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Technical Review of the National Pollutant
Discharge Elimination System Permit Renewal Application for the
Salem Nuclear Generating Station
New Jersey Department of Environmental Protection
The New Jersey Department of Environmental Protection
(NJDEP) Bureau of Point of Source Permitting retained ESSA Technologies
Ltd. to review portions of the Permit Renewal Application of the
Public Service Electric and Gas Company (PSE&G) for the Salem
Generating Station on the Delaware River. The focus of ESSA's assignment
was to review PSE&G's assessment as to whether technological
measures can be implemented at Salem station to reduce the numbers
of organisms that are impinged and entrained at the station each
year where the economic costs of the measures are not wholly disproportionate
to the benefits pursuant to Section 316(b) of the Clean Water Act,
33 U.S.C. Section 1326.
Three distinct analyses in the Application were
addressed by the review: 1) PSE&G's assessment of its compliance
with certain conditions of the 1994 Permit; 2) the costs and benefits
assessment of best technologies available to reduce entrainment
and impingement mortality caused by the Salem station; and 3) the
impact assessment of the station on fish populations and the Delaware
River ecosystem.
The review conducted an overall evaluation of
whether the conclusions reached by the Applicant for these different
analyses were accurate, complete, and appropriate given: 1) the
soundness of methodology; 2) the suitability of the data used in
the analyses; 3) the validity of assumptions used and inferences
drawn; and 4) the level of integration with other components of
the study.
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