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SRS site to Utah DU
Depleted Uranium in cheap, rusty, oil drums, en route to Utah. Apparently they will be buried like this. If not, they will be put in cheap new oil drums. For cheaper than the price of burial, the DU, and other radioactive waste, could be put in good quality containers, and properly stored.

According to the New York Times, Jan. 21, 2014, WCS in Texas is charging as much as $10,000 per cubic ft (roughly 28 liters) to bury so-called low level radioactive waste, which as we’ve seen isn’t low level at all. It includes radionuclides, such as plutonium, which are deadly for thousands and even millions of years. The dump is lined with thick concrete on clay, which sounds good until you think a second. Then you quickly realize, that being a semi-arid climate there’s going to be a lot of shrinkage and expansion of that clay, which means that the concrete will quickly crack. Besides, concrete has a surprisingly short life-span. Furthermore, this $10,000 per cubic ft is as much as 700 times more costly than it would cost for titanium containers. That leaves plenty of money to build above ground housing for the titanium containers. While we don’t know if competitor EnergySolutions’ investment bankers are charging that much in Utah, it is instantly clear why this criminal, albeit legal, enterprise of burying dangerous nuclear waste is of interest to investment bankers. While the German in me likes the idea of the nuclear waste being buried and someone else’s problem – which is clearly why Germany has a track record of sending its radioactive waste to burn and dump in other countries, and Germany wants to keep dumping it in leaky, collapsing, salt domes – the Scots in me realizes that this is a bad idea and that it needs to be safely stored and retrievable (Scotland’s policy). Furthermore, MY old-fashioned banker genes tell me that this is a rip-off. Why would you pay up to 700 times more to destroy the land and water for perpetuity?
Rad Waste Barrels WCS Texas
EnergySolutions which proposes to take depleted uranium at its Clive dump, doesn’t look even as sophisticated as WCS. Rather, it looks like a radioactive junk yard. If you want to find this junkyard on google earth, find Salt Lake City, the Great Salt lake and go a bit west and type Clive or Clive Rd. Utah.
Clive Utah zoom in variety waste
EnergySolutions Mound-Dump Clive Utah
USNRC Comment: Low-Level Radioactive Waste Disposal
ID: NRC-2011-0012-0077 Due Jul 24 2015, at 11:59 PM ET
http://www.regulations.gov/#!documentDetail;D=NRC-2011-0012-0077 Final rule info: http://www.gpo.gov/fdsys/pkg/FR-2015-03-26/pdf/2015-06429.pdf Docket ID: NRC-2011-0012 Nuclear Regulatory Commission (NRC) 10 CFR 60 and 61

As has become clear, the US NRC, and more generally, the US government doesn’t give a damn about the American people. They never have. That’s what happens when you are a colonial settler state outpost to Empire(s). North America was a land grab, immigration pyramid scheme, and still is. The burial and dumping of nuclear waste is an extreme case of this. Texas’ Waste Control Specialists (WCS) is charging up to $10,000 per cubic foot for burying nuclear waste. How much is EnergySolutions charging? At that price some of you may be thinking of turning your own house into a nuclear waste dump. According to the New York Times, “Space inside goes for $10,000 a cubic foot in some cases.” Three fourths of the money goes to WCS, and the rest to to Andrews county and Texas. Read: “Texas Company, Alone in U.S., Cashes In on Nuclear Waste“? By MATTHEW L. WALDJAN. 20, 2014, http://www.nytimes.com/2014/01/21/business/energy-environment/texas-company-alone-in-us-cashes-in-on-nuclear-waste.html?ref=energy-environment&_r=0 How big is a cubic foot? “the volume of a cube with sides of one foot (0.3048 m) in length. Its volume is 28.3168 liters or about one 35th (1/35.3147248277) of a cubic meter.https://en.wikipedia.org/wiki/Cubic_foot We found 20 m3 (20,000 liter) titanium containers online for a range of $10,000 to $100,000, meaning that this burial is between 70 and 700 times more costly. Presumably the lower end is for bulk orders.
desire of the nuclear industry
Well before there was Mormon Brigham Young; well before there were any people named “Wong”, living in America, to speak of the “desire” of the nuclear industry, as Melanie Wong has, there were people living already in Utah. Before a newly arrived Iranian immigrant, Khosrow Semnani (now posturing as an Iran nuclear expert), became filthy rich by setting up a nuclear waste dump west of the Great Salt Lake in the 1980s, after paying off a Utah DEQ regulator (which he admitted to), there were people living in Utah. He then sold the dump to a bunch of former Goldman Sachs investment bankers, EnergySolutions, who want to bury depleted uranium there, and are burying and dumping other nuclear waste. While it’s not exactly the topic at hand, that’s the context: steal land from the American Indians and destroy it by making it into a nuclear waste dump. The land theft was almost within living memory, it was so recent. People need to think about that and at least have some respect for the land and people. The land grab for Resolution Copper mine, opposed by a long list of American Indian tribes, and orchestrated by John McCain, while American Indian leaders were visiting Obama last December, underlines that this isn’t a historical topic, as does attempts by foreign miners to do more uranium mining in the area of the sacred Black Hills of South Dakota, which has been opposed by the Lakota Sioux and other Americans for years, and even decades.

As we saw recently, the Nuclear Energy Institute (NEI) wants to do away with the farce of public participation and transparency, and put in place an official nuclear dictatorship.

The US Federal government is robbing the US taxpayer and increasing the debt to follow the desires of the nuclear industry. And, to fund the ever-growing debt, they have to obey the desires of Japan and its nuclear industry, as well.

In this context, Melanie Wong of the NRC talking about the “desires” of the nuclear industry, no longer appears as shocking as it did last year.

US NRC Workshop “Low Level” Radioactive Waste Disposal for “Stakeholders” – “Panel” included “Energy Solutions” Rad Waste Co. One of the major NRC concerns is: “THE DESIRE OF THE INDUSTRY FOR GREATER FLEXIBILITY AND RELIABILITY IN LLRW DISPOSAL OPTIONS“. Yep, couldn’t make this up if we tried. The nuclear waste dump industry “DESIRES” “GREATER FLEXIBILITY” and the US NRC jumps to it! How about what the people desire?
Nuclear Waste Dump Industry "Desires"
(In case there are restrictions on the logo, we erased it. Original here: http://pbadupws.nrc.gov/docs/ML1407/ML14070A058.pdf)

Milton Hooper (left), Environmental Specialist at the Goshute Indian Reservation, and Carlos Garcia, NRCS, review a riparian management plan for the reservation
Milton Hooper (left), Environmental Specialist at the Goshute Indian Reservation, and Carlos Garcia, NRCS, review a riparian management plan for the reservation. [Slide 97CS3145]Photo by Ron Nichols, USDA Natural Resources Conservation Service. https://en.wikipedia.org/wiki/Goshute
Originally, the Salt Lake Valley was inhabited by the Shoshone, Paiute, Goshute and Ute Native American tribes. At the time of the founding of Salt Lake City the valley was within the territory of the Northwestern Shoshone, who had their seasonal camps along streams within the valley and in adjacent valleys.[1] The land was treated by the United States as public domain; no aboriginal title by the Northwestern Shoshone was ever recognized by the United States or extinguished by treaty with the United States.[2] Father Silvestre Vélez de Escalante, a Spanish Franciscan missionary is considered the first European explorer in the area in 1776, but only came as far north as Utah valley (Provo), some 60 miles south of the Salt Lake City area. The first US visitor to see the Salt Lake area was John Chugg in 1824. U.S. Army officer John C. Frémont surveyed the Great Salt Lake and the Salt Lake Valley in 1843 and 1845.[3] The Donner Party, a group of ill-fated pioneers, traveled through the Great Salt Lake Valley a year before the Mormon pioneers. This group had spent weeks traversing difficult terrain and brush, cutting a road through the Wasatch Mountains, coming through Emigration canyon into the Salt Lake Valley on August 12, 1846. This same path would be used by the vanguard company of Mormon pioneers, and for many years after that by those following them to Salt Lake.[4] … On July 24, 1847 143 men, three women and two children founded Great Salt Lake City several miles to the east of the Great Salt Lake, nestled in the northern most reaches of the Salt Lake Valley.“. https://en.wikipedia.org/wiki/History_of_Salt_Lake_City The Clive facility nuclear waste dump is west of the Great Salt Lake. 168 years ago is nothing. Most of my great great grandparents were teens or pre-teens, and many people living have great grandparents who were alive.

“Energy Solutions” Low Level Waste Facility in Clive, Utah
zoom out with tailings pond

There was already a US Low Level Waste comment period which ended on Monday September 15, 2014 http://www.regulations.gov/#!documentDetail;D=NRC-2014-0080-0002 The law (2011) is available here: http://www.gpo.gov/fdsys/pkg/CFR-2011-title10-vol2/pdf/CFR-2011-title10-vol2-part61.pdf and here: http://www.law.cornell.edu/cfr/text/10/part-61 Part updated in 2012: http://www.law.cornell.edu/cfr/text/10/61.25

Most of the following is from a post from last September. It appears perhaps more relevant to this comment period than to last September’s comment period.

It’s important to recall that the term “low level” radioactive waste, in the US (and the UK), is a patent lie. There is nothing “low level”, for instance, about plutonium 241 ranging from 1,295,000 becquerels (radioactive disintegrations per second) per kilogram (2.2 pounds) for the lowest level “Class A” and 129,500,000 becquerels of plutonium 241 per kg (2.2 pounds) of “Class C”. Plutonium 241 becomes much longer lived Americium 241. These are transuranic elements of the sort which were at WIPP. (The “low level” rule for Pu 241 is a max of 3500 nanocuries/g = 129,500 bq/g = 129,500,000 bq/kg. Class A is x 0.1).

Only in NRC-pro-nuclear fantasy land can over a million radioactive emissions per second of plutonium in 2.2 pounds (1 kg) be “low level”.

Worse, while pretending that they will now make a better facility, the NRC apparently wants it to leak more. They are now saying 0.25 mSv (25 mrem) radiation exposure for the “general public” and 5 mSv (500 mrem) for the “accidental intruder” (The accidental intruder is the person who in future years doesn’t know it’s a nuclear site; it doesn’t include burrowing animals.) AND for both the “general public” and the “accidental intruder” of future generations it is 5 mSv (500 mrem)! In 20 years the accidental intruder who might unknowingly move there would have a 1% chance of having a life-shortening cancer.

They will also allow the much higher, current EPA, limit for the thyroid of 0.75 mSV (75 mrem) for routine exposure. One seriously problematic component of nuclear waste is iodine 129, with a half-life of 15.7 million years. Radioactive iodine is well-recognized, even by the nuclear lobby, as causing thyroid disorders and even cancer. The nuclear lobby argues that thyroid problems are no big deal, however, since people can take thyroid replacement hormone for life. Where they don’t deny a problem, they declare it no big deal, it seems. Nobody needs their thyroids or kidneys, they appear to think. Has everyone in the NRC and nuclear lobby donated both of their kidneys to those who have damaged kidneys from uranium? If not, they need to get moving! Surely for them going to dialysis for life is not a big deal either, if it’s no big deal for other people! [The previous paragraph was from last Sept’s comment period, as is the following paragraph. We haven’t slogged through the new document to see if it is still there, but it almost certainly is, as the 5 mSv intruder number is there].

The NRC also wants the option of following the ICRP exposure rate for nuclear waste disposal, which is 0.3 mSv (30 mrem). These are annual exposures and often bioaccumulative within the body and the environment. If the NRC and the nuclear industry are not brought to heel, all life is doomed. Wild animals can’t take thyroid hormone or do dialysis and these aren’t the only problems brought on by radionuclides.

It is strange that while the ICRP has decided that active nuclear facilities, like nuclear reactors, should leak at 0.1 mSv per facility per year max, where long-lived radionuclides are involved, they think that nuclear waste should be allowed to leak at 0.3 mSv. The ICRP thinks that everyone’s exposure to radiation should be 1 mSv or less from nuclear sources. These sound like small numbers, but closer examination shows that they are not, and that they are building up in the environment. The build-up is more evident in semi-closed waterways such as the Baltic, Irish Sea and surely in Scottish Lochs, if these last were tested. There must certainly be a build-up in the Great Lakes, as well.

So, while, on the one hand, the NRC has recently announced it has decided that a nuclear waste facility should be evaluated in terms of 1,000s of years, rather than a 100 years, or less, they want the facilities to LEAK MORE, and they seem to want more waste to not go to a special facility, but rather into general landfills.

WIPP for transuranic waste, such as plutonium and americium, was supposed to last 10,000 yrs, as was Asse II in Germany. WIPP lasted around 20 years; Asse II lasted less. http://en.wikipedia.org/wiki/Waste_Isolation_Pilot_Plant

FURTHERMORE, IT SEEMS THAT THE NRC’S POLICY IS THAT FOR EVERY RULE THERE IS A LOOPHOLE OR AN EXCEPTION. They appear to be seeking to formalize these into a routine, too, whereby nuclear waste goes more easily to regular landfill.

One big question is if the shift to 1,000s of years means that they will consider accessible bunker-tunnel-like facilities for “low level” waste, similar to WIPP, but in hard-rock? Or, are they still deluding themselves that they can bury it in a mound or underground? Or in salt so that it can look like Asse II or the Texas Brine-Bayou Corne-Louisiana Sinkhole? [They seem to be deluding themselves.]

Everyone can look at Monks Mound, or other mounds, to see that the current policy won’t work. Monks Mound, which was made of soil and clay, started slumping and filling with water almost immediately. The problems were major within a 150 or so years. It required repairs. http://en.wikipedia.org/wiki/Monks_Mound Although there may be some concrete containment-liners in the nuclear waste mounds, concrete degrades over time and more rapidly in the ground (as does everything). The clay “engineering” “barriers” will under go swelling and shrinking and cracking. It’s simply a ridiculous model. All underground structures leak and require pumping to keep dry, according to top experts in tunnel construction. How much they leak depends on location. There will be erosion, subsidence, and collapse of the facility over time. Pumping of ground water, in an effort to keep the site dry, should accelerate erosion and possibly cause sinkholes.

This was apparently the Low Level Waste comment prep session for those “in the know”, which would be people like Ralph Andersen of the “Nuclear Energy Institute”, William Dornsife of “Waste Control Specialists”, and Dan Shrum of “Energy Solutions” (He’s the one who turned in his EPA comments LATE and they were posted ahead of those who were on time), who along with some government officials were “panelists” at this “workshop” last spring. There aren’t even any academics on the panels! As panelists, the Radioactive Waste company reps must have been invited. Were you?

That is, a pro-nuclear lobby group; those who are making money disposing of radioactive waste, and those who are supposed to monitor them were “panelists”. It appears a small, backslapping, little world.
From their powerpoint slides (Emphasis added, including occasionally bold; comments added; some texts referred to added).
Chip Cameron Facilitator
March 7, 2014 NRC Public Meeting Phoenix, AZ
7:30 – 8:00 am Registration 8:00 – 8:15 Facilitator Opening Comments C. Cameron, Facilitator 8:15 – 8:30 NRC Welcome L. Camper, NRC/FSME1 8:15 8:30 NRC Welcome L. Camper, NRC/FSME
8:30 – 9:302 Status of Low-Level Radioactive Waste D. Esh, NRC/FSME Disposal Rulemaking and Discussions 9:30 – 9:45 Break 9:45 – 10:00 Strategic Assessment of M. Wong, NRC/FSME Low-Level Radioactive Waste Regulatory Program Regulatory Program 10:00 – 11:30 Panel Discussions 11:30 – 12:45 pm Facilitated Public Discussions 12:45 – 1:00 Closing Remarks A. Mohseni, NRC/FSME 12:45 1:00 Closing Remarks A. Mohseni, NRC/FSME
1 Office of Federal and State Materials and Environmental Management Programs (FSME)
2The timing is subject to change based on the status of the proposed rulemaking on 10 CFR Part 61.

Larry W. Camper, CEP, CIPM, Director
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
March 7, 2014 NRC Public Meeting Phoenix, AZ


To discuss the status of the proposed revisions to the Commission’s LLRW disposal regulations and gather information on an update to the NRC 2007 Strategic Assessment of the LLRW regulatory program from stakeholders and other interested members of the public“. (p. 4)

David Esh
March 7, 2014 NRC Public Meeting Phoenix, AZ
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
“(p. 6)

2009 Commission Direction
– Two tasks:
Specify a requirement for a site-specific analysis, technical parameters (i.e., new definitions and performance period) to support such analysis, and develop a guidance document.
• “… in a future budget request, the staff should propose the necessary resources for a comprehensive revision to risk-inform the Part 61 waste classification framework, with conforming changes to the regulations as needed, using updated assumptions and referencing the latest ICRP methodology …”
“… This effort should explicitly address the waste classification of depleted uranium
” (p. 7)

2012 Commission Direction

– Flexibility to use current International Commission on Radiological Protection (ICRP) dose methodologies

– Two-tiered period of performance:
– Two-tiered period of performance:
• Tier 1: Compliance period covering reasonably foreseeable future
• Tier 2: Longer period based on site characteristics and peak dose to a designated receptor, that is not a priori

– FLEXIBILITY to establish site-specific waste acceptance criteria based on the results of the site’s performance assessment and intruder assessment

Balance Federal-State alignment and FLEXIBILITY (p.8)

[Notice that this means that they can say that it is unlikely that anyone will be in a certain spot in 100 or 1,000 years so that they can have lower standards. The world population is growing. People will be everywhere, if humanity survives this nuclear folly. Refer to the Monk Mound link to see how people can come from afar in a short time; for older mounds, even the American Indians don’t necessarily know who built them.]

2014 Commission Direction SRM SECY-13-0075

– Three-tiered period of analysis:
• Tier 1: Compliance period of 1,000 years, 25 mrem dose limit for 61.41 and 500 mrem dose limit for 61.42
• Tier 2: Protective Assurance Period from 1,000 to 10,000 years, 500 mrem analytical threshold (goal) for 61.41 and 61.42
• Tier 3: Performance period > 10,000 years, qualitative analysis

– Constancy of features, events, and processes of the natural environment for Tier 2 unless compelling scientific evidence

– Realistic intruder scenarios based on expected activities on and around the disposal site at the time of closure.(p. 9)

[Oh, oh – See that? Assumes environment unchanging, unless “compelling” evidence otherwise. AND, intruder assumed based on time of closure!]

2014 Commission Direction SRM SECY-13-0075

– The proposed rule should be published with a compatibility category “B” applied to the most significant provisions of the revised rule, including the Period of Compliance, the Protective Assurance Analysis Period and its analytical threshold, and the Waste Acceptance Criteria Acceptance Criteria.

– The Protective Assurance Analysis Period (Tier 2) requires the applicant to propose remedial changes to the disposal site design, or impose inventory limits, or propose alternative methods of disposal as it is approached.

Stress defense-in-depth and safety case.

– Thorough review of guidance by LLW community“. (p.10)

[Who’s the “community”? The people near the facility or the “community” of nuclear waste companies?]

Path Forward

Staff will revise the rule, statement of considerations, and guidance document over the next year.
Proposed rule issued for public comment in 2015.
• Extensive stakeholders outreach – 120 days comment period – 1 or more public meeting to engage stakeholders
“(p. 11)

[Who are the stakeholders? Where is the “public meeting” going to be held?

Melanie Wong
March 7, 2014 NRC Public Meeting Phoenix, AZ

Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental M t P Management Programs” (p. 12)


• Background
• Status of the 2007 Strategic Assessment
Proposed updates to the Strategic Assessment
• Next steps
” ( p. 13)


Challenges and issues included:
• increased storage of Class B and Class C LLRW;
• the potential need to dispose of large quantities of power plant decommissioning waste and depleted uranium;
• increased safety concerns;
• the LLRW program required greater resources than were available;
• increased security concerns; and
new waste streams that may be generated
(p. 14)

Background (continued)
2007 Strategic Assessment of the NRC’s regulatory program for LLRW

• identify and prioritize staff activities

• ensure safe and secure LLRW disposal;
improve the effectiveness, EFFICIENCY, and ADAPTABILITY of the NRC’s LLRW regulatory program; and
• ensure regulatory stability and predictability
“. (p.15)

Background (continued)
• Variety of activities proposed
• List of 20 activities developed
• Priorities of high (7 tasks), medium (6 tasks), or low (7 tasks) assigned tasks) assigned


Background (continued)
High Priority Activities

Task # Task Description

1 Review and update guidance on extended storage of LLRW.

2 Develop guidance on 10 CFR 20.2002 Alternate Disposal Requests.

3 Determine if disposal of large quantities of depleted uranium would change the waste classification tables.

4 Update Branch Technical Position on Concentration Averaging and Encapsulation Encapsulation.

5 Develop procedures for IMPORT/EXPORT Review.

6 Develop guidance on alternate waste classification (10 CFR 61.58).

7 Perform scoping study of the need to revise/expand byproduct material financial assurance to account for life-cycle cost.“(p. 17)

§ 20.2002 Method for obtaining approval of proposed disposal procedures. A licensee or applicant for a license may apply to the Commission for approval of proposed procedures, not otherwise authorized in the regulations in this chapter, to dispose of licensed material generated in the licensee’s activities. Each application shall include:
(a) A description of the waste containing licensed material to be disposed of, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal; and
(b) An analysis and evaluation of pertinent information on the nature of the environment; and
(c) The nature and location of other potentially affected licensed and unlicensed facilities; and
(d) Analyses and procedures to ensure that doses are maintained ALARA and within the dose limits in this part. Page Last Reviewed/Updated Thursday, July 10, 2014

Power point continues:
Background (continued)

Medium Priority Activities
Task # Task Description

1 Develop licensing criteria for greater than Class C (GTCC) disposal facility.

2 Consolidate LLRW guidance.

3 Develop guidance that summarizes disposition OPTIONS for low-end materials and waste.

4 Coordinate with other agencies on consistency in regulating low activity waste disposal.

5 Identify new waste streams.

6 Develop information notice on waste minimization Develop information notice on waste minimization“.(p. 18)

Background (continued)

Low Priority Activities
Task # Task Description

1 Evaluate potential changes to LLRW regulatory program as a result of severe curtailment of disposal capacity.

2 Promulgate rule for disposal of low-activity waste.

3 Identify and evaluate potential legislative changes.

4 Implement major revisions to 10 CFR Part 61.

5 Develop waste acceptance criteria for LLRW disposal in uranium mill tailings impoundments.


7 Develop and implement national waste tracking system“. (p. 19)


From: “10 CFR Ch. I (1–1–11 Edition)” [Not in powerpoint slides]
§ 61.58 Alternative requirements for waste classification and characteristics.

The Commission may, upon request or on its own initiative, authorize other provisions for the classification and characteristics of waste on a spe-cific basis, if, after evaluation, of the specific characteristics of the waste, disposal site, and method of disposal, it finds reasonable assurance of compli-ance with the performance objectives in subpart C of this part. (p. 223)

Subpart C—Performance Objectives

§ 61.40 General requirement.

Land disposal facilities must be sited, designed, operated, closed, and
(p. 217)

10 CFR Ch. I (1–1–11 Edition) § 61.41

controlled after closure so that reasonable assurance exists that exposures to humans are within the limits estab-lished in the performance objectives in §§61.41 through 61.44.

§ 61.41 Protection of the general population from releases of radioactivity.

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.

§ 61.42 Protection of individuals from inadvertent intrusion.

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.

§ 61.43 Protection of individuals during operations.

Operations at the land disposal facility must be conducted in compliance with the standards for radiation protection set out in part 20 of this chapter, EXCEPT for releases of radioactivity in effluents from the land disposal facility, which shall be governed by §61.41 of this part. Every REASONABLE effort shall be made to maintain radiation exposures as low as is reasonably achievable.

§ 61.44 Stability of the disposal site after closure.

The disposal facility must be sited, designed, used, operated, and closed to achieve long-term stability of the disposal site and to eliminate to the ex-tent practicable the need for ongoing active maintenance of the disposal site following closure so that only surveillance, monitoring, or minor custodial care are required“. (p.218) [RECALL THAT ALARA, ALARP HAVE NOTHING TO DO WITH WHAT MOST PEOPLE THINK IS “REASONABLE”. IT DOES NOT MEAN FEASIBLE. IT HAS TO DO WITH THE PROFIT OF THE WASTE FACILITY VS. PUBLIC HEALTH RISK, AS THE GOVT. DEFINES RISK! ALARA-ALARP HAVE ROOTS IN A COAL MINING ACCIDENT IN THE UK, WHERE THE WIDOW LOST.]

[Return to powerpoint presentation]
Proposed Updates to the Strategic Assessment

• Review 2007 Strategic Assessment and could reprioritize some of remaining activities
Develop licensing criteria for greater than Class C disposal facility.
• Perform scoping study of the need to revise/expand byproduct material financial assurance to account for life cycle cost life-cycle cost.
• Develop procedures for Import/Export Review
“. (p 21)

Initial Scoping of the Update to the Strategic Assessment

• Activities to consider include
• Licensing Criteria for GTCC
Low Activity Waste Rulemaking
Revision of the Waste Manifest
Waste Attribution
” (p. 22)

Next Steps
• Information gathering
• Federal Register Notice soliciting comments on proposed activities
• Request comment on draft updated Strategic Assessment


March 7, 2014 NRC Public Meeting, Phoenix, AZ
Introduction of Panelists

Brad Broussard Texas Commission on Environmental Quality

Earl Fordham Washington Department of Health

Rusty Lundberg Utah Department of Environmental Quality

Ralph Andersen Nuclear Energy Institute

William Dornsife Waste Control Specialists

Dan Shrum Energy Solutions

Christine Gelles U.S. Department of Energy-Environmental Management

Michael Garner Northwest Interstate Compact on Low-Level Radioactive Waste Management/State of Washington

Gregory Suber U.S. Nuclear Regulatory Commission” (p. 26)


• What changes are anticipated to the national landscape in the LLRW area in the context of safety security and in the LLRW area in the context of safety, security, and the protection of the environment in the next 5-7 years?

• As a result of the new national landscape, what activities from the 2007 Strategic Assessment should remain on the list and are they appropriately prioritized in order to strengthen the NRC’s ability to ensure safe and secure LLRW disposal, improve the effectiveness of its regulations, and assure regulatory stability and predictability while allowing FLEXIBILITY in disposal options?
• As a result of the new national landscape, what additional changes are needed to the NRC regulatory framework?
“( p. 27)

Recap and Closing Recap and Closing
Aby Mohseni, Deputy Director
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
March 7, 2014 NRC Public Meeting Phoenix, AZ

Insights From Insights From Today’s Workshop Today’s Workshop

Next Steps

Evaluate today’s comments
• Additional Outreach efforts
Expect proposed 10 CFR Part 61 rule issued for public comment in 2015
• Draft Strategic Assessment issued for public comment in early 2015
” (p.30) “QUESTIONS” (p. 31) http://pbadupws.nrc.gov/docs/ML1407/ML14070A058.pdf

Aby Mohseni
Mr. Mohseni joined the NRC in 1990 in the Office of Nuclear Reactor Regulations.
He is currently the Deputy Director for Environmental Protection and Performance Assessment Directorate.
His prior appointment was Deputy Director of Spent Fuel Alternative Strategies Division in the Office of Nuclear Materials Safety and Safeguards.
Prior to that, for 5 years, he served as Deputy Director for Licensing and Inspection Directorate, Division of High-Level Waste Repository Safety.
In 2000, he served as Science Advisor to the Chairman of the US Senate Committee on Environment and Public Works.
Prior to joining the NRC, Mr. Mohseni was the Head for Nuclear Safety, Washington State Office of Radiation Protection.
He also served as Senior Project Manager for I&C and for Nuclear Steam Supply System at Satsop Nuclear Plant (WNP-3) in Washington State.
Mr. Mohseni earned a Bachelor’s degree in Physics and a Master’s degree in Nuclear Engineering from the University of Washington, Seattle, WA.
Page Last Reviewed/Updated Wednesday, July 17, 2013