Oyster Creek Nuclear Generating Station:
Ecological & Environmental Impacts

Oyster Creek Nuclear Generation Station (OCNGS), located in Lacey Township, NJ, is the oldest nuclear power plant in the nation, coming online in 1969, and will operate under its current license until 2009. Oyster Creek Nuclear Generating Station (OCNGS) seeks to extend its operating license for 20 years after it expires in 2009 and seeks to renew its pollution discharge permit that regulates the cooling water system.

Each day that OCNGS operates without the required cooling towers, 1.3 billion gallons of Barnegat Bay water gets sucked into and passes through its antiquated cooling system. This is 2.2% of the total volume of Barnegat Bay per day and over 790% of the bay per year. The nuclear plant is literally straining the life from Barnegat Bay.

The negative effects of this obsolete (1969) technology are documented:

Massive destruction of shellfish larvae, fish eggs, and plankton
Thermal pollution
Killing of endangered sea turtles
Large fish kills
Biocides released in the Bay.

When the plant automatically shutdowns for safety reasons, fish kills occur during cold weather due to the lack of warm water input to the Bay. In 2002, 5,876 fish were killed and the plant was fined $1 million ($170.18/fish) by the State of New Jersey. In 2006, 80 fish died and in Dec. 2007 another 5,304 were killed. The fine for 2006 and 2007 incidents was a slap on the wrist in comparison: $67,859 ($12.60/fish). In Nov. 2008, 38 more fish died following a shutdown. Cooling towers would prevent these fish kills and reduce the artificially high temperatures near the plant's current discharge area back to normal.

A closed-cycle system, also called a “closed-loop system,” draws water into plants for cooling and re-circulates it, expelling the heat through cooling towers. Some water must be replaced, but closed-cycle cooling reduces water intake by 95% and dramatically decreases the number of fish, eggs, and larvae that are destroyed by once-through systems by being entrained (sucked into system), impinged (pinned on screens), or fatally scalded. In the draft permit, NJDEP states “closed-cycle cooling is the only cooling water intake structure technology available to the facility to reduce entrainment.” Closed-cycle cooling systems are available technology.

OCNGS POLLUTES BARNEGAT BAY AND
DESTROYS MARINE LIFE

THE FACTS:

The current cooling system, a “once-through cooling system,” removes, on average, 1.3 billion gallons of life-rich estuarine waters from Barnegat Bay EACH DAY, close to 600 million gallons of which is then discharged as chlorinated, heated, lifeless water. The remaining 732 million gallons a day of estuarine water is mixed with this chlorinated, heated water.
NJDEP’s “Preferred Alternative” - Alternative # 1 - requiring a closed-cycle cooling system is the best alternative as it is the “best available technology.” (NJDEP issued a draft New Jersey Pollution Discharge Elimination System or NJPDES permit renewal.)
NJDEP’s Alternative # 2 (e.g., restoration and mitigation measures), is not acceptable as it will allow the continued destruction of marine life in Barnegat Bay. Alternative #2 is unacceptable since restoration measures HAVE NOT been proven to be effective in offsetting the loss of marine life from once-through cooling systems.
The installation of a closed-cycle cooling system will better protect, improve, and restore the health of Barnegat Bay. A closed-cycle cooling system will:

Save trillions of animals -- including 13 million fish and shellfish PER YEAR, such as blue crabs, striped bass, winter flounder, bluefish, grass and sand shrimp, blackfish, bay anchovies, menhaden, spot, and spearing.
Eliminate fish kills caused by thermal shock from the discharge.
Stop the dumping of up to 202 tons of toxic chlorine into the bay per year. Current allowable discharge levels are 20 times the lethal level of many estuarine organisms, including striped bass, bunker, and mummichogs (killis).
Create hundreds of jobs building the new closed-loop system.

Exelon (parent company of AmerGen, which operates the facility) has the financial resources to install a closed-loop system. According to Exelon, it is “one of the nation’s largest electric utilities with 5 million customers and $15 billion in annual revenues.” The company expects to “generate $3.7 billion of cash between 2004-2006 after funding capital expenditures.” Indeed, Exelon’s recent brochure states, “[w]e are a staunch protector of South Jersey wildlife and natural resources.”

Click here for a detailed position paper prepared by Clean Ocean Action.

Click here for additional information about this issue.

BACKGROUND

State "Green Lights" Oyster Creek Nuke Plant

Coastal advocacy groups denounced the New Jersey Department of Environmental Protection (NJDEP) for giving a “green light” to the continued operation of the Oyster Creek Nuclear Generating Station (OCNGS) in Lacey Township, NJ, the oldest operating nuclear power plant in the nation.

On December 28, 2007, NJDEP approved OCNGS’ coastal consistency request for the plant’s proposed re-licensing for 20 years. The OCNGS’ current license expires in 2009. In seeking a license extension, OCNGS must demonstrate that its continued operation is consistent with New Jersey’s Coastal Management Program.

This was the third attempt by OCNGS to gain consistency with NJ’s Coastal Zone Management Program. The NJDEP already denied consistency on August 19, 2005, and May 31, 2007. The NJDEP denied consistency on several grounds, including the lack of data on OCNGS’ impacts on marine fish and fisheries, adverse affects on endangered and threatened sea turtles, and the lack of a plan for public access to the waterfront. According to the coastal advoacy groups, OCNGS’ submissions fail to address impacts from killing endangered turtles, as well as fish and shellfish.

Federal Consistency - THREE TRIES!

Oyster Creek Nuclear Generating Station (OCNGS) seeks to extend its operating license for 20 years after it expires in 2009. As a result, OCNGS must demonstrate that its continued operation is consistent with New Jersey’s Coastal Management Program.

FIRST CONSISTENCY REVIEW REQUEST (2005)

In early 2005, Clean Ocean Action submitted comments on AmerGen's (the permittee) application to the NJ Department of Environmental Protection for a federal consistency application. The Coastal Zone Management Act (CZMA) requires that federal license applicants that conduct activities that could affect a state's coastal zone apply for a federal consistency certification. The applicant must certify that their proposed action is consistent with the state coastal zone management program.

In short, COA believed the application is premature, lacked the necessary data and information to allow the state to assess the project’s effects, and made incorrect assumptions of environmental impacts. Therefore, COA requested that the NJDEP deem the application incomplete and object to the Applicant’s federal consistency certification at this time.

On August 19, 2005, the DEP issued a finding that AmerGen's "request for for a federal consistency determination to be inconsistent with New Jersey's Coastal Management Program." In it's finding, the DEP echoed many of the concerns raised by COA in our comments. Follow this link to read the DEP's Inconsistency Determination, or call the COA Office and we will gladly fax, mail, or email a copy of the document to you.

SECOND CONSISTENCY REVIEW REQUEST (February 2007)

On December 1, 2006, AmerGen requested a new Federal Consistency Determination review from the DEP. This review is required for OCNGS’s efforts to re-license the nuclear power plant for another 20 years. Oyster Creek must show they do not violate any of the state’s environmental rules and regulations. COA and the Americal Littoral Society reviewed the application and supporting documents and submitted comments on how operation of the plant's once-through cooling system leads to unacceptable impacts on aquatic organisms that run contrary to current federal and state environmental regulations. Eight additional environmental groups signed on to our comments and copies were also sent to NJ DEP Commissioner Lisa Jackson, NJ DEP Coastal Management Office Manager Ruth Ehinger, the NJ Congressional Delegation and the Assembly Environmental and Solid Waste Committee. Click on this link to view a copy of our comments.

THIRD CONSISTENCY REVIEW REQUEST (November 2007)

The NJ Department of Environmental Protection (DEP) already denied a positive federal consistency determination twice (the latest being May 31, 2007). The DEP denied consistency on several grounds, including the lack of data on OCNGS’ impacts on marine fish and fisheries, adverse affects on endangered and threatened sea turtles, and the lack of a plan for public access to the waterfront. On September 13, OCNGS began submitting its response to DEP’s May 31 determination.

COA, the American Littoral Society, and Save Barnegat Bay submitted joint comments on this third consistency review with several important concerns. OCNGS’ submissions fail to address impacts from killing endangered turtles, as well as fish and shellfish. Click here for a copy of the groups’ comments.

Draft Generic Environmental Impact Statement for OCNGS

As part of the relicensing process, the NRC released a Draft GEIS for Oyster Creek and public comment was accepted in 2006. Clean Ocean Action submitted joint comments with Americal Littoral Society criticizing the fact that the Draft GEIS failed to take a hard look at the environmental consequences of the proposed relicensing. The draft GEIS cites out-dated studies with glaring deficiencies, contains conclusions that are inaccurate, inappropriate and unscientific, and mentions some environmental impacts in passing while failing to even mention others at all. In addition, the Draft GEIS does not adequately review the implementation of a closed-cycle cooling system as an alternative to the present once-through system that is responsible for killing billions of marine organisms every year. COA and ALS believe the NRC's determination that continued operations of the plant will only result in small impacts and that no viable alternatives exist, are not valid, insufficiently demonstrated and unsupported by factual information.

COA and ALS were not the only groups that disagreed with conclusions and impact assessments made by the NRC in the draft GEIS for Oyster Creek. Comments were submitted by the US EPA, NOAA/National Marine Fisheries Service and NJ DEP that mirrored many of the comments submitted by COA/ALS, including support for the conversion of the plant's current once-through cooling system to a closed-cycle cooling system in order to substantially reduce the plant's impact on aquatic organisms. Click on the links below to view each agencies comments, as well as the NRC and AmerGen's (OCNGS owner) response to the comments submitted by NOAA.

New Jersey Pollution Discharge Elimination System Permit

The NJDEP issued a draft New Jersey Pollution Discharge Elimination System (NJPDES) permit renewal to Oyster Creek Nuclear Generating Station on July 19, 2005. Comments on the draft permit, after two extensions, were due November 21, 2005. Joint comments were submitted by Clean Ocean Action, the American Littoral Society, Save Barnegat Bay, Jersey Coast Anglers Association, Fisherman’s Dock Co-op, Inc., NJ Beach Buggy Association, Garden State Seafood Association, and several other groups and individuals (the “Undersigned Parties”) having particular interests in the preservation and protection of the Forked River, Barnegat Bay, Oyster Creek, the surrounding estuary, and their resources. Clean Ocean Action also presented testimony to the NJDEP regarding the draft NJPDES permit.

In short, the groups support the New Jersey Department of Environmental Protection’s Preferred Alternative (Alternative 1), the installation of a closed-cycle cooling system, and object to the use of restoration as a compliance measure (Alternative 2).

Public Hearings

The NJ Assembly Environmental and Solid Waste Committee convened two public meetings in February 2005 to accept testimony on the proposed re-licensing of the Oyster Creek Nuclear Generating Plant in Lacey Township, NJ. Clean Ocean Action has attended these meetings and presented testimony and a position paper focusing on the marine degradations caused by the plant.

Clean Ocean Action is focused on the imminent proposal to renew the plant’s NJ Pollution Discharge Elimination System (NJPDES) permit for its once-through cooling system. COA's testimony outlines concerns with the significant ecological impacts of this system on the marine environment. These impacts include impingement (the trapping of organisms too large to pass through the screens), entrainment (organisms small enough to pass through the screens enter the cooling system where they are subjected to numerous and potentially fatal insults), thermal and pollution discharges, and chlorination.