John Greeves and Paul Lohaus NRC’s New Proposed Part 61 Rule Talisman International, LLC 1000 Potomac Street, NW Suite 300 Washington, DC 20007 202/471-4244 www.talisman-intl.com John Greeves and Paul Lohaus Turner, Harper & Associates, Inc. 1828 L Street, NW, Suite 710 Washington, DC 20036 (202) 496-1801

COMMON SET OF COMMENTS Agree update needed (e.g. modern dose method, 500 mrem intruder limit, 1000 year compliance period, analysis to peak dose) BUT, proposed Part 61 unnecessarily burdensome, lacks clarity, & disruptive to future regulatory actions Proposal is an overreach 61.7 Concepts 61.13 Technical Analysis 61.44 10,000 year stability 61.xx Defense-In-Depth analysis

SUGGESTED APPROACH FINAL PART 61 RULE Develop a SINGLE Part 61 rule (DU, GTCC, outstanding Classification question) Amend LLW definition to include “Transuranic Radionuclides” Retain existing Section 61.58. Repackage a stand alone Long-Lived Radionuclides Section (61.60 or Subpart H) for sites proposing to accept large quantities of long-lived radionuclides Clarify Per Section 61.1(a), existing sites not subject to all new requirements Replace proposed three-tiered approach with two-tiered analysis

RATIONALE FOR SUGGESTED APPROACH GTCC waste contains long-lived radionuclides like the “newer” waste streams Single rule would provide consistent, equivalent level of health, safety and environmental protection Significant time and resource savings Delaying a final determination on DU or GTCC classification will result in significant regulatory uncertainty Eliminates the need for a separate new rulemaking to address waste classification