ML13182A011

Comment (8) of Charlie and Betty Shank Requesting That NRC to Reconsider Environmental Impacts of Its Decision to Re-License Limerick Units 1 & 2

ML13182A011
Person / Time
Site:	Limerick
Issue date:	06/26/2013
From:	Shank B, Shank C - No Known Affiliation
To:	Cindy Bladey, Leslie Perkins Rules, Announcements, and Directives Branch
References
78FR26663 00008, NRC-2011-0166
Download: ML13182A011 (16)

Text

Mendiola, Doris

Subject:

Attachments:

FW: Limerick DRAFT EIS - Docket ID NRC 2011-0166 Betty and Charlie Shank - E-Mail Comments to NRC 26-13.docx; 6-26-13 CHART -

2011 Violations.doc From: BettyShank [1]

Sent: Wednesday, June 26, 2013 3:13 PM Fn To: PerKins, Leslie C__

Subject:

Limerick DRAFT EIS - Docket ID NRC 2011-0166 N_>

To Ms. Bladey c/o Leslie Perkins, Ti 4F Please add the attachments in this e-mail as additional comments to the written comments we mailed to you June 24, 2013, on NRC's DRAFT EIS for Limerick Nuclear Plant Docket ID NRC-2011-0166.

The attached information is provided to you because we feel it is unacceptable for NRC to exclude ANY impact of Limerick nuclear operations without weighing and evaluating all aspects of Limerick operations carefully. They all have the potential to lead to devastating environmental impacts, whether or not the NRC acknowledges it.

Please be sure all our comments are included in the official NRC public record for Limerick Nuclear Plant's DRAFT EIS.

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Thank you, Charlie and Betty Shank

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tI Charlie and Betty Shank 2461 East High Street, Unit f-28 Pottstown, PA 19464 Cindy Bladey Chief, Rules, Announcements, and Directives Branch (RADB)

Division of Administrative Services, Office of Administration Mail Stop: TWB-05-BO1M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Public Comment: NRC Draft EIS for approving Exelon's License Renewal Application for Limerick Nuclear Plant Docket ID NRC-2011-0166 It may seem insignificant at this moment to point out a superficial detail when so many huge issues are at stake, but we feel that the NRC has shown an astonishing level of insensitivity by releasing the NRC Summary Report on the transcript of the Environmental Impact Statement (EIS) comments from the 9/22/11 EIS public meeting that it says were considered for Limerick's Draft EIS on March 11, 2013 (the 2nd anniversary of the Fukushima disaster).

Probably just a coincidence, it is however, a perfect metaphor for the obliviousness of the NRC to the realities of the world its decisions affect. That pattern of willfulness and stubbornness began at Limerick the moment he NRC put on its blinders concerning Limerick, which was more than a decade before it licensed Limerick's Unit 1.

In April, 1972 a nuclear accident in Germany at the AEG-Kraftwerks Union (KWU) Wurgassen Nuclear Plant was caused by a GE Mark II Boiling Water Reactor. This is relevant because that accident drew attention to the essential design flaw inherent to all GE Mark II Boiling Water Reactors. The KWU accident resulted from a rupture caused by enormous unanticipated BWR vibrations, equal to the seismic vibrations of a major earthquake that built up during the quenching process (cooling process) causing the safety relief valve to fail to close.

On November 15,1972, the first component of Limerick's GE Mark II Boiling Water Reactor rolled onto PECO's (predecessor of Exelon) proposed site aboard a 90-wheel truck. This is relevant because it is indicative of PECO/Exelon's "put the cart before the horse" mentality. In this particular case, before completion of a geological survey or issuance of a construction permit, PECO had made a huge financial investment which, apparently for the NRC, out-weighed concerns about the protection of health, safety, and the environment for millions of people when it licensed Limerick in 1984. We object to NRC's deference to Exelon's repeated use of the cart-before-the-horse strategy strategy. It seems to be a variation of the bad advice given by an old pickpocket to a young recruit:

"Remember, take what you want. It's easier to get forgiveness than to get permission". That is not fair to the public, which has paid a heavy price when PECO/Exelon is wrong.

By 1984, PECO had already committed billions of dollars to the NRC-approved (we assume) experimental bracing for its defective GE Mark II Boiling Water Reactors, the cost of which was attached to ratepayer bills. PECO's rates were already 20-25% higher than the rest of the state, and Limerick wasn't even operating yet. Already on the side of PECO financial pursuits at the expence of public health, safety and the environment, NRC issued Limerick's license for Unit I that same year..

In 1985, PECO was heady with excitement and the public was protesting Limerick's Unit I "went critical" and Limerick Nuclear Plant operations began. "Forbes" didn't share ANY of Exelon's excitement in 1985, labeling U.S. nuclear power "the largest managerial disaster in business history".

Currently, there are a host of problems at Limerick, every one of which has profound environmental impacts.

NRC claims that only those issues it chooses to consider have environmental impacts. We cannot dispute the fact that the NRC has the authority to approve Limerick despite its environmental impacts, and Limerick's environmental impacts are ENORMOUS, despite WHAT the NRC says. We see them because evidence shows they are there. NRC can see them too. No matter how powerful the NRC is, it cannot change the sun into the moon by simply calling the sun the moon.

Limerick's environmental impacts result from incredibly complex complicated problems that become significantly larger as one is seen in relation to another: age-related degradation of Limerick's equipment, systems, underground pipes, and cables, soaring costs, renewed evacuation concerns, expanded data on radiation impacts, concerns with NRC's inexplicable failure to continue to exercise its oversight of Limerick's Motor Operated Valve (MOV) which failed and threatened the long-term stability of Limerick, AND the failure of which broke the law! And all this pales in comparison with Limerick's unresolved high-level radioactive waste issues, when considered in conjunction with the newly revealed Sanatoga Fault running directly under the site!

All of these issues have colossal environmental impacts and the NRC is just playing word games in this terrible game of nuclear roulette. Exelon and NRC decision-makers seem like blinded, self-proclaimed rulers, who are aware that evidence shows that people suffer from Limerick's devastating nuclear operations, but view Limerick's victims as acceptable collateral damage in the battle to preserve Exelon's financial interests at Limerick.

The EIS category labeled "Support for License Renewal" contained comments that came from those who were employed by or received contributions or donations from Exelon: Limerick site VP, VP of License Renewal, Exelon, State Representative, Tom Quigley, Limerick Township Supervisor, Tri-County Chamber of Commerce, Jaeco/ Gas Breaker/UMAC, Inc.,PA Energy Alliance (nuclear PR group), Borough Council. NRC noted in the EIS transcript that the comments in this category provided no new and significant information and would not be considered further.

2 The rest of the public comments transcribed showed great concerns about re-licensing Limerick in light of its unresolved environmental impacts. Well-researched and thorough examinations of the public risks due to the environmental impacts associated with Limerick operations were reflected in many thoughtful educated comments. Cogent analysis of the scope of the environmental impacts that the NRC stubbornly refuses to acknowledge were made by:

1. ACE: Dr. Cuthbert in the afternoon session (pgs. 36-41)

Donna Cuthbert in the evening session (pgs.98-102)

Dr. Cuthbert in the evening session (pgs. 113-118)

2. Montgomery County Planning Commission (pgs.160 - 163)

3. Montgomery County Department of Public Safety: (pgs. 164-165)

4. NRDC (pgs. 166-172)

The NRC treats the public as if we have no value beyond our usefulness as taxpayers, valued only for our ability to fuel massive nuclear subsidies.

The presentation by the NRC of its Draft EIS at its 5/23/13 meeting is a perfect example of NRC's attempt to manipulate perception. The NRC made statements that were contrary to evidence in the EIS transcript. NRC seems to believe that if NRC says something is true, then it becomes truth. This is a problem of incalculable magnitude because it means that NRC's statements can't be relied upon to accurately assess the safety of Limerick Nuclear Plant operations or its true current or potential environment impacts.

One evening earlier this year, we went to a small sparsely attended NRC public meeting at the Limerick Township Building. Despite NRC's statements that it is fully engaged with the public, it looked like the public was not really welcome. Tables and chairs were stacked against the walls (except for a table by the door covered with NRC brochures). The year before, there had been cloth-covered tables in the open with chairs around them, as well as chairs ringing the room.

When we asked who we could talk io about Limerick's safety issues, we were introduced to two NRC representatives. As we all introduced ourselves, they helped us get out folding chairs and we sat down cordially. We chatted amiably, but none of our questions were answered.

We asked about the tonnage and condition of Limerick's highly-packed fuel pools, the "Untimely Declaration of Notification of Unusual Event Following an Earthquake", and Exelon's deferral of safety upgrades. We got no answers.

The year before, we had come to a similar sparsely attended meeting (in part due to minimal official publicity and the scheduling of meetings a day or two before a holiday, or the night before school starts, etc., an NRC pattern). We wanted to discuss our new discovery of the Sanatoga Fault map that showed the fault ran directly under the site and renewed earthquake concerns. But NRC officials expressed ignorance of the map, implying that they knew nothing of the fault and stood by NRC's decades-old original earthquake analysis for Limerick.

We also expressed concerns about the tons of pollution caused by chemicals that come out of the cooling towers as PM-10 with attached radionuclides, along with millions of gallons a day of river water which forms the steamy plumes that can contribute to a multitude of health problems and depletes our river. An NRC official told us that it was just steam, "like steam from your tea kettle". But we understand from the Title V Permit that chemicals added to the towers amount to thousands of pounds of pollution, not "just steam".

These experiences explain what the NRC is attempting to do by defining Limerick's environmental impacts as "small":

saying what it wishes was true. But we see brutality in that childish ploy.

We KNOW that Limerick's environmental impacts cannot be separated from the safety of Limerick's operations. ACE has gathered over a decade of documented harms to public health, safety, and the environment and the harms have been incalculable!

We helped ACE to prepare graphics for NRC's Draft EIS meeting to illustrate our concerns about LIMERICK'S ENORMOUS ENVIRONMENTAL IMPACTS. but NRC officials did not seem to have any knowledge about the issues that worried us. Why do NRC officials profess to know so little about the common workings and issues pertaining to a particular plant?

A Japanese film crew was at the Draft EIS meeting in May. On Friday evening, June 2 1st, NHK aired some footage filmed at that meeting. The selection of spliced pieces was used in Japan to promote nuclear energy reinvestment by promising better public involvement with Japan's NRA (its version of the NRC) based on the illusion that meaningful dialogue between the public and NRC exists in the U.S. What a tragedy that such a false perception of welcomed public involvement with the NRC in the U.S. is being used to lure the Japanese public into submitting to the unnecessary, devastating, and inevitable harms created by nuclear energy production, which are still unresolved in the wake of Fukushima.

This situation reminds us of the early promises made in the U.S. by the nuclear industry about Limerick. In 1980, PECO's V.P. said nuclear energy would be "too cheap to meter". We feel that the NRC's assessment of Limerick's environmental impacts as "small" is similarly unrealistic. It is an injustice to millions of people and an affront to society's moral responsibility to be stewards of the environment for our posterity to keep Limerick on "artificial life support" to protect Exelon's losing gamble that nuclear energy would net great profits.

The following pages document a sampling of evidence that Limerick's environmental impacts are larger, by far, that the NRC is willing to admit.

3 NRC ERRONEOUSLY STATES THAT LIMERICK'S ENVIRONMENTAL IMPACTS ARE SMALL

1. NRC relinquished control of NRC's regulatory process related to the a crucial valve critical to maintaining Limerick plant stability:

Exelon is now in control of that crucial valve.

In 2011, during an accident at Limerick, NRC cited Limerick with noncompliance of a legally binding requirement involving the "failure of feedwater Motor Operated Valve (MOV) which resulted in loss of Core Isolation Coolant (RCIC) for longer than specifications allow according to Technical Specifications (TS)". The NRC cited the violation as a WEAKNESS IN MAINTAINING PLANT STABILITY.

In 2012, Exelon requested an amendment taking the MOV out of Technical Specifications (TS), under NRC regulatory control, and moving the MOV into the Technical Manual (TM),under Exelon's control and not regulated by NRC.

In 2013, the NRC inexplicably granted Exelon's request! However, at TMI, on March 28, 1979, the immediate cause of the loss-of-coolant accident that allowed the uncovering of the core and the melting of about half of it was a valve that stuck open and allowed large volumes of water to escape.

Is this one of those valves? We have grave concerns about it and would appreciate a comprehensive investigation of it.

2. NRC laxity regarding Limerick's aging GE Mark II Boiling Water Reactors (BWRs):

NRC Inspection Reports note serious degradation of Limerick's BWRs that could impact stability, like wear and tear at BWR vessel attachments, and yet NRC has inexplicably granted Exelon "Relief Requests" for such things as weld inspections, counting relief as compliance for re-licensing.

GE has repeatedly warned Limerick about BWR deficiencies, suggesting tests be performed to ensure safe shut down. Did NRC require Exelon to test? What was the outcome?

It is important to note that a nuclear accident in Germany at the AEG-Kraftwerks Union (KWU) Wurgassen Nuclear Plant was caused by a GE Mark II Boiling Water Reactor in 1974. This is relevant because that accident drew attention to the essential design flaw inherent to all GE Mark II Boiling Water Reactors. The KWU accident resulted from a rupture due to enormous unanticipated BWR vibrations, equal to the seismic vibrations of a major earthquake that built up during the quenching process (cooling process) causing the safety relief valve to fail to close.

But PECO had made a financial investment in Limerick's BWRs by that time. SO, to save them, it experimented with an armature to lesson the vibrations. The Philadelphia Inquirer (1984) reported that: "Limerick's modifications included hundreds of additional pipe supports and elaborate bracing systems to make the reactor systems more rigid.., similar to PP&L's Susquehanna Plant... You see pipe supports three times as big as the pipes themselves because of the changes."

Why has NRC granted Exelon relief requests for Limerick Vessel Attachment Weld Inspection and Evaluation Guidelines? In 1984, it was reported that hundreds of safety-related welds at the nuclear plant were not properly performed by the Bechtel Power Corp. welders and that the welds were not properly inspected by Bechtel and NRC inspectors (Mercury, 8/31/84).

On July 11, 2012, the NRC cited Exelon with a violation due to an accident by operator error involving BWR channels at Limerick. The inoperability of two independent channels was an issue: Limerick maintains that safety was maintained, however fatigue cracks were observed along the weld toe due to reverse bending and indicated the line was subject to vibration. Exelon was further cited for failing to respond to NRC in a timely fashion about the issue. We do not know if NRC's oversight in this area is as protective of the public as we would like it to be.

We are very concerned that the following NRC actions may further increase risks to the public:

License Amendment to Modify Safety Limit Minimum Unit 1, Cycle 15 GRANTED Jan. 30/ 2012 Core Operating Limits Report For Limerick Generating Station Unit 1, Cycle 15 GRANTED April 3,2013 "Withdrawal Notice" of "Reporting procedure for mathematical models selected to predict heated effluent dispersion in natural water bodies." (Regulatory Guide (RG) 4.4, NRC-posted in the Federal Register) GRANTED April 3. 2013 Core Operating Limits Report For Limerick Generating Station Unit 2, Reload 12 GRANTED June 10, 2013 Questions concerning these NRC/Exelon actions:

Was the intent of these actions to remove impediments to limiting heated discharges? If so, why?

Theses actions have serious implications for adverse health risks.

If Exelon can't comply with standard limits on heated effluents, why doesn't NRC withhold granting the requests?

Do these actions totally remove the core limits? Do they compromise the integrity of the already degraded BWRs?

>' If the BWRs run hotter, won't they degrade faster?

>' Will NRC adjust its application approval by mandating an adjustment to Exelon's calculation for the accelerated aging effects that may impact the already degrading BWRs, due to higher heat?

We believe a new fuel mix(GNF2) is being used at Limerick. If so, does the new fuel mix produce more heat?

NRC/Exelon history shows a pattern of proceeding with action before (or despite) the possible adverse consequences.

4

>' Is there any way to independently check Limerick's discharge temperatures without NRC or Exelon interference?

a Another concern: everyday, 14.2 million gallons of very hot water leave the cooling towers loaded with dissolved solids and radiation. This hot brew goes down pipe 001 to the diffuser and into the Schuylkill River.

It enters the river at 110 F, a much higher temperature than the Schuylkill River limit of 87 F. When water is hotter than 95 F, it fosters the growth of thermophilic microbic organisms. These organisms include Legionella and Salmonella, among others. These pathogens thrive in warm water. They can also cause fatal infections and pneumonia in compromised individuals and the elderly. This hot water needs to be cooled down more than it can be at the present time.

Exelon asked the Pa. DEP to provide comments about these pathogenic organisms in the river. Exelon wanted the Pa. DEP to confirm Exelon's conclusions that no harm would come from the pathogens during an extended period of operation with these higher temperatures.

The Pa. DEP, to its credit, said it had no data on these organisms in the river to support Exelon's claims. The Pa. DEP was unable to reach any conclusions as to the possible health effects, thus not supporting Exelon's contentions.

3. NRC's refusal to update Limerick's SAMA:

NRC has allowed many of its regulations to be systematically re-written by the NEI (Nuclear Energy Institute),

the powerful lobbying arm of the nuclear industry. The NRC has allowed the NEI to thus create more regulatory protection for the industry, which significantly weakens safety for the public.

An example is the difficulty encountered by the NRDC, when it attempted to require an updated SAMA for Limerick. The NRC would not consider it. NRC's stubborn position is reinforced by the legal armature designed to preserve Limerick for financial reasons, without consideration of whether there's a need for nuclear energy. NRC stated its SAMA position in the federal register (2007): "Staff Position: The NRC staff recommends that applicants for license renewal follow the guidance provided in Nuclear Energy Institute (NEI) 0501, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, Revision A, when preparing their SAMA analysis."

In 2012, the NRC Commission refused the National Defense Resource Council's request (submitted in 2011) for an update of Limerick's SAMA on the grounds that the request was "an impermissible attack on our regulations".

4. NRC's refusal to update Limerick's earthquake analysis:

The Fukushima disaster began on March 11, 2011. Inexplicably, three months later, Exelon submitted its license renewal application for Limerick Nuclear Plant to the NRC.

NRC held a public meeting (9/22/11) to receive public comments on re-licensing Limerick. We were in the audience. A resident commented that she was still waiting for a response from the NRC about Limerick's closest faults, reminding the NRC that Limerick was ranked third on the U.S. Earthquake risk list.

Through ACE, we saw a copy of the resident's response from NRC. The letter and the map focused on the Chalfont Fault (9 miles away) and the Ramapo Fault (17 miles away). The map was complex, but yellow and orange highlight indicated the faults and the fault network.

But we remembered hearing rumors that there was a fault under the plant, and the NRC's map was so hard to decipher that we decided to go to the Pottstown Library to see if there were any other maps there that would be easier to understand. Among the Limerick volumes lining a shelf in the archives, we found a decades-old Geologic Survey by Dames and Moore submitted to PECO in 1974.

Within its pages we found a large fold-out map in color that clearly showed the Sanatoga Fault running under the proposed Limerick Nuclear Plant site. It did not show the Chalfont or Ramapo Faults, but it did show the Linfield Dike not far from the plant, as well as the line marked Quarry Splay close to the site.

In March 2012, when the NRC held a less formal NRC public meeting, we took a copy of the 1974 Geologic Survey map that we had found in the Library to show to the NRC. The NRC Chief, Projects Branch 4, said he'd never seen it before and he referred us to the NRC official who was the author of the resident's response letter and map, who was also present. He had never seen the 1974 map before, either. It seemed that neither had ever even heard of the Sanatoga Fault. However, we were very surprised to hear the author of the letter off-handedly mention that the Ramapo Fault was active...

ACE had arranged a meeting with our local paper and we shared both maps and their respective stories with a reporter. It was weeks after the NRC meeting when the story finally broke, and it covered several pages. Both the Geologic Survey map and the resident's NRC-provided map were splashed across the front page. The paper was full of articles providing an excellent review of many renewed earthquake concerns, including fracking and quarry issues (an active blasting quarry shares its border with Limerick).

The newspaper reported that an NRC spokesperson's answer to the question of whether the NRC had considered the Sanatoga Fault when it licensed Limerick began with "The short answer is yes"....and went on.

Missing from the story was what is always missing: the central issue at stake: the evasiveness of the NRC. Whenever there's an issue of import, like an unusual event or accident at Limerick, the NRC dusts up the story to create the impression that everything is under control.

5

5. Inaccurate prediction models, faulty assumptions: age-related degradation is already surpassing original models for predicting its speed:

No prediction model can protect the public from the dire consequences of Exelon's inaccurate hypotheses, calculations or poor judgment, which the NRC notes are pervasive at Limerick. And problems are growing, due to the age-related degradation resulting from 28 years of nuclear operations. Even so, with about a decade to go of Limerick's original licensed period, inexplicably, NRC is approving Exelon's license renewal request based on relaxed standards for Limerick:

In 2012, NRC refused NRDC's request for an update of Limerick's SAMA, labeling the request "An impermissible attack on our regulations".

In 2012, NRC pared down emergency and evacuation planning, without re-evaluating earthquake risks In 2013, ACE members discovered that NRC was either not aware of, or covered up, the existence of the Sanatoga Fault under the nuclear site (that met with a quarry splay that ran through the active blasting quarry that shares its border with the nuclear plant). NRC public statements have understated the risks.

In 2013, NRC threatened to refer ACE to its allegation team for expressing concerns about Exelon's unworkable Limerick Evacuation Time Estimate (which NRC requires for re-licensing, but refuses to review).This seems unwarranted, when NRC invites "meaningful" public participation.

6. The NRC has approved Exelon amendments that eliminate Limerick's compliance to NRC's re-licensing application requirements, meaning that problems are hidden, without being resolved.

7. NRC has relinquished regulatory control to Exelon officials, who determine what regulations Exelon will comply with and which ones it will eliminate.

8. NRC has repeatedly raised background radiation levels, which raise risks for the public here at Limerick:

The "background level" number that NRC assigns is a trigger point: nuclear plants must report levels above "background" on-site, as a spike indicates a serious problem. Our concern is that NRC's current number is so high that Exelon can claim Limerick's "routine operations and radiation releases" which may not reach the trigger point, comply with NRC regulations, but which, in reality, greatly increasing Limerick's adverse impact on public health, safety, and the environment. This is the history of NRC's assigned radiation level increases:

Pre-1964: natural background radiation: 60-80 Millerems per year Post-1964: NRC raised the level to 80-100 Millerems per year. A noted above, the significance of this is that it is a trigger point: when radiation readings at nuclear plants spiked above that NRC-set trigger point, notification of the NRC was required, Post-Chernobyl (1986): NRC raised the level to 360 Millirems per year Post-Fukushima (2011): NRC raised the level to 620 Millirems per year However, the 2005 National Academy of Science's BEIR VII Study, funded by the EPA, revealed that the smallest radiation dose could increase human health risks: there is no safe dose.

QUESTIONS:

1. Why is the NRC allowing Limerick to operate in violation of its license?

Over a decade of ACE research shows massive deficiencies, and at the top of this list of concerns is the fact that Limerick's GE Mark II Boiling Water Reactors are defective and NRC can't ensure public safety because Limerick's containment is not guaranteed.

2. Why does NRC rely on Exelon, a company with a vested interest in the outcome, to control Limerick's data and to amend NRC's regulations of Limerick so that Exelon appears to conform to regulations without actually having to comply?

Exelon explains Limerick's current licensed period: "The 40-year license term reflects the amortization period generally used by electric utility companies for large capital investments". Exelon's use of nuclear power is a purely financial decision. So, public safety is dependent on NRC regulation. Inexplicably, NRC states that Exelon controls the data that NRC receives and relies on to assess the safety of Limerick. We believe this process is upside-down and poses a significant threat to public health, safety, and the environment.

3. Why isn't NRC using Limerick's abysmal safety record as the strongest evidence that NRC should not rush approval of Limerick's license renewal?

ACE research, some of which was sent to your office in its request for a Senate investigation, documents extraordinary safety issues that NRC fails to address. More is included with this letter.

4. How can the Atomic Energy Act of 1954 be a relevant basis for the license renewal of Limerick in 2013?

The naivety of the 50's and the myth of nuclear safety must give way to the newly understood impacts of nuclear generation in the 2 1 st century. Re-licensing Limerick without requiring Exelon to comply with the conditions of

6 an ordinary NRC License Renewal Application should be viewed as a significant warning sign that Limerick operations must be very unsafe.

5. Why does NRC's "License Renewal Requirements for Power Reactors" sound less like "requirements" and more like a "disclaimer"?

On page '1-3' of Limerick's Safety Evaluation Report, 2012, released Jan. 10, 2013, NRC states that "License renewal requirements for power reactors are based on two key principles:

1. The regulatory process is adequate to ensure that the licensing basis of all currently operating plants maintain an acceptable level of safety with the possible exceptions of the detrimental aging effects on certain functions of certain structures, systems or components, as well as a few other safety-related issues, during the period of extended operation.

2. The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term."Would a person buy a used washing machine with a warranty like that? Limerick is a nuclear plant: it should be held to the highest standards, yet NRC has never required Limerick nuclear plant to be in compliance. Why?

6. How can NRC have any excuse for re-licensing Limerick when Limerick's present condition is so degraded that even current operations pose an incalculable risk public health, safety, and the environment?

7. Why do the four items, that the 1984 NRC section chief said that his staff wanted cleared up before licensing Limerick, still exist at Limerick? (Mercury, 8/31/84)

Improper procedures: pervasive and repeatedly cited by NRC.

Incomplete safety measures: pervasive and repeatedly cited by NRC.

A defective hydrogen remover: at least one accident in the re-licensing period involved a hydrogen leak: is there a way to confirm that the defective hydrogen remover was repaired or replaced?

Faulty valves: In 2011, about six months after Exelon applied for Limerick's license renewal, the NRC cited Limerick with a "white" violation, defined as a "WEAKNESS IN MAINTAINING LONG-TERM PLANT STABILITY". Unlike Limericks' usual violations of noncompliance to regulations, this violation was a "Violation of a Legally Binding Requirement". The violation involved the failure of the Motor Operated Valve (MOV), mentioned on the first page of this letter.

8. To what degree is NRC allowing Modifications to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events? (Issuance of Order: 3/13/12)

9. Is the NRC conducting a substantive "waste confidence study" that protects the public or, as we fear, relying on its phone conference with Exelon?

We hope it is not taking Exelon's word for how it is coping with the substandard containment, or protecting the above-ground storage from a terrorist attack, or providing for backup power in case of extended power outages to cool the fuel pools.

NRC officials told us at a meeting in 2013, that they rely on Exelon to take care of that and they couldn't tell us anything about waste-storage issues.

10. What is the reason that Exelon, a declining private corporation, which some say is on the wrong side of energy progress, can operate Limerick, thus eliminating the public's right to clean air, water, and the environment for posterity, as guaranteed in Pennsylvania's constitution when its method?

See ACE research on how Limerick's nuclear energy can be replaced by readily available, safer, cheaper energy technologies.

11. How can NRC justify the risks to the public caused by Limerick's pervasive safety violations, when demand for nuclear energy is down, alternative energy is available, and so many local businesses have chosen solar over nuclear?

See ACE data on the many local corporations and organizations that have chosen solar over nuclear energy.

12. Why has NRC excused Limerick from complying Compliance with GALL regulations in Limerick's License Renewal Application?

In 1998, the NRC allowed the NEI to amend the GALL Report to make the process of nuclear plant license renewal easier and faster. The Nuclear Energy Institute (NEI) is the powerful lobbying arm of the nuclear industry.

GALL Commitment No. 46 requires applicants for license renewal to test and confirm that their programs for aging equipment and systems work as a condition for re-licensing.

However, Exelon requested the elimination of GALL Commitment No. 46 by amendment that would substitute a one-time test at Limerick in the future. NRC pointed out that eliminating the test would create a 10-year gap during which there would be no way to tell if planned "aging management programs are effective, require modification, or whether there is a need to develop new aging management programs". Exelon's application also contained:

& Deviations from GALL (Generic Aging Lessons Learned)

7 Unclear explanations Unclear theory for aging management And yet NRC approved Exelon's application for Limerick license renewal. The NRC goes through the motions, but the rewording of compliance regulations by NRC and Exelon virtually eliminates literal active safety compliance: it just How can NRC trust Exelon's hypothetical calculations for determining Limerick's possible age-related future repair or equipment replacement needs, when Exelon can't follow simple directions to set aside its share of Limerick's decommissioning funds? NRC cited Exelon with a violation for substituting an Exelon-devised formula for the NRC formula, but the public may pay the price as Exelon potentially could add a burden of $1 million to rate payer costs.

Exelon doesn't pay for its mistakes, Limerick's history shows that the public does, which is patently unfair.

14. Why, when Limerick is in such massive noncompliance, does NRC allow Exelon to:

Control and supply NRC with data, generally without any independent verification.

Impede the regulatory process with little consequence.

Defer notifying NRC in a timely manner.

Substitute untried, nonconforming calculations for NRC's assigned formulas.

CHRONOLOGICAL HISTORY OF LIMERICK & NRC'S BETRAYAL OF PUBLIC TRUST:

Public concerns mount with each Limerick accident while NRC downplays the risks in public statements. The truth is hard to find and NRC seems to have designed it that way. Information is fragmented, with a piece of the story in the newspaper, another piece in an Inspection Report, another in a Safety Evaluation Report, a detail in a letter from Exelon to the NRC one year, and a response to Exelon from NRC the next, and so on. Information about one safety issue is separated into parts and spread here and there amid hundreds of pages of several documents. The following history is an outline of what we have pieced together. It shows some of Limerick's problems and NRC's lax regulation of plant safety issues. This incomplete history shows how the problems of 2013 were forged at Limerick's birth and provides the basis for why we are requesting a U.S. Senate investigation of NRC.

1954 Sept. 16:

Lewis Strauss, the first chairman of the Atomic Energy Commission, in a speech at the National Association of Science Writers, NY City, said, "Our children will enjoy in their homes electrical energy too cheap to meter". The speech was evidence of his hope but was later used by PECO and other energy companies, to sell the idea of nuclear energy to the public.

Between 1975 & 1992, PECO customer bills rose by 204%.

Late '60's H & K Quarry (also known as Sanatoga Trap Rock) began operations. PECO "went public" (sought financial backing and investors). PECO must have known that Limerick Nuclear Plant would share its boundary line with the quarry and share the same rock bed. The blasting quarry still operates today. We have been assured that the blasts are well controlled. The quarry is easy to see on a Google satellite map of Limerick Nuclear Plant.

The NRC had not yet begun operations when PECO plans for its nuclear plant became known. This is relevant because the parent of the NRC, the Atomic Energy Commission (AEC) was in charge when PECO secretly began buying homes and farms for the Limerick Nuclear Plant before local people were aware that their lands would become part of the site for a nuclear plant.

The AEC is relevant because the AEC was promoting and regulating nuclear plants long before it issued PECO's construction permit for Limerick Nuclear Plant in 1974.Limerick's permit was issued the same year that the AEC was dissolved due to its controversial decisions.

1972 A nuclear accident in Germany at the AEG-Kraftwerks Union (KWU) Wurgassen Nuclear Plant was caused by a GE Mark II Boiling Water Reactor.

This is relevant because that accident drew attention to the essential design flaw inherent to all GE Mark II Boiling Water Reactors. The KWU accident resulted from a rupture due to enormous unanticipated BWR vibrations, equal to the seismic vibrations of a major earthquake that built up during the quenching process (cooling process) causing the safety relief valve to fail to close.

197N2(cont.)

November 15:

8 The first component of Limerick's GE Mark II Boiling Water Reactor rolled onto PECO's proposed site aboard a 90-wheel truck.

This is relevant because it is indicative of PECO/Exelon's "put the cart before the horse" mentality. In this particular case, before completion of a geological survey or issuance of a construction permit, PECO had made a huge financial investment which, apparently for the NRC, out-weighed concerns about the protection of health, safety, and the environment for millions of people when it licensed Limerick in 1984. We object to NRC's deference to Exelon's repeated use of the cart-before-the-horse strategy strategy. It seems to be a variation of the bad advice given by an old pickpocket to a young recruit: "Remember, take what you want. It's easier to get forgiveness than to get permission". That is not fair to the public, which has paid a heavy price when PECO/Exelon is wrong.

1974 July 30:

Limerick's Geologic Report (by Dames and Moore) was submitted to PECO.

The report included a letter to the PECO VP that stated: "The scope of our studies was defined during discussions with Philadelphia Electric Company and outlined in our letter of April 11, 1974...The results of this comprehensive investigation indicate that shears exposed in the excavation are not capable by AEC definition"... (what was the definition? There was much controversy at the time about the wisdom of assessing earthquake potential based on the AEC definition of exposed shear capability, as opposed to other methods available at the time, which resulted in a different conclusion. A U.S. senate investigation on this matter might spur the NRC to update Limerick's earthquake analysis.

The Sanatoga Fault that ran under the proposed nuclear plant was clear on the included map. The map showed that the fault traveled straight for a short distance until it touched a line marked "Quarry Splay".

The map did not show the active blasting quarry abutting Limerick Nuclear Plant's boundary line. If it had, the line marked "Quarry Splay" that the Sanatoga Fault met, would have been visible running through the quarry.

It is our understanding that the active blasting quarry was operating before the first component for the defective GE Mark II BWR rolled onto the site, before the Geologic Report was submitted to PECO, before the AEC granted Limerick's construction permit, and before the NRC granted the license for Unit 1. The active blasting quarry is still in operation today.

This is relevant because the Virginia earthquake caused an unusual event at Limerick Nuclear Plant in 201 land NRC cited Exelon for "Untimely Declaration of Notification of Unusual Event following an Earthquake". We sent an email to the NRC April 12, 2013 concerning the August 2011 Virginia earthquake and its impact on Limerick. May 10, 2013, we received a response from an NRC Limerick site inspector stating that vibrations were felt on site but no systems or equipment were affected per walk down inspection.

The inspector further noted that seismic monitoring instruments were actuated during the Virginia earthquake.

The instruments do not self-reset and must be restored to OPERABLE within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a CHANNEL CALIBRATION performed within 5 days following the seismic event.

On September 3, 2010 NRC was notified by GE Hitachi that Limerick's key safety mechanism, the control rods inserted between the rods of nuclear fuel in the GE Mark II BWRs might fail to "scram", or shut down quickly in the event of an earthquake. Friction, worsened in the assembly during an earthquake, might prevent the control rods from moving into position during an earthquake.

On September 26, 2010, GE Hitachi warned NRC that the "scram capability of the control rod drive mechanism may not be sufficient to allow the fuel rods to fully insert". Certain conditions need to be present for this to occur, but "while there may have been a time when the chances of such a string of events happening all at once might be dismissed as too unlikely, the earthquake and subsequent tsunami in Japan in March and Virginia earthquake in August have given such 'what if' scenarios added credence". (Evan Brandt Mercury, 10/5/11)

Not only are we concerned with the integrity of the channels in the BWRs, we are also worried about what can't be seen with a visual inspection. Damage could have been done underground in the miles of pipes and cables that can't be detected with a visual inspection, yet NRC based its conclusion only on a visual walk down. Even rattled underground pipes could leak and go undetected for a long time before Exelon might know. And they could be difficult to fix.

We are requesting that all this be fully investigated and disclosed to the public by NRC.

1975 Jan. 19:

NRC began operations. It had been created with the power and authority to license and regulate commercial nuclear reactors in regard to protecting public health, safety, and the environment.

1978 In a PECO volume archived in the Pottstown Public Library, titled "Design Assessment Report", page 1.3-2 states that "the quencher load specification was submitted to the NRC by PP& L in April 1978. In addition, a full scale SSES unique unit cell test was performed by KWU".

9 KWU is Kraftwerks Wurgassen Union, who, we believe, helped with developing the framework design for stabilizing the defective BWRs. It is essential to note that this was experimental. We have many questions. Do the BWR's still vibrate? Are there any condensation issues, or increased heat due to new fuel combinations, as heat and condensation might accelerate BWR degradation. Has NRC required any new calculation adjustments to adjust for accelerated aging?

The Philadelphia Inquirer (1984) reported that: "Limerick's modifications included hundreds of additional pipe supports and elaborate bracing systems to make the reactor systems more rigid.., similar to PP&L's Susquehanna Plant...You see pipe supports three times as big as the pipes themselves because of the changes.

1979 March 28:

The TMI nuclear plant partial meltdown accident in Pennsylvania resulted in a meltdown of fuel, but it is reported that the melted fuel did not breach containment. A valve stuck open and allowed the escape of enough water to expose the core and melt about half of it.

1980 May 28:

At a Congressional hearing on Limerick evacuation, the NRC and members of Congress outlined many reasons that Limerick should not be built. PECO's V.P. angrily sparred with members of congress and chastised the public for not wanting Limerick Nuclear Plant, saying it would keep electricity costs down. He further testified that, "Emergencies that require evacuation will not occur". He said that safety features at Limerick Plant would not allow the escape of deadly radiation even if an accident did occur.

NRC Director Denton stated that Limerick's population was already twice as dense as the maximum deemed appropriate for safe evacuation.

1981 Limerick Ecology Action (LEA, predecessor of ACE) filed suit against Limerick for violating environmental standards and for not considering design alternatives. We believe that NRC should have halted construction pending resolution of the suit, but construction continued.

1983 Auqust 3:

The GAO declared that Limerick evacuation plans are deficient.

1984 Before Unit 1 ever went on line, PECO customers already had the highest electric rates in Pennsylvania. PECO was expecting to ask for a rate increase of 20-25% after Unit 1 was operational in1985.

1985 Au-q. 8:

Despite unworkable evacuation plans, as well as the lawsuit filed by LEA, the NRC licensed Limerick's Unit 1.

1986 The world was witness to the devastating Chernobyl disaster, still adversely impacting health, today. It was the worst nuclear plant disaster the world had suffered until Fukushima, in 2011.

1989 AuQ. 25:

NRC issues operating license for LGS Unit 2. LEA had won its suit against Limerick, but the case had been dragged on until the plant was built and both Units were licensed.

1995 Limerick Nuclear Plant's Unit 1 experienced a "near miss", according to NRC documentation. Does that mean the core was almost or partially exposed? How close is a "near miss" to a meltdown? The public should have answers to these questions. Was there any BWR damage?

2001 Limerick Nuclear Plant's Unit 2 experienced a "near miss", according to NRC documentation. Again, does that mean the core was almost or partially exposed? How close is a "near miss" to a meltdown? The public should have answers to these questions. Was there any BWR damage?

10 2010 Sept. 3:

GE Hitachi warns NRC that Limerick's key safety mechanism, the control rods inserted between the rods of nuclear fuel in the GE Mark II BWR's, might fail to "scram", or shut down quickly in the event of an earthquake.

Friction, worsened in the assembly during an earthquake, might prevent the control rods from moving into position during an earthquake. (Evan Brandt, Mercury, 10/5/11)

Sept. 26:

GE Hitachi warns NRC that the "scram capability of the control rod drive mechanism may not be sufficient to allow the fuel rods to fully insert". Certain conditions need to be present for this to occur, but "while there may have been a time when the chances of such a string of events happening all at once might be dismissed as too unlikely, the earthquake and subsequent tsunami in Japan in March and Virginia earthquake in August have given such 'what if' scenarios added credence". (Evan Brandt Mercury, 10/5/11) 2011 Mar. 11:

Fukushima multiple meltdowns created horrifying chaos in Japan. Fukushima showed the havoc of evacuation and that radiation dispersal cannot be controlled during meltdown. One of the saddest outcomes was that radiation contamination was so severe that some children were turned away from hospitals because the children were too radioactive.

NRC, perhaps traumatized by the overwhelming evidence of harms created by radiation and meltdown, initiated a false "study" at MIT to "prove" radiation is "harmless" (or, was it perhaps fueled by concerns about liability issues?)

Public concerns have grown about Limerick's lack of evacuation plans and insufficient water sources in the case of a sustained meltdown or a cyber attack that could knock out the grid, or a terrorist attack that could cause a meltdown in the above ground high-level radioactive fuel pools.

NRC has not done enough to ensure that Exelon has enough backup power to keep the cooling water flowing for a sustained power outage. It has been postulated that a cyber attack could knock out the grid for as long as two years. Where would the back-up power come from? Where would enough water come from? Or how can NRC guarantee that Limerick fuel pools won't melt down if there is a direct hit due to terrorist attack? Or enough water to cool the pools for five years, if need be? We urge the U.S. Senate to find out how much planning has been done, if any.

June 22:

Only 3 months after Fukushima, Exelon submitted a License Renewal Application for Limerick Nuclear Plant.

Amazing! (see the 2011 chart of Limerick safety violations) 2011 (cont.)

AUQ. 23:

The Virginia earthquake jolts the Philadelphia region all the way to New England Limerick is third on the earthquake risk list Limerick has the second highest most densely populated evacuation zone NRC has refused to do an updated SAMA NRC has refused to reevaluate its earthquake risk analysis Sept. 19:

The NRC issued a new report which "immediately requires operators to re-evaluate whether U.S. plants can withstand earthquakes and floods". (Associated Press, reported by Evan Brandt, Mercury, 10/5/11) Brandt states that the AP report used NRC data and concluded that "the risk an earthquake would cause a severe accident at a U.S. nuclear plant is greater than previously thought - 24 times as high in one case."

The AP analysis mirrored one done by MSNBC.com in March that also used NRC data to determine that the risk of earthquake damage was greater than once thought by the federal agency. The MSNBC.com report ranked Limerick as the plant with the third highest risk of being damaged by an earthquake.

The NRC disavowed both the MSNBC.com and the AP analysis.

Sept 22:

The NRC held a public meeting to accept comments on the environmental impacts of Limerick, regarding re-licensing. The NRC was questioned by a resident concerning its lack of response to her question 6 months earlier about the nearest faults to Limerick (see page 3 of this letter packet, # 4)

Sept. 30:

GE called for shut-down tests on its Mark II BWRs worldwide. It is unclear if Limerick complied.

Sept. 30:

NRC issued Limerick a violation to for "Untimely Notification of Unusual Event Following an Earthquake" (see page 3, # 4)

Nov. 22:

NRDC submits a request for an updated Limerick SAMA (see page 3, # 3) 2012 The GAO declares Limerick evacuation plans deficient. Exelon refuses to discuss evacuation plans publicly.

11 June 8:

Circuit court judge issues "Waste Confidence" ruling, mandating that re-licensing Limerick cannot occur until 2014, pending a review of spent fuel issues.

2013 Jan. 11 It was reported that a 2nd circuit court of appeals ruled that the NRC could not continue its practice of issuing "exemptions to its own health and safety regulations in secret.

Jan. 14 In an email to the NRC Chief at Limerick, we voiced concerns about what appeared to be missing pages from the Design Assessment Report (DAR), Vol. I, Limerick Generating Station, Units 1 & 2, Philadelphia Electric Company.

They pertained to GE Mark II BWR testing done, we believe, prior to NRC's licensing of Unit 1. In Chapter 8, the labeled notebook divider tab is there, but the information is missing for, " Mark II T-Quencher Verification Test". The next tab is labeled "Response to NRC Questions". It is followed by labeled subsections, but in subsections 100, 300,

& 500, the information is missing. In its response to our email, the NRC knew nothing about the volume.

May23 The NRC held a public meeting to accept comments on NRC's Draft Environmental Impact Statement (EIS).

During both sessions of the meeting, the NRC presented a Power Point presentation through which it announced that.

the NRC had concluded that Limerick's environmental impacts were "small" and that NRC was considering re-licensing Limerick.

ACE members and many others voiced serious concerns at the May 23 meeting about NRC's flawed reasoning.

Dr. Lewis Cuthbert announced that ACE would call for a U.S. Senate Investigation of the NRC. We strongly support ACE in that endeavor.

DOCUMENTS RELEVANT TO OUR QUESTIONS CONCERNING NRC AND LIMERICK NRC's negligent refusal to require Limerick compliance to regulations by Exelon is documented in the following publicly available documents:

"Withholding Information from Public Disclosure" correspondence between NRC and Exelon NRC "Requests for Additional information" (RAIs) resulting from NRC safety Inspections at Limerick NRC "RAIs" in response to Exelon's requested amendments to regulations NRC "RAIs" in response to the submission by Exelon for Limerick's License Renewal Application Summaries of NRC Telephone Conferences pertaining to Limerick issues Google satellite maps of Limerick Nuclear Plant Newspaper accounts of early licensing issues, and current Limerick events, and accidents Various multi-source material relevant to Exelon, Limerick, and the NRC NRC "Findings for CY 2011 at Limerick Generating Station" NRC "Aging Management Programs Audit Report Regarding the Limerick Generating Station, Units 1 & 2,"

Oct. 3, 2011 - Oct. 14, 2011 (NRC claims the audit 'verifies' Exelon's compliance to the GALL Report)

NRC "Limerick Generating Station-Integrated Inspection Report" June 4, 2012 - June 21, 2012 ("NRC claims it 'verifies' Exelon's license renewal program")

July 1, 2012 - Sept. 30, 2012 ("Inspection and Notice of Violation")

NRC Limerick Generating Station - Integrated Inspection Report and Office of Investigations Report (Jan. 1, 2013-March 31, 2013) Note of explanation: The Office of Investigations initiated its inspection due to one isolated incident, not a plant-wide investigation. The incident was a violation involving a technician's mistake in entering a room without the proper neutron dosimetry, which was found not to have been deliberate and easily remedied (our words are used here and are an over-simplification of NRC language, but to the best of our understanding, the Office of Investigations was not inspecting Limerick beyond that specific incident and deemed it of low significance because it did not have the potential to lead to a more significant safety concern and there was follow-up in the corrective actions program). We are clarifying this because the title of this report led us to believe that there was, perhaps, a huge investigation, but it was a single low-level one).

Publicly available archived volumes pertaining to the Limerick Nuclear Plant pre-licensing phase as well as licensing: in the Pottstown Public Library Exelon's Evacuation Time Estimate required by the NRC to re-license Limerick, issued Dec. 2012 NRC's Environmental Impact Statement, issued March 11, 2012 NRC's Draft Environmental Impact Statement, issued April 2013 Internet downloads of information from NRC and Exelon sites Examples of safety issues relevant to the environmental impacts of Limerick

12 LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT AND NOTICE OF VIOLATION (JULY 1 - SEPTEMBER 30, 2012)

SUMMARY

In this inspection NRC cites violations of NRC regulations that relate to safety and compliance noted during its inspection: July 1, 2012 to Sept. 30, 2012 The inspection resulted in operability determinations and functionality assessments of Units 1 & 2, problem resolution, event follow-up, and Notices of Enforcement Discretion" Findings were discussed with T. Dougherty, Site Vice Pres. and some staff, Oct.12, '12 Units 1 & 2 had condensation issues (see JULY 1 reference)

Exelon has shown pervasive lack of adequate measures to preserve safety and to be responsive to NRC (see June 2 51h, July 11 1h, July 1 8 1h)

Control rods needed alignment in Units 1 & 2 in September.

NOTE: These events were covered in this report, but occurred outside the dates assigned to it.

MAY 2: Unit 1: alarm event reported by Exelon: Spurious trip of reactor enclosure ventilation system

" The cause could not be determined Because the restoration of pressure was completed without consequence, the Licensee Event Report (LER) is closed.

JUNE 25: Unit 2: VIOLATION: for failure of simulated LOCA (Loss of Coolant Accident) event During a test, the 'B' RHR minimum flow valve failed to open following a simulated LOCA signal, the test was repeated, with the same results The condition had existed from Nov. 30, 201 luntil condition was corrected on June 27, 2012 JULY 1: Units 1 & 2 were at 100% power when inspection started

• However, both Units had their power periodically reduced during hot weather due to condensation issues 11: Unit 1: UNPLANNED SCRAM resulting in VIOLATION:

" Failure to follow an alarm response procedure following the receipt of a main control room alarm.

" Operators failed to reduce power within15 minutes, and delayed reducing power for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 49 minutes.

Exelon failed to respond to NRC within a reasonable time after NRC required a response, as Exelon Management was reminded to do in a mtg. on August 22, 2012.

" Circumferential fatique cracks were observed along the weld toe due to reverse bending and indicated the line was subiect to vibration (the issue is CLOSED)

ACE concern: Exelon has established a pattern of delaying notification of NRC when accidents happen (to protect Exelon while it endangers public health and safety). But THIS delay in responding to NRC is blatantly and dangerously lopsided.

12: Unit 1: Main turbine problem.

Power was reduced to 22% to remove main turbine from service to repair.

14: Unit 1: With main turbine repaired, Unit 1 was returned to 100% power.

18: Unit 1: UNPLANNED SCRAM & EXPLOSION: Exelon delays responding to NRC resulting in serious violations:

• Inadequate preventive maintenance (PM) resulted in a scram of Unit 1

" An electrical transient flashover (translation: explosion) knocked out the transformer. Recirculation pumps stopped. Loss of water caused main turbine runback. Shutdown was achieved by an unplanned manual scram

" Repairs to transformer were made

" This event could have upset plant stability and challenged critical safety functions during shutdown as well as power operations ACE concern: Is this industry-speak for "it could have led to a melt down?"

The performance deficiency occurred more than 3 years ago, and has cross cutting effects. Ineffective PM implementation continues to exist within Limerick's PM program and is indicative of present performance ACE concern: Is this industry-speak for "a pattern of negligence or carelessness exists at Limerick?)

• As a result of the July 18th event and violation, NRC required Limerick to reinstitute the clean and inspect preventive maintenance (PM) on all load center transformers at an increased frequency of 8 years vs. 20 years (pg. 56-B).Also see expanded explanation, pgs.86-87 & 88-89)

13 22: Following repairs to the transformer, Unit 1 was started up again.(pg. 59-E) th 24: Unit 1 was up to 100% on the 24 27: Unit 2: UNPLANNED SCRAM to:

" replace the leaking "G" safetylrelief valve

" repair a main generator hydrogen leak

• ACE asks why July 1 8 th scram didn't trigger increased NRC oversight of Limerick, because it was the 3rd scram in 7000 hrs. 3 unplanned scrams in 7000 hrs., per Neil Sheehan per Evan Brandt, Mercury, 4/19/12). See June 3 0 th entry below.

29: Unit 2 was started up again 30: NRC noted "No Findings" of "Unplanned Scrams per 7000 Critical Hours" from July 1, 2011 to June 30, 2012 and listed "No findings were identified."

" NRC reviewed Exelon's submittals of Unplanned Scrams with Complications from July 1, 2011 to June 30, 2012 and listed "No findings were identified" 31: Unit 2 was returned to 100% power AUGUST 31: Unit 1, Planned shutdown and maintenance Inspecting for turbine blade cracks & replacing recirculation pump seals.

SEPTEMBER 2: Unit 2: operators reduced power to about 92% to do the following to facilitate fuel channel distortion testinq

" to facilitate control rod pattern adiustment (Unit 2) to perform main steam isolation valve testing Returned to 100% power the same day, and remained at or near 100% for the rest of the inspection 5: Unit 1 reactor started up, again.

7: Unit 1 back to 100% power 9: Unit 1 Powered down to 80% to facilitate Unit 1 control rod pattern adiustment, powered up to 100% the same day and unit 1 remained at or near 100% for remainder of inspection period ACE asks if Limerick's condensation issues are BWR condensation issues, because it is our understanding that they might have serious impacts on the integrity of the BWRs.

Above is a sample of just one small inspection period. But it illustrates the pervasive problems that Limerick has experienced during its re-licensing period, which are problems that have existed for 28 years, and they are indicative of the problems to come, if Limerick is re-licensed.

It's hard for us to believe that the NRC is considering re-licensing Limerick for twenty years beyond its current licensed period, which does not end for a decade. We believe that the NRC's approval of Exelon's License Renewal Application for Limerick would threaten public health, safety, and the environment in unprecedented ways, and should not be granted.

It is hard to understand how ANY impact of Limerick nuclear operations would not be weighed and evaluated carefully because every aspect of Limerick operations has an environmental impact, whether or not the NRC acknowledges it.

The NRC was given the authority and the mission to protect public health, safety, and the environment. But NRC has chosen instead, to try to rescue PECO/Exelon from the ill-conceived, poorly planned and ruinous schemes to profit from Limerick nuclear energy despite Limerick's poorly situated site, substandard

14 construction, and two defective reactors on a small river that NRC knew couldn't sustain the insatiable water needs of Limericks everyday operations.

The NRC still, however has a choice. We beg you to come to your senses and realize what an injustice this entire charade is. Limerick's environmental impacts are enormous, and every accident weakens the plant as well as the public health, safety, and the environment.

We beg the NRC to reconsider the environmental impacts of its decision to re-license Limerick, especially based on the MOV issue noted on the next page, which contains a chart highlighting serious Limerick violations during the year Exelon submitted Limerick's License Renewal Application, 2011.

-xeion suomittea its appiication Tor LUb License Kenewai on june 'z, zui i, aner only zo years into its original 4u-year iicenseo perioo.

nis cnarr shows some violations were documented that same year. (from "NRC Findings for CY 2011 at Limerick Generating Station")

DATE PERFORMANCE DEFICIENCY, 2011 CAUSE OF DEFICIENCY 3/31/11 1event:

NON-COMPLIANCE & significant deficiency WEAKNESS IN ABILITY TO two EVALUATE issues Failure-to-Address Repeated "Technical Specification" (TS) Response-Time Test Failures CONDITIONS AND THEIR EXTENT (IS THIS HUMAN ERROR?)

NON-COMPLIANCE & significant deficiency The instrument panel that controls Unit shutdown did not operate for longer than "TS" allows 6/30/11 1 event:

NON-COMPLIANCE & significant deficiency "IMPROVEMENT NEEDED three Failure to position Recirculation Isolation (RICI) Valves according to clearance IN PREVENTION OF issues (Question: is this a way of saying that two feedwater valves got stuck, so water couldn't be HUMAN ERROR" released to cool the core? Could meltdown occur if the valves had stayed stuck?)

SIGNFICANT DEFICIENCY Failure to identify adverse trend regarding out of calibration instrumentation Weakness in "Corrective-Action (Question: is this a way of saying that no one noticed that the instrument panel wasn't Performance Program" working until shutdown didn't occur?)

(IS THIS HUMAN ERROR?)

NON-COMPLIANCE & significant deficiency Inadequate inspection procedure for High Pressure Coolant Injection Turbine 8/15/11 NON-COMPLIANCE & significant deficiency "LGS IMPEDED THE NRC REGULATORY PROCESS BY CHANGING THE EMERGENCY ACTION LEVEL BASIS WITHOUT NRC APPROVAL" (Wording: NRC Annual assessment Letter to Exelon re: Insp. Rpt., 3/3/11 - 12/31/11) 9/30/11 1 event, NON-COMPLIANCE & significant deficiency three UNTIMELY DECLARATION OF NOTIFICATION OF UNUSUAL EVENT issues FOLLOWING AN EARTHQUAKE (VA earthquake occurred August 23, 2011)

NON-COMPLIANCE & significant deficiency RECATOR SCRAM caused by use of test equipment Failure in decision-making and in SIGNFICANT DEFICIENCY ability to use a systematic process to ensure that safety is Failure to provide adequate restoration instructions for Turbine Control Valve on-line maintenance maintained (IS THIS HUMAN ERROR?)

11/4/11 NON-COMPLIANCE & significant deficiency Weakness in ability to evaluate conditions and their extent Failure to recover from a station blackout due to unavailability of AC backup (IS THIS HUMAN ERROR?)

12/8/11 VIOLATION OF LEGALLY BINDING REQUIREMENT WEAKNESS IN FAILURE OF FEEDWATER MOTOR OPERATED VALVE (MOV)

MAINTAINING LONG-Resulting in loss of Reactor Core Isolation Coolant (RCIC) for longer than regulations allow TERM PLANT SAFETY according to Technical Specifications (TS) 12/31/11 Failure to take appropriate NON-COMPLIANCE & significant deficiency corrective actions Inadequate Corrective Actions for a previous NRC finding for Programmatic Deficiencies in the (IS THIS HUMAN ERROR?)

Preventive Maintenance Program