ML22297A158
| ML22297A158 | |
| Person / Time | |
|---|---|
| Site: | Hermes File:Kairos Power icon.png |
| Issue date: | 10/18/2022 |
| From: | Jennifer Davis NRC/NMSS/DREFS/ENRB |
| To: | - No Known Affiliation |
| References | |
| Download: ML22297A158 (3) | |
Text
From: Jennifer Davis To: Elizabeth Toombs Cc: Kennedy, Ellen P; Tami Dozier; Ashley Waldron; Peyton Doub
Subject:
RE: RE: RE: RE: RE: RE: Password for Kairos Cultural Resource Files Date: Tuesday, October 18, 2022 1:39:10 PM Attachments: THC and TDOA Comments - ML22285A203.pdf
Afternoon Elizabeth,
Apologies for my delayed reply, I was out of the office on annual leave. Thank you for your questions. Here are the responses. If you would like to discuss further, please let us know.
Has the proposed Area of Potential Effects been subject to an archeological survey? I am assuming not based on Section 3.6.3 in the EIS. The 1995 Jacobs report provides coverage for the proposed APE, but it appears to be reconnaissance for known sites only.
No archaeological surveys have been conducted of the APE. Archaeological surveys were not conducted for this effort because there is documentation indicating that the project APE is extensively disturbed. No archaeological resources are known to exist or likely to exist within the project APE or within the East Tennessee Technology Park security fence as a result of this disturbance. According to the DOEs 2011 Environmental Assessment (DOE/EA-1640) and associated NHPA Section 106 consultation, the APE has been extensively disturbed by past activities including cut and fill operations which occurred during construction of the K-25 site and associated facilities (Buildings K-33 and K-31), and later decontamination, demolition, and decommissioning activities that occurred as part of remediation of this area, which has resulted in extensive disturbance of this area. Other evidence of disturbance was provided by the applicant and is referenced in other sections of the draft EIS: Section 3.3.1.1: Surface soils were previously reworked to accommodate the K-31 and K-33 building construction and their subsequent demolition and removal. After decontamination, decommissioning, and demolition, the slabs of the former buildings were removed or grouted into place to accommodate reindustrialization of the Hermes site (Kairos 2021-TN7880 l Sec 3.3.3). Portions of the former building foundations have been encountered less than 12 ft below the ground surface (Kairos 2021-TN7880 l Sec 3.3.3.3). Draft EIS Section 3.3.2.1 - During past decontamination, decommissioning and demolition of the former industrial facilities on the Hermes site, the upper 10 ft of surface soils were removed.
Is there a Cultural Resource Management Plan available? The EIS notes availability as Reference 1, but I did not locate it in the EIS.
The applicant referenced, DOEs Oak Ridge Cultural Resources Management Plan (Reference 1) in its Environmental Report to help summarize previous historic and cultural resource investigations conducted on and in the vicinity of the Oak Ridge Reservation and identify resources recorded at various locations across the Reservation. None of the resources identified within the ER are located within the direct effects area of potential effect. The DOEs Cultural Resources Management Plan was available to NRC staff via a reading room. To obtain a copy, we would need to contact DOE directly.
DOEs completed an Environmental Assessment (DOE/EA-1640) and associated NHPA Section 106 consultation prior to transferring the land and facilities within the East Tennessee Technology Park to the Community Reuse Organization of East Tennessee (CROET). According to DOEs Environmental Assessment, no prehistoric archaeological resources are known to exist within the East Tennessee Technology Park, which also includes the proposed Hermes site.
The proposed footprint of disturbance for the Hermes project is composed entirely of land that was previously used for industrial purposes (i.e., brownfield). No historic and cultural resources are known to exist within the proposed project area due to the massive cut and fill excavation activities associated with the construction of the former K-25 site and associated facilities (i.e., Buildings K-33 and K-31) and their subsequent decontamination, demolition, and decommissioning.
As discussed in Section 3.5.2 of the draft EIS, the applicant is required by deed restrictions to develop an Archaeological Monitoring and Discovery Plan that would establish stop work and notification procedures to address the unexpected discovery of human remains or archaeological materials. As of the environmental audit, Kairos has not developed its Archaeological Monitoring and Discovery Plan, but stated that these procedures would be in place prior to commencing ground-disturbing activities. If human remains or archaeological resources were discovered, work would cease in the area, and notifications would be made in accordance with Tennessee law (T.C.A. § 11-6-107 et seq.-TN7938).
Are there comments available for this currently proposed project from the Tennessee State Historic Preservation Office? If so, can you provide a copy of the comments.
Yes, the THC provided its comments by letter dated September 29, 2022. In its letter, THC stated that the project will not adversely affect historic properties, and has no objection to the implementation of this project as currently planned. We have attached their letter for your reference.
Please let us know if you have any questions.
Jennifer
Jennifer A. Davis Senior Environmental Project Manager Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission (301) 415-3835
From: Elizabeth Toombs <elizabeth-toombs@cherokee.org>
Sent: Thursday, October 13, 2022 5:15 PM To: Jennifer Davis <Jennifer.Davis@nrc.gov>
Cc: Kennedy, Ellen P <Ellen.Kennedy@pnnl.gov>; Tami Dozier <Tamsen.Dozier@nrc.gov>; Ashley Waldron <Ashley.Waldron@nrc.gov>
Subject:
[External_Sender] RE: RE: RE: RE: RE: Password for Kairos Cultural Resource Files
Resending to include Ashley Waldron who is also listed in the recently received request.
- Wado,
Elizabeth Toombs, Tribal Historic Preservation Officer Cherokee Nation Tribal Historic Preservation Office PO Box 948 Tahlequah, OK 74465-0948 918.453.5389
From: Elizabeth Toombs Sent: Thursday, October 13, 2022 1:26 PM To: 'Jennifer Davis' < Jennifer.Davis@nrc.gov>
Cc: Kennedy, Ellen P <Ellen.Kennedy@pnnl.gov>; Tami Dozier <Tamsen.Dozier@nrc.gov>
Subject:
RE: RE: RE: RE: RE: Password for Kairos Cultural Resource Files
Good Afternoon, Jennifer:
I have a couple of follow-up questions based on the EIS and reports.
Has the proposed Area of Potential Effects been subject to an archeological survey? I am assuming not based on Section 3.6.3 in the EIS. The 1995 Jacobs report provides coverage for the proposed APE, but it appears to be reconnaissance for known sites only.
Is there a Cultural Resource Management Plan available? The EIS notes availability as Reference 1, but I did not locate it in the EIS.
Are there comments available for this currently proposed project from the Tennessee State Historic Preservation Office? If so, can you provide a copy of the comments.
Thank you for your time and any additional feedback. Please let me know if any clarification is needed.
- Wado,
Elizabeth Toombs, Tribal Historic Preservation Officer Cherokee Nation Tribal Historic Preservation Office PO Box 948 Tahlequah, OK 74465-0948 918.453.5389