LLW Forum Notes (11)llwforum.org/wp-content/uploads/2016/12/marapr02Notes.pdf · 2017-01-16 ·...

LLW Notes March/April 2002 1

National Research Council Releases Report re Dispositionof Slightly Radioactive Material (Clearance Rule)

LLWnotes

LLW Forum, Inc. 2227 20th Street N.W., Unit 301 Washington D.C. 20009 (202) 265-7990 FAX (202) 265-7995 E-MAIL [email protected] INTERNET www.llwforum.org

Volume 17, Number 2 March/April 2002

National Academies of Science

In This Issue

Legislaiton Introduced in California re Disposal Facility Licensingpage 12

Maine Drafts Legilation to Withdraw from Texas Compactpage 13

Transportation: DOT Study Expected Shortly, While NRC ContinuesRevisionspage 20

health, economic, and environmental impacts,among others.

The committee also reviewed NUREG-1640, adraft NRC report that provides technical guidanceon future policy revisions. The committee foundthe methodology used in the draft guidance toassess potential health effects associated withsalvage or disposal to be "state of the art," butrecommended the consideration of additionalscenarios for disposition, alternative exposurepathways, and the impact of human error. Thecommittee's report suggests using 1 millirem peryear as a starting point for determining anappropriate dose-based standard for the dispositionof material.

The committee's report looked at three generalcategories for the disposal of slightly radioactive

(Continued on page 20)

On March 21, the National Academies of Sciences'National Research Council publicly released its re-port regarding the disposition of slightly radioactivesolid material. The report, which is titled "TheDisposition Dilemma: Controlling the Release ofSolid Materials from Nuclear RegulatoryCommission-Licensed Facilities," is the result of ayear-long study performed by a committee ofexperts put together by the National ResearchCouncil at the Nuclear Regulatory Commission'srequest. (See LLW Notes, January/February 2001,p. 20.)

In particular, the Commission asked the ResearchCouncil to recommend changes to the decision-making process for the disposition of slightly radio-active solid material and to determine whethersufficient technical information exists to establish aconsistent system nationally. The Research Councilcommittee's report finds that NRC's decision-making process is "workable" and protective of thepublic health and safety. However, the report statesthat NRC's process "could benefit from a newframework that uses broad input fromstakeholders—including the general public—todevelop and evaluate options for disposal, reuse,and recycling." The committee proposed aframework, which is intended as a policy-makingtool only, that incorporates the need to assess

2 LLW Notes March/April 2002

Low-Level Radioactive W aste Forum, Inc.

Low-Level Radioactive Waste Forum, Inc. 2227 20th Street N.W., Unit 301 Washington, DC 20009 (202) 265-7990 FAX (202) 265-7995 E-MAIL [email protected] INTERNET www.llwforum.org

LLW FORUM, INC

Key to AbbreviationsU.S. Department of Engergy.............................................DOEU.S. Department of Transportation.................................DOTU.S. Environmental Protection Agency ...........................EPAU.S. General Accounting Office...................................... GAOU.S. Nuclear Regulatory Commission ............................. NRCNaturally-occuring and accelerator-producedradioactive material.......................................................... NARMNaturally-occuring radioactive material.......................NORMCode of Federal Regulations .............................................. CFR

LLW NotesVolume 17, Number 2 March/April 2002

Editor and Writer: Todd D. LovingerLayout and Design: Rita Houskie, Central Interstate Low-Level Radioactive Waste Compact

LLW Notes is published several times a year and is distributed to the Board of Directors of the Low-Level Radioactive Waste Forum, Inc. - an independent, non-profit corporation. Anyone - including compacts, states, federal agencies, private associations, companies, and others - may support and participate in the LLW Forum, Inc. by purchasing memberships and/or by contributing grants or gifts. For information on becoming a member or supporter, please go to our web site at www.llwforum.org or contact Todd D. Lovinger - the LLW Forum, Inc.'s management contractor - at (202) 265-7990. The LLW Notes is owned by the LLW Forum, Inc. and therefore may not be distributed or reproduced without the express written approval of the organization's Board of Directors. Directors that serve on the Board of the Low-Level Radioactive Waste Forum, Inc. are appointed by governors and compact commissions. The LLW Forum, Inc. was established to facilitate state and compact implementation of the Low-Level Radioactive Waste Policy Amendments Act of 1985 and to promote the objectives of low-level radioactive waste regional compacts. The LLW Forum, Inc. provides an opportunity for state and compact officials to share information with one another and to exchange views with officials of federal agencies and other interested parties.

Table of ContentsFederal Agencies and Committees (Cover Story) ................................................. 1National Research Council Releases Report re Disposition of SlightlyRadioactive Material (Clearance Rule) ........................................................................ 1Low-Level Radioactive Waste Forum, Inc .............................................................. 3LLW Forum Holds Meeting In Charleston, South Carolina ......................................... 3US Army Becomes Associate Member........................................................................ 4States and Compacts ................................................................................................ 5S.C. House Votes to Use Barnwell Funds to Balance Budget.................................... 5Radioactive Waste Disposal Referendum Initiative Filed in Utah re New Taxesand Policies (Including Class B and C Waste Disposal Prohibition)........................... 5Envirocare Response to Radioactive Waste Disposal Referendum Initiative ............ 7Utah Radiation Control Board Grants Summary Judgement to Envirocarere 8 of 9 Issues on Appeal ........................................................................................... 8Potentially Radiologically Contaminated Tools Removed from Envirocare;May Have Been Sold to the Public ............................................................................ 10New Jersey Waste Shipments to Colorado Delayed ................................................ 11New Officers Elected to Southeast Compact Commission ....................................... 11Legislation Introduced in California re Disposal Facility Licensing ........................... 12Maine Drafts Legislation to Withdraw from Texas Compact ..................................... 13Courts ....................................................................................................................... 14Intervention Denied in USE’s Promissory Estoppel Action Against California ......... 14Court Throws Out New California Waste Regulations .............................................. 15Romano Appointed CEO of American Ecoloey......................................................... 15DOE Sues Nevada re Yucca Water Permits ............................................................. 16GAO/Congressional Leaders Sue Over White House Energy Policy....................... 16Russian Supreme Court Prohibits Hungary Imports ................................................. 17Russia’s Cleanup Work to be Funded by Processing Foreign Waste ...................... 17Congress................................................................................................................... 18NRC’s FY 2003 Budget Now Available ..................................................................... 18Whistleblower Bill Introduced in Congress ................................................................ 18NCRP Says Consistent Scrap Metal Standards Needed.......................................... 14GAO Report: Fundmental Reassessment of DOE Needed..................................... 15GAO Issues Report re Adequacy of Decommissioning Funds ................................. 15Federal Agencies and Committees (continued)................................................... 19Sources Lost in Foreign Countries ............................................................................ 19DOE Proposes Rule to Protect Classified Info .......................................................... 19Transportation: DOT Study Expected Shortly, While NRC Continues Revisions..... 20Hearings Set re Skull Valley Proposed Spent Fuel Facility....................................... 21NRC Opens New Security Office ............................................................................... 22Revision 2 of Draft Yucca Review Plan Now Available............................................. 22NRC Orders Increased Reactor Security................................................................... 23NRC to Exempt Umetco from Groundwater Cleanup Requirements ....................... 23Annual Report Issued by NRC Office of Enforcement .............................................. 24ASLB Orders Goshutes to Detail Payment Information; NRC Blocks Ruling ........... 24NRC Issues Annual Assessment Letters to Nuclear Power Plants. ......................... 25NRC Proposes to Amend Fee Schedule................................................................... 25Bush Recommends Yucca Mountain; Nevada Governor Exercises Veto ................ 26Mayors Write Bush re Rad Waste Transport............................................................. 26Obtaining Publications............................................................................................ 27


Low-Level Radioactive W aste Forum, Inc.

LLW Forum Holds Meeting InCharleston, South CarolinaThe Low-Level Radioactive Waste Forum, Inc.met in Charleston, South Carolina on March 11and 12, 2002. The LLW Forum ExecutiveCommittee met on March 10. Sixteen LLWForum Directors, Alternate Directors, andmeeting designees representing fifteen differentcompacts, host states, and unaffiliated statesparticipated in the meeting. In addition, threeAssociate Members representing two differentfederal agencies participated, as well as fourteenother state and compact representatives. Otherindividuals representing five different federalagencies attended, as did representatives fromfacility operators, industry organizations, and theprivate sector.

Topics Discussed

During the course of the two day meeting,attendees heard presentations on the followingtopics, among others:

♦ new developments in states and compacts;

♦ an Illinois Low-Level Radioactive WasteManagement Report which contains economicmodeling of disposal facility development, aswell as information on the relationshipbetween the timing of waste receipts anddisposal fees;

♦ industry and NRC perspectives on theentombment option for the decommissioningof nuclear utilities;

♦ updates regarding the Barnwell, SouthCarolina and Envirocare of Utah low-levelradioactive waste disposal faclities;

♦ an update on NRC activities, including agencyaction on Big Rock Point Plant’s proposal todispose of demolition debris with tracequantities of licensed material, the issuance of

a draft supplement to the final environmentalimpact statement on the decommissioning ofnuclear facilities, and the status of licenserenewal requests;

♦ the U.S. Environmental Protection Agency’sfinal rule on the storage, treatment,transportation and disposal of mixed waste;

♦ privatization of the Low-Track System;

♦ security at nuclear power plants;

♦ a proposal regarding the creation of acentralized agency to regulate radioactivematerials;

♦ a draft agreement between states andcompacts and the U.S. Department ofDefense regarding the department’s wastemanagement practices;

♦ the U.S. General Accounting Office’s recentreport on the adequacy of NRC’s assurancesof decommissioning funding during utilityrestructuring; and

♦ the disposal of waste from the FormerlyUtilized Sites Remedial Action Program(FUSRAP) by the Army Corps of Engineers.

In addition, at the Executive Committee meetingon March 10, Kevin Crowley gave a presentationon plans by the National Academies of Sciencesto conduct a study on improving practices for theregulation and management of “low activity”radioactive waste in the United States. The studywill be conducted by a 15-member NationalResearch Council committee that has not yet beenselected. (See LLW Notes, January/February2002, pp. 1, 9–10.)

Other Items of Interest

During the course of the meeting, it wasannounced that the Low-Level Radioactive WasteForum has been awarded a one-year grant of up


to $150,000 from the U.S. Department of Energy,commencing March 2002. LLW Forum membersdiscussed ways in which the additional moniesshould be used to assist members and theorganization in its operations and expressed theirsincere appreciation to DOE for the requestedfinancial assistance.

Actions Taken

Election of Executive Committee and OfficersDuring the course of the meeting, the followingpersons were elected to serve on the ExecutiveCommittee and/or as officers of the LLW Forum,Inc. in 2002:

♦ Max Batavia of the Atlantic Compact,

♦ Kathryn Haynes of the Southeast Compact(Chair),

♦ William Sinclair of the State of Utah,

♦ Leonard Slosky of the Rocky MountainCompact (Vice Chair),

♦ Thor Strong of the State of Michigan,

♦ Terrence Tehan of the State of Rhode Island,and

♦ Stanley York of the Midwest Compact(Secretary/Treasurer).

Resolutions During the course of the meeting,various resolutions were passed by the Board ofDirectors, including:

♦ approval of 2002 budget adjustments andauthorization to officers to make any furtheradjustments that they deem necessary;

♦ authorization to the officers to take theadministrative and management stepsnecessary to implement the DOE grant; and

U.S. Army BecomesAssociate Member

The U.S. Army recently became the secondfederal agency to purchase an AssociateMembership in the Low-Level RadioactiveWaste Forum. Other federal agencies—including the U.S. Nuclear RegulatoryCommission—are reported to also beconsidering membership, while still others—such as the U.S. Environmental ProtectionAgency—have purchased specific servicesfrom the organization.

For additional information about becoming a member,please go to the LLW Forum’s web site atwww.llwforum.org or contact Mr. Todd D. LovingerLovinger—the LLW Forum’s ManagementContractor—at (202) 265-7990.

♦ expressions of appreciation to Governors whosupported the LLW Forum’s grant request andto the U.S. Department of Energy for therequested financial assistance.

Low-Level Radioactive W aste Forum, Inc. continued


Northwest Compact/Utah

Radioactive Waste DisposalReferendum Initiative Filed inUtah re New Taxes andPolicies (Including Class B andC Waste Disposal Prohibition)On April 3, a statewide ballot initiative was filed inUtah that seeks, among other things, to imposesubstantial taxes on the disposal of out-of-statelow-level radioactive waste and to prohibit thedisposal of Class B and C radioactive waste withinthe state. The initiative, which promotes draftlegislation titled the “Radioactive WasteRestrictions Act,” is being sponsored by Utahnsfor Radioactive Waste Control. Also supportingthe initiative are the Utah Education Association(UEA), the Utah Crusade for the Homeless,former state Governor Calvin Rampton, andMickey Gallivan—the son of Salt Lake Tribunepublisher emeritus John Gallivan. In order to getthe initiative on the ballot for the Novemberelections, proponents must procure in 20 ofUtah’s 29 counties the signatures of registeredvoters equal to at least 10 percent of the votes castin the last gubernatorial election—approximately77,000 signatures—by the May 31 deadline.

Tax on the Disposal of Out-of-State Low-Level Radioactive Waste

The Proposed Tax Proponents of thereferendum initiative claim that it could generateas much as $200 million annually—which monieswould be earmarked for education, environmentalregulation, economic development, and assistanceto the impoverished and homeless. Specifically,the initiative calls for the imposition of a time-of-disposal tax—the amount of which tax woulddepend on the kind of low-level radioactive wastebeing disposed of in Utah—as well as a grossreceipts tax of 15 percent on radioactive wastedisposal facilities operating in the state.

Atlantic Compact/South Carolina

S.C. House Votes to UseBarnwell Funds to BalanceBudgetThe South Carolina House voted on April 17 totake $61 million from the cleanup fund for theBarnwell low-level radioactive waste disposalfacility and use it to balance this year’s budget,which has an estimated $74 million shortfall.Budget work is stalled in the Senate, however,where members continue to debate a proposedcigarette tax.

Under the House plan, 40 percent of the moniestaken from the Barnwell fund will go to localschool districts, with the remainder going into thegeneral fund to help make up for a 1.5 percent,across-the-board budget reduction. This will leavethe fund with a balance of approximately$300,000. Last year, legislatures took more than$38 million out of the Barnwell cleanup fund toprotect colleges from budget cuts.

In addition to voting to take money out of thefund, however, the House also passed a provisionthat will require the General Assembly to repaythe fund. The General Assembly will beresponsible for cleaning up the site, should theneed arise.

States and Compacts


States and Compacts continued In explaining the need for such taxes at a newsconference on Wednesday, initiative proponentsnoted that the State of Washington imposes aminimum tax of $20 per cubic foot on wastedisposed of at the Richland facility and the Stateof South Carolina imposes a $235 tax on wastedisposed of at the Barnwell facility. Utah, theyclaim, charges only 10 cents per cubic foot—a taxthat only covers the cost of regulation. Theproposed initiative would raise the tax in Utah tobetween $4 and $150 per cubic foot, dependingon the specific type of waste being disposed.

A press release distributed by initiative proponentsfurther described the tax as follows:

“The Radioactive Waste Restrictions Act wouldimpose a tax on each cubic foot of radioactivewaste disposed of in Utah. That rate would varydepending on the type of waste. This tax—passedthrough to the generator of the waste—would beless than that charged by the other sites thataccept such waste, but substantially more than the10-cent per cubic foot Utah currently charges.”

The act proposes the following specific surchargeson the disposal of low-level radioactive waste inUtah:

Class A LLRW – Containerized$150/ft3

Class A LLRW – Bulk Disposal$20/ft3

Mixed Waste – Containerized$150/ft3

Mixed Waste – Bulk Disposal$30/ft3

PCB Radioactive Waste – Containerized$150/ft3

PCB Radioactive Waste – Bulk Disposal$30/ft3

PCB Mixed Waste – Containerized$150/ft3

PCB Mixed Waste – Bulk Disposal$30/ft3

11e.2 Waste – Bulk Disposal$4/ft3

NORM Waste – Containerized$150/ft3

NORM Waste – Bulk Disposal$20/ft3

Envirocare’s Immediate Reaction EnvirocarePresident Kenneth Alkema was quoted in thelocal papers as calling the proposed tax “unfair,exorbitant, arbitrary and capricious” and asarguing that the initiative is based on incorrectdata about Envirocare’s business and theradioactive waste disposal market. Alkemadisputes that such a tax could raise $200 millionannually and suggests it could put Envirocare outof business.

Another Envirocare representative points out thatone of the initiatives key proponents, DougFoxley, failed in a previous attempt to site his owncompeting radioactive waste facility in TooeleCounty in 1997.

Prior Attempt re Tax In 2001, legislation wasintroduced in the Utah legislature which wouldhave imposed substantial taxes on the disposal oflow-level radioactive waste in Utah. Key portionsof the bill, however, were defeated during debateand the final version passed imposed much lowerfees and taxes than originally sought. (See LLWNotes, March/April 2001, pp. 7 – 9.)

Class B and C Disposal Prohibition

The initiative also seeks to prohibit Utah fromlicensing or siting a facility for the disposal ofhigh-level radioactive waste, greater than Class Cradioactive waste, or Class B or C low-levelradioactive waste within the state. Envirocare ofUtah previously filed an application to dispose ofcontainerized Class B and C waste at its TooeleCounty facility, which application was approved—subject to specified limitations and conditions—by the Executive Secretary of the Utah RadiationControl Board on July 9, 2001. (See LLW Notes,July/August 2001, pp. 6 – 9.) Under Utah law,however, the Governor and legislature mustapprove any new waste disposal licenses.Envirocare has announced that, at this time, it willnot seek the requisite legislative or gubernatorialapproval.


States and Compacts continued

Envirocare Response to Radioac-tive Waste Disposal ReferendumInitiativeIn response to the proposed initiative, Envirocareput out a press release stating that it must be a“cruel hoax” and asserting that “[t]he proposed$200,000,000 tax would exceed Envirocare’s totalrevenues and would essentially ‘kill the goldengoose.’” Envirocare President Ken Alkema fur-ther stated that the proposed initiative “has noth-ing to do with helping education or the homelessand would effectively put 400 people out ofwork.”

In its press release, Envirocare argues that theproposed initiative targets one company and pun-ishes them for being successful. “Our companyprovides jobs, revenues, taxes and fees to TooeleCounty, the state of Utah, and the nation. It im-proves the environment by helping to provide asafe, appropriate place to permanently dispose oflow-level radioactive waste,” commented Alkema.“This tax is patently unfair and unconstitutional.”

Envirocare argues that the numbers presented inthe proposed initiative are inaccurate and mislead-ing because

♦ they are based on Envirocare’s volume ofwastes and not on the radioactive content ofthe wastes,

♦ Envirocare takes in more volume, but far lessradioactivity than its competitors,

♦ it is improper, given the above, to comparethe Envirocare facility to those at Barnwelland Richland, and

♦ it is significant that the Barnwell and Richlandfacilities are owned by the states and take classB and C wastes, which can support muchhigher taxes.

Various entities appealed the Executive Secretary’sJuly 9 decision. On March 1, the Utah RadiationControl Board granted summary judgment infavor of Envirocare of Utah on eight of the nineissues raised on appeal. The remaining issue iscurrently pending before the Board. (See LLWForum News Flash titled, “Utah RadiationControl Board Grants Summary Judgment toEnvirocare re 8 of 9 Issues on Appeal:Intervention Denied re Containerized Class ALicense Amendment,” March 19, 2002.)

Other Aspects of the Proposed Initiative

In addition to imposing new and additional taxeson the disposal of radioactive waste in Utah andprohibiting the disposal of certain types of waste,the proposed initiative also seeks to “[a]dequatelycapitalize[] the Perpetual Care and MaintenanceFund to finance perpetual care of the [Envirocare]facility and for its eventual closure.” The proposalalso seeks to increase the quality of monitoring ofdeposited radioactive waste, clarify the definitionsof all radioactive waste, and prohibit the furtherlicensing of radioactive waste disposal facilities inthe state.

The Radioactive Waste Restrictions Act promotedby the proposed initiative also contains ethicalprotections that further regulate the relationshipsbetween Utah Department of EnvironmentalQuality employees, Radiation Control Boardmembers and disposal operators.

DEQ Review

The Utah Department of Environmental Qualityis currently evaluating the proposal and has notedthat the initiative raises some important technical,policy, administrative, and constitutional issuesthat will impact the future regulation ofradioactive waste in Utah. The initiative makesnumerous changes to the current RadiationControl Act, which would become effective aswritten if enough signatures are garnered to get iton the fall ballot and the initiative passes.


States and Compacts continued ♦ the legislature must authorize sufficient

resources to the Division of Radiation Controlto oversee transportation and disposalactivities associated with the license. Atentative decision to approve Envirocare’slicense request was originally issued onJanuary 2, 2001. (See LLW Notes, January/February 2001, pp. 1, 6.)

Envirocare’s Decision Not to Seek Legislativeor Gubernatorial Approval Shortly after thelicense request was approved, Envirocare issued astatement that “[a]fter careful consideration,Envirocare has determined it will not seeklegislative or gubernatorial approval for its Class Band C low-level radioactive waste proposal.”Under Utah law, the Governor and legislaturemust approve any new waste disposal licenses.Envirocare’s decision was attributed to publicconfusion between the companies proposal andthat of the Goshute Tribe and Private FuelStorage (PFS) to accept high-level spent fuel rodsfrom nuclear power plants.

The legislative session concluded on March 6,2002 with no action being taken. A final agencyaction must occur prior to any legislative orgubernatorial action.

Summary Judgment In late 2001, five groupsfiled appeals to the Executive Secretary's decision.Three of them were granted intervenor status: (1)Families Against Incinerator Risk (FAIR), (2)Utah Legislative Watch, and (3) Citizens AgainstRadioactive Waste. A fourth, Sierra Club,withdrew its petition to intervene at a hearing onJanuary 4, 2002. A decision regarding intervenorstatus of the last appellant, the U.S. Air Force, wasdelayed pending potential resolution of the issuesthat the Air Force brought before the board. Allparties agreed that the Air Force issues could bedecided separately on an issue and timing basis.

The March 1 grant of summary judgment goes tothe following eight issues:

♦ whether issuance of the license applicationposes an unreasonable risk to the health andsafety of the public;

Utah Radiation Control BoardGrants Summary Judgment toEnvirocare re 8 of 9 Issues onAppealIntervention Denied re ContainerizedClass A License AmendmentOn March 1, the Utah Radiation Control Boardgranted summary judgment in favor of Envirocareof Utah on eight of nine issues raised in appeals ofthe Executive Secretary’s July 9 decision toapprove—subject to specified limitations andconditions—the company's application to receiveand dispose of containerized Class A, B, and Clow-level radioactive waste at its facility in TooeleCounty, Utah. (See LLW Notes, July/August2001, pp. 6 – 9).

On the same date, the Board denied FamiliesAgainst Incinerator Risk (FAIR) standing tointervene in the issuance of a license amendmentto allow Envirocare to dispose of containerizedClass A waste in an existing cell.

Containerized Class A, B and C Application(New Cell)

Approval of the License Request The July 9technical decision to approve Envirocare’s licenserequest is based on a review by the Utah Divisionof Radiation Control and its contractor, URSCorporation, of Envirocare’s application,supporting technical documents and publiccomments. It contains the following conditions:

♦ the legislature and Governor must bothapprove the facility;

♦ the legislature must determine ownership ofthe site after 100 years of closure of thefacility; and



♦ whether proper procedures were followed ingranting an exemption to land ownershiprequirements;

♦ whether the land ownership exemptionpreviously granted for Class A waste can beproperly applied to Class B and C wastedisposal;

♦ whether it was improper to issue a licensewithout the site access program being in place;

♦ whether issues regarding assumption ofownership were properly dealt with prior toissuance of the license;

♦ whether the license contains improperconditions and was improperly issued;

♦ whether the licensing decision violatescompact law; and

♦ whether there was improper bias andprejudice on the part of the Board.

One issue - whether Envirocare's emergencyresponse and contingency plans are adequate -was denied summary judgment. The Board gaveFAIR until March 15 to raise any other issues that"may have been missed." Envirocare will thenhave until March 25 to respond to any such filingby FAIR. A hearing on any others that are raisedby FAIR prior to March 15, will be held at theBoard's April 5 meeting. Parties will present aschedule for hearing at the April 5 meeting for theoutstanding issue.

Containerized Class A Amendment (ExistingCell)

Background On November 19, the UtahRadiation Control Board received from FamiliesAgainst Incinerator Risk a Request for AgencyAction and Review and Petition to Intervene inthe matter of the issuance of license amendment#12 to Envirocare of Utah. The license

amendment, which was issued by the Board’sExecutive Secretary on October 19, amendsEnvirocare’s existing license to allow the companyto receive and dispose of containerized Class Alow-level radioactive waste in the existing cell atEnvirocare’s facility in Tooele County, Utah. (SeeLLW Notes, September/October 2001, p. 7.)FAIR contests the issuance of the licenseamendment and requests, among other things,that it be invalidated.

For an explanation of the issues raised by FAIR in itsappeal, see LLW Notes, November/December 2001, pp. 7 - 8.

Denial of Standing The March 1 decisiondenied FAIR standing to intervene in the issuanceof the license amendment by a 10 to 0 vote.Administratively, for the Utah Division ofRadiation Control, the denial constitutes a "finalagency action." However, FAIR may appeal theBoard's decision to deny standing to the UtahCourt of Appeals.

Documents related to Envirocare’s application for thedisposal of containerized Class A, B and C radioactivewaste—including a copy of Envirocare’s license application,the draft Safety Evaluation Report, the draft RadioactiveMaterials License, and the draft Groundwater DischargePermit—as well as to the company's application to disposeof containerized Class A waste in the existing cell areavailable for review and downloading on the Division ofRadiation Control’s website at

www.deq.state.ut_us/eqrad/drc_hmpg.htm .

For further information about the application or theappeals, please contact Bill Sinclair of the Utah Division ofRadiation Control at (801) 536-4250.


States and Compacts continued tools that may have been purchased at the TradingCompany.”

Further investigation revealed that the employeehad more contaminated tools at his house and hadsold a number of tools to the local pawn shop.Some of the tools sold by the pawn shop hadbeen sold to members of the public. Not all thetools were contaminated and a dose assessmentconducted confirmed that handling of the toolsdid not pose a significant health risk. However,the Division of Radiation Control believed it to beprudent to try to recover any contaminated toolsfor return to Envirocare for proper disposal.

All of the pawn shops in Tooele County havebeen visited by inspectors of the Division ofRadiation Control and DEQ is satisfied that theproblem is confined to the one business. Thismatter is still under investigation by the Divisionof Radiation Control. An Order to ModifyLicense Procedures and License was issued by theDivision to facilitate new preventative measures.Envirocare has and will implement the newpreventative measures.

For your information, copies of press releases from both theUtah Division of Radiation Control and Envirocare ofUtah are attached. For additional information, pleasecontact Bill Sinclair, Director of the Division of RadiationControl, at (801) 536-4255, or Kenneth Alkema, ActingPresident of Envirocare of Utah, at (801) 532-1330.

Potentially RadiologicallyContaminated Tools Removedfrom Envirocare; May HaveBeen Sold to the PublicThe Department of Environmental Quality(DEQ) of the State of Utah recently sent out aninformation notice stating that a former employeeof Broken Arrow, Inc.—a contractor forEnvirocare of Utah—allegedly removedcontaminated tools intended for disposal as wasteat the Envirocare facility and sold them toOquirrh Trading Company, a Tooele Countypawn shop. DEQ was notified of the problem byEnvirocare after the company discovered thealleged theft. The trading company’s recordsindicate that a number of tools may have beensold to members of the public from January toDecember 2001. The tools—which may includelarge ratchet and socket sets, large crescentwrenches, and other hand tools—may or may notbe marked U.S., U.S. CCC, US EC and may bepainted red. DEQ’s Division of RadiationControl recently recovered some of thecontaminated tools at the trading company. TheTooele County Health Department assessedpotentially contaminated tools brought in by thepublic at named locations and times fromFebruary 27 to March 4. Local and stateenvironmental health officials will arrange for theproper disposal of tools which are determined tobe contaminated.

“While we do not believe these contaminatedtools present any significant health threat tomembers of the public, it is prudent to make surethat these tools are rounded up and properlydisposed,” said Bill Sinclair, Director of theDivision of Radiation Control. Myron Batemanof the Tooele County Health Department stated,“We are happy to provide facilities and cooperatewith the Department of Environmental Quality inassuring that our Tooele citizens can have theopportunity to assess if there is a problem with

the state and private sectors. He served as theDirector of the Division of Radiological Health inTennessee for nearly 18 years until his retirementin 2000. He currently works as a consultant togovernment entities and private industry onmatters of radiation safety.

For additional information, contact Kathryn Haynes,Executive Director of the Southeast Compact Commissionfor Low-Level Radioactive Waste Management, at (919)821-0500.

(Continued from page 11)


States and Compacts continued Southeast Compact

New Officers Elected toSoutheast CompactCommissionAt its April 12 meeting, the Southeast CompactCommission for Low-Level Radioactive WasteManagement elected a new slate of officers—including a Chair, Vice-Chair and Secretary/Treasurer.

James Setser, who has served as one of the twoGeorgia Commissioners since the creation of theCommission in 1983, was elected Chair. He hasover thirty-eight years of professional experiencein managing environmental programs in thefederal, state and private sectors and has served asVice-Chair of the Commission since 1992. Hecurrently serves as Chief of Program Coordinationin the Georgia Environmental ProtectionDivision, the state liaison officer to the U.S.Nuclear Regulatory Commission, the Governor’srepresentative to the U.S. Department of Energy’sState and Tribal Governments Working Group,and as a technical resource to the Governor’soffice on nuclear matters. Setser replaces Dr.Richard Hodes of Florida who recently passedaway. (See LLW Notes, January/February 2002,p. 7.)

Richard Hunter was elected Vice-Chair of theCommission. Hunter, who has served as one oftwo Florida Commissioners since 1990, currentlyserves as President and CEO of Food TechnologyService, Inc. He previously worked as Florida’sDeputy State Health Officer where he oversaw,among other offices, the state Bureau of RadiationControl.

Michael Mobley was elected as Secretary/Treasurer—a position he has held since 1999.Mobley, who has served as one of two TennesseeCommissioners since 1984, has over thirty-eightyears of environmental management experience in


Rocky Mountain Compact/Colorado

New Jersey Waste Shipmentsto Colorado DelayedThe Colorado Health Department recentlydelayed the issuance of a permit to the CotterCorporation which would allow the shipment ofslightly radioactive soil from New Jersey fordisposal at the company’s uranium mill nearCanon City. The decision to delay the permitissuance was made after Colorado Governor BillOwens raised questions about the plan, saying thatthe “health department should thoroughly reviewwhether the proposed shipments from New Jerseyare covered by the Cotter Corporation’s currentpermit.” In particular, Health Department offi-cials are inquiring as to how the materials wouldbe unloaded from railroad cars, how they wouldbe stored, and how they would be tested to ensurethat they meet the facility’s permit limitations.

The waste in question consists of over 450,000tons of pre-UMTRCA mill tailings from aMaywood, New Jersey Formerly Utilized SitesRemedial Action Program (FUSRAP) site. (SeeLLW Notes, September/October 2001, pp. 15-16.)The site is being cleaned up by the U.S. ArmyCorps of Engineers.

Over 100 local residents attended a meetinghosted by the Cotter Corporation in early March,with many of them expressing opposition to thecompany’s plan. Shortly thereafter, FremontCounty Commissioners requested a six-monthmoratorium on the disposal project in letters sentto the Army Corps of Engineers, U.S. Environ-mental Protection Agency Administrator ChristineWhitman, and members of Colorado’scongressional delegation.In addition, House Majority Leader Lola Spradley(R-Beulah) recently introduced legislation to makeit more difficult for Cotter and other suchcompanies to accept out-of-state waste in thefuture. Under Colorado law, the General



Southwestern Compact/CaliforniaLegislation Introduced inCalifornia re Disposal FacilityLicensingOn February 20, 2002, California AssemblyMember Fred Keeley (D) introduced a bill in thestate legislature that would, among other things,prohibit the proposed Ward Valley low-levelradioactive waste disposal site from serving as thestate’s facility for purposes of the SouthwesternLow-Level Radioactive Waste Disposal Compactand that would prohibit the state from acceptingownership or other property rights to the site ofthat facility. In addition, the bill would repeal theauthority of the State Director of Health Servicesto lease specified property to construct, operateand close a low-level radioactive waste disposalfacility.

As introduced, the bill would define terms andwould prohibit the California Department ofHealth Services from issuing or renewing a low-level radioactive waste disposal facility licenseunless a specific determination were made that thedesign and operation of the facility meets certaincriteria and requirements. Those criteria andrequirements are as follows:

♦ ensure that no radioactive material will beintroduced into the environment;


A Cotter Corporation official was quoted in localpapers as saying that the company has no intentionof entering the radioactive waste disposal business,but rather needs the income from the Maywoodcontract to carry it through a down time in theuranium business. The same official was quoted asnoting that soil from the Maywood site is five to 10times less radioactive than the tailings already on thecompany’s site. Cotter Corporation has acknowl-edged, nonetheless, that it is interested in acceptingradioactive waste similar to that which can be foundat the Maywood site from a site on Long Island, NewYork.

♦ provide continuous monitoring and repackag-ing of materials to prevent any release into theenvironment;

♦ store the waste in containers that will not leakinto the environment and that are labeled withthe name of the generator, shipper, date andcontents by amount, type, and half-life;

♦ design the facility to prevent the escape ofwaste from a container;

♦ design the facility to include multiple,engineered barriers, including—but notlimited to—redundant, impermeable floors,walls, ceilings, and effluent collection systems,designed to contain any spilled or leaked wasteand prevent exposure to rain or otherenvironmental hazards;

♦ store each container in a manner provdingvisual inspection and ready access;

♦ repackage any deteriorating containers; and

♦ collect and place into new containers anyspilled or leaked radioactive materials and anyresulting contaminated materials.

The bill, A.B. 2214, passed 6 to 2 out of AssemblyEnvironmental Safety and Toxic MaterialsCommittee on April 9. It was heard on April 24in the Assembly Appropriations Committee.

Assembly and the Governor have the authority tocontrol where high-level radioactive waste is storedin the state. Spradely’s bill, HB 1408, would extendthis authority to low-level radioactive waste—although the terms of the bill do not extend to sitesfarther than five miles from incorporated cities andtowns. In particular, the bill would require at leasttwo public hearings, an environmental assessment,and approval from the Colorado Health Depart-ment before low-level radioactive material can bebrought into the state.



Texas Compact/Maine

Maine Drafts Legislation toWithdraw from TexasCompactRecently, the State of Maine drafted legislation towithdraw from the Texas Low-Level RadioactiveWaste Disposal Compact. The bill, titled “An Actto Repeal Provisions Imposing FinancialObligations on Electric Consumers Resultingfrom the Texas Low-Level Radioactive WasteDisposal Compact,” was introduced into theMaine legislature and presented at hearing onMarch 20. In its current form, the bill states, inpart, as follows:

“Pursuant to Sections 7.03, 7.04 and 7.05 of theTexas Low-Level Radioactive Waste DisposalCompact, the State of Maine hereby unilaterallyand irrevocably withdraws from and terminates itsagreements under the Compact. The State ofMaine takes this step due to the closure of theState’s largest generator of low-level radioactivewaste in 1997, obviating the need for Maine’smembership in the Compact, and due to thefailure of the host state to cause a facility to bebuilt in a timely manner pursuant to Section 4.04of the Compact agreement.”

The legislation is sponsored by RepresentativeW. Savage (D) of Buxton. It has been referred tothe Committee on Utilities and Energy. To date,there has been no opposition voiced to thelegislative committee. Initial work sessions on thebill, which was introduced as emergencylegislation, began in April.

The voters of Maine approved the state’s entryinto the Texas Compact in 1993 and the compactwas ratified by Congress in 1998. Under theterms of the compact, the State of Texas has soleresponsibility for building, operating anddecommissioning a low-level radioactive wastedisposal facility and the states of Maine andVermont are each required to pay Texas $25

States and Compacts continued million to offset construction costs. Under a letteragreement between the Governors of the threestates, payments by Maine and Vermont weresuspended indefinitely—despite a compactparagraph calling for a $12.5 million paymentfrom each state within 90 days of Congressionalratification.

At the time of entry into the compact, MaineYankee—the state’s sole nuclear power plant—was expected to begin decommissioning at thetermination of its operating license in 2008. In1997, the owner of Maine Yankee decided toterminate operations and undertake immediatedecommissioning of the unit. Currently, morethan 50% of the decommissioning process hasbeen completed and substantial amounts of wastehave been shipped for disposal at the Barnwell,South Carolina and Envirocare of Utah facilities.

According to Public Advocate, “[g]enerators ofradioactive waste in Maine, other than MaineYankee, account for less than 2000 cubic feet ofradioactive waste shipments annually, chiefly fromlaboratories and medical facilities. All of thiswaste is classified as eligible for disposal at theEnvirocare facility in Utah.”

Under the provisions of the Texas Compact,either non-host state may enact legislationwithdrawing itself from the compact provided thatthe withdrawal does not take effect for two years.During that two year period, the withdrawing stateremains liable for operating costs of the TexasCompact Commission and for any payments thatare due and payable to the host county. Currently,no compact commission has been formed and ahost county has not been designated.

Under Maine’s legislative procedures, a bill doesnot take effect after passage until 90 days afteradjournment of the legislature. The billwithdrawing the state from the Texas Compactwas introduced as emergency legislation, however,which raises the visibility of the issue and allowsthe bill to take effect upon signature by theGovernor.


Courts US Ecology v. State of California

Intervention Denied in USEcology’s PromissoryEstoppel Action AgainstCaliforniaOn March 29, Judge E. Mac Amos of the SuperiorCourt of the State of California denied petitionsby Committee to Bridge the Gap, the Los AngelesChapter of Physicians for Social Responsibility,and the Southern California Federation ofScientists to intervene in the remaining cause ofaction in a lawsuit filed by US Ecology concerningthe development of the proposed low-levelradioactive waste disposal facility in Ward Valley,California. In so doing, Mac Amos held that “theProposed Interveners, organizations concernedwith the medical and environmental implicationsof nuclear technology, do not have a direct andimmediate interest in the remaining cause ofaction for promissory estoppel.”

The case—which names as defendants the Stateof California, the Governor, and the Departmentof Health Services and its Director—allegesbreach of contract and promissory estoppel causesof action on the part of the defendants and seeksa writ of mandate directing the state to take thenecessary steps to acquire the Ward Valley site.The suit, as originally filed, seeks in excess of $162million in damages. (See LLW Notes, May/June2000, pp. 20-22.)

Procedural History

In September 2001, a three-judge panel of theState of California Court of Appeal for the FourthAppellate District reversed in part and affirmed inpart a lower court’s decision in the action. Theruling affirmed the lower court’s findings that USEcology “cannot state a breach of an express orimplied contract cause of action based on the . . .[Memorandum of Understanding], and that

Ecology has failed to state a contract cause ofaction based on any other alleged oral or writtenagreement.” The appellate court also affirmed thelower court’s holding that US Ecology could notsustain a claim to force the State of California totake action necessary to cause establishment of theWard Valley site.

However, the appellate court reversed the lowercourt’s findings in regard to US Ecology’s claimfor promissory estoppel, holding as follows:

“We conclude the complaint stated a cause ofaction for promissory estoppel. We emphasize,however, that this conclusion means only thatEcology has plead sufficient facts to overcome ademurrer. Ecology will still be required to proveits claims, and we offer no opinion as to thelikelihood that Ecology will be able to do so. Wenote further that although Ecology seeks all of itspreparation costs and alleged lost profits, the fullscope of contract-based damages are notnecessarily recoverable under the equitablepromissory estoppel doctrine.”

Both US Ecology and the State of Californiapetitioned the California Supreme Court to reviewthe Court of Appeals’ September 5 decision.However, in December 2001 the CaliforniaSupreme Court denied the petitions for review.(See LLW Notes, November/December 2001,pp. 1, 12-13.)

The case is now awaiting remand for trial in theSuperior Court of the State of California, SanDiego. Trial has been set for January 2003.

Denial of Intervention

In denying the petitions to intervene, the courtfound as follows:

“Plaintiff US Ecology’s Fifth Cause of Action forPromissory Estoppel is based upon assurancesmade by defendants starting in December 1985that they would remain committed to completing



Courts continued Committee to Bridge the Gap v.California Department of HealthServices

Court Throws Out NewCalifornia Waste RegulationsA Sacramento County Superior Court judgerecently nullified new waste disposal regulationsadopted by the California Department of HealthServices (DHS) in November 2001. The DHSregulations mirror federal Nuclear RegulatoryCommission regulations that allow, withinspecified limitations, the disposal of slightlycontaminated radioactive materials in regularlandfills. The regulations, according to DHS,follow federal guidelines for decommissioningnuclear facilities and pose no threat to the public.In fact, DHS notes that the new regulationsactually tighten cleanup standards forcontaminated sites. The court, however, foundthat the regulations “will have a significant adverseenvironmental effect.” Moreover, the court ruledthat, contrary to claims of state officials, Californiahas the authority to pursue more protectivestandards for radioactive waste disposal, but failedto consider that option in violation of state law.The court’s ruling was made in response to alawsuit filed by Committee to Bridge the Gap, theCalifornia Federation of Scientists, and Physiciansfor Social Responsibility. The plaintiffs argue thatlandfills are not designed to safely accommodatenuclear waste.

Prior regulations required the elimination ofradioactivity when sites are cleaned up. Thenew regulations, however, allow the release ofsites for another use (and the disposal of debrisfrom the site in an ordinary landfill) if the sitesproduce less than 25 millirem of radioactivity peryear. Such low levels of radiation are not a risk,according to DHS, which notes that the averageAmerican receives 360 millirems of radiation eachyear—300 millirems from natural sources andabout 60 millirems from man-made activities.

Opponents of the rules complain, however, that itis not sufficiently protective of public safety andthe environment. As a result, state Senator GloriaRomero (D), Chair of the Senate SelectCommittee on Urban Landfills, has introducedlegislation that would prohibit the disposal ofradioactive materials in regular landfills and thatwould increase monitoring at landfills to preventradioactive waste from being sent there. The bill,SB 1623, would expand the scope of radioactivematerials that must be disposed of in a licensedfacility. The bill was heard in the SenateEnvironmental Quality Committee on April 22.

According to news accounts, DHS currentlylicenses and monitors approximately 2,100 usersof radioactive materials. Since 1962,approximately 4,000 sites in California have beenreleased from state licensing. Since the new DHSregulation has taken effect, no soil or otherradioactive waste has been disposed of at anordinary landfill because no new sites have beendecommissioned.

Romano Appointed CEO ofAmerican EcologyCompany Receives $5 millionBNFL Cleanup ContractEarlier this week, the Board of Directors ofAmerican Ecology Corporation announced theappointment of Stephen Romano as ChiefExecutive Officer of the company, effectiveimmediately. Romano, who has worked forAmerican Ecology and its subsidiaries for morethan 12 years, has served as President and ChiefOperating Officer of the company since October2001 and retains those titles.

In announcing the appointment, the Board stated:

"We are very pleased to appoint Steve Romano tolead American Ecology as Chief Executive



Courts continued

Walker v. Cheney

GAO/Congressional LeadersSue Over White House EnergyPolicyDavid Walker, Comptroller General of theGeneral Accounting Office, filed a lawsuit in lateFebruary against the White House seekinginformation about the Bush administration’senergy policy. Specifically, the action—which wasfiled at the request of Democratic lawmakers—seeks records of a task force led by Vice PresidentDick Cheney. It alleges that environmentalistswere excluded from the closed-door task groupmeetings, while members of industry were not.

One of the controversial issues in Bush’s energypolicy challenged by supporters of the litigation isa revival of nuclear power and, more specifically,the decision to support the proposed YuccaMountain high-level radioactive waste repository.The action seeks, among other things, todetermine whether the task force impacted theBush decision to support repository development.

The White House argues that releasing recordsfrom the energy task force would erode WhiteHouse authority and blur the constitutional linesbetween the legislative and executive branches ofgovernment.

U.S. Department of Energy v. State ofNevada

DOE Sues Nevada re YuccaWater PermitsThe U.S. Department of Energy recently filed apetition in the U.S. District Court in Las Vegas tocontest a state official’s refusal to extendtemporary water permits at the site of theproposed Yucca Mountain high-level radioactivewaste repository. The state official refused toextend the temporary permits in February, afterPresident George W. Bush approved thedepartment’s decision to build a permanentrepository at the Yucca Mountain site, on thebasis that the site characterization process wascomplete and the temporary permits were nolonger necessary.

DOE added the petition to a prior complaintchallenging the state’s denial of a permanent watersupply at Yucca Mountain. The departmentcontends that the refusal decision contradicts statelaw and that, without water, DOE won’t be ableto complete scientific studies needed to provide “areasonable assurance that the public and theenvironment will be adequately protected fromthe hazards posed by high-level radioactive wasteand spent nuclear fuel.”

The state filed its answer to both complaints inlate March. As part of its response, the state isseeking dismissal of the federal request for thetemporary water permit. In papers filed beforethe court, Nevada attorneys argue that the projectis legally dead and water is not needed at the siteuntil Congress acts to override Nevada GovernorKenny Guinn’s veto of the proposed repository.

“Only if Congress passes new legislationoverriding the Notice of Disapproval and if thePresident signs this new legislation, the YuccaMountain Project may be revived. Until thiseventually happens, a matter of considerablespeculation at this point, the project is legallydead.”


Russian Supreme CourtProhibits Hungary ImportsEnvironmentalists were handed a victory recentlyby the Russian Supreme Court when it struckdown a government decision to allow the importof nuclear waste from Hungary for storage. Thecourt found that a 1992 law which allows Russiato import spent fuel rods from the Ukraine,Bulgaria, Slovakia, and Hungary for reprocessingspecifically requires the return of such waste tothe countries of origin for permanent storage.The lawsuit was initially filed by Greenpeace andother environmental organizations last year whenthey became aware of a 1998 government decisionto allow nuclear waste from Hungary to be sent toRussia for storage.

Environmentalists are also objecting to a lawsigned last year that allows the import of spentnuclear fuel from foreign countries forreprocessing and storage. (See LLW Notes, July/August 2001, p. 16.) Under the plan, spent fuelfrom foreign countries will be sent to Russia viaarmored train for reprocessing. Russia is expectedto earn $20 billion over the next decade under theplan, importing nearly 22,000 tons of spentnuclear fuel. Part of the revenues are slated foruse to clean up existing nuclear pollution inRussia. Environmentalists, however, fear thatRussia’s crumbling infrastructure and weakgovernment make a dangerous environment forimporting radioactive materials.

the process necessary to develop a low-levelradioactive waste disposal facility at Ward Valley.US Ecology alleges that defendants promised theywould make US Ecology the sole and exclusivelow level radioactive waste disposal licensee in []California for 30 years. It appears to the courtthat the Proposed Interveners’ interests are notfounded upon these alleged promises, but arefounded upon environmental and safety concerns


related to the Ward Valley site. In this promissoryestoppel claim, the court does not address thepropriety of these alleged promises; rather, it mustinterpret the legal effect if such promises weremade. Proposed interveners have not shown howthey would directly gain or lose by the legaloperation and effect of a judgment awardingdamages for promises made by the State.”(citations omitted)

In response to the court’s ruling, US Ecologyissued a media advisory stating, in part, as follows:

“US Ecology believes its case against the State isstrong, and expects to recover substantial damagesat trial. Alternately, US Ecology is fully willing towork with the State of California to expeditiouslycomplete the Ward Valley land transfer, allowingburial trench construction and subsequentradioactive waste disposal to proceed inaccordance with the State’s contractual obligationsto the Company and member states of theSouthwestern Compact.”

Courts continued

Russia’s Cleanup Work to beFunded by Processing ForeignWaste

Officials in Russia’s Atomic Energy Ministryhave announced that they believe that theprocessing of imported foreign waste is anacceptable means of financing the processing ofRussia’s own waste. Estimates indicate thatRussia has accumulated nearly 14,000 metric tonsof radioactive waste from the production ofpower, and additional amounts from theproduction of nuclear weapons. Russia has beensearching for the funds to process this waste inorder to improve the ecological situation atproduction facilities. The Atomic EnergyMinistry has concluded that the processing offoreign waste is a good way of collecting theneeded funds.


Congress U.S. Congress

NRC’s FY 2003 Budget NowAvailableThe U.S. Nuclear Regulatory Commission has an-nounced the availability of its budget to Congressfor FY 2003. The budget requests $605.6 million“for regulation of the nation’s nuclear powerplants and nuclear materials to protect publichealth and safety, to promote the common de-fense and security, and to protect the environ-ment.”

The FY 2003 budget request reflects a 4.7 percent($27.1 million) increase over the current budget.Approximately half of the increase is for new re-actor licensing activities, whereas the remainder ofthe increase is for federal pay raises and increasesin benefits and retirement costs; reactor licenserenewal; key safety research; keeping pace with theU.S. Department of Energy’s high-level wasteprogram; and additional investments in theagency’s information technology, human capital,and facilities.

Two challenges highlighted by NRC in its budgetrequest are an increased focus on homeland secu-rity and a renewed interest in building nuclearpower plants. For instance, the budget requestincludes $29.3 million for homeland activities and$24.8 million for new reactor initiatives such asapplication reviews, regulatory improvements, andnew technology research. The budget request alsoincludes $16.9 million to review five license re-newal applications expected in FY 2002 andFY 2003.

Detailed information on NRC’s budget request isavailable at http://www.nrc.gov/who-we-are/ plans.html

Whistleblower Bill Introducedin CongressA bipartisan group of congressional membersrecently introduced legislation that seeks toprotect whistleblowers who expose wrongdoingsin either the federal government or the privatesector. The bill, known as the Paul RevereFreedom to Warn Act, would allow employeesand contractors who expose wrongdoings to filecivil actions in federal courts using jury trials ifthey feel that they have been retaliated against.The laws, as currently written, do not provide forpenalties if the federal government or privatefirms are accused of retaliation.

The legislation was announced at a February 27news conference sponsored by Accuracy in Media,American Federation of Government Employees,Common Cause, Fund for ConstitutionalGovernment, Government Accountability Project,National Taxpayers Union, NationalWhistleblower Center, Patrick Henry Center, andProject on Government Oversight. The bill wassponsored by Senator Charles Grassley (R-IO)and Representatives Steve Israel (D-NY), EdwardMarkey (D-MA), and Constance Morella (R-MD).


DOE Proposes Rule to ProtectClassified InfoThe U.S. Department of Energy is proposing anew rule that would allow it to impose penaltieson contractors and subcontractors who unlawfullyand improperly divulge classified information.The proposed rule--which was published in theApril 1 issue of the Federal Register (pp. 15,3339)--isa response to a controversial congressional re-quirement attached to the FY 2000 DefenseAuthorization Act which provides civil penaltiesof up to $100,000 for specific security violations.

Under the proposed rule, DOE would assess civilpenalties for violations of

♦ regulations related to classified information,♦ any department rule, regulation or order relat-

ed to the protection of restricted data, and♦ compliance orders.

DOE held public meetings on the proposed ruleon May 22 and 29 in Las Vegas and Washington,D.C., respectively. Comments on the proposedrule are due by July 1 to Geralyn Praskievicz,Office of Security, SO-1, Docket No. SO-RM-00-01, DOE, 1000 Independence Avenue, S.W.,Washington, D.C. 20585.

U.S. Department of Energy

Sources Lost in ForeignCountriesThe U.S. Department of Energy has lost track ofhundreds of sealed sources sent to foreigncountries over the years, including sourcescontaining plutonium, according to a recentInspector General report. The sources, many ofwhich were loaned or given to foreign countriesunder the Atoms for Peace Program, were used tocalibrate radiation measuring and monitoringinstruments and for nuclear research anddevelopment.

According to the IG, the problem arose becauseproper enforcement requirements for reportingsealed source information to DOE’s NuclearMaterials Management Safeguards System werenot followed and efforts to maintain a separateSealed Source Registry were discontinued. Thereport further found inconsistent information asto whether the United States still owns many ofthe loaned sources and who is responsible for thesources ultimate disposal. Accordingly, itencouraged DOE to make determinationspromptly as to ownership, location, condition, anddisposal responsibility.

The report attributed the lack of informationabout loaned sealed sources to three main factors:

♦ DOE and its predecessors failed to effectivelymonitor government-owned sources exportedto foreign countries,

♦ international agreements limit reporting byforeign countries on loaned nuclear materials,and

♦ international safeguard controls applying toother forms of nuclear materials do not fullyapply to sealed sources, depending on theamount and type of material that they contain.

The report calls on DOE to work with theInternational Atomic Energy Agency (IAEA) “to

ensure that the sealed sources are properlycontrolled and that existing record systems areupdated and reconciled.” This is especiallyimportant, according to the IG report, in light ofrecent world events.

“Recent world events have underscored the needto strengthen the control over all nuclearmaterials, including sealed sources. Individuallyand collectively, sealed sources represent a health,safety and material security concern.”

The IG report, “Accounting for Sealed Sources ofNuclear Material Provided to Foreign Countries,”(DOE/IG-0546), is available at http:// www.ig.doe.gov .

Federal Agencies and Committees continued


Federal Agencies and Committees continued U.S. Department of Transportation

Transportation: DOT StudyExpected Shortly, While NRCContinues RevisionsThe U.S. Department of Transportation is ex-pected to complete a study shortly on the risks tothe public health, safety, environment and econ-omy from the transportation of radioactive wastefrom nuclear power plants and U.S. Departmentof Energy sites to the proposed Yucca Mountainhigh-level radioactive waste repository. The studywas commissioned by Senator Harry Reid (D-NV)who, along with environmentalists and other op-ponents, is highlighting transportation risks as amajor factor in the bid to shut down the YuccaMountain project.

The U.S. Nuclear Regulatory Commission is ex-pected to publish for public comment shortly pro-posed regulations to make its radioactive materialspackaging and transportation standards compati-ble with the latest International Atomic EnergyAgency (IAEA) transportation standards. NRC,which coordinates its transportation regulationswith DOT, discusses 19 issues in the proposedregulations—11of which are designed to ensureconsistency with IAEA standards and eight ofwhich are initiated by NRC.

Some of the issues included in the rule are:

♦ whether to adopt the IAEA’s uniform, dose-based radionuclide exemption standard or usethe current concentration-based standard,

♦ whether Part 71 certificate holders can safelymake limited changes to the design of a trans-portation package, as permitted for reactorand spent fuel storage facility licensees,

♦ whether single or double containment shouldbe required for plutonium packages, and

solid material: clearance, conditional clearance,and no release.Clearance The term "clearance" means that the materialmeets licensing criteria to be reused withoutrestriction, recycled into a consumer product, ordisposed of at a landfill. Many participants at thecommittee's information-gathering meetings --including environmental groups, steel industryofficials, and licensee representatives -- expressedconcern about this category. The concerns in-cluded potential health risks, product stigma-tization, liability and economic costs. Thecommittee did not make a specific recommen-dation on how to deal with this category, butrather outlined how the NRC can evaluate thepotential impacts of various options.Conditional Clearance The term "conditional clearance" means thatmaterial must be used in a specified application(such as being melted into shielding blocks for useat nuclear facilities) or disposed of at municipalsolid waste landfills, construction and demolitionwaste landfills, and industrial nonhazardouslandfills. Such material would not be used ingeneral commerce.No Release The term "no release" means that "materialsremain under the control of the Nuclear



♦ whether a standard should be developed forreview of large-object packages, or whethereach request should be reviewed through ex-emptions on a case by case basis.

A series of public meetings will be held on theproposed regulations. They have not been sched-uled as of yet.

A copy of the proposed rule can be obtained fromNRC’s web site at http://ruleforum.llnl.gov .



U.S. Nuclear Regulatory Commission

Hearings Set re Skull ValleyProposed Spent Fuel FacilityThe U.S. Nuclear Regulatory Commission hasestablished a schedule for a series of hearings, tobe held in April and May 2002, on a request tolicense a spent nuclear fuel storage facility on theSkull Valley Band of Goshute IndiansReservation. The proposal is being sponsored byPrivate Fuel Storage, L.L.C.—a coalition ofnuclear utilities seeking to site the proposedfacility on the Goshutes reservation. To date, agreat deal of opposition to the proposed facility—which would be located about 60 miles southwestof Salt Lake City—has been raised, includingopposition by the State of Utah and its Governor.

The Atomic Safety and Licensing Board (ASLB)will preside over the hearings, taking testimonyand cross-examinations. The hearings will beopen to the public, but participation will belimited to interested parties previously admitted tothe proceedings, including:

♦ Private Fuel Storage, L.L.C.,

♦ U.S. Nuclear Regulatory Commission staff,

♦ the State of Utah,

♦ the Skull Valley Band of Goshute Indians,

♦ Ohngo Gaudadeh Devia,

♦ the Confederated Tribes of the GoshuteReservation, and

♦ the Southern Utah Wilderness Alliance.

Four issues will be covered in the hearing:

♦ a contention that adequate consideration hasnot been given to hazards from militaryaircraft and other operations near the area,

♦ inquiries as to the ability of the facility towithstand possible earthquakes,

Regulatory Commission or an agreement state thathas assumed the commission's authority toregulate certain licensees." Such materials todaywould need to be sent to Envirocare of Utah,Chem-Nuclear's Barnwell facility, or US Ecology'sRichland site. According to the committee'sestimates, the total cost to dispose of all slightlyradioactive metal and concrete from U.S. powerreactors would be $4.5 billion - $11.7 billion. Incomparison, material that qualifies as "conditionalclearance" can be sent to a landfill with estimateddisposal costs ranging from $300 million to $1billion.

The National Research Council committee'sreport cautioned that its "recommendations applyonly to slightly radioactive solid material licensedby the U.S. Nuclear Regulatory Commission andagree-ment states, and not to the disposition ofmaterials from the closing of government nuclearweapons facilities."Copies of the National Research Council report can befound on the internet at http://www.nap.edu. Copies canalso be purchased from the National Academy Press bycalling (800) 624-6242.


♦ potential groundwater contamination fromnon-radiological waste, and

♦ issues regarding whether the environmentalimpact statement adequately addressesalternatives to the placement of the proposedconnection railway to the facility.

Information about the hearing locations andschedule can be found at http://www.nrc.gov/ public-meetings/meeting-schedule.html#ASLB .

For additional information, contact the Atomic Safety andLicensing Board Office at (301) 415-5036.



Revision 2 of Draft YuccaReview Plan Now AvailableThe U.S. Nuclear Regulatory Commission hasreleased Draft Revision 2 of its plan to review anapplication to build a proposed high-levelradioactive waste repository at Yucca Mountain,Nevada should the U.S. Department of Energysubmit such an application. The plan’s principalpurpose is “to ensure the quality and uniformityof the NRC staff’s licensing reviews.”

The original draft plan was made public last year.It was revised, however, because it is out-of-dateand inconsistent with NRC’s final regulations—issued in November 2001.

The draft review plan has separate sections forpotential reviews of safety of the repository priorto permanent closure, safety after permanentclosure, the performance confirmation program,and administrative and programmaticrequirements. Each section defines NRC’s reviewof DOE’s compliance with NRC regulations.

The NRC plans to accept public comments, andto hold public meetings, on the draft.

A copy of the “Yucca Mountain Review Plan, DraftRevision 2” is available on the NRC’s web site at http:// www.nrc.gov/waste/hlw-disposal/draft-yucca-plan.pdf .

NRC Opens New Security OfficeOn April 7, the U.S. Nuclear Regulatory Commis-sion opened its new Office of Nuclear Securityand Incident Response. Whereas, in the past,NRC had assigned security responsibilities basedon the type of facility requiring protection, thenew office allows for centralization and consolida-tion of security activities which NRC hopes willlead to improved communication and coordina-tion—both within the agency and with externalentities. The creation of the new office was, atleast in part, a response to the September 11 ter-rorist acts.

The new office has a variety of responsibilities,including:

♦ managing the NRC operations center, devel-oping and directing the NRC program for re-sponse to incidents, and interacting with theFederal Emergency Management Agency andother federal agencies,

♦ developing and implementing safeguards, se-curity policy and oversight for a variety oftypes of facilities and for transportation activi-ties,

♦ accounting and controlling materials and ap-plying international safeguard activities ofNMSS,

♦ providing technical support and coordinationfor safeguards, licensing and rulemaking activ-ities implemented by NMSS and NRR,

♦ developing contingency planning and emer-gency response activities for safety and safe-guards events,

♦ coordinating with intelligence and law en-forcement communities,

♦ assessing threats, and

♦ administering NRC counterintelligence, securetelecommunications, and classification/declas-sification programs.


NRC Orders Increased ReactorSecurityIn late February, the U.S. Nuclear RegulatoryCommission ordered the implementation ofinterim compensatory security measures at all 104commercial nuclear power plants in light of thegeneralized “high-level threat environment.” Theorder was, in part, a formalization of securitymeasures implemented by NRC licenseesfollowing the September 11 terrorist attacks.Additional security measures are, however,included which emerged from a comprehensivesecurity review undertaken by NRC following theattacks. According to the order, the requirementsremain in effect until the commission either“determines that the level of threat hasdiminished, or that other security changes areneeded following a comprehensive re-evaluationof current safeguards and security programs.”

Licensees had 20 days from issuance of the orderin which to provide NRC with a complianceschedule. They also were required to notify NRCwithin 20 days and provide written justification ofany inability to comply with specific requirements,of the inapplicability of requirements to theirspecific site, or of violations to operating licenseprovisions or decreases in plant safety that wouldresult from implementation of specificrequirements.

Many of the new security measures were notreleased, for safety purposes. However, they aresaid to include things such as augmented securityforces and capabilities, increased patrols, newsecurity posts, installation of new physical barriers,vehicle checks at greater distances from the plants,greater coordination with law enforcement andmilitary authorities and greater site access controls.

The releasable portions of NRC’s order have beenposted to NRC’s web site at http://www.nrc.gov

Federal Agencies and Committees continued NRC to Exempt Umetco fromGroundwater CleanupRequirementsThe U.S. Nuclear Regulatory Commission isproposing to grant an amendment to sourcematerials license of the Umetco uranium mill inWyoming that would, in effect, alleviate thecompany of meeting certain groundwater cleanuprequirements that it maintains are overlyburdensome and financially impractical. TheUmetco site, which involved the operation of auranium mill site in Wyoming from 1960 to 1979,is now licensed to possess byproduct material inthe form of uranium waste, such as mill tailings,generated by past uranium processing operations.

Specifically, the amendment would allow Umetcoto apply alternate concentration limits to licensedconstituents of groundwater. An environmentalassessment determined that granting theamendment would not impact the likelihood orconsequences of previously analyzed accidents,nor would it impact facility radiation levels orradiological effluents.

In addition to citing the high costs of complianceas a basis for the requested amendment, Umetconotes that the presence of contaminated waterfrom other nearby mines would impact its abilityto meet the standards.

Details of the proposed amendment can be found onNRC’s ADAMS Public Electronic Reading Room athttp://www.nrc.gov/reading-rm.html.



Annual Report Issued by NRCOffice of EnforcementThe U.S. Nuclear Regulatory Commission’sOffice of Enforcement has issued its FY 2001Annual Report which describes enforcementactivities which occurred during the year, as wellas addresses significant policy changes, newinitiatives, staff guidance and implementationissues for the agency’s enforcement program.Also included in the report are summaries ofenforcement cases and actions which thecommission took against facility owners andmaterials users. Included in the report were twopolicy revisions, 89 escalated Notices of Violationwithout civil penalties, 20 proposed civil penalties,and 18 orders, five of which imposed civilpenalties.

In issuing the report, NRC stated that its“enforcement program continues to emphasizethe importance of compliance with regulatoryrequirements, and to encourage promptidentification and comprehensive correction ofviolations.”

A copy of the enforcement program’s annual report isavailable at NRC’s Electronic Reading Room atwww.nrc.gov as well as an Agencywide Document Accessand Management System (ADAMS) document (accessionnumber ML020250035).

ASLB Orders Goshutes to Detail Pay-ment Information; NRC Blocks RulingThe U.S. Nuclear Regulatory Commission’sAtomic Safety and Licensing Board (ASLB) inFebruary directed leaders of the Skull Valley Bandof Goshute Indians to disclose how much moneyit has received from Private Fuel Storage,L.L.C.—the consortium of nuclear utilities seek-ing to site a spent fuel storage facility on theGoshute’s reservation—and to detail how pay-ments have been spent to date, as well as whatpayments are expected to be made in the future.The order was made in response to a request fromdissident members of the Goshute tribe. Finan-cial details were to be due on March 22.

The U.S. Nuclear Regulatory Commission, how-ever, subsequently blocked the ASLB’s decision—temporarily holding that tribal leaders need notdisclose the requested financial information. Inso ruling, the NRC commissioners noted that theyrarely review ASLB procedures. However, in thecase at hand, the commission found that “theboard decision creates an exceptional situationthat warrants immediate commission attentionunder this standard.” The commissioners notedthat nobody would suffer significant harm fromthe delay and that, following an NRC review, theASLB’s decision could be reinstated.

Officer. The Board has full confidence in Steve'sability to manage the organization, deliverexcellent services to our customers, and generateimproved earnings for our investors."

In an unrelated action, American Ecology alsoannounced this week that the company's FieldServices Division has been awarded a $5 millioncontract to decommission a nuclear equipmentrecycling facility owned by a British Nuclear Fuels,Ltd. (BNFL) subsidiary in Oak Ridge, Tennessee.The contract includes large nuclear component

(Continued from page 15) removal, decontamination, and decommissioningof the Manufacturing Sciences CorporationRecycle Facility, which previously processedradioactively contaminated materials andequipment from nuclear power plants.

In announcing the award, Romano stated asfollows:

"This large, competitively bid award highlights thecontinued expansion of American Ecology'sremediation services business. The same highly



NRC Proposes to Amend FeeScheduleThe U.S. Nuclear Regulatory Commission isproposing to amend it annual fees and feescharged for licensing and inspections in order tocomply with federal laws that require the commis-sion to recover approximately 96 percent of itsbudget authority—excluding amounts appropri-ated from the Nuclear Waste Fund and the Gen-eral Fund.

The proposed increase is $6/hour in the labor ratefor NRC services in the reactor program and$8/hour for services in the nuclear materials pro-gram. This would bring the proposed hourly ratesto $156 and $152, respectively. In addition, theproposal seeks to increase annual fees for the fol-lowing licenses and activities: operating powerreactors, high-enriched uranium fuel cycle facili-ties, low-enriched uranium fuel cycle facilities, ura-nium recovery, radiographers, broad-scope medi-cal, and distribution of radiopharmaceuitcals.Other changes affecting fees are proposed also,including adjustments to or clarifications of feewaiver and exemption provisions.

NRC’s total budget authority for FY 2002 is$559.1 million. Approximately $59.7 million ofthat will come from the Nuclear Waste Fund andfrom the General Fund for homeland security ac-tivities. That means NRC must collect approxi-mately $479.5 million in FY 2002 through licens-ing, inspection, annual and other fees.

The proposed rule for the new fee schedule waspublished by NRC in the March 27 FederalRegister (p. 14,818). Comments on the proposedchanges were due April 27.


NRC Issues Annual AssessmentLetters to Nuclear Power PlantsThe U.S. Nuclear Regulatory Commission recentlyissued annual assessment letters for all 103 operat-ing nuclear power plants. In so doing, NRCstated as follows:

“Every six months each plant receives either amid-cycle review letter or an annual assessmentletter along with an NRC inspection plan. Up-dated information on plant performance is postedto the NRC web site every quarter. The next mid-cycle assessment letters will be issued in Septem-ber.”

Public meetings at each plant are planned, to beannounced as scheduled.

The assessment letters have been posted onNRC’s web site at http://www.nrc.gov/NRR/ OVERSIGHT/ASSESS/index.html and are avail-able on the Agencywide Documents Access andManagement System.

trained team that successfully decommissioned aclosed nuclear facility in Oak Ridge under contractto the State of Tennessee is now hard at work atthe new job site."

For additional information, contact Chad Hyslop ofAmerican Ecology Corporation at (208) 331-8400.



White House

Bush Recommends YuccaMountain; Nevada GovernorExercises VetoOn February 15, President George W. Bushformally recommended the proposed YuccaMountain site to the U.S. Congress for thedevelopment of a high-level radioactive wasterepository. The recommendation follows U.S.Energy Secretary Spencer Abraham’s January 10announcement of his selection of the site. (SeeLLW Notes, January/February 2002, pp. 16-17.)The recommendation, made in a formal letter toCongress, noted the need for centralizing spentnuclear fuel storage and disposal and stressed issuesof national security and American energy needs.

Immediately following Bush’s recommendation,Nevada Governor Kenny Guinn (R) announced hisintention to veto the President’s recommendation,saying:

“I am outraged, as are the citizens of Nevada, thatthis decision would go forward with so manyunanswered questions. I believe that we deserve ascientific response to the nearly 300 criticalquestions the Nuclear Regulatory Commission hasstated must be resolved before going forward withYucca Mountain.”

Guinn formally vetoed Bush’s recommendation onApril 8. In so doing, Guinn argued that YuccaMountain is not suitable for a high-level wasterepository and that there is no emergency thatrequires use of the site.

Under federal law, the issue now goes to Congressfor a vote. In order for the project to go forward,Congress must override the state’s veto by amajority vote of both houses. Accordingly, SenateJoint Resolution 34 was introduced by Senator JeffBingaman on April 9 which approves YuccaMountain as the site for a high-level wasterepository. The bill has been referred to the Energyand Natural Resources Committee.

Mayors Write Bush re Rad WasteTransportIn a February letter to President George W. Bush,18 mayors express concerns about thetransportation of high-level radioactive waste andspent nuclear fuel rods through American cities tothe proposed Yucca Mountain waste repository.The letter, which emerged from the U.S.Conference of Mayors’ February 22 LeadershipMeeting, calls on Bush to include a transportationanalysis and an environmental impact study in theU.S. Department of Energy’s final report on theproposed site. The Conference has not taken anofficial position on the proposed Yucca site. Theletter was initiated by Reno Mayor Jeff Griffin.

The letter states, in part, as follows:

“We are concerned the DOE has not yet fullyresearched the methods for the transportation ofnuclear waste. Regardless of the final repositorylocation, we have serious concerns about thetransportation of spent nuclear fuel from reactorsall over the country to Yucca Mountain or anyother repository. These shipments will travelthrough America’s cities past our schools, homesand places of business.”

The U.S. Conference of Mayors had adopted atransportation policy in 1996 that calls for thefederal government to fund (1) training andequipment needed by local emergency responsepersonnel along transportation routes, (2)upgrades to medical facilities that couldpotentially treat accident victims, and (3) upgradesto highways and railroads to ensure safetransportation corridors. The policy also calls onthe U.S. Nuclear Regulatory Commission tocertify shipping transportation containers after apublic process that includes both physical testingand computer modeling to ensure that suchcontainers are capable of withstanding severeaccidents.

A copy of the letter can be obtained atwww.usmayors.org.



Obtaining Publications

To Obtain Federal Government Informationby telephone

• DOE Public Affairs/Press Office ..............................................................................................(202) 586-5806• DOE Distribution Center ...........................................................................................................(202) 586-9642• DOE's National Low-Level Waste Management Program Document Center ...................(208) 526-6927• EPA Information Resources Center ..........................................................................................(202) 260-5922• GAO Document Room ...............................................................................................................(202) 512-6000• Government Printing Office (to order entire Federal Register notices) ..............................(202) 512-1800• NRC Public Document Room ...................................................................................................(202) 634-3273• Legislative Resource Center (to order U.S. House of Representatives documents) ...........(202) 226-5200• U.S. Senate Document Room .....................................................................................................(202) 224-7860

by internet

• NRC Reference Library (NRC regulations, technical reports, information digests, and regulatory guides). .................................................................................www.nrc.gov/NRC/reference

• EPA Listserve Network • Contact Lockheed Martin EPA Technical Support at (800) 334-2405 or e-mail (leave subject blank and type help in body of message). ...........................................................................................listserver@unixmail.rtpnc.epa.gov

• EPA • (for program information, publications, laws and regulations) ............... http://www.epa.gov/

• U.S. Government Printing Office (GPO) (for the Congressional Record, Federal Register, congressional bills and other documents, and access to more than 70 government databases). ........................................................................................................................www.access.gpo.gov

• GAO homepage (access to reports and testimony) ................................................................www.gao.gov

To access a variety of documents through numerous links, visit the web site for the LLW Forum, Inc. at www.llwforum.org

Accessing LLW Forum, Inc. Documents on the WebLLW Notes, LLW Forum Meeting Reports and the Summary Report: Low-Level Radioactive Waste ManagementActivities in the States and Compacts are distributed to the Board of Directors of the LLW Forum, Inc. As ofMarch 1998, LLW Notes and LLW Forum Meeting Reports are also available on the LLW Forum web siteat www.llwforum.org . The Summary Report and accompanying Development Chart, as well as LLW ForumNews Flashes, have been available on the LLW Forum web site since January 1997.

As of March 1996, back issues of these publications are available from the National Technical InformationService at U.S. Department of Commerce, 5285 Port Royal Road, Springfield, VA 22161, or by calling(703) 605-6000.


Appalachian Compact Northwest Compact Rocky Mountain Compact Southwestern CompactDelaware Alaska Colorado ArizonaMaryland Hawaii Nevada California *Pennsylvania * Idaho New Mexico North DakotaWest Virginia Montana South Dakota

Oregon Nothwest accepts RockyAtlantic Compact Utah Mountain waste as agreed Texas CompactConnecticut Washington * between compacts MaineNew Jersey Wyoming Texas *South Carolina Southeast Compact Vermont

Midwest Compact AlabamaCentral Compact Indiana Florida Unaffiliated StatesArkansas Iowa Georgia District of Co.umbiaKansas Minnesota Mississippi MassachusettsLouisiana Missouri Tennessee MichiganNebraska * Ohio Virginia New HampshireOklahoma Wisconsin New York

North CarolinaCentral Midwest Compact Puerto RicoIllinois * Rhode IslandKentucky

LLW Forum Notes (11)llwforum.org/wp-content/uploads/2016/12/marapr02Notes.pdf · 2017-01-16 ·...

Documents

Transcript of LLW Forum Notes (11)llwforum.org/wp-content/uploads/2016/12/marapr02Notes.pdf · 2017-01-16 ·...