Limerick Can Be Closed Now, Despite Relicensing

Limerick Can Be Closed Now, Despite Relicensing

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

URL: http://www.pottsmerc.com/opinion/20150127/relicensing-limerick-nuke-plant-ignores-safety-risks Top of Form

Relicensing Limerick Nuke Plant Ignores Safety Risks

Tuesday, January 27, 2015

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

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

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

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

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

• Radioactive poisoning of our air and water

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

• Schuylkill River depletion

• Pumping toxic mine water into the river for Limerick operations

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

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

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

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

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

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

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

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

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

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

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

Dr. Lewis Cuthbert

President, Alliance for a Clean EnvironmentTop of Form

Bottom of Form

© 2015 The Mercury (http://www.pottsmerc.com)

Limerick Steps On The Gas, Driving Recklessly Toward The Cliff

Limerick Steps On The Gas, Driving Recklessly Toward The Cliff

The Mercury (http://www.pottsmerc.com)Top of Form

Limerick Plant Heading Over Catastrophic Nuclear Cliff

Thursday, January 15, 2015

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

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

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

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

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

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

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

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

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

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

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

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

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

Betty and Charlie Shank

Pottstown

Limerick Relicensing Is A Big Mistake

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

URL: http://www.pottsmerc.com/opinion/20141022/op-ed-limerick-re-licensing-is-a-big-mistakeTop of Form

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

Tuesday, October 21, 2014

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

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

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

Hollow evacuation plans, lack of meaningful regulation, perfunctory public inclusion, and NRC’s willful blindness to the consequences of our routine radiation exposure increase public risk. It’s a nightmare, affecting the health of our families and the environmental legacy we leave our children and grandchildren.

Back in the 1980s before Limerick construction was complete, a suit was filed when the public understood that Limerick operations would violate clean air standards and that design alternatives should have been considered. The suit was won in court, but successfully stalled until Limerick construction was complete. Back then, too many officials fell into the trap of weighing economic factors more heavily than public protection. Elsewhere, more enlightened thinking led to cancelled construction plans and closed plants.

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

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

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

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

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

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

— Betty and Charlie Shank

Pottstown

Terrorist Threats At Limerick Pose Catastrophic Risks

Terrorist Threats At Limerick Pose Catastrophic Risks

ACE wants a safer future for you and your family.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

Limerick Nuclear Plant Is Polluting Our Drinking Water

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

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

Limerick Nuclear Plant’s Environmental Impacts – ACE Testimony to NRC 6-24-13

ALLIANCE FOR A CLEAN ENVIRONMENT (ACE)

JUNE 24, 2013 TESTIMONY ON

NRC’S DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)

FOR LIMERICK NUCLEAR POWER PLANT

NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

 

 

NRC PRODUCED A DRAFT ENVIRONMENTAL IMPACT STATEMENT

FOR LIMERICK NUCLEAR PLANT

WITHOUT ACCURATELY EVALUATING AND REPORTING ON LIMERICK’S

SPECIFIC UNPRECEDENTED HARMFUL ENVIRONMENTAL IMPACTS

FOR THE PUBLIC TO CONSIDER NRC’S EIS FOR LIMERICK VALID,

NRC’S FINAL EIS MUST REFLECT CHANGES IDENTIFIED IN THIS TESTIMONY.

 

 

SIGNIFICANT CHANGES NEEDED FOR LIMERICK’S FINAL EIS INCLUDE:

 

  • Radiation Releases From Limerick Nuclear Plant And Links To Cancer Near Limerick Need To Be Accurately Included, As Identified In This Testimony.

 

  • Cancer Rates Near Limerick Need To Be Accurately Reported, As Identified In This Testimony.

 

  • Unprecedented Harms And Threats To The Schuylkill River Need To Be Accurately Reflected, As Identified In This Testimony. 

 

  • Radionuclides In Groundwater Caused By Limerick Need To Be Accurately Reported, As Identified In This Testimony.

 

  • Major Air Pollution Threats From Limerick Need To Be Accurately Reflected As Indentified In This Testimony, Including Unprecedented Risks From Limerick’s Massive Cooling Tower PM-10 Which Transports Radiation, Many Other Dangerous Highly Corrosive Toxics, and Pathogens Into Our Air.

 

  • Accurate Reporting On Solar Power Needs To Be Included, And More Accurate Comparisons On Alternatives Need To Be Reflected, As Identified In This Testimony.

 

  • Why Limerick’s Decades Old Severe Accident Mitigation Alternatives Needs To Be Updated As Required By A Federal Judge, Not Challenged In Court and Exempted.   NRC Staff Recommended Post Fukushima Safeguards Must Be Required Immediately And NRC Identified Corrosion, Deterioration, And Other Aging Problems In Structures and Systems Must Be Repaired And Replaced, Including In Fuel Pool Liners, PRIOR To Relicensing, As Detailed In This Testimony.

 

  • Limerick’s Earthquake Risk Plans And Upgrades Need To Be Completed Prior to Relicensing As Reflected In This Testimony, And Not Delayed Until 2017 Or Later.

 

  • A New Review Of Limerick’s High-Level Radioactive Wastes and Spent Fuel Storage Is Imperative To Be Included In This EIS, As Identified In This Testimony.

 

  • Limerick’s Low-Level Radioactive Waste Volumes Need To Be Tracked.  Assurances That Exelon Will Not Burn It In Our Region Are Imperative, As Identified In This Testimony.

 

  • Limerick’s Cost-Benefit Analysis Needs To Include All Costs to The Public, As Identified In This Testimony.    

June 24, 2013

ALLIANCE FOR A CLEAN ENVIRONMENT (ACE)

Official Written Testimony On

NRC’s DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)

FOR LIMERICK NUCLEAR POWER PLANT

NUREG-1457, Supplement 49, Docket ID NRC-2011-0166

 

MAJOR PROBLEM: 

NRC PRODUCED A DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR LIMERICK NUCLEAR PLANT WITHOUT ACKNOWLEDGING DOCUMENTED HARMFUL ENVIRONMENTAL IMPACTS.

NRC FAILED TO ACKNOWLEDGE LIMERICK NUCLEAR PLANT’S UNPRECEDENTED THREATS AND HARMS PRESENTED TO NRC IN ACE WRITTEN TESTIMONY 10-26-11.

 

CONSEQUENCES OF NRC’S INACCURATE CONCLUSIONS:

 

Limerick’s DRAFT EIS Could Result In Increased Future Risks And Harms For Millions Of People In The Greater Philadelphia Region. Ignoring Evidence Of Harm Doesn’t Eliminate The Reality Of Current Harms Or Future Threats.  

 

NRC MUST SET THE RECORD STRAIGHT IN ITS FINAL EIS

 

NRC’S Mission Is To Protect Public Health And Safety Related To Limerick Nuclear Plant Operations.  Minimally, That Requires NRC To Provide Full, Fair, And Accurate Disclosure Of All Of Limerick Nuclear Plant’s Unprecedented Environmental Threats And Harms.  The Health And Safety Of Millions Of People In The Greater Philadelphia Region Will Be Further Jeopardized By Negligent Conclusions In NRC’S DRAFT EIS For Limerick Nuclear Plant.

 

NRC Conclusions In Limerick Nuclear Plant’s DRAFT EIS Are An Unethical Injustice To The Public, And Must Be Changed To Reflect The Documented Evidence Of Unprecedented Threats And Harms.  

 

ON BEHALF OF THE HEALTH, SAFETY, AND FINANCIAL INTERESTS OF MILLIONS OF PEOPLE:

 

  1. 1.   ACE Is Requesting That NRC’S DRAFT EIS For Limerick Nuclear Plant Relicensing Be Changed To Accurately Reflect The Documented Evidence ACE Put On NRC’S Public Hearing Record For Limerick’s EIS October 26, 2011.

 

  1. 2.   ACE Is Also Requesting That NRC’S Final EIS Reflect Additional Evidence Of Environmental Threats And Harms Included In This June 24, 2013 Written Testimony.

 

Facts Show Limerick Nuclear Plant’s Environmental Threats Are Clearly “Large”, NOT “Small” As Inaccurately Claimed By NRC.  

 

  • Increases And Exemptions In Limerick Nuclear Plant’s Air And Water Pollution Permits Should Be Sufficient For NRC To Conclude Limerick’s Environmental Impacts Are “LARGE” NOT “SMALL”, Especially When Limerick Couldn’t Meet Its Original Permit Limits Or Safe Limits In Place To Protect Public Health, And Exelon Won’t Pay For Filtration to Reduce health Threats.

 

NRC Did NO Independent Monitoring Or Testing For Limerick’s EIS.  It Is Indefensible For NRC To Claim Limerick’s Impacts Are “Small” When A Body Of Evidence Suggests Otherwise.  

NRC FAILED TO HAVE AN INDEPENDENT EXPERT ANALYZE THE ADDITIVE, CUMULATIVE, AND SYNERGISTIC HARMS TO THE ENVIRONMENT AND PUBLIC HEALTH OVER THE PAST 28 YEARS.  THEREFORE, NRC CAN’T MAKE A RELIABLE, DEFENSIBLE PREDICTION ABOUT THE HARMS FROM LIMERICK UNTIL ITS LICENSES EXPIRE IN 2029, NOR UNTIL 2049, DURING ANOTHER 20 YEARS IF LIMERICK IS RELICENSED.

 

  • Prior to NRC’s scoping process, ACE repeatedly urged NRC and other agencies to do a year of independent monitoring and testing for all of Limerick’s broad range of radionuclides, as well as other toxics massively released into our air and water from Limerick.  NRC never even responded to our requests.

 

WELL DOCUMENTED EVIDENCE OF LIMERICK’S UNPRECEDENTED ENVIRONMENTAL THREATS AND HARMS REFUTE NRC’S INDUSTRY-BIASED UNRELIABLE, UNSUBSTANTIATED CONCLUSIONS THAT LIMERICK’S HARMS ARE “SMALL”.  

  • NRC’S negligent conclusions protect Exelon’s profits and NRC jobs, but fail to protect public health and safety.

 

NRC’s inaccurate conclusions in Limerick’s DRAFT EIS are largely based on untrustworthy estimates, calculations, and “reviews” of monitoring and testing data from Exelon, the company with a clear vested interest in the outcome, that has shown it can’t be trusted to provide full and accurate disclosure at Limerick or elsewhere. 

  • 10-26-11 ACE provided NRC with several specific examples of why Exelon can’t be trusted to provide full, accurate, or timely disclosure of Limerick’s monitoring, testing, calculating, estimating, or reporting.

Example of Exelon’s Unreliable Monitoring:

ü  A vital radiation monitor was inoperable for over an entire year.

Example of Exelon’s Delayed Disclosure:

ü  Exelon waited 23 days to inform the public about a huge radioactive spill into a vital public drinking water source for almost two million people.

 

EVIDENCE SHOWS NRC FAILS TO TAKE MEANINGFUL ENFORCEMENT ACTION AGAINST EXELON’S NEGLIGENCE REGARDING THREATS TO PUBLIC HEALTH, REGARDLESS OF ENORMOUS OPPORTUNITY FOR HARMS TO THE ENVIRONMENT AND PUBLIC HEALTH.

  • 2-3-13 It was reported that Exelon provided NRC with inaccurate information about how much money will be available to decommission Exelon’s power plants, potentially hiding a shortfall of “roughly $1 Billion”.  This should show NRC why they can’t trust any information provided by Exelon, especially in radiological monitoring reports.

 

ACE rejects NRC’s inaccurate, absurd conclusions in its DRAFT EIS for Limerick Nuclear Plant. 

  • 10-26-11 ACE provided NRC with analyses that should have triggered investigations, not just consultations with agencies that allowed dangerous permit increases and exemptions in Limerick’s pollution permits. NRC’s conclusions show that NRC ignored and dismissed important documented evidence from several analyses related to Limerick’s environment and health threats. These analyses were on: 
    • Exelon’s Radiological Monitoring Reports to NRC
    • Limerick’s Title V air pollution permit renewal in 2009
    • Limerick’s NPDES permit for pollution discharges into the Schuylkill River
    • Analyses of radioactive groundwater contamination

 

NRC CLEARLY DID NOT GIVE A FULL AND FAIR REVIEW NOR ADDRESS THE DOCUMENTED EVIDENCE OF ENVIRONMENTAL AND HEALTH HARMS AND THREATS SUBMITTED FROM ACE 10-26-11 ON BEHALF OF PUBLIC INTERESTS.

 

  • NRC ALSO REFUSED ACE’S REQUEST TO MEET TO DISCUSS OUR POLLUTION PERMIT ANALYSES, DESPITE THE FACT THAT NRC FAILED TO INDEPENDENTLY ANALYZE LIMERICK NUCLEAR PLANT’S POLLUTION PERMITS.
    • Not one word appears in Limerick’s EIS about the documented cancer crisis in communities near Limerick.  Nor have the high infant and neonatal mortality issues been acknowledged or discussed.
    • Major evidence related to Limerick’s air and water pollution permit issues goes unaddressed.
    • High-level and low-level radioactive waste issues have not been adequately addressed.

 

NRC REFUSING TO INCLUDE OR DISCUSS DOCUMENTED HEALTH HARMS AND ENORMOUS ENVIRONMENTAL THREATS SPEAKS VOLUMES ABOUT NRC’S INDUSTRY BIASES. 

 

AVOIDING THE PUBLIC AND DISMISSING DOCUMENTED FACTS ABOUT LIMERICK’S POLLUTION THREATS WILL NOT REDUCE RISKS, BUT INSTEAD ALLOW THEM TO CONTINUE AND INCREASE.

  • If NRC’S baseless inaccurate conclusions that Limerick’s harms are “small” are not changed to deal with reality in Limerick’s EIS, then the NRC officials who approved Limerick’s DRAFT EIS must be held accountable for regulatory negligence. 
  • NRC’s irresponsible conclusions will result in unacceptable consequences and injustices to millions of people in the Greater Philadelphia Region.   

 

NRC MADE INACCURATE ILLOGICAL CONCLUSIONS THAT FAIL TO CONSIDER OR ACKNOWLEDGE EXTENSIVE DETAILS PROVIDED IN ACE’S 10-26-11 PUBLIC HEARING TESTIMONY.  EVIDENCE SINCE 2011 ALSO REFUTES NRC’S FALSE CLAIMS THAT HARMS ARE, OR WILL BE, “SMALL”.

 

AMONG THE MOST GLARING OMISSIONS IN NRC’S DRAFT EIS IS THE DOCUMENTED COMPELLING EVIDENCE ACE PROVIDED 10-26-11 ON THE LINKS BETWEEN OUR CANCER CRISIS AND LIMERICK’S ROUTINE AND ACCIDENTAL RADIATION RELEASES SINCE 1985.

 

  • WE SHOWED WHY LIMERICK’S RADIATION RELEASES ARE CLEARLY A MAJOR FACTOR IN CANCER RATES FAR HIGHER THAN THE NATIONAL, STATE, AND TRI-COUNTY AVERAGES, ESPECIALLY IN OUR CHILDREN.

 

  • CANCER RATES ARE DOCUMENTED TO HAVE SKYROCKETED FAR ABOVE THE NATIONAL, STATE, AND TRI-COUNTYU AVERAGES IN COMMUINITIES NEAR LIMERICK, AFTER LIMERICK STARTED OPERATING.

 

  • YET, OUR ALARMING CANCER RATES AND HIGH INFANT MORTAILITY RATES ARE NOT EVEN MENTIONED IN NRC’S DRAFT EIS.  THERE IS NOT ONE WORD ABOUT CANCER INCREASES IN COMMUNITIES NEAR LIMERICK AFTER LIMERICK STARTED OPERATING AND RELEASING RADIATION INTO OUR LIFE-SUPPORT SYSTEMS AND OUR BODIES.

 

  • THIS OMISSION IS UNACCEPTABLE.  THE EVIDENCE IS CLEAR.  NRC’S FINAL DRAFT MUST BE CHANGED TO INCLUDE THE CANCER INCREASES.  FOR NRC’S CONVENIENCE WE HAVE INCLUDED SOME OF THE DETAILS BELOW.

 

  • ACE CALLS ON NRC TO REVIEW THE SUMMARY BELOW THEN REVISE ITS DRAFT EIS TO REFLECT THE REALITY ABOUT LIMERICK’S PAST, CURRENT, AND FUTURE ENVIRONMENTAL AND HEALTH HARMS, INCLUDING OUR ALARMING CANCER AND INFANT MORTALITY RATES.

RADIATION RELEASES

FROM LIMERICK NUCLEAR PLANT AND

 LINKS TO CANCER

 

RADIATION

 

A broad range of radionuclides have routinely and accidentally been released into our air and water for 28 years from Limerick Nuclear Plant.  There are additive, cumulative, and synergistic impacts from exposure through several routes of exposure.  Some radionuclides released from Limerick, like Cesium and Strontium, have decades-long half-lives.

 

LIMERICK NUCLEAR PLANT’S WORST ENVIORNMENTAL AND HEATLTH HARMS ARE CLEARLY ASSOCIATED WITH LIMERICK’S RADIATION RELEASES OVER THE PAST 28 YEARS.

 

NRC’S DRAFT ENVIORNMENTAL IMPACT STATEMENT SHOULD FOCUS ON RADIATION, THE SIGNATURE HARMFUL TOXIC RELEASE FROM LIMERICK NUCLEAR PLANT,

HOWEVER:

  • NRC’S DRAFT EIS – Table of Contents  – FAILS TO MENTION RADIATION
  • NRC’S DRAFT EIS – Executive Summary – FAILS TO MENTION RADIATION
  • NRC’S DRAFT EIS – Table ES-1 – Summary of NRC Conclusions Related to Site-Specific Impacts of License Renewal – FAILS TO MENTION RADIATION.
  • NRC’S DRAFT EIS – Severe Accident Mitigation Alternatives – FAILS TO MENTION RADIATION.
  • NRC’s DRAFT EIS – Purpose and Need For Action – FAILS TO MENTION RADIATION

 

These glaring omissions rise to the level of regulatory malpractice.  It is shocking that this document fails to address radiation exposure and human health impacts in any meaningful way. NRC is mandated to protect public health from Limerick Nuclear Plant Operations, yet NRC has basically chosen to dismiss and/or minimize the impacts of Limerick Nuclear Plant’s regular radiation releases into the life-support systems and the people in the Greater Philadelphia Region in Limerick’s DRAFT Environmental Impact Statement.

 

Radiation exposure to the public is barely mentioned in NRC’s 585 page document DRAFT EIS document.  On the very few pages with any reference, radiation releases and their effects on human health have been shamelessly characterized as minimal or small, an unsubstantiated claim.

 

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.

 

NRC’S failure to acknowledge the harmful impacts of Limerick’s routine and accidental radiation releases into our life-support systems is an injustice that cannot be tolerated.  NRC’s Draft EIS for Limerick must be changed to focus on the actual harmful impacts from Limerick’s routine and accidental radiation releases, the most dangerous health threat our region faces from Limerick Nuclear Plant operations.

  • Ignoring the harmful impacts of Limerick’s additive, cumulative, and synergistic radiation impacts on everyone and everything is a grave omission that will lead to 20 more years of further jeopardizing the families of everyone in our region.
  • As long as Limerick Nuclear Plant continues to operate, radiation will be released into our air, water, soil, and people. More people will suffer needlessly.  Exposure to Limerick’s radiation is an unavoidable and intolerable injustice.  We can’t see, smell, taste, or feel it, but it’s everywhere.  We can’t avoid it.
  • The truth is, the only way to reduce health risks is to tell the truth about radiation releases from Limerick and close Limerick now to stop the routine and accidental radiation releases.  NRC can stop unnecessary radiation exposure, unnecessary suffering, and unnecessary health care costs in the future by closing Limerick now.

 

NRC LOST ALL CREDIBILITY ABOUT HARMS FROM LIMERICK’S RADIATION RELEASES.

 

  • NRC DID NO RADIATION TESTING. 

NRC’s tactics to dismiss and/or minimize the impacts of Limerick’s radiation releases are appalling, shameful, and unacceptable.

  • NRC did NO radiation monitoring or testing for this EIS, yet absurdly claims harms are “small”.
  • In reality, NRC has no accurate idea how much radiation is released from Limerick into our air or water.
  • NRC relies on Exelon’s deceptive and unreliable calculating, estimating, monitoring, and testing, tactics.
  • NRC simply inspects unreliable reports from Exelon.
  • You can’t see, feel, or smell radiation, yet NRC claims to know what radiation is being released by conducting onsite inspections for effluent compliance.
  • Flawed and outdated theoretical models are used for radiation exposure, which only measure external doses, and ignore internal doses, yet NRC continues to absurdly claim Limerick’s radiation releases are safe.
  • 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.
  • Gofman said, “the entire nuclear power program is based on a fraud, that there is a permissible dose that wouldn’t hurt anyone.”

        

  • THERE IS NO SAFE DOSE
  • “Permissible” does not mean safe.  In 2005, the National Academy of Sciences BEIR VII report said there is no safe dose.  Permissible radiation levels do not mean they are safe.
  • Radiation exposure can cause cancer and other serious disease and disability, at any level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility.
  • Fetuses, infants, and children are the most impacted.

 

  • EVIDENCE REFUTES NRC’S PREVIOUS CLAIMS
  • NRC’s absurd claims about oversight of radiation releases in the 2006 “Frequently Asked Questions” for the public hearing 5-23-13 must be refuted with reality.

­   NRC has dose limits, but they do not protect the public.

­   NRC has no accurate idea what total doses from all routes of exposure that each person is getting.

­   NRC set limits on radiological effluent releases, but fails to monitor, test, or require filtration for compliance.

­   NRC admits that scientists are unable to make empirically based estimates of radiation risks from nuclear plants, yet NRC claims risks are small.

  • LAX OVERSIGHT – NRC says its regulations require Exelon to control and limit radiation releases to the air and water to very small amounts and comply with radiation dose limits for the public but that is not true.  Just one example is Limerick’s 3-19-12 radioactive spill into a vital drinking water source.

­   Limerick’s 3-19-12 radioactive spill into a drinking water source for almost two million people shows that Exelon fails to comply with NRC regulations and NRC takes no meaningful enforcement action.

­   People were drinking water with higher than usual radiation levels from Limerick’s spill, yet NRC and Exelon waited 23 days to inform the public. People had no opportunity to avoid use of the radioactive water.

­   Neither NRC nor Exelon has any idea what doses of radiation people were exposed to in their drinking water for the 23 days they weren’t even told it happened.

­   NRC did NO TESTING.  Water companies did NO TESTING.  In fact, NRC inspectors never verified the amount of radioactive water that was spilled.

 

NRC Deceives The Public, About Radiation Risks From Relicensing When Stating Radiation Dose Levels Are “Not Expected to Increase” From Those During the Initial Licensing Period.

  • After Limerick started operating communities near Limerick experienced shocking cancer increases and alarming infant mortality rates, identified in detail below.
  • NRC’s expectation that radiation doses will not increase during relicensing is little comfort.

 

CANCER  -  RATES SKYROCKETED

 

10-26-11 ACE provided NRC with evidence showing communities around Limerick Nuclear Plant already suffered alarming cancer increases after Limerick started operating in 1985.  A cancer crisis has been documented by PA Cancer Registry Statistics and CDC data. 

 

  • Yet, NRC’s DRAFT EIS failed to include this important information.

 

  • NRC’S final EIS must include this evidence about such shocking cancer rates far above the national, state, and tri-county averages, especially in children.

 

LIMERICK’S RADIATION RELEASES HAVE CLEARLY BEEN A MAJOR FACTOR IN THE CANCER CRISIS IN COMMUNITIES AROUND LIMERICK NUCLEAR PLANT.   

The Facts Are Clear and Undeniable:

  • Limerick Nuclear Plant Routinely and Accidentally Released A Broad Range Of Radionuclides Into Our Life Support Systems Since 1985.
  • Radiation Can Cause Cancer At Any Level.
  • A Cancer Crisis Developed In Communities Near Limerick After 1985.

 

  • NRC HAS NO DEFINITIVE PROOF LIMERICK IS NOT A MAJOR FACTOR IN OUR CANCER CRISIS.  NRC MUST NOT OMIT THE CANCER DATA AROUND LIMERICK.
    • Limerick’s Radiation Releases Are Additive, Cumulative, And Synergistic With Each Other And All The Other Carcinogens, Which Explains Why Our Cancer Statistics Are So Much Higher Than The National Average, Especially In Children, The Most Vulnerable Victims Of Radiation Exposure.

 

 

Cancer Data Below Should Have Alarmed Even NRC.

 

 

Cancer Rates Skyrocketed After Limerick Opened

In Montgomery County – Home of Limerick Nuclear Plant

      Increases Mid 80s to 90s

ü  Prostate                                             Increased        132%

ü  Thyroid                                              Increased        128%          

ü  Kidney                                                Increased          96%

ü  Multiple Myeloma                             Increased          91%

ü  Hodgkin’s Disease                            Increased          67%

ü  Non-Hodgkin’s Lymphoma             Increased          61%          

ü  Breast                                                 Increased          61%

ü  Pancreas                                            Increased          54 %

ü  Leukemia                                           Increased          48%

Cancer Rates Far Higher Than U.S. and Tri-County Averages In 6 Communities Close to Limerick Nuclear Plant (1995 to 1999)

Lower Pottsgrove,  Upper Pottsgrove,  West Pottsgrove,  Pottstown,  North Coventry,  Douglass Berks

8 of 11 Most Common Cancers Above National and State Averages -Compared to U.S. and TriCounty

Type of Cancer                                                Above U. S.            Above Tri County

ü  Kidney/Renal Pelvis                                        + 60 %                       + 42.7 %           

ü  Rectum                                                              + 44 %                       + 13.5 %

ü  Uterine                                                             + 44 %                       + 38.7 %

ü  Breast (female)                                                 + 39 %                       + 24.5 %

ü  Brain/Cent. Nervous System                          + 38 %                       + 32.5 %

ü  Urinary Bladder                                               + 35.5 %                    + 17.9 %

ü  Colon                                                                 + 21 %                       +   3.3 %

ü  Lung                                                                  + 11.8 %                    + 18.4 %

ü  Leukemia                                                          + 11.5 %                   + 14.9 %

CHILDHOOD  CANCER

92.5 % Higher Than The National Average

In Six Communities Close To Limerick Nuclear Plant

Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry,  Douglass Berks Township

 

(Ages 0-19) All Cancers Diagnosed from 1995-1999   Rate per 100,000

Type of Cancer                    Cases 0-19            Gr. Pottstown        U.S.                       %AboveU.SSignificance

All Cancers                                        40           28.33                     16.04                     +  76.6                   p<.02

Leukemia                                           13           9.21                       3.89                       +136.8                   p<.055

Brain/Central Nervous Sys.               7           4.96                       2.98                       +  66.4

Kidney/Renal Pelvis                           5           3.54                      0.73                       +384.9                   p<.09

Non-Hodgkin’s Lymphoma               4           2.83                      1.04                       +172.1

All other                                             11

 

Note: Half Of Childhood Cancers Above Are  Leukemia and Brain/Central Nervous System Cancers, Both Associated With Radiation Exposure .

Rates calculated in 2003 using 1990-99 annual Greater Pottstown population 0-19 of 14,120.

For example, leukemia rate = 13 cases/10 years/14,120 x 100,000 = 9.21.

Rates are MUCH HIGHER for FOUR of the CANCERS most common in children, SIGNIFICANTLY HIGHER for ALL CANCERS and LEUKEMIA, and BORDERLINE SIGNIFICANT for KIDNEY/RENAL PELVIS.

 

71% Increase  In Montgomery County, Home of Limerick Nuclear Power Plant    Deaths from Neoplasms in Children    Ages 1 to 14  1981-89   vs.  1990-98

But Rates In Neighboring Counties, PA, and the U.S. Were Down:

ü  Chester County       29.0%   Decrease

ü  Berks County           30.6%   Decrease

ü  Pennsylvania           17.1%   Decrease

ü  U.S.                           21. 2%  Decreas

 

CHILDHOOD CANCER RATES – UPWARD TREND

AFTER LIMERICK STARTED OPERATING IN 1985

Late  1980’s   about            30 %  HIGHER  than the NATIONAL AVERAGE

               Early 1990’s   about           60 %  HIGHER than the NATIONAL AVERAGE

Late  1990’s   up to             92.5 % HIGHER than the NATIONAL AVERAGE

Late  1990’s  almost        100 % HIGHER than the STATE and TRI COUNTY

 

Limerick’s Routine Radiation Releases Are Logically A Major Factor.

Nationwide, cancer is the #1 disease-related death in children. All children are exposed to similar                environmental pollutants, including pesticides and herbicides, cleaning chemicals, mold, second hand smoke, vehicle emissions, and even genetic factors.

 

Closing Limerick Is The Only Way to Stop Routine Radiation Releases.  

As long as Limerick operates, routine radiation will continue to be released into our air, increasing risk of cancer and other diseases and disabilities caused by radiation exposure.

 

NRC Lost All Credibility On Routine Radiation Releases And Cancer Links

  

Links between elevated cancers around nuclear plants are obvious and already documented.

  • After a nuclear plant like Limerick starts operating and continuously releasing a broad range of radionuclides into the air and water, people in the region are continuously exposed to additive, cumulative, and synergistic doses of that radiation from all routes of exposure.
  • Long-term exposure to the witches brew of radiation from nuclear plants like Limerick logically causes increases in cancers around it.
  • Limerick Nuclear Plant is clearly a major factor in the shocking cancer increases around Limerick Nuclear Plant since it started operating.

 

It is NOT credible for NRC to conclude Limerick’s radiation releases or their impacts are “small”.  NRC has no independent documented proof of either.  It is NOT acceptable to dismiss Limerick’s routine radiation emissions as factor in the documented highly elevated cancers around it, especially in children.

 

NRC Refused To Give Full and Fair Consideration To Documented Cancer Data and Research From Independent Scientists

We need NRC employees to have the courage and integrity to acknowledge obvious harms from Limerick Nuclear Plant’s routine and accidental radiation releases and speak up to protect public health instead of nuclear industry profits.   Getting the truth told is vital to stopping the unprecedented injustice of unnecessary radiation poisoning of us and our environment.

 

NRC must start to consider the vast body of independent research showing links between nuclear plant radiation releases and cancer.

  • NRC must stop remaining in denial of a body of documented independent research.  
  • NRC must stop using industry biased unsubstantiated conclusions, to protect nuclear industry interests.
  • NRC should stop making deceptive comparisons between continuous nuclear plant radiation releases and exposure to gamma rays from x-rays and planes.  

 

A Long List Of Cancer Studies Show Links Between Nuclear Plants and Cancer.

U.S. and European studies, as well as four studies on PA Cancer Registry cancer data around Limerick, show increased cancers, especially in children,

 

Dr. Jeffrey Patterson, Professor Emeritus, University of Wisconsin’s School of Public Health and Past President of Physicians for Social Responsibility says:

  • “Background Radiation” is NOT safe.  We live with background radiation, but it does cause cancer”.
  • “There are absolutely no safe levels of radiation.  Adding more radiation ADDS to the health impacts”.
  • “Exposure to radionuclides…increases risk of cancer.
  • “Every effort must be taken to minimize radionuclide content in food and water.”

 

Dr. Steven Wing, University of North Carolina in Chapel Hill, School of Public Health said:  “Generally accepted thinking is that there is no safe dose in terms of cancer or genetic effects of radiation.  The claims of no threat to health…just flies in the face of all the standard models and all the studies that have been done over a long period of time of radiation and cancer”.

 

Dr. Chris Busby, Scientific Secretary of the European Committee on Radiation Risk said, if one plans on living a long, healthy life, the most obvious way is to reduce radiation exposure.   Dr Busby’s Book, “Radiation Toxicity Syndrome”  focuses on harms from radiation exposure.

 

NRC has long been involved in a cover-up with its dismissal and/or distortion of the effects of radioactivity from nuclear plants, even regarding the actual harms and deaths from Chernobyl, TMI, and now Fukushima.

ü  Chernobyl – Almost a million people worldwide died from radioactivity discharged after the 1986 Chernobyl accident, yet NRC continues to use inaccurate low numbers.  Research confirms many terrible diseases and disabilities are tied to Chernobyl.

ü  TMI  – That 1979 accident in PA may be responsible for thousands of deaths.   “Deadly Deceit:  Low Level Radiation – High Level Cover-up” suggests between 50,000 to 100,000 EXCESS DEATHS occurred after the TMI accident.

 

Two Studies By The Radiation and Public Health Project (RPHP), Along With Cancer Rates Around Limerick Nuclear Plant Show Links

 

Strontium 90 (SR-90) in Baby Teeth Is The Smoking Gun.

The Radiation and Public Health Project’s “Tooth Fairy Study” verified Strontium-90 radiation in the baby teeth collected from children around Limerick Nuclear Plant.  (Reported 2003).  

  • Limerick Nuclear Plant’s role in SR-90 in baby teeth around Limerick is clear.
  • Strontium-90 was routinely released into our air and water from Limerick Nuclear Plant since 1985.
  • SR-90 was detected around Limerick in water, milk, soil, and vegetation (2009 Exelon Report).
  • SR-90 was detected in the teeth of children living in the region around Limerick, at some of the highest levels around nuclear plants studied in the U.S.
  • Limerick Nuclear Plant’s 28 years of SR-90 releases were obviously the major factor.
  • Still NRC has attempted to blame 50-year old bomb testing far from Limerick, when Limerick routinely released SR-90 into our air and water since 1985.

 

Strontium-90 (Sr-90) Links to Limerick and Research

  • The Radiation and Public Health Project’s “Tooth Fairy Study” showed SR-90 in baby teeth of children living near Limerick Nuclear Plant have some of the highest levels of Strontium-90 of any area around nuclear plants or other areas studied in the U.S.
  • Children living near Limerick have suffered some of the highest cancer rates in the U.S., skyrocketing  after Limerick opened in1985 to the late 1990s.
    • Childhood cancer rates rose from 30% higher than the national average in the late 1980s to 92.5% higher in the late 1990s.   Limerick started operating and releasing SR-90 in 1985.
  • Exelon’s 2009 Radiological Monitoring Report for Limerick confirms SR-90 is in our water, soil, vegetation, and milk.
  • Signature cancers of Sr-90 are cancers of the bone, including Ewing’s Sarcoma.
  • Sr-90 closely resembles calcium and is readily taken up into the bones and teeth – considered the most hazardous bone-seeking element of nuclear fission because it so closely resembles calcium.
  • Sr-90 lodges near the bone marrow, where stem cells form blood and immune system cells,   increasing risk of many forms of cancer, especially in newborn infants.
  • Sr-90 is considered very hazardous because of its long half-life of 28 years.  Low dose exposure to

Sr-90 is so serious because of protracted exposure over periods of days, months or years.

  • Research confirms that low dose exposures over months or years can be hundreds to thousands of times more damaging than the same dose received in short diagnostic medical exposures or flashes from a nuclear bomb explosion.  (Petkau)
  • Damage is known to involve the developing immune, hormonal, and central nervous systems of infants and children.

For reliable links between Strontium-90 in baby teeth and nuclear plants, refer to the well researched and informative book: Radioactive Baby Teeth:  The Cancer Link by Joseph Mangano, Radiation and Public Health Project.  

 

THYROID CANCER  - “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.

 

Dr. Lewis Cuthbert, ACE President expressed The Alliance For A Clean Environment’s extreme concerns about the shocking thyroid cancer increases and rates above the national average in the region around Limerick Nuclear Plant, since Limerick started operating in 1985.

 

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.

  • THYROID CANCER SKYROCKETED  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

56.2 %  Higher  THAN  U.S.  -   Montgomery  County

53.9 %  Higher  THAN  U.S.  -  Chester  County

14.6 % Higher   THAN  U.S.  -  Berks County

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.

 

LINKS ARE CLEAR BETWEEN

Limerick Nuclear Plant’s Routine Radiation Emissions

And Horrific Thyroid Cancer Rates Around It

  • Limerick Nuclear Plant’s routine Iodine-131 radiation releases into our air and water impact the thyroid.

Proof:  Distribution of KI pills for the thyroid in case of an accident or attack.

  • Those Closest and Downwind To Limerick Have Highest Thyroid Cancer Rates.

 

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.

 

BREAST CANCER

Is Far Higher Than The National Average In Every Age Group In Six Communities Close To Limerick Nuclear Plant.

Includes Lower Pottsgrove, Upper Pottsgrove, West Pottsgrove, Pottstown, North Coventry, Douglass Berks

Breast Cancer  By Age (diagnosed 1995-1999) Compared to the National Average

Age                                               % HIGHER than U.S.

0-29                                                                     + 15.3 %

30-44                                                                    + 51.4 % 

45-64                                                                    + 39.3 %

65+                                                     + 28.6 %

         Source:  Pa Cancer Registry

Breast Cancer is an epidemic nationwide.  It is alarming when Breast Cancer Statistics Around Limerick Nuclear Plant are so far higher than the national average in every age group.

Breast Cancer Average Statistics Above U.S. Average

1995-1999                                           Local       Rate per 100,000                 %  Above    %  Above

Type of Cancer                    Cases     Gr. Potts.  U.S.       Oth. 3 Co.             U.S.           Tri County  

Breast (female)    263         161.5         116.0     129.8                                  +39.2 %       +24.5 %

 

BREAST CANCER – INCREASED 61%

In Montgomery County, Home of Limerick Nuclear Plant,  After Limerick Started Operating.   

Source:  PA Cancer Registry   1985-86 to 1996-97

Research That Links Breast Cancer With Radiation Exposure

  • The Chernobyl experience confirmed that children exposed to radiation have a greater likelihood of developing breast cancer as adults.  Source:  Life Extension, 12/04  (60)
  • 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.
·        Analysis of 350 Studies Finds Half of Breast Cancers are Tied to Environment and Unrelated to Genetic Risk or Lifestyle Choices.

 

LEUKEMIA – Rates Near Limerick Nuclear Plant and Links

Leukemia Rates (1985 to 1994) Were Almost Double the State Average

According to the 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.  

 

Leukemia rates were significantly higher than the national average in six communities near Limerick Nuclear Power Plant

Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry,  DouglassBerksTownship

Statistics:    Joseph Mangano, MPH  MBA  National Coordinator RPHP

(Ages 0-19) All Cancers Diagnosed from 1995-1999   Rate per 100,000

Type of Cancer             Cases 0-19       Gr. Pottstown   U.S.     %AboveU.SSignificance

All Cancers                              40        28.33                16.04                +  76.6              p<.02

Leukemia                                 13        9.21                  3.89                  +136.8              p<.055

(Source:  PA Cancer Registry) Reported June 25, 2003

Note: Rates calculated using 1990-99 annual Greater Pottstown population 0-19 of 14,120.

For example, leukemia rate = 13 cases/10 years/14,120 x 100,000 = 9.21.

 

More Leukemia Links: 

  • 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.
  • Leukemia rates in Chernobyl children confirm a link.

 

The Leukemia Rate has been higher than the other parts of the three county area for at least 15 years with a total of 106 cases from 1985 when Limerick Nuclear Plant started operating to 1999.   (see below)

Leukemia incidence per 100,000, age adjusted to 1970 standard  – Period Greater Pottstown (cases) Other 3-county % Above/Below

1985-89 9.5 (27) 7.1 +33.8%

1990-94 16.6 (44) 8.7 +90.8%

1995-99 11.6 (35) 10.6 + 9.1%

 

The 15 year leukemia rate is approximately about 40% above the other three county rate. 

This is a statistically significant difference (p<.01)

Source:PennsylvaniaStateCancer Registry

 

For the period 1995-99, there were 35 newly-diagnosed cases in the area. The  age-adjusted rate was 11.6 per 100,000, higher than the rest of the three counties, the state, and the nation (See Table below).

Leukemia incidence per 100,000, age adjusted to 1970 standard, 1995-99 Area Rate (cases) % Above/Below Gr. Pottstown

Greater Pottstown 11.6 (35)

Other 3-county 10.6 + 9.1%

Pennsylvania 9.7 +19.6%

United States 10.4 +11.5%

Source:PennsylvaniaStateCancer Registry

 

BRAIN CANCER

Source:  Penn State – Graduate Student Research

 

IN POTTSTOWN  -  The Address of Limerick Nuclear Power Plant

     BRAIN CANCERS WERE SIGNIFICANTLY HIGHER

ü  Than state and national averages

ü  Than municipalities in a 12 mile radius

Statistics:  PA Department of Health, Bureau of Health Statistics ( 2001, August)

Analysis of cancer incidence in PA counties 1994-1998  http://www.health.sate.pa.us/stats Professor – Dr. Steven Couch

 

Municipality-level statistics cannot account for the high numbers of brain cancers in Pottstown. 1999 Brain Cancer Statistics – Rate per 100,000 in Pottstown   9.25

 

In the six communities studied close to Limerick Nuclear Power Plant.

Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry,  Douglass Berks Township

 

        BRAIN/CENTRAL NERVOUS SYSTEM CANCERS

ü  COMPARED TO NATIONAL AVERAGE            38.3  HIGHER

ü  COMPARED TO TRI COUNTY                            32.5  HIGHER

UPWARD TREND – Brain/Central Nervous System cancer statistics since Limerick Nuclear Plant started operating in 1985.

ü  1985-89 15 cases

ü  1990-94 19 cases

ü  1995-99 23 cases

CHILDRENBRAIN / CENTRAL NERVOUS SYSTEM CANCERS ARE AMONG THE HIGHEST CHILDHOOD CANCERS   In six communities studied that are close to Limerick Nuclear Power Plant.

Pottstown , West Pottsgrove, Lower Pottsgrove, Upper Pottsgove, North Coventry,  Douglass Berks Township

According to PA Cancer Registry (1995-1999)

 

Another Link:  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
NRC’S CONCLUSIONS FOR LIMERICK’S DRAFT EIS FAILED TO ACKNOWLEDGE DOCUMENTED EVIDENCE LISTED ABOVE RELATED TO RADIATION AND ALARMING INCREASED CANCERS IN COMMUNITIES NEAR LIMERICK NUCLEAR PLANT.

  • NRC HAS NO PROOF THAT LIMERICK’S RADIATION IS NOT A MAJOR FACTOR IN THE DOCUMENTED CANCER RATES IN COMMUNITIES NEAR LIMERICK THAT ARE ELEVATED FAR ABOVE THE NATIONAL, STATE, AND TRI-COUNTY AVERAGES.
  • CLEARLY, LIMERICK IS A MAJOR FACTOR.  IT IS INCUMBENT UPON NRC TO AT LEAST ACKNOWLEDGE THE PUBLIC CONCERNS ABOUT THE HIGH CANCER RATES AND LIMERICK’S RADIATION RELEASES.

 

NRC’S Final EIS Must Reference The Documented Cancer Crisis Near Limerick.  Cancer Rates Are Far Higher Than National, State, and Tri-county Averages. 

  • Independent research was used to highlight links listed above.
  • Cancer data provided to NRC by ACE is from the PA CANCER REGISTRY and CDC WEBSITE.
  • There is no acceptable excuse for NRC to dismiss this documented evidence in Limerick’s EIS.
  • ACE provided NRC with additional evidence from ACE cancer mapping from distribution of 4,000 health surveys in several communities near Limerick.
  • NRC has had all this documented evidence since October 26, 2011.  NRC never contacted ACE to come to our office to review the cancer studies and research to which we refer, even though NRC’s Review Team was repeatedly just minutes away at the Limerick site.
  • ACE does not discount other causes of cancer, but NRC cannot dismiss Limerick’s 28 years of radiation releases being a major factor in our cancer crisis.

 

INFANT AND NEONATAL MORTALITY RATES FAR HIGHER THAN THE STATE AVERAGE AND EVEN HIGHER THAN PHILADELPHIA AND READING.

  • Infant mortality has been linked to radiation from nuclear plants.  State data documents that Infant and neonatal mortality are far higher in communities around Limerick Nuclear Plant than the state average, as well as far higher than Philadelphia or Reading.
  • In NRC’S Final EIS For Limerick, NRC Must Also Reference Our High Infant and Neonatal Mortality Rates,  Malignant Tumors,  Cardiovascular Disease, and Lower Respiratory Disease – Documented To Be Far HIGHER Than The State Average, and Even Higher Than Philadelphia and Reading.

This was reported by EPA in 2003, using state data.

 

For more detailed information on the cancer crisis around Limerick see www.acereport.org

   #1 Radiation – “Limerick’s Routine Releases”   #2 –  “Cancer – Skyrocketing Increases: Links to Limerick”

#3 Radiation – “No Safe Dose”

 

  • NRC’S ACKNOWLEDGEMENT OF INFORMATION ABOVE SHOULD REQUIRE NRC TO CHANGE ITS DRAFT EIS CONCLUSIONS ABOUT HARMFUL HEALTH IMPACTS FROM “SMALL” TO “LARGE”.    

 

 

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

 

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

 

LIMERICK NUCLEAR PLANT OPERATIONS THREATEN A DRINKING WATER DISASTER FOR THE ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA WHO DEPEND ON THE SCHUYLKILL RIVER FOR THEIR WATER SUPPLY.

LIMERICK NUCLEAR PLANT OPERATIONS ARE CAUSING UNPRECEDENTED THREATS AND HARMS TO THE SCHUYLKILL RIVER INCLUDING FROM:

  • Radioactive Discharges
  • Toxic Discharges From Cooling Towers
  • Heated Discharges
  • Depletion Due To Cooling Towers Insatiable Water Use
  • Toxic Mine Water Pumping To Operate Limerick

WATER RESOURCES ARE THREATENED ACROSS SIX COUNTIES

  • Water Resources Threatened Across Six PA Counties From Potential Limerick Meltdowns.

 

10-26-11 ACE provided a vast body of evidence in written testimony to NRC to analyze and put on the record for Limerick’s EIS. ACE included 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.

 

WE WERE SHOCKED TO SEE THAT NRC’S DRAFT EIS CALLED THE UNPRECEDENTED HARMS AND THREATS THAT WE DOCUMENTED IN OUR TESTIMONY, “SMALL”.    NRC’S DRAFT EIS FOR LIMERICK FAILED TO ACCURATELY REFLECT LIMERICK’S UNPRECEDENTED THREATS AND HARMS TO THIS VITAL DRINKING WATER RESOURCE FOR SO MANY PEOPLE. 

 

  • IT IS INDEFENSIBLE FOR NRC’S DRAFT EIS TO CLAIM LIMERICK’S UNPRECEDENTED THREATS AND HARM TO THE SCHUYLKILL RIVER ARE “SMALL”.  THE EVIDENCE SHOWS OTHERWISE!

 

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 that the river can continue to sustain the wide range of damages caused by Limerick operations even until Limerick’s licenses expire in 2029.  There is no guarantee there will 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.  If there is a meltdown requiring massive amounts of water, others will surely lose their water supply.

 

  • NRC’S DRAFT EIS MUST BE CHANGED TO REFLECT REALITY.   FACTS SHOULD BE CLEAR, EVEN TO NRC THAT THE SCHUYLKILL RIVER CANNOT SUSTAIN LIMERICK’S USE AND ABUSE UNTIL 2049.

 

NRC’S DRAFT EIS CONCLUSION THAT BASICALLY DISMISSES DOCUMENTED HARMS  TO THE DRINKING WATER SOURCE FOR SO MANY PEOPLE IS CLEARLY NRC REGULATORY NEGLIGENCE AND MALPRACTICE!

  • NRC IS PREPARING AN ENVIRONMENTAL IMPACT STATEMENT FOR LIMERICK NUCLEAR PLANT WITHOUT ACKNOWLEDGING OR ANALYZING LIMERICK’S ACTUAL IMPACTS ON SCHUYLKILL RIVER WATER, ECOSYSTEMS, WILDLIFE AND PUBLIC HEALTH TO DATE. 

 

  • IT IS IMPOSSIBLE FOR NRC TO ACCURATELY PREDICT WHAT WILL HAPPEN UNTIL 2049 WHEN NRC FAILED TO REVIEW AND ANALYZE LIMERICK’S WATER  PERMITS AND DOCKETS, AND NRC REFUSED TO MEET WITH PUBLIC INTEREST CITIZENS WHO DID REVIEW AND ANALYZE LIMERICK’S WATER PERMITS AND DOCKETS FROM BEFORE LIMERICK WAS LICENSED THROUGH THE MOST RECENT PERMITS AND DOCKETS ISSUED 4-13. 

 

  • FOR EIS DECISIONS NRC DID CONSULT WITH THE AGENCIES THAT JUST APPROVED NEGLIGENT, UNPROTECTIVE, SHAMEFUL WATER PERMITS WITH EXEMPTIONS AND LOOPHOLES THAT ALLOW LIMERICK TO CONTINUE TO:
  1. A.     DRASTICALLY VIOLATE SAFE DRINKING WATER STANDARDS FOR THE KIND OF POLLUTION THAT TRANSPORTS LIMERICK’S RADIATION AND COOLING TOWER TOXICS INTO THE RIVER.  
  2. B.     SERIOUSLY OVERHEAT THE RIVER
  3. C.     PUMP TOXIC UNFILTERED MINE WATER INTO THE RIVER FOR LIMERICK OPERATIONS

 

ACE Table Of Contents For Written Testimony to DRBC October 23, 2012 Below Provides An Overview Of Issues ACE Wanted To Discuss With NRC Related To:  Limerick Nuclear Plant ‘s – DRBC – DRAFT Docket No. D-1969-210 CP-13

Concerns Expressed In ACE’s Written Public Hearing Testimony Submitted To DRBC

About Not Having Enough Safe Usable Drinking Water In The Future Are Based On:          

                      ACE’s Reviews Of Limerick Nuclear Plant’s:

  1. 2011 NPDES Permit Renewal Request to DEP For Permit No. PA0051926
  2. 2009 Radiological Report By Exelon To NRC
  3. Exelon’s Current Docket Requests to DRBC
  4. PA Right to Know Information from PA DEP
  5. Freedom of Information Act Documents from DRBC
  6. Planned Uprates Which Will Require More Water
  7. Relicensing Which Would Extend Limerick’s Unprecedented Harms and Threats

From Current License Expiration in 2029 to 2049!

Section      Title

  1. 1.      Overview – Why DRBC’S DRAFT Docket Is A Recipe For A Drinking Water Disaster
  • DRBC Approved Every Exelon Request, Even Though They Increase Harms and Threats To The Schuylkill River, Eliminate Safeguards, and Literally Threaten A Drinking Water Disaster
  1. 2.      Changes Needed To DRBC’s DRAFT Docket Essential To Protect Vital Public Drinking Water Resources
  • Water is Life – Why An Ample Safe Water Supply Is Vital To Maintain Good Health
  1. 3.     Limerick Nuclear Plant’s Insatiable Water Needs Impact Parts Of Six Counties
  • DRBC Should DENY Increased Water Use From The Schuylkill River, Perkiomen Creek, and Tamaqua Reservoirs
  • Limerick Nuclear Plant Has Long Been Using Too Much Water While Increasing Heat and Droughts Tax Vital Water Supplies
  • Transporting Billions of Gallons of Water Each Year From One Region To Another For One Business Is An Injustice
  1. 4.      Depletion of the Schuylkill River – Concerns About Not Having Enough Safe Usable Drinking Water In The Future For Almost Two Million People From Pottstown to Philadelphia.  Issues Include:
  • On-Going Depletion Issues
  •  Weakened Low-Flow Restrictions
  • Concentration of Radiation  and All Other Toxics In The Water
  1. 5.      Mine Water Pumped Into The Schuylkill River To Operate Limerick Must Be Filtered By Exelon Or Stopped.   Dangers Include:
  • Almost 1/2 Billion Gallons Per Month Of Contaminated Mine Water Pumped At 10,000 Gallons Per Minute
  • Manganese Permitted at 80 Times Safe Drinking Water Standards
  • Iron Permitted at 20 Times Safe Drinking Water Standards
  • Pottstown Water Issues – Related to Exelon’s Contaminated Mine Water
  1. 6.      Limerick’s Heated Discharges Exceed Schuylkill River Safe Temperature Limits
  • DRBC’s 5-Year DRAFT Docket Fails To Adequately Address Overheating The River
  • Trigger for Limerick Slow Down or Shut Down When The  87 Degree Temperature Limit  Is Exceeded  Should Replace Allowing Exelon To Do A Spreadsheet Starting AFTER The Docket Is Approved
  • DRBC Should Do Independent Temperature Testing Below Limerick’s Discharges During Heat and Drought
  • DRBC’s 59 Degree Requirement Should Be Kept In Place For Precaution
  1. 7.      Total Dissolved Solids – Why DRBC Must NOT Approve A 5-Year Docket That Releases Limerick Nuclear Plant From Compliance With A Limit That Protects Water and Health
  • Limerick Consistently Violates Safe Drinking Water Standards in 5-Year Permitting for Pollution Allowing Transports Of Radiation and Cooling Tower Toxics Into The River
  • Exelon Should Be Required To Filter TDS Discharges To Comply With Legal Limits To Protect Water and Health or Close
  • The 30 Month Monitoring Delay Tactic In DRBC’s Docket Is Unacceptable.   It Circumvents Legal Limits and Buys Time For  Relicensing and Uprates, Increasing Unprecedented Harms and Threats.
  1. 8.      DRBC Must Not Approve Unrestricted Use, In Essence, “Eminent Domain”,  of Vital Water Resources for Millions Of People
  • It Is An Unacceptable, Unthinkable Injustice That Millions Could End Up With No Water or Water So Radioactive It Could Not Be Used Safely, Due To A Limerick Accident or Meltdown
  • DRBC’s Docket Should Not Give Limerick Nuclear Plant Unrestricted Access To All Water Resources During a Limerick Nuclear Emergency or Meltdown, Regardless of the Potential to Render Dry or Otherwise Unusable Any Well or Surface Water Supply
  1. 9.      DRBC’s Director Should Not Control All Water Related Claims Against Limerick and Exelon For Loss Of Water
  • DRBC’s Executive Director should not be given the unilateral authority to 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 has been biased in docket decisions related to Limerick Nuclear Plant, repeatedly making decisions to benefit industry profits, not public water and public health
  1. 10.    DRBC’s Docket Must Require Public Notice and Input For All Future Exelon Requested Water Use To Operate Limerick Nuclear Plant  
  • The public needs and deserves an opportunity to understand and comment on their water resources
  1. 11.   Exelon’s Payments to DRBC For Limerick’s Use of Schuylkill River Water Are Not Being Used To Protect The Schuylkill River From Limerick Nuclear Plant’s Unprecedented Use and Abuse Of The River.
  • Exelon’s Payments to DRBC Provide An Incentive To Allow Increased Water Use and Discharges
  • In 2007, ACE Requested That DRBC Do An Independent Study On Limerick Nuclear Plant’s Impacts On The Schuylkill River Since 1985, To Determine The Consequences Of Future Impacts Related To Current Docket Approval For  More Pollution with Less Safeguards.  DRBC Refused, Claiming A Lack Of Resources. But Exelon’s Yearly Payments to DRBC Suggest Otherwise.
  • Apparent Underreporting and Underpayments to DRBC by Exelon Should Be Investigated and Recovered For A Study PRIOR To Approval of This Docket And Its Dangerous Loopholes 
  1. 12.   Schuylkill River Fund -This Arrangement With DRBC Promotes Deception and Buys Silence and Support For Limerick’s Unprecedented Threats and Harms to the Schuylkill River
  • This Funding Should  Be Used To Filter Dangerous Toxics Discharged From Limerick Nuclear Power Plant  and Contaminated Mine Pit Water
  • Funded Projects Present  Far Less Threats Than Limerick’s Radioactive Discharges, Cooling Tower Toxics, and Wadesville Mine Water Toxics
  1. 13.   Radioactive Discharges – DRBC’s DRAFT Docket Allows 14.2 Million Gallons Per Day Of Limerick Discharges Which Include A Broad Range Of Dangerous Long-Lived Radionuclides, Yet Limerick’s Routine and Accidental Radioactive Discharges Are Completely Ignored by DRBC In The Docket
  • Testing Proves Limerick’s Radionuclides Are In The Schuylkill River, Fish, And Sediment
  • Limerick’s Routine Radioactive Discharges and Radioactive Spills
  • Radiation Health Impacts
  • Philadelphia  – Limerick’s Link To  Highest Radiation Levels In Drinking Water In The Nation
  1. 14.   Fractured Permitting and Limerick Nuclear Plant’s Toxic Assault On The Schuylkill River –

No Agency Is Protecting Schuylkill River Water, or the Health of Millions From Limerick’s Radiation.  DRBC’s Docket Decisions Allow 5 Billion Gallons Of Limerick’s Discharges Contaminated With Radiation And Cooling Tower Toxics Into The River, While DRBC Gets Paid For Those Discharges, Yet Ignores Them In The Draft Docket.

  • DRBC Has An Ethical Obligation To Evaluate The Actual Consequences Of Their Decisions Related To Radioactive Threats
  • DRBC Must Not Issue A Docket That Allows Exelon To Circumvent Clean Water Standards For The Pollution That Transports Limerick’s Very Dangerous Radiation Into The River
  • Exelon Can and Must Filter Limerick’s Outfall 001 and Mine Pit Water, To Comply With Safe Drinking Water Standards To Protect Water and Health
  1. 15.   Cooling Tower Toxics – Tens of Thousands of Pounds of Dangerous Corrosive Toxics Are Added to Limerick’s Cooling Towers, Then End Up In Limerick’s 14.2 Million Gallons of Discharges DRBC Allows Into the Schuylkill River Each Day.
  • DRBC In Essence Plans To Approve A Docket With No Limit for The Pollution That Carries These Toxics Into The River
  • Exelon Cannot Be Permitted To Circumvent Clean Water Standards for This Pollution. Exelon Can and Must Filter TDS to Keep Them Out Of The River
  1. 16.   Monitoring Is Only An Illusion Of Protection.  It Fails To Prevent Harm.
  • DEP’s Deceptive Testing Protocol For Limerick
  • Why Exelon’s Monitoring, Testing, and Reporting Don’t Provide Full and Accurate Disclosure
  1. 17.    Related Correspondence Showing DRBC’s Failure To Address Or Even Answer Public Interest Concerns Over The Past Six Years 
  2. 18.    Letters to the Editor Related To Limerick Nuclear Plant’s Use and Abuse Of Public Water

 

ACE Urged DRBC To Consider The Reality And Totality Of Docket Decisions Being Made Related To Limerick Nuclear Plant’s Use And Discharges Into The Vital Drinking Water Resource For Millions From Pottstown to Philadelphia.  Unfortunately, Decisions In DRBC’s Final Docket Protected Exelon’s Interests, Not Our Vital Public Drinking Water Source.

  • Precaution and Prevention Are Imperative To Avoid A Drinking Water Disaster.  Yet, DRBC’s 2013 Docket For Limerick Failed To Protect Public Drinking Water.  Instead It Protected Exelon’s Profits.

 

  • NRC CONSULTED WITH THIS AGENCY THAT ABANDONED PUBLIC INTERESTS, BUT NRC REFUSED TO MEET WITH ACE OFFICERS ON BEHALF OF PUBLIC INTERESTS. 

 

  • ACE IS STILL OFFERING TO MEET WITH NRC IN OUR OFFICE TO DISCUSS ANY OF THE VITAL WATER ISSUES ASSOCIATED WITH  LIMERICK’S ENVIRONMENTAL AND PUBLIC HEALTH IMPACTS.

 

ACE Table Of Contents Below Is From Written Testimony to PA DEP   October 23, 2012 On Limerick Nuclear Plant’s DRAFT NPDES Permit No. PA0051926 

And Limerick Nuclear Plant’s Unprecedented Threats and Harms To Schuylkill River Drinking Water and Public Health

Section   Title                      

  1. Changes Are Essential In PA DEP’s 5-Year NPDES DRAFT Permit Renewal For Limerick Nuclear Plant, To Protect Schuylkill River Water and Health For Almost Two Million People
  • DEP Has The Responsibility and  Mission To Protect Water and Health of PA Citizens and Future Generations
  • DEP Has The Authority To Require Limerick Nuclear Plant To Comply With Safe Drinking Water Standards and to Enforce Compliance
  • DEP Can and Must Revoke Limerick Nuclear Plant’s NPDES Permit If Exelon Refuses To Comply With Safe Drinking Water Limits For Pollution That Carries Radiation and Cooling Towers Toxics Into A Drinking Water Source For Almost Two Million People
  1. Total Dissolved Solids (TDS) Discharged From Limerick Nuclear Plant’s Outfall 001 – NPDES            Permit Must Include Safe Drinking Water Limit.   TDS Transports Radiation and Cooling Tower Toxics Into The River.  A Safe Drinking Water Limit Must Be In Limerick’s NPDES Permit.
  • This Section Dispels False Claims and Excuses for Loopholes and Exemptions in Limerick’s NPDES Permit

(From DEP Documents and FOIA Obtained by ACE)  Proof:

­   There was a TDS Permit Limit for Limerick

­   Limerick Can’t Meet That TDS Permit Limit

­   Exelon Requested Drastic Increases for Limerick’s TDS Discharges To Avoid Violations

­   DEP Has Caved In To Exelon Current Demand for No Permit Limit For Limerick’s TDS

  1. Cooling Tower Toxics  Must Not Be Exempted From Limerick’s 5-Year NPDES Permit
  • Limerick’s Cooling Towers Discharge Massive Amounts of Dangerous Toxics Into The Schuylkill River With Total Dissolved Solids From Limerick’s Outfall 001
  • These Toxics Can And Must Be Filtered Out To Protect Water, Public Health, and Equipment At Water Treatment Systems
  1. Limerick’s NPDES Permit Must Include A Requirement to Prevent Further Overheating Of The Schuylkill River  From Limerick Nuclear Plant’s Continuous Discharges Heated Up To 110 Degrees (Over 5 Billion Gallons of Heated Discharges Each Year)
  • The Schuylkill River 87 Degree Temperature Limit  Has Been Repeatedly Exceeded
  • To Protect The River and Ecosystems, The Permit Must Include A Requirement For Limerick To Slow or Shut Down Power When The River Temperature Limit Is Exceeded
  • The Permit Must Include Specific Provisions for Enforcement Action
  1. Fractured Permitting For Limerick Is Jeopardizing Schuylkill River Water and Public Health
  • No Agency or Water Company Is Protecting Almost Two Million People From Pottstown to Philadelphia, From Limerick’s Radioactive Discharges Into Their Drinking Water  -  NOT DEP, NOT NRC,  NOT DRBC
  • Fractured Permitting Allows Agencies To Avoid Responsibility,  While Water and Public Health Are Furthered Jeopardized
  1. Why Monitoring Fails To Prevent Harm
  • Monitoring is a Deceptive Tactic Used by Agencies and Industry to Promote the Illusion of Protection
  • Why Exelon’s Monitoring, Testing, and Reporting Can’t Be Trusted
  1. Radiation – Limerick’s Dangerous Radioactive Discharges Are Transported Into The Schuylkill          River With Total Dissolved Solids From Outfall 001
  2. Radiation Health Impacts  – There Are No Safe Levels
  • Limerick Nuclear Plant’s Radioactive Discharges  Are Not Safe
  • Filtration Of Limerick’s Outfall 001 Would Reduce Serious Threats of Health Harms to Millions
  1. Radioactive Spills Reveal How Exelon and Regulatory Related Negligence Jeopardize Water and Health
  • Limerick’s 3-19-12 Radioactive Spill – Neither Exelon Nor Any Agency or Water Company Notified The Public Until 23 Days After The Spill
  • People Using Drinking Water Taken From The Schuylkill River Had NO Opportunity To Take Measures To Protect Themselves Or Their Children
  • Two Radioactive Spills Occurred In The Past Two Years
  •  Several Others Are Documented Over 20 Years
  • There has never been clean-up or even a fine
  1. Philadelphia’s Radioactive Drinking Water – Limerick’s Link
  • Philadelphia Had The Highest Level Of Radiation In Drinking Water In The Nation In 2011 Testing of 66 Water Treatment Systems Across the Nation
  • Limerick Nuclear Plant’s Radioactive Discharges Are Just 20 Miles Upstream From Philadelphia
  1. Depletion of the Schuylkill River is a Major Concern Related to Limerick Nuclear Plant
  • Limerick’s Cooling Towers Have Caused Significant Schuylkill River Depletion Since 1985. Limerick Withdraws Over 20 Billion Gallons Each Year From the Schuylkill River and Only Returns 5 Billion.   There Has Not Been Anywhere Near 15 Billion Gallons Supplemented In Any Year.
  • Depletion Causes Concentration of Limerick Radioactive Discharges, as Well as Cooling Tower Toxics, and Mine Water Toxics
  • Limerick’s NPDES Permit Ignores Depletion of The Schuylkill River and Concentration of Toxics
  1. Mine Water Pumped Into The Schuylkill River To Operate Limerick Must Be Filtered By Exelon
  • Almost 1/2 Billion Gallons Per Month Pumped At 10,000 Gallons Per Minute
  • Manganese Permitted at 80 Times Safe Drinking Water Standards – Iron 20 Times Higher
  • Pottstown Water Issues – Related to Exelon’s Contaminated Mine Water
  • DEP Has Been A Cheerleader For Pumping Contaminated Mine Water Into The River, Despite Calling Mine Water The Worst Threat To Groundwater In PA
  1. DEP Should Not Issue A 5-Year NPDES Permit With Loopholes and Exemptions That Will Enable Exelon To Get Approvals for Limerick Nuclear Plant:
  • Uprates to Run Limerick Harder and
  • Relicensing to Operate Limerick Longer
  • Both Will Have Profound Long-Term Consequences To Schuylkill River Water and Public Health.
  1. Schuylkill River Overview -  How Limerick Nuclear Plant Operations Threaten A Drinking Water Disaster
  2. Precautionary Principle
  3. Unanswered NPDES Questions and Concerns – NO RESPONSE Since January 17, 2011.

ACE Is Still Requesting Specific Responses From DEP, In the Comment Response Document For           This Hearing, To:

  • Letter to Jennifer Fields 9-1-10  NO RESPONSE
  • Letter to David Allard 4-4-09  NO RESPONSE
  1. Letters to the Editor Related To Limerick Nuclear Plant’s Use and Abuse Of Public Water

 

  • NRC CONSULTED WITH THIS AGENCY THAT ABANDONED PUBLIC INTERESTS, BUT NRC REFUSED TO MEET WITH ACE OFFICERS ON BEHALF OF PUBLIC INTERESTS.

 

  • ACE IS STILL OFFERING TO MEET WITH NRC IN OUR OFFICE TO DISCUSS ANY OF THE VITAL WATER ISSUES ASSOCIATED WITH THIS NPDES PERMIT AND LIMERICK’S ENVIRONMENTAL AND PUBLIC HEALTH IMPACTS.

 

In Summary:

  • 10-26-11 ACE provided NRC with a substantial body of irrefutable evidence on how and why Limerick Nuclear Plant operations could result in an irreversible drinking water disaster.  Limerick operations result in unprecedented threats to the Schuylkill River, a vital drinking water source for almost two million people from Pottstown to Philadelphia.
  • Limerick poisons the river water with radiation, routinely and accidently discharging radioactive wastewater containing a broad range of radionuclides, some with long half-lives.
  • NRC previously tried to mischaracterize Limerick’s discharges as just one radionuclide, Tritium, even though Exelon’s Radiological Monitoring Records in NRC’s own files prove the water, sediment, and fish all contain many radionuclides.

Exelon’s 2009 Radiological Monitoring Report For Limerick Shows:

  • 6   of   7  Gross Beta  Radionuclides Were Detected  In Surface Water
  • Beta Emitters Include:  Iodine-131, Cesium-137, Strontium-90, Cobalt-60, Zinc-65
  • Beta radionuclides can damage thyroid, liver, bone, muscles, ovaries, and cause cancer, birth defects, mutations, and miscarriages.

In WATER – 12  Different Radionuclides Were Reported                               

  1.         Iodine    I-131                 1./2 Lives       8    Days             
  2.         Cesium  Cs-134                                 30    Years
  3.         Cesium  Cs-137                                 30    Years
  4.         Manganese  Mn-54                           314   Days
  5.         Zinc        Zn-65                                  250   Days
  6.         Cobalt     Co-58                                   70     Days
  7.         Cobalt     Co-60                                   70    Days
  8.         Zirconium  Zr-95                                 65    Days
  9.         Iron  Fe-59                                          46.6 Days
  10.         Niobium Nb-95                                   35    Days
  11.         Barium   Ba-140                                 13    Days
  12.         Lanthanum   La-140                            40   Hours

                           In FISH  – 9  Different Radionuclides Were Reported                              

  1.         Iodine    I-131                                       8    Days
  2.         Cesium  Cs-134                                 30    Years
  3.         Cesium  Cs-137                                 30    Years
  4.         Manganese  Mn-54                           314   Days
  5.         Zinc        Zn-65                                  250   Days
  6.         Cobalt     Co-58                                   70    Days
  7.         Cobalt     Co-60                                   70    Days
  8.         Iron         Fe – 59                               456.6 Days
  9.         Potassium  K-40                                   1    Day

Note:           The Hazardous Life of a Radioactive Isotope is Ten to Twenty Times its Half-Life

Reality:       Synergistic, Additive, and Cumulative Harmful Impacts Are Obviously Significant

Problems:  Many Radionuclides go Unreported and Unmonitored – Sampling Is Woefully Inadequate

and Controlled by Exelon, a Company that Can’t Be Trusted

  • NRC does no testing.  No independent agency ever did long-term monitoring for all the radionuclides associated with Limerick operations.  But when the National Academy of Sciences says there is no safe level of exposure, the kinds and levels are not as important as the fact that almost two million people are always exposed to radiation in their water from Limerick.
  • Water companies are not required to continuously monitor, test, or filter the water for all Limerick’s radionuclides.
  • The Consequences Of Additive, Cumulative, and Synergistic, Radioactive Discharges From Limerick Nuclear Plant Into The Schuylkill River Since 1985 Are Obviously Significant NRC Doesn’t Test or Even Take Split Samples.  Far More Radionuclides Could be In Water And Fish Than Reported.  NRC Simply Reviews Exelon’s Unreliable Reports.
  • Limerick Nuclear Plant Testing Reports Reveal Iodine-131 In Water and Fish. Limerick is Clearly A Major Source of Iodine-131 Found In Philadelphia Water At The Highest Levels Of Any Water Treatment Plant In The Nation, Out Of 66 Cities Tested. Philadelphia is only about 20 Miles Downstream from Limerick.
  • A dangerous mix of massive toxic corrosive chemicals is discharged into the Schuylkill River from Limerick’s cooling towers.  Huge amounts of toxic chemicals are added to Limerick’s cooling towers every day.  Limerick uses at the site every day 94,293 to 192,614 pounds of toxic chemicals. They don’t just disappear, but instead end up in air and water pollution releases from the site.  Limerick uses Sodium Hypochlorite CHLORINE at the site – 16,000 to 58,000  lbs Per DAY -  Chlorine is continuously discharged into the Schuylkill River with no continuous testing to determine the extent of harm.  In fact, Limerick has just been given a permit exemption for the pollution that transports Limerick’s cooling tower chlorine and other toxics into the river, unmeasured and unfiltered.
  • Limerick’s discharges are violating Safe Drinking Water Standards for Total Dissolved Solids (TDS) (up to five times the safe level).  TDS transports Limerick’s radiation and cooling tower toxics into the river.

ü  To deal with continuous violations of Safe Standards, DEP EXEMPTED Limerick from a safe limit requirement, instead of requiring Exelon to filter the discharges.

ü  NRC is turning a blind eye to this enormous threat to public drinking water health risks and the eventual additional costs to water treatment systems and their customers.

  • Limerick insatiable water use by its cooling towers threatens the water supply across six PA counties.
  • Limerick Nuclear Plant has slowly but surely been depleting the Schuylkill River since it started operating in 1985.  Limerick withdraws more than double the amount of water every day than is withdrawn for Pottstown, Phoenixville, and Norristown in total. Limerick only returns ¼ of that to the river. Even after supplementation, the Schuylkill River had record low flows by 1999.
  • To supplement the flow for Limerick operations, Exelon is pumping billions of gallons each year of toxic unfiltered mine water into the river.  One toxic is permitted to be pumped into the river at 80 times higher than safe drinking water standards, even though it can cause permanent brain damage at the legal limit if showering in this water for 10 minutes each day for 10 years.
  • A meltdown at Limerick could require so much water that Exelon could take everyone’s water supplies without their permission, from Schuylkill County, the Delaware River, the Schuylkill River and all its tributaries, and the groundwater from the residents and businesses surrounding Limerick.
  • Limerick’s continuous heated discharges up to 110 degrees are regularly overheating the river with a temperature limit of 87 degrees.  This jeopardizes the river ecosystem.  Temperature restrictions for the river were just eliminated as requested by Exelon.

For A Detailed Review Of Some Of The Evidence ACE Provided To NRC 10-26-11

www.acereport.org  Download #6

“Schuylkill River – Limerick Operations: Threaten A Drinking Water Disaster”

 

  • EVIDENCE IS UNDENIABLE:  LIMERICK OPERATIONS UNQUESTIONABLY RESULT IN  UNPRECEDENTED THREATS AND HARMS TO THE SCHUYLKILL RIVER, A VITAL DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA.

 

  • IT IS NOT CREDIBLE FOR NRC’S DRAFT EIS TO STATE SUCH ENORMOUS THREATS AND HARMS TO THE SCHUYKLKILL RIVER ARE “SMALL” OR FOR NRC OFFICIALS TO CLAIM NRC IS NOT RESPONSIBLE TO ANALYZE THE ENVIRONMENTAL HARMS FROM LIMERICK’S WATER POLLUTION AND WATER USE PERMITS FOR LIMERICK’S ENVIRONMENTAL IMPACT STATEMENT.

 

  • NRC’S FINAL EIS MUST BE CHANGED TO REFLECT THE REALITY.  NRC’S CONCLUSION MUST SAY HARMS TO A VITAL DRINKING WATER RESOURCE ARE “LARGE”, NOT “SMALL” AND THAT NRC CANNOT GUARANTEE A SAFE, DRINKABLE WATER SUPPLY FOR ALMOST TWO MILLION RESIDENTS AND BUSINESSES FROM POTTSTOWN TO PHILADELPHIA DURING THE PERIOD OF REQUESTED EXTENDED OPERATION.

 

  • THE LONGER LIMERICK OPERATES THE MORE RADIOACTIVE THE SCHUYLKILL RIVER WATER WILL BECOME AND THE MORE TOXIC THE RIVER WILL BECOME FROM LIMERICK’S MASSIVE COOLING TOWER TOXICS AND MASSIVE MINE WATER PUMPING. THE RIVER WILL BECOME MORE DEPLETED AND HEATED. THE MORE RISK THERE WILL BE FOR MELTDOWNS THAT CAN CAUSE TOTAL LOSS OF WATER RESOURCES FOR MILLIONS OF PEOPLE ACROSS SIX PA COUNTIES.
  • TO REDUCE FUTURE HEALTH THREATS TO MILLIONS OF PEOPLE, NRC SHOULD REQUIRE EXELON TO FILTER ITS RADIOACTIVE DISCHARGES, COOLING TOWER TOXICS, AND MINE WATER PUMPING AS A CONDITION OF RELICENSING.

 

 

  1. 3.      RADIOACTIVE GROUNDWATER

 

LIMERICK’S RADIOACTIVE LEAKS AND SPILLS OVER DECADES CAUSED  GROUNDWATER TO BECOME RADIOACTIVE.

 

  • Some of Limerick’s radioactive leaks continued for long periods of time unabated. 

 

  • NRC never required clean-up of groundwater or soil and vegetation around it.

 

  • There are countless opportunities for future leaks in the miles of buried, hard-to-inspect pipes under the Limerick site. 

 

  • For 28 years some pipes have been transporting highly corrosive, heated, and radioactive water.  Aging and deterioration can cause pipes to become brittle and leak.

 

  • Earthquakes can break and disrupt pipes.  There is an earthquake fault right under the site, with four others within 17 miles.

 

IN NRC’S DRAFT EIS FOR LIMERICK, NRC IRRESPONSIBLY CALLED LIMERICK’S GROUNDWATER CONTAMINATION “SMALL” AND MADE INACCURATE STATEMENTS.

  • GIVEN THE LACK OF INDEPENDENT PROOF AND THE HUGE INCREASING RISK FOR RADIOACTIVE LEAKS IN THE MILES OF BURIED PIPES UNDER LIMERICK’S SITE, NRC’S CONCLUSION MUST BE CHANGED FROM “SMALL” TO “UNKNOWN”.

 

THERE IS CAUSE FOR CONCERN, PRECAUTION, AND PREVENTION!

  • AS A CONDITION OF RELICENSING, EXELON SHOULD BE REQUIRED TO CLEAN UP THE RADIOACTIVE GROUNDWATER AND SOIL THAT IS ALREADY CONTAMINATING THE SITE, TO TRY TO AVOID TRAVEL TO OFF-SITE RESIDENTIAL AND BUSINESS WELLS.

 

 

INSTEAD OF CLEAN-UPS AND PRECAUTION,

WE GET COVER-UPS AND LIES FROM NRC.

SETTING THE RECORD STRAIGHT ABOUT

RADIOACTIVE GROUNDWATER AT LIMERICK NUCLEAR PLANT

 

  • Limerick Nuclear Plant’s Leaks and Spills Caused Radioactive Groundwater Contamination, Confirmed By Exelon’s Own Monitoring And Reports To NRC.

 

  • At Least 12 Radionuclides Were Detected In Limerick’s Monitoring Wells.

 

  • 15 of 15 Limerick Nuclear Plant Monitoring Wells Found Beta Radiation. Beta Emitted Can Include Dangerous Long-Lived Radionucldes Such As Strontium-90 and Cesium-137.   Beta Emitters Also Include Iodine-131, Tritium, and Other Radionuclides.

 

  • Limerick’s 600 Acre Site Has Only 15 Monitoring Wells, Placed By Exelon, The Company With A Vested Interest In The Outcome, That Has Shown It Can’t Be Trusted To Provide Full and Timely Disclosure.

 

  • There Is No Independent Proof Radioactive Groundwater Has Not Traveled To Drinking Water Wells Around Limerick.    Within 1 Mile From The Center Of The Site Are 46 Domestic Withdrawal Wells, 2 Commercials Wells, and 1 Institutional Well.   Residents Wondered If Radioactive Groundwater Contamination Explains Limerick’s Purchase Of Hundreds More Acres Since The Mid 2000s.  This Tactic Has Been Used By Other Polluters As A Cover-Up.

 

  • It’s Only A Matter Of Time Until There Are More Radioactive Leaks Under Limerick From Miles Of Aging, Deteriorating Buried Pipelines Which Transported Highly Radioactive and Corrosive Liquids For Decades.   Think What Happens To Pipes In Homes Over Time, That Aren’t Even Continuously Transporting Such Corrosive, Radioactive Water.

 

  • Radioactive Leaks In Limerick’s Buried Pipelines and Fittings Could Go Undetected and Unreported For Decades, If Not Forever.

 

  • Earthquakes Can Cause Leaking In Limerick’s Underground Pipes.  Earthquakes Are Becoming Stronger and More Frequent.  There Are Two Faults Within 17 Miles of Limerick, One 9 Miles Away.   The 8-23-11 Virginia Earthquake Caused Shaking and Concern At The Limerick Site.
  • Limerick’s Historic Radioactive Leaks and Spills Have Never Been Cleaned Up.  In Fact, It Is Difficult, If Not Impossible To Completely Clean Them Up.  It Is Also Costly, If Not Impossible To Completely Remove All Limerick’s Radionuclides From Drinking Water.

 

PREVENTION IS THE ONLY CURE FOR THREATS TO HEALTH AND PROPERTY VALUES!

 

Limerick Nuclear Plant Should Be Closed To Minimize Future Health and Financial Harms From Radioactive Leaks Into Drinking Water.

A 20-year license extension to operate Limerick Nuclear Plant from 2029 to 2049 would allow 60 years of transporting Limerick’s highly radioactive corrosive fluids in miles of buried pipeline under Limerick.

  • Earthquakes, Combined With Deterioration Of Buried Pipes Carrying Highly Radioactive and Corrosive Fluids, Threaten Further Radioactive Groundwater Contamination At Limerick That Could Eventually Lead To A Drinking Water Disaster With No Truly Safe Solutions.

 

Limerick Radioactive Groundwater

Exelon’s 2009 Radiological Monitoring Report For Limerick Nuclear Plant Shows:

12  Radionuclides Are In Limerick’s Groundwater  (Page 10)

 

Exelon And NRC Deceptively Try To Claim It’s Just Tritium

BUT EXELON’S OWN MONITORING REPORT PROVES IT’S NOT JUST TRITIUM

In Exelon’s 2009  Radioactive Groundwater Results For Limerick Nuclear Plant, 12 Radionuclides Were Identified In Drinking Water / Well Testing  “Above Background”

Radionuclides                                   ½ Life

  1. 1.              Iodine    I-131                                       8     Days            
  2. 2.              Cesium  Cs-134                                  30    Years            
  3. 3.              Cesium  Cs-137                                  30    Years 
  4. 4.              Manganese  Mn-54                          314    Days               
  5. 5.              Zinc        Zn-65                                 250    Days
  6. 6.              Cobalt    Co-58                                   70     Days                           
  7. 7.              Cobalt    Co-60                                   70    Days
  8. 8.              Zirconium  Zr-95                               65     Days
  9. 9.              Iron        Fe-59                                    46.6  Days            
  10. 10.            Niobium Nb-95                                   35     Days
  11. 11.            Barium   Ba-140                                 13     Days            
  12. 12.            Lanthanum La-140                            40     Hours

              Note:  The Hazardous Life of a Radioactive Isotope is Ten to Twenty Times its Half-Life

Radionuclides Detected In Limerick’s Groundwater After Exposure  Can Cause:  

Cancer  -  Birth Defects – Mutations  – Miscarriages - In 1st and/or  Successive Generations

 

Beta Radiation Was Detected In 15 of 15  Groundwater Monitoring Locations

Beta / Gamma Emitters   Harmful Health Impacts

    Iodine – 131                                   Thyroid    Ovaries             

    Cobalt – 60                                     Liver         Ovaries             

    Zinc – 65                                         Bone         Ovaries

    Cesium – 137                                 Muscles   Ovaries

                   Strontium-90                                 Bone, Immune, Hormonal, Central Nervous Systems

All Can Cause Cancer – All Radioactive Isotopes Emitting Gamma Attack Reproductive Organs

The National Academy of Sciences BEIR VII Report Says There Is NO SAFE LEVEL of  EXPOSURE to RADIATION -  Synergistic, Additive, and Cumulative Harmful Health Impacts Are Not Evaluated

 

LIMERICK’S  GROUNDWATER  TEST  RESULTS

From  Exelon’s 2009 Radiological Report to NRC For Limerick Nuclear Power Plant  (Section A)

Gross Alpha, Gross Beta, Gamma, Uranium All Detected In Groundwater

Gross Alpha   (dissolved)    Detected   In   9  of 15    Groundwater locations

Gross Alpha   (suspended) Detected   In   5   of 15   Groundwater locations

Gross Beta     (dissolved)    Detected   In 15  of 15   Groundwater locations

Gross Beta     (suspended) Detected   In    3  of 15   Groundwater locations

            Gamma Emitters                Detected   In    3  of  15    Groundwater locations

            Uranium 233/234                Detected   In    4  of   5    Groundwater locations

 

DRINKING  WATER 

Exelon claims there is no drinking water pathway.

  • But Exelon’s claim is disputed by their own report on Page12

Well Survey Around Limerick Nuclear Plant

See Graphic From Exelon’s 2009 Radiological Monitoring Report

Within 1-Mile  (Radius From Center Of Limerick) From Page 12

Limerick has 1 Potable Water Supply Well 175 FEET from Reactor Building

  • Hopefully workers are not drinking this water or using this water for showering or other purposes.

46   Domestic Withdrawal Wells

2   Commercial Wells

1   Institutional Well

    2   Industrial Wells

    1   Fire Water Well Is 500 Feet from cooling towers

 

  • RADIOACTIVE GROUNDWATER AND DRINKING WATER THREATS

WILL INCREASE AS LONG AS LIMERICK OPERATES

 

BREAKDOWNS and LEAKS – There Are Countless Opportunities For Breakdowns and Leaks Under Limerick Nuclear Plant That Can Contaminate Groundwater.

 

  1. Miles of aging buried pipes under Limerick are corroding and deteriorating.
  • Limerick operated since 1985.
  • Miles of Limerick’s old buried pipelines transported highly radioactive and corrosive chemicals for decades.  They become very vulnerable to leaks over time.
  • Pipes and fittings corrode and become brittle over time, then leak.
  • Leaks in the miles of underground buried pipes are hard to detect.
  • Radioactive leaks in the miles of Limerick’s aging buried pipes can go undetected and/or unaddressed and/or unreported for long periods of time, if not forever.   Radiation can slowly spread in groundwater to off-site wells.
  1. Earthquakes can cause leaks by shaking and breaking Limerick’s miles of underground pipes and vast numbers of fittings.
  • Limerick is 3rd on the nation’s earthquake risk list for nuclear plants.
  • Two earthquake faults are extremely close to Limerick – 9 miles and 17 miles away.
  • There is great cause for concern, considering the August 23, 2011 earthquake as far away as Virginia caused shaking with potential for damage to buried pipes at Limerick.

 

RADIOACTIVE GROUNDWATER CONTAMINATION CAN SPREAD INTO OFF-SITE WELLS UNDETECTED NOW AND IN THE FUTURE

  • Limerick is one of the 102 of 104 of our nation’s nuclear reactors that contaminated groundwater with radiation.
  • Groundwater is confirmed to be radioactive under Limerick’s 600 acre site.
  • Reliable monitoring to accurately determine the full extent of spreading radioactive groundwater contamination would be cost prohibitive.  Radiation could poison well water for long periods of time.
  • Limerick’s radioactive contaminated groundwater could have been spreading long periods of time, in any direction, in this fractured bedrock aquifer.    Radioactive groundwater contamination may have already moved off the Limerick site, undetected or unreported by Exelon.
  • Radiation in Limerick’s groundwater was never cleaned up.  There is no plan to clean it up.
  • New leaks and spills can happen without full disclosure.
  • Exelon failed to fully disclose and address radioactive water contamination at some of its other nuclear plants.
  • At one nuclear plant site in Illinois, Exelon failed to provide full and accurate disclosure for years, then finally supplied 600 residents with bottled water for years more until they were finally put on public water.
  • The same thing could happen at Limerick,.jeopardizing drinking water and public health.
  • Once groundwater becomes radioactive it is difficult, if not impossible to clean up.  Exelon never tried, either here or at its other nuclear plants.
  • Radiation levels detected for a specific radionuclide are not the real issue, since there is no safe level of radiation and research on synergistic harmful impacts over time are unknown.
  • Any radiation level in drinking water can cause risk for cancer, immune damage, and other health harms.

 

PREVENTION IS THE ONLY CURE.  It’s Not Likely Limerick’s Radioactive Groundwater Can Be Completely Cleaned Up.  

  • Once groundwater becomes radioactive, it seems impossible to completely clean it up.
  • There are countless residents whose properties could become virtually worthless due to radioactive contaminated groundwater caused by leaks and spills at Limerick.
  • Filtration at residents’ homes would be cost prohibitive for many.
  • History shows Exelon won’t pay to filter residents’ water throughout their homes.
  • All 100 to 200 radionuclides  associated with producing nuclear power would have to be filtered out from all sinks and showers in a home to make it safer.
  • It is difficult and very costly to try to remove all radiation from drinking water.  Some water filtration companies claim it is impossible.

 

Why Exelon’s Monitoring and Reporting Is Not Reliable On Limerick’s Radioactive Groundwater Contamination

 

Exelon’s Radioactive Groundwater Monitoring Is Woefully Inadequate

  • The Limerick Site Is 600 Acres With Just 15 Monitoring Wells Placed By Exelon.   There Are Miles Of Aging Buried Pipelines Under Limerick Carrying Highly Radioactive and Corrosive Liquids.  After decades of operation slow leaks could go undetected and unreported for long periods of time, if not forever.
  • A Monitoring Diagram from Exelon’s Radioactive Monitoring for Limerick Shows Only 15 Monitoring Wells on 600 Acres (On Average, Just 1 Monitoring Well For Every 40 Acres).   Diagram attached from Exelon’s 2009 Radiological Monitoring Report On Limerick Figure 1 Graphic – A-2.
  • Only 15 Monitoring Wells For 600 Acres In This Fractured Bedrock Aquifer Cannot Accurately Determine The Direction Or The Extent Of Limerick’s Radioactive Groundwater Contamination.

ü  Limerick Nuclear Plant is located in a fractured bedrock aquifer (Brunswick Formation).

ü  Research on this kind of aquifer and statements from scientists suggest to accurately identify the extent of radioactive ground water contamination that traveled off site, wells would need to be placed 1 foot apart and stacked around the entire site. 

ü  Radioactive contamination can travel in any direction, at any depth, and fail to ever be detected in a fractured bedrock aquifer.

ü   Hundreds of stacked monitoring wells would be needed to detect all potential groundwater contamination from miles of underground pipes, especially in this fractured bedrock aquifer.

  • Placement Of Monitoring Wells Is Questionable.

Exelon, the company with a vested interest in the outcome decided where to place the monitoring wells. Exelon has shown elsewhere why it can’t be trusted.

Exelon’s attached diagram Reveals:

ü  NO Monitoring Well SSE

ü  Only 1 close to the site S

ü  Only 1 close to the site SE

  • Limerick’s Radioactive Groundwater Contamination May Have Already Contaminated Nearby Drinking Water Wells.

ü  There has never been an independent study to prove nearby wells are not contaminated with radiation.

ü  Exelon controls the entire woefully inadequate monitoring, testing, and reporting process.

 

PROOF RADIOACTIVE GROUNDWATER WAS CAUSED BY LIMERICK NUCLEAR PLANT:   April 27, 2010 Letter From Exelon to NRC

RE: Limerick Nuclear Plant’s 2009 Radiological Environmental Operating Report

  • In This Letter Exelon Admitted Radiation Found In Groundwater and Soil Was From Limerick Nuclear Plant
  1. 1.      Exelon admits Cesium-137 was found in sediment and attributable to Limerick Nuclear Plant “liquid releases”.
  2. 2.      Exelon admits Tritium was in 3 of 15 Limerick groundwater monitoring locations.

 

Issues Related To Exelon’s “Admission” Of Radioactive Contamination of Groundwater and Soil at Limerick:

  • Exelon  admits to detecting only Tritium and Cesium-137 in the groundwater and soil from Limerick Nuclear Plant leaks.  That is ludicrous when  a broad range of radionuclides associated with Limerick  operations would logically be in Limerick’s radioactive leaks into groundwater and soil along with Tritium and Cesium-137.
  • Exelon, the company with a vested interest in the outcome controls the monitoring protocol, testing, and reporting.   We can’t trust Exelon, a company that failed miserably in providing full and timely disclosure about radioactive water contamination due to other nuclear plants they owned in Illinois and New Jersey.
  • Exelon failed to completely clean up radioactive contamination of groundwater.   Exelon says, “There are no commitments in this letter”.
  • If radioactive contamination of groundwater won’t be cleaned up, then  vast numbers of residential wells in the region could eventually become contaminated, as radioactive groundwater contamination spreads.

 

LEAKS AND SPILLS WERE DOCUMENTED AT LIMERICK NUCLEAR PLANT FOR OVER 20 YEARS

NRC Documents Prove Limerick Had Radioactive Leaks and Spills And That The Ground Water Is Radioactive.

Exelon Admitted To 4 Radioactive Leaks Over 20 years (1986 to 2006)

October 2, 2006  Mercury article by Evan Brandt on Limerick leaks.

  • Exelon’s final results of a study, stated, “Limerick is not “actively”  leaking radioactive tritium into groundwater or surface water.”  This title suggested to many that Limerick didn’t leak which is deceptive and not true.   It also absurdly suggested that tritium was the only radionuclide leaked into Limerick’s groundwater, which is proven inaccurate by Exelon’s own radiation reports to NRC for Limerick.
  • Exelon spokeswoman Rapczynski described “historic releases” as 4  “unplanned liquid releases” of tritium that took place “over the past 20 years.”  She said “spills occurred “in isolated area on the plant property where you don’t normally find tritium,”  and claimed they were all reported to NRC and DEP.
  • Rapczynski said Limerick releases were “highly diluted” tritiated water into the Schuylkill River.  Tritium was found in 6 water samples taken from on-site wells at Limerick and in 1 surface water sample.   Exelon said the higher levels are the result of “historic releases”.
  • Both NRC and Exelon downplayed the levels of tritium found, and ignored all the other radionuclides found in Limerick’s groundwater and surface water In Exelon’s own radiation reports to NRC.
  • Both dismissed a 2005 study by the National Academy of Sciences concluding that even low-levels of ionizing radiation, including tritium, pose a health risk if exposure occurs over a long period of time.

 

From Questionnaire Sent to NRC from Exelon about Limerick Nuclear Plant,

For Industry Groundwater Protection Initiative Voluntary Data Collection

March 2002, a Limerick Nuclear Plant steam evaporator leak discharged through the blow-down panel on the north side of the Turbine Building.

  • Exelon admits this radioactive liquid release had the potential to reach groundwater.
  • As a result of the steam seal evaporator leak in March of 2002, 6 inches of gravel over an area of approximately 100 square feet was shipped to a licensed offsite radioactive waste disposal facility.

From Limerick 2009 Groundwater Protection Program Report

Page 12  E.  Leaks, Spills, and Releases

2-13-09 a LEAK from exterior walls of both U1 and U2 condenser bays was observed.

This Radioactive Spill Continued For Six Days. 

  • NO ACTIONS were required to recover or reverse groundwater plumes.  It’s NO Wonder Groundwater Under Limerick Is Radioactive.
  • NO investigations are on-going.
  • Condensation from condenser bays was observed DRIPPING DIRECTLY TO OPEN GROUND AND ASPHALT.
  • Release to ground occurred for SIX DAYS – until catch containments were installed.
  • Radiation released was estimated.
  • Groundwater sampling identified Tritium in 1 down gradient well, MW-LM-9 at a concentration of 1750 pCi/L.
  • All data on the leaks along the condenser bay joints was added to Limerick’s decommissioning file – 10 CFR 50.75(g).
  • 4-3-09 the radioactive water from the catch containments was released to Limerick’s holding pond, which releases through the liquid effluent release point at outfall 001.
  • The catch containment water contained approximately 747 uCi of tritium.

How Far Has Radioactive Groundwater Traveled Over 20 Years?   How Many Leaks Went Undetected and Unreported?

 

Why Exelon’s Groundwater Monitoring Can’t Be Trusted

At other Exelon nuclear plants, Exelon failed to provide full, accurate, and timely disclosure of leaking pipes and radioactive contaminated groundwater.  Exelon failed to take immediate action when problems were found.  Even when radioactive groundwater contamination could no longer be denied, Exelon didn’t replace pipes immediately.  Exelon failed to report radiation leaks into water from their nuclear reactors for many years.  Numerous repeated radioactive leaks went unaddressed over almost ten years at Exelon’s Braidwood nuclear plant.  Exelon also had radioactive leaks at their Dresden and Byron nuclear plants in Illinois.   Some called it Exelon’s “Radioactive Watergate”.

 

Braidwood, Illinois

Exelon’s deception and inaction led to unnecessary health risks and diminished property value concerns.

  • 22 recurring uncontrolled radioactive spills from the same buried pipe went inadequately addressed and not fully disclosed from 1996 to 2005.
  • Exelon supplied 600 people with bottled water for more than four years.
  • For many years there was no bottled water and even after the bottled water was supplied people are still forced to shower, cook, brush their teeth, etc. with radioactive contaminated water.
  • Clean-up of so much radioactive contamination in the ground is a farce.
  • Exposure increases the risk of developing cancer, according to legal papers.  Ironically, while illogically claiming there was no public health threat, March 13, 2010 it was reported Exelon paid a court settlement.
  • A resident said, “it’s scary to live here, but who in their right minds would buy homes here?”
  • Some people questioned whether or not a $1 million settlement to spend on some environmental projects makes up for damage caused by numerous radiation leaks discovered on and around nuclear power plants reported through the years.
  • A mother of a teen battling cancer said, “If the cancer is in the air we breathe or the water we drank, I don’t think there is enough money to go around. I know they admitted to the mistakes but how do you put a price tag on the environments.”
  • Exelon is also paying $11.5 million to bring in a water system. Exelon is footing the bill for Godley residents to enjoy bottled water until the construction is complete.

Oyster Creek, New Jersey

Exelon failed to disclose radioactive leaks until 7 days after the Oyster Creek nuclear reactor was relicensed by NRC. 

In 2009 Exelon disclosed radioactive water leaking from buried pipes 7 days after NRC re-licensed this oldest nuclear plant in the U.S.  Either NRC was duped by Exelon or NRC was complicit.   Either is unacceptable.

  • This seriously damages trust in Exelon and NRC’s credibility in its reviews for re-licensing.  
  • Radioactive water reached a major New Jersey aquifer (southern Jersey’s main drinking water source), at concentrations 50 times higher than those allowed by law.
  • First reported April 9, 2009, the radioactive groundwater contamination is gradually moving toward wells in the area at 1 to 3 feet a day.
  • Corrosion caused the reactor’s crucial safety liner to rust and thin. How long were there undetected / unreported leaks?  Is this happening at Limerick?
  • NJDEP is taking aggressive action to safeguard water and hold Exelon accountable.
  • The wait and see approach in response to another ‘trust us’ from Exelon resulted in exactly what some feared, contamination of one of the most significant aquifers in the region.
  • NRC has failed to suspend or withdraw Oyster Creek’s license renewal.

 

Limerick Leak Went Unaddressed For Years

This Leak Was Reported Through Exelon’s Own Document Mailed To ACE From a Whistleblower.

  • Exelon’s document proved the leak at Limerick went unaddressed for many years, yet both Exelon and NRC first publically denied the leak ever existed.
  • Exelon denied this unaddressed Limerick leak, even though ACE informed Exelon the information came from a document from Exelon’s own files.
  • A year later, even though they first denied the leak existed, ACE was told by NRC that the leak had been fixed.

 

Cause For Concern:

  1. Limerick’s Radioactive Groundwater Could Have Traveled Off-Site Into Residential Wells
  2. There Has Never Been A Comprehensive Independent Radiation Monitoring Protocol At Limerick Nuclear Plant Nor Independent Radiation Monitoring Of Well Water Around Limerick’s Reactors.

ü  Exelon, The Company With A Vested Interest In The Outcome, That Has Shown It Can’t Be Trusted To Provide Full and Timely Disclosure Elsewhere, Controls The Monitoring Protocol

ü  Many Radionuclides Go Unreported and Unmonitored

ü  Radionuclides Detected Are Only Reported If Above Background

March, 2011 – After Fukushima, Background Levels Were Raised From 360 to 620.

 

Absent funding to determine full and accurate independent evidence of harm and then clean-up, precaution in decision making becomes even more imperative.

  • Limerick Should Be Closed To Avoid The Risk Of More Radioactive Groundwater That Can Spread Into Offsite Residential Wells..
  • Closing Limerick Is The Only Way To Minimize Future Risk Of Additional Radioactive Drinking Water.

 

NRC’S DRAFT EIS, IN ESSENCE, IS ALLOWING LIMERICK’S RADIOACTIVE GROUNDWATER CONTAMINATION TO SPREAD AND INCREASE

 

NRC Is Failing In Its Oversight Responsibility To Protect Public Health

FAILURE To Require Clean-Up of Limerick’s Radioactive Groundwater

NRC’s records confirm radioactive leaks and spills at Limerick.

ü  As A Condition of Relicensing NRC should require complete clean-up to avoid radioactive groundwater reaching public drinking water wells very close to Limerick. 

ü  For years, NRC has ignored its oversight and enforcement responsibilities. 

NRC failed to require complete clean-up, jeopardizing nearby drinking water.

NRC’s  “Leak First and Fix Later” Policy Is An Unacceptable Threat to Groundwater and Public Drinking Water.

            NRC has allowed Exelon to:

  • Deceive the agency
  • Cut corners
  • Make up their own regulations
  • Stall corrective actions or even avoid them to save money   

NRC Knew About Limerick’s Radioactive Groundwater For 20 Years, But Ignored Its Oversight and Enforcement Responsibility.

 

Evidence Confirms Why We Can’t Believe or Trust NRC To Protect Our Water:

  1. 1.     NRC fact sheets call leaks at 102 nuclear plants a few. 
  2. 2.     NRC falsely claims huge radioactive leaks into groundwater are “minor”. 

Vermont Yankee – Up to 2.7 million picocuries per liter.  NOT minor.

Illinois – Exelon bought bottled water for 600 people for 4 years.  NOT minor.

Oyster Creek – South Jersey’s drinking water was contaminated at concentrations 50 times higher than allowed by law.  NOT MINOR.

3.   NRC misleadingly suggests leaks contain only one kind of radiation, tritium.       

      Reactors involve 100 to 200 radioactive chemicals.  Not just one is leaking into groundwater.

      Radionuclides like strontium, cesium, iodine, and plutonium are also transported in

underground pipes leaking radioactive wastewater into groundwater.  All can cause cancer. 

4.   NRC’s attempts to trivialize health impacts from tritium by misleadingly stating that  

      “tritium is a mildly radioactive isotope“.    

       Scientific studies show exposure to tritium is linked with higher cancer rates in humans.

Tritium should be securely stored for hundreds of years or it can enter the human body by

breathing, eating, and drinking (mostly from drinking water).

5.   NRC absurdly claims monitoring programs confirm the leaks do not affect public

      health and safety and the environment. 

      There’s a logical and reasonable expectation that public health and safety are unnecessarily

jeopardized. Monitoring is a farce.

    

  • Thousands of residents relying on well water in communities surrounding Limerick Nuclear Plant deserve immediate full and truthful disclosure to protect their family’s health!

 

In 2002 Greenpeace called NRC’s regulation of the nuclear industry a “FARCE”.  They urged shut down of U.S. nukes to “AVOID a TRAGEDY”.  ACE agrees that NRC regulation is a FARCE.

  • Limerick Nuclear Plant should be closed to avoid a tragedy in our region.

Below Is ACE’s Letter to NRC Expressing Our Concern About NRC’s Capitulation to the Nuclear Industry Which Is Leading To An Unfolding Radioactive Groundwater Disaster From Limerick and Other Nuclear Plants

 

June 23, 2010  -  ACE to NRC Branch Chief

RE:   NRC’s Capitulation To The Nuclear Industry About    

  • Potential For An Unfolding Radioactive Groundwater Disaster From Leaking Nuclear Plants 

 

NRC’s  “Leak First and Fix Later” Policy

  • An Unacceptable Threat to Groundwater and Public Drinking Water.
    • 102 of 104 US nuclear reactors are leaking radioactive water into groundwater from underground leaking pipes.
    • NRC’s policy failed to prevent radioactive leaking.  NRC’s policies are NOT protective and NOT acceptable. 
    • NRC should not relicense another nuclear reactor without requiring replacement of pipes.

Major Concerns with NRC Policies

  • NRC allows the industry to deceive the agency, cut corners, make up their own regulations, and stall corrective actions or even avoid them to save money.   
  1. 1.      Buried pipe systems carrying radioactive water under U.S. nuclear reactors remain inaccessible, and therefore, largely uninspected and unmaintained. 
  2. 2.      Radioactive leaks into groundwater are inevitable and can go undetected and uncontained for long periods of time.  Once radioactive groundwater spreads, it’s too late. 
  3. 3.      Radioactive contaminated groundwater is already proven in Illinois, New Jersey, Vermont and others. 
  4. 4.      It’s difficult, costly, and likely even impossible, to completely clean up contamination or filter all radionuclides out of drinking water.
  5. 5.      NRC Ignored its Oversight and Enforcement Responsibility.  NRC should be mandating compliance with established requirements for control and monitoring of buried pipe systems carrying radioactive effluent.
  6. Instead, NRC is ceding its responsibility to voluntary industry initiatives that will add 3 years on to a decades old environmental and public health risk problem.   NRC turned its regulatory authority over to an industry that now plans to stall corrective actions for 3 years, for a decades old radioactive contamination problem.  

ü  Despite NRC efforts initiated in 1979 to prevent uncontrolled radioactive releases to groundwater, NRC is capitulating to an industry decision to take almost three more years before announcing an action plan. 

  • Nuclear industry stall tactics will allow radioactive contamination to spread further and result in relicensing of leaky nuclear reactors.    Oyster Creek example.

 

It’s difficult to understand why NRC assists the nuclear industry in deceiving the public about the reality of the radioactive threats to groundwater from leaking pipes under nuclear plants. 

 

Both NRC and the nuclear industry have avoided full and truthful disclosure of leaks and radioactive groundwater contamination, fail to immediately stop leaking, and downplay and trivialize health risks.  

 

NRC and the nuclear industry downplay and trivialize health risks of prolonged exposure to radiation in water, which causes cancer, genetic mutations, and birth defects.

NRC’s fact sheets are downright deceptive.

  • NRC calls 102 a few.  

ü  102 leaks are documented from1963 thru 2009, with 15 from March 2009 to April 2010.

  • NRC falsely claims radioactive leaks into groundwater are “minor”. 

ü  January, 2010 levels up to 2.7 million picocuries per liter were reported at Vermont Yankee. That  shouldn’t be called “minor” by anyone, much less NRC.

ü  Exelon bought bottled water for 600 people for 4 years in Illinois.  Does NRC expect the public to believe that was for “minor” contamination?

ü  Oyster Creek’s radioactive contamination of groundwater is a major threat to South Jersey’s drinking water.   Radioactive water at concentrations 50 times higher than those allowed by law has reached a major New Jersey aquifer, southern New Jersey’s main source of drinking water.  Reported April 9, 2009, radioactive groundwater is gradually moving toward area wells at 1 to 3 feet a day.

  • NRC misleadingly suggests leaks contain only one kind of radiation, tritium.

ü  Reactors involve 100 to 200 radioactive chemicals.  Not just one is leaking into groundwater.

ü  Radionuclides like strontium, cesium, iodine, and plutonium are likely transported in underground pipes leaking into groundwater.  All can cause cancer.

  • NRC’s attempts to trivialize health impacts from tritium by misleadingly stating 

                        “tritium is a mildly radioactive isotope“.    

ü  Scientific studies show exposure to tritium is linked with higher cancer rates in humans.

ü  Tritium should be securely stored for hundreds of years or it can enter the human body by breathing, eating, and drinking (mostly from drinking water). 

  • NRC illogically and absurdly claims its monitoring programs to confirm the leaks do not

                 affect public health            and safety and the environment. 

                             

With significant documented radioactive contamination of drinking water in Illinois, New Jersey, and Vermont there’s a logical expectation that public health and safety were unnecessarily jeopardized by NRC’s failed policies and inadequate protection.   We don’t want the same thing to happen at Limerick that NRC allowed to happen at Oyster Creek.

 

NRC’s Irresponsible Policies Must Change, Starting At Limerick Nuclear Plant.

  • Exelon is asking NRC for Limerick license renewal, when in Illinois and New Jersey Exelon showed it can’t be trusted to provide full and accurate timely disclosure of radioactive leaks under its nuclear plants.

 

 

  1. 4.  AIR POLLUTION  – DRASTIC INCREASES IN DANGEROUS PM-10 WERE PERMITTED FOR LIMERICK’S COOLING TOWERS IN 2009, YET NRC’S DRAFT CONCLUDED ENVIRONMENTAL IMPACTS FROM LIMERICK’S AIR POLLUTION WERE “SMALL”.

 

THIS KIND OF AIR POLLUTION IS CONSIDERED MORE DEADLY THAN OZONE.

  • IT IS NOT CREDIBLE FOR NRC TO CLAIM THE IMPACTS FROM LIMERICK NUCLEAR PLANT’S AIR POLLUTION ARE “SMALL”.

 

LIMERICK’S DANGEROUS AIR POLLUTION HARMS HEALTH

  • LIMERICK IS CONSIDERED A MAJOR AIR POLLUTION SOURCE UNDER HEALTH-BASED STANDARDS OF THE CLEAN AIR ACT.

 

Limerick Nuclear Power Plant emits so much dangerous air pollution (in addition to radiation) that it’s considered a MAJOR AIR POLLUTION source under the Clean Air Act.  The following facts have been compiled by ACE from Limerick Nuclear Plant’s Title V Air Pollution Permit.

 

LIMERICK NUCLEAR PLANT’S AIR POLLUTION INCLUDES:

  1. 1.      Radiation – from routine operations and accidental releases
  2. 2.      Schuylkill River Toxics – from withdrawing 56.2 Million Gallons Per Day
  3. 3.      Toxic Chemicals – from adding over 300 lbs per day to Cooling Towers
  4. 4.      Greenhouse Gases, Combustion Chemicals & By-products – from Boilers, Etc.
  5. 5.      Waste Fuel – from a Boiler 

 

AIR POLLUTANTS from Limerick Nuclear Plant Include:

  • Radiation
  • PM10
  • VOCs
  • NOx
  • SO2
  • Arsenic
  • Cadmium
  • Chromium
  • Lead
  • PCBs
  • Halogens
  • This dangerous SYNERGISTIC MIX continuously threatens the health of families in the region, especially children.   ADDITIVE, CUMULATIVE HEALTH IMPACTS could be significant.

 

32 SOURCES of Limerick Nuclear Plant’s Air Pollution Include:

  • 2 Cooling towers
  • 3 Boilers
  • 8 Generators
  • 8 Diesel Oil Tanks
  • 8 Day Tanks
  • Degreasing Unit
  • Emergency Spray Pond
  • Various Waste Oil Sources
  • There is NO FILTRATION FOR TOXICS from any of the sources.

 

ACE’s review of Limerick’s air pollution permit revealed a shocking number of air pollution sources and pollutants, with no continuous monitoring or filtration on any of them.  In fact, there are extraordinary permit loopholes.

 

      Limerick’s Permit Loopholes are Unprotective and Unacceptable.  Almost anything goes.

  • Radiation, the signature toxic at a nuclear plant, was excluded even though radiation emissions are regulated by EPA and reported by Exelon to NRC.
  • Limerick Nuclear Plant Title V permit renewal lists 32 air pollution sources and a broad range of pollutants, but excludes radiation the signature toxic released from a nuclear plant.
  • No air pollution control equipment is required on any of the many sources.
  • Reported emissions are based on illusion, not reality.  Annual reports are largely based on Exelon’s own “calculations” and “estimates”, not on actual emissions testing.   There is no independent testing.
  • Exelon can increase dangerous air pollution from the nuclear plant without going through any kind of review or approval process.
  • There are all kinds of exemptions.
  • Preapproved permit revisions are allowed under economic incentives.

 

Limerick Nuclear Plant’s additive, cumulative, and synergistic harmful health impacts are unknown, but clearly significant.  Children, elderly, and those already sick are most impacted.  

Examples of Synergism:

  • NOx + SO2 = acid rain which can jeopardize water, soil and food.   When NOx and SO2 meet with steam (35 to 42 million gallons per day emitted from Limerick towers), sulfuric and nitric acids can be formed in the air causing major respiratory damage and other health harms when inhaled.   Limerick’s permit allows automatic (TONS per year) increases in both.
  • NOx + VOCs with sunlight increases ozone, which kills thousands of people each year and sends many more for hospital emergency room visits.
  • Ozone works synergistically with radiation to enhance the cancer causing effects of radiation.

 

Synergistic, Additive, and Cumulative Harmful Health Impacts From Limerick’s Air Pollution Are Unknown, But Clearly Unprecedented,

 When They Include:

  1. A Broad Range of Radionuclides
  2. Massive Emissions of Many Dangerous Cooling Tower Toxics
  3. Combustion Chemicals From Boilers and Generators
  4. Waste Derived Liquid Fuel
  5. And Various Other Sources of PM-10 Emissions

 

Families throughout the region are at risk from Limerick Nuclear Plant’s radiation emissions and other toxic air pollutants.   Consider the following:

-         Philadelphia, only about 20 miles away, is in the predominant wind direction. 

-         Routine radiation releases go into our air, but are not measured in air or listed in Limerick’s Title V permit. 

-         Limerick’s cooling towers and other sources emit massive dangerous PM 10 emissions which are not accurately measured or filtered.

-         The effluent stream from the river to the sky through the cooling towers includes all river toxics.

-         Cooling tower emissions include toxics added to the towers. 

-         No toxics are filtered out from any of the 32 air pollution sources listed in Limerick Nuclear Plant’s Title V Air Pollution Permit.

 

  • To protect the health of everyone in the region, as a condition of relicensing, NRC should require Exelon to install the most protective filtration for all Limerick Nuclear Power Plant’s air pollution sources, and filtration of Schuylkill River water intake to minimize PM-10 emissions from the cooling towers.

 

 

Other Than Radiation, The Most Dangerous Air Pollution Comes From Limerick Nuclear Plant’s COOLING TOWERS

  • Ø In 2009, Drastic Increases Were Permitted In Particulate Matter (PM-10) From Limerick’s Cooling Towers.

 

In Limerick Nuclear Plant’s Most Recent Title V Air Pollution Permit Renewal, Exelon Requested Drastic Increases In Dangerous Particulate Matter (PM-10) from Limerick’s Two Cooling Towers.

  • Instead of requiring filtration of Schuylkill River water intake to minimize PM-10 emissions from Limerick’s cooling towers, PA DEP permitted drastic increases in PM-10 emissions (more than 6 times higher original permit limits). 

 

Drastic Increases Permitted For Limerick’s PM-10 Are Indefensible.

How many more people will get sick and die as a result of the nasty witches brew of toxic chemicals massively spewed out in aerosol form from Limerick’s cooling towers?   

 

PM-10 consists of tiny airborne particles that can carry other toxics, penetrate deep into the lungs, enter the bloodstream and lead to serious health threats and healthcare costs.

        Long Term PM 10 Health Effects Are Linked To:

ü  Increased Heart Attacks

ü  Strokes

ü  Aggravated Asthma

ü  Inflaming Lungs Like Sunburn On Skin

ü  Increased Respiratory Disease

ü  Decreased Lung Function

ü  Increased Hospital Admission

ü  Increased Emergency Room Visits

ü  Premature Death – Blamed For Thousands Of Deaths Each Year

 

  • To Protect Public Health, As A Condition Of Relicensing, NRC Should Require Exelon To Reduce PM-10 Air Pollution From Limerick’s Cooling Towers by Requiring Filtration Of  Schuylkill River Water Intake For Total Dissolved Solids.

 

PM-10 IS EMITTED FROM 14 DIFFERENT SOURCES AT Limerick Nuclear Plant

ü  2 Cooling Towers   

ü  3 Boilers

ü  8 Generators

ü  The Emergency Spray Pond

How Much PM 10 Is Emitting From Limerick’s 14 Sources?

  • NO ONE KNOWS FOR SURE!   Exelon “ESTIMATES” and “CALCULATES” Limerick’s PM10 Emissions.   THERE ARE NO RELIABLE AIR MEASUREMENTS.

 

PUBLIC HEALTH IS AT RISK FROM LIMERICK’S PM-10 EMISSIONS

  • The American Lung Association says Particulate Matter is more deadly than ozone.
  • Montgomery County is already among the highest for PM-10 emissions in the nation.
  • PM-10 is regulated under health based standards of the Clean Air Act, because it causes serious harm to health.
  • PM-10 causes more emergency room visits and hospital admissions, thus even leading to higher costs for medical care.

 

FACTS ABOUT PM-10 FROM LIMERICK COOLING TOWERS

  • PA DEP stated that Limerick’s cooling towers are an effluent stream from the river to the sky.   35 to 42 million gallons of contaminated water go into the air every day from Limerick’s cooling towers.

PM-10 carries other dangerous toxics withdrawn with as much as 56 million gallons every day from the highly contaminated Schuylkill River  with NO filtration for toxics.

  • Toxic chemicals are added to Limerick’s cooling towers.   Exelon’s response to ACE claimed 324 pounds per day.  Most chemicals listed were extremely corrosive.  All caused health harm.   Pounds added per day to cooling towers could be considerably higher.  Since reviewing Limerick’s NPDES permit renewal we learned over 94,293 to 192,614 Pounds Per Day of Toxic Chemicals are used at Limerick Nuclear Plant.
  • Potential Limerick toxics carried into our air with PM10 from the cooling towers include:

- Radiation     – Heavy Metals     – Pathogens     – Corrosive Chemical Additives

.    

PM-10 Details From Limerick’s Title V Permit

In Limerick’s Title V Permit Renewal TVOP-46-00038, Exelon requested that PA DEP approve a huge increase in blowdown water from 1,256 ppmw to 10,000 ppmw for each cooling tower.

According to Exelon:

  • Limiting blowdown TDS to 1,256 for each cooling tower restricts particulate matter (PM) and creates an unnecessary risk to Limerick for noncompliance.      

 

“PA DEP Air Quality Bureau will not set the limit on TDS concentration for the blowdown entering Outfall 001, since this is a Water Quality issue.” 

  • DEP changed the language of the permit so that Exelon complies with both Air Quality and Water Quality requirements, instead of requiring Exelon to filter Schuylkill River water intake to reduce PM-10 emissions into our air and to enforce Limerick’s original PM-10 permit limits.
  • Limerick Nuclear Plant Was Permitted Conditions That Allow Possibly An 8-Fold INCREASE From The Cooling Towers In PM-10 Emissions, A Dangerous Clean Air Act Pollutant Blamed For Thousands Of Deaths Each Year.
  • This should NOT have happened, especially in a county which already ranks in the top 10% of the nation for dangerous PM-!0 emissions.

 

Exelon Expressed Concern About Air Pollution If They Would Install Cooling Towers As Requested By N.J. DEP, At Oyster Creek In New Jersey:

  • In Essence, Exelon Admitted Cooling Tower Air Pollution Is Harmful.

Exelon used Cooling Tower Air Pollution, as an excuse to avoid spending millions to build cooling                towers at Oyster Creek.  Exelon said, “Cooling Towers Would Create Air Pollution”.

 

Limerick’s Title V Air Pollution Permit Lists 32 Air Pollution Sources and 10 Dangerous Regulated Toxics.

    Air Pollutants Listed In Limerick’s Air Permit      Air Pollution Sources In Limerick’s Permit

Nox                                                                                    2 Cooling Towers

VOCs                                                                                 3 Boilers

PM-10                                                                                 8 Generators

SO2                                                                                    8 Diesel Tanks

Arsenic                                                                               8 Day Tanks

Cadmium                                                                            Degreasing Unit

Chromium                                                                           Emergency Spray Pond

Lead                                                                                   Various Waste Oil Sources

PCBs

Halogens

  • NO FILTRATION IS REQUIRED FOR ANY TOXICS LISTED ABOVE 

Numerous Studies Show The Kinds Of Air Pollution Produced By Limerick’s 32 Sources Contribute To A Broad Range of Disease and Disabilities.

  • World Health Organization Estimated Air Pollution Would Cause About 8 Million Deaths Worldwide by 2020
  • American Cancer Society
  • Harvard School of Public Health
  • John’s Hopkins School of Public Health
  • Cedars-Sinai Medical Center

 

Dr. Devra Davis reported that there are more than 1,000 studies from 20 countries all showing you can predict a certain death rate for asthma, heart disease, and lung disorders based on the amount of air pollution.

 

Cooling Towers Host Pathogens

Research Shows Health Threats From Cooling Towers Include Pathogens

Cooling Towers Spray Infectious Pathogens Into Our Air.  These Pathogens Can Cause Disease in Humans, Even Legionella

 

  • Section 4.9.3 on Microbiological Organisms of NRC’S DRAFT EIS States That Limerick Cooling Towers Release Microbiological Organisms, INCLUDING:

SALMONELLA, LEGIONELLA, AND PSEUDOMONAS AERUGINOSA,which can cause serious and sometimes fatal infections in immune compromised individuals.  

  • THESE TOXINS ARE DOCUMENTED TO BE HARMFUL TO HUMANS AND ANIMALS.

 

  • Exelon requested PA DEP to provide comments or confirm Exelon’s conclusion about a low likelihood of risk from pathogens released from Limerick contribute to related health effects. 

 

  • PA DEP would not make any conclusions regarding the effect on public health.

 

  • NRC says optimal growing temperature is 99 degrees F, but Limerick’s cooling tower waters are allowed to be up to 110 degrees.

 

NRC HAS CONCLUDED THAT IMPACTS ON PUBLIC HEALTH FROM THESE ORGANISMS WOULD BE “SMALL”, BUT THERE NO PROOF OF THAT, WHETHER IN RELEASES TO AIR OR WATER.

  • 44 MILLION GALLONS Of Cooling Tower Steam Are Released Into Our Air Every Day.   
  • 14.2 MILLION GALLONS Of Limerick’s Wastewater Are Released Into The River Every Day.  
  • There Are NO Measurements By NRC Or Exelon For The Pathogens In The Air Or River Releases From Limerick’s Cooling Towers.     
  • Limerick’s Cooling Tower Waste Water Is Allowed To Be Heated Up To 110 Degrees. 
    • NRC HAS NO ACCURATE IDEA OF HOW THESE PATHOGENS ARE IMPACTING THE POPULATION OVER TIME.
    • NRC MUST CHANGE ITS CONCLUSION THAT IMPACTS WOULD BE “SMALL” TO IMPACTS ARE “UNKNOWN”.

 

COOLING  TOWER  DRIFTDRIFT IS SPRAY DROPLETS – NOT VAPOR 

  • Drift Droplets Are Contaminated With Everything In The System
  • Up to 44 Million Gallons of Toxic Filled Steam Are Emitted Into Our Air Every Day.
  • There Is NO Filtration – Exposure Risks Are Unknown

 

Drift Can Contain:

  • Radiation – A Broad Range of Radionuclides

               Examples:            Iodine 131 – Major Isotope Known To Be Released

Strontium-90 – Found in our children’s teeth

Radioactive Crypton – Upsets of electromagnetic imbalance

  • Heavy Metals – From Schuylkill River Water Intake
  • Pathogens and Microbes – Science Daily 8-28-08
  • Toxic Chemicals In Limerick Nuclear Plant’s Drift Come From:

1)      Schuylkill River Water Withdrawn

58.2 Million Gallons Per Day        20 ½ Billion Gallons Per Year

2)      Every day Exelon Adds Massive Amounts Of Toxic Chemicals To Cooling Towers

Toxic/Corrosive Chemicals Added To Limerick’s Cooling Tower Water

-        According to Exelon:  324  Pounds Used EACH DAY     118,260  Pounds Used PER YEAR

-        Could be far more – Over   94,293   to  192,614   Pounds  Per Day  Of Toxic Chemicals Are Used At Limerick Nuclear Plant.

-         Examples of Toxic Additives From Limerick Nuclear Plant’s MSDS Sheets Are Listed Below.    ACE listed corrosives showing why there is cause for concern about corrosion of steel used for Limerick casks and other equipment.

  1. Sulfuric Acid                                         Corrosive to metals
  2. Phosphoric Acid                                   Corrosive to steel / most metals
  3. Phosphonic Acid                                   Corrosive to steel
  4. Hypochlorous Acid                               Corrosive
  5. Sodium Bromide and Water                   Corrosive
  6. Sodium Hydroxide                                Corrosive to metals
  7. Sodium Hypochlorite solution                                Hyprocochloris Acid – Corrosive
  8. Sodium Per Sulfate                                               MSDS says avoid moisture / Incompatible with moisture
  9. Zinc Oxide                                            Breaks down structures such as steel
  10. Ethyl Alcohol                                         Weak Acid -  can be Corrosive
  11. Chlorine                                                World Health Organization Limits Air Exposure

 

  • While All Toxics Above Can Be Carried With Limerick’s Drift, PM10 Is The Only Cooling Tower Air Pollutant Required to be Reported By Exelon In Limerick’s Title V Air Pollution Permit.

 

PROOF OF ENORMOUS HEALTH RISK FROM CORROSIVE CHEMICALS ADDED TO LIMERICK’S COOLING TOWERS:

  • CHLORINE FROM LIMERICK’S COOLING TOWER PLUME CAN CORRODE STAINLESS STEEL.

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

  • KNOWING CHLORINE FROM LIMERICK’S COOLING TOWER AIR EMISSIONS CORRODES STAINLESS STEEL, WE MUST ASK WHAT IS IT DOING TO PEOPLE’S LUNGS?

How we know:

Related to a recent NRC safety inspection report letter to Exelon for relicensing, NRC expressed concern about chlorine contaminated air at Limerick and its corrosive impacts on stainless steel.

  • Exelon Said There Was No Concern Because “The Cooling Tower Plume Is Directed Away From The Plant.”
  • In Essence, Exelon Admitted The Region’s Residents Are Breathing Highly Corrosive Air From Limerick’s Cooling Towers.
  • This Could Explain The Extraordinary Lung Problems Experienced In The Region Around Limerick, Including Lung Cancer.

 

  • EVEN THOUGH EXELON INADVERTENTLY ADMITTED PEOPLE WERE BREATHING HIGHLY CORROSIVE AIR, NRC TOOK NO ACTION TO PROTECT PUBLIC HEALTH.

 

Toxics In Drift Synergize and Blow Far Distances

How far is drift carried from Limerick Nuclear Plant?

  • 2  Cooling Towers Are 500 Feet High (Comparable to a Building over 40 Stories High)
  • Independent measurements are needed over Limerick Nuclear Plant site boundary  

Drift Travels Far Distances - Example: From One County to Another

  • Dispute Over Russian Border  – 1 country complained about cooling towers contaminating their side of the border.
  • Levels over site boundary were greater than permitted - Maine Yankee violations led to company stopping using one chemical after testing

Toxics In Drift Concentrate When They Hit Land and Dry.

  • River Bend – Needed a separate parking lot to shelter cars due to active concentrations

 

Our Region Is Already Overexposed To Air Pollution Compared To The Nation

  • Montgomery County Is In The Top 10% Of The Nation For Emissions Of PM-10 and VOCs
  • Montgomery County Is In The Top 20% For SO2 Emissions
    • Still, DEP Permitted INCREASES In Limerick’s Title V Permit

PM10       Particulate Matter                                  +  3 TONS

VOCs      Volatile Organic Compounds +  5 TONS

SO2         Oxides of Sulfur                     +  8 TONS

NOx         Nitrogen Oxides                     +  5 TONS

CO        Carbon Monoxide                                    + 20 TONS

American Lung Association’s 2003 Report Gave Montgomery County A Grade Of “F” For Unhealthy Air

  • Montgomery County Had 2nd Dirtiest Air in the State, Far Worse Than Philadelphia, Berks, or Chester Counties, “State of the Air Report for 1999-2001.”

 

Examples Of Harmful Health Impacts and Synergism

PM-10  Particulate Matter

ü  Increases Heart Attacks and Strokes

ü  Aggravates Asthma

ü  Inflames Lungs Like Sunburn

ü  Increases Respiratory Disease

ü  Decreases Lung Function

ü  Increases Hospital Admission and Emergency Room Visits

ü  Blamed For Thousands Of Premature Deaths Each Year

VOCs  Volatile Organic Compounds

ü  Cancer

ü  Leukemia

ü  Liver Damage

ü  Kidney Damage

ü  Digestive Disorders

ü  Neurological Disorders

ü  Reproductive Problems

ü  Decreased Immune Function Leading to Many Illnesses

VOC’s Extremely TOXIC In Small Amounts

NOx Nitrogen Oxides

Toxicant to:

ü  Blood

ü  Cardiovascular

ü  Endocrine

ü  Immune System

ü  Reproductive

ü  Neurological

ü  Skin and Sense Organ

NOx reacts with moisture and other compounds to form nitric acid and related particles.

VOCs + NOx = Ground-Level  OZONE

Acute, Short Term Effects include:

ü  Shortness of Breath

ü  Phlegm Build Up

ü  Coughing, Wheezing

ü  Watery Eyes, Runny Nose

ü  Sore Throat

ü  Head Colds

ü  Chest Colds

ü  Chest Pain

Repeated Exposure Can Result In:

ü  Permanent Lung Damage

ü  Respiratory Infection

ü  Lung Inflammation

ü  Aggravate Asthma

 

RADIATION  INTERACTING  WITH  OZONE ENHANCES CANCER RISKS

From Mc Donnell, M.D. Health Effects Research Laboratory

EPA Testimony, April 9, 1987,  to U.S. Senate

Ø  “OZONE  WORKS  SYNERGISTICALLY  WITH  RADIATION  TO  ENHANCE  THE CANCER-CAUSING  EFFECTS  OF  RADIATION.”

 

Radiation, the most potent carcinogen, is routinely released from Limerick Nuclear Plant.   Radiation is the signature, most dangerous toxic released from nuclear plants.    Radiation levels released cause more risk of cancer when breathed in with VOCs and NOx.

 

January 2010, ACE presented agency and elected officials with an expose and list of recommendations and requests related to permitted PM-10 increases at Limerick Nuclear Plant.  

Sources Used For ACE Air Pollution Comments:

Limerick Title V Permit Renewal TVOP-46-00038 12-7-09

EPA Air Pollution Data – Compiled At www.scorecard.org

http://epa.gov/air/particlepollution/

AP 3-19-10 Article in Mercury by Wayne Parry “Exelon Threatens to Shut Down N.J. Nuke Plant”

Statistics and Facts in Hard Science Show: Air Pollution Kills  and Cripples,  Net Works 2001

Cooling Towers May Host New Pathogens – Research by Sharon G. Berk and colleagues – ScienceDaily 8-28-06

All evidence of harm was ignored.  Public health was abandoned.  Agency regulators and elected officials ignored the increased threats to public health and increased financial health care costs, all to protect Exelon’s profits.

 

GIVEN THE HEALTH IMPACTS DOCUMENTED TO BE ASSOCIATED WITH THE KIND OF TOXIC AIR POLLUTION RELEASED FROM LIMERICK, ESPECIALLY FROM THE COOLING TOWERS, LIMERICK NUCLEAR PLANT IS AN OBVIOUS MAJOR FACTOR IN: 

  • State Data Reported By EPA In 2003 SHOWING FAR HIGHER NUMBERS FOR:

ü  Infant and Neonatal Mortality

ü  Malignant Tumors

ü  Cerebrovascular Disease

ü  Respiratory Diseases

ALL ARE FAR HIGHER NEAR LIMERICK NUCLEAR PLANT THAN THE STATE AVERAGE, AND FAR HIGHER THAN PHILADELPHIA OR READING.

 

ACE Summary Conclusions:

 

  • Limerick Nuclear Power Plant Is A Major Air Pollution Source Under Health Based Standards Of The Clean Air Act and Is Clearly A Major Factor In The Health Crisis That Developed After Limerick Started to Operate in 1985.

 

  • Yet, NRC Has Repeatedly Attempted To Ignore and/or Dismiss Limerick’s Air Pollution Threats To Health and The Environment In Limerick’s Updated Environmental Impact Statement (EIS).

 

  • Fractured Agency Permitting Is NOT An Excuse To Dismiss Serious Environmental and Health Impacts From Limerick Nuclear Plant’s Major Air Pollution For NRC’s Updated EIS. Just Because PA DEP Issues Limerick Nuclear Plant’s Air Pollution Permit Does Not Eliminate The Harms Our Region Faces From It.

 

  • Without a year of independent air monitoring, testing, and reporting for all Limerick Nuclear Plant’s radionuclides and other air pollutants, the community should reject any NRC conclusions in NRC’s updated Environmental Impact Statement for Limerick Nuclear Plant as invalid. 

 

  • Unless additive, cumulative, and synergistic harmful health impacts from radiation releases and all other air pollutants from Limerick are accurately determined, including from recent permitted drastic increases,  the Precautionary Principle should be followed and Limerick should be closed, NOT RELICENSED.  

 

  • As long as Limerick Nuclear Plant operates, dangerous air pollution will continue and even increase.  
  • To protect public health and avoid unnecessary health care costs, Limerick should close now.
  • 20 more years of exposure to the massive toxic brew of air pollution from Limerick is unacceptable.  Limerick must close now.

 

Documents and Other Information Are Available For Review By Appointment At The ACE Office In Pottstown (610) 326-2387

 

NRC IS RESPONSIBLE TO PROTECT PUBLIC HEALTH RELATED TO LIMERICK NUCLEAR PLANT.  

  • THE EVIDENCE PROVES LIMERICK’S AIR POLLUTION IS A MAJOR THREAT TO PUBLIC HEALTH.  AS A CONDITION OF RELICENSING, NRC MUST REQUIRE EXELON TO FILTER SCHUYLKILL RIVER WATER INTAKE, AND NOT ALLOW LIMERICK’S DANGEROUS AIR POLLUTION TO CONTINUE WITHOUT AT LEAST SOME SAFEGUARDS.

 

RADIATION RELEASES TO AIR 

  • Limerick routinely releases a broad range of radionuclides into the air.
  • Radioactive air particulates are not listed in Limerick’s Title V Air Permit, even though all air pollutants and sources from a major air polluter are supposed to be listed.
  • Actual data and/or harmful health impacts from Limerick’s routine and accidental radioactive releases are unknown.

 

Radiation Testing and Reporting To NRC Are Deceptive

  • Ø  Radiation Levels Reported By Exelon For Limerick’s Releases To Air Do Not Reflect Risks To The Public From All Limerick’s Radionuclides Released Into Our Air.   
  • JUST BECAUSE EXELON ISN’T REQUIRED TO REPORT ALL RADIONUCLIDES LIMERICK RELEASES INTO OUR AIR, DOESN’T MEAN THOSE RADIONUCLIDES DO NOT INCREASE OUR RISK.

Radiation Levels identified by monitoring are only reported for Limerick by Exelon when they are above an arbitrary background level.  Above background reporting is deceptive.  Exelon can hide actual radiation releases from Limerick and actual risks.  

       Radiation Background Levels Are Arbitrary, Deceptive, and Clearly Not Protective:  

  • 80 to 100 Millirems Per Year – Natural background BEFORE Chernobyl
  • 360 Millirems Per Year – AFTER Chernobyl
  • 620 Millirems Per Year – AFTER Fukushima, Japan

The National Academy of Sciences Says There Is NO SAFE DOSE

March 16, 2011, After Japan’s Nuclear Disaster, NRC Legally Sanctioned Increased Radiation Harm To Regions Like Ours, Routinely Exposed To Nuclear Plant Radiation Releases.

 

Other Deceptive Unprotrective Tactics In Radiation Reporting

  • Exelon, the company with a vested interest in the outcome that has shown it can’t be trusted, controls all radiation monitoring, testing, and reporting.
  • Exelon is allowed to ‘CALCULATE” and “AVERAGE” results.
  • The system fails to report on radiation spikes.

 

Examples From Exelon’s 2007 Self-Monitoring Report to NRC

  1. Lower Limit Detection (LLD)ABOVE BACKGROUND IS DECEPTIVE.   

Defined as smallest concentration of radioactive material in a sample that would yield a net

LLD does not mean the actual level detected  -  Level detected could be far higher

  1. Positive Results Were “CALCULATED”  – Gamma Spectroscopy

Standard deviations represent variability of measured results for different samples rather than single analysis uncertainty.

  1. 3.      Net Activity – Calculated by subtracting background from sample.

MDC was reported in all cases – but they can claim positive activity was not detected.

 

Radioactive Air Particulates – Air particulate samples collected weekly in 2007.

  • GROSS BETA WAS DETECTED AT ALL LOCATIONS.

Beta Emissions Can Include Strontium-90, Tritium, and Many Other Radionuclides

 

  • GAMMA WAS DETECTED IN ALL SAMPLES

Be-7  Beryllium 7:  UNstable (1/2 life 53 days) was detected in all samples

 

Beta Particles and Gamma Rays Penetrate the Human Body and Environment, Causing Biological, Chemical, and/or Physical Damage.

  • Cancer, Leukemia, Heart Failure, Neuromuscular Diseases and Many Other Health Effects Can Result From Long-Term Exposures.  
  • Harmful Health Impacts Can Take Many Years To Develop.

 

Examples:  Harmful Health Impacts To Specific Parts Of The Body

  • Thyroid  /  Ovaries               Iodine – 131          Beta / Gamma  Emitter
  • Liver  /  Ovaries                   Cobalt – 60            Beta / Gamma Emitter
  • Bone / Ovaries                     Zinc – 65               Beta / Gamma Emitter
  • Muscles / Ovaries                Cesium – 137        Beta / Gamma Emitter
  • Bones / Teeth                       Strontium-90         Beta Emitter  29 year half-life

 

  • Strontium 90 (SR-90) Attaches To Particulate Matter – Easily Travels With Air

SR-90 Masquerades As Calcium – Absorbs Into Bones and Teeth.

  • Some of the highest levels of Strontium-90 were found in the teeth of children around Limerick Nuclear Power Plant  (Tooth Fairy Study)

All GAMMA Radiation Emitters Attack REPRODUCTIVE ORGANS

  • Prostate Cancer Increased in Montgomery County 132% Since Limerick Nuclear Power Plant Started (Mid 1980s to Mid 1990s)
  • Other related cancers also drastically increased above the national average since Limerick started operating.

 

Radiation Can Cause Birth Defects, Mutations, and Miscarriages

  • In 1st  and / or Successive Generations After Exposure.  
  • Infant death and childhood cancer reductions after nuclear plant closings in the United States – 2002 Study – Deaths among infants who had lived downwind and within 64 km of each plant dropped.
  • Infant and Neonatal Mortality In The Area Around Limerick Are Far Higher Than State Averages and Higher Than Philadelphia or Reading.

Other radionuclides in testing were claimed by Exelon to be less than the MDC

  • BUT  Minimum Detectable Concentration (MDC) Is Only An ESTIMATE and Only Reported IF Above Background

 

Limerick Nuclear Plant’s Air Pollution Summary:

 

  • 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!

 

Major Points:

 

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 dangerous cooling tower air pollution that is considered more deadly than ozone by the American Lung Association.

  • Exelon’s request for huge PM-10 permit increases to avoid air pollution permit violations alone makes our case.

Limerick’s cooling towers release 44 million gallons of steam into the air every day containing massive PM-10, which transports into our air Limerick’s radioactive air particulates, toxic and corrosive chemicals added to Limerick’s cooling towers by Exelon, toxics from the Schuylkill River including heavy metals, and pathogens from inside the cooling towers.

  • Limerick’s Cooling Towers Emissions Result In A Constant Enormous and Extremely Toxic Effluent Stream Into The Sky.  It is indefensible to consider the harmful consequences of this witch’s brew of toxic air, “small”.

Exelon rejected NJ DEP’s requirement to put up cooling towers at Oyster Creek in N.J., stating air pollution as the reason.

  • Exelon admitted the dangers of cooling tower air pollution.

 

Limerick’s air permit identifies a broad range of toxic pollutants from 32 different air pollution sources involved with Limerick operations – PLUS RADIATION AIR PARTICULATES THAT ARE NOT LISTED IN LIMERICK’S TITLE V PERMIT.

  • THAT SHOULD NOT BE CONSIDERED “SMALL” RISK BY ANYONE.

 

Since ACE’S 10-11 EIS testimony NRC’s letter to Exelon proves that chlorine from Limerick’s cooling tower air pollution is so corrosive that it corrodes stainless steel.

  • EXELON ADMITTED THIS HIGHLY CORROSIVE AIR IS TRANSPORTED OFF-SITE.  IT OBVIOUSLY GETS INTO THE LUNGS OF RESIDENTS.

 

  • GIVEN THE BODY OF EVIDENCE ABOVE ON ALL LIMERICK NUCLEAR PLANT’S DANGEROUS AIR POLLLUTION THREATS, NRC’S DRAFT EIS CONCLUSION THAT LIMERICK’S AIR POLLUTION IMPACTS ARE “SMALL” MUST BE CHANGED IN NRC’S FINAL EIS TO STATE THAT IMPACTS ARE “LARGE”.

 

Sources and Issues:

  1. Limerick Air Pollution Sources and Pollutants.  Source: PA DEP Title V Air Pollution Permit summarized by ACE 2009.
  2. Lists of Limerick Nuclear Plant’s kinds of air pollution, air pollutants, and sources.   Source:  PA DEP Title V Air Pollution Permit – Listed by ACE after review of the permit in 2009.
  3. Limerick Nuclear Plant’s PA DEP Title V Air Pollution Permit (46-00038) Provides The Proof – Only Major Air Pollution Sources Are Required to Submit Title V Permits.  Limerick Nuclear Plant’s most recent Title V Air Pollution Permit Renewal was issued to the owner, Exelon, December 2009.
  4. “Nuclear Plant is a Major Source of Air Pollution – 2/14/09 Op-ed summary of Limerick Nuclear Power Plant’s air pollution permit, informing the public of health risks from  the ACE Board of Directors,.
  5. ACE’s January 2010 Analysis of PA DEP’s Public Response Document Identifies Why Limerick’s Air Pollution is a Major Health Threat to our region and Why This Permit and the Permitting Process Failed to Protect Public Health.
  6. Recommendations and Requests from ACE January 2010 to PA DEP Secretary John Hanger, identifying concerns with the permit and requesting him to take action to reduce specific air pollution threats that his agency permitted to be drastically increased, instead of requiring filtration.
  7. Particulate Matter (PM10), the major air pollution threat from Limerick Nuclear Plant to the families in the region.   12/7/09 PA DEP permitted PM 10 emissions to be emitted 6 to 8 times higher than current limits without requirement for filtration and in addition to an automatically permitted 3 Ton Increase.
  8. List of PM 10 Harmful Health Effects, Sources: EPA and ATSDR.
  9. Toxics Carried With Limerick Nuclear Plant’s Massive Cooling Tower Drift.
  10. 324 Pounds Per Day Toxic Chemicals Added to Limerick’s Cooling Tower’s, Source:  MSDS Sheets Provided by Exelon In 2004.
  11. List of automatically permitted toxics in Limerick’s Title V permit.
  12. Documented harmful health impacts of pollutants with automatically permitted increases.  Source:   EPA.   These pollutants are regulated by EPA under health standards of the Clean Air Act because of their toxicity to humans.
  13. Air in the Region Already in the Top 10% of the worst in the US – For the very pollutants permitted to have automatic increases in Limerick’s Title V permit.
  14. Exhaust Flow Volumes Were Increased In Limerick’s Title V Permit.
  15. Lists of Air Pollution Studies, Including A List On Children – Compiled by ACE.

 

IN CONCLUSION:

 

ACE TESTIMONY REVEALS LIMERICK’S UNPRECEDENTED CONTAMINATION OF OUR AIR AND WATER IS CLEAR AND INDISPUTABLE!

 

  • NRC SHOULD NOT CALL ANY OF THE IMPACTS IDENTIFED ABOVE “SMALL”.  IN TOTAL, THEY SHOULD BE CLASSIFIED AS “LARGE”.

 

THE OVERWHELMING EVIDENCE CONFIRMS SIGNIFICANT ENVIRONMENTAL HARM TO DATE!

 

  • ANOTHER 20 YEARS SHOULD NOT BE A VIABLE CONSIDERATION.

 

NRC’S DRAFT EIS IS ABOUT THE HEALTH AND SAFETY OF THE ENTIRE GREATER PHILADELPHIA REGION.

 

  • NRC’S REGULATORY DECEPTION AND NEGLIGENCE CANNOT BE TOLERATED:

 

ACE absolutely objects to NRC’s deceptive, unprotective regulatory process for this EIS.  NRC seems to believe we don’t understand.  We do understand all too well, but refuse to conform to NRC’s industry-biased process that fails miserably to protect public health, safety, and financial interests.

 

Examples of NRC Negligent Oversight:

 

  1. NRC failed to independently evaluate Limerick Nuclear Plant’s major air pollution permit or its dangerous NPDES permit to pollute the Schuylkill River, even though ACE identified a body of evidence and submitted extensive summaries showing why these permits cause undue risks to the health and safety of vast numbers of people.
  • Instead of an independent review of Limerick’s permits using the information provided from ACE’s review of the permits, NRC consulted with the agencies responsible for allowing Limerick to have dangerous pollution permit increases and permit exemptions because Limerick can’t meet limits in place to protect public health.
  • NRC refused to provide time for ACE to make presentations of the findings from our extensive comprehensive public interest reviews of Limerick’s air and water pollution permits.
  • NRC Public Relations Rhetoric Doesn’t Match Its Actions.  NRC claims to want public input, but then refuses requests to meet.  There is no excuse.  NRC repeatedly came to Limerick Nuclear Plant, just three miles from our home office where we have the permits, along with our analyses, and other research to which we refer.

 

  1. NRC attempts to abdicate responsibility for Limerick’s major air pollution and water contamination is shameful and unacceptable.
  • NRC is responsible for public health and safety related to Limerick Nuclear Plant operations.
  • NRC is preparing an Environmental Impact Statement for Limerick Nuclear Plant.
  • In place of the meeting ACE repeatedly requested to explain the complicated water pollution permit issues, NRC said ACE could talk to members of NRC’s Environmental Review Team at the 5-23-13 public hearing.
  • To best explain the complicated multiple threats ACE prepared multiple graphic boards for discussion at the hearing.
  • Unfortunately, it became clear we were providing information to people who were not interested in being “confused with the facts”.

 

A member of NRC’s Environmental Review Team told ACE members 5-23-13, that NRC is not responsible for the air and water pollution threats from Limerick Nuclear Power Plant.

  • THAT CAN’T BE TRUE!

NRC is responsible for all the health harm from Limerick Nuclear Plant operations.  Major pollution permitted in Limerick’s air and water pollution permits clearly present enormous threats to public health.  THAT MAKES IT NRC’S RESPONSIBILITY.

  • It is indefensible for NRC to make inaccurate, unsubstantiated conclusions in Limerick’s Environmental Impact Statement, if NRC has no intention of actually analyzing health and environmental consequences of Limerick’s air and water pollution permits.
  • It is indefensible for NRC to avoid doing the detailed analyses of the consequences of Limerick’s dangerous pollution permits simply by consulting with the agencies that allowed drastic increases in those permits and allowed dangerous exemptions and loopholes because Limerick can’t meet their original permit limits or standards in place to protect public health.
  • It is inexplicable and unacceptable that NRC refused to have their Environmental Review Team for Limerick’s EIS meet with ACE officers that did do comprehensive independent reviews and analyses of Limerick’s air and water pollution permits.

 

  • NRC failed to respond to ACE comments on Limerick’s unprecedented air and water pollution threats from our 10-26-11 testimony, separately, or in Limerick’s DRAFT EIS as NRC claimed.
  • NRC claimed they used ACE comments to inform their review to develop the DRAFT EIS.  THAT CAN’T BE TRUE or NRC COULD NOT HAVE CONCLUDED HARMS ARE “SMALL”.

 

Ms. Perkins June 10, 2013 e-mail to ACE states that “NRC uses public scoping comments to inform their review and develop the DSEIS.   NRC responds to all public scoping comments by issuing a scoping summary report in the DSEIS.”  That is not true.

  • If NRC had given full and fair review to ACE comments, NRC could not conclude Limerick’s health impacts were “small”.         
    • ACE provided NRC with documented PA Cancer Registry and CDC data showing that after Limerick started operating in 1985, that cancer in communities near Limerick skyrocketed far higher than the national average, especially in children.  ACE also provided  NRC with researched  links between elevated cancer rates and Limerick Nuclear Plant’s routine radiation releases..
    • ACE provided NRC with a 2003 EPA report based on state data showing highly elevated infant  and neonatal mortality rates, malignant tumors, cerebrovascular disease, and lower respiratory disease, all far higher than the state average and even higher than Philadelphia and Reading.
    • ACE provided  NRC with lists of toxics that can cause the health harms above.  Those toxics have been continuously released into our air and water from Limerick since Limerick started operating in 1985.
    • NRC did NO INDEPENDENT TESTING to prove Limerick’s massive air pollution and water contamination or its routine radiation releases were not the major factor in the highly elevated illnesses and other health harms in communities near Limerick.
    • Our cancer crisis, with numbers far higher than the national average after Limerick started operating, suggests those impacts should not be considered “small”.

 

NRC’S REGULATORY NEGLIGENCE AND MALPRACTICE IN PREPARING LIMERICK’S DRAFT EIS CAN JEOPARDIZE THE FUTURE OF THE ENTIRE GREATER PHILADELPHIA REGION.

  • ON BEHALF OF PUBLIC HEALTH, ACE ABSOLUTELY REJECTS NRC’S INACCURATE, ILLOGICAL, AND NEGLIGENT CONCLUSIONS IN ITS DRAFT EIS FOR LIMERICK NUCLEAR PLANT.
  • CONCLUSIONS MUST BE CHANGED TO REFLECT DOCUMENTED EVIDENCE IN THIS 6-24-13 ACE TESTIMONY.

 

 

 

 

 

COMPARISONS OF ENVIRONMENTAL IMPACTS OF ALTERNATIVES

NRC’S CONCLUSIONS ARE LUDICROUS AND INDEFENSIBLE

IN NRC’s DRAFT EIS FOR LIMERICK NUCLEAR PLANT

 

NRC LOOKS FOOLISH MAKING THE INDEFENSIVLE STATEMENT THAT SOLAR POWER HAS THE SAME ENVIRONMENTAL IMPACTS AS NUCLEAR POWER!  

 

IT IS INEXPLICABLE THAT NRC FAILED TO CONSIDER SOLAR POWER AS A COMMON SENSE ALTERNATIVE IN LIMERICK’S EIS.

  • NRC failed to consider solar power as an alternative, despite ACE’s 10-26-11 extensive EIS testimony documenting why solar power is a viable alternative to Limerick Nuclear Plant.
  • NRC excluding solar power as an alternative is more evidence that NRC failed to seriously consider or acknowledge ACE’s 10-26-11 public hearing comments.
  • ACE identified large and small business installations, government building installations, schools, and residential solar installations already in the region of Limerick Nuclear Plant, including the Cuthberts’ personal solar power with battery backup.
  • ACE provided a list of news articles proving solar power had become cost competitive with nuclear power and that large back-up power installations were already available to use solar as baseload power.
  • Since 2011, considerable additional evidence has become available showing that solar power is even more feasible from both a technical and economic standpoint.

LIMERICK’S FINAL EIS MUST BE CHANGED TO REFLECT THE REALITY OF SOLAR POWER AS A REASONABLE, FEASIBLE ALTERNATIVE.

 

NRC’s Draft EIS for Limerick Nuclear Plant presented several conclusions that were simply not supported by scientific fact.  Numerous assumptions appear to have been combined with predetermined, pro-nuclear conclusions.  Many of the conclusions rise to the level of colossal incompetence, if not regulatory malpractice.

 

Several specific examples were included in oral and written testimony presented by Dr. Lewis Cuthbert at the NRC public meeting/hearing on May 23, 2013.  One of the most ludicrous conclusions and assertions was that the impacts from continued nuclear operations at Limerick would result in the same impacts as from all other alternatives, all being “small’”.  This unsupportable conclusion must be changed in the Final EIS to accurately reflect the far greater threats, risks, and impacts from nuclear operations.

 

The substantial written testimony submitted by ACE October 26, 2011 focused on solar power as a preferred and viable alternative for our region, rather than a renewed license for Limerick.  Since that time, solar technology has increased, costs have declined dramatically, and installations in the region have proliferated at an ever-increasing pace.

 

Inexplicably, in its Draft EIS for Limerick, NRC totally dismissed solar power as a viable alternative, despite the considerable body of evidence to the contrary provided by ACE in 2011.  Since that time, an even more compelling body of evidence has emerged supporting the viability of solar power as an alternative energy source.

 

The most recent compelling article on the viability of solar power appeared 3-25-13, “NRG Skirts Utilities Taking Solar Panels to U.S. Rooftop” by Christopher Martin, and Naureen S. Malik.

This Article Confirms The Cost Effectiveness and Viability of Solar Panels Alternatives.  This article supports our conclusion that we don’t need Limerick Nuclear Power Plant.  

  • Utilities are aware that generating power at customer sites is leading to them losing their customers and disrupting their businesses.   Solar power is being installed on vast numbers of rooftops, both residential and commercial.
  • Costs for solar panels keep coming down.  Installation costs keep coming down.  Solar is being combined with battery technology and power management systems.
  • Some utilities recognize their business is becoming far less important, eventually being used just for back-up.
  • NRG Energy, the biggest power provider to U.S. utilities is providing electricity directly to consumers.
  • Energy companies are challenging traditional utilities, by providing rooftop solar panels to power individual buildings.
  • At least a dozen U.S. companies provide rooftop panels at no upfront cost to customers, who typically make fixed reduced monthly payments for the output under decades-long contracts, known as solar leases or power-purchase agreements.
  • By-passing its utility clients, NRC is installing solar panels on rooftops of homes and businesses and in the future will offer natural gas-fired generators to customers to kick in when the sun goes down.
  • NRG is running mini-generation systems that run a single building.  This endeavor strikes at the core business of utilities.
  • Companies such as Sunrun and Sungevity offer services at home-improvement stores.
  • CEO of NRG, David Crane said, “Consumers are realizing they don’t need the power industry at all. That is ultimately where big parts of the country go”.
  • Individual home-owners may soon be able to tie a machine to their natural gas line and tie that with solar on the roof, then totally disconnect the line from the transmission-distribution company.
  • Independent power producers may be evaluating the merits of distributed generation, building many small systems at customer sites instead of a few large ones.

 

When viewed in conjunction with wind power, the need for and cost effectiveness of continued electric from Limerick is no longer a logical option.  A glut of low priced natural gas is also contributing to cheaper power prices.

 

In addition to typical rooftop PV solar panels, new technology has dramatically reduced the footprint of installations.  Homes, small businesses, governmental agencies, and large corporations have moved to solar power in increasing numbers.  Rooftop leasing and thinner, lighter panels have redefined the cost and space constraints that NRC referenced in its flawed Draft EIS.  Today, any home or business in our region can consider viable solar power with no up-front costs to the owner.

 

NRC’s Final EIS for Limerick Nuclear Plant must be changed to include all of this evidence, and accurately reflect the reality of solar power as a currently available and safer alternative to Limerick’s electric.  NRC is encouraged to review and consider additional information that has emerged since 2011, and amend the Final EIS for Limerick accordingly.

 

Additional Information About Solar And Wind Power Viability

 

  • Karl Grossman observed, “Today a host of safe, clean, renewable energy technologies are more than ready.  Combined, importantly, with energy efficiency, they render nuclear power as unnecessary.” (3/29/11)
  • Jeff Immelt, GE CEO stated, “Nuclear power is so expensive compared with other forms of energy that it has become really hard to justify.  It’s really a gas and wind world today.” (7/31/12)
  • Christopher Crane, Exelon CEO said, “The rapid pace of subsidized wind-generated electric power could ultimately force Exelon to shutter nuclear plants.” (2/7/13)
  • Reported in Solar Daily, For the first time, solar energy accounted for all new utility electricity generation capacity added to the U.S. grid, according to the Federal Energy Regulatory Commission’s FERC March 2013 Energy Infrastructure Update (more than 44 Megawatts).  Many analysts predict solar will be the largest source of new U.S. energy over the next four years. (4/16/13)
  • Alice Slater said in a presentation, “We mustn’t buy into the propaganda that clean safe energy is decades away or too costly…arguments made by companies in the business of producing dirty fuel.” (6/9/13)

 

NRC DESERVES A GRADE OF “F” FOR ITS ABSOUTELY DISHONEST EVALUATION OF ENVIRONMENTAL IMPACTS.

 

  • WHAT OTHER ENERGY COULD RENDER THE ENTIRE GREATER PHILADELPHIA REGION UNINHABITABLE FOR GENERATIONS?  NRC LOOKS RIDICULOUS CLAIMING THE ENVIRONMENTAL HARMS FROM LIMERICK ARE “SMALL”, AND THE SAME AS OTHER ENERGIES.

 

  • EVEN WITHOUT A RADIATION ACCIDENT OR MELTDOWN, IN TOTAL, LIMERICK’S THEATS AND HARMS TO THE ENVIRONMENT ARE CLEARLY FAR WORSE THAN ANY OTHER ENERGY.  JUST TWO EXAMPLES – WASTE AND WATER – REFUTE NRC’S ABSURD COMPARISONS.

 

HIGH-LEVEL RADIOACTIVE WASTES – No other energy alternative produces massive amounts of high-level radioactive wastes for which there is no safe solution and a million year EPA health standard for its waste dump.  Limerick’s radioactive wastes will remain deadly and threaten our environment virtually forever. 

  1. A.     Fuel pools holding massive amounts of Limerick’s deadly radioactive wastes are a far worse threat to the environment than the waste from any other energy. Limerick’s fuel pools are corroding and thinning at far faster rates than expected after only 28 years.

­    With loss of cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire, causing tens of thousands of deaths up to 500 miles away, according to a 2000 NRC study.

­    A meltdown in a spent fuel pool could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site.

­    A 2004 Study by Dr. Edwin Lyman, Senior Scientist at the Union of Concerned Scientists, Concluded:

ü  As many as 44,000 near-term deaths from acute radiation poisoning.

ü  518,000 long term deaths from cancer.

ü  Deaths could occur among people living as far as 60 miles downwind.

­    A 2003 study by Dr. Frank Von Hippel, Director of Science and Global Security at Princeton University, concluded that:

ü  A successful terrorist attack on a spent fuel storage pool could have consequences “significantly worse than Chernobyl.”

ü  A catastrophic spent fuel fire could release a radiation plume that could contaminate 8 to 70 times more land than  Chernobyl.  (Would include the entire Philadelphia Metropolitan Region).

­    A January 2003 study by Dr. Gordon Thompson, Director of the Institute for Resource and Security Studies (entitled “Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security”) reviewed ways spent fuel pools are vulnerable to attack.

ü  A nuclear fire in one spent fuel pool would  “render about 95,000 square kilometers of land uninhabitable,” (would cover about 75% of New York State, and into segments of NJ and CT.)

  1. B.     Containers holding some of Limerick’s spent fuel above ground are only guaranteed to last 50 years when there can be significant radioactive threats to the environment from leaking.

 

WATER THREATS AND HARMS ARE UNPRECEDENTED

  1. A.     Limerick is slowly destroying the Schuylkill River, a vital drinking water source for almost two million people.  For 28 years Limerick has routinely and accidently poisoned the river with many types of radionuclides, some with long half-lives.  That radiation is in the water, sediment, fish, and it travels into people’s homes from water treatment plants that do not filter it out.   Highly toxic and corrosive chemicals are routinely discharged into the river from Limerick’s cooling towers.  The insatiable water needs of Limerick’s cooling towers are depleting the Schuylkill River to such a degree that contaminated unfiltered mine water is massively being pumped into the river.  From 1985 to 1999, the river reached record low flows.  In the case of a meltdown, Limerick can take everyone’s water, threatening the water supply across six PA counties.
  2. B.     Limerick’s leaks and spills over decades have made the groundwater radioactive.  15 of 15 beta radiation emitters were documented in the groundwater, along with alpha and gamma radiation emitters, and uranium.  The radiation has never been cleaned up from the water or soil and there is no independent testing of the many residential wells very close to Limerick.   In the case of a meltdown, Limerick could draw water from four wells on site and dry up vast numbers of wells.

 

ACE CONCLUSION:  THERE IS NO NEED TO RELICENSE LIMERICK NUCLEAR PLANT

 

WE DON’T NEED LIMERICK’S ELECTRIC.

  • OUR REGION SHOULD NOT CONTINUE TO BE SUBJECTED TO LIMERICK’S UNPRECEDENTED UNACCEPABLE THREATS AND HARMS TO OUR ENVIRONMENT AND PUBLIC HEALTH.   

 

THERE IS NO NEED TO RELICENSE LIMERICK

  • LIMERICK ONLY PRODUCES ½ OF 1 % OF THE NATION’S ENERGY.  

 

HARMS VS. BENEFITS OF LIMERICK NUCLEAR PLANT

  • WE GET THE HARMS, WHILE OTHERS GET THE BENEFITS
    • Exelon profits
    • Limerick’s electric goes to the grid to be distributed across several states, while millions of people in the Greater Philadelphia Region are forced to live with radiation and other toxic releases into our air, water, soil, food, and our children.
    • Our drinking water supply is threatened.
    • We are subjected to the extraordinary threats from a dangerous defacto high-level radioactive waste dump in our backyards.
    • We are forced to live with the constant threat of catastrophic multiple meltdowns, from which it would be impossible to safely evacuate.

 

FINANCIAL INJUSTICE OF LIMERICK NUCLEAR PLANT

  • Ratepayers in our region were forced to pay the lion’s share of Limerick’s $6.8 BILLION every month in our electric bills from 1985 to 2010.
  • Ratepayers are paying each month in their electric bills for Limerick’s decommissioning even though Exelon is trying to relicense Limerick.
  • Taxpayers have been forced to pick up the burden for Limerick’s owners failing to pay their fair share of taxes.  From 1985 to 2002, no property taxes were paid on the 400 to 600 acres of the Limerick site.  In 2002, a judge ordered Exelon to pay just $3 million per year, when it should have paid $17 million.
  • Taxpayers hold the lion’s share of liability for what could be a trillion dollar disaster at Limerick.  Exelon would only pay the first $12 Billion of the Trillion.
  • Taxpayers will be paying to store Limerick’s deadly radioactive wastes forever.

 

NUCLEAR POWER HAS HAD AN UNFAIR TAXPAYER SUBSIDIES ADVANTAGE SINCE 1943.

  • Taxpayers Subsidies for Energy from 1943 to 1999 totaled $151 Billion In 1999 dollars.
  • 97.7% went to nuclear, while only 3,3% went to wind and solar
  • Now Exelon has the nerve to whine about wind power getting subsidies.

THERE IS A CLEAR AND UNDENIABLE TREMENDOUS IMBALANCE BETWEEN THE IMPACTS OF LICENSE RENEWAL AND THE IMPACTS OF ALTERNATIVES.

  • TO PROTECT THE ENVIRONMENT AND PUBLIC HEALTH, NRC NEEDS TO STOP LYING ABOUT LIMERICK NUCLEAR PLANT’S DIRTY, DANGEROUS, AND COSTLY ELECTRIC IN ITS FINAL EIS FOR LIMERICK.

In the Draft EIS for Limerick Nuclear Plant NRC has shamelessly failed to acknowledge the truth about nuclear power.  It is not safe, clean, or cheap.  There are far safer, cleaner, less dangerous, and cheaper ways to generate electricity.  In the region around Limerick solar power and natural gas can easily replace Limerick’s electric long before Limerick’s license expires.  Other renewable-sustainable energies like wind are also viable options.

 

ACE DID OUR OWN COMPARISON OF SOLAR, WIND, AND NUCLEAR BELOW:

NRC FAILED TO INCLUDE THESE COMPARISONS IN LIMERICK’S EIS.    

  1. 1.      Costs of solar and wind (relatively quick to install) will continue to plummet, while costs for nuclear power will continue to rise. Independent estimates suggest, adding in hidden costs to taxpayers and ratepayers, nuclear plants produce the most costly form of energy. 
  2. Clean, safe energies like solar and wind, along with energy efficiency, are estimated to provide more jobs per dollar spent than nuclear power.
  3. Producing solar and wind energies closer to where they are needed, provides more energy security, removing the necessity for huge grids that can be attacked by terrorists.
  4. The Department of Energy 2006 report stated solar power and wind power could provide far more energy than our nation needs – That solar alone could provide 55 times our entire nation’s energy needs.
  5. Costly security is not needed for solar or wind energy installations.
  • Terrorists are not interested in attacking solar or wind installations.
  • Attacks at solar or wind energy installations would not result in astronomical costs or cause long-term devastation.
  • Nuclear plants can be turned into nuclear bombs, resulting in tens of thousands of deaths and hundreds of billions of dollars in damages from spreading radioactive contamination across vast areas which create dead zones for centuries.
  1. Human error or mechanical failure of solar and wind technologies won’t result in devastation like they can at nuclear plants.
  2. Solar and wind would clearly be a far safer and less costly investment for taxpayers and ratepayers.
  3. Solar and wind don’t create dangerous high-level radioactive waste storage problems, with costs to taxpayers beyond meaningful calculation.
  • Reprocessing is not the solution to high-level radioactive waste problems.  Evidence shows reprocessing makes waste problems worse. Reprocessing is costly, ill-conceived, dangerous and environmentally damaging.  Vitrification is also costly and has not been proven safe.
  1. Nuclear plants are not emissions-free.
  • Solar and wind energies don’t routinely release radiation in to our air and water that is harmful to health.  Radiation exposure can alter DNA, cause cancer, and shorten life-expectancy.
  • Limerick Nuclear Plant Title V air pollution permit proves it is a major polluter under the Clean Air Act. There are 32 air pollution sources on site releasing a broad range of air pollutants, including greenhouse gases.
  • From uranium mining to waste storage, nuclear power emits greenhouse gases.
  1. Solar and wind energies don’t present unprecedented threats and harms to the public water supplies such as those from Limerick Nuclear Plant.
  2. Solar and wind are more dependable in heat and drought when you need power most.   Nuclear reactors require enormous quantities of water to operate.  If water sources diminish significantly or become too hot, due to droughts and heat waves (expected to increase under global warming), reactors cannot operate safely.

 

NRC SAYS IT DECIDED TO EXERCISE ITS NEPA AUTHORITY TO REJECT LICENSE RENEWAL APPLICATIONS ONLY IN CASES WHERE THERE IS SUCH AN IMBALANCE BETWEEN THE IMPACTS OF LICENSE RENEWAL AND THE IMPACTS OF THE ALTERNATIVE THAT IT WOULD BE UNREASONABLE TO ALLOW FURTHER CONSIDERATION OF LICENSE RENEWAL.

  • ACE BELIEVES THE INFORMATION WE PROVIDED ABOVE CLEARLY SHOWS IT WOULD BE UNREASONABLE TO ALLOW FURTHER CONSIDERATION OF LIMERICK NUCLEAR PLANT LICENSE RENEWAL.

 

ACE COMMENTS TO NRC 6-24-13 – ON LIMERICK NUCLEAR PLANT’S DRAFT EIS

SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA)

 

NRC COMMENTS AND CONCLUSIONS IN THIS SECTION ARE PROFOUNDLY ALARMING.

 

NRC devalued every person, all their possessions, and life-support systems in the Greater Philadelphia Region to save Exelon the cost of implementing the most protective safety planning and measures.

 

NRC’s cost-benefit analysis concludes the cost for risk reduction to the population and its life-support systems is not worth the cost to Exelon for severe accident mitigation design alternatives.

 

SAMA assesses environmental, economic, and other consequences.  It’s about human health, economic, and environmental impacts of a nuclear plant.  Limerick’s SAMA is decades out-of-date.

  • STILL, NRC WANTS TO EXEMPT LIMERICK

 

Exelon and NRC want to exempt Limerick, as one of three nuclear plants that never again have to consider an updated Severe Accident Mitigation Analysis in connection with new and significant environmental information under NEPA in relicensing.

  • This is a grotesque dereliction of responsibility.

 

The National Resource Defense Council (NRDC) Filed A Legal Appeal and won in the 3rd Circuit Court of Appeals in Philadelphia, Against Exelon’s Attempt To Circumvent A Safety Analysis Requirement for Limerick Nuclear Plant’s Outdated, Unacceptable Accident Mitigation Analysis.

  • The judge agreed with NRDC’s conclusion that ignoring the population growth around Limerick is unacceptable if an emergency evacuation at Limerick becomes necessary.
  • Common sense planning is needed stating that what was acceptable in 1989 is not good enough now and in the future. 
  • Limerick’s Severe Accident Mitigation analysis was last completed in 1989, relying on the census for 1980 population. 

 

Even after Fukushima, involving boiling water reactors similar to Limerick’s, and drastically increased populations that would clearly be impacted by a Fukushima-type disaster at Limerick, NRC illogically joined Exelon in an appeal against a federal court decision, in order to avoid an updated safety analysis for Limerick.  The federal court decision stated that Limerick can’t be exempted.

  • In this appeal NRC didn’t even pretend to be a neutral arbitrator.  This is totally shameful and unacceptable.

 

Limerick is the 2nd most densely populated nuclear plant in the nation.   Still, NRC is refusing to consider increased population and health risks associated with a Limerick Nuclear Plant accident/meltdown.

  • Due to Limerick’s location, the potential impact of a severe accident would be far greater than at most other U.S. nuclear plants (NRDC research). 
  • Over 8 million people live within 50 miles of Limerick, the radius NRC told Americans to evacuate in Japan during the Fukushima accident.  
  • 1.4 million people are now living downwind in the Philadelphia-Wilmington-Newark metropolitan area.
  • In 1980 Limerick already had double the population density within 30 miles than could evacuate safely (NRC standard).  Now the population density is four times higher.

 

EVACUATION AND EMERGENCY PLANS

ARE INADEQUATE AND FATALLY FLAWED.

 

NRC INEXPLICABLY PARED DOWN EMERGENCY PLANNING AFTER FUKUSHIMA.  NRC’S ACTIONS ARE INDEFENSIBLE.  AFTER FUKUSHIMA,  NRC MADE IT WORSE, NOT BETTER

   

NRC weakened regulations and requirements, including for emergencies and evacuation.

  • NRC overhauled community emergency planning for the first time in more than three decades, however NRC pared down emergency rules and evacuation plans, further jeopardizing the public.  NRC’s new rules after Fukushima make no sense.
  • Many emergency responders view NRC’s new rules as downright bizarre.

1)     NRC Allowed Emergency Drills To Be Run Without Practicing for Radiation

2)     NRC Requires FEWER Exercises for Major Radiation Accidents

3)     NRC Recommends FEWER People Evacuate Right Away

  • Instead Of Attempting To Minimize Chaos And Reduce Radiation Exposure Through Better Emergency Planning and Drills For A Radioactive Accident / Meltdown:

1)     NRC Deceived The Public and Weakened Emergency Rules

2)     NRC Denied Radiation Risks and Harms

3)     Despite Evidence from Fukushima, NRC Failed To Expand Emergency Zones

4)     NRC Has Denied Repeated Requests To Expand Evacuation Zones to 50 Miles, and Ingestion Pathway Zones to 100 Miles.  This Would Better Protect Public Health, Safety, and Financial Interests For Vast Numbers Of People

 

NRC IS ABDICATING ITS RESPONSIBILITY TO ENSURE PUBLIC HEALTH AND SAFETY IN THE GREATER PHILADELPHIA REGION, RELATED TO EMERGENCY PLANNING AND EVACUATION

 

NRC’S RESPONSE TO THE IMPOSSIBILITY OF SAFE EVACUATION FROM LIMERICK NUCLEAR PLANT IS TO IGNORE REALITY, REFUSE TO DISCUSS THE FATALLY FLAWED EVACUATION PLAN, AND SHIRK ITS RESPONSIBILITY.

 

NRC is making decisions that could lead to a Limerick radiation accident/meltdown, while at the same time NRC is shirking its responsibility for radiation contamination released off Limerick’s site when a major radiation release or meltdown occurs. 

 

4-16-13, ACE received a response to our repeated requests to meet with NRC’s Review Team to discuss the findings from our analysis of Exelon’s 12-12 Plume Exposure Time Estimate.  This response from Joseph D. Anderson, Chief Operating Reactor Licensing and Outreach Branch, Division of Preparedness and Response was both shocking and negligent.

  • Anderson’s e-mail to ACE revealed  that NRC has no intention of reviewing or evaluating Exelon’s 12/12 updated Evacuation Time Estimate (ETE) for Limerick’s Radioactive Plume Exposure, even though NRC required it to be produced. 

 

  • NRC takes no responsibility for the accuracy or feasibility of Exelon’s Evacuation Plan for Limerick’s Radioactive Plume, even though NRC ordered it to be done. 
  • Exelon is not making commitments for this evacuation report either.  Exelon’s letter accompanying Limerick’s ETE concludes with:  “There are no commitments in this letter”.  That disclaimer speaks volumes.
  • Even though NRC is clearly responsible for radiation exposure associated with nuclear plants, NRC is claiming the responsibility for Limerick’s radioactive plume after an accident/meltdown is not theirs. Anderson’s e-mail revealed NRC is trying to shirk its responsibility for Limerick’s off-site radioactive contamination after a Limerick accident/ meltdown.
  • NRC is also using industry-biased studies to dispute their own earlier studies that show drastic harms after a nuclear plant radiation accident/meltdown.  NRC is ignoring actual human evidence after meltdowns and making false claims to attempt to minimize public concern about radiation risk from nuclear plant accidents/meltdowns.
  • This is an indefensible and unacceptable position, especially when NRC is making decisions which increase risks for a Limerick disaster.
  • In essence, Anderson admitted NRC has no interest in learning about the analysis of Exelon’s report for Limerick, when he failed to set up a meeting with ACE members who did analyze Exelon’s report.

 

ACE’s Analysis Of Exelon’s 12-12 Evacuation Time Estimate (ETE) For Limerick Nuclear Plant’s Plume Exposure Pathway Emergency Planning Reveals It Is Self-Serving Fiction.

  • Exelon’s fatally flawed, unworkable plan is based on unrealistic, unworkable suppositions, assumptions, inconsistencies, and inaccuracies, with fact-free spin and illogical conclusions.

For More Information See www.acereport.org   ACE Video-Blog Series 1 to 8

Also Download # 16  “Evacuation Plan Is Fatally Flawed

 

1980 public hearing testimony on Limerick evacuation proves NRC knew then that within a 30 mile radius, Limerick had double the population density than could evacuation safely.

  • Population density has now skyrocketed to four times the number NRC considered safe to evacuate in 1980.
  • Philadelphia is only about 21 miles downwind, downstream from Limerick.
  • Limerick is the 2nd most densely populated nuclear plant in the nation.
  • Traffic gridlock is already horrific even in work-hour traffic.  Attempted evacuation from Limerick’s radioactive plume would be chaos, keeping far too many people exposed far too long to dangerous radiation releases from Limerick.

 

NRC received written comments in 2011 from the Montgomery County Planning Commission and the Montgomery County Department of Public Safety, expressing major concerns about evacuation related to Limerick Nuclear Plant.

  • NRC’s EIS failed to address MCPC and Health Director Comments.  That is an unsupportable position.  A radiation accident/meltdown would have devastating impacts on the environment for generations to come.  It must be addressed in Limerick’s EIS.
  • NRC received written comments for Limerick’s 2011 EIS public hearing from the Montgomery County Department of Public Safety, expressing serious concerns about evacuation and Limerick Nuclear Plant.   Montgomery County Safety Director, Thomas Sullivan:

­   Asked for, “a full review of environmental and public safety issues pertaining to the plant.”   In fact, NRC made no attempt to review public safety issues related to post Fukushima planning for a Limerick emergency and NRC’s environmental review is a shameful whitewash.

­    Recommended that Exelon be included as a source of funding for pending roadway infrastructure improvement projects.  ACE concurs that these improvements could to some degree help with safer evacuation plans.  However, NRC failed to include this recommendation in its EIS.

­   Informed NRC that the local, county, and state roads necessary for evacuation are no longer suitable for the amount of traffic that an EPZ evacuation could produce.

­   Expressed concern over delays in patient care for potentially life threatening illnesses.  ACE is also concerned.  NRC failed to address this issue in the EIS.

NRC’s Earlier Estimated Meltdown Consequences

REFUTE

NRC’s New Attempts To Deny Harm From Meltdowns

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 (CRAC REPORT)

For Limerick Nuclear Power Plant  – Reported To Congress In 1982

    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.

Our Population Increase Demands Updated, More Realistic Planning

Census Shows – From 1980 to 2010 (2000 and 2010 Census Data)

Numbers For Fatalities, Injuries, and Deaths Above Would Be Drastically Higher Today Due To A:  FOUR-FOLD INCREASE IN POPULATION DENSITY SINCE 1980

 

LIMERICK’S 10-MILE EPZ Is The 2ND MOST DENSELY POPULATED In The U.S.

 

  1. INFORMATION ABOVE RENDERS NRC’S CLAIMS IN LIMERICK’S DRAFT EIS – SAMA PAGE 5-3 – MISLEADING, AND INDEFENSIBLE

  

It appears NRC will say anything to fool the public to save Exelon money.

  • “Risks of early fatality from potential accidents at the site are small in comparison with risks of early fatality from other human activities in a comparably sized population.”
  • “The accident risk will not add significantly to population exposure and cancer risks.”
  • “Accident risks from Limerick are expected to be a small fraction of risks the general public incurs from other sources.”  THIS IS ABSURD!
  • “Best estimates show risks of …reactor accidents at Limerick are within the range of risks from other nuclear plants.” – THIS IS A MEANINGLESS COMPARISON.

Shame on NRC!  This agency has lost all credibility! 

  • Ø A Limerick Accident/Meltdown Could Cause A Catastrophe That Could Render The Entire Greater Philadelphia Region A Dead Zone For Generations.
  • Ø A Limerick Accident/Meltdown Is About High-Levels Of Radiation Exposure That We Can’t See, Taste, Smell, Or Feel, But That Cause Radiation Sickness,  Cancer, Death, And Impacts Into Future Generations.

Exelon should not be using decades-old 1989 information to determine health and economic impacts   It is inexcusable for NRC to allow Exelon to use decades old comparisons for anything, especially population.  NRC is letting Exelon get away with declaring its review of new and significant information compared to 1989, claiming Exelon did not uncover any cost beneficial plant improvements or SAMAs that would substantially decrease risk of a severe accident.  That doesn’t even make sense considering NRC’s own post-Fukushima recommendations.  Cost beneficial to whom?  Certainly NOT public interests!

 

  • Exelon’s evaluations and claims are based strictly on their costs.  That leads to decisions ignoring unacceptable risks to the public.

 

  • NRC’s job is to ensure public safety, not protect Exelon’s profits.

 

  • NRC is supposed to protect the public’s interests.  NRC has failed to consider and compare impacts and costs to the public for Exelon not being required to spend the money for the safest accident mitigation.

 

Costs to the public for an accident/meltdown at Limerick Nuclear Plant could be astronomical, in terms of suffering, health care costs, and financial costs.

 

  • Off-site economic costs for multiple radiation accidents/meltdowns in Limerick’s reactors and/or fuel pools, in the densely populated Greater Philadelphia region surrounding Limerick Nuclear Plant have not been accurately assessed by anyone.

 

  • Millions of people would need temporary housing and/or permanent relocation.  In today’s economy and political dysfunction, the millions of people in the Greater Philadelphia Region who could lose everything would get no help.

 

  • Costs for dealing with a Limerick disaster are estimated to be a trillion dollars, with taxpayers paying all but $12 billion.

 

  • In addition to complete loss of property, possessions, businesses, and jobs, the short and long term health-care costs would be staggering.  There would not even be enough treatment centers or hospitals to deal with the numbers of people who could end up with acute radiation poisoning or worse.  In Japan, people, including children, were turned away because they were too radioactive.

 

  • NRC never bothered to address any of the public interest issues above in Limerick’s DRAFT EIS.   NRC is only considering costs to Exelon and Exelon’s profits, NOT costs to the public for a Limerick accident/meltdown because NRC failed to require the safest accident mitigation strategies.  That is profoundly negligent!

 

IF NRC CONSIDERED DRASTIC INCREASES IN POPULATION, RELATED TO THE COSTS FOR LOSSES, NRC SHOULD COME TO THE CONCLUSION THAT IT IS JUST TOO RISKY TO CONTINUE TO OPERATE LIMERICK NUCLEAR PLANT.

 

  • In NRC’s FINAL LIMERICK EIS, THE PUBLIC’S OFF-SITE COSTS FOR A LIMERICK RADIATION ACCIDENT/MELTDOWN MUST BE ACCURATELY ESTIMATED BY AN INDEPENDENT ECONOMIC EXPERT WHO UNDERSTANDS WHAT TOTAL RADIOACTIVE CONTAMINTION WOULD DO TO THE ENVIRONMENT AND THE POPULATION.
    • 2010 census data for 50 miles (not 10) must be used and fully considered by a completely independent expert. The public’s costs and interests must be the priority of NRC, not Exelon profits.

 

  • EXELON’S COSTS FOR ALL THE SAFEST MITIGATION ACTIONS WOULD CLEARLY  PALE BY COMPARISON TO THE COSTS FOR FAILING TO PREVENT A LIMERICK ACCIDENT/MELTDOWN, ESPECIALLY CONSIDERING THE DRASTIC INCREASE IN THE DENSITY OF POPULATION AROUND LIMERICK NUCLEAR PLANT.

 

A BODY OF EVIDENCE BELOW SHOWS THAT NRC IS MAKING DECISIONS THAT FAIL IN NRC’S MISSION TO PROTECT THE PUBLIC!

  • Dangerous delays and the opportunity for Exelon to avoid costs for important safety measures at Limerick Nuclear Plant have been allowed by NRC.
  • When NRC knows about problems, whether with fire protection, increased seismic risk, or corrosion and thinning in fuel pool liners, allowing Exelon to choose to delay or avoid mitigation and safeguards for years or forever, amounts to regulatory negligence and even malpractice.
  • NRC’s Decisions and Irresponsible Conclusions in Limerick’s DRAFT EIS are Contributing to Unnecessary Risk for Disastrous Radiation Accidents/Meltdowns and Their Inevitable Catastrophic Impacts.

 

POST-FUKUSHIMA NEGLIGENCE AT LIMERICK

NRC IS ALLOWING DANGEROUS DELAYS FOR IMPORTANT SAFEGUARDS RECOMMENDED BY NRC’S OWN POST-FUKUSHIMA TASK FORCE.

NRC allowed Exelon to DELAY important post-Fukushima safeguards recommended by their own staff, even though Limerick is considered a high-risk nuclear plant with GE Mark II boiling water reactors similar to those at Fukushima.

NRC Is Ignoring Its Own Orders, Based On Fukushima Task Force Recommendations Issued July, 2011.

MARCH, 2012 – NRC officially issued three orders to U.S. nuclear power plants:

  1. Plants must develop and implement measures to keep spent fuel rods cool after an extreme natural disaster.
  2. Sturdier venting systems are required to help prevent pressure-induced explosions.
  3. They must have a reliable read of water levels in spent fuel containers.

MARCH 13, 2012   NRC Issued Order to Modify Licensees Requirements for Mitigation Strategies for Beyond-Design-Basis External Events NRC 3-12-12 Letter   (E-mail notice 3-13-12).

NRC’s Order Requires a 3-phase Approach For Mitigating Beyond-Design-Basis External Events.

  1. Initial phase – Requires use of installed equipment and resources to maintain or restore core cooling, containment, and SFP cooling.
  2. Transition phase – Requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site.
  3. Final phase – Requires obtaining sufficient offsite resources to sustain those functions INDEFINITELY.
  • It is not clear any of these orders have been, or will be, required by NRC to be completed prior to relicensing of Limerick Nuclear Plant.  It is important to remember that Fukushima was relicensed just a short time prior to the catastrophe.  What was clear was the collusion between the owner and the regulator.
  • It is not clear any safety measure will be completed before 2017, six years after the Fukushima disaster.
  • NRC failed to provide answers to specific questions about several of these issues even after repeated requests by ACE.
  • Given Exelon’s track record of avoiding costs for precaution, Limerick should not be relicensed, at least until AFTER all the post-Fukushima recommendations are fully completed and operational to protect public interests.

NRC IS ALLOWING EXELON TO DELAY EARTHQUAKE RISK (SEISMIC HAZARD) UPGRADES FOR OVER FOUR YEARS, UNTIL 2017, EVEN THOUGH LIMERICK IS AT HIGH-RISK FOR EARTHQUAKE DAMAGE.

Delays In Seismic Hazard Upgrades Are Not Required For Over Four Years, Until After 2017

  • Ex-NRC Chairman Jaczko said  “…we recognize there is new information that tells us plants may not be designed to the right seismic standards.to be taking so long is a bit of a concern to me”Earliest completion date for key seismic upgrades at U.S. nuclear power plants is  2017, even for high risk plants.
  • Even after an earthquake triggered the worst nuclear disaster in history, NRC allowed Exelon to delay meaningful seismic upgrades at Limerick until after 2017, even though Limerick Nuclear Plant is considered a very high-risk nuclear plant, and new information indicates a much higher probability of core damage caused by an earthquake than previously believed.
  • An investigation shows some Limerick systems, structures, and components could be unreliable in an earthquake.
  • Fire and flood prevention seals may not tolerate a “seismic event” at Limerick.
  • There is an earthquake fault directly under the Limerick Nuclear Plant site.  Five earthquake faults are  within 17 miles of Limerick.
  • The August 2011 earthquake in VA jolted Limerick.  Limerick was cited for a violation, for which NRC has not disclosed the details. The VA earthquake exceeded nuclear plant design basis.  Others near Limerick could too.  It is important to consider what would happen if there was an earthquake close to Limerick.
  • Of greatest concern:  Potential disruption in the miles of Limerick’s underground pipes and cables critical for delivering cooling water and power to avoid meltdowns.
  • NRC admits Fracking has caused earthquakes in five states, yet refuses to take responsibility for earthquake risk in PA from 3,000 natural gas wells, and permits for 2,000 more to be issued this year.
  • Instead of requiring meaningful upgrades, NRC allowed Exelon to have until 2017 to even produce a self-serving seismic hazard evaluation. NRC is using a nuclear industry biased new seismic source model instead of reliable updated USGS data.
  • USGS has warned that drilling/fracking can cause seismic activity/earthquakes, whose severity and frequency will only become obvious once fracking is more established.
  • NRC has failed to identify specific “geologic experts” used for the industry biased seismic study.
  • Exelon will be allowed to use a new seismic source model (NUREG 2115) developed jointly by industry and the NRC.  This new seismic source model was developed without input from many independent geologic experts or USGS studies considered  relevant geologic studies in the central and eastern United States.
  • Congressman Markey’s “Fukushima Fallout”  May 2011 Seismic Issues Report shows:

ü  NRC failed to factor modern geologic information into seismic safety requirements for nuclear plants.

ü  NRC has not incorporated its technical staff’s recommendation to do this even though new information indicates a much higher probability of core damage caused by an earthquake than previously believed.

ü  NRC has continued to process applications for license extensions at nuclear plants [including Limerick] in a major metropolitan area, even in the absence of upgraded seismic safety requirements.

For more information see www.acereport.org – Download #11 “Earthquake Risks”

 

PROFOUNDLY ALARMING NRC DECISIONS ON VENTS AND FILTERS

In a Limerick radiation accident / meltdown high radiation levels would poison us, our life-support systems, and everything we own.  We would become nuclear refugees.

Still, even with greater risk for a radiation accident / meltdown at Limerick Nuclear Plant:

  1. A.     NRC is allowing Exelon until 2017 to install vents to prevent an explosion.
  2. B.     Even worse, if NRC and the nuclear industry lobbyists, NEI, deem filters “cost beneficial” the very earliest operable system would be 2021, eight years from now.
  • NRC STAFF CONCLUDED, FILTERS ARE VITAL AT NUCLEAR PLANTS LIKE LIMERICK”
  • NRC STAFF SAID, “WITHOUT FILTERS, VENTS COULD BECOME A RADIOACTIVE FIRE HOSE INTO THE SKY.
  • NRC STAFF CONCLUDED, THE CONSEQUENCES OF NO-FILTER VENTS COULD BE SO BAD, FILTERS SHOULD BE REQUIRED, REGARDLESS OF COST TO THE NUCLEAR INDUSTRY.”

NRC COMMISSIONERS ARE SIDING WITH NUCLEAR INDUSTRY LOBBYISTS TO DELAY AND/OR AVOID COSTS FOR SAFETY MITIGATION MEASURES, INSTEAD OF REQUIRING SAFETY UPGRADES RECOMMENDED BY NRC’S OWN STAFF.

  •  NRC’S POST-FUKUSHIMA FILTERED VENT RECOMMENDATIONS BEING DELAYED AND/OR IGNORED SHOW WHY WE CAN’T DEPEND ON NRC OVERSIGHT TO PREVENT OR MINIMIZE A LIMERICK DISASTER.
  • THIS IS A SERIOUS THREAT TO THE ENTIRE PHILADELPHIA REGION.
    • Limerick’s reactors are similar to those at Fukushima that lost power, melted down and exploded.
    • NRC staff concluded that filters for vents are vital at nuclear plants like Limerick. NRC staff concluded the consequences for no-filter vents could be so bad, filters should be required, regardless of cost to the nuclear industry.
    • With filters, some of the radiation could be captured.  Still NRC failed to require Exelon to install vents at Limerick Nuclear Plant.  NRC considers the cost to Exelon rather than extraordinary risk to our future.
    • Exelon is willing to install vents to save Limerick reactors, but is unwilling to spend the money to install radiation filters to minimize harmful impacts from Limerick’s radiation releases on us and our life-support systems.

 

LIMERICK’S TWO MARK II GE BOILING WATER REACTORS, SIMILAR TO THOSE THAT EXPLODED AT FUKUSHIMA, ARE IN VIOLATION OF LICENSE CONDITIONS FOR SAFE OPERATION AND RELIABLE CONTAINMENT. 

  • STILL, NRC IS ALLOWING LIMERICK TO CONTINUE OPERATING WITHOUT BEING IN COMPLIANCE WITH SAFE OPERATION AND RELIABLE CONTAINMENT. 
  • Limerick’s design, construction, and operation are highly unreliable under certain now to be anticipated accident conditions.
  • Yet, NRC voted 3-19-13 to delay regulatory action to reasonably restore containment integrity and install high-capacity radiation filters in upgraded severe accident capable vents.
  • Failure to require the filtration system in vents deliberately defeats the license condition for maintaining public health and safety against the uncontrolled release of radioactivity to the environment associated with reactor core fuel damage.
  • This constitutes a violation of Limerick’s license.   Limerick’s operating license should be revoked.
  • NRC’s response to ACE May 5, 2013 revealed there are two outstanding petitions against Limerick’s violation of license conditions for safe operation and reliable containment.

For more information see www.acereport.org – Download # 8

“Limerick’s Design Flaws, Deterioration, Corrosion”

BACK-UP POWER TO PREVENT MELTDOWNS IN REACTORS AND FUEL POOLS AT LIMERICK IS STILL WOEFULLY INADEQUATE, EVEN AFTER FUKUSHIMA. 

It Appears NRC Will EXEMPT Limerick From NRC’s Post-Fukushima, Still To Be Revised, Station Blackout Rule.  Back-Up Power To Prevent Meltdowns At Limerick Is Clearly Still Woefully Inadequate.

  • The Fukushima disaster proves there could be four simultaneous meltdowns at Limerick and that a constant energy supply is vital for cooling water and other operations to prevent meltdowns.
  • In 2013, two years after Fukushima, NRC has still not required Exelon to have indefinite back-up power to prevent potential meltdowns in Limerick’s two reactors and two fuel pools.
  • New NRC rules say there must be indefinite back-up power, yet it does not appear that indefinite back-up power is available at Limerick.
  • NRC’s new “station blackout” rules do not apply to plants licensed to operate prior to July 21, 1988, which includes Limerick, according to NRC’s website, Last Reviewed/Updated, Friday, March 01, 2013,
  • In 2011, Ex-NRC chairman Jaczko said,  “ I’m not convinced four hours is reasonable to restore off-site power”.
  • Despite repeated requests, NRC has provided no evidence that Limerick has more than four hours of back-up power for each reactor.  It appears there is NO designated back-up power for fuel pools.

 

FIRE CAN LEAD TO A MELTDOWN AT LIMERICK.   SAFETY IS DEFINED BY COMPLIANCE WITH THE REGULATIONS. 

  • YET NRC ALLOWS LIMERICK TO FOLLOW WEAKENED FIRE SAFETY RULES.  
  • NRC ALSO FAILS TO REQUIRE IMMEDIATE ENFORCEMENT FOR FIRE SAFETY VIOLATIONS AT LIMERICK. 
  • In a 7-13-10 response to ACE about Limerick fire safety rules, NRC admitted they have two sets of rules to determine fire safety and that Limerick is one of the plants refusing to adopt the more protective NFPA 805 “Performance-Based Standard for Fire Protection”.
  • NRC is literally playing with fire, allowing Limerick to follow unprotective industry designed policies on fire safety that set up scenarios at Limerick for disastrous consequences.  IN 2008, the GAO faulted nukes over fire safety.
  • While less stringent fire safety regulations increase risks at Limerick, they accommodate industry demands.  NRC allows Limerick to follow fire safety policies that protect nuclear industry profits over public safety.
  • NRC caved in to nuclear industry demands to weaken fire safety regulations to save money and time.
  • Terms used in NRC Fire Safety Fact Sheets reveal how NRC weakened fire rules:

ü  “SAFE ENOUGH”

ü  “Enforcement Discretion”

ü  “Flexibility”

ü  “Reduced Regulatory Burdens”

ü  “Exemptions”

  • NRC fire safety regulations were in place since 1976 and 1980, to assure a fire does not prevent a reactor from safely shutting down.  Three decades after fire safety regulations were established, NRC is still failing to require full compliance at Limerick and other nuclear plants.
  • 125 fires were reported at 54 plants since 1995 (2008 GAO report).  Limerick had a fire in 1997.
  • Some parts of Limerick might not be reliable to prevent damage from fire if the plant was struck with an earthquake.  (NRC inspection reported in the Mercury June 5, 2011, “NRC Inspection Raises New Issues at Limerick Plant”)
    • ACE confirmed Limerick violations of weakened rules, with lax NRC enforcement in response.  (2007 and 2010)  Some violations went uncorrected for long periods of time.
    • Example: Lax NRC enforcement for 2010 fire safety violations at Limerick.

ü  NRC’S 11-9-10 letter to Exelon acknowledged 2 FIRE Violations, but NRC chose to treat them as Non-Cited Violations, even though NRC determined that these violations were “more than minor”.

ü   7-29-10   – Twice – The latching mechanism failed to function on a required fire door between the reactor enclosure and turbine building.

ü   Exelon failed to address Limerick’s degraded condition and failed to set up a required hourly fire watch.

ü  The door hardware was no longer functional for securing the door in a closed position.

ü  An hourly fire watch was required for the inoperable fire door but Exelon failed to set up a fire watch.

NRC FAILED TO TAKE MEANINGFUL ENFORCEMENT ACTION FOR LIMERICK’S FAILURE TO SWIFTLY ADDRESS FIRE SAFETY VIOLATIONS.

  • Given what is at stake for the Greater Philadelphia Region, there is no acceptable excuse for Exelon to avoid full compliance with the safest fire safety rules at Limerick. 
  • NRC plans to relicense Limerick with no plans to require compliance with the safest fire safety rules.
  • NRC has a legal responsibility to ensure American nuclear reactors are safe, but that is not what is happening with fire safety rules and so many other issues  at Limerick.

For more information see www.acereport.org 

Download #14 “Lax Fire Safety Tempting Fate

 

NRC IS WHITEWASHING LIMERICK VIOLATIONS.   NRC IS ALSO FAILING TO HOLD EXELON ACCOUNTABLE WITH MEANINGFUL ENFORCEMENT FOR VIOLATIONS, MANY CALLED SIGNIFICANT BY NRC STAFF. 

EXAMPLES BELOW IDENTIFY PROBLEMS:

  • NRC Allowed Exelon To Avoid Immediate Replacement Of Flawed Safety Mechanisms, Necessary For Safe Shutdown, Despite Warnings To NRC From GE in 2010 and again in 2011.
  • NRC Staff Identified Serious Performance And Aging Problems At Limerick, Yet Failed To Require Immediate Corrections.
  • Exelon Fails To Notify NRC About Huge Problems and Accidents In A Timely Manner Which Violates NRC Regulations. In Response, NRC Issues Simple Violations Without Penalties.
  • NRC Issues A Violation, Then Accepts Exelon Plans, and Moves On With NO Enforcement.
  • NRC Allows Exelon To Get Away With Changing Procedures Without Notifying NRC About Serious Problems That Have The Potential To Lead To A Meltdown.
  • NRC Issued Relief Requests for Limerick’s Risky Aging Equipment Problems.
  • NRC Is Allowing Exelon To Use Outdated Studies, Models, Criteria, and Projections for License Renewal.
  • NRC Issues Deceptively Benign Color Codes For Violations Of NRC Regulations That Have The Potential To Lead To Catastrophic Events.
  • Green findings, for example sound benign,  but are issued for violations which NRC itself says have more than minor significance and that could lead to far more serious problems.
  • Exelon Fails To Follow Procedures In A Way That Assures Long-Term Plant Safety and Requirements For Immediate Action To Reduce Risks.
  • NRC’s Inspection Reports Are Deliberately Convoluted and Deceptive.  NRC Ignores Concerns From Its Own Staff To Make Inaccurate Conclusions That Most Often Ignore Actual Risky Conditions.
  • NRC Allowed Exelon’s Lobbyists, NEI, To Assert Influence In Amending and Weakening NRC Regulations To Facilitate License Renewal.
  • Details on NRC’s weakened safety rules for relicensing were investigated and reported by the Associated Press four part series, first reported June 20, 2011 – by Jeff Donn, “U.S. nuke regulators weaken safety rules. AP Investigation:  Standards being compromised to keep plants running.”

 

NRC IS FAILING TO REQUIRE EXELON TO REPLACE AGING DETERIORATING EQUIPMENT AND SYSTEMS PRIOR TO RELICENSING AT LIMERICK

  • NRC IS ALLOWING EXELON TO DELAY AND EVEN AVOID TAKING CORRECTIVE ACTION ON DANGEROUS AGING, DETERIORATION, AND CORROSION PROBLEMS IDENTIFIED IN SAFETY REVIEWS FOR RELICENSING BY NRC’S OWN STAFF.

NRC documented that Limerick is experiencing significant corrosion, cracking, pitting, fatigue, fouling, erosion, thinning through loss of material, embrittlement, and leaching of steel and other metals making up bolts, piping, welds, ducts, liners, cladding, external surfaces, and walls. 

  • These serious problems are occurring after only 28 years of operation, yet NRC plans to relicense Limerick in 2014, with a decade remaining before Limerick’s first license expires.
  • However, NRC is whitewashing this evidence from its own safety evaluations reports for relicensing.
  • NRC caved in to Exelon’s self-serving demands to delay corrections and replacement so that Exelon can avoid costs. Some corrective actions have been deferred for over a decade, until 2024 and 2029.
  • Exelon should not be allowed to avoid immediate corrections and replacements related to the broad range of aging problems documented at Limerick Nuclear Plant.
  • Exelon should be required to replace all aging equipment and systems BEFORE relicensing.  If Exelon refuses, NRC should not relicense Limerick.  However, NRC plans to relicense Limerick with very few replacements or costly repairs.
  • Critical cables and wires are also at risk of failure.  They can stop working due to water and condensation. That could produce catastrophic consequences during an accident.  There are miles of buried pipes and cables underground at Limerick.
  •  Some very concerning problems appear inevitable, including internal aging effects of components, recurring internal corrosion on internal surfaces in piping and ducting components, loss of coating integrity, corrosion under insulation, and flow blockage of water-based fire protecting system piping.   Still, in determining whether Limerick can operate safely until 2049, NRC has failed to require replacement of all these cables and wires, some of which already have been exposed to water, condensation, and radioactive impacts for 28 years.
  • NRC’s response to community concerns about their failed regulatory oversight, is not to hold Exelon accountable, but instead for citizens to contact NRC’s own Inspector General, another fox in the hen house operation, in which few have any confidence.

 

EXAMPLE:

CORROSION AND LOSS OF THICKNESS DOCUMENTED IN LIMERICK’S “SPENT FUEL” POOL LINERSCOATING DELAYED FOR A DECADE. 

Identified In NRC’s July 20, 2012  and  October 19, 2012  Letters To Exelon

ü  CORROSION RATE IS FAR HIGHER THAN ORIGINAL CALCULATIONS.

ü  NRC DOCUMENTED CORROSION, CRACKING, PITTING, AND CAVITATIONS.

ü  PITTING CORROSION RATE IS 2 TO 10 TIMES HIGHER THAN GENERAL CORROSION.

  • EXELON REQUESTED DELAYING COATING UNTIL LIMERICK’S LICENSES  EXPIRE (12 TO 17 YEARS), WITH INSPECTION EVERY 10 YEARS.
  • NRC TOLD EXELON: ((7-20-12 LETTER) TO DELAY COATING IN FUEL POOLS IS UNACCEPTABLE
  • YET, NRC CAVED IN TO EXELON AND REVISED REGULATIONS TO ALLOW EXELON’S COST-CUTTING DEMAND TO DELAY COATING OF LIMERICK’S FUEL POOL LINERS FOR 11 TO 16 YEARS.
  • EXELON IS ALSO BEING ALLOWED TO INSPECT EVERY 10 YEARS.

 

 

NRC APPROVED PERMIT AMENDMENTS AND LOOPHOLES THAT JEOPARDIZE PUBLIC HEALTH AND SAFETY

EXAMPLES BELOW:

NRC ALLOWED EXELON TO WAIT 7 DAYS (INSTEAD OF 12 HOURS) FOR HOT SHUTDOWN.  THIS IS AN UNACCEPTABLE THREAT TO PUBLIC HEALTH.

  • Limerick should not wait 7 days (instead of 12 hours) to go into hot shutdown when monitoring systems are inoperable (12-9-11 Limerick Permit Amendment Approved by NRC)
  • Both FEMA and NRC publically stated radiation can start to travel off-site within ½ hour of a problem/radiation accident.
  • Vast numbers of people in the Greater Philadelphia Region can now be exposed to higher levels of radiation without their knowledge, for at least 7 days, before Exelon must notify the public.
  • Based on nothing more than “NRC’s reasonable assurance”, NRC makes the absurd, indefensible claim that this amendment will not endanger the health and safety of the public.
  • Exelon has proven it fails to provide immediate full and accurate disclosure about radiation releases, based on Limerick’s most recent radioactive spill into drinking water (3-19-12) for almost two million people.   Exelon and NRC failed to notify the public for 23 days, eliminating the opportunity for people to protect themselves and their children.

 

ACE review and analysis of the following documents provide evidence of NRC’s negligent oversight and failed enforcement.  They refute irrational, unreasonable, and unsubstantiated statements and conclusions in NRC’s DRAFT EIS for Limerick Nuclear Plant.

 

  • NRC’s letters to Exelon related to relicensing reviews
  • NRC’s Integrated Inspection Reports and Notices of Violations for Limerick
  • NRC’s Safety Evaluation Report For Limerick License Renewal (July 2012)
  • NRC’s Safety Evaluation Report for Limerick License Renewal (January 2013)
  • NRC’s DRAFT Environmental Impact Statement (EIS) for Limerick April 30, 2013
  • NRC correspondence to ACE in March, April, and May of 2013

 

Previously ACE compiled a long list of NRC failed policies, decisions, and oversight

www.acereport.org  #15 – “NRC Negligence: Jeopardizing Our Future”

 ‘

ACE is profoundly alarmed by the evidence.  Clearly, it is negligent for NRC to allow Exelon to take the kinds of risks for meltdowns at Limerick caused bydangerous delays of safety upgrades.

 

NRC’s conclusions in Limerick’s DRAFT EIS for Limerick relicensing are further jeopardizing the entire Greater Philadelphia Region and ignoring the unacceptable risks of Limerick’s continued operation under the current conditions, much less 20 more years after 2029.

 

NRC’s response to ACE regarding our concerns about NRC’s failed oversight and enforcement at Limerick is to send us to NRC’s own Inspector General.

  • ACE has no confidence that NRC’s own inspector general could or would conduct a truly objective investigation.

 

QUOTES FROM EX-NRC CHAIRMAN GREGORY JACZKO

  • SUPPORT OUR SERIOUS CONCERNS
  • HE ALSO PROVIDES AN EXPLAINTION FOR WHY NRC IS IGNORING THE EVIDENCE AND MAKING IRRATIONAL, INACCURATE CONCLUSIONS IN LIMERICK’S DRAFT EIS TO RELICENSE LIMERICK NUCLEAR PLANT.

 

3-29-13

  • “Nuclear Plants should be Phased Out” “They Aren’t Safe”
  • Chairman Gregory Jaczko says that the current fleet of operating plants in the US should be phased out because regulators can’t guarantee against an accident causing widespread land contamination.
  • In two key NRC decisions last week Jaczko said the agency “damaged significantly” its international reputation for upholding safety and he accused the five commissioners of “just rolling the  dice” in dealing with severe accidents.

3-14-13

  • The biggest problem with NRC continues to be heavy influence that  industry has in selecting members of the commission.  It’s a very political process.  
  • “It would be virtually impossible for someone who is publicly skeptical of nuclear power to ever be confirmed as a commissioner on the NRC. That is fundamentally wrong.”
  • If you look at the state of nuclear power in the United States, it is not very good.  
  • It is ultimately meetings with senior executives of the utilities, who demand certain things and ask certain things of the chairman, and expect it to be done.
  • Then it turns into political pressure from members of Congress, as utilities will work with members of Congress to have them apply pressure.
  • There is no one else who has the authority to say no to a utility, other than the regulator.
  • Echoing complaints of previous commissioners who have alleged that the NRC is essentially an industry captive, Jaczko said, “The industry has gotten so bold that [before last week’s vote] they were able to say this was a done deal. This damaged significantly the credibility of the NRC. Internationally the NRC had been looked at as the gold standard.”

 

“The NRC Is NOT Doing Its Job” – Dave Lochbaum, Nuclear Engineer

Nuclear Safety Project for the Union of Concerned Scientists

1-17-12

  • Safety is defined by compliance with the regulations.  When it knows that half the plants in the country don’t meet fire protection regulations, it can’t say those plants are safe.”  Limerick is one of the nuclear plants that does not meet the safest fire protection regulations.
  • “In the mid-90s NRC recognized that some 27 US plants were in an area where the seismic risk was larger than they thought and that new reactors would have to be better protected, but NRC didn’t do anything about the 27 reactors that were already built and operating in those regions.”  Limerick is one of them.
  • “When you know about a problem – whether it’s fire protection or increased seismic risk – and you study it and don’t solve it, that’s not what should be done.”

NRC BACKPEDALED OFF ITS INITIAL REGULATIONS.

  • Why? The nuclear industry lobbyists are buying influence in Congress.  They give more to Congress than the tobacco industry did in the mid-90s.
  • In 1998, industry got Congress to threaten to cut the NRC budget by 40%, meaning 500 people would be fired from NRC.  So NRC backed off enforcement of regulations.

PLANTS ARE LICENSED FOR 40 YEARS, BUT THAT DOESN’T MEAN ALL THEIR PARTS LAST FOR 40 YEARS.   AS PLANTS GET OLDER, THE CHANCE OF FAILURE GOES UP.

  • It’s no guarantee plants are safe till 40.
  • Safety margins degrade.  Safety risk goes up because plant equipment is getting older, wearing out.
  • You skip the maintenance now, but it costs thousands tomorrow.

 

ACE CONCLUSION:

 

TO PROTECT THE HEALTH AND SAFETY OF MILLIONS OF PEOPLE IN THE GREATER PHILADELPHIA REGION, THEIR LIFE SUPPORT SYSTEMS, AND THEIR POSSESSIONS, EXELON SHOULD BE REQUIRED TO PROVIDE ALL THE MOST PROTECTIVE SAFEGUARDS IMMEDIATELY, OR LIMERICK NUCLEAR PLANT SHOULD HAVE ITS OPERATING LICENSE REVOKED IMMEDIATELY.

 

 

 

 

 

 

 

 

 

 

LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES

 

NRC’S DRAFT EIS HAS FAILED TO ADEQUATELY ADDRESS THE SITE SPECIFIC ENVIRONMENTAL IMPACTS OF THE MASSIVE AMOUNTS OF HIGH-LEVEL RADIOACTIVE WASTES CURRENTLY STORED IN FUEL POOLS AND CASKS ON THE LIMERICK SITE, AND THE IMPACTS OF THE FUTURE PRODUCTION OF LIMERICK’S  HIGH-LEVEL RADIOACITVE WASTES DURING LIMERICK’S RELICENSING PERIOD.

 

What could possibly have more of an impact on the future environment of the entire Greater Philadelphia Region than storing more and more of the most deadly materials on earth in fuel pools (like Fukushima’s) and above ground casks that can eventually leak?

 

  • Devastating Long-Term Environmental Impacts Can Result From Storing Or Transporting Limerick’s High-Level Radioactive Wastes.

 

  • NRC’s DRAFT EIS Fails To Adequately Address Specific Environmental Impacts of The Massive Amounts Of High-Level Radioactive Wastes Currently In Limerick’s Fuel Pools and Casks.

 

  • A New Review Of Limerick’s Spent Fuel Storage Is Imperative BEFORE Limerick’s EIS DRAFT Is Finalized.  There Are Many Unanswered Questions With Serious Implications For Devastating Environmental Consequences For Generations, If Not Forever.

 

What could have more impact on the future environment of the entire Greater Philadelphia Region than storing massive amounts of the most deadly materials on earth, in corroding and thinning fuel pools, originally made with substandard cement, and extremely vulnerable to meltdowns from earthquakes and terrorist strikes with planes and missiles (like Fukushima’s, high above reactors with no containment)?

  • NRC’s decision to allow Exelon to avoid an assessment of environmental impacts from all the deadly high-level radioactive wastes stored on the Limerick site until after the EIS is approved for relicensing, is really about protecting Exelon’s interests, not public interests.
  • There is NO NEED to rush Limerick’s relicensing, when its original license doesn’t expire for over a decade, another 11 years.
  • Given the extreme dangers and destruction faced by the entire Greater Philadelphia from Limerick’s high-level radioactive waste storage at Limerick, NRC would be negligent to ignore the unprecedented threats to the environment and population in Limerick’s Environmental Impact Statement.

 

Although re-licensing of Limerick was pushed back 2 years by the June 8, 2012 court decision requiring NRC to re-think the environmental impact of storing radioactive wastes (spent-fuel) at nuclear plants, Neil Sheehan from NRC made the inexplicable statement in an e-mail to the Mercury that NRC’s new rules about spent fuel storage, ordered by a court decision to be released September 2014, are not likely to affect Limerick’s Environment Impact Statement.

 

  • “There is no expectation that Exelon would have to conduct a new review of spent fuel storage at Limerick.”  (Mercury – March 8, 2013)

 

  • “Limerick nuke plant relicensing unlikely to be affected by new spent fuel rules” (Mercury – March 13, 2013)

CONTRADICTION:

Neil Sheehan’s March 2013 statements are contradictory to NRC’s December 2012 statements, which revealed the court said NRC should have considered potential environmental effects of leaks and fires involving spent fuel pools.

(Mercury – December 29, 2012 “Limerick nuke plant re-licensing delayed by courts”)

NRC wrote, “The Appeals Court ruled that in evaluating risks from on-site storage of spent fuel, “NRC should have considered the potential environmental effects in the event a permanent repository for disposing is never built and found other deficiencies with the agency’s consideration of leaks and fires involving spent fuel pools”.

  • NRC indicated an intention to respond with a new analysis to be “completed within 24 months”, including for Limerick.
  • NRC intended to “develop an environmental impact statement and a revised waste confidence decision and rule on the temporary storage of spent nuclear fuel.”
  • On Sept. 6, 2012, the NRC announced it would not fight the June 8, 2012 ruling by the U.S. District Court of Appeals, finding that NRC could not ignore the possibility that the federal government may never build a national repository for America’s spent nuclear fuel.

Important facts also in the 12-29-12 article:

  • In 2006, Exelon’s Limerick plant already reached its design capacity and beyond, forcing “dry storage” canisters to be built on-site. Ground was broken in 2007 for a dry cask storage system now storing the plant’s older, colder spent fuel.
  • All the fuel ever used at Limerick since it began operating remains on site to this day. It will remain radioactive for thousands of years.
  • Spent fuel storage should have brought about a two-year relicensing delay by NRC.
  • Until the recent challenge in court, NRC took the negligent position that spent fuel was so safe, it was not to be considered in re-licensing, but a court decision overturned NRC’s irrational conclusion.
  • NRDC petitioned the Atomic Licensing and Safety Board, arguing, among other things, that the reactors should not be re-licensed without a new, site-specific environmental impact review.

 

NRC STATEMENT IN LIMERICK’S APRIL 2013 DRAFT EIS

If the results of the Waste Confidence Decision EIS identify information that requires a supplement to the EIS, the NRC staff will perform any appropriate additional NEPA review for those issues before NRC makes a final licensing decision.” (6-3)

  • THAT MAKES NO SENSE AND IS UNACCEPTABLE FOR TWO REASONS

 

  1. THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK’S FINAL EIS BEFORE 2014, WHEN NRC’S COURT-ORDERED STUDY IS COMPLETED. LIMERICK’S FIRST LICENSE DOES NOT EXPIRE UNTIL 2024, A DECADE AWAY.

It is unacceptable for NRC to finalize Limerick Nuclear Plant’s EIS prior to finalization of NRC’s Court-Ordered Waste Confidence Rules, which will not occur until 2014.  The U.S. Court of Appeals for the D.C. Circuit found that an Environmental Impact Statement needed to add additional discussions concerning the impacts of failing to secure permanent disposal of spent nuclear fuel, and concerning the impacts of certain aspects of fuel pool leaks and fires.

 

  1. THERE ARE MAJOR UNADDRESSED AND UNANSWERED SPECIFIC CONCERNS ABOUT CURRENT STORAGE OF LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES, ESPECIALLY THE WASTE CURRENTLY STORED IN LIMERICK’S FUEL POOLS.

 

NO FINAL LIMERICK EIS SHOULD BE COMPLETED UNTIL AFTER NRC’S WASTE CONFIDENCE RULING HAS BEEN FINALIZED AND ALL LIMERICK SPECIFIC HIGH-LEVEL RADIOACTIVE WASTE ISSUES HAVE BEEN COMPLETELY ANSWERED AND ADDRESSED.

  • IT WOULD BE PREMATURE AND ABSOLUTELY INAPPROPRIATE TO ISSUE LIMERICK’S FINAL EIS WITHOUT INCLUDING THE RULING FROM THE COURT-ORDERED WASTE STUDY, AND WITHOUT ANSWERING IMPORTANT QUESTIONS AND CONCERNS.

 

  • 3-21-13 ACE presented a written request to NRC for responses to specific Limerick high-level radioactive waste issues.
  • NRC failed to respond to the concerns and questions presented 3-21-13.  5-16-13 Mel Gray responded to other issues for which we asked questions, but totally ignored the high-level radioactive waste issues.

 

LIMERICK’S FUEL POOLS

 

Spent Fuel Pools  – A Catastrophe Waiting To Happen

  • Limerick’s Fuel Pools are OVERLOADED with massive amounts of high-level radioactive waste rods.   Wastes held in pools exceed design expectations.
  • Large volumes of Limerick’s highly radioactive wastes produced since Limerick started operating in 1985 are stored in Limerick fuel pools.
  • Fuel pool liners are corroding and thinning faster than expected.
  • Pools are filled with radioactive fluids that are threatening to boil away, introducing radiation into the air.
  • They are vulnerable to a 9/11 type terrorist attack with a plane or missile.  That kind of attack could lead to an unstoppable radioactive fire which could impact people hundreds of miles away, according to an NRC study (2000).
  • Pools are outside the reinforced containment structures for the reactors.
  • With so much deadly radioactive wastes in the pools, an attack on Limerick’s fuel pools could result in an unstoppable radioactive fire, with potentially worse consequences than Chernobyl.

 

Below Is A Summary of Major Issues and Concerns To Be Addressed:

  1. 1.      Corrosion and Thinning Documented in Limerick’s Fuel Pool Liners at Rates up to 10 times Faster than Anticipated. 
  2. 2.      High-Level Radioactive Wastes Stored in Limerick’s Fuel Pools Beyond Design Capacity.
  3. 3.      Limerick Previous Accepting Waste From Other Nuclear Plants – Permit Changed in 2012 Without A Hearing
  4. 4.      Structural Deficiencies in the Concrete of Limerick’s Fuel Pools
  5. 5.      Limerick’s Fuel Pools Are Similar to Those That Exploded at Fukushima – High Above reactors With NO Containment.
  6. 6.      Inadequate Alternative Back-Up Power
  7. 7.      Fuel Pool Instrumentation
  8. 8.      Spent Fuel Pools Are At High Risk For Meltdowns From Loss of Cooling Water Due To:
  • Earthquakes, Cracking, Aging, Brittle, Deteriorating, Substandard Cement
  • Leakage and Evaporation
  • Explosion Inside or Outside Pool Building
  • Terrorist Acts With Planes Or Missiles – Fuel Pools Are Not Protected Against Air Strikes or Missiles

ü   Aircraft Impact

ü   Siphoning

ü   Pumping

ü   Accidental or Deliberate Drop of Fuel In Transfer

See: Spent Fuel Pools Pose A Danger – Associated Press – March 17, 2011

 

CORROSION and LOSS of THICKNESS in LIMERICK’S SPENT FUEL POOLS

NRC caved in to Exelon, ignoring NRC’s own objections to Exelon’s request to delay coating of Limerick’s fuel pools.  NRC plans to ignore documented cracking, corrosion, pitting, and cavitations in Limerick’s fuel pools holding the most deadly materials on earth, related to relicensing approval.   Limerick could be relicensed with no guarantee Exelon ever can or will coat or provide other protective measures on Limerick’s fuel pools.

 

NRC told Exelon that to delay coating the degraded fuel pool areas is unacceptable.

NRC outlined “Substantial Corrosion” and loss of thickness issues in Limerick’s fuel pool liners.

(Documented in 7-20-12 NRC letter to Exelon)

  • The documented corrosion rate is far higher than original corrosion rate calculations for fuel pools.
  • Pitting corrosion rates are unpredictable (usually 2 to 10 times more than the general corrosion rates).

 

In spite of cracking, corrosion, pitting, and cavitations in Limerick’s fuel pools, documented by NRC:

  1. 1.   Exelon requested deferring protective measures like coating until Limerick’s current licenses expires (a delay of 12 to 17 years).
  2. 2.   Exelon proposes inspection only every 10 years.

 

Despite adverse impacts on the safety and integrity of Limerick’s fuel pools and associated unprecedented threats to public health and safety:

  • NRC revised regulations to accommodate Exelon’s requests to delay coating Limerick’s fuel pools, despite enormous threats to public health and safety for millions of people.

 

We Believe NRC’s Assumption That Limerick’s Fuel Pools Can Be Coated At All Is Based On Illusion.  The Public Needs Answers:

 

  1. It is negligent to assume Limerick’s fuel pools will remain safe until Limerick’s current license expires in 16 years, when corrosion has already been documented at rates far faster than originally calculated.  What NRC officials made the inexplicable decision to allow delayed coating of Limerick’s fuel pools, despite NRC’s original conclusion that to delay coating fuel pools was unacceptable?  Please provide name(s) and contact information.

 

  1. NRC appears to be under the illusion that coating fuel pools can be done at all.

Explain the exact process in detail that Exelon would use to coat liners, now or in the future.

 

Answer critical questions below:

  1. Won’t all radioactive water and radioactive wastes need to be removed from fuel pools for repair and coating?

­   As long as Limerick continues to operate, 2 more tons each year of this deadly radioactive waste will need to be cooled in Limerick’s fuel pools for at least 5 years.

­   Limerick’s fuel pools are already overloaded, far beyond design basis, with this waste that requires cooling for a minimum of five years, to avoid combustion resulting in a devastating radioactive fire.

  1. Where would the radioactive wastes currently stored in the pools go until pools are coated?  That waste will still need to be cooled.
  2. Where will the massive amount of radioactive water go when drained for recoating?

 

  1. Did anyone except Exelon ever inspect fuel pool liners for cracking, corrosion, pitting, and cavitations?   Were fuel pool liners ever inspected by NRC?

 

  1. How does NRC justify inspection only every 10 years, when pitting corrosion rates have proven to be much greater than original rate calculations?

LIMERICK’S FUEL POOLS ARE PACKED, FAR BEYOND DESIGN BASIS

 

Limerick’s Radioactive Fuel Rods Are Among The Deadliest Materials On Earth

Estimated Spent Fuel Stored At Limerick

                        An Estimated 1,143 Tons 

Many tons more will be produced each year Limerick operates.

 

Limerick’s Over Packed Fuel Pools Are Extremely Dangerous And Must Be Protected

  • Spent Fuel In Pools Contain More Radioactivity Than Reactors
  • Spent Fuel Rods Give Off Enough Radiation To Kill People In Seconds
  • Pools Are At High Risk From Loss of Water Accidents

 

WHY DO LIMERICK’S FUEL POOLS CONTAIN SO MANY MORE FUEL ASSEMPLIES THAN OTHER NUCLEAR PLANTS OPERATING LONGER?

 

LIMERICK’S FUEL POOLS CONTAIN FAR MORE THAN FUKUSHIMA’S AND OTHER US NUKES:

Limerick’s Fuel Pools Contain Far More Assemblies Than Other U.S. Nuclear Plants, Including Exelon’s Three Mile Island and Oyster Creek

Compared to Fukushima

More Than Twice As Much In 2 Limerick Fuel Pools Than 4 At Fukushima.

6,203 Assemblies -  2   LIMERICK FUEL POOLS

                        2,400 Assemblies -  4   FUKUSHIMA FUEL POOLS

Information Above From The Institute for Policy Studies by Bob Alvarez, “Spent Nuclear Fuel Pools in the U.S.: Reducing the Deadly Effects of Storage”  Appendix A: Site Specific Estimates of Radioactivity in U.S. Spent Fuel  Page 26  Source: DOE/EIS-0250, Appendix A, Tables A-7, A-8, A-9, & A-1

 

  • Did Limerick ever take spent fuel from other nuclear plants?
  • Did Limerick ever take spent fuel from Three Mile Island after the partial meltdown?

NRC’s 5-18-12 written response to ACE about quantity of fuel used at Limerick was puzzling.

“Exact amounts of ‘special nuclear material’ in a licensee’s possession is considered to be security sensitive information and not permitted to be released to the public.”

  1. 1.      We believe the public has a right to know how much waste is at Limerick and where it came from.
  2. 2.      Approximately 2 tons produced each year for the 28 years Limerick operated should be 56 tons, NOT 1,143 tons.  Explain in detail.   Why is there so much more from two Limerick reactors then 4 Fukushima reactors?  
  3. 3.      Even if it is 2 tons per reactor per year, the amount stored in Limerick’s pools should only be 106 Tons, NOT 1,143 Tons.

This discrepancy needs to be fully understood by the public.  If the amount of waste used per reactor each year can be estimated, there is NO LOGICAL REASON NRC should refuse to provide the public with approximate totals.  Anyone should be able to do the math, including terrorists and NRC.  NRC’s response made us wonder what is really going on.

 

  • Did Limerick’s Operating License Amended 12-19-11 Allow Limerick To Receive and Possess Spent Fuel Rods From Other Nuclear Plants?  YES  OR  NO 

 

Limerick’s Operating License Permit Was Amended (12-19-11). Language Included

“To Allow Limerick to Receive and Possess Fuel Assemblies and Fuel Channels From Other Nuclear Plants, Such As That Already Received From Shoreham Decades Earlier.”

Exact language (Below) Is From Limerick’s Amended Operating Permit 12-19-11

UNITED STATES NUCLEAR REGULATORY COMMISSION  WASHINGTON, D.C. 20555-0001

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION,

UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE   Amendment No. 167 License No. NPF-85

Page 3

(4) Pursuant to the Act and 10 CFR Parts 30, 40, 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and

(5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station.

 

DID NRC ALLOW LIMERICK TO ACCEPT HIGH-LEVEL RADIOACTIVE WASTES FROM OTHER NUCLEAR PLANTS DECADES AGO, BUT JUST CHANGE LIMERICK’S OPERATING PERMIT TO ALLOW THAT 12-19-11?  

ACE Requested Detailed Explanations From NRC, But Didn’t Even Receive A Response To The Following Questions;    

  1. Why Would Limerick Have Its Operating License Amended In 2011 To Receive and Possess Radioactive Waste From Other Nuclear Plants, When Limerick Already Received These Wastes From Shoreham and Possibly TMI? 
  2. Did receipt and possession of Shoreham’s waste violate Limerick’s original operating permit?
  3. When Limerick received waste from Shoreham decades ago, wasn’t that in violation of Limerick’s operating permit?
  4. This Is A Major Permit Change, Which Adds Dramatically to The Risk In Our Entire Region and the Transportation Route.  Why Wasn’t The Public Widely Informed With An Opportunity To Comment and Have A Public Hearing?

 

  • How long will it take Exelon to remove most of Limerick’s deadly wastes from dangerous fuel pools and store it in above ground casks? 

 

STRUCTURALLY SUBSTANDARD CEMENT IN LIMERICK’S FUEL POOLS

Defective concrete in Limerick’s fuel pools could have serious adverse effects on the structural adequacy to prevent leaks and meltdowns triggered by an earthquake or a terrorist attack with a plane or missile.  

 

NRC’s 5-12 response to ACE acknowledges the structural defect from the concrete pour of Limerick’s fuel pools, but refers to a decades old unsubstantiated NRC “assumption” that it would have no adverse effect on the structural adequacy.  

  • NRC’S “ASSUMPTION” Is Both Illogical And Unsubstantiated.

 

NRC’s “assumption” was indefensible from the beginning, but it’s even worse now, with increasing threats from earthquakes and terrorist attacks with planes or missiles on the stories high fuel pools.   We remind NRC that if Limerick’s fuel pools suffer cracks and cooling water starts to leak, it can be the beginning of a catastrophic disaster.

 

INADEQUATE ALTERNATIVE BACK-UP POWER TO PREVENT MELTDOWNS IN FUEL POOLS AND REACTORS AS WAS NEEDED AT FUKUSHIMA.

  • It Appears Limerick Will Be EXEMPTED From NRC’s Post-Fukushima Still To Be Revised Station Blackout Rule, And That Back-Up Power To Prevent Meltdowns At Limerick Is Still Woefully Inadequate
  • The Fukushima disaster proves there could be four simultaneous meltdowns at Limerick and that a constant energy supply is vital for cooling water and other operations to prevent meltdowns.
  • In 2013, two years after Fukushima, NRC has still not required Exelon to have indefinite back-up power to prevent potential meltdowns in Limerick’s two reactors and two fuel pools.
  • New NRC rules say there must be indefinite back-up power, yet it does not appear that indefinite back-up power is available at Limerick for fuel pools or reactors.
  • NRC’s new “station blackout” rules do not apply to plants licensed to operate prior to July 21, 1988, which includes Limerick, according to NRC’s website, Last Reviewed/Updated, Friday, March 01, 2013,
  • In 2011, Ex-NRC chairman Jaczko said,  “ I’m not convinced four hours is reasonable to restore off-site power”.
  • Despite repeated requests, NRC has provided no evidence that Limerick has more than four hours of back-up power for each reactor or any back-up for fuel pools. 

 

After Fukushima, we learned only 4 hours or 8 hours of back-up power for Limerick could be woefully inadequate to attempt to prevent meltdowns, yet it appears that is all that is required at Limerick.

  • We also realized in a worst case scenario, there could meltdowns simultaneously, in both reactors and both fuel pools at Limerick from loss of power, then loss of water.
  • In April 2012, ACE first asked NRC about the numbers of Limerick’s back-up generators and the available time of operation for each. 
  • March 21, 2013, ACE again asked for specific answers about the length of time of Limerick’s capability to provide back-up power for both generators and fuel pools simultaneously, in the case of a black-out from natural disasters or terrorist attacks.    

     Specific Questions on Back-Up Power to Prevent Meltdowns:

  1. Does Limerick have access to back-up generators for Limerick’s  2 reactors and 2 fuel pools operating simultaneously?

­   If not, why not?

­   Are all back-up generators planned for Limerick stored on-site?

­   If not, did NRC verify planned back-up generators will actually be available and how long it would take to get them operating on site?

­   How many times a year are capabilities of generators tested (on and off-site)?  There have been many problems with start-up of generators, including a fire at Limerick in 2007.

  1. What is the exact amount of time Limerick can cope with station blackout?

­   Is it still only 4 hours?

­   If not, what is the new minimum capability required for each generator at Limerick?

  1. How long will fuel last that is stored on site (using generators for 2 reactors and 2 fuel pools)?
  2. What is the plan if power can’t be restored within the required time to restore power?

 

After what happened at Fukushima, NRC required indefinite back-up power capabilities. In March, 2012, a year after Fukushima, NRC made new rules requiring a plan to indefinitely survive blackouts, to keep reactors cool during an electric failure.

  • NRC then revised the rule, allowing Exelon to avoid costs of providing indefinite blackout capability at Limerick Nuclear Plant.
  •  Station Black Out does not require a tsunami or an earthquake.  Black Outs at nuclear plants have been caused by blizzards, tornadoes, raccoons, and a bird.

 

  • Given the potential dire consequences, as part of the EIS for relicensing NRC should require Exelon to comply with the new NRC rule for indefinite back-up power for Limerick Nuclear Plant. 
  • Limerick should be required to prepare for the worst case scenario and have indefinite back-up power, enough for both reactors and fuel pools simultaneously to minimize devastating environmental harms.   

 

INADEQUATE FUEL POOL INSTRUMENTATION TO DETECT LOSS OF

WATER TO PREVENT MELTDOWNS.

 

March, 2012, Older reactors with General Electric Co (GE) design containment structures like Limerick’s (similar to those that failed at Fukushima) were ordered by NRC to have sturdier venting systems to prevent damage to reactor cores.

NRC rules required Exelon to install new, more reliable instrumentation at Limerick, to measure Limerick’s spent fuel cooling pools – no later than within 2 refueling cycles.  Exelon was given 60 days to respond.  Exelon’s response was due by May 12, 2012.  Orders were issued by NRC August 30, 2012.

  • HAS EXELON REPLACED LIMERICK’S FUEL POOL LEVEL INSTRUMENTATION?

IF SO, WHEN?   IF NOT, WHY NOT? 

 

Limerick’s spent fuel instrumentation may only be capable of monitoring under normal conditions.  Spent fuel pools rely on maintenance of an adequate inventory of water under accident conditions to provide containment to prevent meltdowns, as well as for cooling and shielding.  Emergency responders need reliable information on water in spent fuel pools to prioritize emergency actions. At Fukushima responders were without reliable instrumentation to determine water level in the spent fuel pool.  This caused concerns that the pool may have boiled dry, resulting in fuel damage.  Fukushima demonstrated confusion and misapplication of resources  that can result from inadequate instrumentation.

 

LIMERICK’S PACKED FUEL POOLS ARE VULNERABLE TO EARTHQUAKES

AND TERRORISTS’ AIR STRIKES AND MISSILES.

Shaking from earthquakes can cause cracking in cement of fuel pools, leaking of cooling water, and eventually potential meltdowns.

NRC gave Exelon until 2017 to deal with earthquake risks at Limerick.

  • What exactly will Exelon do to reduce threats of cracking of brittle cement in Limerick’s fuel pools?
  • Given the consequences, whatever can be done should be required immediately.  Waiting until 2017 is far too risky.

Limerick’s fuel pools are stories high over the reactors, similar to Fukushima’s.  There is no protective containment such as exists around the reactors.  A terrorist air strike or missile could trigger leaking of cooling water, possibly even fires. There is no way to protect fuel pools from terrorist planes or missiles.

  • Would Limerick’s fuel pools be protected against terrorist air strikes or missiles if Limerick is relicensed?  If not, why not?  If so, how?

 

Summary: SPENT FUEL POOLS AT LIMERICK

Large volumes of Limerick’s high-level radioactive wastes (all produced since 1985) are being stored in fuel pools and casks on the Limerick site.  They are among the most deadly materials on earth.  EPA gave storage of this dangerous waste a million-year health standard.   This will likely remain in our region for decades, if not forever.  As long as Limerick operates, tons more of this deadly waste will be produced each year.

  • Limerick’s Spent Fuel Pools Are Packed Beyond Design Basis, And Vulnerable.
  • Limerick’s Spent Fuel Pools Are At High Risk From Loss of Cooling Water Through Leaks Due To:

­Earthquakes – Reactor Failure – Leakage- Evaporation – Explosion Inside or Outside Pool Building – Terrorist Acts Such As  Aircraft Impact,  Siphoning,  Pumping, Accidental or Deliberate Drop of Fuel In Transfer

­    Limerick’s fuel pools are packed far beyond design capacity, sit five stories above ground,  and are highly vulnerable to loss of water through terrorist attacks by plane or missile, and  cracking or crumbling from a strong earthquake.

­    Limerick’s fuel pools were constructed with substandard cement, which is becoming embrittled after 28 years.

  • The Release of Radiation From Limerick’s Fuel Pools Could Render The Entire Greater Philadelphia Region Uninhabitable For Generations.  Health and Economic Impacts Of A Terrorist Attack On Spent Fuel Pools Like Limerick’s Could Be Astronomical.

­   Especially vulnerable to aircraft penetration, Limerick’s fuel pools can be turned into weapons of mass destruction. Still, Exelon has not been required to spend the money to guard Limerick against terrorist missiles or air strikes.

­   Large volumes (over 6,000 assemblies-1,000 tons), of Limerick’s highly radioactive wastes (spent fuel rods) are stored in densely packed fuel pools, elevated five stories above and outside the reinforced containment structure for the reactor.

­   Limerick’s design is similar to reactors in meltdowns at Fukushima. Roof-top fuel pools are highly vulnerable to loss of power and cooling water from an earthquake or other natural disasters, in addition to a variety of attacks by terrorists.

­   With loss of cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire, causing tens of thousands of deaths up to 500 miles away, according to a 2000 NRC study.

­   A meltdown in a spent fuel pool could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from the site.

 

Health and Economic Impacts Of A Terrorist Attack On Spent Fuel Pools Like Limerick’s

 

Limerick’s packed fuel pools can be turned into weapons of mass destruction. Fuel Pools are especially vulnerable to aircraft penetration.   Still, Exelon has not been required to spend the money to guard Limerick against terrorists’ missiles or air strikes.

  

A 2004 Study by Dr. Edwin Lyman, Senior Scientist at the Union of Concerned Scientists, Concluded:

  • As many as 44,000 near-term deaths from acute radiation poisoning
  • 518,000 long term deaths from cancer.  
  • Deaths could occur among people living as far as 60 miles downwind.

 

A 2003 study by Dr. Frank Von Hippel, Director of Science and Global Security at Princeton University, concluded that:

  • A successful terrorist attack on a spent fuel storage pool could have consequences “significantly worse than Chernobyl.”  
  • A catastrophic spent fuel fire could release a radiation plume that could contaminate 8 to 70 times more land than  Chernobyl.  (Would include the entire Philadelphia Metropolitan Region).

 

A January 2003 study by Dr. Gordon Thompson, Director of the Institute for Resource and Security Studies (entitled “Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security”) reviewed ways spent fuel pools are vulnerable to attack.

  • A nuclear fire in 1 spent fuel pool would “render about 95,000 square kilometers of land uninhabitable,” (would cover about 75% of New York State, and into, segments of NJ and CT.)

 

SPENT  FUEL  FIRES

Experts Say:

“A Spent Fuel Fire Can Contaminate 8 To 70 Times More Land Than Chernobyl”

  •     “Spent     Fuel Must Be Seen As Pre-Deployed Radiological Weapons”
  •     ”     With Loss of Water, Spent Fuel Rods Heat Up, Self-Ignite And Burn in an     Unstoppable Fire.”
  •     “Zirconium     Cladding – Can Trigger a Reaction and Fire Which Can Burn Away Cooling     Water”
Fuel     Rods In Pools At Limerick Risk Loss Of Water From A Fire Because:

 

NRC didn’t require Limerick to     follow the safest  fire safety     regulations.  NRC made a second set     of standards followed by Limerick, determined to be “safe     enough”.  That is not     acceptable, given the consequences of a fire involving Limerick’s fuel rods     stored in pools.

The pools are vulnerable to a     9/11 type terrorist attack and fire from jet fuel.  NRC is failing to require Exelon to guard     against this type of attack at Limerick.

We need the most stringent     precautions.  Dr. Thompson concluded a nuclear fire in the spent fuel pool (of     Indian Point Unit 2) would: Release     Enough Cesium-137 “To Render About 95,000 Square Kilometers Of Land     Uninhabitable,” (covering about 75% of New York.  Similar distance would be true here.

 

 

 

LIMERICK’S DRY-CASK STORAGE

 

ANOTHER REASON THAT LIMERICK’S DRAFT EIS MUST BE CHANGED TO INCLUDE   POTENTIAL HARMS FROM THIS DEADLY WASTE:

  • LIMERICK’S HIGH-LEVEL RADIAOCTIVE WASTES STORED   IN CASKS ALSO PRESENT LONG-TERM ENVIRONMENTAL RISKS THAT CAN’T BE IGNORED BY   NRC IN ITS DRAFT EIS FOR LIMERICK. 

 

Spent Fuel Stored   In Above Ground Casks

  •   Casks Are Threatened by Natural Disasters like   Earthquakes, Tornadoes, and Floods.    The extremely heavy casks were shifted on their base during the North   Anna earthquake.  If air flow vents get clogged from   severe weather events and remain clogged for an extended period, rods can   overheat and combust.
  •   Corrosion   of steel holding Limerick’s high-level radioactive waste rods is a huge   concern.   NRC is well aware of   Limerick’s highly corrosive air as a result of chlorine and other corrosives   massively released into the air from Limerick cooling towers with 44 million   gallons of steam every day.
  •   Corrosion   over time may make it impossible to remove rods in the event of a problem   with leaking, for transport, or event the threat of combustion.
  •   Containers   are expected to last 50 years – wastes stay dangerous over a million years.
  •   Much   of Limerick’s wastes are likely to remain on site in these casks for decades,   if not forever.  What will happen if   corrosion makes it impossible to remove the wastes into new containers every   50 years?
  •   How   much of this deadly high-level radioactive waste will be stored in how many   of these casks on the Limerick site by 2029?     2049?

 

NRC’S   DRAFT EIS NEEDS TO ADDRESS THE LENGTH OF TIME RODS NEED TO SAFELY REMAIN IN   THE POOLS BEFORE EXELON REMOVES THEM FOR DRY CASK STORAGE.

  • NRC   HAS ALLOWED EXELON TO REMOVE RODS FOR DRY-CASK STORAGE FAR SOONER THAN THE   5-YEAR TECHNICAL SPECIFICATION REQUIREMENT.
  • ACE   OBJECTS TO THIS DANGEROUS DEVIATION FROM TECHNICAL SPECIFICATIONS, EVEN IF   OLDER RODS ARE WRAPPED AROUND RODS LESS THAN 5 YEARS IN STORAGE.
  •   This is yet another   example of NRC lowering safety protections to accommodate Exelon.
  •   It seems clear that   Exelon is trying to load dry cask storage more quickly to free space for more   waste being generated and that NRC is allowing this risky removal to   accommodate Exelon.

 

NRC Is Clearly Jeopardizing Health and Safety Of Limerick Workers and The Public By Removing Limerick’s Radioactive Rods Sooner Than The 5-Year Technical Specification Requirement.

  • Since 2006, when Exelon first tried to convince the public that cask storage was safe, NRC and Exelon repeatedly stated 5 years was required to safely remove fuel rods from Limerick’s fuel pools, however that ‘s not what happened at Limerick – at least in 2010.
  • IMPORTANT POINT – The less cool down time in fuel pools, the thermally hotter and more radioactive the waste – the more risk of internal combustion and an unstoppable radioactive fire.
  • Dry cask technical specifications state:   Radiation shielding and thermal heat removal require around 5 YEARS, minimum, cool down time in the pool before transfer to dry casks.
  1. Yet, June 16, 2006, NRC in a letter to ACE claimed 1 year storage in the fuel pool at Limerick was sufficient before removal for above ground storage.
  2. July 13, 2006 at a meeting in Limerick NRC again clearly stated cool down time before removal from fuel pools was at least 5 years.
  3. July 25, 2006 ACE received an e-mail from NRC stating:
  • Cooling time in the pool is: 1 year  or  3 years or 5 years

               From: James Trapp – NRC  Date: 07/25/06 07:04:34

In our letter to you dated June 16, 2006 we stated the time was at least 1 year.  This statement was correct.  I received   the following information from Randy Hall that should help to clarify our statement.…. Most spent fuel that is placed in dry           storage must be aged for 5 years or more, as required by all NRC-approved Certificates of Compliance for dry cask            storage   systems….Purposely using the word most, because there are cask designs, including NUHOMS, that would              allow certain low-irradiated fuel to be placed in a cask with only 3 or more years of cooling in the spent fuel pool.

  1. May 6, 2010  -  Exelon Employee At A Limerick Open House Said:

Older and newer “spent fuel rods” are removed from Limerick’s fuel pools at the same time.   Older rods are stored outside newer rods in assemblies (sometimes 1-year old).

  • NRC Irresponsibly Allows Dangerous Fuel Rod Removal To Accommodate Exelon.

Risk to Region – Potential Unstoppable Radioactive Fire

Limerick Workers – Higher Radiation Dose

  • NRC’s Pamphlet Proves How Dangerous Nuclear Power Plant High-Level Radioactive Waste Is.   Office of Public Affairs Brochure  NUREG/BR-0216, Rev.2“May 2002 – Page 7 – How hazardous is high-level waste?   Standing near unshielded spent fuel could be fatal due to the high radiation levels.

TEN YEARS AFTER REMOVAL OF SPENT FUEL FROM A REACTOR:

  • RADIATION DOSE 1 Meter Away From A Spent Fuel Assembly EXCEEDS 20,000 Rems Per Hour
  • 5,000 Rems Would Be Expected To Cause Immediate Incapacitation and Death within One Week

 

Clearly, removing spent fuel rods from pools to load dry casks far sooner than the 5-year requirement is an extremely dangerous experiment that needs to be stopped at Limerick.   While it frees space in pools for new wastes to be generated by Limerick, to make more money for Exelon, it presents unacceptable risks to workers and the public.

Consider The Following:

10 years after removal of spent fuel from a reactor:

ü  Radiation dose 1 meter away from a spent fuel assembly exceeds 20,000 Rems Per Hour

ü  5,000 Rems would be expected to cause immediate incapacitation and death within 1 week.

Information From: NRC’s own pamphlet NUREG/BR-0216, Rev.2 May 2002

211 Radioactive Poisons found in every 10-yr. old irradiated fuel bundle (Canadian Study)

ü  Polonium 210 – Just 1 of 211 – the type that poisoned Alexander Litvinenko in 2006

ü  An alpha emitter with the ability to become airborne with ease

ü  1 Gram could poison 100 million people – Extremely dangerous in milligrams or micrograms

ü  Biological ½ life in humans 30 to 50 days

ü  Targets organs – liver and spleen

ü  Short-term exposure carries long-term risk of death from cancer

 

 

LIMERICK’S DRY CASK STORAGE OF LIMERICK’S DEADLY RADIOACTIVE WASTES ABOVE GROUND IN CASKS – RISKS MUST BE ADDRESSED IN NRC’S FINAL EIS FOR LIMERICK NUCLEAR PLANT

 

Background:

Limerick’s Independent Fuel Storage Installation was placed in service starting July 21, 2008.   Since 2008, Exelon started removing Limerick’s dangerous deadly radioactive wastes from Limerick’s fuel pools to above ground dry cask storage.   From 1985, after Limerick started operating, until 2008, all Limerick Nuclear Plant’s deadly high-level radioactive wastes were stored in Limerick’s fuel pools.  They become dangerously overcrowded.   Limerick’s fuel pools are a similar design to those melting down at Fukushima.

 

Limerick’s dangerous and deadly radioactive wastes will likely remain in our backyard forever, posing serious threats to us and future generations.    Limerick Nuclear Plant has turned us into a DeFacto High-Level Radioactive Waste Dump.   EPA set a million year health standard for high-level radioactive waste storage.  Containers holding these deadly wastes are estimated to safely contain the waste for only 50 years, when the wastes remain deadly for hundreds of thousands of years.

 

CASK DESIGN FLAWS –  A SERIOUS CONCERN

 

  • A Nuclear Engineer Warned ACE About Design Flaws In Casks For Storing Limerick’s High-Level Radioactive Wastes.
  • ACE Reported The Information To NRC.  Sadly, Design Flaws Were Denied Or Ignored.

 

EVENTUALLY PROBLEMS COULD BECOME A RECIPE FOR DISASTER.

 

ü  UNDETECTED CORROSION

ü  INABILITY TO REMOVE IN CASE OF FIRE OR NATURAL DISASTER

ü  FAULTY CONCRETE

ü  EASY TERRORIST TARGET

ü  LAX NRC OVERSIGHT AND ENFORCEMENT

  • THE NUCLEAR ENGINEER WHISTLE BLOWER CALLED LIMERICK CASK TECHNOLOGY “OLD AND DOWNRIGHT DANGEROUS”
  1. 1.      Cask Design Flaws
  • Cement Blocks, Assembled Together, Are Not The Safest Housing For Enclosing Deadly Nuclear Fuel, Not Even Anchored to the Concrete Floor
  • Industry Workers Claim NUHOMS Concrete Enclosure Falls Apart and Container Is Breeched Under a Boeing Airplane Strike.
  1. 2.      Corrosion of Steel
  • Can Eventually Cause Nuclear  Wastes to Collapse On Their Own.
  • Safe Storage Depends on Airflow.  Air Around Limerick Is Likely Highly Corrosive.   It’s Only a Matter of Time Before Invisible and Inaccessible Steel Tubes Turn to Rust.  
  • 40 Ton Radioactive Waste Containers, “Filled With The Nastiest Of Manmade Stuff”, Are Placed And Rest Unfastened On A Set Of Steel Columns. 
  1. 3.      Wastes May Not Be Able To Be Retrieved
  • Rods Are Being Removed From Pools at Limerick Years Before NRC Regulations First Required.  Rods Stored In Casks Too Hot Can Heat Up And Cause Fire.
  • Containers Are Expected To Last 50 Years, While Wastes Are Deadly Hundreds Of Thousands Of Years.

He Said Casks May Be A Sitting Duck In Face of a Crashing Aircraft

 

CORROSION – A MAJOR CONCERN

 

Research validates ACE concerns about corrosion of steel storing deadly wastes at Limerick Nuclear Plant.    No one knows how long it will take for nuclear waste storage containers to break down from corrosion and eventually leak – It is only a matter of time. 

 

How long will it take for steel to corrode that holds high-level radioactive wastes above ground in our back yard at Limerick Nuclear Plant? 

 

2005 NRC’S OWN STUDY FOUND PROBLEMS WITH CORROSION RATES OF METALS USED TO STORE NUCLEAR WASTE.

 

  • YET NRC STOPPED THE RESEARCH INSTEAD OF ADDRESSING THE CORROSIVE STEEL.

PROVEN CORROSION CONCERNS

 

  • 2006 Testimony to Congress by Public Citizen – Provided evidence of scientific misconduct by NRC and DOE related to corrosion rates of metals used to store nuclear wastes.

ü  In 2005 NRC found problems with the corrosion rates of metals used to store nuclear waste, yet failed to address the corrosion problems.

ü  Research identifying corrosion problems was stopped, not the use of steel that would corrode.

  • 2006 NRC dismissed important evidence identified by ACE related to corrosion of steel planned to hold Limerick’s high level radioactive wastes in above ground casks.

ü  Every day Limerick adds massive amounts of toxic chemicals to cooling tower waters.

ü  MSDS sheets identify 10 of them to be corrosive, some highly corrosive and some specifically corrosive to steel.

ü  There is NO FILTRATION to prevent corrosive chemicals from entering the air from cooling tower steam.

ü  Synergistic combinations of the corrosive additives can result in a serious corrosive threat to people and everything exposed to the drift from the cooling towers (44 million gallons every day), including steel holding deadly radioactive wastes stored inside casks that require cooling with outdoor air.

ü  Corrosive air enters casks holding high-level radioactive waste rods stored in steel.

ü  NRC admits corrosion will happen, yet dismissed ACE concerns without site specific testing of cooling tower emissions for specific and conversion corrosives.

ü  NRC’s dismissive, misleading, and irresponsible conclusions defy logic.  They can lead to irreparable disaster in our region.

 

NRC PROVES CORROSION FROM LIMERICK’S COOLING TOWERS CORRODES STEEL AND CAUSES CRACKING IN 4 TO 52 WEEKS.

 

June 12, 2012

  1. a.       RAI B.2.1.25-1.1   

Stress Corrosion Cracking for stainless steel surfaces in an outdoor air environment in auxiliary and steam and power conversion systems.

 

EMPHASIS ADDED:  LIMERICK’S NPDES PERMIT SAYS:

16,000 TO 58,000 lbs per day of CHLORINE (sodium hypochlorite) are used at Limerick Nuclear plant.

 

Exelon told NRC:

  • Even though CHLORINE is ADDED to COOLING TOWERS AS SODIUM HYPOCHLORITE, there is no concern (for stress corrosion cracking of stainless steel surfaces) because “COOLING TOWER PLUME IS DIRECTED AWAY FROM THE PLANT”

NRC Responses:

  • Studies and industry operating experience in chloride-containing environments have shown that stainless steel exposed to an outdoor air environment can crack at temperatures as low as 104 to 120 degrees F, depending on humidity, component surface temperature, and contaminant concentration and composition.
  • Cracking can occur in 4 to 52 weeks.
  • NRC cannot conclude recent inspections are sufficient to demonstrate an aging effect will not occur during the period of extended operation.
  • A prevailing wind does not result in the absence of contaminant deposition by the cooling tower plume.
  • Information has not been provided on the potential for chloride contamination from the onsite soil or nearby agriculture and industrial sources.
  • NRC lacks sufficient information to conclude that stress corrosion cracking cannot occur in stainless steel components located in an outdoor air environment.

 

  • Corrosion can make it difficult, if not impossible, to move Limerick’s extremely heavy casks.  To date, there is no proof Limerick’s radioactive fuel rods can be moved safely after years of exposure to corrosive air.

 

NRC’S DENIAL AND NEGLIGENCE COULD EVENTUALLY LEAD TO DISASTER RELATED TO LIMERICK’S CASKS

  • NRC admits there were fabrication deficiencies in materials used for Limerick’s canisters and concrete, but refuses to call them flaws, and claims they were corrected, even though that may not be entirely accurate.  While the company was fined a nominal amount, in years to come, we could find cask design flaws could lead to a radioactive disaster.
  • July, 2006 Areva, the company making Limerick casks, received a Notice of Violation, documenting specific problems with casks already in place, yet NRC allowed casks for Limerick to continue to be built by this company.
  • November, 2006 in a whistle blower letter it was revealed that there were specific concerns about casks planned to be used at Limerick.
  • In an 11/06 letter to ACE, both NRC and Transnuclear (Areva) admitted there would be corrosion and settling of ground beneath 40 ton casks, yet NRC failed to require air testing in the vicinity of casks for corrosives against metals being used for casks.

 

EARTHQUAKE  THREATS  TO  CASKS

  • The earthquake in Virginia proved heavy cement casks, each weighing many tons, can be jarred and even moved.  Casks at a nuclear plant 12 miles from the epicenter of the August 23, 2011 earthquake in VA were moved by the earthquake.
  • There  is an earthquake fault directly under the Limerick site with two others within 2 miles.  Two other earthquake faults are very close to Limerick.   One 9 miles away is active.  The other is 17 miles away.
  • After a natural disaster like an earthquake, there is no proof that this deadly waste will be able to be removed safely, especially after corrosion has taken place.   None have ever been removed after a long period of time.
  • What could happen if damaged or overheating fuel rods in casks cannot be removed because of jarring from an earthquake?  No one knows.   It’s like playing Russian Roulette.

 

NRC REFUSED TO PROVIDE A RISK ASSESSMENT FOR TERRORISTS

Limerick Is NOT Protected From Terrorists’ Missiles and Air Strikes.

 

ACE REPEATEDLY URGED NRC TO PROVIDE A RISK ASSESMENT FOR TERRORIST ATTACKS ON CASKS. 

  • Limerick has the 2nd most densely populated region in the U.S.
  • NRC was negligent in failing to provide a risk assessment for terrorist attacks related to above ground storage of high-level radioactive wastes at Limerick Nuclear Plant.

 

A Federal Court Ordered NRC To Assess Terrorist Threats In California

A U.S. Court of Appeals 9th Circuit decision forced NRC to assess the threat of a terrorist attack on above ground storage at the Diablo Canyon Nuclear Plant in California.

 

ACE Asked NRC To Consider The Same Threats As Were Required At Diablo Canyon.

1)     The threat posed by a “land-based vehicle bomb.”

2)     A “ground assault with the use of an insider”

3)     A “water-borne assault”

4)     “A large aircraft impact similar in magnitude to the attacks of September 11, 2001.”

 

Similar threats exists at Limerick, yet NRC chose to interpret the 2006 court decision in a very narrow way.  

  • NRC inexplicably claimed an assessment was not necessary at Limerick, even though vast numbers of people live very close to Limerick Nuclear Plant. 
  • NRC dismissed harmful health impacts from radiation exposure, irrationally claiming “a significant release of radiation affecting the public is not reasonably expected to occur”, when army testing suggests otherwise. 
  • NRC also ignored the potential for rods overheating and combusting. 

 

Consider The Following Limerick Specific Issues For A Risk Assessment to be Included In Limerick’s Updated EIS:

1)      Limerick is not guarded against airplane or missile attacks.

2)      Nuke waste housing can be penetrated by missiles (proven by army testing).

3)      THREE AIRPORTS are too close to Limerick Nuclear Plant. 

ü  Army testing proves missiles can penetrate casks.

ü  Pilots take lessons at Limerick Airport, only 1 mile away.

ü  Helicopters fly into the Limerick Airport from which missiles could be launched.

4)      An industrial railroad runs through the nuclear plant site.

Industrial rail tracks run directly through the nuclear plant property, providing a way for terrorists to enter the site undetected.

5)      A large portion of the site is bordered by the Schuylkill River.

Limerick Nuclear Plant property is bordered by the Schuylkill River (over a long distance), presenting a difficult, if not impossible challenge, for too few guards.

6)      Too few guards have to cover Limerick’s 600 acres.

7)      Heavily populated region surrounds Limerick Nuclear Plant – Almost 8 Million people within 50 miles.

 

Limerick Nuclear Plant’s Radioactive Wastes Are A Major Threat To Public Health, Safety, And The Economy In The Greater Philadelphia Region

 

As Long As Limerick Continues To Operate, More Of This Dangerous and Deadly Waste Will Be Produced.

 

  • Limerick is a de-facto high-level radioactive waste dump, storing massive amounts of all the deadly high-level radioactive wastes produced at Limerick since it started operating in 1985.   
  • Large volumes, if not all, of this dangerous waste will likely remain on the Limerick site long past Limerick’s proposed relicensing period in 2049.
  • EPA has a million-year health standard for storage of high-level radioactive waste.

 

In Conclusion:

THERE IS NO SAFE SOLUTION FOR LIMERICK’S HIGH-LEVEL RADIOACTIVE WASTES.

 

  • Facts About Limerick’s Dangerous Deadly High-Level Radioactive Wastes Show The Only Logical Solution Is To Stop Making It.

 

  • LIMERICK SHOULD BE CLOSED AS SOON AS POSSIBLE, NOT RELICENSED.

EACH YEAR LIMERICK OPERATES MANY TONS MORE OF LIMERICK’S DEADLY HIGH-LEVEL RADIAOCTIVE WASTES WILL BE PRODUCED.  THREATS WILL OBVIOUSLY INCREASE IF LIMERICK IS RELICENSED.

 

  • LIMERICK’S RADIOACTIVE WASTES ALREADY PRODUCED NEED TO BE STORED ON SITE SAFER.

 

  • NRC CANNOT JUSTIFY IGNORING LIMERICK SPECIFIC ENVIRONMENTAL IMPACTS FROM LIMERICK’S MASSIVE AMOUNTS OF HIGH-LEVEL RADIOACTIVE WASTES.

 

  • NRC’S FINAL EIS FOR LIMERICK NUCLEAR PLANT SHOULD NOT BE COMPLETED UNTIL AFTER NRC’S COURT-ORDERED HIGH-LEVEL RADIOACTIVE WASTE STUDY IS COMPLETED IN 2014 AND THE RESULTING ACTIONS ARE APPLIED TO LIMERICK.

 

  • THE OUTCOME OF NRC’S COURT-ORDERED HIGH-LEVEL RADIOACTIVE WASTE STUDY MUST BE INCORPORATED INTO LIMERICK’S FINAL EIS, REGARDLESS OF THE LENGTH OF TIME REQUIRED.

 

  • THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK’S EIS FOR RELICENSING, WHEN LIMERICK’S FIRST LICENSE DOES NOT EXPIRE FOR OVER A DECADE.

 

For more information see www.acereport.org

Download #9 “High-Level Radioactive Wastes: A Ticking Time Bomb”

 

 

LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES

 

LOW-LEVEL DOES NOT MEAN LOW RISK.

LIMERICK NUCLEAR PLANT’S “SO-CALLED” LOW-LEVEL RADIOACTIVE WASTES CAN TAKE AS LONG AS 500 YEARS TO FADE TO NATURAL BACKGORUND LEVELS.

 

NRC FAILS TO TRACK VOLUME OF LOW-LEVEL RADIOACTIVE WASTES PRODUCED AT LIMERICK EACH YEAR.  IN MARCH 2013 AN NRC OFFICIAL TOLD ACE THAT TRACKING THE VOLUME OF LIMERICK’S LOW-LEVEL RADIAOCTIVE WASTE ISN’T IMPORTANT.  WE DISAGREE!

  • IF NRC DOESN’T KNOW HOW MUCH IS PRODUCED, NRC CAN’T CONFIRM WHAT HAS HAPPENED WITH ALL OF THE MASSIVE LOW-LEVEL RADIOACTIVE WASTES PRODUCED AT LIMERICK NUCLEAR PLANT.
  • PROBLEM: EXELON COULD STILL BE BURNING SOME OF LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES IN LIMERICK’S BOILER “A” WITHOUT NRC’S KNOWLEDGE.

 

NRC HAS NO ACCURATE IDEA HOW MUCH LOW-LEVEL RADIAOCTIVE WASTE IS PRODUCED AT LIMERICK EACH YEAR OR WHERE IT IS GOING.

  • WE HAVE NO CONFIDENCE NRC HAS ANY IDEA WHAT EXELON IS DOING WITH ALL OF LIMERICK’S MASSIVE LOW-LEVEL RADIOACTIVE WASTES.
  • NRC’S STATEMENTS AND NEWS REPORTS DON’T MATCH LOW-LEVEL RAD-WASTE DESTINATIONS REPORTED BY EXELON ON NRC’S WEBSITE (SIMPLY AS NUMBERS OF TRAIN OR TRUCK SHIPMENTS).
  • JANUARY 2010, EXELON GOT PERMISSION TO SHIP LIMERICK’S LLRW TO PEACH BOTTOM. MARCH 2013 NRC TOLD US LIMERICK’S LLRW WAS SHIPPED TO PEACH BOTTOM. YET, NO SHIPMENTS WENT TO PEACH BOTTOM AT ALL IN 2010, 2011, OR 2012, ACCORDING TO NRC’S WEBSITE.

PROBLEM:  NRC HAS BEEN DECEIVING US ABOUT INCINERATION OF LOW-LEVEL RADIOACTIVE WASTES AT LIMERICK NUCLEAR PLANT. 

  • SINCE 2009, NRC HAS BEEN DENYING THAT LIMERICK EVER BURNED LOW-LEVEL RADIOACTIVE WASTES.
  • MARCH 2013 AN NRC OFFICIAL FINALLY ADMITTED WHAT WE SUSPECTED FROM REVIEWING LIMERICK’S AIR POLLUTION PERMIT IN 2009 – THAT EXELON BURNED LOW-LEVEL RADIOACTIVE WASTES AT LIMERICK.

 

INCINERATING ANY OF LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES IS NOT AN ACCEPTABLE OPTION, ESPECIALLY IN THIS HEAVILY POPULATED REGION WHERE THERE IS ALREADY A HEALTH CRISIS.

  • BURNING RADIOACTIVE WASTES DOES NOT DESTROY THE RADIONUCLIDES, BUT INSTEAD DISPERSES THEM IN SUCH A WAY THAT THEY ARE MORE EASILY INHALED, INCREASING THREATS TO HEALTH FROM THE INTERNAL RADIATION EXPOSURE, THE MOST DANGEROUS EXPOSURE.

 

  • POTENTIAL HARMS FROM BURNING LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES MUST BE INCLUDED IN LIMERICK’S FINAL EIS FOR RELICENSING.

EXELON IS CLAIMING THEY WON’T CONTINUE TO BURN LIMERICK’S LOW-LEVEL RADIAOCTIVE WASTES, BUT:

  • EXELON’S TRACK RECORD SHOWS WHY WE CAN’T BELIEVE OR TRUST EXELON
  • NRC HAS NO SYSTEM IN PLACE TO ACCURATELY CONFIRM WHAT IS BEING DONE WITH ALL LIMERICK LOW-LEVEL RADIOACTIVE WASTE.

 

NRC HAS NO LONG-RANGE PLAN FOR WHAT WILL BE DONE WITH ALL LIMERICK’S MASSIVE LOW-LEVEL RADIOACTIVE WASTES UNTIL LIMERICK’S CURRENT LICENSE IN 2029. 

  • NRC CANNOT JUSTIFY RELICENSING LIMERICK FOR 20 YEARS BEYOND 2929 WHEN THERE IS NO SAFE PLACE TO STORE ALL THE LOW-LEVEL RADIOACTIVE WASTE THAT WILL BE PRODUCED. 
  • THERE IS NO ROOM AT LIMERICK TO STORE THE LLRW THAT MUST BE KEPT AWAY FROM PEOPLE FOR UP TO 500 YEARS,
  • PEACH BOTTOM CANNOT CONTINUE TO TAKE LIMERICK’S WASTES FOR DECADES.  NRC SAID THERE IS NO PLAN TO TAKE LIMERICK’S WASTES TO PEACH BOTTOM FOR MORE THAN ONE YEAR AT A TIME.  
  • THE NATION IS RUNNING OUT OF ROOM TO STORE LOW-LEVEL RADIOACTIVE WASTES AT THE FEW SITES DESIGNATED IN OUR NATION TO STORE IT.

 

RECYCLING CANNOT BE AN OPTION

EXPOSING PEOPLE TO RECYCLED RADIOACTIVE WASTES IN THEIR PRODUCTS SUCH AS BELT BUCKLES, DISHES, AND BABY CARRIAGES INCREASES HEALTH THREATS AND COSTS.  iT IS SHAMEFUL AND NEGLIGENT. 

 

RECYCLING RADIOACTIVE WASTES CAN BE COSTLY TO BUSINESSES.  FOR EXAMPLE, THE BED, BATH, AND BEYOND RECALL ON RADIOACITVE TISSUE HOLDERS. 

 

BURNING LIMERICK’S LOW-LEVEL RADIOACTIVE WASTE CANNOT BE AN OPTION.

We are extremely concerned that Exelon may try to burn Limerick’s low-level radiaoctive waste in an incinerator or even in its boilers at some time in the future.

 

This would be tragic negligence on the part of Exelon and NRC. Visit our website for details www/acereport.org, summaries:

  • · #2 – Cancer – Skyrocketing Increases: Links to Limerick
  • · #5 – Limerick’s Major Air Pollution: A Serious Health Threat
  • · #10 – Low-Level Radioactive Wastes: Not Low Risk

 

Background:

When Limerick Nuclear Power Plant applied for its Title V major air pollution license renewal, ACE questioned whether Limerick was incinerating low-level radioactive wastes. Due to our past investigations and opposition to incinerators in our community, we recognized that some of the air pollutants listed in Limerick’s air pollution permit were the same as those from an incinerator. Burning does not make radiation disappear. Inhaling radionuclides is one of the worst routes of exposure.

 

Section D Source Level Requirements #005 – Operating permit terms and conditions          (a) “The permittee, may, in auxiliary boiler “A”, fire … Specific Waste Derived Liquid Fuel (WDLF).” The air toxics listed below from the WDLF are similar to those from incineration. The permit stated that WDLF Shall Meet Following Contaminant Limits Prior to mixing and Shall Not Exceed Limits After mixing:

(PRIOR to mixing with virgin No. 2 oil) (AFTER mixing or out the stack?)

  • · Arsenic                 10 ppm                   Arsenic                   5 ppm
  • · Cadmium              10 ppm                   Cadmium                2 ppm
  • · Chromium             20 ppm                   Chromium               10 ppm
  • · Lead                    300 ppm                 Lead                      100 ppm
  • · PCB                     49 ppm                  PCB                      10 ppm
  • · Total Halogens 1000 ppm                    Total Halogens        1000 ppm

Ash                       2% ASTMD-482

Sulfur                     0.3%       X-Ray Diffraction

                Permit States: Maximum Amount of WDLF to be burned in the boiler shall not exceed;

1) 10,000 gallons over 12 consecutive months

2) Maximum of 3,000 gallons in any single month

 

The list above suggested to us that Exelon was incinerating at least some of Limerick’s LLRW in one of Limerick’s 3 boilers, calling it “Waste Derived Liquid Fuel”.

 

Our major concern was the synergistic, additive, and cumulative harmful health impacts from all these toxics, combining with all the different kinds of radionuclides routinely released at Limerick, plus the magnified radiation risks from burning LLRW.

 

Experts explained to us the extreme danger with the potential consequences of exposure to radionuclides from an incineration process.

 

PA DEP’s response document denied that Limerick was burning low-level radioactive waste, but also failed to answer many of our specific questions.

 

In 2009 ACE Requested An Accounting For, And Destination Of, All Limerick’s Low-Radioactive Wastes From 2000 to 2049

 

Knowing that low-level does not mean safe and that some radionuclides in low level wastes can take as long as 500 years to fade to natural background levels, and realizing that Limerick could no longer send its low-level waste to Barnwell, S.C., we felt it was important to have full and accurate public disclosure on where Limerick’s low-level wastes would now be taken..  Obviously, there was no more room at Limerick, since Limerick sent it to numerous locations since 2005.

As long as Limerick Nuclear Plant continues to operate, massive amounts of low-level radioactive wastes will continue to be produced.

 

February 27, 2013 ACE requested answers and documentation to several LLRW issues from Mel Gray.  On March 20, 2013 we received a response with links to annual records for shipments of low-level radioactive wastes from Limerick between 2005 and 2011. The  numbers of annual shipments were reported, mostly by truck.  There was no reporting on the number or capacity of vehicles per shipment, total weight, or total volume of wastes shipped. 

 

Written responses were requested to each of the questions and concerns below for which we did not get answers:

  1. Can NRC document the total amounts of low-level radioactive wastes produced at Limerick each year?    If so, please provide totals for each year from2005 through 2011.   If not, why not?
  2. Exelon is now approved to send Limerick’s Low-level radioactive waste to Peach Bottom.  Did NRC verify how many years Peach Bottom will be able to store Limerick’s massive low-level radioactive waste?  Logic suggests if Limerick has no space on site to store it, Limerick’s low-level radioactive wastes cannot continue to be stored at Peach Bottom either.

ü  Is there space to continue to store Limerick’s LLRW there until 2049?

ü  Logic suggests Limerick’s low-level radioactive wastes cannot continue endlessly to be stored at Peach Bottom.

ü  Will Limerick’s low-level radioactive waste be stored at Peach Bottom:

­   Until 2029 when Limerick’s license expires?

­   Until 2049 if NRC approves Limerick’s license renewal?

  1. Can NRC document total amounts of Limerick’s low-level radioactive wastes shipped to Peach Bottom each year since 2009?    If so, please provide those totals.  If not, why not?
  2. Does NRC have written assurances from Exelon that there will be enough space at Peach Bottom to store all Limerick’s low-level radioactive wastes until 2029 when Limerick’s current license expires?   If so, please provide evidence of such assurances.

 

JUSTIFICATION FOR REQUESTED INFORMATION  -  After Barnwell, South Carolina closed in 2008, we repeatedly questioned NRC about the destination of Limerick Nuclear Plant’s massive amounts of low-level radioactive wastes including:

ü Waste Sludges

ü Filter Elements

ü Contaminated Equipment

ü Paper

ü Rags

ü Plastic Sheeting

ü Spent Demineralizer Resins

ü Evaporator Bottoms

ü Materials Used In Decontamination and Contamination Control

ü Shoe Coverings

ü Gloves

ü Mops

ü Wiping Rags

ü Tools

ü Water Treatment Residues

ü Machine Parts

IN 2013, WE FINALLY LEARNED THAT NRC CANNOT ANSWER THE QUESTIONS WE HAD BECAUSE NRC DOES NOT TRACK LLRW VOLUME AND NRC HAS BEEN LAX IN OVERSIGHT.

 

ACE also asked DEP for an accounting of the destination of all Limerick’s massive low-level radioactive wastes since 2000 when Exelon bought Limerick Nuclear Plant.

  • To this day, we never received an accounting.  There has been no accountability from DEP or NRC.

DEP also failed to provide an accounting of all low-level radioactive waste amounts and their destinations since 2000, so that ACE could compare amounts before and after the closing of Pottstown Landfill in 2005 and Barnwell, S.C. in 2009.

 

DEP’S FALSE CLAIM EXPOSED

We are starting to believe no agency is keeping an accurate accounting of Limerick’s low-level radioactive wastes.

  • PA DEP’s Title V 12/09 response document claimed all Limerick’s low-level rad-wastes were stored in a special building on Limerick’s site.
  • A month later, an article in our local paper said Exelon was requesting permission to send Limerick’s low-level radioactive waste to another Exelon site in PA, Peach Bottom.

 

  1. In relation to license renewal, NRC must provide the public with verifiable evidence that NRC has obtained a long-range commitment from Exelon related to the safe destination and storage of all Limerick’s low-level wastes until 2049.
  2. It is imperative for NRC to track the volume of Limerick’s LLRW and make Exelon accountable for safe storage of Limerick’s low-level radioactive wastes, PRIOR to consideration of Limerick relicensing.
  3. 3.   Since low-level radioactive wastes must be kept away from the public and can only be stored at special destinations, it would be negligent to allow this waste to continue to be produced if there is no safe long-term destination for it  

 

  • IT WOULD BE BOTH UNETHICAL AND UNACCEPTABLE FOR NRC TO ALLOW EXELON TO INCINERATE LIMERICK’S LOW-LEVEL RADIOACTIVE WASTES AT OR NEAR LIMERICK. THAT IS NOT AN ACCEPTABLE OPTION IN THIS HEAVILY POPULATED REGION WHERE THERE IS ALREADY A HEALTH CRISIS.

 

 

 

FINANCIAL INJUSTICE OF LIMERICK NUCLEAR PLANT

 

NRC’S COST-BENEFIT ANALYSIS FOR THE ENVIRONMENTAL IMPACTS AND RELICENSING FAIL TO CONSIDER THE PUBLIC’S COSTS FOR HAVING LIMERICK NUCLEAR PLANT IN OUR REGION.

 

NRC’S DRAFT EIS FOR LIMERICK NUCLEAR PLANT FAILS TO IDENTIFY, ANALYZE, ACKNOWLEDGE, OR CONSIDER THE ASTRONOMICAL PAST, CURRENT, AND FUTURE LONG-TERM ENVIRONMENTAL AND HEALTH CARE COSTS TO THE PUBLIC RELATED TO LIMERICK NUCLEAR PLANT OPERATIONS.

 

IN OUR EIS TESTIMONY 10-26-11, ACE REQUESTED THAT NRC CONSIDER ALL COSTS TO THE PUBLIC IN THE COST/BENEFIT ANALYSIS FOR LIMERICK NUCLEAR PLANT’S EIS.

  • NRC MADE NO ATTEMPT TO CALCULATE THE COSTS WE IDENTIFED NOR MADE ANY MENTION OF PUBLIC COSTS FOR LIMERICK NUCLEAR PLANT IN NRC’S EIS FOR LIMERICK.
  • INSTEAD, NRC PLACED DISPROPORTIONATE VALUE ON EXELON’S COSTS AND CONTRIBUTIONS, WHICH PALE BY COMPARISON TO THE PUBLIC’S COSTS FOR HAVING LIMERICK NUCLEAR PLANT IN OUR REGION.

 

IN REALITY:

  • EXELON PROFITS, WE PAY!
    • EXELON AND THEIR CEO’S PROFIT AND BENEFIT.
    • THE PEOPLE IN OUR REGION GET THE HARMS AND PAY THE COSTS.

 

IN REALITY:

  • LIMERICK’S ELECTRIC GOES TO THE GRID TO BE DISTRIBUTED IN THREE STATES, BUT THE PEOPLE IN OUR REGION WERE FORCED TO PAY THE LIONS’ SHARE OF LIMERICK’S CONSTRUCTION AND DECOMMISSIONING.

 

WHAT DID LIMERICK NUCLEAR PLANT COST THE REGION’S TAXPAYERS AND RATEPAYERS SINCE 1985?

  • LIMERICK NUCLEAR PLANT’S COSTS TO THE PUBLIC HAVE BEEN ASTRONOMICAL, TO BOTH TAXPAYERS AND RATEPAYERS, FAR OUTWEIGHING ALL EXELON’S CLAIMED BENEFITS.

 

PUBLIC COSTS FOR LIMERICK NUCLEAR PLANT INCLUDE:

  •         CONSTRUCTION
  •         DECOMMISSIONING
  •         RADIOACTIVE WASTE STORAGE, FOREVER
  •         HIGHER DRINKING WATER   COSTS
  •         HIGHER HEALTH CARE COSTS
  •         HIGHER ELECTRIC RATES

 

EVIDENCE SUGGESTS EXELON OWES THIS COMMUNITY FAR MORE THAN IT DONATES TO OUR REGION’S COMMUNITIES, ORGANIZATIONS, OR POLITICIANS.

NRC fails to make Limerick licensing decisions factoring in true and accurate costs to the public in cost/benefit analyses.

 

For detailed information on Limerick’s Financial Injustice see www.acereport.org

# 18 “Financial Injustice”

 

NRC’s “COST-BENEFIT ANALYSES” are an injustice to public interests.

NRC never did a fair and accurate cost/benefit analysis related to Limerick Nuclear Plant.

NRC fails to value the public’s financial interests. Although this is standard operating procedure for NRC, it is clearly unacceptable.    

 

NRC’S SOCIOECONOMIC ANALYSIS WAS A DISGRACEFUL SHAM, ASSERTING ALL HARMS AND COSTS WOULD BE SMALL, WITH NUCLEAR HAVING EQUAL OR LESS HARMS THAN OTHER ALTERNATIVES.

 

  • WHAT ARE THE HEALTH CARE COSTS FOR LIMERICK’S ROUTINE RADIATION RELEASES?

ACE REQUESTED THAT NRC CALCULATE THE COST FOR ALL CANCERS ABOVE THE

NATIONAL AVERAGE AFTER LIMERICK STARTED OPERATING IN 1985.  WE ASKED THAT

NRC BASE THE NUMBERS ON THE COST TRACKED FOR JUST ONE CHILD DIAGNOSED

WITH CANCER AT 6 MONTHS TO TWO YEARS OF AGE.

  • NRC FAILED TO EVEN RESPOND, MUCH LESS DO THE CALCULATION.

 

  • WHAT ARE THE COSTS FOR ADDITIONAL HOSPITALIZATIONS AND EMERGENCY ROOM VISITS DUE TO ENORMOUS PM-10 EMISSIONS IN LIMERICK’S 44 MILLION GALLONS OF COOLING TOWER STEAM RELEASED EVERY DAY INTO OUR AIR?  EVIDENCE IS UNDENIABLE THAT PM-10 INCREASES EMERGENCY ROOM VISITS AND HOSPITALIZATIONS.  LIMERICK’S PM-10 CONTAINS MASSIVE AMOUNTS OF CHLORINE, PATHOGENS, AND A HOST OF OTHER TOXIC CORROSIVE CHEMICALS ASSOCIATED WITH A BROAD RANGE OF DISEASES AND DISABILITIES FOR WHICN COSTS ARE ASTRONOMICAL.

 

  • NRC WAS WORRIED ABOUT DAMAGE TO STAINLESS STEEL STRUCTURES AND PARTS AT LIMERICK FROM MASSIVE CHLORINE IN COOLING TOWER STEAM.   EXELON ADMITS THE CORROSIVE AIR BLOWS OFF-SITE.  VAST NUMBERS OF RESIDENTS HAVE HAD MUCH DAMAGE TO THEIR CARS, OUTDOOR FURNITURE, ETC.  WHAT IS THE COST TO THE PUBLIC FOR REPLACING THOSE THINGS?

 

  • WHAT ARE THE HEALTH CARE COSTS RELATED TO LIMERICK’S RADIOACTIVE AND OTHERWISE TOXIC DISCHARGES INTO THE DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE?

 

  • WHAT ARE THE COSTS TO WATER COMPANIES AND THEIR CUSTOMERS FOR THE CONSEQUENCES OF MASSIVE TOTAL DISSOLVED SOLIDS RELEASED FROM LIMERICK AND TOXIC MINE WATER PUMPING?

 

Limerick Nuclear Plant’s costs to the public add up to one of the biggest corporate welfare schemes ever.  Yet, NRC never includes astronomical costs to the public in its cost/benefit analyses for licensing. 

 

PECO/Exelon make enormous profits at Limerick, while the public pays the lion’s share of business costs, far beyond corporate donations, contributions, or taxes.

 

  1. Enormous Construction Costs Largely Paid By Ratepayers:

Construction costs for Limerick were $6.8 Billion, largely paid by the region’s ratepayers in their electric bills every month, from 1985 to 2010.  By 1997, our electric rate climbed to 55% above the national average.  This is an outrage.  Limerick’s energy goes to the grid. It goes to several states, but we bear the costs.

 

  1. Property and School Taxes Avoided, Then Drastically Reduced:

PECO/Exelon avoided paying property or school taxes on its site from 1985 to 2002.  Taxpayers were forced to pick up the tab.  In 1999, PECO tried to avoid taxes forever by claiming Limerick was worth zero.  A court settlement assigned Exelon a fraction of what they should have paid.  Instead of paying its fair share, Exelon pays only $3 million a year when it should have been paying $17 million a year.   In essence, from 1985 to 2013 Exelon avoided paying over $400 million dollars in taxes.  That’s unethical.  Exelon donations to this community pale by comparison.

 

  1. Additional Costs For Cancers That Skyrocketed Far Higher Than National Averages After Limerick Started Operating:

What has it cost this region for all the cancers and other illnesses linked to Limerick’s radiation that are alarmingly higher than the national average?  NRC was asked to consider that by ACE in 2011, but didn’t.  The costs of environmentally linked disease and disability are astronomical and preventable.  For example, the costs for one child diagnosed with cancer at six months, and tracked for two years were over $2 million and counting.  NRC failed to consider that in this EIS for Limerick.

 

  1. Water Contamination:

Limerick’s toxic and radioactive wastewater discharges cost water companies and their customers more. Exelon should filter to protect public health. Limerick discharges massive amounts of toxic and radioactive wastewater into a vital drinking water source for almost two million people. Obviously, this can greatly increase the costs for water treatment companies and their customers, and contribute to incalculable health costs.   The costs for Exelon to filter pales by comparison.

 

  1. Growing Amounts Of High-level Radioactive Waste Storage Forever:

Tons are produced at Limerick every year, remaining deadly virtually forever. The public cost is in higher taxes to store it at Limerick.  It is impossible to know how much it will cost the public, saddled with the storage of Limerick’s high-level radioactive wastes, virtually forever.   NRC failed to consider that too.  It is appalling that Exelon has received from our government $300 million, with the promise of another $600 million, just to store their own wastes on site.  That’s taxpayer money.

 

  1. Decommissioning:

Ratepayers are largely funding decommissioning through hidden charges in monthly electric bills to residents in our region. Decommissioning is a big ratepayer rip-off.  We will continue to have to pay for Limerick decommissioning each month in hidden electric charges on our electric bills.

 

Through miscalculation on Exelon’s part, $100 million more will be needed for Limerick, which Exelon wants ratepayers to fund.   Exelon makes mistakes, and we pay for them.  Exelon has an estimated $1 Billion total shortfall, and expects to get $100 Million more from our region in rate hikes for Limerick’s decommissioning.

 

WHY WOULD NRC BELIEVE EXELON ABOUT ANYTHING?

$1 BILLION SHORTFALL IN EXELON’S DECOMMISSIONING FUND

  • NRC caught Exelon shorting its decommissioning fund by $1 BILLION.
  • Yet, NRC will likely fail to require Exelon to be accountable.
  • NRC will likely allow ratepayers and taxpayers to get stuck with yet another huge bill to make up the shortfall in Exelon’s fund.
    • Exelon planned to ask the PA PUC for ratepayers to get increases to pay for the $100 million shortfall for Limerick’s Decommissioning Fund.

EXELON REPEATEDLY DECEIVED NRC ABOUT A BROAD RANGE OF ISSUES.  NRC FAILS TO TAKE MEANINGFUL ENFORCEMENT MEASURES FOR EXELON’S DECEPTION, INCLUDING FINANCIAL.

 

EXELON’S DECEPTION AND REFUSAL TO PAY FOR VITAL NEEDED PREVENTIVE HEALTH AND SAFETY PROTECTIONS CAN HAVE GRAVE CONSEQUENCES TO MILLIONS OF PEOPLE IMPACTED BY LIMERICK NUCLEAR PLANT OPERATIONS.

 

  1. TO PREVENT UNNECESSARY HEALTH CARE COSTS AND HIGHER COSTS FOR PUBLIC DRINKING WATER, AS A CONDITION OF RELICENSING, EXELON SHOULD BE REQUIRED TO FILTER ITS DANGEROUS TOXICS DISCHARGES INTO THE VITAL DRINKING WATER SOURCE FOR ALMOST TWO MILLION PEOPLE.
  • Exelon’s refusal to spend the money to filter the outfall that transports Limerick Nuclear Plant’s dangerous radiation and cooling tower toxics into the vital drinking water source for almost two million people is not acceptable.
  • Exelon should be required to filter the massive amounts of toxic mine water it is pumping into a vital drinking water source. Exelon is poisoning the river with toxic mine water for Limerick operations and should be required to filter it.

WIITHOUT QUESTION, FILTRATION WOULD REDUCE TOXIC THREATS TO WATER AND HEALTH AND THE PUBLIC’S ASSOCIATED COSTS, EVERY YEAR LIMERICK OPERATES.

 

  1. TO PREVENT THE POTENTIAL FOR AN ESTIMATED TRILLION DOLLAR PUBLIC COST FOR DEVASTATING MELTDOWNS, BEFORE RELICENSING LIMERICK, EXELON SHOULD BE REQUIRED TO FULLY COMPLY WITH THE MOST PROTECTIVE NRC POST-FUKUSHIMA SAFETY RECOMMENDATIONS.

 

  1. TO AVOID UNNECESSARY DISASTROUS RADIATION ACCIDENTS AND POTENTIAL MELTDOWNS, BEFORE RELICENSING, EXELON SHOULD BE REQUIRED TO IMMEDIATELY REPLACE AND REPAIR CORRODING, DETERIORATING, AND OTHERWISE AGING LIMERICK SYSTEMS AND STRUCTURES.
  • If NRC allows Exelon to delay or avoid replacing or repairing the serious corrosion and aging problems in the fuel pools and elsewhere that NRC staff identified, until after relicensing, Exelon may never fix them eventually resulting in millions of people losing everything and becoming nuclear refugees with little, if any, help from the government.    
  • Costs for NRC not requiring Exelon to take immediate action to replace and repair all corroding and deteriorating systems and equipment to prevent a large radiation release or even multiple meltdowns could be incalculable.  Costs would include health care, temporary and permanent relocation, clean-up, etc.

 

NRC OFFICIALS MUST NOT ALLOW EXELON TO AVOID COSTS FOR DELAYING OR AVOIDING COMPLETELY NRC STAFF-RECOMMENDED POST-FUKUSHIMA SAFEGUARDS AND PROTECTIVE REPLACEMENT AND REPAIRS FOR PROBLEMS IDENTIFIED BY NRC STAFF IN SAFETY EVALUATIONS FOR LIMERICK.  IF LIMERICK HAS AN ACCIDENT OR MELTDOWN, THOSE OFFICIALS ARE ETHICALLY RESPONSIBLE FOR A CATASTROPHE AND SHOULD BE HELD LEGALLY RESPONSIBLE.

 

THE COSTS FOR NO FILTRATION WILL FAR OUTWEIGH COSTS TO EXELON FOR PRECAUTION AND PREVENTION.   NRC OFFICIALS WHO HAVE NO COURAGE OR CARING FOR THE VICTIMS OF LIMERICK’S UNPRECEDENTED THREATS TO DRINKING WATER AND WHO FAIL TO REQUIRE FILTRATION TO PREVENT UNNCESSARY HEALTH THREATS AND COSTS TO THE PUBLIC ARE ALSO RESPONSIBLE FOR THE INEVITABLE OUTCOME.  

 

 

 

 

 

 

 

 

 

 

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