1. 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/
John Greeves and Paul Lohaus
Turner, Harper & Associates, Inc.
1828 L Street, NW, Suite 710
Washington, DC 20036
(202)

2. 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
Concepts
61.13 Technical Analysis
,000 year stability
61.xx Defense-In-Depth analysis

3. 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
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

4. 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