ML11263A137

E-mail W/Attachment from D. Beissel, NRR to I. King, on Salem/Hope Creek Scoping Comments

ML11263A137
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/04/2011
From:	Beissel D Division of License Renewal
To:	King I Division of License Renewal
References
FOIA/PA-2011-0113
Download: ML11263A137 (120)

Text

King, Ikeda From:

-Beissel, Dennis Sent:

Monday, April 04, 2011 1:58 PM To:

King, Ikeda

Subject:

FW: ACTION: Salem/Hope Creek scoping comments Attachments:

Salem-Hope Creek scoping summary report.docx From: Susco, Jeremy Sent: Monday, August 16, 2010 1:58 PM To: Balsam, Briana; BeBault, April; Beissel, Dennis; Bulavinetz, Richard; Klementowicz, Stephen; Logan, Dennis; Moser, Michelle; Rautzen, William; Rikhoff, Jeffrey; Travers, Allison; Ghosh, Tina; Gallucci, Ray Cc: Imboden, Andy; Eccleston, Charles; Imboden, Andy

Subject:

ACTION: Salem/Hope Creek scoping comments I am helping Charles finish up with the Salem/Hope Creek scoping summary report and Appendix A to the SEIS. As you are reviewing your sections of the draft SEIS, please make sure that following items are addressed (as appropriate) in your section of the SEIS. I have attached the scoping summary report that contains all the comments and response broken down by area.

1) Aquatic ecology: multiple comments related to the quality and quantity (lack thereof) of S/HC's data, effects of the estuary enhancement program

2) Hydrology/Postulated accidents: plants are sited on Artificial Island

3) Socioeconomics: many comments related to the plant's effect on the area through taxes, education, philanthropy, and employment Thanks and let me know if you have any questions, Jeremy Jeremy Susco Project Manager U.S. Nuclear Regulatory Commission (301) 415-2927 ieremy.susco(cnrc.qov I

Environmental Impact Statement Environmental Impact Statement Scoping Process Summary Report Salem Nuclear Generating Station, Units 1 and 2 Hope Creek Generating Station Lower Alloways Creek Township, New Jersey August 2010 R E Q(/

44, U.S. Nuclear Regulatory Commission Rockville, Maryland

Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) received applications from PSEG Nuclear, LLC (PSEG), dated August 18, 2009, for renewal of the operating licenses for Salem Nuclear Generating Station, Units 1 and 2 (Salem) and Hope Creek Generation Station (HCGS). Salem and HCGS are located in Lower Alloways Creek Township, Salem County, New Jersey.

As part of the applications, PSEG submitted environmental reports (ERs) prepared in accordance with the requirements of 10 CFR Part 51 (PSEG, 2009a) (PSEG, 2009b). 10 CFR Part 51 contains the NRC requirements for implementing the National Environmental Policy Act (NEPA) of 1969 (42 U.S.C. 4321 et seq.). Section 51.53(c)(3) outlines requirements for preparation and submittal of license renewal ERs to the NRC.

Section 51.53(c)(3) was based upon the findings documented in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants, (GELS)

(NRC, 1996) (NRC, 1999). The GELS, in which the staff identified and evaluated the environmental impacts associated with license renewal, was first issued as a draft for public comment. The staff received input from Federal and State agencies, public organizations, and private citizens before developing the final document. As a result of the assessments in the GElS, a number of impacts were determined to be small and to be generic to all nuclear power plants. These were designated as Category 1 impacts. An applicant for license renewal may adopt the conclusions contained in the GElS for Category 1 impacts, absent new and significant information that may cause the conclusions to fall outside those of the GELS. Category 2 impacts are those impacts that have been determined to be plant-specific and are required to be evaluated in the applicant's ER.

The Commission determined that the NRC does not have a role in energy planning decision-making for existing plants. Therefore, an applicant for license renewal need not provide an analysis of the need for power or the economic costs and benefits of the proposed action. Additionally, the Commission determined that the ER need not discuss any aspect of storage of spent fuel for the facility that is within the scope of the generic determination in 10 CFR 51.23(a) and in accordance with 10 CFR 51.23(b). This determination was based on the Nuclear Waste Policy Act of 1982 and the Commission's Waste Confidence Rule, 10 CFR 51.23.

On October 23, 2009, the NRC published a notice of intent (NOI) in the Federal Register (74 FR 54859) to notify the public of the staff's intent to prepare a plant-specific supplement to the GElS (henceforth referred to as the SEIS, which stands for supplemental environmental impact statement) regarding the renewal application for the Salem and HCGS operating licenses. The NRC invited the applicant, Federal, State, and local government agencies, local organizations, and individuals to participate in the scoping process by providing oral comments at the scheduled public meetings and/or submitting written suggestions and comments by December 21, 2009. The SEIS will be prepared in accordance with NEPA, CEQ guidelines, and 10 CFR Part 51.

Publication of the NOI in the Federal Register initiated the scoping process for preparing the SEIS. The NRC conducted the public scoping process, from October 23, 2009 through December 21, 2009, to determine the scope of the staff's environmental review of the application for renewal of the operating licenses for Salem and HCGS. The purpose of the

scoping process is to provide an opportunity for the public to identify issues to be addressed in the SEIS and highlight public concerns and issues. The scoping process included two public scoping meetings, which were held at the Salem County Emergency Services Building in Woodstown, NJ on November 5, 2009. The NRC issued press releases, placed an ad in the local newspaper, and distributed flyers locally.

Approximately 35 people attended each of the meetings. Both sessions began with NRC staff members providing a brief overview of the license renewal and NEPA process.

Following the NRC's prepared statements, the meetings were open for public comments.

Sixteen members of the public spoke at these scoping meetings. Three additional members of the public did not attend the scoping meetings but submitted written comments during the SEIS public scoping process. Transcripts for the afternoon and evening meetings are available on the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.,qov/reading-rm/adams.html.

Transcripts for the afternoon and evening meetings are available in ADAMS under Accession Nos. ML093240195 and ML100471177, respectively (NRC, 2009a) (NRC, 2009b). Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS, should contact the NRC's Public Document Room reference staff by telephone at 800-397-4209 or 301-415-4737, or by e-mail at pdr.resource*,nrc.,ov.

As indicated earlier, the scoping process provides an opportunity for public participation to identify issues to be addressed in the SEIS and highlight public concerns and issues. The NOI identified the following objectives of the scoping process:

Define the proposed action; Determine the scope of the supplement to the GElS and identify significant issues to be analyzed in depth; Identify and eliminate peripheral issues; Identify any environmental assessments and other environmental impact statements being prepared that are related to the supplement to the GELS; Identify other environmental review and consultation requirements; Indicate the schedule for preparation of the supplement to the GELS; Identify any cooperating agencies; Describe how the supplement to the GElS will be prepared.

At the conclusion of the scoping period, the staff evaluated the transcripts and prepared responses to the comments. Table 1 identifies the individuals providing comments. A summary of the public scoping summary comments follows Table 1.

TABLE I - Individuals Providing Comments during Scoping Comment Period Commenter Commenter Affiliation (If Stated)

Comment Source ID Name SHC-1 Lee Ware Salem County Freeholders Board Afternoon Scoping Meeting SHC-2 Greg Gross Delaware State Chamber of Afternoon Scoping Commerce Meeting SHC-3 Brian Duffey Salem County Chamber of Afternoon Scoping Commerce Meeting SHC-4 Fred Stein Delaware Riverkeeper Network Afternoon Scoping Meeting, Written SHC-5 Charles Hassler IBEW Local Union 94 Afternoon and Evening Scoping Meetings SHC-6 Carl Fricker PSEG Nuclear, LLC Afternoon and Evening Scoping Meetings SHC-7 Dr. Peter Contini Salem Community College Afternoon Scoping Meeting SHC-8 David Bailey Jr.

Ranch Hope, Inc Afternoon Scoping Meeting SHC-9 Kelly Wichman PSEG Nuclear, LLC Afternoon Scoping Meeting SHC-10 Jane Nagaki New Jersey Environmental Afternoon Scoping Federation Meeting SHC-1 1 Roland Wall Center for Environmental Policy, Afternoon Scoping Academy of Natural Sciences, Meeting Philadelphia SHC-12 Julie Acton Salem County Freeholder Evening Scoping Meeting SHC-13 Frieda Berryhill Not stated Evening Scoping Meeting SHC-14 Nancy Willing Not stated Evening Scoping Meeting SHC-15 Monica Beistline Salem Generating Station Evening Scoping Meeting SHC-16 Fran Grenier Woodstown Borough Councilman Evening Scoping Meeting SHC-17 Gina Carola Sierra Club Written Comments SHC-18 John Greenhill Department of Energy Written Comments SHC-19 Sidney Goodman Not stated Written Comments SHC-20 William Dunn Not stated Written Comments SHC-21 David Rickards Instream Energy, LLC Written Comments SHC-22 Ellen Pompper Lower Alloways Creek Township Written Comments SHC-23 Norm Cohen The Unplug Salem Campaign Written Comments The comments and suggestions received during the public meetings or as part of the scoping process are documented in this section, and the disposition of each comment is discussed. For reference, a unique identifier (Commenter ID) has been assigned to each

comment referenced in Table 1 (e.g., SHC-1). The comments from the transcripts and the written comments are attached at the end of this report.

These comments have been grouped by general categories. The categories are as follows:

1. Comments Concerning License Renewal and Its Processes

2. Comments in Support of License Renewal, PSEG, and Nuclear Power

3. Comments Concerning Aquatic Ecology and Related Issues

4. Comments Concerning Postulated Accidents

5. Comments Concerning Uranium Fuel Cycle and Waste Management

6. Comments Concerning Socioeconomics

7. Comments Outside the Scope of License Renewal

8. Miscellaneous Comments Each comment is summarized in the following pages. In those cases where no new environmental information was provided by the commenter, only a brief response has been provided to the comment.

To the extent practical, preparation of the SEIS will take into account all the reasonable and relevant issues raised during the scoping process. The SEIS will address both Category 1 and 2 issues, along with any new and significant information identified during the scoping process. The SEIS will rely on conclusions supported by information in the GElS for Category 1 issues and will include the analysis of Category 2 issues, including any new and significant information that is identified. The draft SEIS will be made available for public comment. The draft SEIS comment period will offer the next opportunity for the applicant, interested Federal, State, and local government agencies, local organizations, and members of the public to provide input to this environmental review process. The comments received on the draft SEIS will also be considered in the preparation of the final SEIS. The final SEIS, along with the staffs Safety Evaluation Report, will provide much of the basis for the NRC's decision on the Salem and HCGS licefse renewal application.

Summary of Salem I Hope Creek Public Scoping Comments and Responses

1. Comments Concerning License Renewal and Its Processes Comment: Now, you made a great deal about respecting public input. You had 20 license renewals approved now. None have been refused. I just wonder how much public input has really worked in these cases. None have been disapproved.

And some of them, by my estimate, should not have been approved. I have been to the NRC reading room in Washington, and there are records of every plant in there. Does Salem County have as complete a file as I would find it at the NRC reading room? Salem County library? Everything is in there? SHC-13-8 Comment: This letter concerns the proposed relicensing of Hope Creek. We oppose extending the license of this nuclear plant. We also oppose the process by which decisions on relicensing are made. This process makes it virtually impossible for most individuals and many organizations to participate. In addition, because only certain issues are deemed acceptable by the NRC for submission as contentions, many issues of safety and health are not even looked at by NRC in making their decision. We also oppose relicensing a nuclear plant twenty years before its license is up for renewal. SHC-23-1 Comment: However, it is important to put our concerns on the record, even though we do not expect NRC to act on any of them. SHC-23-3 Response: The purpose and need for issuance of a renewed license is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, which may be determined by other energy-planning decision-makers. This definition of purpose and need reflects the Commission's recognition that a renewed license will be issued unless there are findings in the safety review or n the NEPA environmental analysis that would lead the NRC to not grant a license renewal. The NRC does not have a role in determining if a plant will be allowed to operate under the renewed license. If a renewed license is issued, energy-planning decision makers and the applicant will ultimately decide whether a plant will continue to operate based on factors such as the need for power or other matters within the purview of the appropriate decision makers.

The NRC has established an open process to permit all members of the public to participate in the environmental scoping process. The public is invited and encouraged to participate throughout the environmental review process. Input is specifically requested during the scoping period and during the draft SEIS review period. All comments received are evaluated and considered in the preparation of the draft and final SEIS.

Copies of the application and draft and final SEIS are made available for public review at the Commission's Public Document Room (One White Flint North, 11555 Rockville Pike, Rockville, MD 20852) as well as electronically on the NRC Web site at http://www.nrc.gov/reactors/operatinQ/licensinq/renewal/ap plication.htmL The applications, as well as many of the supporting documents are also available from the NRC's Agency-wide Documents Access and Management System (ADAMS) that is accessible from the NRC ADAMS Web site at http://www.nrc.qiov/readinq-rm/adams.htmL A copy of the application,

draft SEIS, and final SEIS are also available, or will be made available, at the Salem County Library.

These comments will not be evaluated further in the SEIS.

Comment: Fourth, the option of purchasing more electricity by de-commissioning these facilities will likely require modifying and building additional transmission lines to support this option. This will have a far more deleterious affect on the environment and communities where these lines will be constructed that continuing to operating these nuclear facilities. Furthermore, importing electricity will likely originate from either coal or gas fired units that produced the greenhouse gases C02 (and other pollutants) as compared to nuclear power that generates zero greenhouse gas. SHC-20-4 Comment: Hope Creek should be decommissioned at the end of its 40 year license.

Affected employees should be relocated and retrained by PSEG. Artificial Island should be turned into a wind power and solar power "park" to produce some of the electrical energy formerly produced by the nuclear plants. SHC-23-12 Response: These comments refer to the alternatives to license renewal, including the alternative of not renewing the operating licenses for Salem and HCGS, also known as the "no-action" altemative. The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS.

Comment: If the NRC can give Oyster Creek a 20 year extension, even though that nuclear plant could not be built under today's standards, and is a meltdown waiting to happen, it is clear that the relicensing process for Hope Creek will be nothing more than paperwork and rubber stamping. SHC-23-2 Response: The NRC performs a comprehensive review of each application submitted of license renewal. The NRC's review of an application for license renewal has four components: a safety review, an environmental review, inspections, and an independent review by the Advisory Committee on Reactor Safeguards (ACRS). The NRC staff performs a safety review of the information provided in the application (as supplemented with additional information provided by the applicant at the NRC's request). The results of the staff's safety review are documented in a publicly available safety evaluation report.

The NRC staff's environmental review results in the publication of a publicly available site-specific draft SEIS on license renewal. The public is invited to comment on the draft SEIS.

Then, after considering all public comments, the NRC staff issues the final SEIS. Teams of inspectors with experience in nuclear plant safety visit the site and verify that the applicant has implemented its aging management plans as committed to in the application. The results of plant inspections conducted as part of the license renewal are documented in inspection reports and are made publicly available. The results are also included in the safety evaluation report. The ACRS is an independent panel of experts that advises the Commission on matters related to nuclear safety. The ACRS reviews the applicant's safety analysis report, the staff's safety evaluation report, and the results of the on-site inspections and makes its recommendation to the Commission regarding issuance of the renewed license. Only after all of these steps are satisfactorily completed will the NRC decide whether or not to renew a plant's operating license.

This comment will not be evaluated further in the SEIS.

2. Comments in Support of License Renewal, PSEG, and Nuclear Power Comments: The comments can be located at the back of this document with the alpha numeric comment identifiers: SHC-1-1, SHC-2-2, SHC-3-2, SHC-5-1, SHC-5-2, SHC-6-1, SHC-6-4, SHC-6-5, SHC-6-8, SHC-7-1, SHC-7-3, SHC-8-2, SHC-9-1, SHC-12-1, SHC-12-3, SHC-15-1, SHC-16-1, SHC-20-2, SHC-20-5, SHC-22-1 Response: These comments are general in nature and are noted. They are primarily supportive of PSEG, nuclear power, and license renewal for Salem and HCGS. The comments provide no new and significant information and will not be evaluated further in development of the SEIS.

3. Comments Concerning Aquatic Ecology and Related Issues Comment: Speaking now directly to the environmental impact study, the Delaware Riverkeeper Network calls on the NRC and other reviewing agencies to hold the applicant to the highest scientific and regulatory standards as they prepare the EIS. Previous permits issued to PSE&G were based on data which were found to be faulty, misleading, biased and incomplete. In 1999 for instance, when PSE&G's permit came up for renewal, the company submitted over 150 volumes of information, data and arguments to support its case that it should be allowed to continue to kill Delaware River fish unimpeded.

Every year the Salem Nuclear Generating Station kills over 3 billion Delaware River fish including: Over 59 million Blueback Herring; Over 77 million Weakfish; Over 134 million Atlantic Croaker; Over 412 million White Perch; Over 448 million Striped Bass; and over 2 billion Bay Anchovy. Even NJDEP's own expert agrees that PSE&G assertionswere not credible and were not backed by the data and studies PSE&G had presented. In fact according to ESSA consultants hired by NJDEP, PSE&G had greatly underestimated its impacts on Delaware River fish. According to ESSA, PSE&G "underestimates biomass lost from the ecosystem by perhaps greater than 2-fold." (ESA report p. xi) And "... the actual total biomass of fish lost to the ecosystem... is at least 2.2 times greater than that listed" by PSE&G. (ESSA Report p. 75)

ESSA Technologies' 154 page review of PSE&G's permit application documented ongoing problems with PSE&G assertions and findings including bias, misleading conclusions, data gaps, inaccuracies, and misrepresentations of their findings and damage. Some examples of ESSA's findings: With regards to fisheries data and population trends, ESSA said "The conclusions of the analyses generally overextend the data or results." (p. ix); PSE&G "underestimates biomass lost from the ecosystem by perhaps greater than 2-fold." (p. xi)

"... the actual total biomass of fish lost to the ecosystem... is at least 2.2 times greater than that listed in the Application (p. 75); "Inconsistency in the use of terminology, poorly defined terms, and a tendency to draw conclusions that are not supported by the information presented detract from the rigor of this section and raises skepticism about the results. In particular, there is a tendency to draw subjective and unsupported conclusions about the importance of Salem's impact on RIS finish species." (p. 77); and Referring to PSE&G's discussion and presentation of entrainment mortality rates, ESSA found PSE&G's "discussion in the section of the Application to be misleading." (p. 13).

The ESSA report contained no less than 51 recommendations for citations which PSE&G needed to take on its 2001 permit application before DEP made its decision, but that did not happen. It is our understanding that while NJDEP pursued some of these (which ones we do not know because it was not referenced in the draft permit documents) many of them were never addressed, and still other were turned into permit requirements to be dealt with over the next 5 years.

In addition to ESSA recommendations, NJDEP received comment from the State of Delaware and USF&W, both of whom conducted independent expert review of the permit application materials and found important problems with sampling, data, analyses and conclusions.

While we are urging you today to hold the applicant to high standards, I conclude be re-stating the fact that because Salem is clearly having an adverse environmental impact on the living resources of the Delaware Estuary and River, regardless of PSE&G's self-serving claims based on faulty scientific studies, the Clean Water Act requires "that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact." SHC-4-2; SHC-4-4 Comment: Not only that, but deceitful testimony has been given in support of the environmental impact of the existing nuclear plants. The statement for renewal states that the existing plants had no adverse effects on the Delaware Estuary. In fact, Salem kills 3 billion fish annually. Environmental expert Robert F. Kennedy Jr. sued the EPA in 1993. He revealed that Salem alone killed more than 3 billion Delaware River fish each year, according to the plant's own consultant. Fish kills are illegal and represent criminal acts.

SHC-19-2 Response: The comments are related to aquatic ecology and the quality and quantity of the data. As part of the NRC's environmental review and subsequent SEIS development, the data generated by the utilities at the facility, as well as other available data, will be reviewed and assessed. NRC's evaluation will be presented in Chapters 2 and 4 of the SEIS.

Comment: The Delaware Riverkeeper Network wants to reaffirm our long-standing position and call to convert the Salem Generating Station to closed-cycle cooling as mandated by Section 316(b) of the Clean Water Act. The Act states that generating plants such as Salem "shall be required that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact." The application before the NRC does not call for the compliance of the Clean Water Act as it relates to best technology available. According to a study conducted by a NJDEP hired expert in 1989 as well as experiences at other facilities, installation of closed cycle cooling towers at Salem would reduce their fish kills by 95%.

And dry cooling at Salem could reduce their fish kills by 99%. SHC-4-1; SHC-4-3 Comment: The Environmental Federation is, also, very firmly committed to the idea that if the relicensing goes forward, on Salem 1 and 2, that best available technology should be applied at those plants, which would be cooling towers to offset the millions of gallons of water that cycle through that plant every day. There has been a lot of talk, today, about how nuclear energy produces no air emissions. And, generally, when we think about environmental impacts we are thinking air, releases to the air, releases to the water, releases to the land. And while it is true that there may be no air emissions, from the plant,

there certainly is a consumptive use of millions of gallons of water a day, run through the cooling cycle, and then discharged back into the Delaware Bay, with a concurrent loss, as Fred mentioned of billions of fish per year, in all stages of life, from larval stage, to small stage, to large scale fish that are impinged on the once-through cooling system. Which I have toured, by the way, and witnessed the huge structure that takes through millions of gallons of water a day. So if there is one environmental issue that I would like to highlight today, is the impact of the Salem Nuclear Plant on water in the Delaware Bay, and the concurrent fish and wildlife that that water, the Delaware Bay supports. We talked about nuclear energy as being a major employer in this area, and I'm certainly respectful of the workers that work there, that keep the plant safe every day, and the niche in the economy that it provides. But there is, also, a huge other economy in the Delaware Bay that is the fishing industry, that is severely affected by the operation of this plant. And so if I were to say the huge, the most huge environmental impact of this plant, is the impact of water, in that once through cooling system. That needs to-be addressed in the environmental impact statement. SHC-10-1 Comment: Now, also, actually these plants were operating against the law, with more than three billion fish killed, annually, from the Delaware River. And anything under three inches is taken up through the intake structure. The NEPA Act, which you have mentioned, which was passed in 1969, was passed just because this kind of damage. On December 18th, 2001, Congress allowed these once-through cooling systems to continue as long as they restored the fish killed. SHC-13-5 Comment: Enclosed is a resolution, passed by the New Jersey Chapter of Sierra, requesting that the Nuclear Regulatory Commission and the New Jersey Department of Environmental Protection require PSE&G to erect cooling towers at the Salem Nuclear Plants as a requirement to renewing the operating licenses. The Executive Board of the New Jersey Chapter is making this request on behalf of over 20,000 members of the New Jersey Chapter. Thank you for your consideration in this very important matter. SHC-17-1 Comment: Every Power Plant currently using intakes, either for once through operations or to replenish water lost from evaporation, should be required to partner with the most local municipality and pipe their treated wastewater to the power plant to eliminate intakes.

Intakes kill millions of fish annually and once through operations adversely modifies the environment surrounding the outflow area. Municipalities need to dispose of their treated wastewater and to pipe this affluent to a facility that can use it is a least expensive and obviously the most environmentally friendly method.

All power plants should upgrade to a cooling tower technology. If too much heat in generated to recycle the water, cooling units can be added to the outflow troughs to reduce the temperature of the water prior to reuse.

The kinetic energy available in cooling tower outflows can be tapped with UEK turbine technology to generate enough electricity to run cooling coil units. ENERGY RECOVERED

= GOOD MANAGEMENT. SHC-21-1 Response: The comments, in general, relate to the aquatic ecology associated with Salem's once-through cooling systems and the potential retrofitting of Salem's once-through cooling water system with cooling towers. The NRC has, in the past, evaluated cooling towers as an alternative for license renewal. In each of those cases, however, the

staff deemed such an alternative to be reasonable and foreseeable because the permitting authority (the States) had indicated that they would mandate closed-cycle cooling as part of the National Pollution Discharge Elimination System (NPDES) permitting processes.

However, in the case of Salem, the New Jersey Department of Environmental Planning (NJDEP) Division of Water Quality has previously determined that the station's once-through cooling system, in conjunction with an intake flow limitation, an enhanced fish return system, and the study and potential implementation of a multi-sensory hybrid system, constitutes best technology available (NJDEP, undated). Based on this determination from NJDEP, the NRC does not consider the retrofitting of Salem's once-through cooling water system a reasonable or foreseeable alternative and therefore will not further address it in the SEIS.

Comment: This program involves ongoing restoration, enhancement, and preservation of more than 20,000 acres of degraded salt marsh, and adjacent uplands within the estuary.

The estuary enhancement program is the largest privately funded wetlands restoration project in the country. More importantly, it was created with extensive public participation, and open communication with regulatory agencies and the public.

As a result all the estuary enhancement program sites are open to the public, and offer boardwalks, nature trails, outdoor education, and classroom facilities.

Studies show that the overall health of the estuary continues to improve. In addition, analysis of long-term fish populations in the estuary show that, in most cases, the populations are stable or increasing.

And that fish population trends are similar through the other areas along the coast. We also recognize our important role and impact to the local community. SHC-6-2; SHC-6-6 Comment: So going back to another impact, and the result of the Salem 1 and 2 plants, not having cooling towers is that PSEG Nuclear entered into a very large estuary enhancement program, which was referred to earlier, preserving 20,000 acres of wetlands. And I would be remiss if I didn't mention a concern that environmental groups raised at the beginning of the restoration project, because many of the acres of wetlands were restored simply by breaching dikes of old salt hay farms, and allowing inundation of phragmites by salt water.

And thus controlling the phragmites and growing a more beneficial kind of vegetation, called Spartana. But there are acres and acres of phragmites, you know what they are, the tall waiving foxtails, as they are often called, which were considered nuisance vegetation, or not favorable vegetation in the wetland restoration. And so in order to control that phragmites, massive aerial herbicide event took place starting in 1995 and '96, over 2000 acres were really sprayed with a pesticide called Glyphesate. And it was thought that one, maybe two applications of that herbicide would take care of the problem. But, to this day, in the year 2009, and continuing on until at least 2013, annual applications by herbicide by aircraft are made to wetlands, as part of this project. The acreage is down now, to around 120 acre realm. But it has been as high as thousands of pounds of a year. And so one of the environmental issue raised by this is, is there going to be continued applications of an herbicide in wetland areas as part of this restoration project, which was meant to offset the impacts caused by the lack of cooling towers. The reason we are concerned about this application of herbicides is that it actually triggered an increase in the use of this herbicide, state-wide. PSEG kind of became the model for how to restore wetlands. And so many other wetland restoration projects began utilizing this methodology. And the result has

been a nine-fold increase in the use of Glyphesate in the state of New Jersey. And so while the use at this particular Alloways creek area is decreasing, not over yet, but still decreasing, the increase in the use, state-wide, is of concern because as you know pesticides generally have a habit of infiltrating our groundwater and surface water. They become part of our drinking water, part of our surface water. And the effect of this herbicide has been linked to cancer effects, birth defect effects, effects on fish, insect populations, and so forth. So we certainly raise this as an issue that needs to be addressed, because nobody has really looked at the cumulative impact of this year, after year application of herbicide to control a nuisance plant, all in the name of restoring wetlands. SHC-10-4 Comment: My comments today are based on observations of Academy scientists, particularly those of our senior fishery scientist, Dr. Rich Horowitz, who is unable to be here today. The estuary enhancement program began in 1994. And, since that time, has been a large scale effort to restore and preserve portions of the Delaware estuary, in both New Jersey and Delaware, encompassing more than 32 square miles, as you heard earlier, it is the nation's largest privately-funded wetlands restoration project. Restoration efforts have included the goal of replacing former salt hay farms, as you heard. And also to remove marshes that are dominated by the invasive phragmites, with saltcord grass dominated marsh. This has required a substantial effort to control phragmites, and to change drainage patterns to foster topography and tidal flow typical of Delaware Bay salt marshes.

The Academy has studied many of these sites, prior to restoration and a number of them following restoration. Yes, the enhancement program has been successful in restoring typical salt marsh conditions at these sites, with most sites being targets for reduction of phragmites, and establishment of salt cordgrass. At the remainder of sites where goals have been partially met, the estuary enhancement program continues to work to further improve marsh conditions. The EP has also preserved open space, as at the bayside track.

Among other improvements at the restored sites, tidal flow and development of tidal channels have increased, allowing for re-colonization of salt cordgrass and other species.

The restored marshes support large numbers of targeted fish species, as well as number of other fishes and invertebrates. These populations continue to -- excuse me, contribute to bay productivity, most notably, at the salt hay farms. The restoration sites also provide important habitat for terrapins, birds, and mammals, and several of the sites are now part of New Jersey's Audubon designated important bird areas. SHC-11-1 Comment: The basic restoration activities, particularly controlling phragmites and fostering development of tidal marsh topography and hydrology, have advanced the field of ecological restoration. The ecological engineering technique of forming primary channels, and then using estuarian processes to further develop channels and topography, is especially notable. And in that way the estuarian enhancement program does provide an important model for marshland restoration. PSEG has also installed fish passage structures at dams in Delaware and New Jersey. These fish ladders have established river herring spawning in nursery areas, and several impoundments, increasing bay-wide populations of these species. PSEG has continued to conduct monitoring programs of Delaware fish populations, which greatly increase our knowledge of Delaware Bay fisheries.

To conclude, the Academy would like to commend PSEG on its demonstrated initiative, and long-term commitment to restoring the critical wetlands of the Delaware estuary. The estuary enhancement program has had numerous positive impacts on the ecology and biodiversity of the region, and has made important contributions to the recreational and educational opportunities available to local communities. The scale and scope of this effort

has supported large scale scientific research, has improved our understanding of the process of environmental restoration. The Academy of Natural Sciences has been pleased to have the opportunity to participate in, and to contribute, to our scientific expertise to this project. SHC-11-3 Comment: Now, I saw that you had a display back there about that Habitation Restoration Act of 2001. But are you really raising fish? Twenty-thousand tons of poison was spread to kill the phragmite. You can't kill that phragmite. I looked at the picture that you had back there, that phragmite keeps coming up. How many tons of poisons are you going to spray over there? Now, I was just told, a while ago, that you are replacing the fish. I would like to know how many fish that you are replacing, and what the story is on that. SHC-13-5 Response: These comments address the estuary enhancement program currently being conducted by PSEG. PSEG's estuary enhancement program is not required by NRC as part of their operating license or renewal application. The estuary enhancement program is a provision of the Salem's New Jersey Pollution Discharge Elimination System (NJPDES) permit. The NJDEP, Division of Water Quality determined that the Station's once-through cooling system in conjunction with an intake flow limitation, an enhanced fish return system, and the study and potential implementation of a multi-sensory hybrid system constitutes best technology available. The Department also required further "Special Conditions" that included: wetland restoration and enhancement; continued monitoring of fish ladders, and improved biological monitoring (NJDEP, undated). The impacts of the estuary enhancement program will be evaluated and incorporated, as appropriate, into the ecological mitigation sections of Chapters 4 and 8 of the SEIS.

Comment: Hope Creek has leaked hydrazine into the Delaware Bay. SHC-23-4 Response: There have been two recent hydrazine discharges at Salem reported to the NJDEP. These events are summarized below:

In June of 2006, PSEG submitted a Discharge Confirmation Report to the NJDEP for the discharge of approximately 2000 gallons of water containing hydrazine and ammonium hydroxide from the Salem Unit 1 Condensate Polisher System to the ground, with an additional discharge of 2000 gallons to the Delaware River through a permitted outfall. The discharge, which occurred on May 10, 2006, was reported to the NJDEP hotline (case number 06-05-10-0235-20) and to the NRC (event number 42563). The source of the discharge was a lifted relief valve within the Salem Unit I Condensate Polisher Building. It was terminated immediately upon discovery. It was reported that 8.3 ounces, or 3 parts per million (ppm), of hydrazine was discharged to the Delaware River and 8.3 ounces, or 3 ppm, was discharged to the ground without recovery. The Department issued a fine in the amount of $8250. 00 which was paid in full. (NJDEP, 2009)

On June 25, 2007, PSEG submitted a Discharge Confirmation Report to the NJDEP for the release of approximately 20, 000 gallons of water, containing hydrazine, from a catastrophic failure of the 24 Demineralizer Vessel sight glass in the condensate polisher system at Salem Unit 2. In this event, condensate water had discharged into the yard area east of the Salem Unit 2 Condensate Polisher Building. The discharge, which occurred on May 24, 2007, was reported to the NJDEP hotline (case number 07-05-24-0259-32) and to the NRC.

The discharge to land was managed in accordance with PSEG Discharge Prevention, Containment and Countermeasure Plan. Sampling and analyses were performed that

demonstrated there was no discharge to surface water as a result of this event. (NJDEP, 2009)

Minor chemical spills are considered a Category I issue and will not be evaluated further in the SEIS, as the effects are readily controlled through the NJPDES permit (as demonstrated above) and are not expected to be a problem during the license renewal term.

4. Comments Concerning Postulated Accidents Comment: What is unique about our community? What is unique about Artificial Island is that it is an island that was constructed of dredge spoil material. It is not an island that existed before the geology of the time. So one of the concerns, environmental concerns would be how stable is the structure of the island to support this plant for another 20 years.

Or three plants, actually. I think that issue will be addressed, more specifically, tonight by another environmental group. What is the effect of sea level rise? We talked about global warming and how nuclear power doesn't produce the kinds of emissions that contribute to global warming. But there is global warming going on, and there is sea level rise. What is the effect of sea level rise on the plant's artificial island? You know, is the island going to be inundated with water, how much over the next few years? Does more infrastructures need to be built there to support the plant? We know that salt water and the effects of the salinity of the bay have contributed to the rusting out of parts of the plant. We know that there has been extensive replacement of structures, and underground piping at the plant.

And that is both, you know, that is an environmental impact, the salinity of the area, on the integrity of the structure of the plant. And that is an environmental issue that needs to be integrated into the safety and the aging issues of the plant. SHC-10-3 Comment: I have been involved with Salem before it was licensed to operate, for the simple reason that Delmarva Power and Light, at the time, also planned to build a nuclear power plant right across the river from here, which would have made this area the largest nuclear complex in the world. I was an intervener, a case I couldn't lose, because they ordered a high temperature gas-cooled reactor, and you know what happened to that. I'm very concerned about this. I attended many hearings on the subject, ever since 1970.

These plants should never have gotten a building permit. Upon examining the documents I found, to my shock, clearly described in detail, on the large map, the soil condition of Artificial Island.

You see, there was no land here. It is called Artificial Island, because the island is built from dredgings of the Delaware River. And in the documents you will find that the borings of 35 feet are essentially nothing but mud and sand. The next 35 feet are gravel and sand.

The last 35 feet are described as Vincentown Formation, which is a different kind of gravel and sand. Borings up to 100 feet have not revealed rock bottom. There is no rock bottom under these plants. The spent fuel pools, the auxiliary buildings, all of it, is sitting perched on cement pilings, I call them stilts, going 75 feet into the mud. And that is what is holding these plants up. Now I have with me pictures of toppled buildings that have simply collapsed with the pilings still sticking to them. And I am deeply concerned to have a fourth reactor on that island. SHC-13-1

Comment: Liquefaction is discussed in the documents. Liquefaction is the phenomenon when there is an earthquake, not a major earthquake, the sand is liquefies, and the building

-- the hundreds of examples all over the world, where you can find that. And you can find some of it even on Google. And I have made statements to that effect before the Delaware House Energy Committee, and other agencies. It doesn't seem to really matter what citizens say. Yes, there was an earthquake up in Morris County. It was, actually, quite sizeable. But there is an earthquake fault, also, on the Delaware River. And, really, it scares me to think that it is only a matter of time, really, that an earthquake could happen here. The Morris earthquake threw people out of the house; they thought there was a big explosion somewhere. It was not just a minor shaking or rattling. Now, as to what could happen, I would like to just go back to the Rasmussen report, which was produced in 1970, as to the safety of nuclear power plants. That wasn't satisfactory, so they commissioned another report in 1985, called "Consequences of Reactor Accident", called the "Crack Report". To just -- the numbers are just staggering. The Crack Report for Salem reads as follows: Early peak fatalities, 100,000 Salem, 100,000 Salem 2. Early peak injuries, 70,000 for Salem 1, 75,000 for Salem 2. Peak cancer deaths, Salem 1 40,000, Salem 2, 40,000.

Damages, Salem 1, 140 billion, Salem 2, 135 billion. This is not fantasy, this is the government report. SHC-13-2 Comment: While speaking with the state official from the Bureau of Nuclear Energy at the New Jersey, before the evaluation hearing had started I asked about having heard that Salem was built on swamp land. And the gentleman, whose name I don't have here, he said of course not, and he proceeded to claim that the pilings went on through the sand, and gravel on Artificial Island, and were drilled securely into the bedrock. So that was the opinion stated at that meeting, to me, by an official from the Bureau of Nuclear Energy here in New Jersey. So I took the question to the record, when I had a chance to speak, and formally ask the question, about Artificial Island structures, do they actually secure into bedrock? Because Frieda Berryhill had told me that in her investigations, that they had not.

So I asked, for the record, and the officials promised me that they would investigate that discrepancy, and give it back to me in writing, which they never did, I never got anything from them.

My concern was based on having heard that yet one more unit was planned to be constructed at the Salem complex. For the structures to be floating on a bed of gravel, and sand, and the result of a significant earthquake, six or seven on the Richter scale, would mean that the base of the structures, containing this nuclear material, would likely experience liquefaction, which Frieda got into a little bit.

That is the changing from compression of the earthquake, of the gravel and sand mix, into a jelly-like material. Liquefaction of the ground underneath causes structures to tip, slide, collapse, and otherwise break apart. It was an unhappy coincidence that the evacuation hearing was on the same day as the earthquake. So it was an interesting experience.

Another earthquake was centered a few miles away from the Salem plant. And although it wasn't more than maybe two on the Richter scale, I'm not sure what it was, it isn't unheard of to think that we would have a more significant earthquake. The officials told me, that day, that the structures are built to withstand up to six or so on the Richter scale. But would that prevent a significant earthquake, maybe not up to that, would that prevent the leaks and cracks of an aging plant that is floating on a bed of gravel and sand, so to speak, should another earthquake occur. So the scope of the licensing process, here today, I think should be investigating that these are drilled into bed rock, that they are subject to liquefaction, and that would the aging of structures, brittle, -- would the aging, basically,

have an impact on potential earthquake activity and contamination of the environment?

And I think that is, hopefully that would be in your scope, some serious study of that.

SHC-14-3 Comment: To renew the license for these nuclear plants represents extreme neglect of the public safety and welfare. It was incredibly poor judgment that these plants were built on "Artificial Island" in the first place. These plants should be shut down, with operation not allowed to continue, much less have their operation greatly extended. Incredibly, PSE&G is considering putting another nuclear plant on this island in this earthquake prone region.

None of the nuclear plants are built on solid rock. They are filled in land. The letter I received from Bruce A. Boger (August 24) confirmed that these plants are not on solid rock.

They rest on compacted engineering fill material or concrete, which have a depth of approximately 70 feet. Concrete pilings are used. The NRC presumes that this will enable them to resist the worst assault that an earthquake can deliver. SHC-19-1 Comment: What can happen from building on unstable land was exemplified in Shanghai, China. At around 5:30 AM on June 27, 2009 an unoccupied building, still under construction at Lianhuanan Road in the Mining district of Shanghai City toppled. Just before toppling, there were reports of cracks on the flood-prevention wall near the buildings and "special geological conditions" in the water bank area. In Japan, seven reactors at the Kashiwasz-Kariwa nuclear power plant in Japan were shut down due to an earthquake, fire and nuclear leak. People were killed and injured by the 6.8 magnitude earthquake, which struck in July, 2007. A new fire at the still shut down plant occurred in March, 2009.

600,000 residents signed a petition opposing restart of the plant. The arrogance of building nuclear plants in an earthquake prone area is almost unbelievable. Believe it! This arrogance is also invested in the other Nuclear Regulatory Commission rules. SHC-19-3 Comment: Hope Creek is vulnerable to a severe earthquake because Artificial Island is built on compacted mud, and its pilings do not reach bedrock. SHC-23-6 Response: The comments address the formation and stability of the land on which the Salem and HCGS are built and the susceptibility of the area to natural disasters such as earthquakes. As part of the NRC licensing process, the impact of the environment on the plant is evaluated as part of the safety analysis, and the impact of the plant on the environment is evaluated as part of the environmental review.

Liquefaction potential was evaluated by the NRC in NUREG-1048, "Safety Evaluation Report Related to the Operation of Hope Creek Generating Station" (NRC, 1984). The report concluded that the river bottom sand will be stable under safe shutdown earthquake conditions.

In addition, issues related to the impacts of natural disasters on the plant continue to be addressed on an ongoing basis as part of the existing operating licenses. If any new and significant information is identified related to the scope of license renewal, such issues will also be addressed as part of the license renewal safety analysis and environmental review.

Comment: I am unable to attend the hearings on 11/15/09 but would like to submit the following questions. There were incidents on 03/13/1989 and 9/19/1989 at the Salem 1 and 2 Nuclear Plants sites when geomagnetic storms caused damage to the single phase, generator step-up transformers which caused them to be taken out of service. The damages were due to geomagnetically induced currents caused by the geomagnetic storms.

Questions:

1. Is there a publically available report that describes these incidents?

2. What was the magnitude of the currents that caused the damage?

3. How long did the damaging currents persist?

4. What was the protective relay system in place at that time such as the IEEE Std C37.91 1985?

5. Where there any modifications to the transformer protective system put into effect?

6. How will the step-up transformers at Salem and hope Creek sites be protected if a super geomagnetic storm (10 times the size of the 1989 storms) occurs during the 20 year extension?

7. Do the sites have spare step-up transformers?

An initial cursory look shows a possible problem with the draft EIS when one examines table 5-2. The probability of a super solar storm of the 1859 or 1921 size is about 1/100 years or 1 % year. This size storm leads to a continental long term (many months) grid outage because of damage to all the U.S. step-up transformers similar to the damage that occurred at Salem New Jersey in 1989 during a fairly mild solar storm. With such an outage the emergency generators (that drive the cooling pumps) fuel supply would run out and could not be replaced because the commercial fuel suppliers would be out of fuel as well. Without fuel for the cooling pumps, the core damage frequency (CDF) appears to be several orders larger that the CDF given in the table 5-2. Perhaps a solar storm initiating event should be included in all the final EIS documents including the Salem and Hope Creek. SHC-18-1; SHC-18-2; SHC-18-3 Response: The seven questions listed in the comment above are under NRC review.

However, these comments involve operational issues that are not within the scope of the license renewal environmental review and, therefore, will not be evaluated in the SEIS.

The second part of this comment involves concerns about the assessment and effects of a solar storm. Chapter 5 of the SEIS considers postulated accidents and severe accident mitigation alternatives (SAMA). The SAMA analysis considers potential ways to further reduce the risk from severe reactor accidents in a cost-beneficial manner. The process for identifying andevaluating potential plant enhancements involves use of the latest plant-specific, peer-reviewed probabilistic risk assessment (PRA) study. These risk assessment studies typically show that loss of offsite power (LOSP) and station blackout (SBO) sequences are among the dominant contributors to core damage frequency (CDF) for nuclear power plants and account for about 20 to 50 percent of the CDF. As a result, enhancements to mitigate SBO events initiated by a LOSP are routinely identified and evaluated in the SAMA analysis. Consideration of SBO events initiated by a solar storm would not be expected to result in identification of additional SAMAs to mitigate LOSP and SBO events since license renewal applicants already perform a thorough search for potential means to mitigate these risk contributors.

Consideration of solar storms would not be expected to substantially impact the CDF for LOSPISBO events because postulated damage to generator step-up transformers would not affect the operation of the emergency diesel generators (EDGs). The EDGs would function to cool the reactor core until connections to the electrical grid are reestablished or alternative means of core cooling are established. Onsite fuel storage is typically sufficient to provide for at least 7 days of EDG operation and would be replenished during this period, as demonstrated at the Turkey Point plant following Hurricane Andrew in 1992 (NRC, 1992). Even given a major disruption in the supply chain, the 7 day period is sufficient for alternative arrangements to be made to resupply fuel for nuclear power plant EDGs in accordance with the National Response Framework (see National Response Framework, Emergency Support Function #12 - Energy Annex, www.fema. qov/ddf/emercqency/nrf/nrf-esf-12.pdf). Alternative means of core cooling would be viable in the longer term, given that core cooling requirements (e.g., required pumped flow rates) would be substantially reduced days and weeks after reactor shutdown, and given the substantial industry and Federal resources that would be available to facilitate these measures.

If there is incompleteness in current PRAs with respect to an underestimate of the frequency or consequence of solar storm-initiated LOSPISBO events, the sensitivity analysis performed on the SAMA benefit calculation would capture the increased benefit that might result from a more explicit consideration of solar storm-induced events. This analysis typically involves increasing the estimated benefits for all SAMAs by an uncertainty multiplier of approximately 2 to determine whether any additional SAMA(s) would become cost-beneficial and retaining any such SAMA(s) for possible implementation. In summary, the consideration of solar storm-initiated events would not be expected to alter the results of the SAMA analysis since enhancements that address these types of events are already considered in the applicants' search for SAMAs to mitigate SBO/LOSP events, and any potential underestimate of the benefit of these SAMAs would be captured in existing applications by the use of the uncertainty multiplier on the SAMA benefits.

5. Comments Concerning Uranium Fuel Cycle and Waste Management Comment: Has the company made any request for dry-cask storage?... With Yucca Mountain canceled you will have to, eventually, go the dry cask storage, I just want to know how soon, or whether you have made any plans, and who is producing them. You don't know that? Okay. SHC-13-7 Comment: Because Yucca Mountain, the national depository for spent nuclear fuel, will not be operative, Lower Alloways Creek will become, and actually is now, a long term nuclear waste dump, which violates the zoning board agreement between PSEG and Lower Alloways. SHC-23-7 Response: The safety and environmental effects of long-term storage of spent fuel onsite have been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified at 10 CFR 51.23), the Commission generically determined that such storage could be accomplished without significant environmental impact. In the Waste Confidence Decision, the Commission determined that spent fuel can be stored onsite for at least 30 years beyond the license operating life, which may include the term of a renewed license.

At or before the end of that period, the fuel would be removed to a permanent repository. In its Statement of Consideration for the 1990 update of the Waste Confidence Decision (55

FR 38472), the Commission addressed the impacts of both license renewal and potential new reactors. In its December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of spent fuel, the Commission states in the rule that there is reasonable assurance that at least one geologic repository will be available within the first quarter of the 21st century, and sufficient repository capacity for the spent fuel will be available within 30 years beyond the licensed life for operation of any reactor. The Commission issued a proposed revision of the Waste Confidence Decision in the Federal Register (73 FR 59551) for comment on October 9, 2008. This revision provided the basis for extending the time for sufficient repository capacity for spent fuel to be available from within 30 years beyond the licensed life for operation of any reactor to within 50 to 60 years.

The proposed revision also provides reasonable assurance that spent fuel can be stored without significant environmental impacts for at least 60 years beyond the licensed life for reactor operation assuming storage of spent fuel in either a spent fuel storage basin or onsite or offsite ISFSI. Accordingly under 10 CFR 51.23(b), no site-specific discussion of any environmental impact of spent fuel storage in reactor facility storage pools or ISFSIs is required in an environmental impact statement associated with license renewal, and these comments will not be evaluated further in the SEIS.

Comment: As far as, you know, there is no radiation produced at this plant, there is some radiation produced at this plant. It meets limits, so called acceptable limits. There is waste that is stored on-site. And so another environmental issue, that the environmental impact statement should address, is how much more waste is going to be generated and stored at the plant, at those enclosures that currently keep all the waste, ever produced at that plant, on the site forever. So waste production concurrent with the relicensing is another very major environmental issue. SHC-1 0-2 Comment: Third, based on my research on the emerging nuclear fusion technology, the disposal of nuclear waste will be one day be safely transmuted to useful isotopes. Nuclear fusion and fission will be paired to provide almost unlimited power without the issue of residual radioactivity. SHC-20-3 Response: The GEIS considered a variety of spent fuel and waste storage scenarios, including onsite storage of these materials for up to 30 years following expiration of the operating license, transfer of these materials to a different plant, and transfer of these materials to an Independent Spent Fuel Storage Installation (ISFSI). For each potential scenario, the GElS determined that existing regulatory requirements, operating practices, and radiological monitoring programs were sufficient to ensure that impacts resulting from spent fuel and waste storage practices would be SMALL, and therefore were a Category 1 issue. The comments contain no information regarding the waste management practices that would be considered new and significant.

6. Comments Concerning Socioeconomics Comment: I didn't realize that we have about in excess of three hundred employees, from Delaware, that come across that bridge each day. But it is not just about the 300 folks that come across that bridge, it is also about the families they support. SHC-2-1

Comment: Approximately 400 businesses and community organizations are members of the Salem County Chamber of Commerce, and this includes PSEG Nuclear, who is a long-time member.

On behalf of the Chamber, I would like the NRC to know that PSEG Nuclear plays a leading role in our community. They have supported the Chamber's efforts to build relationships, within the community, and to make Salem County a premier place to live, work, and conduct business.

They purchase goods and services from dozens of local businesses, and Chamber members, and with our support they are helping to drive the local economy.

Earlier this year PSEG Nuclear, hosted the Chamber Board of Directors for a tour of the Salem and Hope Creek facilities. It became very clear, to the Board of Directors that PSEG operates in a culture of safety and security.

That visit also reinforced the Board's belief that PSEG Nuclear operations provide a safe and clean source of energy. We also believe that nuclear power can help to combat climate change, and that PSEG's operations will continue to play a positive role in Salem County's future.

Without these plants hundreds of people would be left without jobs, dozens of local businesses would struggle, and our local economy would suffer a great loss. SHC-3-1 Comment: As such we have looked to partner with local communities, with our local community, to meet our needs to providing good paying local jobs. We have launched innovative partnerships with the Salem County Community College, and the Salem County Vocational Technical schools, to develop specialized training programs.

Both have been overwhelmingly successful, and will lead to a skilled workforce that will only strengthen the local economy. In Salem County we provide more than 1.4 million dollars, each year, to the local economy through local property taxes.

This funding is vital to supporting local schools and projects. From an economic development point of view, we have also helped to drive the local economic development through projects like revitalization of downtown Salem, and the construction of the Gateway Business Park in Oldmans Township.

We are also active partners in the Salem Main Street Program, and the Salem County Chamber of Commerce. Our support also goes well beyond dollars. Many of our employees are active participants and supporters within the local community. SHC-6-3; SHC-6-7 Comment: Their support is not just verbal. Their support is certainly implementing. And as you know, and you heard Carl say, there is going to be a growing need for employees, as certainly portions of the workforce ages out, and we hope, also, the expansion of opportunity in the future.

As a result we work collaboratively with PSE&G Nuclear, in focusing on a particular area that we think is of great need, an energy, nuclear energy technician position.

We were able to couple with them, and partner at the national level with the Nuclear Energy Institute. And we were selected as one of six community colleges, across the country, that are working on standardizing the curriculum to ensure that educational experience that our students have, will not only prepare them, but certainly ensure safety and security in the future in this field.

And you also heard about the center that has been revitalized in Salem City. Well, I'm proud to tell you that a portion of that center will be hosting a portion of our program.

And through a high tech classroom, as well as laboratory facilities, our students will be working with state of the art equipment. And, most importantly, be supportive both in scholarships, as well as internships.

So we see this as a real win-win. Thinking about this, that we have only, in less than one year, been able to implement this program, we now have a fully accredited nuclear energy technician program, technology program, what we refer to as NET, we now have over 50 students in that program.

The corresponding program, Sustainable Energy, is also working at about 20 students. We see that balance, and PSE&G Nuclear sees that balance, also. And they have been very collaborative in working with Energy Freedom Pioneers, as we look for other alternatives to energy in addition to nuclear.

These are important things, they are important things for our community and, certainly, for our students. But they also go beyond. Two years ago we had an emergency in our Salem center, hosting our one-stop career center. A fire, a fire that immediately caused the dislocation of over 30 workers, and 200 clients a day.

Within two hours we had a commitment from PSE&G Nuclear to relocate that entire program to the former training center. And within two days we were fully operational for the next four months. SHC-7-2 Comment: Ranch Hope, Inc., is a 501C(3) non-profit organization, founded in 1964. Again, our Alloway headquarters are within minutes of the Salem and Hope Creek facilities. Our mission is to provide behavioral health care, educational, and adventure-based environments for children and families from throughout the state of New Jersey, and within the Delaware Valley.

Through its generosity and support of local organizations, such as Ranch Hope, PSE&G Nuclear has touched the lives of thousands of residents, making our community a better place to live.

At Ranch Hope's Alloway campus PSE&G Nuclear supports our efforts to create a green community for children with treatment and educational facilities, not only environmental responsible, but energy efficient, and healthy for children and staff to live and work.

This unique collaboration with PSEG Nuclear not only focuses on changing the lives of children and families, but also energy efficiency, two topics you don't normally see together.

SHC-8-1

Comment: In addition to ecological restoration, the enhancement program has developed increased opportunities for human use and experience, to interact with the estuary.

Public use areas were designed to meet the general education, public access, and ecotourism interest of each community hosting an EEP site.

This has included improved access to many of the sites by land and water, with boat access and parking areas, in turn, supporting extensive recreational activities.

The public use areas have become important settings for numerous formal and informal educational programs. The restored areas have also become significant research sites, and research by EEP, and other organizations, including the Academy, has advanced our knowledge of tidal marsh ecology. SHC-1 1-2 Comment: Not only are they a great community partner, but they are the county's largest employer. A majority of their employees are local residents, who live in our community.

In tough economic times PSEG Nuclear provides an example of integrity and commitment to positive growth that we all need to see.

PSEG Nuclear takes a very proactive role in developing positive relationships with members of the Salem County community, whether it is providing funding and support to local community groups, or attending their events. SHC-1 2-2 Response: These comments concern the socioeconomic impact of Salem and HCGS on local/regional communities and economy and other related issues such as employment, taxes, education, and philanthropy. The staff will address these issues and the socioeconomic impact of renewing the Salem and HCGS operating licenses in Chapter 4 of the SEIS. In addition, the socioeconomic impact of not renewing the operating licenses of these generating stations will be discussed in Chapter 8.

7. Comments Outside the Scope of License Renewal Comment: I was at the 2009 emergency evacuation public hearing, here in New Jersey.

And it was an interesting meeting for me because although Delaware is at risk, or in the 50 mile radius, we don't get this kind of attention, we don't have public hearings. And I imagine that -- I was told, as I got here today, that some feelers went out to see if Delaware wanted to have a meeting similar to this, and it was not -- that didn't happen. But that the emergency evacuation public meeting the state held, I didn't -- well, I will just go right to this. I don't agree with the renewal of the 20 year licenses for the 40 year old structures that exist here today. I don't think it is a wise and reasonable choice for the citizens. We do enjoy the energy that comes out of them, but we also have to expect to live our full lives here in this area. SHC-14-1 Comment: The NRC is still satisfied with a mere ten-mile evacuation zone around a nuke when poisons from Three Mile Island were blown hundreds of miles. Poisons from Chernobyl were blown around the world? The NRC continues support for the Price Anderson Act. This federal law limits liability of a disaster to a microscopic fraction of the potential damage which will be incurred? The act reduces concerns of operating utilities, a

very risky effect. This federal law abolishes the property rights of Americans in order to protect the property rights of nuclear plant owners. This atrociously unfair law is nothing less than fascist. The NRC continues to support the distribution of potassium iodide pills as an assurance that no one will be harmed from a disaster? These pills only protect against radioactive iodine. The pills must be taken immediately and continue to be used for as long as radioactive iodine lingers in the environment. The pills do nothing to project against all of the other radioactive poisons, which are released. This is no real assurance to anyone who is informed. The NRC continues to support ridiculously inadequate evacuation plans following a fuming meltdown at a nuke.

SHC-19-4 Comments: The Evacuation Plan for Salem/Hope Creek is based on faulty assumptions and would not work under many scenarios, including a fast acting radiation release and multiple releases. Under worst case scenarios, thousands of people within the 10 and 50 mile zones would die from radiation exposure. SHC-23-9 Response: Emergency planning is not within the scope of the environmental analysis for license renewal as set forth in 10 CFR Part 51. The staff has an ongoing program for determining the adequacy of offsite emergency plans and is supported in that role by the Federal Emergency Management Agency (FEMA). Each nuclear plant must have an approved emergency plan in accordance with 10 CFR Part 50. Drills and exercises are conducted periodically to verify the adequacy of the plans. If a problem is identified, it is resolved in the context of the current operating license.

The Commission issued a Final Rule on potassium iodide (KI) in the Federal Register on January 19, 2001 (66 FR 5427). The NRC does not require use of KI by the general public because the NRC believes that current emergency planning and protective measures -

evacuation and sheltering - are adequate and protective of public health and safety.

However, the NRC recognizes the supplemental value of KI and the prerogative of the states to decide the appropriateness of the use of KI by its citizens. At this time, the NRC has made KI available to States that wish to include thyroid prophylaxis in their range of public protective actions to be implemented in the event of a serious accident at a nuclear power plant that would be accompanied by a release of radioactive iodine. Both New Jersey and Delaware have programs for issuing the KI pills. The two programs are similar; however, Delaware's program is more formal in that they have an annual issue event that is publicized by mailing, newspaper, TV, and radio. The KI pills are for the individuals living within the 10-mile emergency planning zone (EPZ). In addition, schools and emergency workers also have a cache of pills in case of an emergency.

These comments do not present any new or significant information and will not be evaluated further in the SEIS.

Comment: But I do want to say that some of the safety concerns, and environmental concerns, are related mainly to this issue of the aging of the plant, the salinity, the lack of a firm under-structure to the plant, all make the plant more vulnerable to failures of structure that could lead to an environmental release of radiation, which is the ultimate disaster that everybody fears at this plant. And so while the radiation leakage issue, and emissions issue, is not a day to day concern, you know, when the plant is operating optimally, if there isn't an aggressive strategy for preventive maintenance, that not just waits for something to

happen, and then addresses it, but actually anticipates and replaces structures as they age, before they age. This vulnerability will continue, you know, to be of great concern.

SHC-10-5 Comment: Clearly this plant should have never received a building permit, and surely it should not receive a license to operate for another 20 years. They were originally licensed for 40 years. You are dealing with embrittlement, and all sorts of problems with that. There was a reason for it. SHC-13-4 Comment: A 40 year life span pretty much says it all, it is a 40 year life span, and the thought of another 20 year service from the Salem and Hope Creek structures seems to be asking too much, and offering uncertainty and trepidation to the public. With age come leaks and cracks. The life span of potential contamination isn't worth that bargain, in my view. SHC-14-2 Comment: The environmental impact appears to be minimal for granting an extension of the facilities license and there is certainly a justified need to upgrade portions of nuclear power generating operations to replace aging equipment that will improve the power generating capabilities and mitigate safety issues of an aging plant. SHC-20-1 Comment: The electrical system that connects Hope Creek to the grid is old and has had a number of failures, including transformer failures.

PSEG has a spotty record when it comes to keeping diesel generators working. This is a concern because all three nuclear plants rely on diesel generators if offsite power is interrupted.

PSEG has a serious Safety Conscious Work Environment (SCWE) and Safety Culture problem. This has been a chronic problem at all 3 of PSEG's plants, and continues to show up in NRC inspections under "cross-cutting issues of human performance". One key example at Hope Creek was the loss of 5000 gallons of cooling water, due to human error.

This event could have escalated into a TMI-type of situation. SHC-23-5 Comment: Hope Creek has buried pipes and electrical conduits that have not been inspected and, based on other nuclear plants, may be leaking tritium or in danger of electrical shorts happening. SHC-23-8 Response: NEPA focuses on the environmental impacts of a major Federal action (such as license renewal) rather than on issues related to the safety of an operation. Safety issues become important to the environmental review when they could result in environmental impacts, which is why the environmental effects of postulated accidents will be considered in the SEIS. Because the CEQ regulations implementing NEPA do not include a safety review, the NRC has codified regulations for conducting an environmental impact statement separate from the regulations for reviewing safety issues during its review of a license renewal application. The regulations governing the environmental review are contained in 10 CFR Part 51, and the regulations covering the safety review (which includes the aging management issues discussed in most of these comments) are contained in 10 CFR Part 54. For this reason, the license renewal review process includes an environmental review that is distinct and separate from the safety review. Because the

two reviews are separate, operational safety issues and safety issues related to aging are considered outside the scope for the environmental review, just as the environmental issues are not considered as part of the safety review.

With respect to the safety aspect of such systems and components being able to operate for another 20 years, the staff makes that determination as part of its license renewal safety review, which focuses on the programs and processes that are designed to ensure adequate protection of the public health and safety during the 20-year license renewal period through management of aging components. As part of the license renewal safety review, PSEG Nuclear, LCC, is required to demonstrate that the effects of aging will be adequately managed. These comments do not present any new or significant information and will not be evaluated further in the SEIS.

Comment: I would like to interject, recently I wrote an article as to the soil conditions of this thing. And in that article I mentioned the Price-Anderson Act, that nuclear power plants could never be built without the protection of the Price-Anderson Act. And some gentleman from the NRC felt compelled to write an answer to the local Wilmington paper saying, we don't depend on the Price-Anderson Act, we have 9 billion dollars in reserve for whatever damages we cause. It makes me laugh, because there is no comparison to the damages that could be caused. Nine billion dollars is pocket change. SHC-13-3 Comment: Incredibly, though, that PSEG announced that it planned to spend another 50 million between 2007 and 2011 to explore the potential to construct a new reactor on the island, a fourth reactor. I think not. I would like to ask a few questions, if I may. Nine billion dollars somewhere in the reserve? Can anybody, at the NRC, tell me who is holding this nine billion dollars? I have a letter written to the editor, don't worry about Price-Anderson, we have nine billion dollars... Who would have that nine billion? Well, I will see if I can find out another way. SHC-13-6 Response: The Price-Anderson Nuclear Industries Indemnity Act (Price-Anderson Act) (42 U. S. C. 2210) is a federal law that governs liability-related issues for all non-military nuclear facilities constructed in the United States before 2026. The main purpose of the Act is to partially indemnify the nuclear industry against liability claims arising from nuclear incidents while still ensuring compensation coverage for the general public. The Act establishes a no fault insurance-type system in which the first $10 billion is industry-funded and any claims above the $10 billion would be covered by the Federal government.

Licensees are required by the Act to obtain the maximum amount of insurance against nuclear-related incidents that is available in the insurance market. Currently this insurance amount is approximately $375 million per plant. Monetary claims that fall within this insurance coverage are paid by the insurer. The Price-Anderson fund would then be used to make up the difference. Each reactor company is obliged to contribute up to $111.9 million in the event of an accident, amounting to approximately $11 billion if all of the reactor companies were required to pay their full obligation into the fund. However, this fund is not paid into unless an accident occurs.

If a coverable incident occurs, the NRC is required to submit a report on the cost of the incident. If claims are likely to exceed the maximum Price-Anderson fund value, the President must submit a proposal to Congress that details the costs of the accident, recommends how funds would be raised, and includes plans for compensation to those affected.

These comments provide no new and significant information and will not be evaluated in the SEIS.

Comment: Hope Creek remains a prime terrorist target, and there are many ways terrorists could prevail, only one of which will I list here.

Hope Creek's Spent Fuel Pool is above ground and not protected by containment.

It is a prime terrorists target. If the water in the Pool drains out, there would be massive radiation releases. SHC-23-11 Response: The NRC and other Federal agencies have heightened vigilance and implemented initiatives to evaluate and respond to possible threats posed by terrorists, including the use of aircraft against commercial nuclear power facilities and spent fuel storage installations. Malevolent acts remain speculative and beyond the scope of a NEPA review. The NRC routinely assesses threats and other information provided by other Federal agencies and sources. The NRC also ensures that licensees meet appropriate security-level requirements. The NRC will continue to focus on prevention of terrorist acts for all nuclear facilities and will not focus on site-specific evaluations of speculative environmental impacts resulting from terrorist acts. While these are legitimate matters of concern, they will continue to be addressed through the ongoing regulatory process as a current and generic regulatory issue that affects all nuclear facilities and many of the activities conducted at nuclear facilities. The issue of security and risk from malevolent acts at nuclear power facilities is not unique to facilities that have requested a renewal to their licenses. This comment provides no new and significant information and will not be evaluated in the SEIS.

8. Miscellaneous Comments Comment: Hope Creek emits continual amounts of low level radiation and radionuclides, which contribute to the cancer cases and immune system disorders in the 50 mile zone around Artificial Island. SHC-23-10 Response: Although radiation may cause cancers at high doses, currently there are no reputable scientifically conclusive data that unequivocally establish the occurrence of cancer following exposure to low doses, below about 10 roentgen equivalent man (rem)

(0.1 sievert (Sv)). However, radiation protection experts conservatively assume that any amount of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is higher for higher radiation exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the relationship between radiation dose and detriments, such as cancer induction. Simply stated, any increase in dose, no matter how small, results in an incremental increase in health risk. This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for radioactive effluents and radiation exposures for workers and members of the public. While the public dose limit in 10 CFR Part 20 is 100 millirem (mrem) (1 millisievert (mSv)) for all facilities licensed by the NRC, the NRC has imposed additional constraints on nuclear power reactors. Each nuclear power reactor, including Salem and HCGS, has enforceable license conditions that limit the cumulative annual whole body dose to a member of the public from all radioactive emissions in the offsite environment to 25 mrem (0.25 mSv). In addition, there are license conditions to

further limit the dose to a member of the public from radioactive gaseous effluents to an annual dose of 5 mrem (0.05 mSv) to the whole body and 15 mrem (0. 15 mSv) to any organ. For radioactive liquid effluents, the dose standard is 3 mrem (0.03 mSv) to the whole body and 10 mrem (0.1 mSv) to any organ.

Nuclear power reactors were licensed with the knowledge that they would release radioactive materials into the environment. NRC regulations require that the radioactive material released from nuclear power facilities be controlled, monitored, and reported in publically available documents. The amount of radioactive effluents released into the environment is known to be small. The radiation exposure received by members of the public from commercial nuclear power reactors is so low (i. e., less than a few mrem) that resulting cancers attributed to the radiation have not been observed and would not be expected. To put this in perspective, each person in this country receives a total annual dose of about 300 mrem (3 mSv) from natural sources of radiation (e.g., 200 mrem from naturally occurring radon, 27 mrem from cosmic rays, 28 mrem from soil and rocks, and 39 mrem from radiation within our body) and about 63 mrem (0. 63 mSv) from man-made sources (e.g., 39 mrem from medical x-rays, 14 mrem from nuclear medicine, 10 mrem from consumer products, 0. 9 mrem from occupations, less than 1 mrem from the nuclear fuel cycle, and less than I mrem from fallout due to weapons testing).

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have been conducted, there are no studies to date that are accepted by the scientific community that show a correlation between radiation dose from nuclear power facilities and cancer incidence in the general public. The following is a listing of a few studies recognized by the staff:

In 1990, at the request of Congress, the National Cancer Institute (NCI) conducted a study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The study covered the period from 1950 to 1984 and evaluated the change in mortality rates before and during facility operations. The study concluded there was no evidence'that nuclear facilities may be linked causally with excess deaths from leukemia or from other cancers in populations living nearby (NCI, 1990).

In June 2000, investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at the Three Mile Island power plant and cancer deaths among nearby residents. Their study followed 32, 000 people who lived within 5 miles of the plant at the time of the accident (Talbot et al., 2003).

The Connecticut Academy of Sciences and Engineering, in January 2001, issued a report on a study around the Haddam Neck nuclear power plant in Connecticut and concluded radiation emissions were so low as to be negligible and found no meaningful associations to the cancers studied (CASE, 2001).

Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are striking increases in cancer rates in southeastern Florida counties caused by increased radiation exposures from nuclear power plants. However, using the same data to reconstruct the calculations, on which the claims were based, Florida officials were not able to identify

unusually high rates of cancers in these counties compared with the rest of the State of Florida and the nation (Bureau of Environmental Epidemiology, 2001).

In 2000, the Illinois Public Health Department compared childhood cancer statistics for counties with nuclear power plants to similar counties without nuclear plants and found no statistically significant difference (Illinois Public Department of Health, 2000).

The American Cancer Society in 2004 concluded that although reports about cancer clusters in some communities have raised public concern, studies show that clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population. Likewise, there is no evidence that links strontium-90 with increases in breast cancer, prostate cancer, or childhood cancer rates. Radiation emissions from nuclear power plants are closely controlled and involve negligible levels of exposure for nearby communities (ACS, 2004).

In April 2010, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art study on cancer risk for populations surrounding nuclear power facilities. The NAS study will update the 1990 U.S. National Institutes of Health - NCI report, "Cancer in Populations Living Near Nuclear Facilities" (NCI, 1990). The study is scheduled to begin in 2010 and is expected to be completed within 4 years. Information from the report will be considered for incorporation into future updates of the NRC's guidance and regulations, as appropriate.

To ensure that U.S. nuclear power plants are operated safely, the NRC licenses the nuclear power plants to operate, licenses the plant operators, and establishes license conditions for the safe operation of each plant. The NRC provides continuous oversight of plants through its Reactor Oversight Process to verify that they are being operated in accordance with NRC regulations. The NRC has full authority to take whatever action is necessary to protect public health and safety and the environment and may demand immediate licensee actions, up to and including a plant shutdown.

The impact on human health of renewing the operating licenses for Salem and HCGS will be evaluated in Chapter 4 of the SEIS.

References 10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for Protection Against Radiation."

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of Production and Utilization Facilities."

10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."

55 FR 38472. U.S. Nuclear Regulatory Commission, Washington, D.C, "Waste Confidence Decision." Federal Register, September 18, 1990.

64 FR 68055. U.S. Nuclear Regulatory Commission, Washington, D.C, "Waste Confidence Decision Review: Status." Federal Register, December 6, 1999.

66 FR 5427. U.S. Nuclear Regulatory Commission, Washington, D.C, "Consideration of Potassium Iodide in Emergency Plans." Federal Register, January 19, 2001.

73 FR 59551. U.S. Nuclear Regulatory Commission, Washington, D.C, "Waste Confidence Decision Update." Federal Register, October 9, 2008.

74 FR 54859. U.S. Nuclear Regulatory Commission, Washington, D.C, "PSEG Nuclear, LLC, Salem Nuclear Generating Station, Units 1 and 2, and Hope Creek Generating Station; Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process." Federal Register, October 23, 2009.

American Cancer Society (ACS). 2004. "Cancer Facts and Figures - 2004." Available URL:

http://www.cancer.org/downloads/STT/CAFF finalPWSecured. pdf Bureau of Environmental Epidemiology, Florida Department of Health. 2001. "Report Concerning Cancer Rates in Southeastern Florida." In letter from David R. Johnson to Interested Parties, July 18, 2001. Available URL:

http://www.fpl.com/aboutlnuclear/contentsfdh report.shtml Connecticut Academy of Science and Engineering (CASE). 2001. "Bulletin of the Connecticut Academy of Science and Engineering," Volume 16.2. Hartford, CT, Spring 2001.

Illinois Public Department of Health. 2000. "Health and Hazardous Substances Registry Newsletter." Illinois Public Health, Division of Epidemiologic Studies, Illinois Department of Public Health, 605 W. Jefferson St., Springfield, IL, Fall 2000.

National Cancer Institute (NCI). 1990. Cancer in Populations Living Near Nuclear Facilities.

Bethesda, Maryland.

National Environmental Policy Act of 1969, as amended, 42 U.S.C. 4321 et seq.

New Jersey Department of Environmental Protection (NJDEP), Division of Water Quality.

Undated. "Factsheet for a Draft NJPDES Permit Including Section 316(a) Variance Determination and Section 316(b) Decision. Permit No: NJ0005622," undated. ADAMS Accession No. ML102280120.

New Jersey Department of Environmental Protection (NJDEP), Division of Environmental Safety and Health. 2009. "NJDEP Document Re Salem Hydrazine Spills," November 2009.

ADAMS Accession No. MLXXXXXXXXX.

Price-Anderson Nuclear Industries Indemnity Act, as amended, 42 U.S.C. 2210.

PSEG Nuclear, LLC (PSEG). 2009. "Applicant's Environmental Report - Operating License Renewal Stage," Appendix E of Application for Renewed Operating License, Salem Nuclear Generating Station, Units 1 and 2, Docket Nos. 50-272 and 50-311, August 2009. ADAMS Accession No. ML092430232.

PSEG Nuclear, LLC (PSEG). 2009. "Applicant's Environmental Report - Operating License Renewal Stage," Appendix E of Application for Renewed Operating License, Hope Creek Generating Station, Docket No. 50-354, August 2009. ML092430376 Talbott et al. 2003. "Long Term Follow-up of the Residents of the Three Mile Island Accident Area: 1979-1998." Environmental Health Perspectives, Volume 111, Number 3, pp. 341-348, March 2003.

U.S. Nuclear Regulatory Commission (NRC). 1984. Safety Evaluation Report Related to the Operation of Hope Creek Generating Station, NUREG-1048. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1992. Effect of Hurricane Andrew on the Turkey Point Nuclear Generating Station from August 20-30, NUREG-1474. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -

Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No. ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2009a. Transcript of Salem and Hope Creek License Renewal Public Meeting. Washington, D.C. ADAMS Accession No. ML093240195.

(afternoon meeting)

U.S. Nuclear Regulatory Commission (NRC). 2009b. Transcript of Salem and Hope Creek License Renewal Public Meeting. Washington, D.C. ADAMS Accession No. ML100471177.

(evening meeting)

Meeting Transcripts and Comment Letters The following pages contain the comments from the public scoping meeting transcripts and written comment letters.

MR.

WARE:

Thank you, Lance.

My name is Lee Ware, Director of Salem County Freeholders Board, starting my tenth year as a Freeholder.

I'm a little down today because my beloved Phillies went down.

And I guess it is only appropriate, since I was a baseball coach, for 38 years, I will be the lead-off hitter here today, Lance.

I'm coming before you, today, to let you know that PSEG Nuclear is a valuable asset to our county.

Not only are they great community

partners, but they are the county's largest employer.

They have been good neighbors, and good partners.

A majority of their employees are local residents, who live in our community.

PSEG takes a very proactive role in developing positive relationships with members of Salem County community.

Whether it is providing funding and support to local community groups, or attending every community event.

A lot of members here can attest to that.

We see each other quite a bit.

They are always demonstrating their commitment to Salem County's proud heritage and bright future.

We understand the hesitation of those within and surrounding our county, towards PSEG Nuclear.

SHC-1-1 J

Their concerns regarding

safety, and plant performance, are valid.

However, PSEG Nuclear has consistently demonstrated its commitment to safety, and excellence, through proper planning and transparency.

As life-long residents of Salem County, six miles as the crow flies from the reactors, I feel safe around the SHC-1-1 power plant, I have raised my children here, and they still reside here.

We have seen no negative impact to our environment, or community.

I support PSEG Nuclear and license renewal for the Salem and Hope Creek stations.

Their continued success is our success.

Thank you.

MR.

GROSS:

Good afternoon.

I'm Greg Gross, I'm director of government affairs with the Delaware State Chamber of Commerce, and we represent about 1,700 plus members of the business and corporate communities in the Delaware, throughout Delaware.

And when I was invited, and I want to thank you for the opportunity to come here and speak in support of one of our most valued partners.

And, quite frankly, when I was invited to come speak in

support, I knew about it, I wasn't totally educated about it, but I took a few minutes yesterday, and educated myself about what it means to the Delaware community.

I didn't realize that we have about in excess of three hundred employees, from Delaware, that come across that bridge each day.

But it is not just about the 300 folks that SHC-2-1 come across that bridge, it is also about the families they support.

About the economic structure in our community that it supports.

And also, too, I took a few minutes to query a few of our elected officials that are very involved, and plugged into the environmental community and said, you know SHC-2-2 what, Greg?

We don't worry about them, we don't worry, because they are safe, because they have gone that extra mile to be safe.

If there is something there that they know may be troublesome, they address it before it happens.

So that means something. I said, we don't worry.

There always will be, I'm sure, apprehensions to what goes on, and there always will be fear, I'm sure.

But as each year goes by I'm sure that that fear will slowly dissipate as things often do, with such things of this nature.

But we are happy that we do have such a strong partner involved in every facet of our community in Delaware.

As I said, I didn't realize how much, until I went back and I looked over some things.

And I was saying, wow, I mean it is just incredible SHC-2-2 what a strong partner.

And when you are going down the years of 2016, I think the other one was 2026, I don't know if I will be around in 2026.

I'm hoping I will be around in 2026.

But I hope that I am, and I hope I am back even more educated, and being able to speak more passionately about what I believe is the great work that is done.

And, most importantly, the safety and just preparing for what we are going to be facing in the years, as far as what we are going to need for our energy, and our needs.

It doesn't get any easier.

And, Lord knows, the need doesn't get any smaller, it gets even larger.

So with that said, you know, we give our total support in any way we possibly can, whether we -- whether in a letter, from our President, or any folks that are needed, within our community there, please don't hesitate to let us know.

Thank you, again, for allowing me to take a few minutes of your time to be here with you today, and I look forward to hearing additional comments, thank you.

SHC-2-2 J

MR.

DUFFEY:

Good afternoon.

I'm the current vice-chair, and the 2010 incoming chair of the Salem County Chamber of Commerce.

Approximately 400 businesses and community organizations are members of the Salem County Chamber of

Commerce, and this includes PSEG Nuclear, who is a long-time member.

On behalf of the Chamber, I would like the NRC to know that PSEG Nuclear plays a leading role in our community.

They have supported the Chamber's efforts to build relationships, within the community, and to make Salem County a premier place to live, work, and conduct business.

They purchase goods and services from dozens of SHC-3-1 local businesses, and Chamber members, and with our support they are helping to drive the local economy.

Earlier this. year PSEG Nuclear, hosted the Chamber Board of Directors for a tour of the Salem and Hope Creek facilities.

It became very clear, to the Board of Directors that PSEG operates in a culture of safety and security.

That visit also reinforced the Board's belief that PSEG Nuclear operations provide a safe and clean source of energy.

We also believe that nuclear power can help to combat

climate change, and that PSEG's operations will continue to play a positive role in Salem County's future.

Without these plants hundreds of people would be left without jobs, dozens of local businesses would struggle, and our local economy would suffer a great loss.

The Salem County Chamber of Commerce supports PSEG

Nuclear, and its plans for license renewal, for an additional 20 years of operation for Salem and Hope Creek.

Thank you for your time.

SHC-3-1 SHC-3-2

MR.

STEIN:

Thank you very much.

My name is Fred Stein, I work with the Delaware Riverkeeper

Network, it is a non-profit environmental advocacy organization.

I would like to thank the NRC for the opportunity to speak to the license renewal application submitted by PSEG and Exelon.

We understand the purpose of today's meeting, of the dual meetings, today, is to discuss the process around the license renewal and the requisite EIS scoping.

And I will speak directly to that.

But, first, the Delaware Riverkeeper Network wants to reaffirm our long-standing position, and call to convert the Salem generating station to a closed cycle cooling system, as mandated by the Section 316(b) of the Clean Water Act.

The Act states that generating plants, such as

Salem, shall be required that the

location, design, construction, and capacity of cooling water intake structures SHC-4-1 reflect the best technology available for minimizing the adverse environmental impacts.

The application before the NRC does not call for the compliance of the Clean Water Act, as it relates to the best technology available.

And it should.

According to our study, conducted by New Jersey DEP hired expert in

1989, as well as experiences at other facilities, installations of a closed cycle cooling towers, at

Salem, would reduce the fish kills from the Delaware river by 95 percent.

And dry cooling systems, at Salem, would reduce it even further, to 99 percent.

Speaking now, directly to the Environmental Impact Study, the Delaware Riverkeeper Network calls on NRC, and other reviewing

agencies, to hold the Applicant to the highest scientific and regulatory standards as they prepare the EIS.

Previous permits issued to PSEG were based on data that were found to be

faulty, misleading,

biased, and incomplete.

In 1999, for instance, when the data and arguments to support its case, that it should be allowed to continue to kill the Delaware River fish unimpeded.

Every year the Salem Nuclear Power Plant kills over three billion fish in the Delaware River.

That includes over 59 million blue-backed herring, 77 million weak fish, over 134 million arctic croakers, over 412 million white perch, over 448 million striped bass, and over 2 billion bay anchovies.

Even DEP's own experts agree that PSEG's assertions were not credible, and were not backed by the data and studies PSEG had presented.

In fact, according to an ESSA Consultant hired by New Jersey DEP, PSEG had greatly underestimated its impact on the Delaware river fish resources.

SHC-4-1 SHC-4-2 J

According to ESSA, PSEG underestimated biomass loss from the ecosystem by, perhaps, as many as two-fold.

And the actual total biomass of fish loss to the ecosystem is at least 2.2 times greater than was listed by PSE&G.

ESSA technologies' 154 page review of PSE&G's permit application, documented ongoing problems with PSE&G's assertions and

findings, including

biased, misleading conclusions, data gaps, inaccuracies and misrepresentation of their findings and damage.

Some of the examples of the EESA findings were with regards to the fisheries data and population trends, ESSA said the conclusions of the analysis generally overextended the data or results.

PSE&G underestimated biomass loss from the ecosystem by, perhaps, as many as two-fold.

Inconsistency in the use of terminology, poorly defined terms and tendency to draw conclusions that are not supported by the information presented detract from the rigor of this section and raises skepticism about the results.

In particular there is a

tendency to draw subjective and unsupported conclusions about the importance of Salem's impact on the fish species in the river.

And, finally, referring to PSE&G's discussions, and presentations of entrainment, mortality

rates, ESSA found SHC-4-2 J

PSE&G's discussion in this section of the application, to be misleading.

The ESSA report contained no less* than 51 recommendations for actions which PSE&G needed to take, on its 2001 permit application before DEP.

But that didn't happen, none of those happened.

It is our understanding that while DEP pursued some of these, many of them were never addressed, and still others were turned into permanent requirements to deal with over the next permit cycle.

In addition to ESSA recommendations, New Jersey DEP received comment from the State of Delaware, and the U.S. Fish and Wildlife

Services, both of whom conducted independent expert review of the permit application materials.

And found important problems with sampling, data analysis, and conclusions.

While we are urging you today, NRC, while we are urging you today to hold PSE&G as they go through this EIS process, to the highest standards, I want to reinforce our belief that I started my comment with, that --

I'm sorry, I jumped ahead.

I conclude by restating the fact that because Salem is clearly having an adverse environmental impact on the living resources of the Delaware river, and estuary, regarding PSE&G, SHC-4-2 J

we encourage you to hold them to the highest standards possible.

I'm sorry, I lost my place here.

We feel that it is important that, through the EIS process, that the data that PSE&G and its consultants bring to

you, is

complete, and unbiased, and that it is thoroughly looked at by the NRC, and it will be by the general public, too.

In a Philadelphia Enquirer editorial today, there SHC-4-2 was an article about nuclear energy, talking about that the NRC believes that it is the most regulated industry, and the most regulated government agency.

And it should be.

And we hope that those regulations are there to protect the natural resources of the'river and that we, again, hold PSE&G as they go through this process, to the highest standards possible.

Thank you very much.

DELAWARE RIVERKEEPER Testimony Fred Stine, Citizen Action Coordinator for the Delaware Riverkeeper Network 11/5/2009 I would like to thank the NRC for this opportunity to speak to the license renewal application submitted by PSE&G and Excelon. We understand the purpose of today's duel public meetings is to discuss the processes around the license renewal and requisite EIS scoping and I will speak directly to that.

But first, the Delaware Riverkeeper Network wants to reaffirm our long-standing position and call to convert the Salem Generating Station to closed cycle cooling as mandated by Section 316(b) of the Clean Water Act. The Act states that generating plants such as Salem "shall be required that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact." The application before the NRC does not call for the compliance of the Clean Water Act as it relates to best technology available.

According to a study conducted by a NIDEP hired expert in 1989 as well as experiences at other facilities, installation of closed cycle cooling towers at Salem would reduce their fish kills by 95%.

And dry cooling at Salem could reduce their fish kills by 99%.

Speaking now directly to the environmental impact study, the Delaware Riverkeeper Network calls on the NRC and other reviewing agencies to hold the applicant to the highest scientific and regulatory standards as they prepare the EIS. Previous permits issued to PSE&G were based on data which were found to be faulty, misleading, biased and incomplete. In 1999 for instance, when PSE&G's permit came up for renewal, the company submitted over 150 volumes of information, data and arguments to support its case that it should be allowed to continue to kill Delaware River fish unimpeded.

Everyyear the Salem Nuclear Generating Station kills over 3 billion Delaware River fish including:

Over 59 million" Blueback Herring Over 77 million Weakfish Over 134 million Atlantic Croaker Over 412 million White Perch Delaware Riverkeeper Network 300 Panoc Steet Second Floor Alnstol. PA 19(007

(?_!5 369 198 SHC-4-3 SHC-4-4

Over 448 million Striped Bass Over 2 billion Bay Anchovy Even NJDEP's own expert agrees that PSE&G's assertions were not credible and were not backed by the data and studies PSE&G had presented. In fact. according to ESSA consultants, hired by NJDEP, PSE&G had greatly underestimated its impacts on Delaware River fish. According to ESSA, PSE&G "underestimated biomass lost from the ecosystem by perhaps greater than 2-fold." (ESSA report p. xi) And "... the actual total blomass of fish lost to the ecosystem... is at least 2.2 times greater than that listed" by PSE&G. (ESSA Report p. 75)

ESSA Technologies' 154 page review of PSE&G's permit application documented ongoing problems with PSE&G's assertions and findings including bias, misleading conclusions, data gaps, inaccuracies, and misrepresentations of their findings and damage. Some examples of ESSA's findings:

" With regards to fisheries data and population trends, ESSA said "The conclusions of the analyses generally overextend the data or results." (p. ix)

PSE&G "underestimates biomass lost from the ecosystem by perhaps greater than 2-fold." (p.

xi) "... the actual total blomass of fish lost to the ecosystem... is at least 2.2 times greater than that listed in the Application." (p. 75)

" "Inconsistency in the use of terminology, poorly defined terms, and a tendency to draw conclusions that are not supported by the information presented detract from the rigor of this section and raises skepticism about the results. In particular, there is a tendency to draw subjective and unsupported conclusions about the importance of Salem's impact on RIS finfish species." (p. 77)

Referring to PSE&G's discussion and presentation of entrainment mortality rates ESSA found PSE&G's "discussion in this section of the Application to be misleading." (p. 13)

The ESSA report contained no less than 51 recommendations for actions which PSE&G needed to take on its 2001 permit application before DEP made its decision, but that did not happen. It is our understanding that while NJDEP pursued some of these (which ones we do not know because it was not referenced in the draft permit documents) many of them were never addressed, and still others were turned into permit requirements to be dealt with over the next 5 years.

In addition to ESSA recommendations, NIDEP received comment from the State of Delaware and USF&W, both of whom conducted independent expert review of the permit application materials and found important problems with sampling, data, analyses and conclusions.

While we are urging you today to hold the applicant to high standards, I conclude be re-stating the fact that because Salem is clearly having an adverse environmental impact on the living resources of the Delaware Estuary and River, regardless of PSE&G's self-serving claims based on faulty scientific studies, the Clean Water Act requires "that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact."

SHC-4-4 J

END

TOMELVAE

• EmI PRESS HO111E NE5VIETTERS RESOURCES PUU..ICAllOliS UNeS l:dct't Sliut Largest Predator in the Delaware Estuary Click Hert..or a ri.ter

.Friendly.Page Salem killb over 3 bllion RIS fh a year.

Every year the Salem NUckear Generating Station kills over 3 billion Delaware River fish including:

a Over 59 milion Blueback Herring o Over TT trllion Weakfith Over 134 million Atlantic Croatker

• Over 412 millilnte Perch SOve 448 rmillon Striped Bass a Over 2 blion Bay Anchovy (Figurs provided em rmbersof fh ký Sour. : oonrreorndence fram US Fish& WMwed Servce to NJDEP. June 30. 2000 rm4fg on PSEAG pemi aA hikaion data)

The pemit Issued was based on daib wh*.c-h faulty. naedlig based and missing Inrfoaon and data provided by PSE8O.

In 1999. when PSE&Gs permit COeM up for renewal, the cnrpany submitted over 150 vouinmes of Information, data and arguments to suppor its case that it should be allowed to continue to kill Delaware River ltsh uimpeded. To its credit. NJDEP tIok th advice of environmental groups including Delaware Rivertepr Network, ALS, NJEF, EAGLE, COA and the Coalition for Peace and Justice, and hired an independent expert to help then review PSE&Grs materials. But, to ft dcredit. NJDEP did not require PSE&G to address the many shottcomings and DEP apparently ignored their expert's flindings, just as they did with Versair in 1994.

ESSA Tecinologies' 154 page review of PSE&Gs pesnit applticaton documented ongoing problems with PSE&G's assertions and findings including bias, misleading conclusions, data gaps. Inaccuracies. and misrepresentatlons of their flindings and damage. Some examples of ESSA's findirgs:

I With regards to fisheries data and population trends. ESSA said 'The conclusions of the analyses generally overextend the data or results." (p. Ix)

" PSE&G 'underestimates biomass lost from the ecosystem by perhaps greater than 2-fold." (p. xl)

- the actual total blonass of Ash ot to o the ecosystem... is at least 2.2 times greater than that lWed in the Application." (p. 75)

" "inconlstency In the use of lenninology, poorly defned terms, and a tendency to draw conclusions tat am not supported by the infornation presented detract from the dgor of this section and raises skepticism about the results. In particular, them is a tendency to draw subjective and unsupported conclusions about the importance of Salem's impact on RIS finfish species." (p. 77)

" Referring to PSE&Gs discussio and presentation of entainment mortality rates ESSA found PSE&G'a discssion this section of the Application to be misleading.' (p. 13)

The ESSA report contains no less than 51 recomenndations for actions which PSE&G needed to take an iB 2001 permit applicatlon before DEP made Its decision, but that did not happen. It is our understanding that while NJDEP pursued some of these (whfich ones we do not know because it was not referenced in the draft permit documents) many of them were never addressed, and Sat others were tumed into permit requirements to be dealt with over the next 5 years.

In addition, NJDEP received comrnet from the State of Delaware and USF&W, both of whom conducted independent expert review of the permit application materials and found Important problems with sampling, data, analyses and conclusions.

PSE&G Continues to Polson Sensitive Marhlands Annually and Does Not Mttigation Salem's Fish Kills To date. PSE&G has applied over 22.000 pounds of herbicides, aerially and by hand. to 2.500 acres of sensitive marsh land. (Source: NJEF 2003 gyphosate analysis) The bosa of food, shelter and habitat are unacceptable.

http-//www.delawarerivetkeeper.orginewsresources/factshect.asp?ID--

I 1520 S11/5/2009

The wetlands experiment fats to reduce the Impngementr endfor entrainment impacts of Salem and therefore does not fU the requirements of 316(b), PSE&G is unable to demonstrate that their wetlands experirnent, even if successful (which is doubtful at best). actualty provides benefits to the estuary ecosystem.

" PSE&G takied to conduct any basetine data that would demonstrate whether or not food and habitat were limiting factors for the aquatic communities of the Detaware River system and therefore whether or not wetlands restoration could have contributed positively to their numbers.

" PSE&G is unable to demonstrate that the wetlands it is seeking to restore are superior, in tams of food and habitat for fish and other aquatic populations. than plregnfts. Scientific studies ara doorumenting that prragmfts in fact is not of Inferior value to sparina, that it does provide usable and used food, shelter and cover to both aquatic and terrestrial spades. Tharefom, PSE&G's entire wetlands experiment is based on a false premise.

" The sustainability of the wettnds phregmrnte reduction is dependent on annuial herbicide treatment.

" PSE&G has failed to demonstrate that even if it is successful at replacing the existing prragirifes in.

the Cohans"y and Altoway sites with other species of plants, that this change in vegetation is sustainable and vwil not be overnrm by neighboring stands of phragmitea within a matter of yearn.

" At the Alloways site the Interim goal was met through the removal of approximately 1.000 acres of Phrgmfts dominated wetlands from the restoration program-an action which then skewed the perceived results by removing tram the program a probtematic site

" Actions by PSE&G in the phragrnlfes dominated sites is not increasing fish utilization of those areas. PSE&G monitoring at Altoway Creek includes siles (a) dominated by Ptdogmifts. (b) donmnstad by Spertile or (c) under treatment for phregnritea removal (7Trsted" sites). PSE&G 2000 mondoring showed that within the Alioway Creek study area, fish abundance was similar at alt three types of sites. In 2002, fish abundance at the phrgrrm*a dominated site at Altoway Creek was apprmiametety twice as great as that sean at Spartitna dominated site and the treated site at Alowary Creek. Reproduction of mumnminio and Afantic siverside was seen in the phragmitas dominated sites both prior to and following the trea*ment of phregnft andgrowth patterns were seen to be similar for mutmnrchog end Aldraic silverside both pre anrd post treatment as well.

Studies also indicate that mumrilchog use pragmitea as a food source in phiragoms dominated sites, These results indicate that Phhrrgrs eradication has not demonstrated an Increased utilization of the sits by fish and/or increased fan production.

" Tidal flow has successfully retured to tho New Jereay salt hay farms. Not all sites have attatned percent coverage goals for spartlma coverage buft sparfina and other target species do dominate the three sites. The restored saet hay farms that were originally dominated by Spertina have readied the set goal of marsh coverage eater repeated herbicide applications (Dennis Township and Maurice River) but the one farm that was dominated by phragnma (Commercial Township) has not yet readied the Interim goal of 45% spartine coverage end doesn't come dose to the vegetative coverage of the reference marsh at Moores Beach.

" Young of the year fish assemblages in the soft hay farms were similar between the restored salt marshes and the reference marshes Inciuding size composition. seasonal patterns of occurrence and speces composition. White predator species such as striped bass and white fish were found to be utizing the restored salt hay farm marshes with a higher diversity of spades and a higher density of predator fsh as compared to the reference marshes, forage studies indisted that food habits of the fish were similar between the restored seat marshes and the reference marshes.

" According to PSE&G data 2000-2002 therm has been iftt to no usage of fish ladders instated at Garrison Lake or Coopers Lake. While evidence of spawning was seen in all sites except Garrison Lake, it does not appear that the stodcing efforts have been successful in establishing the return of offspring to the fish ladder sites. Three of the four sites with large numbers of fish utilizing the ladders received limited stocking. Indicating that the fish utilizing the fish ladders are most likely pioneers, rather than either retuming stocked fish or offspring of stocked fish. The shes that have received the largest numbers of slocied fish continue to show limited use of the fish ladders by adults.

PSE&Q's mltlgtilnhtornlo efforts are noti mirtlng the imprigeoent and entrainment Impacts of the Salem fsolity.

PSE&G data end analysis on the record as of 2003 does not demonstrate an increase in baywide abundance values of the representative important species or Atlantic shverside since PSEG completed the marsh restoration and fish ladder installations. Sbiped bass date is difficult to interpret as the abundance numbers in the Delaware are apparently linked to abundance in Chesapeake Bay. Overall, it appears that striped bass have increased, although this increase is not statistically significant. Weakfish and white perch declined in numbers after 1997. although the decine wae not stistically significant A decline was also seen for spot, bay anchovy, Atlantic silverside (1 994-2001), and American shad, with the decline being statistically significant for American shad when comparing 1991-1994 data to 1997-2001 data. Increases have been seen in blueback ern. although these increases am not statistically aigrficanL PSE&G's mitigationtrestoration effons are not mitigating the impingement and entrainment impacts of the Salem facitly.

The costs of cleosed cycle cooling at Salem has net been demonsitated to outweigh Its benefits.

It would cost only about St3 a year per rate-payer (assaurng an average electric bil of S100 a month) to install closed cycle cooling at Salem. This S13 would benefit the health of our fisheries as wae as commnercial and recreational fishing organizations and businesses.

PSE&G has been given over a decade to carry out fts aflemalsve strateg for 'mmrtigating' the impacts of Salem. It has been unable to demonstrate this program is beneficial to the environment and residents of New Jersey. It is lime to hold PSE&G accountable and to recuire implementation of closed cycle cooling al Salem http://www.delawarcriverkeeper.org/newsresources/factshe--t.asp'?ID~l I II1520 11/5/2009

MR.

HASSLER (AFTERNOON):

Good afternoon.

My name is Charlie

Hassler, and I came here to speak in support of the PSE&G licensing for the Salem and Hope Creek units.

I'm a lifelong-resident of Salem City, and I work down at the Salem Hope Creek nuclear facility for the past approximately 34 years.

I'm currently a business agent for the International Brotherhood of Electrical Workers, Local Union 94, which represents the organized labor who are employed permanently at the facility.

Additionally I'm a member of the New Jersey IBEW, the umbrella organization, with about 35,000 members.

New Jersey IBEW is also on record as supporting the relicensing efforts of the Salem and Hope Creek stations.

Our support is based upon understanding of how the NRC proceeds with the relicensing effort.

It is an informed rational support, and comes only with our belief that the safety of our members, and the public at large, will be assured by the continued operation of these plants.

The three units have been operating at capacity of about 90 to 95 percent in the past several years.

Prior to the outages now in progress at Salem unit 2, that unit ran for 515 consecutive days at a capacity factor of one hundred percent.

This type of performance can only be achieved through diligent processes, procedural adherence, while SHC-5-1 J

maintaining and operating the plants.

The personal standards of all workers are very high.

What other industry has improved the standards and operating capacities the way it has been done in nuclear?

This is truly the most watched, from the outside, and scrutinized from within.

The Institute of, Nuclear Power Operators, The Nuclear Management and Resource Council, and the NRC itself, does more internal evaluations than to groups in any other industry.

This is an industry that if you are not bumping the top quartile in performance, you had better have a better plan, or you are in trouble.

The output of the three stations SHC-5-1 supplies New Jersey with about 52 percent of its electric needs.

Producing this electricity is done without creating green house gases, which is an important and critical component to this discussion, given the global warming situation.

Without these

plants, the reliability of the electric delivery to meet demand would be put at risk.

Next, American's reliance on foreign energy imports continues to stress our economy, costing Americans

jobs, and putting the middle class, itself, at risk.

A sound energy policy is our nation's best

interest, and nuclear energy must play an important role in

that policy.

Finally, we must all recognize, that license renewal does not come open-ended, without ongoing monitoring.

Safety and performance standards, just as they are today, will continue for the entirety of the time the plant operates.

If the plant falls below the acceptable standards, myself and the members of my union, will be the first to speak out.

If a major issue, safety-wise arises in the future, you can all rest assured that the NRC has the ultimate power to come in, take away the keys, shut the doors, and close the plant down.

I SHC-5-1 Thank you for the opportunity to speak.

I/

MR.

HASSLER (EVENING):

Good evening.

My name is Charles Hassler, and I'm here tonight to speak in support of the PSEG's relicensing of the Salem and Hope Creek nuclear facility.

I have been on the facility, as a worker, for 34 years.

Right now I'm currently a business agent for the International Brotherhood of Electrical Workers, Local Union 94.

Additionally I'm a member of the New Jersey IBEW, which is the umbrella group in New Jersey that has an organization of about 35,000 members.

New Jersey IBEW also is on record as supporting the relicensing of the Salem and Hope Creek stations.

SHC-5-2 As I said, we represent the organized labor who are permanently employed on the island, at the facility.

Our support is based on our understanding of how the NRC proceeds with this relicensing effort.

It is an informed, rational, support.

And it comes only with our belief that the safety of our members, and the public at large, will be assured by the continued operation of the plants.

The three units have been operating at a capacity factor of about 90 to 95 percent for the past several years.

Prior to the outage that is going on right now at Salem unit 2,

that unit ran for 515 consecutive days at a capacity of over 100 percent.

This type of performance can only be achieved through diligent processes, and procedure adherence, while maintaining and operating the plant.

The personnel standards are high for all workers.

What other industry has improved the standards and operating capacity the way that it has been done in nuclear?

This is truly the most

watched, from the

outside, and scrutinized from within.

The Institute of Nuclear Power Operators, the Nuclear Management and Resource Council, and the NRC itself do SHC52 more internal evaluations than groups in any other industry.

This is an industry that if you are not bumping at the top quartile, you had better have a plan ready and in place or you will be in trouble.

The output of the three stations supply New Jersey with about 52 percent of its electric needs.

Producing this electricity is done without creating greenhouse gases, which is an important and critical component to this discussion, given the global warming situation.

Without these plants the reliability of electric

delivery, to meet

demand, would also be at risk.

Next, Americans reliance on foreign energy imports continues to

stress our economy, costing Americans

jobs, and putting the middle class, itself, at risk.

A sound energy policy is in our nation's best

interest, and nuclear energy must plan an important role in that policy.

Finally, we must all recognize that license renewal does not come open-ended, and without ongoing monitoring.

Safety and performance standards, just as they are today, will continue for the entirety of the time the plant operates.

If the plant falls below acceptable standards, myself and the members of this union, will be the first to speak out.

If a major safety issue arises in the future, we can all be assured that the NRC has the ultimate power to come in, take the keys, shut the doors, and close the plants down.

Thank you for your time.

SHC-5-2 J

MR.

FRICKER (AFTERNOON):

Good afternoon, and thank you for giving me the opportunity to make a

comment regarding the license renewal application of Salem and Hope Creek.

My name is Carl Fricker, and I'm the vice president of operations and support for PSE&G Nuclear, and I am part of the leadership team that is responsible for the safe and reliable operation of our plants.

I have over 25 years of both military and commercial nuclear power plant experience.

And I have worked at PSE&G Nuclear for the past 14 years.

I have had positions in operations, maintenance, quality assessment, and for the last four years, prior to my current job, I

was the plant manager at Salem.

At PSE&G we understand our obligation to the local SHC-6-1 community, to the environment, to our friends,

families, and coworkers, to provide safe,

reliable, economic, and green energy.

In New Jersey over 50 percent of the state's electricity comes from nuclear power.

In fact PSE&G Salem and Hope Creek Nuclear

Plants, is the second largest nuclear facility in the country.

Each day those plants generate enough electricity to supply three million homes.

In addition we are able to meet

the region's energy needs without emitting any green house gases.

Today nuclear power produces over 70 percent of our nation's carbon-free electricity.

We take great pride in that and recognize our important role in fighting climate change now and in the future.

As you hear earlier, our current operating licenses expire in 2016 for Salem unit 1, 2020 for Salem unit 2, and 2026 for Hope Creek.

In 2006 we made the decision to pursue license renewal.

We formed a dedicated team that worked for over two SHC-6-1 and a half years, or about 122,000 person hours, to prepare our application.

That was about 4,000 pages of application.

This review involved a review of thousands of documents, a detailed review of our equipment, and component performance, and a rigorous review of the existing maintenance and engineering programs, to ensure that Salem and Hope Creek will safely operate for an additional 20 years.

Over the past 10 years we have invested over 1.2 billion dollars in our plants, including last year's steam generator replacements at Salem unit 2,

and the various upgrades that supported Hope Creek's extended power uprate.

As part of license renewal we also reviewed any environmental impacts that, by continuing to operate, the Salem and Hope Creek nuclear plants for 20 years, would cause.

We consider ourselves environmental stewards, and since this is an environmental scoping meeting, I want to touch on this subject.

In addition to producing no green house gases, PSE&G has no adverse radiological impacts on our environment.

The NRC requires PSE&G Nuclear, and all U.S. nuclear plants, to maintain an environmental monitoring program, to monitor local radiation levels.

Annually we perform over 1,200 analysis on over 850 environmental

samples, including air, water, soil, and food products like milk, and farm crops.

All analyses samples are cross-checked with other laboratories to ensure precision and accuracy.

We are also closely monitored by the New Jersey Department of Environmental Protection's Bureau of Nuclear Engineering.

The Bureau of Nuclear Engineering independently monitors the local environmental around PSE&G Nuclear, through a remote monitoring system that provides real time readings.

The sampling and monitoring has shown that there is no adverse impact to the environment.

We are also proud stewards of the Delaware river and estuary, through our estuary enhancement program.

SHC-6-1 J

This program involves ongoing restoration, enhancement, and preservation of more than 20,000 acres of degraded salt marsh, and adjacent uplands within the estuary.

The estuary enhancement program is the largest privately funded wetlands restoration project in the country.

More importantly, it was created with extensive public participation, and open communication with regulatory agencies and the public.

As a result all the estuary enhancement program sites are open to the public, and offer boardwalks, nature trails, outdoor education, and classroom facilities.

Studies show that the overall health of the estuary continues to improve.

In addition, analysis of long-term fish populations in the estuary show that, in most

cases, the populations are stable or increasing.

And that fish population trends are similar through the other areas along the coast.

We also recognize our important role and impact to the local community.

PSE&G Nuclear is Salem County's largest employer with over 1,500 employees.

Some members of our workforce, as with all companies, are preparing to retire in the next few years.

As such we have looked to partner with local communities, with our local community, to meet our needs to SHC-6-2 SHC-6-3

providing good paying local jobs.

We have launched innovative partnerships with the Salem County Community College, and the Salem County Vocational Technical

schools, to develop specialized training programs.

Both have been overwhelmingly successful, and will lead to a skilled workforce that will only strengthen the local economy.

In Salem County we provide more than 1.4 million dollars, each year, to the local economy through local property taxes.

This funding is vital to supporting local schools and projects.

From an economic development point of view, we have also helped to drive the local economic development through projects like revitalization of downtown Salem, and the construction of the Gateway Business Park in Oldmans Township.

We are also active partners in the Salem Main Street Program, and the Salem County Chamber of Commerce.

Our support also goes well beyond dollars.

Many of our employees are active participants and supporters within the local community.

In addition to being a

good

neighbor, being transparent is an important aspect of building trust.

We are fortunate to have an excellent relationship with our local stakeholders, and that is not something we take for granted.

SHC-6-3 f

SHC-6-4

With them there is no surprises.

We are proactive 'N and engage them when challenges arise, so that they have an understanding of the challenges and have their questions answered.

This year we have provided more than 30 site tours for key stakeholder groups, close to 500 elected officials, educators,

students, community and trade groups, have been given an inside look at PSE&G Nuclear.

What better way to answer their questions than to let people see, first-hand, the important role of nuclear power.

By the end of this year we will also open the doors to our new energy and environmental resource center, that is housed at our old training center, on Chestnut Street in Salem.

This new information center will be used as an interactive display to educate the public about climate change, and the various ways we can all have a positive impact on our environment.

The center will be open to groups for tours, and provide meeting spaces for local organizations.

In closing, PSE&G Nuclear looks forward to working with the NRC, and the public, as you review our license renewal application.

We have worked hard to provide safe, reliable, economic, and green energy for the past 30 years, and look SHC-6-4 J

forward to the opportunity to build on this success in the future.

Thank you.

I SHC-6-4

MR.

FRICKER (EVENING):

Good evening.

Thank you for the opportunity to make a comment regarding the Salem and Hope Creek Nuclear license renewals.

My name is Carl Fricker, and I'm the vice president of operation support for PSEG Nuclear.

I'm part of the leadership team that is responsible for the safe and reliable operations of the plants.

I have 25 years of experience, both in commercial and Navy nuclear power programs.

And I have worked at PSEG for 14 years.

I have had positions in operations, maintenance, quality assessment, and my last job for the last four years, prior to my current job, was the Salem plant manager.

At PSEG we understand our obligation to the local community, to the environment, our

friends, families, co-workers, to provide safe, reliable, economic and green energy.

In New Jersey, as was mentioned, over 50 percent of SHC-6-5 the state's electric generation comes from nuclear power.

In

fact, PSEG Nuclear at Salem and Hope Creek is the second largest nuclear facility in the country.

Each day they generate enough electricity to supply three million homes.

In

addition, we are able to meet the region's energy needs without generating any greenhouse gases.

Today nuclear power produces over 70 percent of our nation's carbon-free electricity.

We take great pride in this,

and recognize our importance and our ongoing role in fighting global climate change now and in the future.

As was mentioned, our current operating licenses expire for Salem unit 1 in 2016, Salem unit 2 in 2020, and Hope Creek in 2026.

In 2006 we decided to pursue license renewal.

We established a dedicated team that worked for two and a half years, or 122,000 person hours, to prepare the station's application that is approximately 4,000 pages.

This involved the review of thousands of documents, a detailed review of equipment, components, and a rigorous review of existing maintenance and engineering programs to ensure that Salem and Hope Creek will safely operate for an additional 20 years.

Over the past ten years we have invested more than 1.2 billion dollars in equipment upgrades, which included, last

year, a

steam generator replacement at Salem unit 2,

and various upgrades that supported Hope Creek's power uprate.

As part of license renewal we also reviewed any environmental impacts that would occur having the plants operate for another 20 years.

We consider ourselves environmental stewards.

And since this is an environmental scoping meeting, I want to touch on the subject.

In addition to producing no SHC-6-5 J

greenhouse gases, PSEG has no adverse radiological impacts on the environment.

The NRC requires PSEG Nuclear and all U.S. nuclear plants, to have an environmental monitoring program to monitor local radiation levels.

Annually we perform over 1,200 analyses on more than 850 environmental samples, including air, water, soil, and food products, such as milk and farm crops.

All analyzed samples are cross checked with other laboratories to ensure precision and accuracy.

We are also closely monitored by the New Jersey Department of Environmental Protections, Bureau of Nuclear Engineering.

The Bureau of Nuclear Engineering independently monitors the local environment around, PSEG Nuclear through remote monitoring systems, that provide real time readings.

This sampling and monitoring has shown that there is no adverse impact to the environment.

We are also proud stewards of the Delaware

Estuary, through our estuary enhancement program.

This program includes ongoing restoration, enhancement, and preservation of more than 20,000 acres of degraded salt marsh and adjacent uplands in the estuary.

The estuary enhancement program is the largest privately-funded wetlands restoration project in the country.

More importantly it was created with extensive public SHC-6-5 SHC-6-6

participation, and open communications with regulatory agencies and the public.

As a result all estuary enhancement program sites are open to the public, and offer boardwalks, nature trails, outdoor education, and classroom facilities.

Studies have shown that the overall health of the estuary continues to improve.

In addition, analysis of long-term fish populations in the estuary show that most cases populations are stable or increasing, and that the fish population in this area trends are similar to other areas along the coast.

We also recognize our impact to the local community.

It was mentioned earlier that PSEG Nuclear is Salem County's largest employer.

We have over 1,500 employees.

As many companies are experiencing, some members of our work force are preparing to retire in the next few years.

As such, we have looked to partner with the local community to meet our needs and provide good paying local jobs.

We have launched an innovative partnership with the Salem County Community

College, and the Salem County Vocational Technical Schools, to develop specialized training programs.

Both have been overwhelmingly successful, and will lead to a skilled work force that will only strengthen our local economy.

In Salem County we provide more than 1.4 SHC-6-6 J

SHC-6-7 J

million dollars, each year, to the local economy through property taxes.

This funding is vital to the supporting of local schools and projects.

From an economic development point of view, we have also helped drive the local economic development

projects, like the revitalization of

Salem, and the construction of the Gateway Business Park, in Oldmans Township.

We are active participants and partners in the Salem Main Street Program, and the Salem County Chamber of Commerce.

Our support goes well beyond dollars.

Many of our employees are active participants and supporters within the local community.

In addition to being a good neighbor, transparency is an important aspect of building trust.

We are fortunate that we have an excellent relationship with our stakeholders, and it is not something that we take for granted.

With them we make sure that there are no surprises.

We are proactive, and engage them when a challenge arises, so they understand the challenge, and have the opportunity to ask their questions, and have answers.

This year we provided more than 30 site tours for key stakeholder groups.

Close to 500 elected officials, educators,

students, community and trade groups have been on-site to get an inside look at PSEG Nuclear.

SHC-6-7 J

SHC-6-8 J

What better way to answer questions than to let people see, first-hand, the important role of nuclear power?

By the end of this year we will also open our new energy resource and environmental center, housed at our old training center, which is on Chestnut Street in Salem.

This new information center will use interactive displays to educate the public about climate change, and the various ways we can all have a positive impact on our environment.

SHC-6-8 The center will be open to groups for tours, and provide meeting spaces for local organizations.

In closing, PSEG Nuclear looks forward to working with the NRC, and the public, as you review our license renewal application.

We have worked hard to provide safe, reliable, economic and green energy, for more than 30 years, and look forward to the opportunity to build on this success in the future.

Thank you.

DR.

CONTINI:

Good afternoon, thank you.

I am Dr.

Peter Contini, president of Salem Community College, a position that I have held for the past 12 years.

And in that capacity I'm here to acknowledge the support of the college for the license renewal of PSE&G for Salem 1 and 2, as well as Hope Creek.

We base that on our knowledge and experience.

And you have already heard that PSE&G Nuclear is certainly well regarded as a corporate leader in our county.

Certainly through their community leadership, both participating on groups, and supporting

groups, they have directly affected the quality of life in our county.

Additionally we have seen, first-hand, the highly SHC-7-1 professional organization that they are, focused on safety, and security.

And, certainly, generating a most valuable renewable energy

source, one that we think directly addresses New Jersey's energy plan 2020, as well as the potential growth in this county, and throughout the state.

We view them as, certainly, an economic development and workforce driver.

And we

know, first-hand, how that happens.

You just heard Carl speak about a

wonderful opportunity that came about as a result of that level of partnership.

We received, this past February, a 1.7 million dollar three year grant from the U.S.

Department of Labor, Community Based Job Training.

It has two focuses.

One, nuclear energy and, two, sustainable energy.

And the partners in that grant are PSE&G Nuclear as well as Energy Freedom Pioneers, working very collaboratively with our vocational school, Ranch Hope, Calgary Redevelopment, the New Jersey Department of Labor as well as Workforce development and, certainly, our one stop center.

Their support is not just verbal.

Their support is certainly implementing.

And as you know, and you heard Carl

say, there is going to be a growing need for employees, as certainly portions of the workforce ages out, and we hope, also, the expansion of opportunity in the future.

As a result we work collaboratively with PSE&G

Nuclear, in focusing on a particular area that we think is of great need, an energy, nuclear energy technician position.

We were able to couple with them, and partner at the national level with the Nuclear Energy Institute.

And we were selected as one of six community colleges, across the country, that are working on standardizing the curriculum to ensure that educational experience that our students have, will not only prepare them, but certainly ensure safety and security in the future in this field.

SHC-7-1 SHC-7-2 I

And you also heard about the center that has been revitalized in Salem City.

Well, I'm proud to tell you that a portion of that center will be hosting a portion of our program.

And through a high tech classroom, as well as laboratory facilities, our students will be working with state of the art equipment.

And, most importantly, be supportive both in scholarships, as well as internships.

So we see this as a real win-win.

Thinking about this, that we have only, in less than one year, been able to implement this program, we now have a fully accredited nuclear energy technician program, technology program, what we refer to SHC-7-2 as NET, we now have over 50 students in that program.

The corresponding program, Sustainable Energy, is also working at about 20 students.

We see that balance, and PSE&G Nuclear sees that balance, also.

And they have been very collaborative in working with Energy Freedom Pioneers, as we look for other alternatives to energy in addition to nuclear.

These are important

things, they are important things for our community and, certainly, for our students.

But they also go beyond.

Two years ago we had an emergency in our Salem center, hosting our one-stop career center.

A fire, a fire that immediately caused the dislocation of over 30 workers, and 200 clients a day.

Within two hours we had a commitment from PSE&G Nuclear to relocate that entire program to the former training center.

And within two days we were fully operational for the next four months.

It is an organization that understands their role in the community, certainly puts safety and security as a top priority.

But, more importantly, understand the value to our community.

And, for that reason, we fully support their SHC-7-2 SHC-7-3 relicensing.

Thank you.

MR.

BAILEY:

Good afternoon, my name is David L. Bailey, Jr.

I am the chief executive officer of Ranch Hope, Incorporated.

And, personally, I'm a lifelong resident, growing up within minutes of the Salem and Hope Creek in Alloway township, and now raising my family here, as well.

Ranch

Hope, Inc.,

is a

501C(3) non-profit organization, founded in 1964.

Again, our Alloway headquarters are within minutes of the Salem and Hope Creek facilities.

Our mission is to provide behavioral health care, educational, and adventure-based environments for children and families from throughout the state of New Jersey, and within the Delaware Valley.

Through its generosity and support of local organizations, such as Ranch Hope, PSE&G Nuclear has touched SHC-8-1 the lives of thousands of residents, making our community a better place to live.

At Ranch Hope's Alloway campus PSE&G Nuclear supports our efforts to create a green community for children with treatment and educational facilities, not only environmental responsible, but energy efficient, and healthy for children and staff to live and work.

This unique collaboration with PSEG Nuclear not only focuses on changing the lives of children and families,

but also energy efficiency, two topics you don't normally see SHC-8-1 together.

J Just as importantly, PSEG Nuclear demonstrates a

'level of transparency within our community here in Salem County.

Nuclear power represents a mystique that many of us will never fully understand.

However, PSEG Nuclear has taken the time to keep the local community informed.

Groups of key stakeholders, which I

was humbled to be one

myself, including elected officials, educators, business and community leaders, recently toured the Salem and Hope Creek facilities, and we learned, SHC-8-2 first-hand, the importance of nuclear power.

As someone who was fortunate enough to visit these two generating stations, I feel even more comfortable, having seen the safety and security measures they take to provide us with clean, reliable energy, on an every day basis.

This being the case, Ranch Hope, and the families and the communities that we support, fully support the license renewal applications for PSEG Salem and Hope Creek nuclear facilities.

Thank you.

MS.

WICHMAN:

Hi, my name is Kelly Wichman, and I'm an employee of PSEG Nuclear in the nuclear fuels department.

I'm a safety analysis engineer, and this is my first full-time job.

Both my husband and I

moved to Woodstown, New Jersey, just down the road, from the midwest a year and a half ago, to take positions at the Salem and Hope Creek site, and we bought a house here, with the intentions of staying for some time.

I came here today because I believe that Salem and Hope Creek should be granted operating license extensions.

I chose a position in the nuclear industry because I think it has staying power.

I majored in engineering in

college, with the intention of coming into this industry.

And, as I progressed in my education, I

found more and more reasons why nuclear power is really a great option for electricity production.

From an engineer's standpoint, nuclear fuel is one of the most efficient fuels producing thousands of times more energy than a

chemical reaction with the same amount of material.

Say, for example, coal, oil or gas.

In addition, the land footprint is

small, compared to other generating options which, to me, makes nuclear power an obvious choice in a world where finite resources are available.

SHC-9-1 J

My position at PSEG Nuclear has provided me an opportunity to explore new parts of the country, and I have taken advantage of living within a few hours of so many cities.

I have also taken advantage of all the career-related opportunities offered by my job.

I have joined two professional organizations, the North American Young Generation in Nuclear, and the American Nuclear Society.

With Young Generation in

Nuclear, I

formed relationships with more of my coworkers, attended professional development conferences, participated in charity drives, and taught kids in the area about power generation at the Salem Votech.

With those organizations I have seen the positive influence that the plants have on the area, and on the people.

I work there because I feel that the opportunities are great, and I feel that I'm doing something meaningful, by helping produce electricity that everyone uses.

I believe the plant's continued operating presence in the area will only be of benefit to the community.

Thanks.

SHC-9-1 J

MS.

NAGAKI:

So my name is Jane Nagaki, and I'm vice-chair of the New Jersey Environmental Federation, which is the state's largest non-profit environmental organization.

And we raise several environmental issues regarding the relicensing.

First I would like to support the comments of Fred Stein, from the Riverkeeper.

And I won't repeat everything that he said, but the Environmental Federation is, also, very firmly committed to the idea that if the relicensing goes forward, on Salem 1 and 2, that best available technology should be applied at those plants, which would be cooling towers to offset the millions of gallons of water that cycle through that plant every day.

There has been a lot of talk, today, about how nuclear energy produces no air emissions.

And, generally, when we think about environmental impacts we are thinking air, releases to the air, releases to the water, releases to the land.

And while it is true that there may be no air emissions, from the plant, there certainly is a consumptive use of millions of gallons of water a day, run through the cooling cycle, and then discharged back into the Delaware Bay, with a concurrent loss, as Fred mentioned of billions of fish per year, in all stages of life, from larval stage, to small stage,

'N SHC-10-1 J

to large scale fish that are impinged on the once-through cooling system.

Which I have toured, by the way, and witnessed the huge structure that takes through millions of gallons of water a day.

So if there is one environmental issue that I would like to highlight today, is the impact of the Salem Nuclear Plant on water in the Delaware Bay, and the concurrent fish and wildlife that that water, the Delaware Bay supports.

We talked about nuclear energy as being a major employer in this area, and I'm certainly respectful of the workers that work there, that keep the plant safe every day, and the niche in the economy that it provides.

But there is, also, a huge other economy in the Delaware Bay that is the fishing industry, that is severely affected by the operation of this plant.

And so if I were to say the huge, the most huge environmental impact of this plant, is the impact of water, in that once through cooling system. That needs to be addressed in the Environmental Impact Statement.

As far as, you know, there is no radiation produced at this plant, there is some radiation produced at this plant.

It meets limits, so called acceptable limits.

SHC-1O-1 J

SSHC-1O-2

There is waste that is stored on-site.

And so another environmental

issue, that the Environmental Impact Statement should address, is how much more waste is going to be generated and stored at the plant, at those enclosures that SHC-10-2 currently keep all the waste, ever produced at that plant, on the site forever.

So waste production concurrent with the relicensing is another very major environmental issue.

What is unique about our community?

What is unique about artificial island, is that it is an island that was constructed of dredge spoil material.

It is not an island that existed before the geology of the time.

So one of the concerns, environmental concerns would be how stable is the structure of the island to support this plant for another 20 years.

Or three plants, actually.

I think that issue will be addressed, more SHC-10-3 specifically, tonight by another environmental group.

What is the effect of sea level rise?

We talked about global warming and how nuclear power doesn't produce the kinds of emissions that contribute to global warming.

But there is global warming going on, and there is sea level rise.

What is the effect of sea level rise on the plant's artificial island?

You know, is the island going to be inundated with water, how much over the next few years?

Does more infrastructure need to be built there to support the plant?

We know that salt water, and the effects of the salinity of the bay have contributed to the rusting out of parts of the plant.

We know that there has been extensive replacement of structures, and underground piping at the plant.

And that is both, you know, that is an environmental impact, the salinity of the area, on the integrity of the structure of the plant.

And that is an environmental issue that needs to be integrated into the safety and the aging issues of the plant.

Let's see.

So going back to another impact, and the result of the Salem 1 and 2 plants, not having cooling towers is that PSEG Nuclear entered into a very large estuary enhancement program, which was referred to earlier, preserving 20,000 acres of wetlands.

And I would be remiss if I didn't mention a concern that environmental groups raised at the beginning of the restoration project, because many of the acres of wetlands were restored simply by breaching dikes of old salt hay farms, and allowing inundation of phragmites by salt water.

And thus controlling the phragmites, and growing a more beneficial kind of vegetation, called Spartana.

But there are acres and acres of phragmites, you know what they are, the tall waiving foxtails, as they are often called, which were SHC-1O-3

> SHC-1O-4

considered nuisance vegetation, or not favorable vegetation in the wetland restoration.

And so in order to control that phragmites, massive aerial herbicide event took place starting in 1995 and

'96, over 2000 acres were really sprayed with a pesticide called Glyphesate.

And it was thought that

one, maybe two applications of that herbicide would take care of the problem.

But, to this day, in the year 2009, and continuing on until at least 2013, annual applications by herbicide by aircraft are made to wetlands, as part of this project.

The acreage is down now, to around 120 acre realm.

But it has been as high as thousands of pounds of a year.

And so one of the environmental issue raised by this is, is there going to be continued applications of an herbicide, in wetland areas, as part of this restoration project, which was meant to offset the impacts caused by the lack of cooling towers.

The reason we are concerned about this application of herbicides is that it actually triggered an increase in the use of this herbicide, state-wide.

PSEG kind of became the model for how to restore wetlands.

And so many other wetland restoration projects began utilizing this methodology.

And the result has been a nine-fold increase in the use of Glyphesate in the state of New Jersey.

SHC-10-4 J

And so while the use at this particular Alloways creek area is decreasing, not over yet, but still decreasing, the increase in the use, state-wide, is of concern because as you know pesticides generally have a habit of infiltrating our groundwater and surface water.

They become part of our drinking water, part of our surface water.

And the effects of this herbicide has been linked to cancer effects, birth defect effects, effects on fish, insect populations, and so forth.

So we certainly raise this as an issue that needs to be addressed, because nobody has really looked at the cumulative impact of this year, after year application of herbicide to control a nuisance plant, all in the name of restoring wetlands.

So I

think that is the extent of the issues I

wanted to raise today.

But I do want to say that some of the safety concerns, and environmental concerns, are related mainly to this issue of the aging of the plant, the salinity, the lack of a firm under-structure to the plant, all make the plant more vulnerable to failures of structure that could lead to an environmental release of radiation, which is the ultimate disaster that everybody fears at this plant.

And so while the radiation leakage

issue, and emissions issue, is not a day to day concern, you know, when SHC-10-4 SHC-10-5

the plant is operating optimally, if there isn't an aggressive strategy for preventive maintenance, that not just waits for something to happen, and then addresses it, but actually anticipates and replaces structures as they age, before they age.

This vulnerability will continue, you know, to be of great concern.

That concludes my remarks, thank you.

SHC-1O-E

MR.

WALL:

Good afternoon, I'm Roland Wall, I'm the Director for the Center for Environmental Policy at the Academy of Natural Sciences in Philadelphia.

On behalf of the

Academy, I

appreciate the opportunity to

comment, specifically, on the environmental protection and restoration demonstrated in PSEG's estuary enhancement program.

Just a little context as to why the Philadelphia Museum is down here making these comments today.

The Academy of Natural Sciences is the oldest natural history museum in North America but has also been engaged, for over 60 years, in research on ecological sciences, particularly on understanding human impacts on aquatic and estuarian systems.

It is in that role that we have had extensive research on the physical and biological characteristics of the Delaware

estuary, including components of the estuary enhancement program.

My comments today are based on observations of Academy scientists, particularly those of our senior fishery scientist, Dr. Rich Horowitz, who is unable to be here today.

The estuary enhancement program began in 1994.

And, since that time, has been a large scale effort to restore and preserve portions of the Delaware estuary, in both New Jersey and Delaware, encompassing more than 32 square miles, as SHC-11-1 J

you heard earlier, it is the nation's largest privately-funded wetlands restoration project.

Restoration efforts have included the goal of replacing former salt hay farms, as you heard.

And also to remove marshes that are dominated by the invasive phragmites, with saltcord grass dominated marsh.

This has required a substantial effort to control phragmites, and to change drainage patterns to foster topography and tidal flow typical of Delaware Bay salt marshes.

The Academy has studied many of these sites, prior to restoration and a number of them following restoration.

Yes, the enhancement program has been successful in restoring typical salt marsh conditions at these sites, with most sites being targets for reduction of phragmites, and establishment of salt cordgrass.

At the remainder of sites where goals have been partially met, the estuary enhancement program continues to work to further improve marsh conditions.

The EP has also preserved open space, as at the bayside track.

Among other improvements at the restored sites, tidal flow and development of tidal channels have increased, allowing for re-colonization of salt cordgrass and other species.

SHC-11-1

The restored marshes support large numbers of targeted fish species, as well as number of other fishes and invertebrates.

These populations continue to --

excuse me, contribute to bay productivity, most notably, at the salt hay farms.

The restoration sites also provide important habitat for terrapins, birds, and mammals, and several of the sites are now part of New Jersey's Audubon designated important bird areas.

In addition to ecological restoration, the enhancement program has developed increased opportunities for human use and experience, to interact with the estuary.

Public use areas were designed to meet the general education, public access, and ecotourism interest of each community hosting an EEP site.

This has included improved access to many of the sites by land and water, with boat access and parking areas, in turn, supporting extensive recreational activities.

The public use areas have become important settings for numerous formal and informal educational programs.

The restored areas have also become significant research sites, and research by

EEP, and other organizations, including the Academy, has advanced our knowledge of tidal marsh ecology.

SHC-11-1

)

SHC-11-2 J

The basic restoration activities, particularly controlling phragmites and fostering development of tidal marsh topography and hydrology, have advanced the field of ecological restoration.

The ecological engineering technique of forming primary channels, and then using estuarian processes to further develop channels and topography, is especially notable.

And in that way the estuarian enhancement program does provide an important model for marshland restoration.

PSEG has also installed fish passage structures at dams in Delaware and New Jersey.

These fish ladders have established river herring spawning in nursery areas, and several impoundments, increasing bay-wide populations of these species.

PSEG has continued to conduct monitoring programs of Delaware fish populations, which greatly increase our knowledge of Delaware Bay fisheries.

To conclude, the Academy would like to commend PSEG on its demonstrated initiative, and long-term commitment to restoring the critical wetlands of the Delaware estuary.

The estuary enhancement program has had numerous positive impacts on the ecology and biodiversity of the region, and has made important contributions to the recreational and educational opportunities available to local communities.

SHC J

The scale and scope of this effort has supported large scale scientific research, has improved our understanding of the process of environmental restoration.

The Academy of Natural Sciences has been pleased to have the opportunity to participate in, and to contribute, to our scientific expertise to this project.

Thank you for the opportunity to speak on this.

SHC-11-3

MS.

ACTON:

Good evening.

My name is Julie Acton, I'm a Salem County Freeholder.

For those who do not live in New Jersey, I'm equal to a county commissioner.

New Jersey is the only state to have freeholders.

I am also a

member of the Dupont Advisory Committee.

I am a volunteer for Meals on Wheels, and United Way.

I'm a member of the Salem Community College, the Salem County Vocational Technical Advisory

Board, and I'm very involved in my community.

So I pretty much have the pulse of the community at my fingertips.

I am coming before you, this evening, to let you know that PSEG Nuclear is a valuable asset to our county.

Not only are they a great community partner, but they are the county's largest employer.

A majority of their employees are local residents, who live in our community.

In tough economic times PSEG Nuclear provides an example of integrity and commitment to positive growth that we all need to see.

PSEG Nuclear takes a

very proactive role in developing positive relationships with members of the Salem County community, whether it is providing funding and support to local community groups, or attending their events.

They are always demonstrating their commitment to Salem County.

And they acknowledge our proud heritage, and

}

SHC-12-1 SHC-12--

} SHC-12-B-

recognize our bright future.

We understand the hesitation of those within, and surrounding our county, towards PSEG Nuclear.

Their concern regarding safety and plant performance are valid.

However, PSEG Nuclear has consistently demonstrated its commitment to safety and excellence through proper planning and transparency.

As a life-long resident of Salem County, and having raised my children here, I feel safe around the power plant.

We have not seen any adverse impact to our environment, or our community.

I wholeheartedly support PSEG Nuclear and their license renewal for their Salem and Hope Creek stations.

Thank SHC-12-'

you very much for your time.

MS.

BERRYHILL:

Well, this is a little different.

My name is Frieda Berryhill, I'm from Wilmington, Delaware.

I have been involved with Salem before it was licensed to operate, for the simple reason that Delmarva Power and Light, at the time, also planned to build a nuclear power plant right across the river from here, which would have made this area the largest nuclear complex in the world.

I was an intervenor, a

case I

couldn't

lose, because they ordered a high temperature gas-cooled reactor, and you know what happened to that.

I'm very concerned about this.

I attended many hearings on the subject, ever since 1970.

These plants should never have gotten a building permit.

Upon examining the documents I

found, to my shock, clearly described in detail, on the large map, the soil condition of artificial island.

You see, there was no land here.

It is called Artificial Island, because the island is built from dredgings of the Delaware River.

And in the documents you will find that the borings of 35 feet are essentially nothing but mud and SHC-13-1 sand.

The next 35 feet are gravel and sand.

The last 35 feet are described as Vincentown Formation, which is a J

different kind of gravel and sand.

Borings up to 100 feet have not revealed rock bottom.

There is no rock bottom under these plants.

The spent fuel pools, the auxiliary buildings, all of it, is sitting perched on cement pilings, I call them stilts, going 75 feet into the mud.

And that is what is holding these plants up.

Now I have with me pictures of toppled buildings that have simply collapsed with the pilings still sticking to them.

And I am deeply concerned to have a fourth reactor on that island.

SHC-13-1 Liquefaction is discussed in the documents.

Liquefaction is the phenomenon when there is an earthquake, not a major earthquake, the sand is liquefies, and the building --

the hundreds of examples all over the world, where you can find that.

And you can find some of it even on Google.

And I have made statements to that effect before the Delaware House Energy Committee, and other agencies.

It doesn't seem to really matter what citizens say.

Yes, there was an earthquake up in Morris County.

It

was, actually, quite sizeable.

But there is an earthquake fault, also, on the Delaware River.

And, really, it scares me SHC-13-2 I/

to think that it is only a matter of time, really, that an earthquake could happen here.

The Morris earthquake threw people out of the

house, they thought there was a big explosion somewhere.

It was not just a minor shaking or rattling.

Now, as to what could happen, I would like to just go back to the Rasmussen report, which was produced in 1970, as to the safety of nuclear power plants.

That wasn't satisfactory, so they commissioned another report in 1985, called "Consequences of Reactor Accident",

called the "Crack Report".

To just --

the numbers are just staggering.

The Crack Report for Salem reads as follows:

Early peak fatalities, 100,000 Salem, 100,000 Salem 2.

Early peak injuries, 70,000 for Salem 1, 75,000 for Salem 2.

Peak cancer

deaths, Salem 1

40,000, Salem 2,

40,000.

Damages, Salem 1, 140 billion, Salem 2, 135 billion.

This is not fantasy, this is the government report.

I would like to interject, recently I wrote an article as to the soil conditions of this thing.

And in that article I mentioned the Price-Anderson Act, that nuclear power plants could never be built without the protection of the Price-Anderson Act.

SHC-13-2 SHC-13-2

And some gentleman from the NRC felt compelled to write an answer to the local Wilmington paper saying, we don't depend on the Price-Andersbn Act, we have 9 billion dollars in reserve for whatever damages we cause.

It makes me laugh, because there is no comparison to the damages that could be caused.

Nine billion dollars is pocket change.

SHC-13-3 Clearly this plant should have never received a building permit, and surely it should not receive a license to operate for another 20 years.

They were originally licensed SHC-13-4 for 40 years.

You are dealing with embrittlement, and all sorts of problems with that.

There was a reason for it.

Now, also, actually these plants were operating against the law, with more than three billion fish killed, annually, from the Delaware River.

And anything under three inches is taken up through the intake structure.

The NEPA Act, which you have mentioned, which was passed in

1969, was passed just because SHC-13-5 this kind of damage.

On December

18th, 2001, Congress allowed these once-through cooling systems to continue as long as they restored the fish killed.

Now, I saw that you had a display back there about that Habitation Restoration Act of 2001.

But are you really raising fish?

Twenty-thousand tons of poison were spread to kill the phragmite.

You can't kill that phragmite.

I looked at the picture that you had back there, that phragmite keeps coming up.

How many tons of poisons are you going to spray over there?

Now, I was just told, a while ago, that you are replacing the fish.

I would like to know how many fish that you are replacing, and what the story is on that.

Incredibly,

though, that PSEG announced that it planned to spend another 50 million between 2007 and 2011 to explore the potential to construct a new reactor on the island, a fourth reactor.

I think not.

I would like to ask a few questions, if I

may.

Nine billion dollars somewhere in the reserve.

Can anybody, at the NRC, tell me who is holding this nine billion dollars?

I have a letter written to the editor, don't worry about Price-Anderson, we have nine billion dollars.

FACILITATOR BURTON:

Ms.

Berryhill, unfortunately we don't have the NRC staff here who would really be qualified to answer your question.

MS.

BERRYHILL:

Who would have that nine billion?

Well, I will see if I can find out another way.

Has the company made any request for dry-cask SHC-13-5 SHC-13-6 SHC-13-7 storage?

FACILITATOR BURTON:

Again, we really do not have the subject matter experts here to answer that question.

MS.

BERRYHILL:

All right.

FACILITATOR BURTON:

You have one more question?

MS.

BERRYHILL:

Yes, I

do.

With Yucca Mountain canceled you will have to, eventually, go the dry cask storage, I just want to know how soon, or whether you have made any plans, and who is producing them.

You don't know that?

Okay.

Now, you made a great deal about respecting public input.

You had 20 license renewals approved now.

None have been refused.

I just wonder how much public input has really worked in these cases.

None have been disapproved.

And some of them, by my estimate, should not have been approved.

I have been to the NRC reading room in Washington, and there are records of every plant in there.

Does Salem County have as complete a file as I would find it at the NRC reading room?

Salem County library?

Everything is in there?

MR.

ASHLEY:

The application is at the library.

FACILITATOR BURTON:

Hang on a second, let me give you the microphone here.

MR.

ASHLEY:

The license renewal application is at the Salem Library.

But all the other documents are at the reading room at the NRC.

SHC-13-7 SHC-13-8

MS.

BERRYHILL:

At the reading room at the Nuclear Regulatory Commission, okay, thank you very much.

"I SHC-13-8

MS.

WILLING:

Hi, my name is Nancy Willing, and I am from

Newark, Delaware.

I'm a life-long Delawarean.

While I have never held elective office, I thought I would respond to Ms.

Acton, by maybe saying some of my civic responsibilities as well.

But my dad was a plant manager for the plant here in New Jersey.

Growing up he took the ferry in the '50, and got the bridge when it was built, the second bridge.

As a citizen of Newcastle County, I formed up the Friends of Historic Glasgow, interested in preserving historic battle sites.

I have been on the board of W3R, Washington Rainbow Route.

I was recently on the Board of the Civic League for Newcastle County.

And I'm also a Director of the Board of the Community Center in Wilmington, on the east side of Wilmington.

So I have a variety of interests.

I've also ended up in frustration, from what a citizen can do, I ended up writing a political blog.

So I also now write the Delaware Way blog with daily input.

And I have written about -- Frieda is a contributor to the blog.

So a lot of that is googable.

And we try to keep the information out there.

I was at the 2009 emergency evacuation public SHC-14-:

hearing, here in New Jersey.

And it was an interesting meeting

for me because although Delaware is at risk, or in the 50 mile

radius, we don't get this kind of attention, we don't have public hearings.

And I imagine that --

I was told, as I got here today, that some feelers went out to see if Delaware wanted to have a meeting similar to this, and it was not --

that didn't happen.

But that the emergency evacuation public meeting the state held, I didn't -- well, I will just go right to this.

I don't agree with the renewal of the 20 year licenses for the 40 year old structures that exist here today.

I don't think it is a wise and reasonable choice for the citizens.

We do enjoy the energy that comes out of them, but we also have to expect to live our full lives here in this area.

A 40 year life span pretty much says it all, it is a 40 year life span, and the thought of another 20 year service from the Salem and Hope Creek structures seems to be asking too much, and offering uncertainty and trepidation to the public.

With age come leaks and cracks.

The life span of potential contamination isn't worth that bargain, in my view.

While speaking with the state official from the Bureau of Nuclear Energy at the New

Jersey, before the evaluation hearing had started I asked about having heard that Salem was built on swamp land.

SHC-14-1 SHC-14-2 f

SHC-14-3

And the gentleman, whose name I don't have here, he said of course not, and he proceeded to claim that the pilings went on through the sand, and gravel on Artificial Island, and were drilled securely into the bedrock.

So that was the opinion stated at that meeting, to me, by an official from the Bureau of Nuclear Energy here in New Jersey.

So I took the question to the record, when I had a chance to

speak, and formally ask the

question, about Artificial Island structures, do they actually secure into bedrock, or don't they?

Because Frieda Berryhill had told me that in her investigations, that they had not.

So I asked, for the record, and the officials promised me that they would investigate that discrepancy, and give it back to me in

writing, which they never did, I never got anything from them.

My concern was based on having heard that yet one more unit was planned to be constructed at the Salem complex.

For the structures to be floating on a bed of gravel, and sand, and the result of a significant earthquake, six or seven on the Richter scale, would mean that the base of the structures, containing this nuclear

material, would likely experience liquefaction, which Frieda got into a little bit.

That is the changing from compression of the earthquake, of the gravel and sand mix, into a jelly-like SHC-14---

material.

Liquefaction of the ground underneath causes structures to tip, slide, collapse, and otherwise break apart.

It was an unhappy coincidence that the evacuation hearing was on the same day as the earthquake.

So it was an interesting experience.

Another earthquake was centered a few miles away from the Salem plant.

And although it wasn't more than maybe two on the Richter scale, I'm not sure what it

was, it isn't unheard of to think that we would have a more significant earthquake.

The officials told me, that day, that the structures are built to withstand up to six or so on the Richter scale.

But would that prevent a significant earthquake, SHC-14-3 maybe not up to that, would that prevent the leaks and cracks of an aging plant that is floating on a bed of gravel and sand, so to speak, should another earthquake occur.

So the scope of the licensing process, here today, I think should be investigating that these are drilled into bed rock, that they are subject to liquefaction, and that would the aging of structures, brittle, would the aging, basically, have an impact on potential earthquake activity and contamination of the environment?

And I think that is, hopefully that would be in your scope, some serious study of that.

So, thanks.

MS.

BEISTLINE:

Hello everyone, good evening. My name is Monica

Baseline, I

work as a chemical systems engineer at Salem Generating Station.

I'm here tonight representing NAYGN, which is the North American Young Generation of Nuclear.

This group unites young professionals who believe in nuclear science and technology, and show the passion for the field.

Within this chapter I'm our environmental committee

chair, and I

enjoy spending my weekends

camping, hiking, biking, and my favorite, rock climbing.

I graduated with a chemical engineering degree, which gave me a choice of fields after graduation.

After much deliberation and interviewing, I narrowed these choices down to two industries, petroleum refining, and nuclear power.

I

remember, specifically, at dinner during the interviewing process, for refining

jobs, about your ethics matching your company's ethics.

Without this you can't ensure happiness and the ability to be passionate about your job.

I saw our country's dependence on fossil fuels diminishing, and I

was not secure in my

future, in the petroleum industry.

I wanted to make sure that I worked for a company that I did not believe had a negative impact on the environment I enjoyed on the weekends.

I worked with PSEG for more than a year and within this year I have received less than three millirem of dose.

SHC-15-1 JI

This is about half as much as you would receive on a cross-country flight, or a dental x-ray.

I believe nuclear is the future of safe and reliable power.

And I believe we need support from the public to explore things such as interim waste

storage, and reprocessing.

I'm happy to say I love my job, and I'm proud to be with PSEG.

Thank you.

SHC-15-1

-I

MR.

GRENIER:

I'm here, I have a couple of comments.

One is the local Woodstown Borough Councilman, and then another as a resident.

I've been a councilman for a couple of years, and I'd like to say on behalf of the borough, thank PSEG for their leadership in our community, community activities.

Also their stewardship toward the environment, from the estuary enhancement program, and Mr. Fricker spoke a little bit about their lack of greenhouse gases and how environmentally friendly our nuclear facility is.

And also, as Mr.

Hassler spoke of, creation of a good number of well-paying, long-term jobs.

It is not a

project that is just here to build a big road, and then it goes away.

So the jobs are here to stay for long term.

As a resident I would like to say that I've been here for 15 years, as long as I have worked at the island.

And my wife Patty and I are raising three kids in town.

We do seeing eye puppies, we are in scouts, we are in our local church, try to teach our kids how to be active in the community, something that PSEG encourages all of their employees to do through United Way and other programs.

And they give a good amount of money into the county to promote other activities like that.

As I said, I SHC-16-1 J

have been employed with PSEG for 15 years, in chemistry, radiation protection, and now in training.

And I have, first-hand, witnessed what we do at the plant through our

sampling, and our stewardship to the community through our emergency plan activities, and protection of the public.

So I would ask that the NRC consider the plant life extension request, and I strongly encourage that they accept it, move forward with it, and look at the communities that are around here, and the municipalities, and how they all embrace the plant, and the PSEG facility, supportive of it.

I don't know of any municipalities that are against the site.

And I look forward to pursuing, to come to future meetings in the pursuit of the plant life extensions, and also the possibility of a fourth reactor.

Thank you.

SHC-16-1 I

New Jersey Chapter 145 West Hanover Street Trenton, NJ 08618 S I RA

-CýL.u-B October 12. 2009 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Commissioners Jaczko,

Klein and Svinicki, Enclosed is a resolution, passed by the New Jersey Chapter of Sierra, requesting that the Nuclear Regulatory Commission and the New Jersey Department of Environmental Protection require PSE&G to erect cooling towers at the Salem Nuclear Plants as a requirement to renewing the operating licenses. The Executive Board of the New Jersey Chapter is making this request on behalf of over 20,000 members of the New Jersey Chapter.

Thank you for your consideration in this very important matter.

Very truly yours.

Gina Carola f

SHC-17-1

• Chair, West Jersey Group New Jersey. Chapter of Sierra

'0 pfrined ý ocyl pae

SNew Jersey Chapter 145 W. Har~over Seteei CTrrosn NIJ (.N(1 8 JTEL!

(609) 656-7612 FAX: (609) 656-7618

• .wnwze'~.erscy~sierra~ciub.orp Resolution Requesting that;the NJDEP and the NRC Require PSE&Gto Erect Cooling Towers at the Salem Nuclear Plants.

WHEREAS, the Salem nuclear power plants do not have a closedcooling system (cooling towers); and WHEREAS, the plants use over.3 billion gallons ofDelaware Bay water every day for cooling, causing. billions offish and other marine life to be slaughtered every year as they are ground.up in the intake valves; and WHEREAS, the slaughter of the fish severely impacts, the. ecosystem of the Delaware River Estuary by taking billions of smaller bait fish peryear out of the food. chain for larger fish and. birds;:and WHEREAS,.the billions of game and commercial fish.fry that.are ground up and destroyed in the intakevalves severely impacts both the recreational and the commercial fishing industry; and WHEREAS. jobs are dependent on both the recreational and the commercial fishing industry.

NOW THEREFORE, BE IT RESOLVED, that the New Jersey Chapter of the Sierra Club, requests that the New Jersey Department of Environmental Protectiorn and the Nuclear Regulatory Commission require that PSE&GC build a closed cooling system,. such as cooling towers, for.Salem Units. I and 2, which would eliminati 901 to 95:percent ofthe fish slaughier.

BE IT FURTHER RESOLVED, that copies of this resolution be sent to the New Jersey Department of Environmental Protection and the.Nuclear Regulatory Commission.

Dated: September.1.2, 2009 S"IERRA CLUB, NEW JERSEY CHAPTER Kenneth R. Johiinson, Chapter Chair

Charles Eccleston From: Greenhill, John [1]

Sent: Wednesday, November 04, 2009 7:18 PMVl To: Eccleston, Charles

Subject:

Salem and Hope Creek Nuclear Plants 20 year license extensions Importance: High

Dear Mr. Eccleston,

I am unable to attend the hearings on 1115/09 but would like to submit the following questions.

There were incidents on 3/13/1989 and 9/19/1989 at the Salem land 2 Nuclear Plants sites when geomagnetic storms caused damage to the single phase, generator step-up transformers which caused them to be taken out of service.

The damages were due to geomagnetically induced currents caused by the geomagnetic storms.

Questions:

f SHC-18-1 1.

2.

3.

4.

5.

6.

7.

Is there a publically available report that describes these incidents?

What was the magnitude of the currents that caused the damage?

How long did the damaging currents persist?

What was the protective relay system in place at that time such as the IEEE Std C37.91-1985?

Where there any modifications to the transformer protective system put into effect?

How will the step-up transformers at Salem and Hope Creek sites be protected if a super geomagnetic storm (10 times the size of the 1989 storms) occurs during the 20 year extension?

Do the sites have spare step-up transformers?

John V. greenhiff P. Z Department of Energy National Communications System Department of Homeland Security E-mail: iohn.ereenhill(a,.dhs.gov Phone: 703-235-5538

Eccleston, Charles From:

Greenhill, John [John.Greenhill@dhs.gov]

Sent Monday, November 09, 2009 3:46 PM To:

Eccleston, Charles

Subject:

RE: Salem and Hope Creek Nuclear Plants 20 year license extensions

Charles, Many thanks for this information.

An initial cursory look shows a possible problem with this draft EIS when one examines table 5-2 Table 5-2. TMI-1 Internal Events Core Damage Frequency CDF Initiating Event (Per Year)

Contribution to CDF Loss of Offsite Power 7.73 x 106 32.6 Transients 5.80 x 10-6 24.5 Small and Very Small LOCA 4.66 x 10e 19.7 Loss of Nuclear Service River Water 3.67 x 10-15.5 Steam Generator Tube Rupture 9.93 x 10-'

4.2 Internal Floods 4.50 x 10-'

1.9 Large and Medium LOCA 2.05 x 10-7

< 1 ISLOCA 1.80 x 10-1

<1 Total CDF (internal events) 2.37 x 10" 100 The probability of a super solar storm of the 1859 or 1921 size is about 11100 years or 1 %/year. This size storm leads to a continental long term (many months) grid outage because of damage to all the U.S. step-up transformers similar to the damage that occurred at Salem New Jersey in 1989durlng a fairly mild solar storm. With such an outage the emergency generators (that drive the cooling pumps) fuel supply would run out and could not be replaced because the commercial fuel suppliers would be out of fuel as well. Without fuel for the the cooling pumps, the core damage frequency (CDF) appears to be several orders larger that the CDF given in the table 5-2. Perhaps s solar storm initiating event should be included in all the final EIS documents.

yohn Q greenhiiff'P.E Department of Energy National Communications System Department of Homeland Security E-mail: iohn.greenhill~dhs.gov phone:

703-235-5538 From: prvs=557cObb17=Charles.Eccleston@nrc.gov [2] On Behalf Of Eccleston, Charles Sent: Monday, November 09, 2009 3:02 PM To: Greenhill, John

Subject:

RE: Salem and Hope Creek Nuclear Plants 20 year license extensions

John, Here is a recent draft EIS. You will have to open it as a read-only file. Check out Chapter 5.

SHC-18-2

Eccleston, Charles From:

Greenhill, John [John.Greenhill@dhs.gov]

Sent:

Saturday, November 21, 2009 9:24 PM To:

SalemEIfS; HopeCreek@nrc.gov Cc:

Eccleston, Charles; Warren Udy

Subject:

Salem and Hope Creek Nuclear Plants 20 year license extensions Dears Sirs There were incidents on 3/1311989 and 9/19/1989 at the Salem 1.2and Hope Creek nuclear plants sites when geomagnetic storms caused damage to the single phase, generator step-up transformers which caused them to be taken out of service.

The damage was due to geomagnetically induced currents (GIC) caused by the geomagnetic storms.

Questions:

1. Is there a publically available report that describes these incidents?

2. What was the magnitude of the currents that caused the damage?

3. How long did the damaging currents persist?

4. What was the protective relay system in place at that time such as the IEEE Std C37.91-1985?

5.

Where there any modifications to the transformer protective system put into effect?

6.

How will the step-up transformers at Salem and Hope Creek sites be protected if a super geomagnetic storm (10 times the size of the 1989 storms) occurs during the 20 year extension? The next solar maximum is expected 2013-2014.

7. Do the sites have spare step-up transformers?

The TMI Generic Environmental Impact Statement for License (NUREG-1437 Supplement 37) table 5-2 shows the following Table 5-2. TMI-1 Internal Events Core Damage Frequency CDF Initiating Event (Per Year)

Contribution to CDF Loss of Offsite Power 7.73 x 10-'

32.6 Transients 5.80 x 10e 24.5 Small and Very Small LOCA 4.66 x 106 19.7 Loss of Nuclear Service River Water 3.67 x 10-6 15.5 Steam Generator Tube Rupture 9.93 x 10.

4.2 Internal Floods 4.50 x 10-7 1.9 Large and Medium LOCA 2.06 x 10'7

< 1 ISLOCA 1.80 x 10.7

<1 Total CDF (internal events) 2.37 x 10' 100 The probability of a super solar storm of the 1859 or 1921 size is about 1/100 years or 1 %/year. This size storm could lead to a continental wide, long term (many months) outage of the bulk power grid because of damage to all the U.S. step-up transformers. This damaged would be similar to the damage that occurred at Salem New Jersey In 1989 during a fairly mild solar storm. With such an outage, the emergency generators (that drive the cooling pumps) fuel supply could run out and may not be replaced because all the commercial fuel suppliers would be out of fuel as well due to the failure of the electrical pumps. Without fuel for the cooling pumps, the core damage frequency (CDF) appears to be several orders larger that the CDF given in the table 5-2. Perhaps s solar storm initiating event should be included in all the final EIS documents including the Salem and Hope Creek..

SHC-18-3

Johin (D. GreenhiffT.E Department of Energy National Communications System Department of Homeland Security E-mail: iohn.nreenhill(dhs.uov Phone: 703-235-5538 2

Eccleston, Charles From:

Frieda Berryhill [frieda302@comcast.net]

Sent:

Saturday, November 07, 2009 7:25 PM To:

Eccleston, Charles Cc:

Goodman Sid

Subject:

Woodstown N.J.

Dear Mr. Eccleston:

It was truly a pleasure meeting you. The documents you wanted are:

Mr. Goodmans statement to the NRC September 7, 2009 Mr. Goodmans statement to the New Jersey Public Advocate September 23, 09 5 Page letter from the NRC August 24. 2009 Mr. B A Boger fro Eric J. Leeds, Director, Office of Nuclear Reactor Regulation Essentially confirming the soil condition of Artificial Island and the existence of the 70 ft pilings on which the plants are perched. But you can find it in the document room as I did.

Since these are essentially Mr. Goodmans statements I thought it to be more appropriate for him to send them, I have asked Mr. Goodman to do so.

Mr. Sid Goodman Mahwah, N.J. 07430 Tel# 327 5158 Sincerely Frieda Berryhill I

I 158 Grandview Lane Mahwah, NJ 07430 September 7, 2009 Donnie Ashley @ the Nuclear Regulatory Commission

Subject:

Comment on License Renewal for the Salem and Hope Creek Nuclear Power Plants.

To renew the licenses for these nuclear plants represents extreme neglect of the public safety and welfare. It was incredibly poor judgment that these plants were built on "Artificial Island" in the first place. These plants should be shut down, with operation not allowed to continue, much less have their operation greatly extended. Incredibly, PSE&G is considering putting another nuclear plant on this island in this earthquake prone region.

For shame!

None of the nuclear plants are built on solid rock. They are on filled in land. The letter I received from Bruce A. Boger (August 24) confirmed that these plants are not on solid rock.

They rest on compacted engineering fill material or concrete, which have a depth of approximately 70 feet. Concrete pilings are used. The NRC presumes that this will enable them to resist the worst assault that an earthquake can deliver. This is wishful thinking, rather than common sense.

Not only that, but deceitful testimony has been given in support of the environmental impact of the existing nuclear plants. The statement for renewal states that the existing plants had no adverse effects on the Delaware Estuary. In fact, Salem kills 3 billion fish annually.

Environmental expert Robert F. Kennedy Jr. sued the EPA in 1993. He revealed that Salem alone killed more than 3 billion Delaware River fish each year, according to the plant's own consultant. Fish kills are illegal and represent criminal acts.

What can happen from building on unstable land was exemplified in Shanghai, China.

At around 5:30 AM on June 27, 2009 an unoccupied building, still under construction at Lianhuanan Road in the Mining district of Shanghai City toppled.

Just before the toppling, there were reports of cracks on the flood-prevention wall near the buildings and "special geological conditions" in the water bank area.

SHC-19-1 SHC-19-2 f

SHC-19-3

3 In Japan, seven reactors at the Kashiwazi-Kariwa nuclear power plant in Japan were shut down due to an earthquake, fire and nuclear leak. People were killed and injured by the 6.8 magnitude quake, which struck in July, 2007. A new fire at the still shut down plant occurred in March, 2009. 600,000 residents signed a petition opposing restart of the plant.

The arrogance of building nuclear plants in an earthquake prone area is almost unbelievable. Believe it! This arrogance is also invested in other Nuclear Regulatory Commission rules.

The NRC is still satisfied with a mere ten-mile evacuation zone around a nuke when poisons from Three Mile Island were blown hundreds of miles. Poisons from Chernobyl were blown around the world? This satisfaction is idiotic.

The NRC continues support for the Price Anderson Act. This federal law limits liability of a disaster to a microscopic fraction of the potential damage which will be incurred? This Act reduces concerns of operating utilities, a very risky effect. This federal law abolishes the property rights of Americans in order to protect the property rights of nuclear plant owners.

This atrociously unfair law is nothing less than Fascist.

The NRC continues to support the distribution of potassium iodide pills as an assurance that no one will be harmed from a disaster? These pills only protect against radioactive iodine. The pills must be taken immediately and continue to be used for as long as radioactive iodine lingers in the environment. The pills do nothing to protect against all of the other radioactive poisons, which are released. This is no real assurance to anyone who is informed.

The NRC continues to support ridiculously inadequate evacuation plans following a fuming meltdown at a nuke.

The record of the NRC, including other shameful rulings, has earned it the reputation that the initials NRC stand for Nobody Really Cares. The automatic relicensing of old and crumbling nuclear plants by the NRC emphasizes the truth of that reputation.

All of the above represents technological prostitution. At least girls of the night are honest in what they do.

Cut the arrogance? Cut the stupidity! Start protecting Americans. An anything for profits paradigm has brought this great nation to the brink of destruction. The NRC's further actions can allow the final destructive blow. It is unpatriotic.

Very truly yours, Sidney J.Goodman, P.E., M.S.M.E. Professional Engineer NJ License 15326.

Home phone (201) 327-5158 SHC-19-*

SHC-19-4

-I Author of "Asleep at the Geiger Counter" - Blue Dolphin Publishing Inc.

2 Toppled Building lying flat on the ground.

Pilings that were supposed to assure that the building was stable.

Three New Jersey nuclear power plants are built on unstable ground. These are the Salem I, Salem II, and the Hope Creek plants.

They are on Artificial Island in the Delaware River. It was named 'Artificial" because it was man-made with filled in land. There is a swamp on one side of the island with the river on the other side. There is no solid rock underneath. Borings were made up to 100 feet deep.

No rock was found. The reactors are built on pilings similar to the pilings shown in the collapsed Shanghai City building.

See the concrete pilings of the building that collapsed.

Like so many nuclear facilities, these three nukes are close to an earthquake fault. This fault rumbled on February 3, 2009. The noise of geological shocks in February, terrified people in Morris County who thought the shocks were explosions as reported by The Star

Ledger, The Morris County (NJ) quake had an intensity of 3.0. That was a small event according to the US Geological Survey. But much more intense earthquakes are due. Earthquakes may occur a few times a year in New Jersey. Some are so small that they are hardly noticed. A biggie can happen in a hundred years or tomorrow.

From:

wdunn302@comcast.net Sent:

Thursday, September 03, 2009 11:55 AM To:

Ashley, Donnie Cc:

Bill Dunn

Subject:

Comments On Salem and Hope Creek License Application William R Dunn Elsmere, Delaware September 3, 2009 Donnie Ashley, Project Manager Division of License Renewal Office o Nuclear Reactor Regulation U.S. Nuclear regulatory Commission, Mail Stop 01 1-F1 Washington, DC 20555 301-415-3191

Reference:

LICENSE RENEWAL APPLICATION Hope Creek Generating Station Facility Operating License No. NPF-57 LICENSE RENEWAL APPLICATION Salem Nuclear Generating Station Unit 1 Facility Operating License No. DPR-70 Unit 2 Facility Operating License No. DPR-75

Dear Mr. Ashely,

As a former management consultant for a number of EPA 208 Water Quality Area-Wide pollution control programs, I am very much interested in reviewing projects that may have a significant impact on the environment as well as the need to sustain a reliable physical infrastructure that supports our economy and standard of living. Having also worked in Haiti as a consultant, I experienced first hand routine electrical blackouts, an unreliable turn-of-the-

.ninetieth century telephone system, and other infrastructure shortcomings for drinking water and transportation. We take the safety and reliable delivery of these type services for granted in the United States. Electrical generation is the critical infrastructure component that the rest of the economy depends.

I have reviewed the applications for both the Hope Creek and Salem nuclear facilities and would make the following comments:

Hope Creek and Salem Applications

The environmental impact appears to be minimal for granting an extension of the facilities license and there is certainly a justified need to upgrade portions of nuclear power generatingy SHC-20-1 operations to replace aging equipment that will improve the power generating capabilities and mitigate safety issues of an aging plant.

Secondly, nuclear power does not produce greenhouse gas (C02) and consequently would be a SHC-20-2 more attractive alternative to burning coal or natural gas.

J Third, based on my research on the emerging nuclear fusion technology, the disposal of nuclear waste will be one day be safely transmuted to useful isotopes. Nuclear fusion and fission will be paired to provide almost unlimited power without the issue of residual radioactivity.

SHC-20-3 Fourth, the option of purchasing more electricity by de-commissioning these facilities will likely require modifying and building additional transmission lines to support this option. This will have a far more deleterious affect on the environment and communities where these lines will be SHC-20-4 constructed that continuing to operating these nuclear facilities. Furthermore, importing electricity will likely originate from either coal or gas fired units that produced the greenhouse gases C02 (and other pollutants) as compared to nuclear power that generates zero greenhouse gas.

Recommendation I endorse the granting of these facilities a license extension for the aforementioned reasons and would further recommend that these sites be replaced with new state of the art nuclear power plants that would have additional electrical generating capacity. Nuclear power has proven to be SHC-20-5 a reliable and cost-effective source of electricity and would provide the basis for pairing with nuclear fusion technology in approximately 20 years that would meet our countries energy needs as well as safeguard our environment.

Please feel free to contact me if you require additional infornmation or comment.

Very truly yours, William R Dunn

Hearing Docket From:

Sent:

To:

Cc:

Subject:

dorickards@aol.com Saturday, October 24, 2009 2:26 PM Docket, Hearing OGCMailCenter Resource hearing on Salem/Hope Creek nuclear plant DOCKETED USNRC October 24, 2010 (2:26 p.m.)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Rulemaking and Adjudications Staff:

Every Power Plant currently using intakes either for once through operations or to replenish water lost from evaporation should be required to partner with the most local municipality and pipe their treated wastewater to the power plant to eliminate intakes.

Intakes kill millions of fish annually and once through operations adversely modifies the environment surrounding the outflow area. Municipalities need to dispose of their treated wastewater and to pipe this affluent to a facility that can use it is a least expensive and obviously the most environmentally friendly method.

All power plants should upgrade to a cooling tower technology. If too much heat in generated to recycle the water, cooling units can be added to the outflow troughs to reduce the temperature of the water prior to reuse.

The kinetic energy available in cooling tower outflows can be tapped with UEK turbine technology to generate enough electricity to run cooling coil units. ENERGY RECOVERED = GOOD MANAGEMENT.

David 0. Rickards Instream Energy LLC 34612 Rickards Road Frankford, DE 19945-3544 (302)539-9034 Ph (302)537-2372 Fax SHC-21-3

LOWER ALLOWA YS CREEK TOWNSHIP PO BOX 157 501 LOCUST ISLAND ROAD HANCOCK'S BRIDGE, NEW JERSEY 08038 (856) 935-1549 ext #623 (856) 935-7666 Fax lactwpclerk@ya hoo.com November 3, 2009 US Nuclear Regulatory Commission Washington, DC Re: PSEG Nuclear's License Renewal for Salem and Hope Creek Generating Stations My name is Ellen B. Pompper, and I am the current Mayor of Lower Alloways Creek Township. We are the host municipality for PSEG Nuclear's Salem & Hope Creek stations.

I have lived in Lower Alloways Creek Township for over 30 years and served on local government for 12 years, 5 of those years as Mayor.

While some may not want a nuclear plant in their backyard, we welcome PSEG Nuclear, who we consider a good friend and neighbor. PSEG is transparent and open with us. They are quick to call me and let me know of plant issues and news worthy items that affect us. Each Month, I and other Township Officials meet with PSEG Nuclear. We discuss plant operations and other points of interest that impact not only Salem and Hope Creek, but also our community.

As you know, nuclear is a clean source of energy. The plants produce a significant amount of electricity without emitting carbon dioxide and other greenhouse gases.

Our community is dotted with farms that also have seen no environmental impact. PSEG has an extensive monitoring program that ensures the health and safety of the public especially those in Lower Alloways Creek.

I support the license renewal for Salem and Hope Creek another 20 years and ask that the NRC approve this life extension for these stations.

Thank You Ellen B. Pornppcr, Mayor Lower Alloways Creek Township Ebp/rlc*_.

SHC-22-1

The UNPLUG SALEM Campaign 321 Barr Ave., Linwood NJ 08221 ncohen 12@comcast.net www.unplugsalem.org 609-335-8176 11/30/2009 To: Nuclear Regulatory Commission:

Comments for the environmental review of the relicensing of Hope Creek Docket No.

50-354 License No. NPF-57 PSEG Nuclear, LLC The UNPLUG Salem Campaign is a network of organizations and individuals that act as a public health and nuclear safety watchdog for PSEG's three nuclear power plants.

This letter concerns the proposed relicensing of Hope Creek. We oppose extending the license of this nuclear plant. We also oppose the process by which decisions on relicensing are made. This process makes it virtually impossible for most individuals and many organizations to participate. In addition, because only certain issues are deemed acceptable by the NRC for submission as contentions, many issues of safety and health are not even looked at by NRC in making their decision.

We also oppose relicensing a nuclear plant twenty years before its license is up for renewal.

If the NRC can give Oyster Creek a 20 year extension, even though that nuclear plant could not be built under today's standards, and is a meltdown waiting to happen, it is clear that the relicensing process for Hope Creek will be nothing more than paperwork and rubber stamping.

However, it is important to put our concerns on the record, even though we do not expect NRC to act on any of them.

Here are areas that NRC should look at and then deny Hope Creek a 20 year extension:

(1) Hope Creek has leaked hydrazine into the Delaware Bay.

(2) The electrical system that connects Hope Creek to the grid is old and has had a SHC-23-1

} SHC-23-2 SHC-23-3 SHC-23-4

} SHC-23-5

number of failures, including transformer failures.

(3) PSEG has a spotty record when it comes to keeping diesel generators working. This is a concern because all three nuclear plants rely on diesel generators if offsite power is interrupted.

(4) PSEG has a serious Safety Conscious Work Environment (SCWE) and Safety Culture problem. This has been a chronic problem at all 3 of PSEG's plants, and continues to show up in NRC inspections under "cross-cutting issues of human performance". One key example at Hope Creek was the loss of 5000 gallons of cooling water, due to human error. This event could have escalated into a TMI-type of situation.

(5) Hope Creek is vulnerable to a severe earthquake because Artificial Island is built on compacted mud, and its pilings do not reach bedrock.

(6) Because Yucca Mountain, the national depository for spent nuclear fuel, will not be operative, Lower Alloways Creek will become, and actually is now, a long term nuclear waste dump, which violates the zoning board agreement between PSEG and Lower Alloways.

(7) Hope Creek has buried pipes and electrical conduits that have not been inspected and, based on other nuclear plants, may be leaking tritium or in danger of electrical shorts happening.

(8) The Evacuation Plan for Salem/Hope Creek is based on faulty assumptions and would not work under many scenarios, including a fast acting radiation release and

,multiple releases. Under worst case scenarios, thousands of people within the 10 and 50 mile zones would die from radiation exposure.

(9) Hope Creek emits continual amounts of low level radiation and radionuclides, which contribute to the cancer cases and immune system disorders in the 50 mile zone around Artificial Island.

(10) Hope Creek remains a prime terrorist target, and there are many ways terrorists could prevail, only one of which will I list here.

SHC-23-5

}

SHC-23-6 t

SHC-23-7

}

SHC-23-8 J

SHC-23-9 SHC-23-19

}

SHC-23-11

(11) Hope Creek's Spent Fuel Pool is above ground and not protected by containment.

It is a prime terrorists target. If the water in the Pool drains out, there would be massive radiation releases.

(12) If NRC approves the relicensing of Hope Creek, the people of South Jersey and Delaware will become unwitting guinea pigs in NRC's grand experiment to find out if aging nuclear plants actually can last another 20 years or not.

What should be done:

Hope Creek should be decommissioned at the end of its 40 year license. Affected employees should be relocated and retrained by PSEG. Artificial Island should be turned into a wind power and solar power "park" to produce some of the electrical energy formerly produced by the nuclear plants.

]~SHC-23-11

} SHC-23-12 Sincerely, Norm Cohen Coordinator, The UNPLUG Salem Campaign emailed to NRC 11/29/09