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



  • In 2015, NRC documented several Limerick accidents that had significant potential to lead to core damage as “green” and “of very low safety significance.”
  • The public risk that is part of Limerick operations and accidents leads to questions about NRC’s public announcement that in 2015:
  1.   “Overall, LGS operated in a manner that preserved public health and safety”
  2.   Limerick “is moving along on vent installation and other post-Fukushima work we required.”  (Mercury, 3-8-16)


FIRE: 4-5-15

Fire broke out close to the motor-controlled pump that operates one of Limerick’s water systems to prevent core damage.

  1. NRC said the fire would not have occurred if Exelon had done adequate preventive maintenance
  2. NRC said the accident had the potential to lead to core damage.
  3. However, NRC only cited Exelon with a “green Non-Cited Violation (NCV) of very low safety significance” in the safety inspection report
  4. In public statements released on April 6, 2015, NRC and Exelon gave different accounts of the fire:
    • NRC: the fire was in one of the security buildings
    • Exelon: the fire was in an electrical panel in the reactor building
    • NRC: the Unit 2 reactor was at 82% power, shutting down (for refueling)
    • Exelon: both units were at full power
    • NRC: the High Pressure Coolant Injection (HPCI) system that delivers water to the core was damaged and needed repair
    • Exelon: Limerick’s on-site fire brigade put out the fire within eight minutes


  1.  How does NRC justify that an accident with the potential to lead to core damage is “green and of very low safety significance”?
  2.  Did NRC examine its own actions to see if they contributed to this fire?   On 12-29-14, NRC changed a Unit 2 regulation because Unit 2 couldn’t comply with it. When it became apparent that, despite the change, Unit 2 still couldn’t comply, NRC proposed a send revision. NRC announced its proposal, not in the Federal Register as customary, but in the Mercury Classifieds, 2-16-15, because this was an emergency and if NRC didn’t act quickly, it would have to shut Unit 2 down.
  3. Does NRC see any correlation between its lax regulatory enforcement and Exelon’s pervasive lack of maintenance?


A tank of radioactive water overflowed exposing personnel and the Unit 2 reactor building to a high level of radiation, requiring decontamination of building and personnel

  • During Radioactive Waste Clean Up, an alarm signaled that the level of radioactive water in a tank was high
  • The alarm was ignored and the tank overflowed
  • The overflow backed up the floor drain system and radiation levels rose.
  • The Unit 2 reactor building required decontamination
  • Personnel required decontamination, but one of them tracked radiation around multiple levels of the facility where other people were not required to have radiation-protective clothing.
  • NRC cited Exelon with a “Green, Non Cited Violation (NCV) because this was a violation of very low safety significance” which seems excessively lenient, given the magnitude of the risk.


  1. How long did it take before the two personnel were decontaminated, if one, whose “shoe contamination was 65 mrad/hr,” had time to walk around multiple floors of the facility?
  2. As a result of decontaminating Unit 2, was any radiation released into the Schuylkill River or into the air?
  3. Why did Exelon not initially remedy the potential for overflow, as it did after the accident, instead of instructing personnel to ignore the alarm?



Radiation rose as water covering fuel assemblies accidentally drained out of a dry storage cask

  • On July 7th workers began decontamination and preparation of one of the casks loaded with spent fuel to prepare it for on-site storage.
  • Workers followed instructions to pump 25 gallons of water out of the cask and then stop the pump.
  • Because there was no instruction to close the drain valve after stopping the pump, radioactive water continued to drain out of the cask
  • For 90 minutes, no one noticed the water accumulating on the floor.
  • At about 12:00 a.m. on July 8th, a technician noticed Unit 2’s radiation level rising
  • The technician alerted the floor supervisor, who discovered the radioactive water on the floor.
  • 231 more gallons of radioactive water had drained out of the cask, exposing the upper parts of the spent fuel assemblies to  the air
  • NRC issued a Non-Cited Violation (NCV), stating that Exelon had not followed NRC’s code of Federal Regulations: Exelon did not provide complete procedural instructions


  1. What alerted the RP technician to the rise in the level of radiation?
  2.  Why didn’t any one notice the 231 gallons of water accumulating on the floor for 90 minutes?
  3.  During the unclogging of the drain and decontamination of the building and personnel, was any radiation released into the Schuylkill River or into the air?


Exelon, an electric company, should have had no difficulty immediately restoring all the flashing lights on both Limerick’s cooling towers in 2015, yet Exelon failed to do so.

  • Limerick’s cooling towers are 507 feet high, and FAA considers anything over 200 feet high a height safety hazard without continuously flashing, high-intensity lights, day and night.
  • The only reason Limerick’s cooling tower height was waived as a safety hazard during Limerick construction was the promise that they would have the continuous flashing lights
  • At no time during 2015, were all the cooling tower lights operating at the same time.
  • Limerick is required to have its lights on because it is only about a mile from a public access airport, yet there have been times when there were no lights on at all for as long as 6 months at a time.
  • Lights were out on both towers for at least 24 days around the 2015 Thanksgiving holiday, a time of increased air traffic flow in and out of the airport.
  • On 12-10-15, Exelon announced the “flashing beacon” on top of Unit 2 had been restored to service and that repairs had been completed on 12-2-15 (Mercury)
  • Exelon stated that the problem on Unit 1 was on the top of the tower and repairs were scheduled for Spring refueling.


  1. With the completion of spring refueling, why has Exelon only been able to restore three meager lights on a portion of Unit 1?
  2. Why have the lights been out on Unit 2, after Exelon’s announcement on 12-10-15 that the lights had been restored?
  3. How can it be that Exelon, an electric company, can’t even fix its own lights?


It is beyond negligent for NRC to report, as it did, that Limerick “is moving along on vent installation and other post-Fukushima work we required.”  (Mercury, 3-8-16)

  1. By 2015, Exelon had made a mockery of NRC’s 2012 Post-Fukushima’s safety recommendations by not physically fulfilling any of them.
  2. Despite NRC’s 2012 request for compliance without delay, Exelon’s  2015 report for Limerick  showed that “plans” weren’t even complete by 2015, and some issues will only be in the planning stage by 2019.
  3. Examples of dangerous delays and eliminations of NRC’s 2012 post-Fukushima recommendations as of 2015:
      • Vent installation delay  -  no workable plan for installation as of 2015
      • Elimination of filters from the vent delayed installations despite NRC staff stating, “Vents without filters become radioactive hoses into the sky. Vents are vital, regardless of the cost to the industry.”
      • No installed spent fuel pool instrumentation as of 2015, despite the risk of pool meltdowns
      • No Limerick-specific seismic update as of 2015.
      • Unreasonable delay in seismic “study” until 2019, despite earthquake fault fractures under Limerick’s reactors, fuel pools, control room, turbine building, and rad-waste building.

By 2015, the public had, for three decades, been repeatedly exposed to Limerick’s routine and accidental radiation releases and cooling tower pollution. Exelon failed to:

      • Filter discharges into the Schuylkill River, a vital drinking water source for millions of people
      • Notify the public promptly of increased radiation exposure due to accidents, such as the 15,000 gallons radioactive water into the Schuylkill River on 3-19-12 that was not announced to the public for 23 days
      • Stop using high-burn fuel (up to 30% more radioactive gas releases)
      • Filter Limerick’s massive, toxic cooling tower pollution into the air
      • Clean up water and soil from Limerick’s radioactive spills


  1. Why, after NRC’s 2012 post-Fukushima recommendations, has NRC not required a Limerick-specific seismic study to more protectively prepare Limerick for post-Fukushima safety-related upgrades that could protect the public from Limerick’s increased seismic risks?
  2. Why did NRC allow Exelon to eliminate filters, when without filters, the public is at increased risk for radiation exposure?
  3.  Why did NRC allow the use of high-burn fuel in 2015 at Limerick when increased radiation risks will increase harms to Limerick’s dense population in the Greater Philadelphia region and increases Limerick’s risks associated with Limerick’s on-site-storage of log-lasting, high-level,   radioactive waste?

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


ACE Video / Blog – Part 3

The Truth and Consequences of Radiation Exposure

From Nuclear Plant Accidents / Meltdowns

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Radiation Accident or Meltdown With Expanded Evacuation and Ingestion Pathway Zones

The Nuclear Regulatory Commission (NRC) Has Lost All Credibility


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

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

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

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

Probably Met NRC Safety Goals.

NRC Needs New Standards For Fukushima Type Disasters.

How Can We Believe NRC About Anything?

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

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

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

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

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

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

Flawed MIT Study Is Being Used By NRC

To Dismiss The Need For Nuclear Disaster Evacuations

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

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

MIT Awarded More Than $2 Million in Grants And Fellowships

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

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

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

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

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

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

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

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


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

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

Biased Protocols Included:

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

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

· The time frame was too short (Tanaka paper)

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

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

Independent Research And Evidence Dispel MIT’s Radiation Deception:

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

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

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

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

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

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

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

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

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

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

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


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


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

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

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

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

Radiation Exposure Can Affect The Whole Body

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

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

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

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

There Is No Way to Undo Damaging Effects Of Radiation Exposure

To Minimize Exposure

· Time Limit Exposure

· Distance Between You and Radiation

· Shielding Learn About Best Sheltering Procedures

For Radiation Exposure Summaries See: www.acereport.org

#1 Radiation – Limerick’s Routine Releases

#3 Radiation – No Safe dose

#4 Radiation – Reduce Risk

Over 8 Million People Live Within 50 Miles Of Limerick

How Close Do You Live To Limerick Nuclear Plant?

See Natural Resources Defense Council (NRDC)

Radiation Plume Map www.nrdc.org




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

1. Immediate Public Notification By Exelon and NRC

2. Independent Radiation Monitoring With Electronic

Radiation Alert System

3. A 50-Mile Evacuation Zone

4. A 100-Mile Ingestion Pathway Zone

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

Facts About Fukushima Fallout:

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

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

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

Facts About Chernobyl Fallout:

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

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

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

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

· 45,000 Radiation Sickness Cases (Requiring Hospitalization)

· 3,300 Deaths (From Acute Radiation Sickness)

· 45,000 Fatal Cancers (over 50 years)

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

· 190 Children Born With Birth Defects Per Year

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

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

· 74,000 Early Fatalities

· 610,000 Early Injuries

· 34,000 Cancer Deaths

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

This Population Increase Demands Updated Planning.

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

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

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

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


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

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

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

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

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

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

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

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

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

Bogus Comparisons:

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

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