Idaho National Laboratory Cultural Resource Management Plan

with the Idaho SHPO and other interested parties
to develop strategies to mitigate those effects.
Legally, the consulting parties have a minimum of
30 days to review and comment at each step in the
process. Figure 27 illustrates the Section 106
review process.
Since only ~10% of the 890-square-mile
reserve has been inventoried for archaeological
resources and only DOE-ID-owned buildings have
been inventoried within the built environment,
DOE-ID must also ensure no cultural resources are
inadvertently destroyed, transferred, or altered
during ongoing operations. Both of these related
concerns are met through a cultural resource
review process that requires INL CRM Office
involvement whenever a project is proposed that
meets any of the following thresholds:
1. Ground disturbance outside the boundaries of
fenced INL facility areas or within 50 ft of
existing buildings or landscaped areas within
unfenced facility areas
2. Demolition, major structural or landscape
modification, or permanent closure of extant
buildings and structures and/or removal of
original equipment, features, or data
3. Any activities that may affect the EBR-I
facility area, a National Historic Landmark
4. Any ground disturbance within or around
CITRC, where sensitive cultural remains have
been inadvertently discovered in disturbed and
undisturbed contexts
5. Any activities proposed for known or
suspected zones of American Indian
sensitivity and high resource density.
Tailored Cultural Resource
Review
In the past, INL has followed the Section 106
process on a project-by-project and property-byproperty
basis. This has been cumbersome and can
result in costly project delays. Therefore, one of
the main purposes of this plan is to tailor the
Section 106 process to meet INL needs.
The cultural resource review process at INL is
usually initiated through completion of an
environmental checklist. Under the INL NEPA
compliance program, every reasonably foreseeable
federal undertaking on or off INL is preceded by
preparation of an environmental checklist. The
environmental checklist triggers the assessment of
the potential impact of the proposed work for a
wide variety of environmental issues. The federal
agency then assigns a level of documentation (i.e.,
categorical exclusion, environmental assessment,
or environmental impact statement) required for
implementation. The list of threshold activities
mandating cultural resource review, as listed
above, is included in procedures that provide
direction and guidance for preparing
environmental checklists at INL. Thus, even those
INL activities that are categorically excluded from
NEPA review are screened for their potential
impact to cultural resources.
Activities and Properties Exempt From
Cultural Resource Review
INL is an active scientific and engineering
facility where thousands of work orders are
processed each year. To further streamline the
Section 106 process, it is appropriate to define lists
of activities and properties that are exempt from
further cultural resource review. Thus, INL NEPA
compliance and project personnel are also
provided with a categorical list of property types
that are not, themselves, considered significant or
potentially eligible for nomination to the National
Register under the NHPA. As such, actions that
affect the aforementioned property types are
exempt from review. These property types are
listed in Table 1 and captured by structure number
in Appendix I, Table 8.
Most of the properties included on the
exemption list are associated with the modern built
environment at the Laboratory. While these
resources may contribute to overall landscapes
under different historic contexts and research
designs, they are not likely to yield any additional
information important in understanding those
landscapes.
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