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f JERSEY CENTRAL POWER,& LIGHT COMPANY-RESPONSE TO 5
FEDERAL AND STATE COMMENTS ~
ON AECDRAFT.ENVIRONMENTALIMPACTSTATENENT FOR
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OYSTER CREEK NUCLEAR GENERATING STATION DOCKE1 NUMBER 50-219 JANUARY 1974 i
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Agency
Reference:
Letter dated January 23, 1973 from Secretary of the Interior to Mr. Huller, U. S. AEC.
f (1) Response to Commer.t Letter The Applicant concurs in the concern for the canal banks insta-bility which contribute to the sediment problems and which also result in a rather unsightly condition. The canal stabilization program has been given top priority, along with other major areas of concern.
During the summer of 1973, an engineering study was conducted to deter-mine the technical problems and costs involved in preparing such a program in order to def.ne a specific approach to stabilize the canal banks.
Sper..tfications have been prepared for such a program. Work on canal stabilization will be initiated in 1974.
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Agency
Reference:
Lecter dated July 29, 1973 from Mr. Fred H. Tschirley, D,epartment of Agriculture to Mr. Daniel R. Muller, U. S. AEC.
(1) Response to Comment Letter The removal of 352 acres of wildlife habitat during construction was not significant because similar mobile organisms' habitat was avail-able nearby. A description of land use patterns within the plant site may be helpful.
Land use patterns within the plant site fall into either.of two broad classifications:
some land has been altered or developed by man for his use, and the remainder of the site has been left in its natural state.
Figure 2.2-11 reproduced from the Oyster Creek Nuclear Gener -
ating Station Environmental Report depicts the location of the land devoted to each of these uses. Land developed by man includes that occupied by the generating station and grounds, the switch yard, trans-mission right-of-way, several spoil areas, cleared land, transportation right-of-way, and areas designated for industrial or recreational land use, residences, and farm structures. Natural areas are identified as forested or wooded land, salt water marsh, white cedar swamps, and
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1and previously used for pasture and cultivation.
l There were 352 acres of land within the plant site utilized during construction of the plant and transmission right-of-way:
288 acres of spoil and cleared area; 33.5 acres of right-of-way for railroads and transmission lines; 22 acres occupied by the. generating plant and switch yard; and 8.5 acres set aside for an emergency fire pond on Oyster Creek. The spoil within the plant site was deposited during dredging the South Branch of Forked River and,0yster Creek. The cleared areas include the transmission right-of-way, areas adjacent to U. S. Highway 9, and the Garden State Parkway. Approximately a 33 acre area near the Garden State Parkway was cleared of vegetation by the former owner before the Applicant acquired the land. Vegetation is slowly being reestablished in all of these areas. Regrowth ranges f rom very sparse areas to areas with thick ground cover and some trees, such as white cedar.
Soil in these areas is sandy and relatively infertile, there-fore, regrowth of vegetation has been slow.
Surface routes in the vicinity of the plant includes a railroad, two highways, service roads, and f arm access roads. One road goes to the emergency fire system pond on Oyster Creek and another service road serves the transmission line corridor. Also, several dirt and paved roads within the site serve as access roads to the pasture, cultivated land, and forested areas. About 9 acres of land are devoted to roads within the site.
No industries or recreational facilities were dis-placed by the plant.
In 1964 the Lacey Township governing body zoned the land industrial that is bounded on the north by the Middle Branch of Forked River, on the east by U. S. Highway 9, on the south by Oyster Creek, and on the west by the Carden State Parkway. The Dyster Creek Nuclear Generating Station is the only industry that has been con-structed in this industrially zoned area. One family resides on the Applicant's land between the Bay and Highway 9.
This family lives in a well landscaped farm which includes a house and several adjoining farm buildings.
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Wooded and forested areas consist of pitch pine and some mixed hardwoods. The largest of these areas within the site is located wast e
of the' plant, but there are also smaller scattered stands to the east.
The forests provide wildlife habitat, control erosion, and partially screen the plant and transmission lines from the Garden State Parkway and U. S. Highway 9.
There are 218 acres of marshlands on the site which are habitats for terrestrial and aquatic life. In addition to the marshlands, 358 acres of white cedar swamp adjoin the streams.
The land had originally consisted of pine vegetation and fresh and salt water marshes. The pine and mixed hardwood were cleared east of U. S. Highway 9 and the marsh was drained and plowed for crops and pasture by the former owner. Since the Applicant purchased the land, the cleared cropland and pasture has reverted to a savannah (grass-land with scattered trees). The cultivated land has now reverted to the original marsh habitat for wildlife.
l Disturbances to the land dur'ing construction of plant facilitics' included the removal of some pine and hardwood forest, the dredging of a canal, and the replacement of some white cedar swamp and salt water marsh with spoil from dredging and site excavation. The effect i
of these activities resulted in the elimination of some small non-mobile mammals (i.e., moles), reptiles, and amphibians that lived on the disturbed area surrounding the plant. The short-term effect of the removal of 352 acres of wildlife habitat during construction did not significantly aff ect mobile organism movements, because similar habitat was available nearby.
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[3, Aaency Reference Letter' dated-August 22, 1973.from Mr.1 Paul Cromwell, Department of Health, Education and Welfare to Mr. Danici R. Muller,-
~U. S. AEC.
a (1)1 Respons'e to Comment 1
. A thorough analysis of the effects of the " proposed" action on the local-community, addressing such areas as the effect of 100* plant employees and their families on education, transportation, housing, health-f acilities,. etc., lin the local area,. is nct considered approp-riste-at this time since the plant was under construction in 1964 and in operation in 1969. Those effecte have since been assimilated. How-
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ever, the material presented in the Draf t EIS does provide an adequate information base'from which'certain conclusions can be drawn to' form a simple analysis regarding those' effects.
The effects of~100 plant employees and their families on trans-portation in the local area are considered to be minor in view of the following:
(a) The local area is traversed by major state and federal highways, i.e., the Garden State Parkway and U. S. Highway 9 (Draf t EIS page 2-1).
(b) The resident population within a local area of.10 miles of the
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site in 1970 was estimated to be 45,000 (Draft EIS page 2-1).
The average f amily size in the State of New Jersey is 3.17 people (Draf t - EIS page 8-12). The additional effect, therefore, of adding 317 people to that resident population amounts to approx-imately a 0.7% increase in the local area. The Applicant considers.
this increase to be insignificant. Assuming all other variables constant, if the resident population experiences a slight 0.7%
increase, one would expect a proportional or slight increase in the local area traffic flow.
(c) The resident and seasonal population within a local area of 10 miles of the site in' 1970 was estimated to be 97,315 (Draf t EIS page 2-6).
The additional effect, therefore, of adding 317 people to the resident and seasonal population amounts to approximately a 0.3% increase in the local area. The App 1dcant considers this increase to be virtually undetectable'. Assuming all other variables constant, 'if the resident and seasonal population experiences a virtually undetectable increase of 0.3%, one would expect a pro-t portional or virtually undetectable increase in the local area traffic flow. This is especially true with the large numbers of additional casual one-day or weekend visitors during the summer months.
- 'A plant' census in December, 1973 determined that there were about 118 employees
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working at different' times'during any 24-hour period, which therefore closely
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substantiates the average plant staff number of 100 (Draf t EIS page 8-12).
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.(d) The plant was designed to meet electrichl base loads occurring within the Applicant's service area and accordingly, is a source of supply of continuous power (Draf t EIS page 8-3), and accord-ingly the plant is operated on a continuous basis which. requires that the plant staff work three shif ts over a 24-hour period.
98 personnel staff the day shif t from 7:30 A.M. to 4:00 P.M.,10 personnel staff the af ternoon shif t f r'om 3:30 P.M. to 12:00 P.M.,
and 10 personnel staff the night shif t from 11:30 P.M. to 8:00 A.M.
The maximum vehicular rate resulting from the day shif t change to the afternoon shift is 108 vehicles over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> duration. The maximum vehicular rate resulting from the af ternoon shif t change to the night shift is 20 vehicles over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> duration. The maximum vehicular rate resulting from the night shift change to the day shif t is 108 vehicles over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> duration. The net results are average increases in vehicular traffic flow of about i vehicle every 33 seconds from 7:15 A.M. to 8:15 A.M.,1 vehicle every 33 seconds from 3:15 P..M.
to 4:15 P.M., and 1 vehicle every 180 seconds from 11:15 P.M. to 12:15 P.M.
The Applicant considers, therefore, that the net results of average increases in vehicular traffic flow directly at the plant site are small and simply are not excessive or burdensome on the available local transportation roads and highways.
The effects of 100 plant employees and their families on education, health facilitics, etc., in the local area are considered to be minor in view of the following:
(a) Facilities such as schools, etc., are generally financed, con.
structed and operated by local agencies. The major source of revenue for schools is local real estate taxes on-land and build-ings. The plant brought to Lacey Township substantial revenues through the gross receipts and franchise taxes paid by the Applicant as well as through real estate taxes on the land and buildings.
In addition, its 100 employees caused the creation of additional rateables in the form of housing and tne plant supplied nearly.all of the municipal revenues.
(b)
Increases of 0.7% and 0.3% in the respective resident and combined resident-seasonal population levels of 1970 are considered by the Applicant to be relatively small and 1.nsignificant increases on the local educational and health facilities.,
The eff ects of 100 plant employees and. their f amilies on housing in the local area are considered to be minor in view of the following:
(a) The construction of the plant induced the construction of approx-imately 85* new residences in surrounding communities (Draf t EIS page 10-1).
This provided both a major source of homesites for the new employ'ees and employment for the local building industry.
(b) The addition of t.he newly constructed residences caused a net increase in available real estate which is assessable on a locci Icvel for tax revenue.
It was estimated that this increase had an assessable worth of about $2.5 million (Draf t EIS page 10-1).
- 85=66.6% of 130.
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O (2) ' Response to Comment 2 The environmental effects on the estuarine functions of Oyster Creek and the South Branch of Forked River due to the operation of the plant are important areas of concern to the Applicant. This is
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evident by noting that extensive investigations of the aquatic biota-benthic flora and fauna and plankton'have been conducted from 1965 to i.
the present.
Further, the Applicant agrees with the AEC in its con-j clusion (Draf t EIS page 10-11) tF ttems of slight to moderate environ-i mental impact are associated wit'.
- c. ration of.the plant. Additionally, the Applicant is concerned about ;ie stability of the canal banks,~as well as its aesthetics, and therefore intends to implement the most
_ ractical means of stabilizing the banks and improving their aesthetic p
appeal.
The Applicant considers'it appropriate to note that safeguards will be provided whose purpose is.to result in an acceptable environ-mental impact due to plant operation. Pursuant to Section 50.50 of
-10 CFR 50, each operating license issued by the AEC. for a nuclear power plant will specify certain conditions and limitations on the operation of the plant which will result in an acceptable environmental impact.
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4, Agency
Reference:
. Letter dated August-9, 1973 from E. C. Anderson, Department.
j of Health, Education and Welfare to Mr. Paul Cromwell, DHEW.
~(1) Response to General Comment 1 Complete data has been recorded during plant operation since 1969, i.e., tritium releases as well as other radionuclides.
Such data has been continuously recorded and made public in Semi-Annual Reports to the Atomic Energy Commission.
These reports are submitted to the AEC and other agencies requesting copies within sixty days after the end of the six month reporting period.
The reports are available for public_ viewing i
in'the public document room in Washington, D. C.
Additionally, records have been made, submitted and distributed in the semi-annual reports regarding radioactivity data for fluid nuclide releases.
It should be noted that the Applicant is not se~ eking a proposed power increase but rather requesting a license for the life of the plant at the presently approved and licensed power level.
(2) Response to General Comment 2
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1 The Applicant currently has underway a design and engineering effort aimed at making improvements at the Oyster Creek Station to reduce both gaseous and liquid radioactive releases.
These modifications for which AEC approval is currently being sought are aimed at conformance with the "as low as practicable" guidelines.
It should be noted again that the Applicant is not seeking an increase in power'icvel.
In a letter to the AEC dated June 1, 1973, Jersey Central indicated that it has completed its evaluation of the radioactive waste systems currently installed at,the Oyster Creek Station to determine the confor-mance with the proposed Appendix I to 10 CFR 50 - Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low as Practicable" for Radioactive Material in Light Water Cooled Nulcear Power Reactor Effluents. Jersey Central further indicated that the existing radioactive gascous waste system required augmentation to insure conformance with the guidelines of proposed j
Appendix I and submitted a report entitled " Proposed Modification to the Gaseous Radioactive Waste System for Oyster Creek Nuclear Generating Station".
That report discussed the analytical models, data, assumptions and calculations which were used with respect to four possible alternative systems to demonstrate conformance to the proposed Appendix I to 10 CFR.50.
1 In addition, regarding the liquid and solid radioactive waste systems, the Applicant indicated that studies were also in progress to select appropriate modifications to those systems such that they would no longer l
experience difficulty in meeting proposed Appendix I limitations.
By letter dated September 20, 1973, the Applicant further informed the AEC that it had completed its evaluations and had selected suitable modifications to the solid, liquid and gaseous radioactive waste systems for the station, which the Applicant has determined will provide confor-
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mance to the effluent guidelines of the proposed Appendix I to 10 CFR 50.
1 These modifications were described in a report entitled " Preliminary
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'n Description and Analyses'of Proposed Modifications to the Gaseous, Liquid
~ and Solid Radioactive Waste Treatment Systems for the Oyster Creek Nuclear Generating Station".
It is anticipated that the system descriptions in
.that' report will allow the AEC to give its concurrence'that the design and construction of the systems as described will res21t in effluent
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releases well within the limitations of proposed Appent'ix I to 10' CFR 50 and meet with AEC approval.
Amendments to the Final Safety Analysis Report (FSAR) regarding the
' modifications to the gaseous, liquid and solid radwaste system of the Oyster. Creek Nuclear Generating Station are also being prepared and will be submitted to the AEC upon completion.
(3)' Response to Specific Comment 1 Actual release values for tritium are given in the Radwaste Summary Section of each Semi-Annual Report issued by the Applicant.
(4) Response to Specific Eomment 2 See Response to General Comment 2, above.
1 (5) Response to Specific Comment 5 Fuel assemblies are being supplied by Exxon Nucicar Company.
To date, there have not been any shipments of spent fuel to any reprocessing plant.
Shipments to the GE fuel reprocessing plant in Illinois are expected.to be during 1974.
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Atency
Reference:
-Letter dated August 22, 1973 from John J.-Russo, State i
- of New Jersey Department of _ Environmental Protection to Director of i
< n Reiguistion, U.
S.- AEC.
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. (1);' Response'to overall Comments, Section-6.2-i
'Since the startup. of the Oyster Creek environmental monitoring program.. substantial changes have occurred in both the objectives and -
the techniques of radiological environmental monitoring. The Applicant f
is in the process of upgrading the program to conf arm with recommend-l ations of the EPA (ORP/SID 72-2) and the AEC (Regulatory Guide 4.1 and 1.42). The upgrading will involve more sophisticated sampling and 3
l analyses. The design of the upgraded program ir, essentially; complete j
and~a proposed technical specification change will'be submitted to the AEC shortly. Sampling and analysis procedures are already being tested-to assure that the upgraded program will be functioning smoothly at
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the earliest possible date.
(2) Response to Comment 1, Section 6.2 l'
The upgraded program will use thermoluminescent dosimeters (TLD)
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to measure gamma radiation. Although high pressure ion chambers with l
tape recorders could be used to measure plant-related doses as low as i
one or two ar/ year, for economic reasons, thermoluminescent dosimetry j_
using carefully. selected ~ sampling locations, rigid control procedures, and proper data evaluation should enable detection of plant-related 4
j doses as. low as 10 mr/ year with reasonable certainty.
(3) Response to Comment 2, Section 6.2 l-The TLD sampling locations were selected on the basis.of maximum j.
expected off-site doses to the public. Dosimeters will be located at i
eight locations near the site boundary, five locations two to three miles from the plant, and three locations = about 25 miles from the plant to provide background data.
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(4) Response to Comment 3, Section 6 2 Although the upgraded program will use high volume samplers as suppismental monitoring (not as part of the formal program) at two locations, low flow rate pumps will be used'for the formal program.
Commercially available high volume pumps, designed for intermittent use, require frequent repair and replacement when used for continuous sampling.
Frequent breakdowns would mean loss of data.
Low flow rate i
pumps (approximately 1 cfm) are sufficient to meet program sensitivity requirements for the inhalation pathway and are considered adequate 4
by the EPA (ORP/SID 72-2). The feasibility of high volume sampling.
is being investigated because there is hope that a great increase in sensitivity can be.obtained if reliability problems can be solved.
(5) Response to Comment 4. Section 6.2 In the upgraded program, five air samplers will be distributed around the plant at a distance of about two to three miles. Three of w
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these stations will be located near areas of anximum cxpected grpund-level concentration. The other two stations will be located in popu-lated areas.
Additional samplers will be located about 25 miles from the plant to provide background data.
(6) Response to Comment 5, Section 6.2 Charcoal cartridges are being used in air sampling systems to measure airborne radioiodine.
(7) Response to Comment 6, Section 6.2 In the upgraded program, vegetation and soil samples and composite air samples will te analyzed by high-resolution gamma spectrometry.
Precipitation will be analyzed by high-resolution gamma spectrometry if the gross beta concentrati' n. exceeds a predetermined limit.
o (8) Response to Comment 7. Section 6.2 Surface water from Barnegat Bay and Oyster Creek has been analyzed for tritium, strontium-90, and gamma emitters for at least a year. The upgraded program will continue these analyses in addition to the anal-ysis of strontium-89.
(9) Response to Comment 8, Section 6.2 The upgraded program will discontinue special analyses for isotopes not present in plant effluents. No sampling or analyses will be dis-continued, however, until AEC approval of the proposed technical speci-fication change is obtained.
(10) Response to Comment 9, Section 6.2 The use of a continuous or proportional sampler to collect water samples from Oyster Creek is being considered.
(11) Response to Comment 10, Section 6.2 In the upgraded program, bottom sediment samples will be analyzed by high-resolution gamma spectrometry.
(12) Response to Comment 11, Section 6.2 In the upgraded program, gross alpha and beta analysis of clam meat will be replaced by gamma spectometry and radiochemical analysis for strontium-89 and strontium-90.
(13) Response to Comment 12, Section 6.2 l
See Response to Comment 11, Section 6.2, above.
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(14) Response to Comment 13, Section' 6.2 The upgraded program will include sampling and analysis of fish and crabs, as well'as clams.
It is expected that these results and j
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results of. sediment analysis can be used to establish trends of con-centrations in algae and other vegetation.
Studida performed by the State of New Jersey and by the EPA indicate that the same plant effluent isotopes which appear in algae and other aquatic vegetation also appear in sediment, fish, clams and crabs. Measurements of radioactivity in clam and sediment in the past have shown very little contamination from plant ef fluent.
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Agency
Reference:
. Letter dated September 4,'1973 from Mr. Sidney R. Galler.
Of,fice of the Assistant Secretary'of Commerce to Mr. Daniel R.-Muller, U. S. AEC.
a (1) Recponse to Comment on Section 2.7.2, Page 2-30 The natural depth of the bay and the ' induced intake-discharge j.
curr3nt patterns do not indicate that demersal eggs of fish could be swept from the bay bottom and entrained in the cooling water.. The 4
only demersal eggs ever found at the plant was a clutch of about five j
eggs of an unidentified species that were adhering to a piece of sea lettuce (Ulva) taken from the screens at the time of the 1971 screen census. Ulva, as well as other macroalgae, characteristically drifts as part of its natural life hist.ory. There is no reason to believe that bottom currents of the' bay between the maths of Oyster Creek and Forked River ever attain scouring velocities due to the recirculation pattern.
Bottom growths in this area clearly indicate that bottom' j
currents are within the range of natural velocities to which bottom forms are adapted. This would include demersal fish eggs if they are deposited in this stretch of bay bottom.
(2) Response to Comment on Section 4.3.2, Page 4-4, Paragraph 4 4
e Those fish species that have migratory behavior as anadromous, 1
'I catadromous, or lesser migratory patterns in tihe bay include striped bass, white perch, winter flounder, menhaden, the American eel and the blue crab.
(These would be the species of greatest importance to the public interest - other species show minor movements associated with feeding, spawning and seasonal changes.) These species are presently found in both the intake and discharge canals of the Oyster Creek Plant.
In point of fact, the' discharge canal, formerly little o
fished, has develop td into a popular recreational fishery asset.
l (3) Response to Comment on Section 5.2.1, Page 5-2 The Applicant has already addressed the subject of thermal plume dispersion in a letter to the AEC dated November 8,1973 which for-war &d the proposed Oyster Creek Nuclear Generation Station Environ-mental Technical Specifications (ETS).
Section 6 of those ETS describes special surveillance, research or study activities which the Applicant has proposed to undertake. The objective of the Applicant's thermal plume mapping activity is to describe the horizontal and vertical extent of the plume under various conditions of tides, time of day and winds.
In order to understand the general three-dimensional heat distribution as it is aff ected by various environmental conditions, the plume will be mapped using an airborne infrared sensor and simul-taneous temperature-depth profiles from a surface vessel. This will be supplemented by current measurements. These mapping surveys will be of several days duration. During each survey period-the plume size and shape will be measured during three portions of the tide stage.
Current drogue surveys conducted prior to the first temperature survey and periodically throughout the program will be utilized to assess current characteristics. Temperature-depth measurements made during the serial surveys at several-points on approximately five transects
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oriented normal.to the Bay channel will be used to construct cross-
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section profiles along these portions of the plume. - The results of.
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this program, as well as all of,the other environmental surveillance
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programs, will be submitted to the AEC.
.(4) Response to Comment on Section 5.2.1, Page 5-3
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See Response to Comment on Section 5.2.'1, Page 5-2 above.
i i-(5) Response to Comment on Section 5.2.2.4, Page'5-5 The Applicant has already. addressed the concern of canal, erosion and silting.- See Response to Comment Letter to a letter dated 1
January'23, 1973 from the Department of the Interior herein. Also j
see Response to ' Comment 2 to a letter dated August 22, 1973 from the Department of Health, Education and Welfare herein.. The purpose of i
Environmental Technical Specifications (ETS) is to establish certain conditions and limitations on the operation of.the plant which, if not
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exceeded, should result'in an acceptable environmental impact. The j
Applicant-has submitted proposed ETS to the AEC which specifically address the Staff's conclusions (Draft EIS page 5-5) regarding thermal t
discharge and which also address the State of New Jersey recommendations (see Letter dated September 12, 1973 from the State of New Jersey
[
Department of Environmental Protection and response thereto).
'(6) Response to Comment on Section 5.5.2.2, Page 5-18 1
The assumption that the loss of 32,000 crabs per year and 24,000 j
winter' flounder per year "is significant" has no foundation.
In the j
opinion of Dr. C. Wurtz, significant losses imply a loss rate that is of such an order. of magnitude that losses in successive years would be
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cumulative. This' would lead to lowered populations with each succeeding y
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year. The reports of the work done by the Rutger's study group do not l
demonstrate any significant population variation attributable to Oyster Creek Station operation. Therefore, this effect is not considered j'
significant.
l (7) Response to Comment on Section 5.5.2.3, Page 5-20 L
In the Rutgers Progress Report Number 8 the statement of import l
appears on the first page of the Introduction as:,"Although these conclusions are based on an extremely complex situation and do not appear to be statistically significant (emphasis added), we should be aware of the general trend which is taking place." The general trend referred to is a lowering in the number of benthic organisms in and around Oyster Creek and lower primary productivity in the same area.
The latter circumstance dates from the pre-operational period. The eighth Rutgers' report does not include any discussion of fish eggs and larvae passing through condenser tubes and cannot, therefore, con-tribute anything to a discussion of that subject.
It should be noted that the Appia at hr s proposed to undertake
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a special surveillance activity as descritc. in Section 6 of the proposed Oyster Creek Nuclear Generating Station Environmental Technical i
Specifications'. The' principal objective of that activity is to estimate g
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J standing crops of zooplankton in Barnegat Bay and the intake canal.
Zooplankton will be sampled monthly for up to three years with plankton nets and/or pumps. Sampling will be conducted at least monthly for the first year; the frequency may be altered during the last two years on the basis of the first year's results. Specimens will be identified to the lowest taxon possible.
Special emphasis will be placed on determining the species of copepods, bivalve larvae, fish eggs, and fish larvae.
Relative abundance and species diversity will be calcu-lated. The mean biomass of zooplankton per cubic meter will be deter-mined.
Egg ratios will be used as a measure of biological activity in populations of dominant species. Temperature and salinity measure-ments will be taken at the time of each sample. To assess the effects of entrainment or of the thermal plume on zooplankton, mortality from these sources must be compared with the standing -crop in Barnegat Bay.
(8) Response to Comment on Section 5.5.2.4, Page 5-23 The Applicant has taken the necessary action to align itself with the Staffs' opinion regarding the control of the outfall temperature in Oyster Creek (see Response to Comment Letter to a letter dated September 12, 1973 from the State of New Jersey Department of Environ-mental Protection herein).
It is noted that the State of New Jersey has concurred in the Staff's recommendation in the control of temper-ature in Oyster Creek. Additionally, it is further noted that the statement regarding the limitation of outfall temperature to less than 87 F was qualified in the Draf t EIS on the basis of (a) the winter flounder avoidance breakdown temperature of 87 F, (b) the hatchability of copepod eggs show no decrease in viability until temperatures exceed 86 F. (c) the larvae of oysterc experience a 50% mortality when exposed for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 95 F6 (d) the mortalities of Mulinia larvae increase sharply between 93 F and 98 F, (c) estuarine waters with temperatures above 87 F will be an unacceptable environment for the majority of important yc.ing-of-the-year or small fish species and (f) large indi-viduals of the examined fish species may actively avoid temperatures lower than those avoidance temperatures which produce a mean avoidance temperature of 87 F.
(9) Response to Comment on Section 5.5.2.4, Page 5-28 The Applicant has no information or indication of finfish (or shellfish) starvation in the discharge waters fron} the Oyster Creek Nuclear Generating Station either in the canal proper or in the plume area beyond the mouth of the canal.
It is noted, however, that the Applicant has taken action to implement controls and operating pro-cedures to minimize problems caused by attracting fish to the warm discharge. area during the cold months. On November 8, 1973, the proposed Oyster Creek Nuclear Generating Station Environmental Technical Speci-fications were filed with the AEC for the Commissions' review and approval.
Special operating procedures were proposed to minimize the temperature of the discharge water so as to reduce adverse thermal effects on some aquatic organisms. A special surveillance activity was proposed te evaluate the effectiveness of techniques to be implemented for the re-duction of winter fish kills.
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. (10 Response to Comment on Section 6.2.3, Page'6-2 The Applicant has taken the necessary action to align itself with the Staffs' opinion regarding. the accumulation of information needed to complement existing data.. Section 4, Environmental Surveillance, and Section 6, Special Surveillance, Research, or Study Activities of the Oyster Creek Nuclear Generating Station Proposed Environmental Technical Specifications (ETS), submitted to the' AEC.on November 8, 1973,, identify and describe each activity which-the Applicant has
' proposed to undertake.
('11) Response to Comment on Section 6.2.4, Page 6-3 k
The comment suggests sampling of herbivorous and carnivorous i
fishes, waterfowl, and other consumers of aquatic life and notes that i
neither fish nor aquatic vegetation is sampled at present. An updated environmental monitoring program,* to be implemented in the near future, will include sampling of fish, clams, and crabs. The State of New Jersey and the USEPA have sampled and analyzed fish, crabs, clams, algae, and other veg'etation extensively in the vicinity of Oyster Creek.
(The brief description of'these studies in the AEC Environmental Impact Statement did not mention all of these analyses.)
Comparison of vege-tation data with fish, clam, and crab data indicates that fish, clam, and crab sampics can be'used as indicators to monitor time trends in aquatic vegetation concentrations.
(12) Response to Comment on Section 8.6, Page 8-18 The Applicant disputes the statement that "... significant detri-i mental effects (are) being caused by the plant in its present design
' (which) warrant initiation of corrective measures...". The Applicant considers that items of slight to moderate environmental impact are e
i associated with the operation of the plant. After four years of oper-ation, the addition of heated cooling water has had a discernable but
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I minor effect on aquatic organisms. An annual accumulation of warm l
water o a risc in seasonal water temperatures from operation of the plant is not expected to produce any significant deleterious effect.
The environmental monitoring pro' gram, instituted in 1965,'would have detected any change to the environment which would have had a significant detrimental effect.
The Applicant has addressed the areas'of concern regarding impinge-ment monitoring and entrainment monitoring in it's proposed Environ-mental Technical Specifications.
It should be noted that the environ-mental surveillance program has been designed to determine the extent that plant operatior may be causing adverse and beneficial changes in the ecosystem and that the programs are sufficiently comprehensive to cover all elements of the ecosystem that could reasonably be expected to be affected by plant operation'.
(13) Response to Comment on Section 9.2.1.1, Pages 9-8 to 9-10 The comment neglects to admit that there are disadvantages to absolutely everything that man ' proposes, even operational variations of a single cooling scheme. The operational variations of the existing m
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cooling scheme, as well as' consideration of other cooling scheme's, have been evaluated and the balance favors the once-through cooling scheme even though it, as well as any other man-made action, will clearly have disadvantages. The Applicant has already proposed special impact monitoring studies in the areas of entrainment and impingement in order to ascertain the effect on aquatic organisms due to the recom-mended utilization of the plant's dilution syst'm.
e (14) Response to Comment on Sections 9.2.1.3, 9.2.1.4 and 9.2.1.5, Pages 9-13 to 9-19 l
The Applicant considers the comment requesting further discussion of salt water cooling towers "... with smaller approaches than 23 F
..." to be unreasonabic and inappropriate. The Oyster Creek plant went into construction in 1964 and went into commercial operation in 1969. The commenting agencies are. reminded that the Oyster Creek plant review under NEPA is unique, in that the plant has already been con-structed. Alternatives were evaluated in 1964 and thereafter. There was no large salt water cooling tower technology available in 1964, or even in 1969. The 16 formation presented in the draft EIS regarding utilization of salt water cooling towers is adequate and draws from the best available information on that subject that the Applicant was able to obtain.
The Applicant agrees with the AEC on their basis of the reasoning
-for including the operation of the dilution pumps in the discussion of the alternative of a natural draf t salt water cooling tower.
The Applicant has addressed the area of improving liquid, solid and gaseous radioactive vaste systems. See Response to General Comment 2 to letter dated August 9, 1973 from the Department of Health, Edu-cation and Welfare herein.
The Applicant considers that it has rigorously explored all the various avenues of alternative action and suggest the commenting agency's inspection of both the Applicant's Environmental Report prepared for the Oyster Creek Project and the Forked River Project.
However, the Applicant is bound by law to consider economic costs and cannot, there-fore, ignore the economic cost associated with any alternative. This consideration applies to every single action which the Applicant takes since all costs are eventually borne by the, consumer.
Therefore, the i
Applicant does not concur that the alternatives be explored without regard to cost.
The Applicant also does not concur with the comment that "... it would seem that a more complete evaluation of the environmental benefits of alternative closed-cycle cooling systems should be presented...".
A complete evaluation has been made.
It is unreasonable to request that "it would seem that a more complete evaluation" be done when a complete evaluation has already been done by the Applicant and inde-pendently assessed by the Commission.
Additionally.the Applicant disagrees that "... Barnegat Bay is too shallow for optimum heat dis-persion and is unable to discharge its total waste heat load to the atmosphere..." since if this were the case, Bay temperatures would continue to rise as long as the plant operates. This is not the case.
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,. The Bay ia abic to disperse the heat through the use of a mixing zone which ie a limited area existing at a constant, slightly higher temper-ature than ambient Bay temperature. Also, the comment that "...
several large fish kills have occurred in the past..."-implies larger losses than have in fact occurred. The comment additionally fails to limit those losses to what were essentially.monospecific incidents (Atlantic menhaden).
(15) Response'to Comment on Section 9.2.1.10, Page 9-24 The Applicant disagrees with the comment that "It seems to us that... diverting fish toward the dilution pumps would not greatly reduce fish entrapment losses". In the past, one or more dilution water pumps have been operated as required to control the temperature of the plant discharge water. The dilution pumps are used at other times also, to meet minimum' dilution water requirements for the existing radwaste system discharges when all four circulating water pumps are not operating. The dilution pumps are protected only by trash racks which permit the passage of large fish directly into and through the pumps. The low speed, axial flow pumps have seven foot diameter impe11ers. Consequently, damage to fish has not been a problem; this is further substantiated by the experience with run-of-river hydro-electric turbines of similar characteristics. The diversion of fish toward the dilution pumps, therefore, is an alternative to reducing fish entrapment losses. Accordingly, the Applicant considers the suggestion of further discussion and expansion of this section to be unnecessary. Additionally, the Applicant has proposed to the AEC on November 8, 1973, in its submittal of the Oyster Creek Nuclear Gener-atinh Station Environmental Technical Specifications, that the Applicant undertake, as part of its 'overall environmental surveillance program, an impingement monitoring program to determine the number and mortality of organisms impinged on the intake screens and transferred to the
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heated effluent canal. Under this prog ram the number, size, weight and condition (dead or alive) of organiams collected on the intake screens will be recorded periodically for three years. During the first year sampling will be conducted weekly; thereafter, the sampling frequency may be altered.
At the time of sampling, intake velocity, temperature and salinity will be measured. Mortality to organisms trancierred to the effluent canal will be evaluated by placing some living impinged specimens in cages in the effluent canal for a length of time equivalent to the time of passage in the canal. The Applicant has further agreed to study methods of redu'cing the number of fish impinged should the results of the impingement monitoring program demonstrate that a significant 1cvel of impingement is indeed occurring.
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As*ncy Rtferences 'Lsttsr deted Szptembar 6, 1973 from Mr. Sidnty R. Galler, j
Office of the Assistant Secretary of Commerce'to Mr. Daniel R. Muller, U.,S. AEC.
4
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(1) Response to Comment Letter j'
. The doses due to releases o'f halogens from the Oyster Creek station are not substantially above the proposed Appendix I to 10 CFR 50, design 4
obj ectives.
The Applicant has already responded to the AEC regarding proposed modifications to the solid, liquid and gaseous radioactive waste systems in order to conform to proposed Appendix I to 10 CFR 50.
See Response to General Comment 2 to a letter dated August 9, 1973 from the Department of Health, Education and Welfare herein.
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Aaency
Reference:
. Letter dated September.12, 1973 from Mr. Ph'.111ps,
' Federal Power Commission to ifr. Daniel R. Muller, U. S. AEC.
(1) Response to Comnen't Letter
'I Table 8.4, page 8-11, of the Draft Environmental Statement was updated on November 29, 1973 using later information equivalent to that contained in MAAC's Report dated April 1, 1973 and submitted under FPC's Order 383-2.
The revised Table 8.4 is attached herewith.
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1 Reviced and Epdated 11-29-73
TABLE 8.4 PROJECTED GROWIH RATES AND RESERVE MARGINS IN MAAC POWER POOL FOR THE YEARS 1973 THROUGH 1982 (a) s Summer Requirements Winter Requirements Installed Peak Installed Peak Calendar Capacity Loads Reserve With Reserve Without Capacity Loads Reserve With Reserve Without
- Year (MWe)
(MWe) Oyster Creek % Oyster Creek'% (b)
(MWe)
(MWe) Oyster Creek % Oyster Creek % ( 8 1973 36368 30320 19.9 39627 26520 49.4 1974 40904 33040 23.8 22.0 43758 28540 53.3 51.1 h
1975 45691 35740 27.8 26.2 47621 30700 55.1
, 53.1 1976 48476 38570 25.7 24.1 50379 32870 53.3 51.4 1977 52599 41600 26.4 25.0 55364 35330 57.6 54.9 1978 56009 44730 25.2 23.9 60265 38060 58.3 56.7 1979 60566 48230 25.6 24.3 63783 40820 56.3 54.7 1980 65547 51820
.26.5 25.3 68803 43860 56.9 55.4 g
1981 71775 55660 29.0 27.9 75029 47080 59.4 58.0-1982 76211 59740 27.6 26.6 78379 50530 55.1 53.9-(a) Reference 1, Section 2 and 3 (b) Starting in 1974 e
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Agency
Reference:
Letter' dated Septc=ber 12, 1973 from Mr. Richard J.
Sullivan, State of New Jersey Department of Environmental Protection to
'. ' Mr.' Mintzing.
(1) Response to Comment Letter I
The. canal bank stabilization program, which' the Applicant already has underway, was discussed in Response to Comment Letter to the letter dated January 23, 1973 from the Department of Interior herein.
The Applicant has already addressed the AEC Staff conclusion on page 5-5 of the Draf t EIS regarding operation of. the dilution system at full capacity when the water in the discharge canal exceeds 87 F, as measured at the U. S. Route 9 bridge over the discharge canal.
By letter dated November 8,1973, the Applicant submittad their proposed environ-mental technical specifications (ETS) for the Oyster Creek Nuclear Generating Station for AEC approval. Special. conditions for operation were proposed that specifically address the Staff's conclusion in this The Applicant has proceeded with the ordering of equipment and area.
arranging for contractors in order to accomplish the ETS as proposed.
The Applicant will further be prepared to implement those proposed ETS when the Full Term Operating License is issued. It is noted that the AEC already has regulations that require establishment and implementation of ETS that are subject to a continuing review by the AEC. Additional information on ETS is discussed in:
(a) Response to Comment 2 to the letter dated August 22. 1973 from the Department of IIealth, Education and 'n' elf are herein.
l (b) Response to Comment on Section 5.2.1, Page 5-2, Response to Comment l
on Section 5.5.2.3, Page 5-20, Response to Comment on Section 5.5.2.4, Page 5-28, Response to Comment on Section 6.2.3, Page 6-2, Response to Comment on Section 8.6, Page 8-18, and Response to Comment on Section 9.2.1.10, Page 9-24 to the letter dated Septem-ber 4,1973 f rom the Of fice of the Assistant Secretary of Commerce I
herein.
(c) Response to Comment Letter and Response to Comment 7, Introduction and Conclusions to the letter dated September 24, 1973 from the Environmental Protection Agency herein.
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Reference:
Letter dated September 24, 1973 from Mr. Sheldon Mpycrs Environmental Protection Agency to Mr. Huntzing, U. S. AEC.
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(1) Response to Comment Letter The Applicant has already responded to the AEC regarding proposed modifications to the solid, liquid and gaseous radioactive waste systems in order'to conform to proposed Appendix I to 10 CFR 50.
See Response to General Comment 2 to a letter dated August 9, 1973 from the Departcent of Health, Education and Welfare herein. The modifications proposed for the Oyster Creek plant are currently in engineering and detailed informa-tion is planned to be submitted as FSAR Amendments in May and December 1974.
The Applicant will construct a n'ew meteorological tower at the Oyster Creek-Forked River site in the near future to conform with AEC Regulatory Cuide 1.23 requirements.
The Applicant has already addressed the concern areas of impinge-ment and entrainment losses and has responded to the AEC on November 8, 1973 identifying all of the studies it has proposed to undertake as part of its environmental surveillance program and special surveillance, research and study activities. Additionally, the Applicant disagrees with the statement that "the little information that is provided points to an unacceptable icvel of damage". The Applicant submits that there is no justification for the extrapolation of the impingement rates the EPA arrived at in their detailed comments.
The Applicant hereby requests the AEC or the EPA to furnish the Applicant the complete EPA aerial infrared studies of the Oyster Creek thermal discharge including procedures, calibration, equipment and all data thereto in order to permit the Applicant to adequately comment o; the study performed. Absent such submission, the Applicant suggests that the AEC should properly ignore this EPA comment.
It is noteworthy that the studies have not been released for public information, and that the Applicant has been unable to procure even a preliminary report on this subject for their review and comment. Notwithstanding the fore-going, the Applicant has proposed to conduct a thermal plume mapping study, whose objectives have been previously described.
See Response to Comment on Section 5.2.1, page 5-2 to a letter dated September 4, 1973 from the Office of the Assistant Secretary 'of Commerce herein. The results of this program will be submitted to the AEC and will be made available to the public.
Regarding the' comment that there is a " lack of information concerning the biological effects of the plants' cooling system and,the extensive impact of the plants' thermal discharge on Barnegat Bay...", the Applicant submits that there is extensive information on the effects of the cooling system incorporated in the Rutgers and Wurtz reports.
In summary, these multiple studies have found no significant biological effects caused by the plant operation.
Further, it is empirically obvious that the plant has provided a popular recreational fishery for s.
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' game fish and crabs in the discharge waters. EPA's expression of
" extensive impact" is baseless, since if there was a lack of information, i
then there is obviously no basis for their determination of " extensive impact". The Applicant, therefore, disagrees with EPA and requests that the AEC proceed as expeditiously as possible in its review of all these matters and grant the full-term operating license in a timely manner.
(2) Response to Comment 1. Introduction and Conclusions See Response to Comment Letter above.
(3) Response to Comment 2, Introduction and Conclusions See Response to Comment Letter above.
- (4). Response to Comment 3, Introduction and Conclusions See Response to Comment Letter above. As indicated, the meteoro-logical station at the plant is being upgraded to conform to new guide-lines.
Neverthelese, the Applicant categorically denies the EPA's assertion that, based on a few observed problems during one site visit, that the extensive data gathered over many years is " useless".
Such a conclusion is unfounded.
(5) Response to Comment 5, Introduction and conclusions See Response to Comment Letter above.
i (6) Recponce to Comment 6, Introduction and Conclusions See Response to Comment Letter above.
e (7) Response to Comment 7, Introduction and Conclusions Analyses performed by Rutgers University in Oct'ober 1967 (Third and Fifth Progress Reports) have yielded dissolved ~ oxygen concentrations in Oyster Creek of'8.1, 7.96, 8.11 and 8.01 mg/l with a mean of 8.04 mg/1, Data from water quality surveys, conducted by the EPA together with the New Jersey Department of Environmental Protection during the summer of 1966 and 1967, have shown that the dissolved oxygen concentrations of seventeen samples were above the applicable crite,ria for Oyster Creek j
(Ref erence:
" Pre-conf erence Report for Water Quality Standards Setting /
Revision Conference, New Jersey Atlantic Coastal Area", U. S. Environ-4 mental Protection Agency, Region II Office, New York, New York, May 1972 and personal communication). The mean dissolved oxygen concentration in Oyster Creek for the period June 1970 through March 1971 was 7.41 mg/l (Rutgers University Seventh Progress Report).
All of the observed dissolved oxygen values, both pre-operational and post-operational, are greater than the State criteria for Oyster Creek. The applicable criteria are:
" Daily average not less than 5.0 mg/1.
Not less than 4.0 mg/l at any time."
In light of the criteria, the dissolved oxygen levels in Oyster Creek should not be construed as low.
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If the dissolved oxygen levels in Oyster Creek are net construed to be low, in view of the preceding evidence, then the Applicant should not reasonably be expected to (a) charac-terize the adjacent waters with respect to physiochemical data, (b) determine whether oxygen concentrations in the near Bay area are lower than acceptable and (c) determine the effect that the heated effluent has on dissolved oxygen concentrations in the Bay.
The Applicant fails to understand how the EPA can relate acceptable dissolved oxygen concentrations in the Oyster Creet heated effluent to the point where it is necessary to provide data as to the effect it is having on the Bay.
Noteworthy of mention and pertinent to this comment is the general ecological survey of aquatic macroinvertebrates proposed by the Applicant on November 8,,1973 in the Oyster Creek Nuclear Generating Station Environmental Technical Specifications. The survey has been proposed to provide information to complement existing data as, identified by the AEC in the draft EIS (pages 6-2 and 6-3).
The objective of that survey is to evaluate changes in populations of commercial, sport and non-commercial organisms, including shellfish, and to identify alterations of community structure in the region of the Bay affected by the thermal plume.
Benthic macroinvertebrate organisms will be sampled monthly for three years at stations selected as representative during transect studies along the Bay. Quantitative replicate samples will be taken within and outside of the plume to detec't thermal effects on the biota.
Numbers and sizes of organisms collected at sites within the thermal plume will be compared with those at control i
sites elsewhere in the Bay.
Larger organisms may also be evaluat'ed with photographs and traps. Additionally, measurements of.
dissolved oxygen, temperature and salinity will be taken for each sample.
l (8) Response to Comment on Radiological Aspects, Done Assessment The environmental monitoring program is being upgraded to conform with recommendations in USEPA ORP/SID 72-2, dnd USAEC Regulatory Guides 4.1 and 1.42.
At the present time, it is anti-cipated that all analyses will be performed by an outside contractor who will bear primary responsibility for laboratory analysis quality control.
However, the adequacy of the co'ntractor's laboratory analysis quality control program will be monitored by the Applicant.
(9), Response to Comment on Non-Radiological Aspects, Biological Effects 1
On page 13 of the EPA statement a six-month period'of maximum
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abundance of crabs impinging on the screens is given as 466 crabs per hour from April to October.
The Applicant's screen census I
clearly demonstrates that this cannot be the case.
The rate of impingement on the screens.for each month of the 1971 survey was:
April 17 samples 34 crabs per hour May 33 samples 77 crabs per hour June
'40 samples 223 crabs per hour July 5 samples 400 crabs per hour.
'It.is readily apparent from the above data.that crabs do not occur abundantly until June.
Crab samples from the screena taken
.during the 1971 screen census included 39 taken during.the day (7 A.M. to 7<P.M.) and~48 taken at night (7 f.M. to 7 A.M.).. Crabs were found at an overall rate of 45 per hour during the day and
'247 per hour during the night. Of:the five July samples collected four.were night samples.
(The one day sample produced 40 crabs; the four night samples produced 566 crabs.) The July rate of crab impingement in the above data is strongly skewed to the high side.
There is no justification for the; extrapolation of an impinge-ment rate as projected in Figure 1 of the EPA comments.
The EPA states that mortality from acreen impingement combine'd with lag effects after passage.to the discharge canal should be estimated to be 50% rather'than 5%. The Applicant does not agree.
Crabs are amazingly hardy. animals. Once passed to the discharge canal no further kill would be expected that would come anywhere near a 50% loss.'.No dead crabs have ever been observed in the discharge canal..Some minor losses due to residual mechanical damage could conceivably occur.
Crabs have pronounced regenerative capa-bilities and lost appendages reform. Mechanical losses would have to be associated with severe body damage. This has never been observed and any such losses would probably represent much less than one percent of the animals passed over the screens.
Heat in the discharge canal is not lethal to the crabs. As a matter of fact, oyster Creek supports the best inshore crab fishery of Barnegat Bay in so far as the Applicant's consultant has bebn able to determine.
The site is.very popular with crabbers who prefer the discharge waters to the. cooler intake waters for their o
crabbing activities.
A simple count of crabbers along both waters clearly demonstrates this.
If the loeses hypothesized by the EPA did in fact occur the crab population in Oyster Creek would by now be so reduced that the public would no longer bother to crab there.
1 On page 15 of the EPA statement a reference is made to a study showing 165 million mehanden larvae killed at the Brayton Point Plant (New England Power Company). Tliis figure was extrapolated from a one-hour sample collected by Dr. Clarence Tarzwell.. (Tele-phone conversation between Mr. R. R. Younger, Resource Management',
Inc., and Mr. Milton Anderson, environmental engineer, New England Power Co.) The EPA. comments imply that fish larvae-are being destroyed in massive numbers. There simply.is no evidence to
-support this.
Comparative guesses of possible conditions at the Oyster Creek Plant with possible conditions at some other plant are misleading.
The geographic relationship of each plant to its aquatic environment, the species present, plant size, and mechanical operation of the plants must be considered.
Each plant should be studied individually.
In the absence of specific studies only the broadest generalizations can be drawn.
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The Oyster Creek Nuclear Generating Station, after three years of operation, has not eliminated any species from the area.
Further, it has provided a popular, productive fishery that, in season, produces, contrary to the EPA prognostications, striped bass, white perch, winter flounder, crabs, bluefish, and many other species for recreational, angling.
(10). Response to Comment on Non-Radiological Aspects. Chemical Effects The Applicant has made efforts to reduce the chlorine residual level as much as is practicable. Additionally, monitoring for chlorine has been proposed by the Applicant as part of the Oyster i
Creek Nuclear Generating Station Environmental Technical Specifi-cations.
It has been specified that the concentration of chlorine, the only biocide used at the plant, shall not exceed 0.1 mg/l as measured at the discharge' outlet.
Samples will be taken during chlorine treatment once per month for one year. Three replicate
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4 samples will be taken each month. A suitable standard method will be used for chlorine analysis.
Should concentrations greater than 0.1 mg/l in any two of three replicate samples in any month occur, the addition of chlorine in the station will be adjusted to such a level that concentration does not exceed 0.1 mg/l at the discharge out;et on the basis of the analysis of another series of samples.
Generally, aquatic organisms can be adversely affected by concen-trations of chlorine at least as low as 1.0 mg/1.
Continuous exposure to concentrations of 2.5 mg/l or greater is necessary 4
to kill most encrusting organisms. However, some organisms are sensitive to much lower levels for long exposure times.
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'Although residual chlorine concentrations at the condenser or plant waste discharges have been found to be about 0.1 mg/1, these y
levels are greatly reduced upon mixing in the discharge canal.
Residual chlorine concentrations of 0.1 mg/l or less at the dis-charge points should not result in significant adverse effects to aquatic biota in the receiving waters.
The chlorine addition rates will be adjusted to match the existing chlorine demand of the circulating water, such that the residual chlorine meets the limiting condition of the proposed Environmental Technical Specifications. Mixing in the discharge tunnel with water from the other five circuits of the plant's condenser results in concentrations at the discharge outlet of less than 0.1 mg/1.
i Any residual chlorine discharge is probably consumed in the discharge canal within 5 minutes (draf t EIS page 5-28).
Monitoring at the discharge outlet monthly for one. year should provide adequate support for the fact that minimal residual chlorine from the station enters Barnegat Bay.
4 (11) Response to Addit,ional Comments The Applicant will undertake special surveillance to determine the source and magnitude of the EPA measured exposure rates near Route 9.
Unpublished preliminary data suggest that the incremental I
exposure rates compare with typical natural radiation exposure rates throughout the area.
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