Category Archives: Threats to Drinking Water

Limerick Nuclear Plant Is Polluting Our Drinking Water

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OP-ED: Nuclear Plant Is Polluting Our Drinking Water
Tuesday, September 16, 2014

Clean safe water is not a luxury. It’s essential for survival, including personal hygiene, food preparation and cooking. Allowing the intentional destruction of a vital water resource supplying almost 2 million people, for the profit of a multi-billion dollar corporation, is a moral, ethical disgrace.

Why should one business, Limerick Nuclear Plant, be permitted to run the Schuylkill River dry and poison it to such a degree that it can become unusable for other businesses and residents?

It is infuriating and unacceptable that our politicians, agency officials, other leaders, and water companies would allow such injustice to continue. Deafening silence continues, while almost two million people from Pottstown to Philadelphia, face a water and public health crisis.

NRC and DEP might as well be working for Exelon.

• Instead of stopping Limerick’s unprecedented threats and harms to the Schuylkill River, NRC plans to relicense Limerick.

• DEP plans to issue an NPDES water pollution permit with dangerous exemptions and loopholes for Limerick’s radiation and cooling tower toxic discharges, and overheating the river.

PA DEP is allowing Limerick to violate federal protective water law and standards. DEP has the power to deny Limerick an NPDES pollution permit renewal. Instead, DEP plans to approve a permit with shocking exemptions.

Instead of exemptions from compliance, Exelon, Limerick’s owner, should be required to filter Limerick’s dangerous discharges to meet Safe Drinking Water standards.

Exelon is profiting and should be accountable to minimize damage.

Clean water is the law of the land since 1972. Why would PA DEP ignore protective federal clean water laws? Because it saves Exelon the cost of filtration.

Governor Corbett appointed Michael Krancer, a former Exelon attorney, to head DEP. Krancer stayed long enough to assure Limerick’s exemption from federal water laws.

DEP’s unethical negligence has health and financial consequences.

• Suffering and health care costs will increase. DEP plans to allow unlimited amounts of Limerick’s broad range of radionuclides and toxic cooling tower chemicals to be discharged into the river every day with up to 14.2 million gallons of wastewater.

• It’s cost prohibitive for water companies to monitor or filter Schuylkill River water intake for all Limerick’s cancer causing radionuclides and other toxics.

• Increasing costs to water companies for Limerick’s massive Total Dissolved Solids discharges will ultimately be passed on to their customers. Example: Norristown shut down water distribution for four days recently, resulting in costly plant upgrades. Limerick uses two chemicals that can cause brown water (NPDES Permit).

• Rather than requiring Exelon to slow operations when Limerick discharges overheat the river, DEP plans to eliminate river temperature restrictions that protect aquatic life, public health, and safety.

How can NRC relicense Limerick? There isn’t enough water in the Schuylkill River to sustain daily operations, much less for meltdowns.

• Limerick withdraws over two and a half times more water than the combined withdrawal for Pottstown and Norristown water customers, returning just one quarter to the river. The rest goes into the air as steam from the cooling towers.

• Limerick’s cooling towers depleted the river since the late 1980s. By 1999, DEP reported that it reached record low flows. It’s getting worse. Where you once needed a boat to cross, you can now walk across. Tributaries are even drying up.

If your water is coming from the Schuylkill River through PA American Water, Aqua PA, or your municipality, know your risks.

Visit www.acereport.org. Section #6 “Schuylkill River – Limerick’s Operations Threaten A Drinking Water Disaster” and Video Blogs Updates.

Safe drinking water must be the legacy we leave our children.

To save the Schuylkill River and restore an ample, safe water supply for almost two million people and other businesses, Limerick must close. Otherwise, unprecedented threats and harms will increase, expediting a drinking water disaster.

Final permits are pending. Contact elected and agency officials today. For more information: www.acereport.org. To join the fight: aceactivists@comcast.net or (610) 326-2387.

DR. LEWIS CUTHBERT
ACE President

The Mercury (http://www.pottsmerc.com)
URL: http://www.pottsmerc.com/opinion/20140917/op-ed-nuclear-plant-is-polluting-our-drinking-water

NRC’s Failure to Acknowledge Limerick Nuclear Plant’s Unprecedented Threats and Harms to Water Across Six Counties Can Result in a Drinking Water Disaster

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Radioactive groundwater and drinking water threats from Limerick will increase as long as the nuclear plant operates. Limerick should be required to close early. Instead of providing protection to the environment and public, NRC displays astounding willful blindness as it ignores, denies, and dismisses documented threats and harms.

VIDEO BLOG – PART 2 AUGUST 2013

NRC HAS NEGLIGENTLY DISMISSED LIMERICK NUCLEAR PLANT’S UNPRECEDENTED THREATS AND HARMS TO OUR DRINKING WATER

THE SCHUYLKILL RIVER -
LIMERICK NUCLEAR PLANT IS SLOWLY BUT SURELY DESTROYING THE SCHUYLKILL RIVER, THE VITAL DRINKING WATER RESOURCE FOR ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA.

LIMERICK THREATENS A DRINKING WATER DISASTER, YET NRC IRRATIONALLY CLAIMS HARMS ARE “SMALL”

INDISPUTABLE FACTS PROVE LIMERICK IS CAUSING UNPRECEDENTED THREATS AND HARMS TO THE SCHUYLKILL RIVER, INCLUDING:

EXTREMELY DANGEROUS DISCHARGES

• Radiation

• Cooling Towers Toxics – including Extremely Dangerous Chemicals and Pathogens

• Heated Discharges – 110 Degrees (Over 20 Degrees Higher Than River Heat Limit)

• 14.2 Million Gallons Discharged From Limerick Into The River Each Day.

• In 2013 Limerick Was Given A Pollution Permit Without Limits (A Free Pass To Poison The River) Because Limerick Can’t Meet Safe Drinking Water Limits For The Kind of Pollution (TDS) That Transports Radiation and Other Toxics Into the River. Exelon Could Filter, But Won’t.

DANGEROUS DEPLETION

• Limerick’s Cooling Towers Are An Effluent Stream From The River To The Sky -Discharging Up To 42 Million Gallons Of Toxic, Highly Corrosive Steam Into Our Air Each Day

• Limerick Withdraws 58.2 Million Gallons of Water From The Schuylkill River Each Day – More Than Double Total Withdrawn For Norristown, Pottstown, and Phoenixville Water Customers

• Limerick Returns Only 1/4 of The Water It Withdraws – Billions Of Gallons Are Depleted From The Schuylkill River Each Year, Even After Supplementation.

• Limerick Started Operating in 1985. By 1999, The Schuylkill River Had Record Low Flows. Now You Can Walk Across The River Where You Once Needed A Boat.

TOXIC MINE WATER PUMPING TO OPERATE LIMERICK

• Exelon Pumped Billions of Gallons of Unfiltered Toxic Mine Pit Water Into the Schuylkill River (Up to 80 times Safe Drinking Water Standards) to Supplement the Flow for Limerick Operations.

• As Long As Limerick Operates, Billions of Gallons More Toxic Mine Water Will Continue to be Pumped Into This Vital Drinking Water Source.
LIMERICK THREATENS THE WATER SUPPLY ACROSS SIX COUNTIES

• Extraordinary Water Use Caused By Limerick’s Cooling Towers and The Potential For An Endless Water Supply For A Limerick Meltdown Threatens Water Availability From Schuylkill County to Philadelphia, And From The Delaware River.

RADIOACTIVE THREATS TO PUBLIC HEALTH, WILDLIFE, AND FISH

A BROAD RANGE OF DANGEROUS RADIONUCLIDES ARE IN SCHUYLKILL RIVER WATER, FISH, AND SEDIMENT. (Confirmed by Exelon’s Radiological Monitoring Reports to NRC)

RADIATION WAS FOUND IN PHILADELPHIA’S WATER (20 miles downstream from Limerick) AT SOME OF THE HIGHEST LEVELS IN THE NATION.

WATER COMPANIES WITHDRAWING SCHUYLKILL RIVER WATER ARE NOT REQUIRED TO DO REGULAR RADIATION TESTING OR FILTRATION.

NRC’S DRAFT EIS FOR LIMERICK FAILED TO ACCURATELY REFLECT LIMERICK’S UNPRECEDENTED THREATS AND HARMS TO VITAL DRINKING WATER RESOURCES FOR MILLIONS. LIMERICK’S TREATS TO WATER ARE CLEARLY ENORMOUS, NOT SMALL, AS FALSELY CLAIMED BY NRC.

10-26-11 ACE provided NRC with a vast body of evidence in written testimony for Limerick’s EIS, including detailed analyses of Limerick Nuclear Plant’s water pollution permits and Limerick’s water use docket.
• ACE’S Detailed Analyses Of Limerick’s Water Pollution Permits, Water Use Docket, AND Documents Obtained Through FOIA and PA Right-To-Know, As Well As Other Information Provided to NRC Should Have Led NRC To A Clear Understanding Of The Grave Threats and Harms To The Schuylkill River And The People Using The Water As A Result Of Limerick Nuclear Power Plant Operations.

FACTS SUGGEST THE SCHUYLKILL RIVER CANNOT SUSTAIN LIMERICK’S USE AND ABUSE UNTIL 2049.

LIMERICK SHOULD BE REQUIRED TO CLOSE NOW TO SUSTAIN A SAFE, USABLE WATER SUPPLY FOR MILLIONS OF RESIDENTS AND MANY OTHER BUSINESSES.

Historic evidence proves it was clear even before Limerick Nuclear Plant was constructed, that the Schuylkill River was unable to sustain Limerick’s insatiable water use and abuse. It is not clear the river can continue to sustain the wide range of damages caused by Limerick operations even until Limerick’s current licenses expire in 2029.
• There may not be enough safe usable water for the almost two million people and other businesses that need the Schuylkill River for their water supply until 2029.
• A meltdown requiring massive amounts of water could cause millions to lose access to safe water

Detailed evidence below in this video blog supports ACE’s concerns about Limerick’s indisputable threats and harms to vital drinking water resources and ACE’s conclusion that Limerick should close now to protect these vital water supplies.

LIMERICK’S RADIOACTIVE GROUNDWATER

• Decades of Limerick’s leaks and spills have contaminated the groundwater under the Limerick site.

• Radiation from Limerick’s leaks and spills was never cleaned up.

• Monitoring is completely controlled by Exelon, the company with a vested interest in the outcome that has shown here and elsewhere that it can’t be trusted to provide full and accurate disclosure related to radioactive water contamination.

• Even Exelon’s monitoring has confirmed radiation in 15 of 15 monitoring wells.

• Monitoring is woefully inadequate to determine the full extent of the spread of underground radioactive contamination in this fractured bedrock aquifer. Only 15 monitoring wells are placed by Exelon on Limerick’s 600 acres.

• Testing confirms many radionuclides in groundwater (at least 12), proving it is not just tritium as claimed by Exelon and NRC.

• There is no guarantee that Limerick’s radioactive contamination has not traveled into nearby residential and commercial wells.
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
175 Feet From Reactor – 1 Potable Water Supply Well

• Health threats associated with the kinds of radionuclides detected in groundwater include:
Cancer – Birth Defects – Mutations – Miscarriages – In 1st and/or Successive Generations

 RADIOACTIVE GROUNDWATER AND DRINKING WATER THREATS WILL INCREASE AS LONG AS LIMERICK OPERATES. LIMERICK SHOULD BE REQUIRED TO CLOSE EARLY TO MINIMIZE RISKS FROM RADIOACTIVE WATER.

• There Are Countless Opportunities For Breakdowns and Leaks Under Limerick Nuclear Plant Which Will Increase Radioactive Groundwater Contamination.

Miles of hard to inspect aging buried pipes under Limerick transport highly corrosive and radioactive fluids.
Evidence shows pipes and fittings are already corroding and deteriorating.
Leaks can go long periods of time without being detected.
Earthquakes can cause leaks by shaking and breaking in Limerick’s miles of underground pipes

Detailed evidence in this video blog supports ACE’s conclusion that Limerick should close now to prevent increased radioactive groundwater contamination under Limerick that can spread into nearby wells.

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

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

Fax (609) 883-9522
Paula.Schmitt@drbc.state.nj.us

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

Tell DEP to Protect Our Water! Sample Letter to Send to DEP

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Jennifer Fields, Clean Water Management Program Manager
PA Department of Environmental Protection
2 E. Main Street
Norristown, PA 19401
Jefields@pa.gov

RE: Limerick Nuclear Plant’s NPDES Permit No. PA0051926

Dear Ms. Fields,

DEP’s mission is to protect public water and public health. We have a right to clean water under Clean Water Laws, which DEP should be enforcing. DEP’s NPDES permits are permits to pollute our water.

Limerick Nuclear Plant’s discharges (5 billion gallons per year), are by far the worst threat to the Schuylkill River and public health because they include a broad range of radionuclides, some with very long half-lives.

Loopholes and exemptions in Limerick Nuclear Plant’s DRAFT NPDES permit ignore Limerick’s most dangerous discharges into the Schuylkill River, a vital water resource for almost two million people from Pottstown to Philadelphia. Harmful impacts from Limerick Nuclear Plant’s discharges on our water and health do not disappear because DEP allows permit loopholes and exemptions.

To protect Schuylkill River water and health of almost two million people, I urge DEP to make the following changes to the DRAFT NPDES permit for Limerick Nuclear Plant:

Changes Needed to DEP’s DRAFT NPDES Permit Include:

1. Remove the permit EXEMPTION for Total Dissolved Solids from Outfall 001

Justification:
• Outfall 001 TDS transports radiation and cooling tower toxics, Limerick’s most dangerous pollution into the Schuylkill River.
• The Safe Drinking Water TDS limit is 500 mg/L. DEP and Exelon both admitted Limerick can’t meet Limerick’s previous limit of 1000 mg/L. Previous discharges were up to over 2,400 mg/L. Exempting this harmful pollution because Limerick can’t meet the limit is negligent.
• With NO TDS permit limit, Limerick circumvents enforcement of Safe Drinking Water standards under Clean Water Laws, while continuing to seriously jeopardize water and health.

2. Require Exelon to FILTER TDS from Outfall 001 with reverse osmosis or CLOSE Limerick.

Justification:
• Limerick routinely discharges a broad range of radionuclides, including Iodine-131, Cesium-137, and Strontium-90, into the Schuylkill River with TDS discharges. There is no safe level of exposure according the National Academy of Sciences. Added, cumulative, and synergistic impacts while unknown, are obviously significant.
• DEP can reduce Limerick’s radioactive discharges by requiring TDS filtration. While filtration could be expensive for Exelon, radioactive contamination of vital water supplies could be far more costly to the public.

3. Conduct independent, comprehensive monitoring

Justification:
• All monitoring, testing, and reporting are controlled by Exelon, a company that has repeatedly proven here and elsewhere, that it can’t be trusted to provide full, accurate, and timely disclosure.
• DEP’s monitoring requirements for Limerick Nuclear Plant are woefully inadequate. For example:
 2 times a month for Outfall 001 and NOT for radiation and some cooling tower toxics in TDS,
 1 time a year for all other 23 discharges, directly and indirectly, into the Schuylkill River.
• If DEP doesn’t have the funding for meaningful oversight, Limerick should close.

4. Require Exelon to maintain all records permanently, not just 3 years.

Justification:
• Records should be put into electronic files with back-up CDs that should be maintained until the completion of decommissioning.

5. Require IMMEDIATE PUBLIC NOTIFICATION of radioactive spills

Justification:
• Unless the public is notified immediately, people are not given an opportunity to avoid exposure to accidentally increased radioactive exposure.
• The public was not notified until 23 days after Limerick’s 3-19-12 radioactive “spill”. Public health was jeopardized. Notification needs to be immediate, not just to DEP, but also for the public.

Please provide detailed responses to each of my specific requests for changes which would result in reduced threats to public water and health, related to Limerick Nuclear Plant’s NPDES permit.

Sincerely,