Statement to the Nuclear Regulatory Commission

Nov. 5, 2009


Re: License Renewal for Salem and Hope Creeks





I attended many for the hearings back in the 1970’s objecting that Salem be granted an operating license.


These plants should never have been built on Artificial Island in the first place. Upon examining the documents, I found to my horror , clearly described and laid bare on large maps, the soil condition upon which these plants were built.


Salem and Hope Creek are built on swamp land. AERIFICIAL ISLAND , is so named because is was built from dredge spoils  from the Delaware River.  The documents describe the ground , up to 75 ft.

 in 35 ft increments roughly as follows:

First 35 ft essentially mud

Next   35 ft mud and gravel

The last 35 ft they call “Vincentown formation” (sandy quarts and gravel )

Borings up to 100 ft reveal no rock bottom.


These plants, spent fuel pools and auxiliary buildings are now perched on cement pilings dug 70 ft into the sandy soil.


Yes , liquefaction was under discussion during the hearings but

 recklessly dismissed. We have many examples where liquefaction turned this type of soil into “jello” during an earthquake, toppling buildings with the pilings still attached to them.


( have made statements on this matter to many State and Federal Officials . I now have written confirmation from the NRC)


Yes, there is an earthquake fault under the Delaware River and yes, Morris County New Jersey  had a  3.0 earthquake on 1/3/09. It does not take a major quake to damage a sandy mud pile like Artificial Island.

What are the consquences ?


Over the years several studies have been commissioned as to the consequences of a major accident at a nuclear power plant . The Rasmussen Report in 1970 was not “satisfactory”. The final report was issued in 1982.


Here are the results for Salem:

Consequences of Reactor Accident (CRAC-2) Report -- NRC & SANDIA STUDIED MELTDOWNS/RISKS AT US NUCLEAR PLANTS in 1982!

The numbers given are in case of a class-9, or worse case scenario meltdown, and are based on 1982 population data and on 1982 dollars. 

Economic costs, not included are: the cost of providing health care to the affected population; all onsite costs; litigation costs; direct costs of health effects; and indirect costs.



Peak Early Fatalities

Peak Early Injuries

Peak Cancer Deaths

Property Damage 
(in Billions-1982 $)



Salem, Units 1 & 2
Salem, NJ

Unit 1 - 100,000
Unit 2 - 100,000

Unit 1 - 70,000
Unit 2 - 75,000

 Unit 1 - 40,000
Unit 2 - 40,000

Unit 1 - $135 Billion
Unit 2 - $150 Billion



Clearly these plants should have never received  a building permit , rather then a license renewal to operate for another 20 years these plants should be shut down and the site cleaned up.




These plants are operating against the Law.  More then 3 Billion Delaware River fish are killed  each year. The plants intake structure which takes anything under 3 inches makes the fish kills many times higher.

The National Environmental Policy Act of 1969 (NEPA)  was to prevent this kind of  destruction the Salem plant commits  against the aquatic life in the Delaware River.

On Dec. 18 2001  Congress allowed these once through cooling systems  so long as they agreed to “restore” the fish they killed.  PSEG embarked on such a  “habitat restoration program”. In the process to reduce the coverage  of phragmites in these wetlands  PSEG applied 22.000 pounds of herbicide to 2.500 acres of sensitive marshland. There is no “habitat restoration”.


Incredible as it seems PSEG announced that  it planned to spend  $50 million between 2007 and 2011 to explore the potential to construct a new reactor on the same Island


Frieda Berryhill



My private conversations with NRC officials after the formal hearing were very informative. To my surprise one  NRC Official  (Environmental Project Manager )

asked me to send him all the documents I have, including the pictures of toppled buildings (due to liquefaction )  and letter from NRC confirming my concern with the Islands soil condition.

My inquiry as to when PSEG is planning to go to Dry Cask Storage Mr Flicker Vice President of PSEG informed me that they have already started. This will come as a surprise to some of you.

 More on this, and its implication on my next e mail