My Four Years of Archaeology at PORTS

It has occurred to me that some visitors to the Archaeology in Tennessee blog might be interested in knowing a little bit about the challenging and complex archaeological and cultural resource management (CRM) support work that some of my colleagues and I have been providing to the U.S. Department of Energy (DOE) and their site-wide environmental contractor (Fluor-B&W Portsmouth LLC) over the past 4 years at the Portsmouth Gaseous Diffusion Plant (PORTS) in Piketon, Ohio.  For those of you who are unfamiliar with the historical development of nuclear energy in the United States, PORTS is an enormously large industrial facility constructed in the early 1950s to produce highly enriched uranium (U-235) for use in nuclear weapons during the Cold War between the United States and Soviet Union.

PORTS sits on a large federal reservation (3,777 acres) located on uplands along the Scioto River in the geographic heartland of Ohio Hopewell. You may read a more in-depth summary on PORTS at the first link below and visit the recently opened PORTS Virtual Museum at the second link:

I was assigned to provide cultural resources and environmental support to two massive site-wide environmental projects now underway at PORTS.  Initially, it was my duty to provide cultural resources technical assistance and advice to a very close and capable colleague of mine who provides direct oversight assistance to DOE for site-wide CRM at PORTS.  When my work began in 2010, an architectural inventory of PORTS had already been conducted and reported.  Although a limited archaeological survey of the PORTS reservation had been completed and reported in the mid-1990s, a number of undeveloped areas had never been surveyed for archaeological sites.  Therefore, one of the first orders of business was for DOE to conduct archival research and perform a series of archaeological surveys aimed at achieving comprehensive survey coverage of the large undeveloped areas on the reservation. Several different CRM consulting firms in Ohio were hired to do this work.  You may read the archaeological survey reports and other CRM documents completed thus far for the PORTS reservation by clicking on each one at the following link:

During my last 3 years of work, I was charged with integrating the past and real-time results of the many foregoing CRM surveys, inventories, and studies into various environmental compliance documents required under The April 13, 2010 Director’s Final Findings and Orders for Removal Action and Remedial Investigation and Feasibility Study and Remedial Design and Remedial Action, including the July 16, 2012 Modification thereto (DFF&O) agreed to by DOE and the Ohio Environmental Protection Agency.  Integrating this information into the compliance documents to address National Environmental Policy Act of 1969 (NEPA) values (pursuant to DOE’s 1994 Secretarial Policy on NEPA) was also a part of my responsibilities.  In addition, I was involved in writing detailed archaeological survey summaries to support consultations with Native American tribes and other interested parties.

It is worth noting that, rather than using Section 106 of the National Historic Preservation Act of 1966 (NHPA) and 36 CFR 800, the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) process was used.  As provided for in 36 CFR 800.3, an alternative review process can be used.  In this case, the applicable or relevant and appropriate requirements (ARARS) process promulgated under CERCLA was used, enabling a streamlined CRM effort that works directly with a CERCLA compliance model.  The ARARs approach provides for extensive public involvement, thorough alternatives analysis, and development and implementation of mitigation measures where adverse effects to historic properties will occur.  ARARs focus on the substance of NHPA rather than the iterative administrative efforts, yielding a beneficial result sooner and consistent with the cleanup decisions reached by the agencies involved.

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