ML21288A408

South Carolina State Historic Preservation Office Comments Westinghouse Columbia Fuel Fabrication Facility License Renewal Draft Environmental Impact Statement and Section 106 Review

ML21288A408
Person / Time
Site:	Westinghouse
Issue date:	09/21/2021
From:	Harrison A State of SC, State Historic Preservation Office
To:	Diaz-Toro D NRC/NMSS/DREFS/ERMB
References
Download: ML21288A408 (4)

Text

WEC_CFFF_EIS Resource From: Harrison, Alethea <AHarrison@scdah.sc.gov>

Sent: Tuesday, September 21, 2021 11:26 AM To: Diaz Toro, Diana Cc: Johnson, Elizabeth

Subject:

[External_Sender] Westinghouse Columbia Fuel Fabrication Facility (CFFF) License Renewal, Richland County Attachments: RICH_Westinghouse CFFF License Renewal_15-EJ0022_DEIS.pdf From: South Carolina State Historic Preservation Office Please find attached our comments letter on the subject referenced project. A hard copy can be provided upon request.

Please confirm receipt of this email and attachment(s).

Please contact us if you have any questions regarding our comments.

Alethea Harrison Historic Preservation Specialist State Historic Preservation Office SC Department of Archives & History 8301 Parklane Road Columbia, SC 29223 Ph: 8038964123 1

September 20, 2021 Jessie M. Quintero Environmental Review Materials Branch U.S. Nuclear Regulatory Commission Via email to: Diana.Diaz-Toro@nrc.gov Re: Westinghouse Columbia Fuel Fabrication Facility (CFFF) License Renewal Draft Environmental Impact Statement and Section 106 Review Richland County, South Carolina SHPO Project No. 15-EJ0022

Dear Jessie Quintero:

Thank you for your letter of August 6, 2021 which we received via email on August 6, regarding the subject-referenced undertaking. The State Historic Preservation Office (SHPO) is providing comments to the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 106 of the National Historic Preservation Act and its implementing regulations, 36 CFR 800. Consultation with the SHPO is not a substitution for consultation with Tribal Historic Preservation Offices, other Native American tribes including those with state recognition, local governments, or the public. We understand that the NRC is coordinating Section 106 review with the National Environmental Policy Act (NEPA) environmental review.

The proposed undertaking is defined as a 40-year license renewal request. The Area of Potential Effect (APE) for the undertaking is defined as the Columbia Fuel Fabrication Facility (CFFF) license area boundary in Richland County, South Carolina. The NRC notes that some activities on the CFFF are not licensed by the NRC and are considered outside the scope of the undertaking. These include forested areas used for timber production, hay fields that are harvested, and an electrical substation near Bluff Road on seven acres.

In previous correspondence of December 14, 2006 and May 28, 2015 our office noted that the Westinghouse CFFF site as a whole has a very high probability of significant archaeological properties and that any future proposed expansion or ground disturbance in previously undisturbed areas should be submitted to our office for review and comment.

In November 2019 our office concurred with a finding of no historic properties affected for the installation of groundwater wells in previously undisturbed areas, as required by SCDHEC. The

contractor for the project was to follow established procedures for inadvertent discoveries of cultural resources and use ground-penetrating radar (GPR) prior to ground disturbing activities.

Since that time, members of the public and the Pine Hill Indian Tribe have raised concerns about the potential for impacts to unidentified archaeological sites within the CFFF boundary, as well as indirect effects of the operation of the CFFF to sites located beyond the site boundary. We note that a cultural resources survey is currently underway at the CFFF by a cultural resources management firm, and appreciate this effort to identify cultural resources. The survey will also formally evaluate the previously identified Denley Cemetery for National Register of Historic Places eligibility. If available, it will be helpful to include the findings and recommendations of the cultural resources survey in the final Environmental Impact Statement.

Public comments have also raised concerns about the potential for future ground-disturbing activities that do not rise to the level of significant land disturbance. Please provide a definition of significant land disturbance and examples of actions are characterized to have significant land disturbance or not. It would also be helpful to provide information about the types of actions that would require license amendments and additional consultation. We continue to recommend that our office be consulted in any future expansion or additional ground-disturbance in previously undisturbed areas.

Public comments have also provided additional recommendations for Denley Cemetery, including the potential for additional unmarked graves outside the cemetery boundaries, removal of monitoring wells in the vicinity of the Denley Cemetery, and monitoring of all ground disturbances at CFFF by a professional archaeologist.

Given the length of the undertaking, the potential for unknown historic properties, and unanticipated effects, please consider the development of a Programmatic Agreement (PA) to lay out the process for conducting future Section 106 consultation. A PA is appropriate given the time frame of the undertaking (40 year license renewal) and the potential for the project to change, as evidenced by the modification in the undertaking from 2015 to 2019 to install groundwater monitoring wells.

Please refer to SHPO Project Number 15-EJ0022 in any future correspondence regarding this project. If you have any questions, please contact me at (803) 896-6168 or ejohnson@scdah.sc.gov.

Sincerely, Elizabeth M. Johnson Director, Historical Services, D-SHPO State Historic Preservation Office