NUCLEAR INFORMATION
AND RESOURCE SERVICE
6930 Carroll Avenue, Suite 340, Takoma Park, MD 20912
301-270-NIRS (301-270-6477); Fax: 301-270-4291
nirsnet@nirs.org; www.nirs.org
NRC proposes to change “low-level” radioactive waste rules
These changes would allow:
*More than 33 Times Higher Radiation than from High Level Dumps
*More than 20 Times more than from Operating Nuclear Power Reactors
*Depleted Uranium and Reprocessing Waste in “low- level” disposal sites
*Dump operators do Performance Assessments to allow new waste types into existing dumps
July 23, 2015,
Dear Friends,
The
Nuclear Regulatory Commission has proposed unacceptable changes to its
“low-level” radioactive waste rules (10 CFR 61)—as indicated briefly in
the headline above.
Our full comments on this proposal are included below.
We are inviting all organizations to sign on to these comments. But the deadline is tomorrow, so please act now!
To
sign on, please send your name, organization name, city, state and
country (if outside the U.S.) to dianed@nirs.org. Organizational
sign-ons only, please.
Deadline is noon tomorrow, Friday, July 24.
If
you need more information, contact Diane D’Arrigo, NIRS Radioactive
Waste Project Director, at dianed@nirs.org or call her at 301-270-6477
ext 15.
Act now!
Thanks for all you do,
Michael Mariotte
President
Nuclear Information and Resource Service
Comments to NRC on 10 CFR 61 Proposed Radioactive Waste Disposal Regulations
Federal Register / Vol. 80, No. 58 / Thursday, March 26, 2015 / Proposed Rules
10 CFR Parts 20 and 61 [NRC–2011–0012; NRC–2015–0003] RIN 3150–AI92
Low-Level Radioactive Waste Disposal AGENCY: Nuclear Regulatory Commission. ACTION: Proposed rule.
New NRC so-called “Low-Level” Nuclear Waste Dump Rules Would Allow More than
33 Times Higher Radiation than High Level Dumps!
And 20 Times more than from Operating Nuclear Power Reactors!
The
banner on the webpage of the US Nuclear Regulatory Commission flashes
“Protecting People and the Environment.” Critics of the NRC have
challenged this claim and the proposed 10 CFR 61 regulation changes
substantiate that challenge.
The proposed rule flies in the face
of common sense and weakens already-inadequate regulations for licensed
disposal of radioactive waste.
The proposed regulations allow
more than 33 times higher radioactive releases and exposures from
so-called “low-level” radioactive waste dumps than from a high level
waste dump formerly proposed at Yucca Mountain. Federal regulations[1]
for a high level waste repository allow the site to release
radioactivity that would deliver doses of up to15 millirems[2]/year for
the first 10,000 years. From 10,000 to 1 million years, the annual dose
limit is 100 millirems. The NRC proposed regulations allow 25 during
operation but up to and beyond 500 millirems per year from so called
“low-level” radioactive waste disposal sites. The proposed rule allows
so-called “low-level” nuclear waste disposal sites, after closure, to
emit more than 20 times more radioactivity than operating nuclear power
reactors[3] under 40 CFR 190.
We oppose the proposed rule and demand that NRC actually enforce its current minimum regulations at existing sites.
The
EnergySolutions-operated site in Barnwell, South Carolina which has
been leaking for decades, despite a court order against both the company
and the agreement state regulator (DHEC), has no plan to stop or
prevent future leakage.
The Waste Control Specialists (WCS) waste
site was licensed by two out of the three politically- appointed Texas
Commission on Environmental Quality (TCEQ) Commissioners, despite the
technical review team recommending denial or additional changes needed
to protect water. A request by the Sierra Club for a contested case
hearing was denied by the TCEQ Commissioners and Sierra Club has
appealed to the Texas Supreme Court, arguing that TCEQ denied a
legitimate hearing request. Since the license was granted and the site
started receiving commercial and federal radioactive waste, WCS has
changed the license through a series of amendments. First, they asked
for and received an amendment allowing disposal of waste even if water
is present in the area. Second, more recently, an amendment (known as
Number 26) allows the WCS to increase the amount of waste, lowers
financial assurance requirements and adds new waste streams to the site,
including Depleted Uranium (DU). This amendment was approved with
minimal public input and allows “flexibility” for how DU is to be
disposed, including potentially allowing it go into non-containerized
units.
The proposed rule makes the existing 10 CFR 61 even worse
and makes radioactive waste dumps more dangerous. The current rule does
not require isolating the waste for the entire time it is radioactively
hazardous but the proposed rule enables increasing the amount,
radioactivity and longevity of the waste while removing dose limits
“based on technological and economic considerations.”[4] It dubs future
populations “intruders” and allows unlimited doses in the future from
nuclear waste generated and buried today.
The proposed rule
allows private dump-operators to do “black box” calculations to
allegedly justify putting whole new kinds and amounts of radioactive
wastes to existing waste sites, clearly a conflict of interest—profit
for them and not in the interests of the public or environment. It
overrules states that have or might set stricter than federal standards
for public and environmental protection. NRC appears to be lowering its
own federal standards for public and environmental protection and for
democratic participation, possibly in order to facilitate weaker
standards at one or more existing radioactive waste facilities. At a
time when NRC should be enforcing its own administrative and technical
regulations, it is weakening them.
Some
of the provisions in the proposed rule violate common sense, the Atomic
Energy Act, the Low-Level Radioactive Waste Policy Act, the
Administrative Procedures Act, the National Environmental Policy Act and
the International Declaration of Human Rights. We insist that NRC
correct these errors.
Many of our groups have long advocated for better public protection in regulations for nuclear waste disposal, including:
è
No waste that lasts longer than the sites are actively monitored,
repaired and institutionally controlled (with resources to remediate)
should be allowed into a disposal site. We support redefining
“radioactive waste” eligible for shallow land burial under 10 CFR 61 and
Agreement State regulations to keep long-lasting wastes out of
near-surface burial.
10 CFR 61.55 Definitions: The A, B, C,
>C waste classifications in 10 CFR 61.55 make assumptions that have
never been publicly accepted but have become the norm. We continue to
oppose the use of those misleading classifications, thus are more
strongly opposed to allowing even more longer lasting and hazardous
radionuclides into 10 CFR 61 disposal sites.
For example, there
is no level of plutonium that is “safe” or acceptable. Yet Class A
waste, supposedly only dangerous for 100 years, the shortest lasting,
least concentrated class, includes plutonium, hazardous for a quarter to
half million years, up to 10 nanocuries per gram, with no limit on the
number of grams. It also includes iodine 129 hazardous for 160 to 320
million years. Clearly adding the proposed DU which decays into more
radioactive progeny with a long decay chain has no business in 100 year
Class A disposal.
è Define the appropriate class, if there is one, for DU. Initiate plans to consider it as high level waste.
è
Keep uranium including DU, irradiated fuel reprocessing waste including
WIR (waste incidental to reprocessing—a downward reclassification of
high level waste), and other long-lasting wastes out of so-called
“low-level” waste disposal sites.
è Make a goal of isolating
radioactive waste, not legalizing releases. Do not increase allowable
radioactive releases or the projected doses to people during or after
the operational period.
Under the existing 10 CFR 61the sites can
legally leak into “the general environment in ground water, surface
water, air, soil, plants and animals,” an amount calculated to deliver
up to 25 millirems to the whole body, 75 millirems to the thyroid and 25
millirems to any other organ of the body of members of the public,
annually. By adopting the 10 CFR 20 definitions of radiation dose (doing
away with organ dose limits), the proposed rule increases the
radioactivity per millirem for many of the radionuclides.
The
proposed rule makes this much worse, as it allows not 25 but up to 500
millirems (EDE) or more per year, from a closed site. The unspecified
doses are based on technical and economic considerations of the waste
site operator. See the proposed 10 CFR § 61.42. 500 millirems/year is an
amount that is expected to cause cancer in 1 in 25 exposed[5], clearly
an unacceptable risk from closed nuclear waste sites. This is criminal
and disgraceful for an agency claiming to protect the public and
environment.
The existing radioactive waste sites have
historically leaked – some in less than 20 years and well before site
closure. One can only hope that institutional controls will exist for
100 years post-closure, keeping in mind that institutional controls are
not accompanied by resources to capture or control leaks and releases
when they are revealed.
è No Preemption of State Authority; Require States to Regulate as Strictly as NRC -
The
proposed rule supersedes the rights and authority of states to set more
protective standards for facilities in their boundaries by making the
entire 10 CFR 61 Level B Compatibility. As public interest advocates who
participated in the setting of state regulations and siting of
radioactive disposal sites, we strongly oppose this compatibility
designation and support and encourage all state level opposition to this
designation.
NRC should drop the proposed requirement that all
provisions of the new rules be adopted verbatim, Level B Compatibility,
by Agreement States. The ‘Low-Level’ Radioactive Waste Policy Act and
its Amendments (PL 99-240) makes states responsible for so-called
“low-level” radioactive waste that is generated within their boundaries
(although the provision requiring states to take title to the waste if
disposal was not provided was overruled by the US Supreme Court in
1992). NRC should not undercut states by preempting their ability to set
standards that are more protective than federal requirements. This
undercuts states’ ability to be responsive to its citizens and
residents.
NRC should retain and expand the ability for states to
be more protective, to regulate more strictly than the federal 10 CFR
61 regulations. This was part of the commitment and incentive to
encourage and enable states to site new nuclear waste disposal sites.
Changing the rules now looks a lot like a broken promise. It is
predicted that there will be a need for new waste sites in the decades
to come. Reneging on previous commitments and insisting that states
adopt the more lax regulations that NRC is proposing will make that more
difficult.
Rather than relaxing standards and advocating for
more hazardous and long-lasting waste going into waste sites, the US
NRC, at minimum, should be enforcing the existing requirements and
regulations and holding states to those.
In cases the state or
states that are increasing the risks to the public or providing weaker
protections that 10 CFR 61 currently allows, NRC should assert its
authority to maintain federal standards and require Agreement States to
do so. This rulemaking appears to be an effort by NRC to join the lower
common denominator, at least with DU, projections of long term doses
from closed facilities and possibly other provisions.
è “Below Regulatory Concern-”
deregulates,
exempts and releases radioactive waste and materials from radioactive
regulatory control. NRC under its 10 CFR 20.2002 process allows
radioactive waste, material and sites to be managed without radioactive
regulatory controls on a case by case basis. Applications for these
exemptions are not easily publicly available thus devoid of necessary
options for public input and intervention. We are not aware of public
reporting of 10 CFR 61.6 applications and call on NRC to stop treating
nuclear waste, property and materials as if not radioactive whether it
goes to solid, hazardous or other facilities and especially if it is
allowed into the recycling streams or is released for unrestricted or
restricted use.
DELETE the added phrase in proposed rule under
§61.7 Concepts …“Alternative methods of disposal may be approved on a
case-by-case basis as needed under § 61.6.” (Page 9 of the Comparison
between Current Rule Language and Rule Language in Proposed Rule,
"Low-Level Radioactive Waste Disposal” (80 FR 16082)). The NRC must not
forget that the American public and our elected officials have
repeatedly rejected the deregulation of nuclear waste. It should not be
inserted into this rule which is about licensed radioactive disposal.
The proposed rule re-asserts the publicly rejected concept of
deregulation and we demand the deletion of this and any provisions that
allow for manmade radioactive waste, materials, emissions and practices
to be released from radioactive regulatory control. Deregulation,
release, exemption, clearance and deminimus are completely unacceptable.
DELETE
the existing § 61.6 Exemptions[6] from the regulations. If it is
retained, at minimum, CLARIFY that there is must be advance public
notice, comment and opportunity for hearing, adjudicatory hearing and
intervention, as with other license amendments and changes in
regulations. Public notice, comment and opportunity for intervention
should be required for any and all exemption, clearance, release of
radioactive waste or materials from radioactive regulatory control.
è We oppose increasing the amount and longevity of radioactivity that goes into shallow land burial.
The
proposed rule would allow even longer-lasting waste into unlined soil
trenches than the current regulations—waste that will be dangerous much
longer than the sites will be controlled or monitored. These include:
o
Plutonium-239 (240,000 to 480,000 year hazard) and iodine-129 (160 to
320 million year hazard) from nuclear power reactors, are already
allowed in set concentrations in dumps that can be institutionally
controlled for up to just 100 years. Sierra Club and other public
interest and environmental groups have called for limiting the waste
that can go into these dumps to that which is hazardous for 100 years or
less. Pennsylvania extended the institutional control period so if a
facility is opened in that state, the site would be tracked longer than
NRC assumes. Rather than consider the public demands for letting only
shorter-lasting waste into the burial grounds, NRC is now opening the
door to very large amounts of long-lasting waste and waste that gets
more radioactive as it decays into other more radioactive materials. We
direct that NRC analyze and adopt stricter disposal site requirements,
keeping long-lasting waste out of shallow burial sites.
o
Uranium, referred to as Depleted Uranium (DU) after much of the
uranium-235 is removed to make nuclear power fuel and weapons, because
it is “depleted” of that one isotope, is biologically hazardous and
radioactive due to all the other uranium isotopes present and the decay
products of those isotopes increase in radioactivity over time. Thus DU
can deliver increasing doses to the public, giving the peak or highest
dose in more than 2 million years. (See
http://www.deq.utah.gov/businesses/E/EnSolutions/depleteduranium/
and http://www.healutah.org/campaigns/nuclear-utah/nuclear-waste/ )
We support HEAL Utah, Institute for Energy and Environmental Research’s
(IEER) and all other technical comments throughout this entire
rulemaking process against allowing DU into shallow land burial sites
and opposing its de facto inclusion in Class A with no justifiable,
technical analysis. NIRS and IEER challenged the commercial generation
of more DU during the licensing of the LES uranium enrichment facility
now operating in New Mexico. We continue to hold that DU is not
“low-level” waste or Class A, and that there is no safe permanent way to
“dispose” or isolate it from the public and the environment. Because of
the longevity of the hazard, it must be considered high level
radioactive waste, or at least Greater than Class C, unsuitable for
shallow land burial. We oppose the default and pretense NRC is making to
allow it into shallow land burial where it cannot be isolated for the
length of it hazard.
o “Dirty” DU:
So-called Depleted
Uranium or DU could have and has had fission products present which
exacerbate the health effects even further. Uranium recovered from the
reprocessing of highly radioactive irradiated nuclear fuel, became
highly radioactive and was sent back through enrichment facilities
without notifying or protecting the workers from this deadly additional
hazard. The DU generated during that subsequent enrichment processes was
contaminated with fission products as well as the heavier transuranic
residue that came with the “dirty” uranium. Absolutely no calculations
have been done for this rulemaking by NRC nor are there requirements for
disposal licensees to include such information in their Performance
Assessments. This is a clear example that the process will not protect
the public and environment. There is no justification for failing to
incorporate this reality into the rulemaking, further discrediting the
inadequate assessments of harm this proposed rule presents. We submit as
attachments to these comments emails between NIRS and NRC regarding
this omission including the actual Washington Post investigative reports
on this scandal which resulted in involuntary, uninformed exposures of
workers to fission products at enrichment facilities and failure to
provide protection. Many other parameters of the Performance Assessments
would change with this correction. Accurate inclusion of this “dirty”
DU must be required in the assumptions NRC Staff and disposal companies
have made about inadvertent intruder doses and the timeframes and
amounts of “peak exposure.” There may be several peaks that should be
factored.
o High level radioactive waste from reprocessing of
irradiated fuel—dubbed “Waste Incidental to Reprocessing” or even other
high level waste could theoretically be disposed in shallow land burial
grounds. Commercial reprocessing is not happening now and NRC should not
change its rules to accommodate reprocessing. In 2002 NRC had to admit
that the only commercial reprocessing site in the US, at West Valley,
NY, which only operated for 6 years, could not comply with the NRC
License Termination Rule (10 CFR 20 subpart E), thus stated that it
would require significant “flexibility.” In the intervening years,
despite DOE’s successful solidification of the primary extraction liquid
into 275 high level radioactive waste “logs” at West Valley and the
generation of huge amounts of waste in other waste streams, it is
projected to cost roughly $5 Billion to clean up the reprocessing waste
and another ~$5 Billion to clean up the commercial “low-level”
radioactive burial ground, which operated for about a dozen years, at
West Valley. NRC is failing to consider the long term costs of its
weakened 10 CFR 61 regulations.
o Other “unique” waste streams
never originally intended for such unlined shallow land burial grounds
have no business being thrown in the ground at the behest of the
profit-making operators of waste sites. We understand that NRC wants to
“solve” as many waste problems as it can, but pretending burial will
isolate waste, and removing dose limits that could prevent burial are
not acceptable. We demand that NRC strengthen the dose limits…make them
low enough to protect the reproductive stage of our life cycle from not
only cancer but all other radiation-induced negative health effects,
including but not limited to teratogenic and genetic.
o Blended waste and Averaging
Since
the 1982 rule10 CFR 61 was adopted, NRC decided to only make a waste
classification at the point of disposal, to facilitate all sorts of
processing, largely done in Tennessee but also in other states including
Ohio. This has led to unnecessary transport and routine radioactive
releases to the environment around processing facilities.
A
disturbing idea is being considered of bringing waste to disposal site
and then AVERAGING the amount of radioactivity with the amount of
radioactivity already at the site to allow much more radioactivity and
higher concentration waste to be buried.
è NRC is not abandoning
the A B C and >C concentration tables 10 CFR 61.55 but providing many
other methods to comply and apparently leaving it up the waste
operator, not the state or the public.
è NRC creates and
exacerbates a serious conflict of interest by encouraging and permitting
profit-making dump-operators to do their own computer models and
projections to allow more radioactive and longer lasting waste into
trenches. NRC’s claim that computer- generated “Performance Assessments”
can predict a “Safety Case” is false. Increasing hazards does not
provide greater protection.
o NRC admitted that it had not
considered that some uranium is laced with fission products. As we
stated above, some reprocessed uranium was put through uranium
enrichment facilities. NRC should be aware of this well documented and
publicly disclosed history at Paducah and reflect it and other such
historical knowledge. It is not clear if other sites may also have
similar wastes, and certainly if the ill-advised prospect of
reprocessing is pursued, there will be more.
o NRC admits that Waste Incidental to Reprocessing possibly could go to shallow land burial.
o
Greater-that Class-C waste and transuranics above 10 or 100 nanocuries,
previously guaranteed NOT to go to these facilities would be allowed.
o
Dump operators will make more money; generation of more new waste will
be encouraged; the public will not be protected. The NRC, some Agreement
state regulators and the waste site operators are making no “safety
case” for us, the public.
è NRC’s proposed rule would allow
higher amounts of radioactive exposure --higher doses and in some cases,
unlimited radiation doses to the public, as mentioned above.
o
First, this done by “updating,” using a different way to calculate
doses which allows more radioactivity per millirem or unit of dose for
many of the radionuclides. Depending on which radionuclides are being
considered, there can be different amounts in each new millirem EDE (the
‘updated’ dose units) than in each of the existing millirems in the
current rule. Neither of these are ever measured, verified or enforced.
They serve to justify allowing more radioactivity in the waste and waste
sites. We oppose the adoption into 10 CFR 61 of the 10 CFR 20 (ICRP 26
or 60) methods of dose calculation in all cases that increase
radioactivity per millirem, or increase allowable releases and
exposures.
o Second, NRC is increasing and allowing unlimited
millirems/year. The existing rule limits doses to the public during
operations to 25/75/25 millirems per year and does not expressly specify
higher amounts post-closure. This would be an enormous relaxation of
the standards and must be dropped. NRC opening these sites to DU is a
mistake since the radioactivity/radiation levels will rise over time. At
one time DU was expected to be part of wastes that should be
permanently isolated from our environment like irradiated fuel. NRC
should adopt that plan for DU.
è Radiation is more dangerous for females, youth, and threatens the reproductive stage of the human and other life cycles.
The
proposed rule ignores the now-known reality that external ionizing
radiation causes 50% more cancer and fatal cancer in female adults
compared to male adults and 7 times more cancer incidence when the
exposure happens in very young females, compared to exposure of adult
males.[7] Young males and females are both at higher risk, but half of
the global population needs greater protection and NRC dodges this in
its role as regulator. This is irresponsible. Juvenile females are not a
“subpopulation” they are an inextricable link in the human lifecycle.
There is no biological “Reference Man” who did not come from someone who
was in this most sensitive age group. NRC continues to unacceptably
ignore non-cancer health effects, synergistic effects with other toxic
exposures and reproductive effects.
è NRC should not
“update” the radiation dose part of this regulation 10 CFR 61 by
incorporating its 10 CFR 20 standards because those are less protective
than 10 CFR 61 current limits. Any change should “update” the
scientific reality that radiation is more harmful than previous
assessments identified and reduce allowable releases and exposures.
NRC
is failing to protect the reproductive phase of the human lifecycle
(and that of all other species as well). We have commented on this in
the 10 CFR 20 rulemaking and oppose expanding those failures to protect
from radiation into this regulation 10 CFR 61. Radiation is clearly
being found to be more harmful every time it is reviewed (rather, each
batch of new data shows that regulators have failed repeatedly to
honestly report the true hazards of ionizing radiation) yet NRC
stubbornly moves to let the radioactive pollution levels rise as it
increases allowable concentrations and emissions into air and water and
doses to this and future generations. Scientifically, it is
unacceptable.
è There is no limit or parameter on the Performance
Assessment. Allowing the option of the waste site operator choosing his
or her own allowable dose level, means pretty much any kind of waste
can go to these sites. This is worsened by the fact that allowable dose
limits are used for calculations only, never enforced or verified; It is
not scientifically justifiable for NRC to raise the numbers so
Performance Assessments and Safety Cases, by those who stand to profit,
can be done allowing more dangerous and long lasting wastes into shallow
land burial sites.
It is a conflict of interest to allow those
who profit from disposal, the waste site owners and or operators, to do
essentially “black box” calculations to allow more dangerous nuclear
waste into their own facilities. The rule should not have this provision
and any provision it does have should have a requirement for public
notification, comment, intervention and intervener funding.
è The
Emergency Access Clause, Section 6 of the Low Level Radioactive Waste
Policy Act, provides that in emergency situations, operating nuclear
waste facilities could be required to take waste not normally designated
or intended. We have always contended that sites must not be required,
forced, or allowed to take wastes for which they were not originally
intended or characterized. The proposed regulations could do the exact
opposite, provide for any kind of radioactive waste to be accepted.
Under the Environmental Protection Agency’s Protective Action Guides,
such facilities could be expected to take large amount of waste from
emergencies. States should not be forced to accommodate the nuclear
industry polluters in this way. It is time for the federal regulators to
adopt a role of incentivizing waste reduction, not the opposite.
è
Performance Assessments are tools that can easily be used to justify
polluting practices and facilities, not just radioactive. They are not
practically transparent or reviewable by the public. We support HEAL
Utah’s comments on 10 CFR 61 against Performance Assessments.
Performance
Assessments are only predictions and especially not trustworthy when
carried out by those who stand to profit from the conclusions.
NRC
highlights the Performance Assessment proposed for the West Valley
nuclear waste site in its 10 CFR 61 Technical Guidance,[8] but the
public opposes the Performance Assessment being planned for that site
because the Agencies responsible refuse to provide transparency and the
public is being denied input on the contractor, real time access to the
necessary assumptions, documents, expert declarations, computer programs
and codes and resources to hire independent reviewers. The West
Valley experience should be a warning for communities and states where
other nuclear waste sites are located. The site itself has been
estimated to cost $9.7 billion to fully clean up and it threatens to
release its contents into the surrounding streams and the Great Lakes.
The performance assessment is being carried out to justify leaving waste
in rapidly eroding unstable ground.
è Both the current and
proposed 10 CFR 61 allow for unlined soil trench burial of radioactive
wastes that will inevitably leak out. Both fail to protect the public.
The current regulations should be strengthened and the proposed rule
which allows higher radiation exposure to the public than operating
nuclear reactors or a high level radioactive waste repository should be
scrapped.
[1] 40 CFR 197
[2] Millirems are units of
dose that cannot be verified or enforced but that are used to justify
planned routine releases from nuclear facilities.
[3] EPA 40 CFR 190
[4]
Proposed 10 CFR 61.41b allows the dump operator to do a calculation
projecting a dose “…level that is supported as reasonably achievable
based on technological and economic considerations…”
[5] ** Calculation to be provided
[6]
Existing regulation: 10 CFR § 61.6 Exemptions. The Commission may, upon
application by any interested person, or upon its own initiative, grant
any exemption from the requirements of the regulations in this part as
it determines is authorized by law, will not endanger life or property
or the common defense and security, and is otherwise in the public
interest.
[7] See: “Atomic Radiation is More Harmful to Women” October, 2011:
http://www.nirs.org/radiation/radhealth/radiationwomen.pdf as well as other items on radiation and gender posted:
http://www.nirs.org/radiation/radhealth/radhealthhome.htm
[8]
D. Esh, C. Grossman, H. Arlt, C. Barr, P. Yadav, "Guidance for
Conducting Technical Analyses for 10CFRPart 61." Nuclear Regulatory
Commission, Office of Nuclear Material Safety and Safeguards, 2015. <
http://pbadupws.nrc.gov/docs/ML1505/ML15056A516.pdf>.file:///U:/My%20Documents/LLRW/10-cfr-part-61%20redline%20changes.pdf
