ML20072A454

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Forwards Revised Draft Versions of, Cultural Resources Mgt Plan for Residual Lands & Phase 1 Cultural Resources Survey & Assessment to Residual Lands & Responses to SHPO Comments
ML20072A454
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/03/1983
From: Schnell D
UNION ELECTRIC CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20072A456 List:
References
RTR-NUREG-0813, RTR-NUREG-813 ULNRC-634, NUDOCS 8306100147
Download: ML20072A454 (44)
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{{#Wiki_filter:. -- o UNION ELECTRIC COM PANY 1901 GRATIOT STREET ST. Louis, MISSOURI DON ALO F. SCHNELL O BOX 949 ST. LOUIS, MissOU RI 63166 vece esegosognet June 3, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ULNRC-634 Washington, D.C. 20555

Dear Mr. Denton:

DOCKET NUMBER 50-483 CALLAWAY PLANT CULTURAL RESOURCES Ref: 1. NRC letter dated December 24, 1980, from B. J. Youngblood 2. Section 5.7, Final Environmental State-ment NUREG 0813, dated January 1982. The above references requested additional information concerning cultural resources at the Callaway Plant site. On November 8, 1982 final draft reports, "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Callaway Nuclear Power Plant, Callaway County, Missouri" and "A Phase I Cultural Resource Survey and Assessment on Residual Lands at Union Electric Company's Nuclear Power Plant, Callaway County, Missouri", were submitted for comment to the Missouri Division of Parks and Historic Preservation and the Nuclear Regulatory Commission. Transmitted herewith are revised final draft reports and responses to the SHPO's comments. A review of the attached reports clearly documents our effort to identify cultural resources, evaluate these resources for potential significance against National Register eligibility criteria and then design a management plan which appropriately protects identified resources. It should be noted that the survey was conducted on all project property, not just the area of potential environmental impact related to the operation and maintenance of the plant and associated facilities. The management plan provides long-term protection to potentially significant sites as well as sites believed to be insignificant by either avoiding the site or imposing land-use restrictions on 8306100147 830603 A "[ O PDR ADOCK 05000483 C A PDR g } A it. Phase II testing of sites considered potentially eligible for the National Register of Historic Places and subsequent nomination of the sites to the National Register will be postponed until a site is threatened by impact. Sincerely, 'u O Do ald F. Schnell Vice ident l Nuclear DJW/mc Enc. i i

O STATE OF MISSOURI ) ) SS CITY OF ST. LOUIS ) Robert J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief. By Rob C JT ukai Gen al M ager-Engineering Nuclea SUBSCRIBED and sworn to before me this 3rd day of June, 1983 h -b BAR8AYJ. PFAN #s NOTARY PUBLIC. STATE OF MISSOURI MY COMM!SSION EXPIRES APRIL 22,1985 ST. LOUIS COUNTY. s

cc: Glenn L. Koester Vice President Operations Kansas Gas & Electric P.O. Box 208 Wichita, Kansas 67201 Donald T. McPhee Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnoff, Esq. Shaw, Pittman, Potts & Trowbridge 1800 M.

Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S. Nuclear Regulatory Commission RR$1 Steedman, Missouri 65077 l l l ~

p___-- k se O UNION ELECTRIC COMPANY 89 08 G RATIOT STR ECT - ST. Lou tS M AILING ADDRESS: May 16,1983 or. To ;."., *o..L.. Mr. Michael S. Weichman Chief, Re; view and Compliance M0. Dept. of Natural Resources Division of Parks and Historic Preservation P.O. Box 176 Jefferson City, Missouri 65101 RE: Final Draft Reports, Cultural Resources Survey and Management Plan, Union Electric Company's Callaway Nuclear Power Plant, Callaway County, Missouri.

Dear Mr. Weichman:

Please find enclosed our response to your December 30, 1982 comments on the referenced reports. Your comment 1 was a request for a survey project summary form and a map please see enclosure 1). Your comments 2,3,4,8,9,14,16(,18,19,21,22,39,51 and 56 have been addressed by directly incorporating our response into the text of the reports. Our response to the balance of your comments may be found in enclosure 2. Also enclosed are five copies of the revised reports. We feel that the survey and resultant cultural resource report and management plan more than adequately satisfies the requirements of the Missouri Historic Preservation Program, The National Historic Preservation L Act and has adequately addressed National Register eligi-bility. Additionally, you will find that the management plan represents a very conservative approach to cultural resource management by offering an appropriate degree of protection to archaeological sites even though they may be judged insignificant and are located outside defined plant operation and maintenance areas. Please note, however, that we do not agree with your interpretation of the historic architecrural significance of the structures on the property (see page 17 of enclosure 2). In fact, we believe that the majority of these historically insignificant properties represent a threat to public safety and it is our intention to raze them in the future. [

r-2- In the near future I will be contacting you to verify the number of copies of the final r eports you' need for your file. All artifacts will be deposited with the State as soon as conveniently possible. -If you have any questions please contact me.l Sincerely, j David J. Wa old Supervising Biologist Environmental Services DJW/mtn Enc. oth-N) Mis rta h6 cc: Dr. Louis Bykoski %dd an Fred A. Lafser b ti .r Du John Karel I 4 4 bec: D. F. Schnell D.W. Capone } A.C. Passwater kys o'f *@d { ' N.G. Slaten / w Lk & w o J.D. Smith l G.L. Horton M.F. Barnes TES/EMR/1-2t5-2-4 Mike McNerney e o e 1 e a e

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  • CULTURAL RESOURCE SURVEY PROJECT

SUMMARY

SHEET Missouri Department of Natural Resources Historic Preservation Program A Phase I Cultural Resources Survey and Assessment on Residual Lands at Union ReportTitle: Electric Company's Callaway Nuclear Power Plant, Callaway County, Missouri Counties: Callawav Author (s){ Jack H. Ray, Edward M. Morin, Michael Nt M P' kJ.McNerney,R.GailWhite Institutional Affiliationof Author (s): a Federal Ager.cyinvolved/ Client: Nuclear Regulatory Commission / Union Electric Company - Dataof Report: Aoril 1983 Date of Field invest.: August 26-December 16, 1981 Legal Description of Survey Area / Unit: Sec 1, 2, 3, 10, 11, 12. 13. 14. 15. 23. 24. 25. 26. 35. 36. T46N, R8W; Sec 6, 7, 18, T46N, R7W Total Acres Surveyed: 5,848 Historic Preservation Program Drainage: Missouri River 2 /0% 600-dbdi 404 buU-Elevation of Survey Area / Unit: Max. 858 msl Min. _5_0_Lms! Avg. 775 mst 700; 1% 500-600 Flat to gently rolling glaciated prairie in north, heavily dissected upland with Terrain: til e Vegetation:_IAll arass orairie/ oak-hickorv forestD(($1gges ajg g,,t og,g f visibility (as % of survey area / unit): 13% 50-100h 87% 0-50%%, River alona the southern boundary Type: 36% forested, 28% cultivated, 36% pasture Nature of Soil (as % of survey area / unit): Aeolian 72 % Colluvial 18 % Alluvial 6 % Other 4 %g al Raw Lithic Material Available: TypeChert (maior): Burlinaton/ Source in situ / stream depositedf Jefferson City residual / glacial Legallocation: too numerous Nearest Permanent Water Source: Spring Stream River X Lake Other Distance 2.3 kilometers Name Missouri River Closest Tributary: Distance within survey area Name locan Creek Order 3 or 4 s Number of Sites in Survey Area / Unit: Prev. Recorded _.2._. Prehistoric Rec. by Pres. Invest. 77 Prehistoric Historic Archaeo. _.29 Historic Archaeo. Historic Historic Architectural 21 Architectural None None Type of Investigations (Mark all applicable): _X Uterature Search Testing (Phase ll) Reconnaissance Survey Excavation (mitigation) X Intensive Survey All resources Research only Intensive Survey - Archaeological only Other Fieldwork Intensive Survey - Architec.-Historic only Other Ust all sites located within survey area / unit or discussed in report (attach continuation sheet if necessary). See attached

~ * ~ Typesof Site (s) Base camps, field camps, limited activity sites, and mounds Range of Cultural Affi'iation(s) of Site (s) Paleo-Indian / Mississippian Direct impact (s) to Site (s): Total Destruction. Disruption Partial Destruction X No impact Natureof Directimpact(s) Unknown at this time Nature of indirect /Long-Range lmpact io Site (s): Sionificant sites will be orotected (see reference to Manacement Plan) Significance (Mark all applicable): x High (National or regiona!'research applicable) (25 sites) ~ Moderate (Local or state research applicable) Low 1. Disturbed 2. Lacks context 3. Redundant data 4. Future utility uncertain insufficient Information Future Work Recommendations (Mark all applicable): Nominate to Register (after testing) No further work needed X Preserve / avoid Restrict access _ X. Test ~(if impacted) Other Excavate Monitor construction s (must justify by high potential of buried sites) ~ Comments: S:e: A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Callaway Nuclear Power Plant, Callaway County, Missouri. Michael J. McNerney, American Resources Group, Ltd., Carbondale, Illinois. A U.S.G.S. 7.5 min. topographic map indicating all areas actually surveyed and locations of all sites must be attached. Return to Michael Weichman, Chief, Review & Compliance H;storic Preservation Program, Missouri Department of Natural Resources, P.O. Box 176, Jefferson City, Missouri 65102.

e Continuation Sheet A Phase I Cultural Resources Survey and Assessment on Residual Lands at Union Electric Company's Callaway Nuclear Power Plant, Callaway County, Missouri List all sites located with survey area / unit or discussed in report. '23CY20, -74, -242, -251, -252, -253,,254 -255, -256, -257, -258, -259, -260, -261, -262, -263, -264, -265, -266, -267, -268, -269, -270, -271, -272, -273, -274, -275, -276, -277, -278, -279, -280, -281, -282, -283, -284, -285, -286, -290, -291, -292, -293, -294, -295, -296. -297, -298, -299, -300, -301, -302, -303, -304, -305, -306, -307, -308, -309, -310, -311 -312, -313, -314, -315, -316, -317, -318, -319, -320, -321, -322, -323, -324, -325, -326, -327, -328, -329, -330, -331, -332, -333, -334, -335,~-336, -337, -338, -339, -340, -341, -342, -343, -344, -345, -346, -347, -348, -349, -350, -351, -352, -353, -354, -355, -356, and -359 Architectural sites are numbered 1 through 21. O e

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.u ..,m m. 0 - .,e ? April 1983 Responses to M0HP Review A Phase I Cultural Resources Survey and Assessment on Residual Lands at Union Electric Company's j Callaway Nuclear Power Plant, Callaway County, Missouri 5. Site descriptions are difficult to follow as presently organized. Sequential numbering would be far superior for locating a specific site description. Discussions of impacts to sites and recommenda-tions are necessary and should also be included for each individual site. Alternative organizational fomats were considered. A fomat arranged by environmental zones was selected since the focus of-the study was the relationship between environmental zones and site loca-tions. A sequential numbering of sites cross referenced to environmental zones will be added (see Comment #38). 6. Site descriptions should mention, at least in the broad category (upland, prairie, etc.) what other resources might be available, i.e., subsistence resources, lithic resources, etc. It is suggested that an estimate be made at the nature of the activity (ies)l conducted. For example, scrapers, according to angle and wear, indicate hide working vs. woodworking. The environmental setting for each site is presented in Tab,le 5, pp. 186-199. The site descriptions are grouped according to the broad environmental zone they occupy (pp. 201,'225,etc.). T'he natural and lithic resources available in the project area are well described (pp. 4-30). To repeat these available resources for every site would be redundant, e.g., to repeat 79 times that useable chert was available in the nearby ravines and streams would contribute nothing to the report. Functional tool studies are specialized and highly technical, requiring large samples of similar types of tools. The small quantity of artifactual material recovered in the survey is not suitable for such studies. To estimate site activities frcm the examination of a handful of utilized flakes would contribute 'nothing to this study. 1 e --v-w-- e -. . M

s' g a Responses to MOHP Review April 1983 7. Pages 186-199. As knapping and sharpening were continual and frequent pursuits of prehistoric populations, one could just = well describe any sites as a knapping station. Yes, one could. These designations are a function of three factors: the abundant amounts of chert resources available throughout the research area, waste flakes are the most commonly occurring artifacts. on most pre-historic archaeological sites, and many of the sites recorded produced only waste flakes.

10. P$ge16,3rdparagraph.

It is questioned that this is a Winterset fonnation chert (see comment 40). The chert is visually similar to Winterset, and the reference on p.16 indicates that it is a tentative identification. Since the sub-mittal of the draft report, the formation has been identified as Excello, and changes will be made throughout the report. 11. Page 28-30. Caution should be employed in utilizing environmental data from southwestern and southeastern Missouri in order to attempt to use environmental regimes in central Missouri at the end of the Prairie Peninsula. While much of this may be applicable to northern Missouri, it should be pointed out that the project area is not even. in the same environmental area. We are aware of the nature of these data, and they.are used only as a general background framework. There is no statement in the report that identifies this sequence of paleoclimatic events solely with the study area. Rather, this discussion addresses a broader area "during the past 12,000 years in mid-continental North merica" (p. 28).

12. Page 31.

It should be noted that although there is evidence of man in the New World as early as 22,000 P.B., there is no conclusive evidence of Early Man in Missouri. We find no reference to Early Man on this page or elsewhere in the report. The Paleo-Indian period is referenced on page 31. s 2

w. ~ ,4 Responses to M0HP Review April 1983

13. Page 31, 1st paragraph.

The report fails to reference the recent work at Arnold Research Cave which was conducted by the University of Missouri-Columbia (0'Brien et al.), as well as the recent Moreau River surveys (Sturdevant) and Columbia investigations (Schmits). As this project area is in close proximity, more detail should have been taken from these recent investigations. There is no report or published work ("0'Brien et al.") on the results of the 1981 field work at Arnold Research Cave by the University of Missouri-Columbia (telecommunication, Dr. Michael O'Brien, March 4, 1983). The supervising archaeologist of this project (Callaway County) was a member of the field party a't Arnold Research Cave, and the receit infomation which we thought useful to this study is cited as Ray 1981c 'n the references cited. Work in Boone County (Schmits and Wright 1981, i Wright 1981) and Cole County (Sturdevant 1978) is cited in other parts of the report and included in the references. 15. Page 35. 23GA142 (Hemann Site) is not Early Archaic. The single radiocarbon date is Middle Archaic. " Cultural deposits at the Hemann Site span the Holocene from ca. 10,000 B.P. until historic times. Occupation appears to have teen inteese during the early Holocerie; and on the basis of a limited number of projec-tile points, includes brief Paleo-Indian, Dalton and Early Archaic com-ponents" (Schmits 1982:193).

17. Page 38. Teter & Warren (1979) have conflicting information.

Table 8.1, page 234 of Teter & Warren, does not substantiate the dates presented on pages 247-248. The dates of 2100 100 B.P. from the Middle Woodland level were rejected (Teter & Warren 1979:235) and there are no dates anywhere in the text suggestive of an Early Woodland occupation. In addition, Klippel's (1972) Collins Site is a poor example of Early Woodland. O'Brien (1979:63) as well as others believe that the site is multi-component Archaic / Woodland. Most of the features were intersected at the base of the plowzone, and it cannot be detemined what the levels of pit origins were. While the' cited dates are generally accepted as Early Woodland, the dates for Early Woodland have not been finnly established in Missouri. Without pottery, calling it Early Woodiand is questionable as the basis 3 i

U g ,L Responses to M0HP Review April 1983 of defining any Woodland component is the presence of Woodland pottery. Also, there is no basis for equating contracting stemmed projectile points with Early Woodland in Missouri. We are aware that the temporal and cultural dimensions of the terminal Late Archaic-Early Woodland are poorly understood in Missouri and will qualify the comments on page 38 accordingly. Small quantities of slightly contracting and contracting stemed projectile points were recovered at the Collins Site (Klippel 1972:56). Although this site contains other cultural components, these tools probably represent the Early Woodland component. Other investigators working cast of the Callaway plant site believe that contracting stemed projectile points relate to the Early Woodland period (Haas 1978:165, Kling and Martin 1979:38).

20. 'Page 133, 3rd paragraph. When the authors refer to an area "...

sufficient to determine the number of cultural resources present," what factors did they use to determine sufficiency of areas surveyed? Also does the management plan take into consideration cultural resources which are presently unidentified, buried or otherwise currently unknown sites within the project area? Shovel test / transect intervals and related field methods are dis-cussed on pp. 161-163. Careful reading of this section will give the reader a good idea of the sufficiency of the survey. The possibility of deeply buried occupations and unknown sites are addressed in the ' revised management plan, comments 8 and 9, page 43.

23. Page 135, 1st paragraph.

Technology and settlement patterns have a direct bearing on such " inappropriate" topics as social organization and subsistence. We are aware of these relations; the reviewer's comment is taken out of context. See below: "From this brief overview, it is clear that there is a direct rela-tionship between the types of research problems that can be investigated 4

g, s Responses to M0HP Review April 1983 and the nature, intensity, and duration of any given research project. Research questions which are appropriate to a Phase I archaeological survey relying primarily on shovel testing as a means of data recovery are addressed. Questions relating to human biology, ideology, social organization, and subsistence are not appropriate, since hypotheses relating to these areas are not testable or. only marginally testable in a Phase I effort. However, research questions relating to technology and settlement patterns in relation to the natural environment can be addressed in a Phase I' survey. The research design and problem orienta-tion for this study will pose questions relating to two of mankind's important strategies: technology and settlement location." The following change will be made to clarify this section: questions relating to topics requiring large amounts of data, e.g., human biology and ideology.... The appropriateness or inappropriateness has to do with the kinds of questions that might be asked and answered in this type of survey. 24. P. 136-137, last paragraph. Please provide an indepth explanation of why the authors assume that primarily only a general huntingsand gathering fonn of subsistence was prevalent for the prehistoric inhabitants within the project area. Although a variety of site types may be expected due to a wide variety of floral and faunal types present in the area, the physical aspects of its topography make the area more conducive *for exploitation by mobile hunter / gatherer groups or temporary specialized task groups from more sedentary groups outside the research area. Much of the area consists of a rolling typography, restricting its potential use for sedentary horticulturalists. The lack of an extensive arable floodplain S t

~ .t, R:sponses to M0HP Review April 1983 within the immediate area would suggest that horticultural groups, if they were in the general area, would have emphasized exploitation'of game, wild plant resources, and, perhaps,. chert. Further, since the , prehistoric aboriginal inhabitants of the area remained hunter / gatherers until the Woodland period and still pursued these activities through post-contact times, it is expected that hunter / gatherer sites will be the most frequently occurring site types. 1

25. Page 140,1st paragraph. Were the isolated finds also mapped in detail and reported to the Archaeological Survey of Missouri?

See p. 185, Map 16; yes, they were reported.

26. Page 140.

In respect to the definition of " site", how large or small of a circumscribed area is intended to be included? Also, the definition of site types is too vague; the authors should cite source (s) or definitions, if appropriate. l A site is two or more flakes; the size is highly variable and is based in large part on the judgment of the supervising archaeolbgist (see the site survey forms for more details). Site types are after Binford .(1980) as indicated on p. 140.

27. Page 140, 3rd paragraph. As organics can be quick 1y leached from the soil and usually are preserved readily only when quickly buried, the presence of organics to define habitation sites should be used cautiously.

Yes, we are aware of this possibility. Again, the comment is taken out of context. Other factors include subsurface features, artifact I diversity and density, site size, etc. I

28. Pcge 142, 3rd paragraph, line 9.

What is the basis for this tentative l scaling? Some basis for this is required other than species discus-sions. A limited number of species with high volume may yield higher biomass. Some form of index would be better than this (e.g. quantity by environmental areas).

42. Page 352. Again, as there is no firm basis for ranking environmental areas, this test is nearly meaninglets.

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2 R:sponses to M0HP Review April 1983 o While the comment regarding the rationale for environmental ranking of food potential of microenvironments (Comment #28) is a valid point, it must be remembered that this ranking is stated as a hypothesized (or expected) rank ordering (pp. 142,352) in consideration of environmental j data reviewed snd source material cited (pp. 21-27,142). As to the coment that "this test is nearly meaningless" (Comment #42), such a comment is without substance. It is suggested that the reviewer read material on experimental research design which may be found in any intro-ductory statistics text (e.g., Roscoe 1975':170-178,187-209). t

29. Page 145. What was the rationale for limiting the hypothesis pre-sented to hunter-gatherer subsistence / procurement strategies only?

Hypotheses of ecological strategies for horticultural groups would require different data sets, such as evidence of past horticultural prac-tices and remains of cultigens, in the research area. Such data have not been shown to exist; therefore, such hypotheses would be inappropriate. 30. Page 145-146. Hypothesis 1 cannot be tested until some index for scaling potential resources is accomplished. Simply to say that you assume resource areas have one order may have no basis in reality. Also site location is a result of a matrix of choices by aboriginal populations. One factor by itself may not have a major effect on choice of site location. This hypothesis is simply not testable until more detailed work is. done. (Comments 30, 31, 32, 33, pp. 145-146) The hypotheses as stated are statistically testable hypotheses.. Again, it must be remembered that hypothesized distributions against which actual data are tested ) are hypothesized distributions. 34. Pages 145-147. The hypotheses presented are inappropriate, broadly generalized,,and fail to address a single valid research question fonnulated by other intensive investigations in central Missouri, e.g. Schmits, O'Brien eti.al. etc. Suggestions that thp application of research questions derived from 7

.v ,e Responses to M0HP Review Apr.il 1983 a previous. study to be applied to this study in a different area possesses two major shortcomings. Such a_ priori assumptions that only these types of research questions are " valid" indicates "no consideration of the data needed to address the questions and no evaluation of the likelihood that the site contains this infonnation" (Rondeau 1981:34). 35. Page 161. A topographic map of the project area indicating percentage of vegetation / visibility and areas actually surveyed with approximate locations of shovel tests should be included. $eep.184forthesepercentagesandthetransectinterval. The entire project area was surveyed using the techniques described in the methods section (pp. 161-163) and adequately documented in field notebooks. Field notebooks showing shovel test locations are on file at Union Electric Company. A small-scale map of 5,848 acres with small dots indicating approximate shovel test locations would not add to the study. Map ? In the management plan shows general land use/ vegetation patterns.

36. Page 163, 1st paragraph.

Detailed sketch maps of all sites located during this i.nvestigation should be included within the main text or in an appendix. The M0HP has been provided with USGS maps of the project area showing

  • all site locations, along with an ASM site fonn for each site. These maps and fonns, with photographs of every site (on file at Union Electric Company),

provide adequa'te site documentation.

37. Page 175-183. The detail of discussions presented in the " Chert Resources Survey Section" is considered.to be too extensive for t

f this level of investigation. It would be more appropriate as an appendix. l The Chert Resources Survey section is central to the entire study. 6 Hypotheses 3 and 4 relate to chert resources and exploitation, and waste l flakes constitute the major class of prehistoric artifacts reccvered (4,350 l waste flakes vs.18 cultu' rally diagnostic stone tools were collected). 8 'm&

e Responses to M0HP Review April 1983 Therefore,-the eight-page Chert Resources Survey section is consistent with the types and quantities of data recovered, the research questions which were asked, and is not too extensive. The section will remain in its present location. 38. Page 201. Discussion of sites in survey area are listed by environ-mental zones rather than sequentially. This is confusing when trying to locate a specific site. Furthermore, we have some serious reser-vations about the zone referred to as " Dissected Upland /Bottomland Forest Edge." This term appears to consist of a combination of two and possibly three vegetational communities, which probably consists t of slope forest, floodplain forest and edge communities. A sequential listing of sites cross referenced by environmental zones will' be provided with Table 5, p. 186. The Dissected Upland /Bottomland Forest Edge is a heuristic device based on environmental, topographic, and cultural considerations, as well as artificial limits imposed by the project boundaries. It is true that the two zones mentioned above are contained within this zone. It should be noted (Map 16, p. 185) that from j a cultural / environmental perspective it would offer a diverse number of exploitable resources within a very confined space. From an ecological l perspective, the construct.could be extensively debated (in fact, the l utility of the ecotone concept is currently under reconsideration in the ecological disciplines). We feel the zone serves the needs of this study. l 40. Page 282 and 357. Winterset limestone is a member of the Kansas City group which is known to outcrop in western and northwestern Missouri. It is questioned that Winterset chert outcrops 18 km north of the Callaway project area. If it does, this would be an anomaly worth l discussing in more detail. It is also interesting to note that on page 357, the source for Winterset chert has migrated 8 km to the south, i.e. only 10 km from the project area. l See Comment #10. There are two sources: one to the north and one 1 F to the south. l i l 9 s l I i

,o Responses to M0HP Review April 1983

41. Page 297, Plate 13c.

This is not Graham Cave Notched. Itmaynotbeaclassic,butsomeworkersinMissourihavethped theseas"GrahamCave"(Schmits 1982:76-77). Thespecimen(13c)is within the stylistic range of both Graham Cave and Big Sandy points (plates 9a,12a). We will note this range of variation.

43. Page 352. Environmental zones were ranked in decreasing order of food importance.

What is the basis for this ranking? We question that a prairie forest edge zone would have more resources than upland oak hickory forest. The possible incorrect ordering of these zones may account for the lack of significant correlation between food resource potential and site density. Again, this comment addresses a valid point originally raised in comments #28and#42(seepp.6-7). We must again remind the reviewer that the distribution is hypothesized. The reviewer's assertion that a reordering of the zones may account for the lack of a significant correla-tion is well taken; the reordering suggested would result in T = 1.0. However, other reasons, e.g., sample size, construct validity, also may be applicable and are discussed as possibilities on pp. 352-355. To reorder the hypothesized distribution of zones, simply for the sake of obtaining a significant correlation, violates principles of statistical hypothesis testing.

44..Page 355, paragraph 3.

We question the use of the tenn " social complexity". A large number of different site types does not necessarily equate with social complexity. Hunters and gatherers usually will have a greater number of site types than will more " complex" social organizations. We are aware that assumptions, hypotheses, and inferences about the archaeological record are open to question. The discussion on p. 355 deals with an inference based on both the archaeological. record and the site types defined in the research design. It would be well to consider 10 = ,,rw y a t

s Responses to M0HP Review April 1983 the concept within the sentence in which it occurred. "The other zones only produced two types of sites each (field camps and limited activity loci) and therefore expressed roughly equivalent degrees of social com-plexity." 45. Page 355. Hypothesis 2 - This is not a test but is simply intentive observation. As indicated in the first paragraph of the discussion of this hypothesis, "Because of the probica of tied ranks in a small sample size of environments (N=4), this question could not be assessed statis-tically" (p. 355). The sentence order of th'e paragraph will be changed to make this point more explicit. As with other hypotheses considered, a discussion of alternatives (pp. 355-357) follows the discussion of test results. 46. Page 356. Use of the terms " field camp" and " limited activity sites" should be explicitly defined. The phrases " field camp" and " limited activity sites," as well as other site types, are defined on pp. 140-141. 47. Page 357. ' Hypothesis 3 - Same as comment hypothesis 2. (No.45). The differences in quantities of local vs. nonlocal chert types are so obvious that to perfonn a statistical test would be inappropriate. l The rational for not applying a ttst may be found in Thomas (1976:468) in regard to his discussion of Berkson's Interocular Traumatic Test. Perhaps even more germaine is a quotation attributed to A. Whitehead I (citedinThomas 1976:468): "It requires a very unusual mind to make l l an analysis of the obvious."

48. Page 357..What is the basis for identification of Winterset chert in 1

Audrain and Monroe Counties? See Comment #10. 11 + e

,c-Responses to M0HP Review April 1983

49. Page 389, line 1.

This is not a Graham Cave Notched point. See Comment #41. 50. Page 391, paragraph 2. Grantham (1977:179) says nothing about blending of Late Archaic and Early Woodland. True, Grantham did not use the word " blending." However, it would seem to be a reasonabic word choice for summarizing what Grantham said: 1 "While it appears probable that there is at least a minimal Early Woodland occupation in the area, there is as yet no way to separate it from earlier or later material." 52. Page 401. Is this project designed to inventory and eval'uate or to inventory and make recommendations for evaluation of potentially National Register eligible resources? There appears to be a lack of attention paid to proper CRM teminology or scope of work. The project is designed to inventory, evaluate, and identify sites potentially eligible for the National Register of Historic Places within the context of a Phase I survey and to prepare an appropriate management plan. Any further evaluation or assessment should be determined from the results of this Phase I study (see Scope of Work).

53. 'Page 417-418. These criteria are heavily weighted toward large, dense sites.

It is seriously doubted that this ha:; any basis in terms of potential research applicability. This is an arbitrary choice of criteria. Without reference to any specific research . design which can successfully exclude certain site, after they have been adequa'tely evaluated, these criteria are meaningless. Statements of significance are based upon professional judgment. Judgments are credible only when clearly and objectively documented (Wendorf1978:2). As other cultural resources managers have noted, the National Register criteria provide no help in clearly and objectively documenting statements of significance. For example: 12 ~

Responses to M0HP Review April 1983 The former Director, Office of Review and Compliance, ACHP,'said, "this language [ National Register criteria] invites the interpretation that all archaeological sites are eligible for listing on the National Register of Historic Places." An Environmental ' Affairs Specialist, Office of Environ-ment and Safety, Department of Transportation, said, "the National Register criteria needs overhauling. In fact, the believability of the National Register is being seriously hampered by quality of sites, both historical and archeo-logical, that are entered into the Register." The President, Society for American Archeology, said, " Inasmuch as any site, no matter how miserabic, is guaranteed to produce some information on the nation's past, we find ourselves with a system that tends to assign the same level of significance to all sites" (Comptroller General 1981:25). The eight working criteria discussed on pp. 417-418 are supplemental to the National Register criteria. Specifically, the eight criteria are linked directly to the National Register criteria which' relate to archae-ological sites: "(d) that have yielded, or may be likely to yield,.infoma-tion important in prehistory or history" (Federal Register 1976:1595). These provide the field investigator and the reviewer with specific guidelines with which to evaluate archaeological resources, justify recommendations of additional research or ho further research, and to make statements of significance and recommendations of potential National Register eligibility. The outlining of our "eight working criteria" represents the explicit-articulation of judgmental criteria which most archaeologists fail to present in written fom. It is incumbent upon the archaeological com-munity to develop and articulate specific and workable criteria within the context of National Register of Historic Places guidelines in such a manner that National Register of Historic Places goals and professional 4 commitments are met'. 13 s ['

a Responses to IFJHP Review April 1983 Further, as cultural resources managers who have fiscal and scientific responsibilities both to the client and the general public, we believe that site evaluations, statements of significance, and related issues based upon such broad and vague " criteria" regarding cultural resources "that have yielded, or may be likely to yield, infonnation important in prehistory of history" promote poor science, bad business practices, and lead to wasteful cultural resources manage-ment practices in both the private and public sector.

54. Page 418. Twenty-five sites are considered potentially significant and National Register eligible. What is the basis for determining the remaining properties non-eligible? This should be clearly documented on a site by site basis.

The rationale for considering a prehistoric site nonsignificant and thus potentially noneligible for nomination to the National Register of Historic Places is based on the following interrelated ~ factors: 1. Site failed to meet any of the eight criteria. 2. Site produced very few artifacts suggesting a highly transient occupation. Of the 41 prehistoric sites considered potentially nonsignif-icant, 27 produced 5 or fewer waste flakes (35%), and 14 produced 10 l waste flakes or fewer (18%) and no other evidence of prehistoric occupation. l Small sites producing no' thing more than a few waste flakes and lacking l culturally diagnostic artifacts offer little research potential or new l data beyond site location infonnation. Further, such s'ites are numerous in areas of abundant chert resources such as the project area. l 3. Items 1 and 2 above, combined with the fact that the 23 prehis-toric sites considered potentially significant constitute a sample of the known cultural and environmental diversity represented in the project area,providethebasisforrecommendationsofnonsignificance. 14

Responses to M0HP Review April 1983 Architectural sites were evaluated and considered significant or nonsignificant using the criteria of the National Register of Historic Places (see architectural responses to M0HP comments). Historic archaeological sites were considered nonsignificant based on the criteria of the National R~egister of Historic Places, integrity (see p. 431), temporal considerations, and the availability of published sources of historic documentation other than archaeological record. 55. Page 436. If sufficient data is available to make National Register evaluations, i.e. detennination of National Register eligible and non-eligible, as called for in the scope.of work, we question the recommendations for further Phase II testing. It would appear that the author is attempting to generate more work. The Scope of Work requires an assessment of " potential eligibility for the National Register of Historic Places" (see Scope of Work 4.0a, p.3). No specific recommendations for Phase II work are made at this time (p.436). Recommendations for Phase II testing are contingent upon the actual threat of adverse effects should such a situation arise in the future (p.440). These recommendations are consistent with the Scope of Work and the Advisory Council on. Historic Preservation, " Procedures for the Protection of Historic and Cultural Properties" (36 CFR Part 800). These procedures were developed to implement the National Historic Preservation Act of 1966 and Executive Order 11593, " Protection and Enhancement of the Cultural Environment, May 1971." They detail how a federal agency should take into account the undertaking's effect on properties included in or eligible for inclusion in the National Register of Historic Places. The first step in the compliance process is the identification and evaluation of all properties included in or eligible for inclusion in the 15

Responses to M0 lip Review l April 1983 National Register of Historic Places that are located within the potential environmental impact area of the federal undertaking, including both federally owned and nonfederally owned land. Union Electric Company has . completed this first step with' earlier surveys (Evans and Ives 1973, 1978,1979) in direct impact zones and the more recent Phase I' survey of residual lands. The second step is a determination by the federal i agency whether any cultural resources included in or eligible for inclusion ~ in the National Register of Historic Places will be affected by the proposed i undertaking. 4 In determining effect, the federal agency, in consultation with the state historic preservation officer, applies the criteria of effect: an undertaking is considered to have an effect when any condition of the under-taking causes or may cause any change -- beneficial or adverse -- in the quality of the historical, architectural, or archaeological character l that qualified the property under the criteria of the National Register of Historic Places. If the federal agency finds that there will be no effect, then the requirements of the law have been satisf. and there j is no Advisory Council involvement in the matter. If the federal agency finds that there will be an effect, then it,.in consultation with the state historic preservation officer, applies the criteria of adverse effect. Generally, adverse effects occur under conditions,which include but are not limited to: (a) destruction or alteration of all or part of a property; (b) isolation from or alteration of its surrounding environment; (c) introduction of visual, audible, or atmospheric elements that are out F - of character wi,th the property or alter its setting; (d) transfer or sale of a federally-owned property without adequate conditions or restrictions 16 l g -M

~ e Responses to M0HP Review April _1983 regarding preservation, maintenance, or use; and (e) neglect of a property resulting in its deterioration or destruction. At this time, there are no known adverse effects from the operation and maintenance of the Callaway plant which threaten those sites recommended as potentially eligible to the National Register of Historic Places. Further, the management plan recommends protection through avoidance of those potentially eligible on a site-by-site basis. A detemination of "no effect" or " adverse effect" can be made when and if they are threatened. Phase II testing for determination of eligibi.lity is recommended only when these threats are identified and reviewed (McNerney 1982:29-40). Architectural Overview 1. Original fenestration, main facade of house (Inventory #4)- Evidence observed on the exterior of this structure would indicate that -the fomer fenestration pattern was window-window-door-window rather than window-door-door-window as suggested by the reviewer. At present, the inner bay is' sealed over with wood siding. Further verifica-tion of the original function (i.e., window or door) of this bay would i require work beyond the scope of this project. The floor plan will be ~ appropriately noted to indicate this as an assumed original window bay. 2. Photographic research The photographic collections of the Missouri State Historical Society and Missouri State Historic Preservation Office were reviewed during September and October 1981. Files of Callaway County, as well as adjacent counties in Little Dixie, were reviewed. 3-3. Regional examples / sites 2, 4, 11, 12, 15, 20, and 21 The M0HP mention of 'several good examples of southern vernacular 17 I

l Responses to MOHP Review April 1983 architecture in Portland, Mokane, and Readsville is a point well taken. The author is aware of these structures and found them useful in evaluating the architectural significance of extant structures within the project area. However, it is this author's opinion that the extant structures within the study area, when compared with other good examples of southern vernacular architecture and particularly with other examples in Callaway County, diminish in architectural significance. The extant structures of the study area do not represent a distinctive level of achievement in structure or styling; rather, they are of average architectural quality. The reviewer has noted that structurcs at sites numbered 2, 4, 11, 12,15, 20,' and 21 " architecturally represent fragments of a widespread regional southern culture that persisted from the initial settlement period through ca. WW I." The author concurs with this observation and with the assertion that these buildings fall within the Little Dixie building tradition. The Scope of Work for this study requires evaluation of extant . structures for historic architectural significance using the criteria of the National Register of Historic Places. The fact that these struc-ture' are " fragments" rather than good, solid examples of regional. cul-s l ' ture diminishes their potential for significance. Additionally, modifica-tions to these structures have, in most instances, compromised their l historic architectural integrity. With respect to sites 2, 4, 11, 12, 15, 20, and 21, the following clarifications rega.rding architectural quality and integrity are made. b Site 2: Structure A has been modified and modernized by the addition of synthetic siding, replacement windows which do 'not match origir.al 18 h

Responses to M0HP Review April 1983 window types or fenestration patterns, and by the addition of ornamentation inappropriate to the period of the original structure. It is the opinion of this author that the historic architectural integrity of this house has been severely compromised through these modifications. The remaining structures at this site are standard architectural / structural types of recent origin. Site 4: Structure A is a standard double-pen type house.

However, it should be noted that the house is a weaker example of the double-pen type house than, for example, others in nearby Portland.

In tems of proportions, scale, and detail, the house at site 4 is not well developed. From an architectural perspective, the house does not represent a level of achievement or uniqueness to merit nomination to the National Register of Historic Places. The ancillary buildings at this site are standard architectural and structural types and do no appear to meet the criteria for nomination to the National Register of Historic Places. Sites 11 and 12: Several structures at these two sites reflect the traditions of southern vernacular architecture. Structure 11A is a double-pen type house, and structure 12A is a single-pen log house l expanded to a 2-story "I" type house. Structures llc, 12C, and 12D . are agricultural buildings of horizontal log construction which represent southern building traditions. When measured against the criteria of the National Register of Historic Places, these structures do not appear to represent a significant level of innovation, uniqueness, or artistry. While they may be potential candidates l for preservation, they are best categorized as standard examples of their respective building types. l 19 e L

t } Responses to M0HP Review i April 1983 Site 15: Structure A represents the "I" type house tradition of the J i uplands South. However, like the structures discussed above, this house fails to represent a level of architectural significance through either I artistry or uniqueness to satisfy the criteria of the National Register of Historic Places. Sites 20 and 21: Log structures 20A and 21A are both in ruin. Their-i I consideration for architectural significance is diminished by this fact. l 4. Bibliography A list of references cited,,rather than a bibliography, was included i I in the report. In response to the reviewer's concern for a lack of basic literature on southern vernacular architecture, a bibliography is submitted with this document. 5. History of occupants of a single house Fomer owners and occupants of property within the project ' area were contacted (see bibliography) for historical infomation related to both the people and places associated with the old Refom area. Legal and historical documents were reviewed for -references to former landholders in the project area. Archival resources produced little information related to inhabitants 1 of the project area prior to involvement of the Union Electric Company in the 1970s. Interviews with fomer landowners and occupants produced little i concrete infomation useable for reconstructing the history of the occupants of a property. The author concurs with the reviewer's concern for the humanistic association with cultural resources. Accordingly, every effort i P was made to l'ocate reliable infomation concerning fome'r occupants and i their potential significance. No documentary evidence was located which 20 I w w-wi. ,w-mM

). Responses to M0HP Review April 1983 indicated significance of fomer. occupants of the extant structures. Interviews with fomer occupants netted infomation that was, at best, conjectural and inconclusive. Consequently, the report deals with architectural / structural data and excludes oral and genealogical findings. 6. Slave schedules and agricultural census records In both the Historical and Historic Architectural overviews, slave schedules and agricultural censuses are referenced when used as sources (e.g.,p.124). Historical Overview l The reviewer's comments are well taken. Both an abbreviated historical 1 overview and the more extensive historical overview were considered. Based upon the central location of Callaway County within the state where early routes of travel passed, i.e., Missouri River and overland trails, and the need to provide an historical backdrop with which to view the history l of Callaway County, the expanded historical approach was selected. The l history section will be edited before the final report is printed. l The agricultural census data were examined and also considered It s ~was decided that census infomation on agricultural produce, slaves, and l other data available from these sources would be more appropriate for Phase II and Phase III investigations should they be deemed necess'ary in the future. We recognize the usefulness of. this material but believe that it is more appropriate for large-scale mitigation efforts similar to the Cannon Reservoir project where these sources were used. M0HP Comments, Page'7 of Review Letter The report is the result of a Phase I investigation (see Scope of l 21

Responses to M0HP Review April 1983 Work 6.0a, p. 8) on the residual.lan'ds surrounding the Callaway plant site. The Scope of Work recommends evaluation of cultural resources to detemine only their potential suitability for nomination to the National Register of Historic Places (Scope of Work 7.0c). Additional investiga-tions-to support determination of eligibility should be detemined frem the results of the Phase 1 investigations (Scope of Work 6.0, p. 8). Further, Phase II investigations are recommended as an aid to identifying significance or lack of significance by the Missouri Office of Historic Preservation: In the case of archaeological properties, the existence of such resources within a proposed undertaking's impact area is generally not known until after the completion of a cul-tural resource survey and in many instances, insufficient infomation exists to determine if a particular archaeological site is eligible for inclusion in the National Register. Con-sequently, additional investigation in the form of limited archaeological testing or Phase II testing, is often needed to provide the necessary data to ascertain the National. Register significance or lack of significance of a site. (Letter from Michael S. Weichman to Michael J. McNerney, October 15,1979) Therefore, the report is consistent with the Scope of Work and the M0HP guidelines. If the M0HP is. recommending Phase II testing at selected sites to ascertain the National Register significance or lack of signif-icance, it should simply make that recommendation to the Union Electric Company. Other comments on page 7 of the review letter concerning the eight criteria and significance are addressed in the individual comments. MOHP Comment, Page 7, Paragraph 5: Furthemore, we do not believe that the statement presented on pages 435-436 that a National Register District is not warrented because of it is "not in the best interest of U.E. Company" is not sufficient justification, neither from a professional point of view or based'on the Criteria set forth in 36CFR Part 60. It is obvious that i the authors pla.ce the opinion of the client over the importance of the protection of the cultural resources. s 22 l ,,-,4

Responses to M0!iP Review April 1983 This comment is taken out of context and ignores the results of the ' survey, legal considerations, the management plan, and the overall project context. In addition, consideration of the " interests of the client" is as important as the cultural resources. Any profession or business which has its operating authority tied to federal laws must always consider these interests. The cost of cultural resources management is borne directly by a specific client or indirectly by the general public (in this case, users of electricity generated by the Union Electric Company). To consider only the cultural resources fails to grasp the essence of either the regulatory process or the complexity of the cultural resources management process. MOHP Comment, Page 8, Nomination of a National Register District It has been recommended that 23 prehistoric archaeological sites and 2 historic archaeological sites are potentially significant and potentially eligible for nomination to the National Register of Historic Places. Phase II testing, to aid in the determination of National Register eligibility, is recommended to proceed only when, and if, these potentially eligible resources are threatened. Th'e remainin'g cultural resources are not eligible for. nomination to the National Register, and further evaluation or assess-ment is unnecessary at the remaining 104 sites. Further', after careful evaluation of all sites and consultation with other archaeologists and cultural resources managers, it is felt that the cultural resources located on the residual lands at the Callaway Nuclear Plant do not qualify for nomination to the National Register as an historic district (McNerney 1982:28). These recommendations are based on legal and regulatory con-siderations as' well as the archaeological and historical context. 23 t

Responses to M0HP Review April 1983 1. Legal and regulatory considerations: The protection of cultural resources from adverse effects (direct and indirect impacts) has been and is the central theme of cultural . resources management laws and regulations, e.g., That any person who shall appropriate, excavate, injure or l destroy an historic or prehistoric ruin or monument, or any l object of antiquity, situated on lands owned or controlled by the Government of the United States, without the pennis-i sion.... (Antiquit.ies Act of 1906) More recently: Whenever any Federal agency f'inds, or is notified, in writing, by an appropriate historical or archaeological authority, that its activities in connection with any Federal construction project or federally licensed project, activity, or program may cause irreparable loss or destruction of significant scientific, prehistorical, historical, or archaeological data, such agency shall notify the Secretary, in writing, and shall provide the Secretary with appropriate information concerning the project, program, or activity. (PL 93-291, Archaeological and Historic Preservation Act, Section 3, 1974) The Union Electric Company has complied with these and other' federal 1 l laws hy having conducted cultural resources assessments in areas impacted by construction activities related to the building of the Callaway plant (McNerney 1982:2). The intensive survey of the residual lands goes beyond 1 the letter of the law and has demonstrated Union Elec'tric Company's willing-ness 'to meet the spirit of the law as well. Under the Advisory Council's " Procedures for the Preparation of Historic and Cultural Properties" (36CFR800), Section 800.4(6) of the procedures requires that the state historic preservation office be con-suited when any federal, federally funded, or federally licensed under-taking will affect a property included in or eligible for the National i i Register that is located within the undertaking's potential environmental impact. In the opinion of the National Register archaeological staff in 24

R:sponses to M0HP Review April 1983 Washington, D. C., any proposed undertaking within the boundaries of an historic district by an agency having a federal involvement would have to be reviewed to determine the effect of the undertaking on the historic district even if the undertaking would not directly affect any of the eligible sites within the district (Bush 1982: telecommunication). These regulatory requirements are not administrative 1y or archaeologically feasible based upon the findings presented in the Phase I survey report or the overall context of the project., First, the creation of an historic district which contains large amounts of land devoid of any cultural resources (92% of the residual lands lack cultural resources) can not be justified. Second, an historic district on the residual lands would have to be defined by arbitrary boundaries which do not reflect cultural or environmental integrity. Third, the potentially significant cultural resources could be administered more effectively on a site-by-site basis if they were threatened and after a determination of adverse or no adverse effects was made. Therefore, based on the,nonsignificance of many of the cultural resources recorded and evaluated during the Phase I survey and the legal considerations mentioned above, we see little justification in recommend-ing a National Register District for the residual lands. 2. The evaluation of the archaeological / historical context and the evaluation of individual site significance does not support a National, Register District nomination for the following reasons: Of the 79 prehistoric archaeological sites recorded, 41 (52%) a. l produced 10 or fewer waste flakes (27 produced fewer than 5 waste flakes, an.d 14 produced fewer than 10 waste flakes). The research potential at such sites is extremely low, 25

/ Responses to M0HP Review April 1983 b. Only one of the 41 sites produced a culturally diagnostic artifact. c. Aboriginal inhabitants found abundant amounts of useable chert within the project area, a situation which results in the fre-quent occurrence of waste flakes thinly and widely scattered across the landscape. d. Based on the above factors (2a-c), we can not justify Phase II testing for the purpose of further assessing eligibility to the National Register cf Historic Places. e. Ninety-two percent of the area within the project boundaries is devoid of cultural resources (pp. 408-416). It would be difficult to justify creating a National Register District containing this much empty space. f. The 23 prehistoric sites (29% of all sites recorded) recommended as potentially eligible provide a sample of sites represent.ing all known cultural time periods in the project area, each environmental zone, and abundant amounts of waste flakes with which to study problems of lithic technology. This sample provides an adequate base for a wide variety of research problems. g. Dr. Dale R. Henning, Project Consultant, has evaluated the cultural resources recorded on the Callaway Nuclear Power Plant residual lands using criteria developed for district nominations at the Cannon Reservoir in northeastern Missouri. The criteria are posed as-questions: (1) Did the affected area ever constitute a natural and/or cultural region unique unto itself in comparison with the surrounding D area through time? 26

Responses to M0HP Review April 1983 (2) Did the affected area function as a " key point" of any regional or areally-defined cultural manifestation through time which, in the absence of data from there, the whole would never be properly understood? Applying these questions to the archaeological resources in the Cannon Reservoir, it was concluded that the resources and the area possessed cultural-regional integrity.and encompassed a definable natural cultural region which could be offered to district nomination. Evaluating the cul-tura1' resources on the Callaway Nuclear Power Plant residual lands in a similar manner, Dr. Henning concludes: My reading of the data from the project area does not suggest such integrity [like the Cannon area], at any point in time. It [ cultural resources on the residual lands] is "part of" much broader areas, leaving the evaluator to decide which " parts" may be integral to our understanding of regional or areal prehistory and history. I see very few sites which . qualify in any respect as integral to our understanding [of areal prehistory and history].... The Phase I testing program has been very methodical and thorough. In a sense, following the subsurface testing done in search of sites in forested, brushy and grassy locations, dimensions) gs for Phase II. testing (depth and spatial the beginnin has already been begun. Many prehistoric sites located can be thoroughly evaluated in tems of the limits of testing already accomplished. In short, I am suggesting that in tems of the future, all 129 sites located should be subjected to critical review and deteminations of eligibility made for those few which are deemed worthy by virtue of site integrity and potential areal importance. Few enough of the sites located in this project area would survive intensive scrutiny. Phase II testing of those few would probably eliminate a number because of previous disturbance or paucity of artifacts offering cultural identifications. Unless my initial readino of the documentation afforded to date coupled with infomation gatnered thrcugh site visits is seriously in error, I doubt that final evalur.cien pertinent to recommendation to the National Register of flistori: Places would be feasible for more than 10 (probably less) sites in the entire project, area. This figure includes all rescurces, 27 l 1 1

Responses to MOHP Review April 1983 prehistoric, historic and historic-architectural. I would recommend Phase II testing on sites which, following the intensive Phase I work already done, are believed to be unique in some way and retain some semblance of integrity. District nomination is, to me, not feasible for the project area. That area does not constitute either a natural or cultural district at any level nor, judging from the informa-tion available, did it at any time in the prehistoric past. This location has always apparently been part of a much larger world; a world shared with the Missouri River trench and/or Ozark Highlands. To recommend it as a district on the basis of cultural resources seems to me to be a form of punitive act not necessarily conforming to the spirit of the law. (Comments from Dr. Dale R. Henning to American Resources Grcup, Ltd., July 30,1982) The principal investigator concurs with Dr. Henning's conclusions but recomme.nds Phase II only after a determination of future adverse effects to the 23 potentially significant sites which may occur as the result of plant operation, maintenance, or expansion. One other change in the survey report has been made. All discussion of site significance and related management recommendations has been moved to the management report. The first draft contained much of the manage-ment plan; the reader is now referred to the management document. The foregoing discussions constitute the central issues in the decision not to recommend nomination of the cultural resources on residual lands as an Historic District. However, if the p'otentially significant cultural resources identified in this Phase I survey are threatened by adverse effects related to the operation and maintenance of the Callaway plant sometime in the future, Phase II testing related to future adverse effects may provide additional evidence which would support a district nomination at that time. e b 28

g_ l. ~ References Binford, Lewis R. 1980 Willow smoke and dogs' tails: hunter-gatherer settlement systems and archaeological site formation. American Antiquity 45(1):4-20. Comptroller General 1981 Are agencies doing enough or too much for archeological preservation? Guidance needed. _ Report to the Chainnan Committee on Interior and I_nsular Affairs, House of Representatives, CED-81-61. U. S. General Accounting Office, Gaithersburg, Maryland. Evans, David R., and David J. Ives 1973 Initial archaeological survey of the proposed Union Electric Company Nuclear Reactor near Reform, Callaway County, Missouri. Archaeological Survey of Missouri, Columbia. 1978 A cultural resources survey of the proposed Union Electric Company 345 KV transmission line right-of-way, Callaway and fiontgomery counties, Missouri. Union Electric Company, St. Louis, Missouri. 1979 23CY20, the preservation plan for an archaeological site. Archaeological Survey of Missouri, Columbia. Federal Register 1976 Rules and Regulations 41(6):1595. e-Haas, Daniel R. 1978 An archaeologica1 survey of the Little Femme Osage River Hills Area and the Loutre River valley: a multivariate _ approach to environment and site distributions in the lower Missouri valley Il locality. Department of Interior. National Park, Service, Washington, D. C. Kling, Laura, and Elizabeth Martin 1979 An archaeological survey of the Femme Osage and Dardenne Creek drainages, St. Charles County, Missouri. Ms. on file, Department of Anthropology, University of Missouri-Columbia. Klippel, Walter E. 1972-An Early Woodland period manifestation in the prairie peninsula. Journal of the Iowa Archaeological Society 19:1-91. McNerney, Michael J. 1982 A cultural resources management plan for residual lands at the Union Electric Company Callaway Nuclear Power Plant, Callaway County, Missouri. American Resources Group, Ltd., Carbondale, Illinois. 29 L_ J

Ray, Jack H. 1981 Field notes. University of Missouri archaeological field school excavations at Arnold Research Cave. Notebook on file, Division of American Archaeology, Department of Anthropology, University of Missouri-Columbia. Rondeau, Michael F. 1981 The data-focused research design for contract excavations. Contract Abstracts 3(1):33-34. Roscoe, John T. 1975 Fundamental research statistics for the behavioral sciences (second ed.). Holt, Rinehart, & Winston, Inc., New York. i Schmits, Larry J. (editor) 1982 Prehistory and history of the Hennann site (23GA142), Gasconade County, Missouri. Ms. on file, Environmental Systems Analysis, Inc., Overland Park, Kansas. Schmits, Larry J., and Christopher A. Wright (editors) 1981 Archaeological investigations at the Roddy site (23B0966) and the Coates site (23B0965), Boone County, Missouri. Cultural Resources Management Report No. 2. Environmental Systems Analysis, Inc., Overland Park, Kansas. Sturdevant, Craig 1978 An intensive cultural resource survey of the lower Moreau River valley, Cole County, Missouri. Missouri Departinent ofNationalResources,LincolnUniversity,JefferyonCity. Thomas, David Hurst 1976 Figuring anthropology. Holt, Rinehart, & Winston, New York. Wendorf, Fred 1978 The Fort Burgwin conference on national archaeological policies. Ms. on fi-le, Department of Anthropology, Southern Methodist University. ~ l Wright, Christopher A. 1981 TheRoddysite(23B0966). In Archaeological investigations i at the Roddy site (23B0966) and the Coates site (2380965), Boone County, Miss'ouri. Cultural Resources Management l Repor_t No. 2. Environmental Systems Analysis, Inc., Overland Park, Kansas. I. i 30 l

~ ARCHITECTURAL BIBLIOGRAPHY A Phase I Cultural Resources Survey and Assessment on Residual Lands at Union Electric Company's Callaway Nuclear Power Plant, Callaway County, Missouri Publications 'Ankeney, J. S. 1922 A century of Missouri art. The Missouri Historical Review XVI(4):481-501. Anonymous n.d. Only memories now remain of Reform store. Clipping file, .Fulton Public Library, Fulton, Missouri. Black, J. R. (editor) 1966 Yesterdays in Callaway County, Missouri. Kingdom of Callaway Historical Society, Fulton, Missouri. Brunskill, R. W. Universe 1971 Illustrated handbook of vernacular architecture. Books, New York. Caldwell, Dorothy J. 1963 Missouri historic sites catalogue. State Historical Society of Missouri, Columbia. Callaway County Land Use Planning Committee 1941 An intensive land use planning report for Callaway County, Missouri: a preliminary report. Callaway County Land Use Planning Commission, Fulton, Missouri. Finley, Robert, and E. M. Scott 1940 A Great Lakes to Gulf profile of dispersed dwelling types. The Geographical Review XXX(3):412-419. Glassie Henry, III 1969 The double crib barn in south-central Pennsylvania (Part I). Pioneer America 1(1):9-16. Holt, William W.The history of Holts Summit,-Missouri. Modern Litho-Print 1976 ~Company, Jefferson City, Missouri. Jeane, D. Gregory, and Douglas Clare Purcell 1978 The architectural legacy of the lower Chattahoochee valley in Alabama and Georgia. The University of Alabama Press, Tuscaloosa. Kniffen, Fred B. 1936 Louisiana house types. Annals of the Association of American Geographers 26:179-196. 31 W W- ? e a -s v --v y s _g-_

Architectural Bibliography (cont.) 1965 Folk housing: key to diffusion. Annals of the Association of American Geographers 55(4):549-577. Kniffen, Fred, and Henry Glassie 1966 Building in wood in the eastern United States: a time-place perspective. The Geographical Review V.LVI(1):40-66. Lemmer, George Francis 1941 Agricultural improvements in Missouri: 1830 to the Civil War. Unpublished M.A. thesis, Department of Agriculture, University of Missouri-Columbia. Meyer, Douglass K. 1975 Diffusion of upland south folk housing to the Shawnee Hills of southern Illinois. Pioneer America 7(2):56-66. National Historical Company 1884 History of Callaway County, Missouri. Nixon-Jones Printing Company, St. Louis. O'Brien, Michael J., Jacqueline E. Saunders, Dennis E. Lewarch, and Cleyton B. Fraser 1980 An analysis of historical structures in the Cannon Reservoir area, northeast Missouri. Division of Archeological Research, University of Nebraska-Lincoln. O'Brien, Michael J., and Robert E. Warren (editors) 1979 Cannon Reservoir human ecology project -- a regional approach to cultural continuity and change. Division of Archeological Research, University of Nebraska-Lincoln. Rafferty, Milton D. 1980 The Ozarks, land and life. University of Oklahoma Press, Norman. Reidl, Norbert F., Donald B. Ball, and Anthony P. Cavender 1976 A survey of traditional architecture and related material folk culture pattarns in the Normandy Reservoir, Coffee I County, Tennessee. Report of Investigations #17, Department of Anthropology, University of Tennessee-Knoxville. Schroeder, Walter J. 1977 Bibliography of Missouri geography. Department of Geography, University of Missouri-Columbia. Sturdevant, Craig 1970 An intensive cultural resource survey of

  • he lower Moreau River valley, Cole County, Missouri.

Department of Social Science, Lincoln University, Jefferson City, Missouri. Trewartha, Glenn T. 1948 Some regional characteristics of American farmsteads. Annals of the Association of American Geographers 30(3):169-225. 32

Architectural Bibliography (cont.) Wilson, Eugene M. 1970 'The single pen log house in the south. Pioneer America 2(1):21-29. Writer's Program, WPA in the State of Missouri 1941 Missouri: a guide to the "show me" state. Hastings House, New York. Interviews Bezler, Hadley 1981 Personal communication /interv,iew. 101 E. Reed, Fulton, Missouri, September 1. Denny, James. 1981 Personal communication / interview. Missouri Department of Natural Resources, Parks and Historic Preservation Division, Jefferson City, Missouri, September 2-3. Garrett, Oran 1981 Personal communication / interview. 321 Meadowlark Drive, Fulton, Missouri, September 1. Harvey, Boyd 1981 Personal communication / interview. Mokane, Missouri, September 1. Holland, Charley, and Jewel Holland 1981 Personal communication / interview. Steedman, Missouri, September 1. Lawrence, Ralph .~ 1002 Randall, Fulton, 1981 Personal communication / interview. Missouri, September 1. Shiverdecker, Pearl 1981 Personal communication / interview. 507 Highway 54S, Fulton, Missouri, September.4. .Steele, Patrick H., Sr. 1981 Personal communication / interview. Missouri Heritage Trust, Jefferson City, Missouri, September 2. Veatch, Virginia 1981 Personal communication / interview. East Second at Addison Streets, Fulton, Missouri, September 4. Photographs 2 Aerial view of Reform, late 1970s, prior to demolition. Shous Reform store, Water's house north of store, and associated barn. Courtesy of Charley and Jewel Holland, Steedman, Missouri. 33 ...g --_-,.,..we---

~ + ~ ? Architectural' Bibliography (cont;) 8 Barn and wooden silo on" Holland farm (north of General Store). ~ Cour,tesy of Charley and Jewel Hellhnd,, Steedman, Missouri. ~ Holland General StoreJ Reform, Missouri, mid-1970s. Courtesy of s ^ Charley and Jewel Holland, Steedman, Missouri. 3 s = t 4 \\ I .g .{ m %4 h e H-M.j [.\\, g e t' 1 1 y 4 .. m h y T-~ ;.. ,( e. r ^

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