ML18172A276
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Kristine L. Svinicki, Chairman Jeff Baran, Commissioner Stephen G. Burns, Commissioner U.S. Nuclear Regulatory Commission Mail Stop 0-4FOO Washington, DC 20555-0001 May9,2018 Via email to Chairman@NRC.gov, CMRBARAN@nrc.gov, CMRBURNS@nrc.gov Jose Cuadrado, Project Manager Division of Spent Fuel Management
- Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Via email to jose.cuadrado@nrc.gov Annette Vietti-Cook, Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Via email to annette.vietti-cook@nrc.gov
SUBJECT:
Holtec International HI-STORE Consolidated Interim Storage Facility Project Docket No. 72-1051 (Request for 180-day extension of scoping and public period and addition of 18 public hearings)
Dear Members of the Commission:
Don't Waste Michigan, Sierra Club, Beyond Nuclear, Citizens for Alternatives to Chemical Contamination, Nuclear Information and Resource Services, Alliance For Environmental Strategies, Nuclear Energy Information Service, Public Citizen, Vemont Yankee Decommissioning Alliance, Uranium Watch, San Luis Obispo Mothers for Peace, Oregon Physicians for Social Responsibility, Sustainable Energy & Economic Development Coalition, New England Coalition on Nuclear Pollution, Ban Michigan Fracking, Hudson River Sloop Clearwater, Inc., Tennessee Environmental Council, Citizens for Alternatives to Radioactive Dumping, Great Lakes Environmental Alliance, Healthy Environment Alliance of Utah, Canadian Coalition for Nuclear Responsibility, Citizens' Environmental Coalition, Portsmouth/Piketon Residents for Environmental Safety and Security, Chesapeake Physicians for Social Responsibility, Nuclear Watch New Mexico, Physicians for Social Responsibility-Los Angeles, Don't Waste Arizona, Tri-Valley Communities Against a Radioactive Environment, Citizens Awareness Network, Friends of the Earth, San Clemente Green, San Luis Obispo County Grandmothers for Peace, Stand Up/Save Lives Campaign, Bruce Peninsula Environment Group, FLOW (For Love Of Water), Concerned Citizens for Nuclear Safety, Milwaukee Riverkeeper, Food & Water Watch/Food and Water Action, Ecological Options Network, Page I of 11
Occupy Bergen County, Citizens' Resistance at Fermi 2, Sisters of Mercy/ Albuquerque, Crabshell Alliance, Nukewatch, On Behalf of Planet Earth, Coalition Against Nukes, Nuclear Age Peace Foundation, Cape Downwinders and Physicians for Social Responsibility are all organizations that question or oppose the proposed Holtec International (Holtec) consolidated interim storage facility (CISF) for spent nuclear fuel (SNF) being planned for southeast New Mexico. Many of these organizations are planning to intervene in the forthcoming Nuclear Regulatory Commission (NRC) license proceeding for the Holtec CISF.
We hereby request that the Commission extend the scoping comment period for the CISF proposal by 180 days beyond the present terminus of May 29, 2018. The purpose of this request is to afford an opportunity for the convening of additional public comment hearings in 18 American cities likely to be affected by the large-scale transportation effort that will be caused by the Holtec project, and to allow members of the public additional time to undertake pre-filing investigation.
- 1. The Holtec CISF Plan Is Controversial Holtec applied to the NRC by letter dated March 30, 2017 for license authorization to construct and operate a HI-STORE CISF for spent nuclear fuel disposal on a 960-acre site in Lea County, New Mexico. Holtec intends initially to store 500 canisters (8680 metric tons) of SNF, followed by 19 additional phases, all aimed eventually at storing 10,000 canisters and 120,000 or more metric tons. If the first phase is a guide, it may be that more than 170,000 metric tons might end up at Holtec's facility. Even at 120,000 MT, the Holtec CISF would easily be the world's largest SNF interim site.
Holtec plans to provide long-term SNF storage for up to 120 years, 1 or for however much time beyond 120 years it may take to develop a repository. 2 Holtec itself has recommended to the U.S. Department of Energy that a CIS facility "should have a minimum service life of 300 years,"3 all of which raises legitimate questions as to the possible permanence, fitness and suitability of the Holtec plan for storing high-level spent nuclear fuel in the New Mexico desert.
There is no civilian SNF generated in New Mexico. Tens of thousands of tons of dangerous radioactive waste will be transported into the state from hundreds, even thousands, of 1Holtec International Environmental Report (ER Rev. 1), p. 13/543 of.pdf.
2 According to the Holtec ER Rev. 1, p. 19/543 of.pdf: "Holtec anticipates the SNF could be stored at the CIS Facility for up to 120 years, or until a permanent geologic repository is opened consistent with the NRC's Continued Storage Rule." (Emphasis added).
3Letter, Joy Russell, Holtec Vice-President, to DOE, "Response to RF! on Private Initiatives to Develop Consolidated SNF Storage Facilities," 1/27/2017, https://www.energy.gov/sites/prod/files/2017 /02/f34/J an%2027%2C%202017%20-%201 oy%20Russell%
20-%20Response%20to%20the%20RFI%20on%20Private%201nitiatives.pdf Page 2 of 11
miles away, via barge, truck and railroad, followed a century later by a second massive effort of 10,000 more trips, taking the waste away to a permanent geological repository. The waste will pass through 75% of the nation's congressional districts en route to New Mexico. Many of the nation's largest metropolitan areas will endure hundreds of canister transports over decades. The ability of the thin-walled canisters to uniformly withstand travel-related vibrations, moderate jarring, severe accidents or sabotage is dubious.
Once the canisters are delivered, Holtec will store them in shallow concrete burial pits.
The Holtec site is situated in a geologically troublesome area. Holtec will minimally monitor the suspect storage canisters in the hopes of avoiding dangerous spills, leakage and criticality for many decades. After 120 years-or longer--the aspiration is that the SNF will again be transported, this time to a final geological repository.
The CISF may have to accept a far larger volume of waste than can be accepted by the ultimate permanent repository. The Department of Energy had aimed to dispose of 63,000 metric tons of commercial power plant SNF in Yucca Mountain, which is only about half of what Holtec proposes to take in. If an undersized permanent geological repository is opened, the excess SNF waste will have to remain in New Mexico for an unknown period.
There is continuing support in the New Mexico legislature and among economic development advocates for reprocessing as a spin off to the CISF. Reprocessing is a dirty and dangerous means of reclaiming the dangerous isotopes in the waste which may bring a major radioactive waste-producing complex to New Mexico. Holtec's "interim" CISF is undeniably a major component of an enormous undertaking that carries grave national policy and cost implications. The Holtec CISF's centrality to nationwide management of SNF means that additional, nationwide, scoping must be undertaken by the NRC.
- 2. NEPA Scoping to Date for the Holtec CISF Is Grossly Inadequate The NRC's public involvement to date under the National Environmental Policy Act (NEPA) does not match the scale of policy, implementation and environmental concerns. On March 30, 2018, the NRC published in the Federal Register a notice of intent to prepare an environmental impact statement and conduct scoping on the Holtec International HI-STORE CISF project.4 A 60-day public comment period opened by the publication is slated to end on May 29, 2018. Only four public scoping hearings have been convened, including a national phone-in meeting at NRC headquarters in Rockville, Maryland, followed by three hearings in Roswell, Hobbs and Carlsbad, New Mexico, respectively.
This level of public engagement is grossly inadequate for a project of such magnitude.
The scoping process for the CISF pales in comparison to the NEPA public outreach for the proposed Yucca Mountain repository. In 1995, the U.S. Department of Energy (DOE) undertook 483 Fed. Reg. 13802 (March 30, 2018).
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a 120-day effort consisting of public comments and scoping hearings for the Yucca draft EIS in 17 U.S. cities and Nevada:
To reach minority and low-income communities, DOE contacted news publications and radio stations that tend to service these communities to notify them of the scoping meetings and the locations of available information. In addition, DOE met with 13 Native American tribes and organizations and provided them the same information. DOE invited public interest groups, transportation interests, industry and utility organizations, regulators, and members of the general public to participate in the process. The Department mailed a series of information releases to Yucca Mountain stakeholders notifying them of the opportunity to comment on the scope of the EIS; sent press releases and public service announcements to newspapers and television and radio stations; and made information about Yucca Mountain, the EIS, and the scoping process available on the Internet (at www.ymp.gov) and in public reading rooms around the country.
In 1995, DOE held 15 public scoping meetings across the country (DIRS 104630-YMP 1997, p. 7). More than 500 people submitted more than 1,000 comment documents during the 120-day public scoping period. DOE considered all comments-oral and written-it received during the scoping process and grouped them in categories.... 5 Holtec's Environmental Report, the basis for the Draft EIS, largely ignores the massive transportation effort that will be required for the facility to function. The minimal publicity efforts the NRC has conducted to date suggest that the agency may not adequately analyze the transportation implications, and will effectively segment those aspects from the waste storage parts of the proposal. The NRC's poor publicizing of the Holtec application is a far cry from the public involvement that characterized the Yucca Mountain scoping.
- 3. NRC Discretion to Limit Scoping ls Not Unbounded The NRC's discretion to limit or restrict NEPA scoping efforts has boundaries.
Scoping is the initial phase of the overall EIS process under NEPA. Citizens' Comm. to Save Our Canyons v. U.S. Forest Serv., 297 F.3d 1012, 1022 (10th Cir.2002). Scoping is "an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to a proposed action." 40 C.F.R. § 1501. 7; Citizens' Comm. to Save Our Canyons, 297 F.3d at 1022 (goal of scoping is to "identify [ ] specific issues to be addressed and studied" during the EIS process (citing 40 C.F.R. § 1501.7)).
According to the Ninth Circuit, the primary purpose of the scoping period "is to notify s..Final Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada," DOE/EIS-0250, Vol. l, pp. 1-23, 1-24.
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those who may be affected by a proposed government action which is governed by NEPA that the relevant entity is beginning the EIS process; this notice requirement ensures that interested parties are aware of and therefore are able to participate meaningfully in the entire EIS process, from start to finish." Kootenai Tribe of Idaho v. Veneman, 313 F.3d 1094, 1116 (9th Cir. 2002),
citing Northwest Coalition for Alternatives to Pesticides (NCAP) v. Lyng, 844 F.2d 588, 594-95 (9th Cir. 1988).
To initiate the scoping process, the lead agency must publish a Notice of Intention (NOI) in the Federal Register "[a]s soon as practicable after its decision to prepare an [EIS]." 40 C.F.R.
§ 150 I. 7. In the notice, the agency must "[i]nvite the participation of affected Federal, State, and local agencies" and "[ d]etermine the scope... and the significant issues to be analyzed in depth in the [EIS]." Id. § 1501.7(a)(l), (2). The agency "may... [s]et time limits" for the scoping process and "[h]old an early scoping meeting or meetings." Id. § 1501.7(b)(2), (4) (emphasis added).
Those time limits must comply with 40 C.F.R. § 1501.8. Id., § 1501.7(b)(I). Section 1501.8 does not "prescribe [ ] universal time limits for the entire NEPA process," but instead authorizes agencies to set time limits, including limits on the scoping process that are "appropriate to individual actions" and "are consistent with the purposes of NEPA and other essential considerations of national policy." Id. § 1501.8.
Council on Environmental Quality (CEQ) regulations do not set minimum time limits for the scoping period and do not require an agency to extend or reopen the scoping period. Congress intended that agency discretion, and not the courts, "be exercised in determining when extra procedural devices should be employed." Phillips Petroleum Co. v. U.S. EPA, 803 F.2d 545,559 (10th Cir.1986) (emphasis omitted) (quoting Vermont Yankee Nuclear Power Corp. v. Natural Res. Def Council, 435 U.S. 519,546 (1978) (internal quotation marks omitted). Thus a reviewing court generally can overturn an agency decision for failure to provide additional procedure only when there are "extremely compelling circumstances." Vermont Yankee, 435 U.S.
at 543.
- 4. Much More Public Participation ls Warranted We submit that Holtec's CISF proposal presents "extremely compelling circumstances" that necessitate much greater NRC scoping outreach and solicitation of public feedback. This immense, expensive and long-duration SNF storage project requires perfect transportation and containment of extraordinarily deadly substances for centuries to come. The continued storage of SNF at reactor sites as an alternative to Holtec requires further consideration. The risks from even one major cask accident or act of sabotage, if it is accompanied by serious radiation leakage, could be more than the public is willing to accept just to have the waste concentrated in New Mexico.
Before the decision to move deadly SNF 20,000 times can be made, the American public outside of New Mexico should be afforded meaningful participation. We therefore request that the scoping period and comment opportunity for the Holtec CISF be extended from May 29, 2018 until November 30, 2018. During that period, we further request that the NRC convene Page 5 of 11
town hall-style public meetings and comment sessions in the following cities, each of which is located on one or more anticipated major SNF transport routes:
Atlanta Boston Chicago Cleveland Dallas/Forth Worth Detroit San Antonio Kansas City Los Angeles Miami Minneapolis/Saint Paul Nashville New York/Newark Omaha Philadelphia Pittsburgh St. Louis Tampa The possibility of a spent fuel leak, explosion,' criticality or canister breach in any of these urban areas, and the questions of whether and how much Americans and the environment should bear the risks of this massive scheme, should be decided in a process that is truly national, visible and far more extensive.
We request an expedited decision from the NRC on these requests, given the fast-approaching May 29, 2018 deadline.
Thank you very much.
Isl Terry J. Lodge Terry J. Lodge, Esq.
316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 tjlodge50@yahoo.com Counsel for Don't Waste Michigan Isl Kevin Kamps Kevin Kamps, Radioactive Waste Watchdog Beyond Nuclear 6930 Carroll A venue, Suite 400 Takoma Park, Maryland 20912 kevin@beyondnuclear.org www.beyondnuclear.org Isl Victor McManemy Victor McManemy, Chairperson Citizens for Alternatives to Chemical Contamination (CACC)
P.O. Box 23 Isl Wallace L. Taylor Wallace L. Taylor 4403 1st Ave. S.E.
Suite 402 Cedar Rapids, Iowa 52402 Counsel for Sierra Club Lake Station, Michigan 48632 vrmcmanemy@yahoo.com Isl Tim Judson Tim Judson, Exec. Director Nuclear Information and Resource Services 6930 Carroll Ave, Ste. 340 Takoma Park, MD 20912 timj@nirs.org Page 6 of 11
Isl Rose Gardner Rose Gardner, Convenor Alliance For Environmental Strategies Box 514 1402 A venue A Eunice, NM 88232 nmlady2000@icloud.com Isl David A. Kraft David A. Kraft, Director Nuclear Energy Information Service 3411 W. Diversey #13 Chicago, IL 6064 7 neis@neis.org Isl Adrian Shelley Adrian Shelley, Director, Texas Office Public Citizen 309 East 11th Street, Suite 2 Austin, TX, 78701 http://www.citizen.org/texas ashelley@citizen.org Isl Allison Fisher Allison Fisher Outreach Director, Energy Program Public Citizen 215 Pennsylvania A venue SE Washington, D.C. 20003 (202) 546-4996 Isl Manna Jo Greene Manna Jo Greene, Environmental Director Hudson River Sloop Clearwater, Inc.
724 Wolcott Ave.
Beacon, NY 12508 845-265-8080 X 7113 www.clearwater.org Isl Debra Stoleroff Debra Stoleroff Vermont Yankee Decommissioning Alliance Plainfield, Vermont debrasto leroff@protonmai l,com Isl Sarah Fields Sarah Fields Uranium Watch P.O. Box 1306 Monticello, Utah 84532 435-260-8384 sarah@uraniumwatch.org Isl Linda Seeley Linda Seeley, Convenor P.O. Box 3608 San Luis Obispo Mothers for Peace San Luis Obispo, CA 93403 www.mothersforpeace.org Isl Damon Motz-Storey Damon Motz-Storey Clean Energy Organizer Oregon Physicians for Social Responsibility I 020 SW Taylor Street, Suite 275 Portland, OR 97205 info@oregonpsr.org Isl Karen Hadden Karen Hadden, Convenor Sustainable Energy & Economic Development (SEED) Coalition 605 Charismatic Lane Austin, TX 78748 512-797-8481 karendhadden@gmail.com www.NoNuclearWaste.org Isl Schuyler Gould Schuyler Gould, President New England Coalition on Nuclear Pollution Brattleboro, Vermont skygvt@aol.com Page 7 of 11
Isl LuAnne Kozma LuAnne Kozma, president Ban Michigan Fracking 9330 Woods Road Charlevoix MI 49720 www.banmichiganfracking.org Isl John McFadden John McFadden, CEO Tennessee Environmental Council One Vantage Way, Suite E-250 Nashville, Tennessee 37228 Isl Janet Greenwald Janet Greenwald, Convenor Citizens for Alternatives to Radioactive Dumping (CARD) 215 Hartline SW Albuquerque, NM 87105 Isl Tanya Keefe Tanya Keefe, Chair Great Lakes Environmental Alliance 525 Court St.
Port Huron, Ml 48060 tanya _ keefe@yahoo.com Isl Scott Williams Scott Williams, M.D., M.P.H., Director Healthy Environment Alliance of Utah (HEAL Utah) 824 South 400 West Suite B-111 Salt Lake City, Utah 84101 scott@healutah.org Isl Gordon Edwards Canadian Coalition for Nuclear Responsibility 53 Dufferin Road, Hampstead Quebec, H3X 2X8 Canada ccnr@ web.ca Isl Barbara Warren Barbara Warren, Executive Director Citizens' Environmental Coalition 33 Central Ave, 3rd Floor Albany, NY 12210 warrenba@msn.com Isl Vina Colley Vina Colley, President PRESS (Portsmouth/Piketon Residents for Environmental Safety and Security)
Co-Founder ofNNWJ (National Nuclear Workers for Justice)
P.O. Box 136 Portsmouth, Ohio 45662 740-357-8916 vcolley@earthlink.net Isl Gwen DuBois Gwen Dubois, MD, MPH, President Chesapeake Physicians for Social Responsibility 325 E. 25th Street Baltimore Maryland 21218 bikenotbomb@gmail.com Isl Jay Coghlan Jay Coghlan, Executive Director Nuclear Watch New Mexico Alameda #325 Santa Fe, NM 87501 505.989.7342 jay@nukewatch.org www.nukewatch.org.
Isl Denise Duffield Denise Duffield, Associate Director Physicians for Social Responsibility-Los Angeles (PSR-LA) 617 S. Olive Street, Suite 1100 Los Angeles, CA 90014 213-689-9170 ext. 104 dduffield@psr-la.org Page 8 of 11
Isl Stephen Brittle Stephen Brittle, Convenor Don't Waste Arizona 2934 West Northview Avenue Phoenix, AZ 85051 dwaz@fastq.com Isl Marylia Kelley Marylia Kelley, Executive Director Tri-Valley CAREs (Communities Against a Radioactive Environment) 4049 First Street, Suite 139 A Livermore, CA 94551 marylia@earthlink.net Isl Deb Katz Deb Katz, Convenor Citizens Awareness Network Box 83 Shelburne Falls, MA 01370 deb@nukebusters.org Isl Damon Moglen Damon Moglen, Senior Strategic Advisor Friends of the Earth 1101 15th Street, NW, 11th Floor Washington, DC 20005 Ph: 202-222-0708 dmoglen@foe.org Isl Gary Headrick Gary Headrick, Convenor San Clemente Green San Clemente, CA garyheadrick@gmail.com Isl Molly Johnson Molly Johnson, Area Coordinator SLO (San Luis Obispo) County Grandmothers for Peace 6290 Hawk Ridge Pl San Miguel, CA 93451 mollypj@yahoo.com Isl Maureen K. Headington Maureen K. Headington, President Stand Up/Save Lives Campaign 6760 County Line Lane Burr Ridge, IL 60527 630-323-6891 moeteam@comcast.net Isl Siegfried (Ziggy) Kleinau Siegfried (Ziggy) Kleinau, Co-Founder and Outreach Director Bruce Peninsula Environment Group Bruce County, Ontario, Canada ziggyk3 8@gmail.com Isl Liz Kirkwood Liz Kirkwood, J.D., Executive Director FLOW (For Love Of Water) 153 1/2 East Front Street, Suite 203C Traverse City, MI 49684 231.944.1568 liz@flowforwater.org http://flowforwater.org/
Isl Joni Arends Joni Arends, Executive Director Concerned Citizens for Nuclear Safety P.O. Box 31147 Santa Fe, NM 87594-1147 505 986-1973 jarends@nuclearactive.org Isl Greg Mello
- Greg Mello, Executive Director Los Alamos Study Group 290 l Summit Pl. NE Albuquerque, NM 87106 Phone: 505-265-1200 gmello@lasg.org http://www.lasg.org/
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Isl Cheryl Nenn Cheryl Nenn, Riverkeeper Milwaukee Riverkeeper 1845 N Farwell A venue, Suite 100 Milwaukee, WI 53202 414.287.0207 x2 www.mi 1 waukeeriverkeeper.org cheryl _ nenn@milwaukeeriverkeeper.org Isl Eleanor Bravo Eleanor Bravo, Nat'l Pipeline Campaign Manager Food & Water Watch and Action 7804 Pan American Frwy E NE, Suite 2 Albuquerque, NM 87109 Office (505) 633-7366 ebravo@fwwatch.org https://www.foodandwaterwatch.org/
Isl Mary Beth Brangan Mary Beth Brangan, Co-Director EON (Ecological Options Network)
P.O. Box 1047 Bolinas, CA 94924 415-868-1900 - office www.eon3.net https://www.youtube.com/eon3 Isl Sally Jane Gellert Sally Jane Gellert, Convenor Occupy Bergen County Teaneck, NJ SJGUU@aol.com Isl Jessie Collins Jessie Collins, Co-chair Citizens' Resistance at Fermi 2 17397 Five Points Street Redford Ml 48240 313.286.3827 shutdownfermi@gmail.com jessiepauline2003@yahoo.com Isl Sister Marlene Perrotte Sisters of Mercy 1004 Major A venue NW Albuquerque, NM 87107 marlenep@swcp.com Isl Regina Minniss Regina Minniss, Treasurer Crabshell Alliance 6 W. Mt. Vernon Place #301 Baltimore, MD 21201 rminniss@hotmail.com Isl John LaForge John LaForge, Convenor Nukewatch 740A Round Lake Road Luck, Wisconsin 54853 jmichaellaforge@yahoo.com http://nukewatchinfo.org/
Isl Sheila Parks Sheila Parks, Ed.D., Founder On Behalf of Planet Earth Massachusetts 617-744-6020 sheilaruthparks@comcast.net http://www.madownwinders.org/on-behalf-of-planet-earth/
Isl Priscilla Star Priscilla Star, Convenor Coalition Against Nukes 90 Wainscott Stone Road Wainscott, NY 11975 priscillastar@hotmail.com 631-680-5163 Isl Alice Slater Alice Slater, Convenor Nuclear Age Peace Foundation 446 E. 86 St.
New York, NY 10028 212-744-2005 www.wagingpeace.org Page 10 of 11
Isl Diane Turco Diane Turco, Director Cape Downwinders P.O. Box 303 South Harwich, MA 02646 capedownwindersinfo@gmail.com Isl Sandra McCardell Sandra McCardell, President Current-C Energy Systems, Inc.
318 lsleta Blvd. SW Albuquerque NM 87105 Phone 505 795-2702 sandra.coopcatalyst@gmail.com Isl Jeff Carter Jeff Carter, Executive Director Physicians for Social Responsibility l l 11 14th St, NW, Suite 700 Washington, DC 20005 (202) 587-5240 www.psr.org I jcarter@psr.org I @jeffcrtr Page 11 of 11
Mccloskey, Bridin Attachments:
Scoping extension demand lttr FINAL.pdf From: Terry Lodge <tjlodge50@yahoo.com>
To: Chairman@NRC.gov <Chairman@NRC.gov>; CMRBARAN@nrc.gov <CMRBARAN@nrc.gov>;
CMRBURNS@nrc.gov <CMRBURNS@nrc.gov>; jose.cuadrado@nrc.gov <jose.cuadrado@nrc.gov>; annette.vietti-cook@nrc.gov <annette.vietti-cook@nrc.gov>
Cc: Kevin Kamps <kevin@beyondnuclear.org>; Keegan/Michael <mkeeganj@comcast.net>; Diane D'Arrigo
<dianed@nirs.org>; Wally Taylor <wtaylor784@aol.com>
Sent: Wednesday, May 9, 2018, 11 :07:49 AM EDT
Subject:
Holtec International, Docket 72-1051 (Request for expansion of scoping phase)
Hon. Commissioners Svinicki, Baran and Burns, Mr. Cuadrado and Ms. Vietti-Cook:
Kindly review the attached request for extension and expansion of the scoping period in the Holtec International licensing case and respond at your earliest convenience.
Thank you very much.
Terry J. Lodge, Esq.
316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 205-7084 1