ML13172A023
| ML13172A023 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/23/2013 |
| From: | Leslie Perkins License Renewal Projects Branch 2 |
| To: | |
| PERKINS L 415-2375 | |
| References | |
| NRC-4219 | |
| Download: ML13172A023 (53) | |
Text
Official Trans cript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Limerick Generating Station License Renewal EIS Public Meeting: Evening Session Docket Number: (n/a)
Location:
Pottstown, Pennsylvania Date:
Thursday, May 23, 2013 Work Order No.:
NRC-4219 Pages 1-53 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 PUBLIC MEETING TO DISCUSS THE DRAFT SUPPLEMENTAL 4
ENVIRONMENT IMPACT STATEMENT FOR THE LICENSE RENEWAL 5
OF LIMERICK GENERATING STATION 6
+ + + + +
7 EVENING SESSION 8
+ + + + +
9 THURSDAY 10 MAY 23, 2013 11
+ + + + +
12 13 The Meeting convened in the Sunnybrook Ballroom, 14 50 Sunnybrook Road, Pottstown, Pennsylvania, at 7:00 15 p.m., Richard Barkley, Facilitator, presiding.
16 17 18 PRESENT 19 RICHARD BARKLEY, Facilitator 20 LESLIE PERKINS, Environmental Project Manager 21 22 23 24 25
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TABLE OF CONTENTS 1
WELCOME AND PURPOSE OF MEETING..................... 3 2
OVERVIEW OF LICENSE RENEWAL PROCESS................ 5 3
RESULTS OF THE ENVIRONMENTAL REVIEW............... 7 4
HOW COMMENTS CAN BE SUBMITTED..................... 12 5
PUBLIC COMMENTS................................... 12 6
CLOSING/AVAILABILITY OF TRANSCRIPTS............... 53 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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P-R-O-C-E-E-D-I-N-G-S 1
7:04 p.m.
2 FACILITATOR BARKLEY: Thank you. My name 3
is Richard Barkley. I'm the meeting facilitator for 4
this evening. I was here this afternoon as well. We had 5
a productive meeting, I thought, and we covered all the 6
speakers that asked to sign up and I hope we'll repeat 7
that this evening.
8 If you're interested in speaking this 9
evening, please sign up at a yellow card at the back. I 10 think I have 13 people signed up at this point which is 11 actually just a couple less than this afternoon.
12 The purpose of this meeting again is to 13 present the results of the review related to the 14 environmental evaluation of the license renewal for 15 Limerick Station. Again, we'll accept any comments you 16 have. If you have some written remarks you may place 17 them up here at the table. We will take that. There's 18 also the opportunity to provide written comments 19 submitted up until June 27th regarding this application.
20 Why don't we roll to the next page, please?
21 Again, as I mentioned I'll go over the 22 ground rules for this meeting. If you do want to speak, 23 please sign up on a speaker card. To be fair, I'd like 24 to see you try to hold your remarks to five minutes. Most 25
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speakers went between three and seven minutes this 1
afternoon, so if we can do that we'll be fine with 2
covering everyone this evening.
3 I'll try to call the first three speakers 4
at a time so you know you're prepared for the next 5
speaker. That makes for a much smoother transition.
6 And I would ask that you silence your cell phone if you 7
have one on so we don't have disruptions during the 8
meeting. You'll see me working with my cell phone. I 9
use it as a timer during the meeting, but I won't be 10 accepting calls.
11 If we could go to the next slide. There you 12 go. We have two hand-held microphones, if you could hold 13 the microphone fairly close to your mouth that would be 14 great. The audience can hear you then as well as this 15 meeting is being transcribed and so it makes it much 16 easier for him to understand the transcription and 17 accurately record that.
18 I would ask that you do not interrupt the 19 speaker or speak when not at the microphone. The 20 audience this afternoon did that without problem and I 21 hope we repeat that this evening.
22 If you have any questions concerns 23 regarding the conduct of the meeting, please come see me.
24 I know I've talked to two different people that have 25
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schedule constraints tonight, so I'll try to put them 1
early in the order in which they're called.
2 So at this point, I'd like to thank you for 3
your cooperation and have Leslie get started with the 4
presentation.
5 MS. PERKINS: Thank you, Richard, and thank 6
you all for taking the time to come to this meeting. My 7
name is Leslie Perkins and I am the Project Manager for 8
the Environmental Review of Limerick Generating Station.
9 I hope the information we provide at this 10 presentation will help you to understand what we've done 11 so far and the role you can play in helping us make sure 12 that the Final Environmental Impact Statement is 13 accurate and complete. I would like to emphasize that 14 the Environmental Review is not yet complete.
15 Next slide.
16 I'd like to start off briefly by going over 17 the agenda for today's presentation. I will discuss the 18 NRC's regulatory role, the preliminary findings of our 19 Environmental Review which addresses the impacts 20 associated with extending the operating licenses of the 21 Limerick Generating Station for an additional 20 years.
22 I will present the current schedule for the remainder of 23 the Environmental Review and how you can submit comments 24 outside this meeting. And I will discuss how the waste 25
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confidence rulemaking and EIS impact the Environmental 1
Review for Limerick.
2 At the end of the presentation, there will 3
be time for questions and answers on the Environmental 4
Review process. And most importantly, time for you to 5
present your comments on the Draft Supplemental 6
Environmental Impact Statement.
7 Next slide.
8 NRC was established to regulate civilian 9
use of nuclear materials including facilities producing 10 electric power. NRC conducts license renewal reviews 11 for plants whose owners who wish to operate beyond their 12 initial license period. NRC license renewal reviews 13 address safety issues related to managing the effects of 14 aging and environmental issues related to an additional 15 20 years of operation. In all aspects of the NRC 16 regulations, our mission is three-fold: to ensure 17 adequate protection of public health and safety, to 18 promote common defense and security, and to protect the 19 environment.
20 Next slide.
21 We're here today to discuss the potential 22 site-specific impact of license renewal for Limerick 23 Generating Station. The Generic Environmental Impact 24 Statement, also known as the GEIS, examines the possible 25
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environmental impacts that could occur as a result of 1
renewing licenses of individual nuclear power plants 2
under 10 CFR Part 54.
3 The
- GEIS, to the extent
- possible, 4
establishes the bounds and significance of these 5
potential impacts. The analyses in the GEIS encompass 6
all operating light-water power reactors. For each type 7
of environmental impact, the GEIS establishes generic 8
findings covering as many plants as possible. For some 9
environmental issues, the GEIS found that a generic 10 evaluation was not sufficient and that plant-specific 11 analysis was required.
12 The site-specific findings for Limerick are 13 contained in the Draft Supplemental Environmental Impact 14 Statement, also known as the Draft SEIS, which was 15 published April 30th of this year. This document 16 contains analyses of all applicable site-specific issues 17 as well as a review of issues covered by the GEIS to 18 determine whether the conclusions in the GEIS are valid 19 for Limerick. In this process, the staff also reviews 20 the environmental impacts of power generation 21 alternatives to license renewal to determine whether the 22 impacts expected for license renewal are unreasonable.
23 For each environmental issue identified an 24 impact level is assigned. The NRC standards of 25
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significance for impact was established using the White 1
House Council of Environmental Quality terminology for 2
significance. The NRC established three levels of 3
significance for potential impact: small, moderate, 4
and large as defined on the slide.
5 This slide lists the site-specific issues 6
NRC staff reviewed for the continued operation of 7
Limerick during the proposed license renewal period.
8 Overall, the direct and indirect impacts for license 9
renewal on all these issues were found to be small which 10 means that the effects are not detectable or are so minor 11 that they neither destabilize nor noticeably alter any 12 important attribute of the resource.
13 Next slide.
14 This slides provides a summary of our 15 findings with respect to cumulative impact associated 16 with Limerick. Cumulative impacts include the effects 17 on the environment from other past, present, or 18 reasonably foreseeable future human actions. These 19 effects not only include the operation of Limerick, but 20 also the impacts of activities unrelated to Limerick such 21 as future urbanization, other energy-producing 22 facilities in the area, and climate change. Past 23 actions are those related to the resources at the time 24 of the power plant licensing and construction. Present 25
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actions are those related to the resources at the time 1
of the current operation of the power plant. And future 2
actions are considered to be those that are reasonably 3
foreseeable through the end of the plant operation, 4
including the period of extended operation.
5 Therefore, the analysis considers 6
potential impacts of the end of the current license term 7
as well as the 20-year renewal license term. While the 8
level of impact due to direct and indirect impacts of 9
Limerick on aquatic and terrestrial resources were 10 small, the cumulative impacts, when combined with other 11 resources, such as increased urbanization and climate 12 change will be small to moderate for aquatic resources 13 and moderate for terrestrial resources.
In 14 other areas considered, the staff preliminarily 15 concluded the cumulative impacts are small.
16 Next slide.
17 The National Environmental Policy Act, also 18 known as NEPA, mandates that each Environmental Impact 19 Statement consider alternatives to any proposed major 20 federal action. A major step in determining whether 21 license renewal is reasonable or not, is comparing the 22 likely impact of continued operation of the nuclear power 23 plant with the likely impact of alternative means of 24 power generation. Alternatives must provide an option 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 that allows for power generation capability beyond the 1
term of the current nuclear plant operating license to 2
meet future systems generation needs.
3 In the Draft Supplement, NRC staff 4
initially considered 18 different alternatives. After 5
this initial consideration, the staff then chose the most 6
likely and analyzed these in depth.
7 Finally, NRC considered what would happen 8
if no action is taken. And Limerick shuts down at the 9
end of its current license without a specific replacement 10 alternative. This alternative will not provide power 11 generation capacity nor would it meet the needs currently 12 met by Limerick.
13 The NRC's preliminary conclusion is that 14 the environmental impact for license renewal for 15 Limerick would be smaller than those feasible and 16 commercially viable alternatives.
17 The no action alternative will have small environmental 18 impact in most areas with the exception of the social 19 economic impacts which would be small to moderate.
20 Continued operation would have a small environmental 21 impact in all areas. The staff concluded that continual 22 operation of the existing Limerick is the 23 environmentally preferred alternative.
24 Next slide.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 Based on a
review of the likely 1
environmental impacts for license renewal, as well as 2
potential environmental impacts on alternatives to 3
license
- renewal, the NRC staff's preliminary 4
recommendation in the Draft SEIS is that the adverse 5
environmental impacts to license renewal for Limerick 6
are not great enough to deny the option of license renewal 7
for energy planning decision makers.
8 Next slide.
9 For the term beyond the 20-year period of 10 extended operations, the NRC addresses the management of 11 spent nuclear fuel and the Waste Confidence Decision and 12 Rule. Previous license renewal Supplemental EISs noted 13 that the environmental impact of temporary storage of 14 nuclear fuel for the period following the reactor 15 operating license term were addressed by this rule. The 16 Draft Supplemental EIS does not discuss potential 17 environmental impact of storing spent fuel for an 18 extended period after the plant shuts down. That issue 19 will be addressed in the NRC's Waste Confidence 20 Environmental Impact Statement and Rule. The Draft Rule 21 and the EIS is expected to be issued in fall of 2013 and 22 the public will have an opportunity to provide comments.
23 The Final Rule and EIS is expected to be 24 issued in September of 2014.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 Additional information on the Waste 1
Confidence Rulemaking and EIS can be found at the NRC 2
public website at the link listed on the slide.
3 In August 2012, the Commission decided that 4
the Agency would not issue licenses dependent upon the 5
Waste Confidence Decision until the Waste Confidence 6
Rule is completed. However, the Commission directed the 7
staff to proceed with licensing reviews and proceedings.
8 If the results of the Waste Confidence EIS and Rule 9
identifies information that impacts the analysis in the 10 final SEIS for Limerick, the NRC staff will perform any 11 appropriate review for those issues and may supplement 12 the Final SEIS before the NRC makes a final licensing 13 decision as to whether or not to renew Limerick's 14 licenses. If no changes are required, the NRC staff 15 would base its decision on the Final Supplemental EIS for 16 Limerick, the Waste Confidence EIS and Rule, as well as 17 the Safety Evaluation Report.
18 Next slide.
19 I'd like to reemphasize that the 20 Environmental Review is not yet complete. Your comments 21 today and all the written comments we receive by the end 22 of the comment period on June 27th will be considered by 23 the NRC staff as we develop the Final SEIS which is 24 currently planned to be issued in November 2013. Those 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 comments that are within the scope of the Environmental 1
Review and provide new and significant information can 2
help change the staff's findings. The Final SEIS will 3
contain the staff's final recommendation on the 4
acceptability of license renewal based on work we've 5
already done and any new and significant information we 6
receive in the form of comments during the comment 7
period.
8 Next slide.
9 As many of you know, I am the primary contact 10 for the Environmental Review. Rick Plasse is the 11 primary contact for the Safety Review. Copies of the 12 Draft SEIS are available on CD as well as hard copies on 13 the table in the back of the room. In addition, the 14 Pottstown Regional Public Library and the Royersford 15 Free Public Library have agreed to make hard copies 16 available for review. You can also find electronic 17 copies of Draft SEIS along with other information about 18 the Limerick license renewal review online.
19 Next slide.
20 The NRC staff will address written comment 21 in the same way we address spoken comments received 22 today. You can submit written comments either online or 23 via conventional mail.
24 To submit written comments online visit the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 website regulations.gov and search for the docket ID 1
listed on the slide. If you have any written comments 2
today, you may give them to any NRC staff. This 3
concludes our presentation and I'll turn the meeting back 4
over to Richard.
5 FACILITATOR BARKLEY: Okay, thank you, 6
Leslie. Are there any questions regarding the 7
presentation? If not, I'll move right into the comment 8
period.
9 Again, typically, we call elected or 10 appointed officials first. And Michael Moyer is the 11 first one who signed up. Are there any other elected or 12 appointed officials who would like to speak this evening 13 as well? If not, Michael, you're first.
14 MR. MOYER: Thank you for the opportunity 15 to make my comments and I promise that I will keep them 16 brief.
17 The NRC is guilty of regulatory capture in 18 my opinion. Regulatory capture occurs when a regulatory 19 agency created to act in the public interests instead 20 serves to advance and to promote the agenda of the very 21 industry it is charged with regulating.
22 Let me give you a very specific example. On 23 September 14, 2012, I wrote the NRC to request a delay 24 of final public hearing on the Environmental Impact 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 Statement of relicensing the Limerick Generating Station 1
until the NRC's U.S. court-ordered spent fuel study was 2
complete. I never received a response. Not a phone 3
call. Not a letter. Not an email. No response.
4
- Recently, I
called Congressman Jim 5
Gerlach's office and I also called Senator Bob Casey's 6
office for help in getting a response to my letter. I'd 7
like to publicly thank Greg Francis from the 8
Congressman's office and Kurt Imhof from the Senator's 9
office for personally contacting the NRC on my behalf.
10 Even after those efforts, and now some eight months after 11 I had written that letter, I still haven't heard back from 12 the NRC. And I suspect I never will.
13 This helps to illustrate a real-life 14 example of how regulatory capture works. In this case, 15 the regulatory agency in question seems to be more 16 concerned, in my opinion, with keeping Exelon's 17 relicensing of the Limerick Generating Station on track 18 than they are with responding to the concerns to protect 19 the public interest.
20 How is it in the public interest, for 21 example, to attempt to assess the environmental impact 22 of relicensing Limerick Generating Station when we don't 23 know the results of the spent fuel study? And we won't 24 know the results until some time in 2014. How can the 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 NRC properly assess the environmental impact of 1
relicensing Limerick Generating Station until the 2
earthquake mitigation plans have been completed? And we 3
won't know the results until some time in 2017. Why does 4
the NRC seem to be in such a mad rush to relicense a 5
nuclear facility when its license doesn't even expire 6
until 2024? Why? Why? Why?
7 The answer is simple: regulatory capture.
8 The Nuclear Regulatory Commission or better yet, the 9
Nuclear Rubberstamp Committee, which is precisely what 10 it appears to be in my opinion, is far more concerned with 11 being directed by Exelon and Exelon's schedule than it 12 is with responding to the health and safety concerns of 13 the public. That's why today I am formally calling for 14 a congressional investigation of the NRC's practices 15 based on regulatory capture, regulatory malpractice, and 16 willful abandonment of its charge to act in the public 17 interest.
18
- Further, as an elected official 19 representing over 6,000 residents across the Schuylkill 20 River in East Coventry Township, I am formally calling 21 for a final public hearing here in Pottstown before the 22 NRC grants any license renewals to Exelon for its 23 Limerick Generating Station. Thank you. Thank you for 24 your time and consideration.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 (Applause.)
1 FACILITATOR BARKLEY: Okay, thank you, Mr.
2 Moyer. Our next several speakers will be Mark Pavelich, 3
followed by Dr. Ann Baly.
4 MR. PAVELICH: Good evening. My name is 5
Mark Pavelich. I own a business called Organics and I 6
operate it and live in Dowington. I'm extremely 7
passionate about issues that relate to the environment 8
as my company develops, manufactures and deploys 9
materials in organic horticulture.
10 Thus, I'm in the forefront of environmental 11 issues daily. And I do support the relicensing of 12 Limerick Generating Station. Thank you.
13 (Applause.)
14 FACILITATOR BARKLEY: Okay, thank you, 15 Mark. Dr. Baly.
16 DR. BALY: I'm Anita or Ann Baly. I'm 17 mostly retired, former Lutheran pastor and professor of 18 theology. I'd like to comment on one specific 19 environmental issue and one more fundamental question.
20 And first, I just want to publicly thank the Pottstown 21 Mercury and Evan Grant, in particular, for the continued 22 and on-going and careful reporting that has been done on 23 this whole Limerick nuclear plant issue in our community.
24 Otherwise, most of us would know very little about it.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18 Environmentally, I am concerned about 1
evacuation. Now I just learned tonight that evacuation, 2
alas, falls into another unit of the NRC's portfolio.
3 But since the professed number one mission of the NRC is 4
to protect the public health and safety and because I 5
don't know whether that other unit will ever invite 6
public comment, I would like to speak briefly to 7
evacuation tonight.
8 I am in my mid-60s. I am healthy, mobile, 9
resourceful, informed, and well educated. I believe my 10 chances of successfully evacuating in the event of a 11 nuclear disaster are slim to none. I live a mile from 12 the plant at the Sanatoga Ridge Retirement Community. I 13 believe the chances of my neighbors evacuating 14 successfully, most of my neighbors are in their 80s or 15 90s, I think their chances could be described as simply 16 not having a prayer.
17 To pretend otherwise seems like a cruel 18 hoax. Any previous hopes that people would be 19 evacuating only in a ten-mile area, it seems to me, have 20 been definitively answered and dashed by the actual human 21 behavior we saw at Fukushima during their nuclear 22 disaster. People evacuated within a 50-mile area and 23 they had to.
24 When nuclear disaster strikes at Limerick, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 people will be evacuating all over the greater 1
Philadelphia area and into New Jersey. Millions of 2
people, all competing in a panic mode for the same roads 3
that serve us so poorly around here during an ordinary 4
rush hour. And it can only get worse because daily the 5
population increases.
6 But environmental impacts, crucial as they 7
are, are secondary questions. I really wish someone 8
would address why this licensing procedure is happening 9
so early. Unit 2's present license, as Mr. Moyer 10 explained, isn't even up for 16 years. Only God knows 11 what will happen tomorrow, let alone 16 years from now.
12 We will be learning that only as we go along.
13 Think back just 12 years ago. Remember 14 those days, the spring of 2001? I still enjoyed flying 15 in airplanes. I had no sense that the United States in 16 the contiguous 48 states could be attacked by anyone.
17 Our economy was robust, employment was full, interest 18 rates were high. I hadn't even heard of email. Our 19 general feeling in America was that of happiness and 20 safety. Well, all that has changed.
21 Much will happen in the next 12 years that 22 no one can foresee. To proceeding with licensing now 23 makes no sense. It almost seems as though the NRC is 24 saying to us our mind is made up. Do not confuse us with 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 any present or future facts, circumstances, insights, 1
developments, or technologies.
2 Someone must be profiting by this reckless 3
rush to relicense, but the public is being harmed by the 4
haste. You, Nuclear Regulatory Commission, have the 5
power to change this. Please, slow the process down.
6 Thank you.
7 (Applause.)
8 FACILITATOR BARKLEY: Thank you, Ann. Our 9
next speaker is Gail Brown, followed by Donna Cuthbert, 10 and then Leanne Birkmire.
11 MS. BROWN: My name is Gail Brown. And my 12 neighbor is the Limerick Generating Station. I live a 13 short distance from Frick's Lock National Registered 14 Historic District. About two thirds of this district is 15 within the exclusionary boundary, right on the cusp of 16 the Limerick Generating
- Station, therefore, 17 uninhabited.
18 Greatly due to increasing vandalism and a 19 fire at the Lock Tender's House in February 2008, the 20 Frick's Lock stakeholders were formed to negotiate a 21 satisfactory resolution towards the preservation of 22 Frick's Lock. The stakeholders were represented by 23 members from Exelon, the Schuylkill River Heritage Area, 24 East Coventry Township, Chester County, Senator Breneman 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 and Preservation Pennsylvania, and the Pennsylvania 1
Historic and Museum Commission.
2 On February 14, 2011, Valentine's Day, an 3
agreement between Exelon and East Coventry Township was 4
accepted to rehabilitate Frick's Lock. Construction 5
began and was completed the following year 2012. The 6
first public tour of Frick's Lock Historic District is 7
scheduled for June 8, 2013.
8 I believe this is the first time a major 9
utility has rehabilitated a National Historic District 10 in negotiated terms to allow a local historical 11 commission limited access to conduct guided tours within 12 the EAB. Not only did this project enrich the history 13 and heritage of our community, but Frick's Lock also lies 14 adjacent to the proposed Schuylkill River Trail and as 15 a trail head will be a tourist destination and a boost 16 to our local economy.
17 As a
member of the Frick's Lock 18 stakeholders, I am still amazed at what can be 19 accomplished when a large corporation, Exelon, is 20 willing to come to the table and work with individuals 21 and a community to contribute to and enhance our 22 resources. Thank you, Exelon, and I look forward to a 23 continued participation within the Frick's Lock 24 stakeholders.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 (Applause.)
1 FACILITATOR BARKLEY: Here you go, Donna.
2 MS. CUTHBERT: For an agency mandated to 3
protect public health from Limerick nuclear plant 4
operations, NRC's mindset and insistence on repeatedly 5
denying reality is intolerable. NRC's denial protects 6
Exelon's profits and NRC jobs, but they allow more people 7
to become tragic victims of Limerick nuclear plant's 8
radiation and other toxic releases.
9 Sadly, NRC is infested with conflicts of 10 interest which are leading to lies that will further 11 jeopardize everyone in our region.
12 NRC obviously ignored documented evidence 13 of environmental and health harm, compiled and submitted 14 to NRC for this EIS in 2011 by ACE. This evidence should 15 have been alarming even to NRC.
16 NRC did no monitoring or testing. In 17 reality, NRC has no idea how much radiation is released 18 from Limerick. Based on flawed and outdated theoretical 19 models for radiation exposure which only measure 20 external doses and ignore internal doses, NRC 21 shamefully, shamefully continues to absurdly claim 22 Limerick radiation releases are safe. Permissible does 23 not mean safe.
24 In 2005, the National Academy of Sciences, 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 BEIR VII Report said there is no safe level. Dr. John 1
Gofman, once head of AEC's labs raised dire warnings 2
about permitted releases from nuclear plants. He 3
published research warning about permitted releases from 4
nuclear plants. He estimated 32,000 Americans would die 5
each year from fatal cancers induced by allowable 6
radiation releases. Gofman said the entire nuclear 7
power program is based on a fraud that there is a 8
permissible dose that wouldn't hurt anyone. And 9
frankly, we're tired of hearing NRC people say that.
10 We provided NRC with evidence showing 11 communities around Limerick already exacted a high 12 public health toll since Limerick started operating. A 13 cancer crisis has been documented by Pennsylvania cancer 14 registry statistics and CDC data. Cancer rates 15 skyrocketed far above the national average after 1985 16 when Limerick started releasing radiation into our air, 17 water, soil, and people. Links to Limerick are clear.
18 Limerick routinely releases radiation. Radiation 19 causes cancer. We have a cancer crisis and one of the 20 largest relays for life anywhere.
21 The upward trend in childhood cancer rates 22 provides the most tragic link. By the late 1980s, 23 childhood cancer rates climbed to 30 percent higher than 24 the national average; higher by 60 percent in the early 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 1990s and a shock 92.5 percent higher than the national 1
average in the late 1990s. Infant and neonatal 2
mortality rates are far higher than the state average and 3
even higher than Philadelphia and Redding. Studies 4
provide a link.
5 When nuclear plants open, infant mortality 6
rates go up. When they close, rates go down. Autism 7
rose a whopping 310 percent from 1990 to 2000. Learning 8
disabilities increased by 94 percent, a rate double the 9
state increase. Strontium-90 radiation is an 10 undeniable link. Limerick releases strontium-90.
11 It's in our air, water, and soil. Strontium-90 is also 12 documented in the babies' teeth of our children at some 13 of the highest levels in the nation. NRC still 14 shamefully tries to blame decades old bomb testing far 15 from our region. It's ridiculous.
16 Many cancers rose dramatically by the late 17 1990s. Examples include thyroid cancer, 128 percent 18 increase; multiple myeloma, 91 percent increase; breast 19 cancer, 61 percent increase, higher than the national 20 average in every age group and it is 51 percent higher 21 in women 30 to 44. There's a 48 percent increase in 22 leukemia, almost double the state average.
23 Limerick nuclear plant is clearly a major 24 factor in the tragic and costly health crisis around it 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 with children the most profoundly impacted victims.
1 Exposure to Limerick's radiation is an unavoidable and 2
intolerable injustice. We can't see it, smell, taste, 3
or feel it, but it's everywhere. We can't avoid it.
4 As long as Limerick nuclear plant continues 5
to operate, radiation and other dangerous toxics will be 6
released into our air and water and more people will 7
suffer needlessly. We have lost patience with NRC's 8
lies, coverups and negligence. NRC should close 9
Limerick now to protect public health. It's time to stop 10 unnecessary exposures and associated suffering and 11 healthcare costs due to Limerick's operations.
12 (Applause.)
13 FACILITATOR BARKLEY: Thank you, Donna.
14 Leanne. And Tina Daly is next.
15 MS. BIRKMIRE: Good evening. My name is 16 Leanne Birkmire.
I live in Jeffersonville, 17 Pennsylvania. I'm a chemical engineer by trade and I've 18 worked for Exelon for nine years. The past four have 19 been at Limerick Generating Station. My group is 20 responsible for monitoring of the air, water, land, 21 waste, chemicals, tanks, and wildlife in accordance with 22 state, local, and federal regulation.
23 I'm also the lead of the Environmental 24 Stewardship Committee at Limerick Generating Station, a 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 group of approximately 30 volunteer employees who 1
participate in conservation efforts both at the station 2
and in their communities.
3 I believe that Limerick is safe both in its 4
design and in that the employees come to work every day 5
recognizing that nuclear technology is special and 6
unique. I believe that Limerick is operated in a manner 7
that protects the environment and that conservative 8
decisionmaking is used at the station to ensure that we 9
protect the plant, we protect the workers, we protect the 10 public, and we protect the environment for future 11 generations.
12 I support the approval of the Draft 13 Environmental Impact Statement for renewal of Limerick's 14 operating license. Thank you for your time.
15 (Applause.)
16 FACILITATOR BARKLEY:
Tina's next.
17 Followed by Charlie Shank.
18 MS. DALY: My name is Tina Daly. I live 19 within ten miles of Limerick. I have been following the 20 process since the days of the Limerick Ecology Action.
21 I was one of two citizens who commented on the latest air 22 permit, so I won't get into that tonight, and one of the 23 very few who commented on the NPDES permit, also I won't 24 get into that.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 I also spent years worrying over the DRBC 1
water augmentation request that dedicates the Schuylkill 2
River to the production of nuclear power. I am opposed 3
to the relicensing and I believe this plant should be 4
safely decommissioned as soon as possible and with full 5
on-the-record public participation at every step.
6 The DSEIS is completely self serving and 7
shows how far NRC is in bed with Exelon. Nuclear 8
regulatory means regulate. NRC is paid for by all of us 9
and should be fair and impartial. It is strange that the 10 NRC wrote the DEIS. The NRC set up the interior rules, 11 including small, moderate, and large -- what a brilliant 12 idea -- and whether something is new or old. And the NRC 13 will decide whether or not to relicense. What a farce.
14 This is not the way to make decisions.
15 The public notice was not informative in the 16 least. Obviously, NRC is not interested in public 17 input. The notice appeared on 5/9/13 and today is two 18 weeks later. I, for one, cannot adequately review this 19 document in that time frame. However, I do thank the NRC 20 for making the paper copies available on request.
21 This is a meeting that's being transcribed.
22 Are we on the record as we would be at a hearing? Is NRC 23 on the record? I agree with Mr. Moyer, the supervisor, 24 that there should be an on the record public hearing.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 NEPA Section 1502.2(f) says agencies shall not commit 1
resources prejudging selections of alternatives before 2
making a final decision.
3 On page 123 of this document it says "the 4
USNRC preliminary recommendation is that the adverse 5
environmental impacts of license renewal for LGS are not 6
great enough to deny the option of license renewal for 7
energy planning decision makers." I think the NRC is not 8
in compliance with NEPA and I think this needs to be 9
looked into. I think the law is being broken.
10 Throughout the supplemental, we are told 11 that there is no new information to change the past EIS 12 and decisions. The fact is there are lots of new pieces 13 of information. One of the new pieces Donna mentioned 14 is the National Academy's National Research Council BEIR 15 VII No. 2 Report which says there's no safe level of 16 exposure to radiation.
This is new since LGS 17 started up. It is not considered here. I couldn't find 18 anything about it in the document that I was given. It 19 must be considered because of all of the reasons Donna 20 said.
21 Most of the maps are no good. Quickly, show 22 me the star on page 2-3. Show me the township names.
23 What is the location of the business shown on page 217, 24 etcetera. Some of the maps have circles around the plant 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 at varying distances, so of course, you can't compare 1
them.
2 I looked at all the references they used.
3 The references include work by private firms for 4
corporations as far as I can see. Who paid for these 5
studies? Where did the money come from? It seems that 6
NRC did not use work done by such organizations as the 7
Union of Concerned Scientists, Beyond Nuclear, or ACE.
8 This is an example of how NRC is in bed with one side.
9 New also is the above-ground storage of 10 spent nuclear fuel. That certainly wasn't here before 11 and that certainly presents a huge danger to us all. And 12 I might add the public hearing on that was held in the 13 context of whether they could put cement pads in a certain 14 zoning district.
15 New rules about spent fuel may be released 16 in 2014, so this relicensing is obviously premature.
17 The whole document is full of things like 18 the term "permanent disposal." There is no such thing 19 as permanent disposal. Also, there's a reference to 20 corporate wildlife habitat certification. It's just 21 one of the references on one of the lines. This 22 certainly throws all those references about wildlife 23 into question to say the least.
24 Historic resources, Frick's Lock aside, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 don't include some of the places that I know are on the 1
Historic District and it also said that there were no 2
federal lands owned in the 50-mile radius except Valley 3
Forge. Maybe the Independence National Park isn't 4
nationally owned. I don't know. Hopewell Furnace, the 5
Heinz National Wildlife Refuge, I question that.
6 Also federal money is being spent on the 7
Highlands. NRC is a lackey to the nuclear industry and 8
NRC should not consider this premature license 9
application and its circular arguments. NRC should be 10 reorganized into a non-biased, regulatory commission 11 prior to any further decision making. I plan to extend 12 these remarks before the deadline is over.
13 (Applause.)
14 FACILITATOR BARKLEY: Thank you, Tina.
15 Charlie. Then Paul Gunter is up.
16 MR. SHANK: Before I start, I just want to 17 thank again Mr. Moyer for coming over and making his 18 comments. He seems to be the only one who is aware of 19 the potential dangers over there in East Coventry 20 accepting that land.
- Recently, the Limerick 21 nuclear plant refueled Reactor 1. It also uprated the 22 plant to produce more energy. To do this they have mixed 23 in a more powerful fuel, GNF2, and changed the shape of 24 the fuel bundles. These changes make more power, more 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31 radiation, more heat, and more stress on the aging 1
equipment. Exelon is now close to the maximum output for 2
the Limerick reactors. To add more power, expensive 3
changes would be necessary to handle even greater 4
stresses and greater radiation.
5 Every day, 14.2 million gallons of very hot 6
water leave the cooling towers loaded with dissolved 7
solids and radiation. This hot brew goes down Pipe 001 8
to the diffuser and into the Schuylkill River. It enters 9
the river at 110 degrees Fahrenheit a much higher 10 temperature than the Schuylkill River limit of 87 degrees 11 Fahrenheit. Over the course next 30 years, that will 12 amount to about 150 billion gallons of polluted water 13 going into the river.
14 When water is hotter than 95 degrees 15 Fahrenheit it fosters the growth of thermophilic 16 microbial organisms.
These organisms include 17 legionella, yes, legionella, and salmonella among 18 others. These pathogens thrive in warm water. They can 19 also cause fatal infections and pneumonia in compromised 20 individuals and the elderly. This hot water needs to be 21 cooled down more than it can be at the present time.
22 Exelon asked the Pennsylvania Department of 23 Environmental Protection to provide comments about these 24 pathogenic organisms in the river. Exelon wanted the PA 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 DEP to confirm Exelon's conclusions that no harm would 1
come from the pathogens during an extended period of 2
operation with these higher temperatures. The 3
Pennsylvania DEP, to its credit, said it had no data on 4
these organisms in the river to support Exelon's claim.
5 The PA DEP was unable to reach any conclusions as to the 6
possible health effects, thus, not supporting Exelon's 7
contentions.
8 I think it would be better to have more 9
independent study done now than solve any unknowns before 10 racing to relicense Limerick. We have 11 years 11 remaining in the present license period to properly work 12 out these problems. We should not just skip over them 13 or wait until a serious accident happens. The job of the 14 NRC is to promote public safety, not the nuclear 15 industry. The way the NRC has been acting lately, makes 16 the IRS look good.
17 I support ACE's recommendations about the 18 Senate investigation of the NRC and about having a public 19 hearing here for relicensing back in Pottstown.
20 Lastly, I want to mention how Exelon and the 21 agencies like the NRC are destroying public trust. This 22 isn't something that just happened over night. It's 23 been coming on for many, many years. For one thing, they 24 eliminate. They eliminate proper temperature controls 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 and heat standards for the Schuylkill. They allow dirty 1
Wadesville water into the Schuylkill. They grant 2
radiation exemptions. They grant total dissolved solid 3
exemptions. They ignore Clean Air and Clear Water Act.
4 They delay timely notification of the public about 5
accidents and spills. They alter the river flow rate 6
measurements for convenience. They allow 20 time 7
increase in pipe leakage rates for Limerick so it can pass 8
a test. They stall fuel pool liner repairs. They stall 9
protective vent installation. They fail to require 10 filters for the vents. They misled Limerick 11 construction costs. Deceived. The NRC inspectors had 12 been instructed not to write things down on paper so they 13 won't show up in FOIA requests.
14 Secrets. They withhold Exelon information 15 from the public concerning foreign ownership or 16 investors. My favorite, the evacuation plan. The NRC 17 requires this plant for relicensing, they pay for it, 18 Exelon does, and then everybody ignores it.
19 Among some of us, we think of this plant as 20 a dinosaur. To me, the industry is dying, but they just 21 don't want to admit it. We call it nukesaurus. Our 22 country is smarter than this. Because of corporate 23 greed and control, they have taken over this business and 24 this relicensing. We should start over with a fresh 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 sheet of paper. The rest of the world is moving ahead 1
while we tread water. We can do better than this. We 2
can certainly do better than what we're doing now. Thank 3
you very much.
4 (Applause.)
5 FACILITATOR BARKLEY: Paul, after you will 6
be Zach Chizar.
7 MR. GUNTER: Thank you. My name is Paul 8
Gunter. I'm Director of the Reactor Oversight Project 9
at Beyond Nuclear in Takoma Park, Maryland. And I drove 10 up here tonight basically with the message that the 11 relicensing of the Limerick plant is more than just a 12 local issue.
13 The concerns here are far reaching and I 14 think that the story that I wanted to bring to start off 15 with was the concern is how can you do an accurate 16 Environmental Impact Statement if in the midst of trying 17 to figure out just how far the reach of the Fukushima 18 Daiichi nuclear accident really is and in terms of its 19 impact on land contamination, air, water, and marine 20 environment contamination by radioactivity from this 21 accident?
22 And so it's our recommendation, our 23 request, that this relicensing be suspended until 24 there's a more reliable reviewable Environmental Impact 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 35 Statement that tells us what's the results from Fukushima 1
Daiichi and the nuclear catastrophe that happened at the 2
GE boiling water reactors there similar to those here.
3 At Fukushima Daiichi, it was General 4
Electric Mark I boiling water reactor for Units 1 through 5
5 and Unit 6 is a Mark II, like Fukushima Daiichi. And 6
I'm going to recall a story. On March 11, 2011, I was 7
called into CNN in Washington, D.C. to comment on the 8
accident that was emerging at the Fukushima Daiichi 9
facility and I was asked by correspondent Jean Mazur to 10 just briefly say what is your concern as simply as you 11 can put it. And what I said and what was on The Situation 12 Room report for that evening was our concern is that this 13 reactor could literally blow its roof off.
14 And that remark was contrasted by Tony 15 Pietrangelo with the Nuclear Energy Institute that said 16 there's no evidence that there's any threat to 17 containment. What proved out the next day was the 18 explosions that then repeated themselves. And it wasn't 19 a prediction on our part. It was never a prediction, but 20 it was the fact that we've known, I've known for decades, 21 that these GE boiling water reactors are unreliable in 22 terms of their primary component for protecting the 23 public in the event of a severe accident, that being the 24 containment structure.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 36 The Atomic Energy Commission which is the 1
predecessor of the Nuclear Regulatory Commission, its 2
chief safety officer in 1972 said that plant should never 3
be built. And that the reliance on other GE Mark I 4
reactors should be suspended. That was ignored. And in 5
fact, the concerns have only grown since then to the point 6
that on the eve of the explosions at Fukushima this was 7
what carried our concern.
8 But first and foremost, this relicensing 9
should not be going forward because the Nuclear 10 Regulatory Commission's own requirements for the 11 licensing agreement for Limerick have been violated or 12 are in violation. And to extend the operating license 13 is to extend that violation.
14 And I want to read into the record NRC 15 general design criteria which states "the principle 16 design criteria established the necessary design, 17 fabrication, construction, testing, and performance 18 requirements for structures, systems, components, 19 important to safety. That is, structures, systems and 20 components that provide reasonable assurance that the 21 facility can be operated without undue risk to public 22 health and safety."
23 It then goes on to identify general design 24 criterion 16 which is the containment design and states, 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 "requires reactor containment and associated systems 1
shall be provided to establish an essentially leak-tight 2
barrier 3
against the uncontrolled release of radioactivity to the 4
environment and to assure that the containment design 5
conditions important to safety are not exceeded as long 6
as postulated accident conditions require. Essentially 7
leak-tight barrier against uncontrolled release of 8
radioactivity."
9 This is a violation of the licensing 10 agreement as currently operated by Exelon at Limerick 11 facility. But it doesn't stop there. The NRC staff by 12 their own document, SECY-2012-0157, has stated that 13 given a severe accident involving core damage, there's 14 only roughly a 50-50 chance of recovering from the 15 nuclear accident within the pressure vessel and no 16 significant radioactive release from containment.
17 That's a 50-50 chance that it will occur with a 18 significant release from the containment to the 19 environment.
20 The document also reads "if the vessel 21 fails, there is only a 25 percent chance that the 22 operators might cool the molten core inside the 23 containment with no significant release to the 24 environment." In other words, by NRC staff's own 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 38 judgment, that's a 75 percent chance of a core melt 1
exiting containment. That said, NRC states that there 2
is an 11.8 percent chance that a severe core damage 3
sequence would lead to early overpressure containment 4
failure where there is a 90 percent chance that the molten 5
core bypasses the suppression pool, being a primary 6
component of the containment for the Mark II because of 7
drain line failure or a rupture in the drywell, another 8
component.
9 Essentially, this paints a picture for you 10 for us of a very large radioactive release to the 11 environment because of this unreliable containment.
12 Again, which is in violation of Exelon's licensing 13 agreement.
14 The licensing renewal process -- basically, 15 the NRC has never rejected a license renewal application.
16 There have been 75 plants that have received their 17 license extension and the NRC has never really in our 18 experience and we've participated in a number of these 19 interventions, the NRC is always an adversary to 20 questions, concerns, contentions, that would raise the 21 safety bar or question the extension of these operating 22 licenses. So the NRC in these proceedings stands for 23 Nuclear Regulatory Conveyor that is intent upon speeding 24 up the process, granting early application, and it's our 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 39 contention that if you're wondering why Exelon is making 1
its application so early, it's one of our contentions 2
that the industry and the agency have colluded to avoid 3
answering questions about the lesser environmental 4
impact from the on-coming renewable energy renaissance, 5
revolution that is happening, that is attracting 6
investment and is growing by leaps and bounds. The NRC 7
doesn't want to make that kind of information in its 8
Environmental Impact Statement. That's why -- that's 9
precisely why Exelon or any of these other utilities can 10 make application as early as 20 years. That's the rule.
11 I mean what kind of Environmental Impact 12 Statement is worth anything if it's fixed 20 years before 13 the federal action is even required? This gives you the 14 basic plan and blueprint for a bias that this Agency and 15 this industry have concocted to expedite these license 16 extensions prior to what they view as a lot of unwelcome 17 and unnecessary questions about renewable wind, solar, 18 energy efficiency, and whole host of 21st century energy 19 policy chances that are going to happen, that are 20 happening. Thank you.
21 (Applause.)
22 FACILITATOR BARKLEY: Thank you, Paul. Is 23 it Chizar?
24 MR. CHIZAR: Chizar.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 40 FACILITATOR BARKLEY: I butchered it 1
really bad. Dr. Cuthbert, you'll be up next.
2 MR. CHIZAR: Hi. My name is Zach Chizar 3
and I'm an administrator with the Pennsylvania Energy 4
Alliance. Day in and day out, we educate Pennsylvanians 5
about nuclear power as a clean, safe, and reliable source 6
of energy for the future. One of the most rewarding 7
parts of working with this coalition is getting out into 8
the community to meet different people, so many of whom 9
already support nuclear energy.
10 In early April, we were in this very room 11 for Representative Mark Painter's Live Well Expo. Many 12 attendees came by our table to learn about us and some 13 even shared stories about Limerick Generating Station 14 dating back to its origination when it was first opened.
15 Over the last six months, we've had two 16 groups of fourth grade students from Brooke Elementary 17 and Limerick Elementary nearby visit Limerick Generating 18 Station. Nuclear energy is part of their current 19 curriculum in school and the visit served as a perfect 20 wrap up for the unit. The students were actively engaged 21 and many asked great questions about the facility some 22 of which were even interested in how to work there when 23 they were older.
24 In addition, we were also present at the 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 41 community information night that was held last week at 1
Limerick Generating Station. Community events such as 2
this continue to show that results from our March 2012 3
poll still hold true that the public opinion of nuclear 4
power is still very strong and positive near our State's 5
five power plants.
6 As the need for energy continually 7
increases, nuclear power proves to be the most reliable 8
and environmentally friendly solution. Thank you.
9 (Applause.)
10 FACILITATOR BARKLEY: Thank you, Zach.
11 After Dr. Cuthbert, will be Betty Shank and then finally 12 Lorraine.
13 DR.
CUTHBERT:
Thank
- you, Rich.
14 Throughout this Environmental Impact Statement that has 15 been drafted and presented by the NRC, the Agency has 16 persistently and continuously understated, minimized, 17 or denied the documented evidence of harms from Limerick 18 nuclear plant.
19 Your pro-nuclear industry bias is well 20 established, but it's also shameful at the same time. We 21 reviewed the document in its entirety and I will refer 22 to just a few items that illustrate the points that we 23 make on behalf of protecting the public.
24 In Section 9.3.1 of your EIS you admit that 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 42 "during nuclear power plant operations, workers and 1
members of the public would face unavoidable exposure to 2
radiation and hazardous toxic chemicals." Despite this 3
fact, NRC has actually suggested in this repugnant EIS 4
that all of the environmental harms from Limerick are 5
small. I'm going to repeat, all of the environmental 6
harms from Limerick are small and have no measurable 7
impacts.
8 Nuclear power plants are the only 9
facilities on the planet with the capability of rendering 10 entire regions uninhabitable for decades, if not 11 centuries, in the event of a radiation disaster. For NRC 12 to claim that all power generating facilities generate 13 similar wastes is another lie. You stated "the 14 generation of spent fuel and waste material including 15 low-level radioactive waste, hazardous waste, and 16 nonhazardous waste would also be generated at 17 non-nuclear power generating facilities." Really?
18 NRC staff also concluded that cumulative 19 impacts from Limerick's license renewal would be small 20 in all areas except aquatic ecology and terrestrial 21 ecology. That conclusion is patently absurd. You 22 arrogantly and irresponsibly dismiss the harms, risks, 23 and threats from Limerick as callously as you consider 24 the members of our community to be merely acceptable 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 43 collateral damage. You should be ashamed.
1 Even more astonishing than that, NRC staff 2
concluded that continued operation of Limerick nuclear 3
plant would have less environmental impacts than either 4
solar or wind alternatives on air quality, groundwater, 5
surface water, human health and aesthetics. Such 6
conclusions are beyond untenable and unscientific.
7 They bring new meaning to the term hubris. These 8
ludicrous conclusions by NRC are laughable. And yet, 9
they may not be sufficient to reject the Limerick EIS as 10 having zero credibility.
11 In Section 9.3.2 of your EIS Exelon claims 12 "after decommissioning these facilities, and restoring 13 the area, the land could be available for other 14 productive uses." This is a delusional conclusion, 15 worthy of no less than four Pinocchios. This is the same 16 land that Exelon claimed was worth zero when it fought 17 to avoid paying its fair share of property taxes for 18 years.
19 Consider this alternative. The only 20 acceptable use of this site after decommissioning to 21 members of our community would be as a regional NRC 22 office. NRC has utilized their checklist mentality, 23 referred to earlier, through other testimonies.
24 As an approach throughout this EIS, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 44 Limerick's evacuation plan is a perfect example of the 1
checklist mentality. Exelon was required to have an 2
update to its plan on file with NRC no later than 2011.
3 The document was finally submitted to NRC in December 4
2012. Analysis of that document, Exelon's evacuation 5
time estimate, ETE, for Limerick nuclear plant's plume 6
exposure pathway reveals that that update is based on 7
unrealistic, unworkable suppositions, assumptions, 8
inconsistencies, inaccuracies which we have enumerated, 9
and illogical conclusions. NRC refused repeated 10 requests to meet to review our detailed analysis of 11 Exelon's fatally-flawed report.
12 Even more shocking than that, was the 13 admission by NRC officials that they had no need or 14 intention to review, evaluate, or approve Exelon's ETE.
15 The report was turned in, checked, good enough.
16 Well, not for us.
17 Every elected official in this region 18 should be outraged. Exelon's ETE should be summarily 19 rejected by elected officials and the NRC for that 20 matter. This EIS for Limerick nuclear plant is nothing 21 less than an insult to our community. Unsupported 22 conclusions appear to fit your predetermined decision to 23 use your infamous rubber stamp and approve an EIS that 24 will facilitate relicensing of Limerick.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 45 The narrative simply does not comport with 1
reality or documented facts in many areas. This biased 2
EIS is invalid, detached from reality, and unacceptable.
3 You can do much better. NRC has now lost all credibility 4
in the eyes of this community. It is painfully evident 5
that NRC is becoming a cowardly agency, unwilling to 6
implement or enforce minimal protection of the public, 7
despite readily available scientific evidence and 8
well-documented harms.
9 Sadly, you choose to be a subservient lapdog 10 to the nuclear industry and their lobbyists rather than 11 a vigilant watchdog protecting public interest. Only 12 willful blindness could explain this EIS for Limerick 13 nuclear plant which is nothing less than a white wash of 14 epic proportion.
15 It is our conclusion and recommendation 16 that the United States Senate should investigate the NRC 17 for wilful blindness and regulatory malpractice and 18 disallow or forbid all permitting decisions for Limerick 19 nuclear plant until all unresolved findings, legal 20 issues and recommendations from NRC's own staff are 21 finalized and implemented.
22 And finally, ACE is again formally 23 requesting that NRC hold a public hearing in Pottstown 24 to address all of the relicensing issues for Limerick 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 46 nuclear plant not specifically or adequately addressed 1
in the environmental impacts. Our community deserves 2
nothing less.
3 (Applause.)
4 FACILITATOR BARKLEY: Thank you. Betty?
5 And finally, Lorraine after her.
6 MS. SHANK: I have read NRC's safety 7
evaluation reviews of Limerick and inspections and 8
notices of violations. NRC inspectors, to their credit, 9
do a good job identifying problems and citing violations, 10 but somehow they get whitewashed by the time violations 11 are issued.
12 Maybe what the public needs is what is done 13 for Exelon. A cost-benefit analysis. If it got one, 14 the result would show how indefensible Limerick license 15 renewal is. NRC's job is to protect the public. But it 16 has never acknowledged the astronomical costs and the 17 lack of benefits for the public that results from 18 Limerick nuclear operations.
19 As taxpayers and ratepayers, the public 20 does not benefit from Limerick nuclear energy because 21 Exelon makes its enormous profits while the public pays 22 the lion's share of its business costs in one of the 23 biggest corporate welfare schemes ever.
24 Public costs include construction costs, 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 47 the enormous costs skyrocketed and were attached to 1
electric rates that climbed to a whopping 55 percent 2
above the national average.
3 Property and school taxes, Exelon refused 4
to pay its fair share for years. Eventually, a 5
settlement was reached and Exelon now pays around $3 6
million a year. But that's a pittance compared to the 7
$17 million it should have been paying each year all 8
along.
9 Avoidable diseases, cancers and other 10 illnesses in this region are much higher than the 11 national average and are linked to Limerick's radiation.
12 The cost for one six-month-old child treated for just two 13 years who has cancer is over $2 million.
14 Water contamination. Limerick's toxic and 15 radioactive waste water discharges cost water companies 16 and their customers more money. Exelon should filter to 17 protect public health and protect the water companies and 18 the people who use their water downstream 19 High-level radioactive waste storage.
20 Tons are produced at Limerick every year, remaining 21 deadly virtually forever. The public cost is in higher 22 taxes. And we are charged for it to be stored at 23 Limerick.
24 Decommissioning. That's funded through 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 48 hidden charges in our electric bills and through 1
miscalculations, deliberate or not, on Exelon's part, 2
$100 million will be needed for Limerick which Exelon 3
wants ratepayers to fund. Exelon makes mistakes, but we 4
pay for them.
5 Exelon hands out donations like candy with 6
one hand and picks our pockets to do it with the other.
7 Its contributions to this community are paid for by us.
8 It's pennies on the dollar for Exelon and the cost to the 9
public are incalculable.
10 I do not support NRC's decision to relicense 11 Limerick or understand why it is rushing to do so. And 12 I fully support the Cuthbert's recommendations that come 13 from ACE and that are calling for a renewed look at this 14 problem. Thank you.
15 (Applause.)
16 FACILITATOR BARKLEY: Lorraine and if 17 there's anyone else that would like to speak, please come 18 see me.
19 MS. RUPPE: Hi, my name is Lorraine Ruppe 20 and I live in Pottstown. How can NRC believe Exelon's 21 outlandish claims that they are stewards of the 22 environment when, in fact, evidence shows Exelon is 23 damaging the environment every day Limerick operates.
24 Common sense tells us nothing in the world 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 49 threatens our environment and our health more than 1
Limerick nuclear plant operations. We shouldn't have to 2
live with radiation, other toxics poisoning our water and 3
bombarding our children because of Limerick nuclear 4
plant operations. We shouldn't be faced with the 5
depleting water supply because of Limerick's cooling 6
towers or risk having no water if Limerick has an accident 7
or a meltdown.
Our drinking water could dry 8
up or become so radioactive we can't use it.
9 Exelon pumps toxic minewater into the river 10 up to 80 times safe drinking water standards. The toxics 11 don't magically disappear. They end up in our drinking 12 water. And manganese, one of the toxics can lead to 13 permanent brain damage from showering.
14 NRC dismissed serious threats to public 15 drinking water from Limerick nuclear plant. NRC met 16 with DEP and DRBC, but they just gave Limerick five-year 17 permits to use and pollute our drinking water with 18 dangerous loopholes and exemptions because Limerick 19 can't meet safe drinking water standards or other 20 protected limits. That didn't reduce our risks.
21 Exelon should have been required to filter 22 Limerick discharges and those from the minewater to 23 protect our drinking water and public health. Limerick 24 causes irreparable and irreversible damage to the river 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 50 and then donates to a fund deceptively claiming they 1
protect the river. Not one dime of that fund was ever 2
spent to reduce Limerick's radioactive or other toxic 3
discharges.
4 Exelon's donations are a drop in the bucket 5
compared to their profits and tax avoidances. Sadly, 6
organizations hoping to get funding from Exelon ignore 7
Limerick's poisoning of our water and children.
8 How can we take care of our health when we 9
are forced to drink, bathe in, and breathe in toxic 10 chemicals from Limerick operations every day? Too many 11 people are really sick, have thyroid problems and are 12 dying of dreaded disease like cancer.
13 Look at the huge cancer rallies in our 14 community. Why should we risk our lives and fear 15 meltdown, more sickness, cancer from Limerick's 16 electricity when safer energy is available. The problem 17 is NRC appears to be more of a salesman than a policeman.
18 Nuclear power already destroyed parts of 19 the world. This dangerous dinosaur technology must make 20 way for safe, clean energy alternatives that won't 21 destroy our water supplies and our health. Thank you.
22 (Applause.)
23 FACILITATOR BARKLEY: Thank you, Lorraine.
24 Okay, at this point we have a little more 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 51 time left. If there's anyone else that wanted to make 1
any additional remarks I can have them up and if not I 2
will at this point wrap up this meeting.
3 I was very pleased with the comments 4
provided and the way you handled yourselves during this 5
meeting. I very much appreciated your respect for each 6
and every one of the people in the audience. At this 7
point again, we had mentioned you can submit written 8
comments regarding the EIS up until June 27th, so I 9
encourage you to do that and at this point I'd like to 10 wrap up this meeting. Thanks very much.
11 (Whereupon, at 8:25 p.m,, the public 12 meeting was concluded.)
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