Commission Secretary
Delaware River Basin Commission
P.O. Box 7360
West Trenton, NJ 08628-0360

Fax (609) 883-9522
Paula.Schmitt@drbc.state.nj.us

Subject: Public Comment On Exelon’s Limerick Nuclear Plant Docket

Having enough clean, safe water is vital to our lives. If Limerick Nuclear Plant operations dry up our groundwater or surface water resources, or our water becomes so radioactive it can’t be used safely, our homes become worthless and our businesses cannot remain viable.

The Delaware River Basin Commission (DRBC) DRAFT Docket for Limerick Nuclear Plant’s water use jeopardizes water resources in parts of six counties, just for the operations of one business, Limerick Nuclear Plant.

Most at risk are the almost two million people from Pottstown to Philadelphia who rely on the Schuylkill River for their water supply. With so much at stake for so many people, DRBC’s decisions clearly protect Exelon’s profits, not the public’s water.

DRBC’s 5-year docket jeopardizes public water resources with loopholes, exemptions, elimination of long-standing restrictions, and even less regulation. Despite evidence of unprecedented threats and harms, this DRAFT Docket will result in less protection for vital public water resources and health.

To Protect Vital Public Water Resources, Changes Needed To DRBC’s DRAFT Docket:

1. DO NOT APPROVE INCREASED WATER WITHDRAWALS For Limerick Nuclear Power Plant From Any Source. Public Water Resources Must Be Protected For All Other Users. DRBC should not allow Exelon to use any more water for Limerick Nuclear Plant operations at a time when we face increasing drought conditions and record heat waves.

REMOVE APPROVAL FOR INCREASED WATER WITHDRAWALS For Limerick Nuclear Plant
• 2 Million Gallons Per Day Increase From The Schuylkill River
INCREASE PLANNED 56.2 to 58.2 Million Gallons Per Day for Limerick Nuclear
Consider Schuylkill River Water Withdrawal Comparisons:
Pottstown 5 Million Gallons Per Day for 30,000 People
Norristown 17 Million Gallons Per Day for about 87,000 People
• 4.2 Million Gallon Increase As Needed – Perkiomen Creek via the Delaware River
• 7.2 Million Gallons Per Day Increase – Tamaqua’s Still Creek / Owl Creek Reservoirs
From 36 to 43.3 Million Gallons Per Day
• 446.4 Million Gallons Per Month – Unfiltered, Contaminated Wadesville Mine Pool Water
Into The Schuylkill At 10,000 Gallons Per Minute – Could Total Almost 4 Billion Gallons Per Year.

2. Stop toxic mine water pumping Into the Schuylkill, OR require Exelon to filter
Do not approve continued mine water pumping into the river unless Exelon agrees to filter the water. Pumping of almost ½ billion gallons per month of toxic unfiltered mine water into a drinking water source is unacceptable for water and health. Manganese is permitted at 80 times Safe Drinking Water Standards, and Iron 20 time Safe Drinking Water Standards.

3. Do not approve Limerick Nuclear Plant’s 5-year docket with no limit for Total Dissolved Solids (TDS) discharges from Limerick. To protect water and health, the docket must include the requirement for Exelon to filter TDS pollution from Limerick’s most dangerous discharge into the river – Outfall 001. Limerick Nuclear Plant cannot meet DRBC’s 1,000 mg/L discharge limit for the discharge pipe carrying radiation and cooling tower toxics into the river. This is cause to require filtration, not approve a docket that removes the limit. Public water companies do not and should not be expected to filter out all Limerick’s radionuclides and other toxics discharged into the Schuylkill River. The public should not have to pay more for their water.

4. Require Limerick to shut down when river temperatures exceed the 87 degree limit.
Since 1985, Limerick Nuclear Plant has overheated the Schuylkill River with over 5 billion gallons per year of discharges up to 110 degrees. Exelon’s testing at Royersford, just 2 miles downstream from Limerick’s discharges, proves the river is repeatedly exceeding 87 degrees.
 When the Schuylkill River 87 degree heat limit is exceeded at Royersford, DRBC must require Limerick to close, to stop Limerick’s heated discharges.

5. Require unannounced independent testing for flow, temperature, and all discharges.
Exelon’s track record here and elsewhere shows we can’t trust Exelon to provide full, accurate, and timely disclosure. Exelon controls all of the monitoring, calculating, testing, and reporting for Limerick. See www.acereport.org – Section 20 “Why We Can’t Trust Exelon”. This is about unprecedented threats to public water and health from Limerick Nuclear Plant. Independent data is imperative.
 DRBC collects millions in payments each year for our water, from Exelon for Limerick’s withdrawal from and discharges into the Schuylkill River. That money should be used for independent testing in all categories.

6. Eliminate unrestricted use, or ‘eminent domain’, of our water for Limerick Nuclear Plant. DRBC’s Docket gives Limerick Nuclear Plant unrestricted access to all water resources during a Limerick Nuclear emergency or meltdown, until it has been stabilized, regardless of the potential to render dry or otherwise unusable any well or surface water supply which is substantially adversely affected due to Limerick withdrawal.
 Limerick is required to have a 30 day water supply for emergencies. There is only enough water on-site for 48 hours and that includes cooling tower water. It is unacceptable for so many people to face such threats to their water supply. The potential for Limerick accidents or a meltdown is increasing. It is not acceptable to jeopardize the water supplies across six counties when there are far safer energy alternatives that won’t jeopardize our water supplies.

7. Require an independent mediator, NOT the DRBC Director, to hear and adjudicate all
water related claims against Limerick and Exelon In essence, the DRBC Director would have unilateral authority to recognize or reject any related water claims against Exelon and Limerick Nuclear Plant. DRBC’s Executive Director, could make a “Final Determination” regarding the validity of a complaint against Exelon, scope or sufficiency of such investigations, and the extent of appropriate mitigation measures required. DRBC’s executive director should not have authority to determine whether Exelon should be held accountable for repair, replacement, or extent of mitigation measures for dry or otherwise unusable wells or surface water supplies adversely affected. Victims without safe, usable water should not be forced to pay for the investigation and/or mitigation plan prepared by a hydrologist to be submitted to DRBC’s Executive Director.
 DRBC has been biased in docket decisions related to Limerick Nuclear Plant, and has repeatedly made decisions biased toward Exelon’s profits, not public water and public health.

8. Require public notice and input for all future Exelon requested water use for Limerick.
The public needs and deserves an opportunity to understand and comment on their water resources.

Please send written responses to each issue identified in my comments.

Sincerely,