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Thursday
Apr062017

NIRS & Beyond Nuclear to NRC: OBJECTION AND REQUEST FOR RECONSIDERATION OF GENERAL IMPORT LICENSE ISSUANCE TO UNITECH SERVICE GROUP, INC.

Nuclear Information and Resource Service (NIRS) and Beyond Nuclear have submitted an Objection and Request for Reconsideration to the U.S. Nuclear Regulatory Commission (NRC), protesting NRC's flippant rubber-stamp for the importation of 10,000 tons of Canadian (so-called) "low" level radioactive waste/material, into the U.S.

Once imported into the U.S. from Canada, the radioactive waste/material could then be "free-released" into commerce as "below regulatory concern" -- such as recycled into consumer products. It could also be buried in ordinary garbage dumps, as if it weren't radioactive. The radioactive wastes/materials could also be incinerated, or otherwise "heat treated" or "pyro-processed," with untold radioactive emissions to the atmosphere.

Leftovers from all these various processes in the U.S. could them be re-exported to Canada, for disposal.

Comparing the list of radioactive isotopes the radioactive waste/material firm UniTech predicts will be found in the radioactive waste/material stream, to NRC's “Illustrative List of Byproduct Materials Under NRC Export/Import Licensing Authority,” is revealing. The "Illustrative List" is a RULE, i.e., UniTech can import low amounts of these radioactive isotopes into the U.S. 

But UniTech is proposing to import the following radioactive isotopes, which are not covered by the RULE:

Lanthanum, unspecified as to isotope
Neptunium 239
Plutonium 238
Plutonium 239/40
Silver 108

It appears to Beyond Nuclear, NIRS, and their legal counsel, that there would have to be a rulemaking, i.e., that even if a general license is all NRC will do, the approval of a general license would itself have to be conducted as a rulemaking, with full rights to a public legal intervention hearing.

(See the above argument laid out on page 6 of the Objection/Request for Reconsideration.)
 

Terry Lodge of Toledo, Ohio and Brian Paddock of Cookeville, Tennessee serve as legal counsel for the NIRS-Beyond Nuclear environmental coalition.