ML23199A280
| ML23199A280 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/03/2023 |
| From: | Beimers S Nuclear Management Co, State of MN, Dept of Admin., State Historic Preservation Office |
| To: | Martinez N NRC/ADM/PMAE, Office of Administration, NRC/NMSS/DREFS/ENRB |
| References | |
| Download: ML23199A280 (1) | |
Text
July 3, 2023 VIA E-MAIL ATTN: Program Management, Announcements and Editing Staff Office of Administration Mail Stop: TWFN-7A60M U.S. Nuclear Regulatory Commission Washington DC 20555-0001 RE: Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1, Subsequent License Renewal Application (Docket No. 50-263)
Wright and Sherburne Counties, Minnesota SHPO No. 2022-1087 To Whom It May Concern, Thank you for initiating consultation regarding the above-referenced federal undertaking. Information received in our office on March 16, 2023 has been reviewed pursuant to the responsibilities given the State Historic Preservation Officer by Section 106 of the National Historic Preservation Act (54 U.S.C. § 306108) and its implementing federal regulations, Protection of Historic Properties (36 CFR Part 800).
We have completed a review of your letter dated March 13, 2023, a submission which included the following documents intended to initiate Section 106 consultation with our office:
- Enclosure 1: Monticello Nuclear Generating Plant Area Map;
- Enclosure 2: Monticello Site Layout and Site Boundary on Aerial Image; and
- Enclosure 3: Area of Potential Effects on USGS Quad Map.
We understand by your March 13th letter, and also per our follow-up consultation call with NRC staff Nancy Martinez on May 26, 2023, that your agency intends to comply with Section 106 concurrent with the agencys review of the federal undertaking under the National Environmental Policy Act (NEPA).
Pursuant to 36 CFR 800.3-5 it is the federal agencys responsibility to define the federal undertaking; define and document the Area of Potential Effect (APE); identify historic properties within the APE that may be affected by the proposed federal undertaking; and assess the undertakings potential to cause adverse effects to historic properties within the APE, if any.
As noted in your March 13th letter, from March 2022 through February 2023, our office consulted with Northern States Power Company/Xcel Energy (Xcel) regarding the companys initial efforts to identify an appropriate area where historic and archaeological properties may be affected by the license renewal, as well as their efforts to survey and evaluate the Monticello facilitys historic significance and integrity. Since there was no formal notification by the federal agency authorizing Xcel to initiate Section 106 consultation with our office regarding the federal undertaking, we made it clear to Xcel that our review and comments were meant to inform any future Section 106 review process by your agency and, therefore, opinions made during this informal consultation may differ from formal determinations and findings made by NRC in that review process.
While your March 13th submission provides baseline information regarding the project site and proposed operating license renewal, you have not provided information sufficient for our office to complete the Section 106 review at this time.
MINNESOTA STATE HISTORIC PRESERVATION OFFICE 50 Sherburne Avenue Administration Building 203mnshpo@state.mn.us Saint Paul, Minnesota 55155 651-201-3287 mn.gov/admin/shpo AN EQUAL OPPORTUNITY AND SERVICE PROVIDER
Our comments and recommendations for subsequently completing the requisite Section 106 steps are provided below.
Define Federal Undertaking and Area of Potential Effect We understand by your March 13th letter that the undertaking subject to review under Section 106 of the NHPA involves NRC renewal of the federal operating license for the Monticello Nuclear Generating Plant, Unit 1 (Monticello) for an additional twenty (20) years through September 8, 2050.
We understand that your agency has defined the corresponding Area of Potential Effect (APE) to include geographic areas within the Monticello site boundary, as well as transmission lines up to the first substation, that may be affected by activities associated with continued plant operation and maintenance and/or refurbishment activities. At this stage in Section 106 consultation and based upon our minimal understanding of current operations at Monticello, we agree that the APE as described in your Marcy 13th letter and documented on Enclosure 3 is consistent with how Xcel defined the APE during informal consultation and is appropriate. The APE may need further refinement as the federal undertaking is further defined.
Due to the fact that we are not familiar with nuclear generating plant operations and maintenance, specifically what types of effects these activities may have on the built environment and/or land areas, it will be important for your agency to further clarify and define, both for our office and other consulting parties, the scope and nature of nuclear generating plant operations and maintenance, and also what refurbishment activities may entail, so that we may have a clearer understanding of potential effects to historic properties, if any, and further justify the agencys APE definition.
Identification of Historic Properties Historic/Architectural As mentioned above, since the Monticello facility was completed and began operations in 1971, the property met the minimum age requirement to be eligible for listing in the National Register of Historic Places (NRHP) and in our April 29, 2022 letter to Xcel Energy our office recommended intensive level survey and evaluation of the property.
In January 2023, Xcel submitted the Phase I-II architectural history survey and corresponding property inventory forms for the Monticello Nuclear Generating Plant complex and individual properties within the complex. We completed a thorough review of the survey documentation, and, in our February 27, 2023 response letter, we provided the opinion that we agreed with the consultants recommendation that the Monticello Nuclear Generating Plant [WR-MCC-052] lacks significance under relevant historic contexts and therefore does not appear to be eligible for listing in the NRHP as a district. We also agreed with the consultants recommendation that none of the twenty-eight (28) individually surveyed properties met the criteria for individual listing in the NRHP. This opinion was based upon documentation provided in the survey report and corresponding forms. We recommended further revision and final submittal of the inventory forms in our February 27th letter and on May 15, 2023 we received electronic versions of the final survey report and Minnesota Multiple/Individual Property Inventory Forms for all surveyed properties.
Aside from the Monticello Nuclear Generating Plant, it will be important for NRC to clarify the level of effort the agency intends to meet in order to identify all historic/architectural properties which may be eligible or ineligible for listing in the NRHP within the APE.
Archaeology As indicated in Xcels literature review in mid-2022, there are several recorded archaeological sites within the APE for the proposed undertaking.
Xcel has previously communicated to our office that there is no need for an archaeological survey for the relicensing effort. Based upon our understanding of the scope of the proposed federal undertaking, we generally agree that relicensing of Monticello facility does not require an archaeological survey due to the extensive existing disturbance created when the facility was constructed in the late 1960s to 1971 and also that no new construction will occur as part of the relicensing.
However, we would appreciate the inclusion of documentation that describes and/or shows the horizontal and vertical extent of these disturbed areas within the site boundary and a clearer understanding that the relicensing would not result in any future ground-disturbance beyond what has already been documented as thoroughly disturbed. We understand that Xcel is committed to performing environmental review including cultural resources evaluation for any ground disturbing activities and that this should include an archaeological survey in areas that are not previously disturbed.
Please provide a map indicating the areas within the site boundary where Xcel is committed to performing an archaeological survey due to lack of previous ground disturbance. This documentation would serve to support any NRC determination that the level of effort to identify archaeological resources within the APE is appropriate in relation to the scope and nature of the federal undertaking, as it is currently proposed.
Public Notification and Consulting Party Review While several references pertaining to public review and input into the federal licensing process are mentioned in your March 13th letter, and we assume there will be robust public notification through the concurrent NEPA review process, your letter does not provide any specifics regarding agency identification and engagement of other consulting parties in the Section 106 review of the federal undertaking pursuant to 36 CFR 800.2(c)(3-5), including Native American tribes pursuant to 36 CFR 800.2(c)(2). Also, we recommend that your agencys public engagement/notification through the NEPA process, including any public meetings and documents issued for public review, clearly indicate the concurrent Section 106 review and specific focus of public participation in that review consistent with 36 CFR 800.2(d). Please provide information regarding consulting party participation and public notification in any subsequent correspondence submitted to our office.
We look forward to continuing consultation regarding the proposed undertaking. Pease contact me at sarah.beimers@state.mn.us or (651) 201-3290 if you have any questions regarding our review of this project.
Sincerely, Sarah J. Beimers Environmental Review Program Manager Cc via email:
Nancy Martinez, NRC