ML25163A011
| ML25163A011 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/10/2025 |
| From: | Mayer C State of IL, Dept of Natural Resources |
| To: | Stalker A Constellation Energy Generation, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML25163A011 (1) | |
Text
1 Various Counties Morris License Renewal, Dresden Nuclear Power Station 6500 N. Dresden Rd.
Goose Lake Prairie State Natural Area State Park - Country Road 5000 E White & Companys Goose Lake Stoneware Manufactury - 5010 N. Jugtown Rd. NRHP listed 8/6/1998 White & Companys Goose Lake Tile Works - 5010 N. Jugtown Rd. NRHP listed 8/6/1998 Dresden Nuclear Power Station - 6500 N. Dresden Rd., b.ca.1960-1979 SHPO Log #012103124 June 10, 2025 Allison Stalker Constellation Energy 200 Energy Way Kennett Square, PA 19348 We have reviewed the information provided for the above referenced project. Our review is required by Section 106 of the National Historic Preservation Act of 1966, as amended, and its implementing regulations, 36 CFR 800: "Protection of Historic Properties."
At this level of the undertaking, SHPO is only reviewing the "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants, Supplement 17, Second Renewal: Draft Report for Comment" that was submitted to our office on May 22, 2025.
Our office does not concur with the determination of eligibility presented in the architectural survey that found none of the structures to be individually eligible for the National Register of Historic Places. We would ask for additional consideration of the facility as a "...pioneering facility in the history of the nuclear power in the U.S.," as stated in your report (p. 5).
Page 29 of the report states that, "In October 1991, the American Nuclear Society (ANS) designated the Unit 1 containment building a Nuclear Historic Landmark (ANS 2025), [which] acknowledges a historic event or activity [which] successfully provided an essential contribution to, or basis for, the subsequent peaceful application of nuclear technology or nuclear energy, and been a first of a kind, or provided a signific new departure (ANS 2025). The award acknowledges Unit 1s status as the first commercially funded nuclear reactor. Page 31 says, The Unit 1 Reactor building represents the first commercially funded nuclear plant in the United States, and is significant under Criterion A for this association, and, The facilitys significance under Criterion A is specifically associated with its function as the first privately funded nuclear reactor building.
We do not agree with the finding that appears later in the report that the facility is not significant under Criterion C, as explained by the idea that it, 1) "...was not the first containment building constructed in the United States..." and that its 2) "... spherical shape also represents a containment building type popular
2 among nuclear facilities constructed in the 1960s and 1970s...," 3) was replaced, "... in favor of reinforced concrete cylindrical shapes...," and 4) "lacks engineering distinction, is not the work of a master, does not possess high artistic values," and 5) is "... therefore is not significant under Criterion C.
Though the facility is not the first of its kind, it is significant as the first to be commercially funded. Though other spherical containment buildings were built in the 1960s and 70s, Dresden was built in 1960, before the others; engineering distinction is asserted at the beginning of the report.
The American Nuclear Society expressed its significance for over 35 years, and though we do not consider the facility to be the work of a master or hold high artistic value, Dresden, according to Criterion C, Embod[ies]
distinctive characteristics of a type, period, or method of construction. The spherical shape, even though later was discarded in favor of other shapes, remains significant (as many historic resources represent a form that has been abandoned or changed in favor of something more modern).
Additionally, despite the facility no longer operating in its original capacity, it remains significant as would a water tower, gas station, or other functional building or structure that derives significance but no longer functions as it once had. Despite the abandoned, removed, and/or repurposed components, we do not find a lack of integrity for the Unit 1 Reactor Building.
Finally, we consider the facility to hold national, state, and local significance, which is evidenced by the American Nuclear Society's designation of it as a Nuclear Historic Landmark, as a model for privately financed nuclear power, as a contributor to power grid stability, and as foundation of the state and local economies.
SHPO proposes that the draft be re-reviewed and the site is evaluated as a possible historic district.
If you have any further questions, please contact Rita Baker, Cultural Resources Manager, at (217) 785-4998 or at Rita.E.Baker@illinois.gov.
Sincerely, Carey L. Mayer, AIA Deputy State Historic Preservation Officer c: Jennifer Davis, United States Nuclear Regulatory Commission