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 NEWARK, N.J., Aug. 12 /PRNewswire/ -- Public Service Electric and Gas Company (PSE&G) today said the N.J. Department of Environmental Protection and Energy's (DEPE) draft surface water discharge permit for Salem Generating Station represents the best way to protect both the environment of the Delaware estuary and the economic interests of millions of electric ratepayers served by the station.
 The company's comments came during public hearings on the DEPE's draft permit that would resolve environmental issues related to Salem station's cooling water intake system through a combination of water intake system modifications, flow restrictions on the water used by the station, and a comprehensive program to enhance the ecology of the Delaware estuary. This would include a wetlands restoration program and installation of fish ladders on certain Delaware estuary tributaries. PSE&G also would be required to conduct a biological monitoring program of the Delaware estuary. The permit would not require construction of costly cooling towers at the station, a project which PSE&G said would unnecessarily impose costs as high as almost $2 billion on electric ratepayers.
 Testifying for PSE&G at today's hearing were: Robert J. Dougherty, PSE&G senior vice president-electric, who said the draft permit reflects the best scientific and engineering information available and a well- reasoned and properly balanced decision consistent with the public interest and applicable law; Dr. Gerald Lauer, an aquatic ecologist who has assisted PSE&G in studying the Delaware estuary ecology for more than 10 years, who maintained that station operation has not and will not harm aquatic species; Dr. John M. Teal, an ecologist and senior scientist at the Woods Hole Oceanographic Institution, who discussed how the proposed wetlands restoration will help compensate for the effects of losses of aquatic organisms at the station as well as provide additional long-lasting environmental benefits; James M. Nicholson, chief mechanical engineer for New Jersey at the engineering firm of Stone and Webster, who provided details on the problems and costs involved in retrofitting Salem station with cooling towers; and Richard B. Stewart, professor of law at New York University and former assistant U.S. attorney general for environment and natural resources, who said the DEPE's draft permit meets the requirements of the federal Clean Water Act and is entirely consistent with judicial and administrative precedents governing application of that statute.
 Salem Generating Station is located on the eastern shore of the Delaware River in Lower Alloways Creek, Salem County. The station generates 2,200 megawatts (MW) of electricity for customers in New Jersey, Pennsylvania, and Delaware. Salem station is operated by PSE&G which shares ownership of the facility with Philadelphia Electric Company, Atlantic Electric Company, and Delmarva Power and Light Company.
 The federal Clean Water Act requires that thermal discharge -- the temperature of cooling water released into the estuary by Salem station -- assure the protection and propagation of balanced and indigenous fish populations and that the plant's cooling water intake system reflect the best technology available for minimizing adverse impact. The DEPE is responsible for enforcing the federal Clean Water Act requirements through issuance of water discharge permits.
 The DEPE, in October 1990, proposed a surface water discharge permit for Salem station that would have required its immediate shutdown and its retrofit with cooling towers. The permit was based on conclusions made by a DEPE consultant, Versar Inc., that station operation had the potential, in the future, to harm certain aquatic species. This conclusion centered on computer-based mathematical modeling and did not include a proper evaluation of long-term field studies of conditions in the Delaware estuary.
 PSE&G, in response to the 1990 draft permit, provided the DEPE with extensive additional documentation to support its position that cooling towers were not necessary and represented an unwarranted expense for electric customers served by the station. The documentation included updated mathematical modeling estimates of the station's effects on aquatic life, long-term abundance data on the species of concern, data from other electrical generating stations where modeling estimates proved inaccurate, and detailed engineering and cost estimates for building cooling towers at the station.
 While PSE&G believes that Salem station has not and will not have an adverse impact on the Delaware estuary, the company is sensitive to the concerns expressed by the DEPE and others about the potential for the future impact of losses of aquatic organisms that do occur at the station. Based on these concerns, PSE&G in March 1993, proposed a program of cooling water intake system modifications, a flow restriction on cooling water used by the station, a wetlands restoration project to minimize the effects of losses at the station, and a biological monitoring program.
 After reviewing and analyzing all available data, the DEPE, in June 1993, issued a draft water discharge permit for Salem station. The draft permit recognized that thermal discharge does not present an environmental problem. The permit, however, did express concerns about the potential for future impact due to operation of Salem station's cooling water intake structure. As a result, the draft permit included many of the recommendations made by PSE&G. It would require PSE&G to: restrict the cooling water the station draws from the river to an amount 5 percent below design specifications; modify the screens on the station's cooling water intake system to increase the survival of juvenile fish that become caught on the screens; eliminate fish migration impediments on certain Delaware estuary tributaries through construction of fish ladders; test the feasibility of state-of-the-art technology to create sound barriers that deter fish from approaching the water intake system; restore, enhance, and preserve up to 10,000 acres of degraded wetlands; grant a conservation easement to the DEPE for PSE&G's Bayside Tract, a 4,500-acre tract of land in Greenwich Township, Cumberland County; and implement a Delaware estuary biological monitoring program.
 In his testimony, Dougherty said "the DEPE's action appropriately resolves issues related to the renewal of the station's permit in a manner which properly considers and balances environmental benefits and economic consequences associated with available alternatives. While the company acknowledges that Salem's intake structure causes losses to occur," Dougherty said, "evaluation of available information demonstrates that these losses have not caused and will not cause an adverse impact on fish populations. Retrofitting Salem for closed-cycle cooling (cooling towers) would be a wide-scaled and complicated construction project involving substantial costs." PSE&G indicated that updated cost estimates point to a cooling tower price tag of approximately $1.8 billion if an immediate shutdown of the station were ordered, and approximately $650 million if a compliance schedule were allowed.
 Dougherty said PSE&G's recommendations for resolving permit issues were discussed with the DEPE, interested environmental groups, with the public at open house meetings in New Jersey and Delaware, and with various government agencies including the Delaware Department of Natural Resources and Environmental Control (DNREC), the Pennsylvania Fish Commission, the Delaware Estuary Program, the U.S. Army Corps of Engineers, and local officials in South Jersey.
 Dougherty reiterated PSE&G's commitment to continue paying property taxes on land purchased for wetlands restoration, to develop and implement flood prevention measures necessary to protect adjacent upland properties, and where necessary, to correct salt water intrusion into potable water wells or septic systems.
 "We believe," Dougherty said, "that the provisions of the draft permit will protect the Delaware estuary and provide lasting improvement to the ecology of the region in harmony with applicable law and our corporate commitment to meet the need for electric power in an environmentally and economically responsible manner."
 Lauer, an ecologist with 37 years of experience in conducting assessments of industrial activities on aquatic life, said PSE&G's 25- year study of the Delaware estuary "represents one of the most comprehensive, long-term evaluations of a power plant's effects on aquatic life ever conducted." The study clearly shows, he said, that while the losses of small aquatic organisms do occur, "the losses are not causing and will not cause and adverse impact on the community of fish, shellfish, and other aquatic life in the Delaware estuary."
 Lauer said a cooling water withdrawal system typically causes two types of effects. The first, called impingement, occurs when small fish, the vast majority of which are two-to-four-inches in length, are caught on the cooling water intake screens. The second called entrainment, occurs when even smaller organisms such as fish eggs and larvae pass through the screens and flow through the cooling system. The station only interacts with these organisms -- small and juvenile fish, larvae, eggs, and other small organisms.
 In assessing whether these losses have caused an adverse impact, Lauer said PSE&G has considered entrainment and impingement studies at the station, mathematical modeling results which place losses in population level contexts, and abundance monitoring data for the estuary. "The data support PSE&G's conclusion that continued operation of the station will not cause adverse impact on the Delaware estuary," he said.
 Lauer said DNREC (the Delaware Department of Natural Resources and Environmental Control) has conducted the most comprehensive and consistent fish abundance sampling data available for the estuary. The DNREC study, he said, concentrates on small and juvenile fish, which are most relevant for assessing any impact of Salem station. The DNREC data for the years 1981 - 1992, when both Salem station units were operational, do not show any downward trend in abundance for any species of concern.
 "There has been considerable public discussion," Lauer said, "concerning the decline in coastal stocks of larger adult weakfish. Large adult weakfish are not entrained at Salem. The DNREC data for juvenile weakfish show no decline in abundance." He added that the Atlantic States Marine Fisheries Council identified high fishing mortality as a cause for the decline in the adult weakfish population.
 Lauer testified that available evidence indicates the proposed modifications to Salem station's water intake screens will work well to increase survival of fish impinged on the screens. He said studies conducted at other power stations show the sound deterrent technology proposed to be studied at Salem also can be very effective in reducing impingement.
 "All of the best data available confirm that the station's cooling water system is not causing and will not cause an adverse impact on the aquatic community of the estuary," Lauer said. "Further, I and the other scientists who have assisted me, conclude that the draft permit will benefit the species at issue and will increase the biological productivity of the estuary."
 Teal, an ecologist with 40 years experience, noted authority on coastal wetlands and salt marshes, and author of "The Life and Death of the Salt Marsh," has been senior scientist at Woods Hole since 1972 and also is vice chair of the Conservation Law Foundation of New England.
 Teal provided a detailed explanation of the ecosystems of tidal marshes and how coastal marshes support and enhance fish populations by their biological productivity and their ability to provide nursery and refuge habitat.
 "The controversy concerning the DEPE's draft permit has generally focused on two alternatives," Teal said. "One is primarily ecological, broad in effect and long-lasting -- salt march restoration. The other is mechanical and narrow in effect -- cooling towers. The marsh solution will benefit the whole Delaware estuary and its coast, a wide range of animals and plants beyond those immediately affected, is resilient, self-engineered, and is beautiful. Cooling towers address only the immediate concern, need human maintenance for as long as they function, and are ugly. In my opinion as a professional ecologist, marsh restoration to minimize power plant effects makes much more sense than installation of cooling towers."
 Teal said marsh restoration can compensate for losses by their high productivity, the value of the refuge habitat they provide, and the support provided by early season stimulus to rapid growth in the young- of-the-year. Since the concern at the power plant involves juvenile fish of certain species, "it is reasonable, scientifically and practically, to minimize the effects of losses by enhancing the production potential of those fish over a broad area of the Delaware Bay by marsh restoration. The wetlands restoration program," Teal concluded, "is a great idea. Marsh restoration works. Marshes make fish. More marshes mean more fish."
 Nicholson said retrofitting Salem station with cooling towers would be a wide-scale, complicated, "and unprecedented" construction project and would involve, in addition to building the towers, installation of more than 10,000, 100-feet long steel and concrete piles, new condensers, two pump houses, installation of new pumps, construction of additional structures including a new chemical treatment building, new makeup and blowdown systems, a new dechlorination system, a new electrical substation, and more than four miles of seven-feet diameter piping and miles of electrical cables.
 If PSE&G were required to shut down the station immediately, he said the construction phase of the project would take approximately three- and-a-half years and cost approximately $1.8 billion, which includes the cost of replacement power. If construction were allowed to proceed while the plants were in operation under a compliance schedule, the cost would be approximately $650 million. These estimates don't include applicable state and federal taxes and return on capital invested in the project.
 Stewart, who as assistant U.S. Attorney General, was responsible for directing all environmental litigation for the federal government, said "the DEPE's procedural approach and determinations are fully lawful, entirely consistent with Section 316 of the Clean Water Act and other environmental laws, including the National Environmental Policy Act, and amply supported by relevant judicial and administrative precedent." Stewart, a former chairman of the Environmental Defense Fund, said, "I also find as an environmental professional that the department's approach represents wise environmental policy."
 Stewart said proponents of cooling towers who maintain the Clean Water Act mandates installation of cooling towers "are wrong." He said The U.S. Environmental Protection Agency (EPA), which has overall responsibility for administering the Clean Water Act, "has never required retrofit of closed-cycle cooling on existing facilities. They have either required modifications to intake structures similar to those proposed in the draft permit or no modifications at all. When closed- cycle cooling retrofit has been considered, it has consistently been rejected on the ground that its costs are `wholly disproportionate' to the environmental benefit afforded."
 This interpretation, he said, is consistent with the intent of Congress in drafting the Clean Water Act and has been upheld in the courts.
 Stewart termed opposition to the draft permit as "myopic and outdated. It is now widely recognized that both environmental and economic goals can often be better achieved by allowing flexibility for innovative solutions to environmental problems. Environmental protection measures should not be limited to technological `add-ons,' but should emphasize more inclusive approaches that respond to the full range of ecological concerns."
 The DEPE will hold additional public hearings in Cumberland County on Sept. 9 and a round table discussion in October for interested parties before making a final decision on the draft permit.
 -0- 8/12/93
 /CONTACT: Neil Brown of PSE&G corporate communications, 201-430-6017/

CO: Public Service Electric and Gas Company; N.J Department of
 Environmental Protection and Energy ST: New Jersey IN: UTI ENV SU:

TM-OH -- NY062 -- 2261 08/12/93 16:27 EDT
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Date:Aug 12, 1993

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