ML24164A240
| ML24164A240 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/10/2024 |
| From: | Spong A State of MN, Dept of Admin., State Historic Preservation Office |
| To: | Rome M NRC/NMSS/DREFS |
| Nancy Martinez | |
| References | |
| Download: ML24164A240 (1) | |
Text
June 10, 2024 VIA E-MAIL
Michelle Rome, Chief Environmental Technical Review Branch 1 Division of Rulemaking, Environmental and Financial Support Office of Nuclear Material Safety and Safeguards Mailstop: T-4B72 U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001
RE: Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1, Subsequent License Renewal Application (Docket No. 50- 263)
Wright and Sherburne Counties, Minnesota SHPO No. 2022-1087
Dear Michelle Rome,
Thank you for continuing consultation regarding the above -referenced federal undertaking which is being reviewed pursuant to the responsibilities given the State Historic Preservation Officer by Section 106 of the National Historic Preservation Act (54 U.S.C. § 306108) and its implementing federal regulations, Protection of Historic Properties (36 CFR Part 800).
We last wrote to your agency on August 21, 2023 providing comments regar ding your agencys definition of the federal undertaking subject to review under Section 106, corresponding documentation of the Area of Potential Effect (APE), and efforts to identify historic properties within the APE. Thank you for taking into considera tion comments and recommendations we provided in our August 21 st letter and during a subsequent meeting conducted on November 17, 2023. At this time, we have received your April 24, 2024 notice of availability of the Draft Site-Specific Environmental Impact Statement and your May 9, 2024 continuation of consultation under Section 106 of the National Historic Preservation Act (54 U.S.C. § 306108) and its implementing federal regulations, Protection of Historic Properties (36 CFR Part 800). These submittals included the following documentation in support of your agencys determination that the undertaking will not adversely affect historic properties:
- Site-Specific Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 26, Second Renewal Regarding Subsequent License Renewal for Monticello Nuclear Generating Plant, Unit 1 Draft Report for Comment (Office of Nuclear Material Safety and Safeguards, April 2024);
- Survey of Culturally Sensitive Plant Species Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota (Westwood Professional Services, December 2023; the Plant Survey Report ); and
- Phase IA Cultural Resources Literature Search and Site Visit Monticello Nuclear Generating Plant Wright and Sherburne Counties, Minnesota (Westwood Professional Services, January 2024; the Westwood Report ).
Define Federal Undertaking and Area of Potential Effect We understand by your initial letter that the undertaking subject to review under Section 106 of the NHPA involves NRC renewal of the federal operating license for the Monticello Nuclear Generating Plant, Unit 1 (Monticello) for an additional twenty (20) years through September 8, 2050.
Your agency has defined the corresponding Area of Potential Effect (APE) to include g eographic areas within the Monticello site boundary, as well as transmission lines up to the first substation, that may be affected by activities associated with continued plant operation and maintenance and/or refurbishment activities and we agreed that the APE as described in your Marc h 13, 2023 letter and documented on Enclosure 3 of that submittal is consistent with how
MINNESOTA STATE HISTORIC PRESERVATION OFFICE 50 Sherburne Avenue Administration Building 203 Saint Paul, Minnesota 55155 651-201-3287 mn.gov/admin/shpo mnshpo@state.mn.us AN EQUAL OPPORTUNITY AND SERVICE PROVIDER Xcel defined the APE during informal consultation and is appropriate.
In subsequent consultation with our office, we recommended that your agency document and further define the scope of nuclear generating plant operations and maintenance activities that may fall under a renewed license application. This information will provide a clearer understanding of the nature of potential effects to historic properties, if any, and further justify the agencys APE definition and efforts to identify historic properties within the APE. We have now received documentation of this scope in your May 9, 2024 submittal and your April 24, 2024 notice of availability of the Draft Site -
Specific Environmental Impact Statement.
Identification of Historic Properties Historic/Architectural On February 27, 2023, our office concurred that neither Monticello Nuclear Generating Plant (WR -MCC-00052), nor the 27 structures and buildings documented in association with the plant (WR -MCC-00021 to WR-MCC-00047) were individually eligible for listing o n the National Register of Historic Places (NRHP) or part of an NRHP -eligible district. On August 21, 2023 we requested additional clarification from your agency regarding the presence or absence of any other above-ground resources 45 years old or older wi thin the APE. The Westwood Report clearly documented that there are no other above-ground resources 45 years old or older within the APE that are eligible for listing on the NRHP. In the Westwood Report, the only previously documented above -ground resource within the APE is Bridge No. 5434 (WR-MCT-00003), which is no longer extant. A review of our offices Minnesota Statewide Historic Inventory Portal (MnSHIP), we note one additional resource, US Trunk Highway 52 /Interstate 94 (XX-ROD- 00185) within the APE, however this resource was previously determined not eligible for listing on the NRHP.
Archaeology In our letter dated August 21, 2024, we recommended a Phase I archaeological survey of the APE be conducted, aided by documentation of previous disturbances within the APE related to the construction of the plant. We noted in our letter that we would reconsider the need for survey based on previous surveys and disturbances. In response to this recommendation, you have included the Westwood Report with your submittal. The Westwood Report includes background research and the results of a site visit. This report documented the extent of previous disturbances and recommended formal Phase I cultural resources survey for future unanticipated development at locations outside the facility. The Westwood Report also provided an overview of the lack of previously documented archaeological sites within the APE and the high probability for the undisturbed portions of the APE to contain archaeological sites. In y our letter, you state that Xcel Energy will update Monticellos procedures to stipulate:
- No further cultural resources work is required where deep-level disturbances (greater than 10 feet [3.0 meters])
have been documented (as shown in orange in Exhibit 2 9 of the Westwood Report).
- For projects that would take place at surface level or unknown depths of disturbance (as shown in green in Exhibit 29 of the Westwood Report), Xcel Energy will review projects with a Secretary of the Interior qualified archaeologist to determine the appropriate next steps based on that assessment (i.e. archaeological monitoring, survey).
- For projects where ground disturbance would occur in undisturbed areas (areas outside those shown in orange and green in Exhibit 29 in the Westwo od Report), a Phase 1 cultural resources survey will be conducted prior to any development.
- For projects where ground disturbance would occur outside the Monticello Nuclear Power Plant facility complext (shown in Exhibit 29 in the Westwood Report) and tha t are under control of the applicant, the Mille Lacs Band of Ojibwe will be notified and invited to monitor ground disturbing activities, except in the case of emergencies or other extenuating circumstances.
We recommend that the procedures also be updated to include consultation with our office and the other interested consulting parties regarding projects that will occur in areas of surface level or unknown depts of disturbance and undisturbed areas regarding the identification and assessment of effects to historic properties (i.e. the results of the monitoring and/or survey conducted).
Assessment and Finding of Effect Based on the information available at this time, we concur with your agencys finding that the proposed undertaking will have no effect on historic properties. However, if through the term of the 20-year license, ground disturbing projects are proposed that fall into the categories outlined above, Xcel Energy will follow their procedures which will be updated to include stipulations described in your letter, copied here, and amended to include consultation with our office and other interested consulting parties.
Pease contact Environmental Review Archaeologist Lucy Harrington at lucy.harrington@state.mn.us or (651) 201-3283 if you have any questions regarding our review of this project.
Sincerely,
Amy Spong Deputy State Historic Preservation Officer
Cc via email:
Nancy Martinez, NRC Jessica Umana, NRC