ML18026A582

Responds to 800417 Ltr to DE Sells of NRC Re Archaeology at Facility Site.Pa Historical Commission Found That NRC 1979 DES,NUREG-0564,adequately Addressed Archaeological Concerns. Other Surveys Will Be Available for Review When Completed

ML18026A582
Person / Time
Site:	Susquehanna
Issue date:	05/20/1980
From:	Campbell R PENNSYLVANIA POWER & LIGHT CO.
To:	Solenberger R AFFILIATION NOT ASSIGNED
References
NUDOCS 8005290435
Download: ML18026A582 (7)

Text

REGULATOIOIMPORNATION DISTRIBUTION ITEN (RIDE)

CHOATE:

ACCESSION NBR:8005290435 DOC 80/05/20 NOTARIZED'O DOCKET FACIL:5 Susquehanna Steam Electric Statfoni Unit ii Pennsylva OS000387 "388 usquehanna Steam Electric Station< Unit 2E Pennsylva OS000388 A UT NAVALE AUTHOR AFFILIATION CAMPBELLER ~ K, Pennsylvania Power 8 Light Co, RECIP ~ NAME RECIPIENT AFFILIATION SOLENBERGERER, il Af f i ation Unknown I

SUBJECT:

Responds to 800417 tr to OE Sells of NRC t e archeology at 1

facility sfteBPA Hfsto.rical Commission found that NRC 1979 OESiNUREG 0564Eadequately addresses archeologfcal surveys will be available for review when completed, concerns'ther DISTRIBUTION CODE: COSTS COPIES RECEIVEDILTR TITLE: Correspondence Re J .ENCL J SIZE:

Archaeology/History Preserv/Hist Conse,

~O~ES: ~k RECIPIENT COPIES RECIP IEIVT COPIES ID CODE/NAME LTTR ENCL IO CODE/NAME LTTR ENCL ACTION: 05 Psf Pf(~C 1 1 07 LA lk/g43 1 1 20 BC LWC%g 1 1 AD l.h/p( 1 0 lNTERNAL: 0 EG FILE 1 1 02 NRC PDR 1 1 06 1 1 08 ISE 2 2 io ENVN SPEC BR 1 11 CST BNF T ANL 1 1 13 DIRECTOR DSE 1 1 AO ENVIV TECH 0 OELO 1 0 EXTERNAL: 03 LPDR 1 1 04 NSIC 1 1 14 NATL. LAB kVL- 6 6 21 ACRS 1 1 gAy 30 1980 TOTAL NUT'iRER OF COPIES REQUI RED ' TTR

?5 . ENCI gD

TWO NORTH NINTH STREET, ALLENTOWN, PA. 18101 PHONE: (215) 821-5151 R K. CAMPBELL 821-5947 May 20, 1980 Dr. Robert R. Solenberger Assoc. Prof. of Anthropology 50 Franklin Street Bloomsburg, PA 17815 SUSQUEHANNA SES AN ARCHEOLOGICAL REVIEN DOCKET NOS. 50-387 4 50-388 ER 100450 FILE 991-2

Dear Dr. Solenberger:

I would like to take this opportunity to respond to your April. 17, 1980 letter to her. Donald E. Sells of the U.S. Nuclear Regulatory Commission concerning archeology at PPl'TL's Pond Hill Reservoir Site and the Susquehanna Steam Electric Station. I realize that some of your concerns reflect not only upon PP5L policy but also upon policies of the Pennsylvania Historical Commission. We can't speak for the historical commission, however, t h eviewed the Sus<Suehanna site and associated electrical transmission lines in accordance with Section -106 of the National Historic Preservation Act (1966) and found that the U.S. NRC Draft Environmental Statement (NUREG-0564),, 1979 adequately addresses- your concerns, During construction activities, notify the Pennsylvania State Archeologist it if has been PPI}L's policy to any objects of possible archeological importance are unearthed. Ne have also stated this commitment in our Susquehanna Steam Electric Station Environmental Report (Amendments 4 and 5,'ec. 4. 2.3.3, Special Features (1976) .

PP5L, at this time, would like to respond to your comments on archeology associated with this project-to--reassure you that your concerns have been adequately addressed. bfr. Jerome S. Fields of the Environmental Management Department has been coordinating company archeological activities and has provided the attached responses to your various concerns. If you have any additional comments concerning archeology, please feel free to contact 5fr.

Fields at (215) 821-4655.

PPQL is committed to following the appropriate state and federal regulations in this and all other matters relating to our business. Mxen surveys at Pond Hill and the Susquehanna site are completed, copies of the 8005290

Dr. Solenberger May 20, 1980 Page 2 reports will be available for your review at, the Ousterhout Free Library, Wilkes-Barre, PA or from the U.S. Nuclear Regulatory'ommission. In the meantime, thanks for your comments.

Respectfully yours, r~Signed) R. K. CAMPBELL Robert K. Campbell cc: bh . B. J. Youngblood Chief, Licensing Projects Branch 1 Division of Project Management U.S. NRC Nashington, DC 20555 hfr. Singh Bajwa U.S. NRC Nashington, DC 20555 lh . Ira F. Smith, III Director - PA Historical 5 Museum Commission Nilliam Penn Memorial btuseum 5 Archives Bldg.,

Box 1026 Harrisburg, PA 17120 Dr. Barry C. Kent State Archeologist Nilliam Penn Memorial Museum g Archives Bldg.

Box 1026 Harrisburg, PA 17120

ARCHEOLOGICAL RESPONSES The following is a list of PPgL responses to various concerns and comments of Dr. R. R. Solenberger in his April 17, 1980 letter to Mr. Donald E.

Sells of the U.S. NRC.

Comment 1 U.S. NRC DES, Supplement, Appendix B, prepared by Curtis E. Larson, Commonwealth Associates, merely provided a preliminary "phase zero" plan containing no factual information.

Res onse 1 An initial archeological survey of Pond H'll is included in the Pond Hill Reservoir Environmental Report, Sec. 3.2.9; Archeological and Historic Sites, February 1979. The Appendix B your letter referred to was requested by the U.S. NRC. It is a plan for a more comprehensive survey to be conducted this spring. It is not, in itself, the archeological survey.

Comment 2 The Luzerne County Court House was mentioned on page B-3, for cultural resource information. However, neither the wyoming Historical and Geological Society nor the Frances Dorrance Chapter No. 11 of the Society for Pennsylvania Archeology were mentioned.

Res onse 2 In the past, PP4L has contacted the Nyoming Historical and Geological Society for cultural information. In the future, we will contact both this and the Society for Pennsylvania Archeology as appropriate to complete the archeological survey.

Comment 3 Commonwealth Associates based in Michigan, would have to start from scr'atch while the two local organizations have devoted years of research to the history and prehistory of the Susquehanna Valley. "If Mr. Larsen is to do either inventory or salvage archeology, qualified local archeologists should make up his paid staff, rather than exclusively outsiders."

Res onse 3 Even though Commonwealth Associates is located in Jackson, Michigan, a Gilbert/Commonwealth Co. whose main office is in Reading, PA. In 1976, it is Commonwealth Associates provided two environmental reports on transmission lines for the Susquehanna Steam Electric Station (SES). In addition, before PP5L could select a consultant to conduct an archeological survey, the U.S. NRC required the state archeologist's approval of a plan for the survey. PP/L selected Commonwealth Associates because of its archeological

experience and staff and its plan was approved by the state archeologist in October 1979.

Comment. 4 The Pond Hill survey, will, presumably be followed up by "Phase Three" excavation of any significant remains found within the "take area," dam site, etc.

Res onse 4 If any significant remains are found within the "take area," dam site, etc., they will be excavated in accordance with existing federal and state regulations.

Comment 5 "Unfortunately, I have been reliably informed that recent construction activities by PP5L on both sides of the river have been started in violation of Pennsylvania antiquities laws in force for over a decade, and such violations are still continuing at this writing. Steel towers for transmission lines have been erected on both sides of the river with excavations from which competent amateur archeologists saw important cultural, artifacts unearthed such as prehistoric pottery and, in one case at least, human bones from an Indian burial, with no attempt on the part of construction crews to salvage these materials.

Res onse 5 To the best of our knowledge, PPQL has not violated any federal or state antiquities laws. In fact, we are taking all reasonable steps necessary to protect buried cultural artifacts. As indicated in Amendments 4 and 5, 1976, PP5L policy requires that the state archeologist be contacted objects are unearthed during construction. The PP5L Construction if any Department is aware, of this policy, and many important artifacts have been sent to the William Penn Memorial Museum in Harrisburg, Pennsylvania.

Comment 6 "It was only after one of these amateurs made repeated approaches to the PP4L Co. headquarters in Allentown concerning disturbance of burials by tower construction across the river from Bell Bend that archeologists on the staff of the PA State Historical and Museum Commission were contacted, so that a salvage program paid for by PP/L was eventually set up in the summer of 1978. Why had PP5L failed to notify the State Museum before starting to dig for foundations? And why were the state archeologists so out of touch with PPQL's construction plans that they did not themselves previously initiate an intensive (at least Phase Two) survey that would surely have revealed these burials, in one of the richest known archeological areas in the Susquehanna Valley?"

Resoonse 6 From this comment, PP5L assumes you are referring to bfr. T. Knouse's notifying PPOL about an Indian burial site (Knouse Site 36 Lu 43) across the river (east side) from the Susquehanna SES in Ãapwallopen, Pa. This site was located near tower foundations for the 230 kV lines from the station to the 230 kV switchyard on the east side of the river. Once.

notified, PP5L stopped work in the vicinity of the structures and contracted the William Penn Memorial bfuseum to investigate the area and provide an archeological survey. The survey found that the structures were not located-in the burial areas. The state archeologist has followed the Susquehanna Project since the late 1960's and has been contacted by PP4L when there were questions or potential adverse construction impacts.

Moreover, the. area in the vicinity of the Susquehanna SES is not unique to the Susquehanna Valley. The floodplain areas mentioned have been disturbed over the centuries from flooding and erosion, farming, and from various local archeologists collecting artifacts.

Comment 7 "It has even been suggested that the PA State museum archeological staff sought to limit the extent of the 1978 excavation, not because no more valuable early historic material could be found, but to save money for PP4L, and that their current disinterest in requiring PP5L to do salvage archeology at the recreational area now under construction on the right bank of the river has the same purpose. If I misunderstand the present role of the State hfuseum archeologists, I should apologize. I am sending a copy of this letter, to Dr. Barry Kent in Harrisburg for his comments."

Res onse 7 The purpose of the 1978 archeological survey was to assure that Indian burial areas on the east side of the river would not be disturbed by construction of the 230 kV transmission line. The recreation area now under construction on the west side of the river near the Susquehanna SES it is felt does not impact on potential areas of buried cultural resources along the river. However, we will survey this area in 1980. As PP)L is sure you'e aware, present day archeological philosophy does not always salvage or unearth artifacts from the ground, but instead leaves them in areas such as the recreation area near the r'iver that will remain undisturbed. Suggestions that excavation was curtailed to save money si'mply makes no sense. PP5L spends millions of dollars annually for environmental programs and it is inconsistent to cut corners in order to save a few thousand dollars on archeological surveys.

A letter addressed to you from Mr. Ira F. Smith, III of the William Penn Memorial Museum on February 16, 1968, states that "evidence suggesting the presence of undisturbed cultural deposits is not nearly strong enough to warrant a salavage excavation" (Amendment No. 1, Applicant's Env. Report, October 1973). It must also be remembered that this area has been faxmed

for many years and has thus been disturbed. In addition, local amateur archeologists have-collected artifacts here as well as other locations up and down the Susquehanna River.

Comment 8 "It is my strong recommendation that the PP5L Co. now revert to its usual conservation-minded role, as exemplified so well at the Indian Steps Museum farther down the Susquehanna, and at the Montour Preserve (where I have also recommended further archeological reconnaissance and a museum presentation of Indian history), by (A) funding thorough archeological salvage excavation on all parts of the flat area between highway Ill and the river, and (B) installing a "trailside" archeological museum exhibit of the archeology of the Bell Bend and Council Cup region. If visitors are to be invited, archeological interest should be an added attraction.

Indirectly, visitors might come to feel that the vicinity of an atomic plant- is not too dangerous after all."

Res onse. 8 As indicated above, PP5L plans an archeological survey on the Susquehanna SES floodplain this year. PP5L is also considering presenting an archeological exhibit; possibly located at the Susquehanna Energy Information Center, once the surveys are completed.