APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Entergy Arkansas, 22 Inc. 425 West Capitol Avenue P. O. Box 551 Little Rock, AR 72203-0551 Tel 501 377 5876 Fax 501 377 4415
Laura Landreaux Vice President Regulatory Affairs
June 18, 2014
Mr. Michael Sappington, Secretary Arkansas Public Service Commission P.O. Box 400 1000 Center Street Little Rock, AR 72203
Re: APSC Docket No. 13-039-U In the Matter of an Application of Entergy Arkansas, Inc. for a Certificate of Environmental Compatibility and Public Need to Construct and Operate Two 230 kV Transmission Lines and Associated Transmission Facilities to Serve Big River Steel LLC in Mississippi County, Arkansas
Dear Mr. Sappington:
On June 19, 2013, the Administrative Law Judge (ALJ) issued Order No. 3 requiring Entergy Arkansas, Inc. (EAI) to file a report every six months entitled “EAI’s Efforts to Mitigate Damage to Native American Archeological Sites”. Also in Order No. 3, the ALJ required EAI to file all future comments from government agencies and any permits that EAI has received.
EAI received a Notice of Coverage (NOC) for NPDES Stormwater Construction General Permit Number ARR150000 from the Arkansas Department of Environmental Quality for proposed soil disturbing construction activities at the Driver Substation. A copy of the NOC is attached.
A Cultural Resource Survey was performed on a small parcel of property known as “Easement A”, which is part of the right-of-way required to connect the proposed Driver Substation to the existing Entergy Sans Souci – Shelby Tap Transmission Line. The survey was submitted to the Arkansas State Historic Preservation Officer (SHPO) for review. The SHPO response letter indicates no further action is required. A copy of the survey and response letter are enclosed. EAI will submit a copy of the survey and the SHPO response letter to the Quapaw and Osage Nations for their review. Michael SappingtonAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 Page 2 June 18, 2014
Sincerely,
/s/ Laura Landreaux Laura Landreaux Enclosures c: All Parties of Record APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 Permit Tracking Number: ARR154406 ADEQ AFIN: 47-01003 A R K A N S A S Department of Environmental Quality
NOTICE OF COVERAGE (NOC) FOR NPDES STORMWATER CONSTRUCTION GENERAL PERMIT NUMBER ARRlSOOOO
Attn: Shawn Hill Entergy Arkansas 401 W. Capitol Ave. A-TCBY-25E Little Rock, AR 72203
The Notice of Intent (NOI) and Storm water Pollution Prevention Plan (SWPPP) for coverage under the ARR 150000 Stormwater Construction General Permit were received on 3/26/2014 and have been reviewed. The facility has been assigned Permit Tracking Number ARR154406 and AFIN 47-01003. Any permit-related correspondence must include this Permit Tracking Number and AFIN. This NOC is issued to Entergy Arkansas in reliance upon the statements and representations made in the submittal for the following project located in Mississippi County:
Driver 500/250-kV Substation 0.6 miles east on State Rd 198 from intersection with Hwy 61 Osceola, AR 72370
The Project Contact Person for this construction site is Brian Eddins, 501-377-4042.
In accordance with the NO! there will be 19.00 acres disturbed out of 26.50 total acres. If additional acreage will be disturbed, a new site map indicating the new disturbed area and including all requirements of the site map set forth in Part II.A.4.F of ARR 150000 must be submitted to the Department prior to any activity taking place on the additional acreage.
The SWPPP will be located in the construction trailer.
Compliance with all conditions and limitations ofthe enclosed general permit is required.
This authorization must be posted at the construction site in a prominent place per the general permit.
Coverage Date: 03/31/2014
Expiration Date: 10/31/2016
Mo Shafii Assistant Chief, Water Division Arkansas Department of Environmental Quality
ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY, WATER DIVISION 5301 NORTHSHORE DRIVE I NORTH LITTLE ROCK I ARKANSAS 72118-53171 TELEPHONE 501-682-06231 FAX 501-682-0880 www.adeq.state.ar.us I [email protected] APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 1 of Part I Permit No. ARR150000
PART I PERMIT REQUIREMENTS
Information in Part I is organized as follows:
Section A: Definitions Section B: Coverage Under this Permit: 1. Permitted Area 2. Eligibility 3. Responsibilities of the Operator 4. Where to Submit 5. Requirements for Qualifying Local Program (QLP) 6. Requirements for Coverage 7. Notice of Intent (NOI) Requirements 8. Posting Notice of Coverage (NOC) 9. Applicable Federal, State or Local Requirements 10. Allowable Non-Stormwater Discharges 11. Limitations on Coverage (Exclusions) 12. Effluent Limitation Guidelines (ELG) 13. Natural Buffer Zones 14. Waivers from Permit Coverage 15. Notice of Termination (NOT) 16. Responsibilities of the Operator of a Larger Common Plan of Development for a Subdivision 17. Change in Operator 18. Late Notifications 19. Failure to Notify 20. Maintenance 21. Releases in Excess of Reportable Quantities 22. Attainment of Water Quality Standards
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SECTION A: DEFINITIONS
1. "ADEQ" or "Department" is referencing the Arkansas Department of Environmental Quality. The Department is the governing authority for the National Pollutant Discharge Elimination System program in the state of Arkansas.
2. "Arkansas Pollution Control and Ecology Commission" shall be referred to as APCEC throughout this permit.
3. "Automatic Coverage" indicates those sites that are defined as a small construction site or a site that is less than five (5) acres but part of a larger common plan.
4. "Best Management Practices (BMPs)" schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants to Waters of the State. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. According to the EPA BMP manual the use of hay-bales in concentrated flow areas is not recommended as a best management practice.
5. "Cognizant Official" a duly authorized representative, as defined in Part II.B.9.B.
6. "Commencement of Construction" the initial disturbance of soils associated with clearing, grading, or excavating activities or other construction-related activities.
7. "Contaminated" means a substance the entry of which into the MS4, Waters of the State, or Waters of the United States may cause or contribute to a violation of Arkansas water quality standards.
8. "Control Measure" as used in this permit, refers to any Best Management Practice or other method used to prevent or reduce the discharge of pollutants to Waters of the State.
9. "Construction Site" an area upon which one or more land disturbing construction activities occur that in total will disturb one acre or more of land, including areas that are part of a larger common plan of development or sale where multiple separate and distinct land disturbing construction activities may be taking place at different times on different schedules but under one plan such that the total disturbed area is one acre or more.
10. "CWA" the Clean Water Act or the Federal Water Pollution Control Act.
11. "Dedicated Portable Asphalt Plant" a portable asphalt plant that is located on or contiguous to a construction site that provides asphalt only to the construction site on which the plant is located or adjacent to. The term does not include facilities that are subject to the asphalt emulsion effluent guideline limitations at 40 CFR Part 443.
12. "Dedicated Portable Concrete Plant" a portable concrete plant that is located on or contiguous to a construction site and that provides concrete only to the construction site on which the plant is located on or adjacent to.
13. "Detention Basin" a detention basin is an area where excess stormwater is stored or held temporarily and then slowly drains when water levels in the receiving channel recede. In essence, the water in a detention basin is temporarily detained until additional room becomes available in the receiving channel.
14. "Director" the Director, Arkansas Department of Environmental Quality, or a designated representative.
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15. "Discharge" when used without qualification means the “discharge of a pollutant”.
16. "Discharge of Stormwater Associated with Construction Activity" as used in this permit, refers to a discharge of pollutants in stormwater runoff from areas where soil disturbing activities (e.g., clearing, grading, or excavation), construction materials or equipment storage or maintenance (e.g., fill piles, borrow area, concrete truck washout, fueling), or other industrial stormwater directly related to the construction process (e.g., concrete or asphalt batch plants) are located.
17. "Discharge-Related Activities" as used in this permit, include: activities that cause, contribute to, or result in stormwater point source pollutant discharges, including but not limited to: excavation, site development, grading and other surface disturbance activities; management of solid waste and debris; and measures to control stormwater including the construction and operation of BMPs to control, reduce or prevent stormwater pollution.
18. "Disturbed area" the total area of the site where any construction activity is expected to disturb the ground surface. This includes any activity that could increase the rate of erosion, including, but not limited to, clearing, grubbing, grading, excavation, demolition activities, haul roads, and areas used for staging. Also included, are stockpiles of topsoil, fill material and any other stockpiles with a potential to create additional runoff.
19. "Eligible" qualified for authorization to discharge stormwater under this general permit.
20. "Erosion" the process by which the land’s surface is worn away by the action of wind, water, ice or gravity.
21. "Facility" or "Activity" any NPDES “point source” or any other facility or activity (including land or appurtenances thereto) that is subject to regulation under the NPDES program.
22. "Final Stabilization":
A. All soil disturbing activities at the site have been completed and either of the two following criteria are met:
1) A uniform (e.g., evenly distributed, without large bare areas) perennial vegetative cover with a density of 80% of the native background vegetative cover for the area has been established on all unpaved areas and areas not covered by permanent structures, or 2) Equivalent permanent stabilization measures (such as the use of riprap, gabions, or geotextiles) have been employed.
B. When background native vegetation will cover less than 100% of the ground (e.g., arid areas, beaches), the 80% coverage criteria is adjusted as follows: if the native vegetation covers 50% of the ground, 80% of 50% (0.80 x 0.50 = 0.40) would require 40% total cover for final stabilization. On a beach with no natural vegetation, no stabilization is required.
C. For individual lots in residential construction, final stabilization means that either:
1) The homebuilder has completed final stabilization as specified above, or 2) The homebuilder has established temporary stabilization including perimeter controls for an individual lot prior to occupation of the home by the homeowner and informing the homeowner of the need for, and benefits of, final stabilization.
D. For construction projects on land used for agricultural purposes (e.g., pipelines across crop or range land, staging areas for highway construction, etc.), final stabilization may be accomplished by returning the disturbed land to its pre- APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 4 of Part I Permit No. ARR150000
construction agricultural use. Areas disturbed that were not previously used for agricultural activities, such as buffer strips immediately adjacent to “Water of the United States”, and areas which are not being returned to their pre- construction agricultural use must meet the final stabilization criteria in A, B, or C above.
23. "Grading Activities" as used in this permit are those actions that disturb the surface layer of the ground to change the contouring, surface drainage pattern, and/or any other slope characteristics of the land without significantly adding or removing on-site rock, soil, and other materials. This can include demolition, excavation, and filling.
24. "Infrastructure" streets, drainage, curbs, utilities, etc.
25. "Impaired Water" a water body listed in the current, approved Arkansas 303(d) list.
26. "Landscaping" improving the natural beauty of a piece of land (i.e. entrance of subdivision) through plantings or altering the contours of the ground.
27. "Large and Medium Municipal Separate Storm Sewer System" all municipal separate storm sewer systems that are either:
A. Located in an incorporated place with a population of 100,000 or more as determined by the latest Decennial Census by the Bureau of Census: or B. Located in the counties with unincorporated urbanized populations of 100,000 or more, except municipal, separate storm sewers that are located in the incorporated places, townships or towns within such counties; or C. Owned or operated by a municipality other than those described in paragraphs (i) or (ii) and that are designated by the Director as part of the large or medium municipal separate storm sewer system.
28. "Large Construction Site" construction activity including clearing, grading and excavation, except operations that result in the disturbance of less than five acres of total land area. Construction activity also includes the disturbance of less than five acres of total land area that is a part of a larger common plan of development or sale if the larger common plan will ultimately disturb five acres. (Please see Part I.B.14 for partial waivers.)
29. "Larger Common Plan of Development" a contiguous (sharing a boundary or edge; adjacent; touching) area where multiple and distinct construction activities may be taking place at different times on different schedules under one plan. Such a plan might consist of many small projects (e.g. a common plan of development for a residential subdivision might lay out the streets, house lots, and areas for parks, schools and commercial development that the developer plans to build or sell to others for development.) All these areas would remain part of the common plan of development or sale. The following items can be used as guidance for deciding what might or might not be considered a “Common Plan of Development or Sale.” The ‘‘plan’’ in a common plan of development or sale is broadly defined as any announcement or piece of documentation (including a sign, public notice or hearing, sales pitch, advertisement, drawing, permit application, zoning request, computer design, etc.) or physical demarcation (including boundary signs, lot stakes, surveyor markings, etc.) indicating construction activities may occur on a specific plot. The applicant must still meet the definition of operator in order to be required to get permit coverage, regardless of the acreage that is personally disturbed.
If a smaller project (i.e., less than 1 acre) is part of a large common plan of development or sale (e.g., you are building a residential home on a ½ acre lot in a 40 acre subdivision or are putting in a fast food restaurant on a ¾ acre pad that is part of a 20 acre retail center) permit coverage is required. Under 40 CFR 122.26(b)(2)(vi), smaller parts of a larger common plan of development are automatically authorized under this general permit and should follow the conditions of a site with automatic coverage set forth in this permit (see Part I.B.6.A).
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30. "NOC" Notice of Coverage
31. "NOI" Notice of Intent to be covered by this permit.
32. "NOT" Notice of Termination.
33. "Operator" for the purpose of this permit and in the context of stormwater associated with construction activity, means any person (an individual, association, partnership, corporation, municipality, state or federal agency) who has the primary management and ultimate decision-making responsibility over the operation of a facility or activity. The operator is responsible for ensuring compliance with all applicable environmental regulations and conditions.
In addition, for purposes of this permit and determining who is an operator, ‘‘owner’’ refers to the party that owns the structure being built. Ownership of the land where construction is occurring does not necessarily imply the property owner is an operator (e.g., a landowner whose property is being disturbed by construction of a gas pipeline or a landowner who allows a mining company to remove dirt, shale, clay, sand, gravel, etc. from a portion of his property). Likewise, if the erection of a structure has been contracted for, but possession of the title or lease to the land or structure is not to occur until after construction, the would- be owner may not be considered an operator (e.g., having a house built by a residential homebuilder).
34. "Outfall" a point source where stormwater leaves the construction site.
35. "Owner" the owner or operator of any “facility or activity” subject to regulation under the NPDES program. In addition, for purposes of this permit and determining who is an operator, ‘‘owner’’ refers to the party that owns the structure being built. Ownership of the land where construction is occurring does not necessarily imply the property owner is an operator (e.g., a landowner whose property is being disturbed by construction of a gas pipeline). Likewise, if the erection of a structure has been contracted for, but possession of the title or lease to the land or structure is not to occur until after construction, the would-be owner may not be considered an operator (e.g. having a house built by a residential homebuilder).
36. "Physically Interconnected" that one municipal separate storm sewer system is connected to a second municipal separate storm sewer system in such a way that it allows for direct discharges into the second system.
37. "Point Source" any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural stormwater runoff.
38. "Qualified Local Program" is a municipal program for stormwater discharges associated with construction sites that has been formally approved by the Department.
39. "Qualified personnel" a person knowledgeable in the principles and practice of erosion and sediment controls who possesses the skills to assess conditions at the construction site that could impact stormwater quality and to assess the effectiveness of any sediment and erosion control measures selected to control the quality of stormwater discharges from the construction activity.
40. "Regulated Small Municipal Separate Storm Sewer System" all municipal separate storm sewer systems that are either:
A. Located within the boundaries of an “urbanized area” with a population of 50,000 or more as determined by the latest Decennial Census by the Bureau of Census; or B. Owned or operated by a municipality other than those described in paragraph A and that serve a jurisdiction with a APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 6 of Part I Permit No. ARR150000
population of at least 10,000 and a population density of at least 1,000 people per square mile; or C. Owned or operated by a municipality other than those described in paragraphs A and B and that contributes substantially to the pollutant loadings of a “physically interconnected” municipal separate storm sewer system.
41. "Retention Basin" a basin that is designed to hold the stormwater from a rain event and allow the water to infiltrate through the bottom of the basin. A retention basin also stores stormwater, but the storage of the stormwater would be on a more permanent basis. In fact, water often remains in a retention basin indefinitely, with the exception of the volume lost to evaporation and the volume absorbed into the soils. This differs greatly from a detention basin, which typically drains after the peak of the storm flow has passed, sometimes while it is still raining.
42. "Runoff Coefficient" the fraction of total rainfall that will appear at the conveyance as runoff.
43. "Sediment" material that settles to the bottom of a liquid.
44. "Sediment Basin" a basin that is designed to maintain a 10 year-24 hour storm event for a minimum of 24-hours in order to allow sediment to settle out of the water.
45. "Small Construction Site" construction activities including clearing, grading, and excavating that result in land disturbance of equal to or greater than one acre and less than five acres. Small construction activity also includes the disturbance of less than one acre of total land area that is part of a larger common plan of development or sale if the larger common plan will ultimately disturb equal to or greater than one and less than five acres. Small construction activity does not include routine maintenance.
46. "Stormwater" stormwater runoff from rainfall, snow melt runoff, and surface runoff and drainage.
47. "Stormwater Associated with Construction Activity" the discharge from any conveyance which is used for collecting and conveying stormwater and which is directly related to construction activity.
48. "Stormwater Pollution Prevention Plan (SWPPP or SWP3)" a plan that includes site map(s), an identification of construction/contractor, activities that could cause pollutants in the stormwater, and a description of measures or practices to control these pollutants (BMPs).
49. "Temporary Sediment Controls" controls that are installed to control sediment runoff from the site. These could be silt fencing, rock check dams, etc.
50. "Total Maximum Daily Load" or "TMDL" the sum of the individual wasteload allocations (WLAs) for point sources and load allocations (LAs) for non-point sources and natural background. If receiving water has only one point source discharger, the TMDL is the sum of that point source WLA plus the LAs for any non-point sources of pollution and natural background sources, tributaries, or adjacent segments. TMDLs can be expressed in terms of either mass per time, toxicity, or other appropriate measure.
51. "Uncontaminated" cannot exceed the water quality standards as set forth in APCEC Regulation 2.
52. "Urbanized Area" the areas of urban population density delineated by the Bureau of the Census for statistical purposes and generally consisting of the land area comprising one or more central place(s) and the adjacent densely settled surrounding area that together have a residential population of at least 50,000 and an overall population density of at least 1,000 people per square mile as determined by the latest Decennial Census by the Bureau of Census. APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 7 of Part I Permit No. ARR150000
SECTION B: COVERAGE UNDER THIS PERMIT
Introduction
This Construction General Permit (CGP) authorizes stormwater discharges from large and small construction activities that result in a total land disturbance of equal to or greater than one acre, where those discharges enter surface Waters of the State or a Municipal Separate Storm Sewer System (MS4) leading to surface Waters of the State subject to the conditions set forth in this permit. This permit also authorizes stormwater discharges from any other construction activity designated by ADEQ where ADEQ makes that designation based on the potential for contribution to an excursion of a water quality standard or for significant contribution of pollutants to Waters of the State. This permit replaces the permit issued in 2008. The goal of this permit is to minimize the discharge of stormwater pollutants from construction activity. The Operator should make sure to read and understand the conditions of the permit. A copy of the General Stormwater Construction Permit is available on the ADEQ web site at http://www.adeq.state.ar.us/water/branch_permits/general_permits/stormwater/construction/construction.htm . You may also obtain a hard copy by contacting the ADEQ’s General Permits Section at (501) 682-0623.
1. Permitted Area. If a large or small construction activity is located within the State of Arkansas, the operator may be eligible to obtain coverage under this permit.
2. Eligibility. Permit eligibility is limited to discharges from “large” and “small” construction activity, or as otherwise designated by ADEQ. This general permit contains eligibility restrictions, as well as permit conditions and requirements. Operators may have to take certain actions to be eligible for coverage under this permit. In such cases, operators must continue to satisfy those eligibility provisions to maintain permit authorization. If operators do not meet the requirements that are a pre-condition to eligibility, then resulting discharges constitute unpermitted discharges. By contrast, if operators are eligible for coverage under this permit and do not comply with the requirements of the general permit, they may be in violation of the general permit for otherwise eligible discharges.
A. This general permit authorizes discharges from construction activities as defined in 40 CFR 122.26(a), 40 CFR 122.26(b)(14)(x), 40 CFR 122.26(b)(15)(i) and 40 CFR Part 450.
B. This permit also authorizes stormwater discharges from support activities (e.g., concrete or asphalt batch plants, equipment staging yards, materials storage areas, excavated material disposal areas, borrow areas) provided:
1) The support activity is directly related to a specific construction site that is required to have NPDES permit coverage for discharges of stormwater associated with the construction activity; 2) The support activity is not a commercial operation serving multiple unrelated construction projects by different operators, and does not operate beyond the completion of the construction activity at the last construction project it supports; 3) Pollutant discharges from support activity areas are minimized in compliance with conditions of this permit; and 4) discharges from the support activity areas must be identified in a Stormwater Pollution Prevention Plan (SWPPP) stating appropriate controls and measures for the area.
C. Other activities may be considered for this permit at the discretion of the Director as defined in 40 CFR 122.26(b)(15)(ii).
3. Responsibilities of the Operator. Permittees with operational control are responsible for compliance with all applicable terms and conditions of this permit as it relates to their activities on the construction site, including protection of endangered species and implementation of BMPs and other controls required by the SWPPP. Receipt of this general permit does not APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 8 of Part I Permit No. ARR150000
relieve any operator of the responsibility to comply with any other applicable federal, state or local statute, ordinance or regulation.
4. Where to Submit. The operator shall submit a complete and signed Notice of Intent (NOI), Stormwater Pollution Prevention Plan (SWPPP), and application fee to the Department at the following address:
Arkansas Department of Environmental Quality Discharge Permits Section 5301 Northshore Drive North Little Rock, AR 72118-5317
Or by electronic mail (Complete documents (NOI and SWPPP) must be submitted in PDF format) to:
NOTE: Notice of Coverage (NOC) will NOT be issued until payment has been received by ADEQ.
5. Requirements for Qualifying Local Program (QLP). The Department reviews and approves the QLPs to ensure that they meet or supersede both state and federal requirements outlined in this permit and 40 CFR 122.44(s). ADEQ will review the QLP at least every 5 years for recertification. If the Department approves a QLP, then the QLP requirements must at the minimum meet the Department’s requirements. This would include all templates and forms. This permit may be modified to add new QLPs or modify existing QLPs at the Department’s discretion. All public notice and other applicable costs incurred by the modification of the permit for the addition or modification of a QLP will be paid by the QLP.
If the small construction site is within the jurisdiction of a QLP, the operator of the small construction site is authorized to discharge stormwater associated with construction activity under QLP permit requirements only.
At this time only the City of Hot Springs is meeting the ADEQ minimum requirements.
6. Requirements for Coverage.
A. Automatic Coverage. An operator of each site with automatic coverage may discharge under this general permit without submitting to the Department a Notice of Intent (NOI), Stormwater Pollution Prevention Plan (SWPPP) and fee. All the permit conditions set forth must be followed. However, a completed NOC must be posted at the site for automatic permit coverage prior to commencing construction. Operators must have a copy of the SWPPP at the construction to have permit coverage and authorization to discharge. The Operator is responsible for ensuring that the site is in compliance with any changes or updates of this general permit, by either contacting ADEQ or reviewing the ADEQ website http://www.adeq.state.ar.us/water/branch_permits/general_permits/stormwater/construction/construction.htm .
B. Large Construction Sites. An operator of a large construction site discharging under this general permit must submit the following items at least two weeks prior to commencement of construction:
1) An NOI in accordance with the requirements of Part I.B.7 of this permit. 2) A complete SWPPP in accordance with the requirements of Part II.A of this permit. 3) An initial permit fee must accompany the NOI under the provisions of APCEC Regulation No. 9. Subsequent annual fees will be billed by the Department until the operator has requested a termination of coverage by APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 9 of Part I Permit No. ARR150000
submitting a Notice of Termination (NOT). Failure to remit the required permit fee may be grounds for the Director to deny coverage under this general permit.
C. Coverage within a QLP. An operator of a site with automatic coverage, as defined in this permit, shall comply with the requirements of the QLP which has jurisdiction over the site.
7. Notice of Intent (NOI) Requirements.
A. NOI Form. Large Construction site operators who intend to seek coverage for stormwater discharge under this general permit must submit a complete and accurate ADEQ NOI form to the Department at least two weeks prior to coverage under this permit. The NOI form must be the current version obtained from the stormwater webpage indicated above in Part I.B.
If the NOI is deemed incomplete, the Department will notify the applicant with regard to the deficiencies by a letter, email, or phone within ten (10) business days of receipt of NOI. If the operator does not receive a notification of deficiencies from ADEQ’s receipt of the NOI, the NOI is deemed complete. If the applicant does not provide the Department with the requested deficiencies within the deadline set by the Department, then the Department will return the NOI, fee and SWPPP back to the applicant.
B. Contents of the NOI. The NOI form contains, at a minimum, the following information:
1) Operator (Permittee) information (name, address, telephone and fax numbers, E-mail address) 2) Whether the operator is a federal, state, private, public, corporation, or other entity 3) Application Type: New or renewal 4) Invoice mailing information (name, address, and telephone and fax numbers) 5) Project Construction site information (name, county, address, contact person, direction to site, latitude and longitude for the entrance of the site or the endpoints for linear project (in degrees, minutes, and seconds), estimated construction start date and completion date through site final stabilization, estimate of the total project acreage and the acreage to be disturbed by the operator submitting the NOI, type of the project (subdivision, school, etc), whether the project is part of a larger common plan of development.) 6) Discharge information (name of the receiving stream, ultimate receiving stream, name of municipal storm sewer system) 7) Previous/Current permit information 8) The Certification statement and signature of a qualified signatory person in accordance with 40 CFR 122.22, as adopted by reference in APCEC Regulation No. 6 9) The certification of the facility corporation 10) Other information (location of the SWPPP).
C. Notice of Coverage (NOC). Unless notified by the Director to the contrary, dischargers who submit a NOI in accordance with the requirements of this permit are authorized to discharge stormwater from construction sites under the terms and conditions of this permit two weeks after the date the NOI is deemed complete by ADEQ. If the NOC has not been received by the permittee two weeks after the date the NOI is deemed complete by ADEQ, the NOI should be posted until the NOC is received. Upon review of the NOI and other available information, the Director may deny coverage under this permit and require submittal of an application for an individual NPDES permit.
8. Posting Notice of Coverage (NOC).
A. Large Sites: NOC Posting for Large Construction Sites. The posting for large construction sites shall be obtained from APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 10 of Part I Permit No. ARR150000
the Department only after the permittee has met the NOI, permit fee and complete SWPPP submittal to the Department for the coverage.
B. Automatic Coverage Sites. The Automatic Coverage (NOC) for small sites and a single site less than five (5) acres but part of a larger common plan, as defined in Part I.A, can be obtained from the Water Division’s Construction Stormwater webpage at: http://www.adeq.state.ar.us/water/branch_permits/general_permits/stormwater/construction/construction.htm. The NOC must be posted at the site prior to commencing construction. In addition, a copy of the SWPPP must be available at the construction site in accordance with Part II.A.2. B and D prior to commencing construction.
C. Linear Projects. If the construction project is a linear construction project (e.g., pipeline, highway, etc.), the notice must be placed in a publicly accessible location near where construction is actively underway and moved as necessary.
Please note, this permit does not provide the public with any right to trespass on a construction site for any reason, including inspection of a site; nor does this permit require that the permittee allow members of the public access to a construction site.
9. Applicable Federal, State or Local Requirements. The operator must ensure that the stormwater controls implemented at the site are consistent with all applicable federal, state, or local requirements. Additionally, an operator who is operating under approved local erosion and sediment plans, grading plans, local stormwater permits, or stormwater management plans shall submit signed copies of the Notice of Intent (NOI) to the local agency (or authority) upon the local agency’s request.
10. Allowable Non-Stormwater Discharges.
A. The following non-stormwater discharges that are combined with stormwater during construction may be authorized by this permit. Non-stormwater discharges must be addressed in the stormwater pollution prevention plan and measures to minimize or eliminate non-stormwater discharge should be taken if reasonably possible. 1) Fire fighting activities; 2) Fire hydrant flushings; 3) Water used to wash vehicles (where detergents or other chemicals are not used) or control dust in accordance with Part II.A.4.H.2; 4) Potable water sources including uncontaminated waterline flushings; 5) Landscape Irrigation ; 6) Routine external building wash down which does not use detergents or other chemicals; 7) Pavement washwaters where spills or leaks of toxic or hazardous materials have not occurred (unless all spilled materials have been removed) and where detergents or other chemicals are not used; 8) Uncontaminated air conditioning, compressor condensate (See Part I.B.12.C of this permit);, 9) Uncontaminated springs, excavation dewatering and groundwater (See Part I.B.12.C of this permit); 10) Foundation or footing drains where flows are not contaminated with process materials such as solvents (See Part I.B.12.C of this permit);
11. Limitations on Coverage (Exclusions). The following stormwater discharges associated with construction activity are not covered by this permit:
A. Post Construction Discharge. Stormwater discharges associated with construction activities that originate from the site after construction activities have been completed, the site has undergone final stabilization, and the permit has been terminated.
B. Discharges Mixed with Non-Stormwater. Stormwater discharges that are mixed with sources of non-stormwater other than those identified in Part I.B.10. APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 11 of Part I Permit No. ARR150000
C. Discharges Covered by another Permit. Stormwater discharges associated with construction activity that are covered under an individual or an alternative general permit may be authorized by this permit after an existing permit expires provided the expired permit did not establish numeric effluent limitations for such discharges.
D. Discharges into Receiving Waters with an Approved TMDL. Discharges from a site into receiving waters for which there is an established total maximum daily load (TMDL) allocation (www.adeq.state.ar.us/water/branch_planning/default.htm) for Turbidity, Oil & Grease, and/or other pollutants at the discretion of the Director are not eligible for coverage under this permit unless the permittee develops and certifies a stormwater pollution prevention plan (SWPPP) that is consistent with the assumptions and requirements in the approved TMDL. To be eligible for coverage under this general permit, operators must incorporate into their SWPPP any conditions applicable to their discharges necessary for consistency with the assumptions and requirements of the TMDL within any timeframes established in the TMDL. If a specific numeric allocation has been established that would apply to the project’s discharges, the operator must incorporate that allocation into its SWPPP and implement necessary steps to meet that allocation. Please note that the Department will be reviewing this information. If it is determined that the project will discharge into a receiving stream with a TMDL, then the Department may require additional BMPs.
E. Discharges into Impaired Receiving Waters (303(d) List). Discharges from a site into a receiving waters listed as impaired under Section 303(d) of the Clean Water Act ( www.adeq.state.ar.us/water/branch_planning/default.htm ) for Turbidity, Oil & Grease and/or other pollutants at the discretion of the Director, must incorporate into the SWPPP any additional BMPs needed to sufficiently protect water quality. The SWPPP must include a proposal for monitoring to determine if the BMPs and controls are effective. Please note that the Department will be reviewing this information. If it is determined that the project will discharge to an impaired water body, then the Department may require additional BMPs.
12. Effluent Limitation Guidelines (ELG). All permittees must comply with the following effluent limits:
A. Erosion and Sediment Controls. Design, install and maintain effective erosion controls and sediment controls to minimize the discharge of pollutants. At a minimum, such controls must be designed, installed and maintained to:
1) Control stormwater volume and velocity within the site to minimize soil erosion; 2) Control stormwater discharges, including both peak flowrates and total stormwater volume, to minimize erosion at outlets and to minimize downstream channel and streambank erosion; 3) Minimize the amount of soil exposed during construction activity; 4) Minimize the disturbance of steep slopes; 5) Minimize sediment discharges from the site. The design, installation and maintenance of erosion and sediment controls must address factors such as the amount, frequency, intensity and duration of precipitation, the nature of resulting stormwater runoff, and soil characteristics, including the range of soil particle sizes expected to be present on the site; 6) Provide and maintain natural buffers around surface waters, direct stormwater to vegetated areas to increase sediment removal and maximize stormwater infiltration, unless infeasible; and 7) Minimize soil compaction and, unless infeasible, preserve topsoil.
B. Soil Stabilization. Stabilization of disturbed areas must, at a minimum, be initiated immediately whenever any clearing, grading, excavating or other earth disturbing activities have permanently ceased on any portion of the site, or temporarily ceased on any portion of the site and will not resume for a period exceeding 14 calendar days. Stabilization must be completed within a period of time determined by the permitting authority. In arid, semiarid, and drought- APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 12 of Part I Permit No. ARR150000
stricken areas where initiating vegetative stabilization measures immediately is infeasible, alternative stabilization measures must be employed as specified by the permitting authority.
C. Dewatering. Discharges from dewatering activities, including discharges from dewatering of trenches and excavations, are prohibited unless managed by appropriate controls. There shall be no turbid discharges to surface waters of the state resulting from dewatering activities. If trench or ground waters contain sediment, it must pass through a sediment settling pond or other equally effective sediment control device, prior to being discharged from the construction site. Alternatively, sediment may be removed by settling in place or by dewatering into a sump pit, filter bag, or comparable practice. Ground water dewatering which does not contain sediment or other pollutants is not required to be treated prior to discharge. However, care must be taken when discharging ground water to ensure that it does not become pollutant-laden by traversing over disturbed soils or other pollutant sources.
D. Pollution Prevention Measures. Design, install, implement, and maintain effective pollution prevention measures to minimize the discharge of pollutants. At a minimum, such measures must be designed, installed, implemented and maintained to:
1) Minimize the discharge of pollutants from equipment and vehicle washing, wheel wash water, and other wash waters. Wash waters must be treated in a sediment basin or BMP control that provides equivalent or better treatment prior to discharge; 2) Minimize the exposure of building materials, building products, construction wastes, trash, landscape materials, fertilizers, pesticides, herbicides, detergents, sanitary waste and other materials present on the site to precipitation and to stormwater; and 3) Minimize the discharge of pollutants from spills and leaks and implement chemical spill and leak prevention and response procedures.
E. Prohibited discharges. The following discharges are prohibited:
1) Wastewater from washout of concrete, unless managed by an appropriate control; 2) Wastewater from washout and cleanout of stucco, paint, form release oils, curing compounds and other construction materials; 3) Fuels, oils, or other pollutants used in vehicle and equipment operation and maintenance; and 4) Soaps or solvents used in vehicle and equipment washing.
F. Surface Outlets. When discharging from basins and impoundments, utilize outlet structures that withdraw water from the surface, unless infeasible.
13. Natural Buffer Zones. A natural buffer zone as stated below shall be maintained at all times. Exceptions from this requirement for areas, such as water crossings, limited water access, and restoration of the buffer are allowed if the permittee fully documents in the SWPPP the circumstances and reasons for the buffer zone encroachment. Additionally, this requirement is not intended to interfere with any other ordinance, rule or regulation, statute or other provision of law.
A. For construction projects where clearing and grading activities will occur, the SWPPP must provide at least twenty-five (25) feet of natural buffer zone, as measured horizontally from the top of the bank to the disturbed area, from any named or unnamed streams, creeks, rivers, lakes or other water bodies.
B. The Department may also require up to fifty (50) feet of natural buffer zone, as measured from the top of the bank to the disturbed area, from established TMDL water bodies, streams listed on the 303 (d)-list, an Extraordinary Resource Water (ERW), Ecologically Sensitive Waterbody (ESW), Natural and Scenic Waterway (NSW), and/or any other uses APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 13 of Part I Permit No. ARR150000
at the discretion of the Director.
C. Linear projects will be evaluated individually by the Department to determine natural buffer zone setbacks.
14. Waivers from Permit Coverage. The Director may waive the otherwise applicable requirements of this general permit for stormwater discharges from construction activities under the terms and conditions described in this section.
A. Waiver Applicability and Coverage. Based upon 40 CFR Part 122.26.b.15.i.A, operators of small construction activities may apply for and receive a waiver from the requirements to obtain this permit.
B. No Stormwater Leaving the Site. If all of the stormwater from the construction activity is captured on-site under any size storm event and allowed to evaporate, soak into the ground on-site, or is used for irrigation, a permit is not needed.
C. TMDL Waivers. This waiver is available for sites with automatic coverage if the ADEQ has established or approved a TMDL that addresses the pollutant(s) of concern and has determined that controls on stormwater discharges from small construction activity are not needed to protect water quality. The pollutant(s) of concern include sediment (such as total suspended solids, turbidity or siltation) and any other pollutant that has been identified as a cause of impairment of any water body that will receive a discharge from the construction activity. Information on TMDLs that have been established or approved by ADEQ is available from ADEQ online at http://www.adeq.state.ar.us/water/branch_planning/default.htm.
15. Notice of Termination (NOT). All construction activities that disturbed soil are complete, the site has reached final effective stabilization (100% stabilization with 80% density), all stormwater discharges from construction activities authorized by this permit are eliminated and all temporary sediment controls are removed and properly disposed, the operator of the facility may submit a complete Notice of Termination (NOT) to the Director. Along with the NOT, pictures that represent the entire site should be submitted for review. Final stabilization is not required if the land is returned to its pre-construction agriculture use. Operators of small construction sites are not required to submit NOTs for their construction sites. However, final stabilization is required on all sites. If a Notice of Termination is not submitted when the project is completed, the operator will be responsible for annual fees.
16. Responsibilities of the Operator of a Larger Common Plan of Development for a Subdivision.
A. The operator is ultimately responsible for the runoff from the perimeter of the entire development. Regardless for the reason of the runoff, the operator is responsible for ensuring sufficient overall controls of the development.
B. The operator shall not terminate the permit coverage until the following conditions have been met:
1) After all construction including landscaping and lot development has been completed; and 2) All lots are sold and developed.
The following exceptions to this requirement can apply:
a. less than 100% sold and developed at the discretion of the Director, or b. Separation of the larger common plan if twenty-four (24) months have passed with no construction activity, or c. All lots are developed and there are no temporary common controls for subdivision outfalls, i.e. sediment basins, large sediment traps, check dams, etc.
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3) If lots are sold then re-sold to a third party then permit coverage needs to be obtained by each of the operators while they have ownership of the lots. The second owner is responsible to obtain the same certification from the third owner, i.e. the certification must pass from owner to owner.
C. The operator shall not terminate permit coverage until the operators of all the individual lots within the larger common plan are notified of their permitting requirements under this general permit. In this case, the signed certification statements from each operator of individual lots must be maintained in the stormwater pollution prevention plan for the large common plan. A copy of the signed certifications must be submitted to ADEQ with the NOT. The certification shall be as follows:
“I, ______, operator of an individual lot #______, block #______of ______subdivision, certify under penalty of law that I was notified by the operator of the larger common plan of the stormwater permitting requirements for my construction site(s). I understand prior to commencement of any construction activity I have to prepare and comply with a SWPPP and post the Construction Site Notice. I understand that prior to the sale of this lot to another party; I must notify the new owner of ADEQ requirements and obtain this certification from the new owner.”
Signature ______
D. The following examples are provided as clarification:
1) If a small portion of the original common plan of development remains undeveloped and there has been a period of time (i.e., more than 24 months) where there are no ongoing construction activities (i.e., all areas are either undisturbed or have been finally stabilized), operators may re-evaluate the original project based on the acreage remaining from the original “common plan.” If less than five but more than one acre remains to build out the original “common plan”, coverage under the large permit may not be required. However, operators will need to comply with the terms and conditions for Small Construction Sites in the Construction General Permit. If less than one acre remains of the original common plan, the individual project may be treated as a part of a less than one acre development and no permit would be required. 2) If operators have a long-range master plan of development where some portions of the master plan are conceptual rather than a specific plan of future development and the future construction activities would, if they occur at all, happen over an extended period of time (i.e., more than 24 months), operators may consider the “conceptual” phases of development to be separate “common plans” provided the periods of construction for the physically interconnected phases will not overlap. 3) Where discrete construction projects within a larger common plan of development or sale are located ¼ mile or more apart and the area between the projects is not being disturbed, each individual project can be treated as a separate plan of development or sale provided any interconnecting road, pipeline or utility project that is part of the same “common plan” is not concurrently being disturbed. For example, an interconnecting access road or pipeline were under construction at the same time, they would generally be considered as a part of a single “common plan” for permitting purposes. 4) If the operator sells all the lots in the subdivision to one or more multi-lot homebuilder(s), provisions must be made to obtain stormwater permit coverage by one of the following options: a. The permit may be transferred from the first “operator” to the new/second “operator”. b. A new, separate permit may be obtained by the second “operator”. NOTE: If a new permit is to be obtained, then it must be obtained before the first/original permit is terminated. 5) If the operator retains ownership of any lots in the subdivision, the operator shall maintain permit coverage for those lots under the original permit. The operator shall modify the Stormwater Pollution Prevention Plan (SWPPP) by stating which lots are owned and marking the lots on the site map. If there are one (1) or two (2) lots remaining and the total acreage is less than five (5) acres, the original permit could be terminated and those lots could be APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 15 of Part I Permit No. ARR150000
covered as a small site.
17. Change in Operator. For stormwater discharges from large construction sites where the operator changes, including instances where an operator is added after the initial NOI has been submitted, the new operator must ensure that a permit transfer form is received by the Department at least two (2) weeks prior to the operator beginning work at the site.
18. Late Notifications. A discharger is not precluded from submitting an NOI in accordance with the requirements of this part after the dates provided in Part I.B.6 of this permit. In such instances, the Director may bring an enforcement action for failure to submit an NOI in a timely manner or for any unauthorized discharges of stormwater associated with construction activity that have occurred on or after the dates specified in this permit.
19. Failure to Notify. The operator of a construction site who fails to notify the Director of their intent to be covered under this permit, and who potentially discharges pollutants (sediment, debris, etc.) to Waters of the State without an NPDES permit, is in violation of the Arkansas Water and Air Pollution Control Act.
20. Maintenance. Determination of the acreage of disturbance does not typically include disturbance for routine maintenance activities on existing roads where the line and grade of the road is not being altered, nor does it include the paving of existing roads. Maintenance activities (returning to original conditions) are not regulated under this permit unless one or more acres of underlying and/or surrounding soil are cleared, graded, or excavated as part of the operation.
21. Releases in Excess of Reportable Quantities.
A. The discharge of hazardous substances or oil in the stormwater discharge(s) from a facility shall be prevented or minimized in accordance with the applicable stormwater pollution prevention plan for the facility. This permit does not relieve the operator of the reporting requirements of 40 CFR Parts 110, 117 and 302. Where a release containing a hazardous substance or oil in an amount equal to or in excess of a reporting quantity established under either 40 CFR 110, 40 CFR 117, or 40 CFR 302, occurs during a 24-hour period, the following action shall be taken:
1) Any person in charge of the facility is required to notify the National Response Center (NRC) (800-424-8802) in accordance with the requirements of 40 CFR 110, 40 CFR 117, or 40 CFR 302 as soon as he/she has knowledge of the discharge; 2) The operator shall submit within five (5) calendar days of knowledge of the release a written description of the release (including the type and estimate of the amount of material released), the date that such release occurred, and the circumstances leading to the release, and steps to be taken in accordance with Part II.B.13 of this permit to the ADEQ. 3) The Stormwater Pollution Prevention Plan (SWPPP) described in Part II.A of this permit must be modified within fourteen (14) calendar days of knowledge of the release to:
a. Provide a description of the release and the circumstances leading to the release; and b. The date of the release;
4) Additionally, the SWPPP must be reviewed to identify measures to prevent the reoccurrence of such releases and to respond to such releases, and the plan must be modified where appropriate.
B. Spills. This permit does not authorize the discharge of hazardous substances or oil resulting from an on-site spill.
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22. Attainment of Water Quality Standards.
The operator must select, install, implement and maintain control measures at the construction site that minimize the discharge of turbidity and/or oil and grease and/or other pollutants at the discretion of the Director as necessary to protect water quality. In general, except in situations explained in below, the stormwater controls developed, implemented, and updated to be considered stringent enough to ensure that discharges do not cause or contribute to an excursion above any applicable water quality standard.
At any time after authorization, the ADEQ may determine that the stormwater discharges may cause, have reasonable potential to cause, or contribute to an excursion above any applicable water quality standard. If such a determination is made, ADEQ will require the permittee to:
A. Develop a supplemental BMP action plan describing SWPPP modifications to address adequately the identified water quality concerns and submit valid and verifiable data and information that are representative of ambient conditions and indicate that the receiving water is attaining water quality standards; or
B. Cease discharges of pollutants from construction activity and submit an individual permit application.
All written responses required under this part must include a signed certification consistent with Part II.B.9.
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PART II STANDARD CONDITIONS
Information in Part II is organized as follows:
Section A: Stormwater Pollution Prevention Plans (SWPPP): 1. Deadlines for Plan Preparation and Compliance 2. Signature, SWPPP, Inspection Reports, and Notice of Coverage (NOC) 3. Keeping SWPPP Current 4. Contents of the Stormwater Pollution Prevention Plan 5. Plan Certification
Section B: Standard Permit Conditions: 1. Retention of Records 2. Duty to Comply 3. Penalties for Violations of Permit Conditions 4. Continuance of Expired General Permit 5. Need to Halt or Reduce Activity Not a Defense 6. Duty to Mitigate 7. Duty to Provide Information 8. Other Information 9. Signatory Requirements 10. Certification 11. Penalties for Falsification of Reports 12. Penalties for Tampering 13. Oil and Hazardous Substance Liability 14. Property Rights 15. Severability 16. Transfers 17. Proper Operation and Maintenance 18. Inspection and Entry 19. Permit Actions 20. Re-Opener Clause 21. Local Requirements 22. Applicable Federal, State Requirements
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The operator must prepare a Stormwater Pollution Prevention Plan (the plan/SWPPP) before permit coverage. At least one SWPPP must be developed for each construction project or site covered by this permit. The SWPPP must follow the order outlined in Part II.A.4 & 5 below. This basic ADEQ format is available through the Department’s website http://www.adeq.state.ar.us/water/branch_permits/general_permits/stormwater/construction/construction.htm . Other formats may be used at the discretion of the Director if the format has been approved by the Department prior to use. The operator must implement the SWPPP as written from initial commencement of construction activity until final stabilization is complete, with changes being made as deemed necessary by the permittee, local, state or federal officials. The plan shall be prepared in accordance with good engineering practices, by qualified personnel and must:
Identify potential sources of pollution which may reasonably be expected to affect the quality of stormwater discharges from the construction; Identify, describe and ensure the implementation of Best Management Practices (BMPs), with emphasis on initial site stabilization, which are to be used to reduce pollutants in stormwater discharges from the construction site; Be site specific to what is taking place on a particular construction site; Ensure compliance with the terms and conditions of this permit; and Identify the responsible party for on-site SWPPP implementation.
1. Deadlines for Plan Preparation and Compliance.
A. Large Construction Sites.
The plan shall be completed and submitted for review, along with a NOI and initial permit fee 2 weeks prior to commencement of construction activities. Submittals of updates to the plan during the construction process are required only if requested by the Director.
B. Automatic Coverage Sites.
The plan shall be completed prior to the commencement of construction activities and updated as appropriate. Submittal of NOI, permit fee and SWPPP is not required. All conditions set forth in Part II.A must be followed and the NOC must be posted at the site prior to commencing construction. In addition, a copy of the SWPPP must be available at the construction site in accordance with Part II.2. B and D prior to commencing construction.
C. Existing Permittees.
Existing permittees, that were permitted prior to the issuance of this renewal permit, are required to update their plan as appropriate to come into compliance with the requirements contained in Part II.A.4 within ninety (90) days from the effective date of this permit.
2. Signature, Stormwater Pollution Prevention Plan (SWPPP), Inspection Reports and Notice of Coverage (NOC).
A. The SWPPP and inspection reports shall be signed by the operator (or cognizant official) in accordance with Part II.B.9 and be retained at the construction site during normal business hours (8:00 A.M. – 5:00 P.M.).
B. The operator shall make SWPPP and inspection reports available, upon request, to the Director, the EPA, or a State or local agency reviewing sediment and erosion plans, grading plans, or stormwater management plans, or, in the case of a stormwater discharge associated with construction activity which discharges through a municipal separate storm sewer system with an NPDES permit, to the municipal operator of the system.
C. The Director, or authorized representative, may notify the operator at any time that the plan does not meet one or more of the minimum requirements of this Part. Within seven (7) business days of such notification from the Director, (or as
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 3 of Part II Permit No. ARR150000 otherwise provided by the Director), or authorized representative, the operator shall make the required changes to the plan and submit to the Director a written certification that the requested changes have been made. The Department may request re-submittal of the SWPPP to confirm that all deficiencies have been adequately addressed. The Department may also take appropriate enforcement action for the period of time the operator was operating under SWPPP that did not meet the minimum requirements of this permit.
D. The operator must post the NOC near the main entrance of the construction site and visible to the public. The NOC will indicate the location of the SWPPP. If the SWPPP location is changed from the initial location, the NOC shall be updated to reflect the correct location of the SWPPP
3. Keeping SWPPP Current. The operator shall amend the SWPPP within seven (7) business days or whenever there is a change in design, construction, operation, or maintenance at the construction site which has or could have a significant effect on the potential for the discharge of pollutants to the Waters of the State that has not been previously addressed in the SWPPP. The SWPPP should also be modified if a determination has been made through inspections, monitoring (if required), or investigation by the operator, local, state, or federal officials that the discharges are causing or contributing to water quality violation or the plan proves to be ineffective in eliminating or significantly minimizing pollutants from sources identified in stormwater discharges from the construction site.
4. Contents of the Stormwater Pollution Prevention Plan (SWPPP). The SWPPP shall include the following items:
A. Site Description. SWPPP shall provide a description of the following:
1) A description of the nature of the construction activity and its intended use after the Notice of Intent (NOI) is filed (i.e., residential subdivision, shopping mall, etc.); 2) A description of the intended sequence of major activities which disturb soils for major portions of the site (e.g. grubbing, excavation, grading, infrastructure installation, etc.); 3) Estimates of the total area of the site (including off-site borrow and fill areas) and the total area of the site that is expected to be disturbed by excavation, grading or other activities; and 4) An estimate of the runoff coefficient of the site for pre- and post-construction activities and existing data describing the soil or the quality of any discharge from the site.
B. Responsible Parties. The SWPPP must identify (as soon as this information is known) all parties (i.e., General Contractors, Landscapers, Project Designers, and Inspectors) responsible for particular services they provide to the operator to comply with the requirements of the SWPPP for the project site, and areas over which each party has control. If these parties change over the life of the permit, or new parties are added, then the SWPPP should be updated to reflect these changes.
C. Receiving Waters. The SWPPP must include a clear description of the nearest receiving water(s), or if the discharge is to a municipal separate storm sewer, the name of the operator of the municipal system, and the ultimate receiving water(s).
D. Documentation of Permit Eligibility Related to the 303 (d) list and Total Maximum Daily Loads (TMDL). The SWPPP should include information on whether or not the stormwater discharges from the site enter a water body that is on the most recent 303 (d) list or with an approved TMDL. If the stormwater discharge does enter a water body that is on the most recent 303(d) list or with an approved TMDL, then the SWPPP should address the following items:
1) Identification of the pollutants that the 303 (d) list or TMDL addresses, specifically whether the 303 (d) list or TMDL addresses sediment or a parameter that addresses sediment (such as total suspended solids, turbidity, or siltation); 2) Identification of whether the operator’s discharge is identified, either specifically or generally, on the 303 (d) list or any associated assumptions and allocations identified in the TMDL for the discharge; and 3) Measures taken by the operator to ensure that its discharge of pollutants from the site is consistent with the assumptions and allocations of the TMDL.
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If the Department determines during the review process that the proposed project will be discharging to a receiving water that is on the most recent 303 (d) list or with an approved TMDL, then the Department will notify the applicant to include additional Best Management Practices in the SWPPP.
E. Attainment of Water Quality Standards After Authorization.
1) The permittee must select, install, implement, and maintain BMPs at the construction site that minimize pollutants in the discharge as necessary to meet applicable water quality standards. In general, except in situations explained below, the SWPPP developed, implemented, and updated to be considered as stringent as necessary to ensure that the discharges do not cause or contribute to an excursion above any applicable water quality standard.
2) At any time after authorization, the Department may determine that the stormwater discharges may cause, have reasonable potential to cause, or contribute to an excursion above any applicable water quality standard. If such a determination is made, the Department will require the permittee to:
a. Develop a supplemental BMP action plan describing SWPPP modifications to address adequately the identified water quality concerns and submit valid and verifiable data and information that are representative of ambient conditions and indicate that the receiving water is attaining water quality standards; or
b. Cease discharges of pollutants from construction activity and submit an individual permit application.
3) All written responses required under this part must include a signed certification (Part II.B.9)
F. Site Map. The SWPPP must contain a legible site map (or multiple maps, if necessary) complete to scale, showing the entire site, that identifies, at a minimum, the following:
1) Pre-construction topographic view; 2) Direction of stormwater flow (i.e., use arrows to show which direction stormwater will flow) and approximate slopes anticipated after grading activities; 3) Delineate on the site map areas of soil disturbance and areas that will not be disturbed under the coverage of this permit; 4) Location of major structural and nonstructural controls identified in the plan; 5) Location of main construction entrance and exit; 6) Location where stabilization practices are expected to occur; 7) Locations of off-site materials, waste, borrow area, or equipment storage area; 8) Location of areas used for concrete wash-out; 9) Location of all surface water bodies (including wetlands); 10) Locations where stormwater is discharged to a surface water and/or municipal separate storm sewer system if applicable, 11) Locations where stormwater is discharged off-site (should be continuously updated); 12) Areas where final stabilization has been accomplished and no further construction phase permit requirements apply.
G. Stormwater Controls. Each plan shall include a description of appropriate controls and measures that will be implemented at the construction site. The plan will clearly describe for each activity identified in the project description control measures associated with the activity and the schedule during the construction process that the measures will be implemented. Perimeter controls for the site must be installed after the clearing and grubbing necessary for installation of the measure, but before the clearing and grubbing for the remaining portions of the site. Perimeter controls must be actively maintained until final stabilization of those portions of the site upward of the perimeter control. Temporary perimeter controls must be removed after final stabilization and properly disposed. The description and implementation of controls shall address the following minimum components:
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1) Initial Site Stabilization, Erosion, and Sediment Controls and Best Management Practices. Design, install, implement and maintain effective erosion and sediment controls to minimize the discharge of pollutants. At a minimum the following controls and Best Management Practices (BMPs) must be designed, installed, implemented and maintained. Therefore, the SWPPP must address, at a minimum, the following:
a. For larger common plans, only streets, drainage, utility areas, areas needed for initial construction of streets (e.g., borrow pits, parking areas, etc.) and areas needed for stormwater structures may be disturbed initially. Upon stabilization of the initial areas, additional areas may be disturbed. b. The construction-phase erosion (such as site stabilization) and sediment controls (such as check dams) should be designed to retain sediment on-site to the extent practicable. c. All control measures must be properly selected, installed, and maintained in accordance with the manufacturer’s specifications, good engineering, and construction practices. If periodic inspections or other information indicates a control has been used inappropriately or incorrectly, the permittee must replace or modify the control for site situations. d. If sediment escapes the construction site, off-site accumulations of sediment must be removed at a frequency sufficient to minimize off-site impacts (e.g., fugitive sediment in street could be washed into storm sewers by the next rain and/or pose a safety hazard to users of public streets). This permit does not give the authority to trespass onto other property; therefore this condition should be carried out along with the permission of neighboring land owners to remove sediment. e. Sediment must be removed from sediment traps (if used please specify what type) or sedimentation ponds when design capacity has been reduced by 50%. f. Litter, construction debris, and construction chemicals exposed to stormwater shall be prevented from becoming a pollutant source for stormwater discharges (e.g., screening outfalls picked up daily). g. Off-site material storage areas (also including overburden and stockpiles of dirt, borrow areas, etc.) used solely by the permitted project are considered a part of the project and shall be addressed in the SWPPP.
2) Stabilization practices. The SWPPP must include, at a minimum, the following information:
a. Description and Schedule: A description of initial, interim, and permanent stabilization practices, including site-specific scheduling of the implementation of the practices. Site plans should ensure that existing vegetation is preserved where attainable and that disturbed areas are stabilized. Stabilization practices may include: mulching, temporary seeding, permanent seeding, geotextiles, sod stabilization, natural buffer strips, protection of trees, and preservation of mature vegetation and other appropriate measures.
b. Description of natural buffer areas: The Department requires that a natural buffer zone be established between the top of stream bank and the disturbed area. The SWPPP must contain a description of how the site will maintain natural buffer zones. For construction projects where clearing and grading activities will occur, SWPPP must provide at least twenty-five (25) feet of natural buffer zone from any named or unnamed streams, creeks, rivers, lakes or other water bodies. The plan must also provide at least fifty (50) feet of natural buffer zone from established TMDL water bodies, streams listed on the 303 (d)-list, an Extraordinary Resource Water (ERW), Ecologically Sensitive Waterbody (ESW), Natural and Scenic Waterway (NSW), and/or other uses at the discretion of the Director. If the site will be disturbed within the recommended buffer zone, then the buffer zone area must be stabilized as soon as possible. Exceptions from this requirement for areas, such as water crossings, limited water access, and restoration of the buffer are allowed if the permittee fully documents in the SWPPP the circumstances and reasons for the buffer zone encroachment. Additionally, this requirement is not intended to interfere with any other ordinance, rule or regulation, statute or other provision of law. Please note that above-grade clearing that does not disturb the soil in the buffer zone area does not have to comply with buffer zone requirements.
c. Records of Stabilization: A record of the dates when grading activities occur, when construction activities temporarily or permanently cease on a portion of the site, and when stabilization measures are initiated shall be included in the plan.
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d. Deadlines for Stabilization: Stabilization measures shall be initiated as soon as practicable in portions of the site where construction activities have temporarily ceased, but in no case more than fourteen (14) days after the construction activity in that portion of the site has temporarily or permanently ceased, except:
(1) Where the initiation of stabilization measures by the fourteenth (14th) day after construction activity temporarily ceases is precluded by snow cover, stabilization measures shall be initiated as soon as practicable.
(2) In arid, semiarid, and drought-stricken areas where initiating vegetative stabilization measures immediately is infeasible, alternative stabilization measures must be employed as specified by the permitting authority.
3) Structural Practices. A description of structural practices to divert flows from exposed soils, store flows, or otherwise limit runoff and the discharge of pollutants from exposed areas of the site to the degree attainable. Structural practices should be placed on upland soils to the degree attainable. The installation of these devices may be subject to Section 404 of the Clean Water Act. Such practices may include but are not limited to:
- silt fences (installed and maintained) - earthen dikes to prevent run-on - drainage swales to prevent run-on - check dams - subsurface drains - pipe slope drains - storm drain inlet protection - rock outlet protection - sediment traps - reinforced soil retaining systems - gabions - temporary or permanent sediment basins. A combination of erosion and sediment control measures is encouraged to achieve maximum pollutant removal. Adequate spillway cross-sectional area and re-enforcement must be provided for check dams, sediment traps, and sediment basins.
a. Sediment Basins:
(1) For common drainage locations that serve an area with ten (10) or more acres (including run-on from other areas) draining to a common point, a temporary or permanent sediment basin that provides storage based on either the smaller of 3600 cubic feet per acre, or a size based on the runoff volume of a 10 year, 24 hour storm, shall be provided where attainable (so as not to adversely impact water quality) until final stabilization of the site. In determining whether installing a sediment basin is attainable, the operator may consider factors such as site soils, slope, available area on site, etc. Proper hydraulic design of the outlet is critical to achieving the desired performance of the basin. The outlet should be designed to drain the basin within twenty-four (24) to seventy-two (72) hours. (A rule of thumb is one square foot per acre for a spillway design.) The 24-hour limit is specified to provide adequate settling time; the seventy-two (72)- hour limit is specified to mitigate vector control concerns. If a pipe outlet design is chosen for the outfall, then an emergency spillway is required. If “non-attainability” is claimed, then an explanation of non- attainability shall be included in the SWPPP. Where a sediment basin is not attainable, smaller sediment basins and/or sediment traps shall be used. Where a sediment basin is un-attainable, natural buffer strips or other suitable controls which are effective are required for all side slopes and down slope boundaries of the construction area. The plans for removal of the sediment basin should also be included with the description of the basin in the SWPPP.
(2) For drainage locations serving an area less than ten (10) acres, sediment traps, silt fences, or equivalent
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 7 of Part II Permit No. ARR150000 sediment controls are required for all side slope and down slope boundaries of the construction area unless a sediment basin providing storage based on either the smaller of 3600 cubic feet per acre, or a size based on the run off volume of a 10 year, 24 hour storm is provided. (A rule of thumb is one square foot per acre for a spillway.) However, in order to protect the Waters of the State, the Director, at their discretion, may require a sediment basin for any drainage areas draining to a common point.
b. Velocity Dissipation Devices:
Velocity dissipation devices must be placed at discharge locations, within concentrated flow areas serving two or more acres, and along the length of any outfall channel to provide a non-erosive flow velocity from the structure to a water course so that the natural physical and biological characteristics and functions are maintained and protected (i.e., no significant changes in the hydrological regime of the receiving water). Please note that the use of hay-bales is not recommended in areas of concentrated flow.
H. Other Controls.
1) No solid materials, including building materials, shall be discharged to Waters of the State. 2) Off-site vehicle tracking of sediments and the generation of dust shall be minimized through the use of a stabilized construction entrance and exit and/or vehicle tire washing. 3) For lots that are less than one (1) acre in size an alternative method may be used in addition to a stabilized construction entrance. An example of an alternative method could be daily street sweeping. This could allow for the shortening of the construction entrance. 4) The plan shall ensure and demonstrate compliance with applicable State or local waste disposal, temporary and permanent sanitary sewer or septic system regulations. 5) No liquid concrete waste shall be discharged to Waters of the State. Appropriate controls to prevent the discharge of concrete washout waters must be implemented if concrete washout will occur on-site. 6) No contaminants from fuel storage areas, hazardous waste storage and truck wash areas shall be discharged to waters of the State. Methods for protecting these areas shall be identified and implemented. These areas should not be located near a water body, if there is a water body on or near the project.
I. Non-stormwater discharges. Sources of non-stormwater listed in Part I.B.10 of this permit that are combined with stormwater discharges associated with construction activity must be identified in the plan. This list should be site specific non-stormwater discharges.
J. Post-Construction Stormwater Management. The operator is required to provide a description of measures that will be installed during the construction process to control pollutants in stormwater discharges that will occur after construction operations have been completed. Structural measures should be placed on upland soils to the degree attainable. The installation of these devices may be subject to Section 404 (Corps of Engineers) of the Clean Water Act. This permit only addresses the installation of stormwater management measures, and not the ultimate operation and maintenance of such structures after the construction activities have been completed and the site has undergone final stabilization. However, post-construction stormwater BMPs that discharge pollutants from a point source once construction is completed may need authorization under a separate ADEQ NPDES permit. Such practices may include but are not limited to:
- infiltration of runoff onsite - flow attenuation by use of open vegetated swales and natural depressions - stormwater retention structures - stormwater detention structures (including wet ponds) - sequential systems, which combine several practices
A goal of at least 80 % removal of total suspended solids from these flows which exceed predevelopment levels should be used in designing and installing stormwater management controls (where practicable). Where this goal is not met, the operator shall provide justification for rejecting each practice listed above based on site conditions.
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K. Applicable State or Local Programs. The SWPPP must be updated as necessary to reflect any revisions to applicable federal, state, or local requirements that affect the stormwater controls implemented at the site.
L. Inspections.
Inspections should conducted by qualified personnel (provided by the operator). Inspections must include all areas of the site disturbed by construction activity and areas used for storage of materials that are exposed to precipitation. Inspectors must look for evidence of, or the potential for, pollutants entering the stormwater conveyance system. Erosion and sedimentation control measures must be observed to ensure proper operation. Discharge locations must be inspected to determine whether erosion control measures are effective in preventing significant impacts to Waters of the State, where accessible. Where discharge locations are inaccessible, nearby downstream locations must be inspected to the extent that such inspections are practicable. Locations where vehicles enter or exit the site must be inspected for evidence of off-site sediment tracking. Inspections may not be required if the lot(s) within a larger common plan is/are sufficiently stabilized. In addition, inspections may not be required on a completed section of a linear project if that section has been sufficiently stabilized. Stabilized areas of the project should be indicated in the SWPPP and site map and show what date they were stabilized. The operator must ensure that no sediment will leave the lot(s) that are stabilized. These lots must be identified within the SWPPP and show what date they were stabilized. If the operator is unable to ensure this, then inspections must continue.
1) Inspection Frequency. Inspections must be conduct in accordance with one of the following schedules listed below. The schedule must be specified in the Stormwater Pollution Prevention Plan (SWPPP).
a. At least once every 7 calendar days, or b. At least once every 14 calendar days and within 24 hours of the end of a storm event of 0.5 inches or greater (a rain gauge must be maintained on-site).
2) Inspection Form. The ADEQ inspection form should be used for all inspections. The inspection form should include any erosion/sediment controls that are being used on the site. The form is available on the Departments website www.adeq.state.ar.us. If a different form is used it must at a minimum contain the following information:
a. Inspector Name and Title b. Date of Inspection c. Amount of Rainfall and Days Since Last Rain Event (only applicable to Part II.A.4.L.1.b) d. Approximate beginning and duration of the storm event e. Description of any discharges during inspection f. Locations of discharges of sediment/other pollutants g. Locations of BMPs in need of maintenance or where maintenance was performed h. If the BMPs are in working order and if Maintenance is required (including when scheduled and completed) i. Locations that are in need of additional controls j. Location and Dates When Major Construction Activities Begin, Occur or Cease k. Signature of qualified signatory official, in accordance with Part II.B.9
Additional information may be added to the inspection report at the permittees discretion.
3) Inspection Records. The report shall be retained as part of the SWPPP for at least three (3) years from the date the site is finally stabilized. The report shall be signed and have a certification statement in accordance with the requirements of this permit.
4) Winter Conditions. Inspections will not be required at construction sites where snow cover exists over the entire site for an extended period, and melting conditions do not exist. If there is any runoff from the site at any time during snow cover, melting conditions would be considered to be existent at the site and this inspection waiver would not apply. Regular inspections, as required by this permit, are required at all other times as specified in this
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 9 of Part II Permit No. ARR150000 permit. If winter conditions prevent compliance with the permit, documentation of the beginning and ending date of winter conditions should be included in the SWPPP.
5) Adverse Weather Conditions. Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local flooding, high winds, or electrical storms, or situations that otherwise make inspections impractical, such as extended frozen conditions. When adverse weather conditions prevent the inspection of the site, an inspection should be completed as soon as is safe and feasible. If adverse weather conditions prevent compliance with the permit, documentation of the beginning and ending date of adverse weather conditions should be included in the SWPPP.
M. Maintenance. A description of procedures to maintain vegetation, erosion and sediment control measures and other protective measures in good, effective operating condition shall be outlined in the plan. Any repairs that are needed based on an inspection shall be completed, when practicable, before the next storm event, but not to exceed a period of three (3) business days of discovery, or as otherwise directed by state or local officials. However, if conditions do not permit large equipment to be used, a longer time frame is allowed if the condition is thoroughly documented on the inspection form. Maintenance for manufactured controls must be done at a minimum of the manufacture’s specifications. Maintenance for non-manufactured controls, i.e. check dams, sediment traps, must be done upon 50% capacity.
N. Employee Training. The permittee is responsible for training personnel who are responsible for implementing activities identified in the SWPPP on the components and goals of the SWPPP and the requirements of the general permit. This includes contractors and subcontractors. Training should be given by a knowledgeable and qualified trainer. The SWPPP shall identify periodic dates for such training and records of training must be maintained with the SWPPP. Training records that are maintained electronically (i.e. database, etc) do not need to be maintained with the SWPPP, but must be accessible upon request. Formal training classes given by Universities or other third-party organizations are not required but recommended for qualified trainers; the permittee is responsible for the content of the training being adequate for personnel to implement the requirements of the permit.
5. Plan Certification. The SWPPP Certification must be signed by either the operator or the cognizant official identified on the Notice of Intent. All documents required by the permit and other information requested by the Director shall be signed by operator or by a duly authorized representative of the operator (Please see Part II.B.10 below for certification).
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 10 of Part II Permit No. ARR150000 SECTION B: STANDARD PERMIT CONDITIONS
1. Retention of Records.
A. The operator shall retain records of all Stormwater Pollution Prevention Plans, all inspection reports required by this permit, and records of all data used to complete the Notice of Intent (NOI) to be covered by this permit for a period of at least three years from the date the Notice of Termination letter is signed by the Department. This period may be extended by request of the Director at any time.
B. The operator shall retain a signed copy of the Stormwater Pollution Prevention Plan (SWPPP) and inspection reports required by this permit at the construction site from the date of project initiation to the date of final stabilization.
2. Duty to Comply. The operator must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the federal Clean Water Act and the Arkansas Water and Air Pollution Control Act and is grounds for: enforcement action; permit termination, revocation and re-issuance, or modification; or denial of a permit renewal application.
3. Penalties for Violations of Permit Conditions. The Arkansas Water and Air Pollution Control Act (Ark. Code Ann. 8-4- 101 et seq.) provides that any person who violates any provisions of a permit issued under the Act shall be guilty of a misdemeanor and upon conviction thereof shall be subject to imprisonment for not more than one (1) year, or a criminal penalty of not more than twenty five thousand dollars ($25,000) or by both such fine and imprisonment for each day of such violation. Any person who violates any provision of a permit issued under the Act may also be subject to civil penalty in such amount as the court shall find appropriate, not to exceed ten thousand dollars ($10,000) for each day of such violation. The fact that any such violation may constitute a misdemeanor shall not be a bar to the maintenance of such civil action.
4. Continuance of the Expired General Permit. An expired general permit continues in force and effect until a new general permit is issued. If this permit is not re-issued or replaced prior to the expiration date, it will be administratively continued in accordance with Arkansas Act 731 of 2011 and remain in force and effect. If the permittee were granted permit coverage prior to the expiration date, the permittee will automatically remain covered by the continued permit until the earliest of:
A. Re-issuance or replacement of this permit, at which time operators must comply with the conditions of the new permit, within 180 days prior to expiration date and no later than 30 days prior to expiration date; or
B. The operator’s submittal of a Notice of Termination (NOT); or
C. Issuance of an individual permit for the project’s discharges; or
D. A formal permit decision by the ADEQ to not re-issue this general permit, at which time operators must seek coverage under an individual permit.
Small site operators are responsible for ensuring that the site is in compliance with any changes or updates of this general permit, by reviewing the ADEQ website at: http://www.adeq.state.ar.us/water/branch_permits/general_permits/stormwater/construction/construction.htm .
5. Need to Halt or Reduce Activity Not a Defense. It shall not be a defense for an operator in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
6. Duty to Mitigate. The operator shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in violation of this permit which has reasonable likelihood of adversely affecting human health or the environment.
7. Duty to Provide Information. The operator shall furnish to the Director, an authorized representative of the Director, the
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 11 of Part II Permit No. ARR150000 EPA, a State or local agency reviewing sediment and erosion plans, grading plans, or stormwater management plans, or in the case of a stormwater discharge associated with industrial activity which discharges through a Municipal Separate Storm Sewer System (MS4) with an NPDES permit, to the municipal operator of the system, within a reasonable time, any information which is requested to determine compliance with this permit.
8. Other Information. When the operator becomes aware that he or she failed to submit any relevant facts or submitted incorrect information in the Notice of Intent or in any other report to the Director, he or she shall promptly submit such facts or information.
9. Signatory Requirements. All Notices of Intent (NOIs), reports, or information submitted to the Director or the operator of a regulated small, medium, or large municipal separate storm sewer system shall be signed and certified.
A. All Notices of Intent shall be signed as follows:
1) For a corporation: by a responsible corporate officer. For purposes of this section, a responsible corporate officer means:
a. A president, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation; or
b. The manager of one or more manufacturing, production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiating and directing other comprehensive measures to ensure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.
2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively;
3) For a municipality, State, Federal or other public agency: By either a principal executive or ranking elected official. For purposes of this section, a principal executive officer of a Federal agency includes:
a. The chief executive officer of the agency; or
b. A senior executive officer having responsibility for the overall operations of a principal geographic unit of the agency.
B. All reports required by the permit and other information requested by the Director shall be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if:
1) The authorization is made in writing by a person described above and submitted to the Director;
2) The authorization specifies either an individual or a person having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of a well or a well field, superintendent, or position of equivalent responsibility, or position of equivalent responsibility for environmental matters for the company. (A duly authorized representative may thus be either a named individual or any individual occupying a named position); and 3) Changes to authorization. If an authorization under this Part is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the above requirements must be submitted to the Director prior to or together with any reports, information, or applications to be signed by an authorized representative.
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 12 of Part II Permit No. ARR150000 10. Certification. Any person signing a document under this section shall make the following certification:
"I certify under penalty of law that this document and all attachments such as Inspection Form were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
Note: For this permit only, “this document” refers to the Stormwater Pollution Prevention Plan, “attachments” refers to the site map and inspection forms, and “system” is referencing the project site.
11. Penalties for Falsification of Reports. The Arkansas Water and Air Pollution Control Act provides that any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under this permit shall be subject to civil penalties specified in Part II.B.3 of this permit and/or criminal penalties under the authority of the Arkansas Water and Air Pollution Control Act (Ark. Code Ann. 8-4-101 et seq.).
12. Penalties for Tampering. The Arkansas Water and Air Pollution Control act provides that any person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under the Act shall be guilty of a misdemeanor and upon conviction thereof shall be subject to imprisonment for not more than one (1) year or a fine of not more than twenty five thousand dollars ($25,000) or by both such fine and imprisonment.
13. Oil and Hazardous Substance Liability. Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the operator from any responsibilities, liabilities, or penalties to which the operator is or may be subject under Section 311 of the Clean Water Act or Section 106 of CERCLA.
14. Property Rights. The issuance of this permit does not convey any property rights of any sort or any exclusive privileges, nor does it authorize any injury to private property, any invasion of personal rights, or any infringement of Federal, State, or local laws or regulations.
15. Severability. The provisions of this permit are severable. If any provisions of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provisions to other circumstances and the remainder of this permit shall not be affected thereby.
16. Transfers. This permit is not transferable to any person except after notice to the Director. A transfer form must be submitted to the ADEQ as required by this permit.
17. Proper Operation and Maintenance. The operator shall at all times:
A. Properly operate and maintain all systems of treatment and control (and related appurtenances) which are installed or used by the operator to achieve compliance with the conditions of this permit. This provision requires the operation of backup or auxiliary facilities or similar systems which are installed by an operator only when the operation is necessary to achieve compliance with the conditions of the permit. B. Provide an adequate operating staff which is duly qualified to carry out operation, inspection, maintenance, and testing functions required to ensure compliance with the conditions of this permit.
18. Inspection and Entry. The operator shall allow the Director, the EPA, or an authorized representative, or, in the case of a construction site which discharges to a municipal separate storm sewer, an authorized representative of the municipal operator of the separate sewer system receiving the discharge, upon the presentation of credentials and other documents as may be required by law, to:
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. Page 22 13 of Part II Permit No. ARR150000 A. Enter upon the operator's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit; B. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit; C. Inspect at reasonable times any facilities or equipment, including monitoring and control equipment and practices or operations regulated or required by the permit; D. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the CWA, any substances or parameters at any location on the permitted property.
19. Permit Actions. This permit may be modified, revoked and reissued, or terminated for any cause including, but not limited to, the following;
A. Violation of any terms or conditions of this permit; B. Obtaining this permit by misrepresentation or failure to fully disclose all relevant facts; C. A change in any conditions that requires either a temporary or permanent reduction or elimination of the authorized discharge; D. A determination that the permitted activity endangers human health or the environment and can only be regulated to acceptable levels by permit modification or termination; or E. Failure of the operator to comply with the provisions of ADEQ Regulation No. 9 (Fee Regulation). Failure to promptly remit all required fees shall be grounds for the Director to initiate action to terminate this permit under the provisions of 40 CFR 122.64 and 124.5(d), as adopted by reference in ADEQ Regulation No. 6, and the provisions of ADEQ Regulation No. 8.
20. Re-Opener Clause.
A. If there is evidence indicating potential or realized impacts on water quality due to any stormwater discharge associated with industrial activity covered by this permit, the operator of such discharge may be required to obtain an individual permit or an alternative general permit in accordance with Part I.B.22 of this permit, or the permit may be modified to include different limitations and/or requirements.
B. Permit modification or revocation will be conducted in accordance with the provisions of 40 CFR 122.62, 122.63, 122.64 and 124.5, as adopted by reference in ADEQ Regulation No. 6.
21. Local Requirements. All dischargers must comply with the lawful requirements of municipalities, counties, drainage districts, and other local agencies regarding any discharges of stormwater to storm drain systems or other water sources under their jurisdiction, including applicable requirements in municipal stormwater management programs developed to comply with the ADEQ permits. Dischargers must comply with local stormwater management requirements, policies, or guidelines including erosion and sediment control.
22. Applicable Federal, State Requirements. Permittees are responsible for compliance with all applicable terms and conditions of this permit. Receipt of this permit does not relieve any operator of the responsibility to comply with any other applicable federal, state or local statute, ordinance policy, or regulation.
APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22
PANAMERICAN REPORT NO. 33230
PANAMERICAN CONSULTANTS, INC.
CULTURAL RESOURCES SURVEY OF THE PROPOSED DRIVER SUBSTATION EASEMENT A, MISSISSIPPI COUNTY, ARKANSAS
PREPARED FOR: PREPARED BY: FTN ASSOCIATES, LTD. PANAMERICAN CONSULTANTS, INC. 3 INNWOOD CIRCLE, SUITE 200 91 TILLMAN STREET LITTLE ROCK, AKANSAS 72211 MEMPHIS, TENNESSEE 38111
DRAFT NEGATIVE FINDINGS REPORT APRIL 2014 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22
DRAFT NEGATIVE FINDINGS REPORT
CULTURAL RESOURCES SURVEY OF THE PROPOSED DRIVER SUBSTATION EASEMENT A, MISSISSIPPI COUNTY, ARKANSAS
Prepared for: FTN Associates, Ltd. 3 Innwood Circle, Suite 200 Little Rock, Arkansas 72211
Prepared by: Panamerican Consultants, Inc. 91 Tillman Street Memphis, Tennessee 38111 Panamerican Project No. 33340
C. Andrew Buchner, RPA Principal Investigator/Author
APRIL 2014 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22
ABSTRACT
At the request of FTN Associates, Ltd., Panamerican Consultants, Inc. performed a Phase I cultural resources survey of the 3.09-ac. Easement A tract in Mississippi County, Arkansas that is slated for development as a part of Entergy’s Driver Substation project. Easement A is a triangular-shaped 3.09-ac. tract located along and northwest of Arkansas Highway 198 across from the proposed Driver Substation and Easements B and C, which have been previously surveyed for cultural resources. Easement A is associated with a broad level flat composed of Sharkey silty clay soil, and therefore was considered a low-probability setting. A review of the Arkansas Archeology Survey and Arkansas Historic Preservation Program files revealed that there are no previously recorded archaeological sites or historic properties located within Easement A. The tract exhibited good to excellent surface visibility, thus it was surveyed via a pedestrian walkover, supplemented by the excavation of four judiciously placed shovel tests. The survey resulted in negative findings, no archaeological deposits or historic features were encountered within the 3.09-ac. Easement A tract.
As there are no National Register of Historic Places listed, eligible, or potentially significant cultural resources within Easement A, nor within the proposed Driver Substation or Easements B and C, no further archaeological work is recommended prior to releasing these areas for construction.
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ACKNOWLEDGEMENTS
Panamerican Consultants, Inc. appreciates the opportunity to have provided FTN Associates, Ltd. with these archaeological services. Tom Fox was our point of contact.
Panamerican Consultants, Inc. personnel who contributed to the project include the following. Ben Abney served as the Archaeological Technician. Kate Gilow provided administrative support during all phases of the project. Anna Hinnenkamp-Faulk edited the report.
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TABLE OF CONTENTS
ABSTRACT...... i
ACKNOWLEDGEMENTS ...... ii
LIST OF FIGURES...... v
LIST OF TABLES...... v
I. INTRODUCTION...... 1 PROJECT LOCATION ...... 1 OUTLINE OF THE REPORT...... 1
II. ENVIRONMENTAL SETTING ...... 5 PHYSIOGRAPHY ...... 5 GEOMORPHOLOGY...... 5 SOILS ...... 7 NEW MADRID SEISMIC ZONE...... 7 FLORAL COMMUNITIES...... 8 FAUNAL RESOURCES ...... 9 CLIMATE...... 9 PALEOENVIRONMENT ...... 10 LITHIC RESOURCES...... 10
III. CULTURAL BACKGROUND...... 13 HISTORY OF INVESTIGATIONS...... 13 Antiquarian Investigations ...... 13 Early Twentieth Century ...... 14 Lower Mississippi Survey...... 14 1947–1967...... 14 Arkansas Archeological Survey ...... 15 Cultural Resource Management Era ...... 15 CULTURE HISTORY ...... 15 Paleoindian ...... 17 Dalton...... 17 Archaic ...... 18 Poverty Point...... 19 Woodland ...... 19 Mississippian...... 21 Protohistoric ...... 23 Historic Aboriginal ...... 23 Colonial Period...... 24 Early Nineteenth Century...... 24 Civil War and Reconstruction...... 29 Land Reclamation Efforts ...... 30 Tenant Period...... 31 Railroad Period...... 34 The Great Floods of 1927 and 1937 ...... 36 World War II ...... 37 Modern Era ...... 37
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IV. LITERATURE AND RECORDS SEARCH...... 39 SANS SOUCI HISTORY...... 39 ARCHAEOLOGICAL INVESTIGATIONS AT SAN SOUCI ...... 47 Tyronza Phase II Watershed Survey ...... 48 Plum Point Energy Survey ...... 48 Project Blue Water Survey ...... 49 Great River Super Site Survey...... 49 Luxor and Osceola Relief Wells Survey ...... 49 Great River Super Site Testing...... 49 3MS753 Site Testing...... 50 ARKANSAS ARCHEOLOGICAL SURVEY SITE FILES ...... 51 ARKANSAS HISTORIC PRESERVATION PROGRAM STRUCTURE FILES...... 52 NATIONAL REGISTER OF HISTORIC PLACES LISTINGS ...... 52 NATIONAL ARCHAEOLOGICAL DATABASE ...... 52
V. FIELD INVESTIGATIONS ...... 53 METHODS ...... 53 Shovel Test Definition ...... 53 Site Definition...... 53 Survey Documentation ...... 53 FINDINGS ...... 54 DISCUSSION ...... 54
VI. SUMMARY AND RECOMMEDATION ...... 57 SUMMARY...... 57 RECOMMENDATION ...... 57
VII. REFERENCES CITED...... 59
APPENDIX A: BIOGRAPHIES
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LIST OF FIGURES
Figure 1-01. Quad map locator for the Driver Substation Easement A...... 2 Figure 1-02. Engineering plat of the proposed Driver Substation...... 3 Figure 2-01. Geomorphic map with the project area location added...... 6 Figure 3-01. The Sherman Mound as illustrated in Thomas ...... 13 Figure 3-02. A portion of T.J. Porter’s 1839 “Homo-Graphic Chart of the Settlements on the Mississippi River”...26 Figure 3-03. The 1845 GLO plat map for T13N R11E showing settlements and fields between Osceola and Luxora ...... 27 Figure 4-01. Photo of the ca. 1855 McGavock big house at Sans Souci...... 41 Figure 4-02. A portion of the 1914 soil map showing Sans Souci in Section 17 and the proposed Easement A area indicated by arrow...... 45 Figure 4-03. A portion of the 1939 Osceola, Ark.-Tenn. 15-min quad. with the proposed Easement A area indicated by arrow...... 46 Figure 4-04. A portion of the 1965 Osceola, Ark.-Tenn. 15-min quad with the proposed Easement A area indicated by arrow...... 47 Figure 5-01. Photo of Easement A...... 55 Figure 5-02. Photo of Easement A...... 55 Figure 5-03. The southern end of Easement A ...... 56 Figure 5-04. Photo of Easement A...... 56
LIST OF TABLES
Table 3-01. Northeast Arkansas Archaeological Sequence...... 16 Table 3-02. Antebellum population Statistics for Mississippi County, Arkansas...... 25 Table 3-03. Settlements mapped on 1837–1845 GLO plats in the Osceola-Luxora vicinity...... 27 Table 3-04. Mississippi County slave ownership data for 1860...... 28 Table 3-05. Tenant period population statistics for Mississippi County, Arkansas ...... 31 Table 3-06. Tenant period components located near the levee between Middle Nodena and Luxora...... 32 Table 4-01. Previously recorded archaeological sites within 2 km of the study area...... 51 Table 5-01. Shovel test inventory...... 54
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I. INTRODUCTION
At the request of FTN Associates, Ltd. (FTN) Panamerican Consultants, Inc. (Panamerican) performed a Phase I cultural resources survey of the 3.09-ac. Easement A tract in Mississippi County, Arkansas that is slated for development as a part of Entergy’s Driver Substation project. The purpose of this study was to identify all known and unrecorded cultural resources present within the tract, and to provide appropriate management recommendations for any such properties identified.
The project was conducted to assist FTN and Entergy in complying with Federal statutes including Section 106 of the National Historic Preservation Act of 1966, as amended; Executive Order 11593, and the Advisory Council’s “Protection of Historic Sites (36 CFR Part 800)”, effective 17 June 1999, and Arkansas State Historic Preservation Officer (SHPO) guidelines. All field and office work was conducted in accordance with the Standards and Guidelines established in 36 CFR Part 66, Recovery of Scientific, Prehistoric, Historic, and Archaeological Data: Methods, Standards and Reporting Requirements (Federal Register, Volume 42, Number 19-Friday, 18 January 1977), and Appendix B of the Arkansas State Plan: Guidelines for Archeological Fieldwork and Report Writing in Arkansas (Revised Version in effect as of 1 January 2010).
PROJECT LOCATION The proposed Driver Substation and its associated easements (A, B, and C) are planned along and near Arkansas Highway 198 (HY-198), to the northeast of the community of Driver and southwest of the City of Osceola (Figure 1-01). The Driver Substation, Easement B, and Easement C are located southeast of HY-198 (Figure 1-02). These tracts have been previously surveyed for cultural resources (Saatkamp 2007) and, as a result, were excluded from this cultural resources survey.
Easement A is a triangular-shaped 3.09-ac. tract located along and northwest of HY-198 across from the proposed Driver Substation (see Figures 1-01 and 1-02). This tract is bounded by a high voltage powerline to the west, HY-198 to the east, and by an arbitrary survey line to the north. Easement A is part of a larger, active agricultural field. The terrain at Easement A is level, and the elevation is between 250 and 255 ft. Easement A is located near the center of Section 24, Township 12 North Range 10 East (T12N R10E), and can be identified on the Osceola, AR-TN 7.5-min quad.
OUTLINE OF THE REPORT The technical report that follows is organized in the following manner (see also Table of Contents). The most salient aspects of the local environmental setting area are outlined in Chapter II. The local culture history is reviewed in Chapter III. The results of the literature and records search are presented in Chapter IV. The survey’s field methods and results are presented in Chapter V. Chapter VI provides a summary and conclusions. The report concludes with a references cited section and an appendix of biographies of key personnel.
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Figure 1-01. Quad map locator for the Driver Substation Easement A (base map: Osceola, AR-TN 7.5-min. quad).
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Figure 1-02. Engineering plat of the proposed Driver Substation (map courtesy: FTN).
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II. ENVIRONMENTAL SETTING
PHYSIOGRAPHY Mississippi County, Arkansas is located in the northern portion of the Lower Mississippi Valley, defined by Saucier (1994:I:22) as “the greater Quaternary valley and deposits of the Mississippi River and its principal tributaries within the limits of the Coastal Plain.” The town of Cairo, Illinois lies at the confluence of the Ohio and Mississippi rivers and is commonly regarded as the northern limit of the Lower Mississippi Valley. The Lower Mississippi Valley is subdivided into six major lowlands, or basins, and Mississippi County falls within the St. Francis Basin (Fenneman 1938). However, as Saucier (1994:I:24) cautioned, significant portions of these basins “actually consist of the [Mississippi River] meander belt ridge itself.”
Archaeologists consider the St. Francis Basin part of the “Central Mississippi Valley,” which is essentially the region between the mouths of the Ohio and Arkansas rivers (McNutt 1996; Morse and Morse 1983:1). The St. Francis Basin is referred to as the eastern lowlands, while the White-L’Anguille River Basin, located to the west of Crowley’s Ridge, is considered the western lowlands. The topography of the St. Francis Basin is typical of bottomlands along a major perennial stream, ranging from broad flats to alternating areas of swales and low ridges. Except along a few stream banks, local differences in elevation are minor. The nearest significant upland to Osceola is a section of loess bluffs, known as “Chickasaw Bluff No. 1,” which is located opposite Craighead Point in Lauderdale County, Tennessee.
Within the St. Francis Basin, the project area is located within the Mississippi River meander belt, which forms the eastern edge of the basin. Woods et al. (2004) classify this area as a Level IV eco-region within the larger Mississippi Alluvial Valley (a Level III region), and refer to it as the “Northern Holocene Meander Belts” (unit 73a). The Northern Holocene Meander Belts cover 2,430 mi.2 in Arkansas. The topography is characterized as “Broad, flat to nearly flat floodplain containing the meander belts of the present and past courses of the Mississippi River. Point bars, natural levees, flood control levees, swales, meander scars, oxbow lakes, drainage ditches, and meander low gradient rivers and bayous occur” (Woods et al. 2004).
GEOMORPHOLOGY Meander belt systems are dynamic and contain a variety of landforms as a result of shifting channel morphology including natural levees, crevasse splays, distributaries, point bars, and abandoned channels (Saucier 1994:I:98-120, 187-200). Examination of Saucier’s (1994:II: Plate 6) geomorphic map reveals that the proposed Driver Substation and its easements are located on point bar (meander scroll) deposits of the Mississippi River (Figure 2-01). This meander belt (Hpm 1) is the youngest and most recent Holocene meander belt of the Mississippi River. It dates from ca. 3,000 years before present (YBP) to the present (Saucier 1994:255).
Point bars consist of “relatively coarse-grained deposits (mostly silts and sands) that are lain down during higher stream stages…along the convex side of a migrating stream bend” (Saucier 1994:I:109). Ridge and swale topography is characteristic of point bar environments, and these locations frequently contain evidence of human occupation.
Saucier remarks that while the “natural levee environment may be the single most important one in the Lower Mississippi Valley area from several considerations … the abandoned channel environment ranks a close second” (Saucier 1994:I:112). Abandoned channels result from neck or chute cutoffs. When the narrow part of a point bar is breached, then the river flows past the former portions of its channel, resulting in a drop in flow for those channels, and this is called a neck cutoff. A chute cutoff occurs when a flood causes the river to over and scour a swale,
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Figure 2-01. Geomorphic map with the project area location added (after Saucier 1994:II:Plate 6).
There are several abandoned channels of the Mississippi River (Hchm) located in and near the project vicinity, including one located east of the Driver Substation (see Figure 2-01).
The area to the west of the modern Mississippi meander belt in the study vicinity is characterized by Late Wisconsin Stage valley train Level 1 (Pvl 1) deposits and Holocene point bar deposits of minor streams (Hps). Late Wisconsin Stage valley train Level 1, the lowest valley train level, was deposited after the Mississippi River broke through the Bell City-Oran Gap (Saucier
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1994:I:247). Unlike the Late Wisconsin Stage valley train Level 2 (Pvl 2) surface to the west, the Level 1 terrace “contains no Dalton-culture site whatsoever” (Saucier 1994:I:247).
SOILS The Driver Substation is associated with a broad expanse of deep, rich, alluvial soils that are highly productive. This area was formerly known as San Souci Plantation, and portions of it have been under cultivation since the Antebellum period.
At the county level, the Driver Substation occurs within the Convent-Morganfield-Crevasse soil association (Ferguson and Gray 1971:General Soil Map). The Convent-Morganfield-Crevasse association is described as “somewhat poorly drained to well-drained soils that are loamy throughout and excessively drained soils that are sandy throughout” (Ferguson and Gray 1971:General Soil Map). These soils make up about 18 percent of Mississippi County and occur mainly on natural levees along the Mississippi River and its former channels. The specific soil type represented at each of the tested sites is discussed below.
The Driver Substation Easement A is mapped as occurring on Sharkey silty clay (Ferguson and Gray 1971:Sheet 57). Sharkey series soils developed in thick beds of clayey sediment and associated with broad flats (Ferguson and Gray 1971:17). Sharkey silty clay is a poorly drained soil with a very dark grayish-brown or dark grayish-brown silty clay surface layer 10–20-cm thick. This soil has a high “shrink-swell” capacity, and as a result it cracks as it dries. Sharkey silty clay is a Capability Unit IIIw-1, or if frequently flooded it is a capability unit Vw-1 soil.
Because soils are indicators of past environments, soil types can be used to predict a given tract’s potential for containing archaeological deposits. The Soil Conservation Service’s “Capability Unit” classification is a measure of the limitations of each soil type that can restrict its use. These capability units are used by archeologists as indicators of the potential that a given soil type has for containing an archaeological deposit, because soils with few limitations are more likely to yield evidence of human occupation than soils with moderate or severe limitations. From an archaeological standpoint Capability Unit (or Class) are evaluated as followed:
§ Capability Unit I soils have few limitations that restrict their use, and are considered to have a high probability of containing archaeological resources. § Capability Unit II soils have moderate limitations, and are considered to have a moderate probability of containing archaeological resources. § Capability Unit III and IV soils have severe limitations, and are considered to have a low probability of containing archaeological resources. § Capability Unit VII soils have very severe limitations, and are considered to have little probability of containing archaeological resources.
Because Easement A is associated with either a Capability Unit III or V soil types, using soil type as a predictive model, the tract has low to little probability of containing archaeological resources.
NEW MADRID SEISMIC ZONE The project area is located in the New Madrid Seismic Zone (Saucier 1994:I:Figure 52). Four major fault lines (Reelfoot, Ridgely, Cottonwood Grove, and Crittenden County) and one major lineament (Bootheel) comprise this seismic zone. The fault lines and lineaments in this seismic zone are generally oriented northeast-southwest, except for the Reelfoot fault line, which is perpendicular to the others (Saucier 1994:I:Figure 55). Major earthquake events are documented on this fault at 8,100 YBP, 4,000 YBP, and 200 YBP (Guccione and Van Arsdale 1995).
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The New Madrid earthquake devastated the region in the early nineteenth century (see Fuller 1912 for eyewitness accounts). Between 16 December 1811 and 7 February 1812, four magnitude 7+ seismic episodes shook the area. Earthquake features were noted by early archaeologists working along the St. Francis River near the Big Slough Ditch study area (Thomas 1985 [1894]), and are widespread across the region. Smaller magnitude quakes continue to occur in the New Madrid Seismic Zone.
Geomorphologists and archaeologists have initiated multi-disciplinary research to estimate the interval periods between major episodes associated with the seismic zone. Archaeological evidence from Towosahgy State Archaeological Park led Saucier (1991) to suggest a recurrence interval of 468 years. Lafferty et al. (1997) have studied earthquake destruction at Woodland and Mississippian sites in the New Madrid Seismic Zone and proposed that magnitude 7–8 earthquakes occurred every 200–600 years.
FLORAL COMMUNITIES The St. Francis Basin was covered by dense virgin forests in the nineteenth century when U.S. settlers began clearing to open the territory for agriculture. General Land Office (GLO) plat maps and field notes document the early to mid-nineteenth-century conditions by Township and Section. The first significant timber cutting took place in tracts along the Mississippi River where antebellum plantations were established. The most extensive drainage projects and timber booms took place after the Civil War and into the 1950s. Today most of the St. Francis Basin is farmland, as a result the natural flora have been replaced by domesticated plants, especially cotton, soybeans, and rice.
Braun (1950) places the forests of the Mississippi Alluvial Plain within the Southeastern Evergreen Forest Region. The vegetation of this region is described as “warm temperate- subtropical” and is composed of a “variety of different forest communities” that are directly related to “diverse environmental conditions” (Braun 1950:282). The swamps of the St. Francis Basin are considered alluvial or bottomland forest, and are subdivided into three ecozones: swamp forests (also known as deep swamps, true swamps, or sloughs); hardwood bottoms (or glade bottoms); and ridge bottoms (or cane ridges; Braun 1950:291). In Lewis’ (1974) ecological approach, floodplain environments are classified into ten biotic communities.
The swamp forest ecozone is found in locations were water stands year-round, save for a few droughty periods. The principal trees are bald cypress (Taxodium distichum) and water tupelo (Nyssa aquatica). Other species such as silver maple (Acer saccharinum), red maple (Acer rubrum), and water and pumpkin ash (Fraxinus caroliniana, F. tometosa) may also occur (Braun 1950:292). In some places stands of water elm (Planera aquatica) may form dense thickets. Braun’s (1950) swamp forest ecozone is roughly synonymous with Lewis’ (1974:25-26) Cypress Deep Swamp.
The hardwood bottoms ecozone is found on land that is subject to frequent overflow. Typically this ecozone is flooded in late winter and spring, and dry during the fall. In the study vicinity hardwood bottoms were historically fairly extensive and probably covered much of the area, in particular the areas that exhibit Class II and Class III soils. Hardwood bottoms are composed of a mosaic of species, including water oak (Quercus nigra), sweetgum (Liquidambar styraciflua), red maple (Acer rubrum), swamp chestnut oak (Q. michauxii), overcup oak (Q. lyrata), willow oak (Q. phellos), elm (Ulmus sp.), sassafras (Sassafras albidum), hackberry (Celtics occidentalis), pawpaw (Asimina triloba), and dogwood (Cornus florida). These forests are usually dense, the trees are generally large, and the undergrowth is luxuriant.
The ridge bottoms ecozone is found on low rises that are elevated a few meters above the floodplain. Because the water drains off these areas, they support larger numbers of oaks and
8 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: DocketEnvironmental 13-039-u-Doc. 22 Setting hickories than the hardwood bottoms ecozone. Braun (1950:295) remarks, “Here are found some of the finest bottomland forests.” Sweetgum is the predominant tree, but oaks (including white oak [Q. alba]), shagbark hickory (Carya ovata), and pecan (C. illinoensis) are present in significant numbers. Most of the species of the adjacent, wetter hardwood bottoms are also found. In the highest, and thus better-drained areas, beech (Fagus grandifolia) and magnolia (Magnolia grandiflora) can occur.
Some of the ridges in this ecozone were covered in dense stands of giant cane (Arundinaria gigantea), an important resource for prehistoric and historic Native Americans. Braun’s (1950) ridge bottoms ecozone is roughly synonymous with the sweetgum-elm “Cane Ridge” forest of Lewis (1974:21-24). Cane ridges are noted on some GLO plat maps.
FAUNAL RESOURCES Faunal resources available to the prehistoric and early historic inhabitants of the project area would have varied considerably due to the local environment being subject to annual overflow. Faunal communities would have been quite varied during dry periods (Lewis 1974:23). Large mammals including black bear (Ursus americanus), mountain lion (Felis concolor), wolf (Canis lupus), and white-tailed deer (Odocoileus virginianus), were at one time commonplace in the area according to historic accounts. Smaller mammals including raccoon (Procyon lotor), muskrat (Ondatra zibethicus), otter (Lutra canadensis), mink (Mustela vison), gray fox (Urocyon cineroargenteus), red fox (Vulpes vulpes), eastern fox squirrel (Sciurus niger), gray squirrel (Sciurus carolinensis), opossum (Didelphis marsupialis), eastern cottontail rabbit (Sylvilagus foridanus), and striped skunk (Mephitis mephitis) were also present. Avian fauna included large species such as wild turkey (Meleagris gallopavo), ruffled grouse (Bonasa umbellus), and prairie chicken (Tympanuchus cupido) and smaller species such as the passenger pigeon (Ectopistes migratorius; Lewis 1974:23).
Faunal communities in the swamps bordering the local lakes and sloughs are not as varied as those found in the ridge forest, primarily due to a lower-density undergrowth and seasonal inundation. Large mammals, including white-tailed deer and black bear, might likely have occupied this forest type regardless of inundation. Smaller mammals, such as eastern cottontail and swamp rabbits (S. palustris), would have been restricted to dry periods only in their occupation of this forest type. Avian fauna listed as common in the ridge forest would have been restricted to drier periods in seasonal swamps, but migratory waterfowl such as ducks (Anas spp.) and Canada geese (Branta candensis) would have been abundant during the flood season. Along the margins of swamps, small mammals such as beaver (Casor canadensis) and muskrat (Ondatra zibethicus) would have occupied permanent lakes, bayous, and swamps (Lewis 1974:23).
The cypress lakes, bayous, and seasonal swamps would have supported a very high seasonal biomass of fishes (Limp and Reidhead 1979; Peterson et al. 1981), as well as reptiles and mollusks. Fish species that may have been exploited for food include gar (Lepisosteus), freshwater drum (Aplodinotus gruniens), bass/sunfish spp. (Perciformes), catfish (Ictaluridae spp.), crappie (Pomoxis sp.), and buffalofish (Ictiobus cf. Bubalus). Among the reptiles, soft- shelled turtle (Trionyx spinifer) and pond/river turtle (Aquatic Emydidae) were probably favored game species. Various types of mollusks such as spike (Elliptio dilatata), ebony shell (Fusconaia ebena), pocketbook (Lampsilis spp.), and wedge rangia (Rangia cuneata) were available from local aquatic environments as well.
CLIMATE The current climate of Arkansas is classified as humid subtropical. The Mississippi County climate is typical for the Mississippi River Valley, with hot summers, mild winters, and abundant
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The average yearly high temperature for Mississippi County is a mild 72°F, with an average yearly minimum of 50° F. Average daily maximum temperatures range from 92°F during July to 49°F during January. Average daily minimum temperatures range from 70°F in July to 31°F in January (Ferguson and Gray 1971:Table 10). The growing season in Mississippi County is long, averaging 220 days. Freezing temperatures usually occur in early to mid-November and continue until mid-March (Ferguson and Gray 1971:54).
Precipitation in Mississippi County averages ≈48 in. per annum. The wettest month is January, when an average of 5.45 in. of precipitation falls (Ferguson and Gray 1971:Table 10). Frontal systems associated with areas of low pressure provide the area with the majority of its rainfall. During summer months, convection clouds caused by high temperatures and humidity levels provide rainfall frequently during the afternoon hours. Periods of drought are infrequent, and these are seldom severe. Frozen precipitation is minimal, rarely resulting in the accumulation of more than 5 in. (Ferguson and Gray 1971:54).
PALEOENVIRONMENT Paleoenvironmental conditions were substantially different in the late Pleistocene through the middle Holocene. Important regional sites with Quaternary plant fossil records include the Pemiscot Bayou and Big Lake corings in Mississippi County (Scott and Aasen 1987); the Hood Lake coring in Pointsett County (Delcourt and Delcourt 1989); the Old Field site in Stoddard County, Missouri (King and Allen 1977); and the Nonconnah Creek Mastodon site in Shelby County, Tennessee (Delcourt et al. 1980). Delcourt, Delcourt, and Saucier (1997) synthesized data and mapped vegetation reconstructions for the Central Mississippi Valley for various temporal intervals.
Post-glacial warming began about 10,500 B.C., and a cool-temperate spruce-fir-larch forest gave way to a warm-temperate mixed oak deciduous forest (Morse and Morse 1983:8). By 7,000 B.C. the mixed oak deciduous forest was firmly established in the Central Mississippi Valley, and the Mississippi River had diverted through Thebes Gap and changed from braided to meandering. The period from ca. 7000–3000 B.C. (or possibly 8000–4000 B.C.; see Morse and Morse 1983) was warm and dry and is referred to as the Hypsithermal. Modern floristic regions developed after 3000 B.C. with the return of wetter conditions.
LITHIC RESOURCES Within Mississippi County, lithic deposits can best be described as sparse, due to the alluvial origin of the surface. However, regional archaeological assemblages do exhibit a wide range in the number and variety of lithic resources. These resources and their possible sources are reviewed below.
The Citronelle gravel beds associated with Crowley’s Ridge and the Chickasaw Bluffs offered the closest and most readily available source of lithic resources for the inhabitants of prehistoric Northeast Arkansas. Known prior to 1955 as Lafayette chert (Stallings 1989), these gravels likely originated in the mid-continent Paleozoic craton and Appalachian Mountains region prior to being redeposited via erosion during the late Pliocene or early Pleistocene (Guccione et al. 1990:29). Aboriginal use of this lithic material for tool production is well documented in the eastern Arkansas archaeological literature (House 1975:81-84; Morse and Million 1980:15-26).
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A cluster of prehistoric extractive (quarry) sites was documented in the Whaley Slough valley on the western escarpment of Crowley’s Ridge near Bono during the Cache River archeological project (House 1975). This led House (1975:82) to suggest that similar quarry/extractive sites— which are clustered in areas where the Citronelle gravels outcrop—are “probably present along the whole length of Crowley’s Ridge.” Today, Citronelle gravel is used for road surfaces.
Other cryptocrystalline resources that were utilized by the prehistoric population of Northeast Arkansas include, but are not limited to, the following. Burlington chert, which outcrops extensively in the Mississippian limestones of Missouri and Illinois, was favored for tool production during the late Prehistoric period (Morse and Million 1980:15-23). Novaculite, which occurs within the Ouachita Mountains (Haley 1976; Hoffman 1977; Levin 1978), was utilized widely both geographically and temporally (Brockington et al. 1992:79; Morse and Million 1980).
Mill Creek, Cobden, and Kaolin cherts, all available from southern Illinois, were also used to varying extents by prehistoric peoples in northeastern Arkansas. Mill Creek chert occurs in larger cobbles and was preferred for the manufacture of larger tools such as hoes (Cobb 1989), spades, etc. (Lafferty and Hess 1996:19). The manufacture and widespread exchange of large hoe forms exploded in the Early Mississippian period (Cobb 1989:84). A cache of 108 Mill Creek hoes is reported from a Middle Mississippian site near Big Lake (Morse and Morse 1983:255). Morse and Morse (1983:255) note that the presence of large concentrations of hoe chips is a characteristic of middle-late period archaeological sites in northeastern Arkansas. No evidence of the manufacture of such hoes has been found in the region, suggesting that they entered the area as finished trade goods.
Sandstone is another lithic resource available from Crowley’s Ridge tertiary deposits. The abundance of this resource may account for the heavy use of it by aboriginal peoples of the eastern lowlands (Brockington et al. 1992:7.9). Sandstone was utilized by the aboriginal inhabitants of the eastern lowlands primarily to make processing tools, including abraders, mortars, and anvils.
Orthoquartzite is also available along Crowley’s Ridge, especially along its northern extremity (Morse and Million 1980:15-22). Presumably, orthoquartzite was gathered and used in a similar manner as sandstone.
Hematite, a highly variable mineral, can be gathered within eroded areas along the margins of Crowley’s Ridge (Morse and Million 1980:15). This mineral can occur in a grayish black hard form, or a dark red soft form resembling compressed soil. The latter form is known as red ochre and is the most common form of hematite associated with prehistoric cultural manifestations (Vanders and Kerr 1967).
Igneous rock, used principally for axes, mauls, and other heavy tools, was available from two major sources. The Ste. François Mountains in southern-central Missouri readily yield a variety of igneous materials, including rhyolite and coarse-grained granites (Hayworth 1975[1888]:21). Rhyolite was used to manufacture small cutting tools (Childress 1990), while coarse-grained granites were used to manufacture heavy cutting tools (Morse and Morse 1983:5). The presence of abundant primary basalt debitage on Late Mississippian sites near Blytheville has led to the suggestion that Ste. François basalt was monopolized by Nodena phase occupations (Morse and Morse 1983:274). The Ouachita Mountains are also rich in igneous materials, which were traded by aboriginal inhabitants over a large area of the Southeast (Rolingson and Howard 1997). However, the extra-local use of central Arkansas materials dropped to near zero during the late Prehistoric period (Rolingson and Howard 1997:46-47).
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The Ozark uplift contains a variety of cryptocrystalline and other stones that were utilized by aboriginal peoples for tools. The light-colored Burlington occurs in extensive Mississippian limestones in Arkansas and Missouri. Primary outcrops occur along the White River near Batesville, and this material was traded widely. A number of other lithic sources would have been available via trade networks or overland foraging expeditions.
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III. CULTURAL BACKGROUND
The following chapter provides cultural background information relevant to the Driver Substation locality. A briefing on the historic development of archaeological research in Northeast Arkansas is presented first. An attempt is made to incorporate recent Cultural Resources Management (CRM) projects into this overview. Next, a culture history is presented in a stage-by-stage format.
HISTORY OF INVESTIGATIONS
ANTIQUARIAN INVESTIGATIONS Archaeological investigations in the Central Mississippi Valley were initially conducted by self- trained, interested individuals and focused on monumental earthworks. The earliest published scholars, such as Caleb Atwater (1820) and Squier and Davis (1848), attributed the earthworks to a non-aboriginal group, the mythic “Mound Builders.” H.R. Schoolcraft (1854) was one of the few contemporary scholars who advocated that the mounds were actually Native American constructions.
After the Civil War, antiquarian researchers radiated across the Southeast in a quest for museum specimens and during the late nineteenth century, some of the most intensive investigations took place in Northeast Arkansas. Professor Putnam (1875a, 1875b) of the Peabody Museum, was active in the collection of museum specimens and recording of mounds in the Lower St. Francis Basin of Arkansas and New Madrid County, Missouri.
In 1879, Congress created the Bureau of Ethnology within the Smithsonian Institution and a branch known as the Division of Mound Exploration was established in 1881 specifically to determine “the origins of the mounds” (Thomas 1985 [1894]:21). In Cyrus Thomas’s (1985 [1894]) classic Mound Explorations, in which the Mound Builder myth is destroyed, mound groups and pottery specimens from Northeast Arkansas are described, including three sites in Mississippi County: Pecan Point; the Jackson (or Wildy) Mounds; and the Sherman Mound (Thomas (1985[1894]:219-223). The Sherman Mound (3MS16) is referred to by locals as the “Indian Signal Mound” (Edrington 1962b:27). Thomas (1985[1894]:223) described the Sherman Mound as exhibiting a “peculiar form” with three terraces (Figure 3-01), and the excavations in the upper terrace produced cane-impressed daub specimens that reveal it was a sub-platform for a structure.
Figure 3-01. The Sherman Mound as illustrated in Thomas (1985[1894]:Fig. 132).
Thomas (1985 [1894]:Figure 130, 131) illustrated various ceramics from Northeast Arkansas including a head pot and a painted bottle from Mississippi County. W.H. Holmes (1884, 1886, 1903) provides the best descriptive analysis of the numerous ceramics recovered by Thomas’s field crews. The Arkansas data in the 1894 Thomas volume are based on the 1881–1886
13 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 fieldwork of a number of individuals (B. Smith 1985:Table 2), principally Edward Palmer. Details of the 1881–1884 work of Palmer, including formerly unpublished diaries, notes, reports, and illustrations (by a former slave, Henry Lewis), have been compiled and published (Jeter 1990).
With the origin of the mounds now both demonstrated and generally recognized to be Native Americans, the predominate archaeological research issue of the late nineteenth and early twentieth centuries shifted to determining the antiquity of the human occupation of America (cf. O’Brien 1996).
EARLY TWENTIETH CENTURY In the early twentieth century, the pace of archaeological work in the Central Mississippi Valley accelerated. Clarence B. Moore (1908, 1910, 1911, 1916) spent several field seasons in Arkansas excavating large sites in the region along the Mississippi, St. Francis, White, and Black rivers. During his expeditions, Moore (1911:447-476, 1918:574-575) excavated four sites in Mississippi County: Bell (3MS8); Notgrass (3MS15); Pecan Point (3MS78); and Stoffle (or Turnage [3MS17]).
During the period between 1910 and 1930 modern excavation techniques, such as use of a grid and the establishment of stratigraphic control, became popularized. The University of Arkansas Museum, conducted extensive excavations in Northeast Arkansas with a grant from the Carnegie Foundation. Samuel C. Dellinger, the museum curator, selected large St. Francis sites, such as Nodena, Hazel, Vernon Paul, and Togo, for excavation. Much of this work was never published, although a summary was presented in American Antiquity (Dellinger and Dickson 1940). Also in the 1930s, the University of Alabama conducted important excavations at the Nodena site (Morse 1989).
On a national level, the marriage of archaeology and anthropology was accomplished during the early twentieth century, and by 1935 seven universities offered Ph.D. programs in anthropology. Professional archaeological organizations began to form during this period and state societies, which had begun as early as the 1880s in some areas, multiplied. Intensive excavations funded by the Works Progress Administration (WPA) did not occur in Northeast Arkansas.
LOWER MISSISSIPPI SURVEY Beginning in 1939, the Lower Mississippi Survey (LMS), conducted by the Peabody Museum of Archaeology and Ethnology (PMAE at Harvard University), compiled survey data and conducted test excavations at many of the large sites in the region (Phillips et al. 1951). The LMS investigations are a watershed event in the archaeology of the region. S. Williams’ (1954) work at Crosno in Southeast Missouri and other Mississippian sites in the area is another of the LMS’s contributions. The ceramic typology and initial phase definitions for most of the ceramic period archaeological cultures of this region were made by the LMS (S. Williams 1954; Phillips 1970). The extensive LMS site files are now available online.
1947–1967 During this period various organizations and interested individuals conducted research in Northeast Arkansas and because of this, the University of Arkansas began to grow as a research facility. In the late 1950s, the Gilcrease Institute of American History and Art funded excavations at the Banks Site and the Cherry Valley Mound (Perino 1966, 1967), in order to provide perspective on some of their collections. Based on late the 1950s work, the avocational archaeologist John Moselage (1962) produced the Lawhorn Site report, which the Morses (1983:28) note is the first “complete descriptive” site report for Northeast Arkansas. In 1961 and 1962, Ford and Redfield performed a site survey of the Lower Mississippi Alluvial Valley that
14 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 focused on pre-ceramic sites (Redfield 1971). The Ford-Redfield survey was co-sponsored by the National Science Foundation and the American Museum of Natural History. James Ford excavated the Hopewell burial mounds at Helena Crossing for the American Museum of Natural History and obtained some of the first (and still oldest!) 14C dates in East Arkansas (Ford 1963). In 1960, the Arkansas Archeological Society was formed. The Society began publishing a Bulletin that continues today and began a summer dig program that has excavated some sites in Northeast Arkansas (Morse and Morse 1983:29).
On a national level, several significant advances were made as well during this period. Willey and Phillips (1958) published Method and Theory in American Archaeology that proposed a basic archaeological unit taxonomy that replaced the Midwestern Taxonomic System. However, historic archaeology is largely neglected in this work. After 1950, radiocarbon dating became established and available to researchers, and the true antiquity of the Archaic and Paleoindian stages became analytically established. The latter portion of this period falls in Willey and Sabloff’s (1974) “Explanatory Period,” which is characterized by processual analysis, systems theory, use of statistics, and is derived from the neo-evolutionary theory of Leslie White. None of the Smithsonian’s River Basin Survey (RBS) projects took place in the lowlands of Northeast Arkansas.
ARKANSAS ARCHEOLOGICAL SURVEY The Arkansas Archeological Survey (AAS) was created and funded by the state legislature in 1967 (Davis 1982). The campus of Arkansas State University at Jonesboro was selected as the survey station for Northeast Arkansas. Dr. Dan Morse served as the station archaeologist from 1967–1997. Defining the local Northeast Arkansas sequence was one of the first tasks accomplished (Morse 1969). Problem oriented research and salvage projects by the AAS- Northeast Arkansas Station have produced much of the data regarding the archaeology of this area. The station also serves as a regional repository for artifacts.
CULTURAL RESOURCE MANAGEMENT ERA The scope and intensity of archaeological investigations in Northeast Arkansas—and indeed across the Southeast—increased dramatically with the passage of the Moss-Bennett bill, or the Archaeological Conservation Act, by the U.S. Congress in 1974. Most federally mandated cultural resource management studies are a direct result of this legislation. A number of major CRM studies have taken place in Northeast Arkansas, as have numerous smaller studies. Major contracting agencies and companies in Northeast Arkansas include the U.S. Army Corps of Engineers (USACE), the National Park Service (NPS), the Soil Conservation Service, the Arkansas Highway and Transportation Department (AHTD), and Arkansas Power & Light Company.
CULTURE HISTORY The following is a summary of the prehistoric and historic cultural sequence of Northeast Arkansas. Each cultural stage is defined by characteristic artifact assemblages and patterns of subsistence and settlement. The prehistoric sequence in the southeastern United States is traditionally divided into four major stages: Paleoindian; Archaic; Woodland; and Mississippian. Synthesis for Northeast Arkansas and the related cultural manifestations of Southeast Missouri include the following (which were drawn upon in the preparation of this summary): Chapman (1975, 1980); McNutt (1996); Morse and Morse (1983, 1996); O’Brien (1994, 1996); Phillips (1970); and Lafferty and Price (1996). Table 3-01 summarizes the culture history.
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Table 3-01. Northeast Arkansas Archaeological Sequence†. Date Stage Phase or culture Modern A.D. 1950 ——————————— ————————————————— Historic Tenant A.D. 1874 ——————————— ————————————————— Historic Reconstruction A.D. 1865 ——————————— ————————————————— Historic Civil War A.D. 1861 ——————————— ————————————————— Historic Antebellum Statehood A.D. 1836 ——————————— ————————————————— Historic Territorial A.D. 1803 ——————————— ————————————————— Historic Aboriginal; Quapaw, Michigamea; Colonial French, Spanish A.D. 1650 ——————————— ————————————————— Protohistoric Armorel A.D. 1541 ——————————— Late Mississippian Nodena, Parkin, Kent, Walls A.D. 1400 ——————————— ————————————————— late Middle Mississippian Lawhorn A.D. 1200 ——————————— ————————————————— early Middle Mississippian Cherry Valley A.D. 1050 ——————————— ————————————————— Early Mississippian Big Lake, Hayti A.D. 700 ——————————— ————————————————— Baytown Dunklin, Baytown, Hoecake A.D. 400 ——————————— ————————————————— Late Marksville Cow Mound, Keller A.D. 200 ——————————— ————————————————— Early Marksville Helena, Turnage (?) A.D./B.C. ——————————— ————————————————— Tchula Pascola, Turkey Ridge (?) 500 B.C. ——————————— ————————————————— Poverty Point 1500 B.C. ——————————— ————————————————— Late Archaic Frierson 3000 B.C. ——————————— ————————————————— Middle Archaic 7000 B.C. ——————————— ————————————————— Early Archaic Cache River 8000 B.C. ——————————— ————————————————— Dalton L’Anguille 8500 B.C. ——————————— ————————————————— Paleoindian Sedgwick, Crowley’s Ridge 9300 B.C. † This table principally follows the Morse and Morse (1996:Figure 5-5) chronology.
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PALEOINDIAN Paleoindian occupations represent the first well-accepted occurrence of humans in the Western Hemisphere. Paleoindian populations are generally thought of as highly adaptive and mobile hunter-gatherers whose recent ancestors were Upper Paleolithic Siberians who migrated across the present Bering Strait during the Late Pleistocene, when sea levels were ca. 60 m lower.
During the Late Glacial era, when initial human colonization of the Southeast is postulated (ca. 12,000–10,000 YBP), climatic changes followed the receding of the continental ice sheets, and there was a widespread extinction of megafauna. The environment at this time is usually interpreted to have been characterized by a spruce and/or pine-dominated boreal forest (Saucier 1978:42). However, by 1,000 years prior to the fluted point occupations, the environment had changed to deciduous forest (Delcourt et al. 1980).
Recent research on Paleoindian diagnostics (Anderson et al. 1990) indicates that the period may be subdivided into early (ca. 9500–9000 B.C.), middle (ca. 9000–8500 B.C.), and late (ca. 8500– 8000 B.C.) stages based on changes in hafted biface morphology. No radiocarbon dates are available to confirm independently the accuracy of the subdivision. The early occurrence of classic Clovis points is followed by points that Morse and Morse (1983) identify as Coldwater and Sedgwick in Eastern Arkansas. Like most other regions of the Southeast, the Paleoindian diagnostics of the area tend to occur as isolated surface finds. In Northeast Arkansas, early and middle Paleoindian sites are centered on Pleistocene terraces and sand dune deposits along major river systems that were within 30 km of locally available chert sources (Gillam 1996).
Aboriginal groups of the period were likely small, mobile bands dependent upon a hunting-and- gathering economy. Although they may have hunted some of the megafauna that became extinct at the end of the Pleistocene, such as mastodon (Mammut americanum), bison (Bison bison antiquus), and ground sloth (Megalonyx sp.), it is likely that the subsistence base was varied and included a number of plant and animal foods. The nearest firm association of a fluted point with a mastodon remain is at the Kimmswick Site near St. Louis (Graham et al. 1981), although a possible association at Island No. 35 should be noted as well (S. Williams 1957).
DALTON The Dalton period is considered to be transitional between the Paleoindian and Archaic traditions. The key distinguishing feature of material culture is the unfluted, serrated Dalton point, but the Dalton tool kit includes a number of other diagnostic special-function tools and a woodworking adz (Morse and Morse 1983; Morse 1996). Goodyear (1982) suggests that Dalton represents a distinct temporal horizon, dating to 8500–7900 B.C. While technologically similar to Paleoindian, Dalton assemblages suggest an adaptive pattern that is more akin to later Archaic cultures. One of the most important game species from this time forward to the contact era seems to have been the white-tailed deer (Morse and Morse 1983:71). During the Dalton period the Mississippi River meander system was established in the Lower Valley and was working northward, but a braided stream regime still existed here in the St. Francis Basin.
Dalton components are much better represented in Northeast Arkansas than the preceding Early and Middle Paleoindian diagnostics. In the 1960s, the Ford-Redfield survey project identified a heavy concentration of Dalton components in Northeast Arkansas (Redfield 1971; Redfield and Moselage 1970). Important sites include Brand (Goodyear 1974), Sloan (Morse 1997), and Lace (Morse and Morse 1983), with Brand producing evidence for the oldest cemetery in the New World. Other features at Brand were interpreted as living floors and shelter remains. The distribution of sites and site types along the major drainages has also led to the formulation of competing settlement pattern models for band level societies (Morse 1975, 1977; Schiffer 1975; Price and Krakker 1975); see McNutt (1996:191-192) for commentary.
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To the north, in the Missouri Bootheel, the Dalton period is characterized by Plano-like lanceolate projectile points (Chapman 1975:125), indicating a continued affiliation with technologies of the Plains region. The Dalton Serrated point may have developed into broad lanceolate Early Archaic forms, such as Graham Cave Fluted, which date to 8000–7000 B.C. (Chapman 1975:126). Dalton lifeways are best known from more extensively investigated sites such as Graham Cave and Arnold Research Cave in Central Missouri, and Modoc Rockshelter in Illinois (Chapman 1975:94, 234-236).
ARCHAIC The Archaic is usually thought of in terms of three subperiods: Early (ca. 8000–7000 B.C.), Middle (7000–3000 B.C.), and Late (3000–1500 B.C.). Temporal divisions of the Archaic are primarily based on the occurrence of distinctive projectile points. Throughout Archaic times a hunter-gatherer lifeway appears to have continued, and it was focused on essentially the same flora and fauna as represented in the natural environment today. The Archaic is perceived of as a time of regional “settling in,” when an efficient utilization of the environment was keyed to highly cyclical, repetitive seasonal activities continued by indigenous groups over thousands of years (cf. Caldwell 1958). Some seasonal movement to exploit econiches was probably required, but Archaic populations, compared to Paleoindian, are generally portrayed as attached to localities, river valleys, or regions. In the Central Mississippi Valley, virtually no Archaic sites have been excavated, and indeed these components appear to have been overlooked by archaeologists more concerned with ceramic period adaptations (S. Williams 1991; McNutt 1996:194).
The Early Archaic period is best understood from rockshelter excavations, such as Modoc (Fowler 1959) and Graham Cave (Chapman 1975), rather than from open habitation sites. McNutt (1996:194) has commented, “we can see several projectile points coming into the Valley from the west and north, probably in conjunction with the prairie expansion and dry econiches during the Hypsithermal.” Point forms considered diagnostic for the Early Archaic include Hardin, Hidden Valley Stemmed, Rice Lanceolate, Hardaway-Dalton, San Patrice, St. Charles- Plevna, and a variety of named side notch types (Big Sandy, Graham Cave, Cache River, etc.). For Northeast Arkansas, Morse and Morse (1983) proposed a series of horizon markers that grade from classic Early Archaic Corner-Notched forms (ca. 7500–7000 B.C.) into Middle Archaic Basal Notched forms.
The Middle Archaic period was marked by a shift in subsistence modes. This was possibly due to environmental changes caused by a climatic episode called the Hypsithermal, which is dated 7000–3000 B.C. (McNutt 1996) or 8000–4000 B.C. (Morse and Morse 1983). This change resulted in restricted deciduous forest occurrence, limiting the availability of certain floral and faunal resources. The cultural impact of this warming trend appears to have been most strongly felt from 5500–3500 B.C. Several settlement models regarding human adaptation during the climatic optimum have been posited. Morse and Morse (1983) propose that the western lowlands of northeastern Arkansas were largely abandoned for the uplands (Ozark Plateau and its escarpment). However, in the lower Tennessee/Cumberland region, populations appear to have congregated at a limited number of floodplain locations and produced deep middens (Nance 1987). Higgins (1990) proposed that the drying of the uplands forced people into the floodplain (American Bottom).
The Late Archaic period begins with the end of the Hypsithermal climatic episode (ca. 3000 B.C.) and the establishment of the modern climatic regime. The Mississippi River was now a well- entrenched meander belt type stream, and adapting to this type of environment was critical for human occupation of the eastern lowlands. There is evidence for more sedentary lifeways, and possibly limited horticulture was being employed, as sunflower, squash, and other cultivated native starchy seed annuals appear in the archaeobotanical record at this time in the other areas
18 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 of the Southeast. Late Archaic settlement models typically have a seasonal round aspect, and there is evidence that the substantial “winter” villages, typically located on major streams, were actually occupied year round. Both earthen and shell mounds appear in the archaeological record in the Southeast at this time.
The Late Archaic is characterized by a substantial increase in the number of sites, cultural elaboration, and wide spread trade. The period opens with Benton culture, but Benton materials and sites are generally restricted to east of the Mississippi; rarely are Benton points found west of the Mississippi. Morse and Morse (1983:118) suggest Big Creek points (3000–2000 B.C.), which predate Burkett (2000–1000 B.C.) and Weems (1000–500 B.C.) points, are characteristic of pre- Poverty Point Late Archaic assemblages. Two regional Late Archaic phases have been defined: the Frierson phase based on information from the Frierson Site in the western lowlands (Morse 1982) and the O’Bryan Ridge phase in Southeast Missouri (S. Williams 1954). Farther north, the Titterington/Sedalia phase is characteristic of the Late Archaic period in the prairie regions of Missouri and Illinois (McNutt 1996:201).
POVERTY POINT Poverty Point, or Terminal Late Archaic, components are distinguished by the appearance of large mounds, earthworks, clay balls or “Poverty Point Objects,” microlithics, lapidary work, raw material trade, and specialized manufacturing sites. The Poverty Point period (1500– 500 B.C.) is considered one of three cultural “zeniths” in prehistoric Southeastern studies. In other portions of the Southeast, these components are referred to as Gulf Formational (Walthall 1990 [1980]), and include fiber-tempered ceramics as a diagnostic, but here in Northeast Arkansas, fiber-tempered ceramics have yet to be reported (Morse and Morse 1983:124).
Morse and Morse (1983:130) have noted a “pattern of sites located within the lowlands adjacent to the meander belt” and use the Cairo Lowlands as an example. Midden mounds and gathering camps appear in archaeological record at this time and reflect semi-sedentary populations (Morse and Morse 1983; McNutt 1996).
The clay balls are though to be a substitute for boiling stones and have considerable time depth, apparently extending into the early Middle Woodland and cannot be used as exclusively as Poverty Point component markers. A variety of stemmed projectile points are characteristic of the period, including Burkett-Etley-Gary forms, similar to Ledbetter-Pickwick-Mulberry Creek points, and the Weems-Wade-Dyroff-McIntire forms that lead into the Early Woodland.
WOODLAND During the Woodland period intensification in horticultural methods, construction of earthworks, elaboration of artistic expression, and burial rituals are all thought to be interrelated to the reorganization of social structure (Griffin 1967). For at least part of the year, a sedentary group was needed to plant, tend, and harvest crops. Sedentism and communal labor efforts promoted territorial circumscription. This period was also characterized by increased variety and use of ceramics. Ceramic types and varieties thus are a primary consideration in interpreting settlement patterns and chronological progression during the Woodland period. Considerable archaeological attention has been focused on these ceramic cultures and a number of phases and phase sequences have been proposed for east Arkansas and southeast Missouri.
Early Woodland components in the Central Mississippi Valley are referred to as Tchula and these are assumed to be roughly contemporary with Tchefuncte in the Lower Valley (Phillips et al. 1951). The grog/clay-tempered ceramics of Tchula components contrast with the sand- tempered wares of the Pascola phase components to the north. The best documented Tchula assemblage in Northeast Arkansas is from the McCarty site (3PO467), the type-site for the Early Woodland McCarty phase (Morse and Morse 1983; Morse 1986). Ceramics include Cormorant
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Cord Impressed, Mulberry Creek Cord Marked, Withers Fabric Impressed, Baytown Plain and Tchefuncte Stamped, which were associated with a reel shaped gorget, biconical baked clay objects, and heavy groundstone tools. The Burkett site in Southeast Missouri produced related ceramics (S. Williams 1954:28), but the extensive Middle Woodland occupation makes separation of the Early Woodland material difficult at Burkett. In general the Early Woodland is poorly defined in the eastern lowlands.
The Middle Woodland features elaborate burial ceremonialism and artistic expression, and represents the second major cultural “zenith” in the prehistoric Southeast. In the Ohio Valley the Middle Woodland period is referred to in terms of Hopewell, while in the Lower Mississippi Valley this period is characterized as Marksville. The Helena phase (Phillips 1970:887-889; Toth 1988) is thought to represent to represent the local emergence of Hopewellian-type culture in Northeast Arkansas. Excavations at the Helen Crossing Mounds (3PH11) revealed log tombs with burials and associated artifacts such as cut sheet mica, copper earspools, copper coated panpipes, blade flakes, and Marksville ceramics (Ford 1963). Calibrated radiocarbon date intercepts from four Helena Crossing 14C samples range from ca. 90 B.C.–A.D. 429. Mainfort (1988) has interpreted the mortuary pattern at Helena Crossing as evidence for only a moderately stratified society. The Helena Crossing site is, however, an anomaly, as there is a general scarcity of Hopewell/Marksville traits in east Arkansas. The Mound City Group near West Memphis may be an exception (Morse and Morse 1996:125). Habitation site assemblages consist predominately of Baytown Plain and Mulberry Creek Cord Marked, with lesser frequencies of Withers Fabric Marked and Cormorant Cord Impressed. Zone punctated and dentate stamped ceramics, definitive Hopewell markers, occur only in trace frequencies, if at all, especially in small assemblages. The Morses (1996:126) suggest that identified Middle Woodland components are rare as a result of the population being dispersed in hamlets and small villages, and “masking” by subsequent, more intensive occupations at major sites. The Keller site (3PO159) is the best-reported example of the “minimal residential habitation[s] that” are typical of the Late Marksville in Northeast Arkansas (Morse 1988:74).
The initial Middle Woodland occupations are followed by Dunklin (Barnes) and Baytown phases in the Central Mississippi Valley (Morse and Morse 1983). Terminal Middle Woodland/early Late Woodland occupations in Northeast Arkansas are identified by sand-tempered (Barnes or Kennett) ceramics of the Dunklin phase or clay/grog-tempered ceramics of the Baytown phase (see below). These ceramics have discrete (but slightly overlapping) spatial distributions, and are believed to be contemporary (Morse and Morse 1983:Figure 9.1). Morse and Morse (1983) interprets the distribution as reflective of different social groups, while others, including Phillips (1970) suggest environmental differences (i.e., sandy soils) may account for the paste variability.
The Late Woodland period is poorly understood throughout the Southeast. The elaborate ceremonialism, trade networks, and earthworks construction activities associated with Middle Woodland times become attenuated. There is a general paucity of lithic artifacts during the Late Woodland, which may be related to the introduction of the bow and arrow ca. 700 A.D. (see Blitz 1988), which may have reduced “the production of stone points to near zero” (Dunnell and Feathers 1991:26). The bow technology may have led to a dispersal of the regional populations.
In Northeast Arkansas, the dichotomy between sand- and clay/grog-tempered component distributions noted in the waning Middle Woodland becomes fully expressed during the Late Woodland, or the Late Baytown period. (Note: Baytown is a term that has a number of archaeological meanings, primarily: (1) a Late Woodland phase, ca. A.D. 400–700; (2) a ceramic tradition; and (3) a general reference to the Woodland stage). The proximity of these two dichotomous ceramic traditions is interpreted as representing “opposite extremes of the segmentary tribe” (Morse and Morse 1983:192). Baytown components (Phillips 1970) dominate the southern St. Francis Basin, while Dunklin phase components dominate to the northern (Morse and Morse 1983:Figure 9.1). Baytown (and Hoecake, see S. Williams 1954) groups
20 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 appear to have been organized into larger, more socially complex settlements than Dunklin phase groups. Excavations at the Brougham Lake site (Klinger et al. 1983) revealed that Late Woodland Baytown populations utilized circular to oval single poled structures, with a mean floor area of 20 m2.
A “Dunklin phase component underlay” the Big Lake occupation at Zebree (Morse and Morse 1990). Late Woodland Dunklin phase components are very often associated with Early Mississippian Big Lake components. The Morses (1990) calibrate the three 14C dates associated with the Dunklin phase occupation at Zebree to A.D. 691, 829, and 863 (using a 1974 radiocarbon curve), while we obtained results of A.D. 740, 893, and 971 on the same samples using Stuiver and Pearsons’ (1986) more recent radiocarbon curve (i.e., Stuiver and Reimer’s [1993] CALIB software program). This represents a shift of nearly a century. Dunklin phase ceramic assemblages are characterized by: sand-tempered Barnes Cord marked and Plain ceramics, with principal vessel forms being large conoidal jar and small food bowls. Minority decorated types include fabric-impressed and check-stamped (Morse and Morse 1990). Projectiles are crude expended stemmed, side-notched, corner-notched and round-stemmed forms, typically knapped from local Crowley’s Ridge chert or quartzite. Limited Dunklin phase structural evidence (a partial circular structure or windbreak) was reported at Zebree, but numerous pits were associated with this component. The Morses (1983:186) suggested that the Dunklin occupation at Zebree was a winter village composed of a “maximum kin aggregate,” which was relatively isolated—due to lack of evidence for bow technology, horticulture, and/or exotic chert sources.
MISSISSIPPIAN Hallmarks of the Mississippian period include population increase, intensive floodplain settlement, greater emphasis on agricultural activity, earthwork construction on celestial alignments, inter-regional exchange of exotic items, shell-tempered ceramics, and possibly bow warfare. These factors and the development of a distinctive elite iconography are associated with the rise of conscripted, complex sociopolitical system, which we know as chiefdoms. A complex mosaic of competing chiefdoms dominated the late prehistoric Southeast political landscape. These chiefdoms were documented by the Spanish explorers at the close of the Mississippian period, which is often considered the “zenith” of native cultural development.
Two Early Mississippian phases are recognized in Northeast Arkansas: Big Lake (Morse and Morse 1983, 1990) and Hayti, which is largely based on collections from the Kersey site in Pemiscot County (Little River lowlands), Missouri (Marshall 1965). Big Lake components are best understood from excavations at the Zebree site, the type-site for the Big Lake phase, and excavations at the Priestly site (3PO490) near Trumann. Big Lake phase components are characterized by the presence of Varney Red, Mississippi Plain, and Wickliffe Thick ceramics (Morse 1990). Jars are the most common vessel form for Varney Red ceramics, followed by saltpans and simple rounded base bowls. Hooded bottles and Kersey clay objects are also part of these assemblages. Most of the Mississippian Plain vessels were large jars with capacities of over 50 ltr. Wickliffe Thick pottery is associated with a specialized funnel. Local contact with Cahokia during the Early Mississippian period is suggested by the recovery of a Ramey Incised jar from the Perry Dixon site (3MS600; Buchner et al. 2003:84). Other artifacts associated with Big Lake phase assemblages include: sherd abraders; pottery discoidals; Sequoyah, Scallorn, and Madison arrow points; Mill Creek hoes; items related to microlith production; Anculosa shell beads; fish scale tools; and bone fishhooks and harpoons. Subsistence studies suggest a diverse economy, with corn being only a small portion of the diet. Big Lake structures are rectangular and are small, ranging from 6.6–11.4 m2 in size (Morse and Morse 1990:61). While Zebree was fortified, Priestly, a smaller village, was not (Benn 1990:451). Big Lake structures are typically located in distinct midden clusters containing burials and cylindrical pits. At Priestly, a charnel house was identified, and this suggests that public, communal rituals were a part of daily life in
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The Morses (1990:157) note that during the Middle Mississippian, “Mississippian culture crystallized into what is often called ‘mature’ Mississippian.” This period is marked by settlement diversity, with fortified ceremonial centers, smaller villages, and isolated farmsteads, as well as intensive corn agriculture and the rise of independent chiefdoms. Numerous Middle Mississippian components have been excavated (see Morse and Morse 1983:Figure 11.1).
The transition from Early to Middle Mississippian took place ca. A.D. 1000–1050, when Varney Red Filmed ceramics use declines rapidly. The Mangrum (3CG636; Klinger et al. 1981), Hyneman (3PO53; Morse and Morse 1983), Rose Mound (Morse and Morse 1983), Banks Mound 3 (Perino 1967), and Golightly (Morse and Morse 1983) sites are important sites relating to this transitional period.
The early Middle Mississippian Cherry Valley phase (A.D. 1050–1200) is associated with the western lowlands (Phillips 1970:929-930; Morse and Morse 1983). Sites include small ceremonial centers with mounds covering earth-like lodge structures, small villages, and isolated hamlets. The Cherry Valley phase is associated with the “Beaker Horizon” of Morse and Morse (1990:157). Sites with 14C dates for this horizon include Cherry Valley (3CS40), Hazel, Banks 3 (Morse and Morse 1990), and Kochtitzky Ditch (3MS599; Buchner et al. 2003). Other important Beaker sites include the Floodway site (3PO46), the Webb Group (or Bay Mounds, 3CG29), Parkin (3CS29), Turnbow (3CS61), Vernon Paul (3CS25), Ballard (3PO115), and McClellan (3PO32; Morse and Morse 1990:Table 16). Beyond the distinctive, but rare beakers, diagnostics include: O’Byam Incised, Mound Place Incised, loop handled jars, the appearance of bottles and plates, and a variety of arrow points, including Madison, Scallorn, and Shugtown types.
Later Middle Mississippian occupations (A.D. 1200–1400) are associated the “Matthews Horizon” (Morse and Morse 1990:158). During this period the plate vessel form disappears, large strap-handled jars are common, and painted ceramics become more frequent. Trade intensified, not only in exotic items but also in Mill Creek hoes and basalt adzes (Morse and Morse 1983:267). Exchange of Southeastern Ceremonial Complex artifacts, including copper repoussé plates, stone images, and shell gorgets with a distinctive iconography, peaks at this time (Brown et al. 1990). Considerable social change took place, with the settlement pattern shifting from a relatively dispersed pattern of farmsteads and villages with a few ceremonial centers to a pattern characterized by large villages with constituent hamlets clustered around major civic- ceremonial centers (Morse and Morse 1983). This realignment and establishment of a settlement hierarchy is associated with the rise of chiefdom level societies. By A.D. 1400 the braided stream surfaces were abandoned and populations nucleated onto meander belt surface.
Excavations at the Moon site (3PO488) near Trumann revealed evidence of a planned, fortified village dating to this period (Benn 1992). This site has a similar layout to the Powers phase Snodgrass Site in Southeast Missouri (Price and Griffin 1979). In the southern St. Francis Basin, late Middle Mississippian components are considered Lawhorn phase. Important excavated sites include Hazel, Shugtown (Morse and Morse 1983), Lawhorn (Moselage 1962) and Kochtitzky Ditch (3MS599; Buchner et al. 2003). While the Middle Mississippian occupation of the Lower St. Francis Basin was significant, the Cairo Lowlands were also intensively occupied at this time, as evidenced by large fortified sites such as Libbourn, Towasahgy, and Crosno (Chapman 1980; Price and Griffin 1979; S. Williams 1954).
The Late Mississippian occupations have been intensively studied and are characterized by a number of contemporary phases (Phillips 1970; Morse and Morse 1983:Figure 12.1). Highly nucleated and fortified towns are present in some areas (“St. Francis” type sites; see Phillips et al. 1951), while other sections of the St. Francis Basin are apparently uninhabited. These
22 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 depopulated areas are interpreted as “buffer zones” between competing chiefdoms. Much of the Western Lowlands and portions of Missouri were abandoned, resulting in S. Williams’ (1990) “Vacant Quarter Hypothesis.” In Northeast Arkansas, the Nodena (Morse 1989), Parkin (P. Morse 1981), Walls, Kent (House 1993), and formerly Old Town (see House 1993) phases are recognized principally based on decorated ceramic frequencies. Mainfort’s (2003) non- metric, multidimensional scaling analysis of ceramic assemblages from 39 sites “provide[s] little support for the validity” of these cultural-historical units; however, the phases continued to be used for want of a better system. The latter portion (post-1540) of the Late Mississippian period is commonly referred to as the Protohistoric.
PROTOHISTORIC This period is generally considered to have begun with the first appearance of European peoples in the Southeast. De Soto visited the several chiefdoms within the St. Francis Basin in 1541, including Aquixo (Belle Meade, 3CT30), Casqui (Parkin phase), and Pacaha (Bradley, 3CT7). Two of de Soto’s men (Moreno and Silvera) traveled northeast from Pacaha and apparently visited a Nodena phase-Pemiscot Bayou site, Campbell (23PM5; Dye 1993:49). Sites, such as Campbell and Nodena, which were occupied after initial European contact, are considered Armorel phase components (S. Williams 1980). These sites produce low frequencies of European trade goods, such as iron and copper items and glass beads, in association with Late Mississippian artifact types.
HISTORIC ABORIGINAL Terming seventeenth-century aboriginal occupations as “historic” versus “protohistoric” is a rather arbitrary division, as by this point Native American culture had irretrievably changed from pre-European contact lifeways. Most scholars consider Northeast Arkansas to have been depopulated after the de Soto expedition trek west of the Mississippi (1541–1543) and before Marquette and Joliet’s 1673 canoe trip brought them to the Quapaw villages at the mouth of the Arkansas.
The Quapaw phase was proposed by Phillips (1970:943) and updated by Hoffman (1977). These sites are located on the lower Arkansas River. The ceramic assemblages are shell-tempered and appear to have derived from Late Mississippian/Protohistoric culture. Some distinctive ceramic vessel forms such as elaborated painted bottles, teapots, and helmet bowls are considered diagnostic, as are seventeenth-century European trade goods. While Ford (1961) considered his excavations at the Menard Mounds (the Quapaw village of Osotouy) as “conclusive” evidence of the link between the ethnohistorical Quapaw and the archaeological phase, Hoffman (1990:219) has noted there is conflict between Quapaw oral tradition, linguistics, and the ethnological and archaeological data. House and McKelway (1982:SE41) term this problem the “Quapaw Paradox.”
In Northeast Arkansas, Marquette’s 1673 map reveals a Michigamea village in close proximity to what would become the Missouri/Arkansas line. Morse (1992:61) considers this village to be the Grigsby site (3RA262), located near Pocahontas. This site is located halfway between Kaskaskia and the 1673–1690 location for the Kappa Site and is on the Natchitoches Trace, a major trading path that follows the Ozark escarpment. The Michigamea are thought to have operated as trading middlemen between the Illinois French and the lower Arkansas Quapaw, until in 1686 the establishment of Arkansas Post, near the Quapaw village of Osotouy, provided direct access to trade goods for the Quapaw.
In the late seventeenth century, the Quapaw actively sought an alliance with the French, primarily to obtain firearms, so that they could combat the Chickasaw (who had been armed by British traders operating overland from Charlestown). The importance of firearms to the Quapaw is illustrated by their inclusion on early eighteenth-century painted buffalo robes given
23 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 by the tribe to the French king (Horse Capture et al. 1993). During the 1730s and 1740s the Chickasaw were a constant threat to French flatboat traffic on the Mississippi. Bienville organized two unsuccessful campaigns against the Chickasaw and paid the Quapaw for Chickasaw scalps, during this period. In 1749, a Chickasaw raid (led by James Adair, an Englishman) on John Law’s old settlement alarmed all of Louisiana, and as a result Arkansas Post was moved up the Arkansas River to Ecores Rouges (the Red Bluffs).
In the later eighteenth and early nineteenth centuries, several dislocated Native American groups would briefly inhabit the St. Francis Basin, including the Delaware, Shawnee, Chickasaw, Kickapoo, Piankanchaw, Miami, and Wea (Morse and Morse 1983:325). The Cherokee, fleeing from their role in the Muscle Shoals massacre, began infiltrating the St. Francis Basin in significant numbers in 1794 (Hanson and Moneyhon 1989:17). By 1800 the Cherokee were in competition with the Osage for control of the Ozark Highlands. The disrupted eastern Native American groups were apparently welcomed by the Spanish Colonial government, who desired these Indian contingents along the Mississippi to serve as a buffer to American settlers.
After the Jefferson (or Louisiana) Purchase in 1803, the westward movement of American settlers put pressure on these recently established Native American groups in eastern Arkansas to give up their lands. Northeast Arkansas was ceded to the United States through two agreements negotiated by Pierre Chouteau at Fort Clark in North Dakota (Hanson and Moneyhon 1989:19). The second agreement, signed November 10, 1808, is commonly known as the Osage Treaty, and resulted in 14 million acres (including Northeast Arkansas) changing hands. By the 1840s most Native Americans had been pushed out of the Central Valley, although Goodspeed (1889:452) does note that as late as 1861 various Indians of “different tribes” were still living around Chickasawba.
COLONIAL PERIOD Northeast Arkansas was part of Louisiana (New France) during most of the Colonial period. In 1756, the French and Indian War (Seven Years’ War) broke out partly as a result of French efforts to fortify the Ohio Valley. France was defeated and signed the Treaty of Paris on February 10, 1763, which ended the war. Immediately prior to the formal ending of the war the French ceded Louisiana to the Spanish. The Spanish saw Louisiana as a buffer between the British colonists and Mexico, their prized colony. Louisiana was returned to France in 1800, but many Spanish officials still held local offices in 1803.
The region was undoubtedly involved in the European trade network, as by the late seventeenth century, at least 800 coureurs de bois (forest rangers) were hunting in west New France (Arnold 1991:7). Colonial documents suggest that the vast majority of the population was involved in the fur trade. Fort St. Francis was established near the mouth of the St. Francis River in 1766 and Fort Esperanza was established in 1797 across from the fourth Chickasaw bluff (now Memphis, Tennessee). The El Camino Real (Kings Road, also known as Natchitoches Trace) from New Madrid to St. Louis was an important road at this time.
Excavations have been conducted at two of Arkansas Post’s locations: the mid-eighteenth Desha County location (McClurkan 1971), and ca. 1779–1804 upstream Ecores Rouges location (Holder 1957). Holder (1957) identified the remains of the De La Houssaye 1752 fort and the Spanish Fort San Carlos III, built in 1780. Walthall (1991) analyzed the ceramics from Holder’s excavations and observed a temporal lag of 26.5 years between the mean ceramic dates and mean historic dates for the site, an indication of the post’s isolation.
EARLY NINETEENTH CENTURY The Colonial period ends with the Jefferson Purchase in 1803. Arkansas was part of the Louisiana District from 1804–1805 and until 1812 was part of the Louisiana Territory. From
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1812–1819 Arkansas was part of the Missouri Territory. Northeast Arkansas was rocked by a series of massive earthquakes known as the New Madrid earthquakes in 1811–1812 (Fuller 1912). The town of New Madrid was destroyed and the aftershocks continued for months. After the War of 1812 ended (in 1815) and the British-Creek Confederacy was defeated, immigration increased rapidly.
At the Arkansas Post site (3AR47), Bright’s Trading House (1804–1807) and Montgomery’s Tavern (1819–1821) were investigated by the NPS (Martin 1977). Two wells and structural remains, including a brick hearth, and posts and trench patterns characteristic of French settlements were reported. An impressive artifact assemblage including tin glazed earthenware, pearlware, creamware, stoneware, dark green bottle fragments, cutlery, various tobacco pipes, glass beads, gunflints and other gun parts, building hardware, clothing items, coins, and other items such as scissors were recovered.
The town of Davidsonville is probably the best known antebellum archaeological site in Northeast Arkansas (Stewart-Abernathy 1980). This town existed from 1815–1830 on the edge of the Ozark Highlands, near the Natchitoches Trace. Excavations located the brick footings of the courthouse and a brick chimney associated with the post office. Typical early-nineteenth century artifacts were associated with the structural remains, including: blue and green shell edged pearlware; polychrome underglaze pearlware; thin window glass; and wrought and cut nails (Morse and Morse 1983:329).
The GLO began surveying East Arkansas into townships in 1815, and this work continued up to the Civil War. The initial objective was to lie out 2,000,000 ac. for distribution to veterans of the War of 1812 (Hanson and Moneyhon 1989:26). The east/west baseline was set at a point near the mouth of the St. Francis River running due west to the Arkansas River. The Fifth Principal Meridian was used as a north/south line. Land sales based on this Township-Range system began in 1821. Today, the nineteenth-century GLO plat maps and field notes are used by archaeologists to both locate historic features and to reconstruct environmental conditions.
On March 2, 1819, President James Monroe signed a bill creating “Arkansaw Territory,” which included present-day Arkansas and Oklahoma (Hanson and Moneyhon 1989:28). During the Territorial period (1819–1836) county formations by the General Assembly further subdivided the landscape. Mississippi County (1833), Crittenden County (1825), Greene County (1833), Lawrence County (1815), and St. Francis (1827) County covered most of the northeastern corner of the state when Arkansas was admitted to the Union on June 15, 1836. Mississippi County was formed on November 1, 1833 from the northern portion of Crittenden County.
Table 3-02. Antebellum population Statistics for Mississippi County, Arkansas. Census Mississippi Co. Mississippi Co. Territory/State Territory/State Year Total Population Slave Population Total Population Slave Population 1810 — — 1,062 — 1820 — — 14,273 — 1830* 1,272 165 30,388 4,567 1840 1,410 510 97,574 19,935 1850 2,368 865 209,897 47,100 1860 3,895 1,461 435,450 111,115 * Crittenden Co. data provided.
Steamboats provided the most reliable and cheapest transportation during the early to mid- nineteenth century. In 1812, the sternwheeler Orleans became the first ship to reach Mississippi
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County (Goodspeed 1889:451). Osceola developed near Plum Point, a reach that in 1821 was considered one of the “worst places on the Mississippi River” for navigation, due to numerous sandbars and snags (Bragg 1977:57). A number of steamboats sank here, including the Carolina (1841) the Tara Crown, and the Telegraph, while at Nodena bend downstream the Fanny McBurney, the Empress, the Vulcan, the Henry Clay, and the Niagara all sank between 1863 and 1864.
Steamboats need wooded for fuel, and one of the principal occupations of early-nineteenth century settlers along the Mississippi River was selling wood to steamboats (Goodspeed 1889). The clearings these choppers generated became the first settlements and plantation sites. An 1839 river chart reveals the presence of a continuous series of settlements or plantations along the river above and below Osceola (Figure 3-02). GLO surveyors were actively subdividing townships in the Osceola and Luxora area during 1837–1845, and mapped a significant number of fields and houses along the Mississippi River. Many of the plantations and settlements shown along the river between Osceola and Luxora on the 1839 map are shown in more detail on the 1845 GLO plat map for T13N R11E (Figure 3-03). At least 35 GLO features in the Osceola area have been assigned archaeological site numbers (3MS219–3MS261; Table 3-03).
Figure 3-02. A portion of T.J. Porter’s 1839 “Homo-Graphic Chart of the Settlements on the Mississippi River” (map courtesy: Mississippi County Historical and Genealogical Society).
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Figure 3-03. The 1845 GLO plat map for T13N R11E showing settlements and fields between Osceola and Luxora; the modern levee is overlain in red.
Table 3-03. Settlements mapped on 1837–1845 GLO plats in the Osceola-Luxora vicinity. Site Type Component NRHP status Reporter (Date) 3MS219 Herron's Field 1837–1843 Undetermined Keech (1977) 3MS224 E. Daniel's Field 1837–1843 Undetermined Keech (1977) 3MS225 McDaniels House and Field 1837–1843 Undetermined Keech (1977) 3MS226 John Gibbons House and Field 1837–1843 Undetermined Keech (1977) 3MS227 W.J. Jones House and Field 1837–1843 Undetermined Keech (1977) 3MS228 John Bucker's House and Field 1837–1843 Undetermined Keech (1977) 3MS229 Duncan's House and Field 1837–1843 Undetermined Keech (1977) 3MS230 Youst's Gouse 1837–1843 Undetermined Keech (1977)
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Site Type Component NRHP status Reporter (Date) 3MS231 Winn's House 1837–1843 Undetermined Keech (1977) 3MS232 Braden's Field 1837–1843 Undetermined Keech (1977) 3MS235 J. Gable's Yard & C. 1837–1843 Undetermined Keech (1977) 3MS236 S.P. Edington's House 1837–1843 Undetermined Keech (1977) 3MS237 W.B. Bard's House and Field 1837–1843 Undetermined Keech (1977) 3MS238 Mrs. Dicy W. Mills House 1837–1843 Undetermined Keech (1977) 3MS239 Mrs. Dicy W. Mills Field 1837–1843 Undetermined Keech (1977) 3MS240 Williams House 1837–1843 Undetermined Keech (1977) 3MS241 Thos. Killum's House and Field 1837–1843 Undetermined Keech (1977) 3MS242 H.A. Phillips House and Field 1837–1843 Undetermined Keech (1977) 3MS243 Harrington & Patterson's Field 1837–1843 Undetermined Keech (1977) 3MS244 Wilson's Field 1837–1843 Undetermined Keech (1977) 3MS245 Jn. Gables Field 1837–1843 Undetermined Keech (1977) 3MS246 Bard & Edington's Field 1837–1843 Undetermined Keech (1977) 3MS247 Blackmore's & Isadore 1837–1843 Undetermined Keech (1977) Johnson's Fields and a house 3MS248 Norman's House and Field 1837–1843 Undetermined Keech (1977) 3MS249 Wallace's House and Field 1837–1843 Undetermined Keech (1977) 3MS250 Elizabeth Kelley's House and 1837–1843 Undetermined Keech (1977) Field 3MS252 Mrs. Booth's House 1837–1843 Undetermined Keech (1977) 3MS253 Mrs. Booth's Field 1837–1843 Undetermined Keech (1977) 3MS254 Patterson's House and Field 1837–1843 Undetermined Keech (1977) 3MS255 W. Herrington's House 1837–1843 Undetermined Keech (1977) 3MS256 Jos. Simpson's House and Field 1837–1843 Undetermined Keech (1977) 3MS257 Isiah Simpson's House 1837–1843 Undetermined Keech (1977) 3MS258 Simpson's Field 1837–1843 Undetermined Keech (1977) 3MS259 Hutchinson's House and Field 1837–1843 Undetermined Keech (1977) 3MS261 Grandal's Field 1837–1843 Undetermined Keech (1977)
After ca. 1840 most of the Delta plantations shifted from subsistence farming to commercial agriculture, with a heavy emphasis on cotton production (Holley 1993). This trend was part of the western expansion of the “cotton frontier.” Cotton plantations were labor intensive and as a result, the slave population in Mississippi County was relatively high (36 to 37 percent) during the Antebellum period (see Table 3-02). Census data from 1860 revealed that there were 76 slave owners in Mississippi County and the majority of the slave owners (n=43) possessed fewer then ten slaves (Table 3-04). Slave labor contributed greatly to Arkansas’s antebellum economy, adding “at least $16 million to the economy each year and making Arkansas the sixth largest cotton producer in the United States by 1860” (Moneyhon 2012).
Table 3-04. Mississippi County slave ownership data for 1860. Number of Slaves Owner Frequency 1-4 31 5-9 12 10-14 5 15-19 6 20-29 4 30-39 6 40-49 6
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Number of Slaves Owner Frequency 50-69 1 70-99 4 100-199 0 200-299 1 300-499 0 500-999 0 >1,000 0 Total: 76
During the antebellum cotton boom period between 1850 and 1860, the amount of improved land in Mississippi County increased 101.9 percent and cotton production increased 173.4 percent (Holley 1993:242). San Souci Plantation, south of Osceola, was established in 1854 during the boom period. Holley (1993:243-244) remarks that “despite a rush of prosperity” the Arkansas Delta plantations were “too young to be a mature plantation society” and the region was still a raw, undeveloped frontier.
CIVIL WAR AND RECONSTRUCTION Arkansas’ position in the Civil War was complex as a result of being a slave border state. Unionist sentiment was highest in northwestern Arkansas, while the southern and eastern counties, where cotton was produced with slave labor, not surprisingly favored secession. In the initial vote for secession during March 1861, delegates from Northeast Arkansas split, with Mississippi and St. Francis counties favoring secession and Crittenden, Poinsett, Craighead, and Greene counties delegates not favoring secession (Hanson and Moneyhon 1989:41). After the war began in April, the convention reconvened and Arkansas voted for secession on May 20, 1861.
No strategically significant military engagements took place in Northeast Arkansas during the Civil War. During late 1861 and 1862 several engagements took place along the Mississippi River as the Federal campaign to seize control of the river drove southward from Cairo. Island No. 10 near New Madrid was the Confederates strongest position on the river north of Osceola, and it was captured by the Union in April 1862 following a siege (Bragg 1977:27; Daniel and Brock 1996). On May 10, 1862 the Confederate Defense Fleet rammed and sank two Union gunboats in the “Battle of Plum Run Bend” near Osceola. However, by June 1862 Federal forces had swept southward, destroyed the Confederate Defense Fleet and captured Memphis. After the Battle of Helena and the surrender of Vicksburg in early July 1863, virtually all Confederate resistance west of the Mississippi collapsed.
Sporadic guerrilla activity and general lawlessness characterized the latter war years in Northeast Arkansas. In August 1863, the gunboat USS Silver Cloud shelled Osceola due to reported rebel activity (Bragg 1977:55). A skirmish between a Federal regiment and two Confederate companies took place near Jonesboro in August 1863 (Stuck 1960:81). One of the most controversial battles of the Civil War, the Fort Pillow Massacre, took place on April 12, 1864 across the river from Nodena Plantation (Cimprich and Mainfort 1989; Mainfort 1980; Prouty and Barker 1996:17). During July 1864 Missouri Union cavalry skirmished with Confederate guerilla forces near Osceola.
No significant professional Civil War excavations have been conducted in Mississippi County. Across the Mississippi River, excavations at the Civil War Fort Pillow (40LA52) are documented (Mainfort 1980). The Federal soldiers stationed at Fort Pillow frequently patrolled eastern Arkansas and reportedly “supplied themselves with materials for building barracks, by taking away the houses of Osceola” (Goodspeed 1889:457). Near Piggott, the Chalk Bluff Battlefield has been recorded as Site 3CY222.
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In Arkansas, reconstruction lasted from 1865–1874. Far more serious than the loss of life during the war were the effects of occupation. Both sides were responsible for burning crops, buildings, and industrial and manufacturing centers. It took more than twenty years to recover and rebuild from the effects of such destruction, and the scarcity of food and goods during the war had far- reaching, long-term effects on the economic and social fabric of society (Sabo et al. 1990:157).
Due to lawlessness, some areas remained under martial law for several years after the end of the war. This era was bitterly remembered by the local disenfranchised white society as the time of “carpet bag rule.” Organized underground movements with the aims of both “recover[ing] for the whites the control government and society and to destroy the influence of carpetbaggers and Northern opportunists among the Negros,” began after 1867 (Folmsbee et al. 1969:360). The best known of these groups is the Ku Klux Klan, which was active in Northeast Arkansas by 1868 (Stuck 1960). Black secret societies also formed during reconstruction.
A race riot took place in Osceola in 1872 that is known as the Blackhawk War (Goodspeed 1889:458). In 1874, the “Brooks-Baxter War” between rival claimants to the governorship ended when President Grant intervened and ordered the Brooks forces to disperse (Herndon 1922). In 1874, Arkansas adopted a new constitution that restored franchise to all whites and guaranteed full civil rights for blacks, as a result the state was readmitted to the Union.
LAND RECLAMATION EFFORTS The development of the lowlands of eastern Arkansas was closely linked with efforts at reclamation that improved lands that frequently overflowed. One of the first significant actions in reclamation was Congress’s passage of the Swamp Act of 1850. The first Arkansas Swamp Land Secretary was appointed in 1858. Prior to this, levee and drainage ditch construction had been unorganized and conducted on an individual basis. After the Civil War improvements higher up on the Mississippi lead to increased flood heights in the 1870s and 1880s (Burke et al. 1945). Partly as a result, the Mississippi River Commission was created in 1879. In 1881, the first $1,000,000 appropriation was made for levee construction along the Mississippi River (Clay 1986:17). After 1865 and into the 1890s thousands of Irish immigrants participated in manual levee construction.
Much of the St. Francis Basin was sold under this act at prices ranging from $0.50–$1.25 per acre (Harrison and Kollmorgen 1947). Unfortunately, early efforts to use swamp land revenues by inexperienced local levee and drainage district boards were un-coordinated and largely futile.
In 1893, the St. Francis Levee District was created and construction began on the U.S. levee system along the Mississippi River. In 1908, the Little River Drainage District was formed in Southeast Missouri. This district channeled floodwater into Big Lake and thus increased overflow in the unprotected and unorganized portions of Northeast Arkansas. Between 1910 and 1920 numerous local drainage districts were formed in Missouri and Arkansas, and the U.S. government finally realized the need for a consistent and coordinated flood control policy. The Ransdell-Humphreys Flood Control Act of 1917 provided $45,000,000 for such organized flood prevention and control.
As a part of the comprehensive drainage plan, floodways were proposed to contain the St. Francis River and the Right Hand Chute and Left Hand Chute of the Little River. Construction of the levees, drainage ditches, and other control structures began in the early 1920s. The comprehensive drainage plan permitted the economic growth and exploitation of the western portions of Mississippi County.
Local flood control was favored by some, including the R.E.L. Wilson, a millionaire lumberman, the largest landowner, and the major developer of late nineteenth- and early twentieth-century
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Mississippi County (Snowden 1986). However, many other landowners were against the mortgages and bond sales that were necessary to fund the district constructions. The Osceola Semi-Weekly Press reported a story on the drainage debate as follows:
SEES POLITICS IN DRAINAGE FIGHT Osceola, July 14, 1908.—Politics… plays a prominent part in the bitter fight which has resulted from an attempt to organize two big drainage districts in Mississippi county, and which almost culminated in a riot when the petitions for the formation of the districts came up before the county court about 10 days ago… About 300 property owners, objecting to the proposed assessments… proceeded… to take possession of the county court… made threats against Judge Rozzell… The leader of the fight on the drainage districts is Sheriff John A. Lovewell, who for years has been regarded as the political dictator of Mississippi county… J.T. Coston attorney for the county judge, is the leader of the drainage advocates [Osceola Semi-Weekly Press 1908].
R.E.L. Wilson eventually “sold the people on the idea of organizing drainage districts” under the Drainage District Act (Snowden 1986:134). Ditching by the districts began in earnest during the second decade of the twentieth century. The drainage of the swamplands caused a land boom in 1919 (Dew 1968:31).
TENANT PERIOD The period from 1870–1950 is known as the Tenant period (Stewart-Abernathy and Watkins 1982), and is named for the sharecropping or tenant farm labor system that was a significant characteristic of Southern U.S. agriculture after the Civil War. This decentralization of the former plantation system developed during Reconstruction as a means of stabilizing labor relations between former slaves and landowners. Prunty (1955) has interpreted tenancy as a postbellum modification of the plantation system. Arkansas’s farm tenancy percentage peaked in 1930 at 63.0 percent, and was higher than the Southern average (Holley 2000:27). In Mississippi County the tenancy percent during 1930 was even higher: 90.3 percent (Holley 1993:Table 7). This reveals that nearly all the farms in the county were worked by sharecroppers.
Table 3-05. Tenant period population statistics for Mississippi County, Arkansas. Census Total Population Black Population Year 1880 3,633 971 1890 7,332 2,654 1900 11,635 5,900 1910 30,468 13,472 1920 47,320 19,907 1930 69,289 26,145 1940 80,217 25,069 1950 82,375 22,096 1960 70,174 20,712
The importance of the Tenant Farm period in the archaeological record is that it represents the maximum occupation of the study area. At that time there were numerous scattered farmsteads and a complex secondary road network linking them. The dispersed settlement pattern of the Tenant period contrasts sharply with the clustered settlement pattern prior to 1865 (Orser and Nekola 1985:68). The tenant settlement pattern can be observed on early twentieth-century maps, as well as 1930s and 1940s aerial photographs, with alignments along roads and bayous at regular spacing. Sites dating to this period are numerous, and the issue of these sites’ NRHP
31 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 significance status has generated some commentary (Wilson 1990).
The Tenant Farm Activity period is defined as:
…the phase within the history of commercial agriculture in which the rural landscapes dominated by mono-culture are composed of small farms of minimal size operated by white and black renter or sharecropper families. These small farms are tied to the plantation complex and represent a decentralized stage in this development. In this stage the use of capital for the production of a base crop is routed through an extra step consisting of the several families who are responsible for raising the crop. While the direction of capital use and power obviously flows from top to bottom in this stage, the extent to which the tenant family, in fact, exercises control over various of their affairs is problematical, with archaeological implications ranging from source of supply for table ceramics and architectural environment to responsibility for social and physical community patterning and maintenance of ethnic identity [Stewart-Abernathy and Watkins 1982:HA16- HA17].
Stewart-Abernathy and Watkins (1982:HA18) estimate that there are 30,000 to 50,000 tenant house sites in eastern Arkansas. Tenant Farm period components are quite numerous in the Osceola area, and there are at least 55 located near the levee between Middle Nodena and Luxora (Table 3-06).
Table 3-06. Tenant period components located near the levee between Middle Nodena and Luxora. Site Type Component Size (m2) NRHP status Reporter (Date) 3MS404 Domestic site ca. 1900-1940 2,025 Not Eligible Lafferty (1983); Saatkamp (2007); and Buchner et al. (2012) 3MS415 Domestic site ca. 1900-1940 6,000 Not eligible Lafferty (1983) 3MS417 Domestic site ca. 1900-1940 4,900 Not eligible Lafferty (1983) 3MS451 Domestic site Tenant period ? Undetermined Lafferty (1984) 3MS638 Domestic site Tenant period 82,500 Not eligible Walker (2001) 3MS640 Domestic site Tenant period 1,750 Not eligible Walker (2001) 3MS641 Domestic site Tenant period 22,500 Not eligible Walker (2001) 3MS642 Domestic site Tenant period 500 Not eligible Walker (2001) 3MS643 Domestic site Tenant period 1,650 Not eligible Walker (2001) 3MS644 Domestic site Tenant period 1,500 Not eligible Walker (2001) 3MS645 Domestic site Tenant period 3,300 Not eligible Walker (2001) 3MS646 Domestic site Tenant period 13,125 Undetermined† Walker (2001) 3MS663 Domestic site Tenant period 3,600 Undetermined Starr (2001) 3MS664 Domestic site Tenant period 8,000 Undetermined Starr (2001) 3MS665 Domestic site Tenant period 8,000 Undetermined Starr (2001) 3MS666 Domestic site Tenant period 4,800 Undetermined Starr (2001) 3MS667 Domestic site Tenant period 15,000 Undetermined Starr (2001) 3MS668 San Souci Tenant period 1,600 Not eligible Starr (2001) Church 3MS669 Domestic site Tenant period 1,600 Not eligible Starr (2001) 3MS670 Driver 1880s-1890s 900 Not eligible Starr (2001); Cemetery Saatkamp (2004) 3MS671 Domestic site Tenant period 60,000 Undetermined Starr (2001) 3MS695 Domestic site Tenant period ? Undetermined Payne (2003) 3MS705 Domestic site Tenant period 4,500 Not eligible Saatkamp (2004) 3MS706 Domestic site Tenant period 2,400 Not eligible Saatkamp (2004) 3MS709 Domestic site Tenant period 1,500 Not eligible Saatkamp (2004)
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Site Type Component Size (m2) NRHP status Reporter (Date) 3MS710 Domestic site Tenant period 1,600 Not eligible Saatkamp (2004) 3MS711 Domestic site Tenant period 2,000 Not eligible Saatkamp (2004) 3MS713 Domestic site Tenant period 2,800 Not eligible Saatkamp (2004) 3MS758 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS759 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS760 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS761 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS762 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS763 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS764 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS765 Domestic site Tenant period 2,000 Not eligible Saatkamp (2007) 3MS766 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS767 Domestic site Tenant period 21,600 Not eligible Saatkamp (2007) and Buchner et al. (2012) 3MS768 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS769 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS772 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS773 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS774 Domestic site Tenant period 2,000 Not eligible Saatkamp (2007) 3MS775 Domestic site Tenant period 1,600 Not eligible Saatkamp (2007) 3MS779 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS780 Domestic site Tenant period 5,000 Eligible (due to Saatkamp (2007) prehistoric and Buchner et al. component) (2012) 3MS781 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS783 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS784 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS785 Domestic site Tenant period 2,500 Not eligible Saatkamp (2007) 3MS786 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS787 Domestic site Tenant period 900 Not eligible Saatkamp (2007) 3MS789 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS790 Domestic site Tenant period 1,200 Not eligible Saatkamp (2007) 3MS791 Domestic site Tenant period 2,400 Not eligible Saatkamp (2007)
Stewart-Abernathy (1999:240) also notes that “intriguing” investigations at a number of African American and multi-component tenant and owner-occupied farmsteads have been conducted in eastern Arkansas by contract archaeologists (Buchner 1992; Buchner and Childress 1991; Buchner and Weaver 1990; Childress 1990; Weaver et al. 1996). Nearly all of this work was CRM investigations funded by the USACE, Memphis District. Examination of East Arkansas Delta Tenant period archaeological site data lead Buchner (1992) to propose a distinctive “Tenant Period Artifact Pattern” (when assemblages are analyzed using South’s [1977] functional groups). While some deviations can be observed in the frequency patterns identified based on surface collected assemblages versus excavated assemblages, in general the pattern is one where Kitchen Group artifacts dominate. Excavated assemblages tend to produce more nails, thus the proportional representation of the Architecture group increases at the expense of the Kitchen Group.
In Tenant period assemblages, the ceramics are typically cheaper types, often from mismatched sets, and many of these types can be identified following Price (1979). Mean ceramic dates are
33 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 often not calculated for these sites due to the long span of whiteware production, as well as problems relating to temporal lag. Garrow et al. (1989:60) note that “South’s (1977) mean ceramic date (MCD) formula tends to break down after ca. 1860…the primary reason is that neither manufacturing or popularity date ranges have been firmly established for the post-1860 period.” Only trace frequencies of other artifact groups are found (Arms, Clothing, Personal, Furniture, Tobacco), and in small assemblages these minority group types are often not represented.
The cultural deposits at Tenant period sites are typically near surface, often restricted wholly to plowzone contexts, as a result of the buildings being frame structures elevated on brick, concrete, or cypress stump piers. If a house did not have a substantial chimney, it was more likely to be swept away during a flood (cf. Buchner 1992). Occasionally tenant sites are multi-component, (i.e., co-occur with prehistoric material); this is largely dependent on the natural setting of the site. Many Tenant period sites are located on silty clay backswamp soils that were not suitable for human habitation until after drainage improvements were made.
The end of farm tenancy had it origins in Depression economics and “New Deal” politics of the early 1930s. In the spring of 1933, President Roosevelt’s New Deal measures, including the repeal of Prohibition and the Agricultural Adjustment Act (AAA) were voted in (Biles 1986:70). At this time the effects of the Depression and surpluses had driven cotton prices down to 5¢ per pound and the Delta economy, which was so dependant on cotton, was greatly affected. In an effort to counter cotton prices, the AAA initiated federally sponsored cotton reduction programs. By 1934, over 40 percent of cotton acreage normally under cultivation was taken out of production (Biles 1986:71). While cotton prices rose (as expected), the removal of thousands of acres of cotton land from cultivation unfortunately resulted in an “unforeseen” development. It put thousands of Delta sharecroppers out of work, and subsequently many migrated to the “ramshackle slums of Memphis” (Biles 1986:72).
RAILROAD PERIOD During the Railroad period (1855–1950) communication and transportation became dominated by the railroads. This period is “foremost characterized by a drastic reorganization of [a] non- farming settlement pattern keyed to extremely narrow corridors…” (Stewart-Abernathy and Watkins 1982:HA18-19). From an archaeological viewpoint the Railroad period is summarized as:
… aside from the increased presence of consumer goods and increased general information level, the Railroad period is reflected by scores of nucleated settlements whose end or beginning date correspond to the coming of the railroad, and by some of the greatest landscape modifications made by people. These modifications take the form of embankments, cuttings, bridges, and support complexes, and exist on an intensive and extensive scale matched only by the construction after 1950 of highways and levees [Stewart-Abernathy and Watkins 1982:HA18-19].
The first railroad in Arkansas was the Memphis & Little Rock (M&LR), charted in 1853. By 1858 the track was complete from Hopefield (opposite Memphis) to the St. Francis River (Woolfolk 1967). By 1862 the western end of the M&LR line was in place from Little Rock to DeValls Bluff on the White River (Hanson and Moneyhon 1989:49). It was not until after the Civil War that the two sections were joined, under the supervision of former C.S.A. Gen. Nathan B. Forrest. The first permanent bridge constructed over the Lower White River was at DeValls Bluff. With the completion of this bridge in 1871, the M&LR Railroad was open as a continuous line from Hopefield to Little Rock (Moneyhon 1993:212).
Another important early railroad in northeastern Arkansas was the Cairo & Fulton (C&F). By 1874 the C&F, an extension of the St. Louis, Iron Mountain & Southern Railroad, had completed
34 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 a line from Northeast Arkansas (Clay County) to Little Rock and southwest to Fulton on the Red River; trains were running from St. Louis to Texarkana (Hanson and Moneyhon 1989:49). The northeastern section of this line (Corning-Walnut Ridge-Hoxie-Jacksonport) roughly parallels the escarpment of the Ozark Plateau and is still used by National Railroad Passenger Corporation’s (Amtrak’s) Texas Eagle today. Hanson and Moneyhon (1989:49) note that by the close of the 1870s railroads had built 822 mi. of track in Arkansas.
The 1880s railroad construction in Northeast Arkansas was a watershed event. The two most significant lines built in Northeast Arkansas were the St. Louis & Southwestern and the St. Louis & San Francisco (Hanson and Moneyhon 1989:49). In 1882, Jonesboro and Clarendon were linked by the Texas & St. Louis Railroad (H.L. Williams 1930:332). In 1885, this line was reorganized as the St. Louis, Arkansas & Texas and in 1891, it became the St. Louis & Southwestern, or “Cotton Belt.” The St. Louis & San Francisco—SLSF or “Frisco”—ran northwest from Memphis, through Crittenden, Poinsett, Craighead and Lawrence counties. It was not until 1897 that the first railroad bridge over the Mississippi River at Memphis, the Frisco Bridge, was opened. By the turn of the century 3,167 mi. of railroad had been laid in Arkansas (Hanson and Moneyhon 1989:49).
The first railroad to reach Osceola was the Deckerville, Osceola, & Northern Railroad (D, O&N), which opened their depot at Osceola on 13 July 1899 (Edrington 1962b:38). This line runs near western boundary of the Easement A tract. Importantly, it traversed the back part of San Souci Plantation and opened this area up for development. The D, O&N was incorporated in September 1897, and was sold to the Kansas City, Fort Scott & Memphis Railroad (KC, FS&M) in October 1901. By 1916, the KC, FS&M was 100 percent controlled by the SLSF Railroad
One aspect of early railroad development (ca. 1876–1914) was the presence of numerous short line railroads (Hanson and Moneyhon 1989:50). These lines developed out of local interests and played an important role in developing the state. In Northeast Arkansas, the most historically significant short line railroad was the Jonesboro, Lake City and Eastern Railroad (J, LC&E).
During the 1880s railroad boom in Northeast Arkansas, the sunklands had essentially been bypassed (Dew 1968). The major lines skirted the southern and western boundaries of the sunklands, with stations at Paragould, Jonesboro, and Marked Tree. The J, LC&E was chartered April 7, 1897 (Poor’s 1912:1080) by a group of Jonesboro businessmen intent on developing the sunklands. Initially, the J, LC&E ended at Lake City 12 mi. east of Jonesboro, but by 1899 the St. Francis River had been bridged there, thus opening Buffalo Island for development (Dew 1968). In 1902, the next big obstacle, Big Lake, had been bridged and Blytheville was reached. Communities that grew along the J, LC&E include Lake City, Black Oak, Monette, Leachville, Manila, and Dell. In 1905, the J, LC&E consolidated with another local short line railroad, the Chickasawha Railroad. In 1905, the J, LC&E constructed a line southeast to Luxora and Osceola (Hull 1997:386).
The J, LC&E served as both a passenger and freight line, as 34.0 percent and 54.2 percent of its 1911 earnings of $185,252 were derived from these sources, respectively (Poor’s 1912:1080). Its 1911 rolling stock included nine locomotives, three passenger cars, two combination cars, one baggage car, 118 freight cars (33 box; 85 flat), and five service cars. In the same year it operated 86.0 mi. of track and 12.0 mi. of siding. Poor’s (1912) lists the following routes for it in 1911:
§ Jonesboro to Barfield, Ark., 66.0 mi. § Osceola Junction to Osceola, 18.0 mi. § Midway to Luxora, Ark. 1.5 mi. § Midway to Moore’s Landing, 0.5 mi.
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The J, LC&E began experiencing financial difficulties during the panic of 1907 (Dew 1968). By 1913 most of the easily accessible timber along the J, LC&E had been felled and the railroad reported a loss. However, drainage district improvements lead to a land boom in 1919, and the J, LC&E profited from selling cutover lands to farmers. In 1920, cotton prices crashed and the railroad again fell on hard times. By the 1930s cutbacks in service had begun, in part, due to competition from automobiles. The use of railroads in Northeast Arkansas and nationally declined significantly after World War II. The J, LC&E ceased operation on 1 January 1950 (Hull 1997:386).
THE GREAT FLOODS OF 1927 AND 1937 The Flood of 1927 had its origins in August 1926, when heavy rainfall in the central U.S. caused most of the upper Mississippi tributaries to overflow. In late 1926 the U.S. Weather Service noted that “the average reading through the last three months of 1926 on every single river gauge reading on each of the three greatest rivers of North America, the Ohio, the Missouri, and the Mississippi itself…was the highest ever known” (Barry 1998:175).
On New Year’s Day 1927, the Mississippi River reached flood stage at Cairo, Illinois, the earliest for any year on record. Violent winter and spring storms contributed to the worsening conditions and by late March four separate flood crests had passed Cairo (Barry 1998:185). By April, there were already 35,000 refugees and Memphis’s Commercial Appeal (1927) reported, “The outlook was gloomy now.” On Saturday, 16 April a 1,200-ft. section of the levee at Dorena, Missouri (30 mi. below Cairo) crumbled and its collapse “sent a chill all the way down the Mississippi to New Orleans,” since this was the first Federal levee to fail (Barry 1998:194). By the end of April the “Cairo to Memphis sector was lost” and floodwaters continued their devastation at all points downstream (Barry 1998:282).
In June, just as flooded areas of Missouri and Arkansas began emerging from the water—and farmers began planting—another flood crest moved through Cairo (Barry 1998:285). As of that late July, 1,500,000 ac. remained underwater. It was not until August 1927, four months after the first break of the mainline levee on the Mississippi River at Dorena, that all the water receded.
The Red Cross established 154 refugee camps in seven states and over 325,000 people, mostly African-Americans, lived in squalid conditions there for four months. An additional 311,000 people, mostly white, outside these camps were fed and clothed by the Red Cross during the same period. The U.S. Weather Bureau reported 313 deaths from the flood, and put direct losses at $355,147,000 and indirect losses at $1,000,000,00
The legacy of the Great Flood of 1927 was felt not only in mud-caked settlements along the Mississippi River and it tributaries, but also in Washington, D.C. and in the nation’s black community. In Rising Tide: The Great Mississippi River Flood of 1927 and How It Changed America, Barry (1998) addresses not only the physical impacts of the flood, but also the less tangible socio-political developments in its aftermath. Legacies of the flood include shifting “perceptions of the role and responsibility of the federal government—calling for greater expansion—and shatter[ing] the myth of a quasi-feudal bond between Delta blacks and the southern aristocracy…It accelerated the great migration of blacks north. And it altered both southern and northern politics” (Barry 1998:422). Herbert Hoover, who served as relief coordinator and was widely held as a hero for his efforts, was elected President in the aftermath of the flood, and Huey Long was elected Governor of Louisiana.
The Great Flood of 1927 lead to the “Jadwin Plan,” a flood control plan developed by the USACE and presented to Congress by Edgar Jadwin. The Jadwin Plan “embodied the chief principle articulated by Ellet, that the river cannot be contained within levees” and scrapped the
36 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc.Cultural Background 22 previous ‘levee only’ policy by providing designated floodways as a means for the river to spread out over some lands (Barry 1998:423). President Coolidge signed the bill on 15 May 1928. Illinois Congressman Frank Reid stated, “The bill changes the policy of the federal government which has existed for 150 years. It is perhaps the greatest engineering feat the world has ever known…It is the greatest piece of legislation ever enacted by Congress” (Barry 1998:406).
A stalled cold front resulted in extremely heavy rains in early 1937, and by 24 January, a date known as “Black Sunday,” the entire Ohio River from Cairo up to Portsmith was at or above flood stage (American Red Cross 1938:14). All previous flood stage records between Hickman, Kentucky and Helena, Arkansas would shortly be broken. At Osceola, where the flood stage is 28 ft., a record stage of 50.90 ft. was documented on 7 February 1937.
In an attempt to save Cairo and relieve anticipated pressure on the Lower Mississippi Valley levees, the order to activate the New Madrid Floodway was sent by radio from Col. Eugene Reybold in Memphis to W.A. Steele in Cairo on 24 January. Prior to blasting the levee, on 21 January, the USACE issued a warning giving all the New Madrid Floodway residents 48 hours to evacuate. A team of engineers attempted to place explosives in the levee on 24 January, but failed to complete the job because the ground was frozen solid. The following day, 25 January 1937, engineers successfully dynamited the “fuseplug” levee near Birds Point.
While the activation of the New Madrid Floodway saved Cairo, the 1937 flood brought vast devastation to Osceola and Mississippi County (Strange 2012). Hundreds of people lost their homes and belongings, and the cotton crops were decimated. Thousands of refugees poured into Osceola, where Red Cross shelters were set up to receive and treat victims before their removal to Memphis.
WORLD WAR II The immediate and long-term influences that World War II (WWII; 1941–1945) had within the U.S. falls under what cultural resource managers term “Home Front Heritage” (Kelly 2004:40). Arkansas’ Home Front Heritage facilities include military training grounds, airfields, manufacturing, and Prisoner-of-War (POW) internment compounds (Hope 2008). Mississippi County’s Home Front Heritage facilities include the Blytheville Army Air Base (later Eaker Air Force Base), and six branch POW camps that were located at Bassett, Blytheville, Keiser, Luxora, Osceola, and Victoria. Thousands of POWs from these camps were employed as contract labor during the war, and they are credited with saving the state’s rice and cotton crops (Pritchett and Shea 1978). The POW camp at Osceola is recorded as archaeological Site 3MS920.
MODERN ERA Holley (2000:183) considers the period from 1950–1970 in the Mississippi River Delta the “most dramatic period of change—a period in which the region was buffeted by forces that has been building intensity for a generation.” In his view, the two major forces, mechanization and migration, played complementary roles. This era is associated with the “Great Migration,” when over 2,500,000 Southern blacks moved from the Lower Mississippi River Delta area north to urban centers seeking industrial employment and relief from discrimination (Holley 2000:148; Katznelson 1973). This trend can be seen locally; as during the period from 1930–1960 the African-American population of Mississippi County declined 20 percent (see Table 3-04).
Farm mechanization began with the wide-spread introduction of tractors during the 1930s, and accelerated with mechanical cotton picker sales during the 1950s (Holley 2000:115). With the switch to mechanized agriculture, the need for farm labor decreased even further. As a result, many small communities disappeared, and numerous former tenant house locations were then
37 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 plowed under. Farm mechanization also contributed to an increase in the average farm size during this era.
Crop patterns shifted during the modern times. While cotton retains its historical prominence, new crops—especially soybeans and rice—became significant during the 1960s. With the rise of rice agriculture, land leveling became common and many archaeological sites were destroyed during the late twentieth century as a result of this agricultural practice.
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IV. LITERATURE AND RECORDS SEARCH
SANS SOUCI HISTORY The proposed Driver Substation is located within the former limits of the San Souci plantation. Sans Souci was an extensive antebellum and postbellum plantation located on the Mississippi River approximately 4 mi. below Osceola. This plantation placed a significant role in Mississippi County during the Civil War, Reconstruction, and the Tenant period, and some of the leading families in Mississippi County, including the McGavocks and the Griders, are associated with its history. The historic marker at Sans Souci Landing on the Mississippi River abbreviates the plantation’s history as follows:
“The 10,000-acre Sans Souci plantation, established in 1854 by John Harding McGavock, served as a Civil War hospital as the Union Fleet docked across from the home. In addition to farming cotton, much acreage was devoted to hunting deer, bear, and other wild games. In French, “sans socui” means ‘without care’ or ‘no worries.’”
There are number of secondary historical sources that reference Sans Souci (in particular Edrington 1962a, 1962b; Goodspeed 1889; Jacobs n.d.; Mullen 1970). Recent work include Hardy’s (1989) brief article on Sans Souci, and Strange’s (2008) thesis, which focuses on San Souci prior to 1875. The Arkansas Historic Preservation Program (AHPP) recorded the Sans Souci Plantation Site as resource MSØ123 in 1971, but they do not maintain a file on the plantation. The Sans Souci Plantation history that is offered below is cobbled together from various primary and secondary sources, and we are particularly indebted to Dr. Ann Early for sharing her personal research file on Sans Souci Plantation with us.
Sans Souci had it origins during the 1840s when John Harding McGavock’s grandfather, John Harding, made “large purchases in Mississippi County” (Edrington 1962a:297). John Harding is best known for establishing Belle Meade Plantation on the Natchez Trace near Nashville in 1807 (Willis 1998). By the 1840s Harding was one of the Tennessee’s wealthiest men and largest landowners, and thus had the capital to fund land purchases in Arkansas. Strange (2008:5) notes that “Nashville residents Felix Grundy, Jacob McGavock, John Bass, and John Harding … were all related by family or marriage … [and] purchased 20,000 acres of land in Mississippi County” along the Mississippi River during 1832.
Reportedly Mr. Harding traveled “by skiff” down the Cumberland, Ohio, and Mississippi Rivers at various times to make land purchases at the Helena, Arkansas land office (Edrington 1962a:297; Goodspeed 1889:531). GLO records reveal that John Harding is associated with seven land patents dating from 1843–1849 in Mississippi County. These patents were cash sales for tracts totaling 647 ac. in the San Souci area (i.e., T12N R10E, T12N R11E, and T12N R12E). John Harding’s 1844 land patent for the NE¼ of Section 17 of T12N R11E contains the property where we believe the core of Sans Souci plantation would develop.
Harding’s initial four patents, which are dated 1843–1846, describe John Harding as from Nashville, Tennessee or Davidson County, Tennessee (which is the county containing Nashville). On the latter three patents, which are dated 1848–1849, Harding is described as being from Mississippi County. The land patent data thus suggest that John Harding established residency, at least part time, in Mississippi County by ca. 1848. During the 1850s “other members of the McGavock/Harding family settled in the area around Osceola, forming a community of family members in the southern part of the county” (Strange 2008:7).
Edrington (1962a:298) relates a story of John Harding’s “strength of character” involving transporting corn to the Memphis market. It was in his “early” years at San Souci, and he placed
39 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 a bumper crop of corn on a raft for shipment, but the river dropped and left the loaded raft grounded. He simply made camp on the river nearby, and waited until the water rose, and then floated the raft to Memphis as planned. This story can also be viewed as evidence that in the early years San Souci was more akin to a subsistence farm than a cotton plantation.
GLO records also reveal that another Harding (Thomas Harding), also from Nashville, made significant land purchases in the San Souci area at roughly the same time as John Harding. We presume the two are related. Thomas Harding is associated with seven land patents that date from 1844–1848 in Mississippi County. These patents were cash sales for tracts totaling 661 ac., principally in T11N R10E, slightly to the southwest of the John Harding tracts.
The land patents noted above likely formed part of what Edrington (1962a:276-277) refers to as “Harding Farm.” The Harding Farm was described as being 2 mi. south of Osceola. Goodspeed (1889:489) refers to it as the “Hardin farm.” J.D. Driver, who came from Tennessee during the early 1860s, bought the Harding Farm, and cultivated and rented out 14,000 ac. (Edrington 1962a:277).
The founder of San Souci, John Harding McGavock (1824–1861) was born at “Cliff Lawn” in Nashville, and studied at State College in Nashville and Harvard (Edrington 1962a:297; Goodspeed 1889:531). He was “induced” by his grandfather John Harding to establish a plantation on what was then the cotton frontier (Edrington 1962a:297; Goodspeed 1889:531). J.H. McGavock brought many slaves with him from Nashville to clear the land and build cabins at Sans Souci (Carson-Stone 2004). It was a common practice for white pioneers to bring slaves with them during the antebellum cotton boom era (Holley 1993:241). During the developmental period at Sans Souci (i.e., prior to 1854), McGavock apparently spent only part of the year in Arkansas, during which he tended to plantation business and hunted bear (Edrington 1962a:297; Goodspeed 1889:531).
McGavock established permanent residency at Sans Souci after he married Georgia Moore on December 1, 1853 at the Presbyterian Church in Columbus, Mississippi (C. Edrington 1961:7; Hardy 1989:43). John Harding, McGavock’s grandfather, presented the couple with Sans Souci Plantation in Mississippi County as a wedding gift (C. Edrington 1961; Hardy 1989:43; Carson- Stone 2004). Strange (2008:8) notes that the plantation size is often reported as 10,000 ac., but that “the amount on the tax records was closer to” 3,000 ac. Initially they lived in a “stout cabin”, but during 1854 or 1855 (depending on the source) their slaves constructed a big house for them at San Souci (C. Edrington 1961:10; Goodspeed 1889:505). The big house at Sans Souci was “built facing the Mississippi River and was considered a marvel of beauty and convenience in its day” (Edrington 1962b:11; Figure 4-01). Goodspeed (1889:505, 531) provides two descriptions of this residence that are repeated in twentieth-century histories (C. Edrington 1961; Edrington 1962b). They read as follows:
“… residence faces and is about one-half mile from the river. It was built in 1855 and is a building 54x74 feet, two stories in height, with a porch twelve feet wide running the whole length of the and breadth of the house, and at the time of its erection was considered a marvel of beauty and convenience, as all the timber was hand-sawed and the work was well done. It was erected by Mr. McGavock’s slaves, of whom he had a great many, and each room was finished in a certain, distinct kind of wood, one being in black walnut, one in sassafras, another in red gum, and one in ash, each room being designated by these names. The house is approached by a handsome undulating lawn, 200 yards in extent, over which are scattered some magnificent forest oaks, elms, walnut, maple and box elder trees, that are thoroughly appreciated by the family. They also have a handsome flower garden near the house, and ornamental shrubbery assists in making their home all that the heart of man could desire, or that a refined and educated taste could wish.
The house, which was built by John H. McGavock, has a broad piazza 12x74 feet in front, the pillars of which are of swamp cypress, in their natural state, except having their bark stripped off,
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and being painted. They are fluted in the most beautiful and artistic manner, having the appearance of the work of a skillful artist, and are the admiration of every beholder” [Goodspeed 1889:531].
Figure 4-01. Photo of the ca. 1855 McGavock big house at Sans Souci.
After 1854, a “huge” plantation developed around the big house, including slave quarters, barns, a cotton gin, a mill, a plantation store, and other structures (Carson-Stone 2004). Our examination of the 1860 Arkansas slave schedule (which is faded and difficult to read) appears to lists the McGavocks as owning 36 slaves in one entry, and 82 slaves on another entry, for a total of 128 (including 45 males and 63 females). This makes them the second largest slave owners in Mississippi County during 1860 (see Table 3-04), and is a testament to the size of Sans Souci Plantation. In contrast, Strange’s (2008:20) examination of 1859 property tax assessments suggests the McGavocks owned 57 slaves valued at $28,500. Regardless of the exact number of slaves, the McGavolcks were part of the planter class, “which is distinguished by the farmer class” by owning >25 slaves (Strange 2008:20).
While Sans Souci Plantation is often cited as being 10,000 ac. in extent, much of it was forest and probably less than one-third of it likely was under cultivation. This estimation is partly based on Goodspeed’s (1889:489) observation that in 1880 J.D. Driver held 11,000 ac. in Mississippi County, of which 32 percent (3,500 ac.) was in cultivation, and partly based on Strange’s (2008:8) 3,000-ac. assessment of the plantation size based on 1859 tax records.
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The McGavocks grew a high-quality variety of cotton at San Souci that was known as “Black Rattler” (Strange 2008:12). This type of cotton grew well in the warm, moist eastern Arkansas climate. Clarke (1907:43) describes Black Rattler as a long staple variety with 31 percent lint, and small bolls (91 per pound). The San Souci cotton was shipped to Liverpool, England.
Sans Souci also had a landing, and it became a preferred stop for steamboats because of the high bank at Osceola. Strange (2008:18) indicates that steamboats from Memphis stopped twice a week at Sans Souci landing. The section of the Mississippi River at Sans Souci and Osceola was known as Plum Point Reach, and was one of the most dangerous places on the river (Bragg 1977:57). Mark Twain (1883:53) mentions the dangers in passing this reach in Life on the Mississippi. The landing at Sans Souci likely provided a haven for steamboats when navigating this dangerous stretch of the river. The “importance of the Mississippi River and the landing at Sans Souci cannot be understated in the success and wealth of the plantation” and “access to the river provided the young McGavock family with a gateway to the culture to which they were accustomed, making life more bearable in what was then a frontier” (Strange 2008:16, 18).
The McGavocks had four children, which were born in 1854, 1855, 1857, and 1859 (Carson- Stone 2004). Susan John McGavock (born 1857) was their only child to survive into adulthood, and she would inherit Sans Souci.
J.H. McGavock died at his parents home “Cliff Lawn” in Nashville either in April 1861 (Edrington 1962a:297; Carson-Stone 2004) or in December 1861 (Strange 2008:25). Reportedly he had caught a chest cold while repairing a levee in a cold rainstorm.
The Civil War started the year J.H. McGavock died. His widow Georgia McGavock apparently left her younger brother, Judge Clarence L. Moore, in charge of Sans Souci during the early part of the war (Hardy 1989:43). During the conflict, she reportedly worked as a nurse at a hospital for her brother-in-law in Columbus, Mississippi, and smuggled medicines for the hospital during trips to and from San Souci (Carson-Stone 2004; Hardy 1989:43; Jacobs n.d.; Strange 2008:31). In 1863, C.L. Moore joined the CSA and served with N.B. Forrest (Hardy 1989:43).
There were two significant engagements fought near Sans Souci during the Civil War. The first was a naval action known as the “Battle of Plum Run” that was fought on May 10, 1862, and it was an unexpected victory for the South. The Confederate Defense Fleet, which was composed of seven old steamboats converted into rams, surprised the Union gunboats Cincinnati and Mound City and sank them in Plum Point Reach (Bragg 1977:57-59). When three other Union gunboats joined the battle, the Confederate Defense Fleet fled down river to Memphis. Within a month, however, the Memphis Confederate Defense Fleet was destroyed at Memphis (on 6 June 1862), and Union forces occupied Memphis for the duration of the war. The Cincinnati and Mound City were raised, and returned to service with two months (Strange 2008:33).
The second engagement fought near Sans Souci was CSA Gen. Forrest’s assault of Fort Pillow on 12 April 1864, which is considered one of the most controversial battles of the Civil War (Cimprich and Mainfort 1989; Mainfort 1980; Prouty and Barker 1996:17). During the battle the Union garrison of approximately 600 men—composed of approximately 50 percent Black troops—was driven into the inner earthworks, but refused to surrender. Forrest ordered a final assault, and during it Union troops broke ranks and fled to the river suffering heavy casualties: estimates range from 277–297 killed. After the battle Gen. Forrest and his men were accused of murdering the black troops, and the action has become known as the “Fort Pillow Massacre.”
Following the battle, some of the Union wounded were brought via steamboat to Sans Souci (which is 5.7 mi. from Fort Pillow), and the U.S. fleet anchored opposite Sans Souci (Goodspeed 1889:531). Union Gen. Pope ordered the big house at Sans Souci used as a field hospital (Goodspeed 1889:531; Edrington 1962a:298; Strange 2008:34). Reportedly a Confederate spy
42 APSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM:Literature Docket 13-039-u-Doc. and Records 22 Search was hanged from the upstairs balcony, and was buried under the house (C. Edrington 1961:10; Carson-Stone 2004; Strange 2008:46). The yard was also reportedly used as a cemetery for US soldiers (Strange 2008:46), but their bodies were later relocated and reinterred at an unnnamed National Cemetery (Goodspeed 1889:531). Carson-Stone (2004) suggests that they were reinterred at Memphis, and also that not all of the bodies may have been removed.
After the War, Georgia (Moore) McGavock returned to Sans Souci and was happy to find the house still standing (Carson-Stone 2004), but was dismayed at its condition, “desolated and showing the ravages of violence” (C. Edrington 1961:10; Hardy 1989:43). The interior was blood stained, and auger holes had been drilled at the foot of the stairs to allow blood to drain from the operating room in the upstairs parlor (Carson-Stone 2004; Hardy 1989:43). Corpses were found stacked in a wood shed. A “few” former slaves remained at San Souci after the war, and assisted Georgia in repairing the house (Strange 2008:46). The war also took a financial toll on San Souci, as a comparison of 1859 and 1867 tax records shows that the McGavocks’ personal property declined 90 percent: from $47,015–$3,280 (Strange 2008:48). Georgia McGavock filed a claim for $52,615 for cotton taken from San Souci during the war (Jacobs n.d.; Strange 2008:55).
During the Reconstruction period the Sans Souci Plantation house was reportedly used as a Klux Klux Klan (KKK) headquarters (Carson-Stone 2004; Mullen 1970; Strange 2008:49). Georgia McGavock’s brother (C.L. Moore) ran Sans Souci after the war, and as noted above he had served with N.B. Forrest. Gen. N.B. Forrest was one of the founders of the KKK (Hurst 1993), so it is not surprising that Moore sympathized with, or was a member of, the KKK. In 1866, C.L. Moore married Lucy Beale Cooke, and moved to Chickasawba (Blytheville; Hardy 1989:43).
Georgia McGavock remarried in 1868, and her second husband—William A. Erwin of Jackson, Mississippi—had also reportedly ridden with Gen. N.B. Forrest during the War (Carson-Stone 2004; Goodspeed 1889:531; Hardy 1989:43). Given this association it is not surprising that Erwin too sympathized with, or was a member of, the KKK, and used his house for Klan meetings. “Racism was rampant during Reconstruction in Arkansas” and Mississippi County was a hotbed of unrest (Strange 2008:50). Local violence against “carpetbaggers” and African- Americans started in 1868 (C. Edrington 1961:11), and as a result in 1868 Mississippi County was placed under martial law. The violence culminated in the Black Hawk War in 1872, which was a political and racial conflict in Mississippi County (Hale 2009; Strange 2008:50-51). There are no known African-American accounts of the Black Hawk War, which set the stage for post- Reconstruction race relations in east Arkansas (Strange 2008:53).
Susan John McGavock, the only child of J.H. and Georgia (Moore) McGavock to live to adulthood, married William H. Grider in February 23, 1880 (Edrington 2007; Hardy 1989:44). They were married at Sans Souci, and it was the “social event of the season” (Strange 2008:56). W.H. Grider was an Arkansas native who studied and/or practiced law in Memphis (Goodspeed 1889:505). Following the wedding the “newlywed Griders took up residence at San Souci with the Erwins” (Strange 2008:57). W.H. Grider then “took charge of the estate” and 1,300 ac. were cleared under his supervision (Goodspeed 1889:505). In 1889, Goodspeed (1889:505) noted that Grider “rents out a large portion,” presumably of Sans Souci, and owns several thousands of acres of heavy timber. He was assisted in managing Sans Souci by his maternal uncle, C.L. Moore (Goodspeed 1889:505). Beyond managing Sans Souci, in the late 1880s W.H. Grider was also the Sans Souci postmaster, and operated a store, a cotton gin, and a saw mill that employed 50–100 men (Goodspeed 1889:505; Strange 2008:58).
An 1892 Mississippi River chart does not show Sans Souci, but does reveal two landings below the Bullerton Towhead, where Sans Souci Landing is found on twentieth-century charts. These landings are labeled “Driver’s Ldg” and Tanza Ldg.” In 1889, J.D. Driver was described as “one
43 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 of the wealthiest planters in Mississippi County” and he lived on the “Hardin farm” two miles south of Osceola (Goodspeed 1889:489).
William Erwin died in 1882, while Georgia McGavock-Erwin lived until 1912 (Carson-Stone 2004). Susan and W.H. Grider had three children that were born at Sans Souci: Georgia D. (b. 1882), Josephine Louise (b. March 18, 1886), and John McGavock “Mac” Grider (b. 1892). In 1901 Susan (McGavock) Grider moved the family to Memphis, and died shortly thereafter (Carson-Stone 2004). Thus it seems that during the early 1900s Sans Souci was operated by a manager rather than the owner.
In 1899 the Deckerville, Osceola, & Northern Railroad was built across the western portion of Sans Souci Plantation (Edrington 1962b:38). The railroad passed along the western flank of the Sherman Mound and paralleled a dirt road that would become US-61. The railroad opened up the western side of Sans Souci for development. W.H. Grider decided to place a store there some time during the early 1900s, and selected a site across from the Sherman Mound (Edrington 2007:16). The store placement was timely, and it benefited from the increasing rail and highway traffic. A community now known as “Grider” developed with the store as its nucleus. The community eventually included a Post Office and depot, as well as residences (Edrington 2007:16). In later years the store built by W.H. Grider was known as “F.P. Jacobs & Co.” and was named after the Col. Fredrick Philip Jacobs, who was the husband of W.H. Grider’s daughter Josephine (Edrington 2007:16). Josephine Louise (Grider) Jacobs is notable for being the author of Maid of the Mississippi, which was published in 1953, and is about her home at Sans Souci (Edrington 2007; Family Tree Net 2012).
“Mac” Grider (third child of Susan and W.H. Grider) got married at age 17, and moved from Memphis back into the big house at Sans Souci ca. 1909, where he farmed successfully (Carson- Stone 2004). Mac and his wife had two children, but divorced in 1916 (Polston 2010). When the U.S. entered WW I in 1917, “Mac” could not get into the Army Air Corps, and instead joined the Royal Air Force (RAF) and became a combat pilot. He is one of a “small number of US pilots to serve with the RAF” during WW I (Polston 2010). Mac Grider was shot down and killed on June 18, 1918 near Armentieres, France, and his body was never recovered. In 1926 War Birds: Diary of an Unknown Aviator was published, which is reportedly based on Grider’s war diary. The McGavock-Grider Memorial Park on US-61 north of Grider is named in his honor.
From 1912–1927 Sans Souci Plantation was operated by the a firm known as the “Edrington Brothers” (Edrington 1962a:279). The Edrington Brothers included Samuel C. (1863–1943), George (1868–1951), and John William (1869-1953; Edrington 1962a:278-279). The Edrington’s were one of the early antebellum families in Osceola. Prior to forming the Edrington brothers firm, George Edrington was Postmaster of Sans Souci in 1907 (Family Tree Maker 2012). In addition to the plantation, the Edrington Brothers also operated a cotton gin and “a large store” (Edrington 1962a:279). George Edrington’s second wife was Mary Allen, and one of their children was Douglas Edrington. Doug Edrington operated a store at 3MS404 during the 1940s (Buchner et al. 2012).
The 1914 soil map of Mississippi County shows Sans Souci as a cluster of buildings located along the landside of the levee in Section 17 (Figure 4-02). To the north Sans Souci Landing and Sans Souci School can be found. The historic ca. 1855 big house at Sans Souci Plantation burned in April 1922 (Osceola Times 1922), and thus should be shown on the 1914 map. It is probably be one of the structures on the unprotected (riverside) of the levee to the east of the Sans Souci label. Strange (2008:62) reports that the Mississippi River “has moved approximately one mile to the west since the McGavocks settled at Sans Souci” (Strange 2008:62).
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Figure 4-02. A portion of the 1914 soil map showing Sans Souci in Section 17 and the proposed Easement A area indicated by arrow (map courtesy of the Mississippi County Historical & Genealogical Society).
The Sans Souci community label does not appear on U.S. Geological Survey (USGS) 15-min. quad maps that are dated 1933, 1939, and 1948, but Sans Souci Landing does appear on these maps (see Figures 4-03–4-04). The 1933–1948 maps reveal a dwindling community at Sans Souci, and the growth of Grider. Carson-Stone (2004) notes that the last structure at Sans Souci was destroyed in 2000. It was a sharecropper house where a “Mrs. Hunt” had lived since 1935.
During the 1920s to the 1940s, the plantation was almost certainly rented out to multiple sharecroppers. Mississippi County farm tenancy rates were very high at this time (82.9 percent in 1920, and 90.3 percent in 1930; Holley 1993:Table 7). It is probably that F.P. Jacobs (husband of Josephine [Grider] Jacobs) managed the affairs of Sans Souci during the latter Tenant period (i.e., after the Edrington Brothers). Josephine and Col. Jacobs lived at Sans Souci until 1922 when it was destroyed in a fire, and then they built the Grider Plantation at Grider and lived there until 1950. Josephine and Col. Jacobs had one child, Fredrick Philip Jacobs, Jr. (1881–1953; Family Tree Net 2012). Josephine (Grider) Jacobs died in March 1973.
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Figure 4-03. A portion of the 1939 Osceola, Ark.-Tenn. 15-min quad. with the proposed Easement A area indicated by arrow.
During the later Tenant period most of the sections in Sans Souci vicinity were divided up among multiple owners.
Today none of the old family names that were associated with Sans Souci Plantation can be found on the real estate map for T12N R11E. The largest local landowners currently appear to be Entergy Arkansas, Inc., and the Olendorf Investment Co. and/or Olendorf Family Trusts. If the Olendorfs are descendants of the Griders then there would be some continuity in ownership from the heyday of Sans Souci.
In October 2006 “ground was broken” on 1,000 ac. of the former Sans Souci Plantation for the Plum Point Energy Station (Strange 2008:62). This 665-MW coal powered energy station went on line in August 2010 (Powermag 2011)
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Figure 4-04. A portion of the 1965 Osceola, Ark.-Tenn. 15-min quad with the proposed Easement A area indicated by arrow.
ARCHAEOLOGICAL INVESTIGATIONS AT SAN SOUCI There have been at least six cultural resources investigations that covered portions of Sans Souci Plantation (see below for individual project reviews). As a result, a relatively high number of historic period archaeological sites are recorded in the Sans Souci vicinity (see Saatkamp et al. 2010:Figure B-03 for site distributions).
Two sites have been suggested to be the location of Sans Socui (i.e., the McGavock big house and its surrounding facilities). Site 3MS667 is located on the river near Sans Souci Landing (outside the levee’s protection), and 3MS646 is located on the landside of the levee to the west of
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Sans Souci Landing. Unfortunately neither of these sites produced early to mid-nineteenth- century diagnostics when professionally investigated. However an amateur (Ms. Carson-Stone) reportedly has found Civil War era artifacts at 3MS667, and she rather convincingly argues that 3MS667 is the former location of the McGavock big house and slave quarters. Site 3MS646 is possibly the old Edrington home place, a structure that was moved from the riverside to the protected side of the levee.
Most of the other historic archaeological sites in the Sans Souci vicinity are associated with former tenant houses, although 3MS668 is the remains of the Sans Souci Church and 3MS670 is the Driver Cemetery (see Table 3-05). Site 3MS404 was the location of the Doug Edrington Store, and has been Phase II tested (see below).
TYRONZA PHASE II WATERSHED SURVEY In 1983–1984 Mid-Continental Research Associates conducted a sample survey within the Tyronza Watershed for the Soil Conservation Service (Lafferty et al. 1984). This resulted in the identification of a significant number of sites, of which two are Historic components located in the San Souci vicinity (3MS404 and 3MS451).
PLUM POINT ENERGY SURVEY During 2001, Weaver & Associates, LLC (W&A) surveyed four tracts (A–D) totaling 638 ac. for Plum Point Energy Associates (Walker et al. 2001; AMASDA #4431). The study tracts were located on both sides of the mainline levee west of San Souci Landing. A draft report on file at the AAS indicates that the survey resulted in the documentation of one previously recorded site (3MS451) and 19 newly recorded sites (3MS639–3MS656; Walker et al. 2001:i). Walker et al. (2001:114) suggested that potentially significant deposits existed at three sites (3MS451, 3MS646, and 3MS652), and that these sites should be considered eligible.
Importantly, a local informant indicated that Site 3MS646 was the former location of the San Souci Plantation House built by John H. McGavock. Unfortunately Walker et al. (2001:Table 12) recovered only twentieth-century artifacts from 3MS646, so a nineteenth-century occupation at 3MS646 is unsubstantiated by the archaeological record. Additional work could, however, turn up such evidence. Site 3MS646 may be the “old Edrington home place,” a two-story frame house “near Sans Souci” that was moved from the riverfront to a point “close to the levee” because of “high water” (C. Edrington 1961:23). If true, then this could explain why Walker et al.’s informant thought it was the location of the McGavock big house. There are a number of conflicting pieces of critical information between the AAS site card and the draft report text that describe 3MS646, and we caution any future investigators of 3MS646 to carefully review both data sets while planning a research strategy. This site appears to have been avoided and preserved in place during the 2006–2010 construction of the Plum Point Energy Station.
Panamerican’s review of AAS site files reveals that additional work by Mary E. Starr—that is unfortunately not documented in the W&A draft report—resulted in the identification of at least seven additional sites (3MS663–3MS669) within Plum Point Energy Associates Tract C, and one site outside the survey area (3MS670; the Driver Cemetery; Saatkamp et al. 2010). Work conducted by Starr at 3MS667 included the excavation of two shovel tests, and recovery of a surface collection (2001 site form). Starr described 3MS667 as a large (160-x-120-m), but thin, scatter with a dense concentration of domestic material 40 m in diameter around the shovel tests. Site 3MS667 was subsequently proposed by Ms. Carson-Stone to be the location of the McGavock big house (2002 site form update), and she has reportedly recovered Civil War era artifacts from the site (Dr. Early personal files). The McGavock big house and slave quarters are proposed to be located adjacent to the Bungie conveyor at San Souci Landing. Site 3MS667 needs to be intensively surveyed and/or tested to confirm Carson-Stone’s hypothesis.
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PROJECT BLUE WATER SURVEY During 2004, Panamerican surveyed 700 ac. south of Osceola, as a part of a study code named “Project Blue Water” that was associated with the potential development of a steel mill (Saatkamp et al. 2004; AMASDA #4893). The Project Blue Water study area was located south of Osceola and north of Walker et al.’s (2001) Plum Point Energy survey tract (see above). As a result this area is probably more associated with J.D. Driver’s old “Hardin farm” tract than Sans Souci, but portions of the Project Blue Water area may relate to Sans Souci. This survey resulted in the documentation of one previously recorded historic cemetery (3MS670; the Driver Cemetery), and nine newly recorded archaeological sites (3MS705–3MS713). All of Saatkamp et al.’s (2004) newly recorded sites were sparse tenant period domestic scatters that were recommended not eligible for National Register of Historic Places (NRHP) nomination. The Driver Cemetery was found to contain eight monuments dating from 1887–1890, and the recommended treatment plan was avoidance (Saatkamp et al. 2004:82-85). The SHPO concurred with the conclusions and recommendations (Grunewald 2004).
GREAT RIVER SUPER SITE SURVEY During 2007, Panamerican surveyed approximately 3,000 ac. for the Great River Economic Development that was slated for development as a steel mill (Saatkamp 2007; AMASDA #5363). This large tract is located immediately south of U.S. Highway 198 (HY-198), and extends from US-61 at Grider to the levee 4.5 km away, and then to the riverbank (see Saatkamp 2007:Figures 1-02 and 1-02). The Great River Super Site is located south of the core portion of Sans Souci, and thus it represents much of back portion of the plantation that was formerly characterized by scattered tenant settlements and timberland. The Super Site survey resulted in the documentation of four previously recorded sites (3MS16 [the Sherman Mound], 3MS404, 3MS450, and 3MS674), and 72 newly recorded sites (3MS728–3MS799; Saatkamp 2007:225). The majority (n=68) of the recorded sites were sparse tenant period scatters. Five of the sites documented during this survey were considered potentially significant, and since this survey four have been tested for significance (see below). The SHPO review letter indicated that Sherman Mound was likely eligible, and that it should be avoided and preserved in place (Gruenwald 2007).
LUXOR AND OSCEOLA RELIEF WELLS SURVEY During 2009, Panamerican conducted a survey along a 12 km stretch of levee from below Osceola to above Luxora for the USACE, Memphis District (Saatkamp et al. 2010). The work was restricted to a 200 ft. corridor on the landside of the levee, and was conducted during the planning phase of a relief well system that only a fraction of which was ever constructed. This survey resulted in the documentation of ten newly recorded sites (3MS885–3MS894), and revisits to 17 previously recorded archaeological sites and two standing structures. A portion of the Right Of Way (ROW) was not investigated because the Plum Point Energy Station was under construction, but this area had been previously surveyed by Walker et al. (2001). Nineteen of the sites were assessed (or re-assessed) as not eligible, and the remaining eight sites will not be affected by the proposed work. The removable maps found in an appendix to this report are notable for showing survey coverage and site distributions from Luxora to Osceola and Upper Nodena, and some of the tabular data was of sufficient quality to be recycled for use in Chapter III of this report.
GREAT RIVER SUPER SITE TESTING During 2012, Panamerican tested Sites 3MS404, 3MS767, and 3MS780 at the Great River Super Site (Buchner et al. 2012). The Phase II archaeological fieldwork was conducted between 29 June and 10 July 2012 by an eight-person crew, and included the excavation of eleven 1-x-1-m tests units and 331 shovel tests at 10-m intervals, and a geophysical survey of 3MS780. The Phase II findings at the three tested sites are summarized below.
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Site 3MS404 is a 100-x-70-m Tenant period plowzone deposit that produced 1,257 artifacts. A local informant reported that 3MS404 was the location of the Doug Edrington Store and residence during the 1940s. Map data reveals that structures here was razed ca. 1965–1972. Tax records support the informant’s assertion that Doug Edrington operated a store at 3MS404.
Site 3MS767 is a 180-x-120-m Tenant period and late twentieth-century plowzone deposit that yielded 3,887 historic artifacts and one isolated non-diagnostic prehistoric artifact. Twentieth- century archival maps reveal that multiple structures were located at 3MS767 until late in the twentieth century, including one large barn or equipment shed, and the site appears to have functioned as a farm shop and possibly headquarters, as well as a residential area for tenants. The majority (78.4 percent) of the 3MS767 assemblage consists of Architectural Group artifacts.
Site 3MS780 is a 100-x-50-m prehistoric and historic scatter that produced 123 Middle to Late Mississippian artifacts and 227 Tenant period artifacts. Importantly, the excavations revealed the presence of intact Mississippian deposits that contain well-preserved architectural features and abundant daub (> 15.3 Kg of daub was recovered). A geophysical survey suggests that 3MS780 is a village or hamlet containing the remains 14–16 Mississippian structures that are distributed in four clusters across an approximately 60-x-60-m area. The ceramic assemblage from 3MS780 suggests an occupation during the late Middle or early Late Mississippian period.
Site 3MS780 was recommended eligible for NRHP nomination under Criterion D (information potential). Sites 3MS404 and 3MS767 were recommended not eligible for the NRHP.
3MS753 SITE TESTING During 2013, Panamerican tested a fourth archaeological site at the Great River Super Site for NRHP significance: 3MS753 (Buchner et al. 2013). This site located on the far western side of San Souci Plantation in an area that was probably not developed until the twentieth century. The Phase II archaeological fieldwork at Site 3MS753 was carried out from 11–13 February 2013 by a five-person crew and included the excavation of three 1-x-1-m tests units, 36 shovel tests at 10-m intervals, and the recovery of a general surface collection. Site 3MS753 was found to be a sparse scatter of prehistoric (Late Woodland and Mississippian) and historic material that is restricted to the plowzone; no intact subsurface deposits or features were encountered. Site 3MS753 was recommended as not eligible for the NRHP, and no further archaeological work was recommended. 3MS667 Revisit During the 3MS753 testing project, the Panamerican crew and AAS personnel revisited 3MS667, which is interpreted by Ms. Carson-Stone as the ca. 1855 San Souci McGavock big house location. Work conducted during this revisit included shovel testing at 20-m intervals (eight transects of ten shovel tests each), and the recovery of a general surface collection. The site is a low- to moderate-density historic scatter, and artifacts were most frequent ≈100+ m northwest of the Bunge conveyor.
The 2013 revisit of 3MS667 produced 64 artifacts, including 46 artifacts from 15 positive shovel tests and 18 artifacts from the surface. Subsurface recovery was typically from 10–20 cm below surface (cmbs). Unfortunately, this assemblage lacks any clear cut Civil War or Antebellum diagnostics, so Ms. Carson-Stone’s hypothesis still remains to be proven. The 2013 collection is principally is composed of post 1880 domestic and architectural artifacts, and includes several marked firebricks and Coffeyville paver bricks.
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ARKANSAS ARCHEOLOGICAL SURVEY SITE FILES A review of the records and files at the AAS office in Fayetteville was conducted for this project. A standard site files check was performed, and prior archaeological work in and within a 2-km radius of the study area was researched.
Importantly, the site files research reveals that there are no previously recorded archaeological site is located within Easement A. Within a 2-km radius of the proposed Driver Substation there are at least 46 previously recorded archaeological sites (Table 4-01). The majority of these sites are Tenant period domestic scatter that are considered not eligible for NRHP nomination. The only sites with the 2-km radius that require avoidance or additional work are the Sherman Mound (3MS16), 3MS451, and 3MS652; none of which are located within the proposed Driver Substation or Easements A, B, or C.
Table 4-01. Previously recorded archaeological sites within 2 km of the study area. Site Description Remarks Status 3MS16 Sherman Mound Multiple citations Eligible Identified in 1984; Tested in 3MS404 Edrington Store: 20th C. store and residence Not eligible 2012 (Buchner 2012) 3MS450 Early to mid 20th century Described in Saatkamp 2007 Not eligible An extensive Historic scatter on a higher ridge; Identified in 1984; revisited in 3MS451 Undetermined some isolated prehistoric materials as well 2001 (Walker et al. 2001) 3MS533 Tenant period scatter Not eligible 3MS647 Tenant period scatter Walker et al. 2001 Not eligible 3MS648 Tenant period scatter Walker et al. 2001 Not eligible 3MS649 Tenant period scatter Walker et al. 2001 Not eligible 3MS650 Tenant period scatter Walker et al. 2001 Not eligible 3MS651 Tenant period scatter Walker et al. 2001 Not eligible 3MS652 19th century domestic scatter Walker et al. 2001 Undetermined 3MS653 Tenant period scatter Walker et al. 2001 Not eligible 3MS654 Tenant period scatter Walker et al. 2001 Not eligible 3MS655 Tenant period scatter Walker et al. 2001 Not eligible 3MS656 Tenant period scatter Walker et al. 2001 Not eligible 3MS671 20th C. Historic scatter Identified in 2001 by Starr Not eligible 3MS672 20th C. Historic scatter Identified in 2001 by Starr Not eligible 3MS673 20th C. Historic scatter Identified in 2001 by Starr Not eligible 3MS674 20th C. Historic scatter Identified in 2001 by Starr Not eligible 3MS708 20th C. Historic scatter Identified in 2001 by Starr Not eligible 3MS728 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS730 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS731 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS732 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS733 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS734 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS735 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS736 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS737 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS742 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS743 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS749 Tenant period scatter described in Saatkamp 2007 Not eligible
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Site Description Remarks Status 3MS750 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS751 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS752 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS754 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS755 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS756 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS757 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS770 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS771 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS793 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS795 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS798 Tenant period scatter described in Saatkamp 2007 Not eligible 3MS799 Tenant period scatter described in Saatkamp 2007 Not eligible
ARKANSAS HISTORIC PRESERVATION PROGRAM STRUCTURE FILES A review of the records and files at the Arkansas Historic Preservation Program (AHPP) office in Little Rock was conducted for this project. Importantly, this research revealed that there are no previously recorded structures or historic properties within the Driver Substation Easement A tract. Within a 2-km search radius two properties have been recorded:
§ MSØ259 is the ca. 1965 Osceola Drive Inn Theater (NRHP status not eligible); and § MSØ296 is the ca. 1942 Bryan-Crosthwait Farm Complex; site of the Osceola WWII POW camp (NRHP status eligible).
NATIONAL REGISTER OF HISTORIC PLACES LISTINGS As of this writing, there are 33 NRHP listed properties in Mississippi County, Arkansas, including two National Landmarks (National Register of Historic Places 2014). Both of the National Landmarks are Mississippian period archaeological sites: Nodena and Eaker. Two other archaeological sites in Mississippi County are individually listed: Zebree (3MS20) and the Chickasawba Mound (3MS55).
NATIONAL ARCHAEOLOGICAL DATABASE The National Archeological Database (NADB) is a bibliographic inventory of over 350,000 reports on archeological investigation and planning, mostly of limited circulation (i.e., “gray literature;” National Archeological Database 2014). NABD was last updated in August 2004. We searched NADB for Mississippi County, Arkansas literature, and this query resulted in 138 “hits.” This a relatively high number of hits for single county, and is a reflection of the interest that the county’s prehistoric archaeological record has generated since the late nineteenth century. Note that over 19 percent (n=27) of these reports represent USACE sponsored CRM investigations.
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V. FIELD INVESTIGATIONS
METHODS A crew consisting of the Author and one Archaeological Technician conducted the fieldwork at the 3.09-ac. Easement A tract on 19 March 2014. The tract exhibited good to excellent surface visibility, thus it was surveyed via a pedestrian walkover, supplemented by the excavation of four judiciously placed shovel tests.
SHOVEL TEST DEFINITION A shovel test consisted of the excavation of a four-sided hole at least 30 cm to a side (0.09 m2). Each shovel test was excavated to 50 cmbs. To ensure consistent artifact recovery, all sediment was hand-screened through 0.25-in. mesh hardware cloth. All natural and cultural strata revealed in the individual shovel test profiles were recorded using metric depth measurements, and described in terms of textural class and color (using the Munsell Soil Color Chart). Additional strata descriptions were provided as needed, such as moisture, natural rock content, and number and size of roots. Panamerican employs a specialized shovel test form to insure consistent shovel test profile recording. Following recording a shovel test, artifact sample bags (if any) were labeled. All holes were subsequently backfilled as closely as possible to the original condition.
SITE DEFINITION In Arkansas, an archeological site is “defined by the presence of three or more artifacts (chips, flakes, historic objects, etc.) within 5 m of each other, or by the presence of man-made features such as mounds, Civil War entrenchments, [or] wells,” even when there are no artifacts present (2010 State Plan Appendix B guidelines). Additionally, to be recorded in the AAS site files database, a site must be 50 years or older.
An isolated find is recorded as a site if it is a diagnostic or significant artifact. By way of example, Appendix B notes that a diagnostic artifact is “one that provides temporal or cultural information” and an example of a significant artifact is a novaculite flake in the Delta.
SURVEY DOCUMENTATION To ensure appropriate field data management, Panamerican employs a system the company developed for intensive surveys. This system has been successfully implemented for several years and, for example, it has been used successfully during various past projects within Arkansas. Throughout the course of the fieldwork, the crew used specialized forms to individually record the shovel test locations. The status of each shovel test was assessed as positive (), negative (), or not excavated (Ø). In the case of the latter, which are referred to as “no-test” locations, the reason for not excavating a shovel test is provided on the forms. This allows for a complete inventory of shovel tests to be generated. Shovel test profiles, sediment characteristics, and depths of artifact recovery, if any, were recorded on the forms during the fieldwork. At the end of each field day, this information is collected by the field director and reviewed for content. The shovel test data was later entered into a Microsoft Excel spreadsheet by Panamerican laboratory staff, and a table presenting the information was produced. This table documents the intensity of the survey, and demonstrates the coverage of the non-site areas within survey tracts.
In addition to the individual shovel test results recorded by the archaeological technicians, the field documentation included, but was not limited to, the following: (1) the Author maintained a set of field notes that outlines daily activities and provides a general commentary on the project
53 Driver Substation SurveyAPSC FILED Time: 6/18/2014 12:34:24 PM: Recvd 6/18/2014 12:28:36 PM: Docket 13-039-u-Doc. 22 findings, and it also includes any unique or significant findings; (2) the location of each identified cultural resource was recorded on a 7.5-min. quad map; (3) a scale sketch map of each artifact locus was prepared; (4) the survey area and all recorded sites were recorded using photography; and (5) a number of logs or lists were maintained, including ones for artifact bags and photo records.
FINDINGS The survey resulted in negative findings, no archaeological deposits or historic features were documented within the 3.09-ac. Easement A tract. Systematic surface inspection failed to locate any archaeological material or features, and the four judiciously placed shovel tests were sterile.
The cover at Easement A tract was a harvested soybean field with good (50–75 percent) to excellent (75–100 percent) surface visibility. The corners of the tract were professionally marked with silver metallic survey disks and white PVC pipes with pink flagging.
Given the surface visibility offered, the tract was principally surveyed via a pedestrian walkover. Surveyors walked parallel transects spaced 10–12 m apart. No artifacts or cultural features were observed; however, a light scatter of modern trash and road gravel were present in and near the ditch along the base of HY-198. A concrete culvert under HY-198 was observed near the southwestern end of Easement A.
Four judiciously placed shovel tests were excavated across the center of the Easement A tract at roughly 50–60-m intervals. All of these shovel tests were sterile (Table 5-01). They produced identical profiles that are consistent with the published description for Sharkey silty clay (Ferguson and Gray 1971).
Table 5-01. Shovel test inventory. Shovel Test Status Max Depth (cm) Soil Description Notes 1 50 10YR 4/2 clay, homogenous, massive Could not see Ap 2 50 10YR 4/2 clay, homogenous, massive Could not see Ap 3 50 10YR 4/2 clay, homogenous, massive Could not see Ap 4 50 10YR 4/2 clay, homogenous, massive Could not see Ap Key: Positive=; Negative=; and Not Excavated=Ø.
DISCUSSION Given the soil type, it is not surprising that no prehistoric sites are found within Easement A tract (see “Soils” in Chapter II: Environmental Setting). The Sherman Mound (3MS16), which is located 425 m southwest of the tract, is associated with Tunica silty clay soil (Ferguson and Gray 1971:Sheet 57).
The Easement A area was likely not desirable for Euro-American settlement until after the railroad was constructed to the west of the tract in 1899, and was likely not suitable for occupation (due to wetness and poor drainage) until after the regional drainage and clearing projects of the early twentieth century. A review of 1914, 1939, and 1965 quads failed to produce evidence for a structure within the tract.
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Figure 5-01. Photo of Easement A; view southwest from the northeastern corner of the tract (P3190121.jpg).
Figure 5-02. Photo of Easement A; view west across the northern end of the tract (P3190122.jpg).
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Figure 5-03. The southern end of Easement A; view southwest to the Sherman Mound (P3190123.jpg).
Figure 5-04. Photo of Easement A; view northeast from the southern corner of the tract (P3190126.jpg).
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VI. SUMMARY AND RECOMMEDATION
SUMMARY At the request of FTN, Panamerican performed a Phase I cultural resources survey of the 3.09-ac. Easement A tract in Mississippi County, Arkansas that is slated for development as a part of Entergy’s Driver Substation project. The purpose of this study was to identify all known and unrecorded cultural resources present within the tract, and to provide appropriate management recommendations for any such properties identified.
The proposed Driver Substation and its associated easements (A, B, and C) are planned along and near HY-198, to the northeast of the community Driver and southwest of the City of Osceola (see Figure 1-01). Easement A is a triangular-shaped 3.09-ac. tract located along and northwest of HY-198 across from the proposed Driver Substation (see Figures 1-01 and 1-02). The proposed Driver Substation, Easement B, and Easement C are located across (southeast of) HY-198 and have been previously surveyed for cultural resources (Saatkamp 2007), thus were excluded from this cultural resources survey. Easement A is located near the center of Section 24, T12N R10E, and can be identified on the Osceola, AR-TN 7.5-min quad.
A review of the AAS and AHPP files revealed that there are no previously recorded archaeological sites or historic properties located within Easement A. Within a 2-km radius of the tract there are 46 previously recorded archaeological sites (see Table 4-01). Most significantly, Easement A is located within the former limits of the San Souci plantation. Sans Souci was an extensive Antebellum and Postbellum plantation located on the Mississippi River ≈4 mi. below Osceola. This plantation played a significant role in Mississippi County during the Civil War, Reconstruction, and the Tenant period, and some of the leading families in Mississippi County, including the McGavocks and the Griders, are associated with its history.
The Author and an Archaeological Technician conducted the fieldwork at Easement A on 19 March 2014. The tract exhibited good to excellent surface visibility, thus it was surveyed via a pedestrian walkover, supplemented by the excavation of four judiciously placed shovel tests.
The survey resulted in negative findings, no archaeological deposits or historic features were encountered within the 3.09-ac. Easement A tract. Systematic surface inspection failed to locate any archaeological material or features, and the four judiciously placed shovel tests were sterile.
RECOMMENDATION As there are no NRHP listed, eligible, or potentially significant cultural resources within Easement A, nor within the proposed Driver Substation or Easements B and C, no further archaeological work is recommended prior to releasing these areas for construction.
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APPENDIX A: BIOGRAPHIES OF KEY PERSONNEL
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C. ANDREW BUCHNER, PRINCIPAL INVESTIGATOR/FIELD DIRECTOR C. Andrew Buchner has 24 years of experience as a CRM archaeologist. He is a Vice-president and partner in Panamerican Consultants, Inc. and manages the terrestrial operations of the company’s Memphis office. His degrees include an M.A. (1989) in Anthropology from the University of Memphis, and a B.A. (1984) in Anthropology/Sociology from Westminster College, Fulton, Missouri. As a native of Little Rock, “Drew” has a keen interest in Arkansas archaeology, and is a life member of the Arkansas Archeological Society. Mr. Buchner is certified by the Register of Professional Archaeologists (RPA ID# 12420) and is a current member of various professional organizations, including the Society for American Archaeology, the Society for Historical Archaeology, the Society for Industrial Archaeology, the Southeastern Archaeological Conference, and the Caddo Conference. Mr. Buchner has participated in dozens of survey and excavations projects in Arkansas, and he has extensive field experience across the Southeastern U.S. During his career, he has authored and/or co-authored over 500 contract reports, 32 conference papers, and has published 15 articles or research papers, including a monograph in the Arkansas Archeological Survey’s Research Series.
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June 6, 2014 The Department of Mr. Tom Fox Arkansas Project Manager Heritage FTN Associates, Ltd. 3 Innwood Circle, Suite 220 Little Rock, Arkansas 72211-2449
Mike Beebe Re: Mississippi County - General Governor Section 106 Review - USDA-RUS Martha Miller Response for Cultural Resources Survey ofthe Proposed Driver Director Substation Easement A, Mississippi County, Arkansas. Panamerican Report No. 33230 Arkansas Arts Council AHPP Tracking Number 90219
Dear Mr. Fox: Arkansas Natural Heritage Commission The staff ofthe Arkansas Historic Preservation Program (AHPP) has reviewed the above referenced draft report for the proposed undeliaking. We think the Delta Cultural Center fieldwork has been both well executed and documented. We concur that no known historic properties will be affected by the proposed undertaking. Historic Arkansas Museum Please refer to the AHPP Tracking Number listed above in all correspondence. Mosaic Templars Ifyou have any questions, please contact Wm. Lane Shields of my staff at Cultural Center (501) 324-9784.
Old State House Museum Sincerely,
Frances McSwain Deputy State Historic Preservation Officer Arkansas Historic Preservation Program cc: Mr. Everett Bandy, Quapaw Tribe of Oklahoma Ms. Rebecca Brave, Osage Nation 323 Center Street, Suite 1500 Mr. C. Andrew Buchner, Panamerican Little Rock, AR 7220 I Dr. Ann Early, Arkansas Archeological Survey (501) 324-9880 fax: (501) 324-9184 tdd: (50 I) 324-9811 e-mail: infol{l,arkansaspreservation.org website:
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