DEP PROPOSES RENEWAL OF PSEG DISCHARGE PERMIT
The state Department of Environmental Protection (DEP) is proposing
to renew PSEG's permit to use water from the Delaware River to operate
the cooling system at the Salem Nuclear Generating Station.
The current five-year permit issued in July 1994 remains in effect while
the DEP reviews and seeks public comment on the 36-volume permit application
and 137 volumes of attached reference material, submitted in March 1999.
DEP hired an independent consultant, ESSA Technologies of Toronto, to
assist in analyzing parts of the application. There will be two public
hearings on the proposed permit held: Jan. 23 at Pennsville Memorial High
School from 3 - 5 p.m. and again from 7 - 10 p.m., and on Jan. 25 at Cumberland
County College in Vineland from 2 - 5 p.m. and from 7 - 10 p.m.
The permit issued in 1994 included several conditions to reduce fish
mortality and increase fish propagation. Some were required under the
Clean Water Act and others were voluntarily proposed by PSEG. These conditions
included improved intake screens and fish buckets to reduce the number
of fish entering the plant, a limit on intake flow, the study of sounding
devices to deter fish from entering the intakes, installation of fish
ladders, and a major wetlands restoration project, considered the largest
privately funded wetlands restoration project in the nation, to enhance
habitat for fish propagation.
The modified intake screens have smaller and less injurious openings
that are more effective in reducing fish mortality. Specially designed
buckets also help reduce fish mortality by suspending the fish in a curved
lip that reduces injury, before the fish are returned to the estuary via
the fish return system.
"After very careful analysis, we have determined that at this time the
applicant complies with the terms and special conditions in its existing
permit," said DEP Commissioner Bob Shinn. "However, we are proposing additional
requirements as a contingency for renewal. Our main objectives are to
minimize losses associated with the water intakes and to maximize opportunities
to increase fish populations in the Delaware River estuary to further
offset these losses."
New conditions in the proposed permit renewal include a requirement to
study the use of light in combination with the sound system, to deter
the fish from entering the facility. The use of sound alone has not proven
to be effective on all species, so a combination of deterrents is being
proposed, as the best technology available, according to DEP Assistant
Commissioner Dennis Hart. The U.S. Fish & Wildlife Service provided comments
on the March permit application, recommending that the use of sound be
In addition, the proposed permit would require PSEG to continue its
wetlands restoration project, continue the review process provided by
the estuary enhancement oversight committee, and refine its biological
monitoring program to obtain more accurate data on the plant's impact
on fish populations and the effectiveness of the fish ladders and wetlands
enhancements. The company also must refine its plant-related sampling
and analyses including loss estimates and an updated study of the hydrodynamics
at the intakes. DEP also is requiring enhancements to the fish return
system so that the water is less turbulent and therefore less stressful
to the fish.
The existing permit issued in July 1994 requires the company to restore,
enhance or preserve 14,500 acres of wetlands in and around the Delaware
estuary to improve habitat for fish propagation. It specifically requires
the company to purchase a minimum of 8,000 acres of degraded wetlands
plus 6,000 acres of upland buffers (or an additional 2,000 acres of degraded
wetlands). The required work is on-going at eight sites: Alloways Creek,
Cohansey River, Maurice River Twp., Commercial Twp., Dennis Twp., the
Bayside Tract, and two sites in Delaware - Cedar Swamp and The Rocks.
The restoration projects have 12 years to become successful, and so far
all are on track with acceptable levels of vegetative growth recorded
and verified in aerial photos and field inspections. Four of the eight
sites were dominated by phragmites, and the reduction of phragmites is
progressing at all four sites. Phragmites is a tall, widespread, marsh
plant that chokes out other plant life and raises ground elevation thus
reducing fish habitat, and productivity. Phragmities reduction is progressing
through the use of various eradication methods, including a limited use
of herbicides. However, phragmites reduction and herbicide application
are not the subject of this draft permit.
"If it becomes apparent that phragmities reduction cannot occur without
repeated pesticide applications, DEP will require PSEG to substitute other
wetlands or uplands acreage to meet its permit requirements," said Hart.
"Wetlands restoration is an emerging science, and we greatly appreciate
the participation of numerous experts who are assisting with the analysis
of this, the nation's largest privately funded wetlands enhancement project."
Advisory committee members for this project include representatives from
the Scripps Institute of Oceanography, Louisiana University Marine Consortium,
Stevens Institute of Technology, Chesapeake Biological Laboratory Center,
University of Georgia Marine Institute, National Marine Fisheries Service,
U.S. Fish &Wildlife Service, Delaware Estuary Program, State of Delaware
and U.S. Environmental Protection Agency (EPA). Biological monitoring
data on fish populations in the Delaware are obtained in accordance with
a DEP-approved workplan. The biological monitoring data collected by PSEG
compliments the long-term and on-going data collected by the State of
Delaware and DEP. This data was used in analyzing the permit application.
The analyses show the population trends for most species studied are increasing.
ESSA Technnologies, the firm assisting DEP in analyzing portions of
the voluminous application, is an international firm with more than 20
years of experience in managing and evaluating environmental and natural
resource projects. While this is not the first time DEP has retained an
independent consultant to evaluate a New Jersey Pollution Discharge Elimination
System (NJPDES) permit, it is the largest NJPDES permit application ever
received by the department. ESSA will be paid approximately $300,000 with
funds from an assessment added to PSEG's permit fee.
In its 1994 permit, DEP determined that retrofitting the facility with
new cooling towers would have involved a complicated and wide-scale construction
project entailing substantial costs disproportionate to the environmental
benefit. While the Clean Water Act does not call for this type of economic
analysis, there was legal precedent for such an analysis, and EPA concurred
with DEP in this matter. In providing comments on the present permit application,
the U.S. Fish & Wildlife Service in June 2000 agreed it may be prudent
to concentrate on measures that fully minimize and mitigate adverse environmental
impacts, with the existing plant structure, given the life expectancy
of the plant, the costs associated with retro-fitting, and the special
conditions and other measures already implemented.
The proposed permit would allow the withdrawal of 3.024 billion gallons
of water a day, as a monthly average, to cool the reactors, which represents
no change from the existing permit conditions. It should be noted that
at no time does the cooling water come into direct contact with the two
The permit application is available for public review at the DEP headquarters
in Trenton by calling 609-292-4860. The proposed permit will be available
for review at the Salem Free Public Library, the Cumberland County Library,
the Newark Library and DEP headquarters.