Comments of Arjun Makhijani, Ph.D., submitted to Vanessa Pierce, HEAL Utah

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I have examined the data submitted to the Nuclear Regulatory Commission regarding the proposed importation by EnergySolutions of radioactive waste from Italy to the United States. The waste would be processed in Tennessee; subsequently some of it would be disposed of at the EnergySolutions low-level waste facility near Clive, Utah, which is licensed only for Class A low-level waste. The EnergySolutions license also has a number of other specific restrictions as to what can be in its possession as part of waste disposal operations. This memorandum sets forth a preliminary analysis of the proposed importation of radioactive waste from Italy.