ML071570063

E-MAIL (NPA-PD) FW: Letter to Ma State Historic Preservation Officer

ML071570063
Person / Time
Site:	Pilgrim
Issue date:	05/09/2007
From:	Mogolesko F Entergy Nuclear Generation Co
To:	Williamson A NRC/NRR/ADRO
References
TAC MD3698
Download: ML071570063 (17)

Text

I Alicia Williamson - FW: Letter to MA State Historic Preservation Officer Page Page 1ý 1I Alicia Williamson FW: Letter to MA State Historic Preservation Officer From: "Mogolesko, Fred" <fmogole@entergy.com>

To: "Alicia Williamson" <ARWI @nrc.gov>

Date: 05/09/2007 3:04:39 PM

Subject:

FW: Letter to MA State Historic Preservation Officer As requested.

From: Scheffer, Jacob Sent: Wednesday, May 09, 2007 12:38 PM To: Bethay, Stephen; Ford, Bryan; Mogolesko, Fred; Brochu, Jill; BUCKLEY, RICKY N Cc: Egan, Joseph

Subject:

Letter to MA State Historic Preservation Officer Attached for your information is a copy of a letter that was sent to the MA State Historic Preservation Officer In response to comments on the DSEIS submitted to the NRC by the MA Historical Commission (MHC).

CC: "Mogolesko, Fred" <fmogole@entergy.com>, "Ford, Bryan" <BFord@entergy.com>

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Subject:

FW: Letter to MA State Historic Preservation Officer Creation Date 05/09/2007 3:03:39 PM From: "Mogolesko, Fred" <fmogole@,entergv.com>

Created By: fnogole(@,enter"v.com Recipients nrc.gov TWGWPO04.HQGWDOOI ARWI (Alicia Williamson) entergy.com BFord CC (Bryan Ford) finogole CC (Fred Mogolesko)

Post Office Route TWGWPO04.HQGWDOO1 nrc.gov entergy.com Files Size Date & Time MESSAGE 493 05/09/2007 3:03:39 PM TEXT.htm 4258 image001 .gif 862 Letter to MA SHPO.PDF 1002723 Mime.822 1381589 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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... 4. A AA CUM^i DFrC I I/A.lcia VVIIIIalIIUII LAR115I iuVii ..

Entergy Nuclear Operutlons. Inc.

Pilgrim Nuclear Power Statbon 600 Rocky H11Road Plymouth, MA 02360 Director, Nuclear Assessgrlt icPreservto fie irecto Officer Massachusetts Historical Commission 220 Morrissey Blvd.

Boston, MA 02125

Dear Ms. Simon:

This letter represents Information requested based on a discussion between Jonathan Patton of your staff and Fred Mogolesko (Pllgrim's License Renewal Project Manager). The focus of their discussion was your February 8, 2007 letter to Rani Franovich of the USNRC regarding the Pilgrim Application for License Renewal.

We understand your mandate to ensure that no historic properties are adversely affected now or throughout the license renewal period. To this end, Entergy (Pilgrim) has in place a procedure, Entergy Procedure EN-EV-121 (Cultural Resources Protection Plan), that provides the mechanism to protect either existing or potentially existing cultural resources located at the Entergy nuclear sites.

This procedure requires the following:

" Environmental reviews of land disturbance activities must be conducted In accordance with the procedure to ensure either existing or potentially existing cultural resources are protected to the maximum extent practicable.

• The State Historic Preservation Officer (SHPO) must be notified of activities that may affect existing or potentially existing cultural resources, If required by specific state laws, SHPO, operating license conditions or site reporting procedures.

Furthermore, there is another Entergy Procedure EN-EV-115 (Environmental Reviews and Evaluations), which cites the following:

a In accordance with the National Hinindrn Prantl*n A#- e, , ,--..... 3..-

Alicia-Williamson - Letter to MA SHPO.PDF Page 2 Entergy Nuclear Operations, Inc. Letter Number: ENV5.07-002 Pilgrim Nuclear Power Station Page 2 For your further Information, I have enclosed a complete copy of EN-EV-121, and a copy of the pertinent section of EN-EV-1 15.

I hope this Information Is useful and completely addresses the concern you expressed in the February 8, 2005 letter.

Sincerely, JJS/dl Enclosure

r w*

IAlicika Williamson - Le~tter tokMA -SHP0PDF r~

NUCLEAR NoN-CkurJy REL¢,, EN-EV-121 REV. 0 I MANAGEMENT MANUAL I I bwrowATIcMJUaI PAGE 1 OF 12 Cultural Resources Protection Plan ural Resources PRitectkon olah wýner: - Rick N. Buckley/I Corporate Environmental Chairman tPrtnt WAmA I T~tI~~

.... me Tia Approved: R" t" . 11/01106

.(Procedure Owner Signature) (Date)

EN Common 11103106 ANO 01101/07 PNPS ENN Effective GN RIBS Effective ENS Date Date Exception IPEC W3 JAF WPO Procedure Contains NMM REFUBS Forms: YES 0 NO 0-This procedure provides a mechanism for protecting historical and archaeological areas located on Entergy's nuclear site properties.

iamson - Letter to MA SHPO.PDF4 NUCLEAR WN-QA"RIMATUO EN-EV-121 REV. 0K MANUAL IORMAWOK&USE PAGE 2 OF 12 "C'ultural Resources Protection Plan TABLE OF CONTENTS 1.0 PURPOSE ...................................................................... . 3

2.0 REFERENCES

........................................................................ 3 3.0 DEFINITIONS .......... ... ............ 4 4.0 RESPONSIBILITIES ....................................................... 5 5.0 DETAILS ............................................. ........................... . I 5.1 Precautions and Umitations ..................................... 5 5.2 Land Disturbance of Undisturbed Areas ................... 5 5.3 Modification/Remodeling of Cultural Resource Structures ............................................................... 6 5.4 Routine Surveillances .............................................. 7 5.5 Special Protection Measures ................................... 8 5.6 Records ................................................................. 8 6.0 INTERFACES .......... ............. 9 7.0 RECORDS ........................... I 8.0 OBLIGATION AND REGULATORY COMMITMENT CROSS-REFERENCES ....................... 9 9.0 ATTACHMENTS ...............................................

ATTACmmENT 9.1 LAND DIsTUReANCE ENVRONMENTAL REvmw FORM (TYPICAL) ................ .................... 10 ATrACmMENT 9.2 CULTURAL RESOURCe STRUCTURE mOmmFCATIONI RFMOOEUNG REVEW FORM (rYAL) ..................... 12

kAlicia Williamson - Letter to MA SHPO.PDF Paige75]

a mechanism to protect either existing or potentially existing cultural s located at the Entergy Nuclear sites.

2.0 REFERENCES

[1] Regulatory References (a) National Historic Preservation Act (and amendments)

[2] Company References (a) NMM Procedure EN-EV-1 15. Environmental Reviews and Evaluations (b) NMM Procedure EN-IS-1 12, Trenching, Excavation and Ground Penetrating Activities

[3] ANO References

Alicia Williamson - Letter to MA SHPO.PDF Page NUCLEAR NOw-QuA MATO EN-EV-121 REV. 0

~'nte'rri MANAGEMENT0 MANUAL bOmOMTN& .USE PAGE 4 OF 12 Cultural Resources Protection Plan 2.0 cont (b) Letter from Jane Lendway, Vermont Division for Historic Preservation, to Gary Tucker, FTN Associates, LTD., dated October 17, 2005 (refer to Attachment C of License Renewal Environmental Report)

[7] W3 References (a) W3 Cultural Resources Protection Plan 3.0 .DEFINITIONS i1] Disturbed Land Areas - Surface and/or subsurface land areas that were significantly disturbed during the construction phase of the site (i.e., plant's protected area).

[2] Cultural Resources - Resources that Include but are not limited to:

(a) Cemeteries, burial sites, funeral monuments, or other sites with human remains (b) Historic buildings, structures, or building remains (c) Ancient sites containing cultural artifacts such as pottery, tools, weaponry, and other Implements (d) Ritual artifacts (e) Discarded materials (i.e. Indian mounds with shells and animal bones)

(f) Sites of historical significance to the community, state, or nation, such as battlegrounds, encampments, villages, etc.

(g) Traditional cultural properties.

[3] Land-Disturbing Activities - Activities that involve grading, construction of buildings, excavations, reforestation, landscaping, placement of any fill or spoil or other terrestrial Impact.

14) Undisturbed Land Areas - Surface and/or subsurface land areas that have not been disturbed either during the construction phase of the site or during current operations, or if there is uncertainty at the site about the degree of disturbance.

M- -71 IAlip-ia Willi~mmnn - I affpr to MA -qHPOnPDF1 V%; i

-is responsible for maintaining, (a) Conducting environmental reviews of land disturbance activities in accordance with this procedure to ensure either existing or potentially existing cultural resources are protected to the maximum extent practicable.

(b) Ensuring that the State Historic Preservation Off'ce (SHPO) is notified for

Alicia Williamson - Letter to MA SHPO.PDF NUCLEAR m4umiu Rm.Ano EN-EV-121 REV. 0 Mrnter MANAGEMENTA" bWR-KauUW PAGE 6 OF 12 MANUAL Cultural Resources Protection Plan S.2 cont (a) Complete Section A of Attachment 9.1 to this procedure (Lend Disturbance Environmental Review Form) and forward to the Site Environmental Representative for review.

(b) Obtain approval from the Site Environmental Representative prior to the actMty commencing.

(c) Adhere to the management requirements Identified in Section C of Attachment 9.1 (Lend Disturbance Environmental Review Form), as applicable to the land disturbance activity.

(21 Site Environmental Representative, upon receipt of Attachment 9.1 (Land Disturbance Environmental Review Form), Is to:

(a) Contact SHPO for activities that may affect existing or potentially existing cultural resources.

(b) Complete Section B of the Form and Ifapplicable Section C.

(c) Ifapproved, return a copy of the completed Form to the requester.

(d) If not approved, notify the requestor of the reasons for denying the approval.

(e) Maintain copies of the required documents on file.

(f) Conduct periodic visual observations of the area to ensure that any management requirements Identified In Section C of Attachment 9.1 (Lend Disturbance Environmental Review Form) are followed.

(g) Ensure that rnitigation measures are Implemented as appropriate.

5.3 MODFICATION/REMODEUNG OF CULTURAL RESOURCE STRUCTURES

[1] Site Departments, Contract Managers and Contractors, for activities Involving modifications/remodeling to cultural resource structures are to:

(a) Complete Section A of Attachment 9.2 to this procedure (Cultural Resource Structure Modification/Remodelfng Review Form) and forward to the Site Environmental Representative for review.

All. I ca MINI:

I , aoI n - L e t* r[to M A tIr i-oUl -l - PIa ge 9 ,

SNUCLEAR NoW4UALu RMAO EN-EV-121 REV. 0 MANAGEMENT MANUAL l.*oR""W" n. PAGE 7 OF12 Cultural Resources Protection Plan 5.3 c*nt (b) Obtain approval from the Site Environmental Representative prior to the activity commencing.

(c) If applicable, adhere to the management requirements identified in Section C of Attachment 9.2 (Cultural Resource Structure Modification/Remodeling Review Form).

[2J Site Environmental Representative, upon receipt of Attachment 9.2 (Cultural Resource Structure Modification/Remodeling Review Form) is to:

(a) Contact SHPO to Inform them of the activity.

(b) Complete Section B of the Form and If applicable Section C.

(c) If approved, return a copy of the completed Form to the requester.

(d) If not approved, notify the requestor of the reasons for denying the approval.

(e) Maintain copies of the required documents on file.

(t) Condupt periodic visual observations of the area to ensure that any management requirements Imposed by SHPO are followed.

(g) Ensure that mitigation measures are Implemented as appropriate.

5.4 ROUTINE SURVEILLANCES

[1] The Site Environmental Representative should:

(a) Conduct periodic environmental rounds to ensure that no unauthorized activities occur that could damage existing or potentially existing culturally protected resources.

(b) Notify the SHPO and the NRC if ground disturbing activities are discovered within an existing or potentially existing culturally protected resource area, If required by operating license conditions, SHPO or site reporting requirements.

(c) Obtain a certified archaeologist to conduct a damage assessment of the affected area, if deemed necessary.

Page 10 1 IAlicia SHPO.PDF Alicia Williamson - Letter to MA SHPO.PDF

- Page 10 1

ýLPROTECTION PROCEDURES the site find it necessary to conduct any actMties within a culturally W area and If required by operating license conditions, SHPO or site

\res, the Environmental Site Representative should notify the SHPO and

.'writing of the proposed activity. The notification should include, but not limited to:

" A description of the proposed activity.

" Description for the need for the activity.

" A map showing the location of the planned activity In relation the culturally protected areas.

" A demonstration for the need to perform the activity within the culturally protected area.

[2] The NRC, after consultation with the SHPO, will advise the site whether or not a mitigation plan Is required.

5.6 RECORDS

IA!icia Williamson - Letter to MA SHPO.PDF page 11i 6.0 INTERFACES

[1] NMM Procedure EN-IS-112, Trenching, Excavation and Ground Penetrating Activities

[2] NMM Procedure EN-EV-1 15, Environmental Reviews and Evaluations 7.0 RECORDS None 8.0 OBLIGATION AND REGULATORY COMMITMENT CROSS-REFERENCES 8.1 OBLIGATIONS AND COMMITMENTS IMPLEMENTED OVERALL None 8.2 SECTION SPECIFIC OBLIGATIONS AND COMMITMENTS None 8.3 SITE SPECIFIC COMMITMENTS IStep ISite IDocument ICommitment Number or Reference 11 ANO ICAN090005 P-17051

!1.0 ATTA'/CHMENTS 9.1 Land Disturbance Environmental Review Form (Typical) 9.2 Cultural Resource Structure Modificatlon/Remodeling Review Form (Typical)

I I* 4IS.o 1J tci WUU~

VViImdIIo - Letter 1 Mto

/ Srivu.Pb-'- *

\1turbance Activity

1. Brief Description of Activity:-

2. Amount of Land Involved:

I1 Acr

ý I!

rage 3 IAlit-io WAmIifmann - I Mttor tn% MA 5qHPr) PDF y ii ATrACHMENT 9.1 LAND DISTURBANCE ENVIRONMENTAL REVIEW FORM (TYPICAL)

SHEET 2 of 2 C. Required Management Practices Management Practice(s) Yes No NA Stop the activity V a potential historical or archaeological El 0 0 site Is discovered or Ifan existing site Is damaged.

Notify the Site Environmental Representative 0l 0l 0]

Immediately In the event that a potential historical or archaeological site Is discovered during the land disturbance activity.

In the event that a potential historical or archaeological [] 0 El[

artifact Is discovered, do not resume the land disturbance activity until the Site Environmental Representative has performed an evaluation.

Place a protective barrier around existing historic or 0 0 03 archaeological site(s).

Notify the Site Environmental Representative 0] 0l El Immediately In the event that an existing historical or archaeological site Is damaged during the land disturbance activity.

Remarks: Potential evidence that a historical or archaeoloofcal site may exist would be the oresence of ootelrv. class. arrowhead. bones, tools, weaponry, wooden or metal structures.

flakes, brick. mortar or olaster, SHPO Protective Measures:

Approved ByV I Signature Date

I Alicia Williamson - Lefter to MA SHPO.PDF n A...ia.Wi..iamson...Letter .to HP.P

.MA . . . .. +i ATTAcmHUENT 9.2 CULTURAL RESOURCE STRucTuR! MOOIFICATIONIREMOOEUNG REVIEw FoRM (TYPICAL)

SHEET I of I A. Modification/Remodeling Activity

1. Description of Actity

2. Expected Duration of Activity:

B. Environmental Review

1. SHPO Contacted: [] Yes [] No

2. Date SHPO Contacted:

3. SHPO Protective Measures Imposed: [I Yes [I No C. SHPO Protective Measures (if applicable)

Approved By:. /

Signature Date

I A*!.!... bAD!,,, ~ .

tIAl a vvirinason - Letter to MA SHl'U.I-13I- Paae 151 ATTAcm*ENT 9.4 ENWRONMENTAL SCREEmNG REGULATORY BASeS SHEET2OF 5

2. Any land disturbance of undisturbed land areas (i.e., grading acivities. construction, excavations, reforestation, creating, or removing ponds).

" In accordance with the National Historic Preservation Act, any cultural resources In the area must not be disturbed until prior authorization Is obtained fr*m the State Historic Preservation Office and NRC *s set forth In the site's Cultural Resource Protection Plan.

• In accordance with the Clean Water Act, a Construction Stormwater Permit is required for those activities hat disturb one acre or greater In order to manage:

• Sediment runoff and erosion.

• Potential leakage from oil and chemical containers.

• Potential leakage from vehices and equipment.

A construction stormwater permit Is not required for slivicultural activities. However, best management practices must be followed and consideration given to historical locations or endangered spades

• An activity Is exduded from EPP review requirements Waill measurable nonradiological effects are confined to the on-site areas previously disturbed during site preparation and plant construction.

3. Dredging activities In a lake, river, pond, dItches or strem.

• In accordance with the Clean Water Act. a Section 404 Permit Is required:

• For removal or material from a lake. river, pond, ditch or stream.

• For disturbing any material In a lake, river, pond, ditch or stream.

• For disturbing areas designated as wetlands.

4. Increasing the amount of thermal heat being discharged to the river or lake (i.a., associated with once through and dosed cycle cooling wastewater discharges).

• In accordance with the Clean Water Act any temperature Increase In once through or closed cycle cooling water discharges that would exceed the established lrrits set In the LPOES/NPDES/SPDES Permit would have to be approved by the regulatory agency and the Permit modified accordingly.

5. Increasing the concentration or quantity of chemicals being discharged to the river, lake, or air Q.e.,

associated with wastewater and air emission dlscharges)

• In accordance with the Clean Water Act increasing the concentration or quantity of a chemIcai In a wastewater discharge that had already been previously established and defined In a LPDESINPDES/SPDES Permit application would have to be approved by the regulatory agency prior to the change.

" In accordance with the Clean Air Act If air emissions from a source Increases In pounds/hour or ons/year from that specified In the site Air Permit or Air Permit application as a result of Increasing the concentration or quantity of a chemical, regulatory approval would have to be obtained and the site Air Permit potentially modified.