ML11262A343

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E-mail with Attachment from C. Eccleston, NRR, to J. Rikhoff, NRR, on Updated Version of Ej Section
ML11262A343
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 08/09/2010
From: Eccleston C
Office of Nuclear Reactor Regulation
To: Jeffrey Rikhoff
Office of Nuclear Reactor Regulation
References
FOIA/PA-2011-0113
Download: ML11262A343 (11)


Text

CA* /

Rikhoff, Jeffrey From: *Ecclefts-n__Charles Sent: Mo-nday, August 09, 2010 11:08 AM To: -Rik-h-ff7Jeffrey

Subject:

Updated version of EJ section Attachments: 4.9.7 Environmental Justice (062910).docx

Jeff, This is an updated version of the EJ section. Use this version in lieu of version I sent earlier.

&4v",4 q. sEdat, Charles H. Eccleston Nuclear Reactor Regulation Licensing Renewal, Project Manager 301.415.8537 charles.eccleston(nrc.gov 1.

4.9.7 Environmental Justice Under Executive Order (EO) 12898 (59 FR 7629), Federal agencies are responsible for identifying and addressing, as appropriate, potential disproportionately high and adverse human health and environmental impacts on minority and low-income populations. In 2004, the Commission issued a Policy Statement on the Treatment of EnvironmentalJustice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which states, "The Commission is committed to the general goals set forth in EO 12898, and strives to meet those goals as part of its NEPA review process."

The Council of Environmental Quality (CEQ) provides the following information in Environmental Justice. Guidance Under the NationalEnvironmental Policy Act (1997):

Disproportionately High and Adverse Human Health Effects.

Adverse health effects are measured in risks and rates that could result in latent cancer fatalities, as well as other fatal or nonfatal adverse impacts on human health. Adverse health effects may include bodily impairment, infirmity, illness, or death.

Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant (as defined by the National Environmental Policy Act [NEPA]) and appreciably exceeds the risk or exposure rate for the general population or for another appropriate comparison group (CEQ, 1997).

Disproportionately High and Adverse Environmental Effects.

A disproportionately high environmental impact that is significant (as defined by NEPA) refers to an impact or risk of an impact on the natural or physical environment in a low-income or minority community that appreciably exceeds the environmental impact on the larger community. Such effects may include ecological, cultural, human health, economic, or social impacts. An adverse environmental impact is an impact that is determined to be both harmful and significant (as defined by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that uniquely affect geographically dislocated or dispersed minority or low-income populations or American Indian tribes are considered (CEQ, 1997).

The environmental justice analysis assesses the potential for disproportionately high and adverse human health or environmental effects on minority and low-income populations that could result from the operation of Salem and HCGS during the renewal term. In assessing the impacts, the following CEQ (1997) definitions of minority individuals and populations and low-income population were used:

Minority individuals.

Individuals who identify themselves as members of the following population groups:

Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or two or more races, meaning individuals who identified themselves on a Census form as being a member of two or more races, for example, Hispanic and Asian.

Minority populations.

Minority populations are identified when (1) the minority population of an affected area exceeds 50 percent or (2) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis.

Low-income population.

Low-income populations in an affected area are identified with the annual statistical poverty thresholds from the Census Bureau's Current Population Reports, Series P60, on Income and Poverty.

The NRC published an environmental justice policy in 2004. This policy stated that for licensing and regulatory actions pertaining to nuclear power plants, a radius of 50 mi should be used to determine potential impacts to environmental justice populations. This policy retained the Office of Nuclear Reactor Regulations' previous radius determination (69 FR 52040). The geographic area included in this environmental justice analysis consists of those census block groups with all or part of their area within a 50-mi radius of Salem and HCGS.

Minority Population in 2000 There are a total of 23 counties in the 50-mi radius surrounding Salem and HCGS. Of these, seven are in New Jersey (Salem, Cumberland, Cape May, Atlantic, Gloucester, Camden and Burlington), three are in Delaware (New Castle, Kent and Sussex), six are in Pennsylvania (Philadelphia, Montgomery, Delaware, Chester, Lancaster, and York) and seven are in Maryland (Harford, Cecil, Baltimore, Kent, Queen Anne's, Caroline and Talbot).

According to 2000 Census data, 35.1 percent of the population (1,872,783 persons) residing within an 50-mi radius of Salem and HCGS identified themselves as minority individuals. The largest minority group was Black or African American (1,213,122 persons or 19.5 percent),

followed by Asian (190,983 persons or 3.1 percent). A total of 341,886 persons (5.5 percent) identified themselves as Hispanic or Latino ethnicity (USCB, 2003).

Of the (4,579) census block groups located wholly or partly within the 50-mi radius of Salem and HCGS, 1,860 block groups were reported in the 2000 Census as having high density minority population percentages that exceeded the 50-mi radius average (USCB, 2000a). The largest minority group was Black or African American, with 1284 block groups that exceed the 50-mi radius average. These block groups are primarily located in Philadelphia County, Pennsylvania.

There were 24 block groups with Asian, 94 block groups with Some Other Race, and 1 block group with Two or More Races minority classifications that exceeded the 50-mi radius average.

A total of 202 block groups exceeded the 50-mi radius average for Hispanic or Latino ethnicity.

The high density minority population nearest to Salem and HCGS is centered in the City of Salem, New Jersey.

Based on 2000 Census data, Figure 4-1 shows the block groups with high density minority populations within an 80-km (50-mi) radius of Salem and HCGS.

Low-Income Population in 2000 According to 2000 Census data, 119,283 families (2.2 percent) and 620,903 individuals (11.6 percent) residing within a 50-mi radius of Salem and HCGS were identified as living below the Federal poverty threshold in 1999 (USCB, 2003). (The 1999 Federal poverty threshold was

$17,029 for a family of four.) The USCB reported 6.3 percent of families and 8.5 percent of individuals in New Jersey, 6.5 percent of families and 9.2 percent of individuals in Delaware, 7.8 percent of families and 11.0 percent of individuals in Pennsylvania, and 6.1 percent of families and 8.5 percent of individuals in Maryland living below the Federal poverty threshold in 1999 (USCB, 2000a; USCB, 2000b).

Census block groups were considered high density low-income block groups if the percentage of families and individuals living below the Federal poverty threshold exceeded the 50-mi radius average. Based on 2000 Census data, there were 1,778 block groups within a 50-mi radius of Salem and HCGS that are considered high density low-income block groups. The majority of census block groups with low-income populations were located in Philadelphia County, Pennsylvania. The high density low-income population nearest to Salem and HCGS is located in Lower Alloways Creek Township in Salem County, New Jersey. Figure 4-2 shows high density low-income census block groups within a 50-mi radius of Salem and HCGS.

Analysis of Impacts The discussion above indentifies the minority and low-income populations who reside within a 50-mi radius of Salem and HCGS. This area is consistent with the impact analysis for public and occupational health and safety, which similarly focuses on populations within a 50-mi radius of the facilities. Based on the analysis of impacts for all resource areas presented in this draft SEIS, it was determined that there would be no significant adverse health impacts on members of the public and, therefore, there would be no disproportionate and adverse impacts experienced by minority or low-income populations within the area of interest from the continued operation of Salem and HCGS during the license renewal period. Similarly, given the potential environmental effects of continued operation on the physical environment (water, air, aquatic and terrestrial resources) and socioeconomic conditions, there would be no disproportionately high and adverse impacts on minority and low-income populations because of adverse environmental effects.

Miles 0 5 10 20 30 40 Leend

  • Salem and Hope Creek Generating Stations

-- 80-km (50-mi) radius Census 2000 block groups with high density minority populations Source: USCB 2003 Figure 4-1. Census 2000 minority block groups within a 50-mi radius of Salem and HCGS

Miles 0 5 10 20 30 40 Legend

  • Salem and Hope Creek Generating Stations

-- 50-km (50-mi) radius Census 2000 block groups with high density low-income populations Source: USCB 2003 Figure 4-2. Census 2000 low-income block groups within a 50-mi radius of Salem and HCGS

NRC also analyzed the risk of radiological exposure through the consumption patterns of special pathway receptors, including subsistence consumption of fish and wildlife, native vegetation, surface waters, sediments, and local produce; absorption of contaminants in sediments through the skin; and inhalation of plant materials. The special pathway receptors analysis, discussed below, is important to the environmental justice analysis because consumption patterns may reflect the traditional or cultural practices of minority and low-income populations in the area.

Subsistence Consumption of Fish and Wildlife Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and appropriate, to collect and analyze information on the consumption patterns of populations that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these consumption patterns to the public. In this draft SEIS, NRC considered whether there were any means for minority or low-income populations to be disproportionately affected by examining impacts to American Indian, Hispanic, and other traditional lifestyle special pathway receptors.

Special pathways that took into account the levels of contaminants in native vegetation, crops, soils and sediments, surface water, fish, and game animals on or near Salem and HCGS were considered.

PSEG has an ongoing comprehensive Radiological Environmental Monitoring Program (REMP) at Salem and HCGS to assess the impact of site operations on the environment. To assess the impact of the facilities on the environment, the radiological monitoring program at Salem and HCGS uses indicator-control sampling. Samples are collected at nearby indicator locations downwind and downstream from the facilities and at distant control locations upwind and upstream from the facilities. Control locations are usually 9 to 18 miles away from the facilities.

A facility effect would be indicated ifthe radiation level at an indicator location was significantly larger than at the control location. The difference would also have to be greater than could be accounted for by typical fluctuations in radiation levels arising from other naturally-occurring sources (PSEG, 2010).

Samples are collected from the aquatic and terrestrial pathways in the vicinity of Salem and HCGS. The aquatic pathways include fish, Delaware Bay and River (Delaware estuary) surface water, groundwater, and sediment. The terrestrial pathways include airborne particulates, milk, and food product garden (leaf) vegetation, and direct radiation. During 2009, analyses performed on collected samples of environmental media showed no significant or measurable radiological impact from Salem and HCGS site operations (PSEG, 2010).

Aquatic sampling in the vicinity of Salem and HCGS consists of semi-annual upstream and downstream collections of fish, blue crabs, and bottom sediments. Delaware estuary surface water is collected monthly from upstream and downstream locations. All samples are analyzed for gamma-emitting isotopes. Surface water is additionally analyzed for gross beta and tritium.

Drinking water is collected daily from the City of Salem Water and Sewer Department water sources (surface water and groundwater) and composited in a monthly sample. Monthly composites are analyzed for gross alpha, gross beta, tritium, iodine-1 31, and gamma- emitting isotopes. Well water is collected monthly from one nearby farm's well, located upgradient from

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Salem and HCGS, and is analyzed for gross alpha, gross beta, tritium, and gamma emitters (PSEG, 2010).

Fish were sampled twice at three locations in 2009 and blue crabs were collected twice at two locations. In the fish and blue crab samples, only naturally-occurring radionuclides were detected, at concentrations less than the pre-operational levels. There was no indication of an effect from Salem and HCGS operations (PSEG, 2010).

Sediment samples were collected twice from six indicator stations and one control station.

Naturally occurring potassium-40, thorium-232, and radium-226 and radium-228 (RA-NAT) were found at all indicator and control stations, and naturally occurring beryllium-7 was detected at one indicator station; all of these detections were less than pre-operational concentrations.

Cesium 137 was detected in two indicator samples, and no control samples. The positive samples showed lower levels than pre-operational samples. Manganese-54 was detected at one indicator station. There are no pre-operational data for this radionuclide; however, the average concentration of all positive sample results from 1988 to 2008 is slightly higher than the 2009 detected concentration. There was no indication of an effect from operation of the Salem and HCGS facilities (PSEG, 2010).

Surface water samples collected monthly at four indicator stations and one control station revealed trace amounts of tritium (slightly above the minimum detectable concentration range) at the indicator stations and none at the control locations. Gross beta activity was found at both indicator and control locations at levels similar to the pre-operational samples. Naturally occurring potassium-40, thorium-232 and RA-NAT were found in both indicator and control samples. Two potable water samples yielded gross alpha activity below per-operational levels, all samples had gross beta activity below pre-operational levels, no tritium or iodine-131 was detected, and naturally occurring potassium-40, thorium-232 and RA-NAT were detected at levels comparable to previous years sampled. Well water (groundwater) samples had no measureable amounts of tritium, and trace amounts of gross alpha activity. Beta activity levels were lower than the pre-operational data. Potassium-40 and RA-NAT were detected in well water at levels similar to pre-operational levels. There was no indication of an effect from operation of the Salem and HCGS facilities (PSEG, 2010).

Vegetables and fodder crops are collected annually at harvest and are analyzed for gamma-emitting isotopes. Vegetable crops contained only naturally-occurring radionuclides. Potassium 40 was detected at similar levels at both indicator and control locations, at concentrations below pre-operational levels. RA-NAT was not detected in any of the indicator samples, but was detected at two of the control locations. Beryllium 7 was detected in four of the indicator samples, at concentrations comparable to previous years sampled. Fodder crops contained beryllium-7 and potassium-40 at similar concentrations at both indicator and control locations.

Milk samples were collected semi-monthly from three indicator farms and one control farm when cows were at pasture, and monthly when cows were not at pasture, and analyzed for iodine-131 and gamma-emitting isotopes. lodine-131 was not detected in any of the samples, while potassium-40 and RA-NAT were detected at naturally levels less than those found in pre-

operational samples. There was no indication of an effect from operation of the Salem and HCGS facilities (PSEG, 2010).

Air quality samples were collected weekly from six locations. These samples were analyzed for gross beta and iodine-1 31 as a weekly composite and for gamma-emitting isotopes on a quarterly composite basis. Air particulate samples had similar results for both indicator and control locations, and were also comparable to pre-operational levels. Air iodine was not detected. There was no indication of an effect from operation of the Salem and HCGS facilities (PSEG, 2010).

Previously, PSEG had also tested muskrat populations in the area. Muskrats are trapped and consumed by the local population (PSEG, 2006). As of 2006, no muskrat samples have been available for testing as the trappers who were supplying PSEG with samples were no longer operating (PSEG, 2007). The last muskrat data collected in 2005 resulted in only one sample with detectable levels of potassium-40; no other radionuclides were found (PSEG, 2006).

The results of the 2009 REMP (and consideration of the 2005 REMP muskrat data) demonstrate that the routine operation at Salem and HCGS had no significant or measurable radiological impact on the environment. No elevated radiation levels were detected in the offsite environment as a result of plant operations and the storage of radioactive waste. The results of the REMP continue to demonstrate that the operation of Salem and HCGS did not result in a significant measurable dose to a member of the general population or adversely impact the environment as a result of radiological effluents. The REMP continues to demonstrate that the dose to a member of the public from the operation of Salem and HCGS remains significantly below the federally required dose limits specified in 10 CFR 20, 10 CFR 72, and 40 CFR 190.

The New Jersey Department of Environmental Protection (NJDEP) Bureau of Nuclear Engineering (BNE) also samples the area around Salem and HCGS for radionuclides that could be elevated due to the presence of the two facilities. Ten stations within the vicinity are monitored with thermoluminescent dosimetry. During 2008, all station results were comparable to previous years. Air samples were taken at three locations, with results not significantly different from ambient background levels. Surface water was collected from the Delaware River at the onsite surface water inlet building discharge and at a location on the west bank of the river upstream from Salem's effluent discharge; potable well water samples were taken on site.

No gamma emitting isotopes or tritium were found in these samples. Additionally, NJDEP BNE monitors the groundwater on site at Artificial Island in conjunction with the remedial action being undertaken by PSEG to address tritium contamination detected in shallow groundwater near Salem Unit 1. There is no evidence that the tritium has reached any areas outside of the PSEG property. Analyses of fish, shellfish, vegetation and sediment samples detected only potassium-40, a naturally-occurring radionuclide. Trace amounts of strontium-90 were found in all milk samples, at levels consistent with what is expected as a result of nuclear weapons testing in the 1950s and 1960s (NJDEP, 2009).

Based on recent monitoring results, concentrations of contaminants in native leafy vegetation, sediments, surface water, and fish and game animals in areas surrounding Salem and HCGS have been quite low. Consequently, no disproportionately high and adverse human health

impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of fish and wildlife.

References:

59 FR 7629. "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations." Federal Register. February 16, 1994.

69 FR 52040. "Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions." Federal Register. August 24, 2004.

CEQ (Council on Environmental Quality) 1997. Environmental Justice: Guidance Under the NationalEnvironmental Policy Act. Executive Order of the President, Washington.

DC.

NJDEP (New Jersey Department of Environmental Protection). 2009. Environmental Surveillance and Monitoring Report For the Environs of New Jersey's Nuclear Power Generating Stations. January 1, 2008 - December 31, 2008. Bureau of Nuclear Engineering.

Accessed May 17, 2010 at www.state.nj.us/dep/rpp.

PSEG (PSEG Nuclear, LLC) 2006. 2005 Annual Radiological Environmental Operating Report.

January 1 to December 31, 2005. Radiological Environmental Monitoring Program for Salem Generating Station, Unit 1: Docket No. 50-272; Salem Generating Station, Unit 2: Docket No.

50-311; Hope Creek Generating Station: Docket No. 50-354.

PSEG 2007. 2006 Annual Radiological Environmental Operating Report. January 1 to December 31, 2006. Radiological Environmental Monitoring Program for Salem Generating Station, Unit 1: Docket No. 50-272; Salem Generating Station, Unit 2: Docket No. 50-311; Hope Creek Generating Station: Docket No. 50-354.

PSEG 2009a. Salem Nuclear Generating Station, Units 1 and 2, License Renewal Application, Appendix E - Applicant's Environmental Report - Operating License Renewal Stage. Lower Alloways Creek Township, New Jersey. August, 2009.

PSEG 2009b. Hope Creek Generating Station, License Renewal Application, Appendix E -

Applicant's Environmental Report - Operating License Renewal Stage. Lower Alloways Creek Township, New Jersey. August, 2009.

PSEG 2010. 2009 Annual Radiological Environmental Operating Report. January 1 to December 31, 2009. Radiological Environmental Monitoring Program for Salem Generating Station, Unit 1: Docket No. 50-272; Salem Generating Station, Unit 2: Docket No. 50-311; Hope Creek Generating Station: Docket No. 50-354.

Tetra Tech NUS, Inc. 2010. Subsistence Living in the Vicinity of Salem and Hope Creek Nuclear Generating Stations. Prepared for PSEG Nuclear, LLC. Nicole Hill, Tetra Tech NUS, Inc.,

Aiken, SC. February 18, 2010.

... ., I-USCB (U.S. Census Bureau) 2000a. "P87. Poverty Status in 1999 by Age [17] - Universe:

Population for whom poverty status is determined. Data Set: Census 2000 Summary File 3 (SF

3) Sample Data." Accessed June 28, 2010 at http://factfinder.census.qov/.

USCB 2000b. "P90. Poverty Status in 1999 of Families by Family Type by Presence of Related Children under 18 Years of Age by Age of Related Children [41] - Universe: Families. Data Set:

Census 2000 Summary File 3 (SF 3) Sample Data." Accessed June 28, 2010 at http://factfinder. census ..qov /.

USCB 2003. LandView 6 - Census 2000 Tables "P-4. Hispanic or Latino, and Not Hispanic or Latino by Race [73] - Total population. Data Set: Census 2000 Summary File 1 (SF 1) 100-Percent Data"; "P87. Poverty Status in 1999 by Age [17] - Universe: Population for whom poverty status is determined. Data Set: Census 2000 Summary File 3 (SF 3) Sample Data"; and "P90. Poverty Status in 1999 of Families by Family Type by Presence of Related Children under 18 Years of Age by Age of Related Children [41] - Universe: Families. Data Set: Census 2000 Summary File 3 (SF 3) Sample Data" for Census Block Groups within an 80-km (50-mi) radius of Salem and HCGS. December.