Nov 17, 2010

Nukes Part of the Problem, Not the Solution

NJ Environmental Federation Statement about relicensing 3 nuclear plants in Salem

The NJ Environmental Federation, the state’s largest environmental organization with over 100,000 members and 100 member groups, opposes PSE&G’s application  for relicensing the 3 nuclear plants at the Salem site. As the Garden State Chapter of Clean Water Action, we oppose nuclear power in general because it is unsafe,  unsustainable and unnecessary. We oppose the building of a fourth nuclear plant at the Salem site. 

NJ Environmental Federation believes that conservation, efficiency and sustainable energy sources such as wind power, solar power, and wave power should be invested in rather than federally subsidizing nuclear energy and fossil fuels.  America will never wean itself from unsustainable coal, nuclear and natural gas energy until alternatives are aggressively supported.  If the playing field was leveled whether by eliminating all subsidies or providing equal subsidy, wind, solar and efficiency would outcompete nukes and coals every time.

Governor Chrisitie has committed to much more aggressive implementation of the strong goals contained in the 2007 Global Warming Response Act and 2008 Energy Master Plan, e.g., 25% by 2025 Renewable Portfolio Standard and 20% by 2020 Energy Efficiency Portfolio Standard.  These efforts provide the path to a clean, safe, reliable, green energy future and a 4th plant at Salem is not part of this path.

Specific to Salem/Hope Creek, the existing 3 nuclear plants produce radioactive waste that remains a danger for thousands of years into the future. This nuclear waste  has outgrown its spent fuel pools and is now contained in above ground dry cask storage sheds. How much more waste would be produced by a relicensing the three nuclear plants for another 20 years, with no future in site for a permanent safe storage site other than onsite in Lower Alloways Creek?

Further, the safety hazard associated with a malfunction and potential release of toxic radiation into the vicinity of the 3 existing nuclear plants would only be exacerbated by the aging of the facilities.  Tritium leaks at the Salem Reactors have occurred despite “redundant” safeguards, and are an indication that the safety culture at the plant and the preventive maintenance  warrants significant improvement.  Recent EPA internal documents have raised the  concern that in the case of a major nuclear accident, it is unclear whether the federal government and the Nuclear Regulatory Commission would have the authority/finances to clean up any radioactive releases to the environment.   Would the EPA be in charge of overseeing a cleanup, and would the regulations under the Superfund Act apply? Would the NRC/PSEG care to answer that question as part of their relicensing process? I think the public has a right to know who will be paying for such a cleanup and if the money is set aside to do so. It doesn’t bode well that the NRC recently gave jurisdiction for the NJDEP to oversee a cleanup of radioactive waste in Newfield at Shield Alloy, then challenged the court decision successfully to gain back control of the site when it was clear that NJ DEP’s cleanup would direct the waste to be shipped to a radioactive waste disposal site in another state. i.e., NRC against all local public opinion and the opinion of DEP scientists wanted to ‘contain’ the nuclear waste on site in Newfield, that being the cheaper option.  The NRC is not an agency that the public has confidence in to protect the environment.

Salem 1 and 2 are also huge consumers of water for cooling as well, killing 3 billion fish a year through entrainment and impingement. According to PSE&G’s permit renewal application, it states that 1/6th of the production of the Delaware River is being lost to impingement and entrainment at the facility.  Furthermore the application states that between 2002-2006, the fish loss from impingement and entrainment were 2.4 million alewives, 87 million croaker, 2,343 million bay anchovy, 14 million striped bass, 32 million weakfish – and this is just a partial list.  At the same time PSEG states that increased production of fish from restored salt hay farms is estimated at 2.3 times the annual production lost from impingement and entrainment at Salem. PSE&G did not evaluate the fish populations at the Phragmite restoration sites.  Although I am not a scientist I find it hard to believe that restoration mitigates the fish loss, but even if it did, it does not make up for the years of damage done to the ecosystem before the salt hay farms were restored to wetlands, nor does it offset the continuing loss of fish from the once through cooling system.   As part of the Stop the Salem Fish Slaughter/Unplug Salem Coalition” the NJ Environmental Federation has called on PSE&G to install cooling towers at Salem Units 1 and 2 to reduce the cooling water needs and alleviate the fish kill. Since l995, we have been calling for the installation of cooling towers, to no avail.  If PSE&G is not willing to spend the money to install cooling towers and protect the fisheries and estuary of the Delaware River, when cooling towers would obviously provide the best technology available to protect the ecosystem, how are we to trust they will maintain their plants for the next 20 years using the safest methods, or  build a safe and environmentally sound fourth nuclear plant?

Instead of building cooling towers, PSE&G has experimented with a wetland restoration project, built fish ladders, and tinkered with sound deterrents and screen retrofits at the cooling intake structure.  Restoring wetlands while admirable will not bring back the annual loss of fish that continues to occur unabated year after year. In the process of restoring wetlands, PSE&G has introduced over 22,000 pounds of herbicide (glyphosate) into the estuary in an attempt to control Phragmites.   While it was initially thought that one or two applications of herbicide would control the thousands of acres of Phragmites, it has turned into an annual herbiciding application.  As of May, 2010, PSE&G will have been performing annual herbicide applications in Lower Alloways Creek wetlands for 15 years, and they p

lan to extend that spraying even beyond 2010.  This is certainly not a sustainable effort if it depends on annual applications of herbicides.

PSE&G has even publicly stated they can’t afford to build a 4th plant without massive federal subsidies. PSE&G has made commitments to wind and solar power, and needs to do more in this area instead of proposing a 4th nuclear plant. For all these reasons, we urge 1) PSE&G to withdraw their pursuit of another plant, stop seeking unfair subsidies, comply with the federal Clean Water Act by building cooling towers at Salem 1 and 2 as a condition of relicensing, and accelerate its otherwise laudable renewable and efficiency efforts as well.

Jane Nogaki, Vice Chair

NJ Environmental Federation

223 Park Avenue, Marlton, NJ 08053