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

EVIDENCE REFUTING NRC’S ASSESSMENT 
OF LIMERICK NUCLEAR PLANT’S 2015 PERFORMANCE 
AND QUESTIONS THE PUBLIC SHOULD ASK

Introduction

  • 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)

SEVERAL 2015 LIMERICK SAFETY VIOLATIONS BELOW:

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

 QUESTIONS ABOUT LIMERICK’S FIRE:

  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?

OCCUPATIONAL RADIATION EXPOSURE AT LIMERICK: 6-28-15

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.

QUESTIONS:

  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?

 

OCCUPATIONAL RADIATION EXPOSURE AT LIMERICK : 7-7-15 and 7-8-15

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

QUESTIONS:     

  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?

UNIT 1 AND UNIT 2 COOLING TOWER LIGHTS: OUT DURING 2015

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.

   QUESTIONS:   

  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?

LIMERICK HAD FAILED TO MAKE ANY POST-FUKUSHIMA UPGRADES AS OF 2015.  

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

QUESTIONS

  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 www.acereport.org.   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 www.acereport.org.

Dr. Lewis Cuthbert

ACE President

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

                                              BE AWARE!

MILLIONS OF PEOPLE IN THE GREATER PHILADELPHIA REGION FACE CATASTROPHIC THREATS TO LIFE, PROPERTY, AND THE ENVIRONMENT.

OUR REGION COULD BECOME A TOXIC WASTELAND FOR GENERATIONS.

100-CAR CRUDE OIL “BOMB TRAINS” TRAVEL 1/8 OF A MILE FROM LIMERICK NUCLEAR PLANT’S REACTORS AND FUEL POOLS

“BOMB TRAIN” DERAILMENT, EXPLOSIONS, AND EXTENDED FIRES COULD TRIGGER DEVASTATING LIMERICK NUCLEAR MELTDOWNS, CAUSING MILLIONS OF GREATER PHILADELPHIA REGION’S RESIDENTS AND BUSINESSES TO LOSE EVERYTHING.

  • 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 VICTIMS WOULD FACE UNPRECEDENTED CATASTROPHIC CONSEQUENCES DUE TO THE COMBINATION OF LIMERICK NUCLEAR MELTDOWNS PLUS A CRUDE OIL DISASTER.  VICTIMS WOULD NOT BE COMPENSATED FOR THEIR DEVASTATING LOSSES.

  • 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.

WHO WOULD PAY TO DEAL WITH IRREVERSIBLE DEVASTATION FROM CRUDE OIL EXPLOSIONS/FIRE AND 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

TO AVOID CATASTROPHIC DISASTER COMMUNITY LEADERS AND ELECTED OFFICIALS MUST GET THE CRUDE-OIL “BOMB TRAIN” ROUTE MOVED NOW

EVERY CITIZEN MUST SPEAK UP TO COMMUNITY LEADERS AND ELECTED OFFICIALS, TO DEMAND THAT THE CRUDE-OIL “BOMB TRAIN” ROUTE BE MOVED NO CLOSER THAN SEVERAL MILES OUTSIDE THE NUCLEAR PLANT BORDER.

PLEASE REVIEW ATTACHED DETAILED INFORMATION

Compiled By The Alliance For A Clean Environment (ACE)  November, 2015

aceactivists@comcast.net    acereport.org   (610) 326-2387  

 

 

CRUDE-OIL BOMB TRAINS SHOULD NOT TRAVEL WITHIN 1/8 OF A MILE FROM LIMERICK NUCLEAR REACTORS/FUEL POOLS OR ANYWHERE ON THE SITE.   IT’S FAR TOO RISKY!

LIMERICK,  A TICKING TIME BOMB    +   A BOMB TRAIN DERAILMENT      =

CATASTROPHIC DISASTER!!!

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.

WHY CRUDE OIL BOMB TRAIN EXPLOSIONS AND FIRES ON OR NEAR THE LIMERICK NUCLEAR PLANT SITE CAN TRIGGER MELTDOWNS:

LIMERICK NUCLEAR PLANT IS ALREADY VULNERABLE TO CATASTROPHIC MULTIPLE MELTDOWNS.   LIMERICK HAS REACTOR SHUTDOWN PROBLEMS.

  • 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.

LIMERICK ISSUES RELATED TO THE CONSEQUENCES OF A BOMB TRAIN EXPLOSION FOLLOWED BY A DAYS-LONG FIREBALL PRODUCING THICK BLACK SMOKE:

  • 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.

LIMERICK’S DANGEROUSLY RELAXED FIRE SAFETY REGULATIONS

  • 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.

A CRUDE OIL DISASTER ON THE LIMERICK SITE INCREASES OPPORTUNITIES FOR TERRORISM.

  • 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.

A “BOMB TRAIN” DISASTER AT LIMERICK NUCLEAR PLANT MUST BE AVOIDED!

SAFE EVACUATION IS IMPOSSIBLE:

A CRUDE OIL TRAIN DISASTER TRIGGERING LIMERICK MELTDOWNS MUST BE PREVENTED

LIMERICK NUCLEAR PLANT’S EVACUATION PLAN IS UNREALISTIC, UNWORKABLE, AND DEFINITELY NOT “ROBUST”.

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 www.acereport.org.   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.

WILLFUL BLINDNESS IS JEOPARDIZING OUR FUTURE, ESPECIALLY WITH THE ADDED RISK FROM A BOMB TRAIN DISASTER

Higher Radiation Spikes Detected In Air near Limerick Nuclear Plant

 

Video Blog 1-14 

HIGHER RADIATION SPIKES DETECTED IN AIR NEAR LIMERICK NUCLEAR PLANT

The Alliance for a Clean Environment (ACE) documented radiation spikes in the air for several weeks, after being contacted by concerned residents November 22. 

  • Because radiation is routinely released into the air from Limerick Nuclear Plant, ACE believes Limerick is the obvious source, but the precise cause is unknown.

Average levels of airborne radiation near Limerick Nuclear Power Plant were found to be 20 to 30% higher than normal for several weeks in late November and early December. 

  • Measurement of airborne radiation levels January 6 showed elevated levels have continued.
  • All readings evaluated were taken at a site just four miles from Limerick.

ACE uses RadAlert 50 handheld devices made by International Medcom, to monitor airborne radiation levels on a per-minute basis.

  • This device is used by citizens near other U.S. nuclear plants.
  • A court ruling after the Three Mile Island meltdown ordered placement of 50 of the same devices at sites around Harrisburg to enable citizens to detect further meltdowns.  

Joseph Mangano, MPH MBA, a radiation health expert, examined the data collected by citizens and determined:

  • 11-22 to 12-4, 2569 minutes (nearly 43 hours) were recorded four miles west of Limerick. 
  • Average radiation count per minute (CPM) was about 20 to 30% greater than 15, the typical average.
  • December 2-4, 90 of 300 minutes (30%) were over 20.  Typically, only 2 to 3% reach 20 or more.
  • 31 CPM, the highest count, was more than double the normal level.
  • Unusually high patterns continue; 60 minutes were recorded January 6, 2014.  28.3% showed a level of 20 CPM or greater.

ACE contacted NRC 11-22-13 about higher radiation readings.  

  • After four days NRC finally responded, but failed to explain unusually high measurements.
  • NRC conducted NO MONITORING to attempt to examine citizen findings and to locate the source at Limerick.
  • Instead, NRC “reviewed” Exelon’s data and “looked” for a source of higher radiation levels.
  • The problem: NRC can’t see radiation and shouldn’t trust Exelon’s data.  See: www.acereport.org, # 20 “Why We Can’t Trust Exelon”.

NRC’s negligent oversight on our radiation risks from Limerick!

  • 36% margins of error allowed in Exelon’s reporting for Limerick’s radiation releases to air
  • Radiation monitoring equipment left inoperable for over one year
  • Radiation dose factors were omitted for the last five weeks of 2010.

NRC illogically attributed citizen radiation spikes in multiple locations to 1) natural radiation, and 2) electrical surges.

  • Naturally occurring radiation cannot account for weeks of radiation spikes, since natural radiation changes little over time. 
  • Electrical surges were not to blame, since citizen Rad-Alerts use batteries.

ACE believes radiation spikes are from Limerick starting to use high burnup fuel, which can release 2 to 3 times more radioactive fission gas. 

  • NRC has no credible evidence otherwise.    

Limerick’s aging, corroding, and deteriorating reactors, (already operating 24 and 29 years), could be leaking.

  • Radioactive leaks have become more common as reactors age.

Limerick’s radioactive releases can have harmful health impacts. 

  • Limerick produces over 100 radioactive chemicals.
  • Each is harmful to humans when ingested by breathing or via the food chain, raising the risk of cancer, infant mortality, birth defects, and other serious health disorders.
  • Since Limerick started operating in 1985, cancer rates skyrocketed around Limerick. 
  • Childhood Cancer was 92.5% Higher Than The National Average by the late 1990s
  • Strontium-90 was found in our children’s baby teeth, at some of the highest levels around nuclear plants
  • Thyroid Cancer Increased by a shocking128%.by the mid 90s
  • For Detailed Information:  www.acereport.org    ACE Website Downloads

#1 – Radiation  - Limerick’s Routine Releases

#2 – Cancer – Skyrocketing Increases: Links to Limerick

$3 – Radiation – No Safe Dose

Public Health Risks Could Be Reduced Through Awareness, With Minimal Costs.

  • The public has a right to know about higher radiation in their air. Residents could protect themselves with a radiation alert system, similar to the one for ozone: 
  • Citizen radiation monitoring networks should be funded by state or independent grants.
  • Citizen data could be reliably analyzed by the Radiation and Public Health Project, which currently analyzes electronic data from citizen networks around other nuclear plants. 
  • Montgomery and Chester Counties should establish county-wide alert systems to inform      residents when radiation levels are higher.Ask All Elected Officials To Support Funding For Citizen Radiation Monitoring And County Reporting (Similar to Ozone Alerts).
  • We need and deserve reliable radiation warnings, including for Limerick meltdowns.
  • Radiation risks can be reduced – For details on water filtration and more:              ACE Website Download – #4 Radiation – Reduce Risks

RECENT RAD-ALERT DATA ANALYSIS FROM RADIATION MONITORING BY CITIZENS WITHIN 4 MILES OF LIMERICK NUCLEAR PLANT

Appendix – Radiation Counts Four Miles West of Limerick Plant Since 11/22/13

Total                Minutes            % Mins.           Highest

Date     Minutes            >19 CPM        >19 CPM        Reading

11/22     420                       43                         10.2%                  30

11/23     —                         –                           —                        

11/24     681                       68                         10.0%                  31

11/25     —                          –                           —                         

Elected Officials Must Take Action To Protect Us From Limerick’s Harms Or Be Voted Out of Office

 

 ELECTED OFFICIALS MUST TAKE ACTION TO PROTECT US FROM LIMERICK

NUCLEAR PLANT THREATS OR BE VOTED OUT OF OFFICE

WE ARE AT A CROSSROAD!  AT STAKE:
PUBLIC HEALTH, SAFETY, AND FINANCIAL INTERESTS

 

  • Limerick Is Destroying Vital Drinking Water Resources
  • Limerick’s Radioactive Air Releases Add To Cancer And Other Health Risks
  • Limerick Systems Are Rapidly Aging, Corroding, and Increasingly Dangerous
  • There Is No Safe Solution For Limerick’s Deadly Radioactive Wastes
  • There Is No Safe Way To Evacuate Our Densely Populated Region If Limerick Has A Major Radiation Accident or Meltdown
  • Meltdown Risks Are Increasing!  Millions Could Lose Everything!  That Can Be Avoided If Limerick Closes Now. 

    ACE REPEATEDLY INFORMED ELECTED OFFICIALS

  1. In 2011, your officials failed to speak on the Limerick Relicensing public hearing record
  2. In 2012, your officials failed to speak on the public hearing record to protect our drinking water
  3. In 2013, your officials failed to speak on the record about Limerick’s environmental impacts

    ELECTED OFFICIALS’ SILENCE IS UNACCEPTABLE:

  • SILENCE ALLOWS THREATS AND HARMS TO INCREASE
  • SILENCE CONDONES NRC REGULATORY NEGLIGENCE
  • SILENCE PROTECTS EXELON PROFITS AT OUR EXPENSE

    ELECTED OFFICIALS WHO DON’T SPEAK UP NOW

    SHOULD BE VOTED OUT OF OFFICE!

    TO PROTECT PUBLIC HEALTH, SAFETY, AND FINANCIAL INTERESTS,

    LIMERICK NUCLEAR PLANT MUST CLOSE NOW:

  • Stop Limerick’s Radiation Releases Into Our Air and Water
  • Stop Depletion and Overheating of the Schuylkill River, The Vital Drinking Water Resource For Almost 2 Million People, Pottstown to Philadelphia
  • Stop Deadly Radioactive Waste Production. There Is NO SAFE SOLUTION!
  • Reduce Need to Evacuate.  We Can’t Evacuate Safely!
  • Reduce Meltdown Threats That Could Render The Entire Philadelphia Region Uninhabitable.  Millions Could Lose Everything They Own

    ELECTED OFFICIALS’ VOICES MAKE A HUGE DIFFERENCE!

    NUCLEAR PLANTS ARE CLOSING WHERE ELECTED OFFICIALS SPEAK UP

  • Nuclear Plants In California and Vermont Are Closing, In Large Part Because Their Elected Officials, Including State and U.S. Senators, As Well As Governors Spoke Out Against Risks And Harms To The Public From Their Nuclear Plants
  • In New York, Officials, Including Governor Andrew Cuomo and State Senators Have Pushed For Closure Of Indian Point, Citing Its Location Near A Major Population Center
  • Only U.S. Senator Bob Casey Expressed Public Concern About Evacuation Feasibility 

    YOUR VOICE AND VOTE ARE NEEDED 

    TELL FAMILY, FRIENDS, NEIGHBORS, AND ELECTED OFFICIALS WHAT IS AT RISK

    FOR DETAILS ON LIMERICK NUCLEAR PLANT’S THREATS AND HARMS

    WWW.ACEREPORT.ORG

  • TELL LOCAL, STATE, AND FEDERAL ELECTED OFFICIALS YOU PLAN TO HOLD THEM ACCOUNTABLE IN THE VOTING BOOTH FOR THEIR FAILURE TO SPEAK UP TO PROTECT YOUR FUTURE.

DECADES AGO ELECTED OFFICIALS FAILED TO SPEAK UP

NOW WE FACE LIMERICK’S UNPRECEDENTED THREATS AND HARMS

 

PUBLIC WATER SUPPLY SERIOUSLY JEOPARDIZED!

Limerick Nuclear Plant’s Devastating Assault On The Schuylkill River Is Slowly Destroying This Vital Drinking Water Resource For Almost Two Million People From Pottstown to Philadelphia. 

  • Elected Officials Knew Before Limerick Was Licensed That The Schuylkill River Could Not Sustain Limerick Nuclear Plant operations. They Also Knew Limerick Would Radiate and Overheat The River, Jeopardizing Public Health and The Ecosystem.
  • ELECTED OFFICIALS FAILED TO SPEAK UP IN THE 1970S AND 1980S TO STOP AVOIDABLE DESTRUCTION OF THIS VITAL PUBLIC WATER SUPPLY.
  • By 1999 The River Reached Record Low Flows. Limerick’s Cooling Tower Depletion Was A Major Factor.  By 2003, Exelon Asked To  Reduce and Eliminate Requirements In Place To Protect The River Water and to  Pump Massive Amounts of Toxic Unfiltered Mine Waster Into The River To Supplement The Flow To Operate Limerick.
  • AT THE 2012 PUBLIC HEARING, ONLY ONE LOCAL OFFICIAL, MICHAEL MOYER, OPPOSED LIMERICK’S UNPRECEDENTED THREATS AND HARMS TO PUBLIC DRINKING WATER.RADIOACTIVE WASTES THREATEN UNTHINKABLE DISASTER
  • There Is NO SAFE SOLUTION.
  • Transporting It Offsite Is Too Dangerous Due To Accidents and Terrorist Attacks
  • Storing It In Limerick’s Corroded and Thinning Fuel Pools Makes It Vulnerable To Devastating Meltdowns From Accidents or Terrorist Attacks 
  • The Only Solution – STOP MAKING IT. 
  • Until That Happens, We Must Store Existing Wastes On Site SAFER – In Above Ground Casks
  • ACE Repeatedly Informed Elected Officials About Extreme Threats We Face From Limerick’s Radioactive Waste Storage and Transport.   ACE Also Repeatedly Requested Officials To Comment to NRC In Support Of Recommended Actions For NRC’s Radioactive Waste Study
  • NOT ONE ELECTED OFFICIAL TOOK  ACTION TO PROTECT THE PUBLIC’S HEALTH, SAFETY, AND FINANCIAL INTERESTS RELATED TO LIMERICK’S LETHAL HIGH-LEVEL RADCIOACTIVE WASTES.SAFE  EVACUATION NOT POSSIBLE!
  • In 1980, Before Limerick’s Construction, NRC Admitted The Region Within 30 Miles Of Limerick Had Double The Population That Could Be Evacuated Safely
  • IN 1980 ELECTED OFFICIALS REMAINED SILENT AND ALLOWED  LIMERICK NUCLEAR PLANT CONSTRUCTION TO CONTINUE.
  • At The Same Time, In The 1980s, Based On Population Density and Impossible Safe Evacuation, New York Elected Officials Opposed Shoreham Nuclear Plant
  • NEW YORK OFFICIALS OPPOSED SHOREHAM NUCLEAR PLANT BASED ON INABILITY TO EVACUATE SAFELY.  SHOREHAM WAS CLOSED.
  • By 2010, Population Density Around Limerick Nuclear Plant Skyrocketed Over 4 Times Higher Than Could Evacuate Safely.
  • OUR ELECTED OFFICIALS STILL REMAIN SILENT ABOUT OUR INABILITY TO SAFELY EVACUATE, WITH THE EXCEPTION OF U.S. SENATOR BOB CASEY. 
  • Only Michael Moyer, an East Coventry Supervisor, had the courage and integrity to speak out on  behalf of public interests at the public hearing to relicense Limerick Nuclear Plant.LIMERICK’S RADIOACTIVE RELEASES INCREASE CANCER RATES, INFANT MORTALITY, AND OTHER DISEASES AND DISABILITIES. 

    HEALTH THREATS WILL CONTINUE AND INCREASE AS LONG AS LIMERICK OPERATES

  • Since 1985 Limerick released unknown amounts of radiation into our air, water, soil, food, milk, fish and bodies.  
  • Evidence of harm is clear.  Skyrocketing cancers have been documented since Limerick started operating, especially in children.  Infant and neonatal mortality rates became far higher than the state average, and even higher than Philadelphia and Reading.
  • The best way to reduce cancer rates and other health problems is to close Limerick to reduce radioactive releases into our air and water.
  • NOT ONE STATE OR FEDERAL OFFICIAL ATTENDED THE PUBLIC HEARING TO ASK NRC NOT TO RELICENSE LIMERICK, MUCH LESS TO CLOSE IT NOW TO PROTECT PUBLIC HEALTH, SAFETY, AND FINANCIAL INTERESTS.  SERIOUS SAFETY ISSUES ARE BEING IGNORED BY ELECTED OFFICIALS
  • Earthquake Faults – Under Limerick site.  4 others within 17 Miles
  • Reactors May Not Be Able To Shut Down To Prevent Meltdowns
  • Limerick Follows Lax Fire Safety Regulations
  • Substandard Cement in Reactors and Fuel Pools
  • Fuel Pools Corroding and Thinning At Rates 10 Times Faster Than Anticipated
  • Fuel Rods Taken From Pools Years Before Sufficient Cooling Tim

    CALL  OR  E-MAIL

    ELECTED OFFICIALS TODAY

    URGE THEM TO SPEAK OUT

    TO CLOSE LIMERICK NUCLEAR PLANT

    TO PROTECT

    YOUR HEALTH, SAFETY, AND FINANCIAL INTERESTS

     

    Contact as many elected officials as possible! 

    The list below does not include all elected officials who represent residents impacted by Limerick Nuclear Plant operations, but it is important for you to contact any elected official with constituents within 50 miles of Limerick Nuclear Plant.

    Governor Tom Corbett  (R)

    225 Main Capitol Building
    Harrisburg, Pennsylvania 17120

    Phone: (717) 787-2500     Fax: (717) 772-8284

    governor@state.pa.us

    High Street, Suite 100
    U.S. Senator Pat Toomey (R)
    8 Penn Center
    1628 John F. Kennedy Blvd. Suite 1702
    Philadelphia, PA 19103

    Phone: (215) 241-1090    Fax: (215) 241-1095

    mitch_vidovich@toomey.senate.gov   

     

    U.S. Senator Bob Casey  (D)

    2000 Market Street, Suite 1870
    Philadelphia, PA 19103

    Phone: (215) 405-9660  Fax: (215) 405-9669

    kurt_imhof@casey.senate.gov    

  • U. S. Congressman James Gerlach  (R)580 Main Street, Suite 4

    Trappe, PA 19246

    Phone   (610) 409-2780     Fax (610) 409-7988

    scott.savett@mail.house.gov

    U.S. Congressman Charles W. Dent  (R) PA-15

    701 W. Broad Street, Suite 200

    Bethlehem, PA   18018

    Phone (610) 861-9734            Fax (610) 861-9308   

    vincent.odomski@mail.house.gov

     

    U.S. Congressman Pat Meehan   (R)

    940 Sproul Road
    Springfield, PA 19064

    Phone: (610) 690-7323     Fax: (610) 690-7329

    Andrew.Colket@mail.house.gov 

    U. S. Congresswoman Allyson Schwartz  (D) PA-13

    Montgomery County Office
    706 West Avenue
    Jenkintown, PA 19046

    Phone–215/517-6572        Fax–215/517-6575

    Michelle.Espinal@mail.house.gov

     

    PA Senator John Rafferty  (R)Montgomery County

    Montgomery County Office
    3818 Germantown Pike, Suite B
    Collegeville, PA 19426

    Ph: 610-831-8830       FAX: 610-831-8837
    jrafferty@pasen.gov

    jmunera@pasen.gov 

    PA Senator Andrew E. Dinniman  (D)– Chester County

    One North Church Street
    West Chester, PA 19380

    (610) 692-2112           Fax  (610) 436-1721

    andydinniman@pasenate.com

    MINDARS@pasenate.com

     

    PA Senator Judith Schwank(D)   Berks County

    1940 North 13th Street
    Suite 232
    Reading, PA 19604

    (610) 929-2151   FAX: (610) 929-2576

    Jschwank@pasenate.com 

    PA Senator David G. Argall  (R)   Schuylkill County

    One West Centre Street
    Mahanoy City, PA 17948

    (570) 773-0891

    Dargall@pasen.gov

     

    PA Representative Tim Hennessey  (R)

    Old Elverson Train Station
    P.O. Box 255
    Elverson, PA 19520

    Phone: 610-286-9194               Fax: 610-286-1922
    thenness@pahousegop.com

    PA Representative Mike Vereb  (R)

    3950 Germantown Pike. Suite 101
    Collegeville, PA 19426

    Phone: (610) 409-2615      Fax: (610) 409-2619

    mvereb@pahousegop.com

     

    PA Representative Mark Painter (D)

    600 Heritage Drive, Suite 102

    Sanatoga, PA  19464

    Phone (610) 326-9563   Fax (610) 718-5787

    mpainter@pahouse.net  

  • PA Representative Becky Corbin (R) 315 Gordon Drive
    Exton, PA, 19341

    Phone: (610) 524-5595           Fax: (610) 524-5667

    bcorbin@pahousegop.com

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

NRC’S CON-GAME FOR HIGH-LEVEL RADIOACTIVE WASTE 

GREATER PHILADELPHIA REGION RESIDENTS HAVE A HUGE STAKE IN THIS DANGEROUS GAME BECAUSE LIMERICK NUCLEAR PLANT STORES MASSIVE AMOUNTS OF NUCLEAR WASTE ON SITE 

SPEAK OUT!  YOUR COMMENTS ARE NEEDED  

DEADLINE DECEMBER 20, 2013

MAJOR ISSUES FOR COMMENT ARE SUMMARIZED

IN THE ATTACHED LETTERS TO THE EDITOR PUBLISHED 10-29-13 & 11-1-13

FOR DETAILS ON LIMERICK NUCLEAR PLANT’S DANGEROUS NUCLEAR WASTE STORAGE THREATS:

www.acereport.org   Summary #9:  High-Level Radioactive Wastes: A Ticking Time Bomb 

FOR TALKING POINTS ON NRC’S CON GAME:  www.nirs.org

Waste Confidence Policy

Dry Casks vs Fuel Pools

Risks of Fire in Fuel Pools

       Waste Confidence and Climate

 

SEND COMMENTS TO NRC:

 

  • E-mail to:   Rulemaking.Comments@nrc.gov.

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

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

The Mercury (http://www.pottsmerc.com)

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

Friday, November 1, 2013

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

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

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

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

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

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

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

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

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

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

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

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

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

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

DR. LEWIS CUTHBERT
ACE President 

The Mercury (http://www.pottsmerc.com)

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

Tuesday, October 29, 2013

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

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

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

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

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

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

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

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

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

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

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

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

BETTY AND CHARLIE SHANK
Pottstown

NRC Shamelessly Lied About Limerick Nuclear Plant’s Radiation Releases and Alarming Cancer Rates in Communities Around Limerick

NRC is mandated to protect public health from Limerick Nuclear Plant Operations. Inexplicably, NRC has not just minimized the consequences of radiation exposure in our region, but actually ignored and avoided the impacts of Limerick Nuclear Plant’s regular radiation releases into the environment of the Greater Philadelphia Region, in Limerick’s DRAFT Environmental Impact Statement.

Radiation exposure to the public is barely mentioned in NRC’s 585 page DRAFT EIS. On the very few pages with any reference, radiation releases and their effects on human health have been inaccurately characterized as minimal or small. Documented evidence of our health crisis refutes NRC’s unsubstantiated claims.

This is NRC’s most harmful lie yet, because it will allow Limerick’s threats and harms to health in the region to continue for decades.

ACE Video Blog Part 4 8-13

NRC IGNORED LIMERICK’S ROUTINE RADIATION RELEASES AND SKYROCKETING CANCER RATES

THE LINK IS CLEAR!

• LIMERICK RELEASES RADIATION

• RADIATION CAUSES CANCER

• CANCER RATES SKYROCKETED AFTER LIMERICK STARTED OPERATING

• CANCERS ARE DOCUMENTED TO BE ELEVATED AROUND MANY NUCLEAR PLANTS, ESPECIALLY IN CHILDREN

LIMERICK NUCLEAR PLANT’S HARMFUL ROUTINE RADIATION RELEASES INTO OUR ENVIRONMENT HAVE THREATENED OUR HEALTH SINCE OPERATIONS STARTED IN 1985.
YET NRC’S DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS) DECEPTIVELY MINIMIZES THE HARMFUL EFFECTS OF ROUTINE RADIATION EXPOSURE IN OUR REGION. NRC’S EIS CONCLUSIONS ARE NOT CREDIBLE.

NRC’s DRAFT EIS is not responsive to the concerns of residents in our region who are well informed about NRC’s tactics to hide the truth about our radiation exposures from Limerick. We have been exposed to the additive, cumulative, and synergistic impacts of Limerick’s routine radiation releases since 1985. We can’t see it, smell it, taste, it, or feel it. Limerick’s radiation is proven to be in our air, water, soil, vegetation, milk, food, and fish in the Schuylkill River. Research shows we have some of the highest radiation levels in the teeth of our children, even compared to other nuclear plant communities tested.

THE FACTS ARE CLEAR:
­Limerick has been routinely and accidently releasing radiation for the past 28 years.
­It must be concluded that there have been additive, cumulative, and synergistic harmful impacts from all Limerick’s radionuclides released and from all routes of exposure.
­NRC does not acknowledge the large number of radionuclides or levels of them that have been released from Limerick over the past 28 years .
­NRC has no accurate idea of the amount of radiation that Limerick is releasing into our environment, because NRC does NO RADIATION MONITORING or TESTING.
­Exelon, the company with a vested interest in the outcome that has shown it can’t be trusted, controls the entire radiation monitoring, testing, and reporting process.
­Limerick’s radiation releases into our air and water include a broad range of radionuclides that have never been continuously monitored or regularly tested independently by NRC or any other agency.
­Some radionuclides released from Limerick have long half-lives, and their impacts are obviously enormous considering we are exposed from many routes of exposure.
­Yet, NRC negligently ignores Limerick’s radiation impacts in Limerick’s DRAFT EIS .
­Even Exelon’s own deceptive radiation self-testing for Limerick shows many different radionuclides are in our air, water, soil, sediment, milk, and fish.
According to the National Academy of Sciences there is NO SAFE DOSE of radiation exposure. Its BEIR VII report refutes NRC’s unsubstantiated claim that harms from Limerick are “small”.
ACE submitted substantial evidence in 2011 in written public hearing testimony to NRC for Limerick’s DRAFT EIS. We documented our region’s high cancer rates based on PA Cancer Registry data in communities around Limerick. Cancer rates are far higher than the national average.

This evidence of harm should have been alarming, even to NRC. Obviously NRC chose to ignore it.
­NRC’s insistence on repeatedly dismissing obvious harms from Limerick’s routine radiation emissions is unacceptable.
­NRC’s deceptions and denials lead to continued and increasing harms and threats to people from Limerick Nuclear Plant’s radiation and other toxic releases.

NRC routinely inaccurately claims that Limerick’s radiation releases are small and not harmful. But NRC’s claims are based on flawed and outdated theoretical models for radiation exposure.
NRC only measures external doses, and ignore internal doses.

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

CANCER RATES

CANCER INCREASES IN MONTGOMERY COUNTY SKYROCKETED AFTER LIMERICK STARTED OPERATING IN 1985 AND ARE DOCUMENTED TO BE FAR HIGHER THAN THE NATIONAL AND TRI-COUNTY AVERAGES IN SIX COMMUNITIES STUDIED NEAR LIMERICK.

LIMERICK’S RADIATION RELEASES ARE UNDENIBLY A MAJOR FACTOR.
• LIMERICK RELEASES RADIATION
• RADIATION CAUSES CANCER
• CANCER RATES SKYROCKETED AFTER LIMERICK STARTED OPERATING!

ACE PROVIDED NRC WITH DETAILS OF OUR CANCER CRISIS IN 10-26-11 EIS TESTIMONY FOR LIMERICK, YET NRC’S DRAFT EIS FOR LIMERICK FAILED TO INCLUDE THE DATA.

A CANCER CRISIS AROUND LIMERICK NUCLEAR PLANT IS WELL DOCUMENTED BY:
• Four Cancer Reports Using PA Cancer Registry Statistics and CDC Data Show Alarming Increases in Cancer, With Cancer Data Far Above The National and Tri-County Averages, Especially In Children
• ACE Cancer Mapping From Heath Surveys Reveals An Alarming Cancer Crisis

UNDENIABLE LINK – UPWARD TREND IN CHILDHOOD CANCER RATES AFTER LIMERICK STARTED OPERATING IN 1985

Late 1980’s 30 % HIGHER than the NATIONAL AVERAGE
Early 1990’s 60 % HIGHER than the NATIONAL AVERAGE
Late 1990’s 92.5% HIGHER than the NATIONAL AVERAGE
Late 1990’s 100 % HIGHER than the TRI COUNTY AVERAGE

Strontium-90 – An Undeniable Link To Rising Childhood Cancer Rates
• Even Exelon’s 2009 Radiological Report to NRC shows Limerick’s Strontium-90 is in our water, soil, milk, and vegetation
• Strontium-90 testing of our children’s baby teeth shows SR-90 at some of the highest levels in the nation in the teeth of our children.
• Limerick has been releasing SR-90 into our air and water since 1985.
• Children around Limerick have some of the highest levels of SR-90 in their baby teeth.
• It is shameful for NRC to blame decades old bomb testing that was done in the Midwest for SR-90 in the teeth of these children.
• SR-90 evidence serves as a marker to prove Limerick’s radiation is in the bodies of our children.

Documented Cancer Data Provided To NRC By ACE 10-26-11, Should Have Alarmed Even NRC:

• Childhood Cancer Rates Skyrocketed To 92.5 % Higher Than The National Average In Six Communities Close To Limerick Nuclear Plant.
(Pottstown , West Pottrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, Douglass Township)

• There Was A 71% Increase In Childhood Cancer Deaths
In Montgomery County, Home of Limerick Nuclear Power Plant
(Deaths from Neoplasms in Children Ages 1 to 14 1981-89 vs. 1990-98)
• Childhood Cancer Deaths In Neighboring Counties, PA, and the U.S. Went Down:
Chester County 29.0% Decrease
Berks County 30.6% Decrease
Pennsylvania 17.1% Decrease
U.S. 21. 2% Decrease

• Cancer Rates In 6 Communities Close to Limerick Nuclear Plant (1995 to 1999) Are Far Higher Than U.S. and Tri-County Averages For 8 of 11 Most Common Cancers In The U.S. (Compared to U.S. and TriCounty Rates)
Lower Pottsgrove, Upper Pottsgrove, West Pottsgrove, Pottstown, North Coventry, Douglass Berks

Type of Cancer Above U. S. Above Tri County
 Kidney/Renal Pelvis + 60 % + 42.7 %
 Rectum + 44 % + 13.5 %
 Uterine + 44 % + 38.7 %
 Breast (female) + 39 % + 24.5 %
 Brain/Cent. Nervous System + 38 % + 32.5 %
 Urinary Bladder + 35.5 % + 17.9 %
 Colon + 21 % + 3.3 %
 Lung + 11.8 % + 18.4 %
 Leukemia + 11.5 % + 14.9 %

Limerick’s routine radiation releases must be considered a major factor in these cancer rates which are so much higher than the national and tri-county averages. This refutes NRC’s claims that our cancer rates are high because of better detection methods or life-style choices.

• Cancer Rates In Montgomery County, Home of Limerick Nuclear Plant, increased Dramatically After Limerick Opened
Increases Mid 80s to 90s
 Prostate Increased 132%
 Thyroid Increased 128%
 Kidney Increased 96%
 Multiple Myeloma Increased 91%
 Hodgkin’s Disease Increased 67%
 Non-Hodgkin’s Lymphoma Increased 61%
 Breast Increased 61%
 Pancreas Increased 54 %
 Leukemia Increased 48%

THYROID CANCER LINK
After Limerick Nuclear Plant Started Operating in 1985 – In Montgomery County, Home Of Limerick Nuclear Plant
128% INCREASE – 1985-86 to 1996-97 Source: Pennsylvania State Cancer Registry
1998,1999, 2000 – Thyroid Cancer Rate Was About
75% HIGHER – Than U.S. Rate (Also Rising) Source: CDC Website

Thyroid Cancer Rates Are Far Higher Than National Average
In Counties Closest Most Impacted By Limerick Nuclear Plant’s Radioactive Emissions
Montgomery County 56.2 % Higher Than U.S.
Chester County 53.9 % Higher Than U.S.
Berks County 14.6 % Higher Than U.S.
While Berks County is Upwind – It is still higher than the U.S. Average
Source: U.S. Centers for Disease Control and Prevention, http://statecancerprofiles.cancer.gov.
Rates adjusted to 2000 U.S. standard population.

Our region’s thyroid cancer rates are horrific, considering they’re above the U.S. average when, U.S. (1980 – 2006) Increased 154.7 % and PA (2001- 2005) Had The Highest Thyroid Cancer Rates In U.S.

THERE ARE UNDENIABLE LINKS TO LIMERICK NUCLEAR PLANT’S RELEASES OF RADIOACTIVE IODINE-131 INTO OUR AIR AND WATER FOR DECADES.
• Limerick Nuclear Plant’s routine Iodine-131 radiation releases into our air and water impact the thyroid.
• Counties Closest and Downwind From Limerick Have Highest Thyroid Cancer Rates.
• Philadelphia Water Had The Highest Iodine-131 Levels In The Nation – Philadelphia Is Only 20 Miles Downstream From Limerick’s Radioactive Discharges.
Research Links Thyroid Cancer And Radiation Emissions From Nuclear Plants.
• Nuclear plants, including Limerick, routinely release radioactive iodine.
• Radioactive iodine attacks the thyroid gland, a fact confirmed by the potassium Iodide pills issued to residents within 10 miles of a nuclear plant to protect the thyroid in case of an accident or terrorist attack.
• Thyroid cancer is one of the most radiation-sensitive cancers.
• Radioactive iodine released from nuclear plants seeks out the thyroid gland and destroys its cells.
THYROID CANCER – An “Epidemic” Around Nuclear Plants
• The 2009 scientific article reported a Thyroid Cancer Epidemic in a small 90-mile radius encompassing eastern PA, central New Jersey, and southern New York, where 16 reactors are located, including Limerick Nuclear Plant.
• The Alliance For A Clean Environment (ACE) is extremely concerned about the shocking thyroid cancer increases and rates above the national average around Limerick Nuclear Plant., Documented statistics show shocking thyroid cancer increases in Montgomery County, home of Limerick Nuclear Plant, since Limerick started operating in the mid 1980′s to the mid 1990′s.
BREAST CANCER LINK
Evidence shows at the same time Breast Cancer Rates were declining around a nuclear plant that closed in California, Breast Cancer Rates in our regions started increasing after Limerick started operating.
Breast Cancer Rates INCREASED 61% In Montgomery County, Home of Limerick Nuclear Plant, After Limerick Started Operating in 1985.
Source: PA Cancer Registry 1985-86 to 1996-97

BREAST CANCER RATES WERE FAR HIGHER THAN THE NATIONAL AVERAGE IN EVERY AGE GROUP IN SIX COMMUNITIES CLOSE TO LIMERICK
(Lower Pottsgrove, Upper Pottsgrove, West Pottsgrove, Pottstown, North Coventry, Douglass Berks)

Breast Cancer By Age (diagnosed 1995-1999)
Compared to the National Average (Source: Pa Cancer Registry)

Age % HIGHER than U.S.
0-29 + 15.3 %
30-44 +51.4 %
45-64 + 39.3 %
65+ + 28.6 %

Breast Cancer is an epidemic nationwide, therefore these breast cancer rates near Limerick are so much more alarming because they are so much higher than the national average in every age group. They cannot be explained away by heredity, life-style choices, or better screening. Limerick’s radiation releases into our air and water are clearly a major factor.
Research Links Breast Cancer With Radiation Exposure
• Data from Chernobyl confirms that children exposed to radiation have a greater likelihood of developing breast cancer as adults. Source: Life Extension, 12/04
• John W. Gofman, M.D., Ph.D. “Our estimate is that about three-quarters of the current annual incidence of breast-cancer in the U.S. is being caused by earlier ionizing radiation… Source: “Preventing Breast Cancer” 1995
• “Life’s Delicate Balance” Causes and Prevention of Breast Cancer. Janette Sherman, M.D. Analyzes Links Between Cancer and Radiation and Other Toxics.
• 350 Studies Link Half of Breast Cancers to the Environment. The studies show that half of breast cancers causes are not attributed to Genetic Risk or Lifestyle Choices. Limerick’s radiation releases must be considered a major factor in our region’s extraordinarily high breast cancer rates.

LEUKEMIA LINK

In Six Communities Studied Near Limerick Nuclear Plant
LEUKEMIA was documented to be ALMOST DOUBLE THE STATE AVEARGE (1985 to 1994). (Montgomery County Health Department Study on PA Cancer Registry Statistics).

Leukemia represented the largest number of childhood cancers among the 92.5% childhood cancers rates higher than the national average.
The 15 year leukemia rate is approximately about 40% above the other three county rate. This is a statistically significant difference (p Source: Pennsylvania State Cancer Registry
Research Linking Leukemia to Nuclear Plant Radiation Exposure:
• A review of 17 medical journal articles by researchers from the Medical University of South Carolina showed that child leukemia rates were elevated at all 17 reactors.
• Leukemia death rates in U.S. children near nuclear reactors rose sharply in the past two decades, according to a study published in the European Journal of Cancer Care in 2008.
• Documentation of high leukemia rates in Chernobyl children confirm this link.

BRAIN CANCER IN POTTSTOWN IS SIGNIFCANTLY HIGHERTHAN STATE AND NATIONAL AVERAGES OR MUNICIPALITIES WITHIN A 12 MILE RADIUS.

Statistics: PA Department of Health, Bureau of Health Statistics ( 2001, August)
Compiled by: Penn State – Graduate Student Research
Analysis of cancer incidence in PA counties 1994-1998 http://www.health.sate.pa.us/stats

BRAIN/CENTRAL NERVOUS SYSTEM CANCERS
IN THE SIX COMMUNITIES STUDIES CLOSE TO LIMERICK NUCLEAR PLANT.
(Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry, Douglass Berks Township)
 COMPARED TO NATIONAL AVERAGE: 38.3 HIGHER
 COMPARED TO TRI COUNTY AREA: 32.5 HIGHER
DISASTROUS UPWARD TREND
Brain/Central Nervous System cancer statistics since Limerick Nuclear Plant started operating in 1985.
 1985-89 15 cases
 1990-94 19 cases
 1995-99 23 cases

MANY OTHER CANCER STUDIES IN GERMANY AND ELSEWHERE IN EUROPE, AS WELL AS THE U.S., CONFIRM HIGHER RATES OF CANCER AROUND NUCLEAR PLANTS.
­ JUST ONE EXAMPLE: Cancer Near German Reactors http://www.oeconline.org/our-work/kidshealth/healthprofessionals/first-annual-nw-health-conference-pdfs/day 1/Nussbaum%202.6.09.pdf
­THESE CANCER STUDIES PROVIDE ADDITIONAL CONFIRMATION THAT LIMERICK IS A MAJOR FACTOR IN THIS REGION’S ALARMING CANCER RATES.
CANCER STUDIES ALSO SHOW:
 CANCER RATES ROSE WHEN NUCLEAR PLANTS OPENED
 CANCER RATES DECLINED WHEN NUCLEAR PLANTS CLOSED

EVIDENCE BELOW SHOWS MORE HARM TO OUR CHILDREN AFTER LIMERICK STARTED OPERATING IN 1985.

INFANT and NEONATAL MORTALITY IS FAR HIGHER NEAR LIMERICK THAN THE STATE AVERAGE, AND EVEN HIGHER THAN PHILDELPHIA AND READING.
(State Data – Reported by EPA in 2003).
 Evidence shows when nuclear plants open infant mortality rates go up.
 When nuclear plants close, infant mortality rates go down.

• AUTISM INCREASED 310% (1990 to 2000)

• LEARNING DISABILITIES INCREASED by 94%, OVER DOUBLE THE STATE INCREASE OF 46%. (1990 to 2000)

THE FOLLOWING HEALTH HARMS WERE HIGHER THAN THE STATE AVERAGE, AND EVEN HIGHER THAN PHILADELPHIA AND READING
• Malignant Tumors
• Cerebrovascular Disease
• Lower Respiratory Disease
(2003 EPA Report Based on PA Data)

Limerick’s 2009 air pollution permit shows why Limerick’s cooling tower PM-10 air pollution can contribute to increases in cerebrovascular and lower respiratory diseases.

All this evidence shows that a health crisis occurred in our region after Limerick Nuclear Plant started operating in 1985.
• ACE compiled and presented all this evidence to the NRC 10-26-11 in public hearing testimony for NRC’s EIS on Limerick.
• This evidence of our health crisis and its links to Limerick operations should compel NRC to protect public health by closing Limerick now.

For the past 28 years, a broad range of radionuclides (some with long half-lives) have routinely and accidentally been released into our air and water from Limerick Nuclear Plant.

We have been, and will continue to be exposed to the additive, cumulative, and synergistic harmful impacts of Limerick’s radiation through several routes of exposure as long as Limerick operates.

RADIATION RELEASES ARE THE MOST DANGEROUS THREAT TO OUR HEALTH FROM LIMERICK NUCLEAR PLANT.NRC’S DRAFT ENVIORNMENTAL IMPACT STATEMENT FAILED TO ADDRESS LIMERICK’S RADIATION IN ANY MEANINGFUL WAY.

NRC’S glaring omission of radiation and its enormous threat to our environment and health rises to the level of regulatory malpractice.
 It is shocking that NRC’s DRAFT EIS fails to address radiation exposure and human health impacts in any meaningful way.
­ Radiation exposure to the public is barely mentioned in NRC’s 585 page DRAFT EIS.
­ On the very few pages with any reference, radiation releases and their effects on human health have been shamelessly characterized as minimal or small, clearly an unsubstantiated claim, for which NRC has NO independent evidence. NRC’s claim is NOT CREDIBLE.
­ Even Exelon’s own radiological monitoring reports to NRC show that a broad range of radionuclides are documented to be in our air, water, sediment, fish, and milk.
­ Evidence from independent scientists suggest that NO level of radiation exposure is safe.

NRC is mandated to protect public health from Limerick Nuclear Plant Operations, yet NRC has not just minimized the consequences of radiation exposure in our region, but even ignored the impacts of Limerick Nuclear Plant’s regular radiation releases into the life-support system that impacts human health in the Greater Philadelphia Region, in Limerick’s DRAFT Environmental Impact Statement.

Exposure to Limerick’s radiation is an injustice. We can’t see, smell, taste, or feel it, but it’s everywhere. We can’t avoid it. As long as Limerick Nuclear Plant continues to operate, radiation and other dangerous toxics will be released into our air and water. The additive, cumulative, and synergistic harmful impacts of that will cause more people to suffer needlessly.

NRC could stop unnecessary radiation and other toxic exposures due to Limerick Nuclear Plant operations.

Associated suffering and health care costs due to Limerick operations would be dramatically reduced by closing Limerick if NRC would close Limerick now to protect public health.

AS LONG AS LIMERICK NUCLEAR PLANT OPERATES, RADIATION WILL CONTINUE TO BE RELEASED INTO OUR LIFE SUPPORT SYSTEM.

NRC SHOULD REQUIRE LIMERICK TO CLOSE NOW TO PROTECT PUBLIC HEALTH, ESPECIALLY FOR OUR CHILDREN.

HELP CLOSE LIMERICK NOW TO REDUCE RADIATION EXPOSURE AND MINIMIZE RISK FOR CANCER

CONTACT ACE
aceactivists@comcast.net

LEAVE CONTACT INFORMATION AND ANY INFORMATION ABOUT CANCER

NRC Negligently Ignored Massive Dangerous Air Pollution From Limerick Nuclear Plant Despite Health Harms

NRC should have the courage and integrity to tell the truth about the health risks related to Limerick’s massive air pollution. Radiation, toxic chemicals, massive PM-10 from the cooling towers, and chlorine additives are all in our air. No problem according to NRC. Health crisis data around Limerick suggest otherwise.

To protect public health, Limerick needs to close now, and stop polluting our air.

VIDEO BLOG – PART 3 – AUGUST 2013

LIMERICK NUCLEAR PLANT’S DANGEROUS AIR POLLUTION IGNORED BY NRC

LIMERICK’S DANGEROUS AIR POLLUTION HARMS HEALTH.

10-26-11 ACE PROVIDED NRC WITH DOCUMENTED DETAILS FOR LIMERICK’S EIS PUBLIC HEARING COMMENTS.

• Our analysis of Limerick’s Title V air pollution permit and other documentation show why Limerick’s air pollution is a “major” threat to our region.

• NRC ignored this evidence in Limerick’s DRAFT EIS conclusions or NRC could not have concluded Limerick’s air pollution impacts are “small”.

• NO unbiased person could analyze the evidence and the reality and still come to that conclusion!

FACTS SHOW WHY NRC’S DRAFT ENVIRONMENTAL IMPACT STATEMENT IS ABSURD, WHEN CLAIMING LIMERICK’S AIR POLLUTION THREATS ARE “SMALL”

LIMERICK NUCLEAR PLANT’S AIR POLLUTION INCLUDES:
1. Radiation – from routine operations and accidental releases
2. Schuylkill River Toxics – from withdrawing 56.2 Million Gallons Per Day
3. Toxic Chemicals – from adding over 300 pounds per day to Cooling Towers
4. Greenhouse Gases, Combustion Chemicals & By-products – from Boilers, Etc.

• The National Academy of Sciences BEIR VII Report concludes that there is no safe level of radiation. Limerick routinely releases radioactive particulates, the most harmful kind of air pollution because inhaled radionuclides remain in your body causing long-term damage.

• There are additive, cumulative, and synergistic harmful health impacts from all the different radionuclides released into our air with other toxic air pollution. For example: Our region is at high risk for ozone. Ozone works synergistically with radiation to enhance to cancer-causing effects of radiation. Therefore, Limerick’s harmful air pollution impacts have been grossly underestimated.

• Limerick routinely releases a broad range of air pollutants released from 32 different air pollution sources. NONE have filtration.

Limerick’s air pollution contains PM-10, an air pollutant considered more dangerous than ozone, PM-10 is released from 4 different sources at Limerick and is massively released from Limerick’s cooling towers, yet PM-10 is not monitored, but only estimated by Exelon. No agency verifies Exelon’s estimates.

To avoid air pollution permit violations, in 2009, Limerick requested and received a 6-fold INCREASE in its Title V Air Pollution Permit limit for PM-10, dangerous cooling tower air pollution that is considered more deadly than ozone by the American Lung Association.
This was a legal maneuver to make it appear that Exelon complies with its air pollution permit for PM-10.

• Dr. Devra Davis compiled evidence from more than 1,000 air pollution studies in 20 countries showing the certain death rates for asthma, heart disease, and lung disorders were based on the amount of exposure to air pollution.

• Also, Limerick’s cooling towers host pathogens. Those infectious pathogens are transported into our air with the cooling tower plume. They can cause disease in humans and animals. NRC’s DRAFT EIS shows that Limerick’s cooling towers release microbiological organisms including SALMONELLA, LEGIONELLA, AND PSEUDOMONAS AERUGINOSA, which can cause serious and sometimes fatal infections in immune compromised individuals.

IN 2009 LIMERICK ASKED FOR AND RECEIVED DRASTIC PERMIT INCREASES IN AIR POLLUTION FROM ITS COOLING TOWERS. THIS IS THE KIND OF AIR POLLUTION CONSIDERED MORE DANGEROUS THAN OZONE.

NRC’S 4-13 DRAFT ENVIRONMENTAL IMPACT STATEMENT IGNORED ALL THE EVIDENCE OF LIMERICK NUCLEAR PLANT’S DANGEROUS AIR POLLUTION WHEN FALSELY CLAIMING LIMRICK’S AIR POLLUTION IMPACTS ARE “SMALL”.

COOLING TOWER AIR POLLUTION CONTAINS ENOUGH CHLORINE ADDITIVES TO CORRODE STEEL
• Nuclear Industry Studies Show Cracks Can Occur In Stainless Steel In 4 to 52 Weeks.
• Chlorine is added to Limerick’s Cooling Towers as Sodium Hypochlorite
• Limerick Uses 16,000 to 58,000 POUNDS PER DAY of Sodium Hypochlorite

NRC DISMISSED CONCERN ABOUT CORROSIVE AIR FROM LIMERICK’S COOLING TOWERS BY ALLOWING EXELON TO SAY IT DOESN’T MATTER BECAUSE THE CORROSIVE AIR FROM THE COOLING TOWERS TRAVELS OFF-SITE.

NRC EXPRESSED NO CONCERN ABOUT IMPACTS TO THE LUNGS OF PEOPLE OFF-SITE WHO ARE FORCED TO BREATHE LIMERICK’S DANGEROUS CHLORINATED AIR POLLUTION.

LIMERICK’S MASSIVE DANGEROUS AIR POLLUTION WILL CONTINUE AS LONG AS LIMERICK CONTINUES TO OPERATE.

NRC SHOULD TELL THE TRUTH ABOUT THE HEALTH RISKS OF LIMERICK’S AIR POLLUTION AND REFUSE TO RELICENSE LIMERICK. TO PROTECT PUBLIC HEALTH, LIMERICK NEEDS TO CLOSE NOW AND STOP POLLUTING OUR AIR.

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

ACE Video/Blog – Part 7
April, 2013

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

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

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

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

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

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

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

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

MOST CHILDREN COULD BE TRANSPORTED TO RECEPTION CENTERS STILL IN LIMERICK’S RADIOACTIVE PLUME .

TO HAVE ANY HOPEOF MINIMIZING RADIATION EXPOSURE FOR OUR CHILDREN, RECEPTION CENTERS FOR EVACUEES SHOULD BE PLANNED AT LEAST 50 MILES AWAY BASED ON EVIDENCE FROM CHERNOBYL AND FUKUSHIMA.

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

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

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

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

SCHOOL BUSES

 IT APPEARS EXELON’S ETE GROSSLY OVERESTIMATES SCHOOL BUSES AND CERTIFIED DRIVERS AVAILABLE FOR EVACUATION.

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

DISCREPANCY:

1,224 ESTIMATED BUSES NEEDED (Page 1-9)
1,388 CHARTED BY SPECIFIC SCHOOLS (Pages 6-18 to 6-22)

PROBLEMS BEYOND THE 164 – BUS SHORTFALL:
• NO buses or drivers are planned for the schools and day-cares missed by Exelon’s ETE.
• Availability of certified licensed school bus drivers assumed in Exelon’s ETE is questionable at best.
• Assumed vehicle availability along with perfectly modeled traffic patterns make this ETE unworkable to protect children in a Limerick radiation accident / meltdown.
• Residential students from the Hill School and Ursinus College (possibly well over 1,000) are not even included in Exelon’s Time Estimate.

DISCREPANCY:

WHY SUCH A HUGE DISPCREPANCY WITHIN EXELON’S ETE?
­ Page 6-17 Itemized Total 1,706 Vehicles Needed For Hospitals, Nursing Homes, Retirement Communities and Other Special Facilities
­ Page 1-9 Their narrative total for the current study shows 442 vehicles needed

EXELON’S ETE ESTIMATES FOR AMBULANCES AND VANS:

 1,706 AMBULANCES and VANS NEEDED
(To Assume That Such A Large Number Would Be Available Simultaneously Defies Logic.)

EXELON’S ETE CONVERSELY CLAIMS:

 ONLY 442 AMBULANCES AND VANS ARE NEEDED (PAGE 1-9),

EXAMPLES FROM THE ITEMIZED LIST OF 1706
 Pottstown Hospital – ETE Lists 332 Ambulances / Vans Needed
 Phoenixville Hospital – 82 Ambulances and Vans

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

EXAMPLES FROM THE ITEMIZED LIST OF 1706 ALSO INCLUDE:
 Montgomery County Rehabilitation Center – 330 Ambulances and Vans
 Veterans Center – 146 Ambulances and Vans

INCONSISTENCY WITH PRISONS

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

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

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

 ACE’s CONCLUSION:
To assert that 1,706 ambulances and vans would be available simultaneously is beyond irresponsible.

OTHER CONCERNS:

EXELON’S ETE UNDERESTIMATES TRANSIT-DEPENDENT POPULATION:

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

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

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

EXELON’S ETE TELEPHONE SURVEY THAT WAS THE BASIS FOR DETERMINING RESIDENTIAL VEHICLE AVAILABILITY WAS NOT REPRESENTATIVE.

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

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

ETE’S BLINKING LIGHTS AT INTERSECTIONS COULD CONTRIBUTE TO CONFUSION, CONGESTION,AND ACCIDENTS.

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

CONFUSION CREATED BY EXELON’S ETE HINDERS SAFE LIMERICK NUCLEAR PLANT EVACUATION

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

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

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

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

Problems Created By Exelon’s ETE Faulty Assumptions:

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

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

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

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

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

ACE Conclusions:

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

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

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

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

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

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

Major Problems With Limerick’s Current Evacuation Plan:

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

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

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

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

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

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

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

Assumptions that just won’t work in reality:

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

CONTACT ALL ELECTED OFFICIALS

URGE ALL OFFICIALS TO:

1. DEMAND THAT LIMERICK NUCLEAR PLANT CLOSE AS SOON AS POSSIBLE TO PREVENT A MELTDOWN

UNTIL LIMERICK CLOSES DEMAND:

2. IMMEDIATE NOTIFICATION OF LIMERICK RADIATION ACCIDENT

3. EVACUATION ZONE EXPANDED TO 50 MILES

4. INGESTION PATHWAY ZONE EXPANDED TO 100 MILES

ACE Video Blog 3 on the Pattern of Cover-Ups and Lies About Consequences of Radiation Exposure From Nuclear Plant Accidents and Meltdowns

 

ACE Video / Blog – Part 3

The Truth and Consequences of Radiation Exposure

From Nuclear Plant Accidents / Meltdowns

Truth and Consequences of Radiation From Meltdowns Must Be Fully Disclosed So That People In The Greater Philadelphia Region Begin To Understand Why More Protective Limerick Nuclear Plant Emergency and Evacuation Planning Is Imperative

· The Pattern of Unethical Deception About Radiation Exposure After Meltdowns Has Created Disastrous Situations, Needlessly Magnifying Harms For Millions.

­ Victims Were Not Evacuated Soon Enough or Far Enough Away From Meltdowns. They Suffered Needlessly.

­ People Failed To Take Precautionary Actions Because They Were Lied To About Radiation Releases.

· Cover-Ups, Lies, and Secrecy About Radiation Releases and Their Consequences From Meltdowns Must Be Revealed – It’s About Ethics, Human Rights, and Minimizing Harms.

· Government and the Nuclear Industry Deceive The Public. They Manipulate Public Opinion To Reduce Opposition to Nuclear Power To Prevent Collapse of the Nuclear Industry.

· Deaths and Harmful Health Impacts Have Been Deliberately Underestimated – Using Dilution, Discounting Internal Radiation Exposure, Ignoring Diseases Other Than Cancer, Using Deceptive Testing and Estimates.

· The Truth About Consequences of Meltdowns Has Been Suppressed and Withheld – Through Worldwide Censorship of Media and Misleading Industry Propaganda That Denies Reality.

Once a Large Amount of Radiation Enters An Ecosystem It Quickly Becomes Widespread, Contaminating Water, Soil, Plants, Animals, and People

· Radiation is invisible – It also can’t be tasted, smelled, or felt by victims.

· Evidence shows radiation from meltdowns contaminates air, water, soil, and food hundreds of miles away from meltdowns.

· As Radiation moves up the food chain, it Bioaccumulates, Bioconcentrates, and Biomagnifies

· Example: Ingestion of foods contaminated with even “low levels” of radioactive cesium leads to bioaccumulation in the liver, kidneys, small intestines, pancreas, spleen, and heart and endocrine tissues.

· Children are most susceptible to effects of radiation on their internal organs.

· There is “NO SAFE RADIATION DOSE” according to The National Academy of Sciences, Physicians for Social Responsibility, and other experts.

People In The Greater Philadelphia Region Must Have Immediate Notification Of A Limerick Nuclear Plant

Radiation Accident or Meltdown With Expanded Evacuation and Ingestion Pathway Zones

The Nuclear Regulatory Commission (NRC) Has Lost All Credibility

NRC’S LUDICROUS DECEPTION

Fukushima was the worst nuclear disaster in history, expected by independent experts to have worse radiation consequences than Chernobyl – estimated to have released radiation 20 times Chernobyl.

Soon after Fukushima’s meltdowns started, many Japanese people far beyond the evacuation zone started showing signs of radiation poisoning, especially children. Related deaths were certified by officials in 13 Prefectures.

Yet, NRC Told 3,000 Nuclear Experts From 34 Countries:

Fukushima Did Not Result In Big Radiation Doses to the General Population. Immediate Health Consequences Were “Very Close To Nothing,” With “Little To No” Long-Term Health Effects.

Probably Met NRC Safety Goals.

NRC Needs New Standards For Fukushima Type Disasters.

How Can We Believe NRC About Anything?

NRC Protects Nuclear Industry Profits At The Expense Of Public Health and Safety

· NRC is failing in its mission to protect public health and safety.

· In spite of credible evidence from Chernobyl and Fukushima meltdowns proving radiation released travels hundreds of miles and has devastating impacts on health, especially for children, and in spite of NRC warning U.S. citizens to evacuate 50 miles from Fukushima, NRC is still denying the need to expand U.S. evacuation zones beyond 10 miles and ingestion pathway zones beyond 50 miles.

· NRC disregards reliable independent scientific research and fails to fully disclose harmful impacts from routine and accidental radiation releases with deceptively designed word-smithing.

NRC is using industry biased studies to deceive the public about actual consequences of radiation exposure from meltdowns.

NRC is refusing to provide more realistic protective planning for Limerick Nuclear Plant and others.

Flawed MIT Study Is Being Used By NRC

To Dismiss The Need For Nuclear Disaster Evacuations

(May 25th, 2012) Previous Study Disputes MIT Claim (Tanaka et al , 2009)

The flawed study discounted credible human data compiled after Chernobyl and Fukushima meltdowns.

MIT Awarded More Than $2 Million in Grants And Fellowships

(May 21, 2012) http://web.mit.edu/newsoffice/2012/mit-doe-grants-fellowships.html Nuclear science and engineering

$1.65 million was awarded through grants from the Department of Energy Nuclear Energy University Programs and $450,000 was awarded through graduate student fellowships. “Scholarship for Nuclear Communications and Methods for Evaluation of Nuclear Project Acceptability” will develop a model to characterize the factors affecting social acceptance of nuclear projects by potential stakeholders.

MIT Mouse Radiation Study Is Science Fiction (June 7th, 2012 Video)

See Why MIT’s study is pure science fiction, not fact: http://www.youtube.com/watch?v=e8YFe6Q08M8&feature=em-subs_digest

NRC’s response to Fukushima meltdowns was to ignore reality and arrange for MIT do a selection-bias study, using a 35-day short-term mouse study to make it seem as if impacts from radiation exposure are harmless. The MIT study excluded extensive evidence of genetic damage to humans living in a radiation-contaminated environment. Nineteen groups of Children from Chernobyl showed lasting genetic damage from radiation.

A Radioactive Conflict of Interest (June 25th, 2012)

Having the Energy Department control radiation health research makes as much sense as giving tobacco companies the authority to see if smoking is bad for you.

MIT Confronted With Its Malpractice of Science (June 25, 2012)

http://www.huffingtonpost.com/robert-alvarez/mit-radiation-study_b_1623899.html

The MIT Radiation Study Was Confronted With Its Malpractice Of Science. The Study Protocol was flawed. It’s the worst kind of bias, the kind paid to ignore human suffering. “It’s difficult to get someone to understand something when his salary depends upon his not understanding it.”

MIT Mouse Study Debunked In Journal (November 13th, 2012)

Biased Protocols Included:

· The use of genetically altered FYDR mice for one portion of the study but not the comparison groups.

· The wide range in the numbers of mice used in the comparison groups.

· The time frame was too short (Tanaka paper)

· External radiation was the only radiation studied. Internal radiation was not studied, but presents the bigger risk.

· The study left out crucial information that children may have a 3-fold higher risk for damage from radiation at half the accumulated MIT dose.

Independent Research And Evidence Dispel MIT’s Radiation Deception:

A body of independent research on radiation, as well as evidence from actual meltdowns, reveal the truth and consequences of radiation exposure from nuclear plants like Limerick.

· There is NO safe level of radiation exposure, according to the National Academy of Sciences and Physicians for Social Responsibility.

· Ionizing radiation from nuclear plants damages living things and can contaminate the environment permanently.

· Nuclear Plant radiation mutates genes which can cause genetic damage across generations.

· U.S. and European studies have all shown increases in cancer around nuclear facilities.

· Drastic increases in cancer are documented, especially in children, in communities near Limerick Nuclear Plant and Montgomery County, home of Limerick Nuclear Plant , since Limerick Nuclear Plant started operating in1985. (See ACE Website Download #2: “Cancer – Skyrocketing Increases: Links to Limerick”)

Human Health Consequences Resulting From Radiation Releases After Meltdowns At Fukushima, Chernobyl, and Three Mile Island Have Been Revealed By Independent Research:

· Based on the amount of radiation releases over 1.5 million excess cancers are expected from Fukushima.

· Over 1.5 million excess cancers occurred over 25 years from Chernobyl, “Consequences To People And The Environment” – New York Academy of Science nyas.org/annals

· Partial meltdown at TMI may have caused 50,000 to 100,000 excess deaths. Read: “Deadly Deceit: Low Level Radiation – High Level Cover-up” by Jay Gould and Ben Goldman, 1990

Radiation and Public Health Project Director, Joseph Mangano’s Two Excellent Books Reveal Truth And Consequences About Radiation Exposure

· “RADIOACTIVE BABY TEETH: THE CANCER LINK”

The Only Study Of Radiation Levels In Bodies Of Americans Living Near Nuclear Plants – Includes Data On Limerick Nuclear Plant.

· “MAD SCIENCE: THE NUCLEAR POWER EXPERIMENT”

Includes An Account of Consequences From Nuclear Accidents and Meltdowns, Plus A Point-by-Point Refutation of Pro-Nuke Arguments.

“There Is NO Safe Level Of Radionuclide Exposure Whether From Food, Water, Or Other Sources. PERIOD!”

Dr. Jeff Patterson, Former President of Physicians for Social Responsibility, Said:

Exposure to Radionuclides, like Iodine-131 and Cesium-137, INCREASES Risk of Cancer.”

Radiation Exposure Can Affect The Whole Body

The broad range of radionuclides that are present in radioactive releases from nuclear power plants have been linked to damage to: Bladder, Bone, Brain, Breast, Kidneys, Liver, Lungs, Muscles, Ovaries, Pancreas, Skin, Spleen, Thyroid

Radiation Sickness Symptoms Appear in One to Four Weeks and Can Be Mistaken for Other Illnesses Like the Flu:

· Within the first twenty-four hours, symptoms can include nausea, vomiting, diarrhea, headache, fever, etc.

· Within one to four weeks, symptoms can include dizziness, disorientation, weakness and fatigue, hair loss, bloody vomit and stools, infections, poor wound healing, and low blood pressure.

There Is No Way to Undo Damaging Effects Of Radiation Exposure

To Minimize Exposure

· Time Limit Exposure

· Distance Between You and Radiation

· Shielding Learn About Best Sheltering Procedures

For Radiation Exposure Summaries See: www.acereport.org

#1 Radiation – Limerick’s Routine Releases

#3 Radiation – No Safe dose

#4 Radiation – Reduce Risk

Over 8 Million People Live Within 50 Miles Of Limerick

How Close Do You Live To Limerick Nuclear Plant?

See Natural Resources Defense Council (NRDC)

Radiation Plume Map www.nrdc.org

RADIATION EXPOSURE CAN BE MINIMIZED

RELATED TO A LIMERICK ACCIDENT / MELTDOWN

WITH MORE PROTECTIVE UP-FRONT EMERGENCY AND EVACUATION PLANNING

Contact Elected Officials Today To Demand That NRC Require More Protective Emergency Planning Including:

1. Immediate Public Notification By Exelon and NRC

2. Independent Radiation Monitoring With Electronic

Radiation Alert System

3. A 50-Mile Evacuation Zone

4. A 100-Mile Ingestion Pathway Zone

Fukushima and Chernobyl Meltdowns Prove Radioactive Fallout Traveled Far Greater Distances Than 50 Miles. The Radioactive Ingestion Pathway Went Far Beyond 100 Miles.

Facts About Fukushima Fallout:

· Japan’s long-lived radiation contaminated more than 11,500 square miles. (Reported 11-11)

· An area almost the size of Connecticut (some 4,500 square miles) was found to have radiation levels exceeding Japan’s shameful highly inflated allowable radiation limit.

· The radioactively-contaminated exclusion zones surrounding Fukushima cover more than 300 square miles.

Facts About Chernobyl Fallout:

· Evacuations spread over the years as far as 200 miles away from the reactor. Approximately 350,400 people were evacuated from the areas surrounding Chernobyl.

· 80 square miles were declared too radioactive for human habitation and declared a permanent “exclusion” zone.

Yet, Limerick’s Emergency and Evacuation Zone Remains Set At Only 10-Miles. Limerick’s Ingestion Pathway Zone Remains Set At Just 50 Miles. This Is Negligence!

1974 Reactor Safety Study Published by NRC (Referred To As The Rasmussen Report)

· 45,000 Radiation Sickness Cases (Requiring Hospitalization)

· 3,300 Deaths (From Acute Radiation Sickness)

· 45,000 Fatal Cancers (over 50 years)

· 250,000 Non-Fatal Cancers (over 50 years)

· 190 Children Born With Birth Defects Per Year

Note: Non-Insurable Property Damage Was Estimated At $14 Billion

NRC’s Estimated Consequences For An Accident At Limerick Nuclear Power Plant, Reported To Congress In 1982 (Referred to as the CRAC Report):

· 74,000 Early Fatalities

· 610,000 Early Injuries

· 34,000 Cancer Deaths

Census Records From 1980 to 2010 Show That These Numbers Would Be Drastically Higher Today.

This Population Increase Demands Updated Planning.

The Following News Articles and Reports Provide Overwhelming Evidence Of NRC’s Negligent, Ineffective, Unprotective Policies:

· 03/21/11 NRC Increases Estimated “Background” Doses to Radiation Again

· 04/05/11 “NRC’s Pro-Nuke Spin on Evacuation Zones”

· 06/02/11 Some fear U.S. nuclear agency is playing ‘regulatory roulette’

http://edition.cnn.com/2011/US/06/01/nuclear.plant.regulation/index.html

· 07/29/11 NRC Lowers Estimate of How Many Would Die in Meltdown By Matthew Wald

· 08/30/11 NRC: Update evacuation plans near nuclear plants AP – By Matthew Daly

Article exposes no changes to evacuation zones which have remained frozen at a 10-mile radius around each

plant since they were set in 1978, regardless of aging reactors operating at higher power, risking larger

radioactive releases, and skyrocketing populations around some plants – as high as 4 1/2 times higher.

· 09/11/11 Agencies Struggle To Craft Offsite Cleanup Plan For Nuclear Power Accidents November 10, 2010

http://insideepa.com/Inside-EPA-General/Inside-EPA-Public-Content/agencies-struggle-to-craft-offsite-cleanup-plan- for-nuclear-power-accidents/menu-id-565.html

While no agency is taking responsibility for attempting to clean up after a nuclear disaster, all these agencies ignore or miss the fact that nuclear “accidents” NEVER end. Will they ever admit that a nuclear plant worst case scenario is likely to be just too bad to clean up?

NRC and Industry’s Attempt To Hide The Real Risk From Nuclear Plant Radiation

Bogus Comparisons:

· The nuclear industry and NRC intentionally ignore and deny harms from continuous routine radiation exposure from nuclear plant releases. They repeatedly, absurdly dismiss harm from continuous exposure to over 100 radionuclides routinely discharged from nuclear plants and make bogus comparisons to radiation from sunshine, X-rays, and airplane trips.

· The broad range of nuclear plant radionuclides routinely released cause additive, cumulative, and synergistic internal and external radiation damage. Once in the ecosystem, people living in the region of a nuclear plant cannot avoid these exposures. They cannot see it, taste it, feel it, or smell it.