Cooling Tower Deja Vu

The Original Sin of The Green Weenies?

“The past is never dead, it’s not even past” (Wm. Faulkner)

[Updated with End Note]

Tom Johnson at NJ Spotlight has a story today on the long running Salem nuclear power plant cooling tower issues, see:

• DEP TO ISSUE DRAFT WATER PERMIT FOR PSEG’S SALEM NUCLEAR POWER PLANT

I was struck by how Tom so vaguely alluded to the history, a controversial issue he covered at the time for the Star Ledger and surely must recall

At one time, the DEP ordered PSEG to install expensive cooling towers to reduce fish kills, a strategy favored by environmentalists. That decision was later reversed by a subsequent DEP commissioner.

Seeing that I once worked for both those DEP Commissioners – and was fired by the one who reversed the cooling tower requirements way back in July 1994, his name is Bob Shinn –  I thought I’d provide just a little bit of history on the Whitman Administration’s deletion of the prior DEP cooling tower requirements (virtually the same pattern of the Corzine Oyster Creek and Christie cooling tower reversal, no?).

William Faulkner once said: “The past is never dead, it’s not even past”.

Faulkner sure was right, because we are still dealing with this history, most recently on the open space ballot question, where some of the same organizations and individuals (ahem, green weenies) undermined environmental regulation and Clean Water Act programs for some of the same corrupt reasons.

So here is the DEP response to comments document on the NJPDES permit – read the whole thing to get an understanding of the green weenie sell out.

Comment #6 came from those who supported cooling towers as required by the Clean Water Act.

But there were several prominent individuals and organizations who did not join that comment.

First I will provide the text of the comment, then the list of those not supporting cooling towers:

Comment 6

Several commentors state that NJDEP should require PSEG to comply with Section 316(b) of the Clean Water Act and build cooling towers, which are best technology available. Several commentors suggest that PSEG be required to install dry-cooling. One commentor states that NJDEP has not provided the requisite legal justification for its failure to require cooling towers or dry cooling. Because cooling towers would reduce the fish kills by 95% and dry cooling could reduce the fish kills by over 99% these technologies represent “best technology available for minimizing adverse environmental impact”. One commentor states that there is no reason why Salem Units 1 and 2 can not be retrofitted with cooling towers. (Commentors 6, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 25, 29, 31, 36, 37, 38, 39, 40, 41, 43, 44, 45, 46, 47, 48, 53, 54, 55, 56, 59, 60, 63, 64, 65, 67, 68, 72, 73, 74, 75, 85, 86, 92, 94, 98, 105, 118, 119, 121, 122)”

[Note the absence of any green weenies here]

Those who commented on the permit but did NOT support cooling towers and instead supported the PSEG EEP were (commenter number next to individual – see comments below that show commenter number)

• Franklin Parker, Trust for Public Land (#7)
• Dave Moore, NJCF (#27)
• Julia Somers, GSWA (#30)
• Richard Sullivan, “consultant” (#52)
• Rich Kane, NJ Audubon (#108)
• Maureen Ogden (#23)
• Ella Filipone, PRC (#4)
• (where was Mike Catania hiding? He did not comment, but was deeply involved in the original 1994 permit compromise)

We are still dealing with this history, most recently on the open space ballot question, where the same organizations undermined environmental regulation and clean water act programs.

[End note: when I say “corrupt reasons” I am referring to this: – in reviewing these comments, ask yourself why someone from the Great Swamp Association, with no expertise on the issues and no cooling tower issues in her watershed, why would they support a PSEG project in the Delaware Bay? Why would land trusts support a PSEG water pollution control permit? Why would a “river coalition” support a PSEG discharge permit that kills billions of aquatic life and fish in the river?

CORRUPTION, that’s why.

Comment 9

Numerous commentors state that NJDEP is allowing PSEG to engage in experimentation, mitigation and other programs that do nothing to reduce the fish kills but have become an integral part of the company’s marketing plan. One commentor states that no amount of strobe lights, sound deterrents, experimental marsh building, fish ladders and scientific studies deal with the problems of once- through cooling. Some commentors state that the wetlands mitigation experiment, fish ladders and bay-wide monitoring program are not technologies applicable to the cooling water intake structure and therefore do not fulfill the requirements of Section 316(b). One commentor requests that NJDEP not allow any more experiments that do not represent proven technology at the intake structure. Some commentors state that the EEP should not be accepted as a trade-off for cooling towers. (Commentors 36, 37, 38, 39, 40, 41, 44, 45, 46, 47, 48, 64, 65, 68, 86, 98, 99, 119)

[Note above the absence of green weenies here]

[Note below how now the green weenies comment in SUPPORT of PSEG’s plan EEP]

Comment 23

Several commentors state that the EEP is a reasonable alternative to the cooling towers that were originally proposed for the Salem Plant. One commentor states that although it is troubled that the Salem units were able to be constructed without cooling towers, the EEP is a positive response in trying to compensate for the ecological damage caused by the Salem units. Another commentor states that new cooling towers would have functioned for a limited number of years whereas the life of the restored wetland will be infinite. Another commentor states that although it recognizes cooling towers are probably BTA, such an investment is not going to happen today if it did not happen in 1994. Therefore, an alternate means to provide protection for fish and other aquatic life in the estuarine system is in order. (Commentors 7, 22, 23, 66, 71)

Comment 25

Many commentors express support for the EEP, given its lasting impact on the ecosystem, and make specific note of the magnitude of acreage included in the EEP. One commentor states that the creation and improvement of healthy and thriving wetlands and uplands are very worthwhile undertakings for the continued protection of the fish population. Several commentors state that the EEP is a model for other NJPDES permits. Some commentors state that those who drafted the 1994 permit conditions were thinking about the well-being of the entire estuary and that the proposed permit represents bold thinking in resource management. One commentor states that the effects of the Station will be short-lived as compared to the permanent protection of the Delaware Bay environment by the renewed permit conditions. Another commentor states that the restoration sites and adjoining uplands are protected by law and will continue to benefit fish and wildlife and be enjoyed by people long after the generating station is retired. One commentor states that the EEP is a showpiece of environmental sensitivity and practicality and a bright example for the nation. (Commentors 3, 4, 7, 22, 27, 34, 42, 49, 57, 71, 79, 81, 104, 111, 120)

Comment 27

Many commentors state that the EEP provides research benefits. Several commentors recognize the advancements in science and understanding of marsh ecology as a result of the EEP; the EEP has proven that coastal wetlands can be restored on a large scale basis. One commentor states that it is one of the most important projects in the nation due to the severely degraded conditions of the lands restored as well as the large scale of the ecosystem. Another commentor states that through its work in the EEP, PSEG has advanced the science of marsh studies and their conservation that will benefit others to further scientific knowledge of salt marsh restoration. One commentor states that the wetland restoration program with its successes and failures, can instruct those who want to move ahead with wetland improvements in other places in NJ. Another commentor expresses appreciation for the research reports and definitive studies that have resulted from the EEP. The EEP teaches us how to work with nature on such restoration projects. This information will serve the entire world in the decades to come. One commentor states that research and monitoring funded through the EEP has resulted in new and improved insights into marsh function and structure that can be applied throughout the nation. This commentor further notes that the EEP is serving as a model to other major wetland initiatives through a scientific workshop. (Commentors 3, 5, 22, 30, 34, 49, 52, 71, 76, 78, 80, 90, 109)

Comment 28

Several commentors indicate that PSEG is acting in good faith with respect to the EEP and/or other permit conditions. Several commentors note the outstanding effort PSEG has expended with respect to the EEP. Several commentors commend PSEG for the scientific expertise employed. Another commentor compliments the company and the EEP staff. Their demeanor, sincerity and willingness to be involved and helpful has positively impressed those who have worked closely with the staff. Several commentors, all of whom live in or are affiliated with townships that contain EEP sites, express gratitude for the EEP and for their good relationships with PSEG. One commentor commends PSEG for being beneficial stewards of the land. Another commentor states that PSEG kept its promises from 1994 to improve the Delaware Estuary and the citizenry who live, work and recreate here. (Commentors 4, 21, 22, 23, 28, 30, 32, 76, 80, 82, 84, 93, 96, 97, 101, 109, 110, 123)

Comment 38

Several commentors note that the restoration at the Maurice River Township (MRT), Dennis Township and Commercial Township formerly diked salt hay farm sites give evidence of being an impressive success. One commentor states that the restoration at these sites have resulted in dramatic changes and a mosaic of new habitats are emerging. Another commentor states that the restoration at these sites has restored the connection of these lands to the Bay thereby increasing production of valuable biological components, and that these marshes appear to be returning to a very productive level for fish habitat and reproduction. One commentor states that the restoration of these sites have exceeded his expectations. Another commentor states that as a local landowner near the MRT sites, he reports that there have been no negative impacts. Another commentor suggests that full acreage credit be awarded to PSEG under the permit for these three sites. (Commentors 22, 23, 30, 32, 78, 84, 90, 108, 111, 120)

Comment 44

Several commentors note that PSEG has successfully preserved the Bayside Tract and other uplands. The preservation of the Bayside Tract and other uplands are important. One commentor notes that the protection of this site from development is particularly important since it is adjacent to some of the most productive oyster beds in the Delaware Bay. Another commentor suggests that full acreage credit be granted for this site. (Commentors 28, 30, 78, 84, 111)