ML20267A177

From kanterella
Jump to navigation Jump to search
Comment (106) of Tansey Moore, Richard Arnold, & Ron Johnson on Holtec International HI-STORE Consolidated Interim Storage Facility Project
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

Page 1 of 1 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly As of: 9/23/20 8:10 AM Received: September 22, 2020 Status: Pending_Post PUBLIC SUBMISSION COMMENT (106)

PUBLICATION DATE:

3/20/2020 Tracking No. kfe-k64a-01nd CITATION 85 FR 16150 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 https://www.fdms.gov/fdms/getcontent?objectId=0900006484871a0f&format=xml&showorig=false 09/23/2020

TRMTC Tribal Radioactive 9/22/20 Materials Transportation Committee Office of Administration Agua Caliente Band of Cahuilla Indians Mail Stop: TWFN-7-A60M ATTN: Program Management, Announcements and Editing Staff, U.S. Nuclear Regulatory Catawba Indian Nation Commission, Confederated Tribes of the Washington, DC 20555-0001.

Umatilla Indian Reservation Mashpee Wampanoag Tribe Re: Docket ID NRC-2018-0052 - Comments on Holtec International HI-STORE Consolidated Interim Storage Facility Project Morongo Band of Mission Indians Navajo Nation

Dear Office of Nuclear Material Safety and Safeguards,

Nez Perce Tribe The Tribal Radioactive Materials Transportation Committee (TRMTC), a tribal working Omaha Tribe of Nebraska group comprised of twenty (20) federally recognized tribes, supported by a Department of Energy (DOE) Cooperative Agreement to provide input and coordination on the Oneida Nation of Wisconsin Departments transportation activities that potentially impact tribes, respectfully submits Consolidated Group of the following comments related to the Holtec International HI-STORE Consolidated Tribes and Organizations Interim Storage Facility Project draft Environmental Impact Statement (EIS), as noticed in Prairie Island Indian Community the Federal Register on April 27, 2020 (85FR23382).

Pueblo de San Ildefonso These comments on the EIS fall into two categories: (1) concerns with the Nuclear Pueblo of Jemez Regulatory Commissions (NRCs) outreach to tribes and (2) transportation considerations.

Pueblo of Laguna Under the auspices of the DOE National Transportation Stakeholders Forum (NTSF)

Pueblo of Pojoaque TRMTC engages with senior-level staff from DOE, Nuclear Regulatory Commission (NRC), Department of Transportation, other federal agencies and stakeholders who focus Pueblo of Tesuque on national policy, program development and related activities associated with shipments of Santa Clara Pueblo radioactive materials transportation.

Seneca Nation of Indians TRMTCs view is that the NRCs outreach to tribes to determine potential environmental Shoshone-Bannock Tribes 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 Timbisha Shoshone Tribe 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

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 2