ML17275A429

Forwards Comments Re Adequacy of Site Archaeological Investigations & Bonneville Power Administration Survey & Testing Along Asche-Slatt Transmission Route

ML17275A429
Person / Time
Site:	Columbia
Issue date:	07/03/1980
From:	Gordon G INTERIOR, DEPT. OF
To:	Keblusek S, Sells D Office of Nuclear Reactor Regulation
References
W520, NUDOCS 8007160511
Download: ML17275A429 (8)

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NO DOCKET FACIL:50-397 NPPSS Nuclear.Projects Unit 2~ l0ashington Public Powe 05000397 AUTH BYNAME AUTHOR AFFILIATION GORDONEG ~ J ~

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~ of REC IP ~ NAME RECIPIENT AFFILIATION SELLSzDBEG Assistant Director for Environmental Technology KKBLUSKKES, Assistant Director for Environmental Technology

SUBJECT:

Forwards comments re adequacy of site archaeological investigations 8 Bonneville Power Adminsitration survey 8

testing along Asche Slatt transmission routes DISTRIBUTION CODE:

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h W520 United States Department ofthe Interior IIERITAGL'ONSERVATIONAND RECREATION SERVICE PACIFIC SOUTI.INVEST REGION SAN FRANCISCO, CALIFORNIA94 I 02 Interagency Archeological Services 450 Golden Gate Avenue, Box 36065 July 3, 1980 Donald E. Sells, Acting Chief Environmental Projects Branch 2

Division of Site Safety and Environmental Analysis Nuclear Regulatory Commission Washington, D.C. 20555 Atten: Suzanne Keblusek

Dear Mr. Sells:

We appreciate your request for our advice regarding the adequacy of the archeological investigations for the WPSS-2 nuclear power plant, Hanford Reservation, Washington.

We have reviewed pertinent sections of the Environmental Report on the WNP-2 operating license stage and related letter reports regarding the archeological survey of the WNP-2 acerage (1972) and the subsequent investigations at the WNP-2 pump house and water intake area (1975), all of which Ms. Keblusek forwarded to us.

We have also reviewed three documents prepared for the Bonneville Power Administration (Smith et al.

1977; Lindeman 1979; Stanfill and Eller 1979) on archeological survey and testing along the Asche-Slatt (previously AschePebble Springs) transmission route and BPA's files on their follow-up actions.

Ms.

Keblusek requested that we review compliance associated with the BPA line since NRC would ultimately be responsible for this project's effects.

Dr. Michael Berg, BPA senoir environmentalist, was extremely helpful in providing, us with all the pertinent material regarding BPA's archeological investigations along this transmission line.

Our comments and recommendations are enclosed.

We hope these prove useful.

Please call if we can be of further assistance (556-7741 FTS)

Garland J.

ordon, Chief Interagency Archeological Services San Francisco cc:

Jean Welch, Washington SHPO Mike Berg, Senior Environmentalist, BPA Dr. David Rice, Dept. of Anthropology, Univ. of Idaho Britt Storey, ACHP Denver

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COMMENTS We feel that your letter reports from Dr. David Rice (1972, 1975) do not provide full documentation of completed archeological field investigations in terms of todays standards.

The September 1972 letter falls shy of indicating the exact area that was investigated, the fashion in which this area was surveyed, and the location of the Burns and Roe test trench.

We also note that the WNP-2 ER (sec.

2.6) states that Dr. Rice was to determine the effects of transmission line relocation for WNP-2 but the 1972 letter report does not mention the survey of transmission lines.

The April 1975 letter fails to provide full description of archeological materials recovered in Dozer Cut C at the pump house site, or detailed rationale for why these materials are thought to be deflated.

Whether or not this deposit was deflated, the key issue is if the site contains information that is significant to the region's prehistory.

This point is not specifically addressed in the April 1975 letter.

We also feel that the 1977 ER may not fully address the scope of potential impacts to cultural resources.

We feel your EXS could specifically assess impacts to cultural resources within 1) the full project area included within the site exclusion radius of 1950 meters, defined in sec.

2.1.1.2 of the 1977 ER and 2) areas within the exclusion radius of any related waste disposal site.

More generally we feel your EIS should specifically assess potential impacts of further radioactive contamination of archeological materials within the immediate region of the Hanford Reservation, including the six National Register properties listed in the 1977 ER (sec. 2.6).

Dr.

David Rice has alerted us to what he believes to be the effects of radio-active contamination on the carbon fourteen dating of archeological materials downstream from the Hanford Reservation.

He reports obtaining modern radiocarbon dates from archeological sites he believes are in the neighborhood of 1000 to 2000 years old but have been contaminated by radioactive waters.

Exact radiocarbon dates are extremely important for determining the significance of archeological resources.

Dates may be obtained by alter-native methods, but radiocarbon dating is the most common one.

We feel the extent of contamination and the feasibility of alternative dating methods should be demonstrated in this region before no adverse effects can be determined according to the Advisory Council on Historic Preserva-tion regulations 36 CFR 800.

The three documents prepared for the BPA on the Asche-Slatt line (Smith et al.

1978; Lindeman 1979; Stanfill and Eller 1979) adequately address the major cultural resource problems encountered along the transmission route.

Exceptions to this rule existed regarding the survey of Sec.

24 and 25, T 10N, 26E (Tract 2),

a resurvey of portions of Glade Creek (Tract 4), and the possible testing or avoidance of 45-BN-235 and 236 (Tract 5) ~

Subsequently, archeological survey and testing, and relocation of the transmission corridor have rectified these situations to the Washington State Historic Preservation Office's satisfaction, as documented in BPA's project file.

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The major problem with the BPA project documentation appears to be a lack of adequate analysis and description of collected cultural materials.

In several places BPA reports imply that artifacts were collected dur1ng the field surveys.

If materials are collected that provide useful information on the specific nature of sites, then it is standard for the collected materials to be analyzed and described in a report.

In this instance we are particularly interested in the potential indent1fication of the large mammal bone mentioned in a BPA archeologist's project report, and in the specific nature of the lithic manufacturing debris found on the archeological sites.

RECOMMENDATIONS:

Our conclusions regarding the necessity for future work are as follows:

1) The EIS should indicate the exact area and nature of Dr. Rice's 1972 survey.

This survey should include the coverage of the entire project property boundary or else the survey should be supplemented with additional survey.

We suggest you contact Dr.

Rice and have him specify the exact areas he surveyed and in what fashion these areas were surveyed.

2)

A survey should be completed of all accessible, unmodified areas within the WNP-2 exclusion radius, and within the area defined by the exclusion radius of any proposed project waste disposal site.

3) The effects of completed pump house construct1on, and future activity in this area, on the archeological site found in Dozer Cut C should be determined by specifically evaluating its potential to contribute information regarding the prehistory of the Columbia River.

Dr. Rice reports to us that the materials in Dozer Cut C were extremely sparse and intermitent and will not provide 1mportant information regarding the prehistory of the region.

This should be specified in the EIS.

4) A study should be initiated to assess the potential effects of radiocarbon contamination from WPPSS-2, or other nuclear facilities, on the archeological dating of cultural resources in the immediate region of the Hanford Reservation.

5)

NRC should determine if cultural materials collected during the BPA transmission line investigations have been adequately analyzed and reported, and if necessary see that this work is eventually completed.

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