ML20267A177
| ML20267A177 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/22/2020 |
| From: | Arnold R, Rachel Johnson, Moore T Consolidated Group of Tribes & Organizations, Pahrump Paiute Tribe, Prairie Island Indian Community, Tribal Radioactive Materials Transportation Committee (TRMTC) |
| To: | Office of Administration |
| References | |
| 85FR16150 00106, NRC-2018-0052 | |
| Download: ML20267A177 (3) | |
Text
PUBLIC SUBMISSION As of: 9/23/20 8:10 AM Received: September 22, 2020 Status: Pending_Post Tracking No. kfe-k64a-01nd Comments Due: September 22, 2020 Submission Type: Web Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0376 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0414 Comment on FR Doc # 2020-17536 Submitter Information Email: tansey.moore@ncsl.org Government Agency Type: Tribal Government Agency: Tribal Radioactive Materials Transportation Committee General Comment See attached file(s)
Attachments NRC comments on Holtec CISF Sept. 22 2020 Final Page 1 of 1 09/23/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484871a0f&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (106)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
TRMTC Tribal Radioactive Materials Transportation Committee Agua Caliente Band of Cahuilla Indians Catawba Indian Nation Confederated Tribes of the Umatilla Indian Reservation Mashpee Wampanoag Tribe Morongo Band of Mission Indians Navajo Nation Nez Perce Tribe Omaha Tribe of Nebraska Oneida Nation of Wisconsin Consolidated Group of Tribes and Organizations Prairie Island Indian Community Pueblo de San Ildefonso Pueblo of Jemez Pueblo of Laguna Pueblo of Pojoaque Pueblo of Tesuque Santa Clara Pueblo Seneca Nation of Indians Shoshone-Bannock Tribes Timbisha Shoshone Tribe 9/22/20 Office of Administration Mail Stop: TWFN-7-A60M ATTN: Program Management, Announcements and Editing Staff, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
Re: Docket ID NRC-2018-0052 - Comments on Holtec International HI-STORE Consolidated Interim Storage Facility Project
Dear Office of Nuclear Material Safety and Safeguards,
The Tribal Radioactive Materials Transportation Committee (TRMTC), a tribal working group comprised of twenty (20) federally recognized tribes, supported by a Department of Energy (DOE) Cooperative Agreement to provide input and coordination on the Departments transportation activities that potentially impact tribes, respectfully submits the following comments related to the Holtec International HI-STORE Consolidated Interim Storage Facility Project draft Environmental Impact Statement (EIS), as noticed in the Federal Register on April 27, 2020 (85FR23382).
These comments on the EIS fall into two categories: (1) concerns with the Nuclear Regulatory Commissions (NRCs) outreach to tribes and (2) transportation considerations.
Under the auspices of the DOE National Transportation Stakeholders Forum (NTSF)
TRMTC engages with senior-level staff from DOE, Nuclear Regulatory Commission (NRC), Department of Transportation, other federal agencies and stakeholders who focus on national policy, program development and related activities associated with shipments of radioactive materials transportation.
TRMTCs view is that the NRCs outreach to tribes to determine potential environmental impacts to tribal lands, people and resources was too limited. The NRC consulted with a limited number of tribes to determine potential impacts, and outreach efforts focused solely on assessing construction-related impacts.
Potential transportation impacts from shipments of spent nuclear fuel through tribal lands, were not evaluated in the EIS. Transportation may potentially impact tribal people, lands and resources along or adjacent to a route to the proposed facility. Moreover, tribes not
2 only have reservations or Trust lands, but also ceded or ancestral lands, to which they may have Treaty-protected hunting, fishing and gathering rights that could potentially be impacted by shipments of spent nuclear fuel.
Once a transportation route is submitted to the NRC for approval, the agency should commit to identifying tribes along or adjacent to the transportation route to make them aware of the Advanced Notification Program and the option to opt in.
TRMTC appreciates the opportunity to comment and is hopeful that the NRC will take these concerns into consideration and revise the final EIS accordingly.
Respectfully, Richard Arnold, Pahrump Paiute Tribe/ Consolidated Group of Tribes and Organizations TRMTC Co-Chair Richard Arnold Ron Johnson, Prairie Island Indian Community TRMTC Co-Chair Ron Johnson