ML11326A323

Declarations of Suzanne Day, Charles W. Elliott, Linda Lopez, and William P. White

ML11326A323
Person / Time
Site:	Limerick
Issue date:	11/18/2011
From:	Elliott C, Lopez L, William White Natural Resources Defense Council
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML11326A319	List: ML11326A320 ML11326A321 ML11326A322 ML11326A323
References
License Renewal, RAS 21463, 50-352-LR, 50-353-LR
Download: ML11326A323 (15)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ____________________________________ ) In the Matter of ) Docket Nos. 50-352-LR ) 50-353-LR Exelon Generation Company, LLC ) ) Limerick Generating Station, Units 1 & 2 ) November 18, 2011 ___________________________________ ) DECLARATION OF SUZANNE DAY I, Suzanne Day, declare as follows: 1. I make this declaration of my own personal knowledge. If called to testify as a witness, I could and would testify competently regarding its contents. 2. I am a current member of the Natural Resources Defense Council rs. I joined NRDC because I care about the environment and feel that it is not being properly protected. I live on an organic family farm that borders the Delaware River. We can see from our windows the intake system for the public water supply for three counties (Gloucester, Camden, and Burlington Counties). We are also downwind from the nuclear power a conservation easement with the New Jersey Natural Lands Trust because wildlife and native vegetation is threatened by intense development. These are some of the reasons I am personally concerned that we protect our natural world from contamination. For 2 vigilance by regulatory agencies to prevent contamination before problems have to be remediated, a much more costly process than prevention. 3. I live at 3 Taylors Lane in Cinnaminson, New Jersey. I have lived at this address for 20 years this coming May. 4. My home is approximately 35 miles from the Limerick nuclear plants in Pennsylvania. I have been informed that this nuclear facility is seeking to have its operating license renewed for another 20 years by the Nuclear Regulatory Commission 5. I know that LGS operates nuclear power reactors near the area where I live with my family. I also know that LGS stores nuclear waste at the site. Both of these activities concern me. One of my significant concerns about the LGS is that there could be a serious accident at the facility and radiation from the nuclear power plants or the stored nuclear waste could harm my family, the public health of my community, and the surrounding environment in Pennsylvania and New Jersey. The recent events with nuclear reactors in Japan have made it clear to me that that LGS should take all available measures to prevent an accident at its nuclear reactors and to mitigate the environmental consequences of any such accident at its reactors. And just as important, the NRC should require LGS to take such steps. 6. A great many people live near us and it would be difficult for me and my family to evacuate in the event of a crisis. Although there is a warning system in place, we understand that it is outdated. This does not ease my fears about the operating reactors 3 and the nuclear waste. I worry we would have trouble escaping harm if a serious problem arises. 7. I know that the operator and the NRC must undertake an environmental review when nuclear power plants are relicensed. However, I am aware that as part of this relicensing the LGS has not produced an updated study of severe accident consequences and ways to prevent such an accident and to mitigate its consequences. The last plan the applicant or the NRC studied regarding what could and should happen in the event of a serious accident at LGS was in 1989. The Delaware Valley has grown in population and land use has dispersed built-up areas enormously in the interim. Our roadways are choked routinely just on ordinary weekdays. The failure to require full environmental impact studies and plans concerns me very much. I would like to be sure that if the LGS reactors are allowed to operate for an additional 20 years they are using the most up to date equipment and strategies to prevent a nuclear accident, to mitigate against bad environmental consequences, and to plan evacuations that would be feasible. 8. If the applicant updates its analysis of a severe accident and the appropriate mitigation measures are put in place in the event some sort of accident does happen, I would pay attention. It would help me feel safer and more informed about the risks that we face as nearby residents. It would also help me determine what steps I need to take now to protect myself and my family in the event of an accident. But because no such analysis has been conducted on this issue for decades, my worries remain. 9. The NRC has a duty to protect the American people, not to protect the nuclear industry. They also have a duty to keep us informed about the risks inherent in 4 nuclear energy, including those related to aging plants and aging materials that could operate for 60 years. 10. my behalf because I believe with their participation, the Nuclear Regulatory Commission information, this action may address some of my concerns and mitigate impacts to our water, land, and other resources in the event of a serious accident. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief and that this declaration was executed on November 18, 2011 in Cinnaminson, New Jersey. /s/ (electronic signature approved) Suzanne Day UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ____________________________________ ) In the Matter of ) Docket Nos. 50-352-LR ) 50-353-LR Exelon Generation Company, LLC ) ) Limerick Generating Station, Units 1 & 2 ) November 17, 2011 ___________________________________ ) DECLARATION OF CHARLES W. ELLIOTT I, Charles W. Elliott, Esquire, declare as follows: 1. I make this declaration of my own personal knowledge. If called to testify as a witness, I could and would testify competently regarding its contents. 2. I am a current member of the Natural Resources Defense Council since 1981. I joined NRDC because I care about the environment, and believe that it is not being adequately protected. In general, I am concerned about contamination of air, water, soil and food, and the consequent potential impacts on human health and on the natural world. In particular, one of the reasons I originally joined NRDC was because of my concerns about nuclear energy and the risks of nuclear power reactor accidents following the Three Mile Island accident in 1979. 3. I live at 604 Cattell Street, in Easton, Northampton County, Pennsylvania. I have lived at this address for about 16 years. 4. My home is approximately 38 miles from the Limerick Nuclear Generating Stations in Limerick Township, Pennsylvania. I have been informed 2 that this nuclear facility is seeking to have its operating license renewed for another 20 5. I became personally familiar with LGS in my capacity as counsel for the citizen organization Limerick Ecology Action, Inc., Intervenor in the original operating license proceedings for Limerick Units 1 and 2 before the NRC and petitioner for review in the related appeal proceedings before the U.S. Court of Appeals for the Third Circuit. See, http://ftp.resource.org/courts.gov/c/F2/869/869.F2d.719.html. My participation in these matters spanned nearly a decade. In the course of that participation, I physically toured the Limerick facility with members of the Atomic Safety Licensing Board and other parties to the proceeding during construction, reviewed licensing documents and other material related to safety issues and severe accident risks posed by the Limerick facility, and consulted with experts in nuclear safety and risk assessment concerning the risks of operation of LGS. In particular, one of my areas of special concern was to ensure that the Limerick facility employed cost-effective, state of the art measures to prevent and to mitigate the risks of severe accidents. In that regard, I took steps to require that the NRC consider severe accident mitigation alternatives as part of the licensing process. 6. I remain unconvinced that the Limerick facility is as safe as it reasonably could be and I remain concerned with the risks of nuclear reactor operation and with the increasingly dense on-site storage of spent nuclear fuel rods. I am also unconvinced that the NRC has adequately assessed the full-scale long-term consequences of a severe accident at LGS. Recent events at the Fukushima nuclear reactors in Japan have caused me increased concern about the vulnerabilities of nuclear power reactors to external events whose frequency and magnitude have been inadequately assessed. I want to make 3 certain that LGS takes all available measures to prevent a severe accident at its nuclear reactors and to mitigate the environmental and human health consequences of any nuclear accident at its reactors. 7. The region where I live has become increasingly populated and urbanized since the time of the original licensing of the Limerick Generating Station. The Lehigh Valley Planning Commission (the regional planning commission for the Allentown-Bethlehem-Easton, PA Metropolitan Statistical Area (MSA)) of which I am a member, projects significantly increased population growth through 2030, the approximate period of the proposed relicensing. I am concerned that in the event of a severe accident, travel in my area may be impaired or disrupted, particularly where the severity, dynamics and consequences of a nuclear reactor accident can be unclear, fast-moving and unpredictable and in light of the fact that nuclear reactor accidents can cause spontaneous and voluntary evacuations for distances of 100 miles or more. See, e.g., Ziegler, D. & Johnson, J., Evacuation Behavior In Response To Nuclear Power Plant Accidents," Professional Geographer, May, 1984; Cutter, S. & Barnes, K., Evacuation behavior at Three Mile Island. Disasters, 6, 116-124 (1982); Flynn, C., Three Mile Island Telephone Survey -NUREG/CR-1093. Washington, DC: U.S. Nuclear Regulatory Commission, 1979) (evacuees traveled an average distance of 100 miles). I am therefore concerned that in the event of a severe accident it might be difficult for me and my family to evacuate in the event of a crisis to minimize our exposure to radiological contaminants. 8. Moreover, because my home is well within the 50-mile emergency planning zone for the ingestion pathway, I am concerned that a severe accident at the LGS may result in the contamination of food, milk, and water in the area where I live and 4 travel, or that protective action measures taken to interdict, destroy or otherwise prevent the consumption of contaminated food, milk or water may cause a disruption of supplies. 9. I know that the NRC must undertake an environmental review when it grants relicensing permits to nuclear power plants like the Limerick plants. However, I am advised that as part of this relicensing the LGS has not produced an updated study of severe accident consequences and ways to prevent such an accident and to mitigate its consequences. It is my understanding that the last plan the applicant or the NRC studied regarding what could and should happen in the event of a serious accident at LGS was during the original operating licensing proceedings in the late 1980s. Our area has changed dramatically since that time. There are more people, there is more economic activity, and making appropriate plans for the surrounding communities must be very different than what it was two decades ago. 10. This failure to require updated studies and plans concerns me. I would like to be sure that if the LGS reactors are allowed to operate for an additional 20 years they are using the most up to date equipment and strategies to prevent a nuclear accident and to mitigate its environmental consequences. 11. If the NRC were to require the applicant to update its analysis of severe accidents and appropriate mitigation measures I would certainly pay close attention. It would help me feel safer and more informed about the risks that I face as a nearby resident. It would also help me determine what steps I need to take now to protect myself in the event of an accident. But because no such analysis has been conducted on this issue for decades, I remain concerned.

5 12. The NRC has a duty to protect the American people, not to protect the nuclear industry. It also has a duty to keep us informed about the risks inherent in nuclear energy, including those related to aging plants and aging materials that could operate for 60 years. 13. and authorize them to act on my behalf because I believe with their participation, the Nuclear Regulatory Commission will be better positioned to fully review the possible impacts of proposed relicensing for an additional 20 years and its mation, may address concerns and mitigate impacts to human health, and our water, land, and other resources in the event of a serious accident. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief and that this declaration was executed on November 17, 2011 in Easton, Pennsylvania. /s/ Charles W. Elliott_____________ Charles W. Elliott UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ____________________________________ ) In the Matter of ) Docket Nos. 50-352-LR ) 50-353-LR Exelon Generation Company, LLC ) ) Limerick Generating Station, Units 1 & 2 ) November 17, 2011 ___________________________________ ) DECLARATION OF LINDA LOPEZ I, Linda Lopez, declare as follows: 1. I am the director of membership at the Natural Resources Defense Council, Inc. (NRDC). I have been the director of membership for twenty-three years. 2. My duties include supervising the preparation of materials that NRDC distributes to members and prospective members. Those materials describe NRDC and identify its mission. 3. NRDC is a membership organization incorporated under the laws of the State of New York. It is recognized as a not-for-profit corporation under section 501(c)(3) of the United States Internal Revenue Code. 4. NRDC currently has approximately 357,000 members. There are NRDC members residing in each of the fifty United States and in the District of Columbia. NRDC has 15,787 members in Pennsylvania. There are at least 2,894 members living within 50 miles of the Limerick Nuclear Generating Stations and at least 62 members live within 10 miles of the facility.

2 5. NRDFurthermore, NRDC strive[s] to protect nature in ways that advance the long-term welfare of present work[s] to foster the fundamental right of all people to have a voice in decisions 6. Since its inception in 1970, NRDC has, as one of its organizational goals, sought to improve the environmental, health, and safety conditions at the nuclear facilities operated by the Department of Energy and the civil nuclear facilities licensed by the Nuclear Regulatory Commission and their predecessor agencies. To that end, NRDC utilizes its institutional resources (such as its capacities for legislative advocacy, public outreach and education, and litigation) to minimize the risks that nuclear facilities pose to its members and to the general public. I declare under penalty of perjury that the foregoing is true and correct, to the best of my knowledge, information, and belief. Dated: November 17, 2011 s/(electronically signature approved) Linda Lopez UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ) In the Matter of ) ) Exelon Generation Company, LLC ) ) Limerick Generating Station, Units 1 & 2 )

Docket Nos. 50-352-LR 50-353-LR November 16,2011 DECLARATION OF WILLIAM P. WHITE I, William P. White, declare as follows: I. I make this declaration of my own personal knowledge.

If called to testify as a witness, I could and would testify regarding its contents.

2. I am a current member of the Natural Resources Defense Council ("NRDC").

I have been a member for approximately 40 years. I joined NRDC because I care about the environment, and feel that it is not being properly protected.

I am also a former Branch Chief in the Policy. Office of the EPA in Washington, and I served for one year on a task force in the Department of Energy charged with implementing the 1984 Nuclear Waste Policy Act. That Act was passed by Congress with the intent of solving the issue of spent nuclear waste, "once and for all." 3. I live at 135 Pennsylvania Avenue in Bryn Mawr, Pennsylvania.

I have lived at this address for about 25 years. 4. My home is approximately 30 miles from the Limerick Nuclear Generating Stations ("LOS") in Pennsylvania.

I understand that this nuclear facility is seeking to have its operating license renewed for another 20 years by the Nuclear Regulatory Commission

("NRC"). 5. I know that LGS operates nuclear power reactors in the area where I live with my family. I also know that LGS stores nuclear waste at the site. Both of these activities concern me. As a reasonably informed citizen, I am worried about the potential for an aging nuclear facility to accidently cause leakages of radioactivity into the air as occurred not so long ago at the Three Mile Island facility near Harrisburg.

Fortunately, the downwind plume from that accident wafted primarily over farmland before encountering the Philadelphia area. At Limerick, the downwind population is much more dense than in past years. The recent events with nuclear reactors in Japan demand that we make certain that LGS takes all the available measures to prevent an accident at its nuclear reactors and to mitigate the environmental consequences of any such accident at its reactors.

6. I am also concerned that the utility's plans for nuclear waste disposal be opened again to public scrutiny.

The back end of the fuel cycle remains an un-solved problem facing the industry since its inception.

Again, the Japanese accident proved the folly of ignoring this issue, hoping that it will go away. 7. A great many people live near us, and it would be difficult for me and my family to evacuate in the event of a crisis. Although there is a warning system in place, I've read that it is outdated.

This does not ease my fears about the operating reactors and their nuclear waste. I worry we would have trouble escaping harm if a serious problem arises. 2

8. I know that the operator and the NRC must undertake an environmental review when its nuclear power plants are relicensed.

However, I am aware that as part of this relicensing the LGS has not produced an updated study of severe accident consequences and ways to prevent such an accident and to mitigate its consequences.

The last plan the applicant or the NRC studied regarding what could and should happen in the event of a serious accident at LGS was in the late 1980s. Our area has changed a great deal since that time, especially along the Route 422 corridor, with more people and businesses locating there annually.

The failure of LGS to produce updated studies and plans concerns me very much. I would like to be sure that if the LGS reactors are allowed to operate for an additional 20 years, they are using the most up-to-date equipment and strategies to prevent a nuclear accident and to mitigate against its environmental consequences.

9. If the applicant updates its analysis of a severe accident and the appropriate mitigation measures are put in place in the event some sort of accident does happen, I would pay close attention.

I would feel safer and more informed about the risks that I face as a nearby resident.

It would also help me determine what steps I need to take now to protect myself in the event of an accident.

But because no such analysis has been conducted on this issue for decades, my worries remain. I 0. The NRC has a duty to protect the American people, not to protect the nuclear industry.

They also have a duty to keep us informed about the risks inherent in nuclear energy, including those related to aging plants and aging materials that could operate for 60 years. 3

11. I support NRDCis intervention in this case and authorize them to act on my behalf because I believe with their participation, the Nuclear Regulatory Commission*

will be better positioned to fully review the possible impacts of the applicantis proposed relicensing for an additional20 years and based on the Councilis and their experts! information, may address concerns and mitigate impacts to our water, land, and other resources in the event of a serious accident.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief and that this declaration was executed on November 16,201 I in Bryn Mawr, Pennsylvania.

William P. White 4 *