ML21069A045

Comment (179) of Kevin Kamps on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Unit Nos. 1 and 2

ML21069A045
Person / Time
Site:	Point Beach
Issue date:	03/03/2021
From:	Kamps K Beyond Nuclear, Don't Waste Michigan
To:	Office of Administration
References
86FR7747 00179, NRC-2020-0277
Download: ML21069A045 (2)

Text

3/9/2021 blob:https://www.fdms.gov/8472f2b2-fa24-4373-abc5-1d18aa3ae2cc SUNI Review Complete Template=ADM-013 As of: 3/9/21 2:21 PM E-RIDS=ADM-03 Received: March 03, 2021 PUBLIC SUBMISSION ADD: Phyllis Clark, Bill Rogers, Kevin Folk, Status: Pending_Post Tracking No. klu-bldv-95u5 Stacey Imboden, Mary Comments Due: March 03, 2021 Neely Comment (179) Submission Type: Web Publication Date:2/1/2021 Citation: 86 FR 7747 Docket: NRC-2020-0277 Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Unit Nos. 1 and 2 Comment On: NRC-2020-0277-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, Units 1 and 2 Document: NRC-2020-0277-DRAFT-0184 Comment on FR Doc # 2021-02001 Submitter Information Email: kevin@beyondnuclear.org Organization: Beyond Nuclear and Don't Waste Michigan General Comment (Beyond Nuclear, public comment #11, Part 1)

Re: Attachment D: Cultural Resources Consultations, in Point Beach's ER.

Point Beach's outreach to Indigenous Nations, as an attempt to protect Indigenous cultural properties, is woefully inadequate. While a very basic form letter was sent to a single person at 52 different Indigenous Nations, it put the burden on them for further consultation.

The form letter states: "Also, as part of the subsequent license renewal process, NRC may request a consultation with your tribe in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended (Public Law 89-665; 54 U.S.C. 300101 et seq.), and implemented by the Advisory Council on Historic Preservation regulations (36 CFR 800)." (emphasis in original)

"...may request a consulation with your tribe..."?!

Many, to most, to all of those 52 named Indigenous Nations have treaties with the United States of America. Treaties are the highest law of the land, equal in stature to the U.S. Constitution itself.

Sovereign nation to sovereign nation consultation is what is demanded, by law, and by basic respect.

The form letter also states "The ER addresses the potential to impact historic and cultural resources including tribal cultural resources on or near the PBN site."

But historic and cultural Indigenous resources on or near the Point Beach Nuclear site are not the only relevant issues. What about treaty rights to hunting and gathering territory? What about fishing rights in Lake Michigan, as well as inland surface waters? What about Indigenous Nations' burial sites and other blob:https://www.fdms.gov/8472f2b2-fa24-4373-abc5-1d18aa3ae2cc 1/2

3/9/2021 blob:https://www.fdms.gov/8472f2b2-fa24-4373-abc5-1d18aa3ae2cc sacred sites that are undoubtedly in the area, which has been inhabited by Indigenous Nations since time immemorial?

The top paragraph on the second page of the basic form letter reads:

"During the subsequent license renewal term, NEPB proposes to continue operating the units as currently operated and based on aging management studies does not expect that refurbishment, construction, ground disturbing activities, or physical changes will be needed. Protection of known cultural resources on the PBN site is managed by the Archaeological, Cultural, & Historic Resources section of the PBN procedures manual. NEPB does not anticipate operation of PBN to adversely affect the environment or any cultural or historic resources." (emphasis in original)

But the Archaeological, Cultural, & Historic Resources section of the PBN procedures manual was not provided, not in hardcopy form, nor even link to it. Again, the burden in on the Indigenous Nations to track down such documents.

And what about protection of unknown cultural resources, very likely located on the PBN site, perhaps even the footprint of current physical plant facilities, or on supposedly undisturbed land?

Point Beach has stated that no adverse effects on the environment, or any cultural or historic resources, are anticipated, re: 80 years of operation of a severely embrittled nuclear power plant -- the worst in the country -- that has had one of the very worst Operational Experiences in the U.S. nuclear power industry (such as, in a short space of time, multiple NRC "red findings" -- the very worst safety violation designation -- more than the 100+ other reactors across the country, combined!).

Impacts to cultural or historic or pre-historic Indigenous Nations' properties and resources do not just occur through construction projects, such as the building of new parking lots, or dry cask storage pads for ever mounting quantities of high-level radioactive waste dry storage casks, however.

Nuclear power plants "routinely" release radioactivity, with permission from NRC. These "routine" radioactivity releases are not harmless, however. As the National Academy of Science has affirmed, over and over for decades, any exposure to ionizing radioactivity carries a health risk to humans, and those risks accumulate over a lifetime of exposures.

And it's not just humans who are harmed. Other plant and animal species are also harmed, as Dr. Timothy Mousseau's large number of wildlife biology studies from Chernobyl and Fukushima have so clearly shown.

Many traditional Indigenous Nations place tremendous value and regard on other species, in addition to human beings. "We are all related," or "All of our relations" is the English translation of a traditional Indigneous phrase across many Nations, expressed in many different languages, recognizing this, as in prayers, ceremonies, and even daily life, such as while hunting, fishing, and gathering.

There is no mention whatsoever in Point Beach's basic form letter to the 52 Indigenous Nations about radioactivity or radiation and its often very long lasting hazards, depending on the radioisotope released.

Again, the burden is placed on the lone individual written to by Point Beach at 52 Indigenous Nations, to do the research, to discover such impacts and their significance.

(To be continued) blob:https://www.fdms.gov/8472f2b2-fa24-4373-abc5-1d18aa3ae2cc 2/2