ML062610234
| ML062610234 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/07/2006 |
| From: | Scro R Barnegat Bay National Estuary Program |
| To: | Office of Administration |
| References | |
| %dam200612, 71FR34969 00009 | |
| Download: ML062610234 (6) | |
Text
Page 1 of 2 Doris Mendiola - Comment on Oyster Creek Nuclear Generating Station GEIS From:
To:
Date:
Subject:
"Robert Scro" <bscro@ocean.edu>
<OysterCreekEIS @nrc.gov.>
09/07/2006 10:22 AM Comment on Oyster Creek Nuclear Generating Station GEIS Dr. Robert Scro, Director Bamegat Bay National Estuary Program Ocean County College College Dr., P.O. Box 2001 Toms River, NJ 08754-2001 732.255.0472 J7)
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Attention: Comment on Generic Environmental Impact Statement (GELS) for the Oyster Creek Nuclear Generating Station (OCNGS)
Dear Sir:
As was brought to your attention in our letter to you dated November 15, 2005, the Bamegat Bay National Estuary Program (BBNEP) is the principal steward of the natural resources of the Barnegat Bay/Little Egg Harbor estuary. It is composed of federal, state, county, municipal, academic, business, and citizen organizations committed to restore, maintain, protect, and enhance this "estuary of national significance".
The BBNEP is herein submitting comment on the Nuclear Regulatory Commission's (NRC) draft supplement to the Generic Environmental Impact Statement (GEIS) for the Oyster Creek Nuclear Generating Station (OCNGS).
The GEIS contained misconstrued information based on an extensive review of published information (academic journals or other sources) that led to a finding by NRC staff of no significant impacts on aquatic populations in the bay by the OCNGS. In fact, this is not the case.
This information (found on pages 4-15, 4-21, and 4-51 of the GEIS), contains citations from Kennish, M. J.
2001. State of the Estuary and Watershed: An Overview. Journal of Coastal Research, Special Issue 32, pp. 243-273.
The information from the aforementioned publication does conclude that there is no significant impact of the OCNGS on Barnegat Bay aquatic populations, however it is specifically referring to the results of impingement, entrainment, and thermal discharge effects determined for the 1975-1977 period, the only period when impingement and entrainment data were collected concurrently with data population surveys in the bay.
Dr. Kennish contested the use of the these quotes from (pages 4-15, 4-21, and 4-51 of the GEIS) at the public hearing for the GEIS held on Wednesday, July 12, 2006; in Toms River, New Jersey. Therefore, the GEIS has based its conclusions on significantly out-of-date and out-of-context information, rendering their conclusions on OCNGS's impacts on the aquatic populations of Barnegat Bay irrelevant.
During the past 35 years of OCNGS operation, significant concerns have existed regarding impingement, entrainment, and thermal impacts on estuarine and marine life.
As a result, the Science and Technical Advisory Committee (STAC) of the BBNEP convened a meeting on November 1, 2005, and developed the following recommendations for the NRC regarding the OCNGS.
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Page 2 of 2 An independent, scientific body (similar to the National Academy of Science) must be assembled to coordinate and oversee surveys and studies on the impacts of the OCNGS on the Barnegat Bay/Little Egg Harbor estuary.
" There have been very few peer-reviewed studies during the past 30 years of the impact of OCNGS on the population of aquatic communities in central Barnegat Bay. Additional studies must be conducted in the Barnegat Bay/Little Egg Harbor to accurately assess these impacts and they must be done concurrently with entrainment and impingement studies.
The NRC mtust require the OCNGS to focus on remediation of its direct impacts on estuarine and marine organisms in the Barnegat Bay/Little Egg Harbor estuary.
The use of wetlands restoration as a mitigation measure must not be implemented in place of remediation efforts targeting bay populations and communities of organisms.
The BBNEP recommends strongly that the renewal permit include a condition that charges the BBNEP with the role of the independent scientific body whose purpose is to coordinate research efforts in the Barnegat Bay relating to the effects of the OCNGS. The BBNEP's Comprehensive Conservation and Management Plan (CCMP) recognizes the need for such an entity. Action Item 5.15 of the CCMP charges the BBNEP with establishing this technical group for the examination and coordination of data in order to understand OCNGS's role in the overall ecological health of the bay.
Program partners agree that the BBNEP can and should have the lead role in coordinating and overseeing much-needed surveys and studies regarding OCNGS's effects on the Barnegat Bay ecosystem.
In conclusion, the position of the BBNEP is that regardless of the option pursued by the NRC regarding Oyster Creek's license renewal, without question, the OCNGS absolutely must be required to conduct detailed, comprehensive studies of the communities of bay organisms to determine what the overall impact of the power plant is on Barnegat Bay.
Sincerely, Dr. Robert Scro Director Bamegat Bay National Estuary Program file://C:\\temp\\GW }00001.HTM 09/11/2006
c:\\ternp\\GW 1OOOO1~TMP Page 1 I c:\\temp\\GW)00001.TMP Page 1 1.
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OysterCreekEIS Comment on Oyster Creek Nuclear Generating Station GEIS 09/07/2006 10:21:58 AM "Robert Scro" <bscro@ocean.edu>
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September 6, 2006 Chief, Rules and Directives Branch Division of Administrative Services Mailstop T-6D59 US Nuclear Regulatory Commission Washington D.C., 20555 Attention: Comment on Generic Environmental Impact Statement (GELS) for the Oyster Creek Nuclear Generating Station (OCNGS)
Dear Sir:
As was brought to your attention in our letter to you dated November 1.5, 2005, the Barnegat Bay National Estuary Program (BBNEP) is the principal steward of the natural resources of the Bamegat Bay/Little Egg Harbor estuary. It is composed of federal, state, county, municipal, academic, business, and citizen organizations committed to restore, maintain, protect, and enhance this "estuary of national significance".
The BBNEP is herein submitting comment on the Nuclear Regulatory Commission's (NRC) draft supplement to the Generic Environmental Impact Statement (GEIS) for the Oyster Creek Nuclear Generating Station (OCNGS). The GElS contained misconstrued information based on an extensive review of published information (academic journals or other sources) that led to a finding by NRC staff of no significant impacts on aquatic populations in the bay by the OCNGS. In fact, this is not the case.
This information (found on pages 4-15, 4-21, and 4-51 of the GELS), contains citations from Kennish, M. J. 2001. State of the Estuary and Watershed: An Overview.
Jounial of Coastal Research, Special Issue 32, pp. 243-273. The information from the aforementioned publication, does conclude that there is no significant impact of the OCNGS on Barnegat Bay aquatic populations, however it is specifically referring to the results of impingement, entrainment, and thermal discharge effects determined for the 1975-1977 period, the only period when impingement and entrainment data were collected concurrently with data population surveys in the bay.
Dr. Kennish contested the use of the these quotes from (pages 4-15, 4-21, and 4-51 of the GELS) at the public hearing for the GElS held on Wednesday, July 12, 2006, in Toms River, New Jersey. Therefore, the GElS has based its conclusions on significantly out-of-date and out-of-context information, rendering their conclusions on OCNGS's impacts on the aquatic populations of Barnegat Bay irrelevant.
During the past 35 years of OCNGS operation, significant concerns have existed regarding impingement, entrainment, and thermal impacts on estuarine and marine life.
As a result, the Science and Technical Advisory Committee (STAC) of the BBNEP convened a meeting on November 1, 2005, and developed the following recommendations for the NRC regarding the OCNGS.
" An independent, scientific body (similar to the National Academy of Science) must be assembled to coordinate and oversee surveys and studies on the impacts of the OCNGS on the Barnegat Bay/Little Egg Harbor estuary.
" There have been very few peer-reviewed studies during the past 30 years of the impact of OCNGS on the population of aquatic communities in central Barnegat Bay. Additional studies must be conducted in the Barnegat Bay/Little Egg Harbor to accurately assess these impacts and they must be done concurrently with entrainment and impingement studies.
" The NRC must require the OCNGS to focus on remediation of its direct impacts on estuarine and marine organisms in the Barnegat Bay/Little Egg Harbor estuary.
" The use of wetlands restoration as a mitigation measure must not be
- implemented in place of remediation efforts targeting bay populations and communities of organisms.
The BBNEP recommends strongly that the renewal permit include a condition that charges the BBNEP with the role of the independent scientific body whose purpose is to coordinate research efforts in the Barnegat Bay relating to the effects of the OCNGS. The BBNEP's Comprehensive Conservation and Management Plan (CCMP) recognizes the need for such an entity. Action Item 5.15 of the CCMP charges the BBNEP with establishing this technical group for the examination and coordination of data in order to understand OCNGS's role in the overall ecological health of the bay.
Program partners agree that the BBNEP can and should have the lead role in coordinating and overseeing much-needed surveys and studies regarding OCNGS's effects on the Barnegat Bay ecosystem.
In conclusion, the position of the BBNEP is that regardless of the option pursued by the NRC regarding Oyster Creek's license renewal, without question, the OCNGS absolutely must be required to conduct detailed, comprehensive studies of the communities of bay organisms to determine what the overall impact of the power plant is on Barnegat Bay.
BARNEGAT NATIONAL ESTUARY PROGRAM
Bob Scro, Director RUTGERS UNIVERSITY, INSTITUTE OF MARINE AND COASTAL SCIENCES, JACQUES COUSTEAU NATIONAL ESTUARINE RESEARCH RESERVE Michael DeLuca Co-Chair, STAC cc: Michael Masnik, Senior Project Manager, NRC Congressman James Saxton BBNEP Policy Committee Members:
Lisa P. Jackson, NJ DEP Commissioner Tom Fote, Citizen Liaison to the BBNEP The Hon. David Siddons, Island Heights Mayor Allen J. Steinberg, USEPA Region II Administrator Joseph Vicari, Ocean County Freeholder