ML073111223
| ML073111223 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, 07003098  (DPR-026, DPR-064) |
| Issue date: | 10/31/2007 |
| From: | Coghlan J Nuclear Watch of New Mexico |
| To: | Mike Farrar, Lawrence Mcdade, Nicholas Trikouros Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 70-2098-MLA, RAS 14623 | |
| Download: ML073111223 (5) | |
Text
H i
otM statement Page_1..
From:
Jay Coghlan <jcoghlan@nukewatch.org>
To:
<hearingdocket@nrc.gov>, <pah@nrc.gov>, <mxc7@nrc.gov>
Date:
Wed, Oct 31, 2007 3:01 PM
Subject:
MOX statement MOX LIMITED APPEARANCE STATEMENT October 31, 2007 Judges Michael C. Farrar (Chairman), Lawrence G. McDade, and Nicholas G.
Trikouros Atomic Safety & Licensing Board MOX Limited Appearance Box Atomic Safety and Licensing Board Panel Mail Stop T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Atomic Safety & Licensing Board Judges:
On September 6, 2007, I wrote to the Board Panel on behalf of Nuclear Watch New Mexico and Tri-Valley CAREs. I argued that Intentional Destructive Acts should be analyzed in the environmental impact statement for the MOX plutonium fuel factory. The justification of my argument rested upon the 9th circuit decision in Mothers for Peace v. NRC.
I am pleased by the recent decision of the Environmental Protection Agency to request 6onsideration by NRC of Intentional Destructive Acts in the EIS for re-licensing of the Indian Point nuclear generation station. EPA cites Mothers for Peace v. NRC as well (please see point #4 in the attached EPA memo to NRC).
I think it certainly noteworthy that the lead federal agency charged with protecting the environment believes that Mothers for Peace v. NRC applies to Indian Point. To my mind, Mothers for Peace v. NRC logically should apply to the MOX facility as well.
I hope that the Board Panel will carefully weigh the significance of the EPA's Indian Point request and its applicability to the MOX facility. In sum, I believe it strongly buttresses the argument that Intentional Destructive Acts must be considered in all environmental and safety reviews of the MOX facility.
Thank you for your consideration.
DOCKETED USNRC Sincerely, Jay Coghlan October 31, 2007 (3:01pm)
Jay Coghlan, Executive Director OFFICE OF SECRETARY Nuclear Watch New Mexico RULEMAKINGS AND 551 W. Cordova Rd., #808 ADJUDICATIONS STAFF Santa Fe, NM 87505 Docket No. 70-3098-MLA Phone and fax: 505.989.7342 cell: 505.920.7118 jay@nukewatch.org www.nukewatch.org -
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MOX statement Wed, Oct 31, 2007 3:00 PM Jay Coghlan <Jcoghlan0,nukewatch.org>
icoghlan(cinukewatch.org Recipients nrc.gov OWGWPOO2.HQGWDOOI HearingDocket (HearingDocket) nrc.gov OWGWPOO4.HQGWDO01 PAH (Patricia Harich) nrc.gov OWGWPO01.HQGWDO01 MXC7 (Marcia Carpentier)
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UNITED b rATES ENVIRONMENTAL PROTECTION AGENCY
,REGION 2
0o 290 BROADWAY NEW YORK, NY 10007-1866 44 PROI OCT 1 0 2007 Chief, Rules and Directives Branch Division of Administrative Services Mailstop T-6D59 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Indian Point Nuclear Generating Station, Unit Nos. 2 and 3 License Renewal
Dear Sir or Madam:
The Environmental Protection Agency (EPA) has reviewed the environmental report contained in the Indian Point Nuclear Generating Unit Nos. 2 and 3 - License Renewal Application, attended the afternoon environmental scoping meeting on September 19,2007, and is providing the following scoping comments. Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC has prepared an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating licenses for Indian Point Units 2 and 3 (IP2 and IP3) for twenty years beyond the end of the current license terms. Unit 1 is not operational, and is in a safe storage mode. The Indian Point Nuclear Generating Station is located on the Hudson River in Buchanan, New York.
EPA requests that the following issues be discussed in the environmental impact statement for these license renewals:
- 1. A full discussion of the purpose and need to relicense Indian Point Units 2 and 3, quantifying energy demand and the need for such facilities in the region.
2, A management plan for the spent fuel pools, and other means of storage of" spent fuel that will span. the relicensing period..
- 3.
Aid. evaluat ion of" the leaks from the spent fuel pools, including the possible impacts to groundwater, and future actions to ensure that the leakage is stopped.
- 4. An analysis of the irpact, s ol intentional dcstructive acts (e.g., terrorism). The requirement to consider such acts is based on the Ninth District Court's decision in San Luis Obispo Mothers for Peace v. Nuclear Regulatory Commission (June 2(X)6).
- 5. The inclusion amd analysis of all new seismological data on the project area gathered since the Indian Point Generating Station was constructed.
6.. An evaluation of the alternatives to the proposed project,l including reasonable al ternat ives not with in the j urisdict ion of the lead agency. As the facility impacts aquatic Internet Address (URL) e http:ilwww.epagov Recycled/Recyclable
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lifeby impingement and entrainment of fish and shell fish in cooling water, EPA recommends that several cooling alternatives be explored within the draft SEIS.
- 7. A comprehensive evaluation of cumulative. indirect, amd. secondary impacts. The cumulative impacts analysis should consider the environmental impacts of the project as a whole, and, if any, as one of a number of the other proposed and/or approved actions in the area that would have the potential to impact the same resources.
- 8. In 1993. the Council of Environmental Quality guidance., Pollution Prevention and the National Environme ntal Policy Act, encouraged federal agencies to include the concepts of pollution prevention in EISs during the scoping alternatives analysis, mitigation measure developmnent, and decision-making processes.
Thank you for the opportunity to comment. If you have any questions concerning this letter, please contact Lingard Knutson of my staff at (212) 637-3747.
Sincerely yours.
Grace Musumneci, Chief Environmental Review Section Strategic Planning and Multi-MediaPrograms'Branch