ML20329A439

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Pamunkey Consultation Request_North Anna Power Station_17NOV20
ML20329A439
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 11/17/2020
From: Clouthier T
Pamunkey Indian Tribe
To: Robert Elliott
Office of Nuclear Material Safety and Safeguards
References
Download: ML20329A439 (2)


Text

PAMUNKEY INDIAN TRIBE Terry Clouthier TRIBAL GOVERNMENT 1054 Pocahontas Trail Cultural Resource Director Tribal Office King William, VA 23086 (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

2 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, Terry Clouthier Digitally signed by Terry Clouthier Date: 2020.11.17 15:29:42

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