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Holtec’s proposed spent nuclear fuel (high level nuclear waste) site is to the west of Laguna Gatuna. The second large white blotch is Laguna Plata. In the area of Laguna Plata is the Laguna Plata Archeological District, which is on the National Register of Historic Places (National Register Info System ID:
89001209), with periods of historical significance ranging from 6999 BC to 1000 AD. In other words, 1000 to 8000 years old. A very limited investigation near Laguna Gatuna, which is part of the property proposed for Holtec’s spent fuel facility, but located to the east of the proposed nuclear waste facility, identified an archaeological site pre-dating AD 670-790, based on a grass fire. Artifacts found at the site are dated from transitional Late Archaic to Early Jornada Mogollon. Even today, Laguna Plata and Laguna Gatuna are fed by spring(s). They are believed to have been fresh water lakes, in the distant past, making them a great place for early Native Americans to hunt and gather food. It wouldn’t be surprising to find an archaic-historic irrigation system, either. Perhaps an irrigation sytem which linked Laguna Gatuna and Laguna Plata? Perhaps in conjunction with a major village? That could be something which Holtec and the NRC would wish to hide! The fact that Holtec is hiding 144 pages of Appendix C, related to cultural resources, suggests that the site of the proposed nuclear waste dump is of great significance to an understanding of Native American history or they wouldn’t be hiding it.

Holtec’s proposed spent nuclear fuel facility in New Mexico Documents found here: https://www.nrc.gov/waste/spent-fuel-storage/cis/hi/hi-app-docs.html

Map showing the area of the proposed Holtec nuclear waste site.

While Holtec tries to claim copyright, the above map is from the US taxpayer (DOE) funded ELEA study!

Map showing the area of the archaeological investigation, to the east of the interim storage, but still on the property. Note Laguna Gatuna on the two maps as the primary point of orientation.
MUSEUM OF NEW MEXICO OFFICE OF ARCHAEOLOGICAL STUDIES, Laguna Gatuna: Excavations at LA 120945, Lea County, New Mexico , by Peter Yoshio Bullock and Yvonne R. Oakes Principal Investigator“, for the BLM. Crop from map on p. 2.


Holtec’s trying to hide details of historical-cultural sites, with 144 blank pages in their Environmental impacts report. According to the environmental report, submitted to the NRC: “The record search revealed that 91 cultural resource investigations have been conducted within the APEs (Table 3.7.1), with portions of 12 investigations extending into the APE of direct impacts. The records search provide that 42 cultural resources have been previously identified within the APEs (Table 3.7.2), with two of them intersecting the APE of direct impacts. These two sites are a prehistoric artifact scatter and a historical-period rail line segment; both have an undetermined NRHP eligibility status. Of the 40 cultural resources identified within the indirect APE, 14 are eligible for listing in the NRHP, seven are not eligible for listing in the NRHP, 18 have an undetermined NRHP status, and one site has no NRHP status.” https://www.nrc.gov/docs/ML1734/ML17345B064.pdf

As pointed out in a FOIA request: “In the ER, Holtec states that it discovered two historic properties “that could be directly affected by this project,” yet does not explain where they are located, what they are, their significance, how they would be affected by the CISF, nor what measures are being considered to mitigate their destruction or alteration as a consequence of building the CISF. Commencing at p. 321 of the ER, “Appendix C: Cultural Resources Communications and Survey Results,” all of Appendix C (pp. 321-464) is redacted, and each page is marked “Security-Related Information Withheld under 10 CFR 2.390.” …there are 144 pages of Appendix C classified as security-related. What is “secured” by nondisclosure is very unclear. There does not appear to be a provision of 10 C.F.R. § 2.390 that authorizes the withholding of information which is neither proprietary nor related in any obvious way to national security. The identities of the endangered cultural resources and any mitigation proposed to preserve them have been completely withheld from scrutiny by the public….” (Terry J. Lodge Counsel for Don’t Waste Michigan, July 5, 2018 [1] NRC may not answer until August 8th [2] , whereas the comment deadline is today.

Similarly, expansion of the Holtec spent nuclear fuel parking lot may be why the NRC’s trying to hide the location of what looks like a very major mound complex at River Bend nuclear reactor site, in Louisiana. Entergy admitted it is there but hid the map and NRC totally hid it.

One of the direct impact sites, referenced in Holtec’s Environmental Impact Report, appears to be LA 120945, which “was originally believed to be a large structural site” (and maybe it still is!). A limited excavation, commissioned in another context, found “a single-component, short-term use area forming part of a larger site area“: “Since this larger site area is outside of the project area“, they could “only surmise its complete form” (p. 18). Based on this limited excavation, Bullock and Oakes, for the BLM, conclude on p. 18 that there was “repeated, possibly seasonally based, short-term use“. However, on p. 23 they state that the “excavated portion of LA 120945 formed an extremely small percentage of the total site area, making any interpretation little more than conjecture….” (p. 23) Helping with the dating is that “Soon after site use, the site area was burned as part of a regional prairie (or grass) fire. Later it was buried under heavy eolian deposition.” (p. 18) It sounds like the fire led to abandonment. The “LA 120945 has been assigned to the transitional Late Archaic-Jornada Mogollon, based on the presence of diagnostic artifacts and corroborated dates. The C-14 dates of charcoal associated with the burnt soil layer at the site are A.D. 670-790. The archaeomagnetic dates are A.D. 550-700 ….” (p. 18) Thus, we are looking at a site which is well over 1000 years old, since it predates AD 670-790. The study notes that the “transitional Late Archaic-Early Jornada Mogollon affiliation of LA 120945 is confirmed by the radiocarbon date from the site (Appendix 9), A.D. 670-790. This is the date of the prairie (or grass) fire, not the site occupation itself. However, the closeness of these dates with the cultural period represented by the artifact assemblage essentially dates the site. These dates are still within the range of the transitional Late Archaic-Jornada Mogollon period….” (p. 18).

However, recall that later they point out that “The excavated portion of LA 120945 formed an extremely small percentage of the total site area, making any interpretation little more than conjecture…. p. 23 See: “MUSEUM OF NEW MEXICO OFFICE OF ARCHAEOLOGICAL STUDIES, Laguna Gatuna: Excavations at LA 120945, Lea County, New Mexico” , by Peter Yoshio Bullock and Yvonne R. Oakes Principal Investigator ARCHAEOLOGY NOTES 282 “Between March 8 and March 19, 1999, the Office of Archaeological Studies, Museum of New Mexico, excavated a portion of LA 120945 for the Bureau of Land Management, United States Department of the Interior.” See the map on p. 2: http://www.nmarchaeology.org/assets/files/archnotes/282.pdf

The Jornada Mogollon is the name archaeologists use to identify the people who lived in the Tularosa Basin after the Archaic period, which ended almost 2,000 years ago. The Jornada Mogollon was a group of farmers living in houses in small villages throughout the southwest. At first, they lived in pithouses. Pithouses are circular houses dug out of the ground and framed with wood beams. Later, Jornada Mogollon peoples began to build square houses using adobe mud to construct walls. Being a farmer in the Tularosa Basin desert must have been hard. There was little rainfall to rely on and the desert sun was harsh. The Jornada Mogollon in the Tularosa Basin farmed, but they still had to hunt and gather local resources to make sure they could survive. The most significant technological difference in the archaeological record between the Archaic to the Jornada Mogollon is the switch from woven fiber baskets to clay pottery. Identifying broken pieces of pottery is one of the ways archaeologists are able to identify Jornada Mogollon sites. The second technological advancement was the introduction of the bow and arrow. Arrows were even lighter and thinner than spears from the Paleoindian and Archaic periods. Bows could propel these arrows with greater accuracy and speed over long distances. Speed, distance, and accuracy are especially important in relationship to the primary game animals the Jornada Mogollon hunted: deer, rabbits, and birds.

We currently know of several Jornada Mogollon villages that existed throughout the Tularosa Basin, including two on White Sands National Monument: Lake Lucero and Huntington Site. The sheer number of artifacts surrounding these sites suggests that these were incredibly important villages. They are strategically situated along Lake Lucero’s shoreline and the Alkali Flat. This would position them to be near fresh water, as water flows down from the San Andres Mountains especially during heavy rainfall. This area is also near the salt and gypsum deposits left behind from Lake Otero. Salt is an incredibly important mineral for a healthy diet. It can also be used as a preservative to keep foods from spoiling. There is some evidence that the rich gypsum dunefield was used as a source of plaster for the walls of adobe houses, much like gypsum sheet rock is used to construct houses across the United States today. In addition, the large, gypsum crystals like those found at Lake Lucero were used as window panes in some Pueblo villages in the Tularosa Basin and northern New Mexico….” https://www.nps.gov/whsa/learn/historyculture/jornada-mogollon.htm

The US taxpayer (DOE) funded ELEA study for another project at the site made the following observations: Archaeological Sites within the Six-Mile Zone Around the Site
The 6-mile zone around the Site contains 111 square miles, containing previously recorded archaeological sites totaling 211. However, only a dozen block surveys, most of them small, have been conducted in the zone. The remaining surveys are linear—seismic lines, pipelines, and roads. Linear surveys do not provide reliable data for predicting site density.

The largest block survey, conducted by NMSU for the BLM, covered 717 acres in the Laguna Plata Archaeological District (Laumbach 1979). The survey identified 25 archaeological sites and revisited one previously recorded archaeological site—thus, a total of 26 archaeological sites, or 23.2 archaeological sites per square mile. (It should be noted that the survey crew was spaced 98 feet apart. The standard interval now is 49 feet, so a few small archaeological sites may have been missed by the 1979 survey.)

There are several types of archaeological sites that have been recorded within the 6-mile zone around the Site. It should be noted that some sites are multi-component; for example, the same archaeological site location may have been used by PaleoIndian hunters who left Clovis points in 8000 B.C., by Mogollon farmers who left ceramics in A.D. 1300, and by EuroAmerican settlers who left glass, ceramics, and car parts in 1935. The archaeological sites and components range from PaleoIndian (one) through Archaic (11), Mogollon (125), Plains Village (one), Apache (one), and EuroAmerican (five). Archaeological sites of unknown cultural and temporal affiliation total 109.

Archaeological sites are not evenly distributed in size categories. Two clusters are apparent: the first contains 47 archaeological sites (26 percent) that measure 5,382 square feet or less; the second contains 48 archaeological sites (26 percent) that measure between 2.5 acres and 12.4 acres. Forty archaeological sites (22 percent) range between 5,382 square feet and 1.7 acres, nine archaeological sites (5 percent) range between 12.4 acres and 49.4 acres, and one archaeological site measures 100.9 acres. It is clear that most archaeological sites are smaller than 1.9 acres.

National Register eligibility data are incomplete for the identified archaeological sites. Of the 110 archaeological sites within the 6-mile zone around the Site, 69 have been determined eligible to the National Register of Historic Places (NR), 15 have been determined not eligible, and 26 are of undetermined eligibility (usually because testing may be necessary to determine eligibility). Site Visit A site visit was conducted by QRA on March 14, 2007 in order to make a general assessment as to the probability of cultural sites in the area. QRA determined that food would have been abundant in the area, especially after a season of heavy precipitation. Rabbits, birds, and plant foods, mesquite being particularly prolific, were all noted during the site visit. Mesquite is considered an important component of both the prehistoric and historic diet of communities living in the Southwest. Summary of Estimated Cultural Sites ¾ Archaeological sites ranging in cultural/temporal affiliation from 10,000 or 11,000 year-old PaleoIndian sites through Archaic to Mogollon, Plains Village, and historic Apache and EuroAmerican archaeological sites may be expected. Given the frequency of Mogollon archeological sites in this region it is not unreasonable to assume that they will be most abundant, but will be trailed closely by archaeological sites for which cultural and temporal affiliation cannot be determined. ¾ Archaeological site densities of 23+ archaeological sites per square mile (640 acres) are indicated by the single large (717 acres) block survey in the 6-mile radius zone around the Site. ¾ Most archaeological sites will probably be small (1.7 acres), but larger sites are a definite possibility. ¾ Two-thirds of newly discovered archaeological sites will be determined eligible for listing on the NR, which will require avoidance or data recovery. The NR-eligibility of one-fourth will be undetermined and will require testing or, if historic, appropriate historical research, such as literature and archival reviews, interviewing, etc. A few archaeological sites will be determined ineligible for listing on the NR at the time of survey. ” Eddy Lea Siting Study Contract No: DE-FG07-07ID14799 https://www.nrc.gov/docs/ML1024/ML102440738.pdf

Laguna Plata Archeological District
National Register Information System ID:
Applicable Criteria:
Areas Of Significance:
Periods Of Significance:
5000-6999 BC
7500-7999 BC
7000-7499 BC
1000 AD-999 BC
1000-2999 BC
1000-1499 BC
3000-4999 BC
Resource Type:
Address Restricted
Related Collections:
National Register of Historic Places Collection


About a later site in the region, as excerpted from the study for the BLM: “THE MERCHANT SITE: A LATE PREHISTORIC OCHOA PHASE SETTLEMENT IN SOUTHEASTERN NEW MEXICO” , by Myles R. Miller, Tim B. Graves, Robert H. Leslie et. al.:

The Merchant site is representative of the Ochoa phase, a poorly understood time period of southeastern New Mexico dating from around A.D. 1300/1350 to 1450. The Ochoa phase, and the El Paso and Late Glencoe phases of the closely related Jornada Mogollon region to the west, are contemporaneous with the Pueblo IV period of the greater Southwest, the Antelope Creek phase of the southern Plains, and the Toyah phase of central Texas…”

The Carlsbad Field Office contracted Versar, Inc. to conduct remedial archaeological data recovery excavations at the Merchant site (LA 43414), a complex village settlement in southeastern New Mexico. The Merchant site was excavated by the Lea County Archaeological Society (LCAS) from 1959 to 1965, but the results of the excavations were never fully reported. The site was fundamental to the definition of the Ochoa phase, but the nature of the phase had remained poorly known since the excavations in the 1960s. The 2015 fieldwork included a Transect Recording Unit survey, surface mapping and collections, remote sensing, hand and mechanical excavations, and geomorphic studies. The entire site of LA 43414 was surveyed and mapped, identifying several areas of prehistoric occupations including possible agricultural fields. The primary focus of the fieldwork was the village area excavated by the LCAS and the possible agricultural fields located 100 meters to the north.

The primary occupation of the Merchant site consists of a group of domestic rooms with stone foundation walls, two deep pit structures, and extensive trash middens located on an elevated escarpment overlooking the Mescalero Plain of southeastern New Mexico. The LCAS excavations revealed intriguing details on architecture, ceramics, projectile points, and flaked stone artifacts. The remedial excavations were able to clarify some of the architectural details, as well as providing a review of the material culture using contemporary perspectives.

Excavations in two large and deep pit structures excavated by the LCAS in 1959 and 1960 were able to clarify some details of the architecture and remodeling history of the structures, as well as obtaining chronometric dates. The backdirt deposits in and around those structures, as well as other refuse areas, contained thousands of animal bones, lithic flakes, and other items. Volumetric analyses of the bone and artifact densities in midden areas and the backdirt spoil piles found that the Merchant site ranks exceptionally high on the scale of occupational intensity.

One of the potentially most significant findings was the discovery of possible agricultural gridded fields to the north of the LCAS village. Geomorphological, archaeological, and botanical studies were conducted in two possible agricultural features but the results are equivocal. If future investigations confirm the presence of such features, they will represent the easternmost expression of Southwestern intensive farming practices.

The most significant finding of the reinvestigation of the site is that it truly reflects a hybrid of prehistoric Plains and Southwest architectural forms and technologies. The analysis of these details provides new insights into the nature of Late Prehistoric Ochoa phase settlements in southeastern New Mexico….

the LCAS excavations and Leslie’s 1965 publication gave tantalizing details on rooms with formal stone foundation walls (or cimientos), two large and deep pit structures that were called rooms or pithouses but had intriguing similarities to civic-ceremonial rooms of prehistoric and historic Southwestern cultures, thousands of projectile points and formal tools, a new and indigenous ceramic ware called Ochoa Indented, and ceramics and marine shell obtained from distant sources. The mythical status was also due to the fact that the abovementioned details were known among the avocational and professional archaeological communities of southeastern New Mexico, but aside from Leslie’s brief and basic overview, little was truly known of the site beyond an amalgamation of hearsay and oral traditions…

The Merchant Site and the Prehistory of Southeast New Mexico

The Merchant site is representative of the Ochoa phase (A.D. 1300–1450) and represents an atypical residential settlement in southeastern New Mexico, a region dominated by mobile hunter-gatherer groups. The presence of such a site gives rise to several research questions. The research questions involve multiple scales ranging from human adaptations to the local environment of southeast New Mexico to the nature of the social groups that inhabited the site and their relationships to broad patterns of social and economic interaction that took place across the southern Southwest and southern Plains during the fourteenth and fifteenth centuries. There appears to be a distinctive blend of Plains and Southwest material culture, technology, and social organization at the Merchant site. There is a strong hunting tradition evident in the chipped stone tools and technology, while there are also intriguing architectural hints suggesting social organization based on Southwestern traditions of communal architecture. Of course, the different house forms may also be associated with multiple occupations. Ceramics and marine shell indicate economic and social contacts with groups to the west in the Jornada and Salinas region. The possibility that the site represents an actual migration of people from one of those western regions must be considered given our current knowledge of widespread population movements across the Southwest.

Unfortunately, it has been difficult or impossible to address these and other questions in full because of the loss of information from the site and the variable quality of what little information has been published (Leslie 1965a). The studies by Gregory (2006) and Alvarado (2008) contributed important insights but were limited to material culture and could not reconcile the confusing details on the architecture and other aspects of the site. The investigations proposed by the CFO under the Permian Basin PA and described by VersarGMI in the following discussions were designed to remedy this situation. Ultimately, the overarching goal of the project was to allow the Merchant site to take its rightful place among the signature prehistoric settlements of southern New Mexico... “THE MERCHANT SITE: A LATE PREHISTORIC OCHOA PHASE SETTLEMENT IN SOUTHEASTERN NEW MEXICO , by Myles R. Miller, Tim B. Graves, Robert H. Leslie et. al. Prepared for: Bureau of Land Management Carlsbad Field Office 620 E. Greene Street Carlsbad, New Mexicohttps://www.researchgate.net/profile/Myles_Miller/publication/312190368_The_Merchant_Site_A_Late_Prehistoric_Ochoa_Phase_Settlement_in_Southeastern_New_Mexico/links/5875161008aebf17d3b3f30e/The-Merchant-Site-A-Late-Prehistoric-Ochoa-Phase-Settlement-in-Southeastern-New-Mexico.pdf

Note 1: FOIA request: http://www.beyondnuclear.org/storage/kk-links/7%205%2018%20FOIA%20cultural%20properties%20redactions%20FINAL.pdf
Note 2: NRC response: http://static1.1.sqspcdn.com/static/f/356082/27945987/1531374677343/7+11+18+NRC+Acknowledgement+Letter+re+Terry+Lodge+FOIA+request.docx?token=C25h%2BHk3TvLjV3tkTYjDVczHZQ8%3D
Overview of topic and links to the above: http://www.beyondnuclear.org/centralized-storage/2018/7/5/request-for-redacted-information-re-cultural-properties-in-h.html

Laguna Gatuna importance as wetlands and contaminants https://www.fws.gov/southwest/es/Documents/R2ES/WWTP_Wetlands_Contaminant_Report-FINAL.pdf

Merchant site Lea Co NM https://www.archaeological.org/events/22761


Thousands of ancient artifacts uncovered in Eddy County
Maddy Hayden, Carlsbad Current-ArgusPublished 5:44 p.m. MT Aug. 4, 2016

WIPP and San Simeon Sink https://www.osti.gov/servlets/purl/6873031

Laguna Gatuna https://caselaw.findlaw.com/us-10th-circuit/1225346.html


WIPP Laguna Gatuna map, etc. http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/22/064/22064211.pdf

Ochoa mine blm show capitan reef and laguna gatuna https://www.nm.blm.gov/cfo/ochoaMine/docs/INTERA_HydrogeologicImpactAssessmentReport_FINAL.pdf

Capitan reef sinkholes https://www.researchgate.net/publication/313021019_Evaporite_Karst_in_the_Permian_Basin_Region_of_West_Texas_and_Southeastern_New_Mexico_The_Human_Impact

Holtec reaponse nrc mining https://www.nrc.gov/docs/ML1731/ML17310A217.pdf

All blurry geology maps https://www.nrc.gov/docs/ML1731/ML17310A225.pdf

Includes BLM letter (pp. 11-13) regarding imporance of Laguna Plata ecologically and archaeologically and its creation by subsidence.http://ocdimage.emnrd.state.nm.us/Imaging/FileStore/SantaFeAdmin/CF/ADA-03-00560%20Case%20Files%20Part%208/ADA-03-00560%2000001-10000/08781_03623.pdf