ML20309A406

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Comment (64) from Ron Johnson on Behalf of Tribal Radioactive Materials Transportation Committee (Trmtc) on Interim Storage Partners Consolidated Interim Storage Facility Project
ML20309A406
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 11/03/2020
From: Rachel Johnson
Tribal Radioactive Materials Transportation Committee (TRMTC)
To:
Office of Administration
References
85FR27447 00064, NRC-2016-0231
Download: ML20309A406 (3)


Text

PUBLIC SUBMISSION As of: 11/4/20 9:27 AM Received: November 03, 2020 Status: Pending_Post Tracking No. kh2-np61-tvg4 Comments Due: November 03, 2020 Submission Type: Web Docket: NRC-2016-0231 Waste Control Specialists LLC's Consolidated Interim Spent Fuel Storage Facility Project Comment On: NRC-2016-0231-0317 Interim Storage Partners Consolidated Interim Storage Facility Project Document: NRC-2016-0231-DRAFT-0375 Comment on FR Doc # 2020-09795 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 TRMTC NRC comments on ISP CISF 11 3 20 Final Page 1 of 1 11/04/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064849498f2&format=xml&showorig=false SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: James Park Comment (64)

Publication Date 5/8/2020 CITATION 85 FR 27447 PMD-07201051

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 11/3/20 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-2016-0231-Comments on Interim Storage Partners Consolidated Interim Storage Facility Project

Dear Office of Nuclear Material Safety and Safeguards,

TRMTC is a committee of 20 tribal nations established under the auspices of the Department of Energy (DOE) National Transportation Stakeholders Forum (NTSF) which 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. TRMTC respectfully submits the following comments related to the Interim Storage Partners Consolidated Interim Storage Facility (CISF) Project draft Environmental Impact Statement (EIS), as noticed in the Federal Register on May 8, 2020 (85FR27447).

These comments on the EIS fall into two categories: (1) concerns with the NRCs outreach to tribes and (2) transportation considerations.

NRCs outreach to tribes to determine potential environmental impacts to tribal lands, people and resources was too narrow. The NRC consulted with a limited number of tribes to determine potential impacts, and outreach efforts focused solely on assessing construction-related impacts.

Transportation may potentially impact tribal people, lands, and resources along or adjacent to a route to the proposed facility. Potential transportation impacts from shipments of spent nuclear fuel through tribal lands were not evaluated in the EIS.

Furthermore, tribes not only have reservations or Trust lands but also have ceded

2 treaty lands reserved for hunting, fishing, and gathering rights or ancestral lands, that could potentially be impacted by shipments of spent nuclear fuel.

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 once a transportation route is submitted to the NRC for approval.

TRMTC appreciates the opportunity to comment on the draft EIS for the Interim Storage Partners CISF Project. The group is hopeful that NRC will consider the unique needs of tribes and the potential impact on all tribal lands 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