ML20091F726

Provides follow-up to 910807 Telcon Between J Hull & D Lynch on Completion of Section 106 Review for Facility Re Historic Resources Mgt Plan on Efforts Aimed at Protecting & Preserving Archaeological Sites

ML20091F726
Person / Time
Site:	Callaway
Issue date:	09/23/1991
From:	Klima D ADVISORY COUNCIL ON HISTORIC PRESERVATION
To:	Hannon J Office of Nuclear Reactor Regulation
Shared Package
ML20090J475	List: ML20090J471 ML20091F726
References
NUDOCS 9112090347
Download: ML20091F726 (2)

Text

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Advisory Council On liistoric Preservation The Old Post Ofhce Building 1100 Pennsylvania Avenue, NW. #809 Washington DC20004

$7 6 3 'T ~ l Mr. John N. Hannon Director, Project Directorate III-3 United States Nuclear Regulatory Commicsion Washington, DC 20555 Attn: David Lynch REF; Union Electric Company Nuclear Power Plant, Callaway County, Mo

Dear Mr. Hannon:

This is a follow-up-to the telephone conversation of August 7, 1991, among John Hull and David Lynch of the Nuclear Regulatory commission and Anne Weinheimer of the Council's staff regarding completion of-the section 106 review for the Union Electric Company (UEC) Nuclear Power Plant Project in Callaway County, Misscuri. _As part of this undertaking, 25 archeological sites determined to be eligible for listing in the National Register of Historic Places will be affected. Although NRC failed to complete the requirements of Section 106 of the National Histor3.c Preservation Act (NHPA) at the time of theLlicensing, following discussions with us, your office requested the Council's views regarding the Historic Resources Management Plan which had been prepared for NRC to assure the protection of'the affected sites.

After many months of consultation, the consulting parties have been unable to finalize a Programmatic Agreement that is acceptable to all partics. Therefore, it is our position that further consultation would not be productive.

Since the proposed Programmatic Agreement was not developed prior

-to the issuance of a license by NRC, as required by Section 106 of the NHPA and Council's regulations, we do not intend to provide Council comments in accordance with 36 CFR Section 800.6(b). However, we would encourage NRC and UEC to make every effort to protect and preserve the archeological sites located on the plant's property utilizing the-Historic Resources Management

-Plan. We suggest that you take into consideration the comments provided by the Missouri State Historic Preservation Officer on the plan in his letter of December 30, 1982 (copy enclosed).

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ItLis unfortunate that NRC did not request the council's comments on-this undertaking prior to issuing the-license. Despite this oversight, we-feel the UEC han made a concerted effort to implement a cultural resources management plan to avoid,.

mitigate, or minimize effects on historic properties. It' the '

future, perhaps NRC will cor. tact the Council and initiate the consultation process during the early stages of project planning so that-we can conclude the Section 106 review by executing a Memorandum of Agreement or Programmatic Agreement.

If you have any questions or need any assistance, please contact Anne Weinheimer at 202-786-0505. We thank you for all your endeavors through this lengthy review.

'pce'p ly, i

W 1 D Klima D tor, Eastern Office o Project Review Enclosure

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