ML20072S805

Forwards Addl Correspondence W/State of PA Historic Preservation Officer,In Response to Question 310.10 in NRC .W/Two Repts: Norristown Design Changes... & Investigation of Potential Visual Affects..

ML20072S805
Person / Time
Site:	Limerick
Issue date:	04/04/1983
From:	Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML20072S809	List: ML20072S805 ML20072S839 ML20072S853
References
NUDOCS 8304070349
Download: ML20072S805 (16)

Text

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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 EDWARD G. BAUER. JR. *

• END GEN 7RAL COUNSEL (215)841-4000 EUGENE J. BRADLEY ASSOCIATE GENERAL COUNSEL DONALD BLANKEN CUDOLPH A. CHILLEMI M *L*e",^ CORNELL April 4, 1983 ASSISTANT GEN RAL COUNSEL EDWARD J. CULLEN. JR.

JOHN F. KENNEDY, JR.

ASSISTANT COUNSEL Mr. A. Schwencer, Chief Division of Licensing U.S. Nuclear Regulatory Commission Docket No. 50-352 Washington, D. C. 20555 50-353

SUBJECT:

Limerick Generating Station Units 1 and 2 Request for Additional Information

REFERENCE:

1. Letter, A. Schwencer to E. G. Bauer, Jr.

Dated: November 8, 1982

2. Letter, E. G. Bradley to A. Schwencer, Dated: February 25, 1983

Dear Mr. Schwencer:

Question 310.10 (revised) submitted with your November 8, 1982 letter (Reference 1) requested copies of correspondence with the State Historic Preservation Officer. Copies of the following correspondence were provided to you in a February 25, 1983 letter from E. J. Bradley.

1. Brenda Barrett to George N. DeCowsky, dated January 26, 1982

2. Greg Ramsey to Philadelphia Electric Company, dated September 3, 1982

3. George N. DeCowsky to Greg Ramsey, dated September 17, 1982

4. Greg Ramsey to Harry Bechtel, dated September 27, 1982

5. Greg Ramsey to George N. DeCowsky, dated November 16, 1982

6. Donald S. Frieman to Greg Ramsey, dated December 1, 1982 l

7. Greg Ramsey to Donald S. Frieman, dated December 8, 1982 '

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W Since then, we have received the following correspondence (5 copies attached):

1. Greg Ramsey to John Milner Associates, dated February 7,1983

2. Donald S. Frieman to Greg Ramsey, dated February 16, 1983

3. Donald S. Frieman to Greg Ramsey, dated February 22, 1983

4. Donna Williams to Donald S. Frieman, dated March 21, 1983

5. John Milner Associates to Donna Williams, dated March 30, 1983, transmitting the following report which addresses the concerns cited in the above correspondence.

"Norristown Design Changes and Chester County Potential Visual Effect Evaluation, A Report Supplementary to: An Investigation of Potential Visual Effects Upon Previously Recorded Historic Sites in the Vicinity of Proposed Limerick Transmission Lines, Montgomery and Chester Counties, Penn-sylvania" by John Milner Associates, Inc. dated March, 1983.

(The original Milner Historic Site Report, dated 1982, is also attached.)

The answer to Question 310.10 will be revised to convey the above information in the April. 1983 revision of the EROL.

Very truly yours d

Euclosures cc: See attached Service List 1

cc: Judge lawrence Brenner (w/o enclosure)

Judge Richard F. Cole (w/o enclosure)

Judge Peter A. bbrris (w/o enclosure)

Troy B. Conner, Jr., Esq. (w/o enclosure)

Ann P. Hodgdon (w/o enclosure)

Mr. Frank R. Pmano (w/o enclosure)

Mr. Robert L. Anthony (w/o enclosure)

Mr. Marvin I. Irwis (w/o enclosure)

Judith A. Dorsey, Esq. (w/o enclosure)

Charles W. Elliott, Esq. (w/o enclosure)

Mr. Alan J. Nogee

. (w/o enclosure)

Robert W. Adler, Esq. (w/o enclosure)

Mr. Thmas Gerusky (w/o enclosure)

Director, Pennsylvania Emergency Managment Agency (w/o enclosure)

Mr. Steven P. Hershey (w/o enclosure)

James M. Neill, Esq. (w/o enclosure)

Donald S. Bronstein, Esq. (w/o enclosure)

^ Mr. Joseph H. Khite, III (w/o enclosure)

Walter W. Cohen, Esq. (w/o enclosure)

Robert J. Sugarman, Esq. (w/o enclosure)

Rodney D. Johnson (w/o enclosure)

Atcmic Safety and Licensing Appeal Board (w/o enclosure)

Atomic Safety and Licensing Board Panel (w/o enclosure)

Docket and Service Section (w/o enclosure) t 4

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DOMMcNWhLTH OP' PENNEYLVANIA PENNSYLVANIA HISTORICAL aN::: M J3EUM COMN"U"lCN wettaAme pawn memonsak muesum ano A=cnives sun.oins som iose Hamasseune, pswwev6vameA mso February 7, 1983 John Milner Associates 309 N. Matlack Street .-

West Chester,'PA 19380 -

Re Ph'iladelphia Electric Co.

Transmission Linos.

Associated with Limorick Gonorating sention BRG2. 042M 0047 .

Dear Mr. Milper Upon further review of your study, M Investication gf Potential Visual Effects uggn Previousiv Recorded Historic.

l Sites in the Vicinity of Proposed Limerick Transmission Lines, the Durea U cr Histori EPreservation has noted a serious

• omission of sites in the Limerick-Cromby portion of the study.

Only one site on*the Chester County side, River Bend Parm, i.n l noted on your Table 2 as being potentially visually afIcutod.

It appears to us that several sites had been recorded by the Chester County Historic Sites Survey which escaped your attention.

upon Parker's Ford.

Our principal concern at this point are potential effects A historic resource form documenting this resource was received at the Bureau for Historic Preservation on October 10, 1981 and a National Register form on April 26, 1982. This historic district has been approved for nomination by our State, Review Committee and is now pending final review in Washington. We are also aware that the historic house owned by Mr. and Mrs Richard M. Heess, 167 Old Schuylkill Road, Spring City (E. Vincent Twp.) has the potential of being both visually compromised and physically affected by the proposed placement of transmission lines along the railroad corridor. '

The Chester County Survey should be consulted to determine whether other sites have been overlooked.

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Page no . 6 Philadelphia Electric Co.

Transmission Lines associated with Limerick Generating Station

• February 7, 1983 ER82 042M 0047 (cont.)

In our opinion ic is imperative that these significant omissions be corrected and that the analysis of the effects of this project be excended as well to evaluate effects on *

, these sites. ,

. We look forward to meeting you in the near future to discuss your further analysis of effects on-sites in Montgomery and Chester County.

Sincerely, eg' y, Chief Divisio of Planning an Protection

. Bureau for Historic Pre ervation (717) 783-8947 GRask cca D.C. Frieman/

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PHILAD ELP IA ELEt rRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 nsat. ESTATE OsV486000 February 16. 1983 Mr. Greg Ramsey, Chief *

Division of P1-iar & Protectic.2 Bureau for Historio Preservation William Penn Memorial Massum and Azahives an41a4=g Boz 1026 Harrisburg, Pennsylvania 17120 File No. PE 9150 NearMr.Hausey:

I have your letter of February 7,1983 addressed to Mr. Milner of John Milner Ausooistes with respect to our proposed transmission lines associated with Limerick generation.

We are awum that Mr. and Mrs. Richard M. Hoess of East Vinoemt Township, Chester county have submitted their property for placement on the State or National Register. Steps have already been taken to minimise any visual effect our new line may have on the property. In discussion with Mr. and Mrs. Hoess, we have ucreed to change the location of a pole. It will be moved to the property i

line and to the other side of the railroad tracks away from the dwelling. Also, to mitigato I,he possible visual effect on the property other facilities owned by this Company that will be crossed by the proposed tran==ie= ion line will be lowered so the new line will present a lower profile. And lastly, on this property we have a6 reed in a letter to Mr. and Mrs. Essas to add plantings to the existing screen-ing around the dwelling.

May I also point out that the dwelling will not be physically affected by our proposed line. This has -been discussed in meetings with Mr. and Mrs. Heems and this Company's engineers. '

Historic sites on plans attached to our Petition submitted to the Public Utility Commission in December of 1981 were gathered h vprious sonrnes. One of the sources was Mrs. Estella cremra. who 7 bellaw. was irlved in the Guester County survey. We met with Mrs. dweers in the Spring of 1981 and to the best of our knowledge the Parkerford and Heess sit.e ,:: ra not mentio w'.

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. b em. Greg Hamsey -

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February 16, 1983  !

We are prepared together with John Milner Associa.es to discuss any asp -%

of the proposed tran==4== ion lines at your convenience.

Y yours, D. S. Frieman

, Manager 1985:jfg e

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 1215)841 40oo REAl. ESTATE DiviSaops i

February 22, 1983 Mr. Greg Ramsey, Chief Division of Planning and Protection Bureau for Historic Preservation William Penn Memorial Museum and Archives Building ifox 1026 Harrisburg, Pennsylvania 17120

SUBJECT:

Archaeological Survey, Transmission Lines Associated with Limerick Generating Station

Dear Mr. Ramsey:

In a letter ,to you dated December 1,1982, we outlined to you a program designedto adequately consider those prehistoric cultural resources within the area of concern. This letter is to make you aware of the results of the archaeological curvey to dato, and to inform you of the results of discussions with Mr. Kurt Carr, P.H.M.C., on February 2 and 3, 1983, at which time mutually agreeable mitigative measures were determined regarding three sites deemed to be potentially significant.

An outline of these meetings and the mitigative measures agreed upon tollows:

A. First meeting was held on Wednesday, February 2,1983. Those present were Mr Carr and P. Jehle of the P.H.M.C., D. Roberts and E. Eats of John Milner Associates, West Chester, Pennsylvania.

' Representing Philadelphia Electric Company were P. Cava, T. Milone and W. Payne.

Mr. Roberts first reviewed the results of the survey to date, stating that 23 new sites have been uncovered, virtually all of which are ephemeral, upland sites, and do not appear to have significance. The phase two survny was performed on all cites for which suffic:ent data

was not availaule following the phase one survey. Mr. Carr was satisfied that proper procedures had been followed throughout the survey. An offer was made, and accepted, to have Mr. Carr review the artifacts and data associated with these sites the following day at the offices of John Milner Associates in West Chester, Pennsylania.

Three sites which are of concern were then discussed. The first of these sites, 36 CH 103, is directly across the Schuylkill River from Limerick Nuclear Generating Station and will be impacted by one of the transmission lines to be constructed. This sites stretches for

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Mr. Greg Ramsey page 2 February 22, 1983 thousands of feet along the river bank and cannot be avoided during this project.

As this site has yielded thousands of artifacts dating from approximately 7000 B.C. to the period just before the coming '

of the Europeans, and as several features have been uncovered in the process of limited excavations conducted in the past, mitigative measures have been discussed at length in order to determine what measures PE CO may take to minimize impact upon the site. Mitigative measures decided upon, and accepted by Mr. Carr, are as follows:

1. Approximately .1100 feet of new construction is involved with a ningic structure falling within the site. An existing

stone access road leads to within approximately 200 feet of this proposed structure. From this point to the structure a new access road must be constructed. Top soil along the Proposed access road will be carefully stripped witt a

' gradeall ard a thorough search made for subsurface features.

Should any features be found during this process,they will be excavated, unless they should be excessive in number, in which case a representative sample will be excavated. The same procedure the proposed will structure be carried out in the area immediately surrounding site.

2.

As mentioned above, approximately 1100 feet of new right of way affect the site. Impact will be avoided on all but the new structure location by utilizing a helicopter to fly in the lead lines for pulling cabla. This will avoid the necessity of using heavy equipment along the 1100 feet of right of way.

Only the structure location, and the 200 feet of new access road, will have an impact on the site.

The second area of concern lies on the east bank of the Schuylkill River Directly across from our Crosby Generating Station. It has been impossible to do any but minimal archaeological work in this area due to the presence of 2000sewage raw feet ofspread right ofupon way.the Although surface of the ground covering approximately it has been possible to do only minimal survey work in this area, existing collections indicate that a broad range of projectile points, as well as pottery, have been found at one or more sites within this 2800 foot strip. It was proposed to Mr. Carr, and accepted, that a strip approximately 20 feet wide would be plowed, following the route of the proposed access road. A controlled surface search would then be condected along the plowed strip. Should any areas of artifact concentration be uncovered, mitigative measures would be followed within those areas. These mitigative measures would be the same as those proposed for 36 CH 103.

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r pago 3 The third area of concern lies on the east bank of Skippack Creek along our proposed Cromby-North Wales Line. Sites of high potential lie on both sides of the proposed transmission line at this location.

Findings within the right of way, however, have been minimal with the exception of a small area just east of Skippack Creek. This is a ficod plane area lying only 3 to 4 feet above the elevation of the existing creek. No surface finds were found in this area, however, a test pit uncovered a large number of water worn pottery shards lying within a lens of darker soil approximately 6 inches in thickness and approximately 18 1 inches below the surface of the ground. No other artifacts were found. I No artifacts were found in nearby test pits either, nor was the dark l band of soil. Mr. Carr reserved judgment on this location until he could personally view the site in the field the following day, uincussion was twld regarding the two lines to be built along tae existing railroad rights of way between Limerick and Crceby. Mr. Carr stated that with the exception of 36 CH 103 and the site across from Cromby Generating

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Station on which raw cowage hac bcon specad, thoco linos woro clear for construction so long as structure locations and heavy equipment were limited to the ballast area, railroad access roads and other heavily

, disturbed areas. Philadelphia Electric Company has agreed to restrict contractors to those areas.

B. On February 3,1983, following a field inspection of the Skippack Creek site, Mr. Carr met with D. Roberts, K. Satz in the offices of John Milner Associates, Woct chostor, Pennsylvania. W. Payne of this office was not present due to illness. The subject site was discussed in detail. Mr.

Carr felt that the dark lens of soil was probably the only vestige remaining of a prehistoric living surface, the remainder of which had probably washed away during a flood in the past. It was agreed that the

, test pit, in which the pottery sherds and dark lens of soil had been discovered, would be expanded in an attempt to define the limits of the dark band of soil, and hopefully to locate diagnostic artifacts which might be associated with the pottery. Philadelphia Electric Company has agreed to the above.

Mr. Carr reviewed the artifacts and data relative to the 23 now sites uncovered, and agreed that to date sitigative measures were necessary only on the three sites discussed above.

. wo greatly appreciate the quick recponses and close cooperation afforded by you and Mr. Carr, and look forward to working closely with you in the future.

Ver truly rs, WCPsib cca B. Kent h 1  %

D. Solatz D. S. Frieman K. Carr G. Paradis Manager H. Schenk G. Gornish

. Cava W. C. Payne T. Milone G. De Cowsky

.5 COMMONWEALT*1 QF PFNNEY'.VANIA PENNEYl.VANIA HISTORI.GL " AND MUSE JM COMMI5510N -

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, Philadelphia Electric Company , I 2301 Market Street }

P.O. Box 8699 Philadelphia, Pennsylvania 19101 Re: File No. ER 82-042M-0047 Dear Mr. Friemsas Thank you for your letter of February 16 regarding mitigation of possible adverse effects by the tr=a==4=sion lines on Mr. Heess' property in East Vincent Township. Wo. appreciate your efforts on behalf of this property, however, we went to reiterate our concern about negative visual impacts of the lips on 49 other sites discussed in John Milner's report (see November 16 letter to G. N. DeCowsky, copy enclosed).

We are still waiting to hear from you concerning ways to avoid or mitir, ate those. visual effects. Because of the Nuclear Regulatory's resik msibility for licensing the Limerick Station, some resolution will have to be reached under the Advisory Council on Historic Preservation regulations before the licensing can proceed.-

We would be happy to review material you could submit or meet to discuss the issues involved. Please call if you ham ,nestions.

Sincerely, M Mb Donna Williams, Chief Division of Planning & Protection l Bureau for Historic Presertation (717) 783-8947 cc: Brian Richtor, NRC $

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JOHN MILNER ASSOC:IATES ,

l 309 north rnattack street, west chester, pennsylvanin 1938o - telephone 2:5-436 90oo March 30, 1983 Ms. Donna Williams, Chief Division of Planning and Protection Bureau for Historic Preservation Box 1026 Harrisburg, PA 17120 Re: Philadelphia Electric Company, Limerick Trsnsmission Lines, Potential Visual Effects

Dear Ms. Williams:

Enclosed for your review is a supplementary report concerning the above-referenced project. It addresses questions raised by Greg Ramsey's letter of February 7, 1983, which indicated the princi-pal remaining concern was potential visual effects to Parker's Ford, the Heess property, and other sites included in I.he Chenter County survey. In addition to these concerns, the enclosed report discusses design changes made on the Cromby-Plymouth Meeting line in Norristown which will eliminate adverse visual changes to sixteen historic sites. ,

I would like to reiterate some background information about the project. First, I feel it is important to note that PE is making a concerted effort to protect historic and archeological sites from adverse effects resulting from the proposed power lines.

Regarding the historic. sites, PE did not hesitate to undertake the additional work encompassed in the enclosed report. In

addition, PE, in consultation with Mr. and Mrs. Heess, arrived at -

mitigative measures for that property prior to Mr. Ramsey's comments. Regarding archeological sites, PE is undertaking a

, major program of survey, testing, and mitigation and in coopera-l ting fully with Mr. Kurt Carr. Two PE employees are devoting l much of their time in the furtherance of these p,rojects. Mr. ,

i Harvey M. Schenk is assis' ting with the historic sites and, in addition to providing technical information, Mr. Schenk has worked with PE's engineers to develop the mitigation munsures

. presented in the enclosed report. Mr. Walter Payne, a know-ledgeable and conscientious avocational archeologist, has taken l an active role in data collection and in coordinating the archeo-logical program with PE engineers and with landowners. The contributions made by these individuals evidences PE's good faith effort to protect the archeological and historic sitec.

Ancurrects Ancusotocists Pr.ANNERS restoration - adaptive reuse prehistoric a. historic archeology

• historical s. architectural research planning

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f"fould' hike al4d tdjprovide'"sdditional information about the N,e,th'ods,bs,~

('St ruth'e ,and 'Zatz 1982In) .dnd"l' order read to identify 1Es .of John areasNiiner~

of Associates pbtEntial adverse effects, that investigation identified anti-cipated view shed changes and evaluated them as either positive or negative. In. contrast, the enclosed report emphasizes net visual effects by considering c,urrent viewing current viewing -

conditions as well as changes expected to result from the proposed transmission lines. In addition to positive or negative, this approach includes an evaluation category of

" negligible" to account for instances in which the expected change is insignificant. .I feel this approach allows a more comprehensive and realistic' evaluation of potential adverse effects, and would like to apply it to the sites previously evaluated in teram of only postive or negative changes. The following discussion is organized by proposed transminnion lines:

1. Limerick-Cromby . .,,

Sites potentially,affected by the proposed Liberick-Cromby lines include tho'a'e"di'acussed in the enclosed report, and the Coch Home

' in Limerick Township, Montgomery. County. The current view shed of this property ~is dominated by the Limerick cooling towers and existing transmission lines. When. evaluated as strictly positive or negative, the change' anticipated' from the proposed line was considered negative due to the presence of additional visual in-trusions (Struthers and Zatz 1982:11). However, when the enti-l cipated change is evaluated with regard to current elements of the view shed, the net Visual effects of the proposed facilities are expected to b'e negligible due to the low visibility of the proposed transmission facilities and the overriding visual domi- ,

nance of'the existing cooling towers and transmission lines.

2. Cromby-Plymouth Mee' ting "

As discussed in th'e enclosed report, design changes are expected to eliminate adverse' visual effects to the sixteen historic sites l

I in Norristown which would have been affected by extensions to existing railroad catenary structures. The remainder of the I

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I Donna Williams, Chief Div. of Planning and Protection Bureau of Historic Preservation March 30, 1983 -

Page 3 route currently contains lattice structures which are to be replaced by lower, less obtrusive, pole structures. They may be visible from sites 91, 104, 151, and 154 (Struthers and Zatz 1982: Table 2.2). Site 91 is approximately 2,700 feet from the proposed line and is separated from it by a railroad switch yard, an artificial impounding basin, and other negative viewing ele-monts. Similarly, site 151 is further removed from the proposed line and has a view shed towards it which includes multi-ple railroad tracks, the Barbadoes Island generating and sub-station facilities, and additional industrial development. Site 154 lies almost two miles from the proposed line and overlooks the entire valley including the aforementioned negative viewing elements. Due to their distance from the proposed line, the currently negative view shed qualities, and the minimal visual change expected from the replacement of lattice structures with pole structures, these three sites are not expected to be adversely affected by the proposed transmission line. Site 104 shares the negative viewing elements, and as a cemetery, it is probably not eligible for the National Register. Ac*co rd ingly , it is not subject to effects as defined in 36CFR800.

3 Cromby-North Wales The proposed Cromby-North Wales line will be supported by tubular structures within a right-of-way which currently contains lattice

structures. Under the approach'which allowed only a positive or negative evaluation, the determination was negative due to the increased density of lines within the right-of-way (Struthers and Zatz 1982:12). Under the current approach, however, the evalua-tion is negligible because of the minimal change which will actually occur to the view sheds of the historic sites.

4. Limerick-Whitpain The Limerick-Whitpain proposal calla for new lattice structures to be placed adjacent to extant structures of the same type within the right-of-way. As with the Cromby-North Wales line, the original evaluation was negative due to the increased density of lines (Struthers and Zatz 1982:12). When the existing viewing conditions and the symmetrical placement of proposed structures

Donna Williams, Chief Div. of Planning and Protection Bureau of Historic Preservation March 30,- 1983 Page 4 are considered, the changes in the view sheds are more appro-priately evaluated as negligible.

To summarize, minor changes in the view sheds of historic sites may result from the proposed Cromby-Plymouth Meeting, Cromby-North Wales, and Limerick-Whitpain lines. However, when these changes are considered in relation to current viewing conditions, including existing transmission lines, industrial development, and other negative elements, the changes are insignificant. Ac-cordingly, the sites are not expected to be visually arrected by the proposed lines. The Limerick-Cromby line will produce visual intrusions to the historic sites listed in Table 3 of the enclosed report. However, these intrus' ions can be success-fully mitigated as discussed in pages 13 through 16 of the en-closed report. Accordingly, the Limerick-Cromby line is ex-pected to have no adverse effect on the historic sites.

mitigated as discussed in pages 13 through 16 of the enclosed report. Accordingly, the Limerick-Cromby line is expected to have no adverse effect on the historic sites.

I trust the above discussion and .the enclosed, report provide sufficient information to resolve all remaining areas of con-cern. Please call or write if you have questions regarding any aspect of the project. We would be happy to meet with you in Harrisburg or on-site to further discuss the project. As I mentioned on the phone, PE is anxious to satisfy NRC Operating License and PUC siting requirements as soon as possible. It would be most unfortunate if PE faced serious project delays despite their efforts to protect the area's cultural resources.

Thank you-for your assistance in seeing the project to a con-clusion satisfactory to all parties concerned.

Sincerely, J MI NE CIATES, INC.

Thomas L. Struthers Project Manager TLS/pjm Enclosures 4

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Donna Williams, Chief Div. of Planning and Protection Bureau of Historic Preservation -

March 30, 1983 Page 5 References Cited:

Struthers, Thomas L. and Karyn L. Zatz 1982 An Investigation of Potential Visual Effects Upon Previously Recorded Historio sites in the Vicinity of Proposed Limerick Transmission Lines, Montgomery and Chester Counties, Pennsylvania. Report sub-mitted to Philadelphia Electric Company by John Milner Associates, Inc.

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