State Seal
1802 N. Carson Street, Suite 252
Carson City, Nevada 89701
Telephone: (775) 687-3744
Fax: (775) 687-5277
Executive Director

April 6, 1999


Dr. Shirley Ann Jackson, Chairman
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Dear Dr. Jackson:

On February 26, 1999 NRC issued a Notice in the Federal Register seeking public comments on proposed changes to the requirements for environmental review for renewal of nuclear power plant operating licenses. The Notice deals with information on the transportation of spent fuel to the proposed high-level radioactive waste repository at Yucca Mountain. The Notice incorporates information and findings from a draft Addendum to NUREG-1437 (Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Addendum 1, Section 6.3 - Transportation).

I am writing to request that the period for public comment on the proposed changes contained in the Federal Register Notice be extended by 90 days and that NRC agree to hold at least one public hearing on the proposed changes in Las Vegas. In addition, NRC should reissue the Notice with a title that is clearly reflective of the actual content, since the Notice deals exclusively with the transportation of spent nuclear fuel. As it is, the title is misleading and refers only to environmental review for nuclear power plant license renewals.

The public comment period must be extended to afford the State of Nevada, local governments in southern Nevada, other states, and interested parties adequate time to obtain materials required for carrying out an adequate review (i.e., the Addendum to NUREG-1437 and reference documents) and to prepare comments. The current 30 day comment period (which expires on April 27, 1999) is inadequate given the complex and technical nature of the issues covered by the Notice and the Addendum and widespread public interest in nuclear waste transportation.

It is also of concern to the State of Nevada that NRC published this Notice and prepared the draft Transportation Addendum without any consultation with the State of Nevada or local governments in southern Nevada, since the analysis contained in the Addendum deal extensively with the potential impacts of the transportation of spent fuel through the Las Vegas metropolitan area. This is especially troubling since NRC staff incorporated Clark County planning documents into the Addendum without having consulted with County or State personnel regarding the status of information contained in those documents.

To assure that NRC has afforded adequate opportunities for public input - including input from County and State officials most directly involved with spent fuel transportation issues in southern Nevada - it is imperative that NRC hold at least one public hearing in Las Vegas. The hearing should be scheduled early in the extended comment period and should be structured so as to provide, in addition to opportunities for public comment, a summary by NRC staff of the substance of the proposed changes and the rationale underlying them.

Thank you for your attention to this matter.


Robert R. Loux
Executive Director

Victoria Soberinsky, Governor’s Office
Nevada Congressional Delegation
Commission on Nuclear Projects
Clark County
City of Las Vegas
City of North Las Vegas
City of Henderson
Boulder City
Moapa Band of Paiutes
Las Vegas Indian Colony