Jennifer Fields, Clean Water Management Program Manager
PA Department of Environmental Protection
2 E. Main Street
Norristown, PA 19401
Jefields@pa.gov
RE: Limerick Nuclear Plant’s NPDES Permit No. PA0051926
Dear Ms. Fields,
DEP’s mission is to protect public water and public health. We have a right to clean water under Clean Water Laws, which DEP should be enforcing. DEP’s NPDES permits are permits to pollute our water.
Limerick Nuclear Plant’s discharges (5 billion gallons per year), are by far the worst threat to the Schuylkill River and public health because they include a broad range of radionuclides, some with very long half-lives.
Loopholes and exemptions in Limerick Nuclear Plant’s DRAFT NPDES permit ignore Limerick’s most dangerous discharges into the Schuylkill River, a vital water resource for almost two million people from Pottstown to Philadelphia. Harmful impacts from Limerick Nuclear Plant’s discharges on our water and health do not disappear because DEP allows permit loopholes and exemptions.
To protect Schuylkill River water and health of almost two million people, I urge DEP to make the following changes to the DRAFT NPDES permit for Limerick Nuclear Plant:
Changes Needed to DEP’s DRAFT NPDES Permit Include:
1. Remove the permit EXEMPTION for Total Dissolved Solids from Outfall 001
Justification:
• Outfall 001 TDS transports radiation and cooling tower toxics, Limerick’s most dangerous pollution into the Schuylkill River.
• The Safe Drinking Water TDS limit is 500 mg/L. DEP and Exelon both admitted Limerick can’t meet Limerick’s previous limit of 1000 mg/L. Previous discharges were up to over 2,400 mg/L. Exempting this harmful pollution because Limerick can’t meet the limit is negligent.
• With NO TDS permit limit, Limerick circumvents enforcement of Safe Drinking Water standards under Clean Water Laws, while continuing to seriously jeopardize water and health.
2. Require Exelon to FILTER TDS from Outfall 001 with reverse osmosis or CLOSE Limerick.
Justification:
• Limerick routinely discharges a broad range of radionuclides, including Iodine-131, Cesium-137, and Strontium-90, into the Schuylkill River with TDS discharges. There is no safe level of exposure according the National Academy of Sciences. Added, cumulative, and synergistic impacts while unknown, are obviously significant.
• DEP can reduce Limerick’s radioactive discharges by requiring TDS filtration. While filtration could be expensive for Exelon, radioactive contamination of vital water supplies could be far more costly to the public.
3. Conduct independent, comprehensive monitoring
Justification:
• All monitoring, testing, and reporting are controlled by Exelon, a company that has repeatedly proven here and elsewhere, that it can’t be trusted to provide full, accurate, and timely disclosure.
• DEP’s monitoring requirements for Limerick Nuclear Plant are woefully inadequate. For example:
2 times a month for Outfall 001 and NOT for radiation and some cooling tower toxics in TDS,
1 time a year for all other 23 discharges, directly and indirectly, into the Schuylkill River.
• If DEP doesn’t have the funding for meaningful oversight, Limerick should close.
4. Require Exelon to maintain all records permanently, not just 3 years.
Justification:
• Records should be put into electronic files with back-up CDs that should be maintained until the completion of decommissioning.
5. Require IMMEDIATE PUBLIC NOTIFICATION of radioactive spills
Justification:
• Unless the public is notified immediately, people are not given an opportunity to avoid exposure to accidentally increased radioactive exposure.
• The public was not notified until 23 days after Limerick’s 3-19-12 radioactive “spill”. Public health was jeopardized. Notification needs to be immediate, not just to DEP, but also for the public.
Please provide detailed responses to each of my specific requests for changes which would result in reduced threats to public water and health, related to Limerick Nuclear Plant’s NPDES permit.
Sincerely,