ML20244A381
| ML20244A381 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/30/2020 |
| From: | Public Commenter Public Commenter |
| To: | Office of Nuclear Material Safety and Safeguards |
| NRC/NMSS | |
| References | |
| 85FR46193 | |
| Download: ML20244A381 (5) | |
Text
From: Michelle Wise Mitchum <pinehillndn@yahoo.com>
Sent: Sunday, August 30, 2020 6:54 PM To: WEC_CFFF_EIS Resource
Subject:
[External_Sender] Docket ID NRC-2015-0039 Westinghouse Columbia Fuel Fabrication Facility, Columbia, SC Attachments: Letter to US Nuclear Commission 8-30-20.pdf Please see our attached letter in response to the Wesingtonhouse matter.
Chief Michelle Mitchum Pine Hill Indian Tribe Executive Director, Pine Hill Indian Community Development Initiative Director, Pine Hill Health Network Ambassador, Community Health Worker Institute, Center for Community Health Alliance, UofSC Arnold School of Public Health (803) 662-3377
Federal Register Notice: 85FR46193 Comment Number: 21 Mail Envelope Properties (1154074778.573400.1598828041865)
Subject:
[External_Sender] Docket ID NRC-2015-0039 Westinghouse Columbia Fuel Fabrication Facility, Columbia, SC Sent Date: 8/30/2020 6:54:01 PM Received Date: 8/30/2020 6:54:09 PM From: Michelle Wise Mitchum Created By: pinehillndn@yahoo.com Recipients:
Post Office: mail.yahoo.com Files Size Date & Time MESSAGE 369 8/30/2020 6:54:09 PM Letter to US Nuclear Commission 8-30-20.pdf 104685 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Pine Hill Indian Tribe The First People of Fort Jackson, South Carolina August 30, 2020 Office of Administration US Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Docket ID NRC-2015- 0039/Westinghouse Fuel Fabrication Facility, Columbia SC.
Dear US Nuclear Regulatory Commission:
Thank you tremendously for your maintenance of transparency on issues relating to WFFF and their quest to renew their license another 40 years.
Maintaining complete transparency and mutual respect, and by way of history, my Tribe (Pine Hill Indian Tribe) originates during the colonial period in the Wateree-Congaree River Basin in Richland County, SC but was removed from our original lands by the US Government for the installation of Fort Jackson. Acknowledgment of one of our Ancestors' original homesite, Site 38DR466, was announced publicly by Fort Jackson in 2013. Colonial records show that Fort Congaree was built for our People through a trade agreement between my People and James Moore, to which the Commissioners for Indian Trade grew an interest to become invested. Our recent forced removal from our ancestral lands resulted in our migration to western Orangeburg Country where we have remained. Thus, this matter is very important to us as we have a historical investment in this area. While there are many such archaeological sites known in the vicinity of WFFF, such as the over 600 are known on nearby Fort Jackson, many others have yet to be discovered, identified, and properly investigated which would provide valuable information about our Ancestors and our history.
From a unique personal experience, I know the effects of the hydrodynamic practices which I am sure WFFF is likely required to follow while various forms of contamination knowingly continue to leak and are transported to Barnwell County. My personal experience lead to a Louisiana Supreme Court decision (Pounds v. Florida Power & Light Co., 762 So. 2d 161 (La. Ct. App. 2000)). In sum, my ex-husband developed brain damage from exposure to such chemicals, as is recorded in the litigations that followed his exposure on January 14, 1997.
Our son was 1 month and 11 days old when he lost every resemblance of the man I married who is his father. For over 23 years, and many more years to come, my son will never know his father as his father was before this unfortunate and completely avoidable incident. Four men went to work that that day, and four extremely sick strangers were sent home to their families.
Families were destroyed forever, creating an unnecessary generational impact. One of the four injured committed suicide because of his chemical brain injury. Thus, while known 4055 Coburg Lane (803) 662-3377 Orangeburg, South Carolina 29115 pinehillndn@yahoo.com
US Nuclear Commission Re: Docket ID NRC-2015- 0039/WFFF, Columbia, SC Page 2 of 3 contamination is recorded to exist at WFFF, myself and my Tribe fear the health and safety of WFFF employees, residents in multiple locations, and archaeologists and their families.
With our Tribes known and well documented presence in the area, and based on personal experience, the current and potential future posture of this matter might result in contaminating and/or destroying significant cultural resources and sites which will restrict areas from archaeological research. Doing so will jeopardize the health and safety of those excavating the sites. Archaeology requires digging below the ground surface, touching soil with hands, and retaining soil samples for further study and analyses. The health of this physical environment must be protected at all costs in order that we might learn from such cultural resources and educate the citizens of South Carolina of our Indigenous People. Likewise, archaeologists simply should not be placed in an entirely foreseeable, predictable, and avoidable toxic environment causing unknown risk to their lives while attempting to help us identify and recognize our own significant cultural history and impact on what is now South Carolina. Restricting such research leaves the history and cultural study of our Indigenous People of the Province of Carolina, our pre-colonial evidence, and my Tribe since colonization of Carolina marginalized and disenfranchised to traditional written opinions of our histories. Native American burial sites have been identified in close proximity to the Westinghouse Facility and others are certainly present elsewhere.
My Tribes position is that this is an issue of comorbidities involving health, socioeconomics, environment, as well as a culture. As you move forward to determine the appropriate scope of the EIS for the Westinghouse Fuel Fabrication Facility, including significant environmental issues, we urge you to consider the immediate and future holistic impacts in this matter. The holistic impact endangers the past, present and future to which my Tribe is responsible. Allowing the creation of a multitude of detrimental and irreversible dangers expose everyone in the area and potentially in Barnwell, robbing the public at large their right to life. As these invaluable cultural resources and sites become contaminated, our historical presence and impact in South Carolinas history is permanently lost forever. The health of this physical environment must be protected at all costs so we might learn from such cultural resources and educate the citizens of South Carolina.
I also recommend that the Nuclear Regulatory Commission (NRC) ensure that the scope of the Environmental Impact Statement (EIS) for the Westinghouse Fuel Fabrication Facility (WFFF) includes consideration of impacts to archaeological and historical resources outside of the developed boundary of the WFFF. The scope of the EIS should include non-ground disturbing impacts that would result from spills, leaks, clouds or other forms of contamination that would effectively make those resources and the valuable information they contain inaccessible to current and future generations. Like ground disturbing activities such as the installation of subsurface monitoring wells, contamination also has the potential to disturb not just archaeological sites but also human remains in unmarked Native American and African 4055 Coburg Lane (803) 662-3377 Orangeburg, South Carolina 29115 pinehillndn@yahoo.com
US Nuclear Commission Re: Docket ID NRC-2015- 0039/WFFF, Columbia, SC Page 3 of 3 American cemeteries. This would effectively make those areas inaccessible to descendant communities now and in the future. Given the potential for these impacts to move beyond the current boundary of the WFFF, the scope of the EIS should reach to the Congaree River and some distance both up and down the river.
All historical and cultural resources should be identified, assessed, and impacts mitigated as part of any process that grants the WFFF a license to continue operation in this culturally sensitive part of South Carolina. Such a goal could be achieved by conducting intensive archaeological surveys in large areas and clearing them as part of this current licensing process. That process of identification should involve a group of stakeholders, including private landowners, Federally recognized tribes, State recognized Native American communities, South Carolina State Historic Preservation Office, South Carolina Institute of Archaeology and Anthropology, Congaree National Park, Friends of Congaree Swamp, professional archaeologists, historians, cultural anthropologists and other interested parties.
I also recommend that the NRC ensure that the scope of the EIS for WFFF include all known potential health risks, immediate and generational as well as indirectly to future generations which can be identified, assessed, and impacts mitigated as part of the license grant process based on past evidence-based examples matching the current issues.
Finally, and in consideration of our shared uncertain future due to the current COVID-19 pandemic, I recommend that the NRC conduct a forensic cost analysis to determine the economic value of decommissioning and decontamination measures necessary today as compared to in 40 years if the WFFF license is renewed.
I trust you will consider the significance of all issues raised herein as you prepare an EIS for this dangerous facility.
Respectfully, Chief Michelle Mitchum Pine Hill Indian Tribe Executive Director, Pine Hill Indian Community Development Initiative Director, Pine Hill Health Network Ambassador, Community Health Workers Institute, Center of Community Health Alignment, UofSC Arnold School of Public Health 4055 Coburg Lane (803) 662-3377 Orangeburg, South Carolina 29115 pinehillndn@yahoo.com