ML18219A543

Forwards Reply to the Archaeology and Historic Site Comments from Dept. of Interior of Jan. 15, 1976

ML18219A543
Person / Time
Site:	Palo Verde
Issue date:	02/10/1976
From:	Van Brunt E Arizona Nuclear Power Project
To:	Regan W Office of Nuclear Reactor Regulation
References
Download: ML18219A543 (7)

Text

100 4 ALCYCLKD PAPLII ARIZONA NUCLEAR POWER PROJECT Post Office Box 21666 oenix. Arizona 85036 gguqatory Docket Fiji February 10, 1976

't.5.%>-

W. H. Regan, Jr., Chief FEB 1819~7'ID

~~II

':~'E Environmental Projects Branch 3 g T.LGvLAICLT OLLILISSION U. S. Nuclear Regulatory Commission l~toa Washington, D. C. 20555

Reference:

Docket Nos. STN 0-5 STN 50-529 an'd'TN 50- 0'

Dear Mr. Regan:

We have examined the U. S. Department of the Interior's letter of January 15, 1976 commenting on the Draft Supplement to .the Final Environmental Statement.

We would like to reply to the archaeology and historic site comments and have herewith attached our responses.

Pursuant to 10 CFR 2.712, copies of this letter and the Applicants'esponses to the U. S. Department of the Interior's Comments on the Draft Supplement to the Final Environmental Statement have been served on the persons listed in the attached certificate of service.

Respectfully submitted, ARIZONA PUBLIC SERVICE COMPANY g4 gy By Q5 'dwin E. an Brunt, Jr.

Vice President, Nuclear Services tILLLLL On its own behalf and as agent for all other joint applicants LES

.Southern California Edison Com>any ANPP participants: Arizona Public service company ~ xocsaaxP5arMtetÃKKK5PAp~, A salt River. Project Arizona, Electric Power Cooperative, Inc. ~ Public Service Company of New'Mexico ~ El Paso Electric Company

lpga]gpg Docket, te CERTIFICATE OF SERVICE It is hereby certified that true and correct copies of the Applicants'omments to the Draft .Supplement to Final Environmental Statement for Palo Verde Nuclear Generating Station, Units 1, 2 and 3, filed in NRC. Docket Nos. STN 50-528/

50-529 and 50-530, together with the letter, dated February 10, 1976, transmitting said comments, have been placed in the United States mail, postage prepaid, this 10th day of February, 1976 to the following:

Mr. Hugh- K. Clark, Chairman Atomic Safety and Licensing P. O. Box 127A Board Panel Kennedyville, MD 21645 U. S. Nuclear Regulatory Commission Dr. Kenneth A. McCollom Washington, D.C. 20555 Associate Dean College of Engineering Atomic Safety and Licensing Oklahoma State 'University Appeal Board Stillwater, OK 74074 U. S., Nuclear Regulatory Commission Dr. Quentin J. Stober Washington, D.C.. 20555 Research Associate Professor Fisheries Research Institute Docketing and Service University of Washington Section Seattle, WA '98195 Office of'he Secretary U. S. Nuclear Regulatory Stephen H. Lewis, Esp. Commission Stephen M. Sohinki, Esp. Washington,, D.C. 20555 Regulatory Staff Counsel U. S. Nuclear Regulatory .Commission Washington, D.C. 20555 Andrew W. Bettwy, Esq.

Assistant Attorney General 159 State Capitol 1700 West Washington Phoenix, AZ 85007 C ar es R. Koc er Assistant Counsel Southern California Edison Co.

e

~ ~

~Res ense Copies of archaeol'ogical reports prepared by and for Southern California Edison will be filed with the Western Archaeological Center of the Hational .Parks Service,. A copy of Southern California Edison's report entitled Palo Verde Nuclear Generating Station Project Ho., 4 Transmission System Environmental Analysis was sent to Mr. John Clonts of the Western Archaeological Center, November 4, 1975. A copy of the attached preliminary report prepared by the Museum of Horthern Arizona for Southern California Edison's transmission line was mail.ed to Nr. Clonts on February 4, 1976.

Hemilato . Doc e ...ii TO THE U. S. DEPARTMENT OF THE ICE 'ESPONSE COMMENTS ON THE DRAFT SUPPLEMENT TO THE FINAL ENVIRONMENTAL STATEMENT ARCHAEOLOGICAL AND HISTORIC SITES Comment Me are pleased to note the commitment made to full compliance with Executive Order 11593 and Title 36, CFR 800 (page S-10). However,. it is inappropriate under Section 2 (b) of Executive Order 11593 and the National Environmental Policy Act of 1969 to wait until the preconstruction phases to perform an archaeo-logical survey. The surveys and the evaluation of all identified sites for their National Register potential should be made early enough in the planning- stage of the project so results of this evaluation, and thus the results of the potential impacts of the various alternatives upon significant cultural resources, can

.be incorporated into the decision-making process for selecting the best alternative, preferably the one with the least impacts.

~Res ense Southern California Edison believes that the archaeo-logical and hi.storical'tudies performed to date are appropriate for the present level of development of the proposed project. As the project is further developed, more detailed archaeological and historical studies will be undertaken.

Southern California Edison Company currently has an application for. a Certificate of Environmental Compati-bility for a one-mile wide corridor before the Arizona Power .Plant and Transmission Line Siting Committee for the subject project as required by Arizona Revised Statutes Section 40.360, et seq. The archaeological and historical studies to date have been for the purpose of corridor selection only, not final right of way location. To conduct i.n-depth archaeological and historical surveys of a one-mile wide corridor for each possible alternative route alignment at this stage of the project would be prohibitively expensive and time consuming.

Therefore, Southet n California Edison has adopted a program wherein once a corridor is selected, intensive

archaeological and historical surveys of the proposed right of way, plus a fifty foot wide buffer zone to either side of the right of way, will be conducted by an independent consultant. The Museum of Northern Arizona has been issued a purchase order to conduct these surveys.

The data from the Museum's survey will be utilized in selecting transmission tower sites, access roads, marshalling areas and portable concrete batch plant locations to avoid impact to archaeological and his-torical resources to the maximum extent practicable as wel'1 as to aid the NRC in complying with Title 36 CFR 800, Executive Order 11593 and other applicable legislation.

Additionally, each transmission tower site, access road, marshalling yard and concrete batch plant location will be inspected by a professional archaeologist on the staff of Southern California Edison or by a consultant if the staff archaeologist is unavailable.

will be relocated when practicable to avoid any Facilities archaeological or historical resources discovered in this manner. Any relocation areas will also be surveyed and approved pt ior to finalizing plans.

Only when logical or it is infeasible to avoid impact to an archaeo-historical resource will physical mitigation measures such as excavation or surface collection be resorted to. Southern California Edison recognizes that this type of physical mitigation constitutes an "adverse effect" under 36, CFR 800 and would require implementation of the Procedures by the NRC.

It should be noted that thethatprogram described above is substantially similar to proposed by Mr. Bruce Kilgore of the,Western Pegional. Office of the National

,Park Service in his letter of January 12, 1976 to Mr. 'Hi11'iam H. Regan, of the NRC wi:th reference to Supplement 6 to t'e Palo Verde Nuclear Generating Station, Units 1, 2 and 3 Final Environmental Impact Statement.

Southern California Edison believes that the program described above is appropriate under Section 1(3) and 2(b) of Executive Order 11593 and NEPA, and will aid the NRC in fully complying with Title 36 CFR 800 in that the decision on the actual right of way location will be made after the detailed archaeological and historical surveys are compl.eted.

Comment The archaeologist's findings should be used to document the statements made about the potential impacts to cul-tural resources and a copy of the report, or an adequate summary, included in the final statement as an appendix.

The State Historic Preservation Officer should be asked to comment upon the undertaking. A copy of his comments should be included in the final statement. The final supplement should indicate that the National Register has been consulted and that no National Register properties are to be affected by the project.

~Res onse A discussion of the archaeological'nd historical studies performed prior to October 1975 is included in the Palo Verde Nuclear Generating Station Project No. 4 Trans-mission System Environmental Analysis proposed by Southern California Edison and cited as reference 1 in the NRC Draft Supplement A. A copy of a report prepared by the Museum of Northern Arizona for the project dis-cussing an archaeologica~l. site fi.l'e-search and .aerial reconnaissance. of the, alternative route alignments con-ducted between October 1:975 and January 1976 is attached.

Southern Californ.ia Edison, recommends that the NRC make formal contact with appropri'a'te State Historic Preserva-tion Officers as requi.red by Title 36:, CFR 800.4 (a)(2).

It is useful to note that the State Historic Preservation Officer for Arizona is a member of the Arizona Power Plant and Transmission Line Siting Committee referenced above and is familiar with the subject project through hearings before the Committee.

Comment Neither the presently available knowledge on the archaeo-logical resources which might be affected by the proposed project, nor projections of ar chaeological sensitivity may in any way be considered an adequate basis for the assessment of potential adverse effects. Sensitivity maps project areas of differential archaeological site densities. They represent probabilities as to certain archaeological remains occurring in particular areas based on actual field archaeological surveys of varying quality and over only a small percentage of the area.

Often such maps are projections based on present land-forms and water distributions coordinated with expected

occupational patterns of the prehistoric peoples. Thus, they are predictive .models and are not an adequate substitute for hard data. Until factual data are available in regard to the presence or absence and significance of archaeological resources along proposed channels and at spoil sites, it is impossible to evaluate either the impact of the project or its alterna-tives upon the archaeology of the area.

~Res onse Southern Gal'i forni a Edison would like to reemphas i ze the fact that at the present time approval is being sought only for a transmission line corridor, not .a final right of way. It is felt that sensitivity maps are appropriate to corridor selection. The "hard data" mentioned in the 1'ast sentence of the comment is being developed as discussed above, and wi-ll be available to state and federal agencies prior to Southern California Edison seeking approval of a final right of way.

Comment The proposed use of mitigative measures is inconsistent with Title 36, CFR 800 procedures. If archaeological sites which cannot be avoided are going to be excavated, then there will be significant impact upon such resources due to the construction of the project. Salvage excava-tion should not be considered as a measure that wi 11 fully substitute .for the preservation of archaeological resources.

~Res onse As stated above, physical mitigation measures wi11 be implemented only when impact cannot be avoided. Southern California Edison recognizes that such physical mitiga-tion constitutes an "adverse effect" under Title 36, CFR 800 and that use of such measures could require implementation of the Procedures.

Comment Copies of archaeological reports prepared by the project should be sent to the National Park Service, Western Archaeological Center., P. 0. Box 49008, Tucson, Arizona 85717.