ML11266A083
| ML11266A083 | |
| Person / Time | |
|---|---|
| Site: | Limerick  (NPF-039, NPF-085) |
| Issue date: | 09/22/2011 |
| From: | Fettus G Natural Resources Defense Council |
| To: | NRC/SECY |
| SECY RAS | |
| References | |
| License Renewal, RAS 21108, 50-352-LR, 50-353-LR | |
| Download: ML11266A083 (4) | |
Text
fr NRDC THE EARTHS BEST DEFENSE September 22, 2011 Via Electronic Mail Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-- 0001 Attn.: Rulemaking & Adjudications Staff hearing.docket@nrc.gov RE: Extension of time for opportunity to request a hearing and petition for leave to intervene in the NRCs Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Nos. NPF39 and NPF85 for an Additional 20-Year Period, Exelon Generation Company, LLC, Limerick Generating Station, Docket ID NRC201 1-0166, Docket Numbers 50352 and 50353 To whom it may concern:
The Natural Resources Defense Council (NRI)C) writes today to respectfully request that the Nuclear Regulatory Commission (NRC or the Commission) extend for 30 days the deadline to request a hearing and petition for leave to intervene on the following:
Notice ojil cceptance fin Docketing of the Application and Notice of Oppoitzinity/r Hearing Regarding Renewal ofFacility Operating License Nos. NPF-39 and iVPF-85 an Additional 20Year Period, Exe/on Generation Company, LLC, Limerick Generating Station, (hereinafter Limerick Relicensing Project). 76 Fed. Reg. 52992 (August 24, 2011). An extension of time is necessary for the following good cause reasons, in accordance with the factors in 10 C.F.R. § 2.309(c) providing foi nontirnely filings.
The proposed relicensing application and associated environmental report are requests for federal approval of activities that will have significant impact on the environment and affected communities. A detailed public review and careful consideration of the more than 2,100 pages will take considerable time. Indeed, such review needs at least the entirety of the usual allotted 60 day review period and the current timeline, which commenced August 24, 2011, has substantially overlapped with a period where NRDC has expended substantial programmatic energy both of our own accord and at the request of the NRC.
NRDC Request for Extension of Time September 22, 2011 Page 2 Specifically, NRDC has been actively engaged in responding to the Fukushima disaster and how the lessons learned from this accident should affect the practices of the domestic nuclear industry. The petitions we filed in response to the Near-Term Task Force (NTTF) Recommendations were done on our own volition, of course, and are public record. See on the NRC Adams Website, Accession Number ML112290034. We have, however, expended considerable resources at the request of the Commission during the precise time period when we might have been other\\.vise reviewing the Limerick re licensing application.
Specifically, at the invitation of the NRC, Christopher Paine, NRDC Nuclear Program I)irector, served on an external stakeholder panel during the NRC staff meeting on prioritization of the NTTF recommendations. See Docket II) NRC-201J-0196, http://phadupws.nrc.gov/docs/MLI 124/ML1 1249M61pçjf NRCs request for our participation and comment arrived on short notice prior to the meeting on August 3 1, 2011. See Accession Number MU 12430120. Indeed, that request arrived one day prior to the noticing of the Limerick re-license application in the Federal Register. Next, Dr.
Thomas Cochran, NRDC Consulting Senior Scientist, and again at the invitation of the NRC, provided additional comments to the NRC Commissioners during a meeting evaluating the NRC staff recommendations resulting from the previously noted August 31 public meeting. See http ://www.nrc.gov/reading-rm/doc collections/commission/tr/201 1/20 I 109 14.pdf. As with the August 31 NRC Staff meeting, the Commissioners September 14 meeting was announced on short notice and demanded a significant NRDC staff effort to provide constructive suggestions and meaningful responses to selected issues.
In short, NRDC and its experts have already expended considerable time just to start the review of the application and related materials, but it is clear that the time period lost between August 24 and mid-September responding to the NRCs request for our public input severely disadvantages any contribution we might make to the development of a sound record, and thus, we write promptly to request an additional 30 days.
1 More time is needed to address impacts to the regulatory process and requirements as they pertain to relicensirig efforts, in particular the required severe accident mitigation alternatives (SAMA). NRDC is collecting and analyzing a sizable number of referenced documents that have merely been cited (and not hyperlinked or otherwise made widely available via the Internet). Examples of documents that will need to be reviewed by the public include background information on possibly outdated SAMA analyses, emergency planning considerations for the densely populated surrounding areas, and the lack of certain reactor safety systems and protocols. The 60 day review period that commenced August 24 and We note that we do not begrudge the time spent over the past month responding to the NRC and while we appreciate the opportunity to provide our views, the truncated time periods provided by the Commission on the NTTF process have not allowed for nearly as meaningful a public process as the issues merit. Please see our September 2, 2011 comments for more on this concern, cited above. We further note that we have heard several reports ofan inability to access the entire relicensing application on the ADAMS network.
Locating documents on ADAMS has long been fraught with problems and remains a source of concern for NRDC and many others. See Attachment I.
NRDC Request for Extension of Time September 22, 2011 Page 3 concludes on October 24 is insufficient time to gather and thoroughly review all the relevant documents to constructively address whether this application meets the NRCs requirements.
Review of these documents and information by NRDC and our experts will assist in developing a sound record in the proceedings. 10 C.F.R. § 2.309(c)(l)(viii). NRDC has an important interest in this matter. We have members who live near the proposed project who will be directly impacted by the projects activities. While we have made no intervention decisions, if we are not provided an adequate opportunity to request a hearing and intervene, substantial injury to its members may result. A demonstration of standing will be made with the intervention petition if or when it is filed.
In light of the aforementioned, we request that the Secretary grant an extension of 30 days to the existing timeline for the opportunity to request a hearing and petition for leave to intervene in this matter. Please do not hesitate to contact me if you have questions or concerns. Thank you for your attention and consideration of this matter.
Sincerely, Senior Project Attorney Natural Resources Defense Council 1152 15 1h St., N.W.
Washington, D.C. 20005 (202) 289-2371 cc: Peter J. Bamford, Project Manager, peter.bamfordnrc.gov
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