NRC Whitewash of Limerick Nuclear Plant Environmental Impacts Will Allow Continued Harms to the Philadelphia Region

 NRC’s DRAFT of Limerick’s Environmental Impact statement must be rejected by residents and elected officials, and Limerick must close to protect the entire Philadelphia Region. Read all four parts in this video blog series to understand what is at stake, and then take action on the four things you can do to help.






NRC’s whitewash of threats and harms caused by Limerick will result in a continuing assault on the environment and the health, safety, and financial interests of millions of people in the Greater Philadelphia Region.

NRC’s DRAFT Environmental Impact Statement (EIS of April 2013 did not acknowledge Limerick’s documented threats and harms that were submitted for Limerick’s EIS public hearing record by ACE In October, 2011.

NRC’s mission is to protect public health and safety related to Limerick Nuclear Plant operations. but NRC is only protecting Exelon’s profits and NRC’s jobs.

NRC ignored documented evidence proving harms are enormous, not small, as claimed by NRC. ACE provided NRC with a vast body of evidence 11-26-11, proving Limerick presents unprecedented harms and threats to our region, but NRC requirements are written in such a way that they can avoid full disclosure of Limerick’s harms from radiation exposure to the public.

NRC inaccurately and illogically claims that Limerick’s environmental harms are small. NRC’s “standard of significance” for impacts is woefully deficient and unprotective of the public. However, NRC’s claim is baseless. NRC did no independent monitoring or testing for Limerick’s DRAFT EIS. Exelon, the company with a vested interest in the outcome that has shown it can’t be trusted, supplied all the monitoring, testing, estimating, calculating, and reporting for NRC’s DRAFT EIS conclusions. This is unacceptable!

NRC’s EIS absurdly claims that Limerick’s environmental harms are no greater than solar or wind energy. The fact is, Limerick poisons our entire life support system with invisible radiation releases and other toxic chemicals, when solar or wind do not. Wind and solar do not leave deadly wastes that can continue to threaten our environment and health for many generations to come.

Public citizens joined ACE in presenting testimony at NRC’s 5-24-13 public hearing in opposition to Limerick’s outrageous Environmental Impact Statement. Summary comments from ACE officers and others on the major issues can be found in previous ACE blogs on this website.

ACE’s 90-page written testimony was submitted 6-24-13, reiterating detailed documentation of Limerick’s enormous environmental harms. This evidence shows why NRC is guilty of regulatory malpractice related to Limerick Nuclear Plant. To review details call (610) 326-2387.

NRC’s reckless decisions are abandoning public interests, especially in light of the Fukushima catastrophe. Our Congressmen have the power of oversight of the Nuclear Regulatory Commission.

Limerick can’t operate without further jeopardizing public health, safety, and financial interests. NRC has shown little interest in protecting public health and safety. Therefore, ACE has requested a Congressional hearing.

Limerick’s DRAFT EIS must be rejected and Limerick must close.

Congress should demand that NRC require Exelon to immediately take actions to reduce and/or eliminate all Limerick’s enormous threats, regardless of costs to Exelon. The public’s ultimate costs for Exelon and NRC delay tactics and avoidance of risk reduction could be astronomical.

The 7-19-13 Pottstown Mercury article by Evan Brandt, “Limerick Nuke Plant Among Those At Risk For Early Closure” show that Limerick could close early due to economics. But, we believe Limerick should close early due to its enormous radioactive and other toxic threats and harms to our air, water, soil, and children.

The following video blogs in this series support our conclusion:

Video Blog – Part 2 Limerick’s Unprecedented Threats and Harms to Water
Video Blog – Part 3 Limerick’s Major Air Pollution Issues
Video Blog – Part 4 Limerick’s Radiation Links to the Region’s Skyrocketing Cancer Rates




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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Our community deserves nothing less.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Our community deserves nothing less.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

NRC’s offensive EIS whitewash must be rejected.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

I support the recommendations of ACE.

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

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

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

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

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

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

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

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

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

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

I support ACE recommendations.

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

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

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

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

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

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

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

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

I say, “Beware of utilities bearing gifts”!

I support Ace’s recommendations.

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

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

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

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

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

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

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

I support ACE’s recommendations.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

• Limerick regulations are not accounting for risk and threat

• I OPPOSE Limerick Relicensing.

• Limerick is a regional and national issue

• NRC should suspend all reviews or relicensing after Fukushima.

• Limerick is similar to reactors at Fukushima that exploded.

• NRC has a conveyer belt process.

• Failing to consider environmental impacts at Fukushima

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

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

• NRC weakened regulations

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

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

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

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

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

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

• Limerick has safety deficits

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

• NRC assumptions are not on the side of safety

• NRC conclusions should not be accepted by anyone.

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

• 100% vents failed in reactors similar to Limerick

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

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

• Relicensing process should not be happening

• NRC relies on state for radiation monitoring – Investigation

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

ACE Blog 8 Tell NRC and Elected Officials Until Limerick Closes, Changes Must be Made to the Evacuation Plan

ACE Video / Blog Part 8
April, 2013


• Establish INDEPENDENT radiation monitoring so the public can be informed immediately when Limerick has a higher than usual radiation release.
• Independent Regional Radiation Monitoring and Reporting Program For Limerick Nuclear Plant Radiation Releases, With Continuous Radiation Data Posted In Real Time On County Emergency Management Websites.
• Immediate Notification to the public of radiation levels exceeding background levels for more than one hour. Public notification should be made through the emergency broadcast system plus recorded notification message to telephones.
• Provide an immediate electronic public alert system for higher than usual radiation releases.

• Demand that Limerick’s evacuation zone be expanded to 50 miles, to better protect the health and financial interests of millions of people.
• Fukushima made it clear that high levels of radiation travel far more than 10 miles.
• U.S. citizens in Japan were advised to evacuate 50 miles from Fukushima.

• Demand that Limerick’s ingestion pathway zone be expanded to 100 miles, to reduce radiation exposure to millions from radioactive food, water, and soil.
• Dangerous levels of radiation have been detected over 160 miles from Fukushima in water, soil, and food.
• Radioactive water and food cannot safely be consumed. Limiting use of radioactive food and water can minimize unnecessary risk of cancer and other diseases and disabilities .



• Fukushima revealed that multiple meltdowns could occur at Limerick Nuclear Plant too. With reactors and fuel pools like those that exploded at Fukushima, Limerick could release large amounts of radiation.

• It only takes loss of power and cooling water. Loss of power and water could be triggered by earthquakes, other natural disasters, cyber attacks, human error, terrorist attacks with planes or missiles, a host of safety and age-related structure and parts problems, mechanical breakdown, corrosion and aging of miles of buried pipes carrying highly radioactive, corrosive, and heated fluids.


Evidence from Fukushima and Chernobyl show the Radioactive Plume from Limerick Meltdowns would travel far beyond the arbitrary 10-Mile Evacuation Zone. Hundreds of thousands of our children would be transported to radioactive locations just outside the 10 miles.

• Radiation can start escaping off-site within 1/2 hour of a Limerick accident. Yet, Exelon is not required to immediately notify the public. History shows NRC waited days or weeks to notify the public. History shows the truth about the amount and kinds of radiation released will not be fully disclosed to the public until days or weeks later, if ever.

• In a severe Limerick radiation release, moving away from the plume as quickly as possible is imperative to limit radiation exposure and threats to health. Remaining in traffic far too long while exposed to Limerick’s radioactive plume can result in radiation sickness short term. Long-term it can result in increased cancers and many other diseases and disabilities.

• Massive populations on crowded roads, with bottlenecks and accidents, would create widespread chaos, anxiety, and fear. Normal Route 422 Traffic Jams Speak Volumes.

• NRC and elected officials knew In 1980, before Limerick construction was completed, that we had double the population density that could evacuate safely. Since then, population increased over 100%. Just as today, NO agency or elected official spoke out to protect public health, safety, and financial interests.

• FINANCIAL INJUSTICE. Millions of people in the Greater Philadelphia Region could become nuclear refugees losing their health, homes, businesses, and all their possessions. Over 8 million people live within 50 miles of Limerick Nuclear Plant.

• People cannot expect to be compensated for loss of personal property, including homes that would become permanently uninhabitable and businesses that would be unusable. In fact, industry and government could be expected to minimize all compensation costs for evacuated victims and would resist evacuating other victims outside the 10-mile zone to avoid costs. Victims outside the 10-mile evacuation zone wouldn’t even be compensated for temporary housing, even though they would still be in the dangerous radioactive plume.

• It is unclear which agencies are responsible for every aspect of a Limerick radiation accident / meltdown. NRC is already trying to claim no responsibility for off-site radiation. In Japan, the nuclear company claimed they had no responsibility for off-site clean-up.
The ACE Video-Blog Series Should Serve As A Wake-Up Call To Millions In The Greater Philadelphia Region, Related To Limerick Nuclear Plant’s Negligent Emergency and Evacuation Planning.

• This series identifies problems and flaws with Limerick’s Emergency and Evacuation plans.
• It provides evidence of NRC’s historical and current failures and corruption in policies and decision making that compromise and further jeopardize millions of people whose lives could be harmed or ruined permanently as the result of a Limerick Nuclear Plant Radioactive Accident and/or Meltdown.
• It reveals how NRC is refusing to make changes to evacuation planning that could actually reduce radiation exposures to millions in a radiation accident and/or meltdown.
• It reveals why our elected officials must demand a system for immediate independent public notification of a Limerick accidental radioactive release, and demand expanded evacuation and ingestion pathway zones.

The Alliance For A Clean Environment
January to April, 2013

Part 1 – Reveals NRC’s Pared Down Emergency and Evacuation Plans Even After Lessons From Fukushima

Part 2 – Supports the Need for Immediate Notification And Expanded Evacuation and Ingestion Pathway

Part 3 – Reveals The Truth and Consequences of Radiation Exposure From Nuclear Plant Accidents or

Part 4 – Reveals What Really Happened After Fukushima, Chernobyl, and TMI Meltdowns

Part 5 – Reveals The Financial Injustice To The Public From A Radiation Accident / Meltdown

Parts 6 and 7 – Reveal Fatal Flaws In Emergency – Evacuation Plans for Limerick Nuclear Power Plant

Part 8 – Identifies What Must Be Done to Minimize Radiation Risks From A Limerick Radiation Accident
or Meltdown

The Purpose Of This Series Is Minimizing Chaos And Reducing Radiation Exposure By Improving Limerick Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.




ACE Video Blog 7 Analysis of Exelon’s Evacuation time Estimate (ETE) for Limerick

ACE Video/Blog – Part 7
April, 2013

Exelon’s Evacuation Time Estimate (ETE) For Limerick Nuclear Plant’s Plume Exposure Pathway Emergency Planning

ACE requested a copy of Exelon’s most recent 12/12 “Evacuation Time Estimate” (ETE), hoping to find ways to improve on unprotective evacuation plans for Limerick Nuclear Plant. Unfortunately, after careful review of Exelon’s ETE, we are more concerned than ever. This report confirms that safe and timely evacuation is an illusion.

This plan will result in extended radiation exposures, further jeopardizing health and safety for millions in the Greater Philadelphia Region, in the event of a Limerick Nuclear Plant radiation accident / meltdown.

Exelon’s ETE is self-serving fiction based on unrealistic, unworkable suppositions, assumptions, inconsistencies, and inaccuracies, with fact-free spin and illogical conclusions. Exelon’s letter accompanying its ETE concludes with: “There are no commitments in this letter”. That disclaimer speaks volumes.

Exelon’s ETE is a logistic fantasy that is clearly not either realistic or feasible. NRC officials for Limerick had not even evaluated Exelon’s ETE as of the NRC meeting 3-21-13. Any elected official in the region who reviews Exelon’s ETE objectively, should be alarmed. Exelon’s 12/12 ETE should be rejected by elected officials and NRC.

Elected and agency officials knew in 1980 that the population density around Limerick made safe evacuation impossible. They should have stopped Limerick construction. Since 1980, the region’s population soared, making an impossible situation far worse. It’s long past time for elected officials and NRC to protect the public’s health and financial interests, instead of Exelon’s profits.

Based on the impossibility of safe evacuation, NRC can and must shut Limerick down before it melts down.

More Than 65,000 Children In Limerick’s 10-Mile Evacuation Zone (Attending Over 230 Schools and Day-Cares) Could Be Transported To Reception Centers Just Outside Limerick’s 10-Mile Evacuation Zone.
Reception Centers Would Likely Still Be In Limerick’s Radioactive Plume.



• Based on evidence from Fukushima and Chernobyl meltdowns, Limerick Nuclear Plant’s 10-mile evacuation zone must be increased to at least 50 miles to keep vast numbers of children from unnecessary radiation exposure and the many health harms, including cancers, that would result from a Limerick Nuclear Plant radioactive accident / meltdown.

• Exelon’s ETE for Limerick, Unnecessarily Exposes Far Too Many Children To Limerick’s Radioactive Plume For Far Too Long. Reception centers are not far enough outside the 10 mile EPA. Most would still be in Limerick’s radioactive plume. Many mass care centers planned for Limerick evacuees could also still be impacted by Limerick’s radiation.
Evidence from Chernobyl and Fukushima meltdowns prove evacuating children just beyond 10 miles is negligent. NRC evacuated U.S. citizens that were within 50 miles of the Fukushima meltdowns.
­Children far outside Fukushima’s 12-mile evacuation zone experienced radiation sickness symptoms.
­Children over 40 miles away have radiation in their bodies at doses 20 times above recommended safety limits. Vast numbers of Chernobyl children, far distances from the meltdown, experienced devastating diseases and disabilities, especially leukemia, other cancers, and heart problems. See ACE Blog #4 about what really happened at Fukushima and Chernobyl

• Exelon’s ETE plus ACE’s school mapping of Limerick’s 10-mile evacuation zone show there are over 230 schools, pre-schools, and day-care centers. It is difficult to account for all public and private pre-schools, day-cares, and schools. Most day-cares and pre-schools have no emergency plans.

• Some school districts straddle the 10-mile EPZ radius. That creates a different set of problems.
­For example, parents of Methacton School District students believe that all of the school district is in the evacuation plan because all schools in the district are included on Exelon’s mailed evacuation brochure. However, Exelon’s ETE, which most parents won’t see, places Methacton High School outside Limerick’s evacuation zone. This causes confusion for school district officials, parents, teachers, and students.



• Over 65,000 children would need to be evacuated.
• All children are assumed to be evacuated from all schools simultaneously. However, in reality, there are not enough school buses or certified drivers to evacuate all children from all schools simultaneously.
• We can only conclude that thousands of children would be left behind. Currently, many school busses make two separate trips every day – 1 trip for Elementary and 1 trip for Secondary Schools Within Districts. This fact is not addressed in Exelon’s ETE. Currently, public school districts are also responsible for bussing private school students. This factor is also not addressed. Complicating the problem, many bus drivers admit they wouldn’t return for a second trip.


1,388 CHARTED BY SPECIFIC SCHOOLS (Pages 6-18 to 6-22)

• NO buses or drivers are planned for the schools and day-cares missed by Exelon’s ETE.
• Availability of certified licensed school bus drivers assumed in Exelon’s ETE is questionable at best.
• Assumed vehicle availability along with perfectly modeled traffic patterns make this ETE unworkable to protect children in a Limerick radiation accident / meltdown.
• Residential students from the Hill School and Ursinus College (possibly well over 1,000) are not even included in Exelon’s Time Estimate.


­ Page 6-17 Itemized Total 1,706 Vehicles Needed For Hospitals, Nursing Homes, Retirement Communities and Other Special Facilities
­ Page 1-9 Their narrative total for the current study shows 442 vehicles needed


(To Assume That Such A Large Number Would Be Available Simultaneously Defies Logic.)



 Pottstown Hospital – ETE Lists 332 Ambulances / Vans Needed
 Phoenixville Hospital – 82 Ambulances and Vans

Pottstown Hospital Is Within 1 Mile Of Limerick. Phoenixville Hospital Is Also Within The 10-Mile Zone. Both Would Need To Be Evacuated Immediately.
Exelon’s ETE says 332 Ambulances / Vans would be available for Pottstown Hospital, and 82 would be available for Phoenixville Hospital.
­ Where would all these Ambulances / Vans, and Drivers come from to evacuate simultaneously?
­ There is no medical reception center specified in Exelon’s ETE to accommodate large numbers of patients requiring specialized care. Where would so many patients from several hospitals and nursing homes be evacuated to?
­ Some patients could become highly radioactive during an extended evacuation and be rejected by hospitals or other facilities, as the radioactive people were in Japan.

 Montgomery County Rehabilitation Center – 330 Ambulances and Vans
 Veterans Center – 146 Ambulances and Vans


Montgomery County Prison – 100 Vans and Buses (1,200 Inmates)
­ Where will all these prisoners go? There is no destination designated for these prisoners.

Graterford Prison Would NOT Be Evacuated. Instead Graterford Prisoners And Guards Are Supposed To Shelter In Place.
­ There is no mention of what will happen with guards and other prison employees.
­ How will prisoners sustain themselves if all employees evacuate?

Exelon’s ETE States 1,706 Ambulances and Vans Would Be Available Simultaneously To Evacuate In A Timely Manner.

To assert that 1,706 ambulances and vans would be available simultaneously is beyond irresponsible.



Exelon’s ETE drastically underestimated people without cars in places like Pottstown, Royersford, and Collegeville.

• Exelon’s ETE Listed Only 4500 People (.015% of 292,061 Population) As Transit Dependent Population Determined To Be Within Limerick’s 10 Mile Evacuation Zone By Exelon’s Report (Section 5.3 on Page 5-3)
­4,500 is .015% of the estimated 292,061 population, a gross understatement of what could be a significant need.
­ Exelon’s report unbelievably suggests that 99.985% of people in Limerick’s 10-mile evacuation zone would have access to vehicles to evacuate.
­ Exelon’s ETE requires 150 Bus Trips To Evacuate People With No Transportation (Page 1-9).
 ACE CONCLUSION: This defies logic!

• The ETE required residents to call township, borough, or local officials to find out schedule of pick up points.
­ People who work for boroughs and townships are likely to want to evacuate immediately with their families, not man phones.
­ PROBLEM: The list of municipal pick-up points that are in Exelon’s mailed brochure for Montgomery County are all in Pottstown. What happens to people in Royersford and Collegeville? If they have no transportation, how do they get to Pottstown?
­ If the radiation accident / meltdown occurs from a natural disaster like an earthquake, contacting officials could become impossible because of loss of power.


• Telephone Survey On Residential Vehicles Available For Evacuation (Appendix B – Pages 1-7)
­ The sample was too small to make valid conclusions.
 Only .001 % of residents responded.
 Only 317 responses were analyzed out of 292,000 total households.
 Approximately 64% of the 317 were 55 years old or older.

- Survey Questions Failed To Accurately Identify Residential Vehicle Needs
 Survey questions were centered on who in the family is working, how many vehicles they have, how long it would take to get to work and home, and what shift people worked.
 ETE surveyors should have asked if that resident would have another vehicle available if other family members didn’t come home.
 Questions were omitted concerning household vehicles used by workers who were teachers or healthcare workers required to stay with students or patients by Exelon’s ETE.
 Teachers would go to host center with students. Health care workers are expected to stay with patients or shelter in place.
 Prison workers would be required to evacuate with prisoners or shelter in place with them.


• Blinking Lights – (Page 4-2)
Exelon’s ETE Requires Manual Override of Traffic Lights by Undesignated Officials, supposedly to alleviate bottleneck points. In reality, under emergency conditions, a blinking signal would not alleviate congestion, but instead contribute to confusion, increased congestion, and accidents.


• Traffic Congestion – (Page E-3)
The ETE fails to assume worst case scenarios where traffic is stopped all together by adverse weather conditions or traffic accidents. At the most it assumes that the worst case scenario would add only 160 minutes due to adverse winter weather.

• Traffic Estimates for Employees of Many Businesses Were Excluded From Total Vehicle Estimates (Appendix A, Page 6 of 13)
­ For example: Under the list of major employers, many businesses which contribute to traffic congestion are excluded, including diners, restaurants, convenience stores.
­ Examples: Costco, Wawa and Turkey Hill Convenience Stores, Gas Stations, Banks, Car Dealers, Movie Theaters, Restaurants, Library
­ Numbers of vehicles from these businesses would clearly affect roadway congestion and traffic patterns during evacuation.

• Recreation and Shopping (Appendix A Page 8 of 13)
­ Estimates for numbers of people at shopping centers appear to be substantially underestimated.
­ Some parks have been overlooked. For example, Manatawny Park, Riverfront Park in Pottstown, Manderach Park in Limerick, and other local parks.

• Train Traffic – Possible Complications Not Addressed
­ There seem to be NO specific plans addressing train traffic for some of which carries hazardous materials, that goes through the Limerick site.
­ Would train traffic be stopped to facilitate evacuation?

Problems Created By Exelon’s ETE Faulty Assumptions:

• The worst problem of all is that this report places little priority on limiting radiation exposure to evacuees.
• Exelon’s ETE covers a 16-hour evacuation period (Appendix D – Maps of Average Speed by Hour for Road Network Pages 1-16.
• Each hour of exposure to Limerick’s radiation during an accident / meltdown critically impacts the health of residents, especially fetuses and children.

• Exelon’s ETE is a shameless sham that satisfies a regulatory requirement with little regard for reality. Exelon’s ETE includes 100 pages of filler devoted to the unrealistic expectation that its assigned speed limits will be maintained during evacuation on the roads listed and that volumes of traffic will not be exceeded. (Appendix C – Roadway Network Data Table – Pages 1 to 100)

• Exelon’s ETE allows too much time to elapse between public notification and actual evacuation.
­This is about radiation exposure. Yet, initial notification could bypass residents until a response work force is brought in. People living near Limerick would be exposed to radiation the whole time, as long as that takes. (Section 5.2 – Page 5-3) The ETE time lapse warning process means the last 10% to 20% of the population learns too late that an evacuation order has been given.

• Time estimates are based on Exelon’s self-serving proposition that there will be no deviations from the plan. Survival instincts will compel people to flee in ways not anticipated in this ETE.

• Exelon assumes school, hospital, and other employees are going to abandon their loved ones to get on buses and ambulances and follow this plan to the letter. Exelon requires people to abandon their natural instincts to care for their families.

ACE Conclusions:

Exelon’s Self-Serving ETE Is Unworkable, Unprotective, and Irresponsible.

Exelon’s ETE confirms that Exelon still has no plan to safely evacuate the millions of people surrounding Limerick Nuclear Plant.

Exelon hasn’t produced an evacuation plan that ensures safe, timely evacuation from within 10 miles of Limerick Nuclear Plant.

Therefore, it is impossible to produce a plan for a 50-mile evacuation zone, which Fukushima has proven is minimally necessary to protect public health and safety..

To prevent unnecessary environmental devastation and health harm for millions, Limerick Nuclear Plant should close as soon as possible to prevent such a catastrophe from happening in the first place.

To Better Understand What We Could Face After A Limerick Radiation Accident / Meltdown, See ACE Video Blog At – Part 4, For The Truth About Consequences Of Chernobyl and Fukushima Meltdowns.

Major Problems With Limerick’s Current Evacuation Plan:

1. A broad range of extremely dangerous radionuclides would be released in the radiation plume from a Limerick accident/meltdown. Yet, Exelon’s ETE is not based on radiation exposure risk. Emergency workers are not required to practice for a radiological event. This ETE shows why vast numbers of people would be harmed, why Limerick must close to prevent this unnecessary risk, and why even after Limerick is closed we must have truly effective evacuation plans.

2. NRC Should Require Exelon To Notify The Public Immediately In The Event Of A Limerick Nuclear Accident / Meltdown. Radiation Releases Could Start Within The First 1/2 Hour.
• PROBLEM: Radiation is invisible. You can’t smell it, taste it , feel it, or see it.
• NRC should not allow Exelon to wait hours or days. It took 3 days before officials told people to evacuate after TMI.
• Radiation sickness symptoms that would occur within 1 to 24 hours would mimic flu-like symptoms (nausea, vomiting, diarrhea, headache, fever). People wouldn’t realize it was from radiation exposure.
• Exelon’s track record suggests the public won’t be notified until Exelon can no longer hide the accident and can manipulate the messaging. For example, Exelon waited 23 days to notify the public about the 3-19-12 radioactive spill into the drinking water for almost 2 million people from Limerick to Philadelphia.
• Likely, there wouldn’t be an explosion. Increasing radiation could be pouring into our air and water, poisoning us and our life support systems, and go undetected by us. Radiation is invisible and odorless. We can’t see, smell, taste, or feel radiation.
• Radiation exposure symptoms within 1 to 4 weeks could also mistaken for other problems (dizziness, disorientation, weakness, fatigue, bloody vomit and stools, infections, poor wound healing, low blood pressure, and hair loss).
• Long-term radiation damage, such as tumors and cancer, could take years to develop.
• To minimize disaster, immediate evacuation is imperative and the public must heed the first warnings. This statement was made after Fukushima by Michael Chertoff, previous Homeland Security director.

3. Evidence proves Limerick Nuclear Plant’s radiation plume would travel far beyond our current 10-mile evacuation zone, yet:
• NRC is inexplicable and negligently refusing to expand Limerick’s evacuation zone to 50 miles as they did for U.S. citizens in Japan after Fukushima meltdowns.
• NRC is also refusing to expand our ingestion pathway zone from 50 to 100 miles, even though soil, food, water, buildings, animals, and people have documented to be radioactive far beyond 50 miles in Japan.

4. Evidence from actual meltdowns shows most people would be evacuating to centers inside highly radioactive areas, even though they go outside the 10 mile evacuation zone from Limerick.
• Children are the most impacted victims, far more vulnerable to impacts of radiation than adults.
• Children should be moved as far as possible, at least 50 miles away from Limerick in a radiation accident / meltdown.

5. A massive population would be trying to move on over-crowded roads where there would likely be bottlenecks and accidents that would extend the time people are forced to be exposed to Limerick’s radioactive plume,
• There would be widespread chaos, fear, and anxiety.
• Bus Drivers, first responders, and police would face enormous challenges as they attempt to manage and control certain chaos and gridlock on virtually every road in the region.

ACE talked to vast numbers of people in the community. Below are concerns expressed by some of them.
Many people do not realize what would be expected of them.

For example, ACE found most people would expect to evacuate with their families. However, workers at many institutions will be expected to remain behind to care for children, the elderly, prisoners, or patients.
• Health care staff would be expected to remain at their facilities to assist in the care and supervision of patients.
• Teachers would be expected to travel with their children to the locations just outside the 10-mile zone – likely still in the radioactive plume.
• Some prison workers would be expected to shelter in place with the prisoners.
• Municipal office workers in the heavily populated towns (where many people have no cars, like Pottstown, Royersford, Phoenixville, etc.) would be expected to remain in the building for hours, taking calls directing people to locations to wait for buses to evacuate them. Buses likely won’t even come for many.
• Pre-school workers would be expected to remain with the children until parents get there to pick up their children. That could take hours or may be impossible due to chaos.

Assumptions that just won’t work in reality:

• By the time people are notified, they will already have been exposed to radiation releases. Radiation can start escaping in the first 1/2 hour after an accident, but Exelon is not required, and likely won’t, immediately notify the public. People remained unnecessarily exposed far too long before being told to evacuate from Chernobyl and Fukushima.
• Hospitals would be unprepared and unable to treat so many victims of radiation sickness. Some victims could become so radioactive they would be turned away from hospitals and emergency care facilities outside the evacuation zone, as happened in Japan.
• Evacuation plans for schools assume parents will not rush to pick up their children. That just isn’t realistic. Most parents say that is just what they will do.
• Some school plans are contradictory. One school sent home a letter stating parents couldn’t pick up their children, but also told parents where to wait when picking them up.
• Most school bus drivers say that even if they could transport their first load of children to reception centers, they wouldn’t and couldn’t come back for the second.
• Emergency responders may be out in radioactive plumes for hours.
• There are not enough qualified drivers for school buses, ambulances, and other emergency vehicles, even if there were enough vehicles (which there are not).
• There are conflicts of roles for police officers, bus drivers, and first responders. They face challenges of whether to save themselves and their families or stay and save others. This becomes most difficult with a nuclear accident spewing radiation into the air.








ACE Video Blog 6 Historic Fatal Flaws in Limerick Nuclear Plant’s Emergency/Evacuation Plans

ACE Video/Blog – Part 6
April, 2013

Safe Evacuation Was IMPOSSIBLE In 1980, Before Limerick Construction Was Completed!

 In 1980, Population Density Around Limerick Was Already DOUBLE The Number NRC Deemed Safe For Evacuation.
• After the 1979 partial TMI meltdown, NRC’s population criteria were determined for safe evacuation from a meltdown: 500 Persons Per Square Mile In A 30-Mile Radius of a Nuclear Plant Site.
• In 1980, Population Around Limerick Was Double That Density.
Since 1980, Population Around Limerick INCREASED Over 100%.
• Clearly, Safe Evacuation Is Merely An Illusion. We Can’t Evacuate Safely Now With 100% Population Increase From 1980. Limerick Nuclear Plant Should Have Been Scrapped In 1980,Like Shoram Nuclear Plant In New York

Neither Shoram Nor Limerick Nuclear Plant Could Be Evacuated Safety In 1980, Prior To Completion Of Construction. Shoram Was Scrapped, Limerick Was Completed. Why?
New York Elected Officials Valued Public Health And Safety Enough To Take Action.
Elected Officials In PA Did Not!

• 1983 (FEBRUARY): Resolution Passed Declaring Shoram Evacuation Plan Deficient: Suffolk County Legislature Passed A Resolution By A 15-1 Vote That Asserted That The County Could Not Be Safely Evacuated.
• 1989: Shoram Nuclear Plant: SCRAPPED BECAUSE Of EVACUATION PLANS. Governor Cuomo Ordered State Officials Not To Approve Any LILCO(owner)-Sponsored Evacuation Plan. State and local officials knew there was NO WAY to SAFELY EVAUCATE In Case Of An Emergency.

With 100% Population Increase And Growing Risk Of Meltdowns At Limerick
Elected Officials In PA Should Get Limerick Shut Down Due To Impossibility Of Safe Evacuation, Before It Melts Down

1980 Pottstown Mercury News Provides Insight Into Limerick Nuclear Plant’s Evacuation Plan

Pottstown Mercury, May 28,1980
Held By The House Subcommittee On Energy And The Environment

• 1980 – PECO Vice President Vincent S. Boyer Said, “Emergencies That Require Evacuation Will Not Occur.”
ACE Comment: He ignored the 1979 TMI partial meltdown with a dangerously delayed evacuation, that just happened in PA, not far from Limerick. Since then there was Chernobyl and Fukushima.

• 1980 – Boyer drew hisses and boos from the audience during a heated debate with the panel of four Congressmen.
ACE Comment: Our region’s residents recognized PECO deception in 1980.

• 1980 – Boyer claimed safety features at the Limerick Plant would not allow the escape of deadly radiation even if an accident did occur.
ACE Comment: Facts suggest even more deadly radiation would be released from a Limerick accident / meltdown due to Limerick’s substandard containment.
• 1980 – NRC Director Harold Denton said that prior to the mid-1970s, the NRC had no population criteria for nuclear plants. “Before Three Mile Island (1979 – 1 year earlier) if a plant met certain specifications, it was approved.” Denton said the NRC wanted only 500 persons per square mile in a 30-mile radius of the site. He said, “Limerick has about double that density today” (1980)
ACE Comments:
­ NRC expected that people within 30 miles would be harmed, yet today we have only an unprotective 10-mile evacuation radius.
­ In 1980 Limerick was surrounded by double the population density that NRC found acceptable for evacuation within 30 miles. With the drastic population increases around Limerick in the past 32 years, the population is far too dense for safe evacuation today.
• 1980 – Denton admitted that under the (population) standards in place …being applied to nuclear plants being planned (1980), the Limerick site would never be approved (in 1980).
ACE Comment: NRC knew in 1980 that it was not possible to evacuate safely around Limerick, yet NRC allowed Limerick’s construction to go forward.
• 1980 – Denton said special evacuation preparations must be made for … Pottstown Memorial Medical Center and the State Correctional Institution at Graterford.
ACE Comments:
­ More than 30 years later there still isn’t a realistic viable evacuation plan for either.
­ 2013 Evacuation Plans for Pottstown Hospital list an extraordinary number of ambulances that do not appear to exist. Even if vehicles could be found, it is unlikely there would enough qualified drivers.
­ The Phoenixville Hospital, not far from the Pottstown Hospital, also lists large numbers of ambulances and other vehicles. Unrealistic!
­ 2013 Evacuation Preparations for the prison do not exist – the plan is now to simply shelter in place, regardless of the radioactive threats. What about radioactive threats to all of the employees needed to operate the prison?
• 1980 – Congressional Subcommittee Chairman, Peter Kostmayer (D-Bucks County), said Evacuation plans should be required before the Limerick plant is licensed for operation.
ACE Comment: Now, over 30 years later, evacuation plans have been pared down, even though NRC is planning to relicense Limerick, a dangerous aging plant with increasing risks of meltdowns.
• 1980 – Congressional Subcommittee Member, Ed Markey (D-Mass.) said “Economic pressures have limited PE’s concern for safety.”
ACE Comment: Today, over 30 years later, pressures from the industry and regulators have further decreased concerns for safety related to emergency planning and evacuation.
• 1980 – Congressional Subcommittee Member, John Cavanaugh (D-NEB) accused Boyer (PECO) of having “A lack of concern for public fears and concerns”
ACE Comment: Today, Exelon and NRC not only have a lack of concern, they deny actual evidence from meltdowns that occurred both at Chernobyl (1986) and Fukushima (2011).
• 1980 – Dr. Judith H. Johnsrud, Coalition on Nuclear Power, said, “Evacuating the Philadelphia Metropolitan Area would be impossible. The area’s dense population is one reason the nuclear plant should be scrapped.”
ACE Comment: Evacuating the Greater Philadelphia Region safely today is clearly impossible, given the drastic increases in population over the past 32 years. NRC knew Limerick should not have been licensed due to impossibility of safe evacuation. Now the impossibility of safe evacuation should stop Limerick relicensing in its tracks.
• 1980 – Federal, state and county officials said there is no detailed evacuation plan for the Limerick Plant, which is within 10 miles of 195,000 people and within 30 miles of 4 million people.
ACE Comments:
­ Today, over 30 years later, there is still no detailed evacuation plan that could avoid chaos and minimize radiation risk.
­ 293,000 people are now within 10 miles (2010 Population Data –
Nearly 100,000 more people since 1980
­ Over 8 Million people are now within 50 miles (2010 Population Data –
Since 1980, Millions more people live within 50 miles.
• 1980 – Not even one witness could explain how an evacuation could be carried out.
ACE Comment: In 2013, no one can still explain how the evacuation plan could be carried out.
• 1980 – Boyer from PECO offered advice to any Pottstown Area Resident who hears of a Limerick Nuclear accident: “Stay home, your house is a good shield. Cellars are the best place to go.”
ACE Comments:
­ Moving as far away from Limerick’s radiation, as fast as possible is the most protective choice.
­ While staying home is preferable to sitting in traffic under Limerick’s radioactive plume in the short-term, it is imperative to evacuate as soon as safely possible.
­ Staying home is not a safe long-term solution. Everything becomes radioactive, drastically increasing short and long-term health impacts..


In 1980, PECO Vice President Vincent S. Boyer Testified During Limerick’s Hearing, Stating,
“Emergencies That Require Evacuation Will NOT Occur.”

Shame On PECO’s VP! One Already Had Happened 1 Year Earlier! The Three Mile Island Partial Meltdown March 28, 1979, Required Evacuation Right Here In Pa, Not Far From Limerick.

The PA Governor waited 3 days, leaving people unnecessarily exposed to TMI’s radiation releases. Delayed notification is likely to still happen today if Limerick has a radiation accident / meltdown.

TMI may be responsible for 50,000 to 100,000 Deaths. Details about consequences of TMI’s partial meltdown are available:
“Deadly Deceit: Low Level Radiation, High Level Cover-up” By Jay Gould and Ben Goldman, 1990
Gould Suggested: Infant Deaths Soared In Counties Surrounding TMI – 53% 1st Month, and 27% 1st Year
Birth Defect Deaths Higher : 10 Counties Closest to TMI – 15% to 35%

1983 – South Coventry Refused to Approve PE Evacuation Plans
(Pottstown Mercury, August 4, 1983)
• All municipalities within a 20-mile range of the Limerick site had been asked to research their communities and forward the information to their respective county governments. The state was ultimately responsible for a master evacuation plan.
• Richard Whitlock, South Coventry Chairman of Supervisors, said “There are too many gaps in the forms and alot of unanswered questions. We’re not going to approve something for the energy consultants to send to the NRC.”
• The Mercury reported that it was undetermined if an individual plan could be forced onto South Coventry without the approval of local officials.
 ACE Comment: If only elected officials in other local municipalities and our Pa Governor had refused to approve PE Evacuation Plans, Limerick construction could have been stopped. We wouldn’t face the risk of disaster today from Limerick meltdowns and the injustice of losing our health, homes, and all our possession.

(Pottstown Mercury, August 3, 1983) GAO (General Accounting Office – Investigative Arm of Congress) SAYS NUCLEAR EVACUATION PLANS ARE DEFICIENT.
GAO Official Ralph Carlone said,
• “The Federal Emergency Management Agency” has not established minimum standards that (TEST) exercises must meet and has approved exercises that did not provide ample opportunity to demonstrate response capabilities.”
• “Plans for training federal, state, and local government officials have not been implemented.”
• “FEMA does not always require that all plan elements are tested, or verify that they are complying with federal criteria.”
• There is no evidence that deficiencies from earlier exercises have been corrected.
• “Local communities that want to prevent or delay the start-up of a reactor, could use their refusal to participate in the emergency planning process to achieve their objectives.”

In 2011 – PEMA deputy press secretary told The Mercury, while the evacuation plan for Limerick was last updated in 2008, “There have been no serious changes to evacuation routes since they were first devised.”

The Mercury ( Wednesday, July 18,2012
GAO examines Limerick nuke plant’s evacuation plan
By Evan Brandt © 2012 The Mercury (
• Limerick Nuclear Plant is 1 of 4 being profiled by the GAO for examination of disaster evacuation plans.
• U.S. Sen. Robert Casey, D-Pa., asked for a GAO investigation in 2011, of “whether evacuation planning has kept pace with population growth and increased power levels around nuclear plants.” “I called on the GAO to conduct this study because Pennsylvanians living near nuclear plants have a right to know that safety procedures and evacuation planning are in place in case of emergency.”
• Casey’s request was prompted by an Associated Press investigative series on aging nuclear reactors. The series reported that population within 10 miles of U.S. plants has risen an average of 62 percent over the past 30 years.
• Associated Press data shows, the population in a 10-mile radius around the Limerick nuclear plant has increased by 45 percent since 1990 — from 178,047 to 257,625. – An increase of nearly 80,000 people.
• In a 50-mile radius — the region evacuated during the Fukushima disaster in Japan — the population around Limerick has increased by more than 855,000 since 1990.
• Exelon officials insist the increases in population are taken into account in the emergency evacuation plans. However, in 2011, PEMA’s deputy press secretary told The Mercury:
 While the evacuation plan for Limerick was last updated in 2008, “there have been no serious changes to evacuation routes since they were first devised.”
• GAO staff met with Nuclear Regulatory Commission, Federal Emergency Management Agency, Pennsylvania Emergency Management Agency and local emergency responders and plant personnel.
• Exelon’s PR person wrote: “Limerick’s responsive and scalable emergency plan is frequently tested to ensure that it can protect the health and safety of the public. Limerick’s emergency plan incorporates technological advances and lessons learned from recent events.”
• GAO will issue a report “early next year” based on three primary areas of inquiry.

In 2012 – NRC Pared Down Emergency and Evacuation Planning – NRC’s New Rules Make No Sense. Despite Devastating Lessons After Chernobyl and Fukushima:
1. NRC Requires FEWER Exercises for Major Radiation Accidents
2. NRC Recommends FEWER People Evacuate Right Away
3. NRC Allows Emergency Drills To Be Run Without Practicing for Radiation Releases
Many responders view NRC’s new rules as downright bizarre.

In 2012 – 2013 – GAO is currently examining Limerick Nuclear Plant’s evacuation plans, but is avoiding critical questions regarding radiation exposure, the major threat to millions associated with a Limerick Nuclear Plant meltdown.
GAO’s three primary areas of inquiry include:
1. “What are the roles and responsibilities of the Nuclear Regulatory Commission (NRC), the Federal Emergency Management Agency, and state and local entities in evacuation planning for U.S. nuclear power plants?”
2. “How do NRC and FEMA perform their evacuation planning roles and responsibilities?
3. “How do NRC and FEMA help communicate evacuation plans and the risks associated with a potential nuclear power plant accident to the public?”
 GAO’s New Report Doesn’t Appear To Address NRC’s Pared Down Planning, Eliminating Practicing For Radiation Releases or NO REQUIREMENT for IMMEDIATE Notification To Reduce Harmful Short and Long Health Consequences From Radiation Releases in A Limerick Accident / Meltdown.

Multiple Meltdowns Can Happen At Limerick Nuclear Power Plant.

1.It Only Takes Loss of Power and Cooling Water – This Can Be Triggered by Earthquakes, Other Natural Disasters, Fires, Terrorist Attacks, Human Error, or Mechanical Breakdown of Aging Equipment.

2.NRC Is Not Requiring Important Seismic Upgrades At Limerick Until After March 2017, 5 Years After Fukushima. By Then We Could Face Meltdowns. Limerick Is Now Ranked 3rd On The Nation’s Earthquake Risk List, With An Earthquake Fault Right Under The Site And Four Others Within 17 Miles. Earthquake Threats Are Increasing In PA, Including As A Result Of Thousands of Wells Drilled For Natural Gas Fracking In PA.

3.Limerick’s Reactors Are Similar to Nuclear Reactors That Exploded at Fukushima, Yet NRC Is Disregarding and Delaying Its Own Staff’s Most Important Safety Recommendations After Fukushima, Increasing Threats For Radiation Accidents / Meltdowns At Limerick.

4.Limerick Has Design Flaws That Can’t Be Corrected. Cement in Limerick’s Reactor Containment and Fuel Pools Is Substandard.

5.NRC Is Weakening Many Safeguards and Oversight For Limerick’s Aging Problems. Limerick’s Safety Evaluation Reports Verify Corrosion At Far Greater Rates Than Estimated, Plus Cracking, Pitting, Fatigue, Fouling, 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. It’s Only A Matter of Time.

6.Even Though There Is Potential For Devastation Across Hundreds of Miles From A Limerick Radiation Accident/Meltdown, Limerick’s Emergency Plans Are Negligent, Reckless, and Fatally Flawed, Increasing Long-Term Devastating Health and Financial Risks For Millions.

Limerick Meltdowns Could Result In Catastrophic Consequences
For Millions In The Greater Philadelphia Region.
We Could Lose Our Homes, Possessions, Livelihoods, and Health.

74,000 Early Fatalities
610,000 Early Injuries (most any U.S. reactor)
34,000 Cancer Deaths
Population Increased Over 100% Since 1980
Numbers Above Would Be Drastically Higher Toady

Philadelphia Is Just 21 Miles Downwind, Downstream.

 In 1980, NRC expected that people within 30 miles would be harmed. In 1983, all municipalities within 20 miles of Limerick were asked to send information to the county for emergency planning. Yet, we ended up with only a 10 mile evacuation zone.

After Fukushima Meltdowns, NRC Told U.S. Citizens Within 50 Miles To Evacuate.
Over 8 Million People Live Within 50 Miles Of Limerick Nuclear Plant

1974 MELTDOWN CONSEQUENCES – From NRC’s Rasmussen Report
45,000 Radiation Sickness Cses (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 Defective Children Born PER YEAR
$14 BILLION Property Damage – NOT Insurable

Limerick’s Evacuation Plans Cannot and Will Not Minimize Radiation Sickness, Cancer, and Other Health Harms For Millions Of People.



ACE Health survey and Cancer Mapping

ACE Health Survey / Cancer Mapping

ACE Cancer Mapping Reveals A Cancer Crisis That Occurred After Limerick Nuclear Plant Started Operating In 1985.  Mapping Represents Documented Cancer Victims Up To 2004.

PA Cancer Registry data from 1985 to the late 1900s proves there were shocking cancer increases in communities near Limerick Nuclear Plant after Limerick started operating in 1985.  See Download #2 on ACE Website (Cancer- Skyrocketing Increases: Links to Limerick), for statistics on increased cancers in communities near Limerick Nuclear Plant.

The link is clear.  Since 1985, Limerick Nuclear Plant routinely released radiation into our air and water.  Our soil, food, and bodies are impacted.  We are continuously exposed to a broad range of radionuclides released from Limerick through many routes of exposure, including our air, water, soil, and food.  The National Academy of Sciences BEIR VII report proves radiation exposure can cause cancer at any level, especially in children.  Childhood cancers skyrocketed in communities near Limerick, from 30% higher than the national average in the late 1980s, to 92.5% higher than the national average.

Rather than working to minimize cancer risks, government agencies and some elected officials were more interested in covering up alarming cancer statistics documented in four cancer studies using the PA Cancer Registry data.  As a result, in 2002, ACE officers hand delivered health surveys to over 4,000 residents in Pottstown (mailing address of Limerick Nuclear Plant) and the bordering Pottsgroves.  In 2004, ACE mapped the cancers reported through ACE health surveys and other sources.

Cancer mapping from ACE health surveys provided visible evidence of the cancer crisis in communities near Limerick Nuclear Plant.

ACE cancer mapping does not represent all cancers in these communities.  There was not enough room to map all victims.  Some streets were riddled with so many cancer victims, that mapping them all would have made streets unreadable. Well over 500 cancers not mapped were identified before 1994.  Hundreds more identified from 1995 to 2004 were also not mapped.

Cancer victims from other neighboring communities also completed and sent health surveys to ACE through our website.  They learned of the ACE survey project through letters to the editor in the Pottstown Mercury and our Pottstown Cable TV shows.

ACE Video Blog 2 on Calls for Immediate Notification and Expanded Evacuation and Ingestion Pathway Zones


 ACE Report Blog Series

Alliance For A Clean Environment

Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick

Nuclear Plant’s Flawed And Inadequate Emergency and Evacuation Plans.

Part #2    January 2013

Calls For Immediate Notification and Expanded Evacuation and Ingestion Pathway Zones

Many expressed concerns and are calling for more precautionary emergency and evacuation planning, including the National Resources Defense Council (NRDC), the Union of Concerned Scientists, Senator Bob Casey (D-PA),  Associated Press Investigative Report, Pottstown Mercury, The Alliance For A Clean Environment (ACE), and many residents living around Limerick Nuclear Power Plant.

National Resources Defense Council (NRDC) filed an appeal in 2011, related to Limerick Nuclear Plant’s Outdated Severe Accident Mitigation Alternatives, Including Assessing Consequences of a Limerick Accident or Terrorist Attack.

NRDC won in the 3rd Circuit Court of Appeals in Philadelphia.

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.   There are 1,914 Public Schools and 176 Hospitals within 50 miles.  (See NRDC Plume Map

Evacuation planning for health risks from radiation exposure are being ignored, even though up to 1.4 million additional people now living downwind in the Philadelphia-Wilmington-Newark metropolitan area need to be addressed also.

In spite of the court ruling, NRC is refusing to consider increased population and health risks associated with a Limerick Nuclear Plant accident / meltdown.

NRC displayed a grotesque dereliction of duty when they joined Exelon in appealing the court’s decision.

During the hearing NRC made no pretense of being a neutral arbitrator, much less the public’s advocate and protector.

NRDC’s director of the nuclear program said, “After Fukushima, it seems just plain nutty not to require a new studyIt’s hard to believe that after the severity of the Fukushima disaster, involving BWR reactors similar to Limerick’s, that Exelon and NRC blithely maintain they have no reason to take another look at Limerick’s Severe Accident Mitigation Analysis.”

The Union of Concerned Scientists senior scientist said, “…they have not taken into account the issues associated with uncontrolled population growth very close to [nuclear] plants.”   (ABC news 6-27-11)

U.S. Senator Bob Casey (D-PA) urged immediate review  of Nuclear Evacuation Zones in a March 2012 letter to NRC.  Senator Casey Said,  “My Constituents Are Deeply Concerned About The Emergency Evacuation Plans. They deserve to know that all aspects of our preparedness plans have been re-evaluated in the wake of the disaster in Japan.  One year after Japan’s disaster, it is time that millions of Pennsylvanians living in close proximity to nuclear power plants know that unique characteristics of each plant are taken into account in the development of evacuation plans.”  Population densities and transportation infrastructure changed since these plants were first built.  Such changes must affect how NRC determines appropriate evacuation distances.

The Associated Press 2011 Investigative Report (PART III by Jeff Donn) “Populations Around US Nuke Plants Soar” has direct implications for Limerick Nuclear Plant Evacuation Plans.  (See entire summary in ACE Blog at  Highlights below:

Despite all that happened since nuclear plant radiation accidents at TMI, Chernobyl, and Fukushima, evacuation zones have remained frozen at a 10-mile radius since 1978.

Increased dangers and mounting risks have NOT resulted in more protective preparations.

AP reported that NRC, working with the nuclear industry, repeatedly weakened or failed to enforce safety standards.

1998 federal regulations show low-population areas were “preferred” for siting nuclear plants to limit exposure to radiation accidents as part of accident safeguards.

Limerick, about 21 miles from Philadelphia, was not a low-density population area in the 1970s and population has increased dramatically since then.   

Radiation releases happen within the first 1/2 hour of an accident, a fact acknowledged by NRC and FEMA.

NRC has allowed profits to outweigh public health and safety.  

NRC minimizes and rubber stamps evacuation plans, even though they are symbolic, rather than functional, just to keep nuclear plants operating.

NRC is playing with numbers to minimize presumed impacts of accidents.  

Partial drills every two years, with limited accountability for effectiveness, is woefully inadequate.

If NRC required meaningful standards for evacuation emergency plans, there would be no nuclear power plants in populated areas.   Population booms near nuclear reactor sites like Limerick minimally call for stronger evacuation standards, but little has been done.  Compliance with comprehensive evacuation plans based on current demographics would necessitate closing nuclear plants in densely populated regions like Limerick.

Pottstown Mercury Articles and Editorials Identify Concerns Related To Limerick Nuclear Plant Emergency Planning and Evacuation

“Population Soars Near Limerick Plant”  Big population spike causes headache for any emergency plans.  6-27-11

“Casey Not Sure 10-Mile Evacuation Zone Around Nuclear Plants Is Enough”

License Review Should Consider Evacuation Plan”  7-3-11

“…I’m Not Saying It Doesn’t Look Absurd, But Have You Looked At The Evacuation Plan?” Cartoon 

“Casey Urges Immediate Review of Nuclear Evacuation Zones”  3-12

Nuke Plan Evacuation Plans Need to be Realistic”  Editorial 3-20-12

Limerick Nuke Evacuation Plans Need An Update”   3-20-12

GAO Examines Limerick Nuke Plant’s Evacuation Plan, In Response to Senator Bob Casey’s Request for a Study of Evacuation Plans”  Limerick is 1 of only 4 of the nation’s nuclear plants profiled examining disaster evacuation plans.   7-18-12

Limerick Nuclear Evacuation Study Must Eye Growth” Editorial 7-26-12

The long list of those concerned validates risks and cause for action.

ACE Calls On All Citizens and Elected Officials To Speak Out For Immediate Notification And Expanded Evacuation and Ingestion Pathway Zones.

ACE Video Blog 1 on Limerick Nuclear Plant’s Flawed and Inadequate Emergency and Evacuation Plans


 ACE Report Blog Series

Alliance For A Clean Environment

Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick

Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.


Part #1    January 2013

In 2012, NRC Pared Down Emergency and Evacuation Plans

Problem:  After Documented Evidence Of Widespread Radiation Harms From Fukushima, In 2012, NRC Negligently Pared Down Emergency and Evacuation Plans For Limerick and Other Nuclear Plants.

Widespread Radiation Contamination Far Beyond The Evacuation Zone And Devastating Consequences In Japan Make It Clear That Limerick’s Current Evacuation Zone Must Be Expanded and Emergency Plans Must Be Improved, NOT Pared Down.

During Fukushima 2011 meltdowns, NRC called for a 50-mile evacuation zone for U.S. citizens in Japan.  ACE immediately urged NRC to expand Limerick Nuclear Plant’s evacuation zone from 10 miles to 50 miles to better protect people living in our region.

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 and baffling many emergency responders and citizens across the nation.

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

2)       NRC Denied Radiation Risks and Harms

3)       NRC Weakened Emergency Rules

4)       NRC Failed To Expand Emergency Zones

NRC’s New Rules Make No Sense.  Despite Devastating Lessons After Chernobyl and Fukushima: 

1)       NRC Requires FEWER Exercises for Major Radiation Accidents

2)       NRC Recommends FEWER People Evacuate Right Away

3)       NRC Allows Emergency Drills To Be Run Without Practicing for Radiation Releases

Many responders view NRC’s new rules as downright bizarre.

NRC Attempted To Hide New Pared Down Emergency Plans and Drills  From The Public. 

1)       NRC Announced Revisions December 23, 2011, at the Peak of the Holiday Season.

2)       NRC and FEMA 12/11 and 1/12 Web Archives show NO news releases on evacuation plan changes, so most people were unaware safeguards have been minimized and eliminated.

3)       May 2012, the public had the first full disclosure on NRC’s Pared Down Emergency Rules, through an Associated Press Investigative Report by Jeff Donn, titled, Evacuation Plans, Emergency Drills Pared Down Near Nuke Plants”  (In Mercury 5/20/12 –

NRC went to extraordinary lengths to deceive the public about radiation exposure revealing just how little NRC cares about people like us who live in the region of a nuclear power plant.   News Articles Also Reveal That NRC:

1)       Failed to Pursue Emergency Planning Related to Decision-Making, Radiation Monitoring, and Public Education.

2)       Failed to Address Prolonged Station Blackout Conditions.

3)       Failed to Address A Multi-Unit Event, Such As Simultaneous Meltdowns In Limerick’s Two Reactors and Two Fuel Pools.

4)       Preparedness Focus Should Have Shifted To Dealing With Meltdowns Along With Natural and Severe Weather Events, Such As Earthquakes.


Why Did NRC Make New Emergency / Evacuation Rules Less Protective?

ü  NRC is valuing Exelon’s profits over public health and safety.   

From The Beginning, (In 1980), PECO, Limerick’s Original Owner, Attempted To Avoid Costs Associated With Evacuation Plans For Limerick Nuclear Plant

1980 Mercury News Article Reported – May 28, 1980


 NRC has long been aware original evacuation plans were deficient. 

August 3, 1983, GAO said, Nuclear Evacuation Plans Are Deficient” 

 Collusion in Japan reveals that  values which place money before life and health can lead to unnecessary and devastating consequences.  

ü  A 7-12 independent report said the Fukushima disaster was man-made and caused largely as a result of collusive efforts by the government, regulators and TEPCO to avoid developing and implementing basic safety requirements.

ü  It said failure to implement adequate measures to protect against nuclear accidents and poor planning by governments led to confusion over evacuation.  

For more evidence of NRC’s Negligent Decisions, see list of news articles on NRC.

New Pared-Down NRC Nuclear Rules For Evacuation Are Neither Protective Nor Acceptable.  We Must Work to Change Them BEFORE Meltdowns Happens At Limerick Nuclear Plant. 

  1. To Reduce Radiation Exposure, Fukushima Shows Us Immediate Notification Is Imperative, Limerick’s Evacuation Zone Should Be Expanded From 10 to 50 Miles, and the Ingestion Pathway Zone Expanded From 50 to 100 Miles. 
  2. ACE Is Starting A Campaign For Citizens and Elected Officials To Join Forces Now To Demand Better Protection For Millions In The Greater Philadelphia Region.   An ACE You-Tube and Blog Series Will Summarize Issues and Actions Needed.





Look For ACE Report Video-Blog Series Starting in 2013

Starting in January 2013, ACE will begin a Video-Blog Series addressing the need to improve and update Limerick Nuclear Plant’s outdated, flawed, and inadequate emergency and evacuation plans. Each 15 minute video will be uploaded to YouTube, and also be included with an accompanying Blog Post with detailed information on our website. An overview of the series follows.

Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.

This ACE Report Video and Blog Series Should Serve As A Wake-Up Call To Millions In The Greater Philadelphia Region Related To Limerick Nuclear Plant’s Negligent Emergency and Evacuation Planning.

The Nuclear Regulatory Commission (NRC), Limerick Nuclear Plant’s regulator, is required to protect our health and safety, but a body of evidence shows that NRC is instead protecting the financial bottom line of Exelon. NRC’s deceitful claims and actions demonstrate that NRC is failing to fulfill their required duties to protect us.

NRC’s historical and current failures and corruption in policies and decision making are compromising and further jeopardizing millions of people whose lives could be harmed or ruined permanently as the result of a Limerick Nuclear Plant Radioactive Accident and/or Meltdown.

This series of ACE Report Videos and Blogs will identify problems and flaws with Limerick’s Emergency and Evacuation plans. It will reveal why we and our elected officials must demand a system for immediate independent public notification of a Limerick accidental radioactive release, and demand updated and improved planning for expanded evacuation and ingestion pathway zones.

The Alliance For A Clean Environment
January to March – 2013

Video / Blog Part 1
In 2012, NRC Pared Down Emergency and Evacuation Plans, Even After Fukushima

Video / Blog Part 2
Calls For Immediate Notification And Expanded Evacuation and Ingestion Pathway Zones

Video / Blog Part 3
The Truth and Consequences of Radiation Exposure From Nuclear Plant Accidents / Meltdowns

Video / Blog Part 4
What Really Happened After Fukushima, Chernobyl, and TMI Meltdowns

Video / Blog Part 5
Financial Injustice To The Public From A Radiation Accident / Meltdown

Video / Blog Parts 6 and 7
Fatal Flaws In Emergency – Evacuation Plans for Limerick Nuclear Power Plant

Video / Blog Part 8
Regional Campaign To Improve Limerick Nuclear Plant’s Evacuation Plan, Including Immediate Public Notification and Expanded Evacuation And Ingestion Pathway Zones

Tell DRBC to Protect Water Resources in Parts of Six Counties! Sample Letter to Send to DRBC

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

Fax (609) 883-9522

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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