ML14051A063
| ML14051A063 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/20/2014 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Cuthbert L Alliance For A Clean Environment |
| BOWER, FL | |
| References | |
| EDATS I-2014-0033 | |
| Download: ML14051A063 (4) | |
Text
From:
Bower, Fred Sent:
Thursday, February 20, 2014 7:04 AM To:
aceactivists@comcast.net Cc:
Evan Brandt; Thompson, Margaret; Pinkham, Laurie; Scott, Michael; Benner, Eric; DiPaolo, Eugene; Ayala, Juan; Montgomery, Richard; Ennis, Rick; Screnci, Diane; Sheehan, Neil; Tifft, Doug; McNamara, Nancy; Klukan, Brett; Barber, Scott; Nimitz, Ronald; Noggle, James
Subject:
RE: SMOKE VISIBLE from a 3RD LIMERICK SOURCE - AGAIN (EDATS Region I-2014-0033)
Dear Dr. Cuthbert (ACE):
I am writing in response to your email dated January 25, 2014, in which you reiterated concerns about a third plume that was visible from Route 422 at various dates in December 2013. We had previously responded to your questions on December 19, 2013 (ML13353A581). Also, in this most recent email you reiterated a number of questions and asked a number of additional questions related to Exelons use of their onsite auxiliary boilers.
To be clear, the NRC does not regulate or restrict Exelons use of their auxiliary boilers.
Limerick may startup, operate, and shutdown these boilers as needed for plant heating and operation. Thus, you and your constituents may continue to see additional plumes of steam or exhaust throughout this winter and into the future. We have confirmed that Exelon does not burn radioactively contaminated fuel oil in their auxiliary boilers and this has been communicated to you on numerous occasions in the past.
Your questions regarding specific testing and the air quality permits for these auxiliary boilers are best answered by the state of Pennsylvania who regulates these activities. Specifically, you may contact the Pennsylvania Department of Environmental Protection, Bureau of Air Quality at ra-epair@pa.gov. The PADEP confirmed that the 2013 Annual Air Emissions Testing for these boilers took place on December 3, 4, and 5, 2013.
Thank you for your email, Fred Bower Chief l Projects Branch 4 l Division of Reactor Projects l Region I l U.S. NRC 2100 Renaissance Boulevard, STE 100, King of Prussia, PA 19406 l : (610) 337-5200 l BB: (610) 731-1920 l
- Fred.Bower@nrc.gov From: aceactivists@comcast.net [1]
Sent: Monday, January 27, 2014 9:39 AM To: Bower, Fred Cc: Evan Brandt
Subject:
SMOKE VISIBLE from a 3RD LIMERICK SOURCE - AGAIN January 25, 2014
To: Fred Bower, NRC Region 1 Projects Manager From: Dr. Lewis Cuthbert, ACE President RE: Smoke visible from a 3rd source - AGAIN Mr. Bower, ACE contacted you December 4, 2013 about a 3rd plume at Limerick, reported to ACE by local residents.
Your 12-19-13, e-mail response admitted NRC's onsite inspector noticed a large steam plume 12-5-13, coming from Limerick's auxiliary boiler on the east side of the reactor building.
ACE Question:
Is that "Boiler A", as defined in Limerick's Title V air permit?
You claimed the 3rd plume at Limerick was due to a preplanned test to determine the emissions and opacity of the boiler exhaust.
ACE Questions:
- 1. The 1st resident sighting and our reporting was 12-4-13. You said the onsite NRC inspector noticed a large steam plume 12-5-13, while investigating our report. How long is a preplanned burn conducted?
- 2. If the 3rd plume 12-5-13 was a preplanned test on boiler exhaust, how do you explain 3rd plume sightings by residents on 2 subsequent dates after the plume sighting from the "preplanned test".
12-23-13 1-7-14
- 3. Have NRC inspectors noticed, investigated, and reported on 3rd plume incidents on any dates after 12-5-13?
If so, ACE is requesting a copy of any and all NRC official reports on all 3rd plume detections at Limerick Nuclear Plant, by residents and inspectors.
If not, there should be a well documented NRC investigation with full disclosure to the public, on any and all 3rd plume incidents and findings by NRC and/or residents from 12-4-13 to date or even before 12-4-13.
You said the test was performed to verify that the boilers met state regulations.
ACE Questions:
- What exact regulations were tested?
- Did testing include for compliance with air pollution limits? If so, for which pollutants? If not, why not?
- Did Exelon control both the testing protocol and reporting?
- What do you mean when saying, "our inspector confirmed this condition"?
What Condition? How was it confirmed? What was the name of the NRC Inspector?
- You said a PA state inspector observed. What was his/her name and title? How is it possible to observe content of emissions?
You said Limerick is no longer allowed to incinerate Low-Level Rad-Waste as of 2011. You said the authority for Exelon to use radioactively contaminated fuel oil in a Limerick boiler has been removed and in effect since 2011.
ACE Concerns:
- 1. We are concerned that LLRW is still being incinerated in a Limerick boiler, undetected by NRC.
- 2. This incident and other information obtained by ACE suggests to us that NRC's policies and oversight are too lax to know whether Exelon is still incinerating LLRW in its boiler or not, regardless of Exelon's claim to have stopped.
- 3. NRC has no idea how much (volume) LLRW is being produced by Limerick each month or year, a fact confirmed by NRC responses to ACE 3-20-13 and 3-21-13. NRC never tracked Limerick's LLRW volume. 3-21-13 an NRC official, Scott Barber, told ACE that tracking volume is not important.
- 4. Because NRC doesn't know the actual volume of LLRW produced at Limerick, there is no accurate accounting, to know whether all Limerick's LLRW is shipped off site or if some of it is incinerated.
We believe Exelon could still be incinerating some of Limerick's LLRW in its boiler, even if Exelon said they would no longer do that in 2011. Some reasons:
- Repeated 3rd plume sightings and reporting by residents
- NRC's failure to report subsequent 3rd plume incidents to ACE, after we expressed concern.
- NRC's failure to account for Limerick's volume of LLRW.
- The Limerick site has run out of room to store LLRW.
- It is costly to transport it off site.
- Even though Limerick's LLRW was permitted to go to Peach Bottom, records show it never went there. In addition, in 2013, an NRC official told us the Peach Bottom agreement was only for a year or two.
- It's all about the costs to Exelon. It is far cheaper to incinerate it at Limerick, than ship it off-site.
- It's all about the dangerous devastating health threats to our region from incineration of radioactive wastes in Limerick's boilers.
Recent 3rd plume sightings, if from incineration of Limerick's LLRW, are one more reason residents' radiation monitoring detected higher levels of radiation in the air around Limerick Nuclear Plant.
ACE URGES YOU TO RESPOND TO EACH OF OUR CONCERNS AND QUESTIONS AS SOON AS POSSIBLE.