ML20090J471
| ML20090J471 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/30/1982 |
| From: | Weichman M MISSOURI, STATE OF |
| To: | Wambold D UNION ELECTRIC CO. |
| Shared Package | |
| ML20090J475 | List: |
| References | |
| NUDOCS 8507010624 | |
| Download: ML20090J471 (50) | |
Text
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'T*- ^ Decomber 30, 1982 .
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Da vid .1, Wambold Supervisir.g Biologist Environmental Services tinion Elect ric Company P.O. Box 149 5t. Louis, Missouri 63166 Re: Draf t Reports, Cultural Resources Survey and Managenent Plan, tinion Electric Callaway Nuclear Power Plan, Callaway County, Missouri C
Dear Mr. Wembold:
D O The Missouri Historic Preservation Progran has reviewed the draft 14R2 report s
entitled "A Cultural Resources Mana enent Plan for Residential lands at- the Union Electric Company Callaway Nuc ear Power Plant, Callaway County, Missouri" y- and "A Phase 1 Cultural Resources Survey and Assessmant on Residential Lands at Union Electric Company's Nuclear Power Plant, Callaway County, Missouri".
._"_J Based on this review, we have the following connwnts:
Iyso- 1. A completed Missouri Historic Preservation Program's cultural Resource M Survey Project Summary Sheet accorpahted by appropriate ll.S.G.S. topo-3@
g s graphic maps must be provided to this of fice.
- 2. The federal agency involved should be identified in the abstract, intro.
4..* duction, and on the title page. In this instance, the Nuclear Regulatory Commi ssion (NRC)' is the f ederal agency.
O~9 a. The tern cuitura, researce elenent , as utinzed in the Ahstrect and elsewhere in the report is not a generally accepted term. It is recom-D$
4r mended that " property" or " site" be substituted for *elenent".
LLJ o 4 Appropriate. legend.;, including quadrangle names, scale, north a rrow, etc. ,
']j3 must be -included on all 11,5.0,S, topographic naps within the report. Also g2 all maps are poorly reproduced. This should be corrected.
.y 5. Site descriptions are difficult to follow as presently organized, tial numbering would be far superior for locating a specific site descrip-Sequen.
C- c.o tion. Discussions of impacts to sites and recommendations are necessary LLJ t2 and should aise be included f or each individual site.
_4 6 Site descriptions should nention, at least in the broad category (upland . .
C preirie etc.1 what other resources might be available, i.e. subsistence '
D resources, lithic resources, etc. It is suggested that an estinate be nade O8 ' t ' "' "' t " " a f t h" ' ' '" ( ' " $ ) ' " d" 'd - ' " **"""'*
according to angle and wear,' indicate hide working vs. wondworking.
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- 7. Pages 186-199. As knapping and sharpening were continual and f requent. ..
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]h pursuits of prehistoric populations, one could just as well describe any,,,
site as a knapping station.
l R. Map 16 is too small of scale to be readable. Also, on all maps sites must l include at least county designations as well as site number.
1 Chrisiopher S. Dond Governor Division of Parks and H;sioric Preservoiion Fred A. Lofser. Director John Karel Director l
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+ - [9. Page 4.t These figuro headings are not sufficiently complete to stand by i themselves and should be clarified.
- 10 : Page 16, 3rd' paragraph.' It is questioned that this is a Winterset forna-
' tion chert- (see comment 40).
- 11. Page 78 3n. Caution should be enployed in utilizing environmontal data f rom southwestern and southeastern Missouri in-order to attempt to use
, environmental- regimes in central Missoort at the edge of_ the Prairie-Pen-insula. While much of this may be applicable to northern Missouri, it shnold be-pointed out that the project area is not even in the same enviren.
mental area.
- 12. Page 31. It'should he noted that although there is evidence of nan in the New World as early as 22,000 B.P. , there is no conclusive evidence f or-Early Man in Missouri,
- 13. Page 31,-1st. paragraph. The report f ails to reference the recent work at
. Arnold kesearch Cave which was conducted by the University of t'issouri -
Columbia (O'Brien et al), as well as the- recent Morer:0 River surveys (Sturdevant) and Columbia investigations -(Schnits). As this project area is-in close proxiriity, more detail should have been taken f rom these recent.
investigations. '
- 14. Page 35. The. discussion of'the Early Archaic presented by Teter & Warron (1979) on page 246 should be qualified, as elsewhere in_ Teter 6 Warren it-is called Galton, and _with a corrected date of 73904tRO B.C., it is in line with other dates f rom the other Dalton sites-in Missouri.
- 15. Page.35. 23GA14' .Hernann Site) is not Early Archaic. The single radio-d carbon date i' .dle Archaic,
- 16. Page~36. It~ should be noted that there is a significant dif ference within the Middle Archaic assenhiages f rom other sites in the area. Also, the
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Middle Archaic is well dated at the tiermann Site (Schmits 14e.?. listed as Wright -in References Cited) as vell as at 73B0964 (Schmits19RP) 17-Page 38. Teter ., Warren (1970) have conflicting inf ornation.
Tabin 8.1, page 234 of- Teter A Warren,f does not substantiate the dates presented on
- l. 'pages 247-248. The dates of 2100+100 B.P. f ron the liiddle Woodland level were rejected (Teter & Harren 1974:235) and there are no dates anywhere in the text suggestive of an Early Woodland occupation.= In addition, Klippel's _(lo72) Collins Site is a poor example of Early Woodiend. O' Brie +
(1979:63) as well as others believe that the site is nulti-component Archaic / Woodland. Most.of the features were intersected at the base of the plowzone,: and it cannot be determined what the levels of pit origins were. While the cited dates are generally accepted as Early Woodland, the L
dates for Early Woodland have not been f.irnly established in Missouri.
L Without pottery, calling it Early Woodland is-questir.nable as the' basis of defining any Woodland corponent is the presence of Woodland pottery. Alto
- there is no basis for equating contracting stemmed projectiln points with Early Woodland in Missouri.
- 18. Page 30 Non-Hopewell Middle Woodland assenhiages are connnn in Missouri, i While Hopewell occupations occur to the east and west along the Missouri
- o,- Riher, most of thn state is dominated by non-Hopewellina Middle Woodland-E' s ' . ' ,
_ period sites, it would be appropriate t o acknowledge this' situation.
- 19. Page;49.- The National Register nomination for 23CY20 was sent to the
. Department of the-Interior but rnturned because of insuf ficient documan-tation. Thus..it is still considered to be a pending nomination; it has not.been " refused".
- 20. Page 133. 3rd 3aragraph. When the-authors refer to an area "...suf ficient to determine tie number of cultural resources present", what f actors did ,
they use to determine suf ficiency of areas surveyed? Also does the manage-ment plan take into consideration cultural resources which are presently unidentified, buried or otherwise currently unknown sites within the project area?
21._ Page 134, 3rd paragraph, lines 13-15. Stability does not in itself promote
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grcwth and complexity. Society does not change it ifq is stable. Only-through forced change in adaptive subsistence potential does any society alter its technology (i.e. means of effecting adaptation to an environnant) or,- especially, its social organization.
- 22. Page-134, 3rd paragraph, line 11. " Adaptation" and " adjustment" are not the same thing.
- 23. Page: 135,1st uragraph. Technoingy'and settlement patterns have a direct bearing on suc1 "inapproprinte" topics as social organization and subsis-tence.
P4. Page 136-137.- last paragraph. Pleaso provide an indopth explanation of why
.the authors assume that prinarily only a general hunting and gatherin( form of subsistence was prevalent for the prehistoric inhabitants within the
_ project area.
- 25. Page-lan,1st paragraph. Were the isolated finds also mapped in detail and~
reported to the Archaeological Survey of Missouri? -
- 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) of definitions, if appropriate.
?,7. Page 140, 3rd paragraph. As organics can he quickly leached f rom the soil-and usually are preserved readily only when quickly buried, the prest nce of
-organics to define habitation sites should be used cautiously.
- 28. Page 142, 3rd paragraph, line 0 - What is the basis for this tentative-scaling?- Some basis for this is required other than species discussions.
AL1tnited number of species with high volume may yield higher bionass.
Some- form of index would he better than this (e.g. quantity by environ-mental areas). ,
- 29. Page 145. What was the rational for limiting the bypothesis presented to -
. hunter-gatherer subsistence / procurement strategies only?
- 30. Page 145-146 . Hypothesis I cannot be tested until sone index for scaling potential resources is accorplished. Simply to say that you assume re-em e e em t w- w s -m -.+w- n ,---e s + a----e e-g,syy ar-nry-, y e 3u--*--ww ,- w ,-w,. . .-- --e-- c+-+w-- 3---
source areas have *3n ordar may hava no basis in reality. Also, site
. 'ncation i is e result of a matrix of choitai by abnriginal populations.
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Ono factor by itself nay not have a najor effect on choice of site loca-tion. This hypothasis is simply not testa'ble until more detailed work is done.
- 31. Page 146. Hypothesis 2 suf fers the sane drawbacks as the first hypothesis.
- 32. Page 146 Hypothesis 3 is f ar too broad to have nuch validity. The hypcthesis it couched in terns of a general law rather than a suitable, astable hypothesis.
- 33. Page 146. Hypothesis 4 suf fers f rom much the samt problem ts hypothesis three.
- 34. Page 145-147. The hypotheses presented are inappropriate, broadly general-ized, and f ail to address a' single valid research question formulated by other intensive ir.ve stigations in central Missouri, e.g. Schmits, O'Brien et.al. etc.
- 35. Page 161. A topographic nap of the project area indicating percentaga of vegetation / visibility and arees actually surveyed with approximate loca-tions of shovel tests should be included.
- 36. Page 163,1st paragrt? h. Detailed sketch maps of all sites located durin:
this investigation should be included within the main text or in an appen-dix.
- 37. PADe 175-183. .The detail of discussions prasented in the " Chert Pesources Survey Section" is considered to be too extensive for this level of inves-tigation. It would oe more appropriate as an appendix.
- 38. Page 201. Discussien of sites in survey area are listed by environnental zones rather than sequentially. This is confusing when trying to locate a specific site. Furthernore, we ha vp some serious reservations about the zone referred to as " Dissected tipland/Bottomland Forest Edga." This tern appears to consist of a combination of two and possibly three vegetational connunities, which probably consists of slope forest, floodplain forest and edge communities.
- 39. Plate 12, page 275 and others. Many of the tools are referred to as pro-jectile points .in the text but raf erenced as " projectile points / knives" in the illustrations.
- 40. Page 2R3 and 357. Hinterset limestone is a nember of the Kansas City group which is known te nutcrop in western and northwestern Missouri. It is questioned that Winterset chert outcrops 1R km north of ha Callaway project area, if it does, this would be an anomaly worth 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 f rom the project area.
- 41. Page 207, Plate 13c, This is not Graham Cave Notched.
- 42. Page 352. Again, as there is no firn basis for ranking environmental areas, this test is nearly meaningless.
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.' [ 43. Page- 352. ' Environment al zones were ranked'in decreasing order of f ood im-portance. What is thn basis for- this ranking? We question that a prairie u
+- f orest edge = zone would have nore resourt.es than upland oak hickory _ f orest.
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The possible incorrect orderinD of. these zones may account for the lack of-significant correlation between food resource potential and site density.
- 44. Page 355. paragraph 3. We question the use of the term " social compicx-
.ity". - A large number of dif ferent site typas _does not necessarily equate with social complexity. Hunters and gatherers usually_ will have a greater number of site types than will nore "cocplex" social organizations.
AS. page 355. Hypothesis 2 - This is not a test but'is simply intentive obser-vation.
- 46. PaDe 356._ Use of the t erms " field camp" and "linited activity sites' should be explicitly- defined.
- 47. Page 357. Hypothesis 3 - Same- as coment hypothesis 2. (No.A5).
4R. Page 357. What 'is the basis f orf-^# identification h) of Winterset chert in Audrain and lionroe Counties? . '
- 49. Page 3R9, line 1. This is not e Graham Cave Hotched point.
- 50. Page 391,- paragraph 2. Granthm (INf:179) says nothing about blending v Late Archaic and Early Unodland.
- 51. Page 342. Grantham (1c77:Pno.pn1) - This is an overview of the entire Removal of the
. drainage. it does not refer to tha reservoir area alone.
word " prominent'_' is recomended.
- 52. Page 401. is-this project designed to inventory and evaluate or to inven-tory and make recommendations for nvaluation of potentially National Register eligible resources? There appears to be _a lack of attention pa.id to proper Crit terminology- or scope of work. ,
These criteria are heavily weighted toward large, dense
- 53. Pa sites.ge 417 alR.It isL seriously. doubted that this has- any basis-in terms of- po-tentialf research applicability. :This _isian arbitrary choice of criteria.
'Without reference to any specific research design which can successfully f exclude certain site, af ter they have been adequately evaluated, these
- criteria _ are neaningless.
- 54. Page 418.: Twenty-five sites are considered potentially significant and National Register eligible.. What is the basis for determining the re-mainingLproperties non-eligible' This.should be clearly documented on a site hy: site basis. -
- 55. Page A36 If suf ficient data-is available to make National Register eval.
"uations, i.e.-deternination of National- Register eligible and non-eligible-as called for in the scope of. work, we question the recomendations for further Phase 11 testing. It would appear that the author is attempting t-generate more work.
- 56. Page 436. The term " conservative protection boundary zone" should' he defined.
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Regarding Historic Section of tlin report, the first part of this section is basically fillor and is irrelevant to the area in quostion. A rehash of the history of Missouri gleaned f ron not dated sources is not needed, and snakes no contribution whatsoever. A fuli 2n pages passes before we are finally intro-e duced to Callaway County. But even af ter this point the study shif ts in and out of focus, occasionally discussing Callaway County, relying nainly en outdated sources and the rest of tho time giving the unnacessary generic history of various thenes in Missouri history such as henp growing, slavary, the Civil War, railroads, agriculture, etc. The only specific study of slavery in Callaway Cc,unty, Scarpino's, was cited but obviously not reed; nor was Scarpino's Missouri H{storical Review article on this subject.
It is obvious that the authors of this section preferred to produce a super-ficial piece of work that has littia value f ron a cultural resource nanagenent point of view and which will offer no guidance whatsoever towards evaluating the material culture of the region. The only reliable research tonit for doing the type of history needed f or the specific project arP Censu; records. For the years 1850, 60, 7n, acd 80, exact figures f or the individuals residing with-in the survey area could ' oe computed including fantly sizes and ages, nunber of slaves, real estate holdings and values, quantities and values of livestock and crops. Two things that would probably be revealed are that residents within the survey area had fewer slaves than the norm f nr Callauay County, and that they, as did nost southerners, practiced diversified agriculture and raised little herp or tobacco. As it is, the authors have simply, not provided a neaningful context with which to conf ront the cultural resources in the crea.
The Historic Section is f ar short of the state of the art.
In respect to the Architectural nyerview, it is nore focused on the project area than the previous section and based on better sourcos such as fiershall, Scarpino, and the agricultural census. Relative to the inventory forns, we were happy to see the excellent floor plans and photographs. A question could be raised concerning the plan of Inventory H. Dotted lines should indicate the original fenestration which was likely windod-door door-window, and, if so, this structure is firmly within Little Dixie building tradition. Having noted the above, it is necessary to point out some serious weetnesses. As in the Historical Section, the context is poorly estabitsbed. The developnent of the region's architecture is presented too simplistic 1y, and suggests that the author does not have a firm grasp of the subject. The historical photn collection at tha State Historical Society seened not to have been consulted, nor was the Historical Amarican Buildings Survey (HABS) records f or Callaway County, which is on nicrofich in our of fice. Here are shown views of such early double pen houses as the Holman House near Mokane, which indicate the historical depth of the_ reginnal context of the later double pen houses of the survey area. In Portland are other early exarples, and there is an excellent double pen "1" house south of Readsville, mention of which would have provided a sharper context. The examples in tha study area are at the end of a long tradition of southern architecture in the region, but the sense of this tradition does not seem to be fully understood o'r appreciated by the author.
The bibliography also indicates that the authnr is not acquainted with the basic literature on vernacular southern architecture. And there is no specific context of the project area to contrast against the vague regional one based on Scarpino and Mayer and Hanner. No history of the occupants of a single house within the survey area is given, nor is there any indication that the slave schedules or agricultural cansus records for individuals residing within thn area were consulted to denonstrate that the authors genaralizations on these subjects are valid and relevant to the project area. No profile or analysis of l
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At t he end of this report we
- the actual f orne cads wit hin t he ar en is of fered.
'..' - still tnow virtue 11y nothlog about t.he actuoi and re'ai people who inhohited tho project area over tine, and yet we have reans of padded and irrelevant paper work.
As for National Register elipihility, struttures illustrated on Inventory forms $2, 4, 11, 12, 14 and probably ?n and P1, architecturally represent frag-ments of a wide-spread regional southern culture that persisted f rom the ini-tial settienent period thrnugh ca. W 1. Their significance derives f rom this f act and is est ablished as much by the f orm (flonr plan) as by the f abric (even if that f abric is clad in nndern Siding). An appreciation of that con-tert is theref ore essential to th" eviluation, from a National Register eligi-that bility standpoint, of these hunble and sinple structures, linf ortunately,d context is not cletely addressed in the report. ..
in sunnation, it is the opinion of the Missouri Historic Preservation Pro \
gram, that the aforenentioned propmties are pntentially eligthie f or inclusion g in the National Register of Historic Places as inportant extant examples of f g traditional southern vernacular architacture in the Trans-Mississippi West. /
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/ In conclusion, the Missouri Historic Preservation Progran does not agrec with the reco"mondations prof fered in the report concerning the flational Reg-ister of Historic Places eligibi1My of the cultural resources located within the Callaway Nuclear Power Plant project , area. The report f ails to provide suf ficient explicit docunnntation t o suppn'rt the determination of eligibility or non-eligibility on an individac1 hesis for the cultural r esources involved. ;'
We feel major fundenental problen f er this are the eight ":riteria" presnnted on page 417 41 A to evaluate culturri properties to ascertain National Register -
eligibility are not' the crit.eria SM f orth in 36CFR part 60 and utilized by the Department of the Interior in determining National Register cligibility but are arbitrary in nature. Therefore, thy are inappropriate in determining eligibility f r.oglegal f ramewort.
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Furthermore, we do not .helieve t hat the statenent presented on pages 435 436 that a National Register District is not wrrented hoccuse of it is "not in tht best interest of U.E. Company" is not suf ficient just* fication, neither f rom a professional point of view or based on the Criteria set forth in 36CFR part 60. It is obvious that the authors place the opinion of the client over the importance of the protection of the cultural resources.
In addition, the report f ails in fulfill Section 5.D(h) of the Scope of Work which statts that the contractor..."condtirt suf ficient investigations to satisfactorily evalutate such sites [ discovered] in terms of published criterir of eligibility for the National Register of Historic Places... All sites locatet within the study area must he fully avaluated and complete documentation for-warded in order to substantiate recomendation of eligibility (or non aligibi-lity) for the National Register.* However, on pages 436 and 44n of the report it is recomended that Phase 11 archaeological testing be conducted for sites which the authors feni are potentially eligible for the National Register.
This evaluation, in accordance with the Scope of Work, should have already beei comleted.
i in regards to the Cultural Resource Management Plan, we are unable to i provide substantive comments as we are in disagreement with the authors as to However which properties are eligible-f or inclusion in the National Register.
l based on prolininary review, we are in general agreement with the section on l
'.[' hanaginent Recomendations and Guidallnes, with the af orementioned exception-which specifies properties as eligible.-
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lt is the opinion of the Missouri Historic Preservation Progrrm that cni-lettively, the archaeologice) and erchitectural resources located within tbn Callaway Nuclear PNer Plant project area constitute an hiLtoric district.
' Furthermore, contrary to the authors basic assumption. .tfie r7ev Wpror.est I nandated by Section 106 of the National _ Historic Preservation Ar.t is timely and efficient. Given the significance of the cultural resources present within the pro.iect area, we _ feel that the protection of these non-renawahle resource supercedes any " ..possihie inconvenience which may occur from state and federal review"(paga m) and by enpinying a district, will greatly redurr-future review processes andd will result in substantially less paper work than dealing with. sites individually.-
It is the recomenJation of this of fice that the draft report and managw nent plan he revised to addres's the. aforementioned comments, including explicit documentation supporting National Register eligiblity or non-eligibility of the cultural properties involved and the report returned to this of fice in draf t Pending corpletion of the Section 106 f orm f or further review and coment.
process, tinion Electric should ref rain from taking nr sanctioning any action or naking any irreversible or irretrievable comitment that enuld rescit in an -
adverse effect on any potential National Register eligible property or which would foreclose the consideration of modifications or alternatives or minimize to the such adverse proposed undertaking that could
- avoid, hitigatt:,
effects.
If I can he of further assistance, please call nr write.
Sincerely, DIVIS10H OF PAR S' AFD H15ROTIC PRESERV ATION
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- Michael 'S Weichman Chief, Review 1, Compliance MW:c1 cc: Ron Anzalone-
- jHichaelGuinn Dr. ' t.nuis Bykoski I
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