

>1 /f~7S

Felix M. Killar, Jr.

SENIOR DIRECTOR

FUEL SUPPLY/MATERIAL LICENSEES

NUCLEAR GENERATION DIVISION

October 30, 2009

Mr. Michael Lesar

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Mail Stop TWB 5BO1M

Washington, D.C. 20555-0001

"i'• I

Ca

Subject: Industry Response to NRC Questions on the Disposal of Large Quantities of Depleted

Uranium as stated in 74FR30175 dated June 24, 2009

Project Code: 689

Dear Mr. Lesar:

On behalf of industry, the Nuclear Energy Institute1 (NEI) offers the enclosed responses to the

questions noticed in the Federal Register on June 24, 2009 (74FR30175). We offer the general

comments below and the enclosed specific responses to the questions. We trust that U.S. Nuclear

Regulatory Commission (NRC) staff will find this information useful as it proceeds to potentially

develop the technical basis for a proposed rule that would require site-specific analysis for the

disposal of large quantities of depleted uranium.

We appreciate the time and effort that the NRC expended to solicit participation from a wide variety

of stakeholders and conduct the very professional roundtable workshops in Maryland and Utah.

Since the earlier workshops were focused on the potential proposed rule, we suggest that the NRC

1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters

affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's

members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant

designers, major architect/engineering firms, fuel fabrication facilities, nuclear materials licensees, and other organizations

and entities involved in the nuclear energy industry. - ,i9 - -- 9 2

1776 1 Street, NW I Suite 400 1 Washington, DC 1 20006-3708 I P: 202.739.8126 i F: 202.533.0157 I fmk@nei.org i www.nei.org

,z) x qWiV (/,,))

·. I 

NUCLEAR ENERGY INSTllUTE 

Felix M. Killar, Jr. 

SENIOR DIRECTOR 

FUEL SUPPLy/MATERIAL LICENSEES 

NUCLEAR GENERATION DIVISION 

October 30, 2009 

Mr. Michael Lesar 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

U.s. Nuclear Regulatory Commission 

Mail Stop TWB 5B01M 

Washington, D.C. 20555-0001 

~CJ ",'-1 

i I 

"~-'1 

', .. ,--,,1 

Subject: Industry Response to NRC Questions on the Disposal of Large Quantities of Depleted 

Uranium as stated in 74FR30175 dated June 24, 2009 

Project Code: 689 

Dear Mr. Lesar: 

. " .. ~ 

I', ) 

.... -... 

[-',.) 

On behalf of industry, the Nuclear Energy Institute! (NEI) offers the enclosed responses to the 

questions noticed in the Federal Register on June 24, 2009 (74FR30175). We offer the general 

comments below and the enclosed specific responses to the questions. We trust that U.s. Nuclear 

Regulatory Commission (NRC) staff will find this information useful as it proceeds to potentially 

develop the technical basis for a proposed rule that would require site-specific analysis for the 

disposal of large quantities of depleted uranium. 

We appreciate the time and effort that the NRC expended to solicit participation from a wide variety 

of stakeholders and conduct the very professional roundtable workshops in Maryland and Utah. 

Since the earlier workshops were focused on the potential proposed rule, we suggest that the NRC 

1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters 

affecting the nuclear energy industry, including the regulatory aspects of generiC operational and technical issues. NEl's 

members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant 

deSigners, major architect/engineering firms, fuel fabrication facilities, nuclear materials licensees, and other organizations 

and entities involved in the nuclear energy industry. £ .... )'<.Pb 6 -=-#b J--t -t) ?::> \ 

fjr:;/I1~~ a.t.-L--=:- (!'"'!f~(~:55:LJ 1776 I Street, NW I Suite 400 I Washington, DC i 20006-3708 I P: 202.739.8126 i F: 202.533.0157 I fmk@nei.org i www.nei.org 

/!J.1ra),n-A qrrn (bA/0) 

f. YC;./.ql/ (/1/) 
Mr. Michael Lesar

October 30, 2009

Page 2

consider conducting an additional roundtable workshop with technical experts who can provide

detailed information on the myriad of issues that should be addressed in a guidance document and

not the rule, e.g., geochemical factors, waste stabilization practices, and exposure scenarios. As

such, we suggest that this workshop be held before the NRC issues the draft guidance for comment

to better inform the drafting process.

We offer the following general comments for your consideration. First, it is not evident that a

rulemaking is needed to affect the outcome that the NRC is seeking based on a review of the

current Part 61 requirements and corresponding Agreement State regulations, which must be

adequate and compatible with the NRC's rule, and current regulatory oversight. Further, there is no

evidence to suggest that the current regulatory framework is not providing adequate protection to

public health and safety or the environment. That being said, various representatives supported the

September workshops as this matter is important to nuclear industry as a whole and the opportunity

to provide such input then and now is appreciated.

Secondly, industry believes that any NRC rule on the disposal of large quantities of depleted uranium

or other waste streams should be risk-informed and performance-based. Specifically, since the

performance objectives in Part 61 already apply to waste disposal sites, any additional rule language

should be kept to a minimum, e.g., require a site-specific assessment, period of performance and

intruder dose limit, while leaving the engineering decisions and technical approaches at the

discretion of the licensed waste site operator. The licensee's role is to demonstrate and provide the

NRC or the Agreement State reasonable assurance that the performance objectives and standards

can be met if implemented as described, which the regulator would then confirm through inspection

as Agreement States do today. In addition, the supporting guidance should encourage and not

inadvertently dissuade licensees to evaluate and consider unique site features, characteristics and

practices that, when utilized, support the site performance assessment.

Third, as stated during the September 2009 public workshops, industry does not support including a

definition of "unique waste stream" or "significant quantities" in the rule. The origin of the waste is

irrelevant and its characteristics such as radionuclide concentration, volumes, waste form, etc., are

all factors that would be considered by the applicant in its site-specific performance assessment and

evaluated by the regulatory authority.

Finally, industry has the authority and responsibility to safely manage its inventories of depleted

uranium or other waste streams. As such, it should not be assumed that current or future

inventories of depleted uranium will be destined for permanent disposal since it can be considered a

resource by its owner who makes decisions on its management based on current and future market

conditions.

In summary, we appreciate the opportunity to provide further input and look forward to additional

dialogue with NRC on these important matters. If you would like to discuss these matters further,

Mr. Michael Lesar 

October 30, 2009 

Page 2 

consider conducting an additional roundtable workshop with technical experts who can provide 

detailed information on the myriad of issues that should be addressed in a guidance document and 

not the rule, e.g., geochemical factors, waste stabilization practices, and exposure scenarios. As 

such, we suggest that this workshop be held before the NRC issues the draft guidance for comment 

to better inform the drafting process. 

We offer the following general comments for your consideration. First, it is not evident that a 

rulemaking is needed to affect the outcome that the NRC is seeking based on a review of the 

current Part 61 requirements and corresponding Agreement State regulations, which must be 

adequate and compatible with the NRC's rule, and current regulatory oversight. Further, there is no 

evidence to suggest that the current regulatory framework is not providing adequate protection to 

public health and safety or the environment. That being said, various representatives supported the 

September workshops as this matter is important to nuclear industry as a whole and the opportunity 

to provide such input then and now is appreCiated. 

Secondly, industry believes that any NRC rule on the disposal of large quantities of depleted uranium 

or other waste streams should be risk-informed and performance-based. Specifically, since the 

performance objectives in Part 61 already apply to waste disposal sites, any additional rule language 

should be kept to a minimum, e.g., require a site-specific assessment, period of performance and 

intruder dose limit, while leaving the engineering decisions and technical approaches at the 

discretion of the licensed waste site operator. The licensee's role is to demonstrate and provide the 

NRC or the Agreement State reasonable assurance that the performance objectives and standards 

can be met if implemented as described, which the regulator would then confirm through inspection 

as Agreement States do today. In addition, the supporting guidance should encourage and not 

inadvertently dissuade licensees to evaluate and conSider unique site features, characteristics and 

practices that, when utilized, support the site performance assessment. 

Third, as stated during the September 2009 public workshops, industry does not support including a 

definition of "unique waste stream" or "significant quantities" in the rule. The origin of the waste is 

irrelevant and its characteristics such as radionuclide concentration, volumes, waste form, etc., are 

all factors that would be considered by the applicant in its site-specific performance assessment and 

evaluated by the regulatory authority. 

Finally, industry has the authority and responsibility to safely manage its inventories of depleted 

uranium or other was!e streams. As such, it should not be assumed that current or future 

inventories of depleted uranium will be destined for permanent disposal since it can be considered a 

resource by its owner who makes decisions on its management based on current and future market 

conditions. 

In summary, we appreCiate the opportunity to provide further input and look forward to additional 

dialogue with NRC on these important matters. If you would like to discuss these matters further, 
Mr. Michael Lesar

October 30, 2009

Page 3

you may contact me at 202.739.8126 or fmk@nei.org or Janet Schlueter at 202.739.8098 or

jrs@nei.org.

Sincerely,

Felix M. Killar, Jr.

Attachment

c: Mr. Larry Camper, FSME/DWMEP

Ms. Priya Yadav, FSME/DWMEP

Mr. Michael Lesar 

October 30, 2009 

Page 3 

you may contact me at 202.739.8126 or fmk@nei.org or Janet Schlueter at 202.739.8098 or 

jrs@nei.org. 

Sincerely, 

Felix M. Killar, Jr. 

Attachment 

c: Mr. Larry Camper, FSME/DWMEP 

Ms. Priya Yadav, FSME/DWMEP 
Attachment

Industry Responses to NRC Questions on Disposal of Large Quantities of Depleted

Uranium as discussed in 74FR30175 issued June 24, 2009

Question II-1.1-Should the NRC propose a regulatory definition to (a) specify general

criteria that would capture both current and foreseeable unique waste streams; or (b)

limit the definition to a known set of current unique waste streams including significant

quantities of depleted uranium? What characteristics should NRC propose as defining

for unique waste streams?

No. As discussed during the September workshops, industry does not support the inclusion of a

definition of "unique waste stream" in the proposed or final rule which was the subject of the

workshop. Defining a "unique waste stream" is unnecessary, potentially arbitrary, and could

inadvertently preclude the disposal of yet-to-be developed or identified waste streams that would

meet applicable disposal requirements. Instead, waste disposal site applicants and licensees should

be required to meet the applicable performance objectives contained in Part 61 regardless of the

origin of the waste stream.

Question II-1.2-What waste streams containing radionuclides listed in the waste

classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable future,

being disposed of in quantities significantly greater than initially considered in the

development of 10 CFR Part 61?

Industry is not aware of any information to suggest that there are waste streams containing

radionuclides, listed in the waste classification tables, which are currently being disposed of in

significant quantities greater than initially considered in the development of 10 CFR Part 61 and

which pose any threat to public health and safety or the environment.

Question II-1.3-What waste streams containing radionuclides that are not listed in the

waste classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable

future, being disposed of in concentrations or quantities significantly greater than

initially considered in the development of 10 CFR Part 61?

Question II-1.4-What waste streams that were not considered in the initial

development of 10 CFR Part 61 should be considered under the definition of "unique

waste streams"?

Question II-1.5-Should the NRC consider waste streams that result from spent fuel

reprocessing and are not high-level or greater-than-class C waste in the definition of "unique waste streams"?

Question II-1.6-Are there other characteristics besides concentration and quantity that

NRC should consider when defining "unique waste streams"?

Response to Questions II - 1.3 - 1.6

Currently, and in the foreseeable future, there may be a need to dispose of depleted uranium from

commercial and government inventories in quantities that are potentially greater than initially

considered in the development of 10 CFR 61, based on the information contained in this FRN and

SECY-08-0147. However, it should be recognized that holders or owners of depleted uranium may

consider it to be a resource depending on current or future market conditions. As such, current and

Page 1

Attachment 

Industry Responses to NRC Questions on Disposal of Large Quantities of Depleted 

Uranium as discussed in 74FR3017s issued June 24, 2009 

Question II-1.1-Should the NRC propose a regulatory definition to (a) specify general 

criteria that would capture both current and foreseeable unique waste streams; or (b) 

limit the definition to a known set of current unique waste streams including significant 

quantities of depleted uranium? What characteristics should NRC propose as defining 

for unique waste streams? 

No. As discussed during the September workshops, industry does not support the inclusion of a 

definition of "unique waste stream" in the proposed or final rule which was the subject of the 

workshop. Defining a "unique waste stream" is unnecessary, potentially arbitrary, and could 

inadvertently preclude the disposal of yet-to-be developed or identified waste streams that would 

meet applicable disposal requirements. Instead, waste disposal site applicants and licensees should 

be required to meet the applicable performance objectives contained in Part 61 regardless of the 

origin of the waste stream. 

Question II-l.2-What waste streams containing radionuclides listed in the waste 

classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable future, 

being disposed of in quantities significantly greater than initially considered in the 

development of 10 CFR Part 61? 

Industry is not aware of any information to suggest that there are waste streams containing 

radionuclides, listed in the waste classification tables, which are currently being disposed of in 

significant quantities greater than initially considered in the development of 10 CFR Part 61 and 

which pose any threat to public health and safety or the environment. 

Question II-1.3-What waste streams containing radionuclides that are not listed in the 

waste classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable 

future, being disposed of in concentrations or quantities significantly greater than 

initially considered in the development of 10 CFR Part 61? 

Question II-l.4-What waste streams that were not considered in the initial 

development of 10 CFR Part 61 should be considered under the definition of "unique 

waste streams"? 

Question II-l.s-Should the NRC consider waste streams that result from spent fuel 

reprocessing and are not high-level or greater-than-class C waste in the definition of 

"unique waste streams"? 

Question II-l.6-Are there other characteristics besides concentration and quantity that 

NRC should consider when defining "unique waste streams"? 

Response to Questions II - 1.3 - 1.6 

Currently, and in the foreseeable future, there may be a need to dispose of depleted uranium from 

commercial and government inventories in quantities that are potentially greater than initially 

considered in the development of 10 CFR 61, based on the information contained in this FRN and 

SECY-08-0147. However, it should be recognized that holders or owners of depleted uranium may 

consider it to be a resource depending on current or future market conditions. As such, current and 

Page 1 
Attachment

future inventories may or may not be destined for permanent disposal. Finally, industry is not

aware of any information to suggest that there are other waste streams that are currently or could

be in the foreseeable future being disposed of in concentrations or quantities significantly greater

than those considered during the development of Part 61. As stated previously, defining, a "unique

waste stream" is unnecessary, potentially arbitrary, and could inadvertently preclude the disposal of

yet-to-be developed or identified waste streams that would meet applicable disposal requirements.

Question II-2.1-Should the NRC (a) specify a single time period to evaluate the

performance of facilities disposing of all unique waste streams in the near surface; (b)

specify criteria requiring the consideration of how the hazard for each unique waste

stream evolves over time; or (c) permit a licensee to justify a period of performance?

Question II-2.2-If NRC were to specify a single time period for site specific analysis of

facilities disposing of unique waste streams in the near surface, what would be an

appropriate period? What factors should NRC consider in determining a single time

period of performance?

Question II-2.3-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time for each unique waste stream, what factors should NRC

consider in determining these criteria?

Question 11-2.4-If NRC were to permit a licensee to justify a time period of

performance, what factors should NRC consider when evaluating a licensee's

justification?

Question II-2.5-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time, or permit a licensee to justify a time period of performance,

should the NRC consider limiting the maximum extent of the time period considered?

If so, what factors should NRC consider when specifying a maximum period of

performance?

Question II-2.6-What other approaches might NRC consider when specifying criteria

for a period of performance for facilities disposing of unique waste streams in the near

surface?

Response to Question II - 2.1-2.6

There are advantages and disadvantages of specifying the period of performance for disposal

facilities utilizing near surface disposal methods in the rule versus the guidance. However, industry

generally supports specifying the period of performance in the rule for consistency across the

disposal facilities nationwide and to provide for a more transparent and predictable regulatory

process. Industry suggests that the period of performance be set at 10,000 years for consistency

with NRC's existing regulatory guidance for low-level waste disposal facilities and other federal

regulations, e.g., 40 CFR 191 and the Uranium Mill Tailings Radiation Control Act. Industry does not

support specifying criteria for hazards analysis in the rule. This level of detail and information on

how to comply with the performance objectives is more appropriate for a guidance document.

As with any period of performance to demonstrate regulatory compliance, it is best to identify a time

period where the regulator can determine and the licensee can demonstrate with reasonable

assurance, and using current technology and methodology, that the applicable regulatory release

and exposure limits can be met. It is also important that the rule allow for a risk-informed and

Page 2

Attachment 

future inventories mayor may not be destined for permanent disposal. Finally, industry is not 

aware of any information to suggest that there are other waste streams that are currently or could 

be in the foreseeable future being disposed of in concentrations or quantities significantly greater 

than those considered during the development of Part 61. As stated previously, defining a "unique 

waste stream" is unnecessary, potentially arbitrary, and could inadvertently preclude the disposal of 

yet-to-be developed or identified waste streams that would meet applicable disposal requirements. 

Question II-2.1-Should the NRC (a) specify a single time period to evaluate the 

performance of facilities disposing of all unique waste streams in the near surface; (b) 

spe~ify criteria requiring the consideration of how the hazard for each unique waste 

stream evolves over time; or (c) permit a licensee to justify a period of performance? 

Question II-2.2-If NRC were to specify a single time period for site specific analysis of 

facilities disposing of unique waste streams in the near surface, what would be an 

appropriate period? What factors should NRC consider in determining a single time 

period of performance? 

Question II-2.3-If NRC were to specify criteria requiring the consideration of how the 

hazard evolves over time for each unique waste stream, what factors should NRC 

consider in determining these criteria? 

Question II-2.4-If NRC were to permit a licensee to justify a time period of 

performance, what factors should NRC consider when evaluating a licensee's 

justification? 

Question II-2.S-If NRC were to specify criteria requiring the consideration of how the 

hazard evolves over time, or permit a licensee to justify a time period of performance, 

should the NRC consider limiting the maximum extent of the time period considered? 

If so, what factors should NRC consider when specifying a maximum period of 

performance? 

Question II-2.G-What other approaches might NRC consider when specifying criteria 

for a period of performance for facilities disposing of unique waste streams in the near 

surface? 

Response to Question II - 2.1-2.6 

There are advantages and disadvantages of specifying the period of performance for disposal 

facilities utilizing near surface disposal methods in the rule versus the guidance. However, industry 

generally supports specifying the period of performance in the rule for consistency across the 

disposal facilities nationwide and to provide for a more transparent and predictable regulatory 

process. Industry suggests that the period of performance be set at 10,000 years for consistency 

with NRC's existing regulatory guidance for low-level waste disposal facilities and other federal 

regulations, e.g., 40 CFR 191 and the Uranium Mill Tailings Radiation Control Act. Industry does not 

support specifying criteria for hazards analysis in the rule. This level of detail and information on 

how to comply with the performance objectives is more appropriate for a guidance document. 

As with any period of performance to demonstrate regulatory compliance, it is best to identify a time 

period where the regulator can determine and the licensee can demonstrate with reasonable 

assurance, and using current technology and methodology, that the applicable regulatory release 

and exposure limits can be met. It is also important that the rule allow for a risk-informed and 

Page 2 
Attachment

performance-based approach by the applicant or licensee to demonstrate compliance with applicable

standards.

NRC should not specify any such criteria in the rule. Any criteria related to evaluating the evolution

of a waste stream over time should be included in a guidance document, if at all, that is

performance based and not prescriptive, or radionuclide or waste stream specific. The licensee

should be required to demonstrate that the applicable regulatory limits or requirements can be met

regardless of its characteristics, e.g., waste origin, quantity, concentration, radionuclide

concentration, and the regulator's role is to verify that the approach proposed by the licensee can,

theoretically, be met which would then be verified through inspection. NRC should solicit additional

stakeholder input through focused and well orchestrated public roundtable workshops, such as those

conducted in September 2009, to gather information from experts on such technical matters before

issuing the draft guidance for comment. Finally, as stated above, industry does not support the

specification of criteria for the period of performance in the rule.

Question II-3.1-Should NRC specify technical criteria for, or permit licensees to justify,

site-specific exposure scenarios for demonstrating compliance with the performance

objective protecting members of the public for unique waste streams?

Industry believes that NRC should permit licensees to justify site-specific exposure scenarios for

demonstrating compliance with the applicable performance objectives. Each site may have unique

characteristics based on its geographic location, geologic features, local zoning ordinances and

preferences by its residents and elected officials, State oversight, level of community, involvement,

activities at adjacent facilities or properties, etc. that would need to be considered when

demonstrating compliance with the performance objectives.

What factors should NRC consider in specifying technical criteria or reviewing licensee

justifications for exposure scenarios associated with members of the public?

Licensees should be expected to use realistically conservative assumptions in any dose modeling or

exposure scenario calculations and NRC should verify the appropriateness and completeness of

these assumptions. However, this approach should be performance-based, in that, the applicable

regulatory requirements including radionuclide release limits and radiation exposure limits must be

demonstrated to be met and verified through inspection. NRC should solicit additional stakeholder

input through focused and well orchestrated public roundtable workshops, such as those conducted

in September 2009, to gather information from experts on such technical matters before issuing the

draft guidance for comment.

Question 11-3.2-Should NRC specify technical criteria for, or permit licensees to justify,

site-specific exposure scenarios for demonstrating compliance with the performance

objective protecting individuals from inadvertent intrusion for unique waste streams?

What factors should NRC consider in specifying technical criteria, or reviewing licensee

justifications, for inadvertent intruder exposure scenarios?

As stated in response to Question 11-3.1, each site may have unique characteristics. Such

characteristics may have a direct or indirect bearing on the likelihood and consequences of, timeline

associated with, and realistically conservative assumptions associated with an inadvertent intrusion

scenario. However, similar to the issue of a period of performance, industry generally supports

including an intruder dose limit in the rule and suggests that NRC consider setting a 500 millirem per

year limit consistent with existing public exposure limits from residual activity at certain sites under

Page 3

Attachment 

performance-based approach by the applicant or licensee to demonstrate compliance with applicable 

standards. 

NRC should not specify any such criteria in the rule. Any criteria related to evaluating the evolution 

of a waste stream over time should be included in a guidance document, if at all, that is 

performance based and not prescriptive, or radionuclide or waste stream specific. The licensee 

should be required to demonstrate that the applicable regulatory limits or requirements can be met 

regardless of its characteristics, e.g., waste origin, quantity, concentration, radionuclide 

concentration, and the regulator's role is to verify that the approach proposed by the licensee can, 

theoretically, be met which would then be verified through inspection. NRC should solicit additional 

stakeholder input through focused and well orchestrated public roundtable workshops, such as those 

conducted in September 2009, to gather information from experts on such technical matters before 

issuing the draft guidance for comment. Finally, as stated above, industry does not support the 

specification of criteria for the period of performance in the rule. 

Question II-3.1-Should NRC specify technical criteria for, or permit licensees to justify, 

site-specific exposure scenarios for demonstrating compliance with the performance 

objective protecting members of the public for unique waste streams? 

Industry believes that NRC should permit licensees to justify site-specific exposure scenarios for 

demonstrating compliance with the applicable performance objectives. Each site may have unique 

characteristics based on its geographic location, geologic features, local zoning ordinances and 

preferences by its residents and elected officials, State oversight, level of community involvement, 

activities at adjacent facilities or properties, etc. that would need to be considered when 

demonstrating compliance with the performance objectives. 

What factors should NRC consider in specifying technical criteria or reviewing licensee 

justifications for exposure scenarios associated with members of the public? 

Licensees should be expected to use realistically conservative assumptions in any dose modeling or 

exposure scenario calculations and NRC should verify the appropriateness and completeness of 

these assumptions. However, this approach should be performance-based, in that, the applicable 

regulatory requirements including radionuclide release limits and radiation exposure limits must be 

demonstrated to be met and verified through inspection. NRC should solicit additional stakeholder 

input through focused and well orchestrated public roundtable workshops, such as those conducted 

in September 2009, to gather information from experts on such technical matters before issuing the 

draft guidance for comment. 

Question II-3.2-Should NRC specify technical criteria for, or permit licensees to justify, 

site-specific exposure scenarios for demonstrating compliance with the performance 

objective protecting individuals from inadvertent intrusion for unique waste streams? 

What factors should NRC consider in specifying technical criteria, or reviewing licensee 

justifications, for inadvertent intruder exposure scenarios? 

As stated in response to Question II-3.!, each site may have unique characteristics. Such 

characteristics may have a direct or indirect bearing on the likelihood and consequences of, timeline 

associated with, and realistically conservative assumptions associated with an inadvertent intrusion 

scenario. However, similar to the issue of a period of performance, industry generally supports 

including an intruder dose limit in the rule and suggests that NRC consider setting a 500 millirem per 

year limit consistent with existing public exposure limits from reSidual activity at certain sites under 

Page 3 
Attachment

Part 20.1403 and considered during a previous Part 61 rulemaking. NRC should solicit additional

stakeholder input through focused and well orchestrated public roundtable workshops, such as those

conducted in September 2009, to gather information from experts on such technical matters before

issuing the draft guidance for comment.

Question III-1.1-Should NRC specify a lower quantity limit in the definition of

"significant quantities" for near surface disposal?

If so, what factors should NRC consider in setting an appropriate lower threshold for

near surface disposal?

Question III-1.2-Should NRC specify an upper quantity limit in the definition of

"significant quantities"?

If so, what factors should NRC consider in setting an appropriate upper threshold for

near surface disposal?

Question III-1.3-Are there alternative methods NRC should consider when specifying

criteria to define "significant quantities"?

Response to Question III -- 1.1-1.3

As discussed during the September public workshops, industry does not believe that NRC should

attempt to define or set a specific quantitative limit for a "significant" quantity of depleted uranium

proposed for disposal. Setting a somewhat arbitrary quantitative limit does not necessarily reflect a

risk-informed and site-specific approach nor does it helps licensees or applicants demonstrate

compliance with the regulatory performance objectives since site characteristics, waste form, waste

concentration and other unique characteristics will need to be considered when determining whether

certain quantities of radionuclides can be disposed of at a specific site and whether the performance

objectives can be met. As such, an "appropriate lower threshold" may be rendered meaningless and,

may also, inadvertently become a defacto regulatory standard.

Question III-2.1-If NRC were to specify a single time period for the site specific

analysis of near-surface disposal of unique waste streams (see Question II.2.1), what

factors associated with disposal of significant quantities of depleted uranium should

NRC consider in determining a single time period of performance for unique waste

streams, including significant quantities of depleted uranium?

As stated previously, NRC should solicit additional stakeholder input through focused and well

orchestrated public roundtable workshops, such as those conducted in September 2009, to gather

information from experts on such technical matters before issuing the draft guidance for comment.

Question III-2.2-If NRC were to specify criteria requiring the consideration of hazards

for each unique waste stream evolving over time (see Question 11.2.1), what factors

should NRC consider in determining these criteria for disposal of significant quantities of

depleted uranium?

Industry does not support the specification of criteria for hazards consideration in an NRC rule. As

stated previously, the rule should be risk-informed and performance-based and any information to

guide applicants or licensees on the type and completeness of information needed to demonstrate

compliance with the regulation should be contained in a guidance document.

Page 4

Attachment 

Part 20.1403 and considered during a previous Part 61 rulemaking. NRC should solicit additional 

stakeholder input through focused and well orchestrated public roundtable workshops, such as those 

conducted in September 2009, to gather information from experts on such technical matters before 

issuing the draft guidance for comment. 

Question III-l.l-Shouid NRC specify a lower quantity limit in the definition of 

"significant quantities" for near surface disposal? 

If so, what factors should NRC consider in setting an appropriate lower threshold for 

near surface disposal? 

Question III-l.2-Should NRC specify an upper quantity limit in the definition of 

"significant quantities"? 

If so, what factors should NRC consider in setting an appropriate upper threshold for 

near surface disposal? 

Question III-l.3-Are there alternative methods NRC should consider when specifying 

criteria to define "significant quantities"? 

Response to Question III -- 1.1-1.3 

As discussed during the September public workshops, industry does not believe that NRC should 

attempt to define or set a specific quantitative limit for a "significant" quantity of depleted uranium 

proposed for disposal. Setting a somewhat arbitrary quantitative limit does not necessarily reflect a 

risk-informed and site-specific approach nor does it helps licensees or applicants demonstrate 

compliance with the regulatory performance objectives since site characteristics, waste form, waste 

concentration and other unique characteristics will need to be considered when determining whether 

certain quantities of radionuclides can be disposed of at a specific site and whether the performance 

objectives can be met. As such, an "appropriate lower threshold" may be rendered meaningless and, 

may also, inadvertently become a defacto regulatory standard. 

Question III-2.1-If NRC were to specify a single time period for the site specific 

analysis of near-surface disposal of unique waste streams (see Question 11.2.1), what 

factors associated with disposal of significant quantities of depleted uranium should 

NRC consider in determining a single time period of performance for unique waste 

streams, including significant quantities of depleted uranium? 

As stated previously, NRC should solicit additional stakeholder input through focused and well 

orchestrated public roundtable workshops, such as those conducted in September 2009, to gather 

information from experts on such technical matters before issuing the draft guidance for comment. 

Question III-2.2-If NRC were to specify criteria requiring the consideration of hazards 

for each unique waste stream evolving over time (see Question 11.2.1), what factors 

should NRC consider in determining these criteria for disposal of significant quantities of 

depleted uranium? 

Industry does not support the specification of criteria for hazards consideration in an NRC rule. As 

stated previously, the rule should be risk-informed and performance-based and any information to 

guide applicants or licensees on the type and completeness of information needed to demonstrate 

compliance with the regulation should be contained in a guidance document. 

Page 4 
Attachment

Question III-2.3-If NRC were to permit a licensee to justify a time period of

performance (see Question 11.2.1), what factors should NRC consider when evaluating a

licensee's justification for disposal of significant quantities of depleted uranium?

Question III-2.4-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time, or permit a licensee to justify a reasonable time period of

performance (see Question 11-2.1), should the NRC consider limiting the maximum

extent of the time period considered for disposal of significant quantities of depleted

uranium? If so, what factors should NRC consider when specifying a maximum period of

performance?

Question 111-2.5-What other approaches might NRC consider when specifying criteria

for a period of performance for near-surface disposal of significant quantities of

depleted uranium?

Response to Question III -- 2.3-2.5

Industry generally supports including a period of performance in the rule and suggests that NRC

considering using 10,000 years consistent with existing NRC guidance.

Question III-3.1-What factors specific to disposal of significant quantities of depleted

uranium should NRC consider in specifying criteria or reviewing a licensee's justification

for exposure scenarios for protection of members of the public?

Question III-3.2-What factors specific to disposal of significant quantities of depleted

uranium should NRC consider in specifying criteria or reviewing a licensee's justification

for exposure scenarios for the protection of individuals from inadvertent intrusion?

Response to Question III -- 3.1-3.2

Industry has no additional information to provide on this matter at this time. NRC should solicit

additional stakeholder input through focused and well orchestrated public roundtable workshops,

such as those conducted in September 2009, to gather information from experts on such technical

matters before issuing the draft guidance for comment.

Question III-4.1-Should NRC specify or permit licensees to propose physical or

chemical forms (e.g., UF6, U308, metal) for disposal of significant quantities of depleted

uranium?

If so, what factors should NRC consider in specifying criteria for or developing guidance

to review an analysis of physical or chemical forms?

NRC should not attempt to specify physical or chemical forms for disposal of significant quantities of

depleted uranium in the rule. The rule should set the performance objectives or dose limits to be

met with the burden on the applicant or licensee to demonstrate compliance with the applicable

limits and regulations. Any criteria for or guidance regarding the analysis of the forms should only be

included in a guidance document and not the rule. Again, a focused workshop with experts should

be conducted before any draft guidance is issued for public comment.

Page 5

Attachment 

Question 11I-2.3-lf NRC were to permit a licensee to justify a time period of 

performance (see Question 11.2.1), what factors should NRC consider when evaluating a 

licensee's justification for disposal of significant quantities of depleted uranium? 

Question 11I-2.4-lf NRC were to specify criteria requiring the consideration of how the 

hazard evolves over time, or permit a licensee to justify a reasonable time period of 

performance (see Question 11-2.1), should the NRC consider limiting the maximum 

extent of the time period considered for disposal of significant quantities of depleted 

uranium? If so, what factors should NRC consider when specifying a maximum period of 

performance? 

Question 111-2.S-What other approaches might NRC consider when specifying criteria 

for a period of performance for near-surface disposal of significant quantities of 

depleted uranium? 

Response to Question III -- 2.3-2.5 

Industry generally supports including a period of performance in the rule and suggests that NRC 

considering using 10,000 years consistent with existing NRC guidance. 

Question 111-3.1-What factors specific to disposal of significant quantities of depleted 

uranium should NRC consider in specifying criteria or reviewing a licensee's justification 

for exposure scenarios for protection of members of the public? 

Question 1I1"':3.2-What factors specific to disposal of significant quantities of depleted 

uranium should NRC consider in specifying criteria or reviewing a licensee's justification 

for exposure scenarios for the protection of individuals from inadvertent intrusion? 

Response to Question III -- 3.1-3.2 

Industry has no additional information to provide on this matter at this time. NRC should solicit 

additional stakeholder input through focused and well orchestrated public roundtable workshops, 

such as those conducted in September 2009, to gather information from experts on such technical 

matters before issuing the draft guidance for comment. 

Question 11I-4.1-Should NRC specify or permit licensees to propose physical or 

chemical forms (e.g., UF6, U308, metal) for disposal of significant quantities of depleted 

uranium? 

If so, what factors should NRC consider in specifying criteria for or developing guidance 

to review an analysis of physical or chemical forms? 

NRC should not attempt to specify physical or chemical forms for disposal of significant quantities of 

depleted uranium in the rule. The rule should set the performance objectives or dose limits to be 

met with the burden on the applicant or licensee to demonstrate compliance with the applicable 

limits and regulations. Any criteria for or guidance regarding the analysis of the forms should only be 

included in a guidance document and not the rule. Again, a focused workshop with experts should 

be conducted before any draft guidance is issued for public comment. 

Page 5 
Attachment

Question III-4.2-Should NRC specify criteria for, or permit licensees to justify,

stabilizing admixtures (e.g., grout) for disposal of significant quantities of depleted

uranium?

If so, what factors should NRC consider in specifying criteria for, or developing guidance

to review, an analysis of admixtures?

Yes, NRC should allow licensees to add stabilizing admixtures (e.g., grout) to depleted uranium to

ensure that the performance objectives can be met. As stated above, the rule should set the

performance objectives or dose limits to be met with the burden on the applicant or licensee to

demonstrate compliance with the applicable limits and regulations. Any criteria for or guidance

regarding the analysis of the forms should only be included in a guidance document and not the

rule.

Question III-4.3-What other factors should NRC consider when specifying criteria, or

developing technical guidance, regarding waste forms for disposal of significant

quantities of depleted uranium in near-surface facilities?

A focused workshop with experts should be conducted before any draft guidance is issued for public

comment.

Question III-4.4-Should NRC require a site-specific analysis to capture previously

disposed quantities of depleted uranium?

If so, what factors should NRC consider when specifying criteria, or developing technical

guidance, regarding previously disposed quantities of depleted uranium?

To date, depleted uranium has been disposed of in accordance with applicable regulations and with

the approval of the appropriate regulatory authorities. There is no evidence to suggest that worker,

environmental or public health and safety has been compromised since applicable requirements

including dose and release limits can be met. That being said, it appears appropriate that NRC

require a total site-specific analysis to capture previously disposed quantities of depleted uranium to

the degree that this information is readily available or can be calculated bases'on available or readily

available information. Such quantities of depleted uranium clearly contribute to the overall site

performance assessment and the licensee's ability to demonstrate compliance with the applicable

performance objectives.

Question III-5.1-Should NRC specify regulatory criteria for, or permit licensees to

justify, site-specific geochemical parameters for the analysis of disposal of significant

quantities of depleted uranium?

Question III-5.2-If NRC should specify regulatory criteria, then what factors should

NRC consider in developing criteria for geochemical parameters for a site-specific

analysis for disposal of significant quantities of depleted uranium?

Question III-5.3-If NRC should permit licensees to justify site-specific geochemical

parameters, then what factors should NRC consider when reviewing a licensee's

justification?

Page 6

Attachment 

Question III-4.2-Should NRC specify criteria for, or permit licensees to justify, 

stabilizing admixtures (e.g., grout) for disposal of significant quantities of depleted 

uranium? 

If so, what factors should NRC consider in specifying criteria for, or developing guidance 

to review, an analysis of admixtures? 

Yes, NRC should allow licensees to add stabilizing admixtures (e.g., grout) to depleted uranium to 

ensure that the performance objectives can be met. As stated above, the rule should set the 

performance objectives or dose limits to be met with the burden on the applicant or licensee to 

demonstrate compliance with the applicable limits and regulations. Any criteria for or guidance 

regarding the analysis of the forms should only be included in a guidance document and not the 

rule. 

Question III-4.3-What other factors should NRC consider when specifying criteria, or 

developing technical guidance, regarding waste forms for disposal of significant 

quantities of depleted uranium in near-surface facilities? 

A focused workshop with experts should be conducted before any draft guidance is issued for public 

comment. 

Question III-4.4-Should NRC require a site-specific analysis to capture previously 

disposed quantities of depleted uranium? 

If so, what factors should NRC consider when specifying criteria, or developing technical 

guidance, regarding previously disposed quantities of depleted uranium? 

To date, depleted uranium has been disposed of in accordance with applicable regulations and with 

the approval of the appropriate regulatory authorities. There is no evidence to suggest that worker, 

environmental or public health and safety has been compromised since applicable requirements 

including dose and release limits can be met. That being said, it appears appropriate that NRC 

require a total site-specific analysis to capture previously disposed quantities of depleted uranium to 

the degree that this information is readily available or can be calculated bases'on available or readily 

available information. Such quantities of depleted uranium clearly contribute to the overall site 

performance assessment and the licensee's ability to demonstrate compliance with the applicable 

performance objectives. 

Question III-S.l-Shouid NRC specify regulatory criteria for, or permit licensees to 

justify, site-specific geochemical parameters for the analysis of disposal of significant 

quantities of depleted uranium? 

Question III-S.2-If NRC should specify regulatory criteria, then what factors should 

NRC consider in developing criteria for geochemical parameters for a site-specific 

analysis for disposal of significant quantities of depleted uranium? 

Question III-S.3-If NRC should permit licensees to justify site-specific geochemical 

parameters, then what factors should NRC consider when reviewing a licensee's 

justification? 

Page 6 
Attachment

Question 111-5.4-What new or alternative approaches should NRC consider regarding

the incorporation of geochemical parameters in a site specific analysis for disposal of

significant quantities of depleted uranium?

Response to Question III -- 5.1-5.4

NRC should not specify regulatory criteria on site-specific geochemical parameters for the disposal of

depleted uranium or other waste streams since such an approach is not risk-informed or

performance-based. Rather, NRC should consider including such technical information in a guidance

document that should be developed, as stated previously, based on input gathered through an

additional public workshop with technical experts.

Question III-6.1-What new approaches for modeling radon emanation, migration, and

exposure pathways, including the effects of differences in the physical and chemical

properties between radon and its progeny, should NRC consider?

Question III-6.2-Should NRC require licensees to evaluate the effects of radon in a

site-specific analysis for disposal of significant quantities of depleted uranium in nearsurface facilities?

Question 111-6.3-Should NRC specify by regulation, or develop guidance on, the

technical parameters for evaluating radon emanation, migration, and exposure in a sitespecific analysis of significant quantities of depleted uranium?

Question III-6.4-If NRC should specify by regulation the technical parameters for

evaluating radon emanation, migration, and exposure, what factors should NRC

consider in specifying technical parameters for a site-specific analysis for significant

quantities of depleted uranium?

Question III-6.5-If NRC should develop guidance on the technical parameters for

evaluating radon emanation, migration, and exposures to accompany regulatory

criteria, then what factors should NRC consider in the development of guidance for

evaluating technical parameters for a site-specific analysis for disposal of significant

quantities of depleted uranium?

Question III-6.6-What societal uncertainties should NRC consider when developing

guidance for scenarios of exposure to radon gas released from the disposal of significant

quantities of depleted uranium?

Question III-6.7-What alternative methods should NRC consider when developing

guidance on evaluating the impacts of radon gas exposures?

For instance, U.S. Environmental Protection Agency standards at 40 CFR Part 192 for the

control of residual radioactive materials from inactive uranium mill tailings sites specify

that releases of radon-222 to the atmosphere will not exceed an average release rate of

20 picocuries per square meter per second or increase the annual average concentration

of radon-222 in air at or above any location outside the disposal site by more than 0.5

picocuries per liter.

Response to Question III -- 6.1-6.7

Page 7

Attachment 

Question III-s.4-What new or alternative approaches should NRC consider regarding 

the incorporation of geochemical parameters in a site specific analysis for disposal of 

significant quantities of depleted uranium? 

Response to Question III -- 5.1-5,4 

NRC should not specify regulatory criteria on site-specific geochemical parameters for the disposal of 

depleted uranium or other waste streams since such an approach is not risk-informed or 

performance-based. Rather, NRC should consider including such technical information in a guidance 

document that should be developed, as stated previously, based on input gathered through an 

additional public workshop with technical experts. 

Question III-6.1-What new approaches for modeling radon emanation, migration, and 

exposure pathways, including the effects of differences in the physical and chemical 

properties between radon and its progeny, should NRC consider? 

Question III-6.2-Should NRC require licensees to evaluate the effects of radon in a 

site-specific analysis for disposal of significant quantities of depleted uranium in nearsurface facilities? 

Question III-6.3-Should NRC specify by r~gulation, or develop guidance on, the 

technical parameters for evaluating radon emanation, migration, and exposure in a sitespecific analysis of significant quantities of depleted uranium? 

Question III-6.4-If NRC should specify by regulation the technical parameters for 

evaluating radon emanation, migration, and exposure, what factors should NRC 

consider in specifying technical parameters for a site-specific analysis for significant 

quantities of depleted uranium? 

Question III-6.s-If NRC should develop guidance on the technical parameters for 

evaluating radon emanation, migration, and exposures to accompany regulatory 

criteria, then what factors should NRC consider in the development of guidance for 

evaluating technical parameters for a site-specific analysis for disposal of significant 

quantities of depleted uranium? 

Question III-6.6-What societal uncertainties should NRC consider when developing 

guidance for scenarios of exposure to radon gas released from the disposal of significant 

quantities of depleted uranium? 

Question III-6.7-What alternative methods should NRC consider when developing 

guidance on evaluating the impacts of radon gas exposures? 

For instance, U.S. Environmental Protection Agency standards at 40 CFR Part 192 for the 

control of residual radioactive materials from inactive uranium mill tailings sites specify 

that releases of radon-222 to the atmosphere will not exceed an average release rate of 

20 picocuries per square meter per second or increase the annual average concentration 

of radon-222 in air at or above any location outside the disposal site by more than 0.5 

picocuries per liter. 

Response to Question III -- 6.1-6.7 

Page 7 
Attachment

No, NRC should not require licensees to evaluate and calculate the potential contribution from radon

in a site-specific analysis for disposal of large quantities of depleted uranium or other waste streams

in near surface facilities. As NRC is aware, radon is ubiquitous and adequately addressed by the

Environmental Protection Agency and individual States. NRC has not, and should not; begin to

attempt to regulate radon and its contribution to dose by requiring licensees to consider its

contribution to any source of exposure regulated by NRC, e.g., uranium mining and milling,

industrial, medical, low-level waste disposal, etc.

Page 8

Attachment 

No, NRC should not require licensees to evaluate and calculate the potential contribution from radon 

in a site-specific analysis for disposal of large quantities of depleted uranium or other waste streams 

in near surface facilities. As NRC is aware, radon is ubiquitous and adequately addressed by the 

Environmental Protection Agency and individual States. NRC has not, and should not; begin to 

attempt to regulate radon and its contribution to dose by requiring licensees to consider its 

contribution to any source of exposure regulated by NRC, e.g., uranium mining and milling, 

industrial, medical, low-level waste disposal, etc. 

Page 8 
Mendiola, Doris

From:

Sent:

To:

Cc:

Subject:

Attachments:

Diane D'Arrigo [dianed@nirs.org]

Friday, October 30, 2009 10:40 PM

Rulemaking Comments; francis.cameron@nrc.gov.

Diane D'Arrigo; pryors02@suddenlink.net

Comment on Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste

Streams Including Significant Quantities of Depleted Uranium (Document ID

NRC-2009-0257-0001)

NIRS NBFB DU comments.doc , j

ý7)

Comment on

Public Workshop: Potential' Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium (Document ID NRC-2009-0257-0001)

Federal Register iVol. 74, No. 120 /Wednesday, June 24, 2009 /Notices 30175

Nuclear Information and Resource Service and No Bonds for Billionaires oppose the categorization of Depleted Uranium

as "low-level" radioactive waste, especially as Class A "low-level" radioactive waste. It is hazardous for longer than

institutional control periods for licensed nuclear waste dumps such as proposed in Andrews TX. Its length of hazard

exceeds the projected hazardous time periods for Classes A, B and C radioactive waste (100, 300 and 500 years

respectively). We have been concerned that the waste already in those classes will be hazardous much longer than it can

be isolated from the environment, the public and precious water supplies. We support comments of lEER (Institute for

Energy and Environmental Research), submitted to this docket separately

http://www.ieer.orq/comments/DUcomments2009.pdf.

Regarding rulemaking on 10 CFR 61, we oppose unjustified piecemeal additions of "Unique Waste Streams Including

Significant Quantities of Depleted Uranium" to the already inappropriately long-lasting waste in the so-called "low-level"

waste classes. We support removing all wastes that remain radioactive longer than the active institutional control period

from inclusion in the so-called "low-level" waste classes.

Diane D'Arrigo

Nuclear Information and Resource Service

Takoma Park MD

dianedcnirs.orq

Peggy and Melodye Pryor

No Bonds for Billionaires

Andrews TX

pryors02Csuddenlink.net

§1] F7a

Fn "D U.) tU)

0 VS -7-- ?ýe_,11 -6-7)

Mendiola. Doris 

From: 

Sent: 

To: 

Cc: 

Diane D'Arrigo [dianed@nirs.org] 

Friday, October 30, 2009 10:40 PM 

Rulemaking Comments; francis.cameron@nrc.gov. 

Diane D'Arrigo; pryors02@suddenlink.net 

Subject: Comment on Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste 

Streams Including Significant Quantities of Depleted Uranium (Document ID 

N RC-2009-0257 -0001 ) 

Attachments: NIRS NBFB DU comments.doc 

Comment on 

Public Workshop: PotentiaI'Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium (Document ID NRC-2009-02S7-0001) 

Federal Register No\. 74, No. 120 IWednesday, June 24, 2009 !Notices 30175 

Nuclear Information and Resource Service and No Bonds for Billionaires oppose the categorization of Depleted Uranium 

as "low-level" radioactive waste, especially as Class A "low-level" radioactive waste. It is hazardous for longer than 

institutional control periods for licensed nuclear waste dumps such as proposed in Andrews TX. Its length of hazard 

exceeds the projected hazardous time periods for Classes A, Band C·radioactive waste (100,300 and 500 years 

respectively). We have been concerned that the waste already in those classes will be hazardous much longer than it can 

be isolated from the environment, the public and precious water supplies. We support comments of lEER (Institute for 

Energy and Environmental Research), submitted to this docket separately 

http://www.ieer.org/commentsIDUcomments2009.pdf. 

Regarding rulemaking on 10 CFR 61, we oppose unjustified piecemeal additions of "Unique Waste Streams Including 

Significant Quantities of Depleted Uranium" to the already inappropriately long-lasting waste in the so-called "low-level" 

waste classes. We support removing all wastes that remain radioactive longer than the active institutional control period 

from inclusion in the so-called "lOW-level" waste classes. 

Diane D'Arrigo 

'Nuclear Information and Resource Service 

Takoma Park MD 

dianed@nirs.org 

Peggy and Melodye Pryor 

No Bonds for Billionaires 

Andrews TX 

pryors02@suddenlink.net 

1 

~]J 

~·"l-l 

.,,-~.,-...,\ 

- -' "--., , I 

, . 
Nuclear Information and Resource Service

No Bonds for Billionaires

Comment on

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium (Document ID NRC-2009-0257-0001)

Federal Register/Vol. 74, No. 120 /Wednesday, June 24, 2009 /Notices 30175

Nuclear Information and Resource Service and No Bonds for Billionaires oppose the

categorization of Depleted Uranium as "low-level" radioactive waste, especially as Class A "lowlevel" radioactive waste. It is hazardous for longer than institutional control periods for licensed

nuclear waste dumps such as proposed in Andrews TX. Its length of hazard exceeds the

projected hazardous time periods for Classes A, B and C radioactive waste (100, 300 and 500

years respectively). We have been concerned that the waste already in those classes will be

hazardous much longer than it can be isolated from the environment, the public and precious

water supplies. We support comments of lEER (Institute for Energy and Environmental

Research), submitted to this docket separately

http://www.ieer.orq/comments/DUcomments2009.pdf.

Regarding rulemaking on 10 CFR 61, we oppose unjustified piecemeal additions of "Unique

Waste Streams Including Significant Quantities of Depleted Uranium" to the already

inappropriately long-lasting waste in the so-called "low-level" waste classes. We support

removing all wastes that remain radioactive longer than the active institutional control period from

inclusion in the so-called "low-level" waste classes.

Diane D'Arrigo

Nuclear Information and Resource Service

Takoma Park MD

dianed@nirs.org

Peggy and Melodye Pryor

No Bonds for Billionaires

Andrews TX

pryors02@suddenlink.net

Nuclear Information and Resource Service 

No Bonds for Billionaires 

Comment on 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium (Document ID NRC-2009-02S7-000l) 

Federal Register No\. 74, No. 120 /Wednesday, June 24, 2009 !Notices 30175 

Nuclear Information and Resource Service and No Bonds for Billionaires oppose the 

categorization of Depleted Uranium as "low-level" radioactive waste, especially as Class A "Iowlevel" radioactive waste. It is hazardous for longer than institutional control periods for licensed 

nuclear waste dumps such as proposed in Andrews TX. Its length of hazard exceeds the 

projected hazardous time periods for Classes A, Band C radioactive waste (100,300 and 500 

years respectively). We have been concerned that the waste already in those classes will be 

hazardous much longer than it can be isolated from the environment, the public and precious 

water supplies. We support comments of lEER (Institute for Energy and Environmental 

Research), submitted to this docket separately 

http://www.ieer.org/commentsIDUcomments2009.pdf. 

Regarding rulemaking on 10 CFR 61, we oppose unjustified piecemeal additions of "Unique 

Waste Streams Including Significant Quantities of Depleted Uranium" to the already 

inappropriately long-lasting waste in the so-called "low-level" waste classes. We support 

removing all wastes that remain radioactive longer than the active institutional control period from 

inclusion in the so-called "low-level" waste classes. 

Diane D'Arrigo 

Nuclear Information and Resource Service 

Takoma Park MD 

dianed@nirs.org 

Peggy and Melodye Pryor 

No Bonds for Billionaires 

Andrews TX 

pryors02@suddenlink.net 
40r-Il

"7

TALISMAN

October 30, 2009 _ !.,j

Michael Lesar

Chief, Rulemaking and Directive Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001 ..

Subject: Comments on Potential Rulemaking for Safe Disposal of Unique Waste

Streams Including Significant Quantities of Depleted Uranium - 74 FR

30175

Dear Mr. Lesar:

We are filing these comments on behalf of Talisman International, LLC, in response to

the subject notice. In our view, it is important to establish a clear requirement in 10 CFR

Part 61 to perform performance assessments to ensure sites meet the performance

objectives of Part 61. In that regard, there are several fundamental changes that need to

be made to Part 61 to strengthen that requirement. Other matters to improve the

implementation of Part 61 can be treated by NRC guidance. Our comments are contained

in the attachment.

Questions regarding these comments may be directed to Jim Lieberman at (301) 299-

3607 or jlglieblet.com and to John Greeves at (301) 452-3511 or greevesjgaol.com.

Sincerely,

J Lm Le-mo-v

Jim Lieberman

Senior Regulatory Nuclear Consultant

J'ohrv reeve,

John Greeves

Senior Regulatory Nuclear Consultant

I c-

-7i)

/Y/Y)

,( 

TALISMAN 

October 30, 2009 

Michael Lesar 

Chief, Rulemaking and Directive Branch 

Division of Administrative Services 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

Subject: Comments on Potential Rulemaking for Safe Disposal of Unique Waste 

Streams Including Significant Quantities of Depleted Uranium -74 FR 

30175 

Dear Mr. Lesar: 

We are filing these comments on behalf of Talisman International, LLC, in response to 

the subject notice. In our view, it is important to establish a clear requirement in 10 CFR 

Part 61 to perform performance assessments to ensure sites meet the performance 

objectives of Part 61. In that regard, there are several fundamental changes that need to 

be made to Part 61 to strengthen that requirement. Other matters to improve the 

implementation of Part 61 can be treated by NRC guidance. Our comments are contained 

in the attachment. 

Questions regarding these comments may be directed to Jim Lieberman at (301) 299-

3607 or il@lieblet.com and to John Greeves at (301) 452-3511 or greevesj@aol.com. 

Sincerely, 

Jim Lieberman 

Senior Regulatory Nuclear Consultant 

John Greeves 

Senior Regulatory Nuclear Consultant 

, ,) 

. .',1 
Comments on Potential Rulemaking

Safe Disposal of Unique Waste Streams including

Significant Quantities of Depleted Uranium

We support the concept of a rulemaking to specify a requirement for a site-specific

analysis and associated technical requirements for the disposal of significant quantities of

depleted uranium as directed by the Commission in StaffRequirements-SECY-08-

0147-Response to Commission Order CLI-05-20 Regarding Depleted Uranium.

1) 10 CFR 61.13

The issue before the Commission is what changes should be made to 10 CFR Part 61 to

ensure that large quantities of depleted uranium and other unique waste streams are

disposed safely. In our view the solution to this issue is to a large degree clarifying the

requirements to perform a site specific performance assessment demonstrating that the

performance objectives of Part 61 are met. This is consistent with the view of the

Commission in the Louisiana Energy Services proceeding, CLI-05-05 at page 11, January

18, 2005, that:

In the end, the "bottom line for disposal" of low-level radioactive wastes are the

performance objectives of 10 C.F.R. Subpart C, which set forth the ultimate

standards and radiation limits for (1) protection of the general population from

releases of radioactivity; (2) protection of individuals from inadvertent intrusion;

(3) protection of individuals during operations; (4) and stability of the disposal

site after closure. Thus, while there may not yet be detailed technical criteria

established for all of the kinds of land disposal that might be proposed under Part

61, criteria can be developed "on a case-by-case basis," as needed. After all, any

technical requirements are "intended to help ensure that the performance

objectives established in Subpart C are met," but they are "not the end in

themselves, ... [only] a means of achieving the end," which are the performance

standards. (Citations omitted)

Currently, 10 CFR 61.12 and 13 addresses the need to demonstrate that the performance

objectives will be met. However, these provisions have been interpreted by some to not

require the submittal of a site specific performance assessment. As to protection against

the intruder, NRC appears to have accepted the provisions of 10 CFR 61.52 (a)(2) for

either five meter depth or the 500 year intruder barrier to meet the performance

objectives of 10 CFR 61.42. While these depths and barriers may be sufficient in many

cases to meet the performance objectives, without a site specific performance assessment

there is not assurance that the performance objectives will be met for all waste packages

regardless of the radionuclides.

Therefore, we recommend that 10 CFR61.13 be clarified to require that the analyses

required to demonstrate that the performance objectives of subpart C of part 61.41 and

61.42 will be met include a site specific performance assessment. We also recommend

Comments on Potential Rulemaking 

Safe Disposal of Unique Waste Streams including 

Significant Quantities of Depleted Uranium 

We support the concept of a rulemaking to specify a requirement for a site-specific 

analysis and associated technical requirements for the disposal of significant quantities of 

depleted uranium as directed by the Commission in Staff Requirements-SECY-08-

0147-Response to Commission Order CLI-05-20 Regarding Depleted Uranium. 

1) 10 CFR 61.13 

The issue before the Commission is what changes should be made to 10 CFR Part 61 to 

ensure that large quantities of depleted uranium and other unique waste streams are 

disposed safely. In our view the solution to this issue is to a large degree clarifying the 

requirements to perform a site specific performance assessment demonstrating that the 

performance objectives of Part 61 are met. This is consistent with the view of the 

Commission in the Louisiana Energy Services proceeding, CLI-05-05 at page 11, January 

18, 2005, that: 

In the end, the "bottom line for disposal" of low-level radioactive wastes are the 

peiformance objectives of 10 C.F.R. Subpart C, which set forth the ultimate 

standards and radiation limits for (1) protection of the general population from 

releases of radioactivity; (2) protection of individuals from inadvertent intrusion; 

(3) protection of individuals during operat~ons; (4) and stability of the disposal 

site after closure. Thus, while there may not yet be detailed technical criteria 

established for all of the kinds of land disposal that might be proposed under Part 

61, criteria can be developed "on a case-by-case basis," as needed. After all, any 

technical requirements are "intended to help ensure that the performance 

objectives established in Subpart C are met," but they are "not the end in 

themselves, ... [ only] a means of achieving the end," which are the performance 

standards. (Citations omitted) 

Currently, 10 CFR 61.12 and 13 addresses the need to demonstrate that the performance 

objectives will be met. However, these provisions have been interpreted by some to not 

require the submittal of a site specific performance assessment. As to protection against 

the intruder, NRC appears to have accepted the provisions of 10 CFR 61.52 (a)(2) for 

either five meter depth or the 500 year intruder barrier to meet the performance 

objectives of 10 CFR 61.42. While these depths and barriers may be sufficient in many 

cases to meet the performance objectives, without a site specific performance assessment 

there is not assurance that the performance objectives will be met for all waste packages 

regardless of the radionuclides. 

Therefore, we recommend that 10 CFR61.13 be clarified to require that the analyses 

required to demonstrate that the performance objectives of subpart C of part 61.41 and 

61.42 will be met include a site specific performance assessment. We also recommend 
2

that there be periodic updating of the performance assessment to reflect changed

conditions at the site, past disposal history, and new methodology, if any. This is

consistent with the approach taken by DOE at its disposal sites under DOE Order 435.1.

In addition, we recommend that this amendment adopts a Part 61 compliance a period of

10,000 years consistent with NUREG 1573 and 40 CFR 191. However, recognizing the

peak dose may occur after this period, we recommend that the rule require a qualitative

analysis if the peak occurs beyond 10,000 years for input into the environmental analysis

consistent with section 3.2.3 of NUREG-1573, A Performance Assessment Methodology

for Low-Level Radioactive Waste Disposal Facilities (2000), to determine if there is a

need for environmental mitigation. This is also consistent with Section IV.A.6 of the

Decommissioning Criteria for the West Valley Demonstration Project at the West valley

Site (67 FR 5003, 5006, Feb 1, 2002). See also section 4.1.1.1 ofNUREG-1854, NRC

Staff Guidance for Activities Related to US DOE Waste Determinations (2007). A

period of compliance in the rule would assure consistent assessment of compliance by all

parties.

Recognizing that performance assessments require the use of assumptions and scenarios,

we also recommend that the proposed language provides that the assumptions and

scenarios used in performance assessments be reasonably foreseeable to avoid undue

speculation and overly conservative approaches. NRC should permit licensees to justify,

site-specific assumptions and exposure scenarios based on reasonably foreseeable

circumstances to evaluate the critical group that could reasonable encounter material that

is released from the disposal cell after the institutional control period based on reasonably

foreseeable circumstances. This would include residential use; farming; resident

farming; and any other reasonable use consistent with the current environment of the

specific site. For example, a site would not be expected to consider a groundwater

pathway if the groundwater was not useable for irrigation or human consumption. In

addition, the assumptions for the performance analyses would not need to project changes

in society, the biosphere, human biology, or increases or decreases of human knowledge

or technology except for foreseeable changes to the geology, hydrology, and climate

based upon cautious, but reasonable assumptions of the changes in these factors that

could affect the disposal site. The actual details for performing performance assessments

consistent with the regulatory language would be treated in NRC guidance which can be

updated periodically by the NRC without a rule change.

Specifically, we would recommend that the introductory sentence of 10 CFR 61.13 be

amended to read:

The specific technical information must also include the following analyses

needed to demonstrate that the pcrformancc objcctivcs of subpart C willb

met- a site specific performance assessment to demonstrate that the

performance obiectives of subpart C of this part will be met. The

performance assessment would need to be updated for Commission approval

at a five year frequency unless the license provides an alternative period for

updatin2 it. The performance assessment shall include the followin2 analyses

2 

that there be periodic updating of the performance assessment to reflect changed 

conditions at the site, past disposal history, and new methodology, if any. This is 

consistent with the approach taken by DOE at its disposal sites under DOE Order 435.1. 

In addition, we recommend that this amendment adopts a Part 61 compliance a period of 

10,000 years consistent with NUREG 1573 and 40 CFR 191. However, recognizing the 

peak dose may occur after this period, we recommend that the rule require a qualitative 

analysis if the peak occurs beyond 10,000 years for input into the environmental analysis 

consistent with section 3.2.3 ofNUREG-1573, A Performance Assessment Methodology 

for Low-Level Radioactive Waste Disposal Facilities (2000), to determine ifthere is a 

need for environmental mitigation. This is also consistent with Section IV.A.6 of the 

Decommissioning Criteria for the West Valley Demonstration Project at the West valley 

Site (67 FR 5003, 5006, Feb 1, 2002). See also section 4.1.1.1 ofNUREG-1854, NRC 

Staff Guidance for Activities Related to US DOE Waste Determinations (2007). A 

period of compliance in the rule would assure consistent assessment of compliance by all 

parties. 

Recognizing that performance assessments require the use of assumptions and scenarios, 

we also recommend that the proposed language provides that the assumptions and 

scenarios used in performance assessments be reasonably foreseeable to avoid undue 

speculation and overly conservative approaches. NRC should permit licensees to justify, 

site-specific assumptions and exposure scenarios based on reasonably foreseeable 

circumstances to evaluate the critical group that could reasonable encounter material that 

is released from the disposal cell after the institutional control period based on reasonably 

foreseeable circumstances. This would include residential use; farming; resident 

farming; and any other reasonable use consistent with the current environment ofthe 

specific site. For example, a site would not be expected to consider a groundwater 

pathway if the groundwater was not useable for irrigation or human consumption. In 

addition, the assumptions for the performance analyses would not need to project changes 

in society, the biosphere, human biology, or increases or decreases of human knowledge 

or technology except for foreseeable changes to the geology, hydrology, and climate 

based upon cautious, but reasonable assumptions ofthe changes in these factors that 

could affect the disposal site. The actual details for performing performance assessments 

consistent with the regulatory language would be treated in NRC guidance which can be 

updated periodically by the NRC without a rule change. 

Specifically, we would recommend that the introductory sentence of 10 CFR 61.13 be 

amended to read: 

The specific technical information must also include the following analyses 

needed to demonstrate that the performanee objedives of subpart C wiD be 

meH a site specific performance assessment to demonstrate that the 

performance objectives of subpart C of this part will be met. The 

performance assessment would need to be updated for Commission approval 

at a five year frequency unless the license provides an alternative period for 

updating it. The performance assessment shall include the following analyses 
3

and be preformed for a compliance period of 10,000 years using reasonably

foreseeable assumptions and scenarios. If the peak dose occurs after 10,000

years. a qualitative analysis shall be prepared up to the time of the peak dose

for consideration in the site's environmental evaluation.

2) 10 CFR 61.13 (b)

An important aspect of the performance assessment is to demonstrate that the

performance objective for the intruder is met. Demonstration of meeting the applicable

performance objective is currently in paragraph (a). Therefore, we recommend that the

requirements for the analysis required in 10 CFR 61.13 (b) be amended to be consistent

with section 61.13(a). Section 61.13(b) would read:

(b) Analyses of the protection of individuals from inadvertent intrusion must

include demonstration that there is reasonable assurance the waste

classification and segregation requirements will be met and that adequate

barriers to inadvertent intrusion will be provided. The analyses must clearly

identify and differentiate between the roles performed by the natural

disposal site characteristics and design features in isolating and segreaating

the wastes. The analyses must clearly demonstrate that there is reasonable

assurance that the exposure to humans from the release of radioactivity will

not exceed the limits set forth in § 61.42.

3) 10 CFR 61.41

We recommend that an amendment to section 61.41 be made to update the annual dose

methodology to the newer methodology of ICRP 26 and 30 used in 10 CFR Part 20

rather than the methodology used in Part 61 based on ICRP 2 recommendations. This is

consistent with the approach taken in sections 3.3.7.1.2 and 3.3.7.3.1 of NUREG 1573;

footnote 6 of the Decommissioning Criteria for the West Valley Demonstration Project at

the West Valley Site (67 FR 5003, 5005, Feb 1, 2002); and section 4.6.1.3 of NUREG1854.

In addition, section 61.41 should be amended to be consistent with the period of

compliance stated in the proposed amendment to 10 CFR 61.13. Section 61.41 would

read:

Concentrations of radioactive material which may be released to the general

environment in ground water, surface water, air, soil, plants, or animals

must not result in an annual dose exceeding an equivalent of 25 millirems

total effective dose equivalent for a compliance period of 10,000 years i5

millircms to the whole body, 75 millirems to the thyroid, and 25 millircms to

any other- organ o to any member of the public. Reasonable effort should

be made to maintain releases of radioactivity in effluents to the general

environment as low as is reasonably achievable.

3 

and be preformed for a compliance period of 10,000 years using reasonably 

foreseeable assumptions and scenarios. If the peak dose occurs after 10,000 

years, a qualitative analysis shall be prepared up to the time of the peak dose 

for consideration in the site's environmental evaluation. 

2) 10 CFR 61.13 (b) 

An important aspect ofthe performance assessment is to demonstrate that the 

performance objective for the intruder is met. Demonstration of meeting the applicable 

performance objective is currently in paragraph (a). Therefore, we recommend that the 

requirements for the analysis required in 10 CFR 61.13 (b) be amended to be consistent 

with section 61. 13(a). Section 61. 13 (b) would read: 

(b) Analyses of the protection of individuals from inadvertent intrusion must 

include demonstration that there is reasonable assurance the waste 

classification and segregation requirements will be met and that adequate 

barriers to inadvertent intrusion will be provided. The analyses must clearly 

identify and differentiate between the roles performed by the natural 

disposal site characteristics and design features in isolating and segregating 

the wastes. The analyses must clearly demonstrate that there is reasonable 

assurance that the exposure to humans from the release of radioactivity will 

not exceed the limits set forth in § 61.42. 

3) 10 CFR 61.41 

We recommend that an amendment to section 61.41 be made to update the annual dose 

methodology to the newer methodology ofICRP 26 and 30 used in 10 CFR Part 20 

rather than the methodology used in Part 61 based on ICRP 2 recommendations. This is 

consistent with the approach taken in sections 3.3.7.1.2 and 3.3.7.3.1 ofNUREG 1573; 

footnote 6 of the Decommissioning Criteria for the West Valley Demonstration Project at 

the West Valley Site (67 FR 5003,5005, Feb 1,2002); and section 4.6.1.3 ofNUREG1854. 

In addition, section 61.41 should be amended to be consistent with the period of 

compliance stated in the proposed amendment to 10 CFR 61.13. Section 61.41 would 

read: 

Concentrations of radioactive material which may be released to the general 

environment in ground water, surface water, air, soil, plants, or .animals 

must not result in an annual dose exceeding an equivalent of 25 millirems 

total effective dose equivalent for a compliance period of 10,000 years ~ 

millirems ta the whale bady, 75 millirems ta the thyraid, and 25 millirems ta 

any ather argan af to any member of the public. Reasonable effort .should 

be made to maintain releases of radioactivity in effluents to the general 

environment as low as is reasonably achievable. 
4

4) 10 CFR 61.42

10 CFR 61.42 currently requires "...protection of any individual inadvertently intruding

into the disposal site and occupying the site or contacting the waste;" however, the

regulations are silent on the specific dose standard to apply. We recommend that section

61.42 be amended to provide a dose standard for an intruder of 500 mr/yr. This would

provide in the rule the dose standard that currently is only stated in guidance. It is noted

that the 500 millirem was the standard proposed in Part 61 in 1981. ( 46 FR 38081, July

24, 1981). The Statement of Considerations for the final rule did not object to the

number. It was removed apparently at the request of EPA because of its concern of how

one would monitor it or demonstrate compliance with it, but not because EPA disagreed

with it. (47 FR57446, 57449, December 27, 1982). A dose standard of 500 mr/yr is also

used as part of the license termination rule dose standard for intruders (10 CFR 20.1403).

A dose objective would assure consistent assessment of compliance by all parties.

Section 61.42 would read:

Design, operation, and closure of the land disposal facility must ensure

protection of any individual inadvertently intruding into the disposal site and

occupying the site or contacting the waste at any time after active

institutional controls over the disposal site are removed. The intrusion must

not result in an annual dose exceeding an equivalent of 500 millirems total

effective dose equivalent for a compliance period of 10,000 years.

5) 10 CFR 61.55

If the Commission adopts the above changes, performance assessments would be the

norm for disposal sites. However, such performance assessments would be performed

initially when the applicant applied for its license and then periodically thereafter. There

could be a situation where a licensee desired to dispose of depleted uranium or other

radionuclide not addressed in the tables under situations where either the performance

assessment had not considered the depleted uranium or other radionuclide, or the

performance assessment had yet to be performed. This could be addressed by

establishing a requirement that would provide for a site specific performance assessment

if the quantity of the radionuclide to be disposed had not been previously considered in a

performance assessment approved by the NRC. Such a performance assessment would

need to meet the amended provisions discussed above. However, this does not

necessarily mean that a new performance assessment would need to be developed.

Depending on the scope and detail of an existing performance assessment, a current

performance assessment may only need minor changes to update it to include the new

radionuclide.

We recommend that 10 CFR 61.55 (a)(6) be amended to read:

(6) Classification of wastes with radionuclides other than those listed in

Tables 1 and 2. If radioactive waste does not contain any nuclides listed in

4 

4) 10 CFR 61.42 

10 CFR 61.42 currently requires" ... protection of any individual inadvertently intruding 

into the disposal site and occupying the site or contacting the waste;" however, the 

regulations are silent on the specific dose standard to apply. We recommend that section 

61.42 be amended to provide a dose standard for an intruder of500 mr/yr. This would 

provide in the rule the dose standard that currently is only stated in guidance. It is noted 

that the 500 millirem was the standard proposed in Part 61 in 1981. ( 46 FR 38081, July 

24, 1981). The Statement of Considerations for the final rule did not object to the 

number. It was removed apparently at the request of EPA because of its concern of how 

one would monitor it or demonstrate compliance with it, but not because EPA disagreed 

with it. (47 FR57446, 57449, December 27,1982). A dose standard of500 mr/yr is also 

used as part of the license termination rule dose standard for intruders (10 CFR 20.1403). 

A dose objective would assure consistent assessment of compliance by all parties. 

Section 61.42 would read: 

Design, operation, and closure of the land disposal facility must ensure 

protection of any individual inadvertently intruding into the disposal site and 

occupying the site or contacting the waste at any time after active 

institutional controls over the disposal site are removed. The intrusion must 

not result in an annual dose exceeding an equivalent of 500 millirems total 

effective dose equivalent for a compliance period of 10,000 years. 

5) 10 CFR 61.55 

If the Commission adopts the above changes, performance assessments would be the 

norm for disposal sites. However, such performance assessments would be performed 

initially when the applicant applied for its license and then periodically thereafter. There 

could be a situation where a licensee desired to dispose of depleted uranium or other 

radionuclide not addressed in the tables under situations where either the performance 

assessment had not considered the depleted uranium or other radionuclide, or the 

performance assessment had yet to be performed. This could be addressed by 

establishing a requirement that would provide for a site specific performance assessment 

if the quantity of the radio nuclide to be disposed had not been previously considered in a 

performance assessment approved by the NRC. Such a performance assessment would 

need to meet the amended provisions discussed above. However, this does not 

necessarily mean that a new performance assessment would need to be developed. 

Depending on the scope and detail of an existing performance assessment, a current 

performance assessment may only need minor changes to update it to include the new 

radionuclide. 

We recommend that 10 CFR 61.55 (a)(6) be amended to read: 

(6) Classification of wastes with radionuclides other than those listed in 

Tables 1 and 2. If radioactive waste does not contain any nuclides listed in 
5

either Table 1 or 2, it is Class A. However, before such waste can be disposed

a performance assessment must be approved by the Commission.

6) Definition of Significant Quantity and Unique Waste Stream

The subject Federal Register notice sought input on how the NRC should define a

"significant quantity" of depleted uranium and unique waste streams. In light of the

recommended changes discussed above, it is unnecessary to define these terms as the

performance assessment will address them.

7) Guidance vs. Regulation

Regulations provide for certainty, consistency, and enforceability. However, changing

regulations entails significant effort and time. Guidance while not directly enforceable is

easier to change over time. Consequently, it is our view that the fundamental objectives

should be in regulations leaving the details for guidance. This leaves the regulator in the

position to offer its positions on implementation to the industry as guidance and the

industry the ability to defend other ways to implement the fundamental objectives.

However, it is important that the development of guidance like regulations involve public

input that would allow for public comments on drafts before such guidance is issued for

use by either the staff or industry.

Accordingly, we recommend as indicated above that requirements include the need to

demonstrate meeting of performance objectives through performance assessments,

compliance periods, dose standards, and the standard for scenarios and assumptions used

in performance assessments. However, the details for achieving compliance which are

often site related should be in guidance. In that regard, the subject Federal Register

notice addressed a number of issues for consideration in this rulemaking, e.g.,

geochemical parameters, impacts of radon gas releases, and details of performance

assessments. In our view, the issues other than the ones we addressed above should be

addressed in NRC guidance and not made a part of this rulemaking.

8) Implementation

It is recognized that existing licensees may need an appropriate time period to prepare

quality performance assessments so that ongoing operations will not be unduly

interrupted. It is suggested that the effective date be 12 months after publication in the

Federal Register. However, recognizing it is difficult to predict how long it may take for

a regulator to review and approve a performance assessment, the rule should provide that

disposals made after the effective date may be made if the required performance

assessment was submitted for approval at least six months prior to the effective date.

5 

either Table 1 or 2, it is Class A. However, before such waste can be disposed 

a performance assessment must be approved by the Commission. 

6) Definition of Significant Quantity and Unique Waste Stream 

The subject Federal Register notice sought input on how the NRC should define a 

"significant quantity" of depleted uranium and unique waste streams. In light of the 

recommended changes discussed above, it is unnecessary to define these terms as the 

performance assessment will address them. 

7) Guidance vs. Regulation 

Regulations provide for certainty, consistency, and enforceability. However, changing 

regulations entails significant effort and time. Guidance while not directly enforceable is 

easier to change over time. Consequently, it is our view that the fundamental objectives 

should be in regulations leaving the details for guidance. This leaves the regulator in the 

position to offer its positions on implementation to the industry as guidance and the 

industry the ability to defend other ways to implement the fundamental objectives. 

However, it is important that the development of guidance like regulations involve public 

input that would allow for public comments on drafts before such guidance is issued for 

use by either the staff or industry. 

Accordingly, we recommend as indicated above that requirements include the need to 

demonstrate meeting of performance objectives through performance assessments, 

compliance periods, dose standards, and the standard for scenarios and assumptions used 

in performance assessments. However, the details for achieving compliance which are 

often site related should be in guidance. In that regard, the subject Federal Register 

notice addressed a number of issues for consideration in this rulemaking, e.g., 

geochemical parameters, impacts of radon gas releases, and details ofperformance 

assessments. In our view, the issues other than the ones we addressed above should be 

addressed in NRC guidance and not made a part of this rulemaking. 

8) Implementation 

It is recognized that existing licensees may need an appropriate time period to prepare 

quality performance assessments so that ongoing operations will not be unduly 

interrupted. It is suggested that the effective date be 12 months after publication in the 

Federal Register. However, recognizing it is difficult to predict how long it may take for 

a regulator to review and approve a performance assessment, the rule should provide that 

disposals made after the effective date may be made if the required performance 

assessment was submitted for approval at least six months prior to the effective date. 
LES

NOV 02 2009

NEF-09-00209-NRC

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Mail Stop TWB 5B01 M

Washington, DC 20555-0001

UPTnOo

~(~2/7s

iiiT

I2N

(f

Louisiana Energy Services, LLC

NRC Docket 70-3103

Subject:

Reference:

Louisiana Energy Services, LLC, National Enrichment Facility

Submittal of Comments on Proposed Rulemaking

1) Federal Register Notice (FRN), Wednesday, June 24, 2009,

Page 30175

As identified in Reference 1, the U. S. Nuclear Regulatory Commission (NRC) has

proposed rulemaking relative to safe disposal of unique waste streams including

significant quantities of depleted uranium. The NRC staff has also invited comments on

both the issues and questions presented in the FRN.

Louisiana Energy Services, LLC (LES) is hereby submitting written comments on the

issues and questions discussed in the FRN. General comments on the issues and

specific comments on the questions are included in Enclosure 1.

LES supported the recently held depleted uranium rulemaking workshops sponsored by

the NRC, however, given the Performance Objectives in 10 CFR 61, Subpart C, LES

does not believe additional rulemaking is necessary.

Furthermore, in regard to "unique waste streams", LES does not believe it practical or

prudent to attempt to define unique waste streams at present or for the foreseeable

future. LES supports a performance-based approach to waste streams using existing

performance objectives to make determinations for regulatory compliance regarding

disposal.

LES believes that the language involving "significant quantities" should be discontinued.

NRC staff has not provided a proposed definition of the term, which leaves it open for

interpretation. Previous industry experience with ambiguous regulatory language has

resulted in numerous interpretations, confusion and a lack of consistent implementation.

LES building and operating the National Enrichment Facility providing energy independence for America

National Enrichment Facility, PO Box 1789, Eunice, New Mexico 88231, USA T: +1 575 394 4646 F: +1 575 394 4545 W:www.nefnm.com

GLES I~OV 0 2 2009 

NEF-09-00209-NRC 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Mail Stop lWB 5B01 M 

Washington, DC 20555-0001 

Louisiana Energy Services, LLC 

NRC Docket 70-3103 

.. J] 

-"il 

.,. .......... 

) 

, i .... ,..,.... ... . '~ ..... 

r'\ .... , 

\,J 

Subject: Louisiana Energy Services, LLC, National Enrichment Facility 

Submittal of Comments on Proposed Rulemaking 

Reference: 1) Federal Register Notice (FRN), Wednesday, June 24, 2009, 

Page 30175 

: 

I ... ') 

r-:-,? 

.t::: 

N 

As identified in Reference 1, the U. S. Nuclear Regulatory Commission (NRC) has 

proposed rulemaking relative to safe disposal of unique waste streams including 

significant quantities of depleted uranium. The NRC staff has also invited comments on 

both the issues and questions presented in the FRN. 

Louisiana Energy Services, LLC (LES) is hereby submitting written comments on the 

issues and questions discussed in the FRN. General comments on the issues and 

specific comments on the questions are included in Enclosure 1. 

LES supported the recently held depleted uranium rulemaking workshops sponsored by 

the NRC, however, given the Performance Objectives in 10 CFR 61, Subpart C, LES 

does not believe additional rulemaking is necessary. 

Furthermore, in regard to "unique waste streams", LES does not believe it practical or 

prudent to attempt to define unique waste streams at present or for the foreseeable 

future. LES supports a performance-based approach to waste streams using existing 

performance objectives to make determinations for regulatory compliance regarding 

disposal. 

LES believes that the language involving "significant quantities" should be discontinued. 

NRC staff has not provided a proposed definition of the term, which leaves it open for 

interpretation. Previous industry experience with ambiguous regulatory language has 

. resulted in numerous interpretations, confusion and a lack of consistent implementation. . ~ . . 

6u;)S]: 8e/IJ~/J~~ ~-/(F2£:7IfJ)H-[)3 . 

'r;-: .~. I' ~ -a-tt~~ (&6~) 

~,;A~ _Pd:JJ4-EJG 13- "j?~/1iJ~fr14 L/JA/~) ~"'-l - r ),Cd4 V (flY) 

LES building and operating the National Enrichment Facility providing energy independence for America 

National Enrichment Facility, PO Box 1789, Eunice, New Mexico 88231, USA T: +1 5753944646 F: +1 5753944545 W: www.nefnm.com 

::u c= r--

fj"i V) 
Should you have any questions related to this submittal, please contact Mr. Stephen R.

Cowne, Director, Quality and Regulatory Affairs at 575.394.5253.

Respectfully,

; Smith

Chief Operating Officer and Chief Nuclear Officer

Enclosure: As stated

Should you have any questions related to this submittal, please contact Mr. Stephen R. 

Cowne, Director, Quality and Regulatory Affairs at 575.394.5253. 

~ReSpectfUIIY'=Q ~.~ 

~ooSmith Chief Operating Officer and Chief Nuclear Officer 

Enclosure: As stated 
Enclosure 1

LES Comments Regarding Federal Register Notice, Wednesday June 24, 2009,

Page 30175

Enclosure 1 

LES Comments Regarding Federal Register Notice, Wednesday June 24, 2009, 

Page 30175 
Issue General Comments

Issue General Comment Summary:

* LES believes that depleted uranium (DU), when not considered a resource, is

properly characterized as a Class A low level radioactive waste.

" LES does not believe that rulemaking, even limited rulemaking, is necessary to

ensure the Performance Objectives of 10 CFR 61 Subpart C are met to protect

public health and safety.

" Rulemaking cannot occur in a vacuum. Cost-benefit analysis and backfit

assessments must be integral parts considered for any new proposed rulemaking

when the potential outcome of the rulemaking can impact financial and business

models which precede the proposed rulemaking.

" The actual decision to proceed with a rulemaking, even one of limited scope,

should follow and reflect careful consideration of stakeholder input from the

public workshops and this Federal Register Notice (FRN) comment period-the

Commission should be willing to reconsider the need for rulemaking based on the

results of the comments received.

" LES is prepared to work with the NRC to engage and discuss the issues regarding

depleted uranium.

Characterization of Depleted Uranium (DU)

LES believes the current NRC characterization of DU is correct:

* On March 18, 2009 a majority of the NRC Commissioners voted to retain the

Class A low level radioactive waste classification of DU. This recent NRC action

was not a change to the classification of DU. It has been regulated as Class A

waste for decades. With its March 18 vote, the NRC merely reaffirmed the

existing Class A classification.

" LES agrees with and supports the Commission characterization of depleted

uranium as a Class A low level waste, when no longer considered a resource.

* LES appropriately retains the authority and responsibility to declare when

depleted uranium is no longer considered a resource for the owner and is allowed

to base those decisions on current and future market conditions.

Issue General Comments 

Issue General Comment Summary: 

• LES believes that depleted uranium (DU), when not considered a resource, is 

properly characterized as a Class A low level radioactive waste. 

• LES does not believe that rulemaking, even limited rulemaking, is necessary to 

ensure the Performance Objectives of 10 CFR 61 Subpart C are met to protect 

public health and safety. 

• Rulemaking cannot occur in a vacuum. Cost-benefit analysis and backfit 

assessments must be integral parts considered for any new proposed rulemaking 

when the potential outcome of the rulemaking can impact financial and business 

models which precede the proposedrulemaking. 

• The actual decision to proceed with a rulemaking, even one of limited scope, 

should follow and reflect careful consideration of stakeholder input from the 

public workshops and this Federal Register Notice (FRN) comment period-the 

Commission should be willing to reconsider the need for rulemaking based on the 

results of the comments received. 

• LES is prepared to work with the NRC to engage and discuss the issues regarding 

depleted uranium. 

Characterization of Depleted Uranium (DU) 

LES believes the current NRC characterization ofDU is correct: 

• On March 18, 2009 a majority of the NRC Commissioners voted to retain the 

Class A low level radioactive waste classification ofDD. This recent NRC action 

was not a change to the classification ofDD. It has been regulated as Class A 

waste for decades. With its March 18 vote, the NRC merely reaffirmed the 

existing Class A classification. 

• LES agrees with and supports the Commission characterization of depleted 

uranium as a Class A low level waste, when no longer considered a resource. 

• LES appropriately retains the authority and responsibility to declare when 

depleted uranium is no longer considered a resource for the owner and is allowed 

to base those decisions on current and future market conditions. 
Rulemakin2

LES believes there is no need for additional rulemaking, even limited rulemaking, to

address the issue of site-specific analysis for waste streams at present or for future

waste streams for the following reasons:

" Rulemaking is not required as current regulations include appropriate

Performance Objectives for maintaining public health and safety

* The Performance Objectives in 10 CFR 61, Subpart C identify current compliance

requirements with regulations for land disposal of low level radioactive waste

(LLW).

" The 10 CFR 61 Performance Objectives detail the required criteria for low level

waste facilities with regards to protection of public heath and safety.

* Current low level radioactive waste land disposal facilities must meet the 10 CFR

61 Performance Objectives.

The fact that depleted uranium is classified as Class A waste only means that it is

eligible for near-surface land disposal, and not that near-surface disposal may be

appropriate for depleted uranium under all conditions. In order to dispose of

Class A waste, a particular near surface disposal facility receiving the waste must

currently meet the Performance Objectives and applicable technical standards in

10 CFR 61.

* In order to meet the Performance Objectives, analysis presumably must be

currently performed to ensure that from both an incremental receipt shipment

contribution and cumulative facility perspective, the Performance Objectives

remain satisfied.

* Most of the technical issues discussed in the Federal Register Notice (74 Fed.

Reg. 30175 (June 24, 2009)) could be addressed in an NRC guidance document

and does not require rulemaking for implementation. This guidance approach

would also allow the NRC more flexibility to adjust the guidance as new waste

streams or new waste processing and disposal techniques arise without new

rulemaking to implement rule revisions.

* An enhanced regulatory guidance document for Performance Objective

compliance assurance for low level radioactive waste facilities may be valuable to

the stakeholders. This could include scoping and assessment guidance for

important attributes, such as climatic, hydrological, geotechnical and geochemical

conditions regarding waste stream disposal and provide for a common and

systematic assessment process.

Rulemaking 

LES believes there is no need for additional rulemaking, even limited rulemaking, to 

address the issue of site-specific analysis for waste streams at present or for future 

waste streams for the following reasons: 

• Rulemaking is not required as current regulations include appropriate 

Performance Objectives for maintaining public health and safety 

• The Performance Objectives in 10 CFR 61, Subpart C identify current compliance 

requirements with regulations for land disposal of low level radioactive waste 

(LLW). 

• The 10 CFR 61 Performance Objectives detail the required criteria for low level 

waste facilities with regards to protection of public heath and safety. 

• Current low level radioactive waste land disposal facilities must meet the 10 CFR 

61 Performance Objectives. 

• The fact that depleted uranium is classified as Class A waste only means that it is 

eligible for near-surface land disposal, and not that near-surface disposal may be 

appropriate for depleted uranium under all conditions. In order to dispose of 

Class A waste, a particular near surface disposal facility receiving the waste must 

currently meet the Performance Objectives and applicable technical standards in 

10 CFR 61. 

• In order to meet the Performance Objectives, analysis presumably must be 

currently performed to ensure that from both an incremental receipt shipment 

contribution and cumulative facility perspective, the Performance Objectives 

remain satisfied. 

• Most ofthe technical issues discussed in the Federal Register Notice (74 Fed. 

Reg. 30175 (June 24, 2009)) could be addressed in an NRC guidance document 

and does not require rulemaking for implementation. This guidance approach 

would also allow the NRC more flexibility to adjust the guidance as new waste 

streams or new waste processing and disposal techniques arise without new 

rulemaking to implement rule revisions. 

• An enhanced regulatory guidance document for Performance Objective 

compliance assurance for low level radioactive waste facilities may be valuable to 

the stakeholders. This could include scoping and assessment guidance for 

important attributes, such as climatic, hydrological, geotechnical and geochemical 

conditions regarding waste stream disposal and provide for a common and 

systematic assessment process. 
" Bounding analyses could also be conducted for different applications and then

applied to any particular set of circumstances, in a manner similar to a previously

approved Generic/Programmatic Environmental Impact Statements. These

scoping and analytical techniques can also be provided in a regulatory guidance

document.

* Agreement States that are likely to receive depleted uranium as a low level

radioactive waste, such as Utah and Texas, currently have the statutory and

regulatory authority necessary to require additional analyses of depleted uranium

waste streams to ensure public health and safety and protection of the

environment.

* Additionally, prior to allowing a local licensed disposal site to accept depleted

uranium, the State of Utah presumably determined that disposing of depleted

uranium at the local licensed LLW disposal site met the Performance Objectives

of 10 CFR 61. Further, the Utah Division of Radiological Control has not placed

volume restrictions on the disposal of significant quantities of depleted uranium in

oxide form (depleted U30 8) at the local licensed LLW disposal facility.

Cost-Benefit Analysis and Backfittin2

LES believes this proposed rulemaking cannot occur in a vacuum. Cost-benefit

analysis must be included as an integral part of rulemaking and is currently not

addressed in this proposed rulemaking:

" Depleted uranium disposal costs are important financial variables in business

modeling for uranium enrichment companies.

" Depleted uranium disposal costs are factored into decommissioning cost estimates

and are translated into the decommissioning funding instruments required by

regulations.

" Additional costs to uranium enrichment companies imposed by proposed

rulemaking outpuis must be considered relative to the analyzed benefit for those

increased costs.

* Cost-benefit analysis related to avoided radiation dose is not a novel concept as

cost-benefit models and equivalent dose cost assignments are currently prescribed

for nuclear reactor radioactive waste management systems and equipment. In 10

CFR 50 Appendix I, cost-benefit analyses are performed for liquid and gaseous

radioactive waste systems for reactor plants to determine the cost and benefit of

additional radioactive waste processing equipment to compare dose reduction

with capital, operating and maintenance costs. An assignment of $1000 per total

body man-rem and $1000 per man-thyroid-rem is used in the analysis. The

proposed rulemaking should require similar analysis to assess the cost and benefit

• Bounding analyses could also be conducted for different applications and then 

applied to any particular set of circumstances, in a manner similar to a previously 

approved Generic/Programmatic Environmental Impact Statements. These 

scoping and analytical techniques can also be provided in a regulatory guidance 

document. 

• Agreement States that are likely to receive depleted uranium as a low level 

radioactive waste, such as Utah and Texas, currently have the statutory and 

regulatory authority necessary to require additional analyses of depleted uranium 

waste streams to ensure public health and safety and protection of the 

environment. 

• Additionally, prior to allowing a local licensed disposal site to accept depleted 

uranium, the State of Utah presumably determined that disposing of depleted· 

uranium at the local licensed LL W disposal site met the Performance Objectives 

of 10 CFR 61. Further, the Utah Division of Radiological Control has not placed 

volume restrictions on the disposal of significant quantities of depleted uranium in 

oxide form (depleted U30S) at the local licensed LL W disposal facility. 

Cost-Benefit Analysis and Backfitting 

LES believes this proposed rulemaking cannot occur in a vacuum. Cost-benefit 

analysis must be included as an integral part of rulemaking and is currently not 

addressed in this proposed rulemaking: 

• Depleted uranium disposal costs are important financial variables in business 

modeling for uranium enrichment companies. 

• Depleted uranium disposal costs are factored into decommissioning cost estimates 

and are translated into the decommissioning funding instruments required by 

regulations. 

• Additional costs to uranium enrichment companies imposed by proposed 

rulemaking outputs must be considered relative to the analyzed benefit for those 

increased costs. 

• Cost-benefit analysis related to avoided radiation dose is not a novel concept as 

cost-benefit models and equivalent dose cost assignments are currently prescribed 

for nuclear reactor radioactive waste management systems and equipment. In 10 

CFR 50 Appendix I, cost-benefit analyses are performed for liquid and gaseous 

radioactive waste systems for reactor plants to determine the cost and benefit of 

additional radioactive waste processing equipment to compare dose reduction 

with capital, operating and maintenance costs. An assignment of $1000 per total 

body man-rem and $1000 per man-thyroid-rem is used in the analysis. The 

proposed rulemaking should require similar analysis to assess the cost and benefit 
of any potential for avoided dose with respect to any increase in disposal costs

and funding those costs through the decommissioning funding instruments.

Additionally, LES believes that a potential backfit issue exists with this proposed

rulemaking and the Materials License issued to LES under, among other parts of the

Code, 10 CFR 70.

* Any proposed new requirements for disposal of depleted uranium could raise a

backfitting issue, and the NRC may need to prepare a backfitting analysis meeting

the cost-benefit standards of 10 CFR 70.76.

* 10 CFR 70.76(a)(1) defines "backfitting" as "the modification of, or addition to,

systems, structures, or components of a facility; or to the procedures or

organization required to operate a facility; any of which may result from a new or

amended provision in the Commission rules or the imposition of a regulatory staff

position interpreting the Commission rules that is either new or different from a

previous NRC staff position."

* If the NRC imposes new requirements on the procedures by which licensed

uranium enrichment facilities can dispose of depleted uranium, then the new

requirements should invoke the backfitting rule and require the NRC to perform

the cost-benefit analysis described in the regulation to justify any new disposal

requirements.

General Comment Conclusions

" LES agrees that the characterization of depleted uranium, as defined in the current

regulatory structure, is correct and appropriate.

* LES also believes that the current regulatory framework is sufficiently robust to

not require additional rulemaking related to site-specific analysis for waste

streams. This is due to the fact the existing 10 CFR 61 Subpart C Performance

Objectives are, and will remain, the standard by which low level radioactive waste

facilities are licensed and operated. These Performance Objectives are currently

being satisfied through licensee assessment, thus making additional rulemaking

unwarranted.

* Agreement States most likely to receive the depleted uranium as a waste stream

currently have the authority to have site specific analysis performed and available

for review by regulatory authorities in order to protect public health and safety.

This eliminates the need for the proposed rulemaking suggested by the NRC.

" LES believes any proposed rulemaking effort must include a rigorous cost-benefit

analysis. There is precedent in 10 CFR 50, Appendix I for evaluating radioactive

waste systems and equipment against an avoided dose (which has been assigned a

of any potential for avoided dose with respect to any increase in disposal costs 

and funding those costs through the decommissioning funding instruments. 

Additionally, LES believes that a potential backfit issue exists with this proposed 

rulemaking and the Materials License issued to LES under, among other parts of the 

Code, 10 CFR 70. 

• Any proposed new requirements for disposal of depleted uranium could raise a 

backfitting issue, and the NRC may need to prepare a backfitting analysis meeting 

the cost-benefit standards of 10 CFR 70.76. 

• 10 CFR 70: 76( a) (1 ) defines "backfitting" as "the modification of, or addition to, 

systems, structures, or components of a facility; or to the procedures or 

organization required to operate a facility; any of which may result from a new or 

amended provision in the Commission rules or the imposition of a regulatory staff 

position interpreting the Commission rules that is either new or different from a 

previous NRC staff position." 

• If the NRC imposes new requirements on the procedures by which licensed 

uranium enrichment facilities can dispose of depleted uranium, then the new 

requirements should invoke the backfitting rule and require the NRC to perform 

the cost-benefit analysis described in the regulation to justify any new disposal 

requirements. 

General Comment Conclusions 

• LES agrees that the characterization of depleted uranium, as defined in the current 

regulatory structure, is correct and appropriate. 

• LES also believes that the current regulatory framework is sufficiently robust to 

not require additional rulemaking related to site-specific analysis for waste 

streams. This is due to the fact the existing 10 CFR 61 Subpart C Performance 

Objectives are, and will remain, the standard by which low level radioactive waste 

facilities are licensed and operated. These Performance Objectives are currently 

being satisfied through licensee assessment, thus making additional rulemaking 

unwarranted. 

• Agreement States most likely to receive the depleted uranium as a waste stream 

currently have the authority to have site specific analysis performed and available 

for review by regulatory authorities in order to protect public health and safety. 

This eliminates the need for the proposed rulemaking suggested by the NRC. 

• LES believes any proposed rulemaking effort must include a rigorous cost-benefit 

analysis. There is precedent in 10 CFR 50, Appendix I for evaluating radioactive 

waste systems and equipment against an avoided dose (which has been assigned a 
cost from a man-rem perspective) to determine if additional waste treatment

systems are warranted. Similar logic should prevail in this proposed rulemaking.

* LES believes this proposed rulemaking must be reviewed in light of backfit

regulations and provisions in 10 CFR 70.76. Potential changes to waste stream

disposal plans that can alter financial cost models for Material License holders

must be evaluated using backfit regulations in 10 CFR 70. Backfit evaluations

must be done in a clear, rigorous and repeatable fashion to ensure its credibility.

Any nexus to public health and safety, or protection of the environment, must be

clearly demonstrated.

cost from a man-rem perspective) to determine if additional waste treatment 

systems are warranted. Similar logic should prevail in this proposed rulemaking. 

• LES believes this proposed rulemaking must be reviewed in light of back fit 

regulations and provisions in 10 CFR 70.76. Potential changes to waste stream 

disposal plans that can alter financial cost models for Material License holders 

must be evaluated using backfit regulations in 10 CFR 70. Backfit evaluations 

must be done in a clear, rigorous and repeatable fashion to ensure its credibility. 

Any nexus to public health and safety, or protection of the environment, must be 

clearly demonstrated. 
FRN Question Comments

Issue 11-1, Definition of Unique Waste Streams

Question 11-1.1-Should the NRC propose a regulatory definition to

(a) specify general criteria that would capture both current and foreseeable unique waste

streams; or

(b) limit the definition to a known set of current unique waste streams including

significant quantities of depleted uranium? What characteristics should NRC propose as

defining for unique waste streams?

LES Response:

LES does not believe it practical or prudent to attempt to define unique waste streams at

present or for the foreseeable future. Attempts at identifying future unique waste streams

will, at best, be speculative. LES supports a performance-based approach to waste

streams by utilizing existing performance objectives to make determinations for

regulatory compliance regarding disposal.

Question 11-1.2-What waste streams containing radionuclides listed in the waste

classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable future,

being disposed of in quantities significantly greater than initially considered in the

development of 10 CFR Part 61?

LES Response:

LES can provide no information regarding specific waste streams and potential increases

in disposal quantities for those radionuclides listed in the waste classification tables in 10

CFR 61.55.

Question 11-1.3-What waste streams containing radionuclides that are not listed in the

waste classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable

future, being disposed of in concentrations or quantities significantly greater than

initially considered in the development of 10 CFR Part 61?

LES Response:

LES believes that there are no additional radionuclides that were not previously

considered initially in the development of 10 CFR Part 61. LES believes that uranium

(depleted uranium) was appropriately considered initially and the characterization of

depleted uranium remains valid.

Question 11-1.4-What waste streams that were not considered in the initial

development of 10 CFR Part 61 should be considered under the definition of "unique

waste streams"?

FRN Question Comments 

Issue II-I, Definition of Unique Waste Streams 

Question 1I-1.l-Should the NRC propose a regulatory definition to 

(a) specify general criteria that would capture both current and foreseeable unique waste 

streams; or 

(b) limit the definition to a known set of current unique waste streams including 

significant quantities of depleted uranium? What characteristics should NRC propose as 

defining for unique waste streams? 

LES Response: 

LES does not believe it practical or prudent to attempt to define unique waste streams at 

present or for the foreseeable future. Attempts at identifying future unique waste streams 

will, at best, be speculative. LES supports a performance-based approach to waste 

streams by utilizing existing performance objectives to make determinations for 

regulatory compliance regarding disposal. 

Question 1I-1.2-What waste streams containing radionuclides listed in the waste 

classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable future, 

being disposed of in quantities significantly greater than initially considered in the 

development of 10 CFR Part 61 ? ' 

LES Response: 

LES can provide no information regarding specific waste streams and potential increases 

in disposal quantities for those radionuclides listed in the waste classification tables in 10 

CFR 61.55. ' , 

Question 1I-1.3-What waste streams containing radionuclides that are not listed in the 

waste classification tables at 10 CFR 61.55 are currently, or possibly in the foreseeable 

future, being disposed of in concentrations or quantities significantly greater than 

initially considered in the development of 10 CFR Part 61 ? 

LES Response: 

LES believes that there are no additional radionuclides that were not previously 

considered 'initially in the development of 10 CFR Part 61. LES believes that uranium , 

(depleted uranium) was appropriately considered initially and the characterization of 

depleted uranium remains valid. 

Question lI-l.4-What waste streams that were not considered in the initial 

development of 10 CFR Part 61 should be considered under the definition of' 'unique 

waste streams"? 
LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.

Question TI-1.5-Should the NRC consider waste streams that result from spent fuel

reprocessing and are not high-level or greater-than-class C waste in the definition of "unique waste streams"?

LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.

Question II-1.6---Are there other characteristics besides concentration and quantity that

NRC should consider when defining "unique waste streams"?

LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams. 

Question II-loS-Should the NRC consider waste streams that result from spent fuel 

reprocessing and are not high-level or greater-than-class C waste in the definition of 

"unique waste streams"? 

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams. 

Question II-l.~Are there other characteristics besides concentration and quantity that 

NRC should consider when defining "unique waste streams"? 

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams. 
Issue 11-2, Time Period of Performance

Question 11-2.1-Should the NRC

(a) specify a single time period to evaluate the performance of facilities disposing of all

unique waste streams in the near-surface;

(b) specify criteria requiring the consideration of how the hazard for each unique waste

stream evolves over time; or

(c) permit a licensee to justify a period of performance?

LES Response:

With the number of relevant variables needing to be considered for each licensee, LES

believes NRC should not attempt to specify a single time period for performance of

facilities. NRC and the industry should identify the criteria for evaluating the time period

of performance in a regulatory guidance document and allow licensees to implement the

criteria on a site-specific basis.

Question 11-2.2-If NRC were to specify a single time period for site specific analysis

of facilities disposing of unique waste streams in the near-surface, what would be an

appropriate period? What factors should NRC consider in determining a single time

period of performance?

LES Response:

As stated above, LES believes NRC should not attempt to specify a single time period for

performance of facilities.

Question 11-2.3-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time for each unique waste stream, what factors should NRC

consider in determining these criteria?

LES Response:

As stated above, LES believes NRC should not attempt to specify a single time period for

performance of facilities.

LES believes, however, that NRC should utilize and implement currently existing

regulations and standards that have been created for the uranium milling industry and

embodied in 40 CFR 192, Health and Environmental Protection Standards for Uranium

and Thorium Mill Tailings. These regulations provide limits and performance time

periods for uranium and thorium mill tailings. NRC staff is encouraged to utilize these

Issue 11-2, Time Period of Performance 

Question 11-2.1-Should the NRC 

(a) specify a single time period to evaluate the performance of facilities disposing of all 

unique waste streams in the near-surface; 

(b) specify criteria requiring the consideration of how the hazard for each unique waste 

stream evolves over time; or 

(c) permit a licensee to justify a period of performance? 

LES Response: 

With the number of relevant variables needing to be considered for each licensee, LES 

believes NRC should not attempt to specify a single time period for performance of 

facilities. NRC and the industry should identify the criteria for evaluating the time period 

of performance in a regulatory guidance document and allow licensees to implement the 

criteria on a site':'specific basis. 

Question 11-2.2-IfNRC were to specify a single time period for site specific analysis 

of facilities disposing of unique waste streams in the near-surface, what would be an 

appropriate period? What factors should NRC consider in determining a single time 

period of performance? 

LES Response: 

As stated above, LES believes NRC should not attempt to specify a single time period for 

performance of facilities. 

Question 11-2.3-IfNRC were to specify criteria requiring the consideration of how the 

hazard evolves over time for each unique waste stream, what factors should NRC 

consider in determining these criteria? 

LES Response: 

As stated above, LES believes NRC should not attempt to specify a single time period for 

performance of facilities. 

LES believes, however, that NRC should utilize and implement currently existing 

regulations and standards that have been created for the uranium milling industry and 

embodied in 40 CFR 192, Health and Environmental Protection Standards for Uranium 

and Thorium Mill Tailings. These regulations provide limits and performance time 

periods for uranium and thorium mill tailings. NRC staff is encouraged to utilize these 
standards rather than create new ones with the possibility of introducing inconsistencies

between different industry regulations for similar issues.

Question 11-2.4-If NRC were to permit a licensee to justify a time period

of performance, what factors should NRC consider when evaluating a licensee's

justification?

LES Response:

As stated above, LES believes that NRC should utilize and implement currently existing

regulations and standards that have been created for the uranium milling industry and

embodied in 40 CFR 192.

Question 11-2.5-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time, or permit a licensee to justify a time period of performance,

should the NRC consider limiting the maximum extent of the time period considered? If

so, what factors should NRC consider when specifying a maximum period of

performance?

LES Response:

LES believes that placing a limit to the maximum extent of the time period of

performance for a licensee would be arbitrary and may have unintended consequences.

Unless there is a rigorous process that both NRC and industry can endorse for

determining a period of performance, such an arbitrary time limit may modify existing

licenses and may impact types and amounts of acceptable waste at currently-licensed

facilities. This impact can translate into additional transportation distances and time for

radioactive waste to be shipped to the ultimate disposal site, which may actually increase

hazards to the public.

As stated above, LES believes that NRC should utilize and implement currently existing

regulations and standards that have been created for the uranium milling industry and

embodied in 40 CFR 192.

Question 11-2.6-What other approaches might NRC consider when specifying criteria

for a period of performance for facilities disposing of unique waste streams in the nearsurface?

LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.

standards rather than create new ones with the possibility of introducing inconsistencies 

between different industry regulations for similar issues. 

Question II-2.4-IfNRC were to permit a licensee to justify a time period 

of performance, what factors should NRC consider when evaluating a licensee's 

justification? 

LES Response: 

As stated above, LES believes that NRC should utilize and implement currently existing 

regulations and standards that have been created for the uranium milling industry and 

embodied in 40 CFR 192. ' 

Question II-2.S-IfNRC were to specify criteria requiring the consideration of how the 

hazard evolves over time, or permit a licensee to justify a time period of performance, 

should the NRC consider limiting the maximum extent of the time period considered? If 

so, what factors should NRC consider when specifying a maximum period of 

performance? 

LES Response: 

LES believes that placing a limit to the maximum extent of the time period of 

performance for a licensee would be arbitrary and may have unintended consequences. 

Unless there is a rigorous process that both NRC and industry can endorse for 

determining a period of performance, such an arbitrary time limit may modify existing 

licenses and may impact types and amounts of acceptable waste at currently-licensed 

facilities. This impact can translate into additional transportation distances and time for 

radioactive waste to be shipped to the ultimate disposal site, which may actually increase 

hazards to the public. 

As stated above, LES believes that NRC should utilize and implement currently existing 

regulations and standards that have been created for the uranium milling industry and 

embodied in 40 CFR 192. 

Question II-2.6-What other approaches might NRC consider when specifying criteria 

for a period of performance for facilities disposing of unique waste streams in the nearsurface? 

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams. 
As stated above, LES believes that NRC should utilize and implement currently existing

regulations and standards that have been created for the uranium milling industry and

embodied in 40 CFR 192.

Issue 11-3, Exposure Scenarios for Site-Specific Analysis

Question 11-3.1-Should NRC specify technical criteria for, or permit licensees to

justify, site-specific exposure scenarios for demonstrating compliance with the

performance objective protecting members of the public for unique waste streams? What

factors should NRC consider in specifying technical criteria or reviewing licensee

justifications for exposure scenarios associated with members of the public?

LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.

As stated above, LES believes that NRC should utilize and implement currently existing

regulations and standards that have been created for the uranium milling industry and

embodied in 40 CFR 192.

Question 11-3.2-Should NRC specify technical criteria for, or permit licensees to

justify, site-specific exposure scenarios for demonstrating compliance with the

performance objective protecting individuals from inadvertent intrusion for unique waste

streams? What factors should NRC consider in specifying technical criteria, or reviewing

licensee justifications, for inadvertent intruder exposure scenarios?

LES Response:

As stated above, LES does not believe it practical or prudent to attempt to define unique

waste streams.,

LES believes that with the uncertainty associated with future activities at a particular site,

NRC staff should consider providing guidance for inadvertent intruder exposure

scenarios. This guidance should provide intruder scenario bounding criteria for

consideration in a manner similar to the "design basis threat" concept utilized in security

planning. Absent a bounding set of criteria, numerous different scenarios can be

reasonably postulated thus requiring a reactive posture by a licensee or prospective

licensee. This lack of regulatory predictability can result in increased costs to waste

disposers.

As stated above, LES believes that NRC should utilize and implement currently existing 

regulations and standards that have been created for the uranium milling industry and 

embodied in 40 CFR 192. 

Issue 11-3, Exposure Scenarios for Site-Specific Analysis 

Question 11-3.1-Should NRC specify technical criteria for, or permit licensees to 

justify, site-specific exposure scenarios for demonstrating compliance with the 

performance objective protecting members of the public for unique waste streams? What 

factors should NRC consider in specifying technical criteria or reviewing licensee 

justifications for exposure scenarios associated with members of the public? 

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams. 

As stated above, LES believes that NRC should utilize and implement currently existing 

regulations and standards that have been created for the uranium milling industry and 

embodied in 40 CFR 192. 

Question 11-3.2-Should NRC specify technical criteria for, or permit licensees to 

justify, site-specific exposure scenarios for demonstrating compliance with the 

performance objective protecting individuals from inadvertent intrusion for unique waste 

streams? What factors should NRC consider in specifying technical criteria, or reviewing 

licensee justifications, for inadvertent intruder exposure scenarios? 

LES Response: 

As stated above, LES does not believe it practical or prudent to attempt to define unique 

waste streams.' 

LES believes that with the uncertainty associated with future activities at a particular site, 

NRC staff should .consider providing guidance for inadvertent intruder exposure 

scenarios. This guidance should provide intruder scenario bounding criteria for 

consideration in a manner similar to the "design basis threat" concept utilized in security 

planning. Absent a bounding set of criteria, numerous different scenarios can be 

reasonably postulated thus requiring a reactive posture by a licensee or prospective 

licensee. This lack of regulatory predictability can result in increased costs to waste 

disposers. 
Issue 111-1. Definition of Significant Quantities

Question 111-1.1-Should NRC specify a lower quantity limit in the definition of

"significant quantities" for near-surface disposal? If so, what factors should NRC

consider in setting an appropriate lower threshold for near-surface disposal?

LES Response:

LES believes that the language involving "significant quantities" should be discontinued.

NRC staff has not provided a proposed definition of the term, which leaves it open for

interpretation. Previous industry experience with ambiguous regulatory language has

resulted in numerous interpretations, confusion and a lack of consistent implementation.

This lack of specificity should not be re-introduced into the regulatory framework though

this process.

LES believes utilization of the term "significant quantities" without a specific definition

or criteria will introduce additional uncertainty and unpredictability into the regulatory

process and should be avoided. Regulatory uncertainty and unpredictability may

introduce additional costs for disposers.

Question 111-1.2-Should NRC specify an upper quantity limit in the definition of "significant quantities"? If so, what factors should NRC consider in setting an

appropriate upper threshold for near-surface disposal?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process

Question 111-1.3-Are there alternative methods NRC should consider when specifying

criteria to define "significant quantities"?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process

LES believes that, irrespective of "significant quantities" from this discussion, the

prevailing considerations for disposal are the particular low level radioactive waste

disposal site license conditions and the Performance Objectives of 10 CFR 61. By

compliance with the particular low level radioactive waste disposal site license conditions

Issue 111-1, Definition of Significant Quantities 

Question III-lol-Should NRC specify a lower quantity limit in the definition of 

"significant quantities" for near-surface disposal? If so, what factors should NRC 

consider in setting an appropriate lower threshold for near-surface disposal? 

LES Response: 

LES believes that the language involving "significant quantities" should be discontinued. 

NRC staff has not provided a proposed definition of the term, which leaves it open for 

interpretation. Previous industry experience with ambiguous regulatory language has 

resulted in numerous interpretations, confusion and a lack of consistent implementation. 

This lack of specificity should not be re-introduced into the regulatory framework though 

this process. 

LES believes utilization of the term "significant quantities" without a specific definition 

or criteria will introduce additional uncertainty and unpredictability into the regulatory 

process and should be avoided. Regulatory uncertainty and unpredictability may 

introduce additional costs for disposers. 

Question III-l.2-Should NRC specify an upper quantity limit in the definition of 

"significant quantities"? If so, what factors should NRC consider in setting an 

appropriate upper threshold for near-surface disposal? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process 

Question 1I1-1.3-Are there alternative methods NRC should consider when specifying 

criteria to define" significant quantities"? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process 

LES believes that, irrespective of "significant quantities" from this discussion, the 

prevailing considerations for disposal are the particular low level radioactive waste 

disposal site license conditions and the Performance Objectives of 10 CFR 61. By 

compliance with the particular low level radioactive waste disposal site license conditions 
and Performance Objectives, "significant quantities" need not exist in this regulatory

structure.

and Performance Objectives, "significant quantities" need not exist in this regulatory 

structure. 
Issue 111-2, Time Period of Performance for a Site-Specific Analysis

Question 111-2.1-If NRC were to specify a single time period for the site specific

analysis of near-surface disposal of unique waste streams (see Question 11.2.1), what

factors associated with disposal of significant quantities of depleted uranium should NRC

consider in determining a single time period of performance for unique waste streams,

including significant quantities of depleted uranium?

LES Response:

With the number of relevant variables needing to be considered for each licensee, LES

believes NRC should not attempt to specify a single time period for performance of

facilities. NRC and the industry should identify the criteria for evaluating the time period

of performance in a regulatory guidance document and allow licensees to implement the

criteria on a site-specific basis.

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61

Question 111-2.2-If NRC were to specify criteria requiring the consideration of hazards

for each unique waste stream evolving over time (see Question 11.2.1), what factors

should NRC consider in determining these criteria for disposal of significant quantities of

depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

Question 111-2.3-If NRC were to permit a licensee to justify a time period of

performance (see Question 11.2.1), what factors should NRC consider when evaluating a

licensee's justification for disposal of significant quantities of depleted uranium?

Issue 111-2, Time .Period of Performance for a Site-Specific Analysis 

Question 111-2. I-If NRC were to specify a single time period for the site specific 

analysis of near-surface disposal of unique waste streams (see Question H.2.1), what 

factors associated with disposal of significant quantities of depleted uranium should NRC 

consider in determining a single time period of performance for unique waste streams, 

including significant quantities of depleted uranium? 

LES Response: 

With the number of relevant variables needing to be considered for each licensee, LES 

believes NRC should not attempt to specify a single time period for performance of 

facilities. NRC and the industry should identify the criteria for evaluating the time period 

of performance in a regulatory guidance document and allow licensees to implement the 

criteria on a site-specific basis. 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61 

Question 11I-2.2-IfNRC were to specify criteria requiring the consideration of hazards 

for each unique waste stream evolving over time (see Question H.2.1), what factors 

should NRC consider in determining these criteria for disposal of significant quantities of 

depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

Question 1II-2.3-IfNRC were to permit a licensee to justify a time period of 

performance (see Question H.2.1), what factors should NRC consider when evaluating a 

licensee's justification for disposal of significant quantities of depleted uranium? 
LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

Question 111-2.4-If NRC were to specify criteria requiring the consideration of how the

hazard evolves over time, or permit a licensee to justify a reasonable time period of

performance (see Question 11-2.1), should the NRC consider limiting the maximum

extent of the time period considered for disposal of significant quantities of depleted

uranium? If so, what factors should NRC consider when specifying a maximum period of

performance?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

Question 111-2.5-What other approaches might NRC consider when specifying criteria

for a period of performance for near-surface disposal of significant quantities of depleted

uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

Question III-2.4-IfNRC were to specify criteria requiring the consideration of how the 

hazard evolves over time, or permit a licensee to justify a reasonable time period of 

performance (see Question 11-2.1), should the NRC consider limiting the maximum 

extent of the time period considered for disposal of significant quantities of depleted 

uranium? If so, what factors should NRC consider when specifying a maximum period of 

performance? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

Question III-2.S-What other approaches might NRC consider when specifying criteria 

for a period of performance for near-surface disposal of significant quantities of depleted 

uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 
Issue 111-3, Exposure Scenario(s) for a Site-Specific Analysis

Question 111-3.1-What factors specific to disposal of significant quantities of depleted

uranium should NRC consider in specifying criteria or reviewing a licensee's justification

for exposure scenarios for protection of members of the public?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

Question III-3.2--What factors specific to disposal of significant quantities of depleted

uranium should NRC consider in specifying criteria or reviewing a licensee's justification

for exposure scenarios for the protection of individuals from inadvertent intrusion?

LES Response:

LES believes that with the uncertainty associated with future activities at a particular site,

NRC staff should consider providing guidance for inadvertent intruder exposure

scenarios. This guidance should provide intruder scenario bounding criteria for

consideration in a manner similar to the "design basis threat" concept utilized in security

planning. Absence of a bounding set of criteria, numerous different scenarios can be

reasonably postulated thus requiring a reactive posture by a licensee or prospective

licensee. This lack of regulatory predictability can result in increased costs to waste

disposers.

Issue 111-3, Exposure Scenario(s) for a Site-Specific Analysis 

Question 111-3.1-What factors specific to disposal of significant quantities of depleted 

uranium should NRC consider in specifying criteria or reviewing a licensee's justification 

for exposure scenarios for protection of members of the public? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 6l. 

Question 111-3.2-What factors specific to disposal of significant quantities of depleted 

uranium should NRC consider in specifying criteria or reviewing a licensee's justification 

for exposure scenarios for the protection of individuals from inadvertent intrusion? 

LES Response: 

LES believes that with the uncertainty associated with future activities at a particular site, 

NRC staff should consider providing guidance for inadvertent intruder exposure 

scenarios. This guidance should provide intruder scenario bounding criteria for 

consideration in a manner similar to the "design basis threat" concept utilized in security 

planning. Absence of a bounding set of criteria, numerous different scenarios can be 

reasonably postulated thus requiring a reactive posture by a licensee or prospective 

licensee. This lack of regulatory predictability can result in increased costs to waste 

disposers. 
Issue 111-4, Source Term Issues for a Site-Specific Analysis

Question 111-4.1-Should NRC specify or permit licensees to propose physical or

chemical forms (e.g., UF6, U308, metal) for disposal of significant quantities of depleted

uranium? If so, what factors should NRC consider in specifying criteria for or developing

guidance to review an analysis of physical or chemical forms?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

LES believes the NRC should not be prescriptive when discussing physical or chemical

forms for disposal of depleted uranium, regardless of amount or volume. To do so may

unnecessarily limit implementation of advances in technology that may define a more

suitable physical and/or chemical form for depleted uranium in the future. Producers of

depleted uranium may have ability under their Materials License to de-convert depleted

uranium hexafluoride (DUF6) into a variety of chemical or physical forms, such as

depleted uranium dioxide (DUO2), depleted triuranium octaoxide (DU30 8 ), or depleted

uranium tetraflouride (DUF 4). Technology and business financial models used by

uranium enrichment companies employ assumptions for DUF 6 de-conversion and

disposal and prescriptive positions taken by NRC for ultimate waste disposal forms may

not be consistent with those models.

LES believes that Materials Licensees are in the better position to determine the ultimate

waste form, based on maintaining compliance with the 10 CFR 61 Performance

Objectives, business financial modeling and available technology at the time when the

licensee declares the DUF6 no longer a resource and treats the DUF6 as a Class A low

level radioactive waste.

Question 111-4.2--Should NRC specify criteria for, or permit licensees to justify,

stabilizing admixtures (e.g., grout) for disposal of significant quantities of depleted

uranium? If so, what factors should NRC consider in specifying criteria for, or

developing guidance to review, an analysis of admixtures?

LES Response:

Issue 111-4, Source Term Issues for a Site-Specific Analysis 

Question 111-4.1-Should NRC specify or peImit licensees to propose physical or 

chemical fOIms (e.g., UF6, U308, metal) for disposal of significant quantities of depleted 

uranium? If so, what factors .should NRC consider in specifying criteria for or developing 

guidance to review an analysis of physical or chemical fOIms? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this teIm will 

introduce additional uncertaiIlty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

LES believes the NRC should not be prescriptive when discussing physical or chemical 

fOIms for disposal of depleted uranium, regardless of amount or volume. To do so may 

unnecessarily limit implementation of advances in technology that may define a more 

suitable physical and/or chemical fOIm for depleted uranium in the future. Producers of 

depleted uranium may have ability under their Materials License to de-convert depleted 

uranium hexafluoride (DUF6) into a variety of chemical or physical fOIms, such as 

depleted uranium dioxide (DU02), depleted triuranium octaoxide (DU308), or depleted 

uranium tetraflouride (DUF4). Technology and business financial models used by 

uranium enrichment companies employ assumptions for DUF6 de-conversion and 

disposal and prescriptive positions taken by NRC for ultimate waste disposal fOIms may 

not be consistent with those models. 

LES believes that Materials Licensees are in the better position to deteImine the ultimate 

waste fOIm, based on maintaining compliance with the 10 CFR 61 PerfoImance 

Objectives, business financial modeling and available technology at the time when the 

licensee declares the DUF6 no longer a resource and treats the DUF6 as a Class A low 

level radioactive waste. 

Question 11I-4.2-Should NRC specify criteria for, or peImit licensees to justify, 

stabilizing admixtures (e.g., grout) for disposal of significant quantities of depleted 

uranium? If so, what factors should NRC consider in specifying criteria for, or 

developing guidance to review, an analysis of admixtures? 

LES Response: 
As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that the NRC should not be prescriptive in specifying

stabilizing admixtures criteria for any amount of depleted uranium, but should provide

regulatory guidance to the industry, however, not in the form of rulemaking.

Question 111-4.3-What other factors should NRC consider when specifying criteria, or

developing technical guidance, regarding waste forms for disposal of significant

quantities of depleted uranium in near-surface facilities?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that the NRC should not be prescriptive in specifying

stabilizing admixtures criteria for any amount of depleted uranium, but should provide

regulatory guidance to the industry, however, not in the form of rulemaking.

Question 111-4.4-Should NRC require a site-specific analysis to capture previously

disposed quantities of depleted uranium? If so, what factors should NRC consider when

specifying criteria, or developing technical guidance, regarding previously disposed

quantities of depleted uranium?

LES Response:

LES believes that NRC should not require any site-specific analysis for previously

disposed quantities of depleted uranium without performing both a cost-benefit analysis

and backfitting evaluation to determine the impacts of such an analysis.

LES has no indication that previously disposed quantities of depleted uranium were not

in compliance with all applicable laws, regulations, license conditions and 10 CFR 61

Performance Objectives. Therefore, any additional analysis is beyond the scope of

existing regulations with a backfit evaluation.

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that the NRC should not be prescriptive in specifying 

stabilizing admixtures criteria for any amount of depleted uranium, but should provide 

regulatory guidance to the industry, however, not in the form of rulemaking. 

Question 111-4.3-, What other factors should NRC consider when specifying criteria; or 

developing technical guidance, regarding waste forms for disposal of significant 

quantities of depleted uranium in near-surface facilities? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that the NRC should not be prescriptive in specifying 

stabilizing admixtures criteria for any amount of depleted uranium, but should provide 

regulatory guidance to the industry, however, not in the form of rulemaking. 

Question 111-4.4-Should NRC require a site-specific analysis to capture previously 

disposed quantities of depleted uranium? If so, what factors should NRC consider when 

specifying criteria, or developing technical guidance, regarding previously disposed 

quantities of depleted uranium? 

LES Response: 

LES believes that NRC should not require any site-specific analysis for previously 

disposed quantities of depleted uranium without performing both a cost-benefit analysis 

and backfitting evaluation to determine the impacts of such an analysis. 

LES has no indication that previously disposed quantities of depleted uranium were not 

in compliance with all applicable laws, regulations, license conditions and 10 CFR 61 

Performance Objectives. Therefore, any additional analysis is beyond the scope of 

existing regulations with a backfit evaluation. 
LES believes that requiring a site-specific analysis to capture previously disposed

quantities of depleted uranium without the cost-benefit and backfitting analysis can

undermine the argument of regulatory consistency and predictability for all stakeholders.

LES believes that requiring a site-specific analysis to capture previously disposed 

quantities of depleted uranium without the cost-benefit and backfitting analysis can 

undermine the argument of regulatory consistency and predictability for all stakeholders. 
Issue 111-5, Modeling of Uranium Geochemistry in a Site-Specific Analysis

Question 111-5.1-Should NRC specify regulatory criteria for, or permit licensees to

justify, site-specific geochemical parameters for the analysis of disposal of significant

quantities of depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

LES believes that no additional regulatory criteria need be established for evaluating

geochemical parameters for disposal of any amount of depleted uranium. If

characterization of site-specific geochemical parameters is considered relevant to low

level waste disposal facilities, then the requirement to perform the analysis should be

embodied within the regulations for the initial licensing of a low level waste facility for

all radionuclides and not be introduced as a requirement solely due to depleted uranium

disposal, regardless of amount or volume of depleted uranium disposal.

LES believes that requiring a site-specific geochemical parameter analysis without the

cost-benefit and backfitting analysis can undermine the argument of regulatory

consistency and predictability for all stakeholders.

Question 111-5.2-If NRC should specify regulatory criteria, then what factors should

NRC consider in developing criteria for geochemical parameters for a site-specific

analysis for disposal of significant quantities of depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that no additional regulatory criteria need be established

for evaluating geochemical parameters for disposal of any amount of depleted uranium.

Issue 111-5, Modeling of Uranium Geochemistry in a Site-Specific Analysis 

Question III-S.l-Shouid NRC specify regulatory criteria for, or pennit licensees to 

justify, site-specific geochemical parameters for the analysis of disposal of significant 

quantities of depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use ofthis tenn will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Perfonnance Obj ectives of 10 CFR 61. 

LES believes that no additional regulatory criteria need be established for evaluating 

geochemical parameters for disposal of any amount of depleted uranium. If 

characterization of site-specific geochemical parameters is considered relevant to low 

level waste disposal facilities, then the requirement to perfonn the analysis should be 

embodied within the regulations for the initial licensing of a low level waste facility for 

all radionuc1ides and not be introduced as a requirement solely due to depleted uranium 

disposal, regardless of amount or volume of depleted uranium disposal. 

LES believes that requiring a site-specific geochemical parameter analysis without the 

cost-benefit and backfitting analysis can undennine the argument of regulatory 

consistency and predictability for all stakeholders. 

Question ill-S.2-IfNRC should specify regulatory criteria, then what factors should 

NRC consider in developing criteria for geochemical parameters for a site-specific 

analysis for disposal of significant quantities of depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this tenn will 

introduce additional uncertainty and ~npredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Perfonnance Objectives of 10 CFR 61. 

As stated above, LES believes that no additional regulatory criteria need be established 

for evaluating geochemical parameters for disposal of any amount of depleted uranium. 
LES believes that requiring a site-specific geochemical parameter analysis without the

cost-benefit and backfitting analysis can undermine the argument of regulatory

consistency and predictability for all stakeholders.

Question 111-5.3-If NRC should permit licensees to justify site-specific geochemical

parameters, then what factors should NRC consider when reviewing a licensee's

justification?

LES Response:

As stated above, LES believes that no additional regulatory criteria need be established

for evaluating geochemical parameters for disposal of any amount of depleted uranium.

LES believes that requiring a site-specific geochemical parameter analysis without the

cost-benefit and backfitting analysis can undermine the argument of regulatory

consistency and predictability for all stakeholders.

Question 111-5.4-What new or alternative approaches should NRC consider regarding

the incorporation of geochemical parameters in a site specific analysis for disposal of

significant quantities of depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that no additional regulatory criteria need be established

for evaluating geochemical parameters for disposal of any amount of depleted uranium.

LES believes that requiring a site-specific geochemical parameter analysis without the

cost-benefit and backfitting analysis can undermine the argument of regulatory

consistency and predictability for all stakeholders.

LES believes that requiring a site-specific geochemical parameter analysis without the 

cost-benefit and backfitting analysis can undermine the argument of regulatory 

consistency and predictability for all stakeholders. 

Question III-S.3-IfNRC should permit licensees to justify site-specific geochemical 

parameters, then what factors should NRC consider when reviewing a licensee's 

justification? 

LES Response: 

As stated above, LES believes that no additional regulatory criteria need be established 

for evaluating geochemical parameters for disposal of any amount of depleted uranium. 

LES believes that requiring a site-specific geochemical parameter analysis without the 

cost-benefit and backfitting analysis can undermine the argument of regulatory 

consistency and predictability for all stakeholders. 

Question III-S.4-What new or alternative approaches should NRC consider regarding 

the incorporation of geochemical parameters in a site specific analysis for disposal of 

significant quantities of depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that no additional regulatory criteria need be established 

for evaluating geochemical parameters for disposal of any amount of depleted uranium. 

LES believes that requiring a site-specific geochemical parameter analysis without the 

cost-benefit and backfitting analysis can undermine the argument of regulatory 

consistency and predictability for all stakeholders. 

I 

\, 
Issue 111-6, Modeling of Radon in the Environment in a Site-Specific Analysis

Question 111-6.1-What new approaches for modeling radon emanation, migration, and

exposure pathways, including the effects of differences in the physical and chemical

properties between radon and its progeny, should NRC consider?

LES Response:

LES believes that the techniques for modeling radon emanation, migration and exposure

pathways should be consistent with those previously endorsed by the U. S Environmental

Protection Agency and embodied in 40 CFR 192, Health and Environmental Protection

Standards for Uranium and Thorium Mill Tailings. Since evaluation and monitoring

techniques have been previously identified and embodied in Federal regulations, those

criteria should be adequate for depleted uranium applications, regardless of disposed

quantity or volume.

Question 111-6.2-Should NRC require licensees to evaluate the effects of radon in a

site-specific analysis for disposal of significant quantities of depleted uranium in nearsurface facilities?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

LES believes that the Performance Objectives in 10 CFR 61 should determine the types

of licensee evaluation and monitoring needed to ensure compliance. Prescriptive

identification of needed evaluations need not be identified in order for licensees to

maintain compliance with appropriate license conditions and Performance Objectives.

Question 111-6.3-Should NRC specify by regulation, or develop guidance on,

the technical parameters for evaluating radon emanation, migration, and exposure in a

site-specific analysis of significant quantities of depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Issue 111-6, Modeling of Radon in the Environment in a Site-Specific Analysis 

Question 111-6.1-What new approaches for modeling radon emanation, migration, and 

exposure pathways, including the effects of differences in the physical and chemical 

properties between radon and its progeny, should NRC consider? 

LES Response: 

LES believes that the techniques for modeling radon emanation, migration and exposure 

pathways should be consistent with those previously endorsed by the U. S Environmental 

Protection Agency and embodied in 40 CFR 192, Health and Environmental Protection 

Standards for Uranium and Thorium Mill Tailings. Since evaluation and monitoring 

techniques have been previously identified and embodied in Federal regulations, those 

criteria should be adequate for depleted uranium applications, regardless of disposed 

quantity or volume. . 

Question 111-6.2-Should NRC require licensees to evaluate the effects of radon in a 

site-specific analysis for disposal of significant quantities of depleted uranium in nearsurface facilities? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

LES believes that the Performance Objectives in 10 CFR 61 should determine the types 

of licensee evaluation and monitoring needed to ensure compliance. Prescriptive 

identification of needed evaluations need not be identified in order for licensees to 

maintaip compliance with appropriate license conditions and Performance Objectives. 

Question 111-6.3-Should NRC specify by regulation, or develop guidance on, 

the technical parameters for evaluating radon emanation, migration, and eXPQsure in a 

site-specific analysis of significant quantities of depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 
Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should

determine the types of licensee evaluation and monitoring needed to ensure compliance.

LES believes that the technical parameters for modeling radon emanation, migration and

exposure pathways should be consistent with those previously endorsed by the U. S

Environmental Protection Agency and embodied in 40 CFR 192, Health and

Environmental Protection Standards for Uranium and Thorium Mill Tailings. Since

evaluation and monitoring techniques have been previously identified and embodied in

Federal regulations, those criteria should be adequate for depleted uranium applications,

regardless of disposed quantity or volume.

Question 111-6.4ýIf NRC should specify by regulation the technical parameters for

evaluating radon emanation, migration, and exposure, what factors should NRC consider

in specifying technical parameters for a site-specific analysis for significant quantities of

depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities", should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should

determine the types of licensee evaluation and monitoring needed to ensure compliance.

As stated above, LES believes that the techniques for modeling radon emanation,

migration and exposure pathways should be consistent with those previously endorsed by

the U. S Environmental Protection Agency and embodied in 40 CFR 192.

Question 111-6.5-If NRC should develop guidance on the technical parameters for

evaluating radon emanation, migration, and exposures to accompany regulatory criteria,

then what factors should NRC consider in the development of guidance for evaluating

technical parameters for a site-specific analysis for disposal of significant quantities of

depleted uranium?

LES Response:

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should 

determine the types of licensee evaluation and monitoring needed to ensure compliance. 

LES believes that the technical parameters for modeling radon emanation, migration and 

exposure pathways should be consistent with those previously endorsed by the U. S 

Environmental Protection Agency and embodied in 40 CFR 192, Health and 

Environmental Protection Standards for Uranium and Thorium Mill Tailings. Since 

evaluation and monitoring techniques have been previously identified and embodied in 

Federal regulations, those criteria 'should be adequate for depleted uranium applications, 

regardless of disposed quantity or volume. 

Question 111-6.4-' If NRC should specify by regulation the technical parameters for 

evaluating radon emanation, migration, and exposure, what factors should NRC consider 

in specifying technical parameters for a site-specific analysis for significant quantities of 

depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities': should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should 

determine the types of licensee evaluation and monitoring needed to ensure compliance. 

As stated above, LES believes that the techniques for modeling radon emanation, 

migration and exposure pathways should be consistent with those previously endorsed by 

the U. S Environmental Protection Agency and embodied in 40 CFR 192. 

Question 111-6.S-IfNRC should develop guidance on the technical parameters for 

evaluating radon emanation, migration, and exposures to accompany regulatory criteria, 

then what factors should NRC consider in the development of guidance for evaluating 

technical parameters for a site-specific analysis for disposal of significant quantities of 

depleted uranium? 

LES Response: 
As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should

determine the types of licensee evaluation and monitoring needed to ensure compliance.

As stated above, LES believes that the techniques for modeling radon emanation,

migration and exposure pathways should be consistent with those previously endorsed by

the U. S Environmental Protection Agency and embodied in 40 CFR 192.

Question 111-6.6-What societal uncertainties should NRC consider when developing

guidance for scenarios of exposure to radon gas released from the disposal of significant

quantities of depleted uranium?

LES Response:

As stated above, LES believes that the language involving "significant quantities" should

be discontinued. Without a specific definition or criteria the use of this term will

introduce additional uncertainty and unpredictability into the regulatory process.

Irrespective of "significant quantities" from this discussion, the prevailing considerations

for disposal are the particular low level radioactive waste disposal site license conditions

and the Performance Objectives of 10 CFR 61.

LES can offer no substantive comments regarding this question, however, LES believes

that NRC and industry should create a bounding set of criteria and limitations necessary

to provide a clear framework for exposure scenarios. This is necessary to minimize

ambiguity and issues with varying interpretations in the future. Absence of a bounding

set of criteria, numerous different scenarios can be reasonably postulated thus requiring a

reactive posture by a licensee or prospective licensee. This lack of regulatory

predictability can result in increased costs to waste disposers.

Question 111-6.7-What alternative methods should NRC consider when developing

guidance on evaluating the impacts of radon gas exposures? For instance, U.S.

Environmental Protection Agency standards at 40 CFR Part 192 for the control of

residual radioactive materials from inactive uranium mill tailings sites specify that

releases of radon-222 to the atmosphere will not exceed an average release rate of 20

picoCuries per square meter per second or increase the annual average concentration of

radon-222 in air at or above any location outside the disposal site by more than 0.5

picoCuries per liter.

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use of this term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

As stated above, LES believes that the Performance Objectives in 10 CFR 61 should 

determine the types of licensee evaluation and monitoring needed to ensure compliance. 

As stated above, LES believes that the techniques for modeling radon emanation, 

migration and exposure pathways should be consistent with those previously endorsed by 

the U. S 'Environmental Protection Agency and embodied in 40 CFR 192. . . 

Question 111-6.6--What societal uncertainties should NRC consider when developing 

guidance for scenarios of exposure to radon gas released from the disposal of significant 

quantities of depleted uranium? 

LES Response: 

As stated above, LES believes that the language involving "significant quantities" should 

be discontinued. Without a specific definition or criteria the use ofthis term will 

introduce additional uncertainty and unpredictability into the regulatory process. 

Irrespective of "significant quantities" from this discussion, the prevailing considerations 

for disposal are the particular low level radioactive waste disposal site license conditions 

and the Performance Objectives of 10 CFR 61. 

LES can offer no substantive comments regarding this question, however, LES believes 

that NRC and industry should create a bounding set of criteria and limitations necessary 

to provide a clear framework for exposure scenarios. This is necessary to minimize 

ambiguity and issues with varying interpretations in the future. Absence of a bounding 

set of criteria, numerous different scenarios can be reasonably postulated thus requiring a 

reactive posture by a licensee or prospective licensee. This lack of regulatory 

predictability can result in increased costs to waste disposers. 

Question 111-6.7-What alternative methods should NRC consider when developing 

guidance on evaluating the impacts of radon gas exposures? For instance, U.S. 

Environmental Protection Agency standards at 40 CFR Part 192 for the control of 

residual radioactive materials from inactive uranium mill tailings sites specify that 

releases ofradon-222 to the atmosphere will not exceed an average release rate of20 

picoCuries per square meter per second or increase the annual average concentration of 

radon-222 in air at or above any location outside the disposal site by more than 0.5 

picoCuries per liter. 
LES Response:

LES believes that NRC standards and U. S. EPA standards should be consistent, where

appropriate. However, this citation of 40 CFR 192 for radon-222 suggests an

inconsistent application of this standard within the context of this FRN issues and

questions. For example, 40 CFR 192.02 actually states that:

Control of residual radioactive materials and their listed constituents shall

be designed' to:

(a) Be effective for up to one thousand years, to the extent

reasonably achievable, and, in any case, for at

least 200 years, and,

(b) Provide reasonable assurance that releases of radon-222 from

residual radioactive material to the atmosphere will not:

(1) Exceed an average 2 release rate of 20 picocuries per

square meter per second, or

(2) Increase the annual average concentration of radon-222

in air at or

above any location outside the disposal site by more than

one-half picocurie per liter.

Because the standard applies to design, monitoring after disposal is not

required to demonstrate compliance with respect to § 192.02(a) and (b).

2 This average shall apply over the entire surface of the disposal site and

over at least a one-year period. Radon will come from both residual

radioactive materials and from materials covering them. Radon emissions

from the covering materials should be estimated as part of developing a

remedial action plan for each site. The standard, however, applies only to

emissions from residual radioactive materials to the atmosphere.

It is important to note that this standard is for design only, requires no monitoring after

disposal to demonstrate compliance and the period of performance is up to one thousand

years, to the extent reasonably achievable.

LES believes that regardless of depleted uranium amount and volume, low level

radioactive waste disposal for depleted uranium and daughter products, such as radon222, should be no more restrictive than existing regulations such as is contained in 40

CFR 192 and encourages NRC staff to utilize existing regulations where warranted.

LES Response: 

LES believes that NRC standards and U. S. EPA standards should be consistent, where 

appropriate. However, this citation of 40 CFR 192 for radon-222 suggests an 

inconsistent application of this standard within the context of this FRN issues and 

questions. For example, 40 CFR 192.02 actually states that: 

Control of residual radioactive materials and their listed constituents shall 

be designed 1 to: 

(a) Be effective for up to one thousand years, to the extent 

reasonably achievable, and, in any case, for at 

least 200 years, and, 

(b) Provide reasonable assurance that releases ofradon-222 from 

residual radioactive material to the atmosphere will not: 

(1) Exceed an average

2 release rate of 20 picocuries per 

square meter per second, or 

(2) Increase the annual average concentration ofradon-222 

in air at or . 

above any location outside the disposal site by more than 

one-half picocurie per liter. 

1 Because the standard applies to design, monitoring after disposal is not 

required to demonstrate compliance with respect to § 192.02(a) and (b). 

2 This average shall apply over the entire surface of the disposal site and 

over at least a one-year period. Radon will come from both residual 

radioactive materials and from materials covering them. Radon emissions 

from the covering materials should be estimated as part of developing a 

remedial action plan for each site. The standard, however, applies only to 

emissions from residual radioactive materials to the atmosphere. 

It is important to note that this standard is for design only, requires no monitoring after 

disposal to demonstrate compliance and the period of performance is up to one thousand 

years, to the extent reasonably achievable. 

LES believes that regardless of depleted uranium amount and volume, low level 

radioactive waste disposal for depleted uranium and daughter products, such as radon222, should be no more restrictive than existing regulations such as is contained in 40 

CFR 192 and encourages NRC staff to utilize existing regulations where warranted. 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique Waste.streams,' it must not attempt to foriiulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name //7A-w,_ FIa (4/! 

Address92 /. •-.. e r 60 (A-

, 

dJ 

to • e//g r --. 7 2oq, ....... €

LOb

: To: Nuclear Regulatory Commission I 

: Re: Depleted Uranium Disposal Rulemaking I 

I 

I 

: Until the NRC is able to provide a clear description of "other unique l _'.. '. '." ., ",' .1, 

;wastestrearp.s,:' it must not attempt to formulate rules governing their 

: disposaL . 

: Instead, the NRC should focus on reevaluating its decision that 

: shallow land burial is adequate for depleted uranium disposal. I 

i Name y.,l; n WVV'- F ~5'5'-' 1Ai Address Cj 2. Zf 7= l;L/, C&"L. (" l{)O (.'L N. I t/oe-Je//o . ::s;p. B- 3 :1L!Lf ,~) 

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: _________________________________________________________________ 2 
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:./:IIi ,-n 4 t: '-" :•;..••i•-•• • -7 ."*'"' &' 

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Wi I 

~11- jf. ?1~:JZ~f~i~.l-"t 

J{, ~J/ t2 (.I::b ~3 Z-tJ t 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

111 \1111111 i \, 1,111 I II I, ill! 1111 
To: Nuclear Regulatory Commission

Re: DeyI-q!.Yffranium Disposal Rulemaking

Until the NR..-s able to provide a clear description- of "other unique

.wavstd streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name C-4 ."..

Address .S 9/ /ILL U - ,..

-. tti,

NOi

cz) ClTp

I-----------~----------------------------------------- ------------

: To: Nuclear Regulatory Commission I 

: Re: Dsp~1.~ranium Disposal Rulemaking I .. {"'<; •• , , 

I 

I 

: Until the.NR~is able to provide a clear description· of "other unique 

wcrste~ams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted w:anium disposal. . ....u ~. ( 

, . ..---;:)-n' Name O-rrR.1<. 

/. 

y V /-fTv At" ~ Ie ""-". 

) . "---I 

Address !).. a; i7" lit LL u..J;9-Y f)d=.-! 

: 

I.. ... J 

tf), fr3;>O;Z ;-ll 

I 1 _____ ------------------------------------------------____________ _ 
26OC

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28

Chief, Rulemaking & Directives Branch

Division of7Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of"Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i •• i .11i •••• 1.1 .. 1. i •• 1. i ... 11.1 
To: Nuclear PogdYatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "otherunique.,.

waste streams," it must not attempt to foriiulatefdifes governing'"ii " ieir

:disposal.

Instead, the NRC shouid focus on reekaluating its decision that

shallow land hbrialsis adeniuate for denleted uranium disnosal.

~Name__

:Address /6

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I-fl

Cr2'

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

-----------------------------------------------------------------, 

To: Nuclear l?RJg.!fatory Commission : 

Re: Depleted Uranium Disposal Rulemaking I 

I 

. I ,.:,.,: . : . . .' ,;",:,. .", 

Until the NRC is able to provide a clear description of"othe.(imique .. ,{ 

waste streams," itnlust riot attempt to formulate'rures govefuing .. trtei'r~,,':·;:;," 

disnnsal. .' .;: .~ ..... ~,:;:. ":'~', .. ~:,. . . ".,'~~'" . . I .t-'" ~ 

: :~'j<.::b' ,":> .. , 

: Instead, the NRC shouid focus on reeyaluating its decision that 

: shallow lU~ adequate for depleted uranium diS~OSal. 

Name ~~; o-:2~/ff Il 

Address / / CJ / /f./'(f M ~ 

g~ ~d' £3ZOc?- ~, / ~ ~;;.~"" .--n ~ 

CJ 
*i~~l &~ ii)

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office-of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

2fr6 '~JL~31.· ~2r·M~)f;j'·lF~Nll· ,t, 

//0/ ;J: 8 t:!=-S!-. 

~4-.J::r.k.b 8~~ 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

_Office-of Administration 

U,S. NRC 

Mail Stop TWB 5BO 1M 

Washington, DC 20555-001 

-----_5 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name J--..l/./4, 71D

Address/ ? C

-r't-- '0 C/'

-- -----------------------------------------------------------------, 

To: Nuclear Regulatory Commission 

Re: Depleted,Uran.ium. Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name Joh/ltJc'C4~?J;/ SJ.(·r+ -n . __ , .,.....r,,J .... -~ 

') I T1 

Address /1/ 7 1()/~:J,·."b:z.CI( '".'\ 

'" 1 ~ .,/ /Ja;)'f?/ ~u 6 51D~ 

I 

I 1 ______ -----------------------------------------------____________ _ 
j~i- a 4

2~

Chief, Rulemaking & Directives Branch --Divisiorr-of'Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

--Qivi-siurr-ofAdministrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i I! I, i ji 'III/! j I! ilL! iii II! Ii! i 
To: Nuclear Regulatory Commission 'Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

I waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-uranium disposal.

I-ame-73V

Address I)-o 7 / .--- 

"-O

Cri/."

-------------------------~~--------------------------------------, 

To: Nuclear Regulatory Commission 

Re:-Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to fonnulate rules governing their 

disposal. 

I Instead, the NRC should focus on reevaluating its decision that 

: shallow land burial is adequate for depleted~ymium dispqsal. ~:; 

iName 73V'~n r m!JrCil~kJ<-v?,r_i: / '/ 7 A) I (Jjl ~ :g'r-;-..-'.' , Address pi-0 IV . /8' ~~ / / --- :~~ ~:li 

----+l---=_-----.!.~___=:,. (l 0/'5£ __ --'--:=I_-='=--"~-\"Oaa;::-_ Y( cd '-fb -=:f-j-'--0; rill 

~1! -"-.../ .r.::: eftJ 

-.0 

y3/o~ 
2~5~ P1~& 17*

-8j

Chief, Rulemaking & Directives Branch

Division- of-Admirnistrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

II! if III I! (hi

Chief, Rulemaking & Directives Branch 

Division. of-Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

. il! i,m !!ld,L !ill!l ilr. I! ii!i 
------------------

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

:-Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-uranium disposal.

UFRI

Address CeI( 1 t Ch)P (Aw

_ _ _ _ __ _ _ _ _O

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

,-----------------------------------------------------------------, 

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking . , 

, 

., Until the NRC is able to provide a clear description of "other unique 

waste 'streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land 

")~J 

burial is adequate for depleted-l:U:anium dispQsal. 

" 

Name X&'] ~"jl) e±Gi£! y( L~ 

Address Ce I '5 ;;).. Q IG.A~~LM !P..N2.; q-~C. lD 63~3·; ~:, l"...) 

::1, 

c,: ,,' rTn 

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, 

, 

, 

, 

, 1_-- ___ ----------------------------------------------- ____________ _ 
C

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Chief, Rulemaking & Directives Branch

RDiyjsion.of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

I)i~i_si_on_of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

f!li dli!! II i IiI! f Ii "I !I,!; li~i--
-- - --- - - - - - - - -- - - - - - - - - - - --- - - - - - - -

To: I-Nc.eat Regulatory Commission

RW-. Depleted Uranium Disposal Rulemaking "

Until the NRC is able to provide.a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that f-I

shallow land burial is adequate for depleted uanium di"sal.

Name

:Address

_ _ _ _ _ _ _ _ _ cfi,

I. . . . . . . . . . . . . . . . . . . . . . . . --- --- . . . . --- --- ..---- --

To': :N.v.c!ear &.gulatory Commission 

Rb Depfei~d. Uranium Disposal Rulemaking ., ..•.... 

Until the NRC is able to provide.a clear description of "other unique 

waste streams," it must not attempt to formulate rules govemiQ-g their 

disposal. , , 

Instead, the NRC should focus on reevalu~~Q its decisl6h that 

shallow land burial is adequate for depleted-btanium di~iibsal. 1; -.~. 

Name 

AddreSS~ ~(~~ 
,, (~ J ~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

8

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

iur, /I1"1! i, ill LL !i:iwi I,i 
-- - - - - - - - - - - ------------------------------------ - - - -. I

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other umique

waste streams," it must not attempt to formulate rules governing their

disposal. -

Instead, the NRC should focus on reevaluating its decisi6n that

shallow land burial is adequate for depleteduJranium disposal.

Nam e - - _t OA .... ' I

Address T .0 - ' 37..\ _....

1o

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1- - - - - - - - - - - ---- - - - - - -.~.~~~::.; - - - - - - - - - - - - - --- - --- - - - - - --- - - - - - --- - --

: To: Nuclear Regulatory Commission 

, Re: Deplete~ Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of'~oih~;'~que 

waste streams," it must not attempt to formulate rules governing their 

disposal. ):-(~ 

Instead, the NRC should focus on reevaluating its decisiqn that 0! 

: shallow land burial is adequate for depleted::Jranium disposal. f:;::;: : i I c:5 cn: 

: Name "2,t ef k.~~ ~.:PCW-( (t:=:1 ';:~:'~ , u 2 -:'_.; 

Address 1'. O. ~0('~ 7~ ::.:: ~: C~ ~~i i-ri-'" , L - -.p ~~: F'I'...-\~ Th ~?~ 'f3 -t::: (.0' 

co 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

---- U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

1131 1 11 IlIllill 31311 313 1,3311 d

f.?;::::H:S"tf.~ HJt8·~7:· 

~ _ 0 . (bOx ?:, 7 S-q 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

_- U.S.NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name LQ- J13 

Address I• 0 hA __ -__-,_

IV

00H ---------- - --- -- --- -- --- --- -- --- -- --- --- -- --- --

I----------------------~------------------------------ ------------

"~:'i To: Nuclear Regulatory-Commission 

~ .. -: Re: Depleted Uranium Disposal Rulemaking . . I . , 

I 

" 

Until the NRC is able to provide a clear description'of"other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC 'should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name ~\:x;\ ~~ ___ ----,:-~=~~:-

Address ILfIO N· \\~~ __ "''''''''2....-) 

(;0 ()e r (D o3.~~ 

, 

. 

I..JJ 

I 

I 

I 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

~,I-~:l'1.S;~;. tU;S'3.«:· 

L, ~$A. L':f-ff ){,,~.~. ~~{1<\(~~H Pf4: 

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Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of 'other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow l buri is adequ fe for depleted-urani disposal.

~Address _

C-

--------------------------------------------------------------

,-------------~----------~-----------------~--~------- ------------, 

: .~9; N uc.l~arRegulatory.Coriimission ' 

'R-e:'Depleted Uranium Disposal Rulemaking .' . .,- .,A.·' 'f 

Until the NRC is able to provide a clear description of "other unique . 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Name 

Address 

, 

. 

u...' 

co 

. , ':. ) 

1 ____ --------------------------------------------------___________ _ 
(

Chief, Rulemaking & Directives Branch

Division of-A-dministi%-tive Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

-----------

Chief, Rulemaking & Directives Branch 

Division ofAdministtative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01 M 

Washington, DC 20555-001 

j I; i II Ii II! i i!i! 1.1 1 iii i i fill iii i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

!Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted, anium dispbsal.

F71I

--- i

Address L'759-L2 '. - •- :

41-9 - - _rs'2

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking .. 

Until the NRC is able to provide a clear description of "other unique 

.. ,., waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for deplete~tJanium di~~?sal. 

Name4wv:f i-Ictus~ Address l L6--~ N c;Yfi 51-- ~ .' .. 

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, 1 _________________________________________________________________ _ 
28j

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

!•.II l, ,, " " 'J

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

. .. . ,.--. 

ill "iii if ! ! '11111 ! r! d" ! ! Iii ! I 
To: Nuclear Regulatory Commission I

Re: Depleted"Uranium Disposal Rulemaking "

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal. .7

Instead, the NRC should focus on reevaluati ig its decisiofilhat .

shallow land uri is adequate or depleted uranium disposal, 2

Name /

Address ( !_J/- r

----------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted"Uraliium Disposal. Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attemp~ to formulate rules governing their 

I disposal. :TI ;~.:: :::; ---'1 :1;:: I <.:::. I·' .... 

Instead, the NRC should focus on reevaluating"jts decisio~that :l::~ 

shallow laJ?d uri is adequate or depleted Wjapium disposal.) l:~:) 

Name ; 1 I 

Address 

,.) ry-, 

17.r-i ,._) 

1-. 

t~ jTl 

en 

1 _____________________________________________________ - __________ _ 
77.3... T R 7.37 Pd7-?"ý

..... ....

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

----_._-----

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

- ·---6ifi~e of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

iii i! i jj! I! I i II f Ii I il ,i Ii III ii! i 
To: Nuclear Regulatory Commission'. .

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

I/ "-•T

~Name Y- r0 VQ4 I--

Address A ,71 • 

C/o

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1- - - - - - - - - - - - - - - - - - - - - -.-.- -'- -'-: - - - - - - - - - - - - -. - - - - - - - - - - - - - - - - - - - - - - --, 

: To: Nuclear R~gtihifory Com:mission' ",J. : 

I ". ..... .•.. . .......... ",' .. I 

'Re: Depleted Uranium Disposal Rulemaking : 

Until the NRC is .able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposaL 

~ A/I]- Jl 

Name r ....Q,\j JV '~Vl tV=r.e---· . t''':'''''l ' I (2 ,,.,1 A" po." ..... " J 

t~YIA Ii .. , o "''-.:-lbi'<;'" Q : , - , I l.~.)" 

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Address 

j I 

CJ 

1 _________________________________________________________________ _ I 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Off ic e of-Administf-dtion

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemakif)g & Directives Branch 

Division of Administrative Services 

Offic§~of"A:dministrat1on 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Re-falatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of 'other unique

waste streams," it must not attempt to forni-uate rules governing their":+

disposal. 12

Instead, the NRC should focus on reevaluati'-g its decisi 'n thatshallow land burial is adequate for depleted&.Uranium disposal. --- ----

Name

Ad~dress PO &Y

I I

--------------------------------------------------------------

1-----------------------------------------------------------------, 

: To: Nuclear Regulatory Commission : 

: Re: Depleted Uranium Disposal Rlllemaking : , I - .!'-'" , .. ~':;' 

: .~ :,' . :.... . ..~...' .: "~~' 

,." : Until the NRC is able to provide a clear description of '~Q!her unique : ,/i'~' 

'waste streams," it must not atteIt:;lpt to fOIlI!1i.~te rules goy,eming their~l " 

disposal. :'ll ~::5 8~i --.. ....::.: ___ r 'J ),., 

" ) " 'CfJ -'" 

Instead, the NRC should focus on reevaluat¥r~ its decision that '; "" ::=! 

shallow land burial is adequate for deplete(:turaniunl di&posal.. ~F: ....•. ,.... :02:: rur I 

Name K1::*:=~ ~ ~ Address ~ _ ~~ l-aop .,., : 

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28]

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

_T-_

Name I ceitied ."-

Address 'el C/,~ , 7~ 5iNOJ - --------------------------------------------------------------:

-------------------.--~------------------------------- ------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formlllate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name Pa.l) I 3ened~(+ 

Address 

I ! 

, 

. 

1..", 
7

.••= •;•ih77 '-; f•. i.. M • ;P -.. • '

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

hd ilIII l 1 hi lb It hA1 fIIJl

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM' 

Washington, DC 20555-001 

I! Ii! IIIIIIIIIJ 1,1,1 !li,I",li ,I 
To: Nuclear Regulatory Commission

':•Re: Depleted Uranium Disposal Rulemaking -

Until the NRC is able to provide a clear 'descriptkin of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-"uianium disposal.

Name /V.",

Address 44"1(ý

/eic5&~-r N.O

- - - - - - - - - - - --

1- - - - - - - -- - - - - - - ~.-...,:::..!..- - - --- - --- - - - - - --- - --- - - - - - - - - - --- - - - - - --- - --

: To: Nuclear Regulatory Commission 

.. Re,;Qepleted.i!!anium Disposal Ruletpaking, ... '.li~'·· 

" .< ~ ..""'. ' ." . ..~~"~~';:;;~T;:'i~'~;~;;~:~ Until the NRC is able to provide a clear descriptIon of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluatipg its decisio!t that 

shallow land burial is adequate for depletea~Ufanium di~P9sai. 

Name ,SArrr-!iLt.r- ~2 ; I 1.;...' 

~ 

Address 3 5dL! II/ld:.~ .,s 

::x: ,-' (=, 

f'"i~1 

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>.:. ,i-) .J. -

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3A~ZPr7 7 *r3

WO-w--'-v

Chief, Rulemaking &, Directives Branch

Division of Administrative Services

Office-,ofA-dministration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

haIt 1111111Idd JIiL-IIIJ~I !11

· . ..:B~::)'!~:~E.·;t:D-B:::ir;'i' 

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j})(J/JL (D ~.l 03 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

OffiGe·'of~aministration 

··'tfs. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
- - - - - - - - - - - - - - - - - - - - - - --- - - - - - -

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal RulemakingUntil the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that.

shallow land burial is adequate for depletedLuranium disposal.

:Name

Address V < 36 Ah

CI

rT'I

i . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .-

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on r~evaluating its decisiol} that 

shallow land burial is adequate for depleted_irrhnium disposal. --n 

Name 3:c~ 1~4Ie-/ .. ~ 

Address ,),.J 

JI};/> ~ , 

::1.1) 

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nil 

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_________________________________________________________________ f h • 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
-To: Nuclear Regulatory ------- -Commission -- - -- -n --- -- -- -- --- ---- ---

:Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-uranium disposal.

:Nam QJ O__.Q.CY'yi~pS• .-..

Os- .1I

I' TI

I K) Ij

UI

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1- - - - - - - - - - - - - - - - - ~ -~:.. - - 7;:: - - -- - - --- - ":"!' - - --:;"-.- - - - - - - ------- - - - - -,- - - - --, 

: Tp:Nuclear Regulatory Commission I 1 . . ,,"'. 

'Re: Depleted Uranium Disposal Rulemaking" 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for deplete~15'anium di~~l)sal. G ,--- "n Nam~('-'D Q,.-~ I Ol~ s --" ;;;J I ~ ." 

Address ~Od:- v\/. J''-"t...~·1-··J··] \ _ ....... 

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1 _____________________________________________________ -------_____ _ I 
BOISE w S3

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

..Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

J!IlJIJJ!I~f I!

5fJ'JeSE. I[)· S\3~:~' 

3802 ~T~~:~'J9: Pf!;'iY::l'T 

P:;;0, ~ (:, ( t) 

~'~70?J 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

~:c "Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I" i ,i i;! II ,I, i" i, i,! i I i"III, i 
To: Nuclear Regulatory Commission ..

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name (-

A ddress........ -

C-1

-T~~N~~i;~~R;~~I-a~~~ -c~~i;si~~-- ---------~ ---------~,- -------- Re: Depleted Uraniuni Disposal Rulemaking ...... ." '';' 

Until the N.RC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

I j' ~ 

Name/C~~t?,~~~~-; / ji;~ 

Addres ~t? W~ r::;'L2L4 

~-J A'6-g?)~35CJ;' , o '';9 

-t:::: 

0.. 
'2, T

Chief, Rulemaking & Directives Branch

Divisioniof-A'dffiin istrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

J~II iIJ~IhIf if IS! 151111! hUh

Chief, Rulemaking &. Directives Branch 

DivisiOlFof:Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulator/Co6`mmission

:,Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name S- ~, (vT1

'iu If-,,,

Address 17 . R II (

C L . U•-I

VW..5 7•,•.

4=Z .---

?-i .oI ....

- - - - - - - -- - - -- - - -- - - -- - - -- - - -- - - -- - -

I----~------------------------------------------------ ------------

: To: Nuclear Regulatory""C<.immission 

I·Re:D,epleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must l~ot,attempt to formulate rules governing their 

disposal. -- , , " 

'.:\~f • \ 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name \ ) Os wt-l: L- I (!IJ ~ --rz£ -II' QV ) JJ 

Address 3~ I -g~"1 1-+6~~ lLv?~q 

'BCLASVINb -G"» 833) 3"T::~ , 

v.J 

j 

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I 1 ''9 ;,:] ..r::: 

0-

----~-------------------------- .. -------------------~- -------------
S (3

50F E.IJ D_ 1-3--7

3333

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

SMail Stop TWB 5B01M

Washington, DC 20555-001

B:O],SE 10.' 83'7 

J. C?;.sf ~- f~~-':P\~""'l'\o)'.:'t ~::'Iill"'._'·~ 'T' ) ... ~\o.n ... ,,'!-:... V ~ ..... t:: ~'. 

3.3\ B'(}'k. (1..i. 

~e,.,H e-JIAL U 

i3313 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

~,:.<>("·~'Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission .

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name L)jor_-]•L( O-/ 7•. ,,,;,

Address

a} (-- e, -,

I--

1III~

0'~.

-T~~N~~1;~-R;~ill~~b;;~2~~i;sib~-=---------'---~':----------------

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted_uranium 

0' 

disposal. 

NameDe6hL =j1Y'C~.\\ ::t~ ~,,; 

o I' ~ ",{b '. ' ) Address \ '30 ) ~ c/-J.JT'! 

'2:>ou;e,) :I:D .~ ........... ' 

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1 _____ ------------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

h~I 3 Ii,"h 4*Id hl, ,,,t~Ihi

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i "i , il",! f i f I f I i,l, ,I, I, ! ,11,1 
To: Nuclear Regulatory Commission

Re:Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleteduranium disposal.

Address 7311 W: i- ....

------------------------ ---------------------------

------------------~~--,-~----------------------------- ------------, 

To: Nuclear Regulatory Commission, : 

Re:·Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted_utanium disposal. ) ) .~ 

Name Aadrtc 1:n8\e" ~il (.,:~ . ) < 

Address 7312 ltV· tl n@skY>12r;j 

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2 C~CT 2~2~ ~t~t 2 T 28

Chief, Rulemaking & Directives Branch

Division of Administrative Services

... Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

IlEiEIJJI!IlISb EIS lIE I3iI1JIlfi

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

-'~=_--office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I" i! II i I! ,11,1,1; I; II;! i III/;! I 
To: Nuclear Regulator- Commission .. .....

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name LA.f'

Address 360 r / . .

------ / - ------- ¢ ,-- ----....- - --------

----------------------------- ----------

: To: Nuclear Regulato1:"~ CQ!P,IDission •... . .•.. ~: ,{ ... ~ 

:Re: Depleted Uranium Disposal Rulemaking I. '" ,. ~ .. . ' 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for deple~.d uranium disposal. 

Name ((tit E~dJcfkl, -3 ~~: Address J 601 q r ~PI \ 1 '"".I 

E DJ~/ '70 fi:?lO] -~~ 

1 

1 

1 

-I 

1 
'I~ -{ 2OT .

28-

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i " i I j J j ! I ! ; I ! I! .1, i! , I, ; I. ! J I! I 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

[disposal. -!

C:-

Instead, the NRC shold f n reevaluatI its decisiorni that

shall landburial is ýdquate de eted uranium disposal. 1

_-__ _ _-__ , _ _-

Name __________-_-__,

Address c,)

I.. -- t1 I

--- --- - - - - ..... --- - - - - - - -~ ------------------- --.- - --- - - - - - --- - - - - ---

To: Nuclear Regulatory Commission 

Re: Depleted Uraniunl Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their I 

disposal. ~"l =b JJ ,,":J f:; 

r-~'-l 

('I ..... , ..... j .. 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief. Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

ill iIi I i 1III i I j I ! '1',11,',,1' j ,I 
To: Nuclear Regiulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluatitng its decision that p- •' A f I :.: -n shallow land burial is adequate for depleted-+ranium disposal.

Name Ký4JnS b C :

:Address I~ (u Lo~ 

k-3 700

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 1····) 

Instead, the NRC should focus on reevalui~g its deci~i~n that ~ shallow land burial is adequate for depleted-"Uranium di~posal. ;~' 

Name I<P----fhy 7204(5 b~k- ~, ~ 

Address I DO {i? (J, SIr; / ;-f'~~ Ave. ~ 

130 ise =CD ' .. 3709 U) 

1 _________________________________________________________________ _ 
."a-. , .F ., 5 •.•

100

rýej-Te 370 C( -28

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I ad!1Jfs.IisIIsifIm;IsIIa!IJEi

100 l g- :!§t8~c5€..y!t/!fL 2: 'T·· 

~'3e-- ID 8370 L( 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i,! i, III ""I, i "I,I,;i ,i", ji.1 
To: Nuclear RegulatorTCommission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able, to provide a clear descriptin6oiof "other unique

waste streams," it muit not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating-its decision that

shallow land burial is adequate for de leted uranium disposal.

Name -

Address 7.. (- -2: 2

19 --- 0. " 

)

.. . .... - -- i ̧ -X--

------------------------------------------------------------------

To: Nuclear RegulatoryCommission 

Re::bepleted Uranium Disposal Rulemaking .;,.~ 

Until the NRC is able to provide a clear d~scriptiri~i6{i'other unique 

wast~" sJreams," it must not attempt to· formulate niles governing their 

disposal. .. --

Instead, the NRC should focus on reevaluating.its decision that 

shallow land burial is adeqU~leted ur~ium disposal. 

~ ,I , I 

Name_4Ay -~ ~ 

Address //?J/' A/ £~~ ;> :-3: 

gJ~ £)d t:fj~~02: Vl 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

OfficC(5f -A-cm-iitration

U.S. NRC

Mail Stop TWB 5BO0M

Washington, DC 20555-001

iiil*iiilfliifliiilliiiiiil!iiii

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

OfficCof"Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
:-To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluati-rg-its decisionthat

shallow land burial is adequate for depletedir-ianium dispj6sal.

Name ca -5.."'I4./'

-I,---

F'--

-I

Address A ','7

JY) ~ 79 XNO

II

-----------------------------------------------------------------

1-----------------------------------------------------------------

'-TO: Nuclear Regulatory Commission 

Re: Depleted Uranil.1Jll Disposal Rulemaking .,:..". . 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluatiJigJits decisionithat 

shallow land burial is adequate for depleted "iiF~ium disp:Q:sai. " .... ~ <:::.: 

N~am=-e --'&""-"'-'L-J'.JLj-o{~&"I7"rfL~'4..~2----"~...l-·f;'---; L~ 

Address ALe l :z J<fiALSJo (,a (]j~ 

~I 

1_--- __ ----------------------------------------------- ____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOlM

Washington, DC 20555-001

if I I I III If I I if If I if if I hit If IiII

Chief, Rulemaking & Directives Branch 

Diyision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory CommissionRe: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

~Name f9'• t N"'' T,0I 7J :zG:r. C

Address 00,2 -7, P, C- t"0 T

I.....................

o-£ 3 LI :.-•Q .11 

---- ---- ---- ---- --- ---- ---- ---- --- ---- ---- ---- ---

To: Nuclear Regulatory Commission~ 

Re::UepletedUranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium dispQsal. 

JJ. . ..... --- • ...:.> 

Name DAVIO 

Address r; 1, 7 

... 

CJ 

.,1,1 
:-R'IV-'I TS 'FEIM

Chief, Rulemaking & Directives Branch

Division of Administrative Services

.• ... ffice of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

It I J I I JII I ... N

,BiC.JIS:i=': ~T f) .:83'7 ~'J -~~. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

..... J}ffi~e of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1M 

Washington, DC 20555-001 
---

To: Nuclear Regulatory Commission

Re:.DepletedUranium Disposal Rulemaking

'Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial ladequate for depleteduranium disposal. t,

Address 2 _-.

cI-l

1-----------------------------------------------------------------

: To: ~uclear Regulatory Commission 

I Re:Depleted"UraniumDisposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

::X, C , 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is dequate for depleteq~anium di~p6sal. I I 

JU 11 ij£-U7 ":"j 

f~-;:i 

u: 

Name . 

Lv 
- ~ -

Chief, Rulemaking & Directives Branch

Division of Administrative-Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO0M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative-Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

, ' ' 

j,,; ;,11 1llll,l,i i,l"i, i'll ii!1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted.. ianium dispfosal.

Name -. L- jk- --

Address U- -- • q - , --

---------- ---- ----

To: NuClear Regulatory Commission 

Re: Deplete~ Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. .'.) "n .. :.; Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted~Ganium disl1~sal. .]-

Name J"2t\\JL--- ~-U/~ ~} 

Address g]18 tJ, gq~ 

I ___________ ~----------------------------------------- ____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I f i I I I I I i i 1 11 11 1 1 i 11 i I

· ... "~,. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

. Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
,IT°:Nuclar.--------------------------------

To: Nuclear. 'Regulatory Commission.,-.

:, Re:.Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that cshallow land burial is adequate for depleted-uranium disposal.

'¢.'?

Name _____-______ -A 

Address 2.-2-- (,\ \g-• - -, [ C.

I L ti :--Fri

I---------------~---------------------------

: To: ~uclear. Regulatory Commission .~'_ . - -' 

:,B;~:JJ.~p'~~ed Uranium Disposal Rulemaking .~ .... ,~ 

.n "", 

Unfil the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

, , 

Instead, the NRC should focus on reeval~~!tng its deciston that 

shallow land burial is adequate for deplete~uranium disposal. 

Name J0Y\el \-e YA~ :;~2 ~-="--=-=--:----'-_____ : : \..t.) 

Address 7-C;LI W V\I te- ~'I l 

, I j 

l cl 13 -S(o~~ 

1 ______ -----------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

II. i~Ili. 11 ii I bi~~ lid

_ T~C)lS:~: .::ll"O.iP.t3)" .. . . 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nule-ar Regulatory Commission ,

Re:' Depleted-Uranium Disposal Rulemaking

Until the NRC is able -to-provide a clear description of "other unique

Waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted r-anium disposal. _-

:Name-.

Address

0ý_P

--- ------ --- - -- - - --- --- --- --- --- - -- ---- - - --

I------~----------------------------------------------------------, 

: To:)~uSlearJtegulatory Commission : 

:R7:'DeRJf~~ed.Uianiurn Disposal Rulemaking ~ I '£/"'i .-' 

I ~ 

: Until the NRC is able~to'provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted ur:aniurn dispos?l. 

f? ._,...}". ~ --r-j - . I I 

Name ~ --') 

Lt.) 

Address 
S~ 7J

P M

28 OCT

I2on

jinan *

C 1etStam'a ~

88]

.,2 • •,.

Chief, Rulemaking & Directives Branch

,Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

~,.]i;l·".:;.·!. 

833vd '.':L._ '.~'. 

• < ~in an ~. ·1. 

I L 'nt Prc~~'> .1 ~~~Ic~t Sti~~' ( . 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

11111111111111111111111111111111 
--- To: •-Nuclear Regulatory CommissionRe: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

II

Name "'A" -

Address ,'7•2- ( -,. V .; L•

FYIl

I-------------------~-·------------------------------- -------------

I. 

: To:· Nuclear Regulatory Commission·.:· 'r''''",,' .. ,-

: Re: Depleted Uranium Disposal Rulemaking I. . ,."-

I 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name :A-nJ(f~ %d:!!J .~ rJ 

Address tb~2-- ca~±t(U~( 4(; ~ . ! 

l0· / 'J 

~i'e(, .:t4 g7:i~. . ) 

r I ''"--'' 

w 
:~tT~: LU) $~3~?

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

.... , .. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

; 1,;,llillllll Ii ,ill!li,i 'llil,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for deplete-_d-ranium disposal.

:Nam . -,

Address UJ -

3' 7

---------

: To: Nuclear Regulatory Commission . 

. I Re: Depleted Uranium Disposal Ruleql~ing 

Until the NRC is able to provide a clear. description of "other 'unique 

waste streams," it must not attempfio formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for deplet@Jiranium dIsposal. 

.. In T/ .' 

I 

t.-.) 

Name~~fr(}e. .. ~ 

Address 0\ \1J- \/J ( ~b~U~ " 'I 

----.,. 

(3o )~e'l r Q f> '37 oiID.. ) 
L .... e - •, P"T,,,• " .''a

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of AXdniin-istration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office ofA(iJiiiriistration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

ill iIi I i IIII ii/IIi 1/11 i I jIll i /! i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking ,

Until the NRC is able to provide a clear'description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-,uanium disposal. ' £ •~ ~ >Z QI .1~~s -Ti ,• ,,r-

:Name J / •) ,§ '

Address 2//• '-A'6•E' - '

1NO

- - -- - - - - - - - - - - - - - - - - ----- - - - - - - - - - - - - - - -

n-l-'

i . . . . . . . . . . . . . . . .

-~~---~---------------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking . , .,.. ~, ..... ' , 

'/ .... 

Until the NRC is able to provide a cle~'description of"other'~nique waste stream$," it must not attempt to formulate rules governing their 

disposal. '. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for deplete~~e;anium disppsal. 

-Tl 

Name l:&oL ])r VOkES .. ---< , ... 

;"'il 

Address 211£ Mj{MtlRE 1Jtf(lYI? 

120 (s'JS 1 :r j) !J11Z.:::7:1 

7 ;.5 .r.::: 

w 

I 

, 

, 

, 

, 

, 

, 

;:It 

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(/:, 

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T'! :~. _ : 

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::: .. ;:')' 

c~j: -~, 

.... <:' rn' 

(0' , 

, 

, 1 _________________________________________________________________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

-Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

ie;OlSl,f.:,JD :8.37 

',:'<-.. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

_Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

i, ,i 1111111111111 i,l" i, i "I ii,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique-.

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluatinglits decisionithat

shallow land burial is adequate for depleted uranium disposal.

Name

Address

'-3

U'

'I

U ~

Cr3,

9-5703C

":.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1- - - - - - - --- - - - - - - - - - --'::'!'"~- ------.-:'.--- -------------------------------, 

: To; Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking, , , " . :,., 1 . - I,' 

I ,_ : 

" .. :Until the NRC is able to provide a clear description of"oth~r uriiq~~'·'·::':I."~". 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluati~IDits decision:that 

shallow land burial is adequate for depleted uranium disposal. I" 

Name 

Address 

--') ~;i? -. #.1 

, I 

,,-.~....-" 

'-.-"-.. ' .. """ ... ~ .. , 

. I I 

?"3703::J 

, 

. 

lA-' 

I 1_---_------------------------------------------------_____________ . 
CE

XL

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

, ' ,-Hen S:f; .Ir~ "::~3;~:l! 

~g t< ~~~'T·t>C'1-t~~~:~ .,.;.,. .. '.....~ . ':'\ ... _ ~.~~ .,j;,_~ .~. ~-r r:·J ~ t ">l'- '~'" 

3hftJ 3 Co If {sTeer '»v. 

~Ope/:TJ2 ?3703 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

j"I!/III'I'I;'" i, ill/,lll!il,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequa~-s for depletedwi'-anium disposal. C,:

'Name______

Address •-Y•/--,

.. .:" -ýO

- - - --- - - - - - - - - - --- - - - - - --:;;.. - - - - - - - -,- """"-~7":":- --- ---- - - - - - --- - - - - - --- - - --

To: Nuclear Reg1llatory Commission :. 

Re:·'Depleted Uranium Disposal Rulemaking -.,~,', -"- ' .. , . 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decisi9~ that 

shallow land burial is ade~; for depletedjI!;anium dispqsal. 

Name ~~£ .~ -. 

Address;;JLI7V~ ../ :' ~--.... ~~ ,--

~~<- 5.3z?f~; \... __ 1 .r.::: 

w 

:J~} 

e'· r"" 

("I"j (.1: ~ 

":'h 

0:'01' 

f.~o~: 

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;:1" n" 

C~I) 

=:~ <,- n,l C/,' , 

, 

, 

, 

I 

I 

I 

I 

I 

------------------------------------------------------------------
ZACY~ r:I3

~'~' N ~ -.

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

if l11,1111 JI'lifl! ith I JIIJ

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i ,,',11 J II!' i! i " i ,,! ,i Ii!, I i J.I 
'To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for deplete-dturanium disposal.

Name

:Address c-f

* (

-----------------------------------------------------------------

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission ~ : 

Re: Depleted UraniurnDisp()sal Rulemaking : 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. , 

Instead, the NRC should focus on reevalucffilng its decision that 

shallow land burial is adequate for depleted luranium dijposal. ~ __ A j e~ ~-

Name (abt i:r~?SUV -:T~ ~o.J 

Address t;7b Ch VJ MtJ~*' 

tJ)7{"." ~ 'D6 71 B 

I 

I 

I 

I 

I 

I 

, 
. 7 - -, . N I .

Chief, Rulemaking & Directives Branch

Division of-A:difiiistra-tive Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division ofA1lminTSif:1iive Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

I" h iii 1111 i,l"i Ii" i I i"lli,l 
To: Nuclear Regulatory Commission,

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluaiiing its decision that -

shallow land burial is adequate for depleted-uranium disposal. -

,Name1

Address -O(LI N N-.1 - 2 I] 

I .• e.1Y C/-D

I

--------------- -------------------------------------------------

To: Nuclear Regulatory Commission,.. 

Re: Depleted Uranium Disposal Rul~making . 

Un.til the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. ., 

Instead, the NRC should focus on reevalUati~g its deci~l~n that 

shallow land burial is adequate for depleted~&anium disposal. 

Name /'" A"'1 J l-k,tJ, i'" SO 1'\ .'T! ~_,~ .~ -

Address 10(4 N. 2}"- ;Tl 

I _________ ~---- _________________________________________________ _ 
2.,E-28,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

..... Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

-~,~- Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

!-2 Instead, the NRC should focus on reevaluating its decision that .

shallow land burial is adequate for depleted uranium disposal.

SName

Address

45ý2,I

To:' Nuclear Regulatory C0l1!IDissio.n ~-, .. ~ 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluatiAg its decisibJ that I I .'" 

shallow land burial is adequat~ for depleted.-Janium dis~§sal. 

Name Cym r'j "6, J2e~d~ ~ 

Address 3 5 I ~ t± Au>n-1c€--~ D~:9 

DoISG t 10 <f3JP'3- Lfnb 
QGT OCý 2V2rM,, PfMI 2. T

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

j i ! j I iii 1111 j ! i, ,/11111 ! III! I; ! I 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

,,hk :Name 6 nv4 A01.Z

Address _-__ _ _ _ --

- fI i

* ~rI

- -- - - - - - - - - - - - - - - - - - - - - - - - - - - -(-I- - - -

------- --- - - - - - - - - - - - -:::~:-.-- ~ ":".'"': -.- --- - - - - - - - - - - - - - --- - - - - - --- - - - - - --

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name 10 i11 ~ ftu) --==------

3lf 0 Cf/4/t 6 ~ Oi!jd Address ,_, I I 

10 ~15sJ:--) , j+j 

• I 

'.' 

') 

1 

v.) 

---I 

-!::: r;;: C) Cfj 

---------~-----------------------------------------~-- ------------
q- IFEE in11ý-ýChief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

113151111311131311111913193,1131

Chiet~ Rulemaking & Directives Brancr. 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

. Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

j"I,III""I,I,./,I.,I,I",/!,1 
-'To: Nuclear Ri~g&%t1tyt3!!2btttfl1§ WT II"I'l'"l I ... ' '

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear desciiption of "other unique

waste streams," it must not attempt.,to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating-i~ts decision that ,-

shallow land burial is adequate for depleted uranium disposal,

i t ' "• " -... :Name ¢ 3 t.j ' :

Address 3c • ' C

4 /-. /'o c'S im e/~( /~~2< ~ ~ ~Ic:

---------~----------------------------~~-------------- . . -----------

To: Nuclear R~~1'attJt)tIC'OttUtfi~!:U~IIIIIIIII1"IIII1II1It1!1 

Re: Depleted Uranium J?isposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attemp~Jo formulate rules governing their 

disposal. 

" 

Instead, the NRC should focus on reevaluatin&jts decision Jhat ' 

shallow land burial is adequate for depleted ur~ium dispos~L i I " 

Name Ala 11 f IJnolq llaCk;;J5 I 1 ~ J 

'. ~ 

~~ 

Address 3 'fo () Ctcree c/d .'tt:t,;:'~1 i s~ 

12 ,11 --9 

(../cg 4<2 ,I -.:L g 83 7tJ -Z- \:=J cS 

II 

" . 
............ T s ý 

Chief, Rulemaking-& Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

fill! 111!I Jill 111h

Chief, Rulemaking-& Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re:. Depleted Uranium Disposal Rulemaking

:-Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating'ts decision that

shallow land burial is adequate depleted uranium disposal.

IZ j 

~Name

Addr s

6 013

-------------------------------------------

I----~------------------------------------------------ ------------

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking I" ", ' 

: •. ~.~~ \ ~. "', j .. ' : 

"Until the NRC is able to provide a clear ,~e,scriptiori of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal.' 

.... ,.:j . 

Instead, the NRC should focus on reevaluating.1its decision that -~""""'l • ~ 

shallow land burial is adequate depleted w:~ium dispo§J!l. ) , 

Name . r-t I, •• ,) 

/~r~ Il~'! ~l&l{J,·tj). ~16~~ 

1_--- __ ----------------------------------------------- ____________ _ 
PM~

28 OCT C':r- .le stil Q$

.28"

Chief,,Rulemaking & Directives Branch

Division of Administrative, Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I I1111 ~ Ii I~, I, I I 111111 I ~I

': I. r: ~') f: 

't3 ~::~ 'Pt0~ 

Chief"Ru\emaking & Directives Branch 

Division of Administrative: Services 

, Office of Administration 

. U.S. NRC 

':: Mail Stop TWB 5BO 1 M 

! . Washington, DC 20555-001 

. ; 

I"I,III";,I,T"I,I"I,I,,,II,I 'oj" •••• 

.i 

\ 
I----------------- ------------------

To:. Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

'Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attemnpt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.,

Name frt).~& \ iIVle

Address P L4 £ t ... -,

~~ .... C- L 4• O • s:-r

I II

'-:11

. . 'D

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - C•• .....-- - - - - -

,-------------~---------------------------------------------------, 

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking :' ·~r I.r '{ . 1 

'tJntil the NRC is able to provi4e a clear description of "other unique 

waste streams," it must not atte"'mpt to formulate rules governing their 

disposal. -

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposaL ',.'0" ~ 

Name M~>~k~Yl (Ie/"" 

Address 
-~PM s*l

fr{r

SC 28OCT '(Coile('t Stu

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique,

waste streams," it must not attempt to formulate rules governing their.:

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate ft depleted uranium disposal. I

Name *-,

Address . .......

-------- * : c:j: :

a:: :1 I i 1

: To: Nuclear Regulatory Commission , 

: Re: Depleted Uranium Disposal Rulemaking , 

, 

, 

: Until the NRC is able to provide a clear description of "other uniqu~:. 

: waste streams," it must not attempt to formulate rules governing their ,j;:;i:< 

: disposal. : ' 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate £ depleted uranium disposal. 

Name 

Address 

'vJ 

Ul 

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·,-;:.i,. ; •• I 

''''''1 

,., 

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IA&Ms Theresa M. Kaufmann .,A, -I

I• 4977 Clearview Ave. -

Chief, Rul*emaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001.

Chief, RUl.emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM. 

Washington, DC 20555-001· 

11111111111111111111111111111111 

'i ~.~ ',' . , 1 • ; i ' " . :;;: 
;-.To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of '"other. unique.., waste streams," it must not attempt: to formulateiprjes 'govemmgttihghe ir-:-

disposal. ..

Instead, the NRC should focus on reevaluating its deci siofn that

shallow land burial is adequate for depletea'uranium disposal.

!Name r

dres

1,JF- - ----- IL:: ..... 

...i'"• ', .... 

, 

'T-o:Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to providea clear description of "otheruniqll~,'. 

waste streams," it rri,ust not att~rnpt to fOlmulate:rtiJes~g9veiTIihg:th~ir· :',' , disposaL"':' . : ", '" ':;" ", ", 'I' "', . 

, 1 

1 

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i , , . , i . ! 1 ~ , i : i i , i 

~ , { i i ! \ 1 1 ! i ! , i i i I i i \ I , . ! i i , i ! 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

111 1 1 1i I I I I I I I I I I I I I I'l I I I I i I I I I I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regiltatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique ! .. . . ..

waste streams," it must not attempt to formulate rules governing their

disposal.

jzI

Instead, the NRC should focus on reevaluating its decision that C:

shallow land burial is adequate for depleted-dranium disposal. C

Name , , ..

Address ft ,3c (-I), 

----- , "-'I , 

, 

-----------------------------------------------------------------, 

To: Nuclear Re~atory Commissiori : 

, Re: Depleted Uranium Disposal Rulemaking : 

, 

.:1 

Until the NRC is able to provide a clear description of "othe~ unique ' ~: 

waste-streams~" it must not attempt to formulate rules governing their :_ 

disposal. : 

, 

, , 

Instead, the NRC should focus on reevaluatipg its decisi(51)- that 

shallow land burial is adequate for depleted::-\itanium disp0saL ! I ',"::;, ,.---, ...:-,,:,:: 

f -, .~ ,,) , O("Vb ~ . --,"-', 1.",,' 

, : 

Name 

Address lS'+' < 

\ 1 

) X3344 

.. ' 

" / 

, :;elf 

C' r-'" 

Ilil 

(/:J 

):1' 

j·'1 " '-"'1 

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1-- ____ -----------------------------------------------____________ _ 
~&~* ~T) ~37TJ~

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S

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

I IlllI? 13lJj flIt111111111 idl I 11

.. ·12 .\O~~.T. ::¥!:t1)(;~~<t+'i.!$.·.i;,?.I. 

1<6'0 ~ .1'Y'v\\ {\ ~ . 

't\ e;Y\-Se-1 cl ~~~q 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

,,' i ,; """,""""""",, J ,I 
To: Nuclear Regulatory Commission

*Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt.to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name K\O j

Address T 0

I kL~1J,. 33h

Tk - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - k VOýL,,'I1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attemptito formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name KOJ± h'j 1(<A'/ t:5 , J 

~.,~ j 

=r-: 

( I 

r-I::: 

r:o~! 

I Address ~, 0 I ~ ("25 & - '00 :1 

oi : .... .1 

~""""o,r 

.00; '1 

: I 

,=J 
jk Ommn Buckeye

19OCT

•20, 0

• ~~3c USA -:,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

liflililliffillitillififillilliI

,"'\","\..)11' _\~r"i_'.~_~'-"-. . W·~ 

1\ S-r IJ i"l i;'Vcommon Buckeye 

£ 

, ,), 

,-::3 C

, USA 1- Mc"c 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

,,, ',/",,1.1.1 •• ',1,.',1 .. ,,11,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear. description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal. -

Instead, the NRC should focus on reevaluating its decision that

sh How land burial is adequate for depleted uranium disposal.

Address -.

S/...•47 49JiZ •i .. [. ? F..

-- ---U 7 7 - - -

, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevalu(i!.0g its decision that 

aJ

h How land burial is adequate for dePleted ..... ".~ranium di.s.poSal. 

()1Jfp-; ~ ---- ,-, 

anfr':f /U11!r L: ~'< 

Address ()"07 M~".&u~ 

: toca1r/kJ IY~ '8t2J)LL~~ : T I I 

I 

I 

i 

,---~--~-~--~---~------~-~-------~~-~-----~--~--------~--------

~ tlfU fry tI~ a)z~~, 

I 

I 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

lidl Illi I I I I ill I Ill I fill I I I I Id

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

1,,1,111"111,1,.1.1'11.1'1,11,1 
To: Nuclear Regulatory Commission -

Re: Depleted Uranium DisposaLR-ulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal. *

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name L( Lc, C" 

-Address

---- ---- -- ---- -- --- ---- -- -- - - --I s . - - -- -- - -- - - -

Lx}L~~6e~~JI44cZ ~•YQ,

-iN.)

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission ~\_: 

Re: Depleted Uranium DisposaLRulemaking ~" '\; 

Until the NRC is able to provide a clear desc,r~ptionoC~otheruniq'ue :,' 

waste streams," it must not attempt to formulate rules 'goveniing'theit :' -

disposal. I.: 

'" 

Instead, the NRC should focus on reevaluating its decision that 

shallow land burial is adequate for depleted uranium disposal. 

Name' K{)uL; (CLt?(?-'Jw,r 

, .1 

" , ilJ ,1 ... ·-

i''::::: 

f::~.~ 'j" 

~:-~ 

: . "~~"......... ~";t>. .' j /"--1 "., 7-1 ::z: ) :;[: 

i"'-) "0 {!.,: " -. ~I 

._------------------.,.----,-----------,----"-'----------""2----------~-

''V Co 
4. Mr. Rocky Carpender. 10 152 W. State St. 4 . -

. ... T _ _ _ _ _ il• _•

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

i I I if IN I I I 1 1 1 1 11 1 1 1 11 it I I I I Ij I I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i,l jill j 1II1 i ,1,,1,1,,/,1"11 i,l 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal.

Name 6 r, • 6 '-i

:Address . " 4/- c_,,-0 joJ S(~d~i~o, 9Th ....~

.... •CD

0"-

- - - - - - - - - - - - - - -

'.1 I

- ---------1 

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking I " 

I 

I 

: Until the NRC is able to provide a clear description of "other unique I " 

: waste streams," it must not attempt to formulate rules governing their 

: disposal. 

: Instead, the NRC should focus on reevaluating its decision that 

: shallow land burial is adequate for depleted uranium disposal. I G-i. -ri 

_ .r'~ " €..- '1Ii:\O~~ 

I 

jName ]) 0 r; ""-coL 

: Address CZ 2- ~1: I 

rOC? c-e'J~/1o ! Ib 

I 

I~---------------------------------------------------- ____________ ~ 

", " "' " 

\ . \. ''.. i \ , . \ ',\ 

',:./' 
.. . . .-.. ,.

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

..... D~r~~liif:1{;*;yw~¥2.~i~'L . q 1- Q 7- Wr(' 4< L, bo ",,-IJ.J.~, 

t'o ~dh ,s:D, fi3 "jc~.t:)y 

,I, 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
TO: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking '

Until the NRC is able to provide a clear description of,"othaer unique.

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its dkcision that _

shallow land burial is adequate for de],l ted uranium disposal. ,-

Name -At W ill4

AddressI

.9-rn s nCO

--- -- -- --- --- -- -- --- -- -- --- -- -- --- -- -- -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Dispo~_al Rule~aking 

. . .' . .' . .. . . ':':;:;:;;~~;;:~}~~~~l~' Until the NRC IS able to provIde a clear descnptIOn .ot""other~up~que 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on re~uating its:·abcision that~ shallow land burial is adequate for depleted uranium disposal. r:;; ~. ", ',.~".) c ,.. 

Name l"~~" ~~:EW~_·t'i'-~ Address ,1. 't'!.~o.~~'i ;\.q,~;'i~ 

\~\CI.\\\)~Q xb ~ • ••••• d I~~O 

---------------------: -------------------~ - --------------_.- ------~ 
~(~24WM p

.. ; 4APt --..

2

Chief, Rulemaking & Directives Branch

Division of Administrative Services

* Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

\<1. taWM • -no . . ,~-S~O 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

. Office of Administration 

U.S. NRC 

~. Mail Stop TWB 5BO 1M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking*

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their73-I disposal. 1". , - L I

Instead, the NRC should focus on reevaluating its decisioi that

shallow land burial is adequate for depleted uranium disp osal.

:Name ýNAcix-e

Address -

-- -- -- - -- - --

I. . . . . . . . . . . . . . . . . . . . . . . . .

To: Nuclear Regulatory Commission 

Re: Depleted Url¥1ium Disposal Rulemaking . . ~ . 

. ...... ~ 

Until the NRC is able to provide'a clear description of "other unique 

waste streams," it must not attempt to formulate rules gpyeming theiSJ 

disposal.' .-; S: JJ ....... ;.. r"TI -- (" rl 

~'--Tl ;:~::5 ~;:: Instead, the NRC should focus on reevaluating its decision that ti:l 

shallow land burial is adequate for depleted-rrium disp"'Qsal. ~~:, 

Name ro ~ .CJlR.~~ te, VS~~ ~;_ ;: ~§\ I; ,.~. " ," t. /. :~. ",.,,\," '9 ~:~; 

Address G (J S,' \) ~r\. ~ ~ ,~*t~J c:o 

~ 0 ~ ~.Q. ~\) <6) 7o--{ , I . 

. ,:. 

I _________________________________________________ ~--- ____________ _ 
Chiefu Ruaiking &Dire~tives8Býnc

Divisioi'of Administrative Services

Office of Administration

U.S. NRC

-Mail Stop TWB 5B01M

Washington, DC 20555-001

:cfiier,;kl!I~!ff~l&irt~ & tiir~9tiveS:Bfanch' -: ---

-D-ivisio11'of Administrative Services -

-Office of Administratio~ 

U.S. NRC 

-Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
I---

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating-its decision that

shallow land burial is adequate for depleted uranilum dispqsa1.

[Name ,Nrn ( I

jr..Q .....- 1-- • ..... 

Address .

1'P

- - - - - - - - - - - - - - - - - - - - - - - -,-- -•-- - - - - - - - - - - - -

-----------------------------------------------------------------, 

To: Nuclear Regulatory"Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

: Instead, the NRC should focus on reevaluating-its decision that 

: shallow land burial is adequate for depleted w:1i:ftium disposal. : I , ':;"~ 

: Name ~:2 \~1 1 1 

= 
* "c~*~-* '*'* P

* ~

'~O~"'~~

.Y* A"~ ~ /7'" .71< ~. C "~. ~-"~-__

.,r' -t-. ,~

'N /

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Ruiemaking

Until the NRC is able to provide a.clear description of "other unique

waste streams," it must not a ttemptto.formulate rules goyerning their

'disposal.

Instead, the NRC should focus on reevaluing its decision that

shallow land b -al is adequate foideplete ran -sposal.-- I:,,

.Name dj.....-

~Adre-ssa~ c 5

. A.. . . . . . . . . . . . . . . .

1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 1 '-~ .• 

: Re: Depleted Uranium Disposal Rulemaking I 

I 

I 

:UntiLtheNRC is able to provid~ a,c1t?~ qesctjpJion of "other unique_ 

. waste streams,". it must Qpfa1iemp~jQ{()iIhuhite rules go:y.erning their 

disposal" :·":'::"·.;:'c'.{:::;~,~i1~':::::,:_:;· ' . ~ e! 

Instead, the NRC should focus on ree~ai;~i~~"its deci~ion that fQ 

shallow lan~ b "al is ade~e fa dePI~~' man" "TsposaL-;:. 

Name L1 ~ .. , OJ' .:~ 

1 ______ -----------------------------------------------___________ _ 
- 0

o r"4I

~

Md~~

,.,~ -.

I C'

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

ill iIIiIII~ifI!Ii~lIiI~J~fIIJII

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission, -.-

Re: Depleted Uranium Disposal Ruleniaing

Untilthe NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their Jdisposal. .J .i:

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted -uanium disp6sal.

N am e . - ' [ - -'

C---

:Address S1 6 o~A

------------------------------------

----------- --- - --- - - - - - - - - - - - - - - - ----- - -,- -- --- - - - - - --- - --- - - - - ---

To: Nuclear Regulatory Commission"', 

Re: .' Depleted Uranium Disposal ~ Rule_i~g . . 

~;iir:j~}:":,:.~:::~~.;~;..~;.:·, .,,' 

Untilethe NRC'is able to provide a clear description of "other unique 

waste streams;>" it must not attempt to formulate rules gov~niing their I) 

disposal. J .... ) ;··;-.:i; ~~ -n ~ j I ('-' ''''-, :;:: Instead, the NRC should focus on reevaluating its decision that ;~I 

shallow land burial is adequate for depleted:.iliJnium disposal. . , ;~1~ 

Name Ch~2-- £y ~; re- /:Pi ~ "?:~ " ;;:~ 

Address )''-16 5~f~ 4,'h l4enlA~'7!/i ~ ~ 0; 

&a/~!o., [0 4520 I 

1 _____ ------------------------------------------------____________ _ 
'B TEI.) KIP~

C~ ~ .2 -') ,Z 14) 2 :L

5-q6 Ave Zv

i~oilChief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

;:ao!S:E;lo:~a37 '- . c ha 2:.:1t"l ..• &,tt: 2L"'Ctr.} Rf.i ·2· ·L 

0/65. C(fI./fve.Jl-tflq 

~1Jo~~o ti?)c?l r -

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

'"',11111,,1,1,,1,11,1,1,,,11,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the.NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating-its decision that

shallow land burial is adequate for depleted uFanium disposal.

:Name W

:Address 7 6) 0~- -. ,-

/CD

---------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the.NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. . 

':=0 

Instead, the NRC should focus on reevaluatin-g-its decision,that 

shallow ~ land burial is adequate for depleted ur~ium disp~~~l. -,;: ::8. j~ ~:)Q;Yh~ ! I'J/~ V\., I D 8J'Idj 

------------------------------------------------------------------
*~4s~s ~ ~ -~ * 09*;-~ -ZS37

-

)~-~ r

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

11,/,111 •• 1,111,1/.11,1,1, " il, I 

------------------~~ 
To: Nuclear Regulatory Commission

Re'Depleted - Uranium Disposal Rulemaking :" .

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluatingi',ts

shallow land burial is adequate for depleted uran-n

Name W&-"f--O • 

Address I -

ID

decisionithat

am disposal.

-0D

IC

II1'*~*>*'

in

'CI)

-----------------------------------------------------------------

1-----------------------------------------------------------------, 

: To: Nuclear Regulat-ory Commission : 

..• 1 Re:"I~epletedUraniwn Disposal Rulemaking ....,.-.. ;;" 1 

Until the NRC is able to provide a clear description of "other unique' 

waste streams," it must not attempt to formulate rules goveriring their 

disposal. . -, 

Instead, the NRC should focus on reevaluatiri]]ts decisiori:that 

shallow land burial is adequate for depleted Ui~iwn dispos~l. '--'" "":. 

Name KC l±rv.e(hV\g~f~ 

Address I L1 L \ S. Z < \J B:\}e I ~~ I 

',~::J ? oco.-b til> I \'1 ~320~ 

1 

VI 
"• T " 2 ,l P. , -1z. ':'÷ Jl A i -.

zq 21 2- rAw,1

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I1 I! J U1 ~ J ~I I5~J, I33£1131

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC. 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

·",1,111",,;, j "I,; "1,1,,,11,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted-uranium disposal. --.

~Name

Address I (7 -q•S I4- •c /•c/1 L 4 "

K•J c 0 rri

-,fZCD U-,'

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

---------------~-------------------------------------- -----------, 

To: Nuclear Regulatory Commission 

Re: Depleted ~.JI.anium Disposal Rulemaking 

, 

, 

, 

, 

, 

, 

, 

Until the NRC is able to provide a cleardesciiption of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. 

, 

Instead, the NRC should focus on reevaluating its decision that 

: shallow land burial is adequate for depleted-uranium dispqsal. : . -U 01 

:Name ~M.M.~ '-=- ( , . ~ "- , 

Address I '1"3 I~ ~ #=-~rJ 

~.. 

. ~~ 5;: 

-, 0."1)4 ~---,-- '!? ~-..-l 0 Cfc.fss I 'D 

:J" c.: r, 

r-"ili 

(./i~ 

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J ! r~:' .:'-.':, 

r:;'. c: 

:;: 

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, 

, 

, 

, 

, 

, 

, 1 ___ - __ -----------------------------------------------____________ _ 
3n CNIZ

T 2_ 

Chief, Rulemaking & Directives Branch

Division of Administrative Services

-Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

. Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted"uranium disposal.

,Name iii( L -\ .... A-oT

,Address(4 > _

To: Nuclear Regulatory Commission 

Re: Deplet~d, Uranium Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streams," it must not attempt to formulate rules governing their 

disposal. ; 

Instead, the NRC should focus on reevalua~~ its decision that 

1 shallow land burial is adequate for depleteo·hianium disP'bsal. 

Name~b !+Wo~~~ J 

, 

\Jl 

~ o. . ...• 

J- "" 

Address l D JS k: . t£ ~ T{jillC \:J 

~~+--e Q Q () (I): 2~:) 'D \ 

--t 

f~;: 

C'T' 

c./~· . ..... J 

<..J 

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-=.:::::. 

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, 

, 

, 

, 

, 

, 

, 

, 

, 1 _________________________________________________________________ _ 
*\ ~~4":2,T dw~y 

K

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

·~~ .. 2T 

YocO,.+dCb t'0: ~~dO \ 

Chief, Rulemaking & Directives Branch 

_ Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium.Disposal Rulemaking

Until the NRC is able to provide a clear description of "other unique

waste streams," it must not attempt to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land burial is adequate for depleted uranium disposal. i•

Ads•-

:Name

Address 'qC) WJ

I~~r i,\c•~t

To: Nuclear Regulatory Commission 

Re: Depleted Uranium.Disposal Rulemaking 

Until the NRC is able to provide a clear description of "other unique 

waste streanls," it must not attempt to formulate rules governing their 

disposal. 

Instead, the NRC should focus on reevaluating its decision t,hat x' 

shallow land burial is adequate for depleted urf1Q.ium disposal. :~ , ) InName ~;\ Gc,&JY\ ~f~ " .--~_~·ir 

Address =t aD ~_ 3 \h 

"v._WUW\~~~lt(;:."'" J It!.t·· ~l\ 1\ ~ ~ t:-e fnm 8?$~'~ J~rTI :::-:~ z : C?; 

'M.~~~~ It- CfJJI\- Nlt b.l J,ibp~ --~~-.------------------------j 
~~G~.a ILI,3

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

1 11 i II I I I I I f i I i I I I i I I I I 1 1 11 ! 11 ! I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

ii, i ,lII'l"i, i "II j IIII i II! Ii! I 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Until the NRC is able .tq..,provide a clear description of "other unique

waste streams," it mustnotattemrpt-to formulate rules governing their

disposal.

Instead, the NRC should focus on reevaluating its decision that

shallow land .brial is adequate for depleted uranium disposal.

Name..4 . C:

Address

-,.

' f t .,o-.:i

- -- -- -- -- -- ---- -- -- -- -- -.. -- • ----------,

, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

Until the NRC is able tQ,provide a 9Jear description of "other unique 

waste streams," it mustnotattemptto formulate rules governing their , 

disposal. :~ . ; / . ., 

Instead, the NRC should focus on reevaluating its decision that 

shallow land rial is adequate for depleted uranium disposal. 

Name 

Address 

j : i:. I! ; '.i'! ' 

, '. , 

, 

, 

-- ;~.T·l 

;::::::.1 -"'1 

U

n:, " 

, 

, 

, 
Nan cy tV~z4I 

442 S GarfielJ Ave

Pocatello, ID. 83204 . 41~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

ill il m 1.111 II \11 \111111 illl n Ii 
To: Nuclear Regulatory Commission

:Re: Depleted Uranium Disposal, Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing~disposal of depleted uranium and

disposal facilits have implemented those regulations.

Name 4/. - i

Address 6/0 7 6 cr/l --.

FT- : ,:- >

-- - - - - - - - - - - - - - -- - - - - - - -- - - - - - - ----- '

k,• c~r,

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal, Rulemaking . 

, 

, 

, 

, 

, 

, 

, 

I ... 

It is inappropriate to license any new uranium enrichment facility until' 

regulations are in.place governing, disposal of depleted uranium and 

disposal faciliti have implemented those regulations. 

Name Ilfrd~ L. A~ 

,......- ~ 

'''"- ::::z: ,-n 9? I I (=:J V1 

-.....J 
Bill & Susan Mauk

610 E Curling Dr ,

Boise, I]) 83702-1905

~045J83055125 1L 0r ý'CPL6A99

r-E RE-)

S10/19/2009

Wailed From 837O21ý\?-ý

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

1151!JIJJ I ,3i,11115i111311 1a1,i

~- ----. .... ;4 ~r.r,., .• ~._ - -- -- ___ ,.,.-----.-_ 

I' 

I

, ~ ~ ~ Bill & Susan Mauk 

(}("}C) 

~ 

610 E Curling Dr ' 

Boise, ID 83702-1905 - - - -._- ---

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i!li,H1lllli,I"hi"i,J",ii,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaklng

It is inappropriate to license any new uranium enrichment facility until,

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name <-t--•- (/. ,_Tf,-

Address

.......... • ~F ... f :-i

",,..j• kJ'lC/)ir

Fl'j

, 

, -.- . I 

I .. ' ... :. -.:- ,.,"",j.::.;:,,:,:.: ~:" I 

: It is inappropriate" toJicense any new uranium enriclunent facility until: 

: regulations are in place governing disposal of depleted uranium and : 

: disposal facilities have implemented those regulations. : , , , , 

'NamePd-er 

Address 'i77-- Co~ 

p~) 

r] 

---I 

\------) 

···'·"i 

9? 
PY - -. - . :1 . 4" *2" .~. ."*-

y?-i ~ -A.

~'K32cY

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TW" 5BO1M

Washington, DC 20555-001

-II II, III I ~I I31 ~I ~ III, I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I •• i .111 •••• 11' II hit 11.111111 II 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilities'have implemented those regulations.

Name Lc-C(01

Address / '

OC..'e((O g7' 9\O"

- .4

.........- -

.i " 21;.

I-----------~-----~=-~-------------------------------- ------------

: To: Nuclear Regulatory Commission I '. 

: Re: Depleted Uranium Disposal Rulemaking I 

I 

I 

: It is inappropriate to license any new uranium enrichment facility until 

: regulations are in place governing'disposal of depleted uranium and 

: disposal facilities~have implemented those regulations. 

lName ~~ LC(f}oJnj ,. 

/ 7 - C I. (!(~~e~ 12( 

ocQ1-e ((0 1[:) 8B~o0 ""'/-"1 ," ' .~, 

- -' .::::~ ;LI' I \..l.A ;::!) : ..... '~1 •• I 

,,-') .';;;'.; : __________________________________ ' ___ ' ________ .' __ ~ ~ ~ ~ _ I _. ~ ~ ______ ! 
iýV 't

A-iO

I-L)no 8 & .Qj

'~

-. 9

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB SBO1M

Washington, DC.20555-001

ialiIiIsiiIsIatIIIIuilIIII liii

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC.20555-001 

111111111111111 iIi rllllllllllill 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until;

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name_ ..

Address 8-- Al - ' .....

5- -.-------- ------

---~-------------------------~~------.---------------- ------------1 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking , " 

, 

, 

, 

, 

, 

" , : ..... . : 

It is inappropriate to license any new uranium enrichment facility until: 

regulations are in place governing disposal of depleted uranium and : 

disposal facilities have implemented those regulations. ' 

"'-i 

•.• ".)., •• .,.1 

1 ! Name 9!:~--

Address g--<g <# 'l.- N (he, oV ... , __ ;u i '/2 'i 

{at:...- 7:.A? :... .... 
-e \ 6Vo 

8j

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

11,1,111111,111,1111"1,1,,,11,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

, regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name 6 /,r - r'•// 7

Address /7__. ______-_

--- F--

CD)

- - - - - - - - - - - - - - - - - - - - - ---- - - - - - - - - - - - - - - - -

in.j• o

------~----------------------------------------------- -----------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemakirig 

, 

, 

, ",:" I 

":::;:.:;' :."~:. -'( ~".'''''''" .. "~ 

"."'~" i " I" .~ .. ;~; .... ~ 

""" : J'-~~.::~ : .. ~,:~:~ :,,;: ...... 

It is inappropriate to license any new uranium enrichment facilitylilitil';" 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name ~6F1tt/try 

Address IJa;. N·IDt1tS1: __ ~IJ""T"""'--

~ ie.-I D BS-tf) ~ ,,~:Lj \ I ,-,} 

-- ~?,. "'- ~ 

oTj 'f? :----, 

\.......) VI 

C) 

, 1 ______ -----------------------------------------------____________ _ 
fE-3SE Tr) ~3

Chief, Rulemaking & Directives Branch

---Division of Administrative-Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I! 11 ill

Chief, Rulemaking & Directives Branch 

Division of Administrative-Services ~----- - Office of Administration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium • i

disposal failities have implemented those regulations

Namem n __1 T let.y 7

CD'

Address. - - a ) -_ ••',:

gg FT".

~. ~.. '~ :~;~ 

I--~~---------------------------'--------~-~---------- --------------

i To: Nuclear-Regulatory Commission 

1 Re: Depleted Uranium Disposal Rulemaking 

I 

, 

I 

, 

.. .. i .~ -. 

It is iriappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uraniWdum 

disposal facilities have implemented those regulations. ff) I ,\ Il.! 

f1I ( r,). OJ~ut- . t.~1 

Name 1Ut.1k'C{ ~ Y1 -r ctt-t I e~ · . ~ ~ 

Address ? -[) ~ ~ D><- ~ 1-s--S 1 ,:~.'l 

\ 

--! U-,J, 1 

,-- l~-1 Ib:L?~~c(~9 .~ .'," ~;~l 

i-Tl 

~r '3 -t ~9 ~~: VI 0:' -J CJ 
-F '7~ - ? ' "

rn .d.• ,,. ., .,, .- , gUN:,•*

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B0iM

Washington, DC 20555-001

III [I fill H! III If If h! If If I I HII

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration ---- U.S. NRC 

Mail Stop TWB 5 i30 j M 

Washington, DC 20555-00\ 
To: Nuclear Regulatory Commission < (/ 26%,

Re: Depleted Uranium Disposal Rulemaking.

It is inaplfopriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those re-guations.

Name -. ' -

2....V

r

EJI

: ----------------------------------------------------------------- i

- - - --- - - - - - --- ---- - - - - - - - - -::.- - - - - - - ---- - -.- ~.-: - - -:.-: - ~ .. -;:?--- - --- - - - - - ---

To: Nuclear Regulatory Commission '.. . v'd, 1t1; 2~ 

Re: DepletegJJranium Disp.osal. Rulemaking. '. " . " ,.,:", ..... ',." ~ I:. '. '~~.:'. 

It is inappropriate to license any new uranium enrichment facility until 

regulations ~ i!!..1?lace governing disposal of depleted uranium and 

disposal f~Cilities have implemented those regulatIOns. ----

- Name ~,~ 
171 20~3K

~818

Chief, Rulemaking & Directives Branch

Division of Administrative Services- -

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services- - ---

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

~Name j

Address \(4A -QA.Q( >

I Px~e<~S370

c-I

f -~I

C., I

----------------------------------------------------------------

Tg:Nuclear Regulatory Commissign 

Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name ~ ~\ <&--. Q 

:JIJ 

0:: r,' 

n"'l 

(.II; 

--' 

~~:, 

l.~) , 

C' 

~7'1 

EiJ 

I... .J 

f:::?;: 

(/;, , 

, 

, 

, 

, 

, 

, 

, ------------------------------------------------------------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

-Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

--Office of Administration 

u.S. NRC 

Mail Stop TWB 580 I M 

Washington, DC 20555-001 

ill i! Ii Iii! Ii, 1, ,i, ii II ill!, II Ii 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations-are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name . / --4-'

Address "17 62" kV

-I0

---------- - -- -- -- -- - -- -- -- -- -- - -- -- -- -- -

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

, 

, 

, 

, 

, , , 

, 

, It is inappropriate to license any new uranium enrichment facility until' 

regulation~'are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

:::ss ~k~ ~:v.~~JJ~ 5oi~e 1{)~3t,D0 =1 

tTl 

,--, 

'''-"' 

, ------------------------------------------------------------------
- .~1 -8

Chief, Rulemaking & Directives Branch

-Division.of.Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

." . _Division.G£,..Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

LName \ 14/7 u'" rn

,"-0

Address-. / • ... . =.,

67r'

-Tc/I

~I9 I

-----------------------------------------------------------------. 

To: Nuclear Regulatory Commission 

Re:. Depl~ted Uranium Disposal Rulemaking 

, 

, 

, 

, 

, 

" , . . . . I 

It is inappropriate to license any new uranium enrichment facility uritil :'\ 

regulations are in place governing disposal of depleted uranium and : 

disposal facilities have implemented those regulations. : 

, 

Name 08hVl "7YrPr7~ 

Address ::< Y {~ t11.:£ -• V ( -U-~ "-ID:> V I - -' 

?:(~.~ ~ / To r ............. -.. 

il 

0 

, J 

, .:) 

'9 

.t:: 

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, 

, 
Lu ~ ~'%28j

Chief, Rulemaking & Directives Branch

_,Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

- I -, H N I H-111iffILINITHIIII

t-;F' ,,~ . ;:., .. "..,;-.:: 

Chief, Rulemaking & Directives Branch 

__ .. ___ . __ Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

Illi I mil!! i ! ill i I ill f! lil/flil 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulationsare in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name c:,

Address, -

/-- .

71;l

"U , ! -----

To: Nuclear Regulatory Commission. 

Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations'are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name <:::::. '" ...<1 " 1~' _ ~ ~,\l \ ',,", ~. ~ \1..... _ \. .. q" i,i ,,1'--..... c:"'< :. l .-3. t," " l, \ 

w . ~ J 

... 0 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To- Ntc9lear Regulatory Commission

:.Re: Depleted Uranium Disposal Rulemaking "

It is:inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations. I

N am eC '-

Address $Ii/ RA (• i ... C..gt' e /" , '- ":9•,- I

c~se jL ~ L yj -r 0-

- - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - 

1------------------------------------------------------------------

: To; NU9.lear Regulatory Commission 

':.Re: DepletedUranium Disposal Rulemaking :-: .'. ....... /..,. 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations., 

Name 

Address 

!T] GO ...... -........ 

- ) "r"1 

, 

L.J 

1 ______ -----------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

iS~lEIiI~I~!h Jill III 3*

Chief, Rulemaking & Directives Branch 

Division of Administrative Servic.es 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re. Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

ýName (

C: Address , 62.,.:-'i K""

0t0

ILI

To: Nucl~ar Regl.llatory Commission 

Re-: Depleted Uranill,lll Disposal Rulemaking 

It is inapprqpriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Nrune 67r4:~~~ Address riZo () Lf;!/, J l 

i50p>p :7 ,rL <OJ D 

---_.:.....: ?~ ~ 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

II,i,lii! Illf, i, ,1,1111 i illlli,i 
To: Nuclear Regulatory Commission

k6De:ýl16ted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name TR

Address .-• 

-n-i

Co

I-------------------------------------~--------------- ------------

: To: N~clear Regulatory Commission , I., '. '~.:o--. 

::;"H~\~~pleted Uranium Disposal Rulemaking __ .I.:;V 

" 

, 

: It IS inappropriate to license any new uranium enrichment facility until , 

: regulations are in place governing disposal of depleted uranium and 

'disposal facilities have implemented those regulations. 

Name~ ~ 

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'-I \.......; 

co 
-47 7.

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41

Chief, Rulemaking & Directives Branch

_ Diyision of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

_Diyision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

" It is inappropriate to license any new uranium enrichment facility until !regulations are in place governing disposal of depleted uranium and

disposal cilities have implemented those regulations.

,Name _. J 4~Tj .I..

Address 60 ik.....

t.AJ =.a - -

7 D• •- :-

COr

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1------------------------------------------------------------------

: To: Nuclear Regulatory Commission , 

: Re: Depleted Uranium Disposal Rulemaking , , (L. .I .... ~· 

, "',. :h is inappropriate to license any new uranium enrichment facility until , 

',regulations are in phlce governing disposal of depleted uranium and 

disposal f: cilities have implemented those regulations . 

Name . -::sc h --,-1 .', 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

-Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

JI 3313111 J I I I31 IIIlI 51 I,?,J~

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

-oOfficeof Administration 

U.S. NRC 

Mail Stop TWB 5 BO 1 M 

Washington, DC 20555-001 

ill i ,i ii "II i Ii II i,i I! iii III ii Ii 
To, ,Nuclear Regulatory Commission

'FRe: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations. ,i 3 _73:

IName &zC4 LCXe -17

-- -- - -- - ----- -- -- -- -- -- -- -- -- -- -- -- -- -- --

Address -,.--.,---

I _ _ _ _ _ _ __ _ _ _ _ _ _ _ (mlI

·-----------------------------------------------------------------

: To.: Nuclear Regulatory Commission I·· ... '". . 

Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

(7 JJ; Name Luzict(~t1@6 Mev(/"' "~ ",-CO 

Address /5Locc& Warv' .~ 

i!2re :lt2 ~ 7th ~S; 

. 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

iiiiiihiihiisIILbdalliidid

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and.

disposal facilities have implemented those regulations.

.Name___

Address ."jc ' ( - "T -- ..

-ote rc.I --.- I

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----------- --- - - -.::~':. ~ ---------------------------------- --- - - - - - - -, 

To: NuClear Regulatory Commission 

Re: Depleted Uranium Disposal Rule:r.naking 

, 

, 

, 

, 

, 

, 

, . , It is inappropriate to license any new uranium enrichment facility until' 

regulations are in place governing disposal of depleted uranium and. 

disposal facilities have implemented those regulations. 

Name 

Address 

, 

7 , , u.1 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

l I IIII Ji,, ili i,, a i,,,ll~i

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i "I! III! 11 ii ,I, Ii, ii, i! i 11111,1 
To: Nuclear Regulatory Commission

:,.,Re: Depleted Uranium Disposal Rulemaking -I

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

:NameN\ _

Address v:>0 4 73

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- I

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1-----------------------------------------------------------------1 

: To: N4clear Regulatory Commission : 1 ,.... 1 

~.-_..",:Re: Depleted Uranium Disposal Rulemaking , ':1'" : , , , , , .. . It is inappropriate to license any new uranium enrichment facility until' 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name IV\O-.N ~ ~~ 

, 

.... ·,1 

~- ......... 

,rl 

"-'I o 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i., j I iii ,",i .1111. j., i, i 11,11,1 
To: Nucelar Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

it is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Address D Q['.-3-h..

'.:-0• . 'i 

i-i"1 -o -- k i • -r'

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---- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- -

1-----------------------------------------------------------------

: To: Nuc1ear Regulatory Commission I 

. : Re: Depleted Uranium Disposal Rulemaking 

";::~::~:;:'~~~":,.. .,. 

·;c ,1'Ifis inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name ~n e G heeV\ J:Po6 t "" 

; I ! ,_~) 

Address .,:z I n"3 ;J ( I q --/1) <:3-=71- ~ .".::~ 0... 11 w 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i, ,I! ii I II "I, i ,,1,1,:1 ,I.!, i i ,I 
- - - - - - - - - - - - - - - - - - - - - - - - - I!-- - - - -

To: Nuclear.Rcgulatory Commission - Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal faciliti*s have im lemented those regulations.

Name & jj

Address ZI (

-I 7

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear,R~gulatory Commission .... 

Re: Depleted Uranium Disposal Rulemaking" . 

"><,.".,,,. 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in placegoveming disposal of depleted uranium and 

disposal facili~s have ~lemented t?ose "~egUlations .. _: 

Name Q~ / JJ "-> 

1 ~-i' is aJVYY1" '0; c:;;/. 

(j) '637?r r; f :'Tl........... '9 

Address Z. / ( 

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o 
SEIIS 10'-37

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
- - - - - - - - - - - - - - - - - - - - - - - - - - ---- 7. -- - -

To: Nuclear Regulat6oy Commission

-: Re:-Depleted Uranium Disposal Rulemaking I .1

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

:Name /_ / ./v2 sef?

Address /65 L•K5cZ_.-'

'V..]

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1- - - - - - - --- - - - - - - - - - :-'~ - --- - --- - --- - - - - - - - - - --- - --- - --- - - - - - ~ - - ---

: To: Nuclear Regulato'fy Commission , . 

,'Re:-Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name b1ohl1 -rit:J17? s~n . 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

JIIIfIIIlaIIiII!fJIJIfIIJIfII*I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

-,Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name e -i2 r,

Address / 6 77 46/1 . e

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----------------------------------- I -------------------------------

1- - - --- - - - - - --- - --- ~-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - --

: To: NlJclear Regulatory Commission~' -.",', ' -.. -

-~ : Re: Depleted Uranium Disposal Rulemaking , 

" 

, 

: It is inappropriate to license any new uranium enrichment facility until , 

.' regulations are in place governing disposal of depleted uraniUm and 

disposal fa:cilities have implemented those regulations. 

]J 

Name ~ t='A/G Erner..m,,-; ,on 

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Address ) ~ (; 7 W, ?arOJee:glf. ~ --'"'' 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

"Re'cý)epleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and ,

disposal facilities have implemented those regulations.

Name G:f,... .

Address :> -TQ. .-. 

I -.OU-J D - - - - -- - - - - - - - - ----

I-------------~--------------------------------------- ------------, 

: To: Nu~lear Regulatory Cominission" . : I .... " I 

~Re;;J.)epleted Uranium Disposal Rulemaking : ~~::.:~~~.. . : 

, It is inappropriate to license any new uranium enrichment facility until: 

regulations are in place governing disposal of depleted uranium and::g 

disposal facilities have implemented those regulations. . , : ::~:~, -··7-'1 : .:./) 

Name E LLGJI) JOWG-S-) , .. , :.':~' ~=--------------~'-"''-- ,-_ .. ' ..••. , r--- W , .. , 

Address 3( 0& W IQE::o-t-~GJRL :"i,~ ::..===------=----------::s..,_,,- :.:) 

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QSOJS,2 ;r: 62103 ~ ~ :~ 
CAISE I CY ,5

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

hIlI 111k II 31 II I £131 Iii 3133 £11 aI

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i! ,i,IIII" ,l,l"i I i II I ,I, f ,il,i 
To: Nuclear Regulatory Commission'.

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

~NarneQ 4 6JYJ). } A1

Address 1 ..

-WI

k,.,r'' T1J

1-----------------------------------------------------------------

: To: Nuclear RegulatJ'ry Commissiol'i. . . '.~ 1 ',;:" 

. Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name B u 1 e, .,,, ~ pt,Ji) d I, ~~ p ey> R~ +1, 

Address I k 15 ~ 11 f ~.~~ I 

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7~T Of P~2 T

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

hShIlIfIll .11111hillififfiIIII

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

I; Ii! 111,11111111 iii II j 111111/ II 
- - - - - - - -

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate, to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

:Name I-1"] r( fqv&:

Address 4W.' aa.... .....

13

----- ---- - - - - - -- - - - - - - - -- - - - - - - - - - - -

•. =,,:\ 

---------------------------.---------------:-----~---- ------------, 

To: Nuclear Regulatory Commission : 

I 

Re: Depleted Uranium Disposal Rulemaking ~, : 

It is inappropriate,to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities hav.e implemented those regulations. 

~k 

~ ,,. 

Name H/{lIt~q 1l ~. ,_"I 

~ 

{(J{G AI. o-~cI ~r' Address "-") 1 ", ,-.j ''\"'1 

IS/iL, ±b K~ ZdQ. 1 ...... ",.-' ___ z::: 

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28

Chief, Rulemaking & Directives Branch

Division- of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division· of Administrative Services 

----. ---'Office of Administration 

U.S. NRC 

Mail Stop TWB 5 BO 1 M 

Washington, DC 20555-001 

I,! I,ll ililli ,I! I j ,/" i, i", ii, I 
To: Nuclear-Ri'ulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name "V I'

Address ( ( '- 0 •\

Qd j; t 4 f-:

-- - --- ,--- - -

4:c:

To: Nuclear-"Reguiatory Commission ' .. Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any Qew uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have impl~Jnented those regulations. 

Name J ~ Co y j IV eJ 5 (7Vl -xJ 

Address 

I ' 

I I .. ---) 

• .1 
(NA1. 1 0 2 T

lip,

281

Chief, Rulemaking & Directives Branch

Division of Administrative Services

--Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Adntinistrative Services 

--Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re-:Depleted Uranium Disposal-Rulemaking

It is inappropriate to license any. new uranium enrichment facility until

,regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

(/I T

~Name' ;Narne A ::: ,.

Address CA h) 1 - k:\ 

•" I-1"

To: Nuclear Regulatory Commission 

Re:--Depleted Uranium Disposa.1Rulemaking , • - • : ',':"~ ,. :~;' :. : <.. ': I . 

'. -'"It: 

It Is inappropriate to 11~;~~~~Y ne~:-urani~ enrichment facility until 

rregulations are in place governing disposal of depleted uranium and 

disposal facilities have implement~d those r.egplations. 

:{~ Name ~d\L!]):OU.2 tAJ6dl}~ '::11 

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Address II C:. "1t-., Tf"-.Ilq \ .~. ~ 

~I~ t ~ '75~11t~ CJ 

.. ~ 
ID ~S3~

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

." ~~;: ".: ''''.t,-,,\ • •• ' 

~-----=~~~~~ .26;()·CX'.2.0l19 J::-·M1. L 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

"disposal facilities have implemented those regulations.

Name f--;V1 M ',

Address {-a- ' / •r

--- - -

1------------------------------------------------------------------

: To: Nuclear Regulatory Commission 

" , 

,: Re: Depl~ted Uranium Disposal Rulemaking , 

, 

, 

: It is inappropriate to license any new uranium enrichment facility until , 

: regulations are in place governing disposal of depleted uranium and 

-l-disposal facilities have implemented those regulations. ' 

l' L II ( .r =-0 . ,~ 8 

'Name nf) V1 -f1U Y v~ ~ t51 

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Ný Pit : 'C *2 '

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I! I i"uu ul " "

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

--U.S. NRC 

Mail Stop TWB 5801 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission :Re: Depleted.Uraniumý Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name" I"x I F (EG -S -

:Address ( 0 CIA (_,Cr (.

rnI

- - --- j

,-----------------------------------------------------------------

: To: Nuclear Regulatory Commissicm , ~. '. 

'Re: DepletedUraplUlnDisposal ... Rulemaking .. ~ .. . ~ 

',-, •. ~._;..J:" 

. ~,. .,.. .. 

It is inappropriate to license any new Uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name:]) IXI£ SiEGEL. -n , , 

-.~ 

.• 1 

Address 00'3 0 G "\.&2 (e U-J t? £?~I~C2 lL (.e~ ~,.,:., I 

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6*0'tsk.ý'- ruý-In7 " *

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

III Jill ~ LIdS Iifli!bJSfli!i

-

Chief, Rulemaking & Directives Branch 

Division of Administrative Servic~s . 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate .to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities -have implemented those regulations.

Name )

Address S{i " " '2( t

i----

i•"-"lff1

-0z

To: Nuclear Regulatory Co~ission 

Re:.Depl~ted U:fanium Disposal Rulerriaking ~. " . 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities -have implemented those _regulations. 

Name 

Address . , 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

if I I I III I I I I I I I If if if I it it I I ild

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Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

'111, /II. " , i ,I" iii 'I j ,I. " iI,l 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

:disposal facilities have implemented those regulations.

Z0j

:Name .- T

Clj

Address /cY4t -/I. -t r-v ,.etj ••:a:-.,

9 nil

X.J=

- - - - - -- - - - - - - - -- - - - - -- --- -- -- --- -- -. -- - ...-- ,

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking '. .' '~' ... .. \ . t., 

It is inappropriate to license any new ~anium enrichment facility,until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

I"] 

Name S 1 ~,~,v .::h ::-J 

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r-o-i 

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i ------------------------------------------------------------------
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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I! ItJ II,1~ I ~ Il I III Ii I! it ~, WI

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

. i II il i Ii I II i ii I IIII1I1II i III jj Ii 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name L-4 T- . .- i-i

Address o / Sr "

I"~ / 8S76i2ci,"" -

rq

- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commissior,t. '" ._ 

Re: Depleted Uranium Disposal Rulemaking 

, -

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name C/tMt e&l-Mlfll-&:' . /----"1 

Address 1£1) ZAJ () fifth (qt:-:~ 11 

,f;()/gf!- (0 88Zd~ 
ITf)

Anýae nzz'ýChief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

".-,-. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i 1,',lil""i,'"i,i"i,I"lll,l 
To: Nuclear Regulatory Commission

:Re: Depleted Uranium Disposal Rulemaking '

I It is ina'ppropriate to license any new'uranium enrichmentfacility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations ..

Address 0i.

/ f ,I

- -u-- -- - - -

I----------------------------~--~~--~----·~~~·~------------------~~~ 

.: To: Nuclear R~g'i.tlatory Commission I 

: Re: Depleted Uranium Disposal Ruleriiaking· I 

I.. . '.;. ... '.~,. 

It is·inippropriate to license any new'uranium enrichmenrfacilitY until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have im~~lre~Ulations .. _~ I ••.. J 

,_j; -v. -- ' .. -.:0 

Name ~'-'/~ ~5 

Address I ~? 0 JJ '7 ~ Sci 

ieJ(SP-1 r ; /1()~:~37~)· 'I 'Oc.... 

o .~ \"'.1 

---, 
IT) ~3'7

Chief, Rulemaking & Directives Branch

Division of-Administrative Services

-_Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I,1!,iI ,, i f i , h !£if3 I ,f filli

Chief, Rulemaking & Directives Branch 

Division oLAdministrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I,ll, i IIII11 i,i f I i,i II i, i I! I iii i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is ihippropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uraniunm and

disposal facilities have im mented those regulations.

Name n` tu 'Ic 

Address

m/ 8-7o'

------- - - ••.• •_/)

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemakihg 

It is inappropriate to license any ~~w uranium enric~entfadlity until 

regulations are in place governing disposal of depleted uranium and 

disposal facili,ties have imPlmented those regulations. 

Name /1!0 ~Jle// cT0\~ ~.; ~l Address ~--2 I 8 ~ t:ie /J'}(i _.. 

v~ 1 _:. .. ~_:~~:. T'· ,. , 11 I.JJ ~ '-,." • 

. ~(JI KID 8:~ 7 0 ~: ".;~~.~!-! 

p. P'S rJWVZe1 lfv U-c.v!~ ~ ~vw t ~ U1f-I'. --f-oy:fL 1;0 t - C~Jt~ ! 

«J-~--~-i-c_'Fb:r_l--rn-hl1T~-fo£t1~ 
T

OW-,

....

Chief, Rulemaking & Directives Branch

Division of Administrative-Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

'-""-..1",, 

Chief, Ruiemaking & Directives Branch 

Division of AdmiIlistratiNe-Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO i M 

Washington, DC 20555-001 

! 
- - - --- - - -- -- ---- ----.. . - . -. - ---- ---- --- --- ---- --- ---- --- ---- -- -- -.

To: Nuclear Regulatory Commission

Re; Depleted Uranium Disposal Rulemaking .

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented t-oser iulat, ns.

~NameA/

C1

Address / 55 :3 [

C.,

-- - - - - - - - - - - - - - - - - - - -

--- --, - - --- - --.;. - - - - - . - - - - - - -,_-.-- --------------------------- --- - --- - - --

To:: Nuclear Regulatory Commission 

Re;_-Depleted Uranium DisP9sai Rulem~ing }' :~'\'. :.'!- " .. " 

It is inappropriate to license any new urani~ end~hment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented ,~,.,ns. . , 

Name z;k;\A~btt Address /25'5'3 W> Wr::2Fl:;J:; ~~).+D ~3 t d$ ~ ...... --.... ::z: 

'" , } 

~; 

,n '9 

o 
',)B k7%j- ., *Tj.".) ýEl

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Ill IIh i~1. II! i~b lid

... ' 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO I M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place goveming~disposal of depleteduranium and.-,

'disposal facilities have implemented those regUlations. Fri

Name l"- .. ,A.7,

Address C2; 2F 

IV O -,jL 

. I-I

.1

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place govemingTdisposal of depleted.ur~ium and"":R' 

'disposal facilities have implemented those regiilations. ,,~; ~:~l 

"ft ~I Aln rJ /\ ~ t,sstuM '~J ~ :i~~ ,J' tovvuu '- ""I ~ . i::. 

?O ; ~O)( ~q -r~ -~~~ . ,';' ) !l~; 

tekh\N\l\ ,-::c\)'-~~ '11 ". I. ~ V1 ~ 

Name 

Address 

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I 

I 

1 ______________________________ . ___________________________________ _ I 
PM~0

\LL~tA~A/V- -OCT #TS)

ItPrei

Collect S' amr

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

" .1.. ... 

:.1 i i.1 ic . 

. C.:1l Prc~ .. j. 

1 C(lilcct SI <1m . I· 

.. '. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

.. Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

1,,111111111111111111.1.111111.1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name tI ri- -

-'I'7

Address (Y•,9 f. ....... 

• .- NO •3 

------ ------ - - -- - - -- - --- --- -- - -- -- --- -- - -- -- - -- ---

To:' Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking . ~ .. , 

It is inappropriate to license any new w-anium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name TJ 

"n 

Address r .. ,,) 

8m&e J If) I 

" } ~~:, 

";1' 

:;:"~'I c·, ., n;.: 

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, 

I 

, 

, 

, 

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, 1 _____________________________________________________ ____________ ~ 
2~ ocr :~c~c~ ~'M :~. L

28j

Chief, Rulemaking & Directives Branch

Division of Adminiqistrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

IIiJISI 1! l, I .Ini

Chief, Rulemaking & Directives Branch 

Division of Adf!1jni~tratiye Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5 BO 1 M 

Washington, DC 20555-001 

I! II! III! II Ii Ii! IiI ill j ,/,111 iIi 
To-.:Nuclear Regulatory Commission !

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:,, 6.

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name /.h -

Address e err L/ L-.q--

CJO ----

m

-----------------------------------------------------------------1 

TO;-"l;l\Iuc1ear Regulatory Commission·. 

Re: Depleted Uranium Disposal Rulemaking 

1 

1 

1 

1 

1 

;1~;..· .. ,'tfff...;.' 

• • • 01_ • : ; ~t>.',it: ' ;t! 

It is inappropriate to license any new uranium enrichment facility untill-","? .. 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name ]?'J. ~h~ &D~ 

Address ~S (! berr L/. L -If.p 

80 15 ~1 /J) ( itt/)5 ) ...... . 

LA) .'.- "--...... "'n 

i::J 

;!;I 

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n: ---/ 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

il,l, ill,!" I, i Ilil i, ,1,1'1' Ii ,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking.

It is inapprophiate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

:Address _ - 'to,, "-

jYQ .- --- 'I

NO -4

M-1 ------------- -- ---- --- --- - -- -- --- -- -- - --- --- -- -- ---

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking . 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name~~ " 

, 

\ 

<.,1 

::0 

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(J) 

I 

I 

I 

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1 

1 

_________________________________________________________________ J .1 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

* Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

. Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i" i! Iii 111 , iii II iii I ! i ,I, I Iii I I 
To: Nu•tkek Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

:It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted ur"anium and

disposal facilities have implemented those regulations.

LName

Address S 7 Ai

... -I.

7-/

4Z14

- - - - - -- - - -- - - - -- - - - - - - - - - - -- - - - -- - - -

-----------------------------------------------------------------. 1 

1 

1 

1 

1 

:"-"'''''';:'. 

To: Nbo'f'kar Regulatory Commission 

Re: Depleted Uraniu?J)?ispos~1 Rulemaking 

'Hm.'! ,. I :fl:'I!#1I 

It isinappI'opriat~ to li<;ense any new uranium enrichment facility until :",:",,\;: 

regulations are in place governing disposal of deprded uranium and :.,. 

: ~i"\'i\.'-: 

disposal facilities have implemented those regulations. 1 i.·J.,. 

111 - - \..~ If : 

Name VV ILLlA-M.\J I J \\ ( T=':';:'"fj1 ~ ~i; 

Address I ( (6 S I . S4-lI25/0fC£,--Y:=::~/t'-t'-- . ~~1' 

A1ttl7>l.-rJ liIrtm ~~,[ ~ (~i,: i"'n _I 

(-7 ':9 ~l '--" v.) (fj 

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• 1 

1 

1 

1 , 1 1 _____ ------------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate'to license any new uranium enrichment facility until:

regulations are in place governing-disposal of depleted uranium and -

disposal facilities have implemented those regulations ,. -.

Name , ..- .

Address

I

- - - - - - - - - -- -. . . . ..-- - - - -"i •-- 

........ ) -:9 (

1A )

1-----------------------------------------------------------------

: To: Nuclear Regulatory C,ommission 

: Re: Depleted Uranium Disposal Rulemaking , . , 

" It is inappropriate 'to license any new uranium enrichment facility until 

regulations are in place governing ·disposal of depleted uranium and . 

disposal facilities have implemented those regulatiop~.; . 

Name ~]1e?~;';,", , 

~A=dd:=;re=s==-s ---4r_o_b¥~. S ~ ~ t:t ,_,.t " .. 'J ,"- '.' ,}; 

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PML~ /

29 OC T

2 0 P.,.

---------------

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

/ 

Chief, Rulemaking & Directives Branch 

Division of Administrative Service~ 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
- - - - - - - - - -~---- - --- - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place-governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

:Name

.4J

Address l"• si• , A4- - . I tcli C."

- I .-:9

7):'

--- --- - - - ----- - - - - - - - --,~-,-.."...--.,:::- ---- -- - - --- - - - - - - - - - - - - - -- - - --- - --

To: Nuclear Regulatory Conimission 

Re: Depleted Uranium Disposal Rulemaking 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place-governing disposal of depleted uranium and 

disposal ~acilities have implemented those regulations. 

:f~.~;t. ',' c _,'<fA >~'~':-""'~/?> Name l\ ~ 't \'\{ .• 'M' "'~:- \", A (; tt.l(.",,~- :~ ..;~ 

Address J fi !)~ r(L, 

1 _________________________________________________________________ _ I 
cAc7r, '2YL-nia, 2- "T.- - 4"~rn~

28j~

Chief, Rulemaking & Directives Branch

.uivision of Administrative Services.. -

-Office 6f Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Div!<;ion of Administrative SeJy:ices.- ----

'-Office of Ad-ministration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
tTo: NuclearRegUlatory Commission

Re: Depleted Uranium'Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented tihose regulations.

,• "._l,] <.::, I:

Name ,¢I j " - f.

Address 4 I & ''

;Z0 -2'

- - - - - - - - - - - - - - - - - - - - - -

! . . . . . . . . . .

I--------~-----------------~--------------------------- -----------

·h'o: Nuclea.rRegulatoryCommission 

Re: Depleted UraniumJ~isposal Rulemaking '. . "'."' ,,' . \ 

Address / tic!? /1/ \ 

v' 

- .1 

1 

1 

1 

1 

1 

1 

1 1 ______ -----------------------------------------------____________ _ 
&~PT. 28J e

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

hi hlih,,,.11ih~ i,, IIh if,,i1,

(

. ';B<t):lSE:i.1f~L!.1,~;;~i7 

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§!&/u J:;J tgJ7-d 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i"i,IIIII.I,I,llllllllllillll'll 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until

regulationsare in place governing disposal of depleted uranium and

disposal facilities have implemented those reg&lations. vL 

.- .... 

r-1n

m ---- l -r -'i ---• --- -- ---- .. 7 7- 7 . . . 7 " 1. 

.... j -, _V'

:A Q Q ddress . C "• .. !'.3 , •k-•c k l .. .Al Q _ .... : ...... ,•::,-..__-":,•

To: Nuclear Regulatory Commission 

Re: Depleted UraniUm Disposal Rulemaking 

It is inappropriate to license any n~~ uranium enrichment facility until 

regulations "are in place governing disposal of depleted urani~ and 

I disposal facilities have implemented those reg!i!Ittions., 
OCIVS117 ý-' wl -S3 7' -, ..

.. ~. T

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

J, .I,/h,,Ji, ,i, hh h,,JhII 1fId

'""! ";'.; . i : 

Chief, Rulemaking & Directives Branch 

Division of Administrative' Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

: :.:" . , ., I ~ )'"' _ '. 

.' j; I J! iii 1111 i, i I; i,' II /,1", ill I l:,' 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any-new uranium enrichment facility until

regulations are in place governing disposal of depleted uranium and ;P

disp .iities have implemented those rpgulations..

:Name Ii•14 9 vak I:, -.- - 1 j: I .... .S"

AddressO C i d v rc Io.1f 1lA; -d IC >

i75_5

--------------------------------------------------------------

I-~---------------------------------~-~--~------------------------

: To: Nuclear Regulatory Commission 

1 Re: Depleted Uranium Disposal Rulemaking 

.1 

1 

1 

1 

1 

1 

1 

Iris imippropriate to license any-new uranium enrichment facility until 

regulations are in place governing disposal of depleted ur~um and ~: 

disp~ilities have im lemented those r~gulations. -2~ r~: . "]-1 0 .• J .. ~t;' ..... _~ .. ~I ... 

\ 

~;~ ( I~J, 

Name a C- Ce v Jr ~-r<-)';~~~~f'. 1 t - " '~2:: {-::-.l 

Address ~ C 0l-1 d 0 V C IVC ((/,:.(~\ ~ q~ ~!:~~;, 

~O,'S{> Ida i1(l. ~57tfA ; 'f~ ;-:J' 

'" 

-

1 ______ -----------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

1.111 "1. 1"Id"'Ild

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

1,,1,' ill"II, i'l jlll,l,i",il,1 

I 

.-.. -.. -~-.. . 'A",. 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and ,

disposal facilities have implemented those regulations.'

Name L orc- 0 ýO C at v'cL.

:Address 10AI1 S+Y-A44A pzI E)-

-"- - II. . . . . . . . . . . . . . . . . . .

1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

1 Re: Depleted Uranium Disposal Rulemaking 

1 

It is inappropriate to license any new uranium enrichment facility until 

regulations are in place governing aisposal of depleted uranium and ::0 

disposal facilities have implemented those regulations. e~1 ~ \~'\I·I 

Name L () V-(~V1 0 b{¥ I ~ ~dir -·;~'t:~, 

;::..;A~d~dr:;..::e~ss~_3.:,.,L--1~....!..I-Oj--1....---...:::S::......!..-hvt~~~!......:...--=------....!..~---.:· L!'~:...L. ~....:::\ ==-- ~n~i),>cl \~ . -- 1_:1;: \t-:t "/ "-;;0 

"\b-o IK 10 <E3 1 0 ?~. --.9 :S~ r ~ 'c:J -

1 ______ -----------------------------------------------____________ _ 
D'o "IP &370-3 Sf~ 

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Q

b115iii! I! lilIlEilIlliS III ~iid

Chief, Ru\emaking & Directives Branch 

. Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking I.

It is inappropriate to license any new uranium enrichment facility until

:.regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name I-,

Address D.A b =:.ll

- - 71•A - "

' : .

93l

rTI

- - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - -

1------------------------------------------------------------------

: To: Nuclear Regulatory Commission I 

:Re: Depleted Uranium Disposal Rulemaking ·01' 

I 

I 

: It is inappropriate to license any new uranium enrichment facility until I ~ 

: regulations are in place governing disposal of depleted uranium and 

: disposal facilities have implemented those regulations. 

iName IiwIt '-t;~~L;;'" IJ D. ,c_ i I 

Address. bf2tfS- . ~ltrhlrG"~¥ 

'~l~ ,:tt> 337dJ 

I 

I 

Vl ,oio

..) 

:. 00) 

1 ______ -----------------------------------------------____________ ~ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

iiiiiiiiiiijillifilliilliffililI

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail ,Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To!. Nuclear Regulatory Commission

'Re: Depleted;Uraniam Disposal, Rulemaking .

It is inappropriate to license any new uranium enrichment facility until:

regulations are in place governing disposal of depleted uranium and

disposal facilitieshave implemented those regulations.

'Narne L,,... eT",. 

:Addrs (• L- 3 "2... _{i. 0-.,.,I- L•:6AK<, ¢' !..:: C'D

A -

.9 I

I ... , ._ I

I.

I . I

I. . . . . . . . . . . . . . . . . . . . . . . .

---------:,~ -~'~'- ----~ --------.: ~ --~.::..~~":.: -~:t:~~~ ~~.~~~~; .. j~ -------------------, 

To:. NudeatRegulatoryCommissio'fl' " ,,'< ': 

R~: 'Pepleted :TJraniurn: Disposal Rulemaking 1 ~~~. ~ . ~ : . ~. 

, , It is inappropriate to license any new uranium entjchmentfacility until: 

regulations are in place governing disposal of depleted' uranium and ' 1 

disposal facilities ,have implemented those regulations. : 

" 

, 

Name 

Address 

, ; I I 

CJ 

--------------.----~--------------------~------------- -------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

- .," 1 4 '. :j .' 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

ill j Iltlllll i 11'III'i" i! i,!, i 1,1 
To: Nuclear Reuilatory Commission

Re: Depleted Uranium Disposal Rulemaking .

It is inappropriate to license any-new uranium enrichment facility until,:

regulations are in place governing disposal of depleted uranium and

disposal facilities have implemented those regulations.

Name 1, I

''I

recI:

A d d re s ---- -- !-- --- ---- ---- -- o-- - ---- ---- -.- "-- - --,- --?- -_,- 2 .,

----------------------------~-~----------------------- -----------, 

To: Nuclear Regulatory Commission 

Re: Deplet~d, Uranium Disposal Rulemaking .:. 

1 

1 

1 

" .1 

.. 1 

t.,;r .. :.~. ~ . .,z 

It is inappropriate to license ally·new uranium enrichment facilitY ~til .;." 

regulations are in place governing disposal of depleted uranium and 

disposal facilities have implemented those regulations. 

Name L'NJ kINcAJ~J -A.J ; .. :~j ~ 

Address I b ) Y\!\ e ADD 0 pRDOk Rbi :14*1 L1!'f. I~ OJ; ~ 1 }_. [:! I . ' .. .,..,. . _ .• , .. U :o;:~'-~I 

Y 16 1(~7)n;)~~ ~ ~0§£tflA~~~ fro~i 

b U. w~ M7 rkl-e-s ~ f ol~DSC&I! :: . . _.L ~~ 

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j~~~~~~)~;;:,'~~--~-?~~~-~--~-~~--
~OiS~ ~DTh~3~

Chief. Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

·L. j( 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it caiinot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million .years:,.Jprohibits DU disposal at any of the current orpending low-level waste:

disposal facilities. T,

Name A- 6'-Aqssr i [

Address -ý 0(-• KV .. . 0 -,

Ile 7)6 1 VU( " / LoD OD

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

OZ' OI

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive"icnventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of~ 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million .years;:;: ~: 

prohibits DU disposal at any of the current orlpending low-level waste L 

disposal facilities .~ ~;..J ,[? . , I , '.;:> ::~~ 

\ J '----- k ,") '!/, 

Name V t C3 \ A\ a. A- -. G\q s s~~c r~~ '~:'~T;\;j~ 

Address -205 D a v,' J'~-\ S+. Pf-6:Q bo ~-:;: ·-!1~-1~: -_. . I 1 I en (:9 -

Belle VU e (ID 83313 C:.J V1 ~i 00 Gjl 
Su MUORT$

s~~~r Pm --;

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

SU?POriT rJ 

~ HIST 

Ii 

~ Dp~C'rc.nK\I;'\-IT 1 .1 ...... J ':1 ~ • 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive- inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level wastei,

disposal facilities. -

Name

Address 20/24) re ss _ _......... 77. _ 

I s.• /" t63 16 '

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massiveinyentory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years , 

prohibits DU disposal at any of the current or pending low-level wast~;: 

disposal facilities. . -~-i] , .' F~,: 

Name tI/Vvr~ I~ i"; ,,) ~::l 

Address ~O 2 e 2 !lwt/ 50·' ... --' 

i 1 

..... • •• 1 .! ..... : 

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~~~.:I 

n', u:) , 
MarianneBarker v --

20282 Highway 30 1q. OCT

Buh, ID 83316-5703 S 2 ,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Common Buckeye

At

.\ MaiiarmeBarker~:~M 20282 Highway 3U' I~l OCT 

Buhl, ID 83316-5703 2~' r 9 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

1,,'1111,11,1,111111111,111111,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Dispo0l-uiemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or p ending lo~wlevel wast•I

disposal facilities. . .-

Name .•-

Address t'J Ma - - (" 

"--{>. - 7 '_4 i

-- - - - - - - - - - - - - - - - - - - - - - - - - - - --.- - --.

1-----------------------------------------------------------------. 

: To: Nuclear Regulatory Commission I _ 

: Re: Depleted Uranium Disp~~l!lemaking I 

I 

I 

: The U.S. already has a massive inventory of depleted uranium still 

: mixed with hexafluoride, so it cannot be disposed of. 

I 

I 

I 

,.: 

I 

I 

I 

: Once that separation occurs, the size of the \Jiste streamahd the fact f7i~, : that DU grows more radioactive over the co~~se of one niIpion years.,'-!: 

: prohibits DU disposal at any of the current or pending 10:\Y:rlevel wast~:: . 1 ,. .:.', '1' 

: disposal facilities. ii'" -') '-: , ., I C ....... 1'('-: 

: Name .L .. _:P._· 

~ tt'. _ ~_0,:":':1~l c.x.) s::~ ?:;~~I , . ,,--) , \.11 (:n 

: Address <6 Co 2 N ; vY\a'fQ::~vo"Vf--

2~ 852-0 I 

, ; ! 

1_-----------------------------------------------------------------
S5rol

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

h 11111 11111 11111 III! i 1 tlllllIll 
,To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

I !

The U.S. already has a massive inventory of depleted uranium still,

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the coii-ise of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities.

Name 'Name 1• 4 ;• "A.~

:Address [S'c5 -9co

. -------- -- _--_--LQ--- - -------- --- - I------ ------ --

: i ! i l : ! ; ' i ' ! ' ' : I Ii - - - - -- ~ • ! '

1-- - _. - .;. - - - - - .- - - - - - - - - - - - - - .- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - i 

: To: N uc1ear Regulatory Commission I 

: Re: Depleted Uranium Disposal Rulemaking I 

The U.S. already has a massive inventory of depleted uranium stiJl; 

mixed with hexafluoride, so it cannot be disposed of. ,:.;:;:,~. f T'l ';;:~', :" ;: ,: J ~ ,{ 

I 

Once that separation occurs, the size of the waste stream and the fact : 

that DU grows more radioactive over the c6_lJ~e of one million years f:: 

: prohibits DU disposal at any of the current orpending lo.~-level wast~;: 

: disposal facilities. . ... j ':. 

iName ~.b).~ ~_ '" j 

Address l\3S E-. !\k~~;lk ~9 ~ii! ,.-.-J V'1 u ) 

--@ccd.ddn I T-D, 83;«) l V1 
W~,e E7 ~tvt~uCLLQ~

j3~c( 28,

Chief, Rulermaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

", ::~'.\~.~~:'::.:~~':: '~~~" ':::';~~iE:~ ±"':~">' ~:~~~~:.: .. :C'~.;};.~:: 

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-.::':':~~~:::<:;;':':,::::~i::r~,:':~' 

Chief, Rulernaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S, NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

.11111111.111111111 II I I i 1111111I11 
To: Nuclear Regulatory Commission

Re:-Depleted Uranium Disposal Rulemaking

, The U.S already ha s ve inventory of depleted uranium still

-1 mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size-of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or-pending low-level waste I.

disposal facilities.

Name w.(

AA ddress " " " a.,- ....;- "--..:,.

--------- - - -

I-~--------------------------------------------------- ------------

: To: Nuclear Regulatory Commission.· 

: Re:-Depleted Uranium Disp.osal Rulemaking 

. : .. :. ' .. "~ :~{:i·:;·;q~· .. .... ~': ,~~ .... :~.;: .. ;.;::»'.~;~' .... : . ,~""" i':: _ ... '. 

-'-: The U.S. already has a massive inventory of depleted uranium still 

. mixed With hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size-of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or-J~epding low-l~vel waste ::D 

:::aE:it~e( C~ ( s:k~l,,- .~~ ;;i: 

14 (j -; 1 £;P --_· .. ::;:.-"70 -) ;-::\ -, - .> ) :,2:::;- Address _~ ~ 2:-- --.- I"CCi 

J~h( (Vela 8d)(~ ~ 

I 

I 

I ______ --~-------------------------------------------- ____________ _ 
E~Oi5~: NA) ~3W

2~i :-~2 CT 2CI'~ PM L

228J

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

r! ,i ,III, ,! tl" ,Ii "lil" ,i, II, i!i, ,iii II i,I!, ,/ !1"1!/,, ,/,Ii 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste:

disposal facilities. ,

'Name .. ',

Address 44o M (eb A:jL7ýt: 

C:)

- - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of.the current or pending low-level waste 

disposal facilities. ::0' 1 =m 

·-n 0:: ::::.: rl· (::;) 8:1 ~.:: ~, ..... I 

:.: ! '~-1 ~~·._I ,:" c.:: 

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, 

, 

, 1 _________________________________________________________________ _ , 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Adminiiistration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

.=: .. ::; -" .. " 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administmtion 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory CommissionRe: Depleted U ranium DisposalRulemaking

The;-U.S. already'has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities.

Name -7oI4t . A/U9 - ,__

Address , .,.

2722

rk

---------

J'" - -::::."" - - - - - - -.., - -."''''.-.- - - - -". - - - - - - - - - - - -.-",.-,--"" --,,,. - - - -.- --- -.,. - - - - --- --

, To: Nucl~ar RegulC:ltory Co~issio~-·"-" .' 

Re,; Q~pleteZr Ufaniunl Disposal~~Hlemaking 

The'V~S. ·aiready·has a massive inventory of depleteCfliraniumstill 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or pending low-level waste 

disposal facilities. 

Address 3 () ;) 5 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

".': 

",. ',' 

Chief, Ruicmaking & Directives Branch 

Division of Administrative Services 

Oft-ice of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and.the -fact.

that DU grows more radioactive over the course of one million years- .

prohibits DU disposal at any of the current or pending low-level waste:

disposal facilities. I]J I

Address 0

kN-A.A. l'tI I~ tI

A4 4 :ZI

------------------------------------------------

To: Nuclear.Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and.the -fact. 

that DU grows more radioactive over the course of one million years o' .: 

prohibits DU disposal at any ofthe current olpending low-level waste: 

disposal facilities. ~. -0 . L 

Namd~20l: ~;;_~ t.lj 

nO ~ ~/,-~~ l _~-7 L:'J ,.:,:' C:' 

Address ~ ~ ,):,> 2 .:::; ~ -::! s·~: 

~'~I :rAJt2"=fgj~l{& ij 

I 

I 

I 

1 _________________________________________________________________ _ I 
-J3 -0'

Chief. Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB-5BO1M

Washington, DC 20555-001

1111MN U11 I H ff hiddi didIIJ HN~i iIII53 I-ii If ,::;.::: 

.... -" 

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of Admini:mation 

U.S. NRC 

Mail Stop TWB5BOIM 

Washington, DC 20555-001 
I- . - _ --

To:. Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

:'The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years Cj

prohibits DU disposal at any of the current or-pending low-level wast•V1

disposal facilities.

Name Li CYV'.......- -,

Address 22/ v " -= 1

• , CD

_-~---------------------------~---~-----------7------- ------------

: To;' Nuclear Regulatory Commission - . . I. . ." . 

I Re: Depleted Uranium Disposal Rulemaking ..) ,. I 

"', : :~: .~, ,. 

, ... .' . " ~ 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over ,the c~J5se of one w.1llion years ~~ 

prohibits DU disposal at any of the current~rlPending 19JY-level wast~: 

d· I.e: '1" '" ) . .., I Isposa laCl Itles. 'i . .' .~) .~: ::: 

Name L 6?r/ ;;; r~. ',d~~ 1, . .J "._: ~~l 

Address 

"'C) -' :;:;;; eL: 

l j -_.j 

<- no, 

C/:.I 
'F401SIF. 4.`r) -ý8'3 7 -

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

11 fifirif III if 111h 1 1111111 1! 111111, 1-11 If fill

·""'. 

i·~-:: . ----

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission -

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one, million years:>,

prohibits DU disposal at any of t6ii- current or-pending lo`-level wastel-,--,

disposal facilities. -

Name f,4i.-) _______ • ••"

:Address Y P 2,44;J

•cz •in.

I ~ j'~4)t~j~{) 53/

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

• 

To: 'NucleacRegulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a'massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact' , 

that DU grows more radioactive Dver the course of one' million years::, 

prohibits DU disposal at any oftfl;:: current or_pending lo:»:~level wasteZ:~ 

disposal facilities- _L:! 0) r::j . -·~I:l (V) 

Name ~"iJ C-455{~t __ , ~) . ') ,j':, ['j \...0,) c:~,: 

Address ~D'3 )4";{} 9-. <:: ~) rrij ;··i·\H P't (If y'-'t , Ii) &13 /5 Cj ~ ~1 r ~ 

I 

------------------------------------------------------------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

lifill r

Chief, Rulemaking & Directives Branch 

Division of Administrative Ser/ices 

Office of Administraiion 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact ,

that DU grows more radioactive over the coirse of one mifllion years CJ

prohibits DU disposal at any of the current orpending 10iik-level wast"

disposal facilities.

Name & {C I <......•-

Address J2 • " oC, r)

-"'!I.'~ 

-------------------~~--------------------------------- -----------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulema!5;ing . 

. .,~:;.:.-; !;~~~~}.-

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the _~aste stre~ .li,Ild the fact ,', 

that DU grows more radioactive over the c~£se of one million years ~i 

prohibits DU disposal at any of the current9'rpending IQ~-level wastg:1 

disposal facilities. . ") ~- ;?: _. '-f' L ..) c. . / I J c:: 

Name ()Zi C (~-e. ! ~oli/eJ' :9 f±: 

Address R/s·tu / 5A'4£/trf.f-HL-/ ~ . ~ ~! 

/01~ / ~ /? ~2~2..r= u. 

1 ______ -----------------------------------------------___________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years -

prohibits DU disposal at any of the current or:pending low-level waste7T

disposal facilities.

Name!222

Address 4'. ,4/) /.ý

C)A

,/ " o =

To: Nuclear Regulatory Commission, 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

" , " 

, '" ':X: 

·.1· 

II 

I 

1 _________________________________________________________________ _ I 
d4

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

:'" 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

SRe; epleted Uranium Disposal Rulemaking.

The U.S. already has a massive inventory of depleted uranium still

mi~xed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any ;61he current or pending low-level waste

disposal facilities. / _

:Name VI

Address LI£. .

. . r l

I____ _____ __CID

---------- - ---- --------- ---- --- ---- ---- --- ---- ---

·- - - - - - - - - - - - - - - - - - - .;;,.-.~ .;.:: - - -.- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1 

: To: Nuclear Regulatory Commission : I _,.. ",".. • 

: Re~~~.Depleted:Unmium Disposal Ruleniaking . : • " . I 

I I '. .' . : The U.S. already has a massive inventory of depleted uranium still I I . 

I-~ed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any:t..ftbe current or pending low-level waste 

disposal facilities. . ~::CJ .~ 

II, I - - ~ .~ III I/' ~.-J-- -n 

Name I 6-10( Va tit: r 'f!;U .-.-.... , 

Address LrOq £.5/sf:Jf7jj 

0-za;r~ [ltV k a~ 'l3-il 

./ '·,3 

':9 
~*IT Vý fit~

128

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

'" .. "',. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

---Office of Administration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

Thle U.S. already has a massive inventory of depleted uranium still

mixed'with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities.

'Name

Address

CD

-- . -----------------------------------------------------------------, 

To: Nuclear Regulatory Commission , 

, 

, 

, Re: Depleted Uranium Disposal Rulemaking '," :,,-' 

Tne U.S. already has a massive inventory of depleted uranium still 

mixed .... with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or pending low-level waste 

I,.:, .";' 

; 1 

disposal facilities. :JJ ~:~ ~: 

Name K'Gf:-- p[fJ'{1Jf;~2 ' ... 2' 

1 CliM H,/\ ~ i W ,.-, i-' Address WI \ VV \ ,__ :co::: 

0015 l' {) 1~=-fll\ (P: ~l r.=i V1 ~~ o : 

, 

, 

, 

, 

, ------------------------------------------------------------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

II ,i ,|,I!!! Il

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

--_ Office of Administration .. 

u.S. NRC 

Mail Stop TWB 5BOI M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

:mixed with. hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities.

Name . ! : > 5 U:

Address Z..--

IDI CIr

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - !

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulem~ing 

The U.S. already has a massive inventory of depleted uranium still 

mixed with. hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any ofthe current or pending low-level waste \ 

disposal fac' ·ties. 

Name, 

Address fa 2} if 

B?J?8e ( , 

" .. } 

.,". ) 
T4C)I*&FT'2'ET' 'ýS*."i'-'ýP

Chief, Rulemaking & Directives Branch

Division of Administrative Services

-- Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I I~ 111

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

. _ ~...Qffice of Administration 

u.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

I,! 1,1 i / , 1111,1, I i ,I, ! ii/II! Ii! I 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking .. .

The U.S. already has a massive inventory of depleted uranium still

mixed-with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities. -.

:,Nam e ••l,' :: ,.,

Address "". .-.

- - - - - - - - - - - - - --.- ---

The U:S. already has a massive inventory of depleted uranium still ' 

mixed-with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or pending low-level waste, 

disposal facilities. _) J :::r~l 

Name L . -. ..::::.. c' • i 51 c;': SA ~v/'-? j'" L::, 

) 

Address I 3' 0" ~,t~ Is'{fl 5./ ~) 

/!:>~/5 ~_ I/) n-?~~ ~.~.'~ r \'-..J V1 

o 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I liul INIIIdz1111 !~II

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear.Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking -

The U.S. :already'has a massive inventory of depeiied uranium still

mixed with hexafluoride, so it cannot be disposed-of. "

Once that separation occurs, the size of de~waste stream and the fact

that DU grows more radioactive over the.course of one: million years prohibits DU disposal at any of the currentor pending low-levelwaste

disposal facilities. -.

Address C.,

--- -- -- -- -- -- -- --- -- -- -- -- -- -- --- -- -- -- -- -- --

1-----------------------------------------------------------------

: To: Nuclear-Regulatory Commission 1 . 

: Re: D~pleted Uranium Dispo~al Rlllemaki.ng;;!!~.'· ..... .A.' 

1 ..' .• :'. ., 

I ..... . •.. .;.i:.. '. ,,' I ,. ' .. - ..... '''. "\" 

: The U;:~ .. ;alrdidyHras a massive inventory of depf¢t~d::urahium still 

: mixed with hexafluoride, so it cannot be disposed-of .... : ..;.... .: : .. , 

... 1 Once tha~ separation occ.urs, ~he size of t~e~waste str~~ ~~ the f~~ that DU grows more radIOactive over the ... c,Qurse of O1,:t~ mllhon y~ats, 

prohibits DU disposal at any of the current)or pending 1ow-lev~f.:\Yiste 

d· 1 f: '1" II v,) J ~.o:> '.- lsposa aCl ltIes. ...:--; "-; f~) ~;;: 

Nam~~~ ~,~C\< '5fl !_'Lg J li"l 

Address :2. 'l{ <0 {\ • ~~""':~ (f) 

~0\~e... I--:=S:J i '8si)b"2-

f __ ~ __________________________________ ~ _______________ ____________ _ 
T2 b C), PM - "i.

.~

) *

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of AdministraritioU.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

# ifsdlJJ r Ida

,; ... ' .,e,..S()iSf:.:,i(6 (e;:3~i 

,-----;------::--

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of AdminTstrafioif--

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposaf-at any of the current or)pending low-level waste ,-

'-disposal facilities.

Name 0yL ,- rrd

Address 3t. +- Crqt' Ci Y (e--

/ T3

-------------------------------------

I------------------~--------------------------------------------~~~ .. : To: Nuclear Regulatory Commission 

': Re: Depleted Uranium Disposal Rulemaking I 

I 

I 

: The U.S. already has a massive inventory of depleted uranium still I 

:.mixed with hexafluoride, so it cannot be disposed of. I 

I 

I 

: Once that separation occurs, the size of the waste stream and the fact 

: that DU grows more radioactive over the course of one million years 

: prohibits DB disposaCat any oftne current orJ~ending low~)evel waste,:~ 

disposal facilities. . =n !:-;:; ._." I.,. 

mart-,' B r ,'dg·es ::;~ ~:,) l~ 

Address '3 r 2. 1- era n ~ Cre.e.lL5; S;. .~ ~====~~~~~~~~~~-~~~~~ITI- '9 ~ 

__ ~g~o~i~~=t~j~~~b~~q~3~T-O--2---CJ--- ~ ~] 

Name 
c

Chief, Rulemaking & Directives Branch

Division of Administrative Services

-- Offi'f-e-Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

lIE Is fUEl If Il I! d111 III Ud

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

-~~e>fffce ofiXdministration 

U.S. NRC 

Mail StopTWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities. ] -

'Name

Address 7 /.._.

I__ __ __ __ __ __ __CD

('0-

1-----------------------------------------------------------------i 

: To: Nuclear Regulatory Commission : I.~ ", 1 

I Re: .. DepletedUraniumDisposal Rulemaking ,~ .. : 

The u.s. atready has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or pending lo;w-Ievel wa~t~ 

disposal facilities. h :!:2 : c.; ~ 

~b~ -ll ..... , ..... , ,. ·~···I U~, '1"'" N ~rq 0 I r) i ,:'i; ~-:' ame Z ~-(::l w."· ;':;: "~'. 

Address 1S'7t:!J/ ~.sfk?~ ~~,;;~~:; 

~d_ C--f:J, ./ £12 :~S7/~ = -.0 ~ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

-•------TS. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

ISlE 11i3151151 511111 lId

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

..---rrs~ NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current 5irpending lovt-level wastet?

disposal facilities. T -

Name C r ("':.

Address Z "• -5'

CC

------------~-----------~----------------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking "- .. • . I -' .. ..,-~ 

The U.S. already has a massive inventory of depleted uranium stlll 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one mUlion y~ars 

prohibits DU disposal at any of the current §tpending low.-Ievel wast~:~ 

disposal facilities. -n ' L}! 

Name Ck:~ (oP S R _ ~~ ;,::;;r,. , l~' E~l c-.-.' 

Address :Jt{ ljTJ 2. L . Pib t)~ S~' j ~1; 

----~--~~~~~+---~(~~~~~--~~ ('~f: (t, ~~'OO&-3~~1 ~~ : 

I 

I 

I 

I 

I 

I 1 ______ -----------------------------------------------____________ _ 
. M. Z '

,Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

i~;i~i~i1~, 1I3b~hJ 2 112 1213h21

Chief; Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555~OOl 
To:.Nuclear Regulatory Commission

,,Re: Depleted Uranium Disposal Rulemaking

The U.S.. already has a massive inventory of depleted uranium still

:mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of th&Iwaste streamn"and the factr

that DU grows more radioactive over the &dirrse of one7nmillion yearsg,-:

prohibits DU disposal at any of the currenft&o pending lb0w-level wasite

disposal facilities.

Name: ;•

Z= ()- :

Address .Aco

-- - - - - - -- - - - - - -- - - - - - -- - - - - - -- - - - - -

1-----------------------------------------------------------------

:To:Nugl~ar RegulatoryCommission 

:·Rt!:Depleied Uranium Disposal Rulemaking , 

, 

, . 

: The U.S.' 'already has a massive inventory of depleted uranium still , 

'mixed with hexafluoride, so it cannot be disposed of. 

I"'·,,) 

Once that separation occurs, the size of th~aste stream~and the fac~ 

that DU grows more radioactive over the cqqrse of one~glillion years5~ 

prohibits DU disposal at any of the currentoy pending n?w-level.wa~Je 

disposal facilities. :n ~\..r /: ;~~ ':~.' 

Name~~~ ";[3 

Address c:I/¥ ';<A/O mE ;;V. ~ 8 

,L~I 4k g> 33'3,.;:;> 
Cri.-WC C: = "M 10"tr-31, '

C' 3 553•

Chief, Rulemaking.& Directives Branch

Division of Administrative Services

..... Offize7if Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

11111ifill I 111 111 ilf"I 1,111111d

Chief, Rulemaking.& Directives Branch 

Division of Administrative Services 

~'~-'~Office of Adm in istration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To; Nuclear Regulatory Commission

Re:'Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one -million years MI

prohibits DU disposal at any of the current-of pending low-level wast.•I

disposal facilities.

Name . .

Address K• 1 -0 - - -- :

. -~--------~-~-~~----~-~------------------------------- -----------

Tg; NuclelY Regulatory Commission 

Re:~Dep!~~d Uranium Disposal Rulemaking ,:" 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the co\urse of one)nillion years~, 

p:ohibits Dl! .d.isposal at any of the current:·?~pending l?~-level wasl~~: dIsposal facIhtIes. '-...... , :<,0: 

Name ... ~ c.klt ·~l~ ~:J g1 

J

.... ~.i.}' 

:.~:- ~l-~: 

Address .~ : I "'9 _.j' 

~~~~~~~~~LL~L-~~~~~~~ ~: 

[.-g~ ~ (/), ______ ~~4L~~~ ____ ~~~~_L~~_ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC ,

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC) 

Mail Stop TWB 5801 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or-pending low-level waste.,

disposal facilities. 17-

Name -A x•,'• cn --

Address -- ' _ . , • .... 17!

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal,Rulemaking . " 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current ~IPending lo~-level waste)1J 

disposal facilities.~T7 ~E,' -, S v' ~ ~~ 

Name J\h\(J<l<~ 1 J11:1',(o0 l1Y\ .~ ~J'#_.i 

Address 5'07 l'CkJ ~ I ~ • ~l p~i i,---, ':9 . 

S orO{ ~ -;;'7) 2s3J 12: c;; tfj' 

1 _________________________________________________________________ _ 
1CUMT-~-r~ - ~ -58

,i-W -.-

Chief, Rulemaking & Directives Branch

Division of Administrative Services

..... Offiice--f-A-dmiinistration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

i i ! i * i i i ! ! I I i I i I i i i i I I i I i 1 .3 1 1 i : i

" ;"": :,: 

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

. Gffh::e(5rAaministration 

u.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory CommissionRe: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste streami and the fact-7,:

that DU grows more radioactive over the course of onei mllion years-1,

prohibits DU disposal at any of the current. or pending lov-level waste""

disposal facilities. )

Name _______ -:'

Address Q-• 0h- - CA 

Co

To; Nuclear Regulatory Commission" 

Re:" Depleted Uranium Disposal Rulemaking . i,' 'h" 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of th~l~aste strerup;and the fact~ 

that DU grows more radioactive over the c~l!fse of one~~illion yearsm: 

p~ohibits DU disposal at any of the current,~pending IQ:.w-level ~~~~:: 

dIsposal facilities. _ ) ;:":~:~ C',: 

<:::CA5 O~~.T' \.,,)\"~~~:.: ~~ ~lC~ 'I~ 

"'-'-Ad=dr~e~Ss--I'-s----rQc:;;;I'LI.£--' -6'("-V'1-G-o' (c-~-!-="l=\I1L"""'-'~- ~ ~ 5~j I- -+ l{,'C"-'T co eOlh :If> ~~ 7b ~-
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

IF3 If 11133 I2 I 3h If fill! jU~l

.;.t, "';;r-- ,;.:., 

1:,,' ~#,' •• *r ,,' •.•. " ••. 7---.... , .. ·• -''"t·;f·''T: ,-k;l<,'" .. "..~p~ 

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking -

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste-stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any ofthe current-orjpending low-level waste-:

disposal fac' ies. .'- .1. F")

N am e _...._____-.. ..

Amdress CD.1

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking . 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride,so it cannot be disposed of. 

Once thaLscparation occurs, the size ofthe waste.·stream and the fact 

that DU grows more radioactive over the course of one million years 

p:ohibits Dl! d.isposal at any oHhe current.J.:JPending l~~t-level was~: 

dIsposal fac les "'Tl r-' 

. . ~ d . ""') E~;: 

"'-'-"::X:=--.!...L..,~~-~-+-I+-- GPL/ ,':.,:',. I' :j';€ Cr; 

, . t1X ;;L.76J7-~~~: pLfi~i' L~!/2J ~ I ~(/c ~ G~ :~ r OdP:3 , 

, 

, 
L. .........

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administratin

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

L. L~ 

lbt- :21& ~~"i' {:j~~:~:~r' ~~(~.):g ~;:"f* t· T 

/(~;;:jJ 1133,/0 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Admin~trati!.!.!L_ 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
-----------------------------------------------------------

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the coure of one million years

prohibits DU disposal at any of the current or-pending low-level waste I:

disposal facili'i.

:Name

Address

.1

ic

!- - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream an~ the fact 

that DU grows more radioactive over the course of one million years ~::o -,..,.~ .... .) , ~= 

p~ohibits Dl! .d.isposal at any of~e current or:!,~nding low:level waste tr! 

dIsposal facIhtl s. - -,. "-.. . '·'J'}C: 

, ! .~ 'I . \~):2 ~~;i~: Name . ~T:';~~.; 

II /;;; g A~d~d~re5s~sL-~~~~~~~tv-L~~~CD~-~-~. I S--f.. ~l 

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, 

, 

, 

, 

, 

, 

, 1_---------------------------------------------------- ____________ _ 
2e' 5, C-UT " 2- 1 -20 N 2 T A4

Chietf Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

il)I I 1 1 1. JdJ,,,I 1J 1if itH

Chiet: Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory, Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the.size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities. J9 -

Address "•2) 062D:'

*1

- I..

-i -~

---------------------------------------------------------

To: Nuclear Regulatory Col11li1ission . 

Re: Depleted Uranium Disposal Rule~aldng 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the.size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years : 

prohibits DU disposal at any of the current or pending low-level waste: 

. . facilities.="TJ ~. ! .:;-- ..... 1 (I:~~ 

"- - rJ=:, 

t~:5 I::.-J '"< c.,; , 

. 

l.v 

-'d 

~::::I: 

. :.; ;:-.:. >.- '-I 
C~CT 2'~ ~4 2 ~

r., JChief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

-- U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

ILL 1311113331,113111,1 J~ i~ II, I

kfkl~ ''kD 

K334u 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

'-,"U.S.NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory.C-ommission

Re: Depleted Uranium Disposal Rulemaking .

The U.S. already has a massive inventory of depleted uranium still

:rmixed with hexafluoride,.s--i4-cannot be disposed Vf.

Once that separation occurs, the size of the waste stream and the fact. that DU grows more radioactive over the course of [ 

one million years --AcI"

prohibits DU disposal at any of the current or-pending low-level waste',-

disposal facilities. ) I

:Name -

~Address q 3

----- -- -- -- ---- -- -- --- ----- - --- -- --- ---

I-----------~----------------------------------------- ------------

: To:<Nuclear RegulatoryJ~ommission "' .. ,,..·.'c, .•. , . 

: Re: Depleted Uranium Disposal Rulemaking , . 

. ' . .r.j ~.,; • 

: The U.S. already has a massive·inventory of depleted uranium still , 

: mixed with hexafluoride,.-se-it.cannot be disposed ~ V/i.I·C"~ 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years ::C,) 

prohibits DU disposal at any of the currenfo~-!pending l<?'-Y-level wast~:1 disposal facilities. ..-'-~ S2 ~:' _,' : .A •• 

Name thil Gh5;~.~~J :~.' '~:1 

Address 7 '-I 3 '5 c? VIle; !lifil1 c ( ~ ~! 

11 O(X ]:h. '6' > -r[i ~ D'j --~---------'7--------------~--------- : 

, 
t r~r~ '~r~l s~t 2-T

-4 ) -

~

&

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

'1: ..... 

BOISE ID 83"7 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

Ii I i ,I J iI/II if I; ,I,l" i, i 1IIII,i 
To: Nuclear Regulatory Commission

Re:..Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows ,, more radioactive .

over the course-of 1jj one million years

prohibits DU disposal at any of the current or pending low-level waste -

,disposal facilities. .-

Name Uo I Li 

Address "-.

-h ion•I

,,-I----- ---- 4-- -

To: Nucle~ Regulatory Commission 

Re: ·.Depleteq.Uranium Disposal Rulemaking .. '- ....... 

TheU.S. already has a massive inventory of depleted uranium still 

mixed with l1exafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the cours~.of one mil,lit;m years ::c; 

prohibits DU disposal at any of the current orpe*ding low~_l£vel waste ~ disposal facilities. j I ~ u: 

Address 

-to 

I 

W 

I 

------------------------------------------------------------------
&.10iSE IE:Sa7

Chief, Rulemaking & Directives Branch

Division of Administrative Services

-- - Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

.- - Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
:.To: Nuclear Reguilatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or' pending 1. -level waste.

disposal facilities. - -

Name L(v(I'L c•c •,,2---

Address --- 4o ,.

-- -------- - ---- -- ------ -- --7-- - - 6-- - - --- -

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission ~" , "I I 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

I 

Once that separation occurs, the size of the JVaste stream and the fact ~, 

that DU grows more radioactive over the co_&ke of one ipJllion years r~:·, 

prohibits DU disposal at any ofthe current qIPending lo,w-Ievel wa~t.~~:: • • • • ~ \ .. ::.;.:! :"J 

dIsposal facIhtIes. _ ./ !.' ;J~ '~.:-' f\ I.J...! 

Name [UVO { 13 CAc1~lJ~ 

Address 
BiC'-VVE. ID7 8'3

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

. U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I!! iIIIJ33f uhf

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOI M 

Washington, DC 20555-001 

1"/,lli ""I,I"I,II,I,I'I,il Ii 
To: Nuclear Regulatory Comm'issidh .

Re: Depleted UraniumDisposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream-and the fact -,_

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or jpending low-level wast.e:

disposal facilities. ''4 ,,

Name S -Le. •I

Address P,'., 6p< .-

A /7 '6: T/r /VQ/ Eum!

--- --- - --- - - - - - - - - - ~'- -- - - - - - - --- - --- - - -.- ----- --- - - - - - -- - - --- - --

To: Nuclear Regulat~ry Comjnission" ':." . 

Re: Depi~ted'tJranium'Disposal Rulemaking 

The u.s. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

'.~ ::il ) 

Once that separation occurs, the size of the waste stream'and the fact tF ____ " - ,. I I I 

that DU grows more radioactive over the coUrse of one niUlion years ~I) •. ,............ .....::r....... . .- :._, ~,I .• 

prohibits DU disposal at any of the current qr pending lmy-Ievel W~sJ~;:L 

disposal facilities ,'";"'1 W ,:;:::;: ,I., 

. ~~ !?~:' : ) ~'I~ ~:'~.I 

Name LtriA SmiCf1,-n ~:~ 

Address PI 1.0. J3g ~ f Lf S o 

I 

rn.br;~ rD. 83~8D 

IV d T £1/£/2-1 / / , 

"f? <i-

.c:: 

V1 

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C!0 

I ________________ ~------------------------------------ ____________ _ 
80SID 83S7

2Z•. sz•~v 2 g•.• P•;• 2 qT •

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

\. 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has-a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years1

prohibits DU disposal at any of the current-orjpending low-level waste-' FF-I

disposal facilities.

:Address

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has.a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years::c 

prohibits DU disposal at any of the current-0,9pending 16w-Ievel was~: 

disposal facilities. ~?:. [~: 

Name ?C t1~~ ~~13~ .j): ~i Address I ~{{; ({;;..'t'4I'( JtrT\.. 'fj ( vI)-.::. :z: ~:i 

C5i(~)::1j) 1S"a-?oiJ ; ~\ I 

I 

I 

I 

I 

I 
~:~s~* IT) ~3?

~A. ~L..A *~"~ ~ PM -~~. L,.

.... . .

LOil

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of-A-dmiriistration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office ofAomirlistnition 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
.Co: Nuclea" Relatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still.

I mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream ahd the fact

that DU grows more radioactive over the course.•of one million years

prohibits DU disposal at any of the current or poending low4level waste., :ý

disposal facilities. 7" .dZj

Name -

Address ••c II

0 S?

1-----------------------------------------------------------------

4-'1:0: NUclear'Regulatory Commission 

: Re: DepletedUrani!llll Disposal Rulemaking I -

.: • i' . • ••• , . 

The U.S. already has a massive inventory of depleted uraniuin still. 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream ah4 the fact : e 

that DU grows more radioactive over the coursF~of one mim.<)fl years : Fi 

prohibits DU disposal at any of the current orp'e~ding low~r~vel wast~;i: .-, 

disposal facilities. -:..:!~,J .' J:: 

l 1 .. -~. ~E fO-l 

Name jrw~)~ . ,_~ ; ~~ 

Address tSd't> V A1k:t 1/ \J L ~ ))18 / J:: [}] 

r V1 

'JSOtS~.xb ~.'? oy 

1 ______ -----------------------------------------------____________ _ 
7P.R&I sris ZA51v I

28j1

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I! J Ill I

3~ *I , II II III! I3 31

./'. ··f •• • 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i, !Lili",! i,i"i,i"f,i,! ,ii,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium DisposatRulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the cofs-je of one million years _

prohibits DU disposal at any of the current or~ending low-level waste,--

disposal facilities. 7,1

I . - I_ :Nam e Wf £, ... :':. '': ':

Address -9

-- -- -- -- -- -- -- --- [- - -- -- -- -- -- -- -- -- -- -- --

To: Nuclear Regulatory Commission 

Re: Depleted pranium Qisposa~:,Rulemaking . . \ . 

The u.s. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste streamaqd the fact 

that DU grows more radioactive over the co~~e of one mil;lion years (:~ 

prohibits DU disposal at any of the current Of(p'ending lo~~level wastefI~~ 

disposal facilities. '-~);~ . -:n ~i:: :::_, ~,.., .. ~ ~r 

Name £« Vb 4 AILu,~ w kc.-7~: ... , 82 

}~:j 

Address g 0 ~ N! a-~ If S~'- '9 ~:~ -!::: 0) 

go 1 se p0 4- btv ~~-sifo 2--: .c:= : 

I : 

I 

I 

I 

I 

I 

I 

1 ____________________________________________________________ , _____ _ I 
siis:.T- 3

28J

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5801 M 

Washington, DC 20555-001 
i--

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the cour-,-e of one million years

prohibits DU disposal at any of the current orIpending low-level waste;

disposal facilities. "T-t : ~.'. --- :

Narne mica cd. de, n;i_ ,.

Address II /[-or'fk' 1"' S+ ':9

, ~I~ 1?ose; 33"7 c_4)

I-------------~--------------------------------------- ------------. 

: To: N~clear Regulatory Commission : 

: Re: Depleted Uranium Disposal Rulemaking ,: 

" , 

The u.s. already has a massive inyentory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

, , , 

" 

, 

, 

, 

, 

, 

, 

, Once that separation occurs, the size of the waste stream and the fact : 

that DU grows more radioactive over the co~~ of one m;iHion years ::I1 

prohibits DU disposal at any of the current Oi"iP~nding lmv;level wastei:~~ 

disposal facilities. ) ~~Z? ,:,.': -.. ../ I . I~ '.-~ ~:. '. 

Tl t..:.J {:.-

Name mic.aelCL ru Loyola. '--, 

Address \110 North i th S#ee:tCJ 

Boise, rda.ho ?J31o;) , 

':9 

, .. 1-

,:~. S ~:::.~' 

F'i 

c:-:; 

:;'"f . 

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, 

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, 

, 

, 

, 

, 

, 

, 

, 
•..,F.,.. ",•

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office-of Adifiii-stration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

-

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office-of Kdffiifiistration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission,

Re:. Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactiveieover the course, of one million years.

prohibits DU disposal at any oftdfe current "r pending low-level waste.

disposal facilities.

Name • , V, Y I .C

IOt Sic;0 i a-A., Di

·-----------------------------------------------------------------

: To: Nuclear Regulatory Commission' .. ",,, 

: Re: Qepleted Uranium Disposal Rulemaking .~ ~ ,.: '" ~ ') ~ 

The U.S. already has a massivdnventory of depleted uranium still 

mixed with hexafluoride, so it .cannot be disposed of. I 

I 

- I 

Once that separation occurs, the size of the waste stream 'Vld the fact : 

that DU grows more radioactiveif!ver the cO.UiSe,.ofone'inillionyears,;~:! . 

prohibits DU disposal at any of;fh'e current or]:)ending Iq,W-level wast~~; _.... ""'"-) l ..... 

disposal facilities. . ) ">::: ~,: 

~ .-- :'r'l t.~, ; -" C: 

Name 'T""'ct..5)'2 ~e,V\V'\~~~7. ? ) --" ~;: 

Address ~~ ~~~~/lb'~~;tJ . , ~SS~U 
28 OCT , . 2 oJ 

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

j"" 

.' . \.- ." '. jI • -, :. - (. ~ } 

i r;,·;·"d" "D,O"':' 

t (; 0-\; ~vC;: ·S~~~·; 

, ,~ . 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 580 I M 

Washington, DC 20555-001 

IIIIIIIIIIIII,II!I,I"IIIIIIIIII 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a-massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the co~urse of one million years -j

prohibits DU disposal at any of the current or-pending low-level waste.f

disposal facilities.

Name "Tc/ e ,J 6tu.WF 6

:Address 1/',/g ...- ,,, 0 ---

I:

- - -

,-----------------------------------------------------------------j 

: To: Nuclear Regulatory Commission : 

: Re: DepletedUranium Disposal Rulemaking I 

I '. ~>'. -., ''',' ,-< 

: The U.S. already has a-massive inventory of depleted uranium still 

: mixed with hexafluoride, so it cannot be disposed of. I 

I 

I 

: Once that separation occurs, the size of the waste stream and the fact 

: that DU grows more radioactive over the COl~rse of one mrIlion years ::;) I " • 'I.' cJ · 

: prohIbIts DU dIsposal at any of the current Qf=pendmg low,-level wast~~+~ 

: disposal facilities. t:/:, I 'I~ 

I :.,'1 

I 

:Narne 

"'1 

1 

---.... 

: Address If tf ~ f ~A il,c ) £ L 1)"11 :~==~~-L~~------~--~~~----~C===J~ 

: _______ ~_&C~A_1~c_~_l~O,~,-f~o--R.~~-~=o-y-----

'-9 

v.) 

V1 

I 

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: ----~ -1- --~~ ~ -~~ --~- -~ ~ ~ -!-f-!- -+- -~~~-j-U~- J l! ~ ~ -i-i- D --1 L -L --Ii- j 1 ~ ~ --,)~,., 
r-U

• Mr. Step-ien Weeg ..

• -• ++• ;++ :........ .. . , 442 S. Garfield Ave. • r# "

c. Pocatello, ID 83204-3335

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B 0M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

IIIIIIIIIIIIMIIIIIIIII illllill 
I- --------------- -,•"- . . . . . -- . . . . . . . . . . . .--- - - -

To: Nuclear Regulatory Commission

-,Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years -

prohibits DU disposal at any of the current or-pending lo -level wast,-r

disposal facilities.

,Name S"

Address F

*Y,- 7)ie..rr

1 257:

1-------------------:---------------------------------------------

: To: Nuclear Regulatory Commission 1 " 

--:-Re: Depleted Uranium Disposal Ru1emaking 

:/ 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one m~11ion years -;,1 

prohibits DU disposal at any of the current o~-p'ending low-level wast~:~ 

d· 1 f: ·1·· r '1 111 Isposa "aCl lt1es. :'"' "_..J c:, T1 :i> 

: I;~~ 

Name 1..:=:",: 

Address 

\ I 

r~ f\J 'g1-iJ ST 'B=36( <::: 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

It JI III I I 1 I )11111 i l lll 111 1 1

;·S .• ,.;· . ':~~1~:·~S.f":. ~I.p·:~~~1·:3..7· 

D .eAtf..L-fLi-." 

............. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

'11111 J i 11111111111'1,1, i" ! i I,l 
Toi-- Ilear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massiie inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million yearsprohibits DU disposal at any of the current or pending low-level waste

disposal facilities. '-,

:Name

'T I-= {"' 

Address qAL-s)4•- /N, 

GO

- - - - - - -- -- -- -

'r0~lear Regulatory COInmission 

Re:Dep~~ted Uranium qi§1?Q~al~R_I.emaking 

. . ,,~, .. , ~~~~: ;r,~~~~~'~~7:' ~~:. 

The'U.s. already has a rriassl~e inventory 'of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million yearsprohibits DU disposal at any of the current or pending low-Jevel waste 

disposal facilities. _0 ::J ;:~ 

,-[-"1 ::T} 

Address 2 ... 11'1 /fJ. 25Wt & ' 

.»-', r.~ ."-, j .- i... ~ J '1_' • 

'rl ~} I:; ~~ ;;; 

) ::c f:~~~ rl~ ..... ~ 

~~ -I~ 

'"I::::. 

lin 

(jI) 

• 

• 

• 

• 

• '''' ------------------------------------------------------ --.~--~~-~---" 
JChief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

!,.I h mi 131! 1 , I ...!I'l

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

i,l i ! I Ji,l f Ii ,1111 ! i,l" I j'll i i II 
To: Nuclear Regulatory Commission,

Re: Depleted Uranium Disposal Rulemaking -

The U.S. already has a massive invento of-depleed uranium still

mixed with hexafluoride, so it cannot bedisposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste:

disposal facilities.

tNam,: --.

Address JO/ .2 "I

I •L i21I-I

Lfli

'0 -

---------~-~--------------~--------------------------- ---------. 

To: Nuclear Regulatory Commission :' 

Re: Depleted Uranium Disposal Rulemaking : ," 

The u.s. already has a massiv~ inventory of depleted uranium still' 

mixed with hexafluoride, so it canpot be'disposed of. 

; i ! I I 

C~) 

.::~-;::·1 

fj'i 

C) ::::{ 

r~~ 

" 

, 

, 

, 

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, 

en 

, ;, --- - -- - - - - - - - ~ - - ---- - - - - - - - - - - - - - - - - --- - --- - - - - - - - - - --- - - -,",'" - - - - ",,\.p, 
-... ~ A ~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I i I flI!~ IU I 1! I IIJ di

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

'The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it c annot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities. h-

:Name 6"-c]

:Address 1 7 1 -

:'I

(I) I01-

---- ---- ---- --- ---- -- --- ----- ------ -- -- - -- - -- - -

To: Nuclear Regulatory Commission 

Re:. Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

'" 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years 

prohibits DU disposal at any of the current or pending low-level waste I 

: disposal facilities'~J d-:J 

: /JIJ - YJ AA-tPJ" ~;g ," ~~ : Name ~ e; ~ . II ~,_T~ 

i~, -: t'/ ();li A.{ 7 rt) 1 - - ,~.~ ~:-:, Address (T I 1-.. ST? I.J.) ,; ~~~ ~::I - . ) ~:·7 ~:i:j 

6~, j~ rrj~ilOdv ~ ---~~ ,-I rln 

\....J \..oJ (V) 

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---- --- - --- - --- -"- --- -..: --.;:-,;-;:. ---:- - ~:-~:.. ~ ,:",~:~,,,~ -"- -- --- - -.- - - - - - - - - - - --- --~ 
t28.

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I I! !!If f hi,1hf

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current oF-pending low-level waste.,

disposal facilities. C,:

Name ?..c...rr ...

Address SO- S70 CXtL.4)Ic- - I

........ .;

- -- --- - - -- -- -- --- -- - -- -- - - - - --- --- - --. ---. --.

,-----------------------------------------------------------------1 

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking r 

: The U.S. already has a massive inventory of depleted uranium still 

: mixed with hexafluoride, so it cannot be disposed of. r 

r 

r 'c 

: Once that separation occurs, the size of the waste stream and the fact 

: that DU grows more radioactive over the course of one million years 

: prohibits DU disposal at any of the current of-pending lo",,;-level wast~r' 

: disposal facilities. '-'~=; " ..' El~ I , \ 1\ 

. 0~1 

"; ,,,,I 

Name S'v J1cXerC 

Address 

• . r 

: _____ i_~ ___ }j~_~! __ L __ ~ ___ : ___ , __ 'J _______ ~~j~2L __ ~ __ ~_~ ______ ~~; ____ 2 
Ms. Susan Pucke'tt

'• 5025 Mohawk St j,

Pocatello£-ID 832044547-,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

y.;.-:::~~~ ~1{:;l!· ,2.f-t-GfEt P!"-t ":I" T 

" "'Ms. 8usanPu~kett ~ I 

5025 Mohawk 8t "i·: ,. .~<$'--' 1 

"~o~!!tt!llg;)D ~f04-45~" 1 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission--

Re: Depleted Uranium Disposal Ruremaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact '

that DU grows more radioactive over the course of one million years (i

prohibits DU disposal at any of the current ortpending low-level waste,':,

disposal Ea ilities.

Name 4 r..,_

Address .-

. ~0-

- - - --- - - - "

----------------------------------------------------------------- ,;,:,~",,;: 

To: Nuclear Regulatory CommissiOlf" ... 1[..: .. -

Re: Depleted Uranium Disposal Ruremaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

, Once that separation occurs, the size of the waste stream qnd the fact :~:i 

that DU grows more radioactive over the course of one lpipion years f} ,· .. .,-1 .".... ", 

prohibits DU disposal at any of the current or'-I?ending lo~~level wastec: 

, disposal fa ilities.\ \ ': ..', ~l 

Address (7, 

, 

o 

0-

\ \\ \. \\ \ \ \ \ \ \. t \ \ \. \\ \ ~,'\ \ ~ 

I····) 

) I:.:':; 

1--' 

.. - :l;~:; __ ) 

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, 

, 

1 _____ ------------------------------------------------ ____________ _ 
Ni s. Chara Boehm .

PocateIlo JO83201-4816

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Ms. ChaTa Boehm . 

Mr. Ge"!B.e Coutis. ' ... _' 

.S:.J~i'O;\thA'l"o;"r;~~:· Ft"~ :'':i!. i. 

Pocatello II) 83201-4816 

---'~~--.. -.- . >--_.',.,. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

ii i i! iii 11111 ,1'II,l! ,I! i!!! Ii Ii 
To: Nuclear Regulatory Commission *. . .

Re: Depleted Uranium Disposal Rulernýking.

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact Ui,

that DU grows more radioactive over the course of one riillion years prohibits DU disposal at any of the current orfpending loy-level .wa~te,

disposal facilities.

Name"/' "•i, --

Address

Il &T4

- -- - -

,------------------------------------------------------------------

: To: NuclearRegulatory Commission : 

: Re: Dep'leted Uranium Disposal Rulemaking : .. i: .;; : I ~ : ": . .'. , 

, 

: The u.s, already has a massive inventory of depleted uranium still , 

: mixed with hexafluoride, so it cannot be disposed of. I ?;:. ~~J:] , , ~~: 

: Once that separation occurs, the size of the waste stream' and the fact ~~;~:I I \ I 1 .• ..) 

: that DU grows more radioactive over the course of one million years;: 

: prohibits DU disposal at any of the current or:pending lo.k-Ievel :wa~td. : disposal facilities, }.~ ..• :;) ;:,:; 

!Name ~ / &~-=~ eAd~;f f)1 

: Y4.-,,< . ..-J 2!itJe4'1'<- c":J 

: Address 33fp ~ /2~L I 

I Idca/e I/o Til r;J 2-0/ 
fr Ms. Chara Boehm "-r'"

Pocatello ID 83201-4816

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

.- .Mail Stop TWB 5BO1M

Washington, DC 20555-001

h 111111 i it. 11:1 1A -I- All: iIIIII

Chief, Rulemaking & Directives Branch 

Division of Administrative Services . 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

ill ilili II. I i .11 ii 1\ I ii! I. illili 
To: Nuclear-Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of de-fete'd uranium still

mixed with hexafluoride, so it cannot be disposed of...

Once that separation occurs, the size of the-waste stream a~nd the fact m

that DU grows more radioactive over the cir_'seof one million years

prohibits DU disposal at any of the current'0rpendng low-level waste"

disposal facilities. l

Name 4E .

Address \A i

,_•__ __ Lc-o

-- -------- --------- --------- -------

1----------------------------------------------------- -----------~ 

: To: Nuclear'Regulatory Commission , . 

'Re: Depleted Uranium Disposal Ruleinaking 

The U.S. already has a massive inventory of depleteo uranium still 

mixed with hexafluoride, so it cannot be disposed of.. '. 

-'-/,' .',: , . 

Once that separatio~ occurs, the size ~f the_~te str~~'~d the fact ::1" 

that DU grows more radioactive over the coltrse~of one mIllion years;;:! ...... < ,,,,.,, rr', 

pr<?hibits DU disposal at any ofthe current,pt:ipending low-level w~~~~: 

disposal facilities'@J"'Tl ., ~I - \~.:.;;: 

--t //Y'· - - p - ' . \ lo~ A/,-,-:·I?-- -' - :?,,"~;:'l Name' v ~ ,~. ~Ij;~ ~~ fil: 

Address 1-400 \jJ, 3~ : ~ , 

~~D~vlo~ 

f\ : \ 

~----------------------------------------------------- -------------
low'

Chief, Rulemaking & Directives Branch

Division of.Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

• .~''''l.: .. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
:,Io, Nuclear-Regulatory Commission

:'Rý ;.Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or-pending low-level waste:

disposal facilities. - *•1I-

:Name

Address 0S- ')

-----

I---------------------------~'~----------------------- -------------, 

:;Io~ 1'Jucl~ar(Regulatory Commission : 

::Re:::Beplefed Uranium Disposal Rulemaking : I .. ~ ,~ "I. 

, , , ,-

: The U.S. already has a massive inventory of depleted uranium still : , 

mixed with hexafluoride, so it cannot be disposed of. , 

, 

, 

-, 

, 

, Once that separation occurs, the size of the waste stream and the fact : 

that DU grows more radioactive over the course of one million years : 

prohibits DU disposal at any ofthe current or-pending low .. level waste: 

disposal facilities. -!n'-)~.:::=; 

Name \(~ Y\&V-~ e~(So Y- .J ~i:t! t 1 v, l:~ 

Address CoO s l 12 .Q.,~~" '5> -t:2: ~ W~ \72 (.J i I (,) 

Q~ ~ '::>~ J:-\) [~I VJ:J ':9 ~~ -----------------r(~~----------~==--- ~ qJ 

, 

, 

, 

, 

, 

, 

, 1 ______ -----------------------------------------------____________ _ 
PM'. I. T ~ '

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
T'Tq: Nuclear Regulatory Commission

Ke: Depweted uranium . -- sposai uemaking I

The U.S. already hask:&amassive inventory of depleted"uranium still

mixed with hexafluoride, soit.lcannot be disposed of.

Once that separation occurs, the size of theDiXaste stream and the fact,---., that DU grows more radioactive over the cou6rse of one'million years--

prohibits DU disposal at any of the current o, pending f v-level waste::

disposal faciliti s.

Address ..

IV -- --------- ------------- ------------

1-----------------------------------------------------------------

</:J'Q: Nl.lclear Regulatory Commission 

': R,.e:.Depleted Urani\lm Disposal RUlemaking , ~. 

·I.:~.~':"· .... '<'~" ··.~·'f",. . ....... : ,: ... _:>c'. "~-"" .,;.:':.:/ 

The U.S. already has:a:;massive'i1)ventory of deplete~Wanium still 

mixed withhexafluo'f:lde, 'So,it,c~ot be disposed of. 

Once that separation occurs, the size of themaste streariland the faci~~" "._',.'" I '.', that DU grows more radioactive over the cOurse of oneii}J.illion yearsC '" , .... ~_ ~~. ,.- ,'-1 - 1 

prohibits DU disposal at any of the currentoipending lqw-level waste,: 

:z:~~C ..• ~ : .~. Address ~~~ ~ \...',\~SJb\\)~ ~. &J' 

~ 

~~Slt2 -<::':-\ \ ' --:--, \. . \-

: 

1 \ \ 

\li\>yj)'O\~\~i\i~9'N~i~i ~ \ \ \ 1 \ \ ! t \ \ 1 : • \ \;. ~ I ~ t \ t t t t i 

~ e?!:?~\ CDZD dS)U , 

1 ______ -----------------------------------------------____________ _ 
L -"a

*1~*

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
7-- - -

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking.

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it-cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years IF

prohibits DU disposal at any of the current oripending low-level waste :-

disposal facilities. -7! 1

Name a('1.-cr . 2e 

:Address 4_.2q -, - I •f-

------- -- -- - -- --- -- -- - -- --- -- --- -- - -- -- - -- - -

1- - - - - '7 -.: - - -:.=:7. - - --:.- - -,::.~ - - - - - - - - - - ~.~ - - ---- --- - - - - -'- - - - --- - - ---:"". - - - --"j ~ 

: 

I To: Nuclear Regulatory . Commission -. ,: I 

I Re: Depleted Uranium Disposal Rulemaking,': ' 

"h ~':"':.t::f':~; 

The U.S. already has a mass~v,e inventory of depleted uranium still 

mixed with hexafluoride, so ltcannot be disposed of. 

. Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years :~ 

prohibits DU disposal at any of the current o~nding low.~·level waste :[~ 

disposal facilities. :-'fl l , .: 

\ ,,'-!::tt 

C:-? I~~.; _. - r j"l 

n 

-. 

~ (f) 

fYla....c :e. 5'""->0 • ....) " V1 Name -r'\ 

~""'~ ...... ~ &2L{ q-fh Ave.. ;;; c " ~-- Address ,--0 .... 9 

NCLwy>t" .... I dO-k.., ~ . .3 ~~J t-...) 

I 
PfI

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

IS 1J1iIi3555i1i91i1J53i9i15~III

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO I M 

Washington, DC 20555-001 

i"I,JlI,! 1,I,i"/,I,, i ,I II,Ii,' 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted urainium. still.

mixed with hexafluoride, so it cannot be di9i1sed of.

Once that separation occurs, the size of the wate stream aind the fact

that DU grows more radioactive over the course, of one million years _-

prohibits DU disposal at any of the current or pending lowAlevel waste

disposal facilities.

Name T

Address SZ51' (,d) ", W7-

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - -

-----------------------------------------------------------------. 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

, 

, 

, 

, 

, 

~: , _, c, 

The u.s. already has a massive inventory of depleted ur@.ium still r~:\ 

mixed with hexafluoride, so it cannot be di"fwsed of. ' (:::-, 

:-n ':-l';~\?',L , .... _ , ,.. ::;.--:1' I~ ... , 

Once that separation occurs, the size of the w~te stream ajld the faGJt'2:;'f~ 

that DU grows more radioactive over the coUf~, of one miijion years::.L'~; 

prohibits DU disposal at any of the current o(pending low:'i~vel waste ~ ----- .,,0 \l disposal facilities. -'"c\·· if) 

'0 ;:, 

Name J1u.rr fw;;er 

Address 
SQUSE.. TOa 83771

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M Washington, DC 20555-001

Chief, Rulemaking & Directiv,es Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

,;' 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking.

The U.S. already has a massive inventory of depleted uranium still,.

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the coursei of one million years

prohibits DU disposal at any of the current or pending low-level waste,

disposal facilities. --

:Name

Address Are '--

_________________

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking, 

The U.S. already has a massive inventory of depl~t~d,uraniurn stilL ,. 

mixed with hexafluoride, so it cannot be disposed of. 

.~ -~ :~ 

Once that separation occurs, the size of the w~ste stream and the fact :j";' 

that DU grows more radioactive over the coui~~1 of one minion years ,}:::~. 

prohibits DU disposal at any of the current orp'ending 10w:}eve1 was~~:: ;,' :: 

disposal facilities. i V,,; ;::t~) 

NameJ(~tdj~;:w;'·~ :; ;~C,~ 

Address iJ-*f( S.,,'~('k~~. = en 

'& tie I z;D ~~?OCf 
ON -r U 2H377

-~~2b~Aa V 

'~% ~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

~,~ •.. , 

Chief, Rulemaking & Directives Branch -

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

1".i,iil,,·,,1 i J 'I" i"I,I", jj,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemak[.ing"

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years

prohibits DU disposal at any of the current or pending low-level waste

disposal facilities. 713..

-Name

:Address /o2z "

M * I s- L-.-

--- -- -- -- -- -- --- -- -- -- -- -- --- -- -- - -- ------

I-----------~----------------------------------------- -------------

: To: Nuclear Regulatory Commission _ " 

: Re: Depleted Uranium Disposal Rulemakiiig I . '::1" ." , . 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fCl;ct 

that DU grows more radioactive over the course of one million years ~12 

prohibits DU disposal at any of the current or Pfnding lo\~':;level waste':}~ disposal facilities. J-.; <,b-:, 

Name ~i6 ~#I1ed .~ ~;~~1,~, /7c21 z 1t//t?Yl. sl-: . '~~; ~ - l(~ 

/ 

"1'1 --9 (J) rc1. <637CJ~ '0 ' .. 

,".' . 
, , -,i•-•'• .... ,-•~k:•.. .Y• ••," •-.•:

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

liilgIIhiJiIillililiigjIii - -.

Chief, Ru\emaking & Directives Branch .-

Division of Administrative Services 

- Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

.,. - ~ ,~ -.-
- - - - --

:To: Nuclear RegulatoryComrmissionn. h

.Re: Depleted Uranium Disposal. Rulemaking.

'The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

IOnce that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years ,

prohibits DU disposal at any of the current o-jr•-ending low-level waste-+-

disposal facilities.-

Name A m O\*/-,_,

" , +I -h

Address . ICII -0

- - - - -- - - - - - -

.... , " .c" 

:-- - --: -.. :-- ~ -'-": --~ --: --"':' -~ -------"- ~-...;. ~.:;:~~~:'~~~:;'''''~':'' ---; ~.-::;" -.--.- -------'''' ----, 

: To: Nuclear .. Regulatory Corimiission.· .~ .. ." .. . 

: Re: Depleted Uranium Disposal Rulemaking . I . . - . \ . . ~. " . . . . . 

, .. ,., '.' .. '. . , 

: The U.S. already has a massive inventory of depleted uranium still ,. ..' . , 

: mixed with hexafluoride, so it cannot be disposed of. I . I", , 

, 

:. Once that separation occurs, the size Q.f the waste stream and the fact , . 

: that DU grows more radioactive over the course of one million years-

: prohibits DU disposal at any of the cuttent orII?~nding low]level waste~3 : disposal facilities.- . . ,,,on . ~:;::; 

: '0 .--r: I ,-) :.. ;jj t':: 

: Name '~v ~,Ct v\. ~M, IV . :'I':'j Vl_'~!~:r~, 

. ~~ :J>' I I ill:j 

Address 3l& \:i> ' .. -( 0\~1 &!.. '.~'i~ :; l:~ 

_ __ S~O·':.-L.~· ~:"'=-----t--=-7""\ ;;:::;o;::.t.L G.t.£i0 __ ·.L-Y\Y/_' ~l OG - i~ I 

, 

, 

, 

, 

, 

, 1 _________________________________________________________________ . _ , 
.• ', .. .Z O -'57p ý " :

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC20555-001 -
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking I

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the course of one million years dt•

prohibits DU disposal at any of the current ],-Pending loW'level wast,--

disposal facilities.

Name

Address A- " - 40 .. r

dryt ~ fi 9D7ai

-------------~------------------------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking . 

The u.s. already has a massive inventory of depleted uranium still, 

mixed with hexafluoride, so it cannot be disposed of. 

Once that separation occurs, the size of the waste stream and the fact 

that DU grows more radioactive over the course of one million years ;;:!2 

prohibits DU disposal at any of the current ()rpending 10W:~level wasteF:; 

disposal facilities.--n ~ ~:~ ..,.-.-...... ) , ~ I. _ 

> •• ..,.I I ~i-> 

Name ~ ~ 

;:._~ i::f~ r .. ) 

Address ' --0 FJ ,::on 

(j) 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 
y 07

- .,- 1~ - ,- .4

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

h~ I! IIIEIIaIIIE lEE J31..1nA

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Ad'ministration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

f I,I! I illll' i ,i, ,1,1, il,II'1 ii, I 
-o ---i --- -

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste streamiand the facttý1 I

that DU grows more radioactive over the course of one million yearsi "I

prohibits DU disposal at any of the current or pending loW-level waste

disposal facilities.

:Name7 M&/> • KA T .s" y*

:Address 2 jtkO teOAVDDI V-D -

----- -- - -- -- -- -- - -- -- -- - -- -- -- -- - -- -- -- -

---------------------------, ~ ---- -.-::- - "":'~: -.~ .. -------------------------- To: Nu.~lear Regulatory Commission'N"":' 

Re: 'Depleted Uranium DisposafRulemaking ,--

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. 

:g, ':' ,0, f""~: 

Once that separation occurs, the size ofthej:Yaste streami'and the factr(~: 

that DU grows more radioactive over the cohlse of one rtfillion ye~rs:,'2: 

prohibits DU disposal at any ofthe currenfotpending lti~-level W~!~':-:; 

disposal facilities. /" ) Vl ~~ ':{~\ -n . 1--'-) , ::.:::; 1- \ 

NameTAM~ ,¥-iNk '-;'/ *- '1~1 ~==~-fB-+~~~~~~~~----------~~ .~.. U) ,'*\'\ 

r-l - -- - 0~1Dr; 
ZN)0 IMLVA- WJO)~t.

ML~s ýD0727r

-~-~- ,~<

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

jI! JI I I IIIIIIIIII l i II

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
- ----- --- -. I

To: Nuclear Regulatory Commission,

Re: Depleted Uranium. Disposal R ule-iakin -• ...

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so-it cannot be disposedof. .

Oncethat.separationýoccurs; the size of the waste stream and the fact

that DU grows more radioactive over thecour6 s of one million years

prohibits DU disposal at any of the current or-ponding low-level waste:,

disposal facilities. -.-- •

Address -3S5- w, (-C-c Hi( - C.- I*- ?

3 7 r,9

-- - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - -

---------------...,---, --.:. -------------,--'------------..: -, -.:. ----------, 

To: N~clear Regul~tory ~ommissi$n _' .,-,"-::: .. :~:e'-"" ': 

Re: Depleted Uramum DIsposal Rulemaking::: ""- , ': " ~ 

;.;.-'; .. 

TheU;S.-already has a massive inventory of depleted ~anium still 

rrii'xed with hexafluoride, so' it cannot be disposed ,of." , \ ' 

• • 

• 

• 

• 

:t;:) 

0_ 

Once,that-.separation·occUrs~ the size of the .;Q~e stream~d the fact \l~ that DU grows more radioactive over the~couis'~ of one mi~ion year~';;si [ 

prohibits DU disposal at any of the current O1::p.~nding lowdevel w~~e;:Jr:':::i 

disposal facilities. ' \ \ :;:><' ,'; :r::g~\ -:::;:: ::;.: .0 . .-! 

..g e. ~ '" ~ e L t P I~ Lc...£. «,;:fl -9 : ill 

: c:=J l Address ~ 3 g ~ w, R..ose. (-I:' /;( c...t /:::j:::- 2..-0 I 

Name 

• I __ ~ ___ -------,---------------------------------------_____________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

if1!11i, ! 1 1 111 1111 IIII~l

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington,DC 20555-001 

Inl! II i,,! ,I,I"I,I,;J ,I; II Ii ,I 

_. - '.r-. 
To: Nuclear Regulatory Commission..

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranum -stillmixed with hexafluoride, so it cannot be disp,5sed of.

Once that separation occurs, the size ofithe waste streamnand the fact :,that DU grows more radioactive over the course of one mthon years-.--o.

prohibits DU disposal at any of the current orpending lo7,level waste

disposal facilities. " ....

:Name W0

Address L•-• ,S'

- - - - - - - - - - -- - -

Ccj:-

·'.- - - -'- --- - - - - - - ---- - -~- - - -~_-.- - .. :- _ ... .;,.; __ .~..-r,:,_,,:,:~;;:, - - --- - - - - - --- - --- - --- - - - i 

:To: Nuclear Regulatory Commissiorr:-' .,.,. : 

I Re: Depleted Uranium Disposal Rulemaking . : 

I 

I 

I 

The U.S. already has a massive inventory of depleted ur,ap.ium-still- . ::r:j ., c l ' 

mixed with hexafluoride, so it cannot be dis .. p,o,sed of. ;: :, riC 

_"-' nl) 

,--n '=-'2 . " ~.:) 

Once that separation occurs, the size of"the'w~te stream1fnd the fap!.; ;.:: 

that DU grows more radioactive over the course of one mIllion ye#.s~~. 2::; 

prohibits DU disposal at any of the current o.t;Jending lo~:;:level wast~f13 disposal facilities'·--· -- ~I:'~ . fTl '".C? ~~ 

i J .,y;., "' I ,...t-q 0 <!t) 

fVl~ff-h/r7~uJ-~ --0 

Name 

Address tbTS(~}; 

7~~~ fo [>U~~ avL)~. ~-i/:AA~ fu -hevLcL.:;;;JOpd"\.r~ ,-------------------------:-~:~~------~:----------------------~ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

. i 1,1 ,I i i IIIII ~ J" i,i III ii", j 1,1 
To: Nuclear Regulatory Commission

Re: Depleted U.ranitim Disposal Rulemraking

The U.S. already has-a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of. "33

Once that separation occurs, the size of the-waste stream and the factFTI

that DU grows more radioactive over the course of one.million yearsi

prohibits DU disposal at any of the currenftor- pending lofw-level wagte,

disposal facilities. 1T .

t N a m e / l- 

]Address E/--) S, D_- cO

i'- © 2- - - - - -

To: Nucle.ar Regulatory Commission' ',,':;, 

,.... Re: DeBJet~~ U.ranirim DisposarRulemiIking .' - ' . ';'.'( 

TheU.S~ already has·a massive inventory of depleted uraniumstiU . 

mixed with hexafluoride, so it cannot be disposed of. , -n 

JJ --l, . ~-I 

Once that separation occurs, the size of the-:-':waste stream:.,and the fact(0: 

that DU grows more radioactive over the co'ui-se of one 'tiiillion y~aJ~ :;:'-l p~ohibits Dl! .d.isposal at any of the currenf:?~pending le'Y-level ~~j~~.: dIsposal faclhtles. _~__ ;)t:,..' .:) (1):::2: 

Name CO I\.I.)~ HeYl ~-e l ~ ~ -- ~i -..0 

Address S· looE2& 

1 _________________________________________________________________ _ 

__ •_____ == ___ c= ____ ~ •. _c=~ __________ ..... 
EY0i$V *ý3TE 41'

-2

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

j i Ii ! I J II ! 11/,1 ! ,I, i , iI, i ,Ill iii 

~- -
I I

To:. - Nuclear Regulatory Commission -I

Re: Depleted Uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the coui.g of one million years :rCprohibits DU disposal at any of the current orpe5nding low-level waste

disposal facilities.

'Name ... ,.

s--rfC 7,'' .Address 

-----------------------------------------------------------------, 

~o:,NuclearRegulatory Commission ' •• 'o..'l" ••••• "'~.. • I 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it caniiot be disposed of. 

" Once that separation occurs, the size of the waste stream and the fact 

'" 

., 

,::0 that DU grows more radioactive over the course) of one millIon years ,;;;; ................ I r "~\ 

prohibits DU disposal at any of the current or'p~nding low:"'tevel waste :d': 

disposal facilities.···") ""::, ;~;:! ~-;-". 

Name {;j~ M~~~·~ ~n (,.~ ?:l ~~:~ '''___ C) 

Address V\q /0" b S l'k &VJ l=q '9 ~ 0_ ~A \J 0 

~IW'{\ q~I01 --0 

1 ___ --------------------------------------------------____________ _ 
c~ ~ 0-2

1WftM ¶2(O

4.-

4 -

'N (

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I E!I~ Ill,,! 3 111ff uhf lslz!3Ilfi

Chi~f,. ~ulemaking & Directives Branch 

DIvIsIOn of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
. . . . . . . . . . . .- -- -- . ..--- ----- ---- --- - - - - - - ---- -- - . . . . . . . . - -. . . . . . . . . . . . . .- To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking I

The U.S. already has a massive inventory of depleted uranium still.

mixed with hexafluoride, so it cannot be disposed of.

Once that separation occurs, the size of the waste stream and the fact

that DU grows more radioactive over the couffse of one million years.-:ý:*

prohibits DU disposal at any of the current or-pending lowzlevel waste

disposal facilities.

,Name -- 1 ""

:Address 9"63 C.).

I,

'I

-----------------------------------------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. ,., -Tl ~ .. :~; ::n __ 0 .... ~ :--

Once that separation occurs, the size of the w~~e stream ~d the fact ::;:] 

that DU grows more radioactive over the couf~ of one minion years~::l::} .• _ -,,' t _ ~ _1,)1::,.: ... 

prohibits DU disposal at any of the current or-Pt?nding low~level wa$t,~t:··, 

disposal facilities.,~; 7>; ; ) ~;~:~~ .".".............. :.:z ( ... _~ -l ~J 

Name 5 coLC /<aug.( I ...i, -9 :~ ~J 0 I~ 

-.0 

Address Q().3 W. ALgCM.eotc:t 

,. 

r,. 

I 

I 

, 1 ______ -----------------------------------------------____________ _ 
20-29, PiM` 2cK'

w . "A tcx L~ 2 TC 5

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

~a(;t- , ~<.Jo.<... . . 3/lv l.: .. ftL. t .:ItJt:1!~r~: 2' '17 

'2636.) . A (,o.-..e&d. . 

~ F".e... ( tvWL 

~""l~\ 

Chief, Ru\emaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted uranium Disposal Rulemaking

The U.S. already has a massive inventory of depleted uranium still

mixed with hexafluoride, so it cannot be disposed of.

71-', Once that separation occurs, the size of the waste stream and the fact FT

that DU grows more radioactive over the coure of one million years L,,

prohibits DU disposal [ • tiesC at any of the current orjpending low-level wai~te,.IJ

disposal f.ci.ties.

<-

Name --

:Address $Y9//_ ._ -

, - -- A- N2

-----------------------------------------------------------------

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The U.S. already has a massive inventory of depleted uranium still 

mixed with hexafluoride, so it cannot be disposed of. '. ) 

. Tl .. ,' :)11 

Once that separatlon occurs, the size of thewa:ste stream and the fact ~~ 

that DU grows more radioactive over the coJde of one mIllion years E~:; 

prohibits DU disposal at any of the current g!'::1ending low-level wasfe~: disposal facil'ties. I 1 V1>:'~~ t-::!: . )~ .. »;:Ij 

Name 

Address 

o 

.L rr:, 

Ci 

~. t?l1.~?t7::fj)r-hf 

Cf;;~ . ?A~6L,. ------------------------------------------------------------~7--~-
4/:~

2l:y

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO0M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i!, i II i l'llli 11,1 i, i!, I, I" ,11,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,-prepare an environmental!"::

impact statement that fully evaluates DU disposal in a deep geologic

Name .

Address G;l•, A nn ll C'3,

w9 E 2.3 

1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking , 

, 

, 

: The NRC erred when it decided to formulate guidelines for depleted 

: uranium disposal in a low-level waste disposal facility. That decision 

: did not take into account the hundreds of thousands of years over 

: which DU grows more radioactive. , , , 

: 41-) :' ~;~_~ 

: The NRC must, as part of this rulemaking,:prepare an environmental\: , I ' "., ,,'., 

: impact statement that fully evaluates DU dis~osal in a deep geologic ...... : 

i::~4;()aJkii~." ~- ,~j ~.'.~ .. J: ' i I 9? <:" 

: Address /15\ G « /.)11(\ n~"',1 ~~ V1 t}j' , 

, 

, 

, 

, 
~2~~,

~ - t

~

-~-, ~-. -~ --- fl

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I, III, lid

·\i\Jdtt:"rs F~:'~~~~:fL:::j:\.t1;' t~:~::i~~:1£);···J;.i:;\:·:~~~~;~~::;:~~· ~. 

t·~~·~·p(m\"~·· 

Chief, Rulemaking & Directives Branch 

Division of Administrative Servi~es 

Office of Administration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,,prepare an environmental;-

impact statement that fully evaluates DU disposal in a deep geologic.i

repository.

Name Address.... -I

Address K.. c, , 

I Ij•-3 9 -_ ,

: To: Nuclear Regulatory Commission I 

: Re: Depleted Uranium Disposal Rulemaking I 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

I did not take into account the hundreds of thousands of years over 

: which DU grows more radioactive. I 

I 

I ::r~ 

: The NRC must, as part of this ru1emaking'1Pfepare. an eI1.vironment~r~1 

: Impact statement that fully evaluates DU dI,sposal III a d~ep geologIcr ; 

: repository. I \ ~-~·I 

I ; "",',.) 

i

Name l.f~ J-9~ "":,.'. 

.,., ..... 

.. ,., ..... -

7 

_~, i~. _. 1 

',:1 

. .1 

; .. ~~~~: 

--I 

<:! 

r-Tl 

U1 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

:.which DU grows more radioactive. 7-2

The NRC must, as part of this rulemaking$;prepare an .environrmental

impact statement that fully evaluates DU disposal in adeep geologic

repository.

:Name C( tX V-\-" "c..' •-

Address LVO

~QJ

!

?OQC Ctt 0G I-D co ý-1

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

I uranium disposal in a low-level waste disposal facility. That decision 

: did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. ~~:' 

-(l ' F 

The NRC must, as part of this rulemaking;\~repare an ':~.~vironmental 

impact statement that fully evaluates DU disposal in a,q~ep geologic 

repository.' ;~ 

I 

: Name I') I C( V\.. 0· ../ 

::. ..... 

\ \ 

: Address ~O 5" 1'\-. L\ (\ L ol~="! , 

-POCCSe[ \ 0 J 1;:0 g ::2 -z.-ctJ 

'---~------~~-'---~--7-~-'--:-~--11~-~-'-'------------ ------------------
.SAL*.. T ',&KZE -CITY tT 88-4-1 -

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services . 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO I M 

Washington, DC 20555-001 

:., .. ~~~""-.-.'l...-~'. ,~;. 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal'facifity. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact state ent that fully evaluates DU disposal in a deep geologic

repository.

Name .

Address s"ý. ...

• 1 ,3:.eV . . .,i '

t~ ..../

- - - - - - - - - - - - - - - - - - - -'"-- .... ..... 1 - - - r- 

------------------------------------------------------ ------~----l 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposaIJacii'ity. That decision 

I did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

I 

I 

The NRC must, as part of this rulemaking, prepare an environmental 

ent that fully evaluates DU disposal in a deep geologic 

.- .:' 

Name I i 

Address 13ft( ~<:e be:r ~ r/?t:~:, 

6~ ~ I TIL £3 2=>::~ r . I i 

o 

I_- ____ ---------------------------------------------~-- __________ ~ 
____ _e _,_I--83204

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

I"vlail Stop TWB 5BOIM 

Washington, DC 20555-001 

it I i I II i! ! Iii i I! ;j;i 11111!1! iI II 

, 

'. 
--

To: Nuclear Regulatory Commission

Re:.Depleted Uranium Disposal RulemakingThe NRC erred when it decided to formulate'g.iidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

D C( " , 2•F1 , 1

The NRC must, as part of this rulemaking, prepare an environmental ,

impact statement that fully evaluates DU diWposal in a deep geologic:".-

repository. .- - t tFi: 

Address • J i." / vi56"1 t.L--I

I- --- --- --------

l----------------------~------------------------------ ------------, 

: To: Nuclear Regulatory Commission : 

I Re:.Depleted Uranium Disposal Rulemaking-' : 

I 

.. .."", .:....:; ... ~.. . . ..<.;..~1~'~'::':';: ·~"~.r;;;., 

The NRC erred when it decided to formulate,g~idelii1es for depleted"· ";;;:~'::'~:;f:' 

uranium disposal in a low-level waste disposal f~~ility. That decision : 

did not take into account the hundreds of thousands of years over : 

I 

which DU grows more radioactive. i ., ~.L 

--r1 :.': c:! ..-A-J ... :1 1_" 

The NRC must, as part of this rulemaking, prepare an environmental D:: 

impact statement that fully evaluates DU disj>Qsal in a d~ip geologicr: ~~: 

repository /; ___ /> ,," /)\ ~ r::: ~' ~ ~!; Name \(J f:..;;; Ie 17 LJ-' U '~~4 -.AJ ~ 

Address to } 6" b'~r . K E:nJii-LM ~rt13 LWjl 

__ ~~::::m ____ ~mm~m __ m_j 
g 34z;

Chief, Rulemaking &,Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B10M

Washington, DC,20555-001

Chief, RlIlemaking &,Directives Bmllch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC·20555-001 

·",I,II'n"I,I"I,',,',I"ill,1 
To: Nuclear RegulatorWCommission

Re: Depleted Uranium Disposal Rulemaking

:The NRC erred when it decided to formulate guidelines for d6pleted

uranium disposal in a low-level Waste disposal facilift. That decision

did not take into account the hundreds of thousands of years over

which DUI grows more radioactive.

The NRC must, as part of this rulemaking, prieqpare an environmental <:

impact statement that fully evaluates DU diip-0sal in a dep geologic V

repository.

Name

Address 49 "

- -,' - --- -- -- -- -- . . -: -- . .. . -------. .:" ---- . ..-- : • • •'e- •

I -3- - -- -

: To: Nuclear Regulatol¥'Commission , 

, , 

, 

, : Re: Depleted Uranium Disposal Rulemaking , , , 

, 

I .' .- ~ '. .~ .. 

'The NRC en-ed when it decided to formulate guidelines for depleted' 

uranium disposal in a low-level wasiedisposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

," 

The NRC must, as part of this rulemaking, pij'pare an e~~ironmental e:; impa~t statement that fully evaluates DU disp(!Jsal in a dt:~ geologic 51 

reposItory ~ I ~i~ ~\;:::-- :;.f~ fi..yl! ~::~A '!/ "7: ~l Name I~~ ~ y;"\\t'Jf' 'i[ ,(! a~"~ iJ1;~< lJF?JA~~'~" ,~lf;!!f: -: ---......., ~ 1-.." .:.- ~....-- ~ t.~,-~--

Iq ~ (.;1;::s.-;~'Ti '.--, ... ~, ...... {j [":: 

Address :~_t5 ~~~'" tJ ,C~ 'I ,~,1- ~~ Ie ,:.::" ~, _ ':1;,~t .. " 

i{ ,('if '-~ I. I"'::::-!t:!t. &' ~.::::J; 'or J:? "'''' f,j'::i'~" f( i# -('A'\ ~ "~'--''''' ~ !e::§.. \r., ., "'" .:"':~[2k;: . V II'A# -....0 'l..:;:;,.....-""'- ~ .t.~.;:::J I ..... n' , \ ~4 c:~ ..... ~ .... ~.ct""{ ", . I 

::s,V;'l(0?r;;"~,(~Q ,-oc.;~~ ~ , 

.~~ _70 ~}~ ~~NJ3 ~ ~~~~\ /J : 

".:':3! t:.~ "/1" .~"fi~{ ii) ~ , 

-~ -fj-";']j?t-----~-i\ --&-, ~~~~~/-- -------~~ ---- L~)_ --~ {Ti0-;-·~g --~ "" ',,, " ·c-".., , ' f;,'j, '\ ~.. - ( .~ ~ 

• /,C .? \; .. J::;'?"'1' 

",v r~l!-

,:,! l.~ ·.l;,d' ,) .~,'ft,:~' 

( ... __ 

I.. 

~ 

.. ;-c,.;:·· 

..... :~ ". 

c· /,;.. i ~ -..';:;".. 
Ii IC; -3

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I! [ If If

Chief, Rulemaking & Directives Branch 

_. __ Uivision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking -

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic

Srepository.

:Name

Address r' (A xd

- ---- I

I------~------------------------------------------------- ---------

: To: Nuclear Regulatory Commission 

... ' Re:·Depleted Uranium Disposal Rulemaking ..... 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU disposal in a deep geologic • 1- } 

repOSItory. _u ~a ~: 

Name 

Address 

Tl r-, 

rn, 

C/JI 
Chief, Rulemakinrfg-1Jirtives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemakin-~ifectives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

f /Ii ,iii II !I i Ii Ill, i I! id!ll ii II 
- - - - - - 7-- - - - --- - - - - - - - - - - - - 7 - - - - - - -

To: Nuclear, Regulatory Commission

,Re:.Deplefed Uranium Disposal. Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,pDr~epare an elvironmentalt4

impact statement that fully evaluates DU disposal in a deep geologic•,:

repository. -

AddresL 'L -0

( )I

'N)l

Ž70-6 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

I-------.------------~----~~~------------------------- -------------

,.': To: Nuclear. Regulatory Commission 

:Re:Depleted Uranium Disposal Rulemaking I '.. . . -~~ .. ~ ... , . 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking,-~f.fpare an e:!tyironmentale impact statement that fully evaluates DU disp,osal in a d§ep geologicr=;; . I I i";' u) reposItory. ----.,:< 

) . "("'j vJ 
04-.

Chief, Rulemaking-&-Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

1111fl l l il,, J lifl~hdi~l[fl

'.; . 

. ".,-:': 

Chi~f, Rulemaking~&-0irectives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5B01 M 

Washington, DC 20555-001 

i 1/11 iII I! II illl! i .I IIi ,ill ,ff ,t 
To: Nuclear Regulatory Commission Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic

repository.

N am e "C_ n "-A<-

Ad ress •/ 3, :..

C~l

W/_I

---------------------------------- -------------

T.9: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

. did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU disposal in a dyep geologic 

repository. JJ:;:;] 

il 

Name M-\\Q N\.a \,\CJlA" \) "j 

"'-1 

Address d- D N, vJ -\ \ <, 0 ~ ~ t ~ --rj g}7 ;O.-~& 

! 

~, 

' .. ,.', 
Chief, Rulemaking & Directives Branch

-...- Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

... _,~"Qivision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

f"i! iHlI!; I,illlll!! i,i I!!Ii!i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking. "

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU dispsal in a geologic

,repository.

FI1 :Name -

Address --

/ 10

----------------------- - -- -------------

To: Nuclear Regulatory Commission 

Re: Qepleted Uranium Disposal Rulemaking., . 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

," which DU grows more radioactive. 
Chief, Rulemaking & Directives Branch

-- Divisidn-tA- dministrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

dWashinon, DC 20555-001

-t .• ". •. 

X: ~. 

Chief, Rulema~.!,lg & Directives Branch 

-- . Division' o(Administrative Services 

Office of Administration 

U.S. NRC 

, Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

'"idli I Ii d,i'l i d! I id'llll Ii 
I-

,To: Nuclear Regulatory Commission

kRe: Depleted Uranium Disposal Rulemaking- , ,

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive. .. ,

The NRC must, as part of this rulemaking, preIpare an eriironmental',' "

impact statement that fully evaluates DU disp'sal in a deep geologic i,

repository.

Name

Address T-" _ /, o..jy V4 <

V Co_

1-----------------------------------------------------------------

'. :T,o: NilCl~ar Regulatory Commission, I·, , ..... ".. . ... 

- 'Rt!: Depleted Uranium Di~posalRulemaking'<~ .:. 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which -!?U grows more radioactive. ]J ;,,; ~:' 

-"-j :-::= CI:I 

, The NRC must, as part of this rulemaking, ptepare an environmentat ~:' 

impact statement that fully evaluates DU disp.qsal in a deep geologi<;i U • j. LV __ ~c- , 

reposItory. ' I '! C5 s-::, 

Name C;{~a1 Wb~tl'~ : ~T~ I. ;,,..j J:;: v" 

Address \:J \ ~ fa. ~ Oufl ",ex 1< "Dt ' --0 

~J \~) 1.\). 12J a 2. 

1 ______ -----------------------------------------------___________ _ 
-tv

Chief, Rulemaking & Directives Branch

Division of Administrative-Sfervices

Office of Administration

U.S. NRC

Mail Stop TWB 5B0IM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of AdministrativeServices 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

il,/,/li III! i, i, Illf I ,Ii illinii 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,-prepare an environmental 27.

impact statement that fully evaluates DU disposal in a d&ep geologic'

repository. -,

Name 6 V -_7..

Address 2-/0-3

--- ._-,-- --------- - J- -- D-- ---------------------------

_ _ _ _ _ _ _ _ _ __I

I Lh~A2O

-----------------------------------------------------------------, 

To: Nuclear Regulatory Corru:nission,. 

Re: DepletedlJranium Disposal Rulemakirig '. I ",_ 

"," 

The NRC erred when it decided to fonnulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. 'That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

") 

,~ :;!:;.: I -0 .. :: \:=: 

The NRC must, as part of this mlemaking,:-p,repare an en~ironmental [8: 

impact statement that fully evaluates DU di~p6sal in a d~~p geologi~~ ~:~': . , } l' : ... ) .~ :,,,:.:: r" -:. 

reposltory':"r~l lAo! •. ~;?::: ;:~: 

".~.~ .:') ~~~ ~I:. ~ ,> I I 

:-: .. ,_ :z:. C'I 

I j "-9 ~~;l 1'.1 

N. 1911. .. sSi;J ~ Ui) 

Name 

Address 2/0...3 

:Eo is e.. ;;I .I):) 
2/103 ,Py /,9-4d-

,7i;sZ e z -V 2

-4 ......

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington. DC 20555-001

2,/~3 nt. /2P--r.-

j!x,iS e., Xj) ~3h2.. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington; DC 20555-001 

i, ,i,iii!!!, i,i!, I,i" i, i ",ii,i 
,To: 'SMlMar Regulatory Commission ' -

R:'1DepletedUranium Disposal Rulemaking

The NRC erfed when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive. c-,

The NRC must, as part of this rulemaking,.prepare an environmental

impact statement that fully evaluates DU disposal in a dCep geol6gic

repository.

•., F] •-IF

:Name P 4 FIA

Address •

te:~tr'l!?l:ear"~egulatory Commission .. 

RE: Depieted,Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. [1 :.) ~ -'''-'} fill :-11 :";;:. u:: 

The NRC must, as part of this rulemaking;,.prepare an environmenttiL::-:: 

impact statement that fully evaluates DU dis~osal in a d~~p geolog!£ ~~:'l repository. \ I,'·:; (:? :+: 

Name fl+r;~ 13~ ,:~ ; ~~: Address 307;?o N J. ~?; t!:tS+J 00 

BorS-e- Jf) P3?o2--
Chief, Rulemaking & Directives Branch

-Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

- -Bivision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

. Washington, DC 20555-001 

ill i! iii! I!! i! i! Ii! i! ! i I r III Ii rf~' . 
To- Nuclear Regulatory Commission,

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic"'

repository. Fi -'

:Name 5)_ Air G -1 LIt-- ...-

Address [-7.C 5 ,VqjV 

I._=•.............................................

. - -----~-----------------------------------------------~-----------, 

To:-Nuclear Regulatory Commission' : 

Re:l)epleted Uran,ium Disposal Rulemaking :' 

The NRC. erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an eIlyironmental 

impact statement that fully evaluates DU <!!~p,osal in a d~ep geologic~: ·t '-' -- Fr I reposlory. ; i I c>; 

Name V.4:{ tv 12: 6--1 L' 'L 

'--, 

-) 

,-l 1 

'v) 

. -' : 

/ 

I 

I 

I 

I 

I 

I 

I 

---.--~----------------------------------------------- -------------
Chief,-Rliem-ki'ig&-Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington,_DC-20555-001 Hl I II Hi :,1 1 1 i I!I : tfi , I N

Chief,-Rule1i1aKmg ~>Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington,nC20555-00 1 

'I!L ffI!! i! IIi! ,i,l,!i ,11I,li,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental z impact statemen that fully evaluates DU disp9ga1 i a deep geologic 1:

repository.

Name

Address 0 " t O7 1 I

I ....................................-- ,- _-------------

To: Nuclear Regulatory"Commission 

Re: Depleted Ur~ium Disposal Rulemaking " . . 

The NRC erred wheri"it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. ) , 

The NRC must, as part of this rulemaking, p!~~are an en~i~onmental ~I"? 

impact stateme that fully evaluates DU disppsal in a de"ep geologic n~ repository. ~iik~ "':- . ~ ~): A --: .. 1 l~1 l l:~~::' // (-I 

:.>1 ' Name ~..,.",. -,", 

~A::.:d:..:dr=-e::.:s::::s'--__ -+...L......!o.o<!~L--_'-:~:~~o=----'-,r:~=I-;L-__ 4 __ ?t 4- iJ 

' co , 

, 

, 

, 

, 

I _____________________________________ ~~-~~--~--------j 
BIC).

-44

r--rrr V -v

.........

L_8_

Chief, Rulemaking & Directives Branch

.Diyjsjio-of-Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

A . R...~m {)CT' ~;q(!A ~fkT. :r;;;>·. 

ll()\ JVo. ~th *A- .~;,"" .,- .. 

;&".!X.- j..-dPk 

Chief, Rulemaking & Directives Branch 

,.yjyis.i.on-of-Admi n istrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal. Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,-prepare an enrvironmental .... r, impact statement that fully evaluates DU diposal Ip i a deep geologic 

repository.

ýLame 61M

Address -7 z-i , S ,,•.--r,. Ia

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted..Dranium Disposal Rulemaking . . 

.. 

The NRC~rred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part ofthisrulemaking,-:-~r~pare an e~Y.ironmental ~:! impact statement that fully evaluates DU diSRbsal in a d~ep geologic (I.-: 

:::IOrySIM ELAI~ .~ = D~~i -1-! ,~ "'f? ----1, 

Address =:7 ~ <0 52 l>-,.J~ h. '? $>5.h--I»,-<1.~ . -r.::: m! 

00 , 
zgligl T P4-f-R V . T~ ..... ....

Chief, Rulemaking & Directives Branch

Division of Administrative Seivices

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

11111 [Ili IIII! i I III If d Ili I di! i

74f (, cS~ !fudl.- 4-. 

4d... t:!J B3 7 I J. 

Chief, Rulemaking & Directives Branch 

Division of AdIninlstrative Sei'vices . 

Office of Administration 

u.s. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking . I.

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental (rimpact statement that fully evaluates DU disposal in a deep geologic-",

irepository.

Name

:Address &

---

1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission , 

. :Re: Depleted Uranium Disposal Rulemaking " , 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

10 ;:i _D -' .,-' ('-

The NRC must, as part of this rulemaking, pryRare an enyi~onmental f:~ 

impact statement that fully evaluates DU dispo~al in a de'ep geologic, __ ~:':' , • ), .. ,'C'>< ",' reposItory. , .. , .... , 1 ".~::! ~:, I ! ",.1 , -,,:; \,',' 

Name K~.~$ ~..'~~2~iJ I ! "f? -,1 

Address '0 oS (5, ~ ~ -S-:}J J:;;: S~~ '-.I , 

~, \O'b-37)~ i , 

, 

, 

, 

, 

, ------------------------------------------------------------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

ill If III " I 13f 111ffl

Chief,-Rulemaking& Di~ectives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

iuil; iiI! IIi ,iuf,l IIlli,! ;fiji 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when itdecided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

-did not take into account the hundreds of thousands of years over

which DU grows more radioactive. - -,

The NRC must, as part of this rulemaking, prepare an enyironmental!

impact statement that fully evaluates DU disposal in a deep geologic :',-

repository.

L _me C2 n -; 'Name "•oc* -t, \ \YC, 77, -.

I Address 1 11wAy•ri71,-c(qLI -' ' " °CY 'l7-I

To: Nuclear Regulatory Commission 

Re: Depleted UraniurnDisp,osal Rulemaking.,·::.··.· 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposed in a low-level waste disposal facility. That decision : 

_, did not take into account the hundreds of thousands of years over ': 

: which DU grows more radioactive. - " :J:: 

: IJ "C:' ~l:::-r:l ---'... p_ -. .. J. 

The NRC must, as part of this rulemaking, prepare an enYironmentaL ~~:,:: ....... _ ..... , -- ..... ~ .. ,:J .... ). 

impact statement that fully evaluates DU di~P9sal in a de~p geologi~;J.l::· 

repository. "r") w <~6 S+; .~ ~5: .LfFi 

-- ~--- ~:~ N"--:..::am=e"----:s-=:..I.'L)~t't:....:n-'-'_'e.~...:...\-..:..fJI..:...v.::......::::c_;~ ___ __'_,-~-lf_I~. _ "f? :1::: 

[:8 

Address 
Chief, Rulemaking & Directives Branch

Division of-Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division ofAdmihistrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

ill;. (iiil II Lf! ,I! il! itt!, !1I,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision.

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep-geologic H

repository. -*.;

Name i.. -..." '

:Address O: . -7 Q lA-.. .

. .. ii NA

---- - ----- - --- --- ---- --- ---- --- ---- --- ---- --

---------::------------------------------------------------------, 

To: Nuclear Regulatory Commission .: 

1 

Re: Depleted Uranium Disposal Rulemaking .... '" 'I 

, .. '"·~d~;:~~;;~~~:;;:;~~!::;::! 

The NRC erred when it decided to formulate guidelines fordeplei~~" ": : 

uranium disposal in a low-level waste disposal facility. That decision,: ' 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impa~t statement that fully evaluates DU disI?~al in a de~'~Jgeologic .:~ 

reposltory. -rl t;j 

C\ {) ~-) I~·. 

Name r-Pr "'" LO Iv L~ ··'r:·; t~,) ... J :1=.' 

Address ~ l l W ~'-~V\.(ct~0~i~w C) I2iL :h) (!] 

I .~ 1_ 

($.'OIS:L ~b' 6'SlQ~ ~ ?J 

p~ rA-1)l .. ~ f~c..o",\'t.y~ ~b\e:f\e .V\J:tt- ------------~~~~~------------------------------------------~ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

"I>,'j 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

ill i, 1I1"/li,l, ,i ,1"i,L" ii,; 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,-prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic Fr-i

repository.

Name '- ;•c.

CI

d 90 1 (53F 2ý,- 1

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

I did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking,-p,repare an environmental :::r.-

impact statement that fully evaluates DU di~~osal in a d¢~p geologic ~~: • ; I '-- j-rll repository. "'1 S;j co: 

6 2f . -_/ . 1 

N ~~ 1- ~//~-4" /T'"l I,..j (:1 

arne ~ _"C--~ .'~::- '.) :r.;.'::f.. ' .... j 

Address 13(2- Ci4A~ g'n ;~ I'-J gOte W' 6:370(;; 

, " ",jlil 

1 _____________________________________________________ _________ ~~-
Chief, Rulemaking & Directives Branch

Division of Administrative Services

.Office-of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

i,,I Iil:,,:ii i ,, .h. illd

Chief, Rulemaking & Directives Branch 

Divisioll of Administrative Services 

.office-of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i"IIII/, II,i ,i'li Ii, ,/,illlll,/ 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemakingp-,pare an environmental. ,-,

impact statement that fully evaluates DU diý,osal in a deep geologic R

repository. -

-nI)

-Name -(-- J --- --- - - - - - - - - - --.. -- ---..- -

I -

I. . .. . . . . . . . . . . . . . . . . . . .

.-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

'Re: l)epleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

I 

I 

I 

I 

I 

I 1 ______ -----------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

* Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 21555-001

It Jf IIIIJI fit IIIII 111if iffilill

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washi.ngton, DC 20555-001 

I,! 1,/1',,1,1 ,1"1,1,, i,II" Ji,l 
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --- - -- I

To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic

repository. ..

Name UG"

Address " " fo i'

I J-- -- 

------------~----------------------------------------------------1 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU distiQ~al in a deep geologic 

repository. :J."J 

Name 11W3 Gb~':I~{ 

Address 5~S ble. 1-1 -t(J~. 7 ~~ 

\2pf){ L{), Z37/~ 0 

, 

, 

vJ 
Bw•

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i" I,ili.,jll, L I i,l, ,i,i'lllif; 
To: Nuclear Regulatory Commission,

Re: Depleted Uranium.Disposal. Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemakingpTypare an environmental 5-:

impact statement that fully evaluates DU disposal in a deep geologic -

repository.

Name/

Address ___ -.

------- -- I b -4

:- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -::: .. -",-![..::.~.- - - - - - - - - - - - - - - - - - - - - - - - -, 

,To: Nuclear Regulatory Commission' , : 

:' 

: Re: Depleted Uranium. Disposal. Rulemaking " 

I , 

: The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal ina low-level waste disposal facility. That decision 

did not take into account ih~ hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, 'Ptjpare an env.ironmental ::I_, 

impact statement that fully evaluates DU di~posal in a d.~~p geologic f: • I ! '::,::':') ,- "", reposItory. , .. _) < ~:~: 

Name ;}u~ 'I"i~: ;) =:, :3J: n~: 

Address ;'r) '!? C-1: 

<- rn' 

cn: 
Z F, TV -F,3' 

4~rn~.\ 'C

Chief, Rulemaking & Directives Branch

Division of Administrative Services

.Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Jill1ilL 1l1)1~l1l1J1J111fl1)

/' .' ' .. ,;Bt~'rSE->r·D.:,837 

_/.~\ u( ·~t:.':t~',.,~~~.:,;J: ... ~~:\:;l'!i'. :~). ':RN /j?:·1· 

P,.W D~ 

~ e.--~ ~ ""~) ~ckJ-.1) 

~33L\ 0 

------

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

. ~ .. _,,=~.Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

jill, JJ Ii ",I,J,,1 ,I" j,l; "il, J 
To: Nuclear Regulatory Commission

Re: Depleted Urainium Disposal Rulemaking..

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste disposal. facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU diposal in a deep geologic c-:

repository.

1Name C 'c-. . , . Addres -

e0

1----------------------------------------------------------------- -,. 

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal RMlemaking,.", 

: ,,' . ~~ ·1t/.~~:~··~.~::-:; ... -~':"::~' '~ 

: lJle NRC erred when it de<;ided to fOrrinilate:guidelines for depleted 

Uranjumdisposal in a low-level wast€tdisposal, facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, '~repare an env;ironmental 

impact statement that fully evaluates DU disJ{osal in a deep geologic e: . I , ~... ::;:, reposItory. ---'. (,;::3 :_ •• ~I o \ r') ( ~ Jr'-r< ~~:: " . 

Name ~cu- ~,-\- cA.-t t--;:::,! L-_' 

~""'- ~~ 

Address l ')0 Z- rv· '1 ~ 71, .T'j 

(0 '-.,) 
P -1 1*2-

%....A

~

- ~.-~-- -

> I

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO0M

Washington, DC 20555-001

if J,11l,,,, I ill JiJi , iJiJi

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

Washington, DC 20555-001 

i III ,1//" 1,1,/" i, i "i ,i 11,11,1 
:To: Nuclear Regut'atory Commission . .

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over :which DU grows more radioactive.

," - c'i

The NRC must, as part of this rulemaking, prepare an environmental T

impact statement that fully evaluates DU disposal in a deep geologic -

repository.,-

Nae

A ddress .. . .. . i. i . - .

-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - ---- -- - -

7) ,. ,''1"133 5 k

1----------------------------------------------------------.--------

: To: NuclearR,~gltJ~!9ry Commission .,~.,,-..,-.. , . 

'Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided-to formulate guidelines for depleted 

uranium disposal in a low-lever-waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

~'l .~: eJ 

The NRC must, as part of this rulemaking, p~~pare an e~Yironmental h:: 

impact statement that fully evaluates DU dis~9sal in a deep geologtci ':;i 

repository. -. .) ! ,,>~:2 c~: ,~:.r~:"· . -T'l \...oJ 1 ", 

I ~~.. J' '-'-::11 . ::: :: ·,:r~.;~1 :::: 

N"-'-"'am=e"'--------'~'-'__'_ n~....;.(~r'\_'_"_"d~_·_\'i_c_-'-r _i _. __ ,-"",--,-i--,:~' '-'!..,,/=-=").,:=:(.:::;' ~':''--') ':"~ :: . 

£ ~ . j ._ :7 i-os -,.0 ~:! 

Address ~'·U iL;:}J ;;;:. I' l ("!fiN ~\ l~~ S:) ~====~~L-.~,~~ __ ~~-~~-~L--. ~ , .... ~. ,:' / '"'/ 1 

,./) , f. // (')': "~t. /;, / ~ ,-" : 

,I , "" :. " "7 '. , 

, 

, 

, 

, 1 ______ -----------------------------------------------____________ _ 
W-1. 83.2, 

~8j~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

it fifilif I If if If I It If I if if I I IiIi

· .. .' .... 

2tC~ O;C:=(':2;i,Q09! &"l'ff.,~ .2 T 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission. ,

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

urani-m -disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evuates DU disposal in a deepgeologic

repository. / ] .,

'Nare I

Address2

C*_ Oed

: ----------------------------------------------------------------- 2

-----------------------------------------.:. ... :. --- -:.~ ---------------":'-, 

To: Nuclear Regulatory Commission,_ «, "". '-. ',' 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uraniu..udisposal ina low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully ev ates DU disQosal in a deep ,geologic 

repositOry~ /, JJ, ~; :~ , ! .11 . i-n 

Name 

' 1- ,!. -), :J:: F/J j C'::2 f: : 

Address ~ ~_~ LV, j t~ 

0kUeN CY7 J Jaij t<;~i ~ I 

1 _________________________________________________________________ _ I 
81011SE". 10* 837

~~*Vt. Z T

Chief, Rulemaking & Directives Branch

Division-of Administrative Services

-Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

hII~IiJf I ~ 1d15 liII

Chief, Rulemaking & Directives Branch 

Division ·of Aaministrative Services 

-Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i"l,tll 1111 i,ill/,/"i,l" ,11,1 
:To: Nuclear -Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU dispoýal in a deep geologic

repository. ----i

hName f f & .S AjO .......

Address -1-13

I - - - - -

---------------------_._------------------------------------------, 

To: Nuch:~ar Regulatory Commission : 

~e: Depleted Uranium Disposal Rulemaking I 

The NRC erred when itdecided to formulate guidelines for depleted 

uranium di~posal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU disp,o~al in a deep geologic 

repository. =-n ~'~ ;~~ 

Name R I :leur-I RJ·S 5; I N.b :~ ;1:: ~=~~!-..:-=:.:.....:c:=-.!~-----.:...-----..:...+_J +,- w. (~L 

Ao 13 aI...(3 3 .... -< c::. Address r ,0)( I .'-.... '., /::i 

I I ~.'., 

H~~Jlv./h' \ lD f33Jy(); ~1 

----------~~~~-----~-----------j 
Chief, Rulemaking & Directives Branch

Division-ofAdministfative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

J 

.~ 

Chief, Rulemaking & Directives Branch 

Division-of Administrative Services 

Office of Administration 

u.s. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

71~]

The NRC must, as part of this rulemaking, prepare an environmental F,

impact statement that fully evaiuaws. DU disposal in a deIep geologic-,,,.

repository.

Name &

Address 53-z 2 'J. -o -5 5• i4: F*

L/J

-- -- - -- - -- -- - -- - -- - -- -- - -- - -- -- - -- - -- -

.-- - --- - - - - - - - - ~.-.,.- ----- --- ~ --- --- - - - - - - - - - - --- - - - - - - - - - --- - --- - --

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking .. I 

I 

I 

: J'1!eNRC erred when it decidftd~ formulate guidelines for depleted 

uranium disposal in a low-Ievel~aste disposal facility. That decision 

did not take into account the hundreds of thousands of year's over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, p~dpare an erivironmental fr: 

impact statement that fully evalual~s. DU dispbsal in a de@ geologi9., U: 

repository. ~ ) : '.~ ~i~ C~: "Tl w --, 

Name ~ & G 'f Yi v, W <:: 5.:;.: .::~ ffl =-=~~-'--~::"'-='--..!..--~--=--~~..:....'.-=-·':;r=-l- '9 ~: 

Address " J:tt: <J ?l vJ. "TAr' 5\1'_ .r:: Uj 

V1 I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

,------------------------------------------------------------------
C h3if,j Rulemaki-tg-&-Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

-- Washington, DC 20555-001

.. Chief,· Rulemakihg-&·Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5B01M 

- ___ Washington, DC 20555-001 

j ,,1,1/ I" " I, i" i ,I" i, J 11111,1 
-To:-Nuclear Regulatory Commission

Re:-,Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate-guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental =

impact statement that fully evaluates DU disposal in a deep geologic r-i: C_

repository.

Name TI

Address I10 S(y "fI. (714• A4_ .... • )7.-.. "J-.

To: Nuclear Regulatory COn1mission 

Re:-Depleted Uranium Disposal Rulemaking . ", ~.'. 

The NRC erred when it decided to formulat~_guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the· hundreds of thousands of years over 

which DU grows more radioactive. '. 

The NRC must, as part of this rulemaking, Qrepare an environmental :x 

impact statement that fully evaluates DU di§I!6sal in a deep geologic f=: 

repository. ; JJ ~~5 G: 

Name S4f{'\..R1V".. 

Address I 0 2-- ~ 

'~IS~ 

. " .r-;: -r ,I 

Cf(Dwt£'-tr::j ~J ;:,. ;! 

s bw~~ h(A~: ~! 

)b <fS3:&1- ~ ~l I 

I 

I 

I 

I 

I 
HAmik7' u

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

I 11l1 IiIJfIII~hIII*IJfblills

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I, ,i,JilIII , i, i"i, i'II,ill,Ii,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking I -.

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental f,-

impact statement that fully evaluates DU dis psal in a deep geologic,'

repository.

Name -. .. ! ,

'Address 0 2'

0 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - -

l------------------------~~·-------------------------- -------------

: To: Nuclear Regulatory Commission , .-

: Re: Depleted Uranium Disposal Rulemaking , , 

I·.·· 

:; I.' ".''''''.\ 

~ the NRC erred when it dec~ded to formulate guidelines for depleted 

, uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, ~2pare an eri~ironmental eP I l"-'~ 1'-', 

impact statement that fully evaluates DU disp~sal in a d~~p geologic e:: • ..J "- ". I repOSItory. ---r:. I ,.c', I f l~.J : 

. :-:] r~:::,: 

Name ;:=:~ . 

Address 

1-- ____ -----------------------------------------------____________ _ 
Chief, Rulemaking & Directives Branch

-. Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

.:"': ••• : ...... <;,,' 

Chief, Rulemaking & Directives Branch 

-- :Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-00 I 

1111,111, IIli, i"i,illlli,,;'I,1 
To: Nuclear Regulatory Commission,

,Re: Depleted Uranium Disposal Rulemaking.

, The NRC erred when it decided to formulate guidelines for depleted.

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep, geologic,_

repository. - . -,;- ' . ,

Name ,v, kf,., 1(I.(: 2-}e 

Address I ' , ":-- _ _ _ __ _ _1

8 5R 7

----------- -- - -- -- -- - -- -- -- - -- -- -- - -- -- -- -

1--------------------------'---------------------------------------, 

, : To: Nuclear Regulatory Commissio~, " ":" 

: Re: Depleted Uranium Disposal Ruleinaking ,'.,,~. : 

:.". ",' .~<~";~l,,.:l"; ,,::. ':,>' .:". ,. " ,.,., . ,"~'" ",. 

:The NRC erred when it decided toJorriiulate guidelines for depleted· 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an envjronmental 

impact statement that fully evaluates DU dispdsal in a deep geologic 

repository. 'il 

Name ftk -C 6o.JlI/f .. ~~ 

Address 
_:Chief, Rulemaking & Directives Branch

--Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Eli Ills iii 111191 Ii I~~,ll~I

. ,.1· .... \,., 

. i!1,·.:Chief, Rulemaking & Directives Branch 

-Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i! ,; 1111,11,; ," ,till I, i 1111 i,i 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate, guidelines for depieted -

uranium disposal in a low-level waste disposal facility. That decision'

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an envirdnmental ,

impact statement that fully evaluates DU dislIsal in a deep-geologic :;

repository. I'

Name '.. '-"--" ' --i --

aj1

Address rim

----------~------------------------------------------- -----------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

I 

I 

I 

I 

I 

I 

.;.;:<r.... . . " . "_ :..' .. ::'. : ',."" 

The NRC erred when it decided to foimula~e, gui,delirtes for deIHeted,";':':;:" .,::~ 

uranium disposal in a low-level waste disposalfacility. That deCision"'·I.·::,,·: 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prep~re an envi!'§nmental 

impact statement that fully evaluates DU disp~l in a deep~geologic • . I, n : .... :,.. 

reposItory. :~ 7 /) rltl fi ff) 'lTll 

Name ~ \....J4' I' I.WV 

Address I l 0 ( ;£Ji~ -lj!'R 

~t:lj ~ .. -!-

"I;::~ 

riml 

CiZ'i') 

I 

I 

I 

I 

I 

I 

I 

I 
:&iI:T) -.9.37

- (2...•.. •

Chief, Rulemaking & Directives Branch

-- Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

(i..". ' f'-.' , . ,~~T2J)l19,PM' <C;L 

la\ L'd",d t R.d . 

t3.e.htw ~ I..j~. 

Chief, Rulemaking & Directives Branch 

-eoJ)ivision of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRCerred when it decided to formulate guidelines for depleted

uranium di'sposal'in a low-level waste disposal facility. T~hat decision

did not take into account the hundreds of thousands of years over c::,

which DU grows more radioactive. .u r',•

The NRC must, as part of this rulemaking, prepare an eqnjronmental

impact statement that fully evaluates DU disposal in a deep geologic-:•:•",

repository.

Name

Address G .VV0 "

I ~ V

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Dispo.sal Rulemaking . .. ' ,,' .. '.. . '" ,) 

,. . .. 

The N~C.eFIed when it decided to formulate guidelines for depleted 

uranium di'sposarin a low-level waste disp'osal facility. That decision " .. '.'-n 

did not take into account the hundreds of thpusands of ye~s over f~ 

which DU grows more radioactive. -~~ c::;: - I 0 -. I 

:-] <:: -'. ~~ ~.:: 

The NRC must, as part of this rulemaking,p,repare an el!yironmert,t~! ;.:::: 

impact statement that fully evaluates DU disp.~sal in a d~.~p geologic! {~;:: • ..' ..... .:."... '....-1 reposItory. ...... :: .... : 

Name '). ~ 8

1

j 

i\ddress () 
•o~s .0. 37~o " '77'

iv, I

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

I E;J f IIIIff5JIISIIJIIdfIII3IIfJ

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i. ,I.J iI. i.,I,i" i.i. ,i,l. "Ii,' 
To: Nuclear Regulatory Commission

I Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of ye-drs over c

which DU grows more radioactive. J, ....I"

The NRC must, as part of this rulemaking, prepare an en~y~ronmental[ impact statement that fully evaluates DU disposal in a deep geologicý --'

repository. .,

Name _w'. I"<( l, N,

/. i

Address I

-- - - ------- -,- - 1>--

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Disposal Rulemaking 

, 

, 

, 

: ;".' 

I", 

, 

". . 

The NRC erred when it decided to formulate guidelines for depleted ' . 

uranium disposal in a low-level waste disposal facility. That decision , 

did. not take into account t~e h~dreds of tho1l&ands of YC?¥s over ~~ 

WhiCh DU grows more radlOaCtlve.~:l 2:; I \ .. ' "T1.)1"· 

The NRC must, as part of this rulemaking, ~~~~are an environmental~ i{ 

impact statement that fully evaluates DU disR.Q~al in a de~ geologl2.i ~b . _,/ ~~:: . rln repository. c:: -"'- c,~ 

,; :i. /1 I ,--....... l-~l '-0. • ::;~ t, /c.. , I' ['n 

N r' )J ( '/,) r--) t'n arne ,'::.__ ' I \' ~. " '- . ~ 

Address .'. / ,/.,1/ If 
3 7

..,z

~

~4 ~

K~t~ K ~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

l~,,i, 1 1i l~,,~,Ii,,1,

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

J "i ,II i 1.111 ; Ii! I J ,I,ll, i, ; ,1'11 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines'for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over 'which DU grows more radioactive.. ,'

Fri The NRC must, as part of this rulemaking, prepare an environmental F-2,

impact statement that fully evaluates DU disposal in a deep geologic:-

repository. II •.. .. ... .. .. .. - .........- -HrI •:; jI3

Name

Address V NO/ c'

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

-----------------------------------------------------------------, 

To: Nuclear Regulatory Commission : 

I 

Re: Depleted Uranium Disposal Rulemaking . .'.'l'i:\:;: 

.' 

• ~ I ;..:.:/~. ,. ~'. • "': I 

.~;..'" • .' • "_'L" • ..., •••• _";':~:.. '~~"--:'.:.-. 

The NRC e.rred when it decided to formulate guidelinetf~r aeplet~d'l1!!\'+::'! .~.: 

uranium disposal in a low-level waste disposal facility. THat decision : 

did not take into account the hundreds of thousands of years over : 

which DU grows more radioactive. ,:~c: : -U _) ' r--=' ~: -_'I ........ rT' 

The NRC must, as part of this rulemaking, prepare an eii:yironmental c.~~: _...... ",- !"'1-1 J. .... J 

impact statement that fully evaluates DU di~pbsal in a d~ep geologi:c.! ;.': 

repository -I] \;~,' ~? ;.::: . ~ v~ 

Name ~a 5 ~:~ '9 _L~) 

Address P r1 12d-6 ! 5/ ;cj ~ sst 

ae~ EI) S-s LO; 

1 ______ -----------------------------------------------____________ _ 
26 CAP M '1•

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

.)IIIIIIJidIIIIIIIIIINII

· . '~. 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

IlliIHiI",/! Ii ,I,ll Iii i'l,ii,1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Ruleiaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the huindreds of thousands of years over

which DU grows more radioactive. -,

The NRC must, as part of this rulemaking, prepare an environmental'

impact statement that fully evaluates DU disposal in a deep geologic

repository. . >,

Name -

Address

,-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 1 . ~ 

: Re: pepleted Uranium Disposal Rulemaking : ,: .. ~ -.. , .. ~j}::;;;"';-t..,. 

, 

: The NRC erred when it decided to formulate guidelines for depleted 

: uranium disposal in a low-level waste disposal facility. That decision 

: did not take into account the hundreds of th()usands of yeq.rs over :::r:v 

: which DU grows more radioactive. --':tJ . Sic] 

i The NRC must, as part of this rulemaking, pi~bare an en'~ironmental} ',:t 1 , , ... :.' .. ' .. _1 

: impact statement that fully evaluates DU dispo,sal in a de,~p geologi¢·;:, , • • I ' ..... , 

!:::tor~ ~ i: ,9 l~ 

Address~ ~/W ' co 

, 

1_-----------------------------------------------------------------

:: . 

) \: :; , , : , 
P OCA I hEIr;t"-3O1 4-

Chief, Rulemnaking & Directives Branch

Division of Adm~ini strative .Serv ices

O ffice of Administration

U.S. NRC

Mail Stop TWBý 5BO IM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of AdministrativeServices 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

"" 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into .account the hundreds of thousands of years over

which DU grows more fadiAtye.

The NRC must, as part of this rulemaking,, prepare an ein'vironmental.',

impact statement that fully evaluates DU dis osal in a deep geologic .,

repository.

Name

Address /

-- - - - - - - - - - - - - - - - - - - - -- - - - -- - - - - - - - - -- - - - -

1-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Disposal Rulemaking I 

I 

I 

: The NRC erred .when it decided to formulate guidelines for depleted 

: uranium disposal in ~ low-level waste disposal facility. That decision 

: did not take into:,acG.~)Unt the hundreds of thousands of years over 

: which DU grows mon;'raGiAAJ£1.,.ye. -,-,: ~ 

: ,:,::~"", ~~, : The NRC must, as part of this rulemaking"p(epare an eri1rironment<:il;:.: 

: impact statement that fully evaluates DU dis!osal in a deep geologicc<, 1 • . \.),,) ';:-

: repOSItory. " 

: Name 

I 

: Address 

t· j' 

iJ 

;'~ 

'- 'l 

If 

~"'i '14 1 1-------------------------'7'----------------------------------------

l i j i 

, , 

I' 
POCATELLO, ID 83204

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

POCATELLO, \0 83204 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The:NRC erred when it'decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision "

did not take into account the hundreds of thousands of years over

Swhich DU grows more radioactive. i',

The NRC must, as part of this rulemaking, preipare an enVironmental rimpact statement that fully evaluates DU disposal in a deýep geologicý P'

repository.

°il

:Name b lane/VL

AddresslL 4 I

• I

I __ _ _ _ _ _ _ __ _ _ _ _ _ _ _

.,,S -7 -- -- -- - -- -- - -- -- -- - -- -- - -- -- -- - -- -- - -- -- -

I--------~-------------------------------------------- ------------, 

: To: Nuclear Regulatory Commission : 

.: ~~: Depleted Uranium Disposal Rulemaking ."j'~!!4'U'",~~~~ .. ~. 'n. '., :~, < 5' ':':'i~~!i1:~{ 

The NRC erred when if decided to formulate guidelines for depleted""·:"'(·;·l:~ .. 

uranium disposal in a low-level waste disposal facility. That decisiOIf :,' 

did not take into account the hundreds of thousands of years over : 

, which DU grows more radioactive. T: 

-D c: .~ r-, 

The NRC must, as part of this rulemaking, 'I"'f~pare an eQ,yironmental s:: 

impact statement that fully evaluates DU diSfu>sal in a d~p geologif; ~~: . :.,.:., . 'J~'~.,,-, reposItory. I I \.A.I ,; ",';, ~~,' 

Name W /tJJI/e 12oV/M~/ ~ ... ~i Address1L\-fo S~.~~~ u: , 

~Ol~e.., .. iL 

lD ~3 I G'-L- f , 1 ______ -----------------------------------------------____________ _ 
:y~S~Z ~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

j1I 111fllfi , tiSS 01131515 jl

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

i" i d 11,11,1 J i J Ii" "I! j" J II J I 
..................................................................

To: Nuclear Regdiatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into, account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prrepare an environmental _

impact statement that fully evaluates DU disposal in a de geologic

repository. dee geologic .,

Name ..€-o KY SAJO-..5 > :5:>:_,,.'

Address )d r /3 '/3 ./r,

H IL1t !33

- - - - - - - - - - - - - -

To: Nuclear RcgetiatoryCommission 

Re: Depleted Uranium Disposal Rulemaking 

., ,~">:;!i.:· . .; .. ~. ":~':'H~\ 

The NRC erred when it decided to formulate guidelines for depleted 

" uranium" disposru in a low-level waste disposal facility. That decision 

did not take into' account the hundreds of thousands of years over 

which DU grows more radioactive. 

I ';l :r..~ 

The NRC must, as part of this rulemaking,4>rrepare an en~ironmental~: -'on .--~. I r , impact statement that fully evaluates DU disposal in a de~p geologic :l:: 

repository. ',,'") -:- '-, ~_;~ ~": ""' ""I u...1 .' ,'-:, ''', 

Name T~ I~~ r-A ~S) AJ o~ 2;; ·;~t/~~ ,"jl c, 

Address P () !3 dX <; 3 J 3 :--'~J : ~! '-'" v-l ' \ Ji~~h2f) ~33~6 j 

____ J:j(~ ______ ~fb ____________________ J 
?4fl~ :PM. ~ A

£)A '-U~5\3 -- 2il

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

~' ... " 

b~'Jrfh,H1s>":~~O~;P.M,<2,';~" d)i),( Y,) \3 

\<eA-tl~ :cdt~ 

~3')4D 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

lul,m 1\ 111111111/111111,111.1 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-leveltwaste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more-radioactive. ". ,

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU dispoal in a deep geologic

repository. M--

Name _____,___._____

,Address _.._._-_ _,

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- ---

__ __ _ __ __ _ __ __ _ __ __ _1___r

I-----------------~----------------------------------- ------------

: To: Nuclear Regulatory Commission 

l Re: D~pleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-Ievel~waste disposal facility. That decision 

did not take into account the hundreds of thousands. of years over '., '" :" 

I 

which DU grows more,radioactive. : -- -... ~ 

I 

The NRC must, as part of this rulemaking, prepare an 'environmental 

impact statement that fully evaluates DU dis.B~al in a de~~ geologic 

repository. -'T-I .,_:,: 

I 

I 

I 

I 

I 

:IIJ 

~:; 

Name 

Address 

" j 

?-~ ..... "\,.., 

-.,. 

, . .:~ i~2 "' ~.; 1 

lAJ 

l..JJ 

V.J 

r"'} 

c:·; I ')1·. 

:;·1_" 

'. ~:=:', :-::~I 

~,;, 

i-7"11 

S] 

<: 

fJl 

~ ------------------------------------------------------------ ~:')~~. 
~PM -

-'• 2_OCTI OCT C~o~t!2t 

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

1151111111111 1115fllf lfI 111111111

· /(~.;;et, 

Chie( Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

M~il Stop TWB5B01M 

Washington, DC 20555-001 

11111111111111111111111111I11111 

-- -; 
'To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking .

The NRC erred when it'decided to formulate guidelines'for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic repository. lID

NLameC • PO ( - '"LjoJk" -i"-

I1~

Address " 0 U _

go,-jt .3 ?• 0 _-Z_ 177r

1 '71'

;C/~

------------------------------------------------------------------

1 __ - - - - - --- - - - - - - - - - -- - _-W"_ - -- - - --- - --- - --- - --- - --- - - - - - - - - - --- - ---

: To: Nuclear Regulatory Commission 

I Re: Depleted Uranium Disposal Rulemaking 

.,,\\\ 

The NRC erred when it decided to form~late guidelines<for~ depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds ofthousands of years over 

which DU grows more radioactive. 

I The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU disposal in a deep.; geologic 

repository. JJ; 

NameU Ro ( L. bro t.lkos-k,· -~[~ 

Address {2/ 0 /IJ ( l4--L 

. , 

v.J 

-l~~ ''9 

w 

w 

--IT] ,--, 

l::..::j 

:<. I,ll 

I(J) 

I 

I 

I 

I 

I 1 _____________________________________________________ ____________ ~ 
.28'

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I! ifJ ild) fhl aIgfinI fil

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop'TWB 5BOIM 

Washington, DC 20555-001 

ill j,W! u,'j, i I ,i,1 "I, i" ,Ii Ii 
To: Nuclear Regulatory Commission.

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelinesfor depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

'which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an e6niironmental•.','

impact statement that fully evaluates DU disposal in a dlep geologic

repository. '

:Name -r -,

:Address

-- ----- - - - -- -- - -- -- - -- -- - -- --- 3- 7- -- - ---

---------------~-------------------------------------- -----------

To: Nuclear Regulatory Commission, 

Re: Depleted Uranium Disposal Rulem~ing 

The NRC erred when it decided to formulate gliideIines-for depleted 

uranium disposal in a low-level waSte disposal facility. That decision 

did not take into account the hundreds of thousands of years over ,_ ) -LJ 

which DU grows more radioactive. '~~?" ~: :0 . n::: 

The NRC must, as part of this rulemaking:J~pare. an J~tironmem~nEl Impact statement that fully evaluates DU dIsposal m a dS~p geolqg!£ c: ........ -·1 .. " { 1 ___ ', 

repository. \ ~ '., > ~r ~~I 

Name ~ / SuJ,>kV:: .. 'cifr';" ~ ~\ , . ;"; , .. ;'. ':J (; 

Address t 1-"} :,o,~L-.~:-"7SlJ{!£ W. N 

~~~tNdA/L bg'JW7 
.. ... .... .. -.

Chief, Rulemaking &Directives Branch

Division of AdministrativeServices

Office of Administration

U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

Chief, Rulemaking &·DirectivesBranch 

. i ", ;-T, Division of Administrative-ServiCes' 

',,' ; . Office of Administration 

. U.S; NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive. --

The NRC must, as part of this rulemaking, prepare an environmental 2

impact statement that fully evaluates DU disposal in a deep geologlic.-ý.

repository.. . , ,

:Name

:Address,

_I •• 

1_ - - --- - --- - ------- - --- - --- - - - - - - - "';t.;,;o.,~ - - - - - - - - - - - --- - --- - - - - ---- ---

; To: Nuclear Regulatory Commission' 

Re: Depleted Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. ::CJ:~ ~ 

·--n ~:,~: h=: 

The NRC must, as part of this rulemaking, pr~pare an eii~ironment~l ~~: 

impact statement that fully evaluates DU dispbsal ina deep geologi,~~ ~J: . . i I V1 '::~"-'I 

reposltoryffir- \\ ~ 3: -- ~;2 ~~~: 

Name ~Emh-t :~i 

Ad~~\· (ff~~~~ m: 

1 ___________________ . ______________________________________________ _ 
-.... : . I. ...

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

'" .. , 

Chief, Rulemaking & Directives Branch 

Division of Administrative ServiCes 

Office of Administration 

U.S. NRC 

Mail Stop TWB5BOIM' 

Washington, DC 2055')=001 

'-". 
rTo: Nuclear Regulatory Commission

Re: Depleted Uranium DisposalRulemaking-I

The NRC erred when it decided to formulate guidelings'for depleted, 7:

uranium disposal in a low-level waste disposal facility. Thalt decision

did not take into account the hundreds of thousands of years over

:which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an envirpnmental i.

impact statement that fully evaluates DU disposal in a deep geologic :

repository.

Name (\vVttv xc S'_

:Addfress -ýc~c W. lciAýV <)o •_"__L/

- - - - - - - - - - - - - - - - \ 

--------- -'~ ---------------------------------------'---- ---'~ ;.;~"~ --":;" '..;,;.;., 

To: Nuclear Regulatory Commission : 

Re: Depleted Ur'anium Disposal Rulemaking. . 1 

I 

'. • .>.t>\'.t. ~ •.. ~ : 

The NRC erred when it decided' to formulate guideliries"\'for depleted ,":. 

uranium disposal in a low-level waste disposal facilitY. 'That decision· H·l· 

did not take into account the hundreds of thousands of years over .. :.:l 

which DU grows more radioactive. . , .b:J "~ ,= -U .C;) ::;::\ 

The NRC must, as part of this rulemaking, prepare an environmental ::-n impa~t statement that fully evaluates DU disp~~l in a deelfgeolog~~ ~;~!(; reposltory.-q v; ','J ::C::1C::) 

Name b D(w1ti ttClX TV\I\~ S~ :;:' ) ',-: ~ 

Address -;z e-f D {b ()J , 1 ciAlho ~1h : rn 

~15e" l't> 6310)_ 

.. !_-----------------------------------------------------------------
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

Chief; Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactiv,-.

-J-D:- F-11

The NRC must, as part of this rulemaking,-jrepare an environmentalF,7

impact statement that fully evaluates DU disppsal in a deep geologic

repository. /.'

I÷:L A r: ........ !"I)! 

Name '"-

011

Address , - - - - - - - - - - - - - - - - - - - - - - -

To: Nuclear Regulatory Commission 

Re: Depleted Uranium Btsposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. -I ~ :~ ~I J] .- ! <;'" 

The NRC must, as part of this rulemaking,:pr~pare an el'!.yironmentalr~.~~: 

impact statement that fully evaluates DU di~f>psal in a de~p geologt9 ;-::'.~: • .J ' , :'i '_->,1 .;:.::' ", 

reposltOry.~ J M ~:"'.'1 \ I (f'! '.' . -,,,,,," ~l;::::" 

Name '. / D l( ~;() 'f'G'::::: . ~i ~i ~~L. 

Address 3 3 fc tI / 7f~,,!)~~11 ' ,'9 ul .\ 

30 01cL; fLot6;i;f~"" ',,0 
3C~k~J~ i~Od~'

- .- j '..,. .2

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

*' U.S. NRC

Mail Stop TWB 5B01M

Washington, DC 20555-001

til IIs1111111111$11 il i~ll 11i

Chief, Rulemaking & Directives Branch 

Division of Administratiw Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

:Washington, DC 20555-001 

it. it' 'i t • t .1.1 •• , t' t • , • it. t '1.1 
To: Nuclear Regulatory-Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a.lowlevel waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

,'impact stateme&itthat fully evaluates DU dispossAl in a deep~geologiq,

repository. ',. :

Address Q-,o-" +A c dC,- - -

33(oqt(

----

------~----------------------------------------------- -----------, 

To: Nuclear RegillatoryCommission ' "': 

Re:Depleted Uranium. Disposal Rulemaking : 

I 

I 

I' 

The NRC erred when it decided to formulate guidelines for depleted : 

uranium disposal in a.1ow.:level waste disposal facili~. That decision :, 

did not take into accoUnt the hundreds of thousands of years over ': . .'. '" • I 

which DU grows more radioactive. bJ 

r--- . I:-::-~:: 

The NR,C must, as part of this rulemaking, pr~are an en~ronmental :[~'~ impact statemelittpat fully evallgltes DU dispo's~ in a deep~geologiC) ~'t:!"" repository ;:' - ) V' '<?: ~-., :: .. ," ' ,~, , ",,"n Z'SS~i!;l 

Nam~JI,\ cU n Ct±~S ",j "''--'~~. ~ 1 ~~ ., 3~J, :-.\ \ 'f? I ~:::n , : (j) 

Address 0(091= No-r-tbul-e w £JL. i::J' 

tvtt' c\c\(g b, r D' ,~30i{4' 

,----------------------------~------------------------ ------------
C~L2T I L: T'

PIA, kK ~d '~~

.'.'- ~8

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

S~~;)l;;E. IO, &S7~: 

.. "'.\-' ,Z~ lCiCT" ·l't)t;;"""~'~.,)." ·f:·-r: .. _ . >. , .......... ,~~, .. lTlC'lI.· ~ t, 

<.:qDq1i\SM+hU({I~ f-c( 

~ 'M I ctcQ lLbl Tih <?3'l.tJL( If 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BO 1 M 

Washington, DC 20555-001 

<-, ~-., 
- -. --. --. . . . . -. . --. - - . . . . - - .- _ . . . . . . -2 -. --. -, . . . . . . . --------------. . . . . . . To: Nuclear Regulatory Commission .

Re:. Depleted Uranium Disposal Rulemaking

Tlhe NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That' decision

did not take into account the hundreds of thousands of years over •

Swhich DU grows more radioactive. -• -

The NRC must, as part of this rulemaking, prepare an env'fonmentalh..•-!,.

impact statement that fully evaluates DU disposal in a deep~geologicrepository.

:Name So CT) 

Address ~ \ y

CQ";- 7

---------------------------------------------------------

,--------------------'--'---------':' ---------------------------------, " 

lTo: Nuclear Regulatory Commission ''',':':, " :", 

: Re: Depleted Uranium Disposal Rulemaking 1 'I . . I , , ~. 100 ~~.; _'" • "0: I 

'f'''T~e:'NRC erred when it decided to formulate guidelinesfor depleted: 

: uraillurn disposal in a low-level wast~ disposal facility. That'decision : 

: did not take into account the hundreds'ofthousands' ofye.~s over , ::lJ 

l which DU grows more radioactive. 'J.J : .. ::~ ~~i , --'l""1 ,:=;~ " I . I -i.,,~ :-i-:"J 'r~; 

: The NRC must, as part of this rulemaking, .prelJU"e. an envi!onrneri!~rf~:;l~: .. 

: Impa~t statement that fully evaluates DU dlsp~s~l In a deepigeolo~l?(~?: :3/ 

: reposItory. ~ -".:;; 

!Name tj '(,d~',-o.. ~£;Y's,a ,---,'Tl '9 j~ ,. 0' I 

lAddress ~~ 51 ~~~ ':>\- 1 

! \L' " , I : 

: \)b " S:, ~"I ~\? D) l () '1 1 , , I , 

I , 

I , 

: _________ ~ ________________ ._'_- ________ ' ___ ~ ________ ~ _' ____ "- __ , ___ ~ __ __ 1 
V

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

. ,', ';i, , 

""',-:" <; ': : ~' ••• , -,'.''1' 

~,..,."" ' . " 

.: ~ .... 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

. ..... ' 
To: Nuclear Regulatory Commission

'Re: Depleted Uranium Disposal RulemrgAk. .

The NRC erred when it decided to formulate guidelines for depleted.

uranium disposal in a low-level waste disposal facility. That decision i

did not take into account the hundreds of thousands of years over A'

which DU grows more radioactive.

'The NRC must, as part of this rulemaking, prepare an env onmentalo

:impact statement that fully evaluates DU disposal in a deep geologic ,,-

repository. --

I , . - 'C"'-) ',Name •" " 'NAddress

I. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

.~--------------------------------------------~--------- ----------, 

: To: Nuclear. Regulatory Commission . : 

: Re: Depleted Uranium Disposal Rulema19~g : 

: '. .... ;-<.'. . : 

t .. ,;:" The NRC erred when it decided to formulate guidelines for deplet~d~i~{':;:">';;'/ 

uranium disposal in a low-level waste disposal facility. That decision':': .. ' . 

did not take into accowit the hundreds of thousands of years over : . 

which DU grows more radioactive. -0 '~;~l~ 

:!r-\ -:;?;: ,:.0 

!he NRC must, as part of this rulemaking, ?r~p",are. an environment~l,,>:: ::!: lmp~t statement that fully evaluates DU dls~~~al In a deee .. ~eolog~~~:~~ 

reposItory. I \ ,~ ) 0.:-:;j 

Name fYlttR'( It- G- {e n ~. ~ ~:i 

Address 7u. /Pi<r2oV\ ~. ( .&c·se .,:ptJ ~3/0~ , 

• 

• 

. -------------------------~---------------------------------------~ 
d . ......

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I III 11 iea~~ II 111111 III! ill £11 El

\ "'.,,':' 

, " ., "~~ ,', .J.",' 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

u.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

j"I,ll'" :,1,1,,1,1;; i, j",ll,l 

" ,.., 
TN6o ar Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

70f The NRC must, as part of this rulemaking, prepare an environmental ,4

impact statement that fully evaluates DU disposal - ...... in a deep geologic ~~ I,•Z >:

repository.

Name t

Address

i---.--------------------------------------------------------.......

- ~~;;.,:~ ,-::;:: .... '~. - :':'- - - - - ~ -.-::.- - - -.. :;.:=::-- - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

TQ: 1'ftrcie-ar Regulatory Corrumssion 

Re: Depleted Uranium Disposal Rulemaking .' 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

]J ;-; ::to 

The NRC must, as part of this rulemaking, prepare an environmental ;;:~ 

impact statement that fully evaluates DU disposal in a d~p geologic 8-r 

• ' ',_ .J _" __ c :::-', reposltory. ----r~" 1;;:--, 

i J L·rt c,~': 

1

,0 ~ '," (CJ 0 0 \, /A V\ \_~-~_:~, Name .-=:d. ~ \) i V'- cd :-; ?;; ;?il 

Address 2,9: 14, S 1 \ ~~d~ f~ \\l ~: 

~ (/ C (kf.e II Gt J:: P {:S..L6 t 

: 'S _ 
30 0-... 2-0009- PI 2- ,* T,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

',,"!, 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOtM 

Washington, DC 20555-001 

s= s 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Dis posal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over ....

which DU grows more radioactive. J9D -

The NRC must, as part of this rulemakingprepare an environmentalimpact statement that fully evaluates DU diýposal in a deep geologic ,,

~repository.

,:Name /• • •!.!_c:F -

!Address 2,S ,

I 3 ýILPL V 'k

.-----------------------------------------------------------------

: To: Nuclear Regulatory Commission 

: Re: Depleted Uranium Dimlosa:l Rulemaking , - . , 

I . ,.~',' . '.' . ... '.' , . . '. • 

: The NRC erred when it decided to formulate guidelines 'for depleted , - -

: uranium disposal in a low-level waste disposal facility. That decision 

: did not take into account the hundreds of thousands of y~~s over ;;g: , which DU grows more radioactive. JJ ;~:5 r=: 

--'-1 . "" 

i ~, .. ~!~ . . ~".' ~:.~:: The NRC must, as part of this rulemaking;p~~pare an e~vironmehtaV': 

impact statement that fully evaluates DU di&ppsal in a deep geologi~ ~:,: 

repository. ',/;:;;;: :) ::i: P,;: 

Name ~ OAf,fw ,~ : ~i Address Lf6 63 ~ fI) iJ(>~ 

S'~UL r j fc 5'S{ l1 

V J' 

I ______ -------~--------------------------------------- ____________ _ 
t4K&21T Ffi 

I'S (0)/Z(4~

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Ii I Ifll11 1i It I ItitJ I h I, III! I

Chief, Ruiemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

Ii ,1,1/1"" I ,1,.1, i •• I, illlll, I 
ITo: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking,_prepare an. en•ironmental,

impact statement that fully evahua.cs DU disposal in a deep geologic repository.

:.Name ,.-i((J'. '.7-L

:Address &- Ci• -,m t .t. 

~C1.O

To: Nuclear Regulatory Commission 

Re: Deplet~d Uranium Disposal Rulemaking 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands. of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking,-p.repare anetiyironmental ?I • ..... T • J J • -.:) . ::;", Impact statement that fullY eyah:a~cs i.;U qrSP?S2J In a d~,~p geologIc l~T) 

repository. J...! ;:;2 :.~~ 

Name Scucah ~~IL 

Address /60 1 Bed fuel tJn 

) ~~:j '\I \..11 <_ .• 1, I I 1.~ •.•• 

....•. - :;:;:'';1' ~1~-il 

........... :% ~I:; -\--1 =l' , , ' I 'f? <.: 

\:J nil U,) 

0-
Sarah R eha/er . -

1607 Bedford Dr

Boise ID 83705 8'

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

b3i3IJJ1195J3i1.111i11i1151511d

--~---~- -~:~fi;~;·'~~~~:~;·l~~~!~~:f1!:~ :!,:,:~~~. Sarah Ril/haler- -. . ".~ ,c~~~.;: . 

16'07 Bedford Dr ,. ~" i. 

BOl:\'e fD 83705 

-===-:;;:;;;;:::=-__________ - _~_ I 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium P Dp• I Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.....i

The NRC must, as part of this rulemaking, :ptrpare an efivironmental Y,,

impact statement that fully evaluates DU digpbsal in a dlep geologc-,

repository. :,

Name ,.

:Address (' --tt ' o C2D 

I- - - - - - - - - ---- _

To.: Nuclear RegulatDry CDmmissiDn 

Re: Depleted Uranium ~l Rulemaking 

The NRC erred when it decided to fDrmulate guidelines fDr depleted' 

uranium dispDsal in a lDw-level waste dispDsal facility. That decisiDn 

did nDt take into. accDunt the hundreds Df thDusands Df years Dver 

which DU grDWS mDre radiDactive. :r 

1"1 ,-,) c' .. .JJ "'" F: 

The NRC must, as part Df this rulemaking, :pfepare an ert.Yironmental u: 

impact statement that fully evaluates DU disP9sal in a defP geDlogi~2 f: • .... ,. .. <' "'~I repDsItDry. /-rl \.F. c

. ~::.: CIJ 

.. . ,_ ~'" '} ;3;:, 

Name Mo \\ '( ~ofin SoD ,,', :-~~ '. '.0. ~:-; r'l 

Address lo2f\ C3 \-\0\1: )\c.R.\ ~.Qi=e'l . 0 ch 

<!:un \1\ \ ~ rQ.,\ \ Cfr q ~lj-6 r 

I ' 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

IS1I! JJIISIIIEJIE IEI~9JII! ha

".- ': ,~ .... : 

·':t}O:ISE::tD .. SB';;? '" . I."' 

ffi~(')~-Y ;7.P\"t,;;,?~1'~:,L '.' .' . ;""O-A-____. 

--~iqD fuus\(,e\Qq~(>r: • .' . 

~~,rA9t34s1 

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

I"I,/II,!" i ,I" i,l"i ,i '1,II,i 
i-----------

To: Nuclear Regulatory Commission,

Re: Depleted Uranium Disposal Rdlemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive.

The NRC must, as part of this rulemaking, prepare an environmental

impact statement that fully evaluates DU disposal in a deep geologic

repository. CC

Name J2.e SAM...

Address

---------------------------------------------- CD2

-----------------------------------------------------------------, 

To: N~c1ear Regulatory Commission" : . . - ... .-.... ., ,J............ 1 

Re: Depleted Uranium Disposal Rulemaking : ., ~'. .1 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. 

The NRC must, as part of this rulemaking, prepare an environmental 

impact statement that fully evaluates DU disposal in a dt(ep geologic . ~v _ ..', :1" 

reposltory'--n -' r=;:: . S ~ ~ 

=-==="-- Name ____________ 

J6.'\e 

~ 

toltr---+·····r-,--lf-- ~-~;-': 1 .,·~-.. :I 

II ~Ji c:' 

~A~d==d=re=s""'s__=~!:::·::3::;;../IE<·~/~-~---____,-.,:=.~:"?:;"'t_-,·- §~ f,~Jl . ! 1 I CC

): 

_~_5d_W_eSt_f_\~~~fl~QW~.f_d~)~fl~pt~#-<-~-,.7_; ~! '0 , 

, 

, 

, 

, 1 ___ --------------------------------------------------____________ _ 
.2.13=..

~ c~cT jX" ý 2 T* ......

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BO1M

Washington, DC 20555-001

I I I i I I I ! I I I I I I I I j I I I I I I I i I I f I I I I

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

l'II,lli""IIII,IIIIII,III,1111 

9 -_ 
To: Nuclear Regulatory Commission

Re: Deple-twa Uranium Disposal Rulemaking..

The NRC erred when it decided to formulate guidelines'for depleted

uranium disposal in a low-level waste disposal facility. That decision

'did not take into account the hundreds of thousands of years over

which DU grows more radioactive. • hh

The NRC must, as part of this :•Jemaking, ie-pare an environmental

impact statement that fully evaluates DU disposal in a dev geologic,

repository. / .J ...... .,Ir

AddName V 1I "" " :/jz 

,Address _ r

Iý nY

-- - - - - - - - - - - - - - - -- - - - - -- - - - - - - - -

-------------------~---------------------------------- -----------

To: Nuclear Regulatory Commission 

Re: Depl~ Uranium Disposal RulemakiJ}.g ..... 

The NRC erred when it decided to formulate guidelines for depleted 

uraniurri. disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds ofthousands of years over 

which DU grows more radioactive. 

Address 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

- - Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

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Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

~ . Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 
To: Nuclear Regulatory Commission

Re: Depleted Uranium Disposal Rulemaking

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

1which DU grows more radioactive.

The NRC must, as part of this rulemaking,.'prepare an e-nvironmental'

impact statement that fully evaluates DU disposal in a deep ge6olgic

repository.

:Name /7 <7(6 -o =A

SAddress - --

1 ~o~2d'e 0

.-----------------------------------------------------------------

: To: Nuclear Regulatory Commission I 

: Re: Depleted Uranium Disposal Rulemaking I ' 

.. ' 

The NRC erred when it decided to formulate guid~lines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. c-; 'JJ ', .. J- , "'J 

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c-:: r-'" ·· .. ·y-l .... ,. rTl 

The NRC must, as part of this rulemaking,.!p.repare an ~iivironmenta:V::: ') - , .. ,-, ", impact statement that fully evaluates DU ~i.~posal in a deep ge619gif~ 

repository.' I I 1..11 'i j ;~ ~~:: , ~.", ;'.' '.> ':::1':::: ~;;/.~ 

Name c/vC£M /J1oh{~! ~-~ 

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Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office-of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

iiiiiiiiiiiiiiiiiiiiiIlliffililI

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office-of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

IlIlllIIlIIl/lill illlllllllilill 
To: Nuclear Regulatory Commission

Re:- Depjeted Uranium Disposal Rulemaking

The'NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive. - ,-j

The NRC must, as part of this rulemaking, prepare an environmental -

impact statement that fully evaluates DU disposal in a deep geologic I

Srepository. -,

-... Z.. ' F"fl'

:Name FOV-o

Address'.2OL .L H A-td. ?1 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - \

To: Nuclear Regulatory Commission 

Re:· DepJeted Uranium Disposal Rulemaking 

." .".~.:. .' 

the 'NRC 'erred when it decided to formulate guidelines for depleted 

uninium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive',JJ ". ,:;; e, 

, '-n ::c,:;; F:;':: 

The NRC must, as part of this rulemaking, prepare an enYironmental c/.: 

impact statement that fully evaluates DU disifosal in a deep geolQgl£ f~;~: . I I Vl .. 1, . . "., reposItory. .-,,' ;::"'" c.~/ 

Name Rob.\., 1?~ C: o'"'tg! ~ 

Address ~2Dcg H ~rvoJ.. Pi <g~ 0 cn 

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j~bO~- ~ 17T2':~ ta 2 -o,

Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office-6f Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

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lSDlol"" ~Y OCT 2~.Jt;)9 PM:· 2 'T .... ~ , 

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Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office. Of Administration 

u.S. NRC 

Mail Stop TWB 5 BO 1 M 

Washington, DC 20555-001 
To.: Nuclear Regulatory Commission.

Re: Depleted Uranium Disposal Rulemaking- .

The NRC erred when it decided to formulate guidelines for depleted

uranium disposal in a low-level waste disposal facility. That decision

did not take into account the hundreds of thousands of years over

which DU grows more radioactive. -I .

The NRC must, as part of this rulemaking, prepare an eriiironmental" .2', impact statement that fully evaluates DU disposal in a deep geolg

repository. -- :

FrTI :Name f~ra~tliskCC'

:Address 6cj e -rL e Lr-' - -

-------------------------------------------------------------------------

1_ - - - - - - - - - - - - - - - -.- - - _,_~..;;-.c:_~ - - - - - - - - - ,;,..::., - - - - - - - - - - - - - - - - - - - - - - - -, 

,: To~.N,llclear R~gulatory CommissiQn,"" : 

Re: Depleted Uranium Disposai Rule~aldng;'" . r".~,.' 

The NRC erred when it decided to formulate guidelines for depleted 

uranium disposal in a low-level waste disposal facility. That decision 

did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. J];] e:: '-l iT : I ..... r',l .-, 9 ~ 

The NRC must, as part of this rulemaking, prepare an environmental! de:: •... ,..._ .• \ • .. ~) .,~..J ~.':::J 

impact statement that fully evaluates DU disp<;>sal in a deep geologi~': r..:: 

repOSItory. . , . 

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1 _________________________________________________________________ _ 
Chief, Rulemaking & Directives Branch

Division of Administrative Services

Office of Administration

U.S. NRC

Mail Stop TWB 5BOIM

Washington, DC 20555-001

Chief, Rulemaking & Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. NRC 

Mail Stop TWB 5BOIM 

Washington, DC 20555-001 

III i! IIi 1111 illlllllllllllllll,l 
-7q7 F"~6I/76 Page 1 of 2

"Um3IC SUBMISS10N

As of: November 05, 2009

Received: October 30, 2009

Status: PendingPost

Tracking No. 80a4e36f

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0016

Comment on FR Doc # E9-14820

Submitter Information

Name: Gary Merrell

Address:

1943 Bear Mountain Drive

Draper, UT, 84020

Submitter's Representative: None

Organization: Private Citizen

Q1

J-o

<9

General Comment

As a professional consultant in the waste management industry for the last 27 years, I am concerned about the

regulation and classification of depleted uranium (DU) as a low-level radioactive waste. DU poses a radiological

hazard similar to other long-lived alpha-emitting radionuclides (such as the transuranic isotopes) and should be

regulated L6sing the same risk-based considerations as other long-lived alpha emitters. In the attached file, I

point out the similarities between DU and transuranic isotopes and suggest a risk-informed approach for

including DU in the 10CFR 61 classification system.

DU meets the definition of a low-level radioactive waste. However, the waste classification system in 10 CFR

61.55 does not specifically include uranium in the classification tables. As a result, DU receives the 10CFR61

default classification as Class A low-level waste. In general, Class A waste contains predominantly short-lived

radionuclides and has a radiological hazard on the order of 100 years. DU shares neither of these

characteristics with Class A waste because it is very long-lived and the radiological hazard persists far longer

than 100 years.

Under the 10CFR61 classification system, Class A wastes may contain long-lived alpha-emitting radionuclides,

such as transuranics, provided that their concentrations do not exceed 10 nCi/g. Based on the similar

radiological characteristics and hazards of DU and tranuranics (see attached file), I believe a 10 nCi/g Class A

concentration limit for DU is appropriate. For the same reasons, I believe a 100 nCi/g Class C limit for DU is

also appropriate.

I believe it is essential that NRC maintain its long history of scientific integrity and leadership in developing riskIDSI .e0e,- -03

Tcmp~~~ /,t ,-Ll/3 *' =-&. -) 7 y/A

https:•/fdms.erulemaking.net/fdms-web-agency/component/submitterInfoCoverPageCall=Print&PrintId... 11/05/2009 P. Yadrav (nFPYJ

7 Lf p(l36 / 7S 

C,!d'-f /61 

@ 

As of: November OS, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC SUBMISSI Tracking No. 80a4e36f 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257~0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0016 

Comment on FR Doc # E9-14820 

Name: Gary Merrell 

Address: 

1943 Bear Mountain Drive 

Draper, UT, 84020 

Submitter Information 

Submitter's Representative: None 

Organization: Private Citizen 

General Comment 

As a professional consultant in the waste management industry for the last 27 years, I am concerned about the 

regulation and classification of depleted uranium (DU) as a low-level radioactive waste. DU poses a radiological 

hazard similar to other long-lived alpha-emitting radionuclides (such as the transuranic isotopes) and should be 

regulated using the same risk-based considerations as other long-lived alpha emitters. In the attached file, I 

point out the similarities between DU and transuranic isotopes and suggest a risk-informed approach for 

including DU in the 10CFR 61 classification system. 

DU meets the definition of a low-level radioactive waste. However, the waste classification system in 10 CFR 

61.55 does not specifically include uranium in the classification tables. As a result, DU receives the 10CFR61 

default classification as Class A low-level waste. In general, Class A waste contains predominantly short-lived 

radionuclides and has a radiological hazard on the order of 100 years. DU shares neither of these 

characteristics with Class A waste because it is very long-lived and the radiological hazard persists far longer 

than 100 years. 

Under the 10CFR61 classification system, Class A wastes may contain long-lived alpha-emitting radionuclides, 

such as transuranics, provided that their concentrations do not exceed 10 nCi/g. Based on the similar 

radiological characteristics and hazards of DU and tranuranics (see attached file), I believe a 10 nCi/g Class A 

concentration limit for DU is appropriate. For the same reasons, I believe a 100 nCi/g Class C limit for DU is 

also appropriate. 

I believe it is essenti.al that NRC maintain its long history of scientific inte~rity and leadership in developing risk- Ii . 

SUNS I /2.eUltw ~t'l-f)-e--Ie- c -Ill DS ~ /JPIl--t>3. (b I\.f f) 

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p. Yru:/av (ppy) 
Page 2 of 2

based standards for radioactive waste disposal. I am optimistic that the NRC can properly evaluate the technical

and scientific issues necessary to form a sound and consistent technical basis for disposal of low-level waste.

Attachments

NRC-2009-0257-DRAFT-0016.1: Comment on FR Doc # E9-14820

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11/05/2009

Page 2 of2 

based standards for radioactive waste disposal. I am optimistic that the NRC can properly evaluate the technical 

and scientific issues necessary to form a sound and consistent technical basis for disposal of low-level waste. 

Attachments 

NRC-2009-02S7-DRAFT-0016.1: Comment on FR Doc # E9-14820 

https:llfdms.erulemaking.net/fdms-web-agency/ componentl submitter InfoCover Page ?Call = Print&PrintId... 11/05/2009 
As a professional consultant in the waste management industry for the last 27 years, I am

concerned about the regulation and classification of depleted uranium (DU) as a lowlevel radioactive waste. DU poses a radiological hazard similar to other long-lived alphaemitting radionuclides (such as the transuranic isotopes) and should be regulated using

the same risk-based considerations as other long-lived alpha emitters. In the comments

below, I point out the similarities between DU and transuranic isotopes and suggest a

risk-informed approach for including DU in the 10CFR 61 classification system.

NRC Classification of DU

DU meets the definition of a low-level radioactive waste, a fact which was confirmed in

NRC's Memorandum and Order of January 18, 2005 (CLI-05-05). However, the waste

classification system in 10 CFR 61.55 does not specifically include uranium in the

classification tables. As a result, DU receives the 10CFR61 default classification as

Class A low-level waste. In general, Class A waste contains predominantly short-lived

radionuclides and has a radiological hazard on the order of 100 years. DU shares neither

of these characteristics with Class A waste because it is very long-lived and the

radiological hazard persists far longer than 100 years.

Under the 10CFR61 classification system, Class A wastes may contain long-lived alphaemitting radionuclides, such as transuranics, provided that their concentrations do not

exceed 10 nCi/g. Based on the similar radiological characteristics and hazards of DU and

tranuranics (see below), I believe a 10 nCi/g Class A concentration limit for DU is

appropriate. For the same reasons, I believe a 100 nCi/g Class C limit for DU is also

appropriate.

Radiological Hazard Comparison - DU vs Transuranics

The radiological hazard from DU is primarily from the emission of alpha particles. In

this respect, it is similar to transuranic isotopes, such as plutonium and americium. The

table below compares the radiological hazards of Pu-239, Am-241, and DU (with and

without decay products), based on the dose conversion factors for inhalation, ingestion,

and external exposure. The dose conversion factors were taken from Federal Guidance

Reports No. 11 and No. 12.

The table shows that for long time frames, following significant ingrowth of DU decay

products, the radiological hazard of DU exceeds the hazard posed by Pu-239 or Am-241.

Furthermore, because DU and its decay products are very long-lived, its hazard initially

increases and then remains almost constant (after secular equilibrium is reestablished),

while the hazards from the transuranics decrease through radioactive decay. Given the

similar magnitudes of their long-term radiological hazards, I believe it is appropriate to

regulate DU similarly to the transuranics (i.e., 10 nCi/g Class A limit; 100 nCi/g Class C

limit). A risk-based approach for classifying DU suggests that it should be subject to the

same concentration-based limits as the tranuranics in the current 1 OCFR61 classification

system.

As a professional consultant in the waste management industry for the last 27 years, I am 

concerned about the regulation and classification of depleted uranium (DU) as a lowlevel radioactive waste. DU poses a radiological hazard similar to other long-lived alphaemitting radionuclides (such as the transuranic isotopes) and should be regulated using 

the same risk-based considerations as other long-lived alpha emitters. In the comments 

below, I point out the similarities between DU and transuranic isotopes and suggest a 

risk-informed approach for including DU in the lOCFR 61 classification system. 

NRC Classification of DU 

DU meets the definition of a low-level radioactive waste, a fact which was confirmed in 

NRC's Memorandum and Order of January 18,2005 (CLI-05-05). However, the waste 

classification system in 10 CFR 61.55 does not specifically include uranium in the 

classification tables. As a result, DU receives the 10CFR61 default classification as 

Class A low-level waste. In general, Class A waste contains predominantly short-lived 

radionuclides and has a radiological hazard on the order of 100 years. DU shares neither 

of these characteristics with Class A waste because it is very long-lived and the 

radiological hazard persists far longer than 100 years. 

Under the 10CFR61 classification system, Class A wastes may contain long-lived alphaemitting radionuclides, such as transuranics, provided that their concentrations do not 

exceed 10 nCi/g. Based on the similar radiological characteristics and hazards ofDU and 

tranuranics (see below), I believe a 10 nCi/g Class A concentration limit for DU is 

appropriate. For the same reasons, I believe a 100 nCi/g Class C limit for DU is also 

appropriate. 

Radiological Hazard Comparison - DU vs Transuranics 

The radiological hazard from DU is primarily from the emission of alpha particles. In 

this respect, it is similar to transuranic isotopes, such as plutonium and americium. The 

table below compares the radiological hazards ofPu-239, Am-241, and DU (with and 

without decay products), based on the dose conversion factors for inhalation, ingestion, 

and external exposure. The dose conversion factors were taken from Federal Guidance 

Reports No. 11 and No. 12. 

The table shows that for long time frames, following significant ingrowth of DU decay 

products, the radiological hazard ofDU exceeds the hazard posed by Pu-239 or Am-241. 

Furthermore, because DU and its decay products are very long-lived, its hazard initially 

increases and then remains almost constant (after secular equilibrium is reestablished), 

while the hazards from the transuranics decrease through radioactive decay. Given the 

similar magnitudes of their long-term radiological hazards, I believe it is appropriate to 

regulate DU similarly to the transuranics (i.e., 10 nCi/g Class A limit; 100 nCi/g Class C 

limit). A risk-based approach for classifying DU suggests that it should be subject to the 

same concentration-based limits as the tranuranics in the current 10CFR61 classification 

system. 
Table 1. Comparison of DU and transuranic dose conversion factors

Pathway Pu-239 Am-241 DU DU +

decay products

Inhalation 1 .1 6E-04 1.20E-04 3.20E-05 1.64E-04

(Sv/Bq) 28% of Pu-239 1.4 times Pu-239

Ingestion 9.56E-07 9.84E-07 7.25E-08 2.62E-06

(Sv/Bq) 8% of Pu-239 2.7 times Pu-239

External gamma 1.58E-21 2.34E-19 6.1OE-19 6.05E-17

(Sv/s per Bq/m 3) 390 times Pu-239 38,000 times Pu-239

Finally, I believe it is essential that NRC maintain its long history of scientific integrity

and leadership in developing risk-based standards for radioactive waste disposal. I am

optimistic that the NRC can properly evaluate the technical and scientific issues

necessary to form a sound and consistent technical basis for disposal of low-level waste.

T a bile e . ompanson 0 fDU an d t . d ransuramc ose conversIOn f ac t ors 

Pathway Pu-239 Am-241 DU DU+ 

decay products 

Inhalation 1.16E-04 1.20E-04 3.20E-05 1.64E-04 

(SvlEq) 28% ofPu-239 1.4 times Pu-239 

Ingestion 9.56E-07 9.84E-07 7.25E-08 2.62E-06 

(Sv/Bq) 8% ofPu-239 2.7 times Pu-239 

External gamma 1.58E-21 2.34E-19 6.10E-19 6.05E-17 

(Sv/s per Bq/m3) 390 times Pu-239 38,000 times Pu-239 

Finally, I believe it is essential that NRC maintain its long history of scientific integrity 

and leadership in developing risk-based standards for radioactive waste disposal. I am 

optimistic that the NRC can properly evaluate the technical and scientific issues 

necessary to form a sound and consistent technical basis for disposal of low-level waste. 
71/ F--36175

As of: November 05, 2009

Received: October 30, 2009

Status: Pending-Post PUBLIC SUBMISSIONl Tracking No. 80a4ea61

Comments Due: October 30,

ISubmission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a-Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0017

Comment on FR Doc # E9-14820

Page 1 of 1

2009

Submitter Information

Name: Kelsey Nunez

Address:

3602 W. Taft St.

Boise, CO

Submitter's Representative: n/a

Organization: n/a

General Comment

* The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU

grows more radioactive.

° The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU

disposal in a deep geologic repository.

e It is inappropriate to license any new uranium enrichment facility until regulations are in place governing

disposal of depleted uranium and disposal facilities have implemented those regulations.

* Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow

land burial is adequate for depleted uranium disposal.

e The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level

waste disposal facilities.

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7Lf Fil36(75 

'/c1'-1)fJ 9 

@ 

As of: November OS, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of 1 

p BLIC S B ISSI Tracking No. 80a4ea61 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0017 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Kelsey Nunez 

Address: 

3602 W. Taft St. 

Boise, 

Submitter's Representative: nla 

Organization: nla 

General Comment 

II 

-Tl 

,"---"1 \, __ .1 

co 

• The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level waste 

disposal facility. That decision did not take into account the hundreds of thousands of years over which DU 

grows more radioactive. 

• The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully evaluates DU 

disposal in a deep geologic repository . 

• It is inappropriate to license any new uranium enrichment facility until regulations are in place governing 

disposal of depleted uranium and disposal facilities have implemented those regulations. 

• Until the NRC is able to provide a clear description of "other unique waste streams," it must not attempt to 

formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow 

land burial is adequate for depleted uranium disposal. 

• The U.S. already has a massive inventory of depleted uranium still mixed with hexafluoride, so it cannot be 

disposed of. Once that separation occurs, the size of the waste stream and the fact that DU grows more 

radioactive over the course of one million years prohibits DU disposal at any of the current or pending low-level 

waste disposal facilities. 

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l 
Page 1 of 1

7'Y F ZL6/73"

MU I ION As of: November 05, 2009

Received: October 30, 2009

Status: PendingPost

Tracking No. 80a4dc90

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0018

Comment on FR Doc # E9-14820

Submitter Information

Name: Arjun Makhijani

Address:

Institute for Energy and Environmental Research

6935 Laurel Ave, #201 .- ))

Takoma Park, MD, 20912

Organization: Institute for Energy and Environmental Research

General Comment

Please find attached the following:

"IEER Comments on the Nuclear Regulatory Commission's

Rulemaking Regarding the "Safe Disposal of Unique Waste Streams Including Significant Quantities of Depleted

Uranium" / by Arjun Makhijani, October 30, 2009

Attachments

NRC-2009-0257-DRAFT-0018.1: Comment on FR Doc # E9-14820

T l/6 de = /9 d d:61 , 6 T Ar 6 V) LSj 

t.11rnt tl 11/05/29 ) https://fdms.erulemaking~net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11]/05/2009

As of: November OS, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of 1 

p BlIC SUBMISSI Tracking No. 80a4dc90 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0018 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Arjun Makhijani 

Address: 

Institute for Energy and Environmental Research 

6935 Laurel Ave, #201 

Takoma Park, MD, 20912 . 

Organization: Institute for Energy and Environmental Research 

General Comment 

Please find attached the following: 

"lEER Comments on the Nuclear Regulatory Commission's 

Rulemaking Regarding the "Safe Disposal of Unique Waste Streams Including Significant Quantities of Depleted 

Uranium" / by Arjun Makhijani, October 30, 2009 

Attachments 

NRC-2009-0257-DRAFT-0018.1: Comment on FR Doc # E9-14820 

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[#K• z7• INSTITUTE ENVIRONMENTAL FOR ENERGY RESEARCH AND

6935 Laurel Avenue, Suite 201

Takoma Park, MD 20912

Phone: (301) 270-5500

FAX: (301) 270-3029

e-mail: ieer@ieer.org

http://www.ieer.org

IEER Comments on the Nuclear Regulatory Commission's

Rulemaking Regarding the "Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium"'

Arjun Makhijani

October 30, 2009

On March 18, the Nuclear Regulatory Commission (NRC) directed its staff to proceed with a

rulemaking to amend the low-level waste rule to take into account the gap in the existing rule, 2

which does not address depleted uranium waste created in large amounts, such as at uranium

enrichment plants. This followed the preparation by the staff of a paper, SECY-08-147, which

presented the Commission with four options. The March 18, 2009, decision was to proceed with

Option 2 as specified in SECY-08-147.

Previously, in the adjudicatory proceeding for the Louisiana Enrichment Services

(LES) license application, the Commission determined that depleted uranium is

properly classified as low-level radioactive waste. Although the Commission

stated that a literal reading of 10 CFR 61.55(a)(6) would render depleted uranium

a Class A waste, it recognized that the analysis supporting this section did not

address the disposal of large quantities of depleted uranium. Outside of the

adjudication, the staff was tasked to evaluate this complex issue and provide

specific recommendations to the Commission. SECY-08-0147 is the result of the

Commission's direction and provides recommendations for a path forward.

U.S. Nuclear Regulatory Commission, "Notice of Public Workshop on a Potential Rulemaking for Safe Disposal

of Unique Waste Streams Including Significant Quantities of Depleted Uranium," Federal Register v.74, no. 120

(June 24, 2009), pages 30175-30179, on the Web at http://edocket.access. gpo. gov/2009/pdf/E9- 14820.pdf.

Hereafter referred to as NRC FR Notice 2009. Hereafter NRC FR Notice 2009.

2 Annette L. Vietti-Cook (Secretary [of the Commission]), Memorandum to R. W. Borchardt (Executive Director for

Operations), Staff Requirements - SECY-08-O147 - Response to Commission Order CLI-05-20 Regarding Depleted

Uranium, Nuclear Regulatory Commission, March 18, 2009, on the Web at http://www.nrc.gzov/reading-rm/doccollections/commission/srm/2008/2008-0147srm.pdf. The Commission's approval of the staff's recommendation

was not unanimous. Commissioner Gregory Jaczko dissented. See below.

3 R.W. Borchardt (Executive Director for Operations), to the Commissioners [of the NRC], Response to Commission

Order CLI-05-20 Regarding Depleted Uranium, Rulemaking Issue, SECY-08-0147, October 7, 2008, on the Web at

http://www.nrc.jzov/reading-rm/doc-collections/commission/secys/2008/secy2OO8-0 147/2008-01 47scy.pdf.

Hereafter referred to as SECY-08-0147 2008.

1

_______ 17~--_=~~~~~-------------------------------------------------------- 1l@@17 INSTITUTE FOR ENERGY AND 

ENVIRONMENTAL RESEARCH 

6935 Laurel Avenue, Suite 201. 

Takoma Park, MD 20912 

Phone: (301) 270-5500 

FAX: (301) 270-3029 

e~mail: ieer@ieer.org 

http://www.ieer.org 

lEER Comments on the Nuclear Regulatory Commission's 

Rulemaking Regarding the "Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium"l 

Arjun Makhijani 

October 30, 2009 

On March 18, the Nuclear Regulatory Commission (NRC) directed its staff to proceed with a 

rulemaking to amend the low-level waste rule to take into account the gap in the existing rule,2 

which does not address depleted uranium waste created in large amounts, such as at uranium 

enrichment plants. This followed the preparation by the staff of a paper, SECY -08-14 7,3 which 

presented the Commission with four options. The March 18,2009, decision was to proceed with 

Option 2 as specified in SECY -08-14 7. 

Previously, in the adjudicatory proceeding for the Louisiana Enrichment Services 

(LES) license application, the Commission detennined that depleted uranium is 

properly classified as low-level radioactive waste. Although the Commission 

stated that a literal reading of 10 CFR 61.55(a)(6) would render depleted uranium 

a Class A waste, it recognized that the analysis supporting this section did not 

address the disposal oflarge quantities of depleted uranium. Outside of the 

adjudication, the staff was tasked to evaluate this complex issue and provide 

specific recommendations to the Commission. SECY -08-0147 is the result of the 

Commission's direction and provides recommendations for a path forward. 

I U.S. Nuclear Regulatory Commission, "Notice of Public Workshop on a Potential Rulemaking for Safe Disposal 

of Unique Waste Streams Including Significant Quantities of Depleted Uranium," Federal Register v.74, nO.120 

(June 24, 2009), pages 30175-30179, on the Web at http://edocket.access.gpo.gov/2009/pdf/E9-14820.pdf. 

I-Iereafter referred to as NRC FR Notice 2009. Hereafter NRC FR Notice 2009. 

2 Annette L. Vietti-Cook (Secretary [of the Commission]), Memorandum to R. W. Borchardt (Executive Director for 

Operations), Staff Requirements - SECY-08-0147 - Response to Commission Order CLJ-05-20 Regarding Depleted 

Uranium, Nuclear Regulatory Commission, March 18,2009, on the Web at http://www.nrc.gov/reading-rm/doccollections/commission/srm/200S/200S-0147sml.pdf. The Commission's approval of the staffs recommendation 

was not unanimous. Commissioner Gregory laczko dissented. See below. 

3 R.W. Borchardt (Executive Director for Operations), to the Commissioners [of the NRC], Response to Commission 

Order CLJ-05-20 Regarding Depleted Uranium, Rulemaking Issue, SECY-OSc0147, October 7, 200S, on the Web at 

http://www .nrc. gov/reading-nn/doc-collections/commission/secys/2008/secy2008-014712008-0147 scy.pdf. 

Hereafter referred to as SECY-OS-0147 2008. 

1 
As an initial approach to addressing this complicated issue, the Commission has

approved the staff's recommended Option 2 to 1) proceed with rulemaking in 10

CFR Part 61 to specify a requirement for a site-specific analysis for the disposal

of large quantities of depleted uranium (DU) and the technical requirements for

such an analysis; and 2) to develop a guidance document for public comment that

outlines the parameters and assumptions to be used in conducting such sitespecific analyses.

In revising 10 CFR 61.55(a)(6) in this limited scope rulemaking, the Commission

is not proposing to alter the waste classification of depleted uranium. Eventual

changes to waste classification designations in the regulations must be analyzed

in light of the total amount of depleted uranium being disposed of at any given

site. However, the Commission is stating that for waste streams consisting of

significant amounts of depleted uranium, there may be a need to place additional

restrictions on the disposal of the depleted uranium at a specific site or deny such

disposal based on unique site characteristics and those restrictions should be

determined by a site specific analysis which satisfies the requirements of the

proposed new 61.55(a)(9). This thought should be clearly indicated in the

proposed rulemaking package seeking public comment. As part of this

rulemaking, the staff should promptly conduct a public workshop inviting all

potentially affected stakeholders, including licensees, state regulators and federal

agencies. At this workshop, the staff should discuss the issues associated with the

disposal of depleted uranium, the potential issues to be considered in rulemaking,

and technical parameters of concern in the analysis so that informed decisions

can be made in the interim period until the rulemaking is final.4

The first thing to note here is that the Commission is proposing only to revise 10 CFR

61.55(a)(6) and to add a new paragraph 10 CFR 61.55(a)(9), which does not now exist.

Specifically, it is not proposing within this limited rulemaking to modify any part of 10 CFR 61

outside of 10 CFR 61.55(a). This intention is also clear from the Federal Register notice

announcing the workshops. 5 The second critical thing to note is that the vote was not

unanimous. Commissioner Jaczko, who has since been appointed the Chairman of the NRC,

voted against Option 2, having earlier stated his preference for Option 3:

In my original vote on SECY-08-0147, I approved Option 3 (determine

classification for depleted uranium within existing classification framework) and

I disapproved the staff's recommendation for Option 2 (rulemaking to specify

requirement for site-specific analyses for the disposal of large quantities of

depleted uranium). Since that vote, which was dated November 3, 2008, more

information has come to light that I would like to address in my vote.

The disposal of large quantities of depleted uranium (DU) is a unique challenge

because, unlike typical low-level waste, the doses increase over time rather than

decrease. The technical analysis included with SECY-08-0147 indicates that

4 Annette L. Vietti-Cook (Secretary [of the Commission]), Memorandum to R. W. Borchardt (Executive Director for

Operations), Staff Requirements - SECY-08-O147 - Response to Commission Order CLI-05-20 Regarding Depleted

Uranium, Nuclear Regulatory Commission, March 18, 2009, on the Web at http://www.nrc.gov/reading-m-/doccollections/commission/snm/2008/2008-0147srm.pdf

5 NRC FR Notice 2009.

2

As an initial approach to addressing this complicated issue, the Commission has 

approved the staffs recommended Option 2 to 1) proceed with rulemaking in 10 

CFR Part 61 to specify a requirement for a site-specific analysis for the disposal 

of large quantities of depleted uranium (DU) and the technical requirements for 

such an analysis; and 2) to develop a guidance document for public comment that 

outlines the parameters and assumptions to be used in conducting such sitespecific analyses. 

In revising 10 CFR 61.55 (a)( 6) in this limited scope rulemaking, the Commission 

is not proposing to alter the waste Classification of depleted uranium. Eventual 

changes to waste classification designations in the regulations must be analyzed 

in light of the total amount of depleted uranium being disposed of at any given 

site. However, the Comniission is stating that for waste streams consisting of 

significant amounts of depleted uranium, there may be a need to place additional 

restrictions on the disposal of the depleted uranium at a specific site or deny such 

disposal based on unique site characteristics and those restrictions should be 

determined by a site specific analysis which satisfies the requirements of the 

proposed new 61.55(a)(9). This thought should be clearly indicated in the 

proposed rulemaking package seeking public comment. As part of this 

rulemaking, the staff should promptly conduct a public workshop inviting all 

potentially affected stakeholders, including licensees, state regulators and federal 

agencies. At this workshop, the staff should discuss the issues associated with the 

disposal of depleted uranium, the potential issues to be considered in rulemaking, 

and technical parameters of concern in the analysis so that informed decisions 

ca~ be made in the interim period until the rulemaking is fina1. 4 

The first thing to note here is that the Commission is proposing only to revise 10 CFR 

61.55(a)(6) and to add a new paragraph 10 CFR 61.55(a)(9), which does not now exist. 

Specifically, it is not proposing within this limited rulemaking to modify any part of 10 CFR 61 

outside of 10 CFR 61.55(a). This intention is also clear from the Federal Register notice 

announcing the workshops. 5 The second critical thing to note is that the vote was not 

unanimous. Commissioner Jaczko, who has since been appointed the Chairman of the NRC, 

voted against Option 2, having earlier stated his preference for Option 3: 

In my original vote on SECY-08-0147, I approved Option 3 (determine 

classification for depleted uranium within existing classification framework) and 

I disapproved the staffs recommendation for Option 2 (rulemaking to specify 

requirement for site-specific analyses for the disposal of large quantities of 

depleted uranium). Since that vote, which was dated November 3, 2008,more 

information has come to light that I would like to address in my vote. 

The disposal of large quantities of depleted uranium (DU) is a unique challenge 

because, unlike typical low-level waste, the doses increase over time rather than 

decrease. The technical analysis included with SECY -08-0147 indicates that 

4 Annette L. Vietti-Cook (Secretary [of the Commission]), Memorandum to R. W. Borchardt (Executive Director for 

Operations), Staff Requirements - SECY-OB-0147 - Response to Commission Order CL/-05-20 Regarding Depleted 

Uranium, Nuclear Regulatory Commission, March 18,2009, on the Web at http://www.nrc.gov/reading-mlldoccollections/commissionlsnnl2008/2008-0 147 srm.pdf. 

5 NRCFR Notice 2009. 

2 
additional requirements are likely needed for disposal of large quantities of DU

in order to protect public health and safety; for example, increased waste disposal

depth or robust radon barriers may be required. However, Option 2 does not

explicitly change the classification of DU as presently provided for in 10 CFR

61.55 and therefore the waste would remain classified as Class A. I do not

believe that it is logical to argue that that waste that requires additional

requirements for disposal (similar to those required for Class C waste) can still be

labeled as Class A waste.6

As directed by the Commission,, the NRC staff held a two day workshop in Bethesda,

Maryland, in which I was an invited participant, as well as one in Salt Lake City.7 The

proceedings were transcribed. The transcript and slide presentations have been posted on the

NRC's website.

I will first provide comments on the DU portion of the rulemaking and then provide briefer

comments relating to other unique waste forms and the NRC's proposal for a longer term riskinformed revision of the entire low-level waste rule.

A. SECY-08-147 Is Fundamentally Deficient in Concept

Option 2, as described in SECY-08-147, is to keep the existing designation of DU as Class A

waste based on the default paragraph in the low-level waste rule 10 CFR 61.55(a)(6). This

paragraph states: "If radioactive waste does not contain any nuclides listed in either Table 1 or 2,

it is Class A." Since this was recognized as insufficient for ensuring health and safety, Option 2

proposes the addition of a new paragraph. The proposal is summed up in SECY-08-147 as

follows:

Proposed Change: Modify paragraph 61.55(a)(6) to include a statement that, for

unique waste streams including, but not limited to, large quantities of depleted

uranium, the requirements of § 61.55(a)(9) of this part must be met. Section

61.55(a) would then be modified to include a paragraph (a)(9), which would

include a requirement that the disposal facility licensee must perform, and the

Commission must approve, a site specific analysis demonstrating that the unique

waste stream, including large quantities of depleted uranium, can be disposed of

at the site in conformance with the performance objectives in subpart C to Part

61.8

6 Commissioner Jaczko's Revised Comments on SECY-08-0147 Response to Commission Order CLI-05-20

Regarding Depleted Uranium, March 6, 2009, on the Web at http://www.nrc.gov/readine-nn/doccollections/commission/cvr/2008/2008-0147vtr.pdf. See pdf pp. 7 and 8.

7 The transcripts for both the Maryland (September 2 and 3, 2009) and the Utah (September 23 and 24, 2009)

Workshops, the slide presentations, and background documents are available on the NRC's web page: Unique Waste

Streams, on the Web at http://www.nrc.jgov/about-nrc/regulatory/rulemaking/potential-rulemaking/uw-streams.html.

Hereafter cited as NRC DU meeting transcript, September 2, 2009, and NRC DU meeting transcript September 3,

2009.

8 SECY-08-0147 2008, p. 8. Italics, in the original, provide the text of the proposed new paragraph.

3

additional requirements are likely needed for disposal of large quantities of DU 

in order to protect public health and safety; for example, increased waste disposal 

depth or robust radon barriers may be required. However, Option 2 does not 

explicitly change the classification ofDU as presently provided for in 10 CFR 

61.55 and therefore the waste would remain classified as Class A. I do not 

believe that it is logical to argue that that waste that requires additional 

requirements for disposal (similar to those required for Class C waste) can still be 

labeled as Class A waste. 6 

As directed by the Commission, , the NRC staff held a two day workshop in Bethesda, 

Maryland, in which I was an invited participant, as well as one in Salt Lake City.? The 

proceedings were transcribed. The transcript and slide presentations have been posted on the 

NRC's website. 

I will first provide comments on the DU portion of the rulemaking and then provide briefer 

comments relating to other unique waste forms and the NRC's proposal for a longer term riskinformed revision of the entire low-level waste rule. 

A. SECY-08-147 Is Fundamentally Deficient in Concept 

Option 2, as described in SECY-08-147, is to keep the existing designation ofDU as Class A 

waste based on the default paragraph in the low-level waste rule 10 CFR 61.55(a)(6). This 

paragraph states: "If radioactive waste does not contain any nuclides listed in either Table 1 or 2, 

it is Class A." Since this was recognized as insufficient for ensuring health and safety, Option 2 

proposes the addition of a new paragraph. The proposal is summed up in SECY -08-14 7 as 

follows: 

Proposed Change: Modify paragraph 61.55(a)(6) to include a statement that, for 

unique waste streams including, but not limited to, large quantities of depleted 

uranium, the requirements (if § 61.55(a)(9) of this part must be met. Section 

61.55(a) would then be modified to include a paragraph (a)(9), which would 

include a requirement that the disposal facility licensee must perform, and the 

Commission must approve, a site specific analysis demonstrating that the unique 

waste stream, including large quantities of depleted uranium, can be disposed of 

at the site in conformance with the performance objectives in subpart C to Part 

61.8 

6 Commissioner laczko 's Revised Comments on SECY-08-0147 Response to Commission Order CLJ-05-20 

Regarding Depleted Uranium, March 6, 2009, on the Web at http://www.nrc.gov/reading-n11/doccollections/commission/cvrl200812008-0 14 7vtr.pdf. See pdf pp. 7 and 8. 

7 The transcripts for both the Maryland (September 2 and 3, 2009) and the Utah (September 23 and 24, 2009) 

Workshops, the slide presentations, and background documents are available on the NRC's web page: Unique Waste 

Streams, on the Web at http://www .nrc. gov/about-nrc/regulatory/rulemaking/potential-rulemaking/uw-streams.html. 

Hereafter cited as NRC DU meeting transcript, September 2, 2009, and NRC DU meeting transcript September 3, 

2009. 

s SECY-OS-0147 200S, p. S. Italics, in the original, provide the text of the proposed new paragraph. 

3 
There are is a fundamental problem with this paragraph. It assumes that there exist sites that can

comply with the performance requirements of 10 CFR 61, Subpart C. SECY-08-0147 provides

no site-specific analysis to prove this in even one case. As we will see, the generic analysis of

various types of sites and scenarios performed are fundamentally deficient in their assumptions

and in their modeling. The NRC staff did not take into account even the possibility that no site

would be found suitable under the performance requirements of Subpart C. Option 2 contains no

fallback provision to examine alternative methods of managing large amounts of DU that could

meet the performance requirements. Specifically, it does not consider deep disposal.

But the problem goes even deeper. The NRC staff failed even in its generic and deficient

analysis to examine whether shallow land burial (at sufficient depth but less than 30 meters)

could meet the performance requirements of Subpart C. So far as limiting dose to the general

public are concerned, those performance requirements are specified at 10 CFR 61.41 as follows:

Concentrations of radioactive material which may be released to the general

environment in ground water, surface water, air, soil, plants, or animals must not

result in an annual dose exceeding an equivalent of 25 millirems to the whole

body, 75 millirems to the thyroid, and 25 millirems to any other organ of any

member of the public. Reasonable effort should be made to maintain releases of

radioactivity in effluents to the general environment as low as is reasonably

achievable.

SECY-08-0147 did not calculate organ doses at all despite the fact that the main radionuclides in

question - uranium-238, uranium-234, thorium-230, radium-226, radon-222 (and its daughters) -

have dose conversion factors for particular organs that are much greater than for the equivalent

dose to the whole body. For instance, the bone surface dose due to radium-226 per unit intake by

ingestion. is about 44 times larger than the whole body dose equivalent. As another example, the

target organ for radon-222 (and its decay products) is the lung and other organs get minimal

doses. When organ dose to whole body equivalent ratios for inhalation are considered

(important in case waste is uncovered by erosion, especially in dry areas), the differences can be

even greater. The ratio of bone surface dose to the whole body effective dose equivalent for

inhalation of medium solubility thorium-230 is more than 50.9

Other examples are easy to provide. For instance, the bone surface dose from drinking water

contaminated with lead-210 (a decay product of radon-222) is more than 30 times bigger than the

committed whole body equivalent dose.

At the Bethesda, Maryland, workshop, I asked why the performance assessment was not

according to the criteria in 10 CFR 61 Subpart C. Dr. Esh, the principal author of the analysis in

SECY-08-147, stated that the NRC staff had used a "modem" approach and used TEDE as the

performance criterion:

Primarily because in more recent evaluations; in particular, for waste incidental

to reprocessing, we have had direction from the Commission to use more modem

methods, instead of those old methods. So we followed that direction. 10

9 Dose conversion factors are from EPA's Federal Guidance Report 13. 10 NRC DU meeting transcript, September 2, 2009, p. 104.

4

There are is a fundamental problem with this paragraph. It assumes that there exist sites that can 

comply with the performance requirements of 10 CFR 61, Subpart C. SECY-08-0147 provides 

no site-specific analysis to prove this in even one case. As we will see, the generic analysis of 

various types of sites and scenarios performed are fundamentally deficient in their assumptions 

and in their modeling. The NRC staff did not take into account even the possibility that no site 

would be found suitable under the performance requirements of Subpart C. Option 2 contains no 

fallback provision to examine alternative methods of managing large amounts of DU that could 

meet the performance requirements. Specifically, it does not consider deep disposal. 

But the problem goes even deeper. The NRC staff failed even in its generic and deficient 

analysis to examine whether shallow land burial (at sufficient depth but less than 30 meters) 

could meet the performance requirements of Subpart C. So far as limiting dose to the general 

public are concerned, those performance requirements are specified at 10 CFR 61.41 as follows: 

Concentrations of radioactive material which may be released to the general 

environment in ground water, surface water, air, soil, plants, or animals must not 

result in an annual dose exceeding an equivalent of 25 millirems to the whole 

body, 75 millirems to the thyroid, and 25 millirems to any other organ of any 

member of the public. Reasonable effort should be made to maintain releases of 

radioactivity in effluents to the general environment as low as is reasonably 

achievable. 

SECY-08-0147 did not calculate organ doses at all despite the fact that the main radionuclides in 

question - uranium-238, uranium-234, thorium-230, radium-226, radon-222 (and its daughters)-

have dose conversion factors for particular organs that are much greater than for the equivalent 

dose to the whole body. For instance, the bone surface dose due to radium-226 per unit intake by 

ingestion is about 44 times larger than the whole body dose equivalent. As another example, the 

target organ for radon-222 (and its decay products) is the lung and other organs get minimal 

doses. When organ dose to whole body equivalent ratios for inhalation are considered 

(important in case waste is uncovered by erosion, especially in dry areas), the differences can be 

even greater. The ratio of bone surface dose to the whole body effective dose equivalent for 

inhalation of medium solubility thorium-230 is more than 50.9 

Other examples are easy to provide. For instance, the bone surface dose from drinking water 

contaminated with lead-21 0 (a decay product of radon-222) is more than 30 times bigger than the 

committed whole body equivalent dose. 

At the Bethesda, Maryland, workshop, I asked why the performance assessment was not 

according to the criteria in 10 CFR 61 Subpart C. Dr. Esh, the principal author of the analysis in 

SECY-08-147, stated that the NRC staff had used a "modem" approach and used TEDE as the 

performance criterion: 

Primarily because in more recent evaluations; in particular, for waste incidental 

to reprocessing, we have had direction from the Commission to use more modern 

methods, instead of those old methods. So we followed that direction. 10 

9 Dose conversion factors are from EPA's Federal Guidance Report 13. 

10 NRC DU meeting transcript, September 2, 2009, p. 104. 

4 
I pointed out that human beings still have organs, and 10 CFR 61 Subpart C requires organ dose

calculations, so it is not a question of "modern" methods of calculation. Further, the most recent

EPA method of internal dose calculation, published as Federal Guidance Report 13, allows for

both organ dose and whole body effective dose equivalent calculations. So it is not even a

question of "modern" methods versus obsolete methods.

Also, whether a certain method is "modern" or not or whether only whole body equivalent doses

are used in other parts of the NRC's work is irrelevant. The plain language of the present DU

rulemaking process requires an evaluation relative to the performance requirements of 10 CFR

61, and those requirements are in Subpart C. In turn, Subpart C requires, among other things,

limitation of organ dose. Hence, in every circumstance where organ dose may exceed whole

body effective dose equivalent, as is the case with DU disposal, the rule requires the calculation

dose to the critical or most exposed organ.

As noted above, the Commission is proposing only to revise 10 CFR 61.55(a)(6) and add a new

paragraph that would specify disposal requirements for DU. The Commission has not authorized

modification of 10 CFR 61 Subpart C. Specifically, it has not anywhere mentioned that the

organ dose requirement of 10 CFR 61.41, which is in Subpart C, is to be ignored or changed.

Further, SECY-08-0147 itself states that it will examine whether compliance with 10 CFR 61

Subpart C can be achieved with shallow land burial:

The technical analysis addressed whether amendments to § 61.55(a) are

necessary to assure large quantities of DU are disposed of in a manner that meets

the performance objectives in Subpart C of 10 CFR Part 61.1

Dr. Esh, the principal NRC staff author of SECY-08-0147, explicitly stated during the Bethesda,

Maryland, workshop that the NRC was not proposing to modify Subpart C.12

But SECY-08-0147 did not evaluate performance of DU disposal in shallow land facilities

according to a principal element of the requirements of Subpart C. Rather SECY-08-0147

entirely ignored the organ dose calculation requirements of Subpart C as specified in 10

CFR 61.41. This is a central problem with the present proceeding without any other factor.

Further, were organ doses to be calculated, even with the fundamentally deficient modeling

in SECY-08-0147 (see below), that, contrary to the conclusions of the SECY-08-0147, the

model may show that the performance requirements of Subpart C would not be met by

shallow land disposal.

The decision of the NRC instructing the staff to proceed with the rulemaking based on Option 2

is basically flawed since it depends centrally on the technical analysis of the NRC staff in SECY08-0147 actually showing that it was, at least in theory, possible that some imaginable shallow

land configuration could meet the performance requirements of Subpart C. But SECY-08-0147

is fundamentally incomplete since it did not even attempt to calculate organ doses, which are

most important, under the circumstances, for evaluating disposal performance.

SECY-08-0147 2008, p. 1. 12 NRC DU meeting transcript, September 2, 2009, p. 105.

5

I pointed out that human beings still have organs, and 10 CFR 61 Subpart C requires organ dose 

calculations, so it is not a question of "modem" methods of calculation. Further, the most recent 

EP A method of internal dose calculation, published as Federal Guidance Report 13, allows for 

both organ dose and whole body effective dose equivalent calculations. So it is not even a 

question of "modem" methods versus obsolete methods. 

Also, whether a certain method is "modem" or not or whether only whole body equivalent doses 

are used in other parts of the NRC's work is irrelevant. The plain language of the present DU 

rulemaking process requires an evaluation relative to the performance requirements of 10 CFR 

61, and those requirements are in Subpart C. In tum, Subpart C requires, among other things, 

limitation of organ dose. Hence, in every circumstance where organ dose may exceed whole 

body effective dose equivalent, as is the case with DU disposal, the rule requires the calculation 

dose to the critical or most exposed organ. 

As noted above, the Commission is proposing only to revise 10 CFR 61.55(a)(6) and add a new 

paragraph that would specify disposal requirements for DU. The Commission has not authorized 

modification of 10 CFR 61 Subpart C. Specifically, it has not anywhere mentioned that the 

organ dose requirement of 10 CFR 61.41, which is in Subpart C, is to be ignored or changed. 

Further, SECY-08-0147 itself states that it will examine whether compliance with 10 CFR 61 

Subpart C can be achieved with shallow land burial: 

The technical analysis addressed whether amendments to § 61.55(a) are 

necessary to assure large quantities of DU are disposed of in a manner that meets 

the performance obj ectives in Subpart C of 10 CFR Part 61.11 

Dr. Esh, the principal NRC staff author of SECY -08-0147, explicitly stated during the Bethesda, 

Maryland, workshop that the NRC was not proposing to modify Subpart C. 12 

But SECY-08-0147 did not evaluate performance ofDU disposal in shallow land facilities 

according to a principal element ofthe requirements of Subpart C. Rather SECY-08-0147 

entirely ignored the organ dose calculation requirements of Subpart C as specified in 10 

CFR 61.41. This is a central problem with the present proceeding without any other factor. 

Further, were organ doses to be calculated, even with the fundamentally deficient modeling 

in SECY-08-0147 (see below), that, contrary to the conclusions ofthe SECY-08-0147, the 

model may show that the performance requirements of Subpart C would not be met by 

shallow land disposal. 

The decision of the NRC instructing the staff to proceed with the rulemaking based on Option 2 

is basically flawed since it depends centrally on the technical analysis of the NRC staff in SECY08-0147 actually showing that it was, at least in theory, possible that some imaginable shallow 

land configuration could meet the performance requirements of Subpart C. But SECY -08-0147 

is fundamentally incomplete since it did not even attempt to calculate organ doses, which are 

most important, under the circumstances, for evaluating disposal performance. 

II SECY -08-0147 2008, p. 1. 

12 NRC DU meeting transcript, September 2,2009, p. 105. 

5 
Recommendation 1: Since the entire premise of proceeding is fundamentally flawed in

regard to the performance requirements of Subpart C, and since the staff paper on which

the NRC made its decision to proceed with this rulemaking did not even attempt to

calculate organ doses, as required by Subpart C, the NRC should stop the present process

immediately and begin a new rulemaking that properly specifies the parts of the rule that

are being considered for revision and that provides the relevant NRC analysis to the public

so that it may comment upon it.

B. Scientific Deficiencies in SECY-08-0147

The main technical premise on which the proposed rule change in regard to disposal of

significant amounts of DU as Class A waste is that it can be shown that certain low-level waste

shallow land disposal facilities would meet the performance requirements of 10 CFR 61. In this

section we will leave aside the basic problem that SECY-08-147 did not evaluate the most

important part of the performance requirement (dose to the critical organ) and focus on the

model and the assumptions that the staff used in SECY-08-147 to analyze performance.

The following are features of the analysis of performance in SECY-08-0147:

* It considers sites in various climatic zones, but is not site specific.

* It assessed doses for one million years - the approximate period during which the decay

products of U-238, the main ingredient of DU, continue to build up. This approximates a

peak dose calculation.

" As radium-226 builds up over thousands of years, radon-222 emissions increase. Radon222 doses were included in the analysis. A clay layer that would inhibit radon migration

was included. Given the assumption of no erosion, this layer would essentially stay intact

over a million years.

* Shallow burial (defined as less than 30 meters depth) at various depths was considered.

* Chronic intruder as well as offsite resident doses were considered.

* Various exposure pathways were considered.

" Both air and water induced erosion were assumed to be zero for one million years.

* An ad hoc model, consisting of a commercial Monte Carlo package and an in-house

spreadsheet, was developed.

. The dose assessment was based on TEDE, which is Total Effective Dose Equivalent

(defined as the sum of deep external dose and committed effective dose equivalent for

internal dose).

* For the offsite resident a 25 millirem annual TEDE dose limit was applied as the

performance objective. For the chronic intruder who builds a house above the disposal

site, a 500 millirem annual dose limit (TEDE) was applied as the performance

objective.'

3

3 It should be noted that 10 CFR 61 requires assurance that an inadvertent intruder be protected after institutional

control expires, but does not specify a dose limit. 10 CFR 61.42 states in its entirety: "Design, operation, and

closure of the land disposal facility must ensure protection of any individual inadvertently intruding into the disposal

6

Recommendation 1: Since the entire premise of proceeding is fundamentally flawed in 

regard to the performance requirements of Subpart C, and since the staff paper on which 

the NRC made its decision to proceed with this rulemaking did not even attempt to 

calculate organ doses, as required by Subpart C, the NRC should stop the present process 

immediately and begin a new rulemaking that properly specifies the parts of the rule that 

are being considered for revision and that provides the relevant NRC analysis to the public 

so that it may comment upon it. 

B. Scientific Deficiencies in SECY-08-0147 

The main technical premise on which the proposed rule change in regard to disposal of 

significant amounts of DU as Class A waste is that it can be shown that certain low-level waste 

shallow land disposal facilities would meet the performance requirements of 10 CFR 61. In this 

section we will leave aside the basic problem that SECY-08-147 did not evaluate the most 

important part of the performance requirement (dose to the critical organ) and focus on the 

model and the assumptions that the staff used in SECY -08-147 to analyze performance. 

The following are features of the analysis of performance in SECY -08-0147: 

• It considers sites in various climatic zones, but is not site specific. 

• It assessed doses for one million years - the approximate period during which the decay 

products ofU-238, the main ingredient ofDU, continue to build up. This approximates a 

peak dose calculation. 

• As radium-226 builds up over thousands of years, radon-222 emissions increase. Radon222 doses were included in the analysis. A clay layer that would inhibit radon migration 

was included. Given the assumption of no erosion, this layer would essentially stay intact 

over a million years. 

• Shallow burial (defined as less than 30 meters depth) at various depths was considered. 

• Chronic intruder as well as offsite resident doses were considered. 

• Various exposure pathways were considered. 

• Both air and water induced erosion were assumed to be zero for one million years. 

• An ad hoc model, consisting of a commercial Monte Carlo package and an in-house 

spreadsheet, was developed. 

• The dose assessment was based on TEDE, which is Total Effective Dose Equivalent 

(defined as the sum of deep external dose and committed effective dose equivalent for 

internal dose). 

• For the offsite resident a 25 millirem annual TEDE dose limit was applied as the 

performance objective. For the chronic intruder who builds a house above the disposal 

site, a 500 millirem annual dose limit (TEDE) was applied as the performance 

objective. 13 

13 It should be noted that 10 CFR 61 requires assurance that an inadvertent intruder be protected after institutional 

control expires, but does not specify a dose limit. 10 CFR 61.42 states in its entirety: "Design, operation, and 

closure of the land disposal facility must ensure protection of any individual inadvertently intruding into the disposal 

6 
The results of the modeling were as follows:

* Using the TEDE approach, the analysis concluded that shallow land burial, less than 3

meters deep, was not suitable for DU, except for "small quantities" defined as 1 to 10

metric tons. 14

* Disposal of DU in large amounts at humid sites "with viable water pathways is probably

not appropriate."' 5

* For disposal at 5 meters or deeper, up to 30 meters, SECY-08-0147 concluded that

disposal at arid sites could meet performance criteria:

Depleted uranium can be disposed of under arid conditions and meet the

Part 61 performance objectives for 1,000 to I million years performance

periods, if the waste disposal depth is large, or robust barriers are in

place to mitigate radon.' 6

Besides the failure to evaluate doses to organs, the following limitations of the analysis should be

noted (most came up during the presentations or the discussion at the Bethesda, Maryland,

workshop):

1. Climate change was not considered - that is, a constant climate was assumed for one

million years.

2. Changes to the chemical form of uranium over one million years were not considered.

3. Colloidal transport of radionuclides was not included.

4. The clay barrier to radon migration into a home built over or near the disposal area

was assumed to stay intact over a million years (e.g., no cracks would develop that

may allow more migration of radon into the house). The effects of aeolian or fluvial

erosion were not considered. The assumption was that the site would be stable for

one million years. (The assumption is stated as follows in SECY-08-0147: "Site

stability requirements would be achieved. There will not be significant releases of

waste to the environment from fluvial or aeolian erosion."'' 7

Let us consider these problems one by one.

1. Climate change

It is scientifically unsound and contrary to the available data to assume that climate will not

change for one million years. Even without the anthropogenic emissions that are currently

accelerating climate change, climate has changed naturally on times scales of thousands of years.

For instance, Dr. Peter Bums of the University of Notre Dame, a geochemist invited by the NRC

to participate in both workshops, and who participated in both of them, noted that Death Valley

site and occupying the site or contacting the waste at any time after active institutional controls over the disposal site

are removed." A figure of 500 mrem per year is often used for performance assessment.

14 SECY-08-0147 2008, Enclosure 1, p. 16.

"5 SECY-08-0147 2008, Enclosure 1, p. 16.

16 SECY-08-0147 2008, Enclosure 1, p. 16. Emphasis in the original.

17 SECY-08-0147 2008, Enclosure 1, p. 9.

7

The results of the modeling were as follows: 

• Using the TEDE approach, the analysis concluded that shallow land burial, less than 3 

meters deep, was not suitable for DU, except for "small quantities" defined as I to 10 

metric tons. 14 

• Disposal of DU in large amounts at humid sites "with viable water pathways is probably 

not appropriate." 15 

• For disposal at 5 meters or deeper, up to 30 meters, SECY-08-0147 concluded that 

disposal at arid sites could meet performance criteria: 

Depleted uranium can be disposed of under arid conditions and meet the 

Part 61 performance objectives for 1,000 to 1 million years performance 

periods, if the waste disposal depth is large, or robust barriers are in 

place to mitigate radon. 16 

Besides the failure to evaluate doses to organs, the following limitations of the analysis should be 

noted (most came up during the presentations or the discussion at the Bethesda, Maryland, 

workshop): 

1. Climate change was not considered - that is, a constant climate was assumed for one 

million years. 

2. Changes to the chemical form of uranium over one million years were not considered. 

3. Colloidal transport of radio nuclides was not included. 

4. The clay barrier to radon migration into a home built over or near the disposal area 

was assumed to stay intact over a million years (e.g., no cracks would develop that 

may allow more migration of radon into the house). The effects of aeolian or fluvial 

erosion were not considered. The assumption was that the site would be stable for 

one million years. (The assumption is stated as follows in SECY-08-0147: "Site 

stability requirements would be achieved. There will not be significant releases of 

waste to the environment from fluvial or aeolian erosion.,,17 

Let us consider these problems one by one. 

1. Climate change 

It is scientifically unsound and contrary to the available data to assume that climate will not 

change for one million years. Even without the anthropogenic emissions that are currently 

accelerating climate change, climate has changed naturally on times scales of thousands of years. 

For instance, Dr. Peter Bums of the University of Notre Dame, a geochemist invited by the NRC 

to participate in both workshops, and who participated in both of them, noted that Death Valley 

site and occupying the site or contacting the waste at any time after active institutional controls over the disposal site 

are removed." A figure of 500 mrem per year is often used for performance assessment. 

14 SECY-08-0147 2008, Enclosure 1, p. 16. 

15 SECY-08-0147 2008, Enclosure 1, p. 16. 

16 SECY-08-0147 2008, Enclosure 1, p. 16. Emphasis in the original. 

17 SECY-08-0147 2008, Enclosure 1, p. 9. 

7 
was underwater 10,000 years ago and that climate projections could not be relied on for 10,000

or 100,000 or 1 million years.

Climate affects practically every environmental factor relevant to the performance assessment

from the integrity of the cap to erosion rates to dilution of radionuclides in groundwater. As one

example, the model results in SECY-08-0147 show that "[r]adon fluxes to the environment are

very sensitive to the long-term moisture state of the system."'18 Since rainfall is one critical

parameter to vary in climate, the radon dose results would evidently also be affected. Similarly,

radon dose results would be affected if the integrity of the clay liner is damaged or destroyed by

variations in rain, snow, temperature, and/or wind that are greater than those assumed in the

modeling. (SECY-08-0147 assumes no erosion even from the present climate - see below).

In fact, the record of the Bethesda, Maryland, workshop shows that even the NRC staff agreed

that ignoring climate change for such long periods was not appropriate. The terms "silly" and

"silliness" came up in the context of trying to describe attempts to model shallow land burial for

a million years, but it was suggested by the moderator, Chip Cameron, that this was perhaps not

the best language to use in a regulatory context.19 Whatever, the term used to describe the fact

that the modeling ignored climate change, the essence of the matter is that there was general

agreement that climate change should not be ignored for shallow land burial for periods much

shorter than one million years - for instance over 10,000 years. This is not as important in the

context of radionuclides with half-lives that are much shorter than 10,000 years, but in a context

of DU, where the specific activity of the material is growing due to the build up of daughter

products, it is essential to consider climate change.

Recommendation 2: Future modeling for disposal of significant amounts of DU should

include climate change.

2. Chemical changes to the form ofDU

SECY-08-0147 considered only shallow land burial, with a clay cap being put over the waste.

By its very nature, the environment of the DU would be oxidizing. Elementary considerations

show that there would be considerable chemical changes, especially over long periods of time in

the proposed waste form, U30 8, that the NRC has accepted as suitable for disposal in its

licensing process of the two uranium enrichment plants (LES and USEC) that were granted

licenses in 2006 and 2007 respectively. Ignoring chemical changes in U30 8 in an oxidizing

environment is not only scientifically unsound, but it also leads to potential underestimates of

uranium mobilization in groundwater. Such mobilization may be enhanced by the presence of

complexing compounds. The dose estimates in SECY-08-0147 may therefore be considerable

underestimates, notably via the water pathway (including radon via the water pathway).

Recommendation 3: A technical discussion of the expected changes in chemical forms in

the specific environment in which disposal is proposed is essential. Specifically, the effects

of an oxidizing environment on the specific waste form proposed, including U30 8, needs to

be analyzed in detail.

18 SECY-08-0147 2008, Enclosure 1, p. 15.

NRC DU meeting transcript September 2, 2009, at various places in pp. 98 to 116 and also pp. 185, 195, and 251.

8

was underwater 10,000 years ago and that climate projections could not be relied on for 10,000 

or 100,000 or 1 million years. 

Climate affects practically every environmental factor relevant to the performance assessment 

from the integrity of the cap to erosion rates to dilution of radionuclides in groundwater. As one 

example, the model results in SECY-08-0147 show that "[r]adon fluxes to the environment are 

very sensitive to the long-term moisture state of the system."lS Since rainfall is one critical 

parameter to vary in climate, the radon dose results would evidently also be affected. Similarly, 

radon dose results would be affected if the integrity of the clay liner is damaged or destroyed by 

variations in rain, snow, temperature, and/or wind that are greater than those assumed in the 

modeling. (SECY-08-0147 assumes no erosion even from the present climate - see below). 

In fact, the record of the Bethesda, Maryland, workshop shows that even the NRC staff agreed 

that ignoring climate change for such long periods was not appropriate. The terms "silly" and 

"silliness" came up in the context of trying to describe attempts to model shallow land burial for 

a million years, but it was suggested by the moderator, Chip Cameron, that this was perhaps not 

the best language to use in a regulatory context. 19 Whatever, the term used to describe the fact 

that the modeling ignored climate change, the essence of the matter is that there was general 

agreement that climate change should not be ignored for shallow land burial for periods much 

shorter than one million years - for instance over 10,000 years. This is not as important in the 

context of radionuclides with half-lives that are much shorter than 10,000 years, but in a context 

of DU, where the specific activity of the material is growing due to the build up of daughter 

products, it is essential to consider climate change. 

Recommendation 2: Future modeling for disposal of significant amounts of DU should 

include climate change. 

2. Chemical changes to the form ofDU 

SECY -08-0147 considered only shallow land burial, with a clay cap being put over the waste. 

By its very nature, the environment of the DU would be oxidizing. Elementary considerations 

show that there would be considerable chemical changes, especially over long periods of time in 

the proposed waste form, U30S, that the NRC has accepted as suitable for disposal in its 

licensing process of the two uranium enrichment plants (LES and USEC) that were granted 

licenses in 2006 and 2007 respectively. Ignoring chemical changes in U30S in an oxidizing 

environment is not only scientifically unsound, but it also leads to potential underestimates of 

uranium mobilization in groundwater. Such mobilization may be enhanced by the presence of 

complexing compounds. The dose estimates in SECY-08-0147 may therefore be considerable 

underestimates, notably via the water pathway (including radon via the water pathway). 

Recommendation 3: A technical discussion of the expected changes in chemical forms in 

the sp'ecific environment in which disposal is proposed is essential. Specifically, the effects 

of an oxidizing environment on the specific waste form proposed, including U30S, needs to 

be analyzed in detail. 

18 SECY-08-0147 2008, Enclosure 1, p. 15. 

19 NRC DU meeting transcript September 2, 2009, at various places in pp. 98 to 116 and also pp. 185, 195, and 251. 

8 
3. Colloidal transport

In the modeling in SECY-08-0147, the principal pathways for radionuclides to reach the human

environment are diffusion of radon through the clay barrier and dissolution of radionuclides in

groundwater and from that various other water related pathways, such as ingestion of

contaminated food irrigated with contaminated water. However, colloidal transport of

radionuclides was not considered. This could be a significant pathway, especially for insoluble

forms of uranium and its decay products.

Recommendation 4: Colloidal transport needs to be included in the modeling of DU

disposal.

4. The assumption of long-term stability

The model assumes that the disposal site, including the clay cap, will be stable for one million

years. Erosion is ignored. It is assumed that the clay liner will not crack for one million years.

This is a critical factor in the performance modeling results. Cracks would provide a fast path

for radon migration. Assuming that a clay liner will stay intact therefore results in spuriously

low radon dose estimates. Of course, considering a thinning of the cap or a complete erosion of

the cap prior to dissolution of the waste would result in very large long term doses. For instance,

uncovering of the waste by aeolian erosion in a few thousand years would expose intruders to

large external gamma doses from radium-226. These doses would be very small if the cap stays

intact, which is the assumption in SECY-08-0147. It can be expected that large doses would

result from shallow land burial even at the depths at which SECY-08-0147 derives low doses in

dry climate if there any significant erosion. This has been demonstrated in straightforward

modeling exercises by the Institute for Energy and Environmental Research which were

introduced into testimony during the LES licensing proceedings.2z

Recommendation 5: A realistic modeling of the shallow land burial needs to be done that

would include fluvial and aeolian erosion, the effects of compromises of the integrity of the

clay cap via the development of cracks, etc.

5. Conclusions regarding modeling in SECY-08-0147

Several of the modeling assumptions that play large roles in the conclusion of SECY-08-0147

that there could exist shallow land disposal sites where doses would be small (less than 25

millirem per year whole body effective dose equivalent) are scientifically unsound. A realistic

20 Arjun Makhijani and Brice Smith, Costs and Risks of Management and Disposal of Depleted Uranium from the

National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES, Takoma Park, MD: Institute

for Energy and Environmental Research, November 24, 2004. Version for public release redacted on Feb. 1, 2005,

on the Web at http://www.ieer.org/reports/du/lesrpt.pdf, p. 24 (Hereafter Makhijani and Smith 2004/2005) and

Arjun Makhijani and Brice Smith, "Update to Costs and Risks of Management and Disposal of Depleted Uranium

from the National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES by Arjun Makhijani,

PhD. and Brice Smith, Ph.D. based on information obtained since November 2004," Takoma Park, MD: Institute for

Energy and Environmental Research, July 5, 2005. Version for public release redacted on Aug. 10, 2005, on the

Web at http://www.ieer.org/reports/du/LESrptupdate.pdf, p. 16. Hereafter Makhijani and Smith 2005.

9

3. Colloidal transport 

In the modeling in SECY -08-0147, the principal pathways for radionuclides to reach the human 

environment are diffusion of radon through the clay barrier and dissolution of radionuclides in 

groundwater and from that various other water related pathways, such as ingestion of 

contaminated food irrigated with contaminated water. However, colloidal transport of 

radionuclides was not considered. This could be a significant pathway, especially for insoluble 

forms of uranium and its decay products. 

Recommendation 4: Colloidal transport needs to be included in the modeling of DU 

disposal. 

4. The assumption of long-term stability 

The model assumes that the disposal site, including the clay cap, will be stable for one million 

years. Erosion is ignored. It is assumed that the clay liner will not crack for one million years. 

This is a critical factor in the performance modeling results. Cracks would provide a fast path 

for radon migration. Assuming that a clay liner will stay intact therefore results in spuriously 

low radon dose estimates. Of course, considering a thinning of the cap or a complete erosion of 

the cap prior to dissolution of the waste would result in very large long term doses. For instance, 

uncovering of the waste by aeolian erosion in a few thousand years would expose intruders to 

large external gamma doses from radium-226. These doses would be very small if the cap stays 

intact, which is the assumption in SECY -08-0147. It can be expected that large doses would 

result from shallow land burial even at the depths at which SECY-08-0147 derives low doses in 

dry climate if there any significant erosion. This has been demonstrated in straightforward 

modeling exercises by the Institute for Energy and Environmental Research which were 

introduced into testimony during the LES licensing proceedings. 20 

Recommendation 5: A realistic modeling of the shallow land burial needs to be done that 

would include fluvial and aeolian erosion, the effects of compromises of the integrity of the 

clay cap via the development of cracks, etc. 

5. Conclusions regarding modeling in SECY-08-0147 

Several of the modeling assumptions that play large roles in the conclusion of SECY -08-0147 

that there could exist shallow land disposal sites where doses would be small (less than 25 

millirem per year whole body effective dose equivalent) are sciel1tifically unsound. A realistic 

20 Arjun Makhijani and Brice Smith, Costs and Risks of Management and Disposal of Depleted Uranium from the 

National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES, Takoma Park, MD: Institute 

for Energy and Environmental Research, November 24,2004. Version for public release redacted on Feb. 1,2005, 

on the Web at http://www.ieer.org/reports/du/lesrpt.pdf, p. 24 (Hereafter Makhijani and Smith 2004/2005) and 

Arjun Makhijani and Brice Smith, "Update to Costs and Risks of Management and Disposal of Depleted Uranium 

from the National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES by Arjun Makhijani, 

PhD. and Brice Smith, Ph.D. based on information obtained since November 2004," Takoma Park, MD: Institute for 

Energy and Environmental Research, July 5, 2005. Version for public release redacted on Aug. 10,2005, on the 

Web at http://www.ieer.org/reports/du/LESmtupdate.pdf: p. 16. Hereafter Makhijani and Smith 2005. 

9 
analysis that took such factors as climate, clay cap stability, and geochemical considerations into

account would lead to three potential conclusions. First, there is no reliable way to estimate long

term performance of DU in shallow land disposal facilities. Second, radiation doses from

shallow land burial under even modestly realistic assumptions are likely to be well over the

performance requirements of Subpart C. Third, the uncertainties in such dose estimates would

be so high that they would be reasonably considered unreliable.

It is reasonable to conclude that a scientifically reliable assessment of DU disposal in shallow

land disposal facilities cannot be made for the time periods at which peak doses from DU would

be expected, or even much shorter time periods of 10,000 or more years.

C. Period of Performance

The Federal Register notice seeks comment on whether the period for which the performance

requirements in regard to dose be limited. There is at present no limitation for period of

performance in 10 CFR 61. Specifically, Subpart C has no time limitation in it. The Federal

Register notice explains the situation as follows:

NRC continues to consider 10,000 years a sufficient period, with some

exceptions, to capture (i) the risk from the short-lived radionuclides, which

comprise the bulk of the activity disposed; and (ii) the peak radiological doses

from the more mobile long-lived radionuclides, which tend to bound the potential

radiological doses at time frames greater than 10,000 years .... As part of a

planned rulemaking, NRC is soliciting stakeholder views regarding a time period

to evaluate the performance of near-surface disposal of unique waste streams. 21

Neither condition that normally applies the customary period of 10,000 years for which NRC

considers it suitable to estimate performance applies to significant amounts of DU. The first

condition obviously does not apply since all three isotopes of uranium in DU (U-234, U-235, and

U-238) are very long-lived. The second condition also does not apply. DU from enrichment

plants or other similarly pure or nearly pure DU (in any common chemical form) has a specific

activity that is far greater than the 100 nanocuries per gram associated with the limit for Class C

waste containing transuranic alpha emitters. Under dry climatic conditions, should they persist

(as is assumed in some scenarios in SECY-08-0147), the DU would not be expected to be mobile

enough for most of it to migrate away from the site. This is indicated by the peak dose analyses

in SECY-08-0147.

I have argued in expert testimony before the NRC that DU from enrichment plants is much like

(GTCC) waste containing long-lived alpha-emitting transuranic radionuclides at concentrations

greater than 100 nanocuries per gram. This conclusion finds support in a National Research

Council publication as well.

If disposal [of depleted uranium oxide] is necessary, it is not likely to be simple.

The alpha activity of DU is 200 to 300 nanocuries pergram. Geological disposal

is required for transuranic waste with alpha activity above 100 nanocuries per

21 NRC FR Notice 2009, pp. 30176-30177.

10

analysis that took such factors as climate, clay cap stability, and geochemical considerations into 

account would lead to three potential conclusions. First, there is no reliable way to estimate long 

term performance of DU in shallow land disposal facilities. Second, radiation doses from 

shallow land burial under even modestly realistic assumptions are likely to be wen over the 

performance requirements of Subpart C. Third, the uncertainties in such dose estimates would 

be so high that they would be reasonably considered unreliable. 

It is reasonable to conclude that a scientifically reliable assessment of DU disposal in shallow 

land disposal facilities cannot be made for the time periods at which peak doses from DU would 

be expected, or even much shorter time periods of 10,000 or more years. 

C. Period of Performance 

The Federal Register notice seeks comment on whether the period for which the performance 

requirements in regard to dose be limited. There is at present no limitation for period of 

performance in 10 CFR 61. Specifically, Subpart C has no time limitation in it. The Federal 

Register notice explains the situation as follows: 

NRC continues to consider 10,000 years a sufficient period, with some 

exceptions, to capture (i) the risk from the short-lived radionuclides, which 

comprise the bulk of the activity disposed; and (ii) the peak radiological doses 

from the more mobile long-lived radionuc1ides, which tend to bound the potential 

radiological doses at time frames greater than 10,000 years .... As part of a 

planned rulemaking, NRC is soliciting stakeholder views regarding a time period 

to evaluate the performance of near-surface disposal of unique waste streams. 21 

Neither condition that normally applies the customary period of 10,000 years for which NRC 

considers it suitable to estimate performance applies to significant amounts ofDU. The first 

condition obviously does not apply since all three isotopes of uranium in DU (U-234, U-235, and 

U-238) are very long-lived. The second condition also does not apply. DU from enrichment 

plants or other similarly pure or nearly pure DU (in any common chemical form) has a specific 

activity that is far greater than the 100 nanocuries per gram associated with the limit for Class C 

waste containing transuranic alpha emitters. Under dry climatic conditions, should they persist 

(as is assumed in some scenarios in SECY-08-0147), the DU would not be expected to be mobile 

enough for most of it to migrate away from the site. This is indicated by the peak dose analyses 

in SECY-08-0147. 

I have argued in expert testimony before the NRC that DU from enrichment plants is much like 

(GTCC) waste containing long-lived alpha-emitting transuranic radionuclides at concentrations 

greater than 100 nanocuries per gram. This conclusion finds support in a National Research 

Council publication as well. 

If disposal [of depleted uranium oxide] is necessary, it is not likely to be simple. 

The alpha activity of DU is 200 to 300 nanocuries per gram. Geological disposal 

is required for transuranic waste with alpha activity above 100 nanocuries per 

21 NRC FR Notice 2009, pp. 30176-30177. 

10 
gram. If uranium were a transuranic element, it would require disposal in the

Waste Isolation Pilot Plant (WIPP) based on its radioactivity. The chemical

toxicity of this very large amount of material would certainly become a problem

as well. One option suggested by the U.S. Nuclear Regulatory Commission

(USNRC) is disposal in a mined cavity or former uranium mine. Challenges for

this option would include understanding the fundamental differences between

uranium ore (see Sidebar 6.1) and the bulk uranium oxide powder.22

The peak doses from DU disposal are expected to occur after thousands of years, hundreds of

thousands of years, or even a million or more years, depending on the chemical form, disposal

site characteristics, etc. Hence, the normal criteria of the NRC limiting performance evaluation

to 10,000 years do not apply.

The staff's position in SECY-08-0147 regarding the period of performance is ambiguous:

Considering the technical aspects of the problem, the performance assessment

staff recommends a performance period of 10,000 years for the analysis of DU

disposal. However, analyses should be performed to peak impact, and if those

impacts are significantly larger than the impacts realized within 10,000 years,

then the longer term impacts should be included in the site environmental

evaluation .23

It is unclear from this whether or not the staff intends for the peak dose to meet Subpart C

criteria or not. However, unless Subpart C is sought to be changed, the performance assessment

must be carried to the time of peak dose and the dose criteria of 10 CFR 61.41, including organ

dose, must be met. But it should be noted in this context that the NRC staff itself does not

consider the analysis in SECY-08-147 to be conservative.

Specifically, SECY-08-0147 and its Enclosure 1, states that the staff developed a "screening

model" to do a "screening analysis" whose purpose "was to evaluate key variables such as

disposal configurations (disposal depth and barriers), performance periods, institutional control

periods, waste forms, site conditions, pathways, and scenarios.', 24

During the Bethesda, Maryland, workshop, I asked whether the term "screening" was being used

to indicate a conservative analysis - that is, an analysis that would give an upper bound for the

dose estimate, so that one could be reasonably assured that a more realistic analysis would yield

a lower dose estimate. In other words, such a screening analysis would lead to an assurance that

the conclusion that.DU could be disposed of in shallow land burial and meet specified

performance criteria was robust.

22 National Research Council, Board on Radioactive Waste Management, Committee on Improving the Scientific

Basis for Managing Nuclear Materials and Spent Nuclear Fuel through the Environmental Management Science

Program, Improving the Scientific Basis for Managing DOE's Excess Nuclear Materials and Spent Nuclear Fuel,

National Academies Press, Washington, DC, 2003. On the Web at

http://books.nap.edu/books/0309087228/html/index.html., p. 67 as quoted in Makhijani and Smith 2004/2005, pp. 7-

8.

23 SECY-08-0147 2008, Enclosure 1, p. 21. Emphasis in original.

24 SECY-08-0147 2008, Enclosure 1, pp. 8-9.

11

gram. If uranium were a transuranic element, it would require disposal in the 

Waste Isolation Pilot Plant (WIPP) based on its radioactivity. The chemical 

toxicity of this very large amount of material would certainly become a problem 

as well. One option suggested by the U.S. Nuclear Regulatory Commission 

(USNRC) is disposal in a mined cavity or former uranium mine. Challenges for 

this option would include understanding the fundamental differences between 

uranium ore (see Sidebar 6.1) and the bulk uranium oxide powder. 22 

The peak doses from DU disposal are expected to occur after thousands of years, hundreds of 

thousands of years, or even a million or more years, depending on the chemical form, disposal 

site characteristics, etc. Hence, the normal criteria of the NRC limiting performance evaluation 

to 10,000 years do not apply. 

The staffs position in SECY-08-0147 regarding the period of performance is ambiguous: 

Considering the technical aspects of the problem, the performance assessment 

staff recommends a performance period of 10,000 years for the analysis of DU 

disposal. However, analyses should be performed to peak impact, and if those 

impacts are significantly larger than the impacts realized within 10,000 years, 

then the longer term impacts should be included in the site environmental 

evaluation.23 

It is unclear from this whether or not the staff intends for the peak dose to meet Subpart C 

criteria or not. However, unless Subpart C is sought to be changed, the performance assessment 

must be carried to the time of peak dose and the dose criteria of 10 CFR 61.41, including organ 

dose, must be met. But it should be noted in this context that the NRC staff itself does not 

consider the analysis in SECY -08-147 to be conservative. 

Specifically, SECY-08-0147 and its Enclosure 1, states that the staff developed a "screening 

model" to do a "screening analysis" whose purpose "was to evaluate key variables such as 

disposal configurations (disposal depth and barriers), performance periods, institutional control 

periods, waste forms, site conditions, pathways, and scenarios. ,,24 

During the Bethesda, Maryland, workshop, I asked whether the term "screening" was being used 

to indicate a conservative analysis - that is, an analysis that would give an upper bound for the 

dose estimate, so that one could be reasonably assured that a more realistic analysis would yield 

a lower dose estimate. In other words, such a screening analysis would lead to an assurance that 

the conclusion thatDU could be disposed of in shallow land burial and meet specified 

performance criteria was robust. 

22 National Research Council, Board on Radioactive Waste Management, Committee on Improving the Scientific 

Basis for Managing Nuclear Materials and Spent Nuclear Fuel through the Environmental Management Science 

Program, Improving the Scientific Basis for Managing DOE's Excess Nuclear Materials and Spent Nuclear Fuel, 

National Academies Press, Washington, DC, 2003. On the Web at 

http://books.nap.edu/books/0309087228lhtml/index.html., p. 67 as quoted in Makhijani and Smith 2004/2005, pp. 7-

8. 

23 SECY -08-0147 2008, Enclosure 1, p. 2l. Emphasis in original. 

24 SECY-08-0147 2008, Enclosure 1, pp. 8-9. 

11 
Dr. Esh indicated that the term "screening analysis" was not used in that sense in the paper. He

agreed with the suggestion that the screening model in SECY-08-0147 "wasn't conservative.'" 25

Conclusion regarding period of performance: The conclusion from the above is that if the

NRC wishes to assess performance of disposal of DU in significant amounts according to

Subpart C, which contains no time limits, then a limit on the period of performance to

10,000 years is entirely inappropriate. The stated goal of the proposed rulemaking

exercise is to limit consideration of changes to 10 CFR 61.55(a). Therefore, a limitation on

the period of performance cannot be used for disposal of significant quantities of DU

within the context of the present rulemaking. An entirely new rulemaking proceeding

would be needed, since restricting performance evaluation to anything short of peak dose

in this case would be a de facto change in Subpart C.

One may conclude the following by examining the transcripts of the Bethesda, Maryland,

workshop (as well as the Salt Lake City workshop):

" Uncertainties become very large over periods as long as 10,000 to one million or more

years,

* Modeling shallow land burial over periods as long as a million years or more

quantitatively with some confidence appears infeasible, and

* The main radiological problems in dry areas, other than those that might be associated

with uncovering the waste, appear over the long term (thousands of years or more),

presuming the areas remain dry.

During the Bethesda, Maryland, workshop, there were several suggestions about restricting the

period of performance. One was to use the period now required for mill tailings (1,000 years);

another was to use the period required under 40 CFR 191 for deep geologic disposal, for instance

at the Waste Isolation Pilot Plant (10,000 years). However, none of these suggestions can be

legitimately considered under in the present rulemaking. If the NRC wants to consider limiting

the period of performance for significant amounts of DU, then it must start a new proceeding and

propose changes in Subpart C, along with the rationale for those changes.

The rationale for limiting the period of performance cannot be simply to protect the industry or

provide the industry with a way to get rid of DU from enrichment plants or even that it is

difficult to do a modeling exercise to the time of peak dose. Since it is the NRC's mandate to

protect public health, and since public health can be much better protected with appropriate deep

disposal similar to geologic disposal at WIPP, the NRC must first consider such deep disposal

before it considers any relaxation of Subpart C. This would also require a different rulemaking

from the one that the NRC is now embarked upon.

In the context of deep geologic disposal, where estimating performance can be done on a better

scientific foundation, the NRC might consider adopting the approach taken in the French highlevel waste rule. That rule recognizes that the uncertainties increase greatly beyond 10,000

25 NRC DU meeting transcript, September 2, 2009, p. 83.

12

Dr. Esh indicated that the term "screening analysis" was not used in that sense in the paper. He 

agreed with the suggestion that the screening model in SECY-08-0147 "wasn't conseryative.,,25 

Conclusion regarding period of performance: The conclusion from the above is that if the 

NRC wishes to assess performance of disposal of DU in significant amounts according to 

Subpart C, which contains no time limits, then a li~it on the period of performance to 

10,000 years is entirely inappropriate. The stated goal of the proposed rulemaking 

exercise is to limit consideration of changes to 10 CFR 61.55(a). Therefore, a limitation on 

the period of performance cannot be used for disposal of significant quantities of DU 

within the context of the present rulemaking. An entirely new rulemaking proceeding 

would be needed, since restricting performance evaluation to anything short of peak dose 

in this case would be a de facto change in Subpart C. 

One may conclude the following by examining the transcripts of the Bethesda, Maryland, 

workshop (as well as the Salt Lake City workshop): 

• Uncertainties become very large over periods as long as 10,000 to one million or more 

years, 

• Modeling shallow land burial over periods as long as a million years or more 

quantitatively with some confidence appears infeasible, and 

• The main radiological problems in dry areas, other than those that might be associated 

with uncovering the waste, appear over the long term (thousands of years or more), 

presuming the areas remain dry. 

During the Bethesda, Maryland, workshop, there were several suggestions about restricting the 

period of performance. One was to use the period now required for mill tailings (1,000 years); 

another was to use the period required under 40 CFR 191 for deep geologic disposal, for instance 

at the Waste Isolation Pilot Plant (10,000 years). However, none of these suggestions can be 

legitimately considered under in the present rulemaking. If the NRC wants to consider limiting 

the period of performance for significant amounts ofDU, then it must start a new proceeding and 

propose changes in Subpart C, along with the rationale for those changes. 

The rationale for limiting the period of performance cannot be simply to protect the industry or 

provide the industry with a way to get rid of DU from enrichment plants or even that it is 

difficult to do a modeling exercise to the time of peak dose. Since it is the NRC's mandate to 

protect public health, and since public health can be much better protected with appropriate deep 

disposal similar to geologic disposal at WIPP, the NRC must first consider such deep disposal 

before it considers any relaxation of Subpart C. This would also require a different rulemaking 

from the one that the NRC is now embarked upon. 

In the context of deep geologic disposal, where estimating performance can be done on a better 

scientific foundation, the NRC might consider adopting the approach taken in the French highlevel waste rule. That rule recognizes that the uncertainties increase greatly beyond 10,000 

25 NRC DU meeting transcript, September 2,2009, p. 83. 

12 
years. But instead of changing the dose performance standard, it changes the method by which

the modeling is done:

0 For up to 10,000 years, the uncertainties in the parameters are specified explicitly and

probability distributions are provided. This gives a realistic set of estimates of what the

performance would be, assuming the parameters are well characterized.

* Beyond 10,000 years the conservative, fixed values are used for parameters so as to

calculate an upper limit of the dose. The same dose reference number is maintained but

now we have what would be a bounding value for the long term, presuming the upper

bound parameters: climate, geological, and others can be specified in a scientifically

defensible way.

2 6

D. Some Other Matters

It is important to note that SECY-08-0147 did not analyze performance of above-ground

structures, such as those used at the EnergySolutions facility in Utah. Hence, any rule change

would not apply to disposal at that site, unless the NRC actually develops modeling approaches

for above ground structures for a million years. This would be an even more unrealistic task than

the one undertaken in SECY-08-0147 to estimate performance in below ground shallow disposal.

E. Other "Unique" Waste Forms

Like significant amounts of DU, there are several other waste streams that do not clearly fall into

the present structure of 10 CFR 61.55(a) as is recognized now by the NRC. These could include

significant amounts uranium recovered during reprocessing for instance. Such uranium is

typically contaminated with transuranic radionuclides and some fission products.

DU in large amounts is in many ways the best characterized and known of such potential waste

streams. There should be no consideration of other waste streams within the present proposed

rulemaking to revise 10 CFR 61.55(a)(6) and add a new para 10 CFR 61.55(a)(9).

F. The Rights of Agreement States

States that regulate civilian nuclear licensees under agreement with the NRC ("Agreement

States") are required to meet a complex set of "compatibility" requirements to ensure that NRC

requirements are being met. The regulation and enforcement is done at the state level in such

cases. But the NRC has the responsibility to ensure that there is compliance with applicable

federal regulations. The industry and state regulator sentiment is for the NRC to give the

26 Rgle N" 1I1.2.f (10 juin 1991) R~glesfondamentales de saretM relatives aux installations nuclaires de base

autres que reacteurs Tome III: production, contr6le et traitement des effluents et d~chets. Chapitre 2: D~chets

solides, on the Web at http://www.asn.fr/index.php/Les-actioins-de-l-ASN/La-reglementation/Reglementationassociee/Re ges-fondamen tales-de-surete-et-guides-de-I-ASN/RFS-III.2.f-abro gee-par-le-guide-de-surete-relatif-austockage-definitif-des-dechets-radioactifs-en- formation-geologique-pro fonde-du- 12.02.08.

13

years. But instead of changing the dose performance standard, it changes the method by which 

the modeling is done: 

• For up to 10,000 years, the uncertainties in the parameters are specified explicitly and 

probability distributions are provided. This gives a realistic set of estimates of what the 

performance would be, assuming the parameters are well characterized. 

• Beyond 10,000 years the conservative, fixed values are used for parameters so as to 

calculate an upper limit of the dose. The same dose reference number is maintained but 

now we have what would be a bounding value for the long term, presuming the upper 

bound parameters: climate, geological, and others can be specified in a scientifically . ~ . defensible way. 

D. Some Other Matters 

It is important to note that SECY -08-0147 did not analyze performance of above-ground 

structures, such as those used at the EnergySolutions facility in Utah. H~nce, any rule change 

would not apply to disposal at that site, unless the NRC actually develops modeling approaches 

for above ground structures for a million years. This would be an even more unrealistic task than 

the one undertaken in SECY -08-0147 to estimate performance in below ground shallow disposal. 

E. Other "Unique" Waste Forms 

Like significant amounts ofDU, there are several other waste streams that do not clearly fall into 

the present structure of 10 CFR 61.55(a) as is recognized now by the NRC. These could include 

significant amounts uranium recovered during reprocessing for instance. Such uranium is 

typically contaminated with transuranic radionuclides and some fission products. 

DU in large amounts is in many ways the best characterized and known of such potential waste 

streams. There should be no consideration of other waste streams within the present proposed 

rulemaking to revise 10 CFR 61.55(a)(6) and add a new para 10 CFR 61.55(a)(9). 

F. The Rights of Agreement St~tes 

States that regulate civilian nuclear licensees under agreement with the NRC ("Agreement 

States") are required to meet a complex set of "compatibility" requirements to ensure that NRC 

requirements are being met. The regulation and enforcement is done at the state level in such 

cases. But the NRC has the responsibility to ensure that there is compliance with applicable 

federal regulations. The industry and state regulator sentiment is for the NRC to give the 

26 RegIe N° III.2.f (10 juin 1991) Regles fondamentales de surete relatives aux installations nucleaires de base 

autres que reacteurs Tome 111: production, contr6le et traitement des e.ffiuents et dechets. Chapitre 2: Dechets 

solides, on the Web at hUp:llwww.asn.fr/index.php/Les-actions-de-l-ASN/La-reglementation/Reglementationassociee/Regles-fondamentales-de-surete-et-guides-de-1-ASN/RFS-IIl.2.f-abrogee-par-le-guide-de-surete-relatif-aus tockage-defini tif-des-dechets-radioacti t"s-en-formation -geo 10 gique-pro fonde-du-12. 02.08. . 

13 
maximum possible leeway to state authorities. States can generally set more conservative

standards than those at the federal level.

During the Bethesda, Maryland, workshop I expressed concerns as to whether there was

adequate oversight regarding the two sites that may, in the near future, dispose of DU from

enrichment plants - Utah (EnergySolutions site) and Texas (Waste Control Specialists (WCS)

site). Specifically, I raised the issue of whether the NRC was adequately exercising its oversight

responsibilities. I had raised the same issue during my testimony as an expert witness for the

intervenors in the National Enrichment Facility licensing case.

Specifically, I found that some of the results of the modeling done in a performance assessment

that underlies the EnergySolutions license contained physically impossible numbers. For

instance, more uranium-238 was proposed to be disposed of per gram of Utah soil than the

weight of the Earth. I was asked during the Bethesda, Maryland, workshop whether I was

comfortable with the State of Texas agreeing to a DU concentration limit for the WCS site. I

said that the last time I looked at the WCS issue, which was four years ago, I was not convinced

that WCS was even qualified to receive radioactive waste - since, among other things, their

license application at that time proposed to dispose of more U-235 as waste than had ever been

mined.27

If the NRC and the state of Utah has failed to require a correction of such evident scientific

problems, even though it has been formally put on the table, how could one be confident of the

process for licensing and enforcing DU disposal regulations? Neither has the NRC responded to

my comment regarding WCS during the workshop.

I also pointed out that IEER has done the only independent site specific analysis of DU disposal

by shallow land burial for the WCS site and of a site with parameters corresponding to the Utah

site. Our analysis had shown that doses would be exceeded at both sites by large margins in well

under one million years and in most cases on times scales on the order of 10,000 years. I was

told, informally, that NRC staff would look into the record of the LES proceeding. In response, I

told them I would supply the IEER LES reports to the staff. IEER has sent the URLs for the

reports to the moderator Chip Cameron.28

Expectation of IEER: We expect that before any draft rule is promulgated that the NRC will

respond specifically to the above problems in regard to WCS and EnergySolutions and also make

clear whether it intends to be more vigilant in regard to elementary matters of science when it

comes to oversight of agreement states.

27 See Makhijani and Smith 2005, for instance at p. 2 and p. 20.

28 Post-workshop note: IEER sent the URLs to the moderator Chip Cameron on September 21, 2009. These are also

cited in footnote 21, above.

14

maximum possible leeway to state authorities. States can generally set more conservative 

standards than those at the federal level. 

During the Bethesda, Maryland, workshop I expressed concerns as to whether there was 

adequate oversight regarding the two sites that may, in the near future, dispose of DU from 

enrichment plants - Utah (EnergySolutions site) and Texas (Waste Control Specialists (WCS) 

site). Specifically, I raised the issue of whether the NRC was adequately exercising its oversight 

responsibilities. I had raised the same issue during my testimony as an expert witness for the 

intervenors in the National Enrichment Facility licensing case. 

Specifically, I found that some of the results of the modeling done in a performance assessment 

that underlies the EnergySolutions license contained physically impossible numbers. For 

instance, more uranium-238 was proposed to be disposed of per gram of Utah soil than the 

weight of the Earth. I was asked during the Bethesda, Maryland, workshop whether I was 

comfortable with the State of Texas agreeing to a DU concentration limit for the WCS site. I 

said that the last time I looked at the WCS issue, which was four years ago, I was not convinced 

that WCS was even qualified to receive radioactive waste - since, among other things, their 

license application at that time proposed to dispose of more U-235 as waste than had ever been 

mined. 27 

If the NRC and the state of Utah has failed to require a correction of such evident scientific 

problems, even though it has been formally put on the table, how could one be confident of the 

process for licensing and enforcing DU disposal regulations? Neither has the NRC responded to 

my comment regarding WCS during the workshop. 

I also pointed out that IEER has done the only independent site specific analysis of DU disposal 

by shallow land burial for the WCS site and of a site with parameters corresponding to the Utah 

site. Our analysis had shown that doses would be exceeded at both sites by large margins in well 

under one million years and in most cases on times scales on the order of 10,000 years. I was 

told, informally, that NRC staff would look into the record of the LES proceeding. In response, I 

told them I would supply the IEER LES reports to the staff. IEER has sent the URLs for the 

reports to the moderator Chip Cameron. 28 

Expectation ofIEER: We expect that before any draft rule is promulgated that the NRC will 

respond specifically to the above problems in regard to WCS and EnergySolutions and also make 

clear whether it intends to be more vigilant in regard to elementary matters of science when it 

comes to oversight of agreement states. 

27 See Makhijani and Smith 2005, for instance at p. 2 and p. 20. 

28 Post-workshop note: IEER sent the URLs to the moderator Chip Cameron on September 21, 2009. These are also 

cited in footnote 21 , above. 

14 
G. Conclusions

The present rulemaking is based on the false premise that SECY-08-0147 has demonstrated the

feasibility of adequate performance relative to Subpart C of some shallow land disposal facilities.

SECY-08-0147 did not actually calculate performance relative to the most important requirement

of Subpart C - organ dose. It is also fundamentally flawed in its science and in its assumptions.

The suggestions as to limitation of period of performance are, given the NRC's own normal

criteria, entirely out of order in this proposed rulemaking.

The Federal Register Notice as well as the NRC instruction to the staff was to consider a very

limited change to the low-level waste rule. Specifically, the Commission directed the staff to

consider a revision of 10 CFR 61.55(a)(6) and to add a new paragraph 10 CFR 61.55(a)(9) that

would specify how a site specific analysis for depleted uranium (and possibly other "unique

waste streams") should be done. Associated guidance was also to be developed. The NRC did

not state that performance requirements specified in 10 CFR 61 Subpart C would be modified.

On the contrary, both the NRC and the NRC staff have represented that the intent is not to

modify Subpart C but to assess performance with respect to the requirements of Subpart C.

The analysis of SECY-08-0147 did not assess performance according to all the requirements of

Subpart C. Specifically, organ doses were not estimated. There were also explicit suggestions

that the period of performance for disposal of significant quantities of DU might be limited in

some way. This would also be a material change to Subpart C in the context of disposal of large

amounts of DU.

The proposed rulemaking cannot change Subpart C either explicitly or implicitly - for instance

by omitting organ dose calculations or limiting the period of performance. The NRC has not

provided any estimate of the changes in health damage that may be expected as a result of

changes in Subpart C. As a result, the public has been provided with no opportunity to comment

specifically on the changes that would be made to their protection of their health aspects as a

result of any explicit or implicit changes in Subpart C.

A change to Subpart C, where the core public health provisions of the low-level waste

regulations are specified, would be a major change to the regulation. The Atomic Energy Act

requires the NRC to have public health protection as one its primary purposes and it empowers

the NRC to take action accordingly. A change to Subpart C, which is central to the health

protections provided by the low-level waste rule, would therefore be a major federal action. It

would violate the Administrative Procedures Act if Subpart C were to be changed in the context

of the present proposed rulemaking, where no analysis for changing Subpart C has been

provided.

IEER therefore strongly recommends that:

" The present rulemaking be stopped.

" A new rulemaking that corresponds to Option 3 should be initiated for significant

amounts of DU.

15

G. Conclusions 

The present rulemaking is based on the false premise that SECY-08-0147 has demonstrated the 

feasibility of adequate performance relative to Subpart C of some shallow land disposal facilities. 

SECY -08-0147 did not actually calculate performance relative to the most important requirement 

of Subpart C - organ dose. It is also fundamentally flawed in its science and in its assumptions. 

The suggestions as to limitation of period of performance are, given the NRC's own normal 

criteria, entirely out of order in this proposed rulemaking. 

The Federal Register Notice as well as the NRC instruction to the staff was to consider a very 

limited change to the low-level waste rule. Specifically, the Commission directed the staff to 

consider a revision of 10 CFR 61.55(a)(6) and to add a new paragraph 10 CFR 61.55(a)(9) that 

would specify how a site specific analysis for depleted uranium (and possibly other "unique 

waste streams") should be done. Associated guidance was also to be developed. The NRC did 

not state that performance requirements specified in 10 CFR 61 Subpart C would be modified. 

On the contrary, both the NRC and the NRC staff have represented that the intent is not to 

modify Subpart C but to assess performance with respect to the requirements of Subpart C. 

The analysis of SECY -08-0147 did not assess performance according to all the requirements of 

Subpart C. Specifically, organ doses were not estimated. There were also explicit suggestions 

that the period of performance for disposal of significant quantities of DU might be limited in 

some way. This would also be a material change to Subpart C in the context of disposal oflarge 

amounts of DU. 

The proposed rulemaking cannot change Subpart C either explicitly or implicitly - for instance 

by omitting organ dose calculations or limiting the period of performance. The NRC has not 

provided any estimate of the changes in health damage that may be expected as a result of 

changes in Subpart C. As a result, the public has been provided with no opportunity to comment 

specifically on the changes that would be made to their protection of their health aspects as a 

result of any explicit or implicit changes in Subpart C. 

A change to Subpart C, where the core public health provisions of the low-level waste 

regulations are specified, would be a major change to the regulation. The Atomic Energy Act 

requires the NRC to have public health protection as one its primary purposes and it empowers 

the NRC to take action accordingly. A change to Subpart C, which is central to the health 

protections provided by the low-level waste rule, would therefore be a major federal action. It 

would violate the Administrative Procedures Act if Subpart C were to be changed in the context 

of the present proposed rulemaking, where no analysis for changing Subpart C has been 

provided .. 

lEER therefore strongly recommends that: 

• The present rulemaking be stopped. 

• A new rulemaking that corresponds to Option 3 should be initiated for significant 

amounts of DU. 

15 
* The possibility that DU will fall into the Greater than Class C category of low level waste

should be explicitly included.

" The option of deep geologic disposal should be considered - indeed, given the text of the

low-level waste rule as it now stands, this would the normal mode of disposal of

significant amounts of DU.

* Performance standards as set forth in Subpart C should be maintained.

* There should be no limit on the period of performance.

• A change in the method by which performance is evaluated could be considered along the

lines that are specified in the French high-level waste rule cited above.

• The NRC should ensure that sound and defensible scientific assumptions, methods, and

analytical tools are used and that input data represent conditions that might reasonably be

expected, or that would put an upper limit to dose calculations.

* The NRC should exercise more oversight over agreement states to ensure that the

methods, data, conclusions, analyses, computer models, and parameter values meet at

least minimal tests of scientific soundness.

16

• The possibility that DU will fall into the Greater than Class C category of low level waste 

should be explicitly included. 

• The option of deep geologic disposal should be considered - indeed, given the text of the 

low-level waste rule as it now stands, this would the normal mode of disposal of 

significant amounts of DU 

.• Performance standards as set forth in Subpart C should be maintained. 

• There should be no limit on the period of performance. 

• A change in the method by which performance is evaluated could be considered along the 

lines that are specified in the French high-level waste rule cited above. 

• The NRC should ensure that sound and defensible scientific assumptions, methods, and 

analytical tools are used and that input data represent conditions that might reasonably be 

expected, or that would put an upper limit to dose calculations. 

• The NRC should exercise more oversight over agreement states to ensure that the 

methods, data, conclusions, analyses, computer models, and parameter values meet at 

least minimal tests of scientific soundness. 

16 
Page 1 of 1

7q FB.3o/73

PUBLIC SUB ISSI0

As of: November 05, 2009

Received: October 30, 2009

Status: PendingPost

Tracking No. 80a4dc96

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0019

Comment on FR Doc # E9-14820 6

_.L_.J

Submitter Information

Name: Stephen Nelson

Address:

Dept. of Geological Sciences

S-389 ESC

Provo, UT, 84602

Organization: Brigham Young University

-M

`5)

General Comment

Please see attached file.

Attachments

NRC-2009-0257-DRAFT-0019.1: Comment on FR Doc # E9-14820

s~it+31Akole' -6/3lec

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pa .'Lsr~~ C-j5£

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7Jf Rl3D/7S 

(p /cJ. if ) () 9 

@ As of: November OS, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC S BMISSION Tracking No. 80a4dc96 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0019 

Comment on FR Doc # E9-14820 

( 

\ 

-_,l.J 

Submitter Information 

Name: Stephen Nelson 

Address: 

Dept. of Geological Sciences 

S-389 ESC 

Provo, UT, 84602 

Organization: Brigham Young University 

~i~1 

<-.J 

I ... 'c 

General Comment 

Please see attached file. 

Attachments 

NRC-2009-0257-DRAFT-0019.1: Comment on FR Doc # E9-14820 

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October 30, 2009

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Stop TWB 5B01M

Washington D.C. 20555-001

Submitted online via: http://vvwww.regulations.gov

Re: NRC-2009-0257; Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of

Unique Waste Streams Including Significant Quantities of Depleted Uranium; Federal Register, Vol.

74, No. 120, June 24, 2009, p. 30,175-30,179.

Dear NRC Staff and Committee:

Introduction

We submit the following comments in order to facilitate consideration of factors that must be

taken into account when determining whether depleted uranium (DU) can be disposed of safely in shallow

engineered landfills in general, and at the EnergySolutions Utah site in particular. A brief biographical

sketch of each signatory is attached to this letter so that you will be familiar with our qualifications.

To begin, contextual commentary regarding the length of the performance period for DU disposal

is provided, and we return to this issue in a subsequent section of this letter. In order to maintain

environmental protection, the performance period required for a site-specific analysis for DU and its decay

products should extend to the time of peak dose or 1,000,000 years, whichever comes first. This is both

based upon common sense and consistency with other regulatory programs for nuclear waste. Our view is

partially consistent with the paper on depleted uranium prepared by NRC staff last year, which reads in

part:

"Considering the technical aspects of the problem, the performance assessment staff

recommends a performance period of 10,000 years for the analysis ofDU disposal.

However, analyses should be performed to peak impact, and if those impacts are

significantly larger than the impacts realized within 10,000 years, then the longer term

impacts should be included in the site environmental evaluation. "

A simpler philosophy, and one that is more consistent with parallel regulatory programs is that the

performance period should be long enough to include the time of peak dose.

We take issue, however, with another conclusion from the NRC paper:

"Potentially high doses relative to the performance objectives could occur within a

timeframe longer than 10, 000 years from the disposal of large quantities ofD U.

However, the majority of sites, waste forms, and disposal configurations that can meet

the performance objectives at 10, 000 years will continue to meet the performance

objectives at longer time periods. A simple approach that should be considered to ensure

the eventual risk of radon is managed to select a waste disposal depth and cover

thickness based on the projected peak in-growth of the daughter species, rather than

the in-growth over the performance period. [emphasis added]"

Our discomfort with this statement arises from the fact that virtually no shallow engineered

disposal system can be envisaged to persist, intact, for periods of up to 1,000,000 years, the timeframe of

peak doses. NRC's statement appears to make the implicit assumption that climate and tectonic factors will

remain static over these time frames. With respect to climate and attendant consequences to landforms by

erosion and deposition, enough is known about natural climate variation that this assumption is false

everywhere at the earth's surface. NRC's assertion is simply wrong for any shallow, engineered site.

October 30,2009 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Stop TWB 5BO 1 M 

Washington D.C. 20555-001 

Submitted online via: httpj/www.regulations.gov 

Re: NRC-2009-0257; Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of 

Unique Waste Streams Including Significant Quantities of Depleted Uranium; Federal Register, Vol. 

74, No. 120, June 24, 2009, p. 30,175-30,179. 

Dear NRC Staff and Committee: 

Introduction 

We submit the following comments in order to facilitate consideration of factors that must be 

taken into account when determining whether depleted uranium (DU) can be disposed of safely in shallow 

engineered landfills in general, and at the EnergySolutions Utah site in particular. A brief biographical 

sketch of each signatory is attached to this letter so that you will be familiar with our qualifications. 

To begin, contextual commentary regarding the length of the performance period for DU disposal 

is provided, and we return to this issue in a subsequent section of this letter. In order to maintain 

environmental protection, the performance period required for a site-specific analysis for DU and its decay 

products should extend to the time of peak dose or 1,000,000 years, whichever comes first. This is both 

based upon common sense and consistency with other regulatory programs for nuclear waste. Our view is 

partially consistent with the paper on depleted uranium prepared by NRC staff last year, which reads in 

part: 

"Considering the technical aspects of the problem, the performance assessment staff 

recommends a performance period of 1 0, 000 years for the analysis of DU disposal. 

However, analyses should be performed to peak impact. and if those impacts are 

significantly larger than the impacts realized within la, 000 years, then the longer term 

impacts should be included in the site environmental evaluation. " 

A simpler philosophy, and one that is more consistent with parallel regulatory programs is that the 

performance period should be long enough to include the time of peak dose. 

We take issue, however, with another conclusion from the NRC paper: 

"Potentially high doses relative to the performance objectives could occur within a 

timeframe longer than 10,000 years from the disposal of large quantities of DU. . 

However, the majority of sites, waste forms, and disposal configurations that can meet 

the performance objectives at la, 000 years will continue to meet the performance 

objectives at longer time periods. A simple approach that should be considered to ensure 

the eventual risk of radon is managed to select a waste disposal depth and cover 

thickness based on the projected peak in-growth of the daughter species, rather than 

the in-growth over the performance period. [emphasis added/" 

Our discomfort with this statement arises from the fact that virtually no shallow engineered 

disposal system can be envisaged to persist, intact, for periods of up to 1,000,000 years, the timeframe of 

peak doses. NRC's statement appears to make the implicit assumption that climate and tectonic factors will 

remain static over these time frames. With respect to climate and attendant consequences to landforms by 

erosion and deposition, enough is known about natural climate variation that this assumption is false 

everywhere at the earth's surface. NRC's assertion is simply wrong for any shallow, engineered site. 
In this letter, we discuss just one aspect of climate change for the EnergySolutions Utah disposal

site that makes it inappropriate for DU disposal. As experienced earth scientists with wide-ranging

expertise, we believe that rising lake levels associated with glacial and even inter-glacial climate change

will likely lead to eventual inundation and wholesale erosion of the EnergySolutions Utah disposal facility.

Any modeling that does not take into account well-understood geological and climatologic

patterns displayed in the Lake Bonneville basin will grossly under- and mis-estimate the long-term hazards

of exposure from DU and its decay products. Clearly, we believe that any new rule and any associated

guidance related to site-specific analysis of DU should require modeling that includes climatic variation,

out to the time of peak dose. If that is done for the EnergySolutions site in particular, we are led back to

one inevitable conclusion: Over the relevant time frames for DU disposal, the probability that the Clive

site will be flooded approaches 100%. Given that near-certainty, we believe that a proper site-specific

analysis will also inevitably conclude that the EnergySolutions site is not appropriate or safe for DU

disposal.

The remainder of this letter is organized as follows. For context, we review the nature of depleted

uranium (DU) in comparison to "conventional" low-level waste (LLW). This is followed by additional

discussion of the appropriate regulatoryphilosophy, and then by more consideration of the suitability (or

lack thereof) of engineered landfills to accept and isolate DU, and the EnergySolutions Clive facility in

particular. Included in the discussion of the Clive facility are site- and region-specific analyses of the

geology and forward models of lake-level perturbations and erosion related to climate change.

Nature ofDU

Although you are aware of the nature of DU, there are three properties that we wish to reemphasize for context. First, DU has an extremely long half-life (4.5 x 109 yr) such that it effectively lasts

"forever." Second, as it evolves back toward secular equilibrium with its progeny, it becomes many times

more radioactive and at the time of emplacement its activity exceeds that of Class A waste . Such material

will emit alpha, beta, and gamma radiation. Third, the daughter products have geochemical properties that

are, in many instances, greatly divergent from that of 1

38U. Since each of the daughters will eventually

acquire an activity equal to that of the 238U parent, it is just as important to understand the site-specific

geochemical behavior of each daughter radionuclide as it is to understand the behavior of U. In fact, the

geochemical behavior of 234Th and 234Pa must be understood at the time of emplacement . And as we are

sure you are aware, U itself can be quite mobile in aqueous solutions, especially those with an elevated Eh

(U6+) and high carbonate content. As discussed below, future natural climate variation will almost certainly

inundate the Clive, Utah site with waters that may very well exhibit these characteristics.

Applicable Regulatory Philosophy

The typical control period for LLW is a few to several hundred years, depending upon its nature.

Clearly, the philosophy is to provide reasonable assurance of isolation from the environment by in situ

decay until the radiological hazard has largely passed. The Clive site was developed for these types of

materials, not DU.

In the high-level waste (HLW) arena, you are aware that the US EPA sets performance standards.

Congress charged the EPA with the adoption of a dose-based standard and further directed the EPA to

consider guidance by the National Academy of Sciences (NAS) in developing its rule (40CFR197). EPA

had set a compliance period of 10,000 years. We trust that you are aware that a competent Federal Court set

aside the EPA rule in 2004 for failure on the part of EPA to adhere to NAS recommendations that the

compliance period extend to 1,000, 000 years or until peak doses occurred. The rule was remanded back to

the EPA. A final rule, presumably consistent with NAS recommendations 2

, was adopted in Oct. 2008.

Using long-lived alpha enhitting transuranic nuclides a,.s' a yardstick, pure mnetallic DiU) would exceed

linmits in Table 1 of IOCFR61, 55 at the tine of enplacemnent, "Dilution" with ox3gen in oxide./brns places

DU only modestly below the limit. However, it is easily shown that within a year of processing; the rapid

ingrowth of"•34Th and "

34Pa result in DU having three times the activity it had when processed.

2 We presume the rule is consistent with NAS guidance, not because o/the content ojfthe rule, but because

as/far as we are aware it has not been challenged.

In this letter, we discuss just one aspect of climate change for the EnergySolutions Utah disposal 

site that makes it inappropriate for DU disposal. As experienced earth scientists with wide-ranging 

expertise, we believe that rising lake levels associated with glacial and even inter-glacial climate change 

will likely lead to eventual inundation and wholesale erosion of the EnergySolutions Utah disposal facility. 

Any modeling that does not take into account well-understood geological and climatologic 

patterns displayed in the Lake Bonneville basin will grossly under- and mis-estimate the long-term hazards 

of exposure from DU and its decay products. Clearly, we believe that any new rule and any associated 

guidance related to site-specific analysis of DU should require modeling that includes climatic variation, 

out to the time of peak dose. If that is done for the EnergySolutions site in particular, we are led back to 

one inevitable conclusion: Over the relevant time frames for DU disposal, the probability that the Clive 

site will be flooded approaches 100%. Given that near-certainty, we believe that a proper site-specific 

analysis will also inevitably conclude that the EnergySolutions site is not appropriate or safe for DU 

disposal. 

The remainder of this letter is organized as follows. For context, we review the nature of depleted 

uranium (DU) in comparison to "conventional" low-level waste (LLW). This is followed by additional 

discussion of the appropriate regulatory philosophy, and then by more consideration of the suitability (or 

lack thereof) of engineered landfills to accept and isolate DU, and the EnergySolutions Clive facility in 

particular. Included in the discussion of the Clive facility are site- and region-specific analyses of the 

geology and forward models of lake-level perturbations and erosion related to climate change. 

NatureofDU 

Although you are aware of the nature ofDU, there are three properties that we wish to reemphasize for context. First, DU has an extremely long half-life (4.5 x 109 yr) such that it effectively lasts 

"forever." Second, as it evolves back toward secular equilibrium with its progeny, it becomes many times 

more radioactive and at the time of emplacement its activity exceeds that of Class A waste 1. Such material 

will emit alpha, beta, and gamma radiation. Third, the daughter products have geochemical properties that 

are, in many instances, greatly divergent from that of238U. Since each of the daughters will eventually 

acquire an activity equal to that of the 238U parent, it is just as important to understand the site-specific 

geochemical behavior of each daughter radio nuclide as it is to understand the behavior ofU. In fact, the 

geochemical behavior of 234Th and 234Pa must be understood at the time of emplacement 1. And as we are 

sure you are aware, U itself can be quite mobile in aqueous solutions, especially those with an elevated Eh 

(U6+) and high carbonate content. As discussed below, future natural climate variation will almost certainly 

inundate the Clive, Utah site with waters that may very well exhibit these characteristics. 

Applicable Regulatory Philosophy 

The typical control period for LL W is a few to several hundred years, depending upon its nature. 

Clearly, the philosophy is to provide reasonable assurance of isolation from the environment by in situ 

decay until the radiological hazard has largely passed. The Clive site was developed for these types of 

materials, not DU. 

In the high-level waste (HLW) arena, you are aware that the US EPA sets performance standards. 

Congress charged the EPA with the adoption ofa dose-based standard and further directed the EPA to 

consider guidance by the National Academy of Sciences (NAS) in developing its rule (40CFR197). EPA 

had set a compliance period of 10,000 years. We trust that you are aware that a competent Federal Court set 

aside the EPA rule in 2004 for failure on the part of EPA to adhere to NAS recommendations that the 

compliance period extend to 1, 000, 000 years or until peak doses occurred. The rule was remanded back to 

the EPA. A final rule, presumably consistent with NAS recommendations", was adopted in Oct. 2008. 

J Usillg long-lived alpha emittillg trallsuranic nuclides as (/ yurdl'tick, pitre metallic DU would exceed 

limits in Table 1 0/ f OCFR61. 55 at the time o(emplucement. "Dilulion" with (Hygen ill oxideforms places 

DU only modestl)' below the limit. However, it is easily shown that within a year o/processing. the mpid 

ingrowth o/J34Th and 234Pa result in DU having three times the activity it had when processed. 

2 We presume lite rule is cOl/sistell! Ivith NAS guidance, nOi because ()/the content o/the rule, but because 

as/ar as we are aware it has not beel/ challenged. 
Thus, the overarching regulatory philosophy must be that control of radioactive wastes is

maintained until the radiological hazard has largely passed, regardless of the timescale or the nature of the

waste. The NAS accepted that 1,000,000 years might be an appropriate upper temporal limit for HLW

where Qeo loic disposal is required because of the inherent long-lived nature of spent fuel and military

wastes.

We cannot overemphasize the difference between engineered disposal (e.g., LLW) and geologic

disposal (e.g., HLW). Geologic disposal contains the inherent recognition that the nature of the hazard is

sufficiently long-lived that natural barriers are required to mitigate risks. Engineered solutions (i.e.,

landfills) alone are inadequate. DU is, by its very nature, the longest of the long-lived waste streams and

after a few tens of thousands of years (let alone at the time of emplacement) it is hardly benign. Regulatory

philosophy and common sense demand geologic disposal. DU, at face value, is entirely inconsistent with

disposal in any shallow, engineered landfill,

The NRC must resist the environmental narcissism (i.e., "I won't be around when it becomes a

problem") evidenced by entertaining the notion of DU disposal in a shallow landfill. All classification

issues of DU aside, disposal in engineered landfills is simply wrong.

Suitability of Shallow Engineered Disposal

The nature of DU combined with existing regulatory philosophy should foreclose shallow,

engineered disposal on its face. That said, we wish to provide site-specific evidence of the unsuitability of

the EnergySolutions Clive, Utah facility for proposed and existing DU disposal.

Effects of Past Climate Variation: Figure 1 shows the approximate location of the Clive facility,

well within the Bonneville basin. Clive was under water during the entire existence of Lake Bonneville, a

time period extending from approximately 31,000 until 11,500 years ago. Although the Clive site is

approximately 25 meters above the current elevation of the Great Salt Lake, it is about 60 meters below the

lowest of the 3 major still stands of Lake Bonneville. Figure 2 illustrates some of the shoreline features that

developed in response to that lake.

Although the extent, depth and history of Lake Bonneville are well understood, the detailed

histories of the lakes that preceded it are not as well documented due to a paucity of well-dated, wellstudied, and well-preserved lake cores. Such lakes are known to have existed, however. Oviatt et al. (1999)

proposed there were four deep lakes in the Bonneville basin during the last 780,000 years, whereas Eardley

et al. (1973) suggested there may have been 17 deep lake cycles over that time interval. Whether there

were 4 or 17 deep lakes is not particularly important. Both studies illustrate that based on the past, future

repeated flooding of Clive is inevitable.

Link et al. (1999) noted that ".. the permanent addition of Bear River water to Lake Bonneville

likely occurred 50 ± 10 ka (Bouchard et al., 1998), increasing the total discharge into the Bonneville basin

by -33%. This addition, coupled with cool, moist conditions during late Wisconsin time, is generally

thought to have been responsible for the lake reaching its all-time high during the last (Bonneville) lake

cycle (Bright, 1963; McCoy, 1987, Bouchard et al., 1998). "

It is important to understand the consequences of the piracy of the Bear River into the Bonneville

basin. Increasing the catchment area without changing the size of the basin may ampli' lake level

responses to climate change. Since this event occurred late in the 780,000 year record discussed by Eardley

et al. (1973) and Oviatt et al. (1999), past studies of the Bonneville basin may, in fact, under-predict future

lake-level fluctuations.

At the Clive locality in particular, inspection of an' excavation near the EnergySolutions site by

one of us (Oviatt) in the 1980s revealed that Bonneville clays are underlain by oolitic sands approximately

3 m thick. The implication of this observation is clear. Prior to the expansion of Lake Bonneville the Clive

site was submerged by shallow water for an extended period of time in order to permit the formation of

these deposits.

Owens Lake, CA, is a relevant proxy for climate change in the Great Basin. Owens Lake

periodically filled expanded portions of the Owens Valley on the eastern slope of the Sierra Nevada. In

fact, due to climate variation, Bischoff et al. (1997) suggested that there were seven distinct episodes over

the last 500,000 years (Fig. 3) during which Owens Lake levels rose such that it spilled out of its basin into

China Lake, Panamint Valley, and into Death Valley. The timeframe is entirely consistent with 40CFR197

and the period of interest surrounding DU. Bischoff et al. (1997) further suggested that the lake was large

and deep enough to spill out of the Owens Valley 34% of the time, or 170,000 of the last 500,000 years. To

Thus, the overarching regulatory philosophy must be that control of radioactive wastes is 

maintained until the radiological hazard has largely passed. regardless ofthe timescale or the nature ofthe 

waste. The NAS accepted that 1,000,000 years might be an appropriate upper temporal limit for HL W 

where geologic disposal is required because of the inherent long-lived nature of spent fuel and military 

wastes. 

We cannot overemphasize the difference between engineered disposal (e.g., LLW) and geologic 

disposal (e.g., HLW). Geologic disposal contains the inherent recognition that the nature of the hazard is 

sufficiently long-lived that natural barriers are required to mitigate risks. Engineered solutions (i.e., 

landfills) alone are inadequate. DU is, by its very nature, the longest of the long-lived waste streams and 

after a few tens of thousands of years (let alone at the time of emplacement) it is hardly benign. Regulatory 

philosophy and common sense demand geologic disposal. DU, at face value, is entirely inconsistent with 

disposal in any shallow, engineered landfilL 

The NRC must resist the environmental narcissism (i.e., "I won't be around when it becomes a 

problem") evidenced by entertaining the notion of DU disposal in a shallow landfill. All classification 

issues of DU aside, disposal in engineered landfills is simply wrong. 

Suitability of Shallow Engineered Disposal 

The nature of DU combined with existing regulatory philosophy should foreclose shallow, 

engineered disposal on its face. That said, we wish to provide site-specific evidence of the unsuitability of 

the EnergySolutions Clive, Utah facility for proposed and existing DU disposal. 

Effects of Past Climate Variation: Figure 1 shows the approximate location of the Clive facility, 

well within the Bonneville basin. Clive was under water during the entire existence of Lake Bonneville, a 

time period extending from approximately 31,000 until 11,500 years ago. Although the Clive site is 

approximately 25 meters above the current elevation of the Great Salt Lake, it is about 60 meters below the 

lowest of the 3 major still stands of Lake Bonneville. Figure 2 illustrates some of the shoreline features that 

developed in response to that lake. 

Although the extent, depth and history of Lake Bonneville are well understood, the detailed 

histories of the lakes that preceded it are not as well documented due to a paucity of well-dated, wellstudied, and well-preserved lake cores. Such lakes are known to have existed, however. Oviatt et al. (1999) 

proposed there were four deep lakes in the Bonneville basin during the last 780,000 years, whereas Eardley 

et al. (1973) suggested there may have been 17 deep lake cycles over that time interval. Whether there 

were 4 or 17 deep lakes is not particularly important. Both studies illustrate that based on the past, future 

repeated flooding of Clive is inevitable. 

Link et al. (1999) noted that " ... the permanent addition of Bear River water to Lake Bonneville 

likely occurred 50 ± 10 ka (Bouchard et aI., 1998), increasing the total discharge into the Bonneville basin 

by -33%. This addition, coupled with cool, moist conditions during late Wisconsin time, is generally 

thought to have been responsible for the lake reaching its all-time high during the last (Bonneville) lake 

cycle (Bright, 1963; McCoy, 1987; Bouchard et aI., 1998)." 

It is important to understand the consequences of the piracy of the Bear River into the Bonneville 

basin. Increasing the catchment area without changing the size of the basin may amplify lake level 

responses to climate change. Since this event occurred late in the 780,000 year record discussed by Eardley 

et al. (1973) and Oviatt et al. (1999), past studies of the Bonneville basin may, in fact, under-predict future 

lake-level fluctuations. 

At the Clive locality in particular, inspection of an excavation near the EnergySolutions site by 

one of us (Oviatt) in the 1980s revealed that Bonneville clays are underlain by oolitic sands approximately 

3 m thick. The implication of this observation is clear. Prior to the expansion of Lake Bonneville the Clive 

site was submerged by shallow water for an extended period of time in order to permit the formation of 

these deposits. 

Owens Lake, CA, is a relevant proxy for climate change in the Great Basin. Owens Lake 

periodically filled expanded portions of the Owens Valley on the eastern slope of the Sierra Nevada. In 

fact, due to climate variation, Bischoff et al. (1997) suggested that there were seven distinct episodes over 

the last 500,000 years (Fig. 3) during which Owens Lake levels rose such that it spilled out of its basin into 

China Lake, Panamint Valley, and into Death Valley. The timeframe is entirely consistent with 40CFR 197 

and the period of interest surrounding DU. Bischoffet al. (1997) further suggested that the lake was large 

and deep enough to spill out of the Owens Valley 34% of the time, or 170,000 of the last 500,000 years. To 
a first approximation, natural climate variation may have produced similar cyclical inundations of the Clive

site.

As mentioned above, the elevation of Clive is significantly below that of the lowest of the three

major still stands of Lake Bonneville, so it seems likely that flooding might occur at the Clive site in

response to relatively small climate changes. In fact, the low elevation of the Clive site guarantees

inundation with a much greater frequency than the complete filling of the Bonneville basin to its spill point

into the Snake River drainage.

Effects of Future Climate Variation. The cycles of rising and falling lakes in the enclosed

topographic basins of the Great Basin will continue in the future. We can reasonably expect several lake

cycles to inundate the Clive site over the next 500,000 years due to natural climate variation, and we can

hardly imagine that anyone would consider the return of a pluvial lake to the Clive site to be consistent with

waste isolation .

We suspect that that there would be nearly complete unanimity that expanded lakes will return in

the future in response to climate variation if you polled geologists, geographers, and paleo-climatologists

working in or familiar with the Bonneville basin. Even worse, large climate changes may not be requisite

to flood the site. For example, the elevation of the Great Salt Lake has varied by six meters just since 1873

(Tarboton, 2006).

Changes in climate required to increase the level of the Great Salt Lake to that of Clive are

extremely small when compared to current understanding of natural climate variability over the Holocene

Epoch and the last full glacial cycle. We have conducted simple forward models of lake elevation changes.

All else being equal, precipitation only has to increase -3-6 mm/yr for 1000 years to raise the level of the

Great Salt Lake to that of Clive.

Mean lake level does not have to reach Clive in order to cause problems. Given reasonable

interannual variability in climate, the mean lake level only has to reach 15-20 m above modem day Great

Salt Lake. At this level, it is highly probable that the variability about mean lake level will drown Clive for

several hundred years out of every 5,000-10,000 years (see amplitude of variability in Fig. 4). The mean

shift in precipitation required to achieve this is well within reasonable natural or anthropogenic changes in

the climate system. Exposure to shoreline erosion over a few hundred years can conservatively erode

several meters of bedrock (Fig. 5). Engineered disposal cells above grade can hardly be expected to resist

erosion in a large lake with large fetch.

The implications for the Clive site are clear. Clive has been inundated repeatedly in the past.

Clive will be inundated in the future, and the mean changes in climate required to flood and destroy the

emplacement piles are small. We estimate that the probability of the EnergySolutions site being flooded in

the next 100,000 years is close to 100%. Sandquist (2009) maintains that there are 330 tons of natural

uranium currently in the 1700 mi 2 Great Salt Lake. The Clive site, by contrast, could release on the order

of 1,000,000 tons of DU from a landfill with a 2 mi 2 footprint.

The consequences in the vicinity of Salt Lake City for lake level rise to the elevation of the Clive

site (1305 m) are illustrated in Figure 6. Much of what is now the northwestern part of the valley will be

below water, including downtown Salt Lake City. However, what may be more important are the areas that

are not flooded. Large areas will remain habitable. No one can predict what the state of society will be

when the lake returns to this elevation, but there is every expectation that humans will be inhabiting large

portions of the Salt Lake Valley and perhaps relying on lake resources. The almost certain release of

hundreds of thousands of tons of DU into their future environment can be foreseen today.

Summary

DU is, at face value, an inappropriate waste stream for any shallow, engineered disposal site. Its

very nature requires geologic disposal. Shallow disposal simply does not pass the "laugh test." We suggest

that a model exists for proper DU disposal. The operational WIPP site for transuranic waste illustrates that

the geological, geochemical, and engineering knowledge needed for safe DU disposal is already mature.

Specifically, the Clive facility could be an appropriate site for the disposal of "conventional" LLW

from a purely technical perspective. A control period of a few hundred years for Class A LLW can

' There is also considerable irony in the f.act that the lacustrine clays [marls, reallvjfrom which ce//s are

constructed at the Cl/e site, combined with underlving oolitic sands, are primaiv evidence ofits

unsuitability./br DU disposal because they are direct evidence o(#past inundation.

a first approximation, natural climate variation may have produced similar cyclical inundations of the Clive 

site. 

As mentioned above, the elevation of Clive is significantly below that of the lowest of the three 

major still stands of Lake Bonneville, so it seems likely that flooding might occur at the Clive site in 

response to relatively small climate changes. In fact, the low elevation of the Clive site guarantees 

inundation with a much greater frequency than the complete filling of the Bonneville basin to its spill point 

into the Snake River drainage. 

Effects of Future Climate Variation: The cycles of rising and falling lakes in the enclosed 

topographic basins of the Great Basin will continue in the future. We can reasonably expect several lake 

cycles to inundate the Clive site over the next 500,000 years due to natural climate variation, and we can 

hardly imagine that anyone would consider the return of a pluvial lake to the Clive site to be consistent with 

waste isolation). 

We suspect that that there would be nearly complete unanimity that expanded lakes will return in 

the future in response to climate variation if you polled geologists, geographers, and paleo-climatologists 

working in or familiar with the Bonneville basin. Even worse, large climate changes may not be requisite 

to flood the site. For example, the elevation of the Great Salt Lake has varied by six meters just since 1873 

(Tarboton, 2006). 

Changes in climate required to increase the level of the Great Salt Lake to that of Clive are 

extremely small when compared to current understanding of natural climate variability over the Holocene 

Epoch and the last full glacial cycle. We have conducted simple forward models of lake elevation changes. 

All else being equal, precipitation only has to increase ~3-6 mm/yr for 1000 years to raise the level of the 

Great Salt Lake to that of Clive. 

Mean lake level does not have to reach Clive in order to cause problems. Given reasonable 

interannual variability in climate, the mean lake level only has to reach 15-20 m above modem day Great 

Salt Lake. At this level, it is highly probable that the variability about mean lake level will drown Clive for 

several hundred years out of every 5,000-10,000 years (see amplitude of variability in Fig. 4). The mean 

shift in precipitation required to achieve this is well within reasonable natural or anthropogenic changes in 

the climate system. Exposure to shoreline erosion over a few hundred years can conservatively erode 

several meters of bedrock (Fig. 5). Engineered disposal cells above grade can hardly be expected to resist 

erosion in a large lake with large fetch. 

The implications for the Clive site are clear. Clive has been inundated repeatedly in the past. 

Clive will be inundated in the future, and the mean changes in climate required to flood and destroy the 

emplacement piles are small. We estimate that the probability of the EnergySolutions site being flooded in 

the next 100,000 years is close to 100%. Sandquist (2009) maintains that there are 330 tons of natural 

uranium currently in the 1700 mi2 Great Salt Lake. The Clive site, by contrast, could release on the order 

of 1,000,000 tons of DU from a landfill with a V:z mi2 footprint. 

The consequences in the vicinity of Salt Lake City for lake level rise to the elevation of the Clive 

site (1305 m) are illustrated in Figure 6. Much of what is now the northwestern part of the valley will be 

below water, including downtown Salt Lake City. However, what may be more important are the areas that 

are not flooded. Large areas will remain habitable. No one can predict what the state of society will be 

when the lake returns to this elevation, but there is every expectation that humans will be inhabiting large 

portions of the Salt Lake Valley and perhaps relying ori lake resources. The almost certain release of 

hundreds of thousands of tons ofDU into their future environment can be foreseen today. 

Summary 

DU is, at face value, an inappropriate waste stream for any shallow, engineered disposal site. Its 

very nature requires geologic disposal. Shallow disposal simply does not pass the "laugh test." We suggest 

that a model exists for proper DU disposal. The operational WIPP site for transuranic waste illustrates that 

the geological, geochemical, and engineering knowledge needed for safe DU disposal is already mature. 

Specifically, the Clive facility could be an appropriate site for the disposal of "conventional" LL W 

from a purely technical perspective. A control period of a few hundred years for Class A LL W can 

3 There is also considerable iron)' in the/act That the lacustrine clavs [mar/s, real(vJfrom which cells are 

constmcted at the Clive site, combined with ullder(ving oolitic sands, are primmv evidence ()lits 

ullsuitabilityfor DU disposal because they are direct evidence o/past inulldation. 
probably be met without significant risk given appropriate monitoring and other controls. However, the

notion that hundreds of thousands of tons of concentrated DU can be emplaced in this facility (or any other

shallow landfill) and releases controlled or prevented over long but relevant time-scales is patently absurd.

Our analysis also reveals a fundamental and we believe fatal flaw in your proposed rulemaking.

NRC asks about minimum and maximum quantities, regulatory time frames, inadvertent intrusion, source

terms and geochemical modeling, all of which are important issues. However, you have failed to ask two

critical questions. First, you do not ask whether shallow disposal is proper to begin with. You seem to

assume that it is. Our analysis shows that it is not. Second, you do not ask the types of questions that

would raise the issues surrounding the Clive site that we have addressed. If this is true of Clive, then there

are probably fatal flaws at most if not all shallow disposal facilities, albeit for different specific reasons,

that are related to the inherent nature of surface geological processes over long time scales.

Some of us attended a Radiation Control Board meeting on July 14 in Salt Lake City where many

of the objections to DU disposal discussed in this letter were presented. After hearing a presentation by

EnergySolutions, the driving force behind this rulemaking has become clear. EnergySolutions suggested

that in the coming decades as much as 700,000 tons of DU will require disposal. This is a staggering sum.

If we are not mistaken, current federal statute would permit up to 77,000 tons of HLW to be

disposed at Yucca Mountain, or a little more than 10% of the 700,000 tons of DU. Although this is an

apples to oranges comparison, it places the scale of the DU problem in perspective. Geologic disposal of

DU represents a daunting engineering task. 'The need to dispose of massive quantities of DU "somewhere"

is not a justification to dispose of it "anywhere. " Yet, the need for disposal is clearly driving this action. A

programmatic failure on the part of US Government agencies to plan for the ultimate disposition of DU,

however, is not a justification for improper (i.e., shallow) disposal. It is not a justification for endangering

the future health of the Utah environment, or the environment of any other state even if it is over a long

time scale. It is not a justification for the adoption of a regulatory philosophy that is inconsistent with other

programs.

We have learned through the media that tens of thousands of tons of DU may have already been

emplaced at the Clive facility. It came here under the rubric of "Class A" waste, through a literal but

unfortunate reading of the regulations; in fact, an appropriate analysis has never been done. The Utah

Board of Radiation Control should have been informed that large amounts of DU were never adequately

analyzed under the Federal waste classification scheme at a time when state leaders were still in a position

to comment or stop these historical shipments. While there is blame to go around for this state of affairs,

including Utah state officials who are responsible for running our Agreement State program, we expect

more from the NRC. In this regard, we believe the NRC owes the citizens of Utah anapology for this

serious oversight.

Sincerely,

Stephen T. Nelson4

Professor of Geochemistry

-""/' 1 "Summer B. Rupper4

(_11 < 3 ]'. Professor of Climate and Paleoclimate

Charles G. Oviatt

Professor of Geology

4 Because the issues in this letter address both technical andpublic polic(v matters, Brgham Young

University policy requires that its ficulty make clear that their views are their owin and not those ofthe

University or its sponsoriing institution. NVo incividual or organization has the right to state or imply

otherwise.

probably be met without significant risk given appropriate monitoring and other controls. However, the 

notion that hundreds of thousands of tons of concentrated DU can be emplaced in this facility (or any other 

shallow landfill) and releases controlled or prevented over long but relevant time-scales is patently absurd. 

Our analysis also reveals a fundamental and we believe fatal flaw in your proposed rulemaking. 

NRC asks about minimum and maximum quantities, regulatory time frames, inadvertent intrusion, source 

terms and geochemical modeling, all of which are important issues. However, you have failed to ask two 

critical questions. First, you do not ask whether shallow disposal is proper to begin with. You seem to 

assume that it is. Our analysis shows that [t is not. Second, you do not ask the types of questions that 

would raise the issues surrounding the Clive site that we have addressed. If this is true of Clive, then there 

are probably fatal flaws at most if not all shallow disposal facilities, albeit for different specific reasons, 

that are related to the inherent nature of surface geological processes over long time scales. 

Some of us attended a Radiation Control Board meeting on July 14 in Salt Lake City where many 

of the objections to DU disposal discussed in this letter were presented. After hearing a presentation by 

EnergySolutions, the driving force behind this rulemaking has become clear. EnergySolutions suggested 

that in the coming decades as much as 700,000 tons of DU will require disposal. This is a staggering sum. 

Ifwe are not mistaken, current federal statute would permit up to 77,000 tons ofHLW to be 

disposed at Yucca Mountain, or a little more than 10% of the 700,000 tons ofDU. Although this is an 

apples to oranges comparison, it places the scale of the DU problem in perspective. Geologic disposal of 

DU represents a daunting engineering task. 'The need to dispose of massive quantities ofDU "somewhere" 

is not a justification to dispose of it "anywhere. " Yet, the need for disposal is clearly driving this action. A 

programmatic failure on the part of US Government agencies to plan for the ultimate disposition of DU, 

however, is not a justification for improper (i.e., shallow) disposal. It is not a justification for endangering 

the future health of the Utah environment, or the environment of any other state even if it is over a long 

time scale. It is not a justification for the adoption of a regulatory philosophy that is inconsistent with other 

programs. 

We have learned through the media that tens of thousands of tons ofDU may have already been 

emplaced at the Clive facility. It came here under the rubric of "Class A" waste, through a literal but 

unfortunate reading of the regulations; in fact, an appropriate analysis has never been done. The Utah 

Board of Radiation Control should have been informed that large amounts of DU were never adequately 

analyzed under the Federal waste classification scheme at a time when state leaders were still in a position 

to comment or stop these historical shipments. While there is blame to go around for this state of affairs, 

including Utah state officials who are responsible for running our Agreement State program, we expect 

more from the NRC. In this regard, we believe the NRC owes the citizens of Utah an apology for this 

serious oversight. 

Sincerely, 

Stephen T. Nelson4 

Professor of Geochemistry 

Charles G. Oviatt 

Professor of Geology 

!~ 1:r'-

SummerB. Rupper4 

Professor of Climate and Paleoclimate 

.J Because the issues in this leue!" address both technical and public policy marters, Brigham .Youllg 

Unil'ersity policy requires that its j(J(;ulty make clear that their vielt's are their own and !lot those of the 

Unil'ersity 01' its spol1sol'ing illstitulion. No indil'idu(f/ or organization has the right to slate or impl)' 

otherwise. 
Stephen T. Nelson

Professor

Department of Geological Sciences

Brigham Young University

S389 ESC

Provo, Utah 84602

voice: 801-422-8688

e-mail: steve-nelson@byu.edu

Charles G. Oviatt

Professor

Department of Geology

Kansas State University

108 Thompson Hall

Manhattan, KS 66506-3201

voice: 785-532-6724

e-mail: joviatt@ksu.edu

Summer B. Rupper

Assistant Professor

Department of Geological Sciences

Brigham Young University

S318 ESC

Provo, Utah 84602

voice: 801-422-6946

e-mail: summerrupper@byu.edu

Cc:

Utah Governor Gary M. Herbert

Ms. Amanda Smith, Executive Director, Utah Department of Environmental Quality

Mr. Dane Finerfrock, Director, Utah Division of Radiation Control

Dr. Inds Triay, Assistant Director for Environmental Management, US Department of Energy

Utah Radiation Control Board members

Rep. Rob Bishop

Rep. Jim Matheson

Rep. Jason Chaffetz

Sen. Bob Bennett

Sen. Orrin Hatch

Ms. Judy Fahys, Salt Lake Tribune

Ms. Amy Joi O'Donoghue, Deseret News

Mr. Tim Gillie, Tooele Transcript Bulletin

Mr. Don Porter, Ogden Standard Examiner

Mr. Donald Meyers, Provo Daily Herald

Mr. Todd Siefert, St. George Spectrum

Professor 

Department of Geological Sciences 

Brigham Young University 

S389 ESC 

Provo, Utah 84602 

voice: 801-422-8688 

e-mail: steve _ nelson@byu.edu 

Professor 

Department of Geology . 

Kansas State University 

108 Thompson Hall 

Manhattan, KS 66506-3201 

voice: 785-532-6724 

e-mail: joviatt@ksu.edu 

Assistant Professor 

Department of Geological Sciences 

Brigham Young University 

S318 ESC 

Provo, Utah 84602 

voice: 801-422-6946 

e-mail: summer _ rupper@byu.edu 

Cc: 

Utah Governor Gary M. Herbert 

Stephen T. Nelson 

Charles G. Oviatt 

Summer B. Rupper 

Ms. Amanda Smith, Executive Director, Utah Department of Environmental Quality 

Mr. Dane Finerfrock, Director, Utah Division of Radiation Control 

Dr. Ines Triay, Assistant Director for Environmental Management, US Department of Energy 

Utah Radiation Control Board members 

Rep. Rob Bishop 

Rep. Jim Matheson 

Rep. Jason Chaffetz 

Sen. Bob Bennett 

Sen. Orrin Hatch 

Ms. Judy Fahys, Salt Lake Tribune 

Ms. Amy Joi O'Donoghue, Deseret News 

Mr. Tim Gillie, Tooele Transcript Bulletin 

Mr. Don Porter, Ogden Standard Examiner 

Mr. Donald Meyers, Provo Daily Herald 

Mr. Todd Siefert, St. George Spectrum 
Idaho ~

R7 *11,14N&

~',c~cr R~s r

Nf~br

m Y

a-ca.

ýce Fig's

P r,,,:) Riw er

;>

cu.

z

4~N

Figure 1. Map indicating the main Lake Bonneville highstands and the approximate location of the

EnergySolutions Clive, Utah facility. The Stansbury stage lasted from about 25,000 to 24,000 years ago,

whereas the Bonneville and Provo Stages lastedfrom about 18,300 to 14,500 years ago. Modified from

Nelson et al. (2005).

Mij~ly 

~JC'iJ . 

(sec FigA) 

Idaho ~ 

'" L,clhJa 'lluc~twl~V 

R",IIl,x', p,,,, 

W \Veber 1<.lver ~" .. '" 

N 

Pn}Vo 1 

stage 

H,)jlllcvilk 

"IHlte 

Stnn.;bury 

siage 

Figure 1. Map indicating the main Lake Bonneville highstands and the approximate location of the 

EnergySolutions Clive, Utah facility. The Stansbury stage lastedfrom about 25,000 to 24,000 years ago, 

whereas the Bonneville and Provo Stages lastedfrom about 18,300 to 14,500 years ago. Modifiedfrom 

Nelson et at. (2005). 
Figure 2. Illustrations of Lake Bonneville shorelines. A) represents shorelines developed in the Pilot Valley

area north of Wendover, UT. Modifiedfrom Nelson et al. (2005). B) represents an illustration by G.K.

Gilbert's illustrator W.H. Holmes in the 1880's of numerous shorelines at the north end of the Oquirrh

Mountains prior to being largely obscured by human activity. The familiar Wasatch Mountain skyline can

be seen in the distance.

Figure 2. Illustrations of Lake Bonneville shorelines. A) represents shorelines developed in the Pilot Valley 

area north of Wendover, UT. Modifiedfrom Nelson et at. (2005). B) represents an illustration by G.K. 

Gilbert's illustrator WH. Holmes in the 1880 's of numerous shorelines at the north end of the Oquirrh 

Mountains prior to being largely obscured by human activity. Thefamiliar Wasatch Mountain skyline can 

be seen in the distance. 
AL

..V ... ...... n.o s p illin g

spillinlg

0 100 200 200 Qo 400 \ Thousands of years in the past

beginning of Lake Bonne ville io i/ie present

Figure 3. Lake level/climate history for Owens Lake modified from Bischoff et al. (1997). Note that over the

last 500, 000 years that the lake has expanded and spilled its basin repeatedly. Lake Bonneville has likely

experienced similar expansion and contraction in the past and will experience similar episodes in the

future.

Stochastic Forcing of Lake Levels

20 ~ . ~~~~ i.I-Great Salt Lake Level

15~ -I-BonnevilIle Shoreli ne L e

iý10- -- Level of Proposed DU E

F50)

.~10-

__0 1000 2000 3000. 40001 5000 6000 7000, 8000 9000

Time (years)

Figure 4: Lake level variability forced by present-day interannual variability in precipitation and

temperature, but no change in the mean climate state. The inherent memory of a lake results in integration

of the stochastic (white noise) variability in climate variables, resulting in red noise variability in lake

levels. This integration of noise depends strongly on lake size. Smaller lakes have rapid and smaller lake

level anomalies; conversely, larger lakes have slower and larger lake level anomalies. In summary, lake

level can vary even in the absence of a change in climate.

Owen's Lake record 

L 

not spilling 

,-".' " 

~ 

~ 

l 0' 1 00 200 3QO 400 500 

.. Thousands of years in the past 

beginllillg of l.ake BOllneville I()III/(~ preseni 

Figure 1 Lake level/climate history for Owens Lake modified from Bischoff et al. (J 997). Note that over the 

last 500,000 years that the lake has expanded and spilled its basin repeatedly Lake Bonneville has likely 

experienced similar expansion and contraction in the past and will experience similar episodes in the 

future. 

Stochastic Forcing of Lake Levels 

20 --Great Salt lake Level 

15 --Bonneville Shoreline Level I 10 .-. -Level of Proposed DU Burial U) 

.9:! 

<ii 5 E 

0 

c 

q; 0 

Q) 

> ~5 :.5 

]i. -10 <'0 

-1 

-15 

72°0 1000 5000 

Time (years) 

Figure 4: Lake level variability forced by present-day interannual variability in precipitation and 

temperature, but no change in the mean climate state. The inherent memory of a lake results in integration 

of the stochastic (white noise) variability in climate variables, resulting in red noise variability in lake 

levels. This integration of noise depends strongly on lake size. Smaller lakes have rapid and smaller lake 

level anomalies; conversely, larger lakes have slower and larger lake level anomalies. In summary, lake 

level can vary even in the absence of a change in climate. 

1000 
Evolution of Erosional Shoreline at Clive

E

C

U

-15 -10 -6 0 5 10 15

Horizontal Distance (m)

Figure 5. Modeled shoreline erosion over time at CliveJbr a steady-state lake level. The starting profile

for the slope at Clive is in blue. Each successive colored line represents a snapshot in time during the

erosion process: magenta= 100 years, black= 1000 years, green = 2000 years, red = 4000 years, yellow

7000 years, and blue equals 10000 years. All climate variables and wave generation in the erosion model

are based on present day conditions and solid rock. The grey line represents the equilibrium erosion

profile after 10000 years when rednoise lake variability is included. Note that in all simulations, the

majority of the evolution towards an equilibrium shoreline profile occurs in the first 1000 years.

Evolution of Erosional Shoreline at Clive 

20 

15 

10 

~ 

.s 5 Q) 

g 

('Q 

:iii 0 

0 

1i3 

.Q m"'''''''~_ 

-= Q) 

> 

·15 

·20 

·15 ·10 ·5 0 5 10 15 

Horizontal Distance (01) 

Figure 5: Modeled shoreline erosion over time at Clive for a steady-state lake level. The starting profile 

for the slope at Clive is in blue. Each successive colored line represents a snapshot in time during the 

erosion process: magenta= 1 00 years, black= 1 000 years, green = 2000 years, red = 4000 years, yellow = 

7000 years, and blue equals 10000 years. All climate variables and wave generation in the erosion model 

are based on present day conditions and solid rock. The grey line represents the equilibrium erosion 

profile after 10000 years when rednoise lake variability is included. Note that in all simulations, the 

majority of the evolution towards an equilibrium shoreline profile occurs in thejirst 1000 years. 
Figure 6. Map showing the extent offlooding relative to the current urban corridor of the Salt Lake Valley

should Great Salt Lake levels rise to the elevation of the EnergySolutions Clive site (4280ft or 1305 m).

Figure 6. Map showing the extent offlooding relative to the current urban corridor of the Salt Lake Valley 

should Great Salt Lake levels rise to the elevation of the EnergySolutions Clive site (4280 ft or 1305 m). 
References:

Bischoff, J.L, Fitts, J.P., and Fitzpatrick, J.A., 1997, Responses of sediment geochemistry to climate change

in Owens Lake sediment: An 800-k.y. record of saline/fresh cycles in core OL-93: Geological

Society of America Special Paper 317, p. 37-47

Bright, R.C., 1963, Pleistocene lakes Thatcher and Bonneville, southeastern Idaho. PhD dissertation,

University of Minnesota, Minneapolis, 171 p.

Brouchard, D.P., Kaufman, D.S., Hochberg, A., and Quade, J., 1998, Quaternary history of the Thatcher

Basin, Idaho, reconstructed from the 87Sr/ 86Sr and amino acid composition of lacustrine fossils:

implications for the diversion of the Bear River into the Bonneville Basin: Palaeogeography,

Palaeoclimatology, Palaeoecology, v. 141, p. 95-114.

Eardley, A.J., Shuey, R.T., Gvosdetsky, V., Nash, W.P., Picard, M.D., Grey, D.C., and Kukla, G.J., 1973,

Lake cycles in the Bonneville Basin, Utah: Geological Society of America Bulletin, v. 84, p. 211-

216.

Gilbert, G.K., 1890, Lake Bonneville, U.S. Geological Survey Report M 0001, 438 p.

Link, P.K., Kaufman, D.S., and Thackray, G.D., 1999, Field Guide to Pleistocene Lakes Thatcher and

Bonneville and the Bonneville Flood, southeastern Idaho, in Hughes, S.S., and Thackray, G.D.,

eds., Guidebook to the Geology of Eastern Idaho: Idaho Museum of Natural History, p. 251-266.

McCoy, W.D., 1987, Quaternary aminostratigraphy of the Bonneville Basin, western United States:

Geological Society of America Bulletin, v. 98, p. 99-112.

Nelson, S.T., Wood, M.J., Mayo, A.L., Tingey, D.G., and Eggett, D.L., 2005, Shoreline Tufa and

Tufaglomerate from Pleistocene Lake Bonneville, Utah, USA: stable isotopic and mineralogical

records of lake conditions, processes, and climate: Journal of Quaternary Science, v. 20, p. 3-19.

Oviatt, C.G., Thompson, R.S., Kaufmann, D.S., Bright, J., and Forester, R.M., 1999, Reinterpretation of the

Burmester Core, Bonneville Basin, Utah: Quaternary Research, v. 52, p. 180-184.

Rupper, S., 2009, Stochastic climate forcing of Pleistocene Lake Bonneville: Geological Society of

America Abstracts With Programs, v. 41, p. 3.

Sandquist, Gary, 2009, Uranium in GSL, Public Forum, Salt Lake Tribune, Oct. 21, 2009. (The author of

this letter is almost certainly a former Univ. of Utah nuclear engineering professor)

Tarboton, D.G., 2006, What makes the Great Salt Lake level go up and down: Geological Society of

America Abstracts With Programs, v. 37, p. 162.

References: 

Bischoff, lL, Fitts, lP., and Fitzpatrick, lA., 1997, Responses of sediment geochemistry to climate change 

in Owens Lake sediment: An 800-k.y. record of saline/fresh cycles in core OL-93: Geological 

Society of America Special Paper 317, p. 37-47 

Bright, R.e., 1963, Pleistocene lakes Thatcher and Bonneville, southeastern Idaho. PhD dissertation, 

University of Minnesota, Minneapolis, 171 p. 

Brouchard, D.P., Kaufman, D.S., Hochberg, A., and Quade, J., 1998, Quaternary history of the Thatcher 

Basin, Idaho, reconstructed from the 87Sr/86Sr and amino acid composition of lacustrine fossils: 

implications for the diversion of the Bear River into the Bonneville Basin: Palaeogeography, 

Palaeoclimatology, Palaeoecology, v. 141, p. 95-114. 

Eardley, A.J., Shuey, R.T., Gvosdetsky, V., Nash, W.P., Picard, M.D., Grey, D.e., and Kukla, G.1., 1973, 

Lake cycles in the Bonneville Basin, Utah: Geological Society of America Bulletin, v. 84, p. 211-

216. 

Gilbert, G.K., 1890, Lake Bonneville, U.S. Geological Survey Report M 0001, 438 p. 

Link, P.K., Kaufman, D.S., and Thackray, G.D., 1999, Field Guide to Pleistocene Lakes Thatcher and 

Bonneville and the Bonneville Flood, southeastern Idaho, in Hughes, S.S., and Thackray, G.D., 

eds., Guidebook to the Geology of Eastern Idaho: Idaho Museum of Natural History, p. 251-266. 

McCoy, W.D., 1987, Quaternary aminostratigraphy of the Bonneville Basin, western United States: 

Geological Society of America Bulletin, v. 98, p. 99-112. 

Nelson, S.T., Wood, M.1., Mayo, A.L., Tingey, D.G., and Eggett, D.L., 2005, Shoreline Tufa and 

Tufaglomerate from Pleistocene Lake Bonneville, Utah, USA: stable isotopic and mineralogical 

records of lake conditions, processes, and climate: Journal of Quaternary Science, v. 20, p. 3-19. 

Oviatt, e.G., Thompson, R.S., Kaufmann, D.S., Bright, 1., and Forester, R.M., 1999, Reinterpretation of the 

Burn1ester Core, Bonneville Basin, Utah: Quaternary Research, v. 52, p. 180-184. 

Rupper, S., 2009, Stochastic climate forcing of Pleistocene Lake Bonneville: Geological Society of 

America Abstracts With Programs, v. 41, p. 3. 

Sandquist, Gary, 2009, Uranium in GSL, Public Forum, Salt Lake Tribune, Oct. 21, 2009. (The author of 

this letter is almost certainly a former Univ. of Utah nuclear engineering professor) 

Tarboton, D.G., 2006, What makes the Great Salt Lake level go up and down: Geological Society of 

America Abstracts With Programs, v. 37, p. 162. 
BIOGRAPHICAL SKETCHES

Stephen T. Nelson, Qualifications:

I am a professor of geochemistry at a major university where I have taught and engaged in

research for the last 12 1⁄2 years. My area of teaching and research expertise includes isotope geochemistry.

I have established a light stable isotope laboratory, 3H, and 1

4

C liquid scintillation counting facilities, as

well as an alpha spectroscopy laboratory for U-series measurements in naturally-occurring matrices. I teach

a graduate course in isotope geochemisiry and team-teach a graduate course in contaminant hydrogeology.

Much of my research includes the response of arid regions to climate change.

From July 1998 to July 2008 1 was a member, vice chair, and chair of the Utah Radiation Control

Board. From March 1993 to Dec. 1996 1 worked under the Management and Operating Contract for the US

DOE Yucca Mountain Project. I participated in the management of volcanic hazard, mineralogy and

petrology, and geochemistry studies as part of the characterization effort for that site. I also have direct

research experience and interests in the Bonneville basin, which includes the EnergySolutions Clive, Utah

site. In summary, I have considerable experience and insight relevant to the issue of DU disposal in

general and at Clive, Utah in particular.

Charles G. Oviatt, Qualifications:

I am a professor of geology at Kansas State University, in Manhattan, KS. I began studying Lake

Bonneville as a graduate student at the University of Utah in 1977, and I am continuing that work today.

During the eight years I lived in Salt Lake City, I was employed by the Utah Division of State History, the

U.S. Geological Survey, and the Utah Geological Survey, and in each of these positions I continued to

work on Lake Bonneville. In 1985 I moved to Kansas State University to teach geology, and have returned

to Utah to study Lake Bonneville every year (primarily during summers) since then. I have published

numerous scientific articles, maps, reports, and abstracts related to Lake Bonneville. These include: over

20 peer-reviewed scientific journal articles or book chapters, over 40 abstracts of presentations at scientific

conferences, and over 30 other reports, maps, and guidebooks.

Summer B. Rupper, Qualifications:

I am a professor of climate and paleoclimate at a major university, and have been studying the

Earth's climate system for almost a decade. My specific area of research expertise is in quantifying the

interactions between climate and earth's surface, with emphasis on glaciers and lakes. Recently this has

included numerical modeling of the lake-level variability of the Great Salt Lake and glacial Lake

Bonneville, impacts of that variability on erosion rates and shoreline evolution, and the associated

feedbacks and forcings between lakes and regional climate over short and long time-scales. I have

published more than 20 scientific articles, proceedings, book chapters, and abstracts related to climate and

paleoclimate; served as a reviewer and guest editor for top-tier climate and paleoclimate journals; and

served as a reviewer and panelist for climate, glaciology, and geomorphology divisions of major grant

funding agencies.

BIOGRAPHICAL SKETCHES 

Stephen T. Nelson, Qualifications: 

I am a professor of geochemistry at a major university where I have taught and engaged in 

research for the last 12 Y:z years. My area of teaching and research expertise includes isotope geochemistry. 

I have established a light stable isotope laboratory, 3H, and 14C liquid scintillation counting facilities, as 

well as an alpha spectroscopy laboratory for U-series measurements in naturally-occurring matrices. I teach 

a graduate course in isotope geochemistry and team-teach a graduate course in contaminant hydrogeology. 

Much of my research includes the response of arid regions to climate change. 

From July 1998 to July 2008 I was a member, vice chair, and chair of the Utah Radiation Control 

Board. From March 1993 to Dec. 1996 I worked under the Management and Operating Contract for the US 

DOE Yucca Mountain Project. I participated in the management of volcanic hazard, mineralogy and 

petrology, and geochemistry studies as part of the characterization effort for that site. I also have direct 

research experience and interests in the Bonneville basin, which includes the EnergySolutions Clive, Utah 

site. In summary, I have considerable experience and insight relevant to the issue ofDU disposal in 

general and at Clive, Utah in particular. 

Charles G. Oviatt, Qualifications: 

I am a professor of geology at Kansas State University, in Manhattan, KS. I began studying Lake 

Bonneville as a graduate student at the University of Utah in 1977, and I am continuing that work today. 

During the eight years I lived in Salt Lake City, I was employed by the Utah Division of State History, the 

U.S. Geological Survey, and the Utah Geological Survey, and in each of these positions I continued to 

work on Lake Bonneville. In 1985 I moved to Kansas State University to teach geology, and have returned 

to Utah to study Lake Bonneville every year (primarily during summers) since then. I have published 

numerous scientific articles, maps, reports, and abstracts related to Lake Bonneville. These include: over 

20 peer-reviewed scientific journal articles or book chapters, over 40 abstracts of presentations at scientific 

conferences, and over 30 other reports, maps, and guidebooks. 

Summer B. Rupper, Qualifications: 

I am a professor of climate and paleoclimate at a major university, and have been studying the 

Earth's climate system for almost a decade. My specific area ofresearch expertise is in quantifying the 

interactions between climate and earth's surface, with emphasis on glaciers and lakes. Recently this has 

included numerical modeling of the lake-level variability of the Great Salt Lake and glacial Lake 

Bonneville, impacts of that variability on erosion rates and shoreline evolution, and the associated 

feedbacks and forcings between lakes and regional climate over short and long time-scales. I have 

published more than 20 scientific articles, proceedings, book chapters, and abstracts related to climate and 

paleoclimate; served as a reviewer and guest editor for top-tier climate and paleoclimate journals; and 

served as a reviewer and panelist for climate, glaciology, and geomorphology divisions of major grant 

funding agencies. 
Page 1 of 2

7y~3oI75

As of: November 05, 2009

Received: October 30, 2009

Status: Pending-Post CTracking No. 8Oa4dcc7

Comments Due: October 30, 2009

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0020

Comment on FR Doc # E9-14820

Submitter Information

Name: Liz Woodruff C7

Address: i"

PO Box 1731 C

Boise,, ID, 83701

Organization: Snake River Alliance

General Comment

PLEASE SEE THE ATTACHED FILE FOR OUR COMPLETE SUBMITTAL

Thank you for the opportunity to provide comments regarding the rulemaking process for depleted uranium

(DU) and other unique waste streams. These comments are respectfully submitted on behalf of the Snake River

Alliance, Idaho's Nuclear Watchdog and Advocate for Clean Energy. As our Program Director Beatrice Brailsford

has indicated in communications with Patricia Bubar, the Alliance will be submitting additional comments as

soon as Ms. Brailsford's unexpected computer difficulties have been resolved.

The Snake River Alliance is closely monitoring this rule making process, since the finalized rule will directly

impact how the proposed Areva uranium enrichment facility will deal with the waste it will potentially produce

here in Idaho. The outcome of this rule will directly impact whether DU will be stored in Idaho and we are

therefore concerned about risks to public safety and the integrity of Idaho's environment and natural resources

associated with potential storage. More broadly, all stakeholders have an interest in ensuring that the NRC

determines an appropriate disposal pathway for DU that adequately addresses its widely acknowledged unique

characteristics associated with the long life and increasing threat posed by this waste over extended periods of

time that go beyond the scope of scientific predictability.

It is our position that the current classification of depleted uranium as low-level waste (LLW) is inappropriate,

and we are pleased that the NRC is creating a more robust and meaningful rule regarding the disposal of DU.

Nevertheless, we believe the NRC should consider creating a different classification system for DU and other

"unique" waste streams, and hope that this possibility is being seriously considered within this rulemaking

process. We also believe that disposal in a deep geologic repository is the only responsible conclusion of this

rulemaking procedure. F-R!iDS : 40•on--0a3

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As of: November 05, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC S BMISSI N Tracking No. 80a4dcc7 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0020 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Liz Woodruff 

Address: 

PO Box 1731 

Boise" ID, 83701 

Organization: Snake River Alliance 

General Comment 

PLEASE SEE THE ATIACHED FILE FOR OUR COMPLETE SUBMITIAL 

-, I , 

, ., .. ~ ... .., . i I 

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Thank you for the opportunity to provide comments regarding the rulemaking process for depleted uranium 

(DU) and other unique waste streams. These comments are respectfully submitted on behalf of the Snake River 

Alliance, Idaho's Nuclear Watchdog and Advocate for Clean Energy. As our Program Director Beatrice Brailsford 

has indicated in communications with Patricia Bubar, the Alliance will be submitting additional comments as 

soon as Ms. Brailsford's unexpected computer difficulties have been resolved. 

The Snake River Alliance is closely monitoring this rule making process, since the finalized rule will directly 

impact how the proposed Areva uranium enrichment facility will deal with the waste it will potentially produce 

here in Idaho. The outcome of this rule will directly impact whether DU will be stored in Idaho and we are 

therefore concerned about risks to public safety and the integrity of Idaho's environment and natural resources 

associated with potential storage. More broadly, all stakeholders have an interest in ensuring that the NRC 

determines an appropriate disposal pathway for DU that adequately addresses its widely acknowledged unique 

characteristics associated with the long life and increasing threat posed by this waste over extended periods of 

time that go beyond the scope of scientific predictability.· 

It is our position that the current classification of depleted uranium as low-level waste (LLW) is inappropriate, 

and we are pleased that the NRC is creating a more robust and meaningful rule regarding the disposal of DU. 

Nevertheless, we believe the NRC should consider creating a different classification system for DU and other 

"unique" waste streams, and hope that this possibility is being seriously considered within this rulemaking 

process. We also believe that disposal in a deep geologic repository is the only responsible conclusion of this 

rulemaking procedure. e-Ri OS ~ itOn.--tB 

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https:llfdms.erulemaking.net/fdms-web-agency/ componentl submitter InfoCover Page ?Call = Print&PrintId... 11/05/2009 
Page 2 of 2

Attachments

NRC-2009-0257-DRAFT-0020.1: Comment on FR Doc # E9-14820

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11/05/2009

Page 2 of2 

Attachments 

NRC-2009-0257-DRAFT-0020.1: Comment on FR Doc # E9-14820 

https:llfdms.erulemaking.net/fdms-web-agency/ component! submitter InfoCover Page?Call = Print&PrintI d... 11/05/2009 
SNAKE R1VL71

IDAHO'S NUCLEAR WATCHDOG

& CLEAN ENERGY ADVOCATE

www.snakeriveralliance.org

October 3 0 th, 2009

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

U.S. Nuclear Regulatory Commission

Mail Stop TWB 5B01M

Washington, DC

20555-0001

RE: Federal Register Notice, June 2 4 th, 2009, pgs 30175-30179-Notice of Public Workshops on a

Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant Quantities of

Depleted Uranium.

To Whom it May Concern;

Thank you for the opportunity to provide comments regarding the rulemaking process for depleted

uranium (DU) and other unique waste streams. These comments are respectfully submitted on behalf

of the Snake River Alliance, Idaho's Nuclear Watchdog and Advocate for Clean Energy. As our Program

Director Beatrice Brailsford has indicated in communications with Patricia Bubar, the Alliance will be

submitting additional comments as soon as Ms. Brailsford's unexpected computer difficulties have been

resolved.

The Snake River Alliance is closely monitoring this rule making process, since the finalized rule will

directly impact how the proposed Areva uranium enrichment facility will deal with the waste it will

potentially produce here in Idaho. The outcome of this rule will directly impact whether DU will be

stored in Idaho and we are therefore concerned about risks to public safety and the integrity of Idaho's

environment and natural resources associated with potential storage. More broadly, all stakeholders

have an interest in ensuring that the NRC determines an appropriate disposal pathway for DU that

adequately addresses its widely acknowledged unique characteristics associated with the long life and

increasing threat posed by this waste over extended periods of time that go beyond the scope of

scientific predictability.

It is our position that the current classification of depleted uranium as low-level waste (LLW) is

inappropriate, and we are pleased that the NRC is creating a more robust and meaningful rule regarding

SNAKE RIVER 

I 

IDAHO'S NUCLEAR WATCHDOG 

& CLEAN ENERGY ADVOCATE 

www.snakeriveralliance.org 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Mail Stop TWB 5B01M 

Washington, DC 

20555-0001 

October 30th, 2009 

RE: Federal Register Notice, June 24th, 2009, pgs 30175-30179-Notice of Public Workshops on a 

Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant Quantities of 

Depleted Uranium. 

To Whom it May Concern; 

Thank you for the opportunity to provide comments regarding the rulemaking process for depleted 

uranium (DU) and other unique waste streams. These comments are respectfully submitted on behalf 

of the Snake River Alliance, Idaho's Nuclear Watchdog and Advocate for Clean Energy. As our Program 

Director Beatrice Brailsford has indicated in communications with Patricia Bubar, the Alliance will be 

submitting additional comments as soon as Ms. Brailsford's unexpected computer difficulties have been 

resolved. 

The Snake River Alliance is closely monitoring this rule making process, since the finalized rule will 

directly impact how the proposed Areva uranium enrichment facility will deal with the waste it will 

potentially produce here in Idaho. The outcome of this rule will directly impact whether DU will be 

stored in Idaho and we are therefore concerned about risks to public safety and the integrity of Idaho's 

environment and natural resources associated with potential storage. More broadly, all stakeholders 

have an interest in ensuring that the NRC determines an appropriate disposal pathway for DU that 

adequately addresses its widely acknowledged unique characteristics associated with the long life and 

increasing threat posed by this waste over extended periods of time that go beyond the scope of 

scientific predictability. 

It is our position that the current classification of depleted uranium as low-level waste (LLW) is 

inappropriate, and we are pleased that the NRC is creating a more robust and meaningful rule regarding 
the disposal of DU. Nevertheless, we believe the NRC should consider creating a different classification

system for DU and other "unique" waste streams, and hope that this possibility is being seriously

considered within this rulemaking process. We also believe that disposal in a deep geologic repository is

the only responsible conclusion of this rulemaking procedure and we urge the NRC to seriously consider

that outcome. Each of these points will be addressed in more detail below, in addition to various other

concerns and comments regarding rules for the disposal of depleted uranium.

The Unique Characteristics of DU Make Low-Level Waste Sites Inappropriate for Disposal

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level

waste disposal facility. That decision did not take into account the hundreds of thousands of years over

which DU grows more radioactive. Because LLW disposal requirements assume only a 100-year time in

which the waste remains a threat to public safety, the characteristics of DU clearly exceed the scope of

LLW regulations. Any adequate rule will necessarily:

" Require modeling that extends beyond 10,000 years in site assessment criteria. While workshop

comments include the assertion that modeling beyond 10,000 years is difficult, this indicates

less that that modeling should ignore this issue and more that DU requires highly stringent rules

and methods of evaluation than the LLW category provides.

" Evaluate the potential impacts of climate change and geologic activity on any given disposal

sites viability. As Dr. Arjun Makhijani indicated in his comments at the first workshop, climate

modeling in particular has been absent from the current considered relevant factors

surrounding DU's disposal and must be incorporated in future modeling relevant to any site

assessments. Since a site's suitability requires it to be a dry site and since climate changes would

clearly have an impact on the long-term potential for a currently dry site remaining dry over the

extended life of this waste stream, this essential point should be a priority of any finalized rules

and guidelines.

* Acknowledge the potential inadequacy of any hard cover requirement for a near surface

disposal site given the potential for erosion over a time-frame where DU increases in

radioactivity and poses the greatest danger in its millionth year. The potential for erosion of a

hard cover must be addressed and reflected in any regulation.

" Until the NRC is able to provide a clear description of "other unique waste streams," it must not

attempt to formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow land burial is adequate for depleted uranium disposal.

" The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully

evaluates DU disposal in a deep geologic repository. It is only through disposal in a deep

geologic repository that the unique characteristics and subsequent threats posed by depleted

uranium can adequately be addressed. Additionally, any current disposal of DU in LLW sites

should immediately be halted, and future disposal should be limited to a deep geologic

repository.

the disposal of DU. Nevertheless, we believe the NRC should consider creating a different classification 

system for DU and other "unique" waste streams, and hope that this possibility is being seriously 

considered within this rulemaking process. We also believe that disposal in a deep geologic repository is 

the only responsible conclusion of this rulemaking procedure and we urge the NRC to seriously consider 

that outcome. Each of these points will be addressed in more detail below, in addition to various other 

concerns and comments regarding rules for the disposal of depleted uranium. 

The Unique Characteristics of DU Make low-level Waste Sites Inappropriate for Disposal 

The NRC erred when it decided to formulate guidelines for depleted uranium disposal in a low-level 

waste disposal facility. That decision did not take into account the hundreds of thousands of years over 

which DU grows more radioactive. Because LLW disposal requirements assume only a 100-year time in 

which the waste remains a threat to public safety, the characteristics of DU clearly exceed the scope of 

LLW regulations. Any adequate rule will necessarily: 

• Require modeling that extends beyond 10,000 years in site assessment criteria. While workshop 

comments include the assertion that modeling beyond 10,000 years is difficult, this indicates 

less that that modeling should ignore this issue and more that DU requires highly stringent rules 

and methods of evaluation than the LLW category provides. 

• Evaluate the potential impacts of climate change and geologic activity on any given disposal 

sites viability. As Dr. Arjun Makhijani indicated in his comments at the first workshop, climate 

modeling in particular has been absent from the current considered relevant factors 

surrounding DU's disposal and must be incorporated in future modeling relevant to any site 

assessments. Since a site's suitability requires it to be a dry site and since climate changes would 

clearly have an impact on the long-term potential for a currently dry site remaining dry over the 

extended life of this waste stream, this essential point should be a priority of any finalized rules 

and guidelines. 

• Acknowledge the potential inadequacy of any hard cover requirement for a near surface 

disposal site given the potential for erosion over a time-frame where DU increases in 

radioactivity and poses the greatest danger in its millionth year. The potential for erosion of a 

hard cpver must be addressed and reflected in any regulation. 

• Until the NRC is able to provide a clear description of "other unique waste streams," it must not 

attempt to formulate rules governing their disposal. Instead, the NRC should focus on reevaluating its decision that shallow land burial is adequate for depleted uranium disposal. 

• The NRC must, as part of this rulemaking, prepare an environmental impact statement that fully 

evaluates DU disposal in a deep geologic repository. It is only through disposal in a deep 

geologic repository that the unique characteristics and subsequent threats posed by depleted 

uranium can adequately be addressed. Additionally, any current disposal of DU in LLW sites 

should immediately be halted, and future disposal should be limited to a deep geologic 

repository. 
Continued Production of DU Waste Should Be Limited

Because the United States does not have a deep geologic repository for commercial waste streams, any

additional production of DU should be severely limited. It would be irresponsible and inappropriate for

the NRC to license any new enrichment facilities at least until this rule-making process is complete and

even then a demonstrated need for new enrichment must be proven prior to the NRC granting a license

that would result in the further production of DU. Currently, assertions that the expanded

manufacturing of enriched uranium is necessary are based on the tenuous premise that a "nuclear

renaissance" will massively increase demand for enriched uranium. This premise is severely undercut by

the following factors:

* The current economic downturn and the exorbitant costs associated with the construction and

operational viability of a new fleet of U.S. reactors has resulted in significant financing delays

and even cancellations of several proposed "next generation" nuclear reactors

* Recent production slow-downs at various current reactors throughout the United States indicate

that the industry is not, in fact, growing.

" Given the extent to which the nuclear industry relies on subsidization from the federal

government for the financing of any new construction of nuclear reactors, uncertainty over

which energy sources will be prioritized and supported in upcoming federal climate legislation

destabilizes and mitigates the viability of increased nuclear energy production.

* Current supplies of fuel for reactors via the "Megatons to Megawatts" down-blending program

operated by USEC remain adequate to meet the fuel requirements of U.S. reactors. There is

every indication that this program will be extended beyond 2013 and unless the need for

additional supplies of enriched uranium are verifiably demonstrated, the burdens associated

with the disposal of depleted uranium outweigh the risks associated with the licensing, funding,

construction and operation of any proposed U.S. enrichment facility.

Delays in the Completion of De-conversion Facilities Should be Assessed in terms of the Impact on

Potential Storage of DU

Beyond issues associated with what would constitute adequate disposal of depleted uranium and the

imperative of halting further licensing of proposed enrichment facilities, the Snake River Alliance would

appreciate an assessment in the NRC's rule making determinations regarding the potential impacts of

delays in the construction of de-conversion facilities that are a must-take step in the ability to dispose of

DU. How long can we expect any new enrichment facilities to store waste on-site while de-conversion

facilities are built? If de-conversion facilities are delayed or never constructed how will the NRC address

the disposal of DU? Is it appropriate to license new enrichment facilities given the uncertain time-frames

associated with the completion of de-conversion facilities?

Continued Production of DU Waste Should Be Limited 

Because the United States does not have a deep geologic repository for commercial waste streams, any 

additional production of DU should be severely limited. It would be irresponsible and inappropriate for 

the NRC to license any new enrichment facilities at least until this rule-making process is complete and 

even then a demonstrated need for new enrichment must be proven prior to the NRC granting a license 

that would result in the further production of DU. Currently, assertions that the expanded 

manufacturing of enriched uranium is necessary are based on the tenuous premise that a "nuclear 

renaissance" will massively increase demand for enriched uranium. This premise is severely undercut by 

the following factors: 

• The current economic downturn and the exorbitant costs associated with the construction and 

operational viability of a new fleet of U.S. reactors has resulted in significant financing delays 

and even cancellations of several proposed "next generation" nuclear reactors 

• Recent production slow-downs at various current reactors throughout the United States indicate 

that the industry is not, in fact, growing. 

• Given the extent to which the nuclear industry relies on subsidization from the federal 

government for the financing of any new construction of nuclear reactors, uncertainty over 

which energy sources will be prioritized and supported in upcoming federal climate legislation 

destabilizes and mitigates the viability of increased nuclear energy production. 

• Current supplies of fuel for reactors via the "Megatons to Megawatts" down-blending program 

operated by USEC remain adequate to meet the fuel requirements of U.S. reactors. There is 

every indication that this program will be extended beyond 2013 and unless the need for 

additional supplies of enriched uranium are verifiably demonstrated, the burdens associated 

with the disposal of depleted uranium outweigh the risks associated with the licensing, funding, 

. construction and operation of any proposed U.S. enrichment facility. 

Delays in the Completion of De-conversion Facilities Should be Assessed in terms of the Impact on 

Potential Storage of DU 

Beyond issues associated with what would constitute adequate disposal of depleted uranium and the 

imperative of halting further licensing of proposed enrichment facilities, the Snake River Alliance would 

appreciate an assessment in the NRC's rule making determinations regarding the potential impasts of 

delays in the construction of de-conversion facilities that are a must-take step in the ability to dispose of 

DU. How long can we expect any new enrichment facilities to store waste on-site while de-conversion 

facilities are built? If de-conversion facilities are delayed or never constructed how will the NRC address 

the disposal of DU? Is it appropriate to license new enrichment facilities given the uncertain time-frames 

associated with the completion of de-conversion facilities? 
Conclusion

As the workshops on this rule making procedure have indicated, depleted uranium is uniquely difficult

to regulate and poses a series of insurmountable uncertainties and risks that will require extensive

reforms to the way its disposal has been handled in the past and the criteria by which its disposal is

currently being evaluated. At this time, we remain gravely concerned with that the outcome of this

rulemaking process will potentially allow shallow-land disposal and we will continue to insist that the

models being used for site assessment criteria are missing key factors that should be included in the

final rules governing the final disposal methodology associated with DU. Based on the unique

characteristics of and time-frames associated with DU, it is clear that a deep geologic repository would

be the only adequate disposal method. Because an appropriate repository for commercial waste does

not exist and because no de-conversion facilities are operational, DU will, by necessity, be stored

indefinitely on the sites at which it is produced. For all of these reasons we remain adamant that the

NRC should not license new enrichment facilities until this rule is complete and the uncertainties

addressed in these comments are adequately resolved.

Sincerely,

Liz Woodruff

Energy Policy Analyst

Snake River Alliance

350 N. 9th Street, Suite B10

Boise, ID 83702

Phone: (208) 344-9161

Fax: (208) 331-0885

lwoodruff@snakeriveralliance.org

www.sna keriverallia nce.ore

Conclusion 

As the workshops on this rule making procedure have indicated, depleted uranium is uniquely difficult 

to regulate and poses a series of insurmountable uncertainties and risks that will require extensive 

reforms to the way its disposal has been handled in the past and the criteria by which its disposal is 

currently being evaluated. At this time, we remain gravely concerned with that the outcome of this 

rulemaking process will potentially allow shallow-land disposal and we will continue to insist that the 

models being used for site assessment criteria are missing key factors that should be included in the 

final rules governing the final disposal methodology associated with DU. Based on the unique 

characteristics of and time-frames associated with DU, it is clear that a deep geologic repository would 

be the only adequate disposal method. Because an appropriate repository for commercial waste does 

not exist and because no de-conversion facilities are operational, DU will, by necessity, be stored 

indefinitely on the sites at which it is produced. For all of these reasons we remain adamant that the 

NRC should not license new enrichment facilities until this rule is complete and the uncertainties 

addressed in these comments are adequately resolved. 

Sincerely, 

Liz Woodruff 

Energy Policy Analyst 

Snake River Alliance 

350 N. 9th Street, Suite Bl0 

Boise, ID 83702 

Phone: (208) 344-9161 

Fax: (208) 331-0885 

Iwoodruff@snakeriveralliance.org 

www:snakeriveralliance.org 
Page 1 of 2

7 1d YFe36/7•

As of: November 05, 2009

Received: October 30, 2009

Status: Pending-Post

ITracking No. 80a4ebe7

Comments Due: October 30, 2009

Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0021

Comment on FR Doc # E9-14820

,•)~ ... ...... f-i

Submitter Information

Name: Rebecca Chavez-Houck

Address:

643 East 16th Avenue

Salt Lake City, UT, 84103 -

Government Agency Type: Local

Government Agency: Utah State Legislature

General Comment

October 30, 2009

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration, U.S. Nuclear Regulatory Commission

Mail Stop TWB 5B01M, Washington, DC 20555-0001

Subject: Reference ID: NRC-2009-0257. Appeared in June 24, 2009 Federal Register, pg. 30175

Submitted online at http://www.regulations.gov

To Whom it May Concern:

I am writing to express my concerns about your proposed rulemaking on depleted uranium.

1. Significant quantities of depleted uranium have a hazard comparable to transuranic waste; therefore,

depleted uranium should not be allowed for disposal in a near-surface facility, i

Depleted uranium is a long-lived alpha emitter. In terms of its radiological hazard, it is similar to the p Y4.40,

transuranic isotopes. Transuranic wastes are currently disposed of at the Waste Isolation Pilot Plant (WIPP), ('-

htts://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11/05/2009

,-

74 FtZ-3o/76 

(,/d¥J()~ 

As of: November OS, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of2 

PUBLIC S B ISSI N Tracking No. 80a4ebe7 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT -0021 

Comment on FR Doc # E9-14820 

Name: Rebecca Chavez-Houck 

Address: 

643 East 16th Avenue 

Salt Lake City, UT, 84103 

Submitter Information 

Government Agency Type: Local 

Government Agency: Utah State Legislature 

General Comment 

October 30, 2009 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration, U.S. Nuclear Regulatory Commission 

Mail Stop TWB 5B01M, Washington, DC 20555-0001 

Subject: Reference ID: NRC-2009-0257. Appeared in June 24, 2009 Federal Register, pg. 30175 

Submitted online at http://www.regulations.gov 

To Whom it May Concern: 

I am writing to express my concerns about your proposed rulemaking on depleted uranium. 

, 

1../'1 

1. Significant quantities of depleted uranium have a hazard comparable to transuranic waste; therefore, 

depleted uranium should not be allowed for disposal in a near-surface facility. i 

Depleted uranium is a long-lived alpha emitter. In terms of its radiological hazard, it is similar to the p. y. cd v 

transuranic isotopes. Transuranic wastes are currently disposed of at the Waste Isolation Pilot Plant (WIPP), (4 A) 

SL{NSI ~j)iew &~/e-iv E-~-ws --fto~-6.3 . PfY 

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Page 2 of 2

thousands of feet below the Earth's surface. Deep burial of this kind affords greater stability and protection

from potential disturbance of the waste over the many tens of thousands of years that it will be hazardous.

Given the similarity between significant amounts of depleted uranium and the transuranic isotopes, deep

geologic disposal should be the minimum acceptable disposal for depleted uranium. I urge you to revise your

proposed rulemaking to require deep geologic disposal of depleted uranium.

2. The proposed rule should examine the peak hazard from depleted uranium; shortening the "period of

performance" will artificially lower the perceived hazard.

If your Agency continues to develop a rule for the near-surface disposal of depleted uranium, as is now

envisioned, then the site-specific analysis required should have to examine the peak hazard posed by depleted

uranium.

3. Current performance assessments showing disposal of depleted uranium is safe may not be adequate;

disposal of additional significant quantities of depleted uranium should be suspended pending updates to

performance assessments.

Repres

https:H/fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11/05/2009

thousands of feet below the Earth's surface. Deep burial of this kind affords greater stability and protection 

from potential disturbance of the waste over the many tens of thousands of years that it will be hazardous. 

Page 2 of2 

Given the similarity between significant amounts of depleted uranium and the transuranic isotopes, deep 

geologic disposal should be the minimum acceptable disposal for depleted uranium. I urge you to revise your 

proposed rulemaking to require deep geologic disposal of depleted uranium. 

2. The proposed rule should examine the peak hazard from depleted uranium; shortening the "period of 

performance" will artificially lower the perceived hazard. 

If your Agency continues to develop a rule for the near-surface disposal of depleted uranium, as is now 

envisioned, then the site-specific analysis required should have to examine the peak hazard posed by depleted 

uranium. 

3. Current performance assessments showing disposal of depleted uranium is safe may not be adequate; 

disposal of additional significant quantities of depleted uranium should be suspended pending updates to 

performance assessments. 

Repres 

https:llfdms.erulemaking.net/fdms-web-agency/ componentl submitter InfoCover Page ?Call = Print&PrintI d... 11/05/2009 
Page 1 of 1

7T/ F-P-36175

As of: November 05, 2009

Received: October 30, 2009

WPAMBAF% MCM Status: Pending-Post

JTracking No. 80a4edld

Comments Due: October 30,

,Submission Type: Web

Docket: NRC-2009-0257

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including

Significant Quantities of Depleted Uranium

Comment On: NRC-2009-0257-0001

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant

Quantities of Depleted Uranium

Document: NRC-2009-0257-DRAFT-0022

Comment on FR Doc # E9-14820

2009

Submitter Information

Name: Christopher Thomas

Address: I

HEAL Utah . 68 S. Main Street, Suite 400 '-0

Salt Lake City, UT, 84101

Organization: HEAL Utah

General Comment

Please consider the uploaded comments on NRC-2009-0257-0001 submitted by the Healthy Environment

Alliance of Utah (HEAL Utah). Please feel free to contact me if you have any questions or difficulty receiving our

submission.

Attachments

NRC-2009-0257-DRAFT-0022.1: Comment on FR Doc # E9-14820

5uN.il I2cv~e. ) g.l~ ~~6

https://fdms.erulemaking.net/fdms-web-agency/component/submitterlnfoCoverPage?Call=Print&Printld... 11/05/2009

7Lf FfL36176 

&/;;. '+/ () ~ 

As of: November 05, 2009 

Received: October 30, 2009 

Status: Pending_Post 

Page 1 of 1 

PUBLIC SUBMISSI N Tracking No. 80a4ed1d 

Comments Due: October 30, 2009 

Submission Type: Web 

Docket: NRC-2009-0257 

Notice of Public Workshop on a Potential Rulemaking for Safe Disposal of Unique Waste Streams Including 

Significant Quantities of Depleted Uranium 

Comment On: NRC-2009-0257-0001 

Public Workshop: Potential Rulemaking for Safe Disposal of Unique Waste Streams Including Significant 

Quantities of Depleted Uranium 

Document: NRC-2009-0257-DRAFT-0022 

Comment on FR Doc # E9-14820 

Submitter Information 

Name: Christopher Thomas 

Address: 

HEAL Utah 

68 S. Main Street, Suite 400 

Salt Lake City, UT, 84101 

Organization: HEAL Utah 

General Comment 

""',-1 

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........... 

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\ .. ,T', 

Please consider the uploaded comments on NRC-2009-0257-0001 submitted by the Healthy Environment 

Alliance of Utah (HEAL Utah). Please feel free to contact me if you have any questions or difficulty receiving our 

submission. 

Attachments 

NRC-2009-0257-DRAFT-0022.1: Comment on FR Doc # E9-14820 

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October 30, 2009

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration, U.S. Nuclear Regulatory Commission

Mail Stop TWB 5B01 M, Washington, DC 20555-0001

Reference ID: NRC-2009-0257; Federal Register published June 24, 2009. See page 30175.

Submitted online at http://www. regulations. gov

To Whom it May Concern:

I am writing on behalf of the Health Environment Alliance of Utah (HEAL Utah) and our supporters to

express several concerns and suggestions regarding your proposed rulemaking related to the safe

disposal of depleted uranium.

HEAL Utah is a public interest group dedicated to protecting public health that advocates on nuclear

power, nuclear waste, and toxic waste issues. HEAL Utah is supported by nearly 600 active

contributing members and maintains an email distribution list of over 4,000. We have worked on

many issues involving radioactive waste disposal in Utah, including the disposal of foreign nuclear

waste, Class B and C nuclear waste, waste from the Fernald, Ohio, cleanup, and the high-level

waste Private Fuel Storage (PFS) proposal.

Please consider the following comments:

1) Unique waste streams should be given a new regulatory definition of "unclassified," rather than

grouped under the rubric of "Class A" waste. This "unclassified" group should be defined to

include all kinds, volumes, and concentrations of waste not explicitly covered in the "Final

Environmental Impact Statement on 10 CFR Part 61 Licensing Requirements for Land Disposal

of Radioactive Waste," NUREG-0945, 1982. For all such waste streams, a scientifically

defensible site-specific performance assessment demonstrating compliance with the performance

objectives of 10 CFR Part 61 subpart C must be required prior to disposal in a near-surface

facility. Significant quantities of depleted uranium would fall into this "unclassified" category.

2) Uranium waste streams resulting from the reprocessing of spent nuclear fuel must fall under the

"unclassified" rubric and must be specifically prohibited from near-surface disposal pending sitespecific analysis.

3) At the workshop held in Salt Lake City on this topic, several participants remarked that significant

quantities of depleted uranium are materially different than waste that currently falls under the

"Class A" rubric. For example, Dr. David Kocher, from SENES Oak Ridge, said, "It's increasingly

clear that DU really is a different beast in the following way. I think everybody in this room would

admit that if DU were submitted to waste classification in the same way that other stuff was 30

years ago, it's not Class A waste."1 He went on to say that it's not really Class C waste, either,

since Class C wastes were conceived to be small in volume. He concluded that significant

quantities of depleted uranium cannot be adequately covered by the current classification system.

See NRC transcript at http://www.nrc.gov/about-nrc/regulatory/ruleinaking/potential-rulemaking/uwstreams/workshop-2-transcripts-day2.pdf; p. 188

October 30, 2009 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration, U.S. Nuclear Regulatory Commission 

Mail Stop TWB 5B01 M, Washington, DC 20555-0001 

Reference 10: NRC-2009-0257; Federal Register published June 24, 2009. See page 30175. 

Submitted online at http://www.regu/ations.gov 

To Whom it May Concern: 

I am writing on behalf of the Health Environment Alliance of Utah (HEAL Utah) and our supporters to 

express several concerns and suggestions regarding your proposed rulemaking related to the safe 

disposal of depleted uranium. 

HEAL Utah is a public interest group dedicated to protecting public health that advocates on nuclear 

power, nuclear waste, and toxic waste issues. HEAL Utah is supported by nearly 600 active 

contributing members and maintains an email distribution list of over 4,000. We have worked on 

many issues involving radioactive waste disposal in Utah, including the disposal of foreign nuclear 

waste, Class Band C nuclear waste, waste from the Fernald, Ohio, cleanup, and the high-level 

waste Private Fuel Storage (PFS) proposal. 

Please consider the following comments: 

1) Unique waste streams should be given a new regulatory definition of "unclassified," rather than 

grouped under the rubric of "Class A" waste. This "unclassified" group shQuld be defined to 

include all kinds, volumes, and concentrations of waste not explicitly covered in the "Final 

Environmental Impact Statement on 10 CFR Part 61 Licensing Requirements for Land Disposal 

of Radioactive Waste," NUREG-0945, 1982. For all such waste streams, ascientifically 

defensible site-specific performance assessment demonstrating compliance with the performance 

objectives of 10 CFR Part 61 subpart C must be required prior to disposal in a near-surface 

facility. Significant quantities of depleted uranium would fall into this "unclassified" category. 

2) Uranium waste streams resulting from the reprocessing of spent nuclear fuel must fall under the 

"unclassified" rubric and must be specifically prohibited from near-surface disposal pending sitespecific analysis. 

3) At the workshop held in Salt Lake City on this topic, several partiCipants remarked that significant 

quantities of depleted uranium are materially different than waste that currently falls under the 

"Class A" rubric. For example, Dr. David Kocher, from SENES Oak Ridge, said, "It's increasingly 

clear that DU really is a different beast in the following way. I think everybody in this room would 

admit that if DU were submitted to waste classification in the same way that other stuff was 30 

years ago, it's not Class A waste.,,1 He went on to say that it's not really Class C waste, either, 

since Class C wastes were conceived to be small in volume. He concluded that significant 

quantities of depleted uranium cannot be adequately covered by the current classification system. 

I See NRC transcript at http://www.nrc.gov/about-nrc/regulatOly/rulemaking/potcntial-rulcmaking/uwstrcams/workshop-2-transcripts-day2.pdf: p. 188 
4) Federal regulations define Class A waste as presenting "an acceptable hazard" to an intruder

after 100 years (see 10 CFR § 61.7 Concepts.) Significant quantities of depleted uranium will

continue to present a significant hazard far beyond 100 years. On its face, then, depleted

uranium cannot be considered a "Class A" waste under the existing Federal definition and

framework.

5) The time period of 'performance for a performance analysis on "unclassified" waste streams,

including significant quantities of depleted uranium, should be to the time of peak activity or the

time of peak dose. The state of Texas has adopted this approach in their rules. See Texas Rule

§336.709 - Technical and Environmental Analyses. The NRC reviewed this rule without

comment in 2003. If the NRC artificially limits the period of performance, agreement states

should be able to require a longer period of performance.

6) If the NRC defines a period of performance shorter than the time of peak dose or peak activity,

this would represent a significant change to the Federal radiation protection standards. See 10

CFR § 61.41 Protection of the general population from releases of radioactivity. Such a

change would necessitate that the current rulemaking be abandoned and two new rulemaking

procedures be conducted in tandem, one to deal with depleted uranium and unique waste

streams, and another to deal with changes to Subpart C radiation protection standards.

7) Currently, Federal standards limit organ dosea to 25 millirems (mrem) annually. See 10 CFR §

61.41 Protection of the general population from releases of radioactivity. The NRC staff

analysis on depleted uranium released in October of 2008 (part of SECY-08-0147) did not

adequately calculate doses to organs. In other words, doses to organs were only considered

insofar as they contributed to an overall body dose. In this framework used by NRC staff, an

organ could receive greater than a 25 mrem dose in a year, yet the performance objective as

measured to the whole-body would still be under 25 mrem per year. As a result, the NRC staff

analysis on depleted uranium likely under-estimated the hazard of depleted uranium buried in a

near-surface disposal facility.

8) NRC staff's analysis in SECY-08-0147 suffers another major flaw when it comes to considering

changes in climate. For instance, NRC staff assumed that the near-surface disposal facility

would continue to function as designed over the period of performance, even over a period of one

million years. Design features such as waste stability, cover, and disposal depth of depleted

uranium were assumed to remain constant. This approach directly contradicts staff guidance

provided in SECY-96-103. In that 1996 memo, Executive Director for Operations James M.

Taylor writes, "Significant uncertainty exists in predicting long-term design life and degradation

rates of engineered barriers. Staff recommends that typical engineered barriers be assumed to be

physically degraded after 500 years after site closure." Such an assumption as articulated in

1996 appears consistent with the overall regulatory framework for near-surface disposal facilities,

namely that they should present "an acceptable hazard" after 100 years and that the site should

not require "active maintenance" following closure. That NRC staff would subsequently prepare

an analysis in 2008 that assumes a near-surface disposal site continues to function as designed

in perpetuity defies logic and good sense. As a result, the NRC staff's October 2008 analysis

likely underestimates the hazard associated with depleted uranium disposed in a near-surface

facility.

9) NRC staff's SECY-08-0147 was likewise flawed because it did not take into account dramatic

changes in climate that can take place over the timeframes examined (thousands to millions of

years). Dr. Peter Burns from Notre Dame University observed the following: "It's kind of funny in

4) Federal regulations define Class A waste as presenting "an acceptable hazard" to an intruder 

after 100 years (see 10 CFR § 61.7 Concepts.) Significant quantities of depleted uranium will 

continue to present a significant hazard far beyond 100 years. On its face, then, depleted 

uranium cannot be considered a "Class A" waste under the existing Federal definition and 

framework. 

5) The time period of 'performance for a performance analysis on "unclassified" waste streams, 

including significant quantities of depleted uranium, should be to the time of peak activity or the 

time of peak dose. The state of Texas has adopted this approach in their rules. See Texas Rule 

§336.709 - Technical and Environmental Analyses. The NRC reviewed this rule without 

comment in 2003. If the NRC artificially limits the period of performance, agreement states 

should be able to require a longer period of performance. 

6) If the NRC defines a period of performance shorter than the time of peak dose or peak activity, 

this would represent a significant change to the Federal radiation protection standards. See 10 

CFR § 61.41 Protection of the general population from releases of radioactivity. Such a 

change would necessitate that the current rulemaking be abandoned and two new rulemaking 

procedures be conducted in tandem, one to deal with depleted uranium and unique waste 

streams, and another to deal with changes to Subpart C radiation protection standards. 

7) Currently, Federal standards limit organ dosea to 25 millirems (mrem) annually. See 10 CFR § 

61.41 Protection of the general population from releases of radioactivity. The NRC staff 

analysis on depleted uranium released in October of 2008 (part of SECY-08-0147) did not 

adequately calculate doses to organs. In other words, doses to organs were only considered 

insofar as they contributed to an overall body dose. In this framework used by NRC staff, an 

organ could receive greater than a 25 mrem dose in a year, yet the performance objective as 

measured to the whole-body would still be under 25 mrem per year. As a result, the NRC staff 

analysis on depleted uranium likely under-estimated the hazard of depleted uranium buried in a 

near-surface disposal facility. 

8) NRC staff's analysis in SECY-08-0147 suffers another major flaw when it comes to considering 

changes in climate. For instance, NRC staff assumed that the near-surface disposal facility 

would continue to function as designed over the period of performance, even over a period of one 

million years. Design features such as waste stability, cover, and disposal depth of depleted 

uranium were assumed to remain constant. This approach directly contradicts staff guidance 

provided in SECY-96-1 03. In that 1996 memo, Executive Director for Operations James M. 

Taylor writes, "Significant uncertainty exists in predicting long-term design life and degradation 

rates of engineered barriers. Staff recommends that typical engineered barriers be assumed to be 

physically degraded after 500 years after site closure." Such an assumption as articulated in 

1996 appears consistent with the overall regulatory framework for near-surface disposal facilities, 

namely that they should present "an acceptable hazard" after 100 years and that the site should 

not require "active maintenance" following closure. That NRC staff would subsequently prepare 

an analysis in 2008 that assumes a near-surface disposal site continues to function as designed 

in perpetuity defies logic and good sense. As a result, the NRC staff's October 2008 analysis 

likely underestimates the hazard associated with depleted uranium disposed in a near-surface 

facility. 

9) NRC staff's SECY-08-0147 was likewise flawed because it did not take into account dramatic 

changes in climate that can take place over the timeframes examined (thousands to millions of 

years). Dr. Peter Burns from Notre Dame University observed the following: "It's kind of funny in 
a way to listen to people say it's dumb to model a million years. I agree. It's probably almost as

dumb to model 10,000 years in reality because the climate change cycles etc. that we talk about

in a million years they all happen in 10,000 years as well. In 10,000 years we could well be under

1,500 feet of water or some ludicrous thing here as we're in another glacial period and we have a

pluvial lake on top of Salt Lake City and who knows? 2

" Defensible modeling of impacts requires

that assumptions be made about the climate. But over long time periods, from 10,000 to 1 million

years, the climate can dramatically change. Such dramatic changes in climate may actually

preclude defensible modeling over such long timeframes nearly everywhere at the Earth's

surface. Therefore, the long-lived hazard posed by significant quantities of depleted uranium may

naturally preclude near-surface disposal nearly everywhere at the Earth's surface.

10) Federal rules require that areas be avoided where surface geologic processes "may preclude

defensible modeling and prediction of long-term impacts." See 10 CFR § 61.50 Disposal site

suitability requirements for land disposal. HEAL Utah hereby incorporates comments

submitted by Dr. Steve Nelson, Dr. Charles G. Oviatt, and Dr. Summer B. Rupper on the present

rulemaking that indicate a nearly 100% likelihood that one such near-surface disposal facility in

Utah will be inundated and washed away by rising lake levels sometime in the next 100,000

years. Such a finding should preclude this specific facility and any other similarly-susceptible

facilities from receiving significant quantities of depleted uranium for disposal. Dr. Peter Burns

from Notre Dame University appeared to concur in the following comment: "I was outside at lunch

and I was looking up at that hill over there and being a geologist I could easily figure out what the

erosion rate is on that hill and I could figure out okay so we're going to have some climate change

and ... I could bury the depleted uranium in a location where it's fine for 10,000 years but at

15,000 years it's exposed and gone. So you absolutely have to have a consideration of peak

dose, You can't put it somewhere where you know that in 20,000 years or whatever it will not be

there.3'

11) The way the Commission has framed the proposed depleted uranium rulemaking is artificially

narrow and appears to point to a pre-determined outcome. Dr. Kocher seemed to get at this

when he noted, "A comment that has kind of opened my eyes here is that there seems to be an

implicit understanding here that we're developing a rule for near surface disposal and I'm pretty

convinced from what I've heard that the NRC should open the possibility that near surface

disposal may simply not be appropriate for this stuff, for whatever reason. I mean it's conceivable

that you might reach such a decision.4" We believe that any proposed rulemaking should allow

for the possibility of a requirement that significant quantities of depleted uranium be disposed in

deep geologic disposal.

12) If uranium were defined as a transuranic element, then significant quantities of depleted

uranium would require deep geologic disposal based upon the radiological properties of uranium.

Transuranic wastes are currently disposed thousands of feet underground at the Waste Isolation

Pilot Plant (WIPP) in New Mexico. We believe that, based on its physical properties and toxicity,

significant quantities of depleted uranium must be treated under the transuranic waste regulatory

framework, if disposed as a waste.

2 See NRC transcript at http://www.nrc.gov/about-nrc/regulatory/rule-naking/notential-rulemakinig/Lwstream s/workshop-2-transcripts-dayl.pd page 226

3 See NRC transcript at http://www.nrc.gov/about-nrc/ireulatory/rule-nakinc/potential-rulemaking/uwstream s/workshop-2-transcripts-day 1.pdf, page 225

4 See NRC transcript at http://www.nrc.gov/about-nrc/regulatory/rulemaking/potential-rulemaking/uwstreams/workshop-2-transcripts-day l.pd page 239

a way to listen to people say it's dumb to model a million years. I agree. It's probably almost as 

dumb to model 10,000 years in reality because the climate change cycles etc. that we talk about 

in a million years they all happen in 10,000 years as well. In 10,000 years we could well be under 

1,500 feet of water or some ludicrous thing here as we're in another glacial period and we have a 

pluvial lake on top of Salt Lake City and who knows?2" Defensible modeling of impacts requires 

that assumptions be made about the climate. But over long time periods, from 1 0,000 to 1 million 

years, the climate can dramatically change. Such dramatic changes in climate may actually 

preclude defensible modeling over such long timeframes nearly everywhere at the Earth's 

surface. Therefore, the long-lived hazard posed by significant quantities of depleted uranium may 

naturally preclude near-surface disposal nearly everywhere at the Earth's surface. 

10) Federal rules require that areas be avoided where surface geologic processes "may preclude 

defensible modeling and prediction of long-term impacts." See 10 CFR § 61.50 Disposal site 

suitability requirements for land disposal. HEAL Utah hereby incorporates comments 

submitted by Dr. Steve Nelson, Dr. Charles G. Oviatt, and Dr. Summer B. Rupper on the present 

rulemaking that indicate a nearly 100% likelihood that one such near-surface disposal facility in 

Utah will be inundated and washed away by rising lake levels sometime in the next 100,000 

years. Such a finding should preclude this specific facility and any other similarly-susceptible 

facilities from receiving significant quantities of depleted uranium for disposal. Dr. Peter Burns 

from Notre Dame University appeared to concur in the following comment: "I was outside at lunch 

and I was looking up at that hill over there and being a geologist I could easily figure out what the 

erosion rate is on that hill and I could figure out okay so we're going to have some climate change 

and ... I could bury the depleted uranium in a location where it's fine for 10,000 years but at 

15,000 years it's exposed and gone. So you absolutely have to have a consideration of peak 

dose, You can't put it somewhere where you know that in 20,000 years or whatever it will not be 

there.3

" 

11) The way the Commission has framed the proposed depleted uranium rulemaking is artificially 

narrow and appears to point to a pre-determined outcome. Dr. Kocher seemed to get at this 

when he noted, "A comment that has kind of opened my eyes here is that there seems to be an 

implicit understanding here that we're developing a rule for near surface disposal and I'm pretty 

convinced from what I've heard that the NRC should open the possibility that near surface 

disposal may simply not be appropriate for this stuff, for whatever reason. I mean it's conceivable 

that you might reach such a decision. 4

" We believe that any proposed rulemaking should allow 

for the possibility of a requirement that significant quantities of depleted uranium be disposed in 

deep geologic disposal. 

12) If uranium were defined as a transuranic element, then significant quantities of depleted 

uranium would require deep geologic disposal based upon the radiological properties of uranium. 

Transuranic wastes are currently disposed thousands of feet underground at the Waste Isolation 

Pilot Plant (WIPP) in New Mexico. We believe that, based on its physical properties and toxicity, 

significant quantities of depleted uranium must be treated under the transuranic waste regulatory 

framework, if disposed as a waste .. 

2 See NRC transcript at http;llwww.nrc.gov/about-nrc/regulatory/rulemaking/potential-rulemaking/uwstreams/workshop-2-transcripts-day I.pdf, page 226 

3 See NRC transcript at http;llwww.nrc.gov/about-nrc/regulatory/rulemaking/potentiaI-rulemaking/uwstreams/workshop-2-transcripts-day I.pdf, page 225 

4 See NRC transcript at http;llwww.nrc.gov/about-nrc/regulatory/rulemaking/potentiaI-rulemaking/uwstreams/workshop-2-transcripts-day1.pdf: page 239 
13) Chemical toxicity of significant quantities of depleted uranium must be considered in the

required site-specific performance analysis. Dr. Kocher raised this issue: "The issue I want to

raise is about chemical toxicity of depleted uranium. One of the frequently asked questions in the

communication plan raised this issue and basically the answer was the NRC is not going to deal

with this. I would suggest that's not an enlightened approach. It may turn out that chemical toxicity

is not more important than radiation dose from depleted uranium, but it may not, the opposite may

be true."5 If the NRC does not require an analysis of the chemical toxicity associated with

depleted uranium, then any such analysis could grossly underestimate health impacts associated

with depleted uranium disposal in a near-surface facility. The most recent toxicological

information on depleted uranium must be included in such analyses. If the NRC does not conduct

this analysis, Agreement States should require this type of analysis prior to disposal of significant

quantities of depleted uranium.

14) The performance assessment must consider the physical and chemical form of the depleted

uranium, and whether the disposal facility constitutes a reducing or oxidizing environment.

15) Compliance with Environmental Protection Agency (EPA) standards for airborne releases of

radionuclides must also be demonstrated over the relevant timeframes during which significant

quantities of depleted uranium remain hazardous.

16) The performance assessment must include an on-site intruder scenario in order to

adequately account for the radiological impacts to an inadvertent intruder; Federal rules require

as much: "Design, operation, and closure of the land disposal facility must ensure protection of

any individual inadvertently intruding into the disposal site and occupying the site or contacting

the waste at any time after active institutional controls over the disposal site are removed." See

10 CFR § 61.42 Protection of individuals from inadvertent intrusion. The inadvertent intruder

should be protected at a level of 25 mrem per year.

17) As some point in the next 10,000 years it is perfectly plausible that an attempt will be made

to recover energy-producing material from our current waste sites. It is difficult to model this type

of intrusion in a standard risk assessment, but that does not mean that the risk of deliberate

intrusion should be ignored during the rulemaking.

18) The new proposed rule for depleted uranium must require that a site be owned in perpetuity

by either a State or Federal agency, prior to any proposed disposal of significant quantities of

depleted uranium in a near-surface facility. Because depleted uranium will remain hazardous

over timeframes that companies cannot be expected to survive (thousands to millions of years),

and near-surface disposal facilities can reasonably be expected to degrade after 500 years, a

viable long-term custodian must be identified who will actively manage and repair the disposal

site and its hazardous constituents. As a side-note, this new requirement would be in direct

conflict with current regulation, which state, in part: "The analyses must provide reasonable

assurance that there will not be a need for ongoing active maintenance of the disposal site

following closure." See 10 CFR § 61.13 Technical analyses.

19) The performance assessment must examine the effects of all decay-chain radionuclides

resulting from depleted uranium, most especially including radium-226 and radon gas. A radonflux standard is not sufficient to ensure performance objectives are met.

5 See NRC transcript at http://www.nrc.gov/about-nrc/regulatorv/rulemaking/potential-rulernaking/uwstrcams/workshop-2-transcripts-dav2.pdf; page 263

13) Chemical toxicity of significant quantities of depleted uranium must be considered in the 

required site-specific performance analysis. Dr. Kocher raised this issue: "The issue I want to 

raise is about chemical toxicity of depleted uranium. One of the frequently asked questions in the 

communication plan raised this issue and basically the answer was the NRC is not going to deal 

with this. I would suggest that's not an enlightened approach. It may turn out that chemical toxicity 

is not more important than radiation dose from depleted uranium, but it may not, the opposite may 

be true.,,5 If the NRC does not require an analysis of the chemical toxicity associated with 

depleted uranium, then any such analysis could grossly underestimate health impacts associated 

with depleted uranium disposal in a near-surface facility. The most recent toxicological 

information on depleted uranium must be included in such analyses. If the NRC does not conduct 

this analysis, Agreement States should require this type of analysis prior to disposal of significant 

quantities of depleted uranium. 

14) The performance assessment must consider the physical and chemical form of the depleted 

uranium, and whether the disposal facility constitutes a reducing or oxidizing environment. 

15) Compliance with Environmental Protection Agency (EPA) standards for airborne releases of 

radionuclides must also be demonstrated over the relevant timeframes during which significant 

quantities of depleted uranium remain hazardous. 

16) The performance assessment must include an on-site intruder scenario in order to 

. adequately account for the radiological impacts to an inadvertent intruder; Federal rules require 

as much: "Design, operation, and closure of the land disposal facility must ensure protection of 

any individual inadvertently intruding into the disposal site and occupying the site or contacting 

the waste at any time after active institutional controls over the disposal site are removed." See 

10 CFR § 61.42 Protection of individuals from inadvertent intrusion. The inadvertent intruder 

should be protected at a level of 25 mrem per year. 

17) As some point in the next 10,000 years it is perfectly plausible that an attempt will be made 

to recover energy-producing material from our current waste sites. It is difficult to model this type 

of intrusion in a standard risk assessment, but that does not mean that the risk of deliberate 

intrusion should be ignored during the rulemaking. 

18) The new proposed rule for depleted uranium must require that a site be owned in perpetuity 

by either a State or Federal agency, prior to any proposed disposal of significant quantities of 

depleted uranium in a near-surface facility. Because depleted uranium will remain hazardous 

over timeframes that companies cannot be expected to survive (thousands to millions of years), 

and near-surface disposal facilities can reasonably be expected to degrade after 500 years, a 

viable long-term custodian must be identified who will actively manage and repair the disposal 

site and its hazardous constituents. As a side-note, this new requirement would be in direct 

conflict with current regulation, which state, in part: "The analyses must provide reasonable 

assurance that there will not be a need for ongoing active maintenance of the disposal site 

following closure." See 10 CFR § 61.13 Technical analyses. 

19) The performance assessment must examine the effects of all decay-chain radionuclides 

resulting from depleted uranium, most especially including radium-226 and radon gas. A radonflux standard is not sufficient to ensure performance objectives are met. 

5 See NRC transcript at http://www.nrc.gov/about-nrc/regulatOly/rulemaking/potential-rulemaking/uwstreams/workshop-2-transcripts-day2.pdf: page 263 
20) Permitting the disposal of significant quantities of depleted uranium, as the proposed rule

does, constitutes a major Federal action and triggers requirements under the National

Environmental Policy Act (NEPA). An Environmental Impact Statement (EIS) must be conducted

and allow for an examination of all relevant alternatives for depleted uranium management,

including deep geologic disposal and monitored retrievable storage, among others.

21) Colloidal transport of radionuclides must be considered in a site-specific performance

assessment.

22) Most radioactive material cleanups today are the result of bad technological and policy

decisions made in the last 50-70 years. It is highly likely that the DU disposal being done now will

seem inappropriate within the next few centuries. Thus, retrievability and the possibility of future

site cleanups should be considered in any site-specific analysis.

Please feel free to contact me if you have any questions or wish to speak with me further.

Sincerely,

Christopher Thomas

Policy Director, HEAL Utah

801-355-5055

20) Permitting the disposal of significant quantities of depleted uranium, as the proposed rule 

does, constitutes a major Federal action and triggers requirements under the National 

Environmental Policy Act (NEPA). An Environmental Impact Statement (EIS) must be conducted 

and allow for an examination of all relevant alternatives for depleted uranium management, 

including deep geologic disposal and monitored retrievable storage, among others. 

21) Colloidal transport of radionuclides must be considered in a site-specific performance 

assessment. 

22) Most radioactive material cleanups today are the result of bad technological and policy 

decisions made in the last 50-70 years. It is highly likely that the DU disposal being done now will 

seem inappropriate within the next few centuries. Thus, retrievability and the possibility of future 

site cleanups should be considered in any site-specific analysis. 

Please feel free to contact me if you have any questions or wish to speak with me further. 

Sincerely, 

Christopher Thomas 

Policy Director, HEAL Utah 

801-355-5055 
WASTE ,COINTROL

SPECIALI'STS'LLC4

October 30, 2009

U.S. Nuclear Regulatory Commission

Chief, Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration

Mail Stop TWB 5B01M

Washington, DC 20555-0001

References: (1) Radioactive Material License No. R04100 C

(2) Letter from William P. Dornsife, P.E. (WCS), to Dale Klein, Ph.D.

(NRC), re "Information for Consideration by the Commission at

Scheduled 04/17/09 Briefing on Low-Level Radioactive Waste", dated

April 6, 2009

(3) Federal Register, Volume 74, Number 120, pp. 30175-30170,

published on June 24, 2009

Subject: Comments Regarding Potential Rulemaking For Safe Disposal Of Unique

Waste Streams Including Significant Quantities Of Depleted Uranium

Dear Sir or Madam:

Waste Control Specialists LLC (WCS) has already submitted comments for consideration by

the Commission pertaining to depleted uranium as well as other topics on Low-Level

Radioactive Waste (LLW) policy (Reference 2). We were invited and participated in

subsequent public workshops that were held on this matter in Rockville, Maryland, and Salt

Lake City, Utah. WCS today respectfully submits additional comments on the subject

rulemaking initiative for disposal of unique waste streams, including significant quantities of

depleted uranium, as requested by Reference 3. These comments are intended to reinforce and

supplement the previous comments in Reference 2 and those provided as a participant in the

workshops.

WCS received a final license (Reference 1) to dispose of LLW from the Texas Commission

on Environmental Quality (TCEQ) on September 10, 2009. This is the only disposal license

issued in the U.S. that was fully reviewed under 10 CFR Part 61 requirements and technical

standards. The performance assessment (described below) that supported the issuance of the

license considered significant depleted uranium waste streams and demonstrated that human

health and the environment would be protected not just for the next 1,000 years, but for

hundreds of thousands of years into the future. However, TCEQ was reluctant to authorize

disposal of these significant depleted uranium waste streams while NRC is considering

Corporate

5430 LBJ Freeway, Ste. 1700 Facility

Three Lincoln Centre P.O. Box 1129

Dallas, TX 75240 Andrews, TX 79714

Ph. 972.715.9800 Ph. 888.789.2783

Fx. 972.448.1419 Fx. 505.394.3427

1._3yd:f oy

October 30, 2009 

u.s. Nuclear Regulatory Commission 

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

Office of Administration 

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References: (1) Radioactive Material License No. R041 00 

Subject: 

(2) Letter from William P. Dornsife, P.E. (WCS), to Dale Klein, Ph.D. 

(NRC), re "Information for Consideration by the Commission at 

Scheduled 04117/09 Briefing on Low-Level Radioactive Waste", dated 

April 6, 2009 

(3) Federal Register, Volume 74, Number 120, pp. 30175-30170, 

published on June 24, 2009 

Comments Regarding Potential Rulemaking For Safe Disposal Of Unique 

Waste Streams Including Significant Quantities Of Depleted Uranium 

Dear Sir or Madam: 

Waste Control Specialists LLC (WCS) has already submitted comments for consideration by 

the Commission pertaining to depleted uranium as well as other topics on Low-Level 

Radioactive Waste (LL W) policy (Reference 2). We were invited and participated in 

subsequent public workshops that were held on this matter in Rockville, Maryland, and Salt 

Lake City, Utah. WCS today respectfully submits additional comments on the subject 

rulemaking initiative for disposal of unique waste streams, including significant quantities of 

depleted uranium, as requested by Reference 3. These comments are intended to reinforce and 

supplement the previous comments in Reference 2 and those provided as a participant in the 

workshops. 

WCS received a final license (Reference 1) to dispose of LL W from the Texas Commission 

on Environmental Quality (TCEQ) on September 10,2009. This is the only disposal license 

issued in the U.S. that was fully reviewed under 10 CFR Part 61 requirements and technical 

standards. The performance assessment (described below) that supported the issuance of the 

license considered significant depleted uranium waste streams and demonstrated that human 

health and the environment would be protected not just for the next 1,000 years, but for 

hundreds of thousands of years into the future. However, TCEQ was reluctant to authorize 

disposal of these significant depleted uramum waste streams while NRC is considering 

6 u,VSJ::- fJ~/J~~..&ze ?-~l>s~ pZJ4-;?J "'2:> 

Corporate 

5430 LBJ Freeway, Ste" 1700 

Three Lincoln Centre 

Dallas, TX 75240 

Ph. 972.715.9800 

Fx. 972.448.1419 

Facility 

P.O. Box 1129 

Andrews, TX 79714 

Ph. 888.789.2783 

~ ~(J- &l~ (eSf1~) t, yC?dat/ clf7) 
Rulemaking and Directives Branch

October 30, 2009

Page 2 of 5

rulemaking in this regard. As a result, the final LLW disposal license that TCEQ issued to

WCS allows for the disposal of only certain limited waste streams of depleted uranium.

WCS believes that the technical issues associated with the disposal of significant quantities of

depleted uranium, as identified in the documentation associated with this potential rulemaking

and discussed in detail at the public workshops, have been fully resolved for its facility in

Andrews County, Texas. We therefore encourage NRC to proceed expeditiously with this

rulemaking, so that Texas as an Agreement State can promptly establish conforming

regulations, thus allowing WCS to pursue a license amendment to authorize the disposal of

depleted uranium at its facility.

More importantly however, in the interim, WCS encourages NRC to work with its Agreement

States to ensure consistent nationwide implementation of either (1) existing regulations or (2)

a uniform depleted uranium disposal ban pending completion of the NRC's rulemaking and

issuance of subsequent Agreement State conforming regulations and issuance of appropriate

conforming license amendments by individual Agreement States to their licensees.

GENERAL COMMENTS

As the Commission contemplates moving forward with a rulemaking on this topic, significant

effort will be needed to understand the regulatory philosophy of each of the Agreement States

that currently host radioactive waste disposal facilities. NRC needs to ensure that the rule

addresses potential differences in regulatory philosophies by requiring strict compatibility

with the rules that are promulgated and strong oversight on uniform implementation of

guidance. As such, WCS strongly encourages NRC to provide specific directions to the

licensed community on how to proceed in the interim. Specifically, NRC should provide

written guidance on how licensees and Agreement States should proceed to determine

whether or not a performance assessment is sufficient to allow for the timely disposal of

significant quantities of depleted uranium until such time rulemakings by both NRC and

Agreement States are finalized.

SPECIFIC COMMENTS

II. Issues With Disposal Of Unique Waste Streams

Issue II-1. Definition of Unique Waste Streams

WCS Comment: WCS does not believe that a definition for a unique waste stream is needed.

However, NRC should evaluate all other waste streams assessed in the Final Environmental

Impact Statement on 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive

Rulemaking and Directives Branch 

October 30,2009 

Page 2 of5 

rulemaking in this regard. As a result, the final LL W disposal license that TCEQ issued to 

WCS allows for the disposal of only certain limited waste streams of depleted uranium. 

WCS believes that the technical issues associated with the disposal of significant quantities of 

depleted uranium, as identified in the documentation associated with this potential rulemaking 

and discussed in detail at the public workshops, have been fully resolved for its facility in 

Andrews County, Texas. We therefore encourage NRC to proceed expeditiously with this 

rulemaking, so that Texas as an Agreement State can promptly establish conforming 

regulations, thus allowing WCS to pursue a license amendment to authorize the disposal of 

depleted uranium at its facility. 

More importantly however, in the interim, WCS encourages NRC to work with its Agreement 

States to ensure coqsistent nationwide implementation of either (1) existing regulations or (2) 

a uniform depleted uranium disposal ban pending completion of the NRC's rulemaking and 

issuance of subsequent Agreement State conforming regulations and issuance of appropriate 

conforming license amendments by individual Agreement States to their licensees. 

GENERAL COMMENTS 

As the Commission contemplates moving forward with a rulemaking on this topic, significant 

effort will be needed to understand the regulatory philosophy of each of the Agreement States 

that currently host radioactive waste disposal facilities. NRC needs to ensure that the rule . 

. addresses potential differences in regulatory philosophies by requiring strict compatibility 

with the rules that are promulgated and strong oversight on uniform implementation of 

guidance. As such, WCS strongly ericourages NRC to provide specific directions to the 

licensed community on how to proceed in the interim. Specifically, NRC should provide 

written guidance on how licensees and Agreement States should proceed to determine 

whether or not a performance assessment is sufficient to allow for the timely disposal of 

significant quantities of depleted uranium until such time rulemakings by both NRC and 

Agreement States are finalized. 

SPECIFIC COMMENTS 

II. Issues With Disposal Of Unique Waste Streams 

Issue II-I. Definition of Unique Waste Streams 

WCS Comment: WCS does not believe that a definition for a unique waste stream is needed. 

However, NRC should evaluate all other waste streams assessed in the Final Environmental 

Impact Statement on 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive 
Rulemaking and Directives Branch

October 30, 2009

Page 3 of 5

Waste (NUREG-0945) containing long-lived radionuclides to determine if other unique waste

streams exist that may require additional measures to protect public health and the

environment. One such waste stream that should be evaluated is other source material waste

streams that exhibit the same long-term hazards as depleted uranium.

Issue 11-2. Time Period of Performance

WCS Comment: WCS strongly believes that NRC should promulgate a time period of

performance as part of the rulemaking to address the long-term hazards unique to large

quantities of depleted uranium. In defining the time period of performance, NRC is

encouraged to promote environmental fate and transport models that preferably requires a

quantitative and at least qualitative assessment of the impacts to human health and the

environment. Given that the hazards associated with depleted uranium do not peak until long

after 10,000 years, the time period of performance should be at least 10,000 years and include

additional quantitative or qualitative analysis or requirements to address the period beyond.

WCS encourages NRC to consider the philosophy used by the TCEQ to license' WCS' LLW

disposal facility in Andrews County, Texas. In its licensing review, TCEQ regulations require

a minimum period of performance of 1,000 years after site closure or the period where peak

dose occurs, whichever is longer. Under these provisions, WCS was required to demonstrate

that the site characteristics were suitably analyzed for a period of 50,000 years, inclusive of

climate changes (specifically assuming twice the rainfall), and included in the performance

assessment a requirement to evaluate peak dose to infinity. Accordingly, WCS believes that it

has demonstrated that its site in Andrews County, Texas, is protective of the long-lived

hazards posed by large quantities of depleted uranium (including waste from deconversion

processes) to public health and the environment. WCS believes that the approach taken in

Texas should serve as a model for the nation.

Issue 11-3. Exposure Scenarios for a Site-Specific Analysis

WCS Comment: WCS encourages NRC to require consideration of generic exposure

scenarios, such as an intruder scenario, in the rulemaking. WCS again requests NRC to

evaluate the licensing process used by TCEQ to license our facility in Andrews County,

Texas. During this review, it was determined that disposal of depleted uranium would require

placement in reinforced concrete canisters. Use of grout was also required to ensure

stabilization of depleted uranium within the concrete canisters. Additionally, the design

On September 10, 2009, TCEQ issued Radioactive Material License No. R04 100 to conditionally authorize

land disposal of low-level radioactive wastes by WCS.

2 See Title 30 of the Texas Administrative Code (TAC), Chapter 337.709.

Rulemaking and Directives Branch 

October 30, 2009 

Page 3 of 5 

Waste (NUREG-0945) containing long-lived radionuclides to determine if other unique waste 

streams exist that may require additional measures to protect public health and the 

environment. One such waste stream that should be evaluated is other source material waste 

streams that exhibit the same long-term hazards as depleted uranium. 

Issue IJ-2. Time Period of Performance 

WCS Comment: WCS strongly believes that NRC should promulgate a time period of 

performance as part of the rule making to address the long-term hazards unique to large 

quantities of depleted uranium. In defining the time period of performance, NRC is 

encouraged to promote environmental fate and transport models that preferably requires a 

quantitative and at least qualitative assessment of the impacts to human health and the 

environment. Given that the hazards associated with depleted uranium do not peak until long 

after 10,000 years, the time period of performance should be at least 10,000 years and include 

additional quantitative or qualitative analysis or requirements to address the period beyond. 

WCS encourages NRC to consider the philosophy used by the TCEQ to licensel WCS' LLW 

disposal facility in Andrews Count1

, Texas. In its licensing review, TCEQ regulations require 

a minimum period of performance of 1,000 years after site closure or the period where peak 

dose occurs, whichever is longer. Under these provisions, WCS was required to demonstrate 

that the site characteristics were suitably analyzed for a period of 50,000 years, inclusive of 

climate changes (specifically assuming twice the rainfall), and included in the performance 

assessment a requirement to evaluate peak dose to infinity. Accordingly, WCS believes that it 

has demonstrated that its site in Andrews County, Texas, is protective of the long-lived 

hazards posed by large quantities of depleted uranium (including waste from deconversion 

processes) to public health and the environment. WCS believes that the approach taken in 

Texas should serve as a model for the nation. 

Issue IJ-3. Exposure Scenarios for a Site-Specific Analysis 

WCS Comment: WCS encourages NRC to require consideration of generic exposure 

scenarios, such as an intruder scenario, in the rulemaking. WCS again requests NRC to 

evaluate the licensing process used by TCEQ to license our facility in Andrews County, 

Texas. During this review, it was determined that disposal of depleted uranium would require 

placement in reinforced concrete canisters. Use of grout was also required to ensure 

stabilization of depleted uranium within the concrete canisters. Additionally, the design 

I On September 10,2009, TCEQ issued Radioactive Material License No. R04100 to conditionally authorize 

land disposal ofIow-level radioactive wastes by WCS. 

2 See Title 30 of the Texas Administrative Code (TAC), Chapter 337.709. 
Rulemaking and Directives Branch

October 30, 2009

Page 4 of 5

approved for WCS includes an additional concrete liner around the disposal cell as well as a

minimum cover thickness of about 10 meters. These measures were specifically required to

address the inadvertent intruder scenario.

While WCS encourages NRC to specify in the rulemaking generic exposure scenarios as part

of a performance assessment, we recognize that additional information, such as determining

fate and transport modeling parameters, should be addressed in regulatory guidance and not

rulemaking. In developing regulatory guidance, NRC should build upon its experience related

to development of radiological exposure scenarios that have been used to support radiological

dose assessments in support of past rulemaking and license reviews involving the License

Termination Rule (10 CFR Part 20, Subpart E).

III. ISSUES WITH DISPOSAL OF SIGNIFICANT QUANTITIES OF DEPLETED

URANIUM

Issue III-1. Definition of Significant Quantities

WCS Comment: We encourage NRC to define "significant quantities" in the rulemaking in a

graded and risk-informed manner. For example, WCS is authorized in Radioactive Material

License R04100 to dispose of depleted uranium, excluding depleted uranium from

deconversion of UF6, at concentrations less than 10 nCi/g. As previously mentioned, WCS

demonstrated in a performance assessment that depleted uranium in large quantities and much

larger concentrations could be safely disposed of for a time period much longer than 10,000

years into the future. TCEQ elected to pose this additional concentration-based restriction of

10 nCi/g limiting waste form of depleted uranium authorized for disposal until such time that

NRC and then the State complete rulemakings. However, WCS believes conceptually that a

similar trigger level could be useful in defining a threshold requiring more rigorous

requirements that may be needed to protect public health and the environment from the

hazards associated with depleted uranium.

Issue 111-2. Time Period of Performance for a Site-Specific Analysis

See WCS comments pertaining to Issue 11-2. Time Period of Performance.

Issue 111-3. Exposure Scenario (s) for a Site-Specific Analysis

See WCS comments pertaining to Issue 11-3. Exposure Scenarios for a Site-Specific Analysis.

Rulemaking and Directives Branch 

October 30, 2009 

Page 4 of5 

approved for WCS includes an additional concrete liner around the disposal cell as well as a 

minimum cover thickness of about 10 meters. These measures were specifically required to 

address the inadvertent intruder scenario. 

While WCS encourages NRC to specify in the rulemaking generic exposure scenarios as part 

of a performance assessment, we recognize that additional information, such as determining 

fate and transport modeling parameters, should be addressed in regulatory guidance and not 

rulemaking. In developing regulatory guidance, NRC should build upon its experience related 

to development of radiological exposure scenarios that have been used to support radiological 

dose assessments in support of past rulemaking and license reviews involving the License 

Termination Rule (10 CFR Part 20, Subpart E). 

III. ISSUES WITH DISPOSAL OF SIGNIFICANT QUANTITIES OF DEPLETED 

URANIUM 

Issue Ill-l. Definition of Significant Quantities 

WCS Comment: We encourage NRC to define "significant quantities" in the rulemaking in a 

graded and risk-informed manner. For example, WCS is authorized in Radioactive Material 

License R04100 to dispose of depleted uranium, excluding depleted uranium from 

deconversion of UF6, at concentrations less than 10 nCi/g. As previously mentioned, WCS 

demonstrated in a performance assessment that depleted uranium in large quantities and much 

larger concentrations could be safely disposed of for a time period much longer than 10,000 

years into the future. TCEQ elected to pose this additional concentration-based restriction of 

10 nCi/g limiting waste form of depleted uranium authorized for disposal until such time that 

NRC and then the State complete rulemakings. However, WCS believes conceptually that a 

similar trigger level could be useful in defining a threshold requiring more rigorous 

requirements that may be needed to protect public health and the environment from the 

hazards associated with depleted uranium. 

Issue III-2. Time Period of Performance for a Site-Specific Analysis 

See WCS comments pertaining to Issue 11-2. Time Period of Performance. 

Issue III-3. Exposure Scenario(s) for a Site-Specific Analysis 

See WCS comments pertaining to Issue 11-3. Exposure Scenarios for a Site-Specific Analysis. 
Rulemaking and Directives Branch

October 30, 2009

Page 5 of 5

Issue 111-4. Source Term Issues for a Site-Specific Analysis

WCS Comment: In regulatory guidance, NRC should clarify that only stable forms (and not

UF6) of unique waste streams, including depleted uranium, may be disposed of by shallow

land burial. NRC should also provide details in their regulatory guidance on acceptable

approaches to determine and quantify source terms that may be used in a site-specific

analysis.

Issue 111-5. Modeling of Uranium Geochemistry in a Site-Specific Analysis

WCS Comment: WCS believes that NRC should clarify acceptable approaches for modeling

of uranium geochemistry in regulatory guidance.

Issue 111-6. Modeling of Radon in the Environment in a Site-Specific Analysis

WCS Comment: To address the hazard of radon that decays from the 238U parent over time,

NRC should utilize the existing radon flux standard of 20 pCi/m2-sec as codified in 40 CFR

§ 192, Standards for the Control of Residual Radioactive Materials from Inactive Uranium

Processing Sites.

WCS appreciates that opportunity to comment on this important rulemaking initiative and

hopes that are perspective on this subject is helpful as NRC proceeds forward. WCS requests

that a copy of all correspondence regarding this matter be directly faxed (717-540-5102) or

emailed (wdornsife@verizon.net) to my attention as soon as possible after issuance. If you

have any questions or need additional information please call me at 717-540-5220.

Sincerely,

LJ~~P D z

William P. Dornsife, P.E.

Executive Vice President, Licensing and Regulatory Affairs

cc: Larry W. Camper, NRC

Patrice M. Bubar, NRC

Jeffrey M. Skov, WCS

J. Scott Kirk, CHP, WCS

Linda Beach, P.E., WCS

Mike Woodward, Hance Scarborough

Pam Giblin, Baker Botts

Rulemaking and Directives Branch 

October 30, 2009 

Page 5 of5 

Issue IlI-4. Source Term Issues for a Site-Specific Analysis 

WCS Comment: In regulatory guidance, NRC should clarify that only stable forms (and not 

UF6) of unique waste streams, including depleted uranium, may be disposed of by shallow 

land burial. NRC should also provide details in their regulatory guidance on acceptable 

approaches to determine and quantify source terms that may be used in a site-specific 

analysis. 

Issue III-5. Modeling of Uranium Geochemistry in a Site-Specific Analysis 

WCS Comment: WCS believes that NRC should clarify acceptable approaches for modeling 

of uranium geochemistry in regulatory guidance. 

Issue III-6. Modeling of Radon in the Environment in a Site-Specific Analysis 

WCS Comment: To address the hazard of radon that decays from the 238U parent over time, 

NRC should utilize the existing radon flux standard of 20 pCi/m2 -sec as codified in 40 CFR 

§ 192, Standards for the Control of Residual Radioactive Materials from Inactive Uranium 

Processing Sites. 

WCS appreciates that opportunity to comment on this important rulemaking initiative and 

hopes that are perspective on this subject is helpful as NRC proceeds forward. WCS requests 

that a copy of all correspondence regarding this matter be directly faxed (717-540-5102) or 

emailed(wdornsife@verizon.net) to my attention as soon as possible after issuance. If you 

have any questions or need additional information please call me at 717-540-5220. 

Sincerely, 

William P. Dornsife, P .E. 

Executive Vice President, Licensing and Regulatory Affairs 

cc: Larry W. Camper, NRC 

Patrice M. Bubar, NRC 

Jeffrey M. Skov, WCS 

J. Scott Kirk, CHP, WCS 

Linda Beach, P.E., WCS 

Mike Woodward, Hance Scarborough 

Pam Giblin, Baker Botts 
From: Grossman, Christopher 

Sent: Thursday, June 10, 2010 9:47 AM 

To: Miller, Debra 

Cc: Pinkston, Karen 

Subject: FW: NRC to Hold Public Workshops in Maryland and Utah on Safe

 Disposal of Depleted Uranium and Other 

DebPlease place the following e-mail into ADAMS. It should be profiled as publicly available. 

Chris 

From: Dirk A Dunning [mailto:dirk.a.dunning@state.or.us] 

Sent: Thursday, August 20, 2009 2:40 PM 

To: Pinkston, Karen 

Subject: Re: NRC to Hold Public Workshops in Maryland and Utah on Safe Disposal of Depleted Uranium 

and Other 

Hi Karen, 

 

My supervisor has asked me to participate in the Salt Lake City meeting. Please add me to the 

list. It would be helpful as early as possible to have a draft agenda, meeting location, etc... 

 

Some issues that could/should be addressed include: 

 

Mobility of uranium in various soils and how the regulations will deal with that 

 - In the presence of carbonate, and in oxidizing conditions uranium is highly mobile as oxocomplexed species 

Chemistry of uranium and how that affects mobility 

 - Oxo-ion complexation (e.g. carbonate, hydroxide, others...) 

 - Colloid formation (Soderholm and Burns ...) 

 - Redeposition in riverine environments as carbonate levels fall and as redox conditions change 

(directly and indirectly with biological activity) 

Recognition and handling of uranium's dual hazard (chemical and radiological) 

 - At very low U-235 content levels, the chemical hazard may exceed the radiological hazard 

 - At some enrichment levels, the risk from DU is additive (chemical toxicity plus radiological) 
Ecological risks as distinct from human risks 

Inclusion of CERCLA's natural resource damage provisions and early mitigation of harms (not 

claims of irreversible and irretrievable impacts which can be avoided) 

Tribal treaty reserved rights and distinct risk scenarios related to their different use of foods and 

the land 

Environmental Justices issues apart from Tribal issues 

Duration of the hazard (peak risk/dose) and regulating to and beyond the peak 

Need for validated models if risk is to be used as a basis 

Need for concentration standards to limit risk to acceptable levels if risk is not to be calculated 

on an individual site basis 

Preferential transport in the vadose zone/subsurface 

 - Matrix transport 

 - Finger flow 

 - Funnel flow 

 - Capillary flow (horizontal and vertical) 

 - other preferential transport flows 

Need for validated conceptual models and numeric simulation codes that faithfully emulate 

those concepts 

Cap and Barrier failure (requirement to use validated performance estimation) 

 - bypassing (flow of water under the barriers via preferential pathway flow, e.g. 

layered/structured soils) 

 - natural forces (vegetative degradation, animal intrusion, natural force damage - water, wind, 

tornado, seismic, mass area flow such as landslides ...) 

 - man made forces (accidental intrusion - e.g. wells, excavation, exploration; intentional 

intrustion - excavation, exploration; exploitation - industrial construction, road construction, 

terrorism, etc...) 

How to deal with uncertainty in the analysis (not just sensitivity analysis of parameter inputs, or 

selecting output values; but more importantly recognizing the inherent uncertainties in the 

actions, the future, and the results and assuring the safety of future generations). This might 

include a need for multi-model analysis ( a la the Jupiter suite of codes created by USGS, Poeter 

et.al.) 

Waste form durability and testing requirements 

 

 

Dirk Dunning, P.E. 

Oregon Department of Energy 

Nuclear Safety and Energy Siting Division 

625 Marion St. NE 

Salem, Oregon 97301-3737 

(503) 378-3187 

(503) 378-6457 (Fax) 

(800) 221-8035 (Oregon only 800#) 

(503) 378-4040 (Receptionist) 

Dirk.A.Dunning@state.or.us

>>> "opa administrators" <opa@nrc.gov> Thursday, August 20, 2009 8:01 AM >>> 
 NRC NEWS 

U.S. NUCLEAR REGULATORY COMMISSION 

Office of Public Affairs Telephone: 301/415-8200 

Washington, D.C. 20555-0001 

E-mail: opa.resource@nrc.gov

Site: http://www.nrc.gov

 

 

No. 09-138 

August 20, 2009 

 

NRC TO HOLD PUBLIC WORKSHOPS IN MARYLAND AND UTAH ON 

SAFE DISPOSAL OF DEPLETED URANIUM AND OTHER UNIQUE WASTE STREAMS 

 

 The Nuclear Regulatory Commission will conduct two public workshops in September to solicit 

public views on major issues for new regulations on shallow-land disposal of unique radioactive 

wastes, including significant quantities of depleted uranium. 

 

 The first workshop will be held Sept. 2-3 at the Hyatt Regency Bethesda, One Bethesda Metro 

Center, 7400 Wisconsin Ave., Bethesda, Md. The second workshop will be held Sept. 23-24 in 

Salt Lake City, Utah, at the Salt Lake City Marriott University Park, 480 Wakara Way. Both 

workshops will run from 8 a.m. to 5 p.m. each day. 

 

 The Commission directed the agency staff March 18 to initiate a rulemaking to specify a 

requirement for a site-specific analysis for the disposal of large quantities of depleted uranium, 

and other unique waste streams, such as reprocessing wastes and the technical requirements 

for such an analysis. The Commission also directed the staff to develop a guidance document 

for public comment that outlines the parameters and assumptions to be used in the site-specific 

analyses. The Commission said the staff should conduct a public workshop to discuss issues 

associated with disposal of depleted uranium and other unique waste streams, potential issues 

to be considered in rulemaking, and technical parameters of concern in the analysis so that 

informed decisions can be made in the interim before the rulemaking is final. 

 

 Earlier this summer, the NRC requested public comment on topics to be addressed at the 

workshops and the subsequent rulemaking. The agendas for the workshops are available on the 

NRC Web site at this address: , or Karen Pinkston, at (301) 415-3650, or by e-mail using 

docket ID NRC-2009-0257. 

 

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