ML24088A215

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Feb. 20, 2024 Xcel Energy Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information for Monticello Nuclear Generating Plant
ML24088A215
Person / Time
Site: Monticello 
Issue date: 02/20/2024
From: Hafen S
Northern States Power Company, Minnesota, Xcel Energy
To:
Office of Nuclear Material Safety and Safeguards
References
LMT-24-005
Download: ML24088A215 (1)


Text

PUBLIC VERSION

Document Control Desk L-MT-24-005 Page 3 Enclosure Index Enclosure No.

Subject 01 RAI HCR-1 Historic & Cultural Resources 02 RAI GW-5 Water Resources - Groundwater Attachment Index Enclosure No.

Attachment No.

Subject 01 1

Monticello Nuclear Generating Plant, Phase 1A Cultural Resources Literature Search and Site Visit, Wright and Sherburne Counties, Minnesota 01 2

Monticello Nuclear Generating Plant, Survey of Culturally Sensitive Plant Species, Wright and Sherburne Counties, Minnesota 02 1

Minnesota Department of Natural Resources Water Appropriation Permit 2023-2958 02 2

Minnesota Department of Natural Resources Permit Application Findings of Fact Water Appropriation Permit 2023-2958 02 3

Carlson McCain Technical Memorandum Regarding MNGP Gradient Control Well Pumping Monticello, Minnesota.

1 RAI HCR-1 Historic & Cultural Resources Supplement

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 1 Page 1 of 4 Topic: Historic & Cultural Resources RAI HCR-1:

REQUIREMENT: Section 106 of the National Historic Preservation Act (NHPA) directs Federal agencies to identify historic properties within the area of potential effect (APE). Specifically, 36 CFR 800.4(b) states that, in consultation with the State Historic Preservation Office (SHPO) and Indian Tribes, the Federal agency shall take the steps necessary to identify historic properties within the APE based on:

1.

a review of existing information on historic properties within the APE, including any data concerning possible historic properties not yet identified (36 CFR 800.4(a)(2)), and

2. information gathered from consulting parties (SHPO, Tribal Historic Preservation Officer, Indian Tribes) likely to have knowledge of, or concerns with, historic properties within the APE (36 CFR 800.4(a)(3)).

The level of effort (36 CFR 800.4(b)(1)) required for identifying historic properties is determined by the agency official and is required to be a reasonable and good faith effort for the APE and undertaking as a whole, and may include, background research, consultation, oral history interviews, sample field investigation, and field survey. Identification of cultural resources may also occur through a phased identification and evaluation approach (36 CFR 800.4(b)(2)) where memoranda or agreements, programmatic agreements, or other agreement documents and processes are followed, agreed to, and established through consultation.

In accordance with 36 CFR 800.2(c)(2)(ii), Federal agencies must consult with any Indian Tribe that attaches religious and cultural significance to historic properties that may be affected by an undertaking. The agency official shall ensure that consultation in the Section 106 process provides Indian Tribes a reasonable opportunity to identify its concerns about historic properties; advise on the identification and evaluation of historic properties, including those of traditional religious and cultural importance; articulate its views on the undertaking's effects on such properties; and participate in the resolution of adverse effects. This requirement applies regardless of the location of the historic property.

ISSUE: Section 3.8.5 of the ER states that no cultural resource surveys or assessments have been performed onsite at MNGP. Section 3.8 of the ER states that for purposes of subsequent license renewal, the above-ground APE includes the entire MNGP site, and the archaeological APE is considered bounded by the approximately 2,000-acre MNGP site, where ground disturbance might compromise the physical integrity of archaeological data.

While preparing its application for subsequent license renewal, Xcel Energy contacted the Minnesota (MN SHPO) by letter dated March 17, 2022, seeking input on the potential effects from continued operation of MNGP on historic and cultural resources (ML23009A356). In response, by letter dated April 29, 2022, the MN SHPO recommended, in part, that Xcel Energy complete an archaeological survey for areas within the MNGP site that may be subject to ground disturbance as part of relicensing (ML23009A356).

By letter dated March 13, 2023, the NRC initiated consultation with the MN SHPO (ML23069A278). By letter dated July 3, 2023, to the NRC (ML23199A280), the MN SHPO requested documentation that describes and/or shows the horizontal and vertical extent of the

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 1 Page 2 of 4 sites ground disturbance and a map indicating areas within the site boundary where Xcel Energy is committed to performing an archaeological survey. By letter dated August 21, 2023, to the NRC, the MN SHPO recommended that, absent of documentation demonstrating the extent of disturbance of the site (both vertically and horizontally) or previously surveyed areas, the APE be subject to a Phase I archaeological survey (ML23222A126). Furthermore, the MN SHPO stated that the survey need not encompass areas that are obviously disturbed by the construction of the plant and previous operations and maintenance activities at the plant.

Additionally, the MN SHPO stated that the report/documentation should meet the requirements of the Secretary of the Interior's Standards for Identification and Evaluation and should include an evaluation of National Register eligibility for any properties that are identified.

By letter dated March 13, 2023, the NRC initiated NHPA Section 106 consultation with the Mille Lacs Band of Ojibwe (Band) (ML23069A280). This letter also notified the Band that the NRC intends to comply with Section 106 of the NHPA through the National Environmental Policy Act process per 36 CFR 800.8(c). On April 12, 2023, the Band responded with a letter which provided their concerns and feedback and requested continued discussions through government-to-government consultation (ML23117A313). On July 25, and August 10, 2023 (ML23222A126 and ML23237A264), the NRC conducted teleconferences with representatives from the Band to continue dialogue and consultation. During the July 25, 2023, teleconference, the Band expressed concern that MNGP has not been subject to a cultural resources survey, particularly given the potential for burial mounds along the Mississippi River. During the August 10, 2023, teleconference, the Band requested that an inventory of culturally important plant species be conducted to determine/identify if red cedar (Juniperus virginiana) and wild rice (Zizania species) are present on the MNGP site, and to be involved in the process to select a contractor to perform an archaeological survey. Additionally, the Band requested to participate in both surveys. The MN SPHO and Band are consulting parties with the NRC and consultations are currently ongoing.

REQUEST: Given that 1) no cultural resource surveys or assessments have been performed onsite at MNGP; 2) the potential for ground disturbing activities as part of ongoing maintenance activities and operations at MNGP during the SLR term; 3) lack of information on the level of disturbance of the site; and 4) information gathered from consulting parties, the NRC requests the following:

a) Conduct an archaeological survey, which may include subsurface and pedestrian investigations, across the 2,000-acre APE. As described in 36 CFR 800.4(b)(1), the final survey scope and type, including geographic area of reconnaissance and survey technique, will be determined through consultation with the NRC, MN SHPO, the Band, Xcel, and any other consulting parties identified in the Section 106 process. After the survey has been completed, provide a copy of the survey findings and associated inventory forms, if applicable, for NRCs confirmatory review. This archaeological survey must be completed by a Secretary of Interior qualified archaeologist (36 CFR 800.4(b)(1)).

b) Conduct a survey of culturally important plant species to determine/identify if red cedar and wild rice are present within the MNGP site. Provide a copy of the survey findings when finalized.

L-MT-24-005 1 Page 3 of 4 c) Discuss any updates made to MNGPs procedures (discussed in Section 3.8.6 of the ER) used to identify, protect, and minimize the potential impact to cultural resources located within the MNGP site or new procedures developed as a result of the findings from the archeological survey and culturally important plant species survey.

Response to RAI HCR-1:

Xcel Energy is currently coordinating with the MN SHPO, the NRC, and the Band to determine what studies and procedure revisions may need to be completed. Relevant information related to cultural resource surveys or applicable procedure revisions will be provided to the NRC in a supplement as they are available.

Supplement to the RAI HCR-1 Response:

NSPM coordinated with the MN SHPO, the NRC, and the Band for the cultural resources study.

The study was completed for MNGP on January 30, 2024. The cultural resources study is provided in Attachment 1. A brief summary of the report is listed below.

The cultural resources study consisted of a site walkover that was conducted October 23, 2023, and historical research.

Records and databases at the MN SHPO, the Office of the State Archaeologist (OSA),

and others were reviewed to determine if cultural resources have been previously identified in the Project Area, along with the extent of prior investigations and potential for yet unidentified cultural resources.

The work was performed by a Secretary of the Interior-qualified archeologist who was present during the site walkover.

A member of the Bands Tribal Historical Preservation Office (THPO) was also in attendance during the site walkover on October 23, 2023.

No cultural or historical artifacts were identified during the site walkover.

There are areas outside the plant area of high potential for unrecorded archaeological resources due to the proximity of the Mississippi River.

The approximate travel path of the site walkover is included in the cultural resources report.

The three recommendations stated in the Management Summary and Section 7.0, Summary and Conclusion of the Phase 1A Cultural Resources Literature Search and Site Visit report (Attachment 1), will be incorporated into the appropriate site procedures to ensure the protection of archeological, cultural and historic resources. In addition, the NRC recently consulted with the Band to discuss the comments the Band had regarding the MNGP site cultural resource literature search and red cedar survey (NRC 2024). The Band requested that a tribal monitor be present when ground disturbance occurs outside the MNGP facility complex but within the site boundary. Therefore, to accommodate this request, NSPM will also incorporate direction into procedures to notify and invite the Band to observe ground disturbing activities that are under the control of NSPM and outside of the MNGP facility complex (i.e., outside the green and orange areas in Exhibit 29 of Attachment 1). Exceptions will be made if there is an immediate need for ground disturbing activities due to an emergency or other extenuating circumstances.

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 1 Page 4 of 4 In addition, a survey of culturally sensitive plant species was conducted to delineate populations of eastern red cedar (Juniperus virginiana) within the MNGP Project Area. The survey is provided in Attachment 2. This species is considered culturally significant to the Band as well as other Native American tribes. Presence/absence surveys were completed within the entirety of the approximately 2,000-acre MNGP Project Area. The site visits for the plant species were conducted on October 23, December 6-8, December 11, and December 13, 2023. A representative of the Band was present during the October 23 and December 6 site visits. The estimated number of eastern red cedar trees was approximately 12,000 specimens in the 2,000-acre site. The islands were included in the survey.

The Band also identified northern wild rice (Zizania palustris) as culturally significant. As the eastern red cedar survey was conducted outside of the peak growing season of northern wild rice, which is between July and early October, follow up site visits will be conducted in 2024 to document the presence/absence of northern wild rice within the Project Area. The Band will be invited to participate in those surveys.

References:

NRC. 2024. January 11, 2024, Summary of Teleconference Between the U.S. Nuclear Regulatory Commission and the Mille Lacs Band of Ojibwe. January 30, 2024. Agencywide Documents Access and Management System (ADAMS) Accession No. ML24023A090.

Associated Attachments:

1.

Westwood. 2024. Monticello Nuclear Generating Plant, Phase 1A Cultural Resources Literature Search and Site Visit, Wright and Sherburne Counties, Minnesota. Prepared for Northern States Power MN, d.b.a. Xcel Energy. January 30, 2024. 67 p.

2. Westwood. 2023. Monticello Nuclear Generating Plant, Survey of Culturally Sensitive Plant Species, Wright and Sherburne Counties, Minnesota. Prepared for Northern States Power MN, d.b.a. Xcel Energy. December 20, 2023. 26 p.

1 Monticello Nuclear Generating Plant, Phase 1A Cultural Resources Literature Search and Site Visit, Wright and Sherburne Counties, Minnesota.

PREPARED BY:

PREPARED FOR:

Northern States Power MN, d.b.a. Xcel Energy PHASE IA CULTURAL RESOURCES LITERATURE SEARCH AND SITE VISIT Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota JANUARY 30, 2024 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 1 of 67

Phase IA Cultural Resources Literature Search and Site Visit Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota Prepared For:

Northern States Power MN, d.b.a. Xcel Energy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362-9601 Prepared By:

Sara J. Nelson Ryan Grohnke, RA Dean Sather, MA, RPA Westwood Professional Services 12701 Whitewater Dr. Suite 300 Minnetonka, MN 55343 (952) 937-5150 Project Number: R0046559.00 Date: January 30, 2024 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 2 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 i l TBPLS Firm #10074302 Management Summary Northern States Power MN d.b.a. Xcel Energy (Xcel) proposes to relicense the Monticello Nuclear Generating Plant (MNGP) in Wright County, Minnesota (Project; Project Area). In support of anticipated federal environmental review, Xcel contracted Westwood Professional Services, Inc.

(Westwood) to conduct a Phase IA Cultural Resources Literature Search of the proposed Project Area. The Facility is defined as the 85-acre fenced MNGP Plant, and the Plant Support Area (175-acres). The Project Area is the Facility and surrounding MNGP land consisting of approximately 2,000 acres in Wright and Sherburne Counties, Minnesota. A site visit was also performed by Westwood staff in association with MNGP staff and a representative of the Mille Lacs Band of Ojibwe Tribal Historic Preservation Office (THPO). Westwood cultural resource specialist, Dean Sather, MA, RPA, served as Principal Investigator for the Project.

Records and databases at the Minnesota State Historic Preservation Office (SHPO), the Office of the State Archaeologist (OSA), and others were reviewed to determine which cultural resources have been previously identified in the Project Area along with the extent of prior investigations and potential for yet unidentified cultural resources. Historic aerial photographs and information provided by Xcel was reviewed to ascertain previous disturbances within the Project Area. A map indicating areas of previous disturbance and areas of archaeological potential is attached.

The Project Area is located in Sherburne and Wright Counties in SHPO Region 4s, Central Lakes Deciduous South. No previously recorded archaeological sites are known in the Project Area. The MNGP Facility and 27 of its individual resources have been inventoried as historic/architectural resources. They have all been recommended as not eligible for inclusion in the National Register of Historic Places (NRHP) but have not been formally evaluated by SHPO.

The review indicates that historic construction of the MNGP Plant and Plant Support Area had significantly disturbed the immediate area of the plant. Review of the Project indicates that 236 acres or approximately 12% has been previously undisturbed with the remaining 88% potentially being undisturbed. The majority of the disturbances occur at the MNGP Plant. Due to documented previous ground disturbances within the current MNGP Facility, should future ground disturbance be necessary, Westwood recommends no additional survey in areas of documented deep disturbance and consultation with a qualified archaeologist in areas of where disturbance depths are shallow or not fully documented. Westwood recommends that intact archaeological properties are unlikely within the location of the existing nuclear generating complex.

Locations outside of the existing MNGP Facility in the surrounding Project Area are of high potential for unrecorded archaeological resources due to the proximity of the Mississippi River.

Should ground disturbance be necessary for future unanticipated development in this area, Westwood recommends a formal Phase I survey in areas of proposed ground disturbance prior to development. Historic/architectural survey is not recommended. At this time, no development outside of the existing MNGP Facility is planned or anticipated.

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 3 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 ii l TBPLS Firm #10074302 Table of Contents 1.0 Introduction.................................................................................................... 1 1.1 Location........................................................................................................................................ 1 2.0 Scope of Work................................................................................................ 3 3.0 Methods......................................................................................................... 3 4.0 Results of Investigation.................................................................................. 3 4.1 Environmental Background.......................................................................................................... 3 Landscape......................................................................................................................................... 3 Land Use............................................................................................................................................ 4 Flora.................................................................................................................................................. 4 Fauna................................................................................................................................................. 4 Soils................................................................................................................................................... 5 Geology............................................................................................................................................. 5 4.2 Cultural History............................................................................................................................ 5 4.3 Pre-Contact Period....................................................................................................................... 5 Paleoindian Period (13,000 to 9000 Before Present [B.P.]).............................................................. 5 Archaic Period (9000 to 2500 B.P.)................................................................................................... 9 Woodland Tradition (3000 B.P. to 950 B.P.)................................................................................... 10 Mississippian, Oneota, Plains Village, and Psinomani Traditions (950 B.P. to European Contact). 11 4.4 Contact/Post-Contact Period (1630 to Present)........................................................................ 12 5.0 Literature Search.......................................................................................... 13 5.1 Archaeological Region................................................................................................................ 13 2.1 Previous Cultural Resources Surveys......................................................................................... 13 Previously Recorded Archaeological Sites...................................................................................... 13 5.2 Previously Documented Historic/Architectural Resources........................................................ 14 5.3 Other Sources............................................................................................................................ 16 5.4 Historic Disturbances................................................................................................................. 19 Nonextant Disturbances................................................................................................................. 20 5.5 Archaeological Potential............................................................................................................ 21 6.0 Site Visit........................................................................................................ 21 7.0 Summary and Conclusion............................................................................. 23 8.0 References Cited.......................................................................................... 24 Table Table 1-1. Sections Containing Project and Study Area...1 Table 5-1. Previously Recorded Archaeological Sites in Study Area...14 Table 5-2. Previously Recorded Historic/Architectural Resources in Study Area...14 Table 5-3. MNGP Structure Foundation Depths............................................................................ 19 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 4 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 iii l TBPLS Firm #10074302 Figures Figure 1: Cultural Resources Literature Review Study Area.2 Exhibits Exhibit 1: Cultural Resources Literature Review Study Area Exhibit 2: Cultural Resources Literature Area of Potential Effect Exhibit 3: 2021 Historical aerial photograph Exhibit 4: 2019 Historical aerial photograph Exhibit 5: 2017 Historical aerial photograph Exhibit 6: 2015 Historical aerial photograph Exhibit 7: 2013 Historical aerial photograph Exhibit 8: 2010 Historical aerial photograph Exhibit 9: 2009 Historical aerial photograph Exhibit 10: 2008 Historical aerial photograph Exhibit 11: 1997 Historical aerial photograph Exhibit 12: 1991 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 13: 1991 Historical aerial photograph Exhibit 14: 1984 Historical aerial photograph Exhibit 15: 1980 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 16: 1977 Sherburne County and Wright County, Plat Book of Minnesota Exhibit 17: 1963 Historical aerial photograph Exhibit 18: 1961 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 19: 1957 Historical aerial photograph Exhibit 20: 1940 Historical aerial photograph Exhibit 21: 1938-1939 Historical aerial photograph Exhibit 22: c1930 Plat Books of Wright and Sherburne Counties Exhibit 23: 1916 State of Minnesota Plat Book Exhibit 24: 1901-1903 Plat Books of Wright and Sherburne Counties Exhibit 25: 1874 Illustrated Atlas of the State of Minnesota Exhibit 26: 1851-1857 General Land Office (GLO) original survey maps Exhibit 27: Historical Mississippi River Boundaries map Exhibit 28: MNGP Site Visit Exhibit 29: MNGP Map of Disturbances Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 5 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 iv l TBPLS Firm #10074302 Appendices Appendix A: 1968 MNGP Rough Grading & Excavation Site Plans Appendix B: 2023 MNGP Historic/Architectural Resources Survey Area Maps Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 6 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 2 l TBPLS Firm #10074302 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 8 of 67 Exempted from Disclosure by Statute - Withheld Under 10 CFR 2.390(a)(3)

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 3 l TBPLS Firm #10074302 2.0 Scope of Work The Phase IA Literature Search was conducted to provide an inventory of previously recorded cultural resources within the proposed Project Area. The area of consideration also included a one-mile buffer surrounding the entire Project Area in order to ascertain if any recorded properties located immediately adjacent to the Project Area might be impacted by the proposed work either physically or visually. The literature search also assists in determining levels of previous disturbance, the amount and degree of previous work within the area, and the potential for unrecorded cultural resources.

3.0 Methods On October 16, 2023, Westwood Cultural Resource Manager Ryan Grohnke requested a database search from the Minnesota State Historic Preservation Office (SHPO). Additionally, he reviewed the Minnesota state archaeological site files available via the online Portal, maintained by the Office of the State Archaeologist (OSA). Mr. Grohnke was assisted by Westwood Architectural Historian Sara J. Nelson in completing the literature search. Ms. Nelson made multiple visits to SHPO in November of 2023. The literature search produced an inventory of archaeological sites and historic/architectural structures located within the proposed Study Area. Archaeological reports for the counties were reviewed to determine a listing of all surveys conducted within the Project Area. Other documentary research sources used to identify potential cultural resources in the area included county and township histories, historic contexts, environmental background, historical maps and atlases, the 1874 Andreas Atlas, Trygg (General Land Office survey) maps, and historic aerial photography. Additionally, information was provided by Xcel on the environmental background and MNGP development.

A site visit was conducted on October 23, 2023, by representatives of Xcel, Westwood, and the Mille Lacs Band of Ojibwe for a preliminary review of the Project. This site visit helped to inform the current field conditions and archaeological potential of the Project Area. A field survey to assess eastern red cedar (Juniperus virginiana), a plant of cultural significance to the Ojibwe, was conducted by Westwood biologists and will be reported under a separate cover.

4.0 Results of Investigation 4.1 Environmental Background The Project is located in a lightly populated agricultural region in central Minnesota in Sherburne and Wright counties and is currently comprised almost entirely of forest, agricultural land, and the existing nuclear power plant.

Landscape The Project is located in the Anoka Sand Plain and Mississippi Valley Outwash (51h) level IV ecoregion of the North Central Hardwood Forests (51) of the Mixed Wood Plains (EPA 2023). The Anoka Sand Plain and Mississippi Valley Outwash ecoregion level IV is characterized by sandy lake plains and terraces along the Mississippi River (White 2020). The topography of the region Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 9 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 4 l TBPLS Firm #10074302 is level to gently rolling (MnDNR 2023). The Anoka Sand Plain and Mississippi Valley Outwash is bound by the Big Woods (51i) to the south and the St. Croix Stagnation Moraines (51a) to the southwest. The McGrath Till Plain and Drumlins (51k) surround the Anoka Sand Plain and Mississippi Valley Outwash ecoregion to the west, north, and east (EPA 2023).

Prior to Euro-American settlement, the landscape of the Anoka Sand Plain and Mississippi Valley Outwash was primarily comprised of oak barrens, openings, terraces along the Mississippi River, and savannas in sandy areas (White 2020; MnDNR 2023).

Following Euro-American settlement, the regional landscape is composed of agricultural lands, urban areas, and forests (MnDNR 2023). Agricultural areas are predominantly used for corn and soybean production, as well as vegetable and sod farming (MnDNR 2020; White 2020). In 2013, approximately 25 percent of the region was wetlands, 25 percent deciduous forest, and 20 percent corn and soybeans (White 2020). The Minnesota Department of Natural Resources (MnDNR) notes that fire and drought have been important natural disturbance factors in the region (MnDNR 2023).

Land Use The Project Area is comprised of the Monticello Nuclear Generating Power Plant and surrounding woodlands and agricultural fields. The MNGP Facility began operation in 1971. Prior to construction and operation, the land was used primarily as cropland with smaller, lightly forested areas along the Mississippi River and the southeast end of the Project Area (Regents of UM 2015).

Prior to European settlement, the region surrounding the Project Area was a location of resource procurement and habitation by Native peoples, including the Ojibwe and Dakota Nations.

Flora The Anoka Sand Plain and Mississippi Valley Outwash was previously dominated by bur oak (Quercus macrocarpa) and northern pin oak (Quercus ellipsoidalis); however, drought and land use changes have reduced populations for the previously dominant species of the oak barrens and savannas (MnDNR 2023). Jack pine (Pinus banksiana) was also found along the northern boundary of the region (MnDNR 2023). Wet prairie species were previously identified in the eastern portion of the region (MnDNR 2023). The former wet prairies are mainly bogs with patches of aspen (Populus tremuloides) or other hardwood tree species (White 2020). The current landscape flora consists of a mixture of row crop agriculture, pastures, deciduous forests, and urban developed lands (White 2020).

Fauna The general area was previously home to wildlife species such as bison (Bison bison), elk (Cervus canadensis), and wolf (Canis lupus). Present wildlife species in the region include white-tailed deer (Odocoileus virginianus), beaver (Genus Castor), raccoon (Procyon lotor), mink (Neovison vison), coyote (Canis latrans), gray fox (Urocyon cinereoargenteus), and red fox (Vulpes; Wilken et al. 2011). Avian species present in the region include the Canada goose (Branta Canadensis),

turkey vulture (Cathartes aura), wild turkey (Meleagris gallopavo), sandhill crane (Grus canadensis), and ruffled grouse (Bonasa umbellus; Wilken et al. 2011). Rivers, streams, and lakes provide habitat for a variety of species, like walleye (Sander vitreus), northern pike (Esox lucius),

sunfish (Family Centrachidae), and carp (Cyprinus carpio; Wilken et al. 2011).

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 10 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 5 l TBPLS Firm #10074302 Soils Soils in the general area are predominantly comprised of psamments (droughty, upland sandy soils), with lesser areas of hemists (organic soils) in depressions and tunnel valleys, and aquolls (poorly drained prairie soils) along the Mississippi River (MnDNR 2023). The Project soils are largely of the Hubbard-Mosford complex and Sandberg loamy sand, which is are loamy sandy soils that are considered to be somewhat excessively drained and excessively drained (USDA 2023). These soils formed in sandy glacial outwash on outwash plains, valley trains, and stream terraces.

Geology A key to the geological origin of the central Minnesota surface is glacial advances dating back as early as 1.2 million years ago (MGS 2020). Sherburne and Wright Counties geologic deposits are composed of glacial till, lacustrine sand, outwash deposits, terrace deposits, peat deposits, and floodplain alluvium from the Des Moines Lobe, some 14,000 years ago (MGS 2020; Barry 2018; Berg 2017). The Project boundary is located in an area of upland terrace deposits (MGS 2020; Barry 2018; Berg 2017). Glacial Lake Anoka covered much of Sherburne County during the most recent glacial episode in Minnesota (MGS 2020). The sand plains found in the Project Area are a result of the outwash from the Mississippi River when it was blocked by the Grantsburg lobe near St. Cloud, Minnesota (White 2020). Within Sherburne County, the Quaternary overburden associated with the Upper Terrace is generally less than 10 feet in thickness (Lusardi 2013).

Within Wright County, sedimentation near the riverbed is comprised of alluvium, while Mississippi River Valley train sediment (mostly sand) can be found over most of the Project Area and is slightly calcareous under a fairly thick leached zone, over 11 feet thick in most places (Tipping 2013). Surface glacial deposits are usually less than 200 feet thick in the Anoka Sand Plain and Mississippi Valley Outwash ecoregion (MnDNR 2020). The Project boundary is situated in the central portion of the Mississippi River - St. Cloud Watershed. Drainageways are well-defined near the proposed Project.

4.2 Cultural History In general, there are five major archaeological traditions in Minnesota that consist of the Paleoindian, Archaic, Woodland, Plains Village, and the later Mississippian, Oneota and Psinomani periods (Anfinson 1997; Arzigian 2008; Dobbs 1990; Gibbon 2012). These traditions represent varying degrees of cultural adaptations to changing environmental conditions, endemic population growth, and the movement of Native American groups in the past. The following cultural context presents an interpretation of this history based on current archaeological research and broadly accepted models for pre-contact social lifeways. A brief narrative of historic period developments within the state is as follows.

4.3 Pre-Contact Period Paleoindian Period (13,000 to 9000 Before Present [B.P.])

The Paleoindian Period represents the earliest evidence of human occupation in Minnesota, typically separated into the Early Paleoindian (13,000-12,500 B.P.) and Late Paleoindian (12,500-9000 B.P.) periods (Frison 1998). Spear technology was important during this timeframe, as opposed to an emphasis on atlatl and bow and arrow lithic technology seen during later periods. This reflects a subsistence strategy focused on large game hunting and high Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 11 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 6 l TBPLS Firm #10074302 mobility. However, Gibbon (2012:37) suggests foraging behavior may have been broader-spectrum, as evidenced by the long temporal overlap of eastern Archaic and Paleoindian traditions in Minnesota. Paleoindian settlement and mobility patterns constitute a major discussion point in archaeological research.

Clovis culture is commonly regarded as the first evidence of human occupation in Minnesota during the Early Paleoindian Period. Its signature implement, the Clovis projectile point, is made from high quality lithic materials and has a central channel flake that extends part way up the proximal shaft of the tool (Frison 1998). Folsom is another Early Paleoindian technology that temporally follows Clovis during the Early Paleoindian Period. Its projectile point is typically made from high quality materials as well, with the central channel flake extending the entire length of the implement to the distal tip (Hofman 1995). Clovis and Folsom projectile points were used to hunt now-extinct forms of game, including Bison antiquus and mammoths. Evidence for Early Paleoindian occupation in Minnesota is limited to isolated finds of projectile points. Clovis isolated finds (N=30) have been found in central and southeastern Minnesota, while Folsom isolated finds (N=20) are documented in the western and southern parts of the state (OSA 2019).

The Late Paleoindian Period in Minnesota is characterized by an unfluted variety of projectile point similar to earlier lanceolate forms that are associated with the Plano Complex (Dobbs 1990).

Agate Basin, Eden, Hell Gap, and Scottsbluff are varieties of projectile points found during this time, which are often associated with bison kill sites. Late Paleoindian sites are significantly more common in Minnesota, with over 200 being recorded. The Browns Valley Site in western Minnesota and the Bradbury Brook Site are important Late Paleoindian localities in the region (OSA 2019).

Paleoindian archaeology in Minnesota mirrors the initial expansion of Homo sapien sapiens during the height of the Eurasian Upper Paleolithic periods into North America (Gilligan 2010:16). The focal point of this migration is hypothesized to have occurred in a region termed Beringia, which extends from the Verkhoyansk Mountains in Siberian Russia to the edge of the now extinct Laurentide glacial ice sheet in western Canada (Hoffecker and Elias 2007).

Traditionally, the shallow waters of the Bering Sea are argued to have served as the principal access point into the Americas when sea levels were reduced due to extensive glaciation that occurred during the Pleistocene Epoch (2.588 million-12,000 B.P.).

The proposition that the Bering land bridge may have served as passageway for early human migrations was first suggested by the Spanish missionary Fray Jose de Acosta in A.D. 1590 (Hoffecker and Elias 2007:2). Although Spain had not yet explored these waters, de Acosta thought it was the only logical explanation for how Indigenous populations would have come to the Americas. Eric Hultén (1937) later coined the term Beringia to describe the Quaternary ecology of this unique region. The designation Beringia is named for the famous Danish explorer Vitus Bering, who, by way of Russian contract, was the first European to sail the strait in 1728.

The area associated with the bridge is termed the Bering-Chukchi Platform, which extends 1600 km from the Arctic Ocean to the eastern Aleutians (Hoffecker and Elias 2007:5). Although the majority of this region is flat, the topography is punctuated by a few small islands, such as St.

Lawrence Island and Wrangle Island. The majority of the shelf lies beneath less than 100 meters of water and drops to 30 meters near the Chukotka Peninsula, Russia. Over the 2.6-million-year course of the Quaternary Period, 100 Marine Isotope Stages (MIS [Oxygen 16/18 ratios]) have Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 12 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 7 l TBPLS Firm #10074302 been documented, which show the repeated exposure and inundation of the land bridge constituting 50 glacial/interglacial oscillations (Hoffecker and Elias 2007:7-8). Initial human migrations into North America appear to be associated with the cold-snap brought on by the Younger Dryas (12,900-11,700 B.P.), which effectively lowered sea levels by 50 meters, exposing the platform.

The archaeological record for humans expanding into North America is manifested at both interior and coastal sites. Early interior sites include that of Swan Point, Broken Mammoth, and Healy Lake, Alaska, which suggest population movements between the Laurentide and Cordilleran ice sheets between 13,000 and 11,000 B.P. (Holmes 2001; Cook 1996; Yesner 2001).

Concurrently, a rapid coastal migration is also indicated at several South American localities, such as Monte Verde, which demonstrate potential evidence for groups moving by boat down the Pacific shoreline at approximately 15,000 B.P. (Dillehay 1989; Dixon 1999; Fladmark 1979).

Recent genetic work with mtDNA haplogroups in the Americas and Asia appear to confirm the archaeological evidence, showing simultaneous coastal/interior population movement occurring between 18,700 and 14,200 B.P. (ORourke 2009; Perego et al. 2009). Alternatively, although followed by much criticism, Bradley and Stanford (2004) suggest that the progenitors of Clovis, and perhaps other groups, were the product of Atlantic migrations associated with peoples of the Solutrean cultures in France. Current genetic evidence refutes this claim; however, the issue does highlight an important debate in Alaskan archaeology (ORourke 2009; Perego et al. 2009).

The Pleistocene history of Minnesota Is long and complex with most of the state and surrounding regions being covered in glaciers between 18,000 and 11,000 B.P. (Manz 2019:23). Glaciers did not fully recede until approximately 10,000 years ago, where only the southwestern and southeastern parts of the state remained unglaciated. A dominant feature following deglaciation was Glacial Lake Agassiz. This overlapped the northwest portion of the state and formed during the retreat of the Des Moines Lobe, which principally drained to the south via Glacial River Warren (Gibbon 2012:38). As Lake Agassiz retreated farther north, the modern Red River of the North began to form flowing towards the Hudson Bay. In terms of human occupation potential, the southern part of the state is likely the highest probability area to encounter archaeological sites, as it was unglaciated (Gibbon 2012:Map 2.1). Elk, mammoth, and extinct forms of bison (e.g., Bison antiquus) may have been hunted by Pleistocene Native Americans of this time frame in Minnesota; however, other food resources were probably equally important.

Waguespack (2007:69-70) highlights current evidence for early migrations into North America that indicate hunter and gatherers may have been generalized foragers, as opposed to explicitly large game predators. Historically, the first evidence for the Paleoindian Period comes from New Mexico where archaeologists uncovered fluted projectile points in association with extinct megafauna at sites, such as Blackwater Draw (Cook 1927; Figgins 1927). These important early finds quickly placed the antiquity of humans on the mid-continent of North America at the end of the Late Pleistocene (Howard 1936). Much of the debate generated by these discoveries placed too much emphasis on the role megafauna played in the subsistence economy of Paleoindian hunter and gatherers. This pattern is different than many of the interior localities dating prior to 11,000 B.P. (e.g., the Village Lake Site at Healy Lake in Alaska [Cook 1969]), which exhibit a broad-spectrum diet. Bison and wapiti appear to be the predominant large game that were hunted during this early period; however, birds and other small mammals were also exploited (Yesner 2001).

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 8 l TBPLS Firm #10074302 Analogous patterns have been observed outside of Minnesota, including eastern Great Basin sites, such as Bonneville Estates Rock Shelter, which demonstrate a broad-spectrum diet occurring between 13,100 and 12,000 B.P. (Goebel 2007; Graf and Schmitt 2007:103). The archaeological record from this site suggests the prehistoric inhabitants were participating in a mixed foraging and hunting strategy. The identification of this trend in the Great Basin has led to the suggestion that this early phase be called the Paleoarchaic instead of Paleoindian in recognition of the markedly different subsistence strategies that were similar to later archaic groups (Graf and Schmitt 2007; Willig 1988; Willig and Aikens 1988). Realistically, the debate about whether early Paleoindians were generalized foragers or large game specialists likely rests on the relationship between what could have been hunted and what was actually taken (Waguespack 2007:70; Waguespack and Surovell 2003).

In contrast to these views, Kelly and Todd (1988) take the position that early populations of hunter and gatherers entering into the North American continent were heavily dependent on terrestrial fauna, as opposed to plant resources, since this was a more reliable food source. They argue that the strategies employed by these foragers were starkly different than that of modern hunter and gatherers, in that groups were not operating in seasonally restricted spaces. An optimal foraging analysis for procuring large game has recently been conducted by Byers and Ugan (2005). Specifically, they identified variables that may have deterred Paleoindians from focusing exclusively on megafauna, including the large number of individuals needed for processing, difficulty in procuring game, and distribution of game within different environmental patches. The authors conclude that the phenomena of exclusive large mammal hunting likely only occurred in a narrow range of places where game was abundant and processing time was low, such as in the Great Plains (Byers and Ugan 2005:1625). Minnesota and surrounding areas were likely encompassed by this narrower range, as suggested by Kelly and Todd (1988).

Continuing with the issue of broad-spectrum versus predominant large game hunting has been problematic to the debate of humans entering into the North American continent. Guthrie (1990) has supported the notion that humans could have easily followed the wide trails of proboscideans across the land bridge. Haynes (2001) reasons that modern African elephants can serve as an analogy for understanding how Pleistocene hunters may have interpreted herd characteristics.

Such behavioral patterns include 1) the speed, direction, and health of an elephant herd based on the distribution/content of dung, and 2) the relative size of the animals based on the track width.

Elephants create a series of fixed and habitually used trails that would have allowed initial colonizers into interior Alaska as a means to systematically explore the landscape. Conversely, Yesner (2001:317) sees the process of colonization into interior Alaska as involving a "push-pull" factor, presenting evidence for the existence of proboscideans in Siberia up to 9000 B.P.

This suggests that hunters would have been encouraged to remain in western Beringia for a longer period of time to procure this higher ranked resource. Foragers may have only episodically crossed the land bridge as eastward movement began to develop as the principal subsistence cycle.

A theoretical trajectory of incipient occupation into novel landscapes has been proposed by Beaton (1993) to describe the initial colonization of Australia (also see Yesner 2001). His model breaks down human entry into two categories: transient explorers and estate settlers. Beaton suggests that the settlement pattern associated with transient explorers would be lineal, conforming principally to significant geographic features, such as mountains, rivers, etc. This type of occupation may be associated with the earliest sites in Minnesota, which could be situated along the margins of major river corridors (e.g., Glacial River Warren). High mobility and small Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 14 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 9 l TBPLS Firm #10074302 populations are necessary with the transient model, since groups are entering into an unfamiliar landscape leading to potentially high extinction rates. In contrast, estate settlers inhabit new lands in a more radial fashion since there is a greater degree of familiarity with the resources present.

Kelly and Todd (1988) argue that immigrant Paleoindians would have needed to switch territories frequently due to unfamiliar landscapes. This would have been an adaptive method to adjust to resource stress by either switching territories or adjusting the types of foods being consumed. In reality, the Early and Late Paleoindian periods in Minnesota likely represented a combination of these alternating mobility strategies.

Archaic Period (9000 to 2500 B.P.)

Approximately 9000 B.P., a new mode of subsistence strategy began to emerge in the archaeological record across North America (Emerson et al. 2011). The general pattern of this change is the replacement of lanceolate spear points used during the Paleoindian period, and the adoption of atlatl technology with the presence of groundstone implements. This represents a fundamental difference from earlier forager behavior with a diversification of economy that incorporated more plants into the diets of Native Americans. The Archaic Period in Minnesota began substantially later than other regions starting around 9000 B.P., principally in the southeastern part of the state (Anfinson 1997; Gibbon 2012). Important Archaic innovations include the use of grooved mauls and axes, canine domestication, copper tools, and incipient horticulture. The Archaic Period in Minnesota is poorly known; however, it comprises its longest temporal frame of human occupation.

Xeric environmental conditions began around 9000 B.P. with the spread of prairie grassland across most of southern and western Minnesota (Anfinson 1997). Many of the lakes created as a product of Pleistocene glaciation started to dry during this time, leading to a reduction in game (e.g., bison, fish, birds, etc.) dependent on these resources. These environmental transformations promoted a diversification in hunting strategies, which differed dramatically from the Paleoindian Period.

Minnesota experienced a wide variety in changing environmental conditions based on its different ecotones across the state during this time. As a consequence, the traditional models of Early, Middle, and Late Archaic found elsewhere in North American do not directly apply. These different environmental regimes necessitated a variety of adaptive strategies to successfully subsist. Archaeologists have defined these internal periods within the state as follows: Prairie Archaic, Lake Forest Archaic, Shield Archaic, and Riverine Archaic (OSA 2019).

The Prairie Archaic Period is found across the western parts of Minnesota, representing an adaption to grassland environments. Key game hunted during this period were bison, which remained a focus throughout the entirety of the Archaic Period. Itasca State Park Site contains one of the best examples of the Prairie Archaic pattern. This site dates approximately to between 9550 and 7950 B.P. and yielded the remains of an extinct species of bison and the presence of a side-notched dart point. Other important localities from the Prairie Archaic Period include the Granite Falls Site and the Canning Site. A regional variation of the Prairie Archaic during the later periods is the presence of copper tools in the northwestern part of the state, but few examples in the southwestern areas (Anfinson 1997).

The temporal period known as the Lake Forest Archaic accompanies archaeological sites from about 7950 B.P. in much of central and northern Minnesota (Anfinson 1997; Gibbon 2012). Prior Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 15 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 10 l TBPLS Firm #10074302 to this period, most sites in this region would have mirrored those found in grasslands, whose economy focused on bison hunting. As a result, the Prairie Archaic pattern would have been prevalent during the earliest periods based on the similar environment. The expansion of woodlands during the mesic environments of the post-glacial thermal maximum led to a greater diversification of both plant and animal species. The Mississippi River corridor also served as a conduit for archaic groups from other regions, which ultimately influenced the potential spread of technologies and new lifeways into Minnesota. The site of Petaga Point in Kathio State Park is one of the best examples of the Lake Forest Archaic Period and contains evidence of Old Copper culture.

The Shield Archaic Period characterizes sites from far northeastern Minnesota, whose assemblages are the product of Native American adaptations to traditions typically found farther north in Canada (i.e., Canadian Shield). An important characteristic of Shield Archaic sites is the lack of groundstone tools and copper artifacts which are often associated with Archaic groups elsewhere in Minnesota (Anfinson 1997; Gibbon 2012). Shield Archaic sites in Canada are typically found near lakes and rivers where caribou and other migratory game may have crossed.

Similar to other northern adapted populations, these groups may have utilized specialized technologies, such canoes, snowshoes, toboggans, bark and skin-covered shelters, bark containers, and efficient winter clothing. The Fowl Lake Site is an important Minnesota site near the Canadian border that exemplifies the archaeological record of this period.

The Riverine Archaic Period is found at sites located along the lower Mississippi River and other drainages in southeastern Minnesota (Anfinson 1997; Gibbon 2012). The river valley bottomlands provided a rich and varied source of animals and plants that were exploited by Native American populations. Common riverine resources included aquatic tubers, fish, waterfowl, and mussels. Deer, elk, and bison may have been taken in the uplands. The fertile floodplains also provided suitable locations for horticulture where plants, such as squash and various early cultigens, were grown. The King Coulee Site in Wabasha County is one of the most complete archaic sites from this region and dates to between 3450 and 2450 B.P. A slate gorget, mussel shells, squash seeds, and stemmed projectile points were recovered during the excavations (OSA 2019).

Woodland Tradition (3000 B.P. to 950 B.P.)

Substantial cultural changes began to occur in Minnesota approximately 2,500 years ago, with Native American adaptations that mirrored broader trends across the southern and eastern United States (Arzigian 2008). This timeframe, known as the Woodland Period, is marked by the presence of burial mounds, pottery, bow and arrow technology (ca. 1450 B.P.), and intensive plant cultivation. Archaeological settlement patterns show Native American groups beginning to aggregate into larger populations along lakes, rivers, and associated drainages. Woodland archaeological sites are often broken into one of a classic tripartite temporal division of Early (3000-2150 B.P.), Middle (2150-1450 B.P.), and Late Woodland (1450-950 B.P.) periods (Emerson et al. 2008).

Traditionally, variations in the Woodland Period across time and space are argued to derive from broader influences that shaped significant trends in cultural practices. These interaction spheres include the Adena (Early Woodland Period), Hopewell (Middle Woodland Period), and Mississippian (Late Woodland Period) cultures (Anfinson 1997; Gibbon 2012). While these Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 16 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 11 l TBPLS Firm #10074302 divisions work well for other regions of North America, they do not neatly apply to archaeological sites in Minnesota (Arzigian 2008).

Major Woodland complexes in the various regions of the state include Laurel, Brainerd, and Blackduck (northern Minnesota); Malmo, St. Croix, Onamia, and Kathio (central Minnesota); Fox Lake and Lake Benton (southwestern Minnesota); and La Moille, Howard Lake, Sorg, and Effigy Mound (southeastern Minnesota; Arzigian 2008). Pottery is an important distinguishing characteristic of these complexes. Pottery styles were commonly named for the site type where they were first discovered. Ceramic vessels range in form from globular to conoidal, are made with shell or sand grit as temper, and have distinctive designs across the body (e.g., net impressions, patterned incisions). Lithic technology during this timeframe shows a preference for smaller projectile points utilized principally in bow and arrow technology.

A hallmark characteristic of the Woodland Period in Minnesota is presence of burial mounds, of which 12,000 have been recorded in the state (OSA 2019). The areas surrounding Red Wing, Lake Minnetonka, and Mille Lacs Lake have the highest concentrations of burial mounds. Many of these structures have been destroyed due to historic and modern development.

The subsistence strategies of Woodland groups in Minnesota varied widely based on the type of resources available. Wild rice was central to groups living in the northeast quarter of the state, which was husked in excavated pits and parched in ceramic vessels (Arzigian 2008). Other resources hunted or gathered included deer, fish, and various plants, such as maple sap for sugar.

Farther west, around the Red River Valley and southern Minnesota, bison continued to be important as they were in the Archaic Period (OSA 2019). The Three Sisters of squash, beans, and corn were grown in small garden plots, which were further supplemented with other resources (e.g., fish and aquatic mammals).

Mississippian, Oneota, Plains Village, and Psinomani Traditions (950 B.P. to European Contact)

The Woodland Period ends throughout most of Minnesota around 950 B.P., with the exception of the northern portions of the state (Arzigian 2008; Gibbon 2012). The dominant regional influence was the site of Cahokia in the American Bottom near the modern city of St. Louis, Missouri on the Mississippi River (Pauketat 2009). This influence is most clearly seen in archaeological sites near Red Wing, Minnesota, which contain Cahokian-style ceramics, large, palisaded villages, and evidence of corn horticulture. The presence of square earthen mounds may reflect Cahokian socio-religious belief systems. In Minnesota, the manifestation of this interaction is called the Silvernale Phase (Gibbon 2012).

A widespread cultural complex called Oneota in Minnesota is concurrent with the regional influences of Cahokia, lasting from approximately 950 B.P. until the time of French contact (Gibbon 2012). These mobile groups shared Middle Mississippian traits that included corn horticulture and shell-tempered ceramics (e.g., globular vessels with high rims), but lacked permanent structures, such as burial mounds. Oneota is manifested in different types called Orr (southeastern Minnesota), Blue Earth (south-central Minnesota), and Ogechie (central Minnesota). Siouan languages were spoken at the time of French contact (OSA 2019).

Plains Village groups from the region of the Missouri River in the Dakotas began to interact with the Oneota in western Minnesota after 950 B.P. (Anfinson 1997; Ahler and Kay 2007). These Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 17 of 67

Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 12 l TBPLS Firm #10074302 groups hunted bison, practiced corn horticulture, and lived within earth-lodges protected within palisaded forts (e.g., Double Ditch Site in North Dakota). Globular-shaped ceramic jars with crushed rock temper are a hallmark technology of this period. Important Plains Village ceramic complexes in western Minnesota include Cambria, Great Oasis, and Big Stone (OSA 2019).

Psinomani groups are believed to be the ancestors of the modern Dakota people, who lived in east central Minnesota (Gibbon 2012). The principal ceramic type associated with this group is Sandy Lake, whose form is more similar to a bowl rather than the globular jars of Oneota varieties. There is evidence of blended ceramic styles with Oneota Native Americans.

4.4 Contact/Post-Contact Period (1630 to Present)

By the time of European contact in the 1600s, the Dakota and Ojibwe peoples were the primary occupants of present-day Minnesota. The occupancy of the region is reflected in both the archaeological record and historical documentation. In the vicinity of the Project Area, early European explorers encountered both Nations utilizing the region for its resources and identified the indigenous names applied to those locales, emphasizing the importance the Native community placed on those resources (Nicollet, 1843; Gilfillan, 1887; Verwyst, 1892; Upham 1920; Durand, 1994). Several such features are located in both close proximity to and within the Project Area. Communication and consultation with Native communities is an essential component of a robust history of the region and the interpretation of cultural resources that are not exclusively archaeological.

The fur trade in Minnesota involving Europeans and Native Americans first started in the early 1600s and marked the beginning of contact between these two populations. The historical implications of this interaction were felt in numerous ways both economically and with great social consequence (e.g., smallpox). The major players in this arena of interaction were first the French, followed by the British, and much later the Americans. French explorers Marquette and Joliet were among the first Europeans to reach the headwaters of the Mississippi entering Minnesota in 1673 (Kellogg 1917).

Throughout this early period up until the 1850s, fur drove much of the European exploration of Minnesota, leading to the establishment of American settlements, including the important Fort Snelling in 1824 (Hansen 1918). This ultimately led to Minnesota becoming a territory in 1849, later achieving statehood on May 11, 1858. In the 1860s, intensive agriculture and ever-increasing European settlements displaced numerous Native Americans groups. These tensions culminated in the Dakota Conflict of 1862 (Carley 1976).

The period after the 1860s, Minnesota became an epicenter for the agriculture, lumber, and mining industries. Agriculture was prevalent in the southern and western parts of the state with wheat being the primary crop. Mills were constructed along many waterways in the state, with Minneapolis becoming a milling center. Lumber was cut and iron mined in the northeastern areas of the state. The Mesabi, Cuyuna, and Vermilion iron ranges were focal points in the procurement of iron, historically employing thousands of people (Upham 1920). Railroad lines were also economically important in Minnesota, making Minneapolis/St. Paul a focal point in transcontinental railways of the nineteenth and twentieth centuries.

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 13 l TBPLS Firm #10074302 5.0 Literature Search In October and November 2023, Westwood Cultural Resource Manager Ryan Grohnke Westwood Architectural Historian Sara J. Nelson completed the literature search. The literature review Study Area comprised the Project Area (the MNGP Facility and surrounding MNGP owned lands) and a surrounding one-mile buffer. Mr. Grohnke requested a database search from the SHPO and obtained archaeological site locations through a review of the OSA online Portal. Historic structure and cultural resource survey information was acquired through a review of records at SHPO. Additional historical resources including maps and aerial photography were viewed for the Study Area. The results of the literature review and discussed below.

5.1 Archaeological Region The Project Area is located in Wright and Sherburne counties in SHPO Regions 4s and 4e, Central Lakes Deciduous South and East. Prehistoric camp sites in this region are generally located near lakes, rivers, and other water sources with resource procurement sites located anywhere the resource could be found (Anfinson 1990). Early and Early Middle Prehistoric site location patterns are not well known, but by the Late Middle Prehistoric large village sites were found on major lakes, with smaller campsites found along major rivers and large lakes. By the Late Prehistoric period, much of the region was only used for resource procurement with villages generally near wild rice beds (Gibbon et al. 2002).

The Dakota resided in this region at Contact, but by the mid-1700s the Anishinaabeg has assumed control over most of it. Most village sites during this period would have been located near wild rice beds similar to the Late Prehistoric. French fur traders began to move into the region in the late 1600s and established posts along major rivers and lakes (Gibbon et al. 2002).

2.1 Previous Cultural Resources Surveys No information on known archaeological sites or previously conducted archaeological investigations within the Project Area was found during a review of SHPO records.

One architectural history survey has been conducted within the APE. The 2023 investigation of the historic structures at the MNGP plant was conducted by SEARCH, Inc. The MNGP Facility as a whole and 27 individual historic (pre-1978) resources were inventoried, all of which were recommended as not eligible for listing in the NRHP (SEARCH 2023).

Previously Recorded Archaeological Sites Three previously recorded archaeological sites were identified within the Study Area, none of which are located in the Project Area (Table 5-1). All three sites are of the Project and are ineligible or unevaluated for listing in the NRHP.

Sites 21SH0035 and 21SH0036 are prehistoric lithic scatters identified by Stemper and Associates during a survey of the in 1990. The researcher recommended both sites as not eligible for listing in the NRHP. Upon a review of the artifacts from the two sites, SHPO, in a document dated December 13, 1990, suggested no cultural materials were present. The sites may not be sites.

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. No river crossings are apparent in any of the later years of coverage of the Project.

By 1874, the earlier trail had been formalized as a roadway and it followed generally the same route, running south of and parallel to the Mississippi (Exhibit 25). No roads or trails were depicted on the land along the north side of the river, which was lined with stands of trees. No houses were apparent in 1874, including those depicted in the earlier GLO map.

The 1901 to 1903 atlases depict a fair amount of infrastructure development in the Study Area, but not much population settlement. Most of the land had been claimed,

. In Wright County, the Great Northern Railway had been laid through the Project south of the river, running parallel to and just north of the highway.

. On the north side of the river, the predecessor to 157th Street SE had been constructed along the northern Project boundary by 1903.

In 1916, most of the land within the Project along both sides of the river was owned by Mississippi River Electric Power Co. and the Mississippi & Rum River Boom Co. (Exhibit 23).

. The 1920 state road map shows the Mississippi River, Great Northern Railway, and the CSAH 75 predecessor running through the Project. The 1930 and 1956 atlases were not detailed and did not reflect potential changes in the vicinity of the Project.

The 1938 to 1939 and 1940 aerial photography shows that the modern roadway for CSAH 75 was under construction (Exhibits 20 and 21). The new corridor deviated from its predecessor and in the southeast portion of the Project, the roadway curved and crossed over from the north side to south side of the railroad tracks. No major roadways had been added in the Project; few minor trails or access roads were apparent near the river and

. The islands and riverbanks were filled with dense vegetation, except for portions that had been cleared for agricultural land, which is what much of the surrounding area had been cultivated for by that time.

. Nearby, the roadway had been altered slightly to reduce the sharp angles at a curve.

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 18 l TBPLS Firm #10074302 The most substantial changes occurred in the Project Area when the Monticello Nuclear Generating Plant was constructed during the 1970s. In 1977, the turbine building, central reactor building, chimney tower, and three laydown yards are visible, as are several overhead transmission lines running to the north, northeast, and southeast of the southern laydown area.

Dirt access roads run throughout the power plant property, and a spur of the Great Northern railway onto the plant property are also evident.

There were several other significant changes within the Project before 1977: Interstate 94 was built through the Project, generally parallel to and south of CSAH 75, the railway, and the river.

The interstate was constructed through the footprint of the

. An access road and small possibly A pair of baseball fields stood

, and the land between the power plant and the river was crossed by several unpaved pathways.

. More unpaved paths meandered through the woods and bluffs along the north side of the river (Exhibits 16 and 17).

. That map also depicted the new access roads and unpaved paths, railroad spur, tower, substation, and a laydown yard at the MNGP (Exhibit 15).

The 1980 and 1991 maps do not depict any buildings or trails

. In the south, the footprints of several more structures at MNGP are depicted, as is the conference and training center on River Avenue at the far southeast corner. No building sites are depicted elsewhere in the Project.

Since its construction, the Project Area around the MNGP Facility has undergone few changes (Exhibits 3 to 16). On the east side of the Project Area, from 1984 to 1991 a pair of baseball fields were removed from the plant property and replaced by two pairs were built off River Avenue near the MNGP conference and training center, which was also built during that time. In the yard immediately east of the MNGP Facility, a large ground-level J-shaped feature in the ground was evident in aerial photographs from 1977 to 1991. This structure consisted of several channels and was utilized by the Environmental Protection Agency (EPA) Monticello Research Station (MERS).

The hydraulic and temperature environment in the MERS channels was measured and simulated to provide some background for several biological studies (Stefan et al 1981). Aerial photographs indicate that elements of the feature had been removed by 1997, and by 2003 the central section of the feature had been converted to a firing range. The original access road around the perimeter of the feature remains intact as of 2023, and various ground-disturbing activities within its limits are evident since 1997. Between 2010 and 2013, a 0.7-mile-long segment of CSAH 75 in the southeast corner of the Project was slightly realigned. Sometime after 2017, most of the trees lining the northern banks of the Mississippi River were clearcut, and since 2019 the land is sparsely populated by trees and grassy vegetation. The 2021 aerial shows the I-94 corridor under construction and being widened from about 150 feet to approximately 250 feet wide.

The Mississippi River flows along the north side of the MNGP Facility. Exhibit 27 depicts the river boundaries over time since 1938. Because river boundaries conflicted in Sherburne and Wright County atlases, county plat maps were considered unreliable and not mapped.

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 20 l TBPLS Firm #10074302 Building Area during phase I (p. 12). During Phase II 30,200 cu. yd. would be excavated for Buildings and there would be 7,600 cu. yd for Backfilling and Inspection (p. 13).

The 2023 architectural history report indicates that most structures beyond the Reactor Complex were built upon concrete slab foundations; the Reactor and Turbine buildings are among the few with foundations that are reinforced concrete. The Standby Diesel Generator is located at grade and are supported on a 3-foot-thick reinforced concrete mat (Xcel Energy 2005:2-197)

(SEARCH 2023:22). The Intake Structure along the north end of the plant is reinforced concrete construction behind a submerged grille" (SEARCH 2023:15). The Guard House stands over a reinforced concrete cellar-style tornado shelter with a hatch on the buildings north façade (SEARCH 2023:27).

The asphalt driveways and parking lots, unpaved access roads and lots, fences, and structures with on-grade slab concrete foundations are generally all considered Shallow/Surface Level disturbances. Structures with excavated foundations, especially those within the Reactor Complex are considered Deep Level disturbances and are of low archaeological potential.

The grounds of the baseball fields on the south end of the Project would have been leveled and landscaped, which may have varying levels of ground disturbance. The parking lots for the fields and MNGP training and conference center are Shallow/Surface Level disturbances. The building itself is likely slab-on-grade.

. Most of 157th Street SE along the north Project has undergone minimal changes over time; the alterations to the roadway have been fairly concentrated on the westernmost end where the stepped turns have evolved into a wider, singular curve in the road. The I-94 corridor is low potential.

Manmade paths throughout the woods and bluffs along both sides of the river are considered Shallow/Surface Level disturbances; Nonextant Disturbances The grounds of the baseball fields on the east side of the Project would have been leveled and landscaped, which may have varying levels of ground disturbance.

Historical maps and aerial photography reveal that there are more than 20 nonextant building sites located throughout the Project Area.

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 21 l TBPLS Firm #10074302 Manmade paths throughout the woods and bluffs along both sides of the river are considered Shallow/Surface Level disturbances; 5.5 Archaeological Potential As discussed above (Section 5.1), the Project Area is located in SHPO Regions 4s and 4e, Central Lakes Deciduous South and East where prehistoric camp sites are expected to be located near lakes, rivers, and other water sources (Anfinson 1990). Large village sites are expected to be found on major lakes, while smaller campsites and resource procurement sites are expected along major rivers and large lakes.

6.0 Site Visit Monday October 23, 2023, a site visit of the approximate 2,000-acre Project Area was initiated.

The site visit was conducted by Xcel staff, Westwood cultural resources and environmental team members (including Dean Sather, MA, RPA, as Principal Investigator, who meets the Secretary of Interior professional standards for archaeology), and

, a representative of the Mille Lacs Band of Ojibwe Indians THPO. This site visited concentrated on conducting a preliminary visual inspection of the portions of the Project Area located exterior to the MNGP Facility

). The goal of the preliminary visual inspection was to assess the nature of the ground cover, identify areas of archaeological interest, and determine the level of effort that might be required to conduct a formal and comprehensive archaeological survey of the property.

The site visit was initiated on the larger river island located immediately to the west of the MNGP Facility. The inspection began on the eastern tip of the island and progressed to the west. The surface of the island is covered with a sparse forest with a relatively consistent vegetative cover of the forest floor which provided nearly no visual exposure of the ground surface. The surface features of the island are linear and oriented along and west to east axis; parallel to the flow of the river. Three distinct features were identified on the island. The first of these is the floodplain situated along the margins of the island immediately adjacent to the river. The aerial extent of the Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 27 of 67 Exempted from Disclosure by Statute - Withheld Under 10 CFR 2.390(a)(3)

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 22 l TBPLS Firm #10074302 floodplains varied across the island with the larger, broader floodplain surfaces located towards the eastern end of the island. The second feature consisted of a series of shallow linear channels extending through the medial portion of the island. It is assumed that these linear channels are the scoured braided channels developed during flooding episodes. Ground exposures in these linear features exhibit a bed of sand lining the base with no discernable topsoil development. The third feature are a series of linear ridges that run parallel to the river flow. These high grounds occupy the majority of the center of island and are situated along the lateral edges of the channel features.

The site visit continued to the second island within the Project Area, located immediately north and west of the first. The features observed on the second island are nearly identical as the previous. The major difference is that there appear to be more distinct linear features through the medial portion of the island and less developed floodplain along the lateral margins adjacent to the riverbanks. The nature of the difference is indeterminate at this time.

. No formal archaeological investigations of the islands have been conducted to date. Due to time limitations for this preliminary visual inspection of the islands, no formal subsurface investigations were undertaken. Exposures of the sub-surface, provided by tree-falls offered limited subsurface views. No archaeological materials were identified or recovered during this visual inspection.

Following the review of the islands, the visual inspection of the northern banks and middle terrace bluffs of the river valley were initiated. This involved the pedestrian inspection of the landforms located within the Project Area located along the northern banks of the river. The flood plain situated immediately adjacent to the rivers edge was relatively narrow, uneven, and overgrown with a dense vegetative cover that obscured the ground surface and made passage arduous.

. Occasional indications of historic occupations were identified, but not recorded, such as wo-track roads with natural masonry borders, cleared areas of potential historic residential, or commercial/agricultural occupation

. There appeared to be several collections of boulders, perhaps removed from plowed agricultural fields. While evidence of historic occupation was identified, the level of disturbance was not immediately determined.

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Phase I Archaeological Investigations l MNGP Phase IA Literature Search and Site Visit January 30, 2024 23 l TBPLS Firm #10074302 However, it was also determined that the visual inspection of the property provided limited returns for identification of the full potential of archaeological potential and that further inspection of the full property would be of little value and further inspection of the area was suspended.

7.0 Summary and Conclusion No intact archaeological features or deposits have been previously recorded within the current Project Area. Westwood recommends that no intact historic archaeological properties are present within the location of the existing nuclear generating complex. No NRHP significant historic properties are located within the MNGP Facility and there are no historic-age structures within the Project Area beyond the Facility. The 2023 architectural history survey thoroughly documented the historic structures at the MNGP Facility. The plant itself and 27 individual resources were recommended not eligible for inclusion in the NRHP. There are no extant historic-age structures in the Project Area. The paucity of known resources is likely due to lack of previous cultural resources investigations of the area.

The site visit was not designed to, nor did it produce any evidence of intact archaeological features or deposits. Portions of the Project Area included in the visual inspection were so densely vegetated that passage through the area is difficult.

The construction, operation, and maintenance activities associated with the existing nuclear generating plant has heavily disturbed the grounds within the MNGP Plant to depths in excess of 10ft (3.05m) and has effectively negated the potential for intact cultural resource deposits to be preserved (areas highlighted Orange, Exhibit 29). Due to documented significant previous ground disturbances and the 2023 architectural history within the current MNGP Facility, Westwood recommends no additional cultural resources survey in this area.

Areas immediately surrounding the MNGP Plant (the Plant Support Area) are occupied by a variety of standing structures, transportation routes, and other landscape alterations. The degree of subsurface disturbance caused by the construction of these features is undefined and cannot be dismissed out-of-hand. It is assumed that construction disturbance for these features was limited to within the upper 10 ft (3.04m) of the ground-surface.

It is recommended that should ground disturbance be necessary for future unanticipated development at locations outside of the existing MNGP Plant (Orange Area) but in the surrounding MNGP Plant Support Area (Green Area), Westwood recommends a review of proposed construction with a qualified archaeologist to determine the potential for intact archaeological deposits and appropriate next steps which might include monitoring or survey.

Should ground disturbance be necessary for future unanticipated development at locations outside of the Facility (Orange or Green areas), Westwood recommends a formal Phase I cultural resources survey in those areas of proposed ground disturbance prior to development. At this time, no development outside of the existing Facility is planned or anticipated.

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Exhibits Exhibit 1: Cultural Resources Literature Review Study Area Exhibit 2: Cultural Resources Literature Area of Potential Effect Exhibit 3: 2021 Historical aerial photograph Exhibit 4: 2019 Historical aerial photograph Exhibit 5: 2017 Historical aerial photograph Exhibit 6: 2015 Historical aerial photograph Exhibit 7: 2013 Historical aerial photograph Exhibit 8: 2010 Historical aerial photograph Exhibit 9: 2009 Historical aerial photograph Exhibit 10: 2008 Historical aerial photograph Exhibit 11: 1997 Historical aerial photograph Exhibit 12: 1991 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 13: 1991 Historical aerial photograph Exhibit 14: 1984 Historical aerial photograph Exhibit 15: 1980 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 16: 1977 Sherburne County and Wright County, Plat Book of Minnesota Exhibit 17: 1963 Historical aerial photograph Exhibit 18: 1961 Monticello and Silver Creek quadrants 7.5 topographic maps Exhibit 19: 1957 Historical aerial photograph Exhibit 20: 1940 Historical aerial photograph Exhibit 21: 1938-1939 Historical aerial photograph Exhibit 22: c1930 Plat Books of Wright and Sherburne Counties Exhibit 23: 1916 State of Minnesota Plat Book Exhibit 24: 1901-1903 Plat Books of Wright and Sherburne Counties Exhibit 25: 1874 Illustrated Atlas of the State of Minnesota Exhibit 26: 1851-1857 General Land Office (GLO) original survey maps Exhibit 27: Historical Mississippi River Boundaries map Exhibit 28: MNGP Site Visit Exhibit 29: MNGP Disturbances Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 01 Page 37 of 67

1 Monticello Nuclear Generating Plant, Survey of Culturally Sensitive Plant Species, Wright and Sherburne Counties, Minnesota.

PREPARED BY:

PREPARED FOR:

Northern States Power MN, d.b.a. Xcel Energy SURVEY OF CULTURALLY SENSITIVE PLANT SPECIES Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota DECEMBER 20, 2023 Monticello Nuclear Generating Plant L-MT-24-005 Enclosure 01 Page 1 of 26

Survey of Culturally Sensitive Plant Species Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota Prepared For:

Northern States Power MN, d.b.a. Xcel Energy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362-9601 Prepared By:

Westwood Professional Services 12701 Whitewater Dr. Suite 300 Minnetonka, MN 55343 (952) 937-5150 Project Number: R0046559.00 Date: December 20, 2023 Monticello Nuclear Generating Plant L-MT-24-005 Enclosure 01 Page 2 of 26

Survey of Culturally Sensitive Plant Speciesl Monticello Nuclear Generating Plant December 20, 2023 i l TBPLS Firm #10074302 Table of Contents 1.0 Introduction.................................................................................................... 1 1.1 Location.................................................................................................................................. 1 2.0 Scope of Work................................................................................................ 2 3.0 Methods......................................................................................................... 2 4.0 Results........................................................................................................... 2 5.0 Summary and Conclusion.............................................................................. 3 6.0 References Cited............................................................................................ 3 Table Table 1-1. Sections Containing Project Area....1 Exhibits Exhibit 1: Project Area Location Exhibit 2: Red Cedar Observations Overview Map Exhibit 3: Red Cedar Observations Map Book Monticello Nuclear Generating Plant L-MT-24-005 Enclosure 01 Page 3 of 26

Survey of Culturally Sensitive Plant Speciesl Monticello Nuclear Generating Plant December 20, 2023 2 l TBPLS Firm #10074302 The Anoka Sand Plain and Mississippi Valley Outwash was previously dominated by bur oak (Quercus macrocarpa) and northern pin oak (Quercus ellipsoidalis); however, drought and land use changes have reduced populations for the previously dominant species of the oak barrens and savannas (MnDNR 2023). Jack pine (Pinus banksiana) was also found along the northern boundary of the region (MnDNR 2023). Wet prairie species were previously identified in the eastern portion of the region (MnDNR 2023). The former wet prairies are mainly bogs with patches of aspen (Populus tremuloides) or other hardwood tree species (White 2020). The current landscape flora consists of a mixture of row crop agriculture, pastures, deciduous forests, and urban developed lands (White 2020).

2.0 Scope of Work The Survey of Culturally Sensitive Plant Species was conducted to delineate populations of eastern red cedar (Juniperus virginiana) and northern wild rice (Zizania palustris) within the MNGP Project Area. Both species are considered culturally significant to the Mille Lacs Band of Ojibwe as well as other Native American tribes. Presence/absence surveys were completed within the entirety of the approximately 2,000-acre MNGP Project Area.

As the site visit was conducted outside of the peak growing season of northern wild rice, which is between July and early October, follow up site visits will be conducted in 2024 to document the presence/absence of northern wild rice within the Project Area.

3.0 Methods An initial site visit was conducted on October 23, 2023, by representatives of Xcel, Westwood, and the Mille Lacs Band of Ojibwe for a preliminary review of the Project. This site visit helped to determine the current field conditions and potential of species occurrence in the Project Area.

After the initial site visit, follow up site visits occurred between December 6th-8th and on December 11th and 13th, 2023. Singular observations of eastern red cedar were documented as an observation point, while larger populations were surveyed as a polygon with an estimated density (Exhibits 2 and 3).

Initial reconnaissance was conducted for potential habitat for northern wild rice. Follow up investigations for the presence/absence of northern wild rice will be conducted during the peak growing season July-early October in 2024.

4.0 Results Singular observation points of eastern red cedar totaled 1,551 specimens (Exhibits 2 and 3).

An additional 149 populations of eastern red cedar with estimated densities ranging from four (4) to upwards of 800 specimens were mapped within the Project Area (Exhibits 2 and 3).

Approximate total estimates of eastern red cedar in the Project Area total 12,000 specimens.

Large populations (greater than 400+ specimens) of eastern red cedar were mostly observed

, primarily

. Smaller populations were Monticello Nuclear Generating Plant L-MT-24-005 Enclosure 01 Page 5 of 26 Exempted from Disclosure by Statute - Withheld Under 10 CFR 2.390(a)(3)

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Survey of Culturally Sensitive Plant Speciesl Monticello Nuclear Generating Plant December 20, 2023 3 l TBPLS Firm #10074302 observed

. Many of the larger populations contained eastern red cedars in shrub/sapling form.

5.0 Summary Westwood identified approximately 12,000 specimens of eastern red cedar within the approximately 2,000-acre Project Area for the Monticello Nuclear Generating Plant. Additional follow-up investigations for northern wild rice will be conducted in 2024 during their peak growing season, which is between July and October.

6.0 References Cited Kjerland, T. 2015. Wild Rice Monitoring Field Guide. The University of Minnesota Sea Grant Program, Publication #SH15 (2nd ed.) ISNB 978-0-9965959-0-2.

Kjerland, T. 2015. Wild Rice Monitoring Handbook. The University of Minnesota Sea Grant Program. Publication #SH16.

Minnesota Department of Natural Resources (MnDNR). 2023. Ecological Classification System.

Available online, https://www.dnr.state.mn.us/ecs/222Mc/index.html, accessed November 2023.

United States Environmental Protection Agency (EPA). 2023. Ecoregion Download Files-Minnesota Level IV Shapefile. Available online, https://www.epa.gov/eco-research/ecoregion-download-files-state-region-5#pane-21, accessed October 2023.

White, Dennis. 2020. Ecological Regions of Minnesota: Level III and IV maps and descriptions.

U.S.

Environmental Protection Agency.

Available

online, https://gaftp.epa.gov/EPADataCommons/ORD/Ecoregions/mn/mn_eco_desc.pdf, accessed October 2023.

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Exhibits Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota Monticello Nuclear Generating Plant L-MT-24-005 Enclosure 01 Page 7 of 26

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2 RAI GW-5 Water Resources - Groundwater Supplement

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 2 Page 1 of 2 Topic: Water Resources - Groundwater RAI GW-5:

REQUIREMENT: 10 CFR 51.45(c) and 51.53(c)(2) requires that the ER include a description of the affected environment.

ISSUE: On November 22, 2022, Xcel Energy notified the NRC and State officials that tritium concentrations above the offsite dose calculation manual and Nuclear Energy Initiative Groundwater Protection Initiative reporting levels had been detected in an onsite monitoring well.

Section 3.6.4.2.1 of the ER discusses historical inadvertent releases of radionuclides to groundwater, but no discussion or assessment of the November 2022 leak of water containing tritium is provided.

REQUEST:

(2g) A description of the current plan, subject to change, for remediation/mitigation of the groundwater tritium contamination, including:

- location of the cutoff wall,

- locations of hydraulic control pumping wells,

- estimated pumping rates of the hydraulic control pumping wells,

- disposition of the water pumped for hydraulic control,

- criteria to terminate pumping of tritium recovery wells and hydraulic control wells, and

- estimated time to remediate the tritium contamination.

Response to RAI GW-5 (2g):

As of August 18, 2023, Figure 4 shows the approximate location of the sheetpile containment structure (cutoff wall) and the proposed approximate location for the gradient control wells and discharge piping.

The estimated pumping rates for the gradient control wells are 100-200 gallons per minute. The rates will adjust based on river level and hydraulic conditions at the station (i.e., drought versus flooding). The gradient control wells will be issued a water appropriation permit by Minnesota Department of Natural Resources. The gradient control wells will likely be discharged into the intake as shown in Figure 4.

NSPM remains dedicated to remediation of tritium in the groundwater and working with stakeholders to determine the appropriate steps that represents a successful completion of the remediation efforts. As the sheetpile containment structure and gradient control wells have not been finished, it is difficult to predict the time required to achieve the cleanup criteria.

Supplement to RAI GW-5 (2g) Response:

The NRC requested clarifying information regarding the gradient control wells. The three documents attached, Minnesota Department of Natural Resources (DNR) Water Appropriation Permit 2023-2958, Water Appropriation Permits Findings of Fact, and Carlson McCain Technical Memorandum provide the clarifying information regarding the gradient control wells.

Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 2 Page 2 of 2

References:

None.

Associated Attachments:

1. Minnesota Department of Natural Resources Water Appropriation Permit 2023-2958 issued to Northern States Power Company, Minnesota d/b/a Xcel Energy. Prepared for Northern States Power MN, d.b.a. Xcel Energy. January 25, 2024. 4 p.
2. Minnesota Department of Natural Resources Permit Application Findings of Fact Water Appropriation Permit 2023-2958 issued to Northern States Power Company, Minnesota d/b/a Xcel Energy. January 16, 2024. 3 p.
3. Carlson McCain Technical Memorandum Regarding MNGP Gradient Control Well Pumping Monticello, Minnesota. Prepared for Northern States Power Company, Minnesota d/b/a Xcel Energy, February 7, 2024. 4p.

2 Minnesota Department of Natural Resources Water Appropriation Permit 2023-2958.

Well Installation #1: 6.0 inches diameter, 42.0 feet depth, 150 gpm, unique number 872477 Point(s) of Taking UTM zone 15N, 433773m east, 5020392m north SWNW of Section 33, T122N, R25W Well Installation #2: 6.0 inches diameter, 49.0 feet depth, 150 gpm, unique number 872478 Point(s) of Taking UTM zone 15N, 433672m east, 5020296m north SWNW of Section 33, T122N, R25W Well Installation #3: 6.0 inches diameter, 50.0 feet depth, 150 gpm, unique number 872479 Point(s) of Taking UTM zone 15N, 433608m east, 5020240m north SWNW of Section 33, T122N, R25W Well Installation #4: 6.0 inches diameter, 55.0 feet depth, 150 gpm, unique number 872480 Point(s) of Taking UTM zone 15N, 433523m east, 5020190m north NWSW of Section 33, T122N, R25W Well Installation #5: 6.0 inches diameter, 50.0 feet depth, 20 gpm, unique number 872481 Point(s) of Taking UTM zone 15N, 433368m east, 5020271m north NESE of Section 32, T122N, R25W 01/25/2024 01/25/2024 Long-Term Appropriation Issued Date:

Effective Date:

Expiration Date:

Area Hydrologist James Bedell 320-223-7850 james.bedell@state.mn.us Authorized Issuer:

Title:

Email Address:

Phone Number:

This permit is granted subject to the following CONDITIONS:

LIMITATIONS: (a) Any violation of the terms and provisions of this permit and any appropriation of the waters of the state in excess of that authorized hereon shall constitute a violation of Minnesota Statutes, Chapter 103G. (b) This permit shall not be construed as establishing any priority of appropriation of waters of the state. (c) This permit is permissive only. No liability shall be imposed upon or incurred by the State of Minnesota or any of its employees, on account of the granting hereof or on account of any damage to any person or property resulting from any act or omission of the Permittee relating to any matter hereunder. This permit shall not be construed as estopping or limiting any legal claims or right of action of any person other than the state against the Permittee, for any damage or injury resulting from any such act or omission, or as estopping or limiting any legal claim or right of action of the state against the Permittee, for violation of or failure to comply with the provisions of the permit or applicable provisions of law. (d) In all cases where the doing by the Permittee of anything authorized by this permit shall involve the taking, using, or damaging of any property, rights or interests of any other person or persons, or of any publicly owned lands or improvements thereon or interests therein, the Permittee, before proceeding therewith, shall obtain the written consent of all persons, agencies, or authorities concerned, and shall acquire all property, rights, and interests necessary therefore. (e) This permit shall not release the Permittee from any other permit requirements or liability or obligation imposed by Minnesota Statutes, Federal Law, or local ordinances relating thereto and shall remain in force subject to all conditions and limitations now or hereafter imposed by law. (f)

Unless explicitly specified, this permit does not authorize any alterations of the beds or banks of any public (protected) waters or wetlands. A separate permit must be obtained from the Department of Natural Resources prior to any such alteration.

FLOW METER: The Permittee shall equip each installation for appropriating or using water with a flow meter, unless another method of measuring the quantity of water appropriated to within ten (10) percent of actual amount withdrawn is approved by the Department.

CONDITIONS continued on next page...

Page 2 - Permit Number 2023-2958 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 02 Page 2 of 4

CONDITIONS (Continued from previous page)

WATER USE REPORTING: Monthly records of the amount of water appropriated or used shall be recorded for each installation. Such readings and the total amount of water appropriated or used shall be reported annually to the Director of DNR Ecological and Water Resources, on or before February 15 of the following year, via the MNDNR Permitting and Reporting System (MPARS) at www.mndnr.gov/mpars/signin. Any processing fee required by law or rule shall be submitted with the records whether or not any water was appropriated during the year. Failure to report shall be sufficient cause for terminating the permit 30 days following written notice.

MODIFICATION: The Permittee must notify the Commissioner in writing of any proposed changes to the existing permit.

This permit shall not be modified without first obtaining the written permission from the Commissioner.

TRANSFER OR ASSIGNMENT: Any transfer or assignment of rights, or sale of property involved hereunder shall be reported within 90 days thereafter to the Director of DNR Ecological and Water Resources. Such notice shall be made by the transferee (i.e., new owner) and shall state the intention to continue the appropriation as stated in the permit. This permit shall not be transferred or assigned except with the written consent of the Commissioner.

COMMISSIONER'S AUTHORITY: (a) The Commissioner may inspect any installation utilized for the appropriation or use of water. The Permittee shall grant access to the site at all reasonable times and shall supply such information concerning such installation as the Commissioner may require. (b) The Commissioner may, as he/she deems necessary, require the Permittee to install gages and/or observation wells to monitor the impact of the Permittee's appropriation on the water resource and require the Permittee to pay necessary costs of installation and maintenance. (c) The Commissioner may restrict, suspend, amend, or cancel this permit in accordance with applicable laws and rules for any cause for the protection of public interests, or for violation of the provisions of this permit.

PUBLIC RECORD: All data, facts, plans, maps, applications, annual water use reports, and any additional information submitted as part of this permit, and this permit itself are part of the public record and are available for public inspection at the offices of DNR Ecological and Water Resources. The information contained therein may be used by the Division as it deems necessary. The submission of false data, statements, reports, or any such additional information, at any time shall be deemed as just grounds for revocation of this permit.

MONITORING REQUIREMENTS: Minnesota Statutes 103G.282 authorizes the Department of Natural Resources to require permittees to install and maintain monitoring equipment to evaluate water resource impacts from permitted appropriations. You may be required to modify or install automated measuring devices and keep records for each installation. The frequency of measurements and other requirements will be based on quantity of water appropriated, source of water, potential connections to other water resources, nature of concern, and other relevant factors.

DROUGHT PLANNING: In accordance with M.S. 103G.293, all permits must be consistent with the drought response plan detailed in the Statewide Drought Plan at http://files.dnr.state.mn.us/natural_resources/climate/drought/drought_plan_matrix.pdf.

WELL SEALING: The permittee shall notify the Minnesota Department of Health prior to sealing, removing, covering, plugging or filling the well(s) from which the authorized appropriation was made. The well(s) must be sealed by a licensed well driller and in accordance with the procedures required under Minnesota Statutes 103I and Minnesota Rules 4725 as administered by the Minnesota Department of Health.

WATER USE CONFLICT: If notified by the DNR that a water use conflict is suspected and probable from your appropriation, based on confirmation of a formal well interference complaint or a preliminary hydrologic assessment, all appropriation authorized by this permit must cease immediately until the interference is resolved. The permittee may be required to obtain additional data to support the technical analysis, such as domestic well information within a radius of one and one-half miles of the production well. The permittee and impacted party may engage in a negotiated settlement process and there may be modifications made to this permit in support of conflict resolution.

WATER CONSERVATION: All practical and feasible water conservation methods and practices must be employed to promote sound water management and use the least amount of water necessary, such as reuse and recycling water, water-saving devices, and water storage.

DISCHARGE AUTHORIZATION: This permit is valid only in conjunction with all required discharge authorizations from local, state, or federal government units.

CONDITIONS continued on next page...

Page 3 - Permit Number 2023-2958 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 02 Page 3 of 4

Tim Crocker, EWR District Manager Whiteker, Leah, Contact; Northern States Power Company, Minnesota d/b/a Xcel Energy Trent Seamans, Conservation Officers, Big Lake Melissa Collins, DNR Regional Environmental Assessment Ecologist, Region 3 Vacant, DNR Wildlife, Sauk Rapids Joe Stewig, DNR Fisheries, Sauk Rapids Area Barry Rhineberger, County, Wright Daniel Nadeau, SWCD, Wright SWCD Luke Johnson, SWCD, Wright SWCD Hayden Stensgard, City, Monticello Angela Schuman, City, Monticello Ryan Melhouse, City, Monticello Rachel Leonard, City, Monticello Matt Leonard, City, Monticello Lloyd Hilgart, City, Monticello Ron Hackenmueller, City, Monticello Mario Fruccci, City, Monticello cc:

Page 4 - Permit Number 2023-2958 Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 02 Page 4 of 4

2 Minnesota Department of Natural Resources Permit Application Findings of Fact Water Appropriation Permit 2023-2958.

2 Carlson McCain Technical Memorandum Regarding MNGP Gradient Control Well Pumping Monticello, Minnesota.

MNGPGradientControlWellPumping Monticello,Minnesota

CarlsonMcCain,Inc.

Page2 well locations are shown on the attached Figure 1 and Table 1 provides a summary of the well constructiondetails.

Table1-GradientControlWellDetails Well ID Date Installed Unique Number Well Casing Well Screen DepthtoTop ofScreen(ft)

DepthtoBottomof Screen(Well)(ft)

MaximumRate (gpm)

GC1 8/30/2023 872477 6inchLCS 6inchSS 22 42 150 GC2 8/28/2023 872478 6inchLCS 6inchSS 29 49 150 GC3 8/28/2023 872479 6inchLCS 6inchSS 30 50 150 GC4 8/24/2023 872480 6inchLCS 6inchSS 35 55 150 GC5 8/23/2023 872481 6inchLCS 6inchSS 30 50 NotUsed

Thewellsareconstructedwith6inchlowcarbonsteel(LCS)wellcasingand20feetof6inchstainless steel(SS)wellscreensettodepthsrangingfrom42to55feet.Submersiblewellpumpswillbepositioned nearthemidpointofthe20footwellscreenandthewellsaredesignedtooperatewiththepumping levelnearthetopofthewellscreen.ThewellpumpsatGC1throughGC4willbeequippedwith variablefrequencydrives(VFDs)andareintendedtooperateatratesrangingfromapproximately50to 150gallonsperminute(gpm)basedontheelevationofthewatertable.

ANALYSIS

Afterconstructionofthegradientcontrolwells,18hourpumpingtestswereconductedateachwellwith rates ranging from 100 to 180 gpm. A summary of the test data is provided on Table 2. Maximum drawdownobservedatthewellsduringtestingrangedfromapproximately2.4to5.7feet.Anearby observationwellwasalsomeasuredduringeachtestwhereobserveddrawdowndidnotexceed0.20feet atdistancesof208to324feetfromthecorrespondingpumpingwell.

Table2-PumpingTestSummaries TestatWell:

GC1 GC2 GC3 GC4 GC5 PumpingRate,gpm 100 100 175 180 10 StaticWaterElevation,feet 905.64 906.89 906.96 907.01 908.68 FinalPumpingElevation,feet 902.95 904.44 901.21 902.63 899.01 DrawdownAfter~18hours 2.69 2.45 5.75 4.38

~10 DistancetoObservationWell,feet 208 324 214 232

DrawdownatObservationWell,feet 0.17 0.01 0.20 0.17

gpm/ftofDrawdownfromTest 37.2 40.9 30.4 41.1

<1 ApproximateDrawdowninfeetatMin/MaxPumpingRates ApproximateDrawdownat150gpm(Max) 4.03 3.67 4.93 3.65

ApproximateDrawdownat50gpm(Min) 1.34 1.22 1.64 1.22

The relatively small amount of drawdown observed during the tests is characteristic of the highly transmissiveglacialoutwashdepositsinwhichthegradientcontrolwellsarefinished.Drawdownis Monticello Nuclear Generating Plant Docket 50-263 L-MT-24-005 Enclosure 02 Page 2 of 4

MNGPGradientControlWellPumping Monticello,Minnesota

CarlsonMcCain,Inc.

Page3 greatestatthepumpingwell(s)anddiminishesrapidlywithdistancefromthewell.Giventhefactthat thenearestgradientcontrolwellisapproximately2,000feetfromthesiteboundary,and2,900feetfrom thenearestknowndomesticwell,itishighlyunlikelythattheplannedoperationofthegradientcontrol wellswouldadverselyimpactoffsitewatersuppliesorgroundwateravailability.

Additionally, the Minnesota Department of Natural Resources (DNR) has issued MN DNR Water AppropriationPermitNo.20232958foruseofthegradientcontrolwellsandindoingsoissuedthe followingconclusionaspartofitsPermitApplicationFindingsofFact:

ToevaluatetheaquifercharacteristicsDNRGeotechnicalstaffreviewedthesubmitted documentsanddeterminedthatthisapplicationwilllikelynotcauseanegativeimpactto resourceswithinthe1.5mileradius.Themodelreviewshowedthatthedrawdownwill notreachdomesticwells.

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