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NRC-2018-000096 - Released Set
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	NRC-2018-000096
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The Alliance For A Clean Environment 1189 Foxview Road Pottstown, PA 19465 aceactivists@comcast.net

M a y 5, 2014

NRC Ch a irman Allison M. M a cfarlane U.S. Nuclear Regulatory Commiss ion Mail Stop O-16G 4 Washington, DC 20555 -0001 301 -415-1750 Chairman@nrc.go v

RE: FAILURE TO TAKE ACTION TO PROTECT THE GREATER PHILADELPHIA REGION, RELATED TO UNPRECEDENTED EARTHQUAKE RISKS THAT COULD TRIGGER MULTIPLE MELTDOWNS AT LIMERICK NUCLEAR PLANT.

Chairma n Ma c fa rlan e,

It is difficult for us to believe our 3-31-14 letter and attachments actually reached you. NRC's response to the many unprecedented earthquake risks at Limerick Nuclear Plant were clearly defined and summarized by our members. This should require NRC to take immediate act ion to start to close Limerick to av o id m eltdow n s.

Instead of rece iving a response from you, we received an e-mail response from Rick Ennis, Limerick's project manager on 4-23-14 to the letter and attachments we sent you. Our members contacted YQb!

because as stated, since Fu kush ima in 2011, NR C officials for Limerick have repeatedly dismissed our concerns and even tied about serious earthquake risks previously identified and documented by ACE.

We reject Mr. Ennis's sug g estion to use NRC'S p etition pro c ess as a solution.

A preponderance o f evidence suggests that filing a petition will NOT lead to immediate closure of Limerick Nuc lea r Plant, wh ich is what is urgently needed to prevent meltdowns triggered by an earthquake.

NRC's p etition p rocess will NOT work to p rotect the health, safety, or financial Interests of the man y millions of p eople in the Greater Philadelphia Region who would suffer catastro p hic im pacts from Fukushima-like meltdowns at Limerick:

At stake are the health, livelihoods, and well being for gene rations.

The ec ono mic costs coul d be devastating not only to over 8 million people who live within 50 miles of Limerick, but to all taxpayers in our nation.

Evidence s hows that NRC's p etition p ro c ess Is a time consumin g and rigg ed sys tem that enables NRC to dismiss serious concerns and avoid taking p rotective p recautiona ry act ion.

T ime after time, va lid well-defined petitions and legal act ions have b een filed agai n st Limerick Nuclear Plant, only to be denied by NRC.

T he most recent example of NRC's flawed pe tition process is NRC 's March 26, 2014 den ial of the clearly valld petition of Paul Gunter. Beyond Nuclear, requesting the revoking of operating licenses for GE Mark I and II BWR nuclear p lants, including Limerick. His petition was filed on behalf o f public health and safety.

NRC can, and should, use the evidence ACE p rovided to close Limerick Nu clear Plant as soon p ossible, to p rotect the health, safety, and financial interests for millions of peo ple in the Greater Philadelp hia Region.

ACE is co m prised of concerned citizen volun teers w h o care enough to spend countless hours trying to uncover the truth to prov ide full and accu rate disclosure of risks to the public. Yet, we have repeatedly found it is nearly Imposs ible to get NRC to fulfill its mission to protect public safety and the environment.

Our 3-31-14 letter and attachments to you revealed accurate and irrefutable evidence collected through investigations by our members. Newly disclosed earthquake fault fractures that are under Limerick's reactors, fuel poo ls, control room, turbine bu ilding, and rad -waste storage building present unacceptable risks that cannot.be fixed or ignored by NRC.

On 4-24.-14, we received an acknowledgement of the receipt of our letter from Annette Vietti-Cook. She said our letter wa s distributed for appropriate NRC consideration. We have no idea if that means it went to your desk for review.

NRC officials now have ample evidence to take swift, immediate action to avoid Fukushima-like meltdowns that could render the en tire Greater Philadelphia Region uninhabitable for generations. little or nothing has been done to minimize risk of catastrophic meltdowns. This is the 2nd most den sely populated nu clear plant evacuation zone in the U.S. Limerick is just 20 miles from Philadelphia, yet NRC officials have lied in response to residents' concerns about earthquake fa ults near Limerick.

Our earthquake risks are compoun ded by serious deterioration and corrosion docume n ted by NRC staff in Limerick's fuel pools and other systems and stru ctur es.

Exelon, Limerick's owner, is in financial trouble, which is likely to cont ribute to even more neg ligent delays and cutting comers on important repa irs, maintenance, and replacement of Limerick's aging systems to save money.

NRC has already allowed Exelon to use dangerous stall tactics to delay and even avoid ma intenance and repair costs.

The shocking evidence in our letter to you sho u ld be sufficient to trigger NRC action to close Limerick to avoid catastrophic meltdowns at Limerick.

Although we are aware that our letter and attachments are ava ilab le on ADAMS and our information was forwarded to the OIG, that is no substitute for closing Limerick immediately to avoid Fukushima-l ike meltdowns.

We are hopeful you will carefully review the letter and attachments we sent you on March 31, 2014, then take the necessary actions to close Limerick.

Rick Enn is's letter stated that NRC could REVOKE an NRC-issued license. We provided a b ody of irrefutable eviden ce to NRC that must be used to REVOKE Exelon's o perating llcense for Limerick Nu c lear Plant NOW.

THIS UNPRECEDENTED RISK COMMANDS YOUR IMMEDIATE ATTENTION. PLEASE RESPOND PERSONALLY AS SOON AS POSSIBLE!

Thank you,

~~

Dr. Lewis Cuthbert ACE President NRC'S DECISIONS FOR LIMERICK NUCLEAR PLANT ARE JEOPARDIZING OUR FUTURE

THE FOLLOWING INFORMATION PROVIDES COMPELLING EVIDENCE THAT NRC SHOULD REVOKE LIMERICK'S OPERATING LICENSE AND CLOSE LIMERICK NOW TO PROTECT PUBLIC HEALTH, SAFETY, AND FINANCIAL INTERESTS

THE ATTACHED EVIDENCE SHOWS THAT NRC HAS IGNORED LIMERICK NUCLEAR PLANT'S UNPRECEDENTED AND GROWING RISKS FOR CATASTROPHIC MELTDOWNS AND THREATS FOR INCREASED RADIATION-RELATED ILLNESSES.

ACE IS URGING NRC OFFICIALS TO REVIEW THE ATTACHED SUMMARIES AND RECONSIDER NRC DECISIONS FOR LIMERICK NUCLEAR PLANT.

ACE IS ALSO REQUESTING THAT NRC RESPOND IN WRITING TO ALL ISSUES, QUESTIONS, AND CONCERNS IN THE ATTACHED SUMMARIES.

The Alliance For A Clean Environment (ACE)

(May 2014)

For Additional Information: www.acereport.org To Contact ACE : acea~tivists@comcast. net NRC DECISION 1S FOR LIMERICK NUCLEAR PLANT JEOPARDIZE OUR FUTURE

THE LIST BELOW IDENTIFIES DANGEROUS NRC DECISIONS THAT FAIL TO PROTECT PUBLIC HEAL TH, SAFETY, AND FINANCIAL INTERESTS. DETAILS ARE ON THE PAGES THAT FOLLOW.

1. NRC DISMISSED UNPRECEDENTED AND GROWING EARTHQUAKE RISKS AT LIMERICK, INCLUDING EARTHQUAKE FAULT FRACTURES DIRECTLY UNDER LIMERICK'S REACTORS, FUEL POOLS, CONTROL ROOM, TURBINE BUILDING, AND RAD -WAS!E STORAGE BUILDING

2. NRC RECENTLY ALLOWED MORE DANGEROUS HIGH BURN NUCLEAR FUEL USE AT LIMERICK, INCREASING RADIATION RELEASES INTO OUR AIR AND INCREASING RISKS FROM LIMERICK ' S HIGH-LEVEL RADIOACTIVE WASTE STORAGE AND TRANSPORT

3. NRC ALLOWED EXELON TO DELAY RE-COATING LIMERICK'S FUEL POOLS UNTIL 2024, DESPITE THINNING ANO *CORRODiNG UP TO 10 TIMES FASTER THAN ESTIMATED

4. NRC ALLOWED A DANGEROUS DELAY FOR INSTALLING FUEL POOL INSTRUMENTATION,

A POST - FUKUSHIMA NRC RECOMMENDATION TO AVOID FUEL POOL MELTDOWNS

5, NRC IS EXEMPTING LIMERICK FROM FOLLOWING NRC'S RADIOACTIVE WASTE STUDY RESULTS, FAILING TO ACCURATELY EVAULATE LONG-TERM RISKS FROM DANGEROUS MASSIVE HIGH -LEVEL RADIOACTIVE WASTE STORAGE AT LIMERICK

6. NRC ALLOWED EXELON TO DELAY VENT INSTALLATION TO MINIMIZE EXPLOSION RISKS

7. NRC FAILED TO RE UIRE RADIATION FILTERS FOR VENTS TO LIMIT EXPOSURE RISKS

8. NRC IS NOT REQURING INDEFINITE BACK -UP POWER TO PREVENT SIMULTANEOUS LIMERICK MELTDOWNS

9. NRC IS FIGHTING AGAINST UPDATING LIMERICK'S DECADES OLD SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA )

10, NRC REFUSED TO EXPAND EVACUATION AND INGESTION PATHWAY ZONES

11. NRC PARED DOWN EMERGENCY AND EVACUATION PLANNING IN 2012

12. NRC EXEMPTED LIMERICK FROM THE SAFETY TEST REQUIRED FOR RELICENSING

13. NRC ALLOWED EXELON TO WAIT 7 DAYS TO NOTIFY THE PUBLIC ABOUT A RADIATION ACCIDENT, EVEN THOUGH RADIATION CAN BEGIN ESCAPING WITHIN 1/2 HOUR

14. NRC IS FAILING TO TRACK LIMERICK'S LOW-LEVEL RADIOACTIVE WASTE BY WEIGHT AND VOLUME. THEREFORE, EXELON MIGHT BURN SOME OF IT ON SITE TO SAVE MONEY, WITHOUT NRC'S KNOWLEDGE, DRAMATICALLY INCREASING HEALTH THREATS

ACE URGES NRC TO RECONSIDER ITS UNPROTECTIVE DANGEROUS DECISIONS ABOVE AND REVOKE LIMERICK ' S LICENSE, TO PROTECT THE HEAL TH, SAFETY,

AND FINANCIAL INTERESTS OF MILLIONS OF PEOPLE IN THE GREATER PHILADELPHIA REGION.

1. NRC DISMISSED UNPRCEDENTED AND GROWING EARTHQUAKE RISKS AT LIMERICK, INCLUDING FAULT FRACTURES DIRECTLY UNDER LIMERICK'S REACTORS, FUEL POOLS, CONTROL ROOM, TURBINE BUILDING, AND RAD-WASTE STORAGE BUILDING.

NRC offic ials for Limerick ha v e lo n g failed to a c know ledge Limeric k's ex traordinary ea rthq u a ke risks.

Fu ku s h ima wa s justific ation en ou gh for preventive m ea s ur es to b e take n imme dia te ly, ye t a fter three ye ar s NOTHING has b een don e to redu c e risks, d espite th e fa c t tha t Lim erick is co n sidered a " HIGH R ISK" s ite. On e NRC offic ia l afte r the o ther dow n -play ed a nd /or cove red up a b so lutely un acce pta ble risks a t Lim eric k.

2 13 WE LEARNED RISKS ARE FAR WORSE THAN WE REALIZED, NO THANKS TO NRC.

A Se ptemb er 3, 1974 report disc ov e red by A CE m e mb ers in the Po ttsto wn Libra ry, revea ls tha t Limeric k Nuc lea r Pla n t's:

Reactors

Control Room Turbine Building

Rad-Waste Storage Building ALL WERE BUILT DIRECTLY OVER EARTHQUAKE FAULT FRACTURES.

(Lim erick's fu el poo ls w ere n ot listed In the report, presumably b ecause Lim erick's fu el p ools a re abo ve Its GE Ma rk II reac tors, slmflar to those at Fuk ush ima.)

The 1974 repo rt titled; "R eport o n Trea tm en t of Frac ture Zo n es for PECO by Bec hte l Power Co mp a n y",

s h o w s h o w fau lt frac tures under Limeric k w e re prepa red prio r to co n struc tion.

Th is shoc king report in c ludes ph o to gra phs a nd a diag ram to scale showin g:

1. A fault zone fracture after it was filled iri w ith cement (called den tal concrete) In 1973, BEFORE Limerick's Geological Survey was completed in 1974

2. A fault zone fracture directly under Limerick U nit 1 reactor

3. A fault zone fracture filled with cement that sup ports a column for Limerick Unit 2 reactor

4. A fault zone fractu re being filled w ith cement directly u nder the support wall between the control room ar.d turbine building

5. The location of Limerick N uc lear Plant buildings and how they are positioned over the fault zone fractures

6. Spent fuel poo ls are n o t shown in the diagram, since Limerick is a Mark II GE design, with its fuel pools on top of its reactors.

Risks were clear before Limerick was con structed, yet hidden from the public until now.

Limerick's vita l structures were built directly over fault fractures to save PECO costs. In the 1972 Environmen tal Impact Statement for Limerick, the Atomic Energy Comm ission (AEC now NRC) considered alternative sites, which were then eliminated due to industry costs. (See Attachmen t)

Nothing c a n fix this. Limerick Nuclear Plant can ' t sudd e nly be declared safe a s the result of any NRC study or regulation.

NRC must own up to the real dangers and close Limerick immediately, BEFORE there are me ltdowns. In add ition, Limerick's deadly radioactive wastes must be removed from the fuel pools as soon as possib le and placed into hardened on -site casks.

Serious Problems and Conc e rn s Should Not Be Ignored - Major Threats Dramatically Compound and Intensify Pos s ible Damage To Lim e rick's Vital Structur e s Th a t W e re Built Directly Over Earthquake Fault s:

Fou r earthquake faults (one considered ac tive) are within 17 miles of Limerick, in addition to the earthquake fault directly u n der Lim erick's vital infrastructure.

Limerick's decades old reactor containment and fuel pools were b u ilt with substandard cement, increasing earthquake risks for Limerick Nuclear Plant.

limerick's fue l poo ls, located above Limerick's reactors (s.imilar to Fukushima's), a re packed far beyo n d design capacity with some of the most dead ly ma terials on earth.

Limerick's fuel pools w ere co n structed with su.bstanda rd cement, a fact confirmed by 9-22-1 1 Limerick EIS testimony.

Limerick's fuel poo ls a re corroding and thinning at rates up to 1 0 times faster than anticipated, a fact confirmed by NRC staff in letters to Exelon.

Miles of aging and deteriorating pipes and cables buried under Limerick, vital to supply ing energy and water to prevent a meltdown can be disrupted and damaged from an ear thquake, ye t they cannot be inspected. Limerick relies on monitors and gauge$ that are often inoperable.

An earthquake at Limerick could trigger multiple meltdowns In fuel pools, unleashing far more radioactivity than Hiroshima, Nagasaki, or even Chernobyl, because of Limerick's enormous on-site accumulation of spen t fuel.

The 8-23-11 earthquake In V irginia jolted Limerick Nuclear Plant, show ing that Limerick can be impacted by an unpredicted earthquake.

Earthquakes are becoming stronger and more frequent.

Earthquake risks have increased drama tically due to massive trackin g in PA and nearby states. USGS states that fracklng can trigger earthquakes. Since 2007, well over 4,200 natura l gas wells were approved in PA.

In 2012, the local newspaper repo rted that:

Some Limerick systems, structures, and components could be unreliable in an earthquake Limerick's fire prevention seals may not tolerate a "seism ic event".

Given recent earthquake events and discoveries it is clea r that, in reality, Limerick's earthquake risks go far beyo n d Limerick's "so-called" earthquake design bas is.

Limerick is considered a "High Risk" nuclear plant for earthquakes, and reported to be 3rd on the nation 's earthquake risk list.

The 8-23~11 earthqua 1ke in Vi rginia jolted Limerick Nuclear Plant, including the control room. limeric k's infrastructure was uninspected after the V irginia earthquake, despite the risk.

Limerick's earthquake mon itors were inoperable 8-23-11. Limerick had to contact USGS for verification of the Virginia earthqua ke.

Limerick's seismic monitors had remained inoperab le for over a year (documen ted in NRC records).

If the Virginia earthquake jolted Limerick Nuclear Plant, it can be assumed that a similar earthquake could originate in one of the many n earby faults and co u ld be devas tating.

Recently, two small earthquakes originated in Philadelphia, only 21 miles away.

The body of evidence above proves earthquake risks at Limerick Nuclear Plant are both extraordinary and unacceptable, clearly supporting the need to close Limerick now and remove high-level radioactive wastes from Limerick's fuel pools as soon as possible, placing them Into safer hardened cask storage.

NRC FIRST DELAYED AN EARTHQUAKE RISK ANALYSIS UNTIL 2017 1 THEN REFUSED TO INDEPENDENTLY RE-EVALUATE LIMERICK'S EARTHQUAKE RISKS. WHY?

CLEARLY, IF EARTHQUAKE RISKS WERE ACCURATELY INDEPENDENTLY EVALUATED AND PUBLIC INTERESTS WERE VALUED, LIMERICK WOULD HAVE TO CLOSE. IT'S TOO RISKY TO KEEP LIMERICK OPERATING.

FOR DETA ILS: S EE ACE LETTER A ND ATTACHM ENTS TO NRC CHAIR MA N MACFA RLANE

2. NRC ALLOWED LIMERICK TO USE HIGH BURN NUCLEAR FUEL,

INCREASING RADIATION RELEASES INTO OUR AIR AND INCREASING RISKS FROM LIMERICK'S HIGH-LEVEL RADIOACTIVE WASTE STORAGE

It appears Exe lon started us ing this fuel at Limerick before Limerick's license was amended to do that, without any public process to inform the public and allow public commen t. It appears NRC recently started a process to revise Limerick's permit to allow use of this fuel - AFTER THE FACT.

WITH NO PROOF USE OF HIGH-BURN FUEL IS SAFE, NRC APPROVED ITS USE.

NRC NEVER PROVED HIGH BURNUP FUEL CAN BE SAFELY STORED OR TRANSPORTED, BUT APPROVED ITS USE ANYWAY.

NRC IS IGNORING INCREASED RADIOACTIVE THREATS TO PUBLIC HEALTH FROM INCREASED RADIATION RELEASES DUE TO USE OF HIGH BURNUP NUCLEAR FUEL.

NRC 'S F re d B o w e r R efu sed T o An swe r Th e Follo wing Qu estio n s W e First A sked S eptem b e r, 2013:

1. When did Limerick Nuclear Plant start using high burnup fuel?

2. When was Limerick's license amended to start using this fuel?

3. Does NRC plan to continue allowing term storage and transport? Limerick to use this fuel, despite serious concerns about inc reased risks of long-

NRC (Fred Bower) responses below were evasive and illogical, making unsubstantiated cla ims and m ischa racterizin g NRC ' s neg ligen t app roval process for high burnup fuel. Following each comment we show w hy.

related 'We (NRC)... information." cannot provide specific fuel loading information at the Limerick Nuclear Power station as it is Security

This can't be true when U.S. DOE published a copy of the detailed inven tory of all spent power reactor fuel in the U.S., includ ing Limerick (3-31-11).

"It is information that is not normally collected by the NRC".

It is beyond negligent for NRC to fail to track high-burn up fuel.

"We (NRC)... ensure it does not pose an undue risk to public health and safety*.

In reality, NRC clid NOTHING to prevent undue risk to public health and safety fro'm use of high burnup fuel.

NRC APPROVED HIGH BURNUP FUEL USE W HEN IT CAN CAUSE:

2 to 3 Times Higher Radioactive Fission Gas Releases. logically releas ing more radiation Significant Increased Radioactivity and Decay Heat in Limerick's Spent Fuels

'We (NRG) believe that ou r oversight of the industry's use of high bumup fuel provides a reasonable assurance of safety". NRC ha s n o v a lid eviden ce to v erify this a bs urd c la im.

NRC's "reasonable assurance of sa fety" Is based on unsubstantiated c laims b y the nuc lear industry.

NRC jeopardized public safety by allowing the nuclear industry to save money by using more dangerous "high burn up" fu el. NRC based this decision on financi~lly self-serving, unsubstantiated 9laims by the nu c lear industry.

With NO PROOF long-term storage and transport of high burnup fuel are safe, and independent evidence suggesting it isn't safe, NRC approved use of high burn up fuel and continues to a llow its use.

safety Is baseless. DOE's "Demonst ra tion Proiect" on high-burn fue l is just starting, proving NRC's reasonable assurance of

The U.S. DOE and the Electric Power Energy Institute demonstration project to figure ou t actual safety Implications of "high burnup" spent fuel cask storage and transport will not be completed for another 4 years.

DOE would not beg in a costly five-year "Demonstration" project, w ith 2017 as a target date to load the fuel into the demonstration cask if it was safe. This "demonstration project", reported 11 13, is costly to the public, who will largely foot the $15.8 million dollar b ill. The nu c lear industry, which financially benefits from the use of high burnup fuel, is o nly requ i(ed to pay 20%.

"High bumup fuel has been safely stored for many years". It's only been used since the 1990s. It was not stqred for enough years to know It Is safe. In the few years it has be en stored, evidence a lready shows significant increased radioactivity and decay heat, with increased corrosion, thinning, and brittleness of fuel cladding.

"There are many storage system designs that have been approved for the Jong-term storage of high burnup fuel. A number of transportation packages have also been approved lo transport high bumup fuel. " Why was such negligent approval given? There is limited data to show cladding of spent fuel with burnups will remain undamaged, even during licensing periods. NRC has NO PROOF long-term storage and transport are safe.

HIGH - BURN NUCLEAR FUEL U _SE AT LIMERICK NUCLEAR PLANT IS TOO RISKY. FACTS FROM INDEPE.NDENT SOURCES ARE CLEAR.

W ith high er bu rn up, n u c lea r fu el ro ds u ndergo severa l risky ch a nges that inc lude :

Increasing oxidation, cor rosion, and deterioration of the fuel cladd ing.

*Oxidation reduces cladding thickness, while hydrogen {H3) absorption of the cladding to form a hydrogen-based rust of the*zlrconlum metal from the gas pressure inside the rod can cause the cladding to become brittle and fail;

Higher release. internal Pressure rod gas pressure increases are typically between the two to three pellets and the times greateinner wall r. of the cladding le acing to higher fission gas

Elongation or thinning of the cladding from Increased internal fission gas pressure; Structural damage and fa ilure of the cladding caused by hoop (c ircum ferential) stress;

Increased. debris in the reactor vessel, damag ing and rupturing fuel rods;

Cladding viear and failure from prolonged rubbing of fuel rods aga inst grids that ho ld them in the assembly as the reac tor operates (grid to rod fretting).

A significan t increase in radioactivity and decay hea t in the spent fuel.

A potentially larger number of damaged spent fuel assemb lies stored in pools.

Upgraded pool storage w ith respect to hea t remova l and pool c lean ing.

Requ iring as much as 150 years of surface storage before final disposal.

The National Academy of Engineering of the National Academy of Scien ces raised concerns about the viab ility o f high-burnup fuel by noting,

established "The technical... " basis for the spen t fuel currently b eing discharged (h igh utilization, burnup fuels) is not well

"Spen t fuel that may have degraded after extended storage may present riew obsta c les to safe transport."

The New York Times Reported: "NRC has not yet granted a license for the transport of the higher burn up fuels discharged from reactors."

Fuel assemb lies with enough uranium were approved by NRC to run for 6 years instead of the standar d 3 years.

"Some of the younger fuel shows signs of degrading with age."

"The "hicrack ing." gh burn-up fuel" spent longer in the ha rsh environment of a reactor, and now shows signs of corros ion and

ACE URGES NRC TO IMMEDIATELY STOP EXELON FROM USING HIGH BURNUP FUEL AT LIMERICK NUCLEAR POWER PLANT.

CITIZEN RADIATION MONITORING RECENTLY FOUND RADIATION SPIKES.

WE BELIEVE LIMERICK"S USE OF HIGH-BURN FUEL IS A MAJOR FACTOR.

NRC HAS NO PROOF OTHERWISE. NRC DOES NO MONITORING.

LIMERICK'S FUEL POOLS ARE ALREADY TOO RISKY.

IT 15 NEGLIGENT TO KEEP ADDING HIGH BURN FUEL THAT NEEDS TO BE COOLED IN FUEL POOLS 20 YEARS INSTEAD OF 5.

DAMAGED CLADDING OF HIGH-BURN FUEL COULD LEAD TO A FUEL POOL CATASTROPHE.

3. NRC ALLOWED EXELON TO DELAY RE -COATING LIMERICK'S HIGH - LEVEL RADIOACTIVE WASTE FUEL POOLS, IGNORING THE NRC STAFF RECOMMENDATION TO RECOAT POOLS IMMEDIATELY

LIMERICK ' S FUEL POOLS ARE EXTREMELY DANGEROUS, YET NRC 15 FAILING TO REQUIRE EXELON T01 TA~E IMMEDIATE ACTIONS TO:

1) RECOAT LIMERICK'S FUEL POOLS IMMEDIATELY

2) REQUIRE REMOVAL TO HARDENED ON-SITE STORAGE FOR ALL l:IMERICK ' S RADIOACTIVE FUEL RODS STORED IN FUEL POOLS AS SOON AS SAFELY POSSIBLE

CORROSION AND THINNING IN LIMERICK'S."SPENT" FUEL POOLS INCREASES RISKS FOR LOSS OF WATER AND MELTDOWNS, ESPECIALLY COMBINED WITH THE OTHER UNFIXABLE DANGEROUS CONSTRUCTION AND DESIGN FLAWS, YET NRC ALLOWED EXELON TO DELAY RECOATING LIMERICK'S FUEL POOLS FOR A DECADE, UNTIL 2024.

NRC staff said ~imerick's fu el poo ls shou ld be recoa ted immed iately due to corros ion and thinning at rates up to 10 times faster than anticipated.

INSTEAD, NRC caved in to Exelon and made the inexplicable negligent decision to allow Exe lon to wait 10 more years (until Limerick's first license expires in 2024) to recoat Limerick's fuel pools.

HOW IS IT EVEN POSSIBLE TO RECOAT LIMERICK'S CORRODING THINNING FUEL POOLS?

Dead ly radioactive wastes stored and overpacked in Limerick's fuel pools mus t constantly be coo led with water to avoid meltdowns - for a m inimum o f 5 y ea rs before remo val from poo ls. The high burn fuel now used at Limerick m us t be stored in pools for 20 years, according to independent experts.

NRC REPEATEDLY FAILED TO ANSWER OUR UESTIONS BELOW:

1) Wouldn't Limer ic k's fu el pools have to be emptied to recoat them?

2) Where would the massive amounts of highly rad ioacti ve water from emptying Limerick's fuel pools go?

3) Where would huge num b ers o f Limerick's fue l rods be stored for co o ling.while a pool is emptied and recoated?

4) Wo uldn't it be too dang 1erous for workers to recoat fuel po ols?

ACE URGES NRC TO DEMAND THAT EXELON RECOAT LIMERICK'S FUEL POOLS IMMEDIATELY TO AVOID A RADIOACTIVE CATAST 1ROPHE!

A. IF RE COATING CAN'T BE DONE SAFELY OR IF EXELON REF USES, NR C SHOULD DENY RELI CE NSING.

B. THIS IS JUST ONE MORE VALID REASON TO REVOKE LIMERICK'S OPERATING PERMIT I MM EDIATELY. LIMERICK CAN'T KEEP MAKI NG DEADLY WASTE FOR WHICH THERE IS NO SAFE SOLUTION.

WHY LIMERICK'S FUEL POOLS PRESENT CATASTROPHIC RISKS:

CORROSION AND THINNING UP TO 10 TIMES FASTER THAN ESTIMATED SUBSTANDARD CEMENT USED DURING CONSTRUCTION FUEL POOLS ARE BUil TON TOP OF REACTORS, DIRECTLY OVER FAULT FRACTURES POOLS ARE OVERLOADED BEYOND DESIGN CAPACITY FUEL POOLS ARE VULNERABLE TO MELTDOWNS THROUGH LOSS OF WATER THAT COULD BE CAUSED BY TERRORIST ATTACKS, EARTHQUAKES, HUMAN ERROR, OR EQUIPMENT F.AILURE

QUESTIONS ABOUT QUANTITY OF DEADLY HIGH -LEVEL RADIOACTIVE WASTES AT LIMERICK GO UNANSWERED:

1) Why is there far more in Limerick's fuel pools than o lder U.S. nucl ear sites like TMI and Oyster Creek?

Why is there more than double the amount of rods in Limerick's 2 pools compared to 4 at Fukushima?

2) Did Limerick take spent fuel rods from other sites? Did Limerick get rods from TMI after its accident?

3) Did Limerick's opera ting permit allow that when rods were accepted at Limerick from other sites?

Limerick's operating permit wasn't amended un til 12-19-11, to allow Limerick to take spent fuel rods from other sites, yet Shorham's came to Limerick decades ago.

4) Did NRC allow Limerick to remove fuel rods from poo ls soo n er than the 5 years required for safety?

NRC told us three different things. 1 Year, 3 Years, 5 years An Exelon employee sa id 1 year old rods we re being wrapped with older rods for removal.

If NRC allowed early remova l, that is gross negligence. If NRC didn't catch Exelon remov ing rods early, it is gross incompetence.

4. NRC ALLOWED THE DELAY OF FUEL POOL INS.TRUMENTATION TO AVOID FUEL POOL MELTDOWNS-A POST - FUKUSHIMA RECOMMENDATION

3 YEARS AFTER FUKUSHIMA AND 2 YEARS AFTER NRC"S ORDER, LIMERICK'S FUEL POOLS ARE STILL NOT EQUIPPED WITH RELIABLE SPENT FUEL POOL INSTRUMENTATION.

This Is Vital To Accurately Detect Loss of Water In Fuel Pools Which Can Lead To Meltdowns.

INEXPLICABLY, 3-26-14, NRC ANNOUNCED A VOLUNTARY AUDIT PROCESS ", NOT IMMEDIATE INSTALLATION OF THIS VITAL SAFETY UPGRADE

NRC 's 3-12-12 "Issuance of Order to Modify Licenses with Regard to Reliab le Sp ent Fuel Pool Ins trumentation", This order "requires " Limerick to ha ve a reliable means of remotely monitorin g wide range Spen t Fuel Po o l levels to remotely monitor water in spent fuel poo ls to prevent meltdowns.

3-26-1 4 - NRC announced indu stry driven tactics to delay and even avoid costs:

Audit Proc ess Partici ation is VOLUNTARY.

On-site audits will only be cond uct ed " If necessary"

If Exelon does not want to participate In the Audit Process, NRC will reques t Information needed by an "Alternative Mechanism".

Other me thods th at deviate from the Guidance may be found acceptable. In other words, anythin g goes.

NO COMPLIANCE DEADLINE Was Announced.

WHAT WILL HAPPEN FIRST, MELTDOWNS FROM LOW LEVELS OF FUEL POOL WATER GOING UNDETECTED, OR FUEL POOL INSTRUMENTATION INSTALLATION?

NRC MUST REQUIRE IMMEDIATE INSTALLATION OF LIMERICK'S FUEL POOL INSTRUMENTATION TO REMOTELY MONITOR WATER LEVELS TO AVOID THE CONSE UENCES OF THE EXTREME RISKS A S OCIATED WITH LIMERICK'S FU EL POOLS, INCLUDING:

Thinning and Corroding At Rates Up To 10 Times Faster Than Estimated Substandard Cem ent Was Used To Construct Limerick's Fu el Pools Fuel Poo l Construction On Top Of Reactors, On Top of Earthquake Fault Fractures, In An Active Earthquake Zone Vu lnerability To Terrorists' Planes and Missiles Poo ls Are Overloaded, Far Beyond Design Capacity With Enormous Potential For An Unthinkab le Hea lth and Economic Disaster Limerick's 2 fu~I pools hold mor e than 2 1/2 times the amount of fuel ro d assemblies (6,200) than fo u r fue l pools at Fukushima (2,400) and far more than other older U.S. nuclear plants like TMI and Oyster Creek. NRC can't or won't tell ACE why.

With loss of fuel pool coo ling water, Limerick's fue l rod s can heat up, self-ignite, a nd burn In an unstoppable fire. There is no endless source of water. But fuel pool meltdowns coul d jeopardize water supp lies across six count ies. Ma y, 2013, Exe lon wa s permitted to take unllmlted amounts of public water from across six counties to dea l with m eltdowns.

A 2003 study shows a fire in 1 spent fuel pool cou ld release a rad ioactive plum e that cou ld contaminate 6 to 70 times more land than Chernobyl and render about 95,000 square kilometers of land uni n hab itable. *

A spen t fuel poo l disaster could cause fata l rad iation -In du ced cancer In thou sands.of people as far as 500 miles from Limerick. A 2004 study conc luded that 44,000-near-term deaths* could occur from acute radiation poisoning. People could die as far as 60 miles downwind (Philade lphia is Just 20 miles downwind).

5. NRC INEXPLICABLY PLANS TO EXEMPT LIMERICK FROM NRC ' S COURT ORDERED RADIOACTIVE WASTE STUDY RESULTS (expected in the fall of 2014).

GIVEN THE UNPRECEDENTED RISKS, FOR NRC TO EXEMPT LIMERICK AND RELICENSE THIS DANGEROUS FACILITY WITHOUT CONSIDERING ACTUAL RADIOACTIVE WASTE STORAGE R I SKS AT LIMERICK IS REGULATORY MALPRACTICE.

NRC'S SHAMEFUL NUCLEAR WASTE CON-GAME ALLOWS HIGH-LEVEL RADIOACTIVE STORAGE RISKS AT LIMERICK T O GROW A federal court threw out the Nuclear Regulatory Commission's "waste confidence" rule, since it wa s predicated on the base less an d false assumption that a permanent repository for high-level radioact ive waste would be operational relatively soon. The court also found that NRC had no technical -basis to simply assume temporary stora ge methods (fuel pools and dry casks) are adequate for indefinite-- potentially permanent--storage of this lethal material. NRC still asserts that no matter how high-level nuclea r waste is stored--in fuel pools o r in dry casks, it will be safe. Why? Because NRC claims the probability of an acciden t is low..

IT IS ABSURD FOR NRC TO CLAIM THE PROBABILITY OF AN ACCIDENT IS LOW AT LIMERICK NUC LE AR PLANT. A BODY OF EVIDENCE, INCLUDING EARTHQUAKE FAUL TS RIGHT UNDER LIMERICK'S FUEL POOLS AND RAD-WASTE BUILDING, PLUS INCREASING RISK OF EARTHQUAK ES HERE, PROVES OTHERWISE.

6. NRC DELAYED THE INSTALLATION OF VENTS TO AVOID RADIOACTIVE EXPLOSIONS -A POST -F UKUSHIMA RECOMMENDATION

NRC a llowed Exelon to DELAY INSTALLATION of HARDENED CONTAINMENT VENTS AT LIMERICK (ordered by NRC Mar c h, 2012), that cou ld prevent h ydrogen explosions if L ime rick rea ctors lose power a nd wat e r a nd start to m e lt d own: Even though Limerick reac tors are similar to tho se at Fukushima that melted down and meltdown risks at Limerick are enormous and growing, NRC is allowing:

4 MORE YEARS for Unit 1

Until 2018 and 3 MORE YEARS for Unit 2

Untll 2017 It ls regulato ry negligence to dela y these cruc ial safeg ua rds for 6 and 7 years after Fukush ima.

NRC ignored extraordinary risks for meltdowns at Limerick and allow ed Exelon to use these stall tactics, based on its absurd base less co nclusion, that a "Fukushima-like accident is unlikely to occur".

7. NO FILTERS FOR VENTS - NRC FAILED TO RE UIRE INSTALLATION OF FILTERS.FOR VENTS TO MINIMIZE DEVASTATING IMPACTS FROM MASSIVE RADIATION RELEASES, IGNORING NRC STAFF'S OWN CONCERNS AND RECOMENDATIONS.

NRC failed to require filters based on the cost to industry, even though NRC staff said filters were an "important sa fety improvement to protect public health",

NO FILTERS FOR VENTS -_ NRC FAILED TO REQUIRE INSTALL.ATION OF FILTERS FOR VENTS TO MINIMIZE DEVASTATING IMPACTS FROM MASSIVE RADIATION RELEASES, Ignoring NRC stafrs concerns and recommendations.

NRC staff said, with~ ut filters, vents would become a "radioactive fire hose into the sky".

NRC staff recommended (11-12) ordering vent filters at 31 nucl ea r units, including Limerick, regardless of cost to the nucl ea r industry, ba sed ~n the potential severe radiation impacts to the public for not installing them.

8. LIMERICK COULD LOSE POWER AND COOLING WATER LEADING TO 4 SIMULTANEOUS MELTDOWNS, YET NRC DOES NOT REQUIRE LIMERICK TO PLAN FOR INDEF 'INITE ALTERNATIVE BACK - UP POWER TO PREVENT MELTDOWNS.

TO PREVENT MELTDOWNS NRC SHOULD REQUIRE INDEFINITE POWER FOR BLACKOUTS AT LIMERICK TO KEEP BOTH REACTORS AND FUEL POOLS OPERATING IN THE EVENT OF LOSS OF POWER.

Fu ku shima revealed the poten tial for simultaneous meltdowns in Limerick's 2 reactors and 2 fue l poo ls.

Limerick is similar to Fukushima's reactor design. Limerick's fuel pools are built over the reactors. Of major concern, Limerick's reactors and fuel poo ls are built directly over earthquake fault fractu res,

NRC Rules Say Exelon Must Have A P lan to INDEFINITELY SURVIVE BLACKOUTS.

March 0 1, 20 13, NRC 'S website implied New Station Blackout Rules do n ot a pply to plants licensed to operate prior to Jul v 21, 1988. That Includes Limerick.

5~5-13, Mel Gray, NRC, told us NRC announced a draft regulalory basis 4-4-13 for a revised station blackout rule, bu t FAILED TO TELL US NEW RULES WOULD NOT APPLY TO LIMERICK

NRC ~s 5-5-13 response avoided specific answers to our specific questions from both 4-12 and 3-13.

W e ask again. What Is the exact length of time ba c k-up power will be available for both Limerick's reactors and fuel pools simultaneou sly?

1) Is back-up power still only required for 4 or 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months a t Limerick? If no t, what is lhe new m inimum capab ility required for each generator and each fuel pool at Limerick? Fukush im a showed us back-up power capability could be n eeded fo r weeks to prevent meltdowns.

In 2011, after the Fukushima disaster, NRC Chairman Jaczko said, "I 'm not convinced fou r hours Is reasonable to restore off-site power.*

2) How long will fuel for generators last that is stored o n site us ing genera to rs for 2 reactors and 2 fuel pools?

3) NRC said, "h. diesel generator is available for loss of power to the site." Does that mean just one is avai lab le?

4) Emergency gen erators have triggered fires. We asked ho w often Limerick's are tested. NRC said they are tested "periodically". How often Is "periodically"?

9. NRC.IS TRYING TO EXEMPT LIMERICK FROM AN UPDATED SAMA (SEVERE ACCIDE NT MITIGATIO N ALTERNAT IVES}

LIMERICK IS ONE OF ONLY THREE U.S. NUCLEAR PLANTS THAT NRC PLANS TO EXEMPT FROM AN UPDATED SAMA, EVEN THOUGH LIMERICK'S SAMA IS DECADES OUT - OF-DATE.

WHY? WE BELIEVE AN UPDATED SAMA WOULD MEAN NRC COULD NO LONGER DEFEND RISKS FROM CONTINUED OPERATIONS AT LIMERICK.

Facts Show:

Population Density around Limerick is 2nd in the nation and 4 times higher than NRC considered safe for evacuation in 1980 (within 30 miles).

Potential Impacts wou ld be far greater than at most other U.S. nuclear plants. (NRDC research)

Potential costs and consequences of a Limerick accident I me ltdown would be as tronomical.

Over 8 million people live within 50 miles of Limerick, the radius NRC told Americans to evacuate In Japan during the Fukushima accident.

1.4 million people live downw ind in the Philadelphia-Wilmington-Newark metropolitan area.

Th e N a tion a l R esourc e De fe n s e Council (NRDC) WON in the Jrd Circ uit Cou rt of Appe als in Philadelphia, A ain s t Exelon 's Attem t To Circumv e nt This Safet Anal s is R e quirement for Limerick Nucl e ar Plant' s Outdated SAMA.

The common sense planning is Judge agreed with NRDC's needed, stating conc lusion that that Ign oring the what was acceptable in 1989 is population growth around Limerick not good enough now and in the is un acce ptab le, and that future.

Limerick's Severe Accident Mitigation ana lysis was last completed in 1989, relying on the census for 1980 population.

NRC didn't even pretend to be a neutral arbitrator, joining Exelon in an appeal

of the court decision. NRC inexplic a bly called NRDC *s requests "a collateral attack on NRC regulations".

NRC's COST-BENEFIT ANALYSIS DEVALUES EVERY PERSON IMPACTED BY A LIMERICK DISASTER, PLUS ALL THEIR POSSESSIONS AND LIFE-SUPPORT SYSTEM, WHEN CONCLUDING THE COSTS FOR RISK REDUCTION TO THE POPULATION AND THE ENVIORNMENT IS NOT WORTH THE COST TO EXELON FOR SEVERE ACCIDENT MITIGATION DESIGN ALTERNATIVES.

NRC SHOULD REQUIRE AN UPDATED SAMA FOR LIMERICK AND USE IT TO CLOSE LIMERICK TO PROTECT MILLIONS OF PEOPLE.

10. NRC REFUSED TO EXPAND LIMERICK'S EVACUATION ZONE AND INGESTION PATHWAY ZONES

ACTUAL EVIDENCE FROM RADIATION IMPACTS AFTER FUKUSHIMA AND CHERNOBYL DOCUMENT WHY R.ADIOACTIVE PLUMES SPREAD FAR BE;YOND LIMERICK'S CURRENT ZONES AND WHY LIMERICK'S ZONES MUST BE EXPANDED TO PROTECT PUBLIC HEALTH.

NRC HAS FAILED TO PROTECT AND VALUE THE HEALTH, SAFETY, AND FINANCIAL INTERESTS OF MILLIONS OF PEOPLE

NRC FAILURE TO EXPAND LIMERICK'S EVACUATION ZONE BEYOND 10 MILES MEANS:

People are left with a false perception that they are safe beyond 10 miles *

Hundreds of thousands of families will remain in harm's way. Host facilities outside the 1 O mile zone will likely be within the radioact ive plume.

Vast numbers of people will not be evacuating far enough away to k~ep them safe from dangerous radiation plumes, including children in schools. Many host facilities ~re just outsid~ the 1 o

mile EPZ.

People just beyond the 10-mile zone will have NO claims on compensation, NOT even for temporary sheltering and housing.

NRC FA ILUR E TO EXPAND THE "INGESTION PAT H WAY" ZONE BEYOND 50 MILES MEANS:

Large populations beyond SO miles will unknowing ly drink highly radioactive water and eat highly radia ted food Children will unknowingly play on highly radioactive soil

MAPPING SHOWS LIMERICK'S RADIOACTIVE PLUME COULD IMPACT PEOPLE FROM VIRGINIA TO NEW YORK (ACCORDING TO FUKUSHIMA RADIATION DATA PLUMES)

Lime rick is the 2 nd mos t d ense ly populated region aro u nd a nuclea r reacto r in the U.S., with over 8 million p eople living within 50 mlles. Philadelp h ia is just 21 miles downw ind, downs trea m.

Limerick's c u rrent p lan is u nworkable, yet NRC is un w illing to require more protec tive evacuatio n pla nnin g.

11. IN 2012, NRC PARED DOWN EMERGENCY AND EVACUAT ION PLANS,

MAKING THEM LESS PROTECT I VE, NOT MORE PROTECTIVE.

NRC Par e d Down Em e rgency a nd Evacu a tion Pla ns, Ev e n Afte r Wide s prea d Radiation Harms Wer e Documented Due To Fuku s hima Meltdown s.

M a ny R esponders View NRC' s N e w Rules as Down right Bizarre.

I nstead Of Attempting To Min imize C h aos And Reduce Rad iation Exposu re T hrou gh Better Eme rgency Pla nn in g a nd Drills Fo r A Radioactive Acc ide nt / Meltdown:

1) NRC Deceived The Public

2) NRC Denied Radiation Risks and Harms

3) NRC Weaken ed Emergency Rules

4) NRC Failed To Expand Emergency Zones

Despite Devastating Lessons After Chernobyl and Fukushima:

1) NRC Requires, FEWER Exe rcises for Major Radiation Accidents

2) NRC Recommends FEWER People Evacuate Right Away

3) NRC A llo w s Em ergen cy Drills To Be Run Without Practicing for Radiation Releases

4) Siren Alerts Fo r A Limerick Emergency Are Now Tested ONLY 2 Times A Year, NOT Month ly ( 12 Times A Year). Length of Aud ible Alarm Has Been Shortened. Vo lume Is Significantly Lower..

NRC went to extraord inary lengths to deceive the public. News Articles Reveal:

1) WITHOUT Press Releases, NRG Announced Revisions December 23. 2011 at the peak o f the holiday season, in web archives. Most peop le were unaware safeguards were minimized and eliminated.

Full disclosure was not provided un til May 2012, through an Associated Press Investigative Report b y Jeff Donn, titled, "Evacuation Plans, Emergency Drills Pared Down Near Nuke Plants* nn Mercury 5/20/12

- http://W1Nw.pottsmerc.com)

2) NRC Failed to Pursue Emergency Planni ng Related to Decision-Making, Radiation Monitoring, and Public Education.

3) NRC Failed to Address Prolonged Station Blackout Conditions.

4) NRC Failed to Address A Multi-Unit Event, Such As Simultaneous Meltdowns In Limerick's Two Reactors and Two Fuel Pools.

5) Preparedness Foc us Should Have Shifted To Dealing With Meltdowns Along With Natu ra l and Severe Weather Events. Such As Earthquakes.

12. NRC EXEMPTED EXELON FROM THE SAFETY TEST REQUIRED FOR REC LICENSING

The test Is designed to show tha t Exelon's methods for keeping Limerick's aging

systems and equipment are working.

NRC is allowing Exelon to avoid the test before relicensing, allowing a delay for up to a decade or longer. This increases risks to the public.

13. NRC ALLOWED EXELON TO WAIT 7 DAYS TO NOTIFY THE PUBLIC ABOUT A RADIATION ACCIDEN T.

THE P U BLI C COU L D BE E XPOS ED TO RAD IAT ION REL EASES F OR 7 D AY S BE FO R E B EIN G NOTI FI ED BY EXELO N OR N RC. N RC F AI L ED TO RESPO ND TO WH Y T HIS DA NG ER OUS L I CE NSE A MEN DMENT W AS A PPR OV ED.

RADIATION CAN START TO ESCAPE WITHIN 1/2 HOUR AFTER AN ACCIDENT, ACCORDING TO FEMA AND NRC DOCUMENTS.

YET LIMERICK'S "HOT SHUT-DOWN" REQUIREMENT WAS CHANGED FROM 12 HOURS TO 7 DAYS (12-19-11),

14. NRC IS FAILING TO TRACK LIMERICK'S LOW-LEVEL RADIOACTIVE WASTES BY WEIGHT AND VOLUME. THEREFORE NRC CAN'T BE SURE HOW MUCH IS PRODUCED AND WHAT IS BEING DONE WITH IT.

TO SAVE MONEY, EXELON COULD BURN SOME OF LIMERICK'S MASSIVE LOW LEVEL RAD-WASTE ON SITE WITHOUT NRC'S KNOWLEDGE, DRAMATICALLY INCREASING HEAL TH THREATS IN THE REGION.

NRC ADMITS AND RECORDS SHOW THAT NRC FAILS TO REQUIRE REPORTING OF LIMERICK'S SOLID LOW-LEVEL RADIOACTIVE WASTE (LLRW) BY WEIGHT AND VOLUME.

IF WEIGHT AND VOLUME ARE NOT TRACKED, NRC CAN'T VERIFY WHERE IT GOES OR WHAT IT DONE WITH IT.

NRC $TATES IT DOESN'T TRACK WEIGHT AND VOLUME BECAUSE REGULATIONS DON ' T REQUIRE IT.

NRC inexp licably allows Exe lon to report its LLRW off-site disposal In numbers of truck shipments (not included is the weight or volume of LLRW in those shipments).

NRC Must Ex plain The Huge Difference In Limerick LLRW Off-Site Shipments :

82 Ship ments o f Limerick's LLRW were sent off Limerick's site in 2011 110 Ship ments of Limerick's LLRW We re sent off Limerick's site in 2012 NRC Must Ex plain Wh y :

Exe lon Is Allowed To ESTIMATE Solid LLRW Shipped Off-site For Burial or Disposal Exelon Is Allowed A 25% Mar g in of Error in Estimates (From 2012 Exelon Report)

NRC Must Ex plain; Why storage of radioactive hardware has been allowed (2012) in the poof or processed into the dry cask storag e system NRC Must Explain:.

Why NRC Allows Transfer Of Storage From One Exelon Plant To Another (2012 Report)

NOTE: IT IS DANGEROUS TO ALLOW STORAGE OF ANY LLRW IN LIMERICK'S RAD*

WASTE BUILDING, LOCATED ON TOP OF EARTHQUAKE FAULT FRACTURES.

WHY TRACKING LIMERICK'S SOLID LLRW IS NEEDED TO PROTECT PUBLIC HELATH AND SAFETY :

Low-level does not mean low-risk. Independent experts say some of it must be kept away from the public for up to 500 years.

It is negligent for NRG to fail to keep track of the weight and volume of all low wlevel radioactive wastes produced at Limerick.

Exelon was incinerating low - level wa ste at Limerick in a boiler, but now claims to have stopped.

Unless NRC tracks Limerick's LLRW weight and volume, NRC has no proof incineration will not occur on site. Exelon saves big $$$ if burning it on-site instead of shipping it off-site.

However, that is clearly at the expense of the health of the public. *

It appears Exelon may be recycling some of Limerick's low-level radioactive waste.

This could end up in products that can endanger public health, especially children.

Is Exelon Recyc *ling Any Of Limerick's Low-Level Radioactiv e Waste? If So, Is Exelon Getting Compensation For Limerick's Low-Level Radioact ive Waste Recycling.

Expla in what happens at the Energy Solutions Processing Facility and the TOSCO Processing Facility where 42 of Limerick's Truck Shipments Went -In 2012.

NRC MUST CHANGE REGULATIONS TO REQUIRE TRACKING OF SOLID LLRW BY WEIGHT AND VOLUME. OTHERWiSE, NRC CAN ' T ASSURE THE PUBLIC I T'S SAFELY HANDLED.

The Peach Bottom Exam ple: DEC EPTION OR W ILLFU L BLINDNESS?

There is no more room to store it at Limerick. In 2010, NRC gave Exe lon permission to take It to Peach Bottom for storage.

- In 2013 an NRC official told us that the ag reeme nt was only for one year.

Exelon's Rad iolog ica l Effluents Repo rts do not reflect that any of It ever we nt to Peach Bo ttom.

In 2013, an Exelon PR person to ld a group discussing radioactive waste transport, that Limerick's low level radioactive wastes are going to South Dako ta and Peach Bottom in 4 shipments a year.

NRC co n tradicted those claims by Exelon and suggested it all.wen t to Ene rgy So lutions in Clive, Utah,

ACE URGES NRC TO CHANGE REGULA T IONS TO RE UIRE TRACKING BY WEIGHT AND VOLUME OF LIMERICK'S SOLID LOW -LEVEL DIOACTIVE WASTES,

ACE ALSO RE UESTS THAT SOLID LLRW REPORTING BE CLEARLY IDENTI FIED IN A SEPERATE REPORT, AND NOT HIDDEN IN EXELON'S RADIOCTJVE "EFFLUENT' REPORT FOR LIMERICK.

NRC WHITEWASHES LIMERICK VIOLATIONS, MALFUNCTIONS, AND NON-COMPLIANCE JEOPARDIZING PUBLIC SAFETY

NRC'S LAX OVERSIGHT AND ENFORCEMENT ARE A RECIPE FOR LIMERICK DISASTER!

Year After Year, NRC Overlooks Many Serious Issues At Limerick, Downplaying Their Significance By Frequently Declaring Them "Green Findings", Even Though Some Can Lead To Accidents And/Or Meltdowns.

EXAMPLES BELOW SHOW NRC'S DANGEROUSLY DELAYED CORRECTIVE ACTIONS AND NEGLIGENT OVERSIGHT AT LIMERICK NUCLEAR PLANT

1. Seismic Monitors Were Left Ino perable For At Least 1 Year And Four Months.

They Were Inoperable When The Virginia Earthquake Jolted Limerick.

2. Radiation Monitors Were Left Ino perable For Over 1 Year For Radioactive Discharges Into Public Drinking Water For Almost Two Million People

3. Preventive Maintenance Was Deferred For 3 Years For An Airlock Door Magnetic Switch.

That Can Result In Increased Radioactive Releases *

4. Procedures To Protect The Reactor Were Not Followed In The Required 15 Minutes, It Took 1 Hour And 49 Minu tes To Res pond To An Alarm To Reduce Power To Protect The Reactor. This Violation Was Not Recorded Pro perly Until 103 Da y s Later.

5. There Was No Preventive Maintenance Fo r A Limerick Transformer For 3 Years.

This Led To An Explo sion.

6. Defective Material Was Reinstalled Into A Safety S y stem After It Failed.

Exelon Fa iled To Retest Recycled Parts After Repairs And Before Installation.

7. Age-Degraded Relays Were Not Replaced For 8 Years Past Their Vender Recommended Lifetime.

This Could Have Led To Core Damage.

RECENT LIMERICK VIOLATIONS COULD HAVE LED TO SERIOUS PROBLEMS, YET NRC DOWNPLAYED THEIR SIGNIFICANCE. NRC REPEATEDLY Al:.LOWED EXELON TO DELAY CORRECTIVE ACTIONS, INCREASING RISKS TO THE PUBLIC.

1. Radiation Barrier Integrity Wa s Breached.

Spill of 15,000 thousa nd gallons o f radioactive water into the Schuy lkill River.

The public was no t notified for 23 days.

Millions of people were deprived of making the choice not to drink or use the contami n a ted water.

2. Failure OF Degraded Magnetic Switch for a Secondary Containment Airlock Door

Compromised bar rier integrity that, in the even t ~f an accident, would not have pro tected the public from radionuclide releases

3. Failure To Follow Radiation Procedures For Evacuation Of Unit 2 Upper Drywall During Removal Of Irradiated Core Components

Poor Communicatio n to personne l

4. Emergency Diesel Generator Unexpectedly Unavailable For About 40 Hours Due To Poor Maintenance.

Emergency back-up powe r is not optional: loss of power woul d lead to loss of water to the core causing meltdown

5. Failure To Correct Leaking Oil Supply To Emergency Diesel Generator For 6 Months

Degraded cond ition existed from Nov. 2012 - May 2013

Exelon failed to classify it as a critical failure, resulting in a low level of investigation

Could have led to "undesira ble conseqllences"

6. Failure To Replace Age-Degraded Valves For 8 Years Past Their Vendor Recommended Llfetrme: failure of the valves could lead to loss of water to the Cor e

t.

Could lead to core damage/meltdown

Valve failure caused the TM I partial meltdown.

7. Transformer Explosion Due To Lack Of Preventive Maintenance For 3 Years Followed By Failure To Provide Operator Guidance For 103 Days Afterwards

Failure to respo,nd to alarm for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 49 minutes rather than within 15-minutes, as required: delay in reducing power to reduce heat in the reactor could lead to meltdown.

8. Transformer Failure Caused Loss Of Reactor Re-Circulation Pumps Due To Lack Of Maintenance During The Previous Summer

Could have led to meltdown without successful manual shutdown

Failure to take appropriate action

9. Failure To Adequately Evaluate The Voltage To Safety Equipment

Could have resulted in loss of coolant which can lead to meltdown

Due to Exelon's poor guidance

10. Trip Set Points For Circuit Breakers Were Set Too High

Could have led to fires (NRG has reduced fire safety regulations)

11. Failure Of Operating Crew Simulator Test

Could result in core damage

12. Failure To Assess Battery Charger Operability

No explanation for unexpected test failure resu lts for battery chargers

13. Delayed Fire Brigade And Fire Equipment Tran s port To The Spray Pond Pump House

Increased risk of fire damage

Due To Incorrect Exelon Gu idance

14. Failure To Establish Preventive Maintenance For Safa Shutdown Switches

Increased risk of fire damage, while NRG allows Limerick to operate with la x fire regulations.

15. Failure To Address Depressurization In Unit 1

Caused a service air compressor trip

16. Failure To Correct A Previously Failed Circuit Board

Reinstallation of defective ma terial

Poor preventive maintenance

Poor decision mak ing

1,. Failu _re Of Turbine And Control Valve Due To Improper Procedures Which Could Lead To Severe Safety Issues

The fa ilure resulted in an llnplanned automatic reactor shutdown

NRG noted that Exelon could have and should have prevented this problem NRC REPEATEDLY FAILED to PROVIDE FULL AND ACCURATE DISCLOSURE AND DISMISSED PUBLIC COMMENTS, QUESTIONS AND CONCERNS

NRC GOES TO EXTRAORDINARY LENGTHS TO BE DECEPTIVE AND. EVASIVE NRC'S RESPONSES TO PUBLIC INPUT REFLECT WILLFUL BLINDNESS AND FLAWED LOGIC NRC'S PUBLIC PROCESS IS.AN ILLUSION

NRC NEGLIGENTLY DISMISSES PUBLIC INPUT As a group of citizen volunteers, ACE members have been repeated ly frustrated by NRC's process wh ich asks for publlc comrrient, but then fails to actually address or take protective actions on issues raised and questions asked in those comments. Since 2000, ACE has investigated, uncovered, and presented to NRC numerous significant and unprecedented threats and harms to the health and safety of millions of people in the Greater. Philadelphia Region related to Limerick Nuclear P lant.

Yet, over the years, time after time, N RC has dismissed and/or failed to actually answer question~and concerns in extensive ACE testimonies and correspondence.

NRC'S FAILURE TO ANSWER QUESTIONS OR RESPOND TO SERIOUS CONCERNS Major issues of concern identified by ACE members have come from NRC's own records, yet are ignored, dismissed, or spun into deceptive rhetoric by NR C publ ic re latio n s people. NRC records show NRC staff h.as done a good job identifying a wide range of very serious pro ljlems that present huge health and safety threats, as well as risks that could lead to Limerick meltdowns.

Yet NRG officials higher up the ladder (largely public relations peo ple) e nd up dism issing NRC's own staff's findings, co n cerns, and recommendations.

NRC TACTICS USED TO DECEIVE US AND DISMISS UESTIONS AND CONCERNS NRC failed to answe r and add ress important questions raised by ACE members by:

1. Send ing us to websites, often that don't con tain the answers we seek

2. Falsely claiming quest ions were a lready answered

3. Attempting to talk to us on the phone to avo id putting answers in writing

4. H idin g the truth from the pub lic, claiming the issue is security reiated, which is o ften absurd

5. Lying to us outright or through omission

6. Repeatedly says we do not unde rstand NRG procedures and regulations, when they are the problem

7. Public relations spokesman ignore the su bstance of questions and concerns

in their responses

8. Telling us to contact the Office of Inspector Genera! for ar) *inyes tiga tion,

CITIZE N VOLUNTEERS SHOULD NOT BE EXPECTED TO CONTACT THE OFFICE OF INSPECTOR GENERAL TO GET NRC TO PROTECT PUBLIC HEALTH A ND SAFETY. THAT IS THE MISSION OF NRC.

ACE presented a body of evidence showing NRC grossly mischaracterized serio u s issues and mismanages its oversight, further jeopard izing our region.

Yet, time after time, NRC responds not by taking precaut ionary, protective act ions to reduce harms to health or reduce risk of meltdowns, but instead state, "If you feel that NRG hc1s mismanaged elements of our reactor oversight program, you should feel free to contact the Office of the Inspector General (OIG) at NRG."

NRC OFFICIALS REFUSED TO DISCUSS DOCUMENTED RESULTS OF ACE INVESTIGATIONS

1. NRC Failed To Prov ide A Repeated ly Requested Meetin g With The En vironmental Review Tea m For Limeric k's EIS, AFTER Limerick's Environmental Review Team failed to acknowledge or address actual environmental impacts to air, water, and health which ACE put on the pu blic hearing record in hundreds of pages of testimony.

INSTEAD: On '4-25-13, David McIntyre, NRC Office of Public Affairs, a pub lic relations person, offered ACE a 15 m inute phone meeting with him. A 15-mlnutc phone co nversa tion with a PR person is not an acceptable substitute for an in person mee ting so that ACE could explain the complex environmental threats based on our investigations that need further attention.

2. NRC Failed To Meet To Discuss Unr ealistic, Unw orkable Suppositions, Assum ptions, Inconsistencies, a n d Inac curacies, in Exe lon's 2012 Plume Exposure Pathway Time Estimate for Limerick."

INSTEAD: Joseph Anderson, NRC Outreach Branch (another PR.person) absurdly claimed NRC had no responsib ility to review Exelon 's ETE, even though NRC required it to be done. ACE' s response*to Anderson was finally answered on 6-4-13, by Mark Thaggard, NRC Acting Director Division of Preparedness and Response, Office of !'luclea*r Security and Inciden t Respo nse. Thaggard said, "we look forward to discussing w ith you, in a mutually agreeable venue, your concerns and insights rega rding the December 2012 ETE update for the LGS site," but then NE VER RESPONDED to our 6 13 letter suggesting m eeting times and loca1ions.

RADIATION RELEASES FROM LIMERICK NUCLEAR PLANT ARE NOT SAFE

Limerick Nuclear Plant will continue to poison our air, water, food, milk, fish, and children as long as it operates.

NO monitoring or NRC oversight can or will reduce actual health risks from the additive, cumulative, and half-livessynergistic. impacts of Limerick's decades of releases of over 100 different radionuclides, some with long

No one should believe NRC's baseless claims.

Initially, NRC claimed that Limerick doesn't release radiation, despite proof that it does.

Now, NRC admits rad iation is released but repeatedly uses baseless indefensible propaganda and deception to make the claim that radiation levels released from Limerick are safe.

NRC has no accurate idea what levels of Limerick's many radionuclides are released (routinely and accidently) into our air, water, and soil.

NRC Does NO Radiation Monitoring For Radiation Released From Limerick.

NRC's absurd claim that Limerick's radiation releases are safe Is refuted by the refuted by the National Academy of Sciences BEIR VII Report, stating There Is No Safe Level.

"Permissible" Radiation Doses (As Defined By NRC), Does Not Mean Safe.

NRC allows flawed, outdated theoretical models that measure only external radiation doses and ignore internal doses. Additive, cumulative, and synergistic harmful health impacts are unknown.

Dr. John Gofman, once head of AEC's Lab, raised dire warnings in research showing an estimated 32,000 Americans would die each year from fatal cancers iriduced by "allowable" radiation releases from n uclear

plants. He said, "The entire nuclear power program is based on a fraud that there is a permissible dose that

wouldn't hurt anyone."

Skyrocketing cancer rates after Limerick started operating in 1985 suggest Limerick's radiation.releases were never safe. Cancer rates climbed far higher than sl~te and nationa l averages in communities near Limerick, especially in children.

NRC's Radiation Monitoring Requirements For Exelon's Report On Limerick Deceive The Public

Limerick's Radiation Spikes From Accidents And Problems Go Undetected And Unreported. Exelon Averages Results

Exelon, With A Vested Interest In The Outcome, Estimates Risks

NRC Allowed Huge Margins Of Error. Example: Up To A 36% Margin Of Error In Reporting Radioactive Fission Gas, The Kind Increased By Limerick's Use Of High-Burn Fuel. *

Reporting Is Done On Radiation Levels ONLY Over An Arbi'trary Inflated Background Level NRC fails to require actual continuous radiation monitoring, testing, and reporting for all radionuclides being released from Limerick into our air and water.

NRC's Claim of Rigorous Oversight Of Radiation Monitoring Is Absurd and Disputed by the Evidence.

NRG relies only on Exelon data and reports, allowing this company tha t has a vested Interest in the ou tcome and that has repeatedly shown ii can't be trusted, to estimate and calculate risks based on flawed protocols and data.

Examples:

Radioact ive Releases to Air

36% Margins of Error Allowed

Inoperable Radiation Monitoring Equipment (Over 1 Year)

Radiation Dose Factors Were Omitted for a 5-week period Radioactive Releases to Schuylkill River Drinking Water For Almost 2 Million People

NRC failed to discover Limerick's 3-19-12 radioactive spill and falsely claimed it was only tritium. NRC couldn't confirm exact amo u nt of spill or exact time it started. *

For 23 days, NRC failed to require Exelon to report Limerick's radioactive spill. Defenseless families had no opportunity to avoid using th e water. You can't see, smell, or taste radiation.

NRC stood silent while PA DEP allowed unlimited pollution into the river that transports Limerick's radionuclides. Exelon should have been requ ired to filter Limerick's discharges to protecl public health.

NO NRC OVERSIGHT OR MONITORING PROTECTS US FROM LIMERICK'S RADIATION For More Details On Limerick Nu.clear Plant and Radiation Visit www.acererport.org.

1 Radiation - Limerick's Routine Releases #2 Cancer Skyrocketed - Links to Limerick

3 Radiation - No Safe Dose THE ALLIANCE FOR A CLEAN ENVIRONMENT (ACE ) IS OFFICIALLY CALLING ON NRC TO FOLLOW NRC'S MISSION TO PROTECT THE PUBLIC

LIMERICK MUST BE CLOSED NOW DUE TO THREATS THAT CAN 'T BE FIXED BY ANY STUDY OR ACTION, CONTINUED OPERATION OF LIMERICK IS FAR TOO RISKY AND UNACCE 'PTABLE!

WHY NRC MUST CLOSE LIMERICK NUCLEAR PLANT NOW:

1. TO PREVENT CATASTROPHIC MELTDOWNS TRIGGERED BY EARTHQUAKES, MECHANICAL FAILURE, A CYBER ATTACK, OR A TERRORIST ATTACK WITH A PLANE OR MISSILE

LIMERICK'S REACTORS, FUEL POOLS, CONTROL ROOM, TURBINE BUILDING, AND RAD -WASTE BUILDING WERE ALL BUILT DIRECT L Y ON TOP Of EARTHQUAKE FAULT FRACTURES.

CLOSING LIMERICK IS THE ONLY WAY TO PROTECT US FROM THE ENORMOUS POT-ENTIAL FOR CATASTROPHIC MULTIPL E MELTDOWNS TRIGGERED BY STRONGER AND MORE FREQUENT EARTHQUAKES.

Millions of People In The Greater Philadelphia Reg ion Would Lose Everything From Lime;icll Meltdowns, With Nowhere To Turn For Help And NO Insurance to Cover Losses. This Ca n Be Prevented.

2. TO PREVENT LIMERICK'S UNADDRESSED AGING, CORRODING, DETERIORATING SYSTEMS AND EQUIPMENT FROM LEADING TO MELTDOWNS

LIMERICK'S UNADDRESSED DETERIORATING CORRODING AGIN E U PMENT AND SYSTEMS INCREASE MAJOR PROBLEMS THAT CAN LEAD TO RADIOACTIVE ACCIDENTS, AND EVEN MELTDOWNS.

EXELON IS DELAYING AND /OR AVOIDING CRUCIAL REPAIRS AND MAINTENANCE, INCREASING RISKS WHILE CUTTING CORNERS TO SAVE MONEY.

Exelon's Cu rrent Financ ial Woes Suggest Exe lon Won~ Do What Is Necessary To Make Limerick Safer.

Industry Stated Some Equipment Is Just Too Costly To Replace or Repair.

Miles Of Aging Pipes and Cables Buried Under Limerick, Vital To Preventing Meltdowns, Are Deteriorating, Yet Problems Are Impossible To Inspect, Detect, and Costly to Repair.

Substandard Cement Was Used For Limerick's Fue l Pools. Corroding and Thinning Is Already Occurring At Rates Up To 1 O Times Faster Than Anticipated, Yet Exelon Has Unti l 2014 To Recoat Linings.

Design Flaws Will Allow More Radiation to be Re leased In Accidents/ Meltdowns, Yet Exe lon Refused To Provide Filtered Vents.

3. TO STOP ROUTINE RADIOACTIVE RELEASES INTO OUR AIR, WATER, AND SOIL

LIMERICK ' S ROUTINE AND ACCIDENTAL RADIOACTIVE RELEASES INTO OUR AIR, WATER. SOIL, FOOD, AN BODIES WILL ONLY STOP WHEN LIMERICK CLOSES,

ALARMING CANCER AND INFANT MORTALITY RATES W I LL EVENTUALLY DECREASE WHEN LIMERICK NO LONGER RELEASES RADIATION INTO OUR LIFE SUPPORT SYSTEMS.

There is NO SAFE LEVEL of ion izing radiation exposure according to a large body of independent scientists and physicians.

NRC does NO MONITORING, allows Exelon to estimate Limerick's ra diation releases and ri.sks (with huge margins of error), yet absurdly claims it's safe.

4. TO STOP HIGH-LEVEL RADIOACTIVE WASTE ACCUMULATION ON-SITE

UNTIL LIMERICK IS CLOSED, ITS DEADLY HIGH-LEVEL RADIOACTIVE WASTE STOC ~ PILES WILL CONTINUE TO INCREASE AT LIMERICK, ADDING TO ALREADY ENORMOUS RISK.

THERE IS NO SAFE SOLUTION FOR THIS WASTE.

Limerick's Over-Packed and Vulnerable Fu el Pools Present Enormo us Risk For Catastrophic Meltdowns.

Limeric k's U se Of High-Burn Ra dioa c tive Fu el Drama tic a lly Increases Already Da ng erou s Fu el Poo l Degra da tion.

Degra dation o f Fue l Rods Incr eases U sing High-Bu rn Fu el. And, It Mu st Be Stored In Lim erick' s Fue l Po ols 3 Tim es Lo n ger Before Removal.

Lim erick's Cas k Design Is Flaw ed. No Pro o f Exists W as tes Ca n Be Remo ved Over Time Or In Case Of Fire.

5, TO STOP UNPRECEDENTED AND INCREASING THREATS TO DRINK:ING WATER

UNLESS LIMERICK CLOSES SOON, ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA COULD END UP WITHOUT SAFE DRINKING WATER.

LIMERICK RELEASES UNLIMITED RADIATION AND COOLING TOWER TOXICS INTO THE RIVER.

SOME TDS DISCHARGES ARE UP TO 5 TIMES HIGHER T HAN SAFE DRINKING WATER STANDARDS.

Limerick's Cooling Towers are Depleting the Schuylkill River.

Limerick's Overheated Discharges Are Destroying the Schuylkill River Ecosystem.

Exe lLimerick on Pumps Ma ssive Operations. Amounts of UNFJL TERED Toxic Mine Pit Water In to The River To Supplement The Flow For

6. THE REGION IS TOO DENSELY POPULATED TO EVACUATE SAFELY IN THE EVENT OF A MELTDOWN. PREVENTION IS IMPERATIVE!

LIMERICK MUST CLOSE NOW FOR PREVENTION. IT IS NOT POSSIBLE TO EVACUATE SAFELY.

MILLIONS OF PEOPLE COULD BECOME NUCLEAR REFUGEES, LOSING EVERYTHING,. WITH NOWHERE TO GO AND NO HELP, IN THE EVENT OF A FUKUSHIMA-LIKE CATASTROPHE.

Evacuating From A Radloactlve Environmental, and Financial Consequences Could Last Forever, Disaster Is Wo rse Than From A Natu ra l W ith Impacts From New York tDisaster. Devastating Health, o Virginia.

Over Responsible 8 Million Officials People Testified Live W ithin That Roads Can Not Support Safe Evacuation. 50 Miles o f Limerick, the 2nd Mos t Densely Populated N!Jc lea r Region In The U.S.

Exelon's Evacuation Plan Is A Farce.

NRC Relleaving Vast Numbers Of axed Emergency Planning and Evacuation Standards and Re fV ictims With NO Help For Tempo rary or Replacement Housing, Etc. used To Expand The Evacuation Zone.

EXAMPLE OF STRUCTUAL FLAWS THAT CAN'T BE FIXED

1. Earthquake Fault Waste Storage BuilFractures ding Are Directly UN DER limerick's Reactors, Fuel Poo ls, Control Room, Turb ine Buildin g, and Rad

TH IS UNPRE CE DENTED THRE AT CAN 'T BE FIX ED!

2. Substanda rd Cement Wa s Us ed For Limerick's Containment THIS PRES ENTS ENO RMOU S RISK! IT C AN ' T BE.FIXED !

3. Substandard Cement Wa s Used To Build Limerick 's Fuel Pools, Built On Top Of limerick' s Reactors, ON TOP Of Earthquake Fau lt Fractures. Limerick's Fuel Pools Are Corroding and Thinning At Rates, Far Faster Than Anticipated Which Drastically Intensifies the Risks. We Don 't Believe Limerick's Fuel Pools Can Be Recoated When They Conta in Large Volu mes *of Deadly Waste That Must Remain Cooled..,

TH IS P RE SE NTS RIS K OF UNTHINKABLE CATASTR OPH E. RI SK S CAN'T BE ELIMINATED !

4. llmer.lck's GE Mark II Boiling Wa ter Reactors V ibrate Too Much During Norm a l Operations.

LIMERICK'S INSATIABLE WATER NEEDS COMBINED WITH LIMERICK'S RADIOACTIVE AND OTHER TOXIC RELEASES CREATE THE POTENTIAL FOR AN UNNECESSARY DRINKING WATER DISASTER AT A TIME WHEN SAFE WATER IS BECOMING MORE SCARCE 1. Limerick Tower Toxics Into The DrCan't Operate Withou t ink ing Wa tVio la ting er Source For Almost Safe Drinking Wc!te r 2 Million Standards Fo r People TDS That Transports Both Radiation and Coo ling

2. Depletion From Coo ling Tower s. Will Continue, Despite Supplementation 3. -Unfiltered Tox ic Mine Pit Wa ter Pump ing Into This Drinking Water Source For Supplementation To Operate Limerick Will Continue, Threa tening Ha rmfu l Public Health Impacts and Increased Costs to Water Treatment Systems 4. limerick's Heated Discharges Will Continue To Overheat T he River, Threatening Ecosystems LIMERI CK'S U N P RE C EDENTED THRE A TS AND HA RM S TO DRINKING W ATER CAN' T BE ELIM INATED UNLESS LIM ERICK CLOSES

DEMAND FOR NUCLEAR POWER IS DOWN WE DON'T NEED LIMERICK'S ELECTRICITY, BUT VVE NEED A HEALTHY.ENVIRONNIENT AND A SAFE DRINKING WATER SUPPLY.

WE SHOULD NOT FACE RISKING EVERYTHING DUE TO A LIMERICK *MELTDOWN.

Fo r Details On Limerick Nu clea r Pla nt: www.acere port.org or EMAIL aceac tlvists@comcast.net 1

NRC Chairman Allison M. Macfarlane March 31, 2014 U.S. Nuclear Regulatory Commission Ma il Stop 0-16G4 Washington, DC 20555-0001 301-415-1750 Chairman@nrc.gov

Dear NRC Chairman Macfarlane,

LIMERICK NUCLEAR PLANT needs your immed iate attention. There is no way to reduce the extraordinary risks for multiple meltdowns that could be triggered by an earthquake at Limerick Nuclear Plant. We are submitting evidence that shows that Limerick's earthquake risks are so high that it must be closed immediately to avoid unnecessary health and financial devastation to millions of people in the Greater Philadelphia Region.

We contact you because NRC officials for Limerick have long been either incompetent or dishonest by not acknowledging Limerick's extraordinary earthquake risks. NRC is jeopardizing the health, safety, and financial interests of over 8 m illion people living within 50 miles of Limerick Nuclear Plant

Fukushima *was enough justification for preventive measures to be taken immediately, given Limerick's "HIGH RISK status, yet after three years NOTHING has been done to reduce risks.

Attached correspondence shows how one NRC official after the other down-played and/or covered up absolutely unacceptable risks at limerick.

Now we learned earthquake risks at Limerick are far worse than we thought. We just discovered evidence on 2-18-14 which proves that:

Limerick Nuclear Plant's Reactors and Spent Fuel Pools Were Built DJrectly On Top of Earthquake Fault Fractures.

A September 3, 1974 report reveals that limerick Nuclear Plant's (1) Reactors, (2) Control Room,

(3) Turbine Building, and (4) Rad-Waste Storage Building were all built directly on top of earthquake fault fractures. (Limerick's fuel pools were not listed in the report, presumably because Limerick's fuel pools are above its GE Mark II reactors, similar to those at Fukushima.)

The 1974 report titled: "Report on Treatment of Fracture Zones for PECO by Bechtel Power Company", shows _ how fault fractures under Limerick were prepared prior to construction.

This shocking report includes photographs and a diagram to scale showing:

f. A fault Geological zone fracture Survey was completed in 1974 after it was filled in with cement (called dental concrete) in f 973, ~ Limerick's

2. A fault zone fracture directly under Limerick Unit 1 reactor 3. A fault zone fracture filled with cement that supports a column for Limerick Unit 2 reactor

4. A fault turbine building zone fracture being filled with cement directly under the support wall between the control room and

5. The location of Limerick Nuclear Plant buildings and how they are positioned over the fault zone fractures 6. Spent of its reactorsfuel pools are not shown i. n the diagram, since Limerick is a Mark It GE design, with its fuel pools on top Graphics referenced above are attached ( See Attachments}

Risks were clear before Limerick was constructed, yet hidden from the public until now.

Limerick's vital structures were built directly over fault fractures to save PECO costs. In the 1972 Environmental Impact Statement for Limerick, the Atomic Energy Commission {AEC now NRC) considered alternative sites, which were then eliminated due to industry costs. (See Attachment)

Nothing can fix this. Limerick Nuclear Plant can't suddenly be declared safe as the result of any NRC study or regulation. NRC must own up to the real dangers and close Limerick immediately, BEFORE there are meltdowns. In addition, Limerick's deadly radioactive wastes must be removed from the fuel pools as soon as possible and placed into hardened on-site casks.

2

We compiled a body of evidence showing that the earthquake risks at Limerick Nuclear Plant are both extraordinary and unacceptable. As stated before, this evidence clearly supports the need to close Limerick now and remove high-level radioactive wastes from Limerick's fuel pools as soon as possible and placed into safer hardened cask storage.

Serious Problems and Concerns That Should Not Be I g nored: Major Threats That Dramatically Compound and Intensify Possible Damage To Limerick's Vital Structures Built Directly Over Earthquake Faults:

Four earthquake faults earthquake fault directly (one considered active) under Limerick's vital infrastructure. are within 17 miles of Limerick, in addition to the

Limerick's decades old reactor containment and fuel pools were built with substandard cement,

. increasing ea~hquake risks for Limerick Nuclear Plant.

Limerick's fuel pools, located above limerick's reactors (similar to Fukushima's), are packed far beyond design capactty with some of the most deadly materials on earth.

Limerick Limerick's EIS testimony. fuel pools were constructed with substandard cement, a fact confirmed by 9-22-11

Limerick's fuel pools are corroding and thinning at rates up to 10 times faster than anticipated, a fact confirmed by NRC staff in letters to Exelon.

Miles of aging and deteriorating pipes and cables buried under Limerick, vital to supplying energy and water to prevent a meltdown can be disrupted and damaged from an earthquake, yet they cannot be inspected. Limerick relies on monitors and gauges that are often inoperable.

An earthquake at Limerick could trigger multiple meltdowns in fuel pools, unleashing far more radioactivity than Hiroshima, Nagasaki, or even Chernobyl, because of Limerick's enormous on-site accumulation of spent fuel.

The 8-23-11 earthquake in Virginia jolted Limerick Nuclear Plant, showing that Limerick can be impacted by an unpredicted earthquake.

*Earthquakes are becoming stronger and more frequent.

Earthquake risks have increased dramatically due to massive frad<ing In PA and nearby states.

were approved In PA. USGS states that tracking can trigger earthquakes. Since 2007, well over 4,200 natural gas wells

In 2012, the local newspaper reported that:

Some Limerick systems, structures, and components could be unreliable in an earthquake Limerick's fire prevention seals may not tolerate a *seismic evenr.

Given recent earthquake events and discoveries it is clear that, ln reality, Limerick's earthquake risks go far beyond Limerick's "so-called" earthquake design basis.

Limerid< nation's earthquake risk is considered a "High list. Risk" nuclear plant for earthquakes, and reported to be 3rd on the

The 8-23-11 earthquake in Virginia jolted Limerick Nuclear Plant, including the control room.

Limerick's infrastructure was uninspected after the Virginia earthquake, despite the risk.

Limerick's verification earthquake monitors were Inoperable 8-23-11. Limerick of the Virginia earthquake. had to contact USGS for

limerick's records). seismic monitors had remained inoperable for over a year {documented in NRC

If could originate the Virginia earthquake jolted in one of the many nearby faults Limerick Nuclear Plant, and could be devastating. it can be assumed that a similar earthquake

Recently, two small,earthquakes originated in Philadelphia, only 21 miles away.

3

ERRORS WERE MADE DURING LIMERICK NUCLEAR PLANT'S CONSTRUCTION, WHICH CANNOT BE CORRECTED NOW

Dan Ely, A Bechtel Quality Assurance Inspector During Limerick Construction, Testified On 9-22-11 That Failures, Deviations, and Non-Conformances, Including Materials Monitoring, Plagued Limerick Construction From the Beginning.

Mr. Ely said that a number of errors were made and in light of what we know about earthquakes now, the deviations made during the construction of Limerick should be revaluated.

"We need to go back and take a look at all of those mistakes and make sure that they're not written off because a layer in a structure under load caused by an earthquake, that's an issue."

Mr. Ely witnessed a very low-strength sand mix that was erroneously pumped into the fuel pool girders in a layer. There was only supposed to be the very highest quality of cement used in that 36-hour pour, but an engineer (not him) said, "Well, boy. that was a terrible mistake. but it'll be

~

Ely said he now sees a big problem created by that deviation: A layer like that, he said, in a structure under load in an earthquake, is an *issue... In regards to catching fire because it's going to catch fire if the fuel pool girders fall. It's a very hot situation and the consequences of the released material could be life-threatening.

This was only one of a number of errors on that pour, Ely said. He was concerned because he saw no review of those early deviations in Exelon's relicensing application. He testified that:

- Errors were made dur ing the pour of the cement for Limerick's fuel pools, resulting in substandard cement. *

- He said non-conformances such as this need to reviewed in light of what we understand and know today about earthquakes or other anomalies.

- The rebar concrete-reinforced supports were supposed to be filled with the very highest grade of concrete.

- The engineer didn't pay attention and said a terrible mistake had been made, but it would be ok.

Dan Ely stated that when Limerick was being constructed, things were passed over back then that would not be allowed now that earthquake risks at Limerick are better understood, because at that time Limerick's earthquake risk was considered low. He expressed concern, because he felt that they need re-evaluation in light of limerick's increased earthquake risk.

Mr. Ely's testimony shows why NRC's generic review for earthquake risk and Exelon's self serving analyses are not enough to keep us safe. They are absolutely meaningless in relation to Limerick's safety.

Limerick's construction naws clearly present unacceptable risks, especially in combination with Limerick's extraordinary risk for damage from an earthquake. Yet, NRC has Ignored Dan Ely's 9-22-11 testimony, inexplicably refusing to require an independent updated site-specific earthquake risk analysis at Limerick Nuclear Plant.

Ironically, Diane Screnci, NRC senio.r public affairs officer for the Region 1, stated in a 5-20-12 Mercury news article that,.. in many ways, the key to nuclear safety when earthquakes are involved Is less about pre.dieting earthquakes than designing plants that can withstand them".

That statement clearly does not apply to Limerick when Limerick's vital structures were built directly on top of an earthquake fault in an active earthquake region and when errors occurred during Limerick's construction that can't be fixed.

LIMERICK IS CLEARLY NOT A WELL-DESIGNED PLANT AND MAY NOT REMAIN SAFE 4

ALARMING LIMERICK NUCLEAR PLANT DESIGN FLAWS

LIMERICK'S REACTOR FLAWS

Both Limerick's Reactors are GE Mari< II BWRs, Similar to Those That Melted Down at Fukushima Fukushima reactors failed. Units 1,2,and 3 suffered multiple explosions with massive land contamination and groundwater contamination.

Limerick's GE Mark II reactor design has a high probability of failure under severe accident conditions leading to massive land and groundwater contamination.

- According to NRC's own staff, document 2012 - 0157 -GE BWR for Limerick states that both Limerick units are in violation of General Design Criteria #16.

Reactors must have a leak:-tight barrier for as long as required, ye t Limerick 1 and 2 are likely to fail In an accident.

- During core damage there is only a 50-50 chance of recovery - 50-50 chance vessel will fail

- There is a 75% chance it will not recover. Significant radiation will be released into the environment.

- There is a 90% chance meltdown of core will by-pass the system and bum through seals with catastrophic unfiltered radiation released downwind, Impacting millions of people In a heavily populated region.

NRC estimated necessary design, structure, systems, and components...in violation of system for safety.

For further explanation or clarlfica~on refer to the June, 2014 testimony to NRC of Paul Gunter, (Beyond Nuclear) regarding Limerick's 2nd Environmental Impact Statement public hearing

Limerick's Reactors Vibrate Too Excessively During Routine Operations Limerick's reactors vibrate too excessively for their design (Wurgassen effect - NR C issued Bulletin 74-14 to all BWR owners)

Containment may fall d8$pite PECO's experimental piping to stablllze the reactors, which may not hold up In an earthquake.

GE Hitachi does not Guarantee Safe Shutdown At Limerick:

GEH repeatedly warned Exelon (2010 and 2011) that Its inherently defective BWRs may not shut down safely ff Limerick ls operating at low power when an earthquake hits.

Fortunately, Limerick was operating at 100% power when the Virginia earthquake impacted Limerick Nuclear Plant.

It is not clear that Exelon has tested both reactors or If testing achieved safe shutdown at all low power increments. NRC has been evasive In its responses about this testing, NRC actually told us they don't see test results unless they asl( for them. How is that possible or protective? Why wouldn't NRC oversee testing and scrutinize results, given the potential consequences of failure?

LIMERJCK'S FUEL POOLS -AT HIGH RISK FOR MELTDOWNS

DANGEROUS UN FIXABLE DESIGN FLAWS: Limerick's Spent Fuel Pools:

- Limerick's spent fuel pools were built on top of Limerick's defective reactors, on top of earthquake fault fractures

- Similar to Fukushlma's, they are highly vulnerable to meltdowns through loss or power and cooling water from earth quake s, Limerick spent fuel pools were built with substandard cement, according to a Bechtel quality assurance engineer on site at the time of the fuel pool cement pour (9-22-11 NRC testimony), He said Limerick's fuel pools have a layer of low-strength sand mix where only the highest quality cement should be.

- Umerick's roof-top fuel poof designs, five stories high, are above and outside the reinforced containment structure for Limerick's reactors. which could result in extremely high radloactJve releases In a meltdown.

Corrosion and Thinning Are Occurring In Limerick's Dangerous Spent Fuel Pools At Rates Up To 10 Times Faster Than Exe Ion's Calculations Predicted (Identified by NRC staff)

NRC documented corrosion, cracking, pitting, and cavitations.

Problems are so severe that on July 20, 2012, NRC staff stated that fo r Exelon to delay coating the thinning fuel pool liners was unacceptable, yet NRC officials Inexplicably caved In and revised NRC 5

years. regulations to allow delayed coating for 11 to 16 years and to go without Inspection for another 10

An Earthquake At Limerick Could Trigger Loss of Cooling Water In Limerick's Spent Fuel Pools Leading To Catastro ph ic Meltdowns:

Leaks in cement holding Limerick's high-level radioactive wastes can be caused by earthquakes.

- Loss of water in Limenck's fuel transporting cooling water to the pools can be caused If pools. an earthquake disturbs underground pipes

- Spent fuel rods could heat up, self-ignite, and bum in an unstoppable fire, leading to meltdowns

Fuel Pools At Limerick Are Densely Over-Packed - Far Beyond Design Capacity, NRC repeatedly failed to exp lain why Limerick's fuel pools contain so much more spent fuel than other older U.S. nuclear plants, including Exelon's TMI and Oyster Creek.

Large volumes (over 6,000 assemblies =1,000 tons), of limerick's highly radioactive wastes (spent fuel triggers rods) in Limerick's meltdowns. fuel pools could release catastrophic amounts of radiation if an earthquake

Limerick's two fuef pools contain more than twice as much spent fuel as 4 fuel pools at Fukushima. (Data From The In stitute for Polty Studies by Bob Alvarez. ' Spam Nuclear Fuel POOis in the U.S.: Reducing lhe Deadly Effects of Stota9e*, Appendbc A: sne Specific Esllmates of Radioactivity In U.S. Spent Fuel Page 26Source: OOE/EIS--0250.

Appendix A. Tables A-7, A-8, A-9. & A-10)

Health and Economic Impacts of Spent Fuel Pool Fires and Meltdowns at Limerick Nuclear Plant An NRC study in 2000 said, wi1h loss of cooling water in fuel poofs, Limerick's fuel rods can heat up, self-Ignite, and bum in an unstoppable fire, causing tens of thousands of deaths up to 500 miles away

- A 2004 Study by Dr. Edwin Lyman, Senior Scientist at the Union of Concerned Scientists, Concluded The Following Heahh Consequences From Fuel Pool Meltdowns/Fires:

As many as 44,000 near-term deaths from acute radiation poisoning 518,000 long term deaths from cancer.

Deaths could occu r among people living as far as 60 miles downwind.

A 2003 study by Dr. Frank. Von Hippe!, Director of Science and Global Security at Princeton University, concluded that a catastrophic spent fuel fire could release a radiation plume that could Metropolitan contaminate 8 to 70 times Region). more land than Chernobyl. (Would Include the entire Philadelphia

A January 2003 study by Dr Gordon Thompson, Di recto, of the Institute for Resource and Security Stud_ies (entiUed "Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security*)

said a nuclear fire in 1 spent fuel pool would release radiation to *render about 95,000 squar~

kilometers of land uninhabitab le," (would cover about 75% of New York State, and segments of NJ and CT.)

STRONGER AND MORE FREQUENT EARTHQUAKES HAVE SHOWN US THE UNEXPECTED CAN AND DOES OCCUR

Fukushima, the worst nuclear disaster in history, shows us that there is no reactor containment If an earthquake triggers a meltdown at GE Bolling Water Reactors llke Fukushima and like Limerick Nuclear Plant.

Fukushima also shows us that Fukushima reactors were supposedly safe and Fukushima had been approved for NRC regulatory controls wjll not prevent a disaster at Limerickrelicensing. The shortly before the disaster.

THE VIRGINIA EARTHQUAKE (8-23--11 ) IMPACTED LIMERICK NUCLEAR PLANT

Thirty the epicenter eight years after of the earthquake in 2011 that Virginia's earthquake fault impacted Limerwas declared ick. incapable by AEC standards, it was at

The fact that the earthquake fault under Limerick was defined exactly the same way is no comfort to our residents. AEC/NRC concluded an earthquake would not happen in the fault under North Anna,

Virginia, but it did.

LIMERICK"S UNDl!RGROUND INf'RASTRUCTURE WAS NOT INSPECTED AnER THE a.

23-11 QUAKE

Earthquakes can trigger meltdowns through loss of water and power as a result of damage and/or leaks in the miles of vital pipes and cables buried under Limerick Nuclear Plant.

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After the 8-23-11 Virginia quake shook the Limerick site, II became clear that there is no real way to inspect the miles of buried pipes and cables under Limerick for damage or leaks from earthquakes.

An Associated Press article revealed that leaks can go undetected for many years at nuclear plants.

Undetected damage and leaks, combined w ith inoperable monitors and guages increase the chance of meltdowns from earthquakes at Limerick.

LIMERICK NUCLEAR PLANT WAS NOT PREPARED FOR THE 8-23-11 VIRGINIA EARTHQUAKE

Despite public assurances from Exelon and the NRC following that earthquake, an NRC email response to us revealed that when the Virginia earthquake hit Limerick, Exelon was not prepared :

Limerick's Unit 1 & 2 seismic monitoring system was inoperable.

> Seismic monitors could not confirm that an earthquake caused shaking in Limerick's control room.

Exelon had to call USGS for confirmation.

NRC issued a non-cited violation to Exelon for a delay caused by Its call to the USGS, referred to In NRC's chart entitled 11NRC Findings for VY 2011 at Limerick Generating Station" as an "Untimely Declaration of Notification of Unusual Event

_Following an Earthquake".

However, Exelon's deceptive Special Report did not reflect problems with Limerick's seismic monitors or the NRC-issued violation. In fact, If one relied on Exelon's report, which also stated that the post.quake seismic walkdowns revealed no damages, It would seem as if Limerick had functioned very well.

Exelon's deceptive report titled, "Voluntary Special Report-Seismic Monitoring Instrumentation Actuation" failed to mentlon:

Limerick's inoperable seismic monitors, or their inability to confirm the earthquake.

Exelon called USGS to confirm the earthquake.

NRC's violation for the time delay was caused by Exelon's call to the USGS.

Limerick's Seismic Monitors Had Been Inoperable For 1 Year and 4 Months Before The Virginia Earthquake

At Least One Monitor Remained Degraded and Inoperable For 4 Months After The Quake, not the one identlfied in Exelon's Special Report, rema ined degraded and inoperable for 4 months after the quake.

NRC's February 27, 2013 Letter Introducing NRC's Audit of Licensee's Management of Regulatory Commitments reveals that Exelon submitted its comm itment to fix Limerick's Inoperable seismic monitors in 2010, Ulen resubmitted the same commitment 2 more times but never followed through.

The audit letter from NRC Informs Exelon that its commitment perform ance "reveals serious, long -standing mismanagement at Limerick Nuclear Plant." (The audit was conducted at NRC headquarters in Rockville, Maryland from June 6, 2012 to January 29, 2013 and covered a three year period. It was based on a sampling of documents supplied by Exe _lon.)

THERE ARE AT LEAST 5 EARTHQUAKE FAUL TS WITHIN 17 MILES OF LIMERICK. ONE, THE RAMAPO FAULT ZONE, IS DECLARED ACTIVE.

LIMERICK WAS IMPACTED BY THE EARTHQUAKE ORIGINATING IN VIRGINIA.

NRC'S 1983 EARTHQUAKE ANALYSIS FOR LIMERICK NUCLEAR PLANT IS NOT ACCURATE AND IS NOT RELEVANT CONSIDERING THE RISKS WE NOW KNOW WE FACE FROM AN EARTHQUAKE AT LIMERICK,

Full and accurate disclosure of an earthquake fault under Limerick Nuc lear Plant's generators end fuel pools has remained hidden from the public until now, AFTER the evidence was located and disdosed by members of the public, not NRC.

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Millions of people live In the Greater Philadelphia Region. Most of us never real!zed we faced such enormous risks from earthquakes related to Limerick Nuclear Plant because the fact that building the nuclear plant over an earthquake fault zone was never disclosed to the public.

In fact, the public appears to have actually been deceived from the beginning. Originally, the public was told that Limerick's earthquake risks were low. In one of Limerick's earliest Safety Analysis Reports, it states under "Seismology" that "the site lies in a region that has experienced a moderate amount of earthquake activity."

In 2008, the USGS updated Its assessment of seismic threats for Limerick, concludlng that because Limerick's earthquake risk was considered low when its construction began, it now needs to be updated in light of new understanding of Increasing earthquake risks.

Clearly, there is NO way to fix the horrific risks that millions of people face from an earthquake Impact at Limerick Nuclear Plant.

THE AGENCY DEFINITION OF THE SANATOGA FAULT UNDER LIMERICK IS NOT VALID:

Thirty eight years after the AEC (now NRC) defined North Anna's 1 million year old fault as not capable, it was at the epicenter of a 5.86 magnitude earthquake that impacted Limerick Nuclear Plant on August 23, 2011.

It is indefensible to continua to claim the fault under Limerick is not capable:

AEC defined the Virginia fault under the North Anna Nuclear Plant in the same way they described the Limerick Nuclear Plant fault under Limerick except:

- The fault under North Anna was described as having shown no displacement in 1 million years.

- The fault under Limerick was described as having shown no dlsplacement In 500,000 years.

It seems clear that the Atomic Energy Commission was determined to allow nuclear plants to be built on top of fault zones in populated areas. But a nuclear plant built over an earthquake fault doesn't make sense, so the In 1974, a Geologic AEC simply Survey was submitted defined the faults under nuclear plants to the Philadelphia as not capable. Electric Company (PECO). It stated

that the (Sanatoga Fault] shears had shown no displacement in 500,000 and therefore was not capable according to AEC (Atomic Energy Commission) standards.

In 1983, the NRC adopted the AEC's definition of Limerick's fault shears, noting that "there were no capable faults in the site area*.

We believe this sequence of events shows that the public statement that "the fault was factored into NRC's 1983 earthquake analysis, is industry-speak for* We get away with constructing nuclear plants on earthquake faults by defining them as not capable.*

THE AECINRC ASSESSMENT THAT A FAULT IS NOT CAPABLE HAS BEEN PROVEN WRONG:

In 2012, Eliza Richardson, a Penn State Geo-expert, said that it's not too surprising that the assessment of the Virginia fault was off: "... while earthquake expertise has value, It Is not a sinecure, either in Virginia or, possibly at Limerick".

Richardson had reviewed PECO's 1974 Geologic Survey map for Limerick and her assessment was thatgoing through there"., if all the features inferred on the map are part of the same fault, "then it would be a pretty big fault

Richardson further explained, referring to Limerick's 1974 map, th'at "the faults on this map are roughly simllar to the one that caused the northern Virginia earthquake. One earthquake of that size does not happen every day. There are 100 places more likely that you would expect to see, but that one happened where no one expected it.*

In 2011, North Anna's fault was at the epicenter of the largest earthquake east of the Rockies since 1897. It was felt all the way to New England.

Twelve miles from the 5.86 epicenter, 25 of North Anna's 115-ton spent fuel casks were shifted by the quake.

- The quake caused cracks in the reactor containment building.

The Washington Monument, 90 miles from the epicenter, was cracked by the Virginia quake and closed to the public for assessment.

Concerns have risen about leaks in the miles of undetectable underground pipes and cables at North Anna and Limerick.

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NRC HAS INACCURATELY CLAIMED THAT LIMERICK'S EARTHQUAKE RISKS WERE ORIGINALLY FACTORED INTO LIMERICK'S LICENSE.

NRC's adoption of the 1974 AEC definition of earthquake faults not being capable benefits only the nuclear Industry, no t the ov er 8 million people living within 50 miles of Limerick Nuclear Plant.

THE PROOF THAT LIMERICK'S EARTHQUAKE RISKS WERE NOT FACTORED IN, IS THAT LIMERICK'S REACTOR COMPONENTS ARRIVED AT THE LIMERICK SITE IN 1972, TWO YEARS BEFORE LIMERICK'S GEOLOGIC SURVEY WAS SUBMITTED IN 1974.

- In 1972, the Atomic Energy Commission (AEC) issued Limerick's construction permit, a 90-wheel truck carried the first component of PECO's defectively designed GE Mark II Boillng Water Reactor onto PECO's Limerick Nuclear Plant site, accompanied by a police escort.

- In 1972 when Limeric!{'s Draft EIS was released by AEC, the AEC staled that ii did not abandon the location for Limerick Nuclear Plant in favor of an alternative site because it would cost too much money.

- (See Attachmen1)

- The 1972 Draft EIS for Limerick-Page 2-16, Section 2.4.2, "Regional Geology and Assessment of Possible Earthquak e Hazard", exposes faults near and far away from Limerick, but it fails to disclose the Sanatoga Fault and Zone under Limerick or the Ramapo Fault Zone, 17 miles away.

AEC's 1972 Draft EIS for Limerick Nuclear Plant seemed to dellberately downplay earthquake risks at the Limerick site, by eliminating any mentlon of the Sanatoga Fault.

By mat c hing the 1972 Bech tel Report photographs with Its diagrams, the report shows that as early as 1973 Bechtel was flllfng in Sanatoga Fault frachlres with cement to prepare the site for the construction of the plant

P ICTURES SHOW FAULT FRACTURES UNDER LIMERICK BEING FILLED IN WITH CEMENT IN 1973, ONE YEAR BEFORE LIMERICK'S GEOLOGIC SURVEY WAS SUBMI TTED IN 1974

CONSEQUENCES: LIMERICK'S TWO JNHERENTL Y DEFECTIVE, SEISMICALLY CHALLENGED NUCLEAR REACTORS ARE LOCATED ON A FAULT WHERE EARTHQUAKE RISKS WERE SERIOUSLY UNDEREST IMATED

THE FOLLOWING TIMELINE TELLS THE STORY OF A "CART BEFORE THE HORSE" CHECKLIST MENTAJL TY :

- On November 15, 1972, the first reactor component arrived at the Limerick site aboard a 90-wheel truck, two years before Limerick's seismic study was submitted.

In 1973, before It had a construction permit from the AEC/NRC, Bechtel was filling in Sanatoga fault fractures with "dental concrete".

On June 191 1974: The Atomic Energy Commission IAEC - now NRC) issued a construction permit for Limerick Nuclear Plant On July 30, 1974: The Geologic Survey was submitted to PECO.

On September 3, 197 4: Bechtel Power Corporation submitted its report on its treatment of Sanatoga Fault zone fractures.

WE FACE UNACCEPTABLE, UNFIXABLE RISKS FROM THE ORIGINAL NEGLIGENT DECISION TO ALLOW LIMERICK NUCLEAR PLANTS REACTORS, FUEL POOLS. AND OTHER BUILDINGS TO BE BUil T ON TOP OF AN EARTHQUAKE FAULT.

This clearly unfixable threat to the health, safety, and financial interests of millions of people in the entire Greater Phlladelphla Region is the result of a 9

predictable decades old AEC/NRC mentality and pattern of putting the "cart before the horse".

NRC ATTEMPTED TO HIDE THE TRUTH FROM THE PUBLIC ABOUT THE SANATOGA FAULT NRC FAILED TO PROVIDE FULL AND ACCURATE DISCLOSURE ABOUT THE EARTHQUAKE FAULT UNDER LIMERICK, BY LYING TO THE PUBLIC BY OMISSION

NRC first refused to respond to a local concerned mother for four months about the closest earthquake fault to Limerick. When NRC finally responded 4 months later, they lied by omission.

May, 2011, after Fukushima, she asked about the nearest earthquake fault to Limerick.

NRC failed to respond for four months

At NRC's September, 2011 EIS hearing, the resident repeated her request.

October 2011, the resident finally received a response letter dated September 26, 2011 from Andrew Rosebrook, Senior Projects Engineer for Limerick.

- His of the response to the PA-NJ area. question about the closest fault to Limerick Nuc lear Plant Included a fault map

- His stated explanatory letter included the Hopewell focused on the and Flemington Ramapo and Chalfont faults, highlighted faults, on the 9 and 17 PA/NJ m!les map the away, which, he fault zones

in yellow and orange.

NRC Lied by Omission About The Closest Earthquake Fault To Limerick Nuclear Plant by not identifying the Sanatoga Fault directly under the Limerick site

Later, we discovered PE's 1974 Geologic Survey map at the local library showing the Sanatoga Fault under the Limerick site. At NRC's 4 12 Annual Limerick Assessment Meeting, we showed NRG officials the map showing the Sanatoga Fault under the Limerick site.

NRC Officials Denied Knowled ge About the Earthquake Fault Under Limerick

- Andrew Rosebrook, Senior letter and map to the resident), Projects Paul Krohn, Chief Engineer for limerick Branch 4 Reactor Projects, (the NRC official who sent Region 1, the

and both site inspectors acted surprised that there was an earthquake fault under the Limerick site.

- First, Paul Krohn acted like he had never seen the fault before and denied knowledge of

- Mrthe. Rosebrook also denied Sanatoga Fault, referring knowledge of us to Mr. Rosebrook. the Sanatoga Fault or PE's 1974 Geologic

Survey

NRC claimed that the Sanatoga Fault under the Limerick site was factored into Limerick's earthquake risk.

- Despite these officials' denials to residents, the NRC's public printed statement in Evan Brandt's 5-20-12 massive article on the Sanatoga Fault under limerick, was that the fault had been factored into its original 1983 earthquake analysis prior to limerick licensing.

On February 18, 2014, we, as ACE researchers, returned to the library for further investigation and discovered a report showing the position of Earthquake Fault Zone Fractures Directly Under Limerick's Reactors, Fuel Pools, Control Room, Turbine Building, and Rad-Waste Building (Spent fuel pools on top of reactors are not shown)

NRC Failed to Publicly Disclose This Alarming Information, in even three years after Fukushima and the 2011 earthquake in Virginia.

Background:

- Having lived in the area when controversy over Limerick nuclear plant's construction began, we had heard rumors of an earthquake fault where the Limerick site was to be built.

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- After seeing the resident's map, we went to the Pottstown Library to look for more precise infonnation. Our search led us to the Dames and Moore Geologic Survey submitted to PECO in

- The following 1974, which contained a map showing the spring, we took a copy of the Sanatoga Fault map to a 2012 NRC public meeting. running through the Limerick site.

- We showed it knew nothing about the to NRC's Limerick fault under the Branch Chief Limerick at the site. time, Paul Krohn, who a.cted as though he

- February, 2014 we returned to the library and we were shocked to discover a report that shows that both of Limerick Nuclear Plant's GE Mark II Boiling Water Reactors are built on top of fault fractures, portions of which were filled in with cement, as early as 1973. ("Report on Treatment of Fracture Zones for PECO by Bechtel Power Company, 1974" Including photographs and diagrams).

It is alarming to know that Limerick's spent fuel pools, built on top of Limerick's reactors, are also on top of earthquake fault fractures that could trigger multiple meltdowns.

- It Is worrisome to know that other Limerick buildings are over fault fractures, including the control room, turbine building and radwaste storage building.

- Perpendicular to the exposed horizontal fault zone fractures, are fracture fingers extending down Into the earth, ranging in width from an inch to two feet wide, no one knows how far.

After two years of public concem, questions, and research, residents' confirmed that

~ere is an earthquake fault directly under the Limerick site, filled in, in places, with cement, and that right on top of that is built the Limerick Nuclear plant, and at least 4 other earthquake faults within 17 miles of the Limerick site.

NRC HAD TO HAVE KNOWN ABOUT THE EARTHQUAKE FAULT UNDER LIMERICK NUCLEAR PLANT, YET NRC OFFICIALS FAILED TO ACT WITH TRANSPARENCY

In response to PECO/Exelon's application for an operating license, In August 1983 NRC issued its Safety Evaluation Report (SER). On page "2-44" NRC mentions its earthquake risk analysis performed accordance with NUREG-0991.

NRC notes that and yet downplays Limerick's 3 faults have been mapped 'and investigated earthquake risks. within 2 miles of the Limerick site,

NRC IS AWARE OF INCREASED EARTHQUAKE PROBLEMS AND LACK OF SAFEGUARDS, YET, NRC ILLOGICALLY WEAKENED EARTHQUAKE RECOMMENDATIONS OF THE FUKUSHIMA TASK FORCE.

The Associated Press released a report on its 11,000-page records-request, that reveals the NRC's concern, yet to date the NRC has taken no meaningful action to reduce earthquake risks at U.S. nuclear plants.

NRC ISSUED ITS ILLOGICAL DETERMINATION NOT TO HARDEN LIMERICK NUCLEAR PLANT OR ANY OTHERS AGAINST EARTHQUAKES, EVEN DISMISSING THE USGS FINDINGS THAT "FRACKING" CAN TRIGGER EARTHQUAKES.

The AP records request exposed NRC concerns about the risk at nuclear plants from fracking triggering earthquakes, yet NRC used the flawed rationale that *u.s. Plants can stand multiple earthquakes weaker than they were designed for" (5/ 20/12), Mercury, Evan Brandt: * 'Fracking' Quakes Not a Factor for NRC in Nuke Plant Licensing").

Evidence showa that "Fracking" can cause earthquakes, yet NRC has declared that it won't be considering "Fracklng" in relicensing Umerick.

approved. By 2007, PA approved over 4,200 natural gas wells for tracking. Since then, many others were

Nearby states like Ohio and New York are also tracking, USGS confirmed that many Ohio earthquakes were due to tracking.

USGS has also determined that Limerick is in an active earthquake fault zone.

- There is an earthquake fault under limerick. At least 4 other earthquake faults are within 17 miles of Limerick. The one just 9 miles away is considered active.

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IT IS ILLOGICAL AND UNACCEPTABLE FOR NRC TO CLAIM THAT LIMERICK MEETS ALL SEISMIC REQUIREMENTS IMPOSED BY NRC WHEN NRC REQUIREMENTS HAVE BEEN WEAKENED TO THE POINT OF BEING UNPROTECTIVE OF PUBLIC SAFETY.

Limerick sits on the brink of disaster while NRC, the agency that has the power to intervene, has denied and dismissed extraordinary risks to benefit industry.

Despite stronger and more frequent unpredictable earthquakes, and the fact that the 8-23-11 earthquake actually jolted Limerick Nuclear Plant, NRC is falling to acknowledge the reality of the potential for multiple meltdowns from Limerick's extraordinary earthquake risks. Even after the catastrophic multiple meltdowns at Fukushima, the NRC stlll failed to fully disclose, much less address, the fact that Limerick Nuclear Plant was built on fault zone fractures.

Instead of working to effect precaution and prevention, NRC officials tried to deceive residents about Limerick's increased earthquake risks. NRC officials for limerick have tarnished the mission statement of the NRC by being deceptive and dismissive of our concerns about limerick's increased earthquake risks.

Limerick's escalated earthquake risk cannot be evaluated In the neat and tidy illustration of risk assessment in NRC's "parachutist scenario" of NUREG 2122, which asserts *no special risk knowledge is presumed... a basic understanding of nuclear &afety is assumed," to Illustrate risk methodology.

NRC operations began the year after the notorious Atomic Energy Commission issued Limerick's construction permit in 1974. The AEC was disbanded that same year due to protests over its controversial decisions, as both regulator and promoter of nuclear energy plants. The NRC, created from Its ashes, was supposed to regulate on behalf of publ ic safety and the environment.

The AEC's original regulations would not have allowed the use of GE's Mark II Boiling Water Reactors, because contain ment Is not guaranteed. NRC's regulations, as they were written originally, would not have allowed the construction of a nuclear power plant on the Limerick site due to an evacuation zone that was double the population density for safe evacuation.

Fred Bower, NRC Chief Branch 4, has infonned us bye-mall 10-23-13 that seismic reports by Exelon for Limerick Nuclear Plant have satisfied the NRC and so no further audit is necessary in tenns of seismic walkdowns.

Mr. Bower said Limerick was not selected to be audited by the Japan's Lessons Learned seismic walkdown, because Exelon's seismic report satisfied NRC's criteria..

PROBLEM: NRC Is Still Using Inaccurate Prediction Models For Limerick's Earthquake Risks, Based On Decades Old Flawed Assumptions Of Risk.

PROBLEM: Exelon's biased, self-serving seismic report for Limerick Nuclear Plant should not have been used to dismiss actual enormous seismic risk. The original intent of the post-Fukushima earthquake assessment has been diluted and, because it contains no requirement of proof that what is reported by Exelon is true, it is as good as no assessment at all. Exelon controls Limerick's maintenance, testing, reporting, and data. NRC doesn't see anything that Exelon doesn't want it to see.

PROBLEM: NRC's com pliance standards are obviousl y far too low when they can exclude a nuclear plant with the extraordina ry seismic risks at limerick Nuclear Plant.

Fred Bower absurdly claimed that Limerick was not a nuclear plant that represented a higher than average seismic risk

NRC's WILLFUL BLINDNESS TO EXTRAORDINARY EARTHQUAKE RISKS AT LIMERICK NUCLEAR PLANT HAS BEEN, AND CONTINUES TO BE, UNACCEPTABLE AND UNPROTECTIVE.

NRC originally wrote off *~tuai risks from building Limorick Nuclear Plant's vital Infrastructure over an earthquake fault by declaring that fault (Sanatoga Fault) Incapable.

Bechtel, the company that built Limerick, was actually fining In portions of the fault zone fractures at Limerick with cement, a year before Limerick's geologic survey was submitted.

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Errors made during Limerick construction were overlooked, intensifying the risks from today's stronger and more frequent earthquakes.

Unfortunately, It Appears NRC Has Learned NO Lessons from the Fukushima Disaster.

Even as the crisis of Fukushima continues uncontrolled, the NRC's response is to double down, making access harder to acquire or to dismiss the evidence, by saying "we factored it in", or "we have redundant safety systems", or the design basis "has an adequate margin" with no proof that such terminology is anything more than a cloaking device for, 'We're dismissing that because meaningful requirements would oblige licensees to spend money.

There are many similarities between what caused the Fukushima meltdowns and the potential for disaster at Limerick. TEPCO had too coz.y a relationship with Japan's Nuclear Regulation Authority (NRA). The same can be said of Exelon and the NRC.

TEPCO and Japan's NRA ignored expert advice against building a nuclear reactor on an unsuitable site. Japan had a history of cyclical, predictable tsunamis and earthquakes on Fukushima's coast. But common sense was no match for the promise of the money to be made.

The same potential for disaster exists at Limerick. Like TEPCO and the NRA, PECO and the NRC were warned repeatedly before Limerick was licensed, that Limerick was an unsuitable site for a nuclear plant.

Public Safety Has Been, And Continues To Be, Ignored By NRC, Even When Challenged.

A nine year legal action against Limerick over safety was fought and won in the 3rd circuit court of appeals in 1989, but it was too late to protect the public. Both Limerick units were already operating by 1989.

The National Resources Defense Council's request to have Limerick's Severe Accident Mitigation Alternatives updated was approved, but challenged by Exelon. N~C joined Exelon in the challenge, instead of protecting public interests.

Requests to update Limerick's unprotective1974 Atomic Energy Commission definition of earthquake fault capability based on Appalachian experts and staff have been ignored.

Limerick Falls The Most Rudimentary Tests For Safety. Public Interests Have Been Abandoned From The Start If AEC/NRC Had Adhered To Its Regulations In The Beginning, MIiiions Of People In The Greater Philadelphia Region Wouldn't Face Such Risk From Limerick Nuclear Plant Today:

The Sanatoga Fault runs under the limerick Nuclear Plant site A blasting quarry shares Limerick nuclear plant's border Both GE Mark II Boiling Water Reactors could breach In an accident due to substandard design.

The population density in 1980, was double the size that could be safely be evacuated in case of an accident.

Limerick's extraordinary threats to public drinking water were well known in 1980. There was not enough water in the Schuylkill River to sustain Limerick Nuclear Plant operations. The health threats from decades of routine radioactive releases into a vital drinking water source for vast numbers of people were overlooked.

A Major Concern Defined by Former NRC Secretary Jaczko on "Frontline" Shows Why Limerick's Risks Need To Be Re-Evaluated.

Former NRC chairman Gregory Jaczko told FRONTLINE in January 2012: "Invariably, I think right now the kinds of situations in which you (have] accidents are going to be those in which has happened that you haven't necessarily thought about or you misunderstood, or you misanalyzed, or you just missed."

That is exactly the problem and concern related to Limerick's earthquake risks.

The Consequences Of Limerick Meltdowns Triggered By An Earthquake Would Be Catastrophic To Public Health, Safety, and Financial Interests.

Unfortunately, the public will suffer from a Limerick disaster, not Exelon or its stockholders.

In 2013, Naoto Kan, Japan's former prime minister when the Fukushima disaster started, said,

... no other accident or disaster" other than a nuclear plant disaster can "affect 50 million people... no other disaster "could cause such a tragedy" He further said, that "without nuclear power plants we can absolutely provide the energy to meet our demands... ~ could generate all our energy through renewable energy.* ("Counterpunch", March 3, 2014)

WHY LIMERICK SHOULD BE CLOSED DUE TO NEWLY-FOUND EVIDENCE OF EARTHQUAKE FAULT FRACTURES UNDER LIMERICK'S VITAL INFRASTRUCTURE:

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L~MERICK'S RIS KS F ROM EARTHQUAKES ARE EXTRAORDINA R Y Structural deficiencies that ca n be destablflzed by an earthquake, were created by errors, failures, and non-complia n ces during Limerick cons truction. These cannot be fixed now.

USGS said Limerick is in an ac tive earthquake zone.

Limerick, ln add ition one declared to the earthquake faull active. under Limerick, there are a t least four other faults within 17 miles of

Limerick Nu clear Plant was impacted by the 8/23/11 Virginia earthquake. That Is a fact that is now pa rt of Limerick's historical recor d. And Exe lon was not prepared. That too, Is a fad in the historical record.

- Massive tracking in PA and nearby states has increased the risk of triggering earthquakes.

- Earthquakes can undermine plant stability by disturbing the impossible to Inspect miles of b u ried pipes and cables unde r Limerick vital to supplying power and water n eeded to prevent mult!ple meltdowns at Limerick.

SAFE EVACUATION IS IMPOSSIBLE!

It is impossible to safely evacuate this densely populated Greater Philadelphia Region. In 1980 NRC knew there was double the population density tha n could safiely evacuate a 30-mile radius. Now there are at least four times that number.

Over 8 million people now live within 50 miles of Limerick Nuclear Plant.

regarding Everything Limerick's these people increased earthquake risksneed to suNive may hang In the. balance of what the NRC does or does not do

siMillions tes of people could lose everything - Health, homes, (anns, bus inesses, schools, and historical

- Air and water (possibly within 100 miles) would become too radioactive for exposure from Limerick's me ltdown releases, Drinking water su pplies and a safe food supply hang in the ba lance of NRC's decision about what to do about Llmerick's increased ear1hquake risks.

CONCLUSION:

Limerick Nuclear Plant's Reactors and Spent Fuel Pools Were Built Directly On Top of Earthquake Fault Fractures.

No NRC study or regulation can remove the extraordinary earthquake risks at Limerick Nuclear Plant.

Seismic walkdown audits performed by Exelon, the company with a vested interest In the outcome 1 mean nothing at Umerick, It Is clear that Limerick's Inherent design flaws, plus construction errors, failures, and non-conformances Increase Limerick's vulnerability to seismic events, large or small.

You could prevent unnecessary catastrophic health and economic consequences that would follow meltdowns triggered by an earthquake at Limerick Nuclear Plant, Right now, over 8 million people w ithin 50 miles of Limerick are counting on NRC to protect them. NRC's mission statement creates the impression that people are protected by NRC regulations, bu t to date, that is not happening,

To protect the million s of people In the Greater Philadelphia Region, we urge you to use the full power of your position to take these unprecedented and Imperative actions to prevent catastrophic and unnecessary disaster at Limerick Nuclear Plant :

1. Revoke Limer ick Nuclear Plant's Op e rating License Immediately.

2. Require Exelon To Remove Umerick's Deadly Radioactive Wastes From L imerick's Spent Fuel Pools As Soon A s Safely Possible.

3. Require Exelon To Harden On..Site Above-Ground Cask Storage For Wastes Removed From Limerick's Fuel Pools.

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We request that this communication, including all attachments, be placed in NRC's record and posted on NRC's website. Please inform us of the ADAMS location when it is posted.

Thank you in advance, Betty and Charlie Shank, ACE Research Assistants Alliance For A Clean Environment (ACE) 1189 Foxview Road Pottstown, PA 19465 (610) 326-2387 aceactivists@comcast.net

CC U.S. Senator Casey U.S. Senator Toomey U.S. Senator Boxer U.S. Senator Markey U.S. Senator Sanders NRDC NIRS Beyond Nuclear Radiation and Public Health Project Pottstown Mercury Philadelphla Inquirer L IMERICK'S EARTHQUA K E RIS KS CAN 'T BE ELI MINATED

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.... Limerick nuke pla ~t should be ~hut down ro O* 0 Gl 'ti :&

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~ - ~ :t: @ QI 0. = 0 ** Exelon is considering closing some of toting system, but never did. Inoperable

~ **""' its nuclear plants early. Limerick should on Aug. 23, 2011, Limerick's seismic

.a ro 2: =-=~ 0-be near the top of the list for nuclear monitors

could not confirm the quake.

C/l_ plants to be closed.

Exelon had to call the.USGS to confirm E i~ I.)

""' Last month, we found Bechtel's 1974 the quake. NRC ~ited Exeion with a viola

~ -~ report on the '.'Treatment of

Fracture tion.

Zones" at Limerick. A diagram shows Incredibly, Exelon created a contra Sanatoga Fault zone fractures running dietary report claiming that Limerick's directly under a. L4Jierick icactor. Pho-seismic 'monitc,>rs worked as soon as vibra tos show portions of the fault being filled tions.were felt in the control room.. ;

-with cement to level the surface so the Additionally, GE Hitachi repeatedly plant could be buill on top.. warned Limodck to test its GE Mark II

0the fact that Limerick is third on the na-fail to shijt down safely if Limerick's.risks aren ' t just limited to Boiling Water Reactors becituse they may '

running at low tion's earthquake risk list and. has the sec-. power: when a quake hits. Fortunately, ond-most populated evacuation zone

in Limerick Units 1 and 2 were operating the nation. Yet, NRC bas refused requests at 100 percent power when the Virginia to update Limerick' s outdat~d earthquake quake.hit Limerick:..

.. analysis, clinging fo its

Our risks ~e multiplied by NRC's 1983-stance based on ----- refusal to inspect *any Limerick under-40-year-old information*

Gu~ st ground infrastructure. NRG is relying on from a time when earth-Columni st

Lll1].erick's gauges and monitors to reveal E quake risks were less problems in the miles of' neaily 30-year-0 <.> understood, less frequent and less severe. old inaccessible* buried pipes,-and cables e In 2011, NRC lied by oprission when. under the Limerick site..., *,

Cl)

E *it provided a resident with a map which * -An AP report reveals that undergrouncl

~ showed only off-site faults and _that fail~ - leaks can go**unde'tected at nuclear plants 0 to include the fault under Limerick.

for years before discovery. Worse,. NRC It *wasn't until 2012;; after residents Safety* Reports ** show 'tb.at,.iii addition i showed NRC officials Limerick's 1974. to Limerick's -inoperab~e seismic moni Geologic.Surve'y map illustrating tb,e San-

tors, many viplations at Limerick have atoga Fault running under the Limerick

steIIllI).ed. from other monitors a>>d sys-.

site, that NRC officials finally acknowl-terns also inoperable foi years before they edged its existence. ~ Then NRC claimed were discovered.

the fault had been factored into its 1983 In.short, ho)low assurances from Ex*.*

earthquake analysis. If ~o. why did NRC elon and

NRC have not, and cannot, fix omit the fault under Ltmerick from the Lime~ick's increasing. tlµ:eats to. public map it sent to the resident? *

safety. Even fracking in Pennsylvania and A Pen,n State Geo-expert who reviewed its adjoining states a(lds to Lup.erick's the 1974 Geologic Surv~y map saw in,dica-earthquake risk.

tions that the fault 'Ullder Li.n:ierick could

On!'* reason Exelon cites for early nu- *.

'be pretty big. She suggested that a more clear plant closure is political support.

accurate picture of what's going on down (Cooper report July 17, 2013 and Mercu theie is possible using new equipment, ry July 19, 2013.) Our politicians should but it wouldn't be *free (Mercury May 20, speak up now to close Limerick Nuclear 2012). To date, it hasn't been don~. * *

Plant early to protect the safety_ and ~o-

Limerick's overloaded f\\lel pools, stor-nomic future of the Greater Philadel.i>llia ing hi8h-level radioactiv e wastes, sitting Region..

on top of Limerick's reactors, which stt For more information see www.acere on top of fault fractures, present an enor-port.org : Sec.tion *11 "Earthquake Risks."

mous potential for catastrophe. *

For political contact n,.formation, see

-~ u Of major concern, Limerick's seismic "Recent Posts" - Video Blog, "Elected Of a:: monitors were inopc;rable wlien the Aug. ficials Must 'rue Action." Contact elect-WI 23; 2011 Vuginia earthquake shook Lim-ed officials t0d,ay.

~ eric.k Nuclear Plant. For a year an*d four..

LU

.... :I: months before.the quake, ~elon had

BETTY.and CHARLIE SHANK

....... been promising to fix the seismic i:no~- Pottstown **

CD cc

ATTACHMENT FOR ACE 3-31-14 LETTER TO NRC CHAIRMAN ALLISON MACFARLANE

LIMERICK NUCLEAR PLANT MUST CLOSE!

IT CAN'T BE MADE SAFE!

LIMERICK'S REACTORS AND FUEL POOLS ARE BUil T ON TOP OF AN EARTHQUAKE FAULT ZONE THERE IS NO WAY TO FIX THIS!

CONTENTS OF THIS PACKET Evidence That Sho w s That Limerick Nuclear Plant's Reactors and Spent Fuel Pools Were Built Directly On Top of Earthquake Fault Fractures.

ATTACHED PHOTOGRAPHS AND DIAGflAMS ARE FROM:

The 1974 report for Limerick Nuclear Plant titled: "Report on Treatment of Fracture Zones for PECO by Bechtel Power Company", Showing That Fault Fractures Under Limerick Were So Big They Decided To Fill Them In With Cement In Order To Construct Limerick Buildings On Top Of The Fractures

Bechtel's September 3, 1974 Report Reveals That Limerick Nuclear Plant"s Buildings Were Built Directly ON TOP Of Earthquake Fault Fractures:

(1) Reactors [Plus Spent Fuel Pools]

(2) Control Room (3) Turbine Building (4) Rad-Waste Building

Photographs And Diagrams From The 1974 Report:

1. Copy of Bechtel's 197 4 Report Cover

2. Photograph

A fault zone fracture filled with cement that supports a column for Limerick Unit 2 reactor

3. Photograph - A fault zone fracture after it was filled in with cement (called dental concrete) in 1973, BEFORE Limerick's Geologica l Survey was completed in 1974

4. Photograph - A fault zone fracture being filled with cement directly under the support wall between the control room and turbine building

5. Photograph - A fault zone fracture directly under Limerick Unit 1 reactor

6. Diagram

The location of Limerick Nuclear Plant buildings and their position over the fault zone fractures

7. Diagram -The location of fault fractures and their position under Limerick Nuclear Pla*nt buildings

8. Diagram

Showing fracture fingers extending from the horizontal surface fractures into the earth: no one knows how far down they go

NOTE: Spent fuel pools are not shown in the diagram, since Limerick is a GE Mark II BWR design, with its fuel pools built on top of its reactors.

REPORT -

ON

TREATMENT OF FRACTURE ZONES

AT

LIMERICK GENERATING STATION

FOR

PHILADELPHIA ELECTRIC COMPANY

BY

BECHTEL POWER CORPORATION

JOB 8031

September 3, 1974 This-ls A Fault Zone Fracture Filled With C~ment That.Supports A Column For Limerick Unit 2 Reactor

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Was Completed In 1974 '

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'n' concrete was placed in the treated zone on August. 10, 1973.

shows the *zone after being filled with concrete.

This Is Part Of The Fault Zone Fracture Under Limerick Unit 1 Reactor

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- tt.a ACE Clarlflcatlon: UMEIUCIC OEHERATING STATION UIITS I AND I SECTIONS Fracture Fingers PRl!LIMJWtY SAFETY ANAL'IIIS R!:POftTS

-TMElff OF ZONE & Extend Down From AT *,1* LINE Horizontal Fractures TREATMENT OF FRACTURE ZONE A

l'IQ\\/III! I ATTACHMENT FOR ACE 3-31-14 LETTER TO NRC CHAIRMAN ALLISON MACFARLANE

Attached Documents Show That N RC Lied by Omission About The Closest Earthquake Fault To Limerick Nuclear Plant

NRC did not respond to a local concerned mother for four months about the closest earthquake fault to Limerick. When NRC finally responded, NRC lied by omission:

In May, 2011, after Fukushima, Lorraine Ruppe, a resident asked about the nearest earthquake fault to Limerick.

On September 22, 2011, at NRC's EIS hearing, the resident repeated her request.

In October, 2011, the resident finally received a letter dated September 26, 2011, from Andrew Rosebrook, Senior Projects Engineer for Limerick.

- His response to the question about the closest fault to Limerick Nuclear Plant, included a fault map of the PA-NJ area.

- His explanation focused on the Ramapo and Chalfont faults, 9 and 17 miles away, which, he stated included the Hopewell and Flemington faults. Highlighted on the PA/NJ map the fault zones in yellow and orange were the faults 9 and 17 miles from Limerick. He failed to mention the Sanatoga Fault under the Limerick site.

CONTENTS:

1. Deceptive NRC map omitting the Sanatoga Fault under the Limerick site

2. Deceptive NRC letter omitting the Sanatoga Fault from the description of the closest faults to Limerick

3. 1974 map showing Limerick Nuclear Plant sits on the Santoga Fault

4. 1974 map as it originally appeared in the Dames & Moore Geologic Survey

5. Copy of cover of Geologic Report submitted to Philadelphia Electric Company in 1974, discovered by local residents in the local library

6. Copy of Lorraine Ruppe's letter to the editor expressing concer n over Limerick's drastically higher earthquake risks

7. Copy of Lorraine Ruppe's letter to the editor expressing concern over NRC's failure to require immediate expansion of Limerick's evacuation zone relative to increased earthquake risks.

8. Copy of Charlie and Betty Shank's letter to the editor expressing concerns over NRC's stance minimizing Limerick's earthquake risks.

9. Copy of satellite map showing the Limerick site on the Schuylkill River and the adjacent active quarry

NRC HAS KNOWN ABOUT THE EARTHQUAKE FAULT UNDER LIMERICK NUCLEAR PLANT, YET NRC OFFICIALS FAILED TO ACT WITH TRANSPARENCY

NRC IS AWARE OF INCREASED EARTHQUAKE PROBLEMS AND LACK OF SAFEGUARDS, YET, NRC ILLOGICALLY WEAKENED EARTHQUAKE RECOMMENDATIONS OF THE FUKUSHIMA TASK FORCE.

This Is The Deceptive Map, Sent By Mr. Rosebrook, NRC, To A Resident Who Wanted T o Know T he Closest Fault To Limeric k, \\

OMITTING THE SANATOGA FAUL T UNDER LI M ERICK

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EXPLANAJIQN 11 L-,_J Ntworlc*Gttty1bur; Satin ArH unclerlaln by Trla11lc roc:111 of.

.$, Mopptd Faults I tw,t u111ptclflld ),

-- Boundary of Coaatol PIOln Hdlmtnll

ALLI NSYLVANIA : ' ~ Location of 9tologtc sae1lon tllawn In FIOlll't 2,!!5*3, R <LM *,d* F ** 'I I

..,.. ;,.. _ Fi11 / {- Jllt4w11, h 1(:'~'/'.,:.":.*'i>aili *soujco :-Trloulc ba.ln ond I, ouaclattd tou1t1 from Folll (1973) fn P1nn1y1vanla Dnd from 01atnll9801 4nd 1t01c:11tr1(19801 In Ntw Jttny..

41'* Other foutt1 In PtnnsylvonfQ from Ptnna.

Gtol.Survty 1111ft gtol09lc IMP 1

( Mop No. I I l971S, 1980)

MARYLAND 0 2.5 Mllu f

I LIMIIIICIC Ufffl'lt 4181111ATIIIICI MOJ ITATION

\\DELAWJ Ul'Of<TID PINAL IAjiffi ANAl.7111 WOflr

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UNfTED STATES NUCLEAR REGULATORY COMMISSION REGIONI *...

. 475 ALLENDALE ROAl>.

KING OF PRUSSlA,, PENNSYLVANIA 19406-1415

Septembe~ 26. 2011

Lorraine Ruppe 2120 Buchert Road Apartment# 20

_Pottstown, PA 19464

Mrs. Ruppe :

This letter is respof1:5e to a question you brought ui:i to Nicole *sieller, the NRC Resident Inspector at theUmeri.ck Generating Station daring~ September~ Umerick Ueen~

Renewal Meeting co~ming the location of the ~apo.fautt an~ how close it comes to the Limerick Generatitig*~on. I spoke with you on Friday September~ on the phone and ~m.

sending you ;a cop9 a Geologic structure Map from.the Limerick Updated Final Safety Analysis * -

Report which musi:tates ttie Ramapo Fault and other-known.fault lines*Jn the PA-NJ area I

1 highlighted the Ramapo Fault.itself in Yellow {Note ~ -fault is non contiguous on the western side} and the RaJnapo 'fautt network in 0~. which -i&luc.tes the Chalfont, HopeweD, and Flemington f'autts which. branch otl-ffle RarnapQ Fault. The Chalfont Fautt is approximately 9 miles from Limerick to the *~ '*The*Ramapo Fault itself is approximately 17 miles from Limerick to the ~ near Reading......

I hope 1his a~ your.questiort. Feel free to contact me at 61~337-5199 or Andrew.Rosebrook @NRC.go v if you have any adcfl_tional ques1ions or concerns.

Respectfully,

,,. // ~

Andrew A Rosebrook Senior Project Engineer U$NRC, Region I

Enclosure:

Geologic ~re. Vicinity of Newark-Gettysburg Basin.

~.~~!

'J'.-=--- NUCLEAR PIANT Srrs ON SANATOGA FAULT f.' cj/:l'4;_:§;g

-~ V - ~

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Earthquake risks ~t Llm.erjck.are too high On.Nov. 9, 2011, 'Vaughn Shirey re-pollu~ers like Exelo!i..

sponded to my concerns over drastically The more we learn about earthquake higher earthquake ris~ than first thought. risk at Lunerick Nuclear Plant, the more

at Limerick Nuclear Power.Plant. He* re-worried i become.*As :we *saw iri Japan, jecte4 inf orma:P,on. from the most recent earthquakes can lead to a loss of water study on earthquake risk reported in the and meltdowns in fuel pools and genera-J. Me,rcury and inform~tioi;i f~om a Nuclear tors... * *...

Regulatory Commission meeting I at-.

1. Limerick is third on the earthquake tended in' May 2011: He denies a logical risk list. :. \\, :

link between Limerick's radiation *releas-2: Two fault lines are far too close to

.es. since Limerick-rull'ted.

Guest Limerick--Just nine and 17 miles awa~.

operating ~~ ~kyrocket- *, Columnist 3. The *Aug. 23, 2011 earthquake 'hi ing cancer rates; ', ----- Virginia jolted our r~gion. Limerick was

. On_ Jan. 1 Shirey responded. to my. forced to check for dam.age.

re~ponJ:;e. JD.stead of further addressing

4. A key Limerick "safety mechanism" recent.issues on earthquake 'risks, he at-might not be able to shut down aft.er an tac~ed my cre~bility.

It seems I hit a earthquake.

nerve observing that he was uninformed 5. A quality assurance engineer testi on the

latest government and indepen-fled Sept 22, 2011 that he was concerned dent earthquake news and reports. about earthquakes becau.se he saw sub-

.Unfo~tely, Vaughn Shirey's agenda standard cement used in construction of appears cfitical rather than inquisitive. Limerick' s fuel pools that hold deadly ta-He also attacked ACE because their new dioactive wastes at Limerick. I.,

website was under construction.. While ** 6.,A U.S.G.S. study released January claiming to seek the facts, he never visited 2012 shows earthquake risks are drasti the ACE *office to review permits, other cajly increasing.from fracking.in Penn documentatl.on, or discuss the* issues. Call sylvahia. Over. 4, 200 wells were drilled in ACE for an appointment 610-126-2387 Pennsylvania since 2007..

tQ review their* documentation. It's quite 7, Fires can lead to a meltdown and credible. For information on nuclear pow, could result from *ear th.quake, damage.

er issues go to www.nirs.org, www.beyon-Limerick does not follow the safest fire

. dn~clear.org, and [11.diatj.on.qfg. *... safety ~gulatiqns......,.. ;,~.,* :,.. * *., :..

;.....SlJ#ey.say~ lie's -~ b.i~ ;s~h.091, stii~~nt : ** * :.. :.Jb:~~e:~ ~~ - f~c:is: - ~~~.. r_i,sk(;if :*

-. While l appl!lU~ ~e.kip:g enviro~ental Limerick :~e too 1).igli.'-So~ e ai¢ ~~w~-

_' truth~ ; you ~arelygeqhat from *tho*se '.With.,able:. I and

many

other *. people._ looking a:vested iilteresUworzythatMr.'Shirey's at the gro'l¥ing bOciyof,evidence are con-.

., a~tude : couid be.an. ullforttlnl\\te '. co~se;** *vhlced tliai the b est. way :io ~void. a'meit

. : quence of programs 1ike Exelon' s Nucie-' down ts to. close.Limerick 'Nuclear' Plaiii.:

*iif :10j'piogramin 'o~schools.. On1an. ::*."..*. ',':.. ::~:, *._.,**'*, *:<, i

,.* : )t:;i expre~~ed deep ~once1:nlaoout:~ne- ' LQ~'E RUPPE _~;- **. *. i *:.,.. * :..

.... sipe<l'i.ndocttjn,ti,,! **.* !......'... * *.. q n of *our: students by Po'~ *.. ' * *. ;.';

www.pottsmerc.com....

Saturday, April 14, 2012

AS/ THE M~RCURY

ANOTHER

. :: Nl{C **. has.. fajled to *. protect ~rea residents

',(~... t.. **.,.}*,. ~ *. ': *... :*/ t I:* ' : * ' 0 * * ~*' * ' " * * *

,,,, *After

waiting an* entire -year after :ru:*

NRC iii choosing to ignore th~ 183;

..ln(shµni ** w~ lear1;1,ecl.from The* ~ercµry percenf population i.Iicrease**s1:nce )980 on March *11 that the Nuclear Regulatory under Limerick' s original permitting.

d>mmission failed to* require *an* linme,:

Meltdown threats at Limerick are m,:

diate* expanded evacuation ione

and mi-creasing froni natural disasters. Ilk~.~*

proved planning for a Limerick Nuclear quakes, aging, and terrorists attaclcs.

Plant meitoown. **. *

Fukushima meltdowns'_,pr<;>ve "so

... NRC is shamelessly allowing Exelon to called" redundan~ safety**~ystems fail.

use yet another sta.R tactic snidy, jeopar-

August 23, 2011. *a Virgutia earth

. dizing public health and safely to protect quake caused Limerick to check; for dam*

.Exelon's profits once ~ain. age: 1\\vo faults are just nine and 17 miles We need common _____ from Limerick.. ",,.., :.

sense and a more pro-Guest.

A January 20 J2 µSGS ~ciqy showed tective evacuatidn plan Columnlst fracking causes earthqu~es. Fracking i~

~~iately, no1 *anoth- ----- drastically increa~µig in Pennsylvania as.

er study. The potential 4,200.natural gas wells were ap_proved in.

for evacuation of our regiqn because of a. Penrisyl vania since 2007: -.,. *

Limerick Nuclear Plant disaster is ~ too

Limerick still.is~*t prote~te4 against real;but the evacuation plan is not. Lim*. terrorist planes or missiles, iior 96I11plet~

crick must be closed as soon as possible ly protected against cybefattacks; *;.

to preverit a meltdown, * -. In 2011, five nuclear piants in U.S.

. *. NRC recommended a SO mile evac-lost primary power, due

lo

earthquakes uation zone in Japan, but for Limerick or extreme weather eveµts *such as. toma it's still 10 miles. Why? Under the 10 mile does, hup;icanes and flooding;.'....*,.

. :tule, Exelon can get away y.r:iqi the idea NRC!s grote~quc der~lictlon.:otre- *.

that evacuation is possible; but not if the sponsibility ~lated to Limerick reliceris*

, zone is cxpande4 to 50. Limerick should ing was challenged N:o:veinber. 2011 by have to close. *

the National Resources Defense Council. *

.. *

Over eight million people,are with*. NRDC filed a petition ~o intc~ne for cir-.

.. in 50 ~e.s of Limerick. There are 1,914 cumventing safety analysis requiJ.'em~nt~.

.- schools and p6 hospitals.. Evacuation citing Limerick 's obsolete accident miti-chaos would be.indescribable as people gation study...,..,.,.,.

arc *subjected to radioactive plumes dur-While radiation would travel a long.

iDg evacuation,. ~th literally no~ enough distance. we -_who are clos*est '!','OUld. get the *

,r(\\ad space to eva~ate safely. *brunt of radiation exposure. Better*emer-.

.

Philadelphia is 21 miles downwind, gency.planning could ~e.radiation

'downstream from Limerick, but not in its exposures during evacuation... but only

. evacuation plan. closing Limerick would.eliminate risk of

Limerick's emergency plan still in-c:. meltdown.

spbnsibly doesn't account for wind patterns

. and populatioµ. An csti.matccj one million RUPPE

people now live downwind from Limerick. WRRAlNE Pottstown www.pottsmerc.qom

A10 / THE MERCURY Thursday, June 7, 2012

~--:""...-

ANOTHER VIEW

Nuclear plant safety should be tdp concern

-~. '..... 'r.. * *

,, Staff writer Evan Brandt_ did a great payers were burdened with monumental.

job_. of presenting new isS1,1es in "On the increased costs while PECO raked * ~

. Fault Line" in The Mercury On May 20. hug~ pro.fits (Pbila. Inquirer August :*13, :- -:

Toe 'Mercury laid the groundwork fo r 1984). We worry about wlzy a safety test.

.'wh~t should be the starting point for a for Limerick's GE Mark II react6r -.antL.

comprehensive, updated *safety analysis of NRC's response to it are both missing*

the Limerick. nuclear plant: Although the from o~e-of.PEC0 1s Final Analysis Safety,

Nuclear Regulatory Commission should Rep ort volumes in the µbrary..:'..... *

be o~ watchdog, it stands squarely in the We know that an earthquake triggered *.

'

way of crucial new scru- *. Fuirusbima' s multiple meltdowns by cati;.*.

-:tiny. \\*:.,. *.. Guest" ID$_. lo*s ~.-of powe.t= and foss. o_( ~ooµn_g.~~-,.

.. NRC s.stance JS not Columnist

ter. TpeAug. 23, 2011Vin~uua earthquak~

. surprising, 1n *1981, be- - - - -- caused tremors at Limerick.. Limerick i$

fdr~ Unit 1 was cqmplet-...... raiike<;l third on o\\ii :n*ation's -~afth'qtiak~ *...

. :*.*'i' ed.- LEA (the predecessors *:suit.<ln beh"alf of the public against the with of ACE) filed risk list. De.quarry blasting. spite all these* on* the border of facts coupled°Liin:'. * :; '..

- Atomic-Energy Commission, predecessor crick's-property. and possible earthq°iiake. *,.

_ of N,RC. Even. bacl,; then, it had too cozy

risks.from frac.k:in.g in * ~ennsylvarua;*.th.~ *

~'.relatjonship with PECO (now Exelon).* NRC s'till resists updl\\tint its 'safety anaM

'.Toe* Mercury aptly tjtled the report of ; sis.for the Limeripk Nuclear plant.

11.: ::, '.

,. '- tli~t:story, *oavid Against Federal Goli-When a concerned, mothcr_ requesteq,.

.. * ;ath ~ (Sept. 281. 1997).-In it, LEA charged ~ormation about. the.nearest f~'ul~

t~*

- -:Liz.nerick wi~: 1) violating the National the nucrear plarit, NRC.sei:J.t her :orie of.'.

. ~rivironmental Policy Act:and. 2) not thf maps shown on.The Mercurys front' :

.. considering safety-enhancing nuclear de-. page' on May 20, highlighting.the.Ramapo... *

-~s\\in:.'alternatWes for Limerick. The suit

and Chalfont Faults. *Following th.at :*ow:.:

4£agge_d. on for nine years, but iEA won

own research at 'th~ ~ottstown :Libnizy;' *

. Jis:_faC!*based cas~ in fed_eral court. Th<t led us to PECQ's l914 'Geological Survey.*

. judge' s'rulini wa:s a*ml(ljot embarrassment map. It liigblighted the Sanatoga Fauli :

Joi' th:e' AEC, but it was too late for real right under the 'plant *site. That map :was.:,

-~a(etr;° Limerick* was* already const: i:uctea. also fea~d *o~ -~e Mercury's front.page. * ;, ;

. : '* y{e :.are very concerned a~out ~e do-We showed the 1974_ map to N'RC. *or *.,;

, sign.' fla.ws o( Limerick's. aging

GB Maik ficials at th~ir public meeting on April ~8,;

U -Bo~g Water-Reactors: Or~ reac-Each of them de~ed ev.er-having_ s~~n it'.

'.tof operations can produce an in_temal before. NRC says *that

earthquake. risks;:

' ) ~ismic 'rea~~on similar to a Jriaj()~ e~. ~ere ll;S~essed befor~ Li:31-en_ck co~C:,'.:

quake;.*causrng possible *catastrophic con-tion began. However, Limerick's first *.re tainment failure. An: accident in** 1972 at a actor was rolle'd onto the* site* in 1972, bu(*

West German plant was. the first sign of the seismic siudy_was_no~ completed ~til..

that trouble: the forces ruptured the wan* 1974. * *, * *. * * *

1

0feel that, becati~e of Lin:l.eqck's*

.ofthewctwell. ;.. *

We :'

GE notified PECO of the feactor prob-troubled history, plus evolving under- :*

leins iri 1974. Other nuclear plants sued standing of earthquake

risks and* their ;-*

GB, 'or wert;' sciapped, bµt not Limerick. relationship to catastrophic *events,.the,,

PECO braced the reactors with expensive plant should shut

down

befor~ it

melts

e~eering and construction work. pass-down. *

. ing the nevi.~o. after beip.g promised that Limerick's CHARUE costs. onto their ratepayers. and BEITY SHANK

energywou1d be too cheap to me~,.rate-Pottstown Uoogie Maps rage J or 1

To see all lh* delalls 1h11 an, -.islb: e on the saeen, ose the *Pr1nr Wnk next to tile map.

Google

ACE Clarification:

Limerick Nuclear Plant Is Located On The Schuylkill River, Bordered By An Active Blasting Quarry.

http://maps.google.com/maps?ll=40.226655,-75.5873l l &spn=0.005,0.007&t=k 5/18/2012 ATTACHMENT FOR ACE 3-31-14 LETTER TO NRC CHAIRMAN ALLISON MACFARLANE

AEC SHOULD HAVE CHOSE N AN ALTER N ATIVE SITE FOR LIMERICK NUCLEAR PLA N T

HOW EVER AEC'S DRAFT ENVIRONMENTAL STATEM ENT SHOWS THAT COST CONSIDERATIONS PRE-EMPTEQ PUBLIC SAFETY CONCERN S

The Atomic Energy Commission's 1972 DRAFT ENVIRONMENTAL ST A TEMENT shows that AEC knew in 1972 that the site chosen for Limerick Nuclear Plant was In an area that had experienced earthquakes.

AEC considered alternative sites, however chose the Limerick site due to economic considerations, downplaying the earthquake risks,.

AEC did not choose an alternative site, due to what Philadelphia Electric considered:

Irrecoverable Costs New Site Capitol Costs Purchase Power Costs Due To Construction Delay

Costs Were Based On Philadelphia Electric (PE) Estimates See Attached Table 12.4 PE Saved An Estimated $201 to $236 Million In Projected Losses That decision costs PE/ PECO ratepayers the lions' share of

$6.8 Billion Reported In 1997

AEC's 1972 Environmental Statement Downplays Possible Earthquake Hazard By Failing to Mention the Sanatoga Fault Under the Limerick site.

DRAFT ENVIRONMENTAL STATEMENT

by the

DIRECTORATE OF LICENSING UNITED STATES ATOMIC ENERGY COMMISSION

related to the

LIMERICK GENERATING STATION UNITS 1 ;AND 2

PHILADELPHIA ELECTRIC COMPANY

Ooi;ket Nos. 50-352 and 50-353

Issued: December 1972 12-8

12.3.3 Alternative Site

Abandonment of the Limerick site in favor of one of the alter native sites would entail a two year (minimum) delay and numerous additional monetary and envi~onmental costs. The monetary penalty of an alternate site would be composed mainly of three factors: a) frrecoverable costs of site preparatiQn activities at the Limerick site, b) new site capital costs greater than original Limerick sit~ capital costs, and c) purchase of power during the de~ period necessita~ed by starting w,ith another site. The applicant's estimate of these economic penalties are given in Tabie 12.4.

The environmental impact of station construction at an alternative site selected now would be greater than at the Limerick site since it would be in addition to site preparation activities which have already occurred at the Limerick site.

an alternative site would require a. more thorough analysis of An assessment of the environmental impact of station operation at the ecological community at a specific site. Operation of the station at the Limerick site is acceptable ecologically.

The staff concludes that on balance the additional monetary and ecological costs associated with relocating the station at an alternative site are greater than any benefits to be gained by this action.

I'

12.-9

Tab le 12. 4 P.conomlc: penalty for ahemative aiie

Penalty coinpared with Limerick (millions of dollars)

tuecovuable coi ts 60 Additional c:apib.l costs 45-80 1976 and 1977 eDtlJY 96 Total penalty 201-236 2-16

2.4.2 Regional geology and assessment of possible earthquake hazard The site is in an area where earthquake frequency 1s moderate; how ever, no earthquake to our knowledge bas ever been severe enough possible hazard from earthquakes, an _to cause more than trivial damage. Nevertheless, to assess the examination of the geology of mor.about 12 miles wide, will be necessary.11-18 e than just the Triassic. Basin, which in the plant area is only

The Triassic Basin forms part of the Piedmont PhysiogJ;"aphic Prov

ince, which is divided into upland and lowland sections. The upland section is underlain by metamorphosed sedimentary and crys talline rocks of Paleozoic and Precambrian age. The rocks are relatively resistant to erosion and support an uneven hilly surface.

The higher hills are capped by Cambrian quartzites and by Precam brian crystalline rocks; broad valleys characterize the areas under lain by limestone and calcareous shale. The less rugged lowland section to the north. and west of the Piedmont uplands is formed Ridges in the Triassic lowland trend northeas.largely on relatively soft shales and sandstones of Triassic age. t-southwest along the strike of the *more resistant bedrock formations. Higher and more rugged terrain exists where these formations have been intruded by diabase dikes and sills.

The peneplaixi surface ~ut on the Precambrian and metamorphosed early Paleozoic rocks of the Piedmont slopes south and east where it is overlain by the sand. silt, and clay of the Coastal Pla;tn Province. To the north; the Piedmont Province is bordered by the JOOrphosed Paleozoic sediments* and by the Reading Prong of the New Valley and Ridge Province, which is underlain by moderately meta England upland, which is underlain by Precambrian crystalline rocks.

The Precambrian rocks are much altered by igneous intrusion and by ~eformation. However. these deformations occurred long ago, Paleozoic rocks of the Piedmont are also mch deformed by orogenies and there is no remnant

of the forces which caue,ed them. The early which date from the early and middle Paleozoic. Like the later Paleozoic rocks of the Valley and *Ridge Province, they were again deformed at the c~ose of the Paleozoic in the Appalachian Revolu tion, some. 200 million years ago, but these forces likewise appear to have been

dissipated at that time, and there is no longer any movement on the large faults then *formed.

During the late Paleozoic and perhaps during the early part of tion were worn down to base level. Indeed, the Triassic red beds the Triassic, the DIOUlltains formed during the Appalachian Revolu may be regarded as part of the later phases of this peneplanation.

~-~::-:"_::.. ::*:::;;~;.~:~Missie, this partial peneplain was waxped and faulted

~~::j1~*~s *in which the red beds were deposited mid to.

. -*' )ifagh~r land from which these sediments were derived.

"' ;;~ *')J.gneo~ activity. during this perlod of depoeition,

- - - -*tt'..iavas we:te poured out on the surface. After the depo l*,~*~ \\f~~ ' red beds, faulting continued as -did the emplac~t

. iJ * ~ -'d:lles and sill, which cut the red beds. The dikes in M..... _,:,,.;,,*.. ;-* .':fic:n:itinued to 'be intruded *after the faulting had ceased.

'*"' ~ **jgf

tJ:de is* the observation that some of the faults were

....., *".,_:",**.'~(~f:-th~ dikes, which llitst_ have come after the faulting, ci;~-:~~*are not *displaced by it. The Chalfont fault, the closest

'.~~~e:~1~ 'faults, _passes 9 miles to the nort~ast of the site.

,1-i..,;,:,de~ ~~dPthrow on this fault in the general area of the site is

~/;~01 { ft\\,1af >>ueks. Comity* Pennsylvania, but the throw decreases to

.:,:,!;(!:,OdCV.ff:* cn':*lesa

nearer the site. This fault extends to the north-

_:.~ : ( -eatVtbr6tigb *-.New J ereey, where the maxfnmm vertical displacement

\\.. *.is. some lOi,000 ft. This is a major struct~al element, but there

~

i, *. tias. baen no movemen~ *along this fault. as shown by the'IDlfractured

.

:: : ~; *.s~ce the close of the Triassic some 140 m:ill:f.on years ago.

':* : *.**~re ue -also several smaller faults cl.oser to the site. The

.: :~ite~~t iapproach. of a fault: trace *to the site is 1300 ft west:; its

'.\\ i~rt:i.cal displacement is 350 ft. lbe fault plane is occupied by

~,11i1r'Jlrl.assic diabase intrusive which is part of the Downingtown dike

\\.'_.,a:nd which has not been affected by the movement on the fault."

Another fault with an apparent vertical lllOV~t of 350 ft passes 2800 ft south of the plant area. A third fault. about 2 miles SOU*theast of the site., shows vertical movement of 130 ft. There are also numerous small faults in the area nth displacements of

.:: 1 less than 2 ft, but these are of no importance.

Where any of these Triassic faults, or*ao.y of the faults in the older rocks of the Piedmont,. pass under the unconsolidated deposits Clearly, these fa~:t:s have been inactive £or a very long time. of the coastal plain, the coastal plain deposits are not displaced.

There ue, however, small earthquakes in th~eral regi.on, most of them in the P:l.edmont Province. some minor shocks have occurred 1n a northeast-southwest trend along the fall zone, which is the dividing line between the Piedmont Province and the Coastal Plain.

The nearest destructive earthquakes.were in Charleston, South Caro lina, over 500 miles away, and in the St. Lawrence River Valley,.

350 tniles sway, so that their inten.aity at the site was negl1Jib1e.

There have,. however, been uumeroU& minor earthquakes mu.ch neater to the site.

The 1DOst important.of these relatively minor earthquakes took. pl.ace near Wilmington, Delaware, in 1871. some 30 to 40 miles from the s:1te*. The intensity at the epiceater was VII on the Modified Mer calli scale. An earthquake intensity of VII can slightly damage, 2-18

but will pot destroy, buildings of ordina:ry construction but pre sents 110 threat to well-constructed bu11dings like a nuclear power plant. Thie shock may have been fe1t as far away as the site but would present no hazard at this

distance. The quake is believed to have been associated with rock structures :in the Piedmont, pos sibly with earth adjustments along the fall lina.

A second earthquake occurred at Wilkes-Barre in 1954; this is a coal-min~g area~ about 65 miles north of the site. At the epi center the intensity was VII, and hundreds of homes were damaged.

in a five-block area. Sidewalks were pushed upward with a heaving motion and then collapsed. 'l'wo days later there was a second shqck much like the first, and more damage resulted. The origin of the

.. shocks was at shallow depth, as the intensity died out rapidly away £ram the epicenter. There is a possibility that the shock was due to a cave-in in one of the mines. The shock would not have been felt at the site.

A third earthquake in the general area of the site was

at or near York, 60 miles southwest of the site, in 1889. The maximum inten sit:y at: t:he epicenter was VI. No serious damage was reported. The shock was fel.t throughout northeastern Maryland, northern Delaware, and.southeastern Pennsylvania, from Trenton on the north to Hagers town, Maryland. Although it would. have been felt at the site, the intensity would. have been too low to cause

arr:y cu,mage.

In view of the foregoing, and after a study of all the evidence, the design basis earthqWlke (the st:rOIJgest shock which would not damage tbe station) i.ras put at a ground acceleration of 0.15 g,

and the operating basis earthquake (the Btrongest shock which would not require the station to shut down) was put at 0.075 g. 19 The design basis earthquake is rougbly equivalent to the intensity of VII at *the epicenter of the 1871 Wilmington,, Delaware earthquake.

This design appears conservative and is equivalent to the anti-seismic design of most nuclear power reactors in the northeastern United States.

2.5 HYDROLOGY 2.5.1 Groundwater

Groundwater 1a a lllinor resource 1n the are.a around the station and, in general, in the lowlands underlain by the Triassic -rocks. 20-2.s These red beds hold water only 1n joints and fractures. Except very locally where the rock is much shattered, wells yield less than 100 gpm. Groundwater accounts for only about 3% of the total 2-19

industrial and commercial use :f.n the.region. Numerous domestic wells, however. extract small quantities of water from *the Triassic strata, and there are ab~ut JS s mall domestic wells within a 1-mile radius of the Station site.

Groundwater occurs large1y. under water table conditions, although its movement aiong joints and fractures is complex and locally the deeper groundwater may be confined under artesian conditions. The complexity 9£ the groundwater movement makes mapping the water table difficult, but in general such a map is a s~bdued replica of the topogi;-aphy. Groundwater in the station area moves very slowly in the direction of the Schuylkill River. There is no danger of con taminating the groundwater resources of the area by even a major accident at *the St~tion. '

2.5. 2 :.:surface wa1:er

2.. s'.2~1. Schuy1kill

River

Th~ ~ate!~hed of the Schuylkill - River lies entir~ly in southeaste~

PeIU\\~r~v~fa. 26 '.111e bas~n ~ s a~out 80 miles l~ng ; ~d 25 miles wide

. an4.*~,~ _. ~ -- ~-e~. ot; l:909 aqua~~ *m11.es above ~t;s junction with the Del,ji'Cla,re:.,t ; Pl:ii.lad~lphia. Tlj.e station site iJ; on tl_i~ northeast

,' sid,e, ::9£/tfe.. rlv~;r, ~out 49. r _~ve;r, mile$ 1:1P~tream: ~f9Dl the Dele;ware

. and :-~. :mtl~~ *.*~~tream from Pottstown (see Fig, i: s) *. Most of the

,ro~. '.~clerlyi.ng the watershed of the Schuylkill are of low permea-j ;*?i.\\~~ f.)~~ 4 < b~_<?re ' ;tt tle groundwat~1: **. (. !!he 1>ie~st9c;~J ice sheets

did *-r~g~ ' do~~ ~ -. far south as the headwaters of.th~ ;_Schuylkill; there t. fo~ ~~ ~; ~;f,l~/lYtl:1f Y, lacks the hig~l~ permeable depos ~ ~s. of sand and

,. _.gr,, ' t !},i~ t,til~eri,~e ~~ *no~ *t.l).em: :par_~s. of t _~e :-~~t~rshed of the

~-., De. i *~ :r.,r r:ijnd * ~cl\\,\\~~ J t'tle.Jiuch;u;,µ River; ',.For t~~s reason the

~l,;*,*'. ~1 -~ ~.. i~1¥ ~1~ ):k~d va*dg.t;cms,µi. fli;>~ -~.* For ~8:111Pl~ ~- -~lie instanta-

.,. -~,p, ~'$~ -- ~~ s, fQr ;-the

SchU,l.kil; ~. ~ yer at _ Pot~s tqwn were only 87,

{; * **91 t* -;l-'.,;~ d.J O?. __ *cfs fo~. 193Q, 19}], *~.J.932,. ml:~ 1933, ' tespectively.

f-~ *,In ~. ".-,1~-~~~;;anequs 1~. flqw, I~ 46l ' cfs; -~l of these low

<_, fl j)~~~ re *~

Sept~ml>et "~,*Q.ctober an~ represent the ex-

-:*** t-~ l~ \\ p~ riod _of recprd fr91J1_ 1~27 to J969 _~ 1i'~ow frequency

! * :: ~if.. '!~~ in Pi-gs. 2. 9,'a,ud. 2.10.,, Upon 1;he., c~_,;n.pletion of the

.*.:*,_\\j,l., ' ' *'t;* '. t!ie low flaws 'w':µl b~ **augmentea by. '65 cfs

but the

~ft'.*. '>' *J:e>~ fJ.~ will.4:iot l,e*-. greatly chang~~- - The average t-~-,-.1:~, '/j,:,lf

requir~nts *pf *the station ~e :5~ ' cfs. and in f<;;.'11?: *:lfY~l;l~iF?-~S alr_ea_a7 allot~ed to otoer ~U?~f 8 both upstream

. ~- J~ *.. ~::,.,*_~.Ji !t'.*~~ttstown and.<J~stre~ *.. :.~J~ Scbuy.J.kill is already overallocated at times of (471 cf~).-..,-P#,ncipally in ti; l '.t1~~) ~~~1icant _pians ~o J!IS]ce W th~ -1~f!c:i.ency with water J~;:,*.. ~.>:;t1t~. ~tii ~ Delaware River. The propo~ea t()ute for this i~-,,;.*,,;a* "'*~1t:a,;,*.,*h * ***. in Fi 2 11 *

-~., ;...... ~ - :s own. g. *

ATTACHMENT FOR ACE 3-31-14 LETTER TO NRC Cf-lAIRMAN ALLISON MACFARLANE

ACE CHALLE NGES TO INFORMATION PROVIDED BY NRC OFFICIALS RELATED TO INCREASED EARTHQUAKE RISKS THAT COULD TRIGGER MELTDOWNS AT LIMERICK NUCLEAR PLANT

NRC Responses to ACE Questions and Concerns:

Reveal How One NRC Official After The - Other Down-Played and/or Covered Up Absolutely Unacceptable Earthquake Risks at Limerick Nuclear Plant.

Demonstrate That NRC Has No Intention of Acknowledging or Reducing Documented and Increasing Earthquake Risks at.

Limerick Nuclear Plant.

NRC Comments Were Tak en From E-Mail Responses To ACE From The Following NRC Officials:

October 2, 2012 Paul Krohn, PE, Chief, Projects Branch 4 Division of Reactor Projects E-mail Response to ACE Questions Raised 9-16-12

May16,2013 Mel Gray, Chief, Branch 4, Division of Reactor Projects, NRC Region 1 Office, E-mail Responses to ACE Concerns Submitted March, 2013.

December 9, 2013 Fred Bower, NRC Chief Projects Branch 4, Region 1 E-mail Responses to Shanks' 11-4-1*3 Questions and Concerns October 2, 2012 Paul Krohn, PE, Chief, Projects Branch 4 Division of Reactor Projects E-mail Response to ACE Questions Raised 9-16-12

ACE's 9-16-12 e-mail requested information concerning a "new seismic study" for Limerick Generating Station, Units 1 and 2.

Mr. Krohn's Response :

I assume you are referring to the seismic reevaluation that will be performed in response to NRC staff recommendations from the Near-Tenn Task Force (NTTF) review of the accident at the Fukushima Dai-ichl nuclear facility. By letter dated March 12, 2012 (ADAMS Accession No. ML12053A340), the NRC issued a Request for Information (RFI) to nuclear power plant licensees, pursuant to 10 CFR 50.54(f), regarding Recommendations 2.1 (seismic and flooding evaluations). 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the NTTF review of insights from the Fukushima Dai~ichl accident. With respect to the seismic portion of Recommendation 2.1. the RFI requested licensees to perform a reevaluation of the seismic hazards at the site using present-day NRC requirements and guidance. Specific details. regarding the reevaluat ion of seismic hazards are contained in Enclosure 1 to the letter dated March 12, 2012.

Our Res ponses:

This process If flawed. NRC's industry-driven, self-serving checklist mentality is jeopardizing safety of the entire Greater Philadelphia Region.

NRC has amended the original NTTF, so that NRC regulations give the appearance of attention to the new seismic risks since Fukushima, yet is allows loopholes for Limerick's extraordinary seismic risks to be ignored.

Now, in 2014, three years after Fukushima, still nothing has been done to minimize seismic risks at Limerick Nuclear Plant

In 2008, the USGS updated its assessment of seismic threats for Limerick, concluding that because Limerick's earthquake risk was considered low when its construction began, it now needs to be updated In light of new understanding of earthquake risks on the East Coast, yet NRC is dismissing newly understood earthquake risks for the entire East Coast.

Within 1 year of Paul Krohn's response, on 10-23-13, Fred Bower, NRC Chief Branch 4 informed us that no further audit is necessary in tenns of seismic walkdowns tor Limerick Nuclear Plant.

Paul Krohn's Response :.

In response *to your question regarding who will do the study, for Limerick, the study will be done by Exelon (and/or its consultants).

Our Response NRC's seismic requirements have been weakened to such a degree that Exelon's biased, self serving seismic report for Limerick Nuclear Plant satisfies NRC's criteria. NRC's com pliance standards are obviousl y so low that they allow NRC to Ig nore the extraordina ry seismic risks at Limerick Nuclear Plant.

Paul Krohn's Response :

Regarding the interface between Limerick seismic studies and NTTF activities, Mr. Chris Gratton, Senior Project Engineer, Nuclear Reactor Regulation, is an appropriate contact (301 415-1055).

Our Response:

Suggesting that we speak on the phone, off the record, not In writing, fails to result in documentation that we are seeking. Phone conversations allow for misinterpretations. We object to NRC's repeated use of the phone conversation tactic. We believe It is meant to avoid accountability.

Paul Krohn.Response:

Your email also mentioned that earthquake faults in the vicinity of the Limerick site must be included in the seismic evaluation.

Our Res p onse:

NRC completely ignored our request by falling to do an honest updated seismic evaluation for Limerick Nuclear Plant. Instead, one NRC official after the other, including Mr. Krohn, has down ~

played and/or covered"up the absolutely unacceptable earthquake risks at Limerick Nuclear Plant Paul Krohn Response :

The licenslng bases for existing nuclear power plants considered historical data at each site.(e.g., faults, seismic activity).

Our Respanse:

AEC/NRC never honestly considered the actua l earthquake risk, historically or currently, as evidenced in AEC's December 1972 Draft EIS for Limerick. Limerick's fault is just as vulnerable and u npredictable as North Anna's fault. AEC declared both not capable.

Paul Krohn Resoonse :

Notwithstanding, as discussed in Enclosure 1 to the NRC's letter dated March 12, 2012, licensees will be using present-day NRC requirements (I.e., U.S. Code of Federal Regulations, Tille f0, Energy, Part 100, "Reactor Site Criteria*) and guidance with respect to characterizing seismic hazards for tttelr reevaluations.

Our Response:

NRC's regulations are meaningless because.they allow such enormous seismic risks at Limerick Nuclear Plant. NRC characterizations have repeatedly been proven erroneous.

Paul Krohn Response :

As such, all licensees in the central and eastern United States wlll be using a new seismic source model (NUREG 2115) developed Jointly by industry and the NRC. This new seismic source model was developed with inp1Jt from many geologic experts and considered all relevant geologic studies in the central and eastern United States.

Our Response :..

When Industry Is at the table to develop regulations, the public's safety is abandoned.

Geologists and scien tists outside the nuclear Industry disagree*wlth those models used by the nuclear Industry. NRC's new seismic source model fails to take serjously the seismic hazardous we *really have in the Greater Philadelphia Region.

Paul Krohn Response ;

Your email also raised concerns regarding the risks of earthquakes being triggered by certain activities (quarry blasting, drllli'lg of gas wells). The focus of the seismic reevaluation is on the expected seismic ground motion levels for the site from potential earthquakes that are large enough to impact a nuclear power plant. Smaller earthquakes generated from blasting and drilling of gas wells are not expected to have a significant impact on well-engineered facilities such as nuclear power plants.

Our Response:

Evidence presented at NRC's 9-22-11 public hearing proves that Limerick Nuclear Plant is not well engineered,

Prediction models do not allow for a worst case scenario.

Common sense suggests that it wouldn't t.ake a large earthquake to disrupt the mil~s of buried deteriorating pipes and cables under Limerick Nuclear Plant that are vit.al to ensuring the constant supply of power and water to avoid meltdowns.

USGS documented that tracking triggers earthquakes, NRC can't predict how rnany or know how significant the earthquakes might be from any of the 4,200 gas wells approved In PA by 2007, or from massive fracklng in* surrounding states.

After Fukushima, NRC should have learned that predict.ability models don't work to protect the public.

Paul Krohn Response:

Your email also raised concerns that "speciflc deficiencies and structural flalNS" must be included in the seismic evaluation. If the reevaluated ground motion levels are higher than the original plant's design ground motion levels,

then licensees will evaluate the impact of the reevalua1ed ground motion levels on their plant systems, structures and components through a risk evaluation.

Our Response:

Evidence proves that Limerick has "specific design deficiencies and structural flaws" that obviously

NRC has not addressed our concerns about substandard cement In Limerickhave not been included In Exelon's self-$etving seismic evaluation. 's reacto rs and spent ruel

pools, built directly on top of fault fractllres.

Errors were documented 9-22-11. NRC was made aware that there were failures, deviations, and non*

confonnances in the construction of Limerick that now need to be re--evaluated. These can't be fhced after the fact There is no wa.y to make Limerick safe.

May 16, 2013 Mel Gray, Chief, Branch 4, Division of Reactor Projects, NRC Region 1 Office, E-mail Responses to Questions and Concerns Submitted by ACE March, 2013.

Mel Gray, Chief, Branch 4, Division of Reactor Projects, NRC Region 1 Office, finally e-mailed responses 5-16-13 to concerns ACE submitted to NRC in March, 2013.

Mel Gray Response:

Limerick units currently meet all seismic requirements imposed by NRC.

Our Response: Considering the magnitude of Limerick's earthquake risks, NRC's seismic requirements are grossly insufficient.

Mel Gray Response :

NRC estimates of the potential for earthquake hazards for some nuclear power plants may be*larger than previous estimates. However, NRC has determined that currently operating pl.ants remain safe.

Our Response:

NRC has provided no actual proof that Limerick Nuclear Plant is safe from earthquake hazards.

Worse, NRC requires no actual proof. Based on the evidence we have collected, Limerick Nuclear Plant's earthquake hazard risk is enormous. The USGS study actually proves that Limerick's earthquake risks are dramatically greater than originally estimated.

Mel Gray Response :

Recent data warrants further study and analysis under NRC's Generic Issue Program.

Our Response:

The problem is that the Generic Issue Program does not begin to address the degree of Limerick's enormous earthquake hazard risks.

Mel Gray Response:

The objective of the Generic Issue (GI) 199, "Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern U.S. *on Exiting Plants," was to perfonn a conservative, screening-level assessment to evaluate if further investigations of seismic safety for operating reactors in the central a~ eastern US are warranted, consistent with NRC directives.

Our Response:

NRC acknowledges probabilistic seismic hazard problems exist for Eastern U.S., yet NRC to this day, has never truly addressed worst-case scenario assessments at Limerick Nuclear Plant.

Limerick's earthquake risks cannot be considered generically, when the USGS says Limerick is in an ACTIVE earthquake region, and its reactors and fuel pools are directly on top of fault fractures.

Limerick doesn't need further investigation of seismic safety. Risks are gigantic and obvious.

Limerick needs to be closed now to prevent meltdowns triggered by an earthquake.

Mel Gray Response :

Results of the Gl-199 safety/risk assessment should not be interpreted as definitive estimates of plant-specific seismic risk becau se some analyses were conservative making the calculated risk higher than in reality.

Our Response :

This absurd dangerous loophole ignores actual risks at Limerick.

Mel Gray Response:

The nature of the Information used (both seismic hazard data and plant-level fragility information) make these estimates useful only as a screening tool.

Our Response:

Both seismic hazard data and plant-level fragility information should have closed Limerick down.

Instead, NRC Is dismissing Limerick's risks, jeopardizing millions of people-unnecessarily, based on subjective and biased conclusions. Data and fragility Information imply that ob}ective mark ers exist that NRC Is choosing to ignore.

Mel Gray Response:

Further actions to address the Gl-199 issues are being taken as part of the regulatory actions by the NRC's Japan Lessons-Learned Project Directorate.

Our Response:

The Fukushima disaster happened on March 11, 2011. Yet, 3 years later, to date, NRC has taken NO ACTION. It is beyond negligent for NRC to have given nuclear facilities 6 years to complete Just a "study" at a high-risk nuclear plant like Limerick. It's even worse, for NRC to be looking for ways to ignore risks and avoid action.

Mel Gray Response :*

Licensees have been requested, pursuant to 10 CFR 50.54(f), to perform a re-evaluation of the seismic hazards at the site using present-day NRC requirements and guidance.

Our Response:

It defies logic to ask Exelon to re-evaluate Limerick's seismic hazards, when Exelon has a vested interest in minimizing Limerick's earthquake risks.

Mel Gray Response:

Small magnitude earthquakes have had little effect on well-engineered structures such as nuclear power plants.

Our Response:

The evidence shows that Limerick does NOT have well-engineered reactors or fuel pools. There is no proof that even small earthquakes won't disturb the miles of vital inaccessibly aging and deteriorating underground pipes and cables buried under Limerick, which are necessary to prevent meltdowns.

Mel Gray Response:

All currently operating nuclear power reactors, including the Limerick Generating Station, are designed to withstan d the effects of natural phenomena, such as earthquakes.

Our Response:

A body of evidence related to Limerick shows that statement is NOT true.

Mel Gray Response :

NRC requires safety-significant structures, systems. and components be designed to take Into account:

a. The most severe natural phenomena (earthquakes) histo,rically reported for the site and surrou11ding area.

The NRC's regulations require additional design mari1in be added to account for uncertainties due to a limited historical data record;

b. Appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena;and c. The importance of the safety functions to be performed.

Our Response:

During Limerick construction there were errors, failures, deviations, and non-conformances which NRC requirements fall to take into account...

Historically reported earthquake data to determine Limerick's risk is moot after the 8-23-11 Virginia earthquake jolted Limerick.

We learned that NRC had no intention of attempting to Inspect underground Infrastructure at Limerick after the Virginia quake jolted Limerick. Miles of pipes and cables buried under Limerick are difficult, tf not Impossible, to actually inspect. There is no proof that other damages did not occur in other areas of the site.

NRC can't guarantee that any structure systems or components will work as intended. On 8-23-11, Limerick's seismic monitors were inoperable when the quake hit Limerick. Exelon had to rely on the USGS for conformation. What els~ wasn't.working?

Mel Gray Response:

NRC continues to monitor the safety of all nuclear power reactors. This effort includes a request for reactor licensees to re-evaluate seismic hazards as part of the NRC-required actions following the March 2011 Fukushima accident.

Our Response:

To date, 3 years later, NO meaningful changes have made Limerick Nuclear plant safer. NRC's monitoring of Exelon's data to assess Limerick's safety from earthquake risks defies all logic and reason. In fact, no monitoring, no study, no evaluation or assessment can reduce the possibility of a catastrophic meltdown at Limerick Nuclear Plant.

December 9, 2013 Fred Bower, NRC Chief Projects Branch 4, Region 1 E-mail Responses to Shanks' Questions 11-4-13 Questions and Concerns

11-4-13-We e-mailed Fred Bower, NRC Chief Projects Branch 4, Region 1, to ask if Limerick had been included in the seismic hazard walkdown audit associated with the Near-Term Task Force Recommendation 2.3 that NRC requested March 12. 2012. We asked if not, why not.

Fred Bower Response:

Limerick was NOT one of the sites audited.

Our Response:

The reasons Bower cited for Limerick not being audited are exactly the reasons that LIMERICK SHOULD HAVE BEEN AUDITED.

Fred Bower Response:

Limerick was not chosen because Exelon's report for Limerick was consistent with walkdown guidance.

Our Response:

NRC's guidance is clearly flawed Clarity of walkdown guidance is not an acceptable measure of earthquake risk.

Fred Bower Response:

Limerick was not chosen because it was not among sites with higher than average seismic risk.

Our Response: Limerick certainly qualifies as having higher than average seismic risk, a documented fact that NRC officials have repeatedly dismissed.

3-17 Our local newspaper reported that Limerick Nuclear Plant was identified as 3rd on the nation's earthquake risk list, according to a USGS report. It is *impossible to understand that when NRC selected six plants of 66.U.S. plants, Limerick was not one of the six selected, when USGS assessed Limerick to be 3rd highest at risk.

8-24 The article in our local paper, "Earthquake Jolts Region" reported that Limerick was impacted by the 9-23-11 Virginia earthquake.

Spring 2012, we showed NRC a map of the Sanatoga Fault under the Limerick site from its 1974 Geologic Survey.

Fred Bower Response:

Limerick was not chosen because of the apparent level of effort or experience of licensee staff performing the walkdowns was questioned;

Our Response:

This Is clearly irrelevant. No walkdown, regardless of effort, can expose the magnitude of Limerick's earthquake risks.

Fred Bower Response:

Limerick was not chosen because it was not representative of the larger population of US nuclear plants.

Our Response:

Limerick should have been chosen precisely because its risks are far higher than many other US nuclear power plants. Not only is Limerick at higher earthquake risk, it has the 2nd most densely populated evacuation zone in the U.S.

Fred Bower Response:

Although Limerick was considered, six other plants were selected because they met more of the selection criteria and the plants were expected to give the staff insights into how licensees, in general, implemented the seismic walkdowns.

Our Response:

The immense earthquake risks that actually exist at Limerick show that if NRC actually did consider Limerick and dismissed it, that NRC's Seismic Walkdown Audit appears designed to eliminate the perception of earthquake risks at nuclear plants.

Fred Bower Response:

Each plant's walkdown report, including Limerick's will be reviewed individually and a staff assessment of adequacy will be issued.

Our Response:

NRC's review of Exelon's responses is meaningless. The adequacy of Ex:elon's responses have nothing to do with the reality of Limerick's extraordinary risks. This NRC process will not, and cannot, lead to earthquake risk reduction at Limerick.

Fred Bower Resoonse:

stated that during original Limerick licensing, NRC reviewed earthquake risk in NUREG-0991, dated August 1983, which was NRC's Safety Evaluation Report (SER) concerning the application for an operating license for Limerick:

NRC noted that three faults have been m apped and investigated within 2 miles of the site. The closest one is the Sanatoga fault. (Page 2-44 of the SER)

A panel of experts in Appalachian geology and the NRC staff concluded that that these faults have experienced their last displacements more than 500,000 years ago.

This section of the SER concluded that there were no capable faults In the site area.

Our Response:.

Why would NRC dismiss the earthquake fault risk at Limerick? Clearly, it was not because there was no earthquake risk. This was a very controversial decision made clearly to enable Limerick to be licensed, despite being built directly on top of earthquake fault fractures. It seems clear that NRC chose to dismiss the earthquake fault risk at Limerick in order to license Limerick. Clearly, earthquake faults directly under Limerick's nuclear reactors and spent fuel pools, as well as the control room, turbine building, and rad-waste building present unacceptable earthquake risks.

The risk was too great even before Limerick was licensed. NRC's regulations, had they been followed at the time of licensing, would have prohibited Limerick licensing. NRC's regulations were weakened to permit Limerick licensing, and they have continued to be weakened even further ever since.

ATTACHMENT :

LOCAL NEW S ARTICLE S S HOW:

1. Since Fukushima, I n forma tion About Increased Earthqua ke Risk~ a t Limerick Nuclear Plant, Originally Acknowled ge d by NRC, Have Been Dismissed by NRC.

2. A s M o re Is U n d e rs tood A bout Limerick*s I ncreasin g Earthqua ke Risks, Reside nts' Co ncern s also Inc rease.

3. Advances in Seismic Science are dismissed b y the NRC by sta ting that Nucle ar P lants are Design ed W ell Enough to Wi thstan d an y Ea rthqua kes T hat M a y Come.

In T he Case of L imerick N uclear Plan t, tha t is no t True - L imerick's Erro rs, Deviations, and No n co n fo rmances Du ring Cons truc tion Can no t Be Fixed.

Limerick's Cons tructio n is Do cumen ted to be Su bsta n dard.

Only the first page of each article is included.

The articles are availab le at the Pottstown Mercury website, PottsMerc.com Limerick plant ranked 3r d on U.S. quake - risk list -..

Published: Thursday, March 17, 2011; Last Update.cl: Thu. Mar 17, 2011, 7:21am

By Evan Brandt ebrandt@pottsmerc.com

i i

t '. J --

~ ~ J

LIMERICK - Data in a Nuclear Regulatory Commission study released less than a year ago bas led an MSNBC investigation to conclude that Exelon Nuclear's Limerick Generating Station is the third most at risk of ~e from earthquake of all I 04 nuclear plants in the nation.

The ranking takes on particular significance as the world watches Japan grapple with a ca.c:cading nuclear disaster caused by a Pacific Ocean earthquake and subsequent tsunami on March 11.

The NRC study came about as a result of the U.S. Geologic Survey' s 2008 updating of earthquake risks around the country. which used better data and more sophisticated measurements and *modeling than were used in the 1996 and 2002 efforts.

As a result of the new seismic data. the NRC study looked at all 104 nuclear plants in the country and increased the risk probability of an e.arthquake damaging many of them. In fact, only eight bad their risk of earthquake damage lowered. MSNBC reported.

The risk of an earthquake damaging either or both reactors at Limerick was increased by 141 percent, now making it the third most at risk, after the Pilgrim Nuclear Plant in PlymoQth Mass.

and the Indian Point Atomic Generating Station in Buchanan. N. Y., according to the analysis by MSNBC.

-

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.. / IMERICK - Deep in the ground. beneath the poured

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PENNSYLVANIA- *: ).*

concrete and reinforced steel of the Limerick nuclear L plant's evaporation towers, 'lie severaTsleeping subter-

ranean th.teats.. " * *

-,- As far as the plant's ovei;~tors are co:qcerned* - as we!J as the

"'?> q 0 1 ~- *regutators: of the -fedc:ra1 ag~cy -tb~t oversees nuclear pJants -

I,.-., -_ they are tlJ.r~ats that -are likely to st~y asleep.... **..

., And. e.'ie_ll. i f.the*Saµato~a. fault,. _Of the ChaJfonHa~t. O! ~~

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fault, awoke-an<;! ~hook. ' t~ ose. landmark **towers. in al(:-:

~ *~ earthquake, it's unlikety*thafquake. would be. seveFe enough t.~-~

cause enougb clamage to tbe*plant ~o create disaster..

who mapped /tAt least that *hel9~atfaults,in 1974.for ~e Philadelphia Ele<>:was. the concl~ion reached by the geologistj:t=.

Chalfont tric Company. -: : ** * * --,.

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ir.L1M~R1c~,. Despite improvements in geologists' understanding of tru;-:

I -.:___.--. GE~er,r.. NEW Bast Coast earthquake.picture-clearly.punctuated by last A~., -._.

r,. JERSEY gust's unexpected Virginia tiemot felt "in several states - thaH; I / conclusion remains unshaken-for boQith~ plant's current ownt

/ er, ~elon Nuclear, and_the agency which oversees th~ p lan~

I Ptlll.ADELPH~ Please see FAULT -0n A3 I.~.--$!~, OBWes. & -: *~..,,;::- - : -. -. MaOfB GtJO/ogfc RePQrt J.9"l4

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NR~: Nuke

reaSsess earthqllake tisk l)lailtS*inUSt _

By Evan Brandt quake damage as the

result of -to be largely free of the ris1c. of ebrandt@pottsmerc.com a new *model developed for.just such.phenomena.

that purpose.. That belief evaporated Aug.

. LIMERICK..., Experts at'Ex The. model was developed 23 when :* a. 5.8-magnitude earth efon N?clear's Limerick Gen-using new and more accurate quake-centered. in Louisa Coun have to re-assessments of earthquake risk ty, Va., s.p&wiled

tremors that Experts at the Limerick. erNuc(ear Generating Station wlll M I. crating.Sta~on will -c ury Fl have to asses.s how _vwnerablee Photo *. *

the, plant east of:'the Mississippi River.* an' reassess the plant's earthquake preparedness. :

and its -eqrupment are to earth-area o'rthe country once -b elieved Please see EARTHQUAKE on A3 Cf/'J. l.f ti Quakesmay

.nuke plant be factor in relicensing

By Evan Brandt ebraf1dt@pottsrnerc.cpm.

' LOWER'. POTISOROVE :: As the

-Nuclear Regulatory Commi.ssibn p~

pares to receive comment from the public *tomorrow about what *environ mental issues should be considered

when deciding on Exelon's request to rolicense the Lim.er*...---- ---.

ick Nuclear Gener Umerlckon ating Station, they are* likely preparing Arsquake to* answer a* few* risk list-A4 quemions about earthquakes. '*

Earthquakes are much on the mind of the agency these days as it announced last wee~

it is* looking for public input on a draft instruction re~ "U'.S.. nu clear power pliµits to re,..ex.a.ntjne their sj.tes'* seismic risk and provide that information to the NRC." *

This request for public comments

-which will be accepted until Nov.

t'S and which will also be the subject of a public meeting in October -

comes in th,e heels of the earthquake related Fukushima Dai-icbi nuclear plant disaster in Japan and the Aug.

2~ earthquake that rocked a Vll'ginia

nuclear plant and was felt in Penn-* 1 - ' * ~. U} Llmerl;.1,.--f,.n* **

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Servin the Tri-Coun. Area since 193 1

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Ya : earthquake Tremor felt measuring 5.8 at nuke plant sends tremors but operation as far as Maine

By Bra ndle Kessler continues bkessle@ppttsmerc.com By Evan Bra nd l POTTSTOWN -

A 5.8 magnitude ebrandt@pottsmerc.com earthquake struck near Richmond,' Va.,

~:I shortly before 2 p.m. Tuesday, sending LlMERICK - The earthquake that tremor.; through Pottstown and along struck the East Coast Tuesday afternoon

most of the East Coast did not shut down Exelon Nuclear's Lim The earthquake was among the strong erick Generating Station. est ever recorded on the East Coast, ~c Spokesman Joseph Szafran said follow cording to the U.S. Geological Survey.

ing the seismic event, which did register at Officials said there were no immediate

. reports of deaths, but the trembling of the the nuclear facility, the plant was operat quake, the epicenter ~ which was about ing at full capacity. 40 miles northwest of Richmond, Va..

r.;nu;.P.tl ~n-ir.. ;n WA!ii::h1not"" T\\ C' ;uot Both units are 100 percent and are on -~ ~* VA~,.&.£, AV~""I.IUC)-.- _,..,. __..,_ Y#<. r-...- -..

~.~ the Capitol, White House and Pentagon.

line," Szafran said in a* phone interview. At the Pentagon, a low rumbling in just before "For this type of event, we have pro3 p.m. Tycsday. creased until the building itself was shak cedures in place, including a walk-:<Iown ing, and people ran into the corridors of of all structures." No evacuation was m>> there, to shouts the complex. The *of"Evacuate! shaking continued Evacuate!~

essary, "We're he doing said. like we always do, making~ The Park Service closed all monu sure the plant is operating safely," Szafran ments and memorials on the National said.:"Our team weiu right into *;rn~ AP Photos Mall, and ceiling*tiles fell at Reagan Na sure everything is fine. We have

pro-Susy Ward, center, and other office work tionah~rt. outside Washington. All ers gather on the sidewalk In downtown flights there*were put,on*hold.

(Scc NUCLEAR 011AS) Washington roomer¢. after an earthquake In lower Manhattan,.the 26-story feder shook the nation ' s c;apltol Tuesday..al

courthouse in lower Manhattan, blocks from gri;>und ze~o. of the Sept. 11 Earthquake centered in Va. rolls across Pa. (See' QUAKE on A3)

By Joe Mandak ;Jnd. ~ * *.. i

- Maryclaire Dale *1*-*0HIO 1L'

P~.,. *i Assoeiated Press PHILADELPHIA-. Buildings -Rr/'/ *w~~~~!t\\~~.r. VA Gt. f l j

shook from Philadelphia to fitts.. w.va. * '!!.* -<, '.{ Jr.tu burgh and points north Tuesday Ky. l\\ *. * --_ Yl*\\,_____. *1 as a 5.8 magnitude. earthquake Z ~ ** Ric Cl;s!........

centered in Virginia rolled across, ~ 4' r, -*

,.. Penm,-ylvania, causing'Jittle dam 1

of the. Epicenter _ * * -. '--;

age but giving many their first magnitude ~a,~~

real taste of a tremor. *.., ': Cracks appear on the facade of a 5.8 earthquake ~.. !?jl The state's.nuclear

p.ower building on Market Street* 1n down. -;--:-'\\ __

N.C*. ;:j'._¥;.. :i plants reporte<I no impact: :: town,Philadelphia following an * * ;:.. *' *~*'- -~ * * /.D.fi,," ', "* :.1.4.. 1 ~/\\!9.~.. t'W i.

The Depar~nt ofTtiµts~r-[; earthquake along the East Coast.. ' "'~t<:>.t,i~,-.. -*~ Opqan_:,,;-....... !

tation sent its inspectors to do Tuesday. '\\.;..

s.c..A \\.,...f~..,~}-,*.~ir;,* u ~.H>a * /!!:..,.-; } rod precautionary checks of bridges At left, people who came out on the _.

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across the state, with priority to street after an eartllquake look up at a ~ _..,.i.>>"'d *1.._ ~~~b window that cracked during the quake SOURCES: E$RI; USG~ AP (Sec PA QUAKE 011 A6) on Market Street !n Philadelphia.

.Servin

the Tri-Coun Area since. 1931 Thursday, A~t -25, 2011 * ~ottsto~ PAi 75¢

. LIMERICK *,-

POWER PLANT

.. infrastructure ;Undel'grOiuid

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uninspected

after quake

By Evan Brandt.,

ebrandt@pot_tsmerc.com

LIMEIUCK. - Wlien an earthquake hit Virginia Tuesday aftemoon,

nuclear power plants up and down the East Co~

- including Exelon*.Nuclear's Umeric.k Generating-Station - began assessing if damage~.Part of the problen;i, occutred '. how~er, -*.. may be that the p],ace an earthquake is mo~ likely to cause damage is al.sq tlie place the baid*

~ to inspect-un.dei;ground..

is_ Making a JW1e iny~tive report that sccnarlo more worrisome by the Asso ciated Ptess that found that as*the Jllltion's nuclear fl~ ages, much o( its under-

- *:. ** ~ound mfrastnfctute, to moist conditions, may be cxpos.ed ilete.dorati.ng constantly

. e.ven faster. * *.:: ~ earthquake damage is not a

simp[e ope.ration given that "ea.ch plant

. mi.c. has _uniquc deSlgtl resistan~ *. according-~catiq.ps for seis. to Nuclear

. Sheehan.....

Regulatory Commission spokesman. Neil "built to

Called it's "design withstati.a the basis," largest each historical plant. is earthquake * * * ;<~<,_ f,~*-7, in th~ area, with addition.al..,.. ~.\\""'. *

(SeeNUCLEAR.onAJ) * *,*:* " ' "'"".. ~ -* *-~r"':* ~**

The Mercury (http://www.pottsmerc.com),Serving Pottstown, PA and The Tri County area, PA.

URL :

http://www.pottsmerc.com/apps/pbcs.dll/artide? AID=/20120520/NEWS01/120529941&template=prlntart

'Fracking ' Quakes Not A Factor For NRC In Nuke Plant Licensing

By Evan Brandt ebrandt@pottsmerc.com

Sunday, May 20,2012

The last thing the people of Youngstown, Ohio expected last New Year' s Eve was another earthquake.

But not only did a magnitude 4.0 earthquake hit, it was just the Jatcst and the largest in a series of a dozen quakes that had been going on for a year in an area of the country not known for earthquakes.

The culprit, according to a preliminary report by the Ohio Department of Natural Resources issued March 12, was "fracking" wastewater injected deep into the earth and, apparently, unsett1infl. things down there.

The conclusion - soon to be bolstered by a U.S. Geological Survey report that says injecting fracking wastewater deep into the ground "almost certainly" caused a wave of earthquakes from Alabama to Colorado - is bound to add fuel to the already fiery discussion about the environmental impacts of fracking.

But the science is too fresh to affect the Nuclear Regulatory Commission's view of whether an increased risk of earthquakes from fracking poses an increased risk of damage to nuclear plants.

' 'The NRC continues to conclude, based on the evidence available today, that U.S. nuclear plants can safely withstand multiple earthquakes weaker than the plants are designed for," Scott Burnell, a public affairs officer for the NRC wrote in a May 18 e-mail to The Mercury.

To be sure, the evidence of a connection between fracking practices and earthquakes is new science.

The soon-to-be released USGS report makes note of a six-fold increase in earthquakes of magnitude 3 or greater since 2001, according to reporting bv National Public Radio's Statelmpact Pennsylvania news service.

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In the appropriate blocks:..

'2. Oblak, MESSENGER/COURIER algnalW"e, dale 2. Oblaln r.ESSENGER/COURIER or RECIPIENT 2. Retain RECIPIENrs COPY.

rece!Yed, and time receivlld In firat blockl provldod. ttgnaturo, dato roc.lwtd, and Ume rocofved in lie 3. Return oliglnal lo monnger/courier immediately,

13. Retain "SENDER'S SUSPENSE COPY." appropriate blocks provided. who Wil return it to the aender.

NRC FORM 253 (9-,98)

RECIPIENT'S COPY

ML24206A209

Contents

Text

Dear NRC Chairman Macfarlane,

Background:

Enclosure:

Navigation menu

ML24206A209

Text

Dear NRC Chairman Macfarlane,

Background:

Enclosure:

Navigation menu

Search