ML032830359
| ML032830359 | |
| Person / Time | |
|---|---|
| Site: | Robinson  (DPR-023) |
| Issue date: | 08/18/2003 |
| From: | Matthews M State of SC, Dept of Archives and History |
| To: | Kuo P Division of Regulatory Improvement Programs |
| References | |
| Download: ML032830359 (2) | |
Text
August 18, 2003 IA Gencratons Mr. Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555-0001 RE:
NB Robinson Steam Electric Plant, No. 2 License Renewal and National Historic Preservation Act Darington, Chesterfield Counties
DearMr. Kuo:
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r We have rivwed.tie =pozt =tRed-11VAs eRwt Marnw for the above'referenced project, which Wrevived July 17. Based on the information provided, we have sever concerns as to whether historic properties have been adequately documented. Therefore, we cannot concur with your determination that no historic properties will be affected by the relicensing process.
Section 106 of the National Historic Preservation Act requires the federal agency to determine the area of potential effects (APE) within which historic properties maybe affected. We do not agree with your delineation of the APE to include only 'the power plant site and its immediate environs.' We believe that an APE should be drawn to include the impoundment, which is used as a cooling pond for the nuclear power plant. The fluctuation in impoundment levels can have an effect on archaeological sites on the shoreline. There is precedent for establishing an APE to include the shoreline of the cooling pond as shown in the Giltural Resources Report for the Virgil Summer NRP Relincensing.
Once the APE has been established, usually in consultation with the State Historic Preservation Office, identification of historic properties within the APE should take place.
It appears as though the NRC has undertaken adequate background research at both our office and the South Carolina Institute of Archaeology and Anthropology. That background research showed archaeological sites near the APE, as well as previously identified historic sites: the WleyWanren Farmr the Old Camden Road, the Segars Farm Complex. It is also stated that thee possibilityfor intact archaeological evidence of historic use in the APE remains.' That state-ment Alone should take youto the next phase of surveyworkin oider to detenmine if any historic propertyactuallyexists within the APE. Yet there is no evidence that any current surveys were undertaken as part of this research.
S.C. Department of Archives & History
- 8301 Parklane Road
- Columbia
- 29223-4905
- 803-896-6100 4www.state.sc.us/scdah
Mr. Pao-Tsin Kuo RE: MB Robinson Relicensing, Darlington &Chesterfield Page 2 We also question the purpose of supplying comments from both our office and the Department of the Interior that are almost thirryyears old. A statement made in response to an "after-the-fact" environmental review from thirty years ago does not address issues that are known to be of concern now. Specifically, the review by the Department of the Interior, stated that although the project will not affect any sites cunently listed as a National Historic Landmark, or part of the NPS, it clearly points out that no 'interdisciplinary investigations of the development area by professionals was done,' and therefore previously unknown cukumal resources may have been lost since the plant was already constructed.
Our recommendations are as follows:
- 1. Expand the boundaries of the APE to include the shoreline of Lake Robinson.
- 2. Perform an advanced level of archaeological surveyto locate sires that maybe associated with the Wiley Warren Farm.
- 3. Evaluate potential effect to unidentified archaeological sites that maybe affected by drawing water from the cooling pond for the nuclear reactor.
Once these recommendations have been completed, we suggest you submit a revised report to our office for review and comment.
We are providing these comments to assist you with your responsibilities pursuant to Section 106 of the National Historic Preservation Act, as amended. If you have any questions, please contact me at (803) 896-6169. Thank you.
miceey Athews Review and Compliance Coordinator State Historic Preservation Office