ACE Summary Report – August, 2012
IT’S ABOUT OUR WATER!

Don’t Let Exelon Get Away With, In Essence, “Eminent Domain”, of Our Water Resources In Parts of Six Counties For Limerick Nuclear Plant Operations and Exelon Profits.

LIMERICK NUCLEAR PLANT IMPACTS WATER ACROSS SIX COUNTIES
Including Schuylkill, Berks, Montgomery, Chester, Bucks, and Philadelphia

Details Summarized In This Report Reveal Limerick Nuclear Plant’s Unprecedented And Unjust Use And Abuse Of Our Water That Are Being Whitewashed And Legalized By Agencies That Supposedly Protect Our Water and Health.

But, DEP’S NPDES PERMIT And DRBC’s DOCKET Are
STILL DRAFTS – THEY’RE NOT A DONE DEAL!

It’s VERY Important For You To Attend The Public Hearing Tuesday, 8-28-12
6:00 To 9:00 P.M. Sunnybrook Ballroom In Pottstown

The Alliance For A Clean Environment (ACE), Investigated Many Pollution Threats To Public Water Over The Past 15 Years. After Review Of Documents And Permits On Limerick Nuclear Plant’s Harms And Threats Since 2006, We Concluded Limerick Nuclear Plant’s Water Use and Discharges Clearly Present The Most Dangerous Threats To Public Water Supplies For The Largest Numbers Of People.

In Essence – To Protect Our Water, Exelon Must Be Required To:
 Filter Out Toxics Which Jeopardize Water And Health
 Comply With Clean Water Standards and Laws – With NO EXEMPTIONS
 Face Revoking Of Limerick’s Permits For Violations Of The Law

Our View:
WE NEED SAFE WATER! WE DON’T NEED LIMERICK NUCLEAR PLANT!
We Must Have An Ample, Safe Water Supply To Thrive and Survive. Limerick Nuclear Plant Threatens Water Resources In The Many Serious Ways Revealed In This Report. Limerick’s electric goes to the grid, supplying only ½ of 1% of our nation’s energy. It’s sold across several states, but we face unprecedented use and abuse of our water. Safer energy alternatives are ready now, that won’t threaten our water supply.

At The End Of This Report, We Prepared A List Of Suggested Changes That, If Made, Could Reduce Some Of The Serious Risks We Face, For Both DEP’s Permit To Pollute The Schuylkill River and DRBC’s Permit Allowing Limerick to Have “In Essence Eminent Domain” Over Our Water.

We Must OPPOSE One Person, A Biased “DRBC CZAR” Deciding If Exelon Is Held Accountable For Limerick Nuclear Plant Rendering Wells Or Surface Waters Dry Or Otherwise Unusable From Radiation Or Other Toxic Discharges. Victims Would Even Be Forced To Hire A Hydrologist To Present “The Czar” With A Report.

YOU CAN HELP PROTECT OUR WATER!
REVIEW THE FACTS IN THIS REPORT AND SPEAK UP NOW!
1. ATTEND DEP/DRBC PUBLIC HEARING, Tuesday 8-28-12, From 6:00 to 9:00 PM
Parents, Grandparents, All Concerned Citizens – This Is Our Opportunity To Reduce Limerick’s Threats To Our Water.
Please Take Time to Attend. Speak Out Or Let Your Presence Be Your Voice.
2. SUBMIT WRITTEN COMMENTS BY OCTOBER 27, 2012 by 5:00 P.M.
Before Or After The Hearing You Can Submit Written Comments
Addresses Listed On ACE Blog For Public Hearing
Please Copy ACE at either:
aceactivists@comcast.net or 1189 Foxview Road, Pottstown, PA 19465
3. ASK ELECTED OFFICIALS TO SPEAK UP TO PROTECT OUR WATER
Their Silence Protects Exelon Profits, Not Our Water

DETAILS BELOW
REVEAL THAT YOUR WATER IS NOT BEING PROTECTED!

Unprecedented Use and Abuse of Public Water Resources For Profit
• PA DEP and DRBC Will Hold A Joint Public Hearing August 28, 2012 at Sunnybrook in Pottstown
• DEP and DRBC Went To Extraordinary Lengths To Avoid Enforcement of Limits and Law
• Problem: Limerick Nuclear Plant Can’t Meet The Clean Water Law Without Filtration, But Instead of Requiring Filtration, DEP and DRBC Plan to Issue Permits With NO LIMITS. Eliminating Limits Protects Exelon’s Profits, But Jeopardizes The Health Of Almost Two Million People From Pottstown to Philadelphia, Who Depend On The Schuylkill River For Their Water.
• PA DEP Draft Permit – To Be Issued By April 2013 For 5 Years – Most Alarming Issues:
­ Radiation and Cooling Tower Toxics In TDS Discharges From Outfall 001 Would Be Allowed To Be Discharged Into The Schuylkill River With No Limits, Even Though The Schuylkill River Is a Drinking Water Source For Almost Two Million People From Pottstown to Philadelphia.
­ Both DEP and Exelon Admit Limerick Can’t Meet Safe Drinking Water Standards.
­ Limerick’s TDS Discharges Drastically Exceeded DRBC Limits – (2010 Data- Nearly 5 Times Higher Than Safe Standards).
­ DEP Exempted Discharge 001 Instead Of Requiring Filtration To Protect Public Health
• DRBC Draft Docket (Permit) – To Be Issued April, 2013 – Most Alarming Issues:
­ In Essence, DRBC’s Docket Would Give Limerick Nuclear Plant “Eminent Domain” Over Our Vital Water Resources
­ In Essence, DRBC’s Docket Would Eliminate Future Public Participation
­ More Water Would Be Allocated To Limerick Nuclear Plant From Many Sources
­ The Schuylkill River Would Basically Be Dedicated To Limerick Nuclear Plant
­ For An Accident or Meltdown, Limerick Would Have Unrestricted Water Use From All Sources, For An Unlimited Amount Of Time
­ DRBC’s Director Would Unilaterally Decide All Claims Against Exelon For Water Loss Or Contamination
­ Victims Would Be Forced To Pay For A Hydrologist Study To Present To The DRBC Director For Claims Against Exelon

DEP and DRBC DRAFT Permits Protect Exelon’s Profits, NOT Our Water
• Permit Approvals Could Lead To A Drinking Water Disaster, Especially In The Schuylkill River, Which Is A Vital Water Source For Almost 2 Million People and Businesses from Pottstown to Philadelphia.
• DEP and DRBC Are NOT Objective. Before Limerick Started Operating, These Agencies Gave Approvals Allowing Limerick To Start Operating, Knowing The Schuylkill River Could Not Sustain The Insatiable Water Needs Of Limerick’s Cooling Towers.
• Current DRAFT Permits Continue To Ignore Limerick’s Unprecedented Threats and Harms To Our Water.
• Both Agencies Plan To Issue Permits Knowing Limerick’s Dangerous TDS Discharges Can’t Meet Safe Drinking Water Limits Into The Schuylkill River, A Vital Drinking Water Source For Almost 2 Million People.
• DRBC’s Permit Jeopardizes The Water Supply Across 6 Counties and S.R. Water Quality.
• DEP’s NPDES Permit Is A Permit To Pollute The Schuylkill River:
­ With Radiation and Other Cooling Tower Toxics – With No Limits
­ With Woefully Inadequate Monitoring, Testing, and Reporting Which Are All Controlled By Exelon, A Company We Can’t Trust To Provide Full and Accurate Disclosure
­ With NO Independent Testing Of Limerick’s Most Dangerous Discharges Or Actual Oversight
• To Enforce The Law To Protect Our Water, Both DEP and DRBC Should Refuse To Issue Permits Until Exelon Agrees To FILTER Limerick’s Intake and Discharges, As Well As Wadesville Mine Water Discharges.
• Exelon Should Filter or Close Limerick Nuclear Power Plant.
• If The Public Doesn’t Speak Out, These Agencies Will Continue to Protect Exelon Profits At The Expense Of Our Water.

DRBC Was Negligent From The Beginning
• Limerick Nuclear Plant Should NOT Have Been Built Along The Schuylkill River. There’s Never Been Enough Water In The Schuylkill River, To Sustain The Insatiable Water Needs Of Limerick Nuclear Plant’s Cooling Towers.
• DRBC Approved Limerick Nuclear Plant’s 1st Docket in the 1980s, Allowing Limerick To Start Operating, Knowing There Wasn’t enough water in the Schuylkill River.
• Proof: DRBC’s requirement for Exelon to spend the money to transport water from the Delaware River by way of the Perkiomen Creek.
• Problem: DRBC failed to do the math showing billions of gallons of water MORE EACH YEAR would be withdrawn from the Schuylkill River than discharged, even after Delaware River supplementation.
• The Delaware River Provided Only A Fraction Of Water Supplementation Needed To Stop Schuylkill River Depletion Over The Past 27 Years.
• FOIA records show DRBC ignored concerns expressed by many in our region BEFORE Limerick’s water use was approved by DRBC. Concerns included – Limerick Nuclear Plant’s harmful impacts to the Schuylkill River, the public water supply, and public health.
• Concerns were justified. The injustice of Limerick’s long-term consequences on our water supply are magnified now in times of heat waves and drought.

Negligence In Current DEP and DRBC Permitting
• DEP and DRBC Pass The Buck and Allow Exelon To Control All Monitoring, Testing, and Reporting.
• DEP’s NPDES Permit Is A License for Limerick Nuclear Plant To Pollute – Without Limits.
• Exelon Would be Given 30 Months, AFTER The Permit Is Issued (April, 2013), to do studies to determine their own permit limits – It Would Be Like Us Setting Our Own Tax Rates.
• 24 Pipes Go Into The Schuylkill River From The Limerick Nuclear Plant Site, With An Exemption For Total Dissolved Solids,
Which Include Radiation and Cooling Tower Toxics.
• Concerns About Limerick’s Impacts To The Schuylkill River Now Include:
­ Radioactive and Other Dangerous Pollution Discharged Into The River With No Limit
­ Continued Over-Heating of the River
­ Drought Conditions Concentrating Radiation and Other Toxics Discharged Into The River
­ Cooling Tower Depletion Raising Worries About Dangerously Low River Flows or Even Drying Up
• It goes from Bad to Worse. Nearly 2 Million People Depend On The Schuylkill River for Their Water. There Will Be Less and
Less Usable Water As Populations Increase.
• There Is No Enforcement Power If DEP Passes the Responsibility for TDS Limits To DRBC.
• There Will Be No Future Input On Limerick’s Water Use And Discharges – DRBC’s Director Would Be The River Czar
• Public Officials Need To Speak Out – They’ve Been Negligent So Far – They Need To Get To The Hearing And Speak Out To
Protect the Public’s Water

WATER INCREASES For Limerick Nuclear Plant In DRBC’s Draft Docket – A Threat To Water Supplies Across 6 Counties.

Schuylkill River – Further Jeopardized By DRBC DRAFT Docket

­ INCREASE – 2 MILLION GALLONS MORE WITHDRAWN PER DAY (DRBC Docket)
Currently Limerick Nuclear Plant Withdraws 56.2 Million Gallons Per Day
Limerick Already Withdraws More Than 2 1/2 Times More Than The Total Withdrawn For All Pottstown and Norristown Customers Combined.
­ Pottstown Withdraws 5 Million Gallons Per Day – For 30,000 Customers
­ Norristown Withdraws 17 Million Gallons Per Day – For 87,000 Customers

­ INCREASE – COOLING TOWER USE – 2 MILLION GALLONS MORE PER DAY.
How Can We Afford 2 Million Gallons More Cooling Tower Steam Each Day Knowing It Contains Toxic Chemicals and Dangerous Particulate Matter PM-10
­ DRBC Docket Plans To Allow From 42 to 44 Million Gallons Per Day

 SCHUYLKILL RIVER DEPLETION – LIMERICK’S ROLE IS UNDENIABLE Limerick’s Cooling Towers Depleted Schuylkill River Flows By Billions of Gallons Each Year For Decades, Since 1985.
­ After 27 Years Of Operation, Limerick’s Drastic Water Withdrawals From The Schuylkill River and Cooling Tower Water Use Have Obviously Played A Major Role In Significant Depletion Of The Schuylkill River and Its Tributaries.
­ Limerick Likely Withdrew Over 20 Billion Gallons Of Schuylkill River Water EACH Year, And Only Returned 5 Billion Gallons (Heated and Radioactive).
­ It Would Have Taken 15 Billion Gallons Of Supplementation From Other Sources Each Year Since The Late 1980s To Prevent Depletion. That Didn’t Happen. In Fact, ACE Found No Proof That More Than 3 Billion Gallons Were Supplemented In Any Year.
Residents Who Use The Schuylkill River For Recreation Started Expressing Concern To ACE Over EXTREMELY Low Schuylkill River Flows In 2006.
­ Where They Once Needed A Boat To Cross, They Now Could Walk Across The River. The Manatawny Creek Became Nearly Dried Up. Other Tributaries Are Very Low.
­ Residents’ Concerns About Low Flows Started ACE’s Investigation Into Limerick’s Water Use.
­ DEP’s Own 1999 Booklet, “Water Is Life”, Expressed Concern About What DEP Called “RECORD LOW FLOWS” In the Schuylkill River.
­ DEP’s Contradiction Is Puzzling. While DEP Admitted In 1999 That The Schuylkill River Had Reached Record Low Flows, DEP Is Now Claiming There Is NO Difference In Flows Since Limerick Started Operating.
­ DEP Lost All Credibility In The Community Claiming Flows Didn’t Change.

 ENOUGH IS ENOUGH! Why Should More Schuylkill River Water Be Dedicated To Limerick Nuclear Plant? Limerick Should Cut Power, NOT Take 2 Million Gallons PER DAY MORE Of A Vital Public Water Resource.
1. The Schuylkill River Is A Vital Water Resource for Almost Two Million People From Pottstown To Philadelphia. Hospitals, Fire Companies, Schools, And Many Other Businesses Also Depend On The Schuylkill River For Water.
2. Public Demands Are Increasing Through Increased Populations and More Contaminated Groundwater Wells, While Water In The River Is Depleting Through Limerick’s Use and Increasing Heat Waves and Droughts.
3. Depletion Concentrates Limerick’s Radioactive And Other Toxic Discharges.

IMPACTS ON OTHER WATER RESOURCES
DRBC DRAFT DOCKET APPROVALS TO OPERATE LIMERICK NUCLEAR PLANT

Delaware River By Way Of Perkiomen Creek
• INCREASE – From 42 To 46.2 Million Gallons Per Day

Tamaqua’s Still Creek / Owl Creek Reservoirs
• INCREASE – From 36 to 43.3 Million Gallons Per Day

Wadesville Mine Pit Water
Contaminated Pumping Into The Schuylkill River Continued
• 446.4 Million Gallons Per Month Can Be Pumped UNFILTERED
• @ 10,000 Gallons Per Minute

Groundwater In Schuylkill County Around Wadesville Mine At Risk
DRBC’S DOCKET ALLOWS BILLIONS OF GALLONS OF GROUNDWATER TO CONTINUE TO BE TRANSFERRED FROM SCHUYLKILL COUNTY FOR USE AT LIMERICK NUCLEAR PLANT IN MONTGOMERY COUNTY, BY WAY OF THE SCHUYLKILL RIVER.
• Since 2003, To Operate Limerick Nuclear Plant, Exelon Pumped Billions Of Gallons Of Contaminated Wadesville Mine Pit Water Into The Schuylkill River.
• It Was Estimated In 1953, That Wadesville Mine Only Started With 3.6 Billion Gallons.
• Wadesville Mine Pit Water Recharges From Surrounding Groundwater In Schuylkill County.
• Even If Mine Water Pumping Is Done 6 Months A Year, That’s Almost 3 Billion Gallons PER YEAR Of Water Transported From Schuylkill County To Limerick.
How Many Years Can This Drain On Groundwater Around Wadesville Mine Continue Before Area Wells Are Impacted?

Groundwater Around Limerick Nuclear Plant
Limerick’s Groundwater Withdrawals Could Jeopardize Residential Well Water.
• Limerick Nuclear Plant Uses Four Groundwater Wells Located Onsite.
• Total Annual Groundwater Withdrawal Allocation – 73.2 Million Gallons Per Year
• Only A Fraction Is Returned To The Ground.
• WELLS WITHIN 1 MILE From The Center Of The Limerick Nuclear Plant Site:
46 Domestic Withdrawal Wells
13 Residences LESS Than 1 Mile From Reactor Building
3 Homes 1 Mile From Reactor Building
2 Commercial Wells
Exelon Was Advised This Allocation Will Only Continue Until 2019. Then What?
With Increasing Heat And Drought Conditions,
 Can Anyone Prove There Will Be Enough Groundwater For Residents, Other Businesses, And Limerick Nuclear Plant’s Huge Groundwater Withdrawals;
 Even Until 2019?
 Until 2029, When Limerick’s Current License Expires?
 Until 2049, If Limerick’s License Is Renewed?

MAJOR INJUSTICE IN DRBC’S DRAFT DOCKET – In Essence, DRBC’s DOCKET ALLOWS “EMINENT DOMAIN” OVER ALL OUR WATER RESOURCES IN THE EVENT OF A LIMERICK NUCLEAR PLANT ACCIDENT OR MELTDOWN.
• In A Limerick Nuclear Plant Emergency Or Meltdown, Limerick Would Get Unrestricted Access To All Water Resources, Including Groundwater, As Long As The Need Exists – Days, Weeks, Or Months.
­ Limerick Only Stores Enough Emergency Water Onsite For 48 Hours, and That Includes All Limerick’s Cooling Tower Water.
­ Exelon Is Required To Have A 30-Day Supply. They Must Be Counting On All Our Water.
­ What Happens In A Drought?. Groundwater Withdrawals at Limerick Could Run Residential Wells Dry For Miles Around Limerick, As Well As The Schuylkill River.
• We Learned Accidents and Meltdown Threats At Limerick Are Increasing. We Should NOT Face The Risk Of Losing All Access To A Safe, Usable Water Supply Due To Limerick Nuclear Plant.
• Exelon Should Not Be Given Legal Access To All Our Water.
 LIMERICK SHOULD BE CLOSED BEFORE THERE IS A MELTDOWN AND EVERYONE LOSES ALL THEIR WATER RESOURCES.

DANGEROUS DISCHARGES INTO THE SCHUYLKILL RIVER

RADIOACTIVE DISCHARGES Into The Schuylkill River From Limerick Nuclear Plant
• Limerick Nuclear Plant’s Routine and Accidental Radioactive Discharges Into The Schuylkill River Are The Most Dangerous Threat To Those Whose Water Comes From The Schuylkill River.
• 5-Year Draft Permits For Limerick Nuclear Plant’s Discharges Have NO LIMITS For ALL Limerick’s Radionuclides Discharged Into the Schuylkill River,
• Limerick’s Radioactive Discharges Can Include Over 100 Different Radionuclides, Some With Very Long Half-lives. For Example, Strontium-90 has a half-life of 28 years. Cesium-137 has a half-life of 30 years.
• Additive, Cumulative, and Synergistic Impacts From All Radionuclides Released From Limerick Nuclear Plant Are Unknown, But Obviously Significant After 27 Years Of Discharges.
• Radionuclides Discharged From Limerick Into The Schuylkill River Do NOT Disappear. They Travel With Schuylkill River Water, But Are Rarely Monitored, Tested, Reported, or Filtered Out At Water Treatment Plants From Limerick to Philadelphia.
• Almost Two Million People Who Use Schuylkill River Water Are Exposed To These Radionuclides Through Their Drinking Water, and Through Food Grown In The Region Using Water From The Schuylkill River.
• Evidence of Harm – Philadelphia Is About 21 Miles Downstream From Limerick Nuclear Plant’s Radioactive Discharges. Philadelphia’s Drinking Water Was Found To Have The Highest Radiation Level Of All 66 Water Treatment Plants Testing Across The Nation After Fukushima. Iodine-131 Was The Radionuclide Tested. Limerick Discharges Iodine-131 Into The Schuylkill River.
• Limerick’s Radionuclides Also Get Into The Sediment and Fish, A Fact Proven By Exelon’s Own Radiological Monitoring Reports To NRC.
• DEP and DRBC Falsely Assert That NRC Protects Us From Limerick’s Radioactive Discharges Into The River. In fact, NRC NEVER TESTED FOR RADIOACTIVE DISCHARGES INTO THE SCHUYLKILL RIVER FROM LIMERICK, NEITHER HAVE DRBC OR DEP.
 RADIATION DISCHARGES ARE BEING IGNORED BY DEP AND DRBC.
 THERE IS NO JUSTIFICATION FOR ISSUING THESE 5-YEAR PERMITS THAT RESULT IN LIMERICK NUCLEAR PLANT ROUTINELY DISCHARGING A BROAD RANGE OF RADIONUCLIDES INTO A VITAL DRINKING WATER SOURCE:
­ WITH NO ACCOUNTABILITY FOR THE CONSEQUENCES OF EXPOSURE TO THAT RADIATION
­ WITHOUT REQUIRING LIMERICK NUCLEAR PLANT TO FILTER
 LIMERICK’S RADIOACTIVE DISCHARGES ARE LEGALLY PERMITTED:
­ WITHOUT LIMITS
­ WITHOUT REQUIREMENTS FOR INDEPENDENT MONITORING OF DISCHARGES FOR ALL RADIONUCLIDES ASSOCIATED WITH LIMERICK’S OPERATIONS.
­ WITHOUT REQUIREMENTS FOR EXELON TO FILTER AT THE DISCHARGE POINT
­ WITHOUT REQUIREMENTS FOR WATER COMPANIES TO DO CONTINUOUS MONITORING AND FILTRATION FOR ALL LIMERICK’S RADIONUCLIDES
COOLING TOWER TOXICS ARE DISCHARGED INTO THE SCHUYKILL RIVER
 WITH NO LIMITS
 WITH “EXEMPTIONS” FROM REGULATION IN DEP’S NPDES PERMIT
• Massive Amounts of Extremely Toxic and Corrosive Chemicals Are Dumped Into The Cooling Towers Every Single Day.
• Chlorine is just one of a broad range of toxics used in the cooling towers. Chlorine, As Sodium Hypochlorite, Is Used At Limerick Every Day (16,000 to 58,000 POUNDS PER DAY).
• Most Cooling Tower Toxics Are Not Measured, Regulated, or Reported In Limerick’s Discharges Into The Schuylkill River.

TOTAL DISSOLVED SOLIDS (TDS) TRANSPORT RADIATION AND COOLING TOWER TOXICS INTO THE SCHUYLKILL RIVER
• Both DEP and Exelon Admit That Limerick Nuclear Plant Cannot Meet Safe Drinking Water Standards (500 mg/L) Under The Clean Water Act For Dangerous Limerick TDS Discharges.
• One 2010 Sample Was Almost 5 Times Higher Than The Safe Drinking Water Standards.
• There Was NO PENALTY, Even Though The Schuylkill River Is A Vital Source Of Drinking Water for Almost 2 Million People From Pottstown To Philadelphia.
• Limerick Nuclear Plant Drastically EXCEEDED Even DRBC’s TDS Discharge Limit of 1,000 mg/L in 13 of 15 Samples for 2010.
• Given The Content Of TDS Discharges From Limerick Nuclear Plant Into A Vital Drinking Water Source, DEP’s NPDES PERMIT IS FAILING TO PROTECT PUBLIC HEALTH.
1. DEP MUST REQUIRE FILTRATION FOR TDS FROM LIMERICK’S RADIOACTIVE AND COOLING TOWER DISCHARGE PIPE 001 – NOT PROVIDE A PERMIT EXEMPTION FOR TDS FROM THIS DANGEROUS DISCHARGE PIPE.
2. IT IS NOT ACCEPTABLE FOR DEP TO ISSUE POLLUTION DISCHARGE PERMITS TO LIMERICK NUCLEAR PLANT WITH NO TDS LIMITS, BECAUSE LIMERICK CANNOT MEET STANDARDS IN PLACE TO PROTECT DRINKING WATER.
3. WHY WOULD EXELON BE PERMITTED TO DO THEIR OWN SAMPLING 30 MONTHS “AFTER” PERMITS ARE ISSUED, TO SATISFY DRBC REQUIRMENTS OF 1,000 mg/L?
4. A BODY OF EVIDENCE SHOWS WHY WE CAN’T TRUST EXELON. THEY HAVE A VESTED INTEREST IN THE OUTCOME. WHO COULD BELIEVE THEIR SAMPLING?
5. DEP SHOULD NOT TURN OVER TDS REGULATORY AUTHORITY TO DRBC, AN AGENCY WITH NO TEETH TO REQUIRE ENFORCEMENT OF LIMITS.

24 DISCHARGE POINTS FROM LIMERICK NUCLEAR PLANT END UP IN THE SCHUYLKILL RIVER.
 MONITORING REQUIREMENTS ARE WOEFULLY INADEQUATE AND UNPROTECTIVE.
• 2 TIMES PER MONTH – Monitoring For Outfall 001, The Most Dangerous Discharge Point Because It Discharges Radiation, Cooling Tower Chemicals, and TDS.
­ NO ONE MONITORS FOR RADIATION OR OTHER COOLING TOWER TOXICS.
Comprehensive Independent Testing From Outfall 001 For All Limerick’s Radionuclides Has Never Been Done By Any Agency, Including NRC, DRBC, nor DEP
­ Without Monitoring For All Radionuclides and Toxics It Is Impossible To Identify Spikes or Determine Health Threats.
­ Without Continuous Monitoring It Is Impossible to Identify Spikes
• 1 TIME PER YEAR – Monitoring for All Other 23 Discharge Points From Limerick’s Site.

Monitoring, Calculating, Testing, And Reporting Are All Unreliable And Unprotective
• Exelon, The Company With A Vested Interest In The Outcome, That Has Shown It Can’t Be Trusted For Full and Timely Disclosure Controls The Entire Process, With Lax Agency Oversight And NO Enforcement for Violations – Details www.acereport.org #20 “Why We Can’t Trust Exelon”
• Exelon’s Monitoring Reports Are Loaded With Loopholes and Deception.
• Water Companies Don’t Protect Your Water From Limerick’s Radioactive Discharges
• 3-19-12 Radioactive Spill, Is An Example Of How Public Health Is Jeopardized By Exelon
­ The Public Was NOT Notified Until 23 Days Later
People From Limerick to Philadelphia Did Not Know It Could Have Been Unsafe To Use Their Water.
­ Regulators / Elected Officials Not Notified Immediately Then Remained Silent. ‘
­ Exelon, NOT WATER COMPANIES, Tested After The Radioactive Spill.

HEATED DISCHARGES – Into The Schuylkill River
• Limerick Discharges 14.2 Million Gallons Per Day = Over 5 Billion Gallons Per Year.
• Discharges Are Permitted To Be As High As 110 Degrees.
• After 27 Years, 135 Billion Gallons Of Limerick Nuclear Plant’s Heated Discharges, Up To 110 Degrees, Obviously Raised The Temperature Of The Schuylkill River From Limerick to Philadelphia.

TEMPERATURES In The Schuylkill River REPEATEDLY EXCEEDED The 87 Degree Limit,
2 MILES DOWNSTREAM From Limerick’s Heated Discharges, At Royersford’s Intake.
• DEP Has An 87 Degree Schuylkill River Water Temperature Limit.
• DRBC’s Ambient Temperature Limit of 87 Degrees For The Schuylkill River.
• 2 Miles Downstream from Limerick’s Heated Discharges The River’s 87 Degree Limit Was Repeatedly EXCEEDED – At Royersford’s PA American Water Intake.
• It is predictable that after 27 years of Limerick Nuclear Plant’s 24/7 highly heated discharges, that the river temperature would EXCEED 87 Degrees.
• Limerick Discharges Are Allowed To Be 110 Degrees, 23 Degrees Higher Than The River’s Temperature Limit.
• Limerick’s heated discharges could be even higher than 110 degrees. ONLY Exelon knows temperatures actually released. There has never been independent long-term heat monitoring by any agency, directly beyond Limerick’s heated discharges into the Schuylkill River.
• Harmful impacts could obviously be significant to ecosystems, yet there has never been a long-term independent study.
• Huge fish kills occurred repeatedly close to Limerick’s heated discharge point. Limerick’s heated, radioactive discharges were the most likely cause, but there was never an independent investigation to prove cause.
 DEP/DRBC NEGLIGENCE.- BOTH AGENCIES INTEND TO ISSUE LIMERICK NUCLEAR PLANT’S PERMITS ALLOWING HEATED DISCHARGES WITHOUT ADDRESSING THE FACT THAT LIMERICK NUCLEAR PLANT’S HEATED DISCHARGES ARE OVERHEATING THE RIVER. THERE IS:
­ NO PENALTY FOR OVERHEATING OF THE RIVER
­ NO REQUIREMENT FOR INDEPENDENT RIVER TEMPERATURE MONITORING AT ROYERSFORD, 2 MILES DOWNSTREAM FROM LIMERICK DISCHARGES.
­ NO REQUIREMENT FOR LIMERICK TO CUT POWER, TO LOWER TEMPERATURES, EVEN IN EXTREME HEAT AND DROUGHT.
 THERE IS ONLY A REQUIRMENT “AFTER” THE PERMIT IS ISSUED APRIL 2013, FOR EXELON TO PREPARE A CHART ON HOW OFTEN TEMPERATURES ARE EXCEEDED OVER 87 DEGREES, BASED ON ONLY EXELON’S OWN HEAT MONITORING AT ROYERSFORD.

DRBC’S 59 DEGREE TEMPERATURE RESTRICTION SHOULD NOT BE REMOVED
• DRBC Had A 59 Degree Temperature Restriction Since The Early 1980s, Before Limerick Started To Operate In 1985.
• According to DRBC Documents, The Reason For The 59 Degree Temperature Restriction –
“To Protect Schuylkill River Flow And Water Quality Conditions Until 2020”.
• Dissolved Oxygen Testing Is Easily Manipulated To Hide Elevations, Yet Based Only On Exelon’s Dissolved Oxygen Testing, DRBC Agreed To Eliminate Its Temperature Precaution, Originally In Place To Protect The Schuylkill River Flow and Water Quality Conditions That Were To Be Enforced Until 2020.
• DRBC’s DRAFT DOCKET Removes This Decades Old Protection For Schuylkill River Quality and Flow, Regardless Of Harmful Consequences.
 THIS IS UNACCEPTABLE. EVIDENCE SHOWS WE CAN’T TRUST EXELON.
 DRBC’S 59 DEGREE RESTRICTION SHOULD BE REINSTATED MINIMALLY UNTIL 2020.

TOXIC MINE WATER PUMPING INTO THE SCHUYLKILL RIVER MUST BE FILTERED IF EXELON WANTS TO KEEP USING THAT WATER FOR LIMERICK OPERATIONS.

• DEP Said, “Mine Water Is The Worst Threat To Groundwater In PA”, Yet DEP Is A Cheerleader For Exelon’s Massive Mine Water Pumping (UNFILTERED) Into the Schuylkill River.
• Billions of Gallons Of Toxic, Unfiltered Mine Water Have Been Pumped At 10,000 Gallons PER MINUTE Into The Schuylkill River, A Vital Drinking Water Source, Since 2003, For The Benefit Of Limerick Nuclear Plant Operations and Exelon’s Profits.
• DEP Lost Credibility When Comparing Mine Water Run-Off To Pumping 10,000 Gallons Per Minute And Making The Unsubstantiated Claim That Dilution Is The Answer To This Intentional Pollution.
• If DRBC ‘s Docket for Limerick Is Approved, Billions More Could Be Pumped EVERY YEAR, Compounding And Increasing Problems and Threats.

 This Is Without A Doubt, An Additive And Cumulative Toxic Threat To Public Health Which Can Also Increase Costs To Water Treatment Systems and Their Customers.
 Major Toxics Discharged Into the Schuylkill River Due to Wadesville Mine Water Pumping Include Iron, Manganese, and TDS, All Of Which Were Found Elevated By 2008, After 5 Years of Pumping, At Pottstown Waste Water Treatment Plant, The First Schuylkill River Drinking Water Intake After Wadesville Mine Water Pumping.

• Iron – 20 Times Safe Drinking Water Standards – Discharge Limit From Wadesville Mine Pit Into The Schuylkill River. Iron Can Cause Cancer and Hemochromotosis, As Well As Costly Breakdown Of Equipment At Water Treatment Plants.
• Manganese – 80 Times Safe Drinking Water Standards – Discharge Limit From Wadesville Mine Pit Into The Schuylkill River. Manganese Can Cause Permanent Brain Damage, After 10 Years Of Exposure Through Showering 10 Minutes A Day.
• Total Dissolved Solids (TDS) – Caused Problems At Pottstown After Only A Few Years Of Pumping.

 DRBC’s Docket Allows Exelon To Pump Up to 432 Million Gallons Per Month. Exelon Should Be Required to Filter All Toxic Mine Water Pumped Into The Schuylkill River For Limerick Operations, Or Exelon Should Be Stopped From Pumping It.

Changes Can Be Made To DEP’s Draft Permit Requiring Exelon To Be Accountable To Reduce Toxic Treats To Water And Health, In Order To Follow The Law And To Improve Oversight and Enforcement Of Violations.

PA DEP DRAFT NPDES PERMIT – NO: PA0051926
Urge PA Elected Officials To Ask DEP and Governor Corbett To:
1. Remove Exemption For Radiation And Cooling Toxics In TDS Pollution Discharges
2. Require Strict Enforcement And Meaningful Penalties For Violations Of Clean Water Act Standards
3. Require Independent Comprehensive Testing
4. Require Immediate Notification Of Radioactive Spills
5. Require Exelon To Maintain All Records Permanently, Not Just 3 Years
6. Require Exelon To Filter Or Close Limerick
7. Require Reverse Osmosis Filtration For TDS, With Frequent Filter Changes To Protect The River and Public Health

DRBC’s Planned Approvals For Limerick Nuclear Plant Will Lead To Increased Threats To Public Water In Six Counties

DRBC DRAFT DOCKET – NO. D-1969-210 cp-13
Urge PA Elected Officials To Ask DEP and Governor Corbett To:
1. NOT Allow Increased Water Use for Limerick Nuclear Plant
2. Stop Mine Water Pumping for Limerick Operations or Require Exelon to Filter
3. NOT Issue Limerick’s Docket Without TDS Limits For Outfall 001
4. Require Limerick to Reduce Operations or Shut Down When River Temperatures Exceed 87 Degree Limit
5. Require Unannounced Independent Testing for Low Flow Limits, Temperature Restrictions, and All Radiation and Toxic Chemicals
6. Require Public Notice and Input For All Future Limerick Nuclear Plant Water Use
7. Require An Independent Mediator to Hear and Adjudicate All Water Related Claims Against Limerick and Exelon

If Exelon Refuses To Filter and Comply With Laws To Protect Our Water,
Then Limerick Nuclear Plant’s Water Permits
Should NOT Be Approved and Limerick Should Be Forced To Close.

For More Information – ACE Website www.acereport.org
­ Section #6 – “Schuylkill River, Limerick’s Operations Threaten Drinking Water Disaster”
­ Section #20 – “Why We Can’t Trust Exelon”