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Text

Comment (2) of Ruth W. Foster, on PSEG Salem Hope Creek Generating Station, Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site, Final Report
	ML16055A112
Person / Time
Site:	Salem, Hope Creek, 05200043
Issue date:	01/20/2016
From:	Foster R; State of NJ, Dept of Environmental Protection
To:	Cindy Bladey; Rules, Announcements, and Directives Branch
References
	80FR72751 00002, NRC-2014-0149, NUREG-2168
	Download: ML16055A112 (32)
	v • d • e

State of 'f jre DEPARTMENT OF ENVIRONMENTAL PROTECTION OFFICE OF PERMIT COORDhINATION AND ENVIRONMENTAL REVIEW CHRIS CHRISTIE BOB MARTIN Governor P.O. Box 420 Mail Code 401-07J Trenton, New Jersey 08625-0420 Commissioner Telephone Number (609) 292-3600 KIM GUADAGNO FAX NUMBER (609) 633-2102 Lt. Governor January 20, 2016 ey, Chief Ms. Cindy Blad Rules, Announc ements, and Directives Branch //.j:**

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Office of Administration 6*Ž-/g/i;/c;7C~:5@7 Mailstop 3WFN-06-A44MP t United States Nuclear Regulatory Commission .7.r (-J.

Washington, DC 20555-0001 O2:,

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=2 RE: PSEG Salem Hope Creek Generating Station Lower Alloways Creek Township, Salem County

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Docket NRC-2014-0149; NUIREG-2168 L.LJ Unites States Nuclear Regulatory Commission Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site, Final Report The New Jersey Department of Environmental Protection's Office of Permit Coordination and Environmental Review (PCER) distributed, for review and comment, the Final Environmental Impact Statement (FEIS) as prepared by the U.S. Nuclear Regulatory Commission (NRC) and, as a cooperating agency, the U.S. Army Corp of Engineers (USACE). On December 5, 2014 (enclosed), the Department provided comment on the Draft EIS for this proposed early site permit for an additional nuclear unit at the PSEG facility in Lower Alloway's Creek Township, Salem County. Based on this most recent submittal, we offer the following comments; Air Bureau of Evaluation and Planning

1. Appendix J - PSEG Site Characteristics and Plant Parameter Envelope Values:

The Final BIS includes Table J Assumptions by Technical Area Not Covered in Table J- 1. Table J-2 states, "Potential borrow areas for borrow pits have been identified at several locations in New Jersey, Pennsylvania, and Maryland, however, the extent of the land required has not been determined."

Comment - The General Conformity Applicability Analysis (Applicability Analysis) must include the air emissions from the trucks transiting to and from the borrow pits (within a non-attainment or maintenance area). Please include the air emissions from the

>4- II truck transits to and from the borrow pits (within a non-attainment or maintenance area)

U, *.Q' [I in the Applicability Analysis.

New Jersey is an Equal OpportunityEmployer 1 Printedon Recycled Paper andRecyclable

.7

2. 3.3.1 Site Preparation - The Final EIS states, "Most of the causeway structure would be made of prefabricated elevated sections set in place from an elevated crane to minimmize impacts along the causeway route."

Comment - The General Conformity Applicability Analysis (Applicability Analysis) must include the air emissions from the elevated crane that will be used to set the prefabricated sections for the causeway inplace. Please include the air emissions from the elevated crane in the Applicability Analysis.

Thank you for giving the Department the opportunity to comment on this project. If you have any additional questions, please do not hesitate to call me at (609 292-3600.

Sincerely, Office of Permit Coordination and Environmental Review Enclosure cc:

John Gray, NJDEP, Deputy Chief of Staff-Ryan Anderson, NJDEP-Land Use Regulation.

Karen Tucillo, NJDEP-Bureau of Nuclear Engineering Richard Dalton, NJD)EP-NJGS ..

Marty Mosen, NJDEP-Land Use Regulation - Tidelands Joel Pecchioli, NJDEP-Land Use ODST David Owen, NJDEP-Air Permitting Vincent Maresca, NJDEP-SHPO Angela Skowronek, NJI)EP-Air Planning Kelly Davis, NJDEP-NHRG-F+W Samuel Reynolds - USACE Steve Tambini, DRBC Lingaard Knutsen, USEPA Region 2 Jennifer Dixon-Herrity, Chief, NRC Office of New Reactors Dr. Alan Fetter, NRC Environmental Project Manager 2

'. 'DEPARTMIENr OF ENVIRONI~IENTAL PROTECTION ..

CHIRIS CURISTIE OFFICE OF PERMIT COORDINATION AND Em~lONME.NTAI REVIEW :BOB MARTIN Governor P.O. Box 420 Mail Code 401-073f Trenton, New Jfersey 08625-0420 Commissioner Telephone Number (609) 292-3600 KIM GTUADAGNO FAx N*UMBER (609) 633-2102 Lt. Governor December 05, 2014.

Ms. Cindy Bladey, Chief Rules, Announcements, anld Directives Branch Division of Administrative Services Office of Administration1 Mailstop 3WFN-06-A441VP United State Nuclear Regulatory Com.mdi.ssion Washington, D.C. 20555-000 1 RE: PSEG Salem Hope Creek Generating Station Lower Alloways Creek Township, Salem County Docket NRC-2014-0 149; # 52-043 Comments on Draft Environtmental-Impalct Statement for PSEG E~arly Site Permit Application.Review United States Nuclear Regulatory Commission

Dear Ms. Bladey:

The New Jersey Department of Environmental Protection's (Department) Office of Permit Coordination and Environmental Review (PCER) distributed,, for review and comment, the Draft Environmental Impact Statement prepared by¢ the US Nuclear Regulatory Commission .(NRC) as part of it's review of.an application by PSEG Power LiLC and'PSEG Nuclear LLC (PSEG) for an Early Site Permit for a proposed additional nuclearfnt, *at'.heir: facility in Lowcer Alloways Creek Tow-nship, Salem County. The Department p.reviously, provided: initial .and supjglemental' comment on the Early Site Permit Site Report on September 15, 2010 and December 10, 201.0.

(enclosed). We offer the following comments for your consideration..*

Nuclear Engineerin* -

The Bureau of Nuclear Engineering has reviewed the U.S. Nuclear Regulatory Commission's "Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site" and offers the following comments:

1) Volume 1, Section 2.3.3.2 "Groundwater Quality", Page 2-50, Lines 1 The statemenlt that SGS Unit 2 ". .. has a tritium monitoring system often wells installed due to elevated tritium concentrations in the shallow aquifer resulting from precipitation capture of vented iritiated-water vapor" is inco~rrect. According to PSEG.Nuclear, these wells were installed "to assist in identifying potential leaks from Salem Unit 2" following the discovery of a leak of condensate from an expansion joint on the SGS Unit 2 plant vent. Thle "haighly tritiated" water that escaped from the expansion joint leaked onto the Auxiliary Building roof and was transported to nearby New Jersey is an Equal Opportu.nity Employer 1Printedon Recycle~d Paperand Recyclable

catch basins via the roof drain and stormwater collection system (PSEG Nuclear, LLC, Remedial

Action Progress Report, Second Quarter 2013* J.anuary 28, 2014).

2) Volume 1, Section 2.4.2.3 "ImportantAquatic Species and Habitats", Page 2-109, Lines 6-33 and Section 4.3.3.2 "ImportantAquatic Species and Habitats", Page 4-47, Lines 14-19

-I descriptions of the easterm oyster population and, fishery are inaccurate and incomplete. The

assertion that the eastern oyster was not "...observed in the Delaware River Estuary in the vicinity of the PSEG Site between 2003 and 2010" is contrary to the well documented descriptions of the oyster beds in the iNew Jersey portions of Delaware Bay provided by the Haskin Shellfish Research Laboratory of the Rutgers University New Jersey Agricultural Experiment Station since the 1990's (http://hsrl.rutgers.edu/SAWreports/index.htm). According to those reports, there are extensive oyster beds within the 6-mile vicinity of the PSEG Site. Thenearest oyster bed, the Hope Creek Bed, extends from approximately 0:56 miles to 2.3 miles downstream from Artificial Island and covers 734 acres. Additional oyster beds located downstream from Artificial Island and within the 6-mile vicinity include the Fishing Creek Bed (315 acres), the Liston Range Bed (289 acres), the Round Island Bed (472 acres), the Upper Arnolds Bed (446 acres) and portions of the Arnolds Bed (630 acres). The vast majority of the commercial oyster harvest comes from the Direct Market beds located 11-16 miles downstream from Artificial IslandL It is important to note however, that as part of the .managementof this fishery, the oyster population of these Direct Market beds is supplemented with large numbers of oysters transplanted from the above described upstream beds located within 6-miles of Artificial Island. In 2013 for example, 21,050 bushels of oysters/cultch were transplanted from the beds located within the 6-mile vicinity to the Direct Market beds. Based upon the estimated density of 404 oysters per bushel of oyster/cultch material during 2013, this equates to approximately 8,504,200 oysters. Tranisplants from the Hope Creek Bed, the upper portions of which are located less than 3,000 fe~et downstream from Artificial Island, have been suspended since 2012 to allow for recovery from a 2011 low salinity.

mortality event attributable to flooding associated with Hurricane Irene and Tropical Storm Lee.

During the 20Q9-20 11 .period however, the Haskin Shellfish Research Laboratory reported that-*

16,450 buashels of oysters/cultch, or the equivalent of nearly 10 million oysters, were transplanted to. the downstream Direct Market beds fto~m the Hope Creek Bed alone. .

With regard to the New Jersey commercial harvest of eastern oysters, according to the EIS "... .the last reported commercial fishery in New Jersey reported a harvest of 550,086 lb in 2008". More recent Delaware Bay specific harvest data are available from the above referenced reports by the Haskin Shellfish Research Laboratory. According to the February 2014 report, the total harvest from the New Jersey portions of Delaware Bay in 2013 was 84,276 bushels. This was an increase of 6,136 bushels compared to the 2012 harvest, and the seventh consecutive year in which the

harvest equaled or exceeded the 18s-year mean of 75,409 bushels: ..

The available data on the oyster fishery in the.New Jersey portions of Delaware Bay, as well as similar data for the State of Delaware portions of the bay, need to be evaluated in order, to ensure an accurate assessment of the potential impacts of the construction and operation of the proposed nuclear power facility on the eastern oyster. For example, construction activities that result-in increased sediment load in the river could adversely impact the nearby oyster beds. In addition, oysters are filter feeding bivalves that are known to accumulate, and in some cases 2.

bioconcentrate, radionuclides typically found in ef-fluents from nuclear power plants such as cobalt-58, cobalt-60, zinc-65, anid silver-i110. Effluent specific radionuclides have been found in oysters as far as 7.5 mile~s from the point of discharge of nuclear power plants (McLean, R. I., J.

K. Summer~s, K. A. Rose, and S. L. Domotor, 1987. Silveri110, Cobalt-58, anud Zinc-65 Conct~ntrations in the American Oyster, Crassostreavirginica (CGmelin), Near-The Calvert Cliffs Nuclear Power Plant, Maryland Power Plant Research Program, December 1987). The proximity of some of the Delaware Bay oyster beds to the PSEG Site, and the practice of transplanting large numbers of oysters from beds fiear the site to downstream beds that support a signi~ficant commercial fishery, make oyster colasumption an important potential exp'osure pathway to man..

As such, that pathway should be monitoredas part of aneffective Radiological Environmental Monitoring Program (REMVP) for the proposed facility.

3) Volume 1, Section 2.11 "Radiological Environment ", Page 2-191, Lines 2 As part of the discussion of the groundwater contamination caused~by the spent fuel pool leak at SGS Unit 1, the NRC states that "Nqocontamination is believed to have migrated to the unrestricted area."

The direction of groundwater flow inmthe area of concern however, is towards the nearby Delaware River, and the licensee's groundwater monitoring data indicate that at least some of the contaminated groundwater has migrated into the river and therefore into the unrestricted area. .

Monitoring Well AG-S for ex~ample,.is a shallow monitoring well (24.2 ft. below ground surface) located approximately 360 ft. down gradient from the source of contamination (seismic gap) and-only 40 ft. from the bank of the Delaware Ri.'ver. Tritium. concentrations as high as 33,200 pCiAL have been observed in groundwater samples from this well (Januaary 2005). In addition, although the spent fuel pool leak was discovered in 2002, it was not until June of 2013 that the licensee determined that the contamination had reached the deeper Vincentown Aquifer as well as the.

shallow, water bearing unit. Well AA-V was installed in the .Vincentown Aquifer (85 ft. below-ground surface) in May of 2013 and is located appr~oximately 130 feet from the river bank.

Tritium concentrations in groundwater, samples-from Welt *AA- V haye ranged from 7,000 to 13,000 pCiIL, several times higher than the tritium concentrations observed at the same location ..

in the sballow; water bearing unit (Well AA). The in~stallation of additional moni'toring wells will be required in order to properl~y characterize the: extent of the contamination in the Vincentown Aquifer. However, the available data suggest that at least some of the contaminated groundwater in this deeper formation has discharged or Will discharge into the Delaware River. In fact, the licensee has performed a mass flux estimation ofthe quantity .oftritium reachtn.g the Delaware River. They estimated that 0.011 curies per year could reach the Delaware River from the shallow, water bearing unit, and 0.066 curies per year could reach the river from the deeper groundwater (Mass Flux Estimation Memo, PSEG Nuclear LLC, Salem and Hope Creek Nuclear Generating Stations, Hancocks Bridge, New Jersey, Prepared by ARCAD.IS U. S., Inc., Project No. NP000571.2013, dated October 29, 2013).

4) Volume 2, Section 7.2.2.2 "Impacts on Groundwater Quality", Page 7-16, Lines 31 The existing and potential impacts on groundwater quality are not accurately characterized here.

The NRC states "The existing SGS and HCGS have impacted shallow groundwater quality, but these impacts have been minor and have been limited to the immediate vicinity of the PSEG Site." AS documented in the previous comment however, existing impacts to groundwater quality have not been limited to the shallow groundwater. Ground water contamination attributable to the 3

spent fuel pooi leak at Salem Unit 1 has been detected in the deeper V~incento~wn Aquifer. The-extent of the contamination in~this aquifer has':yet to be determined. ."*'* .

With regard to potential impacts on groundwater quality, i.the NRC states "Potential impacts to .

groundwater quality could come from inadvertent spills that could migrate to the. shallow water zones." This statement .incorrectly assumes that the impact of any spills will be limited to the shallow groundwater at the site. Recent experience at Salem Unit 1, as well as the Oyster Creek Nuclear. Generating Station in Lacey Towncship, New Jersey, has clearly demonstrated that the

probability that tritium contaminated water released into shalloW unconfined aquifers will ultimately reach deeper confined aquifers is much greater than previously predicted. Construction activities typically associated with .nuclearpower plants, such as deep excavations for building foundations and other structures, and the installation of cofferdams to support dewatering" operationus, can significantly alter site hydrological conditions. An unintended consequence of. .-

these activities has been the creation of downward pathways that have allowed contaminants to pass through the confining layers into the deeper aquifers.

5) Volum.e 2, Section 7.3.2.5 "Climate Change", Page 7-29, Lines 1 This section of the EIS references a 2011. report by the Partnership for the Delaware Estuary that examines- the potential impacts of climate change on marine bivalve shellfish populations in the Delaware" Estuary (PDE 201!1-TN2 190). According to that report, the combined effects of climate change,.

rising sea level, channel deepening, and increasing demands for freshwater from the Delaware River and nearby aqieawl eut nasgnificant increase in the salinity of Delaware Bay. As a result, .it is expected that the oyster population will expand further up the estuary, towards the PSEG Site. In that scenario, the populations located in down bay areas that currently support most of the commercial fishery (Direct Market Beds) would be depleted byr the diseases that are more prevalent in high salinity conditions. The *oyster populiations in the upper bay, locaited just downstream from the PSEG Site, and that currently serve primarily as a source of transplan~ts to.

replenish the down bay* Direct Market beds, would then become the center of the commnercial oyster harvest. The location of a large c.ommercial oyster fishery just downstream from three existing nuclear power plants, and potentially one or two additional units, would result in a-significant increase in the frequency of occurrence and concentration of effluent specific radionudlides in oysters that are sold for human consumption. Therefore, that exposure pathway should be monitored as part of an effective Radiological Environmental Monitoring Program (REMP) for the proposed facility.

If yo~u have any additional questions, please contact Karen Tuccillo at (609) 984-7443.

NJ Geological and Water Survey The sections of the draft EIS pertaining to geology and ground water have been reviewed and the-comments below need to be addressed. The comments are by section and page.*

Section 2.3.1.2 Groundwater Hydrology

p. 2-38, lines 17 to 19. The EIS cites Martin.(1998) for the heads in the middle aquifer bein.g about 20 ft.. above sea level before pumping.

Comment: It shouldbe noted that two .wells were drilled at Artificial Island by the US Army Corps of Engineers in 1930-1932. The Historic Well Records at the NJDEP indicate both wells 4.4

A.

were~completed in what is now termed the middle P-RM aquifer. Water levels given for the well at the south end of Artificial Island range from sea level to + 4 feet, not the 20 feet above sea level as the computer simulation indicated. These actual measurements agree closely with the - 4 feet measured on 4/1/1969 [NWSI-(USGS 392744075315301 33030- .ArtIsland)] in the middle PRM at Artificial Island. Before the construction began at Artificial Island there, were no large regional pumping areas near enough to reduce the heads in the aquifer at Artificial Island. All the head-reductions in the .area were the result of the pumping at the plant site, nowhere else...

p. 2-39, lines 20-21. Indicates Figure 2-18 shows the stratigraphy of the PSEG site based on geotectinical borings."

Comment: When Figure 2-18 is examined there are problems with the unit identiflcation~s, especially in the upper part of the borings. There is no Kirk-wood, either upper or lower, at Artificial Island (see Owens and others, 1998). The Kirk-wood was eroded away during the Pleistocene and the sand (lower Kirkwood) and the clay (upper Kirk-wood) above the sand and below the artificial fill and alluvium are both late Pleistocene deposits (see Owens and Minard, 1979). The figure also shows the Itornerstown and Navesink Formations as too shallow at the site. Since the EIS references this figure as being from the PSEG (TN3452), that report was checked, but no boring information could be found there. The SSAR, [PSEG (TN3453)], was found to :have the boring logs and other information. When the, logs were reviewed it is evident that the geologists logging the borings misidentified the Hornerstown and Navesink in every¢ boring. They describe the Hornerstown as a fine to silty sand having a trace to a few glauconite or a few to little glauconite. The Hornerstown Formation contains the highest glauconite content found in any geologic formation in New Jers.ey. The glauconite ranges between 40 and 90% of the sand fraction, not a trace or few grains as is described in the boring logs. Also on page 2-170

ofthis EIS,-Figure 2-30, the description of Htornerstown indicates it is highly glauconitic, not a*

trace of glancouite as the boring logs indicate. .The first appearance of any significant amount of glanucnite in the logs is what they are identifyring as the Navesink Formation, but it is.in fact, the H-omerstown Formation. Owens and others (1998), -at a scale of 1:100,000, shows Kirkdwood

eroded away with the Vinucentown Formation being the youngest pre- Pleistocene formation at Artificial Island. Stanford (2011), at a scale of 1:24,000 also indicates that~the Kirkwood Formation is not present at Artificial Island since it.was eroded away during the flhinoian lowstand about 150,000 years ago. Descriptions of theilomerstown Formation can be 'found in" Owens and others (1998), Miller and others (2005), andRosenau and others (1969).

It is important to recognize that the Kirkwood Formation is not present at Artificial Island since it means that the "confinin g" clays above the Vincentown Formation are not regional in extent. The clays on site are limited in'aerial extent and do not form a single layer extending inland for miles protecting aquifers below the water table as they wo~uld if they were actually the clays of the Kirkwood Formation. The clay and lower sand are Pleistocene deposits and that is thereason why they are so variable in thickness and extent at the site.

p. 2-39, lines 37-38.

Comment: There is no K~irkwood Formation at Artificial Island. The clay separating the alluvi'um from the Vinmcentown Formation is Pleistocene, not Miocene as is .the Kirkwood Formation..

p. 2-41, Table 2-7.

Comment: There is no Kirkwood F~ormation at Artificial IslandAlso as mentioned above the geologists that described the borings for SSAR and ER misidentified the Homerstown Formation.

In the ER, p. 2.6-6, they describe the Hornerstown Formationi as having a trace to some :...

glanconite at the site and they indi~cate the glanconite increases with depth. They further indicate that the glauconite can make up greater than 30% of the sand fraction near the base. of the 5

formation. It should be noted that the Vincentown-Homnerstown contact is .generally placed where there is a significant increase in glauconite from about 20 to 40%. The IHornerstown Formation is the e~asiest unit to recognize in the New Jersey because of its high glauconite content. The depths*

to top of Hornerstown would be deeper than is indicated&.Note, the boring information Was found in Appendix 2AA (Boring Logs), of the. SSAR. This Appendix has the geologist desdriptions and.

formation identifications and in addition, some of the figures in the SSAR show geophysical logs

for some of those borings. Benson (2006), Plate 1, Section B-B' shows the Hornerstown-Navesink Contact in the' 1800-foot boring at Artificial Island& This contact is placed at the top of a-major gamma spike atabout 175 feet below sea level. This is the same gamma splice that is found in Boring NB-i (about -150') and Boring EB-3 (about -168') The geologic logs for these two borings show the Hormerstown-Navesink contact over 40 feet higher because the geologists .

logging the borings at the plant were misidentifying the Homerstown Formation as indicated-above..

p. 2-41, line 18.- .*

Comment: There is. no.Kirkwood Formation at the site. The clay over the Vincentown Formation is Pleistocene.

P. 2-42, lines 11-18. The ETS discusses the water levels in the.middle and lower PPM aquifers and indicate the water levels in these two aquifers appear to be affected by New Castle County water withdrawals.

Comment: The problem with that conclusion' is that the pumping at Artificial ISland started before significant pumping started in southern New Castle County and'caused a significant lowering of the potentiometri'c surface to below -50 feet over two miles from the plant pumping wells (see Walker, 1983., Plate 1, wells'33-363 and 33-364).' Lines 16-18, refefr-ing to Plate 8, dePaul and other~s, (2009), states "The head measured in the USGS observation well 33-93.4 (site observation Well J) at the south end of Arti~ficial Tslanid was -70 ft, a drawdown of about 50 ft below the. apparent regional groundwater head." On Plate 8,well 33-934, with a water level of -

70 feet, and nearby well 33-918, -with a water level of -44 feet, are shown as being in the middle*

PPM. This difference in the potentiometric. surface seems to account for the statement in lines 16-'

18. The problem with that conclusion is that well #33-9 18 (Plate 8) with a water level of -44 feet is in the lower PPM, not the middle PPM as shown. The USGS has this well listed in the wrong .

aquifer in their INWSI"database. USGS well 33-9 18 is the plant production well PW 6 .and USGS well 33,458 (Plate 9) is observation well 6 (OW .6). Plate'9 (lower PRM') shows well 33-458 with a water level of -45 feet :very similar to well :33-918 with -44 feet. Appendix 9 of dePaul and others (2009) indicattes well 33,458 is screened.at .1112-1132 feet in the lower PPM and Appendix. 8 has .well 33-918. screened atlr1154,1.35 ft. in~middie PPM. These two wells are less than 50 feet apart, at the essentially the sam.e depth and yet the USGS has these two wells'located in different aqtzifers. Note on p. 2-45, lines 8-11, the EIS indicates the SGS derives its grounadwater from two pumping wells in the middle and lower PPM at depths. 'of 840 and. 1135 feet. The 1135 foot well is PW 6, USGS well 33-918.

If wei1 33-918 on Plate 8 was plotted where it belongs on Plate. 9', then the data on Plate 8 would'*

indicate the -70 feet in the middle PRM aquifer is a more regional drawdown caused by the plant, not a local deep cone of drawdown that changes from -70 to -44 feet in a short distance. All 'the USGS synoptic water level reports for the New Jersey Coastal Plain show a significant lowering*

of the water levels in the middle PPM caused by the p~umping at Artificial Island. The data indicates the greatest lowering of the water: level in the aquifer occurred in about 1978, which was likely a result of pumping at maximum diversion, during construction.

6

'If Section 2.3.3.2 Groundwater Quality. -" .

p..2-49, lines 24-41. The EIS discusses the-tritium leak and groundwater remnediation at salem 1 and lines .33-35 indicates the leak at the spent fuel has been1 remediated.

Comment: The actual leak has not been sealed. PSEG is just preventing the spent fuel. pool water from reaching the environment by better maintenance of the tell tails and collecting the water that builds up in the .seismic gaP. It should be noted that if approval is given and construction began on a new plant, any dewatering would have to closely monitored to prevent any remaining tritium or any other contamiinants in either the water table or Vincentown aquifers from being pulled into uncontaminated areas of both."

p. 2-50, lines 1-5. The report indicates here-that tritium on the north side of Salem 2 is not due to a major release into the subsurface but due to tritium capture by precipitation of vented tritiated water vapor.

Comment: The tr-itium capture is a theory, but is not a proven fact, as the cause of the tritium on.

the ndrth side of U~nit 2. Tritium occurs both in the shallow water table aquifer and in the deeper Vincentown aquifer in wells CB and K significantly above background.

p. 2-50, lines 15-19. The BIS indicates that the chlorides have been stable over time With notable deviations.--

Comment: Without plotting the amounts of water pumped from each well on the Figure 2-20 it is difficult to tell .what is going on, but there seems to be a correlation that indicates when the chloride levels drop in wells PW 5 and PW* 6 the chloride lev¢els increase in HIC 1 and TIC 2 withi well HGC 1 jumping to over 200 mag/L, an increase of an order of magnitudte. With PW 6 the-chlorides are dominantly over 200 mgiL with some readings over 250mng/L the drinking water" standard. It is likely that any increased pumpage from this well in lower PRM Wil cause the chloride to exceed the drnkilng water standard on a ¢ontinuous basis. Also. HG 1 shows indications of possibly exceeding the drinking water Standard if pumped at a greater rate than it currently being used. These two wells-~are showing signs be~ing..unsuitab~e for drinking~water.

usage .withPSEG currently not pumping the wells at the appro~ved maximum diversion rate.

Section 2.8 Geology : .,* *:* . :"* .:

p. 2-169, lines 31-33. The EIS indicates,-te Coastal Plaint sediments form a Wedge that ranges from a feather edge at the Fall Line to 19,685 feet at the. coast near Cape May. .

Comment: Basement (crystalline bedrodck)-was penetrated-in the AnchorDickinson gas well about 2.5 miles from the*coast at Cape May-Poinlt at a depth of 6,357 feet, nowhere near the.-

19,000+ feet cited on-line 32. * * ..

p. 2-169, lines 35-37. The EIS indicates that Figure 2-30 is the stratigraphic section for the PSEG.

site (see comment below) ... "."

p. 2-170, Figure 2-30 Stratigraphic Section of the PSEG Site.

Comment: It is~stated that this figure depicts the stratigraphic section for the site. The upper part of the section shown consists. of Quaternary Marsh deposits, Cape May Formation, Kirkw.ood*

Formation, Shark River Formation, Manasquan Formation, Vincentown Formation, and '

Hornerstown Fonmation for the Cenozoic. Of the those units listed as being at the site, neither the Kirkwood, Shark Rivet or Manasquan Formations are present under Artificial Island. The figure.

also shows the Hornerstown in both Cenozoit and Mesozoic Eras. The base of the Horuerstown, is Paleocene, not Cretaceous so it does not cross into the MesozoicEra. , ...

7

p. 2-171, lines 27-29. The report indicates that.jNeogene strata (upper* Tertiary) encounteredat the PSEG site during the geotechnical investigation is composed of the Kirkwood Formation and it is divided into upper and lower units. ..

Comment: As indicated above (comments for p. 2-39), there is no Kirkwood at the. site, even

though PSEG and their consultants *tl call the shallow clays at the site the Kirkwood Formation.

The clays below the alluvium and above the Vincentown are Pleistodene, not Miocene, an age difference of about 19 million years. They were exposed, during the construction of the Salem reactors and examined and photographed by geologists from the U.S. Geological Survey with a report being published in 1979. Both PSEG and NRC should accept modem geologic mapping and not use mapping done pre-1910. All modem geologic mapping of the area published since the Geologic Map of New Jersey, 1910-1912, indicates theKirk-wood is not present under Artificial Island. Owens and others (1998) shows the lower contact of the Kirk-wood. orientated almost north-south to the east of the plant indicating the Kirkwood has been eroded out under the plant site.

The fact that the.Kirkwood Formation is not present at the site and that the Shallow Pleistocene clays between the alluvium and the Vincentown are not continuous running from the river inland uander Salem County to the east and northeast of the plant should be accepted by NRC.

Section 3.0 Construction and Preconstruction Activities

p. 3-20 Table 3-2. .

Comment: The table indicates "Excavate to Kirk-wood Formation (both units)." This should be revised to "Excavate to the Pleistocene clay and sand unit" since there is no Kirkwood Formation present on Artificial Island. The material they call Kirkwood is Pleistocene in age and is mapped as the Cape May Formation (stanford, 291 1). Cross section A-A' depicts the geology from river across the plant site to the eastemn edge of quadrangle. Also see Owens and Minard (1979).

p. 3-21, lines 41-42. The report indicates the preconstruction excavation would go down to about 50 feet to the Kirkwood..- -

Comment: There is no Kirkwood present. on Artificial Island. It should be down to the" "Pleistocene clay unit"!. .

Section 4.2.1.2 Groundwater......

p. 4-17, line 28-29. The 'EIS indicates the excavation Would be down through the fill, alluvium, and Kirkwood into the Vincentown . ..

Comment: Again note there is no. Kirkwood Formation present at Artificial Island. The iKirkwood Formation was eroded away in this area during thne late Tertiary and early Pleistocene and the Cape May Formation was deposited in the incised river valley between 450,000 and.

200,000 years ago (Stanford, 2011). : -..

Section 4.2.2.2 Groundwater Impacts ._

p. 4-19, lines 3-4."

Comment: Again, the Kirkwood Formation is not present at the site.

p. 4-20, lines 24-38 and 4-21, lines .1-12. The Eis indicates that the preconstruction and construction pumping from the PRM would be minor and small. They cite Section 5.2.2.2 Comment: There are si.gnificant issues with Section 5.2.2.2 therefore see comments below on that section.

8

p. 4-23 and 2-24, Section 4.2.3.2 Groundwater Quality Impacts Comment: This section discusses various potential s*pills such as gasoline, etc.. but fails to mention or discuss the ongoinig groundwater cleanup of the tritium at the Salem Generating Station.. Since the contamination is in both the water table and the Vincentown aquifers, any.

dewatering in either of these .water bearing zones will affect any remaining plumes of contamination. Since the Vincentown Formation is semi-confined at Artificial Island the" dewatering affects will extend out significantly further than in the water table aquifer.

p. 4-24; lines 29-30. The ETS indicates the Vincentown is too saline for potable water in the vicinity of the PSEG site. The PSEG Nuclear, LLC, Remedial Action Progress Report, Third Quarter, 2013 (dated March 12, 2014) shows several domestic wells within the 5 mile buffer of the plant utilizing the Vincentown Formation.

p. 4-24, lines 1-20}. The report indicates that the preconstruction and construction impacts on ground water quality would be~small in the PRM and cite Section 5.2.3.2.

Comment: See comment above for p. 2-50, lines 15-19 and the comments on Section 5.2.3.2.

Section 5.2.2.2 Groundwater Use Impacts.

p. 5-9, lines 24-26. The EIS states thiat according to dePaul and others (2009), the existing heads in the middle PRM are about -20 feet at 3 to 5 miles northeast of the site.

Comment: It is not clear how they come to that conclusion when the nearest middle PRM wells

-- shown on Plate 8 of dePaul and others are-about 7 and 9 miles northeast anld have measured water

... levels of -32 and -31 feet respectively. The nearest wells to the southwest, west and northwest all

are 6 or slightly more than 6 miles from the site and .theyhave water levels of -32 to -34 feet.

... With the potentlometric surface at -32 feet 7' miles from the PSEG site where the potentiometric

surface is at -70 feet it is difficult to understand how NRC concluded that the heads were about -

20 feet at 3 to 5 miles from the site without any other wells between the two measured wells.

Well 33-918, on Plate 8, at the PSEG site has a measurement of-44 feet but as indicated in the.

comnments abo*ce for p. 2-42; lines 11-18, Well 33-=918 is not in the middle PRM, but is in the-"

lower PRIM aquifer. It is less than 50 feet from well 33-458 on-Plate 9 (Lower Potomac-Raritan-Magothy Aquifer) and is screened at almost the exact same depth, a 1 foot difference in depth.

Even if this well was in the middle PRM as shown, there is no indication of the -20 foot number which the EIS cites from dePaul and others. If the 14-17 feet of drawdown on line 26 is added to*

the more likely -40to -45 feet at 3 to 5 miles based the actual information on Plate 8 then the-impact is somewhat greater than SMALL. -

Section 5.2.3.2 Groundwater Quality Impacts - "'

p. 5-15, lines 23-42 and p. 5-16, lines 1-17. The EIS discusses the impact of the additional groundwater pumping for the new plant on the potential of saltwater intrusion into the middle PRM..On line 30-31 they indicate that Dame s and Moore in 1987. measured chlorides of 15mg/IL

([IC 1 and HC 2) and 45mg/L (PW 5).in 1987 and in lines 31-33 they indicate from 2003 to 2013 the median chlorides were 8 mag/1 ([HC 1), 5 mg/L (HC2) and 22 mg/L. (PW 5). 'The report concludes that the higher chlorides may have been due to the higher plant pumping rate of 493 gpm (1987) to 369 gpm (2003-2013) or due to agreater regional pumping in the early 1980's that was decreased by the initiation of Critical Area 2.

Comment: The problem with the analysis and its conclusions in this section is that by comparing the, median of the chlorides in the wells, biased the data to the very low end, since the data not evaluated is~over an order of magnitude greater than the median chloride concentration. The issue 9

concerning chlorides was also discussed above in comment for p. 2-50, lines 15-1. Without .

having the amount of water pumped from each of the wells compared to the chlorides it is not possible to know why wells HC 1 and PW 5 increased in chloride conicentration by over an order.

of magnitude a number of times during the 10 year period as shown on Figure 2-20. Until it is known why these two middle PRM wells Occasionally increased in chlorides so dramatically up.

to and over,200 mg/T. from the 8 mg/L (TIC 1) and 22 mg/L (-PW 5), the NRC is only speculating.

as. to what would happen if the pumpage at the plant increases. Is the .front of chlorides over the drinking water standards very close to these wells, are the chlorides up coning, or do the wells have leaky casings? Until the source of the high chloride readings in wells TIC 1 and PW 5 is known, it is not possible to realistically determine the impact of the additional pumnpage from a new plant at Artificial Island.

p. 5-16, lines 12-17. The EIS cites Pope and Gordon (1999) to indicate salinty changes in the aquifers is more responsive to historic sea level changes than to 20t' century pump age and concludes that the operational impacts of the increased pumpage at the plant on the resource would be SMALL..

Comment: When Figures if, 2f and 3f of Pope and Gordon, 1999 are examined it is impossible to locate the freshwater-saltwater interface by the data shown on each figure, let alone to know where it was in pre-pumping times. The freshwater-saltwater interface is ,defined on page 1 of Pope and Gordon ". .. as the hypothetical line seaward of which the chloride concentration is equal.

to or greater thanl0,000 milligrams per liter." Furthermore, it is not the 10,000 mg/L chloride line that has the impact, it is .the 250 mg/L chloride drinkin g water standard that has the impact on the use of the-resource, so .it does not matter how fast or slow the 10,000 line moves. But~it does matter how fast the 250 mg/L line moves and it must be very close to the plant as evidenced by the anomalous 200 +/-/- mg/L chlorid~e readings in wells HIC 1 and PW 5 shown on Figure 2-20 of thisEIS. :

References cited and examined:

Benson, Richard N., 2006, Internal stratigraphic correlation of the subsurface Potomac Formation, New Castle County, Delaware, and adjacent areas in Maryland and New Jersey: Delaware Geologi'cal Survey, Report of Investigation No. 71, 5p...

Cauller, Stephen J.,. Carleton, Glen B., .and Storclk, Melissa 1., 1999, Hydrogeology of, Water Withdrawal-from, and Water Levels and Chloride Concentrations in the Maj or Coastal Plain Aquifers of Gloucester and Salem Counties, New Jersey: U.S. Geological Survey, Water-Resources Investigations Report 98-4136, l23p.

dePaul, V. T., Rosman, R., and Lacombe, P. J., 2009, Water-Le*vel Conditions in Selected Confined Aquifers of the New Jersey and Delaware Coastal Plain, 2003: U.S. Geological Survey, Scientific Investigation Report 2008-5145, l35p.

Ecke!, James A. and Walker, Richard L., 1986, Water Levels in Major Artesian Aquifers of the New Jersey Coastal Plain, 1983: U.S. Geological Survey, Water-Resources Investigations Report 86-4028, 62p.

Lacombe, Pierre J. and Rosman, Robert, 199.7, water levels in, Extent of Freshwater. in, and Water Withdrawal from Eight Major Aquifers, New Jersey Coastal Plain, 1993: U.S. Geolo~gical Survey, Water-Resources Investigations Report 96-4206, 8 plates.

Martin, Mary, 1998, Ground-Water flow in the New Jersey Coastal Plato.: U.S. Geological Survey, Professional Paper 1404-H, p. H11-H1146.

10

Miller, DrillingK:.G., Sugarman,,P. 1., Browning, J. V., et al.;.2005, Miliville Site, Proceedings of the Ocean Program,. Initial -Reports-. -i*Volumae -174AX " supplement:.

http://2eolo.cv.rutaers.edu/imanes/stories/core repository/i174AXS.5.MV.pdf Owens, James p., and MVin ard, James P., 197.9, Upper Cenozoic Sediments of the Lower DelaWare Valley and Nor-therm De~lmarva Peninsula, New Jersey, Pennsylvania, Delaware, and Maryland: U.S. Geological Survey, Professional Paper' 1067-D, p. Dl1-D47."

Owens, James P., Sugarman, Peter I., Sobi, Norman F., Parker, Ronald A., Houghton, Hugh F., Volkert, Richard A., Drake, Avery A., Jr., and Omdorff, Randall C., "1998, Bedrock Geologic Map of Central and Southern New Jersey: U.S. Geological Survey, Miscellaneous Investigation Series Map,-2540-B, scale 1:100,000.

Pope, Daryll A., and Gordon, Allison D., 1999, Simulation of ground-water flow and movement of the freshwater-saltwater interface in the New Jersey Coastal Plain: U.S. Geological Survey Water-Resourc~es Investigations Report 98-4216, 159p.

Rosenanu, J. C., Lang, S. M., Hilton, G. S., Rooney, J. 0., 1969, Geology and Ground-Water Resources of Salem County, New Jersey: N. J. Department of Conservation and Economic Development, Special Report 33, 142p.

Stanford, Scott D., 2011, Geology~of the Canton and Taylors-Bridge Quadrangles, Salem an4l Cumberland Counties, New Jersey: New Jersey Geological Survey, Open-File Map Series OFM 92,"

Sutgarman, Peter I. and Monteverde, Donald H.,. 2008,: Correlation of deep aquifers using coreholes arid:'

geophysical logs in parts of Cumberland, Salem, Gloucester, arid Camden Counties, New. Jersey: New.

Jersey Geological Survey; Geologic.Map Series GMS 08-1. .

Walker, R. L., 1983, Evaluation of Water L~evels. in Major Aquifers of the New Jersey Coastal Plain, 1978:

U.S. Geological Survey, Water-Resources Investigations Report 82-4077, 56p.

If you h~ave any additional questions, please contact.Ri.chard Dalton at (609) 292-2576.

Natural and Historic Resources -. ..

The Department's Division of Fish arnd Wildlife .(DFW)has reviewed the Draft Resource Report.

and has the following comments.

Bureau of Marine Fisheries:

The BMIF would recommend "*NO ACTIQIN" on this Early Site Permitfor the following reas0ns:"

Even though the syrstein proposed is a closed-cycle cooling system with a fish screening.

system designed to "increase survival:"of impinged fishes, impacts on aquatic organisms in the Delaware River will occur through the intake system. The EIS does not attempt to-quantify in any way the amount of fish that will be impinged and potentially survive but loosely categorizes the loss as minimal.. More information is required on what .the actual losses Will be and what percentage of fishes will survive the new and improved fish screening system.*

The EIS identifies that impacts will occ~ur from the facilities discharge. Possible outcomes include thermal, chemical and physical effects on the substrate and hydrological changes. The EIS goes on further to say that these effects were found to be 11

minimal. Detailed information is required on how these effects were deemed to be m in ma . ... /:.:""' . .

Two Federally-listed endangered fish species occur near the PSEG Site including the Short-nose sturgeon and the Atlantic sturgeon. The National Marine Fisheries Service considers the estuarine portion of the Delaware River Estuary and tidal waters near the PSEG Site to be essential fish habitat for 15 species including river herring (alewife and blueback) and American shad. Stocks of these fishes have been on the decline.

If this project moves forward, BMF would suggest they set aside mitigation funding for the DEP that can be utilized for anadromous fisheries research in the area and for the remaining fish species that utilize the project site as essential fish habitat.

Sheilflsheries:,

Shellfisheries maj or concern is that the BIS states that there are no oysters in the sampling areas

(*5age 167). If they are using river~sampling zone 7, the one closest to the plant, there is a large oyster population in the south end of that zone. There is also large population just south of that .

zone.

Endangered & Non-same Species Program:

ENSP has attached a few pages from .the EIS that summarizes the "unavoidable impacts" but those numbers are different from another section that summarizes this way:.

430 acres on PSEG site & vicinity, of which 225 will be permanently disturbed (lost) and 205 temporarily disturbed. Loss of PSEG's CDF, which may require ACE to build another CDF in the region. .

Causeway: 69 acres disturbed of which 46 would be permanent and 23 ac temporary. The road.

crosses Alloways Creek wetlands, Abbott's Meadow WMA and Mad Horse Creek WMA..

ENSiP concerns include-o Loss of marsh habitat for marsh species (N. harrier, black rail, sedge wren, short-eared owl, bald. eagle, shorebirds, etc.)

Disturbance, mortality, and other secondaty effects of a new roadway across marsh (all marsh species) :..

Possible degradation of the marsh due to changes in hydrology, spread, of invasive plants, etc.

Possibility of increased impingem~ents of marine fish and tuitles due to increased water intake.

At this latitude of the Bay, the most prominent species of concern are bald eagles and the high-marsh dependent birds '(harrier and black rail). The wetland mitigation, should address these species and include creation and stabilization of tidal marsh and high marsh.

ENSP would want to have sufficient mitigation for loss of marshes, both permanent and temporary, and especia~lly to target the most at-risk species -- the ones that require high marsh and which have been hurt by earlier PSE&G projects. ENSP would even suggest they need to se&

aside mitigation funding that the DEP can use to .make improvements on state and conservation lands to benefit the high marsh sp*ecies.

12

NJDFW ENSP Will need to work with other sections of the DEP as to mitigation measures for lost wetlands, secondary impacts, and loss of state lands.

If you have any additional questions, please con~tact Kelly Davis at (908) 236-211 8..

Cultural and Historic Resources In accordance with 36 CFR Part 800: Protection of -HistoricProperties* as published with amendments in the Federal Register on 6 July 2004 (69 FR 40544-40555), we offer the following comments: .

Summary:. This new SiHPO Opinion finds the John Maddox Denta House and the Sara Mason House are eligible for inclusion on the National Register of Historic Places under Criterion C for 18th century pattern-brick architecture. While the process to identify all historic pr~operties and affects assessment has not yet been completed, construction of the new, larger cooling towers will adversely affect the viewsh=ed of the Abel and Mary Nicholson House National Historic Landmark...

800.4 Identifying Historic Properties Thank you for identifying the area of potential effects (APE) for the cooperating agencies; specifically, the. Nuclear Regulatory Commission (NRC) responsibilities-for Artificial Island, (physical and visual impacts) and the U.S. Army Corps of Engineers .(USACE) responsible for dredging and the Money Island Access Road APE.,

The HFPO concurs with the NRC's Environmental Impact Statement for an Early Site Permit.

(ESP) at the PSEG Site (EIS) that the Phase II archaeological survey for the barge facility and water intake area has been completed with a finding of no historic properties affected.

The HIPO agrees Phase I archaeological survey for, Money Island access road identified archaeological sites 28-Sa-179, 28-Sa-180, 28-Sa-182, .and.28-Sa-186. Phase. II archaeological survey will be completed during the Combined Construction and Operating License Application (COLA) as needed depending on the final APE. The vis'ial impact of the proppsed Money Island.

access road is on-going. ......

The K-PO looks forward to reviewing the NRC's assessment and analysis by a geomorphologist that the soil boring program for Artificial Island determined no presence exists for prehistoric soils below the former river bed encapsulated belowArtificial Island." .

Based upon AKR.F's April 20, 2012 addendum historic properties visual impact assessment report, as the Deputy State Historic Preservation Officer for New Jersey, I find the following properties eligible for listing on the National Register of Historic Places. under Criterion C for 18t century pattern-brick architecture:

1. John Maddox Denn House (112 Popular Street, Lower Alloways CreekTownship)

2. Sarah Mason House (349 Fort Elfsborg Road, Elsinboro Township)

In consequence, this is a new SHIPO opinion of eligibility. ..

13

~'1 800.5 Assess Adverse Effects- -'* "..

Through earlier conisultation, the IHIPO agreed that- permitting- a new eniergy 'station through the ESP process would not be have the potential to effect historic properties and that IPO comment on visual impacts would be conducted during the COLA. when more specific, dletailed construction information was available. 'A review of t~he EIS suggests HPO has failed to mfake

th~is point clear to NRC (ETS Sections,2.7,1, 4:6, and 7.5). While more specific IPO comment on visual impacts will be forthcoming through section 106 'consultation during the COLA, the cumulative effects. of introducing two additional cooling towers, 76. feet higher than the existing, with. vapor columns will adverselY affect the viewshed of the Abel and Mary Nicholson House National Historic Landmark.

Additional Comments* '

Thank you again for-providing the opportunity to re~view and comment on the potential for the project to effect historic properties. The HPO .lookis forward to continued consultation to. identify historic properties, assess affects, and resolve adverse effects on historic properties. Please reference the EPO project number 09-0740 in-any future calls, emails, submissions or written correspondence to help expedite your review, and response. If you have any questions, please do not *hesitate to contact Vincent Maresca *of at (609-633-2395) with questions regarding archaeology or Michelle Craren (609-984-0176) with questions regarding historic architecture, historic districts, or historiclandlscapes.

Land Use Reguilation Pro~raim- Office of Dredging and Sediment Technologyv The Office of Dredging and Sediment Technology (ODST) has completed a review of the above-referenced document, prepared by the U.S. Nuclear Regulatory Commission. (NRC) and the USACIE-Philadelphia District. This Draft Envirornmefital Impact Statement (-DEIS) evaluates (1) the issuance of an Early Site Permit (ESP) by the NRC for new nuclear power generating facilities at the PSEG Artificial Island site, and (2) USACE permit actions associated with the proposed project,-including dredging, dredged-material management,, fill, and other regulated "preconstruction'"activities."

This review focused on the dredging, and -dredgedI material aspects of the proposed project, and cons~idered previous ODST comments on the ESPiEnvironmnental Site Report prepared by PSEG for the project (enc~losed letter dated December 10, 2010).

(1) The USACE-Philadelphia District is a cooperating agency on the preparation of the EIS, and will use the EIS to support its decision-making process for regulated activities on the PSEG Artificial Island site associated wi~th the construction and operation of new nuclear power generating facilities. The USAGE issued a Public Notice to this effect, to which ODST has provided comments (letter dated September 30, 2014). At this point, given that the proposed PSEG project is "conceptual" in nature and .the scope and magnitude of potential impacts are to be further clarified in the future after the "selected alternative/design" has been identified, it appears premature for the USACE to make any regulatory decisions concerning the project. .

(2) In order to construct the proposed nuclear power* generating facilities, the~ USACE will have to permanentiy transfer 85 acres of its existing Artificial Island Upland CDF to PSEG. In exchange, PSEG and USACE have proposed a land exchange, and that PSEG will obtain all the permits needed to construct and operate - and will construct - a new upland CDF at. Site 15G along the Delaware River. This land.' exchange is the subject of a 14

Draft Environmental has commented Assessment (DEA) prepared .bythe USACE, which the Department on (letter from Ruth Foster dated August 27, 2014).* However, the actual acres .of land to be exchanged and their relationship, to the USAGE Artificial Island

Uplan~d CDF vary between the DEIS and the Land Exchange DEA -

a.. Section 2.2.1, page 2-5, para. #2:. states that .PSEG will acquire 85 acres of the

~USAGE Artificial Island Upland CDF. However, the land exchange evaluated in the DEA includes the transfer of 631 acres of federally-owned land to PSEG - 94

~acres comprising Cell 3 of the USAGE Artificial-Island .Upland GDF, and 537 acres of adjacent wetlands (to be used as a "buffer area"). The ESP DEIS and Land Exchange DEA must be consistent with each other.

b. Section 2.2.1, page 2-5, para. #2: states that PSEG will temporarily lease an additional 45 acres of the USAGE Artificial Island Upland GDF - but also states

'TSEG would retur the 45 ac of leased land to the USAGE, subject to any required long-term exclusion area boundary (EAB) control conditions .from the NRG." Thus, potentially 130 acres of the USAGE Artificial Island Upland GDF could be transferred to PSEG. The - acreage transferred must ibe verified to evaluate the potential impacts of the proposed project on the operation- of the USAGE Artificial Island Upland GDF. and its future capacity to meet the maintenance dredging needs of the.USAGE. [Also see Section 2:.12, page 2-1931-Proposed Land Exchange Between USAGE and PSEG.] -

c.. Section 2.2.1, page 2-6,.para. #2: states that the 85 acres to be permanently acquired from the USAGE consists -of 50 acres that are part of the USAGE Artificial Island"Upland GDF and 35 acres of an aidj acent coastal marsh.

d. Table 2-1, page 2-9:- associated with the "'85-Ac Parcel to'be Acquired" -are. 28.3 -

-acres of Phzragmites-dominate~d Goastal` Wetlands and 0.2 acres Saline Marsh -

- not 35 acres, of adjacent coastal marshi -

_(3) The~potential impacts of PSEG permanently :and .temporarily using lan~d associated with the USAGE Artificial Island Upl.and CDF on the present and future, dredged material disposal capacity- available to the .U-SA.CE .for~ deepening and maint~enance dredging.

activities have not been evaluated in the .DEIS..-If the acquisition/use of this. land by PSEG will result in the need for' the USAGE :to. develop additional upland GDFs to meet its dredged material disposal need~s, this cumulative impact of the proposed PSEG project must also be evaluated in the DEIS..Likewise, the potential impacts of construction activities associated .with the proposed PSEG- project on the present use. and operation of the USAGE Artificial Island Upland GDF must be evaluated in the DEIS. --

-a. To quantitatively verify that the remainling portions of the USAGE Artificial Island Upland GDF will have adequate capacity to meet the dredged material S*disposal needs of the U.SAGE, the DEIS should (1) calculate the available

dredged material disposal capacity considering the transfer of both 85 acres and 130 acres of the facili~ty to PSEG, and (2) compare that to estimates -of the USAGE maintenance dredged material disposal needs over the next 50 years for the reaches of the Delaware River that-the Artificial Island Upland GDF serves.

b. Section 4.1.1, page 4-8, para.#1 states "Tfhe AriiilIsland GDF providesth USAGE with dredge spoil disposal capacity ... the USAGE would need to.

rejilace some or all of this disposal capacity by using -an .existing GDF or 15

.developing a new CDF ait an~other location." Thus, the DEIS concludes that the proposed project wvould have ",moderate" impacts on land-use. However, since the potential impacts of the proposed project* on the operation of the USACE

Artificial Island Upland CDF and the potential need to construct and operate a

new .upland CDF have :not been evaluated in. the DEIS, it does not appear possible to comprehensively evaluate the potential, land use impacts of the proposed project. [Also see Table4-21, page 4-105 - Site and Vicinity.]

(4) Section 4.0, page 4-3, para. #3 and Section 5.0, page 5-1, para. #3: the N'RC review team that prepared the DEIS assigned impact levels of "small", "moderate" or "large"' to the

. resource areas to be impacted-by the proposed project. These "impact category levels

[are] based on the assumption [emphasis added].that the mitigation measures identified in the [-PSEG Environmental Report] or activities planned by various State and county governments ... are implemented. Failure to implement these upgrades might result in a change in the impact category level." Thus, the actual potential impacts of the proposed project have. not been evaluated in the DEIS - this is a fundamental flaw in the preparation of the DEIS. For example, by using the above-noted procedure, this suggests that the NRC review team may have underestimated the potential impacts of the proposed

project to in the follo~wing sections of the DEIS -

a. Section 4.3.2.2, page 4-40: states "Mvitigation of unavoidable impacts ... may include [emphasis added] restoration of habitats ... "

b. Section 4.3.2.2, page 4 Upland Terrestrial Impacts: states "The mitigation of

... .. "temporary impacts ... could include [emphasis added] restoration ... Mitigation

-. of impacts .... may include [emphasis added] grading and plantin~g .. These

.. measures, in combination could restore [emphasis added] quality habitat for i.. .. resident wildlife populations." *

c. Section 4.3.2.3, page 4-43:, para. #1: states '"Mitigatfion of wetland resources may he [emphasis added] warranted." * .

d. Section 4.3.3.4, page 4-49: states "PSEG. plans to consult with local, State, and federal agencies regarding additional and practicable mitigation needs ....." to address aquatic impacts. Thus, since these mitigation requirements were not

known by the NRC review team when preparing the DEIS, how could they be

incorporated into its assignment~of an impact level?

e. Table 4-21, page 4-108 - Terrestrial and Wetland Resources: states "Proposed

""*. *compensatory actions could offset some of the impacts."

.(5) Some of the impact evaluations conducted, in the DEIS are, in part, made relative to the

"quantity" .ofthe affected resource presentiin the site -vicinity or in the surrounding region

- since, the impacts resulting from the proposed PSEG project would only be a small

percentage of this larger quantity, the-impacts are considered to be small or minor. This approach - taken to the extreme and applied to all proposed development projects or

human activities in given region .- would lead theoretically to, imply that there is

a no/minimal water or air pollution, habitat fragmentation, threatened/endangered species,

etc. In addition, this type of analysis does not-consider potential threshold effects on natutral resources when considering if the level of impact could "destabilize" the resource.

Thus, it is not appropriate to. use such an analysis in a DEIS to determine the magnitude and scope of potential project impacts. [For example, see: Forestland, page 4-26; Water, 16

page 4-27; Habitat Loss* Impacts - page: 4-29; Terrestrial Species of Recreational or

Commercial Value, page 4-31; Artificial Ponds. and Onsite Marsh .Creeks, page 4-44; 7.1

.=Laud

- Use, page 7-8. ],.

(6) Section.2.3:3.1, page .2-45+: includes a minimal presentation and discus~sion of current surface water quality .data in the vicinity of the PSEG site;*thus, it is not possible to evaluate the potential impacts of the proposed project on surface water quality based on the information provided in the DEIS.

(7) Section 2.4.2.1, page 2-83, para. #1: briefly mentions "PSEG's active licensed desilt basin". This basin should be clearly shown on an appropriate figure, and its operation.

discuissed.in the DEIS. [Also see Section 4.3.1.1, page 4 Impacts on Habitats, para.

2.] -

(8) Section 2.4.2.1, page 2-91, para. #2 - Delaware River Estuary: uses data from 1973-1976

- to characterize plankton in the Delaware River Estuary - use of 40-plus year old data to describe existing conditions is not appropriate.

(9) Section 3.4, *page 3-26: maintenance dredging acti~vities needed to support the operation*

of the proposed project are only briefly discussed and evaluated in the DEIS.

(10) Section 4.2.1.1, page 4 Delaware River: states that approximately 92 acres of the bottom of the Delaware River will be dredged (using both mechanical and.

hydraulic means), resulting in about 665,000 cubic yards (CY) of dredged material that

'"would be disposed on the site or at another afpproved upland disposal site."' The Office

of Dredging and Sediment Technology ,will 'be the NIDEP lead on all dredging and dredged material management regulatory actions associated with-the proposed PSEG project. The DEIS barely discusses the dredging and dredged material aspects of th&

proposed project. All ,dredging and dredged material management activities associated with the construction and operation, of* the proposed PSEG project must be comprehensively evaluated in the DEIS. This would include sampling and testing of the sediment to be dredged consistent with the requirements of the 1997 NJDEP Dredging Technical Manual. ..

a. Section.4.2.3.1, page 4-22, para. #2: potential dredging impacts to surface water quality cannot be evaluated without (a) 'identifying the dredging methods, and (b) testing the sediment to be dredged for contaminants of concern.

b. Section 4.3.3.1, page 4-45 :~ Delaware River Estuary: an additional 1,350-7,150 CY of dredged material may have to be managed, depending on the final design.

of the proposed PSEG project. Also, this section of the DEIS estimates that about 590,000 CY of sediment will be dredged (again, subject to final project design),

but Section 4.2.1.1 (page 4 see above comment) estimates that 665,000 CY of dredged material will be generated..

c. If an additional on-site or off-site upland CDF is needed to manage the dredged material fron the *proposed PSEG project (construction and

.operation/.maintenance), the impacts of the construction. and operation of this facility should be evaluated in the DEIS." -

17

i. Section 7.3.1.1, page 7-19, pama. #3: states "The USACE Delaware River Main Channel Deepeninig project would require a site to dispose of dredged material. The UJSACE proposes to dispose of dredged material at [the] Fort Mifflin CDF." .

ii. Section 7.3.1.1, pages 7-19/20: states ".... current operations at SGS and UcGS would require a new location for disposing of dredged material, and a disposal site also would be needed for dredged material from developing a new barge access, are at the PSEG. site." . .

iii. Section 7.3.1.1, pages 7-19/20: concludes that "The effects on terrestrial and wetland habitat would, be expected to be less than, but consistent with, those of the Delaware River Main Chmannel Deepening Project."

This is incorrect - since the Delaware River Main Channel Deepening Project did notrequire the construction of any new upland CDFs, and it appears one or more new upland CDFs are needed to support the proposed PSEG project, associated impacts resulting from thle PSEG.

project are not consistent with - and would potentially be greater than -

"those associated with the Delaware River Main Channel Deepening

Project. Thus, it isnot possible for the NRC review team to conclude that "the cumulative impact, on terrestrial and .wetland ecology habitats from dredging activities as a result of building and operating a new nuclear.

-poivcer plant at the PSEG site in conjunction with past, present, and

reasonably foreseeable dredging activities would be minimal.." . .

d. Section, 5.2.1,*page 5-5, para. #1: the need to conduct maintenance dredging in the-future associated with the proposed PSEG project is briefly mentioned, but the quantity of dredged material to be managed - and how the dredged material

will be managed- is not addressed.. [Also see Section 5.2.3, page 5 Physical

:Effects of Discharge, and Section, 5.3.2.1, page 5-39 -.Physical, Impacts.]

(11). be' Section 4.3.1.1, page 4-26-F orestland, para. #1: notes that 80.3 acres of forests wlbe"temporarily disturbed" on .the.PSEG site, and an additional 1 acre "temporarily disturbed" associated-with. construction of the proposed causeway. If these impacts to forests are "temporary" - how will they be restored?

(12) Section-4.3.3.2, page. 4 Shortnose. Sturgeon and Atlantic Sturgeon: best

management practices to miimze impacts to these fish will also include seasonal dredging "windows" (see Section 4.3.3.3, page 4-49).

(13) Many of the construction-related impacts are noted as "temporary" in duration.

However, Onlstruction activities will occur over an estimated time period of 7 years (see Table 3-2, page 3-20): -

(14) Section 2.4.1.1, page 2 Amphibians: reports the first known siting of green tree frogs. (Hyla cinerea) in New Jersey on the PSEG site; the significance of this discovery - and potential project impacts to this frog population - should be evaluated by

the Division of Fish and Wildlife. [Also see Section 4.3.1.2, page 4-3 8- Other Important Terrestrial Species and Section 5.3.1.2, page 5 Other Important Species]

If you have any additional questions, please contact Suzanne Dietrick at (609) 292-883.8 18

Land Use Regulation Program- Coastal Regulation "

The draft Division IBIS from of theLand NRCUseandRegulation in response(DLUR) offers Notice to the Public the .following from thecomments in response to the Army Corps of Engineers, Philadelphia District (Corps) .issued on September 4, 2014 as .a result of the application from

-PSEG Nuclear, LLC for a permit pursuant to Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act. The Corps. is a cooperating agency with the NRC on this Major Federal Action.- -

The project consists of the construction of a new nuclear power plant/reactor and associated infrastructure at the existing Salem Hope Creek facility in Lower Alloways Creek Township in Salem County. ,Associated infrastructure includes intake structures, discharge struc.tures, a barge unloadi, g and mooring facility, new bulkheading, dredging, electrical substations and a new causeway: The proposed project will result in numerous impacts to regulated features including" the permanent disturbance of 131. acres of wetlands and the temporary disturb~ance of 82 acres of wetlands.

Prior to any construction, the proposed project wif require several permits from the Division including a CAFRA Individual Permit, Waterfront Development Individual Permit, Freshwater Wetlands Individual Permit, Coastal Wetlands permit and a Tidelands conveyance.

The Division has reviewed the draft IBIS and has one clarifying comment:

p. 298, line 22 - "CoastalZone ManagementAct (CZM'A) (16 Usc 14.51-TN1243.). Federal Consistency Determinationhas been made with conditions by NJDEPstating that the project submittedfor NRC review is consistent with New Jersey s Rules on CoastalZone Management

(NJDEP2010-17'T235).". . .

On Jily'23, 2010, the Division issued a Federal Consistency to PSEG.Power, LLC and PSEG Nuclear, LLC.in anticipation of the submittal of the ESP. The Federal Consistency was intended to be only for the siting of the project at the Salem Hope Creek site. A Consistency.

Determination has not been issued for the project before. the NRC and the Corps.' The Federal.

Consistency was conditioned on the applicant receiving the required permits named above. Once those approvals are obtained, the pr.oject will be considered consistent with the Coastal Zone Management Act. " : - -

If you have any additional questions, please contact-Ryan -Anderson in the Land Use.Regulation Program. at (609) 292-1230 and Marty Mosen in the Tidelands program at (609.) 633-7900:

Air Oualitv - Planning The Bureau of Air Quality Planning (BAQP) has reviewed the Draft Environmental ImPact Statement (IBIS) for an Early Site Permit (ESP) at the PSEG Site and has the follo~wing comments:

1) Executive Summary Evaluation of Environmental Impacts The Dr.aft IBIS for the ESP states, "When evaluating the environmental impacts associated with

nuclear power plant construction and operations, the NRC's authority is limited to construction activities related to radiological health and safety or common defense and security; that is; under 10 CFR 51.4, the NRC-authorized activities are related to Safety-related structures, systems, or components and may include pile driving; subsurface preparation; placement of backfill, 19

concrete, or permanent retaining w~alls within ,an excavation; installation of foundations; or im-.

place assembly, erection, fabrication, or testing.". . ..

Comment #1 This comment concerns the General Conformity~provisions of the U.S. Clean Air Act along with.

its implementing USEPA regulations. Section 93.150 (a) (Prohibition) of the Federal General Conformity regulation states, "¢No department, agency or instrumentality of the Federal Government shall engage in, support in any way or provide financial assistance for, license or

' permit, or approve any activity which does not conform to an applicable implementation plan."

The Federal General Conformity regulation requires that the direct and indirect emissions resulting from project activities that require a permit, license, approval etc. by a Federal agency,

must be assessed through an Applicability Analysis to determine if a Conformity Determination is necessary. Section 93.153 (b) (Applicability) of the Federal General Conformity regulation states, "a conformity determination is required for each criteria pollutant or precursor where the total of direct and indirect emissions of the criteria pollutant or precursor in a nonattainment or maintenance area caused by a Federal action would equal or exceed any of the rates in paragraphs (b) (1) or (2) of this section." The Draft Environmental Impact Statement (EIS) for an E'arly Site.

Permit (ESP) at the PSEG Site indicates that.the Federal agencies. that have jurisdiction for this project are the NRC, US Army Corps' of Engineers (USACE) and the U.S. Coast Guard (USCG)-

(Page 4-12 and Page 11-2)..

A General Conformity Applicability Analysis for ozone (Volatile Organic Compounds (VOCs) and Oxide.s of Nitrogen (NOx)) is neede.d for this project, and, if necessary, a Conformity Determination may also be subsequently needed for this project.

When preparing the analysis, the direct and, indirect air. emissions associated with project activities covered by the Federal permits, license, approv~als etc., from the NRC, USACE and the USCG project activities must be included in the analyses.. ... ...

The following Clean Air Act General Conformity information is provided for future Project Planning Purposes:. -. ... . .....-

A) If multiple Federal Agencies have jurisdiction for various aspects .ofa project as indicated in the ESP, Section 93.154 (Federal agency conformity responsibility) of the Federal General Conformity regulation provides that "a Federal agency may choose to adopt the analysis of another Federal agency or develop its own analysis in order to make its conformity determination." .- '-

B) The USEPA's General Conformity Guidance: Questions and Answers (July 13, 1994) indicates that a project cannot be broken down into segments so that each segment would be below the de minimis levels. All reasonably foreseeable emissions must be included for the project as a whole in determining applicability..

C) If a conformity'determination is required, Section 93.157 (b) (Reevaluation of conformity) states, "The conformity status of a Federal action automatically lapses 5 years from the date a final conformity determination is reported under §93.155, unless the Federal action has been completed or a continuous program to implement the Federal action has commenced.".

2) 1.1.2 Site Preparation and Preliminary Activities The Draft EIS for the ESP states, "PSEG submitted an application to the NRC for an. ESP that did not include a request for a limited work autho.rization (LWA). Prior to receiving a CP or.COL, the holder of an ESP without an LWA may only perform the preliminary activities not requiring 20

NRC- authorization, as enumerated in 10 CFR 50..1O?(a)(2). These preliminary activities can include clearing and grading, excavating, erection of support buildings and transmission lines, and other associated activities."

Comment #2. ,

Comment #1 *above also applies to this portion of the project. Section 93.150 (b) (Prohibition)

of the regulation requires that an action must conform to a State Implementation Plan (SIP) before the action is taken. New Jersey is~in nonattainment of the 8-hour ozone National Ambient Air Quality Standard (NAAQS), therefore, the project must~conform to the SIP prior to aiiy preliminary activities/preconstruction activities are undertaken.

Other Sections of the Draft BIS for the ESP that are Applicable to Comments #1 anid #2 above" are:-

1'.1.5 Preconstrucfion Activities. Page 1-7 8, lY Paragraph, Line 42.

3.3 Construction and Preconstruction Activities, Page 3-19, 2 nd Paragraph, Lines 9 - 17.

The USACE permit (CENAP-OP-R-2009--0457, Page 4, 2 nd Paragraph) states that, "The proposed construction-and/or permitting of the causeway/bridge structure falls under the authority of the Uuited States Coast Guard (USCG),pursuant to Section 9 of the Rivers and Harbors Act of 1999."

In addition, the Federal Energy Regulatory Commission (FERC) may provide approvals for the

siting of pipeline/transmission lines.

3.3.1 Site Preparation. Page 3-20, 1*t Paragraph, Lines 3 - 7."--*

3.3.1 Site Preparation, Page 3-21, 1*t P.aragraph, Lines 4 - 13. ... '

3.3.2 Power Block Construction, Pages 3-22, 6t' Paragraph,. Lines 29--38. Page 3-23, 1st Paragraph,. Lines 1 -3.

4.0 Construction Impacts At the Proposed Site, Page 4-2, 2 nd Paragraph, Lines 17 -21 4.0 Construction Tmpacts-Atthe Proposed Site, Page 4-2, 3rd ParagrapthLines 26.-33.* .

4.1.1 The Site and Vicinity, Page 4-7 3 rd Paragraph, Lines .10 - 16. '

4.1.20Offsite Area~s, Page 4-8, 4t" Paragraph, Lines 33 --34. ..

4.2 Wajer-Related Impacts. Page 4-12, 2n Paragraph, Lines 19 "L -

4.7.2 Traffic (Emissions), Page 4-85, 1l* Paragraph, Lines 4 -=6..

3) See Section 4.4.1.3 Air Quality. Page 4-52, 5* Paragraph, Lines 38 -40. Page 4-53, 1st Paragraph, Lines 1-2. ""

Comment #3' Comment #2 above also applies to thiis portion of the project.

In addition, it is not known at this time if an air mitigation plan .will be req uired in order for this project to conform to the SIP. **

21

,-- d

4) See Section 4.7.1 Constraction and Preconstmction Activities, Page 4-83, 3 rd. Paragraph,' Lines 20 -24. "' .

Comment #4 Comment #2 above also applies to this portion of the project. In addition to the N\RC and the UJSACE, please include the USCG in the statement.

5) See Section 4.7.1 Construction and Preconstruction Activities. Page 4-83. 3 rd Paragraph. Lines 27 -31. .

Comment #5 ".

Comment #2 above also applies to this portion of the project. In-addition, this statement indicates that an ESP with no Limited Work Authorization for the PSEG Site will not directly or.

indirectly cause any emissions. However, the statement in #2 above, states that ".... the holder of an ESP without an LWA may only perform preliminary activities not requiring NRC authorization, as enumerated in 10 CFR 50.10O(a)(2). These preliminary activities can include clearing and grading, excavating, erection of support buildings and transmission lines, and other

a~ssociated activities."Y These activities will produce air emissions. Please explain the dis~crepancy in the twio statements.

6) 5.7.1.1 Criteria Pollutants The Draft BIS for the ESP states, ".Table 5-13 presents'PSEG's estimated annual non-radiological emissions associated with operating a new nuclear power plant at the PSEG Site..The estimated ,

annual NOx emissions in Table 5-13 are 52.5 tpy, well below the 100 tpy de minimis rate... The estimated annual VOC emissions are 202 tpy, significantly larger than the 40 CFR 93. 153(b) (1) de minimis rate (40 CFR 93, Subpart B, 40 CFR 93-TN2495)... If, at the combined construction permit and operating license (COL) stage, the estimated VOC emission rate remains above the de minimis rate, NRC staff will need to demonstrate conformity with the applicable state.,

implementation plan (SIP*) according to 40 CER 93.150 to. comply with the General, Conformity Rule (40 CFR 93, Subpart B, 40 CFR 93-TN2495). Because the ESP does not authorize the activities that would lead to these emissions, the General Conformi.ty Rule is not addressed at this timle.".

Comment # 6" Modifications to the SGS and HCGS .Title V. Operating permit will be' required for a new nuclear plant, the air emissions associated with the operation, of a nuclear plant are exempt from the Federal General Conformity regulation. Section 93..153 (d)() of the Federal General Conformity regulation states that a conformity determinaton is not required for "the portion of an action that includes *major or minor new or modified stationary sources that require a permit under the new source review (NSR) program (Section 110(a) (2) (c) and Section 173 of the Act) or the prevention of significant deterioration program (title I, part C of the Act)."

For any additional questions, please contact Angela Skowronek at (609) 984-0337*

Air quality - Permitting The Bureau of Air.Permits has reviewed the Draft BIS for the proposed nuclear reactor at Salem and Hope Creek Generating Stations. The new plant is proposed to have supporting equipment,.

such as cooling towers, auxiliary boilers, and emergency generators that emit air pollutants.

These equipment items are subject to Federal and State air pollution control regulations. PSEG Nuclear would be required to submit an operating permit modification application to incorporate 22

these equipment items and theirassociated emissioo ns~in the existinig Title V operating permit for Salem and Hope Creek Generating Stations.

If you have any additional questions, please contact David Owen at (609) 633-1129.

Water Resources Management .

The expanded area is not in the current sewer service area. Currently, the Hope Creek Generating station, which has process wastewater as well as sanitary wastewater strea~ms, is identified on -

Block 26, Lot 4 only. Should the expansion or new reactor create additional process and/or .

sanitary wastewater on an expanded lot, the applicant will have to comply with the Water.

Quality Maniageiment Plan (WQMP) rules at NJAC 7:15-5.24 and 5.25. More details regarding process and/or sanitarywastewater are~required in order to fully assess this project. For additional questions, please contact Jaime Murray at (609) 777-4349.

Water Resources :- Surface Water Permitting The Division of Water Qual~i.ty has the following comments on the draft Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site. Where appropriate, an excerpt from the ETS has been included after the comment and referenced page number along with any suggested changes where underlined text indicates an addition and sfriketbrough text indicates deletion.

Executive Summary Page xx (Lines 30-31)

Comment: The Department supports PSEG's proposed plant design that will use either mechanical or natural draft cooling towers-to remove waste heat from the water discharge. This is consistent with current Section 316(b) regulations which require new facilities with a design intake flow equal to or greater than 10 MGD tb maintain the intake flow of cooling water at a level commensurate with that. achievable with ai closed dcycle, recirculating cooling system.

Thermal Discharge Page 5-,11 (Lines 6 and 7)"

Comment: .PSEG did apply for a renewal of the 316(a) variance i.n 2006 as part of their overall NJPDES permit renewal request, however, the reniewal permit has not yet bseen issued by NJDEP2 The original 3.16(a) variance was issued in the 2001 final permit and remains effective as a~result of PSEG's submittal Of a timely renewal application. As a result, this language should be -

clarified as follows: ."

In 2006, PSEG applied for the N-PDES permit-renewal with a request for renewal of the 316(a) variance. PSEG submitted a timely application for renewal of the NJ-PDES permit.

therefore the conditions of their expired permit remain in effect pursuant to N.J.A.C. 7: 14A-2.8.

Page 5-12 (Lines 17-22)*

Comment: The Department has determined that the section summarizing the results' from the CORMIX simulations needs to be clarified and/or-questioned for .thenew nuclear power plant.

Specifically, it is counterintuitive that two new units with cooling towers could generate a smaller

.23

thermal plume than the existing HeatDissipation Area (i-~IDA) for the single unit at HCGS. NRC should evaluate the conclusions of the CORMIX simulations.

Page 5-13 Figure 5-2 Comment: Figur~e 5-2 is misleading in comparing a 1.*50 F Temperature Envelope for the new plant to the existing HDA for the HICGS. The TIDA for HCGS is larger thana l.5°F Temperature Envelope wouldbe for HCGS because it includes the allowable increase of 4° F from September through May. When a I-IDA is developed for the new plant, it will be larger than the extent depicte~d in Figure 5-2, with a greater overlap with the HCGS I-IDA.

Page 5-12 (Lines 24:28)

Comment: It is true that the extent of the thermal plume from a new plant will be small mn' comparison to the existing SGS TIDA. However, NRC has not discussed the additive effe~ct ofthe overlapping thermal discharges from all three power plants (SGS, HCGS, and the new plant) and is understating the effects of the impacts of thermal discharges from a new nuclear power plant as minor relying on the basis that SGS has greater impacts.

If you have any additional questions, please contact Heather Genievich at (609) 292-4860.

Water Resources - Water Allocation and Well Permittin2 TheBureau of Water Allocation & Well Permitting (BWAWP) has reviewed the Draft Environmental.Impact Statement (EIS) for an Early Site Permit (ESP) at the PSEG Site submitted with the PSEG ESP app~lication for a~proposed nuclear electric generating plant located adjacent to the existing .Hope Creek Generating Station (HCGS) and Salem Generating Station, Units 1 and 2 (SGS) in Lower Alloways Creek Township, Salem County, New Jersey (NJ).

A specific reactor technology has not yet be4en selected. However, the design characteristics of four reactor technologies under consideration were used to establish a plant parameter envelope (PPE) (Site Safety Analysis Report [S.SAiR] Section 1.3). While issuance of the.ESP, does not authorize construction and operation- of any new¢nuclear~power units, .this EIS analyzes the .

environmeihtal impacts that could result from the 'construction and operation of one or two new nuclear power units at the PSEG Site. These impacts are analyzed to determine if the site is suitable for the addition of the new nuclear plant, and whether there is an alternative site that is environmentally preferable to the proposed site. .

PSEG has not y;et selected a specific reactor(s) technology. Four different technologies are under consideration including:

Advanced Passive 1000 (APlO00)

U.S. Evolution~ary Power Reactor (U.S. EPR) "

Advanced Boiling Water Reactor (ABWR)

U.S. Advanced Pressurized Water Reactor (US-APWR)..

The new plant uses a recirculating (closed-cycle) cooling water system that includes natural draft, mechanical, or fan-assisted natural draft cooling towers. A new¢ shoreline intake structure supplies makeup water from the Delaware River to the new plant. A new discharge structure conveys cooling tower blowdown to the Delaware River in conformance with New Jersey Pollutant

.Discharge Elimination System (NJPDES) permit requirements. Section 3.4, Cooling System, 24

provides additional detail on the intake, discharge, an..d cooling tower components of the plant cooling system. ".**. -

In accordance with Water Supply Management Act, N.J.S.A. 58:1lA-i et seq. and its supporting regulations N.J.A.C. 7:19-1 et seq. the following will be required from.BWAWP:

A Water Allocation T.emporary Dewatering Permit will be required for construction dewatering where the dewatering rate is 100,000 gallons per day or more for more than 30 days in a consecutive 365-day period. If the dewatering period is 30 day~s or less, a Permi~t by Rule will suffice however it is expected the construction phase will be considerably longer. A Dewatering Permit by Rule may be applicable if the dewatering occurs from within a coffer dam.

The current water Allocation Permit, No. 221 6P requires modification if additional groundwater withdrawal or additional groundwater sources are planned for the new plant. Included with such a request for major modification of the Water Allocation Permit will be a ilydrogeologic Report prepared in accordance with TI\-12-2 guidelines pursuant to N.J.A.C. 7:19-2.2(c).

The site is south of Water Supply Critical Area No* 2. Increases in withdrawals from the PRM Aquifer are being reviewed by BWAWP due to concerns with safe yield and salt water intrusion.

The results of the draft 2008 and 2013 USGS .synoptic groundwater-level measurements indicate that the water levels in the Middle PRM aquifer where the site obtains their industrial water supply have declined. -..

Natural replenishmaent of ground water is probably not occurring in the middle and lower PRM aquifers as evidenced by the results of US GS monitoring. A localized cone of depression is present in Salem county centered at Artificial'Islald as the result of local pumping from both the middle and undifferentiated PEM, and the Lower PRM aquifers. A regional cone of depression extends from New Castle County, Delaware enacompassing Salem County as a result of heavy pumping in the Middletown anid St. Georges USGS quadrangles in Delaware where water levels are as low as -187 feet in the Lower PRM, and -58 in the.Middle PRM ..

Locally, water levels decreased from -70 feet in 2003 'to -75 feet in'2008 at Observ ation Well I (3400004055) well screened in the middle and undifferentiated PRM aquifer. Water levels also decreased from -33 feet in 1983, -45 feet in 2003,'to -46 feet in 2008 at Observation Well 6 (3400001511t) screened in the lower PRMV aquifer."

The amount of water needed will depend upon the reactor(s) 'technologies used.. The surface water intake(s) are not regulated by BWAWIP since the surface water intake(s) are located south of the-Delaware Memorial Bridge at River Mile (RM) 69. However, the Delaware River Basin' Commission (DRBC) should be contacted to determine if their review of this project is required.

Additionally, the Department's Division of Fish and Wildlife must be contacted to determine the*

impact to the aquatic biota in the Delaware River due to impingement and entrainment due to cooling systems operation, heat stress due to the thermal discharge plume, and chemicals .in the discharged blowdown from the new nuclear power plant.

Well Drilling Permits* for construction dewatering Wells, permanent water supply wells and "

closure of abandoned Wells will be required fromBWAWP. .-. "

25

di .*

BWAWP anticipates that its portion of a pre-application meeting would require approximately 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . In addition, a representative of the New Jersey Geologic and Water Survey (NJGWS) would need to be present at the meeting (NJGWS contact Jim Boyle). .

Prior to~any meeting, the BWAWP requests that the following information be provided:.

SAnticipated allocation limits in gallons per minute (gpm), million gallons per month (mgmn), and million gallons per year (mgy).'

Anticipated source of supply (:aquifer) and quantity, of water to be diverted from each source (gpm, mgln, and mgy).

GIS mapping depicting source locations.

,, A general discussion of proposed aquifer testing or basis for an aquifer testing waiver.

If you have any additional questions, please contact Barbara Ware at (609) 984-6831.

Thank you for giving the New Jersey Departnent of Environmental Protection the opportunity to comment on the Draft Environmental Impact Statement for the proposed PSEG Salem Hope Creek Early Site Permit review. If you have any concerns, please contact our offce at (609-292-3600.

Sincerely, RuhW otr PDScin e

Office of Permit Coordinati~on Sand Environmental Review Enclosures -

C: John Gray, NJDEP-PCER Angela Skowronek, NJDEP-A~ir Qnalit-Planning David Owen, Aliya Khan, NIDEP-Air ?ermiting Kelly Davis, NJ'IEP - NHRG Fish and Wildlife .-.. .

Vincent Maresca, NJDEP - Historic Preser-vation Karen Tucillo, NIDEP -Bureau of Nuclear Engineering "

Suzanne Dietrick, Joel Pecchioli, NJDEP - Office of Dredging and Sediment Technology" Heat~her Genievich, NJIDEP - Discharge to'Surface Water Permits R~yan Anderson, NJDEP - Land Use Regulation'-

Jennifer Myers, Barbara Ware, NJDEP - Water Allocation and Well Permitting Jaime Murray, NIDEP - Water Resources Management Richard Dalton, NJD)EP-NJ Geological and Water Survey Barbara Ware, NJDEP-Water Allocation-Marty Mosen, NJDEP-Tidelands.

Samuel Reynolds, Nichole Minnichbach - US Ainay Corp"of Engineers Steve Tarnbini, DRBC .

Lingaard Knutsen, USEPA Region 2 .

Gary Bickle, AKRF, Inc .

Ms. Jennifer Dixon-H~eriity, Chief United States Nuclear Regulatory Commission Office of New Reactors, Division of New Reactor Licensing Environmental Projects Branch*

Washington, DC 20555-0001 26

EXHIBIT MI. UNAVOIDABLE IMPACTS,

. ;. * ' Impact Level Environmental Resource U navoidable Impact Building Operation Lano use "About' 430 acres on and a djacenit to.the *"MODERATE .:SMALL"_

. :..,.

PSEG Site Would be.comniitt'ed to the :=.

"_:'.._: prioject thr.'6ughout preconstruction~and ' *. *-

-... *.

.'.'*." co

dnstruction, of which 225 a*cres w6Juld not -. .-i-

.:.::.: -be' available for use after 6onstruction is :* "

"':i. c*;omplete5:About 69 acres wduld b&" .- '*

.":oo*mmitted during pr~econst:u'ctibn for the :*- - SMALL.-_.

J! .-'auseway; b~f whichW45.5 acres WolId not .- ":

z-I~ availablefor~use after the causeway is*="- ..."

,;N" Water. Use 'Small amounts of surface water from. : SMALL '

S storm water retention POndS would be used for dust suppression during building of the new nuclear"power plant.

Groundwater would be obtained from existing wells used for the Hope Creek SM..A-L"L".

and Salem Generating Stati~ons.

Temporary and localized groundwater impacts would result from dewatering for power block construction arnd preconstruction arid constructio'n support.

(including concrete, batch plant supply and dust:suppression), During operations, surface-water~withdrawals from the Delaware River could exceed the PSEG current storage allocatlgn of water in the Merrill Creek reservoir. Minor groundwater consumption* for-sanitary and"-"

potable water systems and for-. .:* :::

demineralized makeup water:. *: .. :

Quality Surface-water quality would be affected -: *-SMALL

, by clearing ,vegetation; disturbing the land surface; inadvertent release of, .

contaminants associated with building materials arid equipme nt; buildcing -

activiies in the tidal marsh and~t!dal -*

stream areas; and dredging activities In

the Delaware River. Temporary and localized groundwater-quality impacts would result from dewatering for power, block conistruction and discharge of groundwater to adjacent sui'face water bodies.

35

EXHIBIT. M, (CONTINUED)

Impact Level Environmental Resource Unavoidable +Impact .Building *.Operation

.. ..... During operations, impacts to the Delaware River from thermal discharge

ahd discharge of nonradioactive liquid.

effluents from the cooling Water system, as~well as potable and sanitary discharges. Possible groundwater Impacts from chemical or radiological.

spills that could migrate to shallow water (brackish) zones or saline intrusionto deep aquifers due to groundwater-

.withdrawals. -

.Ecology! 'Ter'restrial and C-onstru.ction and precdnstructiorn.Would -:MO.DE.R.ATE- SMAILLI Wetland= ..- disturb about 430 acres on and .adjacent....:*

.. Resources i;to~the .PSEG.Site and 6.9 aci~es along the ; .;i*, i.

.:L. ~~~~proposed causeway. About.225 acres.. '.-:*"*

_.'.:;:. ~~~on. the site .would.be perma~nehtly ,.. ;.i;"-! * "

-&"

tote sie widd etmporril

~~~~~disturbed and 205 acres 6n~and adjacent .' - -:

digturbed. Permanent disturbance on

""..the site would lnclude 408 acres of ;* !

--." *-- ::". wetland habitat and 9 *acres of old field _ ,...

.-..c -... d ~br:ush/shwrbIl d h~abitat. Thmporary---

,:o.

.':...

... .:.......

-...: .: *., disturbance.on 80acres of old thesite field andiwould include" ?-

Phragjtnites.-, " ." - ..:,: "- ...

...:.i.: ..*-..._.. *-* 'dominated old field .habitat and 32 acres . - .+ -.: ;. ..*..

"" "" -:. +'v .'of wetland 'habitat. Temporary- -.- : ._ :!; . "

".".: i: :'. *. :.disturbanc." adjacent to the sate woul1d -- ; -- : - _

"* -* *" ....-i~l~clude:30.2-acres of wetla"nd habita~t.-- . - .... -.

"" :' * " ;*~~P~rec-orstructfion wouldl disturb"69,0 acre-s "":"- " :-

.*' '* " :"*. ;45.5 acres would be pSermfanently *. * .: " :! .::: :

disturb~ed and 2,3o acres wiould be .:" :- : '"i"{! ,.: "

-- "".... -tmporanily distube Permanre~nt . - '; .:- .! :.. .- .- -

";. -i*: .'~~disturbance would, .nclude.23 acres.'of .L.* .",*'-..-:.

.:- ..' ,.. _:- ..;. --,: wetlaiid habia n 3.5 acres of . ... *..". -,.,. ..-

'-- " ": '-."-'. forestland habitat;.Ternp rr *i ! .* ? -" * :

-.:. :2 "': **: distub~ancwouldlinclude-20 1 acres4 of:""; : = -

:':-'.'": ":-:* :-*' wetland habitat.""Increased risk of bird--- .!. _ :. .... ,.. -

'-" " : :--' 611isliris wlth sti'uctur~s, wildlife .. , .

7.."* . 'b*: .. - voidance du~e t6lncreased noise and '. ".7" ;-: -;'? ...

-%.. .." "--: :..:: ". ,artlfici~i light, and, potential-mpacts of. ... .:- .

-. *-- .'..: *i'.* 'salt de~positi~on oh vegetati~n near th~e :?" ;.. -

36 ,

,p

" EXHIBIT M, (CONTINUED)

Impact Level Environmental Resource -Unavoidable Impact Building .Operation

'.SMAkLL "sMALL Aquatic P~hysical altceration of hab~itat (e.g.,' :

..Resources . infilling, cofferdam placement, dredgibg,

.- ..,. .pile driving); includihg temporary .or ._ -

"--.permanent-rem oval of as~sociated benthic:.

if:.: ::. .-.organ~isms. sedimeritati~n, ch~anges ini .

-: .- .-:.'}hydrological re',ime~s, an~d changes in:.

= ...-.

- w.

ivater::quality. Aqu-atic-habitats agfeoted 7*

-*;:" -"" - *' ;wotild include artificial ponds andI snja{ll

....... ' .;imarsh creeks; habitas associate-d with -

':*.i . °: "the D~elaware Rivet and Delaware River .:

" "*" " Estuairy; find'tile interconnected system "'

... . ~of tidal wetlands andl marsh creeks-; SMAL SMALL.-*

" i:- '- _-prima~rily north of the PS.EG .Sitei:.*:. " (most to (most)to-

-. " -L

'" .-.Dufnng operations, impacts to aquatic: M.DERAT MOD-RAT

." .-- .

"*'...

* *~biota in the Delaware River from...:z.

(eteics (ethis

p. .

,.-,

.:.-, :,.-impi~ngem~ent and e..trainiment due to.:

.::oolingc syistem o'perations, heat stress-

" **--.* due to the-thermnal disch.arge pliurne, *nd

.: 2_1" *. .. : :.chem~icals in the dischar'ged blowdo~wn.

.. -.

.,o.* . "). .from.,the new nuclear powe~r..plaint...:

Socioeconomic Physioal Minor physical impacts associated with increasedl noise, airt pollution~.emissions, and vehicle, traffic. .Building and' operating"new. cooling towers and new reactor dome~s at* the PSEGSite~and an elevated .causeway to the PSEG Site would noticeably affec.t 'aesthetic qualities from sensit~ive vle~ApoJins, Demography The in-migration ofworkersandtiheir .SMALL SMALL familieslto suppoitbuilding~a new nuclear power plant wO~d*in'crease the" population of the economic impact area by about 0.16 percent.' The increase would be most-proniounced in Salem County, New Jersey, which would experience about a 1.24 percent, increase in population. The. in-midration of workers an~d their families to support operating a new nuclear power plant would increase the population of the economic impact area by about 0.05 percent. The increase would be most pronounced in Salem. County, New Jersey, which would experience about a 0.4 percent increase in population.

m 37

Adl EXHIBIT M. (CONTINUED)

Impact Level Environmental Resource . Unavoidable Impact Building Operation Lconomic None ,.,MALL to ,..M~ALL to and Tax LARGE LARGE (beneficial) (beneficial)

Infrastructure Increase in local traffic during building, SMALL SMALL and resulting in increased congestion. (most) to (most) to Community Aesthetic impacts near recreational MODERATE MODERATE Services resources, specifically on the Delaware (traffic and (recreation)

River and PSEG Estuary Enhancement recreation)

Program viewing platforms, would not be amenable to mitigation for the increased industrialization at the PSEG Site. -

Environmental Julstice .-.None~ :-*. % ..-.. " .- C-. None : -:. None :

Historic and Cultural Resources No unavoidable adverse impacts to SMALL SMALL historic and cultural resources are anticipated.

Meteorology and Air Quality fFugitive dust and~emissions of criteria" SMALL *.SMALL :,

4"-ollutants; h'Izardous air pollutan~ts; and :':! --- : ';

greenhouse"gases from lan~d disturbing :-. *i.;., {.":.i

[anrd building activities and .equi~rent.' : . .. . ,-

..;and from additional veh icle trafric, but 1." '-" #= * -:-:

-impacts wcir~ld be temporary. Citeria. ~ *- " * :

!<pollutant, .. hazardous air pollutarnt,

. ...

v-* :

- gree~nhouse gas, and. coc!i.ng system. : .. -. ..

.,. emissions;.. Operations would irncrease -. " ' ""

.:-.gaseous anhd p~a.rticulate emissions by a :-. - -*,;

"small amount, primarily from equipi~ent : .. . .. .

N .onra-oogca.Helt associated wvith~auxiliary systemsi and.. --.. :..; .-.. _

-:the c.ooling towers. T'he primary soiJrces * ' :* -.. --

..of em~issions from.,auxiliary systems -. *' * .. :..".*"-:.

would be the aiikiliar*' boil~ers; standby *. : ,! :

pov~ r uni~ts such as diesel generato~rs or_! : .- .'- ";

i:gas turbine.s; and engine-driven* .::* : ; .=. . -.

-emergency. equipment. The cooling:.-o- .* i*--

.-towers wouldl be*.he prfimary source of"

-particulate~emissions::.". : _!: .. .

Fugitive dust; occupational injuries; noise; and the transport of materials and SMALL SMALL personnel to the site. Exposure to etiologic microorganisms through cooling systems; noise generated by unit operations; and accidents during transportation of operations and outage workers to and from the site; 38

State of 'f jre DEPARTMENT OF ENVIRONMENTAL PROTECTION OFFICE OF PERMIT COORDhINATION AND ENVIRONMENTAL REVIEW CHRIS CHRISTIE BOB MARTIN Governor P.O. Box 420 Mail Code 401-07J Trenton, New Jersey 08625-0420 Commissioner Telephone Number (609) 292-3600 KIM GUADAGNO FAX NUMBER (609) 633-2102 Lt. Governor January 20, 2016 ey, Chief Ms. Cindy Blad Rules, Announc ements, and Directives Branch //.j:**

r...*

Office of Administration 6*Ž-/g/i;/c;7C~:5@7 Mailstop 3WFN-06-A44MP t United States Nuclear Regulatory Commission .7.r (-J.

Washington, DC 20555-0001 O2:,

...... t 0)f

=2 RE: PSEG Salem Hope Creek Generating Station Lower Alloways Creek Township, Salem County

,(_*

Docket NRC-2014-0149; NUIREG-2168 L.LJ Unites States Nuclear Regulatory Commission Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site, Final Report The New Jersey Department of Environmental Protection's Office of Permit Coordination and Environmental Review (PCER) distributed, for review and comment, the Final Environmental Impact Statement (FEIS) as prepared by the U.S. Nuclear Regulatory Commission (NRC) and, as a cooperating agency, the U.S. Army Corp of Engineers (USACE). On December 5, 2014 (enclosed), the Department provided comment on the Draft EIS for this proposed early site permit for an additional nuclear unit at the PSEG facility in Lower Alloway's Creek Township, Salem County. Based on this most recent submittal, we offer the following comments; Air Bureau of Evaluation and Planning

1. Appendix J - PSEG Site Characteristics and Plant Parameter Envelope Values:

The Final BIS includes Table J Assumptions by Technical Area Not Covered in Table J- 1. Table J-2 states, "Potential borrow areas for borrow pits have been identified at several locations in New Jersey, Pennsylvania, and Maryland, however, the extent of the land required has not been determined."

Comment - The General Conformity Applicability Analysis (Applicability Analysis) must include the air emissions from the trucks transiting to and from the borrow pits (within a non-attainment or maintenance area). Please include the air emissions from the

>4- II truck transits to and from the borrow pits (within a non-attainment or maintenance area)

U, *.Q' [I in the Applicability Analysis.

New Jersey is an Equal OpportunityEmployer 1 Printedon Recycled Paper andRecyclable

.7

2. 3.3.1 Site Preparation - The Final EIS states, "Most of the causeway structure would be made of prefabricated elevated sections set in place from an elevated crane to minimmize impacts along the causeway route."

Comment - The General Conformity Applicability Analysis (Applicability Analysis) must include the air emissions from the elevated crane that will be used to set the prefabricated sections for the causeway inplace. Please include the air emissions from the elevated crane in the Applicability Analysis.

Thank you for giving the Department the opportunity to comment on this project. If you have any additional questions, please do not hesitate to call me at (609 292-3600.

Sincerely, Office of Permit Coordination and Environmental Review Enclosure cc:

John Gray, NJDEP, Deputy Chief of Staff-Ryan Anderson, NJDEP-Land Use Regulation.

Karen Tucillo, NJDEP-Bureau of Nuclear Engineering Richard Dalton, NJD)EP-NJGS ..

Marty Mosen, NJDEP-Land Use Regulation - Tidelands Joel Pecchioli, NJDEP-Land Use ODST David Owen, NJDEP-Air Permitting Vincent Maresca, NJDEP-SHPO Angela Skowronek, NJI)EP-Air Planning Kelly Davis, NJDEP-NHRG-F+W Samuel Reynolds - USACE Steve Tambini, DRBC Lingaard Knutsen, USEPA Region 2 Jennifer Dixon-Herrity, Chief, NRC Office of New Reactors Dr. Alan Fetter, NRC Environmental Project Manager 2

'. 'DEPARTMIENr OF ENVIRONI~IENTAL PROTECTION ..

CHIRIS CURISTIE OFFICE OF PERMIT COORDINATION AND Em~lONME.NTAI REVIEW :BOB MARTIN Governor P.O. Box 420 Mail Code 401-073f Trenton, New Jfersey 08625-0420 Commissioner Telephone Number (609) 292-3600 KIM GTUADAGNO FAx N*UMBER (609) 633-2102 Lt. Governor December 05, 2014.

Ms. Cindy Bladey, Chief Rules, Announcements, anld Directives Branch Division of Administrative Services Office of Administration1 Mailstop 3WFN-06-A441VP United State Nuclear Regulatory Com.mdi.ssion Washington, D.C. 20555-000 1 RE: PSEG Salem Hope Creek Generating Station Lower Alloways Creek Township, Salem County Docket NRC-2014-0 149; # 52-043 Comments on Draft Environtmental-Impalct Statement for PSEG E~arly Site Permit Application.Review United States Nuclear Regulatory Commission

Dear Ms. Bladey:

The New Jersey Department of Environmental Protection's (Department) Office of Permit Coordination and Environmental Review (PCER) distributed,, for review and comment, the Draft Environmental Impact Statement prepared by¢ the US Nuclear Regulatory Commission .(NRC) as part of it's review of.an application by PSEG Power LiLC and'PSEG Nuclear LLC (PSEG) for an Early Site Permit for a proposed additional nuclearfnt, *at'.heir: facility in Lowcer Alloways Creek Tow-nship, Salem County. The Department p.reviously, provided: initial .and supjglemental' comment on the Early Site Permit Site Report on September 15, 2010 and December 10, 201.0.

(enclosed). We offer the following comments for your consideration..*

Nuclear Engineerin* -

The Bureau of Nuclear Engineering has reviewed the U.S. Nuclear Regulatory Commission's "Environmental Impact Statement for an Early Site Permit (ESP) at the PSEG Site" and offers the following comments:

1) Volume 1, Section 2.3.3.2 "Groundwater Quality", Page 2-50, Lines 1 The statemenlt that SGS Unit 2 ". .. has a tritium monitoring system often wells installed due to elevated tritium concentrations in the shallow aquifer resulting from precipitation capture of vented iritiated-water vapor" is inco~rrect. According to PSEG.Nuclear, these wells were installed "to assist in identifying potential leaks from Salem Unit 2" following the discovery of a leak of condensate from an expansion joint on the SGS Unit 2 plant vent. Thle "haighly tritiated" water that escaped from the expansion joint leaked onto the Auxiliary Building roof and was transported to nearby New Jersey is an Equal Opportu.nity Employer 1Printedon Recycle~d Paperand Recyclable

catch basins via the roof drain and stormwater collection system (PSEG Nuclear, LLC, Remedial

Action Progress Report, Second Quarter 2013* J.anuary 28, 2014).

2) Volume 1, Section 2.4.2.3 "ImportantAquatic Species and Habitats", Page 2-109, Lines 6-33 and Section 4.3.3.2 "ImportantAquatic Species and Habitats", Page 4-47, Lines 14-19

-I descriptions of the easterm oyster population and, fishery are inaccurate and incomplete. The

assertion that the eastern oyster was not "...observed in the Delaware River Estuary in the vicinity of the PSEG Site between 2003 and 2010" is contrary to the well documented descriptions of the oyster beds in the iNew Jersey portions of Delaware Bay provided by the Haskin Shellfish Research Laboratory of the Rutgers University New Jersey Agricultural Experiment Station since the 1990's (http://hsrl.rutgers.edu/SAWreports/index.htm). According to those reports, there are extensive oyster beds within the 6-mile vicinity of the PSEG Site. Thenearest oyster bed, the Hope Creek Bed, extends from approximately 0:56 miles to 2.3 miles downstream from Artificial Island and covers 734 acres. Additional oyster beds located downstream from Artificial Island and within the 6-mile vicinity include the Fishing Creek Bed (315 acres), the Liston Range Bed (289 acres), the Round Island Bed (472 acres), the Upper Arnolds Bed (446 acres) and portions of the Arnolds Bed (630 acres). The vast majority of the commercial oyster harvest comes from the Direct Market beds located 11-16 miles downstream from Artificial IslandL It is important to note however, that as part of the .managementof this fishery, the oyster population of these Direct Market beds is supplemented with large numbers of oysters transplanted from the above described upstream beds located within 6-miles of Artificial Island. In 2013 for example, 21,050 bushels of oysters/cultch were transplanted from the beds located within the 6-mile vicinity to the Direct Market beds. Based upon the estimated density of 404 oysters per bushel of oyster/cultch material during 2013, this equates to approximately 8,504,200 oysters. Tranisplants from the Hope Creek Bed, the upper portions of which are located less than 3,000 fe~et downstream from Artificial Island, have been suspended since 2012 to allow for recovery from a 2011 low salinity.

mortality event attributable to flooding associated with Hurricane Irene and Tropical Storm Lee.

During the 20Q9-20 11 .period however, the Haskin Shellfish Research Laboratory reported that-*

16,450 buashels of oysters/cultch, or the equivalent of nearly 10 million oysters, were transplanted to. the downstream Direct Market beds fto~m the Hope Creek Bed alone. .

With regard to the New Jersey commercial harvest of eastern oysters, according to the EIS "... .the last reported commercial fishery in New Jersey reported a harvest of 550,086 lb in 2008". More recent Delaware Bay specific harvest data are available from the above referenced reports by the Haskin Shellfish Research Laboratory. According to the February 2014 report, the total harvest from the New Jersey portions of Delaware Bay in 2013 was 84,276 bushels. This was an increase of 6,136 bushels compared to the 2012 harvest, and the seventh consecutive year in which the

harvest equaled or exceeded the 18s-year mean of 75,409 bushels: ..

The available data on the oyster fishery in the.New Jersey portions of Delaware Bay, as well as similar data for the State of Delaware portions of the bay, need to be evaluated in order, to ensure an accurate assessment of the potential impacts of the construction and operation of the proposed nuclear power facility on the eastern oyster. For example, construction activities that result-in increased sediment load in the river could adversely impact the nearby oyster beds. In addition, oysters are filter feeding bivalves that are known to accumulate, and in some cases 2.

bioconcentrate, radionuclides typically found in ef-fluents from nuclear power plants such as cobalt-58, cobalt-60, zinc-65, anid silver-i110. Effluent specific radionuclides have been found in oysters as far as 7.5 mile~s from the point of discharge of nuclear power plants (McLean, R. I., J.

K. Summer~s, K. A. Rose, and S. L. Domotor, 1987. Silveri110, Cobalt-58, anud Zinc-65 Conct~ntrations in the American Oyster, Crassostreavirginica (CGmelin), Near-The Calvert Cliffs Nuclear Power Plant, Maryland Power Plant Research Program, December 1987). The proximity of some of the Delaware Bay oyster beds to the PSEG Site, and the practice of transplanting large numbers of oysters from beds fiear the site to downstream beds that support a signi~ficant commercial fishery, make oyster colasumption an important potential exp'osure pathway to man..

As such, that pathway should be monitoredas part of aneffective Radiological Environmental Monitoring Program (REMVP) for the proposed facility.

3) Volume 1, Section 2.11 "Radiological Environment ", Page 2-191, Lines 2 As part of the discussion of the groundwater contamination caused~by the spent fuel pool leak at SGS Unit 1, the NRC states that "Nqocontamination is believed to have migrated to the unrestricted area."

The direction of groundwater flow inmthe area of concern however, is towards the nearby Delaware River, and the licensee's groundwater monitoring data indicate that at least some of the contaminated groundwater has migrated into the river and therefore into the unrestricted area. .

Monitoring Well AG-S for ex~ample,.is a shallow monitoring well (24.2 ft. below ground surface) located approximately 360 ft. down gradient from the source of contamination (seismic gap) and-only 40 ft. from the bank of the Delaware Ri.'ver. Tritium. concentrations as high as 33,200 pCiAL have been observed in groundwater samples from this well (Januaary 2005). In addition, although the spent fuel pool leak was discovered in 2002, it was not until June of 2013 that the licensee determined that the contamination had reached the deeper Vincentown Aquifer as well as the.

shallow, water bearing unit. Well AA-V was installed in the .Vincentown Aquifer (85 ft. below-ground surface) in May of 2013 and is located appr~oximately 130 feet from the river bank.

Tritium concentrations in groundwater, samples-from Welt *AA- V haye ranged from 7,000 to 13,000 pCiIL, several times higher than the tritium concentrations observed at the same location ..

in the sballow; water bearing unit (Well AA). The in~stallation of additional moni'toring wells will be required in order to properl~y characterize the: extent of the contamination in the Vincentown Aquifer. However, the available data suggest that at least some of the contaminated groundwater in this deeper formation has discharged or Will discharge into the Delaware River. In fact, the licensee has performed a mass flux estimation ofthe quantity .oftritium reachtn.g the Delaware River. They estimated that 0.011 curies per year could reach the Delaware River from the shallow, water bearing unit, and 0.066 curies per year could reach the river from the deeper groundwater (Mass Flux Estimation Memo, PSEG Nuclear LLC, Salem and Hope Creek Nuclear Generating Stations, Hancocks Bridge, New Jersey, Prepared by ARCAD.IS U. S., Inc., Project No. NP000571.2013, dated October 29, 2013).

4) Volume 2, Section 7.2.2.2 "Impacts on Groundwater Quality", Page 7-16, Lines 31 The existing and potential impacts on groundwater quality are not accurately characterized here.

The NRC states "The existing SGS and HCGS have impacted shallow groundwater quality, but these impacts have been minor and have been limited to the immediate vicinity of the PSEG Site." AS documented in the previous comment however, existing impacts to groundwater quality have not been limited to the shallow groundwater. Ground water contamination attributable to the 3

spent fuel pooi leak at Salem Unit 1 has been detected in the deeper V~incento~wn Aquifer. The-extent of the contamination in~this aquifer has':yet to be determined. ."*'* .

With regard to potential impacts on groundwater quality, i.the NRC states "Potential impacts to .

groundwater quality could come from inadvertent spills that could migrate to the. shallow water zones." This statement .incorrectly assumes that the impact of any spills will be limited to the shallow groundwater at the site. Recent experience at Salem Unit 1, as well as the Oyster Creek Nuclear. Generating Station in Lacey Towncship, New Jersey, has clearly demonstrated that the

probability that tritium contaminated water released into shalloW unconfined aquifers will ultimately reach deeper confined aquifers is much greater than previously predicted. Construction activities typically associated with .nuclearpower plants, such as deep excavations for building foundations and other structures, and the installation of cofferdams to support dewatering" operationus, can significantly alter site hydrological conditions. An unintended consequence of. .-

these activities has been the creation of downward pathways that have allowed contaminants to pass through the confining layers into the deeper aquifers.

5) Volum.e 2, Section 7.3.2.5 "Climate Change", Page 7-29, Lines 1 This section of the EIS references a 2011. report by the Partnership for the Delaware Estuary that examines- the potential impacts of climate change on marine bivalve shellfish populations in the Delaware" Estuary (PDE 201!1-TN2 190). According to that report, the combined effects of climate change,.

rising sea level, channel deepening, and increasing demands for freshwater from the Delaware River and nearby aqieawl eut nasgnificant increase in the salinity of Delaware Bay. As a result, .it is expected that the oyster population will expand further up the estuary, towards the PSEG Site. In that scenario, the populations located in down bay areas that currently support most of the commercial fishery (Direct Market Beds) would be depleted byr the diseases that are more prevalent in high salinity conditions. The *oyster populiations in the upper bay, locaited just downstream from the PSEG Site, and that currently serve primarily as a source of transplan~ts to.

replenish the down bay* Direct Market beds, would then become the center of the commnercial oyster harvest. The location of a large c.ommercial oyster fishery just downstream from three existing nuclear power plants, and potentially one or two additional units, would result in a-significant increase in the frequency of occurrence and concentration of effluent specific radionudlides in oysters that are sold for human consumption. Therefore, that exposure pathway should be monitored as part of an effective Radiological Environmental Monitoring Program (REMP) for the proposed facility.

If yo~u have any additional questions, please contact Karen Tuccillo at (609) 984-7443.

NJ Geological and Water Survey The sections of the draft EIS pertaining to geology and ground water have been reviewed and the-comments below need to be addressed. The comments are by section and page.*

Section 2.3.1.2 Groundwater Hydrology

p. 2-38, lines 17 to 19. The EIS cites Martin.(1998) for the heads in the middle aquifer bein.g about 20 ft.. above sea level before pumping.

Comment: It shouldbe noted that two .wells were drilled at Artificial Island by the US Army Corps of Engineers in 1930-1932. The Historic Well Records at the NJDEP indicate both wells 4.4

A.

were~completed in what is now termed the middle P-RM aquifer. Water levels given for the well at the south end of Artificial Island range from sea level to + 4 feet, not the 20 feet above sea level as the computer simulation indicated. These actual measurements agree closely with the - 4 feet measured on 4/1/1969 [NWSI-(USGS 392744075315301 33030- .ArtIsland)] in the middle PRM at Artificial Island. Before the construction began at Artificial Island there, were no large regional pumping areas near enough to reduce the heads in the aquifer at Artificial Island. All the head-reductions in the .area were the result of the pumping at the plant site, nowhere else...

p. 2-39, lines 20-21. Indicates Figure 2-18 shows the stratigraphy of the PSEG site based on geotectinical borings."

Comment: When Figure 2-18 is examined there are problems with the unit identiflcation~s, especially in the upper part of the borings. There is no Kirk-wood, either upper or lower, at Artificial Island (see Owens and others, 1998). The Kirk-wood was eroded away during the Pleistocene and the sand (lower Kirkwood) and the clay (upper Kirk-wood) above the sand and below the artificial fill and alluvium are both late Pleistocene deposits (see Owens and Minard, 1979). The figure also shows the Itornerstown and Navesink Formations as too shallow at the site. Since the EIS references this figure as being from the PSEG (TN3452), that report was checked, but no boring information could be found there. The SSAR, [PSEG (TN3453)], was found to :have the boring logs and other information. When the, logs were reviewed it is evident that the geologists logging the borings misidentified the Hornerstown and Navesink in every¢ boring. They describe the Hornerstown as a fine to silty sand having a trace to a few glauconite or a few to little glauconite. The Hornerstown Formation contains the highest glauconite content found in any geologic formation in New Jers.ey. The glauconite ranges between 40 and 90% of the sand fraction, not a trace or few grains as is described in the boring logs. Also on page 2-170

ofthis EIS,-Figure 2-30, the description of Htornerstown indicates it is highly glauconitic, not a*

trace of glancouite as the boring logs indicate. .The first appearance of any significant amount of glanucnite in the logs is what they are identifyring as the Navesink Formation, but it is.in fact, the H-omerstown Formation. Owens and others (1998), -at a scale of 1:100,000, shows Kirkdwood

eroded away with the Vinucentown Formation being the youngest pre- Pleistocene formation at Artificial Island. Stanford (2011), at a scale of 1:24,000 also indicates that~the Kirkwood Formation is not present at Artificial Island since it.was eroded away during the flhinoian lowstand about 150,000 years ago. Descriptions of theilomerstown Formation can be 'found in" Owens and others (1998), Miller and others (2005), andRosenau and others (1969).

It is important to recognize that the Kirkwood Formation is not present at Artificial Island since it means that the "confinin g" clays above the Vincentown Formation are not regional in extent. The clays on site are limited in'aerial extent and do not form a single layer extending inland for miles protecting aquifers below the water table as they wo~uld if they were actually the clays of the Kirkwood Formation. The clay and lower sand are Pleistocene deposits and that is thereason why they are so variable in thickness and extent at the site.

p. 2-39, lines 37-38.

Comment: There is no K~irkwood Formation at Artificial Island. The clay separating the alluvi'um from the Vinmcentown Formation is Pleistocene, not Miocene as is .the Kirkwood Formation..

p. 2-41, Table 2-7.

Comment: There is no Kirkwood F~ormation at Artificial IslandAlso as mentioned above the geologists that described the borings for SSAR and ER misidentified the Homerstown Formation.

In the ER, p. 2.6-6, they describe the Hornerstown Formationi as having a trace to some :...

glanconite at the site and they indi~cate the glanconite increases with depth. They further indicate that the glauconite can make up greater than 30% of the sand fraction near the base. of the 5

formation. It should be noted that the Vincentown-Homnerstown contact is .generally placed where there is a significant increase in glauconite from about 20 to 40%. The IHornerstown Formation is the e~asiest unit to recognize in the New Jersey because of its high glauconite content. The depths*

to top of Hornerstown would be deeper than is indicated&.Note, the boring information Was found in Appendix 2AA (Boring Logs), of the. SSAR. This Appendix has the geologist desdriptions and.

formation identifications and in addition, some of the figures in the SSAR show geophysical logs

for some of those borings. Benson (2006), Plate 1, Section B-B' shows the Hornerstown-Navesink Contact in the' 1800-foot boring at Artificial Island& This contact is placed at the top of a-major gamma spike atabout 175 feet below sea level. This is the same gamma splice that is found in Boring NB-i (about -150') and Boring EB-3 (about -168') The geologic logs for these two borings show the Hormerstown-Navesink contact over 40 feet higher because the geologists .