ML26050A453

Long Mott Draft Hcr Section - March 2026

ML26050A453
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Issue date:	03/02/2026
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3-1 Draft Environmental Assessment Historic and Cultural Resources Section Regarding a Construction Permit for the Long Mott Generating Station Docket No. 50-614 March 2026

3-2 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS 3.8 Historic and Cultural Resources This section describes the cultural background and the historic and cultural resources at the Long Mott Generating Station (LGMS) site and its surrounding area. The National Environmental Policy Act of 1969, as amended (NEPA; 42 United States Code [U.S.C.] 4321 et seq.) (TN661) requires Federal agencies to consider the potential effects of their actions on the affected human environment, which includes aesthetic, historic, and cultural resources as these terms are commonly understood, including such resources as sacred sites. Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA) (54 U.S.C. § 306108-TN4839),

requires Federal agencies to consider the effects of their undertakings on historic properties.

While NHPA emphasizes impacts on historic properties, for NEPA compliance, impacts on cultural resources that are not eligible for or listed in the National Register of Historic Places (NRHP) would also need to be considered. In accordance with Title 36 of the Code of Federal Regulations (36 CFR) Section 800.8(c) (TN513), the U.S. Nuclear Regulatory Commission (NRC) complies with the obligations required under NHPA Section 106 through its process under the NEPA.

Historic and cultural resources describe material culture left behind from past human activity.

These resources include sites, objects, landscapes, structures, or other natural features of significance to groups of people who have traditional association with it. Historic properties are defined as resources eligible for listing in the NRHP. The NRHP is the Nations official list recognizing buildings, structures, objects, sites, and districts of national, State, or local historical significance which merit preservation. The criteria for eligibility are listed in the 36 CFR 60.4 (TN1682) and include (A) association with significant events in history; (B) association with the lives of persons significant in the past; (C) embodiment of distinctive characteristics of type, period, or construction; and (D) sites or places that have yielded, or are likely to yield, important information.

3.8.1 Affected Environment The proposed action is the issuance of a construction permit (CP) for the construction of the LGMS reactor. The Area of Potential Effects (APE) consists of approximately 1,537 acre (ac)

(622 hectares (ha)) of the LGMS site and represents the location and extent of areas required for all LMGS-related construction and operation activities. A 0.5 mile (mi) (0.8 kilometer (km))

buffer has been incorporated to account for potential indirect impacts on architectural resources and historic properties, if present (Figure 3-1). This determination is made irrespective of land ownership or control.

3-3 Figure 3-1 Archaeological Area of Potential Effect at the Long Mott Generating Station Site

3-4 Cultural Background Documented human occupation in Texas began prior to the Paleoindian Period, roughly 20,000 years ago. Two archaeological sites are known to contain deposits dating to this time.

The Gault site in Central Texas has well-dated archaeological deposits dating before the academically accepted earliest known occupation, Clovis, associated with the Paleoindian period. Excavations have yielded lithic artifacts and other cultural material (large bifaces, macro-blades, flaked tools) predating Clovis culture, dating between 22,000 and 16,000 years ago (TSHA 2025-TN12506). The Debra L. Friedkin site in Bell County, Texas is another pre-Paleoindian site, with archaeological evidence of early site use starting approximately 16,000 years ago (Waters et al. 2018-TN12507).

The Paleoindian Period (13,500-8,000 BC) is typically characterized by small groups of highly mobile nomadic hunters who followed big game such as mammoths, mastodons, and bison across the landscape. The Clovis and Folsom cultures typically represent this period. Locally, the Golondrina Complex (~10,000 years ago) is a hallmark of the South Texas Plains, while the Angostura and Scottsbluff point types mark the transition into the Early Archaic phase (Hester Undated-TN12509). Clovis points has been found near Port Lavaca, along Oso Creek, and in San Patricio County (TSHA 2025-TN12510).

The Archaic Period (8,000 BC-AD 700) represents a continuation of the hunter/gatherer subsistence economy practiced during the Paleoindian Period. The archaeological record reveals a shift in settlement patterns during this period. People adapted to warmer environments, expanding plant and small-game foraging, and developing specialized tools.

Toolkits from this period show the predominance of hand stones and milling slabs for the processing of hard seeds and other plant foods. The Archaic Period is divided into the Early, Middle, and Late eras. The Early Archaic in the Coastal Bend is typified by stemmed points such as Baird and Taylor-style projectiles, documented from the coast into the interior of the state. The Middle Archaic Period is mainly typified by Calf Creek points. Typical Late Archaic projectile varieties across South Texas include Ensor, Frio, Fairland, and Ellis styles (TSHA 2025-TN12510).

The Late Prehistoric Period (AD 700-1500) in south Texas is characterized by the emergence of the bow and arrow and intensified use of coastal and inland resources. Scallorn, Edwards, and Zavala points began to emerge around 1,300 years ago (TSHA 2025-TN12510). Other material culture such as perforators, small and large end scrapers, and flake knives have also been noted in Late Prehistoric sites. The Kirchmeyer site in Calhoun County represents Late Prehistoric activity in the region. Artifacts identified at the site have included Rockport-style ceramics and metal fragments, noting transitions into early colonial settler times.

Mesoamerican-influenced artifacts have also been identified in this region. Taylor (2025-TN12513) analyzed 29 human bone artifacts from multiple Late Prehistoric sites in South Texas that have appeared to have been modified into musical instruments, similar to the Aztecs omichicahuaztli, musical rasps made out of femurs (Taylor 2025-TN12513).

The Long Mott area of Texas was inhabited by the Karankawa Tribe prior to European exploration (Ricklis 1996-TN12224). The Karankawas people relied heavily on the coastal estuaries for their diet, which included fish, shellfish, bison, and deer (Lipscomb and Seiter 2020-TN12225). Their subsistence methods involved hunting, fishing, and gathering, adapting to the seasonal availability of food. The Tribes first recorded interaction with Europeans occurred in 1528, documented by lvar Núnez Cabeza de Vaca, a survivor of Pánfilo de Narváez's 1527-1528 expedition, who provided crucial ethnological insights into their way of life

3-5 (Johnson 2020-TN12226). Although these early encounters introduced European diseases, it was not until over a century later that substantial European interactions occurred (Lipscomb and Seiter 2020-TN12225). The Spanish attempted to convert the Karankawa to Christianity by establishing missions like Mission Espíritu Santo in Goliad, about 45 mi (72 km) northwest of the project area (Roell 2017-TN12227). Following Mexican independence in the 1820s, changes in land distribution began, which were further influenced by Texass independence in 1836, leading to shifts in settlement patterns and land use (Davis 2016-TN12237).

Historic and Cultural Resources at LMGS In Texas, the Texas Historical Commission (THC) is responsible for administering Federal and State-mandated historic preservation programs to identify, evaluate, register, and protect the States archaeological and historic resources under the direction of the Texas State Historic Preservation Officer. The THC maintains the Texas Archeological Sites Atlas (Atlas) electronic database, which inventories all the registered cultural resources within the state, including those within the LMGS vicinity. The NRC staff queried the Atlas database to gain a better understanding of the historic and cultural resources within the region. A 0.5 mi (0.8 km) radius was used to identify all historic properties that could be potentially affected by the undertaking.

The Atlas search indicated that there are no previously recorded archaeological sites, historic buildings, or historic properties within the archaeological APE or 0.5 mi (0.8 km) buffer area.

The closest historic property to the project area is the Victoria Barge Canal, just over 1.5 mi west of the project area. In 1945, Congress authorized the construction of the 35 mi (56 km) long canal through the Rivers and Harbors Act of 1945. Construction on the Calhoun County portion began in 1954 and extended into Victoria County in 1958 (TSHA 2021-TN12602).

Today, the USACE maintains the canal. In addition to the canal being a significant economic resource for the county, it is also a recreational spot for general aquatic activities and fishing.

The canal was determined eligible for listing on the NRHP in 2023 under Criterion A for its association with maritime history, industry, and transportation on a local level (Stantec 2023-TN12239).

Although not considered eligible for the NRHP, the Moreman Community Cotton Gin is within the 0.5 mi (0.8 km) buffer area, about 2,526 feet (ft) (770 meter (m)) north of the APE. The gin is part of a complex that originated in 1934 and is recognized as being one of the earliest cotton gins in the area. In 2016, the State added a historical marker near the property noting its importance as a community center and its contribution to the countys early economic development in the early 1900s. Over the years, the complex has been heavily modified to its current state but still continues to operate today, providing economic and industrial opportunity to local cotton farmers (LME 2025-TN12251; THC 2020-TN8672).

Long Mott Energy (LME) indicated that no Traditional Cultural Properties (TCPs) are recorded within the APE or within a 1 km (mi) buffer surrounding the APE. Further, LME confirmed that no potential TCPs were identified during WSP USA Environment & Infrastructure, Inc.s (WSPs) survey (LME 2025-TN12596). To date, no TCPs have been identified by NHPA Section 106 consulting parties.

Previous Surveys Two previously conducted archaeological surveys are recorded in the Atlas (#8400009819 and

1. 8400009824). However, the Atlas provides no details regarding the purpose of the surveys, the investigating firm, the sponsoring agency(ies), or the results of the field investigation. The only

3-6 information provided is that both surveys occurred sometime in May 2001. Both surveys are over 1,312 ft (400 m) northeast of the APE (THC 2020-TN8672).

One built environment survey has been conducted in the project area. Between October 2021 and October 2022, Johnson, Mirmiran & Thompson, Inc. (now Stantec), conducted a countywide built environment survey across four counties (Aransas, Calhoun, Jefferson, and Refugio) to document and assess impacts to historic resources that resulted from Hurricane Harvey. In Calhoun County specifically, 2,973 historic-age resources were documented and evaluated for potential listing on the NRHP. This consisted of 2,917 historic age buildings, 27 sites, objects, and structures, 20 neighborhoods/communities constructed after World War II (WW-II), six mobile home communities, and three industrial complexes. Of the 2,973 documented resources, 2,896 resources were recommended not eligible for the NRHP, 43 properties were recommended eligible, two resources were already listed on the National Register (the La Salle monument and the Matagorda lighthouse) and three historic districts were recommended eligible for listing on the NRHP: Port Lavaca, Lynnhaven, and Point Comfort. The Port Lavaca historic district was inventoried individually and collectively as a historic district due to the number of resources within the district that were constructed prior to WW-II. Stantec recommended 29 properties as contributing to the district and 6 properties as non-contributing to the district. The Point Comfort district had been previously determined eligible, therefore Stantec reassessed the district and maintained its eligibility determination. Due to all the buildings being constructed after 1949, Lynnhaven was recorded as one resource, consistent with the survey methodology approved by the THC (Stantec 2023-TN12239).

Resources inventoried by Stantec that are close to the project area include the Union Carbide Corporation Plant Complex (constructed in 1954), the Dow Seadrift Operations Industrial Park (constructed ca. 1970), and 6 buildings constructed around the 1950s: 2 agricultural buildings, 3 domestic buildings, 1 commercial building, and the previously aforementioned Victoria Barge Canal. With the exception of the canal, all were recommended not eligible for the NRHP (THC 2025-TN12238; Stantec 2023-TN12239).

New Surveys To support NRCs environmental review, LME contracted environmental firm WSP in 2023 to complete archaeological and architectural surveys of the proposed action area for the submittal of the CP application.

For the archaeological survey, WSP surveyed a total of 1,548 ac (626 ha) but documented the results in two separate reports. The first report covered 617 ac (250 ha) surveyed for the Department of Energys (DOE) funding action pertaining to siting activities at LMGS (Hunter and Cantrell 2023-TN12277). The remaining 930 ac (376 ha) were documented in the supplemental report included in LMEs Environmental Report (LME 2025-TN12251). Prior to the field investigation, WSP provided its planned methodology to THC for their concurrence, which occurred June 7, 2023 (LME 2025-TN12596). A total of 382 shovel tests were excavated across the APE in 75-100 m (246-328 ft) intervals. Although 75 m (246 ft) exceeds the suggested 30 m (100 ft) interval recommended by the Council of Texas Archaeologists, the intervals were deemed appropriate by THC for the project area due to the disturbed nature of the APE resulting from the industrial development in the area. No cultural resources were identified in the survey. THC concurred with WSPs determination of No Historic Properties Affected February 16, 2024 (LME 2025-TN12163).

3-7 An architectural survey was conducted the same week as the archaeological survey. A total of 10 historic-age properties were identified within 0.5 mi (0.8 km) of WSPs architectural APE.

Seven of the resources were previously documented by Stantec in their 2021-2022 county-wide historic resources survey. In addition to re-visiting the properties Stantec recorded, WSP identified and recorded three additional new resources in their survey (AR 2, AR 3, and AR 7).

AR 2 consists of the remnant structural foundations and one extant structure of the former GAF Chemicals Corporation (now ISP Technologies, LLC) industrial facility, located northeast of State highway 185. AR 3 is about 850 m (0.5 mi) northwest of AR 2 and consists of 2 utility structures associated with the former GAF Chemicals Corporation. AR 7 is a residential building constructed in 1965. None of the resources inventoried during WSPs survey were recommended eligible for the NRHP. THC concurred with the recommendation February 16, 2024 (LME 2025-TN12163).

Consultation The NRC initiated NHPA Section 106 consultation with the Advisory Council on Historic Preservation (NRC 2025-TN12515), the THC (NRC 2025-TN12536), and 21 federally recognized Tribes (NRC 2025-TN12537). In the letters, the NRC provided information about the proposed action, defined the APE, and indicated that the NHPA review would be integrated with the NEPA process in accordance with 36 CFR 800.8(c). Responses were received from the THC (THC 2025-TN12538), the Advisory Council on Historic Preservation (ACHP 2025-TN12539), Kickapoo Tribe of Texas (NRC 2025-TN12568), the Comanche Nation (Comanche Nation 2025-TN12612), and the Cherokee Nation.

3.8.2 Environmental Impacts of Construction Construction can be the most impactful activity to cultural resources due to ground-disturbing activities associated with excavation, vegetation clearing, utility installation, and facility construction. In this case, the project area has been impacted by previous construction activities, including the construction of the existing Seadrift plant and surrounding facilities. The area has also been impacted by ongoing farming and cultivation. In September 2025, DOE analyzed and approved ground-disturbing activities as part of site characterization and environmental monitoring activities within the project footprint of the current proposed action (DOE 2023-TN12667). The installation and sampling activities reviewed in September 2025 are considered preconstruction activities under NRCs regulatory purview; therefore, they are mentioned as known impacts from construction but not analyzed as part of the proposed action.

Scope reviewed included sampling and characterization of water, soil, rock, or contaminants, installation and operation of field instruments, well drilling for sampling and monitoring of groundwater, installation and operation of air monitoring equipment, and the installation, operation, and monitoring of a 200 ft (60 m) meteorological tower (LME 2025-TN12596). Based on the negative findings of cultural resources from WSPs archaeological surveys (Hunter and Cantrell 2023-TN12277; LME 2025-TN12251), DOE determined that the activities would not impact historic and cultural resources within the project area.

For the proposed action, it is expected that little to no impacts to historic and cultural resources or historic properties are to occur within the APE. However, construction activities typically excavate at deeper depths than archaeological surveys do. If cultural resources were to be inadvertently discovered, they would most likely be in disturbed contexts. Based on confirmatory information provided by the applicant, LME intends to have an Inadvertent Discovery Plan in place prior to the beginning of construction to cover the inadvertent discovery of cultural resources, if applicable (LME 2025-TN12596). Indirect impacts from construction (visual or

3-8 auditory) to historic properties such as the NRHP-eligible Victoria Barge Canal would be temporary. Any impacts would most likely be limited by the existing Seadrift Operations Facility, existing structures, vegetation, and local terrain.

3.8.3 Environmental Impacts of Operation As previously stated, the majority of impacts to historic and cultural resources and/or historic properties mostly result from physical ground-disturbing activities. Once the plant is operational, it is expected that there would be little to no impacts to potential unknown cultural resources in the area. If additional ground-disturbing operational or maintenance activities were to occur, it would most likely occur in previously disturbed contexts impacted by the aforementioned construction described in Section 3.8.2. Similar to construction impacts, indirect impacts from plant operation to historic and cultural resources and historic properties within the region would most likely be limited by the existing Seadrift Operations facility, structures, vegetation, and local terrain.

3.8.4 Environmental Impacts of Decommissioning Impacts from decommissioning are expected to be similar to those described in Sections 3.8.2 and 3.8.3. Further analysis of potential impacts would be assessed when the applicant submits a license amendment request for decommissioning activities. For the proposed action, because there are no known historic and cultural resources or historic properties within the APE or within 0.5 mi (0.8 km) of the APE, impacts would not be expected.

3.8.5 Conclusions For the purposes of NHPA, the proposed action would result in No Historic Properties Affected, as defined in 36 CFR 800.4(d)(1) (TN513). There would be no impact to historic and cultural resources. The NRC staff determined that impacts to historic and cultural resources related to the activities from construction, operations, and decommissioning the LMGS would not be significant.

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36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 800, Protection of Historic Properties. TN513.

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Comanche Nation. 2025. Letter from T.E. Villicana, Technician, Comanche Nation Historic Preservation Office, to A. Muniz, NRC, dated June 6, 2025, regarding Re: Acceptance or Docketing of The Long Mott Generating Station Construction Permit Application Submitted by Long Mott Energy, LLC, L-EPID-2025-LRM-0035). Lawton, Oklahoma. ADAMS Accession No. ML25160A180. TN12612.

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