Why NRC’s Draft Environmental Impact Statement for Limerick Nuclear Plant Is A Whitewash!

NRC is further jeopardizing the entire Philadelphia Region for generations to come by its unsubstantiated, inaccurate conclusions in the May 2013 Limerick Nuclear Plant DRAFT Environmental Impact Statement (EIS).

To date, our elected officials continue to remain silent, failing to speak up to protect our health and safety related to Limerick Nuclear Plant’s serious radioactive threats to our health, environment, and future and from unprecedented threats to our drinking water supplies across six PA counties and massive cooling tower air pollution. There has already been a documented cancer crisis since Limerick started operating in 1985. Our elected officials can no longer afford to put on blinders and silently allow these harms to our environment and residents to continue. We must demand protective action now from our elected officials.

ACE and others are requesting a U.S. Congressional investigation into NRC’s regulatory negligence, failure to enforce its regulations, and unacceptable rush to facilitate relicensing of Limerick Nuclear Plant. NRC has violated its own mission in failing to protect the environment and public health for millions of Philadelphia region residents in their shocking and shameless Draft EIS for Limerick.

We urge you to review statements made on behalf of public interests below, then talk to your local, state, and federal officials to support a Congressional investigation. Your health, safety, and financial interests are at stake. It’s about your future and that of future generations.

May 23, 2013 the Nuclear Regulatory Commission held a public hearing for the public to make on-the-record comments on NRC’s DRAFT Environmental Impact Statement (EIS) for Limerick Nuclear Power Plant relicensing.

Due to the time constraints placed on public comment by NRC, Alliance For A Clean Environment (ACE) members presented different testimonies at the 2:00 and 7:00 P.M. sessions.

The testimonies provide a summary on major problems and issues related to what is clearly an NRC whitewash that will further jeopardize everyone in the Greater Philadelphia Region.

Below are testimonies from Dr. Lewis Cuthbert, ACE President, followed by Donna Cuthbert, Betty Shank, Charlie Shank, and Lorraine Ruppe.

Following ACE members’ statements are summaries of testimonies from Paul Gunter, from Beyond Nuclear, and Scott Portzline, fromTMI.

May 23, 2013
To: Nuclear Regulatory Commission
From: Dr. Lewis Cuthbert, President
Alliance For A Clean Environment
1189 Foxview Road
Pottstown, PA 19465
Re: 2:00 P.M. Session Testimony on Limerick Nuclear Plant’s
Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

Members of ACE have reviewed the 585 page NRC Environmental Impact Statement (EIS) for the Limerick Nuclear Plant. You should be ashamed of this flawed and biased report. The document is incomplete, unreliable, and invalid.

Your EIS is riddled with faulty assumptions, unsupported conclusions, glaring omissions, exemptions, delays and deferrals of vitally important and necessary actions, and exclusions of numerous environmental factors that will have adverse implications for generations. NRC’s callous disregard for public health and safety is shocking. You are guilty of nothing less than regulatory malpractice.

This public meeting/hearing has been sprung like a trap on our community. ACE objects to NRC proceeding on this EIS at this time, with important questions and issues not yet addressed or answered. There is no need, when Limerick’s current licenses do not expire until 2024 and 2029. NRC has failed to acknowledge or respond in writing to substantial written testimony submitted by ACE in October 2011 on fourteen major categories. Attached to, and part of this testimony, are photos of ACE display boards about some of the issues unanswered by NRC.

NRC also failed to adequately respond to additional questions submitted by ACE at your March 2013 annual Limerick performance review meeting for 2012 operations. Many of the serious, and still unaddressed concerns will be articulated in testimony presented and submitted by ACE members today. Although we received a response from NRC, most of the vague responses failed to adequately answer our questions.

The NRC is recklessly placing “the cart before the horse” in this matter. NRC must stop and delay all activities and actions related to Limerick Nuclear Plant relicensing, including finalizing this EIS, until AFTER:

1. Limerick’s Emergency Evacuation Plan has been revised to include
-Immediate notification of radiation releases through independent monitoring and reporting
-Expanding the Evacuation Zone to 50 miles
-Expanding the Ingestion Pathway Zone to 100 miles

2. National Resource Defense Council (NRDC) legal action appeals on Limerick’s Severe
Accident Mitigation Analysis (SAMA) Requirements have been resolved. NRDC believes
that after Fukushima, involving reactors similar to Limerick’s, that we should not rely on
decades-out-of-date safety analysis.

3. Exelon has completed all needed inspections, maintenance and corrective actions at
Limerick Nuclear Plant, that have been deferred until between 2017 and within 6 months of
the expiration of the current license in 2024

4. NRC’s court-ordered high level radioactive waste study has been completed (2014 or later),
and all waste storage issues and rules are in effect, including for Limerick

5. Earthquake Mitigation Plans have been completed (2017), and all necessary changes have
been made at Limerick

6. NRC required vents have been installed to prevent radioactive hydrogen gas buildup and
explosions (2017)

7. Exelon installs filters for the vents to minimize radiation releases during meltdowns. NRC
staff concluded the consequences of not installing filters could be so bad that filters should
be required regardless of costs.

8. Exelon installs filtration for Limerick’s water intake, to reduce harmful air pollution from the
cooling towers

9. Exelon installs filtration for Limerick’s radioactive and toxic wastewater discharges, to reduce
contamination of a drinking water source for almost two million people

10. Exelon installs filtration for toxic mine water pumped into a drinking water source, to operate
Limerick Nuclear Plant

This premature and incomplete EIS is a pathetic example of the lack of courage and integrity at the NRC You have abandoned and violated your own mission to protect public health and safety. You have betrayed this entire region, once again. NRC’s failure to protect our environment and residents is irrefutable evidence that you no longer have a moral compass.

Your rush to rubber stamp Limerick’s EIS and license renewals is a cowardly betrayal of every man, woman, and child in this community, as well as future generations that will unquestionably be harmed by twenty additional years of operation at Limerick Nuclear Plant.

It is our conclusion and recommendation that the U. S. Senate should investigate the NRC for willful blindness and regulatory malpractice, and disallow or forbid all permitting decisions for Limerick Nuclear Plant, until all unresolved findings, legal issues, and recommendations from NRC’s own staff are finalized and implemented.

ACE is formally requesting that NRC hold a public hearing in Pottstown, to address all of the relicensing issues for Limerick Nuclear Plant not specifically or adequately addressed in the Environmental Impact Statement.

Our community deserves nothing less.

May 23, 2013
To: Nuclear Regulatory Commission
From: Dr. Lewis Cuthbert, President
Alliance For A Clean Environment
1189 Foxview Road
Pottstown, PA 19465
Re: 7:00 P.M. Session Testimony on Limerick Nuclear Plant’s
Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

Throughout this ludicrous Environmental Impact Statement (EIS), NRC has persistently understated, minimized, or denied the documented evidence of harms from Limerick Nuclear Plant. Your pro-nuclear industry bias is both unmistakable and shameful.

In Section 9.3.1 of your EIS, you admit that, “During nuclear power plant operations, workers and members of the public would face unavoidable exposure to radiation and hazardous toxic chemicals.” Despite this fact, NRC has actually suggested in this repugnant EIS that all of the environmental harms from Limerick are small, and have no measurable impacts. Nuclear power plants are the only facilities with the capability of rendering entire regions uninhabitable for decades, if not centuries, in the event of a radiation disaster. For NRC to claim that all power generating facilities generate similar wastes is a lie. You stated, “The generation of spent fuel and waste material, including low-level radioactive waste, hazardous waste, and nonhazardous wastes would also be generated at non-nuclear power generating facilities.”

NRC staff also concluded that cumulative impacts from Limerick’s license renewal would be small for all areas except aquatic ecology and terrestrial ecology. That conclusion is patently absurd.

You arrogantly and irresponsibly dismiss the harms, risks, and threats from Limerick as callously as you consider the members of our community to be acceptable collateral damage. You should be ashamed.

Even more astonishing, NRC staff concluded that continued operation of Limerick Nuclear Plant would have less environmental impacts than either solar or wind alternatives on air quality, groundwater, surface water, human health, and aesthetics. Such conclusions are beyond untenable and unscientific. They bring new meaning to the term hubris. These ludicrous conclusions by NRC staff are laughable, and sufficient to reject the Limerick EIS as having zero credibility.

In Section 9.3.2 of your EIS, NRC states, “After decommissioning these facilities and restoring the area, the land could be available for other productive uses.” This is a delusional conclusion worthy of no less than four Pinocchios! This is the same land that Exelon claimed was worth zero when it fought to avoid paying its fair share of property taxes for years. Consider this alternative – the only acceptable use of this site after decommissioning to members of our community would be as a regional NRC office.

NRC has utilized a “checklist mentality” approach throughout this EIS. Limerick’s Evacuation Plan is a perfect example. Exelon was required to have an update to its plan on file with NRC by 2011. The document was finally submitted to NRC in December 2012.

Analysis of Exelon’s Evacuation Time Estimate (ETE) for Limerick Nuclear Plant’s Plume Exposure Pathway reveals the update is based on unrealistic, unworkable suppositions, assumptions, inconsistencies, inaccuracies, and illogical conclusions. NRC refused repeated requests to meet to review our detailed analysis of Exelon’s fatally flawed report.

Even more shocking was the admission by NRC officials that they had no need or intention to review, evaluate, or approve Exelon’s ETE. The report was turned in – check, and good enough for NRC. Every elected official in the region should be alarmed. Exelon’s ETE should be rejected by elected officials and NRC.

This EIS for Limerick Nuclear Plant is an insult to our community. Unsupported conclusions appear to fit your predetermined decision to use your infamous rubber stamp and approve an EIS that will facilitate relicensing of Limerick. The narrative simply does not comport with reality and documented facts in many areas. This biased EIS is invalid, detached from reality, and unacceptable. NRC has now lost all credibility in our community.

It is painfully evident that NRC has become a cowardly agency, unwilling to implement or enforce minimal protection of the public, despite readily available scientific evidence and well documented harms. Sadly, you choo se to be a subservient lapdog to the nuclear industry, rather than a vigilant watchdog protecting public interest. Only willful blindness could explain this EIS for Limerick Nuclear Plant, which is nothing less than a whitewash of epic proportions.

Our community deserves nothing less.

To: NUCLEAR REGULATORY COMMISSION
From: Donna Cuthbert, Pottstown, PA 19465 aceactivists@comcast.net
Re: May 23, 3013 2:00 P.M. Testimony
Limerick Nuclear Plant’s Environmental Impact Statement NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

NRC’s Environmental Impact Statement makes illogical, inaccurate, absurd, and indefensible claims. Calling Limerick’s environmental impacts “small” is an offensive lie.

NRC failed to honestly assess Limerick’s past, current, and additive harms since 1985. NRC did no testing. ACE repeatedly requested comprehensive independent monitoring and testing for this EIS. Instead, we got a despicable whitewash.

ACE documented how and why Limerick Nuclear Plant presents unprecedented environmental threats and health harms to our region in written testimony presented to NRC in October, 2011. Based on that, we reject NRC’s invalid unsubstantiated prediction of ‘small’ future harms from Limerick.

NRC failed to respond to our massive documentation. Would acknowledging facts require NRC to close Limerick? NRC wouldn’t give ACE one hour for a meeting with NRC’s Environmental Review Team. NRC clearly doesn’t want to face the facts. ACE display boards at this meeting are intended to identify significant harms NRC chose to ignore for Limerick’s DRAFT EIS.

ACE analyzed Limerick’s air and water pollution permits, and Exelon’s Radiological Monitoring reports which document enormous harms. NRC’s PR people are embarrassingly uninformed about Limerick’s air and water pollution. Instead of giving ACE an hour, NRC met with agencies that just issued 5-year pollution permits with exemptions for high levels of dangerous pollution in violation of protective laws.

Radiation reports for Limerick confirm many radionuclides are in our air, water, milk, soil, sediment, and fish. Yet, NRC keeps claiming Limerick’s radioactive releases are just tritium. Over 100 radionuclides are associated with Limerick operations. NRC looks foolish. One Limerick radionuclide is confirmed in the baby of our children at some of the highest levels in the nation.

Additive, cumulative, and synergistic harmful impacts since 1985 are unknown, but clearly enormous. NRC never did independent testing for each radionuclide or toxic chemical in each route of exposure.
• NRCs EIS conclusions rely on self-serving biased calculations, estimates, monitoring, and reports totally controlled by Exelon, the company
with a vested interest in the outcome, that has shown it can’t be trusted.
• Exelon’s deceptive radiation monitoring tactics were identified by ACE. Included:
(1) Radwaste monitoring declared inoperable for over a year (June 08 to July 09)
(2) Exemptions from reporting using lame excuses like misplaced monitors.
• To base EIS conclusions on visual site inspections is ridiculous! You can’t see, smell, taste, feel, or measure radiation or other toxics
released off-site.

Facts confirm Limerick’s environmental harms are enormous, not small.

1. Limerick is a major air polluter under health based standards of the Clean Air Act, releasing so much air pollution from the cooling towers, a
six-fold increase was granted in 2009 for the kind of air pollution that’s more deadly than ozone

2. Limerick’s PM-10 air pollution transports cooling tower toxics, pathogens, and radionuclides into our air every day with 44 million gallons of
steam. NRC must be aware that Exelon refused to install cooling towers at Oyster Creek, citing too much air pollution as the excuse.

3. Limerick is slowly but surely destroying the drinking water source for almost two million people from Pottstown to Philadelphia.
– Limerick discharges 14.2 million gallons of radioactive, heated wastewater every day.
– Limerick drastically exceeds Safe Drinking Water Standards.
– Without filtration Limerick can’t meet limits and Exelon won’t pay to filter.

4. The river water, sediment, and fish are contaminated with many radionuclides. That includes radioactive iodine-131 like that in Philadelphia’s
drinking water plus many others. It’s not just tritium as falsely claimed.

5. Limerick discharges are overheating the Schuylkill River, threatening the ecosystem. Limerick discharges up to 110 degrees into a river with an
87 degree limit every day.

6. Cooling tower water use threatens drinking water supplies across six counties.

7. Cooling towers depleted the Schuylkill River since 1985. By 1999, there were record low flows.

8. Since 2003, Exelon pumped billions of gallons of toxic unfiltered mine water into the river for Limerick operations.

9. Decades of radioactive leaks and spills contaminated groundwater.
- Only 15 monitoring wells on 600 acres are inadequate to know how many residential wells might already be radioactive.
- Radioactive leaks and spills were never cleaned up.
- 2009 radiation monitoring reports show;
 - 15 of 15 wells detect beta radiation
 - 9 detected alpha radiation
 - 3 detected gamma radiation
 - 4 detected uranium 233/234

NRC’s offensive EIS whitewash must be rejected.

May 23, 2012
To: Nuclear Regulatory Commission
From: Donna Cuthbert, Pottstown, PA 19465
Re: 7:00 P.M. Testimony
Limerick Nuclear Plant’s Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

For an agency mandated to protect public health from Limerick Nuclear Plant operations, NRC’s mindset and insistence on repeatedly denying reality is intolerable.

NRC’s denials protect Exelon’s profits and NRC jobs, but allow more people to become tragic victims of Limerick Nuclear Plant’s radiation and other toxic releases. Sadly, NRC is infested with conflict of interests which are leading to lies that will further jeopardize everyone in our region.

NRC obviously ignored documented evidence of environmental and health harms compiled and submitted to NRC for this EIS in 2011 from ACE. This evidence of harm should have been alarming, even to NRC.

NRC did NO radiation monitoring or testing for this EIS. In reality, NRC has no idea how much radiation is released from Limerick.

Based on flawed and outdated theoretical models for radiation exposure, which only measure external doses, and ignore internal doses, NRC shamefully continues to absurdly claim Limerick’s radiation releases are safe.

“Permissible” does not mean safe. In 2005, the National Academy of Sciences BEIR VII report said there is no safe. Dr. John Gofman, once head of AEC’s Lab, raised dire warnings about permitted releases from nuclear plants. He published research showing an estimated 32,000 Americans would die each year from fatal cancers induced by “allowable” radiation releases. Gofman said, “the entire nuclear power program is based on a fraud, that there is a permissible dose that wouldn’t hurt anyone.

We provided NRC with evidence showing communities around Limerick already exacted a high public health toll since Limerick started operating. A cancer crisis has been documented by PA Cancer Registry Statistics and CDC data.

Cancer rates skyrocketed far above the national average after 1985, when Limerick started releasing radiation into our air, water, soil, and people. Links to Limerick are clear. Limerick routinely releases radiation. Radiation causes cancer. We have a cancer crisis and one of the largest relays for life anywhere.

The upward trend in childhood cancer rates provides the most tragic link. By the late 1980s childhood cancer rates climbed to 30% higher than the national average, 60% higher in the early 1990s, and a shocking 92.5% higher in the late 1990s.

Infant and neonatal mortality rates are far higher than the state average, and even higher than Philadelphia and Reading (reported by EPA in 2003).
Studies provide a link. When nuclear plants open infant mortality rates go up. When they close rates go down.
Autism rose a whopping 310% (1990 to 2000).
Learning disabilities increased by 94%, a rate double the state increase. (1990 to 2000)

Strontium-90 Radiation Is An Undeniable Link.
Limerick releases Strontium-90. It’s in our air, water, and soil.
Strontium-90 is documented in the baby teeth of children at some of the highest levels in the nation.
NRC shamefully tried to blame decades old bomb testing far from our region.

Many Cancers Rose Dramatically by the Late 1990s. Examples include:
128% increase in Thyroid cancer
91% increase in Multiple Myeloma
61% increase in Breast cancer with rates far higher than the national average in every age group – 51% higher in women 30 to 44..
48% increase in Leukemia and almost double the state average

Limerick Nuclear Plant is clearly a major factor in the tragic and costly health crisis around it, with children the most profoundly impacted victims.

Exposure to Limerick’s radiation is an unavoidable and intolerable injustice.
We can’t see, smell, taste, or feel it, but it’s everywhere. We can’t avoid it.

As long as Limerick Nuclear Plant continues to operate, radiation and other dangerous toxics will be released into our air and water and more people will suffer needlessly.

We have lost patience with NRC’s lies, cover-ups, and negligence.

NRC should close Limerick now to protect public health. It’s time to stop unnecessary exposures and associated suffering and health care costs due to Limerick operations.

May 23, 3013
To: Nuclear Regulatory Commission
From: Betty Shank, Pottstown, PA 19464
Re: Comments: Limerick Nuclear Plant’s Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

NRC’s job is to protect the public, but it has never acknowledged the astronomical costs and the lack of benefits for the public that result from Limerick nuclear operations.
As taxpayers and ratepayers, the public does not benefit from Limerick nuclear energy because Exelon makes its enormous profits while the public pays the lion’s share of its business costs in one of the biggest corporate welfare schemes ever. Public costs include:

1. Construction costs: The enormous costs were attached to electric rates that climbed to 55% above the national average.
2. Property and school taxes: Exelon refused to pay its fair share for years. Eventually a settlement was reached and Exelon now pays around $3
million a year, but that’s a pittance compared to the $17 million it should have been paying each year all along.
3. Avoidable Diseases: Cancers and other illnesses in this region are much higher than the national average and are linked to Limerick’s
radiation. The cost for one six-month-old child diagnosed with cancer and treated for just two years is over $2 million.
4. Water Contamination: Limerick’s toxic and radioactive wastewater discharges cost water companies and their customers more. Exelon should filter to
protect public health.
5. High-level Radioactive Waste Storage: Tons are produced at Limerick every year, remaining deadly virtually forever. The public cost is in higher
taxes to store it at Limerick.
6. Decommissioning: is funded through hidden charges in our electric bills. Through miscalculation on Exelon’s part, $100 million more will be
needed for Limerick, which Exelon wants ratepayers to fund. Exelon makes mistakes, and we pay for them.

Exelon hands out donations like candy with one hand, and picks our pockets to do it with the other. Its contributions to this community are paid for by us. It’s pennies on the dollar for Exelon. And the costs to the public are incalculable. I do not support NRC’s decision to re-license Limerick or understand its reasoning.

I support the recommendations of ACE.

May 23, 3013
To: Nuclear Regulatory Commission
From: Betty Shank, Pottstown, PA 19464
Re: Comments: Limerick Nuclear Plant Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

NRC regulations have become as deteriorated and unprotective as Limerick’s aging equipment. That equipment is plagued by thinning, pitting, fatigue, erosion, leaching, embrittlement, and GE Mark II Boiling Water Reactor stress corrosion cracking. The list of opportunities for disaster is endless.

Limerick monitoring equipment has been out of service, unnoticed sometimes for more than a year and automated systems have failed, discovered only after accidents occur.

Public statements by NRC and Exelon following such events are generic and deceptive. The public receives no more respect than the river that Limerick is destroying and the air that it is polluting, all for Exelon’s profits.

NRC and Exelon have gone through all the motions required for re-licensing but, it’s all for show.

Hollow evacuation plans, lack of meaningful regulation, perfunctory public inclusion, and NRC’s willful blindness to the consequences of our routine radiation exposure increase public risk. It’s a nightmare, affecting the health of our families and the environmental legacy we leave our children and grandchildren.

Back in the ’80’s before Limerick construction was complete, a suit was filed when the public understood that Limerick operations would violate clean air standards and that design alternatives should have been considered. The suit was won in court, but successfully stalled until Limerick construction was complete. Back then, too many officials fell into the trap of weighing economic factors more heavily than public protection. Elsewhere, more enlightened thinking led to cancelled construction plans and closed plants.

Exelon makes no secret of the fact that its first concerns are profits and investors. Exelon executives believe nuclear plants create the profits. But, that’s because the public has been forced to support nuclear energy in an egregious example of corporate welfare. WE get sick, OUR drinking water supply is reduced and contaminated, OUR air is polluted, and still, we not only pay for many of Exelon’s nuclear business costs, but for its mistakes as well.

It is the height of injustice for NRC to allow this corporate abuse to continue, when safer electric power is available.
When NRC and Exelon claim that Limerick operations comply with NRC regulations, don’t be fooled. There’s hardly anything left of them for Exelon to comply with. It’s hard to imagine the risks that lie ahead in the decade that’s left of Limerick’s current license, let alone twenty years beyond that.

NRC may be approving Limerick license renewal simply because it can, not because it is its only option or the right thing to do. So this extraordinary breach of public trust will allow Exelon to continue its premeditated assault of humanity and the environment purely for profit. What a travesty!

I support ACE recommendations.

May 23, 3013
To: Nuclear Regulatory Commission
From: Charlie Shank, Pottstown, PA
Re: Comments: Limerick Nuclear Plant’s Environmental Impact Statement NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

An issue that is finally getting some attention at U.S. nuclear plants is the leakage of radioactive water into the ground beneath and around these plants. ALL plants leak. These leaks come from pipes, tanks, and many of the plant’s systems. The NRC states that “events happen at all plants that are often unknown of, unseen, uncontrolled, and unmonitored releases of radioactive liquids into the ground”.

Exelon spokesmen will tell you that they monitor everything and that they have control of everything – don’t believe it! The NRC statement contradicts that propaganda. These radioactive releases are in addition to the known surface spills that frequently occur.

In 2006, nuclear plants started a program to check into this mounting leakage problem. Fifteen wells were drilled on Limerick property outside of the power block area where the reactors and other equipment sits.

One well, P-12, south and down gradient of the power block area showed 4,400 p/ci/L of tritium, well over the reasonable European safe drinking water level for Tritium which is 2700p/ci/L. Not liking the results, that well was closed and almost immediately a new well was drilled, well MW-LR9. This well, west and down gradient of the power block showed 1700 p/ci/L. Over the next few years, as all 15 wells were tested, they all showed Tritium and all 15 showed gross beta emitters. Three wells contained gamma emitters, 9 had alpha emitters, and 4 out of 5 wells tested positive for uranium.

All the ground around Limerick’s plant is radioactively contaminated. Most water flow at Limerick, both surface and subsurface, is to the south and west toward Possum Hollow Creek, the Schuylkill River, and East Coventry Township. Many wells on the East Coventry side of the river are in the same Brunswick fractured bedrock formation.

Recently Exelon re-gifted East Coventry with 154 acres it had taken by eminent domain from private citizens and the township some 30 years ago. This land could have been subjected to possible radiation contamination above and below the surface for many years before it was returned.

This story reminds me of the Trojan horse story. With Limerick’s renewed license, and at least 30 more years of contamination to come, imagine what this land could turn into. No independent radiological study was ever done before this land was transferred. The people of East Coventry should insist on radiological studies now and in the future. I’m very grateful to Mr. Michael Moyer, East Coventry Supervisor, for his ability to see the possible serious problems with this situation and question this decision.

I say, “Beware of utilities bearing gifts”!

I support Ace’s recommendations.

Recently, the Limerick Nuclear Plant refueled reactor #1. It also uprated the plant to produce more energy. To do this, they have mixed in a more powerful fuel, GNF2, and changed the shape of the fuel bundles. These changes make more power, more radiation, more heat, and put more stress on the aging equipment. Exelon is now close to the maximum output for the Limerick reactors. To add more power, expensive changes would be necessary to handle the even greater stresses and increased radiation.

Everyday, 14.2 million gallons of very hot water leave the cooling towers loaded with dissolved solids and radiation. This hot brew goes down pipe 001 to the diffuser and into the Schuylkill River. It enters the river at 110 F, a much higher temperature than the Schuylkill River limit of 87 F.
When water is hotter than 95 F, it fosters the growth of thermophilic microbic organisms. These organisms include Legionella and Samonella, among others. These pathogens thrive in warm water. They can also cause fatal infections and pneumonia in compromised individuals and the elderly. This hot water needs to be cooled down more than it can be at the present time.

Exelon asked the Pa. DEP to provide comments about these pathogenic organisms in the river. Exelon wanted the Pa. DEP to confirm Exelon’s conclusions that no harm would come from the pathogens during an extended period of operation with these higher temperatures.

The Pa. DEP, to its credit, said it had no data on these organisms in the river to support Exelon’s claims. The Pa. DEP was unable to reach any conclusions as to the possible health effects, thus not supporting Exelon’s contentions.

I think it would be better to have more independent study done now and solve any unknowns before racing to re-license Limerick. We have 11 years remaining in the present licensed period to properly work out these problems. We should no just skip over them, or wait until a serious accident happens.

The job of the NRC is to protect public safety, not the nuclear industry! The way the NRC has been acting lately makes the IRS look good!

I support ACE’s recommendations.

May 23, 2013
From: Lorraine Ruppe, Pottstown, PA
Subject: Testimony On Limerick Nuclear Plant’s Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

I’m concerned about an earthquake triggering one or more meltdowns at Limerick Nuclear Plant. What worries me are the miles of hard to inspect pipes and cables buried under Limerick that can be disrupted and then incapable of delivering vital electric and cooling water to prevent meltdowns.

NRC should be worried too, but instead gave Exelon until 2017 to come up with a new seismic risk “study” or plan. It’s beyond negligent for NRC to allow Exelon to wait years to take action. Limerick is considered a high-risk nuclear plant and earthquake risks are increasing.

My search for earthquake fault lines closest to Limerick Nuclear Plant is one big reason I have no confidence in any of NRC’s conclusions in Limerick’s Environmental Impact Statement.

May 2011, I asked NRC how close the nearest fault lines were to Limerick Nuclear Plant. September, 201I at the first EIS hearing, I repeated my request. When NRC finally responded, I received a letter and map showing earthquake fault lines 9 and 17 miles from Limerick.

Later, I learned NRC failed to disclose an earthquake fault right under the Limerick site and two others within 2 miles. Local residents discovered a 1974 seismic study for Limerick in the Pottstown Library, clearly identifying these faults.

So why did NRC fail to disclose these faults when I asked about the closest earthquake faults to Limerick.? Was this a cover up or incompetence? Neither is good. April 18, 2012 NRC’s Andrew Rosebrook, who sent me the map and letter, claimed to be unaware of the fault under Limerick when shown the seismic map from the library.

The August 2011 earthquake in Virginia shook Limerick Nuclear Plant and caused a Limerick notice of violation. This should have caused NRC to require Exelon to reduce seismic risks immediately

Rosebrook did admit that the Ramapo Fault, just 17 miles away from Limerick is active. He also validated my concern about blasting at the quarry bordering Limerick.

Fracking could trigger an earthquake disrupting underground pipes and cables. Over 3,000 gas well were approved in PA. 2,000 more are to be approved this year.

Structural problems and flaws associated with Limerick construction are a concern. For example, Limerick’s packed deadly fuel pools were constructed with substandard cement.

All this, yet NRC isn’t requiring Limerick to do important seismic upgrades until after 2017, even though Limerick is considered by some to be 3rd on the nation’s earthquake risk list. By then, we could have an earthquake and meltdown.

Limerick should never have been built here in the first place. NRC falsely claims earthquake risks were considered prior to Limerick approval. That’s not true. The first reactor was delivered to Limerick’s construction site in 1972, two years before the 1974 Limerick seismic study was completed.

With earthquakes becoming stronger and more frequent, NRC owes it to us to shut Limerick down before it melts down.

May 23, 2013
Testimony To: The Nuclear Regulatory Commission
From: Lorraine Ruppe, Pottstown, Pa 19464
Subject: Testimony On Limerick Nuclear Plant’s Environmental Impact Statement
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

How can NRC believe Exelon’s outlandish claims that they are stewards of the environment when in fact, evidence shows Exelon is damaging the environment every day that Limerick operates? Common sense tells us nothing in the world threatens our environment and our health more than Limerick Nuclear Plant operations.

We shouldn’t have to live with radiation and other toxics poisoning our water and bombarding our children because of Limerick Nuclear Plant operations.

We shouldn’t be faced with a depleting water supply because of Limerick’s cooling towers or risk having no water if Limerick has an accident or meltdown. Our drinking water could dry up or become so radioactive we can’t use it.

Exelon pumps toxic mine water into the river up to 80 times Safe Drinking Water standards. Toxics don’t magically disappear. They end up in our drinking water. Manganese, one of the toxics, can lead to permanent brain damage from showering.

NRC dismissed serious threats to public drinking water from Limerick Nuclear Plant. NRC met with DEP and DRBC, but they just gave Limerick 5-year permits to use and pollute our drinking water, with dangerous loopholes and exemptions because Limerick can’t meet Safe Drinking Water Standards or other protective limits. That didn’t reduce our risks. Exelon should have been required to filter Limerick discharges and those from the mine water to protect drinking water and public health.

Limerick causes irreparable and irreversible damage to the river, then donates to a fund to deceptively claiming they protect the river. Not one dime of that fund was ever spent to reduce Limerick’s radioactive or other toxic discharges.

Exelon’s donations are a drop in the bucket compared to their profits and tax avoidances. Sadly, organizations hoping to get funded from Exelon, then ignore Limerick’s poisoning of our water and children.

How can we take care of our health when we are forced to drink, bathe in and breathe in toxic chemicals from Limerick operations?

Too many people are really sick, having thyroid problems, and dying of dreaded diseases like cancer. Look at the huge cancer rallies in our community.

Why should we risk our lives and fear meltdowns, more sickness and cancer for Limerick’s electricity, when safer energy is available? The problem is, NRC appears to be more of a salesman, than a policeman.

Nuclear Power already destroyed parts of the world. This dangerous dinosaur technology must make way for safe clean energy alternatives that won’t destroy our water supplies and health.

Paul Gunter, Beyond Nuclear 5-23-13 Summary of Comments On Limerick Nuclear Plant’s EIS

• Limerick regulations are not accounting for risk and threat

• I OPPOSE Limerick Relicensing.

• Limerick is a regional and national issue

• NRC should suspend all reviews or relicensing after Fukushima.

• Limerick is similar to reactors at Fukushima that exploded.

• NRC has a conveyer belt process.

• Failing to consider environmental impacts at Fukushima

• NRC has no will or ability to challenge license extensions . 75 are done. No rejections in spite of all the questions

• Limerick application is in violation of license agreements. NRC knows design will fail. NRC’s own staff – 2012 – 0157 – GE BWR at Limerick
- #16 – 2 Limerick Units Violation of General Design Criteria #16
- Must have a leak-tight barrier for as long as required
- Limerick 1 and 2 very likely to fail in an accident
- NRC’s own staff —– for core damage 50-50 chance of recovery
- 50-50 chance vessel will fail
- 75% chance will not recover – Will be significant radiation release into environment
- 90% chance meltdown of core will by-pass system and burn through seals with catastrophic unfiltered radiation released downwind – THAT’S US.
- NRC estimated necessary design, structure, systems, and components ….in violation of system for safety.
- Limerick can’t be run without undo risk to public health and safety, but;
- Mark II – 100% guaranteed failure under severe accident conditions Leading to massive land contamination and groundwater contamination.
- Fukushima demonstrates 100% guaranteed failure – Units 1,2,3 – Multiple explosions with massive land contamination and groundwater
contamination.

• NRC weakened regulations

• Public is not provided a process that fairly evaluates risk.

• We don’t need Limerick to be operating at this risk

• Limerick should be put in phase out, not relicensed.

Scott Portzline, TMI – Comments On Limerick EIS 5-23-13

• Generation growth not occurring in PA – Downturn – 1/3 of what it used to be

• Limerick could close and it wouldn’t affect the grid

• Limerick has safety deficits

• Undue risks – NRC is not charged with protecting your property

• NRC assumptions are not on the side of safety

• NRC conclusions should not be accepted by anyone.

• He agrees with ACE – Data does not support conclusions in report

• 100% vents failed in reactors similar to Limerick

• Hydrogen buildup – Paul Gunter predicted explosion on CNN day before it happened at Fukushima

• Should heed the warnings of TMI
- TMI failed to follow guidelines – Evacuation was delayed
- Higher degrees of radiation – waited too long

• Relicensing process should not be happening

• NRC relies on state for radiation monitoring – Investigation

• Section 5.2 – Denying outside threat of sabotage causing severe accidents
- NRC considers NO more than internal initiated event
- Study flawed
- What if hole in containment from saboteur
- NRC confines analysis to the building staying in tact.