ML092860594

Comment (2) of Ross Gould and Manna Jo Greene on Behalf of Hudson River Sloop Clearwater, Inc., Requesting Extension of Public Comment Period Regarding Environmental Reviews for Nuclear Power Plant License Renewal

ML092860594
Person / Time
Site:	Indian Point
Issue date:	09/25/2009
From:	Gould R, Greene M J Hudson River Sloop Clearwater
To:	NRC/SECY/RAS
References
74FR38238 00002, NRC-2008-0608, RIN 3150-142
Download: ML092860594 (2)

Text

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• 2:0 1 2~7E Kd DEDMRT DEDCM A0oQ IV,--010 HUDSON RIVER SLOOP C'LEARWATER, N September 25, 2009 VIA U.S. MAIL AND E-MAIL Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-001 Attn: Rulemakings and Adjudications Staff Ru leniak iný.Commentsý(inric. -ov Re: Revisions to Environmental Review of Nuclear Power Plant Operating Licenses (10 C.F.R. Part 51, RIN 3150-142, NRC-2008-0608, 74 Reg. 38,117 (July 31, 2009)Dear Rulemakings and Adjudications Staff: Hudson River Sloop Clearwater, Inc. ("Clearwater")

hereby respectfully requests that the Nuclear Regulatory Commission extend the comment period for the above-referenced rulemaking proceedings by 90 days. As an organization dedicated to addressing environmental issues related to the operation of Indian Point power plant and that is an Intervenor in the proceedings for the license renewal application for Indian Point, Clearwater has a vested interest in the subject rulemaking.

The proposed rule attempts to update findings made 13 years ago that relate to the environmental reviews for nuclear power plant license renewal. Since the time of the ,5C A)SZ7;f _&Zw-60__ý-/9j~-7'--~5 2-5-. 7~ ~ (j~~ /&I~I-Secretary September 25, 2009 Page 2 findings significant events and new knowledge have fundamentally changed the baseline enviromnent.

A significant amount of time is required to provide a thorough review of the NRC's update to determine whether the proposed modifications are. appropriate in today's environmental landscape.

Granting additional time for meaningful public input will be beneficial.

to the process and allow for a more comprehensive and transparent review by the NRC.The need for ample time for the.review and comment is evidenced by the fact that NRC itself required a substantial amount of time and effort to propose revisions.

Indeed, the NRC spent three years since the first I10-year review cycle ended in 2006 devising the proposed changes. The resulting draft documents incorporating the NRC's changes g (Generic Environmental Impact Statements (GEIS) for License Renewal of Nuclear Il'k (NUREG-1437, Revision 1), Regulatory Guide 4.2, Supplement I, Revision 1, and Environmental Standard Review Pla, 'Supplement I, Revision 1 (NUREG-1555)), are quite voluminous in nature and will take considerable amnount of time to properly review and analyze.We believe that the current 75-day comment period, which expires on October 14, 2009, is not a sufficient amount of time to provide Clearwater and the public with a full and fair opportunity to provide meaningful comments.

Therefore, Clearwater submits that the comment period should be extended for an.additional 90 days.Thank you very much for your consideration of this request. Should someone with to contact us to discuss any of the f6regoiing, please contact Ross Gould at- (917) 658-7144, or via e-mail at rgouldesq

&Rmail.c6hi.

Sincerely,*. Ross Gould Member Manna Jo Greene Environmental Director