ML12131A499
| ML12131A499 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 03/11/2013 |
| From: | David Wrona License Renewal Projects Branch 2 |
| To: | Gallagher M Exelon Generation Co |
| Perkins L, 415-2375 | |
| References | |
| Download: ML12131A499 (182) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11,2013 Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
ISSUANCE OF ENVIRONMENTAL SCOPING
SUMMARY
REPORT ASSOCIATED WITH THE STAFF'S REVIEW OF THE APPLICATION BY EXELON GENERATION COMPANY, LLC FOR RENEWAL OF THE OPERATING LICENSE FOR LIMERICK GENERATING STATION, UNITS 1 AND2
Dear Mr. Gallagher:
The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted an environmental scoping process and solicited public comments from August 26 to October 28, 2011. This process determined the scope of the staff's environmental review of the application for renewal of the operating license for Limerick Generating Station, Units 1 and 2 (LGS). The scoping process is the first step in the development of a plant-specific supplement to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS), for LGS.
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As part of the scoping process, the staff held two public meetings in Pottstown, PA on September 22, 2011, to solicit public input regarding the scope of the review: The staff also received written comments by letter, e-mail, and through www.Regulations.gov. At the conclusion of the scoping process, the staff prepared the enclosed environmental scoping summary report identifying comments received during the scoping period. In accordance with Section 51.29(b) of Title 10 of the Code of Federal Regulations ('10 CFR) the staff will send a copy of the scoping summary report to all participants in the seoping process.
The transcripts of the public scoping meetings are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. The transcripts for the afternoon and evening meetings are listed under ADAMS accession numbers ML11287A207 and ML11287A211, respectively. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov.
M. Gallagher
- 2 The draft supplement to the GElS is scheduled to be issued in March 2013. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federal Register. If you have any questions concerning the staff's environmental review of this license renewal application, please contact the Project Manager, Ms. Leslie Perkins, at 301-415-2375 or bye-mail at Leslie.Perkins@nrc.gov.
Sincerely, OJ9c/~
David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-352 and 50-353
Enclosure:
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Environmental Impact Statement Scoping Process Summary Report Limerick Generating Station Pottstown, PA March 2013 u.S. Nuclear Regulatory Commission Rockville, Maryland ENCLOSURE
- 2 Introduction The U.S. Nuclear Regulatory Commission (NRC) received an application from Exelon Generation Company, LLC (Exelon), dated June 22,2011, for renewal of the operating license for Limerick Generating Station, Units 1 and 2 (LGS). LGS is located in Pottstown, PA, about 35 miles from Philadelphia, P A. The purpose of this report is to provide a concise summary of the determinations and conclusions reached, including the significant issues identified, as a result of the scoping process in the NRC staff's environmental review of this license renewal application.
As part of the application, Exelon submitted an environmental report (ER) (Exelon 2011) prepared in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 51, which contains the NRC requirements for implementing the National Environmental Policy Act of 1969 (NEPA). The requirements for preparation and submittal of ERs to the NRC are outlined in 10 CFR 51.53(c)(3).
The requirements in Section 51.53(c)(3) were based upon the findings documented in NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS) (NRC 1996; NRC 1999). In the GElS, the staff identified and evaluated the environmental impacts associated with license renewal. After issuing a draft version of the
. GElS, the NRC staff received and considered input from Federal and State agencies, public organizations, and private citizens before developing the final document. As a result of the assessments in the GElS, a number of impacts were determined to be generic to all nuclear power plants (or, in some cases, to plants having specific characteristics such as a particular type of cooling system). These generic issues were deSignated as "Category 1" impacts. An applicant for license renewal may adopt the conclusions contained in the GElS for Category 1 impacts unless there is new and significant information that may cause the conclusions to differ from those of the GElS. Other impacts that require a site-specific review were designated as "Category 2" impacts and are required to be evaluated in the applicant's ER. The Commission determined that the NRC does not have a role in energy-planning decision making for existing power plants. Therefore, an applicant for license renewal need not provide an analysis of the need for power or the economic costs and benefits of the proposed action. On August 26, 2011, the NRC initiated the scoping process by issuing a Federal Register Notice (76 FR 53498). This notified the public of the staffs intent to prepare a plant-specific supplement to the GElS regarding the application for renewal of the LGS operating licenses. The plant-specific supplement to the GElS is also referred to as the Supplemental Environmental Impact Statement or SEIS. The SEIS will be prepared in accordance with 10 CFR Part 51.
The scoping process provides an opportunity for public participation to identify issues to be addressed in the SEIS and to highlight public concerns and issues. The notice of intent identified the following objectives of the scoping process:
Define the proposed action Determine the scope of the SEIS and identify significant issues to be analyzed in depth Identify and eliminate peripheral issues
- 3 Identify any environmental assessments (EAs) and other environmental impact statements being prepared that are related to the SEIS Identify other environmental review and consultation requirements Indicate the schedule for preparation of the SEIS Identify any cooperating agencies Describe how the SEIS will be prepared The NRC's proposed action is whether to renew the LGS operating licenses for an additional 20 years.
The scope of the SEIS includes an evaluation of the environmental impacts of license renewal and reasonable alternatives to license renewal. The "Scoping Comments and Responses" section of this report includes specific issues identified by the comments. The subsequent NRC responses explain if the issues will be addressed in the SEIS and, if so, where they will likely be addressed.
Throughout the scoping process, the NRC staff identified and eliminated peripheral issues. This report provides responses to comments that were determined to be out of the scope of this review. Those that were considered to be in scope will be evaluated in detail and documented in the appropriate sections of the SEIS for LGS, Units 1 and 2, license renewal.
The NRC staff is required to consult with the National Marine Fisheries Service and U.S. Fish and Wildlife Service under the Magnuson~Stevens Fisheries Conservation and Management Act and Section 7 of the Endangered Species Act in order to evaluate the potential impacts of continued operation on the affected endangered species. In order to fulfill its obligations under the National Historic Preservation Act, the NRC initiated consultation with the Advisory Council on Historic Preservation, and the Pennsylvania State Historic Preservation Office.
- 4 The SEIS will be prepared by NRC staff with contract support from Pacific Northwest National Laboratory.
The NRC invited the applicant; Federal, State and local government agencies; Indian tribal governments; local organizations; and individuals to participate in the scoping process by providing oral comments at the scheduled public meetings or by submitting written comments before the end of the scoping comment period on October 28, 2011. The scoping process included two public meetings which were held on September 22, 2011, at the Sunnybrook Ballroom, 50 North Sunnybrook Road, Pottstown, PA 19464-2946. The NRC issued press releases, purchased newspaper advertisements, emailed information to State and local government agencies and delegates, and distributed flyers locally to advertise these meetings.
Approximately 100 people attended the meetings. Each session began with NRC staff members providing a brief overview of the license renewal process and the NEPA environmental review process. Following the NRC's prepared statements, the floor was opened for public comments. Twenty-four attendees provided oral comments that were recorded and transcribed by a certified court reporter. Transcripts of the entire meeting are available using the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html.
Transcripts for the afternoon and evening meetings are available in ADAMS under Accession Nos. ML11287A207 and ML11287A211, respectively (NRC 2011 a, NRC 2011 b) The NRC issued a summary of the scoping meetings on September 22, 2011 (NRC 2011 c).
All documents associated with this scoping process are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or in ADAMS. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR Reference staff by telephone at 1-800-397-4209 or 301-415-4737 or bye-mail at pdr.resource@nrc.gov. The ADAMS accession number for each document is listed below in Table 1.
In addition to the comments received at the meetings, the NRC also received 20 letters and 21 e-mails with comments about the review. At the conclusion of the scoping period, the NRC staff reviewed the transcripts, meeting notes, and all written material received in order to identify individual comments. Figure 1 explains how the comments are labeled.
Figure 1. Key to Identifiers "My name is John Doe(a) and this comment relates }
to alternative energy sources.
I would also like to discuss my comments that
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relate to Aquatic Resources... "
"My name is Jane Doe and my comment relates to Aquatic Resources.. "
}
2 -1 _AQ(d)
(a) commenter name identified in Table 1.
(b) commenter ID specified in Table 1.
(c) sequential comment number (d) technical category, presented in Table 2 and Table 3.
Table 1 identifies the individuals providing comments and the assigned Commenter ID. For oral comments, the individuals are listed in the order in which they spoke at the public meeting.
- 5 Table 1 also includes the accession numbers of each source of comments in order to locate the original reference in the NRC's ADAMS.
Comments were consolidated and categorized according to the topic within the proposed SEIS or according to the general topic if outside the scope of the GElS. Comments were placed into 1 of 17 technical issue categories, which are based on the topics that will be contained within the staff's SEIS for LGS, as outlined by the GElS. These technical issue categories and their abbreviation codes are presented in Table 2.
Once comments were grouped according to subject area, the NRC staff determined the appropriate action for the comment. The action or resolution for each comment is described in the NRC staff's responses in this report. Table 3 represents the location where the response to each technical category begins. In those cases where no new environmental information was provided by the commenter, a brief response has been provided to the comment and no further evaluation will be performed.
Table 1. Individuals Providing Comments During The Scoping Comment Period Each commenter is identified along with their affiliation and how their comment was submitted.
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';:<;,<::;;~~Hmll<er.". J Dr. Lewis Cuthbert Alliance for a Clean Environment 1
Afternoon scoping meeting Evening scoping meeting ML11287A207 ML11287A211 ML11354A392 Letters Ml11036A244 ML11036A245 Bill Maguire Limerick Site Vice President, Exelon 2
Afternoon scoping meeting ML11287A207 Evening scoping meeting I\\.I1L11287 A211 State Representative Representative Tom Afternoon ML11287A207 3
Quigley scoping meeting Afternoon scoping meeting ML11287A207 Lorraine Ruppe Resident 4
Evening scoping meeting ML11287A211 Letter ML11308B354
- 6 Mike Gallagher Vice President for License Renewal, Exelon 5
Afternoon seoping meeting ML11287A207 Evening seoping meeting ML11287A211 Dr. Fred Winter Resident 6
Afternoon seoping meeting ML11287A207 Evening seoping meeting ML11287A211 Letter ML11305A016 Afternoon Thomas Neafey Resident 7
ML11287A207 seoping meeting Afternoon Dr. Anita Baly Resident ML11287A207 8
seoping meeting Letter ML11035A010 Schuylkill River Heritage Afternoon Tim Fenehel 9
ML11287A207 Area seoping meeting Afternoon Bill Vogel Resident 10 ML11287A207 seoping meeting Tri-County Area Chamber Afternoon Eileen Dautrieh 11 ML11287A207 of Commerce seoping meeting Afternoon Billy Albany Resident 12 ML11287A207 seoping meeting Jaeeo/Gas Afternoon John McGowen 13 ML11287A207 Breaker/UMAC, Inc.
seoping meeting Afternoon Ted Del Gaizo Resident 14 ML11287A207 seoping meeting Afternoon Tim Phelps Resident 15 ML11287A207 seoping meeting Evening seoping Thomas Saporito Saporito-Associates 16 meeting ML11287A207 Evening seoping Jeff Chomnuk Resident 17 ML11287A207 meeting
- 7
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Evening scoping ML11287A207 Daniel Ludwig Resident 18 meeting Evening scoping Catherine Allison 19 IVIL11287 A207 meeting Pennsylvania Energy Evening scoping Jeffrey Norton 20 IVIL11287 A207 Alliance meeting Evening scoping Dan Ely Resident 21 ML11287A207 meeting Evening scoping Jay Beckermen Resident 22 ML11287A207 meeting Pottstown Energy Evening scoping Jim Der 23 ML11287A207 Advisory Committee meeting Evening scoping Traci Confer Energy Justice Network 24 ML11287A207 meeting Camilla Lange 25 Email ML11279A107 Eric Hamell 26 Email ML11279A108 Steven Furber 27 Email ML11279A109 Charlene Padworny 28 Letter ML11279A110 Sylvia Polluck 29 Letter ML11279A111 Email ML11290A106 Joe Roberto 30 Email ML11279A112 Delaware Tribe Historic Brice Obermeyer 31 Letter ML11279A113 Preservation Office Stockbridge-Munsee Sherry White Tribal Historic 32 Letter ML11279A114 Preservation Office Unknown 33 Letter ML11286A298 Richard Kolsch Resident 34 Email ML11286A299 Charles and Resident 35 Letter ML11286A300 Elizabeth Shank Nancy Leaming Resident 36 Email IVIL11290A 102
- 8
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Cynthia Gale Resident 37 Email ML11290A103 Jude Schwegel 38 Email ML11290A104 Michael Gale Resident 39 Email IViL11290A 105 Melissa Antrim Resident 40 Email ML11291A155 Michael Antrim Resident 41 Email ML11291A156 Joan McGone 42 Email ML11292A011 Mary Lou and Resident 43 Letter ML11294A208 Harold Smith Lisa Smoyer 44 Email ML11300A011 Unknown 45 Letter ML11300A012 Lori Molinari Resident 46 Letter ML11305A072 Doris Meyers Resident 47 Email ML11305A014 Ken Sekellick Resident 48 Email ML11305A015 Anthony Gonyea Onondaga Nation 49 Letter ML11305A006 Debby Penrod Resident 50 Email ML11305A007 Charlie Koeing Resident 51 Email ML11305A008 Joyce Webber Resident 52 Email ML11305A009 Charlotte Derr Resident 53 Letter ML11307A388 Montgomery County Michael Stokes 54 Letter ML11307A387 Planning Commission Montgomery County Thomas Sullivan Department of Public 55 Letter ML11307A386 Safety Natural Resources 56 Letter ML11307A456 Defense Council Sharon Yohn 57 Email ML11307A455 Michael Smokowicz 58 Email ML11307A454 Barbara Miller Resident 59 Letter ML11311A063 Debra Schneider Resident 60 Letter ML11313A013
- 9 Table 2. Technical Issue Categories. Comments were divided into one of the 16 categories below, each of which has a unique abbreviation code.
- ~
AL Alternative Energy Sources AM Air & Meteorology DC Decommissioning GE Geology GW Groundwater HA Historic & Archaeological HH Human Health LU Land Use License Renewal and its LR Process Opposition to License Renewal Outside of Scope(a)
Postulated Accidents & Severe PA Accident Mitigation Analyses (SAMA)
Radioactive & Non-Radioactive RW Waste SE Socioeconomics SR Support of License Renewal SW Surface Water (al Outside of Scope are those comments that pertain to issues that are not evaluated during the environmental review of license renewal and include, but are not limited to, issues such as need for power, emergency preparedness, safety, security, and terrorism.
Table 3. Comment Response Location in Order of Resource Area Alternative Energy Sources Air & Meteorology Decommissioning Geology Groundwater Historic and Archaeological Human Health Land Use License Renewal and its Process 11 11 12 12 12 12 13 13 13 Opposition to License Renewal 14 Outside of Scope 14 Postulated Accidents & SAMA 31 Radioactive & Non-Radioactive 31 Waste Socioeconomics 31 Support of License Renewal 32 Surface Water 32
- 10 The comments and suggestions received as part of the scoping process are documented in this section, and the disposition of each comment is discussed. The meeting transcripts and written comments are included in their original form at the end of this report. In those cases where no new environmental information was provided by the com menter, a brief response has been provided to the comment, and no further evaluation will be performed.
The preparation of the SEIS will take into account all the relevant issues raised during the scoping process. The SEIS will address both Category 1 and 2 issues, along with any new information identified as a result of the scoping process. The SEIS will rely on conclusions supported by information in the GElS for Category 1 issues and will include analysis of Category 2 issues and any new and significant information. The NRC will issue a draft SEIS for public comment. The comment period will offer the next opportunity for the applicant, interested Federal, State, and local government agencies, Indian tribal governments, local organizations, and other members of the public to provide input to the NRC's environmental review process.
The comments received on the draft SEIS will be considered in the preparation of the final SEIS. The final SEIS, along with the staffs safety evaluation report (SER), will provide much of the basis for the NRC's decision on the Exelon application to renew or not renew the licenses for LGS.
- 11 Limerick Generating Station Scoping Comments and Responses
- 1. Alternative Energy Sources (AL)
Comment: The following comments have been categorized under the resource area of Alternative Energy Sources. The comments express opposition to nuclear power, cite renewable energy solutions such as wind, solar, geothermal, and/or the alternative of not renewing the operating license, also known as the "no-action" alternative.
Identifiers: 1-44-AL, 4-8-AL, 5-3-AL, 16-7 -AL, 25-5-AL, 27 AL, 28-2-AL, 29-1-AL, 35-6-AL, 37 AL, 39-16-AL, 44-5-AL, 44-1 O-AL, 44-12-AL, 53-2-AL, 60-3-AL, 60-19-AL Response: The staff will evaluate all reasonable alternatives, including the no-action alternative in Chapter 8 of the SEIS. In this chapter, the NRC staff examines the potential environmental impacts of alternatives to license renewal for LGS, as well as alternatives that may reduce or avoid adverse environmental impacts from license renewal, when and where these alternatives are applicable.
In evaluating alternatives to license renewal, the NRC staff first selects energy technologies or options currently in commercial operation, as well as some technologies not currently in commercial operation but likely to be commercially available by the time the current LGS's operating licenses expire in 2024 and 2029.
Second, the NRC staff screens the alternatives to remove those that cannot meet future system needs. Then, the remaining options are screened to remove those whose costs or benefits do not justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, constitute alternatives to the proposed action that the NRC staff evaluates in-depth throughout Chapter 8. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 2. Air & Meteorology (AM)
Comment: The following comments have been categorized under the resource area of Air and Meteorology. These comments express opposition to LGS on the basis of increased air pollution and severe weather.
Identifiers: 1-16-AM, 1-22-AM, 1-32-AM, 35-3-AM, 37-2-AM, 39-3-AM, 60-8-AM Response: The staff will address air quality and cumulative impacts associated with greenhouse gases and other emissions in Chapters 2 and 4 of the draft SEIS. Greenhouse gas emissions of the nuclear fuel cycle will be discussed in Chapter 6. Finally, the environmental impacts of the alternatives evaluated in depth will be discussed in Chapter 8, including air emissions. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 12
- 3. Decommissioning (DC)
Comment: The following comment has been categorized under the area decommissioning.
The comment addresses a concern regarding approving a closure plan for LGS prior to granting an extended license for LGS.
Identifiers: 34-2-DC Response: The staff will address the impacts of decommissioning LGS in Chapter 7 of the SEIS. Additionally, the environmental impacts of the no-action alternative will be discussed in Chapter 8 ofthe draft SEIS. This comment is in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 4. Geology (GE)
Comment: The following comments have been categorized under the resource area of geology. These comments address concerns regarding LGS being located near a fault line.
Identifiers: 1-12-GE, 4-2-GE, 4-14-GE, 30-2-GE, S1-4-GE, S2-S-GE, 60-2-GE
'Response: The staff will address the current geologic environment for LGS in Chapter 2 of the draft SEIS. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 5. Groundwater (GW)
Comment: The following comments have been categorized under the resource area of groundwater. The comments express concern over groundwater contamination.
Identifiers: 1-34-GW, 37-4-GW, 37-S-GW, 39-S-GW, 39-6-GW, 4S-10-GW Response: The staff will address the groundwater impacts ofrenewing the LGS's operating licenses in Chapters 2 and 4 of the draft SEIS. In addition, the groundwater impacts of not renewing the operating licenses will be discussed in Chapter 8 of the draft SEIS.
These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 6. Historical and Archaeological (HA)
Comment: These comments have been categorized under the resource area of historical and archaeological. These comments identify whether or not historical and archeological sites are located near LGS.
Identifiers: 31-1-HA,49-1-HA Response: The staff will address the historical and archaeological impacts ofrenewing the LGS's operating licenses in Chapters 2 and 4 of the draft SEIS. Finally, the environmental impacts of alternatives evaluated in depth will be discussed in Chapter 8 of the SEIS. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 13
- 7. Human Health (HH)
Comment: The following comments have been categorized under the resource area of Human Health. The comments describe health risks, such as cancer or mortality rates, related to operations at nuclear plants and/or LGS.
Identifiers: 1-15-HH, 1-1S-HH, 1-25-HH, 1-26-HH, 1-36-HH, 4-6-HH, 4-7-HH, 6-1-HH, 6-2-HH, 6-6-HH, 6-S-HH, 19-6-HH, 21-1-HH, 25-2-HH, 36-1-HH, 36-3-HH, 37-1-HH, 37-7-HH, 37-14-HH, 39-2-HH, 39-15-HH, 40-4-HH, 40-5-HH, 41-3-HH, 42-2-HH, 43-6-HH, 44-S-HH, 44-9-HH, 45-6 HH. 45-6-HH, 45-7-HH, 45-S-HH, 47-2-HH, 4S-2-HH, 51-3-HH, 52-6HH, 57-3-HH, 5S-1-HH, 60 10-HH,60-14-HH
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Response: The staff will address the human health impacts of renewing the LGS operating licenses in Chapters 2 and 4 of the draft SEIS. In addition, the environmental impacts of alternatives evaluated in depth will b,~ discussed in Chapter 8 of the SEIS, including human health impacts. These comments able in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 8. Land Use (LU)
Comment: The following comments have been categorized under the resource area of land use.
Identifiers: 54-5-LU Response: The staff will address the land use impacts of renewing the LGS's operating licenses in Chapters 2 and 4 of the draft SEIS. In addition, the land use impacts of not renewing the operating licenses. will be discussed in Chapter 8. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 9. License Renewal and its Process (LR)
Comment: The following comments have been categorized under License Renewal and its Process. The comments express opposition to the process. These comments also refer to the advertisement, quantity, and location of the public meetings.
Identifiers: 1-4-LR, 1-19-LR, 4-9-LR, 3-1-LR, 4-13-LR, S-1-LR, S-5-LR, 16-2-LR, 16-3-LR, 16 4-LR, 19-4-LR22-1-LR, 22-3-LR, 25-1-LR, 30-1-LR, 30-13-LR, 34-1-LR, 41-1-LR, 4S-3-LR, 54 7-LR, 56-2-LR60-5-LR, 60-13-LR, 60-20-LR Response: These comments refer to the license renewal process. A summary of the license renewal process is provided in Chapter 1 of the draft SEIS. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
-14
- 10. Opposition to License Renewal (OR)
Comment: The following comments have been categorized under the area of Opposition to License Renewal. The following comments are general in nature and express opposition to nuclear power and/or the license renewal of LGS.
Identifiers: 1-5-0R, 1-20-0R, 1-21-0R, 1-29-30, 6-5-0R, 6-9-0R, 6-11-0R, 10-1-0R, 19-3 OR, 25-4-0R, 26-1-0R, 27-2-0R, 28-1-0R, 29-2-0R, 30-10-0R, 35-1-0R, 35-7-0R, 38-1-0R, 40-1-0R, 40-6-0R, 41-4-0R, 42-3-0R, 43-1-0R, 44-1-0R, 44-4-0R, 44-11-0R, 45-1-0R, 45 11-0R, 46-1-0R, 48-1-0R, 52-1-0R, 52-1-0R, 53-1-0R, 57-1-0R Response: These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 11. Outside of Scope (OS)
The following comments were determined to be outside of scope of the environmental review.
Except where noted, comments are represented below as direct quotes; however, original formatting from source documents may not be completely met, as comments have been received in several different media.
Comment: 1-2-0S; There is no way for either NRC or Exelon to ensure the safety of the environment or the residents impacted by this plant. It cannot be made fail safe.
Comment: 1-7-OS; After only 26 of 40 years, numerous signs of aging and risk have been identified. Corrosion, deterioration, fatigue, cracking, thinning with loss of material, loss of fracture toughness are all documented in Exelon's own renewal application in the aging management section. Instances of equipment fatigue and cracking of vital equipment include the reactor vessel and coolant system.
Comment: 1-8-0S; Aging equipment, after only 26 years suggests that NRC should not just close the plant by 2029, but also ramp up their oversight vigilance during the remaining 18 years of the current license.
Comment: 1-9-OS; In the past few years, Limerick has had numerous unplanned shutdowns suggesting there are already significant problems. Three occurred in one week in June 2011.
Loss of coolant leaks and accidents at Limerick have already been documented. Serious radioactive contamination could go undetected and unreported for years from the corroding infrastructure, much of it underground.
Comment: 1-39-0S;... accidents and leaks from corroding, deteriorating equipment plus miles of buried pipes and cables. Many problems and shutdowns have already occurred at this facility in its first 26 years of operation. They are a matter of record.
Comment: 4-11-OS; And the one thing that's really important is that NRC and the nuclear industry are claiming that age is no issue while at the same time they admit that some parts are too big and too expensive to replace.
-15 Comment: 5-2-05; There are two different parts of our application, the safety review and the environmental review. For the safety review, we took an in-depth look at the history and the condition of the safety equipment in the plant. We did that to determine whether the necessary maintenance was being performed on that equipment and to make sure that the equipment will be able to operate when it's needed, not only for today, but also for an additional 20 years of operation. When you look back at Limerick, when it was built, all the equipment was new. It was thoroughly tested to make sure it would perform properly, but like anything else equipment does age. That doesn't mean it won't work, but it does age and certain activities need to be done to the equipment. So we perform preventive maintenance. Sometimes we refurbish the equipment. Some equipment is replaced. There may be modifications done to upgrade the equipment in the plant and in fact, as Bill Maguire has stated, Limerick had spent over $200 million in the last couple years alone to improve and modernize the equipment and enhance plant operations and safety. We also then reviewed calculations that were performed as part of the original design of the plant that were done to ensure that the plant could operate safely for 40 years. We analyzed those calculations and were able to confirm that the plant would be able to operate safely for 60 years. Overall, our conclusion from our engineering review was that Limerick could operate safely for up to 60 years.
Comment: 16-5-05; And with respect to the NRC's environmental review, the NRC in my view failed to properly consider the embrittlement of this nuclear reactor vessel. When these nuclear reactors are operating the neutrons cause the metal in the reactor vessel to become brittle over time. And after numerous years of operation these reactor vessels could crack because they're so brittle. But the NRC doesn't properly evaluate that and the NRC doesn't require the licensee to do destructive testing and analysis of the reactor's metal vessel prior to rubber-stamping a 20-year extension to these licenses. Twenty years from now, oh actually 20 years from 2024 which will be 2044 this reactor is going to be even more critically brittle and the NRC's not going to understand the dynamics of that and the reactor could crack and it's going to melt down because you can't recover from a loss of coolant accident of that magnitude.
Comment: 21-1-05; My concern is that this hastened license renewal process is inappropriate for engineering reasons. I worked in a variety of different areas in the construction of that power plant and there were continual deviations that were provided, whether it was in-storage maintenance monitoring of the condition of the components that were used to the actual construction of that plant. I could cite you several examples. What I would like to ask of the public is that the people that had worked at that nuclear power plant take a look at this licensing renewal and understand that they need to review those failures and those deviations that were provided to go ahead with the construction of that plant with non-conformances that were reviewed, but not reviewed in light of what we understand and know today about earthquakes or other anomalies. We need to have enough time to make the evaluation on those deviations.
The cooling pools. The fuel pool girders that are placed there. There are rebar concrete reinforced supports where a quality engineer, he was supposed to be accepting the very highest grade of concrete to be placed in a 36-8 hour pour there and he didn't pay attention. And the coffer dam was being built down in the river and up comes this sand mix with a very low strength and gets pumped up into those fuel pool girders in a layer and the engineer said well, boy, that was a terrible mistake, but it'll be okay. We need to go back and take a look at all of those mistakes and make sure that they're not written off because a layer in a structure under load caused by an earthquake, that's an issue. It might not be an issue for the strength of the fuel pool girders to support those fuel pools that when we see them in Japan and they catch fire because they're extremely hot and you need to address that. I was on that pour but I wasn't the
- 16 engineer that made that error, but there's a number of errors that were made. And I don't see or understand that the NRC or the review or the licensing application taking a look at those failures and those errors and addressing them in light of the knowledge that we have today.
Comment: 22-7-OS; And I would like to finally address an isSue that the speaker on the cell phone brought up. He talked about embrittlement of concrete over the lifetime so far of the nuclear reactor containment vessel. That's an internal environmental matter. I don't know if it's quite in the scope of what the NRC plans to talk about or plans to look at, but something that I have not read about at all is an NRC requirement for destructive testing.
Comment: 22-8-0S; What I haven't heard anything about except generalizations is has anybody done any destructive even borehole testing of these containment vessels and their support pourings to find out has there been in fact any deterioration of the concrete, the rebar and anything else that went in there. The stuff that's buried in the concrete, the wire, all of those things that are buried in the concrete. If you haven't bothered to open that stuff up since the plant was built how on earth do you know what condition it's in? Shouldn't that be a requirement to do some destructive, open the bottom testing, go all the way through and make sure what you think is there is what's there and in the condition that it should be in to last for another 20 or 40 years?
Comment: 25-3-0S;... it seems to me that the situation of unprotected above ground cask holding radioactive waste, as well as past safety failures and deviations in operations must be reviewed and addressed.
Comment: 30-6-0S; There are many other environmental friendly sources of energy and Limerick is anything but that. As a matter of fact, Limerick is a TIME BOMB, placed at the wrong location, on the wrong land, too close to major populations, run by a for profit company who cannot even handle the basic maintenance issues of power lines, in an aged building without the newest technology nor able to stand a real earthquake, and on and on.
Comment: 30-9-0S; Lastly, some who have a vested interest in working at the plant, etc. are quick to state that it is safe, etc. - not now, nor has it ever been fool proof against disasters, technical glitches, etc.
Comment: 30-12-OS; Why was Limerick taken "offline" three times in as many months? Is NRC checking?
Comment: 37-10-0S, 39-11-0S; Accidents and leaks from corroding, deteriorating equipment plus miles of buried pipes and cables.
Comment: 38-2-0S; I'm worried about Exelon Generation Co., LLC's safety record and I hope you will consider my opinion on this matter.
Comment: 40-2-OS; Limerick was built to last 40 years. The older any facility gets, the more likely breakdowns and equipment failure will occur. When it's a nuclear power plant. meltdown could result from corroding, deteriorating, and aging pipes, cables, and equipment - honestly, a number of things. Miles of deteriorating underground buried pipes and cables are a major concern - [and how] often are these inspected? Signs of mechanical damage and breakdown already exist - three unplanned shutdowns June 2011, preceded by many others since 2007,
- 17 one with loss of cooling water. While some parts can be replaced, by the nuclear industry's own admission, some equipment is too big and expensive to replace. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is up. To add 20 more years to that, without having a clue as to what the condition will be, would be beyond careless.
Comment: 42-1-05; Statistics regarding nuclear accidents at similar aging structures are well documented. Those two towers are ticking time bombs and the NRC knows this and needs to shut them down. Following the Japanese nuclear disaster our Limerick nuclear plant hit the statistical at risk list again.
Comment: 44-2-05; There is no "independent" testing being done at Limerick. The results of testing are provided by their own company, who has a vested interest in the outcome of those results, so how could you ever believe that they would be honest about the results? Seriously??
Comment: 44-7-05; There should also be a concern for accidents and leaks from corroding and deteriorating equipment at the site from over the years which could cause parts of it to be shut down for periods of time, as well as the miles of buried pipes and cables. There are many concerns that should be fully looked at and considered, and just with minimal thought to them, it shouldn't take a "rocket scientists" so to speak to figure out that it is not in the best interest of the public or environment to allow them to re-license.
Comment: 45-3-05; Everything has a life expectancy. Limerick's was 40 years. The older any facility gets,the more likely mechanical*breakdowns and equipment failure will occur. When it's a nuclear plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and equipment. Miles of difficult to inspect corroding, deteriorating underground buried pipes and cables are a major concern. Signs of mechanical damage and breakdown already exist - three unplanned shutdowns June 2011, preceded by many others since 2007, one with loss of cooling water. While some parts can be replaced, by the nuclear industry's own admission, some equipment is too big and expensive to replace.
Comment: 46-2-05; If this license renewal is granted, this plant will continue operating until 2049, at which time it will be over 60 years old. Cracks in concrete and corrosion in piping will inevitably develop as this facility ages. While some of this "wear and tear" may be evident to visual inspection, some of it will also occur in less accessible places, such as in underground piping systems. The Associated Press has shown that tritium leaks in underground piping systems frequently go undetected-sometimes for years-in aging nuclear power plants. While no leaks of this kind have so far been documented at Limerick, the odds of these sorts of problems developing will only increase with every successive decade of the plant's working life.
Comment: 51-2-05; Relicense should not be permitted because all kinds of deterioration has occurred and is occurring and the present licenses do not run out until 2024 and 2029. They are doing this now because they know it would not pass if they waited for 2024 and 2029. This is an old plant and there is much corrosion and concrete deterioration that is going on. There are many miles of buried pipes that cannot [be] checked reliably.
Comment: 52-2-05; The Limerick plant was built to be used for 25 years. It has now gone far beyond its limitations.
- 18 Comment: 55-1-0S; The NRC should provide a full review of environmental and public safety issues pertaining to the plant. It is understood that emergency responders providing services to the power plant understand the hazards associated with daily operations of the plant. However, in light of events in Japan and recent seismic activity in this area, the NRC should clarify the risks associated with plant operations in times of unusual activity, outage operations, and during times of natural/man-made events that may pose a risk to the plant in terms that the public will understand in an attempt to quell public concern.
Comment: 60-7-0S; Deterioration of cement and rebar-crumbles over time.
Comment: 60-12-0S; Go back and look at structural errors when plant was being built.
Comment: 60-16-OS; Accidents and leaks-many shut downs and risk of meltdown, earthquakes, hurricane, aging equipment.
Response: These comments discuss issues related to NRC's safety review of the license renewal application as well as issues related to other safety concerns and past safety performance at LGS.
The NRC's environmental review is confined to environmental matters relevant to the extended period of operation requested by the applicant. The regulations governing the environmental review are contained in Title 10 ofthe Code of Federal Regulation (10 CFR) Part 51, and the regulations for the safety review are contained in 10 CFR Part 54. Because the two reviews are separate, operational safety issues and safety issues related to aging are outside the scope for the environmental review.
The principal safety concerns associated with license renewal are related to the aging of structures, systems, and components important to the continued safe operation of the facility.
When the plants were designed, certain assumptions were made about the length of time each pfant would be operated. During the safety review for license renewal, the NRC must determine whether aging effects will be adequately managed so the original design assumptions will continue to be valid throughout the period of extended operation, or verify that any aging effects will be adequately managed. For a/l aspectsof operation, there are existing regulatory requirements governing a plant that offer reasonable assurance of adequate protection if its license were renewed.
The NRC assesses plant performance continuously and communicates its assessment ofplant performance in letters to the licensees. These assessment letters are available on a plant performance page for each plant, and are posted on the web site as they become available.
The NRC assessment reports for LGS can be access at http://www.nrc.qovINRRlOVERSIGHTIASSESSIUM1I1im1chart.htmland http://www.nrc.qovINRRlOVERSIGHTIASSESSIUM2IIim2chart.html.
Therefore, these comments are not within the scope of the environmental review and will not be evaluated further in the development of the SEIS.
Comment: 1-42-0S;..one that I think probably should jump to the head of the list for the NRC based on a lot of comments from a lot of other analysts and elected officials, the need for an updated evacuation plan and increased emergency planning zone (EPZ), a 10-mile radius. This
- 19 plan is seriously outdated. It is by many expert's observations fatally flawed. There will be no evacuation in the event of a worst case scenario. Several people spoke to that this evening. The population in this area has increased more than 180 percent since 1980 to 2010, U.S. Census data. Updates are obviously needed and they should be reasonable, comprehensive, detailed and accommodate all of the demographics from 1985 to today and from today until as far out as the NRC is willing to license this facility.
Comment: 8-2-05; As we look around, we see that the population in this area is getting denser all the time. The roads are not being improved. And that leaves me with concerns about how we would effect an evacuation were one needed. I suspect strongly that we couldn't perform a good evacuation today. And I also suspect that the population will be increasing and the roads deteriorating. In fact, just this morning in the Pottstown Mercu!)', they were reporting on the hearing that was held on Route 422 which is our main road around here. And Barry Seymour is quoted, he's the Executive Director of the Delaware River Valley Regional Planning Commission, and he told last week's forum audience that population projections anticipate a 50 percent increase in the region and if we don't increase capacity on 422, we will have virtual gridlock all the way to the Berks County line.
Comment: 16-6-05; The other point is the NRC's Commission over there in Rockville, in the White Flint Building, they recently adopted a new policy with respect to evacuations. They want these licensees to update their evacuation plans. Now, I would hope that the NRC staff has made that requirement to the Limerick licensee so that the people near and around within 15 miles of the nuclear plant can properly and timely evacuate the area. Again, the Associated Press's investigation, year-long investigation shows that the populations around these nuclear plants increased tenfold over the years and that the roads and the congestion, you can't timely evacuate these areas. And the NRC keeps pushing these evacuation plans onto the licensee but the NRC doesn't enforce its regulation or properly review if these plans are even effective.
Comment: 19-2-05; Talk about evacuation when these natural disasters and realities hit us.
One accident, two hour backup, almost no exaggeration, one thousand cars. There will be no evacuation. I don't want to be like scare tactics here but like I said, the weather and so forth, natural disasters has really been hitting the whole United States and the world lately so it's a reality.
There was flooding after the hurricane that We just had. Five days later there was roads closed in Pottstown, in North Coventry, East Coventry. There were, when I tried to get home from work right on Route 724, no exaggeration again from all the back roads about 500 cars. There will be no evacuation and I certainly hope that people understand I'm not trying to be scare tactics. I see this. I'm sure a lot of you have seen this and been in these situations. All with a little bit of flooding. What this does to the roads. Again, there will be no evacuation.
Comment: 22-5-05; The environment in which this plant operates has changed because of in-migration, population increase for all sorts of reasons. Part of that's been discussed tonight in terms of evacuation routes, would you be able to get people out were there an accident. The roads haven't changed very much, the population has. That I think is a valid environmental concern that surely ought to be addressed.
Comment: 23-2-05; The emergency planning is an area which needs to be seriously looked at.
Hard and soft infrastructure on that. Hopefully that's something which is part of the ongoing
- 20 operational requirements for periodic review and update since obviously this is not a static environment we live in. That has to be changed on an ongoing basis.
Comment: 30"3-08; The NRC had NO business allowing this plant to ever be built a) so close to such populated areas like Philadelphia (now, what the 3 largest city in the country?) within less than an hour, and exactly due SE from the site.
Comment: 30-4-08; When Limerick was built, there was no idea that the area would grow in population like it has. For safety reasons, just look on any given day the traffic on Route 422 -.
stacked and stuck for miles on end. Route 422 is the #1 route for evacuations and does not handle regular commuter traffic let alone entire communities.
Comment: 34-5-08; Developers are required to fund traffic improvements to an area to allow an area to be developed, this should apply to Limerick. The evacuation plan now will not work.
When the plant was started there was no traffic out here, now it is grid lock. Limerick should fund new roads and bridge[s] to alleviate traffic jams in order to have an orderly evacuation.
Comment: 37-13-08, 39-14-08; Need for updated evacuation plan and increased EPZ.
Comment: 40-3-08; Over eight million people live within 50 miles of Limerick Nuclear Plant.
Safe evacuation is not possible, even within the seriously flawed and inadequate current 10-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation plan (to 50 miles) and be sure there are enough shelters and supplies available to accommodate the over 8 million people within that radius. Exelon should pay for the supplies.
Comment: 41-2-08; Earthquakes and other natural disasters are more frequent and stronger than ever before. Limerick is 3rd on the earthquake risk list. Underground pipes and cables can shake and break, which would lead to loss of power, loss of cooling water, and meltdown.
Limerick's substandard containment flaw means more radiation would ~e released. It is simply too dangerous to keep Limerick operating. Would you want to live within miles of this potential catastrophic disaster? Add the enormous population growth that this area has seen over the past 10 years - with little to no road improvements - and attempting to evacuate the area during a disaster would be futile. It would be virtually impossible to get out of harms way.
The older any facility gets, the more likely breakdowns and equipment failure will occur.
Limerick was built to last 40 years. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is up. To add 20 more years to that, without possibly knowing what the condition will be, would be careless. No one can predict what the condition of Limerick will be in 2024 or 2029. Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not an option. Plain and simple. That's a scary thought for those of us who live here!!
Comment: 45-5-06; No NRC policy, review, or report can make Limerick failsafe from a catastrophic meltdown. Over eight million people live within 50 miles of Limerick Nuclear Plant.
Safe evacuation is merely an illusion, even within the seriously flawed and fundamentally inadequate current 10-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation plan (minimally to 50 miles) and be sure there are enough shelters and supplies available to accommodate the over 8 million people within the 50 miles. Exelon should pay for the supplies.
- 21 Comment: 46-5-05; Questions about the Limerick reactors' ability to withstand accidents and natural disasters are all the more pressing because so many people could potentially be affected if something catastrophic were to occur. Since 1990, the population within a [10]-mile radius of the plant has increased by 45%, from 178,047 to 257.625. In addition. Philadelphia, with a population of 1,526,006, is only about 28 miles away. How much more might these populations increase by 2049? Bearing in mind that the NRC advised Americans within a 50 mile radius of Fukushima to evacuate last spring. one can only imagine how difficult it would be to carry out such evacuations if the unthinkable were ever to occur at Limerick.
Comment: 51-1-05; They are only doing it because the plant has issues that they are trying to hide. The evacuation plan is a joke because we would not get out of our driveways. It would not have worked 10 years ago and certainly with the population growth it would be much worse.
Comment: 52-4-05; The roads to any safe place are overwhelmed with congestion with normal traffic.
Comment: 54-2-05; Since the original plant was constructed, the population in the surrounding communities has grown dramatically. Limerick Township and nearby Upper Providence Township have been two of the most rapidly growing communities in the county. This growth largely fueled by access to US Route 422 Expressway and available land with suitable infrastructure. has dramatically changed the character of the area surrounding the Limerick Power Station. In the past few years, the Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the adjoining Costco shopping center opened along US Route 422 about one mile north of the Limerick Power Station property. The land adjoining those facilities is being, considered for various types of retail and residential uses. At one time, a large gambling casino had been, proposed in this location as well. Other lands in Lower Pottsgrove Township near the Limerick Power Station have also been proposed for similar types of uses.
While the county planning commission has tried to promote lower densities of growth in proximity to the Limerick Plant, the local communities and the marketplace favor this location for significant development due to its proximity to the US Route 422 interchange at Township Linel Evergreen Road. The growth that has taken place in the area around the power plant, and in particular the growth taking place in the area immediately adjoining the plant and the primary access to it, as well as the projected growth in the future, could complicate evacuation plans and the movement of appropriate emergency-response personnel to the plant in the event of a disaster. Certainly this access could be even more critical in the event of a natural disaster when other roads to the plant may be impassable. The environmental assessment review needs to analyze this growth in the vicinity of the power plant to evaluate what impact it would have on plant operations and whether or not safe evacuation can take place from the newly developed areas.
Comment: 54-3-05; The growth in the whole US Route 422 Corridor has raised numerous proposals for expanding the vehicle capacity of the 422 expressway. Current peak commuting traffic tie ups on portions of the expressway serve as evidence that it may have inadequate capacity to continue to serve as a safe evacuation corridor for the region. The county transportation plan recognizes the need for various road improvements along the US 422 Corridor to address current and future traffic demands. The first priority projects in the plan include interchange improvements at the Township Line Roadl Evergreen Road intersection which is also the primary access route to the plant; needed widening and reconstruction of the
- 22 highway east of the power station between Route 29 and US Route 202 in King of Prussia, reconstruction, of US Route 422 in the vicinity of Pottstown, and the reconstruction and widening of the Route 422 Bridge across the Schuylkill River at Betzwood. A passenger train line is also proposed as a first priority in the transportation plan to provide service through the western portion of the county into Norristown. The proposed route for this train line is the existing Norfolk Southern rail line that goes through the Limerick Power Station Property. Other improvements including the widening and expansion of US Route 422 from Pottstown to Route 29 and additional interchange improvements at Township Line! Evergreen Road are proposed as secondary priorities in the county plan. In addition to these improvements, several other localized improvements that may impact evacuation feasibility are proposed in the county plan.
Due to funding limitations in Pennsylvania, these projects are not likely to move forward at this time. The environmental impact review should consider the capacity of the roadway facilities to service the Limerick Plant, as well as provide sufficient evacuation of the area in the event of a disaster. Possible mitigation strategies to be considered in the environmental assessment review could include the role of Exelon in funding the important road improvements needed in this area to ensure safe evacuation and access to the plant in any type of disaster.
Comment: 54-6-05; The Montgomery County Open Space Plan proposes a trail along the river through the power plant property. This trail is proposed as the Schuylkill East Trail, which would be developed as unpaved trail between Mont Clare and Pottstown. Essentially the proposed route would follow an old road way between the river and Norfolk Southern rail line through the Limerick Power Station site. Though such a trail route would appear to raise significant safety concerns due its proposed proximity to the power station, appropriate elements could be designed into any trail system to limit its threat to plant's security. We have found that trails can enhance the overall security of an area since they concentrate users along a defined corridor.
Furthermore, trails can provide emergency access routes that could be used during different disaster events to evacuate people and provide access for emergency response.
Comment: 55-3-05; It is important to note that the 10-mile Emergency Planning Zone (EPZ) is the second largest in population in the nation. As a result of recent development and type of development in the area of LGS, it is important to review the Evacuation Time Estimate Study (ETE) on a more timely basis and account for the transient population present in the hotels that have accompanied this development. Additionally, funding should be supplied for either Exelon staff or County staff to act as a transient planning and outreach specialist to assist these transient population locations with emergency planning.
Comment: 55-4-05; It should be noted that the Evacuation Time Estimate is currently being updated. Required highway and roadway infrastructure upgrades should be included as a part of and also as a result of any changes noted in the updated ETE. Special attention for improvement should be given to the local, county and state roads used for evacuation that feed the larger highways, as many of these roadways are no longer suitable for the amount of traffic that an EPZ evacuation could produce.
Comment: 55-5-05; The NRC should consider requiring Exelon to enhance planning for day to day emergency situations that require a response from local emergency services. Often times, Fire and EMS access is delayed due to screening of vehicles and personnel. This can cause delay in patient care to potentially life threatening illnesses.
- 23 Comment: 57-2-08; It's in an area with high population - we could never all evacuate if necessary.
Comment: 59-1-08; In Pottstown about Y2 mile from Limerick Power Plant we have four bridges. One they are not going to fix, one just was fixed, one has been in progress of being fixed for months now, last one is a [third1 of the way of being fixed. To get out of town the only other way is toward Allentown. If anything should happen, not many people could get on the one road. Please don't extend the license for Limerick..
Comment: 60-1-08; No way to evacuate area.
Response: These comments discuss issues related to emergency planning. The emergency plans for nuclear power plants cover preparations for evacuation, sheltering, and other actions to protect residents near plants in the event of a serious incident. Nuclear power plant owners, government agencies, and State and local officials work together to create a system for emergency preparedness and response that will serve the public in the unlikely event of an emergency. Federal oversight of emergency preparedness for licensed nuclear power plants is shared by the NRC and Federal Emergency Management Agency (FEMA).
FEMA takes the lead in initially reviewing and assessing the offsite planning and response and in assisting State and local governments, while the NRC reviews and assesses the onsite planning and response. FEMA findings and determinations as to the adequacy and capability of implementing offsite plans are communicated to the NRC. The NRC reviews the FEMA findings and determinations, as well as the onsite findings. The NRC then makes a determination on the overall state of emergency preparedness. These overall findings and determinations are used by the NRC to make radiological health and safety in the continuing oversight of operating reactors. The NRC has the authority to take action, including shutting down any reactor deemed not to provide reasonable assurance of the protection ofpublic health and safety.
The Commission considered the need for a review of emergency planning issues in the context of license renewal during its rule making proceedings on 10 CFR Part 54, which included public notice and comment. As discussed in the statement of consideration for the rulemaking (56 FR 64966), the programs for emergency preparedness at nuclear power facilities apply to aI/
nuclear power facility's licensees and require the specified levels ofprotection from each licensee regardless ofplant design, construction, or license date. Requirements related to emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50.
These requirements apply to al/ operating licenses and will continue to apply to facilities with renewed licenses. Through its standards and required exercises, the Commission reviews existing emergency preparedness plans throughout the life of any facility. Therefore, the Commission has determined that there is no need for a special review of emergency planning issues in the context of an environmental review for license renewal.
The "FEMA After Action Reports and Communication Related to Specific Emergency Exercises" document the Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise for nuclear power plants. The most recent exercise for Limerick plant was conducted on November 15, 2011. The results of the Limerick and other nuclear power plant exercises are publicly viewable at http://www.nrc.qov/about-nrc/emerq preparednesslrelated-informationlfema-after-action-reports.html
- 24 Therefore, the comments are outside the scope of the license renewal review and will not be evaluated further in the development of the SEIS.
Comment: 16-1-05;.... I'm very upset at the NRC's refusal to honor my enforcement petition filed 10 CFR 2.206 with respect to the Limerick nuclear plant. The NRC denied that petition on the basis that I would have an opportunity to intervene on this proceeding through the NRC's judicial process. However, that's not available to me. I made that quite clear in the 2.206 petition. Now, I don't have standing as a United States citizen because of my physical location in Jupiter to intervene in a proceeding in Pennsylvania where this plant is located. The NRC staff is incorrect in their opinion and they have a legal obligation to honor that enforcement petition and to provide an opportunity for me to address the Petition Review Board. So I want to put that on the record and I'm asking the NRC to look into that issue.
Reponses: This comment discusses concerns regarding the 2.206 petition process. Section 2.206 of Title 10 of the Code of Federal Regulations (10 CFR 2.206) describes the petition process-the primary mechanism for the public to request enforcement action by the NRC in a public process. This process permits anyone to petition NRC to take enforcement action related to NRC licensees or licensed activities. Depending on the results ofits evaluation, NRC could modify, suspend, or revoke an NRC-issued license or take any other appropriate enforcement action to resolve a problem. Requests that raise health and safety issues without requesting enforcement action are reviewed by means other than the 2.206 process.
The NRC staff reviews request in accordance with NRC Management Directive (MD) 8.11, "Review Process for 10 CFR 2.206 Petitions" (ADAMS Accession No. ML041770328). MD 8.11 specifies the criteria that are used to determine whether to accept or reject petitions for review.
By letter dated, August 1, 2011 (ADAMS Accession No. ML11214A228), it was requested that under 10 CFR, Section 2.206 that the NRC deny the licensee's application for renewal of operating licenses. The following was the basis for the request:
Petitioner contends here that the LGS Units 1 and 2 employ nuclear reactor vessels which have been in operation for a period ofyears sufficient to cause the metal in the nuclear reactor vessels to become dangerously brittle and subject to cracking or shattering from continued operations and stresses during an extended 20-year period beyond the original safety design basis for which the NRC granted the primary operating licenses identified above. Petitioner contends here that the licensee has not and cannot provide the NRC with sufficient and reliable test data to show that the material condition of the nuclear reactor vessels in question has not degraded and become dangerously brittle; or that continued operations of the nuclear reactors for 20-years beyond the initial 40-year license period will not cause the reactor vessels to crack or shatter and result in a Loss-of-Coolant Accident (LOCA) and cause harm to the health and safety of the public and to the environment at large.
By letter dated August 17, 2011 (ADAMS Accession No. ML112231397), the NRC staff indicated that it reviewed the request and in accordance with MD 8.11, the staff concluded that the request did not meet the criteria for review under 10 CFR 2.206. Per MD 8.11, the NRC will not review a request where there is a proceeding through which a petitioner is, or could be, a party, and through which the petitioner's concerns could be addressed.
- 25 The concerns identified in the 2.206 petition request fall within the scope of the safety review of the license renewal application. The principal safety concerns associated with license renewal are related to the aging of structures, systems, and components important to the continued safe operation of the faCility. When the plants were designed, certain assumptions were made about the length of time each plant would be operated. During the safety review for license renewal, the NRC must determine whether aging effects will be adequately managed throughout the period of extended operation. For all aspects of operation, there are existing regulatory requirements governing a plant that offer reasonable assurance of adequate protection if its
. license were renewed.
Therefore, this comment is not within the scope of the environmental review and will not be evaluated further in the development of the SEIS.
Comment: 4-12-05; I frankly am really concerned about NRC accommodating the nuclear industry with weakened regulations, lax enforcement, negligence and unsubstantiated denials.
It's happened right here even with their fire safety regulations that are -- we're on weakened fire safety regulations even though we know that that can eventually lead to a meltdown. I know my time's up. Thank you.
Comment: 1-38-05,37-9-05,39-10-05; Lax fire safety regulations Response: These comments discuss concerns regarding NRC'sfire protection regulations.
The NRC's fire protection regulations, inspections, and research focus on continuing nuclear power plant safety. To accomplish this, the NRC requires a robust fire protection program at every commercial nuclear power plant in the United States.
Nuclear power plants today use multiple layers of fire protection features to keep fires from damaging plant safety systems. Some of these features include fire barriers such as insulation, fire detection systems, and fire suppression systems (such as sprinklers). If a required element of fire protection is not available, the licensee must compensate for it, often by placing dedicated personnel on a continuous fire watch. The NRC regularly inspects licensees' means of achieving and maintaining the reactor's safe shutdown capability in the event of a fire.
The National Fire Protection Association (NFPA) Standards Council approved NFPA Standard 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805), on January 13, 2001, as a risk-informed, performance-based standard for existing light-water nuclear power plants. The NRC staff cooperatively participated in the development of NFPA 805. Published in February 2001, NFPA 805 describes a methodology for existing light-water nuclear power plants to apply risk-informed, performance-based requirements and fundamental fire protection design elements to establish fire protection systems and features required for all modes of reactor operation. In addition, it presents a methodology for establishing fire protection procedures, systems, and features for nuclear power plants that are decommissioning and permanently shut down.
The NRC has modified its fire protection regulations to allow licensees to adopt, on a voluntary basis, NFPA 805, in lieu of their existing fire protection licensing basis. This initiative is part of an NRC effort to incorporate risk information into the agency's regulations and enhance safety.
- 26 The NRC continues to oversee fire protection at nuclear power plants through inspection and oversight through its ongoing reactor oversight process. The comments are outside the scope of the license renewal review and will not be evaluated further in the development of the SEIS.
Comment: 1-3-08; No other facility has the potential to render the entire region uninhabitable, possibly for centuries as the result of an accident or terrorist attack. This is the highest-risk facility that could exist in any community in this country.
Comment: 1-41-08; [T]hreats from unguarded terrorist attacks with planes and missiles and a new threat, cyber attacks. Fuel pool[s] are vulnerable to attack.
Comment: 4-3-08; Indian Point nuke plant was sketched as a possible terrorist target in reference to 9/11 attacks. A suspected terrorist worked at Limerick for 24 years without the industry knowing it. How scary is that?
Comment: 34-6-08; The plant is vulnerable to terrorist attacks. An airport is located next to the facility. A plane could be flown into the reactor or the emergency power supply for the water circulation system at the same time terrorist could cut all outside power to the plant this would cause a meltdown and render entire area and downwind of the area uninhabitable for hundreds of years.
Comment; 24-2-08; I also think that it would be very prudent to put a lot of attention on terrorist attacks on the fuel pools.
Comment: 30-7-08; The cooling towers are within basic walking distance from shopping malls and all right aside of it - please explain that - with minimal security from what many of us can see.
Comment: 36-4-08; I also am concerned about terrorist attacks, natural [disasters] and the more common "human error." I plead with you to not renew this license.
Comment: 37-12-08,39-13-08; Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacks[.]
Comment: 44-6-08; Haven't we already seen some of the damage that a terrorist attack can cause for our country an for others? Do you really need to risk more possible attacks on a power plant that is not fully equipped for that kind of attack or for some natural disasters that can occur. This plant is not prepared from attacks with planes, missiles, and other threats such as cyber attack.
Comment: 45-4-08; Terrorists have made it clear they intend to attack nuclear plants. Exelon has refused to pay to guard Limerick against a 9/11 type terrorist attack with plane or missile, even though the most deadly targets (Limerick's fuel pools) are vulnerable to such attacks.
Limerick is a similar design to nuclear plants in Japan that are melting down and exploding.
NRC's own report from 2000 shows people 500 miles away could be impacted by an accident or attack on such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick vulnerable fuel pools five stories high. Cyber attacks, now declared an act of war, could wipe
- 27 out systems that could lead to meltdown. Hackers have penetrated the Pentagon and other well guarded systems. Exelon's new plan for cyber attacks give us little comfort.
Comment: 55-7-05; While recreation utilization is of importance and a major mission within this country, homeland security must be of a concern with any open access within vicinity of LGS.
However, we concur that with support of local law enforcement and a commitment from LGS to control and monitor access, trail though may be accomplished Response: These comments discuss issues related to security and terrorism. Security issues are periodically reviewed and updated at every operating plant. These reviews continue throughout the period of an operating license, whether original or renewed. If issues related to security are discovered at a nuclear plant, they are addressed immediately, and any necessary changes are reviewed and incorporated under the operating license. In addition, since 9/11, the NRC and other Federal agencies have heightened vigilance and implemented initiatives to evaluate and respond to possible threats posed by aircraft against commercial nuclear power facilities and independent spent fuel storage installations.
While security issues are legitimate matters of concern, they will continue to be addressed through the ongoing regulatory process as a current and generic regulatory issue that affects all nuclear facilities and many of the activities conducted at nuclear facilities. The issue of security and risk from malevolent acts at nuclear power facilities is not unique to facilities that have requested a renewal of their licenses.
The comments are outside the scope of the license renewal review and will not be evaluated further in the development of the SEIS.
Comment: 4-4-05; The Pacific Ocean is now severely irradiated by Fukushima. Radiation impacts of Fukushima equalled over 20 Hiroshima bombs when I last researched.
Comment: 6-22-05; After Fukushima, Limerick listed as one of the top 10 to have very serious problem when we have an earthquake.
Comment: 37-6-05,39-7-05; Radiation reporting levels increased dramatically after Japan disaster.
Comment: 46-3-05; While the problems associated with age will develop in any nuclear power plant over time, there are additional problems with the reactors at Limerick. Limerick's reactors are boiling water reactors similar to those that catastrophically melted down last spring in Japan.
Although these reactors have a later containment design, they have the same fundamentally flawed reactor pressure vessel design as those that failed at Fukushima. In the BWR design, the control rods come up through the bottom of the pressure vessel, instead of dropping down from above as in other reactor designs. While the reactor pressure vessel itself is made of very thick steel, the bottom of the BWR pressure vessel contains 60 holes through which the rods enter the vessel. In the event of a meltdown, however, these same holes can provide a "path of least resistance" through which the hot molten fuel can escape with relative ease; it then only has to melt through connecting pipes that are much thinner and weaker than the metal of the pressure vessel itself. This apparently occurred at Fukushima, where authorities now admit that reactor fuel underwent not merely a "melt-down," but a "melt-through," breaching the inner
- 28 pressure vessel and in the process releasing considerable amounts of radioactive material into the environment.
Comment: 46-4-08; One might be tempted to dismiss the comparison Fukushima on the grounds Limerick in Pennsylvania is unlikely to experience a similar combination tsunami and earthquake. While the tsunami is not an issue, however, recent analysis by the Nuclear Regulatory Commission suggest that earthquakes pose more significant threat to the Limerick reactors than was recognized at the time of their construction and initial licensure. (Incidentally, it now appears that at least one of Fukushima's reactors was significantly damaged by the earthquake even before tsunami struck.) According to the NRC's own data, Limerick's two reactors are the third and fourth most likely in the country to sustain core damage in the event of an earthquake. There is a fault line called Ramapo fault line that runs slightly north of Limerick, and two small earthquakes associated with this fault line occurred as recently as February 2009.
The unexpected quake shook Virginia's North Anna nuclear plant with over two times the amount of force that was designed to withstand should make use take very seriously the NRC's data regarding Limerick's greater than previously recognized vulnerability to earthquake damage. These concerns are compounded by the fact that the manufacturer of Limerick's controls rods, GE Hitachi, recently acknowledge concerns that the control rods in its BWR might not function properly in the event of an earthquake.
Comment: 56-3-08;...We further note, given the extended timeframes for expiration of the existing LGS operating licenses, that they easily encompass the five year timeframe that the Commission has set out for formulation and implementation of NRC staff safety recommendations to be undertaken "without unnecessary delay" in the wake of the Fukushima accident. In light of these important nuclear safety developments, we seek no reason why this proposed NEPA analysis, and hence the entire licensing proceeding that it is required to support, could not be deferred for at least five years, until the Commission has completed its decision-making and schedule for implementation of post-Fukushima safety upgrades. As noted above, to ensure the timeliness and accuracy of the NEPA analysis, the deferral could be even longer (on the order of 7 years for Unit 1), to allow for the inclusion of the results of the extended rulemakings contemplated under the Commission's regulatory response to the Fukushima accident.
Response: As explained above, the NRC's ongoing safety review of operating reactors is outside the scope of this environmental review for license renewal. The NRC will continue to take necessary actions to ensure that all plants including LGS operate safely under their current and extended operating periods. The NRC continues to evaluate and act on the lessons learned from the March 2011 nuclear accident in Japan to ensure that appropriate safety enhancements are implemented at nuclear power plants here in the U. S. In accordance with Commission direction, the NRC's activities are being led by a steering committee comprised of senior NRC management. Additionally, the NRC established the Japan Lessons Learned Project Directorate, a division of skilled employees focused exclusively on implementing the lessons learned.
On March 12, 2012, the NRC issued the first regulatory requirements for the nation's reactors based on the lessons learned at Fukushima Daiichi. The NRC issued three orders requiring safety enhancements to operating reactors, construction permit holders, and combined license holders. These orders require nuclear power plants to implement safety enhancements related
- 29 to (1) mitigation strategies to respond to extreme natural events resulting in the extended loss of power at plants, (2) ensuring reliable hardened containment vents at Mark I boiling water reactors, and (3) enhancing spent fuel pool instrumentation. The plants are required to promptly begin implementation of the safety enhancements and complete implementation within two refueling outages or by December 31, 2016, whichever comes first. In addition, the NRC issued a request for information, requesting each licensee to reevaluate the seismic and flooding hazards at the site using present-day methods and information, conduct walkdowns of its facilities to ensure protection against the hazards in its current design basis, and reevaluate emergency communications systems and staffing levels.
The public can access additional information regarding the NRC response to the Japan nuclear accident on the NRC's public website..
The comments are outside the scope of the license renewal review and will not be evaluated further in the development of the draft SEIS.
Comment: 55-8-05; In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon to reopen the LGS Information Visitor Center. As a result of the incident in Fukushima, Japan, the Montgomery County Department of Public Safety has a received a higher than normal volume of inquiries concerning nuclear power generation from the public. The LGS Information Center, although dated, could be upgraded to provide this service to the community to raise awareness and promote education of the nuclear power industry. This center could also be incorporated as an educational stop on the County Trail system.
Response: The NRC's Office of Public Affairs (OPA) is available to address the public concerns and questions regarding nuclear safety. The office follows news coverage of the agency and responds to media and public inquiries. If members of the public have questions or comments about the NRC, nuclear safety, or related topics, they can contact OPA at OPA.Resource@nrc.gov. For specific questions and concerns regarding Limerick, the public can contact the Region IOPA at OPA1.Resource.@nrc.gov. Additional contact information for OPA can be accessed at http://www.nrc.gov/about-nrc/orqanization/opafuncdesc.html.
The comments are outside the scope of the license renewal review and will not be evaluated further in the development of the draft SEIS.
Comment: 1-28-05; How about the customers that paid -- I hear them talk about how great the costs are for Limerick. We paid for Limerick from 1985 to 2010 in our electric bills. And in fact the electric[ity] that was supposed to be too cheap to meter turned out to be 55 percent above the national average by 1997. So that's how cheap Limerick electric is.
Comment: 1-43-05; Increased cost to the public. We've heard a little bit about this this evening, more cancers, more illnesses, more emergency room visits, more hospitalization from increased PM-10. Massive research on what particulate matter in terms of PM-1 0 does to human beings. And there are a few other things that contribute to those visits. The costs are astronomical. One case that Donna mentioned, $2.2 million for a childhood cancer case. You do the math.
- 30 Comment: 18-2-05; If we don't get the license which I doubt but what would -- how would we get electric if the license were canceled?
Comment: 19-5-05; What's more important, not all this electricity that we need for all our cell phones and everything. In a way we are responsible for the fact that PECO and all these other Exelon companies are building power plants. I myself you know am guilty of a lot of this but let's just maybe for a solution besides the wind and solar power and everything stop using all this new technology. Yes, you need it for some jobs and businesses, it's good for certain things, but let's not overindulge where we need so much electricity that we are willing to risk our lives.
Cancer, polluted water. There's no drinking water anymore. People have to pay to buy water that comes from natural springs. But you're using plastic bottles, you can't even trust that.
But this whole world has kind of just changed from you know nature. Let's get back to nature, let the -- instead of having all the young teenagers on their cell phones texting, using more electricity, that again it's going to cause cancer for them. Everybody has to stop and think why do we need the power plants? We really don't and again, Thomas, our wonderful caller mentioned some alternatives like the solar power, wind, but I'm just saying we are using so much electricity and stupid little video games on the computers. People get on the computers for hours at a time doing nonsense. That's taking up electricity where again why do you need all this electricity?
Comment: 48-4-05; Prior to the construction of the Limerick power plant, everyone in our surrounding area was told that our electricity would be one of the lowest in the U.S. This was a bold face lie!!!! It is one of the highest in the U.S.!!! [Exelon] lied to us then and they will distort the facts now.
Comment: 60-6-05;... To expensive Comment: 60-18-05; Increase costs-medical problems Comment: 60-22-05; Nuclear energy is dirty and expensive. Since Limerick was built we have had some of the most expensive energy - higher rates Response: These comments address concerns regarding the cost of energy and the need for nuclear power. The regulatory authority over licensee economics (including the need for power) falls within the jurisdiction of the States and to some extent within the jurisdiction of the Federal Energy Regulatory Commission. The proposed rule for license renewal had included a cost benefit analysis and consideration of licensee economics as part of the NEPA review. However, during the comment period, State, Federal, and licensee representatives expressed concern about the use of economic costs and cost-benefit balancing in the proposed rule and the GElS.
They noted that the President's Council on Environmental Quality (CEQ) regulations interpret NEPA to require only an assessment of the cumulative effects of a proposed Federal action on the natural and man-made environment and that the determination of the need for generating capacity has always been the States' responsibility. For this reason, the purpose and need for the proposed action (i.e., license renewal) is defined in the GElS as follows:
The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs,
- 31 as such needs may be determined by State, licensee, and, where authorized, Federal (other than NRC) decision-makers.
Section 51.95(c)(2) of 10 CFR states that:
The supplemental environmental impact statement for license renewal is not required to include discussion ofneed for power or the economic costs and economic benefits of the
, proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation.
The comments are outside the scope of the license renewal review and will not be evaluated further in the development of the draft SEIS.
Comment: 22-4-05; I wonder how many people here are aware of something called the Price Anderson Nuclear Industries Indemnity Act. Who knows about that? The title alone should give you some pause. Why do we need a nuclear industries indemnity act? What does it do? What it does is it puts a ceiling of a few hundred million dollars on the liability that nuclear power plant owners have for the damage their plants would cause. It's basically a scheme, they pay into a pool. The problem is that ceiling was set a very long time ago. It's totally unrealistic in terms of the risk in just the value of houses in areas that are covered by a plant like this. When this plant was planned the population in the area that its plume would cover probably wasn't 20 percent of what the population is now. That is I think a valid environmental concern.
Comment: 22-6-05; The question I ask about the money liability is -.:. let's just go back to the Price Anderson Act. The fact is that the nuclear industry does not pay market rates for insurance to cover it for the liabilities. This congressional act from way back in the 1960s eliminates that need. Back then the insurance industry didn't have the research to put a price on what should the Limericks of the world have to pay for a liability policy. I think there's plenty of insurance industry experience now. So my question would be if nuclear plants are so safe why do we need the Price Anderson Act?
Response: The Price-Anderson Act Nuclear Industries Indemnity Act (Price-Anderson Act; 42 U. S. C. 2210) is a federal law that governs liability-related issues for all non-military nuclear facilities constructed in the United States. The main purpose of the Act is to partially indemnify the nuclear industry against liability claims arising from nuclear inCidents while still ensuring compensation coverage for the general public. The Act establishes a no fault insurance-type system in which the first $10 billion is industry-funded and any claims above the $10 billion would be potentially covered by the Federal government.
Licensees are required by the Act to obtain the maximum amount of insurance against nuclear related incidents that is available in the insurance market. Currently, this insurance amount is approximately $375 million perplant. Monetary claims that fall within this insurance coverage are paid by the insurer. The Price-Anderson fund would then be used to make up the difference.
Each reactor company is obliged to contribute up to $111.9 million in the event of an accident, amounting to approximately $11 billion (as of 2011) if all of the reactor companies were required to pay their full obligation into the fund. However, this fund is not paid into unless an accident occurs. If a coverable incident occurs, the NRC is required to submit a report on the cost of the incident.
- 32 If claims are likely to exceed the maximum Price-Anderson fund value, the President must submit a proposal to Congress that details the costs of the accident, recommends how funds would be raised, and includes plans for compensation to those affected.
The comments are outside the scope ofthe license renewal review and will not be evaluated further in the development of the draft SEIS.
Comment: The following comments have been categorized under the area of Postulated Accidents and SAMA. The following comments express concern over the impacts to the environment as a result of a postulated accident, such as earthquakes and terrorist attacks.
Additionally, the comments raised concerns regarding the potential of new and significant information related to SAMA.
Identifiers: 1-1-PA, 1-13-PA, 1-24-PA, 4-1-PA, 4-15-PA, 6-7-PA, 8-6-PA, 19-1-PA, 30-10-PA, 37-11-PA, 39-12-PA, 45-2-PA, 47-1-PA, 56-1-PA, Response: The staff will address postulated accidents and the potential of new and significant information related to SAMA in Chapter 5 of the draft SEIS. These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 13. Radioative and Non-Radioactive Waste (RW)
Comment: The following comments have been categorized under the resource area of Radioactive and Non-Radioactive Waste. The comments express concern over the generation and storage of radioactive waste and the impact to the environment.
Identifiers: 1-10-RW; 1-11-RW, 1-14-RW, 1-30-RW, 1-36-RW, 1-37-RW, 6-4-RW, 18-1-RW, 23-3-RW; 30-7-RW, 34-3-RW, 35-5-RW, 37-8-RW,, 39-9-RW, 52-5-RW, 60-4-RW, 60-11-RW, 60-14-RW Response: The staff will address radioactive and non-radioactive waste management in Chapter 2 of the draft SEIS. The impacts of the waste management will be addressed in Chapters 4 and 6 of the draft SEIS. Finally, the environmental impacts of alternatives *evaluated in depth will be discussed in Chapter 8 of the draft SEIS, including waste management. These comments are in scope and will be represented and responded to in Appendix A ofthe draft SEIS.
- 14.
Socioeconomics (SE)
Comment: The following comments have been categorized under the resource area of Socioeconomics. The comments express support for LGS based on tax benefit, employment, and monetary contribution to organizations within the community. The comments express concerns related to the increase of homes and businesses in the area.
Identifiers:,1-29-SE, 52-3-SE
- 33 Response: The staff will address the socioeconomic impacts of renewing the LGS operating licenses in Chapters 2 and 4 of the SEIS. In addition, the socioeconomic impacts of not renewing the operating licenses will be discussed in Chapter 8. These comments are in scop,e and will be represented and responded to in Appendix A of the draft SEIS.
- 15. Support for License Renewal (SR)
Comment: The following comments have been categorized under the area of Support for License Renewal. The following comments are general in nature and express support for nuclear power and/or the license renewal of LGS.
Identifiers: 2-1-SR, 3-1-SR, 5-1-SR, 5-4-SR, 7-1-SR, 11-1-SR, 12-1-SR, 13-1-SR, 14-1-SR, 14-2-SRT, 17-1-SR, 20-1-SR, 50-1-SR Response: The comments provide no new and significant information and will not be evaluated further in the development of the draft SEIS.
- 16. Surface Water (SW)
Comment: The following comments have been categorized under the resource area of surface water. The comments express concern over the environmental impacts on the surrounding water supply such as Schuylkill River.
Identifiers: 1-17-SW, 1-23-SW, 1-32-SW, 4-5-SW, 4-10-SW, 23-1-SW, 24-1-SW, 5-4-SW, 35 4-SW, 36-2-SW, 45-9-SW, 54-4-SW, 55-6-SW, 60-9-SW, 60-21-SW Response: The staff will address the surface water impacts of renewing the LGS operating licenses in Chapters 2 and 4 of the draft SEIS. In addition, the surface water impacts of not renewing the operating licenses will be discussed in Chapter 8 of the draft SEIS.
These comments are in scope and will be represented and responded to in Appendix A of the draft SEIS.
- 34 References 10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, "Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders."
10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of Production and Utilization Facilities."
10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions."
10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."
[Exelon) Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick Generating Station, Units 1 and 2, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. ADAMS Accession No. ML11179A104.
National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq.
[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C.,
ADAMS Accession Nos. ML040690705 and ML040690738.
[NRC) U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C., ADAMS Accession No. ML040690720.
[NRC] U.S. Nuclear Regulatory Commisson. 2005. NRC Management Directive 8.11, Review Process for 10 CFR 2.206 Petitions. ADAMS Accession No. ML041770328.
[NRC] U.S. Nuclear Regulatory Commission. 2011 a. Letter from Harold Chernoff, Branch Chief, Licensing Branch 1-2 to Thomas Saporito. August 17, 2011. ADAMS Accession No. ML112231397
[NRC] U.S. Nuclear Regulatory Commission. 2011 a. Official Transcript of Proceeding, "Limerick Generating Station License Renewal PubliC Meeting: Afternoon Session." Adams Accession No ML11287A207
[NRC] U.S. Nuclear Regulatory Commission. 2011 b. Official Transcript of Proceeding, "Limerick Generating Station License Renewal Public Meeting: Afternoon Session." Adams Accession No ML11287A211
[NRC] U.S. Nuclear Regulatory Commission. 2011c. Summary of Public Scoping Meetings Conducted on September 22, 2011, Related to the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application. ADAMS Accession No. ML04069720.
Price-Anderson Nuclear Industries Indemnity Act, as amended, 42 U.S.C. 2210.
- 35 Comment Letters and Meeting Transcripts The following pages contain the comments, identified by commenter designation and comment number, from letters, emails, and public scoping meeting transcripts.
- 36 1
2
~.'
- 5.
7 9
11 12 13 14, 18 19' ZO' 21
- 24.
2S 31 tunthinkable proportions.
Whether a na*tuTal disaster or. terrorist, at.tack oc(:;uis; by' relicensing' Lim¢ti 1-1-PA I NRC would in e,f*fect be placing Russian roul-ette with he lives of mote than eight rriillion peo[::ile.
NRC,must close Limeri-ck Nuclear p:rant'. by 2029.
There is nb,way for ;eJtt:l'er NRC; or Exelo11 I
, t-2-0S I to ensure' tt:le safety of the environmef.lt OT the residents impacted by this, plal)t.
It cannot be made 1';;.;.1
",<;;fp Nt:l.r>t r,Pte f'ri,..,',1.:; j-." r."'" tp?
"Cl*j-.pn:t-*.. '"
f,...,
tender the entire uhinhabit.iible, possibly '.p
~o.r 1-3;OS I centu*ries as the Te'sul t of,an accident or -t errO'ri-st attack'.
Thhi is t'he *t:lighest-rTsk facili.ty th'at co.uld exist in any community in this country.
L'u'rrent 40 year 'operatlng. licenses explre n
2024' and 2029,.
Why the rush to renew these 1,4-LR I icenses now*?
we ut'ge "tne NKC: to say no to c;xe.Lon. sl t J1-5-0R I reql!esteq Ii¢ense renewals.
The public w:a's led pel,ieve that Limer,ick! s ruel 'pools, and I 1-B-LR tail 13 s of and cables could oper'cite Isafely *for.40 *years and then the would close.
Is Exeldh fea'rfUl that the lon'get :they wait the 'more serious problems may arise?
After
- 26.,of 40 ye'ars" nUmeroUs signs t-7XJS I of,aQinq and risk have been ident'ified.
'Cor,rosion, N~L Rf GROS.~
COURT REpORTERS AND TRANScRiBERS 1323 RHODE ISLAND AVE:, N,W.
(202) 234"443,3 W"SH!NGTOt:l,D:C; ~2000f>.3701 WWw,o!',alrgross.com I
- 37 32 1
2,
,of material" loss of fracture, 3'
documented in Exelon' sown renewal 4
managemEiflt section.
Instances, of 'equiRment 5
fatigue and cracking of vital,equipment l'nclude the
'6 t;eactor V,essEH and coolant system.
tJ.nnIng w,:ct
'7 Aging equipment" a*fter only 26 years that NRC shOuld not just c!qs'e, the
'2029, but also ramp up theiLovers'ight 10 dU'iih¢t th,e remai'ning: 18: years of the current licens<§..
11
- In the past
- few years, Limer*ick has had m:lmerous shutdowns sug<;restihg'there are al£'eady 13 12 problems.
Three occurred in one week in L6ss. Of cOolant 1.eaks and a,c,cldehts at 'r--,----...J 1'4:
already been documented.
lB adiQactive
,con,tairiination Gould go ;uhdetected and 17 nreported for years from the corroding 18nffastructure, much of it undet'gtound.
19' There have already been two :near misses' at 2Q LimeriCk £tOin 1996 to 2QOl.
21, This aging plant is 'an,accident waHing to 22 Larg,e vOlumes, more than 6,0,00 assemblies rL--J....,--=-:"..,.,
1-1O-RW more'
-:::han a
'Lhousand tons of highly 24radiO'acti've waste inUie form of spentfue.l r'ods are 25, pools, elevated five stories stored. in NEAL ~ GROS,S COURTREPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW, (202) 234'4433 WASHINGTON, D;C 20005-3701
- 38 1
2
~
,4
-S 6,
7
- 8
9
- 10.
12 13 14 15' 16 17' 19 20 21 22:
2'3:
24 25 above and oueside the reinforced This plant -will proauce,a spent fuel rod~ ~very
,l lon" lS no,W for nuclear plants States.,
vi*itl:!
loss of cooling.water, Lime;r:1.ck's fu~l tods coUld heat up, s'elf
,: :and,burn i !'lan fire, with catastrophic r::esults.
Exelon has not b,een re'quired to spend the money to guaid despite reques,ts to do SQ.
Dry cask storage and transport aile :a-ls'!'--',---,,-=-==.
,dangerous a 1t'erriat'iyes.
I,t' stiine to
!imer1ck and stop producing such waste for hid\\ there 'is no, safe solution.
,As long as Limei::ick perates harms to us and our environment will Their harmful envi*ronment:al impa'cts are unprecedented.
I,i.t the conclusion of dlir' II-year
- of :r:ol:rtine radiation re1eases and revi'ew of permit's for,major aLe po-llUtion and avarie,ty 6f dangerous water contamination issues, it's clear tha,t this energy is not just dirty, His in fact filt'b:y.
Evidence that we've compiled has addressed a
wide NEAL ~,G~OSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE:, NW, (202) 234'4433 WASHING1:qNj D.C:20005-3701
34
- 39 1
.2 4
5 6,
9 1'0 n
12 13 14 15' 16 17 18, 1,9 20
- n 2
24 25 range o,f topics:
routine radiation relea'ses into the radi0active, wastewater discharges into the
- River, roadioactive groundwater cbntamina,t r,adi6a,ctive huc.1i¢les assej,cia,t,ed with
,the detected il:'1 'our soil, OUT sediment, our QUt fish, oUr water,,and, milk.,
Research,has confiTmed radiatiol:'1 in OUI 1-15-HH liildien"'s, baby teeXh ihtRis 86inr'tluni ty.
Major' air
,-I-J.-..,..,...,,..,
IH6-AM I all ution issues under health-based standards of the '-r-.,----'
lean Air Act, 32 individual sources list,e,d.
- Drastic, armful increases in particulate matter nown also as PM-'Ie from the cooling towers, other air ollution increases also permitted.
DangeroUs depletioh of t'he Schuylkill R,i in and by itself, a singular reason to den'f-\\fL...,-~::-:-:":-.-.,
IH7-SW I
this permit.
The Schuylkill is' a vital dtihkincj water source for nearly two mi1lion people,from Pottstown to Philadelphia.
It is, being depleted ahd, contaminated every day that this plan,t, operates.
Alartriirig canc'er incr'eas'es weI,l documented in this community higher than 'hationala'nd sta'te averages started operat*ing until the late 19905.
that have' been repeatedly far P-18-HH a'f,ter Limerick The findings of oui i'r'tv,estiga,tion lead u's to conclude that this plant, is' i.n common language a
recipe fOT
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disaster.
WhiH NRC is requited to prep:are a
. 2 3L supplement.
to the Limerick Environmental I.mpact r.-"':-::""':"":-1 1-19-LR I
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statement
.for.
liceI\\s~
w:e
.hav~
litHe S
confiden'ce in the process based on NRC's r:egu-lat'ory histOry.
It w6,uld be difficult to.emimetate ashof.t
'7 list, so I'm going to rely on w,ritten document's.
- 8 There ati:' critics of the NRC,out the:re.who 'have done a 9,
mu.ch.better-job than we have o*f.generating such a 10 list" mO,st notablY-a scathing indictment by
- the 11 Asso'ciated Press.
I'm not going to re-enumerat'e that 12 ihformation.
13 It's loncg past time for the NRC: to summon r-"=-==
1-20-.08 I 14, I~he cc5ur'age to do the tight thing in our,,Judgment and 18 actually protect the environment and the
- pub1ic, 16 rather than the industry.
17 Today,.1 am going to be submitt*ingon the 1'8 record summary packets of our' research on Liirierick' s 19' major air pollution, harms.tothe Sc'huyikill :Ri'Ver, 20 radio'acti,ve grouhdWater contamination', links, between 21, Limerick's rad1.a,tion and our elevated cancers in this
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cornrhuni t~ and.how Lime,rick" s nucl'ear' power can, in 2:3' fact, be' replaced with safer sources today.
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Based on the compelli'flg body',of evidence 1~21 ~OR I 25, of environmenta1 harms to date and the enormous NtAL t<. uKU~,~
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- 22 2'3 24 25 increased popuJ..at:i:on in proxim-ity to this LimE?Eick NuClear Plant mList be clos.ed by 202,9.
There *is no amount of energy production that is the, lives.of so many people.
Thank you very much.
.)
-fACILITATOR BARKLEY:
Thank you, sir".
MR *. MA'GUIRE:GQod afternoon.
My name. is Bill MaguLt:e :and :1 am the site vice president at Limerick Station.
Arid I
have overall responsibi ty fo,r* the safe and r:eliable operat'ion of the facil I have :been working in the nuclear power industry for,25 years and my career beC(an at the Limerick Generating Station as an eng*ineer.
continued '.with a
license to be a
licensed seni,ot reactor operator.
supervisor' in the operations organization and was the 6r\\-shift B.enior mahager.of that facH for many years*.
I have also worked at a few other riu.clea*r stations across the country and before rejoinIng Limerick as the site vice president in May of 2*010, I was the site vice president at the Peach Bottom Atomic PQwer :Station in southe,astern pennsyl.\\rania in yprk NEAL R. GROSS CQURTREPoRTERSAND'TRANSCRiBERS 1323 RHODE ISLAND AVE:; N.W.
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25 37 OpeEating Limerick Generating Station sa:fely and reliably.is a i t;y that everyone at the power station takes very seriously.
li'le understanqo).lr to the community, to t;hi:;
environment, and to.each other to operate.the plant safely.
A key.component of a thriving community like ours is th~ availability Of s{3.fe;c;lean.,
and reliable electrieity.
And as we look into the future for the power needs of Pennsylvania ar'ldthe United States as a' wRole, we can see the increa'sing demand for th:s very res.ource.
At the same time" there's a*
growing concern about gases ahdclimate change that is a result of fossil fuels.
To help meet that
~to~ihg pOwer demand ahd to help our environment clean, Exeionhas 'applied to the u.s..
NuClear Regulatory CommissIon, fOr a: 20-year,e~xtensi,on to the plant's li<z:ense.
'Limerick's current licensefOt Unit 1
~ill expire in 2024 and Uhit 2in 2029.
Wi*th license renewal*, Lime,nick can pr:ov-ide our 2:04,9.
We understand our, special obligation to operate the.
and reliably ahd to maint'ain a close reI with our neighbors.
'ifJe pledge to NEAL It GROS,S COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW.
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22 2.'3' 24 25 38 ont*inue that special t*rust as we operate,the pla'nt e11into th,' future.
The 104 nuclear reactors in,the, United
$t'ates provide roughly 20 PE2rcent of our nation,' s
'More than 70 reactors na'tionwide have already rE2ceived approval from theN,ucle,ar RegulatorY Commission for a,20-yea-r license extension including tl1e Peach Bottom At'omi c. 'PoWE2r Stat ion in, Yo,ik Courlty.
Limerick Generating S'tation operates in a manner that preserVes the
~nvi~onment.
The plant produces almost no greerihouse gases.
The plant conducts approximately 17.00 tests annually on air; water, fish, soil" cow's milk, and other food products to measure for enViro,nriie'ntal impact.
We alsomairiti3'in a chaino£ radiation monitors surrounding the plant.
In
- 2005, the
~nvirbnriiental fuana~eriient systems at Limerick Generating Station achieved certification
- under,
,the stri,ct criterion of the Inte-rnational Organization £or' Standardization, ISO.
This certification is known as ISO 14001, a
common industry reference
,for the envi ronmental certification.
The ISO lAOOl certification r~quires a commitment to excellence to prevent pollution and to ensure: continuous improvement in environmEm:t:al areas'.
In
- 2010, the Wildlife Habitat Council NEAL RGROS.S COURT REPORTERS AND'TRANsCRiBERS 1323 RHODE ISLAND AVE., NoW.
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11 12 13 14 15 16' 1 T 18 19 20 21, 22 2'3 24, 25 recognized Li'mer,ick, Generating Sta'tion's commitment to envifoninentalstE:'!wa'idship by awarding us the,Wildlife at Work.certification.
1his dis~inction was awarded to :Liinerick Generating Station for our c6iliini tinent towards establ i'shinglong-term wildlife habiiat e,hhanc,ements that provided undisturbed habitats, with
- food, wat'er,
- cover, and spa'ce for animal speclees livln~ on the ~lant,station's landscape.
To ensure 'Limerick continues.f.o operate sa'fel'y for years to
- corrie, Exe.1on is inv,es'ting in upgrades to plant equipment,.
Since 20.10.,
Exe~on has invested mbr'e' than
,$20.0.
ini11ioh in'to the plant including installation of new safe,ty equipment, new electricaL cables, 'neW valves.,
and refurbishing the cooling towers:
In addi tion, Limerick ha's made more thah $4,0. rrii 11 io'h in phys'ical security up,grades sin,ce 20.0.1.
OLir investmen,t,in the future, does,riot,s,t,op with equipment.
We have, hired,and trained over 10.0.
new employees ove'j:" the last three, Years, mostly coming f'rom :ournat,ive region here.
We ma,intain a steady workforce of,approximately 850. people and during bur annual maintenance and refueling outages,we bring in between 15,0.0.,and 20.0.0. 'temporary workers that provide a boost to our local economy.
Hiring and NEAL RGROS,S COURTREP0RTERSANDTRANScRfBERS 1323 RHODE ISLAND AVE', NW, (202) 234'4433 WASHINGTON; D,C, '2000~3701,
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-1 ret,aining top talen,t is a key priori ty for Limerick 2
Generat'ing, Stat'ion.
3'Over the past' 2'5 years, Limerick hasi 'been 4,
pne of the bes:t performing andnios.t r,eUable 5*
generating sta.t,ions in the nucle'a'rpower industry.
'6 DurIng thatt'iITLe, the plant has set' s:evetal, re,cords
'7 for cont*inuous days ofopera.tion and has*
ibeen 8
J:;ecognized by theiridustr¥ for duf t,eliable operation..
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In March 2*01'0:,. L'imerick compl,et'eda successful run of 10 727 Coritinuou's days for oLir 'Unit 1
plant.
This 11 repEesented the second longest cont*inuous run for a 12 boiling,water reactor iri the Uhited States.
While we do not set out to break reco'l::ds, 14, c.o,ntInubus operations ate on indic'atcit' of the 15 excel'l ent human performance and equipment,reliability 16 tha't Limerick strikes. fof' evefy day.
17 We also take pride.in our investments in 18 the corilIinjnity.
IIi 2010, Limerick donated more than 19
$600,,000 to the corrununit.y in contributions to the 2,0 Uhited Way, fire ahd arilbulimce companies, educational 21 health and youth organi,zations.
And many of our 22 employees serve as volunteers in the 10calcbrilrilLinities 23 around the plant.
24 IIi conclusion; TIimerick Gene~at'inq StatIon 25 looks forward t,o wofking with the Nuclear Regulatory NEAL R GROS.S COURTREPoRTERSANO'TRANScRiBER'S 1323 RHODE ISLAND AVE:, NW, (202)234'4433 WASHINGT()t:J, D;C: 20005-3701
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Commission as you revi.ew our license renewal.
I appreciate the opportunity to s~peak with you tliis af"t*e rnoon.
ThaFlk you.
FACILITATOR BfiRKLEY:.Thariks! Bill.
(Applal:1se.j FACILITATOR BARKLEY':'
Representative REP. QUIGLEY:
Good afternoon, my; name is State Tom Quigley.
T represent the 146th District hereof which lo.w.er Po*ttsville is a party of that distr.ict, so I want to we1come the NRC h.eteteday to the b.eaGtiful Sunnybrook Ballroom fo*r thi's and thankth'em for coming out to listen to the c.and t'ake coiThtlentary.
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I' m here t'oday "to voice my strong support I--J...--...,
3-1-SR.
f6r the teli of
.the Limeri.ck GeneraTing Stati'on.
I wanted to touch *on a couple points of wh:y I
- feel it is important for this Tacility to be re1icensed.
First is the amounl: of electYicity that is pn)duced by thisfacilityo.
One *oL the things that lllyself and tny cqlleagu'es' in HarrisQurg hear consd:stently from businesses and the Commonweal*th and out citizens is the demand for energy' ahdei.e,ct.tici now and more importantly what that demand is going to NEAL R GROS.S COURT REPORTERS AND TRANSCRIBER'S 1323 RHODE ISLAND AVE:. N.W.
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15i 16 17 18; 19 20 22, 2,3 24 2'5 42 be in the f.hlture, Right.now this f.acility electricit.y for
- two millions homes and without some of t'hat the. greenhouse could gases t be produced by hat we
- coal, heat 130 na.tural 3;1*SR Corit'd 6i 1.
And.I'm going to put 'a. caveat in there for' my good friends out* in the western part of' the state viner.<=' coal is a big part of thE; Pennsylvania economy and t'm sugg.est'ing that this be done to the exclusion of coval and nevertheless, some of the techl'lo'logies that. they're developing out 'there a,re also impor,tant fQT that' industry and for the Cal1unonweal th of Pennsylvania',
Agci.'in, one of thec6ncerhE\\
We heai::
conslstently from business'es is how can we come here ihto Pennsylvania wi.th the ihfrastructure what it is which needs to be improved for the tr'ansmissi'on o*f the electricity; but more generatiol"l of that electricity,?
NLitnber two, I 'think 1$
is the
- Again, in these tough economic times
.that we "re here in the Cormnonwealth of'Penl'lsy1vania and alsQ in this na't.ion, one of the top issues. that we hear ab.out is jobs, NEAL R. GROSS couin REPORTERs'ANDTRANSCRIBERS 1323 RHODE ISLAND AVE..* N,W.
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}l,nd as was ment.ioned by the site vice j:esii::ient, ove"r 860
.2 ate employed here with an nnual payroll of $75 million.
The direct impact that 3'
4; s to the Commonwealth of PennsylvarHa, b.fco[irse.,.is 5
- eal'ized through the s,taie income tax and also all, of
'6.
h'es.e lo.cal mur(iG'ipalities most of them enact an 7
.arned i,ncome tax which again sustains their :townships $-,1-SR Cont'd s well as the.it si:::hbbld'istr,i,cts..
T6.have 1-.,-----'
'9 hat taken away T
thin;k would have' an e:ven 'mor:e 10'
'ramatic impact on o,ur local 11 As was ment.ioned the impact for the local 12 i'ea here, the:
wo.tkers who show ul?
he.!'e 13 uring the outages and the refueling, there I s 14, een two hotels tha,t havespr.ung up.alOng the 4.22 IS orridor with another one pianned right up here at the lB ana,toga *area.
Ag,ain, mOre, jobs and mote economic 17 rowth here for :ourcorrununi'ties.
18
- Thirdly, I
wan.t to tal.k abo.ut the 19' ornmunication that I 'veexperienced in the -seven yea,rs 20, hat I've been in office with Exelon ahdwit'h th'eir 21 ovcernment Af,fairs people as wel-l as with the*ir 'site 22 eople..
T 'Ve been on the sit.e, thrE!'e times~ tvtice for 2
'*~
<y tour and one to make a' present*at,ion during an nnivrsa-ty of the fac'il i ty.
And I have to that 24 t is a very -secure area.
T' know a lot of e are 25 NEAl, It GROSS COURT REPORTERS AND TRANSCRiBERS 1323 RHODE ISlAND AVE;, NW, (202) 234-'4433 y.JASHINGT0N,D,C: 20005-3701
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9 10 11 12 13 14 IS' 16 18 19' 20 21 22 2'3 24 25 44 80ncerned,about terrorism attacks or people be'ing on But unl.ess gone oyef the,reand gone through a tour, seeing how things are set seeing the armed security measures that, are in pl,ace, I think you 'come away mUC,A m6rEi 't,eLi,eved with th,at, And I 'm,,al:He tb speak to my constituents more af,'t'irmatively about the
~nd s~curity of the facility.
Any time that there I sheen "the occu:rtence there r whether it will be a, -couple t'imes a hunter has wandered onto t'he property where the authoti ti'es were cal,led; the GovernrriEmt Af:airs people at 8xelon are on the phone to me or with anema,il 1:'6 let me khow what's happenin,g before t,he out to the, media or to the, press.
So always very well prepared in their explana tions, not-only of that happen at the plant itpelf r but also ihCidemts and iss,uesthat occur around the country and a,rol:md the world.
Obviously, what took place in J,"apan wi th theinciden,t over there, they were on the phone with me and me,t with rhea few time,S to,explain,wha*t t'i;)}Jk place over-there and how' the sa.feguards are be,ing put in
'hebe s;o that do.esn't h2l;ppen at this It was mentioned earlier the dry cask NEAL R: GROS,S COURT REPoRTERS'AND TRANSCRIBERS 1323 RHODE ISLAND AVE.! NoW, (202) 234'4433 WASHINGTON, D.C: 20005-3701
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45 storage where the spent f,uel rads are; now stored
.outsiae in 'a dry cask, s:torage fact lity.
When t'hatwas proposed back in 2005-2006, the Gen'erat,ingStioatfon held t,wo open hous,es tbat ;wer",
well attended.
I went to both.of them where they had peop1e ant,here ta explain 'to,the wliat exact'ly was taldng place with this, dry cask storage,vlhy it was necessary.
A lot of qLiestions andanswe,rs b,acK arid forth and I think a lot of the peapIe came away better informed about tha't Just aL an open 'house, the 's*ite VP,who; just s'p,oke, BiU came 6\\1't to: give some initial comments and wound up spenoing the fu'll 'haur ih an imp17.omp,tLi and answ,e'r session and not again just planteo a
lot of tough ques,tions.
And I
think again the people c,a'me feelin'g confident in the openness and the transparency that was ayed in that qu'estibri arid answer session.
Another Of that is for 're1i,cens'ing for the.overall en:v:iEonment here,is the good Ci tizenshipthat the Gerie,r,ating Statton lias, exhibited.
As was mentioned by Bill, some of the charitable contribLitions 'that have <;Johe on, not for' the host community of Limerick, bu,t also for the surround,ing NEAL It GROSS COURT REPORTERSANDTRANsCRiBERS 1323 RHODE ISLAND AVE, NW, (202) 2;14-4433 WASH\\NGT()N,O,C, 20005-3701
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I attended a few dedication services where th""yprovj,ded t'O the Upper ProVidence Elementary S8i:lool and the Limer-ick Elementary SChool foI' an putside !"'ri'iironment'aL Cl~li:isro,6rri.
One
,of the things we, talk about as poli tie:;;ll le~ders, arid I'm on the :;.:rouse E,duc;ation is the need fO.r our chiIdren to be educated particularTy in 'the scii=nces and given these budget constI'aints that.
we're operating
- under, both the school distri~cts and, the Commonw.ea:lth, i,t' S :;lood to see a corporate citizen stepping up to the plate and that financial support, part'icularl.y ih the area of sci'ence.
They've also paTtnered wi,th the Montgomery county Community College to provide assistance' in support for an associate degree,in nuclear technology.
Again, we hear so much about our s,tudents here not w,ell veYsed in teciinolQgy and engineering and things of tha,t nature.
So again" up to the plate to p.t'ovide that assistance
- when, in fact, perhaps in these tough budget times the might' not be able to do that.
Last, I want to talk about, overall. publ,ic opinion ahd issues.
One 6f the thing~ that I looked at: when I talk about safety and the: feeling of NEAL R. GROSS COURT REPoRTERS AND TRANScRIBER'S 1323 RHODE ISLAND AVE, N.w' (202) 234'4433 WASHINGTON; D,C; 2000S-3701 I!iWW,n<ealrgl-oss,com
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~0mfor,t that people have here is how, many of the
.2 people.who.w6'17k at tt'i'at plant live wi thin the ten"':mil$
radius of the facility?
And I askedthatquestd::on 4
wnen I fir'st\\;;,as elected in 20.04, and I just asked, it
- 5.
again in
,for this hearing and 563 liVe within tli¢ ten:-mil,e radi us:.
7 The popul,ation :growth in my District in 8:
tl7le past ten w.e're, getting ready to redr.a,:,' our 9
lines based on the 2010 Census, so I broke-i,tdown: by 10 as to. hm".much. the po.pulati6n has, :ihcreased 11 in t::h'o.se areas:
Limerick To.vmship, increasing by *3'3.5 P6ttsgtove by 29.5; Royer,s'fo.rd Bo.rbligh, 12 13 where I live, 11.9; Lower Pottsgro.:ve., 7; Pbttsto.wn, 14:
now this is: a: little bi,t skewed, bUt I have a small IS piece of New, Hanover Township which actually increased 16 54 When you look at,the public o.pinion, and 18 again, we calls on a lot of different iss'ues ahd 1,9 as I
mentioned that dry cas k storage issue.
Back 20 therl; at the sariletime that that issue was be,in!;!
21 rolled out. to' the public, Boyd Gaming had pur-chased a 22,i:Iext,to our plant \\'Ias g,etting r'e,ady to had applied for a license, casino license'.
At that 24 time" my; offiG,e had recei\\.re,d 2 calls in regard to the dr.y cask s,tor.age proj ect, over 200 calls the 25 N~LR:G~S COURT REPORTERSAND'TRANScRiBERS 1323 RHODE ISLAND AVE:, NW.
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casino application.
So at the time*, it appeared wer~ more c.cmeern"ed about theprospecto'E a:
casino being in their than they *were a drY ca~k §tbrage facility_
And lastly, as some of you heard*, there is tight* now to p.ut t'iold en Route 422.
And in the pastsi.x months',,rith the incidents in
- 2.
Japaf'l, wi th the *current e*at.thquake *w.e had here*,
~i th the AP story telling you how: these plants are all foUling apart, I receivec two c.alls regarding that one wheFe tl:!eY' could get the' KI pill's, one wheTe they could more calls and emails the proposed 422 _
So again, it app.e.ats tha't the constituents and the,.146th; they're more concerned about the prospect. of p'aying a toll to ride of 422 than
'are about the huclear power plant issues.
So
- again, I
,strongly support the rel.icensing of* this for the reasons I
mentioned.
Thank. you.
(Applause. )
FACILITATOR BARKLEY:
Thank Representative Quigley.
The next three people I'd like toea'll, first is Lorraine Ruppe, 'private citizen; and the N~LR..GRO~S COURT REPoRTERSAND TRANScRIBERS 1323 RHODE ISLAND AVE!, NW.
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next, Michael Gallagher of Ex-elon; an(j. f'inally, I'd like to call Dr. fred Winter. after that.
MS,. RUPPE:
Hi, my name: is Lorraine ReJppe.
'1 am speahrig hefE) today to and Euture generations, especially in our cowmani,ty.
Reside.rits, ar,e f,eatfOl ab.ou:t the of di-sas,ters nere' in l-i*ghto.f Fukushima 'in March 2'011 and since the and Hurricane, 'Irene in 2611 af~ecting Dur area~
~Limate ~hanges, etce~era, at'e caW5ing disas*tersever.ywhere,arid to get worse.
Increasing floods, droughts, earthquakes, ornadoshave made us all feel inseceJre, making
.ucle,ar power increasingly espe<:;ially,with the plant basically in our backyards.
'that comes through, this area,collIe, be a Fukushima, Ghernobyl or Three 'l-111e.Island which remindS me, four months hav.e. passed sinCe ther.-~=-=,..,
4-2-GE NRC failed to back to me when I asked how close the Remapo fault line is 1:0 the Limerick 'nu.clear reac;.tor.s?
Maybe I can get 'an answer Indian Point hllk.e plant was sketched as a possible terrori*st target in refe*rence 1'0 9/11 atta,ckS.
A t'errorist worked at Limetick, for years without the indust.ry knowing i L How scary is (20.2) 23~4433 NEAL It GROS.S COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" N,W; Wl"SHINGTON, D,C,20005-370.1
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that?
2 The
'E'aCific Ocean i:s nOw 3'
irradiated by Fukushima.
Radiation impacts of
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Fukushima
~q led over'. 20 Hiroshima bombs when I last 5
esearched.
Our.drinking and ba,thing water here is 7
4/7 for years 'with radiation and unfiltered toxic
- 8 ontaminat!"d mine.water, thanks t,o 'the NRCahd Exelon.
4"5~SW I 9
This is disgusting.
1,0 MOst of us have to depend on. the wate,r,;
specially for bathing..
Some of us pay extra for 11 12 aLer Iil tr'ati'on or drink. bottled 'Nater because we are 13 Iraid to drink from the Schuylkill and *because it
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astes really bad no,\\{.
,Imagine how toxic it would be 15 8 plus years from now if the're, was even' any wa.ter l6i:;'ft.
There has been iFlcreased parti'culate 18 inatt'er in the, ait'and oth.er toxies ftom Limerick b*:-;-;;-;--,
4-6cHH I 19 causing increased asthma, heart attacks, and strokes.
20
}\\nd to add insul.t to inj ur;f', Li'merick was grant'E~d,a permi to allow an eight-fold inc:rease'
,i,n air 21 pollutipn since 2009.
Cancer rates in our atea ha~e
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2'3 skyrocketed since Limerick has been up and Funning,in 24 the '80s and rates hav,e, s't'eaaily ihcr,eased.
I The Toothfairy E'roj ec,t showed high levels 114-7-HH I 25 NEAL R: GROS,$
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i:;hildren hea test to riuke, pl ants.
Bab'tteethneat Limerick, p1'ant had the h,ighest le:vels in 1::h'e whole United, States.
This stuff ahd l3odlG10WS.what else,is in our bodi,es now than'ks toa Nuclear RegulatoEY Commission that tq it ni'c::ely is les's th,an enthusiastic about us:.,
Sola,erwihd, geothermal, oeean 't'hermal, neEgy conservation and,efLiciency are now cheaper han riuclearpower,,along with b,eing truly Clean ahd afe.
The
'o,f Energy '2006 report stated c)lar alO'ne could
,55 times,our entire nat ion's nergy needs which leads me to a point" there have eeh humeroUs studiesprovihg the many dangerous and eadly consequences o.f nuclear,power.
There's no deriyihCJthe massivedevastatioh it hasali:'eady caused and, '.',ill continue to cause indefinitely, bu:t;.
the industry still goes on in
,their trance-li ke, indif.ferent fasl:li,on as if everything is safe and wonderful and will continue to be 18 plus years Team now or until '2049 for our conununi,ty.
This is what t'eally scares us the most,.
The NRC has turned into a
culture of seCfecy~ hiding the dangers,and sweeping the,problems under the rug.
The industry' saddiction to money and NEAL It GROS,S COURT REPoRTERSANDTRANOCRiBERS 1323 RHODE ISLAND AVE:" NW, (202) 234'4433 yYASHINGl:0I':t D:C:20005-3701 WwW,n~alrgioss,cooi Cont'd r:4-'::,8:-_A'i'":L'"'"'1
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But, my
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ig question of the day: is why is Exelon applying for an extension 18 years, ahead of time~ Thank YOj1.
(Applause. )
FACILITAT,OR 8;Z\\RKLEY:,
- rhank, ybu., Lortaif)e:,
Mike?
MR.
GALLAGHER:
My name is Mike Gallagher and I'm the Vice President of License
- Rehewal for Exelbn.,
I haVe over,all responsibi 1 i ty fO'r the Limerick
'Station license renewal Exelon has a great deal of experience with 1 icens,e renewal i
,as we have a1readyobta'ine,d the renewed li'censes for 'our Peach Bottom and our TMI in Penhsylvifni'a, bur Oyster Creek p,laht in N'ew
- Jersey, and ou,r Dresden and <::ij1ad Cities plants in Illinois.
Just bri,eEl y about mysel f.
T've been working in the nuclear power iIidUstry for 30 I
was a 1 icensed senior operator and plant manager at Limerick and I worked at two.other nuclear i?larits and our' corporate,o'ffices,.
Mr,..Mag,uire, the 131 te vice p'res1deht I,or Limerick spoke about reasons for the license NEALRGROSS COURT REPORTERSANDTRANSCRiBERS 1323 RHODE ISLAND AVE" NoW.
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53 for Limerick.
I'd 'like to speak brieSly about t'he pr.ocess for this licBnsei renewal. 'application and the amount of work and engineering analysis that was put into ptepar.ingthe Because Station can 1""5,-L.1-"~S""'R""-'
decided to IL--r---...I e operated and,r.eUabIY, ursue 'license. renewa1 for 'Limeridc Limericzk is a
'ery cle,an source which pT;oduces no as emissions.
Limerick i.s also good for the economy
'nthat it lowers market prices: on electritit,y for :the itizens of Pennsylvania to t*he tune of $880 miHion e'r year.
So in,2'00'9, we' announced our 'intention to seek license,renewal for Limerick.
La,ter that year; we started the work necessa!'y to prepar::e the application.
After over 'bio of
- work, we submitted the application to the Nuclear Regulator,)!
OorrirrfissiQn, on June 22, 2011.
The application, as Lisa had. mentioned" when you printh. out it's about 21 00 pages.
.J>.r,d when it in the binders it's three large binders.
It's a huge amount of inforrnat*ion.
But that ohly t.epYesents a small part of the. work that was done for the engineering analysi to' p!'eparethis lC,atibn.
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if we pri,nted it all out would be about 290 binders of 2
information.
We nvest:ed over 000 manhours of 3:
engineering work.
Once wecomplet'ed,our engineering 4
wO'rk to pr,E!pa're th~ application, we in, experts 5
from outside 'Exe'lon to review' the application to
'6 ensure that i twas'complete, thorough,and accurate~,
7 bur total cost to prepa~e the and ~et this 8:applicaUbn 'reviewed by the NRC will, be, abo,tIt S}O 9
million.
10 Tliei::e
- ate, t;.,:o diffetefit parts of our 11 pplication,tl:ie safety review and,the envil'onmental 12 e:view.
For thesafe,ty review, we, took an in-depth 13 ook at the and the condition of the safety 14 quipITient in the plant.
'We did that to determine 18 hether the necessary maintenance 'was being performed 16 h that equipment,,and to make sUr,:
tha t th'3 equiptnt'::nt 17 Jill be able to opeL'ate when it.' s needed" not only for 18 oday; but als,o, for an, additional 20 yeats
,of 5-2-0.8 19 20 When you look b,ack at Limerick" when it 21 as
- built, all the e",uipmen,t was new,.
It was 22, hotou'ghlYtested to make sute it would petform roperly, but like anything, else does age.
23' hat doesn't mean i tW,oh I t wo'rk, bout' it' does age,and 25 24 ertainactivi ties need to be done to the equipment.
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refutbisn the There may be modificat.,ions done to upgrade the e.quipment ir:l tn!'!
and in fact., as Bill, Magllire has stated, Limerick had spent ove'r $200 million i!1 the las.t couple years alone to imptov;e ano, m'odernize
,the equipmen.tandenhance piant *,opera,t'ions and safety.
Wi" alSo th.en revie'tl.ed
~al¢u'lati,6hstha:t 5~2"OS, Cont'd were performed as of the original desigrl of the plant t!lat viere done, to ensute t!la.:t the plant cb.uld opera*te sa,felyfor, 4 (')
years.
We ar:lalyzed those calcu1ations and wer'eable to confitmtha:t the pl.ant would*
be able to operate safely for 60 year*s.
OverEdl, out concliis:io:1 ftom out engineering' rev,iew was that Limerick could opei'ate safely for up to 60 yeats.
We also took a look at the environmen,ta,l impacts of continllihg to oPerate LitnericJ(.
l'le, looked at all the impacts of continued impact of the plant on the environment.
Qur conclusiO.n is that irripacts,on the environment ar-e small and I use the term small in the sense that; is i'n the defines small as envi,ronmen*tal effects are not detectable oraTe minor.
We
,also revlewed the alternatIves If NEAL R: GROSS CQURTREP0RTERSANDTRANSCRIBERS 1323 RHODE ISLAND AVE:, N,W, (202) 2~4433 WASHINGTON, 0.:C:20005-3701
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~3 24 25 56 Limerick would not have its 1icense, renewed and a!:lother s,outce of elect'ti,c w,ould need to,b,e installed either here on site or someplace else to th,e replacement ele,ctricity, we conclUded t,hat any' other means,of generating the replacement electricity' w,Quld ha).T,e, mor~ of an
,on the envil'onment,than continued operation of Limerick.
for 5~3cAL Cont'd' i'nstance" if Limerick could be by a wind generation facility, the wind form would ha:v;e to occupy between 1.0 and 4,0 percent of all the land in the s'tate of DelawaTe and that would have a
huge impact on the land.
If a soJar cO,Dld rep1ace Limerick, it would need to Gover 32 to 50 percent of the en,tite Li.nd area of, Montgomery In conclusion, we operate Lime:J:'ick safely and we can cQntinlieto operate it safely forah additional, Limer'ick will provide appf6ximately 2348 megawatts of baSe-load gen:etation~.J..,.,,,...,,,.--.
5-4;SR, that's not only safe" but it's clean, reliable and economical.
Continued operation
,of Limerick wi,11 benefit this community, the Corfuhor1w,ealth, of Pennsylvaf'lia and our nation.
Thanks for giving me the time for this.
Thank yoU.
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9 11 12 13 15' 16 17 18 19 20 21 22 24 25 F}l,CILITATOR B>>RKLEY:
Thank
- you, Mi ke.
Dr~ Wiht~r?
Good afternoon.
Thanks for letting me.
We have heatd a lot-of ahd I
cons,* haven I t we?
And it S hard to make a dec:l:sion thaT's for sure.
But let me get heri::...
s a pnysl8la*n. pract:lcclng EaOLO or
.over 5.0 y.ears, I
..s.tillhav~ s;trong concern aooUt cancer sensi*t:rvities from harmful Dadiation exposures, naturally.
My medical colleagues share the same concerns because we have seen our can'cer rates ihcrease since the Liinerick plant "itar'ted; especially thyroid cancer.
It jumped to 7.8 percent highet. here than the na.ti.onal av.erage.
.And some,of the people T talked to, th'is is because e are aging more now.,
getting older,.
s.o there are more cancers.
But that's not true because in other areas siinilai to oUr area inPbttstown, theY're not heatly the th=troid cancers that we.are.
This has been well established by the. sta.te.
You 'donder why some of our medical and
- cancer, fundtaisets haven '*t rEi.acted with more responsibility in order to stop this.
They're making a.lot of money, bUt riot N!kinc:j )!i.ueh effort to environmental damage.
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Y'es, we are creating* our own form 'of 2
t.ertoiism.
Now t'hat. sounds. kind 'of f.utlny, do:esri't it?
3:
But allowing any harmfl:ll
.env*ironmental events to 4occ:ui; WE= are allowin<;j oui o,wn form of terrorism; j lIst 5
like foreign people would come
~A here,
'6 Ha:il:ing at,teIidedci. Hiroshima" Japari 'atorr 7'
omb clinic right after.WoridWar II, naturally I had chance to see the worst results
,bf harmful
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adiat,ioA.
All those'little kids I saw who only l,ived 10 or a fe'\\.[ days, n le,ftme wi.th, a very sad memory.
- Of 16~2-HH I 11 ourse, what is happening here will be t'a'king 'much 12 otlger~ but it sura is not good.
I don't know whether you've heard tha,t 1-4:
orne s,cientists are already pt,edi,c.ting that I'.rr 1,5 orry to te,ll you this, but nuclear energy has the 16 apaci ty of desttoyingmankitld.
It may take, about 100 17 ears, but our whole world, is exposed to the harmfiJl 18:
ffects,.maybe not so much here in the United st'at~e:S, 1.9' ut.the whole world can be affected.
2:0, Of course, what is happening here will be 2'3 environmental disasters and a concern about our nea'rby 24 earthquake faul tan<::i others in the east,ern 1). s.,
25 especially one near New York City.
And then there are NEAL R: GROS,S COURT REPORTERSANDTRANSCRisERS 1323 RHODE ISLAND AVE:, NoW, (202) 234-'4433 WASHINGTON, D:C;20005-3701 wWW,n~alrgfoss,cooi
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,he rad,ioactive, spent fuel waste material itti'ng
- arCiuna, supppsedly We,
,can't (Control the use, of' nuclear power i'n the res*t of the wo'dd, b.ut can keep }'imerica safer arid Cleanet here.
So please, ask your politicians~ reliable 6-5-QR oliti.ciaris to close the Limerickpo:we'r.plant'.
LE',t's save 'America,for our kids and descendants.
I hope you will take my c,oh'.cerns s.er'iously.
And thank you for listening.
(Appi'.':luse.)
-FACILITATOR BARKLEY;*
Okay" thank you, Dr.,
Winter.
.The. nex,t thre.e People.1 'd like to.ca:ll is T.om Neafcy of Limerick Township, followed by Dr. Anita Baly; arid th.en Tim Fi=ncnel of the. SchuYlkill Ri.ver Heritage "Foundation.
MR.
NEAFGY.:
Good 'afternoon, thank you.
My name is 'rom Neafcy.
'1"m the Chai rman of' Limeri ck T6whshipBoa'rd of SiJpervisorsand I \\'lant to thank for this opportunity to speak at. thisfor.um today.
As toe pri*va:te employer in the region, the Board isthank*ful for the 860 jobs that E2Ce1on
- provides, i ti ve impact of thei operat.ion" the of our* 10'cal community.
comrr,iJni ty and local e,c6nomy,are. erihanced by the nee.ded services provided by.the township,' which includes the NEAL Ft GRO$.$
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24 25, 60 roaGlway network main,ta'*ined by our Limeriick.Township ic sa prov,ided 1:h:e.Limer'ick and Linfield Fire and our local emergency medic.al resPQlis\\,,;,
o'ur ic blit iecreatiol1 facilities. and also t'he police that's provided by' Limerick's 21 sv;orn office.rs.
Because of:: Limerick
'S'ta tion ' s lCicadonwithinour boiders,the Limerick Township Police Department is the only police depaortment in Penns wLth jurisdiction, over Tier 1
crit.ical This Board prides 'i1:self on '1:he services provided directly b01:h to the residents and the, businesses 'of this community ahd the tbwnship's. ability to maintain those current levels of serv{c~ during these difficult economic do';'mtutns.
ate thankful for th.e generosity of the Limeri*ck generat:ing a*nd Exelon for being good corporate nei'ghbbrs.and the assis1:ance they provide to.
the' Wi thout their financial assistance that to prbvide those servii-ces to' the 80mmunity would fall squa.rely on the backs of '1:he.taxpayers.
They-assist in out.fire companies.
They have been sponso'rs' of our Limerick Comf.mnity Days.
And We.are con'UdEmt that Limerick generating facility and Exe10n will continue NEAL It GI'{OS,~
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We also a~e in support of th~ relicens~ng of the Limerick nuClear plant.
Thank you.
(Applause. )
,fACILITAT.OR BARKLEY:.
Dt. Bal'y.?
DR.
BALY:
Good afternoon.
I'm Anita
~a1Y.
I'in a.retired Lutheran pastor and my.c6.ricern luodayis with the' speed at which this appli'cation process is going.
I mean.i t seem's to ine. that to omniscience and prescience tha*t we should attribute to AlinightyGodi but cer'tainlj not to ahy of us hLiinah beings.
I would favor' a 51.ower process..
look around, we see,that the population in this 'aTea is gettihg denser all the time.
T.h~ioads ar.e hot
. h being improved.
- And t h'at 1 eaves me W'l:t*
concerns about how
,w~ ""ould effect an *eva.cuat*ion. were one needed.
T suspect, strongl y tha*t we couldn't perform a And I al'so suspect tha:.t the population will be increasing and the roads deteriorating.
In fact, just this morning, iii the Pottstown Mercury, they were reporting on the hearing NEAL R: GROS.S COURT REPORTERS 'AND TRANSCRIBERS 1323 RHODE ISLAND AVE:, N,W, (202) 234'4433 WASHINGTON, D.C, 20005-3701 wvNi:li!,alrgross,com 7-1-SR I Cont'd 8-2-0S I I--r-.,...---'
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. r.ouno here...
Ahd Sa.fEY Beyniour xecutive Director of the orumaudience that population 5.0 perc:ent inc.rea se i nthe
'ncrease eapacity on
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rid10.ck all the waY, to the Berks County lihe.
- isqu6ted, Delaware Riv.er and he told projections and i'f 'we don.'.t
'we will have vi*rtual he"'s:
last Naybe we'll improve that. situat*ion, but it 's. way too t.o know if that will happ,en.
And so my plea and my concern,is can we slow this down* so that we know; in fact, what theenvirbnmeh:tal impa,¢t's are going to be 'closer to a time that the decision is made.
Thank you, (Applause. )
FACILITATOR BERKLEY:
Thank you, Tim?
l'lR. FENCHEL:
Good afternoon.
Ny name' is T.im Fenche.l and I 'n", on. the staff of the Schuylkill River National and State Her*itage.Area.
We are one of 49 conqressiona 11y-desigoat.ed Areas in the cou:ltry and our mission is to use recreation',
conservation, cultural and hisbo'rIc preservation and tourism as tools for community revi talization ahd economic with the Schuylkill River Valley_
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24 25 The Heritage Area has had the for almost s.even, year's now to partherwith E}xelbn Nuclear and the Limerick Station on seve'ral local anrJ proje,cts an,d pro'grams.
These programs have proven to have a po'Sitive impa'ct on our lei.cal cdrrimunities:, reside nts,atICl natural t'es,ource s'"
And I would iike to take 'a few moment's to highlight those how.
In
- 2005, Exelon Nuclear approaehedus about the Iity of tq.g:ethe'r on a
grant program that would work to resto,re our area IS critiea:! n'atur,al resource, the kill Ri,ver.
The
'r,iver has been detrimentally impacted by hundreds of yeats of ab(J"se and neglect, prTmari as a. resul,t of our n'atton I s hi reiated to the IndustL'ial Revolutio*n.
But even mo*re due to deforesta,tion, farming practices, and continued,open space development.
Beginning in 2006', after uhecreation of j.)rogram gl1'idel ines, an tofuI'M ttee.and a rlece'ssary accoun*ting and repoL'u'ing st'J:iuctures, Exelon began. making annual conU'ibutio.ns t6the Schuylkill River Re'StoL'ation Fl:lnd.
The Schu:y;lkill Ri:verHeritage A'reaacts as*th,e administrator ahd the bf this progr'am, redistribuuing Exelon's contributions NEAL R GROS,S COURT REPoRTERS AND TRANsCRIBERS 1323 RHODE ISLAND AVE:, NW.
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to local, and regiona1watershed groups, conservat,ion 2
orgini'i arid local government for 3:
proj eCEs addressing
,the quality and quantityof Schuylkill Riverwat,er.
Proj ects focusihg on agricultural remedi abandoned mi-ne, and
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!3tqrrriwater t,Urioff are supported thtpUgh this prograin.,
7 To 'date, Eixelon has contribuEed over
.2
- 8 rriinion to the r'estoration fund for wate,t'sh,ed"
- wide projects.
T,wenty-b;o have been awarded and 11 10 9
ects' have. been,completed.
These proj ects h'ave 11 made animpac,t on the water quality and quanti t.y of 12 the kill River which is a source of: drinking 13 water for over 1.75 million people in southeastern 14 Penns'!l vania.
IS Exelon's es,tablishment and contribution to l'6the res,t6rat'ion fund has been a in00el pro:gram and 'is 17 now a uniquely' valued publ partnership as se\\(e'ta 1 new:
have joined e,ffotts and 'made 19 18 their own cont,r'rbutions to the fund.
Both the 20 Philadelphia Water arid 'the Partnership for 21 the Delaware, Est.uary have brought funding to the 22, and region'al watershed ptoj ects.
2'3 The contributions made by Exelonhave been the 24 catalYst to leverage additional funds well
',over 25
$600,000 for area restoration.
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16' 17 18, 19 20 21 22 Z:3 24 25 The goal of the Restoration Fund ComIni t tee is to be, abl e to of half a 'million dollars annua,lly for the' fund and in tu'rn;
<:::onserv:ation projects that will continue to ensure the future health or the 11 River.
In,ciadi ticin to pur wot'l( on the,r$s,totation fund,,we have assisted ExeloD NucJ:ea,r, East Coventry
,Townshi(J,and Cheste*r Couht,y iii a anning effort to begin the process of restorat,ion and preservation of the historic Fricks Locks ViI Earlier this yearj Exe'lon Nuclear" the current owne:lisof" the VIllage, signed an agreement wi.th East Township to stabilize, rehabil<itate, and protect several
'of ene,ster County I s oldest biJildih9s.
Exe.1on has to spend
.5 million to restore the exterior of seve'ral buildings as s::abilized.fLfihs.
A fence will be buil:: around t;hegrounds and the corpora'tion is donating fO,ui:
houses to the t9wnship.
wotth an estimated $1 million.
In addition, thl3 corpor'ation has to continue to do routine maintenance on,the v:illage and wcirk with the local historic,al soc'iety to hos,t historic and educat,ional tours for t,he' public.
Fr'om our perspective, much of the sD,cces,s of this can be assigned to the, hard wO'J:k, N~L R: GROS,S COU'RTREPORTERSAND'TRANScRlBERS 1323 RHODE ISLAND 'AVE:, NW.
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9, 10 11 12 13 18 18 19 2,0 21 22 2:3 24 25 66 dedicat"i:on and personal commitment of' txelon staff and management.
Bas,ed on the verV positi \\it;"
community programs and involvement we have experienced and witnessed first,hand as a regional br,gahization,we would like to communicate our suppor.t for the r,elicehsing and continued operation Qf
'Li:nierick (Applause. )
t:ACILITATOR BA:<.KLEY:
- Okay, thank you.
The next three people I
would like to cal Bill
- Vogel, followed by Eileen Dautrich, i'Sthathow you say that?
MS. DAUTRICH:
Dautrich.
fACILITATOR BARKLEY:
Oautrich.
Oka)'.
And th'en Bill Albany.
MR. VOGEL:
,Hi, tfly name is Bill Vogel.
I live inl?hoenixV'ille.
Uni ts 1 and 2 had an initia,l life expectancy of
~o years.
They ~te no0 a~kihg tb increase that 20 years, a
full one third inc'rease.
Everything has a lifeexpectanc:y', machihery, as,<<ell as people.
Demographically, my li,De expectancy is 74.
If I was to. get a one th'itd extension, like the Limerick plant wants, that I-lould take me to IlL V'lhat do you thihk is, going to happen to me betw:e,eh age 74" my life span, my nameplate capacity, and the year when
..~.. I~ "'"'~"""
COURT REPoRTERS)O;ND TRANSCRIBERS 1323 RHODE ISlAND AVE:, NW, (202) 234-'4433
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- 72 1
1 reachllr?
It's going to go down hilL That's
,2 lif(:jcy¢le.
Machinery has, th,em.
You don't need an 3,
engineer to tell you that.
Just, like human beings 4
have them.
We be,come less, ~ffecti ve; less efficient, 5
less 'compe,tent.
6 The ficant differehce is my failure 7
will be conta,inable,.
Limerick's most likely will not. 10-1 c,LR I Cont'd 8
Tf I drive ove£: you with my c,at be¢aus,e T no longer
~
see as well or have the reflexes I once had, that1s a 10trageoy for you, your family, for rile and my family.
11 The sphere ocf the tragedy is containable.
If Limerick 12 Uni t 1
or 2
fails i all hell breaks
- 100S8, n'o 13 disrespect.
That 's what a nuclear failure is, hell.
14, It affects everybody in this, room!
everybody ih the 15' community, everYbody,in the tri-state aT:ea, not for a 16 week, but for de,c'ades.
It'a very, very last we 17 want to happen.
18 AhdI thin< we,' re oursel'(iesiri 19' harm's,ray by taking somethiHg thauhad a lifespan of 20 40 yea'rs arid addingahbther' 20 To iL,.
It doesn't make 21 sense.
The only way to rationalize it is through our 22, personal fear,of being' inconvenienc'l:!,d becau'se we lose 10-2 a
~ery, very good source of power, It's done a great OR I job fot us.
But 1 ike me, you get to a' point where 24 25, your ability to provide a great job is at an end and NEAL RGROS,S COURT REPoRTERS'ANDTRANscRiBER'S 1323 RHODE ISLAND AVE,. NW, (20,2) 234'4433 WASHINGTON, D,C, 20005-3701
- 73 68 t.hfngs' start deteriorating.
Let IS not pllt ourselves 2
1 in tha,tposi tioh.
Let's make an i:ntelligeritdecision 3,
17l0W and allow, these' two units to expire at their 4namep1at.e time.
Thank yOU" 5,
7 9
10 11 12 13 14, 18 16 17 18, 19' 20' 21 22 23 24 25 (Applallse. )
.fACILITAT,OR BAAKLEY":
Thin'lk
¥ou, 8i 11.
Eileen.
MS., DAUTRICH:
Good afternOon..
My name, is Eileen. Dautrich.
I'm presidel7lt of tbe Tri-County Area h§ffiber cifCommerce.
to ba hera toda¥ t6 rovide examples Q*f how Limerick 'Gener.ating Statiol7l is a valued cOminunity and business pattnerand echo. 'the statements already shared by several others.
,.Le one
- 0. f the tri - cciunty area's largest employer.,
providing professional employment for local residents.
Those local residents employed by Limerick Station are supportihg the, enti're bus:ines$ cowmilnitY.
hey"re purchas ing personal goods and services from, local small businesses.
The annual outage, is, a
trernel7ldous,benefit to the local economy and ouJ:' loca1 usinesses.
Limerie'k' encciurages thei':r o.utage emp10yees,to visit and pun:hase from tri-cQunty ar.ea, local businesses, and small bu'sihesses.
In addition to the j0bs they local NEAL R: GROS,S COURT REPORTERSJ\\NDTRANScRIBERS 1323 RHODE ISLAND AVE:, NW,
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. 2 3:
4, 5:
6; 7
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2S 69 residents, they're making :a significant investment in
,our localc6rnmun'ities.
Municipali ti'es and 'Ei"isidents benefit from assistance received from Limerick to 0tart, maintain,,expand parks; r"ecreation,and 'qu'ali t~(
of life :oppor:tunit,ies.
ThEiirco'rporate,c)JHure of giv:ing back eo the community is practiced by their hundreds of employees.
Nonprofit organiz'ations are supp,orted oy Limerick, Generating Station and the ef'for.ts of their employees.
financial donations, as well as Volunteer hours and time are
- donated, enaoli,ng our local nbnprofits to provide the.much needed services that impact those in need throughout the tri-county area, Th.e Limerick' Generating Station is confident in the clean 'and safe environment they main,tain in ourcornmunity.
The. community has. been invited to experience the:
generat:i:ng station firsthand.
The charriDer hos,ted a merriDership breakf'as,t and the site vice president, Sill Maguire provided the keynote presentation.
Re s,urnmarized safetY,measu'res and advancements at Limerick and answered. ques't.ions pertaining to the Limerick plant and its safety.in, the wake 'o,f,the tsunami,in J,apan.
In addi tionr after our' Q'reakfast', Chamoer merriDers were encouraged,to attend the informationa'l NEAL R: GROS,S COLiRT REPoRTERSANDTRANscRIBERS 1323 RHODE ISLAND AVE:. NW, (202) :234-4433 WASHINGTOt"J; D:C: 2000S-3701
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24 25 71 see policies and procedures that people talk about and
'~teput up qh a shelf 'and
't"e f.ollowed.at ;best haphazardly with a wink and a nod and deviation f*rom th~ polity is not :addressed.
One of the things that I'm continuously itnpressed a.t LGS When T Visit is their. s6und,adheter'lce to policy and f'lrocedur:e.
They don';t deviate from it.
- 1 ve o'een. 'to numerous diills at the :plaiit', :num'erOus exercises at the f'llant., 'some of whi.chwere Tun by the NRC:: and I'v,e never seen them fail.
always come out *on "top.
In fact, in 2'009, Limeri*ck was selected as a si.te fo,r the first cbmprehensi:ve pilot exercise involving federal, state, and loca'liaw 'enforcement SWAT t'eams to actually into th,e. poweT block and conduct tact1ca*l opera.t*i:onsin there, and that drl,ll
",as uS,.ed as a bo.ilerplate to develop and procedures for implementation.
in plants throughout th.e. cOu*ntry.
bneof the I'm'sorr:y, I'don't believe that c,ontinll.ed ope'rations of the power would have any, detrimef'ltal effect on publie s'afety in the sQ.utheas.t region.
Thank you.
\\
FACILITATOR BARKLEY':
- Okay, thank you.
I'd lik'e to call the final tht'ee speakers who have NEAL R: GRO~S COURT REPOFiTERSAND TRANScRiBER'S 1323 RHODE ISLAND AVE" NoW.
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2, 4
5 6
7
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1:0 11 12 13
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1:5' 16 17 18 19 20 21 22 23
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72 signed up"
- John McGowan, Ted Del Gaizo, and Timothy John?
MR.
McGOWAN:
Thank you' vexy much,.
My name is John McGowan and I am, a life,-long t",;,ide,nt of the Delaware Valley.
I have lived hal*f'o15 my -- or I
.shOuld say thee I.,imerick NtlcleatE'o'wi;;r Station has.been operating for half of my' life.
T own three ma:nufactUring coinpimies; in the Malvernar,ea and employ a
number of people in thos facili*ties who rely tremendously on the 'LimerickE'owerGeherating Station to supply safe, reliable electrical power to us opeJ:'atinig.
Today, I would like to say that in all of the years that 'I '\\re liv,ed in this area, I'v,e ne.ver worried at all about the safety of the nuclear power plant.
I see it everyday_
And. it bothers me, not in the least.
I have nev,er' seen any credible evidence to 13-1-SR suggest that thexe ate safety ems with this plant.
In terms of reliability, it is the same.
It is runn'ing 2'4/7, :365 days a year and it lias b:een doing so for a of a century and I hope it continues to do s,o 'for many more 'years too come'.
As faJ:.'
as ins environmental impact.,
I think it's,pretti :widely known that nuclear poyrer is one of the cleanest environmental energi esthat we N~L R; GRO~.S COURT REPoRTERSANDTRANSCRfsER'S 1323 RHODE ISLAND AVE" NW.
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2 "3'
- 4.
5, 7
8
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2'3' 34,
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possess today thrOl.:ghout the world and *to dismiss it is I think a foolish notion.
The impact or t'he Limerick plant in our regio'n has been extraordinarilypositiye.
provides', as we all know' and have h'e'ard t'od'ay, lots of 13-17SE jobs, lots' of, good jobs, tax revenues fO.r. s.chob1s,:
Coht'd local governments and fOL'those who 'live i*n the *a-rea IL..,.--_-l to e0joy the fruits of public s,etv.ipes and itals(j provides a
lot of charitable donations to the c9iri."nunitywhichis very important.
I think that to not this plant rutminc:j and. nc:itconsider a renewal of its lic::eflse for an extended period would be a t*ragic mistake' for all of us and I wo.uld like tQ end this that the only meltdown that wouidconcern me is the economic one that certai would happen to,this area sho.uld this plant not continue to operate.
- )
FACILITATOR g}l.RKLEY:
Ted, go. at:lead.
MR.
GAIZO:
Hi, my name.is Ted Del Gaizo.
I'm a registered profeSSional engineer i8 the Cornrhonwealthof Pennsylvania.
I'm,als,o president and CEO of a small business engineering,firm in neac.rby Exton, *PennsYlvania.
t-1y experience, in nuclear power goes,back NEAL R GROSS COURT REP0RTERSANDTRANsCRIBERS 1323 RHODE ISLAND AVE:, NW.
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2 4,
5 7
9 10 11 12 13 14 18 16 17 18 19' 20' 21 22 24 25 74 to the 1960s where I spent 14 years in Navy submarin'es arid I personally opeEat:ed, maintained; and refueled nuclear :power s during chat period.
But I'm here.tOday,as a private ci tlzen, as a resident o,f, the' a'!'ea and as a member 0-£ the Energy Klliance t'p go on, recofdarid s I
str:ongly
- f'avor license
.reNewal for the Limerick Generatiri9St'at'ion..
I say that be,cause in personal experience' I know in api te of some of the things you: \\fe' ¢robab1y he,a rd.here tooay, nuel ea r is sa*fe, rel*iable, secure and cl'ean,.
that:, I would like to* go on recprd, I would like my neighbors to know we are lucky to have the Limerick Station in this area.
In the industry, it has a top repu.tation.
It-is one of the fines,t. nuclea*r power ants, in Arrierica.
And E:xelon, if not, the best, is certai-nly one of the finest: nuclear operato'r:s in t.he woild.
I have nothing but conf:bdence,that Exelon will work to<;fether wi,th the NRC, will,tun th*rough the process and we willcome up with the right conc*lusion hete,wliich is license. renewal should be granted 'to the Limerick Eenerating Station.
I think we need to keep Limerick operating as long'as we can.
In addition, in of some other things (202)234'4433 NEAL R; GRO~S COURT REPoRTERS 'AND TRANSCRiBERS 1323 RHODE ISLAND AVE:; NW.
WASHINGTON, DC, 20005-3701 WiVw:nealrgfOSS,com
I ClPPl.aud and I Thank you.
1
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-79 76 openness in the thinking process that goes into place fo'r renew:al of any nuclear power And so from' my as.a bus.inesspersor\\. who has I unde'rstand.the. value this is to. the region.
And for the. NRC for *what great. work that they're doil'lg enc:ourage Tne renewal process tptake (Applause. 1 FACILITATOR BARKLEY:
Thank you.
with that;. I have all 15 wh0 had.signed for-this
, have been called.
Is there anyone else who would like to make.3 ShOEt
- t.emark at wO.lild like to st*lll speak at this point?
Okay, if not, I '.d like to make two points before we wrap up.
- One, the, NRC does have publ.ic meet'ing 'feedback forms whicn give. us feedback on how Y0U think 1:.his.meet:ingwas conducted, so I. would greatly you 11 out one of those foims for us so' that we' can learn how to There is anothersessioii of this.meeting at '7 0 c10.ck ton1ght.
I You I re welcome to speak again tonight.
l:\\nd secondly, what I td l1ket6 say is I facilitate a lot of meetings the Northeast (202) 234-4433 CO NEAL R: GROS.S REPORTERSAND'TRANScRiBERS 1323 RHODE ISLAND AVE:, NW, WASHINGTG!N,D,C: 20005-3701 URT Www,riiea1rgtoss.cooi worked in thi~
- 80 27 meeting via conference bridge.
.l\\nd due to the arrangements of the audio irt this toom 'i t wasn't possible to do it any other way than a cell phone.
So we're
.to go to him anq ask him to make a
statement for the period and move f:romthere.
So our first spE:aket will be Mr.
Thomas Saporito who is a senior associate and he actually l*ives in Florida.
So as so,oh as we can work Jiav.ing him on the microphone we will have him make hi.sstatement.
Ar:e we.free to it a try?
MS.
REGNER:
Go ahead.
Y*es.
Go ahead, Mr.. Sapori.to.
Is it my turn to speak?
MS. REGNER:
Yes.
MR.
SA?ORITO:
Can you hear me okay?
FACILITATOR 8J1.RKLEY:
As best we. can, yes.
MS. REGNER:
Yes; go ahead.
MR.
SA?ORITO:
An right..
My name is Thomas Sapo'rito.
I'm the s.enior consultaRt with Sapr:odani Associates and I" m.located in Florida.
I would like to c.oltunenton the NRC's 16-1-0S environmental*review but. before I do 'that I want to state th'at, you know',
I'm very upset at* the NRC's
- refusal to honor my enforcement petition filed tinder NEAL R: GROSS COURT REPORTERS AND'TRANSCRIBERS 1323 RHODE ISLAND AVE:, NW.
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28
- 81 10 CFR 2.206 wi,th respect to the Limerick nuclear denIed that petition on the.basiS that an opportuni.ty to intervene on this thr;ough the NRC'.s.
judicial process'1\\3_1_0S Conrd However, 'that's not a'Va-i,lable tome.
r made that quite clear in the 2206pet'ition..
- NoW, I don 't Nrj$
standing a's a
United States citizen because of my location in to interVene in a
proceeding in Pennsylvania where this ptant is Ideated.
The NRC staff is incorrect in their opinion and they have a
legal obli*gation to
!:lonor that enforcement petition and tb me to address the Petition Review Board.
So I want to tbat ohthe:,re.cord and 1'm asking the NRC to.lo.ok l~
into that ssue.
1E With
- respect, to this environmental 1.7 petition the fellow who spoke, earlier from the' NRC, I
.It don I t re.call his name..
It was very hard for me to hear this communi,cation his name.
But* anyway,.
one of his corriinents 'was incorrect and he mis*1nformecl the publ ic..
And I'd. like to correct that 16-2-LR statement.
Hes,tated that the NRC is exter,ding the ~..--_--I original operating license which was granted by the NRC for a Period of tirre that that initial 40
,year license was not based on considerations or NEAL R: GI~OS,~
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between the J:Jucl,ear Re\\J.ulatory Commission. and the 1
Uni*ted' S,tates Congress where Congress wants to stop th'i.s put a mbrat.o.tiuni on. the re-licensing 1
1:.lntil toe: Fukushima disasters can be fully understood 1
and the e'nfiahcemerit enac,ted in August for oUi:: po.wei::
lants here.
This particular nU(;;lear plant, these 1
lants, you kn0w, their license is already good till
.1 Why are *\\,e here rim, 12 years ahead of time
_ryin<:r to extend.this. license?
And the only 'reason is ecause t.t' s a foot race* the NRC 's in with Congl'ess 16'4clR 2
hdnothihg more" This has nothing to do
~ith rotecting public health and safety, it.' s the NRC's 24 eal to
'cc:mtinue to rubber'-stamp these Ecense xtensions without allowing* citizens due process like NEAL R:; GRO~S COURT FiEPORTERSAND TRANSCR'IBERS 1323 RHODE ISLAND AVE, N.W.
(2~2) 234'4433 WASHINGTON; DC; 20005-3701 29 echnical cons ide ra t ions.
But that's abs not rue and thei::'e I;[as recently a year-long inves.Ugative don'eby 'the Associaved Press who interviewed r.-1~6--=2--:-L=R""
nuclea t.personnel, engiii.e,ers~ s"fety engineers Cont'd nt:he' nuclear ir'ldus1:-*ry who told them that the 4O~year i.ceFlses iqsued J;:iy the N~C f9.1::* 104 nuclear ants in he United States was based on safety ar:ld technica:l tecnh:'..Ccd analysis..
-So these license ex*tension proceedi*ngs like: the one we're 1*
.are a rubber-stamping of. thes.e 2
'icense *extensIons.
This is in fact a
foot race
1
- 83 30
- t already' talked,about and without doing a
int'ens,e and 'thorough enYir.ontne,Qt,al I'eview.
And with respect>
to the NRC's f3nvironrriental
,tevie':l the NRC in my view failed to properly.consider the embrittlement. of th-is nuci,ear iY'eactor vessel.
Wlcien thes,e nuclear rea,ci:'"ors ar(§ ppera'bing the neutTons cause th'e metal in the reactor fi'essel to be,come J:5.r'ittl,e over 'tithe.
And after rumerous years of these -reactor vessels
're so brittle.
Bl.lt the NRC
~oesn't proper,ly evaluate, that and' the r\\JRC doesn't lequirethe, licensee to do destr:uctive t,es'tin9 and 1,
14 1
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~nalysis of the reactor's metal vessel prior to ubber-stamping a extension to thes~ license~.
Twenty years from now, oh actually 20 years from 2024
!'ihieh will be, 20:44 :this teactoT is going to be even more critically brittle and the NRC.' S not, going to
-nde'rstand the dyrU:ifui,cs of :that and the reactor ¢ould rack and it's going to melt 'down because you can't ecover from a
loss of coolant accident o'f that magnitude.
So tha't 3 one point.
The other lint is the NRC'sCorruiiiss'ibii pver there in Rockville, in the White Flint Building, hey recently adopted a new icy with respect to r=vacuations.
They \\vant these licensees to update NEAL R: GROS,S COURT REPORTERS AND TRANSCR,isERS 1323 RHODE ISLAND AVE;; N,W, (202) 234"4433 VliASHINGTC>N, D,C: 20005-3701 w.v.N:riealrgioss,coni I
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31 their evacuation plans.
- Now, 1 would hope that the NRC staff has made that requirement to the.Limerick licensee so.that the people near and around within 15 evacuate the a:rea.
Aga:i:n, the Associated Press's 16-6~OS I itive.stigat y:ear-lQriq investigaUbn shows theft th~ C6hfd popula*tions around these nuclear plants increased tenfold 6ve.t thEi ye'arsahd that tne.roads and the congestton, you can't timely evacuate these are*as.*
And. the, NRC keeps pushih9, these evacu:ation onto the licensee but the NRC doesn't enforce its regulation or* Rroperly review i fthese plans are e\\ren e f.fect i ve.
The NRC. is requ'iredunder. the law in this
'review, the environmental review to consider rene,.lable alternatives.
And that. means need.
Is there really:' a n'eed for these two nuclear plant*s to operate and the answer' is no..
Simply stated if all the *cus"tomer*s.who receive power from these nuclear plants were to 'simply rerilov.e their hot w.atet heaters and therr. wi th on-demand electElc water heaters you would reduCe the.electti*c base load demand 50
~o 7~ percent.
~ou wouldn't need either one of those ftuclear power plants to operate..
.1 f you take that fur*the!' and introduce other energy conservatAon you NEAL R GROS,S COURT REPoRTERS'ANO'TRANsCRIBERS 1323 RHODE ISLAND AVE. NW.
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- 85 32 would ac.tually have fhe licensee shut down 'more: of their other powe,i:
becau8,e of you wOuld ne'ed a demand.
.If you take wind energy,which,is plentif,ulup 4
,there in Pennsylvar-tia angeveh the new s()lar panel which can operate when the, sun isn "t shi'ning on a clo,udy day, you' could replace eVen more plants.
So' these renewableene*rgy sources 'even with towiiid.energy since you,hciveacommOn throughout the United 'states you can have wi,ndfarms genera.te power to.,a c.ornrilO,h 16-7~AL pqint 'and supplYihg Cont'd the power t'hat, these' nuclear plants ar,e now providing.
'I'he, NRC's lz'equireduhder the law to c,onsider these altern'atives to extendtng this license.
AFld I would hQpe that the NRC's fi'nal evaIiJation and rev,iew shows a
complete and thorough ana'lysis of aU.
these renewable energy sO,brc,es inCluding installing on-demand' hot: water, elec,t*ri:c heater and doi-ng, an analysis of how many megawatts.you're, going to take orf the and based on those evaluations make a licensing determination whether, or not thiS license should be ext,ended.
Because 20 years from now all these renewable res,ources 'a*t,e to be all that much :more adv,anced and capable of supplying all that much mOEe power than they'r:e currently
- ying, S6, those are my comments and I,would hope that the NRC takes them (202) 234-4433 NEAl,. R: GROSS COURT REPoRTERSAND'TRANSCRlaERS 1323 RHODE ISLAND AVE" NoW, W!'-SHI!'JGTONi D,C,'20005-3701
- 86 3;3 seriously and applies them to this license renewal.
MS.
REGNE~:
Can you heat that.?
They't~
clapping.
FACILITATOR BARKLEY:
Ok?y;.at this point I'll call back Mr. Saporito later' and t.hank. him tor his rerrtaiks ahd foX
.sue.cinet in his r.ematkS.,
It's awfully awkward to provi*de* Gomments viath,is avenue..
The Hrst three people I would like* to call are.ac;tua inCliViduals who did not s¢eakthis aft'ernoon so I'd 'like to start with them.
- Firstly, Jeff Chtirtmuk" then Daniel Ludewig, and t.heh final.ly Catherine Allison.
So Jeff, ~f you ~ould lead o£f.
MR.
CHUMNUK:
Hi, my name is Jeff Chutnnuk and. I'm a member of Borough Council with Pottstown BoroiJgtl.
And my c6riLrr',ehts tohight are more I guess a newly elected official with 1
1 1
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2 Z
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About a year ago I had the opportunity to go down,to the generating stat,ion andlr-..l..-_~
17-1-SR eetwith Joe Saffron and the flrst part of my meeting had. t:o do with looking.forsome support for the Pottstown So.apbox Derby.
.Through some conver'satibn hile we were standing outside you know Joe NEAL R GROSS COURT REPORTERS 'AND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW.
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- 87 34 enlightened me a little bit on what Exelon and the
~t~tion do for th~
c6inm(mities, supporting our and,other Civic organizations.
'You know" with our cleanup,; our8.alva,tion Army and now th'~
Thank you.
And irre were stafidIn9 outsidetli'cft' it ni'ce out" and our conversation led plant i tsel f.
We yre're standin9 theTe around, it's a impresslve sight.
So L' asked him
- about, you
- know, possibly having a
t'6ur fO,r officials.
He said he woula look into it and see what he could do.
A couple of months later he got a group' of about 20 of us and gave us a tour of And I hav,e, to say tl:latfr,om the time we walked through the front gates and past the as oifr tout' ptog'ressed, you know" throughout the plant safety was pal'amount.
Whether you were having what the different 6610rs are on the diffeTent panels and, wna*t they mean to diffeterlt failsafes;why you wa:lkce'tXain areas certain ways and what lines you had to stand behind, yo.u know, w,as par'amo.untwith them.
You know" from the environment, I'm looking around and,this NEALRGROSS COURT REPORTERS AND TRANsCRIBERS 1323 RHODE ISLAND AVE:; NW:
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- 88 35 place is spotless.
And I asked why and it's because they can"t afford to ha'ie, qirt or lint or fuzz: balls around because of static electricity because it could c'reat,e issues.
So ftom that aspect I it, was a geod,tour and it made' me feel good abo,ut the there.
To finish our tour, we ended up in' the control ~06m Upstairs.
And I'd say a dozen 0'(
so ind'ividuals up there moni,tO'ring.youknow ng going onwi,thihthe.plant and around the plaht.
And
- again, explaining:
the faTlsafes and why they'r.e 11"'1~7'--1:--S~R=-'...,
d6uble,-, triple-che:cked to eliminate human error.
It Cont~d was just very impresslve and as an.elected official to doWn and,take a toUr' of the plant arid understand how operates.
I know when I left I personally knm*!
hQw to issue a concern \\.Ji th the, genetatingstatiorl.
I know I fe'l t a lot better and,a lot safer
'home t,hat,night'.
Ahd it was a1 sogoo.d to, r,ea 1 i ze" you
- know, as one of our region I s largest employers now thatth.ey,are. wi 11ing to give back to the }:6niimjnity an8., keep safety first.
So thank you, I just wanted to make those, COIT'ments.
FACILITATOR BARKLEY:
Thank Jeff.
lJaniel?
NEAL ~ GROS.S COURT REPORTERS AND TRANSCRiBER'S 1323 RHODE ISLAND AVE, NW.
(202) 234-4433 Vo.iASHINGTON, D.C, 200~3701
- 89 MR,.
LUDEWIG; I'm Dan Ludewig.
ques.nons.
Ohewou1d. bo::; wh'at aEe. w.e to the 20 yea*rs of spent rods and how are 'You aKe.caro::; 0 36 Just two 00.wi th going to license which 1 doubt bul what would how would. we 18-2~OS.
get lle.cttic if. the license w,ere canceled?
1; don't know.who answer:s this...
fACILITATOR BARKLEY; I! 11 ask Lis.a to speak.
1 MS.
REGNER:
Yes, the spent fuel rods...
1 Limeric~ is licen~ed fbr an individual ~pent fuel pool I
facility.
They offload the fuel.
Once they 've 1
cooled to a ceEtain level they will put those into dry In.
the 1
environmental review that's looked at generically.*
1 Li~e~ick dbes have for th.e, spent fuel ro.ds.
1 That's an ongoing, it' onsi te. and part of their I
reactor bversightprocess i3S well.
So the 'residents:;
that work at, the pI antmoni tor thesa*fe operation of 2,
those facilities.
2 The second quest:ion, where would.the power
- 2.
come from if Limerick were. shut dbWh?
The*te are 2
alternate power facil*i,ties in the area.
- Dave, you 2:4 want to give that att,y?
2 MR.
WRONA:
I'm David, Wrona, a
branch NEAL R; GROS$
couin REPORTERSANDTRANSCRIBERS 1323 RHODE ISLAND AVE, NW.
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- 90 38
,Can everyone hear me 'in the back. row?
I am Catherine Allison :an¢l I was b.O'rn and raised in thie;: ar,ea so,as
- far a's th'eNRC wanting to koo;.! how this the know it very well.
I've also. trave)ed the So did anyone Flot be able to hearD'le, j,ust r,aise YQ,t)r' AC\\,nd.,
You" re go.od?
6kay.
One thing is t'he NRC tonight is doing a scoping basically for environmental for the fe-licensing.
What I wanted to say is for years everyone, If m being general he-re', but most e have be.en talking abOut the e,ff:ects of like" you kn0w, canc::er, you know, the implact on the clean air"
.clean water which thi'ngs' w,e; aTe all conceL'ned about and a
lot 0f us just didn't do anything aboUt it even though we were ve):y cohce.rn,ea.
Now wi.ththe -- 'unfortunately 'it's a reiHity ho.w that i,-ie have hUfiicanes,moretornado,es, tsunamis the' world.
And I hate to say it bm: it is a reality now that we. haVe 'terrorist attacks 1.--..J._-""'_P"'",A""""
19 1 and. Limeri:ck is definit::elyone.
I don't want to be 1'-..,..----'
blowing this oUt o,f proportion bUt it's j.ustsori\\ething that I know that we've, all been concerned about, not wanting to. s,ay' yes, Limei:ick,.ahd all the people tha.t built the power plant and the company sa~ oh, there's NEAL R: GRO.S.S.
COURTREPORTERSZlND TRANSCRIBERs 1323 RHODE ISLAND AVE" NW:
(202) 234'4433 WASHINGTQ.N, D.C,2000:>-3701 wwwn~alrgfoss,coni
- 91 39 1
Prussia.
Talk, about evacuation When disaste.ts and realiti,es hit us,.
One 1
hour backup, almos,t, no 'exaggera,tion" one There will De no evacuation.
I dO,n't 1
scaTe tactics here but. like I
- said, 1
so forth, natural disast'ers, has really whole United States and the world ately SQ it's a There was flooding after the hurricane Lhatwe just had.
Five lat,er 'there, was rQ'ads 2
~losed in Pottstown, in North Coventry, East
- 2.
There,,:rete, when I tried, to get home from work right 2
n Route 724, no exaggeration aga'in from' all the back 2,4 oads about 500 cars.
There will be no evac,uat'iori and understand I'm not certainl 2
NEAL R GROS,S COURTREPoRTERS'fiND TRANSCRiBERS 1323 RHODE ISLAND AVE" NW, (202) 234-4433
~ASHIN~TON;D,C, 20005-3701 WwW:n~alrgfoss.com o impact to the air and nhe wa,ter pollut'ion and so So we've kind <'if. just blinded Q,ur" you know, to that and let's believe then" Qkay:" let's lTlil1ute.
L,et '.8 really believe that there is no in our clea'l'l a,fr, clean water and those of and can!=,~er, et c,etera,.
Let's just into th?
reality which is terrorist a.ttacks which would Let's j,us"t for example 't,here was, human there wi,th the spent fuel,rods and or :a r'adia,tion leak.,
T jU'$t drove tonight of two cars.
l'ike and 19-1-P~
Cont'd 19.2,~OS
- 92 40 1
to. be scare tactics.
I see this.
I'm sure a lot, of you have seen this and been in thesesi'tuations".
All
~19"""~'-:-2--::0""'S'""l' with a l~ttle bit of flooding_
What this does to the Corit'd roads.
Aqain there will be no. evacuaXion.
So from day 'one I think po.wer plants never
~hould have been built b,ut now that they are here why 19c3-0RI
~ould we ever want to.
re,-license.
And as our Thomas, he was very eloquent.
He was stating the fact why are we re-licensing them, what, 12 ye'ars ahead oJ time.
To me that is absurd.
Li,ke maybe a year before I
or 'they have to do s.omestudies, two years before.
I Why do they want us, and love Tho.mas's words, r'-:-:-'-:--:-::::--1 19-4-LR I 14 rubber,-stamp somethihg?
Twelve years befo.rehahd 'to,,go 1
into what, 2024 for Unit 1 was l,t and 2029: for uni t2?
Why do they need to push this lic£hsing renewal?
You've got to stop and think.E'eo.ple, go home, think about that.
I'm hot an exper,t like evidently our caller Thomas was but again, I'm concerned about, human life.
This is what I have at the top here.We are alking about human 1i,£e.
What's more important, not all this e'lect'ricity that w,e need for, all our cell I
2 phones and everything.
In a way we are responsible 19-5-.08 I 24 for the fact that E'ECO and all these, o,the'r Exelon ompanies are building power pl'ants.
I myself you I~~L.~. Ut(U;),;)
COURTREPORTERSAND'TRANsCRisERS 1323 RHODE ISLAND AVE:, NW, (202) 234-4433 WASHINGTON, D:C;2000~3701 1
1 2
- 93 41 Know am gUl.lt'y 0] a lot ort:n1.s nut let s Just ma,yne L
fOE a solut'ion 'besides,the 'wind and solar power and eve£ything stop using all this new technology..
Yes, 4
you, heed it for s.olTle, jobs, and businesses, it's 'g.ood for ce"rtain things, but let:' s not overindulge where we E
need so much electricitythat 'we, are wi 11 ihg' to r,isk OUl' lives.
Cancer" polluted,water.
The re".s. 'no drinkiiigwater' anYmore,.
People, have to pay to QUy water that' comES from natural 'springs.
But, you',re 8
1C using plastic bottles, you can"t even tr11st that.
But,t.his whole world has kind o,f,just 1
'1 changedfrom you know natur,e.
nature, let the
'instead of having all the young 14t:Eeha<;jerS on their cell phones texting; usin9 mo£e I
It electri'city, t'ha,t,again it.' s going to cause cancer tor
,Ethem.
Ever;y'body has to. stop and think ",hy do we need the power plants?
We really don't and again, Thomas, Hour wonde,tfu1ca11er mehtionedsome <;llternat'ive,s like I ~
the solar power" wind, but I'Tn just saying we are 2C using s6 much electricity and stupid l'ittle video games on the computers.
Peopile get on the for h6ursat a time nonsense.
Tha,t's takin9, up 2
elect,ricity where again why do, you need all this 24 2
electriCi,ty?
It eQuId b,e causing cancer in youi:' I children.
I am not that old but I'm not that young 1"'1,.,~,..J~1.:!-6""JH"'"'-H:--II (20.2)23404433 NEAL It GRO,S,S CbURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE:, NW:
WASHINGT<:l~, DC, :20005-3701,
- 94 42 but I hate to." tell yQU I "have so. many f:r-iends and
¢6w.otk.ers.and 35; 40, 50 Qld, cancer.
And.why'?
We have to. 's.to.p and think.
Go home"; don't just al"ways, you knQw!, just go.\\v:at.ch TV and o.n your computer.
Stop and think what we're 19-&'HH C.ont'd doing t.o bodies; our i:::IUldren, Qur This is this tene.wal is coming do.wn.tQ human lives, the ity D£ Qur lives.
this cancer.?
t'li.ctdwaves and So I won't* go on and on, buti I just think: us 'as a can't just all be just compl about the power companies, we are the. 'ones using the electricity.
That's all I' in saying.
we :Should cut back and we wo.n't need power plants..
Thank yQU.
E'AGILITJi.TOR ElARKLEY:
Thank yo.u, Catherine.
The next three. peQple I!d like to call wo.uld be Jeffrey NQrtQn Qf the P.
Energy Alliance, then Bill te and then finally LQ:ttaine Mr.. Norton?
MR.
NORTON.:
Goo.d evenitl9' My name is 2
Nort'on and I'm here to represent the 24 Penhsyl vania Energy Alliance which is. an
'2 grassro.o.ts diverse QrganizatiQn made 'up: Qf G:Qmmunity NEAL Ft GROSS COURTREPORTERS ANDTRANScRisER"S 1323 RHODE ISLAND AVE>, NW; (2Q2) 234'4433 WASHINGTON, D.C: 20005-37~1 V(MV'.ri~alrgross.cQlTi
- 95 1
1 readers and who promote a
- Clean, saf~, reliable and a:fforda:ble power.
I'm go.ing to be making essentially five in:
o.f lic,er.se renewal for Limerick Statio.ns,al'1d,they are' that, nurriber '~ne, lowers elec,tricity prices" it protects against g,r;eenho.use gases, it 'strengthens our econo.Mies arid it is safe.
With r:egard to my first point in the Limerick Genera,tihg, 'S,tation reduced wholesareenergy costs inPennsylvania million in, 2010 thus 10'tleririg electricity prices all consumers.
I:::: operates around the, clock 14 s'tabUiiing the nation! s eleGtricitydistribLiti,on l~
system and the electricity marketplace.
The, avera'ge 1
p'roduction costs at nuClear plants have actually declined more than 30 percent in the past 10 1
years due t.o v:ario.lls efficiencies.
Nuclear power is 1
cheaper to. pr.oduce than other,fo.rmso.! 'electricity such as coal and natural g,as',
mo.derate t,he, pEi'<::e of electricity for 2
My next point is that Lime'ri,zk
'2' St'at-io.n al'ld nuclear plal'lts strengtheno.u.:::
loca.l 2A eco.nomies arid it i6,a Valuable economic driver' fer the 2
Commo.nwealbh c,f Pennsylvania.
Limerick Generating (202) 234'4433 NEAL RGROS,S COURT REPORTERS ANDTAANScR'IBERS 1323 RHODE ISLAND AVE:, NW, WASHINGTON, O,C, 20005-3701 w,.,w,nealrgross,cooj nuclear power as source of points Generating nucl ear:,energy o.urenviro.hnient Toea1 lowering has 20+SR by $8801'-,.----'
fo'r
,th'ereby and consumers.
- 96 44 Station contributes $113' million annually in' direct economic contributions to 'th.e, Penns:!lva:niaeconomy through va*rious employee wages,and salaries I, purchase 4
of g06ds and B,er-vices
'from other Pennsylvania:
businesses and in property tax paymentrs to the local
- i0vernments.
Limerick:
Station a:! so contributes gen'erously as we I ve' a,lso heard and in fact in 2010 contributed
$600,00,0 tb va'tious community organizations.
Limerick has over 800 fuIl,~t,ime Cont'd employees
',and more than L,OOo skilled 1
1 temporary contract employees. during annual refueling 1
outag'es.
A significant of the current 1,
nuclea,r plant vlorkfor,ce will reach retirement age in 1jclthe next 10 yeats crepting a demand for-high-paying jobs in the nuclear industry.
Limerick Generating S,tation is one of Pennsylvania I s most valuable' economic and energy asset-s and the cotr,mo'nw'ea1th should,embr,ace it.
My third poi.nt is tha.t nuclear energy pfotec,ts our environmeht from greenhouse and reduces the need to generate f170m fossi1 fuels.
If Limerick Gen'erating Stat'i,On were retired 2
from service replacing the electri,city would require 2.4 fhcr'eased natural gas'-fired or coal-fired generation.
2
- Nuclear energy is the nalion I s source of N~L R: GROS,S CQURTREPORTERSAND TRANScRiBERS 1323 RHODE ISLAND AVE:, NoW, (202) 234'4433 WASHINGT9N,D,C,20005}701
- 97 45 carbon-free electricity and is critical to our ri at i6n "s.environmental, se'cu'r'i tyand energy go'als.
My next point is that nuclear energy is
.safe..
It's always, on, it's $,table, it':S a r,elt:able source of electricity and' the: station here' 'at Limerick has been built with multiple, redundant
~a fety layers.
And the workforce is committed t*O' best practices and
,-:;ontinuou3, improvement.
It is ~lso irriportaflt for our nation "s quest to be energy~independent..According. to the Bureau.0J Labor Statistics it's safer to wo.rka~t a nuclear plant than in industries such
- as manufacturing, real estate and finance.
And. aCi::::ording to the Department of Energy a person receives more r.adiation exposur.e flying from Baltimore to Los Angeles than by s,tanding near a nuclear plant 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fOr a year.
On a
personal no*te I've been inside Limerick Generating Station several t*imes.
I've also iived within 30 miles with my four boys and wife nex*t to the Limerick Gen.eratin9 Sta.ticin and also Thre.e Mile Isl'and.*Ifeel safe, secure and comfortable.
T,hat i-s why I'm in support of the re-licensing df the Limerick 2
.4 Generating Station.
Thank you very much.
24 (Applause)
FACILITATOR BARKLEY:
Thank you.
Mr.
NEAL R: G~OS.S COURT REPORTERS 'AND TRANSCRIBERS 1323 RHODE ISLAND AVE:, N.w.
(202),234'4433*
WASHINGTON., D:C: 20005-3701 w,..w:nealrgioss.coni 20~1-SR I Cont;'d
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- 98 54 three people I'll call are Donna Gut'hbert,.followed by Mike Gallagher.ahd then follbweel tis: Dr. Fred Wint'er..
Oka y, Donna, MS.
CUTHBERT:
some of these gentlemen speak tonight. t fe:el like 11m 1
in fantasy lahd..
Ebi:' somebody to and actually. say that there ',s '1'10' adveTse' *impacts, f,rom Limerick nu.clearpower plant is, It is unbelievable,.
I have
-spent the last.
11 years permits from Limericknuc;lear plant.
They are a major air polluter under the Clean lXirAet
'anel to say they're not d6ingi t any,moE¢.i asked for the conditions that would allow increase in dangerous,ait pollution theit claimed to kill people, thousands of deaths per year.
And they asked for an eightfold incr.ease..
As a matter of fact, these *a-re all the air luLi,on sources and the pollutants theY lis.t Hi their own permit.
if you add tha,t to all the an is radiation
'emissions there,*s bro.ad range
,of radionucliGes..
For somebody to just claim that i.t' s only tritiumgo'ing into the water 'is It's unbelievable what they expec.tpeople to believe'.
I encourage eve:rybody to back to the tal::ile 0'8 haVe and take,a good look at t,hat River board.
NEAL R: GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE... N,W.
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They are destroying the Schuylkill R+/-ver~
There was wat.er. in the Schu,y;1kill River to sustain this nuclear plant from the very beginning and now we're,seeing the consequ'ences of thataIid* they put more and more pollution,in i.t.
They want to pump mine wate,r in t6 supplement t.h.e flow f6:r Limerick.
Tt's contaminated and they don't filter it.
And they're actually asking for a huge, fOur times Safe OririkirleJ Wa*t*er standard increase in. total dissolved soli:ds which a lot of toxic pollutant*s.
So they put radiation *into the river 24 [YOurs *3 da::{,
365 days a year; 'arid n6w they're: asking f'or these huge increases and have the nerve. to get up here and: :say tha,t they have no environmental impacts.
Frankly I'Ve haa enough of HYisdeception at the expense of public
~1 The facts show" when we' looked at Exelon! s thing fo,r environmental harms they say they-were clean energy,.
The facts show Limerick isn '*t: ciean, it,is i1thy,.
It's. not safe, it's a ticking time bonib.
And ruclear power:, they sayi t S
always on.
Tha't "s not t
/--L-_..,-,
1~24-PAI If tueeithet as: 'evidenc.ed byshutdo.wns, some. f6r lonc:j'r-...----'
per*iods caused by earthquakes, tornadoes, hurricanes, lFi*res, heat and drought and more.
Itcleady isn.'t always on in Japan.*
So when you take all of this NEAL R; GRO~~
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(~02) 2~4-4433 WASHINGTON, D.C, 20005-3701
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,toge,ther and you look at all the ways that th'ey pollute oUrenvironmeht with raqiation and all the othe'r tox-ics, every day.,Limerick opeTates our children
- '1 faqo mor,e risk',
And thaT's',What it's all about,
'It's about the health of our regi.on" The sooner this ace,c165,es, the bet,t,~r off we'll all be, Even if you'look at infant mortality ra,tes we have infant mortcdit:{' rates and neonatal mor1::allty rates far above st'ate averages aht.!. even aboye Ph'iladelphia and Reading, and, vie've had these for quite awtc!ile.
The fact ds when babies are r.1-:':~2:-::5-:'-H":':"H":"11 the most vulne'r:able in the, wbmb what else, w6uldwe expect'?
And by the way, for those of you who have been sayi that ACE da'ta is ahe,cdotal today I have news for you.
This infant mortality report for pxamp]
is state data report"Od by EPA ih 20.0..3,.
Ev,=ry cancer stat:is,tic that you see back there is based on Pennsylvania cancer Registry statistics or CDC statistics.
So i1:: is not anecdotal, those are the cancer increases, 'those are the cancer above the national average that have happened here since LimericKstatte,d operating, That is a fact, So it's notanecdot:al and the fac.t of the matter is I thought this was aboUt the environr'ner:tt but apparently it's about mor:tey.
So L decided that NEAL R. GROS,S COURT REPORTERS AND TRANsCRIBER'S 1323 RHODE ISLAND AVE" NW, (202) 234'4433 WASHINGTON, D,C:200q5-3701 WwW*n!.alrgross.coni
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- 101 57 bet\\-leen the sessio.ns I
\\-las go.ing to. change things arouno.
a little bit.
I co.Old ta1kabo.ut the environmental impacts o.*f this pIace* fer a \\-lhGle \\-/eek it':~ so. bad.
And I've got.all the do.cume*hts in o.ur office to prove it*..
Let's. talK abo.ut, let's take: a minute flew tho.ugh and w.e I ri;; gOing :to talk.aboLlt the cost..
rinat is this actually costing us~
Let's j Llst think about cancer fer W.e haVe sbmahY cancers abo.ve the national average.
Childhoo.d cancer, 92..5 percent than the national aver:acjEL Think about that.
,oJe track the cost of o.ne child\\-llth cancer. diagnosed at sixmbntns to. two ana Lip cmtil that time it was $'2.2 millio.n.
Hew many *mo.re kiEishave that abo.ve th.e national averacje?
Cost that out and how many other cancers are above the. natio.nal average?
You.do. t*hemath.
thatbOL Hew abo.ut the customers that paid I
heat t.hem talk abo.ut hew:.i;)'t.eat the co.sts ate fOr Llmerick.
Ne fer time rick from 198& to. tOlD in 1-27-08 our electric bills.
.And in fa.ct t'he electric that was suppo.sed to. be teo cheap to meter turned. out to be 55 petcen.t above the national ave*rage. by 1.9.97.
So. tha.t
- s how cheap Limerick electric is.
Then you take *the pto.pertytaxes..
The:y trted to. get zero for their property t*axes by the end ~.-----I NEAL It GROS.S COURT REPORTERS AND TRANsCRiBERs 1323 RHODE ISLAND AVE:; NW, (202) 234'4433 WASHINGTON, D.C20005-3?01.
WwW,nealrgross.com 2
- 102 58 f the ' 90s and didn '*t pay any property taxes un,til the early 20DOs at which time they paid $.3 million 1,28-SE instead of the million were.. supposed to pay. Con'td
- 4 Sowheh y9.U t!1ink.abqut that no wonder *Exelorj.' s around a
couple million in the thiscqmniClnity a lot more than out.
MS.
RUE'E'E::
So then there' sthe cost for the poll ution re ih the river.
Ire asking for increases in pollution.
want to put more mine water in..
':'hey.want to increase. the.total dissolved salts.
That's going to eost water treatment systems a
lot of to try to 71 tbt extra 1-:"""'_1'-c""'_=S""'W 4
O treatment for that.
It can even break down their
.equiprr;enL,some of the snIff that's co'mirig but of the mines.
And when you think about it who actually ultimately pays that cOS.t'?
Vje do.
We.
tot increased cost*s forohlr water* because they'r.ehaving to do that at the' water treatment And it seems to me that if you. really take a good '1-ook at things Limetick has got to be the major c.aus.e for the radiation in E'hiladelphia's water.
So. all inaH. taken as a whole this has unprecedented envilTonmental harms.
There is no NEAL R: GROS.S COURT REPoRTERSANDTRANSCRisERS 1323 RHODE ISLAND AVE:, N.w.
(202) *234-4433 WASHINGTON, DC 7000?-3701 www.ri~alrgross.com
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- 103 59 question about that*.
Anybody that* doesn't believe it dome lo.ok a't the perinits w1'th me cand I'll show you exactly what's going on.
I invi,teanybodyto do that.
And the..one thiQg thciVs r..ecilly impc,rtarit is that NRC and *t*he nuclear industry are claiming that 4-11~OS I age is no issue while.at the. same time the:y admittha.t some parts are t*oo big and,too expensive to' replace..
I :frank'lyam really conc.erned about NRC accoinn\\odating the nuclear industry with weakened regulations, lax enfoTcement,negligence and unsubst'antiat'ed denials.
4*12~OSI It's happened right here even with their* fire saf'ety regulations that are --
w.e! re o*riweakene.d fire safety
'regulations even thoug'h we*
know that.
that can even.tUa11 y lead to a mel.tdiywri.
I *kno.wmy time's up.
Thank you.
(Applause)
E'ACILITA'IlOR BARKLEY:
Thank you, Donna.
Mike?
MR.
GALLAGHER:
- Oka:y, good evening.
My riSme's Mike Gallagher arid I'm vice president of license renewal for Exelon..
I havet:he overaLL
'responsibility for the Limeri.ck license' renewal application.
Exelon has a great* deal of experience in licerise renewal.
We.'v'e obtained renewed licenses for the Peach Bottom and TMIplants in Pennsylvania, also NEAL & GROS.~
COURT REPoRTERS AND TRANScRiBERS 1323 RHODE ISLAND AVE, NW.
(202) 234'4433 WASHINGTON,D.C; 2000!;-3701 2
- 104 68 FACILITATOR We have an inspect'ion, ongoing at 'that point right now, the North p.nna facil.i ty.
So yes" it did'experience an e,'l'rthqua](e:
its oEiginal,,design.
Sp fa:: the inspections have revealed no -- minimal damage.
only h.eard 6f pne even visible, sigfls of prob'lems.
But,the overall analysis, this is co'htrriuingahdthe licel'lsee has to have permissi'on,f,rom us to' restart after an ext:eflsive inspection.
MR. ELY:
My concern is that this hastened license renewal
- proGess, is engineering reasons.
I worked in a
vari,e:roy elf 21-1-08 different areas in the,constructibn of that power plant and thel"e We,re cont:inua1 deviat.ions that were prbvi;je,d, wh,ethe:r it was i
maintenance monitoring of the condition o,f the components that were used the, a'ctual construction of that plant.
I could ci,t,e.you several examples.
What I \\ii,ould like, to ask of the public is that the people that had, worked at that nuclear power
~laht take,3 look at this lic~nSin~ renewal and understand, that they need to review those failures and tho,sede'liiations that were provided to go ahe,ad with the construction or that lant wit'h Bon-conformances NEAL R GRO,S.$
COURT REPORTERS AND TRANScRIBERS 1323 RHODE ISLAND AVE" NW:
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- 105 69 that we other
,the pools.
There quality engineer" very highest grade hour pour there 'and cofferdam was Being comes this sand mix pumped upihto thci:S:e the engineer said inistake, but it'll be take a' look at all of
'that they're not writteh structure under load caused an isslie.
It might not Be of the fuel pool girders to that when we see them in Japah because they're extremely hot and that.
I was cin that pO,ur but I that made that error" but there's 24 that,were m'ade.
Ahd, I don't see
'2 the NRC or the review or the licensing applica,t,ionis (202) 234'4433 NEAL R: GROS,S COURT REPORTERS AND'TRANSCRiBERS 1323 RHODE ISLAND AVE, NW, VVASHINGTON, D:C;20005-3701 were reviewed, but not rev'iewed in light of what uhders,tandand know tod'ayabout earthquakes or anomalies.
We need' to have enough,t,ime to make eValuation
,on those deviatiohs.
The cooling The fuel poul g,irders tha,t arepla'ced there:.
ar'e rebar concrete re,inforc,ed 5upportswh,ere a he was supposed to be accepting t'he of c.oncrete to be 'pla,ced in a 36 he didn "t pay attention.
And the built down ih the river and,up with a very low strength and ~ets fuel pool girders in a ia:y-er and
- well, boy, that was a
terr-ible okay.
We ne,ed to go ba,ck ahd those mistakes and make sure off Because a
layer ih a by an earthquake, tha,t' s an iss,ue for the strength support those,fuel pools and the¥ cat,ch,fire you need to address wash' t the ehgir'ieer a number of errors or und,er'stahd tha,t 1
1 1
1 14 1"
2
- 106
'2 2,4 70 taking' a look at those failures anCi, t'hose errors and addressing t*oday.
them,in liSlht of 'the, that we h'ave 21-1-,08 Cont'd
$qme PePple don't unijej:'scahd ab.out radiati'on and :t read when the ;Japa,nese thingocc;,Jrrecd and I hear,d on the news a radl;:Hog,is.t talking about oh, the radia.tion-is such a low amount'.
I't really isn't the low ah\\b,Unt of radiation exposUre tha,t we incidentally 'in standing next to a
nuclear power 21-2-HH It's, three teri-tho,usandths of a
gr.am of plutonium that is death fOL-you if you breathe that dust particle.
It*, s almost certain death.
And t,he problem becomes you can' thave --
and it's not to be, a nuClear bomb.
It'~goihg to catch on fire if the fuel pool girders were to fail, and you'II have a cloud of a materL31 that in and of itself you might n0t have radiatfon exposure to it but that cle when it deposits its,elf can be an issue mlfch the,same as fluor-ide is what* 'caus'es cancer when it' 5 a radioactive fl u*oride.
That's why we're, very care,ful in a plant with no Tef10n and no fluor-ide components.
So we need to pay attenti'oR to some of that engineeri'ng and I'm not c,ertain that,that's being done.
I'd like to se'e' an agency OJ? for.somebody to NEA~ R; GRCS,S COURT REPORTERi:i'AND TRANScRiBE'RS 1323 RHODE ISLAND AVE:" N,W, (202)234-4433 WASHINGr9r:J, D.C; 2000~3701
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- 107 1
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2 71 contact me if they know about ;a variety of different flaws t'hat they saw dufihgthe construe,tioD.
.J'\\nd my email addressisa*sqchaLr@yahoo.com.
Yes, I will be the chair of the PhiladelphL:l s,ection of. the Amerie:an Society for comi-n'<g uP' and I've been chair ih the (Jas.t' S0 I'm very quality-oriented and I'd appreciate* any feedback from people that have issues with that 80nstruct'iofi.
Thank you.
FACILITAT,OR BARKLEY,:
Okay.
Thank YOu; Dan.
Jim Beckerman?
MR.
BECKERMAN:
.GooE! even*ing.
My name, is Jay Beckerman.
I'm a resident of Phoenixville.
I*
fQunE! out aboutth'is meeting becaus,e I scan a lot.of ne\\vspaper websi tes.
I found the notice of the, meeting on the West 'Chester Daily Local website,.
it in the Phoenixville: paper, didn't see it in the Ph'ilacieYphia ne4spaper, cJidnlt heaT about it on any of the local radio stations, didn't hear about it on cable, didn't hear abOut it tin any Qf the televisiOn.
Once a month, what is it the first Tuesday about 2: 00 I hear the siren that we all hear.
What should happen in terms of people gettiAg notice is ev-efybody who's within the area should something happen at Limerick should find out about, this NEAL It GROS,S COURT'REPORTERSAND'TRANSCRiBER'S 1323 RHODE ISLAND AVE, NW, (202)234'4433 IJI(ASHINGTON; D.C, 200~3701 v,ww,nealrgross,ccm 2
1
- 108 72 and I seriously doubt that that actually I
think it was pUEe accid\\2nttha.t I found it..
S.ome:thing as seri:ous as license ren'ewal should. get the same ki*nd
.of oLiti'ea¢h that occurs wfien Limerick does wna:t;: it s'hould which is to, mail out every year o*r two to a'll ' 22~2cLR bfthe possibly a ff'e~te,dhorries the maps ahd the no,ti ficatlons o,f how do you.e,vacuate'.
Tf you' r*e to tEmewa which once every 20 years I don I t understand why the NRC doesn't require the :same
-kind of outr,each public' hoti fication so people get a chance to come to one-time meetings like this.
I think that is.a basic fla.\\f in the NRC's licensing and re-licensing procedure and I think it should address that.
The slide behind me documents exactly two libta~ies that the docLimehts are to gO ih.
vJhy 22-3-LR not in my library in Phoenixville?
Why not in Mont9ometY County ahd. Nb'riistbwn ahd all of the other publ*ic libraries that are in areas that can be
,affected
.the pJ"um:e should Why a*re the documents in such a restricted area:':'
I'd like toswit,ch a nttle bit.
been resea.rching, I didn't even know about thisF,CE org*anizati6n.
Glad to firid it.
I've been on my own information about nuc,lear power plants and NEAL R; GROS.S COURT REPORTERSJ'l:NDTRANSCRISERS 1323 RHODE ISLAND AVE, NW, (202) 234'4433 WASHIN<;>TOt:J;D:C.2000~3701 www :n~alrgross,com
- 109 t,heir risks for quite awhile.
An organizatioFlI ran i shed this booK ti Ued Insunri01ihtable Risks.
The' organ'izat~ion is called the Ins,titute for Ehergy ahd Enyironmental Research.
It's an well-researched book.,
I doubt very many people have read i,t but you should.
Thi 6rgani,zationis at least as *interest'ed in' alt:ernative en'ergy sources as it is ih hav'itlgpti,t th,e, effor,t iii to document',what,ar¢: th'e vIi th nuclear power engi~neering-wi se.
- r*he man who's head of
,this organiz'ation, is a
nuclear He's a PhD nucle.ar scientist*._
These, are: fir:st-class researchers, this is PhD-level stuff wEitten for popul'a,r So I'll,be 9'lad t,b make riloredetail about the book ava'i lable to an:/body who wants to know_
p,~ few I have, one that I~ve beeh about for a long time_
I wonder,how many he'te a':::-eaw,are, of something called.the P,j::ice Anderson Nuclear Industries Indemnity P,.ct_
Who knows 22-4-08 about th'at?
The title alone should s'ome'r-...,---...J pause.
Why do we need a nuclear industries indemnity act?
What does it do?
What,it does i sit puts a ceiling of a
few hundred million dollars on the liabili ty that nuc1ea,r power pla'nt owners have fQr the damage' their plants would cause _
It' 5 basically a NEALRGRO~S COURT REPoRTERS AND TRANSCRiBERS 1323 RHODE ISLAND AVE" NW, (202) 23+4433 WASHINGTO/>l, D,C; 2000~3701 w...w:nealrgros$,com
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- 110 1
1 1
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24
'25 74
.l. e proU.J.em lS Ll:aL
,:eil i'ng was set a very 101i9 time, ago.
It 's, tOtally:
unreali stle in terms 0 f the ri sk in just the va,l ue, of 22-4-08 I Conrd h9uses, in areas that are t:,bvered by a plant lik,e this.
WJ::lenthis plar.:tt was anned the population in the a.rea that it",' pluine 'w0lHd cover wasn't 2,0 percent of wJ::lat the population is now.
That is I think a valid environmenUll concern.
The 'environment in which this plant ope,rates has:
because of in-inigration~ p,opulation increas,e for all sorts.of reasons.
Part of that's been discussed tonight,in terms o.f evacua'tion y,rould :you be able to get people out were there an accident.
The roads haven't changed very: much, the popUlation h'as,.
That I thi"tlk is a valid envitonmental concern that surely ought to be actdr.essed..
The questior.:t I
ask about:
the money llablllty lS let s
~ust go bac:k to the Prlc;e Anderson Act.
The fact ds that the nuclear
- ry does no,t pay matke.t rates. for insurance to cover it for the liabilities.
This congressional act f*rom way 22~6*08 I back in the 19608 e'limina,tes that ne.ed.
Back Then the insurance industry didn't have the resea,rch to put a price onwhat8hduld the Limericks of the world have to pay for a liabil,1ty policy.
I think there's plenty (20,2) 2~4'4433 NEAL R; GROS,S COURT REPoR'TERS AND TRANsCRiBERS 1323 RHODE ISLAND AVE:. NW, V>{ASHINGTOI>/,D,C; '20005-3701
- 111 75 of insurance, industry,experience, now.
So my question would be i.f nuclear the Price Anderson Act?
(Applause)
I: listened, Pm going to switCh subj ectsagain.
I listened to Mr. Gallagher and I heard something I rea:lly dldn I t expect. to hear:.
He said that their studies, sa:i:Cithat thispla,nt is now saeeto run for 60 years.
That sounds to me l:r:ke adj;ranced notice to the public tha:tthis isn't the fi*rst renewal they' Ee going to ask for on this plant.,
ME. Gallagher, are you going t.o ask fOE anothin one 20 yeaTs from now?
FACILITATOR BARKLEY:
We, hayen'T had any licensee at this point in time ask for something that.
MR.
BECKERM~:
Ybudian't make the ata temei'lt.
Mr. Gallagher did.
FAG:ILITATOR BARKLEY:
I know andl' I m not to have him address this from theaUdi ence.
Tht;s is a meet*ing with us.
MR.
BECKERMAN:
lind I
would like to 2
finally address an issue that the speaker on the cell 22-7-08 phone up.
He talked aboutembti ttlement.of 11-.-----'
2.4 2'
concrete' over the lifetime sa faT of the nuclear N~A.L R;GROS.S COURT'REPoRTERS'AND'TRANsCRlBERS 1323 RHODE ISLAND AVE;, NoW, (202) 234'4433 WASHINGT()N. D,C; 20005-3101 WWi/nealrgl'OSS,com
- 112 76 reactor con'tatnment vessel.
That's an internal en~irofi~~ntal m~ttet.
the scope of what the I
NRC don't plans know if to talk it '.s about quit'e.in
.or plans 2::\\7-08 Con'id 4
to look at" bCrt $bmething t'hatI have not r'ead ao.out at all is an i~RC for destructive testing.
For instCjnce, if you want,tqkn.ow what a tree lo.oJ<:s like on the ins*ide you put a borehole in it.,ana you pull a co't,e s'ample out and find out whiit tf.!'a.tt'ree looks I ike on the.i nside.
I f an engineer wants to 1
,know what is the of the. concrete that was I
poured for a
road I
used t*o work for Florida 1
D.epartment b,f Transportation oor,eo.uta sample nd then you take a 100k at it.
What I haven't heard nythihg about except zati,ons is has anybody one 'any destructive even *borehole testing of' these I
QriUilnmeht vessels ar:\\d th.sir pourihgs to fifid ut has there been in any deterioration of the 1
22-8-08 bnc-rete, the *reba*r ;;Ind anYthing else thatweht iii here.
The that's buried in the concrete, the i*re" all..ofthos,e things that *are buried in the 1
oncrete.
If you.haven't 'bothered to open that. stuff 2
'2
- P since the plant was b'uil,t how' ori earth do yo.u know
'2 hat condition it's iFl?
Shouldn't.
that be a
e'quirement 't.o do some destructive,.open the b.6tt.cim 2esting, go all the way through and make sure what you NEAL R; GROS.S CDURTREPoRTERSANO TRANSCRiBERS 1323 RHODE ISLANO*AVE., NW.
(202) 234-4433 WASHINGTQt'.O.C; 20005--3701
- 113 think is that it years?
there is what I sthere.and shoula be into last for So.t*hese are questions tha-t 77 in the condition another 20 0E 4.0 I'd like, the N'R<::
2~-8"OS Confq 1::.0 go into.
I: thahk very mLl<::;h fot.
listerlirig.~
O:ver-all it S been a very info.rmati vee presentation by I
both thE';; ptoponE';;nts ahd p.eople whbhave questions ahd I thank yo.U for the opportunity.
I would like to see El. 'mee*tihg IH:-", this: oqcur. at a bigge*r venue wi thmofe notice.
An example would be,ast've discussed with is.it?
Ms..
FACILITATOR BARKLEY:*
Regner, yes.
lvlR.
BECKERMAN :
I didn't have heEname correc.t.
The EX'po Center would be 'more central to where the pl"l.ime.area for this is.
It's right off 422.
This is not hard to get to, that I'S
.hot. hard to to.
T1:: '.s much mo.-r.e in th.e center of the population.
Thank you very much.
(Applause)
FACILITATOR BARKLEY:
- Okay, thank you.
Mt., Cuthbe.r.t?
Again, following Mr. Cuthbert's. remaTks it'll be Jim Derr to. wrap up the evening.
DR. CUTHBERT:
Good evening" My hame is Dr. Lewi s Cuthbert.
I*' m the president' 0'[ ACE, the Alliance fbI' a Clean Environment.
Ahd my co.mments this evening are going to -ai ffer from. this afternoon NEAL R; GROS,S COURT REpQRTERS'ANDTRANSCRIBERS 1323 RHODE ISLAND AVE:, N.w:
{202) 2~4l433 WASHINGT()N,D.C;20005-3701
- 114 78 because they're going to be focusing on as a geneJ:;al topic documented evidenc.e.
We.'ve: heard a
lot of assert'ions, assumptions and cla'ims throughout the day
.4 many o.f. which\\:iould be very difficult to ?ubstantiate in our experience~
Based on an II-year investigat.ion conduc.ted by 'the. Alliance. fora Clean Environmentw.e have formed a cOl'1clusion that we are present*ing to the NuClear Regulatoi:Y Commis.sion today and that 'is very r.-'=-=-=:o 1-29-0RI simply that Limerick nuclear power plant must be I-,.-_.....J closed. by the NRC, notre-li.ceOsed.until 20,49.
.And
.that "s based 01'1 a
substantial, body -of evidence in 1
terins of. documerited environmental harm's, threats, and 1
'risks that have in fact gotten i*nto 'our a-ir, our 1.4 water; oLir soil, ou'r food, oUr' milk a'nd oLit children..
The evidence is not refutable_
So I'll be presenting as part of my remarks tonight what I.'m calling a short list* of 14 reasons why the NRC may feel free to with mor.e than adequate j usti ficat*ion deny this permit.
And I'm
~oing to categorize each of them very brieflY without any furtl<lerdescription or analysis,.
The evidence coine's froin a variety of permits, official records and Z
reports, al'1d Exelon's own renewal applica'Lionwhichis 24 sizable by their own adinissi.ol'1 and in our experience
~
in taking a look at it.
NEAL R: GROSS COURT REPORTERS AND TRANScRiBERS 1323 RHODE ISLAND AVE, NW:
(202) 234-4433 WASHINGTON, D.C, 20005-3701 1
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- 115 79 The 14 items any' of which in our should,be adequate and sUfficient t6 den.y tht's permit 1-31-AM I 1-30-RW I
,ef1ewal
- include, nurnber 1, rad1at*ion into air and
~ater from routine and, accidental emis,,!i,ohs.,
Number 2, major ",ir pollution under health-based standards. of tne Clean Air Act.
A Ti.tle 5 'germi,t being, iss.ued to this
,means by definition' that
'are a ma.jor' air polluter under the, federal Clean Aii' ACt.
Nurnber Schuylkill River depletion and major 3"
1-32-8W I drinking water contamination.
Keep in mind this is a:
vital drinking water source for neaTly 2 minionl
- pe6ole, from here to PMihidelphL3.
Number 4 '
-radioactive groundwa.ter contamination.
Number SI1-33-GW radlatlon H;pOrtlng
.leveJ.s lncr",ased dramatl<:;aLl.y 1-34-RW I after the tukushima Japal'l drsaster.
Number 6,
documet)ted alarmil'lg c,ancer increases' especially in out 1~35-HHI chIldren since Limerick. st'arted operating.
Number 7,
deadly high-level tadieacfi ve ",aSte.s that are packed I
1-36-RWI in vulnerable fuel pools on this site,and they are' in fact unprotected.
They are aboVe ground and unprotected..
Number 8,,lax fi,r:e safe.ty regulations 1-37c08 I and multiple "/ioiations.
Number.9" accidents, and leaks from corroding, de
- i equipment plus 1-38~OS I miles of buried pipes arid.cabl.es.
Man:y problems and shutdowns have already occurred. at this facility in NEALRGROSS COURT REPORTERS'AND TRANSCRIBERS 1323 RHODE ISLAND AVE,. NW,
(~0,2) 234"4433 WASHING'!:q/:l;DC, 20005-3701
~nealrgross,cOl)i I
- 116 86 I rL-::-:--=-::,-,
1 1
1 1
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2 2
2, 24 2'
its first 26 years of oper;;t!:ion.
They,aTe a matter of.
1-;38~OS I Cont'd recOrd..
Number 10, increaseq risk bf mertd6wnsfrom
- more, a,nd stronger earthqua'kes and other 1-39-08 1
natural disast,ers.s,uth as tornadoes ahd floods, not' to meFltion mechan-lca,l failures.
Number 1*1, threa*ts, from urig,uarded t,ertoriStat::ta.<ikswlth planes, andmH'-siles 1-4o-.oSI and a
new' threat, cyber at,t.acks.
Fuel pool are vulnerable t6 attack.
Number 12, OFle
'Ghat I
think.probably should j limp t6 the head 6fthe Ii s.t for the NRC b,ase'd on a lot of comments from a lot of other ana'lysts aFld elected officials, the ne.ea for an upda.ted eva.cuatiorl plan and increased a 10-mile radi.us..
This plan 1-41-0S.
is seEio\\.isl&
outdate.d.
It is by many,expert's 1
observations fa.tally.
[clawed.
There: will be no evacUatio'n in 'the event of a worst case scenari,o.
Several e
spoke to that this eveFling.
The population in this area has increased more than. 180 perceFl'G since 1980 to 20tO, U..s.Census data.
Upda,tes are obviousl'y needed ahd
,should be reasonable, det:al*led and accommodate all of the demographics from 198.5 to, today ahd from today,until as far out::' as the NRC is willing to license this facility.
II Nu,mb'er 13,. increasedc0st to the public. 1,-42-0S I NEAL R! GROSS COURT REPORTERS'ANDTRANsGRISERS 1323 RHODE ISLAND AVE;. NW.
(202) 234'4433 WASHINGTON;D;C:.200q5-3701 wWw*nealrgioss.corri
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- 117 81 We've heard a little bit about this this eYening, more cancers, mote 'illn'es ses, more err\\erg'enc'y roOin vi sits,
- more, izat"ion from increased PM-lo..
Massive research 9n 'what iculat:e ma:t:ter in, tern',s of PM-lo.
does to human beings,.
And 't'here are a few other tnings that contripute to those visUs.,
,The,costs af~
One 'case that Donna mentioned, $2.2 mill ion for a 8hildhbod c:ahce,t cas;e,You 9otri~ math" i:l.nd number 14 f the last it'em on my tist.
e have had 26, ye'ars of insults t'o our environment;:
1-43.AL and I
choose that word purposely, insults to our environment and costly,nuclear power" it with safe, Clean, renewable energy before 20.29.,
That is a mat,ter bf sci'entifi,c fa,ct, It is a scientific certainty that harms, threats and risks to our environment :arid to our community will increase
'continuously LimeriCk's current licenses re in 20.29.
It would be both unethical and 'irresponsible for the NRC. to. cavalierly a' lic'ense renewal without the most rigorous review' andj usti fication, in the history of this ag'ency.
- NRC, opportuni,ty before you that most people and agene,ies rieverare afforded, I,t I S,c,a:lled a do-ove'!:"
a chance to. correct a litany ofmist'akes and erro.rs associat'ed NEAL R; GRO~S COURT REPORTERs;t;NDTRANSCRIBERS 1323 RHODE ISLAND AVE, NW:
(202) 23<F4433 WASHINGTON, D,C,2oo1)5-3701 (w,W,nealrgloss,ccm 24
118 82 with this :facility and with your agency 'sincel9*85.
Twi=ntieth cen.tury techno16g.y aHd infrasttuc't'ute.are no sufficient**ly rel;iable: fOE any of you to assu*re 4
us that there l.s:.nothing to fearahq no'thing about whfch.to be concerned.
Benial of documented evidence is no lOhger an option.
We! 11.
be submitting additional of research documentation and evidence tor-light aloh9 with my commEmtswhi.chwill compl,imentwhat I
did earlier today.
The major categories that you"ll be ge'tting fO.r a:dditional 1:'eading and
- review, mel,tdol-m
- threats, evacuation plans; Exelon "s incfccutatt"j and unsubstantia:ted cIa,ims and a criticism *of the NRC's oversight t,rack record in this,.com.'iiunity.
Thank you much and' please a¢c,ept this for review.
(Applause)
FACILITATOR BARKLE:X:
Okay, thank, you, will.
Thafi*k Mr. Betr?'
MR.
BERR:
Good evening.
I wO.uld.
add some comments just tofuake sure my understanding is,that this isessent'ially the NRC's opportunity of listening f6r thihgs Iy to be incl uded in the envi ronmental sH:e revlew of the re-And jUst a few things 'which.ar.e question marks that lots.of folks in the community I thi-nk will NEAL R;,GROSS COURT REPORTERS'AND TRANScRiBERS 1323 RHODE ISLAND AVE:, NW, (202) 234-4433 WASHINGT()i':l, D.C. 20005-3701
~.n~alrgross.corri
- 119 83 be interested in.
Host: of these have been touched on.
Mine water:-
- issue, better defining tnat quality and flow particularLy i-n lightr of the likely pending ch21n.<:;les in stbtmwater conceiTlsaIid in the. aTea.
that flow to the Schuylkill is going tciaffe:c:.t all 't'he LUes around ne.re who:
The emergency plimning is anare'a Which needs to be seriously looked at.
Hard and -soft 123-2-0S 1 irifrasttl.lcture on that.
ly that's something 1
I which i,s part of the ongoing operat.ional requirements fo.r periodi.c review.and update since obvl.ouslY thi.s is not a static- :envi-ronment we live in.
That has to be t::hanged on an ongo'ing basis.
And then. to 1'm sure 1
the generic plan includes a
pretty' good 23-3-08 I 1
~ise;'ussion of filel storage long-term and shott..:term pnsi1=e' but ce'r:tainly the site-specific fuel storage onsideratiohs.
And I w.ant to second the corfuhents' by 1
HL Ely of review of records 'of non-conformances' ane 23-4-0S I anything. that was done is. part of the fhinal construction record.
And basically that's --
those
- 2.
ar.e the tnings that we I re* going to be lodkingfor a
'2 better understandingoL Thank you.
24 (Applause)
E'ACILITATOR: BARKlEY:
I did have olle last N~LRGROSS COURTREP0RTERS'AND TRANSCRIBERS 1323 RHODE ISLAND AVE:, NW, (202) 234-4433 WASHINGT()~; D.C, 20005-3701
- 120 84 request for an *individual to speak.
'Shepromi ses she' lionly be two minutes so we! 11 have he[ up and then we'll wrap up the Thank you.
MS. CONFER':'
Hi, my, name is Tta,::l~onfet, I'm with Energy JU8ticeNetwork.,
ehergy wliich we do flot b,eli'e,,v;e Iiucle,ar is.
I would 11*ke to put our name behind a11 of Buzz ubhbert' 8 want to a,d(j that I wal~t the, NRC to loo,k 1 water deplet10n issues f,rom shale gas 24-1-SW in both rtv-,ers.
I also think. that it and I rackirigupriver would be very: prudent to put a lot of' attention ter-xoI-ist attacks on the fuel And those are primary comments.
Thank you for your time.
(Applause)
FACILITATOR BARKLEY:
- Okay, thank you.
With that I'd like to have Lisa come; Lip for a minute: and give, closing remarks.
MS. REGNER:
I j us t to real qL1i*ckly thank our senior resident i
who came out tonight o,ut of the goodhess of hex heart.
She does not get paid for 'Chis.
Jo, wouId you. mind standing uP?
(Applause)
MS.
REGNER:
Thank you.
This i'8 one of the NRC inspectors who works at the plant day in and NEAL R,:QRO$,S COURT REPoRTERS'ANDTRANScRIBERS 1323 RHODE ISLAND AVE" NW, (202) 2:J4:4433 WASHINGTQN. D,C'2000~3701 w...w'0!e'alrgross.cooi
- 121 -
Mendiola, Doris From:
Sent:
Camilla Lange [camiliange@verizon.netJ Monday. September 26.2011 2:20 AM
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To:
Subject:
Regner. Lisa NRC Public Meeting Feedback
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Dear Ms. Regner:
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I attended the NRC Limerick Generating Station License Renewal public meeting at Sunnybrook Ballroom on 9/22/11. I listened attentively to comments from alliS speakers at the evening session and took into account all the pro and con argLiments presented. Despite all the reassurances from Exelon representatives about the safety and efficacy of the generating station's nuclear power, I have serious reservations and concerns about these issues.
First of all. considering the impact of the outcome to the many area residents, this forum was not widely publicized for local citizens to be aware of this important matter and offer feedback. Secondly. it does not make sense that Exelon is pursuing renewal for a license that does not expire until 2024. This action seem ve remature.
er orms 0 ener can an mus e U Ilze 0 mee ener consum Ion eman s. 25-5 Thank you for arranging the public meetings to discuss this serious matter. I trust you will take my AI ts into consideration and urge Exelon to provide other such forums with widespread notification beforehand so that more interested citizens can participate.
Sincerely.
Camilla Lange 616 W. Schuylkill Road Apt. 164 Pottstown. PA 19465 camillange@verizon.net c,
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- 122 Mendiola, Doris From:
Eric Hamel! [stripey7@yahoo.comJ Sent:
Wednesday. September 21. 2011 7:38 AM To:
Regner. Lisa
Subject:
, Limerick Follow Up Flag:
Follow up Flag Status:
Flagged Please do NOT extend the Limerick licenses! 126-t-ORI Eric Hamell Philadelphia. PA o/&(P/~/j e
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- 123 Mendiola, Doris From:
steve furber [ctevewrx@yahoo.com]
Sent:
Tuesday, September 20,20114:17 PM To:
Regner, lisa ijc94';~~
Subject:
limerack Renewal 7trJL§:3~1</
Follow Up Flag:
Follow up Flag Status:
Flagged Iask that you please consider the future of our great state. I don't think oil or nuclear energy is the way. I truly believe in heart, that in order to protect the health of our population for the future, we must change our ways today.
Sincerely, Steven Furber JJ
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- 124 Page 1 of 1 As of: September 27, 2011 Received: September 22, 2011, PUBLIC SUBMISSION:.-:~~? G; 8; q7 Status: Pending_Post Tracking No. 80f27eee Comments Due: October 28, 2011 Submission Type: Web Docket: NRC-2011-0166
~::~::-:::\\/cD Notice of Receipt and Availability of Application for Renewal of Limerick Generating Station, Units 1 and 2 Facility Operating License Comment On: NRC-20l1-0166-0003 Exelon Generation Company, LLC; Notice of Intent to Prepare an Environmental Impact Statement and Conduct' the Scoping Process for Limerick Generating Station, Units 1 and 2 Document: NRC-2011-0166-DRAFT-0002 Comment on FR Doc # 2011-21921 RUL~S' '
Submitter Information Name: Charlene Padwomy Address:
1117 Oakdale Dr PottstQ'l.vn, pennsyvania, 19464-2782 General Comment Thanks so much, Charlene Padwomy https:llfdms.erulemaking.netlfdms-web-agency/componentlcontentstreamer?objectId=0900006480f27ee... 09127/2011
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0 LIMERICK GENERATING STATION Environmental Scoping Comments Division of License Renewal NRC*2011*0166 Written Comment Form Must be received on or before October 28. 2011. Please print clearly, Name~ / u / It fjpjj{ C. k
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Chief, Rules, Announcements, and Directives Branch Mail Stop: 1WB*05*B01 M U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
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- 126 Gallagher, Carol 1,1...,:;
From:
Joe Roberto [joe@robertoandassociates.com]
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Wednesday, September 21, 2011 7:20 PM t:.:;
To:
Regner, Lisa
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Joe Roberto
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Subject:
LIMERICK
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Dear NRC:
First of all, let me ask why the lack of public notice regarding the public hearing to be held for Limerick Licensing Extension when in fact the current permit is through 2024 and Exelon is asking for another 20 year extension? Your first priority is NOT for the publically traded, for profit company to rush to get this public notice "done" as a requirement to extend the permit another 20 years out which is not due to expire for another 10+ years but to rather really solicit input from the community and folks impacted. The NRC did not do so. There was one article in the local newspapers stating that there would a public session and only saw the actual notice, by virtue of an article in the North Penn Reporter yesterday. This is not proper notice in general and not sure NRC did what is required. What is required and what have you done? And if proper notice was not done, I want another one(s) scheduled please. I, respectfully, am very interested in this answer.
FEEL FREE TO READ THE FOLLOWING AT THE PUBLIC HEARING:
Now, let's get to the big issue at hand. Limerick should NOT be approved for an extension with their permit for the following reasons:
an extension sooner than later 50 Limerick is designated as one of the TOP THREE nuclear plants in the country based on it's construction (which is similar to the ones in Japan - and we see how they failed) and tlie fact that it sits on an earthquake fault line.
The NRC JUST a few weeks ago stated that "more information needs to be done and studied H regarding further fortifying nuclear plants regarding earthquakes. Thus, until you folks know exactly what needs to be done, etc.
THERE IS NOTHING TO APPROVE as long as Limerick sits in it's current position.
Do NOT think that earthquakes only happen on the West Coast - as we JUST had a 6+ earthquake less than a month a o. BY ONLY luck was there no dama e to the lant, environment or communit.
Philadelphia (now, what the 3 largest city in the country?) within less than an hour, and exactly due SE from When Limerick was bUilt, there was no idea that the area would grow in population like it has. For safety reasons, just look on any given day the traffic on Route 422 - stacked and stuck for miles on end. Route 422 is the #1 route for ev cuations and does not handle re ular commuter traffic let alone entire communities.
The NRC and USA Government STILL have not decided on where to store spent nuclear rods an as we spea each spent rod is sitting in baths on the limerick sit, stacking up -expanding even a greater hazard to the community. environment, etc. SO put simply. there is ABOSLUTELY NO REASON to approve this request for YEARS until the US Government decides how the will handle such rods and such rods and ro er stored.
There are many other environmental friendly sources of energy and limerick as anything but that As a matter 30-6 fact, limerick is a TIME BOMB, placed at the wrong location, on the wrong land, too close to major populations, -OS run by a for profit company who can not even handle the basic maintenance issues of power lines, in an aged bull'.
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- 127
- Let's also mention a fact that Category I Hurric.ane Irene, which could have been a Category 3, just zipped jess ~0 than 100 miles away from the site a few weeks ago and then Hurricane Lee which decided to travel further fas AM came close to also causing chaos. limerick is still TOO close to the disaster of Hurricanes as well.
lastly. some who have a vested interest in working at the plant, etc. are quick to state that It is safe, etc. - notI30-9-1 now, nor has it ever been fool proof against disasters, technical glitches, etc.
I as us, ee rm y an many In t e communi y ee t e exact same way, a
ere IS 0 approve (especially so far in advance, with no answer on usage rods nor what needs to be done to prevent a meltdown due to a earthquake, etc.) or EVER since the population will only increase and the facility age further. It is the wrong timing, wrong plant, wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and "energy" to develop solar fields, wind, etc... They would rather beat the hell out of a high efficiency plant at any and all cost to the environment and community. This is where the NRC does the right thing and says NO until a year before it expires. NRC needs to take a stand as you have the data and know what I have stated above is more than fair and true.
Thank you for your time and attention.
- Regards, Jd,R~
2
- 128 l*~/d1~/43IJ 7t.rJC581f~
Delaware Tribe Historic Preservation Office 1420 C of E lliive, Suite 190 Emporia, KS 6680 I (j)
(620) 340-0111 bobermeyer@delawaretribe.org September 23, 20 11 Chief, Rules, Announcements,.and Directives Branch Division ofAdministration Services Office ofAdministration Mailstop TWB-05-BOIM U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: Request for scoping comments concerning the Limerick Generating Station, Units 1 and 2, License Renewal Application Review
Dear Lisa Regner:
Thank you for informing the Delaware Tribe on the proposed construction associated with the above referenced project. OUf review indicates that there are no religious or culturally significant sites in the project area. As such, we defer comment to your office 131-1-HA!
as well as to the State Historic Preservation Office and/or the State Archaeologist.
We wish to continue as a consulting party on this project and look forward to receiving a copy of the cultural resources survey report ifone is performed. We also ask that if any human remains are accidentally unearthed during the course ofthe survey and/or the construction project that you cease development immediately and inform the Delaware Tribe ofIndians ofthe inadvertent discovery.
If you have any questions, please feel free to contact this office by phone at (62) 340 0111 or bye-mail at bobermever@delawaretribe.orn Sincerely,
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Additional Infornuition Required:
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L "No P1IjlP~t<S!'JheTribe concurs with a Federal agen<;Y's~di9g ~t there are 132.'.HA no National R;~g1ster eligible or listed properties within the F.ederiil{,un~ing's area of potential effeClf or APE'.. 3&CFR,800.4 (d) (1)
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- 130 U.S. NUCLEAR REGUI..ATORY COMMISSION rC~~~~~-"i
.~RC P!JBLlC MEETING FEEDBACK Ii.
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Meeting Meeting Limerick Gener:ating Station License Renewal Overview Bnd Environmental Date:
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Title:
StO~~g Com.lllentll Public Meeting In order to better serve ttiepublic, we need to hear from the meeting participants. Please take a few minutes to fill Qut this feedback form and retum it to NRC.
- 1.
How did you hear abo~t th'ts me~tirig?
[J NRC Web Page ljNRC Mailing Ust
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Were you able to find supporting information prior to the meeting?
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Did the meeting achieve its stated purpose?
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Has ttiis meeting helped you with your understanding of the topic?..
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Were the meeting starting time, duration, and location
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- 7.
Are you satisfied oyerall with the N.R<;: stC!ff who LJ participated inthe meeting?
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OPTIONAL Name Continue Comments on the reverse. ~
Check he", ifyou would like e member ofNRC staff 10 rontact you Telephone No.
E*Mall OMS NO-315().()191 Pvbf~ ~ Hotifieatior!: if is mNnS U$tId;o itnpO~ M WOtmatiOn cot1eetiQn doeS rot displ.y. OJrrontiy valid OMa: con1rd n~, the NRC !My not ~ Of.penJOt', and a pe-rSJ:n is.
not ~1lt11b f.~,lo.l/'!6 Wonnatoo ooHeaion.
Please fold on the dotted lines with Business Reply side out, tape the bottom, and mail back to the NRC.
- 131 -
Mendiola, Doris
Subject:
FW: Response from "Comment on NRC Documents" 9'p/'/~//
OriginClI Message--
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From: Richard Kolsch [1]
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Subject:
Response from "Comment on NRC Documents"
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Richard Kolsch (Rklsch@aol.com) on Thursday, September 22, 2011 at 17:44:25 F'~
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DocumencTitle: License Renewal Limerick PA Comments: Comments on Limerick Power Plant License Renewal Limerick, PA September 22, 2011
- 1. Why is there a rush to renew the license? It is not due 34-1 until 2024, approval at the earliest should be 2019. This would allow 5 years for the business plan of PEeo to -LR either continue or close the plant and make arrangements for,additional power to replace the closed plant.
134-4-HHI 4, Developers are required to fund traffic improvements to an area to allow an area to be developed, this I should apply to Limerick. The evacuation plan now will not work. When the plant was started there was no traffic out here, now it is grid lock.
I34-5-0S Limerick should fund new roads and bridge to alleviate traffic
- 2. A firm closure plan should be approved before license renewa 134-2-DCI is accepted, This plan must include what is to be done with the Site, where the nuclear waste will be disposed of etc. The en",.. "".,..,Q.. '.,,,'"
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site like the now defunct Yucca site. The public and our future RW generation deserves to know what is expected to be done at the site. Radioactive material must not be allowed to remain on the site.
- 3. The government should conduct a survey of various illness in the vicinity of the nuclear plant prior to am renewal of a license. If this would indicate a danger living near the plant then the license should not be renewed.
ams in order to have an orderly evacuation.
I
- 5. The plant is vulnerable to terrorist attacks. An airport is located nex1 to the facility. A plane could be flown into the reactor building or the emergency power supply for the water circulation system at the same time
-PA terrorist could cut all outside power to the plant this would cause a meltdown and render the entire area around ~
and downwind of the area uninhabitable for hundreds of years.
organization: None address1: 1694 Kepler Rd.
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- 132 1/6'6-/&&11 September 24, 20 I I 2461 E. High St.,Unit t-lB 7~r"e -:j73¥ ~~
Pottstown PA 19464 USNRC Mailstop: TWB-05-BOI M
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Washington DC 20555 USNRC Lisa Regner:
We wish to add our comments to the NRC record.
We attended one ofthe NRC hearings concerning Limerick's Environmental Impact (9/22111 at 2:00 p.m.) and were appalled that local business and community leaders avoided voicing concerns about Limerick's environmental impact, mentioning itS economic influence, instead. That doesn't.mean that those speakers had no concerns. The NRC would be remiss to consider a "thank you for money and jobs" as part of its evaluation ofcoriununity-wide nudear safety issues connected with Limerick's re-licensing request.
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The nuclear process is not an enlightened way to generate electrical energy. This plant needs 10 transition itself into a more intelligent way ofgenerating energy by actually phasing out and safely shuttinf:3"'S=-_-=S'-_A""""'L--'
down the nuclear plant. By retraining its workers and adopting the safer green technologies, it could truly I,----..J partner with the local community withoul putting its workers oul ofjobs.
be addressed. Re-licensing should not even be a consideration! The NRC must fully investigate the
_I 135 environmental concerns presented Dr. Lewis and Donna Cuthbert.(ACE), Dr. Winter, and each resident 7-OR who so civilly represented this community'S concerns at the September 22, 2011 hearings. The Limerick Nuclear Power Plant should.NOT be re-licensed and should, instead, begin to address the pollution issues i has already created as it seriously and carefully shuts down its reactors.
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Sin~rely,
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Charles and Elizabeth Shank (610-323-6715)**, *
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- 133
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naturalcat@comcast.net
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Sent:
Wednesday, October 12,2011 5:26 PM
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To:
Regner, Lisa
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Subject:
NRC ID DOCKET 2011-0166
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- 134
- - ~ ". *W Mendiola, Doris vJ From:
Cynthia Gale [cgale@baroergale.com]
Sent:
Wednesday. October 12. 2011 4:31 PM To:
Regner, Lisa Cc:
Michael Gale
Subject:
DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD":::::
- I I o
Dear Ms. Regner,
On behalf of my family, friends, and neighbors. please do not relicense the Limerick Nuclear Power Plant. We work in Pottstown. live In Elverson, and our young daughter goes to school in Kimberton. All these locations are in harm's way of Limerick. Every day when I drop our child off at school I have a view of the Limerick towers when I travel on Route 724. I pray everyday that nothing happens when our daughter is at SChool. We no longer feel safe or even drink our tap water, do you?
Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run It Until 2049 Threats and Harms, Already Unacceptable After 26 Years, Are Increasing!
Since 1985, Unprecedented Environmental Harms, Threats. and Risks From Limerick Include:
- 1.
Radiation Into Air and Water From Routine and Accidental Emissions !37-1-RW !
- 2.
Major Air Pollution Under Health Based Standards of the Clean Air Act 137-2-AM
- 3.
Schuylkill River Depletion and Major Drinking Water Contamination 37-3-SW; 37-4-GW
- 4.
Radioactive Groundwater Contaminationl37 GWI
- 5.
Radiation Reportirig Levels Increased Dramatically After Japan DisasterI37-6-GS I
- 6.
Alarming Cancer Increases. Especially In Children, Since Limerick Started Operatin
- 7.
Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Site 137cS-RW I
- 8.
Lax Fire Safety Regulations 137-9-GS I
- 9.
Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles cif Buried Pipes and Cable
- 10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 37-11
-PA
- 11.
Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacksl37 GS I
- 12.
Need for an Updated Evacuation Plan and Increased EP~37-13-GS I
- 13.
increased Costs to the Public - More Cancers and Other Costly Illnesses, More Emergency Room Visits and Hospitalizations from Massive Increases in PM-10 and TDS, Treatment of Public Drinking Water, 137-14-HH I Environmental Clean-Up
- 14. Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replar::c=e:-=d~-=-:-..,
With Safe, Clean, Renewable Energy.
137-15-AL I List Compiled By The Alliance For A Clean Environment - September 2011 5 d A/5../-
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- 135 8/~/;w//
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w From:
Schweg [schweg@gmail,com)
Sent:
Thursday, October 13, 201110:21 AM To:
Regner, Lisa
Subject:
Limerick License Renewal-NRC I,D. Docket 2011-0166 Hello Ms. Regner, I'm writing to you to state my opposition to the reiicensing of the Limerick Generating Station in Limerick 38-1-0R I'm worried about Exelon Generation Co., LLC's safety record and I hope you will consider my opinion 'r'+/-I:~"~':""'I 38-2-08 Respectfully, Jude Schwegel 79 South White Horse Road Phoenixville, Pa 19460 If you want to be important-wonderful. If you want to be recognized-wonderful. Ifyou want to be great wonderful. But recognize that he who is greatest among you shall be your servant. That's a new definition of greatness.
Everybody can be great, because everybody can serve. You don't have to have a college degree to serve. You don't have to make your subject and your verb agree to serve. You don't have to know about Plato and Aristotle to serve. You don't have to know Einstein's theory ofrelativity to serve. You don't have to know the second theory ofthermodynamics in physics to serve. You only need a heart full of grace, a soul generated by love.
And you can be that servant.
Excerpted from The Drum MajorInstinct sermon of the Rev. Dr. Martin Luther King, Jr.
Delivered at Ebenezer Baptist Church, Atlanta, Georgia, on 4 February 1968
- 136 3/Jt./.:4!J //
Mendiola Doris 7~~/( 53?,-:y?'
From:
MichaelGa/e [mgale@barbergale.comJ Sent:
Thursday, October13, 20119:26 AM To:
Regner. Lisa
Subject:
DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD.
And. get the US manufacturing again making wind turbines. solar panels.
-J retrofitting older buildings to be energy efficient. not funding this an other budget-busting toxic time bombs;
'. ) 139-1-ALt Limerick NuCla.ar Planfs UcensaExpires In 2029 - Exelon Wants To Run It Until 2049 1-'
L*J Threats and Harms. Already Unacceptable After 26 Years. Are Increasing!
Since 1985 Unprecedented Environmental Harms, Threats and Risks From Limerick Include:
(11 o W
- 1.
Radiation Into Air and Water From Routine and Accidental EmissionsI39-2-RWI
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- 2.
Major Air Pollution Under Health Based Standards of the Clean Air ActI39-3-AMI r=?:===:::::::::=:=~-=-=,.,..,..,..-....,
- 3.
Schuylklll River Depletion and Major Drinking Water Contamination !39-4-SW; 39-5*GW
- 4.
Radioadive Groundwater Contamination 139-6-GWI
- 5.
Radiation Reporting Levels Increased Dramatically Aller Japan Disaster 139-7-OS
~~:-;::--=-:-':':"":"I
- 6.
Alarming Cancer Increases. Especially In Children, Since Limerick Started Operating 139-8-HHI
- 7.
Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On SlleI39-9-RW 1
- 8.
Lax Fire Safety RegUlationsl39-1 O-OS I
- 9.
Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cables 139-11-0S
- 10.
Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disasle~39-12-PA
- 11.
Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacks 139-13-0S
- 12.
Need for an Updated Evacuation Plan and Increased EPzI39-14-0S I
- 13.
Increased Costs to the Public More Cancers and Other Costly Illnesses. More Emergency Room Vi Is an H Massive Increases in PM-10 and TDS, Treatment of Public Drinking Water, Environmental Clean-Up 39-15-HH
~:-:::::--:-:--::----;;'~--:-:-"'l
- 14. Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replaced With Safe, Clean, 139-16-AL I Renewable Energy.
Usl Compiled By The Alliance For A Clean Environment - September 2011 We sincerely hope you will act with your fellow citizens' health, and indeed longevIty in mind.
Sincerely, Michael Gale 17~ north hanover street pGr\\slown. pa 19464 6!()*705*3606 I' mgale@barberoale.com ht!p:llwww.barbergale.com dcsifI1;;lllj :H1Stui,wb{~ bt'lmds
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- 137
~~//
Mendiola, Doris
Subject:
FW: LIMERICK From: Joe Roberto [mailto:joe@robertoandaSSQCiates.coml Sent: Monday, September 26, 2011 2:46 PM To: Regner, Usa
Subject:
R~: liMERICK 7't;r £.03"/-'Yt7 w
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There is also something that I did not comment on before - why was limerick taken "offline" three times in as m,;-::(i::,:n.:.L:-,-'-:;;:=->
months? Is NRC checking?
30-14-0S
- Thanks, Jot~~
- 138
.~
Mendiola, Doris From:
Melissa Antrim [mantrim@boscovs.com)
Sent:
Friday, October 14, 2011 2: 18 PM To:
Regner. Lisa Cc:
Antrim, Melissa home)
Subject:
Via email:
0.5. NRC Docket 2011-0166 - Limerick License Renewal
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Reference:
Request for Denial of Limerick License Renewal -
NRC 1.0. Docket 2011-0166
Dear Ms. Regner:
attended Ihe recent meeting on the possible renewal of limeriCK NuClear Plant s license tor zu years pasl lIS current
~024 and 2029 expiration dates, I strongly believe, as do many of my local friends and family. that the Limerick Nuclear Plant must be closed, nol relicensed. Approving Limerick Nuclear Plant to be relice~sed unlil 2049 would be jeopardizing he health of thousands and Ihousands of people in neighboring communities. There is substantial evidence [eadilv
~vailable which justifies closing Limerick. Renewing this license could lead to a catastrophic meltdown.
140-1-0R I Limerick was. built to last 40 years. The older any facility gets, the more likely breakdowns and equipment failure will occur. When it's a nuclear power plant, meltdown could result from corroding. deleriorating, and aging pipes. cables, and equipment - honestly, a number of things.
Miles of deteriorating underground buried pipes and cables are a major concern - how and how often are these inspected? Signs of mechanical damage and breakdown already exist three unplanned shutdowns June 2011, preceded by many others since 2007. one with loss of COOling water.
While some parts can be replaced, by the nuclear industry's own admission. some equipment is too big and expensive to replace. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is up. To add 20 more years to that, without having a clue as to what the condition will be, would be beyond careless. 140-2-0S I air and water ihat got into the milk. vegetation, and food since Limerick started operating.
r4'-:0'--""'4-:-H""'H~
,~
-efJ3 Over eight million people live within 50 miles of Limerick Nuclear Plant.
Safe evacuation is not possible, even within the seriously flawed and inadequate current 10-mile evacuation plan.
Until Limerick closes, NRC should expand the evacuation plan (to 50 miles) and be sure there are enough shelters and supplies available to accommodate the oVr=:e:,-:r;::.B-::-,::::-::,-,
million people within that radius. Exelon should pay for the supplies.
40-3-0S It doesn't take an accident or disaster for Limerick to poison the region's residents with radiation.
Ra labon rom Limerick's routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request It's not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe level of exposure according to the National Academy of Sciences andPhysiclans for Social Responsibility.
NRC never did any radiation monitoring.or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted.
Exposure to radiation is known to cause cancer. It should be obvious to NRC that Limerick played a major role in our tragic. well documented cancer crisis after Limerick started operating in the mid 1980s to the late 1990s.
Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher than national and state averages, especially in children. Our children had the highest levels of Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-90 into our
- 139
- e. It's sca hyroid cancer increased by 128% from 1985 to 1997 was a side note, with no family history or other obvious risk 40-5-H H 40c6-0R actors in my life, I was recently treated for thyroid cancer. Since my diagnosis. I have leame<l of many other locals like to think the choice, of where we live could kill us.
It would be careless, unethical' and immoral for NRC to approve Exelon's requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029.
Sincerely, Melissa Antrim 1008 Reading Ave Boyertown.. PA 19512 The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer.
2
hey could monitor themselves. It should be obvious to NRC that limerick played a major role in our ancer crisis after limerick started operating in the mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC showed skyrocketing rates for several cancers much higher than national and state averages, especially in children - innocent children. Thyroid cancer increased by 128% from 1985 to 1997. I have local friends and family with thyroid cancer and brain ncer not one, but several. Sadly, it's no longer uncommon in this area to have a personal link to ancer. However, it IS uncommon in other areas of the country. It used to be uncommon here too prior to Limerick. Would YOU want to live here? Would YOU approve a license renewal so close to home? Your job is to safely review the facts. Don't like the money of these corporations 'A"!~~!--.
acts.
41-3-HH
- 140
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From:
Michael Antrim [antrlm89@gmail.comj
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Sent:
Friday, October 14, 2011 2:35 PM To:
Regner, Lisa
'il
Subject:
Limerick - NRC 1.0. Docket 2011-0166 ill*
Reference:
Request for Oenlalof limerick License Renewal -
NRC 1.0. Docket 2011-WS
Dear Ms. Regner:
The possible renewal of Limerick Nuclear Planfs license for 20 years past its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a great deal. It's hard to understand why something this major would be done so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why 6n earth would this be renewed so early? It's a lengthy process that could begin earlier, but in no way should something this mportant be rushed through now. Why not wait until closer to the expiration.dates, and then seek approval? I understand this is how the original guidelines were set up - but those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing the health of millions. Renewing this license could be catastrophic o millions. Someone has to speak up; someone has to step up.
141-1-LA 1 Earthquakes and other natural disasters are more frequent and stronger than ever before. Limerick is 3rd on the earthquake risk list. Underground pipes and cables can shake and break, which would lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard containment flaw means more radiation would be released. It is simply too dangerous to keep limerick operating. Would you want to Jive within miles of this potential catastrophic disaster? Add the enormous population growth that this area has seen overthe past 10 years - with little to no road improvements - and attempting to evacuate the area during a disaster would be futile, It would be virtually impossible to get out of harms way.
141 0 $
1 The older any facility gets, the more likely breakdowns and equ'jpment failure will occur. limerick was built to last 40 years. Limerick is showing signs of stress and no one knows just how bad this will be by the time th~ current license is up. To add 20 more years to that. without possibly knowing what the condition will be, would be careless. No one can predict what the condition of Limerick will be in 2024 or 2029.
Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not an ootion. Plain and simole. That's a scarY thouaht for those of us who live here!!
Exposure to radiation is known to cause cancer. NRC has not done any radiation monitoring or testing at Thank you for your time today. Just remember, it would be careless, unethical and immoral for NRC to approve requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 41-4-0R
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- 141 -
Mendiola, Doris From:
Sent:
To:
Subject:
Dear Ms. Regner:
joanmcglone@comcast.nel Sunday, October 16, 2011 10:11 PM Regner. Lisa Limerick License Renewal re: Limerick License Renewal - NRC 1.0. Docket2011-0166 I am opposed to the license renewal of the Limerick nuclear plant which was designed to safely. 142-1 operate for 30 yrs. cmdshould now be safely ~hutdown. Statistics regarding nuclear accidents at los similar aging structures are well documented. Those two towers are ticking timebombs and the Nt'\\r::Hf~-"'----'
knows this and needs to shut them down. Following the Japanese nuclear disaster our Limerick nuclear olant hit the statistical at risk list acain. The increased risk of cancer is well-founded in the literature also. Why does the NRC think they can play God with people's lives? It is no longer debatable, shutit down before our very lives are jeopardized!!!
So-called quality of life issues addressed as part of public debate, e.g. "the power is always on"!42-3-0R !
seems irrelevant to us when our families are required to evacuate during a disaster. Limerick must be closed and NOT relicensed at any cost, specifically the cost of life itself!
Sincerely, Joan McGI.one Resident of Royersford borough I
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- 143 Mendiola, Doris
Subject:
FW:*limerick license Renewal-NRC 1.0. Docket 2011-0166 Attachments:
limericl<.odt
--Original Message--
From: Angelbosley <angelbosley@aolcom>
To: Lisa.Regner <LisaRegner@NRC.gov>
Cc: AngelBosley <AngeIBosley@aol.com>
Sent: Sun, Oct 23,201112:48 pm
Subject:
'Limerick License Renewal-NRC 1.0. Docket 2011-0166 Lisa. Regner:
Hello, I am attaching a letter to you regarding limerick Power Plant trying to Re-license until 2049. Please read il. Thank you for your time and attention.
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Lisa Smoyer r'~
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- 144 Sunday, October 23,2011 Lisa Regner, License Renewal Mailstop TWB-05-BO I M Washington DC 20555 Lisa.Regner@NRC.gov
- Limerick License Renewal-NRC I.D. Docket 2011-0166
Dear NRCfLisa Regner:
I was unable t6 attend the public hearing at the time that is occurred. I would like to voice my concern to all of you throl.lgh this letter. There are so many reasons why you as a group should already know that it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from re-Iicensing. The problem that always seems to come up at some of these public hearings and sessions where businesses/corporations want to expand and become bigger and run their businesses long past the time that they should truly be allowed in order to keep people safe, always comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these things occur, people and businesses tum a "blind eye" so to speak to the dangers of allowing a b.usiness like the Limerick Power Plant to renew its license again. That is unacceptable! I expect and demand better service from you to h".Jn 144-1-OR protect myself and my family from harm!
There is no "independent" testing being done at Limerick. The results ortestmg are provided by their own company, who has a vested interest in the outcome of those results, so how could you ever believe that they would be honest about the results? Seriously??
144-2-05 I There is concern that should be faced regarding the ~chuylklll River and the attects it IS gomg to have 44-3 I SW ana beart wrenchmg to know that ottIclaJs and organizatIOns are not paymg attention to what can happen to the public if Limerick Power Plant continues to operate longer then expected. Ignoring the obvious problems our community is facing and hoping that after they serve their term, it will be someone else s problem to deal with is Wlacceptable. Now is the time. Step up and do what is morally right for hwnanity.
on the public if it becomes denleted and/or toxic due to the contaminates going in it. It is disgusting 144-4-0RI We as a society need to wake up and start paying attention to the massive harm power plants can cause to the people, animals, water, air, etc. Why does everyone want to pay attention when it is way too late?? There are safer alternative forms of energy available to our country/communities. We should be working on them and training employees, who currently work for the nuclear power plants how to work with safer forms of energy to help our country move forward in today's society.
144-5-AL 1
~aven't we already seen some of the damage that a terrorist attack can cause tor our country and for ~
pthers? Do you really need to risk more possible attacks on a power plant that is not fully equipped for 4;:
hat kind of attack or for some other natural disasters that can occur. This plant is not prepared for -
Mtacks with planes missiles, and other threats such as a cyber attack. There should also be a concern,-
tor. aCCIdents and leaks from corro teriorating equipment at the site from over the years 144-7-051 I
- 145 (Page 2 of3) which could cause parts of it to be shut down for periods of time, as well as the miles of buried pipes 44-7 and cables. There are many concerns that should be fully looked at and considered, and just wit!" OS minimal thought to them, it shouldn't take a "rocket scientists" so to speak to figure oul that it is not ir Cont'd the best interest ofthe public or environment to allow them to re-license.
he most alarming and. compelling thing to me as a taxpayer, homeowner, and mother is the verwbelmingand alarming cancer increases to the public after Limerick had started operating. The DC website showed a 92.5% higher than the national average for childhood cancer in six ommunities close to the Limerick Nuclear Plant which included, Pottstown, West Pottsgrove, Lower ottsgrove, Upper Pottsgrove, North Coventry, and Douglass Berks Township from cancers diagnosed om 1995-1999. The Pennsylvania State Cancer Registry For Montgomery County-from 1985-86 to 996.97 also shows cancer rates skyrocketed in Montgomery County where the Limerick Nuclear Plant s located during the Mid 80's to 90's after they opened. Prostate Cancer increased 132%, Thyroid ncer increased 128%, Kidney cancer increased 96%, Multiple Myeloma increased 91 %, Hodgkin's isease increased 67%, Non-Hodgkin's Lymphoma increased 61 %,Breast cancer increased 61 %,
ancreas cancer increased 54%, and Leukemia increased 48%.
adiation exposure can cause cancer and other serious disease and disability, at any level of exposure ccording to the National Academy of Sciences and Physicians for Social Responsibility. Permissible diation levels does not mean that they are safe levels for everyone in the community.
Most ermissible levels are based on the average heaJthy adult. They are not levels that were based or esearched for fetuses, infants, toddlers and children or pets. Fetuses, infants, children, pets and the Iderly and immuned compromised individuals are at most risk of health problems. There is a broad ange of dangerous radionuclides routinely released into our air and water from the Limerick Nuclear lant as well.as any accidental releases. Permissible radiation levels does not mean that they are safe adiation levels it onl means that the are allowed.
I have children as well as other loved ones that have or have had allergies, asthma, learning disabilitie*",H~.~H-r--J speech disabilities, behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc.
deserve to live in a community where our air and water isn't being contaminated constantly with hazardous chemicals, radiation, etc. when there are other energy alternatives out there that arer.b;;.;e",::in~-::-!-..,
used that are safer for the communi.
44-10-AL I.expect you to do what is morally right now for me, my family, my neighbors, my community, and the pets, wildlife, air, water, and environment in whole by rejecting, refusing and opposing Limerick Power 44-11-1 OR Plant from re-licensing to' run their business longer then originally planned for 2029. Don't turn a "blind eye" now. Do your lob knowing that YOU are doing what is morally right and safe for humanity and for my children and for the future of generations to come. Please help women have a chance to carry a baby full term without complications due to any possible air and water pollution that may have been caused by allowing more radiation into the environment when there are safer alternatives for energy.
144-1.2-.AL I
- 146 (page 3 of3)
One person/individual can make a huge difference in the life of others whether or not you realize it. It can have a domino effect on others. Please step up and be that one person that we truly need right now to do what is right Why'does it have to take someone to be personally affected by a situation or to have a loved one suffer or die to step forward and do something? Please don't wait. Now is the time.
Please be courageous enough to stancJ up and fight for what. is right for this community and. for humanity in a whole"no matter how hard or long the task may seem, it will be worth itin the end!!!
I appreciate your time and attention in this matter. Thank you.
Sincerely, LisaSmoyer-Upper Pottsgrove Resident 1027 Farmington Ave.
Pottstown PA 19464 cc: Friends, Family and some community members
No
- meHdown, NRC poliCY, review, or Over ei ht million eo report Ie live can within make Limerick failsafe from a catastrophic Safe 50 miles of Limerick Nuclear Plant.
/E-/(F):JS;: HDq-0 3
~~x6~(~~~
- 147 October 8, 2011 (j/~Io/Q)I/
U.S. NRC 1~f1(ci3-¥9'~
Ms. Lisa Regner Mailstop TVIIB-05-B01 M Washington, D.C. 20555 Usa.Regner@NRC.gov e
Subject:
Deny Limerick License Renewal - NRC 1.0. Docket 2011-0166
Dear Ms. Regner:
I urge NRC to deny Exelon's request.to renew Limerick Nuclear Planfs license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant must bectosed, 45+ OR not relicensed. for many valid reasons. Approval for Limerick Nuclear Plant to be relicensed 1 I
. until 2049 woulcj be reckless and would show blatant disregard for the health and safety of the public. There is more than sufficient. evidence of harms and threats to justify closing Limerick.
There are too many things beyond NRC's control that could lead to a catastrophic meltdown.
Limerick is 3rd on the earthquake risk list.
H is too dangerous to keep Limerick operating.
Earthquakes and other natural disasters are more *frequent and stronger.
Underground pipes and cables can shake and break. then lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard containmen, flaw means more radiation would he released.
14&-2*PA Eve ing has a ite expectancy.
Imenck's was years.
e older any aCllity gets, the more likely mechanJcal breakdowns and equipment failure wili OCClJr.
When it's a nuclear plant, meHdown could resuH from corroding. deteriorating, and aging pipes, cables, and 1-:4-:::5-:.3::-.-:::0:-:::5::-'1 equipment. Miles of difficuH to inspect corroding, deteriorating underground buried pipes and t-----'
cables are a major concern. Signs of mechanical damage and breakdown already exist* three unplanned shutdowns June 2011. preceded by many others since 2007, one with loss of cooling water.
While some parts can be replaced, by the nuclear industry's own admission. some n
i ande ivetore I erron save ma e c ear ey In en 0 a nuc ear p an.
xe on as re 0
pay to guard Limerick against a 9/11 type terrorist attack with a plane or missile, even though the most deadly targets (Limerick's fuel pools) are vulnerable to such attacks. Limerick is a similar design to nuclear plants in Japan that are melting down and exploding.
NRC's own report froril2000 shows people 500 mileS away could be impacted by ari'accident or attack onr-f=-=-=---,
such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick's vulnerable 45-4-08 fuel pools five stories high, Cyber attacks, now declared an act of war, could wipe out systems that could lead to meHdown.
Hackers have penetrated the Pentagon and other well guarded s stems. Exelon's new an for ber attacks ives us little comfort.
I
- 148
-, ~.
evacuation is merely an illusion, even within the seriously flawed and fundamentally inadequate current 1O-mile evacuation plan.
Until Limerick closes, NRC should expand the evacuation plan (minimally to 50 miles) and be sure there are enough shelters and supplies available to accommodate the over 8 million people within the 50 miles. Exelon should pay for the supplies.
Unless this is done, Limerick should be closed as soon as possible.
But, it doesn't take an accident or disaster for Limerick to poison the region's residents with radiation. Radiation from Limerick's routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility.
45-5-0S Cont'd 145-6-HH Exposure to radiation is known to cause cancer. It should be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis after Limerick started operating in the mid 1980s to the late 1990s. Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher than national and state averages, especially in children. Our children had the highest levels of Strontium-90 radiation in 45-8-HH I their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-99 into our air and water that got into the milk, vegetation, and food since Limerick started operating.
Thyroid cancer increased by 128% from 1985 to 1997.
Other cancers rose dramatically as well.
Limerick Nuclear Plant is slowly destroying the vital public drinking water source for almost two million people from Pottstown to Philadelphia.
Radioactive and heated wastewater is discharged by limerick Nuclear Plant into the 'Schuylkill River 24fi. limerick's cooling towers are causing significant depletion. To supplement the flow to operate Limerick, Exelon wants to pump more contaminated mine water into the river. No one can credibly assure us if drinking 45-9~SW I water will remain safe even until 2029 when Limerick's original license expires.
Limerick contaminated groundwater. Radioactive leaks and spills over the years were never cleaned up. More radioactive leaks can be expected in the Mure through earthquakes, 45-10-GWI deterioration, and corrosion. Many residential wells are very close to limerick.
WOU 0
une I n 1m oa ov n
eq I
extensions for Limerick Nuclear Power Plant All of the unprecedented harms, threats, and risks from Limerick Nuclear Plant will increase if NRC approves an additional 20 year Limerick 145-11-0R I license extension, until 2049. Limerick Nuclear Plant must be closed by 2029.
Sincerely, e4-L JJ~
- 149 1618 Benjamin Dr.
Ambler, PA 19002 Oct. 21, 2011 Ms. Lisa Regner Project Manager NRC Environmental Review Project
Dear Ms. Regner:
am wntmg to express my opposition to the re-licensure of Limerick nuclear power generating station, 146-1-0R 1
~hich is located about 20 miles from my home. There are several reasons why this re-licensure is not in.
he best interests of people living in the surrounding community.
It tnlS license renewal IS grante<l. thIS plant will contmue operatmg untIl LU49, at whIch tIme It WII! be over sixty years old. Cracks in concrete and corrosion in piping will inevitably develop as this facility ages. While some ofthis "wear and tear" may be evident to visual inspection, some of it will also occur in less accessible places, such as in underground piping systems. The Associated Press has shown that tritium leaks in underground piping systems frequently go undetected-sometimes for years-in aging nuclear power plants! While no leaks ofthis kind have so far been documented at Limerick, the odds of f
b these sorts 0 pro lems developmg will only Increase with every successive decade of the plant's working life.
While the problems associated with age will develop in any nuclear power plant over time, there are additional problems with the reactors at Limerick. Limerick's reactors are boiling water reactors similar to those that.catastrophically melted down last spring in Japan. Although these reactors have a later containment design, they have the same fundamentally flawed reactor pressure vessel design as those that failed at Fukushima.i ; In the BWR design, the control rods come up through the bottom of the pressure vessel, instead ofdropping down from above as in other reactor designs. While the reactor pressure vessel itself is made of very thick steel, the bottom of the'BWR pressure vessel contains 60 holes through which the rods enter the vessel.in In the event of a meltdown, however, these same holes can provide a' "path of least resistance" through which the hot molten fuel can escape with relative ease; it then only has to melt through connecting pipes that are much thinner and weaker than the metal of the pressure vessel itself.;' Tllis apparently occurred at Fukushima, where authorities now admit that reactor fuel underwent not merely a "melt-down," but a "melt-through," breaching the inner pressure vessel and in the process releasing considerable amounts of rod ioactive material into the environment.'
146-2-0S 1 146-3-osl vne ml!911 De lempleo IOOlsmlss me companson wnn I'UKUSnima on me grounos l-lmenCK 10 Pennsylvania is unlikely to experience a similar combination tsunami and earthquake. While the tsunami is not an issue, however, recent analysis by the Nuclear Regulatory Commission suggests that earthquakes pose a more significant threat to the Limerick reactors than was recognized at the time of their construction and initial licensure. (Incidentally, it now appears that at least one of Fukushima's reactors was significantly damaged by the earthquake even hefore the tsunami struck,)'" According to the NRC's own data, Limerick's two reactors are the third and fourth most likely in the country to sustain core damage in the event of an earthquake.'"; There is a fault line called the Ramapo fault line that runs slightly north 'of Limerick, and two small earthquakes associated with this fault line occurred as recently as February 2009.';i; The unexpected quake that shook Virginia's North Anna nuclear plant with over lWo times the amount afforce that it was designed to wilhsland should make us take very seriously the N RC's data regarding Limerick's greater than previously recognized vulnerability to earthquake damage.;'
These concerns are compounded by the fact that the manufacturer of Limerick's control rods, GE Hitachi, 46~4-PA I
- 150 Questions about the Limerick reactors' ability to withstand accidents and namral disasters are all the more pressing because so many people could potentially be affected if something catastrophic were to occur.
Since 1990, the population wiihin a ten-mile radius ofthe plan 1 has increased by 45%, from 178,04710 257,625.'" In addition,-Philadelphia, with a population of 1,526,006, is only about 28 miles away. How much more might these populations increase by 20491,Bearing in mind that the NRC advised Americans 46-S-0SI within a 50 mile radius of Fukushima to evacuate last spring, one can only imagine how difficult il would be to carry out such evacuations if the unthinkable were, ever to occur at Limerick.
Finally, my concerns regarding the impact of this nuclear power plant on my community are not limited to <;atastrophic scenarios that might potentially OCCIJr. There have been some recent studies published in health journals that show a higher incidence ofcertain illness-particularly among children-in communities surrounding nuclear power plants.'" Whil,e these studies were conducted in a variety of 46-6-HH I locations, they seem to be consistent with some ofthe data that Pottstown's local Alliance for a Clean Environment presents on its website regarding irlcreased cancer and leukemia rates-also especially among children--in the greater Pottstown area.""
For all ofthese reasons,I am asking the Nuclear Regulatory Association to deny Exelon's request to extend Limerick's operating license for an extra twenty years.
Thank you for your time.
Sincerely, Lori Molinari
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- 151 -
Mendiola, Doris From:
Regner, lisa Sent:
Thursday, October 27, 201110:17 AM To:
Gallagher, Carol Cc:
Mendiola, Doris
Subject:
limerick Comment dictated to PM (docket NRC-2011*0166)
Environmental Scoping comment dictated to PM (L Regner) on October 27, 2011:
I'm against it for two reasons:
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II am fully aware of the amount of cancer that is prevalent In this area.
1147.2.HH I DorisMeyers Read back to Ms. Meyers twice by PM to ensure accuracy ofC/fctated statement Lisa M Regner, Senior Project Manager Division of license Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Usa.Regner@NRC.Gol/
Office: 0 11 H-23 Mail Stop: 011 F-l (301) 415-1906
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- 152 Mendiola, Doris From:
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quteasz@comcast.net Thursday, October 27, 2011 3:03 PM Regner, Lisa Limerick Nuclear Plant Relicensing Hello Ms. Re ner:
Just a quick note requesting the NRC to NOT allow the relicensing ofthe Limerick, Pa.,
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nll<;:lear plant at this time.
48-1-0R move 0
own, a., some Ime ago In pe ec
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la WI prostate cancer. Although, I cannot prove it was a direct cause ofthe nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior to fhe relicensing of the Limerick plant by reputable sources not by cQrporate interests groups that can manipulate the statistics in Exelon's favor.
Wouldn't it be in the best interest of our community and surrounding communities if the higher cancer rate was due to the Limerick power plant???? This question is a "no brainer".
There is plenty of time for testing to be done prior to the relicensing.
so, w y e urry...
hich we are not aware.
hy must the license be renewed at this time when they are licensed through 2024 and 029????
gain, WHY THE HURRY???
48-3-LR o relicensenow is not in the best interest of everyone in our area.
Prior to the construction of the Limerick power plant, everyone in our surrounding area was told that-our electricity would be one of the lowest in the U.S.
THIS WAS A BOLD FACE LIE!!!! IT IS ONE OF THE HIGHEST IN THE U.S.!!!,...,..",--:---=-'::---1 Excelon lied to us then and the will distort the facts now.
48-4-0S PLEASE DO NOT BE IN A HURRY TO RELICENSE LIMERICK WITHOUT COMPLETE AND HONEST TESTING BY AN IMPARTIAL COMPANY. There is plenty of time after the test results.
Thank you for reading my e-mail. I hope God guides your agency into making the correct decision.
Ken Sekellick 661 N. Price St.
Pottstown, PA. 19464 guteasz@comcast.net
- 153 RULES,:
936Shenkel Road
>j~/;LjJ~ Pottstown, P A 19465 October 25, 201 J 7~?/{S:3~1(
U.S.NRC e
CIO Lisa Regner, License Renewal Re: Limerick License MailslOp TWB-0505-BOJ M Renewal Washington, D. C. 20555 NRC I.D. Docket 2011-0166
Dear Lisa,
NRC:
As a physician, Jam writing to help you understand that nuclear reactors are not safe.
I attended the medical clinic in Hirosh~ma right after the bombing and saw the radiation horrors caused by nuclear bombing. I have kept a close watch on similar problems by nuclear energy in the medical field since then, not only worldwide, but because of our nearby nuclear power plant. Here are some concerns.
Incidentally, baby teeth studies have revealed Strontium 90 radioactive particles whichr.!-,::-:-:-:-;-,
can.affect the child's immune system for more illness.'
6*8~HH We can't control the use of nuclear in the rest ofthe world, but we can keep the U. S.
safer by eliminating nuclear energies. Fortunately, many ofour European allies including Australia have decided to phase out reactors. We should join them to reduce human suffering. Also this can reduce our increasing costs ofhealth care!
6-9-0R I lease listen to this advice after years ofdoing my best for America. Rely on more and ruly safe and renewable sources like solar, wind and geothermal power.
imerick Power Plant is ranked in the top 3 riskiest nuclear power plants in the U.S.A. 16-11-0R imerick Power Plant must be closed not relicensed.
Sincerely yours, lsi Fred S, Winter Fred S',Winter, M. D.
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- 154
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Anthony Gonyea Onondaga Nation Hemlock Rd. Box 319B 1tr{33~7<;t via Nedrow, NY 13120 Oct. 15,.2011 David J Wrona US Nuclear Regulatory Commission Washington, DC 20555-0001 V1 V1 RE:
Project ID: Limerick Generating Station limerick Township of Montgomery County, PA
Dear Mr. Wrona,
Thank you for providing the Onondaga Nation with information about this project. If anything changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 have licenses that may be renewed In 2024 and 2029 respectively, therefore you may send updates and information until then.
149-1-HA In the event that during project construction, any archeological resources or remains, Including, without limitation, human remains, funerary objects, sacred objects, or objects of cultural patrimony are uncovered, please Immediately stop construction and contact me at (315)952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at (315)475-2559.
If you have any comments or questions about this matter, please do not hesitate to let me know. Thank you for your help.
Sl~~
Anthony Gonyea A Falthkeeper for the On!,)ndaga Nation Onondaga Nation Historic Preservation Office Section 106 Representative "E-/[..J-J:rs;::::- ff"J) 1'7-.iJ3
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- 155 wanted to let you know that I am a complete and full supporter of the Limerick Nuclear plant. I am Iso supportive of the scientific judgement and expertise of those such as yourself who have theF:;.*o"=.b....,*'~="
f making the decisions.
50+SR (I saw your name in an article in the Mercury where the writer was requesting that objections be sent to you. I thought I would take advantage of the contact information to state a contrary position.)
I grew up in coal-mining country, and never saw a stream or a creek with clear water uncontaminated by acid mine runoff until I was in my late teens. Opponents to nuclear power have usually never lived near coal truck entrances to mines and caal plants, and have probably never lost family members to mine cave-ins or black lung. Risks should be minimized as much as possible, but the world will always have something that someone objects to. Unscientific or fear-based objections to nuclear power are unproductive and do not advance safe*or reasonably priced power.
I work in the pharmaceutical industry (I was first educated asa pharmacist. and then as an aHorney; I now help to get new vaccines approved, and to help increase vaccination rates). The parallel I see is wi.th the group of people who see disaster in every prescription drug product, and complain about everything the FDA approves or does. Nothing is ever 'safe' enough for them.
Please renew Limerick, using the best scientific information and risklbenfit analysis available to Thank you.
Debby Penrod 215 Amanda Smith Drive PO Box 516 Pottstown, PA 19464
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Hi,
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Mendiola. Doris
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Deb Penrod [deb24532@comcast.net)
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Thursday, October 27. 20118:06 PM Regner. lisa greetings from a SUPPORTER of Limerick nuclearplant VI 1'0
- 156 Mendiola, Doris From:
DocKoenig@aol.com Sent:
Thursday. October 27,2011 8:49 PM To; Regner, Lisa
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Subject:
Fwd: Nuclear Limerick From: DocKoenig@aol.com To: LisaRegner@nrc.gov Sent: 10127/2011 7:36:13 P.M. Eastern Daylight Time SUbj: Nuclear Limerick
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Hello Lisa Limerick should not.be licensed. or relicensed at this time. The are onl doing it because the plant has issues that they are trying to hide. The evacuation pia is a joke because w~ woul~ not get out o~ our drive~QYs. It would not have worked 10
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years ago and certainly with the population growth It would be much 151-2-0S' OO"vs]: 13f!',j/;~~~
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- 157 Mendiola, Doris From:
. John & Joyce Webber Ubwebberpc@comcast.net)
Sent:
Friday,.October28, 2011 2:41 PM To:
Regner, Lisa
Subject:
Exlon Limerick Relicensing 52-1-0R As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from Exelon's Limerick Nuclear Power Plant), I urge you to vote AGAINST the premature relicensing ohhat facility.
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-E (4) The roads toany safe place are overwhelmed with congestion with normal traffic. (5)The plant can n longer store its used fuel rods and has asked permission to begin transporting them to another facility.
r:5~2:-"4-;---:::0~S::'I (5) It is one of the six most dangerous plants in the country because of its proximity to an earthquake fault.
52-5-0S
- 16) The surrounding area has abnormally high cancer rates among adults and children. !152-6-HH!
for all these reasons and many others too numerous to mention, it would be a truly disastrous mistake to extend Exelon's limerick license for 20 years beyond the current licenses that do no expire until 2024 & 2029!
Please consider the thousands and thousands of people who would be lost to an accident that could be prevented.
Sincerely, Joyce B. Webber 2338 Holly Drive Gilbertsville, PA 19525
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From:
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Friday, October 28, 2011 3:06 PM c.'
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Regner, Lisa
Subject:
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Dear Lisa,
It was good to meet you at the September 22, 2011 hearing the NRC held at Sunnybrook.
As I stated then, I continue to be concerned and puzzled about the very early and pre-mature application of Exelon to extend the licenses of the towers. One of those towers does not come up for renewal until 2024 and the other 2029. I ask the NRC not to work on therelicensing question for this facility for at least ten years. Th wait CQuid only ensure better information. The public cannot possibly benefit from a decision to renew the licenses at this time. The best.decision will be made based on the best possible information. The NRC does no have that best information this early. Much will happen in the next ten years. I urge the NRC to wait and see how any of it affects the prospect of continuing these plants at that later date.
What can happen in the next ten years that we can all learn from relevantly could be anything. It may be better information about how natural disasters are affecting nuclear facilities; we may know more about weather patterns that could cause damage. We will certainly know more about the world situation in terms ofadvances in terrorist technological capabilities and goals. We will know more about how well nuclear plants in general and the Limerick facility are faring as they continue to age. If someone steps forward to fund studies, we will know yet more about cancer rates in the nuclear zone. (We do know something about that now: Joseph Mangano and others have done studies already that I assume he has provided to you, and I urge you to consider carefull'.
One big concern--because ofJapan's recent experience and the fact that we had an earthquake here in the Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes. It has been widely reported--by MSNBC and the AP, using NRC data--that the Limerick plant has the nation's third highest risk of being damaged by an earthquake. When the plant was built, no one thought this area would get earthquakes.
Now we do. I understand that Congress is now or soon will be considering increasing earthquake preparedness capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would encourage them to do less than they should to make the Dlants safer.
18-6-PA I There can be no good reasons for relicensing now. Please wait as long as possible to do that. Better infonnation helps everyone who wants an outcome that is right and socially beneficial--notjust profitable for Exelon.
Thank you for your consideration.
Anita Baly
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- 160 MONTGOMERY COUNTY PLANNING COMMISSION box,)l1
- norristown
- pennsylvania' 19404-0311
- 610~2'78-3722 office location: suite 201
- one,montgomery plaza' swede &. airy streets. norristown pa FAX; 610-278-3 ~41,
- Website Www,pllinliing,montcopa.org
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- '1 October 25,2011
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V1 Chief. Rules Announcements. and Directives Branch V1 Mail Stop: TWB-05-BOIM US Nuclear Regulatory Commission Washington. DC 205550001 RE:
Environmental Scoping Comments
, Limerick Nuclear Generating 'Station Division of License Renewal NRC-2011-0166
Dear NRC Staff:
We have examined the'pmpos~d reli~~nsin'g'ieview info~ation presented by NRC staff at the,Public Heanngheld inP6ttstown on September 22 and the information posted on the website'operated'by the NRC.,We feel thatit is vital that any decision regarding the relicensirig of. the Limerick Nuclear Power Station reflect careful consideration of all relevanl public health and safety. security, ana environmental issues that pertain to nuclear power generation in general and the unique conditions at the nuclear power generating station situated in Limerick Township, It is our uniierstanding that an Environmental Impact Statement will be deveioped which addresses relevant enyironmentru impacts pertaining to socioeconomics, environmental justice, and noise;,cultural resources, archeology, and geological science; atmospheric science"air'quality; hydrological sciences; transportation and land use; radiation protection; nuclear safety. fuel cycle, waste, and accident analysis; construction,operation, refurbishment,. and decommissioning; regulatory compliance;
,aquatic ecology; an,d water quality, Further it is our understanding that a detailed safety review will be conducted to review design assumptions; assess aging management of safety systems; and determine if new monitoring and insPections are needed during the expanded Ilc~nsing period.
While we impl~re the NRC to db a full review of both environmental and pliblic safety issues pertahrin:g to the plant-particularly addressing radioactivity exposures during norma! operation of the power station and, during various types of unusual events and disasters- ~ aiiditionally feel that the impact review preceding any 'rellcensing decisiQ'h should also address specific iss,ues.pertaining to the plant based upon it's conformity to the MontgomeryCo}lnty Comprehensive,Plan 'and overall county development policies. Below we have itemiz~cl iS,sues wi~ respect to hUld use change and growth around the 'power plan,t,transportation apd evacuation capacity,
.schuylkill River; and county trruls that we feel warrant consideration in the environmental impact.study.
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- 161 J
NRC Staff October 25, 2011 Land Use Change and GroWth around the Power Plant:
Since the original.pla,nt was constructed, the population in the surrounding communities has grown dramatically. Limerick Township and nearby Upper Providence Township have been two ofthe most rapidly 'growmg commurutieS in. the' county. This gro:wfu largely fueled by access to US Route' 422 Expressway and':
available land with suitable infrastructure: has dramaticallychan'ged the character of the area surrounding the Limerick Power Station. In thepasf few years, the.'., '
Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the adjoining Costco shoppi.ng center opened along US Route 422 about one mile north of the.,Limerick Power,~tilt1<?Q..propt;rtY.:-T.he'land adjoinin!{thbse facilities is being'.
cOIlsidered for variOUl> t::Y~s of retai1 and resiaential' uses.. At'one time. a large.'
gamblirigcasiIlo had'been'pr6posed mthi~l6Cation as 'well. Other lands in Lower Pottsgrove Township neaithe Liinerick Power Station have also been proposed for similar types of uses.
54-2-05 While the county plan.i1ing commission has tried to promotelow'erdensities of growth in proximity to the Limerick Plant, the local communities and the marketplace favor this location for significant development due to its proximity to the US Route 422 interchange at Township Line/ Evergreen Road. The growth that has taken place in the area around the power plant, and in particular the growth taking place.in the area immediately adjoining the. plant and the primarY access to if; as well as the projected growth in the future, could complicate evacuation plans and*the movement of.
appropriate emergenc:Y"resPCfnse persbnnef'{o the'plan(in the event or-a disaster-.
Certainly this access could be even mor~ critical in 'the event ofanatural disaster when other roads to the plant may bli'linpassable. The envir'onmental "assessment review needs to analyze this'groWth in the vicinity of the power plant -to evaluate what impact it would have: on plant operations and whether or not safe evacuation can take pla~e fr~m the newly developed areas.
rans ortation and Evacuation Ca ad he growth in the whole US Route 422 Corridor has raised numerous proposals for xpanding the vehicle capacity of the 422 expressway. Current peak commuting affic tie ups on portions of the expressway serve as evidence that it may have
'nadequate capacity to continue to serve as a safe evacuation corridor for the region.
unty transportation plan recognizes the need for various road improvements the US 422,corridor to addr~ss current and future traffic demands, The first ty projects in the plan inchideinterchange improvements at the Township Line oadl Evergreen Road intersection which is also the primary access route to the 154"3-0SI lant; needed widening and reconstruction of the highway east of the power station etween Route 29 and US Route 202 in King of Prussia, reconstruction' of US Route 22 in the vicinity ofPottstown. 'and the reconstruction and widening of the Route 422 ridge across the Schuylkill River at Betzwood. A passenger train line is also roposed as a first priority in the transportation plan to provide service' through the estern portion of the county into Norristown, The pr9Posed route for this train line is e existing Norfolk Southern rail line that goes through the Limerick Power' Station operty. o.ther ~pr()vem<<,;nts including the wid~ning <!fl.d expansion: of US Route 422 rom Pottstotvn to 'Route 29 and additional interchange iniprovements at'Township ine/ Evergreen'Road'are pr6p9sed;assecon~aiy p~orities in 'the cO'!lntj plan. In*
ddition'to, the'se iplpr,(;rye#lents. several6ther'iocali.Zed i~provementstl'lat may impact vacuation feasibility aie'prbpasediri*the' codntY plan. ::: '.,,' "
"'.... 110
- 162 NRC Staff October 25, 2011 ue to un mg mltations m ennsy vama, t ese projects are not 1 e y to move forward at this time.,The envirpnmental impact review should consider the capacity of the roadway facilities to service the Limerick J>lant as well as provide sufficient 54-3-08 evacuatioI1of th~ area in the event ora disaster: Possiple mitiga,ti0Il strategies 'to be Cont'd considered in th,e"environmental assessment review c'ould include the role of Exelon in fundingt;l;l,e impo~t road improvements needed in thjsarea to ensure safe evacuation and access to the,laut in 'an 1 e of disaster.
lSchuylkillRlver;,.,:" ';;1, ':.{'.':. ',',,,,'
Since the last ~pactstatemen!,was p-l"ep.ilr~dilji,1973,.ilie.',S!:n1.!ylkiliRiver has' been' designated as a state scenic river an~'as a,ihentage'af,e~'w" both the ~tate and t~deraJ.
government. D,ue, to these designations and the effortsofn6n-'Pfofit organiZations and loc.al gov~n::tment, acce!'s to the river has peen expahd~d so that the river has become a recr~ation and heritage tourism destination. U~e of the river in the vicinity of the plant will continue to grow. With the retUrn of American Shad made,possible thr.ough down stream !jsh laqders, in~erest in ~e river cQuld eyengrow further in the 154-4-8W 1 future.
The,Limerick p'lant.withdraws sizeable portions of river water. During low flow periods, additional,qll,antities ofwater 'are,released into the river from the Wade~ville Mine, and Still Creek Reservoir in Schuylkill County to compensate for the watet:
withdraWn at the plant.. Thililprocess was initia)1y approv.~d:b:¥ the, DetawareRiver
. Basin,Commission (DRBq..in 2,003 and: k~pt'~9tiye ttrr0,ugh a series of docket amendments. FJ,ltureo';et::w.ater,use iS9,e,pendent upon the ability of this water make up system toopel'ate withiI1 variou:s watel( qualitY, and flow,parameters set by DRBC.
It is importantto:evaluat~, th~ viability,ofthe use of.the riyer water and water make up system to provide, needed water through the expanded plant lifetime. Analysis of this aspect of plant operation needs to account for the water quality impact from the total dissolved solids in the Wadesville water among other parameters. If resumed use of the Delaware water diversion is anticipated, an evaluation of that system is required tc ensure that the capacity is available in the conveyance system and that water 'qucility objectives can be met.for discharge into the East Branch of the Perkiomen Creek..
County Trails and Open Space:.*
The county has been working.hard to develop an interconnected system of open space and trails along th~.Schuylkill River and within other natural re,source areas of the..
county. In doing this, the county has provided funding to local muniCipalities and non-profit conservation organizations to purchase open space and park land; acquirec county land and agriculture easements; and developed trails. The Limerick, Generating Station, site contains significant land along the Schuylkill River that has 1 5 LU I 54 been identified as part of the Schuylkill River Greenway in the county plan. The use and management of these lands ft!lative to the county open space and natural areas inventory plans should be evaluated in. tilt! relicensing process.
TheMontgo~e~rCounty 6p~rirSpace Pla~ proposes a trailalong the bver through the power plant property"iThis trail is. prQPosedas the Schuylkill East Trail, which would be developed as unpav,~d.trah be):WeenM.oa~ Clare and Pottstown. Essentihlly the proposed rout~,'Y9uldJpJl.ovv.i:ID,ol~'{0~d,~a~t:b.etween,:ftt~ ryver and Norfolk SCHlthern.
rail line through the \\"imeri<:l<;.po~~r St~tiQn,site..,:rhgugh ~:Uch.atrailrou.te, wQu!d "
.ppea; to,al",,;..iIi';;;",i>fctj; "'Ociini5hi; ii, proP,o";~ 'pi""imity toth~ ~ ~
- 163 NRC Staff October 25,2011
, appropnate elements could be designed into any trail system to limit its threat to plant's security. We have found that trails can enhance the overall 'security Of an 54-6-0S I area since they concentrate users along a defined corridor. Furthermore, trails can provide emergency access routes that could be used, during different disaster events to Cont d evacuate peopl~ ap..d provide access for emergency response. This trail and the management 'of undeveloped portions of the Limerick Power Station site should be considered in 'the environmental assessment.
Community Outreach and Education:
As part of the environmental assessment process and the evaluation of the plant safety and long term operational capacity, we think that it is important for the NRC to malntai.:t1 close communicati,on with the community surrounding the plant. Overall education about the plant and the associated risks presented by its operation should be provided in a variety of ways so that the public is better informed about the plant and the overall evaluation taking place as part of the relicensing.
(
Ifyou have any questions, please contact me. Also, we offer our assistance in providing local information that may be helpful to your review.
- / ::,'."1:.
Michael M. Stokes Assistant Director mstokes'@imontcopa.org (610) 278-3729'
- c. Thomas Sullivan, PUblic'Safety Dep~ent 54-7-lR I
- 164 COUNTY OF MONTGOMERY Commissioners Montgomery County JAMES R. MATIHEWS Department of Public Safety CHAIRMAN Operations Center so Eagkville Road JOSEPH M. HOEFFEt BRUCE L CASTOR. Jr Eagleville. PA 19403 (610)631-6500 FAX (610)631-6536 mOMAS M. SULLIVAN WW'\\lI(dps.rnontcopa.org DEPARTMENT DIRECTOR October 25, 201 i Chief, R.uIes Announcements, and Directives BranCh o/~/2ZJI/
MailStop: 1WB-05-BOIM US Nuclear Regulatory Commission J6 ?J(..6'9~7~
W-1shington, DC 205550001 Re: Environmental Scoping Comments Limerick Nuclear Gener.ltin& Station Division of License Renewal B
NRC2011-0166
Dear NRC Staff:
The Montgomery County Department of Public Safety 'WOuld like to offer the following comments regarding the NRC relicensing review information presented at the Public Hearing held in Pottstown on September"22, 2011.
- ifhe NRC should provide afull review of environmental and public safety issues pertaining to the plant.
t is understood that emergency responders providing services to the power plant understand the hazards associated with daily operations of the plant. However, in light of events in Japan and recent eismic activity in this area, the NRC should clarify the risks associated with plant operations in times of 155-1-0S 1 iunusual activitJI outage operations, and during times of natural! man-made events that may pose a risk o the plam in terms that the public will understand in an attempt to quell public concern.
- ~ concur that the NRC require Exelon to conform to the Montgomery CoUnty Comprehensive Plan o not only ensure cooper:u:ion in the community; but also in the region.
Additionail:>s it is also 155-2-osl uggested that Exelon be included in pending roadway infras= improvements projects as both a take holder and oossible source of funding.
It is important to note that the 10 - mile Emergency Planning Zone (EPZ) is the second largest in population in me nation. As a result of recent development and type of development in the area of LGS, it ~important to review the Evacuation Tune Estimate Study (ETE) on a more timely basis and r:=-::-:;:-;::'1 accoutu: for the transient population present in the hotels that have accompanied this development. 155-3-0S 1 Additional!); funding should be supplied for either Exelon staff or County staff to act as a transient planning and outreaeh specialist to assist these transient populat.ion locations with emergency planning.
It should be noted that the Evacuation Tune Estimate is currently being updated Required highway and roadway infrastructure upgrades should be inciuPed as a part of O'!fld also as a result of any changes 1=:::--:,-=:::"'1 noted in me updated ETE. Special attention for improvement should be given to the local, county and 155-4-0S 1 state roads used for evacuation that feed the larger highways, as many of these roadways are no longer suitable for the amount.of tramc that an EPZ evacuation could produce.
~7{--t.::>>'S :::,£J!y-~-2J:3
~=X;tJ~0H/(~
- 165 October 25, 2011
.Th.e NRC should consider requiring Exelon. to enhance planning for day to day emergency situations that require a response from local emergency services. Often times, Fire and EMS access is ddayed due 155-5-0S I to screening of vehicles and peISonneL This can cause delay in patient care to potentially life threatening i11nesses.
A note S 0 reg e
veISlon 0 e
River water to e East Bot e Pe.r:kiomen. Due to the residential build-up along the Pe.r:kiomen Creek area, additional consideration r!:5:-;:5:-*6=---::O~L-"
should be presented and discussed with the Anny Corps of Engineers and the National Weather Service regarding potential flooding impact this may have on the area.
While recreation utilization is of importance and a major mission within this coun~ homeland security must be of a concern with any open access within the vicinity of LGS. However, we concur that with '"'5""5:--"'7--"',
support of local law enforcement and a commitment from LGS to control and monitor access, trail OS
~ughput may be accomplished.
In an attempt to promote and increase commUnity outreach, the NRC should consider requiring Exelon to reopen the LGS Infprmation VISitor Center. As a result of the incident in Fukushima, Japan, the Montgomery County Department of Public Safety has a received a higher than normal volume of 1-:=-=-=:0 th Th.
ugh 55-8-0S I inquiries concerning nw:r.u-power generation from e public.
e LGS Information Center, altho dated, could be upgraded to provide this service to the community to raise awareness and promote.
education of the nuclear power industry. This center could also be incorporated as an educational stop I on the County Trail s~tem.
If you have any questions please feel free to contact me.
VerytrulyYOI *,
(}L.,~~-
1 ~omas M Sullivan Director of Public Safety CG R. Graf, co.o.
M Stokes, Assistattt Director of Planning S. Mickalonis, Deputy Director for EmergencyMgt.
J. Wilson, Radiological Planning Specialist
- 166
~~c THE EARtH'S BESt DEFIHSE October 28, 20 II Via Electronic Mail Ms. Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C.20555-000 I Electronic Mail: cindy.bladey@nrc.gov RE:
Natural Resources Defense Council Comments on Limerick EIS Scoping Process NRC Docket 10: NRC-2OI 1-0166
Dear Ms. Bladey:
The Natural Resources Defense Council (NRDC) comments today on the Nuclear Regulatory Commission's (NRC) Notice 0/Intent To Prepare an Environmenlalimpaci Sialemenl and Conducl {he Scuping Process/or UlIlerick Generming 8laliol1. Unil.\\" I and 2, (hereinafter "Limerick EIS Scoping Process). 76 Fed. Reg. 53498 (August 26, 2011).
Summary of Comments Our comments specitical1y address the NRC's National Environmental Policy Act <<NEPA) 42 U.S.C. § 4321, et seq,) obligations and the need for any environmental analysis the agency conducts to include an up-to-date "Severe Accident Mitigation Alternatives" (SAMA) analysis that fully incorporates current insights into severe nuclear accident causation and mitigation.
While we recognize that, as a private entity. the relicensing applicant, Exelon Generation Company, is not directly bound by NEPA, the same is not true for' the NRC. Given that the applicant's ER generally serves as the basis for the Commission's eventual DraftEnvironmental Impact Statement (Draft EIS), and Exelon suggests it need not revise and update its SAMA analysis, we are raising this NEPA concern at this early stage in hopes that this matter may be addressed before the agency moves to relicense a facil ity based on a legally insufficient NEP A review.
- 167 The*.ppgi1111l.sAMA.;ati:lIysig for the timerick;den'~Jaiing Si.ation. (LQS)~s,t1989repoi1. ihatwlt issued as th.e resultofa rulil}g byth5) U.S.. Court o(Appeals for )11e l1)ird.qirc,!it;I which concluded thatthe NRC had Tailed*to consider a "reasonablesef' ofSevere Accident Mitigation Design Alternatives {"SAMDAs").In 1989; the NRC sllhseqli'ehtly ado'pted this SAMDA imiilysis:anihgeilcy staffconcludedthey had. "discoyererl no substantial changes in the proposed actionas*preyious!y.ev,aJuattldi!1the.FE~ [final E;nvtronmellU!1 Statem.t::nt] th~j ~e relevant !o environlllelltal concerns nor sigtlifi~ant new circufllstangeilor informa~ion re.leyantto environmental concerns and bearingjon the licensing of [LGS]".
AStheonginal ills SAMDkeffort inJ989was the first m'anoatedeffortto foctis on SAMt\\S,i the p:otiorrtpat an updllte.d SA-MAanlllysi~ l1eednot be (:Qmplete~tl!tthelicens.e renewalst;tge (for the exactreaclor site that gave birth to the regulatory requirement) wefind~highly objectionable, particularly in Iight*ofthecatastrophic.nuClear accident that befelLsimilar Boiling Water Reactot(BWR) units. in: japanitiMarch,*2011. It has become cIearin the 170 yearS of.
combined U.S. BWRoperationalexpenence.$(nce }989 (hat:domestica:nd interIjaiional events prov,id~nlJmerOllS ~xample.l> ()f"n.ew'informati()Jl" and m.alce a slrong case;f()rth~fn.ee.dJo 156-hRA I reconsider'allthat has been learned about newly discovered. risks and vulnerabilities ofnucIear power:plarits.
I(has be.en noted3 that global Core Pan111ge eyentshappen:ata,rate that exc~.eds NRC's pre~umptiops'ofwhat should be considered.s.afe at plants w.i!hinthe U.S., whichimplie~that eitherthe'NRC estimates'fodlomesticpiants are wrong or that international nucIear;plants have a core damage frequency much higher thari wllat the NRC deems sife. Either scenario is trOUbling and deserves'the industry's:fuflatteiltioh and effort. ExeiQrl's 1989 effort in response tQ Jl1eGourt Was, !e.spectfully; less than onewo.uld have QQped for.in light offue seriousness of the i~sue. The LGS 1~89 SAMDAcan in no way claim necessary'conservatism, with regard to publicsafetyoverthe total timeframe:of a possibie.sixty year reactor lifetime.
in.conttast to'the 198?SAMDA,relatively recentSAMAaila!yses conducted in other license.
r"n~w~1 applicatiQlls;Su.ch asthosdor'~ites afNir).e Mile p,oint, Three,Mile Wand, and the JosephM. ~arley Nl,Iclear Plant, to nalI).e a few; were considerably m9reothorough. 3llP addressed a*range oDdetailed alternatives, PursuanHo regulatory'anaiysistechniquessupplied by NRC4 and aided i:iyan *industry-supplied.cguidarice.document5; niosfmoclern-day, SAMA analyses are aesigned using aJaidy pfescnptive.setofinitia[ assumptiohs, baseline calculations, arid c6st ben~fit<lrithmeticrecipes '\\h.~temploy the.Uli" otsophisticate~ codes in thei.r evalu.ati.on of potential risk and*the benefit of removing this risk..
I Iimerick'Ecology Aciio'J v.. NRC; 869.F.:id'719.(3,d CiT. 1(89) 2Or:SAMDAsm this case; and*we use t/1e*termsinterchaligeably. for the purpOses ofthese c.ol)1ments, JOi()bql1mp'licatiOY/s oflheF~il11a Disasterfo;NuciearBow~~, T. (;;ocl1.n1n, M. McKinzie (l1RDC).\\Vo!ld Fedef\\lti()~,\\f Sci~~j~ts' Ihtern,ati()nai S~Il)inarsoilPl~n~tllryE~,rgepci()s.Erice~ Sicjly: Aug 201 t 4NUREQ!BR~01 ~4Regu/atory AnalysisTllchnicaIEva}u.ati1!!1 Hanc!boo.k,Jan 1997 1 NEI 05-01 [Rev A] Severe A ccident Mitigation Altemam;es (SAMA) ~nalysis - OUicJl1fIce Docuriumt, Nov.2005
- 168 The.mostcominohcode used' is the MELCORacciderit consequence. code system ~MACCS2)6, whichpiovidCi;a'modeling framework (ot calculating the off~~ite consequences of:asevere...
a9cide.nL 11ii~code 'acgepil?'I~rf;!idVanced set of jnput'pai"ametel1!,,ift9iudlQgpoPllJ atiQl1,density distr.il>ll.tiotIs within 59 niiles, detaiJed regionalecon~l11i9 data obtained froInIJ1ultipie:soll1:ces, nuclide release scenarios.accounting.for,reactof*coreinventory, emergency response and
- exposlire variables! and meteorological data for plume migration pathWays: The current state* or' krioWledge regatdiflgthe.assumptiohs and urtdetStahdingOf severe accident events'has expanded
- and imprq\\1ediIl.ihe'interv,enin~fv,entY-two years since~e ipitiill ~AJvIDA analysisfqr LOS.
While we acknowledge thaHhisanalysis was limited.by.theknowledge available at the time, the
- iimitations arid shortconiingsof iiprevious erainnb way disqualify the claim'tllat,ih light.of numero\\Js'adViinces.iri mo(Hilirigcapabilities, a library ofdlSCO\\lered,cost~benefi¢iiil SAt\\4:As; and
- the salien.:y qfs."vere. accid,el1t nskif<;>llo-.ying th.e !iisast~r llt FukushiJl.la D~iichi; nQiQP!yis there:new and significant information, there are significant volumes:ofthis information acquired.
since 1989.
- JlJ tI,e.licel1see's Curre111 el1yironrriental report, the i<ientificatipna:qd treatinenl,Qf'newapd signi.ficl!J1t'infQrmatiqn(fo1Jf:i~llms, ill tQtaIj were d~veh:medonlyin the IlllrrQW con~e~.o{!low they may affeci the dated SAMDA analysis,'ILshouldgowithoutsayingtllaHhis approach does hot compnseall ofthe. applicable new and Iioteworthy severe. accident mitigation strategies beafuigoifthe sitejn question, or serve to remedy.gaps and omissions in the origihaJ SAMDA analysis.
The'entire set of first-stage envisioned alternatives in the initial:SAMDAanalysis was*no more thari fifteen options. The "ana1ysis" in thecurrerit erivironmentaireport consists ofperfunctory, "back-of-the-'enve!ope'calculations in lieu ofa properSAMA anaiY,sis;The current op'crator Exeloh'referredio,these cQnsidl':fations iisrepresentingan "~bundance ofcautiofi~;i'W~ disagree.
One oftheJargest problems with the calculations offered,. aside from.only focusing on an arbitrarily iimited.number ofaIternatives, is'thiltiicensee.evaluated*each.item of new iriforihation in is.olation oftheother.factots that. would also.changetfle.cost-bellefitcpflclusion fofaparticulat alt.el1lative,The effects of ea9hchanged p.arMIleteI: :(~:g,; population, offsite ~col!omicrisk, co~(
per person-I:em averted, and seismic *hazards).should be evaluated.in a co.mprehensiv~ motl.:l that
- shows,the*aggregate benefit, as performed in.all current-day SAMA analyses. Unfortunately;
- their analysis bartilyscrapedJhe.surfaceofhoW this 'new mformation should actnallybe considered in.the.cohtext of eri~ironiriental irripacts:
In comparison, a "reasonable set" of. alternatives for another recently relicensedplant included an initial conSideration of128 SAMAcandidates. developed from previous lists at other, plants, NRC d6cUments,ahd 'documents rehitedto acfvancedpower reactordeslghs. 7 After screci1irigthis.
mltiar setJornon-appljcable 9r previously implemented desigrts:a;; ~el1as cOfl1biningldropping gommon-benefitoptiomi, the appli.::antwas stillieftwith.a sct offortyullique SAK1Acandtdaies, for which!t'w~.requireHo enter preliminary costestimates inasoccalled'*':Phase I. Analysis." A 6NUREG1CR.6613;VoU; Code Manual!orMACCS2.. User'SOuide, D. Chanin &ML Young; May 1998 7 joseph'M F~leYN~de~);lant ~ App{icaq(mfor.Li~efJse RelJ~aLAppendixD. E"NironmentaJl~.eporl; Atiachl1Jen! F.8iivereAccideniMitigation AlternativeS, Sept 2003
- 169 total.Of fifteen SAMA canoidatessurViveo this screenihg to enter* more oetailedcost cOhsidetatiordnthe Pna.<;e'IUmalysis, ofwhich:nohewere deemed cost-beneficial. However, in mqil}er rtm~~ll\\ilPpI.i9ati()n;8 the. $Afo[A apalysis fOUri~,elevefl p~ot~ntiaily ~9~i-Qeneficiid options from *an.initial ~et of1,hirty-three.
q6-H~AI In,ahNRC report discils-singlns1ghtsonSAMAsin.connection withpiarit license rehewals,9 th'l....C_o_n_t_'d_...
agency. ;ilitnors iist nilinerouspoteQtiaily cost-beneficial SAMAs relatingt!> station blackouts, pro.tf:ction anq support'sysl<':rn!l, pr()fequresl.Uld trainipg,.an<J f:~ernar~vetlts as. flood, fir" and se!sm.ichaz.a.rds. The authorS notfjthat"'averted onsiie costs (AOSG) is a criticalfactor in*
cost-benetitanalysesand tends to make preventative SAMAs more attractiveJhanmitiga:tive SAMAS:" TIlis AOSC factor. was not cOhsidered in.eithe'rthe onginal SAMDA or the*recently submitted :ehv'ironmehtal :report.
Finally,' NRDCbelieves thatih addition 'to a'comprehensivelyupdated.SAMAanaJ ysis;the licensee or agency must conduct a study that,.as part ofthe supplementaLenvironmentalrimpact statement, presents postulated accident scenar.i6ssh<)\\vmg!the fujI range ahdweight of ellvironmerttal, eqoriomic, and.hea:ltlirisks'posed,by these accidep.ts: This tYPe ofstudy should m()d.el~sit~-sp~ilic !ievere aqcidents and illustrat~the full ~onsequen:ces*ofarange 'of!l!lvere accident scenarios 'so thatthe~public and theirpolicy makers can make iriformed aecisions whether to.continiie plahtoperations after.the existing f1censes expire, thereby continuing to'TIU the nskof it severenilClear accident, investin additiomll accident mitigation capabilities, or alternatively, avoid these risks altogether by relyingonaportfo\\io of low car,b6n.electricity ge,ner~tionaltern~tives that coulq meet future~lectricity service netlds;over the lice.~se ellfen~io period.
Thd;AMA,aiialysesare inadequate in this t~gard becaus~ they 'Only address,isblated issiJesin ~
cosi-benefltanllfysis thatdiscp.unts th~:<<uhillla1i"e. iinpacts on gi.splace(!p:opullltions,r(lgional
~conomic losses, (l!1d.enviroillllentai cleanup. These types of calc~latiqnsdo notpresent'!l,clear picture ofthe potential hazards or costs'experienced.in the event ofa' severe accident Instead.
they tend to ma.i;k:the ful1 range ofaccident conseqliences thatpoiicy'makers iiiay Wish to avoio.
Rec:en:tIy, NRbc produced an analysis, ofthe type we believe:shouldbe,inC!uded iIi the LillJerickNEEAanalysis,to infofI1l ongoing relicensing.~fforts :nthe Indian. P9iQt nucl~ar plan
". 10
- SIte, In.order to. illustrate the fuil'extent ora major accident"theNRDCstIidYIised the U.S:
Depattmentof Defense compurer model H~AC{Hazard:Prediction and AssessmenfCapability 1
to calc.ulate site-specifjc release radiological source~teqns, resu1t,ing fallout plll,mes, and data 01; the effects on,nearby populations. The.results were compared tO'similar modeling of:the Fukushima,disaster to. provide a sense of scale, and to estimate the rough.magnitude offinancia S Three Mile Island.Nuclear. StatioriUnit '1 - License Renewal Application, Em~ronmeiltal Rep(>r~.Appendi:'C:E:
SAMA ANALYSIS 9 Persp.~cliv.es pn Severe A/iddent!vlitigati?h Alte.rnatives[or Ufi...Plant Lic,!seRe'(lewal,T Gosh"R Palla, D.
Heltg.1i; U:S'NRC, SqJt'20Q9(Ac(;es,sion 1'{o: M(092750488).
lQNuclearAcciilenta,(Iro:li'anPoinl: Conseque1}ces anilC?s~, MMcK,inzie~ ()Ct 2011 (http'i/wWwmdc.orglnuc!ear/indianpointlfileslNRD8-1336 :Indian Point FSr8mediurn.pdt) 11 HazardPr~diction fl.ndAs;ie'ss~ent Capability(HPAC), version {O:4. Wa~i:rigt~n;D:C. :Qef~nse Threat Reciuction Agency, Apr 2004
- 170 ana economic damages that woulclbe:illcurredl'f a severe accident weteto occUr at Indiari P6i'nt.
This is not a.liypotlietical issue~Policy makers in'sevenlLcOlintties,:ihciuding Germany and SWItzerland, ha"emacle. decisionS'nQtt() graptnuclear plant licens:e exietisibnsjo avoi!i nayirigT endureJhecontil1uipg risk ofsevere nucl~ar pla~taccidel1ts.
Regardless ofExeJon' sown corporate understanding ofitS legal obligations, NEPAis.clear in iii weli-esti.blisned mandates and what itrequiies' ofthe:NRG. NEPA requites thatt:ecleralagehcies chlgacierizeellvi,ronJlleniaI impactsi?roaaIyioin,cluaeno! onlyecologic!\\l ~ffects;sucha~
physical, cheJ1lical, raciiQlogical and bi()logical\\lffec~, but'l!lsoaes:thetic, hi~toric, cultural, economic, and..social effects12 NEP A requires, an,agency to consider. both the direct effects caused hY'ariaction arid' any indireCt effectS that areteasonablyforeseeable. Effects include direct. effects';cauSed by the :action.and;oc~currihg;atthe same.tlme and place and indirect effects causeg i?yJheac.ti()n, !Jut later in, time or farther removed,in ~stance,~ut stillreasona~ly foreseeable.
56-1-RA I Mostspecifically, NEPA dir:ectSiliatJ,)'RC take. a "hard 100](" atthe environmentlil iinpactsofits propos~4 actioll, in this inst!!llcethe.relicensing o[two nWR Mark2unjtsforap'addiiiQnlll20 yeaflli and compare themto afuH rarlge Qtre!!sQnapl'l,alternatiYes;"What.. constitutes.a, 'hard look' cannot be outlined with nile"like precision,'but it"at least encompasses a thorough investigation*into the environrrientalimpactsOfari agency's action and a candid ackn6w!edgement ofthe risks that thoseilnpar.fts,entail." Nan AudubonSdc. v.I)ejJt,O(theNav~
422 F.3d 174,185 (4th,Gir. 2005) (empnaSis added).A$a stalld~ghQrs,et:or.the ~RC:s draft ElS
'the applicant's E:R 40es',l1ot meerthi§ ~t~ndard. Intakinglhe"hard)ool<' required ~y law, the NRC~must therefore,address the potential environmental impacts ofa range of*severe accidents-and accidehtmitigation strategies--cespeciallyinliglit of the new 'lnf'orination pr.ovided bythe FUkushi'manu~lelit disaster: on the perforrnilnce ofnWR radioiogical cOi).iainmentii). aprolongedJ9ss-of~c06lant, cOl:e~dama~e scenario.
For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA analysis be conduCted as part of (or supplemeniJo) the required supplemental environmental, iinpactstatement, the draft of which is currently scheduled for August 2012 and the final SEIS currently schedufedJorFebt:uary.2'Q13. Adqitiona1\\y, th.efuU cumulative "ffectof sever" accid,ents.must bestui,iiedal1q,[1resented as part ofthese qoquments. These analyses Illust make every effort to meet the current expectations of what these studies~,should encompass and use the necessary gUidance and too!scomrilonlyutilizecl by tile inCtlisky and NRC The NRC's' legal obligation to :consider"new iriformatiori and deterinmii its rilidearsitfety sijYiificance exists independently ofw/lether a CS.'U1A h'!S or has f!otbeen prep<lrcd previOl~sly: in"the eventa:
SAMA has not been prepared; then new and potentially significant,nuclearsafity,information must be inc1udedinlhe initial SAMA; ifa previous SAMA exists,.then it must.be updated to re'flecfthisnewjnforinati6ti,arid,theresulting)':ostsand benefits bfthefuIlspectiUrri of reasonable acciaentmitigation alternatives mUst. be considered as part.ofthe Draft. Supplemental Environnwnta! Impact*SiaJement, and issuedJQf public com.ment.
Firially, we have grave misgivingSregaruiiigtheTuture.time-dependence, accuracy, and
'1=::-:--:-:::-1 relevance of'the.iicensee's current ER, as presumptive'll' mcorporated in the NRC's pianrled 156-2~LR I
- 171 SEIS.JorLGS license eXtension, gi:veililiat'sucliilcense ex1ensioh wiiI nof become effective,unti the current unit. operating liCehsesexpihi in 20:24-,(for Unit 1) and 2029 for Unii2, We submit that~ai:lyd~cisiol}'to rel,ic~nse th~se imjis IIlllst,',be supP9rt,,4 py the mqst lime1yNEPA: MId SAM,A analysis obtainable with..ll:t'a,reasonaple i\\1ter:VaI '(e.g:.five y~at])pri9rtoactlllii.expirati9r ofthe, existing licenses.
56-2cL:R I lriter:va'!s, of f2 and 17'yearsare'notreHuiredforcorporate,,/aIming purposes and are far, too lon~C6nfd to crepiply ~,llsiainthe acpur<l9Y,and releval}£~ of NEfA anaiyseli,or f()t:the NRQ.l() accurat~ry.
projecthoth !h.e fl,lture <<onc:iition of'\\he plant;1h" Mure lltateqfnucle(U' safety knowledge,tn;nds in local resource,use, population, and the affected environmerit, and the future range,of reasonable efectrlcitysuP,I:Jly a1temativesto Los liCense eXtelision, By companson,majO'r government Qwned miclear'instaliations,such as nuclear 'Iaooratories and we'aponpro'dtietion sites,.are reguiredJo conduct site-wide' NEP A reyiews oftheir operations anq facil~typlans. eve!)
five years. Using*1his federal standard for timeliness, the NRC~s NEP A analysis forLGS relicensing-shouldnot commence before 2019, for Unit'l,and before 2024Jor Unit 2, or should be suhiectedto mandatory reassessffieritahdsupplemeiitation afief those dares.
Wefurihern,!-)t<.:;givxn the ~~nded tim",frames for "xpiration'QX theexisting.LGS operating icenses, thatthey.easily encompass the five-year timeframethat the Commissionhai setout for ormulaiionandimple~ehtatioi1 ofNRC staftsafety recommendations to be,undertaken
\\vithout.unnecessary delay" irithewake ofthe FukuShima accident. In li!Wt oftbeseimportaiit 156-3-:0$1 nuqlear~afety developments,weseek.no reason Why this proPQsedNEPA 4lla1ysis, and hence the entirelice.TlsingpJ'()c~ediTlgthatit is required to sUPPQrt;~ould!l()t bt( de~err~d for at least five years,*until the..Commission:has completed its-decision"makingandschedule for implementation
~f post-Fiikushlma saIety.tipgrades.ASrioted.above,to ensure.'the timeliness and accuracy ofthe*
NEPA analysis,.the defeinil;co.ul1:1be eyenJonger(on the order of7yea'rS for.Unit 1), to;allow or the ilicl1.1~iono.fthe results ofthe extendedmillmakings c9ntelj:lplateU under the.'
Commission's regulatory response to ihe FIJkushirp.a acc.ident Preparation of the applicilrit's ER,and the NRC's subsequent SEIS;couldtheri take account Of
'these tequiredsafety mo.dificatiollsand.chhanceosevere accident coping 'Strategies, alid these yvouldbe reflecte.d in a sigtlificljl1tly revis,edSAMAanalysi.s: In the,;e c.9mme11.~, we are not.
formalJy advocating sllch. a deferred path.wayfor theLGS relicepsing proceeding; bu(merely note its plausibility and inherent advantages forallparties,to the proceeding, Withoulsuch a deferral, the only.sensible alternative courSe..isto enSutethe.incorporation bfthe.most up-to':date nudears-af~tykrlowledge - "neWilrid:si@jficantinformatiQn'; - regaroing BWR Mark) reactors am~ severe; iJ.cciQent mitigatiol} il}19*thecun:entlicensingproceedin~.
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'Thankyou for your consideration ofthese comments. Pleasedonothesitate'to contact us at (2()2);289-6868 if you have any questions.
. Sincerely, 6-4, If ~1i-J; Geoffrey H.ettus "Director, Nuclear Program J~]~.
G. Jordan Weaver, PhIl Program Scientist Christopher E. Paine
- 173 Mendiola, Doris From:
lorraineruppe@aol.com Sent:
Friday, October 28,20116:33 PM To:
Regner, Lisa
- rJ
Subject:
Fwd:Faultlines close to Limerick Nuclear Plant
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~ ~~*1 Please include this for the record conceming relicensing of Limerick Power Plant.
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':=J rn From: lorraineruppe <Iorraineruppe@aol.com>
a 7'?/1{ ~-:34-C; f' To: letters <Ietters@pottsmerc.com>
Sent: Mon, Oc124, 2011 9:09 pm Letter to Editor Exelon is rushing the timeline to reissue a Iicense(1 8 years ahead of time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the NRC to get back to me conceming an already known survey of fault lines. 4-13-LR It took five months for the Nuclear Regulatory Commission to answer my question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Chalfont Fault is only 9 miles East.
,...,.....,....,...,&'="'1 Ramapo Fault is 17 miles Northwest. This is alarming!
The 9-21-11 Mercurv article said" whether or not earthauake risk is a factor in the current relicensing request for Limerick remains to be seen". It would be grossly unacceptable for the NRC to ignore Limerick's extreme vulnerability to earthquake damage..
Earthquake risk should be on the top of of NRC's relicensing concerns for Limerick. Earthquake risks are far greater for Limerick than previously realized-increased by 141%. We now know Limerick is3rd on nation's earthquake risk liS,;.,t:-:"-=-,,:!::-:_-,
.Plus,evidence shows earthquakes in the East can be far stronger than Limerick's" design basis" can withstand. 14-15-PA I There's a good chance that an earthquake can exceed Limerick's design basis, causing a severe nuclear accident, jeopardizing the health, safety and financial well being of our entire region.
The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant.Since January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick:
Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to nuclear disaster. It's disquieting that NRC uses a "visual inspection" to determine damage on buried pipes. Problems may not be identified unt it's too late.
For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on fires and earthquakes.
To save money, Exelon typically concludes Limerick is "safe enough". This is unacceptable!
1.0-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear plant. The warning was tied t renewed focus on earthquake risk. Irs difficult to see how Limerick's design flaws can be fixed, even if. Exelon WOULD spend the money:
There is no proof whatsoever Limerick's design can withstand other threats ranging from hurricanes, tornadoes, floods, 0 terrorist attacks to an impact from a jet airliner.
We need precaution before there is a catastrophe. NRC should close Limerick as soon as possible.
'£'1fT.!X5 =- t!3 ))1-(- 0.3 Lorraine Ruppe
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- 174 Mendiola, Doris From:
sunbeamsky [sunbeamsky@aoLcomj Sent:
Monday, Octdber 31,20112:28 PM To:
Regner, Usa
Subject:
power plant renewal
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-175 -
Mendiola, Doris From:
Smokowicz; April (ApriI.Smokowicz@graph!cpkg.com)
Sent:
Wednesday, November 02, 2011 8:49 AM To:
Regner, lisa Cc:
msworkdog@Verizon.net
Subject:
Pottstown Mercury article 10127/11 Good Morning I know this is late according to your article, but I wanted to still send you some information.
I feel that there is a lot of people that had not known to report anything because of not knowing who to go to.
I don't understand why the hospitals don't give statistical information based on areas?
158-1-HH 1 Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. We had lived on limerick Center Road'for m()st of our young lives and now with our kids. I don't know what other information you would need but I would be happy to get you whatever you might need.
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~U.S.NRC United Sr.m::s Nuclc3-r ReguLuor.y Commi~ionH Prot<<tingPeople fl1JIi the Envirrminmt LIMERICK GENERATING STATION Environmental S'c'oping Comments Division of Ucense Renewal
, NRC-2011-0166 Written Comment Form Must be received on or before October 28, 2011: Please print clearly, Name: "\\ie 'br~ ~t\\t', C:\\er
Title:
' C\\Y, lee fI Organization: (.AI"'-' {-teL- ~+/-~+~ s of H-Mer; LeA.....
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