List of Shocking Evidence Documenting a Pattern of Negligence by NRC and Exelon at Limerick Nuclear Plant










June 2010

  • NRC issued its “Waste Confidence Decision and Temporary Storage Rule”
  • NRC never waited for or required proven failsafe spent fuel storage before licensing  Limerick or to relicense the age-degraded nuclear plant



  • GE Hitachi notified NRC that Limerick’s Mark II Boiling Water Reactors (BWRs) might not shutdown under certain circumstances



  • NRC and Exelon’s lobbying arm, the Nuclear Energy Institute (NEI), issued an industry-friendly plan for reviewing License Renewal Applications


1-1-11 to 12-31-11

  • NRC cited Exelon for “Impeding the Regulatory Process”

Annual Assessment  Letter for Limerick Generating Station, 3-5-12



  • Unit 2 recirculation pumps tripped off-line



  • A tripped switch caused the Unit 2 Primary Isolation Valve to close during refueling



  • Fukushima’s disaster and meltdowns began, raising global human radiation dosage levels from 360 millirems/yr to 620 millirems/yr, according to the NRC



  • NRC cited Limerick with a “white” violation (noncompliance of a legally binding requirement) for the breakdown of one of its water delivery systems



  • Unit 2 reactor tripped off-line due to turbine control trouble



  • Unit 2 was manually tripped off-line during start up activities.



  • Unit 1 tripped off line from 100% power



  • Exelon submitted Limerick’s License Renewal Application to NRC, without being required to update Limerick’s Severe Accident Mitigation Alternatives (SAMA)



  • Exelon had made changes to Limerick’s emergency actions without NRC approval which reduced safety



  • An earthquake originating in Virginia, struck Limerick Nuclear Power Plant and operators felt vibrations in Limerick’s control room,

Seismic monitors, inoperable for over a year, could not confirm the earthquake



  • “Enformable Nuclear News” reported that designers, operators, and regulators of nuclear power plants only plan for statistically probable events – thus not preparing for events that, though not probable, could raise risks if an accident does not play out as modeled


9- 2011 to 8-2012

  • NRC cited Exelon with violations associated with impeding the regulatory process at Limerick (NRC Integrated Inspection Report, Cover letter 2-5-13)



  • The AP mirrored a report done in March by MSNBC that ranked Limerick as the plant with the 3rd highest risk of being damaged by an earthquake (MSNBC used NRC data)



  • An 11,000 page records-request showed that NRC experts worried privately that nuclear plants needed stronger safeguards in response to their higher post- Fukushima earthquake risk assessments,

This finding by the Associated Press (AP) is important at Limerick due to its higher risks that were not accounted for in a GI-199 assessment for Limerick based only on  generic modeling, not Limerick-specific information



  • NRC held a public hearing about Limerick’s Environmental Impact Statement (EIS) in response to Exelon’s submission of Limerick’s License Renewal Application.

The stated premise  was to provide public input, but public input was completely dismissed when NRC issued its Final EIS, August, 2014



  • GE Hitachi repeated its 9-3-10 warning that Limerick’s Inherently defective GE Mark II Boiling Water Reactors (BWRs) may fail to to safely shutdown under certain circumstances,


10- 3-11 to 10-14-11

  • NRC conducted its “Generic Aging Lessons Learned (GALL) Audit” designed by Exelon’s lobbying arm, the Nuclear Energy Institute (NEI) to fast-track license renewal.


11-4-11 (The date listed on” NRC Findings for CY 2011 at Limerick generating Station”)

  • Failure to verify power availability necessary for station blackout recovery


11-7-11 to 11-10-11

  • NRC conducted a required site auditSite Audit” in response to Exelon’s 6-22-11 License Renewal Application



  • The Natural Resources Defense Council (NRDC) filed a petition requesting that Limerick nuclear plant risks be re-evaluated, due to Limerick’s outdated 1989 Severe Accident Mitigation Alternatives (SAMA)



  • NRC approved Exelon’s amendment request to substitute more frequent monitoring and other indications of reactor coolant system leakage for an inoperable monitoring system that was used along with:

             1) The Containment Atmosphere Gaseous Monitoring System

             2) The Primary Containment Pressure and Temperature Monitoring System

On 9-6-13, NRC issued a violation for inoperability of Limerick’s radioactive gas clean-up system, that was traced back to 10-26-10, which raised the public’s offsite radioactive gaseous effluent exposure for that period



  • In secret, NRC pared down evacuation plans and emergency drills near nuclear plants


12-31-11(The date listed on” NRC Findings for CY 2011 at Limerick generating Station”)

  • A relay in service 6 years beyond its vendor-recommended replacement date failed



  • NRC granted Exelon’s Limerick License Amendment to modify the Unit 1 safety limit minimum



  • The Nuclear Information and Resource Service (NIRS) and 37 co-petitioners joined the petition request by to NRC to expand emergency planning zones

On 4-9-14, NRC denied the expansion



  • An Instrument and Controls (I & C) technician accidentally entered a room with high radiation, posted as requiring a neutron radiation monitor, without one



  • NRC revised its regulations for license renewal applications that  helped fast-track the process without protections that the public felt were necessary

The changes were initiated by Exelon’s lobbying arm, the Nuclear Energy Institute(NEI)


February, 2012

  • In response to NRDC’s petition, NRC held a hearing



  • NRC ordered the installation of reactor vents “without delay” when it knew that vents without filters cause extreme public radiation dosage due to vent-expelled radiation

NRC later granted Exelon’s request to delay vent installation until 2018 (Unit 1)and 2019 (Unit 2)



  • NRC issued its order to modify licenses with regard to requirements for Mitigation Strategies for Beyond-Design-Basis external events



  • NRC granted Exelon an amendment that changed the method of calculating core reactivity from “predicted versus monitored control rod density”

NRC stated it had reasonable assurance that public health and public safety would not be endangered



  • 15,000 gallons of radioactive water spilled into the Schuylkill River, but neither Exelon nor NRC alerted water companies or the public to take protective action and the public never knew it occurred until the local newspaper 23 days later, on 4-13- 12


4- 4-12

  • The spill had not yet been made public, when eleven days later, a high level of Iodine 131 was found in the Philadelphia Water Department’s water.
  1. Iodine 131 is a signature fission byproduct of Limerick nuclear plant
  2. Exelon denied it was from Limerick


4- 4-12

  • The Atomic Safety and Licensing Board (ASLB) allowed the NRDC’s SAMA challenge  to move forward



  • Limerick’s 15,000 gallon radioactive water spill into the Schuylkill River was announced in the Mercury

People had been denied the option to switch to bottled water, especially for infants, the sick, or the elderly for over three weeks, and elevated levels of iodine had been discovered in Philadelphia’s water supply eleven days after the spill



  • A false alarm indicated a trip of the reactor enclosure ventilation system, the cause of which could not be determined



  • Then-chairman of the NRC publicly revealed that NRC uses a computer model called ‘pencil whipping’ so any nuclear plant, no matter how degraded, looks “good to go” for continued operations.


June, 2012

  • the U.S. Court of appeals for the D.C. Circuit vacated (erased) the NRC’s 2010 Waste Confidence Decision and Temporary Storage Rule, ordering NRC to issue no license renewals pending resolution of waste storage issues



  • For six months , Exelon failed to recognize the condition that led to a valve failure
  1. During a test, a water flow valve failed to open following a loss of water signal and failed again when the test was repeated
  2. The condition had existed, but not been recognized since 11-30-11



  • Eight years past their vendor-recommended lifetime, degraded relays caused an unplanned shutdown that could have led to core damage.



  • Operator failure to follow an alarm within 15 minutes delayed power reduction for an hour and 49 minutes, resulting in an unplanned shutdown
  1. Circumferential fatigue cracks were observed around the weld toe
  2. Limerick’s Unit 1 reactor has acrack in a weld joining an inlet riser to two jet pumps and the transition piece



  • Three years of inadequate preventive maintenance resulted in a transformer explosion in the plant’s control structure, adjacent to the control room, necessitating a manual scram due to loss of power to main generator cooling water pumps, the 4th scram since 2010



  • Unplanned shutdown & outage due to leaking safety/relief valve & hydrogen leak



  • Exelon was cited for its 9-month failure to respond to a Unit 1 reactor alarm for ‘depressurization and IA dryer filter’



  • Unit 2 reactor shutdown during startup was caused by a reactor water level transient that caused malfunction of the turbine valves



  • NRC granted Exelon’s request to eliminate the test to demonstrate age-degraded equipment operability from Limerick’s License renewal Application

NRC allowed Exelon to eliminate Commitment No. 46, which was the requirement for the test



  • NRC joined Exelon in Exelon’s appeal to stop NRDC’s Petition to require Exelon to include an updated SAMA as a part of Limerick’s License Renewal Application,

The 5-member Commission agreed, contending that NRDC had launched an “impermissible collateral attack on our regulations,”



  • Failure to adequately evaluate the voltage to safety equipment, which could have resulted in loss of coolant or fire. Failure in real time could result in core damage.



  • A 3-month NRC Inspection of Units 1 and 2 that began on 10-1-12 listed the following  summary of Limerick deficiencies:
  1. Failure to administer an NRC Annual Operating Test Simulator Scenario Re-examination that met procedural requirements
  2. Failure to revise EDG Tank Cleaning Work Instructions
  3. Failure to follow Radiation Protection Procedures for personal protection
  4. Inoperable Primary Containment Isolation Valves
  5. Redundant Reactivity Control System setpoint drift
  6. Inoperable Isolation Instrumentation
  7. Three Main Steam Isolation Valves failed the Surveillance Test
  8. Exelon made changes to the Emergency Plan without NRC approval


2000 to the end of 2012

  • Limerick reported 114 violations from 2000 to the end of 2012
  1. Charlotte Observer, !0-16-13,  Business National News, 10-15-13
  2. NRC’s inconsistent enforcement shows extraordinary differences among U.S. regions.
  3. Our concern is that, based on the NRC and Exelon e-mailed report we received from NRC when we questioned NRC about the quake that hit Limerick on 8-23-11, it appears that the significance of violations may be substantially underplayed in Exelon’s records
  4. Based on NRC Safety Inspection Reports, it appears that NRC’s process of rating violations is significantly impaired by NRC’s pre-determined objective to keep Limerick operational by lessoning the appearance of violations that could significantly impact plant stability



  • Exelon did not verify that adequate voltages would be available to safety-related equipment during a design basis loss-of-coolant accident

Exelon’s License Renewal Application for Limerick contained many similar deficiencies as well as flawed assumptions.


1- 30-13

  • NRC granted Exelon’s request to withhold from public disclosure: “Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package” (Executed by Global Nuclear Fuel-Americas, LLC (GNF-A)



  • NRC closed the issue of Limerick’s degraded Motor Operated Valve (MOV) System that broke down on 5-23-15 while experimentation to keep it operational continued



  • The Atomic Safety and Licensing Board (ASLB) referred NRDC’s petition requesting an updated SAMA for Limerick to the 5-member NRC Commission for final determination



  • NRC’s Commitments Audit revealed a pattern of inexplicable negligence in the area of Exelon’s Preventive Maintenance, especially in regard to the inoperability of Limerick’s seismic monitoring system



  • NRC issued Amendments No. 209 (Unit 1) and 170 (Unit 2) re: Relocation of Technical Specifications for Motor-Operated Valve Thermal Overload Protections

This change charts new territory for unknown risks



  • Beyond Nuclear’s Reactor Oversight Project Director and 22 public advocacy groups joined together to request that NRC revoke the operating licenses for all nuclear plants operating with the defective GE Mark I and Mark II Boiling Water Reactors (BWRs) in the U.S.
  1. Limerick has two defective Mark II BWRs
  2. NRC refuses to test the reactors using the surveillance capsules that the 2013 NRC chief said were in Limerick’s reactors.



  • Two RP technicians were accidentally locked temporarily in a Unit 2 area known to have high radiation risk

The workers were freed without mishap, but it is worth noting that this level of risk exists



  • Aside from poor maintenance there was no explanation for the unexpectedly low condition of Unit 1 battery chargers



  • NRC granted Exelon’s request to change the Core Operating Limits Report for Limerick Generating Station Unit 1, Reload component removal 14, Cycle 15, Revision 10



  • NRC issued a “Withdrawal Notice” for “Reporting Procedure for Mathematical Models Selected to Predict Heated Effluent Dispersion in Natural Water Bodies.” (Regulatory Guide (RG) 4.4)



  • An engineering recommendation that had been made on 10-26-10, but overlooked was made again, to test the Unit 2 Primary Containment Instrument Gas (PCIG) check valve, because there was a problem.

This recommendation continued to be overlooked until 9-6-13 when it was discovered that off-site radiation doses were raised due to the failure of the valve



  • A Former NRC Chairman said, in light of what he learned from Fukushima, the public has no protections and no U.S. nuclear plants are safe

Predictably, the president and chief executive of Exelon’s lobbying arm, the Nuclear Energy Institute (NEI) asserted that “U.S. nuclear Energy facilities are operating safely. That was the case prior to the Chairman’s tenure, the case during his tenure, and it is still the case today.”



  • A reactor automatically shutdown due to improper procedures and lack of ordinary foresight



  • It was reported in an interview, that the average nuclear plant has 6 guys on Ebay trying to buy old parts.
  1. The reason is that if they put a new part in, and it isn’t like the original, they have to go to the NRC and ask permission. Old parts are in their warehouse so when a part breaks down, they can replace it “in kind” instead of getting something newer or better.
  2. Could it be possible that the 16 years of refurbished equipment malfunctions mentioned for date 8-21-13 resulted from this practice?



  • NRC approved nuclear industry-friendly alternatives and weakened Post-Fukushima Near Term Task Force Recommendations instead of enforcing them,
  1. It is of little benefit to the public to have pro-nuclear industry groups driving the NRC policies which expedited Limerick license renewal
  2. NRC is refusing to regulate Limerick on behalf of protecting people and the environment, in favor of an industry that has shown that it is not interested in public health and safety



  • 6-month failure of Emergency Diesel Generator (EDG)



  • Ventilation System Trip due to the degraded performance of the Primary Containment Isolation System’s reactor enclosure equipment compartment exhaust flow transmitter



  • Safe-shutdown switches for Units 1 & 2 sustained fire damage due to poor preventive maintenance

The fire brigade and fire equipment delivery to the spray pond pump house was delayed



  • NRC granted Exelon’s amendment change for Core Operating Limits Report For Limerick Generating Station Unit 2, Reload 12



  • NRC released a deceptive newspaper public statement: “NRC Wants Upgraded Vent System” as if vents without filters offer the public protection.
  1. This was a degraded version of NRC’s 1980 post-TMI recommendation to install filtered vents at Limerick, which NRC never enforced
  2. This repeat of NRC’s 3-12-12 recommendation, reveals that NRC is more concerned with appearing to protect people than in actually protecting them



  • NRC cited “Improper procedures, performance deficiency, and poor decision making” as causes for turbine and control valve stoppage causing Unit 2’s unplanned automatic reactor  shutdown



  • Depressurization in Unit 1 due to a service air compressor trip caused by reintroducing a previously failed circuit board



  • Failure of the transformer automatic voltage changer



  • 9 months of human error led to repeat inadvertent depressurization of Unit 1 reactor.



  • NRC’s Petition Review Board (PRB) recommended dismissal of a public request by Beyond Nuclear and 22 other public advocacy groups to close all nuclear plants operating with defective GE Mark I & II BWRs.
  1. The dismissal was made without answering questions and addressing charges
  2. Petitioners did not give up, as shown on 9-30-13



  • Limerick Units 1 & 2 exhibited four or more of the 11 risk factors that qualified it for early closure in a report by Mark Cooper, senior fellow for economic analysis, Institute for Energy and the Environment in his report, “Renaissance in reverse: Competition Pushes Aging U.S. Nuclear Reactors to the Brink of Economic Abandonment” He noted:
  1. The death of Limerick’s large planned power uprate project
  2. Risk factors based on ratings by Moody’s, UBS, and Credit Suisse
  3. Although this is not a prediction, keeping aging nuclear plants on-line if they need repairs or retrofits does not make economic sense and Limerick is undergoing major repairs and experiments, especially on its core water delivery system that no longer operates as a motor-driven system.



  • NRC announced its password-protected portal

For, it says, licensee contractors’ submittals that support post-Fukushima Near Term Task Force recommendations



  • The Attorneys General of New York joined in an effort to stop NRC from erasing all record of a judicial ruling that the public has a right to intervene before major amendments are granted to a nuclear plant’s operating license



  • Incorrect amount of chemical added to Emergency Diesel Generator jacket water



  • A defective Redundant Reactivity Control System (RRCS) Analog Trip Module (ATM) board rendered the Unit 1 RRCS inoperable



  • The defective ATM board was replaced with a refurbished board and returned to service, however within 24 hours, the channel reading was drifting again



  • The ATM malfunction did not actuate the Unit 1 Residual Heat Removal (RHR) heat exchanger bypass valve control, requiring further troubleshooting.



  • 16 years of refurbished equipment malfunctions took seven days, from 8-14-13 to 8-21-13, to recognize



  • NRC notified Exelon that there was deficiency in the Motor Operated Valve (MOV) system in nuclear plants like Limerick which was identified in 1985

Known as “hammering”  the defect had already damaged Limerick’s MOV system, which is undergoing a series of new experiments



  • The unnoticed inoperability of Limerick’s radioactive gas clean-up system for almost 3-years, was finally noticed
  1. Beginning on 10-26-10, inoperability raised the public’s offsite radioactive gaseous effluent exposure
  2. Two years before the Atomic Energy Commission (AEC) issued Limerick’s construction permit, which was 12 years before In NRC issued the license for Unit 1, the AEC stated that Limerick’s “estimated doses from gaseous effluents are much higher than those considered acceptable by the staff. With the estimated outage of the gas clean-up system, the air immersion dose to an individual at the site boundary will be about 480 millirems/year” (AEC’s 1972 Limerick Environmental Impact Statement, EIS).
  3. Note: radiation does not stop at Limerick’s boundary.
  4. Limerick’s radioactive gas release report from 2011 had an uncertainty rate of 15.7% – 36.6%.
  5. The AEC’s estimate of 480 millirems /yr for Limerick radiation, with outage of its gas clean-up system, may or may not be accurate.
  6. According to NRC’s estimate, Chernobyl raised the global background radiation doses of human exposure from 100 to 360  millirems/yr., Fukushima’s meltdowns that started on 3-11-11, raised the dosage to 620 millirems/ year , and at Limerick, on top of that, we have high off-site gassing
  7. Exelon deceptively states that all sources of radiation are the same, however, nuclear plants produce radionuclides unknown in nature, which may have unknown additive, cumulative, and synergistic effects



  • Reintroducing a refurbished circuit board caused a service air compressor trip depressurizing Unit 1



  • Beyond Nuclear and 22 other public advocacy groups filed a petition before the NRC’s Petition Review Board (PRB) as part of Beyond Nuclear’s “Freeze Our Fukushimas” campaign.
  1. The petition charged that NRC’s post-Fukushima actions ignore the dangerous vulnerabilities of U.S. nuclear plants currently operating with GE’s inherently defective Mark I and II Boiling Water Reactors (BWRs)
  2. Beyond Nuclear suggested that while Japan contemplated how to freeze a wall 90 feet into the earth to contain Fukushima’s radioactivity, NRC’s focus should be on permanently freezing the operation of all GE Mark I and II BWRs nuclear plant operations.
  3. On 2-26-14, Beyond Nuclear initiated a  massive public advocacy group effort to request requiring the installation of severe-accident-capable containment vent systems in conjunction with external, engineered, radiation filter installation at nuclear plants (including Limerick)



  • NRC defined the primary responsibility for nuclear plant safety and security as resting with the licensee, in Limerick’s case Exelon, and NRC minimized its own role by stating that NRC simply has oversight
  • This announcement compounds lax public protections:
  1. NRC defines its Reactor Oversight Program (ROP) as ‘documenting’ risks with enforcement essentially an ‘interpretation’ of regulations.
  2. The clarification was made in an NRC address to interested nuclear industry stakeholders anticipating NRC’s cessation of functions if there was a government shutdown
  3. The NRC / Exelon relationship is a huge problem, because 90% of NRC’s nearly $1 billion budget is paid by the nuclear industry it supposedly regulates and there seems to be no mechanism for enforcement
  4. As was shown at Fukushima, industry self-reporting is unreliable due to self-interest



  • A congressional study pointed to inconsistencies in NRC’s enforcement of violations at power plants throughout the U.S.



  • It was reported that reactor water monitoring systems do not work correctly and it is very difficult to operate a nuclear power plant with any degree of certainty.

When one of the reactors has an emergency shutdown, operators simply do not know if the reactor has enough water to keep it cool(Fairewinds Energy Education podcast discussion between a nuclear researcher and an experienced nuclear engineer)



  • The Office of the Inspector General (OIG) announced that NRC was inadequately enforcing regulatory requirements of active component aging and NRC’s management was not focused or coordinated

Active components are valves, motors, fans, electrical relays, etc., whereas passive components include pipes, supports, and tanks



  • NRC held a short “affirmation hearing” that all five members of the federal NRC commission attended, and where they all affirmed their agreement to refuse NRDC’s petition for an updated Limerick SAMA
  1. In 1996, NRC amended its regulations to require SAMA analysis for all new nuclear plants, specifically exempting Limerick from needing another for re-licensing
  2. NRC argues that Limerick’s SAMA that was done in 1989 doesn’t have to be updated
  3. However, Limerick’s SAMA was court-ordered, not voluntarily produced
    • In 1981, before Limerick construction was complete, Limerick Ecology Action (LEA, predecessor of ACE) sued NRC for, among other things, not considering alternatives for Limerick.
  • NRC did not halt construction when LEA filed the suit in court
  • NRC continued construction and dragged out the court case until NRC had licensed Unit 1(1984) and Unit 2 (1989)
  • NRC was ordered to produce a SAMA as part of the court’s judgment against NRC to increase public protection
  1. NRC completed Limerick’s court-ordered SAMA in 1989
  2. Produced under court order as an after thought to licensing Limerick, NRC’s Limerick SAMA may not have been produced as thoughtfully and protectively as it might have been, and so might need updating, given the new understandings we have gained about the risks associated with Limerick operations since Fukushima.



  • Although, immediately after Fukushima’s nuclear disaster, NRC explained that filtered vents offer the public better protection than vents alone as a post-Fukushima upgrade, in November 2013, NRC caved in to industry pressure and eliminated filters, due to industry costs
  1. Then, NRC directed utilities to follow the guidance of Exelon’s lobbying arm, the Nuclear Energy Institute (NEI) and install vents only, classifying that as, “compliance”
  2. NEI is the very powerful lobbying Arm of the nuclear Industry (not a government-appointed regulatory agency)
  3. On  3-12-12, NRC had ordered the installation of reactor vents “without delay”
  4. On 6-12-13, NRC released a deceptive newspaper public statement: “NRC Wants Upgraded Vent System” as if vents without filters was a good thing and as if upgrades were being installed in a timely fashion.
  5. On 2-26-14, Beyond Nuclear initiated a  massive public advocacy group effort to request radiation filters on vent installations at nuclear plants (including Limerick)



  • 6-month emergency diesel generator leak due to critical component failure of a pipe fitting that leaked for from Nov. 2012-May, 2013, was discovered



  • Beyond Nuclear initiated a massive public advocacy group effort to request that the Office of Inspector General (OIG) investigate the NRC Commissioner’s 3-19-13 majority vote that resulted in the 6-6-13 Order that ignored the NRC’s  own technical staff’s recommendation to require the installation of severe-accident-capable containment vent systems with radiation filters at nuclear plants (including Limerick)
  1. Although filtered vents are being mandated in other countries, the U.S. has allowed Exelon to stall until 2018 and 2019 for its vent-only installations
  2. Limerick eliminated filter installation to save itself money, even though filters protect humans and NRC originally recommended them as cost-justified expenditures (source: NRC’s Backfitting cost-justified Substantial Safety, draft)



  • Unit 1 Rapid Plant Shutdown into hot shutdown due to an Electro-Hydraulic Control (EHC) System failure

This caused the inability of all Low Pressure Turbine Intercept Valves to close



  • Mercury report: “‘Scram’ advances Limerick nuke plant refueling”



  • NRC released the report of the 3-13-15 meeting between NRC staff and Exelon’s lobbying arm, the Nuclear Energy Institute (NEI) to discuss current License Renewal Topics



  • NRC denied expansion of nuclear power plant Emergency Planning Zones (EPZs) requested by the NIRS petition



  • Mercury report: “NRC rejects bid to expand evac zones around nuclear plants”



  • NRC released its deceptive 2013 assessment of Limerick in the Mercury with the headline, “NRC: ’green’ rating for plant in 2013”
  1. NRC deceptively chose the color green, which indicates a violation,knowing that people are conditioned to think green means safe.
  2. People are unaware that compliance is not a matter of physical adherence to a standard, but instead, means the data base record shows that no physical violation exists because the record of the regulation, in its original form, has been replaced by the regulation without the requirement, while the violation still exists physically on-site
  3. Green violations blanket many Limerick safety defects, such as accidents that can lead to core damage and Limerick’s defective GE Mark II Boiling Water Reactors, which all contribute to Limerick’s continual state of high risk



  • NRC issued its deceptive post-Fukushima seismic evaluation of Limerick based on generic modeling which hid Limerick’s real earthquake risks



  • Digital First Media post: “NRC Ruling on Evacuation Planning Fails the ‘Shadow Test’”



  • Mercury report: “De-commissioning fund yields little consequences for Exelon”
  1. For years, Exelon substituted its own formula for setting aside funds for decommissioning, which saved Exelon money
  2. Part of the resulting shortfall of millions of dollars has been assigned to ratepayers



  • NRC issued a revision of its “Design Spectra for Seismic Design of Nuclear Power Plants”
  1. NRC stated that it was issuing this revision without a public comment period because there were only minor staff changes and the NRC staff considers this approach acceptable for defining response spectra for the design of nuclear power plants
  2. Limerick, however is unique, with a set of unique seismic markers that may not be in the guide
  3. This guide is not a rule and does not require equipment upgrades, because the nuclear industry fought against upgrades due to costs, even though NRC said they offered cost-justified public protection



  • Mercury report: “NRC Mum About Security Problem at Limerick Nuclear Plant”



  • Emergency Diesel Generator ‘D14’ cylinder liner cracking and leakage was observed during startup after  2-year outage



  • NRC announced its “Waste Confidence Rule” which fast-track Limerick license renewal and simply directed Limerick to store all its waste on-site despite growing evidence that none of NRC’s assumptions about the nuclear industry’s ability to handle nuclear waste work:

Nation-wide evidence suggests that NRC’s mandate for Limerick to store high level radioactive waste on-site is no solution for Limerick:

  1. In 2014, the nation’s only underground nuclear waste repository was forced to close. A storage container burst, contaminating the facility and 22 workers. State and DOE officials were forced to pay $74 million in settlements for dozens of permit violations.
  2. On 10-14-15, an underground fire that began in 2010, smoldered and spread to within 1,000 ft. from uncontained nuclear waste.Repeated appeals to Federal, Missouri and Environmental Protection Agency, were ignored as of that date
  3. On 10-26-15, a soundless 40-second video was turned over to state officials showing bursts of white smoke and dirt flying from several explosions on 10-18-15 from the nation’s first federally-licensed low-level radioactive waste dump in the Nevada desert.Opened in 1962, its license was suspended in the 1970s for mishandling shipments of material that were buried but exploded and burned, as shown in the footage. The nuclear dump has not been safely brought under control since its shutdown in 1992



  • The Mercury reported that in September, Exelon would contest the NRC’s issuance of a “greater than green” violation regarding Limerick security.



  • NRC issued Limerick’s deceptive “Final Environmental Impact Statement” (EIS), one of the last steps in license renewal that resulted from NRC’s allowing public input, but excluding public input from influencing NRC’s issuance of Limerick’s EIS  
  1. Ignoring publicly presented evidence, NRC stated that Limerick’s Environmental impacts were small
  2. The scope NRC’s EIS was extraordinarily narrow and NRC defined the environmental parameters to exclude many factors commonly considered important l by the millions of people living within Limerick’s evacuation zone


10-1-14 to 12- 31-14

  • NRC stated in its Inspection Report, that it “verified Limerick’s ‘Evacuation Time Estimate’ (ETE) updates”
  1. NRC made a reference to the ETE in a sentence but has not, so far, acknowledged reading and analyzing it
  2. It is worrisome that NRC defined “verification” in Limerick’s Commitment Audit (2-27-13) as a search of Limerick’s database using key words. Verification should include reading the ETE to verify that it is workable, which it is not



  • 100-gallons of chlorine leaked into the Schuylkill River from a faulty valve

A second chemical was added, to try to neutralize the chlorine



  • Mercury article: “Limerick nuke plant leaks 100 gallons of bleach in to the Schuylkill River”



  • NRC relicensed Limerick without the backing of many experts and the public, whose concerns regarding safety and environmental protections were dismissed
  1. Granfathered defects include Limerick’s inherently defective BWRs, a motor-operated core water delivery system that is no longer motor-operated and is the subject of experiments, no Limerick-specific reevaluation of Limerick’s earthquake risks, no updated SAMA, no test of age-degraded equipment, and a host of exemptions for systemic deficiencies
  2. Flawed theories about high-level radioactive waste (spent fuel) have been proven wrong all along, yet NRC was able to license Limerick through the technicality of issuing its Waste Confidence Rule, without proof that it is failsafe.



  • Mercury article: “Limerick nuke plant’s license renewed for 20 years”



  • “The bottom line is, compliance with current licensing basis requirements has never been shown to be valid at any nuclear plant in the country, not at any plant at any time,”

Source: statement by a nuclear engineer with the Union of Concerned Scientists in “Aging Risk vs. Inherently Safe” article regarding extending the life of nuclear power plants



  • Exelon’s engineering team inspected its own experimental work to keep Limerick running and NRC issued its “evaluation” of the team’s inspection report in “Changes, Tests, Experiments, and Permanent Plant Modifications”



  • Mercury report: “Environmentalists Challenge Re-licensing of Limerick Nuke Plant”

The article highlighted NRDC action on behalf of public safety on 12-15-14, opposing NRC’s license renewal of Limerick without an updated SAMA



  • Mercury report: “Bomb Squad Called to Limerick Nuclear Plant, No Bomb Found”

Fortunately no bomb was found, but the fact remains that Limerick is a terrorist target



  • Surprisingly, instead of publishing Exelon’s request to Amend Amendment 174 in the Federal Register, as required, NRC posted it in the Mercury’s ‘Classifieds’ section, stating that it did so because this was an emergency and there was no time to post it in Federal Register.
  1. NRC stated that if it did not grant Exelon’s requested amendment, NRC would have to shut Unit 2 down for being in violation of regulations.
  2. The emergency was that Exelon could not meet an equipment installation date of 2-27-15, which it knew it needed to do when it asked for the Amendment that set the date that Exelon wanted amended again.



  • Submittal to NRC: ACE Objection to Exelon’s Requested Amendment of Amendment No. 174, Leak Detection System Setpoint and Allowable Value Changes”

NRC granted the amendment, allowing Unit 2 to operate in physical violation of regulations until spring refueling



  • Mercury report on Limerick accident: “Valve Leak shuts down Limerick nuclear plant”



  • Mercury report on Schuylkill’s insufficient water supply: “Exelon nuke plant seeks more Schuylkill River water during heat waves”

Limerick’s insatiable water use is a growing threat to the public health and safety in this time of global warming



  • Exelon declared an “alert” at Limerick due to a “small” fire which was, according to Exelon, in the reactor building and, according to NRC, in one of the security buildings.



  • Unit 2’s preplanned shutdown did not work, requiring an immediate manual full shutdown, or a shutdown of a shutdown.

It worked, but shows the constant gamble with safety at Limerick



  • NRC issued Limerick Amendment Nos. 216 (Unit 1)and 178 (Unit 2), approving  “Technical Specification Task Force (TSTF) Traveler TSTF-523, for “Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment Spray Systems”



  • Unit 2’s radiation levels rose due to the accidental overflow of radioactive liquid from a tank resulting in exposure and decontamination of personnel and accessible areas of Unit


7- 7 & 8 -15

  • Accidental drainage of 231 gallons of cask water “exposing fuel assembly tops”  because there were no directions to close the discharge valve after work was completed

Radiation rose until it was noticed by the RP technician, who alerted the floor manager, who noticed the water accumulating on the refueling floor.



  • “Town and Country” newspaper published the headline, “Montco Health Department to Distribute Free Potassium Iodide Tablets on Aug. 6



  • State officials identified trains called “oil bomb trains” as hazards that warranted updated emergency preparation (Mercury). The public objected to tracks running through Limerick’s site, 1/8 mile from the reactors



  • Two circulating water pumps tripped requiring power reduction



  • The Mercury reported, “Feds (NRC) halt study of cancer risks at 7 nuclear plants”
  1. Federal regulators (NRC) pulled the plug on a five-year study of the risk of cancer in communities around six U.S. nuclear plants and a nuclear fuel site.
  2. Cancer statistics document very high levels of cancer around Limerick



  • NRC approved Exelon’s relief request exempting Limerick’s pumps from  Inservice Testing (IST)
  1. This exemption excuses Limerick’s pumps from the new testing requirement of the American Society of Mechanical Engineers (ASME)
  2. NRC based its approval of the exemption on its conclusion that the alternative (no testing) will provide “an acceptable level of quality and safety” (the public’s definition of acceptable quality and safety may differ from NRC’s)



  • ACE filed an objection to NRC’s proposed deregulation of radiation exposure, contending that deregulation might remove accountability and liability for routine and accidental radiation releases from Limerick Nuclear Plant.
  1. At issue was NRC’s proposal to claim that radiation exposure is beneficial to humans
  2. However, some radionuclides produced by Limerick’s fission process are man-made and not found in nature, like Iodine 131 and Strontium-90 and the effects of Limerick’s radiation are not known, nor is the cumulative, additive, and synergistic effect on health fully understood


  • NRC issued a Limerick violation for inadequate procedures resulting in exceeding structural and seismic concrete block wall adequacy for storage of Emergency Diesel Generator switchgear, circuit breakers, and ground trucks
  1. This was more than minor because it interfered with equipment availability for preventing core damage in an emergency
  2. NRC reviewed Exelon’s responses regarding Exelon’s response to this violation



  • A fleeting equipment malfunction caused an unplanned shutdown during startup.



  • Post-Fukushima, Limerick has not instituted NRC’s recommendations yet, and unlike Fukushima, Limerick is not situated beside an ocean, but has an anemic river augmented by the water pumped in from the Wadesville Mine Pit.
  1. Meanwhile, five years after its meltdowns, Fukushima officials haven’t stopped Fukushima from leaking.
  2. So officials have approved the activation of a one-mile long wall of refrigerated pipes dug 100 feet underground around Fukushima in the hopes that the soil around the plant can be frozen, confining radiation to Fukushima’s melted reactors
  3. If an accident happened at Limerick, the consequences to the Greater Philadelphia Region, Pennsylvania and the nation would be catastrophic, in terms of death, and/or  impaired health, loss of environmental resources and economic devastation,
  4. It hardly seems worth using Limerick as an energy source that has been proven to be such an enormous and unnecessary risk in terms of the safer, cheaper, cleaner alternatives  available currently that could form the basis for a more sustainable energy policy


Evidence Refuting NRC’s Assessment of Limerick Nuclear Plant’s 2015 Performance



  • In 2015, NRC documented several Limerick accidents that had significant potential to lead to core damage as “green” and “of very low safety significance.”
  • The public risk that is part of Limerick operations and accidents leads to questions about NRC’s public announcement that in 2015:
  1.   “Overall, LGS operated in a manner that preserved public health and safety”
  2.   Limerick “is moving along on vent installation and other post-Fukushima work we required.”  (Mercury, 3-8-16)


FIRE: 4-5-15

Fire broke out close to the motor-controlled pump that operates one of Limerick’s water systems to prevent core damage.

  1. NRC said the fire would not have occurred if Exelon had done adequate preventive maintenance
  2. NRC said the accident had the potential to lead to core damage.
  3. However, NRC only cited Exelon with a “green Non-Cited Violation (NCV) of very low safety significance” in the safety inspection report
  4. In public statements released on April 6, 2015, NRC and Exelon gave different accounts of the fire:
    • NRC: the fire was in one of the security buildings
    • Exelon: the fire was in an electrical panel in the reactor building
    • NRC: the Unit 2 reactor was at 82% power, shutting down (for refueling)
    • Exelon: both units were at full power
    • NRC: the High Pressure Coolant Injection (HPCI) system that delivers water to the core was damaged and needed repair
    • Exelon: Limerick’s on-site fire brigade put out the fire within eight minutes


  1.  How does NRC justify that an accident with the potential to lead to core damage is “green and of very low safety significance”?
  2.  Did NRC examine its own actions to see if they contributed to this fire?   On 12-29-14, NRC changed a Unit 2 regulation because Unit 2 couldn’t comply with it. When it became apparent that, despite the change, Unit 2 still couldn’t comply, NRC proposed a send revision. NRC announced its proposal, not in the Federal Register as customary, but in the Mercury Classifieds, 2-16-15, because this was an emergency and if NRC didn’t act quickly, it would have to shut Unit 2 down.
  3. Does NRC see any correlation between its lax regulatory enforcement and Exelon’s pervasive lack of maintenance?


A tank of radioactive water overflowed exposing personnel and the Unit 2 reactor building to a high level of radiation, requiring decontamination of building and personnel

  • During Radioactive Waste Clean Up, an alarm signaled that the level of radioactive water in a tank was high
  • The alarm was ignored and the tank overflowed
  • The overflow backed up the floor drain system and radiation levels rose.
  • The Unit 2 reactor building required decontamination
  • Personnel required decontamination, but one of them tracked radiation around multiple levels of the facility where other people were not required to have radiation-protective clothing.
  • NRC cited Exelon with a “Green, Non Cited Violation (NCV) because this was a violation of very low safety significance” which seems excessively lenient, given the magnitude of the risk.


  1. How long did it take before the two personnel were decontaminated, if one, whose “shoe contamination was 65 mrad/hr,” had time to walk around multiple floors of the facility?
  2. As a result of decontaminating Unit 2, was any radiation released into the Schuylkill River or into the air?
  3. Why did Exelon not initially remedy the potential for overflow, as it did after the accident, instead of instructing personnel to ignore the alarm?



Radiation rose as water covering fuel assemblies accidentally drained out of a dry storage cask

  • On July 7th workers began decontamination and preparation of one of the casks loaded with spent fuel to prepare it for on-site storage.
  • Workers followed instructions to pump 25 gallons of water out of the cask and then stop the pump.
  • Because there was no instruction to close the drain valve after stopping the pump, radioactive water continued to drain out of the cask
  • For 90 minutes, no one noticed the water accumulating on the floor.
  • At about 12:00 a.m. on July 8th, a technician noticed Unit 2’s radiation level rising
  • The technician alerted the floor supervisor, who discovered the radioactive water on the floor.
  • 231 more gallons of radioactive water had drained out of the cask, exposing the upper parts of the spent fuel assemblies to  the air
  • NRC issued a Non-Cited Violation (NCV), stating that Exelon had not followed NRC’s code of Federal Regulations: Exelon did not provide complete procedural instructions


  1. What alerted the RP technician to the rise in the level of radiation?
  2.  Why didn’t any one notice the 231 gallons of water accumulating on the floor for 90 minutes?
  3.  During the unclogging of the drain and decontamination of the building and personnel, was any radiation released into the Schuylkill River or into the air?


Exelon, an electric company, should have had no difficulty immediately restoring all the flashing lights on both Limerick’s cooling towers in 2015, yet Exelon failed to do so.

  • Limerick’s cooling towers are 507 feet high, and FAA considers anything over 200 feet high a height safety hazard without continuously flashing, high-intensity lights, day and night.
  • The only reason Limerick’s cooling tower height was waived as a safety hazard during Limerick construction was the promise that they would have the continuous flashing lights
  • At no time during 2015, were all the cooling tower lights operating at the same time.
  • Limerick is required to have its lights on because it is only about a mile from a public access airport, yet there have been times when there were no lights on at all for as long as 6 months at a time.
  • Lights were out on both towers for at least 24 days around the 2015 Thanksgiving holiday, a time of increased air traffic flow in and out of the airport.
  • On 12-10-15, Exelon announced the “flashing beacon” on top of Unit 2 had been restored to service and that repairs had been completed on 12-2-15 (Mercury)
  • Exelon stated that the problem on Unit 1 was on the top of the tower and repairs were scheduled for Spring refueling.


  1. With the completion of spring refueling, why has Exelon only been able to restore three meager lights on a portion of Unit 1?
  2. Why have the lights been out on Unit 2, after Exelon’s announcement on 12-10-15 that the lights had been restored?
  3. How can it be that Exelon, an electric company, can’t even fix its own lights?


It is beyond negligent for NRC to report, as it did, that Limerick “is moving along on vent installation and other post-Fukushima work we required.”  (Mercury, 3-8-16)

  1. By 2015, Exelon had made a mockery of NRC’s 2012 Post-Fukushima’s safety recommendations by not physically fulfilling any of them.
  2. Despite NRC’s 2012 request for compliance without delay, Exelon’s  2015 report for Limerick  showed that “plans” weren’t even complete by 2015, and some issues will only be in the planning stage by 2019.
  3. Examples of dangerous delays and eliminations of NRC’s 2012 post-Fukushima recommendations as of 2015:
      • Vent installation delay  -  no workable plan for installation as of 2015
      • Elimination of filters from the vent delayed installations despite NRC staff stating, “Vents without filters become radioactive hoses into the sky. Vents are vital, regardless of the cost to the industry.”
      • No installed spent fuel pool instrumentation as of 2015, despite the risk of pool meltdowns
      • No Limerick-specific seismic update as of 2015.
      • Unreasonable delay in seismic “study” until 2019, despite earthquake fault fractures under Limerick’s reactors, fuel pools, control room, turbine building, and rad-waste building.

By 2015, the public had, for three decades, been repeatedly exposed to Limerick’s routine and accidental radiation releases and cooling tower pollution. Exelon failed to:

      • Filter discharges into the Schuylkill River, a vital drinking water source for millions of people
      • Notify the public promptly of increased radiation exposure due to accidents, such as the 15,000 gallons radioactive water into the Schuylkill River on 3-19-12 that was not announced to the public for 23 days
      • Stop using high-burn fuel (up to 30% more radioactive gas releases)
      • Filter Limerick’s massive, toxic cooling tower pollution into the air
      • Clean up water and soil from Limerick’s radioactive spills


  1. Why, after NRC’s 2012 post-Fukushima recommendations, has NRC not required a Limerick-specific seismic study to more protectively prepare Limerick for post-Fukushima safety-related upgrades that could protect the public from Limerick’s increased seismic risks?
  2. Why did NRC allow Exelon to eliminate filters, when without filters, the public is at increased risk for radiation exposure?
  3.  Why did NRC allow the use of high-burn fuel in 2015 at Limerick when increased radiation risks will increase harms to Limerick’s dense population in the Greater Philadelphia region and increases Limerick’s risks associated with Limerick’s on-site-storage of log-lasting, high-level,   radioactive waste?

Not Surprising! NRC Killed Its Cancer Study



© 2015 The Mercury (

NRC Fails To Protect Public From Nuclear Plants

NRC killed its study on cancer in populations near nuclear plants (The Mercury AP article Sept. 10).

Not surprising! The impossibility of hiding the undeniable truth about increased cancer around nuclear plants is the real reason NRC killed its study.

Many studies already documented cancer increases around nuclear plants in Europe and the U.S., including around Limerick Nuclear Plant.

NRC has powerful self-serving reasons not to disclose the damning reality. NRC lies about nuclear plant radiation and our cancer risks to protect the nuclear industry and their own jobs. Admitting the truth would trigger a public outcry, forcing Limerick and other nuclear plants to close. NRC officials would lose their jobs, with nothing left to regulate.

NRC wasted $1.5 million and over five years developing strategies to disguise the truth. Despite initial independent efforts to stop NRC from distorting reality, its cancer study methodology remained fatally flawed. See:

NRC intentionally designed this whitewash to support NRC’s unsubstantiated, industry-biased, absurd position that radiation releases from nuclear plants aren’t harmful.

NRC officials should be ashamed:

1. NRC first falsely claimed no radiation escapes

2. Next, NRC admitted radiation is released, but made unsubstantiated claims that it’s not harmful

3. Now, NRC is shockingly considering an industry inspired scheme to claim, “a little radiation is       good for you.”

Why? To eliminate liability and minimize industry costs associated with radiation harms, evacuation planning and decommissioning.

John Gofman, a medical physicist, warned over 40 years ago that nuclear power kills. He said, “The evidence on radiation producing cancer is beyond doubt. It is not a question anymore: radiation produces cancer, and the evidence is good all the way down to the lowest doses.”

Physicians For Social Responsibility and The National Academy of Sciences report stated there is no safe level of radiation exposure. Continuous low dose radiation exposure is just as harmful as one high-level dose. See – Section #3 Radiation – No Safe Dose.

We never believed NRC would release a study showing nuclear power’s true harmful health impacts.

For years, NRC ignored documented shocking cancer rates, especially in children, around Limerick Nuclear Plant. ACE repeatedly informed NRC, yet Limerick wasn’t one of six nuclear plants included in NRC’s cancer study. Written comments on NRC’s cancer study were also submitted by ACE on May, 18, 2012 and during a national cancer study phone meeting on Dec. 11, 2013.

Since 2000, ACE investigated the link between Limerick Nuclear Plant’s radioactive releases and our shocking skyrocketing cancer increases, far above the national average. (Pa. Cancer Registry and CDC data 1985 to early 2000s). Links are clear. Childhood cancer rates near Limerick spiked to 92.5 percent higher than the national average by 1999. RPHP’s tooth study showed high levels of Strontium-90 radiation in our baby’s teeth. SR-90, not found in nature, was released from Limerick into our environment since 1985. ( Section#2, Cancer – Skyrocketing Increases: Links to Limerick)

Limerick’s radioactive releases end up in our drinking water, soil, food and people. Most impacted: fetuses and children. Additive, cumulative and synergistic impacts were never accurately determined. NRC has no accurate idea how much radiation Limerick released over the past 30 years, nor actual resulting health harms. ( Section#1, Radiation – Limerick’s Routine Releases)

NRC does no radiation monitoring, yet absurdly claims releases are small. Exelon, with a vested interest in the outcome, controls all radiation testing and reporting. Deception includes:

• Over 100 radionuclides are released, yet not continuously monitored and reported in real time.

• Radiation spikes are hidden using averages, estimates.

• Examples: Limerick’s unreliable radiation monitoring. Up to 36 percent margins of error (radioactive gases) make reports unreliable. Radiation monitor for a vital drinking water resource was inoperable for over a year. Limerick violates Safe Drinking Water Standards with impunity, sometimes drastically.

Radiation releases will increase with use of high-burn fuel and aging. If you want Limerick closed to protect you and your family, e-mail

Dr. Lewis Cuthbert

ACE President

Time To End Taxpayer Funding Of NRC

Time to End Taxpayer Funding of NRC

How much is your life worth? Not much, according to the NRC.

Why? Because NRC reduces the incalculable worth of a human life to a low-balled monetary amount on paper that compares human lives to the costs of installing the most effective, protective safety systems and equipment available at Limerick Nuclear Plant.

From all the evidence we’ve seen, it’s apparent that NRC’s aim is not to protect the public, but to protect nuclear industry profits.  NRC provides nothing more than an illusion of safety. NRC’s assurances that Limerick Nuclear Plant is safe are as stale as old cigarette ads.

NRC’s budget for 2016, which has been submitted to Congress, shows that $122 million (about 10%) comes from the taxpaying public. The bulk of NRC’s budget (about 90%) comes from the nuclear industry that NRC is supposed to regulate.  This creates an undeniable conflict of interest.

The problem is that NRC continually weakens its regulations to benefit Exelon, despite Limerick’s obvious increasing risks to public health and safety.  Exelon requests that regulations be changed or eliminated and NRC always complies.  Regulations at Limerick have been drastically weakened through exemptions, exclusions, amendments, deferments, delays, relief from inspections, and experiments.

In essence, NRC’s weakening of Limerick’s regulations is a service NRC provides which allows Exelon to cut corners and avoid costs.  NRC should never have allowed Exelon to substitute a list of plans and commitments instead of the testing of Limerick’s aging equipment and systems to prove that they work, as required for Limerick relicensing.

When citizens want to express objections to NRC’s reckless decisions and actions, NRC offers the public NRC’s dead-end petition process, a total farce.  NRC has never ruled in favor of any petition filed against Limerick. Just over the past four years, for example, NRC dismissed the following petitions, in spite of the valid issues they raised:

  • A petition from the National Resources Defense Council (NRDC) requesting an updated Severe Accident Mitigations Alternatives (SAMA) for Limerick
  • Petitions from several nuclear engineers warning that Limerick’s reactors may fail.

On May 21, 2015, NRC held its annual open house stating that NRC would respond to public questions about Limerick’s 2014 performance. NRC discouraged public participation by:

  • Giving short notice in the local paper (the same day that the meeting was scheduled)
  • Holding the meeting the day before a long holiday weekend
  • Holding the meeting from 5:00 p.m – 6:30 p.m., inconveniently dinner time for most families

Despite the fact that NRC’s open house was about NRC’s assessment of Limerick’s 2014 operations, No  NRC resident inspector who worked at Limerick in 2014 was in attendance. Instead, new 2015 resident inspectors were there, but they said they knew nothing about Limerick’s 2014 inspections and appeared to be woefully ignorant of Limerick’s inherent defects.   This repeated tactic allows NRC to avoid accountability to the public.

Of utmost concern is NRC’s irresponsible refusal to test the surveillance capsules from Limerick’s defective reactors for embrittlement.  At the open house, NRC officials absurdly defended NRC’s previously stated decision to test another nuclear plant’s reactor surveillance capsules to determine Limerick’s reactor embrittlement status and associated risk to the public. Limerick’s reactors have been operating for 30 years. Would you have confidence that your 30 year-old car is safe to drive based on the inspection of someone else’s car?

NRC’s conflict of interest results in unprotective decisions about Limerick that can lead to meltdowns and widespread devastation in which the public would lose everything.  NRC should value public safety over Exelon’s profits, but its actions show that NRC doesn’t care about public safety.

Maybe it’s time to end public taxpayer funding of NRC and ask Congress to reject NRC’s budget proposal of $122 million of taxpayer money.

Betty and Charlie Shank

2461 E. High Street, Unit F-28

Pottstown, PA 19464

(610) 323-6715

Limerick Nuclear Plant Is Not Protected Against Tornado/Wind Hazards

Limerick Nuclear Plant Is Not Protected Against  Tornado/Wind  Hazards

Heads should roll at NRC.  NRC is allowing Exelon to delay and even avoid costs for minimizing Limerick Nuclear Plant meltdown risks, despite the fact that the Greater Philadelphia Region could become a dead zone for generations and millions of us could lose everything if Limerick melts down.

NRC is negligently allowing Exelon to use stall tactics to avoid finalizing procedures to insure all Limerick’s emergency equipment can remain deployable after a tornado to minimize risk of meltdowns.  No strategies exist for deployment path debris removal at Limerick.  This is unacceptable.

NRC’s own 3-17-15 Audit Report states that Limerick’s equipment storage configuration is NOT considered to be reasonably protected against “tornado wind/missile hazards” and that Exelon still has “NO PLAN” completed for compliance.

To allow Exelon to get away with not immediately insuring Limerick’s access or use of necessary emergency equipment in a tornado wind/missile hazard is regulatory malpractice by NRC. Tornadoes occur in our region.  Risks are increasing.  Just within three weeks in 2015 (late June to early July),  three tornadoes occurred in our area.  Tornado watches and warnings have become frequent.

Examples include:

  • 7-10-15:  The National Weather Service confirmed that three tornadoes touched down in PA, including one that ripped off the roof of an elementary school in Berks County.
  • 7-1-15:  The National Weather Service confirmed an EF-1 Tornado touched down in Honey Brook, Chester County.
  • 4-20-15: A Tornado watch was in effect for Montgomeryand Chester Counties.
  • 7-27-94: A DEADLY TORNADO STRUCK PARTS OF LIMERICK TOWNSHIP (Near Limerick Nuclear Plant), killing an infant and her parents and destroying property.
  • It was reported that a tornado blew off the roof of the NRC building in King of Prussia.

FEMA’s website states that citizens should pledge to prepare for tornadoes, calling them nature’s most violent storms.   So why isn’t FEMA telling NRC to require Exelon to immediately prepare the Limerick site against tornado/wind hazards?   Tornadoes can develop so rapidly that there can be little, if any, warning.   FEMA states that a tornado damage path can be in excess of one mile wide and 50 miles long.  That could encompass most of Limerick Nuclear Plant’s 600 acre site.  FEMA says a tornado can cause fatalities and devastate a neighborhood in seconds.  Devastation could be catastrophic if a tornado triggers meltdowns at Limerick.

Four years after Fukushima meltdowns (March 2011), Limerick’s meltdown threats have increased dramatically, yet NRC has failed to require Exelon to complete any of NRC’s March 2012 Post-Fukushima orders to avoid meltdowns.  Examples:

  • No filtered vents to minimize radioactive fallout
  • No fuel pool instrumentation to immediately identify loss of vital cooling water
  • No way identified to minimize and/or eliminate growing risks for earthquake-triggered meltdowns Examples of Limerick’s unprecedented risks from earthquakes include:

Limerick’s reactors, fuel pools, rad-waste building, turbine building, and control room are all built directly on top of earthquake fault fractures

Four other earthquake faults within 17 miles of Limerick

Massive fracking in PA and surrounding states can trigger earthquakes.  This dramatically increased Limerick’s risk for meltdowns, especially from disruption in any of the miles of vital pipes and cables under Limerick needed to transport water and power to prevent meltdowns.

Given such extraordinary risks to the public’s health, safety, and financial interests, NRC should require Exelon to take immediate action to insure that all Limerick Nuclear Plant’s emergency equipment remains deployable during a tornado/wind hazard event and require Exelon to comply with all NRC’s 2012 Post-Fukushima recommendations to prevent meltdowns.

Every local, state, and federal official in the Greater Philadelphia Region should pressure NRC to require Exelon to take all immediate precautions to prevent meltdowns.   If you agree, contact ACE at  For more information on details about Limerick’s threats to our region, visit

Dr. Lewis Cuthbert

ACE President


NRC’s Reckless Disregard For Health And Safety Is Shameful

NRC’S Reckless Disregard For Health And Safety Is Shameful

“Safety is NOT a primary concern of NRC”.   If NRC’s primary concern was safety, NRC would be closing Limerick Nuclear Plant as soon as possible.

NRC has in fact shown reckless disregard for the consequences of Limerick Nuclear Plant operations on the people in the Greater Philadelphia Region.

Despite ACE’s repeatedly expressed public concerns on a broad range of unprecedented health and safety issues related to Limerick, NRC’s responses have shown that NRC REALLY DOESN’T CARE ABOUT HEALTH AND SAFETY.

NRC’s reckless disregard is identified by inaction related to Limerick’s threats and harms below:

  1. More Radiation Releases from Limerick Using High-Burn Fuel
  2. Radioactive Contamination of Vital Drinking Water Resources
  3. Depletion And Pollution of Drinking Water for Almost 2 Million People From Pottstown To Philadelphia
  4. Massive PM10 Air Pollution (More Deadly Than Ozone) from Limerick’s Cooling Towers
  5. Faster Corrosion Of Equipment and Systems Than Estimated
  6. Unprecedented Earthquake Risk Could Result in Fukushima-Like Multiple Meltdowns
  7. Tons of Deadly High-Level Radioactive Wastes Piling Up On-Site, In Our Back Yard, with No Long-Term Safe Solution
  8. More Dangerous High-Level Radioactive Waste Storage and Transport from Using High Burn Fuel
  9. Limerick is Less Safe Four Years After Fukushima.  NRC Failed to Require Exelon Comply With NRC’s Post Fukushima Recommendations To Minimize Meltdown Risks.
  10. Inadequate Safeguards Against Terrorists Air Strikes, Missiles, Drones, and Cyber Attack Threats
  11. Derailment and/or Explosions from Crude Oil Bomb Trains Traveling Through the Limerick Site

Costs to Exelon always trump public safety in NRC decisions. Exelon is making a mockery of NRC’s 2012 Post-Fukushima Orders to prevent meltdowns.

NRC is allowing Exelon to delay costs of compliance (for up to 7 years, maybe longer). That seriously jeopardizes the health and financial interests of millions of people in the Greater Philadelphia Region because NRC’s 2012 recommendations were about mitigating meltdown risks at Limerick.

Meltdown threats are increasing dramatically at Limerick from massive fracking that can trigger earthquakes, to tornado wind/missile hazards, and cyber and drone attacks.  Yet, Limerick’s Fukushima-like reactors are no safer now than before the Fukushima meltdowns in 2011:

  • Despite increasing risks for Limerick meltdowns, NRC allowed Exelon to avoid costs for radiation filters. In 2012, NRC’s own staff said these filters were imperative, regardless of cost to industry, because the vents installed to minimize explosions would become “radioactive fire hoses into the sky”.  Three years after NRC’s 2012 orders, Exelon still doesn’t even have plans completed for vents.
  • Despite increasing risk of earthquakes from fracking, and the unprecedented risk of meltdowns from Limerick’s reactors and fuel pools built with substandard cement directly over fault fractures, NRC is ignoring risks.  Four other earthquake faults are within 17 miles of Limerick.  Even the 8-23-11 Virginia earthquake jolted Limerick. Miles of Limerick’s underground pipes and cables vital to preventing meltdowns can be disrupted, yet are not actually inspected.  Often, NRC allows Limerick’s monitoring systems to remain inoperable for long periods of time, even over a year sometimes. NRC’s solution to Limerick’s unprecedented earthquake risks: Allow Exelon until 2019 to complete a “self-serving seismic study”.  Hardly risk reduction!
  • Despite increasing tornado risks, even in our region, NRC admitted in its 3-17-15 audit report that Limerick is not reasonably protected against the tornado wind/missile hazard.  Equipment needed to mitigate a tornado would not be available.

NRC’s PR people appear to be either uninformed or ethically challenged. NRC would close Limerick if they really care about our safety.  For more information see or e-mail

Rebuttal of NRC’s Op-Ed Claiming That Public Safety is its Priority

REBUTTAL of NRC’s Op-Ed Claiming that Public Safety is its Priority

NRC’s recent Mercury op-ed (4-19-15) is an outrageous deception. NRC is many things but it is not always truthful and it is not always humane. NRC’s decisions for Limerick have shown reckless disregard for public health and safety, despite NRC’s assertion that safety is its priority. NRC clearly puts Exelon’s profits before safety.

The sad reality is that for NRC, it’s all about allowing dangerous degrading nuclear plants like Limerick to continue operating, despite the risks and costs to all of us.

Things are so bad at Limerick that NRC is actually stonewalling the public.  Honest, direct answers are hard to come by.  After many e-mail exchanges with the NRC regional chief for Limerick, ACE tells us that it is still unable to get direct answers about dangerous situations and safety-related breakdowns in Limerick’s systems and equipment.  NRC’s chief went so far as to inform ACE that he doesn’t even want the public to e-mail NRC’s on-site resident inspectors with Limerick-specific concerns. Why does this NRC chief expect the public to contact only him when he appears to be a PR person with the goal of controlling Limerick information on behalf of Exelon’s interests, not public safety?  ACE found that Limerick’s on-site inspectors can provide more accurate and timely responses to serious concerns than anyone in the regional office.

NRC has NOT enforced its regulations at Limerick, which NRC’s op-ed stated that it has the authority to do.  Instead of  enforcing compliance, when rules or licensed conditions for Limerick are violated, NRC has weakened or eliminated its regulations, saving Exelon the costs of compliance.  We should all object to weakened safety at Limerick through NRC’s granting of exemptions, exclusions, experiments, amendments, dangerous delays, and reliefs (counting relief from inspections as compliance).  These tactics greatly jeopardize the health and financial interests of everyone in the Greater Philadelphia Region.

Limerick’s records show that its reactors were defective from the start and now, 30 years later, they are degrading faster than estimates predicted.  Our most recent concern is about the high number of Limerick scrams (planned or unplanned shutdowns), that can cause age-degraded defective reactors like Limerick’s to crack, leaking radioactive water from the core, which can lead to meltdowns. Testing on Belgium’s reactors confirmed our concerns about cracking: 16,000 cracks were identified in two reactors. Limerick’s reactors could have even more cracks.   A nuclear engineer filed a petition against Limerick due to Limerick’s high number of scrams and their impact on reactor embrittlement-induced cracking:

  • ACE identified 12 scrams in NRC’s own safety reports, just from February 25, 2011 to February 23, 2015.
  • On February 23, 2015 Limerick’s Unit 1 scram was due to a valve problem. TMI’s partial meltdown was caused by a valve problem.
  • On April 13, 2015, Unit 2 suffered back-to-back scramming events, which we haven’t seen before  (an unsuccessful planned scram followed by a manual scram).

Don’t let NRC tell you that Limerick is safe.  NRC’s conclusions about the safety of Limerick are dependent entirely on Exelon’s self-serving guesstimates and reports.  Exelon is making a mockery of NRC’s regulatory process as NRC ignores:

  • Unprecedented earthquake risks that increase Limerick’s meltdown risks
  • PA fracking that increases Limerick’s earthquake risks
  • Crude-oil “bomb train” tracks going through the Limerick site.  A derailment could trigger a Limerick catastrophe.
  • Cyber attacks and other terrorist threats that are increasing.

Don’t believe baseless NRC assurances that Limerick is safe.  The only way to minimize risks of meltdowns is to close Limerick.  If you agree, e-mail ACE at  For more information see

Betty and Charlie Shank

2461 East High Street, Unit F-28

Pottstown, PA  19464

(610) 323-6715


Limerick Can Be Closed Now, Despite Relicensing

Limerick Can Be Closed Now, Despite Relicensing

The Mercury (

URL: Top of Form

Relicensing Limerick Nuke Plant Ignores Safety Risks

Tuesday, January 27, 2015

It’s insanity for the Nuclear Regulatory Commission to allow Exelon’s Limerick Generating Station to operate a total of 60 years, yet that’s the result of NRC’s reckless rubberstamp relicensing. To relicense Limerick, NRC negligently weakened its regulations reducing public protections and long term plant stability.

NRC rigged the game and dangerously tilted the playing field. NRC makes the rules, breaks them, then weakens and remakes them to let Exelon slide to save money, despite potentially devastating consequences to millions of people in the Greater Philadelphia Region. This constitutes regulatory malpractice. We need and deserve a Congressional investigation on NRC’s negligent relicensing of Limerick.

Though Limerick is a radioactive time bomb, NRC allowed dangerous loopholes, exemptions, delayed actions, and license amendments. NRC irrationally allowed Limerick to operate another 30 years, despite Limerick’s profound vulnerability to accelerated corrosion and age-related deterioration of its systems and equipment. For decades taxpayers and ratepayers subsidized this fault-riddled nuclear plant, with its defective reactors and substandard construction, none of which can be fixed.

Limerick cannot be completely protected from a cyber or other terrorist attack that can cause Limerick to spew enough radiation into our air to cause us to lose everything. Yet, Exelon, profiting from this insane gamble, is almost entirely shielded from liability for the public’s health and financial losses resulting from Limerick meltdowns.

Instead of protecting our health, safety, and the environment, NRC denies reality to defend this dangerous, dirty, risky, deteriorating, corroding nuclear plant. For another 30 years we will have no real protection from:

• Radioactive poisoning of our air and water

• Massive dangerous PM-10 air pollution from the cooling towers

• Schuylkill River depletion

• Pumping toxic mine water into the river for Limerick operations

• Producing deadly radioactive wastes for which there is no safe solution

• Meltdown threats from cyber, air, and missile attacks by terrorists

• Earthquake fault fractures under Limerick’s reactors and fuel pools

The good news is, like Vermont Yankee Nuclear Plant, Limerick can still be closed now. Even though relicensed, Vermont Yankee was closed December 29, 2014. Vermont elected officials and dedicated activists worked together to get Vermont Yankee closed in order to protect public health, safety and the environment. Now, one less nuclear reactor threatens the U.S. with a Fukushima-like catastrophe.

If Exelon was compelled to comply with original NRC safety regulations, we believe Exelon may have closed Limerick due to costs required for meeting original NRC safer standards. In 2013, high equipment repair costs apparently led to the shutdown of two San Onofre reactors.

NRC’s middle management went to extraordinary lengths to nullify NRC staff’s own post-Fukushima safety recommendations and safety upgrades recommended for Limerick relicensing.

Our elected officials need to look at reality and stand up now to protect their constituents. Despite years of repeated ACE efforts to inform elected officials of Limerick’s unprecedented threats and harms, to date, our officials have chosen to ignore reality. We believe the lure of political contributions effectively silenced opposition to Limerick, despite undeniable unprecedented threats to the future of millions of people.

Silence protects Exelon profits, but allows us to continue to be victimized by Limerick Nuclear Plant operations. Our elected officials need commitment and courage to protect us like officials in Vermont and California, who had the political will to help close their nuclear plants.

Limerick must be closed now to minimize health threats, harms to the environment, and to prevent an avoidable catastrophe that would be devastating to all who live and work in the Greater Philadelphia Region and beyond.

We need our local, state, and federal PA officials to help close Limerick now. They need to hear from you. Ask them to review evidence compiled at or call (610) 326-2387 for a presentation.

In reality, Limerick’s electric can be replaced now with cleaner, safer, and cheaper electric that won’t threaten our health and lead to a catastrophe.

Dr. Lewis Cuthbert

President, Alliance for a Clean EnvironmentTop of Form

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© 2015 The Mercury (

Limerick Steps On The Gas, Driving Recklessly Toward The Cliff

Limerick Steps On The Gas, Driving Recklessly Toward The Cliff

The Mercury ( of Form

Limerick Plant Heading Over Catastrophic Nuclear Cliff

Thursday, January 15, 2015

Instead of relicensing Limerick Nuclear Plant, the NRC should have revoked its licenses to slow Limerick’s speed as it drives toward a potentially catastrophic nuclear cliff. But from the start, NRC bent its own rules and regulations so it could license Limerick, enabling PECO/Exelon to profit from Limerick’s nuclear energy at the public’s expense.

Limerick’s relicensing has been one of the most heavily contested in the nation. Limerick’s history has included a judicial ruling in favor of public safety concerns, local and national petitions, and individual objections leveled against Limerick, but all have fallen on NRC’s deaf ears. Although NRC claims it “considers” public concerns, in reality NRC just tosses aside evidence of deficiencies and threats to public safety and the environment.

NRC and Exelon don’t really have an incentive to stop Limerick from threatening the public because even if Limerick melts down, the Price Anderson Act caps Exelon’s liability to a miniscule fraction of the estimated trillion dollar cost for a Limerick catastrophe. Taxpayers will end up paying the lion’s share of the costs if Limerick melts down.

Taxpayers will also end up paying for storing Limerick’s massive amount of high-level radioactive waste, unfairly burdening future generations of taxpayers forever. Closing Limerick would end the production of this deadly waste.

Reports show that Limerick’s equipment is aging faster than hypothetical models calculated. Yet, NRC allows Limerick to continue speeding toward potential catastrophe, bending and eliminating inconvenient regulations that the public believes are the “rules of the road”. For instance:

∙ Despite Limerick’s already accelerated reactor aging, NRC irresponsibly approved a Limerick “power uprate”, the packing of its reactors with extra fuel rods, which means the reactors run hotter and as a result, degrade faster. This accelerates Limerick’s speed toward the nuclear cliff.

· The first of Limerick’s reactor components arrived on-site starting in 1972. They were defective upon delivery: earlier that year the same reactor design had caused a nuclear accident at another nuclear plant, exposing the design defect.

· Many of Limerick’s deteriorating systems, structures and components will be half-a-century old by the time its original licenses expire in 2024 and 2029. Limerick could go over the nuclear cliff before then.

When an NRC safety inspection report revealed accelerated corrosion in Limerick’s suppression pools, NRC staff recommended immediate recoating, but Exelon preferred not to. So in deference to Exelon, NRC irresponsibly allowed a delay of 10 years for recoating. This saved Exelon money in the short-term, but increased public safety risks.

NRC’s initial post-Fukushima recommendation to install vents with filters on both of Limerick’s defective reactors was meant to minimize public radiation exposure in a Limerick accident or meltdown. Filtered vents should have been imperative for Limerick from the start. NRC eliminated the requirement for filters from its recommendations to save Exelon money, even though vents without filters become a fire hose of radiation into the sky during a meltdown, exposing the public to massively increased radiation doses. Over eight million people live within 50 miles of Limerick, the second most densely populated evacuation zone in the nation. There have never been workable evacuation plans.

NRC even allowed Exelon to remove a critical safety test of its aging equipment from Limerick’s license renewal application, in spite of the fact that NRC told Exelon how dangerous it would be. Amazingly NRC relicensed Limerick untested.

It is worrisome that Exelon and its nuclear industry lobbyists control the NRC. The NRC should be in control of Exelon, not the other way around. However, it’s not too late for NRC to close Limerick, fulfilling its stated mission “to protect people and the environment.”

NRC could and should revoke Limerick’s licenses now, before Limerick runs off the nuclear cliff, taking the greater Philadelphia Region and beyond with it.

Betty and Charlie Shank


NRC’s Con Game for High-Level Radioactive Waste – Action Needed!









Waste Confidence Policy

Dry Casks vs Fuel Pools

Risks of Fire in Fuel Pools

       Waste Confidence and Climate




  • E-mail to:

If you don’t receive an automatic email reply confirming receipt, call 301–415–1677.

  • Fax comments to:   Secretary, U.S. Nuclear Regulatory Commission at 301–415–1101
  • Mail comments to:  Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555–0001, ATTN:  Rulemakings and Adjudications Staff.

The Mercury (

OP-ED: Shedding Light on NRC’s Nuke Waste Con Game

Friday, November 1, 2013

Evan Brandt’s article on Oct. 5, “Gov’t Shutdown May Delay Relicensing of Limerick Nuke Plant”, explained that NRC’s 2012 court-ordered spent fuel study would be delayed by the 2013 government shutdown. Actually, the government shutdown shed light on NRC’s nuke waste con game.

There is NO safe solution for radioactive fuel rods that can remain radioactive for a million years (EPA). They’re among the deadliest materials on earth. Yet, NRC’s “Nuclear Waste Confidence” game makes unsubstantiated claims that high-level radioactive wastes can be stored safely, soundly, and securely, virtually forever. This applies to nuclear plant sites like Limerick and allows them to continue producing and piling up deadly radioactive wastes under the absurd pretense that there is a safe solution.

Unthinkable devastating health and economic consequences threaten our future whether stored in fuel pools, above ground casks, from reprocessing, or from dangerous transport to a central location. NRC’s assumptions are far-fetched and negligent, including that dry cask storage systems, structures, and components can and will be entirely replaced once per century. NRC fails to identify astronomical public costs or where funds would come from for expensive massive replacements forever. NRC irrationally assumes society is willing or able to pay such costs, even if replacement is possible.

It was insanity for NRC to even consider relicensing Limerick Nuclear Plant when there is no safe solution for its deadly radioactive wastes.

Of greatest concern are Limerick’s fuel pools, already packed beyond design capacity, and dangerously vulnerable to meltdowns with potential for unthinkable health and economic devastation. Limerick’s two fuel pools hold more than two and a half times the amount of fuel rod assemblies (6,200) than four fuel pools at Fukushima (2,400) and far more than other older U.S. nuclear plants like TMI and Oyster Creek. NRC can’t or won’t tell ACE why.

With loss of fuel pool cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire. There is no endless source of water, but May 2013, Exelon was permitted to take unlimited amounts of public water from across six counties to deal with such a disaster.

· A 2003 study shows a fire in one spent fuel pool fire could release a radioactive plume that could contaminate eight to 70 times more land than Chernobyl and render about 95,000 square kilometers of land uninhabitable.

· A spent fuel pool disaster could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from Limerick. A 2004 study concluded that 44,000 near-term deaths could occur from acute radiation poisoning. People could die as far as 60 miles downwind (Philadelphia is just 20 miles downwind).

Limerick’s densely packed fuel pools are vulnerable to loss of water and meltdown through aging, accidents, natural disasters, and terrorist attacks. There is much cause for concern.

· Limerick’s roof-top fuel pools, located over reactors (like Fukushima’s), are five stories high with no outside containment. Devastating leaks could occur from terrorists’ missiles or air strikes, yet Exelon provides no protection against either.

· Limerick’s fuel pool liners are corroding and thinning at rates up to 10 times faster than anticipated. NRC staff called for immediate recoating, but Exelon was allowed to delay coating for over a decade.

· Cement originally used for Limerick’s fuel pools is substandard (verified by a Limerick quality control inspector), increasing risk for loss of water from an earthquake or terrorist attack.

NRC should close Limerick now to stop producing such deadly radioactive wastes and store it safer on site. For details: #9 “High-Level Radioactive Wastes: A Ticking Time Bomb.”

What can you do? Written public comments are being accepted by NRC before November 27 on NRC’s absurd Nuclear Waste conclusions. NRC needs to receive large numbers of public comments — by webform, email, snail mail or fax. Sample comments and addresses will be available at or from ACE at 610-326-2387.

ACE President 

The Mercury (

OP-ED: Spent Fuel Continues to Plague Nation’s Nuclear Power Plants

Tuesday, October 29, 2013

Evan Brandt’s story, “Gov’t Shutdown May Delay Relicensing of Limerick Nuke Plant” on Oct. 5 was timely. However, the delay in relicensing has not slowed Limerick operations. Every year that Limerick operates, it creates tons of high-level radioactive wastes, deceptively called “spent fuel.”

There is nothing “spent” about this high-level radioactive waste. It is one of the most deadly materials on earth. “Spent fuel” rods can cause cancer or genetic damage to an unshielded person who stands next to it after only 30 seconds. It can cause a lethal dose of radiation in just three minutes.

Massive amounts of this waste are stored on site at Limerick in fuel pools and above ground casks. On-site storage presents enormous risks to our entire region. Exelon would like to transport Limerick’s radioactive waste off-site to avoid liability, but transport presents astronomical health and financial risks to us and potentially all Pennsylvania residents.

Transportation of “spent fuel” has been dubbed a “mobile Chernobyl.” Even the DOE acknowledges that accidents will happen. It estimates that radiation releases from just one nuclear transport accident could devastate at least 42 square miles for generations.

Even at low speeds on road or rail, there could be truck or train accidents leading to catastrophic radioactive fires.

Transport is especially dangerous here in Pennsylvania where roads and bridges are “crumbling” (Governor Corbett’s description). Transporting nuclear waste on Pennsylvania’s inadequate infrastructure is simply immoral and unethical. The NRC estimated that just one transport accident or terrorist attack involving nuclear waste could cost the public as much as $2 billion.

Victims along the route would lose their homes, property and possessions. Homeowners insurance would not cover a radiation transport accident. In fact, even without an accident, it was reported that property values have already declined in five states along nuclear waste routes.

Local officials should have the right to say no to radioactive waste transport through their communities. Philadelphia, Bucks County and Falls Township officials have already said “no.” But the right of these officials to say no could be taken away by Harrisburg politicians who are being heavily lobbied by the nuclear industry to overrule local officials.

Transporting Limerick’s waste off site would present unacceptable risks to all Pennsylvania residents. Limerick has far more “spent fuel” on-site than Fukushima, even though Limerick has half the reactors. Once the spent fuel goes off-site, Exelon is no longer liable for it. As soon as it’s off-site we, the people, are required to assume liability for any radiation disaster involving transport.

Don’t let Exelon duck its liability for Limerick’s deadly radioactive waste by transporting it off-site.

Call Pennsylvania state senators and representatives. To protect your property values and homes, urge them to uphold the right of local officials to say “no” to the transportation of high-level nuclear waste (“spent fuel”) on Pennsylvania’s crowded and degraded infrastructure.

For more detailed information on high-level radioactive waste transport go to, and see #9 “High-Level Radioactive Wastes: A Ticking Time Bomb.”