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DRAFT FOR SIGN ON BY FRIDAY FEB 22 dianed@nirs.org 301 270 6477 x 16

Office of the Secretary
U.S. Nuclear Regulatory Commission
Washington, DC 20555

February 22, 2008 ??
Dear Office of the Secretary,

The Nuclear Regulatory Commission is currently considering applications (Nos. IW023 and XW013, Federal Register Volume 73, Number 28, 2/11/08) from EnergySolutions for import/export licenses that would bring 20,000 tons, 1 million cubic feet, 600,000,000,000,000 becquerels of radioactive waste (mainly from Italian nuclear power and related industries) into the US for processing including incineration, transport and disposal.

Our organizations request a 90-day extension on the time period to request a hearing or petition for leave to intervene and for public comment.

In terms of volume, the application appears to allow close to all of the Italian “low and intermediate” level nuclear waste inventory to be brought to the US through US ports, on US roads, rails and/or waterways for processing in Tennessee and dumping either in Tennessee or at the licensed nuclear dump in Utah.

The activities of the nuclear waste processors in Tennessee, including EnergySolutions, which release some nuclear waste into regular solid waste trash dumps and into recycling streams, currently are being questioned and challenged in that state.

Importing such massive amounts of nuclear waste for transport and processing could affect the ability to manage our own country’s growing amounts nuclear waste.

Because of the
àunprecedented large amounts of waste and radioactivity involved,
àpotential impact on ports, transport routes, communities with processors and those downwind and downstream;
àincreased potential for radioactive materials deregulated via EnergySolutions to get into commerce or unregulated waste facilities;
ànewness of the information to many potentially affected parties and communities;
àpotentially disproportionate impact on communities of color and low income communities in several of the directly affected states,

we call for an extension on the comment, hearing and intervention request period for the EnergySolutions import/export licenses for Italian nuclear waste.


Diane D’Arrigo
Nuclear Information and Resource Service