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..                                                                    3 8 tate of Netu ilersey DEPARTMENT OF THE PUBLIC ADVOCATE DIVISION OF PUBLIC INTEREST ADVOCACY CN 850 JOSEPH H. RODRIGUE2                              TRENTON, NEW JERSEY 08625              RICHARD E. SHAPIRO DIP.ECTOR PUBLIC ADVOCATE TEL: 609-292-1693
                                                                  . August 21, 1984 Mr. A. Schwencer, Chief '
Licensing Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission 7920 Norfolk Avenue, Room 144a Bethesda, MD. 20555 Re: Hope Creek Generating Station Docket No. 50-354
 
==Dear Mr. Schwencer:==
 
                            .We are writing to provide the comments of the Department of the
:Public Advocate on the Draft Environmental Statement (DES) related to
                    .the-operation of the Hope Creek-Generating Station. Our principal overall concern is that the DES fails to evaluate the cumulative risks and environmental-impacts of the Hope Creek Generating Station and the Salem Nuclear Generating Station, which is already located on Artificial-Island. Since the two facilities. are in close proximity to each other, there will obviously be cumulative' risks and impacts. that will be greater than the individual risks and impact of the Hope Creek Gener -
ating Station. 'As a consequence, these cumulative risks and impacts must be carefully determined and assessed byLthe staff prior to any FES-.on the' Hope Creek Generating Station. Kleppe v. Sierra Club, 427 U.S. 390, 410, 414 n. 26, 96 S. Ct. 2718, 2730, 2732 n. 26 (1976).
In addition to this overarching problem with the DES, the Public Advocate also submits the following: comments on specific provisions of the DES:
Section 4.2.3.2:
The DES recognizes that the applicant is required to
                                    " develop plans for a supplemental water storage reservoir to compensate for consumptive water use from the Del-aware' River" under' certain circumstances. While an application has been filed with the Delaware River Basin Commission (DRBC) and is under review, the DES can-
                                  "not measure surface water use until that application has been ruled upon. Therefore, the surface water use section is deficient in the absence of a final-DRBC disposition.                                                9p 0    -
l
                                                                                                  '    l New Jersey is An Equal Opportunity Employer 8408270136 840821-PDR ADOCK 05000354 D                          PDR
 
Mr. JA. Schwencer, Chief                                        August 21,'1984 Section 4.2.5:
_ - at r      ,y    <
3 Obviously, intervenors are-in no, position ito comment                              i:            j on the NRC's viewtof the radioactive waste manage-ment system until the staff's detailed evaluation is -
presented in the SER, which is to be issued in October 1984. We will defer any comments until the release of the report except to note that the DES
                -is inadequate at the present time without this in-
                ; dispensable assessment.
Section 4.3.5.1:
The DES states.that the Hope Creek Station _should not affect the success of the reintroduction of. endangered species through artificial nesting. Yet, the DES states this as a conclusion and provides no reason or explanation why Hope Creek will not affect this activity.
Additionally, the DES should demonstrate that Hope Creek will not adversely affect the osprey. The DES's conclusory statements in this regard do not provide a reasoned explanation.
Section 5.3.1.1:
See comment above relating to Section 4.2.3.2.
Section 5.3.2.1:
The intervenor seriously questions whether any inforrred determination relating to surface water quality can be reached prior to completion of the applicant's chlorination study. The biofouling experienced at the Salem Generating Station necessitates an overall reevaluation of chlorination procedures to insure that surface water quality is preserved.
The staff should have this information prior to drafting the FES.
Section 5.3.3:
The staff's conclusions that considerations of alternative locations for any structures identified as being in the floodplains is neither required nor practicable is un-explained, and not evident from the DES.
Section 5.6.1:
The assumption that the osprey will not be adversely
+                affected by the Hope Creek operation is not sufficiently b
 
3                                                          4 w                                -
  ''    Mr. A. Schwencer, Chief                                                                  August 21, 1984 documented. Assessing the impact resulting from the operation of Salem alone does not provide an evaluation of the cumulative impact ~on the osprey.
Section 5.9.3.2:
The intervenor is concerned about any evaluation of
    ,                the operation of the radioactive waste treatment systems until the detailed evaluation of the system is presented in the SER. The capability of the system to meet the requirements of Appendix I will not be evaluated until the October 1984 report and a proper assessment of the
_ radiological impact of the plant on humans must await that information.
Pages 5-46:
The basis for the staff's reliance on a generic study involving PWRs for the probabilities relating to a Hope -                                          ,
Creek BWR is not adequately explained. The assumption that "it is unlikely that . . . [the] core-melt liquid path-way release for the BWRs would exceed that conservatively estimated for the LPGS" is not- documented, and the reasons supporting this assumption are not discussed.
Section 5.14.2:
The intervenor questions the appropriateness of the NRC's reliance on the State 'of New Jersey for the protection of water quality and aquatic biota. Intervenor submits that this ecological monitoring should still be part of NRC oversight of the operation of the Hope Creek Generating Station and should not be delegated to a state agency.
Section 5.14.3:
The FES cannot be prepared until the applicant has submitted the additional information required by the staff (5-62).
Section 6.4.2:
                    -In calculating the benefits of the Hope Creek Station, the DES assumes that the unit will operate at an annual average capacity factor of 55%. However, experience with the
;                    applicant's operation of the Salem reactors demonstrates that the projected annual average capacity is substantially greater than the actual average annual operating capacity of these two plants. Realistic projections based on part experience of the applicant with similarly situated facilities should be utilized rather than assumptions that are incon-sistent with this experience.
 
Mr. A. Schwencer, Chief                                August 21, 1984 Appendix F:
The DES is deficient in that neither the staff nor the licensee conducted a probabilistic risk assessment (PRA) for Hope Creek. We submit that such a PRA must be conducted and that the extrapc'_ation of data is inappro-priate in these circumstances.
Thank you for your consideration of the above comments. If you have any questions, please contact either of the undersigned.
Sincerely yours, JOSEPH H. RODRIGUEZ Public Advocate, State of New Jersey By:      z(              -
RICHARD E. SHAPIRG i                                          Director Division of Public Interest Advocacy W
SUSAN REMIS lS Assistant Deputy Public Advocate
 
~    m i 2.:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board                ,
PUBLIC SERVICE ELECTRIC              :
            - AND GAS COMPANY (HOPE                :        Docket No. 503540L GENERATING STATION)                  :
CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenor's Comments to the Draft Environmental Statement Related to the-Operation of the Hope Creek Generating Station" dated August 21, 1984, in the abovecaptioned matter, have been served upon the following by deposit in the United States mail on this 21st day of August,1984:
Mr. : A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, D.C. 20555 Honorable Marshall E. Miller, Chairman -
Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Honorable Peter A. Morris Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Honorable David R. Schink Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Panel
                            . U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555
 
.i . . . ,
a....
Docketing and Service Section Office of the Secretary
                            .U.- S. Nuclear Regulatory Commission Washington, DC 20555.
Lee Scott Dewey, Esqui e                                          ~
                            . Office of the Executive Legal Director
                            - U. S. Nuclear Regulatory Commission Washington, DC 20555 -
Richard Fryling, Jr. , Esquire Associate General Counsel Public Service Electric & Gas Company P. O. - Box 570 (TSE)
Newark, NJ 07101 Troy B. Conner, Jr. , Esquire Conner & Wetterhahn 1747 Pennsylvania Avenue, N.W.
Washington, DC 20006 Carol Delaney, Esquire Deputy ~ Attorney General
                            ' Department of Justice State Office Building - 8th Floor-820 North French Street Wilmington, Delaware 19801
                                                            /h      '
Oh      I ik Richard T. Shapiro, Diiector-Division of Public Interest Advocacy A cu C s          )    t Susan C. Remis Assistant Deputy Public Advocate Dated: August 21, 1984 L-}}

Latest revision as of 13:55, 12 May 2020

Comments on Des.Des Fails to Evaluate Cumulative Risks & Overall Environ Impacts of Hope Creek & Salem Nuclear Generating Stations.Certificate of Svc Encl.Related Correspondence
ML20095E987
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 08/21/1984
From: Remis S, Jaime Rodriguez, Shapiro R
NEW JERSEY, STATE OF
To: Schwencer A
Office of Nuclear Reactor Regulation
References
OL, NUDOCS 8408270136
Download: ML20095E987 (6)
v • d • e


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.. 3 8 tate of Netu ilersey DEPARTMENT OF THE PUBLIC ADVOCATE DIVISION OF PUBLIC INTEREST ADVOCACY CN 850 JOSEPH H. RODRIGUE2 TRENTON, NEW JERSEY 08625 RICHARD E. SHAPIRO DIP.ECTOR PUBLIC ADVOCATE TEL: 609-292-1693

. August 21, 1984 Mr. A. Schwencer, Chief '

Licensing Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission 7920 Norfolk Avenue, Room 144a Bethesda, MD. 20555 Re: Hope Creek Generating Station Docket No. 50-354

Dear Mr. Schwencer:

.We are writing to provide the comments of the Department of the

Public Advocate on the Draft Environmental Statement (DES) related to

.the-operation of the Hope Creek-Generating Station. Our principal overall concern is that the DES fails to evaluate the cumulative risks and environmental-impacts of the Hope Creek Generating Station and the Salem Nuclear Generating Station, which is already located on Artificial-Island. Since the two facilities. are in close proximity to each other, there will obviously be cumulative' risks and impacts. that will be greater than the individual risks and impact of the Hope Creek Gener -

ating Station. 'As a consequence, these cumulative risks and impacts must be carefully determined and assessed byLthe staff prior to any FES-.on the' Hope Creek Generating Station. Kleppe v. Sierra Club, 427 U.S. 390, 410, 414 n. 26, 96 S. Ct. 2718, 2730, 2732 n. 26 (1976).

In addition to this overarching problem with the DES, the Public Advocate also submits the following: comments on specific provisions of the DES:

Section 4.2.3.2:

The DES recognizes that the applicant is required to

" develop plans for a supplemental water storage reservoir to compensate for consumptive water use from the Del-aware' River" under' certain circumstances. While an application has been filed with the Delaware River Basin Commission (DRBC) and is under review, the DES can-

"not measure surface water use until that application has been ruled upon. Therefore, the surface water use section is deficient in the absence of a final-DRBC disposition. 9p 0 -

l

' l New Jersey is An Equal Opportunity Employer 8408270136 840821-PDR ADOCK 05000354 D PDR

Mr. JA. Schwencer, Chief August 21,'1984 Section 4.2.5:

_ - at r ,y <

3 Obviously, intervenors are-in no, position ito comment i: j on the NRC's viewtof the radioactive waste manage-ment system until the staff's detailed evaluation is -

presented in the SER, which is to be issued in October 1984. We will defer any comments until the release of the report except to note that the DES

-is inadequate at the present time without this in-

dispensable assessment.

Section 4.3.5.1:

The DES states.that the Hope Creek Station _should not affect the success of the reintroduction of. endangered species through artificial nesting. Yet, the DES states this as a conclusion and provides no reason or explanation why Hope Creek will not affect this activity.

Additionally, the DES should demonstrate that Hope Creek will not adversely affect the osprey. The DES's conclusory statements in this regard do not provide a reasoned explanation.

Section 5.3.1.1:

See comment above relating to Section 4.2.3.2.

Section 5.3.2.1:

The intervenor seriously questions whether any inforrred determination relating to surface water quality can be reached prior to completion of the applicant's chlorination study. The biofouling experienced at the Salem Generating Station necessitates an overall reevaluation of chlorination procedures to insure that surface water quality is preserved.

The staff should have this information prior to drafting the FES.

Section 5.3.3:

The staff's conclusions that considerations of alternative locations for any structures identified as being in the floodplains is neither required nor practicable is un-explained, and not evident from the DES.

Section 5.6.1:

The assumption that the osprey will not be adversely

+ affected by the Hope Creek operation is not sufficiently b

3 4 w -

Mr. A. Schwencer, Chief August 21, 1984 documented. Assessing the impact resulting from the operation of Salem alone does not provide an evaluation of the cumulative impact ~on the osprey.

Section 5.9.3.2:

The intervenor is concerned about any evaluation of

, the operation of the radioactive waste treatment systems until the detailed evaluation of the system is presented in the SER. The capability of the system to meet the requirements of Appendix I will not be evaluated until the October 1984 report and a proper assessment of the

_ radiological impact of the plant on humans must await that information.

Pages 5-46:

The basis for the staff's reliance on a generic study involving PWRs for the probabilities relating to a Hope - ,

Creek BWR is not adequately explained. The assumption that "it is unlikely that . . . [the] core-melt liquid path-way release for the BWRs would exceed that conservatively estimated for the LPGS" is not- documented, and the reasons supporting this assumption are not discussed.

Section 5.14.2:

The intervenor questions the appropriateness of the NRC's reliance on the State 'of New Jersey for the protection of water quality and aquatic biota. Intervenor submits that this ecological monitoring should still be part of NRC oversight of the operation of the Hope Creek Generating Station and should not be delegated to a state agency.

Section 5.14.3:

The FES cannot be prepared until the applicant has submitted the additional information required by the staff (5-62).

Section 6.4.2:

-In calculating the benefits of the Hope Creek Station, the DES assumes that the unit will operate at an annual average capacity factor of 55%. However, experience with the

applicant's operation of the Salem reactors demonstrates that the projected annual average capacity is substantially greater than the actual average annual operating capacity of these two plants. Realistic projections based on part experience of the applicant with similarly situated facilities should be utilized rather than assumptions that are incon-sistent with this experience.

Mr. A. Schwencer, Chief August 21, 1984 Appendix F:

The DES is deficient in that neither the staff nor the licensee conducted a probabilistic risk assessment (PRA) for Hope Creek. We submit that such a PRA must be conducted and that the extrapc'_ation of data is inappro-priate in these circumstances.

Thank you for your consideration of the above comments. If you have any questions, please contact either of the undersigned.

Sincerely yours, JOSEPH H. RODRIGUEZ Public Advocate, State of New Jersey By: z( -

RICHARD E. SHAPIRG i Director Division of Public Interest Advocacy W

SUSAN REMIS lS Assistant Deputy Public Advocate

~ m i 2.:

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board ,

PUBLIC SERVICE ELECTRIC  :

- AND GAS COMPANY (HOPE  : Docket No. 503540L GENERATING STATION)  :

CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenor's Comments to the Draft Environmental Statement Related to the-Operation of the Hope Creek Generating Station" dated August 21, 1984, in the abovecaptioned matter, have been served upon the following by deposit in the United States mail on this 21st day of August,1984:

Mr. : A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, D.C. 20555 Honorable Marshall E. Miller, Chairman -

Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Honorable Peter A. Morris Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Honorable David R. Schink Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Panel

. U. S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555

.i . . . ,

a....

Docketing and Service Section Office of the Secretary

.U.- S. Nuclear Regulatory Commission Washington, DC 20555.

Lee Scott Dewey, Esqui e ~

. Office of the Executive Legal Director

- U. S. Nuclear Regulatory Commission Washington, DC 20555 -

Richard Fryling, Jr. , Esquire Associate General Counsel Public Service Electric & Gas Company P. O. - Box 570 (TSE)

Newark, NJ 07101 Troy B. Conner, Jr. , Esquire Conner & Wetterhahn 1747 Pennsylvania Avenue, N.W.

Washington, DC 20006 Carol Delaney, Esquire Deputy ~ Attorney General

' Department of Justice State Office Building - 8th Floor-820 North French Street Wilmington, Delaware 19801

/h '

Oh I ik Richard T. Shapiro, Diiector-Division of Public Interest Advocacy A cu C s ) t Susan C. Remis Assistant Deputy Public Advocate Dated: August 21, 1984 L-

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