ML103060210

Letter to David Wrona from Thomas B. Lyons of the New York State Office of Parks, Recreation and Historic Preservation

ML103060210
Person / Time
Site:	Indian Point
Issue date:	10/26/2010
From:	Lyons T State of NY, Office of Parks Recreation & Historical Preservation
To:	David Wrona Division of License Renewal
References
TAC MD5411, TAC MD5412
Download: ML103060210 (1)

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.David A. Paterson O NEW YORK STATE Z Governor New York State Office of Parks, Carol Ash Recreation and Historic Preservation Commissioner The Governor Nelson A. Rockefeller Empire State Plaza

• Agency Building 1, Albany, New York 12238 www.nysparks.com October 26, 2010 David J. Wrona Chief, Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re:

NRC Indian Point License Renewal Buchanan, Westchester County

Dear Mr. Wrona:

Thank you for your letter dated September 27, 2010 to Ruth Pierpont regarding the Jicense-renewal of the Indian Point Nuclear Power Generating Units 2'and 3. The New York State Historic Preservation Office (SHPO) previously commented on this matter.under Section.106 of the National Historic Preservation Act bv letter dated March 24,

• .2,O9O(660py attached). As notedinthatletter,.SP.O's comments '.do -not includez:

potential*environmnental.impactsto *New.

oYorkStaf*.Parklandthat may be inybiyei"in or near your proj ect..Such impactsmust be considered. ag part of the enivironmental. review, of the project pursuant to the National Environmental Policy Act..:. The New York State.Office of Parks, Recreatibn and. Historic, Preservation -therefore appreciates -this opportunity to comment, upon a specific impact upon one of our irreplaceable facilities that does not appear to have beenaddressed in the draft Supplemental Efiironmental.

Impat statement.(DSEIS).

As noted in section 2.2.9 of the DSEIS, Stony Point Battlefield State Historic Site is, located just south of and -directly across the Hudson River from the Indian Point facility. Thist histoich sitf is directlyvassociated with the July 16, 1779,battle of Stony Point.where General Anthony Wayne and~a small elite force of the Continental Army captured the British garrison stationed atthe point. This eventimarked the last miajor..

conflict of the.Rkeolutionary War in'thenorthern theater.. -. The 45-acre park is th-th characterized by surviving.' 18-century earth works and an early 19, century'navigational light.house, The,.site:was.designited aNational Historic-Landmark by the.United Stated D*ePame~ntof the.Interior on Janury..20,16*.* 1This is the:Nation s highesthistorical P

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An Equal Opportunity/Affirmative, Action Agency C,* printed on recycled paper

According to the Department of the Interior "National Historic Landmarks are nationally significant historic places designated by the Secretary of the Interior because they possess exceptional value or quality in illustrating or interpreting the.heritage of the United States. Today, fewer than 2,500 historic places bear this national distinction." The.

DOI goes on to state: "National Historic Landmarks are exceptional places. They form a common bond between all Americans. While there are many historic places across the nation, only a small number have meaning to all Americans--these we call our National Historic Landmarks." As such, the Stony Point Battlefield is an irreplaceable asset to the people of New York State and the Nation.

The DSEIS in Chapter 5.2 purports to assess the impacts of a Severe Accident and the feasibility of Mitigation Alternatives, but ignores the impact of such an accident upon Stony Point Battlefield and fails to consider the implementation of alternatives to mitigate such impacts. Any loss, temporary or otherwise, of the public's access to this place would significantly diminish the Nation's lexicon of tangible historic resources associated with the American Revolutionary War. Stony Point Battle Field Historic Site is a significant historic and cultural asset to the people of New York State and the Nation and we request that any potential impacts to this site be fully assessed in the environmental analysis of the relicensing of Indian Point.

If you should have any questions regarding these comments I can be reached at (518) 474-0409.

Sincerely, Thomas B. Lyons Director of-Resource Ma gagement cc:

Tom Alworth Enclosure I

40c David A. Paterson

'Governor o NEW YORK STATEC Govrno New YorkState Office.-of

.Parks,,..

C ommissioner Recreation and Historic, Preservation The Governor Nelson A'"Rockefeller "EmpireState Plaza 'Agency Bdidding 1',AlbanV; New' York 12238..

www.nysparks.com:

'2 March 242009 Tim Basham Enercon Services Inc.

6525 N. Meridian, Suite 400 Oklahoma City, Oklahoma 73116 Re:

NRC Entergy Indian Point Units 2 and 3 Operating License'Renewal

'4"50 Broadwxay Town'of Buchanan, Westchester County 06PR06720

Dear Mr. Basham:

Thank you for requesting the com.niments of the State Historic Preservation Office (SHPO). We have reviewed the project in accordance with Section 106 of the National Historic Preservation Act of 1966. These comments are those of the SHPO-and relate only to Historic/Cultural resources. They do not include potential environmental impacts to New York State Parkland that may be involved inor hear your project. Such impacts must be considered as part of the environmental review of ?heijroject pursuant to the National Environmental Policy Act and/or the State Environmental Quality Reriev Act (New York Environmental. Conservation Law Article 8).

It is our understanding that the potential Cooling Tower Construction locations. are being studied for feasibility as a requirement by the NYSDEC. If the cooling towers will need.to be constructed at a later date, ffirther consultation will'be necessary.

The proposed scope for the Phase IB methodology should include determining the Area of Potential Effect (APE), evaluating and documenting the vertical/horizontal disturbances and testing using the Standards for Cultural Resource Investigations and the Curation of Archaeological Collections in New York State and the 20q5 NYSHPO Phase I Archaeological Report Format Requirements. A geomorphologist should determine the need for deep testing if there is the potential for buried deposits. Testing may be necessary to determine fill depth and/or disturbance of original soil.

Finally, the visual effect will have to be assessed as part of the project if the cooling towers will be built.

An Equal Opportunity/Affirmative Action Agency

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Page 2 06PR06720 For further correspondence regarding thisproject, please be sure to refer to the OPRHP Project Review (PR) number noted above. If you have any questions, please call me at (518) 237-8643, extension 3288.

Sincerely,.

Cynthia Blakemore Historic Preservation Program Analyst cc.

James Thomas, Enercon Services James Briscoe, Enercon Services (vial e-mail)

Dara Gray, IPEC (via e-mail)

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