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JE"CEY CENTIL'.L POWER 6 L3GHT C0!PANY RESPONSE TO Tile ATOMIC ENERGY COMMISSION DRAFT ENVIRON}EUTAL STATEENT s
RELATED TO TllE OYSTER CREEK MUCLEAR GENEPATING STATION DOCKET NU}EER 50-219 DECE!BER 1973 1
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'GENCI%L 1.A ffch Mortelities 1.D Ef fects of Canal Construction and Operation 1.C Canal Ernricn Silting and Sedimentation t
l.D The I:ffects of Released Ecat
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Impfugement on Intake Screens i
1.T Entrainment_of Plankton, E qs and Larval Forns La_nd Use end Consumntive Water Use 1.G n
1. 11 C,hemical and Itadiological Discharneo i
1 2.
LICENSC CONDITIONS AND TECllNICAL SPECIFICATION REQUIRDENTS i
3.
PLANT MODIr1 CATIONS ASSOCIATED WITil MINIMIZING ENVIRONME"TAL IMPACT l
3.A Intake and Dircharre Canal Improvements j
3' B Dilution Pung Modificatiog I
3.C Cooling Unter System Procedure changes 3.D Cenal Terpercture Monitoring Syst,em 1
4.
DETAIL CO.5ENTS ON Ti!E AEC DRAIT ENVIRON!I"TAL STATDENT
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GENERAL
~The environmental problems identified and evaluated in the Ovster Creek Station Envizonrental neport,-P. arch 1972, and the AEC Draft Environrental Statenent Relating to the Oyster Creek Nuclear Generating Station are considered.by Jersey Central Power & Light Company to be of minor importance, in comparison to the contribe
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- the plant to the human environment and theLwe11' being of the human community. However, in light of the company's commitment to conduct its activities in a manner consistent with the goals of environmental protection and to reasonably minirize the environmental impact ofLits operations and construction activitics, Jersey Central has determined to undertake the irprovements or r.;;:diNtions to, plant systens and procedures discussed below. lThe envireacantal inpacts and adverse effects will be discussed in the order that they appear in the Summary and Conclusi_ons of the AEC Draf t Environ-mental Statement (pt.res i through 111).
A.
Fish Mortalities The menhaden mortalitics occurring in the discharge canal during the winter months are caused by:
(1)- The attraction of the fish by the varm water in the canal and their tendeiicy to' stay there during vinter instead of migrating to generally warmer water to the south, and (2)' 1he reduction of the terporaturo in the discharge canal and thereal pJune when the plant ceases operation. The resulting water temperature (Bay winter anbient 30" to 40*F) and, perhaps,.the rate of change of rater temperature are lethal to nenhaden.
i Several steps are being taken 'to minimize these occurrences:
(1)
To the extent that such action is consistent with safe plant operations, shutdowns vill be avoided during the winter months when such mortalities may occur, i-
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(2)
In order to reduce the attractiveness of the thereal plume and canals as winter habitate for menhaden, the dilution pump system will be operated to reduce the plant Delta T and therefore the plume and discharge canal temper-J atures.
The-details of the alterations and procedures are discussed-later in Section 3.B.
4 (3)- In order'to reduce the rate at which the diecharge canal and plume return to ambient temperature af ter a plant shutdown or trip, alterations wi)) Le nade so that the dilution pumps will be automatica])y stopped when the plant trips. As soon as possible af ter a trip, circulating water synten pumps will be secure 1 consistent with the need for coolinn water for safe couldoun of the plant.
During an orderly shutdown, dilution pumps and circulat.1:a, 4
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water pumps vill be shutdown in a canner which will ninimize the rate of LeeperatureEdecrease in the discharge canal, 2
it'is.important to note that these measures will not necessarily-eliminate the occurrence of fish mortalities but mayl reduce v number of fish mortality in61 dents.
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.he raensures mentioned above vill, we -believe, reduce.the nt.nber of fish corta11 tics in any incident.
Several alternative solutions
- such as weirs to prevent fish nigration up the canal. -and deliberate shutdoens or load reductions during the migration.
.ocason to discourage schooling in the dischargo-canal have been considered. The first alternative, whether tried on the enf sting canal or a separate canal on Jersey Central property, which avoids the present property owners along the discharge' canal, would again not clininate the. problem but only ninimize it. The present ecnal could not be fully blocked by a weir.
because of the'use by boats proceedirg to and from private property and marince along the discharge canal. A weir could
~be p3 aced upstrecm of the rost vesterly private prorerty but' j
regard 1 css of the Jocations of the weir, a thernal plume would
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exint downstreau, uhich would be an attraction for merhaden I
and which would cool down after plant shutdown resulting in fish t..ortalities.
Furthermore, a good number of'fich'onter the discharge canal through the-dilution systen and from the l
circulating water intnhe. screen systen. Tnese fish would be cubject to the thermal stress during plant shutdown. Although 5
these r.odifications probably would reduce the w ber of rhh that die per-incident, the number of fishkill incidents would not necessarily be reduced and J'crsey Central does not believe the cost of these changes is warranted. We believe the changes that are being-irnplemented will significantly reduce the impact of station operations on the finfich pcpulation.
i D.
Effects of Canal ~ Construction and Operation Jerocy Central does not feel that there are any bases for the conclusions drawn by the Commission concerning the irpact
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of the loss of spawning and nursery areas or the introduction of boring marine orcanisms into the canal.
These retters are discussed more fully in a later section.
There are no alterations to the plant or changes in plant procedures which could have a beneficial effect on these two concerna and which i
are considered reasonable by Jersey Central.
C.
Cana) Crosion, Silting and Sedirentation l
The concern expressed-by Jersey Central's consultants, the
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Departmant of the Interior W and the'AEC staff as well as the need for canal-improvemnt to permit full diluting and circulating water system flow led to a study of-alternative canal stabilization methods. Jersey Central will proceed with a program to stabilize the banks of th'e intake canal
>(D U.S. Dem t:,.nt.cf t he-Interior let ter f r.- P. W. Lyons, Deputy A w20 tar.t.
Sceretary of the Interior, to D. R. Mdller, Directorate of Licensing, ITAL;C,. dated 7anuary 23, 1,973.-
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~'e betwcon State Highway. Route 9 and _ the plant and the discharge canal between the plant'and State Highway Route 9 as'soon as.all-regulatory approvals. arc obtained. These alterations
- vill _ cost.approximately $1.2 million~and will take many months to-complete..The modifications will include Ifned drainage.
-ditches ~to collect and control run-off water from the canal banks and surrounding areas.
During the reconstruction of the banks, the cuals will' be returned to t.bcir design condition.
to permit. full operation of..the dilution system as discussed in L above and D. belou.
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-In a stipulation between' Jersey Central and the ':ew Jeracy Departnent. of Conservation and Econouic Developtwnt(2)-which was ir(3 crented by a New Jereey Public Utility Connission Order Jersey Contral agreed "that it will be responsible for dredging such r,hoals as'may be due to cooling water flows.
State representatives shall ansist in determining the anount and location of dredging based among other things on Cor:pany's 1962 and 1966. surveys and the Stato agreen 'to cooperate in l
. making available its records to aid the Company to carry out its.dreds!ng programs".
An-up-to-date survey of the canals bottom coatour in. being
. rnde and vill be cc:rpared to the referenced 1962 and 1966 data to deter:nine the dredging that need be done. Jersey Central vill consult with the State and af ter obtaining the appropriate regulatory aut.horications vill accoe.plish the necessary dredging.
D.-
The Effects of Released Heat
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-The conclusion that the heat released from the plant "makes a significant inpact on the waters of the Day" is not supported by the Staff's analyses, and is contradicted by the reports j
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of Rutgcr's work in the waters used by the plant.
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in order to reduce even the potential for environmental effects duo to elevated temperatures in the canal and t.hc Bay, Jeracy j
Central will agree to run up to two dilution pumps any tire the canal tornerature resches or exceeds 87'F at the railroad bridge.
j Such a requirement has becn :rade a part of the Environmental
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Technical Specificat ions.
The rationale for rur.ning two pumps
. continuously when above 87'F instead of the three suggested t
by the'AEC staff is presented in Section 3.C.
In addition, a new temperature monitoring system is being inr,talled at 4
the railroad bridges across the intake and discharge canals, i
and intake temperature and the temperatures at the bridges j
will be continuously recorded.- Temperature at the discharge 1
canal bridge will be alarned to alert the operators to the 4
need for dilution puup operation.
(2) State _.of New Jersey, Department of Public Utilities, ' Board of Public
' _ Utility Comniscioners Stipulat. ion. -' DCED, Docket' No. 652-60,
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_ _ February 14, 1966.
L(3)L State of hN JernayL 1mpartment of lwblic UtilIt.ien, lioard of Public 1
UtilitV Com.b.'16.r.uta Second Interiu Or?.e. Dxlet No. 652-60, 1
ApriJ,22,;]966.
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l E.
Imoincewsnt on Intake Screens We question the AEC estimates of loss of crabs and winter flounder on the intake screens since the short duration of the curvey and the small number of sampling dates prohibits accurate extrapolation of these data to yearly impingement rates. Jerr,cy Central has included a survei' lance program in the propered Environmental Technical Specifications which will deterrsina the number and condition cf orgcnisms impinged on the intaka screens and transferred to the heated effluent canal.
The results of this progran vill be used as the basis for a Limitinn Condition for Operation, a Reporting Level, syctem alterations, or no action at all, depending on the severity of the impact.
F.
Entrainrent of Plankton, Eves and thrn1 Forrys is discussed in the statetent, insufficient data are availabin to assess the fq.act of entrainment.
Therefore, the proposed Environtental Technica.1 Specifications include en entrainnent surveillcnce program which is designed to determine the kinds and quancitica of phytoplankton and zeeplankton (including invertebrate end fish eggs and larvae) taken into the condenser cooling systen and the t.ortality sinong organisr.s passing through the nysten and being exposed to cicvated temperatures.
The renults of thiu curveillance program will be used as discussed above under Impincement.
G.
L.md Use and Consumntive water use lhese inpacts were and are necessitated by the project, and are not considered by Jersey Central as significant in light of the projecta benefits to the human environment.
11.
CherAcal and Radiologien1 Discharges All chemical and radiological effluents are at such low levcis as to be en insignificant impact on the environment.
Due to the concern over possible copper buildup in shellfish, Jeracy Central vill conduct a special study to determine if copper content in shellfish in Barnegat Bay is cor elated with their location with respect to the station dit harge.
The results will be reported to the Commission.
The radiological environtental monitoring program contained in the Oyster Crcok Station Technical Specifications is currently being revised and will be.subnitted as a requested change to that document.
2.
LICENSE C0"DIT10MS L"D TECHNICAL SPECIFICATION REQUIRE'!ENTS Jersey Central concurs in the need for canal bank icarovenent t o reduce the truntport of silt and cedlnentation.
The detalin of there improvetants are disconced in Scotion 3. A.
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Jersey Central also agrecs to the use of the dilution pumps to reduce tbc temperature of the discharge canal and therefore the ten?crature of the thernal plume in Barnegat Bay. However, instead of usipg all three pumps as suggested by the staff, Jersey Central proposes to use two continuourly, maintaining one in standby to be turned on if one of the operating pumps should fail and to permit normal caintenance of the pumps. This proposal is discuased in nore detail in Section 3.h.
Jersey Central agrees to utilize existing systens to the greatest extent practical to ninimize the probability and extent of fish r.ortu11tica resulting froa plant shutdown during the vinter. These systen and operating procedure changes are outlined in Section lA above and datailed in Section 3.C.
While there is no reason to believe that fish itpingement on the intake screenc at Oyster Creek is a significant impact, Jersey Centrsl vill conduct a survaillance progran to better evaluate this ccncern.
This progrna is included in the proposed Oycter Crech Environr. ental Technical Specifications (OCE'I S).
The Environmental Technical Specifications include requircnents for evaluating and reporting any preb3er.s associated with plant operations thM hwe a harraful effect on the environnent.
Action necest,nry to correct or minimize the problem vill be determined on a caso basis.
3.
phANT MODIFICATIONS ASSOCTATED WITH MINIMIZING ENVIRONITNTAh IPACT A.
Intake and Discharge _ Canal Irprovecents The intake and discharge canals at the Oyster Creek Station were designed to acconadate full fic..' of the dilution and circulating vator nystena (1,250,000 GPM).
Due to crosion fron surface run-of f and canal flow and trancport of silt, shoaling has taken place at vacioua locations in the canals and a generally un-sightly condition has resulted along the banks.
Jersey Central j
intends to correct this situation by restoring the design flow capacity and by ensuring the long-term stability of the banks.
Several bank treatments (crushed stone, vood bulkheading, j
fabriforn, etc.) are being considered.
The inprovements vill i
include c drainage systen to prevent future surface runof f from
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effecting the banks once stabilized.
Soundinga are currently being taken in the discharge canal to determine the amount of shoaling, if any, that has occurred as a result of plant operations.
A,8 discussed in Section 1.C dredging vill be perforned in accordance eith the existing Jersey Central - State of New Jersey agtcenents.
The. design and engineering work for the canal improvenent and dredging vork is being done this ninter and as soon as regulatory approvals can te obtained, thes" activitien v331 proceed.
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- B.
Dilution Pumn Podi ficationg l
The Dilution Water System vas not desigacd for winter operation and, in the past, has only been used during the summer months.
In order to upgrade the pumps to enabic winter operation as diccussed in Section 3.C. an autonatically controlled seal and lubricating vater heating. system, autonotically controlled gear oil heatern, and a heated building enclosing the pumps and auxiliary systems vill be added.
Jersey Central is proceeding on the dcsign cad ongineering work for the modifications and it is e.vp cted that the raodifications will be cor.pleted before the 1974-1975 vinter season.
During the 1973-1974 uinter, heat tracing of necessary systema is being utilized on an interim basis to permit operation.
An automatic trip feature will. also be installed on the dilution purpr. This trip will result in an immediate cessation of dilution systen f]ou after a plant trip (turbine trip) to minitrixe the cooJdown rate of the discharge canal.
C.
Cooline Unter Systen Procedure Changes The operations of the cooling vater systems, including dilution pumps rnd circulating vater pumps vill be altered to produce the uininum thereni impact and to mininize the probability and extent of winter fish nortalities.
In all cases where dilution pump operation. is called for,
.inveny cener 1 prnposes te operete a car.inun cf tre dilutien pumps instead of all three. This mode of operation is suggested:
(1)
To provide sorac degree of ficxibility to pernit nornal and corrcctive maintenance, (2)
To provide a backup pump should one trip during operation, thus enabling the systeta to better maintain the existing conditions, and (3)
Eecause the third pump is of marginal benefit in reducing canal temperature but involvec more than a 26% increase in flou.
1 The need for naintenance tine is self explanatory. The nominal Delta T across the Oyster Crcok condenser for full load conditions and various conbinations of dilution and circulating water pumps is given in Table 3.C.1.
It is our belief that maintenance of stable conditions of tenperature and flov in the canal is better than a cyclic regita.
Table 3.C.1 shows that the third purp results in only a 1.7'F decrease in the Delta T (and therefore, in the discharge canal tenperature) while increasing the flow by more than 26% (i.e. 260,000 CPM added to 980,000 CP:1). The second putp, on the othet hand, decreases dincharge canal terperature by 3.1*P or by more than one seventh of the total Pelt a T.
It in our judrensnt that the third pumn, because of its minor contribution to terperature decrease jn hetter hept in standby to function as the secono pup.p, rt.ould ero O' the others fall.
Pu;;.p ugi ation will be impletuatea au follows:
mt Bay water (1) During "se times of the year when Bare (as measured at the intche s.)acture) tempera e
l is below 60*T, two dilution pumps uill'be run continuously.
(!!0TE: Prior to canal improvenents, only one pump will be used.)
(2)
In the summer, when discharge temperatures at the Route 9 railroad. bridge crossing the canal reaches 87'F, one dilution pump will be placed into operation.
When this temperature exceeds 87'F with one dilution purp,
operating, a second pump vill be put into operation.
TABht 3.C.1*
No. of Circulating No. of Dilution Condenser
__ Ua t e r punp n Pumpn Del ta T ( *F) 4 0
20 4
1 12.2 4
2 9.1 4
3 7.4
- Assumes Full power (620 FMe Net).
The control circuitry for the dilution pumps w311 be altered to include an autonatic trip of these pumps when a turbine trip occurs (i.e. when heat input to the canci conces).
This will reduce the flow of ambient temperature water (relatively cold) into the discharge canal and therefore will reduce the rate of change of temperature. This reduction in tle cooldown rate of the canal vill help to mininize the s! ock to menhaden. Once the heat input to the main condenser 1
ceases (because'of a plant trip or reactor isolation) the temperature of the circulating water, leaving the condenser drops to the sane tenperature as the intake (or to within a few degrees of intake tenperature).
This water also contributes to the rapid cooldown of the discharge canal.
However, due to the need for sore or all of this water for safe plant shutdoun and cooldoun, these pumps cannot be automatically tripped.
Operating proceduren will be modified, houever, to direct the pinnt operators to secure these pumps as soon 1
as possible consistent with safe shutdown and cooldcun of the station.
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D.
Canal Tenperature Monitoring System i
I A study to evaluate the discharge canni requirenents at the brid.ce and to deternine the cost reoresentative locations and depths for moattoring of the discharre watern has been pelforned. Thermal and current velocity surveys were carried out un reveral days in March and April 1973 using fixed point recording instruments and mobile field equipnent.
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Program measurenents revealed that the flow under the railroad trestle exhibits varying degrees of density stratification.
Cencrally there is a lens of f reshwater from Oyster Creek and periodic freshwater runoff riding atop the denser brackish Barnegat Bay water which has been heated and discharged by the Oyster Creek Nuclear Generating Station.
During the mercurement periods the surface waters (1 to 2 feet in depth) were consistently cooler than the rest of the vertical profile, particularly on the south side of the cenal receiving the freshwater discharge from Oyster Creek.
A similar result noted on the north side of the canal was apparently due te coua Oyster Creek freshwater crcssing the canc1 and remaining in an area of generally low velocities.
The surface waters of the discharge canal upstream of the trestic are norral.ly cooler than the c.ain stream brachish waters because of the freshvater inflcw and surface cooling effects.
The reaidence cine of waters upstrenn of the trestic, determined by the plant chutdown measurer:ents conducted in April, is less than one hour.
Solar and atmosphcric heatirig at the
,urface layers--a slow process--wauld be insignificant within this tina frama.
Therefore, temperature sensurements in the mainstream of the brachish ione represent conservative (high temperature) values at the trestJe.
Based on the above reasoning, the renitoring point temperature sencors will be p3cced near mid-channel at a water depth of four feet, one foot below the previous 1v used sennor locat inn.
1Vo'indcpendent censors will be psed to insure that adequate redun~dancy is provided to allow for routine equip = nt failure, accidental damage, or vandalism, and to allov for naintenance downtiec.
In order to have a talid measurecent of intake tenperature, a similar installation of redundant temperature sensors will be placed near nid-channel of the intabc canni at the railroad trestic approximately four feet below the surface.
The two intake temperature readings, the two discharge temperature readings and the condenser diccharge temperature will be recorded in the rtation control room. The discharge t emperat ure will be alarmed ;o alert operators to the need for dilution purp operation as discussed above.
4.
DETAIL COPJ'ENTS ON THE AEC DRAFT ENVIRONMENTAL STATEMENT Jersey Central Power & Light Company has reviewed the Draft Environ-ment al S *.n.e men t (DES) related to the Oyster Creek Station and subtits the follocing comments for your consideration in preparing the Final Environnentul Statenent:
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Summary and Conclusion a
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Statement 1.
" Periodic kills of fish..."
l One reported fish mortality incident is presented on page 5-28, paragraph 2 of the DES. The last sentence of this paragraph and the first paragraph on page 5-23 state that otter large kills have occurred, but no information is given regarding who rooorted them, nagnitude, rpecies involved, etc.
Factual informstion chould be supplied to support the suenary statement.
Statement 2.
Effects of Canal Construction and Operatien.
Jersey Central sp.ru s that to sone extent the current, salinity and terpcrature regines of Oyster Creek have been changed by the construction and operation of the station coolint; system canals.
The work donc by Dr. Ruth Turner and others show the presence of shiptorms (Teredo navalis and Dankin Cou]dii) in great abundance in the dir. charge canal. Hewever, the conclusion thct the caned construction and operation has caused the intro-duction of these carine boring organises into the cs.nal is totally incorrect.
1965 surveys by Jersey Central's Consulting Biologist, Dr. C. B. Wurtz, reported in December 1971, indicate that native ship. orns existed in the streans tributcry to Barnegat Bay as a natural community element prior to canal construction.
The sclinity reginc of Oyster Creek before canal construction is also questionable..
Dr. Wurtz'c 1965 survey clearly showed th t fresh water bdtton fauna was lost fron the community at the head ui Sands Foint harina which is the marina closest to the plant.
Dounotream from this point the bottom uns enaerobic during June 1965.
During Septer.bcr 1965 the sar.p]e stations near the mouth of the Oyster Creck compicx had a typical estuarine botton fauna, but the middle stretch (up to Sende Point Marina) was still anacrobic.
No doubt flesh hater extended downstream i
for come distance beyond the point where fresh water bottem organisms were found, but this would simply be a surf ace extension.
1he fresh water would overrido the more dense saline water of the botton.
The conclusion that canal construction and operation "has climi-nated spawning and nursery areas throught the canal" is also que s ti onabi c. 'It presumes that these areas were productive j
spawning and nursery nreas prior to construction and operation.
j in fact, the 1965 survey by Dr. Wurtz demonctrated that these ctreams were not important in this respect and that Oyster Creek
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in particular could not have served such a function because the bottum was largely anaerobic.
The question of damages donc to the local marinas as a result of shipvorns and the degree to which Jersey Central is responsible for the damage is presently the subject of litigation in the State Courts of New Jersey.
The natter is still pending.
In thia resp.cet, evaluations and statenents based solely upon opinions and/or statemu.ta by marina ovners reust be carefully verified l
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before being,' presented as fact. Jersey Centtal feels that the question of environmental impact and the balancing of envirent nantal costs of the plant versu; the benefits derived must not only consider the irpact on these local individuals but must cover the coats and benefits as applicable to all nembers of the human environnent.
'he correct references for this statement rhcu'd be 5. 5. 2, 5. 5. 2.1, and 5.2.2.2.
S ta t e c.an t 3.
Canal bank crosfoa and silting.
'1he conclusie,. that the silting is excessive is not supported by docunentcd evidence in the statement. Tne carina operatorn are engnged in litigatica over the subject and should not be censidered a.4 the sole source of inforestion upon which to base this con-clusion.
Stct ecent 4.
Thermal discharge and effects.
The act ual thermal limi tntion, Uhich is the subject of a new Jersey Public Utility Conmissica Interim Order f 2 (Docket 652-60) requires that tenperatures be limited to 95'F not at the U.S.
Route 9 bridge but at a buoy located in Barnegat Bay between Oycter Creek r.nd Forked River.
The second nentence of the staterent says that " heat may reduce the productien of fish by chout 5CL0 lbs. annuc11y".
It should be nade cicar that this is only cn esticate, ertrapo]ated frod an cstinate hiven icr yearly recuction of phytopli.ukton.
The discussion in 5.5.2.4 does not fully erplain hew the conversion bienass of phytoplaahton to bicr. css of fish was rade.
The letter j
part of the second sentence ("this heat may... cause a significent loss of winter flounder cnd zooplaahton") is unfounded.
I t. is ste,ted in 5.5.2.4 nud in the Oycter Creek Environmental Report page 5.14 3 that winter flounder avcid the hented discharge area.
1he loss of flounder as,ve13 as zooplankton are apparentJy caused by entraprent on the intake screens and not by temperature pec se.
Stater. cat 5.
Impincoment on intake screens.
The 32,000 blue crabs and 24,000 winter flounder lost annually by inpingement should be placed in perspective to the aquatic ecosystem in order to justify this as a "signifiennt loss".
The area around the plant is a haven for sports fishernen during winter with both crabs and tinter flounder caught in large nunbcrs.
The number of flounders loss is greatly over-estimated beccuse the assumption is cade that they are present i
year round, which is not true.
The proper reference section is 8.4 not 8.3.
Statetent 6.
Loss of zooplankton, fish larvae and eggs.
The fi r,ure fer neeplankton, fish larvae and fi:.h eggs lost nu d to be p.inced in percpective with regard to the ecosystem.
The calculaticus were based on a conclonerate of data (5. 5.2.3) 10 -
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1 which' eay not be truly representative of the aquatic ecosystem 1
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in questicn.
In' light of this, the final sentence in the fifth paragraph on page 5-22 is too definitive.
It should.
not be stated that "the station is killing approxinately 150 million eggs.per. year and_100 million fish inrvae". The reference section should be 8.4.not 8.3.
I State ent 7.
Loss of 80 acres of freshwater marsh and 45 acres
- of sal twater. marsh.
The reference sections should include 8.4. not 8.3.
Stater.ent 9.
References should also include secticn 8.4.
j Item 7B(1) page iv.
'Ua propose changes in the statements that indicate the programs
'that-will be instituted at the site.
These are discussed more fully in'Section 3 of this "hesponse".
a.
JCPSL intends to -use a maximum of two dilution pumps and a temperature measuring depth of 4 feet belou rean tide i
icyc1 to reduce the effects of the cooler Oyster Creek water as discussed in Section 3.D above.
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- b.. The vording here should be revised to read "The applicant uill inctall appropriate controls, and employ operating
,precedurce and meccurce that vill mitigate the extint i
of fish mortalities."
I Detailed cone:. ants on the balance of the Draft Environtental Impact L
Statemant follow:
Page 2-l'O, Paragraphs 3'& 4.
h In paragraph 3, the. extent to which salt vater tidal action a-affected Oyster Creek prior to the canal dredging is not suh-stantiated. The reference and sources that forr.ed the basis for the conclusion that "the quality of Oystcr Creek water was relatively unaffected by salt water intrusion to a point 2500 feet East of the highuay" should be presented. The paragraph also
. fails to discuss how this conclusion is drawn with respect to surface unter quality or salt unter intrusion along the' entire i
length of the creek.
Paragraph 4 tends to indicate that a salt water wedge did exist on the bottom of Oyster Creek perhsps to a point much further West than that indicated in the above quote.
Figure 2.8, page 2-18.
The following revisions are needed:
- 1.. The dashed line needs to be explained.
In the Oyster Creek G
Environne ital Report (ER) Figure 2.7-2, which is the basin
. f o r (1.t subjcct Figure, tl.e Jes%J li.m indicatcc the bovad.a tes
,7 of the~ pine barren area.
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Arcas designated " deciduous swampo" and " cedar swamps" in E!; Figure 2.7-2 are combined in' the statetent Figure
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2.8 and indicated as " lowland forest".
Eccause the cedar swamps are considered as rare and endangered habitats, and the death of these swarps is considered an important lepcet, it seems imperative to distinctly designate cedar evamps in this figure.
- 3.. The ER Figure 2.~7-2 dis tinguishes between salt and frer.huater marshes vhereas the statement describes the sane areas as "saltsater marsh".
The ER designation is more exact and, therefore, preferabic.
Page 2-19, pararreph 2, line 8.
Should be revised to read " Wildlife of economic and recreational inportance found within a 5-milc radius of the site include red and smithern flying squirrel, gray and red fo::, beaver and deer.
Tabic 2.6 ar.d 2. 7.
These tables are taken from ER tables 2.7-4 and 2.7-5 respectively, but include only " representative" species fram the ER table.
It appears there is no rationale for the selection of these species since some of thec seemingly are of no greater import than r.pecies that were deleted.
Either a definition of the " representative" specica should be given or the entire sp(cies list included.
In Tabic 2.7 the designation " Birds and Waterfowl" implies that watertowl are not birds which is not correct.
Page 2-21, third line from bottom.
The cernent on the nesting of the Osprey, en endangered erecics is 1,n contradiction to the En staterent that according to a state conservatien officer six pair nested in the Ocean County area durinr, the 1971 breeding season.
Tabic 2.8 has several nistakes.
The following changer should be made in order to concur with the of ficini 1970 American Fisheries Society List of Conmon and Scientific names of Fishes from the U.S. and Canada:
a.
The accurate name of the redfin pickerel is Esor americanus nraricanus, b.
The species name of the yellow bullhead is misspelled.
It should be natalis.
c.
Chuhnucker is one word.
d.
"Eastcti." should be deleted before the con: mon names " creek chubsucher" nad " pirate perch".
c.
7:.e "fusife m darter" is now officially eclied the "sw v.?
darter". It s scientific nnr.c in Et heostona fusiforme.
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- . *a; 2Page 2-23.
Paragraph 2 stater, that 119 benthic algal. species wegeLidentified.
_However,-in.the En pacc 2.7-1, 137 species:of.benth Elflora are reported. Were the.lgpecies not accounted for in the '
statement algal species or ligher plants?
n.
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Paragraph:3 and-Table 2-9 on'page 2-23 list tuo different spellings ofLthe cigal species "Gracillcria" and "Gracilaria"..The correct' 1,
spelling should bc verified.
Pasc.2-24~, paragraph 3,711ne 5.
(
"synchasta" should be "synchaeta".
~ Table 2.13.
1 i
L This~ Table should include the scientific ncmes o' finfish.
i Common. naces are too ambiguanr.. The 1970 America 1 Fisheries Society liet should be consulted.
Page 2-30, paragraph 1, line 4.
l
~
The word "tautog" should not be capitalized.
J Popc-4-3, paragraph 3, line 8.
j "regarding" should be " regrading".
s Page 5-3, first full paragraph.
4 I
I The second from the last staturaent states that "the ability 4
of the bay to disperse the waste energy either by transport to the ocean or by heat transfer from the surface, does not nearly match the station heat discharge"..If this were truc, v
Barnegat Bay temperatures would continue to rise as long as the plant operates.
In fact, this is not the case and the next sen'tence in that paragraph concludes that the Bay is abic l
to dicperse the heat in a mixing zone which is a limited aren existing at a constant, slightly higher tenperature.
L The conclusion about the ability of the Bay to disperse heat j
should be deleted or corrected.
Pages 5-3, 5-4, Section 5.2.2.1.
The statement that tenperatures up to 104*F were recorded in July.1972 should be subriantiated before they are adopted and published in an AEC document.
L The statenent on page 5-4, paranraph~ 2, regarding fogging is in directLeonilict with the statement on page 5-2, paragraph 2.
The occurrence of wrere fogging and increae.ed accider.ts on
' Route' 9' due to fogging have' uot hen r"bs tantiated in the-Stateivnt.
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r The only refWence available to support this cdac]usion consists of interviews with marina operators by reprecentatives of Regulatory Operations. Local traffic ~ officials should be con-sulted to determine if such dangers exist.
Page 5-4, line 4.
"weater" should be " weather".
Page 5-4, Section 5.2.2.2.
The conclosjon that operation of Oycter Creek has a13cred invasion of the shipworms into the ccnal is unsupported since surveys f.n 1965 demonstrated the existence of these organises as a natural conctiteent of the estuarine corxanity.
Page 5-5, paragraph 1.
liigher silting may very well be a probJen'in thc operation of the narinas.
It is not clear that all silting in and around r.arinas is as a result of the operation of the Oyster :reck station.
Iloucver, as discussed in Section 1.C Jersey Cs.itral already has an agreerent with the State of New Jersey to correct any shoaling condition caused by plant operations and this work is presently _
being pinnned.
Page 5-5, last paragraph and page 5-3, paragraph 2.
'1he reaperature at whf ch dilution pumps are put into operation (S7'r) has, apparently, been deternined by tne Att btati on the basis of laboratory studies conducted by Gif t and L'estman of Rutgers Uaiversity. This level is the rean tenperature at which various fich and shellfish exhibited avoidance behavior.
This may not be a revningful temperature.
The 'failing of these studies in terns of the applicability of their rcsults to the field situation is related to the following facts:
a.
The results are derived from experiments uhtch vera conducted with one acclimation temperature (68*F); the resultant upper avoidance teuperatures are thus applicable only to those tiecs of the year when the organisms in the field are acclimated to this general temperature.
b.
Acclination times in the 1choratory were very short (about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).
c.
Physiological state, salinity, day length, and various ot her factors may affect the response of organiens to temperature changes.
Acclination of a species to different seasonal ter<peratures (lover in vinter, higher in summat, for instance) ray yield dif ferent upper avoldance tc=peratures--3over in uinter and h i gh c r in sutze r.
..- u.
-In ona of their-c):periments Gift and Westaan demonstrated this:
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' fact.LAmbient. temperature accliention studies with the Atlantic j
silversides showed that. " highly significant idifferences (greater than '99% probability) between :the mean responses at different ambient water terperaturcs" exist.
1
- l age 5-12, ' paragraph 1.
i i
This paragraph ecatains several typagraphical errors including the-repeat ~ of 7!11nes near the end of the paragraph; '
i.e.,
' linen 17 to 23 should be deleted cc they are the sar.e as lines.
fl0 to 16 Page 5-17, paragraph 1.
The statement about[ fresh' water in Oyster Creek to~ a point.
2500 feet East or U;S. Route 9 should includa'a discussion of the salt water wedge which may have had a significant effect en the population of shipportis in the Oyster Creek canal prior to-operation of the-station.
Page 5-18.
i
' Estimates of the numbers of winter flounder and crabs killed-by inpingeecat eay be in error duc-to the short duration of the sampling (April 31 - July 1, :1973) used to produce the l
.cstitated impingement.ratco._The rer.n of the number of organisms
~
itpinged per hour nay decrease-if itpingement data ucre available for other tine periods.
In many estuarine situatione, the composition of the animal community changes significantly seasonally.
Furthermore, the assessment of the significance of these mortality l
rates.is meaningless without considering:
a.
The size ranges of the organistw inginged.
b.
The population icyclo and production of thene organisms i
in the bay.
Page 5-23.
The assessment of the significance of the ef fect of the loss of phytople.nkton production in teres of pounds of fish lost per year to commcreial fisherran assumes:
i The 5000 pounda of fish would have been cauF t by commercial j
h a.
fisherman.
b.
All phytoplankton are converted to fish.
It also nenumes the w thhd of conversion fron phytoplankton
' ]
c.
to finh bici. ass is conect.
Since the rethod of conversion in not presented, no assessment of errors is possibic.
On the. oti.er side of the matter, the potential production of offsprinn of.thenc'fich in not c;nsidered.
1 eg g
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Assuming that the conversion factorn from phycoplankton to biomass of concercial species is correct, then commarcial shellfish 6
- species which also feed on plankton should be included in the estiriates for comercial prodection from the Bay. According to Table 2.12 of the Draft Statement, at Icast 2,791,400 pounds of che11 fish were caur,ht in Barnegat Bay in 1969. When this figure is added to the 76,400 pounds of com:nercial fish catch, the loss is less than 0.2%.
Iage 5-30, Section 5.7.2., paragraph 2.
The third sentence should read "About 14 truckloads...".
Toble 9.8.
"tianhaden" should be " Menhaden".
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