ML23333A009

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Attachment a - NRC Extension of Comment Period-1
ML23333A009
Person / Time
Site: Turkey Point  
Issue date: 10/27/2023
From: Lance Rakovan
Office of Nuclear Material Safety and Safeguards
To: Bills C, Cartwright S
Miami Waterkeeper
Shared Package
ML23333A008 List:
References
Download: ML23333A009 (1)


Text

11/26/23, 2:45 PM Biscayne Bay Waterkeeper Mail day extension review https://mail.google.com/mail/u/0/?ik=88fda35597&view=pt&search=all&permmsgid=msg-f:1780931854622358043&dsqt=1&simpl=msg-f:1780931854 1/3 Sydnei Cartwright <sydnei@miamiwaterkeeper.org>

15-day extension review Lance Rakovan <Lance.Rakovan@nrc.gov>

Fri, Oct 27, 2023 at 1:49 PM To: Cameron Bills <cameron@miamiwaterkeeper.org>, Audrey Siu <audrey@miamiwaterkeeper.org>, Sydnei Cartwright

<sydnei@miamiwaterkeeper.org>

Audrey, Cameron & Sydnei -

Ive talked your request over with my management and we have something of a compromise to offer. Officially extending the commenting period means we would have to take several formal steps including issuing a Federal Register Notice.

Instead, what Id like to offer is that we pledge to accept whatever comments you provide by November 26th (your 15-day request would put us right before Thanksgiving and you can assume that there would not be much action on them until the following week) without a formal extension. Per our earlier discussions, we have already started taking action on the issues you detailed in your previous request letter.

Please let me know if you have any additional questions.

Best, Lance From: Cameron Bills <cameron@miamiwaterkeeper.org>

Sent: Wednesday, October 25, 2023 12:30 PM To: Lance Rakovan <Lance.Rakovan@nrc.gov>

Cc: Audrey Siu <audrey@miamiwaterkeeper.org>; Sydnei Cartwright <sydnei@miamiwaterkeeper.org>

Subject:

[External_Sender] Re: 15-day extension review

Lance, Thank you for getting back to us so quickly, and for clarifying that NRC set an initial comment period that exceeds the 45-day minimum.

We know that y'all have a lot on your plate right now, and we would really appreciate any extension you are able to provide. Thank you for your consideration.

Best, Cameron Attachment A

11/26/23, 2:45 PM Biscayne Bay Waterkeeper Mail day extension review https://mail.google.com/mail/u/0/?ik=88fda35597&view=pt&search=all&permmsgid=msg-f:1780931854622358043&dsqt=1&simpl=msg-f:1780931854 2/3 On Wed, Oct 25, 2023 at 8:44AM Lance Rakovan <Lance.Rakovan@nrc.gov> wrote:

Audrey -

Ive received your request and will do my best to get back to you much quicker than last time.

I will note, however, that I believe the intent of the language you cite in 10 C.F.R. § 51.73 pertaining to a 15-day extension is meant to apply to the 45-day comment period NRC typically provides for a draft EIS (per NEPA). In the case of the Turkey Point draft site-specific EIS, NRC decided to apply that 15-day extension automatically given the first-of-its-kind nature of the document. This is why the comment period was 60 days from the start. Im not saying that were not going to consider your request, but wanted to at least let you know how that 15 day extension language is being looked at here at the NRC.

I will try to get back to you by the end of the week.

Best, Lance From: Audrey Siu <audrey@miamiwaterkeeper.org>

Sent: Tuesday, October 24, 2023 6:44 PM To: Lance Rakovan <Lance.Rakovan@nrc.gov>

Cc: Cameron Bills <cameron@miamiwaterkeeper.org>; Sydnei Cartwright <sydnei@miamiwaterkeeper.org>

Subject:

[External_Sender] 15-day extension review Hi Lance, Thank you again for taking the time to speak with us last week. We understand that our 60-day extension request was denied. We are writing in the hopes that you will grant us a shorter, 15-day extension request, as provided in 10 C.F.R.

§ 51.73 ("To the extent practicable, NRC staff will grant reasonable requests for extensions of time of up to fifteen (15) days.").

We realize that NRC has a number of competing deadlines. However, we would be grateful for even a short extension.

Thank you kindly in advance for your consideration.

Audrey Siu Policy Director Miami Waterkeeper Attachment A

11/26/23, 2:45 PM Biscayne Bay Waterkeeper Mail day extension review https://mail.google.com/mail/u/0/?ik=88fda35597&view=pt&search=all&permmsgid=msg-f:1780931854622358043&dsqt=1&simpl=msg-f:1780931854 3/3 305-586-0151 Miami Waterkeeper logo Protecting the water you love.

www.miamiwaterkeeper.org FACEBOOKlINSTAGRAMlTWITTER Attachment A