ML20325A060

Comment (13) of Terry Clouthier on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Virginia Electric and Power Company; North Anna Power Station, Unit Nos. 1 and 2

ML20325A060
Person / Time
Site:	North Anna
Issue date:	11/17/2020
From:	Clouthier T Pamunkey Indian Tribe - Cultural Resource Department
To:	Office of Administration
References
85FR69665 00013, NRC-2020-0234
Download: ML20325A060 (3)

Text

Page 1 of 1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 11/19/20 3:41 PM ADD: Tam Tran, Robert Elliott, Joseph Received: November 17, 2020 Status: Pending_Post PUBLIC SUBMISSION McManus, Antoinette Smith-Walker, Mary Neely Tracking No. khm-g36c-xew6 Comment (13) Comments Due: November 23, 2020 Publication Date:

11/3/2020 Submission Type: Web CITATION 85 FR 69665 Docket: NRC-2020-0234 Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Virginia Electric and Power Company; North Anna Power Station, Unit Nos. 1 and 2 Comment On: NRC-2020-0234-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; Virginia Electric and Power Company; North Anna Power Station, Unit Nos. 1 and 2 Document: NRC-2020-0234-DRAFT-0013 Comment on FR Doc # 2020-23463 Submitter Information Email: terry.clouthier@pamunkey.org Government Agency Type: Tribal Government Agency: Pamunkey Indian Tribe - Cultural Resource Department General Comment See attached file(s)

Attachments 2021-251 Nuclear Regulatory Commission Environmental Review of North Anna Power Station Unit Nos 1 and 2 in Louisa and Spotsylvania Counties Virginia https://www.fdms.gov/fdms/getcontent?objectId=0900006484964f26&format=xml&showorig=false 11/19/2020

PAMUNKEY INDIAN TRIBE Terry Clouthier TRIBAL GOVERNMENT 1054 Pocahontas Trail Cultural Resource Tribal Office King William, VA 23086 Director (804) 843-2109 FAX (866) 422-3387 THPO File Number: 2021-251 Date: 11/17/2020 Robert B. Elliott Chief U.S Nuclear Regulatory Commission Environmental Review License Renewal Branch Division of Rulemaking, Environment and Financial Support Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike Rockville, MD 20852 RE: Nuclear Regulatory Commission (NRC) Environmental Review of North Anna Power Station, Unit Nos. 1 and 2 Subsequent License Renewal Application, Louisa and Spotsylvania Counties, Virginia

Dear Mr. Elliot,

Thank you for contacting the Pamunkey Indian Tribe regarding the undertaking related to conducting a review of the environmental effects of renewing the operating licenses for North Anna Power Station, Unit Nos. 1 and 2 in Louisa and Spotsylvania Counties, Virginia. My office offers the following comments.

My office would like to remain a consulting party for this proposed undertaking.

The location of this power station is along the North Anna River which is one of the principal tributaries to the Pamunkey River and flows directly into it therefore we are very concerned with any potential environmental impacts from the renewal of the operating license.

From the consultation letter:

the current Unit 1operating license expires on April 1, 2038, and the Unit 2 operating license expires on August 21, 2040. The requested renewals would extend the operating license expiration dates for NAPS, Unit Nos. 1 and 2, to April 1, 2058 and August 21, 2060, respectively.

Why is the license renewal occurring so early for this undertaking considering that it is decades before they are due? Numerous environmental impacts could occur at those facilities in the

intervening twenty years before they are due that could potentially change the results of the proposed environmental impact statement. It is irresponsible of your agency to conduct a license renewal and review with literally half of the current operating license left to go through. This irresponsible behavior does not instill any faith in your agencies ability to conduct a National Environmental Policy Act (NEPA) review which will address potential cumulative effects from the current license as the current license is only halfway through its life cycle and therefore potential effects are not fully understood from the current license.

From your agencys website:

About NRC: The U.S. Nuclear Regulatory Commission (NRC) was created as an independent agency by Congress in 1974 to ensure the safe use of radioactive materials for beneficial civilian purposes while protecting people and the environment.

and NRC Mission: The NRC licenses and regulates the Nations civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.

Both the mission and the very creation of the NRC includes protecting the environment and my office fails to see how that can be achieved by conducting an environmental review so early in the life cycle of the current license as outlined above.

My office would like to consult further with your agency on this matter to address why the license renewal is being reviewed so early.

Additionally, my office would like to review any documents thus far created and any other documents created for this undertaking in the future.

Thank you for considering our cultural heritage in your decision-making process.

Please submit all correspondence via email whenever possible to the email below.

If you have any questions feel free to email me at terry.clouthier@pamunkey.org.

Sincerely, 2