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?

“Bomb Trains” Should Not Travel 1/8 Mile From Limerick’s Reactors And Fuel Pools

“Bomb Trains” Should NOT Travel 1/8 Mile From Limerick’s Reactors And Fuel Pools

BE AWARE!  100-car crude-oil “bomb trains” regularly travel just 1/8 of a mile from Limerick Nuclear Plant’s reactors and fuel pools.

Frequent railroad transport of millions of gallons of explosive, flammable, hazardous crude-oil, only 1/8 of a mile from Limerick’s reactors and fuel pools, must be stopped immediately.   A “bomb train” derailment, explosion, and enormous fireball could burn for days in an unstoppable fire with days of thick black smoke which could trigger catastrophic multiple meltdowns.

Limerick, already a ticking time bomb + a bomb train derailment = catastrophic disaster!!!  

Millions of victims in the Greater Philadelphia Region would face unprecedented catastrophic consequences to our life, property, and the environment.  We could lose everything – homes, businesses, jobs, and health.  Drinking water for almost two million people (Pottstown to Philadelphia) would become too radioactive/toxic for safe use.  Long-term ecological damage would leave ghost towns that can’t be cleaned up safely. Our entire region could become a toxic wasteland for generations.

Victims would not be compensated adequately for losses, if at all.  Who would pay to deal with irreversible devastation from crude oil explosions/fire plus massive radioactive contamination from Limerick meltdowns?  Bottom line:  no one!

  • NOT insurance companies that refuse to cover radiological accidents
  • NOT Exelon, with its government guaranteed limited liability protection
  • NOT the railroad industry, already fighting for exemption from strict liability for derailment damages
  • NOT Pennsylvania, already burdened with an enormous deficit
  • NOT the federal government, already trillions of dollars in debt and totally dysfunctional

Train derailment disasters should be anticipated.  Occurring with more frequency, incidents occurred in over 250 municipalities – ProPublica data 2011-2014.  The worst caused widespread evacuation, death, destruction of buildings, and loss of electric and drinking water.  A 2015 accident in West Virginia proved safer trains and slower speeds aren’t the answer.

No matter what claims the oil, rail, or nuclear industries make, there is no emergency plan that could effectively deal with a disaster of this magnitude within 1/8 of a mile of Limerick’s reactors and fuel pools.  Fire fighters and emergency responders shouldn’t be expected to be on the front lines of such dangerous uncontrollable disasters.

Safe evacuation is an absurd illusion!  Limerick Nuclear Plant’s emergency and evacuation plans are fatally flawed and unworkable.  To understand why – review the 8-part ACE video-blog series on Emergency and Evacuation Plans for Limerick’s radioactive plume at   This should be a wake-up call, especially for all responsible for emergency and evacuation planning.

“Bomb trains” regularly traveling through the Limerick site dramatically increase Limerick’s already unacceptable risk for meltdowns from Limerick’s dangerously lax fire safety requirements, reactor shutdown problems, deteriorating aging equipment and systems, cyber attacks, and earthquake faults directly under reactors and fuel pools with increasing risk of earthquakes from fracking.   A crude oil disaster on the Limerick site could be caused by terrorism.  Even the attempted emergency response would increase opportunities for terrorism.

Crude oil bomb trains should not travel within 1/8 of a mile from limerick nuclear reactors and fuel pools, or anywhere on the site.   It’s far too risky!

Hoping it doesn’t happen is not the answer.   Denial allows extraordinary risks to continue and increase.

Officials have expressed concern but there has been no meaningful action to avoid such devastation.  We should not face such risk or put our fire fighters and first responders in such dangerous circumstances.

Catastrophic disasters from crude oil explosions and fires near Limerick Nuclear Plant can and must be prevented with foresight and political will to face and eliminate this unnecessary risk.  Willful blindness jeopardizes our future.

SPEAK UP NOW!  Demand that community leaders and elected officials get the crude oil “bomb train” route moved now, no closer than several miles outside the nuclear plant border.

For detailed information compiled by the Alliance For A Clean Environment (ACE) see

Dr. Lewis Cuthbert

ACE President

“Bomb Trains” Should Not Travel Through The Limerick Site – Detailed Information

                                              BE AWARE!





  • Recent reports of crude oil derailment disasters show “bomb trains” keep exploding and turning into huge fireballs that burn for days, requiring miles-wide evacuations and resulting in devastating losses.
  • These unstoppable fires result in days-long thick black toxic smoke that are difficult, if not impossible to extinguish.
  • Crude oil trains travel frequently though Pottstown.  Officials expressed serious concerns. (8-18-15 AP).


  • Millions of people would lose their homes, businesses, and health.
  • Drinking water for almost two million people (Pottstown to Philadelphia) would become radioactive/toxic.
  • Long-term ecological damage would leave ghost towns that can’t be cleaned up safely.


  • NOT insurance companies that refuse to cover radiological accidents
  • NOT Exelon, with its government guaranteed limited liability protection
  • NOT the railroad industry, already fighting for exemption from strict liability for derailment damages
  • NOT Pennsylvania, already burdened with an enormous deficit
  • NOT the federal government, already trillions of dollars in debt and totally dysfunctional




Compiled By The Alliance For A Clean Environment (ACE)  November, 2015   (610) 326-2387  






Millions of people in the Greater Philadelphia Region face devastating risk from frequent railroad transport of millions of gallons of explosive, flammable, hazardous crude oil, only 1/8 of a mile from Limerick’s reactors and fuel pools.

Each shipment of explosive, flammable, hazardous crude oil traveling near Limerick’s reactors and fuel pools is estimated to contain:

  • 30,000 gallons in each rail car.  100 or more rail cars can contain over 3 million gallons.
  • Heat from the rupture and ignition of just one 30,000-gallon car can set off a chain reaction, causing other cars to explode, releasing a days-long fireball that is difficult, if not impossible to extinguish.  Basically, responders must let it burn out.

Train derailment disasters should be anticipated.  ProPublica data (2011-2014) reveals that incidents have occurred in over 250 municipalities.  Whole towns have already had to evacuate from crude-oil trains and fires.  No one should assume or suggest there will not be a crude-oil train derailment, explosion, and fire on or near the Limerick Nuclear property.

The worst of eight major crude oil train accidents and risks include:

  • A train derailment and explosion killed 47 and destroyed 30 buildings in Quebec.
  • 2,300 residents were evacuated in North Dakota. The fireball was observed several states away.
  • Serious crude-oil train derailments and fires are occurring with more frequency.  Many have occurred just since the beginning of 2015.
  • A fuel-oil train already derailed a few miles from Philadelphia.  Sixty-five tank cars bound for Philadelphia had loose, leaking, or missing safety components to prevent flammable, hazardous contents from escaping (Hazmat report – last two years).

Safer trains aren’t the answer.  A new train with a safer-design derailed in February 2015 in West Virginia, despite adhering to the speed limit.

  • Hundreds of families had to flee their homes in frigid weather
  • Burning continued for days
  • Drinking water and electricity were lost
  • Leaking crude oil poisoned the water supply
  • Fireballs erupted from crumbled tank cars, underscoring volatility of crude oil’s propane, and butane
  • Toxic water and dirt are difficult and very costly to attempt to clean up

Hoping it doesn’t happen doesn’t eliminate catastrophic risk!  Denial allows risks to continue and increase.

  • Richard Lengel, Pottstown’s Fire Chief, said in the Mercury 2-23-15, “If something catastrophic happens, there’s no municipality along the railroad that can handle it, the volume [crude oil] is too greatWe just have to hope that nothing happens, honestly.” 
  • The Pottstown Mercury 3-1-15 editorial got it right concluding, “Clearly, hope is not enough to maintain safety…”
  • No matter what claims the oil, rail, or nuclear industries make, there is no emergency plan that could effectively deal with a disaster of this magnitude within 1/8 of a mile of Limerick’s fuel pools.

Fire fighters and emergency responders shouldn’t be expected to be on the front lines of such devastating uncontrollable disasters.

  • Emergency responders are smart to be concerned.
  • Authorities say most fire and emergency departments are only capable of responding to a 9,000 gallon tanker truck incident, but DOT-111 crude oil cars hold 30,000 gallons, exceeding the response capacity.

Catastrophic disasters from crude oil explosions/fires near Limerick Nuclear Plant can and must be prevented with foresight and political will to face this unnecessary risk and take action.



  • Limerick has a history of chronic shutdown problems.  Publically available official reports show that Limerick’s reactors may not be able to be shut down safely in an emergency.
  • An explosion and days-long fire from a crude oil “bomb train” derailment could require immediate Limerick reactor shutdowns to avoid meltdowns.  This may not be possible.


  • Entire towns have been forced to evacuate after a bomb train disaster.  Limerick workers, including guards, so close to the disaster should certainly be evacuated for their own health and safety.  Yet, evacuation of Limerick workers could increase meltdown risks in Limerick’s 2 reactors and 2 fuel pools.
  • Limerick workers might be unable to access all necessary emergency equipment vital to preventing meltdowns, due to a crude oil explosion, massive heat, and extended days of thick black smoke.
  • Limerick’s control room would likely be impacted from days of thick black smoke.  Even Occidental Chemical’s vinyl chloride powder accidents (.7 of a mile from Limerick Nuclear Plant) caused Limerick’s operators to “button up” Limerick’s control room.   What would happen in days of thick black soot from a huge crude oil fire?
  • Extreme heat and soot could disturb the natural air flow needed for casks holding high-level radioactive wastes.  Blocked cask vents could go undetected in thick black smoke leading to overheating of the stored high-level radioactive wastes.


  • NRC weakened Limerick’s fire safety regulations, and still fails to enforce the weakened regulations.
  • Limerick does not use the safest fire barrier systems in all areas, to protect cables important to safe shutdown.  Even Limerick’s recent 4-5-15 fire in a reactor panel shows that Limerick is extremely vulnerable to fire that could lead to meltdowns.
  • Reduced fire safety at Limerick has new meaning in relation to days-long crude oil fires because Limerick’s fire barriers are only required to protect cables for 1 hour.
  • Without the safest fire barriers, fire detection and suppression systems, and spatial separations, Limerick plant stability is compromised. Fires can erupt in many ways at a nuclear plant.  Fires from crude oil bomb trains add significantly to Limerick’s risk of meltdowns due to fire.
  • Reactors and fuel pools need a constant supply of water to prevent meltdowns.  A crude oil fire could disable Limerick’s cooling water delivery system, resulting in simultaneous meltdowns in Limerick’s 2 reactors and 2 fuel pools.
  • Exelon’s liability limit encourages cutting corners to save money.


  • Evacuation of security guards could increase risk of a terrorist attack.
  • Terrorists could trigger a bomb train derailment,  initiating crude oil explosions and fires at any point along the lengthy rail track route on the nuclear plant site.





ACE’s evaluation of  Exelon’s fatally flawed 2012 “Evacuation Time Estimate (ETE) For Limerick’s Plume Exposure Pathway” is useless as a planning tool for safe evacuation

  • Exelon’s ETE is self-serving fiction riddled with inconsistencies and inaccuracies, fact-free spin, unsubstantiated suppositions and assumptions, illogical conclusions.
  • Exelon’s ETE is not realistic and must be rejected.

To understand why Limerick Nuclear Plant’s emergency and evacuation plans are fatally flawed and inadequate, we urge you to review the 8-part ACE video-blog series on Emergency and Evacuation Plans for Limerick at   It serves as a wake-up call to millions in the Greater Philadelphia Region about Limerick Nuclear Plant’s negligent emergency and evacuation planning:

  • ACE Analysis of Exelon’s Evacuation Time Estimate For Limerick’s Plume Exposure Pathway(Video / Blog Part 7)

This analysis reveals self-serving, unrealistic, unworkable fiction, with suppositions, inconsistencies, and inaccuracies, featuring fact-free spin with illogical conclusions.

  • Historic Fatal Flaws In Limerick’s Emergency – Evacuation Plans (Video / Blog – Part  6)
  • In 2012, NRC Pared Down Emergency and Evacuation Plans, Even After Fukushima  (Video / Blog – Part  1)
  • Calls For Immediate Notification And Expanded Evacuation and Ingestion Pathway Zones   (Video /Blog – Part 2)
  • The Truth and Consequences of Radiation Exposure From Nuclear Plant Accidents / Meltdowns  (Video / Blog – Part 3)
  • What Really Happened After Fukushima, Chernobyl, and TMI Meltdowns  (Video / Blog – Part  4)
  • Financial Injustice To The Public From A Radiation Accident / Meltdown  (Video / Blog -Part  5)
  • Until Limerick Closes, Changes That Must Be Made To Limerick’s Evacuation Plan, To Minimize Radiation Exposure Risks After A Limerick Radiation Accident and/or Meltdowns   (Video / Blog – Part  8)

In 1980 NRC publicly admitted that safe evacuation from Limerick was impossible.  NRC testified at Limerick’s 1980 public hearing that Limerick had double the population density for a safe evacuation.  NRC admitted that people within 30 miles would be harmed.  Things are far worse now, since the population around Limerick has increased dramatically in the past 35 years.

Thomas Sullivan, Montgomery County Director of Public Safety, testified at a public hearing for Limerick Nuclear Plant relicensing in 2011 that many local, county, and state roads used for evacuation that feed the local highways were no longer suitable for the amount of traffic that Limerick’s EPZ evacuation could produce.  Traffic conditions have worsened, yet in 2015 Thomas Sullivan, claimed, “Because of the Limerick generating plant, we have robust plans…” (Mercury 2-23-15), dismissing potential dangers associated with the transport of crude oil.  The serious problems and flaws with Limerick’s Emergency and Evacuation plans have been ignored by Mr. Sullivan and others.


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

Crude-Oil Bomb Trains Travel Through Nuclear Plant Property

Crude-Oil Bomb Trains Travel Through Limerick Nuclear Plant Property

The Mercury (


Saturday, April 25, 2015

The Mercury article of Feb. 23, “We just have to hope that nothing happens” has profound implications to everyone in the Greater Philadelphia Region. We applaud the March 1 Mercury editorial conclusion, “Clearly, hope is not enough to maintain safety…”

So-called “bomb trains” containing up to 3 million gallons of explosive, flammable, hazardous crude oil travel right through Pottstown and the Limerick Nuclear Plant Site. A derailment, explosion and days-long fire ball near Limerick’s reactors and deadly fuel pools could trigger simultaneous meltdowns with catastrophic radioactive releases. Millions of Greater Philadelphia Region residents could lose everything forever.

Days of thick black smoke from a crude oil fire could be devastating. Even Occidental Chemical’s large vinyl chloride accidents (seven-tenths of a mile from Limerick) caused problems at Limerick, according to employees, some of whom are very worried about crude oil train derailments.

Risks are increasing. Emergency responders are smart to be concerned. They shouldn’t be expected to be on the front lines of such devastating uncontrollable disasters.

Train derailment disasters should be anticipated. Sixty-five tank cars bound for Philadelphia had loose, leaking, or missing safety components to prevent flammable, hazardous contents from escaping (Hazmat report – last two years). A fuel-oil train already derailed a few miles from Philadelphia.

Heat from the rupture and ignition of one 30,000-gallon car can set off a chain reaction, causing other cars to explode, releasing a days-long fireball. Basically, responders must let it burn out.

Over 100 railcars, estimated to hold three million gallons, regularly sit on tracks from the Dollar General in Stowe to Montgomery County Community College.

ProPublica data from the federal Pipeline and Hazardous Materials Safety Administration (2011-2014) shows incidents in over 250 municipalities. The worst of eight major crude oil train accidents include:

• A train derailment and explosion killed 47 and destroyed 30 buildings in Quebec.

• 2,300 residents were evacuated in North Dakota. The fireball was observed states away.

Safer trains aren’t the answer. A new safer-design derailed February 2015 in West Virginia, despite adhering to the speed limit. Hundreds of families had to flee their homes in frigid weather. Burning continued for days. Drinking water and electricity were lost. Leaking crude oil poisoned the water supply. Fireballs erupted from crumbled tank cars, underscoring volatility of crude oil’s propane, butane, etc.

Safe evacuation from our densely populated region is an illusion. Limerick Nuclear Plant’s evacuation plan is unworkable and unrealistic, not robust as claimed by a health official. Just consider work hour traffic combined with deteriorated roads and bridges. We encourage officials to visit to view ACE’s 2012 video-blog series on the reality of Limerick’s evacuation plan. For a graphic presentation call (610) 326-2387.

Who pays to deal with irreversible devastation from train derailments and meltdowns? Clearly, not the oil industry, nuclear industry, railroad or government. We’d be on our own, despite:

1. Long-term ecological damage that would leave ghost towns that can’t be cleaned up safely.

2. Risking the vital drinking water resource for almost two million people (Pottstown to Philadelphia).

3. Millions of people losing their homes, businesses and health.

Richard Lengel, Pottstown’s Fire Chief, admitted, “If something catastrophic happens, there’s no municipality along the railroad that can handle it, the volume [crude oil] is too great. We just have to hope that nothing happens, honestly.”

Hope is no solution! Neither is denying the reality of our unacceptable devastating risks.

The catastrophic disasters we face can, and must, be prevented with foresight and political will to face the facts and take action. Enough of corporate profits jeopardizing public safety.

Wake up! Speak up! Tell local, state and federal elected officials to stop this insanity!

Say no to dangerous crude oil trains traveling through our communities and the Limerick site.

Say no to continued Limerick Nuclear Plant operations to avoid meltdowns that can be triggered by cyber/terrorist attacks, embrittled/cracking reactors, earthquakes and now oil-train explosions/fires.

— Dr. Lewis Cuthbert

ACE President

© 2015 The Mercury (



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

Bottom of Form

© 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


Limerick Relicensing Is A Big Mistake

The Mercury (

URL: of Form

OP-ED: Limerick Re-Licensing Is A Big Mistake

Tuesday, October 21, 2014

We strongly object to NRC’s preparations for re-licensing Limerick Nuclear Plant (Mercury, Sept. 2, 2014) because public safety has been given a backseat to Exelon’s economic interests. This is especially worrisome because NRC has drastically weakened its own regulations to re-license Limerick, despite Limerick’s aging systems and equipment which are plagued by corrosion, thinning, pitting, fatigue, erosion, leaching, embrittlement and stress corrosion cracking. The list of opportunities for disaster is endless.

Exelon’s records show that some monitors have been out of service at Limerick for more than a year. Automated systems have failed, discovered only after accidents occur. Public statements by NRC and Exelon following such incidents have failed to provide timely, accurate disclosure to the public. The result is that impacted residents have received no more respect than the Schuylkill River which is being destroyed by Limerick operations and the air that it is being polluted for Exelon’s profits.

NRC and Exelon have gone through the motions required for re-licensing, but it’s all for show. The enormous risks that our region faces from Limerick’s ever-growing high-level radioactive waste storage threats have been ignored by NRC. The Continued Storage Rule does not stop the production of Limerick’s high-level radioactive waste which remains lethal, virtually forever.

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 1980s 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.

We have learned that Limerick’s construction is substandard and that its reactors, fuel pools, control room, turbine building and radwaste storage building actually sit on top of open earthquake fault fractures, filled in with cement.

Exelon has made no secret of the fact that its first concerns are profits and investors. We have been reduced to pawns in a game of nuclear roulette. We get sick. Our drinking water supply is reduced and contaminated. Our air is polluted. And on top of that, we are forced to pay for Limerick’s business costs, as well as PECO/Exelon’s costly mistakes.

It would be the height of injustice for NRC to relicense Limerick Nuclear Plant and allow this corporate abuse to continue, when safer electric power has been proven to be viable and available.

The last step in relicensing depends on the decision of just one person, the director of the Office of Nuclear Reactor Regulation. We strongly urge that before making a final decision on relicensing Limerick, NRC’s director carefully evaluate Limerick’s unresolved and unfixable issues including:

  • Security concerns like terrorism and cyber attacks
  • Catastrophic earthquake risks due to Limerick’s substandard construction directly on top of fault fractures
  • Unprecedented water pollution and depletion of our vital drinking water supply
  • Lax fire standards
  • Lack of adequate water to deal with potential multiple meltdowns
  • The legal challenge by the National Resources Defense Council related to Limerick’s outdated SAMA.

Our politicians need to open their eyes and see that the safety of millions of people and our environmental future hang in the balance of Limerick relicensing. There is no need to live with so many risks when safer, cleaner, cheaper alternatives are viable, available, and could replace Limerick Nuclear Plant now. We urge all officials to call for the closure of Limerick to protect public interests.

— Betty and Charlie Shank


Terrorist Threats At Limerick Pose Catastrophic Risks

Terrorist Threats At Limerick Pose Catastrophic Risks

ACE wants a safer future for you and your family.

A 2013 Defense Department analysis said NO U.S. nuclear plant is protected against terrorist attacks, and all pose catastrophic risks.

We can avoid a Limerick Nuclear Plant catastrophe if our elected officials and government agencies stop dodging the harsh reality of risk and take action.

To insure a safer future we must transition to safer energy immediately, and close Limerick now before a terrorist attack triggers a meltdown which can be caused by loss of power and/or water.

Millions of people would suffer irreparable health harms from Limerick’s radioactive plume contaminating everything.

We would be financially ruined and permanently displaced. It’s insanity to allow that kind of unnecessary risk to continue.

After 9/11, ACE started investigating Limerick’s vulnerabilities to terrorism, plus security and evacuation problems. For details: #13 “Terrorists Threats: Precaution Is Inadequate” and Video Blog Series 1-8. The reality is alarming. It’s not fear-mongering to report it in hope of prevention.

On July 30, 2014, the Mercury printed Evan Brandt’s article, “NRC Mum about Security Problem at Limerick Nuclear Plant”. It’s unacceptable for NRC to withhold information about risks from those who would be most impacted by the consequences.

For a year following 9/11, taxpayers paid for Limerick’s air defense. Since then, NRC refused to require Exelon to pay for that, despite extraordinary risks from terrorists’ planes or missiles.. If a plane or missile crashed into a fuel pool, it could result in loss of water, meltdown, and fire.

One expert reported that a fuel pool fire could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site. “Spent fuel” rods (among the deadliest materials on earth) are jam packed in Limerick’s extremely vulnerable fuel pools, constructed with substandard cement and without extra containment walls. Like Fukushima’s, they’re directly above Limerick’s reactors.
On September 24, 2014, a PBS documentary, “Cyber Security, Rise of the Hackers”, revealed the reality of high-stakes cyber attacks. For example: the Stuxnet virus targeted an Iranian nuclear plant in 2010, destroying over 1,000 centrifuges before detection. Stuxnet, capable of spreading, could be a blueprint for cyber attacks on U.S. nuclear plants. Even a cyber attack on the grid could lead to extended loss of power and water, triggering meltdowns at Limerick.

Limerick security and NRC oversight are so lax that an Al-Qaida suspect worked undetected for 5 years (2002-2007) during Limerick re-fueling.

Inexplicably, in 2012, even after lessons from Fukushima, NRC pared down emergency evacuation planning for radiation exposure after meltdowns.

Nearly 8 million people live within 50 miles of Limerick, the evacuation zone that NRC recommended after Fukushima. Millions of people, in all directions, would suffer health harms, financial ruin, and permanent displacement, while Exelon would be liable for only a tiny fraction of the estimated one trillion dollar cost.

We can’t evacuate safely! No workable evacuation plan exists. Escape routes would be completely gridlocked.

The Montgomery County Planning Commission and the Department of Safety both warned NRC about inadequate infrastructure to support safe evacuation. Where would everyone go, with Philadelphia just over 20 miles downwind and downstream from Limerick?

The price of ignoring the public’s health and financial risks are incalculable, yet almost all our elected and agency officials have displayed callous disregard for the extraordinary terrorist threats we face related to Limerick Nuclear Plant and our future.

We can’t afford to elect more politicians like Tom Quigley, who took contributions from Exelon and publicly supported Limerick relicensing until 2049, despite ACE repeatedly informing him of irrefutable catastrophic risks, including terrorism.

Before voting 11-4-14, ask each candidate if they will help close Limerick now to protect your family.

We also encourage you to review just released 2013-2014 environmental voting records of PA state senators and representatives at