ALLIANCE FOR A CLEAN ENVIRONMENT (ACE)
JUNE 24, 2013 TESTIMONY ON
NRC’S DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)
FOR LIMERICK NUCLEAR POWER PLANT
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166
NRC PRODUCED A DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR LIMERICK NUCLEAR PLANT
WITHOUT ACCURATELY EVALUATING AND REPORTING ON LIMERICK’S
SPECIFIC UNPRECEDENTED HARMFUL ENVIRONMENTAL IMPACTS
FOR THE PUBLIC TO CONSIDER NRC’S EIS FOR LIMERICK VALID,
NRC’S FINAL EIS MUST REFLECT CHANGES IDENTIFIED IN THIS TESTIMONY.
SIGNIFICANT CHANGES NEEDED FOR LIMERICK’S FINAL EIS INCLUDE:
- Radiation Releases From Limerick Nuclear Plant And Links To Cancer Near Limerick Need To Be Accurately Included, As Identified In This Testimony.
- Cancer Rates Near Limerick Need To Be Accurately Reported, As Identified In This Testimony.
- Unprecedented Harms And Threats To The Schuylkill River Need To Be Accurately Reflected, As Identified In This Testimony.
- Radionuclides In Groundwater Caused By Limerick Need To Be Accurately Reported, As Identified In This Testimony.
- Major Air Pollution Threats From Limerick Need To Be Accurately Reflected As Indentified In This Testimony, Including Unprecedented Risks From Limerick’s Massive Cooling Tower PM-10 Which Transports Radiation, Many Other Dangerous Highly Corrosive Toxics, and Pathogens Into Our Air.
- Accurate Reporting On Solar Power Needs To Be Included, And More Accurate Comparisons On Alternatives Need To Be Reflected, As Identified In This Testimony.
- Why Limerick’s Decades Old Severe Accident Mitigation Alternatives Needs To Be Updated As Required By A Federal Judge, Not Challenged In Court and Exempted. NRC Staff Recommended Post Fukushima Safeguards Must Be Required Immediately And NRC Identified Corrosion, Deterioration, And Other Aging Problems In Structures and Systems Must Be Repaired And Replaced, Including In Fuel Pool Liners, PRIOR To Relicensing, As Detailed In This Testimony.
- Limerick’s Earthquake Risk Plans And Upgrades Need To Be Completed Prior to Relicensing As Reflected In This Testimony, And Not Delayed Until 2017 Or Later.
- A New Review Of Limerick’s High-Level Radioactive Wastes and Spent Fuel Storage Is Imperative To Be Included In This EIS, As Identified In This Testimony.
- Limerick’s Low-Level Radioactive Waste Volumes Need To Be Tracked. Assurances That Exelon Will Not Burn It In Our Region Are Imperative, As Identified In This Testimony.
- Limerick’s Cost-Benefit Analysis Needs To Include All Costs to The Public, As Identified In This Testimony.
June 24, 2013
ALLIANCE FOR A CLEAN ENVIRONMENT (ACE)
Official Written Testimony On
NRC’s DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)
FOR LIMERICK NUCLEAR POWER PLANT
NUREG-1457, Supplement 49, Docket ID NRC-2011-0166
NRC PRODUCED A DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR LIMERICK NUCLEAR PLANT WITHOUT ACKNOWLEDGING DOCUMENTED HARMFUL ENVIRONMENTAL IMPACTS.
NRC FAILED TO ACKNOWLEDGE LIMERICK NUCLEAR PLANT’S UNPRECEDENTED THREATS AND HARMS PRESENTED TO NRC IN ACE WRITTEN TESTIMONY 10-26-11.
CONSEQUENCES OF NRC’S INACCURATE CONCLUSIONS:
Limerick’s DRAFT EIS Could Result In Increased Future Risks And Harms For Millions Of People In The Greater Philadelphia Region. Ignoring Evidence Of Harm Doesn’t Eliminate The Reality Of Current Harms Or Future Threats.
NRC MUST SET THE RECORD STRAIGHT IN ITS FINAL EIS
NRC’S Mission Is To Protect Public Health And Safety Related To Limerick Nuclear Plant Operations. Minimally, That Requires NRC To Provide Full, Fair, And Accurate Disclosure Of All Of Limerick Nuclear Plant’s Unprecedented Environmental Threats And Harms. The Health And Safety Of Millions Of People In The Greater Philadelphia Region Will Be Further Jeopardized By Negligent Conclusions In NRC’S DRAFT EIS For Limerick Nuclear Plant.
NRC Conclusions In Limerick Nuclear Plant’s DRAFT EIS Are An Unethical Injustice To The Public, And Must Be Changed To Reflect The Documented Evidence Of Unprecedented Threats And Harms.
ON BEHALF OF THE HEALTH, SAFETY, AND FINANCIAL INTERESTS OF MILLIONS OF PEOPLE:
- 1. ACE Is Requesting That NRC’S DRAFT EIS For Limerick Nuclear Plant Relicensing Be Changed To Accurately Reflect The Documented Evidence ACE Put On NRC’S Public Hearing Record For Limerick’s EIS October 26, 2011.
- 2. ACE Is Also Requesting That NRC’S Final EIS Reflect Additional Evidence Of Environmental Threats And Harms Included In This June 24, 2013 Written Testimony.
Facts Show Limerick Nuclear Plant’s Environmental Threats Are Clearly “Large”, NOT “Small” As Inaccurately Claimed By NRC.
- Increases And Exemptions In Limerick Nuclear Plant’s Air And Water Pollution Permits Should Be Sufficient For NRC To Conclude Limerick’s Environmental Impacts Are “LARGE” NOT “SMALL”, Especially When Limerick Couldn’t Meet Its Original Permit Limits Or Safe Limits In Place To Protect Public Health, And Exelon Won’t Pay For Filtration to Reduce health Threats.
NRC Did NO Independent Monitoring Or Testing For Limerick’s EIS. It Is Indefensible For NRC To Claim Limerick’s Impacts Are “Small” When A Body Of Evidence Suggests Otherwise.
NRC FAILED TO HAVE AN INDEPENDENT EXPERT ANALYZE THE ADDITIVE, CUMULATIVE, AND SYNERGISTIC HARMS TO THE ENVIRONMENT AND PUBLIC HEALTH OVER THE PAST 28 YEARS. THEREFORE, NRC CAN’T MAKE A RELIABLE, DEFENSIBLE PREDICTION ABOUT THE HARMS FROM LIMERICK UNTIL ITS LICENSES EXPIRE IN 2029, NOR UNTIL 2049, DURING ANOTHER 20 YEARS IF LIMERICK IS RELICENSED.
- Prior to NRC’s scoping process, ACE repeatedly urged NRC and other agencies to do a year of independent monitoring and testing for all of Limerick’s broad range of radionuclides, as well as other toxics massively released into our air and water from Limerick. NRC never even responded to our requests.
WELL DOCUMENTED EVIDENCE OF LIMERICK’S UNPRECEDENTED ENVIRONMENTAL THREATS AND HARMS REFUTE NRC’S INDUSTRY-BIASED UNRELIABLE, UNSUBSTANTIATED CONCLUSIONS THAT LIMERICK’S HARMS ARE “SMALL”.
- NRC’S negligent conclusions protect Exelon’s profits and NRC jobs, but fail to protect public health and safety.
NRC’s inaccurate conclusions in Limerick’s DRAFT EIS are largely based on untrustworthy estimates, calculations, and “reviews” of monitoring and testing data from Exelon, the company with a clear vested interest in the outcome, that has shown it can’t be trusted to provide full and accurate disclosure at Limerick or elsewhere.
- 10-26-11 ACE provided NRC with several specific examples of why Exelon can’t be trusted to provide full, accurate, or timely disclosure of Limerick’s monitoring, testing, calculating, estimating, or reporting.
Example of Exelon’s Unreliable Monitoring:
ü A vital radiation monitor was inoperable for over an entire year.
Example of Exelon’s Delayed Disclosure:
ü Exelon waited 23 days to inform the public about a huge radioactive spill into a vital public drinking water source for almost two million people.
EVIDENCE SHOWS NRC FAILS TO TAKE MEANINGFUL ENFORCEMENT ACTION AGAINST EXELON’S NEGLIGENCE REGARDING THREATS TO PUBLIC HEALTH, REGARDLESS OF ENORMOUS OPPORTUNITY FOR HARMS TO THE ENVIRONMENT AND PUBLIC HEALTH.
- 2-3-13 It was reported that Exelon provided NRC with inaccurate information about how much money will be available to decommission Exelon’s power plants, potentially hiding a shortfall of “roughly $1 Billion”. This should show NRC why they can’t trust any information provided by Exelon, especially in radiological monitoring reports.
ACE rejects NRC’s inaccurate, absurd conclusions in its DRAFT EIS for Limerick Nuclear Plant.
- 10-26-11 ACE provided NRC with analyses that should have triggered investigations, not just consultations with agencies that allowed dangerous permit increases and exemptions in Limerick’s pollution permits. NRC’s conclusions show that NRC ignored and dismissed important documented evidence from several analyses related to Limerick’s environment and health threats. These analyses were on:
- Exelon’s Radiological Monitoring Reports to NRC
- Limerick’s Title V air pollution permit renewal in 2009
- Limerick’s NPDES permit for pollution discharges into the Schuylkill River
- Analyses of radioactive groundwater contamination
NRC CLEARLY DID NOT GIVE A FULL AND FAIR REVIEW NOR ADDRESS THE DOCUMENTED EVIDENCE OF ENVIRONMENTAL AND HEALTH HARMS AND THREATS SUBMITTED FROM ACE 10-26-11 ON BEHALF OF PUBLIC INTERESTS.
- NRC ALSO REFUSED ACE’S REQUEST TO MEET TO DISCUSS OUR POLLUTION PERMIT ANALYSES, DESPITE THE FACT THAT NRC FAILED TO INDEPENDENTLY ANALYZE LIMERICK NUCLEAR PLANT’S POLLUTION PERMITS.
- Not one word appears in Limerick’s EIS about the documented cancer crisis in communities near Limerick. Nor have the high infant and neonatal mortality issues been acknowledged or discussed.
- Major evidence related to Limerick’s air and water pollution permit issues goes unaddressed.
- High-level and low-level radioactive waste issues have not been adequately addressed.
NRC REFUSING TO INCLUDE OR DISCUSS DOCUMENTED HEALTH HARMS AND ENORMOUS ENVIRONMENTAL THREATS SPEAKS VOLUMES ABOUT NRC’S INDUSTRY BIASES.
AVOIDING THE PUBLIC AND DISMISSING DOCUMENTED FACTS ABOUT LIMERICK’S POLLUTION THREATS WILL NOT REDUCE RISKS, BUT INSTEAD ALLOW THEM TO CONTINUE AND INCREASE.
- If NRC’S baseless inaccurate conclusions that Limerick’s harms are “small” are not changed to deal with reality in Limerick’s EIS, then the NRC officials who approved Limerick’s DRAFT EIS must be held accountable for regulatory negligence.
- NRC’s irresponsible conclusions will result in unacceptable consequences and injustices to millions of people in the Greater Philadelphia Region.
NRC MADE INACCURATE ILLOGICAL CONCLUSIONS THAT FAIL TO CONSIDER OR ACKNOWLEDGE EXTENSIVE DETAILS PROVIDED IN ACE’S 10-26-11 PUBLIC HEARING TESTIMONY. EVIDENCE SINCE 2011 ALSO REFUTES NRC’S FALSE CLAIMS THAT HARMS ARE, OR WILL BE, “SMALL”.
AMONG THE MOST GLARING OMISSIONS IN NRC’S DRAFT EIS IS THE DOCUMENTED COMPELLING EVIDENCE ACE PROVIDED 10-26-11 ON THE LINKS BETWEEN OUR CANCER CRISIS AND LIMERICK’S ROUTINE AND ACCIDENTAL RADIATION RELEASES SINCE 1985.
- WE SHOWED WHY LIMERICK’S RADIATION RELEASES ARE CLEARLY A MAJOR FACTOR IN CANCER RATES FAR HIGHER THAN THE NATIONAL, STATE, AND TRI-COUNTY AVERAGES, ESPECIALLY IN OUR CHILDREN.
- CANCER RATES ARE DOCUMENTED TO HAVE SKYROCKETED FAR ABOVE THE NATIONAL, STATE, AND TRI-COUNTYU AVERAGES IN COMMUINITIES NEAR LIMERICK, AFTER LIMERICK STARTED OPERATING.
- YET, OUR ALARMING CANCER RATES AND HIGH INFANT MORTAILITY RATES ARE NOT EVEN MENTIONED IN NRC’S DRAFT EIS. THERE IS NOT ONE WORD ABOUT CANCER INCREASES IN COMMUNITIES NEAR LIMERICK AFTER LIMERICK STARTED OPERATING AND RELEASING RADIATION INTO OUR LIFE-SUPPORT SYSTEMS AND OUR BODIES.
- THIS OMISSION IS UNACCEPTABLE. THE EVIDENCE IS CLEAR. NRC’S FINAL DRAFT MUST BE CHANGED TO INCLUDE THE CANCER INCREASES. FOR NRC’S CONVENIENCE WE HAVE INCLUDED SOME OF THE DETAILS BELOW.
- ACE CALLS ON NRC TO REVIEW THE SUMMARY BELOW THEN REVISE ITS DRAFT EIS TO REFLECT THE REALITY ABOUT LIMERICK’S PAST, CURRENT, AND FUTURE ENVIRONMENTAL AND HEALTH HARMS, INCLUDING OUR ALARMING CANCER AND INFANT MORTALITY RATES.
FROM LIMERICK NUCLEAR PLANT AND
LINKS TO CANCER
A broad range of radionuclides have routinely and accidentally been released into our air and water for 28 years from Limerick Nuclear Plant. There are additive, cumulative, and synergistic impacts from exposure through several routes of exposure. Some radionuclides released from Limerick, like Cesium and Strontium, have decades-long half-lives.
LIMERICK NUCLEAR PLANT’S WORST ENVIORNMENTAL AND HEATLTH HARMS ARE CLEARLY ASSOCIATED WITH LIMERICK’S RADIATION RELEASES OVER THE PAST 28 YEARS.
NRC’S DRAFT ENVIORNMENTAL IMPACT STATEMENT SHOULD FOCUS ON RADIATION, THE SIGNATURE HARMFUL TOXIC RELEASE FROM LIMERICK NUCLEAR PLANT,
- NRC’S DRAFT EIS – Table of Contents – FAILS TO MENTION RADIATION
- NRC’S DRAFT EIS – Executive Summary – FAILS TO MENTION RADIATION
- NRC’S DRAFT EIS – Table ES-1 – Summary of NRC Conclusions Related to Site-Specific Impacts of License Renewal – FAILS TO MENTION RADIATION.
- NRC’S DRAFT EIS – Severe Accident Mitigation Alternatives – FAILS TO MENTION RADIATION.
- NRC’s DRAFT EIS – Purpose and Need For Action – FAILS TO MENTION RADIATION
These glaring omissions rise to the level of regulatory malpractice. It is shocking that this document fails to address radiation exposure and human health impacts in any meaningful way. NRC is mandated to protect public health from Limerick Nuclear Plant Operations, yet NRC has basically chosen to dismiss and/or minimize the impacts of Limerick Nuclear Plant’s regular radiation releases into the life-support systems and the people in the Greater Philadelphia Region in Limerick’s DRAFT Environmental Impact Statement.
Radiation exposure to the public is barely mentioned in NRC’s 585 page document DRAFT EIS document. On the very few pages with any reference, radiation releases and their effects on human health have been shamelessly characterized as minimal or small, an unsubstantiated claim.
Exelon’s own radiological monitoring reports to NRC show that a broad range of radionuclides are documented to be in our air, water, sediment, fish, and milk.
NRC’S failure to acknowledge the harmful impacts of Limerick’s routine and accidental radiation releases into our life-support systems is an injustice that cannot be tolerated. NRC’s Draft EIS for Limerick must be changed to focus on the actual harmful impacts from Limerick’s routine and accidental radiation releases, the most dangerous health threat our region faces from Limerick Nuclear Plant operations.
- Ignoring the harmful impacts of Limerick’s additive, cumulative, and synergistic radiation impacts on everyone and everything is a grave omission that will lead to 20 more years of further jeopardizing the families of everyone in our region.
- As long as Limerick Nuclear Plant continues to operate, radiation will be released into our air, water, soil, and people. More people will suffer needlessly. 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.
- The truth is, the only way to reduce health risks is to tell the truth about radiation releases from Limerick and close Limerick now to stop the routine and accidental radiation releases. NRC can stop unnecessary radiation exposure, unnecessary suffering, and unnecessary health care costs in the future by closing Limerick now.
NRC LOST ALL CREDIBILITY ABOUT HARMS FROM LIMERICK’S RADIATION RELEASES.
- NRC DID NO RADIATION TESTING.
NRC’s tactics to dismiss and/or minimize the impacts of Limerick’s radiation releases are appalling, shameful, and unacceptable.
- NRC did NO radiation monitoring or testing for this EIS, yet absurdly claims harms are “small”.
- In reality, NRC has no accurate idea how much radiation is released from Limerick into our air or water.
- NRC relies on Exelon’s deceptive and unreliable calculating, estimating, monitoring, and testing, tactics.
- NRC simply inspects unreliable reports from Exelon.
- You can’t see, feel, or smell radiation, yet NRC claims to know what radiation is being released by conducting onsite inspections for effluent compliance.
- Flawed and outdated theoretical models are used for radiation exposure, which only measure external doses, and ignore internal doses, yet NRC continues to absurdly claim Limerick’s radiation releases are 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.”
- THERE IS NO SAFE DOSE
- “Permissible” does not mean safe. In 2005, the National Academy of Sciences BEIR VII report said there is no safe dose. Permissible radiation levels do not mean they are safe.
- Radiation exposure can cause cancer and other serious disease and disability, at any level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility.
- Fetuses, infants, and children are the most impacted.
- EVIDENCE REFUTES NRC’S PREVIOUS CLAIMS
- NRC’s absurd claims about oversight of radiation releases in the 2006 “Frequently Asked Questions” for the public hearing 5-23-13 must be refuted with reality.
NRC has dose limits, but they do not protect the public.
NRC has no accurate idea what total doses from all routes of exposure that each person is getting.
NRC set limits on radiological effluent releases, but fails to monitor, test, or require filtration for compliance.
NRC admits that scientists are unable to make empirically based estimates of radiation risks from nuclear plants, yet NRC claims risks are small.
- LAX OVERSIGHT – NRC says its regulations require Exelon to control and limit radiation releases to the air and water to very small amounts and comply with radiation dose limits for the public but that is not true. Just one example is Limerick’s 3-19-12 radioactive spill into a vital drinking water source.
Limerick’s 3-19-12 radioactive spill into a drinking water source for almost two million people shows that Exelon fails to comply with NRC regulations and NRC takes no meaningful enforcement action.
People were drinking water with higher than usual radiation levels from Limerick’s spill, yet NRC and Exelon waited 23 days to inform the public. People had no opportunity to avoid use of the radioactive water.
Neither NRC nor Exelon has any idea what doses of radiation people were exposed to in their drinking water for the 23 days they weren’t even told it happened.
NRC did NO TESTING. Water companies did NO TESTING. In fact, NRC inspectors never verified the amount of radioactive water that was spilled.
NRC Deceives The Public, About Radiation Risks From Relicensing When Stating Radiation Dose Levels Are “Not Expected to Increase” From Those During the Initial Licensing Period.
- After Limerick started operating communities near Limerick experienced shocking cancer increases and alarming infant mortality rates, identified in detail below.
- NRC’s expectation that radiation doses will not increase during relicensing is little comfort.
CANCER - RATES SKYROCKETED
10-26-11 ACE provided NRC with evidence showing communities around Limerick Nuclear Plant already suffered alarming cancer increases after Limerick started operating in 1985. A cancer crisis has been documented by PA Cancer Registry Statistics and CDC data.
- Yet, NRC’s DRAFT EIS failed to include this important information.
- NRC’S final EIS must include this evidence about such shocking cancer rates far above the national, state, and tri-county averages, especially in children.
LIMERICK’S RADIATION RELEASES HAVE CLEARLY BEEN A MAJOR FACTOR IN THE CANCER CRISIS IN COMMUNITIES AROUND LIMERICK NUCLEAR PLANT.
The Facts Are Clear and Undeniable:
- Limerick Nuclear Plant Routinely and Accidentally Released A Broad Range Of Radionuclides Into Our Life Support Systems Since 1985.
- Radiation Can Cause Cancer At Any Level.
- A Cancer Crisis Developed In Communities Near Limerick After 1985.
- NRC HAS NO DEFINITIVE PROOF LIMERICK IS NOT A MAJOR FACTOR IN OUR CANCER CRISIS. NRC MUST NOT OMIT THE CANCER DATA AROUND LIMERICK.
- Limerick’s Radiation Releases Are Additive, Cumulative, And Synergistic With Each Other And All The Other Carcinogens, Which Explains Why Our Cancer Statistics Are So Much Higher Than The National Average, Especially In Children, The Most Vulnerable Victims Of Radiation Exposure.
Cancer Data Below Should Have Alarmed Even NRC.
Cancer Rates Skyrocketed After Limerick Opened
In Montgomery County – Home of Limerick Nuclear Plant
Increases Mid 80s to 90s
ü Prostate Increased 132%
ü Thyroid Increased 128%
ü Kidney Increased 96%
ü Multiple Myeloma Increased 91%
ü Hodgkin’s Disease Increased 67%
ü Non-Hodgkin’s Lymphoma Increased 61%
ü Breast Increased 61%
ü Pancreas Increased 54 %
ü Leukemia Increased 48%
Cancer Rates Far Higher Than U.S. and Tri-County Averages In 6 Communities Close to Limerick Nuclear Plant (1995 to 1999)
Lower Pottsgrove, Upper Pottsgrove, West Pottsgrove, Pottstown, North Coventry, Douglass Berks
8 of 11 Most Common Cancers Above National and State Averages -Compared to U.S. and TriCounty
Type of Cancer Above U. S. Above Tri County
ü Kidney/Renal Pelvis + 60 % + 42.7 %
ü Rectum + 44 % + 13.5 %
ü Uterine + 44 % + 38.7 %
ü Breast (female) + 39 % + 24.5 %
ü Brain/Cent. Nervous System + 38 % + 32.5 %
ü Urinary Bladder + 35.5 % + 17.9 %
ü Colon + 21 % + 3.3 %
ü Lung + 11.8 % + 18.4 %
ü Leukemia + 11.5 % + 14.9 %
92.5 % Higher Than The National Average
In Six Communities Close To Limerick Nuclear Plant
Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, Douglass Berks Township
(Ages 0-19) All Cancers Diagnosed from 1995-1999 Rate per 100,000
Type of Cancer Cases 0-19 Gr. Pottstown U.S. %AboveU.S. Significance
All Cancers 40 28.33 16.04 + 76.6 p<.02
Leukemia 13 9.21 3.89 +136.8 p<.055
Brain/Central Nervous Sys. 7 4.96 2.98 + 66.4
Kidney/Renal Pelvis 5 3.54 0.73 +384.9 p<.09
Non-Hodgkin’s Lymphoma 4 2.83 1.04 +172.1
All other 11
Note: Half Of Childhood Cancers Above Are Leukemia and Brain/Central Nervous System Cancers, Both Associated With Radiation Exposure .
Rates calculated in 2003 using 1990-99 annual Greater Pottstown population 0-19 of 14,120.
For example, leukemia rate = 13 cases/10 years/14,120 x 100,000 = 9.21.
Rates are MUCH HIGHER for FOUR of the CANCERS most common in children, SIGNIFICANTLY HIGHER for ALL CANCERS and LEUKEMIA, and BORDERLINE SIGNIFICANT for KIDNEY/RENAL PELVIS.
71% Increase In Montgomery County, Home of Limerick Nuclear Power Plant Deaths from Neoplasms in Children Ages 1 to 14 1981-89 vs. 1990-98
But Rates In Neighboring Counties, PA, and the U.S. Were Down:
ü Chester County 29.0% Decrease
ü Berks County 30.6% Decrease
ü Pennsylvania 17.1% Decrease
ü U.S. 21. 2% Decreas
CHILDHOOD CANCER RATES – UPWARD TREND
AFTER LIMERICK STARTED OPERATING IN 1985
Late 1980’s about 30 % HIGHER than the NATIONAL AVERAGE
Early 1990’s about 60 % HIGHER than the NATIONAL AVERAGE
Late 1990’s up to 92.5 % HIGHER than the NATIONAL AVERAGE
Late 1990’s almost 100 % HIGHER than the STATE and TRI COUNTY
Limerick’s Routine Radiation Releases Are Logically A Major Factor.
Nationwide, cancer is the #1 disease-related death in children. All children are exposed to similar environmental pollutants, including pesticides and herbicides, cleaning chemicals, mold, second hand smoke, vehicle emissions, and even genetic factors.
Closing Limerick Is The Only Way to Stop Routine Radiation Releases.
As long as Limerick operates, routine radiation will continue to be released into our air, increasing risk of cancer and other diseases and disabilities caused by radiation exposure.
NRC Lost All Credibility On Routine Radiation Releases And Cancer Links
Links between elevated cancers around nuclear plants are obvious and already documented.
- After a nuclear plant like Limerick starts operating and continuously releasing a broad range of radionuclides into the air and water, people in the region are continuously exposed to additive, cumulative, and synergistic doses of that radiation from all routes of exposure.
- Long-term exposure to the witches brew of radiation from nuclear plants like Limerick logically causes increases in cancers around it.
- Limerick Nuclear Plant is clearly a major factor in the shocking cancer increases around Limerick Nuclear Plant since it started operating.
It is NOT credible for NRC to conclude Limerick’s radiation releases or their impacts are “small”. NRC has no independent documented proof of either. It is NOT acceptable to dismiss Limerick’s routine radiation emissions as factor in the documented highly elevated cancers around it, especially in children.
NRC Refused To Give Full and Fair Consideration To Documented Cancer Data and Research From Independent Scientists
We need NRC employees to have the courage and integrity to acknowledge obvious harms from Limerick Nuclear Plant’s routine and accidental radiation releases and speak up to protect public health instead of nuclear industry profits. Getting the truth told is vital to stopping the unprecedented injustice of unnecessary radiation poisoning of us and our environment.
NRC must start to consider the vast body of independent research showing links between nuclear plant radiation releases and cancer.
- NRC must stop remaining in denial of a body of documented independent research.
- NRC must stop using industry biased unsubstantiated conclusions, to protect nuclear industry interests.
- NRC should stop making deceptive comparisons between continuous nuclear plant radiation releases and exposure to gamma rays from x-rays and planes.
A Long List Of Cancer Studies Show Links Between Nuclear Plants and Cancer.
U.S. and European studies, as well as four studies on PA Cancer Registry cancer data around Limerick, show increased cancers, especially in children,
Dr. Jeffrey Patterson, Professor Emeritus, University of Wisconsin’s School of Public Health and Past President of Physicians for Social Responsibility says:
- “Background Radiation” is NOT safe. We live with background radiation, but it does cause cancer”.
- “There are absolutely no safe levels of radiation. Adding more radiation ADDS to the health impacts”.
- “Exposure to radionuclides…increases risk of cancer.
- “Every effort must be taken to minimize radionuclide content in food and water.”
Dr. Steven Wing, University of North Carolina in Chapel Hill, School of Public Health said: “Generally accepted thinking is that there is no safe dose in terms of cancer or genetic effects of radiation. The claims of no threat to health…just flies in the face of all the standard models and all the studies that have been done over a long period of time of radiation and cancer”.
Dr. Chris Busby, Scientific Secretary of the European Committee on Radiation Risk said, if one plans on living a long, healthy life, the most obvious way is to reduce radiation exposure. Dr Busby’s Book, “Radiation Toxicity Syndrome” focuses on harms from radiation exposure.
NRC has long been involved in a cover-up with its dismissal and/or distortion of the effects of radioactivity from nuclear plants, even regarding the actual harms and deaths from Chernobyl, TMI, and now Fukushima.
ü Chernobyl – Almost a million people worldwide died from radioactivity discharged after the 1986 Chernobyl accident, yet NRC continues to use inaccurate low numbers. Research confirms many terrible diseases and disabilities are tied to Chernobyl.
ü TMI – That 1979 accident in PA may be responsible for thousands of deaths. “Deadly Deceit: Low Level Radiation – High Level Cover-up” suggests between 50,000 to 100,000 EXCESS DEATHS occurred after the TMI accident.
Two Studies By The Radiation and Public Health Project (RPHP), Along With Cancer Rates Around Limerick Nuclear Plant Show Links
Strontium 90 (SR-90) in Baby Teeth Is The Smoking Gun.
The Radiation and Public Health Project’s “Tooth Fairy Study” verified Strontium-90 radiation in the baby teeth collected from children around Limerick Nuclear Plant. (Reported 2003).
- Limerick Nuclear Plant’s role in SR-90 in baby teeth around Limerick is clear.
- Strontium-90 was routinely released into our air and water from Limerick Nuclear Plant since 1985.
- SR-90 was detected around Limerick in water, milk, soil, and vegetation (2009 Exelon Report).
- SR-90 was detected in the teeth of children living in the region around Limerick, at some of the highest levels around nuclear plants studied in the U.S.
- Limerick Nuclear Plant’s 28 years of SR-90 releases were obviously the major factor.
- Still NRC has attempted to blame 50-year old bomb testing far from Limerick, when Limerick routinely released SR-90 into our air and water since 1985.
Strontium-90 (Sr-90) Links to Limerick and Research
- The Radiation and Public Health Project’s “Tooth Fairy Study” showed SR-90 in baby teeth of children living near Limerick Nuclear Plant have some of the highest levels of Strontium-90 of any area around nuclear plants or other areas studied in the U.S.
- Children living near Limerick have suffered some of the highest cancer rates in the U.S., skyrocketing after Limerick opened in1985 to the late 1990s.
- Childhood cancer rates rose from 30% higher than the national average in the late 1980s to 92.5% higher in the late 1990s. Limerick started operating and releasing SR-90 in 1985.
- Exelon’s 2009 Radiological Monitoring Report for Limerick confirms SR-90 is in our water, soil, vegetation, and milk.
- Signature cancers of Sr-90 are cancers of the bone, including Ewing’s Sarcoma.
- Sr-90 closely resembles calcium and is readily taken up into the bones and teeth – considered the most hazardous bone-seeking element of nuclear fission because it so closely resembles calcium.
- Sr-90 lodges near the bone marrow, where stem cells form blood and immune system cells, increasing risk of many forms of cancer, especially in newborn infants.
- Sr-90 is considered very hazardous because of its long half-life of 28 years. Low dose exposure to
Sr-90 is so serious because of protracted exposure over periods of days, months or years.
- Research confirms that low dose exposures over months or years can be hundreds to thousands of times more damaging than the same dose received in short diagnostic medical exposures or flashes from a nuclear bomb explosion. (Petkau)
- Damage is known to involve the developing immune, hormonal, and central nervous systems of infants and children.
For reliable links between Strontium-90 in baby teeth and nuclear plants, refer to the well researched and informative book: Radioactive Baby Teeth: The Cancer Link by Joseph Mangano, Radiation and Public Health Project.
THYROID CANCER - “Epidemic” Around Nuclear Plants
The 2009 scientific article reported a Thyroid Cancer Epidemic in a small 90-mile radius encompassing eastern PA, central New Jersey, and southern New York, where 16 reactors are located, including Limerick Nuclear Plant.
Dr. Lewis Cuthbert, ACE President expressed The Alliance For A Clean Environment’s extreme concerns about the shocking thyroid cancer increases and rates above the national average in the region around Limerick Nuclear Plant, since Limerick started operating in 1985.
Documented statistics show shocking thyroid cancer increases in Montgomery County, home of Limerick Nuclear Plant, since Limerick started operating in the mid 1980′s to the mid 1990′s.
- THYROID CANCER SKYROCKETED After Limerick Nuclear Plant Started Operating in 1985
In Montgomery County, Home Of Limerick Nuclear Plant
128% INCREASE – 1985-86 to 1996-97
Source: Pennsylvania State Cancer Registry
- 1998,1999, 2000 – Thyroid Cancer Rate Was About
75% HIGHER - Than U.S. Rate (Also Rising)
Source: CDC Website
- Thyroid Cancer Rates Are Far Higher Than National Average
In Counties Closest Most Impacted By Limerick Nuclear Plant’s Radioactive Emissions
56.2 % Higher THAN U.S. - Montgomery County
53.9 % Higher THAN U.S. - Chester County
14.6 % Higher THAN U.S. - Berks County
While Berks County is Upwind – It is still higher than the U.S. Average
Source: U.S. Centers for Disease Control and Prevention, http://statecancerprofiles.cancer.gov.
Rates adjusted to 2000 U.S. standard population.
- Our region’s thyroid cancer rates are horrific, considering they’re above the U.S. average when, U.S. (1980 – 2006) Increased 154.7 % and PA (2001- 2005) Had The Highest Thyroid Cancer Rates In U.S.
LINKS ARE CLEAR BETWEEN
Limerick Nuclear Plant’s Routine Radiation Emissions
And Horrific Thyroid Cancer Rates Around It
- Limerick Nuclear Plant’s routine Iodine-131 radiation releases into our air and water impact the thyroid.
Proof: Distribution of KI pills for the thyroid in case of an accident or attack.
- Those Closest and Downwind To Limerick Have Highest Thyroid Cancer Rates.
Research Links Thyroid Cancer
And Radiation Emissions From Nuclear Plants.
- Nuclear plants, including Limerick, routinely release radioactive iodine. Radioactive iodine attacks the thyroid gland, a fact confirmed by the potassium Iodide pills issued to residents within 10 miles of a nuclear plant to protect the thyroid in case of an accident or terrorist attack.
- Thyroid cancer is one of the most radiation-sensitive cancers. Radioactive iodine released from nuclear plants seeks out the thyroid gland and destroys its cells.
Is Far Higher Than The National Average In Every Age Group In Six Communities Close To Limerick Nuclear Plant.
Includes Lower Pottsgrove, Upper Pottsgrove, West Pottsgrove, Pottstown, North Coventry, Douglass Berks
Breast Cancer By Age (diagnosed 1995-1999) Compared to the National Average
Age % HIGHER than U.S.
0-29 + 15.3 %
30-44 + 51.4 %
45-64 + 39.3 %
65+ + 28.6 %
Source: Pa Cancer Registry
Breast Cancer is an epidemic nationwide. It is alarming when Breast Cancer Statistics Around Limerick Nuclear Plant are so far higher than the national average in every age group.
Breast Cancer Average Statistics Above U.S. Average
1995-1999 Local Rate per 100,000 % Above % Above
Type of Cancer Cases Gr. Potts. U.S. Oth. 3 Co. U.S. Tri County
Breast (female) 263 161.5 116.0 129.8 +39.2 % +24.5 %
BREAST CANCER – INCREASED 61%
In Montgomery County, Home of Limerick Nuclear Plant, After Limerick Started Operating.
Source: PA Cancer Registry 1985-86 to 1996-97
Research That Links Breast Cancer With Radiation Exposure
- The Chernobyl experience confirmed that children exposed to radiation have a greater likelihood of developing breast cancer as adults. Source: Life Extension, 12/04 (60)
- John W. Gofman, M.D., Ph.D. “Our estimate is that about three-quarters of the current annual incidence of breast-cancer in the U.S. is being caused by earlier ionizing radiation… Source: “Preventing Breast Cancer” 1995
- “Life’s Delicate Balance” Causes and Prevention of Breast Cancer. Janette Sherman, M.D. Analyzes Links Between Cancer and Radiation and Other Toxics.
· Analysis of 350 Studies Finds Half of Breast Cancers are Tied to Environment and Unrelated to Genetic Risk or Lifestyle Choices.
LEUKEMIA – Rates Near Limerick Nuclear Plant and Links
Leukemia Rates (1985 to 1994) Were Almost Double the State Average
According to the Montgomery County Health Department Study on PA Cancer Registry Statistics.
Leukemia represented the largest number of childhood cancers among the 92.5% childhood cancers rates higher than the national average.
Leukemia rates were significantly higher than the national average in six communities near Limerick Nuclear Power Plant
Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, DouglassBerksTownship
Statistics: Joseph Mangano, MPH MBA National Coordinator RPHP
(Ages 0-19) All Cancers Diagnosed from 1995-1999 Rate per 100,000
Type of Cancer Cases 0-19 Gr. Pottstown U.S. %AboveU.S. Significance
All Cancers 40 28.33 16.04 + 76.6 p<.02
Leukemia 13 9.21 3.89 +136.8 p<.055
(Source: PA Cancer Registry) Reported June 25, 2003
Note: Rates calculated using 1990-99 annual Greater Pottstown population 0-19 of 14,120.
For example, leukemia rate = 13 cases/10 years/14,120 x 100,000 = 9.21.
More Leukemia Links:
- A review of 17 medical journal articles by researchers from the Medical University of South Carolina showed that child leukemia rates were elevated at all 17 reactors.
- Leukemia death rates in U.S. children near nuclear reactors rose sharply in the past two decades, according to a study published in the European Journal of Cancer Care in 2008.
- Leukemia rates in Chernobyl children confirm a link.
The Leukemia Rate has been higher than the other parts of the three county area for at least 15 years with a total of 106 cases from 1985 when Limerick Nuclear Plant started operating to 1999. (see below)
Leukemia incidence per 100,000, age adjusted to 1970 standard – Period Greater Pottstown (cases) Other 3-county % Above/Below
1985-89 9.5 (27) 7.1 +33.8%
1990-94 16.6 (44) 8.7 +90.8%
1995-99 11.6 (35) 10.6 + 9.1%
The 15 year leukemia rate is approximately about 40% above the other three county rate.
This is a statistically significant difference (p<.01)
For the period 1995-99, there were 35 newly-diagnosed cases in the area. The age-adjusted rate was 11.6 per 100,000, higher than the rest of the three counties, the state, and the nation (See Table below).
Leukemia incidence per 100,000, age adjusted to 1970 standard, 1995-99 Area Rate (cases) % Above/Below Gr. Pottstown
Greater Pottstown 11.6 (35)
Other 3-county 10.6 + 9.1%
Pennsylvania 9.7 +19.6%
United States 10.4 +11.5%
Source: Penn State – Graduate Student Research
IN POTTSTOWN - The Address of Limerick Nuclear Power Plant
BRAIN CANCERS WERE SIGNIFICANTLY HIGHER
ü Than state and national averages
ü Than municipalities in a 12 mile radius
Statistics: PA Department of Health, Bureau of Health Statistics ( 2001, August)
Analysis of cancer incidence in PA counties 1994-1998 http://www.health.sate.pa.us/stats Professor – Dr. Steven Couch
Municipality-level statistics cannot account for the high numbers of brain cancers in Pottstown. 1999 Brain Cancer Statistics – Rate per 100,000 in Pottstown 9.25
In the six communities studied close to Limerick Nuclear Power Plant.
Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, Douglass Berks Township
BRAIN/CENTRAL NERVOUS SYSTEM CANCERS
ü COMPARED TO NATIONAL AVERAGE 38.3 HIGHER
ü COMPARED TO TRI COUNTY 32.5 HIGHER
UPWARD TREND – Brain/Central Nervous System cancer statistics since Limerick Nuclear Plant started operating in 1985.
ü 1985-89 15 cases
ü 1990-94 19 cases
ü 1995-99 23 cases
CHILDREN – BRAIN / CENTRAL NERVOUS SYSTEM CANCERS ARE AMONG THE HIGHEST CHILDHOOD CANCERS In six communities studied that are close to Limerick Nuclear Power Plant.
Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, Douglass Berks Township
According to PA Cancer Registry (1995-1999)
Another Link: Cancer Near German Reactors
NRC’S CONCLUSIONS FOR LIMERICK’S DRAFT EIS FAILED TO ACKNOWLEDGE DOCUMENTED EVIDENCE LISTED ABOVE RELATED TO RADIATION AND ALARMING INCREASED CANCERS IN COMMUNITIES NEAR LIMERICK NUCLEAR PLANT.
- NRC HAS NO PROOF THAT LIMERICK’S RADIATION IS NOT A MAJOR FACTOR IN THE DOCUMENTED CANCER RATES IN COMMUNITIES NEAR LIMERICK THAT ARE ELEVATED FAR ABOVE THE NATIONAL, STATE, AND TRI-COUNTY AVERAGES.
- CLEARLY, LIMERICK IS A MAJOR FACTOR. IT IS INCUMBENT UPON NRC TO AT LEAST ACKNOWLEDGE THE PUBLIC CONCERNS ABOUT THE HIGH CANCER RATES AND LIMERICK’S RADIATION RELEASES.
NRC’S Final EIS Must Reference The Documented Cancer Crisis Near Limerick. Cancer Rates Are Far Higher Than National, State, and Tri-county Averages.
- Independent research was used to highlight links listed above.
- Cancer data provided to NRC by ACE is from the PA CANCER REGISTRY and CDC WEBSITE.
- There is no acceptable excuse for NRC to dismiss this documented evidence in Limerick’s EIS.
- ACE provided NRC with additional evidence from ACE cancer mapping from distribution of 4,000 health surveys in several communities near Limerick.
- NRC has had all this documented evidence since October 26, 2011. NRC never contacted ACE to come to our office to review the cancer studies and research to which we refer, even though NRC’s Review Team was repeatedly just minutes away at the Limerick site.
- ACE does not discount other causes of cancer, but NRC cannot dismiss Limerick’s 28 years of radiation releases being a major factor in our cancer crisis.
INFANT AND NEONATAL MORTALITY RATES FAR HIGHER THAN THE STATE AVERAGE AND EVEN HIGHER THAN PHILADELPHIA AND READING.
- Infant mortality has been linked to radiation from nuclear plants. State data documents that Infant and neonatal mortality are far higher in communities around Limerick Nuclear Plant than the state average, as well as far higher than Philadelphia or Reading.
- In NRC’S Final EIS For Limerick, NRC Must Also Reference Our High Infant and Neonatal Mortality Rates, Malignant Tumors, Cardiovascular Disease, and Lower Respiratory Disease – Documented To Be Far HIGHER Than The State Average, and Even Higher Than Philadelphia and Reading.
This was reported by EPA in 2003, using state data.
For more detailed information on the cancer crisis around Limerick see www.acereport.org
#1 Radiation – “Limerick’s Routine Releases” #2 – “Cancer – Skyrocketing Increases: Links to Limerick”
#3 Radiation – “No Safe Dose”
- NRC’S ACKNOWLEDGEMENT OF INFORMATION ABOVE SHOULD REQUIRE NRC TO CHANGE ITS DRAFT EIS CONCLUSIONS ABOUT HARMFUL HEALTH IMPACTS FROM “SMALL” TO “LARGE”.
- 2. LIMERICK THREATENS A DRINKING WATER DISASTER, YET NRC IRRATIONALLY CLAIMS HARMS ARE “SMALL”
THE SCHUYLKILL RIVER IS THE VITAL DRINKING WATER RESOURCE FOR ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA. LIMERICK NUCLEAR PLANT IS SLOWLY BUT SURELY DESTROYING THE SCHUYLKILL RIVER.
LIMERICK NUCLEAR PLANT OPERATIONS THREATEN A DRINKING WATER DISASTER FOR THE ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA WHO DEPEND ON THE SCHUYLKILL RIVER FOR THEIR WATER SUPPLY.
LIMERICK NUCLEAR PLANT OPERATIONS ARE CAUSING UNPRECEDENTED THREATS AND HARMS TO THE SCHUYLKILL RIVER INCLUDING FROM:
- Radioactive Discharges
- Toxic Discharges From Cooling Towers
- Heated Discharges
- Depletion Due To Cooling Towers Insatiable Water Use
- Toxic Mine Water Pumping To Operate Limerick
WATER RESOURCES ARE THREATENED ACROSS SIX COUNTIES
- Water Resources Threatened Across Six PA Counties From Potential Limerick Meltdowns.
10-26-11 ACE provided a vast body of evidence in written testimony to NRC to analyze and put on the record for Limerick’s EIS. ACE included detailed analyses of Limerick Nuclear Plant’s water pollution permits and Limerick’s water use docket.
- ACE’S Detailed Analyses Of Limerick’s Water Pollution Permits, Water Use Docket, AND Documents Obtained Through FOIA and PA Right-To-Know, As Well As Other Information Provided to NRC Should Have Led NRC To A Clear Understanding Of The Grave Threats and Harms To The Schuylkill River And The People Using The Water As A Result Of Limerick Nuclear Power Plant Operations.
WE WERE SHOCKED TO SEE THAT NRC’S DRAFT EIS CALLED THE UNPRECEDENTED HARMS AND THREATS THAT WE DOCUMENTED IN OUR TESTIMONY, “SMALL”. NRC’S DRAFT EIS FOR LIMERICK FAILED TO ACCURATELY REFLECT LIMERICK’S UNPRECEDENTED THREATS AND HARMS TO THIS VITAL DRINKING WATER RESOURCE FOR SO MANY PEOPLE.
- IT IS INDEFENSIBLE FOR NRC’S DRAFT EIS TO CLAIM LIMERICK’S UNPRECEDENTED THREATS AND HARM TO THE SCHUYLKILL RIVER ARE “SMALL”. THE EVIDENCE SHOWS OTHERWISE!
Historic evidence proves it was clear even before Limerick Nuclear Plant was constructed, that the Schuylkill River was unable to sustain Limerick’s insatiable water use and abuse.
It is not clear that the river can continue to sustain the wide range of damages caused by Limerick operations even until Limerick’s licenses expire in 2029. There is no guarantee there will be enough safe usable water for the almost two million people and other businesses that need the Schuylkill River for their water supply until 2029. If there is a meltdown requiring massive amounts of water, others will surely lose their water supply.
- NRC’S DRAFT EIS MUST BE CHANGED TO REFLECT REALITY. FACTS SHOULD BE CLEAR, EVEN TO NRC THAT THE SCHUYLKILL RIVER CANNOT SUSTAIN LIMERICK’S USE AND ABUSE UNTIL 2049.
NRC’S DRAFT EIS CONCLUSION THAT BASICALLY DISMISSES DOCUMENTED HARMS TO THE DRINKING WATER SOURCE FOR SO MANY PEOPLE IS CLEARLY NRC REGULATORY NEGLIGENCE AND MALPRACTICE!
- NRC IS PREPARING AN ENVIRONMENTAL IMPACT STATEMENT FOR LIMERICK NUCLEAR PLANT WITHOUT ACKNOWLEDGING OR ANALYZING LIMERICK’S ACTUAL IMPACTS ON SCHUYLKILL RIVER WATER, ECOSYSTEMS, WILDLIFE AND PUBLIC HEALTH TO DATE.
- IT IS IMPOSSIBLE FOR NRC TO ACCURATELY PREDICT WHAT WILL HAPPEN UNTIL 2049 WHEN NRC FAILED TO REVIEW AND ANALYZE LIMERICK’S WATER PERMITS AND DOCKETS, AND NRC REFUSED TO MEET WITH PUBLIC INTEREST CITIZENS WHO DID REVIEW AND ANALYZE LIMERICK’S WATER PERMITS AND DOCKETS FROM BEFORE LIMERICK WAS LICENSED THROUGH THE MOST RECENT PERMITS AND DOCKETS ISSUED 4-13.
- FOR EIS DECISIONS NRC DID CONSULT WITH THE AGENCIES THAT JUST APPROVED NEGLIGENT, UNPROTECTIVE, SHAMEFUL WATER PERMITS WITH EXEMPTIONS AND LOOPHOLES THAT ALLOW LIMERICK TO CONTINUE TO:
- A. DRASTICALLY VIOLATE SAFE DRINKING WATER STANDARDS FOR THE KIND OF POLLUTION THAT TRANSPORTS LIMERICK’S RADIATION AND COOLING TOWER TOXICS INTO THE RIVER.
- B. SERIOUSLY OVERHEAT THE RIVER
- C. PUMP TOXIC UNFILTERED MINE WATER INTO THE RIVER FOR LIMERICK OPERATIONS
ACE Table Of Contents For Written Testimony to DRBC October 23, 2012 Below Provides An Overview Of Issues ACE Wanted To Discuss With NRC Related To: Limerick Nuclear Plant ‘s – DRBC – DRAFT Docket No. D-1969-210 CP-13
Concerns Expressed In ACE’s Written Public Hearing Testimony Submitted To DRBC
About Not Having Enough Safe Usable Drinking Water In The Future Are Based On:
ACE’s Reviews Of Limerick Nuclear Plant’s:
- 2011 NPDES Permit Renewal Request to DEP For Permit No. PA0051926
- 2009 Radiological Report By Exelon To NRC
- Exelon’s Current Docket Requests to DRBC
- PA Right to Know Information from PA DEP
- Freedom of Information Act Documents from DRBC
- Planned Uprates Which Will Require More Water
- Relicensing Which Would Extend Limerick’s Unprecedented Harms and Threats
From Current License Expiration in 2029 to 2049!
- 1. Overview – Why DRBC’S DRAFT Docket Is A Recipe For A Drinking Water Disaster
- DRBC Approved Every Exelon Request, Even Though They Increase Harms and Threats To The Schuylkill River, Eliminate Safeguards, and Literally Threaten A Drinking Water Disaster
- 2. Changes Needed To DRBC’s DRAFT Docket Essential To Protect Vital Public Drinking Water Resources
- Water is Life – Why An Ample Safe Water Supply Is Vital To Maintain Good Health
- 3. Limerick Nuclear Plant’s Insatiable Water Needs Impact Parts Of Six Counties
- DRBC Should DENY Increased Water Use From The Schuylkill River, Perkiomen Creek, and Tamaqua Reservoirs
- Limerick Nuclear Plant Has Long Been Using Too Much Water While Increasing Heat and Droughts Tax Vital Water Supplies
- Transporting Billions of Gallons of Water Each Year From One Region To Another For One Business Is An Injustice
- 4. Depletion of the Schuylkill River – Concerns About Not Having Enough Safe Usable Drinking Water In The Future For Almost Two Million People From Pottstown to Philadelphia. Issues Include:
- On-Going Depletion Issues
- Weakened Low-Flow Restrictions
- Concentration of Radiation and All Other Toxics In The Water
- 5. Mine Water Pumped Into The Schuylkill River To Operate Limerick Must Be Filtered By Exelon Or Stopped. Dangers Include:
- Almost 1/2 Billion Gallons Per Month Of Contaminated Mine Water Pumped At 10,000 Gallons Per Minute
- Manganese Permitted at 80 Times Safe Drinking Water Standards
- Iron Permitted at 20 Times Safe Drinking Water Standards
- Pottstown Water Issues – Related to Exelon’s Contaminated Mine Water
- 6. Limerick’s Heated Discharges Exceed Schuylkill River Safe Temperature Limits
- DRBC’s 5-Year DRAFT Docket Fails To Adequately Address Overheating The River
- Trigger for Limerick Slow Down or Shut Down When The 87 Degree Temperature Limit Is Exceeded Should Replace Allowing Exelon To Do A Spreadsheet Starting AFTER The Docket Is Approved
- DRBC Should Do Independent Temperature Testing Below Limerick’s Discharges During Heat and Drought
- DRBC’s 59 Degree Requirement Should Be Kept In Place For Precaution
- 7. Total Dissolved Solids – Why DRBC Must NOT Approve A 5-Year Docket That Releases Limerick Nuclear Plant From Compliance With A Limit That Protects Water and Health
- Limerick Consistently Violates Safe Drinking Water Standards in 5-Year Permitting for Pollution Allowing Transports Of Radiation and Cooling Tower Toxics Into The River
- Exelon Should Be Required To Filter TDS Discharges To Comply With Legal Limits To Protect Water and Health or Close
- The 30 Month Monitoring Delay Tactic In DRBC’s Docket Is Unacceptable. It Circumvents Legal Limits and Buys Time For Relicensing and Uprates, Increasing Unprecedented Harms and Threats.
- 8. DRBC Must Not Approve Unrestricted Use, In Essence, “Eminent Domain”, of Vital Water Resources for Millions Of People
- It Is An Unacceptable, Unthinkable Injustice That Millions Could End Up With No Water or Water So Radioactive It Could Not Be Used Safely, Due To A Limerick Accident or Meltdown
- DRBC’s Docket Should Not Give Limerick Nuclear Plant Unrestricted Access To All Water Resources During a Limerick Nuclear Emergency or Meltdown, Regardless of the Potential to Render Dry or Otherwise Unusable Any Well or Surface Water Supply
- 9. DRBC’s Director Should Not Control All Water Related Claims Against Limerick and Exelon For Loss Of Water
- DRBC’s Executive Director should not be given the unilateral authority to 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 has been biased in docket decisions related to Limerick Nuclear Plant, repeatedly making decisions to benefit industry profits, not public water and public health
- 10. DRBC’s Docket Must Require Public Notice and Input For All Future Exelon Requested Water Use To Operate Limerick Nuclear Plant
- The public needs and deserves an opportunity to understand and comment on their water resources
- 11. Exelon’s Payments to DRBC For Limerick’s Use of Schuylkill River Water Are Not Being Used To Protect The Schuylkill River From Limerick Nuclear Plant’s Unprecedented Use and Abuse Of The River.
- Exelon’s Payments to DRBC Provide An Incentive To Allow Increased Water Use and Discharges
- In 2007, ACE Requested That DRBC Do An Independent Study On Limerick Nuclear Plant’s Impacts On The Schuylkill River Since 1985, To Determine The Consequences Of Future Impacts Related To Current Docket Approval For More Pollution with Less Safeguards. DRBC Refused, Claiming A Lack Of Resources. But Exelon’s Yearly Payments to DRBC Suggest Otherwise.
- Apparent Underreporting and Underpayments to DRBC by Exelon Should Be Investigated and Recovered For A Study PRIOR To Approval of This Docket And Its Dangerous Loopholes
- 12. Schuylkill River Fund -This Arrangement With DRBC Promotes Deception and Buys Silence and Support For Limerick’s Unprecedented Threats and Harms to the Schuylkill River
- This Funding Should Be Used To Filter Dangerous Toxics Discharged From Limerick Nuclear Power Plant and Contaminated Mine Pit Water
- Funded Projects Present Far Less Threats Than Limerick’s Radioactive Discharges, Cooling Tower Toxics, and Wadesville Mine Water Toxics
- 13. Radioactive Discharges – DRBC’s DRAFT Docket Allows 14.2 Million Gallons Per Day Of Limerick Discharges Which Include A Broad Range Of Dangerous Long-Lived Radionuclides, Yet Limerick’s Routine and Accidental Radioactive Discharges Are Completely Ignored by DRBC In The Docket
- Testing Proves Limerick’s Radionuclides Are In The Schuylkill River, Fish, And Sediment
- Limerick’s Routine Radioactive Discharges and Radioactive Spills
- Radiation Health Impacts
- Philadelphia – Limerick’s Link To Highest Radiation Levels In Drinking Water In The Nation
- 14. Fractured Permitting and Limerick Nuclear Plant’s Toxic Assault On The Schuylkill River –
No Agency Is Protecting Schuylkill River Water, or the Health of Millions From Limerick’s Radiation. DRBC’s Docket Decisions Allow 5 Billion Gallons Of Limerick’s Discharges Contaminated With Radiation And Cooling Tower Toxics Into The River, While DRBC Gets Paid For Those Discharges, Yet Ignores Them In The Draft Docket.
- DRBC Has An Ethical Obligation To Evaluate The Actual Consequences Of Their Decisions Related To Radioactive Threats
- DRBC Must Not Issue A Docket That Allows Exelon To Circumvent Clean Water Standards For The Pollution That Transports Limerick’s Very Dangerous Radiation Into The River
- Exelon Can and Must Filter Limerick’s Outfall 001 and Mine Pit Water, To Comply With Safe Drinking Water Standards To Protect Water and Health
- 15. Cooling Tower Toxics – Tens of Thousands of Pounds of Dangerous Corrosive Toxics Are Added to Limerick’s Cooling Towers, Then End Up In Limerick’s 14.2 Million Gallons of Discharges DRBC Allows Into the Schuylkill River Each Day.
- DRBC In Essence Plans To Approve A Docket With No Limit for The Pollution That Carries These Toxics Into The River
- Exelon Cannot Be Permitted To Circumvent Clean Water Standards for This Pollution. Exelon Can and Must Filter TDS to Keep Them Out Of The River
- 16. Monitoring Is Only An Illusion Of Protection. It Fails To Prevent Harm.
- DEP’s Deceptive Testing Protocol For Limerick
- Why Exelon’s Monitoring, Testing, and Reporting Don’t Provide Full and Accurate Disclosure
- 17. Related Correspondence Showing DRBC’s Failure To Address Or Even Answer Public Interest Concerns Over The Past Six Years
- 18. Letters to the Editor Related To Limerick Nuclear Plant’s Use and Abuse Of Public Water
ACE Urged DRBC To Consider The Reality And Totality Of Docket Decisions Being Made Related To Limerick Nuclear Plant’s Use And Discharges Into The Vital Drinking Water Resource For Millions From Pottstown to Philadelphia. Unfortunately, Decisions In DRBC’s Final Docket Protected Exelon’s Interests, Not Our Vital Public Drinking Water Source.
- Precaution and Prevention Are Imperative To Avoid A Drinking Water Disaster. Yet, DRBC’s 2013 Docket For Limerick Failed To Protect Public Drinking Water. Instead It Protected Exelon’s Profits.
- NRC CONSULTED WITH THIS AGENCY THAT ABANDONED PUBLIC INTERESTS, BUT NRC REFUSED TO MEET WITH ACE OFFICERS ON BEHALF OF PUBLIC INTERESTS.
- ACE IS STILL OFFERING TO MEET WITH NRC IN OUR OFFICE TO DISCUSS ANY OF THE VITAL WATER ISSUES ASSOCIATED WITH LIMERICK’S ENVIRONMENTAL AND PUBLIC HEALTH IMPACTS.
ACE Table Of Contents Below Is From Written Testimony to PA DEP October 23, 2012 On Limerick Nuclear Plant’s DRAFT NPDES Permit No. PA0051926
And Limerick Nuclear Plant’s Unprecedented Threats and Harms To Schuylkill River Drinking Water and Public Health
- Changes Are Essential In PA DEP’s 5-Year NPDES DRAFT Permit Renewal For Limerick Nuclear Plant, To Protect Schuylkill River Water and Health For Almost Two Million People
- DEP Has The Responsibility and Mission To Protect Water and Health of PA Citizens and Future Generations
- DEP Has The Authority To Require Limerick Nuclear Plant To Comply With Safe Drinking Water Standards and to Enforce Compliance
- DEP Can and Must Revoke Limerick Nuclear Plant’s NPDES Permit If Exelon Refuses To Comply With Safe Drinking Water Limits For Pollution That Carries Radiation and Cooling Towers Toxics Into A Drinking Water Source For Almost Two Million People
- Total Dissolved Solids (TDS) Discharged From Limerick Nuclear Plant’s Outfall 001 – NPDES Permit Must Include Safe Drinking Water Limit. TDS Transports Radiation and Cooling Tower Toxics Into The River. A Safe Drinking Water Limit Must Be In Limerick’s NPDES Permit.
- This Section Dispels False Claims and Excuses for Loopholes and Exemptions in Limerick’s NPDES Permit
(From DEP Documents and FOIA Obtained by ACE) Proof:
There was a TDS Permit Limit for Limerick
Limerick Can’t Meet That TDS Permit Limit
Exelon Requested Drastic Increases for Limerick’s TDS Discharges To Avoid Violations
DEP Has Caved In To Exelon Current Demand for No Permit Limit For Limerick’s TDS
- Cooling Tower Toxics Must Not Be Exempted From Limerick’s 5-Year NPDES Permit
- Limerick’s Cooling Towers Discharge Massive Amounts of Dangerous Toxics Into The Schuylkill River With Total Dissolved Solids From Limerick’s Outfall 001
- These Toxics Can And Must Be Filtered Out To Protect Water, Public Health, and Equipment At Water Treatment Systems
- Limerick’s NPDES Permit Must Include A Requirement to Prevent Further Overheating Of The Schuylkill River From Limerick Nuclear Plant’s Continuous Discharges Heated Up To 110 Degrees (Over 5 Billion Gallons of Heated Discharges Each Year)
- The Schuylkill River 87 Degree Temperature Limit Has Been Repeatedly Exceeded
- To Protect The River and Ecosystems, The Permit Must Include A Requirement For Limerick To Slow or Shut Down Power When The River Temperature Limit Is Exceeded
- The Permit Must Include Specific Provisions for Enforcement Action
- Fractured Permitting For Limerick Is Jeopardizing Schuylkill River Water and Public Health
- No Agency or Water Company Is Protecting Almost Two Million People From Pottstown to Philadelphia, From Limerick’s Radioactive Discharges Into Their Drinking Water - NOT DEP, NOT NRC, NOT DRBC
- Fractured Permitting Allows Agencies To Avoid Responsibility, While Water and Public Health Are Furthered Jeopardized
- Why Monitoring Fails To Prevent Harm
- Monitoring is a Deceptive Tactic Used by Agencies and Industry to Promote the Illusion of Protection
- Why Exelon’s Monitoring, Testing, and Reporting Can’t Be Trusted
- Radiation – Limerick’s Dangerous Radioactive Discharges Are Transported Into The Schuylkill River With Total Dissolved Solids From Outfall 001
- Radiation Health Impacts – There Are No Safe Levels
- Limerick Nuclear Plant’s Radioactive Discharges Are Not Safe
- Filtration Of Limerick’s Outfall 001 Would Reduce Serious Threats of Health Harms to Millions
- Radioactive Spills Reveal How Exelon and Regulatory Related Negligence Jeopardize Water and Health
- Limerick’s 3-19-12 Radioactive Spill – Neither Exelon Nor Any Agency or Water Company Notified The Public Until 23 Days After The Spill
- People Using Drinking Water Taken From The Schuylkill River Had NO Opportunity To Take Measures To Protect Themselves Or Their Children
- Two Radioactive Spills Occurred In The Past Two Years
- Several Others Are Documented Over 20 Years
- There has never been clean-up or even a fine
- Philadelphia’s Radioactive Drinking Water – Limerick’s Link
- Philadelphia Had The Highest Level Of Radiation In Drinking Water In The Nation In 2011 Testing of 66 Water Treatment Systems Across the Nation
- Limerick Nuclear Plant’s Radioactive Discharges Are Just 20 Miles Upstream From Philadelphia
- Depletion of the Schuylkill River is a Major Concern Related to Limerick Nuclear Plant
- Limerick’s Cooling Towers Have Caused Significant Schuylkill River Depletion Since 1985. Limerick Withdraws Over 20 Billion Gallons Each Year From the Schuylkill River and Only Returns 5 Billion. There Has Not Been Anywhere Near 15 Billion Gallons Supplemented In Any Year.
- Depletion Causes Concentration of Limerick Radioactive Discharges, as Well as Cooling Tower Toxics, and Mine Water Toxics
- Limerick’s NPDES Permit Ignores Depletion of The Schuylkill River and Concentration of Toxics
- Mine Water Pumped Into The Schuylkill River To Operate Limerick Must Be Filtered By Exelon
- Almost 1/2 Billion Gallons Per Month Pumped At 10,000 Gallons Per Minute
- Manganese Permitted at 80 Times Safe Drinking Water Standards – Iron 20 Times Higher
- Pottstown Water Issues – Related to Exelon’s Contaminated Mine Water
- DEP Has Been A Cheerleader For Pumping Contaminated Mine Water Into The River, Despite Calling Mine Water The Worst Threat To Groundwater In PA
- DEP Should Not Issue A 5-Year NPDES Permit With Loopholes and Exemptions That Will Enable Exelon To Get Approvals for Limerick Nuclear Plant:
- Uprates to Run Limerick Harder and
- Relicensing to Operate Limerick Longer
- Both Will Have Profound Long-Term Consequences To Schuylkill River Water and Public Health.
- Schuylkill River Overview - How Limerick Nuclear Plant Operations Threaten A Drinking Water Disaster
- Precautionary Principle
- Unanswered NPDES Questions and Concerns – NO RESPONSE Since January 17, 2011.
ACE Is Still Requesting Specific Responses From DEP, In the Comment Response Document For This Hearing, To:
- Letter to Jennifer Fields 9-1-10 NO RESPONSE
- Letter to David Allard 4-4-09 NO RESPONSE
- Letters to the Editor Related To Limerick Nuclear Plant’s Use and Abuse Of Public Water
- NRC CONSULTED WITH THIS AGENCY THAT ABANDONED PUBLIC INTERESTS, BUT NRC REFUSED TO MEET WITH ACE OFFICERS ON BEHALF OF PUBLIC INTERESTS.
- ACE IS STILL OFFERING TO MEET WITH NRC IN OUR OFFICE TO DISCUSS ANY OF THE VITAL WATER ISSUES ASSOCIATED WITH THIS NPDES PERMIT AND LIMERICK’S ENVIRONMENTAL AND PUBLIC HEALTH IMPACTS.
- 10-26-11 ACE provided NRC with a substantial body of irrefutable evidence on how and why Limerick Nuclear Plant operations could result in an irreversible drinking water disaster. Limerick operations result in unprecedented threats to the Schuylkill River, a vital drinking water source for almost two million people from Pottstown to Philadelphia.
- Limerick poisons the river water with radiation, routinely and accidently discharging radioactive wastewater containing a broad range of radionuclides, some with long half-lives.
- NRC previously tried to mischaracterize Limerick’s discharges as just one radionuclide, Tritium, even though Exelon’s Radiological Monitoring Records in NRC’s own files prove the water, sediment, and fish all contain many radionuclides.
Exelon’s 2009 Radiological Monitoring Report For Limerick Shows:
- 6 of 7 Gross Beta Radionuclides Were Detected In Surface Water
- Beta Emitters Include: Iodine-131, Cesium-137, Strontium-90, Cobalt-60, Zinc-65
- Beta radionuclides can damage thyroid, liver, bone, muscles, ovaries, and cause cancer, birth defects, mutations, and miscarriages.
In WATER – 12 Different Radionuclides Were Reported
- Iodine I-131 1./2 Lives 8 Days
- Cesium Cs-134 30 Years
- Cesium Cs-137 30 Years
- Manganese Mn-54 314 Days
- Zinc Zn-65 250 Days
- Cobalt Co-58 70 Days
- Cobalt Co-60 70 Days
- Zirconium Zr-95 65 Days
- Iron Fe-59 46.6 Days
- Niobium Nb-95 35 Days
- Barium Ba-140 13 Days
- Lanthanum La-140 40 Hours
In FISH – 9 Different Radionuclides Were Reported
- Iodine I-131 8 Days
- Cesium Cs-134 30 Years
- Cesium Cs-137 30 Years
- Manganese Mn-54 314 Days
- Zinc Zn-65 250 Days
- Cobalt Co-58 70 Days
- Cobalt Co-60 70 Days
- Iron Fe – 59 456.6 Days
- Potassium K-40 1 Day
Note: The Hazardous Life of a Radioactive Isotope is Ten to Twenty Times its Half-Life
Reality: Synergistic, Additive, and Cumulative Harmful Impacts Are Obviously Significant
Problems: Many Radionuclides go Unreported and Unmonitored – Sampling Is Woefully Inadequate
and Controlled by Exelon, a Company that Can’t Be Trusted
- NRC does no testing. No independent agency ever did long-term monitoring for all the radionuclides associated with Limerick operations. But when the National Academy of Sciences says there is no safe level of exposure, the kinds and levels are not as important as the fact that almost two million people are always exposed to radiation in their water from Limerick.
- Water companies are not required to continuously monitor, test, or filter the water for all Limerick’s radionuclides.
- The Consequences Of Additive, Cumulative, and Synergistic, Radioactive Discharges From Limerick Nuclear Plant Into The Schuylkill River Since 1985 Are Obviously Significant NRC Doesn’t Test or Even Take Split Samples. Far More Radionuclides Could be In Water And Fish Than Reported. NRC Simply Reviews Exelon’s Unreliable Reports.
- Limerick Nuclear Plant Testing Reports Reveal Iodine-131 In Water and Fish. Limerick is Clearly A Major Source of Iodine-131 Found In Philadelphia Water At The Highest Levels Of Any Water Treatment Plant In The Nation, Out Of 66 Cities Tested. Philadelphia is only about 20 Miles Downstream from Limerick.
- A dangerous mix of massive toxic corrosive chemicals is discharged into the Schuylkill River from Limerick’s cooling towers. Huge amounts of toxic chemicals are added to Limerick’s cooling towers every day. Limerick uses at the site every day 94,293 to 192,614 pounds of toxic chemicals. They don’t just disappear, but instead end up in air and water pollution releases from the site. Limerick uses Sodium Hypochlorite CHLORINE at the site – 16,000 to 58,000 lbs Per DAY - Chlorine is continuously discharged into the Schuylkill River with no continuous testing to determine the extent of harm. In fact, Limerick has just been given a permit exemption for the pollution that transports Limerick’s cooling tower chlorine and other toxics into the river, unmeasured and unfiltered.
- Limerick’s discharges are violating Safe Drinking Water Standards for Total Dissolved Solids (TDS) (up to five times the safe level). TDS transports Limerick’s radiation and cooling tower toxics into the river.
ü To deal with continuous violations of Safe Standards, DEP EXEMPTED Limerick from a safe limit requirement, instead of requiring Exelon to filter the discharges.
ü NRC is turning a blind eye to this enormous threat to public drinking water health risks and the eventual additional costs to water treatment systems and their customers.
- Limerick insatiable water use by its cooling towers threatens the water supply across six PA counties.
- Limerick Nuclear Plant has slowly but surely been depleting the Schuylkill River since it started operating in 1985. Limerick withdraws more than double the amount of water every day than is withdrawn for Pottstown, Phoenixville, and Norristown in total. Limerick only returns ¼ of that to the river. Even after supplementation, the Schuylkill River had record low flows by 1999.
- To supplement the flow for Limerick operations, Exelon is pumping billions of gallons each year of toxic unfiltered mine water into the river. One toxic is permitted to be pumped into the river at 80 times higher than safe drinking water standards, even though it can cause permanent brain damage at the legal limit if showering in this water for 10 minutes each day for 10 years.
- A meltdown at Limerick could require so much water that Exelon could take everyone’s water supplies without their permission, from Schuylkill County, the Delaware River, the Schuylkill River and all its tributaries, and the groundwater from the residents and businesses surrounding Limerick.
- Limerick’s continuous heated discharges up to 110 degrees are regularly overheating the river with a temperature limit of 87 degrees. This jeopardizes the river ecosystem. Temperature restrictions for the river were just eliminated as requested by Exelon.
For A Detailed Review Of Some Of The Evidence ACE Provided To NRC 10-26-11
www.acereport.org Download #6
“Schuylkill River – Limerick Operations: Threaten A Drinking Water Disaster”
- EVIDENCE IS UNDENIABLE: LIMERICK OPERATIONS UNQUESTIONABLY RESULT IN UNPRECEDENTED THREATS AND HARMS TO THE SCHUYLKILL RIVER, A VITAL DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA.
- IT IS NOT CREDIBLE FOR NRC’S DRAFT EIS TO STATE SUCH ENORMOUS THREATS AND HARMS TO THE SCHUYKLKILL RIVER ARE “SMALL” OR FOR NRC OFFICIALS TO CLAIM NRC IS NOT RESPONSIBLE TO ANALYZE THE ENVIRONMENTAL HARMS FROM LIMERICK’S WATER POLLUTION AND WATER USE PERMITS FOR LIMERICK’S ENVIRONMENTAL IMPACT STATEMENT.
- NRC’S FINAL EIS MUST BE CHANGED TO REFLECT THE REALITY. NRC’S CONCLUSION MUST SAY HARMS TO A VITAL DRINKING WATER RESOURCE ARE “LARGE”, NOT “SMALL” AND THAT NRC CANNOT GUARANTEE A SAFE, DRINKABLE WATER SUPPLY FOR ALMOST TWO MILLION RESIDENTS AND BUSINESSES FROM POTTSTOWN TO PHILADELPHIA DURING THE PERIOD OF REQUESTED EXTENDED OPERATION.
- THE LONGER LIMERICK OPERATES THE MORE RADIOACTIVE THE SCHUYLKILL RIVER WATER WILL BECOME AND THE MORE TOXIC THE RIVER WILL BECOME FROM LIMERICK’S MASSIVE COOLING TOWER TOXICS AND MASSIVE MINE WATER PUMPING. THE RIVER WILL BECOME MORE DEPLETED AND HEATED. THE MORE RISK THERE WILL BE FOR MELTDOWNS THAT CAN CAUSE TOTAL LOSS OF WATER RESOURCES FOR MILLIONS OF PEOPLE ACROSS SIX PA COUNTIES.
- TO REDUCE FUTURE HEALTH THREATS TO MILLIONS OF PEOPLE, NRC SHOULD REQUIRE EXELON TO FILTER ITS RADIOACTIVE DISCHARGES, COOLING TOWER TOXICS, AND MINE WATER PUMPING AS A CONDITION OF RELICENSING.
- 3. RADIOACTIVE GROUNDWATER
LIMERICK’S RADIOACTIVE LEAKS AND SPILLS OVER DECADES CAUSED GROUNDWATER TO BECOME RADIOACTIVE.
- Some of Limerick’s radioactive leaks continued for long periods of time unabated.
- NRC never required clean-up of groundwater or soil and vegetation around it.
- There are countless opportunities for future leaks in the miles of buried, hard-to-inspect pipes under the Limerick site.
- For 28 years some pipes have been transporting highly corrosive, heated, and radioactive water. Aging and deterioration can cause pipes to become brittle and leak.
- Earthquakes can break and disrupt pipes. There is an earthquake fault right under the site, with four others within 17 miles.
IN NRC’S DRAFT EIS FOR LIMERICK, NRC IRRESPONSIBLY CALLED LIMERICK’S GROUNDWATER CONTAMINATION “SMALL” AND MADE INACCURATE STATEMENTS.
- GIVEN THE LACK OF INDEPENDENT PROOF AND THE HUGE INCREASING RISK FOR RADIOACTIVE LEAKS IN THE MILES OF BURIED PIPES UNDER LIMERICK’S SITE, NRC’S CONCLUSION MUST BE CHANGED FROM “SMALL” TO “UNKNOWN”.
THERE IS CAUSE FOR CONCERN, PRECAUTION, AND PREVENTION!
- AS A CONDITION OF RELICENSING, EXELON SHOULD BE REQUIRED TO CLEAN UP THE RADIOACTIVE GROUNDWATER AND SOIL THAT IS ALREADY CONTAMINATING THE SITE, TO TRY TO AVOID TRAVEL TO OFF-SITE RESIDENTIAL AND BUSINESS WELLS.
INSTEAD OF CLEAN-UPS AND PRECAUTION,
WE GET COVER-UPS AND LIES FROM NRC.
SETTING THE RECORD STRAIGHT ABOUT
RADIOACTIVE GROUNDWATER AT LIMERICK NUCLEAR PLANT
- Limerick Nuclear Plant’s Leaks and Spills Caused Radioactive Groundwater Contamination, Confirmed By Exelon’s Own Monitoring And Reports To NRC.
- At Least 12 Radionuclides Were Detected In Limerick’s Monitoring Wells.
- 15 of 15 Limerick Nuclear Plant Monitoring Wells Found Beta Radiation. Beta Emitted Can Include Dangerous Long-Lived Radionucldes Such As Strontium-90 and Cesium-137. Beta Emitters Also Include Iodine-131, Tritium, and Other Radionuclides.
- Limerick’s 600 Acre Site Has Only 15 Monitoring Wells, Placed By Exelon, The Company With A Vested Interest In The Outcome, That Has Shown It Can’t Be Trusted To Provide Full and Timely Disclosure.
- There Is No Independent Proof Radioactive Groundwater Has Not Traveled To Drinking Water Wells Around Limerick. Within 1 Mile From The Center Of The Site Are 46 Domestic Withdrawal Wells, 2 Commercials Wells, and 1 Institutional Well. Residents Wondered If Radioactive Groundwater Contamination Explains Limerick’s Purchase Of Hundreds More Acres Since The Mid 2000s. This Tactic Has Been Used By Other Polluters As A Cover-Up.
- It’s Only A Matter Of Time Until There Are More Radioactive Leaks Under Limerick From Miles Of Aging, Deteriorating Buried Pipelines Which Transported Highly Radioactive and Corrosive Liquids For Decades. Think What Happens To Pipes In Homes Over Time, That Aren’t Even Continuously Transporting Such Corrosive, Radioactive Water.
- Radioactive Leaks In Limerick’s Buried Pipelines and Fittings Could Go Undetected and Unreported For Decades, If Not Forever.
- Earthquakes Can Cause Leaking In Limerick’s Underground Pipes. Earthquakes Are Becoming Stronger and More Frequent. There Are Two Faults Within 17 Miles of Limerick, One 9 Miles Away. The 8-23-11 Virginia Earthquake Caused Shaking and Concern At The Limerick Site.
- Limerick’s Historic Radioactive Leaks and Spills Have Never Been Cleaned Up. In Fact, It Is Difficult, If Not Impossible To Completely Clean Them Up. It Is Also Costly, If Not Impossible To Completely Remove All Limerick’s Radionuclides From Drinking Water.
PREVENTION IS THE ONLY CURE FOR THREATS TO HEALTH AND PROPERTY VALUES!
Limerick Nuclear Plant Should Be Closed To Minimize Future Health and Financial Harms From Radioactive Leaks Into Drinking Water.
A 20-year license extension to operate Limerick Nuclear Plant from 2029 to 2049 would allow 60 years of transporting Limerick’s highly radioactive corrosive fluids in miles of buried pipeline under Limerick.
- Earthquakes, Combined With Deterioration Of Buried Pipes Carrying Highly Radioactive and Corrosive Fluids, Threaten Further Radioactive Groundwater Contamination At Limerick That Could Eventually Lead To A Drinking Water Disaster With No Truly Safe Solutions.
Limerick Radioactive Groundwater
Exelon’s 2009 Radiological Monitoring Report For Limerick Nuclear Plant Shows:
12 Radionuclides Are In Limerick’s Groundwater (Page 10)
Exelon And NRC Deceptively Try To Claim It’s Just Tritium
BUT EXELON’S OWN MONITORING REPORT PROVES IT’S NOT JUST TRITIUM
In Exelon’s 2009 Radioactive Groundwater Results For Limerick Nuclear Plant, 12 Radionuclides Were Identified In Drinking Water / Well Testing “Above Background”
Radionuclides ½ Life
- 1. Iodine I-131 8 Days
- 2. Cesium Cs-134 30 Years
- 3. Cesium Cs-137 30 Years
- 4. Manganese Mn-54 314 Days
- 5. Zinc Zn-65 250 Days
- 6. Cobalt Co-58 70 Days
- 7. Cobalt Co-60 70 Days
- 8. Zirconium Zr-95 65 Days
- 9. Iron Fe-59 46.6 Days
- 10. Niobium Nb-95 35 Days
- 11. Barium Ba-140 13 Days
- 12. Lanthanum La-140 40 Hours
Note: The Hazardous Life of a Radioactive Isotope is Ten to Twenty Times its Half-Life
Radionuclides Detected In Limerick’s Groundwater After Exposure Can Cause:
Cancer - Birth Defects – Mutations – Miscarriages - In 1st and/or Successive Generations
Beta Radiation Was Detected In 15 of 15 Groundwater Monitoring Locations
Beta / Gamma Emitters Harmful Health Impacts
Iodine – 131 Thyroid Ovaries
Cobalt – 60 Liver Ovaries
Zinc – 65 Bone Ovaries
Cesium – 137 Muscles Ovaries
Strontium-90 Bone, Immune, Hormonal, Central Nervous Systems
All Can Cause Cancer – All Radioactive Isotopes Emitting Gamma Attack Reproductive Organs
The National Academy of Sciences BEIR VII Report Says There Is NO SAFE LEVEL of EXPOSURE to RADIATION - Synergistic, Additive, and Cumulative Harmful Health Impacts Are Not Evaluated
LIMERICK’S GROUNDWATER TEST RESULTS
From Exelon’s 2009 Radiological Report to NRC For Limerick Nuclear Power Plant (Section A)
Gross Alpha, Gross Beta, Gamma, Uranium All Detected In Groundwater
Gross Alpha (dissolved) Detected In 9 of 15 Groundwater locations
Gross Alpha (suspended) Detected In 5 of 15 Groundwater locations
Gross Beta (dissolved) Detected In 15 of 15 Groundwater locations
Gross Beta (suspended) Detected In 3 of 15 Groundwater locations
Gamma Emitters Detected In 3 of 15 Groundwater locations
Uranium 233/234 Detected In 4 of 5 Groundwater locations
Exelon claims there is no drinking water pathway.
- But Exelon’s claim is disputed by their own report on Page12
Well Survey Around Limerick Nuclear Plant
See Graphic From Exelon’s 2009 Radiological Monitoring Report
Within 1-Mile (Radius From Center Of Limerick) From Page 12
Limerick has 1 Potable Water Supply Well 175 FEET from Reactor Building
- Hopefully workers are not drinking this water or using this water for showering or other purposes.
46 Domestic Withdrawal Wells
2 Commercial Wells
1 Institutional Well
2 Industrial Wells
1 Fire Water Well Is 500 Feet from cooling towers
- RADIOACTIVE GROUNDWATER AND DRINKING WATER THREATS
WILL INCREASE AS LONG AS LIMERICK OPERATES
BREAKDOWNS and LEAKS – There Are Countless Opportunities For Breakdowns and Leaks Under Limerick Nuclear Plant That Can Contaminate Groundwater.
- Miles of aging buried pipes under Limerick are corroding and deteriorating.
- Limerick operated since 1985.
- Miles of Limerick’s old buried pipelines transported highly radioactive and corrosive chemicals for decades. They become very vulnerable to leaks over time.
- Pipes and fittings corrode and become brittle over time, then leak.
- Leaks in the miles of underground buried pipes are hard to detect.
- Radioactive leaks in the miles of Limerick’s aging buried pipes can go undetected and/or unaddressed and/or unreported for long periods of time, if not forever. Radiation can slowly spread in groundwater to off-site wells.
- Earthquakes can cause leaks by shaking and breaking Limerick’s miles of underground pipes and vast numbers of fittings.
- Limerick is 3rd on the nation’s earthquake risk list for nuclear plants.
- Two earthquake faults are extremely close to Limerick – 9 miles and 17 miles away.
- There is great cause for concern, considering the August 23, 2011 earthquake as far away as Virginia caused shaking with potential for damage to buried pipes at Limerick.
RADIOACTIVE GROUNDWATER CONTAMINATION CAN SPREAD INTO OFF-SITE WELLS UNDETECTED NOW AND IN THE FUTURE
- Limerick is one of the 102 of 104 of our nation’s nuclear reactors that contaminated groundwater with radiation.
- Groundwater is confirmed to be radioactive under Limerick’s 600 acre site.
- Reliable monitoring to accurately determine the full extent of spreading radioactive groundwater contamination would be cost prohibitive. Radiation could poison well water for long periods of time.
- Limerick’s radioactive contaminated groundwater could have been spreading long periods of time, in any direction, in this fractured bedrock aquifer. Radioactive groundwater contamination may have already moved off the Limerick site, undetected or unreported by Exelon.
- Radiation in Limerick’s groundwater was never cleaned up. There is no plan to clean it up.
- New leaks and spills can happen without full disclosure.
- Exelon failed to fully disclose and address radioactive water contamination at some of its other nuclear plants.
- At one nuclear plant site in Illinois, Exelon failed to provide full and accurate disclosure for years, then finally supplied 600 residents with bottled water for years more until they were finally put on public water.
- The same thing could happen at Limerick,.jeopardizing drinking water and public health.
- Once groundwater becomes radioactive it is difficult, if not impossible to clean up. Exelon never tried, either here or at its other nuclear plants.
- Radiation levels detected for a specific radionuclide are not the real issue, since there is no safe level of radiation and research on synergistic harmful impacts over time are unknown.
- Any radiation level in drinking water can cause risk for cancer, immune damage, and other health harms.
PREVENTION IS THE ONLY CURE. It’s Not Likely Limerick’s Radioactive Groundwater Can Be Completely Cleaned Up.
- Once groundwater becomes radioactive, it seems impossible to completely clean it up.
- There are countless residents whose properties could become virtually worthless due to radioactive contaminated groundwater caused by leaks and spills at Limerick.
- Filtration at residents’ homes would be cost prohibitive for many.
- History shows Exelon won’t pay to filter residents’ water throughout their homes.
- All 100 to 200 radionuclides associated with producing nuclear power would have to be filtered out from all sinks and showers in a home to make it safer.
- It is difficult and very costly to try to remove all radiation from drinking water. Some water filtration companies claim it is impossible.
Why Exelon’s Monitoring and Reporting Is Not Reliable On Limerick’s Radioactive Groundwater Contamination
Exelon’s Radioactive Groundwater Monitoring Is Woefully Inadequate
- The Limerick Site Is 600 Acres With Just 15 Monitoring Wells Placed By Exelon. There Are Miles Of Aging Buried Pipelines Under Limerick Carrying Highly Radioactive and Corrosive Liquids. After decades of operation slow leaks could go undetected and unreported for long periods of time, if not forever.
- A Monitoring Diagram from Exelon’s Radioactive Monitoring for Limerick Shows Only 15 Monitoring Wells on 600 Acres (On Average, Just 1 Monitoring Well For Every 40 Acres). Diagram attached from Exelon’s 2009 Radiological Monitoring Report On Limerick Figure 1 Graphic – A-2.
- Only 15 Monitoring Wells For 600 Acres In This Fractured Bedrock Aquifer Cannot Accurately Determine The Direction Or The Extent Of Limerick’s Radioactive Groundwater Contamination.
ü Limerick Nuclear Plant is located in a fractured bedrock aquifer (Brunswick Formation).
ü Research on this kind of aquifer and statements from scientists suggest to accurately identify the extent of radioactive ground water contamination that traveled off site, wells would need to be placed 1 foot apart and stacked around the entire site.
ü Radioactive contamination can travel in any direction, at any depth, and fail to ever be detected in a fractured bedrock aquifer.
ü Hundreds of stacked monitoring wells would be needed to detect all potential groundwater contamination from miles of underground pipes, especially in this fractured bedrock aquifer.
- Placement Of Monitoring Wells Is Questionable.
Exelon, the company with a vested interest in the outcome decided where to place the monitoring wells. Exelon has shown elsewhere why it can’t be trusted.
Exelon’s attached diagram Reveals:
ü NO Monitoring Well SSE
ü Only 1 close to the site S
ü Only 1 close to the site SE
- Limerick’s Radioactive Groundwater Contamination May Have Already Contaminated Nearby Drinking Water Wells.
ü There has never been an independent study to prove nearby wells are not contaminated with radiation.
ü Exelon controls the entire woefully inadequate monitoring, testing, and reporting process.
PROOF RADIOACTIVE GROUNDWATER WAS CAUSED BY LIMERICK NUCLEAR PLANT: April 27, 2010 Letter From Exelon to NRC
RE: Limerick Nuclear Plant’s 2009 Radiological Environmental Operating Report
- In This Letter Exelon Admitted Radiation Found In Groundwater and Soil Was From Limerick Nuclear Plant
- 1. Exelon admits Cesium-137 was found in sediment and attributable to Limerick Nuclear Plant “liquid releases”.
- 2. Exelon admits Tritium was in 3 of 15 Limerick groundwater monitoring locations.
Issues Related To Exelon’s “Admission” Of Radioactive Contamination of Groundwater and Soil at Limerick:
- Exelon admits to detecting only Tritium and Cesium-137 in the groundwater and soil from Limerick Nuclear Plant leaks. That is ludicrous when a broad range of radionuclides associated with Limerick operations would logically be in Limerick’s radioactive leaks into groundwater and soil along with Tritium and Cesium-137.
- Exelon, the company with a vested interest in the outcome controls the monitoring protocol, testing, and reporting. We can’t trust Exelon, a company that failed miserably in providing full and timely disclosure about radioactive water contamination due to other nuclear plants they owned in Illinois and New Jersey.
- Exelon failed to completely clean up radioactive contamination of groundwater. Exelon says, “There are no commitments in this letter”.
- If radioactive contamination of groundwater won’t be cleaned up, then vast numbers of residential wells in the region could eventually become contaminated, as radioactive groundwater contamination spreads.
LEAKS AND SPILLS WERE DOCUMENTED AT LIMERICK NUCLEAR PLANT FOR OVER 20 YEARS
NRC Documents Prove Limerick Had Radioactive Leaks and Spills And That The Ground Water Is Radioactive.
Exelon Admitted To 4 Radioactive Leaks Over 20 years (1986 to 2006)
October 2, 2006 Mercury article by Evan Brandt on Limerick leaks.
- Exelon’s final results of a study, stated, “Limerick is not “actively” leaking radioactive tritium into groundwater or surface water.” This title suggested to many that Limerick didn’t leak which is deceptive and not true. It also absurdly suggested that tritium was the only radionuclide leaked into Limerick’s groundwater, which is proven inaccurate by Exelon’s own radiation reports to NRC for Limerick.
- Exelon spokeswoman Rapczynski described “historic releases” as 4 “unplanned liquid releases” of tritium that took place “over the past 20 years.” She said “spills occurred “in isolated area on the plant property where you don’t normally find tritium,” and claimed they were all reported to NRC and DEP.
- Rapczynski said Limerick releases were “highly diluted” tritiated water into the Schuylkill River. Tritium was found in 6 water samples taken from on-site wells at Limerick and in 1 surface water sample. Exelon said the higher levels are the result of “historic releases”.
- Both NRC and Exelon downplayed the levels of tritium found, and ignored all the other radionuclides found in Limerick’s groundwater and surface water In Exelon’s own radiation reports to NRC.
- Both dismissed a 2005 study by the National Academy of Sciences concluding that even low-levels of ionizing radiation, including tritium, pose a health risk if exposure occurs over a long period of time.
From Questionnaire Sent to NRC from Exelon about Limerick Nuclear Plant,
For Industry Groundwater Protection Initiative Voluntary Data Collection
March 2002, a Limerick Nuclear Plant steam evaporator leak discharged through the blow-down panel on the north side of the Turbine Building.
- Exelon admits this radioactive liquid release had the potential to reach groundwater.
- As a result of the steam seal evaporator leak in March of 2002, 6 inches of gravel over an area of approximately 100 square feet was shipped to a licensed offsite radioactive waste disposal facility.
From Limerick 2009 Groundwater Protection Program Report
Page 12 E. Leaks, Spills, and Releases
2-13-09 a LEAK from exterior walls of both U1 and U2 condenser bays was observed.
This Radioactive Spill Continued For Six Days.
- NO ACTIONS were required to recover or reverse groundwater plumes. It’s NO Wonder Groundwater Under Limerick Is Radioactive.
- NO investigations are on-going.
- Condensation from condenser bays was observed DRIPPING DIRECTLY TO OPEN GROUND AND ASPHALT.
- Release to ground occurred for SIX DAYS – until catch containments were installed.
- Radiation released was estimated.
- Groundwater sampling identified Tritium in 1 down gradient well, MW-LM-9 at a concentration of 1750 pCi/L.
- All data on the leaks along the condenser bay joints was added to Limerick’s decommissioning file – 10 CFR 50.75(g).
- 4-3-09 the radioactive water from the catch containments was released to Limerick’s holding pond, which releases through the liquid effluent release point at outfall 001.
- The catch containment water contained approximately 747 uCi of tritium.
How Far Has Radioactive Groundwater Traveled Over 20 Years? How Many Leaks Went Undetected and Unreported?
Why Exelon’s Groundwater Monitoring Can’t Be Trusted
At other Exelon nuclear plants, Exelon failed to provide full, accurate, and timely disclosure of leaking pipes and radioactive contaminated groundwater. Exelon failed to take immediate action when problems were found. Even when radioactive groundwater contamination could no longer be denied, Exelon didn’t replace pipes immediately. Exelon failed to report radiation leaks into water from their nuclear reactors for many years. Numerous repeated radioactive leaks went unaddressed over almost ten years at Exelon’s Braidwood nuclear plant. Exelon also had radioactive leaks at their Dresden and Byron nuclear plants in Illinois. Some called it Exelon’s “Radioactive Watergate”.
Exelon’s deception and inaction led to unnecessary health risks and diminished property value concerns.
- 22 recurring uncontrolled radioactive spills from the same buried pipe went inadequately addressed and not fully disclosed from 1996 to 2005.
- Exelon supplied 600 people with bottled water for more than four years.
- For many years there was no bottled water and even after the bottled water was supplied people are still forced to shower, cook, brush their teeth, etc. with radioactive contaminated water.
- Clean-up of so much radioactive contamination in the ground is a farce.
- Exposure increases the risk of developing cancer, according to legal papers. Ironically, while illogically claiming there was no public health threat, March 13, 2010 it was reported Exelon paid a court settlement.
- A resident said, “it’s scary to live here, but who in their right minds would buy homes here?”
- Some people questioned whether or not a $1 million settlement to spend on some environmental projects makes up for damage caused by numerous radiation leaks discovered on and around nuclear power plants reported through the years.
- A mother of a teen battling cancer said, “If the cancer is in the air we breathe or the water we drank, I don’t think there is enough money to go around. I know they admitted to the mistakes but how do you put a price tag on the environments.”
- Exelon is also paying $11.5 million to bring in a water system. Exelon is footing the bill for Godley residents to enjoy bottled water until the construction is complete.
Oyster Creek, New Jersey
Exelon failed to disclose radioactive leaks until 7 days after the Oyster Creek nuclear reactor was relicensed by NRC.
In 2009 Exelon disclosed radioactive water leaking from buried pipes 7 days after NRC re-licensed this oldest nuclear plant in the U.S. Either NRC was duped by Exelon or NRC was complicit. Either is unacceptable.
- This seriously damages trust in Exelon and NRC’s credibility in its reviews for re-licensing.
- Radioactive water reached a major New Jersey aquifer (southern Jersey’s main drinking water source), at concentrations 50 times higher than those allowed by law.
- First reported April 9, 2009, the radioactive groundwater contamination is gradually moving toward wells in the area at 1 to 3 feet a day.
- Corrosion caused the reactor’s crucial safety liner to rust and thin. How long were there undetected / unreported leaks? Is this happening at Limerick?
- NJDEP is taking aggressive action to safeguard water and hold Exelon accountable.
- The wait and see approach in response to another ‘trust us’ from Exelon resulted in exactly what some feared, contamination of one of the most significant aquifers in the region.
- NRC has failed to suspend or withdraw Oyster Creek’s license renewal.
Limerick Leak Went Unaddressed For Years
This Leak Was Reported Through Exelon’s Own Document Mailed To ACE From a Whistleblower.
- Exelon’s document proved the leak at Limerick went unaddressed for many years, yet both Exelon and NRC first publically denied the leak ever existed.
- Exelon denied this unaddressed Limerick leak, even though ACE informed Exelon the information came from a document from Exelon’s own files.
- A year later, even though they first denied the leak existed, ACE was told by NRC that the leak had been fixed.
Cause For Concern:
- Limerick’s Radioactive Groundwater Could Have Traveled Off-Site Into Residential Wells
- There Has Never Been A Comprehensive Independent Radiation Monitoring Protocol At Limerick Nuclear Plant Nor Independent Radiation Monitoring Of Well Water Around Limerick’s Reactors.
ü Exelon, The Company With A Vested Interest In The Outcome, That Has Shown It Can’t Be Trusted To Provide Full and Timely Disclosure Elsewhere, Controls The Monitoring Protocol
ü Many Radionuclides Go Unreported and Unmonitored
ü Radionuclides Detected Are Only Reported If Above Background
March, 2011 – After Fukushima, Background Levels Were Raised From 360 to 620.
Absent funding to determine full and accurate independent evidence of harm and then clean-up, precaution in decision making becomes even more imperative.
- Limerick Should Be Closed To Avoid The Risk Of More Radioactive Groundwater That Can Spread Into Offsite Residential Wells..
- Closing Limerick Is The Only Way To Minimize Future Risk Of Additional Radioactive Drinking Water.
NRC’S DRAFT EIS, IN ESSENCE, IS ALLOWING LIMERICK’S RADIOACTIVE GROUNDWATER CONTAMINATION TO SPREAD AND INCREASE
NRC Is Failing In Its Oversight Responsibility To Protect Public Health
FAILURE To Require Clean-Up of Limerick’s Radioactive Groundwater -
NRC’s records confirm radioactive leaks and spills at Limerick.
ü As A Condition of Relicensing NRC should require complete clean-up to avoid radioactive groundwater reaching public drinking water wells very close to Limerick.
ü For years, NRC has ignored its oversight and enforcement responsibilities.
NRC failed to require complete clean-up, jeopardizing nearby drinking water.
NRC’s “Leak First and Fix Later” Policy Is An Unacceptable Threat to Groundwater and Public Drinking Water.
NRC has allowed Exelon to:
- Deceive the agency
- Cut corners
- Make up their own regulations
- Stall corrective actions or even avoid them to save money
NRC Knew About Limerick’s Radioactive Groundwater For 20 Years, But Ignored Its Oversight and Enforcement Responsibility.
Evidence Confirms Why We Can’t Believe or Trust NRC To Protect Our Water:
- 1. NRC fact sheets call leaks at 102 nuclear plants a few.
- 2. NRC falsely claims huge radioactive leaks into groundwater are “minor”.
Vermont Yankee – Up to 2.7 million picocuries per liter. NOT minor.
Illinois – Exelon bought bottled water for 600 people for 4 years. NOT minor.
Oyster Creek – South Jersey’s drinking water was contaminated at concentrations 50 times higher than allowed by law. NOT MINOR.
3. NRC misleadingly suggests leaks contain only one kind of radiation, tritium.
Reactors involve 100 to 200 radioactive chemicals. Not just one is leaking into groundwater.
Radionuclides like strontium, cesium, iodine, and plutonium are also transported in
underground pipes leaking radioactive wastewater into groundwater. All can cause cancer.
4. NRC’s attempts to trivialize health impacts from tritium by misleadingly stating that
“tritium is a mildly radioactive isotope“.
Scientific studies show exposure to tritium is linked with higher cancer rates in humans.
Tritium should be securely stored for hundreds of years or it can enter the human body by
breathing, eating, and drinking (mostly from drinking water).
5. NRC absurdly claims monitoring programs confirm the leaks do not affect public
health and safety and the environment.
There’s a logical and reasonable expectation that public health and safety are unnecessarily
jeopardized. Monitoring is a farce.
- Thousands of residents relying on well water in communities surrounding Limerick Nuclear Plant deserve immediate full and truthful disclosure to protect their family’s health!
In 2002 Greenpeace called NRC’s regulation of the nuclear industry a “FARCE”. They urged shut down of U.S. nukes to “AVOID a TRAGEDY”. ACE agrees that NRC regulation is a FARCE.
- Limerick Nuclear Plant should be closed to avoid a tragedy in our region.
Below Is ACE’s Letter to NRC Expressing Our Concern About NRC’s Capitulation to the Nuclear Industry Which Is Leading To An Unfolding Radioactive Groundwater Disaster From Limerick and Other Nuclear Plants
June 23, 2010 - ACE to NRC Branch Chief
RE: NRC’s Capitulation To The Nuclear Industry About
- Potential For An Unfolding Radioactive Groundwater Disaster From Leaking Nuclear Plants
NRC’s “Leak First and Fix Later” Policy
- An Unacceptable Threat to Groundwater and Public Drinking Water.
- 102 of 104 US nuclear reactors are leaking radioactive water into groundwater from underground leaking pipes.
- NRC’s policy failed to prevent radioactive leaking. NRC’s policies are NOT protective and NOT acceptable.
- NRC should not relicense another nuclear reactor without requiring replacement of pipes.
Major Concerns with NRC Policies
- NRC allows the industry to deceive the agency, cut corners, make up their own regulations, and stall corrective actions or even avoid them to save money.
- 1. Buried pipe systems carrying radioactive water under U.S. nuclear reactors remain inaccessible, and therefore, largely uninspected and unmaintained.
- 2. Radioactive leaks into groundwater are inevitable and can go undetected and uncontained for long periods of time. Once radioactive groundwater spreads, it’s too late.
- 3. Radioactive contaminated groundwater is already proven in Illinois, New Jersey, Vermont and others.
- 4. It’s difficult, costly, and likely even impossible, to completely clean up contamination or filter all radionuclides out of drinking water.
- 5. NRC Ignored its Oversight and Enforcement Responsibility. NRC should be mandating compliance with established requirements for control and monitoring of buried pipe systems carrying radioactive effluent.
- Instead, NRC is ceding its responsibility to voluntary industry initiatives that will add 3 years on to a decades old environmental and public health risk problem. NRC turned its regulatory authority over to an industry that now plans to stall corrective actions for 3 years, for a decades old radioactive contamination problem.
ü Despite NRC efforts initiated in 1979 to prevent uncontrolled radioactive releases to groundwater, NRC is capitulating to an industry decision to take almost three more years before announcing an action plan.
- Nuclear industry stall tactics will allow radioactive contamination to spread further and result in relicensing of leaky nuclear reactors. Oyster Creek example.
It’s difficult to understand why NRC assists the nuclear industry in deceiving the public about the reality of the radioactive threats to groundwater from leaking pipes under nuclear plants.
Both NRC and the nuclear industry have avoided full and truthful disclosure of leaks and radioactive groundwater contamination, fail to immediately stop leaking, and downplay and trivialize health risks.
NRC and the nuclear industry downplay and trivialize health risks of prolonged exposure to radiation in water, which causes cancer, genetic mutations, and birth defects.
NRC’s fact sheets are downright deceptive.
ü 102 leaks are documented from1963 thru 2009, with 15 from March 2009 to April 2010.
- NRC falsely claims radioactive leaks into groundwater are “minor”.
ü January, 2010 levels up to 2.7 million picocuries per liter were reported at Vermont Yankee. That shouldn’t be called “minor” by anyone, much less NRC.
ü Exelon bought bottled water for 600 people for 4 years in Illinois. Does NRC expect the public to believe that was for “minor” contamination?
ü Oyster Creek’s radioactive contamination of groundwater is a major threat to South Jersey’s drinking water. Radioactive water at concentrations 50 times higher than those allowed by law has reached a major New Jersey aquifer, southern New Jersey’s main source of drinking water. Reported April 9, 2009, radioactive groundwater is gradually moving toward area wells at 1 to 3 feet a day.
- NRC misleadingly suggests leaks contain only one kind of radiation, tritium.
ü Reactors involve 100 to 200 radioactive chemicals. Not just one is leaking into groundwater.
ü Radionuclides like strontium, cesium, iodine, and plutonium are likely transported in underground pipes leaking into groundwater. All can cause cancer.
- NRC’s attempts to trivialize health impacts from tritium by misleadingly stating
“tritium is a mildly radioactive isotope“.
ü Scientific studies show exposure to tritium is linked with higher cancer rates in humans.
ü Tritium should be securely stored for hundreds of years or it can enter the human body by breathing, eating, and drinking (mostly from drinking water).
- NRC illogically and absurdly claims its monitoring programs to confirm the leaks do not
affect public health and safety and the environment.
With significant documented radioactive contamination of drinking water in Illinois, New Jersey, and Vermont there’s a logical expectation that public health and safety were unnecessarily jeopardized by NRC’s failed policies and inadequate protection. We don’t want the same thing to happen at Limerick that NRC allowed to happen at Oyster Creek.
NRC’s Irresponsible Policies Must Change, Starting At Limerick Nuclear Plant.
- Exelon is asking NRC for Limerick license renewal, when in Illinois and New Jersey Exelon showed it can’t be trusted to provide full and accurate timely disclosure of radioactive leaks under its nuclear plants.
- 4. AIR POLLUTION – DRASTIC INCREASES IN DANGEROUS PM-10 WERE PERMITTED FOR LIMERICK’S COOLING TOWERS IN 2009, YET NRC’S DRAFT CONCLUDED ENVIRONMENTAL IMPACTS FROM LIMERICK’S AIR POLLUTION WERE “SMALL”.
THIS KIND OF AIR POLLUTION IS CONSIDERED MORE DEADLY THAN OZONE.
- IT IS NOT CREDIBLE FOR NRC TO CLAIM THE IMPACTS FROM LIMERICK NUCLEAR PLANT’S AIR POLLUTION ARE “SMALL”.
LIMERICK’S DANGEROUS AIR POLLUTION HARMS HEALTH
- LIMERICK IS CONSIDERED A MAJOR AIR POLLUTION SOURCE UNDER HEALTH-BASED STANDARDS OF THE CLEAN AIR ACT.
Limerick Nuclear Power Plant emits so much dangerous air pollution (in addition to radiation) that it’s considered a MAJOR AIR POLLUTION source under the Clean Air Act. The following facts have been compiled by ACE from Limerick Nuclear Plant’s Title V Air Pollution Permit.
LIMERICK NUCLEAR PLANT’S AIR POLLUTION INCLUDES:
- 1. Radiation – from routine operations and accidental releases
- 2. Schuylkill River Toxics – from withdrawing 56.2 Million Gallons Per Day
- 3. Toxic Chemicals – from adding over 300 lbs per day to Cooling Towers
- 4. Greenhouse Gases, Combustion Chemicals & By-products – from Boilers, Etc.
- 5. Waste Fuel – from a Boiler
AIR POLLUTANTS from Limerick Nuclear Plant Include:
- This dangerous SYNERGISTIC MIX continuously threatens the health of families in the region, especially children. ADDITIVE, CUMULATIVE HEALTH IMPACTS could be significant.
32 SOURCES of Limerick Nuclear Plant’s Air Pollution Include:
- 2 Cooling towers
- 3 Boilers
- 8 Generators
- 8 Diesel Oil Tanks
- 8 Day Tanks
- Degreasing Unit
- Emergency Spray Pond
- Various Waste Oil Sources
- There is NO FILTRATION FOR TOXICS from any of the sources.
ACE’s review of Limerick’s air pollution permit revealed a shocking number of air pollution sources and pollutants, with no continuous monitoring or filtration on any of them. In fact, there are extraordinary permit loopholes.
Limerick’s Permit Loopholes are Unprotective and Unacceptable. Almost anything goes.
- Radiation, the signature toxic at a nuclear plant, was excluded even though radiation emissions are regulated by EPA and reported by Exelon to NRC.
- Limerick Nuclear Plant Title V permit renewal lists 32 air pollution sources and a broad range of pollutants, but excludes radiation the signature toxic released from a nuclear plant.
- No air pollution control equipment is required on any of the many sources.
- Reported emissions are based on illusion, not reality. Annual reports are largely based on Exelon’s own “calculations” and “estimates”, not on actual emissions testing. There is no independent testing.
- Exelon can increase dangerous air pollution from the nuclear plant without going through any kind of review or approval process.
- There are all kinds of exemptions.
- Preapproved permit revisions are allowed under economic incentives.
Limerick Nuclear Plant’s additive, cumulative, and synergistic harmful health impacts are unknown, but clearly significant. Children, elderly, and those already sick are most impacted.
Examples of Synergism:
- NOx + SO2 = acid rain which can jeopardize water, soil and food. When NOx and SO2 meet with steam (35 to 42 million gallons per day emitted from Limerick towers), sulfuric and nitric acids can be formed in the air causing major respiratory damage and other health harms when inhaled. Limerick’s permit allows automatic (TONS per year) increases in both.
- NOx + VOCs with sunlight increases ozone, which kills thousands of people each year and sends many more for hospital emergency room visits.
- Ozone works synergistically with radiation to enhance the cancer causing effects of radiation.
Synergistic, Additive, and Cumulative Harmful Health Impacts From Limerick’s Air Pollution Are Unknown, But Clearly Unprecedented,
When They Include:
- A Broad Range of Radionuclides
- Massive Emissions of Many Dangerous Cooling Tower Toxics
- Combustion Chemicals From Boilers and Generators
- Waste Derived Liquid Fuel
- And Various Other Sources of PM-10 Emissions
Families throughout the region are at risk from Limerick Nuclear Plant’s radiation emissions and other toxic air pollutants. Consider the following:
- Philadelphia, only about 20 miles away, is in the predominant wind direction.
- Routine radiation releases go into our air, but are not measured in air or listed in Limerick’s Title V permit.
- Limerick’s cooling towers and other sources emit massive dangerous PM 10 emissions which are not accurately measured or filtered.
- The effluent stream from the river to the sky through the cooling towers includes all river toxics.
- Cooling tower emissions include toxics added to the towers.
- No toxics are filtered out from any of the 32 air pollution sources listed in Limerick Nuclear Plant’s Title V Air Pollution Permit.
- To protect the health of everyone in the region, as a condition of relicensing, NRC should require Exelon to install the most protective filtration for all Limerick Nuclear Power Plant’s air pollution sources, and filtration of Schuylkill River water intake to minimize PM-10 emissions from the cooling towers.
Other Than Radiation, The Most Dangerous Air Pollution Comes From Limerick Nuclear Plant’s COOLING TOWERS
- Ø In 2009, Drastic Increases Were Permitted In Particulate Matter (PM-10) From Limerick’s Cooling Towers.
In Limerick Nuclear Plant’s Most Recent Title V Air Pollution Permit Renewal, Exelon Requested Drastic Increases In Dangerous Particulate Matter (PM-10) from Limerick’s Two Cooling Towers.
- Instead of requiring filtration of Schuylkill River water intake to minimize PM-10 emissions from Limerick’s cooling towers, PA DEP permitted drastic increases in PM-10 emissions (more than 6 times higher original permit limits).
Drastic Increases Permitted For Limerick’s PM-10 Are Indefensible.
How many more people will get sick and die as a result of the nasty witches brew of toxic chemicals massively spewed out in aerosol form from Limerick’s cooling towers?
PM-10 consists of tiny airborne particles that can carry other toxics, penetrate deep into the lungs, enter the bloodstream and lead to serious health threats and healthcare costs.
Long Term PM 10 Health Effects Are Linked To:
ü Increased Heart Attacks
ü Aggravated Asthma
ü Inflaming Lungs Like Sunburn On Skin
ü Increased Respiratory Disease
ü Decreased Lung Function
ü Increased Hospital Admission
ü Increased Emergency Room Visits
ü Premature Death – Blamed For Thousands Of Deaths Each Year
- To Protect Public Health, As A Condition Of Relicensing, NRC Should Require Exelon To Reduce PM-10 Air Pollution From Limerick’s Cooling Towers by Requiring Filtration Of Schuylkill River Water Intake For Total Dissolved Solids.
PM-10 IS EMITTED FROM 14 DIFFERENT SOURCES AT Limerick Nuclear Plant
ü 2 Cooling Towers
ü 3 Boilers
ü 8 Generators
ü The Emergency Spray Pond
How Much PM 10 Is Emitting From Limerick’s 14 Sources?
- NO ONE KNOWS FOR SURE! Exelon “ESTIMATES” and “CALCULATES” Limerick’s PM10 Emissions. THERE ARE NO RELIABLE AIR MEASUREMENTS.
PUBLIC HEALTH IS AT RISK FROM LIMERICK’S PM-10 EMISSIONS
- The American Lung Association says Particulate Matter is more deadly than ozone.
- Montgomery County is already among the highest for PM-10 emissions in the nation.
- PM-10 is regulated under health based standards of the Clean Air Act, because it causes serious harm to health.
- PM-10 causes more emergency room visits and hospital admissions, thus even leading to higher costs for medical care.
FACTS ABOUT PM-10 FROM LIMERICK COOLING TOWERS
- PA DEP stated that Limerick’s cooling towers are an effluent stream from the river to the sky. 35 to 42 million gallons of contaminated water go into the air every day from Limerick’s cooling towers.
PM-10 carries other dangerous toxics withdrawn with as much as 56 million gallons every day from the highly contaminated Schuylkill River with NO filtration for toxics.
- Toxic chemicals are added to Limerick’s cooling towers. Exelon’s response to ACE claimed 324 pounds per day. Most chemicals listed were extremely corrosive. All caused health harm. Pounds added per day to cooling towers could be considerably higher. Since reviewing Limerick’s NPDES permit renewal we learned over 94,293 to 192,614 Pounds Per Day of Toxic Chemicals are used at Limerick Nuclear Plant.
- Potential Limerick toxics carried into our air with PM10 from the cooling towers include:
- Radiation – Heavy Metals – Pathogens – Corrosive Chemical Additives
PM-10 Details From Limerick’s Title V Permit
In Limerick’s Title V Permit Renewal TVOP-46-00038, Exelon requested that PA DEP approve a huge increase in blowdown water from 1,256 ppmw to 10,000 ppmw for each cooling tower.
According to Exelon:
- Limiting blowdown TDS to 1,256 for each cooling tower restricts particulate matter (PM) and creates an unnecessary risk to Limerick for noncompliance.
“PA DEP Air Quality Bureau will not set the limit on TDS concentration for the blowdown entering Outfall 001, since this is a Water Quality issue.”
- DEP changed the language of the permit so that Exelon complies with both Air Quality and Water Quality requirements, instead of requiring Exelon to filter Schuylkill River water intake to reduce PM-10 emissions into our air and to enforce Limerick’s original PM-10 permit limits.
- Limerick Nuclear Plant Was Permitted Conditions That Allow Possibly An 8-Fold INCREASE From The Cooling Towers In PM-10 Emissions, A Dangerous Clean Air Act Pollutant Blamed For Thousands Of Deaths Each Year.
- This should NOT have happened, especially in a county which already ranks in the top 10% of the nation for dangerous PM-!0 emissions.
Exelon Expressed Concern About Air Pollution If They Would Install Cooling Towers As Requested By N.J. DEP, At Oyster Creek In New Jersey:
- In Essence, Exelon Admitted Cooling Tower Air Pollution Is Harmful.
Exelon used Cooling Tower Air Pollution, as an excuse to avoid spending millions to build cooling towers at Oyster Creek. Exelon said, “Cooling Towers Would Create Air Pollution”.
Limerick’s Title V Air Pollution Permit Lists 32 Air Pollution Sources and 10 Dangerous Regulated Toxics.
Air Pollutants Listed In Limerick’s Air Permit Air Pollution Sources In Limerick’s Permit
Nox 2 Cooling Towers
VOCs 3 Boilers
PM-10 8 Generators
SO2 8 Diesel Tanks
Arsenic 8 Day Tanks
Cadmium Degreasing Unit
Chromium Emergency Spray Pond
Lead Various Waste Oil Sources
- NO FILTRATION IS REQUIRED FOR ANY TOXICS LISTED ABOVE
Numerous Studies Show The Kinds Of Air Pollution Produced By Limerick’s 32 Sources Contribute To A Broad Range of Disease and Disabilities.
- World Health Organization Estimated Air Pollution Would Cause About 8 Million Deaths Worldwide by 2020
- American Cancer Society
- Harvard School of Public Health
- John’s Hopkins School of Public Health
- Cedars-Sinai Medical Center
Dr. Devra Davis reported that there are more than 1,000 studies from 20 countries all showing you can predict a certain death rate for asthma, heart disease, and lung disorders based on the amount of air pollution.
Cooling Towers Host Pathogens
Research Shows Health Threats From Cooling Towers Include Pathogens
Cooling Towers Spray Infectious Pathogens Into Our Air. These Pathogens Can Cause Disease in Humans, Even Legionella
- Section 4.9.3 on Microbiological Organisms of NRC’S DRAFT EIS States That Limerick Cooling Towers Release Microbiological Organisms, INCLUDING:
SALMONELLA, LEGIONELLA, AND PSEUDOMONAS AERUGINOSA,which can cause serious and sometimes fatal infections in immune compromised individuals.
- THESE TOXINS ARE DOCUMENTED TO BE HARMFUL TO HUMANS AND ANIMALS.
- Exelon requested PA DEP to provide comments or confirm Exelon’s conclusion about a low likelihood of risk from pathogens released from Limerick contribute to related health effects.
- PA DEP would not make any conclusions regarding the effect on public health.
- NRC says optimal growing temperature is 99 degrees F, but Limerick’s cooling tower waters are allowed to be up to 110 degrees.
NRC HAS CONCLUDED THAT IMPACTS ON PUBLIC HEALTH FROM THESE ORGANISMS WOULD BE “SMALL”, BUT THERE NO PROOF OF THAT, WHETHER IN RELEASES TO AIR OR WATER.
- 44 MILLION GALLONS Of Cooling Tower Steam Are Released Into Our Air Every Day.
- 14.2 MILLION GALLONS Of Limerick’s Wastewater Are Released Into The River Every Day.
- There Are NO Measurements By NRC Or Exelon For The Pathogens In The Air Or River Releases From Limerick’s Cooling Towers.
- Limerick’s Cooling Tower Waste Water Is Allowed To Be Heated Up To 110 Degrees.
- NRC HAS NO ACCURATE IDEA OF HOW THESE PATHOGENS ARE IMPACTING THE POPULATION OVER TIME.
- NRC MUST CHANGE ITS CONCLUSION THAT IMPACTS WOULD BE “SMALL” TO IMPACTS ARE “UNKNOWN”.
COOLING TOWER DRIFT – DRIFT IS SPRAY DROPLETS – NOT VAPOR
- Drift Droplets Are Contaminated With Everything In The System
- Up to 44 Million Gallons of Toxic Filled Steam Are Emitted Into Our Air Every Day.
- There Is NO Filtration – Exposure Risks Are Unknown
Drift Can Contain:
- Radiation – A Broad Range of Radionuclides
Examples: Iodine 131 – Major Isotope Known To Be Released
Strontium-90 – Found in our children’s teeth
Radioactive Crypton – Upsets of electromagnetic imbalance
- Heavy Metals – From Schuylkill River Water Intake
- Pathogens and Microbes – Science Daily 8-28-08
- Toxic Chemicals In Limerick Nuclear Plant’s Drift Come From:
1) Schuylkill River Water Withdrawn
58.2 Million Gallons Per Day 20 ½ Billion Gallons Per Year
2) Every day Exelon Adds Massive Amounts Of Toxic Chemicals To Cooling Towers
Toxic/Corrosive Chemicals Added To Limerick’s Cooling Tower Water
- According to Exelon: 324 Pounds Used EACH DAY 118,260 Pounds Used PER YEAR
- Could be far more – Over 94,293 to 192,614 Pounds Per Day Of Toxic Chemicals Are Used At Limerick Nuclear Plant.
- Examples of Toxic Additives From Limerick Nuclear Plant’s MSDS Sheets Are Listed Below. ACE listed corrosives showing why there is cause for concern about corrosion of steel used for Limerick casks and other equipment.
- Sulfuric Acid Corrosive to metals
- Phosphoric Acid Corrosive to steel / most metals
- Phosphonic Acid Corrosive to steel
- Hypochlorous Acid Corrosive
- Sodium Bromide and Water Corrosive
- Sodium Hydroxide Corrosive to metals
- Sodium Hypochlorite solution Hyprocochloris Acid – Corrosive
- Sodium Per Sulfate MSDS says avoid moisture / Incompatible with moisture
- Zinc Oxide Breaks down structures such as steel
- Ethyl Alcohol Weak Acid - can be Corrosive
- Chlorine World Health Organization Limits Air Exposure
- While All Toxics Above Can Be Carried With Limerick’s Drift, PM10 Is The Only Cooling Tower Air Pollutant Required to be Reported By Exelon In Limerick’s Title V Air Pollution Permit.
PROOF OF ENORMOUS HEALTH RISK FROM CORROSIVE CHEMICALS ADDED TO LIMERICK’S COOLING TOWERS:
- CHLORINE FROM LIMERICK’S COOLING TOWER PLUME CAN CORRODE STAINLESS STEEL.
INDUSTRY STUDIES SHOW CRACKS CAN OCCUR IN STAINLESS STEEL IN 4 TO 52 WEEKS.
Chlorine is added to Limerick’s Cooling Towers as Sodium Hypochlorite
Limerick Uses 16,000 to 58,000 POUNDS PER DAY of Sodium Hypochlorite
- KNOWING CHLORINE FROM LIMERICK’S COOLING TOWER AIR EMISSIONS CORRODES STAINLESS STEEL, WE MUST ASK WHAT IS IT DOING TO PEOPLE’S LUNGS?
How we know:
Related to a recent NRC safety inspection report letter to Exelon for relicensing, NRC expressed concern about chlorine contaminated air at Limerick and its corrosive impacts on stainless steel.
- Exelon Said There Was No Concern Because “The Cooling Tower Plume Is Directed Away From The Plant.”
- In Essence, Exelon Admitted The Region’s Residents Are Breathing Highly Corrosive Air From Limerick’s Cooling Towers.
- This Could Explain The Extraordinary Lung Problems Experienced In The Region Around Limerick, Including Lung Cancer.
- EVEN THOUGH EXELON INADVERTENTLY ADMITTED PEOPLE WERE BREATHING HIGHLY CORROSIVE AIR, NRC TOOK NO ACTION TO PROTECT PUBLIC HEALTH.
Toxics In Drift Synergize and Blow Far Distances
How far is drift carried from Limerick Nuclear Plant?
- 2 Cooling Towers Are 500 Feet High (Comparable to a Building over 40 Stories High)
- Independent measurements are needed over Limerick Nuclear Plant site boundary
Drift Travels Far Distances - Example: From One County to Another
- Dispute Over Russian Border – 1 country complained about cooling towers contaminating their side of the border.
- Levels over site boundary were greater than permitted - Maine Yankee violations led to company stopping using one chemical after testing
Toxics In Drift Concentrate When They Hit Land and Dry.
- River Bend – Needed a separate parking lot to shelter cars due to active concentrations
Our Region Is Already Overexposed To Air Pollution Compared To The Nation
- Montgomery County Is In The Top 10% Of The Nation For Emissions Of PM-10 and VOCs
- Montgomery County Is In The Top 20% For SO2 Emissions
- Still, DEP Permitted INCREASES In Limerick’s Title V Permit
PM10 Particulate Matter + 3 TONS
VOCs Volatile Organic Compounds + 5 TONS
SO2 Oxides of Sulfur + 8 TONS
NOx Nitrogen Oxides + 5 TONS
CO Carbon Monoxide + 20 TONS
American Lung Association’s 2003 Report Gave Montgomery County A Grade Of “F” For Unhealthy Air
- Montgomery County Had 2nd Dirtiest Air in the State, Far Worse Than Philadelphia, Berks, or Chester Counties, “State of the Air Report for 1999-2001.”
Examples Of Harmful Health Impacts and Synergism
PM-10 Particulate Matter
ü Increases Heart Attacks and Strokes
ü Aggravates Asthma
ü Inflames Lungs Like Sunburn
ü Increases Respiratory Disease
ü Decreases Lung Function
ü Increases Hospital Admission and Emergency Room Visits
ü Blamed For Thousands Of Premature Deaths Each Year
VOCs Volatile Organic Compounds
ü Liver Damage
ü Kidney Damage
ü Digestive Disorders
ü Neurological Disorders
ü Reproductive Problems
ü Decreased Immune Function Leading to Many Illnesses
VOC’s Extremely TOXIC In Small Amounts
NOx Nitrogen Oxides
ü Immune System
ü Skin and Sense Organ
NOx reacts with moisture and other compounds to form nitric acid and related particles.
VOCs + NOx = Ground-Level OZONE
Acute, Short Term Effects include:
ü Shortness of Breath
ü Phlegm Build Up
ü Coughing, Wheezing
ü Watery Eyes, Runny Nose
ü Sore Throat
ü Head Colds
ü Chest Colds
ü Chest Pain
Repeated Exposure Can Result In:
ü Permanent Lung Damage
ü Respiratory Infection
ü Lung Inflammation
ü Aggravate Asthma
RADIATION INTERACTING WITH OZONE ENHANCES CANCER RISKS
From Mc Donnell, M.D. Health Effects Research Laboratory
EPA Testimony, April 9, 1987, to U.S. Senate
Ø “OZONE WORKS SYNERGISTICALLY WITH RADIATION TO ENHANCE THE CANCER-CAUSING EFFECTS OF RADIATION.”
Radiation, the most potent carcinogen, is routinely released from Limerick Nuclear Plant. Radiation is the signature, most dangerous toxic released from nuclear plants. Radiation levels released cause more risk of cancer when breathed in with VOCs and NOx.
January 2010, ACE presented agency and elected officials with an expose and list of recommendations and requests related to permitted PM-10 increases at Limerick Nuclear Plant.
Sources Used For ACE Air Pollution Comments:
Limerick Title V Permit Renewal TVOP-46-00038 12-7-09
EPA Air Pollution Data – Compiled At www.scorecard.org
AP 3-19-10 Article in Mercury by Wayne Parry “Exelon Threatens to Shut Down N.J. Nuke Plant”
Statistics and Facts in Hard Science Show: Air Pollution Kills and Cripples, Net Works 2001
Cooling Towers May Host New Pathogens – Research by Sharon G. Berk and colleagues – ScienceDaily 8-28-06
All evidence of harm was ignored. Public health was abandoned. Agency regulators and elected officials ignored the increased threats to public health and increased financial health care costs, all to protect Exelon’s profits.
GIVEN THE HEALTH IMPACTS DOCUMENTED TO BE ASSOCIATED WITH THE KIND OF TOXIC AIR POLLUTION RELEASED FROM LIMERICK, ESPECIALLY FROM THE COOLING TOWERS, LIMERICK NUCLEAR PLANT IS AN OBVIOUS MAJOR FACTOR IN:
- State Data Reported By EPA In 2003 SHOWING FAR HIGHER NUMBERS FOR:
ü Infant and Neonatal Mortality
ü Malignant Tumors
ü Cerebrovascular Disease
ü Respiratory Diseases
ALL ARE FAR HIGHER NEAR LIMERICK NUCLEAR PLANT THAN THE STATE AVERAGE, AND FAR HIGHER THAN PHILADELPHIA OR READING.
ACE Summary Conclusions:
- Limerick Nuclear Power Plant Is A Major Air Pollution Source Under Health Based Standards Of The Clean Air Act and Is Clearly A Major Factor In The Health Crisis That Developed After Limerick Started to Operate in 1985.
- Yet, NRC Has Repeatedly Attempted To Ignore and/or Dismiss Limerick’s Air Pollution Threats To Health and The Environment In Limerick’s Updated Environmental Impact Statement (EIS).
- Fractured Agency Permitting Is NOT An Excuse To Dismiss Serious Environmental and Health Impacts From Limerick Nuclear Plant’s Major Air Pollution For NRC’s Updated EIS. Just Because PA DEP Issues Limerick Nuclear Plant’s Air Pollution Permit Does Not Eliminate The Harms Our Region Faces From It.
- Without a year of independent air monitoring, testing, and reporting for all Limerick Nuclear Plant’s radionuclides and other air pollutants, the community should reject any NRC conclusions in NRC’s updated Environmental Impact Statement for Limerick Nuclear Plant as invalid.
- Unless additive, cumulative, and synergistic harmful health impacts from radiation releases and all other air pollutants from Limerick are accurately determined, including from recent permitted drastic increases, the Precautionary Principle should be followed and Limerick should be closed, NOT RELICENSED.
- As long as Limerick Nuclear Plant operates, dangerous air pollution will continue and even increase.
- To protect public health and avoid unnecessary health care costs, Limerick should close now.
- 20 more years of exposure to the massive toxic brew of air pollution from Limerick is unacceptable. Limerick must close now.
Documents and Other Information Are Available For Review By Appointment At The ACE Office In Pottstown (610) 326-2387
NRC IS RESPONSIBLE TO PROTECT PUBLIC HEALTH RELATED TO LIMERICK NUCLEAR PLANT.
- THE EVIDENCE PROVES LIMERICK’S AIR POLLUTION IS A MAJOR THREAT TO PUBLIC HEALTH. AS A CONDITION OF RELICENSING, NRC MUST REQUIRE EXELON TO FILTER SCHUYLKILL RIVER WATER INTAKE, AND NOT ALLOW LIMERICK’S DANGEROUS AIR POLLUTION TO CONTINUE WITHOUT AT LEAST SOME SAFEGUARDS.
RADIATION RELEASES TO AIR
- Limerick routinely releases a broad range of radionuclides into the air.
- Radioactive air particulates are not listed in Limerick’s Title V Air Permit, even though all air pollutants and sources from a major air polluter are supposed to be listed.
- Actual data and/or harmful health impacts from Limerick’s routine and accidental radioactive releases are unknown.
Radiation Testing and Reporting To NRC Are Deceptive
- Ø Radiation Levels Reported By Exelon For Limerick’s Releases To Air Do Not Reflect Risks To The Public From All Limerick’s Radionuclides Released Into Our Air.
- JUST BECAUSE EXELON ISN’T REQUIRED TO REPORT ALL RADIONUCLIDES LIMERICK RELEASES INTO OUR AIR, DOESN’T MEAN THOSE RADIONUCLIDES DO NOT INCREASE OUR RISK.
Radiation Levels identified by monitoring are only reported for Limerick by Exelon when they are above an arbitrary background level. Above background reporting is deceptive. Exelon can hide actual radiation releases from Limerick and actual risks.
Radiation Background Levels Are Arbitrary, Deceptive, and Clearly Not Protective:
- 80 to 100 Millirems Per Year – Natural background BEFORE Chernobyl
- 360 Millirems Per Year – AFTER Chernobyl
- 620 Millirems Per Year – AFTER Fukushima, Japan
The National Academy of Sciences Says There Is NO SAFE DOSE
March 16, 2011, After Japan’s Nuclear Disaster, NRC Legally Sanctioned Increased Radiation Harm To Regions Like Ours, Routinely Exposed To Nuclear Plant Radiation Releases.
Other Deceptive Unprotrective Tactics In Radiation Reporting
- Exelon, the company with a vested interest in the outcome that has shown it can’t be trusted, controls all radiation monitoring, testing, and reporting.
- Exelon is allowed to ‘CALCULATE” and “AVERAGE” results.
- The system fails to report on radiation spikes.
Examples From Exelon’s 2007 Self-Monitoring Report to NRC
- Lower Limit Detection (LLD) – ABOVE BACKGROUND IS DECEPTIVE.
Defined as smallest concentration of radioactive material in a sample that would yield a net
LLD does not mean the actual level detected - Level detected could be far higher
- Positive Results Were “CALCULATED” – Gamma Spectroscopy
Standard deviations represent variability of measured results for different samples rather than single analysis uncertainty.
- 3. Net Activity – Calculated by subtracting background from sample.
MDC was reported in all cases – but they can claim positive activity was not detected.
Radioactive Air Particulates – Air particulate samples collected weekly in 2007.
- GROSS BETA WAS DETECTED AT ALL LOCATIONS.
Beta Emissions Can Include Strontium-90, Tritium, and Many Other Radionuclides
- GAMMA WAS DETECTED IN ALL SAMPLES
Be-7 Beryllium 7: UNstable (1/2 life 53 days) was detected in all samples
Beta Particles and Gamma Rays Penetrate the Human Body and Environment, Causing Biological, Chemical, and/or Physical Damage.
- Cancer, Leukemia, Heart Failure, Neuromuscular Diseases and Many Other Health Effects Can Result From Long-Term Exposures.
- Harmful Health Impacts Can Take Many Years To Develop.
Examples: Harmful Health Impacts To Specific Parts Of The Body
- Thyroid / Ovaries Iodine – 131 Beta / Gamma Emitter
- Liver / Ovaries Cobalt – 60 Beta / Gamma Emitter
- Bone / Ovaries Zinc – 65 Beta / Gamma Emitter
- Muscles / Ovaries Cesium – 137 Beta / Gamma Emitter
- Bones / Teeth Strontium-90 Beta Emitter 29 year half-life
- Strontium 90 (SR-90) Attaches To Particulate Matter – Easily Travels With Air
SR-90 Masquerades As Calcium – Absorbs Into Bones and Teeth.
- Some of the highest levels of Strontium-90 were found in the teeth of children around Limerick Nuclear Power Plant (Tooth Fairy Study)
All GAMMA Radiation Emitters Attack REPRODUCTIVE ORGANS
- Prostate Cancer Increased in Montgomery County 132% Since Limerick Nuclear Power Plant Started (Mid 1980s to Mid 1990s)
- Other related cancers also drastically increased above the national average since Limerick started operating.
Radiation Can Cause Birth Defects, Mutations, and Miscarriages,
- In 1st and / or Successive Generations After Exposure.
- Infant death and childhood cancer reductions after nuclear plant closings in the United States – 2002 Study – Deaths among infants who had lived downwind and within 64 km of each plant dropped.
- Infant and Neonatal Mortality In The Area Around Limerick Are Far Higher Than State Averages and Higher Than Philadelphia or Reading.
Other radionuclides in testing were claimed by Exelon to be less than the MDC
- BUT Minimum Detectable Concentration (MDC) Is Only An ESTIMATE and Only Reported IF Above Background
Limerick Nuclear Plant’s Air Pollution Summary:
- 10-26-11 ACE provided NRC with documented details for Limerick’s EIS public hearing comments. Our analysis of Limerick’s Title V air pollution permit and other documentation show why Limerick’s air pollution is a “major” threat to our region.
- NRC ignored this evidence in Limerick’s DRAFT EIS conclusions or NRC could not have concluded Limerick’s air pollution impacts are “small”. NO unbiased person could analyze the evidence and the reality and still come to that conclusion!
To avoid air pollution permit violations, in 2009, Limerick requested and received a 6-fold INCREASE in its Title V Air Pollution Permit limit for dangerous cooling tower air pollution that is considered more deadly than ozone by the American Lung Association.
- Exelon’s request for huge PM-10 permit increases to avoid air pollution permit violations alone makes our case.
Limerick’s cooling towers release 44 million gallons of steam into the air every day containing massive PM-10, which transports into our air Limerick’s radioactive air particulates, toxic and corrosive chemicals added to Limerick’s cooling towers by Exelon, toxics from the Schuylkill River including heavy metals, and pathogens from inside the cooling towers.
- Limerick’s Cooling Towers Emissions Result In A Constant Enormous and Extremely Toxic Effluent Stream Into The Sky. It is indefensible to consider the harmful consequences of this witch’s brew of toxic air, “small”.
Exelon rejected NJ DEP’s requirement to put up cooling towers at Oyster Creek in N.J., stating air pollution as the reason.
- Exelon admitted the dangers of cooling tower air pollution.
Limerick’s air permit identifies a broad range of toxic pollutants from 32 different air pollution sources involved with Limerick operations – PLUS RADIATION AIR PARTICULATES THAT ARE NOT LISTED IN LIMERICK’S TITLE V PERMIT.
- THAT SHOULD NOT BE CONSIDERED “SMALL” RISK BY ANYONE.
Since ACE’S 10-11 EIS testimony NRC’s letter to Exelon proves that chlorine from Limerick’s cooling tower air pollution is so corrosive that it corrodes stainless steel.
- EXELON ADMITTED THIS HIGHLY CORROSIVE AIR IS TRANSPORTED OFF-SITE. IT OBVIOUSLY GETS INTO THE LUNGS OF RESIDENTS.
- GIVEN THE BODY OF EVIDENCE ABOVE ON ALL LIMERICK NUCLEAR PLANT’S DANGEROUS AIR POLLLUTION THREATS, NRC’S DRAFT EIS CONCLUSION THAT LIMERICK’S AIR POLLUTION IMPACTS ARE “SMALL” MUST BE CHANGED IN NRC’S FINAL EIS TO STATE THAT IMPACTS ARE “LARGE”.
Sources and Issues:
- Limerick Air Pollution Sources and Pollutants. Source: PA DEP Title V Air Pollution Permit summarized by ACE 2009.
- Lists of Limerick Nuclear Plant’s kinds of air pollution, air pollutants, and sources. Source: PA DEP Title V Air Pollution Permit – Listed by ACE after review of the permit in 2009.
- Limerick Nuclear Plant’s PA DEP Title V Air Pollution Permit (46-00038) Provides The Proof – Only Major Air Pollution Sources Are Required to Submit Title V Permits. Limerick Nuclear Plant’s most recent Title V Air Pollution Permit Renewal was issued to the owner, Exelon, December 2009.
- “Nuclear Plant is a Major Source of Air Pollution – 2/14/09 Op-ed summary of Limerick Nuclear Power Plant’s air pollution permit, informing the public of health risks from the ACE Board of Directors,.
- ACE’s January 2010 Analysis of PA DEP’s Public Response Document Identifies Why Limerick’s Air Pollution is a Major Health Threat to our region and Why This Permit and the Permitting Process Failed to Protect Public Health.
- Recommendations and Requests from ACE January 2010 to PA DEP Secretary John Hanger, identifying concerns with the permit and requesting him to take action to reduce specific air pollution threats that his agency permitted to be drastically increased, instead of requiring filtration.
- Particulate Matter (PM10), the major air pollution threat from Limerick Nuclear Plant to the families in the region. 12/7/09 PA DEP permitted PM 10 emissions to be emitted 6 to 8 times higher than current limits without requirement for filtration and in addition to an automatically permitted 3 Ton Increase.
- List of PM 10 Harmful Health Effects, Sources: EPA and ATSDR.
- Toxics Carried With Limerick Nuclear Plant’s Massive Cooling Tower Drift.
- 324 Pounds Per Day Toxic Chemicals Added to Limerick’s Cooling Tower’s, Source: MSDS Sheets Provided by Exelon In 2004.
- List of automatically permitted toxics in Limerick’s Title V permit.
- Documented harmful health impacts of pollutants with automatically permitted increases. Source: EPA. These pollutants are regulated by EPA under health standards of the Clean Air Act because of their toxicity to humans.
- Air in the Region Already in the Top 10% of the worst in the US – For the very pollutants permitted to have automatic increases in Limerick’s Title V permit.
- Exhaust Flow Volumes Were Increased In Limerick’s Title V Permit.
- Lists of Air Pollution Studies, Including A List On Children – Compiled by ACE.
ACE TESTIMONY REVEALS LIMERICK’S UNPRECEDENTED CONTAMINATION OF OUR AIR AND WATER IS CLEAR AND INDISPUTABLE!
- NRC SHOULD NOT CALL ANY OF THE IMPACTS IDENTIFED ABOVE “SMALL”. IN TOTAL, THEY SHOULD BE CLASSIFIED AS “LARGE”.
THE OVERWHELMING EVIDENCE CONFIRMS SIGNIFICANT ENVIRONMENTAL HARM TO DATE!
- ANOTHER 20 YEARS SHOULD NOT BE A VIABLE CONSIDERATION.
NRC’S DRAFT EIS IS ABOUT THE HEALTH AND SAFETY OF THE ENTIRE GREATER PHILADELPHIA REGION.
- NRC’S REGULATORY DECEPTION AND NEGLIGENCE CANNOT BE TOLERATED:
ACE absolutely objects to NRC’s deceptive, unprotective regulatory process for this EIS. NRC seems to believe we don’t understand. We do understand all too well, but refuse to conform to NRC’s industry-biased process that fails miserably to protect public health, safety, and financial interests.
Examples of NRC Negligent Oversight:
- NRC failed to independently evaluate Limerick Nuclear Plant’s major air pollution permit or its dangerous NPDES permit to pollute the Schuylkill River, even though ACE identified a body of evidence and submitted extensive summaries showing why these permits cause undue risks to the health and safety of vast numbers of people.
- Instead of an independent review of Limerick’s permits using the information provided from ACE’s review of the permits, NRC consulted with the agencies responsible for allowing Limerick to have dangerous pollution permit increases and permit exemptions because Limerick can’t meet limits in place to protect public health.
- NRC refused to provide time for ACE to make presentations of the findings from our extensive comprehensive public interest reviews of Limerick’s air and water pollution permits.
- NRC Public Relations Rhetoric Doesn’t Match Its Actions. NRC claims to want public input, but then refuses requests to meet. There is no excuse. NRC repeatedly came to Limerick Nuclear Plant, just three miles from our home office where we have the permits, along with our analyses, and other research to which we refer.
- NRC attempts to abdicate responsibility for Limerick’s major air pollution and water contamination is shameful and unacceptable.
- NRC is responsible for public health and safety related to Limerick Nuclear Plant operations.
- NRC is preparing an Environmental Impact Statement for Limerick Nuclear Plant.
- In place of the meeting ACE repeatedly requested to explain the complicated water pollution permit issues, NRC said ACE could talk to members of NRC’s Environmental Review Team at the 5-23-13 public hearing.
- To best explain the complicated multiple threats ACE prepared multiple graphic boards for discussion at the hearing.
- Unfortunately, it became clear we were providing information to people who were not interested in being “confused with the facts”.
A member of NRC’s Environmental Review Team told ACE members 5-23-13, that NRC is not responsible for the air and water pollution threats from Limerick Nuclear Power Plant.
NRC is responsible for all the health harm from Limerick Nuclear Plant operations. Major pollution permitted in Limerick’s air and water pollution permits clearly present enormous threats to public health. THAT MAKES IT NRC’S RESPONSIBILITY.
- It is indefensible for NRC to make inaccurate, unsubstantiated conclusions in Limerick’s Environmental Impact Statement, if NRC has no intention of actually analyzing health and environmental consequences of Limerick’s air and water pollution permits.
- It is indefensible for NRC to avoid doing the detailed analyses of the consequences of Limerick’s dangerous pollution permits simply by consulting with the agencies that allowed drastic increases in those permits and allowed dangerous exemptions and loopholes because Limerick can’t meet their original permit limits or standards in place to protect public health.
- It is inexplicable and unacceptable that NRC refused to have their Environmental Review Team for Limerick’s EIS meet with ACE officers that did do comprehensive independent reviews and analyses of Limerick’s air and water pollution permits.
- NRC failed to respond to ACE comments on Limerick’s unprecedented air and water pollution threats from our 10-26-11 testimony, separately, or in Limerick’s DRAFT EIS as NRC claimed.
- NRC claimed they used ACE comments to inform their review to develop the DRAFT EIS. THAT CAN’T BE TRUE or NRC COULD NOT HAVE CONCLUDED HARMS ARE “SMALL”.
Ms. Perkins June 10, 2013 e-mail to ACE states that “NRC uses public scoping comments to inform their review and develop the DSEIS. NRC responds to all public scoping comments by issuing a scoping summary report in the DSEIS.” That is not true.
- If NRC had given full and fair review to ACE comments, NRC could not conclude Limerick’s health impacts were “small”.
- ACE provided NRC with documented PA Cancer Registry and CDC data showing that after Limerick started operating in 1985, that cancer in communities near Limerick skyrocketed far higher than the national average, especially in children. ACE also provided NRC with researched links between elevated cancer rates and Limerick Nuclear Plant’s routine radiation releases..
- ACE provided NRC with a 2003 EPA report based on state data showing highly elevated infant and neonatal mortality rates, malignant tumors, cerebrovascular disease, and lower respiratory disease, all far higher than the state average and even higher than Philadelphia and Reading.
- ACE provided NRC with lists of toxics that can cause the health harms above. Those toxics have been continuously released into our air and water from Limerick since Limerick started operating in 1985.
- NRC did NO INDEPENDENT TESTING to prove Limerick’s massive air pollution and water contamination or its routine radiation releases were not the major factor in the highly elevated illnesses and other health harms in communities near Limerick.
- Our cancer crisis, with numbers far higher than the national average after Limerick started operating, suggests those impacts should not be considered “small”.
NRC’S REGULATORY NEGLIGENCE AND MALPRACTICE IN PREPARING LIMERICK’S DRAFT EIS CAN JEOPARDIZE THE FUTURE OF THE ENTIRE GREATER PHILADELPHIA REGION.
- ON BEHALF OF PUBLIC HEALTH, ACE ABSOLUTELY REJECTS NRC’S INACCURATE, ILLOGICAL, AND NEGLIGENT CONCLUSIONS IN ITS DRAFT EIS FOR LIMERICK NUCLEAR PLANT.
- CONCLUSIONS MUST BE CHANGED TO REFLECT DOCUMENTED EVIDENCE IN THIS 6-24-13 ACE TESTIMONY.
COMPARISONS OF ENVIRONMENTAL IMPACTS OF ALTERNATIVES
NRC’S CONCLUSIONS ARE LUDICROUS AND INDEFENSIBLE
IN NRC’s DRAFT EIS FOR LIMERICK NUCLEAR PLANT
NRC LOOKS FOOLISH MAKING THE INDEFENSIVLE STATEMENT THAT SOLAR POWER HAS THE SAME ENVIRONMENTAL IMPACTS AS NUCLEAR POWER!
IT IS INEXPLICABLE THAT NRC FAILED TO CONSIDER SOLAR POWER AS A COMMON SENSE ALTERNATIVE IN LIMERICK’S EIS.
- NRC failed to consider solar power as an alternative, despite ACE’s 10-26-11 extensive EIS testimony documenting why solar power is a viable alternative to Limerick Nuclear Plant.
- NRC excluding solar power as an alternative is more evidence that NRC failed to seriously consider or acknowledge ACE’s 10-26-11 public hearing comments.
- ACE identified large and small business installations, government building installations, schools, and residential solar installations already in the region of Limerick Nuclear Plant, including the Cuthberts’ personal solar power with battery backup.
- ACE provided a list of news articles proving solar power had become cost competitive with nuclear power and that large back-up power installations were already available to use solar as baseload power.
- Since 2011, considerable additional evidence has become available showing that solar power is even more feasible from both a technical and economic standpoint.
LIMERICK’S FINAL EIS MUST BE CHANGED TO REFLECT THE REALITY OF SOLAR POWER AS A REASONABLE, FEASIBLE ALTERNATIVE.
NRC’s Draft EIS for Limerick Nuclear Plant presented several conclusions that were simply not supported by scientific fact. Numerous assumptions appear to have been combined with predetermined, pro-nuclear conclusions. Many of the conclusions rise to the level of colossal incompetence, if not regulatory malpractice.
Several specific examples were included in oral and written testimony presented by Dr. Lewis Cuthbert at the NRC public meeting/hearing on May 23, 2013. One of the most ludicrous conclusions and assertions was that the impacts from continued nuclear operations at Limerick would result in the same impacts as from all other alternatives, all being “small’”. This unsupportable conclusion must be changed in the Final EIS to accurately reflect the far greater threats, risks, and impacts from nuclear operations.
The substantial written testimony submitted by ACE October 26, 2011 focused on solar power as a preferred and viable alternative for our region, rather than a renewed license for Limerick. Since that time, solar technology has increased, costs have declined dramatically, and installations in the region have proliferated at an ever-increasing pace.
Inexplicably, in its Draft EIS for Limerick, NRC totally dismissed solar power as a viable alternative, despite the considerable body of evidence to the contrary provided by ACE in 2011. Since that time, an even more compelling body of evidence has emerged supporting the viability of solar power as an alternative energy source.
The most recent compelling article on the viability of solar power appeared 3-25-13, “NRG Skirts Utilities Taking Solar Panels to U.S. Rooftop” by Christopher Martin, and Naureen S. Malik.
This Article Confirms The Cost Effectiveness and Viability of Solar Panels Alternatives. This article supports our conclusion that we don’t need Limerick Nuclear Power Plant.
- Utilities are aware that generating power at customer sites is leading to them losing their customers and disrupting their businesses. Solar power is being installed on vast numbers of rooftops, both residential and commercial.
- Costs for solar panels keep coming down. Installation costs keep coming down. Solar is being combined with battery technology and power management systems.
- Some utilities recognize their business is becoming far less important, eventually being used just for back-up.
- NRG Energy, the biggest power provider to U.S. utilities is providing electricity directly to consumers.
- Energy companies are challenging traditional utilities, by providing rooftop solar panels to power individual buildings.
- At least a dozen U.S. companies provide rooftop panels at no upfront cost to customers, who typically make fixed reduced monthly payments for the output under decades-long contracts, known as solar leases or power-purchase agreements.
- By-passing its utility clients, NRC is installing solar panels on rooftops of homes and businesses and in the future will offer natural gas-fired generators to customers to kick in when the sun goes down.
- NRG is running mini-generation systems that run a single building. This endeavor strikes at the core business of utilities.
- Companies such as Sunrun and Sungevity offer services at home-improvement stores.
- CEO of NRG, David Crane said, “Consumers are realizing they don’t need the power industry at all. That is ultimately where big parts of the country go”.
- Individual home-owners may soon be able to tie a machine to their natural gas line and tie that with solar on the roof, then totally disconnect the line from the transmission-distribution company.
- Independent power producers may be evaluating the merits of distributed generation, building many small systems at customer sites instead of a few large ones.
When viewed in conjunction with wind power, the need for and cost effectiveness of continued electric from Limerick is no longer a logical option. A glut of low priced natural gas is also contributing to cheaper power prices.
In addition to typical rooftop PV solar panels, new technology has dramatically reduced the footprint of installations. Homes, small businesses, governmental agencies, and large corporations have moved to solar power in increasing numbers. Rooftop leasing and thinner, lighter panels have redefined the cost and space constraints that NRC referenced in its flawed Draft EIS. Today, any home or business in our region can consider viable solar power with no up-front costs to the owner.
NRC’s Final EIS for Limerick Nuclear Plant must be changed to include all of this evidence, and accurately reflect the reality of solar power as a currently available and safer alternative to Limerick’s electric. NRC is encouraged to review and consider additional information that has emerged since 2011, and amend the Final EIS for Limerick accordingly.
Additional Information About Solar And Wind Power Viability
- Karl Grossman observed, “Today a host of safe, clean, renewable energy technologies are more than ready. Combined, importantly, with energy efficiency, they render nuclear power as unnecessary.” (3/29/11)
- Jeff Immelt, GE CEO stated, “Nuclear power is so expensive compared with other forms of energy that it has become really hard to justify. It’s really a gas and wind world today.” (7/31/12)
- Christopher Crane, Exelon CEO said, “The rapid pace of subsidized wind-generated electric power could ultimately force Exelon to shutter nuclear plants.” (2/7/13)
- Reported in Solar Daily, For the first time, solar energy accounted for all new utility electricity generation capacity added to the U.S. grid, according to the Federal Energy Regulatory Commission’s FERC March 2013 Energy Infrastructure Update (more than 44 Megawatts). Many analysts predict solar will be the largest source of new U.S. energy over the next four years. (4/16/13)
- Alice Slater said in a presentation, “We mustn’t buy into the propaganda that clean safe energy is decades away or too costly…arguments made by companies in the business of producing dirty fuel.” (6/9/13)
NRC DESERVES A GRADE OF “F” FOR ITS ABSOUTELY DISHONEST EVALUATION OF ENVIRONMENTAL IMPACTS.
- WHAT OTHER ENERGY COULD RENDER THE ENTIRE GREATER PHILADELPHIA REGION UNINHABITABLE FOR GENERATIONS? NRC LOOKS RIDICULOUS CLAIMING THE ENVIRONMENTAL HARMS FROM LIMERICK ARE “SMALL”, AND THE SAME AS OTHER ENERGIES.
- EVEN WITHOUT A RADIATION ACCIDENT OR MELTDOWN, IN TOTAL, LIMERICK’S THEATS AND HARMS TO THE ENVIRONMENT ARE CLEARLY FAR WORSE THAN ANY OTHER ENERGY. JUST TWO EXAMPLES – WASTE AND WATER – REFUTE NRC’S ABSURD COMPARISONS.
HIGH-LEVEL RADIOACTIVE WASTES – No other energy alternative produces massive amounts of high-level radioactive wastes for which there is no safe solution and a million year EPA health standard for its waste dump. Limerick’s radioactive wastes will remain deadly and threaten our environment virtually forever.
- A. Fuel pools holding massive amounts of Limerick’s deadly radioactive wastes are a far worse threat to the environment than the waste from any other energy. Limerick’s fuel pools are corroding and thinning at far faster rates than expected after only 28 years.
With loss of cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire, causing tens of thousands of deaths up to 500 miles away, according to a 2000 NRC study.
A meltdown in a spent fuel pool could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site.
A 2004 Study by Dr. Edwin Lyman, Senior Scientist at the Union of Concerned Scientists, Concluded:
ü As many as 44,000 near-term deaths from acute radiation poisoning.
ü 518,000 long term deaths from cancer.
ü 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:
ü A successful terrorist attack on a spent fuel storage pool could have consequences “significantly worse than Chernobyl.”
ü 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).
A January 2003 study by Dr. Gordon Thompson, Director of the Institute for Resource and Security Studies (entitled “Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security”) reviewed ways spent fuel pools are vulnerable to attack.
ü A nuclear fire in one spent fuel pool would “render about 95,000 square kilometers of land uninhabitable,” (would cover about 75% of New York State, and into segments of NJ and CT.)
- B. Containers holding some of Limerick’s spent fuel above ground are only guaranteed to last 50 years when there can be significant radioactive threats to the environment from leaking.
WATER THREATS AND HARMS ARE UNPRECEDENTED
- A. Limerick is slowly destroying the Schuylkill River, a vital drinking water source for almost two million people. For 28 years Limerick has routinely and accidently poisoned the river with many types of radionuclides, some with long half-lives. That radiation is in the water, sediment, fish, and it travels into people’s homes from water treatment plants that do not filter it out. Highly toxic and corrosive chemicals are routinely discharged into the river from Limerick’s cooling towers. The insatiable water needs of Limerick’s cooling towers are depleting the Schuylkill River to such a degree that contaminated unfiltered mine water is massively being pumped into the river. From 1985 to 1999, the river reached record low flows. In the case of a meltdown, Limerick can take everyone’s water, threatening the water supply across six PA counties.
- B. Limerick’s leaks and spills over decades have made the groundwater radioactive. 15 of 15 beta radiation emitters were documented in the groundwater, along with alpha and gamma radiation emitters, and uranium. The radiation has never been cleaned up from the water or soil and there is no independent testing of the many residential wells very close to Limerick. In the case of a meltdown, Limerick could draw water from four wells on site and dry up vast numbers of wells.
ACE CONCLUSION: THERE IS NO NEED TO RELICENSE LIMERICK NUCLEAR PLANT
WE DON’T NEED LIMERICK’S ELECTRIC.
- OUR REGION SHOULD NOT CONTINUE TO BE SUBJECTED TO LIMERICK’S UNPRECEDENTED UNACCEPABLE THREATS AND HARMS TO OUR ENVIRONMENT AND PUBLIC HEALTH.
THERE IS NO NEED TO RELICENSE LIMERICK
- LIMERICK ONLY PRODUCES ½ OF 1 % OF THE NATION’S ENERGY.
HARMS VS. BENEFITS OF LIMERICK NUCLEAR PLANT
- WE GET THE HARMS, WHILE OTHERS GET THE BENEFITS
- Exelon profits
- Limerick’s electric goes to the grid to be distributed across several states, while millions of people in the Greater Philadelphia Region are forced to live with radiation and other toxic releases into our air, water, soil, food, and our children.
- Our drinking water supply is threatened.
- We are subjected to the extraordinary threats from a dangerous defacto high-level radioactive waste dump in our backyards.
- We are forced to live with the constant threat of catastrophic multiple meltdowns, from which it would be impossible to safely evacuate.
FINANCIAL INJUSTICE OF LIMERICK NUCLEAR PLANT
- Ratepayers in our region were forced to pay the lion’s share of Limerick’s $6.8 BILLION every month in our electric bills from 1985 to 2010.
- Ratepayers are paying each month in their electric bills for Limerick’s decommissioning even though Exelon is trying to relicense Limerick.
- Taxpayers have been forced to pick up the burden for Limerick’s owners failing to pay their fair share of taxes. From 1985 to 2002, no property taxes were paid on the 400 to 600 acres of the Limerick site. In 2002, a judge ordered Exelon to pay just $3 million per year, when it should have paid $17 million.
- Taxpayers hold the lion’s share of liability for what could be a trillion dollar disaster at Limerick. Exelon would only pay the first $12 Billion of the Trillion.
- Taxpayers will be paying to store Limerick’s deadly radioactive wastes forever.
NUCLEAR POWER HAS HAD AN UNFAIR TAXPAYER SUBSIDIES ADVANTAGE SINCE 1943.
- Taxpayers Subsidies for Energy from 1943 to 1999 totaled $151 Billion In 1999 dollars.
- 97.7% went to nuclear, while only 3,3% went to wind and solar
- Now Exelon has the nerve to whine about wind power getting subsidies.
THERE IS A CLEAR AND UNDENIABLE TREMENDOUS IMBALANCE BETWEEN THE IMPACTS OF LICENSE RENEWAL AND THE IMPACTS OF ALTERNATIVES.
- TO PROTECT THE ENVIRONMENT AND PUBLIC HEALTH, NRC NEEDS TO STOP LYING ABOUT LIMERICK NUCLEAR PLANT’S DIRTY, DANGEROUS, AND COSTLY ELECTRIC IN ITS FINAL EIS FOR LIMERICK.
In the Draft EIS for Limerick Nuclear Plant NRC has shamelessly failed to acknowledge the truth about nuclear power. It is not safe, clean, or cheap. There are far safer, cleaner, less dangerous, and cheaper ways to generate electricity. In the region around Limerick solar power and natural gas can easily replace Limerick’s electric long before Limerick’s license expires. Other renewable-sustainable energies like wind are also viable options.
ACE DID OUR OWN COMPARISON OF SOLAR, WIND, AND NUCLEAR BELOW:
NRC FAILED TO INCLUDE THESE COMPARISONS IN LIMERICK’S EIS.
- 1. Costs of solar and wind (relatively quick to install) will continue to plummet, while costs for nuclear power will continue to rise. Independent estimates suggest, adding in hidden costs to taxpayers and ratepayers, nuclear plants produce the most costly form of energy.
- Clean, safe energies like solar and wind, along with energy efficiency, are estimated to provide more jobs per dollar spent than nuclear power.
- Producing solar and wind energies closer to where they are needed, provides more energy security, removing the necessity for huge grids that can be attacked by terrorists.
- The Department of Energy 2006 report stated solar power and wind power could provide far more energy than our nation needs – That solar alone could provide 55 times our entire nation’s energy needs.
- Costly security is not needed for solar or wind energy installations.
- Terrorists are not interested in attacking solar or wind installations.
- Attacks at solar or wind energy installations would not result in astronomical costs or cause long-term devastation.
- Nuclear plants can be turned into nuclear bombs, resulting in tens of thousands of deaths and hundreds of billions of dollars in damages from spreading radioactive contamination across vast areas which create dead zones for centuries.
- Human error or mechanical failure of solar and wind technologies won’t result in devastation like they can at nuclear plants.
- Solar and wind would clearly be a far safer and less costly investment for taxpayers and ratepayers.
- Solar and wind don’t create dangerous high-level radioactive waste storage problems, with costs to taxpayers beyond meaningful calculation.
- Reprocessing is not the solution to high-level radioactive waste problems. Evidence shows reprocessing makes waste problems worse. Reprocessing is costly, ill-conceived, dangerous and environmentally damaging. Vitrification is also costly and has not been proven safe.
- Nuclear plants are not emissions-free.
- Solar and wind energies don’t routinely release radiation in to our air and water that is harmful to health. Radiation exposure can alter DNA, cause cancer, and shorten life-expectancy.
- Limerick Nuclear Plant Title V air pollution permit proves it is a major polluter under the Clean Air Act. There are 32 air pollution sources on site releasing a broad range of air pollutants, including greenhouse gases.
- From uranium mining to waste storage, nuclear power emits greenhouse gases.
- Solar and wind energies don’t present unprecedented threats and harms to the public water supplies such as those from Limerick Nuclear Plant.
- Solar and wind are more dependable in heat and drought when you need power most. Nuclear reactors require enormous quantities of water to operate. If water sources diminish significantly or become too hot, due to droughts and heat waves (expected to increase under global warming), reactors cannot operate safely.
NRC SAYS IT DECIDED TO EXERCISE ITS NEPA AUTHORITY TO REJECT LICENSE RENEWAL APPLICATIONS ONLY IN CASES WHERE THERE IS SUCH AN IMBALANCE BETWEEN THE IMPACTS OF LICENSE RENEWAL AND THE IMPACTS OF THE ALTERNATIVE THAT IT WOULD BE UNREASONABLE TO ALLOW FURTHER CONSIDERATION OF LICENSE RENEWAL.
- ACE BELIEVES THE INFORMATION WE PROVIDED ABOVE CLEARLY SHOWS IT WOULD BE UNREASONABLE TO ALLOW FURTHER CONSIDERATION OF LIMERICK NUCLEAR PLANT LICENSE RENEWAL.
ACE COMMENTS TO NRC 6-24-13 – ON LIMERICK NUCLEAR PLANT’S DRAFT EIS
SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA)
NRC COMMENTS AND CONCLUSIONS IN THIS SECTION ARE PROFOUNDLY ALARMING.
NRC devalued every person, all their possessions, and life-support systems in the Greater Philadelphia Region to save Exelon the cost of implementing the most protective safety planning and measures.
NRC’s cost-benefit analysis concludes the cost for risk reduction to the population and its life-support systems is not worth the cost to Exelon for severe accident mitigation design alternatives.
SAMA assesses environmental, economic, and other consequences. It’s about human health, economic, and environmental impacts of a nuclear plant. Limerick’s SAMA is decades out-of-date.
- STILL, NRC WANTS TO EXEMPT LIMERICK
Exelon and NRC want to exempt Limerick, as one of three nuclear plants that never again have to consider an updated Severe Accident Mitigation Analysis in connection with new and significant environmental information under NEPA in relicensing.
- This is a grotesque dereliction of responsibility.
The National Resource Defense Council (NRDC) Filed A Legal Appeal and won in the 3rd Circuit Court of Appeals in Philadelphia, Against Exelon’s Attempt To Circumvent A Safety Analysis Requirement for Limerick Nuclear Plant’s Outdated, Unacceptable Accident Mitigation Analysis.
- The judge agreed with NRDC’s conclusion that ignoring the population growth around Limerick is unacceptable if an emergency evacuation at Limerick becomes necessary.
- Common sense planning is needed stating that what was acceptable in 1989 is not good enough now and in the future.
- Limerick’s Severe Accident Mitigation analysis was last completed in 1989, relying on the census for 1980 population.
Even after Fukushima, involving boiling water reactors similar to Limerick’s, and drastically increased populations that would clearly be impacted by a Fukushima-type disaster at Limerick, NRC illogically joined Exelon in an appeal against a federal court decision, in order to avoid an updated safety analysis for Limerick. The federal court decision stated that Limerick can’t be exempted.
- In this appeal NRC didn’t even pretend to be a neutral arbitrator. This is totally shameful and unacceptable.
Limerick is the 2nd most densely populated nuclear plant in the nation. Still, NRC is refusing to consider increased population and health risks associated with a Limerick Nuclear Plant accident/meltdown.
- Due to Limerick’s location, the potential impact of a severe accident would be far greater than at most other U.S. nuclear plants (NRDC research).
- Over 8 million people live within 50 miles of Limerick, the radius NRC told Americans to evacuate in Japan during the Fukushima accident.
- 1.4 million people are now living downwind in the Philadelphia-Wilmington-Newark metropolitan area.
- In 1980 Limerick already had double the population density within 30 miles than could evacuate safely (NRC standard). Now the population density is four times higher.
EVACUATION AND EMERGENCY PLANS
ARE INADEQUATE AND FATALLY FLAWED.
NRC INEXPLICABLY PARED DOWN EMERGENCY PLANNING AFTER FUKUSHIMA. NRC’S ACTIONS ARE INDEFENSIBLE. AFTER FUKUSHIMA, NRC MADE IT WORSE, NOT BETTER
NRC weakened regulations and requirements, including for emergencies and evacuation.
- NRC overhauled community emergency planning for the first time in more than three decades, however NRC pared down emergency rules and evacuation plans, further jeopardizing the public. NRC’s new rules after Fukushima make no sense.
- Many emergency responders view NRC’s new rules as downright bizarre.
1) NRC Allowed Emergency Drills To Be Run Without Practicing for Radiation
2) NRC Requires FEWER Exercises for Major Radiation Accidents
3) NRC Recommends FEWER People Evacuate Right Away
- Instead Of Attempting To Minimize Chaos And Reduce Radiation Exposure Through Better Emergency Planning and Drills For A Radioactive Accident / Meltdown:
1) NRC Deceived The Public and Weakened Emergency Rules
2) NRC Denied Radiation Risks and Harms
3) Despite Evidence from Fukushima, NRC Failed To Expand Emergency Zones
4) NRC Has Denied Repeated Requests To Expand Evacuation Zones to 50 Miles, and Ingestion Pathway Zones to 100 Miles. This Would Better Protect Public Health, Safety, and Financial Interests For Vast Numbers Of People
NRC IS ABDICATING ITS RESPONSIBILITY TO ENSURE PUBLIC HEALTH AND SAFETY IN THE GREATER PHILADELPHIA REGION, RELATED TO EMERGENCY PLANNING AND EVACUATION
NRC’S RESPONSE TO THE IMPOSSIBILITY OF SAFE EVACUATION FROM LIMERICK NUCLEAR PLANT IS TO IGNORE REALITY, REFUSE TO DISCUSS THE FATALLY FLAWED EVACUATION PLAN, AND SHIRK ITS RESPONSIBILITY.
NRC is making decisions that could lead to a Limerick radiation accident/meltdown, while at the same time NRC is shirking its responsibility for radiation contamination released off Limerick’s site when a major radiation release or meltdown occurs.
4-16-13, ACE received a response to our repeated requests to meet with NRC’s Review Team to discuss the findings from our analysis of Exelon’s 12-12 Plume Exposure Time Estimate. This response from Joseph D. Anderson, Chief Operating Reactor Licensing and Outreach Branch, Division of Preparedness and Response was both shocking and negligent.
- Anderson’s e-mail to ACE revealed that NRC has no intention of reviewing or evaluating Exelon’s 12/12 updated Evacuation Time Estimate (ETE) for Limerick’s Radioactive Plume Exposure, even though NRC required it to be produced.
- NRC takes no responsibility for the accuracy or feasibility of Exelon’s Evacuation Plan for Limerick’s Radioactive Plume, even though NRC ordered it to be done.
- Exelon is not making commitments for this evacuation report either. Exelon’s letter accompanying Limerick’s ETE concludes with: “There are no commitments in this letter”. That disclaimer speaks volumes.
- Even though NRC is clearly responsible for radiation exposure associated with nuclear plants, NRC is claiming the responsibility for Limerick’s radioactive plume after an accident/meltdown is not theirs. Anderson’s e-mail revealed NRC is trying to shirk its responsibility for Limerick’s off-site radioactive contamination after a Limerick accident/ meltdown.
- NRC is also using industry-biased studies to dispute their own earlier studies that show drastic harms after a nuclear plant radiation accident/meltdown. NRC is ignoring actual human evidence after meltdowns and making false claims to attempt to minimize public concern about radiation risk from nuclear plant accidents/meltdowns.
- This is an indefensible and unacceptable position, especially when NRC is making decisions which increase risks for a Limerick disaster.
- In essence, Anderson admitted NRC has no interest in learning about the analysis of Exelon’s report for Limerick, when he failed to set up a meeting with ACE members who did analyze Exelon’s report.
ACE’s Analysis Of Exelon’s 12-12 Evacuation Time Estimate (ETE) For Limerick Nuclear Plant’s Plume Exposure Pathway Emergency Planning Reveals It Is Self-Serving Fiction.
- Exelon’s fatally flawed, unworkable plan is based on unrealistic, unworkable suppositions, assumptions, inconsistencies, and inaccuracies, with fact-free spin and illogical conclusions.
For More Information See www.acereport.org ACE Video-Blog Series 1 to 8
Also Download # 16 “Evacuation Plan Is Fatally Flawed”
1980 public hearing testimony on Limerick evacuation proves NRC knew then that within a 30 mile radius, Limerick had double the population density than could evacuation safely.
- Population density has now skyrocketed to four times the number NRC considered safe to evacuate in 1980.
- Philadelphia is only about 21 miles downwind, downstream from Limerick.
- Limerick is the 2nd most densely populated nuclear plant in the nation.
- Traffic gridlock is already horrific even in work-hour traffic. Attempted evacuation from Limerick’s radioactive plume would be chaos, keeping far too many people exposed far too long to dangerous radiation releases from Limerick.
NRC received written comments in 2011 from the Montgomery County Planning Commission and the Montgomery County Department of Public Safety, expressing major concerns about evacuation related to Limerick Nuclear Plant.
- NRC’s EIS failed to address MCPC and Health Director Comments. That is an unsupportable position. A radiation accident/meltdown would have devastating impacts on the environment for generations to come. It must be addressed in Limerick’s EIS.
- NRC received written comments for Limerick’s 2011 EIS public hearing from the Montgomery County Department of Public Safety, expressing serious concerns about evacuation and Limerick Nuclear Plant. Montgomery County Safety Director, Thomas Sullivan:
Asked for, “a full review of environmental and public safety issues pertaining to the plant.” In fact, NRC made no attempt to review public safety issues related to post Fukushima planning for a Limerick emergency and NRC’s environmental review is a shameful whitewash.
Recommended that Exelon be included as a source of funding for pending roadway infrastructure improvement projects. ACE concurs that these improvements could to some degree help with safer evacuation plans. However, NRC failed to include this recommendation in its EIS.
Informed NRC that the local, county, and state roads necessary for evacuation are no longer suitable for the amount of traffic that an EPZ evacuation could produce.
Expressed concern over delays in patient care for potentially life threatening illnesses. ACE is also concerned. NRC failed to address this issue in the EIS.
NRC’s Earlier Estimated Meltdown Consequences
NRC’s New Attempts To Deny Harm From Meltdowns
1974 Reactor Safety Study Published by NRC – Referred To As The Rasmussen Report
- 45,000 Radiation Sickness Cases (Requiring Hospitalization)
- 3,300 Deaths (From Acute Radiation Sickness)
- 45,000 Fatal Cancers (over 50 years)
- 250,000 Non-Fatal Cancers (over 50 years)
- 190 Children Born With Birth Defects Per Year
Note: Non-Insurable Property Damage Was Estimated At $14 Billion
NRC’s Estimated Consequences For An Accident (CRAC REPORT)
For Limerick Nuclear Power Plant – Reported To Congress In 1982
74,000 Early Fatalities
610,000 Early Injuries
34,000 Cancer Deaths
Census Records From 1980 to 2010 Show That These Numbers Would Be Drastically Higher Today.
Our Population Increase Demands Updated, More Realistic Planning
Census Shows – From 1980 to 2010 (2000 and 2010 Census Data)
Numbers For Fatalities, Injuries, and Deaths Above Would Be Drastically Higher Today Due To A: FOUR-FOLD INCREASE IN POPULATION DENSITY SINCE 1980
LIMERICK’S 10-MILE EPZ Is The 2ND MOST DENSELY POPULATED In The U.S.
- INFORMATION ABOVE RENDERS NRC’S CLAIMS IN LIMERICK’S DRAFT EIS – SAMA PAGE 5-3 – MISLEADING, AND INDEFENSIBLE
It appears NRC will say anything to fool the public to save Exelon money.
- “Risks of early fatality from potential accidents at the site are small in comparison with risks of early fatality from other human activities in a comparably sized population.”
- “The accident risk will not add significantly to population exposure and cancer risks.”
- “Accident risks from Limerick are expected to be a small fraction of risks the general public incurs from other sources.” THIS IS ABSURD!
- “Best estimates show risks of …reactor accidents at Limerick are within the range of risks from other nuclear plants.” – THIS IS A MEANINGLESS COMPARISON.
Shame on NRC! This agency has lost all credibility!
- Ø A Limerick Accident/Meltdown Could Cause A Catastrophe That Could Render The Entire Greater Philadelphia Region A Dead Zone For Generations.
- Ø A Limerick Accident/Meltdown Is About High-Levels Of Radiation Exposure That We Can’t See, Taste, Smell, Or Feel, But That Cause Radiation Sickness, Cancer, Death, And Impacts Into Future Generations.
Exelon should not be using decades-old 1989 information to determine health and economic impacts It is inexcusable for NRC to allow Exelon to use decades old comparisons for anything, especially population. NRC is letting Exelon get away with declaring its review of new and significant information compared to 1989, claiming Exelon did not uncover any cost beneficial plant improvements or SAMAs that would substantially decrease risk of a severe accident. That doesn’t even make sense considering NRC’s own post-Fukushima recommendations. Cost beneficial to whom? Certainly NOT public interests!
- Exelon’s evaluations and claims are based strictly on their costs. That leads to decisions ignoring unacceptable risks to the public.
- NRC’s job is to ensure public safety, not protect Exelon’s profits.
- NRC is supposed to protect the public’s interests. NRC has failed to consider and compare impacts and costs to the public for Exelon not being required to spend the money for the safest accident mitigation.
Costs to the public for an accident/meltdown at Limerick Nuclear Plant could be astronomical, in terms of suffering, health care costs, and financial costs.
- Off-site economic costs for multiple radiation accidents/meltdowns in Limerick’s reactors and/or fuel pools, in the densely populated Greater Philadelphia region surrounding Limerick Nuclear Plant have not been accurately assessed by anyone.
- Millions of people would need temporary housing and/or permanent relocation. In today’s economy and political dysfunction, the millions of people in the Greater Philadelphia Region who could lose everything would get no help.
- Costs for dealing with a Limerick disaster are estimated to be a trillion dollars, with taxpayers paying all but $12 billion.
- In addition to complete loss of property, possessions, businesses, and jobs, the short and long term health-care costs would be staggering. There would not even be enough treatment centers or hospitals to deal with the numbers of people who could end up with acute radiation poisoning or worse. In Japan, people, including children, were turned away because they were too radioactive.
- NRC never bothered to address any of the public interest issues above in Limerick’s DRAFT EIS. NRC is only considering costs to Exelon and Exelon’s profits, NOT costs to the public for a Limerick accident/meltdown because NRC failed to require the safest accident mitigation strategies. That is profoundly negligent!
IF NRC CONSIDERED DRASTIC INCREASES IN POPULATION, RELATED TO THE COSTS FOR LOSSES, NRC SHOULD COME TO THE CONCLUSION THAT IT IS JUST TOO RISKY TO CONTINUE TO OPERATE LIMERICK NUCLEAR PLANT.
- In NRC’s FINAL LIMERICK EIS, THE PUBLIC’S OFF-SITE COSTS FOR A LIMERICK RADIATION ACCIDENT/MELTDOWN MUST BE ACCURATELY ESTIMATED BY AN INDEPENDENT ECONOMIC EXPERT WHO UNDERSTANDS WHAT TOTAL RADIOACTIVE CONTAMINTION WOULD DO TO THE ENVIRONMENT AND THE POPULATION.
- 2010 census data for 50 miles (not 10) must be used and fully considered by a completely independent expert. The public’s costs and interests must be the priority of NRC, not Exelon profits.
- EXELON’S COSTS FOR ALL THE SAFEST MITIGATION ACTIONS WOULD CLEARLY PALE BY COMPARISON TO THE COSTS FOR FAILING TO PREVENT A LIMERICK ACCIDENT/MELTDOWN, ESPECIALLY CONSIDERING THE DRASTIC INCREASE IN THE DENSITY OF POPULATION AROUND LIMERICK NUCLEAR PLANT.
A BODY OF EVIDENCE BELOW SHOWS THAT NRC IS MAKING DECISIONS THAT FAIL IN NRC’S MISSION TO PROTECT THE PUBLIC!
- Dangerous delays and the opportunity for Exelon to avoid costs for important safety measures at Limerick Nuclear Plant have been allowed by NRC.
- When NRC knows about problems, whether with fire protection, increased seismic risk, or corrosion and thinning in fuel pool liners, allowing Exelon to choose to delay or avoid mitigation and safeguards for years or forever, amounts to regulatory negligence and even malpractice.
- NRC’s Decisions and Irresponsible Conclusions in Limerick’s DRAFT EIS are Contributing to Unnecessary Risk for Disastrous Radiation Accidents/Meltdowns and Their Inevitable Catastrophic Impacts.
POST-FUKUSHIMA NEGLIGENCE AT LIMERICK
NRC IS ALLOWING DANGEROUS DELAYS FOR IMPORTANT SAFEGUARDS RECOMMENDED BY NRC’S OWN POST-FUKUSHIMA TASK FORCE.
NRC allowed Exelon to DELAY important post-Fukushima safeguards recommended by their own staff, even though Limerick is considered a high-risk nuclear plant with GE Mark II boiling water reactors similar to those at Fukushima.
NRC Is Ignoring Its Own Orders, Based On Fukushima Task Force Recommendations Issued July, 2011.
MARCH, 2012 – NRC officially issued three orders to U.S. nuclear power plants:
- Plants must develop and implement measures to keep spent fuel rods cool after an extreme natural disaster.
- Sturdier venting systems are required to help prevent pressure-induced explosions.
- They must have a reliable read of water levels in spent fuel containers.
MARCH 13, 2012 NRC Issued Order to Modify Licensees Requirements for Mitigation Strategies for Beyond-Design-Basis External Events NRC 3-12-12 Letter (E-mail notice 3-13-12).
NRC’s Order Requires a 3-phase Approach For Mitigating Beyond-Design-Basis External Events.
- Initial phase – Requires use of installed equipment and resources to maintain or restore core cooling, containment, and SFP cooling.
- Transition phase – Requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site.
- Final phase – Requires obtaining sufficient offsite resources to sustain those functions INDEFINITELY.
- It is not clear any of these orders have been, or will be, required by NRC to be completed prior to relicensing of Limerick Nuclear Plant. It is important to remember that Fukushima was relicensed just a short time prior to the catastrophe. What was clear was the collusion between the owner and the regulator.
- It is not clear any safety measure will be completed before 2017, six years after the Fukushima disaster.
- NRC failed to provide answers to specific questions about several of these issues even after repeated requests by ACE.
- Given Exelon’s track record of avoiding costs for precaution, Limerick should not be relicensed, at least until AFTER all the post-Fukushima recommendations are fully completed and operational to protect public interests.
NRC IS ALLOWING EXELON TO DELAY EARTHQUAKE RISK (SEISMIC HAZARD) UPGRADES FOR OVER FOUR YEARS, UNTIL 2017, EVEN THOUGH LIMERICK IS AT HIGH-RISK FOR EARTHQUAKE DAMAGE.
Delays In Seismic Hazard Upgrades Are Not Required For Over Four Years, Until After 2017
- Ex-NRC Chairman Jaczko said “…we recognize there is new information that tells us plants may not be designed to the right seismic standards.…to be taking so long is a bit of a concern to me”. Earliest completion date for key seismic upgrades at U.S. nuclear power plants is 2017, even for high risk plants.
- Even after an earthquake triggered the worst nuclear disaster in history, NRC allowed Exelon to delay meaningful seismic upgrades at Limerick until after 2017, even though Limerick Nuclear Plant is considered a very high-risk nuclear plant, and new information indicates a much higher probability of core damage caused by an earthquake than previously believed.
- An investigation shows some Limerick systems, structures, and components could be unreliable in an earthquake.
- Fire and flood prevention seals may not tolerate a “seismic event” at Limerick.
- There is an earthquake fault directly under the Limerick Nuclear Plant site. Five earthquake faults are within 17 miles of Limerick.
- The August 2011 earthquake in VA jolted Limerick. Limerick was cited for a violation, for which NRC has not disclosed the details. The VA earthquake exceeded nuclear plant design basis. Others near Limerick could too. It is important to consider what would happen if there was an earthquake close to Limerick.
- Of greatest concern: Potential disruption in the miles of Limerick’s underground pipes and cables critical for delivering cooling water and power to avoid meltdowns.
- NRC admits Fracking has caused earthquakes in five states, yet refuses to take responsibility for earthquake risk in PA from 3,000 natural gas wells, and permits for 2,000 more to be issued this year.
- Instead of requiring meaningful upgrades, NRC allowed Exelon to have until 2017 to even produce a self-serving seismic hazard evaluation. NRC is using a nuclear industry biased new seismic source model instead of reliable updated USGS data.
- USGS has warned that drilling/fracking can cause seismic activity/earthquakes, whose severity and frequency will only become obvious once fracking is more established.
- NRC has failed to identify specific “geologic experts” used for the industry biased seismic study.
- Exelon will be allowed to use a new seismic source model (NUREG 2115) developed jointly by industry and the NRC. This new seismic source model was developed without input from many independent geologic experts or USGS studies considered relevant geologic studies in the central and eastern United States.
- Congressman Markey’s “Fukushima Fallout” May 2011 Seismic Issues Report shows:
ü NRC failed to factor modern geologic information into seismic safety requirements for nuclear plants.
ü NRC has not incorporated its technical staff’s recommendation to do this even though new information indicates a much higher probability of core damage caused by an earthquake than previously believed.
ü NRC has continued to process applications for license extensions at nuclear plants [including Limerick] in a major metropolitan area, even in the absence of upgraded seismic safety requirements.
For more information see www.acereport.org – Download #11 “Earthquake Risks”
PROFOUNDLY ALARMING NRC DECISIONS ON VENTS AND FILTERS
In a Limerick radiation accident / meltdown high radiation levels would poison us, our life-support systems, and everything we own. We would become nuclear refugees.
Still, even with greater risk for a radiation accident / meltdown at Limerick Nuclear Plant:
- A. NRC is allowing Exelon until 2017 to install vents to prevent an explosion.
- B. Even worse, if NRC and the nuclear industry lobbyists, NEI, deem filters “cost beneficial” the very earliest operable system would be 2021, eight years from now.
- NRC STAFF CONCLUDED, “FILTERS ARE VITAL AT NUCLEAR PLANTS LIKE LIMERICK”
- NRC STAFF SAID, “WITHOUT FILTERS, VENTS COULD BECOME A RADIOACTIVE FIRE HOSE INTO THE SKY.”
- NRC STAFF CONCLUDED, “THE CONSEQUENCES OF NO-FILTER VENTS COULD BE SO BAD, FILTERS SHOULD BE REQUIRED, REGARDLESS OF COST TO THE NUCLEAR INDUSTRY.”
NRC COMMISSIONERS ARE SIDING WITH NUCLEAR INDUSTRY LOBBYISTS TO DELAY AND/OR AVOID COSTS FOR SAFETY MITIGATION MEASURES, INSTEAD OF REQUIRING SAFETY UPGRADES RECOMMENDED BY NRC’S OWN STAFF.
- NRC’S POST-FUKUSHIMA FILTERED VENT RECOMMENDATIONS BEING DELAYED AND/OR IGNORED SHOW WHY WE CAN’T DEPEND ON NRC OVERSIGHT TO PREVENT OR MINIMIZE A LIMERICK DISASTER.
- THIS IS A SERIOUS THREAT TO THE ENTIRE PHILADELPHIA REGION.
- Limerick’s reactors are similar to those at Fukushima that lost power, melted down and exploded.
- NRC staff concluded that filters for vents are vital at nuclear plants like Limerick. NRC staff concluded the consequences for no-filter vents could be so bad, filters should be required, regardless of cost to the nuclear industry.
- With filters, some of the radiation could be captured. Still NRC failed to require Exelon to install vents at Limerick Nuclear Plant. NRC considers the cost to Exelon rather than extraordinary risk to our future.
- Exelon is willing to install vents to save Limerick reactors, but is unwilling to spend the money to install radiation filters to minimize harmful impacts from Limerick’s radiation releases on us and our life-support systems.
LIMERICK’S TWO MARK II GE BOILING WATER REACTORS, SIMILAR TO THOSE THAT EXPLODED AT FUKUSHIMA, ARE IN VIOLATION OF LICENSE CONDITIONS FOR SAFE OPERATION AND RELIABLE CONTAINMENT.
- STILL, NRC IS ALLOWING LIMERICK TO CONTINUE OPERATING WITHOUT BEING IN COMPLIANCE WITH SAFE OPERATION AND RELIABLE CONTAINMENT.
- Limerick’s design, construction, and operation are highly unreliable under certain now to be anticipated accident conditions.
- Yet, NRC voted 3-19-13 to delay regulatory action to reasonably restore containment integrity and install high-capacity radiation filters in upgraded severe accident capable vents.
- Failure to require the filtration system in vents deliberately defeats the license condition for maintaining public health and safety against the uncontrolled release of radioactivity to the environment associated with reactor core fuel damage.
- This constitutes a violation of Limerick’s license. Limerick’s operating license should be revoked.
- NRC’s response to ACE May 5, 2013 revealed there are two outstanding petitions against Limerick’s violation of license conditions for safe operation and reliable containment.
For more information see www.acereport.org – Download # 8
“Limerick’s Design Flaws, Deterioration, Corrosion”
BACK-UP POWER TO PREVENT MELTDOWNS IN REACTORS AND FUEL POOLS AT LIMERICK IS STILL WOEFULLY INADEQUATE, EVEN AFTER FUKUSHIMA.
It Appears NRC Will EXEMPT Limerick From NRC’s Post-Fukushima, Still To Be Revised, Station Blackout Rule. Back-Up Power To Prevent Meltdowns At Limerick Is Clearly Still Woefully Inadequate.
- The Fukushima disaster proves there could be four simultaneous meltdowns at Limerick and that a constant energy supply is vital for cooling water and other operations to prevent meltdowns.
- In 2013, two years after Fukushima, NRC has still not required Exelon to have indefinite back-up power to prevent potential meltdowns in Limerick’s two reactors and two fuel pools.
- New NRC rules say there must be indefinite back-up power, yet it does not appear that indefinite back-up power is available at Limerick.
- NRC’s new “station blackout” rules do not apply to plants licensed to operate prior to July 21, 1988, which includes Limerick, according to NRC’s website, Last Reviewed/Updated, Friday, March 01, 2013,
- In 2011, Ex-NRC chairman Jaczko said, “ I’m not convinced four hours is reasonable to restore off-site power”.
- Despite repeated requests, NRC has provided no evidence that Limerick has more than four hours of back-up power for each reactor. It appears there is NO designated back-up power for fuel pools.
FIRE CAN LEAD TO A MELTDOWN AT LIMERICK. SAFETY IS DEFINED BY COMPLIANCE WITH THE REGULATIONS.
- YET NRC ALLOWS LIMERICK TO FOLLOW WEAKENED FIRE SAFETY RULES.
- NRC ALSO FAILS TO REQUIRE IMMEDIATE ENFORCEMENT FOR FIRE SAFETY VIOLATIONS AT LIMERICK.
- In a 7-13-10 response to ACE about Limerick fire safety rules, NRC admitted they have two sets of rules to determine fire safety and that Limerick is one of the plants refusing to adopt the more protective NFPA 805 “Performance-Based Standard for Fire Protection”.
- NRC is literally playing with fire, allowing Limerick to follow unprotective industry designed policies on fire safety that set up scenarios at Limerick for disastrous consequences. IN 2008, the GAO faulted nukes over fire safety.
- While less stringent fire safety regulations increase risks at Limerick, they accommodate industry demands. NRC allows Limerick to follow fire safety policies that protect nuclear industry profits over public safety.
- NRC caved in to nuclear industry demands to weaken fire safety regulations to save money and time.
- Terms used in NRC Fire Safety Fact Sheets reveal how NRC weakened fire rules:
ü “SAFE ENOUGH”
ü “Enforcement Discretion”
ü “Reduced Regulatory Burdens”
- NRC fire safety regulations were in place since 1976 and 1980, to assure a fire does not prevent a reactor from safely shutting down. Three decades after fire safety regulations were established, NRC is still failing to require full compliance at Limerick and other nuclear plants.
- 125 fires were reported at 54 plants since 1995 (2008 GAO report). Limerick had a fire in 1997.
- Some parts of Limerick might not be reliable to prevent damage from fire if the plant was struck with an earthquake. (NRC inspection reported in the Mercury June 5, 2011, “NRC Inspection Raises New Issues at Limerick Plant”)
- ACE confirmed Limerick violations of weakened rules, with lax NRC enforcement in response. (2007 and 2010) Some violations went uncorrected for long periods of time.
- Example: Lax NRC enforcement for 2010 fire safety violations at Limerick.
ü NRC’S 11-9-10 letter to Exelon acknowledged 2 FIRE Violations, but NRC chose to treat them as Non-Cited Violations, even though NRC determined that these violations were “more than minor”.
ü 7-29-10 – Twice – The latching mechanism failed to function on a required fire door between the reactor enclosure and turbine building.
ü Exelon failed to address Limerick’s degraded condition and failed to set up a required hourly fire watch.
ü The door hardware was no longer functional for securing the door in a closed position.
ü An hourly fire watch was required for the inoperable fire door but Exelon failed to set up a fire watch.
NRC FAILED TO TAKE MEANINGFUL ENFORCEMENT ACTION FOR LIMERICK’S FAILURE TO SWIFTLY ADDRESS FIRE SAFETY VIOLATIONS.
- Given what is at stake for the Greater Philadelphia Region, there is no acceptable excuse for Exelon to avoid full compliance with the safest fire safety rules at Limerick.
- NRC plans to relicense Limerick with no plans to require compliance with the safest fire safety rules.
- NRC has a legal responsibility to ensure American nuclear reactors are safe, but that is not what is happening with fire safety rules and so many other issues at Limerick.
For more information see www.acereport.org
Download #14 “Lax Fire Safety Tempting Fate”
NRC IS WHITEWASHING LIMERICK VIOLATIONS. NRC IS ALSO FAILING TO HOLD EXELON ACCOUNTABLE WITH MEANINGFUL ENFORCEMENT FOR VIOLATIONS, MANY CALLED SIGNIFICANT BY NRC STAFF.
EXAMPLES BELOW IDENTIFY PROBLEMS:
- NRC Allowed Exelon To Avoid Immediate Replacement Of Flawed Safety Mechanisms, Necessary For Safe Shutdown, Despite Warnings To NRC From GE in 2010 and again in 2011.
- NRC Staff Identified Serious Performance And Aging Problems At Limerick, Yet Failed To Require Immediate Corrections.
- Exelon Fails To Notify NRC About Huge Problems and Accidents In A Timely Manner Which Violates NRC Regulations. In Response, NRC Issues Simple Violations Without Penalties.
- NRC Issues A Violation, Then Accepts Exelon Plans, and Moves On With NO Enforcement.
- NRC Allows Exelon To Get Away With Changing Procedures Without Notifying NRC About Serious Problems That Have The Potential To Lead To A Meltdown.
- NRC Issued Relief Requests for Limerick’s Risky Aging Equipment Problems.
- NRC Is Allowing Exelon To Use Outdated Studies, Models, Criteria, and Projections for License Renewal.
- NRC Issues Deceptively Benign Color Codes For Violations Of NRC Regulations That Have The Potential To Lead To Catastrophic Events.
- Green findings, for example sound benign, but are issued for violations which NRC itself says have more than minor significance and that could lead to far more serious problems.
- Exelon Fails To Follow Procedures In A Way That Assures Long-Term Plant Safety and Requirements For Immediate Action To Reduce Risks.
- NRC’s Inspection Reports Are Deliberately Convoluted and Deceptive. NRC Ignores Concerns From Its Own Staff To Make Inaccurate Conclusions That Most Often Ignore Actual Risky Conditions.
- NRC Allowed Exelon’s Lobbyists, NEI, To Assert Influence In Amending and Weakening NRC Regulations To Facilitate License Renewal.
- Details on NRC’s weakened safety rules for relicensing were investigated and reported by the Associated Press four part series, first reported June 20, 2011 – by Jeff Donn, “U.S. nuke regulators weaken safety rules. AP Investigation: Standards being compromised to keep plants running.”
NRC IS FAILING TO REQUIRE EXELON TO REPLACE AGING DETERIORATING EQUIPMENT AND SYSTEMS PRIOR TO RELICENSING AT LIMERICK
- NRC IS ALLOWING EXELON TO DELAY AND EVEN AVOID TAKING CORRECTIVE ACTION ON DANGEROUS AGING, DETERIORATION, AND CORROSION PROBLEMS IDENTIFIED IN SAFETY REVIEWS FOR RELICENSING BY NRC’S OWN STAFF.
NRC documented that Limerick is experiencing significant corrosion, cracking, pitting, fatigue, fouling, erosion, thinning through loss of material, embrittlement, and leaching of steel and other metals making up bolts, piping, welds, ducts, liners, cladding, external surfaces, and walls.
- These serious problems are occurring after only 28 years of operation, yet NRC plans to relicense Limerick in 2014, with a decade remaining before Limerick’s first license expires.
- However, NRC is whitewashing this evidence from its own safety evaluations reports for relicensing.
- NRC caved in to Exelon’s self-serving demands to delay corrections and replacement so that Exelon can avoid costs. Some corrective actions have been deferred for over a decade, until 2024 and 2029.
- Exelon should not be allowed to avoid immediate corrections and replacements related to the broad range of aging problems documented at Limerick Nuclear Plant.
- Exelon should be required to replace all aging equipment and systems BEFORE relicensing. If Exelon refuses, NRC should not relicense Limerick. However, NRC plans to relicense Limerick with very few replacements or costly repairs.
- Critical cables and wires are also at risk of failure. They can stop working due to water and condensation. That could produce catastrophic consequences during an accident. There are miles of buried pipes and cables underground at Limerick.
- Some very concerning problems appear inevitable, including internal aging effects of components, recurring internal corrosion on internal surfaces in piping and ducting components, loss of coating integrity, corrosion under insulation, and flow blockage of water-based fire protecting system piping. Still, in determining whether Limerick can operate safely until 2049, NRC has failed to require replacement of all these cables and wires, some of which already have been exposed to water, condensation, and radioactive impacts for 28 years.
- NRC’s response to community concerns about their failed regulatory oversight, is not to hold Exelon accountable, but instead for citizens to contact NRC’s own Inspector General, another fox in the hen house operation, in which few have any confidence.
CORROSION AND LOSS OF THICKNESS DOCUMENTED IN LIMERICK’S “SPENT FUEL” POOL LINERS – COATING DELAYED FOR A DECADE.
Identified In NRC’s July 20, 2012 and October 19, 2012 Letters To Exelon
ü CORROSION RATE IS FAR HIGHER THAN ORIGINAL CALCULATIONS.
ü NRC DOCUMENTED CORROSION, CRACKING, PITTING, AND CAVITATIONS.
ü PITTING CORROSION RATE IS 2 TO 10 TIMES HIGHER THAN GENERAL CORROSION.
- EXELON REQUESTED DELAYING COATING UNTIL LIMERICK’S LICENSES EXPIRE (12 TO 17 YEARS), WITH INSPECTION EVERY 10 YEARS.
- NRC TOLD EXELON: ((7-20-12 LETTER) TO DELAY COATING IN FUEL POOLS IS UNACCEPTABLE
- YET, NRC CAVED IN TO EXELON AND REVISED REGULATIONS TO ALLOW EXELON’S COST-CUTTING DEMAND TO DELAY COATING OF LIMERICK’S FUEL POOL LINERS FOR 11 TO 16 YEARS.
- EXELON IS ALSO BEING ALLOWED TO INSPECT EVERY 10 YEARS.
NRC APPROVED PERMIT AMENDMENTS AND LOOPHOLES THAT JEOPARDIZE PUBLIC HEALTH AND SAFETY
NRC ALLOWED EXELON TO WAIT 7 DAYS (INSTEAD OF 12 HOURS) FOR HOT SHUTDOWN. THIS IS AN UNACCEPTABLE THREAT TO PUBLIC HEALTH.
- Limerick should not wait 7 days (instead of 12 hours) to go into hot shutdown when monitoring systems are inoperable (12-9-11 Limerick Permit Amendment Approved by NRC)
- Both FEMA and NRC publically stated radiation can start to travel off-site within ½ hour of a problem/radiation accident.
- Vast numbers of people in the Greater Philadelphia Region can now be exposed to higher levels of radiation without their knowledge, for at least 7 days, before Exelon must notify the public.
- Based on nothing more than “NRC’s reasonable assurance”, NRC makes the absurd, indefensible claim that this amendment will not endanger the health and safety of the public.
- Exelon has proven it fails to provide immediate full and accurate disclosure about radiation releases, based on Limerick’s most recent radioactive spill into drinking water (3-19-12) for almost two million people. Exelon and NRC failed to notify the public for 23 days, eliminating the opportunity for people to protect themselves and their children.
ACE review and analysis of the following documents provide evidence of NRC’s negligent oversight and failed enforcement. They refute irrational, unreasonable, and unsubstantiated statements and conclusions in NRC’s DRAFT EIS for Limerick Nuclear Plant.
- NRC’s letters to Exelon related to relicensing reviews
- NRC’s Integrated Inspection Reports and Notices of Violations for Limerick
- NRC’s Safety Evaluation Report For Limerick License Renewal (July 2012)
- NRC’s Safety Evaluation Report for Limerick License Renewal (January 2013)
- NRC’s DRAFT Environmental Impact Statement (EIS) for Limerick April 30, 2013
- NRC correspondence to ACE in March, April, and May of 2013
Previously ACE compiled a long list of NRC failed policies, decisions, and oversight
www.acereport.org #15 – “NRC Negligence: Jeopardizing Our Future”
ACE is profoundly alarmed by the evidence. Clearly, it is negligent for NRC to allow Exelon to take the kinds of risks for meltdowns at Limerick caused bydangerous delays of safety upgrades.
NRC’s conclusions in Limerick’s DRAFT EIS for Limerick relicensing are further jeopardizing the entire Greater Philadelphia Region and ignoring the unacceptable risks of Limerick’s continued operation under the current conditions, much less 20 more years after 2029.
NRC’s response to ACE regarding our concerns about NRC’s failed oversight and enforcement at Limerick is to send us to NRC’s own Inspector General.
- ACE has no confidence that NRC’s own inspector general could or would conduct a truly objective investigation.
QUOTES FROM EX-NRC CHAIRMAN GREGORY JACZKO
- SUPPORT OUR SERIOUS CONCERNS
- HE ALSO PROVIDES AN EXPLAINTION FOR WHY NRC IS IGNORING THE EVIDENCE AND MAKING IRRATIONAL, INACCURATE CONCLUSIONS IN LIMERICK’S DRAFT EIS TO RELICENSE LIMERICK NUCLEAR PLANT.
- “Nuclear Plants should be Phased Out” “They Aren’t Safe”
- Chairman Gregory Jaczko says that the current fleet of operating plants in the US should be phased out because regulators can’t guarantee against an accident causing widespread land contamination.
- In two key NRC decisions last week Jaczko said the agency “damaged significantly” its international reputation for upholding safety and he accused the five commissioners of “just rolling the dice” in dealing with severe accidents.
- The biggest problem with NRC continues to be heavy influence that industry has in selecting members of the commission. It’s a very political process.
- “It would be virtually impossible for someone who is publicly skeptical of nuclear power to ever be confirmed as a commissioner on the NRC. That is fundamentally wrong.”
- If you look at the state of nuclear power in the United States, it is not very good.
- It is ultimately meetings with senior executives of the utilities, who demand certain things and ask certain things of the chairman, and expect it to be done.
- Then it turns into political pressure from members of Congress, as utilities will work with members of Congress to have them apply pressure.
- There is no one else who has the authority to say no to a utility, other than the regulator.
- Echoing complaints of previous commissioners who have alleged that the NRC is essentially an industry captive, Jaczko said, “The industry has gotten so bold that [before last week’s vote] they were able to say this was a done deal. This damaged significantly the credibility of the NRC. Internationally the NRC had been looked at as the gold standard.”
“The NRC Is NOT Doing Its Job” – Dave Lochbaum, Nuclear Engineer
Nuclear Safety Project for the Union of Concerned Scientists
- “Safety is defined by compliance with the regulations. When it knows that half the plants in the country don’t meet fire protection regulations, it can’t say those plants are safe.” Limerick is one of the nuclear plants that does not meet the safest fire protection regulations.
- “In the mid-90s NRC recognized that some 27 US plants were in an area where the seismic risk was larger than they thought and that new reactors would have to be better protected, but NRC didn’t do anything about the 27 reactors that were already built and operating in those regions.” Limerick is one of them.
- “When you know about a problem – whether it’s fire protection or increased seismic risk – and you study it and don’t solve it, that’s not what should be done.”
NRC BACKPEDALED OFF ITS INITIAL REGULATIONS.
- Why? The nuclear industry lobbyists are buying influence in Congress. They give more to Congress than the tobacco industry did in the mid-90s.
- In 1998, industry got Congress to threaten to cut the NRC budget by 40%, meaning 500 people would be fired from NRC. So NRC backed off enforcement of regulations.
PLANTS ARE LICENSED FOR 40 YEARS, BUT THAT DOESN’T MEAN ALL THEIR PARTS LAST FOR 40 YEARS. AS PLANTS GET OLDER, THE CHANCE OF FAILURE GOES UP.
- It’s no guarantee plants are safe till 40.
- Safety margins degrade. Safety risk goes up because plant equipment is getting older, wearing out.
- You skip the maintenance now, but it costs thousands tomorrow.
TO PROTECT THE HEALTH AND SAFETY OF MILLIONS OF PEOPLE IN THE GREATER PHILADELPHIA REGION, THEIR LIFE SUPPORT SYSTEMS, AND THEIR POSSESSIONS, EXELON SHOULD BE REQUIRED TO PROVIDE ALL THE MOST PROTECTIVE SAFEGUARDS IMMEDIATELY, OR LIMERICK NUCLEAR PLANT SHOULD HAVE ITS OPERATING LICENSE REVOKED IMMEDIATELY.
LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES
NRC’S DRAFT EIS HAS FAILED TO ADEQUATELY ADDRESS THE SITE SPECIFIC ENVIRONMENTAL IMPACTS OF THE MASSIVE AMOUNTS OF HIGH-LEVEL RADIOACTIVE WASTES CURRENTLY STORED IN FUEL POOLS AND CASKS ON THE LIMERICK SITE, AND THE IMPACTS OF THE FUTURE PRODUCTION OF LIMERICK’S HIGH-LEVEL RADIOACITVE WASTES DURING LIMERICK’S RELICENSING PERIOD.
What could possibly have more of an impact on the future environment of the entire Greater Philadelphia Region than storing more and more of the most deadly materials on earth in fuel pools (like Fukushima’s) and above ground casks that can eventually leak?
- Devastating Long-Term Environmental Impacts Can Result From Storing Or Transporting Limerick’s High-Level Radioactive Wastes.
- NRC’s DRAFT EIS Fails To Adequately Address Specific Environmental Impacts of The Massive Amounts Of High-Level Radioactive Wastes Currently In Limerick’s Fuel Pools and Casks.
- A New Review Of Limerick’s Spent Fuel Storage Is Imperative BEFORE Limerick’s EIS DRAFT Is Finalized. There Are Many Unanswered Questions With Serious Implications For Devastating Environmental Consequences For Generations, If Not Forever.
What could have more impact on the future environment of the entire Greater Philadelphia Region than storing massive amounts of the most deadly materials on earth, in corroding and thinning fuel pools, originally made with substandard cement, and extremely vulnerable to meltdowns from earthquakes and terrorist strikes with planes and missiles (like Fukushima’s, high above reactors with no containment)?
- NRC’s decision to allow Exelon to avoid an assessment of environmental impacts from all the deadly high-level radioactive wastes stored on the Limerick site until after the EIS is approved for relicensing, is really about protecting Exelon’s interests, not public interests.
- There is NO NEED to rush Limerick’s relicensing, when its original license doesn’t expire for over a decade, another 11 years.
- Given the extreme dangers and destruction faced by the entire Greater Philadelphia from Limerick’s high-level radioactive waste storage at Limerick, NRC would be negligent to ignore the unprecedented threats to the environment and population in Limerick’s Environmental Impact Statement.
Although re-licensing of Limerick was pushed back 2 years by the June 8, 2012 court decision requiring NRC to re-think the environmental impact of storing radioactive wastes (spent-fuel) at nuclear plants, Neil Sheehan from NRC made the inexplicable statement in an e-mail to the Mercury that NRC’s new rules about spent fuel storage, ordered by a court decision to be released September 2014, are not likely to affect Limerick’s Environment Impact Statement.
- “There is no expectation that Exelon would have to conduct a new review of spent fuel storage at Limerick.” (Mercury – March 8, 2013)
- “Limerick nuke plant relicensing unlikely to be affected by new spent fuel rules” (Mercury – March 13, 2013)
Neil Sheehan’s March 2013 statements are contradictory to NRC’s December 2012 statements, which revealed the court said NRC should have considered potential environmental effects of leaks and fires involving spent fuel pools.
(Mercury – December 29, 2012 “Limerick nuke plant re-licensing delayed by courts”)
NRC wrote, “The Appeals Court ruled that in evaluating risks from on-site storage of spent fuel, “NRC should have considered the potential environmental effects in the event a permanent repository for disposing is never built and found other deficiencies with the agency’s consideration of leaks and fires involving spent fuel pools”.
- NRC indicated an intention to respond with a new analysis to be “completed within 24 months”, including for Limerick.
- NRC intended to “develop an environmental impact statement and a revised waste confidence decision and rule on the temporary storage of spent nuclear fuel.”
- On Sept. 6, 2012, the NRC announced it would not fight the June 8, 2012 ruling by the U.S. District Court of Appeals, finding that NRC could not ignore the possibility that the federal government may never build a national repository for America’s spent nuclear fuel.
Important facts also in the 12-29-12 article:
- In 2006, Exelon’s Limerick plant already reached its design capacity and beyond, forcing “dry storage” canisters to be built on-site. Ground was broken in 2007 for a dry cask storage system now storing the plant’s older, colder spent fuel.
- All the fuel ever used at Limerick since it began operating remains on site to this day. It will remain radioactive for thousands of years.
- Spent fuel storage should have brought about a two-year relicensing delay by NRC.
- Until the recent challenge in court, NRC took the negligent position that spent fuel was so safe, it was not to be considered in re-licensing, but a court decision overturned NRC’s irrational conclusion.
- NRDC petitioned the Atomic Licensing and Safety Board, arguing, among other things, that the reactors should not be re-licensed without a new, site-specific environmental impact review.
NRC STATEMENT IN LIMERICK’S APRIL 2013 DRAFT EIS
“If the results of the Waste Confidence Decision EIS identify information that requires a supplement to the EIS, the NRC staff will perform any appropriate additional NEPA review for those issues before NRC makes a final licensing decision.” (6-3)
- THAT MAKES NO SENSE AND IS UNACCEPTABLE FOR TWO REASONS
- THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK’S FINAL EIS BEFORE 2014, WHEN NRC’S COURT-ORDERED STUDY IS COMPLETED. LIMERICK’S FIRST LICENSE DOES NOT EXPIRE UNTIL 2024, A DECADE AWAY.
It is unacceptable for NRC to finalize Limerick Nuclear Plant’s EIS prior to finalization of NRC’s Court-Ordered Waste Confidence Rules, which will not occur until 2014. The U.S. Court of Appeals for the D.C. Circuit found that an Environmental Impact Statement needed to add additional discussions concerning the impacts of failing to secure permanent disposal of spent nuclear fuel, and concerning the impacts of certain aspects of fuel pool leaks and fires.
- THERE ARE MAJOR UNADDRESSED AND UNANSWERED SPECIFIC CONCERNS ABOUT CURRENT STORAGE OF LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES, ESPECIALLY THE WASTE CURRENTLY STORED IN LIMERICK’S FUEL POOLS.
NO FINAL LIMERICK EIS SHOULD BE COMPLETED UNTIL AFTER NRC’S WASTE CONFIDENCE RULING HAS BEEN FINALIZED AND ALL LIMERICK SPECIFIC HIGH-LEVEL RADIOACTIVE WASTE ISSUES HAVE BEEN COMPLETELY ANSWERED AND ADDRESSED.
- IT WOULD BE PREMATURE AND ABSOLUTELY INAPPROPRIATE TO ISSUE LIMERICK’S FINAL EIS WITHOUT INCLUDING THE RULING FROM THE COURT-ORDERED WASTE STUDY, AND WITHOUT ANSWERING IMPORTANT QUESTIONS AND CONCERNS.
- 3-21-13 ACE presented a written request to NRC for responses to specific Limerick high-level radioactive waste issues.
- NRC failed to respond to the concerns and questions presented 3-21-13. 5-16-13 Mel Gray responded to other issues for which we asked questions, but totally ignored the high-level radioactive waste issues.
LIMERICK’S FUEL POOLS
Spent Fuel Pools – A Catastrophe Waiting To Happen
- Limerick’s Fuel Pools are OVERLOADED with massive amounts of high-level radioactive waste rods. Wastes held in pools exceed design expectations.
- Large volumes of Limerick’s highly radioactive wastes produced since Limerick started operating in 1985 are stored in Limerick fuel pools.
- Fuel pool liners are corroding and thinning faster than expected.
- Pools are filled with radioactive fluids that are threatening to boil away, introducing radiation into the air.
- They are vulnerable to a 9/11 type terrorist attack with a plane or missile. That kind of attack could lead to an unstoppable radioactive fire which could impact people hundreds of miles away, according to an NRC study (2000).
- Pools are outside the reinforced containment structures for the reactors.
- With so much deadly radioactive wastes in the pools, an attack on Limerick’s fuel pools could result in an unstoppable radioactive fire, with potentially worse consequences than Chernobyl.
Below Is A Summary of Major Issues and Concerns To Be Addressed:
- 1. Corrosion and Thinning Documented in Limerick’s Fuel Pool Liners at Rates up to 10 times Faster than Anticipated.
- 2. High-Level Radioactive Wastes Stored in Limerick’s Fuel Pools Beyond Design Capacity.
- 3. Limerick Previous Accepting Waste From Other Nuclear Plants – Permit Changed in 2012 Without A Hearing
- 4. Structural Deficiencies in the Concrete of Limerick’s Fuel Pools
- 5. Limerick’s Fuel Pools Are Similar to Those That Exploded at Fukushima – High Above reactors With NO Containment.
- 6. Inadequate Alternative Back-Up Power
- 7. Fuel Pool Instrumentation
- 8. Spent Fuel Pools Are At High Risk For Meltdowns From Loss of Cooling Water Due To:
- Earthquakes, Cracking, Aging, Brittle, Deteriorating, Substandard Cement
- Leakage and Evaporation
- Explosion Inside or Outside Pool Building
- Terrorist Acts With Planes Or Missiles – Fuel Pools Are Not Protected Against Air Strikes or Missiles
ü Aircraft Impact
ü Accidental or Deliberate Drop of Fuel In Transfer
See: Spent Fuel Pools Pose A Danger – Associated Press – March 17, 2011
CORROSION and LOSS of THICKNESS in LIMERICK’S SPENT FUEL POOLS
NRC caved in to Exelon, ignoring NRC’s own objections to Exelon’s request to delay coating of Limerick’s fuel pools. NRC plans to ignore documented cracking, corrosion, pitting, and cavitations in Limerick’s fuel pools holding the most deadly materials on earth, related to relicensing approval. Limerick could be relicensed with no guarantee Exelon ever can or will coat or provide other protective measures on Limerick’s fuel pools.
NRC told Exelon that to delay coating the degraded fuel pool areas is unacceptable.
NRC outlined “Substantial Corrosion” and loss of thickness issues in Limerick’s fuel pool liners.
(Documented in 7-20-12 NRC letter to Exelon)
- The documented corrosion rate is far higher than original corrosion rate calculations for fuel pools.
- Pitting corrosion rates are unpredictable (usually 2 to 10 times more than the general corrosion rates).
In spite of cracking, corrosion, pitting, and cavitations in Limerick’s fuel pools, documented by NRC:
- 1. Exelon requested deferring protective measures like coating until Limerick’s current licenses expires (a delay of 12 to 17 years).
- 2. Exelon proposes inspection only every 10 years.
Despite adverse impacts on the safety and integrity of Limerick’s fuel pools and associated unprecedented threats to public health and safety:
- NRC revised regulations to accommodate Exelon’s requests to delay coating Limerick’s fuel pools, despite enormous threats to public health and safety for millions of people.
We Believe NRC’s Assumption That Limerick’s Fuel Pools Can Be Coated At All Is Based On Illusion. The Public Needs Answers:
- It is negligent to assume Limerick’s fuel pools will remain safe until Limerick’s current license expires in 16 years, when corrosion has already been documented at rates far faster than originally calculated. What NRC officials made the inexplicable decision to allow delayed coating of Limerick’s fuel pools, despite NRC’s original conclusion that to delay coating fuel pools was unacceptable? Please provide name(s) and contact information.
- NRC appears to be under the illusion that coating fuel pools can be done at all.
Explain the exact process in detail that Exelon would use to coat liners, now or in the future.
Answer critical questions below:
- Won’t all radioactive water and radioactive wastes need to be removed from fuel pools for repair and coating?
As long as Limerick continues to operate, 2 more tons each year of this deadly radioactive waste will need to be cooled in Limerick’s fuel pools for at least 5 years.
Limerick’s fuel pools are already overloaded, far beyond design basis, with this waste that requires cooling for a minimum of five years, to avoid combustion resulting in a devastating radioactive fire.
- Where would the radioactive wastes currently stored in the pools go until pools are coated? That waste will still need to be cooled.
- Where will the massive amount of radioactive water go when drained for recoating?
- Did anyone except Exelon ever inspect fuel pool liners for cracking, corrosion, pitting, and cavitations? Were fuel pool liners ever inspected by NRC?
- How does NRC justify inspection only every 10 years, when pitting corrosion rates have proven to be much greater than original rate calculations?
LIMERICK’S FUEL POOLS ARE PACKED, FAR BEYOND DESIGN BASIS
Limerick’s Radioactive Fuel Rods Are Among The Deadliest Materials On Earth
Estimated Spent Fuel Stored At Limerick
An Estimated 1,143 Tons
Many tons more will be produced each year Limerick operates.
Limerick’s Over Packed Fuel Pools Are Extremely Dangerous And Must Be Protected
- Spent Fuel In Pools Contain More Radioactivity Than Reactors
- Spent Fuel Rods Give Off Enough Radiation To Kill People In Seconds
- Pools Are At High Risk From Loss of Water Accidents
WHY DO LIMERICK’S FUEL POOLS CONTAIN SO MANY MORE FUEL ASSEMPLIES THAN OTHER NUCLEAR PLANTS OPERATING LONGER?
LIMERICK’S FUEL POOLS CONTAIN FAR MORE THAN FUKUSHIMA’S AND OTHER US NUKES:
Limerick’s Fuel Pools Contain Far More Assemblies Than Other U.S. Nuclear Plants, Including Exelon’s Three Mile Island and Oyster Creek
Compared to Fukushima
More Than Twice As Much In 2 Limerick Fuel Pools Than 4 At Fukushima.
6,203 Assemblies - 2 LIMERICK FUEL POOLS
2,400 Assemblies - 4 FUKUSHIMA FUEL POOLS
Information Above From The Institute for Policy Studies by Bob Alvarez, “Spent Nuclear Fuel Pools in the U.S.: Reducing the Deadly Effects of Storage” Appendix A: Site Specific Estimates of Radioactivity in U.S. Spent Fuel Page 26 Source: DOE/EIS-0250, Appendix A, Tables A-7, A-8, A-9, & A-1
- Did Limerick ever take spent fuel from other nuclear plants?
- Did Limerick ever take spent fuel from Three Mile Island after the partial meltdown?
NRC’s 5-18-12 written response to ACE about quantity of fuel used at Limerick was puzzling.
“Exact amounts of ‘special nuclear material’ in a licensee’s possession is considered to be security sensitive information and not permitted to be released to the public.”
- 1. We believe the public has a right to know how much waste is at Limerick and where it came from.
- 2. Approximately 2 tons produced each year for the 28 years Limerick operated should be 56 tons, NOT 1,143 tons. Explain in detail. Why is there so much more from two Limerick reactors then 4 Fukushima reactors?
- 3. Even if it is 2 tons per reactor per year, the amount stored in Limerick’s pools should only be 106 Tons, NOT 1,143 Tons.
This discrepancy needs to be fully understood by the public. If the amount of waste used per reactor each year can be estimated, there is NO LOGICAL REASON NRC should refuse to provide the public with approximate totals. Anyone should be able to do the math, including terrorists and NRC. NRC’s response made us wonder what is really going on.
- Did Limerick’s Operating License Amended 12-19-11 Allow Limerick To Receive and Possess Spent Fuel Rods From Other Nuclear Plants? YES OR NO
Limerick’s Operating License Permit Was Amended (12-19-11). Language Included
“To Allow Limerick to Receive and Possess Fuel Assemblies and Fuel Channels From Other Nuclear Plants, Such As That Already Received From Shoreham Decades Earlier.”
Exact language (Below) Is From Limerick’s Amended Operating Permit 12-19-11
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION,
UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 167 License No. NPF-85
(4) Pursuant to the Act and 10 CFR Parts 30, 40, 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and
(5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station.
DID NRC ALLOW LIMERICK TO ACCEPT HIGH-LEVEL RADIOACTIVE WASTES FROM OTHER NUCLEAR PLANTS DECADES AGO, BUT JUST CHANGE LIMERICK’S OPERATING PERMIT TO ALLOW THAT 12-19-11?
ACE Requested Detailed Explanations From NRC, But Didn’t Even Receive A Response To The Following Questions;
- Why Would Limerick Have Its Operating License Amended In 2011 To Receive and Possess Radioactive Waste From Other Nuclear Plants, When Limerick Already Received These Wastes From Shoreham and Possibly TMI?
- Did receipt and possession of Shoreham’s waste violate Limerick’s original operating permit?
- When Limerick received waste from Shoreham decades ago, wasn’t that in violation of Limerick’s operating permit?
- This Is A Major Permit Change, Which Adds Dramatically to The Risk In Our Entire Region and the Transportation Route. Why Wasn’t The Public Widely Informed With An Opportunity To Comment and Have A Public Hearing?
- How long will it take Exelon to remove most of Limerick’s deadly wastes from dangerous fuel pools and store it in above ground casks?
STRUCTURALLY SUBSTANDARD CEMENT IN LIMERICK’S FUEL POOLS
Defective concrete in Limerick’s fuel pools could have serious adverse effects on the structural adequacy to prevent leaks and meltdowns triggered by an earthquake or a terrorist attack with a plane or missile.
NRC’s 5-12 response to ACE acknowledges the structural defect from the concrete pour of Limerick’s fuel pools, but refers to a decades old unsubstantiated NRC “assumption” that it would have no adverse effect on the structural adequacy.
- NRC’S “ASSUMPTION” Is Both Illogical And Unsubstantiated.
NRC’s “assumption” was indefensible from the beginning, but it’s even worse now, with increasing threats from earthquakes and terrorist attacks with planes or missiles on the stories high fuel pools. We remind NRC that if Limerick’s fuel pools suffer cracks and cooling water starts to leak, it can be the beginning of a catastrophic disaster.
INADEQUATE ALTERNATIVE BACK-UP POWER TO PREVENT MELTDOWNS IN FUEL POOLS AND REACTORS AS WAS NEEDED AT FUKUSHIMA.
- It Appears Limerick Will Be EXEMPTED From NRC’s Post-Fukushima Still To Be Revised Station Blackout Rule, And That Back-Up Power To Prevent Meltdowns At Limerick Is Still Woefully Inadequate
- The Fukushima disaster proves there could be four simultaneous meltdowns at Limerick and that a constant energy supply is vital for cooling water and other operations to prevent meltdowns.
- In 2013, two years after Fukushima, NRC has still not required Exelon to have indefinite back-up power to prevent potential meltdowns in Limerick’s two reactors and two fuel pools.
- New NRC rules say there must be indefinite back-up power, yet it does not appear that indefinite back-up power is available at Limerick for fuel pools or reactors.
- NRC’s new “station blackout” rules do not apply to plants licensed to operate prior to July 21, 1988, which includes Limerick, according to NRC’s website, Last Reviewed/Updated, Friday, March 01, 2013,
- In 2011, Ex-NRC chairman Jaczko said, “ I’m not convinced four hours is reasonable to restore off-site power”.
- Despite repeated requests, NRC has provided no evidence that Limerick has more than four hours of back-up power for each reactor or any back-up for fuel pools.
After Fukushima, we learned only 4 hours or 8 hours of back-up power for Limerick could be woefully inadequate to attempt to prevent meltdowns, yet it appears that is all that is required at Limerick.
- We also realized in a worst case scenario, there could meltdowns simultaneously, in both reactors and both fuel pools at Limerick from loss of power, then loss of water.
- In April 2012, ACE first asked NRC about the numbers of Limerick’s back-up generators and the available time of operation for each.
- March 21, 2013, ACE again asked for specific answers about the length of time of Limerick’s capability to provide back-up power for both generators and fuel pools simultaneously, in the case of a black-out from natural disasters or terrorist attacks.
Specific Questions on Back-Up Power to Prevent Meltdowns:
- Does Limerick have access to back-up generators for Limerick’s 2 reactors and 2 fuel pools operating simultaneously?
If not, why not?
Are all back-up generators planned for Limerick stored on-site?
If not, did NRC verify planned back-up generators will actually be available and how long it would take to get them operating on site?
How many times a year are capabilities of generators tested (on and off-site)? There have been many problems with start-up of generators, including a fire at Limerick in 2007.
- What is the exact amount of time Limerick can cope with station blackout?
Is it still only 4 hours?
If not, what is the new minimum capability required for each generator at Limerick?
- How long will fuel last that is stored on site (using generators for 2 reactors and 2 fuel pools)?
- What is the plan if power can’t be restored within the required time to restore power?
After what happened at Fukushima, NRC required indefinite back-up power capabilities. In March, 2012, a year after Fukushima, NRC made new rules requiring a plan to indefinitely survive blackouts, to keep reactors cool during an electric failure.
- NRC then revised the rule, allowing Exelon to avoid costs of providing indefinite blackout capability at Limerick Nuclear Plant.
- Station Black Out does not require a tsunami or an earthquake. Black Outs at nuclear plants have been caused by blizzards, tornadoes, raccoons, and a bird.
- Given the potential dire consequences, as part of the EIS for relicensing NRC should require Exelon to comply with the new NRC rule for indefinite back-up power for Limerick Nuclear Plant.
- Limerick should be required to prepare for the worst case scenario and have indefinite back-up power, enough for both reactors and fuel pools simultaneously to minimize devastating environmental harms.
INADEQUATE FUEL POOL INSTRUMENTATION TO DETECT LOSS OF
WATER TO PREVENT MELTDOWNS.
March, 2012, Older reactors with General Electric Co (GE) design containment structures like Limerick’s (similar to those that failed at Fukushima) were ordered by NRC to have sturdier venting systems to prevent damage to reactor cores.
NRC rules required Exelon to install new, more reliable instrumentation at Limerick, to measure Limerick’s spent fuel cooling pools – no later than within 2 refueling cycles. Exelon was given 60 days to respond. Exelon’s response was due by May 12, 2012. Orders were issued by NRC August 30, 2012.
- HAS EXELON REPLACED LIMERICK’S FUEL POOL LEVEL INSTRUMENTATION?
IF SO, WHEN? IF NOT, WHY NOT?
Limerick’s spent fuel instrumentation may only be capable of monitoring under normal conditions. Spent fuel pools rely on maintenance of an adequate inventory of water under accident conditions to provide containment to prevent meltdowns, as well as for cooling and shielding. Emergency responders need reliable information on water in spent fuel pools to prioritize emergency actions. At Fukushima responders were without reliable instrumentation to determine water level in the spent fuel pool. This caused concerns that the pool may have boiled dry, resulting in fuel damage. Fukushima demonstrated confusion and misapplication of resources that can result from inadequate instrumentation.
LIMERICK’S PACKED FUEL POOLS ARE VULNERABLE TO EARTHQUAKES
AND TERRORISTS’ AIR STRIKES AND MISSILES.
Shaking from earthquakes can cause cracking in cement of fuel pools, leaking of cooling water, and eventually potential meltdowns.
NRC gave Exelon until 2017 to deal with earthquake risks at Limerick.
- What exactly will Exelon do to reduce threats of cracking of brittle cement in Limerick’s fuel pools?
- Given the consequences, whatever can be done should be required immediately. Waiting until 2017 is far too risky.
Limerick’s fuel pools are stories high over the reactors, similar to Fukushima’s. There is no protective containment such as exists around the reactors. A terrorist air strike or missile could trigger leaking of cooling water, possibly even fires. There is no way to protect fuel pools from terrorist planes or missiles.
- Would Limerick’s fuel pools be protected against terrorist air strikes or missiles if Limerick is relicensed? If not, why not? If so, how?
Summary: SPENT FUEL POOLS AT LIMERICK
Large volumes of Limerick’s high-level radioactive wastes (all produced since 1985) are being stored in fuel pools and casks on the Limerick site. They are among the most deadly materials on earth. EPA gave storage of this dangerous waste a million-year health standard. This will likely remain in our region for decades, if not forever. As long as Limerick operates, tons more of this deadly waste will be produced each year.
- Limerick’s Spent Fuel Pools Are Packed Beyond Design Basis, And Vulnerable.
- Limerick’s Spent Fuel Pools Are At High Risk From Loss of Cooling Water Through Leaks Due To:
Earthquakes – Reactor Failure – Leakage- Evaporation – Explosion Inside or Outside Pool Building – Terrorist Acts Such As Aircraft Impact, Siphoning, Pumping, Accidental or Deliberate Drop of Fuel In Transfer
Limerick’s fuel pools are packed far beyond design capacity, sit five stories above ground, and are highly vulnerable to loss of water through terrorist attacks by plane or missile, and cracking or crumbling from a strong earthquake.
Limerick’s fuel pools were constructed with substandard cement, which is becoming embrittled after 28 years.
- The Release of Radiation From Limerick’s Fuel Pools Could Render The Entire Greater Philadelphia Region Uninhabitable For Generations. Health and Economic Impacts Of A Terrorist Attack On Spent Fuel Pools Like Limerick’s Could Be Astronomical.
Especially vulnerable to aircraft penetration, Limerick’s fuel pools can be turned into weapons of mass destruction. Still, Exelon has not been required to spend the money to guard Limerick against terrorist missiles or air strikes.
Large volumes (over 6,000 assemblies-1,000 tons), of Limerick’s highly radioactive wastes (spent fuel rods) are stored in densely packed fuel pools, elevated five stories above and outside the reinforced containment structure for the reactor.
Limerick’s design is similar to reactors in meltdowns at Fukushima. Roof-top fuel pools are highly vulnerable to loss of power and cooling water from an earthquake or other natural disasters, in addition to a variety of attacks by terrorists.
With loss of cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire, causing tens of thousands of deaths up to 500 miles away, according to a 2000 NRC study.
A meltdown in a spent fuel pool could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site.
Health and Economic Impacts Of A Terrorist Attack On Spent Fuel Pools Like Limerick’s
Limerick’s packed fuel pools can be turned into weapons of mass destruction. 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).
A January 2003 study by Dr. Gordon Thompson, Director of the Institute for Resource and Security Studies (entitled “Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security”) reviewed ways spent fuel pools are vulnerable to attack.
- A nuclear fire in 1 spent fuel pool would “render about 95,000 square kilometers of land uninhabitable,” (would cover about 75% of New York State, and into, segments of NJ and CT.)
SPENT FUEL FIRES
“A Spent Fuel Fire Can Contaminate 8 To 70 Times More Land Than Chernobyl”
- “Spent Fuel Must Be Seen As Pre-Deployed Radiological Weapons”
- ” With Loss of Water, Spent Fuel Rods Heat Up, Self-Ignite And Burn in an Unstoppable Fire.”
- “Zirconium Cladding – Can Trigger a Reaction and Fire Which Can Burn Away Cooling Water”
|Fuel Rods In Pools At Limerick Risk Loss Of Water From A Fire Because:
NRC didn’t require Limerick to follow the safest fire safety regulations. NRC made a second set of standards followed by Limerick, determined to be “safe enough”. That is not acceptable, given the consequences of a fire involving Limerick’s fuel rods stored in pools.
The pools are vulnerable to a 9/11 type terrorist attack and fire from jet fuel. NRC is failing to require Exelon to guard against this type of attack at Limerick.
We need the most stringent precautions. Dr. Thompson concluded a nuclear fire in the spent fuel pool (of Indian Point Unit 2) would: Release Enough Cesium-137 “To Render About 95,000 Square Kilometers Of Land Uninhabitable,” (covering about 75% of New York. Similar distance would be true here.
|LIMERICK’S DRY-CASK STORAGE
ANOTHER REASON THAT LIMERICK’S DRAFT EIS MUST BE CHANGED TO INCLUDE POTENTIAL HARMS FROM THIS DEADLY WASTE:
- LIMERICK’S HIGH-LEVEL RADIAOCTIVE WASTES STORED IN CASKS ALSO PRESENT LONG-TERM ENVIRONMENTAL RISKS THAT CAN’T BE IGNORED BY NRC IN ITS DRAFT EIS FOR LIMERICK.
Spent Fuel Stored In Above Ground Casks
- Casks Are Threatened by Natural Disasters like Earthquakes, Tornadoes, and Floods. The extremely heavy casks were shifted on their base during the North Anna earthquake. If air flow vents get clogged from severe weather events and remain clogged for an extended period, rods can overheat and combust.
- Corrosion of steel holding Limerick’s high-level radioactive waste rods is a huge concern. NRC is well aware of Limerick’s highly corrosive air as a result of chlorine and other corrosives massively released into the air from Limerick cooling towers with 44 million gallons of steam every day.
- Corrosion over time may make it impossible to remove rods in the event of a problem with leaking, for transport, or event the threat of combustion.
- Containers are expected to last 50 years – wastes stay dangerous over a million years.
- Much of Limerick’s wastes are likely to remain on site in these casks for decades, if not forever. What will happen if corrosion makes it impossible to remove the wastes into new containers every 50 years?
- How much of this deadly high-level radioactive waste will be stored in how many of these casks on the Limerick site by 2029? 2049?
NRC’S DRAFT EIS NEEDS TO ADDRESS THE LENGTH OF TIME RODS NEED TO SAFELY REMAIN IN THE POOLS BEFORE EXELON REMOVES THEM FOR DRY CASK STORAGE.
- NRC HAS ALLOWED EXELON TO REMOVE RODS FOR DRY-CASK STORAGE FAR SOONER THAN THE 5-YEAR TECHNICAL SPECIFICATION REQUIREMENT.
- ACE OBJECTS TO THIS DANGEROUS DEVIATION FROM TECHNICAL SPECIFICATIONS, EVEN IF OLDER RODS ARE WRAPPED AROUND RODS LESS THAN 5 YEARS IN STORAGE.
- This is yet another example of NRC lowering safety protections to accommodate Exelon.
- It seems clear that Exelon is trying to load dry cask storage more quickly to free space for more waste being generated and that NRC is allowing this risky removal to accommodate Exelon.
NRC Is Clearly Jeopardizing Health and Safety Of Limerick Workers and The Public By Removing Limerick’s Radioactive Rods Sooner Than The 5-Year Technical Specification Requirement.
- Since 2006, when Exelon first tried to convince the public that cask storage was safe, NRC and Exelon repeatedly stated 5 years was required to safely remove fuel rods from Limerick’s fuel pools, however that ‘s not what happened at Limerick – at least in 2010.
- IMPORTANT POINT – The less cool down time in fuel pools, the thermally hotter and more radioactive the waste – the more risk of internal combustion and an unstoppable radioactive fire.
- Dry cask technical specifications state: Radiation shielding and thermal heat removal require around 5 YEARS, minimum, cool down time in the pool before transfer to dry casks.
- Yet, June 16, 2006, NRC in a letter to ACE claimed 1 year storage in the fuel pool at Limerick was sufficient before removal for above ground storage.
- July 13, 2006 at a meeting in Limerick NRC again clearly stated cool down time before removal from fuel pools was at least 5 years.
- July 25, 2006 ACE received an e-mail from NRC stating:
- Cooling time in the pool is: 1 year or 3 years or 5 years
From: James Trapp – NRC Date: 07/25/06 07:04:34
In our letter to you dated June 16, 2006 we stated the time was at least 1 year. This statement was correct. I received the following information from Randy Hall that should help to clarify our statement.…. Most spent fuel that is placed in dry storage must be aged for 5 years or more, as required by all NRC-approved Certificates of Compliance for dry cask storage systems….Purposely using the word most, because there are cask designs, including NUHOMS, that would allow certain low-irradiated fuel to be placed in a cask with only 3 or more years of cooling in the spent fuel pool.
- May 6, 2010 - Exelon Employee At A Limerick Open House Said:
Older and newer “spent fuel rods” are removed from Limerick’s fuel pools at the same time. Older rods are stored outside newer rods in assemblies (sometimes 1-year old).
- NRC Irresponsibly Allows Dangerous Fuel Rod Removal To Accommodate Exelon.
Risk to Region – Potential Unstoppable Radioactive Fire
Limerick Workers – Higher Radiation Dose
- NRC’s Pamphlet Proves How Dangerous Nuclear Power Plant High-Level Radioactive Waste Is. Office of Public Affairs Brochure NUREG/BR-0216, Rev.2“May 2002 – Page 7 – How hazardous is high-level waste? Standing near unshielded spent fuel could be fatal due to the high radiation levels.
TEN YEARS AFTER REMOVAL OF SPENT FUEL FROM A REACTOR:
- RADIATION DOSE 1 Meter Away From A Spent Fuel Assembly EXCEEDS 20,000 Rems Per Hour
- 5,000 Rems Would Be Expected To Cause Immediate Incapacitation and Death within One Week
Clearly, removing spent fuel rods from pools to load dry casks far sooner than the 5-year requirement is an extremely dangerous experiment that needs to be stopped at Limerick. While it frees space in pools for new wastes to be generated by Limerick, to make more money for Exelon, it presents unacceptable risks to workers and the public.
Consider The Following:
10 years after removal of spent fuel from a reactor:
ü Radiation dose 1 meter away from a spent fuel assembly exceeds 20,000 Rems Per Hour
ü 5,000 Rems would be expected to cause immediate incapacitation and death within 1 week.
Information From: NRC’s own pamphlet NUREG/BR-0216, Rev.2 May 2002
211 Radioactive Poisons found in every 10-yr. old irradiated fuel bundle (Canadian Study)
ü Polonium 210 – Just 1 of 211 – the type that poisoned Alexander Litvinenko in 2006
ü An alpha emitter with the ability to become airborne with ease
ü 1 Gram could poison 100 million people – Extremely dangerous in milligrams or micrograms
ü Biological ½ life in humans 30 to 50 days
ü Targets organs – liver and spleen
ü Short-term exposure carries long-term risk of death from cancer
LIMERICK’S DRY CASK STORAGE OF LIMERICK’S DEADLY RADIOACTIVE WASTES ABOVE GROUND IN CASKS – RISKS MUST BE ADDRESSED IN NRC’S FINAL EIS FOR LIMERICK NUCLEAR PLANT
Limerick’s Independent Fuel Storage Installation was placed in service starting July 21, 2008. Since 2008, Exelon started removing Limerick’s dangerous deadly radioactive wastes from Limerick’s fuel pools to above ground dry cask storage. From 1985, after Limerick started operating, until 2008, all Limerick Nuclear Plant’s deadly high-level radioactive wastes were stored in Limerick’s fuel pools. They become dangerously overcrowded. Limerick’s fuel pools are a similar design to those melting down at Fukushima.
Limerick’s dangerous and deadly radioactive wastes will likely remain in our backyard forever, posing serious threats to us and future generations. Limerick Nuclear Plant has turned us into a DeFacto High-Level Radioactive Waste Dump. EPA set a million year health standard for high-level radioactive waste storage. Containers holding these deadly wastes are estimated to safely contain the waste for only 50 years, when the wastes remain deadly for hundreds of thousands of years.
CASK DESIGN FLAWS – A SERIOUS CONCERN
- A Nuclear Engineer Warned ACE About Design Flaws In Casks For Storing Limerick’s High-Level Radioactive Wastes.
- ACE Reported The Information To NRC. Sadly, Design Flaws Were Denied Or Ignored.
EVENTUALLY PROBLEMS COULD BECOME A RECIPE FOR DISASTER.
ü UNDETECTED CORROSION
ü INABILITY TO REMOVE IN CASE OF FIRE OR NATURAL DISASTER
ü FAULTY CONCRETE
ü EASY TERRORIST TARGET
ü LAX NRC OVERSIGHT AND ENFORCEMENT
- THE NUCLEAR ENGINEER WHISTLE BLOWER CALLED LIMERICK CASK TECHNOLOGY “OLD AND DOWNRIGHT DANGEROUS”
- 1. Cask Design Flaws
- Cement Blocks, Assembled Together, Are Not The Safest Housing For Enclosing Deadly Nuclear Fuel, Not Even Anchored to the Concrete Floor
- Industry Workers Claim NUHOMS Concrete Enclosure Falls Apart and Container Is Breeched Under a Boeing Airplane Strike.
- 2. Corrosion of Steel
- Can Eventually Cause Nuclear Wastes to Collapse On Their Own.
- Safe Storage Depends on Airflow. Air Around Limerick Is Likely Highly Corrosive. It’s Only a Matter of Time Before Invisible and Inaccessible Steel Tubes Turn to Rust.
- 40 Ton Radioactive Waste Containers, “Filled With The Nastiest Of Manmade Stuff”, Are Placed And Rest Unfastened On A Set Of Steel Columns.
- 3. Wastes May Not Be Able To Be Retrieved
- Rods Are Being Removed From Pools at Limerick Years Before NRC Regulations First Required. Rods Stored In Casks Too Hot Can Heat Up And Cause Fire.
- Containers Are Expected To Last 50 Years, While Wastes Are Deadly Hundreds Of Thousands Of Years.
He Said Casks May Be A Sitting Duck In Face of a Crashing Aircraft
CORROSION – A MAJOR CONCERN
Research validates ACE concerns about corrosion of steel storing deadly wastes at Limerick Nuclear Plant. No one knows how long it will take for nuclear waste storage containers to break down from corrosion and eventually leak – It is only a matter of time.
How long will it take for steel to corrode that holds high-level radioactive wastes above ground in our back yard at Limerick Nuclear Plant?
2005 NRC’S OWN STUDY FOUND PROBLEMS WITH CORROSION RATES OF METALS USED TO STORE NUCLEAR WASTE.
- YET NRC STOPPED THE RESEARCH INSTEAD OF ADDRESSING THE CORROSIVE STEEL.
PROVEN CORROSION CONCERNS
- 2006 Testimony to Congress by Public Citizen – Provided evidence of scientific misconduct by NRC and DOE related to corrosion rates of metals used to store nuclear wastes.
ü In 2005 NRC found problems with the corrosion rates of metals used to store nuclear waste, yet failed to address the corrosion problems.
ü Research identifying corrosion problems was stopped, not the use of steel that would corrode.
- 2006 NRC dismissed important evidence identified by ACE related to corrosion of steel planned to hold Limerick’s high level radioactive wastes in above ground casks.
ü Every day Limerick adds massive amounts of toxic chemicals to cooling tower waters.
ü MSDS sheets identify 10 of them to be corrosive, some highly corrosive and some specifically corrosive to steel.
ü There is NO FILTRATION to prevent corrosive chemicals from entering the air from cooling tower steam.
ü Synergistic combinations of the corrosive additives can result in a serious corrosive threat to people and everything exposed to the drift from the cooling towers (44 million gallons every day), including steel holding deadly radioactive wastes stored inside casks that require cooling with outdoor air.
ü Corrosive air enters casks holding high-level radioactive waste rods stored in steel.
ü NRC admits corrosion will happen, yet dismissed ACE concerns without site specific testing of cooling tower emissions for specific and conversion corrosives.
ü NRC’s dismissive, misleading, and irresponsible conclusions defy logic. They can lead to irreparable disaster in our region.
NRC PROVES CORROSION FROM LIMERICK’S COOLING TOWERS CORRODES STEEL AND CAUSES CRACKING IN 4 TO 52 WEEKS.
June 12, 2012
- a. RAI B.2.1.25-1.1
Stress Corrosion Cracking for stainless steel surfaces in an outdoor air environment in auxiliary and steam and power conversion systems.
EMPHASIS ADDED: LIMERICK’S NPDES PERMIT SAYS:
16,000 TO 58,000 lbs per day of CHLORINE (sodium hypochlorite) are used at Limerick Nuclear plant.
Exelon told NRC:
- Even though CHLORINE is ADDED to COOLING TOWERS AS SODIUM HYPOCHLORITE, there is no concern (for stress corrosion cracking of stainless steel surfaces) because “COOLING TOWER PLUME IS DIRECTED AWAY FROM THE PLANT”
- Studies and industry operating experience in chloride-containing environments have shown that stainless steel exposed to an outdoor air environment can crack at temperatures as low as 104 to 120 degrees F, depending on humidity, component surface temperature, and contaminant concentration and composition.
- Cracking can occur in 4 to 52 weeks.
- NRC cannot conclude recent inspections are sufficient to demonstrate an aging effect will not occur during the period of extended operation.
- A prevailing wind does not result in the absence of contaminant deposition by the cooling tower plume.
- Information has not been provided on the potential for chloride contamination from the onsite soil or nearby agriculture and industrial sources.
- NRC lacks sufficient information to conclude that stress corrosion cracking cannot occur in stainless steel components located in an outdoor air environment.
- Corrosion can make it difficult, if not impossible, to move Limerick’s extremely heavy casks. To date, there is no proof Limerick’s radioactive fuel rods can be moved safely after years of exposure to corrosive air.
NRC’S DENIAL AND NEGLIGENCE COULD EVENTUALLY LEAD TO DISASTER RELATED TO LIMERICK’S CASKS
- NRC admits there were fabrication deficiencies in materials used for Limerick’s canisters and concrete, but refuses to call them flaws, and claims they were corrected, even though that may not be entirely accurate. While the company was fined a nominal amount, in years to come, we could find cask design flaws could lead to a radioactive disaster.
- July, 2006 Areva, the company making Limerick casks, received a Notice of Violation, documenting specific problems with casks already in place, yet NRC allowed casks for Limerick to continue to be built by this company.
- November, 2006 in a whistle blower letter it was revealed that there were specific concerns about casks planned to be used at Limerick.
- In an 11/06 letter to ACE, both NRC and Transnuclear (Areva) admitted there would be corrosion and settling of ground beneath 40 ton casks, yet NRC failed to require air testing in the vicinity of casks for corrosives against metals being used for casks.
EARTHQUAKE THREATS TO CASKS
- The earthquake in Virginia proved heavy cement casks, each weighing many tons, can be jarred and even moved. Casks at a nuclear plant 12 miles from the epicenter of the August 23, 2011 earthquake in VA were moved by the earthquake.
- There is an earthquake fault directly under the Limerick site with two others within 2 miles. Two other earthquake faults are very close to Limerick. One 9 miles away is active. The other is 17 miles away.
- After a natural disaster like an earthquake, there is no proof that this deadly waste will be able to be removed safely, especially after corrosion has taken place. None have ever been removed after a long period of time.
- What could happen if damaged or overheating fuel rods in casks cannot be removed because of jarring from an earthquake? No one knows. It’s like playing Russian Roulette.
NRC REFUSED TO PROVIDE A RISK ASSESSMENT FOR TERRORISTS
Limerick Is NOT Protected From Terrorists’ Missiles and Air Strikes.
ACE REPEATEDLY URGED NRC TO PROVIDE A RISK ASSESMENT FOR TERRORIST ATTACKS ON CASKS.
- Limerick has the 2nd most densely populated region in the U.S.
- NRC was negligent in failing to provide a risk assessment for terrorist attacks related to above ground storage of high-level radioactive wastes at Limerick Nuclear Plant.
A Federal Court Ordered NRC To Assess Terrorist Threats In California
A U.S. Court of Appeals 9th Circuit decision forced NRC to assess the threat of a terrorist attack on above ground storage at the Diablo Canyon Nuclear Plant in California.
ACE Asked NRC To Consider The Same Threats As Were Required At Diablo Canyon.
1) The threat posed by a “land-based vehicle bomb.”
2) A “ground assault with the use of an insider”
3) A “water-borne assault”
4) “A large aircraft impact similar in magnitude to the attacks of September 11, 2001.”
Similar threats exists at Limerick, yet NRC chose to interpret the 2006 court decision in a very narrow way.
- NRC inexplicably claimed an assessment was not necessary at Limerick, even though vast numbers of people live very close to Limerick Nuclear Plant.
- NRC dismissed harmful health impacts from radiation exposure, irrationally claiming “a significant release of radiation affecting the public is not reasonably expected to occur”, when army testing suggests otherwise.
- NRC also ignored the potential for rods overheating and combusting.
Consider The Following Limerick Specific Issues For A Risk Assessment to be Included In Limerick’s Updated EIS:
1) Limerick is not guarded against airplane or missile attacks.
2) Nuke waste housing can be penetrated by missiles (proven by army testing).
3) THREE AIRPORTS are too close to Limerick Nuclear Plant.
ü Army testing proves missiles can penetrate casks.
ü Pilots take lessons at Limerick Airport, only 1 mile away.
ü Helicopters fly into the Limerick Airport from which missiles could be launched.
4) An industrial railroad runs through the nuclear plant site.
Industrial rail tracks run directly through the nuclear plant property, providing a way for terrorists to enter the site undetected.
5) A large portion of the site is bordered by the Schuylkill River.
Limerick Nuclear Plant property is bordered by the Schuylkill River (over a long distance), presenting a difficult, if not impossible challenge, for too few guards.
6) Too few guards have to cover Limerick’s 600 acres.
7) Heavily populated region surrounds Limerick Nuclear Plant – Almost 8 Million people within 50 miles.
Limerick Nuclear Plant’s Radioactive Wastes Are A Major Threat To Public Health, Safety, And The Economy In The Greater Philadelphia Region
As Long As Limerick Continues To Operate, More Of This Dangerous and Deadly Waste Will Be Produced.
- Limerick is a de-facto high-level radioactive waste dump, storing massive amounts of all the deadly high-level radioactive wastes produced at Limerick since it started operating in 1985.
- Large volumes, if not all, of this dangerous waste will likely remain on the Limerick site long past Limerick’s proposed relicensing period in 2049.
- EPA has a million-year health standard for storage of high-level radioactive waste.
THERE IS NO SAFE SOLUTION FOR LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES.
- Facts About Limerick’s Dangerous Deadly High-Level Radioactive Wastes Show The Only Logical Solution Is To Stop Making It.
- LIMERICK SHOULD BE CLOSED AS SOON AS POSSIBLE, NOT RELICENSED.
EACH YEAR LIMERICK OPERATES MANY TONS MORE OF LIMERICK’S DEADLY HIGH-LEVEL RADIAOCTIVE WASTES WILL BE PRODUCED. THREATS WILL OBVIOUSLY INCREASE IF LIMERICK IS RELICENSED.
- LIMERICK’S RADIOACTIVE WASTES ALREADY PRODUCED NEED TO BE STORED ON SITE SAFER.
- NRC CANNOT JUSTIFY IGNORING LIMERICK SPECIFIC ENVIRONMENTAL IMPACTS FROM LIMERICK’S MASSIVE AMOUNTS OF HIGH-LEVEL RADIOACTIVE WASTES.
- NRC’S FINAL EIS FOR LIMERICK NUCLEAR PLANT SHOULD NOT BE COMPLETED UNTIL AFTER NRC’S COURT-ORDERED HIGH-LEVEL RADIOACTIVE WASTE STUDY IS COMPLETED IN 2014 AND THE RESULTING ACTIONS ARE APPLIED TO LIMERICK.
- THE OUTCOME OF NRC’S COURT-ORDERED HIGH-LEVEL RADIOACTIVE WASTE STUDY MUST BE INCORPORATED INTO LIMERICK’S FINAL EIS, REGARDLESS OF THE LENGTH OF TIME REQUIRED.
- THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK’S EIS FOR RELICENSING, WHEN LIMERICK’S FIRST LICENSE DOES NOT EXPIRE FOR OVER A DECADE.
For more information see www.acereport.org
Download #9 “High-Level Radioactive Wastes: A Ticking Time Bomb”
LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES
LOW-LEVEL DOES NOT MEAN LOW RISK.
LIMERICK NUCLEAR PLANT’S “SO-CALLED” LOW-LEVEL RADIOACTIVE WASTES CAN TAKE AS LONG AS 500 YEARS TO FADE TO NATURAL BACKGORUND LEVELS.
NRC FAILS TO TRACK VOLUME OF LOW-LEVEL RADIOACTIVE WASTES PRODUCED AT LIMERICK EACH YEAR. IN MARCH 2013 AN NRC OFFICIAL TOLD ACE THAT TRACKING THE VOLUME OF LIMERICK’S LOW-LEVEL RADIAOCTIVE WASTE ISN’T IMPORTANT. WE DISAGREE!
- IF NRC DOESN’T KNOW HOW MUCH IS PRODUCED, NRC CAN’T CONFIRM WHAT HAS HAPPENED WITH ALL OF THE MASSIVE LOW-LEVEL RADIOACTIVE WASTES PRODUCED AT LIMERICK NUCLEAR PLANT.
- PROBLEM: EXELON COULD STILL BE BURNING SOME OF LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES IN LIMERICK’S BOILER “A” WITHOUT NRC’S KNOWLEDGE.
NRC HAS NO ACCURATE IDEA HOW MUCH LOW-LEVEL RADIAOCTIVE WASTE IS PRODUCED AT LIMERICK EACH YEAR OR WHERE IT IS GOING.
- WE HAVE NO CONFIDENCE NRC HAS ANY IDEA WHAT EXELON IS DOING WITH ALL OF LIMERICK’S MASSIVE LOW-LEVEL RADIOACTIVE WASTES.
- NRC’S STATEMENTS AND NEWS REPORTS DON’T MATCH LOW-LEVEL RAD-WASTE DESTINATIONS REPORTED BY EXELON ON NRC’S WEBSITE (SIMPLY AS NUMBERS OF TRAIN OR TRUCK SHIPMENTS).
- JANUARY 2010, EXELON GOT PERMISSION TO SHIP LIMERICK’S LLRW TO PEACH BOTTOM. MARCH 2013 NRC TOLD US LIMERICK’S LLRW WAS SHIPPED TO PEACH BOTTOM. YET, NO SHIPMENTS WENT TO PEACH BOTTOM AT ALL IN 2010, 2011, OR 2012, ACCORDING TO NRC’S WEBSITE.
PROBLEM: NRC HAS BEEN DECEIVING US ABOUT INCINERATION OF LOW-LEVEL RADIOACTIVE WASTES AT LIMERICK NUCLEAR PLANT.
- SINCE 2009, NRC HAS BEEN DENYING THAT LIMERICK EVER BURNED LOW-LEVEL RADIOACTIVE WASTES.
- MARCH 2013 AN NRC OFFICIAL FINALLY ADMITTED WHAT WE SUSPECTED FROM REVIEWING LIMERICK’S AIR POLLUTION PERMIT IN 2009 – THAT EXELON BURNED LOW-LEVEL RADIOACTIVE WASTES AT LIMERICK.
INCINERATING ANY OF LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES IS NOT AN ACCEPTABLE OPTION, ESPECIALLY IN THIS HEAVILY POPULATED REGION WHERE THERE IS ALREADY A HEALTH CRISIS.
- BURNING RADIOACTIVE WASTES DOES NOT DESTROY THE RADIONUCLIDES, BUT INSTEAD DISPERSES THEM IN SUCH A WAY THAT THEY ARE MORE EASILY INHALED, INCREASING THREATS TO HEALTH FROM THE INTERNAL RADIATION EXPOSURE, THE MOST DANGEROUS EXPOSURE.
- POTENTIAL HARMS FROM BURNING LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES MUST BE INCLUDED IN LIMERICK’S FINAL EIS FOR RELICENSING.
EXELON IS CLAIMING THEY WON’T CONTINUE TO BURN LIMERICK’S LOW-LEVEL RADIAOCTIVE WASTES, BUT:
- EXELON’S TRACK RECORD SHOWS WHY WE CAN’T BELIEVE OR TRUST EXELON
- NRC HAS NO SYSTEM IN PLACE TO ACCURATELY CONFIRM WHAT IS BEING DONE WITH ALL LIMERICK LOW-LEVEL RADIOACTIVE WASTE.
NRC HAS NO LONG-RANGE PLAN FOR WHAT WILL BE DONE WITH ALL LIMERICK’S MASSIVE LOW-LEVEL RADIOACTIVE WASTES UNTIL LIMERICK’S CURRENT LICENSE IN 2029.
- NRC CANNOT JUSTIFY RELICENSING LIMERICK FOR 20 YEARS BEYOND 2929 WHEN THERE IS NO SAFE PLACE TO STORE ALL THE LOW-LEVEL RADIOACTIVE WASTE THAT WILL BE PRODUCED.
- THERE IS NO ROOM AT LIMERICK TO STORE THE LLRW THAT MUST BE KEPT AWAY FROM PEOPLE FOR UP TO 500 YEARS,
- PEACH BOTTOM CANNOT CONTINUE TO TAKE LIMERICK’S WASTES FOR DECADES. NRC SAID THERE IS NO PLAN TO TAKE LIMERICK’S WASTES TO PEACH BOTTOM FOR MORE THAN ONE YEAR AT A TIME.
- THE NATION IS RUNNING OUT OF ROOM TO STORE LOW-LEVEL RADIOACTIVE WASTES AT THE FEW SITES DESIGNATED IN OUR NATION TO STORE IT.
RECYCLING CANNOT BE AN OPTION
EXPOSING PEOPLE TO RECYCLED RADIOACTIVE WASTES IN THEIR PRODUCTS SUCH AS BELT BUCKLES, DISHES, AND BABY CARRIAGES INCREASES HEALTH THREATS AND COSTS. iT IS SHAMEFUL AND NEGLIGENT.
RECYCLING RADIOACTIVE WASTES CAN BE COSTLY TO BUSINESSES. FOR EXAMPLE, THE BED, BATH, AND BEYOND RECALL ON RADIOACITVE TISSUE HOLDERS.
BURNING LIMERICK’S LOW-LEVEL RADIOACTIVE WASTE CANNOT BE AN OPTION.
We are extremely concerned that Exelon may try to burn Limerick’s low-level radiaoctive waste in an incinerator or even in its boilers at some time in the future.
This would be tragic negligence on the part of Exelon and NRC. Visit our website for details www/acereport.org, summaries:
- · #2 – Cancer – Skyrocketing Increases: Links to Limerick
- · #5 – Limerick’s Major Air Pollution: A Serious Health Threat
- · #10 – Low-Level Radioactive Wastes: Not Low Risk
When Limerick Nuclear Power Plant applied for its Title V major air pollution license renewal, ACE questioned whether Limerick was incinerating low-level radioactive wastes. Due to our past investigations and opposition to incinerators in our community, we recognized that some of the air pollutants listed in Limerick’s air pollution permit were the same as those from an incinerator. Burning does not make radiation disappear. Inhaling radionuclides is one of the worst routes of exposure.
Section D Source Level Requirements #005 – Operating permit terms and conditions (a) “The permittee, may, in auxiliary boiler “A”, fire … Specific Waste Derived Liquid Fuel (WDLF).” The air toxics listed below from the WDLF are similar to those from incineration. The permit stated that WDLF Shall Meet Following Contaminant Limits Prior to mixing and Shall Not Exceed Limits After mixing:
(PRIOR to mixing with virgin No. 2 oil) (AFTER mixing or out the stack?)
- · Arsenic 10 ppm Arsenic 5 ppm
- · Cadmium 10 ppm Cadmium 2 ppm
- · Chromium 20 ppm Chromium 10 ppm
- · Lead 300 ppm Lead 100 ppm
- · PCB 49 ppm PCB 10 ppm
- · Total Halogens 1000 ppm Total Halogens 1000 ppm
Ash 2% ASTMD-482
Sulfur 0.3% X-Ray Diffraction
Permit States: Maximum Amount of WDLF to be burned in the boiler shall not exceed;
1) 10,000 gallons over 12 consecutive months
2) Maximum of 3,000 gallons in any single month
The list above suggested to us that Exelon was incinerating at least some of Limerick’s LLRW in one of Limerick’s 3 boilers, calling it “Waste Derived Liquid Fuel”.
Our major concern was the synergistic, additive, and cumulative harmful health impacts from all these toxics, combining with all the different kinds of radionuclides routinely released at Limerick, plus the magnified radiation risks from burning LLRW.
Experts explained to us the extreme danger with the potential consequences of exposure to radionuclides from an incineration process.
PA DEP’s response document denied that Limerick was burning low-level radioactive waste, but also failed to answer many of our specific questions.
In 2009 ACE Requested An Accounting For, And Destination Of, All Limerick’s Low-Radioactive Wastes From 2000 to 2049
Knowing that low-level does not mean safe and that some radionuclides in low level wastes can take as long as 500 years to fade to natural background levels, and realizing that Limerick could no longer send its low-level waste to Barnwell, S.C., we felt it was important to have full and accurate public disclosure on where Limerick’s low-level wastes would now be taken.. Obviously, there was no more room at Limerick, since Limerick sent it to numerous locations since 2005.
As long as Limerick Nuclear Plant continues to operate, massive amounts of low-level radioactive wastes will continue to be produced.
February 27, 2013 ACE requested answers and documentation to several LLRW issues from Mel Gray. On March 20, 2013 we received a response with links to annual records for shipments of low-level radioactive wastes from Limerick between 2005 and 2011. The numbers of annual shipments were reported, mostly by truck. There was no reporting on the number or capacity of vehicles per shipment, total weight, or total volume of wastes shipped.
Written responses were requested to each of the questions and concerns below for which we did not get answers:
- Can NRC document the total amounts of low-level radioactive wastes produced at Limerick each year? If so, please provide totals for each year from2005 through 2011. If not, why not?
- Exelon is now approved to send Limerick’s Low-level radioactive waste to Peach Bottom. Did NRC verify how many years Peach Bottom will be able to store Limerick’s massive low-level radioactive waste? Logic suggests if Limerick has no space on site to store it, Limerick’s low-level radioactive wastes cannot continue to be stored at Peach Bottom either.
ü Is there space to continue to store Limerick’s LLRW there until 2049?
ü Logic suggests Limerick’s low-level radioactive wastes cannot continue endlessly to be stored at Peach Bottom.
ü Will Limerick’s low-level radioactive waste be stored at Peach Bottom:
Until 2029 when Limerick’s license expires?
Until 2049 if NRC approves Limerick’s license renewal?
- Can NRC document total amounts of Limerick’s low-level radioactive wastes shipped to Peach Bottom each year since 2009? If so, please provide those totals. If not, why not?
- Does NRC have written assurances from Exelon that there will be enough space at Peach Bottom to store all Limerick’s low-level radioactive wastes until 2029 when Limerick’s current license expires? If so, please provide evidence of such assurances.
JUSTIFICATION FOR REQUESTED INFORMATION - After Barnwell, South Carolina closed in 2008, we repeatedly questioned NRC about the destination of Limerick Nuclear Plant’s massive amounts of low-level radioactive wastes including:
ü Waste Sludges
ü Filter Elements
ü Contaminated Equipment
ü Plastic Sheeting
ü Spent Demineralizer Resins
ü Evaporator Bottoms
ü Materials Used In Decontamination and Contamination Control
ü Shoe Coverings
ü Wiping Rags
ü Water Treatment Residues
ü Machine Parts
IN 2013, WE FINALLY LEARNED THAT NRC CANNOT ANSWER THE QUESTIONS WE HAD BECAUSE NRC DOES NOT TRACK LLRW VOLUME AND NRC HAS BEEN LAX IN OVERSIGHT.
ACE also asked DEP for an accounting of the destination of all Limerick’s massive low-level radioactive wastes since 2000 when Exelon bought Limerick Nuclear Plant.
- To this day, we never received an accounting. There has been no accountability from DEP or NRC.
DEP also failed to provide an accounting of all low-level radioactive waste amounts and their destinations since 2000, so that ACE could compare amounts before and after the closing of Pottstown Landfill in 2005 and Barnwell, S.C. in 2009.
DEP’S FALSE CLAIM EXPOSED
We are starting to believe no agency is keeping an accurate accounting of Limerick’s low-level radioactive wastes.
- PA DEP’s Title V 12/09 response document claimed all Limerick’s low-level rad-wastes were stored in a special building on Limerick’s site.
- A month later, an article in our local paper said Exelon was requesting permission to send Limerick’s low-level radioactive waste to another Exelon site in PA, Peach Bottom.
- In relation to license renewal, NRC must provide the public with verifiable evidence that NRC has obtained a long-range commitment from Exelon related to the safe destination and storage of all Limerick’s low-level wastes until 2049.
- It is imperative for NRC to track the volume of Limerick’s LLRW and make Exelon accountable for safe storage of Limerick’s low-level radioactive wastes, PRIOR to consideration of Limerick relicensing.
- 3. Since low-level radioactive wastes must be kept away from the public and can only be stored at special destinations, it would be negligent to allow this waste to continue to be produced if there is no safe long-term destination for it
- IT WOULD BE BOTH UNETHICAL AND UNACCEPTABLE FOR NRC TO ALLOW EXELON TO INCINERATE LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES AT OR NEAR LIMERICK. THAT IS NOT AN ACCEPTABLE OPTION IN THIS HEAVILY POPULATED REGION WHERE THERE IS ALREADY A HEALTH CRISIS.
FINANCIAL INJUSTICE OF LIMERICK NUCLEAR PLANT
NRC’S COST-BENEFIT ANALYSIS FOR THE ENVIRONMENTAL IMPACTS AND RELICENSING FAIL TO CONSIDER THE PUBLIC’S COSTS FOR HAVING LIMERICK NUCLEAR PLANT IN OUR REGION.
NRC’S DRAFT EIS FOR LIMERICK NUCLEAR PLANT FAILS TO IDENTIFY, ANALYZE, ACKNOWLEDGE, OR CONSIDER THE ASTRONOMICAL PAST, CURRENT, AND FUTURE LONG-TERM ENVIRONMENTAL AND HEALTH CARE COSTS TO THE PUBLIC RELATED TO LIMERICK NUCLEAR PLANT OPERATIONS.
IN OUR EIS TESTIMONY 10-26-11, ACE REQUESTED THAT NRC CONSIDER ALL COSTS TO THE PUBLIC IN THE COST/BENEFIT ANALYSIS FOR LIMERICK NUCLEAR PLANT’S EIS.
- NRC MADE NO ATTEMPT TO CALCULATE THE COSTS WE IDENTIFED NOR MADE ANY MENTION OF PUBLIC COSTS FOR LIMERICK NUCLEAR PLANT IN NRC’S EIS FOR LIMERICK.
- INSTEAD, NRC PLACED DISPROPORTIONATE VALUE ON EXELON’S COSTS AND CONTRIBUTIONS, WHICH PALE BY COMPARISON TO THE PUBLIC’S COSTS FOR HAVING LIMERICK NUCLEAR PLANT IN OUR REGION.
- EXELON PROFITS, WE PAY!
- EXELON AND THEIR CEO’S PROFIT AND BENEFIT.
- THE PEOPLE IN OUR REGION GET THE HARMS AND PAY THE COSTS.
- LIMERICK’S ELECTRIC GOES TO THE GRID TO BE DISTRIBUTED IN THREE STATES, BUT THE PEOPLE IN OUR REGION WERE FORCED TO PAY THE LIONS’ SHARE OF LIMERICK’S CONSTRUCTION AND DECOMMISSIONING.
WHAT DID LIMERICK NUCLEAR PLANT COST THE REGION’S TAXPAYERS AND RATEPAYERS SINCE 1985?
- LIMERICK NUCLEAR PLANT’S COSTS TO THE PUBLIC HAVE BEEN ASTRONOMICAL, TO BOTH TAXPAYERS AND RATEPAYERS, FAR OUTWEIGHING ALL EXELON’S CLAIMED BENEFITS.
PUBLIC COSTS FOR LIMERICK NUCLEAR PLANT INCLUDE:
- RADIOACTIVE WASTE STORAGE, FOREVER
- HIGHER DRINKING WATER COSTS
- HIGHER HEALTH CARE COSTS
- HIGHER ELECTRIC RATES
EVIDENCE SUGGESTS EXELON OWES THIS COMMUNITY FAR MORE THAN IT DONATES TO OUR REGION’S COMMUNITIES, ORGANIZATIONS, OR POLITICIANS.
NRC fails to make Limerick licensing decisions factoring in true and accurate costs to the public in cost/benefit analyses.
For detailed information on Limerick’s Financial Injustice see www.acereport.org
# 18 “Financial Injustice”
NRC’s “COST-BENEFIT ANALYSES” are an injustice to public interests.
NRC never did a fair and accurate cost/benefit analysis related to Limerick Nuclear Plant.
NRC fails to value the public’s financial interests. Although this is standard operating procedure for NRC, it is clearly unacceptable.
NRC’S SOCIOECONOMIC ANALYSIS WAS A DISGRACEFUL SHAM, ASSERTING ALL HARMS AND COSTS WOULD BE SMALL, WITH NUCLEAR HAVING EQUAL OR LESS HARMS THAN OTHER ALTERNATIVES.
- WHAT ARE THE HEALTH CARE COSTS FOR LIMERICK’S ROUTINE RADIATION RELEASES?
ACE REQUESTED THAT NRC CALCULATE THE COST FOR ALL CANCERS ABOVE THE
NATIONAL AVERAGE AFTER LIMERICK STARTED OPERATING IN 1985. WE ASKED THAT
NRC BASE THE NUMBERS ON THE COST TRACKED FOR JUST ONE CHILD DIAGNOSED
WITH CANCER AT 6 MONTHS TO TWO YEARS OF AGE.
- NRC FAILED TO EVEN RESPOND, MUCH LESS DO THE CALCULATION.
- WHAT ARE THE COSTS FOR ADDITIONAL HOSPITALIZATIONS AND EMERGENCY ROOM VISITS DUE TO ENORMOUS PM-10 EMISSIONS IN LIMERICK’S 44 MILLION GALLONS OF COOLING TOWER STEAM RELEASED EVERY DAY INTO OUR AIR? EVIDENCE IS UNDENIABLE THAT PM-10 INCREASES EMERGENCY ROOM VISITS AND HOSPITALIZATIONS. LIMERICK’S PM-10 CONTAINS MASSIVE AMOUNTS OF CHLORINE, PATHOGENS, AND A HOST OF OTHER TOXIC CORROSIVE CHEMICALS ASSOCIATED WITH A BROAD RANGE OF DISEASES AND DISABILITIES FOR WHICN COSTS ARE ASTRONOMICAL.
- NRC WAS WORRIED ABOUT DAMAGE TO STAINLESS STEEL STRUCTURES AND PARTS AT LIMERICK FROM MASSIVE CHLORINE IN COOLING TOWER STEAM. EXELON ADMITS THE CORROSIVE AIR BLOWS OFF-SITE. VAST NUMBERS OF RESIDENTS HAVE HAD MUCH DAMAGE TO THEIR CARS, OUTDOOR FURNITURE, ETC. WHAT IS THE COST TO THE PUBLIC FOR REPLACING THOSE THINGS?
- WHAT ARE THE HEALTH CARE COSTS RELATED TO LIMERICK’S RADIOACTIVE AND OTHERWISE TOXIC DISCHARGES INTO THE DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE?
- WHAT ARE THE COSTS TO WATER COMPANIES AND THEIR CUSTOMERS FOR THE CONSEQUENCES OF MASSIVE TOTAL DISSOLVED SOLIDS RELEASED FROM LIMERICK AND TOXIC MINE WATER PUMPING?
Limerick Nuclear Plant’s costs to the public add up to one of the biggest corporate welfare schemes ever. Yet, NRC never includes astronomical costs to the public in its cost/benefit analyses for licensing.
PECO/Exelon make enormous profits at Limerick, while the public pays the lion’s share of business costs, far beyond corporate donations, contributions, or taxes.
- Enormous Construction Costs Largely Paid By Ratepayers:
Construction costs for Limerick were $6.8 Billion, largely paid by the region’s ratepayers in their electric bills every month, from 1985 to 2010. By 1997, our electric rate climbed to 55% above the national average. This is an outrage. Limerick’s energy goes to the grid. It goes to several states, but we bear the costs.
- Property and School Taxes Avoided, Then Drastically Reduced:
PECO/Exelon avoided paying property or school taxes on its site from 1985 to 2002. Taxpayers were forced to pick up the tab. In 1999, PECO tried to avoid taxes forever by claiming Limerick was worth zero. A court settlement assigned Exelon a fraction of what they should have paid. Instead of paying its fair share, Exelon pays only $3 million a year when it should have been paying $17 million a year. In essence, from 1985 to 2013 Exelon avoided paying over $400 million dollars in taxes. That’s unethical. Exelon donations to this community pale by comparison.
- Additional Costs For Cancers That Skyrocketed Far Higher Than National Averages After Limerick Started Operating:
What has it cost this region for all the cancers and other illnesses linked to Limerick’s radiation that are alarmingly higher than the national average? NRC was asked to consider that by ACE in 2011, but didn’t. The costs of environmentally linked disease and disability are astronomical and preventable. For example, the costs for one child diagnosed with cancer at six months, and tracked for two years were over $2 million and counting. NRC failed to consider that in this EIS for Limerick.
- Water Contamination:
Limerick’s toxic and radioactive wastewater discharges cost water companies and their customers more. Exelon should filter to protect public health. Limerick discharges massive amounts of toxic and radioactive wastewater into a vital drinking water source for almost two million people. Obviously, this can greatly increase the costs for water treatment companies and their customers, and contribute to incalculable health costs. The costs for Exelon to filter pales by comparison.
- Growing Amounts Of High-level Radioactive Waste Storage Forever:
Tons are produced at Limerick every year, remaining deadly virtually forever. The public cost is in higher taxes to store it at Limerick. It is impossible to know how much it will cost the public, saddled with the storage of Limerick’s high-level radioactive wastes, virtually forever. NRC failed to consider that too. It is appalling that Exelon has received from our government $300 million, with the promise of another $600 million, just to store their own wastes on site. That’s taxpayer money.
Ratepayers are largely funding decommissioning through hidden charges in monthly electric bills to residents in our region. Decommissioning is a big ratepayer rip-off. We will continue to have to pay for Limerick decommissioning each month in hidden electric charges on 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 has an estimated $1 Billion total shortfall, and expects to get $100 Million more from our region in rate hikes for Limerick’s decommissioning.
WHY WOULD NRC BELIEVE EXELON ABOUT ANYTHING?
$1 BILLION SHORTFALL IN EXELON’S DECOMMISSIONING FUND
- NRC caught Exelon shorting its decommissioning fund by $1 BILLION.
- Yet, NRC will likely fail to require Exelon to be accountable.
- NRC will likely allow ratepayers and taxpayers to get stuck with yet another huge bill to make up the shortfall in Exelon’s fund.
- Exelon planned to ask the PA PUC for ratepayers to get increases to pay for the $100 million shortfall for Limerick’s Decommissioning Fund.
EXELON REPEATEDLY DECEIVED NRC ABOUT A BROAD RANGE OF ISSUES. NRC FAILS TO TAKE MEANINGFUL ENFORCEMENT MEASURES FOR EXELON’S DECEPTION, INCLUDING FINANCIAL.
EXELON’S DECEPTION AND REFUSAL TO PAY FOR VITAL NEEDED PREVENTIVE HEALTH AND SAFETY PROTECTIONS CAN HAVE GRAVE CONSEQUENCES TO MILLIONS OF PEOPLE IMPACTED BY LIMERICK NUCLEAR PLANT OPERATIONS.
- TO PREVENT UNNECESSARY HEALTH CARE COSTS AND HIGHER COSTS FOR PUBLIC DRINKING WATER, AS A CONDITION OF RELICENSING, EXELON SHOULD BE REQUIRED TO FILTER ITS DANGEROUS TOXICS DISCHARGES INTO THE VITAL DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE.
- Exelon’s refusal to spend the money to filter the outfall that transports Limerick Nuclear Plant’s dangerous radiation and cooling tower toxics into the vital drinking water source for almost two million people is not acceptable.
- Exelon should be required to filter the massive amounts of toxic mine water it is pumping into a vital drinking water source. Exelon is poisoning the river with toxic mine water for Limerick operations and should be required to filter it.
WIITHOUT QUESTION, FILTRATION WOULD REDUCE TOXIC THREATS TO WATER AND HEALTH AND THE PUBLIC’S ASSOCIATED COSTS, EVERY YEAR LIMERICK OPERATES.
- TO PREVENT THE POTENTIAL FOR AN ESTIMATED TRILLION DOLLAR PUBLIC COST FOR DEVASTATING MELTDOWNS, BEFORE RELICENSING LIMERICK, EXELON SHOULD BE REQUIRED TO FULLY COMPLY WITH THE MOST PROTECTIVE NRC POST-FUKUSHIMA SAFETY RECOMMENDATIONS.
- TO AVOID UNNECESSARY DISASTROUS RADIATION ACCIDENTS AND POTENTIAL MELTDOWNS, BEFORE RELICENSING, EXELON SHOULD BE REQUIRED TO IMMEDIATELY REPLACE AND REPAIR CORRODING, DETERIORATING, AND OTHERWISE AGING LIMERICK SYSTEMS AND STRUCTURES.
- If NRC allows Exelon to delay or avoid replacing or repairing the serious corrosion and aging problems in the fuel pools and elsewhere that NRC staff identified, until after relicensing, Exelon may never fix them eventually resulting in millions of people losing everything and becoming nuclear refugees with little, if any, help from the government.
- Costs for NRC not requiring Exelon to take immediate action to replace and repair all corroding and deteriorating systems and equipment to prevent a large radiation release or even multiple meltdowns could be incalculable. Costs would include health care, temporary and permanent relocation, clean-up, etc.
NRC OFFICIALS MUST NOT ALLOW EXELON TO AVOID COSTS FOR DELAYING OR AVOIDING COMPLETELY NRC STAFF-RECOMMENDED POST-FUKUSHIMA SAFEGUARDS AND PROTECTIVE REPLACEMENT AND REPAIRS FOR PROBLEMS IDENTIFIED BY NRC STAFF IN SAFETY EVALUATIONS FOR LIMERICK. IF LIMERICK HAS AN ACCIDENT OR MELTDOWN, THOSE OFFICIALS ARE ETHICALLY RESPONSIBLE FOR A CATASTROPHE AND SHOULD BE HELD LEGALLY RESPONSIBLE.
THE COSTS FOR NO FILTRATION WILL FAR OUTWEIGH COSTS TO EXELON FOR PRECAUTION AND PREVENTION. NRC OFFICIALS WHO HAVE NO COURAGE OR CARING FOR THE VICTIMS OF LIMERICK’S UNPRECEDENTED THREATS TO DRINKING WATER AND WHO FAIL TO REQUIRE FILTRATION TO PREVENT UNNCESSARY HEALTH THREATS AND COSTS TO THE PUBLIC ARE ALSO RESPONSIBLE FOR THE INEVITABLE OUTCOME.