The Alliance For A Clean Environment ACE Website Blog Post

Blog Post #3 – May 13, 2012

Limerick Nuclear Plant Must Shut Down Before It Melts Down

1. Meltdowns Can Be Triggered By Loss of Power and Loss of Water.
 Earthquakes Can Trigger Meltdowns.
 Limerick Is Considered A VERY High Risk Nuke Plant – 3rd On The Nation’s Quake-Risk List
 The Questions Is – Why Was Limerick Allowed To Be Constructed Here Right Over An Earthquake Fault, And So Close To So Many Others, Including One That Has Been Active?

In 1972 – Limerick Proceeded Without A License For Construction Or Permission -
BEFORE Limerick’s Earthquake Study Was Even Completed In 1974
– Exelon’s Fact Sheet Claims Limerick Construction Began In 1974.
• But November 15, 2972, before PECO ever received a permit, a mammoth 90-wheel truck, escorted by police, carried a new nuclear reactor vessel to the Limerick site in Pottstown.
• Attorney Lawrence Sager told the Mercury,
“It shows … arrogance of the utility. It has no license for construction, nor permission to proceed, and yet they moved the vital parts onto the site.”

Cover Up? Evaluate NRC’s Omissions and/or Confusion Regarding Earthquake Faults Under and Near Limerick Nuclear Plant. You decide.

- ACE members recently confirmed that there is a fault right under the Limerick Nuclear Plant site. They discovered this in the Pottstown Library from a 1974 geological study done for Limerick’s original licensing,
• The Sanatoga Fault is right under Limerick Nuclear Plant, yet NRC failed to disclose that fault under Limerick or two others within 2 miles of Limerick when asked to identify the closest faults to Limerick by a local Mother very concerned after knowing an earthquake triggered the March 2011 Fukushima nuclear disaster.

- Two other faults were identified by NRC in a letter and map sent to the resident 10/11 – After multiple requests and over 5 months after the original 5-11 request.
• The resident’s letter and map identified ONLY faults 9 and 17 miles from Limerick.
9 miles – Chalfont Fault 17 miles away – Ramapo Fault
• At NRC”s 4-18-12 meeting in Limerick, NRC officials appeared totally unaware of the fault right under Limerick Nuclear Plant.
• The NRC official who sent the letter and map which failed to identify the fault under Limerick, admitted 4-18-12 that the Ramapo fault 17 miles from Limerick was active with 2 or 3 quakes.
• He also expressed concern about the quarry next to the Limerick site.

- A cover-up to construct Limerick? Just Like North Anna in Virginia?
• The geological study revealing the Sanatoga Fault right under Limerick Nuclear Plant was completed in 1974.
• But in 1972, the first Limerick reactor was already delivered to the site.
• There was a documented earthquake fault cover-up in order to push through the construction of North Anna. The risk was uncovered and challenged in court, but the company only paid a fine and proceeded with construction.
• Limerick’s generator was already delivered before the earthquake study was reported.
• Now it appears to many, that NRC is covering up the risk, after the fact.
• 5-9-12 NRC responded to ACE questions 4-18-12 about the fault under Limerick. NRC points to 3 faults within 2 miles of Limerick, but fails to address the fact that the Sanatoga Fault is directly under the Limerick Nuclear Plant site.
• NRC points us to a 1983 Safety Evaluation Report which concludes there are “no capable faults” in the site area. That study is outdated and no longer valid based on new information. In 2011 we saw earthquakes becoming far stronger and more frequent, a risk that will only increase with fracking of thousands of gas wells in PA.
• NRC even contradicted that conclusion when admitting the Ramapo fault is active.

- Earthquake threats are stronger and more frequent
• Earthquakes Triggered Fukushima Meltdowns
• 8-23-12 Virginia quake shook our region – Limerick had to check for damage, but the place an earthquake is most likely to cause damage is also the place hardest to inspect – underground.
• Damage is hard to detect in the miles of buried underground pipes and cables under the 600 acre Limerick site. What could happen from earthquakes in faults so close to and under Limerick?

- Fracking Could Trigger An Earthquake at Limerick
• A 2012 USGS study confirmed that fracking can trigger earthquakes
• In PA 4,200 natural gas wells have been approved since 2007
• Many, including a high-ranking NRC official, are even concerned about the quarry very close to Limerick, especially now knowing there is a fault right under Limerick.

- Limerick is considered a high-risk nuke, ranked 3rd on the nation’s quake-risk list
• Yet, Limerick is not required to comply with KEY seismic safety upgrades until 2017
NRC’S NEGLIGENT EXCUSE – “Limited Resources – Prioritizing” Rick Ennis 4-18-12
NRC couldn’t answer how you fix earthquake faults under and too close to Limerick.

2. Safety of Limerick’s Design Was Challenged In 1981 In Federal Court,
YEARS BEFORE Limerick Completion. Construction Should Have Been
Halted In 1981, Pending The Decision. It Was About Safety In Design

In 1981 Limerick Ecology Action sued in federal court – Accusing NRC (AEC) of:
- Violating the National Environmental Policy Act
- Not Considering Safety Enhancing Design Alternatives For Limerick Nuclear Plant.
NRC was ordered to listen to LEA’s proposals by the 3rd circuit court of appeals in Philadelphia.
- The order was a major embarrassment to NRC and setback for PECO.
Reported in Mercury “David Against Federal Goliath” – September 28, 1997
The case dragged on nearly 9 years – the decision came too late:
- Unit 1 was Finished
- Unit 2 Completion was Approved.

3. Limerick’s Design Flaws Are A Serious Threat To The Entire Philadelphia
Region
- Limerick’s reactor containment is substandard, meaning more radiation would be released in an accident or attack.
- 9-22-11 A quality assurance engineer at the time cement was poured for Limerick’s fuel pools testified that cement was faulty.
- 5-9-12 – NRC substantiated that “there were deviations in a concrete pour for the spent fuel pool.”
- NRC admitted to ACE 5-9-12 – At the time of construction NRC (AEC) claimed there would be “no adverse effect on the structural adequacy of the spent fuel pool”. In other words, even with potentially deadly consequences, NRC overlooked and allowed substandard cement to be used for very critical fuel pool construction.
- That negligent conclusion was accepted decades ago, but NOT NOW, with increasing threats to Limerick’s fuel pool integrity from both earthquakes and terrorist attacks,
- The quality assurance engineer, Dan Ely, expressed heightened concerns 9-22-11, due to increased risk of stronger and more frequent earthquakes and other natural disasters.
This should be enough of a concern to NRC and elected officials in our entire region to call for closure of Limerick to prevent devastation to the entire Philadelphia region.

4. Limerick’s Densely Packed Deadly Fuel Pools Are Highly Vulnerable To
Meltdown

- Cement holding Limerick’s Deadly Radioactive Wastes Is Substandard.

- Large volumes (over 6,000 assemblies-1,000 tons), of Limerick’s highly radioactive wastes (spent fuel rods) are stored in Limerick’s densely packed fuel pools, elevated five stories above and outside the reinforced containment structure for the reactor.

- After decades of holding all Limerick’s highly radioactive and heated “spent fuel” rods, Limerick’s substandard cement could crumble like a tea cup from a strong earthquake or a terrorist attack with a plane or missile.

- Limerick’s Fuel Pools are similar to Fukushima’s, but Limerick’s 2 fuel pools hold far more deadly spent fuel than 4 of Fukushima’s.

- A 2011 Study On DOE Records Shows Limerick’s 2 Fuel Pools Hold:
• Almost three times more than four of Fukushima’s fuel pools
• Far more than many U.S. nuclear plants, including Exelon’s TMI and Oyster Creek
• Far more than the reactors

- With loss of cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire.

- Fire in a spent fuel pool could release enough cesium-137 “to render about 95,000 square kilometers of land uninhabitable” (Comparable to covering about 75% of New York)

- Loss of water from Limerick’s fuel pools could create a disaster far worse than Chernobyl and 100 times worse than Hiroshima.

- A meltdown from loss of water in a spent fuel pool could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site according to a 2000 NRC study.

- Limerick’s “Spent Fuel” pools are at high risk from loss of cooling water due to:
• Earthquakes
• Leakage and/or Evaporation
• Reactor Failure
• Explosion Inside or Outside Pool Building
• Terrorist Acts Including Aircraft Impact or Missiles

- Fuel Pools are especially vulnerable to aircraft penetration. Still, Exelon has not been required to spend the money to guard Limerick against terrorists’ missiles or air strikes.

- A 2004 Study by Dr. Edwin Lyman, Senior Scientist at the Union of Concerned Scientists, Concluded:
• As many as 44,000 near-term deaths from acute radiation poisoning
• 518,000 long term deaths from cancer.
• Deaths could occur among people living as far as 60 miles downwind.
- A 2003 study by Dr. Frank Von Hippel, Director of Science and Global Security at Princeton University, concluded that:
• A successful terrorist attack on a spent fuel storage pool could have consequences “significantly worse than Chernobyl.”
• A catastrophic spent fuel fire could release a radiation plume that could contaminate 8 to 70 times more land than Chernobyl. (Would include the entire Philadelphia Metropolitan Region).
- How dangerous is “spent fuel”?
• Standing 1 yard away unshielded can cause death in less than 3 minutes.
• 30 seconds of exposure can cause significant increased risk of cancer and genetic damage.

5. Deja Vu – Limerick’s Serious Safety Concerns Are Being Ignored By NRC
Yet Again.
- In 2011, the National Resources Defense Council (NRDC) Intervened On Our Behalf Against Limerick Nuclear Plant Relicensing, Accusing Limerick of Dodging A New Safety Study
- NRDC Said “Limerick’s Safety Analysis Is Decades Out Of Date. A New Limerick Safety Analysis Is Necessary.” NRDC Cited Limerick’s Obsolete Severe Accident Mitigation Study. NRDC’s Director Said,
• “After Fukushima, it seems just plain nutty not to require a new study on Limerick’s Boiling Water Reactors similar to those at Fukushima.”
• “Exelon and NRC blithely maintain they have NO reason to take another look at Limerick’s Severe Accident Mitigation Analysis”
- The licensing board ruled in favor of NRDC, but Exelon and NRC (the agency supposedly protecting our safety) appealed the decision, even though this is about our safety.
Why would Exelon and NRC fight so hard against a new safety study?
- Many believe Limerick should have to close as a result of a new safety study.

Dr. Lewis Cuthbert
ACE President