ML22293B656
| ML22293B656 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/18/2022 |
| From: | Ayres R, Reiser C, Silverstein R Friends of the Earth, Miami Waterkeeper, Natural Resources Defense Council |
| To: | Lance Rakovan Office of Administration, NRC/NMSS/DREFS/ELRB |
| Lance Rakovan NMSS/REFS/ELRB 301-5252728 | |
| References | |
| NRC-2022-0172 | |
| Download: ML22293B656 (2) | |
Text
October 18, 2022 Via Electronic Mail Program Management, Announcements and Editing Staff Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 TurkeyPoint34Environmental@nrc.gov Lance Rakovan Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Lance.Rakovan@nrc.gov
Subject:
Request for 45 Day Extension of Comment Period of Turkey Point Subsequent License Renewal Scoping Process, Docket ID NRC-2022-0172
Dear U.S. Nuclear Regulatory Commission:
Miami Waterkeeper, Friends of the Earth (FOE), and the Natural Resources Defense Council (NRDC) write today to respectfully request that the Nuclear Regulatory Commission (NRC) extend the deadline for public comment on the Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement Florida Power & Light Company Turkey Point Nuclear Generating Unit Nos. 3 and 4, 87 Fed. Reg. 61,104 (Oct. 7, 2022), for an additional forty-five (45) days. Each of our three organizations represent members in South Florida, intervened in the 2018 Atomic Safety and Licensing Board and Commission proceedings, and plan to intervene again. An extension of time is necessary for the following reasons.
On September 28, 2022, just over a week before the NRC Notice regarding the Turkey Point scoping, hurricane Ian made landfall in Florida. As a Category 4 storm, just shy of Category 5, Ian was the fifth-strongest hurricane on record to strike the United States. Ian hit Florida with intense wind, heavy rainfall, and unprecedented storm surge. The storm knocked out power for more than four million customers in Florida.1 While the epicenter of the hurricanes destruction was not in the same region as the Turkey Point nuclear plant, the region was not left untouched.2 It will take Florida a long time to recover from hurricane Ian,3 and currently significant attention, energy, and concern is focused on the recovery effort. As such, requiring this community to comment on the Turkey Point scoping process within a short 30 days is unreasonable.
1 https://www.nesdis.noaa.gov/news/hurricane-ians-path-of-destruction.
3 https://www.washingtonpost.com/nation/2022/09/30/hurricane-ian-damage-photos-videos/;
The Turkey Point licenses will not expire for ten years, after which the licenses can continue during the subsequent renewed license process pursuant to the timely renewal doctrine. Thus, extending the comment deadline here would not cause significant harm.
Further, our organizations small staff and relatively minor resources are stretched thin. Our attorneys are preparing for active litigation in federal courts, and there are multiple additional comment deadlines at the beginning of November 2022. A mere 45-day extension to the Turkey Point scoping comment period will provide the time necessary for our organizations to provide constructive comments.
We urge the NRC to extend the comment period. Please do not hesitate to contact us if you have questions or concerns. Thank you for your attention and consideration of this matter.
Sincerely, Caroline Reiser Staff Attorney Natural Resources Defense Council creiser@nrdc.org Rachel Silverstein, Ph.D.
Executive Director & Waterkeeper Miami Waterkeeper rachel@miamiwaterkeeper.org Richard Ayres Counsel for Friends of the Earth ayresr@ayreslawgroup.com