Generic Environmental Impact 

Statement for License 

Renewal of Nuclear Plants

Supplement 49

Regarding

Limerick Generating Station,

Units 1 and 2

Appendices

Final Report

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 49

Volume 2
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Generic Environmental Impact 

Statement for License Renewal 

of Nuclear Plants

Supplement 49

Regarding 

Limerick Generating Station,

Units 1 and 2

Appendices

Final Report

Manuscript Completed: August 2014

Date Published: August 2014

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 49

Volume 2

Cover Sheet

Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor

Regulation. There are no cooperating agencies involved in the preparation of this document.

Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 

Supplement 49, Regarding Limerick Generating Stations, Units 1 and 2, Final Report 

(NUREG–1437). Limerick Generating Stations, Units 1 and 2 are located in Montgomery

County, Pennsylvania. 

For additional information or copies of this document contact:

Division of License Renewal

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Mail Stop O-11F1

11555 Rockville Pike

Rockville, Maryland 20852

Phone: 1-800-368-5642, extension 2375

Email: leslie.perkins@nrc.gov

ABSTRACT

This final supplemental environmental impact statement has been prepared in response to an 

application submitted by Exelon Generation Company, LLC (Exelon) to renew the operating 

license for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 years.

This final supplemental environmental impact statement includes the preliminary analysis that 

evaluates the environmental impacts of the proposed action and alternatives to the proposed 

action. Alternatives considered include natural gas combined-cycle (NGCC), supercritical

pulverized coal, new nuclear, wind power, purchased power, and not renewing the license (the 

no action alternative).

The U.S. Nuclear Regulatory Commission’s preliminary recommendation is that the adverse 

environmental impacts of license renewal for LGS are not great enough to deny the option of 

license renewal for energy planning decisionmakers. This recommendation is based on the 

following:

• the analysis and findings in the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants; 

• the environmental report submitted by Exelon;

• consultation with Federal, state, and local agencies;

• the NRC’s environmental review; 

• consideration of public comments received during the scoping process; 

• consideration of public comments received on the draft supplemental 

environmental impact statement; and 

• consideration of the information presented in the Natural Resources Defense 

Council’s severe accident mitigation alternatives-related waiver petition.

iii
NUREG–1437, Supplement 49, Volumes 1 and 2, 

have been reproduced from the best available copy.

iv
TABLE OF CONTENTS

ABSTRACT.............................................................................................................................. iii

TABLE OF CONTENTS ............................................................................................................ v

FIGURES................................................................................................................................ xiii

TABLES .................................................................................................................................. xv

EXECUTIVE SUMMARY ........................................................................................................ xix

ABBREVIATIONS AND ACRONYMS ................................................................................... xxv

1.0 PURPOSE AND NEED FOR ACTION............................................................................ 1-1

1.1 Proposed Federal Action......................................................................................... 1-1

1.2 Purpose and Need for the Proposed Federal Action ............................................... 1-1

1.3 Major Environmental Review Milestones................................................................. 1-2

1.4 Generic Environmental Impact Statement ............................................................... 1-3

1.5 Supplemental Environmental Impact Statement...................................................... 1-6

1.6 Cooperating Agencies............................................................................................. 1-7

1.7 Consultations .......................................................................................................... 1-7

1.8 Correspondence ..................................................................................................... 1-8

1.9 Status of Compliance .............................................................................................. 1-8

1.10 References ............................................................................................................. 1-9

2.0 AFFECTED ENVIRONMENT.......................................................................................... 2-1

2.1 Facility Description.................................................................................................. 2-1

2.1.1 Reactor and Containment Systems.............................................................. 2-1

2.1.2 Radioactive Waste Management ................................................................. 2-1

2.1.3 Nonradiological Waste Management............................................................ 2-7

2.1.4 Plant Operation and Maintenance................................................................ 2-9

2.1.5 Power Transmission System........................................................................ 2-9

2.1.6 Cooling and Auxiliary Water Systems ........................................................ 2-16

2.1.7 Facility Water Use and Quality ................................................................... 2-21

2.2 Surrounding Environment...................................................................................... 2-24

2.2.1 Land Use ................................................................................................... 2-24

2.2.2 Air Quality and Meteorology....................................................................... 2-25

2.2.3 Geologic Environment................................................................................ 2-28

2.2.4 Surface Water Resources .......................................................................... 2-31

2.2.5 Groundwater Resources ............................................................................ 2-35

2.2.6 Aquatic Resources..................................................................................... 2-38

2.2.7 Terrestrial Resources................................................................................. 2-48

2.2.8 Protected Species and Habitats ................................................................. 2-51

2.2.9 Socioeconomics......................................................................................... 2-67

2.2.10 Historic and Archaeological Resources...................................................... 2-82

v 
Table of Contents

2.3 Related Federal and State Activities ..................................................................... 2-86

2.4 References ........................................................................................................... 2-86

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT .................................................. 3-1

3.1 References ............................................................................................................. 3-3

4.0 ENVIRONMENTAL IMPACTS OF OPERATION............................................................ 4-1

4.1 Land Use ................................................................................................................ 4-1

4.2 Air Quality ............................................................................................................... 4-2

4.3 Geologic Environment............................................................................................. 4-2

4.3.1 Geology and Soils........................................................................................ 4-2

4.4 Surface Water Resources ....................................................................................... 4-3

4.4.1 Generic Surface Water Issues ..................................................................... 4-3

4.4.2 Surface Water Use Conflicts ........................................................................ 4-4

4.5 Groundwater Resources ......................................................................................... 4-5

4.5.1 Generic Groundwater Issues........................................................................ 4-5

4.5.2 Groundwater Use and Quality Conflicts ....................................................... 4-5

4.6 Aquatic Resources.................................................................................................. 4-8

4.6.1 Exposure of Aquatic Organisms to Radionuclides........................................ 4-8

4.7 Terrestrial Resources.............................................................................................. 4-9

4.7.1 Generic Terrestrial Resources Issues .......................................................... 4-9

4.7.2 Effects on Terrestrial Resources ................................................................ 4-10

4.8 Protected Species and Habitats ............................................................................ 4-11

4.8.1 Correspondence with Federal and State Agencies..................................... 4-11

4.8.2 Aquatic Species and Habitats .................................................................... 4-12

4.8.3 Terrestrial Species and Habitats ................................................................ 4-17

4.9 Human Health....................................................................................................... 4-20

4.9.1 Generic Human Health Issues ................................................................... 4-21

4.9.2 Radiological Impacts of Normal Operations ............................................... 4-21

4.9.3 Microbiological Organisms ......................................................................... 4-24

4.9.4 Electromagnetic Fields—Acute Effects ...................................................... 4-26

4.9.5 Electromagnetic Fields—Chronic Effects ................................................... 4-27

4.10 Socioeconomics.................................................................................................... 4-27

4.10.1 Generic Socioeconomic Issues .................................................................. 4-28

4.10.2 Housing...................................................................................................... 4-28

4.10.3 Public Services—Public Utilities................................................................. 4-29

4.10.4 Offsite Land Use ........................................................................................ 4-29

4.10.5 Public Services—Transportation ................................................................ 4-30

4.10.6 Historic and Archaeological Resources...................................................... 4-31

4.10.7 Environmental Justice................................................................................ 4-32

4.11 Evaluation of New and Potentially Significant Information ..................................... 4-39

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Table of Contents

4.12 Cumulative Impacts............................................................................................... 4-41

4.12.1 Air Quality .................................................................................................. 4-42

4.12.2 Water Resources ....................................................................................... 4-44

4.12.3 Aquatic Resources..................................................................................... 4-46

4.12.4 Terrestrial Resources................................................................................. 4-49

4.12.5 Human Health............................................................................................ 4-51

4.12.6 Socioeconomics......................................................................................... 4-51

4.12.7 Cultural Resources .................................................................................... 4-53

4.12.8 Summary of Cumulative Impacts ............................................................... 4-53

4.13 References ........................................................................................................... 4-55

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ................................... 5-1

5.1 Design-Basis Accidents .......................................................................................... 5-1

5.2 Severe Accidents .................................................................................................... 5-2

5.3 Severe Accident Mitigation Alternatives .................................................................. 5-3

5.3.1 Containment Performance Improvement Program ....................................... 5-4

5.3.2 Individual Plant Examination ........................................................................ 5-4

5.3.3 Individual Plant Examination of External Events........................................... 5-5

5.3.4 Accident Management Program................................................................... 5-5

5.3.5 NRC Efforts to Address Severe Accident-Related Issues Since the 

Publication of the 1996 GEIS ....................................................................... 5-6

5.3.6 10 CFR 50.54(hh) Conditions of License Regarding Loss of Large Areas 

of the Plant Caused by Fire or Explosions.................................................... 5-6

5.3.7 Severe Accident Management Guidelines.................................................... 5-7

5.3.8 Fukushima-Related Activities ....................................................................... 5-7

5.3.9 Evaluation of Other New Information............................................................ 5-9

5.3.10 The Applicant’s Evaluation of New and Significant Information .................. 5-10

5.3.11 Risk............................................................................................................ 5-11

5.3.12 Population Increase ................................................................................... 5-12

5.3.13 Consideration of Offsite Economic Cost Risk ............................................. 5-13

5.3.14 Changed Criterion for Assigning Cost Per Person-Rem Averted................ 5-15

5.3.15 Changed Seismic Hazard Proposed in GI-199........................................... 5-16

5.3.16 Additional Staff Evaluation for New and Significant Information ................. 5-19

5.3.17 Cost-Effective SAMAs Identified at Other Plants........................................ 5-20

5.3.18 Current State of the Art Knowledge for Performing SAMA Analysis ........... 5-22

5.3.19 Enrichment of Fuel (Power Uprates) .......................................................... 5-23

5.3.20 Conclusion ................................................................................................. 5-24

5.4 References ........................................................................................................... 5-26

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6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS ................... 6-1

6.1 The Uranium Fuel Cycle.......................................................................................... 6-1

6.2 Greenhouse Gas Emissions.................................................................................... 6-3

6.2.1 Existing Studies ........................................................................................... 6-3

6.2.2 Conclusions: Relative Greenhouse Gas Emissions..................................... 6-9

6.3 References ........................................................................................................... 6-10

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING............................................... 7-1

7.1 Decommissioning.................................................................................................... 7-1

7.2 Staff Review of the Exelon ER ................................................................................ 7-3

7.3 Conclusion .............................................................................................................. 7-3

7.4 References ............................................................................................................. 7-3

8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES...................................................... 8-1

8.1 Natural Gas Combined-Cycle Alternative ................................................................ 8-5

8.1.1 Air Quality .................................................................................................... 8-7

8.1.2 Groundwater Resources .............................................................................. 8-8

8.1.3 Surface Water Resources ............................................................................ 8-9

8.1.4 Aquatic Resources..................................................................................... 8-10

8.1.5 Terrestrial Resources................................................................................. 8-11

8.1.6 Human Health............................................................................................ 8-12

8.1.7 Land Use ................................................................................................... 8-12

8.1.8 Socioeconomics......................................................................................... 8-13

8.1.9 Transportation............................................................................................ 8-13

8.1.10 Aesthetics .................................................................................................. 8-14

8.1.11 Historic and Archaeological Resources...................................................... 8-14

8.1.12 Environmental Justice................................................................................ 8-15

8.1.13 Waste Management................................................................................... 8-16

8.2 Supercritical Pulverized Coal-Fired Alternative...................................................... 8-16

8.2.1 Air Quality .................................................................................................. 8-18

8.2.2 Groundwater Resources ............................................................................ 8-20

8.2.3 Surface Water Resources .......................................................................... 8-21

8.2.4 Aquatic Resources..................................................................................... 8-22

8.2.5 Terrestrial Resources................................................................................. 8-22

8.2.6 Human Health............................................................................................ 8-23

8.2.7 Land Use ................................................................................................... 8-24

8.2.8 Socioeconomics......................................................................................... 8-24

8.2.9 Transportation............................................................................................ 8-25

8.2.10 Aesthetics .................................................................................................. 8-26

8.2.11 Historic and Archaeological Resources...................................................... 8-26

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8.2.12 Environmental Justice................................................................................ 8-26

8.2.13 Waste Management................................................................................... 8-27

8.3 New Nuclear ......................................................................................................... 8-28

8.3.1 Air Quality .................................................................................................. 8-29

8.3.2 Groundwater Resources ............................................................................ 8-30

8.3.3 Surface Water Resources .......................................................................... 8-31

8.3.4 Aquatic Resources..................................................................................... 8-31

8.3.5 Terrestrial Resources................................................................................. 8-32

8.3.6 Human Health............................................................................................ 8-32

8.3.7 Land Use ................................................................................................... 8-33

8.3.8 Socioeconomics......................................................................................... 8-33

8.3.9 Transportation............................................................................................ 8-34

8.3.10 Aesthetics .................................................................................................. 8-34

8.3.11 Historic and Archaeological Resources...................................................... 8-35

8.3.12 Environmental Justice................................................................................ 8-35

8.3.13 Waste Management................................................................................... 8-36

8.4 Wind Alternative.................................................................................................... 8-37

8.4.1 Air Quality .................................................................................................. 8-39

8.4.2 Groundwater Resources ............................................................................ 8-39

8.4.3 Surface Water Resources .......................................................................... 8-40

8.4.4 Aquatic Resources..................................................................................... 8-40

8.4.5 Terrestrial Resources................................................................................. 8-41

8.4.6 Human Health............................................................................................ 8-41

8.4.7 Land Use ................................................................................................... 8-42

8.4.8 Socioeconomics......................................................................................... 8-43

8.4.9 Transportation............................................................................................ 8-44

8.4.10 Aesthetics .................................................................................................. 8-44

8.4.11 Historic and Archaeological Resources...................................................... 8-44

8.4.12 Environmental Justice................................................................................ 8-45

8.4.13 Waste Management................................................................................... 8-45

8.5 Purchased Power.................................................................................................. 8-46

8.5.1 Air Quality .................................................................................................. 8-47

8.5.2 Groundwater and Surface Water................................................................ 8-47

8.5.3 Terrestrial and Aquatic............................................................................... 8-47

8.5.4 Human Health............................................................................................ 8-47

8.5.5 Land Use ................................................................................................... 8-48

8.5.6 Socioeconomics, Transportation, and Aesthetics....................................... 8-48

8.5.7 Historic and Archaeological Resources...................................................... 8-48

8.5.8 Environmental Justice................................................................................ 8-49

8.5.9 Waste Management................................................................................... 8-49

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Table of Contents

8.6 Alternatives Considered but Dismissed................................................................. 8-50

8.6.1 Solar Power ............................................................................................... 8-50

8.6.2 Combination Alternative: Wind, Solar, and NGCC..................................... 8-58

8.6.3 Combination Alternative: Wind and Compressed Air Energy Storage ....... 8-66

8.6.4 Wood Waste .............................................................................................. 8-75

8.6.5 Conventional Hydroelectric Power ............................................................. 8-76

8.6.6 Ocean Wave and Current Energy .............................................................. 8-76

8.6.7 Geothermal Power..................................................................................... 8-77

8.6.8 Municipal Solid Waste................................................................................ 8-78

8.6.9 Biomass Fuels ........................................................................................... 8-79

8.6.10 Oil-Fired Power.......................................................................................... 8-79

8.6.11 Delayed Retirement ................................................................................... 8-79

8.6.12 Fuel Cells................................................................................................... 8-80

8.6.13 Coal-Fired Integrated Gasification Combined-Cycle................................... 8-80

8.6.14 Demand-Side Management ....................................................................... 8-81

8.7 No-Action Alternative ............................................................................................ 8-82

8.7.1 Air Quality .................................................................................................. 8-83

8.7.2 Groundwater Resources ............................................................................ 8-83

8.7.3 Surface Water Resources .......................................................................... 8-83

8.7.4 Aquatic and Terrestrial Resources ............................................................. 8-83

8.7.5 Human Health............................................................................................ 8-83

8.7.6 Land Use ................................................................................................... 8-83

8.7.7 Socioeconomics......................................................................................... 8-84

8.7.8 Transportation............................................................................................ 8-84

8.7.9 Aesthetics .................................................................................................. 8-84

8.7.10 Historic and Archaeological Resources...................................................... 8-84

8.7.11 Environmental Justice................................................................................ 8-84

8.7.12 Waste Management................................................................................... 8-84

8.8 Alternatives Summary ........................................................................................... 8-85

8.9 References ........................................................................................................... 8-87

9.0 CONCLUSION................................................................................................................ 9-1

9.1 Environmental Impacts of License Renewal............................................................ 9-1

9.2 Comparison of Alternatives ..................................................................................... 9-1

9.3 Resource Commitments.......................................................................................... 9-2

9.3.1 Unavoidable Adverse Environmental Impacts .............................................. 9-2

9.3.2 Short-Term Versus Long-Term Productivity ................................................. 9-2

9.3.3 Irreversible and Irretrievable Commitments of Resources ............................ 9-3

9.4 Recommendations .................................................................................................. 9-3

10.0 LIST OF PREPARERS................................................................................................. 10-1

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Table of Contents

11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 

THIS SEIS ARE SENT.................................................................................................. 11-1

12.0 INDEX........................................................................................................................... 12-1

APPENDIX A COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

UNITS 1 AND 2, ENVIRONMENTAL REVIEW ............................................... A-1

APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS................................................. B-1

APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS ....................... C-1

APPENDIX D CONSULTATION CORRESPONDENCE ........................................................ D-1

APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ...... E-1

APPENDIX F DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

IMPACTS ANALYSIS ..................................................................................... F-1

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FIGURES

Figure 1–1. Environmental Review Process.......................................................................... 1-2

Figure 1–2. Environmental Issues Evaluated During License Renewal ................................. 1-6

Figure 2–1. Location of LGS, 6-mile Vicinity.......................................................................... 2-3

Figure 2–2. Location of LGS, 50-mile Region........................................................................ 2-4

Figure 2–3. LGS Site Boundary and Facility Layout .............................................................. 2-5

Figure 2–4. Limerick to Cromby 230-kV Transmission Line Route ...................................... 2-11

Figure 2–5. Cromby to North Wales 230-kV Transmission Line Route................................ 2-12

Figure 2–6. Cromby to Plymouth Meeting 230-kV Transmission Line Route ....................... 2-13

Figure 2–7. Limerick to Whitpain 500-kV Transmission Line Route..................................... 2-14

Figure 2–8. Location of Schuylkill Pumphouse and LGS Discharge Structure..................... 2-17

Figure 2–9. LGS Makeup Water Supply System and Alternative Water Sources Within the 

Delaware River Basin....................................................................................... 2-19

Figure 4–1. 2010 Census Minority Block Groups Within a 50-mi Radius of the LGS........... 4-35

Figure 4–2. 2010 Census Low-Income Block Groups Within a 50-mi Radius of LGS.......... 4-37

xiii

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TABLES

Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of 

License Renewal ................................................................................................ xxii

Table 2–1. Annual Fuel Use and Air Emission Estimates for Significant Sources at 

LGS.................................................................................................................. 2-28

Table 2–2. NOAA Trust Resources Observed in LGS-Related Aquatic Studies ................. 2-47

Table 2–3. Federally and Pennsylvania-Listed Aquatic Species......................................... 2-54

Table 2–4. Federally and Pennsylvania-Listed Terrestrial Species..................................... 2-60

Table 2–5. Pennsylvania-Listed Bird Species in the Action Area........................................ 2-65

Table 2–6. Limerick Generating Station, Employee Residence by County ......................... 2-68

Table 2–7. Housing in Berks, Chester, and Montgomery Counties in 2010........................ 2-68

Table 2–8. Public Water Supply Systems in Berks, Chester, and Montgomery 

Counties........................................................................................................... 2-69

Table 2–9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual 

Daily Traffic Count............................................................................................ 2-71

Table 2–10. Population and Percent Growth in Berks, Chester, and Montgomery 

Counties from 1970 to 2000 and Projected for 2010–2050............................... 2-73

Table 2–11. Demographic Profile of the Population in the Limerick Generating Station 

Socioeconomic Region of Influence in 2010..................................................... 2-74

Table 2–12. Seasonal Housing in Counties Located Within 50 Miles of the Limerick 

Generating Station ........................................................................................... 2-75

Table 2–13. Migrant Farm Workers and Temporary Farm Labor in Counties Located 

Within 50 Miles of Limerick Generating Station ................................................ 2-77

Table 2–14. Major Employers by Industry in the LGS ROI in 2010....................................... 2-78

Table 2–15. Largest Private Sector Employers – Montgomery County – 2007..................... 2-79

Table 2–16. Estimated Income Information for the Limerick Generating Station Region 

of Influence in 2010.......................................................................................... 2-79

Table 2–17. Limerick Generation Station Tax Distribution, 2006–2010 ................................ 2-81

Table 2–18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget............... 2-82

Table 3–1. Category 1 Issues Related to Refurbishment ..................................................... 3-1

Table 3–2. Category 2 Issues Related to Refurbishment ..................................................... 3-2

Table 4–1. Land Use Issues................................................................................................. 4-2

Table 4–2. Air Quality Issues ............................................................................................... 4-2

Table 4–3. Surface Water Resources Issues ....................................................................... 4-3

Table 4–4. Groundwater Resources Issues ......................................................................... 4-5

Table 4–5. Aquatic Resources Issues .................................................................................. 4-8

Table 4–6. Terrestrial Resources Issues.............................................................................. 4-9

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Table 4–7. Protected Species and Habitats Issues ............................................................ 4-11

Table 4–8. Human Health Issues ....................................................................................... 4-20

Table 4–9. Socioeconomics Issues.................................................................................... 4-28

Table 4–10. Summary of Cumulative Impacts on Resource Areas....................................... 4-54

Table 5–1. Issues Related to Postulated Accidents.............................................................. 5-1

Table 6–1. Issues Related to the Uranium Fuel Cycle and Waste Management .................. 6-1

Table 6–2. Nuclear Greenhouse Gas Emissions Compared to Coal .................................... 6-6

Table 6–3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas......................... 6-7

Table 6–4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

Sources.............................................................................................................. 6-8

Table 7–1. Issues Related to Decommissioning................................................................... 7-2

Table 8–1. Summary of Alternatives Considered In Depth ................................................... 8-5

Table 8–2. Summary of Environmental Impacts of the NGCC Alternative Compared 

to Continued Operation of the Existing LGS ..................................................... 8-16

Table 8–3. Summary of Environmental Impacts of the Supercritical Coal-Fired 

Alternative Compared to Continued Operation of LGS ..................................... 8-28

Table 8–4. Summary of Environmental Impacts of the New Nuclear Alternative 

Compared to Continued Operation of the Existing LGS.................................... 8-37

Table 8–5. Summary of Environmental Impacts of the Wind Alternative Compared to 

Continued Operation of the Existing LGS......................................................... 8-46

Table 8–6. Summary of Environmental Impacts of Purchased Power Compared to 

Continued Operation of the Existing LGS......................................................... 8-50

Table 8–7. Summary of Environmental Impacts of the Solar PV Alternative Compared 

to Continued Operation of the Existing LGS ..................................................... 8-57

Table 8–8. Summary of Environmental Impacts of the Combination Alternative 

Compared to Continued Operation of the Existing LGS.................................... 8-66

Table 8–9. Summary of Environmental Impacts of the Wind and CAES Alternative 

Compared to Continued Operation of the Existing LGS.................................... 8-75

Table 8–10. Environmental Impacts of No-Action Alternative............................................... 8-85

Table 8–11. Summary of Environmental Impacts of Proposed Action and Alternatives........ 8-86

Table 10–1. List of Preparers............................................................................................... 10-2

Table 11–1. List of Agencies, Organizations, and Persons to Whom Copies of This 

SEIS Are Sent .................................................................................................. 11-1

Table A–1. Individuals Providing Comments during the Scoping Comment Period............... A-2

Table A–2. Technical Issue Categories ................................................................................ A-5

Table A–3. Comment Response Location in Order of Resource Area .................................. A-6

Table A–4. Individuals Providing Comments on the Draft SEIS.......................................... A-43

xvi
Table of Contents

Table A–5. Technical Issue Categories .............................................................................. A-45

Table A–6. Comment Response Location in Order of Resource Area ................................ A-46

Table B–1. Generic Summary of Findings on NEPA Issues for License Renewal of 

Power Plants...................................................................................................... B-2

Table C–1. Federal and State Environmental Requirements ................................................ C-2

Table C–2. Licenses and Permits......................................................................................... C-6

Table D–1. Consultation Correspondence ............................................................................ D-2

Table E–1. Environmental Review Correspondence............................................................. E-2

Table F–1. Projects and Actions Considered in the Cumulative Impacts Analysis................ F-2

xvii

ABBREVIATIONS AND ACRONYMS

°C degree(s) Celsius

°F degree(s) Fahrenheit

AADT average annual daily traffic 

ac acre(s)

AC alternating current

ACHP Advisory Council on Historic Preservation

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act of 1954 

AEC U.S. Atomic Energy Commission

AEPS alternative energy portfolio standard

ALARA as low as is reasonably achievable

ANSI American National Standards Institute

APE area of potential effect

AQCR air quality control region 

ATWS anticipated transient without scram 

BHP Bureau of Historic Preservation

BMP best management practice

BOL Bureau of Laboratories

BTU British thermal unit(s)

BTU/kWh British thermal unit(s) per kilowatt-hour

BTU/lb British thermal unit(s) per pound

BWR boiling water reactor

BWROG BWR Owners’ Group

CAA Clean Air Act, as amended through 1990

CAES compressed air energy storage

CCS carbon capture and storage

CDF core damage frequency

Ceq/kWh carbon equivalent per kilowatt-hour 

CEQ Council on Environmental Quality

CEUS central and eastern United States

CFR Code of Federal Regulations

cfs cubic feet per second

cm centimeter(s)

xxv 
Abbreviations and Acronyms

cm/s centimeter(s) per second

CO carbon monoxide 

CO2 carbon dioxide

CPI Containment Performance Improvement

CRGIS Cultural Resources Geographic Information System

CS candidate species

CSAPR Cross-State Air Pollution Rule

CSP concentrated solar power

CT combustion turbine

CWA Clean Water Act of 1972

dB decibels

dBA decibels adjusted

DBA design-basis accident

DC direct current

DMR Discharge Monitoring Report

DOE U.S. Department of Energy

DRBC Delaware River Basin Commission

DSEIS draft supplemental environmental impact statement

DSM demand-side management 

DVRPC Delaware Valley Regional Planning Commission

DWS drinking water standard

E.O. Executive Order

EFH essential fish habitat

EI exposure index

EIA Energy Information Administration (of DOE) 

EIS environmental impact statement

ELF EMF extremely low-frequency electromagnetic field

EMS environmental management system

EP emergency preparedness

EPA U.S. Environmental Protection Agency 

EPCRA Emergency Planning and Community Right-to-Know Act of 1986

EPG Emergency Procedure Guidelines

EPRI Electric Power Research Institute

EPT Ephemeroptera, Plecoptera, and Trichoptera

ER Environmental Report 

xxvi 
Abbreviations and Acronyms

ESA Endangered Species Act of 1973, as amended 

ESEP Expedited Seismic Evaluation Process

Exelon Exelon Generation Company, LLC

FE Federally endangered

FENOC First Energy Nuclear Operating Company

FES final environmental statement

fps feet per second

FR Federal Register

FSAR final safety analysis report

ft foot (feet)

FT Federally threatened

ft3 cubic foot (feet)

FW feedwater

FWCA Fish and Wildlife Coordination Act

FWS U.S. Fish and Wildlife Service

g gram(s)

gal gallon(s)

GDC general design criterion/criteria

GE General Electric 

GEIS Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants, NUREG–1437

GHG greenhouse gas 

GIC Green-is-Clean

GMRS ground motion response spectrum/spectra

gpd gallons per day 

gpm gallons per minute 

GW groundwater

ha hectare(s)

Hg mercury

HLSA high-level storage area

Hz hertz

IAEA International Atomic Energy Agency

IEEE Institute of Electrical and Electronics Engineers, Inc.

IGCC integrated gasification combined-cycle 

IHS IPEEE HCLPF spectrum/spectra

xxvii 
Abbreviations and Acronyms

IN information notice

in. inch(es)

IPE Individual Plant Examination

IPEEE Individual Plant Examination of External Events

ISFSI Independent Spent Fuel Storage Installation

ISO International Organization for Standardization

kg kilogram(s)

km kilometer(s)

km2 square kilometer(s)

kV kilovolt(s)

kW kilowatt(s)

kWh kilowatt-hour(s)

L/min liter(s) per minute

lb pound(s)

LEFM Leading Edge Flow Meter

LGS Limerick Generating Station, Units 1 and 2

Limerick Limerick Generating Station, Units 1 and 2

LLMW low-level mixed waste

LLRW low-level radioactive waste

m meter(s)

m/s meter(s) per second

m2

 square meter(s)

m3 cubic meter(s)

m3

/s cubic meters per second 

mA milliampere(s)

MACCS2 MELCOR Accident Consequence Code System 2 

MAIS macroinvertebrate aggregated index for streams 

MassDEP Massachusetts Department of Environmental Protection

MATS Mercury and Air Toxics Standards 

MBTA Migratory Bird Treaty Act of 1918

MCPC Montgomery County Planning Commission 

MDPH Massachusetts Department of Public Health

MF migratory fishes

mg/L milligrams per liter

mgd million gallons per day 

xxviii 
Abbreviations and Acronyms

mGy million gallons per year

mi mile(s)

mi2 square mile(s)

min minute(s)

mm millimeter(s)

MMI Modified Mercalli Intensity

MMPA Marine Mammal Protection Act of 1972

mph mile(s) per hour

mrad milliradiation absorbed dose

mrem milliroentgen equivalent man

MSA Magnuson–Stevens Fishery Conservation and Management Act, 

as amended through 2006

MSL mean sea level

mSv millisievert

MSW municipal solid waste

MT metric ton(s)

MUR measurement uncertainty recapture

MW megawatt(s)

MWd megawatt-day(s)

MWd/MTU megawatt-day(s) per metric ton of uranium 

MWe megawatt(s) electrical 

MWt megawatt(s) thermal

NA not applicable 

NAAQS National Ambient Air Quality Standards

NAS National Academy of Sciences

NASS National Agricultural Statistics Service

NCI National Cancer Institute

NCRP National Council on Radiation Protection and Measurements

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act of 1969

NERC North American Electric Reliability Corporation

NESC National Electrical Safety Code

NETL National Energy Technology Laboratory

NGCC natural-gas-fired combined-cycle 

NHPA National Historic Preservation Act of 1966, as amended

xxix
Abbreviations and Acronyms

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service (of NOAA)

NOAA National Oceanic and Atmospheric Administration 

NOx nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service

NRC U.S. Nuclear Regulatory Commission 

NRCS National Resources Conservation Service

NRHP National Register of Historic Places

NRR Office of Nuclear Reactor Regulation

NTTF Near-Term Task Force

NUREG NRC technical report designation (Nuclear Regulatory 

Commission)

NWS National Weather Service

O3 ozone

OCA Owner-Controlled Area

ODCM Offsite Dose Calculation Manual

OPA Office of Public Affairs

PADEP Pennsylvania Department of Environmental Protection

PAH polycyclic aromatic hydrocarbon

Pb lead

PBAPS Peach Bottom Atomic Power Station

PCBs polychlorinated biphenyl 

pCi/L picocuries per liter

PDCNR Pennsylvania Department of Conservation and Natural Resources

PDEP Pennsylvania Department of Environmental Protection

PE Pennsylvania endangered

PECO PECO Energy Company, the energy delivery subsidiary of Exelon

Corporation serving retail customers in southeastern Pennsylvania 

(also used as an acronym for Philadelphia Electric Company, a 

predecessor of PECO Energy Company and Exelon Generation)

PFBC Pennsylvania Fish and Boat Commission

PGA peak ground acceleration

PGC Pennsylvania Game Commission

PJM PJM Interconnection, LLC

PM particulate matter

xxx 
Abbreviations and Acronyms

PM10 particulate matter >2.5 microns and ≤10 microns in diameter

PM2.5 particulate matter ≤2.5 microns in diameter

PNDI Pennsylvania Natural Diversity Inventory

PNHP Pennsylvania Natural Heritage Program

PNNL Pacific Northwest National Laboratory

POST Parliamentary Office of Science and Technology

PPC Preparedness, Prevention, and Contingency

PR Pennsylvania rare

PSD Prevention of Significant Deterioration

psia pounds per square inch absolute

PT Pennsylvania threatened

PV photovoltaic

PWR pressurized water reactor

RAI request for additional information

RCA radiological control area

RCRA Resource Conservation and Recovery Act of 1976, as amended

REMP radiological environmental monitoring program

REOP Radiological Environmental Operation

RERS reactor enclosure recirculation system

RGPP Radiological Groundwater Protection Program

RKm river kilometer

RM river mile

RMC RMC-Environmental Services

ROI region of influence

ROP Reactor Oversight Process

ROW(s) right(s)-of-way

RPS renewable portfolio standard

RSP radwaste storage pad

RWCU reactor water cleanup 

SAMA Severe Accident Mitigation Alternative

SAMDA Severe Accident Mitigation Design Alternative

SAMGs Severe Accident Mitigation Guidelines

SAR safety analysis report

SCPC supercritical pulverized coal 

SCR selective catalytic reduction 

xxxi 
Abbreviations and Acronyms

SE state endangered

SEIS supplemental environmental impact statement 

SER safety evaluation report

SGTS standby gas treatment system

SHPO State Historic Preservation Officer

SIP State Implementation Plan

SMA Seismic Margin Assessment

SNF spent nuclear fuel

SO2 sulfur dioxide

SOx sulfur oxide(s)

SPCC Spill Prevention Control and Countermeasure

SPID Screening, Prioritization and Implementation Details

SPRA Seismic Probabilistic Risk Assessment

SR state rare

SSC species of special concern

SSCs structures, systems, and components

SSE safe-shutdown earthquake

ST state threatened

State Commonwealth of Pennsylvania (or other state if specified)

STG steam turbine generator

Stroud Stroud Water Research Center

Sv sievert

SW surface water

SWPPP Stormwater Pollution Prevention Plan

TDS total dissolved solids

TLD thermoluminescent dosimeters

TMDL total maximum daily upload

TMI Three Mile Island

tpy ton(s) per year

TSP total suspended particles

TWh terawatt-hour(s)

U uranium

U.S. United States

U.S.C. United States Code

UCB upper confidence bound

xxxii 
Abbreviations and Acronyms

UFSAR updated final safety analysis report

USACE U.S. Army Corps of Engineers 

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USGCRP United States Global Change Research Program [or GCRP]

USGS U.S. Geological Survey

VOC volatile organic compound

WEC wave energy conversion

WHC Wildlife Habitat Council

WWF warm water fishes

xxxiii 

APPENDIX A 

COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

UNITS 1 AND 2, ENVIRONMENTAL REVIEW

A. COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

UNITS 1 AND 2, ENVIRONMENTAL REVIEW

A.1 Comments Received During Scoping

The scoping process began on August 26, 2011, with the publication of the U.S. Nuclear 

Regulatory Commission’s (NRC’s) notice of intent to conduct scoping in the Federal Register

(FR) (75 FR 53498). As part of the scoping process, the NRC held two public meetings at the 

Sunnybrook Ballroom in Pottstown, PA, September 22, 2011. Approximately 100 members of 

the public attended the meetings. After the NRC staff presented prepared statements pertaining 

to the license renewal and the scoping processes, the meetings were opened to members of the 

public for their comments. Attendees provided oral statements that were recorded and 

transcribed by a certified court reporter. Transcripts of the entire meeting are available using 

the NRC’s Agencywide Documents Access and Management System (ADAMS). ADAMS 

Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. 

Transcripts for the afternoon and evening meetings are available in ADAMS under Accession 

Nos. ML11287A207 and ML11287A211, respectively (NRC 2011a, 2011b). In addition to the 

comments received during the public meetings, comments were received through the mail and 

e-mail. 

Each commenter was given a unique identifier so that every comment could be traced back to 

its author. Table A-1 identifies the individuals who provided comments applicable to the 

environmental review and the commenter ID associated with each person’s set of comments. 

The individuals are listed in the order in which they spoke at the public meeting and in random 

order for the comments received by letter or e--mail. To maintain consistency with the scoping

summary report, the unique identifier used in that report for each set of comments is retained in 

this appendix.

Specific comments were categorized and consolidated by topic. Comments with similar specific 

objectives were combined to capture the common essential issues raised by participants. 

Comments fall into one of the following general groups:

• Specific comments that address environmental issues within the purview of 

the NRC environmental regulations related to license renewal. These 

comments address the Category 1 (generic) or Category 2 (site-specific) 

issues identified in NUREG-1437, “Generic Environmental Impact Statement

for License Renewal of Nuclear Plants” (GEIS), or issues not addressed in 

the GEIS. The comments also address alternatives to license renewal and 

related Federal actions. There are also comments that do not identify new 

information for the NRC to analyze as part of its environmental review.

• There are comments that address issues that do not to fall within or are 

specifically excluded from the purview of NRC environmental regulations 

related to license renewal. These comments typically address issues such as 

the need for power, emergency preparedness, security, current operational 

safety issues, and safety issues related to operation during the renewal 

period.

A-1 
Appendix A

Table A–1. Individuals Providing Comments during the Scoping Comment Period

Commenters are identified below, along with their affiliations 

and how their comments were submitted.

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Dr. Lewis Cuthbert Alliance for a Clean 

Environment 1 

Afternoon scoping

meeting ML11287A207

Evening scoping

meeting ML11287A211

Written Comments

ML11354A392

ML11036A244

ML11036A245

Bill Maguire Limerick Site Vice 

President, Exelon 2 

Afternoon scoping

meeting Ml11287A207

Evening scoping

meeting ML11287A211

Representative 

Tom Quigley State Representative 3 Afternoon scoping

meeting ML11287A207

Lorraine Ruppe Resident 4 

Afternoon scoping

meeting ML11287A207

Evening scoping

meeting ML11287A211

Written Comments ML11308B354

Mike Gallagher Vice President for License 

Renewal, Exelon 5 

Afternoon scoping

meeting ML11287A207

Evening scoping

meeting ML11287A211

Dr. Fred Winter Resident 6 

Afternoon scoping

meeting ML11287A207

Evening scoping

meeting ML11287A211

Written Comments ML11305A016

Thomas Neafcy Resident 7 Afternoon scoping

meeting ML11287A207

Dr. Anita Baly Resident 8 

Afternoon scoping

meeting ML11287A207

Written Comments ML11035A010

Tim Fenchel Schuylkill River Heritage 

Area 9 Afternoon scopingmeeting ML11287A207

Bill Vogel Resident 10 Afternoon scoping

meeting ML11287A207

A-2 
Appendix A

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Eileen Dautrich Tri-County Area Chamber of 

Commerce 11 Afternoon scopingmeeting ML11287A207

Billy Albany Resident 12 Afternoon scoping

meeting ML11287A207

John McGowen Jaeco/Gas Breaker/UMAC, 

Inc. 13 Afternoon scopingmeeting ML11287A207

Ted Del Gaizo Resident 14 Afternoon scoping

meeting ML11287A207

Tim Phelps Resident 15 Afternoon scoping

meeting ML11287A207

Thomas Saporito Saporito-Associates 16 Evening scoping

meeting ML11287A207

Jeff Chomnuk Resident 17 Evening scoping

meeting ML11287A207

Daniel Ludwig Resident 18 Evening scoping

meeting ML11287A207

Catherine Allison Resident 19 Evening scoping

meeting ML11287A207

Jeffrey Norton Pennsylvania Energy 

Alliance 20 Evening scopingmeeting ML11287A207

Dan Ely Resident 21 Evening scoping

meeting ML11287A207

Jay Beckermen Resident 22 Evening scoping

meeting ML11287A207

Jim Der Pottstown Energy Advisory 

Committee 23 Evening scopingmeeting ML11287A207

Traci Confer Energy Justice Network 24 Evening scoping

meeting ML11287A207

Camilla Lange Resident 25 Written Comments ML11279A107

Eric Hamell Resident 26 Written Comments ML11279A108

Steven Furber Resident 27 Written Comments ML11279A109

Charlene Padworny Resident 28 Written Comments ML11279A110

Sylvia Polluck Resident 29 Written Comments ML11279A111

Joe Roberto Resident 30

Written Comments ML11290A106

Written Comments ML11279A112

Brice Obermeyer Delaware Tribe Historic 

Preservation Office 31 Written Comments ML11279A113

Sherry White Stockbridge-Munsee Tribal 

Historic Preservation Office 32 Written Comments ML11279A114

A-3 
Appendix A

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Unknown Unknown 33 Written Comments ML11286A298

Richard Kolsch Resident 34 Written Comments ML11286A299

Charles and 

Elizabeth Shank Resident 35 Written Comments ML11286A300

Nancy Leaming Resident 36 Written Comments ML11290A102

Cynthia Gale Resident 37 Written Comments ML11290A103

Jude Schwegel Resident 38 Written Comments ML11290A104

Michael Gale Resident 39 Written Comments ML11290A105

Melissa Antrim Resident 40 Written Comments ML11291A155

Michael Antrim Resident 41 Written Comments ML11291A156

Joan McGone Resident 42 Written Comments ML11292A011

Mary Lou and 

Harold Smith Resident 43 Written Comments ML11294A208

Lisa Smoyer Resident 44 Written Comments ML11300A011

Unknown Resident 45 Written Comments ML11300A012

Lori Molinari Resident 46 Written Comments ML11305A072

Doris Meyers Resident 47 Written Comments ML11305A014

Ken Sekellick Resident 48 Written Comments ML11305A015

Anthony Gonyea Onondaga Nation 49 Written Comments ML11305A006

Debby Penrod Resident 50 Written Comments ML11305A007

Charlie Koeing Resident 51 Written Comments ML11305A008

Joyce Webber Resident 52 Written Comments ML11305A009

Charlotte Derr Resident 53 Written Comments ML11307A388

Michael Stokes Montgomery County 

Planning Commission 54 Written Comments ML11307A387

Thomas Sullivan Montgomery County 

Department of Public Safety 55 Written Comments ML11307A386

Natural Resources 

Defense Council 56 Written Comments ML11307A456

Sharon Yohn Resident 57 Written Comments ML11307A455

Michael Smokowicz Resident 58 Written Comments ML11307A454

Barbara Miller Resident 59 Written Comments ML11311A063

Debra Schneider Resident 60 Written Comments ML11313A013

A-4 
Appendix A

To evaluate the comments, the NRC staff gave each comment a unique identification code that 

categorizes the comment by technical issue and allows each comment or set of comments to be 

traced back to the commenter and original source (transcript, letter, or e-mail) from which the 

comments were submitted.

Comments were placed into one of the technical issue categories, which are based on the 

topics that will be contained within the staff’s supplemental environmental impact statement 

(SEIS) for Limerick Generating Station (LGS), as outlined by the GEIS. These technical issue 

categories and their abbreviation codes are presented in Table A-2.

Table A–2. Technical Issue Categories

Comments were divided into 1 of the 16 categories below, each of which has a unique 

abbreviation code.

Code Technical issue

AL Alternatives Energy Sources

AM Air & Meteorology

DC Decommissioning

GE Geology

GW Ground water

HA Historical and Archeological 

HH Human Health 

LU Land Use

LR License Renewal and its Process

OL Opposition to License Renewal

OS Outside of Scope(a)

PA Postulated Accidents and Severe Accident Mitigation Alternatives (SAMA)

RW Radioactive & Non-Radioactive Waste

SE Socioeconomics

SR Support of License Renewal

SW Surface Water

(a) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental 

review of license renewal and include, but are not limited to, issues such as need for power, emergency 

preparedness, safety, security, terrorism, and spent nuclear fuel storage and disposal.

Comments received during scoping applicable to this environmental review are presented in this 

section, along with the NRC response. They are presented in the order shown in Table A-3. 

The comments that are outside the scope of the environmental review for LGS are not included 

here but can be found in the scoping summary report, which can be accessed through ADAMS 

Accession No. ML12131A499.

A-5 
Appendix A

Table A–3. Comment Response Location in Order of Resource Area

Comment category Page

Alternative Energy Sources (AL) A-6

Air & Meteorology (AM) A-9

Decommissioning (DC) A-9

Geology (GE) A-10

Groundwater (GW) A-11

Historical and Archeological (HA) A-12

Human Health (HH) A-13

Land Use (LU) A-19

License Renewal and its Process (LR) A-19

Opposition to License Renewal (OR) A-23

Postulated Accidents and SAMA (PA) A-27

Radioactive & Non-Radioactive Waste (RW) A-32

Socioeconomics (SE) A-33

Support of License Renewal (SR) A-33

Surface Water (SW) A-38

A.1.1 Alternative Energy Sources (AL)

Comment: 1-44-AL; We have had 26 years of insults to our environment, and I choose that 

word purposely, insults to our environment and costly nuclear power. We can replace it with 

safe, clean, renewable energy before 2029. That is a matter of scientific fact.

Comment: 4-8-AL; Solar wind, geothermal, ocean thermal, energy conservation and efficiency 

are now cheaper than nuclear power, along with being truly clean and safe. The Department of 

Energy 2006 report stated solar alone could provide 55 times our entire nation's energy needs 

which leads me to a point, there have been numerous studies proving the many dangerous and 

deadly consequences of nuclear power.

Comment: 5-3-AL; We also reviewed the alternatives if Limerick would not have its license 

renewed and another source of electric generation would need to be installed either here on site 

or someplace else to generate the replacement electricity. We concluded that any other means 

of generating the replacement electricity would have more of an impact on the environment than 

continued operation of Limerick. For instance, if Limerick could be replaced by a wind 

generation facility, the wind from [it] would have to occupy between 10 and 40 percent of all the 

land in the state of Delaware and that would have a huge impact on the land. If a solar facility 

could replace Limerick, it would need to cover 32 to 50 percent the entire land area of 

Montgomery County.

Comment: 6-10-AL; Please listen to this advice after years of doing my best for America. Rely 

on more and truly safe and renewable sources like solar, wind, and geothermal power. 

A patriotic duty to protect our kids.

A-6 
Appendix A

Comment: 16-7-AL; The NRC is required under the law in this review, the environmental 

review to consider renewable energy sources, alternatives. And that means need. Is there 

really a need for these two nuclear plants to operate and the answer is no. Simply stated if all 

the customers who receive power from these nuclear plants were to simply remove their hot 

water heaters and replace them with on-demand electric water heaters you would reduce the 

electric base load demand by 50 to 70 percent. You wouldn't need either one of those nuclear 

power plants to operate. If you take that further and introduce other energy conservation you 

would actually have the licensee shut down more of their other power plants because of you 

would need a demand. If you take wind energy which is plentiful up there in Pennsylvania and 

even the new solar panel which can operate when the sun isn’t shining on a cloudy day you 

could replace even more operating power plants. So these renewable energy sources even 

with respect to wind energy since you have a common grid throughout the United States you 

can have wind farms generate power to a common grid point and supplying the power that 

these nuclear plants are now providing. The NRC’s required under the law to consider these 

alternatives to extending this license. And I would hope that the NRC’s final evaluation and 

review shows a complete and thorough analysis of all these renewable energy sources 

including installing on demand hot water electric heater and doing an analysis of how many 

megawatts you're going to take off the grid and based on those evaluations make a licensing 

determination whether or not this license should be extended. Because 20 years from now all 

these renewable resources are going to be all that much more advanced and capable of 

supplying all that much more power than they’re currently supplying.

Comment: 25-5-AL; Other forms of energy can and must be utilized to meet consumption 

demands.

Comment: 27-1-AL; I am under the belief that the natural disaster in Japan is enough for 

Pennsylvania to make a move toward clean energy.

Comment: 28-2-AL; I support more healthy and efficient sources of energy such as Solar and 

Wind Power. Please stop ignoring the detrimental effects that this power plant is having on our 

environment, health, and children’s health...it’s time to move on to betters things for all involved.

Comment: 29-1-AL; I hope Exelon Energy does not get Renewed. I am sure we could find 

alternative energy that would not be contaminating the whole area.

Comment: 35-6-AL; The nuclear process is not an enlightened way to generate electrical 

energy. This plant needs to transition itself into a more intelligent way of generating energy by 

actually phasing out and safely shutting down the nuclear plant. By retraining its workers and 

adopting the safer green technologies, it could truly partner with the local community without 

putting its workers out of jobs.

Comment: 37-15-A, 39-16-AL; Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not 

Needed. It Can And Should Be Replaced With Safe, Clean, Renewable Energy.

Comment: 44-5-AL; We as a society need to wake up and start paying attention to the 

massive harm power plants can cause to the people, animals, water, air, etc. Why does 

everyone want to pay attention when it is way too late?? There are safer alternative forms of 

energy available to our country/communities. We should be working on them and training 

employees, who currently work for the nuclear power plants, how to work with safer forms of 

energy to help our country move forward in today’s society.

Comment: 44-10-AL; We deserve to live in a community where our air and water isn’t being 

contaminated constantly with hazardous chemicals, radiation, etc., when there are other energy 

alternatives out there that are being used that are safer for the community.

A-7 
Appendix A

Comment: 44-12-AL; Do your job knowing that you are doing what is morally right and safe for 

humanity and for my children and for the future of generations to come. Please help women 

have a chance to carry a baby full term without complications due to any possible air and water 

pollution that may have been caused by allowing more radiation into the environment when 

there are safer alternatives for energy.

Comment: 53-2-AL; We need cleaner air and water. We need to decrease radiation. We 

need clean, safe, renewable energy. 

Comment: 60-3-AL; Do not extend—Plenty of safe alternatives—water—solar—wind—

geothermal.

Comment: 60-19-AL; Can replace with clean renewable energy before current license expires. 

Response: In evaluating alternatives to license renewal, the NRC staff first selects energy 

technologies or options currently in commercial operation, as well as some technologies not 

currently in commercial operation but likely to be commercially available by the time the current 

LGS’s operating licenses expire, in 2024 and 2029. 

Second, the NRC staff screens the alternatives to remove those that cannot meet future system 

needs. Then, the remaining options are screened to remove those whose costs or benefits do 

not justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, 

constitute alternatives to the proposed action that the NRC staff evaluates in depth throughout

Chapter 8. 

The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS. In this chapter, the 

NRC staff examines the potential environmental impacts of alternatives to license renewal for 

LGS, as well as alternatives that may reduce or avoid adverse environmental impacts from 

license renewal, when and where these alternatives are applicable.

In addition to evaluating alternatives to the proposed action, the NRC staff also—when 

appropriate—examines alternatives that may reduce or avoid environmental impacts of the 

proposed action; the NRC staff does so to illustrate how such alternatives may mitigate potential 

impacts of license renewal.

The NRC staff considered 18 alternatives to the proposed action and then narrowed to the five 

alternatives considered. In addition to the five alternatives, the staff considered the no-action 

alternative (not renewing the operating license).

The alternatives evaluated in depth included the following:

• natural-gas-fired combined-cycle (NGCC)

• supercritical pulverized coal 

• new nuclear

• wind power

• purchased power

• no action

Other alternatives considered, but dismissed, are listed below:

• solar power

• combination alternative of wind, solar, and NGCC

• combination alternative of wind and compressed-air energy storage

• wood waste

• conventional hydroelectric power

• ocean wave and current energy

A-8 
Appendix A

• municipal solid waste

• biofuels

• oiled-fired power

• delayed retirement

• coal-fired integrated gasification combined-cycle 

• demand-side management (DSM)

A.1.2 Air & Meteorology (AM)

Comment: 1 -16-AM; Major air pollution issues under health-based standards of the Clean Air 

Act, 32 individual sources listed. Drastic, harmful increases permitted in particulate matter 

known also as PM-10 from the cooling towers, other air pollution increases also permitted.

Comment: 1-22-AM; They are a major air polluter under the Clean Air Act and to say they're 

not doing it anymore, they just asked for the conditions that would allow an eightfold increase in 

dangerous air pollution that actually is claimed to kill people, thousands of deaths per year. And 

they asked for an eightfold increase. As a matter of fact, these are all the air pollution sources 

and the pollutants they list in their own permit. If you add that to all the radiation emissions 

there’s a broad range of radionuclides.

Comment: 1-32-AM; [M]ajor air pollution under health-based standards of the Clean Air Act. 

A Title 5 permit being issued to this facility means by definition that they are a major air polluter 

under the federal Clean Air Act.

Comment: 37-2-AM, 39-3-AM; Major Air Pollution Under Health Based Standards of the Clean 

Air Act

Comment: 60-8-AM; They want increase emissions—Pollutants

Response: Air pollutant emissions associated with LGS operations are presented in 

Sections 2.2.2.1 of the SEIS. The NRC’s evaluation of LGS’s air emissions is presented in 

Section 4.2 of this SEIS. 

Comment: 35-3-AM; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

aging and inadequate equipment, its increased air pollution by particulate matter, its horrific 

destruction of Schuylkill river. 

Response: Aging management of plant systems is evaluated as part of the LRA safety review. 

The results of the staff’s safety review of the LRA for LGS will be documented in the staff’s 

safety evaluation report (SER).

Air pollutant emissions associated with LGS operations are presented in Sections 2.2.2.1 of the 

SEIS. The NRC’s evaluation of LGS’s air emissions is presented in Section 4.2 of this SEIS. 

Surface water resources at LGS, including the Schuylkill River, and the effects of plant 

operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 

the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon 

by LGS and including the sources of water used to augment low flows in the Schuylkill River.

A.1.3 Decommissioning (DC)

Comment: 34-2-DC; A firm closure plan should be approved before license renewal is 

accepted. This must include what is to be done with the site, where the nuclear waste will be 

disposed of etc.

A-9 
Appendix A

Response: Decommissioning would occur whether LGS were shut down at the end of its 

current operating license or at the end of the period of extended operation. Environmental 

impacts from the activities associated with the decommissioning of any reactor before or at the 

end of an initial or renewed license are evaluated in the GElS (NUREG-1437) and in 

NUREG-0586 Generic Environmental Impact Statement for Decommissioning Nuclear Facilities, 

Supplement 1, “Regarding the Decommissioning of Nuclear Power Reactors,” published 

in 2002. The findings from these two documents are used to support the findings in the SEIS by 

the use of tiering. Tiering is a process by which agencies eliminate repetitive discussions. The 

effects of license renewal on the impacts of decommissioning are stated in Chapter 7 of this 

SEIS.

A.1.4 Geology (GE)

Comment: 1-12- GE; Limerick, in addition, is now third on the earthquake risk list for nuclear 

plants in the United States.

Comment: 4-2-GE; [F]our months have passed since the NRC failed to get back to me when I 

asked how close the R[a]mapo fault line is to the Limerick nuclear reactors?

Comment: 4-14-GE; It took five months for the Nuclear Regulatory Commission to answer my 

question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! 

Two faults are dangerously close. Chalfont Fault is only 9 miles East. Ramapo Fault is 17 

miles Northwest. This is alarming!

Comment: 30-2-GE; Limerick should NOT be approved for an extension with their permit for 

the following reasons:

• Limerick is designated as one of the TOP THREE nuclear plants in the 

country based on it's construction (which is similar to the ones in Japan—and 

we see how they failed) and the fact that it sits on an earthquake fault line.

• The NRC JUST a few weeks ago stated that “more information needs to be 

done and studied” regarding further fortifying nuclear plants regarding 

earthquakes. Thus, until you folks know exactly what needs to be done, 

etc.THERE IS NOTHING TO APPROVE as long as Limerick sits in it's 

current position.

• Do NOT think that earthquakes only happen on the West Coast—as we 

JUST had a 6+ earthquake less than a month ago. BY ONLY luck was there 

no damage to the plant, environment or community.

Comment: 51-4-GE; Limerick is built on a fault

Comment: 52-5-GE; It is one of the six most dangerous plants in the country because [of] its 

proximity to an earthquake fault.

Comment: 60-2-GE; Earthquake Fault

Response: Geologic and seismic conditions were considered in the original design of nuclear 

power plants and are part of the license bases for operating plants. Seismic conditions are 

attributes of the geologic environment that are not affected by continued plant operations and 

refurbishment and are not expected to change appreciably during the license renewal term for 

all nuclear power plants. Nevertheless, as part of characterizing the environmental baseline 

(affected environment) and associated resource conditions of LGS and the vicinity, 

Section 2.2.3 of the SEIS includes a discussion of the current geologic environment, including 

its seismic setting. Specifically, the section includes a discussion of the Ramapo fault system. 

A-10
Appendix A

This fault system encompasses the Chalfont fault and other named geologic faults. In addition, 

the NRC and Exelon considered in Chapter 5 of this SEIS whether increased seismic risk could 

provide a seriously different picture of severe accidents mitigation at Limerick.

As noted in the section, the nearest mapped faults to LGS have not been geologically active for 

more than 140 million years.

To the extent that the comments express concern for the seismic design of LGS, the seismic 

design of structures are beyond the scope of the environmental review. NRC’s assessment of 

seismic hazards for existing nuclear power plants is a separate and distinct process from 

license renewal reviews. Seismic hazard issues are being addressed by the NRC on an 

ongoing basis at all licensed nuclear facilities. The NRC requires all licensees to take seismic 

activity into account to maintain safe operating conditions at all nuclear power plants. When 

new seismic hazard information becomes available, the NRC evaluates the new data and 

models to determine if any changes are needed at existing plants, regardless of whether or not 

a plant has renewed its license or is applying for license renewal. This reactor oversight 

process, which includes seismic safety, remains separate from license renewal.

Unrelated to license renewal, the NRC completed the Generic Issues Program Safety/Risk 

Assessment Stage for Generic Issue (GI) 199 in August 2010, “Implications of Updated 

Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing 

Plants,” which evaluated recent updates to estimates of the seismic hazard in the central and 

eastern United States. The results of the GI-199 Safety/Risk Assessment indicated that the 

currently operating nuclear power plants have adequate safety margin for seismic issues. The 

NRC’s assessment indicated that overall seismic risk estimates remain SMALL, and adequate 

protection is maintained. NRC Information Notice 2010–18 (ADAMS Accession 

No. ML101970221) was then issued to nuclear power plants and independent spent fuel 

storage installations (ISFSIs). It provided notice of the NRC’s intent to follow the appropriate 

regulatory process to request that operating plants and ISFSIs provide specific information 

relating to their facilities to enable the NRC staff to complete the Regulatory Assessment, in 

which candidate backfits would be identified and evaluated. The NRC then developed a draft 

Generic Letter to request needed data from power reactor licensees.

Further, following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the 

March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established the 

Near-Term Task Force, as directed by the Commission. The Japan Near-Term Task Force 

assessment resulted in the issuance of letters requesting information per Title 10 of the Code of 

Federal Regulations (10 CFR) 50.54(f) letter on March 12, 2012. These letters were issued to 

all power reactor licensees and holders of construction permits and address GI-199 in its 

entirety in recommendation 2.1 regarding seismic reevaluations, (ADAMS Accession 

No ML12056A046). The NRC staff will use this information, as well as information requested in 

the 10 CFR 50.54(f) letter, to determine if further regulatory action is needed, including issuing 

orders to modify, suspend, or revoke a license. 

A.1.5 Groundwater (GW)

Comment: 1-34-GW, 37-5-GW, 39-6-GW; Radioactive Groundwater Contamination.

Comment: 37-4-GW, 39-5-GW; Schuylkill River Depletion and Major Drink Water 

Contamination

Comment: 45-10-GW; Limerick contaminated groundwater. Radioactive leaks and spills over 

the years were never cleaned up. More radioactive leaks can be expected in the future through 

earthquakes, deterioration, and corrosion. Many residential well are very close to Limerick. 

A-11
Appendix A

Response: This comment deals with groundwater quality issues related to the operation of 

LGS. Groundwater resources at LGS, and the effects of plant operations on groundwater 

hydrology and quality, are presented in Sections 2.2.5 and 4.4 of the SEIS. Specifically, 

Section 2.2.5.1 discusses groundwater users at and in the vicinity of the plant, and 

Section 2.2.5.2 summarizes the results of the NRC’s review of Exelon’s Radiological 

Groundwater Protection Program (RGPP) for LGS, including the placement of site groundwater 

monitoring wells. As part of this evaluation, the NRC staff specifically reviewed the 

hydrogeologic investigation prepared for LGS in 2006 and the results of ongoing groundwater 

quality monitoring. Chapter 2 of this SEIS cites all studies reviewed by the NRC staff.

Based on the staff’s review, and as presented in Section 4.4.3 of this SEIS, no strontium-90 or 

gamma-emitting radionuclides have been detected in groundwater or surface water associated 

with LGS operations or at levels above natural background. While inadvertent releases of 

liquids containing tritium (a radioactive isotope of hydrogen) have occurred to the ground and 

subsurface at LGS, levels in groundwater have been less than one-tenth of the 

U.S. Environmental Protection Agency (EPA) established drinking water standard of 20,000 

picocuries per liter. No upward trend in tritium levels has been observed, and Exelon’s ongoing 

RGPP functions to detect and address potential new sources of groundwater contamination. 

Further, there are no offsite drinking water wells downgradient of LGS that could be affected by 

inadvertent releases of radionuclides to groundwater. 

A.1.6 Historical and Archaeological (HA)

Comment: 31-1-HA; Thank you for informing the Delaware Tribe on the proposed construction 

associated with the above referenced project. Our review indicates that there are no religious or 

culturally significant sites in the project area. As such, we defer comment to your office as well 

as to the State Historic Preservation Office and/or the State Archaeologist.

We wish to continue as a consulting party on this project and look forward to receiving a copy of 

the cultural resources survey report if one is performed. We also ask that if any human remains 

are accidentally unearthed during the course of the survey and/or the construction project that 

you cease development immediately and inform the Delaware Tribe of Indians of the inadvertent 

discovery.

Comment: 49-1-HA; Thank you for providing the Onondaga Nation with information about this 

project. If any changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 

have licenses that may be renewed in 2024 and 2029 respectively, therefore you may send 

updates and information until then.

In the event that during project construction, any archeological resources or remains, including, 

without limitation, human remains, funerary objects, sacred objects, or objects of cultural 

patrimony are uncovered, please immediately stop construction and contact me at 

(315) 952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at

(315) 475-2559.

Response: In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate 

compliance with section 106 of the National Historical Preservation Act with steps it has taken to 

meet its requirements under the National Environmental Policy Act (NEPA). An overview of 

consultation activities that occurred during the preparation of this SEIS is given in 

Section 4.10.6. All consultation parties will receive a copy of the draft SEIS to review and 

provide comments to the NRC. 

A-12
Appendix A

A.1.7 Human Health (HH)

Comment: 1-15-HH; Research has confirmed radiation in our children's baby teeth in this 

community.

Comment: 1-18-HH; Alarming cancer increases that have been well documented in this 

community repeatedly far higher than national and state averages after Limerick started 

operating until the late 1990s.

Comment: 1-25-HH; The sooner this place closes the better off we'll all be. Even if you look at 

infant mortality rates we have higher infant mortality rates and neonatal mortality rates far above 

state averages and even above Philadelphia and Reading, and we've had these for quite 

awhile. The fact is when babies are the most vulnerable in the womb what else would we 

expect? And by the way, for those of you who have been saying that ACE data is anecdotal 

today I have news for you. This infant mortality report for example is state data reported by 

EPA in 2003. Every cancer statistic that you see back there is based on Pennsylvania Cancer 

Registry statistics or CDC statistics. So it is not anecdotal, those are the cancer increases, 

those are the cancer above the national average that have happened here since Limerick 

started operating.

Comment: 1-26-HH; We have so many cancers above the national average. Childhood 

cancer, 92.5 percent higher than the national average. Think about that. We track the cost of 

one child with cancer diagnosed at six months to two years and up until that time it was 

$2.2 million. How many more kids have that above the national average? Cost that out and 

how many other cancers are above the national average?

Comment: 1-36-H; [D]ocumented alarming cancer increases especially in our children since 

Limerick started operating

Comment: 4-6-HH; There has been increased particulate matter in the air and other toxics 

from Limerick causing increased asthma, heart attacks, and strokes. And to add insult to injury, 

Limerick was granted a permit to allow an eight-fold increase in air pollution since 2009. Cancer 

rates in our area have skyrocketed since Limerick has been up and running in the '80s and 

rates have steadily increased.

Comment: 4-7-HH; The Toothfairy Project showed high levels of strontium 90, a radionuclide 

in baby teeth of children nearest to nuke plants. Baby teeth near Limerick plant had the highest 

levels in the whole United States. This stuff and God knows what else is in our bodies now 

thanks to a Nuclear Regulatory Commission that to put it nicely is less than enthusiastic about 

protecting us.

Comment: 6-1-HH; As a physician practicing radiology for over 50 years, I still have strong 

concern about cancer sensitivities from harmful radiation exposures, naturally. My medical 

colleagues share the same concerns because we have seen our cancer rates increase since 

the Limerick power plant started, especially thyroid cancer. It jumped to 78 percent higher here 

than the national average. And some of the people I talked to, this is because people are aging 

more now, getting older, so there are more cancers. But that's not true because in other areas 

similar to our area in Pottstown, they're not nearly getting the thyroid cancers that we are. This 

has been well established by the state.

Comment: 6-2-HH; Having attended a Hiroshima, Japan atom bomb clinic right after World 

War II, naturally I had a chance to see the worst results of harmful radiation. All those little kids 

I saw who only lived for a few days, it left me with a very sad memory. Of course, what is 

happening here will be taking much longer, but it sure is not good. I don't know whether you've 

heard that some scientists are already predicting that -- I'm sorry to tell you this, but nuclear 

A-13
Appendix A

energy has the capacity of destroying mankind. It may take about 100 years, but our whole 

world is exposed to the harmful effects, maybe not so much here in the United States, but the 

whole world can be affected.

Comment: 6-6-HH; According to the National Center of Disease Control, Pennsylvania ranks 

No. 1 for the highest incidence of Thyroid cancer. This occurred after installation of nuclear 

power plants in our area as well as in the rest of the State. Medical journals are reporting high 

rates of cancer near nuclear plants.

Comment: 6-8-HH; Incidentally, baby teeth studies have revealed Strontium 90 radioactive 

particles which can affect the child’s immune system for more illness.

Comment: 19-6-HH; but I hate to tell you I have so many friends and coworkers and people 

that are only 35, 40, 50 years old, cancer. And why? We have to stop and think. Go home, 

don't just always, you know, just go watch TV and get on your computer. Stop and think what 

we're doing to ourselves, our bodies, our children, our grandchildren.

This is again, this licensing renewal is coming down to human lives, the quality of our lives. 

Again, why all this cancer? Microwaves and electricity. So I won't go on and on, but I just think 

us as a group can't just all be just complaining about the power companies, we are the ones 

using the electricity. That's all I'm saying. Maybe we should cut back and we won't need power 

plants.

Comment: 21-2-HH; Some people don't understand about radiation and I read when the 

Japanese thing occurred and I heard on the news a radiologist talking about oh, the radiation is 

such a low amount. It really isn't the low amount of radiation exposure that we get incidentally 

in standing next to a nuclear power plant. It's three ten-thousandths of a gram of plutonium that 

is death for you if you breathe that dust particle. It's almost certain death. And the problem 

becomes you can't have -- and it's not going to be a nuclear bomb. It's going to catch on fire if 

the fuel pool girders were to fail and you'll have a cloud of a material that in and of itself you 

might not have radiation exposure to it but that particle when it deposits itself can be an issue 

much the same as fluoride is what causes thyroid cancer when it's a radioactive fluoride. That's 

why we're very careful in building a plant with no Teflon and no fluoride components

Comment: 36-1-HH; I am concerned about the effects of our surrounding air and water supply 

of my children and grandchildren, some of whom are already inflicted with cancer and other 

diseases. 

Comment: 37-1-HH, 39-2-HH; Radiation into Air and Water From Routine and Accidental 

Emissions

Comment: 37-7-HH, 39-8-HH; Alarming cancer increases, especially in children, since 

Limerick started operating

Comment: 37-14-HH, 39-15-HH; Increased Costs to the Public—More cancers and other 

costly illnesses, more emergency room visits and hospitalization from massive increases in 

PM-10 and TDS, treatment of public drinking water, environmental clean-up

Comment: 25-2-HH; The scientific statistics citing dramatic increase in cancer rates, infant 

mortality, and Schuylkill River water pollution is disturbing. 

Comment: 36-3-HH; I am more concerned about the effects of surrounding air and water 

supply and the future of my children and grandchildren, some of whom are already inflicted with 

cancer and other diseases.

Comment: 40-4-HH; it doesn’t take an accident or disaster for Limerick to poison the region’s 

residents with radiation. Radiation from Limerick’s routine and accidental emissions alone for

A-14
Appendix A

the past 26 years is reason enough to deny Exelon’s request. It’s not credible for NRC to claim 

continuous radiation levels are safe for me and my family when there is no safe level of 

exposure according to the National Academy of Sciences and Physicians for Social 

Responsibility.

NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by 

Exelon and DEP cannot be trusted. Exposure to radiation [is] known to cause cancer. It should 

be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis 

after Limerick started operating in the mid 1980s to late 1990s. Four cancer studies based on 

PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher 

than national and state averages, especially in children. Our children had the highest levels of 

Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 

Nuclear Plant released SR-90 into our air and water that got into the milk, vegetation, and food 

since Limerick started operating.

Comment: 40-5-HH; Thyroid cancer increased by 128% from 1985 to 1997—was as side note, 

with no family history or other obvious risk factors in my life, I was recently treated for thyroid 

cancer. Since my diagnosis, I have learned of many other locals like me. It’s scary to think the 

choice of where we lived could kill us.

Comment: 41-3-HH; Exposure to radiation is known to cause cancer. NRC has not done any 

radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP 

cannot be trusted—it’s ridiculous to think they could monitor themselves. It should be obvious 

to NRC that Limerick played a major role in our cancer crisis after Limerick started operating 

mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC 

showed skyrocketing rates for several cancers much higher than national and state averages, 

especially children—innocent children. Thyroid cancer increased 128% from 1985 to 1997. I 

have local friends and family with thyroid cancer and brain cancer—not one, but several. Sadly 

it is uncommon in other areas of the country. It used to be uncommon here too—prior to 

Limerick. Would you want to live here? Would you approve a license renewal so close to 

home? Your job is to safely review the facts.

Comment: 42-2-HH; The increased risk of cancer is well founded in the literature also.

Comment: 44-8-HH; The most alarming and compelling thing to me as a taxpayer, 

homeowner, and mother is the overwhelming and alarming cancer increases to the public after 

Limerick had started operating. The CDC website showed 92.5% higher than the national 

average for childhood cancer in six communities close to the Limerick Nuclear Plant which 

included, Pottstown, West Pottsgrove, Lower Pottsgrove, North Conventry, and Douglas Berks 

Township from cancers diagnosed from 1995-1999. The Pennsylvannia State Cancer Registry 

For Montgomery County from 1985-86 to 1996-97 also shows cancer rates skyrocketed in 

Montgomery County where the Limerick Nuclear Plant is located during the Mid 80’s and 90’s 

after they opened. Prostate Cancer increased 132%, Thyroid Cancer increased 128%, Kidney 

cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin’s Disease increase 67%, 

Non-Hogdin’s Lymphoma increased 61%, Breast cancer increased 61%, Pancreas cancer 

increased 54%, and Leukemia increased 48%.

Radiation exposure can cause cancer and other serious disease and disability, at any level of 

exposure according the National Academy of Sciences and Physicians Responsibility. 

Permissible radiation levels does not mean that they are safe levels for everyone in the 

community. Most permissible levels based on the average healthy adult. They are not levels 

that were based or researched for fetuses, infants, toddlers, and children or pets. Fetuses, 

infants, children, pets, and the elderly and immuned compromised individuals are at most risk of 

health problems. There is a broad range of dangerous randionulcides routinely released into air 

A-15
Appendix A

and water from the Limerick Nuclear Plant as well as any accidental releases. Permissible 

radiation levels does not mean that they are safe radiation levels, it only means that they are 

allowed.

Comment: 44-9-HH; I have children as well as other loved ones that have or have had 

allergies, asthma, learning disabilities, speech disabilities, behavioral disabilities, thyroid 

conditions, cancers, skin disorders and irritation, etc. I know neighbors and other community 

members that have suffered from the same and more.

Comment: 45-6-HH; But, it doesn’t take an accident or disaster for Limerick to poison the 

region’s residents with radiation. Radiation from Limerick routine and accidental emissions 

alone for the past 26 years is reason enough to deny Exelon’s request. It’s not credible for NRC 

to claim continuous radiation levels are safe for me and my family when there is no safe level of 

exposure according to the National Academy of Sciences and Physicians for Social 

Responsibility.

Comment: 45-7-HH; NRC is failing to acknowledge obvious health harms from Limerick’s 

continuous additive, cumulative, and synergistic radiation releases which get into water, food, 

soil, vegetation, milk, and our bodies. NRC has no idea what health harms some of the region’s 

residents experienced from Limerick Nuclear Plant. NRC never did any radiation monitoring or 

testing at Limerick. Evidence shows testing done by Exelon and DEP cannot by trusted.

Comment: 45-8-HH; Exposure to radiation is known to cause cancer. It should be obvious to 

the NRC that Limerick played a major role in our tragic, well documented cancer crisis after 

Limerick started operating in the mid 1980s to the late 1990s. Four cancer studies based on 

PA Cancer Registry and CDC data showed skyrocketing rate for several cancers for higher than 

the national and state averages, especially children. Our children had the highest levels of 

Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 

Nuclear Plant release SR-90 into our air and water that got into the milk, vegetation, and food 

since Limerick started operating. Thyroid cancer increased by 128% from 1985 to 1997. Other 

cancers rose dramatically as well.

Comment: 46-6-HH; Finally, my concerns regarding the impact of this nuclear power plant on 

my community are not limited to catastrophic scenarios that might potentially occur. There have 

been studies published in health journals that show a higher incidence of certain illness—

particular among children—in communities surrounding nuclear plants. While these studies 

were conducted in a variety of locations, they seem to be consistent with some of the data that 

Pottstown’s local Alliance for a Clean Environment presents on its website regarding increased 

cancer and leukemia rates–also especially among children–in the greater Pottstown area.

Comment: 47-2-HH; I am fully aware of the amount of cancer that is prevalent in this area.

Comment: 48-2-HH; I moved to Pottstown, Pa., some time ago in perfect health. In 2006, 

I was diagnosed with prostate cancer. Although, I cannot prove it was a direct cause of the 

nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior 

to the relicensing of the Limerick plant by reputable sources not by corporate interests groups 

that can manipulate the statistics in Exelon’s favor.

Wouldn’t it be in the best interest of our community and surrounding communities if the higher 

cancer rate was due the Limerick power plant? This question is a “no brainer.” There is plenty 

of time for testing to be done prior to relicensing.

Comment: 51-3-HH; Cancer rates are higher than the national average and NRC is going with 

the status quo.

A-16
Appendix A

Comment: 52-6-HH; The surrounding area has abnormally high cancer rates among adults 

and children.

Comment: 57-3-HH; I also feel its presence has led to [an] increase of cancer in our area.

Comment: 58-1-HH; I feel that there is a lot of people that had not known to report anything 

because of not knowing who to go to. I don't understand why the hospitals don't give statistical 

information based on areas?

Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's 

Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. 

We had lived on Limerick Center Road for most of our young lives and now with our kids. I don't 

know what other information you would need but I would be happy to get you whatever you 

might need.

Comment: 60-10-HH; High infant mortality rates and neo natal, cancer increase, thyroid 

cancer rates 70% higher 

Comment: 60-14-HH; cancer increases, especially children 

Response: The NRC’s mission is to protect the public health and safety and the environment 

from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC’s 

regulatory limits for radiological protection are set to protect workers and the public from the 

harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. 

Radiation standards reflect extensive scientific study by national and international organizations. 

The NRC actively participates and monitors the work of these organizations to keep current on 

the latest trends in radiation protection.

Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art 

study on cancer risk for populations surrounding nuclear power facilities. The NAS study will 

update the 1990 U.S. National Institutes of Health—NCI report, “Cancer in Populations Living 

near Nuclear Facilities.”

The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify 

scientifically sound approaches for carrying out an epidemiological study of cancer risks. This 

scoping study began on September 1, 2010, and will last for 15 months. The result of this 

Phase 1 study will be used to inform the design of the cancer risk assessment, which will be 

carried out in a future Phase 2 study.

Although radiation can cause cancers at high doses, currently there are no data to 

unequivocally establish the occurrence of cancer following exposures to low doses, below about 

10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of 

radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is 

higher for larger radiation exposures. Therefore, a linear, no-threshold dose response 

relationship is used to describe the relationship between radiation dose and detriments such as 

cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to 

result in an incremental increase in health risk. This theory is accepted by the NRC as a 

conservative model for estimating health risks from radiation exposure, recognizing that the 

model probably over-estimates those risks. Based on this theory, the NRC conservatively 

establishes limits for radioactive effluents and radiation exposures for workers and members of 

the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC 

(10 CFR Part 20, “Standards for Protection Against Radiation”), the NRC has imposed 

additional constraints on nuclear power reactors. Each nuclear power reactor, including LGS, 

has license conditions that limit the total annual whole body dose to a member of the public 

outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the 

A-17
Appendix A

dose to a member of the public from radioactive material in gaseous effluents to an annual dose 

of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem 

(0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ.

Chapter 4 of this SEIS discusses the radiological environmental monitoring program (REMP) 

that LGS uses for environmental monitoring. The purpose of the LGS Radiological REMP is to 

evaluate the radiological impact that operation may have on the environment. The program is 

designed to highlight and look at specific consumption pathways for local inhabitants and 

special interest groups. The LGS REMP is made up of three categories based on the exposure

pathways to the public. They are as follows: atmospheric, aquatic, and ambient gamma 

radiation. The atmospheric samples taken around LGS are airborne particulate, airborne iodine, 

milk, and broad leaf vegetation. Sampling for the LGS REMP program is performed as 

specified in Appendix I to 10 CFR Part 50, “Domestic licensing of production and utilization 

facilities,” as well as agreements made with the State of Pennsylvania Department of 

Environmental Protection (PDEP), Bureau of Radiation Protection.

The amount of radioactive material released from nuclear power facilities is well measured, well 

monitored, and known to be very small. The doses of radiation that are received by members of 

the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 

millirem) that resulting cancers attributed to the radiation have not been observed and would not 

be expected. To put this in perspective, each person in this country receives a total annual 

dose of about 300 mrems (3 mSv) from natural sources of radiation (i.e., radon, 200 mrem; 

cosmic rays, 2 mrem; terrestrial (soil and rocks), 28 mrem; and radiation within our body, 

39 mrem) and about 63 mrem (0.63 mSv) from man-made sources (i.e., medical x-rays, 

39 mrem; nuclear medicine, 14 mrem; consumer products, 10 mrem; occupational, 0.9 mrem; 

nuclear fuel cycle, <1 mrem; and fallout, <1 mrem).

A number of studies have been performed to examine the health effects around nuclear power 

facilities. The following is a list of some of the studies that have been conducted:

• In 1990, at the request of Congress, the National Cancer Institute (NCI) 

conducted a study of cancer mortality rates around 52 nuclear power plants 

and 10 other nuclear facilities. The study covered the period from 1950 to 

1984 and evaluated the change in mortality rates before and during facility 

operations. The study concluded there was no evidence that nuclear facilities 

may be causally linked to excess deaths from leukemia or from other cancers 

in populations living nearby.

• Investigators from the University of Pittsburgh found no link between radiation 

released during the 1979 accident at the Three Mile Island Nuclear Station 

and cancer deaths among nearby residents. This study followed more than 

32,000 people who lived within 5 mi (8 km) of the facility at the time of the 

accident.

• In January 2001, the Connecticut Academy of Sciences and Engineering 

issued a report on a study around the Haddam Neck Nuclear Power Plant, in 

Connecticut, and concluded that exposures to radionuclides were so low as 

to be negligible and found no meaningful associations to the cancers studied.

• In 2001, the American Cancer Society concluded that, although reports about 

cancer clusters in some communities have raised public concern, studies 

show that clusters do not occur more often near nuclear plants than they do 

by chance elsewhere in the population. Likewise, there is no evidence linking 

A-18
Appendix A

the isotope strontium-90 with increases in breast cancer, prostate cancer, or 

childhood cancer rates.

• In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims 

that there are striking increases in cancer rates in southeastern Florida 

counties caused by increased radiation exposures from nuclear power plants. 

However, using the same data to reconstruct the calculations on which the 

claims were based, Florida officials did not identify unusually high rates of 

cancers in these counties compared with the rest of the state of Florida and 

the nation. 

• In 2000, the Illinois Public Health Department compared childhood cancer 

statistics for counties with nuclear power plants to similar counties without 

nuclear plants and found no statistically significant difference.

In summary, there are no studies to date that are accepted by the nation’s leading scientific 

authorities that indicate a causative relationship between radiation dose from nuclear power 

facilities and cancer in the general public. The amount of radioactive material released from 

nuclear power facilities is well measured, well monitored, and known to be very small.

The staff addresses human health impacts of renewing the LGS operating licenses in 

Chapters 2 and 4 of the draft SEIS.

A.1.8 Land Use (LU)

Comment: 54-5-LU; The county has been working hard to develop an interconnected system 

of open space and trails along the Schuylkill River and within other natural resource areas of the 

county. In doing this, the county has provided funding to local municipalities and nonprofit 

conservation organizations to purchase open space and park land; acquired county land and 

agriculture easements; and developed trails. The Limerick Generating Station site contains 

significant land along the Schuylkill River that has been identified as part of the Schuylkill River 

Greenway in the county plan. The use and management of these lands relative to the county 

open space and natural areas inventory plans should be evaluated in the relicensing process.

Response: Current onsite and offsite land use conditions in the vicinity of LGS are described in 

Sections 2.2.1 and 2.2.9.3 of this SEIS. The NRC’s evaluation of LGS’s impacts on onsite and 

offsite land use during the license renewal term is presented Section 4.1 of this SEIS. While 

license renewal is not expected to affect the use and management of LGS lands identified as 

part of the Schuylkill River Greenway, this information will be evaluated with other potential 

cumulative effects in Section 4.12.6.

A.1.9 License Renewal and its Process (LR)

Comment: 1-4-LR; Current 40-year operating licenses expire in 2024 and 2029. Why the rush 

to renew these licenses now?

Comment: 1-19-LR; While NRC is required to prepare a supplement to the Limerick 

Environmental Impact Statement for license renewal, we have little confidence in the process 

based on NRC's regulatory history. It would be difficult to enumerate a short list, so I'm going to 

rely on written documents.

Comment: 4-9-LR; But my big question of the day is why is Exelon applying for an extension 

18 years ahead of time?

A-19
Appendix A

Comment: 4-13-LR; Exelon is rushing the timeline to reissue a license (18 years ahead of 

time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the 

NRC to get back me concerning an already known survey of fault lines.

Comment: 8-1-LR; I'm a retired Lutheran pastor and my concern today is with the speed at 

which this application process is going. I mean it seems to me that to predict what 

environmental factors will be in place 13 years hence and 18 years hence, posits a kind of 

omniscience and prescience that we should attribute to Almighty God, but certainly not to any of 

us human beings. I would favor a slower process.

Comment: 8-5-LR; As I stated then, I continue to be concerned and puzzled about the very 

early and pre-mature application of Exelon to extend the licenses of the towers. One [of] those 

does not come up for renewal until 2024 and the other 2029. I ask the NRC not work on the 

relicensing for this facility for at least ten years. The wait could only ensure better information. 

The public can not possibly benefit from a decision to renew the licenses at this time. The best 

decision will be made based on the best possible information. The NRC does not have the best 

information this early. Much will happen in the next ten years. I urge NRC to wait and see how 

any of it affects the prospect of continuing these plants at that later date.

What can happen in the next ten years that we can all learn from the relevantly could be 

anything. It may be better information about how natural disasters are affecting nuclear 

facilities; we may know more about weather patterns that could cause damage. We will 

certainly know more about the world situation in terms of advances in terrorist technological 

capabilities and goals. We will know more about how well nuclear plants in general and the 

Limerick facility are faring as they continue age. If someone steps forward to fund studies, we 

will know yet more about cancer rates in the nuclear zones

Comment: 16-4-LR; This particular nuclear plant, these plants, you know, their license is 

already good till 2024. Why are we here now 12 years ahead of time trying to extend this 

license? And the only reason is because it's a foot race the NRC's in with Congress and 

nothing more. This has nothing to do with protecting public health and safety, it's the NRC's 

zeal to continue to rubber-stamp these license extensions without allowing citizens due process 

like I already talked about and without doing a cost intense and thorough review.

Comment: 19-4-LR; He was stating the fact why are we re-licensing them, what, 12 years 

ahead of time. To me that is absurd. Like maybe a year before or they have to do some 

studies, two years before. Why do they want us, and I love Thomas's words, rubber-stamp 

something? Twelve years beforehand to go into what, 2024 for Unit 1 was it and 2029 for 

Unit 2? Why do they need to push this licensing renewal? You've got to stop and think.

Comment: 25-1-LR; First of all, considering the impact of the outcome to many area residents, 

this forum was not widely publicized for local citizens to be aware of this important matter and 

offer feedback. Secondly, it does not make sense that Exelon is pursuing renewal for a license 

that does not expire until 2024.

Comment: 30-1-LR; It is NOT due to expire until 2024—thus, Exelon has nothing to [lose] but 

getting an extension sooner than later so they can sit back and relax operating for the next 

20+ years. 

Comment: 30-13-LR; Since the reactor has until 2024—why the rush, and only one public 

meeting. I if you have not heard it, you will. There is a major public outrage over this one 

meeting and not know about it until too late. People want public meetings so that people hear 

that many are against this plant rather than just submitting comments to the NRC which appears 

to be rubber stamping license requests—which is not comforting to me and many.

A-20
Appendix A

Comment: 3-1-LR; Why is the request so early—The NRC should get a request closer to [the] 

expiration date. Also, the inspection should [be] done closer to the expiration date. In 2023, 

not 2013.

Comment: 34-1-LR; Why is there rush to renew the license? It is not due until 2024, approval 

at the earliest should be 2019. This would allow 5 years for the business plan of PECO to either 

continue or close the plant and make arrangements for additional power to replace the closed 

plant.

Comment: 41-1-LR; The possible renewal of Limerick Nuclear Plant’s license for 20 years past 

its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a 

great deal. It’s hard to understand why something this major would be done so far in advance. 

It’s IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth 

would this be renewed early? It’s lengthy process that could begin earlier, but in no way should 

something this important be rushed through now. Why not wait until closer to the expiration 

dates, and then seek approval? I understand this how the original guidelines were set up—but 

those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 

jeopardizing the health of millions. Renewing this license could be catastrophic to millions.

Comment: 48-3-LR; Also, why the hurry? Common sense would indicate that Exelon knows 

something which we are not aware. Why must the license be renewed at this time when they 

are licensed through 2024 and 2029?

Again, Why The Hurry? To relicense now is not the best interest of everyone in our area. 

Comment: 56-2-LR; Finally, we have grave misgivings regarding the future time-dependence, 

accuracy, and relevance of the licensee’s current ER, as presumptively incorporated in the 

NRC’s planned SEIS for LGS license extension, given that such license extension will not 

become effective until the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for 

Unit 2. We submit that any decision to relicense these units must be supported by the most 

timely NEPA and SAMA analysis obtainable within a reasonable interval (e.g.[,] five years) prior 

to actual expiration of the existing licenses.

Intervals of 12 and 17 years are not required for corporate planning purposes and are far too 

long to credibly sustain the accuracy and relevance of NEPA analyses, or for the NRC to 

accurately project both the future condition of the plant, the future state of nuclear safety 

knowledge, trends in local resource use, population, and the affected environment, and the 

future range of reasonable electricity supply alternatives to LGS license extension. By 

comparison, major government owned nuclear installations, such as nuclear laboratories and 

weapon production sites, are required to conduct site-wide NEPA reviews of their operations 

and facility plans every\five years. Using this federal standard for timeliness, the NRC’s NEPA 

analysis for LGS relicensing should not commence before 2019, for Unit 1, and before 2024 for 

Unit 2, or should be subjected to mandatory reassessment and supplementation after those 

dates.

Comment: 60-5-LR; 12 years ahead of time—no way to guarantee safety

Comment: 60-13-LR; NRC should not be considering this so far in advance—no way to assure 

safety—shut it down

Response: According to NRC regulations, 10 CFR Part 54, “Requirements for renewal of 

operating licenses for nuclear power plants,” a nuclear power plant licensee may apply to the 

NRC to renew a license as early as 20 years before expiration of the current license. The NRC

determined that 20 years of operating experience is sufficient to assess aging and 

environmental issues at the site. Additionally, 20 years is a reasonable lead period because if 

A-21
Appendix A

the NRC denies the license renewal application, it takes about 10 years to design and construct 

major new generating facilities, and long lead time times are required by energy-planning 

decisionmakers.

Comment: 54-7-LR; As part of the environmental assessment process and the evaluation of 

the plant safety and long term operational capacity, we think that it is important for the NRC to 

maintain close communication with the community surrounding the plant. Overall education

about the plant and the associated risks presented by its operation should be provided in a 

variety of ways so that the public is better informed about the plant and the overall evaluation 

taking place as part of the relicensing.

Response: The NRC’s Office of Public Affairs (OPA) is available to address the public’s

concerns and questions regarding nuclear safety and information regarding about LGS. The 

office follows news coverage of the agency and responds to media and public inquiries. If 

members of the public have questions or comments about the NRC, nuclear safety, or related 

topics, they can contact OPA at OPA.Resource@nrc.gov. For specific questions and concerns 

regarding Limerick, the public can contact the Region I OPA at OPA1.Resource.@nrc.gov. 

Additional contact information for OPA can be accessed at 

http://www.nrc.gov/about-nrc/organization/opafuncdesc.html

Comment: 1-6-LR; The public was led to believe that Limerick's generators, fuel pools, and 

miles of underground pipes and cables could operate safely for 40 years and then the facility 

would close. Is Exelon fearful that the longer they wait the more serious problems may arise?

Response: The original licenses for commercial nuclear power plants were granted for 40 year 

period, which was set by the Atomic Energy Act 1954 and the NRC’s regulations. It was 

imposed for economic and antitrust reasons rather than technical limitations of the plant. 

According NRC regulations, 10 CFR Part 54, a nuclear power plant licensee may apply to the 

NRC to renew a license as early as 20 years before expiration of the current license. Part 54 

requires the applicant to demonstrate that it can successfully manage aging at the facility during 

the period of extended operation.

Comment: 22-1-LR; I'm a resident of Phoenixville. I found out about this meeting because I 

scan a lot of newspaper websites. I found the notice of the meeting on the West Chester Daily 

Local website. Didn't find it in the Phoenixville paper, didn't see it in the Philadelphia 

newspaper, didn't hear about it on any of the local radio stations, didn't hear about it on cable, 

didn't hear about it on any of the television.

Comment: 60-20-LR; Should have been more public notice for hearing—Mail notices so 

people have an opportunity to attend.

Response: The NRC provides notice of the environmental public meetings through the Federal 

Register, press releases, and local advertisements. The public also can get information about 

all NRC public meetings at the NRC public Web site, 

http://www.nrc.gov/public-involve/public-meetings/index.cfm. The public also can receive public 

meeting notices and press releases by subscribing to e-mail notices for reactor correspondence 

for Limerick at http://www.nrc.gov/public-involve/listserver/plants-by-region.html. 

Comment: 22-3-LR: The slide behind me documents exactly two libraries that the documents 

are going to go in. Why not in my library in Phoenixville? Why not in Montgomery County and 

Norristown and all of the other public libraries that are in areas that can be affected by the 

plume should something happen here? Why are the documents in such a restricted area?

Response: The NRC contacts the local libraries in the communities surrounding the plant to 

ask if the agency could send them copies of license renewal applications and other documents 

A-22
Appendix A

related to the license renewal review so that they could be accessed by members of the public. 

However, some libraries have limited shelf space and may not be able to accommodate the 

NRC. Members of the public also can access the license renewal application and SEIS on the 

Limerick license renewal Web page on the NRC public Web site. The public can access the site 

at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html. 

Additionally, the NRC will have hard copies and CDs of the draft SEIS available for the public 

during the public meeting on the draft SEIS. Members of the public also can contact the NRC to 

request a hard copy or CD of the SEIS.

Comment: 16-2-LR; And I'd like to correct that statement. He stated that the NRC is extending 

the original operating license which was granted by the NRC for a 40-year period of time that 

that initial 40- year license was not based on safety considerations or technical considerations. 

But that's absolutely not true and there was recently a year-long investigative report done by the 

Associated Press who interviewed expert nuclear personnel, engineers, safety engineers in the 

nuclear industry who told them that the 40-year licenses issued by the NRC for 104 nuclear 

plants in the United States was based on safety and technical—safety technical analysis. So 

these proceedings, these license extension proceedings like the one we're currently at are a 

rubber-stamping of these 20-year license extensions.

Comment: 16-3-LR; This is in fact a foot race between the Nuclear Regulatory Commission 

and the United States Congress where Congress wants to stop this process, put a moratorium 

on the re-licensing until the Fukushima disasters can be fully understood and the enhancement 

enacted in August for our power plants here.

Response: As a result of Fukushima, the NRC issued three orders requiring safety 

enhancements of operating reactors, construction permit holders, and combined license 

holders. These orders require nuclear power plants to implement safety enhancements related 

to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at 

plants, (2) ways to ensure reliable hardened containment vents, and (3) ways to enhance spent 

fuel pool instrumentation. The plants are required to promptly begin implementation of the 

safety enhancements and complete implementation within two refueling outages or by 

December 31, 2016, whichever comes first. In addition, the NRC issued a request for

information asking each licensee to reevaluate the seismic and flooding hazards at the site 

using present-day methods and information, conduct walkdowns of its facilities to ensure 

protection against the hazards in its current design basis, and reevaluate emergency 

communications systems and staffing levels. LGS is required to comply with the NRC orders or 

revised regulations whether or not the operating licenses are renewed.

A.1.10 Opposition to License Renewal (OR)

Comment: 1-5-OR; We urge the NRC to say no to Exelon's requested license renewals.

Comment: 1-20-LR; It’s long past time for the NRC to summon the courage to do the right 

thing in our judgment and actually protect the environment and the public, rather than the 

industry.

Comment: 1-21-OR; Based on the compelling body of evidence of environmental harms to 

date and the enormous increased population in proximity to this facility, Limerick Nuclear Plant 

must be closed by 2029. There is no amount of energy production that is worth risking the lives 

of so many people.

Comment: 1-29-OR; Nuclear Regulatory Commission today and that is very simply that 

Limerick nuclear power plant must be closed by the NRC, not re-licensed until 2049.

A-23
Appendix A

Comment: 6-5-OR; So please, ask your politicians, reliable politicians to close the Limerick 

power plant. Let's save America for our kids and descendants

Comment: 6-9-OR; We can’t control the use of nuclear in the rest of the world, but we can 

keep the U.S. safer by eliminating nuclear energies. Fortunately, many European allies 

including Australia have decided to phase out reactors. We should join them [to] reduce human 

suffering. Also this can reduce our increasing costs of health care.

Comment: 6-11-OR; Limerick Power Plant is ranked in the top 3 riskiest nuclear power plants 

in the U.S.A. Limerick Power Plant must be closed not relicensed.

Comment: 10-1-OR; If Limerick Unit 1 or 2 fails, all hell breaks loose, no disrespect. That's 

what a nuclear failure is, hell. It affects everybody in this room, everybody in the community, 

everybody in the tri-state area, not for a week, but for decades. It's very, very last thing we want 

to happen.

And I think we're putting ourselves in harm's way by taking something that had a lifespan of 

40 years and adding another 20 to it. It doesn't make sense. The only way to rationalize it is 

through our personal fear of being inconvenienced because we lose a very, very good source of 

power. It's done a great job for us. But like me, you get to a point where your ability to provide 

a great job is at an end and things start deteriorating. Let’s not put ourselves in that position. 

Let’s make an intelligent decision now and allow these two units to expire at their nameplate 

time.

Comment: 19-3-OR; So from day one I think power plants never should have been built but 

now that they are here why would we ever want to re-license.

Comment: 25-4-OR; I attend to agree with the fourteen reasons provided by the Alliance For A 

Clean Environment why Exelon should be denied the renewal license. In my opinion, the 

long-term negative consequences caused by the Limerick Generating Station far outweigh any 

possible benefits it may contribute.

Comment: 26-1-OR; Please do NOT extend the Limerick licenses!

Comment: 27-2-OR; Renewing Limerick’s license just as controversies are arising with pushes 

to move from dependence on Nuclear energy is a bold business strategy by them. I don’t think 

this the right move to make. A long term contract will limit any sort of wiggle room to address 

future issues that may arise.

I ask that you please consider the future of our great state. I don’t think oil or nuclear energy is 

the way. I truly believe in heart, that in order to protect the health of our population for the 

future, we must change our ways today.

Comment: 28-1-OR; I object being continuously poisoned by the Limerick Nuclear Plant’s 

radiation and other dangerous toxins. Please do not allow for an extension of the Limerick 

Nuclear Power Plant’s operation license. 

Comment: 29-2-OR; The Reactor time has served its years and should not be renewed.

Comment: 30-10-OR; I feel firmly and many in the community feel the exact same way, that 

there is no reason to approve NOW (especially so far in advance, with no answer on usage on 

rods nor what needs to be done to prevent a meltdown due to an earthquake, etc.) or Ever since 

the population will only increase and the facility age further. It is the wrong timing, wrong plant, 

wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and “energy” to develop 

solar fields, etc... They would rather beat the hell out of a high efficiency plan at any and all cost 

to the environment and community. This where the NRC does the right thing and says NO until 

a year before it expires. 

A-24
Appendix A

Comment: 35-1-OR; Limerick Nuclear’s influence is vast and horrific. This industry is a 

behemoth that has not been honest with the public about its true impact, forming its own 

"environmental" partnerships that are pure pronuclear propaganda tools. It's economic 

contributions are miniscule when compared to its enormous profits, while destroying our quality 

of life. The nuclear process’s devastating environmental effect on our community cannot be 

understated.

Comment: 35-7-OR; Ordinary daily nuclear generation has had devastating community-wide 

consequences that need to be addressed. Re-licensing should not even be a consideration! 

The NRC must fully investigate the environmental concerns presented Dr. Lewis and Donna 

Cuthbert (ACE), Dr. Winter, and each resident who so civilly represented this community's 

concerns at the September 22, 2011 hearings. The Limerick Nuclear Power Plant should NOT 

be re-licensed and should, instead, begin to address the pollution issues it has already created 

as it seriously and carefully shuts down its reactors.

Comment: 38-1-OR; I’m writing to you to state my opposition to the relicensing of Limerick 

Generating Station in Limerick Township, Pennsylvania.

Comment: 40-1-OR; I attended the recent meeting on the possible renewal of Limerick 

Nuclear Plant’s license for 20 years past its current 2024 and 2029 expiration dates. I strongly 

believe, as do many of my local friends and family that the Limerick Nuclear Plant must be 

closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 

jeopardizing the health of thousands and thousands of people in neighboring communities. 

There is substantial evidence readily available which justifies closing Limerick. Renewing this 

license could lead to a catastrophic meltdown.

Comment: 40-6-OR; It would be careless, unethical and immoral for NRC to approve Exelon’s 

requested license extensions Limerick Nuclear Power Plant. Limerick Nuclear Power Plant 

must be closed by 2029.

Comment: 41-4-OR; Just remember, it would be careless, unethical and immoral for NRC to 

approve Exelon’s requested license extensions for Limerick Nuclear Power Plant. Limerick 

Nuclear Plant must be closed by 2029.

Comment: 42-3-OR; Why does the NRC think they can play God with people lives? It is no 

longer debatable, shut it down before our very lives are jeopardized.

So-called quality life issues addressed as part of public debate, e.g.[,] “the power is always on” 

seems irrelevant to us when our families are required to evacuate during disaster. Limerick 

must be closed and NOT relicensed at any cost, specifically the cost of life itself!

Comment: 43-1-OR; Do NOT renew Limerick licenses. It’s too dangerous and too old. Please 

listen to their neighbors like us.

Comment: 44-1-OR; There are so many reasons why you as a group should already know that 

it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, 

wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from 

re-licensing. The problem that always seems to come up at some of the public hearings and 

sessions where businesses/corporations want to expand and become bigger and run their 

businesses long past the time that they should truly be allowed in order keep safe, always 

comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these 

things occur, people and businesses turn a “blind eye” so to speak to the dangers of allowing a 

business like the Limerick Power Plant to renew its license again. That is unacceptable. I 

expect and demand better service from you to help protect myself and my family from harm!

A-25
Appendix A

Comment: 44-4-OR; It is disgusting and heart wrenching to know that officials and 

organizations are not paying attention to what can happen to the public if Limerick Power Plant 

continues to operate longer than expected. Ignoring the obvious problems our community is 

facing and hoping that after they serve their term, it will be someone else problem to deal with is 

unacceptable. Now is the time. Step up and [do] what is morally right for humanity

Comment: 44-11-OR; I expect you to what is morally right now for me, my family, my 

neighbors, my community, and the pets, wildlife, air, water, and environmental in whole by 

rejecting, refusing, and opposing Limerick Power Plant from relicensing to run their business 

longer than originally planned for 2029. 

Comment: 45-1-OR; I urge NRC to deny Exelon’s request to renew Limerick Nuclear Plant’s 

license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant 

must be closed, not relicensed, for many valid reasons. Approval of Limerick Nuclear Plant to 

be relicensed until 2049 would be reckless and would show blatant disregard for the health and 

safety of the public. There is more than sufficient evidence of harms and threats to justify 

closing Limerick. There are too many things beyond NRC’s control that could lead to a 

catastrophic meltdown.

Comment: 45-11-OR; It would be both unethical and immoral for NRC to approve Exelon’s 

requested license extensions for Limerick Nuclear Power Plant. All of the unprecedented 

harms, threats, risks from Limerick Nuclear Plant will increase if NRC approves and additional 

20 year Limerick license extension, until 2049. Limerick Nuclear Plant must be closed by 2029.

Comment: 46-1-OR; I am writing to express my opposition to the re-licensing of Limerick 

nuclear power generating station, which is located about 20 miles from my home. There are 

several reasons why this relicensing in not in the best interests of people living in the 

surrounding community

Comment: 48-1-OR; Just a quick note requesting the NRC to NOT allow the relicensing of the 

Limerick, PA, nuclear plant at this time.

Comment: 51-1-OR; Please protect our citizens from possible disaster and do not relicense 

Limerick

Comment: 52-1-OR; As a resident of New Hanover Twp., Montgomery County, PA (less than 

5 miles from Exelon’s Limerick Nuclear Power Plant), I urge you to vote AGAINST the 

premature relicensing of that facility. 

Comment: 53-1-OR; I implore you to not relicense the Nuclear Power Plant of Limerick when 

its licenses expires in 2029. If I had my wish, the power plant would be closed years before 

2029.

Comment: 57-1-OR; Just wanted to voice my opinion for a no vote to renew the license for the 

Limerick power plant.

Response: These comments are general in nature and express opposition to Exelon, nuclear 

power, and license renewal of LGS. The portions of these comments that express general 

opposition to renewing the licenses for LGS provide no new and significant information and 

have not resulted in any changes to this SEIS. tThe technical aspects of these comments are 

addressed in the respective technical sections of this appendix.

A-26
Appendix A

A.1.11 Postulated Accidents & SAMA (PA)

Comment: 1-1-PA; Whether a natural disaster or terrorist attack occurs, by relicensing 

Limerick, NRC would in effect be playing Russian roulette with the lives of more than eight 

million people. NRC must close Limerick Nuclear Plant by 2029.

Comment: 1-13-PA; With loss of cooling water, Limerick's fuel rods could heat up, self ignite, 

and burn in an unstoppable fire with catastrophic results. Exelon has not been required to 

spend the money to guard limerick against terrorists, missiles, or air strike despite repeated 

requests to do so.

Comment: 1-24-PA; It’s not safe, it’s a ticking time bomb. And nuclear power, they say it’s 

always on. That’s not true either as evidence by shutdowns, some for long periods caused by 

earthquakes, tornadoes, hurricanes, fires, heat, and drought and more.

Comment: 4-1-PA; Increasing floods, droughts, earthquakes, tornados have made us all feel 

insecure, making nuclear power increasingly risky, especially with the Limerick plant basically in 

our backyards. Any earthquake that comes through this area could be a possible Fukushima, 

Chernobyl or Three Mile Island...

Comment: 4-15-PA; The 9-21-11 Mercury article said “whether or not earthquake risk is a 

factor in the current relicensing request for Limerick remains to be seen”. It would be grossly 

unacceptable for the NRC to ignore Limerick's extreme vulnerability to earthquake damage.

Earthquake risk should be on the top of NRC's relicensing concerns for Limerick. Earthquake 

risks are far greater for Limerick than previously realized—increased by 141%. We now know 

Limerick is 3rd on nation's earthquake risk list Plus evidence shows earthquakes in the East can 

be far stronger than Limerick's “design basis” can withstand.

There's a good chance that an earthquake can exceed Limerick's design basis, causing a 

severe nuclear accident, jeopardizing the health, safety and financial well being of our entire 

region.

The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant. Since 

January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick.

Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to 

nuclear disaster. It's disquieting that NRC uses a “visual inspection” to determine damage on 

buried pipes. Problems may not be identified until it's too late.

For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on 

fires and earthquakes. To save money, Exelon typically concludes Limerick is “safe enough”. 

This is unacceptable!

10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear 

plant. The warning was tied to renewed focus on earthquake risk. It's difficult to see how 

Limerick's design flaws can be fixed, even if Exelon WOULD spend the money.

There is no proof whatsoever Limerick's design can withstand other threats ranging from 

hurricanes, tornadoes, floods, or terrorist attacks to an impact from a jet airliner.

We need precaution before there is a catastrophe. NRC should close Limerick as soon as 

possible.

Comment: 6-3-PA; Of course, what is happening here will be taking much longer, but it is sure 

not good news. Besides harmful power plant exposures, we have environmental disasters and 

a concern about our nearby earthquake fault and others in the eastern U.S., especially one near

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Appendix A

New York City. And then there are the radioactive spent fuel deadly waste material sitting 

around, supposedly protected.

Comment: 6-7-A; An earthquake in our area is not too far fetched. And of course, threat of 

terrorism with vulnerable spent fuel are always a concern. 

Comment: 8-6-PA; One big concern—because of Japan’s recent experience and the fact that 

we had an earthquake in the Limerick plant’s territory—is refurbishing the plants so they can 

withstand earthquakes. It has been widely reported by MSNBC and the AP, using NRC data—

that the Limerick plant has the nation’s third highest risk of being damage by an earthquake. 

When the plant was built, no one thought this area would get earthquakes. Now we do. I 

understand Congress is now or soon will be considering increasing earthquake preparedness 

capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would 

encourage them to do less than they should to make the plant safer.

Comment: 19-1-A; Now lately with the -- unfortunately it's a reality now that we have 

hurricanes, more tornadoes, tsunamis throughout the world. And I hate to say it but it is a reality 

now that we have terrorist attacks and Limerick is definitely one. I don't want to be blowing this 

out of proportion but it's just something that I know that we've all been concerned about, not 

wanting to say yes, Limerick, and all the people that built the power plant and the company say 

oh, there's no impact to the air and the water pollution and so forth. So we've kind of just 

blinded our, you know, selves to that and let's believe then, okay, let's take a minute. Let's 

really believe that there is no impact in our clean air, clean water and those type of things and 

cancer, et cetera. Let's just go into the new reality which is terrorist attacks which would 

happen. Let's just say for example there was human error there with the spent fuel rods and 

something happened, or a radiation leak.

Comment: 30-10-PA; Let’s also mention a fact that Category I Hurricane Irene, which could 

have been Category 3, just zipped less than 100 miles away from the site a few weeks ago and 

then Hurricane Lee which decided to travel further east case close to also causing chaos. 

Limerick is still TOO close to the disaster of Hurricanes as well. 

Comment: 37-11-PA, 39-12-PA; Increased Risked of Meltdown From More Frequent and 

Stronger Earthquakes and Other Natural Disasters

Comment: 45-2-PA; Limerick is 3rd on the earthquake risk list. It is too dangerous to keep 

Limerick operating. Earthquakes and other natural disasters are more frequent and stronger. 

Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling 

water, and meltdown. Limerick’s substandard containment flaw means more radiation would be 

released.

Comment: 47-1-PA; Limerick Generating Station is old and I don’t think it is strong enough to 

with stand plane impacts, earthquakes, or tornadoes that occur here. 

Response: The comments express concern for the potential adverse environmental impacts 

associated with postulated accidents. The impacts of design basis accidents were evaluated in 

the GElS and determined to be small for all plants; therefore, it is a Category 1 issue. The GElS 

evaluated severe accidents for all plants including LGS, and it concluded that the impact was 

small under Part 51, “Environmental protection regulations for domestic licensing and related 

regulatory functions.” In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal 

Environmental Reports must provide consideration of alternatives to mitigate severe accidents if 

the staff has not previous evaluated SAMAs for the applicant’s plants in an environmental 

impact statement or related supplement or in an environmental assessment. The staff has 

previously performed a site-specific analysis of severe accidents mitigation in the NEPA

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Appendix A

document for LGS. For the license renewal review, the staff must consider whether new and 

significant information affects the environmental determination in the NRC regulations. 

A detailed discussion of postulated accidents, and the staff’s considerations of new and 

significant information related to SAMA, including seismic risk, can be found in Chapter 5 of this 

SEIS.

Comment: 56-1-PA; The original SAMA analysis for the Limerick Generating Station (LGS) is 

a 1989 report that was issued as the result of a ruling by the U.S. Court of Appeals for the Third 

Circuit, which concluded that the NRC had failed to consider a “reasonable set” of Severe 

Accident Mitigation Design Alternatives (“SAMDAs”). In 1989, the NRC subsequently adopted 

this SAMDA analysis and agency staff concluded they had “discovered no substantial changes 

in the proposed action as previously evaluated in the FES [Final Environmental Statement] that 

are relevant to environmental concerns nor significant new circumstances or information 

relevant to environmental concerns and bearing on the licensing of [LGS]”.

As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, the 

notion that an updated SAMA analysis need not be completed at the license renewal stage (for 

the exact reactor site that gave birth to the regulatory requirement) we find highly objectionable, 

particularly in light of the catastrophic nuclear accident that befell similar Boiling Water Reactor 

(BWR) units in Japan in March, 2011. It has become clear in the 770 years of combined 

U.S. BWR operational experience since 1989 that domestic and international events provide 

numerous examples of “new information” and make a strong case for the need to reconsider all 

that has been learned about newly discovered risks and vulnerabilities of nuclear power plants.

It has been noted that global core damage events happen at a rate that exceeds NRC’s 

presumptions of what should be considered safe at plants within the U.S., which implies that 

either the NRC estimates for domestic plants are wrong or that international nuclear plants have 

a core damage frequency much higher than what the NRC deems safe. Either scenario is 

troubling and deserves the industry’s full attention and effort. Exelon’s 1989 effort in response 

to the Court was, respectfully, less than one would have hoped for in light of the seriousness of 

the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to 

public safety over the total timeframe of a possible sixty year reactor lifetime.

In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license 

renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the 

Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and 

addressed a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied 

by NRC and aided by an industry-supplied guidance document most modern-day SAMA 

analyses are designed using a fairly prescriptive set of initial assumptions, baseline calculations, 

and cost benefit arithmetic recipes that employ the use of sophisticated codes in their evaluation 

of potential risk and the benefit of removing this risk.

The most common code used is the MELCOR accident consequence code system (MACCS2), 

which provides a modeling framework for calculating the off-site consequences of a severe 

accident. This code accepts an advanced set of input parameters, including population density 

distributions within 50 miles, detailed regional economic data obtained from multiple sources, 

nuclide release scenarios accounting for reactor core inventory, emergency response and 

exposure variables, and meteorological data for plume migration pathways. The current state of 

knowledge regarding the assumptions and understanding of severe accident events has 

expanded and improved in the intervening twenty-two years since the initial SAMDA analysis 

for LGS.

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Appendix A

While we acknowledge that this analysis was limited by the knowledge available at the time, the 

limitations and shortcomings of a previous era in no way disqualify the claim that, in light of 

numerous advances in modeling capabilities, a library of discovered cost-beneficial SAMAs, and 

the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is 

there new and significant information, there are significant volumes of this information acquired 

since 1989.

In the licensee’s current environmental report, the identification and treatment of new and 

significant information (four items in total) were developed only in the narrow context of how 

they may affect the dated SAMDA analysis. It should go without saying that this approach does 

not comprise all of the applicable new and noteworthy severe accident mitigation strategies 

bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA 

analysis.

The entire set of first-stage envisioned alternatives in the initial SAMDA analysis was no more 

than fifteen options. The “analysis” in the current environmental report consists of perfunctory, 

“back-of-the-envelope” calculations in lieu of a proper SAMA analysis. The current operator 

Exelon referred to these considerations as representing an “abundance of caution.” We 

disagree.

One of the largest problems with the calculations offered, aside from only focusing on an 

arbitrarily limited number of alternatives, is that licensee evaluated each item of new information 

in isolation of the other factors that would also change the cost-benefit conclusion for a 

particular alternative. The effects of each changed parameter (e.g., population, offsite economic 

risk, cost per person-rem averted, and seismic hazards) should be evaluated in a 

comprehensive model that shows the aggregate benefit, as performed in all current day SAMA

analyses. Unfortunately, their analysis barely scraped the surface of how this new information 

should actually be considered in the context of environmental impacts.

In comparison, a “reasonable set” of alternatives for another recently relicensed plant included 

an initial consideration of 128 SAMA candidates developed from previous lists at other plants, 

NRC documents, and documents related to advanced power reactor designs. After screening 

this initial set for non-applicable or previously implemented designs as well as 

combining/dropping common-benefit options, the applicant was still left with a set of forty unique 

SAMA candidates, for which it was required to enter preliminary cost estimates in a so-called 

“Phase I Analysis.” A total of fifteen SAMA candidates survived this screening to enter more 

detailed cost consideration in the Phase II analysis, of which none were deemed cost-beneficial. 

However, in another renewal application, the SAMA analysis found eleven potentially 

cost-beneficial options from an initial set of thirty-three.

In an NRC report discussing insights on SAMAs in connection with plant license renewals, the 

agency authors list numerous potentially cost-beneficial SAMAs relating to station blackouts, 

protection and support systems, procedures and training, and external events such as flood, 

fire, and seismic hazards. The authors note that “averted onsite costs (AOSC) is a critical factor 

in cost-benefit analyses and tends to make preventative SAMAs more attractive than mitigative 

SAMAs.” This AOSC factor was not considered in either the original SAMDA or the recently 

submitted environmental report.

Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the 

licensee or agency must conduct a study that, as part of the SEIS, presents postulated accident

scenarios showing the full range and weight of environmental, economic, and health risks posed 

by these accidents. This type of study should model site-specific severe accidents and illustrate 

the full consequences of a range of severe accident scenarios so that the public and their policy 

makers can make informed decisions whether to continue plant operations after the existing 

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Appendix A

licenses expire, thereby continuing to run the risk of a severe nuclear accident, invest in 

additional accident mitigation capabilities, or alternatively, avoid these risks altogether by relying 

on a portfolio of low carbon electricity generation alternatives that could meet future electricity 

service needs over the license extension period.

The SAMA analyses are inadequate in this regard because they only address isolated issues in 

a cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional 

economic losses, and environmental cleanup. These types of calculations do not present a 

clear picture of the potential hazards or costs experienced in the event of a severe accident. 

Instead they tend to mask the full range of accident consequences that policy makers may wish 

to avoid. Recently, NRDC produced an analysis, of the type we believe should be included in 

the Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear 

plant site.

In order to illustrate the full extent of a major accident, the NRDC study used the 

U.S. Department of Defense computer model HPAC (Hazard Prediction and Assessment 

Capability) to calculate site-specific release radiological source-terms, resulting fallout plumes, 

and data on the effects on nearby populations. The results were compared to similar modeling 

of the Fukushima disaster to provide a sense of scale, and to estimate the rough magnitude of 

financial and economic damages that would be incurred if a severe accident were to occur at 

Indian Point. This is not a hypothetical issue. Policy makers in several countries, including 

Germany and Switzerland, have made decisions not to grant nuclear plant license extensions to 

avoid having to endure the continuing risk of severe nuclear plant accidents.

Regardless of Exelon’s own corporate understanding of its legal obligations, NEPA is clear in its 

well-established mandates and what it requires of the NRC. NEPA requires that federal 

agencies characterize environmental impacts broadly to include not only ecological effects, such 

as physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, 

economic, and social effects. NEPA requires an agency to consider both the direct effects 

caused by an action and any indirect effects that are reasonably foreseeable. Effects include 

direct effects caused by the action and occurring at the same time and place and indirect effects 

caused by the action, but later in time or farther removed in distance, but still reasonably 

foreseeable.

Most specifically, NEPA directs that NRC take a “hard look” at the environmental impacts of its 

proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional 

20 years, and compare them to a full range of reasonable alternatives. “What constitutes a 

‘hard look’ cannot be outlined with rule-like precision, but it at least encompasses a thorough 

investigation into the environmental impacts of an agency’s action and a candid 

acknowledgement of the risks that those impacts entail.” Nat’l Audubon Soc. v. Dept of the 

Navy, 422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC’s 

draft EIS, the applicant’s ER does not meet this standard. In taking the “hard look” required by 

law, the NRC must therefore address the potential environmental impacts of a range of severe 

accidents—and accident mitigation strategies—especially in light of the new information 

provided by the Fukushima nuclear disaster on the performance of BWR radiological 

containment in a prolonged loss-of-coolant, core-damage scenario.

For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA

analysis be conducted as part of (or supplement to) the required SEIS, the draft of which is 

currently scheduled for August 2012 and the final SEIS currently scheduled for February 2013. 

Additionally, the full cumulative effect of severe accidents must be studied and presented as 

part of these documents. These analyses must make every effort to meet the current 

expectations of what these studies should encompass and use the necessary guidance and 

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Appendix A

tools commonly utilized by the industry and NRC. The NRC’s legal obligation to consider new 

information and determine its nuclear safety significance exists independently of whether a 

SAMA has or has not been prepared previously: in the event a SAMA has not been prepared, 

then new and potentially significant nuclear safety information must be included in the initial 

SAMA; if a previous SAMA exists, then it must be updated to reflect this new information, and 

the resulting costs and benefits of the full spectrum of reasonable accident mitigation

alternatives must be considered as part of the Draft Supplemental Environmental Impact 

Statement, and issued for public comment.

Response: For license renewal, the NRC discharges its NEPA obligation to consider severe 

accident mitigation through 10 CFR 51.53(c)(3)(ii)(L) and Table B–1. In accordance with 

10 CFR 51.53(c)(3)(ii)(L), the license renewal ERs must provide a consideration of alternatives

to mitigate severe accidents if the staff has not previous considered SAMAs for the applicant’s 

plant in an environmental impact statement or related supplement or in an environmental 

assessment. LGS is a plant that had a previous SAMA documented in a NEPA document.

Under NEPA, the NRC must consider whether new and significant information affects 

environmental determinations in the NRC’s regulations, including the determination in 10 CFR 

51.53(c)(3)(ii)(L) and Table B–1, that the agency need not reconsider SAMAs at license renewal 

if it has already done so in a NEPA document for the plant. New information is significant if it 

provides a seriously different picture of the impacts of the Federal action under consideration. 

For SAMAs, new information may be significant if it indicated a given cost-beneficial SAMA

would substantially reduce the risk of a severe accident, by reducing the probability, or the 

consequences of a severe accident. 

The staff’s evaluation of new and significant information for SAMAs is addressed in Section 5.3 

of this SEIS.

A.1.12 Radioactive & Non-Radioactive Waste (RW)

Comment: 1-10-RW; This aging plant is an accident waiting to happen. Large volumes, more 

than 6,000 assemblies weighing more than a thousand tons of highly radioactive waste in the 

form of spent fuel rods are stored in densely-packed pools, elevated five stories above and 

outside the reinforced containment structure.

Comment: 1-11-RW; This plant will produce about two more tons of dangerous spent fuel rods 

every year that it operates.

Comment: 1-14-RW; Dry cask storage and transport are also very dangerous alternatives. 

It's time to close Limerick and stop producing such deadly waste for which there is no safe 

solution. As long as Limerick operates harms to us and our environment will increase.

Comment: 1-30-RW; [R]adiation into air and water from routine and accidental emissions

Comment: 1-36-RW; [D]eadly high-level radioactive wastes that are packed in vulnerable fuel 

pools on this site and they are in fact unprotected. They are above ground and unprotected

Comment: 6-4-RW; [T]he radioactive spent fuel deadly waste material sitting around, 

supposedly protected 

Comment: 18-1-RW; One would be what are we going to do with the 20 years of spent rods 

and how are you going to take care of those.

Comment: 23-3-RW; And then to—I'm sure that the generic plan includes a pretty good 

discussion of fuel storage long-term and short-term onsite but certainly the site-specific fuel 

storage considerations.

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Appendix A

Comment: 30-7-RW; The NRC and USA Government still have not decided where to store 

spent nuclear rods and as we speak each spent rod is sitting in baths on the Limerick site, 

stacking up—expanding even a greater hazard to the community, environment, etc. So put 

simply, there [is] absolutely no reason to approve this request for years until the 

US Government decides how they will handle such rod and such rods and properly stored.

Comment: 34-3-RW; The disposal area must be in operation not some theoretical site like the 

now defunct Yucca site. The public and our future generation deserves to know what is 

expected to be done at the site. Radioactive material must not be allowed to remain on the site.

Comment: 35-5-RW; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

aging and inadequate equipment, its increased air pollution by particular matter, its horrific 

destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage.

Comment: 37-8-RW, 39-9-RW; Deadly high level radioactive wastes packed in vulnerable fuel 

pools on site

Comment: 52-5-RW; The plant can no longer store its used fuel rods and has asked 

permission to begin transporting them to another facility.

Comment: 60-4-RW; Spent fuel—Storage—Uranium mining—Dirty

Comment: 60-11-RW; Nuclear waste—nothing clean

Comment: 60-14-RW; Radiation in air and water—Radioactive ground water

Response: Radioactive and non-radioactive waste management is discussed in Section 2.1.2

in this SEIS. The NRC’s evaluation of impacts of the uranium fuel cycle and waste 

management are addressed in Chapter 6 of this SEIS. 

A.1.13 Socioeconomics (SE)

Comment: 1-28-SE; Then you take the property taxes. They tried to get zero for their property 

taxe[s] by the end of the 90s and didn’t pay any property taxes until the early 2000s at which 

time they paid $3 million instead of $17 million they were suppose to pay. So when you think 

about that no wonder Exelon’s willing throw around a couple million in the community. They 

owe this community a lot more than what they’re giving.

Comment: 52-3-SE; The area around the facility has exploded with homes and businesses

Response: The property taxes paid by Exelon are presented in Section 2.2.9.2 in this SEIS. 

Section 2.2.9.1 discusses the total number of vacant and occupied housing units in Berks, 

Chester, and Montgomery counties. Section 2.2.9.6 presents information on the number of 

businesses in the area. Section 4.9 presents the NRC’s evaluation of socioeconomic impacts of 

continued operation of LGS. In addition, the socioeconomic impacts of not renewing the 

operating license are discussed in Chapter 8.

A.1.14 Support of License Renewal (SR)

Comment: 2-1-SR; Operating Limerick Generating Station safely and reliably is a responsibility 

that everyone at the power station takes very seriously. We understand our obligation to the 

community, to the environment, and to each other to operate the plant safely.

A key component of a thriving community like ours is the availability of safe, clean, and reliable 

electricity. And as we look into the future for the power needs of Pennsylvania and the United 

States as a whole, we can see the increasing demand for this very important resource.

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Appendix A

At the same time, there's a growing concern about greenhouse gases and climate change that 

is a result of burning fossil fuels. To help meet that growing power demand and to help keep 

our environment clean, Exelon has applied to the U.S. Nuclear Regulatory Commission for a 

20-year extension to the plant's operating license. Limerick's current license for Unit 1 will 

expire in 2024 and Unit 2 in 2029. With license renewal, Limerick can provide our region with 

clean power through 2049.

We understand our special obligation to operate the plant safely and reliably and to maintain a 

close relationship with our neighbors. We pledge to continue that special trust as we operate 

the plant well into the future.

Comment: 3-1-SR; I’m here today to voice my strong support for the relicensing of the 

Limerick Generating Station. I wanted to touch on a couple points of why I feel it is important for 

this facility to be relicensed. 

First is the amount of electricity that is produced by this facility. One of the things that myself 

and my colleagues in Harrisburg hear consistently from businesses and the Commonwealth and 

our citizens is the demand for energy and electricity now and more importantly what that 

demand is going to be in the future.

Right now this facility generates enough electricity for two millions homes and without producing 

some of the greenhouse gases that we hear so much about that could be produced by coal, 

natural gas, or oil. And I'm going to put a caveat in there for my good friends out in the western 

part of the state where coal is a big part of the Pennsylvania economy and I’m suggesting that 

this be done to the exclusion of coal and nevertheless, some of the technologies that they're 

developing out there are also important for that industry and important for the Commonwealth of 

Pennsylvania.

Again, one of the concerns we hear consistently from businesses is how can we come here into 

Pennsylvania with the infrastructure being what it is which needs to be improved for the 

transmission of the electricity, but more importantly the generation of that electricity?

Number two, I think is important is the jobs and overall economy. Again, in these tough 

economic times that we're facing here in the Commonwealth of Pennsylvania and also in this 

nation, one of the top issues that we hear consistently about is jobs.

And as was mentioned by the site vice president, over 860 people are employed here with an 

annual payroll of $75 million. The direct impact that is to the Commonwealth of Pennsylvania, 

of course, is realized through the state income tax and also all of these local municipalities most 

of them enact an earned income tax which again sustains their townships as well as their 

respective school districts. To have that taken away I think would have an even more dramatic 

impact on our local economy.

As was mentioned the impact for the local area here, the temporary workers who show up here 

during the outages and the refueling, there's already been two hotels that have sprung up along 

the 422 corridor with another one planned right up here at the Sanatoga area. Again, more jobs 

and more economic growth here for our communities.

Thirdly, I want to talk about the communication that I’ve experienced in the seven years that I've 

been in office with Exelon and with their Government Affairs people as well as with their site

people. I've been on the site three times, twice for a tour and one to make a presentation during 

an anniversary of the facility. And I have to say that it is a very secure area. I know a lot of 

people are concerned about terrorism attacks or people being on the property. But unless 

you've actually gone over there and gone through a tour, seeing how things are set up, seeing 

the armed guards there, seeing the security measures that are in place, I think you come away 

A-34
Appendix A

much more relieved with that. And I’m able to speak to my constituents more affirmatively about 

the safety and security of the facility.

Any time that there's been the slightest occurrence there, whether it will be a couple times a 

hunter has wandered onto the property where the authorities were called, the Government 

Affairs people at Exelon are on the phone to me or with an email right away to let me know 

what's happening before the word gets out to the media or to the press. So they're always very 

well prepared in their explanations, not only of things that happen at the plant itself, but also 

incidents and issues that occur around the country and around the world.

Obviously, what took place in Japan with the incident over there, they were on the phone with 

me and met with me a few times to explain what took place over there and how the safeguards 

are being put in place here so that doesn’t happen at this facility.

Comment: 5-1-SR; Because the license Generating Station can be operated safely and 

reliably, Exelon decided to pursue license renewal for Limerick. Limerick is a very clean energy 

source which produces no greenhouse gas emissions. Limerick is also good for the economy in 

that it lowers market prices on electricity for the citizens of Pennsylvania to the tune of 

$880 million per year.

Comment: 5-4-SR; [W]e operate Limerick safely and we can continue to operate it safely for 

an additional 20 years. Limerick will provide approximately 2340 megawatts of base-load 

generation that's not only safe, but it's clean, reliable and economical.

Continued operation of Limerick will benefit this community, the Commonwealth of Pennsylvania 

and our nation.

Comment: 7-1-SR; As the largest private employer in the region, the Board is thankful for the 

860 jobs that Exelon provides, the positive impact of their operation, the vitality of our local 

community. The community and local economy are enhanced by the needed services provided 

by the township, which includes the roadway network maintained by our Limerick Township 

Public Works, public safety provided by the Limerick and Linfield Fire Companies, and our local 

emergency medical response, our public parks, our recreation facilities and also the police 

protection that's provided by Limerick’s 21 sworn officers.

Because of Limerick Generating Station's location within our borders, the Limerick Township 

Police Department is the only municipal police department in Pennsylvania with the primary 

jurisdiction over Tier 1 critical infrastructure. This Board prides itself on the services provided 

directly both to the residents and the businesses of this community and the township's ability to 

maintain those current levels of service during these difficult economic downturns. We are 

thankful for the generosity of the Limerick generating plant and Exelon for being good corporate 

neighbors and the assistance they provide to the community. Without their financial assistance 

that impact to provide those services to the community would fall squarely on the backs of the 

taxpayers. They assist in our fire companies. They have been corporate sponsors of our 

Limerick Community Days. And we are confident that Limerick generating facility and Exelon 

will continue that support in the future and be our good corporate neighbor. We also are in 

support of the relicensing of the Limerick nuclear plant.

Comment: 11-1-SR; I’m president of the Tri-County Area Chamber of Commerce. I'm happy 

to be here today to provide examples of how Limerick Generating Station is a valued community 

and business partner and echo the statements already shared by several others. They’re one 

of the tri-county area’s largest employer, providing professional employment opportunities for 

local residents. Those local residents employed by Limerick Generating Station are supporting 

the entire tri-county business community. They’re purchasing personal goods and services from 

local small businesses. The annual outage is a tremendous benefit to the local economy and 

A-35
Appendix A

our local businesses. Limerick encourages their outage employees to visit and purchase from 

tri-county area, local businesses, and small businesses.

In addition to the jobs they provide local residents, they’re making a significant investment in our 

local communities. Municipalities and residents benefit from assistance received from Limerick 

to start, maintain, expand parks, recreation, and quality of life opportunities.

Their corporate culture of giving back to the community is practiced by their hundreds of 

employees. Nonprofit organizations are supported by Limerick Generating Station and the 

efforts of their employees. Financial donations, as well as volunteer hours and time are 

donated, enabling our local nonprofits to provide the much needed services that impact those 

in need throughout the tri-county area. 

The Limerick Generating Station is confident in the clean and safe environment they maintain in 

our community. The community has been invited to experience the generating station firsthand. 

The chamber hosted a membership breakfast and the site vice president, Bill Maguire provided 

the keynote presentation. He summarized safety measures and advancements at Limerick and 

answered questions pertaining to the Limerick plant and its safety in the wake of the tsunami in 

Japan.

Comment: 12-1-SR; I don’t believe that continued operations of the power plant would have 

any detrimental effect on public safety in the southeast region.

Comment: 13-1-SR; Today, I would like to say that in all of the years that I’ve lived in this area, 

I’ve never worried at all about the safety of the nuclear power plant. I see it every day. And it 

bothers me not in the least. I have never seen any credible evidence to suggest that there are 

safety problems with this plant. In terms of reliability, it is the same. It is running 24/7, 365 days 

a year and it has been doing so for a quarter of a century and I hope it continues to do so for 

many more years to come. 

As far as its environmental impact, I think it’s pretty widely known that nuclear power is one of 

the cleanest environmental energies that we possess today throughout the world and to dismiss 

it is I think a foolish notion. 

The impact of the Limerick plant in our region has been extraordinarily positive. It provides, as 

we all know and have heard today, lots of jobs, lots of good jobs, tax revenues for schools, local 

governments and for those who live in the area to enjoy the fruits of public services and it also 

provides a lot of charitable donations to the community which is very important.

I think that to not keep this plant running and not consider a renewal of its license for an 

extended period would be a tragic mistake for all of us and I would like to end this by saying that 

the only meltdown that would concern me is the economic one that certainly would happen to 

this area should this plant not continue to operate.

Comment: 14-1-SR; But I'm here today as a private citizen, as a resident of the area and as a 

member of the Pennsylvania Energy Alliance to go on record and say I strongly favor license 

renewal for the Limerick Generating Station. I say that because in my personal experience I 

know in spite of some of the things you’ve probably heard here today, nuclear power is safe, 

reliable, secure and clean. But in addition to that, I would like to go on record, I would like my 

neighbors to know we are lucky to have the Limerick Generating Station in this area. In the 

industry, it has a top reputation. It is one of the finest nuclear power plants in America. And 

Exelon, if not the best, is certainly one of the finest nuclear operators in the world.

I have nothing but confidence that Exelon will work together with the NRC, will run through the 

process and we will come up with the right conclusion here which is license renewal should be 

A-36
Appendix A

granted to the Limerick Generating Station. I think we need to keep Limerick operating as long 

as we can. 

Comment: 14-2-SR; And so from my perspective as a citizen, as a business person who 

worked in this community, I understand the value this is to the region. And for me, I applaud the 

NRC for what they’re doing here. I applaud Exelon for the great work that they’re doing there 

and I encourage the renewal process to take place.

Comment: 17-1-SR; And my comments tonight are more I guess from my perspective as a 

newly elected official with the generating station. About a year ago I had the opportunity to go 

down to the generating station and meet with Joe Saffron and the first part of my meeting had to 

do with looking for some support for the Pottstown Soapbox Derby. Through some 

conversation while we were standing outside you know Joe [told] me a little bit on what Exelon 

and the generating station do for the surrounding communities, whether it’s supporting our 

firefighters, police departments and other civic organizations. You know, from a Pottstown 

perspective they help us with our yearly borough cleanup, our Salvation Army and now the 

Soapbox Derby. Thank you.

And we were standing outside that day, it was pretty nice out, and our conversation led to the 

power plant itself. We were standing there looking around it’s a pretty impressive sight. So I 

asked him about, you know, possibly having a tour for municipal officials. He said he would look 

into it and see what he could do. A couple of months later he got a group of about 20 of us and 

gave us a tour of the plant one evening. And I have to say that from the time we walked through

the front gates and past the security as our tour progressed, you know, throughout the plant 

safety was paramount. Whether you were having explained what the different colors are on the 

different panels and what they mean to different fail safes, why you walk certain areas certain 

ways and what lines you had to stand behind, you know, safety was paramount with them. You 

know, from the environment, I'm looking around and this place is spotless. And I asked why 

and it's because they can’t afford to have dirt or lint or fuzz balls around because of static 

electricity because it could create issues. So from that aspect I thought it was a good tour and it 

made me feel good about the safety aspects there.

To finish our tour we ended up in the control room upstairs. And I’d say maybe a dozen or so 

individuals up there monitoring you know everything going on within the plant and around the 

plant. And again, explaining the failsafes and why they're double-, triple-checked to eliminate 

human error. It was just very impressive and as an elected official to go down and take a tour of 

the plant and understand how it operates. I know when I left I personally know how to issue a 

concern with the generating station. I know I felt a lot better and a lot safer going home that 

night. And it was also good to realize, you know, as one of our region’s largest employers now 

that they are willing to give back to the community and keep safety first. So thank you, I just 

wanted to make those comments.

Comment: 20-1-SR; I’m going to be making essentially five points in support of license 

renewal for Limerick Generating Stations and they are that, number one, nuclear energy lowers 

electricity prices, it protects our environment against greenhouse gases, it strengthens our local 

economies and it is safe.

With regard to my first point in lowering electricity prices the Limerick Generating Station has 

reduced wholesale energy costs in Pennsylvania by $880 million in 2010 thus lowering 

electricity prices for all consumers. It operates around the clock thereby stabilizing the nation's 

electricity distribution system and the electricity marketplace. The average electricity production 

costs at nuclear plants have actually declined more than 30 percent in the past 10 years due to 

various efficiencies. Nuclear power is cheaper to produce than other forms of electricity 

A-37
Appendix A

generation such as coal and natural gas, and helps moderate the price of electricity for 

consumers.

My next point is that Limerick Generating Station and nuclear plants strengthen our local 

economies and it is a valuable economic driver for the Commonwealth of Pennsylvania. 

Limerick Generating Station contributes $113 million annually in direct economic contributions to

the Pennsylvania economy through various employee wages and salaries, purchase of goods 

and services from other Pennsylvania businesses and in property tax payments to the local 

governments. Limerick Generating Station also contributes generously as we've also heard and 

in fact in 2010 contributed $600,000 to various community organizations. Limerick has over 

800 full-time employees and employs more than 1,000 skilled temporary contract employees 

during annual refueling outages. A significant percentage of the current nuclear plant workforce 

will reach retirement age in the next 10 years creating a demand for high-paying jobs in the 

nuclear industry. Yes, Limerick Generating Station is one of Pennsylvania's most valuable 

economic and energy assets and the commonwealth should embrace it.

My third point is that nuclear energy protects our environment from greenhouse gases and 

reduces the need to generate electricity from fossil fuels. If Limerick Generating Station were 

retired from service replacing the electricity would require increased natural gas-fired or 

coal-fired generation. Nuclear energy is the nation’s largest source of carbon-free electricity 

and is critical to our nation's environmental, security and energy goals. 

My next point is that nuclear energy is safe. It's always on, it’s stable, it’s a reliable source of 

electricity and the station here at Limerick has been built with multiple redundant safety layers.

And the workforce is committed to best practices and continuous improvement. It is also 

important for our nation's quest to be energy-independent. According to the Bureau of Labor 

Statistics it’s safer to work at a nuclear plant than in industries such as manufacturing, real 

estate and finance. And according to the Department of Energy a person receives more 

radiation exposure flying from Baltimore to Los Angeles than by standing near a nuclear plant 

24 hours for a year.

On a personal note I've been inside Limerick Generating Station several times. I’ve also lived 

within 30 miles with my four boys and wife next to the Limerick Generating Station and also 

Three Mile Island. I feel safe, secure and comfortable. That is why I'm in support of the 

re-licensing of the Limerick Generating Station.

Comment: 50-1-SR; I wanted to let you know that I am complete and full supporter of the 

Limerick Nuclear plant. I am also supportive of the scientific [judgment] and expertise of those 

such as yourself who have the job of making the decisions.

Response: These comments express support for nuclear power or the license renewal of LGS 

or both. The comments provide no new and significant information and will not be evaluated 

further. 

A.1.15 Surface Water (SW)

Comment: 1-17-SW; Dangerous depletion of the Schuylkill River, in and by itself, a singular 

reason to deny this permit. The Schuylkill is a vital drinking water source for nearly two million 

people from Pottstown to Philadelphia. It is being depleted and contaminated every day that 

this plant operates.

Comment: 1-23-SW; They are destroying the Schuylkill River. There was enough water in the 

Schuylkill River to sustain this nuclear plant from the very beginning and now we’re seeing the 

consequences of that and they more and more pollution in it. They want to pump mine water in 

A-38
Appendix A

to supplement the flow for Limerick. It’s contaminated and they don’t filter it. And they’re 

actually asking for huge, four times Safe Drinking Water standard increase in total dissolved 

solids which carry a lot of toxic pollutants. So they put radiation into the river 24 hours a day, 

365 days a year, and now they’re asking for these huge increases and people have the nerve to 

get up here and say that they have no environmental impacts. 

Comment: 1-32 SW; Schuylkill River depletion and major drinking water contamination. Keep 

in this is vital drinking water source for nearly 2 million people from here to Philadelphia.

Comment: 4-5-SW; Our drinking and bathing water here is being continuously polluted by 

Limerick every day, 24/7 for years with radiation and unfiltered toxic contaminated mine water, 

thanks to the NRC and Exelon. This is disgusting. Most of us have to depend on the water,

especially for bathing. Some of us pay extra for water filtration or drink bottled water because 

we are afraid to drink from the Schuylkill and because it tastes really bad now. Imagine how 

toxic it would be 18 plus years from now if there was even any wate[r] left.

Comment: 4-10-SW; So then there’s the cost for the pollution they’re putting in the river. 

They're asking for increases in pollution. They want to put more mine water in. They want to 

increase the total dissolved salts. That's going to cost water treatment systems a lot of money 

to try to—for extra treatment for that. It can even break down their equipment, some of the stuff 

that’s coming out of the mines. And when you think about it who actually ultimately pays that 

cost? We do. We pay for increased costs for our water because they're having to do that at the 

water treatment systems. And it seems to me that if you really take a good look at things 

Limerick has got to be the major cause for the radiation in Philadelphia's water.

Comment: 23-1-SW; Mine water issue, better defining that quality and flow particularly in light 

of the likely pending changes in stormwater concerns and regulations in the area. Adding that 

flow to the Schuylkill is going to affect all the municipalities around here who have to deal with 

stormwater.

Comment: 44-3-SW; There is concern that should be faced regarding the Schuylkill River and 

the affects it is going to have on the public if it becomes depleted, and/or toxic due to the 

contaminates going in it.

Comment: 36-2-SW; I am more concerned about the effects of surrounding air and water 

supply and the future of my children and grandchildren, some of whom are already inflicted with 

cancer and other diseases.

Comment: 45-9-SW; Limerick Nuclear Plant is slowly destroying the vital public drinking water 

source for almost two million people from Pottstown to Philadelphia. Radioactive and heated 

wastewater is discharged by Limerick Nuclear Plant into the Schuylkill River 24/7. Limerick’s 

cooling towers are causing significant depletion. To supplement the flow to operate Limerick, 

Exelon wants to pump more contaminated mine water into the river. No one can credibly 

assure if drinking water will remain safe even until 2029 when Limerick’s original license 

expires.

Comment: 54-4-SW; Since the last impact statement was prepared in 1973, the Schuylkill 

River has been designated as a state scenic river and as a heritage area for both the state and 

federal government. Due to these designations and the efforts of non-profit organizations and 

local government, access to the river has been expanded so that the river has become a 

recreation and heritage tourism destination. Use of the river in the vicinity of the plant will 

continue to grow. With the return of American Shad made possible through down stream fish 

ladders, interest in the river could even grow further in the future.

A-39
Appendix A

The Limerick Plant withdraws sizeable portions of river water. During low flow periods, 

additional quantities of water are released into the river from the Wadesville Mine, and Still 

Creek Reservoir in Schuylkill County to compensate for the water withdrawn at the plant. This 

process was initially approved by the Delaware River Basin Commission (DRBC), in 2003 and 

kept active through a series of docket amendments. Future river water use is, dependent upon 

the ability of this water make up system to operate within various water quality and flow 

parameters set by DRBC. It is important to evaluate the viability of the use of the river water 

and water make up system to provide needed water through the expanded plant lifetime. 

Analysis of this aspect of plant operation needs to account for the water quality impact from the 

total dissolved solids in the Wadesville water among other parameters. If resumed use of the 

Delaware water diversion is anticipated, an evaluation of that system is required to ensure that 

the capacity is available in the conveyance system and that water quality objectives can be met 

for discharge into the East Branch of the Perkiomen Creek.

Comment: 60-9-SW; Dirty polluted mine water

Response: These comments express concern in part over the health of the Schuylkill River, 

including river flow and water quality. Surface water resources at LGS, including the Schuylkill 

River, and the effects of plant operations on surface water hydrology and quality are presented 

in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface 

water sources relied upon by LGS and include the sources of water used to augment low flows 

in the Schuylkill River. Section 2.1.7 further describes the surface water and groundwater

sources used to support plant operations, the volumes of water used, and the regulatory 

conditions and associated regulatory agencies that govern the plant’s water uses. With respect 

to the comments regarding depletion of the Schuylkill River, the NRC’s evaluation of LGS’s 

consumptive use of surface water is presented in Section 4.3.2.1 of the SEIS. As described in 

Section 2.1.7.1 and 4.3.2.1, the DRBC has imposed consumptive use limits on LGS’s surface 

water withdrawals. During low river flows, the DRBC limits the plant’s consumptive withdrawals 

to no more than 12 percent of river flow to be protective of aquatic life and downstream water 

users. Under average flow conditions, consumptive water use by LGS amounts to about 

3 percent of river flow.

With respect to concerns about pollution attributable to operation of LGS, effluent discharges to 

the Schuylkill River through its discharge structure are regulated by, and subject to water quality 

standards set by, the PDEP, in conjunction with the DRBC docket issued to Exelon. More 

precisely, these discharges are regulated through the National Pollutant Discharge Elimination 

System (NPDES) permitting process as discussed in Section 2.2.4.1. Although the Schuylkill 

River has historically been affected by a range of activities as described in Section 2.2.4.1 and 

further in Section 4.11.3 (Cumulative Impacts), the main stem of the Schuylkill River in the 

vicinity of the LGS currently meets designated water quality standards and uses, including use 

as a source for public water supply. 

As required by its operating license, Exelon Generation conducts a REMP at LGS to assess the 

radiological impact, if any, to its employees, the public, and the environment around the plant 

site. The REMP measures the aquatic, terrestrial, and atmospheric environment for 

radioactivity, as well as the ambient radiation. The NRC’s staff’s evaluation of the radiological 

impacts of LGS operation and its REMP are discussed in Section 4.8 of this SEIS. As part of its 

evaluation, the NRC staff reviewed Exelon’s annual radiological environmental operating reports

(REOP) for 2006–2010 to look for any significant impacts to the environment or any unusual 

trends in the data. A 5-year period provides a representative data set that covers a broad range 

of activities that occur at a nuclear power plant. Based on the review of the radiological 

environmental monitoring data, the staff found that there were no unusual and adverse trends, 

and there was no measurable impact to the offsite environment from LGS operations. Further, 

A-40
Appendix A

the NRC’s ongoing Inspection Program periodically inspects Exelon’s Radioactive Effluent 

Monitoring and REMP programs for compliance with the NRC’s radiation protection standards in 

10 CFR Part 20. The NRC’s Inspection Program evaluates the data for compliance with 

radiation protection standards. If the data were to show a noncompliance with requirements, 

the NRC would take appropriate enforcement action. Additional information for LGS can be 

found at 

http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/lim1-2.html. 

Comments 1-23-SW, 4-5-SW, 4-10-SW, 45-9-SW, 54-4-SW, and 60-9-SW specifically raise the 

issue of the diversion of water from the Wadesville Mine Pool to augment the flow of the 

Schuylkill River. The use of mine pool water and other diversion sources to augment surface 

water flows to support LGS operations are described in Sections 2.1.6 and 2.1.7 of the SEIS. 

These sections also summarize the background and current status surrounding the ongoing 

water diversion demonstration project that is regulated by the DRBC. The NRC staff’s 

evaluation of the projected impacts on surface water resources of the continued operations of 

LGS during the license renewal term are presented in Section 4.3 of this SEIS. Regarding use 

of the Wadesville Mine Pool and other low flow augmentation sources, the DRBC, and not the 

NRC, is responsible for regulating such activities. Likewise, and as mentioned above, the 

Pennsylvania DEP through the NPDES permitting process, along with DRBC’s docket approval 

process, are responsible for regulating effluent discharges from LGS and will ultimately decide if 

revised effluent limits on chemical and thermal discharges are appropriate.

Comment: 55-6-SW; A note should be added regarding the diversion of Delaware River water 

to the East Bank of the Perkiomen. Due to the residential build-up along the Perkiomen Creek 

area, additional consideration should be presented and discussed with the Army Corps of 

Engineers and the National Weather Service regarding potential flooding impact this may have 

on the area.

Comment: 35-4-SW; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

aging and inadequate equipment, its increased air pollution by particular matter, its horrific 

destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage.

Response: Aging management of plant systems is evaluated as part of the LRA safety review. 

The results of the staff’s safety review of the LRA for LGS will be documented in the staff’s SER.

Air pollutant emissions associated with LGS operations are presented in Section 2.2.2.1 of the 

SEIS. The NRC’s evaluation of LGS’s air emissions is presented in Section 4.2 of this SEIS. 

Surface water resources at LGS, including the Schuylkill River, and the effects of plant 

operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 

the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied on by 

LGS and include the sources of water used to augment low flows in the Schuylkill River. 

Comment: 24-1-SW; ...I want to add that I want the NRC to look into potential water depletion 

issues from shale gas fracking upriver in both rivers.

Comment: 60-21-SW; Depleted water due to fracking up river

Response: The contributions of past, present, and reasonably foreseeable future actions or 

activities in the Delaware River Basin, including hydraulic fracturing (fracking), have been 

considered in the cumulative impacts analyses of this SEIS as presented in Section 4.11 of the 

SEIS. With respect to surface water, these impacts are presented in Section 4.11.3. In 

addition, the environmental impacts of alternatives to the proposed action (i.e., whether to grant 

a renewed operating license to LGS) are evaluated in depth in Chapter 8 of the SEIS. This 

A-41
Appendix A

includes comparative analysis of a natural gas-fired combined-cycle facility as a replacement 

power source for LGS and considers related effects of hydraulic fracturing to supply natural gas.

A.2 Comments Received on Draft Supplemental Environmental Impact Statement

The staff distributed the Generic Environmental Impact Statement for License Renewal of 

Nuclear Power Plants Supplement 49 Regarding Limerick Generating Station, Units 1 and 2, 

Draft Report for Comment (NUREG-1437, Supplement 49), referred to as the draft SEIS, to 

Federal, state, and local government agencies, and interested members of the public. As part 

of the process to solicit comments on the draft SEIS, the staff: 

• placed a copy of the draft SEIS into the NRC’s public Electronic Reading

Room, on its license renewal website, Pottstown Regional Public Library in 

Pottstown, PA, and Royersford Free Public Library in Royersford, PA; 

• sent copies of draft SEIS to the applicant, members of the public who 

requested copies, and certain Federal, state, and local agencies; 

• published a notice of availability of the draft SEIS in the Federal Register on 

May 7, 2013 (78 FR 26663); 

• placed newspaper ads and issued press releases announcing the issuance of 

the draft SEIS, the below noted public meetings and instructions on how to 

comment on the draft SEIS; and

• held two public meetings at Sunnybrook Ballroom, Pottstown, PA, on May 23, 

2013, to describe the results of the environmental review and answer 

questions on the license renewal process (ADAMS Accession No. 

ML13172A026). 

The staff has reviewed the public meeting transcripts and the written comments that are part of 

the docket file for the application, all of which are available online at the NRC public Electronic 

Reading Room (using ADAMS) or at the NRC’s Public Document Room at the NRC 

Headquarters in Rockville, MD, referenced by the appropriate ADAMS accession number 

shown in Table A–4. 

Each commenter was given a unique identifier so that every comment could be traced back to 

its author. Table A–4 identifies the individuals who provided comments applicable to the 

environmental review and the commenter ID associated with each person’s set of comments. 

The individuals are listed in the order in which they spoke at the public meetings and in random 

order for written comments received.

A-42
Appendix A

Table A–4. Individuals Providing Comments on the Draft SEIS

Commenters are identified below, along with their affiliations 

and how their comments were submitted.

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Mariea Geho East Coventry Township 

Supervisor 1 Afternoon Meeting ML13172A019

Dr. Lewis Cuthbert Alliance for a Clean 

Environment (ACE) 2 

Afternoon Meeting

Evening Meeting

Written Comments

ML13172A019

ML13172A023

ML13182A040

Charlie Shank Resident 3 

Afternoon Meeting

Evening Meeting

Written Comments

Written comments

ML13172A019

ML13172A023

ML13182A011

ML13190A307

Donna Cuthbert ACE 4 Afternoon Meeting

Evening Meeting

ML13172A019

ML13172A023

Betty Shank Resident 5 

Afternoon Meeting

Evening Meeting 

Written Comments

Written Comments

ML13172A019

ML13172A023

ML13182A011

ML13190A307

Steve Aaron PA Energy Alliance 6 Afternoon Meeting ML13172A019

Lorraine Ruppe Resident 7 Afternoon Meeting

Evening Meeting

ML13172A019

ML13172A023

Marci Dietrich Resident 8 Afternoon Meeting ML13172A019

Kim Murphy Berks Conservancy 9 Afternoon Meeting ML13172A019

Scott Portzline Resident 10 Afternoon Meeting ML13172A019

Shirley Whyte Resident 11 Afternoon Meeting ML13172A019

Tana Rinehart-Ulman Resident 12 Afternoon Meeting ML13172A019

Paul Gunter Beyond Nuclear 13 Afternoon Meeting

Evening Meeting

ML13172A019

ML13172A023

Alisa Otteni Exelon 14 Afternoon Meeting ML13172A019

Les Rinehart Business Owner 15 Afternoon Meeting

Written Comments

ML13172A019

ML13157A261

Chris Conroy Exelon 16 Afternoon Meeting ML13172A019

Leroy James Watters Resident 17 Afternoon Meeting ML13172A019

Michael Moyer East Coventry Township 

Supervisor 18 Evening Meeting ML13172A023

Mark Pavelich Business owner 19 Evening Meeting ML13172A023

Dr. Anita Baly Resident 20 Evening Meeting ML13172A023

Gail Brown Resident 21 Evening Meeting ML13172A023

Leanne Birkmire Exelon 22 Evening Meeting ML13172A023

Tina Daly Resident 23 Evening Meeting

Written Comments

ML13172A023

ML13190A308

Zach Chizar PA Energy Alliance 24 Evening Meeting ML13172A023

Marvin Lewis Resident 25 Written Comments ML13141A151

ML13141A152

Kelly Jameson Resident 26 Written Comments ML13170A313

A-43
Appendix A

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Janice Monger Resident 27 Written Comments ML13172A048

Barbara Rudnick Environmental Protection 

Agency 28 Written Comments ML13183A033

E. Christopher 

Abruzzo

Pennsylvania Department of 

Environmental Protection 29 Written Comments ML13182A010

Corrine Hanson Natural Resources Defense 

Council 30 Written Comments ML13189A129ML12326A976

Michael Stokes Montgomery County 

Planning Commission 31 Written Comments ML13192A004

Michael Gallagher Exelon 32 Written Comments ML13172A345

To evaluate the comments, the NRC staff gave each comment a unique identification code that 

categorizes the comment by technical issue and allows each comment or set of comments to be 

traced back to the commenter and original source (transcript, letter, or e-mail) from which the 

comments were submitted.

Comments were placed into one of the technical issue categories, which are based on the 

topics that will be contained within the staff’s SEIS for LGS, as outlined by the GEIS. These 

technical issue categories and their abbreviation codes are presented in Table A–5.

A-44
Appendix A

Table A–5. Technical Issue Categories

Comments were divided into 1 of the 21 categories below, each of which has a unique 

abbreviation code.

Code Technical Issue

AL Alternative Energy Sources

AM Air & Meteorology

AE Aquatic Ecology

CC Climate Change

CI Cumulative Impacts

DC Decommissioning

GE Geology

GHG Greenhouse Gas

GW Groundwater

HA Historical and Archeological 

HH Human Health 

LU Land Use

LR License Renewal & NEPA Process

OR Opposition to License Renewal

OS Outside of Scope (a)

PA Postulated Accidents and Severe Accident Mitigation Alternatives (SAMA)

RW Radioactive Waste

SE Socioeconomics

SR Support of License Renewal

SW Surface Water

TE Terrestrial Ecology

(a) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental review 

of license renewal and include, but are not limited to issues such as need for power, emergency preparedness, 

safety, terrorism, and security.

Comments received on the DSEIS are presented in this section, along with the NRC responses. 

They are presented in the order shown in Table A–6.

A-45
Appendix A

Table A–6. Comment Response Location in Order of Resource Area

Comment category Pages

Alternative Energy Sources (AL) A-46

Air & Meteorology (AM) A-66

Aquatic (AQ) A-69

Climate Change (CC) A-70

Cumulative Impacts (CI) A-71

Decommissioning (DC) A-73

Geology (GE) A-74

Greenhouse Gas (GHG) A-77

Groundwater (GW) A-78

Historical and Archeological (HA) A-82

Human Health (HH) A-83

Land Use (LU) A-95

License Renewal and Its Process (LR) A-96

Opposition to License Renewal (OR) A-108

Out of Scope (OS) A-109

Postulated Accidents and SAMA (PA) A-123

Radioactive Waste (RW) A-137

Socioeconomics (SE) A-147

Support for License Renewal (SR) A-149

Surface Water (SW) A-152

Terrestrial Ecology (TE) A-162

A.2.1 Alternative Energy Sources (AL)

Comment: 2-15-AL; Even more astonishing than that, NRC staff concluded that continued 

operation of Limerick nuclear plant would have less environmental impacts than either solar or 

wind alternatives on air quality, groundwater, surface water, human health and aesthetics. Such 

conclusions are beyond untenable and unscientific.

Response: NRC staff assessed the environmental impacts of the proposed action and 

alternatives based on the staff’s technical evaluation using the best available information. NRC 

staff characterized potential environmental impacts for each resource area as SMALL, 

MODERATE, or LARGE based on the definitions of these impact levels in 10 CFR Part 51. 

Chapter 8 provides a discussion of these technical evaluations and a technical basis for the 

impact determinations for the alternatives, and Chapter 4 provides similar information for the 

proposed action. In Section 8.8 the staff concludes that impacts on air quality are less from 

continued operation of LGS than from any of the alternatives involving fossil fuels, though they

are likely to be greater than wind and solar PV alone. Based on the evaluations in Chapters 4 

and 8, the staff concludes that the environmental impacts of renewal of the operating license for 

LGS would be smaller than those of feasible and commercially viable alternatives studied in this 

SEIS that satisfy the purpose and need of license renewal (i.e., providing 2,340 MWe of 

baseload power to the grid).

A-46
Appendix A

This comment does not provide any new and significant information, therefore, no changes 

were made to the SEIS. 

Comment: 2-69-AL; IT IS INEXPLICABLE THAT NRC FAILED TO CONSIDER SOLAR 

POWER AS A COMMON SENSE ALTERNATIVE IN LIMERICK'S EIS.

• NRC failed to consider solar power as an alternative, despite ACE's 10-26-11 

extensive EIS testimony documenting why solar power is a viable alternative 

to Limerick Nuclear Plant.

• NRC excluding solar power as an alternative is more evidence that NRC 

failed to seriously consider or acknowledge ACE’s 10-26-11 public hearing 

comments.

• ACE identified large and small business installations, government building 

installations, schools, and residential solar installations already in the region 

of Limerick Nuclear Plant, including the Cuthberts’ personal solar power with 

battery backup.

• ACE provided a list of news articles proving solar power had become cost

competitive with nuclear power and that large back-up power installations 

were already available to use solar as baseload power.

• Since 2011, considerable additional evidence has become available showing 

that solar power is even more feasible from both a technical and economic 

standpoint.

LIMERICK’S FINAL EIS MUST BE CHANGED TO REFLECT THE REALITY OF SOLAR 

POWER AS A REASONABLE, FEASIBLE ALTERNATIVE.

NRC’s Draft EIS for Limerick Nuclear Plant presented several conclusions that were simply not 

supported by scientific fact. Numerous assumptions appear to have been combined with

predetermined, pro-nuclear conclusions. Many of the conclusions rise to the level of colossal 

incompetence, if not regulatory malpractice.

Several specific examples were included in oral and written testimony presented by Dr. Lewis 

Cuthbert at the NRC public meeting/hearing on May 23, 2013. One of the most ludicrous 

conclusions and assertions was that the impacts from continued nuclear operations at Limerick 

would result in the same impacts as from all other alternatives, all being “small[.”] This 

unsupportable conclusion must be changed in the Final EIS to accurately reflect the far greater 

threats, risks, and impacts from nuclear operations.

The substantial written testimony submitted by ACE October 26, 2011[,] focused on solar power 

as a preferred and viable alternative for our region, rather than a renewed license for Limerick. 

Since that time, solar technology has increased, costs have declined dramatically, and 

installations in the region have proliferated at an ever-increasing pace.

Inexplicably, in its Draft EIS for Limerick, NRC totally dismissed solar power as a viable

alternative, despite the considerable body of evidence to the contrary provided by ACE in 2011. 

Since that time, an even more compelling body of evidence has emerged supporting the viability 

of solar power as an alternative energy source.

The most recent compelling article on the viability of solar power appeared 3-25-13, “NRG Skirts 

Utilities Taking Solar Panels to U.S. Rooftop” by Christopher Martin, and Naureen S. Malik. 

This Article Confirms The Cost Effectiveness and Viability of Solar Panels Alternatives. This 

article supports our conclusion that we don’t need Limerick Nuclear Power Plant.

A-47
Appendix A

• Utilities are aware that generating power at customer sites is leading to them 

losing their customers and disrupting their businesses. Solar power is being 

installed on vast numbers of rooftops, both residential and commercial.

• Costs for solar panels keep coming down. Installation costs keep coming 

down. Solar is being combined with battery technology and power 

management systems.

• Some utilities recognize their business is becoming far less important, 

eventually being used just for back-up.

• NRG Energy, the biggest power provider to U.S. utilities is providing 

electricity directly to consumers.

• Energy companies are challenging traditional utilities, by providing rooftop 

solar panels to power individual buildings. 

• At least a dozen U.S. companies provide rooftop panels at no upfront cost to 

customers, who typically make fixed reduced monthly payments for the 

output under decades-long contracts, known as solar leases or powerpurchase agreements.

• By-passing its utility clients, [NRG] is installing solar panels on rooftops of 

homes and businesses and in the future will offer natural gas-fired generators 

to customers to kick in when the sun goes down[.]

• NRG is running mini-generation systems that run a single building. This 

endeavor strikes at the core business of utilities.

• Companies such as Sunrun and Sungevity offer services at homeimprovement stores.

• CEO of NRG, David Crane said, “Consumers are realizing they don’t need 

the power industry at all. That is ultimately where big parts of the country 

go[.”]

• Individual home-owners may soon be able to tie a machine to their natural 

gas line and tie that with solar on the roof, then totally disconnect the line 

from the transmission-distribution company.

• Independent power producers may be evaluating the merits of distributed 

generation, building many small systems at customer sites instead of a few 

large ones.

When viewed in conjunction with wind power, the need for and cost effectiveness of continued 

electric from Limerick is no longer a logical option. A glut of low priced natural gas is also 

contributing to cheaper power prices.

In addition to typical rooftop PV solar panels, new technology has dramatically reduced the 

footprint of installations. Homes, small businesses, governmental agencies, and large

corporations have moved to solar power in increasing numbers. Rooftop leasing and thinner, 

lighter panels have redefined the cost and space constraints that NRC referenced in its flawed 

Draft EIS. Today, any home or business in our region can consider viable solar power with no 

up-front costs to the owner.

NRC’s Final EIS for Limerick Nuclear Plant must be changed to include all of this evidence, and 

accurately reflect the reality of solar power as a currently available and safer alternative to 

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Appendix A

Limerick’s electric. NRC is encouraged to review and consider additional information that has 

emerged since 2011, and amend the Final EIS for Limerick accordingly.

Comment: 2-70-AL; ACE DID OUR OWN COMPARISON OF SOLAR, WIND, AND NUCLEAR 

BELOW:

NRC FAILED TO INCLUDE THESE COMPARISONS IN LIMERICK’S EIS.

1. Costs of solar and wind (relatively quick to install) will continue to plummet, while costs for 

nuclear power will continue to rise. Independent estimates suggest, adding in hidden costs to 

taxpayers and ratepayers, nuclear plants produce the most costly form of energy.

2. Clean, safe energies like solar and wind, along with energy efficiency, are estimated to 

provide more jobs per dollar spent than nuclear power.

3. Producing solar and wind energies closer to where they are needed, provides more energy 

security, removing the necessity for huge grids that can be attacked by terrorists.

4. The Department of Energy 2006 report stated solar power and wind power could provide far 

more energy than our nation needs – [t]hat solar alone could provide 55 times our entire 

nation’s energy needs.

5. Costly security is not needed for solar or wind energy installations.

• Terrorists are not interested in attacking solar or wind installations.

• Attacks at solar or wind energy installations would not result in astronomical 

costs or cause long-term devastation.

• Nuclear plants can be turned into nuclear bombs, resulting in tens of 

thousands of deaths and hundreds of billions of dollars in damages from 

spreading radioactive contamination across vast areas which create dead 

zones for centuries.

6. Human error or mechanical failure of solar and wind technologies won’t result in devastation 

like they can at nuclear plants.

7. Solar and wind would clearly be a far safer and less costly investment for taxpayers and 

ratepayers.

8. Solar and wind don’t create dangerous high-level radioactive waste storage problems, with 

costs to taxpayers beyond meaningful calculation.

• Reprocessing is not the solution to high-level radioactive waste problems. 

Evidence shows reprocessing makes waste problems worse. Reprocessing 

is costly, ill-conceived, dangerous and environmentally damaging. 

Vitrification is also costly and has not been proven safe.

9. Nuclear plants are not emissions-free.

• Solar and wind energies don’t routinely release radiation in to our air and 

water that is harmful to health. Radiation exposure can alter DNA, cause 

cancer, and shorten life-expectancy.

• Limerick Nuclear Plant Title V air pollution permit proves it is a major polluter 

under the Clean Air Act. There are 32 air pollution sources on site releasing 

a broad range of air pollutants, including greenhouse gases. 

• From uranium mining to waste storage, nuclear power emits greenhouse

gases.

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Appendix A

10. Solar and wind energies don’t present unprecedented threats and harms to the public water 

supplies such as those from Limerick Nuclear Plant.

11. Solar and wind are more dependable in heat and drought when you need power most. 

Nuclear reactors require enormous quantities of water to operate. If water sources diminish 

significantly or become too hot, due to droughts and heat waves (expected to increase under 

global warming), reactors cannot operate safely.

Response: As described in Section 8.6, the NRC staff considered and eliminated a standalone 

solar power alternative from the range of reasonable alternatives to relicensing LGS. 

Alternatives that cannot meet future system needs by providing amounts of baseload power 

equivalent to LGS’s current generating capacity do not justify inclusion in the analysis of 

reasonable alternatives. The potential for solar technologies to serve as a reliable baseload 

power alternative to LGS depends on the value, constancy, and accessibility of the solar 

resource. Within PJM, solar PV installations receive a 38-percent capacity credit (PJM 2014). 

On this basis, approximately 6,160 MWe of solar capacity would be necessary to replace LGS. 

While it is theoretically possible to replace LGS’s capacity with solar photovoltaic technology, 

land requirements for such a facility would be significant. Exelon (2011) estimates that a 

utility-scale solar PV facility located in PJM receives 2.8 to 3.9 kWh of solar radiation per square 

meter per day. As a result, Exelon estimated that a solar PV facility would require 

approximately 6.5 ha (16 ac) per MWe of capacity (Exelon 2011). Thus, the total area 

necessary for solar PV installations in PJM to produce 6,160 MWe is approximately 40,000 ha 

(98,900 ac). The 2013 GEIS states that solar PV systems may have “substantial land 

requirements” and therefore believes that Exelon’s land use estimate is reasonable. 

In addition, in the GEIS, the NRC noted that, by its nature, solar power is intermittent (i.e., it 

does not work at night and cannot serve baseload when the sun is not shining), and the 

efficiency of collectors varies greatly with weather conditions. A solar-powered alternative 

would require energy storage or backup power supply from other sources to supply equivalent 

electric power at night. Further, installations of solar panels on residential and commercial 

rooftops are referred to as “distributed solar power,” and it is theoretically possible to replace 

LGS’s annual generation with these types of solar installations. Assuming a 90-percent 

capacity factor, LGS produces over 20 million megawatt hours annually. Based on an average 

house size of 139 m2 (1,500 square feet (ft2)) with a usable roof space of 70 m2 (753 ft2) and a 

conversion efficiency of 15 percent, over 1,000,000 new or existing homes would have to be 

fitted with solar panels to replace the generation from LGS. With a 2009 inventory of 927,000 

detached single-family homes, (http://www.census.gov/housing/ahs/data/philadelphia.html), all 

of these structures (plus 73,000 other structures of this size) in the Philadelphia metropolitan 

area would likely require installations of solar panels under this proposed alternative. Without 

significant government or utility incentives, installation of distributed solar panels on this scale in 

either commercial or residential applications is unlikely. In addition, this solar alternative would 

require energy storage or backup power supply from other sources at night to supply baseload 

generation equivalent to that of the LGS. For these reasons, NRC did not evaluate distributed 

solar as an alternative to LGS license renewal.

The comment also addresses the air and water impacts of the proposed action versus that of 

solar and wind power. These impacts were evaluated in Chapter 8 of the SEIS. The impacts 

were characterized as SMALL for all three scenarios, although the staff noted in Section 8.8 that 

impacts on air quality are less from continued operation of LGS than from any of the alternatives

involving fossil fuels, though they are likely to be greater than wind and solar PV alone. NRC 

staff assessed the environmental impacts of the proposed action and alternatives based on the 

staff’s technical evaluation using the best available information. NRC staff characterized 

potential environmental impacts for each resource area as SMALL, MODERATE, or LARGE 

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Appendix A

based on the definitions of these impact levels in 10 CFR Part 51. Chapter 8 provides a 

discussion of these technical evaluations and a technical basis for the impact determinations for 

the alternatives and Chapter 4 provides similar information for the proposed action. In addition, 

in Section 8.8 the staff concludes that impacts are less from continued operation of LGS than 

from any of the alternatives involving fossil fuels, though they are likely to be greater than wind 

and solar PV alone. Based on the evaluations in Chapters 4 and 8, the staff concludes that the 

environmental impacts of renewal of the operating license for LGS would be smaller than those 

of feasible and commercially viable alternatives studied in this SEIS that satisfy the purpose and 

need of license renewal (i.e., providing 2,340 MWe of baseload power to the grid).

The comments also relate to security concerns and operational programs. Site security and 

operational programs are outside the scope of the environmental review. An NRC safety 

review, which includes security and operational program considerations, for the license renewal 

period is conducted separately. Although a topic may not be within the scope of review for 

license renewal, NRC is always concerned with protecting health and safety. Any matter 

potentially affecting safety can be addressed under processes currently available for existing 

operating licenses, such as the reactor oversight process (ROP). 

These comments do not provide new and significant information and does not fall within the 

scope of the license renewal; therefore, no changes were made to this SEIS. 

Comment: 5-30-AL; How can NRC justify the risks to the public caused by Limerick’s 

pervasive safety violations, when demand for nuclear energy is down, alternative energy is 

available, and so many local businesses have chosen solar over nuclear?

Response: The comment relates to operational safety. Operational safety is outside the scope 

of the environmental review. An NRC safety review for the license renewal period is conducted 

separately. Although a topic may not be within the scope of review for license renewal, NRC is 

always concerned with protecting health and safety. Any matter potentially affecting safety can 

be addressed under processes currently available for existing operating licenses, such as the 

ROP. This comment does not provide new or significant information and does not fall within the 

scope of the license renewal, as set in 10 CFR Part 51.

Regarding the aspects of the comment relating to nuclear energy demand, availability of 

alternative energy and the energy choices of local business, the NRC ultimately makes no 

decision about which alternative (or the proposed action) to carry out because that decision falls 

to utility, state, or other Federal officials. However, the Commission’s regulations require that 

NEPA impacts associated with these alternatives be disclosed (10 CFR 51, Appendix A(5)). 

Comparing the environmental effects of these alternatives, however, will assist the NRC in its 

decision as to whether the adverse environmental impacts of license renewal are so great as to 

deny the option of license renewal for energy-planning decisionmakers (10 CFR 51.95(c)(4)). 

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS.

Comment: 13-5-AL; [I]t’s one of our contentions that the industry and the agency have 

colluded to avoid answering questions about the lesser environmental impact from the oncoming renewable energy renaissance, revolution that is happening, that is attracting

investment and is growing by leaps and bounds. The NRC doesn’t want to make that kind of 

information in its Environmental Impact Statement.

Response: NRC staff assessed the environmental impacts of the proposed action and 

alternatives based on the staff’s technical evaluation using the best available information. NRC 

staff characterized potential environmental impacts for each resource area as SMALL, 

MODERATE, or LARGE based on the definitions of these impact levels in 10 CFR Part 51. 

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Appendix A

Chapter 8 provides a discussion of these technical evaluations and a technical basis for the 

impact determinations for the alternatives and Chapter 4 provides similar information for the 

proposed action. Based on the evaluations in Chapters 4 and 8, the staff concludes that the 

environmental impacts of renewal of the operating license for LGS would be smaller than those 

of feasible and commercially viable alternatives studied in this SEIS that satisfy the purpose and 

need of license renewal (i.e., providing 2,340 MWe of baseload power to the grid).

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

Comment: 30-8-AL; Section 8 of the GElS Supplement retains many of the factual, legal, and

analytical errors in the Applicant’s ER previously identified by NRDC. See Natural Resources

Defense Council Combined Reply To Exelon And NRC Staff Answers To Petition To Intervene 

In the Matter of EXELON GENERATION COMPANY, LLC (Docket No. 50-352-LR, Docket No. 

50-353-LR (Limerick Generating Station, Units 1 and 2)) January 6, 2012 (License Renewal 

Application), p. 46–78. Furthermore the GElS Supplement for LGS fails to conform to the basic 

guidelines for consideration of the No Action Alternative outlined in the GElS (NUREG-1437, 

1996). The Commission makes a distinction, as do all Federal agencies subject to NEPA, 

between the analysis of reasonable alternatives that satisfy the purpose and need for a 

proposed action—in this case meeting the future base load generating requirement currently 

being met by LGS via license extension or a reasonable alternative—and the alternative of no 

action, which by definition would not satisfy the purpose and need for nuclear or equivalent 

“base load” capacity, but might offer other advantages, such as the preservation of important

environmental equities and/or the avoidance of significant environmental risks - such as a

severe accident at LGS affecting the health, property, and livelihoods of millions of people within 

a 50 mile radius of the plant -- which could be uncovered through a NEPA analysis.

The Nuclear Regulatory Commission’s (NRC’s) environmental review regulations implementing 

NEPA (10 CFR Part 51) require that the NRC consider all reasonable alternatives to a proposed 

action before acting on a proposal, including consideration of the no-action alternative. The 

intent of such a consideration is to enable the agency to consider the relative environmental 

consequences of an action given the environmental consequences of other activities that also 

meet the purpose of the action, as well as the environmental consequences of taking no action 

at all. GElS at 8-1 (emphasis added).

Thus, as is clear from the preceding quotation, the Commission regards the “No Action

Alternative” as distinct from, and therefore not interchangeable with, consideration of the

“Proposed Action” and “reasonable alternatives” that “also meet the purpose of the action.” 

Almost by definition, then, analysis of the “No Action Alternative” cannot be equated with 

satisfying the purpose and need for the proposed action, and therefore the required NEPA

consideration of “No Action” cannot reasonably be equated with “replacing the generating 

capacity of LGS,” or limited to an analysis of this particular problem. Instead, as we stated 

previously in our Contention 4E concerning the ER, absent LGS license extension, the likely 

evolution of electricity system resources [in the PJM Interconnection] is an empirical and 

analytical question...that necessarily involves making an informed projection of the likely 

portfolio of PJM electricity system resources available in the region served by LGS beginning 13 

years and 18 years hence that could reasonably be expected to supply the energy services

currently supplied by LGS.” As we have stated previously, the “reasonably foreseeable system 

resources” available under no action include, in addition to those reviewed by Exelon as 

reasonable alternatives to extended operation of LGS, all forms of Demand Side Management

(DSM), waste heat co-generation, combined heat and power, and distributed renewable energy 

resources (including rooftop and parking-lot PV solar, wind, small hydro, and gasified biomass 

A-52
Appendix A

feeding small combustion turbines and fuel cells). The draft GElS Supplement analysis of the 

No Action Alternative fails to consider the environmental impacts of this reasonably foreseeable 

portfolio of PJM system resources, and thereby fails to make the required comparison between 

the environmental impacts of No Action and the continued operation of LGS for an additional 20 

years. Although now dated, the 1996 GElS clearly suggests and sanctions this approach to 

analysis of the No Action Alternative. Section 8.1 of the GElS includes a brief, but highly 

instructive discussion of “conservation and power import alternatives[.]” 

Although these alternatives do not represent discrete power generation sources[,] they 

represent options that states and utilities may use to reduce their need for power generation 

capability. In addition, energy conservation and power imports are possible consequences of 

the no-action alternative. GEIS at 8-2 (emphasis added).

The GElS outlines the necessary scope of environmental analysis for the no-action alternative 

as follows:

[T]he no-action alternative is denial of a renewed license. Denial of a renewed license as a 

power generating capability may lead to a variety of potential NRDC COMMENTS ON draft 

GElS Supplement 49 June 27, 2013[,] page 9 of 24 outcomes. In some cases denial may lead 

to the selection of other electric generating sources to meet energy demands as determined by 

appropriate state and utility officials. In other cases, denial may lead to conservation measures

and/or decisions to import power. In addition, denial may result in a combination of these 

different outcomes. Therefore, the environmental impacts of such resulting alternatives would 

be included as the environmental impacts of the no action alternative. GElS at 8-2 (emphasis 

added).

The draft GElS Supplement fails to take this integrated portfolio approach to its analysis of the

No Action Alternative, and to a considerable extent, this deficiency also affects its analysis of

reasonable alternatives for LGS replacement. In particular, it fails to project how the current

level of energy services supported by LGS “baseload capacity” within PJM could be supplied 10

and 15 years hence by a balanced portfolio of end-use energy efficiency improvements,

avoidance/reduction of transmission losses, utility-scale wind power (both land and offshore),

residential solar, institutional/industrial/commercial rooftop solar, parking-lot solar, small hydro, 

small wind, distributed geothermal, industrial waste-heat cogeneration, residential and

commercial combined heat and power systems, landfill and agriculture biogas generation using

fuel cells and/or small combustion turbines, emerging wave/tidal/ocean thermal technologies,

utility scale NGCC, and if needed, power imports from outside PJM. Such balanced portfolios 

for replacing existing traditional large-scale baseload generating assets are objectively 

reasonable and are indeed the target of current explicit state and federal policies.

Response: The staff reviews and considers the details of the applicant’s ER. In addition to 

that review, the NRC performs an independent assessment of the environmental impacts of 

proposed alternatives, including the No Action Alternative. Any information provided in the ER 

is evaluated by the staff prior to the NRC’s independent assessment which informs the SEIS.

The scope of the analysis of the no-action alternative is intended only to consider the 

environmental effects that arise directly as a result of plant shutdown, if NRC denies the 

application to renew the operating licenses for LGS. The No Action Alternative was evaluated 

and discussed in Section 8.7 of the SEIS. Section 8.2 of the GEIS states that “the no-action 

alternative is denial of a renewed license.” Denial of a renewed license as a power generating 

capability may lead to a variety of potential outcomes. In some cases, denial may lead to the 

selection of other electric generating sources to meet energy demands as determined by 

appropriate state and utility officials. In other cases, denial may lead to conservation measures 

or decisions to import power or both. In addition, denial may result in a combination of these 

A-53
Appendix A

different outcomes. In the SEIS, 18 alternatives to the proposed action were considered, 

including DSM and renewable resources. DSM and some other renewable resources were 

eliminated from detailed study because the staff determined that they cannot meet future 

system needs by providing amounts of baseload power equivalent to LGS’s current capacity 

and, in some cases, whose costs or benefits do not justify inclusion in the range of reasonable 

alternatives. Assuming that a need currently exists for the power generated by LGS, the noaction alternative would require the appropriate energy planning decisionmakers (not NRC) to 

rely on an alternative to replace the capacity of LGS. For that reason, the environmental 

impacts of alternative energy sources are equally applicable to the no-action alternative in that 

the alternatives analyzed in this section are all possible actions resulting from denial of a 

renewed license.

This comment does not provide any new and significant information; therefore, no changes 

were made in the SEIS. 

Comment: 30-9-AL; (page 8-2, line 7) “The NRC ultimately makes no decision about which 

alternative (or the proposed action) to carry out because that decision falls to utility, state, or 

other Federal officials. Comparing the environmental effects of these alternatives, however[,]

will help NRC decide whether the adverse environmental impacts of license renewal are so 

great as to deny the option of license renewal for energy-planning decisionmakers (10 CFR 

51.95(c)(4).” 

The referenced regulation states, in pertinent part: “The Commission shall determine whether 

or not the adverse environmental impacts of license renewal are so great that preserving the 

option of license renewal for energy planning decisionmakers would be unreasonable.” By 

failing to compare the environmental consequences of license renewal for the obsolescent LGS 

reactors—including the consequences of a low probability but severe LGS accident and the full 

life cycle consequences of LGS fuel production, storage, and disposal—with a reasonably 

projectable range of balanced electricity portfolios (comprised of energy efficiency and 

numerous distributed low-carbon energy resources) as outlined above, the draft GElS 

Supplement fails to supply the information necessary to a fully informed, NEPA-compliant 

comparison of the environmental risks and consequences of the Proposed Action with the 

alternative of No Action, while also arbitrarily excluding such balanced low-carbon portfolios 

from its analysis of “reasonable” alternatives for LGS capacity replacement.

Response: 10 CFR 51.95(c)(4) states, in pertinent part: “...the NRC staff, adjudicatory officers, 

and Commission shall determine whether or not the adverse environmental impacts to license 

renewal are so great that preserving the option of license renewal for energy planning 

decicsionmakers would be unreasonable.” Regarding severe accidents, the Severe Accident 

Mitigation Alternatives (SAMA) Analysis is limited to the proposed action, in this case, the 

operation of a nuclear power plant. It is a method to determine potential cost-beneficial 

measures, or mitigation, to reduce the probability and the resulting consequences of severe 

accidents. In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal Environmental 

Reports must provide consideration of alternatives to mitigate severe accidents if the staff has 

no previously evaluated SAMAs for the applicant’s plants in an environmental impact statement 

or related supplement, or in an environmental assessments. LGS is a plant that had a previous 

SAMA documented in a NEPA document. Therefore, Exelon was not required to, and did not, 

submit a SAMA in its license renewal ER. Exelon did consider whether new and significant 

information affects the environmental determination in the NRC regulations. The staff also 

analyzed the information in the applicant’s ER with respect to the 1989 SAMDA Analysis for 

LGS, public comments, and its own review of information relevant to LGS to search for new and 

significant information with respect to the NRC’s determination not to conduct a second SAMA 

analysis at LGS for license renewal and the studies and assumptions underlying that 

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Appendix A

determination. In conducting that search, the staff considered whether new information 

provided a seriously different view of the consequences of renewing the LGS operating license 

than previously contemplated. The staff also did not identify any new and significant information 

that rises to a level that requires staff to seek Commission approval to conduct a new SAMA 

analysis (similar to the waiver requirement that applies for Category 1 issues when staff

identifies new and significant information). The impacts of all other new information do not 

contribute sufficiently to the environmental impacts to warrant their inclusion in a SAMA 

analysis, since the likelihood of finding cost-effective plant improvements that substantially 

reduce risk is small. Additionally, the staff did not identify a significant environmental issue not 

covered in the GEIS, or that was not considered in the analysis in the GEIS and leads to an 

impact finding that is different from the finding presented in the GEIS.

With regard to consideration of “life cycle consequences of LGS fuel production, storage, and 

disposal,” on June 8, 2012, the United States Court of Appeals, District of Columbia Circuit, 

vacated the NRC’s Waste Confidence Decision and Rule, after finding that it did not comply with 

NEPA. (See New York v. NRC, 681 F. 3d 471 (D.C. Cir. 2012). Without the analysis in the 

Waste Confidence Decision, the NRC cannot assess how long the spent fuel will need to be 

stored on site. Therefore, the NRC has reclassified this GEIS issue from a Category 1 issue 

with no assigned impact level to an uncategorized issue with an impact level of uncertain. 

Therefore, the SEIS only considers the impact of onsite SNF storage for the term of the license 

renewal. The radiological impacts from the onsite SNF storage to human health during the term 

of the license renewal continue to be well within regulatory limits, and therefore meet the 

standard for a conclusion of SMALL impact.

The impacts associated with onsite storage of SNF are discussed in Chapter 6 of the SEIS. This

comment does not provide any new and significant information, therefore, no changes were 

made to the SEIS. 

Comment: 30-10-AL; (page 8-2, line 25) “In evaluating alternatives to license renewal, the 

NRC considered energy technologies or options currently in commercial operation, as well as 

some technologies not currently in commercial operation but likely to be commercially available 

by the time the current LGS operating licenses expire.” The GElS Supplement does not appear 

to take into account technology change at all in its analysis, and in fact appears to rely on 

sources for the cost and performance of alternative generating technologies that are dated 

(e.g.[,] 2008, rather than 2012–13 when the GElS Supplement analysis was prepared) 

suggesting that the Staff has continued to lean heavily on the flawed and dated analysis in the 

Applicant's ER. For example, the discussion of solar technology alternatives for replacing LGS 

Units 1 and 2 in 2024 and 2029, respectively, is based on the technically dated 1996 GElS, a 

ten-year-old analysis by utility-dominated Electric Power Research Institute (EPRI) conducted in 

2003, the Applicant’s own hugely deficient ER, which examines central station solar deployment 

alternatives that are absurdly unsuited to the geographic area served by PJM, and a draft 2010 

BLM-DOE PEIS for “Solar Energy Development in Six Southwestern States” (emphasis added), 

while failing to cite a single document describing the extensive distributed solar development 

occurring right next door to LGS in the states of New Jersey and New York. The current and 

projected technical characteristics, capacities, and costs of various plausible solar and 

alternative low-carbon technologies, and combinations of such technologies are nowhere 

described, so there is no empirical basis for ascertaining whether the few arbitrarily selected 

and misconceived “alternatives” compare favorably or unfavorably with LGS license extension 

or the other large central stations alternatives ([p]ulverized coal, IGCC gas, new nuclear, and 

onshore wind) arbitrarily deemed “reasonable” and therefore subjected to “detailed” analysis. 

Nor does the draft GElS Supplement make any attempt to project the performance and cost of 

solar and other renewable energy technologies that could plausibly be available beginning 10–

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Appendix A

15 years hence as “reasonable” alternatives to LGS license extension, and potentially impose 

fewer environmental harms and risks than LGS and its supporting fuel cycle. Nor does the draft 

GElS Supplement project the performance and cost of energy storage technologies and related 

low carbon technologies, such as fuel cells, that can “smooth” the output and extend the 

availability of “intermittent” renewable energy and thereby make it a round-the-clock dependable 

source of power on the grid. These vast gaps in the draft GElS Supplement analysis are 

impossible to ignore.

Comment: 30-11-AL; (page 8-2, line 39) “Alternatives that cannot meet future system needs 

by providing amounts of baseload power equivalent to LGS’s current generating capacity, and in

some cases, those alternatives whose costs and benefits do not justify inclusion in the range of

reasonable alternatives, were eliminated from detailed study.” This statement abundantly

illustrates why this analysis does not begin to fulfill the requirements of NEPA: (a) Please

explain why, if NRC believes it is precluded from making a “decision about which alternative

[including the proposed action] to carry out,” it is nonetheless knows enough to both implicitly

specify “future system needs” and then exclude alternatives that “cannot meet those needs by

providing amounts of baseload power equivalent to LGS’s current generating capacity?” (b) We

note that the GElS Supplement contains no projections of “future system needs,” nor does it

contain any evidence whatsoever that various plausible combinations of DSM, reduced-carbon

distributed generation, and renewable energy resources would prove incapable of meeting

future customer demand for energy services now met by LGS, thus requiring future dependence 

on LGS license extension or a similar large “baseload” facility.

Indeed, the analytical requirement that any “reasonable alternative” to LGS license renewal—

with the exception of an exceptionally vague, barely considered “purchased power alternative” 

that is nonetheless deemed “reasonable”—must be comprised of a singular generating

technology of equivalent effective generating capacity to LGS, is an unrealistic, unnecessary,

arbitrary and capricious assumption. This is particularly true given that electric power from LGS

license renewal or alternative would be sold into a competitive wholesale power market 10–15

years hence—allowing plenty of time for the Independent System Operator/Regional

Transmission Organization (ISO/RTO) via competitive reverse auctions to “clear” the future

capacity market represented by LGS’s possible demise—and that DSM measures and all forms

of utility-scale and distributed generation are free to compete in this marketplace to meet future 

demand.

Comment: 30-37-AL; (page 8-84, line 2, Alternatives Summary) The discussion under this 

heading presents conclusions that are based not on reasoned analysis supported by facts, but 

rather on the mere application of three vague qualitative labels—“SMALL,” “MODERATE,” and 

“LARGE,” which are associated with no discernible quantitative measures of impacts, and are 

themselves frequently employed in combination—e.g.[,] “SMALL to MODERATE,” “SMALL to 

LARGE,” “MODERATE to LARGE[”]—in a manner that further deprives the required comparison 

of environmental impacts among alternatives of any substantive meaning.

The lack of accurate up-to-date information on the environmental impacts and installed costs of 

various alternatives to LGS license extension deprives the analysis—and therefore the deciding 

agency, other federal agencies, state and local governments, and individual citizens—of any 

meaningful ability to weigh the environmental benefits and risks of these alternatives against 

their costs. The selection of alternatives deemed “reasonable” for detailed analysis is further 

biased by the imposition of an arbitrary screen that only “standalone baseload alternatives” 

capable of “replacing” LGS generating capacity in toto can meet the underlying purpose and 

need for LGS license renewal. Imposition of this screen excludes from detailed consideration a 

wide range of potential low-carbon/DSM/distributed generation/renewable energy portfolios that 

could plausibly provide the same level of energy services that would be otherwise be provided 

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Appendix A

by a 20[-]year LGS license renewal. In so doing, the draft GElS Supplement ignores the clear 

requirement of NEPA to examine “all reasonable alternatives” to the Proposed Action—which 

courts have subsequently interpreted as requiring analysis of the full range of reasonable 

alternatives—including the environmental consequences of “No Action.” 

Response: In developing its alternatives analysis, the NRC relied on published reports on each 

of the alternative energy technologies being considered. Importantly, the NRC’s analysis of 

alternative energy technologies remained focused on the purpose and need of the proposed 

action, i.e., to provide an option that allows for power generation beyond the term of the current 

nuclear power plant operating license to meet future system generating needs, as such needs 

may be determined by state, utility, system, and where authorized, Federal (other than NRC) 

decisionmakers. In the SEIS, alternative technologies were evaluated for reliability (as a 

baseload power source), availability, resource requirements, environmental impact, and existing 

transmission infrastructure that would connect that alternative with the load centers being 

served by the reactor. Only after all such factors were considered were conclusions made 

regarding acceptable alternatives.

To that end, 18 alternatives to the proposed action were considered, including DSM and 

renewable resources. DSM and some other renewable resources were eliminated from detailed 

study because the staff determined that they cannot meet future system needs by providing 

amounts of baseload power equivalent to LGS’s current capacity and, in some cases, whose 

costs or benefits do not justify inclusion in the range of reasonable alternatives.

These comments do not provid any new and significant information, therefore, no changes were 

made to this SEIS.

Comment: 30-13-AL; (page 8-6, line 15) “In addition, because the natural gas-fired alternative

derives much of its power from a gas-turbine cycle, and because it wastes less heat than the

existing LGS unit, it requires significantly less cooling water.” How much less? Please quantify

this difference, both in terms of the consumptive uses of freshwater resources and the thermal

loads discharged to receiving water bodies.

Comment: 30-14-AL; (page 8-6, line 17-20) The draft GElS Supplement provides high 

capacity factors for LGS from 2003 to 2010. (a) Please provide the average capacity factors for 

these units before and after this time interval, and the average lifetime capacity factor achieved 

for each unit to date. (b) To what extent can the very high capacity factors achieved in this 

period be attributed to deferred maintenance and capital additions that must be recouped by 

higher downtimes in subsequent years? (c) To what extent might the very high capacity factors

achieved for LGS from 2003 to 2010 reflect a higher degree of operating nuclear safety risk, due

to the reluctance of regulators to interrupt economical operations to identify and rectify safety

deficiencies? (d) In the more than two years since the Fukushima severe accident, and

attendant increased regulatory attention, what has been the operating capacity factor of (a) the

US nuclear fleet; (b) all reactors of the same design class as LGS (i.e.[,] GE-BWR Mark I’s); (c) 

all reactors in the PJM Connection?

Comment: 30-15-AL; (page 8-6, line 23) “...the NRC presumes that appropriately sized units 

could be assembled annually to produce electrical power in amounts equivalent to LGS.” (a) 

Why is it rational to presume that Natural Gas Combined Cycle (NGCC) capacity must nearly or 

entirely replace LGS capacity, leading to excessive fuel consumption and C[O2] emissions, 

rather than examining supplemental NGCC use in a “firming” mode to support maximum 

achievable market penetration of clean renewable energy alternatives like wind and solar? (b) 

How much NGCC capacity would be required to firm and backstop sufficient wind, distributed 

PV, waste-heat cogeneration, and small hydro capacity to replace LGS Unit 1 in 2024 and Unit 

2 in 2029, assuming a relicensed LGS capacity factor of 89% and implementation of DSM 

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Appendix A

measures that shrink future PJM demand for LGS output by an average 1.5% per year over 15 

years? (c) Please compare the “load-following” characteristics of LGS versus efficient modular 

Natural Gas Combined Cycle (NGCC) generation. Which represents the better technology for 

load-following and “firming” high levels of market penetration for “intermittent” renewables?

Comment: 30-16-AL; (page 8-10, line 7) “The staff estimated that the consumptive water loss 

for an equivalent-sized combined cycle plant would be about one-third the LGS water use.” 

Please quantify this comparison in gallons-per-day of consumptive use for each technology, and

quantify the differences in thermal load discharged directly to receiving waters.

Comment: 30-17-AL; (page 8-10, lines 10–16) (a) Please present this stream flow calculation 

as a comparison between the LGS and IGCC alternative. (b) What is the reduction in stream 

flow in units of cubic meters per second and expressed as a percentage of the mean annual 

stream flow in the Schuylkill River, caused by operation of LGS, and what is this stream flow 

compared to the NGCC alternative? (c) What level of reduction in stream flow from LGS 

operation triggers “the need for low-flow augmentation from either the Delaware River or the 

Wadesville Mine Pool?” (d) Please provide technical references for the data used to make this 

comparison.

Comment: 30-18-AL; (page 8-12, lines 39–40) “Most of this land requirement would occur on 

land where gas extraction already occurs. Some natural gas could come from within 

Pennsylvania or nearby states.” (a) Please provide the factual basis and references for these 

statements. (b) What percentage of this supply for a replacement NGCC plant might 

reasonably be expected to come from “fracked” natural gas sources?

Comment: 30-19-AL; (page 8-12, lines 41–44) Please provide the factual basis and references 

for the statement that satisfying the fuel requirement for an extended 20[-]year LGS operating 

life fuel requirement would result in the disturbance of 1,640 acres. Upon what assumptions, 

regarding ore grade, mining and processing techniques, and enrichment tails assay, is this 

calculation based?

Comment: 30-20-AL; (page 8-17, Section 8-2) “Supercritical Pulverized Coal-Fired 

Alternative”: Please provide the detailed scientific and technical basis for the draft GElS 

Supplement conclusion that, in light of the global scientific consensus surrounding coal power’s 

outsized contributions to Global Warming, and the serious threat the latter presents to climate 

stability and species survival, a new Supercritical Pulverized Coal Plant with the approximate 

generating capacity of LGS is nonetheless a “reasonable” alternative to LGS license extension 

10–15 years hence, while a low-carbon/renewable energy portfolio enhanced by DSM 

measures and another decade or more of technology improvements, as described earlier, is 

dismissed as “unreasonable.” Take as much time as you like, as it will take you a long time to 

explain this assertion.

Comment: 30-21-AL; (page 8-20, lines 25–27) “Without CCS in place [i.e. the more likely

deployment scenario] the staff’s projected C[O2] emissions for the SCPC alternative would be

18,363,843 tons (16,659,678 MT) per year. The overall impact from the releases of GHGs of a

coal-fired alternative would be MODERATE.” (a) Please describe the scientific and analytical

basis for this statement? What specifically about the emission of 16.66 million metric tons of

C[O2], in addition to 559 MT of fine particulates and 1,118 MT of particulates qualifies as

“MODERATE” in comparison to the air quality impacts of available and projected cleaner

electricity portfolio alternatives? (b) Does this 16.66 million metric ton figure include the C[O2]-

equivalent emissions from all GHG gas sources involved in the coal mine-to-ash pond life 

cycle? If not, what would a more complete SCPC life cycle accounting amount to in metric tons 

of C[O2] equivalent per year?

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Comment: 30-22-AL; (page 8-28, line 11) “Several designs are possible for a new nuclear 

facility. However, a two-unit nuclear power plant similar to the existing LGS in output is most 

likely.” (a) Please describe the “several designs” that NRC believes are not only “possible” but 

“reasonably foreseeable”—the relevant NEPA analytical standard—as partial or complete 

replacements for the license-extended capacity of LGS. (b) Please provide analytical support 

for the assertion that construction and operation of “a two-unit power plant similar to LGS in 

output” is “likely” in the economically competitive wholesale power environment of PJM, given 

that such costly units would have to be in the detailed planning stages today to be on line when 

LGS Unit 1’s license expires in 2024. (c) Given the failure over the last 13 years of the ever 

impending “nuclear renaissance” to deploy a conventional gigawatt-class nuclear plant in a 

merchant power environment, please describe the set of economic and policy circumstances 

that NRC believes would make such a scenario “reasonably foreseeable” within the next 10–15 

years. (d) Ironically, the draft GElS Supplement fails to consider the contribution that 

purportedly safer, load-following, and less environmentally-intrusive Small (50–300 MWe) 

Modular Reactors (SMRs) might make to a low-carbon/renewable energy portfolio to “replace” 

LGS, even though the Commission is actively considering the licensing of such reactors within 

the same timeframe as LGS license extension. Please either justify or rectify this omission.

Comment: 30-23-AL; (page 8-31, lines 16–17) (a) Please offer quantitative technical support 

for the conclusion that “the overall impacts on surface water use and quality from construction 

and operations under the new nuclear alternative would be SMALL, and for the referenced

determination (in 4.3.2) that “the impacts of LGS operations on surface water resources are

SMALL” relative to other LGS license extension alternatives. (b) Please reconcile this 

conclusion with the finding on page 8-10, lines 3 to 16, that the “NGCC alternative would require 

much less cooling water than LGS Units 1 and 2, and consumptive water use would be much 

less...about one-third the LGS water use.” (c) Since a gigawatt class nuclear power plant sets 

the top of the scale for power plant heat loading of aquatic environment and/or consumptive use 

of water (i.e.[,] it poses an unattractive tradeoff between two environmental harms) please 

explain how both the nuclear plant and an NGCC plant of equivalent capacity can, relative to 

each other, both have surface water impacts assessed as “SMALL”? (d) Are the harmful 

groundwater impacts of ISL uranium mining and natural gas “fracking” included in the 

assessment that the groundwater impacts of the LGS, New Nuclear, and NGCC alternatives are 

also “SMALL?” Please provide the empirical basis for this conclusion.

Comment: 30-24-AL; (page 8-33, lines 23–25) “According to GElS estimates [that are now 17 

years old], an additional 1000 ac (400 ha) of land would be affected by uranium mining and

processing during the life of the new nuclear power plant.” (a) Please clarify the comparison

being attempted here—does the figure of 1000 ac affected by uranium mining and processing

“during the life of the new nuclear plant” refer to the 20[-]year life of the new plant that is

comparable to the 20[-]year license extension of LGS, or to the anticipated 60[-]year licensed

lifetime of both plants[?] (b) If the latter, does this mean that NRC is asserting that fueling 2350

MW of nuclear capacity at LGS (or a new plant with similar specifications) for 20 years at >90%

capacity factor would only require the disturbance of 1000/3 = 333.33 acres of land for mining,

processing, conversion, enrichment, waste storage, fuel fabrication, and disposal? (c) Please

provide the complete technical assumptions and methodology used in making this calculation,

including the ore grade, mining technology, enrichment tails assay, and fuel burnup assumed in

the original GElS analysis and any updates that may be justified in light of new information after

the passage of 17 years.

Comment: 30-25-AL; (page 8-46 to 8-48, Section 8.5: Purchased Power) Despite its alleged 

status as a “reasonable alternative” subjected to “detailed analysis” in the draft GElS 

Supplement, this section is exceptionally brief (2.5 pages) and notably devoid of any 

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quantitative or even qualitative analysis. The projected mix(es) of “purchased power,” including 

DSM resources, that could reasonably “replace” LGS Unit 1 in 2024 and Unit 2 in 2029 are 

nowhere specified, not even qualitatively, and the various broad “area impact” discussions 

consist of a single paragraph each and carry the usual meaningless labels made worse by[,] in 

most cases[,] embracing a fuzzy qualitative range. You can’t get much further than that from an 

accountable quantitative analysis that can be objectively evaluated and assessed for accuracy.

Thus we are told, for example, that impacts from this unspecified mix of purchased power would 

be “Small to Moderate” for “Air Quality” and “Terrestrial and Aquatic,” but “Small to Large” for 

“Land Use” and “Socioeconomics, Transportation, and Aesthetics.” How these and other 

environmental conclusions were arrived at is a mystery, as the analysis is unmoored from any 

factual or analytical foundation.

The potential role of DSM resources receives a backhanded acknowledgement—“At some

times, some portion of replacement power needs may be addressed by PJM’s demand

response program”—but this nod literally begs the questions “when” and “what fraction” of LGS 

replacement power needs could be met by DSM resources? PV solar and other distributed low 

carbon generation (e.g.[,] small wind, small hydro, industrial waste heat co-gen, combined heat 

and power, landfill/water-treatment/agricultural bio-gas) appear to be excluded from the

“analysis,” which merely refers to the Staff’s “assessment” that “purchased power” 10 and 15

years hence “would likely come from one or more of the other types of alternatives considered

in this chapter,” but the analysis refers by name only to “the new nuclear, coal, and natural gas,

and wind alternatives described in previous sections,” and the mix of even this limited menu of

resources that qualifies as “reasonable” (by virtue of its comparative environmental

consequences) is never specified. In other words, this section fails to meet the minimum

standard for analysis required under NEPA and the NRC’s own implementing regulations.

Comment: 30-26-AL; (page 8-49, Section 8.6: Alternatives Considered but Dismissed) This 

section is plagued by a dearth of technical data and analysis to support its conclusions, and 

therefore not surprisingly its environmental conclusions range from misguided to false.

Response: This series of comments are all requesting specific data and analyses that NRC 

staff reviewers developed to arrive at their conclusions. NRC staff assessed the environmental 

impacts of the proposed action and alternatives based on the staff’s technical evaluation using 

the best available information. NRC staff characterized potential environmental impacts for 

each resource area as SMALL, MODERATE, or LARGE based on the definitions of these 

impact levels in 10 CFR Part 51. Chapter 8 provides a discussion of these technical evaluations 

and a technical basis for the impact determinations for the alternatives and Chapter 4 provides 

similar information for the proposed action. In addition, in Section 8.8 the staff concludes that 

impacts on air quality are less from continued operation of LGS than from any of the alternatives 

involving fossil fuels, though they are likely to be greater than wind and solar PV alone. Based 

on the evaluations in Chapters 4 and 8, the staff concludes that the environmental impacts of 

renewal of the operating license for LGS would be smaller than those of feasible and 

commercially viable alternatives studied in this SEIS that satisfy the purpose and need of 

license renewal (i.e., providing 2,340 MWe of baseload power to the grid). 

These comments do not provide any new and significant information, therefore, no changes to 

this SEIS were made. 

Comment: 30-27-AL (page 8-49, lines 17–20) “Although some aspects of solar generation 

result in few environmental impacts, solar technology requires substantial land areas.” This 

statement is misleading, and should be revised to say: “Although most (but not all) aspects of 

solar generation result in little or no harmful environmental impacts, and even net environmental 

benefits—for example[,] the shading and weather protection afforded by solar parking 

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structures, and the avoidance of long-range transmission impacts afforded by electricity 

production on or near the site of electricity consumption—some large utility-scale 

implementations of solar technology require substantial land areas, and some CSP technologies 

require roughly the same amount of water for cooling of the steam cycle as most other 

thermoelectric technologies.” 

Comment: 30-30-AL; (page 8-50, line 35) Contrary to Exelon’s absurd portrayal in its ER of a 

virgin land-based 98,900[-]acre solar PV replacement for LGS license extension, “the Staff

notes that much of the solar capacity installed in PJM is likely to be in the form of rooftop 

installations,” and acknowledges that “this type of installation minimizes land disturbance, can 

provide electricity to end-users, and minimizes the modifications necessary to the transmission 

system[.]” Unfortunately, the draft GElS Supplement does not follow through on the logical 

implications of these (already widely understood) beneficial characteristics of distributed PV 

solar, nor explore the likelihood that 100% of all solar PV “land-based installations” could also 

be undertaken on already disturbed land areas, such as parking lots, freeway embankments, 

abandoned military bases, and urban-industrial “brownfields, meaning that solar deployment in 

the densely populated PJM connection area would not require any conversion of current land in 

open space uses (e.g.[,] farm land, wildlife habitat, forest areas) to PV solar power production.” 

Comment: 30-28-AL; (page 8-49, line 21) “The potential for solar technologies to serve as 

reliable baseload power alternative (sic) to LGS depends on the value, constancy, and 

accessibility of the solar resource.” But who is insisting that solar serve as a “reliable baseload 

power alternative.” This is about as sensible as asserting, “The potential of Roger Federer to 

serve as a reliable quarterback in the NFL depends on the constancy of his throwing arm and 

his accessibility to the defense.” It’s asking current solar technologies to forgo what they do 

well—serving daytime intermediate and peaking power loads—and forcing them to do what 

everyone knows they can’t (yet) do (until the advent of economical large scale electrical storage

technologies[)]—provide 24-7 round the clock power to the grid in “discrete baseload

applications.” 

Forcing solar technologies into the irrelevant straitjacket of “discrete baseload applications” is a

none too subtle device to tilt the analytical playing field away from the applications that

maximize solar’s advantages and toward those that maximize the strengths of nuclear power,

coal, and gas central-station alternative. Get rid of the “standalone baseload” assumption, and

embed solar energy in a portfolio of other renewable and low-carbon electricity resources with

complementary characteristics, and there is basically no limit to the reliable integration of solar

energy into the future electricity grid. Such a system will necessarily be organized somewhat

differently than the present system, allowing a far greater degree of autonomy, resilience, and

reliability than the current central-station, hub and spoke model of electric power production and 

distribution that fails with virtually every intense summer thunderstorm or winter ice storm. In 

some areas of the country, some people are already meeting their entire electric power needs 

from off-grid solar applications, including round-the-clock availability via battery storage.

Comment: 30-29-AL; (page 8-50, line 10) “Because PV does not produce electricity at night 

and produces diminished amounts of power during particular weather conditions, the staff does 

not consider solar PV to provide a viable standalone alternative to license renewal.” Again, no 

one save the NRC [s]taff and the Exelon is insisting that solar, in order to serve a portion of the 

load now served by LGS, must by itself provide a “viable standalone alternative to license 

renewal.” This is an arbitrary hurdle confected by the [a]pplicant and [s]taff that bears no 

resemblance to reality.

In the real world of wholesale power markets and emission controls, there is no “standalone” 

baseload alternative to a 2.3[-]GW twin-unit nuclear plant save another 2.3[-]GW (or larger) 

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twin-unit nuclear plant. As the draft GElS Supplement tacitly acknowledges by its acceptance of 

an undocumented random mix of “purchased power” on the wholesale power market as a 

reasonable alternative to LGS license extension, in the real world there are few if any

“standalone” baseload options for LGS replacement power, and by far the likeliest LGS

replacement option is a portfolio of resources, which by 2024 and 2029 will include a wide range 

of “reasonably foreseeable” electricity resources, including a significant rooftop and parking lot 

PV solar component.

Comment: 30-31-AL; (page 8-53, line 40) “The footprint of a utility scale standalone PV solar 

installation would be quite large. Based on Exelon’s local PJM territory estimates,

approximately 98,900 ac (40,000 ha or 155 mi2 [400 km2] of land would be needed to support a

solar PV alternative to replace the LGS (Exelon 2011).” Why does the draft GElS Supplement

bother to repeat this absurd canard when the [s]Staff has already acknowledged on previous

pages that its premises are false? No utility executive would seek to deploy such a massive 

solar facility on previously undeveloped land in the heavily populated PJM, nor would they 

obtain the environmental permits to do so, or the financing to purchase or lease that much land, 

and build the necessary transmission. It’s a technical and economic non-starter. This farcical 

land-based “standalone” alternative distorts the range of solar PV environmental impacts 

reported in the draft GElS Supplement (there is insufficient direct normal solar radiation in the 

PJM Connection area to support concentrating solar thermal power plants (CSP) plants).

Without this spurious alternative, the Land Use impacts of the “Solar PV Alternative” would be

assessed as “SMALL” rather than “SMALL TO LARGE.” “Terrestrial Ecology” impacts would

likewise be “SMALL” rather than “SMALL TO MODERATE,” and so on right down the list. If

confined to existing structures and paved over areas in the already built urban and suburban

environments, the PV solar alternative would have “SMALL” environmental impacts that would

put it on par with the alleged assessed impacts of “continued operation of LGS,” which are

likewise deemed SMALL in all impact areas.

Response: In Section 8.6.1.5, the NRC staff discussed the total land area required to support a 

solar PV alternative to replace LGS. The land area required would be up to 155 mi2 (420 km2) 

(see Section 8.6.1.7 of the SEIS). This represents a land area about 2.5 times larger than the 

land area of the District of Columbia. (The land area of the District of Columbia is 61.05 mi2—

see http://quickfacts.census.gov/qfd/states/11000.html.) However, the section also discusses 

the variability of the impact given that the alternative would include “many relatively small 

installations on building roofs or existing residential, commercial, or industrial sites.”

Additionally, as stated in Section 8.0 of the SEIS, “alternatives to renewing the LGS operating 

licenses must meet the purpose and need for the proposed action....” The proposed action is to 

“provide an option that allows power generation capability beyond the term of a current [in this 

case, LGS] nuclear power plant operating license....” LGS generates baseload power, thus 

alternatives considered must be capable of doing so as well. As stated in Section 8.6.1, solar 

PV systems have limitations that prevent them from being considered as a standalone system 

and was therefore eliminated on that basis. Solar power was also considered a part of a 

combination alternative in Section 8.6.2. That alternative was also eliminated from detailed 

study because NRC staff determined that the alternative may not be able to generate 2,340 

MWe by the time the LGS licenses expire. 

These comments do not provide and new and significant information, therefore, no changes 

were made to this SEIS. 

Comment: 30-32-AL; (page 8-57, line 16) “Because this alternative [i.e. a combined 2300 

MWe of installed wind capacity, 3000 MWe of solar PV capacity, and 400 MWe of NGCC 

capacity] many [may] not (sic) be able to generate 2,340 MWe because of the variable wind and 

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Appendix A

solar PV resources, the staff does not consider the wind, solar, and NGCC combination 

alternative to provide a viable standalone alternative to license renewal. The staff considers a 

standalone alternative here, however, because Exelon includes a wind, solar, and NGCC 

combination alternative in its range of alternatives to license renewal in the ER.” This is a 

problematic and self-contradictory paragraph. First, it documents the fact that, for reasons that 

are not disclosed, the [s]taff’s choice of reasonable alternatives is influenced not by the 

technical, environmental and economic performance of real world alternatives, by rather 

dictated by Exelon’s earlier choice of alternatives in the ER, no matter how irrational these 

alternatives turn out to be when subjected to even a minimal review of relevant facts.

Second, it provides no analytical basis in the above alternative for truncating the fully

dispatchable generation and storage components before attaining an aggregate capacity

sufficient, with or without DSM measures, to reliably replace the energy services now supported 

by LGS. Of course, never mentioned is the fact that LGS itself must be and is backed up by 

excess grid “reserve capacity” (largely coal and gas-fired) for those times when one or both 

units are down for maintenance or even unplanned and possibly extended “outages,” an

inherent operational risk of nuclear plants.

Conceptually, this “load following” reserve capacity is no different from the intermediate

generation resources needed to “firm” a combination of wind, solar and other renewable

resources to whatever level of reliability is believed to be required. It is capricious to truncate

this portfolio at some arbitrarily reduced level of readily dispatchable and responsive generation 

capacity (e.g.[,] at 400 MW of NGCC, as in this example) when it could just as easily include not 

only more natural gas NGCC capacity but also other distributed but reliably dispatchable 

resources, such as bio-gas, waste-heat cogen, pumped storage, battery storage, fuel cells, and 

small and large hydro, which together could reliably cover the range of integrated output 

fluctuations experienced by a geographically and technologically dispersed portfolio of

renewable energy resources. 

For example, why not include in this firming portfolio the 703 MWe of hydro potential (a 1997

number!) that the draft GElS Supplement (p. 8-75, line 19) says is distributed across 104 sites in

Pennsylvania, only one of which is larger than 100 MWe? Small hydro technologies have

improved over the last 16 years, making it likely tha[t] more than 703 MWe could be extracted

today from the state’s hydro resources. 

Comment: 30-33-AL; (page 8-78, line 18) “In the GELS [sic], the NRC indicated that 

technologies relying on a variety of biomass fuels had not progressed to the point of being 

competitive on a large scale or being reliable enough to replace a baseload plant such as 

LGS...the staff finds biomass fueled alternatives are still unable to replace LGS capacity and 

are not considered feasible alternatives to LGS license renewal (emphasis added).” Once again, 

the draft GElS Supplement employs an arbitrary and capricious construct—that each electricity 

technology considered must alone be sufficient to “replace LGS capacity”—to ignore the 

contribution that “biomass fuels”—including fuel cells and microturbines running on captured 

methane from landfills, animal husbandry operations, and water treatment plants—could play in 

an integrated low[-]carbon electricity portfolio to provide the energy services that would 

otherwise be supplied by LGS license extension.

Comment: 30-34-AL; (page 8-79, lines 8–18) The fuel cell costs given in this paragraph are 

dated, and in any event, vary widely and should be expressed as a range based on the specific

application and the value of the avoided costs arising from that specific application. For

example, highly (70%) efficient distributed fuel cells running 75% on biogas and 75% in CHP

mode offer significant avoided costs—e.g.[,] vastly reduced GHG emissions, and reduced

transmission, fuel, and HVAC costs—that add up to a substantial value proposition that can

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more than offsets their relatively high installed cost-per-kilowatt. NRDC believes that installed

costs of fuel cell systems will go down significantly with the increased market penetration and

higher production volumes of fuel cell systems in the time period leading up to the possible

retirement of LGS Unit 1 in 2024.

The draft GElS Supplement’s unsupported assumption that “fuel cells are not economically or

technologically competitive with other alternatives for electricity generation” may or may not hold 

true in 2024–2029. It thus merits closer analysis, given that distributed fuel cell power plants in 

the multi-megawatt range and smaller residential/commercial CHP systems are now being 

installed around the world, including by leading businesses in the U.S. These units have a high 

availability that approximates “baseload” power applications and could be employed to “firm” 

renewable energy output and render it “dispatchable” on the grid. As onsite-generated power at 

the point of consumption, they can also be employed to shed load from the transmission and 

distribution grid at peak times, and thus represent a potential DSM resource that would tend to 

reduce the need for extension of the full LGS plant capacity.

Comment: 30-35-AL; (page 8-79, line 12) Likewise, the installed cost of solar PV ($6,171/kW) 

given in the draft GElS Supplement is wildly out of date, seemingly reflecting solar installed 

costs as of 2008, and thus suggests an lack of due diligence in preparation of the draft GElS 

Supplement. As shown in the following chart, PV module prices have dropped 80% since 2008!

According to a December 2012 report from DOE’s NREL and Lawrence Berkeley Laboratory, 

for utility-scale solar, the capacity-weighted average installed price declined from $6.2/W for

projects installed during 2004–2008, to $3.9/W for projects installed during 2009–2010, and to

$3.4/W for projects installed in 2011. (See http://emp.lbl.gov/sites/all/files/LBNL-5919e.pdf).

The draft GElS Supplement analysis of solar alternatives appears to be predicated not only on

faulty consumptive solar land use assumptions, but on erroneous cost assumptions as well,

suggesting that the entire solar alternatives analysis must be redone.

Response: The Council on Environmental Quality’s “Forty Most Asked Questions Concerning 

CEQ’s National Environmental Policy Act Regulations” states that “[w]hen there are potentially a 

very large number of alternatives, only a reasonable number of examples, covering the full 

spectrum of alternatives, must be analyzed and compared in the EIS....What constitutes a 

reasonable range of alternatives depends on the nature of the proposal and the facts in each 

case.” The NRC has determined that a reasonable set of alternatives should be limited to 

analysis of single, discrete electric generation sources and only electric generation sources that 

are technically feasible and commercially viable.

As stated in 10 CFR Part 51, Appendix A, Section 5, “[a]ll reasonable alternatives will be 

identified.” In the SEIS, 18 alternatives to the proposed action were considered, including 

combinations of different technologies and DSM. Section 8.0 of the SEIS states that the NRC 

staff “considered energy technologies or options currently in commercial operation, as well as 

some technologies not currently in commercial operation but likely to be commercially available 

by the time the current LGS operating licenses expire.” The staff only examined in detail those 

alternatives that would be able to provide 2,340 MW of baseload by the time LGS’s licenses 

expire. Alternative technologies were evaluated for reliability (as a baseload power source), 

availability, resource requirements, environmental impact, and existing transmission 

infrastructure that would connect that alternative with the load centers being served by the 

reactor. Only after all such factors were considered were conclusions made regarding 

acceptable alternatives.

In developing its alternatives analysis, the NRC relied on published reports on each of the 

alternative energy technologies considered. Importantly, the NRC’s analysis of alternative 

energy technologies must remain focused on the purpose of the proposed action, i.e., to meet 

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future system generating needs, as such needs may be determined by state, utility, system, and 

where authorized, Federal (other than NRC) decisionmakers. This SEIS has accounted for any 

new and significant site-specific information developed since the preparation of the revised 

GEIS.

These comments do not provide any new and significant information; therefore, no changes 

were made to this SEIS.

Comment: 30-36-AL; (page 8-81, line 18, Comments on Section 8.7, No-Action Alternative) 

This section, which supposedly considers the environmental impacts of the “No Action 

Alternative” of not renewing the operating licenses of LGS Units 1 and 2 when they expire at the 

end of their current license terms, in 2024 and 2029, respectively. The section is only 3 pages 

long, including a half-page summary table, and thus constitutes a mere pro[ ]forma pretense at 

presenting a NEPA-compliant analysis of the environmental consequences—both harmful and 

beneficial—of “No Action.” In fact, the analysis is impermissibly truncated because it addresses 

“only those impacts that arise directly as a result of plant shutdown,” not including “the 

environmental impacts from decommissioning and related activities,” which this section claims 

“have already been addressed in other documents,” and other connected and reasonably 

foreseeable impacts.

This leaves prompt and direct “shut-down effects” as the only subject for analysis, and in all

impact areas save one (“Socioeconomics,” which may be “Small to Moderate”) these are each

assessed in a single paragraph as SMALL, making (absurdly) the impacts of “No Action” 

environmentally equivalent to the effects of “Continued Operation of LGS,” which are likewise all 

assessed as being “SMALL.” The vacuity of this analysis is readily apparent. How can the

environmental consequences and risks of operating 2340 MWe of aging and technologically

obsolescent nuclear capacity for an additional 20 years have no discernible difference in

impacts when compared with not operating this capacity over the same time period?

Instead of reducing the required analysis of No Action to such meaningless comparisons, the

draft GElS Supplement must address the reasonably foreseeable range of real world

consequences from implementing the No Action Alternative, such as potential increases in 

C[O2] emissions and other pollution arising from increased reliance on fossil-fueled generation, 

to an increased reliance within PJM on DSM measures and low-carbon distributed generation,

including vastly greater reliance on clean renewable energy solutions, to the less tangible

benefits for citizens of the Philadelphia metro area of living with a reduced risk of being harmed

by a severe nuclear accident. This section as currently drafted fails to comply with NEPA. Few

potential impacts are examined, and none are quantified in a manner that admits meaningful

comparison, as required by law.

Response: The No Action Alternative was evaluated and discussed in Section 8.7 of the SEIS. 

The scope of the analysis of the no-action alternative is intended only to consider the 

environmental effects that arise directly as a result of plant shutdown if NRC denies the 

application to renew the operating licenses for LGS. Even with a renewed operating license, 

LGS will eventually shut down, and the environmental effects addressed in Section 8.7 will 

occur at that time. When LGS shuts down, either from the no-action alternative or at some time 

after license renewal, energy planning decisionmakers will be required to rely on an alternative 

to replace the capacity of LGS, rely on energy conservation or power purchases to offset parts 

of the LGS capacity, or rely on some combination of measures to offset and replace the 

generation provided by the facility. The environmental effects of such alternatives have been 

discussed and considered in the SEIS.

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Appendix A

Regarding the environmental impacts of decommissioning, those impacts are discussed in 

NUREG-0586, Chapter 7 of the license renewal GEIS, and Chapter 7 of this SEIS.

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

A.2.2 Air & Meteorology (AM)

Comment: 2-8-AM; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant’s relicensing including finalizing this EIS until after several issues are addressed 

or take place.

......Number eight, Exelon installs filtration for Limerick’s water intake to reduce harmful air 

pollution from the cooling towers....

Response: Air pollutant emissions associated with LGS operations are presented in Section

2.2.2.1 of the SEIS. The NRC’s evaluation of LGS’s air emissions is presented in Section 4.2 of 

this SEIS.

The commenter requests that NRC require Exelon to install filtration to the cooling towers to 

reduce emissions. Air permits for sources of air emissions at LGS are granted by the PDEP. 

The PDEP is responsible for developing, requiring and enforcing air permit criteria. The PDEP 

determines required pollution control technology.As discussed in Section 2.2.2 of the SEIS, as a 

condition of the Title V operating permit, Exelon is required to submit an annual compliance 

certification to the PDEP, which includes fuel usage and estimated air pollutant emissions. The 

methodology to estimate emissions is identified in the annual compliance certification, in 

accordance with the permit, and approved by the PDEP. The NRC staff requested and 

reviewed Exelon’s Title V operating permit issued by the PDEP and annual compliance reports 

submitted to the PDEP (ML12110A222); LGS has been in continuous compliance with the 

requirements of the Title V permit . 

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

Comment: 2-61-AM; AIR POLLUTION—DRASTIC INCREASES IN DANGEROUS [PM10] 

WERE PERMITTED FOR LIMERICK’S COOLING TOWERS IN 2009, YET NRC’S DRAFT 

CONCLUDED ENVIRONMENTAL IMPACTS FROM LIMERICK’S AIR POLLUTION WERE 

“SMALL.” 

THIS KIND OF AIR POLLUTION IS CONSIDERED MORE DEADLY THAN OZONE.

• IT IS NOT CREDIBLE FOR NRC TO CLAIM THE IMPACTS FROM 

LIMERICK NUCLEAR PLANT’S AIR POLLUTION ARE “SMALL.” 

LIMERICK’S DANGEROUS AIR POLLUTION HARMS HEALTH[.]

• LIMERICK IS CONSIDERED A MAJOR AIR POLLUTION SOURCE UNDER 

HEALTH-BASED STANDARDS OF THE CLEAN AIR ACT.

Comment: 4-7-AM; Limerick is a major air polluter under health-based standards of the Clean 

Air Act releasing so much air pollution from the cooling towers that a six-fold increase was 

granted in 2009 for the kind of air pollution that’s more deadly than ozone.

Limerick’s [PM10] air pollution transports cooling tower toxics, pathogens and radionuclides into 

our air every day with 44 million gallons of steam. Exelon refused to install cooling towers at 

Oyster Creek[,] citing too much air pollution as the excuse. Need we say more?

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Appendix A

Comment: 26-4-AM; Limerick is a major air polluter under health-based standards of the Clean 

Air Act, releasing so much cooling tower [PM10], that Limerick needed a 6-fold permit increase in 

2009. PM[10] is considered more deadly than ozone.

Response: As discussed in Section 2.2.2.1 of the EIS, Exelon maintains a Title V operating 

permit. The Title V operating permit is granted by the PDEP. PDEP is responsible for 

safeguarding the health of Pennsylvanians by achieving the goals of the Federal Clean Air Act

(CAA), ensuring compliance with permitting requirements, and developing enforcement policies. 

The commenters note that Exelon applied for a Title V operating permit renewal in 2009; 

renewal of this permit was approved by the PDEP and the renewal did not reflect any change in 

air emissions from the facility and contained all the applicable requirements including

monitoring, recordkeeping, and reporting (Pennsylvania Bulletin, Volume 39, Number 52: 

December 26, 2009). The 2009 Title V renewal revised the calculation methodology for PM10

emissions from each cooling tower at LGS (ML12110A233); the revised calculation 

methodology is more conservative and resulted in an increase in calculated PM10 emissions. 

There were no changes to cooling tower operation in the operating permit renewal. 

As noted by the commenters, Limerick is a major stationary source and subject to Title V 

permitting requirements. Major source status is determined by its potential to emit. As defined 

in 40 CFR 70.2, potential to emit is the maximum capacity of a stationary source to emit any air 

pollutant under its physical and operational design. In other words, potential to emit is the 

complete and unrestricted operation of a source (365 days per year, 24 hours per day) at 

maximum design and emission rates. Actual emissions for a source will normally be less than 

the potential to emit as the operation is less than unrestricted operation. In accordance with the 

Title V permit, Exelon submits an annual compliance certification to the PDEP and emissions for 

2007–2011 are presented in Table 2–1 of the EIS. As there are no plans for refurbishment for 

license renewal and there are no expected new air emissions associated with license renewal, 

the cumulative impacts from the proposed license renewal on air quality are SMALL.

These comments do not provide any new and significant information; therefore no changes 

were made to this SEIS.

Comment: 2-62-AM; LIMERICK NUCLEAR PLANT’S AIR POLLUTION INCLUDES:

• 1. Radiation—from routine operations and accidental 

• 2. Schuylkill River Toxics—from withdrawing 56.2 Million Gallons Per Da[y]

• 3. Toxic Chemicals—from adding over 300 lbs per day to Cooling Tower

• 4. Greenhouse Gases, Combustion Chemicals & By-products—from Boilers, 

Etc[.]

• 5. Waste Fuel—from a Boile[r]

Comment: 2-63-AM; AIR POLLUTANTS from Limerick Nuclear Plant Include:

• Radiation 

• PM[10] 

• VOCs 

• NOx 

• S[O2] 

• Arsenic 

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Appendix A

• Cadmium

• Chromium 

• Lead

• PCBs

• Halogens 

This dangerous SYNERGISTIC MIX continuously threatens the health of families in the region, 

especially children. ADDITIVE, CUMULATIVE HEALTH IMPACTS could be significant.

Response: The comments identified above, along with supporting documentation submitted 

with the comments, raise concerns about air pollutant emissions from LGS and their impacts to 

human health, air emission sources at LGS, emission control technology, estimated emissions 

as opposed to actual emission measurements, permitted increases in air emissions by the 

PDEP, and radiation emissions.

Chapter 2 of the EIS discusses air pollutant emissions and sources resulting from operations at 

LGS, and Chapter 4 of the EIS discusses the potential impacts on air quality from continued 

operation of LGS during the license renewal term.

The Environmental Protection Agency has set limits on six criteria air pollutants (O3, CO, Pb, 

SOx, NOx, PM2.5 and PM10), known as primary standards, to provide public health protection, as 

these are considered harmful to public health. The CAA requires states to attain and maintain 

these standards. The PDEP is responsible for achieving the goals of the Federal CAA, by 

ensuring compliance with permitting requirements and developing enforcement policies.

As discussed in Section 2.2.2.1, LGS has a Title V permit issued by the PDEP to operate 

sources of air pollution at LGS, and Exelon is required to submit annual compliance certification 

to the PDEP. The NRC staff reviewed Exelon’s emission inventory production reports for LGS 

for 2007 through 2011 that were submitted to the PDEP (ML12110A233), which identified the air 

pollutant emissions the commenter has highlighted. Emissions of criteria air pollutants resulting 

from operation are presented in Table 2–1, and the sources of air pollution, as noted by the 

commenter, are identified in Section 2.2.2.1 of the SEIS. Based on the NRC staff’s review of 

LGS’s air pollutant emissions and no planned site refurbishment activities during the license 

renewal term, the NRC staff concluded that the impact from continued operation would be 

SMALL.

In the supporting documentation provided with the comments, the commenter requests that 

NRC require Exelon to install filtration to reduce emissions; however, the PDEP is responsible 

for the requirements and enforcement of emission control technology. Additinally, the 

commenter expressed concernes about estimated calculated air emissions as opposed to 

actual measured air emissions. Exelon estimates actual air emissions and provides these 

estimated values to the PDEP as part of their annual compliance certification in accordance with 

the requirements of the Title V operating permit. The methodology to estimate emissions is 

identified in the annual compliance certification, in accordance with the permit, and approved by 

the PDEP. The NRC staff requested and reviewed Exelon’s Title V operating permit issued by 

the PDEP (ML12110A222).

In the supporting documentation provided with the comments, the commenter also raised the

concern that radiation emissions are omitted from the Title V permit. The NRC is responsible 

for regulating air emissions of radionuclides from nuclear power reactors. The Title V permit 

pertains to sources of criteria air pollutants (O3, CO, Pb, SOx, NOx, PM2.5, and PM10) or 

hazardous air pollutants not regulated by the NRC. The impacts to human health from 

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Appendix A

radioactive effluent releases from LGS are discussed in Chapter 4 of the SEIS. Based on the 

NRC staff’s review of LGS’s radioactive effluent and environmental monitoring programs, the 

NRC concluded that doses were within NRC and EPA radiation protection standards and the 

impact during the license renewal term would be SMALL.

These comments do not present any new and significant information; therefore, no changes 

were made to this SEIS.

A.2.3 Aquatic (AQ) 

Comment: 23-27-AQ; Dilution is not a solution for pollution. P. 2-45 line 11, Exelon has not 

conducted sampling or monitoring of aquatic biota in Possum Hollow Run[.] Why not? Almost 

criminal, has DEP? Read the NPDES Permit application and weep.

Where are the dredge spoils for the Vincent Dam that were removed from the Schuylkill River 

several years ago? Were they tested for RAM? Why is this information so hard to get?

Response: Section 2.2.6 provides an overview of aquatic resources within the vicinity of LGS 

and its associated cooling system, including relevant aquatic monitoring and other studies 

conducted by Exelon and Federal, State, and local natural resource agencies. Sections 2.1.6 

and 2.2.4.2 describe Exelon’s NPDES permit and associated monitoring. For example, 

Exelon’s NPDES permit specifies maximum levels of various chemical concentrations and 

thermal limits in the discharge. In general, the purpose of an NPDES permit is to ensure that 

the concentration of various chemicals, organisms, or other pollutants within water bodies meet 

mandatory state and Federal standards for clean water. This comment does not provide any 

new and significant information; therefore, no changes were made to this SEIS

Comment: 23-38-AQ; Marcellus shale, page 4-47 line 28. Please note article attached p 5-29-

13. New since LNPP went on line.

Comment: 23-39-AQ; Please explain this. Page 4-48 line 12 (4.12.3.4 conclusion). This is 

completely illogical and dangerous. New since LNPP went on line. Stresses on river. Recently 

for 8 years agonized over and Exelon won—river is now augmented and groundwater in 

Schuylkill County and the river devoted to LNPP. Yes—increasing urbanization[.] Yes—

increasing demand for water. People have right to clean water depend on factors NRC can[’]t 

qua[n]tify. How can you write that and then make a conclusion?

Response: Section 4.12.3 describes the cumulative impacts to aquatic resources from other 

past, present, and reasonably foreseeable Federal and non-Federal activities that could have 

overlapping impacts with the continued operation of LGS. Section 4.12.3.2 specifically 

describes potential cumulative impacts from the mining of Marcellus shale. This section was 

updated based on new projects that have been considered or approved since publication of the 

draft SEIS.

NRC staff characterized potential cumulative impacts on aquatic resources as SMALL to 

MODERATE by applying the definitions of these impact levels in 10 CFR Part 51. This 

assessment is based on the staff’s technical evaluation using the best available information. 

Comment: 32-14-AQ; Page 2-37, Lines 11 to 13, Section 2.2.6. During the water supply 

demonstration project (see LGS License Renewal Application Environmental Report, p. 3-8, 

Section 3.1.2.1), the DRBC removed temperature as a restriction on water withdrawal from the 

Schuylkill River, and the DRBC docket issued on May 8, 2013[,] did not reinstate any 

temperature restriction. Accordingly, Exelon requests that the sentence in lines 11 to 13 on 

page 2-37 be revised as follows: “When temperature and flow conditions in the Schuylkill River 

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Appendix A

do not meet DRBC criteria for water use, LGS secondarily relies[ ]on water from Perkiomen 

Creek.”

Comment: 32-15-AQ; Page 2-40, Line 31, Section 2.2.6.1. During the water supply 

demonstration project (see LGS License Renewal Application Environmental Report, p. 3-8, 

Section 3.1.2.1), the DRBC removed temperature as a restriction on water withdrawal from the 

Schuylkill River, and the DRBC docket issued on May 8, 2013[,] did not reinstate any 

temperature restriction. Accordingly, Exelon requests that the sentence in lines 11 to 13 on 

page 2-37 be revised as follows: “As described in Section 2.1.6, LGS withdraws water from 

Perkiomen Creek, rather than the Schuylkill River, if the flow and temperature conditions in the

Schuylkill River do not meet DRBC criteria for water use.”

Response: The NRC staff updated Section 2.2.6 of the SEIS to reflect the most current DRBC 

docket that was issued on May 8, 2013.

Comment: 32-24-AQ; NRC’s determination of SMALL to MODERATE cumulative impacts on 

aquatic resources is based on the combination of past flow alterations, increased suburban 

residential/commercial development, existing power/industrial/municipal NPDES dischargers, 

Marcellus shale/energy development activities, and climate change. Exelon requests that this 

conclusion be further clarified by adding the following sentence at the end of the paragraph in

line 17 on page 4-48: “However, the most significant contributory effects would come 

from activities in the region that are unrelated to continued LGS operation.” 

Response: Section 4.13.3 examines the cumulative impacts from other past, present, and 

reasonably foreseeable Federal and non-Federal activities that could have overlapping impacts 

with the continued operation of LGS. The NRC staff determined that the cumulative impacts 

from other past, present, and reasonably foreseeable activities would range from SMALL to 

MODERATE. As stated in Section 4.6 and stated in Section 4.13.3, impacts to aquatic 

resources from the continued operation of LGS would be SMALL. This comment does not 

provide any new and significant information; therefore, no changes were made to this SEIS. 

A.2.4 Climate Change (CC) 

Comment: 28-3-CC; As new science emerges on the topic of Climate Change, this facility 

should consider adaptations that might be appropriate for the future. Please address this issue 

in the Final EIS[.]

Response: NRC is actively engaged to stay abreast of changes in environmental conditions at 

its licensed facilities. In informing NRC’s operating reactor license renewal environmental 

reviews, NRC utilizes consensus information from the U.S. Global Change Research Program 

(USGCRP). The USGCRP integrates and presents the prevailing consensus of Federal 

research on climate and global change, as sponsored by 13 Federal agencies. Climate change 

and its related impacts on air quality (Section 4.12.1), water resources (Section 4.12.2), aquatic 

resources (Section 4.12.3), and terrestrial resources (Section 4.12.4) are discussed in the EIS. 

The discussions identify the environmental impacts that could occur from changes in regional 

climate conditions specific to a resource area. Climate change adaptation of a facility is 

considered out of scope for the environmental review, which documents the potential 

environmental impacts of continued operation, and was not evaluated in the development of this 

SEIS. 

Implications of global climate change are important to the operating conditions and 

infrastructure of LGS. All currently operating nuclear power plants are located in consideration 

of site-specific environmental conditions. This siting analysis included consideration of 

meteorologic and hydrologic siting criteria set forth in 10 CFR Part 100, as applicable, and 

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Appendix A

nuclear power plants were designed and constructed in accordance with 10 CFR Part 50, 

Appendix A, General Design Criteria (GDC). These regulations require that plant structures, 

systems, and components important to safety be designed to withstand the effects of natural 

phenomena such as flooding from severe storms, without loss of capability to perform safety 

functions. Plant operations are dictated by NRC-issued operating license technical 

specifications which ensure that plants operate safely at all times. Technical specifications and 

operating procedures exist to ensure safe operation of the facility. Any proposed changes in 

operating conditions contrary to operating license technical specifications requires the NRC to 

conduct safety reviews of any such license amendment prior to allowing the specific licensee to 

continue operation. Additionally, the NRC evaluates nuclear power plant operating conditions 

and physical infrastructure to ensure continued safe operations through its reactor oversight 

program. If new information becomes available, the NRC evaluates the new information to 

determine if any changes are needed at existing plants or to its regulations. 

The NRC performs a safety review of the applicant’s license renewal application to determine if 

there is reasonable assurance that the effects of aging will not adversely affect any systems, 

structures, or components. The results of the safety review are documented in the SER. 

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

A.2.5 Cumulative Impacts (CI)

Comment: 2-14-CI; NRC staff also concluded that cumulative impacts from Limerick’s license 

renewal would be small in all areas except aquatic ecology and terrestrial ecology. That 

conclusion is patently absurd. You arrogantly and irresponsibly dismiss the harms, risks, and 

threats from Limerick as callously as you consider the members of our community to be merely 

acceptable collateral damage.

Response: The definition of a cumulative impact is the impact on the environment which 

results from the incremental impact of the action (license renewal) when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or nonFederal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor, but collectively significant, actions taking place over a period of time.

As discussed in Chapter 4 of the SEIS, with the exception of aquatic and terrestrial ecology, 

continued operation of Limerick during the license renewal term would have SMALL to no 

impact on environmental conditions in the region beyond what is already being experienced. 

For example, since Exelon has no plans to hire additional workers during the license renewal 

term, overall expenditures and employment levels at Limerick would remain unchanged with no 

additional demand for permanent housing and public services. Based on this and other 

information presented in Chapter 4 of the SEIS, there would be no contributory effect from the 

continued operation of Limerick on environmental conditions in the region beyond what is 

already being experienced. Therefore, the only contributory effects would come from 

reasonably foreseeable future planned activities at Limerick, unrelated to the proposed action 

(license renewal), and other reasonably foreseeable planned offsite activities. 

This comment does not provide any new and significant information; therefore, no changes 

were made to the SEIS. 

Comment: 9-1-CI; I am here to testify on behalf of the Schuylkill River Restoration Fund that 

Exelon supports. The Berks Conservancy has been a successful annual award recipient and 

implementer of the Schuylkill River Restoration Fund grants for agricultural best management 

practices since the inception of the fund. 

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Appendix A

The implementation of agricultural best management practices directly affect the quality of water 

in the Schuylkill River watershed and are done to positively impact the drinking water for 

hundreds of thousands of people who live in our region. The Schuylkill River Restoration Fund 

grant awards have been critical to the completion of dozens of agricultural best management 

practice projects on different farms in Berks County. These projects are done in prioritized 

subwatersheds of the Schuylkill River watershed, generally those where they are ranked as the 

most impaired.

The Schuylkill River Restoration Fund as a private grant fund has granted us over $1.3 million 

since 2008 and has enabled us to leverage larger, significant public funds including [U.S.

Department of Agriculture] USDA Natural Resource Conservation Grants.

Our Schuylkill River Restoration Fund Agriculture Best Management Practice Project has taken 

a holistic approach to water protection utilizing conservation and nutrient management planning. 

The north storage barnyard patrols, stormwater controls, segregating clean rainwater from 

surface manures, stream bank venting, prescribed grazing, and riparian buffer restoration.

Investment in conservation measures on Schuylkill River watershed farms is critical on 

numerous fronts: upgrading farm facilities, especially in regard to the manure management and 

fertilizer dollars[,] helps to keep farmers competitive and successful. When farms are 

competitive and successful, conversation of farms to development is less likely to occur, thereby 

retaining fields capable of groundwater recharge as opposed to the impervious surfaces of 

housing and commercial ventures which generate serious stormwater and water quantity 

impact.

Proper management and timing of application of manure by segregation from surface waters on 

farms and stormwater generated on farms is not only beneficial to farmers’ time management 

and bottom line, but it’s also beneficial to plant growth and production and to water quality as 

nutrients are utilized by crops and not lost in streams, thereby protecting water quality.

The implementation of this agricultural best management practice, Schuylkill River Restoration 

Fund Project has also served as the impetus for public drinking water suppliers to participate 

and invest in these projects as additional funders and has been an exemplary model for 

public/private cooperation and a successful mode for accomplishing the work on the ground for 

water quality.

The Schuylkill River Restoration Fund has positively influenced the water quality and quantity of 

the surface water of the Schuylkill River watershed utilized by local and regional drinking water 

suppliers like Philadelphia Water Department, Aqua PA, Reading Area Water Authority, 

Western Berks Water Authority, Birdsboro Water Authority, and Kutztown Borough.

The Berks Conservancy strongly supports the continuation of the Restoration Fund for its 

benefit to the food and water supplies security of the Schuylkill River watershed and welcomes 

Exelon’s continued support.

Response: This comment expresses appreciation for Exelon’s continued support for the 

Schuylkill River Restoration Fund. The comment highlights the positive influence the fund has 

had on water quality, and the quantity of surface water in the Schuylkill River watershed utilized 

by local and regional drinking water suppliers. 

The staff considered the comment to determine if the information provided would change the 

staff’s findings in Chapter 4 of this SEIS that the potential cumulative impacts would range from 

SMALL to MODERATE, depending on the resource. The staff determined that the information 

provided in the comment did not provide new and significant information; therefore, no changes 

were to this SEIS. 

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Appendix A

A.2.6 Decommissioning (DC)

Comment: 2-28-DC; 2-3-13 It was reported that Exelon provided NRC with inaccurate 

information about how much money will be available to decommission Exelon’s power plants, 

potentially hiding a shortfall of “roughly $1 Billion[.”] This should show NRC why they can’t trust 

any information provided by Exelon, especially in radiological monitoring reports.

Comment: 5-9-DC; Decommissioning. That’s funded through hidden charges in our electric 

bills and through miscalculations, deliberate or not, on Exelon’s part, $100 million will be needed 

for Limerick which Exelon wants ratepayers to fund. Exelon makes mistakes, but we pay for 

them. 

Response: The NRC does not assess licensee decommissioning financial assurance as part 

of license renewal; rather licensees are required to provide an updated decommissioning 

funding status report every two years for NRC review. The most recent licensee 

decommissioning funding status reports were submitted to the NRC in March of 2013 and the 

staff’s analysis is summarized in SECY-13-0105, which is available on the NRC website.

http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2013/ 

These commenst do not provide any new and significant information; therefore, no changes 

were made to this SEIS.

Comment: 23-42-DC; Closure and decommissioning should be clearly understood by local 

population. If the life is what will be left at the end and who is liable? So do a complete EIS for 

decommissioning[.]

Comment: 23-43-DC; What? P. 7-1, line 27. There are no site-specific issue related to 

decommissioning. The site will be the same whether or not the plant operates? Of course there 

are issues[,] and NRC should spell them out.

Comment: 23-44-DC; Brownfields is the biggest public scam there is[;] it[’]s about liability and 

transferring it on to public. The spent fuels rods will be there. What will happens to them? 

Closure – What happens to radioactive materials like cement, steel, water, sole etc. in closure? 

What happens to the HLW pool? How long is Exelon liable? What gets dumped there?

Comment: 2-16-DC; In Section 9.3.2 of your EIS Exelon claims “after decommissioning these 

facilities, and restoring the area, the land could be available for other productive uses.” This is a 

delusional conclusion, worthy of no less than four Pinocchios. This is the same land that Exelon 

claimed was worth zero when it fought to avoid paying its fair share of property taxes for years.

Response: The impacts of decommissioning are described in the Generic Environmental 

Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning 

of Nuclear Power Reactors, NUREG-0586 (decommissioning GEIS). Some activities (e.g., 

security and oversight of SNF) would remain unchanged, while others (waste management, 

office and clerical work, laboratory analysis, surveillance, monitoring, and maintenance) would 

continue at reduced or altered levels after the termination of reactor operations.

The decommissioning process, by its very nature, generates wastes. The wastes generated are 

shipped off site, where they are permanently disposed of, or stored onsite for a certain period or 

indefinitely. Under the three decommissioning options analyzed in the decommissioning GEIS, 

the DECON process would generate the most waste. In this process, the equipment, 

structures, and portions of the facility and site that contain radioactive contaminants are 

removed and decontaminated to a level that permits termination of the license after cessation of 

operations. In the SAFSTOR process or ENTOMB process, the materials are left on site 

temporarily or permanently, respectively.

A-73
Appendix A

The types of wastes generated during decommissioning would include low level radioactive 

waste, mixed waste, hazardous waste, and nonradioactive, nonhazardous waste. No spent 

fuel, high level radioactive waste, or transuranic waste would be generated during 

decommissioning because spent fuel would have been removed from the reactor and stored in 

either the reactor’s spent fuel pool or in an ISFSI before the start of decommissioning.

The NRC has developed regulations and guidance for the decommissioning of nuclear facilities, 

including nuclear power plants. These regulations are found in 10 CFR 50.82 (Termination of 

License), Subpart E to 10 CFR Part 20 (Radiological Criteria for License Termination), and the 

guidance document Consolidated NMSS Decommissioning Guidance, NUREG-1757.

At the completion of decommissioning, which may take up to 60 years to complete (10 CFR 

50.82(a)(3)), the licensee would conduct a final status survey to demonstrate compliance with 

criteria established in the decommissioning plan. At the end of the decommissioning process, 

the nuclear power plant site and any remaining structures on the site may be released for 

unrestricted or restricted use. The radiological criteria for releasing sites for unrestricted use are 

given in 10 CFR 20.1402. The criteria for restricted conditions and alternate criteria that the 

NRC may approve under certain conditions are listed in 10 CFR 20.1403 and 10 CFR 20.1404, 

respectively.

These comments provided no new and significant information; therefore, no change was made 

to this SEIS.

A.2.7 Geology (GE) 

Comment: 2-55-GE; Earthquakes can break and disrupt pipes. There is an earthquake fault 

right under the site, with four others within 17 miles.

Comment: 2-59-GE; Earthquakes can cause leaks by shaking and breaking Limerick’s miles of

underground pipes and vast numbers of fittings.

• Limerick is 3rd on the nation’s earthquake risk list for nuclear plants.

• Two earthquake faults are extremely close to Limerick—9 miles and 17 miles 

away.

• There is great cause for concern, considering the August 23, 2011[,]

earthquake

Comment: 4-2-GE; [...]which reminds me, four months have passed since the NRC failed to 

get back to me when I asked how close the R[a]mapo fault line is to the Limerick nuclear 

reactors? Maybe I can get an answer today[.]

Comment: 4-14-GE; It took five months for the Nuclear Regulatory Commission to answer my 

question concerning how close the nearest fault[ ]line is to Limerick Nuclear Plant. No wonder! 

Two faults are dangerously close. Chalfont Fault is only 9 miles East. Ramapo Fault is 17 

miles [n]orthwest. This is alarming!

Comment: 7-3-GE; My search for earthquake fault lines closest to Limerick Nuclear Plant is 

one big reason I have no confidence in any of NRC’s conclusions in Limerick's Environmental 

Impact Statement. May 2011, I asked NRC how close the nearest fault lines were to Limerick 

Nuclear Plant. Six months later in September 2011 at the first EIS hearing, I repeated my 

request. When NRC finally responded, I received a letter and a map showing earthquake fault 

17 miles from Limerick.

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Later, I learned NRC failed to disclose an earthquake fault right under the Limerick site and two 

others within two miles. Local residents discovered a 1974 seismic study for Limerick in the 

Pottstown Library, clearly identifying these faults. So why did NRC fail to disclose these faults 

when I asked about the closest earthquake faults to Limerick?

Comment: 7-4-GE; The August 2011 earthquake in Virginia shook Limerick Nuclear Plant and 

caused a Limerick notice of violation. This should have caused NRC to require Exelon to 

reduce seismic risk immediately. Rosebrook did admit that the Ramapo Fault just 17 miles from 

Limerick is active. He also validated my concern about the blasting at the quarry bordering 

Limerick.

Comment: 30-3-GE; Limerick should NOT be approved for an extension with their permit for 

the following reasons:

• Limerick is designated as one of the TOP THREE nuclear plants in the 

country based on [its] construction (which is similar to the ones in Japan—

and we see how they failed) and the fact that it sits on an earthquake fault 

line.

• The NRC JUST a few weeks ago stated that “more information needs to be 

done and studied” regarding further fortifying nuclear plants regarding 

earthquakes. Thus, until you folks know exactly what needs to be done, etc.[ 

]THERE IS NOTHING TO APPROVE as long as Limerick sits in [its] current 

position.

• Do NOT think that earthquakes only happen on the West Coast—as we 

JUST had a 6+ earthquake less than a[ ]month ago. BY ONLY luck was 

there no damage to the plant, environment[,] or community.

Response: These comments express concern that identified earthquake faults located near 

LGS could affect plant operations and safety as well as concern for measures to address 

seismic risk. Geologic and seismic conditions and related natural hazards were considered in 

the original siting and design of all nuclear power plants, including Limerick, and are part of the 

license bases for operating plants. Seismic conditions are attributes of the geologic 

environment that are not affected by continued plant operations and are not expected to change 

appreciably during the license renewal term. Seismic hazards and related natural phenomena 

are assessed in the site-specific safety review, where appropriate, that is performed for license 

renewals, rather than in the environmental review. NRC’s Safety Evaluation Report for Limerick 

is available at http://pbadupws.nrc.gov/docs/ML1217/ML12173A470.pdf. This report is also 

available to the public through the ADAMS electronic reading room on the NRC’s website 

(www.NRC.gov). The ADAMS accession number for the site report is ML12173A470. 

Further, the NRC requires all licensees to take natural phenomena, including seismic activity 

and related effects, into account in order to maintain safe operating conditions at all nuclear 

power plants. When new information becomes available, the NRC evaluates the new 

information to determine if any changes are needed at existing plants. This has been the case 

with all such events with lessons for maintaining safe operating conditions at nuclear power 

plants including the events of September 11, 2001, the accident at the Fukushima Dai-ichi

nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and

subsequent tsunami, and the August 23, 2011, earthquake near Mineral, Virginia, close to the 

North Anna Power Station. This evaluation process remains separate from license renewal. 

For example, following the events of September 11, 2001, NRC required all nuclear plant 

licensees to take additional steps to protect public health and safety in the event of a large fire 

or explosion. If needed, these additional steps could also be used during natural phenomena 

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Appendix A

such as earthquakes, tornadoes, floods, and tsunami. In general, these additional steps are 

plans, procedures, and prestaged equipment, whose intent is to minimize the effects of adverse 

events. In accordance with NRC regulations, all nuclear power plants are required to maintain 

or restore cooling for the reactor core, containment building, and spent fuel pool under the 

circumstances associated with a large fire or explosion. These requirements include using 

existing or readily available equipment and personnel, having strategies for firefighting, 

operations to minimize fuel damage, and actions to minimize radiological release to the 

environment. Thus, topics related to the impact of earthquakes on plant systems are outside 

the scope of the environmental review. Nevertheless, as part of characterizing the 

environmental baseline (affected environment) and associated resource conditions of the 

Limerick site and vicinity, Section 2.2.3 of this SEIS includes a discussion of the geologic 

environment including its seismic setting. 

The bedrock of the Eastern United States is essentially laced with faults and similar structural 

features that are primarily attributable to ancient tectonic events and associated displacement 

that has not continued into the present. Most of the mapped faults have no seismic significance 

at all as there has been no differential movement along most such faults since their formation, 

and no associated earthquake activity in recent times. Such is the case with the Triassic-age 

bedrock that underlies the LGS site as described in Section 2.2.3 of this SEIS. As discussed in 

Section 2.2.3, the small faults mapped in proximity to the LGS site have been well-documented, 

have not been active for at least 140 million years based on field studies, and they are not 

included in the U.S. Geological Survey’s Quaternary Fault and Fold Database. Consequently, 

these small faults are not considered “capable” of producing earthquakes as defined in NRC’s 

regulations at 10 CFR Part 100, Appendix A.

All earthquakes that do occur are centered on faults in the earth’s crust, and the relatively 

infrequent earthquakes experienced in the Eastern United States are located on faults that are 

deeply buried, making identification of the causative fault difficult. For locations east of the 

Rocky Mountains, the best guide to earthquake hazard is the frequency and distribution of 

earthquakes themselves. Regionally, in association with tectonic margins in deep crustal rock, 

there are more extensive fault systems that have been associated with earthquake activity. As 

referenced by commenters, one of these is the Ramapo fault system, which is also described in 

Section 2.2.3 of this SEIS. Section 2.2.3 summarizes historical and current earthquake activity 

within the region surrounding Limerick.

These comments do not present any new and significant information; therefore, no changes 

were made to this SEIS. 

Comment: 23-24-GE; P. 2-30 line 28 “...shaking would likely result[...]” too vague and wishful

Response: This comment expresses concern over a statement in Section 2.2.3 of the SEIS 

regarding the effects from ground shaking expected to be produced in eastern Pennsylvania 

from a magnitude 6.0 earthquake occurring in southeastern New York or northern New Jersey. 

As part of characterizing the environmental baseline (affected environment) and associated 

resource conditions of the Limerick site and vicinity, Section 2.2.3 of this SEIS includes a 

discussion of the geologic environment, including its seismic setting, based on the best 

available information. However, no impacts or hazard analysis has been performed. Seismic 

hazards and related natural phenomena are assessed in the site-specific safety review, where 

appropriate, that is performed for license renewals, rather than in the environmental review. 

Seismic hazard is also addressed on an ongoing basis as part of the ROP and other processes, 

which are separate from license renewal. 

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Appendix A

As also cited in Section 2.2.3 and listed in Section 2.4 of the SEIS, the information referenced 

by the NRC staff in making the statement originates from a report from the Pennsylvania 

Department of Conservation and Natural Resources, Bureau of Topographic and Geological 

Survey. Specifically, the referenced report discusses historical shaking effects in eastern 

Pennsylvania from moderate earthquakes that occurred in 1737 and 1884. 

For additional information, see also NRC’s response to Comments 2-55-GE, 2-59-GE, 4-2-GE, 

7-3-GE, 7-4-GE, and 30-3-GE.staffThis comment does not present any new or significant 

information; therefore, no changes were made to this SEIS.

Comment: 23-25-GE; P. 2-30 line 30 “ adequately conservative” vague and pathetic 

considering all things Japanese. 

Response: This comment expresses concern over a statement in Section 2.2.3 of the SEIS 

regarding the level of earthquake-produced ground shaking for which LGS was designed. As 

cited in Section 2.2.3 and listed in Section 2.4 of the SEIS, the statement cited by the 

commenter is based on the Updated Final Safety Analysis Report for LGS. Geologic and 

seismic conditions and related natural hazards were considered in the original siting and design 

of all nuclear power plants, including Limerick, and are part of the license bases for operating 

plants. Further, the NRC requires all licensees to take natural phenomena, including seismic 

activity and related effects, into account in order to maintain safe operating conditions at all 

nuclear power plants. When new information becomes available, the NRC evaluates the new 

information to determine if any changes are needed at existing plants. For additional 

information, see also NRC’s response to Comments 2-55-GE, 2-59-GE, 4-2-GE, 7-3-GE, 7-4-

GE, and 30-3-GE. 

This comment does not present any new or significant information; therefore, no changes were 

made to this SEIS.

A.2.8 Greenhouse Gas (GHG)

Comment: 32-27-GHG; The LGS DSEIS states that the various studies reviewed show that 

“the relatively low order of magnitude of GHG [greenhouse gas] emissions from nuclear power, 

when compared to fossil fueled alternatives (especially natural gas), could potentially disappear 

if available uranium ore grades drop sufficiently . . .” (Emphasis added.) This statement is 

speculative, based on worst-case assumptions, and a review of the information presented in the 

draft LGS DSEIS reveals it to be incorrect. None of the studies cited in Table 6-3 (page 6-7) 

shows that the difference in GHG emissions between nuclear and natural gas would 

“disappear,” even under the worst-case speculative conditions of declining ore grades and bestcase future improvements in natural gas technology. See, e.g., POST (2006) (showing GHG 

emissions nearly an order of magnitude lower for nuclear even under these assumptions). For 

this reason, Exelon suggests reevaluation of the accuracy of the conclusions in the draft LGS 

DSEIS regarding future relative magnitudes of GHG emissions from nuclear power plants 

compared to natural gas power plants.

Response: The NRC staff relied on current available information in discussing its independent 

analysis of Greenhouse Gas Emissions in Section 6.2. Table 6–2 through Table 6–4 present a 

sampling and wide range of studies of lifecycle GHG emissions estimates of various electricity 

generation technologies. The statement the commenter identifies is supported by Mortimer 

(1990), Storm van Leeuwen and Smith (2008), and Sovacool (2008) (all cited in Table 6–3). 

These studies present data on the variation of carbon dioxide emissions released from nuclear 

power with uranium ore grade and illustrate that low grade uranium ores (less than 0.01 percent

uranium oxide), nuclear power lifecycle carbon dioxide emission could potentially exceed those 

A-77
Appendix A

of fossil-fuel fired power plants. Storm van Leeuwen and Smith (2008) particularly present the 

comparison between nuclear power and a gas-fired power plant emissions with decreasing ore 

grade. The commenter references POST (2006), which is also presented in Table 6–3.

The statement regarding future relative magnitudes of GHG emission has not been revised as 

this independent analysis has presented current available data and the sources that support the 

statement questionedby the commenter However, the NRC staff recognizes that additional 

clarification should be provided and additional clarification has been inserted under the note on 

Table 6–2 and Table 6–3.

Comment: 32-28-GHG; On page 6-9, the draft LGS DSEIS states in line 40 that “[f]ew studies 

predict that nuclear fuel cycle emissions will exceed those of fossil fuels within a timeframe that 

includes the LGS periods of extended operation.” However, none, rather than “few,” of the 

studies cited in the draft LGS DSEIS appear to support this thesis. Therefore, Exelon suggests 

that the quoted sentence be deleted and replaced with the following sentence: “Nearly all 

studies predict that nuclear fuel cycle emissions will remain an order of magnitude or 

more below those of all types of fossil fuels during the LGS periods of extended 

operation.”

Response: The NRC staff agrees that this statement needs to be revised. However, there are 

studies that support that nuclear power GHG emissions can possibly exceed those of fossil 

fuels if the ore grade decreases after the year 2050 (See Storm van Leeuwen and Smith 2008). 

Since the renewed operating licenses would allow an additional 20 years of operation for 

Limerick Units 1 and 2, the renewed licenses would expire in 2044 and 2049, respectively. 

Therefore, the statement has been revised to read:

Few studies (e.g., Mortimer 1990, Storm van Leeuwen and Smith 2008) predict that nuclear 

lifecycle emission will exceed those of fossil fuels as a result of declining ore grade, however, 

this is not expected to occur within the timeframe that includes the period of extended operation 

of LGS. 

A.2.9 Groundwater (GW)

Comment: 2-52-GW; Some of Limerick's radioactive leaks continued for long periods of time 

unabated.

Comment: 2-53-GW; NRC never required clean-up of groundwater or soil and vegetation 

around it.

Comment: 2-56-GW; IN NRC'S DRAFT EIS FOR LIMERICK, NRC IRRESPONSIBLY 

CALLED LIMERICK'S GROUNDWATER CONTAMINATION “SMALL” AND MADE 

INACCURATE STATEMENTS.

• GIVEN THE LACK OF INDEPENDENT PROOF AND THE HUGE 

INCREASING RISK FOR RADIOACTIVE LEAKS IN THE MILES OF BURIED 

PIPES UNDER LIMERICK'S SITE, NRC'S CONCLUSION MUST BE 

CHANGED FROM “SMALL” TO “UNKNOWN[.”]

Comment: 2-57-GW; THERE IS CAUSE FOR CONCERN, PRECAUTION, AND 

PREVENTION!

• AS A CONDITION OF RELICENSING, EXELON SHOULD BE REQUIRED 

TO CLEAN UP THE RADIOACTIVE GROUNDWATER AND SOIL THAT IS 

ALREADY CONTAMINATING THE SITE, TO TRY TO AVOID TRAVEL TO 

OFF-SITE RESIDENTIAL AND BUSINESS WELLS.

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Appendix A

Comment: 2-60-GW; RADIOACTIVE GROUNDWATER CONTAMINATION CAN SPREAD 

INTO OFFSITE WELLS UNDETECTED NOW AND IN THE FUTURE

• Limerick is one of the 102 of 104 of our nation's nuclear reactors that 

contaminated groundwater with radiation.

• Groundwater is confirmed to be radioactive under Limerick's 600 acre site.

• Reliable monitoring to accurately determine the full extent of spreading 

radioactive groundwater contamination would be cost prohibitive. Radiation 

could poison well water for long periods of time.

• Limerick's radioactive contaminated groundwater could have been spreading 

long periods of time, in any direction, in this fractured bedrock aquifer. 

Radioactive groundwater contamination may have already moved off the 

Limerick site, undetected or unreported by Exelon.

• Radiation in Limerick's groundwater was never cleaned up. There is no plan 

to clean it up.

• New leaks and spills can happen without full disclosure.

• Exelon failed to fully disclose and address radioactive water contamination at 

some of its other nuclear plants.

• At one nuclear plant site in Illinois, Exelon failed to provide full and accurate 

disclosure for years, then finally supplied 600 residents with bottled water for 

years more until they were finally put on public water.

• The same thing could happen at Limerick jeopardizing drinking water and 

public health.

• Once groundwater becomes radioactive it is difficult, if not impossible to clean 

up. Exelon never tried, either here or at its other nuclear plants.

Comment: 3-1-GW; My comments concern the groundwater, an issue that is finally getting 

some attention at U.S. nuclear plants is the leakage of radioactive water into the ground, 

beneath and around these plants. All plants leak. These leaks come from pipes, tanks, and 1 

many of the plant's systems. The NRC states that events happen at all plants that are often 

unknown of, unseen, uncontrolled, and unmonitored releases of 4 radioactive liquids into the 

ground. Exelon spokesmen will tell you that they monitor everything and that they have 

everything under control. Don't believe it.

The NRC's statement contradicts that propaganda. These radioactive releases are in addition 

to the known surface spills that frequently occur. In 2006, nuclear plants started a program to 

check into this mounting leakage problem. Fifteen wells were drilled on Limerick property 

outside of the power block areas where the reactors and other equipment sit. One well, P12, 

south and downgrade of the power block area, showed 4400 picocuries per liter of tritium, well 

over the reasonable European safe drinking water level for tritium which is 2700 picocuries per 

liter.

Not liking the result, that well was closed and almost immediately a new well was drilled. Well 

NWRL-9. This well west and downgrade of the power block showed 1700 picocuries per liter. 

Over the next few years as all 15 wells were tested, they all showed tritium and all showed 

gross beta emitters.

Three wells contained gamma emitters, nine had alpha emitters, four out of five wells tested 

positive for uranium. All the ground around Limerick's plant is radioactively contaminated. Most 

A-79
Appendix A

water flow at 4 Limerick, both surface and subsurface, is to the south and west towards Possum 

Hollow Creek, the Schuylkill River and yes, East Coventry Township. Many wells on the East 

Coventry side of the river are in the same Brunswick fractured bedrock formation.

Response: These comments express concern over groundwater quality impacts related to the 

operation of LGS as well as groundwater monitoring and the need for cleanup of groundwater 

contamination. In summary, groundwater resources at LGS and the effects of plant operations 

on groundwater hydrology and quality are presented in Sections 2.2.5 and 4.5.2.2 of the SEIS. 

Section 2.2.5 summarizes the state of knowledge related to historical radionuclide releases to 

groundwater beneath the site, hydrogeologic investigations performed at the site, and the 

results from historical and ongoing groundwater monitoring. More specifically, Section 2.2.5.1 

discusses groundwater users at and in the vicinity of the plant and Section 2.2.5.2 summarizes 

the results of NRC’s review of Exelon’s RGPP for LGS, including the placement of site 

groundwater monitoring wells. The NRC staff specifically reviewed the hydrogeologic 

investigation prepared for LGS in 2006 and the results of ongoing groundwater quality 

monitoring. Section 4.9.2 of this SEIS presents the NRC staff’s evaluation of the impacts of 

radionuclide releases from LGS to groundwater and other media with respect to human health. 

All studies reviewed by the NRC staff are cited in Chapters 2 and 4 of this SEIS.

Sections 2.2.5.2, 4.5.2.2, and 4.9.2 of this SEIS have been updated to reflect the latest 

groundwater monitoring results for LGS, which are documented as part of Exelon’s annual 

REOP submitted to the NRC. These reports document the results of Exelon’s REMP. Exelon 

must also submit radionuclide effluent release reports to the NRC as required by 

10 CFR 50.36a. The regulation requires nuclear power plants to annually submit a report that 

lists the types and quantities of radioactive effluents released into the environment as a 

requirement of each nuclear power plant’s operating license. As detailed in Section 4.9.2 of this 

SEIS, the REMP measures the aquatic, terrestrial, and atmospheric environment for 

radioactivity, as well as the ambient radiation. The REMP supplements the radioactive effluent 

monitoring program by verifying that any measurable concentrations of radioactive materials 

and levels of radiation in the environment are not higher than those calculated using the 

radioactive effluent release measurements and transport models. These reports are publicly 

available at 

http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/lim1-2.html. 

Based on the staff’s review and as presented in Section 4.5.2.2 of this SEIS, no strontium-90 or 

gamma-emitting radionuclides have been detected in groundwater or surface water associated 

with LGS operations or at levels above natural background. While inadvertent releases of 

liquids containing tritium (a radioactive isotope of hydrogen) have occurred to the ground and 

subsurface at LGS as recently as 2012, levels in groundwater are less than one-tenth of the 

drinking water standard of 20,000 picocuries per liter. No upward trend in tritium levels has 

been observed, and Exelon’s ongoing RGPP functions to detect and address potential new 

sources of groundwater contamination. Regardless, there are no offsite drinking water wells 

downgradient of LGS that could be affected by inadvertent releases of radionuclides to 

groundwater. Additionally, the NRC’s ongoing Inspection Program periodically inspects 

Exelon’s radioactive effluent monitoring and REMP programs (as described in Section 4.9.2 of 

this SEIS) for compliance with NRC’s radiation protection standards in 10 CFR Part 20. The 

NRC’s inspection program evaluates the data for compliance with radiation protection 

standards. If the data were to show a noncompliance with requirements, the NRC would take 

appropriate enforcement action.

Exelon has implemented its RGPP as part of its participation in the Nuclear Energy Institute’s 

Groundwater Protection Initiative (NEI 2007). The program is designed to ensure timely 

detection and effective response to situations involving inadvertent radiological releases to 

A-80
Appendix A

groundwater, from whatever the source, and to enhance licensee communications with their 

stakeholders about these situations. The early detection of contamination, typically through 

onsite monitoring wells, allows licensees to take actions as necessary to prevent the offsite 

migration of licensed radioactive material. The NRC also reviews licensees’ implementation of 

the industrywide Ground Water Protection Initiative as part of its radiation protection program

oversight. The program itself is not an NRC-required program and NEI’s guidance document 

is not subject to regulatory enforcement.

With respect to contamination, there are regulatory requirements for licensees to conduct 

radioactive effluent and environmental surveys and monitoring for routine effluents and also for 

abnormal spills and leaks of radioactive liquids. Specifically, 10 CFR 50.75(g) requires that 

licensees keep records of radiological information important to the safe and effective 

decommissioning of the facility. These records include information on known leaks, spills, or 

other unusual occurrences involving the spread of contamination in and around the reactor

facility. These records contain information on significant radioactive contamination remaining 

after any cleanup or when the contamination may have spread to inaccessible areas within the 

facility. Such records of spills and leaks are periodically reviewed by NRC inspectors.

At the end of the renewed operating license, a licensee’s decision to remediate contamination 

before the plant is decommissioned is typically based on several factors, including “as low as is 

reasonably achievable” (ALARA) considerations for potential worker and public dose, cost, 

feasibility, disposal options, and external stakeholder considerations. The NRC has defined 

radiation limits for the decommissioning of a nuclear reactor and release of the facility or site for 

unrestricted use by members of the public. The requirements are contained in 10 CFR Part 20, 

Subpart E, “Radiological Criteria for License Termination.”

These comments do not present any new or significant information; therefore, no changes were 

made to this SEIS in response to these comments.

Comment: 2-41-GW; Water companies are not required to continuously monitor, test, or filter 

the water for all Limerick's radionuclides.

Comment: 2-43-GW; Limerick Nuclear Plant Testing Reports Reveal Iodine-131 In Water and 

Fish. Limerick is Clearly A Major Source of Iodine-131 Found In Philadelphia Water At The 

Highest Levels Of Any Water Treatment Plant In The Nation, Out Of 66 Cities Tested. 

Philadelphia is only about 20 Miles Downstream from Limerick.

Response: These comments express concern over testing for radionuclides in public water 

supplies. NRC’s authority does not extend to requiring public systems to test for contaminants. 

That authority is held by the Commonwealth of Pennsylvania in their implementation of the 

provisions of the Safe Drinking Water Act. staff

These comments do not present any new or significant information; therefore, no changes were 

made to this SEIS in response to these comments.

Comment: 32-12-GW; Page 2-23, Lines 30to 31, Sections 2.1.7.2. Because the DRBC docket

for LGS has been approved, revise the sentence in lines 30 to 31 on p. 2-23 as follows: “The

draft docket issued by the DRBC (see Section 2.1.7.1) proposes groundwater production limits

for LGS. The approved DRBC docket for LGS (see Section 2.1.7.1) restricts groundwater 

withdrawals from each LGS well and from the total system, except during fire

emergencies and other plant emergencies.” 

Response: The NRC staff updated Section 2.1.7.2 of this SEIS to be consistent with the May 

8, 2013, docket approval by the DRBC.

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Appendix A

Comment: 32-29-GW; Page 8-9, Lines 22 to 23, Section 8.1.2. Because LGS does not use 

groundwater for service water makeup, revise the sentence in lines 22 to 23 on page 8-9 as 

follows: “This includes the use of groundwater for service water makeup backup supply of fire 

emergency water and potable and sanitary uses.” 

Response: The NRC staff updated Section 8.1.2 for consistency with Section 2.1.7.2 of the 

SEIS with regard to current uses of groundwater at LGS.

Comment: 32-31-GW; Page 8-12, Lines 12 to 13, Section 8.2.2. Because LGS does not use 

groundwater for service water makeup, revise the sentence in lines 12 to 13 on page 8-21 as 

follows: “This includes the use of groundwater for service water makeup backup supply of fire 

emergency water and potable and sanitary uses.”

Response: The NRC staff updated Section 8.2.2 for consistency with Section 2.1.7.2 of the 

SEIS with regard to current uses of groundwater at LGS.

Comment: 32-32-GW; Page 8-30, Lines 41 to 42, Section 8.3.2. Because LGS does not use 

groundwater for service water makeup, revise the sentence in lines 41 to 42 on page 8-30 as 

follows: “This includes the use of groundwater for service water makeup backup supply of fire 

emergency water and potable and sanitary uses.”

Response: The NRC staff updated Section 8.3.2 for consistency with Section 2.1.7.2 of the 

SEIS with regard to current uses of groundwater at LGS.

A.2.10 Historical and Archaeological (HA) 

Comment: 1-1-HA; The rehabilitation of Frick's Locks Village as a historical site and 

destination within the township is very exciting. The rehabilitation work performed by Exelon 

has given the village renewed life and has brought our history into focus. The community has 

benefitted as a result of Exelon's commitment to work with the township on preserving Frick's 

Locks Village. And they did a wonderful job. We had an opening there last week and it was 

really great.

Comment: 21-1-HA; And my neighbor is the Limerick Generating Station. I live a short 

distance from Frick's Lock National Registered Historic District. About two thirds of this district 

is within the exclusionary boundary, right on the cusp of the Limerick Generating Station, 

therefore, uninhabited.

Greatly due to increasing vandalism and a fire at the Lock Tender's House in February 2008, 

the Frick's Lock stakeholders were formed to negotiate a satisfactory resolution towards the 

preservation of Frick's Lock. The stakeholders were represented by members from Exelon, the 

Schuylkill River Heritage Area, East Coventry Township, Chester County, Senator Breneman 

and Preservation Pennsylvania, and the Pennsylvania Historic and Museum Commission.

On February 14, 2011, Valentine's Day, an agreement between Exelon and East Coventry 

Township was accepted to rehabilitate Frick's Lock. Construction began and was completed 

the following year 2012. The first public tour of Frick's Lock Historic District is scheduled for 

June 8, 2013.

I believe this is the first time a major utility has rehabilitated a National Historic District in 

negotiated terms to allow a local historical commission limited access to conduct guided tours 

within the EAB. Not only did this project enrich the history and heritage of our community, but 

Frick's Lock also lies adjacent to the proposed Schuylkill River Trail and as a trail head will be a 

tourist destination and a boost to our local economy.

A-82
Appendix A

As a member of the Frick's Lock stakeholders, I am still amazed at what can be accomplished 

when a large corporation, Exelon, is willing to come to the table and work with individuals and a 

community to contribute to and enhance our resources. Thank you, Exelon, and I look forward 

to a continued participation within the Frick's Lock stakeholders.

Response: These comments are supportive of Exelon’s rehabilitation of the Fricks Lock 

Historic District. These comments provide no new or significant information; therefore, no 

changes were made to this SEIS. 

Comment: 23-10-HA; Historic resources, Frick's Lock aside, don't include some of the places 

that I know are on the Historic District and it also said that there were no federal lands owned in 

the 50-mile radius except Valley Forge. Maybe the Independence National Park isn't nationally 

owned. I don't know. Hopewell Furnace, the Heinz National Wildlife Refuge, I question that.

Response: Identification and discussion of specific historic and archaeological resources is 

limited to those resources which may be directly or indirectly affected by continued operations of 

LGS. Other historic and archaeological resources may exist within the general vicinity of LGS 

and surrounding counties; however, identification of historic and cultural resources focuses on 

those resources located within the defined area of potential effect (APE)—the plant site and its 

immediate environs. The existence of historic and archaeological resources outside of the APE, 

such as Pottstown Historic District, is referenced in Section 2.2.10.2 of this SEIS.

Section 2.3, “Related Federal and State Activities,” has been updated to accurately reflect 

Federally owned lands, facilities, and wildlife refuges and reserves within 50 mi of LGS.

Comment: 32-18-HA; Page 2-83, Lines 35 to 37, Section 2.2.10.2. Because rehabilitation and 

mothballing activities at the Fricks Lock Historic District have been completed, revise the 

sentence in lines 35 to 37 on page 2-83 as follows: “The rehabilitation and mothballing activities 

are specified to meet the Secretary of Interior’s Standards for Rehabilitation and construction 

activity, which began is expected to begin in 2012, was completed in May 2013.” 

Response: The NRC staff updated Section 2.2.10.2 of the SEIS to include the information in 

the comment.

A.2.11 Human Health (HH)

Comment: 2-66-HH; RADIATION INTERACTING WITH OZONE ENHANCES CANCER 

RISKS From Mc Donnell, M.D. Health Effects Research Laboratory EPA Testimony, April 9, 

1987, to U.S. Senate

 OZONE WORKS SYNERGISTICALLY WITH RADIATION TO ENHANCE 

THE CANCER-CAUSING EFFECTS OF RADIATION.

Radiation, the most potent carcinogen, is routinely released from Limerick Nuclear Plant. 

Radiation is the signature, most dangerous toxic released from nuclear plants. Radiation levels 

released cause more risk of cancer when breathed in with VOCs and NOx.

Comment: 2-67-HH; RADIATION RELEASES TO AIR

 Limerick routinely releases a broad range of radionuclides into the air.

 Radioactive air particulates are not listed in Limerick's Title V Air Permit, even 

though all air pollutants and sources from a major air polluter are supposed to 

be listed.

 Actual data and/or harmful health impacts from Limerick's routine and 

accidental radioactive releases are unknown.

A-83
Appendix A

Radiation Testing and Reporting To NRC Are Deceptive

 Radiation Levels Reported By Exelon For Limerick's Releases To Air Do Not 

Reflect Risks To The Public From All Limerick's Radionuclides Released Into 

Our Air.

 JUST BECAUSE EXELON ISN'T REQUIRED TO REPORT ALL 

RADIONUCLIDES LIMERICK RELEASES INTO OUR AIR, DOESN'T MEAN 

THOSE RADIONUCLIDES DO NOT INCREASE OUR RISK.

Radiation Levels identified by monitoring are only reported for Limerick by Exelon when they are

above an arbitrary background level. Above background reporting is deceptive. Exelon can 

hide actual radiation releases from Limerick and actual risks.

Radiation Background Levels Are Arbitrary, Deceptive, and Clearly Not Protective:

 80 to 100 Millirems Per Year - Natural background BEFORE Chernobyl

 360 Millirems Per Year - AFTER Chernobyl

 620 Millirems Per Year - AFTER Fukushima, Japan

The National Academy of Sciences Says There Is NO SAFE DOSE

March 16, 2011, After Japan's Nuclear Disaster, NRC Legally Sanctioned Increased Radiation

Harm To Regions Like Ours, Routinely Exposed To Nuclear Plant Radiation Releases.

Other Deceptive Unprotrective Tactics In Radiation Reporting

 Exelon, the company with a vested interest in the outcome that has shown it 

can't be trusted, controls all radiation monitoring, testing, and reporting.

 Exelon is allowed to [“]CALCULATE” and “AVERAGE” results.

 The system fails to report on radiation spikes.

Examples From Exelon's 2007 Self-Monitoring Report to NRC

1. Lower Limit Detection (LLD) - ABOVE BACKGROUND IS DECEPTIVE.

Defined as smallest concentration of radioactive material in a sample that would yield a 

net LLD does not mean the actual level detected - Level detected could be far higher

2. Positive Results Were “CALCULATED” - Gamma Spectroscopy

Standard deviations represent variability of measured results for different samples rather 

than single analysis uncertainty.

3. Net Activity - Calculated by subtracting background from sample.

MDC was reported in all cases - but they can claim positive activity was not detected.

Radioactive Air Particulates - Air particulate samples collected weekly in 2007.

 GROSS BETA WAS DETECTED AT ALL LOCATIONS.

Beta Emissions Can Include Strontium-90, Tritium, and Many Other Radionuclides

 GAMMA WAS DETECTED IN ALL SAMPLES

Be-7 Beryllium 7: UNstable (1/2 life 53 days) was detected in all samples

Beta Particles and Gamma Rays Penetrate the Human Body and Environment, Causing 

Biological, Chemical, and/or Physical Damage.

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Appendix A

 Cancer, Leukemia, Heart Failure, Neuromuscular Diseases and Many Other 

Health Effects Can Result From Long-Term Exposures.

 Harmful Health Impacts Can Take Many Years To Develop.

Examples: Harmful Health Impacts To Specific Parts Of The Body

 Thyroid / Ovaries Iodine - 131 Beta / Gamma Emitter

 Liver / Ovaries Cobalt - 60 Beta / Gamma Emitter

 Bone / Ovaries Zinc - 65 Beta / Gamma Emitter

 Muscles / Ovaries Cesium - 137 Beta / Gamma Emitter

 Bones / Teeth Strontium-90 Beta Emitter 29 year

Strontium 90 (SR-90) Attaches To Particulate Matter - Easily Travels With Air SR-90 

Masquerades As Calcium - Absorbs Into Bones and Teeth.

 Some of the highest levels of Strontium-90 were found in the teeth of children

around Limerick Nuclear Power Plant (Tooth Fairy Study)

All GAMMA Radiation Emitters Attack REPRODUCTIVE ORGANS

 Prostate Cancer Increased in Montgomery County 132% Since Limerick 

Nuclear Power Plant Started(Mid 1980s to Mid 1990s)

 Other related cancers also drastically increased above the national average 

since Limerick started operating.

Radiation Can Cause Birth Defects, Mutations, and Miscarriages,

 In 1st and I or Successive Generations After Exposure.

 Infant death and childhood cancer reductions after nuclear plant closings in 

the United States – 2002 Study - Deaths among infants who had lived 

downwind and within 64 km of each plant dropped.

 Infant and Neonatal Mortality In The Area Around Limerick Are Far Higher 

Than State Averages and Higher Than Philadelphia or Reading.

Other radionuclides in testing were claimed by Exelon to be less than the MDC

 BUT Minimum Detectable Concentration (MDC) Is Only An ESTIMATE and 

Only Reported IF Above Background

Comment: 2-68-HH; ACE provided NRC with documented PA Cancer Registry and CDC data 

showing that after Limerick started operating in 1985, that cancer in communities near Limerick 

skyrocketed far higher than the national average, especially in children. ACE also provided 

NRC with researched links between elevated cancer rates and Limerick Nuclear Plant's routine 

radiation releases.

Comment: 2-12-HH; In Section 9.3.1 of your EIS you admit that “during nuclear power plant 

operations, workers and members of the public would face unavoidable exposure to radiation 

and hazardous toxic chemicals.” Despite this fact, NRC has actually suggested in this repugnant 

EIS that all of the environmental harms from Limerick are small. I'm going to repeat, all of the 

environmental harms from Limerick are small and have no measurable impacts.

Comment: 2-31-HH; Not one word appears in Limerick's EIS about the documented cancer 

crisis in communities near Limerick. Nor have the high infant and neonatal mortality issues 

been acknowledged or discussed.

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Appendix A

Comment: 2-34-HH; AMONG THE MOST GLARING OMISSIONS IN NRC'S DRAFT EIS IS 

THE DOCUMENTED COMPELLING EVIDENCE ACE PROVIDED 10-26-11 ON THE LINKS 

BETWEEN OUR CANCER CRISIS AND LIMERICK'S ROUTINE AND ACCIDENTAL 

RADIATION RELEASES SINCE 1985.

 WE SHOWED WHY LIMERICK'S RADIATION RELEASES ARE CLEARLY A 

MAJOR FACTOR IN CANCER RATES FAR HIGHER THAN THE 

NATIONAL, STATE, AND TRICOUNTY AVERAGES, ESPECIALLY IN OUR 

CHILDREN.

 CANCER RATES ARE DOCUMENTED TO HAVE SKYROCKETED FAR 

ABOVE THE NATIONAL, STATE, AND TRI-[COUNTY] AVERAGES IN 

[COMMUNITIES] NEAR LIMERICK, AFTER LIMERICK STARTED 

OPERATING.

 YET, OUR ALARMING CANCER RATES AND HIGH INFANT [MORTALITY]

RATES ARE NOT EVEN MENTIONED IN NRC'S DRAFT EIS. THERE IS 

NOT ONE WORD ABOUT CANCER INCREASES IN COMMUNITIES NEAR 

LIMERICK AFTER LIMERICK STARTED OPERATING AND RELEASING 

RADIATION INTO OUR LIFE-SUPPORT SYSTEMS AND OUR BODIES.

 THIS OMISSION IS UNACCEPTABLE. THE EVIDENCE IS CLEAR. NRC'S 

FINAL DRAFT MUST BE CHANGED TO INCLUDE THE CANCER 

INCREASES. FOR NRC'S CONVENIENCE WE HAVE INCLUDED SOME 

OF THE DETAILS BELOW.

Comment: 2-39-HH; Limerick poisons the river water with radiation, routinely and accidently 

discharging radioactive wastewater containing a broad range of radionuclides, some with long 

half-lives. NRC previously tried to mischaracterize Limerick's discharges as just one 

radionuclide, Tritium, even though Exelon's Radiological Monitoring Records in NRC's own files 

prove the water, sediment, and fish all contain many radionuclides

Comment: 2-40-HH; NRC does no testing. No independent agency ever did long-term 

monitoring for all the radionuclides associated with Limerick operations. But when the National 

Academy of Sciences says there is no safe level of exposure, the kinds and levels are not as 

important as the fact that almost two million people are always exposed to radiation in their 

water from Limerick.

Comment: 2-42-HH; The Consequences Of Additive, Cumulative, and Synergistic, Radioactive 

Discharges From Limerick Nuclear Plant Into The Schuylkill River Since 1985 Are Obviously 

Significant NRC Doesn't Test or Even Take Split Samples. Far More Radionuclides Could be In 

Water And Fish[ ]Than Reported. NRC Simply Reviews Exelon's Unreliable Reports.

Comment: 4-4-HH; One Limerick radionuclide is confirmed in the babies' teeth of our children 

at some of the highest levels in our nation. Additive, cumulative, and synergistic harmful since 

1985 are unknown, but clearly enormous. NRC never did independent testing for each 

radionuclide or toxic chemical in each round of exposure.

Comment: 4-14-HH; In 2005, the National Academy of Sciences, BEIR VII Report said there is 

no safe level. Dr. John Gofman, once head of AEC’s labs raised dire warnings about permitted 

releases from nuclear plants. He published research warning about permitted releases from 

nuclear plants. He estimated 32,000 Americans would die each year from fatal cancers induced 

by allowable radiation releases. Gofman said the entire nuclear power program is based on a 

fraud that there is a permissible dose that wouldn't hurt anyone. And frankly, we're tired of 

hearing NRC people say that.

A-86
Appendix A

We provided NRC with evidence showing communities around Limerick already exacted a high 

public health toll since Limerick started operating. A cancer crisis has been documented by 

Pennsylvania cancer registry statistics and CDC data. Cancer rates skyrocketed far above the 

national average after 1985 when Limerick started releasing radiation into our air, water, soil, 

and people. Links to Limerick are clear. Limerick routinely releases radiation. Radiation 

causes cancer. We have a cancer crisis and one of the largest relays for life anywhere.

The upward trend in childhood cancer rates provides the most tragic link. By the late 1980s, 

childhood cancer rates climbed to 30 percent higher than the national average; higher by 60 

percent in the early 1990s and a shock 92.5 percent higher than the national average in the late 

1990s. Infant and neonatal mortality rates are far higher than the state average and even 

higher than Philadelphia and Redding. Studies provide a link.

When nuclear plants open, infant mortality rates go up. When they close, rates go down. 

Autism rose a whopping 310 percent from 1990 to 2000. Learning disabilities increased by 94 

percent, a rate double the state increase. Strontium-90 radiation is an undeniable link. Limerick 

releases strontium-90. It's in our air, water, and soil. Strontium-90 is also documented in the 

babies' teeth of our children at some of the highest levels in the nation. NRC still shamefully 

tries to blame decades old bomb testing far from our region. It's ridiculous.

Many cancers rose dramatically by the late 1990s. Examples include thyroid cancer, 128 

percent increase; multiple myeloma, 91 percent increase; breast cancer, 61 percent increase, 

higher than the national average in every age group and it is 51 percent higher in women 30 to 

44. There's a 48 percent increase in leukemia, almost double the state average Limerick 

nuclear plant is clearly a major factor in the tragic and costly health crisis around it with children 

the most profoundly impacted victims. Exposure to Limerick's radiation is an unavoidable and 

intolerable injustice. We can't see it, smell, taste, or feel it, but it's everywhere. We can't avoid 

it.

As long as Limerick nuclear plant continues to operate, radiation and other dangerous toxics will 

be released into our air and water and more people will suffer needlessly. We have lost 

patience with NRC's lies, cover ups and negligence. NRC should close Limerick now to protect 

public health. It's time to stop unnecessary exposures and associated suffering and healthcare 

costs due to Limerick's operations.

Comment: 5-2-HH; Hollow evacuation plans, lack of meaningful regulation, perfunctory public 

inclusion, and NRC's willful blindness to the consequences of our routine radiation exposure, 

increased public risk.

Comment: 5-7-HH; Avoidable diseases, cancers and other illnesses in this region are much 

higher than the national average and are linked to Limerick's radiation. The cost for one sixmonth-old child treated for just two years who has cancer is over $2 million.

Comment: 2-64-HH; Synergistic, Additive, and Cumulative Harmful Health Impacts From 

Limerick's Air Pollution Are Unknown, But Clearly Unprecedented, When They Include:

1. A Broad Range of Radionuclides

2. Massive Emissions of Many Dangerous Cooling Towers Toxics.... 

Comment: 8-2-HH; So I have so much that I could talk about and what I really want to put at 

the last part of this, that I didn't get into is basically we have a way of quantifying and qualifying 

the risk now to humans and that is genetic testing. We can actually test the genes and do 

studies now of the people that live in the region of a nuclear power plant. We know that nuclear 

energy or nuclear problems occur in damaged chromosomes. We now have the technology 

and medicine and research to actually look and take blood from people that live in a region of 

A-87
Appendix A

nuclear power and actually demonstrate what is going on inside that person's body, things that 

just because we don't see it on the outside of a person, does not mean that there is not 

chromosomal damage already that we can quantify, qualify in their blood.

Why there has not been any research ongoing about that, I don't know. The good old Tooth 

Fairy test of strontium-90, that sort of has been pushed to aside, but we have had the 

technology to actually do research on genetic changes in people's blood from radiation and let's 

look at the results of that. Let's have tests done about and let's see what's going on and we can 

actually really take note of this and go from there about what damage is really occurring and 

that's not from a meltdown. We know that happens. We know there's breakage of 

chromosomes and such. But what really -- we can look at the silent damage that's occurring 

from just the normal use of a power plant.

Comment: 23-7-HH; Throughout the supplemental, we are told that there is no new 

information to change the past EIS and decisions. The fact is there are lots of new pieces of 

information. One of the new pieces Donna mentioned is the National Academy's National 

Research Council BEIR[ ]VII No. Report which says there's no safe level of exposure to 

radiation. This is new since LGS started up. It is not considered here. I couldn't find anything 

about it in the document that I was given.

Comment: 23-35-HH; [P.] 4-21, Human Health, Did we know about baby teeth and strontium 

90 when the plant began? Have we learned nothing about RAM and cancer and other illnesses 

in 40 years? Come on. NRC relied on Exelon for info on health? Can you see cancer on a site 

visit? Did you ignore ACE in scoping? What info, not paid for by Exelon or other corporate 

interest did NRC evaluate for this?? I see none or too few in your bibliographies.

Comment: 23-36-HH; Page 4-22 line 27, normal operations is uprating “normal”? All this 

about radiological impacts of so call normal operation (Define the term “normal”) must be 

prefaced with the National Academy finding that there is no safe level of exposure to ionizing 

radiation. The rest is fluff

Comment: 25-2-HH; The recent discoveries concerning epigenetics put the past predictions of 

health effects on future generations into grave doubt. The predictions based on Mendel's 

observations do not nor were meant to predict neot[e]ny due to genes being switched on or off 

by uncontrolled radiation.

Comment: 26-3-HH; Don’t be fooled! 'Permissible' doesn't mean safe. The National Academy 

of Sciences BEIR VII report (2005) said there is “NO SAFE DOSE[.”]

Dr. John Gofman, former Atomic Energy Commission chief, raised dire warnings about 

permitted radiation releases from nuclear plants, publishing research showing an estimated 

32,000 Americans would die each year from fatal cancers induced by “allowable” radiation 

releases. Gofman said, “The entire nuclear power program is based on a fraud, that there is a 

permissible dose that wouldn't hurt anyone.” 

Cancers skyrocketed after 1985, when Limerick started releasing radiation into us and our 

environment. Shocking cancer rates are documented far higher than the national average, 

especially in children, with data from the PA Cancer Registry and CDC website. ACE cancer 

mapping is alarming. Our relay for life is one of the largest anywhere. Limerick's radiation 

releases are obviously a major factor.

Response: The NRC’s mission is to protect the public health and safety and the environment 

from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC’s 

regulatory limits for radiological protection are set to protect workers and the public from the 

harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. 

A-88
Appendix A

Radiation standards reflect extensive scientific study by national and international organizations. 

The NRC actively participates and monitors the work of these organizations to keep current on 

the latest trends in radiation protection.

Although radiation can cause cancers at high doses, currently there are no data to 

unequivocally establish the occurrence of cancer following exposures to low doses, below about 

10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of 

radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is 

higher for larger radiation exposures. Therefore, a linear, no-threshold dose response 

relationship is used to describe the relationship between radiation dose and detriments such as 

cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to 

result in an incremental increase in health risk. This theory is accepted by the NRC as a 

conservative model for estimating health risks from radiation exposure, recognizing that the 

model probably overestimates those risks. Based on this theory, the NRC conservatively 

establishes limits for radioactive effluents and radiation exposures for workers and members of 

the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC 

(10 CFR Part 20, “Standards for Protection Against Radiation”), the NRC has imposed 

additional more-restrictive dose constraints on nuclear power reactors. Nuclear power reactors, 

including LGS, have license conditions that limit the total annual whole body dose to a member 

of the public outside the facility to 25 mrem (0.25 mSv). In addition, there are other license 

conditions that limit the dose to a member of the public from radioactive material in gaseous 

effluents to an annual dose of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, 

a dose limit of 3 mrem (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ.

All nuclear plants were licensed by the NRC with the expectation that they would generate, 

store, and release radioactive material to both the air and water during normal operation. To 

ensure that nuclear power plants are operated safely, the NRC licenses the plants to operate, 

licenses the plant operators, and establishes license conditions for the safe operation of each 

plant. The NRC provides continuous oversight of each plant under the NRC’s inspection and 

enforcement programs. The NRC’s ROP integrates the NRC’s inspection, assessment, and 

enforcement programs. The operating reactor assessment program evaluates the overall safety 

performance of operating commercial nuclear reactors and communicates those results to 

applicant management, members of the public, and other government agencies. The 

assessment program collects information from inspections and performance indicators in order 

to enable the NRC to arrive at objective conclusions about an applicant’s safety performance. 

Based on this assessment information, the NRC determines the appropriate level of agency 

response. The NRC conducts followup actions, as applicable, to ensure that the corrective 

actions designed to address performance weaknesses were effective. While the NRC 

maintains regulatory oversight of LGS, it is the responsibility of LGS’s management to ensure 

that plant operation complies with NRC requirements at all times.

Chapter 4 of this SEIS discusses the REMP that LGS uses for environmental monitoring. The 

purpose of the LGS REMP is to evaluate the radiological impact that operation may have on the 

environment. The program is designed to highlight and look at specific consumption pathways 

for local inhabitants and special interest groups. The LGS REMP is made up of three 

categories based on the exposure pathways to the public. They are as follows: atmospheric, 

aquatic, and ambient gamma radiation. The atmospheric samples taken around LGS are 

airborne particulate, airborne iodine, milk, and broad-leaved vegetation. Sampling for the LGS 

REMP program is performed as specified in Appendix I to 10 CFR Part 50, “Domestic licensing 

of production and utilization facilities.” The NRC routinely inspects LGS’s radioactive effluent 

monitoring and environmental monitoring programs for compliance with NRC regulations. In 

addition, LGS cooperates with the PDEP Bureau of Radiation Protection to share environmental 

A-89
Appendix A

samples and data. In Chapter 4 of this final SEIS, the NRC staff reviewed LGS’s radioactive 

effluent and environmental monitoring programs to determine the potential impacts of renewing 

the LGS operating licenses. The NRC staff concluded that the impacts to human health during 

the license renewal term would be SMALL.

The amount of radioactive material released from nuclear power facilities is controlled, 

measured, monitored, and known to be very small. The radiation dose received by members of 

the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 

mrem in a year) that cancers attributed to radiation have not been observed and would not be 

expected. To put this in perspective, each person in this country receives a total annual dose of 

about 620 mrem (6.2 mSv). About half of the total annual average radiation exposure comes 

from natural sources. The other half is mostly from medical procedures. The average annual 

radiation exposure from natural sources is about 310 mrem (3.1 mSv). Radon and thoron 

gases account for two-thirds of this exposure, while cosmic, terrestrial, and radiation from 

potassium-40 that exists naturally in our bodies account for the remainder. No adverse health 

effects have been discerned from exposure to natural radiation. Manmade sources of radiation 

from medical, commercial, and industrial (which includes nuclear power plants) activities 

contribute about another 310 mrem (3.1 mSv) to our annual radiation exposure. As stated 

above, this dose is mostly from medical procedures. One of the largest of these sources of 

exposure is computerized tomography (CT) scans, which account for about 150 mrem (1.5 

mSv) of the average annual exposure. Other medical procedures together account for about 

another 150 mrem (1.5 mSv) each year. Because of the increased use of medical imaging 

procedures in health care, the average radiation dose has shown a significant increase in the 

last two decades. In addition, some consumer products, such as tobacco, fertilizer, welding 

rods, exit signs, luminous watch dials, and smoke detectors, contribute about another 10 mrem 

(0.1 mSv) to our annual radiation exposure. Although there is distinction between natural and 

manmade radiation, there is no difference in the potential health impacts.

A number of studies have been performed to examine the health effects around nuclear power 

facilities. The following is a list of some of the studies that have been conducted:

 In 1990, at the request of Congress, the NCI conducted a study of cancer 

mortality rates around 52 nuclear power plants and 10 other nuclear facilities. 

The study covered the period from 1950 to 1984 and evaluated the change in 

mortality rates before and during facility operations. The study concluded 

there was no evidence that nuclear facilities may be causally linked to excess 

deaths from leukemia or from other cancers in populations living nearby. 

Note: On April 7, 2010, the NRC contracted with the NAS to perform a stateof-the-art study on cancer risk for populations surrounding nuclear power 

facilities (ADAMS Accession No. ML100970142). The NAS has a broad 

range of medical and scientific experts who can provide the best available 

analysis of the complex issues involved in discussing cancer risk and 

commercial nuclear power plants. The NAS study will update the 1990 U.S. 

National Institutes of Health NCI report, “Cancer in Populations Living Near 

Nuclear Facilities.” The study’s objectives are to: 1) evaluate whether cancer 

risk is different for populations living near nuclear power facilities, 2) include 

cancer occurrence, 3) develop an approach to assess cancer risk in 

geographic areas that are smaller than the county level, and 4) evaluate the 

study results in the context of offsite doses from normal reactor operations. 

The initial pilot phase of the study began in the summer of 2010 and is 

currently examining the cacer risks around seven nuclear sites using two 

types of epidemiological studies. One type will examine multiple cancer 

A-90
Appendix A

types in populations of all ages living near the nuclear sites and the other will 

be a record-linkage-based case-control study of cancers in children living 

near the nuclear sites.

 Investigators from the University of Pittsburgh found no link between radiation 

released during the 1979 accident at the Three Mile Island Nuclear Station 

and cancer deaths among nearby residents. This study followed more than 

32,000 people who lived within 5 mi (8 km) of the facility at the time of the 

accident.

 In January 2001, the Connecticut Academy of Sciences and Engineering 

issued a report on a study around the Haddam Neck Nuclear Power Plant, in 

Connecticut, and concluded that exposures to radionuclides were so low as 

to be negligible and found no meaningful associations to the cancers studied.

 In 2001, the American Cancer Society concluded that, although reports about 

cancer clusters in some communities have raised public concern, studies 

show that clusters do not occur more often near nuclear plants than they do 

by chance elsewhere in the population. Likewise, there is no evidence linking 

the isotope strontium-90 with increases in breast cancer, prostate cancer, or 

childhood cancer rates.

 In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims 

that there are striking increases in cancer rates in southeastern Florida 

counties caused by increased radiation exposures from nuclear power plants. 

However, using the same data to reconstruct the calculations on which the 

claims were based, Florida officials did not identify unusually high rates of 

cancers in these counties compared with the rest of the State of Florida and 

the Nation.

 In 2000, the Illinois Public Health Department compared childhood cancer 

statistics for counties with nuclear power plants to similar counties without 

nuclear plants and found no statistically significant difference.

In summary, there are no studies to date that are accepted by the Nation’s leading scientific 

authorities that indicate a causative relationship between radiation dose from nuclear power 

facilities and cancer in the general public.

The NRC staff addressed human health impacts from radioactive material from LGS during the 

license renewal term in Chapter 4 of the final SEIS and concluded that the impacts would be 

SMALL.

These comments do not provide any new and significant information; therefore, no changes 

were made to this SEIS in response to these comments.

Comment: 5-19-HH; NRC has repeatedly raised background radiation levels, which raise risks 

for the public here at Limerick: 

The “background level” number that NRC assigns is a trigger point: nuclear plants must report 

levels above “background” on-site, as a spike indicates a serious problem. Our concern is that 

NRC's current number is so high that Exelon can claim Limerick's “routine operations and 

radiation releases” which may not reach the trigger point, comply with NRC regulations, but 

which, in reality, greatly increasing Limerick's adverse impact on public health, safety, and the 

environment. This is the history of NRC's assigned radiation level increases:

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Appendix A

 Pre-1964: natural background radiation: 60-80 Mill[i]rems per year

 Post-1964: NRC raised the level to 80-100 Mill[i]rems per year. A noted 

above, the significance of this is that it is a trigger point: when radiation 

readings at nuclear plants spiked above that NRC-set trigger point, 

notification of the NRC was required,

 Post-Chernobyl (1986): NRC raised the level to 360 Millirems per year

 Post-Fukushima (2011): NRC raised the level to 620 Millirems per year

 However, the 2005 NAS’s BEIR VII Study, funded by the EPA, revealed that 

the smallest radiation dose could increase human health risks: there is no 

safe dose.

Comment: 25-4-HH; Back when I was a child, the radiation background was reported as 60 

millirems per year. The background is now reported by the DoE and EPA as 600 to 700 

millirems per year. Long ago, the background was 600 or 700 millirems per year. When the 

background radiation fell to 600 or 700 millirems per year, life on this Earth proliferated with a 

profusion of species and animals as never before. Evolution ran rampant. We are faced with a 

background dose that may make mankind an endangered species. The time to stop dumping 

radiation into the air, water and soil is past. Stop now!

Response: It is estimated that each person in this country receives a total annual dose of 

about 620 mrem (6.2 mSv). This information on background radiation was obtained from the 

National Council on Radiation Protection and Measurements (NCRP), Report 160. The NCRP 

reported that about half of the total annual average radiation exposure comes from natural 

sources. The other half is mostly from medical procedures. The average annual radiation 

exposure from natural sources is about 310 mrem (3.1 mSv). Radon and thoron gases account 

for two-thirds of this exposure, while cosmic, terrestrial, and radiation from potassium-40 

naturally in our bodies account for the remainder. No adverse health effects have been 

discerned from exposure to natural radiation. Manmade sources of radiation from medical, 

commercial, and industrial (which includes nuclear power plants) activities contribute about 

another 310 mrem (3.1 mSv) to our annual radiation exposure. As stated above, this dose is 

mostly from medical procedures. One of the largest of these sources of exposure is CT scans, 

which account for about 150 mrem (1.5 mSv) of the average annual exposure. Other medical 

procedures together account for about another 150 mrem (1.5 mSv) each year. Because of the 

increased use of medical imaging procedures in health care, the average radiation dose has 

shown a significant increase in the last two decades. In addition, some consumer products, 

such as tobacco, fertilizer, welding rods, exit signs, luminous watch dials, and smoke detectors, 

contribute about another 10 mrem (0.1 mSv) to our annual radiation exposure. Although there 

is distinction between natural and manmade radiation, there is no difference in the potential 

health impacts. Additional information about radiation can be viewed on the NRC’s website 

using the following link: www.nrc.gov/about-nrc/radiation.html.

These comments do not provide any new and significant information; therefore, no changes 

were made to this SEIS.

Comment: 2-65-HH; Cooling Towers Host Pathogens 

Research Shows Health Threats From Cooling Towers Include Pathogens

Cooling Towers Spray Infectious Pathogens Into Our Air. These Pathogens Can Cause 

Disease in Humans, Even Legionella

A-92
Appendix A

• Section 4.9.3 on Microbiological Organisms of NRC'S DRAFT EIS States 

That Limerick Cooling Towers Release Microbiological Organisms, 

INCLUDING: 

SALMONELLA[,] LEGIONELLA[,] AND PSEUDOMONAS AERUGINOSA[,]

which can cause serious and sometimes fatal infections in immune 

compromised individuals.

• THESE TOXINS ARE DOCUMENTED TO BE HARMFUL TO HUMANS AND 

ANIMALS.

• Exelon requested PA DEP to provide comments or confirm Exelon's 

conclusion about a low likelihood of risk from pathogens released from 

Limerick contribute to related health effects.

• PA DEP would not make any conclusions regarding the effect on public 

health.

• NRC says optimal growing temperature is 99 degrees F, but Limerick's 

cooling tower waters are allowed to be up to 110 degrees.

NRC HAS CONCLUDED THAT IMPACTS ON PUBLIC HEALTH FROM THESE

ORGANISMS WOULD BE “SMALL[,”] BUT THERE NO PROOF OF THAT, WHETHER IN

RELEASES TO AIR OR WATER.

• 44 MILLION GALLONS Of Cooling Tower Steam Are Released Into Our Air 

Every Day.

• 14.2 MILLION GALLONS Of Limerick's Wastewater Are Released Into The 

River Every Day.

• There Are NO Measurements By NRC Or Exelon For The Pathogens In The 

Air Or River Releases From Limerick's Cooling Towers.

• Limerick's Cooling Tower Waste Water Is Allowed To Be Heated Up To 110 

Degrees.

o NRC HAS NO ACCURATE IDEA OF HOW THESE PATHOGENS ARE 

IMPACTING[ ]THE POPULATION OVER TIME.

o NRC MUST CHANGE ITS CONCLUSION THAT IMPACTS WOULD BE 

“SMALL” TO IMPACTS ARE “UNKNOWN[.”]

Comment: 3-4-HH; When water is hotter than 95 degrees Fahrenheit it fosters the growth of 

thermophilic microbial organisms. These organisms include legionella, yes, legionella, and 

salmonella among others. These pathogens thrive in warm water. They can also cause fatal 

infections and pneumonia in compromised individuals and the elderly. This hot water needs to 

be cooled down more than it can be at the present time.

Comment: 15-13-HH; Another concern: everyday, 14.2 million gallons of very hot water leave 

the cooling towers loaded with dissolved solids and radiation. This hot brew goes down pipe 

001 to the diffuser and into the Schuylkill River. It enters the river at 110 F, a much higher 

temperature than the Schuylkill River limit of 87 F. When water is hotter than 95 F, it fosters the 

growth of thermophilic microbic organisms. These organisms include Legionella and

Salmonella, among others. These pathogens thrive in warm water. They can also cause fatal 

infections and pneumonia in compromised individuals and the elderly. This hot water needs to 

be cooled down more than it can be at the present time.

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Exelon asked the Pa. DEP to provide comments about these pathogenic organisms in the river. 

Exelon wanted the Pa. DEP to confirm Exelon's conclusions that no harm would come from the 

pathogens during an extended period of operation with these higher temperatures.

The Pa. DEP, to its credit, said it had no data on these organisms in the river to support 

Exelon's claims. The Pa. DEP was unable to reach any conclusions as to the possible health 

effects, thus not supporting Exelon's contentions

Response: The NRC acknowledges that there is a potential impact from thermophilic 

organisms associated with the discharge of thermally heated water and specifically reviews this 

issue as part of the license renewal process. In Section 4.9.3 of the LGS SEIS, the NRC staff

reviewed the potential impacts from thermophilic microorganisms associated with thermally 

heated water from LGS discharged into the Schuylkill River.

As discussed in Section 4.9.3 of the SEIS, the research data show that thermophilic 

microorganisms generally occur at temperatures of 77 °F to 176 °F (25 °C to 80 °C) with an 

optimal growth temperature range of 122 °F to 150 °F (50 °C to 66 °C), and minimum and 

maximum temperature tolerances of 68 °F (20 °C) and 158 °F (70 °C), respectively. However, 

thermal preferences and tolerances vary across bacterial groups. For examples, pathogenic 

thermophilic microbiological organisms of concern (i.e., Salmonella spp. and Shigella spp., the 

Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living amoebae Naegleria 

spp., and Legionella spp.) have optimal growing temperatures of approximately 99 °F (37 °C). 

The NRC staff reviewed the LGS NPDES permit issued by the State of Pennsylvania (permit no. 

PA0051926) which requires the temperature in the thermal discharge to be monitored at least 

once weekly for compliance with an instantaneous maximum limit of 110 °F (43.3 °C) for the 

protection of human health. Although thermophilic microbiological organisms of concern during 

nuclear reactor operation could grow at that stated instantaneous maximum temperature limit, 

several years of LGS’s Discharge Monitoring Report data were reviewed by the NRC staff, 

which showed that maximum summer discharge temperatures ranged from 90 °F to 95 °F 

(32.2 °C to 35.0 °C). These temperatures are below the optimal growing temperature of 

approximately 99 °F (37 °C); therefore, the NRC staff concluded that the ambient river conditions 

are not likely to support the proliferation of the pathogenic organisms of concern.

In addition, salmonella organisms are associated with poor sanitation and while they can survive 

in water, they do not multiply in water. LGS discharges its sanitary sewage to the local publicly 

owned treatment works, which further reduces the potential for the facility’s discharged water to 

introduce pathogenic microorganisms that could present a threat to recreational users of the 

Schuylkill River.

NRC staff characterized potential impacts on human health as SMALL by applying the 

definitions of the SMALL, MODERATE, and LARGE impact levels described in 10 CFR Part 51. 

These comments do not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

Comment: 7-8-HH; And manganese, one of the toxics can lead to permanent brain damage 

from showering.

Comment: 7-10-HH; How can we take care of our health when we are forced to drink, bathe in, 

and breathe in toxic chemicals from Limerick operations every day? Too many people are really 

sick, have thyroid problems and are dying of dreaded disease like cancer.

Look at the huge cancer rallies in our community. Why should we risk our lives and fear 15 

meltdown, more sickness, cancer from Limerick's electricity when safer energy is available. The 

problem is NRC appears to be more of a salesman than a policeman.

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Appendix A

Nuclear power already destroyed parts of the world. This dangerous dinosaur technology must 

make way for safe, clean energy alternatives that won’t destroy our water supplies and our 

health. Thank you

Response: The NRC staff considered the potential impacts on human health and the 

environment from the industrial use of chemicals at LGS during the license renewal term.

LGS must monitor its chemical and radioactive discharges into the Schuylkill River in order to 

comply with NRC’s radiological limits and the Commonwealth of Pennsylvania’s chemical limits. 

Discharges of wastewater containing chemicals are subject to discharge authorizations under 

the NPDES implemented by the Commonwealthof Pennsylvania. LGS must comply with these 

regulatory requirements. As part of its environmental review for the license renewal of LGS, the 

NRC staff reviewed LGS’s radioactive and nonradioactive waste management programs. 

Details of LGS’s radiological and nonradiological effluent monitoring programs and the NRC’s 

evaluation of the two programs are contained in Chapters 2 and 4 of this final SEIS.

In addition, nonradioactive groundwater and soil contamination at LGS is subject to 

characterization and cleanup under EPA- and State-regulated remediation and monitoring 

programs. As discussed for discharges to the river, LGS must comply with these regulatory 

requirements.

The NRC staff discussed LGS’s radiological and nonradiological waste programs and their 

potential impacts in Chapters 2 and 4 of this final SEIS and concluded that the impacts were 

SMALL.

This comment does not provide any new and significant information; therefore, no changes 

weremade to the SEIS. 

Comment: 32-21-HH; Because the type of dosimeter used to measure environmental radiation 

doses may be changed from time to time, revise the sentence in lines 14 to 16 on page 4-23 as 

follows: “The ambient gamma radiation pathway measures direct exposure from environmental 

radiation doses using thermoluminescent dosimeters, which are typically thermoluminescent

dosimeters.” 

Response: The NRC staff agree with this comment and the SEIS has been updated to reflect 

this information

A.2.12 Land Use (LU)

Comment: 23-28-LU; Page 2-24 line 35, Conrail rail line. Page 2-24 line 33, “all activities on 

the LGS site are under the control of Exelon.” Exactly what does that mean? Is Conrail under 

the control of Exelon? Please be specific.

New since LNG started, changes to Conrail that very well might impact us all. See attached 

article about Paulsboro and Conrail and liability. When LNG began Conrail was owned by one 

entity and since then has changed hands. I think it is a common carrier but it may be that users 

contract between themselves and Conrail or CSX or NS. All of this is important, mixed with 

Exelon stating on p. 2-24 line 33 that it controls all activities. NRC must stop the approval of the 

GEIS and all relicensing until the public is informed about the railroad and who is liable for what 

at this site.

Comment: 23-33-LU; P. 4-1, there is no mention of issues related to the rail line (thru the site) 

which I view as very critical for the public to understand in detail. What is Exelon[’]s relationship 

with the railroad(s)?

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Appendix A

Response: For security reasons, Exelon controls and protects all onsite activities involving 

commercial reactor operations and the storage of nuclear material at the LGS site. The Conrail 

line that passes through the LGS site is located within a right-of-way on Exelon property. 

Maintenance of the rail line is the responsibility of Conrail and is outside the control of Exelon. 

Conrail is a separate corporation not under the control of Exelon Corporation or Exelon 

Generation Company, LLC. These comments did not provide any new and significant 

information; therefore, no changes were made to the SEIS.

Comment: 23-34-LU; [P.] 4-1, tables refer to GEIS so citizens have a hard time getting needed 

info.

Response: The comment asserts that the NRC purposely makes it difficult to access needed 

information (e.g., GEIS). The NRC has a longstanding practice of conducting its regulatory 

responsibilities in an open and transparent manner. In that way, the NRC keeps the public 

informed of the agency’s regulatory, licensing, and oversight activities. The NRC views nuclear 

regulation as the public’s business and, as such, believes it should be transacted as openly and 

candidly as possible to maintain and enhance the public’s confidence. Ensuring appropriate 

openness explicitly recognizes that the public must be informed about, and have a reasonable 

opportunity to participate meaningfully in, the NRC’s regulatory processes. This means that 

public stakeholders must have access to clear and understandable information about the NRC’s 

role, processes, activities, and decisionmaking. The NRC encourages members of the public to 

participate in the license renewal review process and contribute ideas and expertise so that the 

NRC can make regulatory decisions with the benefit of information from a wide range of 

stakeholders.

Copies of the Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(NUREG-1437) (GEIS) are available upon request. The GEIS is also available on line at 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/. Local libraries and 

reference librarians can provide assistance in accessing this document. The GEIS can also be 

accessed by using the ADAMS Public Electronic Reading Room at http://www.nrc.gov/readingrm/adams.html/ under ADAMS accession numbers ML13106A241, ML13103A242, and 

ML13106A244. This comment does not provide any new and significant information; therefore, 

no changes were made to this SEIS.

A.2.13 License Renewal & NEPA Process (LR)

Comment: 2-1-LR; ACE objects to NRC proceeding on this EIS at this time with important 

questions and issues not yet addressed or answered. There is no need when Limerick's current 

licenses do not expire until 2024 and 2029.

Comment: 2-10-LR; This premature and incomplete EIS is apathetic example of a lack of 

courage and integrity at the NRC. You have abandoned and violated your own mission to 

protect public health and safety. You have betrayed this entire region once again. NRC's 

failure to protect our environment and residents is irrefutable evidence that you no longer have a 

moral compass. Your rush to rubber stamp Limerick's EIS and license renewals is a cowardly 

betrayal of every man, woman, and child in this community, as well as future generations that 

will unquestionably be harmed by 20 additional years of operation at Limerick. 

Comment: 3-5-LR; I think it would be better to have more independent study done now than 

solve any unknowns before racing to relicense Limerick. We have 11 years remaining in the 

present license period to properly work out these problems. We should not just skip over them 

or wait until a serious accident happens. The job of the NRC is to promote public safety, not the 

nuclear industry.

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Comment: 8-1-LR; Now let me see, I'm wondering why do we have to have a relicensing, right 

now, for 20 more years for Exelon? I don't get it. If it's already licensed now to like 2017 or 

2024, 2029, why are we in the world have to do this now unless we're waiting for something bad 

to happen? We better get the license on board first because if something really bad happens, 

well, maybe we'll stop to fix it. We can't get shut down if we already have the license. I don't 

know. I was a naval officer one time, but I'm not someone who knows a lot about systems.

So what's the rush of getting the license right now? Well, I don't know.

Comment: 18-4-LR; Why does the NRC seem to be in such a mad rush to relicense a[ 

]nuclear facility when its license doesn't even expire until 2024? Why? Why? Why?

Comment: 13-6-LR; That's why -- that's precisely why Exelon or any of these other utilities can 

make application as early as 20 years. That's the rule.

I mean what kind of Environmental Impact Statement is worth anything if it's fixed 20 years 

before the federal action is even required?

This gives you the basic plan and blueprint for a bias that this Agency and this industry have 

concocted to expedite these license extensions prior to what they view as a lot of unwelcome 

and unnecessary questions about renewable wind, solar, energy efficiency, and whole host of 

21st century energy policy chances that are going to happen, that are happening.

Comment: 20-2-LR; But environmental impacts, crucial as they are, are secondary questions. 

I really wish would address why this licensing procedure is happening so early. Unit 2's present 

license, as Mr. Moyer explained, isn't even up for 16 years. Only God knows what will happen 

tomorrow, let alone 16 years from now. We will be learning that only as we go along.

Comment: 20-3-LR; Much will happen in the next 12 years that no one can foresee. To 

proceeding with licensing now makes no sense. It almost seems as though the NRC is saying 

to us our mind is made up. Do not confuse us with any present or future facts, circumstances, 

insights, developments, or technologies. Someone must be profiting by this reckless rush to 

relicense, but the public is being harmed by the haste. You, Nuclear Regulatory Commission, 

have the power to change this. Please, slow the process down.

Comment: 27-4-LR; We are wondering why it[’]s so important for Limerick power plant to 

renew their license so soon.

Comment: 30-1-LR; “The NRC makes the decision to grant or deny license renewal based on 

whether the applicant has demonstrated that the environmental and safety requirements in the 

agency's regulations can be met during the period of extended operation.” (page 1-1, lines 12-

14)

The existing licenses for Units 1 and 2 of the Limerick Generating Station (LGS) expire on 

October 26, 2024, and June 22, 2029, respectively. The current licenses for LGS do not expire 

for another 11 (Unit 1) and 16 years (Unit 2). Renewing these licenses for another 20 years 

would result in the licenses expiring in 2044 (Unit 1) and 2049 (Unit 2). Has the NRC defined 

when, in the course of an applicant's current license, that applicant can or should apply for a 

license extension? If an applicant applies for a license extension early, as in this case more 

than a decade before expiration of current licenses, then the NEPA analysis which supports the 

federal action has to be projected further out into the future and is therefore less certain and can 

be relied on with less confidence in the government's decision. For example, as noted below, 

Section 3 of the GElS Supplement concerns the environmental impacts of refurbishment, 

including major refurbishment activities in a boiling water reactor (BWR) such as replacement of 

recirculation piping and pressurized water reactor steam generators. The GElS Supplement for 

LGS did not include an evaluation of the environmental impacts of nuclear power plant 

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refurbishment because “Exelon did not identify the need to undertake any major refurbishment 

or replacement actions” (page 3-2, lines 10-11). However after a further decade of operation 

the need to undertake major refurbishment could arise. In another example, Section 4 of the 

GElS Supplement for LGS discusses the fluctuations in measurements of tritium in groundwater

at monitoring wells since 2006 (page 4-6, lines 27-33). As the LGS units age over another 

decade, tritium levels in groundwater could fluctuate further, necessitating additional 

environmental review under NEPA. 

NRDC recommends that, in order to reduce uncertainty, the federal government defer a final

decision on license extension for LGS until a time period closer to the expiration of current

licenses for these two reactors, for example within two years of expiration of current licenses.

Reinforcing this position, the GElS Supplement asserts that: “The NRC has established a 

license renewal process that can be completed in a reasonable period of time with clear 

requirements to ensure safe plant operation for up to an additional 20 years of plant life” (page 

1-3, lines 20- 22). If the license renewal process can be completed in a reasonable time, then 

renewing licenses for LGS so far in advance is unwarranted, and forces NRC's analysis in 

support of the NEPA process to be significantly weakened, as the NRC must thereby predict 

events farther in the future in support of government decision making.

Response: According to NRC regulations, 10 CFR Part 54, “Requirements for renewal of 

operating licenses for nuclear power plants,” a nuclear power plant licensee may apply to the 

NRC to renew a license as early as 20 years before expiration of the current license. The NRC 

determined that 20 years of operating experience is sufficient to assess aging and 

environmental issues at the site. Additionally, 20 years is a reasonable lead period because, if 

the NRC denies the license renewal application, it takes about 10 years to design and construct 

major new generating facilities, and long lead times are required by energy-planning 

decisionmakers.

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS. 

Comment: 23-32-LR; There are no definitions, what does “refurbishment” mean?

Comment: 30-2-LR; GElS Supplement Section 3 “ENVIRONMENTAL IMPACTS OF 

REFURBISHMENT” does not, in fact, analyze the environmental impacts of refurbishment

because: “Exelon did not identify the need to undertake any major refurbishment or 

replacement actions associated with license renewal to support the continued operation of LGS 

beyond the end of the existing operating license” (page 3-2, lines 10-12). NRDC requests that 

the NRC itself determine if Exelon's statement is reasonable in a final GElS Supplement. A 

steam generator replacement will likely be needed to support operation in the extended license 

period, probably in conjunction with the planned, but now deferred, power uprate for Limerick. 

The GElS Supplement is deficient in this regard, as major refurbishment activities have occurred 

at numerous reactors in the course of their operating life, and may or may not occur at LGS in 

the future. Given the length of time to the end of extended licenses for LGS Unit 1 and Unit 2, 

31 and 36 years, respectively, how much certainty can the NRC have that major refurbishment 

will not be required after decades of continued operation? Given the uncertainty in projecting 

aging effects so far forward in time, a conservative and robust approach to NEPA requirements 

in support of the government's decision should include an analysis of the environmental impacts 

of refurbishment at LGS.

Response: Refurbishment activities are physical activities or changes to the facility or site that 

are undertaken to prepare a nuclear power facility for continued operation. These activities, 

which occur as needed, include enhanced inspection, surveillance, testing, maintenance and 

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Appendix A

repair, replacement, and modification of plant systems, structures, and components. For some 

facilities, replacement of large components of the nuclear steam supply system (e.g., steam 

generator or pressurizer) may be necessary; repair or replacement of pumps, pipes, control rod 

systems, electronic circuitry, electrical and plumbing systems, or motors may be necessary as 

well. 

Not many facilities are expected to need refurbishment activities in connection with license 

renewal. Many License renewal applicants anticipate that they will replace components and 

conduct additional inspection activities within the bounds of normal facility component 

replacement and inspection. Refurbishment activities (e.g., steam generator and vessel head 

replacement) have already taken place during the current operating license term at a number of 

nuclear power plants. These activities have been conducted for economic, reliability, or 

efficiency reasons during refueling or maintenance outages under the original operating license. 

In addition, very few applications have identified any refurbishment activities associated with 

license renewal. The NRC acknowledged in the 1996 GEIS that licensees may undertake 

refurbishment activities for reasons of safety, economics, reliability, or efficiency (i.e., not just to 

support license renewal). Few of the applications received to date have identified major facility 

refurbishment activities or modifications necessary to support the continued operation of the 

facility beyond the end of the existing operating license.

As part of the license renewal safety review, the applicant must confirm whether the design 

assumptions made during the plant’s initial licensing about the length of time the plant would be 

operated will continue to be valid throughout the period of extended operation and whether 

aging effects will be adequately managed. The applicant must demonstrate that the effects of 

aging will be managed in such a way that the intended functions of “passive” or “long-lived” 

structures and components (such as the reactor vessel, reactor coolant system, piping, steam 

generators, pressurizer, pump casings, and valves) will be maintained during extended 

operation. For active components (such as motors, diesel generators, cooling fans, batteries, 

relays, and switches), surveillance and maintenance programs will continue throughout the 

period of extended operation.

LGS Units 1 and 2 are General Electric (GE) BWRs producing steam for direct use in the steam 

turbine. Unlike pressurized water reactors (PWRs), BWRs do not need steam generators to 

support power generation. Extended power uprates usually require significant modifications to 

major pieces of nonnuclear equipment such as high-pressure turbines, condensate pumps and 

motors, main generators, or transformers, but no new construction on previously undisturbed 

land is anticipated to occur (Exelon 2011).

If additional aging management activities are needed, the applicant may be required to establish 

new monitoring programs or increase inspections. For instance, applicants would specify 

activities that need to be performed (such as activities related to water chemistry and 

inspections) to prevent and mitigate age-related degradation. These activities increase the 

likelihood that the program is effective in minimizing degradation and that a component is 

replaced if specified thresholds are exceeded.

Plant maintenance activities not associated with license renewal are outside the scope of the 

environmental review for license renewal. The NRC provides continuous oversight of nuclear 

power plants through its ROP to verify that they are being operated and maintained in 

accordance with NRC regulations. This oversight includes having full-time NRC inspectors 

located at the plant and periodic safety inspections conducted by NRC inspectors based in an 

NRC Regional Office. The inspections look at a plant’s compliance with NRC’s regulations, 

which include the following: plant safety (routine and accident scenarios), radiation protection of 

plant workers and members of the public, radioactive effluent releases, radiological 

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environmental monitoring, emergency preparedness, radioactive waste storage and 

transportation, quality assurance, and training. The NRC has full authority to take whatever 

action is necessary to protect public health and safety. 

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS. 

Comment: 30-12-LR; (page 8-3, line 14) “A three-level standard of significance -SMALL,

MODERATE, or LARGE-is used to indicate the intensity of environmental effects for each

alternative undergoing in-depth evaluation.” This vague taxonomy of relative impacts conveys

almost no meaningful information regarding the specific nature and ecological harms of the

impacts thus described, but only that some are (supposedly) relatively larger or smaller than

others, but often not even that much information is conveyed, as when a “qualitative” range is

employed (e.g.[,] “SMALL to LARGE”) to characterize an impact area, and compared to the 

same environmental facet of alternatives likewise expressed as a range (“SMALL to 

MODERATE” or “SMALL to LARGE[”).] Thus, for example when the “Land Use” impact is given 

as SMALL for “License Renewal,” but “SMALL to MODERATE” for “New Nuclear at an Alternate 

Site,” and “SMALL to LARGE” for Solar PV, no useful information is conveyed, as it is entirely 

possible that the specific implementations of each of these alternatives could all be 

characterized as “SMALL.” In fact, if the comparison had not encompassed a phony solar 

alternative focused on gargantuan utility-scale solar development on undisturbed lands, and 

focused solely on distributed rooftop and parking lot PV deployments, the net consumptive land 

use requirements of the “unreasonable” solar alternative would actually be zero, less than the 

“SMALL” and “SMALL to MODERATE” impacts of the nuclear alternatives! The failure to

meaningfully quantify and compare impacts is a violation of NEPA, as “the analysis for all draft

environmental impact statements will, to the fullest extent practicable, quantify the various

factors considered.” Only to the extent that there are “important qualitative consideration or

factors that cannot be quantified” is it acceptable for NRC to discuss “considerations or factors

in qualitative terms.” See 10 C.F.R. 51.71(d); see also 40 C.F.R. § 1502.22(a), “[i]f the 

incomplete information relevant to reasonably foreseeable significant adverse impacts is 

essential to a reasoned choice among alternatives and the overall costs of obtaining it are not 

exorbitant, the agency shall include the information in the environmental impact statement.” 

Response: The impacts discussions presented in the LGS SEIS explain and quantify the 

various environmental factors considered in reaching an impact significance level of SMALL, 

MODERATE, or LARGE for each of the license renewal NEPA issues listed in Table B-1 in NRC 

regulations 10 CFR Part 51. A standard of significance was established for each NEPA issue 

based on the CEQ terminology for “significantly” (see 40 CFR 1508.27). Since the significance 

and severity of an impact can vary with the setting of the proposed action, both “context” and 

“intensity,” as defined in CEQ regulations 40 CFR 1508.27, were considered. Context is the 

geographic, biophysical, and social context in which the effects will occur. In the case of license 

renewal, the context is the environment surrounding the nuclear power plant. Intensity refers to 

the severity of the impact in whatever context it occurs. Based on this, the NRC established 

three levels of significance for potential impacts: SMALL, MODERATE, and LARGE. The 

definitions of the three significance levels are presented in the footnotes to Table B-1 of 10 CFR 

Part 51, in Appendix B to Subpart A.

As required under NRC regulations 10 CFR 51.71(d), the LGS draft SEIS includes analyses that 

consider and weigh the environmental effects of the proposed action (license renewal) and the 

environmental impacts of alternatives to the proposed action. The LGS draft SEIS relies on 

impact significance level conclusions from supporting information in the 1996 and 2013 GEIS. 

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While a range of replacement power alternatives are discussed in the LGS SEIS, the only real 

alternative to license renewal within NRC’s decisionmaking authority is to not issue a renewed 

operating license. The NRC has no authority or regulatory control over the selection of 

replacement power alternatives. In addition, the NRC cannot ensure that environmentally 

preferable replacement power alternatives are selected. The impacts of not issuing a renewed 

operating license are addressed in the LGS SEIS as alternatives to license renewal.

This comment does not provide any new and significant information; therefore, no changes 

weremade to the SEIS. 

Comment: 31-4-LR; The relicensing process has raised local questions about the Limerick 

Generating Station. It will become more of a permanent element of the community with 

extension of the license as requested. Therefore, it is vital to have an effective and continuous 

education program about the generating station and the associated risks presented by its 

operation. Education can take the form of many types of activities that further engage local 

residents and keep them better informed about the plant and their role and responsibilities in the

event of an emergency at the facility

Response: The NRC’s OPA is available to address the public concerns and questions 

regarding nuclear safety and information regarding Limerick. The office follows news coverage 

of the agency and responds to media and public inquiries. If members of the public have 

questions or comments about the NRC, nuclear safety, or related topics, they can contact OPA 

at OPA.Resource@nrc.gov. For specific questions and concerns regarding Limerick, the public 

can contact the Region I OPA at OPA1.Resource@nrc.gov. Additional contact information for 

OPA can be accessed at http://www.nrc.gov/about-nrc/organization/opafuncdesc.html. 

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS. 

Comment: 2-23-LR; NRC Did NO Independent Monitoring Or Testing For Limerick's EIS. It Is 

Indefensible For NRC To Claim Limerick's Impacts Are “Small” When A Body Of Evidence 

Suggests Otherwise.

Comment: 2-24-LR; NRC FAILED TO HAVE AN INDEPENDENT EXPERT ANALYZE THE 

ADDITIVE, CUMULATIVE, AND SYNERGISTIC HARMS TO THE ENVIRONMENT AND 

PUBLIC HEALTH OVER THE PAST 28 YEARS. THEREFORE, NRC CAN'T MAKE A 

RELIABLE, DEFENSIBLE PREDICTION ABOUT THE HARMS FROM LIMERICK UNTIL ITS 

LICENSES EXPIRE IN 2029, NOR UNTIL 2049, DURING ANOTHER 20 YEARS IF LIMERICK 

IS RELICENSED.

Comment: 4-5-LR; NRC's EIS conclusions rely on self-serving biased calculations, estimates, 

monitoring, and reports totally controlled by Exelon, the company with a vested interest in the 

outcome that has shown it can't be trusted.

Comment: 23-25-LR; Prior to NRC's scoping process, ACE repeatedly urged NRC and other 

agencies to do a year of independent monitoring and testing for all of Limerick's broad range of 

radionuclides, as well as other toxics massively released into our air and water from Limerick. 

NRC never even responded to our requests.

Response: The NRC does not routinely perform independent monitoring around nuclear power 

plants. Independent sampling and monitoring by the NRC is only performed in rare and 

exceptional situations where there is credible evidence that a licensee’s monitoring program is 

not adequate to demonstrate adequate protection of public health and safety. The NRC 

licenses the nuclear plants, licenses the plant operators, and establishes regulations and 

license conditions for the safe operation of each plant. The NRC provides continuous oversight 

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of plants through its ROP to verify that the plants perform all required monitoring and are being 

operated in accordance with NRC rules and regulations. The NRC has authority to take 

appropriate action as necessary to protect public health and safety and may demand immediate 

licensee actions, up to and including a plant shutdown.

The NRC staff relies on other governmental agencies for data on issues outside its purview. 

For example, the SEIS, in Section 2.2.4, Surface Water Resources, uses data from the U.S. 

Geological Survey to document the volume of water flowing in the Schuylkill River near LGS. 

Also, in Section 2.2.4.2, Surface Water Quality and Effluents, the NRC staff uses data from the 

PDEP-issued NPDES permit No. PA0051926 to assess the impacts to the Schuylkill River from 

nonradiological wastewater effluents. For radiological environmental monitoring data, in Section 

4.9.2, Radiological Impacts of Normal Operations, the NRC staff used data from the PDEP

Bureau of Radiation Detection’s independent environmental monitoring program. Throughout 

the SEIS, there are environmental issues where the NRC staff used governmental agencies to 

obtain environmental data independent of Exelon’s data.

Based on the NRC’s staff review of data from Exelon and governmental agencies, no new and 

significant information was found to question the quality or integrity of the data used in the LGS 

SEIS; therefore, no changes were made to the SEIS.

Comment: 2-30-LR; NRC CLEARLY DID NOT GIVE A FULL AND FAIR REVIEW NOR 

ADDRESS THE DOCUMENTED EVIDENCE OF ENVIRONMENTAL AND HEALTH HARMS 

AND THREATS SUBMITTED FROM ACE 10-26-11 ON BEHALF OF PUBLIC INTERESTS.

• NRC ALSO REFUSED ACE'S REQUEST TO MEET TO DISCUSS OUR 

POLLUTION PERMIT ANALYSES, DESPITE THE FACT THAT NRC 

FAILED TO INDEPENDENTLY ANALYZE LIMERICK NUCLEAR PLANT'S 

POLLUTION PERMITS.

Comment: 2-38-LR; IT IS IMPOSSIBLE FOR NRC TO ACCURATELY PREDICT WHAT WILL 

HAPPEN UNTIL 2049 WHEN NRC FAILED TO REVIEW AND ANALYZE LIMERICK'S WATER 

PERMITS AND DOCKETS, AND NRC REFUSED TO MEET WITH PUBLIC INTEREST 

CITIZENS WHO DID REVIEW AND ANALYZE LIMERICK'S WATER PERMITS AND 

DOCKETS FROM BEFORE LIMERICK WAS LICENSED THROUGH THE MOST[ ]RECENT 

PERMITS AND DOCKETS ISSUED 4-13.

Comment: 4-2-LR; ACE analyzed Limerick's air and water pollution permits and Exelon's 

radiological monitoring reports which document enormous harms. NRC's PR people are 

embarrassingly uninformed about Limerick's air and water pollution. Instead of giving ACE an 

hour, NRC met with agencies that just issued five-year pollution permits with exemptions for 

high levels of dangerous pollution in violation of protective laws.

Response: The NRC acknowledges the commenter’s concerns about meeting with NRC sStaff

and agrees that public participation and input are necessary and important. Following the 

issuance of the draft SEIS for LGS and as further described in Appendix A, Section A.2, NRC 

announced and held two public meetings at Sunnybrook Ballroom, Pottstown, PA, on May 23, 

2013, to describe the results of the environmental review and answer questions on the license 

renewal process. Each meeting was preceded by a one-hour open house where the public 

could meet with and ask questions of NRC staff. These activities and interactions were 

conducted in accordance with NRC’s policy and procedures for conducting public meetings in 

support of NRC’s regulatory processes. The NRC staff’s responses to public comments 

received relative to LGS operations and regulatory requirements are contained in Section A.2 of 

this Appendix.

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Appendix A

These comments do not present any new or significant information; therefore, no changes were 

made to this SEIS.

Comment: 2-2-LR; NRC has failed to acknowledge or respond in writing to substantial written 

testimony submitted by ACE in October 2011 on 14 major categories.

Comment: 2-21-LR; NRC'S Mission Is To Protect Public Health And Safety Related To 

Limerick Nuclear Plant Operations. Minimally, That Requires NRC To Provide Full, Fair, And 

Accurate Disclosure Of All Of Limerick Nuclear Plant's Unprecedented Environmental Threats 

And Harms. The Health And Safety Of Millions Of People In The Greater Philadelphia Region 

Will Be Further Jeopardized By Negligent Conclusions In NRC'S DRAFT EIS For Limerick 

Nuclear Plant. NRC Conclusions In Limerick Nuclear Plant's DRAFT EIS Are An Unethical 

Injustice To The Public, And Must Be Changed To Reflect The Documented Evidence Of 

Unprecedented Threats And Harms.

ON BEHALF OF THE HEALTH, SAFETY, AND FINANCIAL INTERESTS OF MILLIONS OF

PEOPLE:

1. ACE Is Requesting That NRC'S DRAFT EIS For Limerick Nuclear Plant Relicensing Be 

Changed To Accurately Reflect The Documented Evidence ACE Put On NRC'S Public 

Hearing Record For Limerick's EIS October 26, 2011.

2. ACE Is Also Requesting That NRC’s Final EIS Reflect Additional Evidence Of 

Environmental Threats And Harms Included In This June 24, 2013 Written Testimony.

Comment: 4-1-LR; NRC failed to respond to our massive documentation. Would 

acknowledging facts require NRC to close Limerick? NRC wouldn't give ACE one hour for a 

meeting with NRC's Environmental Review Team. NRC clearly doesn't want to face the facts

Comment: 23-11-LR; I love “The comments considered to be within the scope of the 

environmental license renewal...” Judging the public and ignoring the public. P. 1-3 line 6.

Comment: 26-1-LR; NRC ignored and/or dismissed the hundreds of pages of ACE written EIS 

testimony presented to NRC October 2011, documenting through permit reviews, records from 

NRC's own files, PA Cancer Registry data, and other state health statistics, Limerick's 

unprecedented threats and harms to our region and its residents.

Response: The NRC considers public participation necessary and important for the 

environmental review process. As part of the environmental review for LGS, every scoping

comment and supporting documentation received during the scoping comment period was

evaluated and considered in the preparation of the site-specific anlyisis for LGS, as appropriate. 

Scoping Comments that were considered outside the scope of the environmental review were 

addressed in the Scoping Summary Report issued in March 2013. The Scoping Summary 

Report is publicly available and can be accessed from the ADAMS Public Electronic Reading 

Room at http://www.nrc.gov/reading-rm/adams.html/ under ADAMS accession number 

ML12131A499. The scoping comments considered to be in scope are listed in Section A.1 of 

this SEIS. 

Every comment and supporting documentation received on the draft SEIS was considered and, 

if appropriate, incorporated into the final SEIS. All of the comments on the draft SEIS are listed 

in Section A.2 of this SEIS, along with the discussion about whether the comments were within 

the scope of license renewal and, if appropriate, where changes to the text of the final SEIS 

were made in response to the comments.

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS.

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Appendix A

Comment: 18-1-LR; Let me give you a very specific example. On September 14, 2012, I 

wrote the NRC to request a delay of final public hearing on the Environmental Impact Statement 

of relicensing the Limerick Generating Station until the NRC's U.S. court-ordered spent fuel

study was complete. I never received a response. Not a phone call. Not a letter. Not an email. 

No response.

Recently, I called Congressman Jim Gerlach’s office and I also called Senator Bob Casey's 

office for help in getting a response to my letter. I'd like to publicly thank Greg Francis from the 

Congressman's office and Kurt Imhof from the Senator's office for personally contacting the 

NRC on my behalf. Even after those efforts, and now some eight months after I had written that 

letter, I still haven't heard back from the NRC. And I suspect I never will.

This helps to illustrate a real-life example of how regulatory capture works. In this case, the 

regulatory agency in question seems to be more concerned, in my opinion, with keeping 

Exelon's relicensing of the Limerick Generating Station on track than they are with responding 

to the concerns to protect the public interest.

Response: The NRC receive an e-mail from Congressman Jim Gerlach’s office on May 13, 

2013, requesting that the NRC provide a response to commenter’s concern regarding the public 

meeting on draft SEIS for Limerick. NRC responded to Congressman Jim Gerlach’s office

request and stated in its response that the commenter claimed that the U.S. Court of Appeals 

decision on the NRC’s waste confidence decision and rule meant no final public hearing on the 

DSEIS could be held was incorrect. The response further explained that in August 2012, the 

Commission issued an order directing the NRC staff to continue to work on licensing activities, 

but not to issue licenses dependent on the waste confidence rule until the court’s remand is 

appropriately addressed. The order specifically states that “this determination extends just to 

final license issuance; all licensing reviews and proceedings should continue to move forward.”

NRC’s response to Congressman Jim Gerlach’s office is publicly available and can be accessed 

from the ADAMS Public Electronic Reading Room at 

http://www.nrc.gov/reading-rm/adams.html/ under ADAMS accession number ML13162A446.

This comment does not provide any new and significant information: therefore, no changes 

were made to the SEIS

Comment: 23-5-LR; This is a meeting that's being transcribed. Are we on the record as we 

would be at a hearing? Is NRC on the record? I agree with Mr. Moyer, the supervisor, that 

there should be an on the record public hearing. NEPA Section 1502.2(f) says agencies shall 

not commit resources prejudging selections of alternatives before making a final decision.

On page 123 of this document it says “the USNRC preliminary recommendation is that the 

adverse environmental impacts of license renewal for LGS are not great enough to deny the 

option of license renewal for energy planning decision makers.” I think the NRC is not in 

compliance with NEPA and I think this needs to be looked into. I think the law is being broken.

Response: The public meetings held on May 23, 2013, to receive public comments on the draft 

SEIS were transcribed. As stated earlier in this section, the meeting transcripts are publicly 

available and can be accessed from the ADAMS Public Electronic Reading Room at 

http://www.nrc.gov/reading-rm/adams.html/ under ADAMS accession numbers ML13172A019 

and ML13172A023. The NRC staff conducted the environmental review for Limerick in 

accordance with NEPA and NRC’s regulations in 10 CFR 51. As part of the review the staff

evaluated reasonable alternatives to license renewal, including the no-action alternative as 

required by NEPA. NEPA does not require that a Federal agency choose an alternative with the 

least impact but rather that it disclose all potential impacts so that the decision that the agency 

makes can be fully informed. The NRC has no authority or regulatory control over the ultimate 

A-104
Appendix A

selection of future energy alternatives. Likewise, the NRC cannot ensure that environmentally 

superior energy alternatives are used in the future. The NRC makes a decision to renew or not 

to renew a license based on safety and environmental considerations. The final decision on 

whether or not to continue operating the nuclear facility will be made by the licensee and by 

state and Federal (non-NRC) decision-makers. 

This final decision will be based on economics, energy reliability goals, and other objectives 

over which the other entities may have jurisdiction. Moreover, given the absence of the NRC’s 

authority in the general area of energy planning, the NRC’s identification of a superior

alternative does not guarantee that such an alternative will be used.

The staff’s evaluation of reasonable alternatives to license renewal can be found in Chapter 8 of 

this SEIS.

Comment: 23-12-LR; Where is the safety report? Can we see it and comment in public? P. 1-

3 line 23

Response: The results of the staff’s safety review are available to the public. There is no 

formal comment period required for the safety review. While members of the public do not 

have an opportunity to comment on the SER, the Adivisory Committee on Reactor Safeguard 

(ACRS) meetings are open to the public. The ACRS is an independent panel of experts that 

advises the Commission on matters related to nuclear safety. The ACRS conducts an indepent 

review of the the applicant’s safety analysis report, the staff’s SER, and the results of the onsite 

inspections, and makes its recommendation to the Commisson regarding issuance of the 

renewed license. 

Additionally, any person who believes they would be adversely affected by a specific reactor

license renewal may request a hearing. Approximately two months after the NRC receives the

application, a notice is posted in the Federal Register indicating the opportunity for hearing 

regarding the renewal fo the operating license and instructions for filing a request for a hearing. 

Members of the public may also petition the Commission, in accordance with the provisions in 

10 CFR 2.206, for consideration of safety issues during current operation and the period of 

extended operation of the plant. 

The staff’s SER for Limerick is publicly available and can be accessed from the ADAMS Public 

Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html/. The ADAMS 

accession number for the SER is ML12357A349. The SER is also available on the Limerick 

license renewal public website at 

http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html. 

This comment does not provide any new and significant information; therefore, no changes 

were made to this SEIS

Comment: 2-26-LR; NRC'S negligent conclusions protect Exelon's profits and NRC jobs, but 

fail to protect public health and safety.

Comment: 2-37-LR; NRC IS PREPARING AN ENVIRONMENTAL IMPACT STATEMENT 

FOR LIMERICK NUCLEAR PLANT WITHOUT ACKNOWLEDGING OR ANALYZING 

LIMERICK'S ACTUAL IMPACTS ON SCHUYLKILL RIVER WATER, ECOSYSTEMS, 

WILDLIFE AND PUBLIC HEALTH TO DATE.

Comment: 23-3-LR; The DSEIS is completely self serving and shows how far NRC is in bed 

with Exelon. Nuclear [R]egulatory means regulate. NRC is paid for by all of us and should be 

fair and impartial. It is strange that the NRC wrote the DEIS. The NRC set up the interior rules, 

including small, moderate, and large -- what a brilliant idea -- and whether something is new or 

A-105
Appendix A

old. And the NRC will decide whether or not to relicense. What a farce. This is not the way to 

make decisions.

Response: These comments address concerns regarding the staff’s environmental review and 

development of the draft SEIS. The NRC staff performed its environmental review and 

developed the draft SEIS in accordance with NEPA and NRC’s requirements in 10 CFR Part 51. 

The NRC staff evaluated the impacts of license renewal on several resource areas, such as 

threatened and endangered species, terrestrial resources, aquatic resources, air quality, ground 

and surface water, land use, socioeconomic factors, and human health. The staff’s evaluation 

of the impacts of license renewal on all resource areas can be found in Chapter 4 of this SEIS.

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS. 

Comment: 2-11-LR; And finally, ACE today is formally requesting on the record that NRC hold 

a public hearing in Pottstown at some date in the future to address all of the relicensing issues 

for Limerick Nuclear Plant not specifically or adequately addressed in the Environmental Impact 

Statement.

Comment: 2-18-LR; And finally, ACE is again formally requesting that NRC hold a public 

hearing in Pottstown to address all of the relicensing issues for Limerick nuclear plant not 

specifically or adequately addressed in the environmental impacts. Our community deserves 

nothing less.

Response: The NRC acknowledges the comments and agrees that public participation and 

input are necessary and important. It is NRC practice to hold at least two sets of public meetings 

on plant-specific SEISs in the vicinity of the reactor site that is the subject of a license renewal 

application. These meetings occur at important stages of the environmental review of the 

application.

The first set of meetings occur in the vicinity of the nuclear power plant after the license renewal 

application is received and provides the public an opportunity to provide its insights on the 

scope of the plant-specific SEIS. Transcripts of the meetings are made available to the public 

after the meetings are conducted. As stated, earlier in this Appendix, for the LGS license 

renewal review, the NRC held two public meetings at the Sunnybrook Ballroom in Pottstown, 

PA, September 22, 2011. During the meeting attendees had an opportunity to provide oral 

statements that were recorded and transcribed by a certified court reporter. Trancripts of the 

entire meeting are publicly available and can be accessed from the ADAMS Public Electronic 

Reading Room at http://www.nrc.gov/reading-rm/adams.html/ under ADAMS accession 

numbers ML11287A207 and ML11287A211. 

The second set of public meetings occurs after issuance of the draft SEIS and is also held in the 

vicinity of the nuclear power plant requesting license renewal. The purpose of these meetings, 

typically consisting of an afternoon and evening session, are to present an overview of the draft 

SEIS and to obtain comments from the public and other interested stakeholders related to the 

draft. Transcripts of these public meetings are made available after the meetings are 

conducted. The NRC held to two meeting at the Sunnybrook Ballroom in Pottstown, PA, on May 

23, 2013. Trancripts of the entire meeting are publicly available and can be accessed from the 

ADAMS Public Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html/ under 

ADAMS accession numbers ML13172A019 and ML13172A023.

The NRC currently does not plan to hold additional meetings for the environmental review. 

These comments do not provide any new and significant information; therefore, no changes 

were made to the GEIS in response to these comments. 

A-106
Appendix A

Comment: 23-13-LR; Mitigation of adverse impact means you still allow adverse impacts and 

try not to do worse things, but you might, P. 1-4 line 29[.]

Response: According to the CEQ regulations in 10 CFR 1508.20, mitigation means:

 avoiding the impact altogether by not taking a certain action or parts of an 

action,

 minimizing impacts by limiting the degree or magnitude of the action and its 

implementation, 

 rectifying the impact by repairing, rehabilitating, or restoring the affected 

environment, 

 reducing or eliminating the impact over time by preservation and 

maintenance operations during the life of the action, and 

 compensating for the impact by replacing or providing substitute resources or 

environments. 

In terms of the impacts during license renewal, this definition can include such activities as: 

 using best-management practices to mitigate the impact of any required 

dredging;

 relocating a project, such as additional storage or laydown yards, to avoid 

impact on a historic or an archeological site;

 reconfiguring intake structures to reduce impingement or entrainment of fish 

or shellfish larvae; and 

 making structural changes to equipment to mitigate the potential for severe 

accidents.

For Limerick the staff considered mitigation measures for each Category 2 (i.e., site specific) 

issue, as applicable. The staff’s evaluation can be found in Chapter 4 of this SEIS.

Comment: 23-37-LR; [P.] xvii line 1. Rules – a revised rule is expected to be published. Let’s 

put this application aside for about 15 years until the rules are in and in effect and the public 

know what they say.

Response: This comment is concerning staffthe revision of the NRC’s requirements in 10 CFR 

Part 51, which is discussed in the Executive Summary of the draft SEIS. 

On June 20, 2013, the NRC published a final rule (78 FR 37282) revising 10 CFR Part 51, 

“Environmental protection regulations for domestic licensing and related regulatory functions.” 

The final rule updates the potential environmental impacts associated with the renewal of an 

operating license for a nuclear power reactor for an additional 20 years. A 2013 revised GEIS, 

which updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS 

specifically supports the revised list of NEPA issues and associated environmental impact 

findings for license renewal contained in Table B–1 in Appendix B to Subpart A of the revised 

10 CFR Part 51. The 2013 rule revised the previous rule to consolidate similar Category 1 

and 2 issues, change some Category 2 issues into Category 1 issues, consolidate some of 

those issues with existing Category 1 issues, and add new Category 1 and 2 issues.

The 2013 rule became effective July 22, 2013, after publication in the Federal Register. 

Compliance by license renewal applicants was not required until June 20, 2014 (i.e., license 

renewal applications submitted later than 1 year after publication must be compliant with the 

new rule). Therefore, it does not apply to Exelon’s license renewal application. Nevertheless, 

A-107
Appendix A

under NEPA, the NRC must now consider and analyze, in its license renewal SEIS for Limerick, 

the potential significant impacts described by the revised rule’s new Category 2 issues, and, to 

the extent there is any new and significant information, the potential significant impacts 

described by the revised rule’s new Category 1 issues.

The environmental review of the LGS license renewal application was performed using the 

criteria from the 1996 and 1999 GEIS. Neither Exelon nor NRC identified information that is 

both new and significant related to Category 1 issues that would call into question the 

conclusions in the GEIS. This conclusion is supported by the NRC’s review of the applicant’s 

ER and other documentation relevant to the applicant’s activities, the public scoping process, 

public comments on the draft SEIS, and the findings from the environmental site audit 

conducted by the NRC staff. 

The NRC staff also reviewed information relating to the new issues identified in the 2013 GEIS, 

specifically, geology and soils, radionuclides released to the groundwater, effects on terrestrial 

resources (noncooling system intake), exposure of terrestrial organisms to radionuclides, 

exposure of aquatic organisms to radionuclides, human health impacts from chemicals, physical 

occupational hazards, environmental justice, and cumulative impacts. These issues are 

documented in Chapter 4 of this SEIS. 

This comment does not provide any new and significant information; therefore, no changes 

were made to the SEIS. 

A.2.14 Opposition to License Renewal (OR)

Comment: 5-10-OR; I do not support NRC's decision to relicense Limerick or understand why 

it is rushing to do so.

Comment: 5-29-OR; What is the reason that Exelon, a declining private corporation, which 

some say is on the wrong side of energy progress, can operate Limerick, thus eliminating the 

public's right to clean air, water, and the environment for posterity, as guaranteed in 

Pennsylvania's constitution when its method?

Comment: 11-1-OR; It is my feeling, and a lot of other people I know, that the NRC should not 

even be considering relicense of Limerick nuclear power plant considering the density of our 

population and the increasing risk that exists for a meltdown.

Comment: 23-2-OR; I am oppose[d] to the relicensing and I believe this plant should be safely 

decommissioned as soon as possible and with full on-the-record public participation at every 

step.

Comment: 23-45-OR; The alternative I cho[o]se is closure now.

Comment: 23-47-OR; This not the time to approve this SEIS. This is not the time to consider 

extending the license to operate. This is the time to close this NPP. Venting, Terror, threats, 

earthquakes, expected regulatory changes; do not renew while these issues and many others 

are not resolved.

Comment: 27-1-OR; After hearing all the facts in regards to the safety of the Limerick Nuclear 

Plant, there is no doubt that this power plant should be closed down. I was watching Frontline 

on TV and saw where Germany shut down sixteen of their Nuclear power plants.

Comment: 27-5-OR; For all of our safety this power plant should be shut down.

Response: These comments express opposition to license renewal of LGS. The comments 

provide no new and significant information; therefore, no changes were made in this SEIS in 

response to these comments. 

A-108
Appendix A

A.2.15 Out of Scope (OS)

Comment: 2-3-OS; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place.

Number one, Limerick's emergency evacuation plan has been revised to include three specific 

changes: immediate notification of radiation releases through independent monitoring and 

report; expanding the evacuation zone to 50 miles; and expanding the ingestion pathway zone 

to 100 miles.....

Comment: 2-17-OS; As an approach [throughout] this EIS, Limerick's evacuation plan is a

perfect example of the checklist mentality. Exelon was required to have an update to its plan on 

file with NRC no later than 2011. The document was finally submitted to NRC in December 4 

2012. Analysis of that document, Exelon's evacuation time estimate, ETE, for Limerick nuclear 

plant's plume exposure pathway reveals that that update is based on unrealistic, unworkable 

suppositions, assumptions, inconsistencies, inaccuracies which we have enumerated, and 

illogical conclusions. NRC refused repeated requests to meet to review our detailed analysis of 

Exelon's fatally-flawed report.

Even more shocking than that, was the admission by NRC officials that they had no need or 

intention to review, evaluate, or approve Exelon's ETE. The report was turned in, checked, 

good enough.

Comment: 10-2-OS; Concerning evacuations, well, let me go back to radiation. You had

radiation detectors in the building. You have hydrogen that's not being accounted for properly. 

The Nuclear Regulatory Commission no longer has their own monitors that they maintain for 

radiation at nuclear plants. They're relying on the states to do that and the licensee to do that. 

Fortunately, at Three Mile Island, we have our own radiation monitoring network from the 

citizens.

Evacuations. A year ago, I provided documentation that the severe accident -- well, it's called a 

state-of-the-art accident consequences analysis, showed that it was rigged. There's probably 

going to be an investigation into that. May end up being in Congress, possibly bordering on the 

criminal investigations, whatever regulatory agencies, whatever that would be called.

The premise that there's no undue risk, that's what this is all about. Is there undue risk 

associated with this relicensing? The answer is yes. The premise that no undue risk will occur 

is always 8 about a timely evacuation. The NRC is not charged with protecting your property. 

They're charged with making sure you get out of town if something terrible starts to happen.

Could somebody show me one accident that happened in the world where a timely evacuation 

occurred? Or even where one was ordered in a timely way? It's not going to happen. Because 

what will happen is that people at the plant will finally realize, wow, the conditions are such that 

we've got to order an evacuation which did not happen at Three Mile Island. The reactor was 

already in the condition that the evacuation should have been ordered. It was pre-agreed. Yet, 

they didn't follow that guideline.

So the plant will call the governor's office and the governor will say okay, thank you. He'll take 

ten minutes to think about it. He'll start getting some phone calls saying now wait a minute, we 

think we got this going for us. And it gets delayed and it gets delayed. Next thing you know 

evacuation gets ordered and people are going around with higher degrees of radiation because 

they waited too long. That happened at Three Mile Island. Fukushima, plenty of disagreements 

of when evacuation should have taken place, let alone the cleanup.

A-109
Appendix A

Comment: 11-2-OS; Limerick is the second most densely populated nuclear plant in the 

nation. Relicensing 1 would be a major adjustment to millions of people in the greater 

Philadelphia area. Evacuating from a meltdown would be far worse than any evacuation 

portrayed by Hollywood. There would be traffic gridlock, accidents, panic. It will keep people 

directly exposed to massive radiation for far too long, increasing the risk of immediate radiation 

sickness and 19 eventually cancer and other disease and disability. People could become so 

radioactive they might be turned from a hospital. The hospitals here are not equipped or 

prepared to have such a disaster. They train for natural disasters, but not massive radiation 

exposure.

Reality suggests that the population could evacuate safely. I mean it can evacuate safely. 

Montgomery County officials basically confirm that in the 2011 testimony to you to the NRC that 

they already knew in 1980 a public hearing on evacuation, the NRC said Limerick could take 

double the population that could be safely evacuated within 30 miles. And now they know 30 

miles is not nearly enough, even close to the safe distance to avoid radiation plume.

The NRC allows Limerick to move forward despite risk to so many. And now the NRC plans to 

relicense Limerick knowing the population density is four times than the original number that 

they thought they could evacuate safely.

I have devastating caused by evacuation decisions by the Japanese government at Fukushima. 

NRC was supposed to approve Limerick's evacuation plan by looking at the population growth 

and the distance needed to escape the radioactive plume. Instead, NRC is dismissing lessons 

weakening evacuation plans and failing to expand evacuation zones.

In 2001, the ACE reported “Exelon seeks to cut costs in planning for emergencies.” The NRC 

allowed PECO and Exelon to cut corners at the expense of public interest. NRC's new rules 

make no sense. NRC now allows emergency drills to be run without practicing for radiation 

releases. NRC requires fewer exercises for radiation accidents. NRC's recommendation is 

fewer people evacuate after an incident to avoid a gridlock. So they'll do it in stages.

Comment: 20-1-OS; Environmentally, I am concerned about evacuation. Now I just learned 

tonight that evacuation, alas, falls into another unit of the NRC's portfolio. But since the 

professed number one mission of the NRC is to protect the public health and safety and 

because I don't know whether that other unit will ever invite public comment, I would like to 

speak briefly to evacuation tonight.

I am in my mid-60s. I am healthy, mobile, resourceful, informed, and well educated. I believe 

my chances of successfully evacuating in the event of a nuclear disaster are slim to none. I live 

a mile from the plant at the Sanatoga Ridge Retirement Community. I believe the chances of 

my neighbors evacuating successfully, most of my neighbors are in their 80s or 90s, I think their 

chances could be described as simply not having a prayer.

To pretend otherwise seems like a cruel hoax. Any previous hopes that people would be 19 

evacuating only in a ten-mile area, it seems to me, have been definitively answered and dashed 

by the actual human behavior we saw at Fukushima during their nuclear 22 disaster. People 

evacuated within a 50-mile area and they had to.

When nuclear disaster strikes at Limerick, people will be evacuating all over the greater 

Philadelphia area and into New Jersey. Millions of people, all competing in a panic mode for the 

same roads that serve us so poorly around here during an ordinary rush hour. And it can only 

get worse because daily the population increases.

Comment: 31-1-OS; As the Environmental Impact Statement indicates, the population in the 

50-mile radius of the plant was 6,819,505 in 1980 and is expected to reach 9,499,925 by 2030, 

A-110
Appendix A

a 39 percent increase in population. It is also noted that according to 2010 Census, there are 

1,365,850 people residing within 20 miles of the Limerick Generating Facility. Limerick 

Township, where the plant is located, and nearby Upper Providence Township have been two of 

the most rapidly growing communities in the county. This growth occurring along the US Route 

422 Expressway has dramatically changed the character of the area surrounding the Limerick 

Generating Station. In the past few years, the Philadelphia Premium Outlet. Mall, a 600,000 

square foot retail facility, and the adjoining Costco shopping center opened along US Route 422 

about one mile north of the Limerick Generating Station property.

The land adjoining those facilities is being considered for various types of retail and residential 

uses. Other lands in Lower Pottsgrove Township near the Limerick Generating Station have 

also been proposed for similar types of uses[.]

While the county planning commission has tried to promote lower densities of growth in 

proximity to the Limerick Generating Station, the local communities and the marketplace favor 

this location for significant development due to its proximity to the US Route 422 interchange at 

Township Line/ Evergreen Road. The growth that has taken place in the area around the power 

plant and in particular the growth taking place in the area immediately adjoining the plant and 

the primary access to it, as well as the projected growth in the future, could complicate 

evacuation plans and the movement of appropriate emergency response personnel to the plant 

in the event of a disaster. Certainly this access could be even more critical in the event of a 

natural disaster when other roads to the plant may be impassable. The Environmental Impact 

Statement needs to analyze this growth in the vicinity of the power plant to evaluate what impact 

it would have on plant operations and whether or not safe evacuation can take place from the 

newly developed areas within the extended licensing period.

Comment: 31-2-OS; The growth in the whole US Route 422 Corridor has raised numerous 

proposals for expanding the vehicle capacity of the 422 Expressway. Congested traffic 

conditions, are a way of life along the expressway and raise concern about future viability of the 

expressway and other local arterial roads as a safe evacuation routes for the region. The 

county transportation plan recognizes the need for various roa[d] improvements along the US 

422 Corridor to address current and future traffic demands. The current county comprehensive 

plan recommends several measures to enhance transportation capacity in this portion of the 

county, though due to funding limitations in Pennsylvania, these projects are not likely to move 

forward at this time. Possible mitigation strategies to be considered in the license renewal could 

include the role of Exelon in funding the important road improvements needed in -this area to 

ensure safe evacuation and access to the plant in any type of disaster.

Comment: 2-74-OS; NRC weakened regulations and requirements, including for emergencies 

and evacuation.

• NRC overhauled community emergency planning for the first time in more 

than three decades, however NRC pared down emergency rules and 

evacuation plans, further jeopardizing the public. NRC's new rules after 

Fukushima make no sense.

• Many emergency responders view NRC's new rules as downright bizarre. 

o 1) NRC Allowed Emergency Drills To Be Run Without Practicing for 

Radiation

o 2) NRC Requires FEWER Exercises for Major Radiation Accidents

o 3) NRC Recommends FEWER People Evacuate Right Away

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• Instead Of Attempting To Minimize Chaos And Reduce Radiation Exposure 

Through Better Emergency Planning and Drills For A Radioactive Accident / 

Meltdown:

o 1) NRC Deceived The Public and Weakened Emergency Rules

o 2) NRC Denied Radiation Risks and Harms

o 3) Despite Evidence from Fukushima, NRC Failed To Expand Emergency 

Zones

o 4) NRC Has Denied Repeated Requests To Expand Evacuation Zones to 

50 Miles, and Ingestion Pathway Zones to 100 Miles. This Would Better 

Protect Public Health, Safety, and Financial Interests For Vast Numbers 

Of People

Comment: 27-2-OS; We should not have to prepare for a nuclear disaster. If we would have a 

disaster, there is no way that the evacuation plan would work.

Comment: 28-2-OS; EPA suggests that the Final GEIS include greater detail of potential 

environmental impacts and the measures taken to address the increase population surrounding 

the facility both the aspect of emergency notification/evacuation planning and from cumulative 

effects perspective. As you may be aware there has been substantial population growth around 

the area of the LGS. While section 5 provides details on postulated accidents, and Section 

4.12.8 includes summary of cumulative impacts, it is unclear in both cases, how the increase of 

population has been factored into the analysis.

Comment: 5-16-OS; Inaccurate prediction models, faulty assumptions: age-related 

degradation is already surpassing original models for predicting its speed:

No prediction model can protect the public from the dire consequences of Exelon's inaccurate 

hypotheses, calculations or poor judgment, which the NRC notes are pervasive at Limerick. 

And problems are growing, due to the age-related degradation resulting from 28 years of 

nuclear operations. Even so, with about a decade to go of Limerick's original licensed period, 

inexplicably, NRC is approving Exelon's license renewal request based on relaxed standards for 

Limerick:

• In 2012, NRC refused NRDC’s request for an update of Limerick's SAMA, 

labeling the request “An impermissible attack on our regulations[.”]

• In 2012, NRC pared down emergency and evacuation planning, without reevaluating earthquake risks

o In 2013, ACE members discovered that NRC was either not aware of, or 

covered up, the existence of the Sanatoga Fault under the nuclear site 

(that met with a quarry splay that ran through the active blasting quarry 

that shares its border with the nuclear plant). NRC public statements 

have understated the risks.

o In 2013, NRC threatened to refer ACE to its allegation team for 

expressing concerns about Exelon's unworkable Limerick Evacuation 

Time Estimate (which NRC requires for re-licensing, but refuses to 

review).This seems unwarranted, when NRC invites “meaningful” public 

participation.

Response: The informating presented in these comments primarily discusses issues related to 

emergency planning (evacuation). Section 2.2.9.5 of the SEIS acknowledges that the 

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populations of Berks, Chester, and Montgomery Counties have continued to grow since 1970 

contributing to increased traffic volumes on local roads around LGS (see also Table 2–9). 

However, emergency preparedness and evacuation planning are part of the current operating 

license and are outside the scope of the environmental analysis for license renewal. 

Emergency preparedness programs are required at all nuclear power plants and require 

specified levels of protection from each licensee regardless of plant design, construction, or 

license date. Requirements related to emergency planning are in the regulations at 10 CFR 

50.47 and Appendix E to 10 CFR Part 50. These requirements apply to all operating licenses 

and will continue to apply to facilities with renewed licenses. The NRC has regulations in place 

to ensure that existing emergency preparedness and evacuation plans are updated throughout 

the life of all plants. For example, nuclear power plant operators are required to update their 

evacuation time estimates after every U.S. Census or when changes in population would 

increase the estimate by either 25 percent or 30 minutes, whichever is less. Additionally, the 

NRC assesses the capabilities of the nuclear power plant operator to protect the public by 

requiring the performance of a full-scale exercise—that includes the participation of various 

Federal, state, local government agencies, and Tribes—at least once every two years. These 

exercises are performed in order to maintain the skills of the emergency responders and to 

identify and correct weaknesses.

Within the context of license renewal, the Commission considered the need for a review of 

emergency planning issues during the 1991 rulemaking proceedings on 10 CFR Part 54, which 

included public notice and comment. As discussed in the statements of consideration for the 

rulemaking (56 FR 64943, 64966-67; December 13, 1991), the programs for emergency 

preparedness at nuclear power facilities apply to all nuclear power facility licensees and require 

the specified levels of protection from each licensee regardless of plant design, construction, or 

license date. As a result, the Commission determined that, “[t]here is no need for a licensing 

review of emergency planning issues in the context of license renewal” (56 FR 64966-67).

Therefore, issues related to emergency planning are outside the scope of the license renewal 

review . 

Comment 5-16-OS, also discusses concerns regarding NRC refusing the NRDC’s request for 

an update of the Limerick SAMA and identified faults lines near LGS that could effect plant 

operations and safety. Both of these issues are considered within scope of the environmental 

review for license renewal. Staff responses to similar comments concerning the NRDC’s request 

for an updated SAMA analysis for Limerick are presented in Section A.2.16 of this SEIS. Staff

responses to similar comments concerning identified seismic faults located near LGS are 

presented is section A.2.7 of this SEIS.These comments do not provide any new and significant 

information; therefore, no changes were made to the SEIS. 

Comment: 10-3-OS; So I guess lastly I want to talk about sabotage because that's what I 

mostly do at every nuclear power plants and counterterrorism issues since 1984. Never went 

public until 1993 as a result of a[n] intrusion where a man drove a station wagon into the nuclear 

plant at Three Mile Island into the turbine building itself. It took four hours to find him and of 

course everything was fine according to the NRC report until the federal hearings came up and 

made them reconsider security.

Response: This comment discusses issues related to security and terrorism. Security issues 

are periodically reviewed and updated at every operating plant. While security issues are 

legitimate matters of concern, they will continue to be addressed through the ongoing regulatory 

process as a current and generic regulatory issue that affects all nuclear facilities and many of 

the activities conducted at nuclear facilities. The issue of security and risk from malevolent acts 

at nuclear power facilities is not unique to facilities that have requested a renewal of their 

licenses. These reviews continue throughout the period of an operating license, whether 

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original or renewed. If issues related to security are discovered at a nuclear plant, they are 

addressed immediately, and any necessary changes are reviewed and incorporated under the 

operating license. In addition, since 9/11, the NRC and other Federal agencies have 

heightened vigilance and implemented initiatives to evaluate and respond to possible threats 

posed by aircraft against commercial nuclear power facilities and ISFSIs. 

The comment is outside the scope of the license renewal review and will not be evaluated 

further in the development of the SEIS.

Comment: 2-27-OS; 10-26-11 ACE provided NRC with several specific examples of why 

Exelon can't be trusted to provide full, accurate, or timely disclosure of Limerick's monitoring, 

testing, calculating, estimating, or reporting.

Example of Exelon's Unreliable Monitoring:

• V A vital radiation monitor was inoperable for over an entire year.

Example of Exelon's Delayed Disclosure:

• Exelon waited 23 days to inform the public about a huge radioactive spill into 

a vital public drinking water source for almost two million people.

Comment: 3-2-OS; Recently, the Limerick nuclear plant refueled Reactor. It also uprated the 

plant to produce more energy. To do this they have mixed in a more powerful fuel, GNF2, and 

changed the shape of the fuel bundles. These changes make more power, more radiation, 

more heat, and more stress on the aging equipment. Exelon is now close to the maximum 

output for the Limerick reactors. To add more power, expensive changes would be necessary 

to handle even greater stresses and greater radiation.

Comment: 3-8-OS; They allow 20 times increase in pipe leakage rates for Limerick so it can 

pass a test. They stall fuel pool liner repairs. They stall protective vent installation. They fail to 

require filters for the vents. They misled Limerick construction costs.

Comment: 4-6-OS; Exelon's deceptive radiation monitoring tactics were identified by ACE. 

Included radwaste monitoring declared inoperable for over a year. Exemptions from reporting 

using lame excuses like misplaced monitors.

Comment: 5-11-OS; NRC relinquished control of NRC's regulatory process related to the a 

crucial valve critical to maintaining Limerick plant stability:

Exelon is now in control of that crucial valve. In 2011, during an accident at Limerick, NRC cited 

Limerick with noncompliance of a legally binding requirement involving the “failure of feedwater 

Motor Operated Valve (MOV) which resulted in loss of Core Isolation Coolant (RCIC) for longer 

than specifications allow according to Technical Specifications (TS)[.”] The NRC cited the 

violation as a WEAKNESS IN MAINTAINING PLANT STABILITY.

In 2012, Exelon requested an amendment taking the MOV out of Technical Specifications (TS), 

under NRC regulatory control, and moving the MOV into the Technical Manual (TM),under 

Exelon's control and not regulated by NRC.

In 2013, the NRC inexplicably granted Exelon's request! However, at TMI, on March 28, 1979, 

the immediate cause of the loss-of-coolant accident that allowed the uncovering of the core and 

the melting of about half of it was a valve that stuck open and allowed large volumes of water to 

escape.

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

comprehensive investigation of it.

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Comment: 5-11-OS; NRC laxity regarding Limerick's aging GE Mark II Boiling Water Reactors 

(BWRs):

NRC Inspection Reports note serious degradation of Limerick's BWRs that could impact 

stability, like wear and tear at BWR vessel attachments, and yet NRC has inexplicably granted 

Exelon “Relief Requests” for such things as weld inspections, counting relief as compliance for 

re-licensing. GE has repeatedly warned Limerick about BWR deficiencies, suggesting tests be 

performed to ensure safe shut down. Did NRC require Exelon to test? What was the outcome?

It is important to note that a nuclear accident in Germany at the AEG-Kraftwerks Union (KWU) 

Wurgassen Nuclear Plant was caused by a GE Mark II Boiling Water Reactor in 1974. This is 

relevant because that accident drew attention to the essential design flaw inherent to all GE 

Mark II Boiling Water Reactors. The KWU accident resulted from a rupture due to enormous 

unanticipated BWR vibrations, equal to the seismic vibrations of a major earthquake that built up 

during the quenching process (cooling process) causing the safety relief valve to fail to close.

But PECO had made a financial investment in Limerick's BWRs by that time. SO, to save them, 

it experimented with an armature to less[e]n the vibrations. The Philadelphia Inquirer (1984) 

reported that: “Limerick's modifications included hundreds of additional pipe supports and 

elaborate bracing systems to make the reactor systems more rigid.., similar to PP&L’s 

Susquehanna Plant... You see pipe supports three times as big as the pipes themselves 

because of the changes.” 

Why has NRC granted Exelon relief requests for Limerick Vessel Attachment Weld Inspection 

and Evaluation Guidelines? In 1984, it was reported that hundreds of safety-related welds at 

the nuclear plant were not properly performed by the Bechtel Power Corp. welders and that the 

welds were not properly inspected by Bechtel and NRC inspectors (Mercury, 

8/31/84).inspectors (Mercury, 8/31/84).

On July 11, 2012, the NRC cited Exelon with a violation due to an accident by operator error 

involving BWR channels at Limerick. The inoperability of two independent channels was an 

issue: Limerick maintains that safety was maintained, however fatigue cracks were observed 

along the weld toe due to reverse bending and indicated the line was subject to vibration. 

Exelon was further cited for failing to respond to NRC in a timely fashion about the issue. We 

do not know if NRC's oversight in this area is as protective of the public as we would like it to be.

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

• License Amendment to Modify Safety Limit Minimum Unit 1, Cycle 15 

GRANTED Jan. 30/ 2012

• Core Operating Limits Report For Limerick Generating Station Unit 1, Cycle 

15 GRANTED April 3,2013

• “Withdrawal Notice” of “Reporting procedure for mathematical models 

selected to predict heated effluent dispersion in natural water bodies.” 

(Regulatory Guide (RG) 4.4, NRC-posted in the Federal Register) GRANTED 

April 3[,] 2013

• Core Operating Limits Report For Limerick Generating Station Unit 2, Reload 

12 GRANTED June 10, 2013

• Questions concerning these NRC/Exelon actions:

o Was the intent of these actions to remove impediments to limiting heated 

discharges? If so, why? [These] actions have serious implications for 

adverse health risks.

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o If Exelon can't comply with standard limits on heated effluents, why 

doesn't NRC withhold granting the requests?

o Do these actions totally remove the core limits? Do they compromise the 

integrity of the already degraded BWRs?

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

o Will NRC adjust its application approval by mandating an adjustment to 

Exelon's calculation for the accelerated aging effects that may impact the 

already degrading BWRs, due to higher heat? We believe a new fuel 

mix[ ](GNF2) is being used at Limerick. If so, does the new fuel mix 

produce more heat?

o NRC/Exelon history shows a pattern of proceeding with action before (or 

despite) the possible

o Is there any way to independently check Limerick’s discharge

temperatures with NRC or Exelon interference?

Comment: 5-17-OS; The NRC has approved Exelon amendments that eliminate Limerick's 

compliance to NRC's re-licensing application requirements, meaning that problems are hidden, 

without being resolved.

Comment: 5-18-OS; NRC has relinquished regulatory control to Exelon officials, who 

determine what regulations Exelon will comply with and which ones it will eliminate.

Comment: 5-20-OS; Why is the NRC allowing Limerick to operate in violation of its license? 

Over a decade of ACE research shows massive deficiencies, and at the top of this list of 

concerns is the fact that Limerick's GE Mark II Boiling Water Reactors are defective and NRC 

can't ensure public safety because Limerick's containment is not guaranteed.

Comment: 5-21-OS; Why does NRC rely on Exelon, a company with a vested interest in the 

outcome, to control Limerick's data and to amend NRC's regulations of Limerick so that Exelon 

appears to conform to regulations without actually having to comply?

Exelon explains Limerick's current licensed period: “The 40-year license term reflects the 

amortization period generally used by electric utility companies for large capital investments[.”] 

Exelon's use of nuclear power is a purely financial decision. So, public safety is dependent on 

NRC regulation. Inexplicably, NRC states that Exelon controls the data that NRC receives and 

relies on to assess the safety of Limerick. We believe this process is upside-down and poses a 

significant threat to public health, safety, and the environment.

Comment: 5-22-OS; Why isn't NRC using Limerick's abysmal safety record as the strongest 

evidence that NRC should not rush approval of Limerick's license renewal?

Comment: 5-25-OS; How can NRC have any excuse for re-licensing Limerick when Limerick's 

present condition is so degraded that even current operations pose an incalculable risk public 

health, safety, and the environment?

Comment: 5-26-OS; Why do the four items, that the 1984 NRC section chief said that his staff

wanted cleared up before licensing Limerick, still exist at Limerick? (Mercury, 8/31/84)

• Improper procedures: pervasive and repeatedly cited by NRC.

• Incomplete safety measures: pervasive and repeatedly cited by NRC. A 

defective hydrogen remover: at least one accident in the re-licensing period 

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involved a hydrogen leak: is there a way to confirm that the defective 

hydrogen remover was repaired or replaced?

• Faulty valves: In 2011, about six months after Exelon applied for Limerick's 

license renewal, the NRC cited Limerick with a “white” violation, defined as a 

“WEAKNESS IN MAINTAINING LONG-TERM PLANT STABILITY[.”] Unlike 

Limericks' usual violations of noncompliance to regulations, this violation was 

a[ ]”Violation of a Legally Binding Requirement[.”] The violation involved the 

failure of the Motor Operated Valve (MOV), mentioned on the first page of 

this letter. 

Comment: 13-2-OS; Let me read you what the general design criteria says according to the 

NRC's own requirement. “The principal design criteria establish the necessary design, 

fabrication, construction, testing, and performance requirements for structures, systems, and 

components important to safety. That is structures, systems, and components that provide 

reasonable assurance that the facility can be operated without undue risk to the public health 

and safety.” How can this Agency proceed with licensing, relicensing in view of the dramatic 

failures that we all witnessed world-wide on television at the moment at Fukushima Daiichi and 

those series of explosions which now demonstrate that the General Electric Mark I boiling water 

reactor containment system is a 100 percent guaranteed failure. Three operational units at the 

time, Units 1, 2, and 3, 100 percent failure under severe accident conditions. Multiple 

explosions, 5 massive land contamination, marine contamination, groundwater contamination, 

and that's the evidence. That's what we all witnessed.

But it doesn't stop there. The NRC's own general design criteria focuses on the containment 

design itself for this nuclear power plant. These two units. And that is general design criterion. 

And again, this is the NRC's own language. “Containment design. Reactor containment and 

associated systems shall be provided to establish an essentially leak-tight barrier against the 

uncontrolled release of radioactivity to the environment and to assure that the containment 

design conditions important to safety are not exceeded for as long as a postulated accident

condition is required. The NRC knows that the Limerick Units 1 and 2 containment design is 

very likely to fail if challenged by a nuclear accident. In fact, the NRC's own staff in a paper 

prepared for the Commission, SECY-2012-0157, identifies that for the General Electric Mark II 

boiling water reactor at Limerick, involving core damage, there is roughly a 50-50 chance of 

recovering from the nuclear accident within the pressure vessel with no significant reactor

release from containment. That's their language. The flip side is that it's a 50-50 chance that 

the vessel will fail with a significant release from containment.

It goes on to say, this is the NRC staff that “if the vessel fails, there's a 25 percent chance that 

the operators might cool the molten core inside the containment with no significant release to 

the environment.” Okay, the flip side of that is there's a percent chance that they will recover, 

that there will be a release, a significant release. This is the NRC's own estimate of Limerick 1 

and 2.

That said, NRC states there is an 11.8[-]percent chance that a severe core damage sequence 

will lead to early over pressure containment failure where there is a 90 percent chance the 

molten core will bypass the containment system, principally the suppression pool because it will 

burn through seals in the containment and there will be a catastrophic release of unfiltered 

radioactivity into the environment and to the population down wind. That's you. That's us. 

That's miles and miles and miles away. This is the kind of gambling that the Agency and the 

industry are engaged in for the emolument of a few men. We don't need this plant to be 

operating at that risk.

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In fact, this plant should not receive a license renewal and should be put into a phase out just on 

the fact that they are in violation of their license agreement.

Response: These comments discuss issues related to safety concerns and past safety 

performance at LGS. The NRC assesses plant performance continuously and communicates 

its assessment of plant performance in letters to the licensees. These assessment letters are 

available on a plant performance page for each plant, and are posted on the website as they 

become available. The NRC assessment reports for LGS can be accessed at 

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/LIM1/lim1_chart.html and 

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/LIM2/lim2_chart.html. 

Additionally, there are two methods of reporting safety and security concerns to the NRC. The 

choice depends on whether the concern is considered an emergency or not. Emergency

concerns include: 

• any threat, theft, smuggling, vandalism, or terrorist activity involving a nuclear 

facility or radioactive materials; 

• lost or damaged radioactive materials; and

• any accident involving a nuclear reactor, nuclear fuel facility, or radioactive 

materials.

Members of the public reporting an emergency concern should call the NRC’s 24-hour 

Headquarters Operation Center at 301-816-5100. Nonemergency concerns should be brought 

to the attention of the NRC project manager assigned to a specific plant. The list of NRC project 

managers is located at http://www.nrc.gov/reactors/operating/project-managers.html#pwr. This 

web page also contains a quick link to the NRC telephone directory.

These comments are not within the scope of the environmental review and will not be evaluated 

further in the development of the SEIS.

Comment: 2-54-OS; 

• There are countless opportunities for future leaks in the miles of buried, hardto-inspect pipes under the Limerick site.

• For 28 years some pipes have been transporting highly corrosive, heated, 

and radioactive water. Aging and deterioration can cause pipes to become 

brittle and leak.

Comment: 5-1-OS; NRC regulations have become as deteriorated and unprotective as 

Limerick's aging equipment. That equipment is plagued by thinning, pitting, fatigue, erosion, 

leaching, embrittlement, and GE Mark II boiling water reactor stress corrosion cracking. The list 

of opportunities for disaster is endless. Limerick monitoring equipment has been out of service, 

unnoticed sometimes for more than a year, and automated systems have failed, discovered only 

after accidents occur. Public statements by NRC and Exelon following such events are generic 

and deceptive.

Comment: 7-2-OS; What worries are the miles of hard to inspect pipes and cables buried 

under Limerick that can be disrupted and then incapable of delivering vital electricity and cooling 

water to prevent meltdown. NRC should be worried, too, but instead gave Limerick until 2017 to 

come up with a new seismic risk study or plan. It's beyond negligence for NRC to allow Exelon 

to wait years to take action.

Comment: 5-24-OS; Why does NRC's “License Renewal Requirements for Power Reactors” 

sound less like “requirements” and more like a “disclaimer”? 

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On page '1- 3' of Limerick's Safety Evaluation Report, 2012, released Jan. 10, 2013, NRC states 

that “License renewal requirements for power reactors are based on two key principles:

1. The regulatory process is adequate to ensure that the licensing basis of all currently 

operating plants maintain an acceptable level of safety with the possible exceptions of 

the detrimental aging effects on certain functions of certain structures, systems or 

components, as well as a few other safety-related issues, during the period of extended 

operation.

2. The plant-specific licensing basis must be maintained during the renewal term in the 

same manner and to the same extent as during the original licensing term. “Would a 

person buy a used washing machine with a warranty like that? Limerick is a nuclear 

plant: it should be held to the highest standards, yet NRC has never required Limerick 

nuclear plant to be in compliance. Why?

Comment: 5-31-OS; Why has NRC excused Limerick from complying Compliance with GALL

regulations in Limerick's License Renewal Application?

In 1998, the NRC allowed the NEI to amend the GALL Report to make the process of nuclear 

plant license renewal easier and faster. The Nuclear Energy Institute (NEI) is the powerful 

lobbying arm of the nuclear industry. GALL Commitment No. 46 requires applicants for license 

renewal to test and confirm that their programs for aging equipment and systems work as a 

condition for re-licensing. 

However, Exelon requested the elimination of GALL Commitment No. 46 by amendment that 

would substitute a one-time test at Limerick in the future. NRC pointed out that eliminating the 

test would create a 10-year gap during which there would be no way to tell if planned “aging 

management programs are effective, require modification, or whether there is a need to develop 

new aging management programs[.”] Exelon's application also contained:

• Deviations from GALL (Generic Aging Lessons Learned)

• Unclear explanations 

• Unclear theory for aging management

And yet NRC approved Exelon's application for Limerick license renewal. The NRC goes 

through the motions, but the rewording of compliance regulations by NRC and Exelon virtually 

eliminates literal active safety compliance.

Response: These comments discuss issues related to NRC’s safety review of the license 

renewal application. The NRC’s environmental review is confined to environmental matters 

relevant to the period of extended operation requested by the applicant. The regulations 

governing the environmental review are contained in 10 CFR Part 51, and the regulations for 

the safety review are contained in 10 CFR Part 54. Because the two reviews are separate, 

operational safety issues and safety issues related to aging are outside the scope for the 

environmental review.

The principal safety concerns associated with license renewal are related to the aging of 

structures, systems, and components important to the continued safe operation of the facility. 

When the plants were designed, certain assumptions were made about the length of time each 

plant would be operated. During the safety review for license renewal, the NRC must determine 

whether aging effects will be adequately managed so the original design assumptions will 

continue to be valid throughout the period of extended operation. The SER for the safety 

review of the Limerick license renewal reviewed can be accessed from the ADAMS Public 

Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html/ under ADAMS 

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accession number ML12357A349. The SER is also available on the Limerick license renewal 

public website at 

http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html. 

These comments are not within the scope of the environmental review and will not be evaluated 

further in the development of the SEIS.

Comment: 2-5-OS; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place....

......Number three, Exelon has completed all necessary inspections, maintenance, and 

corrective actions at Limerick Nuclear Plant that have been deferred by NRC until sometime 

between 2017 and within six months of the expiration of the current license in 2024....

Comment: 2-7-OS; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place.

.....Number five, Earthquake mitigation plans have been completed, 2017. And all necessary 

change have been made at Limerick.

Number six. NRC required vents have been install to prevent radioactive hydrogen gas buildup 

and explosions 2017. 

Number seven. Exelon installs filters for those vents to minimize radiation releases during 

meltdowns. NRC's own staff has concluded the consequences of not installing filters could be 

so bad that filters should be required regardless of expense.... 

Comment: 2-77-OS; NRC IS ALLOWING DANGEROUS DELAYS FOR IMPORTANT 

SAFEGUARDS RECOMMENDED BY NRC'S OWN POST-FUKUSHIMA TASK FORCE.

NRC allowed Exelon to DELAY important post-Fukushima safeguards recommended by their 

own staff, even though Limerick is considered a high-risk nuclear plant with GEMark II boiling 

water reactors similar to those at Fukushima.

NRC Is I[g]norin[g] Its Own Orders, Based On Fukushima Task Force Recommendations Issued

July, 2011. MARCH, 2012 - NRC officially issued three orders to U.S. nuclear power plants:

1. Plants must develop and implement measures to keep spent fuel rods cool after an 

extreme natural disaster.

2. Sturdier venting systems are required to help prevent pressure-induced explosions.

3. They must have a reliable read of water levels in spent fuel containers.

MARCH 13, 2012 NRC Issued Order to Modify Licensees Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events NRC 3-12-12 Letter (E-mail notice 3-13-

12).

NRC's Order Requires a 3-phase Approach For Mitigating Beyond-Design-Basis External 

Events.

1. Initial phase - Requires use of installed equipment and resources to maintain or restore 

core cooling, containment, and SFP cooling.

2. Transition phase - Requires providing sufficient, portable, onsite equipment and 

consumables to maintain or restore these functions until they can be accomplished with 

resources brought from off site.

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3. Final phase - Requires obtaining sufficient offsite resources to sustain those functions 

INDEFINITELY.

• It is not clear any of these orders have been, or will be, required by NRC to 

be completed prior to relicensing of Limerick Nuclear Plant. It is important to 

remember that Fukushima was relicensed just a short time prior to the 

catastrophe. What was clear was the collusion between the owner and the 

regulator.

• It is not clear any safety measure will be completed before 2017, six years 

after the Fukushima disaster.

Comment: 13-1-OS; I'm here to speak in opposition to the Limerick relicensing primarily 

because the NRC, following the Fukushima accident, should suspend all relicensing license 

extension reviews, particularly this is important because the Limerick unit is similar to the 

General Electric boiling water reactors that exploded at the Fukushima Daiichi nuclear power 

plant site. So it's a concern that the Agency and the industry are proceeding with a conveyor 

belt-like process that is ignoring the environmental impacts. It's failing to consider the 

environmental impacts that are still coming out, that are still being revealed by the accident at 

Fukushima.

I can tell you that the concern goes far beyond just the fact that the NRC is ignoring these 

concerns. The problem is that the NRC doesn't have the ability or the will to actually challenge 

a license extension for any nuclear power plant, let alone the Limerick plant as it is a sister plant 

to Fukushima Daiichi.

Comment: 18-3-OS; How can the NRC properly assess the environmental impact of 

relicensing Limerick Generating Station until the earthquake mitigation plans have been 

completed? And we won't know the results until sometime in 2017.

Comment: 13-4-OS; The concerns here are far reaching and I think that the story that I wanted 

to bring to start off with was the concern is how can you do an accurate Environmental Impact 

Statement if in the midst of trying to figure out just how far the reach of the Fukushima Daiichi 

nuclear accident really is and in terms of its impact on land contamination, air, water, and 

marine environment contamination by radioactivity from this accident? And so it's our 

recommendation, request, that this relicensing be suspended until there's a more reliable 

reviewable Environmental Impact Statement that tells us what's the results from Fukushima 

Daiichi and the nuclear catastrophe that happened at the GE boiling water reactors there similar 

to those here.

Comment: 7-5-OS; Fracking could trigger an earthquake, disrupting underground pipes and 

cables. Over 3,000 gas wells were approved in Pennsylvania. Two thousand more are to be 

approved this year. Structural problems and flaws associated with Limerick construction are of 

concern. For example, Limerick's PAC 70 fuel pools were constructed with substandard 

cement. After all of this, NRC isn't requiring Limerick to do important seismic upgrades until 

after 2017, even though Limerick is considered by some to be third on the nation's earthquake 

risk list.

By then we can have an earthquake and a meltdown. Limerick should never have been built in 

the first place. NRC falsely claims earthquake risk were considered prior to Limerick approval. 

That's not true. The first reactor was delivered to Limerick's construction site in 1972, two years 

before this 1974 when the seismic study was completed. With earthquakes becoming stronger 

and more frequent NRC owes it to us to shut Limerick down before it melts down.

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Comment: 10-1-OS; The plants are no longer required to have hydrogen recombiners. So 

during an accident event, much hydrogen is created. But they no longer are required to try to 

eliminate that problem that leads to an explosion. The vents that were used in Fukushima did 

employ the fix that was recommended here in the United States by the Nuclear Regulatory 

Commission. One hundred percent of those vents failed. It's a very similar vent that's here at 

Limerick.

In an accident scenario, the releases could be much more dangerous than what these reports 

assume. This is one of the faulty data sets that I'm going out. This conclusion should not be 

accepted by anyone because the assumptions that are made are not conservative meaning on 

the side of safety. They are sometimes at best protective of their interest rather than the health 

and safety of the people.

Response: As explained above, the NRC’s ongoing safety review of operating reactors is 

outside the scope of this environmental review for license renewal. The NRC will continue to 

take necessary actions to ensure that all plants, including LGS, operate safely under their 

current and extended operating periods. The NRC continues to evaluate and act on the lessons 

learned from the March 2011 nuclear accident in Japan to ensure that appropriate safety 

enhancements are implemented at nuclear power plants here in the United States. 

On March 12, 2012, the NRC issued the first regulatory requirements for the Nation’s reactors 

based on the lessons learned at Fukushima Dai-ichi. The NRC issued three orders requiring 

safety enhancements of operating reactors, construction permit holders, and combined license 

holders. These orders require nuclear power plants to implement safety enhancements related 

to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at 

plants, (2) ensuring reliable hardened containment vents, and (3) enhancing spent fuel pool 

instrumentation. The plants are required to promptly begin implementation of the safety 

enhancements and complete implementation within two refueling outages or by December 31, 

2016, whichever comes first. In addition, the NRC issued a request for information, requesting 

each licensee to reevaluate the seismic and flooding hazards at the site using present-day 

methods and information, conduct walkdowns of its facilities to ensure protection against the 

hazards in its current design basis, and reevaluate emergency communications systems and 

staffing levels.

The NRC continues to implement Fukushima lessons learned within existing regulatory

processes that include review of industry response to orders, requests for information (RFIs),

use of operating experience, rulemaking, and conducting additional research.

The public can access additional information regarding the NRC response to the Japan nuclear 

accident on the NRC’s public Web site at 

http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html. 

Comment: 26-6-OS; FIN[A]NCIAL INJUSTICE OF MAJOR PROPORTIONS!

We get the harms, Exelon gets the profits, and others including in other states get electric. 

Limerick's electric goes to the grid. It isn't produced just for people in our region. However, 

ratepayers in our region paid the lion's share of the $6.8 billion in costs for Limerick construction 

in their monthly electric bills from 1985 to 2010, and we still pay each month for Limerick 

decommissioning. Property taxes were avoided by PECO/Exelon from 1985 to 2002, when a 

court ordered Exelon to pay only $3 million each year, instead of the $17 million that should be 

paid each year.

Response: This comment addresses concerns regarding the cost of energy. The regulatory 

authority over licensee economics (including the need for power) falls within the jurisdiction of 

the States and to some extent within the jurisdiction of the Federal Energy Regulatory 

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Commission. The proposed rule for license renewal had included a cost-benefit analysis and 

consideration of licensee economics as part of the NEPA review. However, during the comment 

period, State, Federal, and licensee representatives expressed concern about the use of 

economic costs and cost-benefit balancing in the proposed rule and the GEIS. They noted that 

the President’s CEQ regulations interpret NEPA to require only an assessment of the 

cumulative effects of a proposed Federal action on the natural and man-made environment and 

that the determination of the need for generating capacity has always been the States’ 

responsibility. For this reason, the purpose and need for the proposed action (i.e., license 

renewal) is defined in the 1996 GEIS as follows:

The purpose and need for the proposed action (renewal of an operating license) is to 

provide an option that allows for power generation capability beyond the term of a 

current nuclear power plant operating license to meet future system generating needs, 

as such needs may be determined by State, licensee, and, where authorized, Federal 

(other than NRC) decision-makers. 

The purpose and need for NRC’s proposed action is to provide an option to continue 

plant operations beyond the current licensing term to meet future system generating 

needs, as such needs may be determined by State, utility, system, and, where 

authorized, Federal (other than NRC) decision-makers

Section 51.95(c)(2) of 10 CFR states that:

The supplemental environmental impact statement for license renewal is not required to 

include discussion of need for power or the economic costs and economic benefits of the 

proposed action or of alternatives to the proposed action except insofar as such benefits 

and costs are either essential for a determination regarding the inclusion of an 

alternative in the range of alternatives considered or relevant to mitigation. 

The comment is outside the scope of the license renewal review and will not be evaluated 

further in the development of the draft SEIS.

A.2.16 Postulated Accidents & SAMA (PA)

In CLI-13-07, the Commission directed the staff to review the significance of any new SAMArelated information in its environmental review of Exelon’s license renewal application, including 

the information presented in NRDC’s waiver petition (NRDC 2012), and to discuss its review in 

the final supplemental EIS (NRC 2013b). Comments numbered 30-XX-PA were NRDC 

comments relating to SAMA, including those in the waiver petition. Similar comments submitted 

by other stakeholders are binned with the NRDC comments.

Comment: 30-3-PA; (Section 5.3, pages 5-3 to 5-14) The NRC begins this section by 

recounting the reasons the Commission concluded in 1999 that future updating of the 1989 

Severe Accident Mitigation Design Alternatives (SAMDA) analysis would be unnecessary-the 

basis for 10 CFR 51.53(c)(3)(ii)(L). To the contrary, as shown here, subsequent events have 

proven that the Commission's earlier thinking was flawed. We begin by quoting from the GElS 

Supplement: "The staff has previously performed a site-specific analysis of severe accident

mitigation in a NEPA document for LGS in the Final Environmental Statement Related to 

Operation of LGS Units 1 and 2 in NUREG-0974, Supplement 1 (NRC 1989) ("1989 SAMDA 

Analysis")." (Page 5-3, lines 13-15). The staff concluded that: "The risks of early fatality from 

potential accidents at the site are small in comparison with risks of early fatality from other 

human activities in a comparably sized population, and the accident risk will not add significantly 

to population exposure and cancer risks. Accident risks from Limerick are expected to be a 

small fraction of the risks the general public incurs from other sources. Further, the best 

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estimates show that the risks of potential reactor accidents at Limerick are within the range of 

such risks from other nuclear power plants (emphasis added)." (page 5-3, lines 25-31). The 

last sentence in the quote above is false, in that the theoretical "best estimate" calculation of 

core damage frequency is orders of magnitude lower than the historical risk, when world data 

are used, as described below.

The staff goes on to say: "However, in the LGS specific 1989 SAMDA Analysis, the staff

acknowledged: In the longer term, these same severe accident issues are currently being 

pursued by the NRC in a systematic way for all utilities through the Severe Accident Program

described in SECY-88-147, "Integration Plan for Closure of Severe Accident Issues" (NRC 

1988c). The plan includes provisions for an Individual Plant Examination (IPE) for each 

operating reactor, a Containment Performance Improvement (CPI) program, and an Accident

Management (AM) program. These programs will produce a more complete picture of the risks

of operating plants and the benefits of potential design improvements, including SAMDAs. The

staff believes that the severe accident program is the proper vehicle for further review of severe

accidents at nuclear power plants, including Limerick." (page 5-3, lines 32-43, emphasis

supplied). Of course subsequent to the Fukushima Dai-ichi accident, the last sentence in the

quote above turned out to be incorrect, in that the Staff and Commission have decided to

address most of the Fukushima issues in separate venues.

The staff then go on to observe: "In light of these studies, the Commission believed [in 1996] it

was "unlikely that any site-specific consideration of SAMAs for license renewal will identify major 

plant design changes or modifications that will prove to be cost-beneficial for reducing severe 

accident frequency or consequences" (61 FR 28467)." (page 5-4, lines 5-8). Again, the

Commission programs for addressing a wide range of safety issues requiring potential plant

design changes as a follow up to the accident at Fukushima Dai-ichi have proven that the

Commission's earlier conclusion was short sighted and in error.

Beginning on page 5-7, the Staff correctly observes: "Additionally, both the applicant and the

NRC must consider whether new and significant information affects environmental 

determinations in the NRC's regulations, including the determination in 10 CFR 51.53(c)(3)(ii)(L)

and Table B-1 that the agency need not reconsider SAMAs at license renewal if it has already 

done so in a NEPA document for the plant." (page 5-7, lines 10-13). The Staff then sets a high

bar: "New information is significant if it provides a seriously different picture of the impacts of the 

Federal action under consideration. Thus, for mitigation alternatives such as SAMAs, new

information is significant if it indicates that a mitigation alternative would substantially reduce an 

impact of the Federal action on the environment. Consequently, with respect to SAMAs, new

information may be significant if it indicated a given cost-beneficial SAMA would substantially

reduce the impacts of a severe accident, the probability or consequences (risk) of a severe

accident occurring." (page 5-7, lines 13-15, emphasis added).

Having set the bar high, the staff proceeds to analyze four issues, and does so individually,

rather than collectively. The Staff ignores an issue we raised in NRDC's intervention in the

Limerick license renewal proceeding. The Declaration of Thomas B. Cochran, Ph.D., Matthew 

G McKinzie, Ph.D., And Christopher J. Weaver, Ph.D. on behalf of the Natural Resources 

Defense Council, In the Matter of Exelon Generating Company, LLC, (Limerick Generating 

Station License Renewal Application) Dockets No. 50-352-LR and 50-353-LR), November 22, 

2011, namely, that the risk of a core damage accident at Limerick is likely to be much greater 

than the theoretical estimate based on the Limerick Probabilistic Risk Assessment (PRA). In the 

Cochran, McKinzie, Weaver declaration we stated: "The Limerick SAMDA analysis relies on a 

Core Damage Frequency (CDF) of 4.2 x 10-5 per year (NRC, 1989) and the Environmental 

Report submitted by the applicant cites an estimate of CDF, which only includes internal events, 

for Limerick Units 1 and 2 of 3.2 x 10-6 per year based on a Probabilistic Risk Assessment 

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(PRA) (Exelon, 2011b). In a recent update to the licensee's IPEEE model to include internal 

fire risks as well as internal events in its PRA, the license calculated a total CDF of 1.8 x 10' per 

year for these hazard groups (NRC, 2011b). Because the PRA is based on modeling

assumptions that contain a large number of approximations, large uncertainties, and omissions, 

the absolute value of a CDF calculated using PRA is not a reliable predictor of the actual CDF 

value."

Worldwide, NRDC calculates that there have been approximately 429 light water reactors

(LWR) that have operated approximately 11,500 reactor-years, and that five of these LWRs

(Three Mile Island Unit 2, Greifswald Unit 5, Fukushima Daiichi Units 1, 2, and 3) have

experienced core damage as CDF is defined in NUREG-1150 Vol. 1, pg. 2-3. Thus, for this 

class of nuclear power reactors, LWRs, the CDF is approximately 4.3 x 10-4 per reactor-year 

based on the historical record. I calculate that in the United States there have been 

approximately 116 LWRs that have operated approximately 4,100 reactor years. One of these 

LWRs (Three Mile Island Unit 2) experienced core damage as defined by NUREG-1150. Thus, 

for this class of nuclear power reactors the CDF is approximately 2.4 x 10-4 per reactor-year 

based on the historical record. The Limerick reactors, BWRs with Mark 2 containments, are 

similar in many respects to Fukushima Daiichi Units 1, 2 and 3, BWRs with Mark 1

containments. While no U.S. BWRs have experienced core damage as defined by NUREG1150, I calculate that worldwide there have been approximately 117 BWRs that have operated 

approximately 3,300 reactor years. Three of these BWRs (Fukushima Daiichi Units 1, 2, and 3) 

have experienced core damage as defined by NUREG-1150. Thus, for this class of nuclear 

power reactors worldwide the CDF is approximately 9 x 10-4 per reactor-year based on the 

historical record.

In sum, the global CDFs for all LWRs and the subset of BWRs based on historical data are 

much greater than the theoretical value calculated by the applicant for Limerick Units 1 and 2, 

as is the U.S. historical CDF for LWRs. If a larger CDF is assumed in a PRA, then the 

calculated cost of severe accidents within a SAMA analysis would be increased proportionally, 

and thus it would be more likely that the economic viability of the measures to mitigate such 

accidents would be cost-beneficial. 

We do not argue that any of the above CDF estimates based on the historical evidence 

represent the most accurate CDFs for Limerick Units 1 and 2. In our judgment the most

accurate values of CDF probably lie somewhere between the theoretical values calculated by

the applicant and one or more of the U.S. or global values based on the historical record.

However, the CDFs used in a Limerick SAMA analysis should be evidence based. The 

applicant's estimates of CDF are non-conservative and a Limerick SAMA analysis would benefit 

from a sensitivity analysis in which higher core damage frequencies are assumed. Given the 

historical operating record of similar reactors, we assert that it is simply not credible to assume 

the CDF for older BWR reactors in the United States, such as Limerick Units 1 and 2, to be as 

low as 1.8 x 10-5 per reactor year, i.e., about one core damage event per 55,000 reactor-years 

of operation.

A range of CDF values including values close to those estimated from the global historical

evidence should be used in the SAMA analyses for Limerick Units 1 and 2. This issue should 

be analyzed and discussed in the Limerick environmental report and the final environmental

impact statement. 

In our view a current-day SAMA analysis is required in the NEPA analysis of severe accidents 

one that includes the cumulative impacts of a severe accident based on new and significant 

information, including a range of core damage frequencies between the very low frequency 

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estimated by the theoretical PRA process and the high frequency estimated using historical 

world data.

Response: The commenter states, “the global CDFs for all LWRs and the subset of BWRs 

based on historical data are much greater than the theoretical value calculated by the applicant 

for Limerick Units 1 and 2.” The staff recognizes that the CDF could be calculated on a generic 

basis from direct experience or on a site-specific basis using probabilistic risk assessment. This 

is also recognized by the commenter. The commenter states, “First, the probability can be 

estimated using the techniques of probabilistic risk assessment [PRA]. In a PRA study, analytic 

techniques such as fault trees are used to predict the occurrence of comparatively rare 

sequences of events that would lead to severe fuel damage and, potentially, a radioactive 

release. Second, the probability can be estimated from direct experience.”

The staff disagrees that a SAMA is not credible because the CDF is not estimated generically 

from direct experience. The site-specific, plant-specific PRA takes into account site-specific 

hazards, design of the plant, and plant specific operational practices that affect how a particular 

plant responds to potential challenges. This site-specific PRA is expected to yield a much more 

accurate estimate of risk (including CDF) than a historical rate calculation using an extremely 

limited set of data points that aggregates all different plant designs, operational practices, and 

site conditions around the world. The SAMA analysis for license renewal is a Category 2 issue, 

which means that it should be evaluated on a site-specific bases. In the Limerick example, 

Exelon calculates the current CDF using plant specific fault trees, event trees and reliability 

information. This approach is consistent with the current guidance for preparing a SAMA 

analysis provided in Revision A of Nuclear Energy Institute (NEI) 05-01, “Severe Accident 

Mitigation Alternatives (SAMA) Analysis” (NEI 2005), which was endorsed by the staff for use in 

SAMA analysis. This guidance provides the applicant guidance to use the plant-specific PRA 

model. Based on this site specific information, the applicant is to estimate the severe accident

risk, off-site dose and economic impacts of a severe accident. 

While the commenter further suggests that the direct experience model could help refine sitespecific PRA estimates, the commenter does not provide specific proposals on how the direct 

experience model could improve those estimates, other than to state that the true CDF for 

Limerick might lie between the two. The staff believes that, the plant-specific estimate, based 

on the most current information regarding the plant design, appears to be the most accurate 

measure of risk at Limerick. 

The NRC also recognizes that newer calculation methods could be developed or operating 

experience could occur that might identify a new SAMA candidate for consideration (See CLI10-11) (noting that while ”there will always be more data that could be gathered, agencies must 

have some discretion to draw the line and move forward”). In promulgating the license renewal 

rule, the Commission recognized that additional SAMAs could be identified. However, the 

Commission indicated that future SAMAs would only likely identify cost-beneficial changes that 

“generally would be procedural and programmatic fixes, with any hardware changes being only 

minor in nature and few in number.” Therefore, the Commission explicitly determined that, if a 

consideration of SAMA was completed, another need not be completed at license renewal, 

despite the fact that future SAMA analyses may uncover additional, cost-beneficial SAMAs. 

This is because the NRC has evaluated and continues to evaluate severe accidents in the 

current operating term. Significantly, while the Commission did impose additional safety 

requirements on operating reactors following Fukushima, the Commission did so on the basis of 

a safety analysis conducted under the Backfit Rule, not the results of a SAMA analysis 

conducted for NEPA purposes. Those SAMA analyses had long assumed that prolonged 

station blackouts, such as the one experienced by the Fukushima reactors, could yield 

devastating consequences. Therefore subsequent events, including the Fukushima events, 

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have confirmed the Commission’s twin expectations that 1) future SAMA analyses would not 

likely find major plant improvements cost beneficial and that 2) the NRC would continue to 

reduce risk at regulated facilities through its ongoing safety oversight. 

Finally, the comment suggests that the Staff erred by considering the challenges (earthquakes, 

population increases, etc.) to the Limerick SAMDA analysis separately, instead of collectively. 

However, considering the challenges to the Limerick SAMDA analysis collectively in an 

undisciplined fashion may yield unrealistic results. Therefore , the staff evaluated the 

challenges separately, as provided in Chapter 5 of the Limerick environmental impact 

statement. Moreover, as discussed in Chapter 5, the CDF at Limerick has decreased 

dramatically since 1989 and the 1989 SAMDA analysis rested on many conservatisms. 

Therefore, the Staff finds it unlikely that these challenges, even considered together, would 

constitute new and significant information with respect to severe accident mitigation at Limerick 

and no changes were made to the SEIS.

Comment: 2-74-PA; Exelon and NRC want to exempt Limerick, as one of three nuclear plants 

that never again have to consider an updated Severe Accident Mitigation Analysis in connection 

with new and significant environmental information under NEPA in relicensing.

Comment: 2-75-PA; The National Resource Defense Council (NRDC) Filed a Legal Appeal 

and won in the 3rd Circuit Court of Appeals in Philadelphia, Against Exelon's Attempt To 

Circumvent a Safety Analysis Requirement for Limerick Nuclear Plant's Outdated, Unacceptable 

Accident Mitigation Analysis.

• The judge agreed with NRDC's conclusion that ignoring the population 

growth around Limerick is unacceptable if an emergency evacuation at 

Limerick becomes necessary.

• Common sense planning is needed stating that what was acceptable in 1989 

is not good enough now and in the future.

• Limerick's Severe Accident Mitigation analysis was last completed in 1989, 

relying on the census for 1980 population.

Even after Fukushima, involving boiling water reactors similar to Limerick's, and drastically

increased populations that would clearly be impacted by a Fukushima-type disaster at Limerick,

NRC illogically joined Exelon in an appeal against a federal court decision, in order to avoid an

updated safety analysis for Limerick. The federal court decision stated that Limerick can't be

exempted.

Comment: 2-79-PA; Exelon should not be using decades-old 1989 information to determine 

health and economic impacts. It is inexcusable for NRC to allow Exelon to use decades old

comparisons for anything, especially population. NRC is letting Exelon get away with declaring 

its review of new and significant information compared to 1989, claiming Exelon did not uncover 

any cost beneficial plant improvements or SAMAs that would substantially decrease risk of a 

severe accident. That doesn't even make sense considering NRC's own post-Fukushima 

recommendations. Cost beneficial to whom? Certainly NOT public interests!

• Exelon's evaluations and claims are based strictly on their costs. That leads 

to decisions ignoring unacceptable risks to the public.

• NRC's job is to ensure public safety, not protect Exelon's profits.

• NRC is supposed to protect the public's interests. NRC has failed to consider 

and compare impacts and costs to the public for Exelon not being required to 

spend the money for the safest accident mitigation. 

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Costs to the public for an accident/meltdown at Limerick Nuclear Plant could be astronomical, in 

terms of suffering, health care costs, and financial costs. 

• Off-site economic costs for multiple radiation accidents/meltdowns in 

Limerick's reactors and/or fuel pools, in the densely populated Greater 

Philadelphia region surrounding Limerick Nuclear Plant have not been 

accurately assessed by anyone.

• Millions of people would need temporary housing and/or permanent 

relocation. In today's economy and political dysfunction, the millions of people 

in the Greater Philadelphia Region who could lose everything would get no 

help.

• Costs for dealing with a Limerick disaster are estimated to be a trillion dollars, 

with taxpayers paying all but $12 billion.

• In addition to complete loss of property, possessions, businesses, and jobs, 

the short and long term health-care costs would be staggering. There would 

not even be enough treatment centers or hospitals to deal with the numbers 

of people who could end up with acute radiation poisoning or worse. In 

Japan, people, including children, were turned away because they were too 

radioactive.

NRC never bothered to address any of the public interest issues above in Limerick's DRAFT 

EIS. NRC is only considering costs to Exelon and Exelon's profits, NOT costs to the public for a 

Limerick accident/meltdown because NRC failed to require the safest accident mitigation

strategies. That is profoundly negligent!

IF NRC CONSIDERED DRASTIC INCREASES IN POPULATION, RELATED TO THE COSTS 

FOR LOSSES, NRC SHOULD COME TO THE CONCLUSION THAT IT IS JUST TOO RISKY 

TO CONTINUE TO OPERATE LIMERICK NUCLEAR PLANT.

In NRC's FINAL LIMERICK EIS, THE PUBLIC'S OFF-SITE COSTS FOR A LIMERICK 

RADIATION ACCIDENT/MELTDOWN MUST BE ACCURATELY ESTIMATED BY AN 

INDEPENDENT ECONOMIC EXPERT WHO UNDERSTANDS WHAT TOTAL RADIOACTIVE 

CONTAMINTION WOULD DO TO THE ENVIRONMENT AND THE POPULATION.

Comment: 5-14-PA; NRC's refusal to update Limerick's SAMA: 

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

Energy Institute), the powerful lobbying arm of the nuclear industry. The NRC has allowed the 

NEI to thus create more regulatory protection for the industry, which significantly weakens 

safety for the public. 

An example is the difficulty encountered by the NRDC, when it attempted to require an updated 

SAMA for Limerick. The NRC would not consider it. NRC's stubborn position is reinforced by 

the legal armature designed to preserve Limerick for financial reasons, without consideration of 

whether there's a need for nuclear energy. NRC stated its SAMA position in the federal register 

(2007): "Staff Position: The NRC staff recommends that applicants for license renewal follow the 

guidance provided in Nuclear Energy Institute (NEI) 0501, Severe Accident Mitigation 

Alternatives (SAMA) Analysis Guidance Document, Revision A, when preparing their SAMA 

analysis." 

In 2012, the NRC Commission refused the National Defense Resource Council's request 

(submitted in 2011) for an update of Limerick's SAMA on the grounds that the request was "an 

impermissible attack on our regulations".

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Comment: 30-4-PA; On page 5-4 of the GElS Supplement, the NRC discusses the 

Containment Performance Improvement (CPI) Program and the Individual Plant Examination 

(IPE), and in this discussion the GElS Supplement repeatedly states that the NRC relies on 

these programs in determining that Severe Accident Mitigation Alternatives (SAMAs) need not 

be performed at license renewal if the staff had already performed a SAMA review in an earlier 

NEPA document. The phrasing clearly implies that any new and significant information that 

may be discovered in the intervening years between initial licensing and the license renewal 

stage will have been adequately considered and should satisfy all requirements pursuant to 

NEPA, namely a thorough analysis of environmental impacts. However, the CPI, IPE, Individual 

Plant Examination of External Events (IPEEE), or any other accident management programs or

processes, cannot substitute for NEPA review under the legal precedent United States v. 

Coalition for Buzzards Bay, 644 F.3d 26, 38 (1st Cir. 2011), which rejected arguments that

alternative process can substitute for NEPA. In addition, the case Limerick Ecology Action, Inc. 

v. NRC, 869 F.2d 719, 729 (3rd Cir. 1989)) established that Atomic Energy Act procedures 

cannot substitute for compliance with NEPA.

Response: Several comments were made regarding the need to perform an updated SAMA

analysis. As provided in the introductory section of Section 5.3 of this SEIS, the Commission 

made the generic determination, codified in Table B-1 of Part 51 and 10 C.F.R. § 

51.53(c)(3)(ii)(L), that if the NRC had conducted a site-specific consideration of severe accident

mitigation alternatives (“SAMA”) for a plant in a previous EIS or environmental assessment 

(“EA”), another SAMA need not be done for license renewal. 

The Staff has previously performed a site-specific analysis of severe accident mitigation design 

alternatives (“SAMDA”) in a NEPA document for LGS in the Final Environmental Statement 

Related to Operation of Limerick Generating Station, Units 1 and 2, NUREG-0974 Supplement 

1 (ADAMS Accession No. ML112221A204)). Therefore, the applicant’s license renewal ER for 

Limerick and the Staff’s SEIS do not have to reassess the issue.

Importantly, this does not mean that the Commission only considers ways to mitigate severe 

accidents at a given site once. Instead, the Commission has considered alternatives for 

mitigating severe accidents at many sites, including Limerick, multiple times through a variety of 

NRC programs. Examples of these NRC programs include the containment improvement 

program, Individual Plant Examination, Individual Plant Examination of External Events, 

Accident Management Program, 10 CFR 50.54(hh) rulemaking Regarding Loss of Large Areas 

of the Plant Caused by Fire or Explosions, Severe Accident Mitigation Guidelines, and 

Fukushima-Related Activities. These NRC programs are described in sections 5.3.1 through 

5.3.8 of Chapter 5 of this FSEIS. 

Chapter 5 of Exelon’s ER also contained an evaluation of new information to determine whether 

it was significant as required by 10 CFR 51.53(c)(3)(iv). The assessment described in Section 

5.1 found no new and significant information that would change the small impact determination 

for severe accidents set forth in the GEIS (NRC, 1996a, Sec. 5.5.2). Also, the applicant 

determined that no new and significant information has been found that would change the 

generic conclusion codified by the NRC that LGS need not reassess severe accident mitigation 

alternatives for license renewal [10 CFR 51.53(c)(3)(ii)(L)].

Furthermore, the Staff’s independent evaluation of new and significant information is discussed 

in sections 5.3.9 through 5.3.17 of this Limerick SEIS. The Staff took a hard look at new 

information to determine if it was significant for purposes of the National Environmental Policy 

Act (NEPA). The Staff did not identify any new and significant information that would invalidate 

the 1989 Limerick SAMDA Analysis or the Commission’s generic conclusions in 

51.53(c)(3)(ii)(L). In making this determination, the NRC reasonably relied on the studies 

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mentioned above, among other things, to inform its analysis of SAMAs under NEPA. This is

discussed in sections 5.3.1 through 5.3.8 of Chapter 5 of this FSEIS. 

Comment: 30-38-PA; Exelon has omitted from its ER a required analysis of new and 

significant information regarding the potential new severe accident mitigation alternatives 

previous considered for other BWR Mark II Containment reactors. 

Response: Regarding this comment, the staff sent a letter dated February 12, 2014, to Exelon 

requesting additional information about potentially new SAMAs previously considered for other 

plants. The staff’s review of this information is provided in section 5.3.17 of the SEIS.

During the litigation on this issue the staff extensively discussed these claims and provided 

further analysis in its legal filings. The staff’s briefs to the Commission are available at 

ML13072A804 and ML13079A501 and provide the staff’s position on the issue. The 

Commission’s rulings on the issue are in CLI-12-19 (NRC 2012a) and CLI-13-07 (NRC 2013b).

Comment: 30-39-PA; Exelon’s reliance on data from TMI in its analysis of the significance on 

new information regarding economic cost risks constitute an inadequate analysis of new and 

significant information. 

The ER analysis of the significance of including information regarding the potential economic 

impact of a severe accident at Limerick erroneously relies on data from an analysis done at TMI, 

a site that involves a markedly different and less economically developed area than the area 

within 50 miles of Limerick, which includes the densely populated urban environments of 

Philadelphia, PA, Camden and Trenton, NJ and Wilmington, DE. The ER thus fails to evaluate 

the impact of a properly conducted economic analysis on the assessment of the environmental 

consequences of a severe accident at Limerick. 

The ER ignores new and significant information regarding the likely cost of cleanup from a 

severe accident in a metropolitan area like Philadelphia and thus understates the impact of a 

properly conducted economic analysis on the environmental consequences of a severe accident

at Limerick. 

Response: The staff’s review of this information is provided in section 5.3.12 and 5.3.13 of the 

SEIS. Since Limerick’s calculation was reasonable, more conservative than any of the 

population increase evaluations found in the GEIS, and mitigation alternatives as a result of

population increases are implemented in the current term, the staff find’s Limerick’s evaluation 

acceptable and population increases at Limerick are not new and significant information. 

Moreover, even if population increase led to another SAMA becoming cost beneficial, that 

SAMA would still not likely result in a substantial reduction in offsite risk, given the substantial 

reduction in CDF at Limerick since the 1989 SAMDA analysis.

During the litigation on this issue the staff extensively discussed these claims and provided 

further analysis in its legal filings. The staff’s briefs to the Commission are available at 

ML13072A804 and ML13079A501 and provide the staff’s position on the issue. The 

Commission’s rulings on the issue are in CLI-12-19 (NRC 2012a) and CLI-13-07 (NRC 2013b).

Comment: 30-40-PA; A legally sufficient analysis of newly identified severe accident mitigation 

alternatives for Limerick must utilize modern techniques for assessing whether those 

alternatives are cost-beneficial, and Exelon’s ER erroneously concluded that new mitigation

alternatives can be evaluated without use of those modern techniques. 

Response: The staff review of this comment determined that a modern SAMA analyses for 

LGS would be unlikely to uncover cost-beneficial major plant improvements or plant 

improvements that could substantially result in lower doses to offsite populations in the event of 

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a severe accident. The staff’s review of this information is provided in section 5.3.18 of the 

SEIS.

During the litigation on this issue the staff extensively discussed these claims and provided 

further analysis in its legal filings. The staff’s briefs to the Commission are available at 

ML13072A804 and ML13079A501 and provide the staff’s position on the issue. The 

Commission’s rulings on the issue are in CLI-12-19 (NRC 2012a) and CLI-13-07 (NRC 2013b).

Comment: 2-4-PA; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place.

......Number two, the National Resource Defense Council legal action appeals on Limerick's 

severe accident mitigation analysis requirements have been resolved. That's an open, legal 

issue...

Comment: 23-41-PA; Page 5-1, Postulated Accidents leads to 5.3 SAMA. I concur with NRDC. 

Response: The comments above are in support of the NRDC’s contentions and waiver petiton 

submitted regarding the need to perform an updated SAMA analysis. 

As provided in the introductory section of Section 5.3 of this SEIS, the Commission made the 

generic determination, codified in Table B-1 of Part 51 and 10 C.F.R. § 51.53(c)(3)(ii)(L), that if 

the NRC had conducted a site-specific consideration of SAMA for a plant in a previous EIS or

environmental assessment, another SAMA need not be done for license renewal. 

The staff has previously performed a site-specific analysis of SAMDA in a NEPA document for 

LGS in the Final Environmental Statement Related to Operation of Limerick Generating Station, 

Units 1 and 2, NUREG-0974 Supplement 1 (ADAMS Accession No. ML112221A204)). 

Therefore, the applicant’s license renewal ER for Limerick and the staff’s SEIS do not have to 

reassess the issue.

On October 31, 2013, the Commission issued order CLI-13-07 (ML13304B417), which denied 

NRDC’s waiver request but indicated that the issues raised in the NRDC’s waiver petition bear 

consideration in the staff’s environmental review of the Exelon’s application outside the 

adjudicatory process. The Commission referred the waiver petition to the Staff as additional 

comments on the Limerick DSEIS for the Staff’s consideration and response. The Commission 

also directed the Staff to review the significance of any new SAMA-related information in its 

environmental review of Exelon’s application, including information presented in the NRDC 

waiver petition, and to discuss its review in the FSEIS. The staff has reviewed all potentially 

new and significant SAMA-related information, including information presented in the NRDC 

waiver petition and discussed its review in Chapter 5 this SEIS as directed by the Commission 

in CLI-13-07. Additionally, the staff has considered the information in the NRDC waiver petition 

as public comments on the DSEIS and responded to these comments in Appendix A of this 

SEIS. 

Comment: 2-76-PA; Limerick is the 2nd most densely populated nuclear plant in the nation. 

Still, NRC is refusing to consider increased population and health risks associated with a 

Limerick Nuclear Plant accident/meltdown.

• Due to Limerick's location, the potential impact of a severe accident would be 

far greater than at most other U.S. nuclear plants (NRDC research).

• Over 8 million people live within 50 miles of Limerick, the radius NRC told 

Americans to evacuate in Japan during the Fukushima accident. 

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• 1.4 million people are now living downwind in the Philadelphia-WilmingtonNewark metropolitan area.

• In 1980 Limerick already had double the population density within 30 miles 

than could evacuate safely (NRC standard). Now the population density is 

four times higher.

Response: The issue regarding population growth around Limerick Generating Station is 

discussed in Section 5.3.2 in the SEIS. It should be noted that the NRC emphasizes the 

integration of safety, security, and emergency preparedness as the basis for the NRC's primary 

mission of protecting public health and safety (10 CFR 50.54(q), which contains the 

requirements for following and maintaining current emergency plans). To prepare for a 

radiological emergency, NRC developed regulations, guidance, and communications related to 

emergency preparedness for nuclear power plants which is summarized at 

http://www.nrc.gov/about-nrc/emerg-preparedness/regs-guidance-comm.html. 

Comment: 2-78-PA; 1974 Reactor Safety Study Published by NRC - Referred to as The 

Rasmussen Report[:]

• 45,000 Radiation Sickness Cases (Requiring Hospitalization)

• 3,300 Deaths (From Acute Radiation Sickness)

• 45,000 Fatal Cancers (over 50 years)

• 250,000 Non-Fatal Cancers (over 50 years)

• 190 Children Born With Birth Defects Per Year

Note: Non-Insurable Property Damage Was Estimated At $14 Billion

NRC's Estimated Consequences For An Accident (CRAC REPORT) For Limerick Nuclear 

Power Plant - Reported To Congress In 1982

 74,000 Early Fatalities

610,000 Early Injuries

 34,000 Cancer Deaths

Census Records From 1980 to 2010 Show That These Numbers Would Be Drastically Higher 

Today.

Our Population Increase Demands Updated, More Realistic Planning

Census Shows - From 1980 to 2010 (2000 and 2010 Census Data)

Numbers For Fatalities, Injuries, and Deaths Above Would Be Drastically Higher Today Due To 

A: FOUR-FOLD INCREASE IN POPULATION DENSITY SINCE 1980. 

LIMERICK'S 10-MILE EPZ Is The 2ND MOST DENSELY POPULATED In The U.S.

INFORMATION ABOVE RENDERS NRC'S CLAIMS IN LIMERICK'S DRAFT EIS - SAMA

PAGE 5-3 - MISLEADING, AND INDEFENSIBLE

It appears NRC will say anything to fool the public to save Exelon money.

• "Risks of early fatality from potential accidents at the site are small in 

comparison with risks of early fatality from other human activities in a 

comparably sized population."

• "The accident risk will not add significantly to population exposure and cancer 

risks." 

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• "Accident risks from Limerick are expected to be a small fraction of risks the 

general public incurs from other sources." THIS IS ABSURD!

• "Best estimates show risks of ... reactor accidents at Limerick are within the 

range of risks from other nuclear plants.”- THIS IS A MEANINGLESS 

COMPARISON.

Shame on NRC! This agency has lost all credibility!

• A Limerick Accident/Meltdown Could Cause A Catastrophe That Could 

Render The Entire Greater Philadelphia Region A Dead Zone For 

Generations.

• A Limerick Accident/Meltdown Is About High-Levels Of Radiation Exposure 

That We Can't See, Taste, Smell, Or Feel, But That Cause Radiation 

Sickness, Cancer, Death, And Impacts Into Future Generations.

Response: With respect to the commenter’s concern regarding calculations from the 

“Rasmussen Study” or “CRAC report,” the NRC has devoted considerable research resources, 

both in the past and currently, to evaluating accidents and the possible public consequences of 

severe reactor accidents. The NRC's most recent studies have confirmed that early research 

into the topic led to extremely conservative consequence analyses that generated invalid results 

for attempting to quantify the possible effects of very unlikely severe accidents. They often used 

unnecessarily conservative estimates or assumptions concerning possible damage to the 

reactor core, the possible radioactive contamination that could be released, and possible 

failures of the reactor vessel and containment buildings. These previous studies also failed to 

realistically model the effect of emergency preparedness. The NRC staff is currently pursuing a 

new state-of-the-art assessment of possible severe accidents as part of its ongoing effort to 

evaluate the consequences of such accidents. The State-of-the-Art Reactor Consequence 

Analyses (SOARCA) project incorporates the results of more than 25 years of research to 

analyze the realistic outcomes of postulated severe reactor accidents, even though it is 

considered highly unlikely that such accidents could occur. The SOARCA objective is to develop 

updated and more realistic analyses of severe reactor accidents by including significant plant 

changes and updates (e.g., system improvements, training and emergency procedures, and 

offsite emergency response) that plant owners have made, which were not reflected in earlier 

assessments conducted by the U.S. Nuclear Regulatory Commission (NRC). These plant 

changes also include recent enhancements in respone to the terrorist attacks on September 

11, 2001. 

NUREG/BR-0359, “Modeling Potential Reactor Accident Consequences,” describes the 

research and it can be access on the NRC’s public webiste at 

http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0359/

In light of these more recent analyses, these comments do not provide any new and significant 

information; therefore, no changes were made to the SEIS.

Comment: 7-1-PA; I'm concerned about an earthquake triggering one or more meltdowns at 

Limerick Nuclear Plant.

Comment: 5-15-PA; NRC’s refusal to update Limerick's earthquake analysis:

The Fukushima disaster began on March 11, 2011. Inexplicably, three months later, Exelon 

submitted its license renewal application for Limerick Nuclear Plant to the NRC.

NRC held a public meeting (9/22/11) to receive public comments on re-licensing Limerick. We 

were in the audience. A resident commented that she was still waiting for a response from the 

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Appendix A

NRC about Limerick's closest faults, reminding the NRC that Limerick was ranked third on the 

U.S. Earthquake risk list.

Through ACE, we saw a copy of the resident's response from NRC. The letter and the map 

focused on the Chalfont Fault (9 miles away) and the Ramapo Fault (17 miles away). The map 

was complex, but yellow and orange highlight indicated the faults and the fault network.

But we remembered hearing rumors that there was a fault under the plant, and the NRC's map 

was so hard to decipher that we decided to go to the Pottstown Library to see if there were any 

other maps there that would be easier to understand. Among the Limerick volumes lining a shelf 

in the archives, we found a decades-old Geologic Survey by Dames and Moore submitted to 

PECO in 1974. Within its pages we found a large fold-out map in color that clearly showed the 

Sanatoga Fault running under the proposed Limerick Nuclear Plant site. It did not show the 

Chalfont or Ramapo Faults, but it did show the Linfield Dike not far from the plant, as well as the 

line marked Quarry Splay close to the site.

In March 2012, when the NRC held a less formal NRC public meeting, we took a copy of the 

1974 Geologic Survey map that we had found in the Library to show to the NRC. The NRC 

Chief, Projects Branch 4, said he'd never seen it before and he referred us to the NRC official 

who was the author of the resident's response letter and map, who was also present. He had 

never seen the 1974 map before, either. It seemed that neither had ever even heard of the 

Sanatoga Fault. However, we were very surprised to hear the author of the letter off-handedly 

mention that the Ramapo Fault was active.

ACE had arranged a meeting with our local paper and we shared both maps and their 

respective stories with a reporter. It was weeks after the NRC meeting when the story finally 

broke, and it covered several pages. Both the Geologic Survey map and the resident's NRCprovided map were splashed across the front page. The paper was full of articles providing an 

excellent review of many renewed earthquake concerns, including fracking and quarry issues 

(an active blasting quarry shares its border with Limerick).

The newspaper reported that an NRC spokesperson's answer to the question of whether the 

NRC had considered the Sanatoga Fault when it licensed Limerick began with "The short 

answer is yes"....and went on. Missing from the story was what is always missing: the central 

issue at stake: the evasiveness of the NRC. Whenever there's an issue of import, like an 

unusual event or accident at Limerick, the NRC dusts up the story to create the impression that 

everything is under control.

Comment: 5-27-PA; To what degree is NRC allowing Modifications to Requirements for 

Mitigation Strategies for Beyond- Design-Basis External Events? (Issuance of Order: 3/13/12)

Response: These comments address issues related to the potential impacts of natural 

disasters on the plant. The potential impacts of natural disasters, such as earthquakes and 

hurricanes and the plant’s ability to continue to operate are addressed on an ongoing basis as 

part of the NRC’s current oversight process. These actions are being addressed independent of 

license renewal.

The NRC has directed licensees to perform a seismic re-evaluation using updated information. 

Operating reactor sites are using present-day information to re-evaluate the earthquake 

effects—or hazards—that could impact their site. These newly re-evaluated hazards, if worse 

than what the plant had originally calculated, will be analyzed to determine if plant structures, 

systems, and/or components need to be updated to protect against the new hazard. The NRC 

will review each step in the analysis process and take action to require plant changes as 

necessary.

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Additional information is provided at:

http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard/seismicreevaluations.html

Modifications to requirements for mitigation strategies for beyond design basis external events 

are evaluated on a plant by plant basis and are currently ongoing. Information regarding the 

Status of Limerick 1 and 2 is available at: 

http://www.nrc.gov/reactors/operating/ops-experience/japan/plants/lim1.html 

As discussed in section 5.3.15 of chapter 5, the Limerick SAMDA analysis contained very large 

conservatisms regarding seismic risk. Therefore, these comments do not provide any new and 

significant information; therefore, no changes were made to the SEIS.

Comment: 10-4-PA; Well, things are a lot better in the security state, but there's still some 

problems. But I want to point out one specific issue using their report and it's in Section 5.2. 

This will be the last thing I have to say. In Section 5.2 regarding severe accidents, they did an 

analysis of sabotage and said that core damage and radiological release from such acts would 

be no worse than the damage and release expected from internally-initiated events. Well, first 

of all, that wording should be changed. Internally initiated could indicate sabotage even from 

an insider. So that should be accidental events rather than internally. We're talking about 

sabotage versus accident. 

• From GEIS: With regard to sabotage, quantitative estimates of risk from 

sabotage are not made in external event analyses because such estimates 

are beyond the current state of the art for performing risk assessments. The 

commission has long used deterministic criteria to establish a set of 

regulatory requirements for the physical protection of nuclear power plants 

from the threat of sabotage, 10 CFR Part 73, "Physical Protection of Plants 

and Materials", delineates these regulatory requirements. In addition, as a 

result of the World Trade Center bombing, the Commission amended 10 CFR 

Part 73 to provide protection against malevolent use of vehicles, including 

land vehicle bombs. This amendment requires licensees to establish vehicle 

control measures, including vehicle barrier systems to protect against 

vehicular sabotage. The regulatory requirements under 10 CFR part 73 

provide reasonable assurance that the risk from sabotage is small. Although 

the threat of sabotage events cannot be accurately quantified, the 

commission believes that acts of sabotage are not reasonably expected. 

Nonetheless, if such events were to occur, the commission would expect that 

resultant core damage and radiological releases would be no worse than 

those expected from internally initiated events.

Based on the above, the commission concludes that the risk from sabotage and beyond design 

basis earthquakes at existing nuclear power plants is small and additionally, that the risks form 

other external events, are adequately addressed by a generic consideration of internally initiated 

severe accidents.

Although external events are not discussed in further detail in this chapter, it should be noted 

that the NRC is continuing to evaluate ways to reduce the risk from nuclear power plants from 

external events. For example, each licensee is performing an individual plant examination to 

look for plant vulnerabilities to internally and externally initiated events and considering potential 

improvements to reduce the frequency or consequences of such events. Additionally, as 

discussed in Section 5.4.1.2, as part of the review of individual license renewal applications, a 

site-specific consideration of alternatives to mitigate severe accidents will be performed in order 

A-135
Appendix A

to determine if improvements to further reduce severe accident risk or consequences are 

warranted.

The second and most important of what I'm saying is they say they could identify no issues that 

were greater than internally-initiated events. What if the containment building is no longer 

intact? What if the saboteurs found a way of nuclear transport -- there's that nuclear term, 

engineering term -- of radioactive material outside the containment building during a sabotage 

event. Well, that happened at Three Mile Island, not from sabotage, but the valves in the 16 

drain were already lined up, where radioactivity was escaping the building early.

Response: A complete discussion of what is meant by internally-initiated events in the context 

of sabotage is provided on page E-7 to E-8 of GEIS Rev. 1.

In this context, internal events refer to initiating events such as a loss of feedwater. If the loss of 

feedwater occurs because of sabotage or catastrophic failure, the plant effect is the same. 

Also, as provided in the SEIS, comprehensive deterministic criteria in regulatory requirements 

are established for the physical protection of nuclear power plants from the threat of sabotage. 

Further information on NRC’s actions regarding sabotage is available at: 

http://www.nrc.gov/security/post-911.html. 

As explained in section 5.2 of Chapter 5, the NRC has concluded that the threat of sabotage is 

too remote and speculative for consideration under a NEPA analysis, and the Third Circuit Court 

of Appeals has upheld this view. However, the NRC will continue to evaluate terrorist acts for 

all nuclear facilities through the ongoing regulatory process that affects all nuclear facilities. 

These comments do not provide any new and significant information; therefore, no changes 

were made to theSEIS.

Comment: 25-1-PA; P. R. A. Probable risk assessments are used to emphasize the 

likelihood that the plant will survive for a specific period. PRA demand the conclusion that 

enough plants operating long enough will suffer a devastating and 'beyond design basis 

accident.' The public does not see the dark side of the PRA analysis!

The accidents at TMI#2 and Chernobyl and Pleasantville (AKA Fukushima) demonstrate the 

above.

Response: One of the Nuclear Regulatory Commission’s key responsibilities is to ensure the 

operation of nuclear power plants and other NRC-licensed facilities present no undue risk to 

public health and safety. The agency does this by applying and enforcing a set of technical 

requirements on plant design and operations, described in 10 CFR Part 50. Generally, these 

are written in terms of traditional engineering practices such as “safety margins” in design, 

construction, and operations. Probabilistic risk assessment (PRA) systematically looks at how 

the pieces of a complex system work together to ensure safety. PRA allows analysts to quantify 

risk and identify what could have the most impact on safety. A fact sheet regarding PRA is 

provided at: 

http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/probabilistic-risk-asses.html

Note that consideration of risk is an important element of decisionmaking at the NRC to 

determine adequate protection of the health and safety of the public. In short, this requires an 

assessment of the probabilities and consequences of a particular risk, as well as a hard look at 

whether concerns raised in a proposal are based on realistic assumptions, or real world safety, 

security, or legal issues. The “adequate protection” standard does not mean "zero risk.” The 

NRC does not have a technical or legal basis to ever try and achieve zero risk in a given area. 

Therefore, determining how much risk is acceptable is a critical function of the NRC. 

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Appendix A

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS.

A.2.17 Radiological Waste (RW)

Comment: 2-13-RW; For NRC to claim that all power generating facilities generate similar 

wastes is another lie. You stated “the generation of spent fuel and waste material including lowlevel radioactive waste, hazardous waste, and nonhazardous waste would also be generated at 

non-nuclear power generating facilities.” Really?

Comment: 2-33-RW; High-level and low-level radioactive waste issues have not been 

adequately addressed.

NRC does no testing. No independent agency ever did long-term monitoring for all the 

radionuclides associated with Limerick operations. But when the National Academy of Sciences 

says there is no safe level of exposure, the kinds and levels are not as important as the fact that 

almost two million people are always exposed to radiation in their water from Limerick.

Comment: 2-82-RW; LOW-LEVEL DOES NOT MEAN LOW RISK.

LIMERICK NUCLEAR PLANT'S “SO-CALLED” LOW-LEVEL RADIOACTIVE WASTES CAN

TAKE AS LONG AS 500 YEARS TO FADE TO NATURAL [BACKGROUND] LEVELS.

NRC FAILS TO TRACK VOLUME OF LOW-LEVEL RADIOACTIVE WASTES PRODUCED AT 

LIMERICK EACH YEAR. IN MARCH 2013 AN NRC OFFICIAL TOLD ACE THAT TRACKING 

THE VOLUME OF LIMERICK'S LOW-LEVEL RADI[OA]CTIVE WASTE ISN'T IMPORTANT. 

WE DISAGREE!

 IF NRC DOESN'T KNOW HOW MUCH IS PRODUCED, NRC CAN'T 

CONFIRM WHAT HAS HAPPENED WITH ALL OF THE MASSIVE LOWLEVEL RADIOACTIVE WASTES PRODUCED AT LIMERICK NUCLEAR 

PLANT.

 PROBLEM: EXELON COULD STILL BE BURNING SOME OF LIMERICK'S 

LOW-LEVEL RADIOACTIVE WASTES IN LIMERICK'S BOILER “A” 

WITHOUT NRC'S KNOWLEDGE.

NRC HAS NO ACCURATE IDEA HOW MUCH LOW-LEVEL RADI[OA]CTIVE WASTE IS

PRODUCED AT LIMERICK EACH YEAR OR WHERE IT IS GOING.

 WE HAVE NO CONFIDENCE NRC HAS ANY IDEA WHAT EXELON IS 

DOING WITH ALL OF[ ]LIMERICK'S MASSIVE LOW-LEVEL RADIOACTIVE 

WASTES.

 NRC'S STATEMENTS AND NEWS REPORTS DON'T MATCH LOW-LEVEL 

RAD-WASTE DESTINATIONS REPORTED BY EXELON ON NRC'S 

WEBSITE (SIMPLY AS NUMBERS OF TRAIN OR TRUCK SHIPMENTS).

 JANUARY 2010, EXELON GOT PERMISSION TO SHIP LIMERICK'S LLRW 

TO PEACH BOTTOM. MARCH 2013 NRC TOLD US LIMERICK'S LLRW 

WAS SHIPPED TO PEACH BOTTOM. YET, NO SHIPMENTS WENT TO 

PEACH BOTTOM AT ALL IN 2010, 2011, OR 2012, ACCORDING TO 

NRC'S WEBSITE.

PROBLEM: NRC HAS BEEN DECEIVING US ABOUT INCINERATION OF LOWLEVEL

RADIOACTIVE WASTES AT LIMERICK NUCLEAR PLANT.

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Appendix A

 SINCE 2009, NRC HAS BEEN DENYING THAT LIMERICK EVER BURNED 

LOW-LEVEL RADIOACTIVE WASTES.

 MARCH 2013 AN NRC OFFICIAL FINALLY ADMITTED WHAT WE 

SUSPECTED FROM REVIEWING LIMERICK'S AIR POLLUTION PERMIT 

IN 2009 - THAT EXELON BURNED LOWLEVEL RADIOACTIVE WASTES 

AT LIMERICK.

INCINERATING ANY OF LIMERICK'S LOW-LEVEL RADIOACTIVE WASTES IS NOT AN

ACCEPTABLE OPTION, ESPECIALLY IN THIS HEAVILY POPULATED REGION WHERE

THERE IS ALREADY A HEALTH CRISIS.

 BURNING RADIOACTIVE WASTES DOES NOT DESTROY THE 

RADIONUCLIDES, BUT INSTEAD DISPERSES THEM IN SUCH A WAY 

THAT THEY ARE MORE EASILY INHALED, INCREASING THREATS TO 

HEALTH FROM THE INTERNAL RADIATION EXPOSURE, THE MOST 

DANGEROUS EXPOSURE.

 POTENTIAL HARMS FROM BURNING LIMERICK'S LOW-LEVEL 

RADIOACTIVE WASTES MUST BE INCLUDED IN LIMERICK'S FINAL EIS 

FOR RELICENSING.

Comment: 2-83-RW; EXELON IS CLAIMING THEY WON'T CONTINUE TO BURN 

LIMERICK'S LOW-LEVEL RADI[OA]CTIVE WASTES, BUT:

 EXELON'S TRACK RECORD SHOWS WHY WE CAN'T BELIEVE OR 

TRUST EXELON

 NRC HAS NO SYSTEM IN PLACE TO ACCURATELY CONFIRM WHAT IS 

BEING DONE WITH ALL LIMERICK LOW-LEVEL RADIOACTIVE WASTE.

NRC HAS NO LONG-RANGE PLAN FOR WHAT WILL BE DONE WITH ALL LIMERICK'S

MASSIVE LOW-LEVEL RADIOACTIVE WASTES UNTIL LIMERICK'S CURRENT LICENSE IN 

2029.

 NRC CANNOT JUSTIFY RELICENSING LIMERICK FOR 20 YEARS

BEYOND 2929 WHEN THERE IS NO SAFE PLACE TO STORE ALL THE 

LOW-LEVEL RADIOACTIVE WASTE THAT WILL BE PRODUCED.

 THERE IS NO ROOM AT LIMERICK TO STORE THE LLRW THAT MUST 

BE KEPT AWAY FROM PEOPLE FOR UP TO 500 YEARS,

 PEACH BOTTOM CANNOT CONTINUE TO TAKE LIMERICK'S WASTES 

FOR DECADES. NRC SAID THERE IS NO PLAN TO TAKE LIMERICK'S 

WASTES TO PEACH BOTTOM FOR MORE THAN ONE YEAR AT A TIME.

 THE NATION IS RUNNING OUT OF ROOM TO STORE LOW-LEVEL 

RADIOACTIVE WASTES AT THE FEW SITES DESIGNATED IN OUR 

NATION TO STORE IT.

RECYCLING CANNOT BE AN OPTION EXPOSING PEOPLE TO RECYCLED RADIOACTIVE 

WASTES IN THEIR PRODUCTS SUCH AS BELT BUCKLES, DISHES, AND BABY 

CARRIAGES INCREASES HEALTH THREATS AND COSTS. IT IS SHAMEFUL AND 

NEGLIGENT.

RECYCLING RADIOACTIVE WASTES CAN BE COSTLY TO BUSINESSES. FOR EXAMPLE, 

THE BED, BATH, AND BEYOND RECALL ON RADIOAC[TI]VE TISSUE HOLDERS.

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Appendix A

Comment: 5-9-RW; High-level radioactive waste storage. Tons are produced at Limerick 

every year, remaining deadly virtually forever. The public cost is in higher taxes. And we are 

charged for it to be stored at Limerick.

Comment: 23-14-RW; Minimize means it is still there but may be less. P. 2-1 line 36

Comment: 23-15-RW; Keep in mind the National Academy has said there is no safe level of 

exposure to ionizing radiation. P. 2-1 line 39 stuff are about minimizing, controlling, meeting 

standards that allow exposure etc. ALARA is a laugh. Calculate p. 2-2 line 9 – not prevent, not 

measure but calculate (how??) Objective is to limit releases [p.] 2-2 line 13. Not stop but limit. 

P. 2-2 line 23 Reduce to ALARA. I mean really, this all very silly but very scary.

Comment: 23-16-RW; Waste from laundry P. 2-2 line 38. Does it stay in the same tank 

forever? What happens to it?

Comment: 23-18-RW; P. 2-6 line 9- a favorite line “diluted with air,” it[’]s still there. P. 2-6 line 

18 permanent disposal. There is no such thing as permanent disposal or permanent – just 

moving it around.

Comment: 23-19-RW; Another favorite, p. 2-7 line 33 “using corporate procedures” What are 

they?

Comment: 23-20-RW; Exelon want uprates. Keep that in mind. What is now may differ with 

uprates. Line 34 p. 2-8 “... does not expect...” nicely vague.

Comment: 27-3-RW; They are polluting our air and water and we in Pottstown and 

surrounding areas are paying the price.

Comment: 29-1-RW; As it relates to management and disposal of LLRW, Exelon has received 

approval from the NRC for storage of LGS LLRW at the Peach Bottom Atomic Power Station 

(PBAPS) in Delta, PA. The NRC consulted with DEP prior to approval of Exelon's request. 

Considering the lack of an interim LLRW storage facility at the LGS, the small number of 

shipments, and the existing capacity of the interim LLRW storage facility at the PBAPS, DEP 

determined that the transfer of LLRW from LGS to PBAPS would not pose any danger to public 

health, safety or the environment. However, DEP stated that it expects Exelon to immediately 

cease shipments of LLRW from LGS to PBAPS when a disposal facility for Class B and C 

wastes becomes available. The new Waste Control Specialists facility in Texas is now fully 

operational and, as such, Exelon has confirmed that they will begin shipments of LGS LLRW to 

the Texas facility and halt future shipments of LLRW from LGS to PBAPS.

Response: All nuclear plants were licensed by the NRC with the expectation that they would 

generate, store, and release radioactive material to both the air and water during normal 

operation. Airborne and liquid releases of radionuclides from nuclear power plants must meet 

radiation dose-based limits specified in NRC’s 10 CFR Part 20, the ALARA criteria in 10 CFR 

Part 50, Appendix I, and EPA’s 40 CFR Part 190. Regulatory limits are placed on the radiation 

dose that members of the public might receive from all of the radioactive material released by 

nuclear plants. Licensees are required, on an annual basis, to report the amount and type of 

radioactive liquid and gaseous effluents discharged into the environment as well as the amount 

of solid radioactive waste shipped for disposal. In addition, licensees must report the results of 

their REMPs annually to the NRC. The annual effluent release and radiological environmental 

monitoring reports submitted to the NRC are available to the public through the ADAMS 

electronic reading room available through the NRC website (www.NRC.gov).

The NRC provides continuous oversight of each plant under the NRC’s inspection and 

enforcement programs. The NRC’s ROP integrates the NRC’s inspection, assessment, and 

enforcement programs. The operating reactor assessment program evaluates the overall safety 

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performance of operating commercial nuclear reactors and communicates those results to 

applicant management, members of the public, and other government agencies. The 

assessment program collects information from inspections and performance indicators in order 

to enable the NRC to arrive at objective conclusions about an applicant’s safety performance. 

Based on this assessment information, the NRC determines the appropriate level of agency 

response. The NRC conducts followup actions, as applicable, to ensure that the corrective 

actions designed to address performance weaknesses were effective. While the NRC 

maintains regulatory oversight of LGS, it is the responsibility of LGS’s management to ensure 

that plant operation complies with NRC requirements at all times.

NRC regulation 10 CFR 20.2004, “Treatment or disposal by incineration,” allows for the 

incineration of contaminated waste oil. However the radioactive effluent releases must be 

added to the plant’s radioactive gaseous effluents, and the dose to members of the public must 

be within NRC dose limits. In addition, LGS must report, in its annual radioactive effluent 

release report, the total radioactive emissions from this disposal method. While LGS is allowed 

to use incineration to dispose of its contaminated waste oil, the NRC staff reviewed LGS’s 

annual radioactive effluent release reports for the years 2007staffto 2011 and found no 

instances when contaminated waste oil was incinerated. The NRC staff’s review of the LGS’s 

2011 annual radioactive effluent release report (ADAMS Accession No. ML12129A391) found 

that LGS officially eliminated the option to incinerate contaminated waste oil. This action was 

taken when the LGS plant manager approved the change to the LGS Offsite Dose Calculation 

Manual which removed the option to burn contaminated waste oil in the plant’s auxiliary boiler 

system. This action by the LGS plant manager prevents the burning of contaminated waste oil. 

As discussed in the previous paragraph, the NRC inspectors periodically review LGS’s 

radiological programs to ensure compliance with NRC requirements and LGS’s procedures and 

program requirements.

In Chapter 4 of this SEIS, the NRC staff reviewed LGS’s radioactive waste management 

program and environmental monitoring programs to determine the potential impacts of renewing 

the LGS operating licenses. The NRC staff concluded that the impacts to human health would 

be SMALL.

These comments do not provide any new and significant information; therefore, no changes 

were made to the SEIS in response to these comments.

Comment: 2-6-RW; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place.

...Number four, NRC's court-ordered high level radioactive waste study has been completed, 

2014 or later, and all waste storage issues and rules are in effect, including for Limerick....

Comment: 2-78-RW; NRC'S DRAFT EIS HAS FAILED TO ADEQUATELY ADDRESS THE 

SITE SPECIFIC ENVIRONMENTAL IMPACTS OF THE MASSIVE AMOUNTS OF HIGHLEVEL 

RADIOACTIVE WASTES CURRENTLY STORED IN FUEL POOLS AND CASKS ON THE 

LIMERICK SITE, AND THE IMPACTS OF THE FUTURE PRODUCTION OF LIMERICK'S 

HIGH-LEVEL RADIOAC[TI]VE WASTES DURING LIMERICK'S RELICENSING PERIOD.

What could possibly have more of an impact on the future environment of the entire Greater 

Philadelphia Region than storing more and more of the most deadly materials on earth in fuel 

pools (like Fukushima's) and above ground casks that can eventually leak?

 Devastating Long-Term Environmental Impacts Can Result From Storing Or

Transporting Limerick's High-Level Radioactive Wastes.

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Appendix A

 NRC's DRAFT EIS Fails To Adequately Address Specific Environmental 

Impacts of The Massive Amounts Of High-Level Radioactive Wastes 

Currently In Limerick's Fuel Pools and Casks.

A New Review Of Limerick's Spent Fuel Storage Is Imperative BEFORE Limerick's EIS DRAFT 

Is Finalized. There Are Many Unanswered Questions With Serious Implications For 

Devastating Environmental Consequences For Generations, If Not Forever.

What could have more impact on the future environment of the entire Greater Philadelphia 

Region than storing massive amounts of the most deadly materials on earth, in corroding and 

thinning fuel pools, originally made with substandard cement, and extremely vulnerable to 

meltdowns from earthquakes and terrorist strikes with planes and missiles (like Fukushima's, 

high above reactors with no containment)?

 NRC's decision to allow Exelon to avoid an assessment of environmental 

impacts from all the deadly high-level radioactive wastes stored on the 

Limerick site until after the EIS is approved for relicensing, is really about 

protecting Exelon's interests, not public interests.

 There is NO NEED to rush Limerick's relicensing, when its original license 

doesn't expire for over a decade, another 11 years.

 Given the extreme dangers and destruction faced by the entire Greater 

Philadelphia from Limerick's high-level radioactive waste storage at Limerick, 

NRC would be negligent to ignore the unprecedented threats to the 

environment and population in Limerick's Environmental Impact

Comment: 2-79-RW; NRC STATEMENT IN LIMERICK'S APRIL 2013 DRAFT EIS “If the 

results of the Waste Confidence Decision EIS identify information that requires a supplement to 

the EIS, the NRC staff will perform any appropriate additional NEPA review for those issues 

before NRC makes a final licensing decision.” (6-3)

THAT MAKES NO SENSE AND IS UNACCEPTABLE FOR TWO REASONS

1. THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK'S FINAL EIS BEFORE

2014, WHEN NRC'S COURT-ORDERED STUDY IS COMPLETED. LIMERICK'S 

FIRST LICENSE DOES NOT EXPIRE UNTIL 2024, A DECADE AWAY.

It is unacceptable for NRC to finalize Limerick Nuclear Plant's EIS prior to finalization of 

NRC's Court-Ordered Waste Confidence Rules, which will not occur until 2014. The 

U.S. Court of Appeals for the D.C. Circuit found that an Environmental Impact Statement 

needed to add additional discussions concerning the impacts of failing to secure 

permanent disposal of spent nuclear fuel, and concerning the impacts of certain aspects 

of fuel pool leaks and fires.

2. THERE ARE MAJOR UNADDRESSED AND UNANSWERED SPECIFIC CONCERNS

ABOUT CURRENT STORAGE OF LIMERICK'S HIGH-LEVEL RADIOACTIVE 

WASTES, ESPECIALLY THE WASTE CURRENTLY STORED IN LIMERICK'S FUEL 

POOLS.

NO FINAL LIMERICK EIS SHOULD BE COMPLETED UNTIL AFTER NRC'S WASTE

CONFIDENCE RULING HAS BEEN FINALIZED AND ALL LIMERICK SPECIFIC HIGHLEVEL

RADIOACTIVE WASTE ISSUES HAVE BEEN COMPLETELY ANSWERED AND

ADDRESSED.

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Appendix A

IT WOULD BE PREMATURE AND ABSOLUTELY INAPPROPRIATE TO ISSUE LIMERICK'S 

FINAL EIS WITHOUT INCLUDING THE RULING FROM THE COURT-ORDERED WASTE 

STUDY, AND WITHOUT ANSWERING IMPORTANT QUESTIONS AND CONCERNS.

Comment: 2-80-RW; Spent Fuel Pools- A Ca[ta]strophe Waiting to Happen

 Limerick’s Fuel Pools are OVERLOADED with massive amounts of high level 

radioactive waste rods, Wastes held in pools exceed design basis

 Large volumes of Limerick’s high level produced since Limerick started 

operating in 1985 are stored in limerick pool

 Fuel Pool are corroding and thinning faster than expected

 Pools are filled with radioactive fluids that are threatening to boil away, 

introducing radiation into the air. 

 Pools are outside the reinforcement containment structures for the reactors.

Comment: 2-81-RW; THERE IS NO SAFE SOLUTION FOR LIMERICK'S HIGH-LEVEL

RADIOACTIVE WASTES.

 Facts About Limerick's Dangerous Deadly High-Level Radioactive[ ]Wastes 

Show The Only Logical Solution Is To Stop Making It.

 LIMERICK SHOULD BE CLOSED AS SOON AS POSSIBLE, NOT 

RELICENSED. EACH YEAR LIMERICK OPERATES MANY TONS MORE 

OF LIMERICK'S DEADLY HIGH-LEVEL RADI[OA]CTIVE WASTES WILL BE 

PRODUCED. THREATS WILL OBVIOUSLY INCREASE IF LIMERICK IS 

RELICENSED.

 LIMERICK'S RADIOACTIVE WASTES ALREADY PRODUCED NEED TO 

BE STORED ON SITE SAFER.

 NRC CANNOT JUSTIFY IGNORING LIMERICK SPECIFIC 

ENVIRONMENTAL IMPACTS FROM LIMERICK'S MASSIVE AMOUNTS OF 

HIGH-LEVEL RADIOACTIVE WASTES.

 NRC'S FINAL EIS FOR LIMERICK NUCLEAR PLANT SHOULD NOT BE 

COMPLETED UNTIL AFTER NRC'S COURT-ORDERED HIGH-LEVEL 

RADIOACTIVE WASTE STUDY IS COMPLETED IN 2014 AND THE 

RESULTING ACTIONS ARE APPLIED TO LIMERICK.

 THE OUTCOME OF NRC'S COURT-ORDERED HIGH-LEVEL 

RADIOACTIVE WASTE STUDY MUST BE INCORPORATED INTO 

LIMERICK'S FINAL EIS, REGARDLESS OF THE LENGTH OF TIME 

REQUIRED.

 THERE IS NO NEED TO RUSH TO COMPLETE LIMERICK'S EIS FOR 

RELICENSING, WHEN LIMERICK'S FIRST LICENSE DOES NOT EXPIRE 

FOR OVER A DECADE.

Comment: 5-28-RW; Is the NRC conducting a substantive “waste confidence study” that 

protects the public or, as we fear, relying on its phone conference with Exelon?

We hope it is not taking Exelon's word for how it is coping with the substandard containment, or 

protecting the above-ground storage from a terrorist attack, or providing for backup power in 

case of extended power outages to cool the fuel pools.

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NRC officials told us at a meeting in 2013, that they rely on Exelon to take care of that and they 

couldn't tell us anything about waste-storage issues.

Comment: 18-2-RW; How is it in the public interest, for example, to attempt to assess the 

environmental impact of relicensing Limerick Generating Station when we don’t know the results 

of the spent fuel study? And we won’t know the results until some time in 2014.

Comment: 23-8-RW; New also is the above-ground storage of spent nuclear fuel. That 

certainly wasn't here before and that certainly presents a huge danger to us all. And I might add 

the public hearing on that was held in the context of whether they could put cement pads in a 

certain zoning district.

New rules about spent fuel may be released in 2014, so this relicensing is obviously premature. 

The whole document is full of things like the term “permanent disposal.” There is no such thing 

as permanent disposal.

Comment: 23-40-RW; page 4-50 line 39, spent fuel storage. New since LNPP began, a de 

facto HLW dump. What rules govern it? Limerick township zoning? And Building codes? Who 

has liability?

Comment: 28-1-RW; EPA concluded this rating in part due to deficient information on the 

potential environmental impact associated with the onsite disposal of spent fuel subsequent to 

the decommission of Units 1 and 2. Section 6 of the draft generic EIS provides information on 

impacts associated with spent fuel both “Onsite and Offsite”; however, it does not provide 

sufficient detail of potential environmental impacts of onsite storage subsequent to reactor

decommissioning. EPA recommends that the Final EIS address this aspect of the project’s 

future activities.

Comment: 29-2-RW; Regarding the storage of spent nuclear fuel at the LGS site, DEP has 

publicly expressed concerns about long-term storage of spent nuclear fuel at the reactor sites. 

We encourage the NRC to continue with the timely development of an environmental impact 

statement, as part of its Waste Confidence decision and rule, to account for the long-term 

storage of spent nuclear fuel and high-level radioactive waste and associated transportation. 

The Commonwealth of Pennsylvania has been and continues to be a strong advocate for the 

Department of Energy's creation of a permanent repository for disposal of spent nuclear fuel 

and high-level radioactive waste.

Comment: 30-5-RW; In the GElS Supplement Section 6, the NRC states[,] “There are no 

Category 2 issues related to the fuel cycle and waste management[”] (page 6-1, line 19). The 

implications of this determination for the fuel cycle and solid waste management are that 

storage, transportation and offsite radiological risk associated with spent nuclear fuel are 

independent of the proximity and size of populations in the region of LGS spent nuclear fuel 

storage, or the sizes of populations along roads or rail lines if spent nuclear fuel is transported 

offsite from LGS. In Section 5 of the GElS Supplement, Exelon estimates that the population 

within 50 miles of LGS is projected to increase to 9,499,925 in the year 2030 (page 5-9, lines 7-

8). This population estimate, which includes portions of the Philadelphia metropolitan area, 

shows that LGS is an outlier among US nuclear power plants in terms of having large nearby 

populations. Therefore fuel cycle and solid waste management issues cannot be analyzed 

generically for LGS. The draft GElS Supplement should re-analyze fuel cycle and solid waste 

management on a site-specific basis with respect to evaluating the risks and consequences of 

extending the operating licenses for LGS.

Comment: 30-6-RW; Despite the fact that the NRC has determined that fuel cycle and solid 

waste management are category I issues, the NRC did examine site-specific impacts in the 

GElS Supplement with respect to the potential for new and significant information: “the staff did 

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Appendix A

not find any new and significant information related to the remaining uranium fuel cycle and 

solid waste management issues listed in Table 6-1 during its review of the Limerick Generating

Station environmental report (ER) (Exelon 2011), the site visit, and the scoping process.

Therefore, there are no impacts related to these issues beyond those discussed in the GElS. 

For these Category 1 issues, the GElS concludes that the impacts are SMALL, except for the 

issue, “Offsite radiological impacts (collective effects),” which the NRC concluded are 

acceptable[”] (page 6-2, lines 8-14)[.] As discussed in the GElS Supplement Section 1, “The 

NRC's standard of significance for impacts was established using the Council on Environmental 

Quality (CEQ) terminology for “significant.” The NRC established three levels of significance for 

potential impacts: SMALL, MODERATE, and LARGE[”] (page 1-4, lines 6-8). NRDC notes that 

the impacts for the fuel cycle issue “Offsite radiological impacts (collective effects)” has not been 

evaluated using the three levels of significance which the NRC has established. NRDC 

comments that the NRC should clarify the impacts of “[Offsite] radiological impacts (collective 

effects)” in terms of SMALL, MODERATE or LARGE impacts, and describe the basis for this 

categorization of the risk.

Comment: 30-7-RW; Regarding the June 2012 U.S. Court of Appeals for the District of 

Columbia Circuit's decision to vacate the NRC's Waste Confidence Decision (WCD) Update 

(State of New York, et al. v. NRC, 681 F.3d 471 (D.C. Cir. 2012)) that has forced the NRC to 

develop an Environmental Impact Statement (EIS), in Section 6 of the GElS Supplement NRC 

states that: “If the results of the WCD EIS identify information that requires a supplement to this 

EIS, the NRC staff will perform any appropriate additional NEPA review for those issues before 

the NRC makes a final licensing decision.” NRDC comments that the potential environmental 

impacts defined by a future WCD EIS could plausibly be LARGE and be a deciding factor in the 

federal government's decision as to whether or not to extend the operating licenses of the two 

reactors at LGS. Exelon's ER and the draft GElS supplement does not now include an analysis 

of the environmental impacts caused by the storage of nuclear waste at Limerick following the 

end of the requested operating license nor does it contain an analysis of the environmental 

effects of failing to establish a repository (and thus the necessity of a site specific review of 

indefinite storage of spent fuel). The absence of such an analysis violates NEPA and related 

regulations. Because neither the ER nor the GElS (NUREG-1437), nor the NRC in any other 

context has examined these impacts, and because, as reiterated in the GElS supplement, the 

United States Court of Appeals for the District of Columbia Circuit vacated the findings and 

regulations that NRC relied on to bar consideration of such impacts in license renewal, such 

analysis is now required to satisfy the requirements of NEPA for license extension at LGS. 

Furthermore, since these nuclear waste impacts are an intrinsic part of the NEPA analysis 

required to support a Commission decision on license renewal, and this analysis is missing from

the draft circulated for public comment that we are commenting on today, this draft GElS

Supplement should be reissued and recirculated for public comment when this missing analysis 

becomes available.

Response: The NRC is committed to ensuring that both SNF and low-level radioactive wastes 

are managed to prevent health impacts to the public. Spent nuclear fuel is currently stored at 

LGS in its spent fuel pool and in its ISFSI. This practice is expected to continue until DOE is 

ready to take possession of the SNF. At this time, it is uncertain when this will happen. 

The NRC is aware that a repository for SNF may not be available in the time frame that it was 

originally envisioned. Historically, the NRC’s Waste Confidence Decision and Rule represented 

the Commission’s generic determination that spent fuel can continue to be stored safely and 

without significant environmental impacts for a period of time after the end of a reactor’s 

licensed life for operation. This generic determination meant that the NRC did not need to 

consider the storage of spent fuel after the end of a reactor’s licensed life for operation in NEPA

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Appendix A

documents that supported its reactor and spent fuel storage application reviews. The NRC first 

adopted the Waste Confidence Decision and Rule in 1984. The NRC amended the Decision 

and Rule in 1990, reviewed it in 1999, and amended it again in 2010 (49 FR 34658 and 34694; 

55 FR 38474; 64 FR 68005; and 75 FR 81032 and 81037). The Waste Confidence Decision 

provided a regulatory basis and NEPA analysis to support the Waste Confidence Rule (10 CFR 

51.23). 

On December 23, 2010, the Commission published in the Federal Register a revision of the 

Waste Confidence Rule, supported again by a Waste Confidence Decision, to reflect 

information gained from experience in the storage of spent fuel and the increased uncertainty in 

the siting and construction of a permanent geologic repository for the disposal of spent nuclear 

fuel and high-level waste (75 FR 81032 and 81037). In response to the 2010 Waste Confidence 

Rule, the States of New York, New Jersey, Connecticut, and Vermont—along with several other 

parties—challenged the Commission’s NEPA analysis in the decision, which provided the 

regulatory basis for the rule. On June 8, 2012, the United States Court of Appeals, District of 

Columbia Circuit in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012) vacated the NRC’s Waste 

Confidence Rule, after finding that it did not comply with NEPA.

In response to the court’s ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it 

would not make final decisions for licensing actions that depend upon the Waste Confidence 

Rule until the court’s remand is appropriately addressed. The Commission also noted that all 

licensing reviews and proceedings should continue to move forward. In addition, the 

Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC staff proceed 

with a rulemaking that includes the development of a generic EIS. 

The generic EIS, which provides a regulatory basis for the revised rule, would provide NEPA

analyses of the environmental impacts of spent fuel storage at a reactor site or at an away-fromreactor storage facility after the end of a reactor's licensed life for operation ("continued 

storage"). As directed by the Commission, the NRC will not make final decisions regarding 

renewed license applications until the court’s remand is appropriately addressed. This will 

ensure that there would be no irretrievable or irreversible resource commitments or potential 

harm to the environment before the impacts of continued storage have been appropriately 

considered. 

On September 13, 2013, the NRC published a proposed revision of 10 CFR 51.23 (i.e., the 

Waste Confidence Rule), which, if adopted as a final rule, would generically address the 

environmental impacts of continued storage (78 FR 56776). The NRC also prepared a draft 

generic EIS to support this proposed rule (NRC 2013b) (78 FR 56621). The final rule is 

scheduled to be published by October 2014. Upon issuance of the final rule and GEIS, the 

NRC staff will consider whether additional NEPA analysis of continued storage is warranted 

before taking any action on the LGS license renewal application. 

The impacts associated with onsite storage of SNF are discussed in Chapter 6 of the SEIS.

These comments do not provide any new and significant information; therefore no changes 

were made to the SEIS. 

Comment: 32-1-RW; Page 2-6, Lines 12 to[ ]13, Section 2.1.2.2. Clarify the sentence that 

reads “Discharge of these gases are planned, monitored, controlled, and discharged through 

the south stack” by changing it to read as follows (see LGS ER page 3-18, 3rd para.): 

“Discharge of these gases are is planned, monitored, and controlled. and All are discharged 

through the north stack, except those from the reactor enclosures, which are discharged 

through the south stack.” 

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Appendix A

Comment: 32-2-RW; Page 2-6, Lines 14 to 15, Section 2.1.2.2. Clarify the sentence that 

reads “The standby gas treatment system (SGTS) and the reactor enclosure recirculation 

system[ ](RERS) are used to reduce radioactive levels before being discharged into the 

environment” by changing it to read as follows (see LGS ER page 3-18, 4th para.): “The 

standby gas treatment system (SGTS) and the reactor enclosure recirculation system (RERS) 

are used to reduce radioactive radioactivity levels before being discharged into the environment

in gases from the reactor enclosures before they are discharged into the environment.” 

Response: The NRC staff updated Section 2.1.2.2 of the SEIS to include the information in the 

comments.

Comment: 32-3-RW; Page 2-6, Lines 17 to 18, Section 2.1.2.3. Clarify the sentence that 

reads “The solid waste management system collects, processes, and packages solid 

radioactive waste for storage and offsite shipment and permanent disposal” by changing it to 

read as follows (see LGS ER page 3-19 and 3- 20): “The solid waste management system 

collects, processes, and packages solid radioactive wastes for temporary onsite storage, as 

well as shipment and permanent offsite disposal and offsite shipment and permanent 

disposal.” 

Comment: 32-4-RW; Page 2-6, Lines 23-24, Section 2.1.2.3. Because not all dry wastes are 

sent to Duratek for processing and (2) Duratek does not provide final disposal services, clarify 

the sentence that reads “Compressible and non-compressible wastes are packaged and 

temporarily stored until they are sent to Duratek in Tennessee for processing or final disposal” 

by changing it to read as follows (see LGS ER page 3-20): “Compressible and noncompressible wastes are packaged and temporarily stored until they are sent offsite to Duratek 

in Tennessee for processing or final disposal.” 

Comment: 32-5-RW; Page 2-6, Lines 26 to 29, Section 2.1.2.3. Clarify the sentence that 

reads “Wastes from the reactor water cleanup (RWCU) system floor drains, equipment drains, 

and fuel pool system usually exceed the criteria for LLRW or low specific activity material and 

are packaged in containers and stored in the high level storage area (HLSA), which is located in 

the Radwaste Enclosure” by changing it to read as follows (see LGS ER page 3-20): 

“However, wet wastes from the reactor water cleanup (RWCU) system floor drains, equipment 

drains, and fuel pool system usually exceed the criteria for both Class A LLRW or and low 

specific activity material. ,and Therefore, if they cannot be reused, they are packaged in 

containers and stored in the high level storage area (HLSA), which is located in the Radwaste 

Enclosure.” 

Comment: 32-7-RW; Replace the last two sentences of the paragraph that begins in line 41 on 

page 2-6 as follows: “Class B/C LLRW stored at LGS or packaged in the future will be sent to 

PBAPS to be stored at the LLRW storage Purpose and Need for Action facility at that site. The 

storage capacity for LGS Class B/C 1 wastes at PBAPS is expected to be sufficient through the 

extended operating license for both LGS units.Class B/C LLRW stored at LGS or packaged 

in the future may be sent to PBAPS to be stored at the LLRW storage facility at that site. 

The storage capacity for LGS Class B/C wastes at PBAPS is expected to be sufficient 

through the extended operating license for both LGS units. However, storage of LGS 

Class B/C wastes at PBAPS should be unnecessary during the term of a contract, which 

was executed in February 2013, for treatment and disposal of such wastes at a licensed 

offsite facility in Texas.” 

Response: The NRC staff updated Section 2.1.2.3 of the SEIS to include the information in the 

comments.

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Appendix A

Comment: 32-8-RW; Page 2-7, Lines 7 to 9, Section 2.1.2.4. Clarify the words “however, if it 

were necessary to treat and dispose of LLMW during the license renewal period, Exelon would 

store it on site, in compliance with the 1976 Resource Conservation and Recovery Act (RCRA) 

storage and treatment conditional exemption” as follows: “however, if it were necessary to treat 

and dispose of LLMW were generated during the license renewal period during the license 

renewal period, Exelon would store it on site, in compliance with the 1976 Resource 

Conservation and Recovery Act (RCRA) storage and treatment conditional exemption.”

Comment: 32-9-RW; Consider deleting the paragraph in lines 13 to 17 on page 2-7 because it 

repeats information provided in the preceding paragraph. In addition, although Exelon has 

previously shipped LLMW for treatment and disposal by the facilities named in the paragraph, 

future contractual arrangements may be different.

Response: The NRC staff updated Section 2.1.2.4 of the SEIS to include the information in the 

comments.

Comment: 32-10-RW; Page 2-8, Lines, 20 to 21, Section 2.1.3.1. Under Pennsylvania 

regulations there are 4 types of universal waste management facilities: large quantity handlers 

of universal waste (LQHUWs), small quantity handlers of universal waste (SQHUWs), universal 

waste transporters, and destination License Renewal Environmental Report, LGS is classified 

as a Small Quantity Handler of universal wastes (less than 5,000 kg accumulated at any time). 

Accordingly, the sentence in lines 20 to 21 on p. 2-8 of the draft SEIS, should be corrected to 

read as follows: “LGS is considered a Large Quantity Generator Small Quantity Handler of 

universal wastes (less than 5,000 kg accumulated at any time) (greater than 2,200 lb [1,000 

kg] permonth)”[.]

Response: The NRC staff updated Section 2.1.3.1 of the SEIS to include the information in the 

comments

A.2.18 Socioeconomics (SE) 

Comment: 5-5-SE; As taxpayers and ratepayers, the public does not benefit from Limerick 

nuclear energy because Exelon makes its enormous profits while the public pays the lion's 

share of its business costs in one of the biggest corporate welfare schemes ever. Public costs 

include construction costs, the enormous costs skyrocketed and were attached to electric rates 

that climbed to a whopping 55 percent 2 above the national average.

Comment: 5-6-SE; Property and school taxes, Exelon refused to pay its fair share for years. 

Eventually, a settlement was reached and Exelon now pays around $3 million a year. But that's 

a pittance compared to the $17 million it should have been paying each year all along.

Comment: 23-31-SE; Does Limerick Nuclear PP pay its fair share of taxes [?] Probably not.

Response: Chapter 2, Section 2.2.9.6, of this SEIS presents a discussion of the regional tax 

structure and the distribution of present revenues to each taxing jurisdiction and district. The 

NRC has no role in how states and local jurisdictions tax their utilities, assess power plant value, 

or distribute tax money. These comments do not provide any new and significant information; 

therefore, no changes were made to the SEIS.

Comment: 23-29-SE; P. 2-69 and commuting routes. New population growth, see attached 

news article. There has been major population growth and use of roads. Just go on 422 at rush 

hour- leave your NRC desk and come try driving around. Many roads are already clogged.

Response: Section 2.2.9.5 of the SEIS acknowledges that the populations of Berks, Chester, 

and Montgomery Counties have continued to grow since 1970, contributing to increased traffic 

volumes on local roads around LGS (see also Table 2–9). However, as discussed in Section 

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Appendix A

4.10.5, since Exelon has no plans to add additional workers during the license renewal period, 

traffic volume and levels of service on roadways in the vicinity of LGS are not expected to 

change because of license renewal. Therefore, there would be no transportation impacts during 

the license renewal term beyond those already being experienced. This comment did not 

provide any new and significant information; therefore, no changes were made to the SEIS.

Comment: 23-30-SE; Because health can be adversely impact by exposure to RAM there are 

costs to schools [and] to the health system. These are not discussed or the discussion is 

inadequate.

Response: According to NRC regulation 10 CFR 51.71(d), draft SEISs prepared at the license 

renewal stage under § 51.95(c) need not discuss the economic costs and benefits of license 

renewal. The draft SEIS relies on conclusions supported by health effects information 

presented in the GEIS. Radiation doses to the public from continued reactor operations during 

the license renewal term are expected to continue at current levels and would remain well within 

regulatory limits. The NRC has established multiple layers of radiation protection limits to 

protect the public against potential health risks from exposure to effluent discharges from 

nuclear power plant operations. This comment did not provide any new and significant 

information; therefore, no changes were made to the SEIS 

Comment: 32-17-SE; Clarify the sentence in lines 8 to 10 on page 2-71 by revising it as 

follows: “As the ROI has a population greater than or equal to 190 persons per square mile 

within 80.4 km (50 miles), this translates to a Category 4, “in close proximity” population 

density based on the GEIS measure of proximity (greater than or equal to 190 persons per 

square mile within 50 miles).”

Response: The NRC staff updated Section 2.2.9.5 of the SEIS to include the information in the 

comment.

Comment: 32-22-SE; In sections 4.10.2 to 4.10.5, which discuss the impacts of LGS license 

renewal on housing, public utilities, offsite land use, and transportation, the DSEIS does not 

reach conclusions on the level of impacts (i.e., SMALL, MODERATE, etc.). Instead each 

section concludes that “there would be no ... impacts during the license renewal term beyond 

those already experienced.” Exelon suggests that NRC consider providing impact level 

determinations in these sections using the standard levels of SMALL, MODERATE, and LARGE 

adopted in the GEIS. 

Comment: 32-26-SE; Exelon suggests that NRC consider providing an impact level 

determination in Table 4-10 for “Socioeconomics” using the standard levels of SMALL, 

MODERATE, and LARGE adopted in the GEIS. 

Response: The NRC staff’s impact discussions and conclusions are consistent with 

regulations 10 CFR 51.70, 10 CFR 51.71, and NRC NEPA guidance in the Environmental 

Standard Review Plan, NUREG-1555, Supplement 1. These comments do not provide any new 

and significant information; therefore, no changes were made to the SEIS.Comment: 32-23-

SE; Because payments to Chester County taxing entities are very small, consider revising the

sentences in lines 33 to 37 on page 4-30 as follows: “As discussed in Chapter 2, Exelon pays

the majority of its annual property taxes for LGS to the following entities in Montgomery

County and Chester Counties: Limerick Township,; Spring-Ford Area School District, Lower

Pottsgrove Township, Pottsgrove School District, Cherster County, East Coventry Township, and

Owen J. Roberts School District. Exelon also makes tax payments to taxing authorities in 

Chester County and Bucks County, but the amounts are relatively minor.” 

Response: The NRC staff updated Section 4.10.4.2 of the SEIS to include the information in 

the comment.

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Comment: 32-30-SE; The description of a NGCC plant in lines 32 to 33 on page 8-14 is 

credited to “Exelon 2011.” However, section 8.9 lists no reference document to which this short 

form citation is assigned. Furthermore, since the draft LGS DSEIS excludes the existing LGS

site as the host for replacement generating facilities (see page 8-3, lines 22 to 27), Exelon 

questions the assumption that an alternative NGCC plant would have two cooling towers that 

exceed 500 ft in height, which implies natural draft hyperbolic towers. Accordingly, Exelon 

suggests that the accuracy of the description on page 8-14 of onsite features at an alternative 

NGCC plant should be verified.

Response: The NRC updated Section 8.1.10 of the SEIS by revising lines 32 to 33 as follows: 

“The four NGCC units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 

150 ft (46 m) tall.with two cooling towers over 500 ft (152 m) high (Exelon 2011)” However, 

reference information to “Exelon 2011” has been added to Section 8.9.

A.2.19 Support for License Renewal (SR)

Comment: 6-1-SR; As one of the founders of the Pennsylvania 8 Energy Alliance, I speak on 

behalf of a state-wide group of independent community, business, and environmental leaders 

and organizations representing a variety of professional backgrounds. We formed the coalition 

more than four years ago as a forum for like-minded Pennsylvanians who believe nuclear 

energy is a critical component of meeting our energy needs and to advocate for the continued 

operation of clean, safe, and reliable sources of electricity generation all throughout 

Pennsylvania.

Our members consists of a former Secretary of the PA Department of Environmental Protection, 

a former Pennsylvania Game Commission executive, a former Secretary of the PA Department 

of Environmental Resources, and a former Secretary of the Pennsylvania department of 

Conservation and Natural Resources. Like me, these environmental stewards all believe 

nuclear energy has an important role to play in our Commonwealth, and a green nuclear facility 

such as Limerick operates safely and well within environmental standards. 

Nuclear energy provides clean energy that helps to power our homes and businesses reliably 

and safely. I personally have met many of the men and women who work in this industry and I 

know them to be smart, conscientious, earnest and passionate about the work that they do. 

As you know, Pennsylvania is among the nation's largest producers of nuclear energy. To meet 

our ever-increasingly demand for electricity in a way that does not destroy our environment, we 

need a diverse energy mix that includes nuclear power, cleaner fossil fuels, renewable sources 

and energy efficiency. Conservation alone will not offset the expected growth in our electricity 

use and renewal sources like wind and solar, while certainly important, are often unreliable.

Support for nuclear power throughout the Commonwealth remains strong. In 2012, the PA 

Energy Alliance conducted a public opinion poll of nearly a thousand Pennsylvanians from all 

across the state that showed 90 percent of those surveyed believed nuclear power is an 

important part of meeting the country's electricity needs. More than three quarters believe that 

nuclear is a reliable source of energy and perhaps most importantly for today's proceedings, 

more than seven in ten support allowing existing nuclear power plants to extend their operating 

licenses.

We are pleased to see strong support comes from residents who live closest to our nuclear 

facilities. So on behalf of the membership of the Pennsylvania Energy Alliance, thank you for 

the opportunity to share these thoughts with you today.

Comment: 12-1-SR; I run a local daycare as well. We have toured Limerick, have taken the 

children on field trips there and they've always had such excellent field trips. The kids always 

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enjoyed going there to learn about Limerick and learn about nuclear power and how it benefits 

our community.

Also, they support local children's organizations such as soccer clubs and other -- baseball 

teams and things. They have been great supporters of the community. I would have no 

problem. I like the safeguards. We have a very comprehensive plan in place in case something 

would happen with Limerick, what to do with the children and how to get them safely out of the 

area. But I have no doubt that we will ever, ever have to use that plan and I've been working in 

this industry for years now. Thank you[,] Limerick[.]

Comment: 14-1-SR; Unlike some of you guys who have come three hours and thank you for 

coming three hours, I'm a local resident. I live in Chester Springs. I'm raising my kids here. I 

have three children at J. Roberts School District which is a local school district. I am a trained 

certified environmental auditor. I have years of international auditing experience. I've seen 

quite a lot out there, trust me. I have stories. But currently, for the last two years I have been 

employed by Exelon. I work for Corporate Environmental. I sit in the Kennett Square campus 

and I support and assist Limerick Generating Station.

Part of my job responsibility is to provide governance and oversight related to environmental 

complaints and make sure the site follows the environmental regulations and stays compliant. I 

believe the station has a very strong environmental program based on my history, my 

understanding of the rules and audits down by international, internal agencies. We get audited 

by more people than you've probably ever imagined with acronyms that I still cannot keep up 

with and I thought environmental regs had acronyms. I'm impressed with the staff at this plant.

These staff are your neighbors. They work in this plant. They care about their own 

environment, just like I do. I live here. My kids go here. I care about where I live.

And some of the other stuff I do with them is on the side. My children come just like the other 

woman said with her child. My kids take tours of the plant. They learn about how fission works 

and they learn about how a nuclear power plant works and they[ ]can talk conversationally 

about how Limerick works.

They help with the Boy Scouts and the Girl Scouts with building the trails and planting the 

pollinator gardens and bird houses. I also support the station, actually multiple stations with a 

Wildlife Habitat Council certification and the work that they do for that certification. And recently 

we started working with the Audubon Society.

So I'm pretty impressed and I'm here to say I support the Draft EIS renewal of the Limerick 

operating license. Thank you.

Comment: 15-1-SR; I'm a local business. My business is located right in front of the power 

plant. We have absolutely no problems with the powerplant. We're in favor of relicensing. I 

feel the same commitment they do as far as environmental safeguards They do it every day. 

We see it. We see security there. We see if anybody is out snooping around in front there, they 

send security over right away. And they have a lot of systems in place that protect the people.

[I] have lived and worked in and around the power plant all my life. I've hauled trash out of there 

when I was in high school. When the facility opened up, I hauled trash out of there. Now many 

years later, I built my business right next door. I have employees. None of them have any 

problems. Exelon is a great corporate neighbor. They're great for the neighbors there in the 

community. They do a lot for the community, donations and what have you. We all use electric. 

We all turn the lights on at night. We all need it. If you look around, there was two local coalfired plants that were closed down recently. So we need a source. And Exelon is a good 

source. The power plant does a great job.

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Years ago, when I was in high school, nobody wanted to build a house around the power plant. 

Nobody -- they were scared. Now they're building right next to it. And the reason they're doing 

that is because they see the safety track record. They have a safety track record there. They 

don't have any problems. There's no incidence there that I know that would make me feel 

uncomfortable about going into work. 

I drink the water every day. And I repeat, I'm in favor of repermitting and thank you for your 

time.

Comment: 16-1-SR; I've worked for Limerick for about the past four years. And I do believe, 

based on my own experience that Limerick is operated in a way that's safe and protective of the 

environment. In my opinion, Exelon is a very good corporate citizen and operates 16 the plant 

in an environmentally-responsible manner.

Through my job at Limerick, I've had a lot of contact with staff from various regulatory agencies 

that issue Limerick operating permits and do inspections at Limerick on a regular basis. The 

comments and feedback that I've received from these agency staff have shown me that the 

agencies really appreciate a company like Exelon at Limerick that takes environmental 

responsibilities and environmental compliance seriously. 

I support the approval of the Draft Environmental Impact Statement for Limerick's license 3 

renewal application. Thanks.

Comment: 19-1-SR; I own a business called Organics and I operate it and live in Dowington. 

I'm extremely passionate about issues that relate to the environment as my company develops, 

manufactures and deploys materials in organic horticulture.

Thus, I'm in the forefront of environmental issues daily. And I do support the relicensing of 

Limerick Generating Station.

Comment: 22-1-SR; I believe that Limerick is safe both in its design and in that the employees 

come to work every day recognizing that nuclear technology is special and unique. I believe 

that Limerick is operated in a manner that protects the environment and that conservative 

decisionmaking is used at the station to ensure that we protect the plant, we protect the 

workers, we protect the public, and we protect the environment for future generations.

I support the approval of the Draft Environmental Impact Statement for renewal of Limerick's 

operating license.

I'm an administrator with the Pennsylvania Energy Alliance. Day in and day out, we educate 

Pennsylvanians about nuclear power as a clean, safe, and reliable source of energy for the 

future. One of the most rewarding parts of working with this coalition is getting out into the 

community to meet different people, so many of whom already support nuclear energy. 

In early April, we were in this very room for Representative Mark Painter's Live Well Expo. 

Many attendees came by our table to learn about us and some even shared stories about 

Limerick Generating Station dating back to its origination when it was first opened.

Over the last six months, we've had two groups of fourth grade students from Brooke 

Elementary and Limerick Elementary nearby visit Limerick Generating Station. Nuclear energy 

is part of their current curriculum in school and the visit served as a perfect wrap up for the unit. 

The students were actively engaged and many asked great questions about the facility some of 

which were even interested in how to work there when they were older.

In addition, we were also present at the community information night that was held last week at

Limerick Generating Station. Community events such as this continue to show that results from 

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our March 2012 poll still hold true that the public opinion of nuclear power is still very strong and 

positive near our State's five power plants.

As the need for energy continually increases, nuclear power proves to be the most reliable and 

environmentally friendly solution. Thank you.

Response: These comments express support for nuclear power or the license renewal of LGS 

or both. The comments provide no new and significant information and no changes have been 

made in the SEIS in response to these comments. 

A.2.20 Surface Water (SW)

Comment: 2-9-SW; NRC must stop and delay all activities and actions related to Limerick 

Nuclear Plant's relicensing including finalizing this EIS until after several issues are addressed 

or take place.

...Number nine, Exelon installs filtration for Limerick's radioactive and toxic waste water 

discharge to reduce contamination of the primary drinking water source for almost two million 

Pennsylvanians.

And Number ten, Exelon installs filtration for toxic minewater pumped into a drinking water 

source in order to operate Limerick Nuclear Plant.

Comment: 2-22-SW; Facts Show Limerick Nuclear Plant's Environmental Threats Are Clearly 

“Large[,”] NOT “Small” As Inaccurately Claimed By NRC.

• Increases And Exemptions In Limerick Nuclear Plant's Air And Water 

Pollution Permits Should Be Sufficient For NRC To Conclude Limerick's 

Environmental Impacts Are “LARGE” NOT “SMALL[,”] Especially When 

Limerick Couldn't Meet Its Original Permit Limits Or Safe Limits In Place To 

Protect Public Health, And Exelon Won't Pay For Filtration to Reduce health 

Threats.

Comment: 2-32-SW; Major evidence related to Limerick's air and water pollution permit issues 

goes unaddressed.

Comment: 2-35-SW; THE SCHUYLKILL RIVER IS THE VITAL DRINKING WATER 

RESOURCE FOR ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO 

PHILADELPHIA. LIMERICK NUCLEAR PLANT IS SLOWLY BUT SURELY DESTROYING 

THE SCHUYLKILL RIVER.

LIMERICK NUCLEAR PLANT OPERATIONS THREATEN A DRINKING WATER DISASTER 

FOR THE ALMOST TWO MILLION PEOPLE FROM POTTSTOWN TO PHILADELPHIA WHO 

DEPEND ON THE SCHUYLKILL RIVER FOR THEIR WATER SUPPLY.

LIMERICK NUCLEAR PLANT OPERATIONS ARE CAUSING UNPRECEDENTED THREATS 

AND HARMS TO THE SCHUYLKILL RIVER INCLUDING FROM:

• Radioactive Discharges

• Toxic Discharges From Cooling Towers

• Heated Discharges

• Depletion Due To Cooling Towers Insatiable Water Use

• Toxic Mine Water Pumping To Operate Limerick

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WATER RESOURCES ARE THREATENED ACROSS SIX COUNTIES

• Water Resources Threatened Across Six PA Counties From Potential

Limerick Meltdowns.

Comment: 2-29-SW; ACE rejects NRC's inaccurate, absurd conclusions in its DRAFT EIS for 

Limerick Nuclear Plant.

10-26-11 ACE provided NRC with analyses that should have triggered investigations, not just 

consultations with agencies that allowed dangerous permit increases and exemptions in 

Limerick's pollution permits. NRC's conclusions show that NRC ignored and dismissed 

important documented evidence from several analyses related to Limerick's environment and 

health threats. These analyses were on:

• Exelon's Radiological Monitoring Reports to NRC

• Limerick's Title V air pollution permit renewal in 2009

• Limerick's NPDES permit for pollution discharges into the Schuylkill River

• Analyses of radioactive groundwater contamination

Comment: 2-36-SW; IT IS INDEFENSIBLE FOR NRC'S DRAFT EIS TO CLAIM LIMERICK'S 

UNPRECEDENTED THREATS AND HARM TO THE SCHUYLKILL RIVER ARE “SMALL[.”] 

THE EVIDENCE SHOWS OTHERWISE!

Historic evidence proves it was clear even before Limerick Nuclear Plant was constructed, that

the Schuylkill River was unable to sustain Limerick's insatiable water use and abuse.

It is not clear that the river can continue to sustain the wide range of damages caused by

Limerick operations even until Limerick's licenses expire in 2029. There is no guarantee there

will be enough safe usable water for the almost two million people and other businesses that

need the Schuylkill River for their water supply until 2029. If there is a meltdown requiring

massive amounts of water, others will surely lose their water supply.

• NRC'S DRAFT EIS MUST BE CHANGED TO REFLECT REALITY. FACTS 

SHOULD BE CLEAR, EVEN TO NRC THAT THE SCHUYLKILL RIVER

CANNOT SUSTAIN LIMERICK'S USE AND ABUSE UNTIL 2049.

Comment: 2-44-SW; A dangerous mix of massive toxic corrosive chemicals is discharged into 

the Schuylkill River from Limerick's cooling towers. Huge amounts of toxic chemicals are added 

to Limerick's cooling towers every day. Limerick uses at the site every day 94,293 to 192,614 

pounds of toxic chemicals. [They] don't just disappear, but instead end up in air and water 

pollution releases from the site. Limerick uses Sodium Hypochlorite CHLORINE at the site - 

16,000 to 58,000 lbs Per DAY - Chlorine is continuously discharged into the Schuylkill River with 

no continuous testing to determine the extent of harm. In fact, Limerick has just been given a 

permit exemption for the pollution that transports Limerick's cooling tower chlorine and other 

toxics into the river, unmeasured and unfiltered.

Comment: 2-45-SW; Limerick's discharges are violating Safe Drinking Water Standards for 

Total Dissolved Solids (TDS) (up to five times the safe level). TDS transports Limerick's 

radiation and cooling tower toxics into the river.

• To deal with continuous violations of Safe Standards, DEP EXEMPTED 

Limerick from a safe limit requirement, instead of requiring Exelon to filter the 

discharges.

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• NRC is turning a blind eye to this enormous threat to public drinking water 

health risks and the eventual additional costs to water treatment systems and 

their customers.

Comment: 2-46-SW; Limerick Nuclear Plant has slowly but surely been depleting the Schuylkill 

River since it started operating in 1985. Limerick withdraws more than double the amount of 

water every day than is withdrawn for Pottstown, Phoenixville, and Norristown in total. Limerick 

only returns of that to the river. Even after supplementation, the Schuylkill River had record low 

flows by 1999.

Comment: 2-48-SW; Limerick's continuous heated discharges up to 110 degrees are regularly 

overheating the river with a temperature limit of 87 degrees. This jeopardizes the river 

ecosystem. Temperature restrictions for the river were just eliminated as requested by Exelon.

Comment: 2-49-SW; IT IS NOT CREDIBLE FOR NRC'S DRAFT EIS TO STATE SUCH 

ENORMOUS THREATS AND HARMS TO THE SCHU[YL]KILL RIVER ARE “SMALL” OR FOR 

NRC OFFICIALS TO CLAIM NRC IS NOT RESPONSIBLE TO ANALYZE THE

ENVIRONMENTAL HARMS FROM LIMERICK'S WATER POLLUTION AND WATER USE 

PERMITS FOR LIMERICK'S ENVIRONMENTAL IMPACT STATEMENT.

Comment: 2-50-SW; THE LONGER LIMERICK OPERATES THE MORE RADIOACTIVE THE 

SCHUYLKILL RIVER WATER WILL BECOME AND THE MORE TOXIC THE RIVER WILL 

BECOME FROM LIMERICK'S MASSIVE COOLING TOWER TOXICS AND MASSIVE MINE

WATER PUMPING. THE RIVER WILL BECOME MORE DEPLETED AND HEATED. THE

MORE RISK THERE WILL BE FOR MELTDOWNS THAT CAN CAUSE TOTAL LOSS OF

WATER RESOURCES FOR MILLIONS OF PEOPLE ACROSS SIX PA COUNTIES.

Comment: 2-51-SW; TO REDUCE FUTURE HEALTH THREATS TO MILLIONS OF PEOPLE, 

NRC SHOULD REQUIRE EXELON TO FILTER ITS RADIOACTIVE DISCHARGES, COOLING 

TOWER TOXICS, AND MINE WATER PUMPING AS A CONDITION OF RELICENSING.

Comment: 3-3-SW; Every day, 14.2 million gallons of very hot water leave the cooling towers 

loaded with dissolved solids and radiation. This hot brew goes down Pipe 001 to the diffuser 

and into the Schuylkill River. It enters the river at 110 degrees Fahrenheit a much higher 

temperature than the Schuylkill River limit of 87 degrees Fahrenheit. Over the course next 30 

years, that will amount to about 150 billion gallons of polluted water going into the river.

Comment: 3-6-SW; They eliminate proper temperature controls and heat standards for the 

Schuylkill. They allow dirty Wadesville water into the Schuylkill.

Comment: 4-8-SW; Limerick is slowly, but surely destroying the drinking water source for 

almost two million people from Pottstown to Philadelphia. Limerick discharges a 14.2 million 

gallons of radioactive heated wastewater every day. Limerick drastically exceeds safe drinking 

water standards. Without filtration Limerick can't meet safe standards and Exelon won't pay to 

filter.

Comment: 4-10-SW; Cooling tower water used threatens drinking water supplies across six 

counties. Limerick withdraws more water than three towns -- doubles what three towns take in, 

Pottstown, Norristown, and Phoenixville. Cooling towers depleted the S[ch]uylkill River since 

1985. By 1999, there were record low flows in the Schuylkill River. Since 2003, Exelon 

pumped billions of gallons of toxic unfiltered minewater into the river for Limerick operations. 

Decades of radioactive leaks and spills contaminated groundwater. Fifteen of wells detect beta 

radiation. Nine detect alphas. Three gamma. Four uranium. These radioactive leaks were 

never cleaned up and really this offensive EIS whitewash must[ ]be rejected by elected officials 

and the public.

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Comment: 5-3-SW; Our drinking water supply is reduced and contaminated.

Comment: 5-8-SW; Water contamination. Limerick's toxic and radioactive waste water 

discharges cost water companies and their customers more money. Exelon should filter to[ 

]protect public health and protect the water companies and the people who use their water 

downstream[.]

Comment: 7-7-SW; We shouldn't be faced with the depleting water supply because of 

Limerick's cooling towers or risk having no water if Limerick has an accident or a meltdown. Our 

drinking water could Exelon pumps toxic minewater into the river up to 80 times safe drinking 

water standards. The toxics don't magically disappear. They end up in our drinking water. dry 

up or become so radioactive we can't use it.

Comment: 7-9-SW; NRC dismissed serious threats to public drinking water from Limerick 

nuclear plant. NRC met with DEP and DRBC, but they just gave Limerick five-year permits to 

use and pollute our drinking water with dangerous loopholes and exemptions because Limerick 

can't meet safe drinking water standards or other protected limits. That didn't reduce our risks. 

Exelon should have been required to filter Limerick discharges and those from the minewater to 

protect our drinking water and public health. Limerick causes irreparable and irreversible 

damage to the river and then donates to a fund deceptively claiming they protect the river. Not 

one dime of that fund was ever spent to reduce Limerick's radioactive or other toxic discharges.

Comment: 17-1-SW; The water comes out from behind the Norristown Dam in Norristown 

which is the county seat where Pennsylvania's water comes from. And the first introduction that 

I had with Limerick had to do with a committee of the Norristown Boat Club, we were concerned 

about them boiling off all the water. And I was involved with the DRBC rules and regulations 

back to the original ones. And what the DRBC does is it controls consumptive use because 

Limerick can burn off a lot of our drinking water.

Comment: 23-1-SW; I also spent years worrying over the DRBC water augmentation request 

that dedicates the Schuylkill River to the production of nuclear power.

Comment: 26-5-SW; Limerick discharges of Total Dissolved Solids (TDS) into the Schuylkill 

River are up to five times Safe Drinking Water Standards. TDS transports radiation and cooling 

tower toxics into this vital drinking water source for almost two million people from Pottstown to 

Philadelphia. Cooling towers are depleting the river, even after supplementation with toxic 

unfiltered mine water and other sources.

Response: These comments express concern in part over the water quality of the Schuylkill 

River and the impact of LGS water use and wastewater discharges. See also NRC’s response 

to Comments 2-62-AM and 2-63-AM with respect to air quality issues and Comment 2-52-GW et 

al. regarding groundwater quality. 

Surface water resources at LGS, including the Schuylkill River, and the effects of plant 

operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.4 of 

the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon 

by LGS and includes the sources of water used to augment low flows in the Schuylkill River. 

Section 2.1.7 further describes the surface water and groundwater sources used to support 

plant operations, the volumes of water used, and the regulatory conditions and associated

regulatory agencies that govern the plant’s water uses. These sections, as contained in this 

final SEIS, have been updated to reflect the DRBC’s May 8, 2013, approval of a consolidated 

docket for Exelon governing surface and groundwater withdrawals by LGS and its effluent 

discharges to the Schuylkill River. 

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With respect to the comments regarding depletion of the Schuylkill River, the NRC’s 

independent evaluation of LGS’s consumptive use of surface water is presented in Section 

4.4.2.1 of the SEIS. As described in Sections 2.1.7.1 and 4.4.2.1, the DRBC has imposed 

consumptive use limits on LGS’s surface water withdrawals. During low river flows, and as 

prescribed by Exelon’s approved consolidated docket, the DRBC limits the plant’s normal 

consumptive withdrawals for two-unit full-power operation to no more than 12 percent of river 

flow to be protective of aquatic life and downstream water users. Under average flow 

conditions, consumptive water use by LGS amounts to about 3 percent of river flow.As stated in 

Section 4.4.2.1 based on the information and analysis presented, the NRC staff concludes that 

the impact on surface water resources and downstream water availability from consumptive 

water use by LGS, Units 1 and 2, during the license renewal term would be SMALL. 

The docket issued by the DRBC for LGS also approves Exelon’s water supply operation and 

maintenance plan for LGS which, in part, provides for the collection and analysis of data to 

ascertain Exelon’s compliance with the terms of the docket. In accordance with the operation 

and maintenance plan, Exelon is specifically required to monitor and report the concentration of 

TDS discharged to the Schuylkill River via LGS’s primary point source discharge structure 

(outfall 001). As indicated in the approved docket, this monitoring is intended to demonstrate 

that discharges from outfall 001 satisfy the DRBC’s effluent limits and basin-wide water quality 

standards for TDS and, alternatively, to identify the need and basis for TDS-specific effluent 

limits on LGS.

Commenters also expressed concern about water quality degradation and standards, pollution 

sources, and chemical usage specifically attributable to operation of LGS and its effluent 

discharges to the Schuylkill River through its primary discharge structure (outfall 001). These 

discharges are regulated by, and subject to ambient water quality standards set by, the PDEP, 

in conjunction with the DRBC docket issued to Exelon. The DRBC is the agency responsible for 

setting Delaware River basinwide water quality standards for the protection of aquatic life and 

other beneficial uses, including use of basin waters as a public water supply. Point source 

discharges to surface waters including the Schuylkill River are regulated through the NPDES

permitting process in accordance with the Federal Clean Water Act, as discussed in Section 

2.2.4.2. For Pennsylvania, NPDES permit authority has been delegated by the EPA to the 

Pennsylvania DEP. Thus, the statutory and regulatory authority for setting water quality 

standards and permitting effluent discharges to surface waters rests with these agencies, and 

not the NRC. 

LGS’s current NPDES permit establishes effluent limits on various nonradiological 

contaminants, temperature, and cooling tower chemical additives, while prohibiting the 

introduction of some pollutants entirely. The permit also establishes usage rates for cooling 

tower chemical additives. The permit also stipulates that the release of radiological materials be 

in compliance with NRC regulations at 10 CFR 50, Appendix I. Following the DRBC’s issuance 

of a final consolidated docket for LGS in May 2013, the Pennsylvania DEP is expected to issue 

a revised NPDES permit for LGS in the near future, as discussed in Section 2.1.7.1 of this final 

SEIS. In accordance with its statutory and regulatory authority, DEP will ultimately decide if 

additional or more stringent effluent limits on chemical and thermal discharges are appropriate. 

Although the Schuylkill River has historically been impacted by a range of activities as described 

in Section 2.2.4.2 and further described in Sections 4.12.2 and 4.12.3 (Cumulative Impacts) of 

this final SEIS, the main stem of the Schuylkill River in the vicinity of the LGS currently meets 

designated water quality standards and uses, including use as a source for public water supply. 

Regarding radiological contaminants, Exelon maintains a radioactive effluent monitoring and a 

REMP at LGS to assess the radiological impact, if any, to its employees, the public, and the 

environment around the plant site. Exelon must annually submit radionuclide effluent release 

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reports to the NRC as required by 10 CFR 50.36a. The regulation requires nuclear power 

plants to annually submit a report that lists the types and quantities of radioactive effluents 

released into the environment as a requirement of each nuclear power plant’s operating license. 

As further described in Section 4.9.2 of this SEIS, the REMP measures the aquatic, terrestrial, 

and atmospheric environment for radioactivity, as well as the ambient radiation. The REMP 

supplements the radioactive effluent monitoring program by verifying that any measurable 

concentrations of radioactive materials and levels of radiation in the environment are not higher 

than those calculated using the radioactive effluent release measurements and transport 

models. These reports are publicly available at 

http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/lim1-2.html. 

The NRC staff’s evaluation of the radiological impacts of LGS operation and its REMP are 

discussed in Section 4.9.2 of this SEIS. As part of its evaluation, the NRC staff, in part, 

reviewed Exelon’s annual radiological environmental operating reports (REOP) for 2007 to 

2012, which are submitted under the REMP, to look for any significant impacts to the 

environment or any unusual trends in the data. Such a timeframe provides a representative

data set that covers a broad range of activities that occur at a nuclear power plant. Based on 

the review of the radiological environmental monitoring data, the staff found that there were no 

unusual and adverse trends, and there was no measurable impact to the offsite environment 

from LGS operations. Further, the NRC’s ongoing Inspection Program periodically inspects 

Exelon’s Radioactive Effluent Monitoring and REMP programs for compliance with NRC’s 

radiation protection standards in 10 CFR Part 20. The NRC’s inspection program evaluates the 

data for compliance with radiation protection standards. If the data were to show a 

noncompliance with requirements, the NRC would take appropriate enforcement action. 

Additional information for LGS can be found at 

http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/lim1-2.html. 

Several commenters also expressed particular concern over the use of water diverted from the 

Wadesville Mine Pool to augment the flow of the Schuylkill River. The use of mine pool water 

and other diversion sources to augment surface water flows to support LGS operations are 

described in Sections 2.1.6 and 2.1.7 of the SEIS. The NRC staff’s evaluation of the projected 

impacts on surface water resources of the continued operations of LGS during the license 

renewal term are presented in Section 4.4 of this SEIS. Regarding use of the Wadesville Mine 

Pool and other low flow augmentation sources, the DRBC, not the NRC, is responsible for 

regulating such activities. The consolidated docket for LGS approved by the DRBC in May 

2013 includes provisions for the use of water from the Wadesville Mine Pool for flow 

augmentation in the Schuylkill River, subject to certain conditions. Most notably, the 

consolidated docket permits Exelon to use Wadesville Mine Pool as a flow augmentation source 

only as long as TDS concentrations in the Schuylkill River remain below 500 mg/L. The DRBC 

has specified monitoring requirements to verify compliance with all terms and conditions of the 

consolidated docket.

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS in response to these comments.

Comment: 2-47-SW; A meltdown at Limerick could require so much water that Exelon could 

take everyone's water supplies without their permission, from Schuylkill County, the Delaware 

River, the Schuylkill River and all its tributaries, and the groundwater from the residents and 

businesses surrounding Limerick.

Response: This comment expresses concern over the potential water demand to respond to a 

severe accident at LGS. The focus of the environmental review as documented in this SEIS is 

to evaluate the various potential environmental impacts associated with the expected normal 

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Appendix A

operation of LGS for an additional 20 years. In the event of the occurrence of a design-basis 

accident or emergency shutdown condition requiring water for emergency core cooling, no more 

surface water or groundwater would normally be required than is currently required for 

full-power two-unit operation. Nonetheless, in accordance with LGS’s consolidated docket 

issued by the DRBC in May 2013 (DRBC 2013), Exelon is authorized to withdraw surface water 

and groundwater as necessary until the emergency is abated.

For license renewal, the NRC discharges its NEPA obligation to consider severe accidents 

mitigation through 10 CFR 51.53 (c)(3)(ii)(L) and Table B–1. In accordance with 10 CFR 

51.53(c)(3)(ii)(L), the license renewal ERs must provide consideration of alternatives to mitigate 

severe accidents if the staff has not previously evaluated SAMAs for the applicant’s plants in an 

environmental impact statement or related supplement or in an environmental assessment. 

LGS is a plant that had a previous SAMA documented in a NEPA document. The staff has 

previously performed a site-specific analysis of severe accident mitigation design alternatives 

(“SAMDA”) in a NEPA document for LGS in the Final Environmental Statement Related to 

Operation of Limerick Generating Station, Units 1 and 2, NUREG-0974 Supplement 1 (ADAMS 

Accession No. ML112221A204)). Therefore, the applicant’s license renewal ER for Limerick 

and the Staff’s SEIS do not have to reassess the issue. 

Under NEPA, the applicant and NRC must consider whether new and significant information 

affects environmental determination in the NRC’s regulations, including the determination in 10 

CFR 51.53(c)(3)(ii)(L) and Table B–1, that the agency need not reconsider SAMAs at license 

renewal if it has already done so in a NEPA document for the plant. New information is 

significant if it provides a seriously different picture of the impacts of the Federal action under 

consideration. The staff’s evaluation of new and significant information for SAMAs is addressed 

in Section 5.3 of this SEIS.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS.

Comment: 3-7-SW; They alter the river flow rate measurements for convenience[.]

Response: This comment expresses concern over river flow rate measurements, although the 

exact nature of the concern is unclear. As described in Sections 2.1.7.1 and 4.4.2.1 of this 

SEIS, the DRBC has imposed consumptive use limits on LGS’s surface water withdrawals. 

During low river flows on the Schuylkill River, and as prescribed by Exelon’s approved 

consolidated docket, the DRBC limits the plant’s normal consumptive withdrawals for two-unit

full-power operation to no more than 12 percent of river flow to be protective of aquatic life and 

downstream water users. Under average flow conditions, consumptive water use by LGS 

amounts to about 3 percent of river flow. River flow is based on measured flow at specified river 

gaging stations maintained by the U.S. Geological Survey, as referenced in Sections 2.1.6 and 

2.2.4 of this SEIS. The docket also approves Exelon’s water supply operation and maintenance 

plan for LGS which, in part, provides for the collection and analysis of data to ascertain Exelon’s 

compliance with the terms of the docket.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS.

Comment: 23-17-SW; Where is the pump house shown on [p.] 2-17?

Comment: 23-23-SW; [p.] 2-17 Where it this? Very vague.

Response: These comments express confusion over the location of the pumphouse shown in 

Figure 2–8 in the draft SEIS. The pumphouse is situated on the east bank of the Schuylkill 

River just southwest of the LGS plant site. In Figure 2–8 of the SEIS, the Schuylkill Pumphouse 

A-158
Appendix A

is labeled with a pointer arrow to the structure. The facility is discussed in Section 2.1.6.1 of this 

SEIS. These comments provide no new and significant information; therefore, no changes were 

made to the SEIS.

Comment: 23-22-SW; P. 2-16 Line 11 “clay lined” how do you know it doesn’t leak? In 

significant interface – how do we know? No info given?

Response: This comment expresses concern about the integrity of the spray pond. As 

discussed in Section 2.1.6.4 of this SEIS, the spray pond is connected to the emergency service 

water system to supply cooling water to emergency equipment. Heated water is pumped to the 

pond where it is evaporatively cooled by the pond’s spray nozzles or, under certain conditions, 

returned via the winter bypass lines. As noted in Section 2.2.5.1 of this SEIS, the absence of 

discernible groundwater mounding beneath the pond indicates that no significant leakage is 

occurring. As described in Exelon’s Environmental Report (Exelon 2011), performance of the 

spray pond is monitoring and accumulated sediment accumulated sediment on the ponds clay 

liner is removed, when required, to maintain the storage volume of the pond in accordance with 

performance requirements. In addition, the NRC carries out periodic inspections of all safetyrelated facilities in compliance with its licensing and regulatory requirements. This comment 

provides no new and significant information; therefore, no changes were made to the SEIS.

Comment: 28-4-SW; Additionally, one of the leading causes of water quality impairment in 

Schuylkill River watershed is related to stormwater runoff. Over the last 20 years stormwater 

management practices have evolved from peak flow attenuation to low impact development. 

Please include any information on if or how the facility will upgrade its stormwater management 

practices over the re-licensing period. EPA recommends the facility to consider upgrading its 

stormwater management practices to current standards.

Response: EPA’s comment expresses concern over the need for LGS to upgrade its 

stormwater management facilities and practices. NRC’s authority does not extend to requiring 

operating nuclear plants to replace or modify their stormwater management systems to reduce 

impacts. Nonetheless, the NRC expects that each licensee will comply with all applicable 

Federal, State, and local permits that the licensee must obtain to operate its plant, including 

those that are required by the Clean Water Act and its implementing regulations. Discharges to 

surface waters including the Schuylkill River are regulated through the NPDES permitting 

process in accordance with the Federal Clean Water Act, as discussed in Section 2.2.4.2 of this 

SEIS. For Pennsylvania, NPDES permit authority has been delegated by the EPA to the 

Pennsylvania DEP. Thus, the statutory and regulatory authority for stormwater management 

rests with the DEP. Exelon’s current NPDES permit does require that a Preparedness, 

Prevention, and Contingency Plan be maintained for the LGS site which requires the use of best 

management practices to reduce pollutants in stormwater discharges. Exelon currently has an 

NPDES permit renewal application before the Pennsylvania DEP, as referenced in Sections 

2.1.7.1 and 2.2.4.2 of this SEIS. In accordance with its statutory and regulatory authority, DEP 

will ultimately decide if additional or more stringent controls on stormwater are appropriate.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS.

Comment: 31-3-SW; The Limerick Plant will depend upon river water for a longer period of 

time as a result of the license renewal. During low flow periods, additional quantities of water 

are released into the river from the Wadesville Mine and Still Creek Reservoir in Schuylkill

County to compensate for the water withdrawn at the plant through a docket approved by the 

Delaware River Basin Commission (DRBC). Since the relicensing action would extend the time 

period of this flow augmentation system, continued monitoring and analysis of the river is vital to 

ensure that the water quality of the river is not impaired by the total dissolved solids in the 

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Appendix A

Wadesville water among other parameters. This is particularly important due to the role of the 

Schuylkill River, a state scenic river, which is an important regional water supply source and 

recreation area. If resumed use of the Delaware water diversion is anticipated, an evaluation of 

that system should be undertaken to ensure that the capacity is available in the conveyance 

system and that water quality objectives can be met for discharge into the East Branch of the 

Perkiomen Creek.

Response: EPA’s comment expresses concern in part over surface water diversions from 

supplemental water sources to support continued LGS operations and the need for water quality 

monitoring. 

The regulation of surface waters across the Commonwealth of Pennsylvania, including 

discharges regulated under the Clean Water Act and water quality monitoring and assessment, 

is within the regulatory authority of the PDEP. 

The DRBC is the agency responsible for setting Delaware River basinwide water quality 

standards for the protection of aquatic life and other beneficial uses, including setting allocation 

limits on the use of basin waters for end uses. Thus, the statutory and regulatory authority for 

evaluating the long-term effects of the water diversion activities cited by EPA rests with these 

agencies, not the NRC. The NRC performs plant-specific reviews of the environmental impacts 

of license renewal in conformance with NEPA and the requirements of 10 CFR Part 51. 

Accordingly, surface water resources at LGS, including the Schuylkill River, and the effects of 

plant operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.4 

of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon 

by LGS and includes the sources of water used to augment low flows in the Schuylkill River. 

Section 2.1.7 further describes the surface water and groundwater sources used to support 

plant operations, the volumes of water used, and the regulatory conditions and associated 

regulatory agencies that govern the plant’s water uses. These sections, as contained in this 

final SEIS, have been updated to reflect the DRBC’s May 8, 2013, approval of a consolidated 

docket for Exelon governing surface and groundwater withdrawals by LGS and its effluent 

discharges to the Schuylkill River. 

NRC’s independent evaluation of LGS’s consumptive use of surface water is presented in 

Section 4.4.2.1 of the SEIS. As described in Sections 2.1.7.1 and 4.4.2.1, the DRBC has 

imposed consumptive use limits on LGS’s surface water withdrawals. During low river flows, 

and as prescribed by Exelon’s approved consolidated docket, the DRBC limits the plant’s 

normal consumptive withdrawals for two-unit full-power operation to no more than 12 percent of 

river flow to be protective of aquatic life and downstream water users. Under average flow 

conditions, consumptive water use by LGS amounts to about 3 percent of river flow. Under the 

approved docket, it is expected that LGS operations will be able to increasingly rely upon 

augmented flows in the Schuylkill River from upstream sources, including Wadesville Mine Pool, 

and less on diversions from the Delaware River. 

The docket issued by DRBC also approves Exelon’s water supply operation and maintenance 

plan for LGS which, in part, provides for the collection and analysis of data to ascertain Exelon’s 

compliance with the terms of the docket. In accordance with the operation and maintenance 

plan, Exelon is specifically required to monitor and report the concentration of TDS discharged 

to the Schuylkill River via LGS’s primary point source discharge structure (outfall 001). As 

indicated in the approved docket, this monitoring is intended to demonstrate that discharges 

from LGS’s primary outfall structure satisfy the DRBC’s effluent limits and basinwide water 

quality standards for TDS and, alternatively, to identify the need and basis for TDS-specific 

effluent limits on LGS. The docket and operation and maintenance plan also govern the 

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Appendix A

operation of the East Branch Perkiomen Creek diversion and Perkiomen Creek intake to ensure 

that instream flow and water quality objectives are met.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS.

Comment: 32-6-SW; The sentence in lines 34 to 35 on page 2-16 reads as follows: “The 

screens have 0.25-in. (0.64-cm) mesh openings designed to limit water approaching the 

screens to a velocity of 0.75 fps (0.23 m/s).” As Exelon explained in its March 27, 2012 

response to the NRC's Request for Additional Information, item E1-7, the information in this 

sentence was based on initial design information provided during the LGS construction permit 

stage (in Section 3.4.3 of the LGS ER-CP) and subsequently reflected in the LGS FES-CP and 

ASLB Initial Decision of June Pumphouse design resulted in a decrease from 0.75 fps to 0.61 

fps in design velocity for the as-built screens. This decrease is acknowledged in Section 4.2.4 

of the LGS FES-OL, as well as in the DRBC Docket No. D-1969-210 CP-13 (p. 3, Sec. A.2.b), 

which was approved on May 8, 2013. Accordingly, Exelon requests that the sentence in lines 

34 to 35 on page 2-16 be revised to read as follows: “The screens have 0.25-in. (0.64- cm) 

mesh openings designed to limit water approaching the screens to a velocity of 0.75 fps (0.23 

m/s) 0.61 fps (0.19 m/s). 

Response: The NRC staff updated Section 2.1.6.1 of the SEIS to include the information in this 

comment.

Comment: 32-11-SW; Page 2-23, Lines 2 to 3, Sections 2.1.7.1. Beginning after the words 

“and held a hearing on August 28, 2012” on line 3, insert the following sentence: “On May 8, 

2013, the DRBC unanimously approved the docket for water withdrawals by and 

discharges from the LGS.” 

The approved DRBC Docket No. D-1969-210 CP-13 is available on the DRBC website at the 

following URL: http://www.state.nj.us/drbc/library/documents/dockets/050713/1969-210CP13.pdf[.]

Response: The NRC staff updated Section 2.1.7.1 of this SEIS to include an updated 

discussion of the docket review process for LGS as well as the May 8, 2013, approval.

Comment: 32-13-SW; Page 2-33, Lines 45-47, Sections 2.2.4.2. In lines 45 to 47 on page 2-

33, the LGS DSEIS indicates that Exelon has not received any Notices of Violation, 

nonconformance notifications, or related infractions associated with the site’s NPDES permits or 

related to other water quality matters within the past 5 years, based on a letter from Exelon t[o]

NRC responding to an NRC request for additional information, dated February 28, 2012. 

Please note that the Pennsylvania Department of Environmental Protection ([PD]EP) issued a 

Notice of Violation (NOV) to LGS dated 03/06/2012. The NOV addressed external corrosion 

and pitting observed by [PD]EP on the outer shells of the Unit 1 and 2 Sulfuric Acid 

Aboveground Storage Tanks (DEP Tank Nos. 001A and 002A) during inspections that were 

performed in December 2011. LGS completed the required corrective actions, had the tanks reinspected, and submitted a letter to the [PD]EP on 03/27/2012 documenting the corrective 

actions. At this time, there are no open actions with respect to the NOV, and no other NOVs 

have been received in the past 5 years.

Response: The NRC staff updated Section 2.2.4.2 of this SEIS to include the information 

provided in the comment. 

Comment: 32-19-SW; The sentence in lines 20 to 22 on p. 4-4 indicates that NRC staff did not 

consider use of water from the Wadesville Mine Pool and the Still Creek Reservoir in its impact 

level determination because the final DRBC docket had not been approved and use of these 

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Appendix A

waters remained a demonstration project. Exelon recommends modifying the sentence based 

on DRBC’s approval of Docket No. D-1969-210 CP-13 on May 8, 2013 Exelon recommends 

modifying the sentence based on DRBC’s approval of Docket No. D-1969-210 CP-13 on May 8, 

2013. The approved docket, which authorizes the Wadesville Mine Pool and Still Creek 

Reservoir as augmentation water sources for the Schuylkill River, is available on the DRBC 

Web site at the following URL:

http://www.state.nj.us/drbc/library/documents/dockets/050713/1969-210CP-13.pdf

Response: The NRC staff updated Section 4.4.2.1 of this SEIS consistent with the May 8, 

2013, docket approval by the DRBC. 

Comment: 32-20-SW; Because the DRBC made the demonstration project permanent by 

approving Docket No. D-1969-210 CP-13 on May 8, 2013, consider revising the sentence in 

lines 28 to 30 on page 4-4 as follows: “This trend toward an increasing reliance on augmented 

flows in the Schuylkill River would be expected to increase during the license renewal term 

should the demonstration project continue or be made permanent by DRBC, as requested by 

Exelon.”

Response: The NRC staff updated Section 4.4.2.1 of this SEIS consistent with the May 8, 

2013, docket approval by the DRBC. 

A.2.21 Terrestrial (TE)

Comment: 32-16-TE; Page 2-62, Lines 6 to 21, Section 2.2.8.3. On February 18, 2013, a bald 

eagle was observed and photographed hunting waterfowl in the LGS spray pond. This 

observation will be reported in the Limerick Corporate Lands for Learning application to be 

submitted to the Wildlife Habitat Council in late June 2013.

Response: The NRC staff updated Section 2.2.8.3 of the SEIS to include the information in the 

comment.

Comment: 32-25-TE; Page 4-50, Lines 15-22, Section 4.12.4. NRC's determination of 

MODERATE cumulative impacts on terrestrial resources is based on neighboring energyproducing facilities, habitat fragmentation from increased suburban development, agricultural 

runoff, nearby parks and recreation areas, and climate change, with no contribution for the 

minimal terrestrial impacts from continued LGS operation. Considering that ,of the neighboring 

energy-producing facilities, one closed 2 units in 2011 (Cromby), another closed 1 unit in 2012 

(Eddystone), and one was withdrawn (Linfield Energy Center), Exelon suggests that SMALL to 

MODERATE may be a more appropriate cumulative impact level, similar to aquatic resources.

Response: The NRC staff updated Section 4.12.4 and Appendix F to correct the errors noted 

in the comment regarding the operational status of neighboring energy-producing facilities. 

However, because the conclusion of “MODERATE” cumulative impacts on terrestrial resources 

is based on the effects of neighboring energy-producing facilities in addition to a number of 

other factors, the staff determined that these corrections would not change the overall 

conclusion of MODERATE. This comment does not provide any new and significant information; 

therefore, no changes were made to the SEIS.

A.3 References

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of practice for 

domestic licensing proceedings and issuance of orders.”

A-162
Appendix A

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

renewal of operating licenses for nuclear power plants.”

[DRBC] Delaware River Basin Commission. 2013. Docket No. D-1969-210 CP-13, Exelon 

Generation Company, LLC Limerick Generating Station and Surface Water Augmentation, 

Montgomery, Bucks, Schuylkill, Berks and Chester Counties, Pennsylvania. Approved 

May 8, 2013. Available at 

<http://www.nj.gov/drbc/library/documents/dockets/050713/1969-210CP-13.pdf> (accessed 

11 September 2013).

[Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

License Renewal Stage. ADAMS No. ML11179A104. 

[NEI] Nuclear Energy Institute, NEI 05-01, “Severe Accident Mitigation Alternatives (SAMA) 

Analysis” (NEI 2005) ADAMS No. ML060530203

[NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative – Final 

Guidance Document. Washington, DC: NEI. NEI 07-07 [Final]. August 2007. ADAMS 

No. ML091170588. 

[NEPA] National Environmental Policy Act of 1969. 42 U.S.C. § 4321 et seq.

[NRC] U.S. Nuclear Regulatory Commission. 1989. Final Environmental Statement Related to 

Operation of LGS, Units 1 and 2. Washington, DC: NRC. NUREG-0974, Supplement 1. 

August 1989. ADAMS No. ML112221A204.[NRC] U.S. Nuclear Regulatory Commission. 1996.

Generic Environmental Impact Statement for License Renewal of Nuclear Plants. 

Washington, DC: NRC. NUREG-1437, Volumes 1 and 2. ADAMS Nos. ML040690705 and 

ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2011a. Official Transcript of Proceeding, “Limerick 

Generating Station License Renewal Public Meeting: Afternoon Session.” ADAMS

No. ML11287A207

[NRC] U.S. Nuclear Regulatory Commission. 2011b. Official Transcript of Proceeding, “Limerick 

Generating Station License Renewal Public Meeting: Evening Session.” ADAMS

No. ML11287A211

[NRC] U.S. Nuclear Regulatory Commission. 2011c. Memorandum and Order CLI-11-05 

September 9, 2011 (ADAMS No. ML11252B059)

[NRC] U.S. Nuclear Regulatory Commission. 2011d. NRC News S-11-07, “Adequate Protection 

in Commission Decision-Making, Remarks of Commissioner William C. Ostendorff,” NEI 

Lawyers Committee Meeting, March 7, 2011 (ADAMS No. ML11060377) 

A-163
Appendix A

[NRC] U.S. Nuclear Regulatory Commission. 2013a. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation. 

NUREG 1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Nos. ML13106A241, 

ML13106A242, and ML13106A244.

[NRC] U.S. Nuclear Regulatory Commission. 2013b. Memorandum and Order In the Matter of 

EXELON GENERATION COMPANY, LLC (Limerick Generating Station, Units 1 and 2) CLI-13-

07 October 31, 2013 (ADAMS No. ML13304B417)

[NRC] U.S. Nuclear Regulatory Commission. 2013c. NRC Staff's Brief on the Board's Referred 

Ruling in LBP-13-1, Mar 13, 2013, ML13072A804

[NRC] U.S. Nuclear Regulatory Commission. 2013d. ASLB Order Denying Petition for Waiver 

of 10 C.F.R. § 51.53(c)(3)(ii)(L) and Referring this Decision to the Commission LBP-13-01 

February 6, 2013 (ADAMS No. ML13037A477)

[NRC] U.S. Nuclear Regulatory Commission. 2013e. Official Transcript of Proceeding, “Limerick 

Generating Station License Renewal EIS Public Meeting: Afternoon Session.” ADAMS

No. ML13172A027

[NRC] U.S. Nuclear Regulatory Commission. 2013f. Official Transcript of Proceeding, “Limerick 

Generating Station License Renewal EIS Public Meeting: Evening Session.” ADAMS

No. ML13172A019. 

[NRC] U.S. Nuclear Regulatory Commission. 2013g. “Environmental Impact Statement, Scoping 

Process, Summary Report.” March 2013. ADAMS No. ML12131A499.

[NRDC] Natural Resources Defense Council. 2012. Natural Resources Defense Council’s 

Petition, By Way Of Motion, For Waiver Of 10 C.F.R. § 51.53(C)(3)(Ii)(L) As Applied To 

Application For Renewal Of Licenses For Limerick Units 1 And 2, November 21, 2012. ADAMS 

No. ML12326A976

A-164
Appendix A

Scoping Comment Letters and Meeting Transcripts

The following pages contain the comments, identified by commenter designation and comment 

number, from letters and public scoping meeting transcripts.

A-165
Appendix A

A-166

31 

1 u n thinkable p ropor t ions . Wh e the r a natural disast er 

2 p r t e r rorist a ttack occurs, by relicensing Lime rick, 1-1-PA I 

3 NRc would in e ffect be pl acing Russi a n r oulette with 

4 the liv es of more tha n eight milli o n people . NRC must 

5 close Lime rick Nuc lear Pl ant by 2 029 . 

6 There is n o way for either NRC or Exelon 

1-2-0S I 

7 t o ensu r e t h e s afety o f the envir o nment or the 

8 r esi dents impacted b y this p lant . It cannot be made 

9 fclil SCJfp No o t.hPr fCJ cc i li t v hCJs t.hP notPnt i CJ l t o 

10 rend e r t he ent ire regi o n u ni nhabi table , p o ssibly f o r 

1-3-0S I 

11 centuries as the result of an a ccident o r t errorist 

12 attack . This is t he highest- risk facility t hat coul d 

13 exist i n a ny c ommuni ty i n t h is c o u ntry. 

14 Current 40- year operati ng licenses exp i re 

15 n 2024 a nd 2029 0 Why the rush t o renew these 1-4-LR I 

16 i censes now? 

1 7 we u rge t h e N KC to say no t o t;xelon s 

18 requested license renewa l s . The public wa s l e d t l 1-5-0R I 

1 9 li eve t hat Limerick ' s generators , fuel pools, and 

20 il es o f u nderground pipes a nd cabl es could 

11-6-LR 

operate 

I 

21 safely fo r 4 0 years and then the f acility would c los e . 

22 I s Exe lon fe arful that the longer they wa i t t h e more 

23 serious problems may arise? 

24 After o n l y 26 of 40 y ears, numerous s igns 1-7-0S I 

25 o f agi ng a nd r is k have b een i d e n t i fied . Corrosion , 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., NW. 

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-167

32 

1 ld e t e riora tlo n , tat1gue , cracK1ng , t n 1 nn1ng Wl tn los s 

2 o f ma ter ial, loss of f ractur e tou ghne ss a re all 1-7-0S I 

Cont'd 

3 d ocume n t e d i n Exelon ' s own ren ewal a pp lica t i o n in the 

4 agi ng ma nageme nt sec t ion . I nst a nce s o f equipmen t 

5 f a t i gue a nd c r acking o f vit al equipme nt include the 

6 r eactor vess e l a nd cool ant s ystem. 

7 Aging equipment , a f t er o nly 26 ye ars 

8 s ug g e sts that NRC s ho u l d no t j ust c l o s e the p l a nt by 1-8-0S I 

9 2 029 , but also ramp up thei r oversight v i g i lance 

10 d u r i ng t he r e ma i n i n g 1 8 years o f the cu r r ent l i c ense . 

1 1 In t h e past f ew years, Limerick has h ad nume rous 

1 2 npl ann ed shutdowns suggesti ng t h e r e are a l ready 

13 ign ifi ca n t pro b l e ms . Th r ee o c c urred i n one wee k i n 

14 u n e 2011. Los s o f c o ol ant l eak s and a cci dent s a t 

1-9-0S I 

15 i merick h ave a l read y been docume nt ed . Serio us 

1 6 ad i o active contami nation coul d go u ndet e cted a nd 

1 7 n r epor ted fo r years f r om the c orrod i n g 

18 n f rastru c t u r e , mu c h of it und e rground . 

1 9 There h a v e a l r eady bee n t wo n ea r miss e s a t 

20 Lime rick f r om 1 996 to 2001 . 

21 Thi s a ging plant is an a ccident wa iti ng to 

2 2 h a ppen . Larg e v o l umes , more than 6 , 000 assembli e s rL-.J.-::--:=,.,...,.,-, 

1-10-RW I 

23 wei ghi ng mo r e than a tho usand tons o f h ighly 

2 4 r adioacti ve waste i n the f orm of s p ent f uel rod s a re 

25 s tor ed in d e n s ely- packed pools, e l ev a t e d f i v e s t ories 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-168

33 1 

1 above and outside the reinforced containment 1-10-RW I 

Cont'd 

2 

3 

tructure . This p lant 

ons o f dangerous spent 

will produce about two more I 

,...,U.-:-:-:::::-:-:-:-1 

fuel rods every year that it 1-11-RW I 

4 perates. Llmerlck , ln addltlon , lS now thlrd on the l I 

5 earthquake risk list f o r nuclear p lants in the 

6 States. 

7 Wi t h loss o f cooling water, Limerick ' s 

8 fuel rods could heat up , sel f ignit e , and burn in an 

9 unstoppable fire with catastrophic results. Exelon 

10 has not been requ i red to spend the money t o g uard 1-13-PA I 

1 1 Limerick against terro rists, missiles, or air strikes 

12 despit e repeat ed requests t o do so . 

13 Dry c ask storage a nd transpo r t are also'r'-:-''-:-!-=:-:-:-:o 

p -14-RW I 

14 ery dangero us a lternatives. It ' s time to close 

15 imerick and stop produci ng s uch deadly waste for 

16 hi ch there is no safe s o lut i o n . As long as Lime rick 

17 perates harms to us and our environme nt will 

18 ncrease . 

19 Their harmfu l environmental impacts are 

20 unprecedented . At the conc lusion o f our 11- year 

21 i nvestigation of rou tine radiation releases and review 

22 o f permits for ma j or air pollution a nd a variety of 

23 dangerous water contamination issu es, it ' s clear that 

24 thi s energy is not just dirty, it is i n fact filthy. 

25 Evidence that we ' ve compiled has addressed a wide 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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34 

1 range o f topics : routine radi a t i o n r e leas es into the 

2 air, radioactive wastewate r discharges into the 

3 Schuylkill River, radioactive groundwater 

4 contamination, radioact i v e n uclides associa t ed with 

5 the plant detected in our soil, o ur sediment , our 

6 v egetat ion , our f ish, our water, and mil k . 

7 Res earch has c o nfirmed radiation in our 1-15-HH 

8 

9 

10 lean Air Act , 32 i ndividu a l sources list ed . Drastic, 

1 1 armful increases per mi tted in part iculate matt er 

12 nown a l s o as PM- 1 0 from t h e coo ling t owers, other air 

13 ollution increases a l s o permitted . 

14 Dangerous depletion of t h e Schuylkill 

15 s ing ul a r r eason to deny~-:-::~~---, 

p-17-SW I 

Riv er, in a nd by itself, a 

16 this permit . The Schuylkill is a vital d r inking water 

17 s ource for nearly two million peopl e from Pottstown t o 

18 Philadelphia . I t is being depleted and contami nated 

19 eve ry day that this p lant operates. 

20 Alarming cancer increases that h ave been 

21 well d ocume nted i n this commu nity repeatedly far j1-18-HH I 

22 higher than national and state a v erag es a fter Limerick 

23 started operat i ng until the l ate 1990s . The 

24 f i ndings of our inv estigation l ead us to conclude that 

25 this p lant is i n common language a recipe for 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

I 
Appendix A

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35 

1 disaster. 

2 While NRC is r e q uired t o prepare a 

3 supplement to the Limerick Environmental Impact 

1-19-LR I 

4 Statement f or license renewal , we have little 

5 c onfidence in t he process based o n NRC ' s regulatory 

6 history. It would b e difficult t o enumerate a short 

7 list, s o I ' m going t o r e ly o n written document s . 

8 There are c ritics o f t he NRC out there who have d o ne a 

9 much better job t han we have of generating such a 

10 l i s t, mo s t notably a s c a t h i ng i ndi c t ment by t he 

11 Ass o ciat ed Press. I ' m not going t o re- enumerate that 

12 informati o n . 

13 It ' s long past t i me for the NRC t o summon f7-7::-::~, 

1-20-0R I 

14 t he courage t o d o the r i ght thi ng in o ur judgment and 

15 a c tuall y protect the environment and t he pub l ic, 

16 r a t her t ha n t he industry . 

17 Today, I am going to be submitti ng on t h e 

18 reco rd s ummary packets of our resea rch on Li merick ' s 

19 major air poll ution , h arms to the Schuylkill River, 

20 r adioactive groundwater contamination , links between 

21 Limerick ' s r adiation a nd o ur e l evated cancers in this 

22 community and how Limerick ' s n uclear power can , in 

23 fact , b e replaced with safer sources today . 

24 

25 

Based on the compelling body of evi dence 

o f e nvi r onmental ha rms t o date and 

(202) 234-4433 

Nt:AL K. uKU~~ 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 

t he eno r mous 

www.nealrgross.com 

1-21-0R I 
Appendix A

A-171

1 i ncreased p opulat ion i n proximity to this f acility, 

2 Limerick Nuclear Plan t must b e closed by 2029 . 

3 The r e is no amount of e nergy p r oducti o n that is 

4 worth riskin g the l ives o f s o many people . Thank you 

5 v ery much . 

6 (Applause . ) 

7 FACILITATOR BARKLEY : Thank you , sir. 

8 MR . MAGUI RE : Good aftern oon . My name is 

9 Bill Maguire and I am the site v i ce president a t 

10 Li merick Generati n g Stat i on . And I h ave ove r all 

1 1 responsibility for t he safe and reliable operatio n of 

12 t he faci l i ty. 

13 I have been working in t h e n u c l ear power 

14 i ndust r y f o r 25 years a nd my ca reer began a t t he 

15 Limerick Generating Stati on as an engineer . I 

1 6 continued wi t h a l icense to b e a licensed senior 

17 reactor operator sup e rviso r in the operati ons 

18 o rganizati on a nd wa s the on- shi ft senior manager of 

1 9 that fa c ility f or many y ears. 

20 I h ave also worked at a few other nucl ear 

21 stations across the cou ntry and b efore rejoining 

22 Limerick as t h e s i te vice presid ent in May of 201 0 , I 

23 was t h e site vice president at the Peach Bottom Atomic 

24 Power Station in southeastern Penn s y lvan ia in York 

25 County . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

I 

1-21-0R I 

Cont'd 
Appendix A

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37 

1 Operating Limerick Generating Stat ion 

2 safe l y and reliabl y is a responsibil ity that everyone 

3 at t he power station takes very seriously. We 

4 u nderst and our obligation to the community, to the 

5 environment , and to each oth er to operate t h e plant 

6 safely. 

7 A key component o f a thriving community 

8 l ike ours is the ava i lability o f safe , clean, and 

9 reliable electricity. And as we l ook into the future 

10 for the power needs of Pennsylvania and t he United 

1 1 States as a whole , we can see the increasing demand 

12 for this very i mpo rtant resour ce . 

13 At t he same time , there ' s a growi ng 

14 c oncern abo ut greenhouse gases and climate change that 

15 is a result of burn ing fossil fuels . To help meet 

16 that growi ng p ower demand and to help keep our 

17 environmen t clean, Exe1on has applied to the U. S . 

18 Nuclear Regulatory Commission for a 20- year extension 

1 9 to the pl ant ' s opera ting license . Lime rick ' s current 

20 l icense fo r Unit 1 will expire in 202 4 and Unit 2 in 

21 2029 0 With license renewal , Lime rick can provide our 

22 r egi on with clean power through 2049 . 

23 We understand our special obligation t o 

24 operate the plant sa fely and reliably and to ma i ntain 

25 a close relationship with our neighbors . We p ledge t o 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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38 

1 ontinue that special trust as we operate the plant 

2 ell int o the future . 

3 The 104 nuclear reactors in the Unit ed 

4 States provide roughl y 20 percent o f our nation ' s 

5 electricity. More than 7 0 react o rs nationwide have 

6 already received a pprova l from the Nuclear Regulatory 

7 Commission for a 20 - year license extension inc luding 

8 t he Peach Bottom Atomi c Power St a tio n in Yor k Count y . 

9 Limerick Generating Station ope rates in a 

10 mann er t hat preserves the enviro nment. Th e plant 

11 produces a lmost no g reenhouse gases . The plant 

12 conduct s approximately 1 700 t ests annually on air, 

13 wa te r , fish , s oil , cow ' s milk, and ot her food products 

14 t o measure f or envi ronmental impact . We also ma i ntain 

15 a c h ain of radiatio n mon itors surrounding the plant . 

16 In 2005 , t h e environmental management 

17 systems at Limerick Generating Station achieved 

18 certifi cati on u nder the s t ri c t criterion of the 

1 9 Internationa l Organization for Standardization, ISO . 

20 This certification is known as ISO 14001 , a common 

21 industry reference f o r the environmental 

22 certification. The ISO 1 4001 certification requi res a 

23 commitmen t t o e xce ll e nce to prevent pollu tion a nd t o 

24 ensure continuou s i mprove ment in environmental areas . 

25 

(202) 234-4433 

In 2010, the Wildlif e Habitat Council 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

I 

2-1-sRI 

Cont'd 
Appendix A

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39 

1 recogni zed Limeric k Genera t i ng Station ' s commitment t o 

2 environmental stewardship by awarding us the Wildlife 

3 at Work Certifi cation . Thi s dis tinction was awarded 

4 t o Lime rick Generating St ation f or our commitment 

5 t owa rds establishing long- t erm wildl ife habitat 

6 e n hancements that provided undisturbed habitats with 

7 f ood , water , cover , and space for animal species 

8 l iving on the p l a n t station ' s l a ndscape . 

9 To ensure Lime r ick c onti nues t o operate 

1 0 safe l y f o r years t o c ome , Exelon is investing i n 

11 upgrades t o p lant equipment . Since 201 0 , Exelon has 

12 invest ed mo re t han $200 million i nto t he plant 

13 including installati on o f new safety equipment, new 

14 electri ca l cabl es, new valves, and refurbishing the 

15 c ooling t owers . In addit i o n , Limerick has made more 

16 tha n $40 million i n physical security upgrades s i nce 

1 7 2001. 

1 8 Our investment i n the future does not stop 

19 with equipment . We hav e hired and tra ined ove r 100 

20 new employees over the last three years, mostly coming 

21 f r o m ou r native region here . We maintain a s t e ady 

2 2 wor k fo rce o f appr oxima t ely 850 peopl e a nd during our 

23 annual maintenance and re fueling outages, we b r i ng in 

24 b etween 1500 and 200 0 temporary workers that pro v i de a 

25 b oost t o our local economy. Hi ring 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

and 

www.nealrgross.com 
Appendix A

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40 

1 r e t aining t op t alent i s a key p r i ority f or Limerick 

2 Gene r a t i ng Stati o n . 

3 Ove r t he past 25 years, Limerick h as been 

4 o ne o f the b est perf ormi ng a nd most r e liable 

5 gene r a t i n g s tati ons in t he n ucl ear p owe r industry . 

6 During t h a t t ime , t he p lant has s e t severa l records 

7 f or con t inuous days o f ope rat ion and has been 

8 recognized by the i ndustr y f or o u r r e liable op e ratio n . 

9 I n Ma r ch 2010 , Lime r ick comp leted a s uccessf u l r un o f 

1 0 727 co ntinuous days f o r our Unit 1 p l a nt . Thi s 

11 represented t he second l o ngest continuou s run f o r a 

12 b o ili ng water reacto r i n the Un i ted Sta tes . 

13 Whi l e we d o not set o ut t o break records, 

14 c ontinuous operat i o n s are o n indi c a tor of the 

15 e x ce l lent human perfo rmanc e a nd equipmen t reliability 

16 that Lime r i c k s trikes f o r every day . 

1 7 We a l s o t a ke p r i d e i n o ur invest ments in 

1 8 the commu nity. In 201 0 , Limeri c k dona t ed more than 

19 $600 , 0 00 to t he community i n contribut i o ns to t h e 

20 Uni ted Wa y , f i r e and ambul ance compani e s , ed ucati onal 

21 h ea l t h and yo u t h o rgani za tions. And many o f our 

2 2 emplo yees serv e as vo l un teers in the loca l c ommuniti e s 

2 3 around t h e p l a n t . 

24 I n con clusio n , Limerick Gener ating Station 

25 looks forwa r d to worki ng with the Nucl ea r Re gu l atory 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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41 

1 Commission as you revi ew our license renewa l . I 

2 appreciate the oppo r tunity t o speak with you this 

3 a ft ernoon . Thank you . 

4 FACILITATOR BARKLEY : Thanks , Bill. 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Repres entative 

7 Quigley. 

8 RE P . QUIGLEY : Good afternoon , my name is 

9 State Representative Tom Quigley. I represent t he 

10 146th District here o f which lower Pot t s ville is a 

1 1 party of t ha t distri c t , s o I want t o we lcome t he NRC 

12 here t oday t o t h e beau tiful Sunnybroo k Ba l lroom f o r 

13 this meeting and t h ank t h em for comi ng o ut to listen 

14 t o the public and take c omme nta r y . 

15 I ' m here today t o vo ice my stro ng support 

16 for the re l icensing o f t he Limerick Generating 

17 Station . I wanted t o touch o n a couple p o i n ts of why 

18 I feel it is i mpor tant f o r this f acili ty to be 

1 9 relicensed . 

20 First is the amount of electricity that is 

21 produced b y this faci lity . One of the thi ngs that 

22 myself and my colleagues in Harrisburg hear 

23 consist e n t ly from bus inesses a nd the Commonwealth and 

24 o u r citizens is the demand for ener gy and e l ectricity 

25 now and more impo rtantl y wh a t t hat d emand is going t o 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

3-1-SR I 
Appendix A

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42 

1 be in the future . 

2 Right now this facility generat es enough 

3 electricity for two millions homes and without 

4 producing some o f the greenhouse gases that we hear so 3-1-SR 

5 much about t hat coul d be produced by coal , natural 

6 gas, or o il. And I ' m goi ng to put a caveat in there 

7 f or my good f riends out in t he western p art o f the 

8 state where coal i s a b ig part o f t he Pennsyl vani a 

9 economy and I ' m suggesti ng t hat this be done to t he 

10 excl usion of coal a nd n everthel ess, s ome of t he 

1 1 t echnol ogies t hat they ' re developing out the re are 

12 also important for that ind ustry and importa nt for t he 

13 Commonwealth o f Pennsylvania . 

14 Again, one o f the c o ncerns we hear 

15 c onsistently from businesses is how can we come here 

16 into Pennsylva n i a with t he infrastructure b eing what 

17 it is whi ch needs to be improved for the transmi ssi on 

18 o f the e l ectricity, but more impor tantly the 

1 9 generation of t h at electricit y? 

20 Number two , I think is important is the 

21 j obs and overal l economy . Again , in t h ese tough 

22 economic t imes that we ' re facing here i n the 

23 Commonwealth of Pennsylvania and a lso i n this nation, 

24 one of the top issues that we hear consistently about 

25 is jobs. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

Cont'd 
Appendix A

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43 

1 And as was ment ioned by the site vice 

2 resident , over 860 people are empl oyed here with an 

3 nnual payroll o f $75 million . The direct impact that 

4 s t o the Commonwea lth of Pennsylvania , of course , is 

5 ealized through the state income tax and also all of 

6 hese local municipali t ies most o f them enact an 

7 

8 

arned income tax which again sustains their ownships r.~-~1-- ~-.~ 

Cont'd 

swell as t heir respec tive school distri cts. To have ~~----~ 

9 hat taken away I think would have an even more 

10 ramat ic i mpact on our l o cal economy . 

11 As was mentioned t he i mpact f or t h e local 

12 rea here , the temporary workers who show up here 

13 uring the o utages and the refueling , there ' s already 

14 een two hotels t hat have sprung up along the 422 

15 orridor with another one planned right up here at the 

16 ana toga area . Aga i n , more j obs and more economic 

17 rowth here for o u r communities . 

18 Thirdly , I want to talk about the 

19 ommunicati on that I ' ve experienced in the seven years 

20 hat I ' ve been in office with Exelon and with their 

21 overnment Affairs peopl e as well as with their site 

22 

23 

24 

25 

eople . I ' ve b een on the site three times, twice for 

tour and one to make a presentation during an 

nniversary of the facility . And I have to say that 

t is a very secure area . I know a lot of people are 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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44 

1 concerned about terrorism attacks or people being o n 

2 the property. But unl ess y o u ' ve actually gone over 

3 there and gone through a t o ur, seeing how things are 

4 set up , seeing t he a rme d guards there , seeing t he 

5 security measure s t hat are in place , I think you come 

6 away much more relieved with t ha t . And I ' m abl e t o 

7 speak t o my const ituents more affi rmat ively about t h e 

8 

9 

safety and security o f t h e facili t y . 13- 1-SR I 

ICont'd 

Any t i me that t here ' s been t he s l i ghtest 

10 occurrenc e the re , whet her it wi l l be a c o upl e times a 

1 1 hunter has wandered o nto t h e property where t he 

12 authorities were c a l led, t h e Government Affa irs people 

13 at Exe lon are o n t he phone to me or wit h an email 

14 r i ght away t o let me know what's happening befo re t he 

15 word gets out t o the media o r t o the press. So 

16 they ' r e a lways very well p repared in their 

1 7 explanations , not only o f t hings that happen a t t h e 

18 plant itself , but also inci dents and issues that occur 

1 9 around the coun try and around t he wor l d . 

20 Obviously, what took p l ace in Jap a n with 

21 the inc ide nt over there, they were on t he phone with 

22 me and met with me a few times to e xpl ain what took 

23 p lace over there and how t he safeguards are being put 

24 i n place he r e so t h at do esn ' t happen a t t his facility. 

25 

(202) 234-4433 

I t was ment i o n ed e a r l ier the dry cask 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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45 

1 storag e where t he spent fuel r ods are now stored 

2 o utsi de i n a d r y cask s t orag e faci lity . When that was 

3 proposed b ac k i n 2005- 2006 , the Generating Station 

4 held t wo open houses that were very well a tte nded . I 

5 went to b o t h of them where t hey h ad peopl e on there t o 

6 explain to the people what exa ctly was taking place 

7 wit h thi s dry cask s t orage , why i t was necessary . A 

8 lot o f questions and a nswers ba c k and f ort h and I 

9 t hi nk a lot of the p e opl e came away bet ter informed 

1 0 about t ha t process. 

11 Just recent l y at a n open house , t he sit e 

12 VP who just spoke , Bill Maguire , came o u t to give some 

13 ini tial c omments and wou nd up spending the ful l hour 

14 in an impromptu question and answer sessio n and not 

1 5 again just planted questi ons , a l o t of tough 

16 q uest ions . And I t hink again the people came away 

1 7 f eeling confident i n t he openness and the transparency 

1 8 that was displ ayed i n tha t question and answer 

19 session . 

20 Another point of that is for relicensing 

21 for t he overal l envi ronment here i s the good corporate 

22 citizenship that the Generating Station has exhibited . 

23 As was mentioned by Bill, some o f the charitable 

24 contrib uti o ns that have gone on , not onl y for the host 

25 community of Lime rick, b ut also f or t he surrounding 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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46 

1 areas. I a t tended a f ew dedication service s where 

2 they provided mo n ey to the Upper Providence Elementary 

3 School and the Li merick Elementary School f o r an 

4 o utside environmen tal classroom. 

5 One o f t h e thi ngs we tal k about as 

6 p o l itical leaders, and I ' m on the Hou se Educatio n 

7 Committee , is the need f o r our children t o be ed u cated 

8 particularl y in the sci ences and g i ven t h ese b udget 

9 c onstraints t hat we ' re o perati ng unde r , b o t h t he 

1 0 school distri c t s and the Commonweal t h , it ' s good t o 

11 see a c o rpo rate c itizen steppi ng up t o the plate and 

12 providing t hat fi nancial s upport, particularly i n t he 

1 3 area of science . They ' ve also pa r tnered wit h t he 

14 Montgomery Co u nty Community Co llege t o provide 

15 assistance in s u pport for an associat e degree i n 

16 n uclear e ngineering technology . 

1 7 Again, we hear s o much about our students 

1 8 here not b e i ng well versed in technology and 

19 engineering and things o f that n at u re . So again, 

20 stepping up to the p l ate to provide that assi stanc e 

2 1 when , in fa ct, perhaps i n these t ough budget times 

2 2 whe r e the government might n ot be able to d o that . 

23 Last, I want t o talk abou t overall p ublic 

24 opi nion and sa f ety issues. One of t he t hings that I 

25 looked at when I tal k about saf e ty and the feel ing of 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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47 

1 comfort that p eople hav e h ere is how many of the 

2 people who work at t ha t plant live wit hin the t en- mile 

3 radius of t he f acilit y? And I as ked that question 

4 when I first was elected in 2004 and I just asked i t 

5 again i n preparat ion for t h is heari ng a nd 563 

6 empl oyees l ive wi t hin the t en- mi le radius. 

7 The populati on growth i n my Dist rict in 

8 t he past ten yea r s , we ' re getti ng ready to r edraw our 

9 lines b a s e d on the 201 0 Cens us, s o I broke i t down by 

1 0 t own s h i p as to how much the populat i o n h a s i ncre a s ed 

11 in t hose areas : Lime r i ck Townshi p , i ncr easing by 33 . 5 

12 percent; Up p e r Pottsg r ove b y 2 9 . 5 ; Royersford Boroug h , 

1 3 whe re I liv e , 11 . 9; Lower Pottsgrove , 7 ; Pottstown , 2 ; 

1 4 now this is a l i t t le bit s kewed , b u t I have a smal l 

1 5 piece of New Ha nover Townshi p which act ua lly i ncreased 

1 6 by 54 percent . 

1 7 When you l ook at the p u blic opini on, and 

18 aga i n , we get ca l ls on a lot of d ifferent i ssues and 

19 as I ment ioned that dry cask storage issue . Back 

20 then , at the same time that that issue was being 

21 rol led out to the pub lic, Boyd Gaming had p u rchased a 

22 p roperty next to our pl ant was getting ready to apply 

23 -- had appl ied for a license , casino license . At that 

24 time , my o f fice had received 2 ca l ls in regard to the 

25 dry cask storag e proj ect , over 200 calls regardi ng the 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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1 casino a pp lication . So a t the time , i t appeared 

2 p eople were more c o ncerned about the prosp ect o f a 

3 casino b eing i n the ir neighborhood t han they were a 

4 dry cask storage f acility. 

5 And lastly, as some o f yo u hea rd , t here is 

6 a propo sal right now t o put a hold on Rout e 422 . And 

7 again , i n the past six months wi t h the inc idents in 

8 Japan , with the current earthq uak e we h ad here , with 

9 the At' sto r y telling yo u how these p l a n ts are a l l 

1 0 fa lling apart, I recei ved t wo calls regarding that one 

11 where t h e y coul d get the KI pil ls, o ne where they 

12 coul d -- what wa s the e va cuat ion plan f o r t ha t , and 

1 3 more calls and e mail s r egarding the proposed 42 2 . So 

14 aga i n , i t a ppears t hat t he c onstituents a nd t he 1 46t h , 

1 5 they ' re more conc e rned about the prospect of paying a 

1 6 t oll t o r ide of 422 t han t hey are about the nuclear 

1 7 p ower p lant issues. 

1 8 So again , I strongl y support the 

19 r e l icen si ng of thi s f o r t he reasons I mentio ned . 

20 Thank you . 

21 (Applause . ) 

2 2 FACILI TATOR BARKLEY : Thank you, 

23 Representative Quigley. 

24 The ne x t t h r ee people I ' d like to call , 

25 first is Lorraine Ruppe , p r ivate c itizen ; and the 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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49 

1 next , Michael Gallagher o f Exelon ; and finally, I ' d 

2 l ike to call Dr . Fred Winter a fter that . 

3 MS . RUPPE : Hi , my name is Lorraine Ruppe . 

4 I a m speaking h ere today t o represent t h e child ren 

5 and fut ure genera tions, esp ecially in our community. 

6 Residents are fea rful ab out the possibility of 

7 disasters here in light o f Fukushima in March 201 1 and 

8 since the earthquake and Hurri cane Irene in August 

9 2011 affecting o u r area . Climat e changes, e t c etera, 

10 are causing disast ers everywhere and cont inuing t o get 

11 worse . 

12 Increasing f l oods, d rought s , eart hquakes, 

13 t ornad o s h ave made us all fee l i nsecure , making 4-1-PA I 

14 nuclear power inc reas ingly risky, especial ly with t he 

15 Limerick plant basically in our bac kya rds . Any 

16 earthquake tha t comes through this area could be a 

17 p ossible Fukushima , Chernobyl o r Three Mile Island 

18 whi ch reminds me , four months have passed since the r.-~-=-::--, 

4-2-GE I 

1 9 NRC failed t o get back to me when I asked how c lose 

20 the Remapo fault line i s to the Li merick nuclear 

21 reactors ? Maybe I can get an answer tod ay . 

22 Indian Point nuke plant was sketched as a 

23 possible terrorist target in re f erence to 9/11 

24 attacks . A s uspected terrorist worked at Limerick for 

25 years without the industry knowing it. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 

How scary is 

www.nealrgross.com 

4-3-0S I 
Appendix A

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5 0 

1 that? 

2 The Pacific Ocean is now severely 4-4-0S I 

3 irradiated by Fukushima . Radiation i mpacts of 

4 Fukushima equalled over 20 Hiroshima bombs when I last 

5 esearched . Our drinking and b a t hing water here is 

6 e i ng continuously pollut ed by Limerick every day, 

7 4/7 f or years wit h r a di ati on and un filtered t oxic 

8 ont ami na t ed mi ne water, thanks to t h e NRC and Exelon . 4-5-SW J 

9 This is disgusting . 

10 Most of us have to depend o n t h e water, 

11 special ly for bathing . Some o f u s p a y extra f o r 

12 ater filtrat i on or drink b o ttled water because we are 

13 f raid to dri nk f r om the Schuylkill a nd because it 

14 astes reall y bad now . Imagi n e how toxic i t would be 

15 8 p l us years from now if there was even any water 

16 eft . 

17 There has been i ncreased particulate 

18 matter in t he air and other toxics from Lime ic ....,._ .,....,.,...,......., 

4-6-HH I 

1 9 causing incr eased asthma , heart attacks, and strokes. 

20 And to add insult to i njury, Li merick was granted a 

21 p ermit to all ow an e ight - fo l d increase in air 

22 p o llution since 2009 . Cancer rates in our a rea have 

23 skyrocketed since Limerick has been up and running in 

24 the ' 80s and rates h ave s t eadil y increased . 

25 I 

(202) 234-4433 

The Toothfai ry Pro j ect showed high l evels 114-7-HH I 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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51 

1 or stront ium O!U , a rad1onuc11 d e in bab y teeth or 

2 children nearest to nuke plan ts. Baby teet h near 

3 Limerick p lant had the hig hest levels i n the whole 

4 Unit ed States. This s t uff a nd God knows what else i s 

5 i n our bodies now t hanks to a Nuclear Regulatory 

6 Commission t hat t o put it nicely is l ess than 

7 e nt husiastic about p r otecting us. 

8 Solar wi nd , geothermal , ocea n t h ermal , 

9 nergy conservatio n a nd efficienc y are now cheaper 

10 ha n nuclear power, along with being t ruly clean and 

11 afe . The Department o f Energy 2006 report s t a t ed 

12 o l ar a lone coul d provide 55 t imes ou r entire na tion ' s 

13 nergy needs which leads me to a point , there have 

14 ee n numero us studies proving the many da ngero us and 

15 eadly consequences of nucl ear p ower . There ' s no 

16 denying the massi ve devastation it has a l ready cau sed 

17 and wi l l continu e t o cause i ndefinitely, but the 

18 industry still goes on in t he ir trance- like, 

1 9 indifferent f ashion as if everything is safe and 

20 wonderful and wi l l continue to b e 18 plus years from 

21 now o r u ntil 2049 for o u r community. This i s what 

22 r ea lly scares us t he most . 

23 The NRC has turned into a culture of 

2 4 secrecy, hi di ng the dangers a nd sweeping t h e problems 

25 under the rug . 

(202) 234-4433 

The i ndustry' s addiction to mo ney and 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

4-7-HH I 

Cont'd 

~-:--~:,.......,....,...., 

4-8-AL I 
Appendix A

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52 

1 p ower has blinded them to moral life and death issues 

2 and facts set right in front of t heir faces . But my.-1:--='-::-=---, 

14-9-LR I 

3 ig question of the day i s why is Exelon applying for 

4 an extension 18 years ahead of time? Thank you . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Thank you , Lorraine . 

7 Mike? 

8 MR . GALLAGHER: Good a f ternoon . My name 

9 is Mike Gallagher and I ' m t he Vice President of 

10 Li cense Renewal for Exelon . I have overall 

1 1 responsibi lity for t he Limerick Generating St ation 

12 l i cense renewal applicati on . 

13 Exelon has a great dea l of experi ence wi th 

14 l i cense renewa l , as we have already obtained t he 

15 renewed l icenses for our Peach Bo t tom and our TMI 

16 plants in Pennsyl vania , o ur Oyster Cree k plant i n New 

17 Jersey, and o u r Dresde n and Quad Cities plants in 

18 Illinois. 

19 Just briefly a bo ut mysel f . I ' ve been 

20 working in the nu c l ear power industry for 30 years . I 

21 was a licensed senior operator and plant manager at 

22 Limerick a nd I worked a t two other nuclear plants and 

23 o ur corporate offices . 

24 Mr . Maguire , t he site vice president for 

25 Limerick spoke abou t reasons for renewi ng the license 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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53 

1 for Limerick . I ' d like to speak briefly a bo ut the 

2 process f o r preparing this l icens e r enewa l application 

3 a nd the amount of work and engineeri ng a na lysis that 

4 was put into preparing t he a p p lica t ion . 

5 Because t he license Gene r a t i ng St a tion can 

6 pe operat ed safely and reliably, Exelon decid ed t o 

7 pu rsue l icens e renewal fo r Limerick . Lime r i ck is a 

8 very c lean ener gy source whic h produces no greenhouse 

9 as emissi o ns . Limerick i s a l s o good f o r the eco nomy 

10 n t hat i t l owers market pri ces on electri c ity f or t he 

1 1 piti zen s o f Pe nnsylvania to the tune o f $880 mi llion 

12 per year . 

13 So i n 2009 , we annou n ced o ur i nte nti on t o 

14 seek l icens e r enewa l for Limerick . Later t hat year, 

15 we star t e d t he work necessary to prepare the 

16 applicati on . After o ver two years of work, we 

17 submitted the appl ication to the Nuclear Regul a tory 

18 Commission o n June 22 , 2011 . The a ppl i ca t ion, as Lisa 

1 9 had mentio ned , when you print it o u t i t ' s about 2 100 

20 p ages. And when you p u t it in the binders it ' s three 

21 large binde r s . I t ' s a huge amoun t o f informat ion. 

22 But t hat only represents a small part o f t he work that 

23 was done for t he engi neering analysis t o p repare this 

24 application . 

25 The tot al amount o f engineering ana lysis, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

~~~=---, 

5-1-SR I 
Appendix A

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5 4 

1 i f we printed it a l l o ut wou l d be about 290 binders of 

2 i n formation . We invested over 60, 000 manhours of 

3 engineering work . Once we completed our engineering 

4 work to prepare t he application, we brought in experts 

5 from outside Exelon t o review the application t o 

6 e ns ure that it was complete , thorough and accurate . 

7 Our tot al cost t o prepare t he applicat ion a nd get this 

8 appl icati o n revi ewed by t he NRC wi ll be about $30 

9 mi llion . 

10 There are t wo different parts of our 

1 1 f:lpplica t i on, t he safety review and the environmental 

12 eview. For t he safet y revi ew, we t ook an in- dept h 

13 ook at the history and t he conditio n of t h e safety 

14 quipment i n the plant . We did t hat to determi ne 

15 hether the necessary maint enance was b eing performed 

16 pn that equipment and to make s u re t hat the equipment 

17 ~i ll be abl e to operat e when it' s n eeded , not onl y for 

18 oday, but a l so for a n additional 20 years of 

1 9 ppe ration . 

20 When you look back at Limerick, when it 

21 as b uilt, all the equ ipment was new . I t was 

22 horoughly tested to make s ure it would perform 

23 properl y , but like anything e lse equipme nt does a g e . 

24 ~h at doesn ' t mean it won ' t work, but it does age and 

25 ertain acti v ities n eed to be done to the equipment . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

5-2-081 
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55 

1 So we perform prev entive maint e nance . Some t imes we 

2 r efurbi s h the equipmen t . Some equipment is repl aced . 

3 There may be modificati o ns d one t o upg rade the 

4 equipment in the p lant and in f act, as Bill Maguire 

5 h as stated , Limerick ha d spen t ov er $200 mill ion in 

6 the last couple y ears alone t o improve a nd modernize 

7 the equipment a nd e nha nc e pl ant operations and s afe t y . 

8 

9 were 

We also t hen 

performed as par t of 

revi ewed calculat ions that 5-2-0S I 

Cont'd 

t he o riginal des ign o f t he 

10 plant t hat were d one t o e nsure t hat the plant coul d 

11 ope rate safely for 40 yea rs . We a na lyzed tho se 

12 calculat i ons and we re able t o confirm t hat t he plan t 

13 woul d be abl e t o operat e saf e l y fo r 6 0 yea rs. 

14 Overall , our conc lusio n from ou r e ng ineeri ng r ev i ew 

15 was t hat Lime rick could ope rate safely for up to 60 

1 6 years. 

17 We also t o o k a l ook at t he e nvi ronmental 

18 i mpacts of continuing t o operate Limeri ck . We l oo ked 

1 9 at all the impacts o f con t inued i mp act o f the p l a n t on 

20 the e nvironme nt . Our concl u sion is that impacts on 

21 t he environmen t are small and I use the term s mall in 

22 t he sense t h a t is in the regulati on . The regul ation 

23 defi nes s ma ll as environmental effect s are not 

24 detectabl e or are minor . 

25 

(202) 234-4433 

We a l so revlewed t h e a l tern a t lves l f 115-3-AL I 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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56 

1 Lime rick wo uld not hav e its license r e newed and 

2 another source o f electric generation would n eed to b e 

3 i nstall ed either here on s i t e or someplace else t o 

4 gene r a t e the repl acemen t electri city. We concluded 

5 tha t a n y o ther means o f generating t he replacement 

6 ele ctri c ity would have more of a n impact o n t he 

7 e nvironment than continued operation o f Lime rick . Fo r 115-3-AL I 

IICont'd 

8 instance, if Li meri c k could b e r eplaced by a wind 

9 g enerat ion faci l i t y , the wi nd f orm would have t o 

10 occupy b e t ween 1 0 and 40 percent o f a l l t he land i n 

1 1 t he s t ate o f Delaware a nd t hat would h ave a huge 

12 impact on t he l and . I f a s ola r facilit y could replace 

13 Limeri c k , i t woul d n eed t o cover 32 t o 50 percent of 

14 t he e nt ire land area o f Montgomery County. 

15 I n conc lusion , we ope rate Li merick safely 

16 and we can conti n u e to operate it safely f or an 

17 addi t iona l 20 years . Limer ick will provide 

18 approximately 2 3 4 0 megawatts of bas e - l oad generation 

1 9 that ' s not o nl y s a f e , but it ' s clean, reliable and 

20 economica l . 

2 1 Co n t i nued o pe ration of Li meric k will 

22 b ene fit this community , the Commonwe alth of 

23 Pennsyl vania a nd ou r nation . Thanks for giving me the 

24 t ime for this. Thank you . 

25 

(202) 234-4433 

(Applau se . ) 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

5-4-SR I 
Appendix A

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57 

1 FACILITATOR BARKLEY : Thank you , Mi ke . 

2 Dr . Wi n t er? 

3 DR. WINTER: Good a f ternoo n . Thanks f or 

4 letting me s p eak . We h av e h ea rd a l ot of pros a nd 

5 cons, h aven ' t we ? And i t ' s hard t o make a deci s i o n 

6 tha t ' s for sure . But le t me ge t goi n g here . 

7 As a pnyslcl an p ra ct.lclng r a alo l ogy r: o r 

8 ove r 50 yea rs, I s t i ll h ave s t r ong concer n about 

9 c a ncer s ensi tiviti es from h a rmfu l r adiat i o n e x posures, 

10 n a t u r a l ly. My medical col l eag ues s h are t he s ame 

1 1 c oncerns b eca us e we h a v e s e en o u r c anc er rat e s 

12 increas e since t h e Li merick powe r p l a nt sta rted , 

13 especi a l ly thyro i d canc er . I t j ump ed to 78 percen t 

14 h i gh e r he r e t han the nat i on a l average . And s ome of 

15 the p eopl e I tal ked t o , thi s i s becaus e peop le a r e 

1 6 agi ng more now, g e t t i ng old e r , so t h e r e a r e more 

17 cancers. But t hat ' s not true b eca use i n o ther a r e as 

18 simi lar to ou r a rea i n Pottstown, they ' re not nearly 

1 9 getting the thyroi d cancers t ha t we are . This has 

20 b een well establi s hed by t h e state . 

21 You wond er why some of our medical and 

22 cancer f und raisers h aven ' t reacted with more 

23 responsibil ity i n order to stop t h is. They ' re ma king 

2 4 a l ot o f money , but no t taking much effort to prevent 

25 e nviro nment al d amage . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

6-1-HH I 
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5 8 

1 Yes, we are creating our own form of 

2 t err orism. Now tha t sounds kind o f f unny, doesn ' t it? 

3 But allowing any harmful environmental events t o 

4 occur , we are allowing o ur own form of ter r orism, j ust 

5 like foreign p eople wo uld come in here . 

6 Having attended a Hiroshima , Jap an atom 

7 omb c linic right a ft e r Wo rld War II, natural ly I had 

8 chanc e t o see t he worst res u lts o f harmful 

9 adiation . All those little kids I saw who only lived 

10 or a few days, i t l eft me with a very sad memory. Ofii6-2-HH I 

1 1 ourse , what is happeni ng here will be taking much 

12 onger, but it s u re is no t good . 

13 I don ' t know whether you ' ve heard that 

14 orne s c ientists are already predi c t ing that I ' m 

15 orr y to tell yo u t h is, but n u c lear energy has the 

16 apacity of destroying man k ind . I t may t a ke about 1 00 

1 7 ears, but our whole wo r l d is e xposed to t he ha r mful 

18 f f ects, maybe not so much here i n t he United States, 

1 9 ut the whole world can be affected . 

20 Of course , what is h a ppening here will b e 

2 1 taking much longer, but it is s u re not good news . 

22 Besides harmful power plant expos ures, we have 

23 environmental disasters and a concern about our nearby 

24 earthq uake fault a nd othe r s in t he eastern U. S ., 

25 especially o ne n ear New York City . And t hen there are 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

6-3-PA I 
Appendix A

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.------------------, 59 I 

i-::1--:--:::-::::-o 1 h e radioactive spent f uel d eadly waste material 6-4-os 1 

2 itting around , s upposedly protected . We can ' t 

3 control the use o f nuc lear power in the rest o f the 

4 world , but can k eep America safer a nd cleaner here . 

5 So please , ask your politic i a n s , reliable 116-5-0R I 

6 p o lit icians t o close t he Lime r ick power p l a nt . Let ' s 

7 s ave America f o r our kids and des cendants . I h ope you 

8 will take my concerns seri ousl y . And t hank you f o r 

9 listening . 

10 (Ap plause . ) 

11 FACILITATOR BARKLEY: Oka y , t h ank you , Dr. 

12 Wi nt er. The nex t three p e o p l e I ' d l i k e t o call is Tom 

13 Nea f cy of Limerick Township, f ollowed by Dr . Anita 

14 Baly, a nd then Tim Fen c he l o f t he Schuylki l l River 

15 Heritage Fo undati on . 

1 6 MR . NEAFCY : Good a fternoon , thank you . 

17 My name i s Tom Neafcy. I ' m the Chairman of Lime r ick 

18 Township Board of Supervi sors and I want to thank you 

1 9 for this opportu nity to s p eak at this forum today. 

20 As the largest private empl oyer i n the 

2 1 region , the Board i s thankful f o r t h e 8 6 0 j obs that 

22 Exelon provides, the positive impact of the i r-1=-L-L=, F-1-SRI 

23 operati on , the vitality o f our local community. The 

24 communi ty and l ocal econ omy are enhanced by the needed 

25 services p r ovided b y t h e t ownship , which inc ludes t he 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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60 

1 roadway network maintained by our Limerick Township 

2 Public Works, public safety provided by the Limerick 

3 and Linfie l d Fire Companies , a nd our local e mergency 

4 medical response , our public parks, our recreation 

5 facilities and also the police protection that ' s 

6 provided by Limerick ' s 2 1 sworn o ffi c ers. 

7 Because o f Limerick Generating Station ' s 

8 location within our b o rders, the Limeri ck Township 

9 Police Depart ment 

10 depart ment in 

11 jurisdictio n over 

is the only municipal police 

Pennsylvania wi t h 

Tier 1 critical 

t he pri mary 

r=l7 .... -1,....-s=-R=-___,I 

infrast ructure ·iCont'sd 

12 Thi s Board prides i tself on t he servi ces provided 

13 directly bo t h t o the residents and t he b usinesses of 

14 this community and t he township ' s ability to ma i ntai n 

15 those current levels of service during these difficult 

16 economic downturns . We are thankful for the 

17 generosity of the Limerick generating plant and Exelon 

18 for being good corporate neighbors and the assistance 

19 they provide to the community . Without their 

20 financia l assi stance that impact to provide those 

21 services to the community would fal l squarely on the 

22 backs of the t axpayers . They assist in o ur fire 

23 companies . They have b een corporate sponsors of our 

24 Lime rick Community Days . And we are confident that 

25 Limerick generating facility and Exelon will continue 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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61 

1 that support in the fut ure and be our good corporate 

2 neighbor. 

3 We also are i n support of the relicensing 

4 o f the Limerick nucl ear plant . Thank you . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Dr . Baly? 

7 DR . BALY : Good afternoon . I ' m Anita 

8 Baly . I ' m a reti red Lutheran pa s tor and my concern 

9 t oday is wit h the speed at which this appli cation 

10 p rocess is go i ng . I mean it seems to me t hat t o 

11 p redict what environmental fact ors will be in p lace 1 3 

12 years hen c e and 1 8 years hence , posits a k i nd of 

13 p mni sci ence and prescience that we should att ribute t o 

14 f\lmi ght y God , b ut certainly not t o any of us human 

15 eings . 

16 I would favor a slower process . As we 

17 look around, we see that the population in this area 

18 is getting denser all the time . The roads are not 

1 9 b e i ng improved . And that l eaves me wi th concerns 

20 about how we would effect an e v acuation were one 

21 needed . I suspect strongly t hat we couldn ' t perform a 

22 good evacuation today . And I a l so suspect that the 

23 population will be increasing and the roads 

24 deteriorating. In fact , just this morning in the 

25 Pottstown Mercury , they were reporting on the hearing 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

7-1-SR I 

Cont'd 

8-1-LR I 

8-2-os 1 
Appendix A

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62 

1 hat was held o n Rout e 422 which is ou r main road 

2 around here . And Barry Seymour is quoted , he ' s t he 

3 xecutive Director of the Delaware River Valley 

4 Regi o nal Plan ning Commission , and he t old last week ' s 

5 orum audience that population proj ections anti c i pate 

6 a 50 p ercent increase in the region and if we don ' t 

7 ncrease capacit y o n 422 , we will have v i rtual 

8 gri dlock a l l the way to t he Berks Count y l ine . 

9 Maybe we ' ll improve t h at situation , but 

10 it ' s way too early t o k now i f that will happen . And 

1 1 s o my p lea a nd my concer n i s can we s low this down so 

12 t hat we k now, i n fact , what the envi r onmen t a l impact s 

13 are going t o be closer to a time t hat the decision is 

14 made . Thank you . 

15 (Ap p l a use . ) 

16 FACILITATOR BARKLEY: Thank you . Ti m? 

17 MR . FENCHEL : Good afternoon . My name is 

18 Ti m Fenchel and I ' m o n the staff of the Schuylkill 

1 9 River National and State Heritage Area . We are on e of 

20 4 9 congressional ly- designated Heritage Areas in the 

21 country and our mission i s to use recreation, 

22 conservation, educati on , cultural and historic 

23 preservation and tourism as tools for community 

24 revitalization and economic development with the 

25 Schuyl ki ll River Valley. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

118-2-081 

IICont'd I 
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1 The Herit age Area has had the opp ortunity 

2 for almost seven y ears now to partner wit h Exelon 

3 Nuclear a nd the Limerick Generating St ation on several 

4 local and region al project s and programs . These 

5 programs have proven t o have a positive impact on our 

6 local commun i ties, residents, and natural resources. 

7 And I would lik e t o take a few moments t o highlight 

8 those now . 

9 In 2005, Exelon Nuc lear app roache d u s 

1 0 about the possibil i ty of partnering together on a 

11 grant program t h a t wo uld work t o restore our area ' s 

12 critical natural resource , t h e Schuylkill Rive r . The 

1 3 river ha s b e en d etrimental l y i mpacted by hu ndreds of 

14 years o f abu se and neglect , primari ly as a resu lt of 

1 5 o ur nation ' s history related to the I ndustrial 

16 Revolution . But even more recently, due t o 

1 7 deforestati on , farming p ractices , and continued open 

18 space developmen t . 

19 Beginning in 2006 , after the creati o n of 

20 grant program g uidelines, an a dvisory committee and a 

21 necessary accounting and reporti ng stru ctures, Exe l on 

22 b egan making annual contribu tions t o the Schuylkill 

23 River Restoration Fund . The Sch uyl kill River Heritage 

24 Area acts as the administrator and t he manager of this 

25 grant program, redistributi ng Exelon ' s co ntribut ions 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
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6 4 

1 t o local and regional watershed groups, con serv ati on 

2 organi zati o ns , and local g overnment agenc i es f or 

3 project s add ressi n g the q uality a nd q u antity of 

4 Schuylkill River water . Projects f ocus ing on 

5 agricultural remediation , abandoned min e drainage , and 

6 stormwat er runo ff are supported t hrough this p r ogram. 

7 To d a t e , Exelon ha s cont r ibuted over $1 . 2 

8 million t o the restorat i o n fund f or wa t ershed - wide 

9 projects. Twent y- t wo g rants have been awarded a nd 1 1 

1 0 project s have been completed . These project s have 

11 made a n i mpac t on t he water quality and quantity of 

12 t he Schuyl kill Ri v er which is a sou r c e o f d rin king 

1 3 wa ter f or over 1 . 7 5 milli on people i n s out heastern 

14 Pennsylvani a . 

1 5 Ex e lon ' s establ i shment and c ontributio n t o 

1 6 t he restoration f u nd has been a model p rogr a m and is 

1 7 now a uniquely valued public/private partnership as 

18 s eve ral new partners have j oined e fforts and made 

19 t heir own contributions to t h e fund . Bot h the 

20 Philadelphia Water Dep artment and the Partn ership for 

21 t he Del aware Estua ry have b rought f unding to the 

22 program and supported regi o na l watershed projects. 

23 The con tributions made by Exe l on have been the 

24 catalyst to l everage additi o nal fund s wel l over 

25 $600 , 000 for area r estoration . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
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65 

1 The goal o f the Re storation Fu nd Advisory 

2 Commi ttee is to b e able t o support a sustainable level 

3 o f half a mi l lion d o llars a nnually for the fund a nd in 

4 turn , conservation pro j ects t ha t will conti nue t o 

5 e nsure the f uture hea lth o f the Schuyl kil l River. 

6 In additi o n t o our work o n the res t oration 

7 fund , we have assist e d Exelon Nucl ear, East Coventry 

8 Town ship, and Chester County in a p l a nning eff ort t o 

9 begin the p r ocess o f rest o ratio n and preservation o f 

10 t he his t o r i c Fricks Locks Vi l lage . Earli er t his year, 

1 1 Ex elon Nuclear, the current owne r s of the v i llage , 

12 signed an agreement wi t h East Coventry Township t o 

13 stabilize , rehabilitate , a nd protect several of 

14 Chest e r County ' s oldest build i ngs . Exelon has agreed 

15 t o spend $2 . 5 mill ion to resto re t he exterior of 

16 several b uildings as stabi lized ruins . A fen ce wil l 

17 be built around the grou nds and t he corporati o n is 

18 donating four ho uses to the t ownship worth an 

1 9 e stimated $1 million. 

20 In additi o n , the corp o ra tion has agreed to 

21 continue t o do routine maintenance on the v i llage and 

22 work with the loca l historical society to host guided, 

23 historic and educati o n a l tours for t h e pub lic . 

24 From ou r perspective , mu ch o f the success 

25 o f t h i s pa r tnership can be assi g ned to the h ard wo rk, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
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1 dedicat ion and personal commitment of Exelon staff and 

2 management . Based on the very positive community 

3 programs and i n volvement we h ave experienced and 

9-1-SR I 

4 witnessed first hand as a regional organization , we 

5 would like to communicat e our support for the 

6 r e l icensi ng and contin ued operati on of Limerick 

7 Generat i n g Stati o n . Thank you . 

8 (Ap p l a u se . ) 

9 FACILITATOR BARKLEY : Okay, t hank you . 

10 The next t hree p eopl e I would like to c all , Bill 

1 1 Vogel , fol l owed by Eileen Dautrich, is tha t how you 

12 s ay that ? 

13 MS . DAUTRICH : Da utrich . 

14 FACILITATOR BARKLEY: Daut r i ch . Okay. 

15 And then Bi l l Al bany. 

16 MR . VOGEL : Hi , my name i s Bil l Vogel . I 

17 live i n Phoenixvill e . Units 1 and 2 had an i n i t i al 

18 life expectancy of 40 years . They are now asking to 

1 9 increase that 20 years, a f ull one thi rd increase . 

20 Everything has a life expectancy, machinery, as well 

21 as people . Demographi call y , my life expectancy i s 74 . 10-1-LR 1 

22 If I was to get a one third extension, like the 

23 Limerick plant wants, t h at would take me to 111 . What 

24 do you think is going to happen to me between age 74 , 

25 my life span, my namepl ate capacit y , and t he year when 

(202) 234-4433 

nL.ML. "-• U"-V»» 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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67 

1 I reach 111? I t ' s going to go d own hill . That ' s 

2 l ifecycle . Machine ry has them. You don ' t n eed a n 

3 e ng ineer t o t ell you that . Just l i ke h uman beings 

4 h a v e t hem . We b e come less e ff ect i v e , less effi c i e nt, 

5 less compe t e nt . 

6 The significant differen ce is my f a i lure 

7 will b e containabl e . Limeri c k ' s most likely wi ll n o t . 

8 If I drive over you with my ca r because I no l onge r 

9 see as we l l or h ave t h e re flex es I o nce had, t hat ' s a 

10 t ragedy for you , your f amily , f or me a nd my famil y . 

11 The s p here o f t h e tragedy is containabl e . I f Limerick 

12 Uni t 1 o r 2 fails, a l l h e l l breaks loo se , no 

13 disrespect . That ' s what a nuclear fa ilure is, hell. 

14 It affects everyb ody in t his r oom, everyb ody in t he 

15 c ommunity, everybody i n the t r i -state a rea , not for a 

1 6 week , but for decades . It' s very, very last thing we 

17 want to happ e n . 

18 And I think we ' r e putting ourselves in 

1 9 harm ' s way by taki ng s omething that had a lifespa n of 

20 40 years and adding anot her 20 to it. It doesn ' t make 

21 sense . Th e onl y way to rationalize it is t h ro ugh our 

22 p ersonal fear o f b eing i nconvenience d b eca use we lose 

23 a very, very good sou rce of power . It ' s done a great 

24 j ob for u s . But like me , you get to a point where 

25 your abi l ity to prov ide a g rea t j ob is at an end and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

10-1-LR I 

Cont'd 

10-2-

0R I 
Appendix A

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6 8 

1 thi ngs start d eteri orati ng . Let ' s not put ourselves 

2 i n that position . Let ' s make an i nt ellig ent decisi on 

3 now a nd allow these t wo u nits t o expire at t h e i r 

4 namepl a t e time . Thank you . 

5 (Ap p l a u se . ) 

6 FACILITATOR BARKLEY: Thank you , Bi ll. 

7 Eil een . 

8 MS . DAUTRICH : Good a f t ernoon . My name i s 

9 Eileen Daut rich . I ' m president o f the Tri - Count y Area 

110-2-0RI 

ICont'd I 

10 

11 

I ' m happy to be here t od ay t o I 

,..,u.....,....=-=..., 

p r ovid e e xampl e s of how Limeric k Gene r a t i ng St a t i o n is j1 1-1 -SR I 

f:;hambe r of Comme rce . 

12 a val ued communit y and b usi ness part ne r a nd e c ho t he 

13 s t at eme nts a l r eady s h a r e d by seve ral o thers . 

14 The y ' re one o f t he tri-cou n t y a rea ' s 

15 largest e mp l oye r , provi ding profess ional employment 

16 p pport uni t i e s for l ocal residents . Those local 

17 resi dents emp l oyed by Li merick Generating Stat i on are 

18 s upport i n g the entire t r i - cou nty bus iness community . 

1 9 rrhey ' re p urchasing per sonal good s and servi c e s from 

20 local smal l businesses. The annual outage i s a 

21 tremendou s benefit t o the local economy and our local 

22 si esses . Limerick encourages their outage 

23 employees to visi t and purchase f rom tri- county area , 

2 4 local b usi nesses, a nd s mall businesses . 

25 In a dditi o n t o t he jobs t hey p rovi de l o cal 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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69 

1 residents, t h ey ' re making a signi ficant investmen t in 

2 

3 

4 

5 

6 

o ur local communi tie s . Municipalit ies and residents 

benefit from assistance received from Limerick t o j1 1-1-SR I 

ICont'd 

start, maintain, expand parks, recreat ion , and quality 

o f life opportunities. 

Their corporate c ulture o f g i ving back t o 

7 the community i s practi ced by their hundreds of 

8 empl oyees . Nonprofit o rganizations are support ed by 

9 Li merick Generating Station and t he efforts o f their 

10 empl oyees . Finan c ial donati o ns , as well as v o l unteer 

11 hours and time are d o nat e d , enabling our local 

12 nonprofits t o provide t h e much n eeded servi c es that 

13 impa ct t hose in n eed throughout the tri- county area . 

14 The Limerick Ge ner ating Stat ion is 

15 c onfident i n the clean and safe environment they 

16 ma i ntain in our community . The commu nity has been 

17 invited t o experience the generati ng stat i on 

18 f i rsthand . The chamber hosted a membe rship breakfast 

1 9 and t he site vice presiden t , Bill Maguire p rovided the 

20 keynote p resent ati o n . He s ummari zed safety measu res 

2 1 and advancements at Limerick and answered questions 

22 p ertaini ng to the Limerick plant and its safety i n the 

23 wake of the tsuna mi i n J apan . 

24 In addition, after our breakfast, Chamber 

25 members were encouraged to a t t end t he i n f orma tional 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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71 

1 see p o l i cies a nd procedures t h a t people t al k about and 

2 they ' re put up o n a shelf and they ' re followed a t best 

3 haphazardly with a wink a nd a n o d and deviation from 

4 the policy is n o t addressed . 

5 One of the things tha t I ' m c o nti n uously 

6 i mpressed a t LGS whe n I visit is t he i r sound adhere nce 

7 t o policy and pro cedu re . They do n ' t deviate from it. 

8 I ' ve been t o numerous drills a t t he plant , numerous 

9 exercises at the p l a n t , some o f which were run by t he 

10 NRC and I ' ve never seen t h e m fail . The y always come 

11 o u t o n t op . In fact , in 2009 , Limerick was selected 

12 as a s i te f or t he f i rst comprehen sive pilot exercise 

13 invol v i ng federal , state, and local law enforce ment 

14 SWAT teams t o a c tually g o i n to the power blo ck and 

15 c onduct t actical operati o ns in t h ere , and tha t drill 

16 was us ed as a boiler plate t o deve lop pol i cies and 

1 7 procedures f or implementation in power plants 

18 thro ughou t the country. 

1 9 One of the I ' m s o rry, I don ' t believe 

20 that cont i nue d operations o f the power p l ant would 112-1-SRI 

2 1 h ave any detrimental effect o n p u b l ic safety i n the 

22 southeast regio n . Tha n k you . 

23 (Applaus e . ) 

24 FACILITATOR BARKLEY : Okay, thank you . 

25 I ' d like t o call the fi nal t hree speakers who have 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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72 

1 signed up , John McGowan , Ted Del Gaizo , and Timothy 

2 Phillips. John? 

3 MR . McGOWAN : Thank you very much . My 

4 n ame is John McGowan and I a m a l i f e - long r esident of 

5 the Delaware Valley. I have lived half o f my -- or I 

6 should say the Limerick Nuc l ear Power Station has been 

7 ope rating for half o f my l ife . I own three 

8 manu f act uri ng companies i n the Ma lvern area and employ 

9 a number o f people in those faci l ities who r ely 

10 t remendously on the Limerick Power Generating Station 

1 1 t o supply safe , reliable e lectrical power t o keep us 

12 operat ing . 

13 Today, I would like to say t ha t in all of 

14 the years t h at I ' ve lived in this area , I ' ve never 

15 worried at all about the safety of the nuclear power 

16 plant . I see it every day. And it bothers me not in 

17 the l east . I have never seen any credible evidence t o lr-:-13:!--1-:-_-::S::-R;::::-'J 

18 suggest t hat there are safety problems with this 

19 plant. In t e rms o f reliability, it is the same . It 

20 is running 2 4/7 , 365 days a year and it has b een doing 

21 so for a quarter of a century and I hope it continues 

22 to do so for ma ny more years to come . 

23 As far as its environmental impact , I 

24 thi nk it ' s pretty widely known that nuclear p ower is 

25 o ne of the cleanest environmental energ ies tha t we 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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7 3 

1 p ossess t od a y throughout the world and t o dismiss it 

2 is I t hink a foolis h n oti on . 

3 The impact o f the Li merick plant in our 

4 r egi o n h as b een extraor dinaril y positive . It 

5 provides, as we all know and h ave heard t oday, lots of 

6 j obs, l ots o f good jobs, tax r even u es for schools, 

7 local governments and for t hos e who live in the area 

8 t o e n joy the fruits o f publi c services and it a lso 

9 p r ovides a lot of charitabl e d o nations t o t he 

10 communi t y whi c h is ver y important . 

11 I think that t o not keep this plant 

12 running a nd not cons i d er a renewal of its l icense f o r 

13 an extended period would be a tragic mistake fo r all 

14 o f us and I would like to e nd t h i s b y saying t hat t he 

15 o nly meltdown that wo uld c o ncern me is t he eco nomic 

16 one that certai nly wo uld happen t o thi s area should 

17 this p l ant not conti nue to operate . 

18 (Applause . ) 

1 9 FACILITATOR BARKLEY: Ted , go ahead . 

20 MR . DEL GAIZO : Hi , my name i s Te d Del 

21 Gaizo . I ' m a registered professional engi neer i n the 

22 Commonwealth of Penns y lvania . I ' m also presid ent and 

23 CEO of a small business e ngineering firm in nearby 

24 Exton , Pennsylvania . 

25 

(202) 234-4433 

My exp eri e nce in n uclear p ower goes back 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

13-1-SE 

Cont'd 
Appendix A

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74 

1 t o the 1960s where I spe n t 14 years i n Navy submarines 

2 a nd I p ersonally operated , maintain ed , a nd r efuel ed 

3 nuc l ear power plan ts during tha t period . 

4 But I ' m he r e today as a priv a t e c itize n , 

5 as a resident o f the area a nd as a member o f the 

6 Pennsylvani a Energy Alliance t o go o n r ecord a nd say I 

7 strongly favor l icense r e n ewal for the Limerick 

8 Genera t i n g Stat ion . I say t hat because i n my pers onal 

9 experienc e I know in spit e o f s ome of the t hings 

10 you ' ve probably h ea rd here t od ay, nuclea r power i s 

11 safe , reliable , secur e and c l ean . But i n additio n t o 

12 t hat , I would l ike t o go o n record , I woul d l i ke my 

13 nei ghbors t o know we are lucky t o have the Lime r i c k 

14 Generat i ng Station i n t h i s area . In the i ndustry, i t 

15 has a top reputat i o n . It is one of the fi nest nuclear 

1 6 p ower plants i n America . And Exel on , i f not the best , 

17 is certainly one o f the f i n est n uclear operators in 

18 the world . 

1 9 I have no thing but confidence t hat Exelon 

20 will work together with the NRC , will run thro ugh the 

21 process and we wil l come up with t h e r i ght concl usion 

22 here which is license ren ewal s h ould b e granted to the 

23 Limerick Generating Station . I think we n eed to keep 

24 Lime rick operating as long as we can . 

25 

(202) 234-4433 

In a ddition , in spi te of some other t h ings 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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76 

1 openness in the thinking process t hat goes into place 

2 for renewal of any nuclear power plant . 

3 And so f rom my perspective as a citizen, 

4 as a business person who h as worked i n this community, 114-2-SR I 

5 I understand the value t his is to t he r egion . And for 

6 , I a pplaud the NRC f or what they ' re doing here . I 

7 applaud Exelon fo r the g reat work that t hey ' re doing 

8 t here and I e nco urage the renewa l process t o take 

9 p lace . Thank you . 

10 (Applau se . ) 

11 FACILITATOR BARKLEY : Thank you . Wi t h 

12 t hat , I have all 15 people who had signed up f o r this 

13 meeting , have been call ed . Is there anyone else who 

14 would l i ke to make a short follow- up r emark or woul d 

15 like to stil l speak at this poi nt ? 

16 Okay, if not, I ' d like to make two points 

17 before we wrap up . One , the NRC does have public 

18 meeting feedback fo r ms whi ch give us feedback on how 

19 you think thi s meeting was cond ucted , so I would 

20 greatly app reciate you filling out one of those forms 

21 for us so that we can learn how to i mprove . There is 

22 another session of this meeting at 7 o ' clock tonight . 

23 You ' re welcome to speak again tonight . 

24 And secondly, what I ' d l i ke to say is I 

25 facilitate a lot of meetings throughout t he Northeast 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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27 

1 meeting via c o nference bridge . And due to the 

arrang e ments of the audio in this room i t wasn ' t 

p ossible t o do it any other way than a cell phone . So 

we ' r e going to go to h im a nd ask him to make a 

stat ement f or the period and move from there . So our 

first speaker will be Mr. Thomas Saporito who is a 

s eni or consulting ass o ciate and he actua lly lives in 

Florida . So as soo n as we can work having him on t he 

mi crophone we will have him ma ke his statement . Are 

1 we free t o give i t a try? 

MS . REGNER : Go ahead . Yes . Go ahead, 

1 Mr . Sapori t o . 

1 MR . SAPORITO : Is it my t urn t o speak? 

MS . REGNER : Yes . 

1 MR . SAPORITO : Okay . Can you hear me 

1 oka y? 

FACILITATOR BARKLEY : As best we can , yes. 

1 MS . REGNER : Yes , go ahead . 

1 MR . SAPORITO : All r ight . My name is 

2 Thomas Saporito . I ' m the seni or consu l tant with 

Saprod ani Associates and I ' m l o c ated i n J upiter, 

2 Florida . I woul d like to comment on the NRC ' s 

2 environmental r e v iew but before I d o that I want t o 

state that, yo u know, I ' m very upset at the NRC ' s 

2 refusal to honor my enf orcement p e tit ion filed under 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

16-1-os 1 
Appendix A

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2 8 

1 10 CFR 2 . 2 06 wit h respect t o the Limerick n uclea r 

plant . The NRC den i e d that p e t iti o n on the basis that 

I would have an opportunity t o intervene on this 

proceedin g thro ugh the NRC ' s j udicial p rocess. 

Howeve r , t hat ' s not availabl e to me . I made that 

q uite c l ear in t he 2 2 06 petit ion . Now, I d o n ' t have 

standing as a Un i t e d Stat e s cit izen becaus e of my 

physical location i n Jupiter to intervene in a 

proceeding in Pe nnsylvania where this p l a n t is 

1 located . The NRC s t aff is inco rrect in their opinio n 

and they have a l e g a l obligati o n to honor that 

1 enforcemen t pet iti on and t o provide a n opport unity f o r 

1 me t o address the Peti tion Review Bo ard . So I want t o 

put t hat on t he reco rd and I'm as ki ng t he NRC to l ook 

1 into t h at issue . 

1 Wi t h respect to t his e nvironmental 

petit ion the fel low who spo ke earlier from t he NRC, I 

1 don ' t r ecall his n a me . It was very ha r d f or me to 

1 hear t hro ugh this communication his name . But anyway, 

2 one o f his comments was e x cep t i on a l l y incorrect and he 

misinformed the p ub lic . And I ' d l ike to correct that 

16-1-0SJ 

Cont'd I 

2 statement . 16-2-LR I He stated that the NRC is e x t e ndi ng t he 1--r-----' 

2 original operating license whi ch was gra nt ed by the 

NRC f or a 40 - year period o f time that that initial 40-

2 year l ice ns e was not based o n safety considerations o r 

(202) 234-4433 

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COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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29 

1 echnical considerations. But that ' s absolutely not 

rue and there was recently a year- long investigative 

4 

eport done by t he Associated Press who int erviewed 

t-:1~6 2::--:-: L R::::-ol 

:oxpert nuclear personnel , engineers, safety engineers Cont'd 

~ n the nuclear industry who told them tha t the 40 - year 

E i censes issued by the NRC f or 104 n uclear plants in 

7 he Unit e d Stat es was based on sa f ety and t echni cal 

afety techni cal analysi s . So these proceedings, 

c hese license extension proceedings like the one we ' re 

1C :;urrent ly a t are a rubber- stamping of these 20- year 

11 icense extensions. Thi s is i n fact a foot r a ce 

1 2 between the Nucl ear Regulato r y Commission a nd t he 

L ' Uni ted St ates Congress where Congress wants to s t op 

1 4 t hi s process, put a moratorium on the re- l icensing 

16-3-LR I 

1 " until the Fukushima disasters can be fully understood 

1E and the enhancement enacted in August for o u r power 

1 7 ::>lants here . This particular nuclear p l ant , these 

1 c ::>lants , you know, their license is a lready good till 

024 . Why are we here now 1 2 years ahead of time 

2C rying to extend this license? And the only reason is 

21 ::>ecause it ' s a foot race t he NRC ' s in with Congress 16-4-LR I 

nd nothing more . This has nothing to do with 

2 ::>rotectin g public health and safety, it ' s the NRC ' s 

2 4 eal to continue to rubber- stamp these license 

2 ~ 2xt ensions wit hout allowing citizens due p rocess li ke 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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1 

30 

I already tal ked a b out a nd without doing a cost 

i n tense and t horough e nvironment a l r eview. 

And with respect to t he NRC ' s 

environmental review the NRC i n my v iew f ail ed t o 

pro p erly con sider t h e embri t t lement o f this n uclear 

eactor vessel . When these nuclear re actors are 

::>pe rating the neutrons cause the me t a l i n the react o r 

vessel t o become brittle over t ime . And a f t e r 

nume rous y ear s of ope rat ion these reactor v essels 

coul d crack because t hey ' r e s o brittl e . But t he NRC 

::lo esn ' t properly evaluate that and the NRC doesn ' t 

equire the licensee t o d o dest ructive test i ng a nd 

a na l ys i s of the reactor ' s meta l vesse l pri or t o 

ubber - s t amping a 20- year e x ten sion t o these l icenses. 

Twe nty years f r om now, o h actually 20 years from 202 4 

w-hi ch wi l l be 204 4 t his react or is goi ng to be even 

more c rit ically brittle and the NRC ' s not going t o 

understand the dynamics of t ha t and t he r e actor could 

c r ack and i t ' s going to melt d own because you can ' t 

ecover from a loss of cool ant accident of that 

magnitude . So that ' s one point . 

The other point is the NRC ' s Commi ssion 

I 

16-4-LR I 

Cont'd 

16-5-0S I 

::>ver there in Rockville, in the Whit e Flint Bui l ding, 16-6-0 SI 

hey recentl y a d op ted a new p olicy with respect to 

evacuat ions . 

(202) 234-4433 

The y want these licensees t o update 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-214
Appendix A

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32 

1 would actuall y have t he licensee shut down more of 

their other power p lant s because o f yo u would need a 

demand . I f you t a k e wind energy which is plentiful up 

there in Pe nnsylvani a and ev e n the n ew sol ar pa n el 

whi ch can operat e when t he sun isn ' t shini ng on a 

cloudy day you could r e p lace even more ope rat ing powe r 

plants. So the s e renewable e nergy s ources ev e n with 

r espect to wi nd energy s i nce you have a common gri d 

throughout t he United St a tes you can have wind farms 

1 g enerat e powe r t o a common g rid point a nd s upplying 

the powe r t hat t he se nucl ear p lants are now providing . 

1 The NRC ' s required under the law t o consider these 

1 a l t erna t i v es t o extending t his l icen se . And I woul d 

hope t h at the NRC ' s f i nal evalu ation and revi ew shows 

1 a c omplete and t horou gh analysis o f all t hese 

1 renewab le energy sources including i nstal ling ondemand hot water electric h eater and doing an analysis 

1 o f how many megawatts you ' r e go i ng t o take off the 

1 gri d and based on those eval uations make a l icensing 

2 determination whether or not this l icense should b e 

extend ed . Because 20 years from now all these 

2 renewable resources are going to be all that much more 

2 advanced and capable of supplying all that much more 

p ower t han they ' re currently s upplyi ng . So those are 

2 my comments a nd I would hope t hat the NRC t a kes them 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

16-7-AL I 

Cont'd 
Appendix A

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33 

1 seriously and applies t hem to t his lice nse r enewa l . 

And I hope everybody heard me . 

(Applause) 

MS . REGNER : Can you hear t ha t? They ' re 

c lapping . 

FACILITATOR BARKLEY : Okay, a t t his point 

I ' 11 call back Mr . Sapo rito later and thank h im f o r 

his r emarks and fo r being s u ccinc t in his remarks. 

I t ' s awful l y awkward t o provide comments v ia this 

ave n ue . 

The first three people I would l ike t o 

call are act u a l ly i nd ivid u a ls who did not speak this 

afternoon s o I ' d l ike to start with them. Firstly, 

Jeff Chumnuk , then Danie l Ludewig , and t hen fi nally 

Cat h e r i ne Al lison . So Je ff, if you c oul d l ead off. 

MR . CHUMNUK: Hi , my name is Jeff Chumnu k 

and I ' m a member of Borough Counc il with Pottstown 

Borough . And my comments t oni g ht are more I g uess 

f r o m my perspectiv e as a newly elected o f ficial with 

the g enerating station . About a year ago I h ad the 

opportunity t o go d own to the genera t i ng station and 

1.-:-::L..:-=:-=--, 

17-1-SR I meet with Joe Sa ffro n and the fi r st part of my meeting 

h ad to do with looking for some s upport for the 

Pottstown Soapbox Derby. Th rough some conversation 

while we 

(202) 234-4433 

were s tanding outsid e 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

you know Joe 

www.nealrgross.com 
Appendix A

A-217

34 

1 e nlight ened me a litt le b it on what Exelon and the 

generat i ng stat ion do f o r t he surrounding communities, 

whether it' s suppo rting o u r f i refighters, police 

d epa rtments and other civ ic o rganizatio ns . Yo u know, 

from a Pottstown perspe cti ve they help us with our 

y ea r l y b o r ough cleanup, o ur Salvat ion Army and now t he 

Soapbox Derby . Thank yo u . 

And we we re standi ng o utside that day, it 

was pret ty nice out, and o u r c o nversatio n l ed to t he 

1 power p lant i t sel f . We were s t anding there loo king 

around , it ' s a pretty i mpressive sight . So I asked 

1 h i m about, you know, possibl y havi ng a tour f o r 

1 municipal offi c ial s . He said he woul d look i n to it 

and see what he could d o . A couple of months later he 

1 got a group o f about 20 o f us and gave us a t o u r of 

1 the plant one evening . And I have t o say t hat from 

the time we walked through the fro nt gates and p ast 

1 the security as o u r t o u r p rogressed , you know, 

1 throug hout t he plant safety was p aramount . Whether 

2 you were having explained what the different col ors 

are on the different panels and what t hey mean to 

2 different f a i l safes, why you walk certain areas 

2 certain ways a nd what lines you had to stand behind, 

you know, safety was pa r amount with them . You know, 

2 from the e nvi ronment, I ' m looking around and t his 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

17-1-SR I 

Cont'd 
Appendix A

A-218

1 

35 

p lace is spotless . And I asked why and it ' s because 

they can ' t afford to have d irt or lint or fuzz ba lls 

around b ecause o f static e lectricity becau se it could 

create issues. So f rom t ha t aspect I thought i t wa s a 

good t o ur and it made me feel good about the safety 

aspect s there . 

To finish o ur tour we ended up in the 

contro l room upstairs. And I ' d say maybe a dozen o r 

s o i ndivid ua l s up there monitoring you know everything 

goi ng o n within t he p l ant and around t he plant . And 

again , expl aining t h e failsafes and why t hey ' re 

I.-1......J7'--1--S=-:R=--"'I 

It Cont'd doub l e -, triple- check ed t o e l iminate human erro r . 

was jus t very impressi ve a nd as an e l ected official t o 

go down and t ake a tour of the p l ant a nd u nderst and 

how it operates . I know when I left I personal ly know 

how to issue a concern with the generating stati on . I 

know I fe lt a lot better and a lot safer going home 

that night . And i t was also good to realize , you 

know, as one o f our region ' s largest empl oye r s now 

that they are wi l ling to give back to the community 

a nd keep safety first. So t hank you, I just wanted to 

ma ke t hose comments . 

Daniel? 

(202) 234-4433 

(Applause) 

FACILITATOR BARKLEY : Thank you , J eff. 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

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1 

36 

MR . LUDEWIG : I ' m Dan Ludewig . Just two 

q uest ions . One would be what are we going t o do with lo.:':-:--::::-:-:-:"1, 18-1-RW1 

1 

the 20 years of spent rods and how are you going t o 

t a k: e care ot those . And secondly, l t we d o n t get the 

license which I doubt but what woul d -- how woul d we 

get electric if the license were canceled? I don ' t 

know who answers this . 

FACILITATOR BARKLEY : I ' l l ask Lisa t o 

speak . 

MS . REGNER : Yes , the spent fuel rods. 

Limerick is l icensed for an individual spent f uel pool 

facil i t y . They off load t he spent fue l . Once t hey ' ve 

c oo led t o a cert ai n level they will p ut t hose into dry 

cask storage and store tho se onsite . In t he 

environmen tal review that ' s l ooked at generi cally. 

Limerick does have storage for the spent fue l r ods. 

That ' s a n o ngoing , it ' s o nsite and part of their 

reactor oversight process as well . So t he residents 

that work at the plant monito r the s a fe operation of 

those fac iliti es . 

The second question , where would the power 

come f rom i f Limerick were shut down? There a re 

alternate p ower facilities in the area . Dave , you 

want to give that a try? 

MR . WRONA: I ' m David Wrona , a branch 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

18-2-0S I 
Appendix A

A-220

3 8 

1 Can e v eryone hear me i n the back row? I am Catherine 

Allison a nd I was born and raised in this area so as 

far as t he NRC wanting to know how t his impacts the 

area I know it very well . I ' ve also t raveled the 

world so , Europe , et ce t era . So did anyone not be 

abl e to hear me , just r a i se your ha nd . You ' re good? 

Okay . 

One thi ng I wanted t o say is the NRC 

t oni ght is doing a scoping b asically for e nvironment al 

1 p u rposes f o r t he re - licensing. Wha t I wanted t o say 

is for years everyone , I ' m being general he re , but 

1 most peopl e have been t a l king abo ut t h e e ffects of 

1 l ike , you know, cancer, you know, the impact on t h e 

clean air, c lean water which things we are a l l 

1 concerned about and a lot of us just didn ' t do 

1 anythi ng about i t even t hough we were very concerned. 

Now l ately with the -- unfortunatel y it' s 

1 a reality now that we have hurri canes , more tornadoes, 

1 tsunamis throughout the world . And I hate to say it 

2 but it i s a reality now that we have terrorist attacks 

and Limerick is definitely one . I don ' t want to be 

2 blowing t his out of proportion but it ' s just something 

2 that I know that we ' ve all been concerned about , not 

wanting to say yes, Limerick, and all the people that 

2 built the power p l a nt and the company s ay o h , t here ' s 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

1,-,-:,-'-:-:-:--. 

19-1-PA I 
Appendix A

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39 

1 no impact to the air and the wat er pollution and so 

f orth . So we ' ve kind o f j ust b linded our, you know, 

selves to tha t and l et ' s believe then , o kay, let ' s 19-1-PA 

Cont'd 

a ke a mi nut e . Let ' s really b elieve tha t there is no 

mpact i n our clean air, clean wa t er a nd those type of 

hi ngs and cancer, e t cet era . Let ' s just go into t he 

new rea l ity which is terrorist a t tacks which would 

happen . Let ' s j ust say for example ther e was human 

error there with the spent fue l rods and s omething 

happened , o r a radi ation lea k . I j ust d r ove toni ght 

rom King of Prussi a . Talk about evacuation when 

hese natural disast ers and realities hit us . One 

a cci dent, two hou r backu p , a lmost no exaggerat ion, one 

housand cars. The re wil l be no evacuati on . I don 't 

want t o be l ike scare tactics here but like I said, 

he weather and s o forth , na tural d isasters has really 

bee n hitting t he whole United States and the worl d 

ately so it' s a reality . 

There was flooding after the h u rri cane 

hat we just had . Five days later there was roads 

lased in Pottstown , i n North Coventry, East Coventry. 

There were , when I tri ed to get home from work right 

~n Route 724 , no e x aggeration again from all the back 

oads ab o ut 500 cars. There will be no evacuation and 

certainlv hope that p eopl e understand I ' m not trvino 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

19-2-0S I 

I 
Appendix A

A-222

1 

40 

t o b e scare tactics . I see this . I ' m sure a lot of 

you have seen this and been in these situations. All 

with a little bit of f looding . What t his does to 

1-:- 1 9- --::::"""8,...,1 

the Cont'd 

r oads. Aoain there will be no evacu ation . 

So from day one I think power plants never 

should h ave b een built but now t hat they are 19-3-0R I here whY \--r---...1 

would we ever want t o re- license . And as our 

gent leman cal ler just said, I believe his name was 

Thomas , he was very eloquent . He was stat ing the f a ct 

why are we re- li c ensing t hem, what, 1 2 years ahead of 

t ime . To me that is absurd . Like maybe a year before 

o r they have t o do s ome studies, two years before . 

Why do they and l ove Thomas ' s wo r d s , r'-:-::-1--:-:--:--, 

19-4-LR I 

want us, I 

rubber- stamp something? Twe lve years beforehand to go 

into what , 202 4 for Unit 1 was it and 2029 for Unit 2? 

Why do they need to push this licensing re newal? 

You ' ve got to stop and think . Peop l e , go home , think 

about that. I ' m not an expert like evidently our 

cal ler Thomas was but again , I ' m concerned about human 

life . This is what I have at the top here . We are 

a l king a b out human life . What ' s more important , not 

all this electricity that we need for all ou r cell 

phones and everything . In a way we are responsible 19-5-0S I 

-For the fact that PECO and all these other Exelon 

omp anies are buil ding power plants. 

(202) 234-4433 

1'11:1\L "· U"U;;);;) 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 

I myself you 

www.nealrgross.com 
Appendix A

A-223

4 1 

1 Know am gu11ty or a lot or tn1s but let s JUSt maybe 

for a solution besides the wind a nd solar power and 

everyt hin g stop usi ng all t his new tec h nology . Yes, 

4 you need it for some j obs and businesses, it ' s good 

~ for certain t hings, but let ' s not overindulge where we 

E need so much electricity that we are willing t o risk 

7 o u r lives. Cancer, polluted water. There ' s no 

dri nki ng water anymore . Peopl e have t o pay to buy 

c wa t er that comes from natural springs . But you ' re 

1C usi ng plastic bot tles, you can 't even trust t hat. 

11 But this whole world has kind of just 

1;; changed from you know nature . Let's get back t o 

L ' n at u re , let t h e -- i nstead o f having all the young 

1 4 t eenagers on their c ell phones texti ng , using more 

1 " electricity, that again it ' s going to cause cancer for 

lE them . Everyb ody has to stop and think why do we need 

1 7 the powe r p lants? We really don ' t and again , Thomas, 

1c o u r wonderfu l caller mentioned some a l ternatives like 

1 S the solar power, wind, but I ' m just saying we are 

2C using so much electricity and stupid little v ideo 

21 games on the computers. People get on the computers 

for hours at a time doing nonsense . That ' s taking up 

2 electri city where again why do you need all this 

119-5-0SI 

ICont'd I 

2 4 cancer in your I 

not that young 6~- ~1 

electrici ty? It could be causing 

2 ~ children . 

(202) 234-4433 

I am not t h a t old but I ' m 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-224

1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

42 

1 but I hate to tel l you I h ave so many friend s and 

c owo rkers a nd peop le that are only 35 , 40 , 50 years 

old, cance r . And wh y? We have to stop and t hink . Go 

home , don ' t j ust always, you know, jus t go watch TV 

a nd get o n your computer. 

doi ng to o urs e lve s , o ur 

g randchildren . 

Stop and think what we ' re r-:-:'f--:::-_:-:-:--:-~I 

Cont'd bodi es, our children, our 

This i s agai n , t his l i censing renewa l is 

c omi ng d own t o human l ives, the quality o f o ur liv es. 

Again , wh y a l l t his c ancer? Mi crowaves and 

electricity . So I won 't go on and on, b ut I just 

t hi nk us a s a group can ' t just all be j ust complaining 

about the power companies, we a re t he o nes using t h e 

electricity . That ' s a l l I ' m saying . Maybe we s hould 

cut back and we won ' t need power p lants. Tha n k you . 

(Ap p l a use) 

FACILITATOR BARKLEY: Thank you, 

Catheri ne . The nex t t h ree p eople I ' d l i ke to c all 

would b e Jeff rey Nort on o f the P. Energy Al liance , 

then Bi l l Maguire and t hen f i nally Lorra i ne Ruppe . 

Mr . Norton? 

MR . NORTON: Good e v ening . My name is 

J effrey Norton a nd I ' m here to represen t the 

Pennsylvania Energy Al liance which i s an independ ent 

2 grassro ots diverse organi z a t i o n made up of c ommun i t y 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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43 

1 leaders a nd org a ni zati o n s who promote nuclear power as 

a clean, safe , r e l iable and affordable sou rce of 

p ower. I ' m going t o be ma ki ng essentially five points 

i n s u pport o f l ice n se renewal for Limerick Generating 

Stat ions and they are that , number o ne , nuclear energy 

lowers e l ect ricit y prices, i t pro tects our environment 

against greenhous e gas e s , it strengthens o ur local 

economi es and it is sa fe . 

Wi th regard t o my f i r st p o int in lowe r ing 

e lectricity prices the Limerick Ge nerati ng St ati o n has 

reduced wholesal e energy co sts i n Pen n s y l vania by $880 

mi llion i n 2010 thus l owering elec tri c ity pri c es f o r 

a l l c ons ume rs. I t operates around t he clo c k t he reby 

stabilizing t h e n ati on ' s e l e c t ricity dist ributi on 

system and t he e lect r i city ma rketplace . The average 

electricity prod ucti on costs at nuc lear p l a n t s have 

actually decl i ned mo re t han 30 perce n t i n the past 1 0 

years due to various effi ciencies . Nuclear p owe r is 

c heaper to produce than other f orms of electri city 

generation such as coal and nat ura l gas, and helps 

moderat e the pri ce of electrici ty for consumers . 

My n ext point is t h at Limerick Generating 

Station and nuc l ear plants strengthen ou r local 

economies and i t is a valu a b le economic driver f or the 

Commonwea lth o f Penn sylvania . Li merick Generating 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

20-1-SR I 
Appendix A

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44 

1 Station contributes $113 million a n nually in direct 

economic co ntributions to the Penn sylvania economy 

through various e mployee wages and salaries, p urchase 

o f goods a nd services from other Pennsylvania 

businesses and i n propert y tax payments to the local 

governments . Limer ick Generati ng Station also 

contributes generously as we ' ve also heard and i n fa c t 

1 

t empora ry contract e mp l oyees during annual refueling 

1 o utag es . A sign ifi cant percent age o f t h e cur rent 

1 n uc lear plant wor k fo r c e wi ll reach retirement age in 

t he next 10 years creating a demand f o r high- paying 

1 j ob s in t he nuc lear industry . Yes , Lime r i ck 

1 Generat i ng Station is one of Pennsylvania ' s mos t 

val u ab l e economic and energy assets and t h e 

1 commonwea lth should embrace it . 

1 My third point is that nuclear ene r gy 

2 p rotects our enviro nment from greenhouse gases and 

reduces the need to ge n erate e l ectri c i ty from fossi l 

2 f ue l s . I f Limeri c k Ge n erat i ng Station were retired 

2 from servi ce replacing t h e e lectricity wo uld requ ire 

increased nat u ral gas- fired or coal- fired generati on . 

2 Nuclea r energy is the nation ' s largest source of 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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1 

45 

carbon- free e l ectricity a nd is critical to our 

natio n ' s e nviro nmental, security and energy goals. 

My next point is t h at n uclear e nergy is 

safe . It ' s a lways on , it ' s stable, it ' s a r e liable 

s ource o f electricity and t he s t ati o n here a t Limerick 

has been b uil t with multiple redunda nt saf ety l ayers. 

And t he workforce is c o mmitted t o best practices and 

cont inuous i mprovement . I t i s also impo rtant f or our 

nat i o n ' s quest t o be energy- independent . According t o 

t he Bu reau o f Labor St atist ics it ' s safer to work a t a 

nuc l ear p lant than in i ndustries such as 

manu factur i ng , r ea l estate and fi nance . And according 

t o t he Department o f Energy a p erson r e c e i ves more 

radi a t i on e xposu re fl y i ng f r om Bal t imore to Los 

Ange l es than by standi ng near a nucl ear p l ant 24 hours 

for a year . 

On a personal no te I ' ve bee n i nside 

Lime rick Generating Stati o n several t imes . I ' ve also 

l ived within 3 0 mi les with my f our boys and wife next 

t o the Limerick Generating Sta t ion a nd a l so Th r ee Mil e 

Island . I fe e l safe , secu re and comfortable . Tha t is 

why I ' m in support of the re - licensing o f the Limerick 

Generat i n g Station . Thank you ve r y much . 

(Applaus e ) 

FACILITATOR BARKLEY : Tha nk you . Mr. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

20-1-SR I 

Cont;'d 
Appendix A

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5 4 

1 three people I ' ll call are Donna Cuthbert , fol lowed by 

Mi ke Gallagher a nd the n f ollowed by Dr . Fr ed Winter. 

Okay, Don na . 

MS . CUTHBERT : You k now, after hearing 

s ome of the s e gentl emen speak t o night I f eel like I ' m 

l i ving in f antasy land . For s omebody t o get up here 

and actually say t hat there ' s no advers e impacts f rom 

Li merick n uclear power plant i s insani t y . I t is 

unbe l ievable . I have s pent t he last 11 years 

1 revi ewing per mits from Li meri ck nuclear power plant. 

They are a ma jor a i r po l l ut e r under the Clean Air Act 

1 and to say they ' r e not d o i ng it anymore , t hey just 

1 asked f o r t he condi t i ons t h at wou ld all ow an eigh tfold 

increase in dange rous air pollutio n that a c t ua lly is 

1 claimed to ki l l people , thousands of deaths per year. 

1 And t hey asked f or an eightfo ld i ncrease . 

As a ma t ter o f f act , these are all t he air 

1 p o llution sou r ces and the pollutants they list in 

1 their own permit . If yo u add that t o a ll the 

2 r adiation emissi o ns there ' s a b road range of 

radionuclides. For some bod y to just c l aim that it' s 

2 o nly t riti um go i ng i nto t he water is insanity . It ' s 

2 unbelievabl e what they exp ect p eople to b elieve . I 

e ncourage ev erybody t o go b ack t o the table we have 

2 and take a good l o ok at that Schuylkill Ri ver boa r d . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

1-22-AMI 
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55 

They are destroying t he Schuyl kill River. There was 

never enough water in the Schuylkill River to sustain 

this nuc lear plant f rom t h e very beginning and now 

we ' re seeing the consequences of that and they put 

more and more pol lution in it. They want to pump mine 

wa t er in t o supplement the fl ow f or Limerick . It ' s 

cont aminated and they don ' t f ilter it . And they ' re 

act ually aski ng for a huge , fou r t imes Safe Dri nki ng 

Wa t er standard i ncrease in t o tal dis s olved solids 

whi ch carry a l ot o f t oxic pollutants. So t hey put 

radi a tion int o t he r i ver 24 hours a day, 365 days a 

year, and now t h ey ' re asking f o r these h u ge i ncreases 

and peopl e have the n e rve t o get up here and say that 

t hey have no environmental impact s . Frankly I ' ve had 

enough o f this deception at the expense of public 

.l T 

The facts s how, when we looked at Exelon ' s 

thi ng for environmental harms they say they were clean 

energy . The facts show Limerick isn ' t clean, it is 

ilthy. It ' s not safe , it ' s a ticking t ime bomb . And 

nuclear power, they say it' s a l ways o n . That ' s not 

rue either as evidenced by shutdowns, some for long 

p eriods caused by earthquakes, tornadoes , hurricanes, 

-Fires, heat and dro ught and more . It clearly isn ' t 

always o n in Japan . So when you take a l l of this 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

1-23-SW I 

1-:-:!-:--:::-:-1 1-24-PA I 
Appendix A

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56 

1 t ogether and yo u look a t all the ways that they 

p o llute o ur envi ronme nt with rad iat ion and all the 

othe r t oxics, every day Limerick operates our children 

f ace more risk. And t hat ' s what i t ' s all about . It ' s 

about the health o f o ur region . 

The sooner t h i s place closes the bette r 

o f f we ' ll all be . Even if you l oo k at i nfant 

mo r t alit y rates we have higher inf ant mort a l i ty rat e s 

and neonata l mo r t a l i t y rates f ar above s t ate averages 

and even above Phi l adelphi a and Reading , and we ' ve had 

t hese for q u ite awhil e . The fact is when babies are r-:1--'-2':-:5::-_-:-H:-:- H.,..,I 

t he most vulnerabl e in t he womb what e l se wou ld we 

expect ? And by t he way, fo r those o f you who have 

bee n sayi ng t hat ACE data is anecdot a l t oday I have 

news for you . This infant mortal i ty report for 

example i s state data reported by EPA i n 2003 . Every 

cancer statist i c t h at you see back there is based on 

Pennsylva nia Cancer Registry s tatistics o r CDC 

statistics. So it i s not anecdotal , those a re the 

cancer increases, t hos e are the cancer above t he 

national average that have h a ppene d here since 

Limerick start e d operati ng . That is a fact. 

So it ' s not anecdotal and the f act of the 

matter is I t ho ught t his was a b out the environment but 

apparently it ' s a bout money . So I d e cided t hat 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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57 

1 between the sessions I was going to change things 

around a l ittle bit . I could talk about the 

environmental impacts o f this place for a whole week 

it ' s so bad . And I ' ve got all the documents in our 

o ffice to prove it. Let ' s talk about , let ' s take a 

mi nute now though and we ' r e goi ng t o talk about t he 

cost . What is t his p l ace act ually cost ing us? Let ' s 

just t hi nk about cancer f or example . We have s o many 

cancers above t he national average . Chil dhood cancer, 

92 . 5 percent h i g he r than t he nati o nal average . Thi n k 

about that . We track the c o st of one c h i ld wit h 

1-26-HH I 

cancer d i agno s ed a t six mo n t hs to t wo years and up 

until t hat time i t was $2 . 2 mi llion . How many more 

k i ds have that above the nat i ona l average? Cost that 

o ut and how many other cancers are above the nati onal 

average? You do the mat h . Figu re that out . 

How abo u t t h e customers that paid I 

hear them talk a bo u t how g reat the costs are for 

Limerick . We paid f or Limerick from 1985 t o 2010 in 1- --=-~ 

1-27-os 1 

o ur electric bills. And i n fact the e l ectric that was 

supposed to b e t oo chea p to meter t u r n e d out t o be 55 

p ercent above the national average by 1997 . So that ' s 

how cheap Limerick electric is . 

The n you ta ke the property t a x es . They 

tried to get zero f or their property taxes by the end 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

1-28-SE I 
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5 8 

1 o f t he ' 90s a nd d i dn ' t pa y any p r operty tax es until 

the ea rly 2000s a t whi c h time they paid $3 mi l lio n !-:-"=~-:=-~ 

1-28-SE I 

i n s t ead o f the $17 mi l lion they were supposed to pay. Con'td 

So when you think a b o ut tha t n o wonde r Exelon ' s 

willing to throw around a cou p l e mi l lion i n t he 

community . They owe this community a l ot more tha n 

wh a t t hev ' r e aivina o u t . 

(Ap p l a use) 

MS . RUPPE : So t he n t h e r e ' s t h e c o st f o r 

t he poll u t i on t hey ' re put t i ng i n t h e river . Th e y ' r e 

a ski ng f o r i n creases i n p o llut i o n . They want t o put 

more mi n e water i n . They want t o i ncreas e t he t o t al 

disso lved sal t s . Tha t ' s g o i ng t o c o s t water t reatme n t 

a lot o f mo ney to t ry t o f or ex ra .......,,.......,,..,....,..,., 

4-10-SW I systems 

treatme nt fo r t h a t . I t c a n eve n break down t heir 

e quipment , s ome of the stuff that ' s comi ng o ut o f t he 

mine s . And when you t h i n k about i t who a ctually 

ultimatel y p a ys t h at cost? We d o . We pay for 

increased cost s for our wa t er because t he y ' re havi ng 

to d o t h at at the wat er treatme n t syst ems . And i t 

seems to me t hat i f you rea lly take a good l oo k at 

t hi ngs Limeri ck has got to be the ma j or cause for the 

radiati on i n Ph i l ad elph ia ' s water . 

So a l l i n a ll taken as a whole t his p l ace 

h as u nprecedented e nvironme ntal h arms . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

The re i s no 

www.nealrgross.com 
Appendix A

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1 question a bout that . An ybody t hat doesn ' t believ e it 

c ome look at the permits with me and I ' l l show you 

exactly what ' s going on . I i nvite anyb ody to d o t h at. 

And t he one thing t hat ' s really important 

is that NRC a nd the nuclear i ndustry are claiming that 4-11-08 1 

age is no i ssue whi le at the same t ime they admit that 

s ome parts are t oo b ig and too expensive to replace . 

I f rankly am really concern ed about NRC accommodating 

the nuclear i ndustry wi th weakened regu lati o ns, lax 

1 e nforceme n t, n e g l igence a nd un substantiated deni als. 4-12-081 

I t ' s h a p pened right he re even wi th t heir fire safet y 

1 regulat ions t hat are -- we ' r e o n weakened fire safet y 

1 regulat ions eve n though we know t hat t hat can 

eventually lead to a meltdown . I know my time ' s up . 

1 Tha nk you. 

1 (Ap p l a use) 

FACILITATOR BARKLEY : Thank you, Do nna . 

1 Mike? 

1 MR . GALLAGHER: Okay, good eveni ng . My 

2 name ' s Mike Ga l l agher and I ' m vice presid ent of 

license renewal for Exelon . I have the overal l 

2 responsibility f or the Limerick l i cense renewal 

2 appl ication . Exel o n has a great d ea l of experience in 

l i cense renewal . We ' ve obta i n ed renewed l icenses for 

2 the Peach Botto m and TMI p lants i n Pennsylv ania , a lso 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-234

6 8 

1 FACILITATOR BARKLEY : We have a n 

i nspect ion ongo ing at t h a t point r ight now rega rding 

the North Anna facilit y . So yes, i t did experience a n 

earthquake beyo nd i t s ori g i nal desi gn . So f a r t he 

i nspect ions have rev ealed no -- mi nimal damage . I ' v e 

o nly heard of one piece o f equipme nt that exp eri e nced 

even visible signs o f problems . But the ove r all 

ana l ysis, this is continui ng and t he l icensee has t o 

have permissio n from us t o restart after an extensive 

1 i nspect ion . 

MR . ELY: My concern i s t hat t his hastened 

1 l i cense r enewal process i s inappropri ate f o r 

1 engi neeri ng reasons . I worked i n a variety of 

d i ffere nt areas in the construc t ion o f t hat power 

1 plant and t here were conti n ual deviat i o ns tha t were 

1 provided, whether i t was in- storage mai ntenance 

moni toring of t he condition o f t he components that 

1 were used t o the actu al const r u cti o n of that p lant . I 

1 could cite you several exampl es . 

2 What I would like to as k of the public is 

that the p eop le that had worked at that nuclea r power 

2 plant take a look at thi s licensing renewal and 

2 understand t hat they need to review those failures and 

those deviations that were provided to go ahead with 

2 the construction of t hat p lant with non- c on formances 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

21-1-0S I 
Appendix A

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69 

1 that were reviewed, b u t not reviewed in l ight o f what 

we understand a nd know today about earthquakes or 

othe r anomalies. We need t o have enough time to make 

the evaluat ion o n those deviatio ns . The cooling 

p ools. The fue l pool girders that are placed there . 

There a r e rebar concrete reinforced supports where a 

q uality engi neer, he was supposed to be accepting t he 

very hi ghest grade o f concre t e t o be placed i n a 36-

hour pour there and he didn ' t pay attentio n . And t he 

1 cofferdam was being built down in t he r i ver and up 

c omes t his sand mi x wit h a very low strength and get s 

1 pumped up i n t o those fuel p ool g i rders in a layer and 

1 t he e ng i neer sai d well , b oy, t hat was a t errible 

mi stake , but it ' 11 be okay . We need to go back and 

1 take a look at a ll of tho se mistakes and make sure 

1 that they ' re not wr itten off because a l a yer i n a 

structure under load caused by an earthquake , t hat ' s 

1 an issue . It might not be a n issue for t he strength 

1 o f the fue l pool gir ders t o support those fuel pools 

2 that when we see them in Japan and they catch fire 

b ecause t hey ' re extremely hot and you need to address 

2 that . I was on that po ur but I wasn ' t the engineer 

2 that ma d e that e r ror, but there ' s a number o f e r rors 

t hat were made . And I don ' t see or understand that 

2 the NRC or the review or the licensi ng application is 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

2 1-1-0S I 

Cont'd 
Appendix A

A-236

7 0 

1 t aking a l ook a t t hose fa ilur e s and t hose errors and 

21 -1-0S I addressing them in l ight o f the knowledge that we ha v e 

Cont'd 

t oday. 

Some people d o n ' t unde rstand about 

radiation and I read when t he Japanese t hing occurred 

a nd I hea rd on the news a r adiol ogist t alking about 

o h , the radiation is s uch a low amo unt . It r eally 

i s n ' t the l ow amount of radi atio n exposure that we g e t 

i nc i dentally i n s t anding next to a nuclear power 

plant . I t ' s three t en-thousandt hs o f a gram of 

p lut onium that is death f or you if yo u breat he that 

dust p arti c l e . It ' s almost cert ain death . And t he 

problem becomes you can ' t h ave -- and it' s no t go i ng 

t o be a nuclear bomb . I t ' s go i ng t o catch on f ire if 

the f uel pool girder s we re to f ail and you ' ll have a 

cloud o f a ma t erial that in and o f itself you migh t 

not have radiation exposure t o i t but that particle 

whe n it deposits i t s elf can be an issue much the same 

as f l uori de i s what causes thyroid cancer when i t ' s a 

r adioactive fl uorid e . Tha t ' s why we ' re very carefu l 

in building a p lant with no Te fl o n and no f l uorid e 

components . 

So we n eed to pay attenti o n to s ome of 

t hat e ngineering and I ' m no t certain that tha t ' s being 

d one . 

(202) 234-4433 

I ' d like t o see an agency or fo r somebody t o 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

21 -2-HHI 
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A-237

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1 

1 

1 

1 

1 

1 

2 

2 

2 

71 

1 contact me if they know ab out a variety o f different 

flaws that they saw during the construction . And my 

email address is asqchair@yahoo . com. Yes , I will be 

the chair o f the Philadelphia section of the American 

Society f or Quality coming up and I ' ve been past chair 

i n the past s o yes , I ' m very quality- oriented a nd I ' d 

appreciate any feedback from people that have issues 

with t hat construction . Thank you . 

(Applause) 

FACILITATOR BARKLEY : Okay. Thank you, 

Dan . Jim Becker man? 

MR . BECKERMAN : Good eveni ng . My name is 

Jay Beckerman . I ' m a resident of Phoeni xville . I 

found out about this meet ing because I scan a l ot of 

newspaper websites . I fou nd the notice of the meeting 

on t he West Chester Daily Local websi te . Didn ' t find ~~ 

22-1 -LR I 

it in the Phoenixville paper, d idn ' t see it in the 

Philadelphia newspaper, did n ' t hear about it o n any of 

the local radio stations, didn ' t hear a bout it on 

cable , did n ' t hear about it on any of the televi s ion . 

Once a month , what is i t the f irst Tuesday 

about 2 : 00 I hear the siren that we all hear. What 

should happen in terms of peopl e getting notice is 

everybody who ' s within the plume area should something 

2 happen at Limer ick s hould find out about this meeting 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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72 

1 a nd I seriously doubt that that actually happened . I 

thi nk it was pure acci de n t t ha t I found it. Something 

as serious as license renewal should get the same kind 

o f outreach that occurs when Limeri ck does what it 

should which is to mail out every year or two t o all 

o f t he possibly affected ho mes the maps and t he 

notifications of how do you evacu ate . I f you ' re going 

t o renew a plant which happens once every 20 years I 

don ' t u nderst and why t he NRC doesn 't require the s ame 

1 k i nd of ou t reach p ublic notifi cation so people get a 

chance t o come t o one - time meet ings like t hi s . I 

1 t hi nk that is a basi c flaw i n the NRC ' s l i censing and 

1 re- licens i ng procedure a nd I think i t shoul d address 

t hat . 

1 The slide behind me documents exactly two 

1 l ibraries that the doc uments are goi ng to go i n . Why 

not in my l ibrary i n Phoenixvi lle? Why not in 

1 Montgomery County and Norristown and a ll of the other 

1 public l ibraries t ha t are in areas that can be 

2 affected by the plume should something happen here? 

Why are the doc uments i n s uch a restricted area? 

2 I ' d l ike to switch a little bit . I ' ve 

2 b een researching , I didn ' t even know about this ACE 

organization . Glad to find it. I ' ve b een researching 

2 o n my own i nformation about nuclear power plants and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

22-2-LR I 

22-3-LR I 
Appendix A

A-239

1 

7 3 

their risks f o r quite awhile . An orga ni zati o n I ran 

across published this book t itled Ins u r mountable 

Risks . The organization is called the I nstitute for 

Energy a nd Environmental Res earch . It' s a n a mazingly 

well- researched book . I d o ubt v ery many peop le have 

r ead it but you should . This organization is at l east 

as int erested in alternative energy sources as it is 

in h avi ng put the e ffo rt in to d ocument what are t he 

problems with nuclear power engineering- wise . The man 

who ' s head of this o rganizatio n is a nuclear 

scientist, a guy named Arjun Makhij ani . He ' s a PhD 

n uc lear sci ent ist . These are f irst- c lass researchers, 

this is PhD- l evel stuff wri tten for popular 

c onsumption . So I ' ll be glad t o make more detail 

about t he book available to anybody who wants to know. 

A few q ue stions I have , o ne t hat I ' ve been 

thi nki ng about for a l ong t ime . I wonder how many 

peopl e here are aware o f something cal led the Price 

Anderson Nuclear Industries Indemn ity Ac t . Who knows 

about that? The title alone should give you some 

p ause . Why do we n eed a n u c l ear industries i ndemni ty 

act? What d oes i t do ? What it does i s it puts a 

ceiling o f a few h undred million dollars on the 

l i a b i lity that nuclear power plant owners have for the 

damage t heir pl ants would cause . I t ' s basically a 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

22-4-0S I 
Appendix A

A-240

1 

74 

scileme , u1ey pay ln LO a poo.L . Tile prou.Lem l s Lila L 

c e iling was set a v ery long time ago . It ' s t o t a lly 

unrealistic in terms o f the risk in just the va lue of 22-4-08 I 

Cont'd 

houses i n areas that are covered by a p lant like this. 

When this plan t was planned t he populatio n in the 

area that its plume woul d cove r prob ably wasn ' t 20 

p ercent of what the population i s now . That is I 

thi nk a va lid environment al conce rn . The env ironment 

in which this plant operates h as changed because of 

i n- migrati on , p o pu l a t ion increase fo r all s o r t s of 

reasons . Pa r t of that ' s been discussed t o night i n 22-s-o8 1 

t erms o f evacuatio n rout es, would yo u be able t o get 

p e o p l e out were there a n accident . The roads h aven ' t 

cha nge d v e ry much , the p opulati o n has. That I think 

is a val i d environmental concern t hat surely o ugh t t o 

be addressed . 

The q ue stion I ask about the money 

l i a b ility is let s j ust go back t o the Pr ice 

Anderson Ac t . The fact is t hat the nuclear industr y 

does not pay ma rket rates for insu ran ce to cover it 

for the liabil i ties. This congressi o na l act from way 22-6-08 I 

b ack i n the 1960s eli minates t h at need . Back then the 

insurance i ndustry didn ' t have the research to put a 

pri ce on what should the Limericks of the world have 

t o pay f or a l iabilit y p o licy . I t hi nk t here ' s p lenty 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-241

1 

~--------------------5 I 

o f insurance industry experience now . So my question 

2~2--=....., -o=-"'=""" q 

would be if nuclear plants are so safe why do we need 

the Price Anderson Act? 

(Applause) 

MR . BECKERMAN : I l ist e n ed , I ' m going t o 

switch subjects again . I l istened to Mr . Gallagher 

and I h eard something I really d i dn 't expect t o hear. 

He said t hat their studi es said t hat t his plant is 

now safe t o run for 60 years . That s ounds t o me like 

advanced not i ce to the publ i c t hat t his isn ' t t he 

first renewal t hey ' re goi ng t o ask for on t h i s plant. 

Mr . Gallagher, are you goi ng to ask f or another one 

20 years from now? 

FACILITATOR BARKLEY : We have n ' t had any 

licensee at this point in time ask for s omething 

beyond that . 

MR . BECKERMAN : Yo u didn ' t ma ke the 

statement . Mr . Ga l lagher did . 

FACILITATOR BARKLEY : I know and I ' m not 

going to have him address t his from the audience . 

This is a meeting with us . 

MR . BECKERMAN : And I would like to 

finally address an issue that the speaker on the cell 

phone brought up . He talked about embri ttlemen t of 

concrete over t he lifet ime so f ar o f the nuclear 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

Cont'd I 

22-7-0SI 
Appendix A

A-242

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1 

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1 

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1 

1 

1 

2 

2 

2 

76 

reactor containment vessel . Tha t ' s an internal 

e nvironmental ma t t er. I don ' t know i f it' s q uite in 

the scope of what the NRC plans to talk about or plans 

t o look a t , b ut something t ha t I have not read about 

at all is an NRC requiremen t f or destructive t esting. 

For inst ance , if you want t o know what a tree looks 

like on the i nside you put a borehole in it and you 

pull a core sample o u t and you fi nd out what t h a t tree 

looks like on the insi de . I f an engi neer wants t o 

know wha t is t he qua l i ty of the concret e t h at was 

poured for a road -- I used to work for Florida 

Department of Transportati on they bo re out a sample 

nd t h en you t ake a look a t it . What I haven 't heard 

nything a bout exc ep t general izations is has anybody 

one any destructive even borehole test ing of these 

ontai nment vessels and t heir s upport pourings to find 

22-7-0S I 

Con'td 

put has there been i n fac t any deteriorat ion of the 22-8-0S I 

oncrete, the r ebar and anything else that went in 

her e . The stuff that ' s bur i ed i n the concrete , the 

ire , all of those things that are buried in the 

oncrete . If you haven ' t bothered to open that stuff 

p since the plant was built how o n earth do you know 

hat condi tion it ' s in? Shouldn ' t that be a 

equirement to do some destructive , open t h e bottom 

2 esting , go all the way t h rough and make s u re what you 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-243

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1 

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1 

2 

2 

2 

77 

1 thi nk is t here is wh a t ' s there and i n the c ondi t i o n 

that i t 

y ea rs? 

s hould be i n to last f or another 20 or 40 22-a-osl 

Cont'd 

So t hese are q u est ions that I ' d like the NRC 

t o go into . I thank y ou v e ry much f or listening . 

Overall it ' s been a very i nformative presentat i o n by 

b o t h t he propo nents and people who hav e questi ons and 

I thank you f o r the opport u nity. I woul d l i ke t o see 

a meeting like thi s occur at a bigger venue with more 

not ice . An e x amp le woul d be, as I ' ve dis cussed wi t h 

Ms . Regner is it? 

FACILITATOR BARKLEY : Re g ner, y es . 

MR . BECKERMAN : I didn 't have her name 

c orrect . Th e Phil ade l phi a Expo Cent er would be mo re 

cen tral t o where the p lume area for this p l ant is. 

It ' s right off 422 . This is not hard t o get to, 

t hat ' s not h a rd t o get to . It' s much mo r e in the 

center o f the p opu l ation . Thank you very mu ch . 

(Applaus e ) 

FACILITATOR BARKLEY : Okay , t hank you . 

Mr . Cu thb ert? Aga i n , f oll owi ng Mr . Cuthbert ' s remarks 

it ' ll b e Jim Derr to wrap up the e v e ning . 

DR . CUTHBERT : Good evening . My name is 

Dr . Lewis Cuthb ert . I ' m the president of ACE , the 

All iance for a Clean Environment . And my comments 

2 this evening are going to di f f er from this aft e rnoon 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

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78 

1 because they ' re go ing t o b e focusing o n as a general 

t opic documented evidence . We ' ve heard a lot of 

assertion s , assumptions and claims throughout the d a y 

many of which would be very difficult t o subst antiate 

in o u r experience . Based o n an 1 1- year investigation 

conduct ed by the Alliance f or a Clean Environment we 

have formed a conclusion that we are presenting t o t he 

Nucl ear Regulatory Commi ssion today and that is very 

simply that Limeri ck nuclear power plant must be 

1 closed by t he NRC, no t re- l i censed unti l 20 4 9 . And 

t hat ' s based on a s ub stantial b o dy o f evidence in 

1 t erms of d ocumented environmental harms, t h reats and 

1 risks that have i n fact gott en into our air, our 

water, our s oil , our food , our milk and our children . 

1 The evidence is not refutable . 

1 So I ' ll be presenting as part of my 

remarks tonig ht what I ' m calling a short list of 14 

1 reasons why the NRC may feel free to with more than 

1 adequate j ustification deny this permit . And I ' m 

2 going to categorize each of them very briefly wi thout 

any further d escription or ana lysis. The evidence 

2 comes from a variety of permits, o ffi c ial records and 

2 reports, and Exelon ' s own renewal application which is 

sizable by their own admission and in o ur experience 

2 i n taking a look at it . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

f-:--.11:-::--=-::-1 1-29-0RI 
Appendix A

A-245

79 

1 The 14 i tems any o f which i n our j udgment 

s hould b e adequate a nd sufficient to deny this permit 

enewal i nc l ude , n umber 1 , radiation into air a nd 1-30-RW I 

"ater from routine and accid ental emissions. Number 

2 , ma j or a i r pollution und er healt h - based stand ard s of 

the Cl ean Air Act . A Tit le 5 permit being issued t o 

1-31-AM I 

this facili t y means b y d e finition t hat they are a 

major air pol lut er under t h e federal Clean Ai r Act . 

Number 3 , Schuyl kill Ri ver dep l e t ion a nd ma jor 

1-32-SW I 

d r i nki ng water c o nt a mi nati on . Ke ep i n mi nd this is a 

vit al drinki ng wa t e r s o u rce f o r nea rly 2 million 

people f r om he re t o Philadelphia . Number 4 

radi o act i v e groundwat er c o nt ami nation . Number sf 1-33-GW I 

raa1 at1on report1ng levels 1 ncreasea a ramatlca LLy 

a fter t he Fukushima Japan disaster . Number 6 , 

1-34-RW I 

documen t ed a larmi ng can cer increases especially in o ur 

1-35-HH I 

children since Lime rick started operating . Number 7 , 

deadly high - level radioactive wastes t hat are packed 

1-36-RW I 

in vul nerable fuel pool s on this site and t hey are in 

fact unprotected . The y are above ground and 

unprotected . Number 8 , lax fire saf ety regul ations 1-37-0S I 

and multipl e violations. Numbe r 9 , accidents and 

leaks from corroding , deteriorating equipme n t plus 

1-38-0S I 

mil es o f b uried p ipes and cables. Many problems and 

shu tdowns have already occurred a t t his fac i lity in 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-246

1 

80 1 

r':-1-:-3:-::--:-0::-::~1 

Cont'd 

its first 26 years of operation . They are a matter of 

r eco rd . Number 10, increased risk o f meltdowns from 

more frequent and s tro nger earthquakes a nd other 1-39-o8 1 

nat u ral disast ers such as tornadoes and floods, not t o 

ment ion mech anical failures . Number 11 , threats from 

unguarded t errorist a t tacks with p lan es a nd missiles 

and a new t h reat , cyber atta cks . Fuel pool are 1-40-081 

vulnerable to att ack . 

Number 1 2 , one that I think probably 

should jump t o the head of t he l i st for t he NRC based 

o n a lot of comments from a l o t o f o t her anal y sts and 

elected offici als, the need f o r an updated evacuation 

plan and i ncreased EPZ , a 10- mi le radius . This p lan 

is serio usly o utdated . It is by many expert ' s 1-41-08 1 

observations fatally f lawed . There wi ll be no 

evacuation i n the event of a worst case scenario . 

Several people spoke to that t his evening . The 

popul ation in this a rea has increased more than 1 80 

percent since 1980 to 2010 , U. S . Census d ata . Updates 

are obviousl y needed and they should be reasonable , 

comprehensive , d etailed and accommodate all of the 

demographics from 1 985 to today and from tod ay until 

as far o u t as the NRC is willing to license this 

facility. 

I Number 13 , increased cost to t he public. 1-42-08 1 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-247

81 

1 We ' ve heard a little bit about this this evening , more 

cancers, more illnesses, more emergency room visits, 

more hospitalizat ion fr om i n creased PM- 10 . Massive 

111-42-0S I research on what particulate ma t t er i n t erms o f PM- 10 IICont'd 

does t o human beings. And there are a f ew other 

thi ngs that contribute to those visits. The costs are 

astronomical . One case that Donna mentioned, $2 . 2 

mi llion f or a childhood cancer case . You do t he mat h . 

And number 14 , the last i tem o n my list. 

1 We have had 26 years of i nsults to our envi ronment, 

and I choose that word p urpo sely, insult s to 1-43-AL I our \--.---' 

1 environment and c o s t ly nuclear power . We can replace 

1 it with safe , clean, re n ewable energy before 2029 . 

That is a matter of scientific fact . 

1 It is a scientific certainty that harms, 

1 threats and risks t o o ur environment and t o our 

community will increase continuously daily until 

1 Limerick ' s c u rrent operating licenses expire in 2029 . 

1 It would be both unethical and i rresponsible for the 

2 NRC to cavali erly approve a license renewal wi thout 

t h e most rigorous review and justification in the 

2 history of this agency . NRC, you have a rare 

2 opportunity b efore you t h at most people and agencies 

never are afforded . It ' s called a do - over, a chance 

2 to correct a litany of mista kes and errors associated 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-248

82 

with t his f acility and with your agency sin ce 1985 . 

Twentieth century t echno l ogy and infrast ructure are no 

longer sufficiently reliable for a n y o f you t o assure 

us t h at there is nothing t o fear a nd no thing about 

which t o b e concerned . Den ial of d ocumented evi dence 

i s no longer a n opt ion . We ' l l b e s ub mitting 

addit ional packets of research d o cumentation and 

evi dence tonight a long with my comments whi c h will 

c ompl iment wha t I did earlier t oday . The ma jor 

1 c a t e gories t h at yo u ' ll be getting f or additional 

r eading and review, meltdown t hreats, evacuation 

1 plan s , Exelon ' s i naccura t e a nd un substan tiated c laims 

1 and a cri t i cism o f the NRC ' s oversi g ht track r e co rd i n 

t his commu nity . Th ank yo u ve ry much a nd please accept 

1 this for review. 

1 (Ap p l a use) 

FACILITATOR BARKLEY : Okay, t hank yo u , I 

1 will . Th ank yo u . Mr . De r r ? 

1 MR . DERR : Good e vening . I thought I 

2 woul d add some comments just t o make sur e my 

2 unde r s t anding is that this is ess entially the NRC ' s 

2 opportunity of list e ning f or things specifically to be 

2 included in the environmental site review of t he relicensing . And j ust a few t hings whi c h are question 

2 marks that l ots o f f ol ks in t he community I t hink will 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-249

8 3 

1 b e interested in . Most o f these have b een touched on . 

Mine wat er issue , b etter d efining that 

quality and fl ow particularly i n light o f t he likely 

pending c hanges i n stormwat er c o n cerns and regulations 23-1-SVV I 

i n t he area . Adding that f low t o t h e Schuylkill is 

goi ng t o a ffect a ll t he municipalities around he re who 

have t o d eal with sto r mwa t er. 

The emerge ncy p lanning is an area which 

needs to b e seri o usly l ooked a t. Hard a nd soft 

123-2-0S I 

i nfrast ruc ture on that . Hopefully t ha t's s ome t hing 

whi ch is part of t he o ngoing operat i o n al requirement s 

f or pe riod i c review and updat e since obvi o usly t his is 

not a static e nvi ronment we l i ve i n . That has t o be 

cha nge d on a n o ngo ing b asis. And then t o -- I' m sure 

hat t he generic p l an includes a pretty good 

::l is cussion o f f u e l sto rage l ong- term a nd s hort - term 

::msi te but certainly the site- specific f uel storage 

onsiderati ons . And I want to seco nd the comments by 

Mr . Ely o f review o f record s of non- conf o rmances and 

anything that was done is part of the i niti al 

constructi o n record . And basica l l y that ' s those 

are t he things that we ' re going to be looking f or a 

b etter unde rsta ndi ng of. Thank you . 

(Applause) 

FACILITATOR BARKLEY : I d i d h ave o ne last 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 www.nealrgross.com 

23-3-0S I 

23-4-0S I 
Appendix A

A-250

84 

1 request for an individual to speak . She promises 

she ' ll o nly b e two minutes so we ' ll have her up and 

then we ' ll wrap up the me eting . Thank you . 

MS . CONFER : Hi , my n ame is Traci Confer. 

I ' m with Energy Justice Network . We support clean 

e nergy which we do not believe nucl ear is . I would 

like t o put our name behind all of Buzz Cut hbert ' s 

omments and I want to add that I want the NRC t o look 

n t o potential water depl etion issues from s ha le gas 

1 racking upriver i n both r i vers . I also think t hat i t 

woul d be very prudent to p ut a lot of attention on 

1 t errorist a t tacks on the f u e l pools. And those are my 

1 primary comments . Thank you f o r your time . 

(Appl a u se) 

1 FACILITATOR BARKLEY : Okay, t hank you . 

1 With that I ' d like to have Lisa Regner come u p for a 

minute and give closing remarks . 

1 MS . REGNER : I just wanted to real quickly 

1 thank our senior resi dent insp ector who came out 

2 tonight out of the good ness of her heart . She does 

not g et paid for this . Jo, would you mi nd standing 

2 up? 

2 (Applause) 

MS . REGNER : Thank you . This is one of 

2 t he NRC inspectors who works at the plant day in and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

24-1-SW I 

24-2-0S I 
Appendix A

A-251

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Dear Ms. Regner: 

Camilla Lange [camillange@verizon.net] 

Monday, September 26, 2011 2:20 AM 

Regner, Lisa 

NRC Public Meeting Feedback 

~te/c2// 

%rJ<_J3f-1~ 

(f) 

I attended the NRC Limerick Generating Station License Renewal public meeting at Sunnybrook Ballroom on 

9/22/11 . I listened attentively to comments from all 15 speakers at the evening session and took into account 

all the pro and con arguments presented. Despite all the reassurances from Exelon representatives about the 

safety and efficacy of the generating station's nuclear power, I have serious reservations and concerns about 

these issues. 

First of all, considering the impact of the outcome to the many area residents, this forum was not widely 

publicized for local citizens to be aware of this important matter and offer feedback. Secondly, it does not 

make sense that Exelon is pursuing renewal for a license that does not expire until 2024. This action seem 

ve remature. 

consum 1on eman s. 25_

5_ 

Thank you for arranging the public meetings to discuss this serious matter. I trust you will take my AI ts 

into consideration and urge Exelon to provide other such forums with widespread notification beforehand so 

that more interested citizens can participate. 

Sincerely, 

Camilla Lange 

616 W. Schuylkill Road Apt. 164 

Pottstown, PA 19465 

camilla nge@verizon. net 

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Appendix A

A-252

Mendiola, Doris 

From: 

Sent: 

To: 

Subject : 

Follow Up Flag: 

Flag Status: 

Eric Hamell [stripey7@yahoo.com] 

Wednesday, September 21 , 2011 7:38AM 

Regner, Lisa 

Limerick 

Follow up 

Flagged 

Please do NOT extend the limerick licenses! 126-1-0R I 

Eric Hamell 

Philadelphia, PA <ijOJ&. /02# // 

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Appendix A

A-253

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Follow Up Flag: 

Flag Status: 

steve furber [ctevewrx@yahoo.com] 

Tuesday, September 20, 2011 4:17 PM 

Regner, Lisa 

Limerack Renewal 

Follow up 

Flagged 

ij&q, /~ /,/ 

?t?£.5:3~51~ 

@ 

Kenewmg Ltmenck's ltcense JUSt as controverstes are ansmg wtth pushes to move trom dependence on Nuclear ~7_::2·1 

energy is a bold business strategy by them. I don't think this is the right move to make. A long term contract ~ 

will limit any sort of wiggle room to address future issues that may arise. · 

I ask that you please consider the future of our great state. I don't think oil or nuclear energy is the way. I truly 

believe in heart, that in order to protect the health of our population for the future, we must change our ways 

today. 

Sincerely, 

Steven Furber 

JJ :0 

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Appendix A

A-254

RULES . :.J ;/ iECTIVES ~r; .\~C:H .. ·. 

PUBLIC SUBMISSION: ~- :: ~~ c; 8= ll7 

~~ -1\ ' i 

Page I of I 

As of: September 27, 2011 

Received: September 22, 2011 

Status: Pending_Post 

Tracking No. 80f27eee 

Comments Due: October 28, 2011 

Submission Type: Web 

Docket: NRC-2011-0166 ,-,' - , · -! \' !- 0 

Notice of Receipt and Availability of Application for Renewal of Liirlerick Generating Station, Units I and 2 

Facility Operating License 

Comment On: NRC-2011-0166-0003 

Exelon Generation Company, LLC; Notice of Intent to Prepare an Environmental Impact Statement and 

Conduct the Scoping Process for Limerick Generating Station, Units I and 2 

Document: NRC-2011-0166-DRAFT-0002 

Comment on FR Doc# 2011-21921 

Submitter Information 

:ij~J:D/1 

7~r/L 5~7~ 

Name: Charlene Padwomy 

Address: 

1117 Oakdale Dr 0 

Pottstown, pennsyvania, 19464-2782 

General Comment 

Thanks so much, 

Charlene Padworny 

_,£-7(_.;:: j)5 ,.,_. p .!:>H -d 3 

~;; / /)~ f-At-'2 .;2_) 

https :/ /fdmsoerulemakingonet/fdms-web-agency /componentlcontentstrearner?objectld=0900006480f27 ee. 0 0 09/27/20 II 
Appendix A

A-255

U.S.NRC Unired Scares Nucle<lr Rcgul:uory <:nmmi.uinn 

Proterting Peopk tznd the Environmmt 

LIMERICK GENERATING STATION 

Environmental Scoping Comments 

Division of License Renewal 

NRC-2011-0166 

Written Comment Form 

Must be received on or before October 28, 2011. Please print clearly. 

Name: S,Y /u I A Po //1 C k_ 

Title: JPs t d 'f IJ t J ~ £j <; 1 (b u .p I.J t rr.. (' 

0 

Organization:------:::-------------- -----

Address: .)3 EA IS L DR· ~ty-: .. }i - !7:;-,--/o _ _ · lA/ " '· ~ _ 

J State -~'-'{)'r /)'-'--}--- z· 1p c o d e: ·;;';,// 7~~ ._.. ..::. .-

Use other side if more space is needed. 

Comment Forms may be mailed to: 

Chief, Rules, Announcements, and Directives Branch 

Mail Stop: lWB-05-801 M 

U.S. Nuclear Regulatory Commission 

::::;:-, 

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Washington, DC 20555-0001 ~ 

Su.U5J- /)e-vt'eur'~~ 

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Appendix A

A-256

Gallagher, Carol :.i 

From: Joe Roberto Uoe@robertoandassociates.com] 

Wednesday, September 21, 2011 7:20 PM 

·-r,J 

w Sent: <::: 

To: 

Cc: 

Regner, Lisa ,.. J ~ } , 1 

Subject: 

Joe Roberto . ~~OJ-~ I~ I/ 

LIMERICK 

74-rX 53-7"-1(0 w 

Dear NRC: 

First of all, let me ask why the lack of public notice regarding the public hearing to be held for Limerick Licensing 

Extension when in fact the current permit is through 2024 and Exelon is asking for another 20 year extension? Your first 

priority is NOT for the publically traded, for profit company to rush to get this public notice "done" as a requirement to 

extend the permit another 20 years out which is not due to expire for another 10+ years but to rather really solicit input 

from the community and folks impacted. The NRC did not do so. There was one article in the local newspapers stating 

that there would a public session and only saw the actual notice, by virtue of an article in the North Penn Reporter 

yesterday. This is not proper notice in general and not sure NRC did what is required . What is required and what have 

you done? And if proper notice was not done, I want another one(s) scheduled please. I, respectfully, am very 

interested in this answer. 

FEEL FREE TO READ THE FOLLOWING AT THE PUBLIC HEARING: 

Now, let's get to the big issue at hand. Limerick should NOT be approved for an extension with their perm it for the 

following reasons: 

• Limerick is designated as one of the TOP THREE nuclear plants in the country based on it's construction (which is 

similar to the ones in Japan- and we see how they failed) and the fact that it sits on an earthquake fault line. 

• The NRC JUST a few weeks ago stated that "more information needs to be done and studied" regarding further 

fortifying nuclear plants regarding earthquakes. Thus, until you folks know exactly what needs to be done, etc. 

THERE IS NOTHING TO APPROVE as long as Limerick sits in it's current position. 

• Do NOT think that earthquakes only happen on the West Coast- as we JUST had a 6+ earthquake less than a 

month a o. BY ONLY luck was there no dam a e to the I ant, environment or communit . 

When Limerick was built, there was no idea that the area would grow in population like it has. For safety 

reasons, just look on any given day the traffic on Route 422- stacked and stuck for miles on end. Route 422 is 

the #1 route for evacuations and does not handle re ular commuter traffic let alone entire communities. 

• The NRC and USA Government STILL have not decided on where to store spent nuclear rods and as we spea' ~t-;;:-::-:::o 

each spent rod is sitting in baths on the Limerick sit, stacking up-expanding even a greater haza rd to the 

community, environment, etc. SO put simply, there is ABOSLUTELY NO REASON to approve this request for 

YEARS until the US Government decides how the will handle such rods and such rods and ro erl stored. 

• There are many other environmental friendly sources of energy and Limerick as anything but that. As a matter 30-6 

fact, Limerick is a TIME BOMB, placed at the wrong location, on t he wrong land, too close to major populations, -OS 

run by a for profit company who can not even handle the basic maintenance issues of power lines, in an aged 

buil · h r I 

6 C))_) s .!- 13 e.- J/1 &r 

/f~e./ii:::: /J?:;H-013 
Appendix A

A-257

• Let's also mention a fact that Category I Hurricane Irene, which could have been a Category 3, just zipped less 30-8-

than 100 miles away from the site a few weeks ago and then Hurricane Lee which decided to travel further Eas AM 

came close to also causing chaos. Limerick is still TOO close to the disaster of Hurricanes as well. 

Lastly, some who have a vested interest in working at the plant, etc. are quick to state that it is safe, etc. -no~ 130-9-~ 

now, nor has it ever been fool proof against disasters, technical glitches, etc. I OS 

us, ee 1rm y an many m t e commun1 y ee t e exact same way, a ere IS o approve 

(especially so far in advance, with no answer on usage rods nor what needs to be done to prevent a meltdown due to a 

earthquake, etc.) or EVER since the population will only increase and the facility age further. It is the wrong timing, 

wrong plant, wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and "energy" to develop solar 

fields, wind, etc ... They would rather beat the hell out of a high efficiency plant at any and all cost to the environment 

and community. This is where the NRC does the right thing and says NO until a year before it expires. NRC needs to 

take a stand as you have the data and know what I have stated above is more than fair and true. 

Thank you for your time and attention. 

Regards, 

J«-R~ 
Appendix A

A-258

/-C? /d& /43 /) 

7~ ,;:=::~ .5:3119 <7 

Delaware Tribe Historic Preservation Office 

1420 C of E Drive, Suite 190 

Emporia, KS 6680 I 

(620) 340-0111 

bobermeyer@delawaretribe.org 

September23, 2011 

Chief, Rules, Announcements, and Directives Branch 

Division of Administration Services 

Office of Administration 

Mailstop TWB-05-B01M 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555 

Re: Request for scoping comments concerning the Limerick Generating Station, Units 1 

and 2, License Renewal Application Review 

Dear Lisa Regner: 

Thank you for informing the Delaware Tribe on the proposed construction associated 

with the above referenced project. Our review indicates that there are no religious or .-----

culturally significant sites in the project area. As such, we defer comment to your office 131-1-HAI 

as well as to the State Historic Preservation Office and/or the State Archaeologist. 

We wish to continue as a consulting party on this project and look forward to receiving a 

copy of the cultural resources survey report if one is performed. We also ask that if any 

human remains are accidentally unearthed during the course of the survey and/or the 

construction project that you cease development immediately and inform the Delaware 

Tribe of Indians of the inadvertent discovery. 

If you have any questions, please feel free to contact this office by phone at (62) 340-

01 11 or by e-mail at bobermeyer@delawaretribe.org 

Sincerely, 

Brice 

~~ Obermeyer 

Delaware Tribe Historic Preservation Office 

1420 C ofE Drive, Suite 190 

Emporia, KS 66801 

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Appendix A

A-259

Stocf;firitfge-Munsee 'Iriba{ :Jlistoric Preservation Office . SfJmy 'l#iitt -'TriDaf :Jlistcric Preservation 0/fiar 

'W1.3447 Camp 14 ~atf gjc?-IR /'&9 1/ 

P.O. 'Bo~ 70 

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Project Number ~J~ tit/VI ! 11 0' b/n_ 1 "f-1~ TCNS Number 1 CompanyName ( /] 

dizf ~ /L.< ~ ~ f ~ fu~ . 

We have received you letter for the ab~ve listed project. Before we can process the 

request we need rriore information. The additional items needed are checked below. 

Additional Information Required: 

.·.-.. 

--~~h:~t!!f;~~~~~s~~~;~ese~ati9P.. ~ffi~ .~-,:=/ ~' ... ..... ?,·.~ .... :~.::;:_',;!J .: .~.- ', = Literaturefreco!i.d ~eiu-~h f11cr~gir}g ~lored m~p~. '· · - · -· ,--

Picturesofth~ slie .. . · '· ·· .. .. . ···, ·<:·;·T 

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.. =Any rep,orts Q!:~ tate Historic Preser-vation .Offlce ~~y llaVe ;: . L.· _-< - __ Has the site'ibeen previ~u!!).Ydisturbed · . .· : il C:-? 

Review, fee ~:ust be included with letter · ·: .·· ~. 9 :e, 

If site has beelr previously disturbed please explain what the u5e~~~ . .aricl llen it was . , .... : .· . . ,., disturbed. •. ' ' . · _ , ;. ,. :· :'. :··.·· 

Other comnieqts,or information needed -------,-------,i-;; ,r::-::_.,-:,,.---­ \:::-:.~tr 

: .·l . ~ 

After review~g.- ;youdetter we fmd that: .. ) , ~- ',:;l','.~ 

.: .. : .. -

·::. 

___2(__ "No P;f.<llp~es!' ~heJ'ribe concurs with a Federal agengy's ~di~ ~t there are 

no National Rliister eli~ible or listed properties within the f.ederali¥m4~rtaking's area of 

potential effe~ or APE'_3qCFR,800.4 (d) (1) · . .. '·. · .... I : ,, , 

"No I;:(i~::ct" hi~tori-c or pr-eru~toric pn')pefties a~e p,t-esent .. but tlte, Rederal underta~ing ~f,~(Jt~ ~o effect' on the Natio11al Regi~1er e.li~l?Je or \~te pr~#erties as defined ~)~ed so~ l6(~) · · · .~. . ·· · -· · .. ,.,.,: :·. t· ·. ;: · ... :~-. 

"No· Adverse Effect" referMo-written opinionS pr:e~ided to a Federal agency as to 

whether or not! the Tribe agrees with.(or believes thanli~re should be) a Federal agency 

finding that its; Federal undenaking would have ''No Adverse Effect" 36 CFR 800.5(b) 

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Appendix A

A-260

U.S. NUCLEAR REGULA TORY COMMISSION 

NRC P!.IBLIC MEETING FEEDBACK ~ .; ... ..,. 

i- ~~;~~~~--- 1 

I 

L ___ ~ ______ _ !: ;-· :. , ........ . Meeting 

Date: 

Meeting 

09/22/20ll Title: 

Li~e~ic . ~~erati~g Station License Renewal Overview and Environmental 

Scoping Comments Public Meeting . . ....!.-.:..... .. ....... ... .-.:.~ ---·---··--···"·- ---------------- ·--· ----------"··--· 

In order to better serve ttie public, we need to hear from the meeting participants. Please take a few minutes to fill out 

this feedback form and return it to NRC. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

How did you hear about this meeting? 

I_ _] NRC Web Page 

[] RadiofTY 

LJ NRC Mailing List 

D Other 

Were you able to find supporting information prior to 

the meeting? 

Did the meeting achieve its stated purpose? · 

Has this meeting helped you wiih your understanding 

of the to_pic? -

Were the meeting starting time, duration, and location 

reasonably ~nvenient? .·.!·. -- ·•·"'··· .. 

. _;: . ' • . · .. ' --t •• . . ~ : . ~ 

Were you given sufficient opportunity to ask questions 

or express your views? 

Are you satisfied overall with the N_Ry st<!ff who 

participated inthe meeting? -- '.. -- ~ ~ • ·, .. 

No Somewhat 

X!§. (Ptease explain below) 

I i 

[ijj' 

[J 

[] 

[] 

L..l 

I .! 

0 

[] 

[J 

i '] '--

.; .' . 

Continue Comments on the reverse. ~ 

OPTIONAL 

. - - -- --- ----. . 

Organization --Q 

~<9 <'-~~. 

~-{--- --------·--·- -------- - - Name 

Telephone No. E-Mail r -~ Check here if you would like a 

-- ----- - ------------------- ----- .... --- ... ...... member of NRC staff to contact you 

OMS NO. 3150..0197 Expires: 0813112012 

Public Prote:tion Notification If a means used to impose an inlonnation collection does not display a curr$0lly veJicl OMS control nvmber, the NRC may not conduct CH" spor . and a person ito 

not required to tespond 10. the information colledion. 

Please fold on the dotted lines with Business Reply side out, tape the bottom, and mail back to the NRC. 
Appendix A

A-261

, .... 

Mendiola, Doris 

Subject: FW: Response from "Comment on NRC Documents" 

Y'P"")~;; -----Original Message----- /'/ 

From: Richard Kolsch !mailto:Rklsch@aol.coml 7'~ /I( ~3-¥ /'6 

Sent: Thursday, September 22, 2011 5:44PM @ To: INFOCOLLECTS Resource 

Subject: Response from "Comment on NRC Documents" / () 

Below is the result of your feedback form. It was submitted by 

=o .~...:~ 

:D 

c: il ·;-, r--

'"") '" ,.., (.r.; - ·1 ~ j . ·- • ' J 

-,-, N .. r I 

Richard Kolsch (Rklsch@aol.com) on Thursday, September 22, 2011 at 17:44:25 ......_ -- ;: ~~;~{ 

.--n '!? C) 

-I 

0 ..c: ~ N (/) 

Document_ Title: License Renewal Limerick PA 

Comments: Comments on Limerick Power Plant License Renewal Limerick, PA September 22, 2011 

1. Why is there a rush to renew the license? It is not due 34-1 

until 2024, approval at the earliest should be 2019. This would allow 5 years for the business plan of PECO to -LR 

either continue or close the plant and make arrangements for additional power to replace the closed plant. 

2. A firm closure plan should be approved before license renewa l34-2-DCl 

is accepted. This plan must include what is to be done with the 

site, where the nuclear waste will be disposed of etc. The 

site like the 

"''""' 

now oou'" defunct ...,.., "'' Yucca 

~""" site. v.l-'"' "'"v' 

The public 

ov• ~vooand v uo¥vowuvg

our future o ~ RW 

generation deserves to know what is expected to be done at the site. Radioactive material must not be 

allowed to remain on the site. 

3. The government should conduct a survey of various illness in the vicinity of the nuclear plant prior to an 

renewal of a 134-4-HHI 

license. If this would indicate a danger living near the plant 

then the license should not be renewed. 

4. Developers are required to fund traffic improvements to an area to allow an area to be developed, this 1 

should apply to Limerick. The evacuation plan now will not work. When the plant 

was started there was no traffic out here, now it is grid lock. l34-5-0S 

Limerick should fund new roads and bridge to alleviate traffic I ams in order to have an orderly evacuation. 

5. The plant is vulnerable to terrorist attacks. An airport is located next to the facility. A plane could be flown ;J into the reactor building or the emergency power supply for the water circulation system at the same time 

terrorist could cut all outside power to the plant this would cause a meltdown and render the entire area around A 

and downwind of the area uninhabitable for hundreds of vears. 

organization: None 

address1 : 1694 Kepler Rd. 

address2: · ~,tJ~ 

6 cJ ,-tiS_;:: ;f JI ~ /' 

'l~~ ;1'7)J-1 .-- L) I :3 

,£--Q']J5 ; ,!&ZJ.)..(-?J 3 

~ ::= ;/ ;87J--T c ~,e .:L) 
Appendix A

A-262

f/01~ I 6h!J I I 

September 24, 20 II 

7~r,.e .. ::5-a¥ ~~ 2461 E. High St.,tJnit F-lB 

Pottstown PA 19464 

US NRC 

Mailstop: TWB-05-BOI M 

Washington DC 20555 

USNRC Lisa Regner: 

0) 

We wish to add our comments to the NRC record. 

We attended one of the NRC hearings concerning Limerick's Environmental Impact (9/2211 I at 

2:00 p.m.) and were appalled that local business and community leaders avoided voicing concerns about 

Limerick's environmental impact, mentioning its economic influence, instead. That doesn't mean that those 

speakers had no concerns. The NRC would be remiss to consider a "thank you for money and jobs" as part 

of its evaluation of community-wide nuclear safety issues connected with Limerick's re-Iicensing request. . . . . . 

be addressed. Re-licensing should not even be a consideration! The NRC must fully investigate the r:-::-:::-:::c::--, 

environmental concerns presented Dr. Lewis and Donna Cuthbert (ACE), Dr. Winter, and each resident 135-7 -OR 

who so civilly represented this community's concerns at the September 22, 20 II hearings. The Limerick 

Nuclear Power Plant should NOT be re-licensed and should, instead, begin to address the pollution issues i 

has already created as it seriously and carefully shuts down its reactors. 

= .. ..; : 

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/)··:a:: . :·.. ,U-c?J 3 f7~~-~-/9.?J . . ,. . 

... Sincerely, 

~lJrd~tll~ 

Charles and Elizabeth Shank 

(610-323-6715) . 

, • , , • 1• :; • : •: • • •• - • ~ 'r . . . :•. • ·.:n 

, ... ;. · · .P~U---:JJs- ·/JJ)H-0 .3 

,., .:~ ~-. X:/;~ ((-u~~) 
Appendix A

A-263

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

naturalcat@comcast.net 

Wednesday, October 12, 2011 5:26 PM 

Regner, Lisa 

NRC 10 DOCKET 2011 -0166 

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Appendix A

A-264

-•. - . 

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Dear Ms. Regner, 

&"~/?/) // 

7't rJ<:. sa~7' r?' 

Cynthia Gale [cgale@barbergale.com] 

Wednesday, October 12, 2011 4:31 PM 

Regner, Lisa 

Michael Gale 

TJ 

:l 

DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD. ::::::-

: I 1 

0 

\..·.) 

':9 

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(/) 

On behalf of my family, friends, and neighbors, please do not relicense the Limerick Nuclear Power 

Plant. We work in Pottstown, live in Elverson, and our young daughter goes to school in Kimberton. All 

these locations are in harm's way of Limerick. Every day when I drop our child off at school I have a 

view of the Limerick towers when I travel on Route 724. I pray everyday that nothing happens when our 

daughter is at school. We no longer feel safe or even drink our tap water, do you? 

Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run It Until 2049 

Threats and Harms, Already Unacceptable After 26 Years, Are Increasing! 

Since 1985. Unprecedented Environmental Harms, Threats. and Risks From Limerick Include: 

1. Radiation Into Air and Water From Routine and Accidental Emissions 137 -1 -RW I 

2. Major Air Pollution Under Health Based Standards of the Clean Air Act 137 -2-AM 

3. Schuylkill River Depletion and Major Drinking Water Contamination 37 -3-SW; 

37-4-GW 

4. Radioactive Groundwater Contaminationi37-5-GWI 

5. Radiation Reporting Levels Increased Dramatically After Japan Disasteri37-6-0S 

6. Alarming Cancer Increases, Especially In Children, Since Limerick Started Operatinq37-7-HHI 

7. Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Site 137-8-RW 1 

8. Lax Fire Safety Regulations i37-9-0S I 

9. Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cable 

10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 37-11 

11 . Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacksl37 -12-0S I 

-PA 

12. Need for an Updated Evacuation Plan and Increased EP 37-13 0S I 

13. Increased Costs to the Public- More Cancers and Other Costly Illnesses, More Emergency Room Visits 

and Hospitalizations from Massive Increases in PM-10 and TDS, Treatment of Public Drinking Water, 137-14-HH I 

Environmental Clean-Up 

14. Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replar::c::=e;-.;;; d::-;:--:-:--, 

With Safe, Clean, Renewable Energy. 137-15-AL I 

List Compiled By The Alliance For A Clean Environment- September 2011 

5c.J..V5J- 1]-e-y/~ ~~ ,;:::;-xr?Js = /J-Z>N-#3 

/7~= IT:vH-~/3 ==- x /J~(L~R...<) 
Appendix A

A-265

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hello Ms. Regner, 

8/~/~1/ 

%rA:~3~7'~ 

Schweg [schweg@gmail.com] 

Thursday, October 13, 201110:21 AM 

Regner, Lisa 

Limerick License Renewal- NRC J.D. Docket 2011-0166 

::TI 

.Tl ,-, 

........ 

---

Ill 

0 

w 

I'm writing to you to state my opposition to the relicensing of the Limerick Generating Station in Limerick 38-1-0R . . 

Respectfully, 

Jude Schwegel 

79 South White Horse Road 

Phoenixville, Pa 19460 

If you want to be important-wonderful. If you want to be recognized-wonderful. If you want to be greatwonderful. But recognize that he who is greatest among you shall be your servant. That's a new definition of 

greatness. 

Everybody can be great, because everybody can serve. You don't have to have a college degree to serve. You 

don't have to make your subject and your verb agree to serve. You don't have to know about Plato and Aristotle 

to serve. You don't have to know Einstein's theory of relativity to serve. You don't have to know the second 

theory of thermodynamics in physics to serve. You only need a heart full of grace, a soul generated by love. 

And you can be that servant. 

Excerpted from The Drum Major Instinct sermon of the Rev. Dr. Martin Luther King, Jr. 

Delivered at Ebenezer Baptist Church, Atlanta, Georgia, on 4 February 1968 
Appendix A

A-266

' .. ' 

Mendiola, Doris 

~..2G,/~ // 7~~/(53-l-.7'7 

From: 

Sent: 

To: 

Subject: 

Michael Gale [mgale@barbergale.com] 

Thursday, October 13, 2011 9:26AM 

Regner, Lisa 

DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD. 

II . ·~ 

And, get the US manufacturing again making wind turbines, solar panels, =.] · · ~ retrofitting older buildings to be energy efficient, not funding this an other budget-busting toxic lime bombs, ·-; 

. ) 139- 1 -ALC 

Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run II Until 2049 

Threats and Harms, Already Unacceptable After 26 Years, Are Increasing! 

Since 1985 Unprecedented Environmental Harms Threats and Risks From Limerick Include: 

1. Radiation Into Air and Water From Routine and Accidental Emissionsi39-2 -RWI 

2. 

,-f 

---- ;TJ 

0 

3. 

Major Air Pollution Under Health Based Standards of the Clean Air Acti39 - 3 -AMI 

r=?::::;::=;;;::=:=:=~-:-::::-:-:-:---, Schuylkill River Depletion and Major Drinking Water Contamination 139-4-SW; 39-5-GW 

4. 

5. 

6. 

7. 

8. 

Radioactive Groundwater Contamination 139- 6 -GWI 

Radiation Reporting Levels Increased Dramatically After Japan Disaster 139- 7 -OS 

~~=-=--:'-:-:-:"! Alarming Cancer Increases, Especially In Children, Since Limerick Started Operating 139-8 -HHI 

Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Sitei39-9-RW I 

Lax Fire Safety Regulations 139- 1 0-0S I 

:!? 

-fi: 

w '"', 

9. Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cables 139- 11 -0S 

10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 39 12 PA 

11. Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacks 139-13-0S 

12. Need for an Updated Evacuation Plan and Increased EPZI39- 14-0S I 

13. Increased Costs to the Public- More Cancers and Other Costly Illnesses, More Emergency Room Visits an 

Massive Increases in PM-1 0 and TDS, Treatment of Public Drinking Water, Environmental ean-Up r.3:-:9 "::->::-'7 :-+'-"""""'"""=i 

14. Dangerous. Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replaced With Safe, Clean, 139-16-A L I 

Renewable Energy. . . 

List Compiled By The Alliance For A Clean Environment - September 2011 

We sincerely hope you will act with your fellow citizens' health, and indeed longevity in mind. 

Sincerely, 

Michael Gale 

172 north hanover street 

pottstown. pa 19464 

61 0-705-3606 I' 

mgale@barbergale.com 

http://www.barbergale.com 

dcsi911i1t!J lr.~t ra blc brands 

,c--/[...:0s=-/3bl'7'- .v 3 

~=X/J'~~:J 
Appendix A

A-267

Mendiola, Doris 

Subject: FW: LIMERICK 

~~// 

7'~r£03-'/-9~ 

From: Joe Roberto [mailto:joe@robertoandassociates.coml 

Sent: Monday, September 26, 2011 2:46PM 

To: Regner, Lisa 

Subject: RE: UMERICK 

-:::o 

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) -' 

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rn w U) 

V1 

1 nanKs ana a gam, smce tniS reactor nas unt11LUL4 wny tne rusn, ana only one public meet1ng. IT you nave not neara n, 

ou will. There is a major public outrage over this one meeting and not knowing about until too late. People want 

public meetings so that people hear that many are against this plant rather than just submitting comments to the NRC 

V>'hich appears to just rubber stamp license requests - which is not comforting to me and many. But I do thank you very 

tnuch for the courtesy, response and review of points. 130-13-LR ~ 

I

There is also something that I did not comment on before- why was Limerick taken "offline" three times in as many l 

months? Is NRC checking? 130-14-0S 

Thanks, 
Appendix A

A-268

~ 

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Melissa Antrim (mantrim@boscovs.com] 

Friday, October 14, 201 1 2:18PM 

Regner, lisa 

Antrim, Melissa home) 

Docket 2011-0166- limerick License Renewal ' _, 

~2 

:JJ 

c: rrn 

(f.' 

:::~ ~:"8 ~-~ 

Via email: Lisa.Regner@NRC.gov 

U.S. NRC 

>;;~~ c: 

< rr 

u Ms. Lisa Regner 

Mailstop TWB-05-80 1 M 

Washington, D.C. 20555 

Reference: Request for Denial of Limerick License Renewal - NRC I.D. Docket 2011-Q166 

Dear Ms. Regner: 

attended the recent meeting on the possible renewal of Limenck Nuclear Plant's license tor 20 years past 1ts current 

12024 and 2029 expiration dates. I strongly believe, as do many of my local friends and family, that the Limerick Nuclear 

Plant must be closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing 

he health of thousands and thousands of people in neighboring communities. There is substantial evidence '"'"iii" vaila le which justifies closinQ Limerick. Renewing this license could lead to a catastrophic meltdown. 140-1-0R I 

Limerick was built to last 40 years. The older any facility gets, the more likely breakdowns and equipment failure will 

occur. When it's a nuclear power plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and 

equipment - honestly, a number of things. Mites of deteriorating underground buried pipes and cables are a major 

concern - how and how often are these inspected? Signs of mechanical damage and breakdown already exist -

three unplanned shutdowns June 201 1, preceded by many others since 2007, one with loss of cooling water. While 

some parts can be replaced, by the nuclear industry's own admission, some equipment is too big and expensive to 

replace. limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is 

up. To add 20 more years to that, without having a clue as to what the condition will be, would be beyond careless. 140_

2_

08 I 

Over eight million people live within 50 miles of limerick Nuclear Plant Safe evacuation is not possible, even within the 

seriously flawed and inadequate current 10-mile evacuation plan. Until Limerick closes, NRC should expand the 

evacuation plan (to 50 miles) and be sure there are enough shelters and supplies available to accommodate the ov.r'e7cr::'8'-::-.l:::-:;::---, 

million people within that radius. Exelon should pay for the supplies. 40-3-0S 

It doesn't take an accident or disaster for Limerick to poison the region's residents w1th ra 1at1on. a 1a 1on rom 

Limerick's routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request It's 

not credible for NRC to claim continuous radiation levels are safe for me and my family when there is ~ 

level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility. 

NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot 

be trusted. Exposure to radiation is known to cause cancer. It should be obvious to NRC that Limerick played a 

major role in our tragic, well documented cancer crisis after Limerick started operating in the mid 198.0s to the late 1990s. 

Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far 

higher than national and state averages, especially in children. Our children had the highest levels of Strontium-90 

radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-90 into our 

air and water that got into the milk, vegetation, and food since Limerick started operating. r4:-::0:-_-:4-:-H:-:f-H;--, ' ~ -.iJ3 
Appendix A

A-269

-. 

hyroid cancer increased by 128% from 1985 to 1997 -was a side note, with no family history or other obvious risk 

actors in my life, I was recently treated for thyroid cancer. Since my diagnosis, I have learned of many other locals like 

e. It's sea to think the choice of where we live could kill us. 40-5-HH 

It would be careless, unethical · and immoral for NRC to approve Exelon's requested 

Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 

Sincerely, 

Melissa Antrim 

1008 Reading Ave 

Boyertown, PA 19512 

The information transmitted is intended only for the person or entity to which it is addressed and may contain 

confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of 

any action in reliance upon, this information by persons or entities other than the intended recipient is 

prohibited. If you received this in error, please contact the sender and delete the material from any computer. 
Appendix A

A-270

. . .. ., 

1" ... ) 

g).u/~1/ 

./tr.--t G;-:3~'/f' Mendiola, Doris J:J '2 ~ 

--------~-----------------------------0--------~ ----~~,----- 6 ~~~mt:: Michael Antrim [antrim89@gmail.com] )t ·~) _, ~-::. ~~ :;: 

To·. Friday, October 14, 2011 2:35PM .

1

._1 ~ :c; ;::~·· 

Regner, Lisa · · ·;:>-

Subject: Limerick- NRC LD. Docket 2011-0166 -::::::: ::;?. .~-~2 ~·: 

iTi . '>:' 0, 

Reference: Request for Denial of Limerick License Renewal - ~ i$; NRC J.D. Docket 2011-01-66 'c;2 (/) 

Dear Ms. Regner: 

he possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates 

more than 12 years ahead of time, worries me a great deal. It's hard to understand why something this major would be 

one so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth 

ould this be renewed so early? It's a lengthy process that could begin earlier, but in no way should something this 

mportant be rushed through now. Why not wait until closer to the expiration dates, and then seek approval? I 

nderstand this is how the original guidelines were set up - but those are long outdated. Approving Limerick Nuclear 

Plant to be relicensed until 2049 would be jeopardizing the health of millions. Renewing this license could be catastroohic 

o millions. Someone has to speak up; someone has to step up. 141-1-LR I 

Earthquakes and other natural disasters are more frequent and stronger than ever before. Limerick is 

3rd on the earthquake risk list. Underground pipes and cables can shake and break, which 

would lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard 

containment flaw means more radiation would be released. It is simply too dangerous to keep 

Limerick operating. Would you want to live within miles of this potential catastrophic disaster? Add 

the enormous population growth that this area has seen over the past 10 years - with little to no road 

improvements - and attempting to evacuate the area during a disaster would be futile. It would be 

virtually impossible to get out of harms way. 141-2-0S I 

The older any facility gets, the more likely breakdowns and equipment failure will occur. Limerick was built to last 

40 years. Limerick is showing signs of stress and no one knows just how bad this will be by the time 

the current license is up. To add 20 more years to that, without possibly knowing what the condition 

will be, would be careless. No one can predict what the condition of Limerick will be in 2024 or 2029. 

Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not an 

ootion. Plain and simole. That's a scarv thouaht for those of us who live here!! 

hey could monitor themselves. It should be obvious to NRC that Limerick played a major role in our 

cancer crisis after Limerick started operating in the mid 1980s to 2000. Four cancer studies based on 

Pennsylvania Cancer Registry and the CDC showed skyrocketing rates for several cancers much 

higher than national and state averages, especially in children - innocent children. Thyroid cancer 

increased by 128% from 1985 to 1997. I have local friends and family with thyroid cancer and brain 

ancer- not one, but several. Sadly, it's no longer uncommon in this area to have a personal link to 

ancer. However, it IS uncommon in other areas of the country. It used to be uncommon here too -

prior to Limerick. Would YOU want to live here? Would YOU approve a license renewal so close to 

home? Your job is to safely review the facts. Don't like the money of these corporations ~~~-!----. 

acts. 

Thank you for your time today. Just remember, it would be careless, unethical and immoral for NRC to approve ' 

requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 41-4-0R 

. Sincerely, • · /'-

SUVSL lfe-//~~&..4::. 

A~-P/3 

/*:ZYS-= J9'!:Y-/-~ 3 

~-=X:4~C~£_~ 
Appendix A

A-271

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Dear Ms. Regner: 

joanmcglone@comcast.net 

Sunday, October 16, 2011 10:11 PM 

Regner, Lisa 

Limerick License Renewal 

re: Limerick License Renewal- NRC I.D. Docket 2011-0166 

I am opposed to the license renewal of the Limerick nuclear plant which was designed to safely . 1(2-1-

operate for 30 yrs. and should now be safely ,1>hut down. Statistics regarding nuclear accidents at OS I 

similar aging structures are well documented. Those two towers are ticking timebombs and the NK~ 

knows this and needs to shut them down. Following the Japanese nuclear disaster our Limerick 

literature 

nuclear_pJant 

also. 

hit 

Why 

the 

does 

statistical 

the NRC 

at risk 

think 

list 

they 

again. 

can 

The 

play 

increased 

God with 

risk 

people's 

of cancer 

lives? 

is well-founded 

It is no longer 

in the 

~ H 

debatable, shut it down before our very lives are jeopardized!!! 

So-called quality of life issues addressed as part of public debate, e.g. "the power is always on"I42-3-0R I 

seems irrelevant to us when our families are required to evacuate during a disaster. Limerick must 

be closed and NOT relicensed at any cost, specifically the cost of life itself! 

Sincerely, 

Joan McGlone 

Resident of Royersford borough 

JJ 

'Tl 

\ .) 

-n 

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Appendix A

A-272

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Appendix A

A-273

Mendiola, Doris 

Subject: 

Attachments: 

-----Original Message-----

FW: •umerick License Renewal-NRC I .D. Docket 2011-0166 

Limerick.odt 

From: Angelbosley <anqelbosley@aol.com> 

To: Lisa. Regner <Lisa.Regner@NRC.gov> 

Cc: AngeiBosley <AnqeiBosley@aol.com> 

Sent: Sun, Oct 23, 2011 12:48 pm 

Subject: •Limerick License Renewal-NRC I. D. Docket 2011-0166 

Lisa Regner: 

Hello, I am attaching a letter to you regarding Limerick Power Plant trying to Re-license until 2049. Please read it. Thank 

you for your time and attention. 

Sincerely, 

Lisa Smoyer 

1027 Farmington Ave. 

Pottstown PA 19464 

484-945-0246 

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Appendix A

A-274

Sunday, October 23, 2011 

Lisa Regner, License Renewal 

Mail stop TWB-05-BO 1 M 

Washington DC 20555 

Lisa.Regner@NRC.gov 

*Limerick License Renewal-NRC I.D. Docket 2011-0166 

Dear NRC/Lisa Regner: 

I was unable to attend the public hearing at the time that is occurred. I would like to voice my concern 

to all of you through this Jetter. There are so many reasons why you as a group should already know 

that it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, wildlife 

in general and the environment for you to refuse/oppose Limerick Power Plant from re-licensing. The 

problem that always seems to come up at some of these public hearings and sessions where 

businesses/corporations want to expand and become bigger and run their businesses long past the time 

that they should truly be allowed in order to keep people safe, always comes back to the issue of 

money, offerings, bribes, donations, etc. in the end. When these things occur, people and businesses 

tum a "blind eye" so to speak to the dangers of allowing a business like the Limerick Power Plant to 

renew its license again. That is unacceptable! I expect and demand better service from you tn h Pin 

protect myself and my family from harm! 144-1-0R I 

an eart wrenc mg to now t at o tcta s an orgamzattons are not paymg attentton to w at can 

happen to the public if Limerick Power Plant continues to operate longer then expected. Ignoring the 

obvious problems our community is facing and hoping that after they serve their term, it will be 

someone else s problem to deal with is unacceptable. Now is the time. Step up and do what is morally 

right for humanity. r-:4-:4-'-4-:--:::0:-:R::-~ 

We as a society need to wake up and start paying attention to the massive harm power plants can cause 

to the people, animals, water, air, etc. Why does everyone want to pay attention when it is way too 

late?? There are safer alternative forms of energy available to our country/communities. We should be 

working on them and training employees, who currently work for the nuclear power plants how to 

work with safer forms of energy to help our country move forward in today's society. 144-5-AL I 

Haven't we already seen some of the damage that a terrorist attack can cause for our country and for ~ 

others? Do you really need to risk more possible attacks on a power plant that is not fully equipped for 44-

6 

hat kind of attack or for some other natural disasters that can occur. This plant is not prepared for -PA 

ttacks with planes missiles and other threats such as a cyber attack. There should also be a concern .---

or accidents and leaks from corroding and deteriorating equipment at the site trom over the years 144-7-0S 
Appendix A

A-275

(Page 2 of3) 

which could cause parts of it to be shut down for periods of time, as well as the miles of buried pipes 

and cables. There are many concerns that should be fully looked at and considered, and just witt 

minimal thought to them, it shouldn't take a "rocket scientists" so to speak to figure out that it is not ir 

the best interest of the public or environment to allow them tore-license. 

he most alarming and compelling thing to me as a taxpayer, homeowner, and mother is the 

verwhelming and alarming cancer increases to the public after Limerick had started operating. The 

DC website showed a 92.5% higher than the national average for childhood cancer in six 

ommunities close to the Limerick Nuclear Plant which included, Pottstown, West Pottsgrove, Lower 

ottsgrove, Upper Pottsgrove, North Coventry, and Douglass Berks Township from cancers diagnosed 

om 1995-1999. The Pennsylvania State Cancer Registry For Montgomery County- from 1985-86 to 

996-97 also shows cancer rates skyrocketed in Montgomery County where the Limerick Nuclear Plant 

s located during the Mid 80's to 90's after they opened. Prostate Cancer increased 132%, Thyroid 

ancer increased 128%, Kidney cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin's 

isease increased 67%, Non-Hodgkin's Lymphoma increased 61 %,Breast cancer increased 61%, 

ancreas cancer increased 54%, and Leukemia increased 48%. 

adiation exposure can cause cancer and other serious disease and disability, at any level of exposure 

ccording to the National Academy of Sciences and Physicians for Social Responsibility. Permissible 

adiation levels does not mean that they are safe levels for everyone in the community. Most 

ermissible levels are based on the average healthy adult. They are not levels that were based or 

esearched for fetuses, infants, toddlers and children or pets. Fetuses, infants, children, pets and the 

lderly and immuned compromised individuals are at most risk of health problems. There is a broad 

ange of dangerous radionuclides routinely released into our air and water from the Limerick Nuclear 

lant as well as any accidental releases. Permissible radiation levels does not mean that they are safe 

adiation levels it on! means that the are allowed. 

44-7-

OS 

Cont'd 

I have children as well as other loved ones that have or have had allergies, asthma, learning disabilitie,.,_H_H__,_..J 

speech disabilities, behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc. 

I expect you to do what is morally right now for me, my family, my neighbors, my community, and the 44-11 - 1 

pets, wildlife, air, water, and environment in whole by rejecting, refusing and opposing Limerick Power OR 

Plant from re-licensing to· run their business longer then originally planned for 2029. Don't tum a 

"blind eve" now. Do vour iob knowing: that vou are doing: what is morallv ri12:ht and safe for humanitv 

and for my children and for the future of generations to come. Please help women have a chance to 

carry a baby full term without complications due to any possible air and water pollution that may have 

been caused by allowing more radiation into the environment when there are safer alternatives for 

energy. . J44-12-AL J 
Appendix A

A-276

(Page 3 of 3) 

One person/individual can make a huge difference in the life of others whether or not you realize it. It 

can have a domino effect on others. Please step up and be that one person that we truly need right now 

to do what is right. Why does it have to take someone to be personally affected by a situation or to 

have a loved one suffer or die to step forward and do something? Please don't wait. Now is the time. 

Please be courageous enough to stand up and fight for what is right for this community and for 

humanity in a whole, no matter how hard or long the task may seem, it will be worth it in the end!!! 

I appreciate your time and attention in this matter. Thank you. 

Sincerely, 

Lisa Smoyer- Upper Pottsgrove Resident 

1027 Farmington Ave. 

Pottstown P A 19464 

CC: Friends, Family and some community members 
Appendix A

A-277

October 8, 2011 

U.S. NRC 

Ms. Lisa Regner 

Mailstop TWB-05-801 M 

Washington, D.C. 20555 

Lisa.Regner@NRC.gov 

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Subject: Deny limerick license Renewal - NRC I.D. Docket 2011-o1&6 

Dear Ms. Regner: 

I urge NRC to deny Exelon's request to renew Limerick Nuclear Plant's license for 20 

years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant must be closed, 

not relicensed, for many valid reasons. Approval for Limerick Nuclear Plant to be relicensed 

until 2049 would be reckless and would show blatant disregard for the health and safety of the 

public. There is more than sufficient evidence of harms and threats to justify closing Limerick. 

There are too many things beyond NRC's control that could lead to a catastrophic meltdown. 

limerick is 3rd on the earthquake risk list. It is too dangerous to keep Limerick 

operating. Earthquakes and other natural disasters are more frequent and stronger. 

Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling 

water, and meltdown. Limerick's substandard containment flaw means more radiation would bA 

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145-1-0R I 

released. J45-2-PA 

Everything has a life expectancy. Limenck's was 40 years. The older any facility gets, 

the more likely mechanical breakdowns and equipment failure will occur. When it's a nuclear 

I 

plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and 1-:4-::5,-3""'--=o:-:S~I 

equipment. Miles of difficult to inspect corroding, deteriorating underground buried pipes and 

cables are a major concern. Signs of mechanical damage and breakdown already exist - three 

unplanned shutdowns June 2011, preceded by many others since 2007, one with loss of cooling 

water. While some parts can be replaced, by the nuclear industry's own admission, some 

eauiornent is too bia and exoensive to reolace. 

errons s ave rna e 1 c ear ey 1n en o a a nuc ear p an s. xe on as re us o 

pay to guard Limerick against a 9/11 type terrorist attack with a plane or missile, even though 

the most deadly targets (limerick's fuel pools) are vulnerable to such attacks. Limerick is a 

similar design to nuclear plants in Japan that are melting down and exploding. NRC's own 

report from 2000 shows people 500 miles away could be impacted by an accident or attack on .-:'::,.....,--=::::-• 

such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick's vulnerable 45-4-0S 

fuel pools five stories high. Cyber attacks, now declared an act of war, could wipe out systems 

that could lead to meltdown. Hackers have penetrated the Pentagon and other well guarded 

s stems. Exelon's new Jan for c ber attacks ives us little comfort. 

No NRC policy, review, or report can make Limerick failsafe from a catastrophic 

meltdown. Over ei ht million eo le live within 50 miles of Limerick Nuclear Plant. Safe 

,.C -/{!-- 2> S .::: /9-DIY- 0 3 

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Appendix A

A-278

.... ···!" "" 

evacuation is merely an illusion, even within the seriously flawed and fundamentally inadequate 

current 1 0-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation 

plan (minimally to 50 miles) and be sure there are enough shelters and supplies available to 

accommodate the over 8 million people within the 50 miles. Exelon should pay for the supplies. 

Unless this is done, limerick should be closed as soon as possible. 

But, it doesn't take an accident or disaster for limerick to poison the region's residents 

with radiation. Radiation from Limerick's routine and accidental emissions alone for the past 26 

years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous 145-6-HH 

radiation levels are safe for me and my family when there is no safe level of exposure according 

to the National Academy of Sciences and Physicians for Social Responsibility. 

NKv IS ramng tO acKnow1eage oov1ous nearm narms rrom umencK·s connnuous aaamve, 

cumulative, and synergistic radiation releases which get into our water, food, soil, vegetation, 

milk, and our bodies. NRC has no idea what health harms some of the region's residents 

experienced from limerick Nuclear Plant. NRC never did any radiation monitoring or testing at 

Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted. 

Exposure to radiation is known to cause cancer. It should be obvious to NRC that 

limerick played a major role in our tragic, well documented cancer crisis after limerick started 

operating in the mid 1980s to the late 1990s. Four cancer studies based on PA Cancer Registry 

and CDC data showed skyrocketing rates for several cancers far higher than national and state 

averages, especially in children. Our children had the highest levels of Strontium-90 radiation in 

their baby teeth of any group near any nuclear plant studied. limerick Nuclear Plant released 

SR-90 into our air and water that got into the milk, vegetation, and food since limerick started 

operating. Thyroid cancer increased by 128% from 1985 to 1997. Other cancers rose 

dramatically as well. 

Limerick Nuclear Plant is slowly destroying the vital public drinking water source for 

almost two million people from Pottstown to Philadelphia. Radioactive and heated wastewater 

is discharged by limerick Nuclear Plant into the Schuylkill River 24n. Limerick's cooling towers 

are causing significant depletion. To supplement the flow to operate limerick, Exelon wants to 

pump more contaminated mine water into the river. No one can credibly assure us if drinking 

water will remain safe even until 2029 when Limerick's original license expires. 

limerick contaminated groundwater. Radioactive leaks and spills over the years were 

never cleaned up. More radioactive leaks can be expected in the Mure through earthquakes, 

deterioration, and corrosion. Many residential wells are very close to Limerick. 

Sincerely, 

e ~ JJ--4L45-7-HHI 

45-8-HH I 

45-9-SW I 

45-10-GWI 
Appendix A

A-279

1618 Benjamin Dr. 

Ambler, PA 19002 

Oct. 21,2011 

Ms. Lisa Regner 

Project Manager 

NRC Environmental Review Project 

Dear Ms. Regner: 

am writmg to express my opposition to there-licensure of Limerick nuclear power generating station, 

hich is located about 20 miles from my home. There are several reasons why this re-licensure is not in 

he best interests of people living in the surrounding community. 

1 H tnts ucense renewal ts gramea, thts ptam wut contmue operatmg until ~u<+~, at wmcn ttme tt Will be 

over sixty years old. Cracks in concrete and corrosion in piping will inevitably develop as this facility 

ages. While some of this "wear and tear" may be evident to visual inspection, some of it will also occur 

in less accessible places, such as in underground piping systems. The Associated Press has shown that 

tritium leaks in underground piping systems frequently go undetected-sometimes for years-in aging 

nuclear power plants.' While no leaks of this kind have so far been documented at Limerick, the odds of 

these sorts of problems developing will only increase with every successive decade of the plant's working 

life. 

While the problems associated with age will develop in any nuclear power plant over time, there are 

additional problems with the reactors at Limerick. Limerick's reactors are boiling water reactors similar 

to those that catastrophically melted down last spring in Japan. Although these reactors have a later 

containment design, _they have the same fundamentally flawed reactor pressure vessel design as those that 

fai led at Fukushima." In the BWR design, the control rods come up through the bottom of the pressure 

vessel, instead of dropping down from above as in other reactor designs. While the reactor pressure 

vessel itself is made of very thick steel, the bottom of the BWR pressure vessel contains 60 holes through 

which the rods enter the vessel.'" In the event of a meltdown, however, these same holes can provide a 

" path of least resistance" through which the hot molten fuel can escape with relative ease; it then only has 

to melt through connecting pipes that are much thinner and weaker than the metal of the pressure vessel 

itself.'v This apparently occurred at Fukushima, where authorities now admit that reactor fuel underwent 

not merely a "melt-down," but a "melt-through," breaching the inner pressure vessel and in the process 

releasing considerable amounts of radioactive material into the environment.v 

146-1-0R I 

146-2-0S I 

146-3-0SI 

vne mtgm oe tempteo to otsmtss tne companson wnn ~uKusmma on me grounos umencK m 

Pennsylvania is unlikely to experience a similar combination tsunami and earthquake. While the tsunami 

is not an issue, however, recent analysis by the Nuclear Regulatory Commission suggests that 

earthquakes pose a more significant threat to the Limerick reactors than was recognized at the time of 

their construction and initial licensure. (Incidentally, it now appears that at least one of Fukushima's 

reactors was significantly damaged by the earthquake even before the tsunami struck.).; According to the 

NRC's own data, Limerick's two reactors are the third and fourth most likely in the country to sustain core 

damage in the event of an earthquake.vii There is a fault line called the Ramapo fault line that runs 46-4-P A I 

slightly north of Limerick, and two small earthquakes associated with this fault line occurred as recently 

as February 2009 . .-;;; The unexpected quake that shook Virginia's North Anna nuclear plant with over two 

times the amount of f orce that it was designed to withstand should make us take very seriously the NRC's 

data regarding Limerick's greater than previously recognized vulnerability to earthquake damage_;, 

These concerns are compounded by the fact that the manufacturer of Limerick's control rods, GE Hitachi, 
Appendix A

A-280

Questions about the Limerick reactors' ability to withstand accidents and natural disasters are all the more 

pressing because so many people could potentially be affected if something catastrophic were to occur. 

Since 1990, the population within a ten-mile radius of the plant has increased by 45%, from 178,047 to 

257,625." In addition, Philadelphia, with a population of I ,526,006, is only about 28 miles away. How 

much more might these populations increase by 2049? Bearing in mind that the NRC advised Americans 

within a 50 mile radius of Fukushima to evacuate last spring, one can only imagine how difficult it would 

be to carry out such evacuations if the unthinkable were ever to occur at Limerick. 

Finally, my concerns regarding the impact of this nuclear power plant on my community are not limited 

to catastrophic scenarios that might potentially occur. There have been some recent studies published in 

health journals that show a higher incidence of certain illness-particularly among children-in 

communities surrounding nuclear power plants."' While these studies were conducted in a variety of 

locations, they seem to be consistent with some of the data that Pottstown's local Alliance for a Clean 

Environment presents on its website regarding in,creased cancer and leukemia rates-also especially 

among children-in the greater Pottstown area."" 

For all of these reasons, I am asking the Nuclear Regulatory Association to deny Exelon's request to 

extend Limerick's operating license for an extra twenty years. 

Thank you for your time. 

Sincerely, 

Lori Molinari 

46-5-0SI 

46-6-HH I 
Appendix A

A-281

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Regner, Lisa 

Thursday, October27, 201 110:17 AM 

Gallagher, Carol 

Mendiola, Doris 

Limerick Comment dictated to PM (docket NRC-201 1-0166) 

Environmental Scoping comment dictated to PM (L. Regner) on October 27, 2011: 

I'm against it for two reasons: 

11 am fully aware of the amount of cancer that 1s prevalent 1n this area. 1147-2-HH I 

Doris Meyers 

Read back to Ms. Meyers twice by PM to ensure accuracy of dictated statement. 

Lisa M Regner, Senior Project Manager 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

lisa.Regner@NRC.Gov 

Office: 0 11 H-23 

Mail Stop: 0 11 F-1 

(301) 415-1906 ~0 

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Appendix A

A-282

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hello Ms. Re ner: 

quteasz@comcast. net 

Thursday, October 27, 2011 3:03 PM 

Regner, Lisa 

Limerick Nuclear Plant Relicensing 

Just a quick note requesting the NRC to NOT allow the relicensing of the Limerick, Pr.a-:::-.-':- ~~ 

nuclear plant at this time. 48-1-0R 

move o o sown, a., some 1me ago 1n pe ec ea . , w w1 

prostate cancer. Although, I cannot prove it was a direct cause of the nuclear power plant, 

I feel that much further, unbiased studies and tests need to be done prior to the 

relicensing of the Limerick plant by reputable sources not by corporate interests groups 

that can manipulate the statistics in Exelon's favor. 

Wouldn't it be in the best interest of our community and surrounding communities if the 

higher cancer rate was due to the Limerick power plant???? This question is a "no r.-:::--=-:-:-:'-:--1 

brainer". 

There is plenty of time for testing to be done prior to the relicensing. 

so, w y e urry ... 

hich we are not aware. 

hy must the license be renewed at this time when they are licensed through 2024 and 

029???? 

gain, WHY THE HURRY??? 48-

3-LR 

o relicense now is not in the best interest of everyone in our area. 

Prior to the construction of the Limerick power plant, everyone in our surrounding area 

was told that our electricity would be one of the lowest in the U.S. 

THIS WAS A BOLD FACE LIE!!!! IT IS ONE OF THE HIGHEST IN THE U.S.!!! r:-::--=-=~ 

Excelon lied to us then and the will distort the facts now. 

PLEASE DO NOT BE IN A HURRY TO RELICENSE LIMERICK WITHOUT COMPLETE 

AND HONEST TESTING BY AN IMPARTIAL COMPANY. There is plenty of time after the 

test results. 

Thank you for reading my e-mail. I hope God guides your agency into making the correct 

decision. 

Ken Sekellick 

661 N. Price St. 

Pottstown, PA. 19464 

guteasz@comcast.net 
Appendix A

A-283

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B 

936 Shenkel Road 

Pottstown, P A 19465 

October 25, 2011 

ocr, ~- n 1;-D I 11_ 1 • - I \ ;-

U.S. NRC 

C/0 Lisa Regner, License Renewal 

Mailstop TWB-0505-BOl M 

Washington, D. C. 20555 

Dear Lisa, NRC: 

Re: Limerick License 

Renewal 

NRC I.D. Docket 2011-0166 

As a physician, I am writing to help you understand that nuclear reactors are not safe. 

I attended the medical clinic in Hiroshima right after the bombing and saw the radiation 

horrors caused by nuclear bombing. I have kept a close watch on similar problems by 

nuclear energy in the medical field since then, not only worldwide, but because of our 

nearby nuclear power plant. Here are some concerns. 

Incidentally, baby teeth studies have revealed Strontium 90 radioactive particles which ~::-:-;:-;-, 

can affect the child's immune system for more illness. · 6-8-HH 

We can't control the use of nuclear in the rest of the world, but we can keep the U.S. 

safer by eliminating nuclear energies. Fortunately, many of our European allies including 6-9-0R I 

Australia have decided to phase out reactors. We should join them to reduce human 

suffering. Also this can reduce our increasing costs of health care! 

lease listen to this advice after years of doing my best for America. Rely on more and 

ruly safe and renewable sources like solar, wind and geothermal power. A patriotic dut)'-,----' 

imerick Power Plant is ranked in the top 3 riskiest nuclear power plants in the U.S.A. i6_11 _

0 R 

imerick Power Plant must be closed not relicensed. . 

Sincerely yours, 

Is! Fred S, Winter 

Fred S. _Winter, M. D. r-::-' 

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Appendix A

A-284

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@ 

Anthony Gonyea 

Onondaga Nation 

Hemlock Rd. Box 3198 

via Nedrow, NY 13120 

Oct. 15, 2011 JJ 

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David J Wrona 

US Nuclear Regulatory Commission 

Washington, DC 20555-0001 

RE: Project ID: Limerick Generating Station 

Limerick Township of Montgomery County, PA 

Dear Mr. Wrona, 

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Thank you for providing the Onondaga Nation with information about this project. If 

anything changes are made, I would like to be consulted. I realize that Unit 1 and Unit 

2 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may 

i (') 

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send updates and information until then. ,....,...,. .~.:-:---. 149-1-HA I 

In the event that during project construction, any archeological resources or remains, 

including, without limitation, human remains, funerary objects, sacred objects, or objects 

of cultural patrimony are uncovered, please Immediately stop construction and cqntact 

me at (315)952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at 

(315)475-2559. 

If you have any comments or questions about this matter, please do not hesitate to let 

me know. Thank you for your help. 

51~~ 

Anthony Gonyea 

A Faithkeeper for the Onondaga Nation 

Onondaga Nation Historic Preservation Office 

Section 106 Representative 

60.V5J /Je-J/1~~~ 

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Appendix A

A-285

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hi, 

q)?c,j~/1 

% i7r. S3-l-/~ 

Deb Penrod [deb24532@comcast.net] 

Thursday, October 27, 2011 8:06 PM 

Regner, Lisa 

greetings from a SUPPORTER of Limerick nuclear plant 

JJ ., 

, ... ) 

--· 

V1 

N 

wanted to let you know that I am a complete and full supporter of the Limerick Nuclear plant. I am 

lso supportive of the scientific judgement and expertise of those such as yourself who have the 'ob 

f making the decisions. f-=5"::'0-:::1'--:-S;::-:R;:::"' 

(I saw your name in an article in the Mercury where the writer was requesting that objections be sent 

to you. I thought I would take advantage of the contact information to state a contrary position.) 

I grew up in coal-mining country, and never saw a stream or a creek with clear water uncontaminated 

by acid mine runoff until I was in my late teens. Opponents to nuclear power have usually never lived 

near coal truck entrances to mines and coal plants, and have probably never lost family members to 

mine cave-ins or black lung. Risks should be minimized as much as possible, but the world will 

always have something that someone objects to. Unscientific or fear-based objections to nuclear 

power are unproductive and do not advance safe or reasonably priced power. 

I work in the pharmaceutical industry (I was first educated as a pharmacist, and then as an attorney; I 

now help to get new vaccines approved, and to help increase vaccination rates). The parallel I see is 

with the group of people who see disaster in every prescription drug product, and complain about 

everything the FDA approves or does. Nothing is ever 'safe' enough for them. 

Please renew Limerick, using the best scientific information and risklbenfit analysis available to ou. 

Thank you. 

Debby Penrod 

215 Amanda Smith Drive 

PO Box 516 

Pottstown, PA 19464 

,c-~-z::xs = /l ])H- t?J 3 

~ -:-ex. /5 ~ c h<-/19_,,2-) 
Appendix A

A-286

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

DocKoenig@aol.com 

Thursday, October 27, 2011 8:49 PM 

Regner, Lisa 

Fwd: Nuclear Limerick 

From: DocKoenig@aol.com 

To: LisaRegner@nrc.gov 

Sent: 10/27/2011 7:36:13 P.M. Eastern Daylight Time 

Subj: Nuclear Limerick 

~0'&/~~ 

r/G 3~:1~ 

Hello Lisa Limerick should not .be licensed. or relicensed at this t ime. 

doing it because the plant has issues that they are trying to hide. The evacuation pia 

is a joke because we would not get out of our driveways. It would not have worked 10 lr:IS:-::1~1::-_-:::0:-:::S:--,1 

years ago and certainly with the population growth it would be much 

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Appendix A

A-287

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

· John & Joyce Webber [jbwebberpc@comcast.net] 

Friday, October 28, 2011 2:41 PM 

Regner, Lisa 

Exlon Limerick Relicensing 

As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from Exelon's Limerick Nuclear 

Power Plant), I urge you to vote AGAINST the premature relicensing of that facility. 52-1-0R 

o/C? J~ // 

2) It has now gone far beyond its limitations. ~ r /{_. 0.3-1- / f" 

p1 Tfie ,.., "o"od tfie foo,hty fi., e.ploded w,tfi fiom., ood """"-""'152-3-SE I 0 

(4) The roads to any safe place are overwhelmed with congestion with normal traffic. (5)The plant can n 

longer store its used fuel rods and has asked permission to begin transporting them to another facility. r:5!-::2:--4-=---::o""s"" 

(5) It is one of the six most dangerous plants in the country because of its proximity to an earthquake fault. 

j6) The surrounding area has abnormally high cancer rates among adults and children. 1152-6-HHI 

For all these reasons and many others too numerous to mention, it would be a truly disastrous mistake to 

extend Exelon's Limerick license for 20 years beyond the current licenses that do no expire until 2024 & 2029! 

Please consider the thousands and thousands of people who would be lost to an accident t hat could be 

prevented. 

Sincerely, 

Joyce B. Webber 

2338 Holly Drive 

Gilbertsville, PA 19525 

610-326-2584 

: ' ~ 

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Appendix A

A-288

Mendiola, Doris 

q /c:J4 I r::hfJ // 

;tr/?. S3-¢9~ 

From: Anita Baly [ajbaly@yahoo.com] 

Friday, October 28, 2011 3:06 PM 

Regner, Lisa 

--: ... \~ ,;...·. 

.-0 

Sent: C'.· 

To: .. , ~ 

Dear Lisa, 

Subject: Limeriok Pl•m Reli"'"""' AG"" 

It was good to meet you at the September 22, 2011 hearing the NRC held at Sunnybrook. 

V1 

w 

. . ! 8 _, 

0? 

~ 

As I stated then, I continue to be concerned and puzzled about the very early and pre-mature application of 

Exelon to extend the licenses of the towers. One of those towers does not come up for renewal until 2024 and 

the other 2029. I ask the NRC not to work on the relicensing question for this facility for at least ten years. Th~ 

wait could only ensure better information. The public cannot possibly benefit from a decision to renew the 

licenses at this time. The best decision will be made based on the best possible information. The NRC does no 

have that best information this early. Much will happen in the next ten years. I urge the NRC to wait and see 

r::-:::-:-L=---. how any of it affects the prospect of continuing these plants at that later date. 18-5-LR 1 

What can happen in the next ten years that we can all learn from relevantly could be anything. It may be better 

information about how natural disasters are affecting nuclear facilities; we may know more about weather 

patterns that could cause damage. We will certainly know more about the world situation in terms of advances 

in terrorist technological capabilities and goals. We will know more about how well nuclear plants in general 

and the Limerick facility are faring as they continue to age. If someone steps forward to fund studies, we will 

know yet more about cancer rates in the nuclear zone. (We do know something about that now: Joseph 

Mangano and others have done studies already that I assume he has provided to you, and I urge you to consider 

~fu~ ' 

One big concern--because of Japan's recent experience and the fact that we had an earthquake here in the 

Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes. It has been widely 

reported--by MSNBC and the AP, using NRC data--that the Limerick plant has the nation's third highest risk of 

being damaged by an earthquake. When the plant was built, no one thought this area would get earthquakes. 

Now we do. I understand that Congress is now or soon will be considering increasing earthquake preparedness 

capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would encourage them to 

do less than thev should to make the nlants safer. 18-6-PA 1 

There can be no good reasons for relicensing now. Please wait as long as possible to do that. Better 

information helps everyone who wants an outcome that is right and socially beneficial--not just profitable for 

Exelon. 

Thank you for your consideration. 

Anita Baly 

,E~_2).5 .=:: /JZJ.t7-23 

~ --:7 ~ 0-~.e_:l._) 
Appendix A

A-289

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Appendix A

A-290

MONTGOMERY COUNTY PLANNING COMMISSION 

box 311 • norristown • pennsylvania • 19404-0311 • 610-278-3722 

office location: suite 201 • one montgomery plaza • swede & airy streets • norristown pa 

FAX 610-278-3941 • Website www.planning.montcopa.org 

:-.. ) 

JJ .--·, 

-n '-;; ) 

' ] 

;2:1 

r= 1--: (/'. 

October 25, 2011 

____ ... 

:71 :-::~ ~: 

Chief, Rules Announcements, and Directives Branch 

Mail Stop: TWB-05-B01M 

US Nuclear Regulatory Commission 

Washington, DC 205550001 

RE: Environmental Scoping Comments 

Limerick Nuclear Generating Station · 

Division of License Renewal 

NRC-2011-0166 

Dear NRC Staff: 

...._ -L 

:-ll I':Y CJ Vl 

Vl 

We have examined the.pr0posed reli~e~sing review info~mation presented by NRC staff 

at the Public HeMing held in .Pottstown on September 22 and the information posted 

on the web site. operated by the NRC. We feel thatit is vital that any decision 

regarding the · relicensirig ~f the Limerick Nuclear Power Station reflect careful 

consideration of all relevant public health and safety, security, and environmental 

issues that pertain to nuclear power generation in general and the unique conditions 

at the nuclear power generating station situated in Limerick Township. It is our 

understanding that an Environmental Impact Statement will be developed which 

addresses relevant environmental impacts pertaining to socioeconomics, 

environmental justice, and noise; cultural resources, archeology, and geological 

science; atmospheric sCience, .air' quality; hydrological sciences; transportation and 

land use ; radiation protection; nuclear safety, fuel cycle, waste, and accident analysis; 

construction, operation, refurbishment,, and decommissioning; regulatory compliance; 

aquatic ecology; and water quality. Further it is our understanding that a detailed 

safety review will be conducted to review design assumptions; assess aging 

management of safety systems; and determine if new monitoring and inspections are 

needed during the expanded licensing period. 

While we implo~e the NRC to do a full review of both environmental and public safety 

issues pei"tainin:g to the plant- particularly addressing radioactivity exposures during 

normal operation of the power station and. during various types of unusual events and 

disasters- we additionally feel that· the impact review preceding any relicensing 

decision should also address specific issues.pertaining to the plant based ·upon it's 

conformity to the Montgomery County Comprehensive Plan ·and overall county 

development policies. Below we h<~.ve itemize<:! is.sues wi~ respect to land use change 

and growth around the 'power plan.t, transportation ~d evacuation capacity, 

Schuylkill River; and county trruls that we feel warrant consideration in the 

r: ~·: 

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environmental impact study. 

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~=X? fi~ ~/.//(.~) 
Appendix A

A-291

NRC Staff -2- October 25, 2011 

Land Use Change and Growth around the Power Plant: '· 

Since the original plant was constructed, the population in the surrounding 

communities has grown dramatically. LimeriCk Township and nearby Upper · · 

Providence Township have been two of the most rapidly growing communities· in the · 

county. This gro:wi:h largely fueled by access to US Route· 422 Expressway and ' 

available land with suitable infrastructure, has dramatically chan'ged the character of 

the area surrounding the Limerick Power Station. In tlie .past few years, the .. ,· 

Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the 

adjoining Costco s.hoppi,ng center opened along US Route 422 about one mile north of 

the .. Limerick Power ~tau<,>i}. proper.cy.: ·'I'Ile.land adjoining tilosdacilities is being· · 

corisideredfor various types of retail and residential. uses. · At' orie time,· a large 

gamblirig casino had been prdposecl i.ri this location as ·well. Other lands in Lower 

Pottsgrove Township ne.ai the Limerick Power Station have also been proposed for 

similar types of uses. · .. · ··' 

While the county planniri:g commission has tried to promote·lowerderisi'ties of groWth 

in proximity to the Limerick Plant, the local communities and the marketplace favor 

this location for significant development due to its proximity to the US Route 422 

interchange at Township Line/ Evergreen Road. The growth that has taken place in 

the area around the power plant, and in particular the growth taking place·in the area 

immediately adjqiriing the. plant and the primary access to it; as well as the projected 

growth in the future, could complieate e~ad.1ation plans and the movement of · 

appropriate emerge'nc)i'resp8nse per'sbnnel'fo the ·plant in the event of'a disaster. 

Certainly this access could be even more critical in the event of-a natural disaster 

when other roads to the plant may be··frnpassable. The envit onmental assessment· 

review needs to analyze this 'groWth in the vicinity of the powe·r plant to evaluate what 

impact it would have: on plant operations and whether or not safe evacuation can take 

place from the newly developed areas. · · · · · ." . · 

ransoortation and Evacuation Caoacitv: · · 

ifhe growth in the whole US Route 422 Corridor has raised numerous proposals for 

xpanding the vehicle capacity of the 422 expressway. Current peak commuting 

raffic tie ups on portions of the expressway serve as evidence that it may have 

· nadequate capacity to continue to serve as a safe evacuation corridor for the region. 

ifhe county transportation plan recognizes the need for various road improvements 

fuong the US 422 ,Corridor to address current and future traffic demands. The first 

!Priority projects in the plan include ·interchange improvements· at the Township Line 

!Road/ Evergreen Road intersection which is also the primary access route to the 

!Plant; needed widening and reconstruction of the highway east of the power station 

!between Route 29 and US Route 202 in King of Prussia, reconstruction· of US Route 

22 in the vicinity of Pottstown, and the reconstruction and widening of the Route 422 

!Bridge across the Schuylkill River at Betzwood. A passenger train line is also 

!Proposed as a first priority in the transportation' plan to provide service' through the 

jwestem portion of the county into Norristown. The proposed route for this train line is 

!the existing Norfolk Southern rail line that goes through the Limerick Power Station 

!Property. O,ther ill).provenients including the widening and expansion of US Route422 

rom Pottsto&n tO Route 29 and additionhl i.iiterchange improvements at Township 

!Line/ Evergreen'Road·are pi-oposed.as ·seccindaiy priorities irl'tlie co'!.l.nty plan. In · 

ddition 'to these im..i.:>r9yeinents, several other' localiZed 1J;ripi:ove'ments iliat may impact 

!evacuation feasibility a:te'propased irt'the' cqurity plan. •: ' · · ·' · · · 

. 

-- .J 

54-2-0S I 

154-3-osl 
Appendix A

A-292

., 

... ... _ .. 

NRC Staff -3- October 25, 2011 

Due to tundmg lim1tat10ns m Pennsylvania, these proJects are not llkely to move 

forward at this time .. The envirpnmental impact review should consider the capacity of 

the roadway facilities to service the Limerick J>lant as well as provide sufficient 

evacuation .of the. area in the event of a disaster·. Possible mitigation strategies 'to be 

considen!d ui the environmental assessment review could include the role of Exelon in 

funding t4e imp~~i:~t road im:pr~vements needed in tt1is area to ensure safe 

evacuation and access to the, planf ln any type of disaster. . . 

·•·,'. '•,. · r .. 

Schuyuau River;,.> .,,., .. .: ':. ,: C·i. ;_. : ··.·' ·. , ...... , ; .. : . ·. ,. . . . . . . · ,. , . . 

Since the last i,mpact statemen!.was prep~~d il:)- ,1973, the S~hl!ylkill River haS been · 

designated as a state scenic river ari~ as a ,hefitiige,area 'fotb()tll the state and federal 

govemment. b.ue to these. designations. and the efforts. of non-· profit organiiations 

and local goveiT.lment, access t6 the river. has been expanded so that the river has 

become a recreati'on and heritage i:ourism destination. Use of the river in the vicinity 

of the plant will continue to grow. With the retum of American Shad made possible 

thi'ough down stream fj.sh ladder~, interest in th~ rive.r: 9quld even grow further in the 

future. · · · .. .. · · · · 

The .Limerick P,lant withdraws sizeable portions of river water. During low flow 

periods, additjonal.quantities of water are released into the river from the Wade~ville 

Mine. and Still Creek Reservoir in Schuylkill County to compensate for the water: · 

withdraWn. at the plant . . Thil:! .. process was initia)Jy approv~d ·. QY. the. Delaware River 

. Basin .Commission (DRBGHn ~003 and kept ~ytiye. t~ro.ugh a series of docket 

amend):Ilents . . ~tun~ rj.ver,w:ater,u,se is ~e.pende!'l!. upon the ability of this water make 

up sy~tem to opeJCate withinvariou.s wat.e]; quality. and flow,parameters set by DRBC. 

It is important.to evaluate. th~ iability oftli.~ use ofthe river water and water make up 

system to provide needed water through the expanded plant lifetime. Analysis of this 

aspect of plant operation needs to account for the water quality impact from the total 

dissolved solids in the Wadesville water among other parameters. If resumed use of 

the Delaware water diversion is anticipated, an evaluation of that system is required tc 

ensure that the capacity is available in the conveyance system and that water quality 

objectives can be met .for discharge .into the East Branch of the Perkiomen Creek. . 

County Trails and Open Space: . 

54-3-0S I 

Cont'd 

154-4-SW I 

The county has been working hard to develop an interconnected system of open space 

and trails along the': .Schuylkill River and within other natural re.source areas of the 

county .. In doing this, the county has provided funding to local muniCipalities and 

non-profit conservation organizations to purchase open space and park land; acquirec 

county land and agriculture easements; and developed trails. The Limerick. 

Generating Station site contains significant land along the Schuylkill River that has I 4 LU I 

been identified as part of the Schuylkill River Greenway in the county plan. The use 5 -5-

and management of these lands relative to the county open spac;e and natural areas 

inventory plans should be evaluated in. the relicensing process. . . . · 

.The Montgo~ery County Op~ri Space Plan proposes a trail along· th.e ~iver thro~gh the 

power plant property . . ,This trail is prqposed as the Schuylkill East Trail, which w~uld 

be developed as \.Inpav,e,dtrail. b~.r,Vee~ Mo.ti~ Clare and Pottstown. ·Essentially the 

proposed route w.ould .foJlow.an old road:WayJJetween ti:t~ 'rj.ver ~d Norfolk Sou them 

rail line through 'uie. LiiiierickJ'oW.er Station. site . . Though s:ucha trail routewould · 

appea. to mi" •ignificM\ i:.lOtY 00oci;fn~,'4ri~ lis ;><OP)>O"~ 'pi.<?><imity totli~ ~Owe, ~ 
Appendix A

A-293

NRC Staff -4- October 25, 20 11 

station, appropriate elements could be de~igned into any trail system to limit its threat 

to plant's security. We have found that trails can enhance the overall security of an 

area since they concentrate users along a defined corridor. Furthermore, trails can 

provide emergency access routes that could be used during different disaster events to 

evacuate people and provide access for emergency response. This trail and the 

m:iuuigemen~ ~(undeveloped portions of the Limerick Power Station site should be 

considered iri 'the environmental assessment. -

Community Outreach and Education: 

As part of the environmental assessment process and the evaluation of the plant 

safety and long term operational capacity, we think that it is important for the NRC to 

mainta.ID.close communication with the community surrounding the plant. Overall 

education about the plant and the associated risks presented by its operation should 

be provided in a variety of ways so that the public is better informed about the plant 

and the overall evaluation taking place as part of the relicensing. 

If you have any questions, please contact me. Also, we offer our assistance in 

providing local information that may be helpful to your review. 

Sincerely, · ·' •• " ! ·· f ;_, 

Michael M. Stokes 

Assistant Director 

mstokes.@montcopa.org 

(610) 278-3729 . 

:· .: 

: ... {; ' ~l ·: 

c. Thomas Sullivan, Public Safety DepaJ't!llent 

. •' o "' 

~ ; •' .. ' I ',• ! ' I f 

54-6-0S 

Cont'd I 

54-7-LR I 
Appendix A

A-294

COUNTY OF MONTGOMERY Commissioners 

JAMES R. MATTHEWS 

CHAIRMAN 

)OS~PH M. HOEFFEL BRUCE L. CASTOR, jr 

TiiOMAS M. SULLIVAN 

DEPARTMENT DIRECTOR 

October 25, 2011 

Ollef, Rules Announcements, and Directives Branch 

Mail Stop: 1WB-05-B01M 

US Nuclear Regulatory Commission 

Washington, DC 205550001 

Re: Environmental Scoping Conunents 

Limerick Nuclear Generating Station 

Division of License Renewal 

NRG2011-0166 

Dear NRC Staff: 

Montgomery O>Unty 

Department of Public Safety 

Operations Center 

50 Eagleville Road 

Eagleville, PA 19403 

(610)631-6500 FAX (610)631-6536 

www.dps.montcopaorg 

o/c74-/:?LJ 1/ 

;zr)(.6-o_LJ ~ 

) 

.. ·! 

® 

The Montgomery County Department of Public Safety would like to offer the following conunents regarding 

the NRC relicensing review information presented at the Public Hearing held in Pottstown on September 22, 

2011. 

• [The NRC should provide a full review of environmental and public safety issues pertaining to the plant . 

t is understood that emergency responders providing services to the power plant understand the 

::n 

c::: 

r-,-:-··. 

(j', 

·.--.1 . --j-i-j 

c; 

.....; 

(f) 

~ 

~azards associated with daily operations of the plant. However, in light of events in Japan and recent 

eismic activity in this area, the NRC should clarify the risks associated with plant operations in times of 155-1-0S I ~usual activity, outage operations, and during times of natural I man-made events that may pose a risk 

o the plant in terms that the public will understand in an attempt to quell public concern. 

• rwe concur that the NRC require Exelon to conform to the Montgomery County Comprehensive Plan 

o not only ensure cooperation in the conununity, but also in the region. Additionally, it is also 155-2-0SI uggested that Exelon be included in pending roadway infrastructure improvements projects as both a 

take holder and possible source of funding. 

• It is important to note that the 10 - mile Emergency Planning Zone (EPZ) is the second largest in 

population in the nation. As a result of recent development and type of development in the area of 

LGS, it is important to review the Evacuation Tune Estimate Study (ETE) on a more timely basis and 

account 155-3-osl for the transient population present in the hotels that have accompanied this development. 

Additionally, funding should be supplied for either Exelon staff or County staff to act as a transient 

planning and outreach specialist to assist these transient population locations with emergency planning. 

• It should be noted that the Evacuation Time Estimate is currently being updated. Required highway 

and roadway infrastructure upgrades should be included as a part of and also as a result of any changes r::-:~~~ 

noted in the updated ETE. Special attention for improvement should be given to the local, county and 155-4-0S I 

state roads used for evacuation that feed the larger highways, as many of these roadways are no longer '------' 

suitable for the amount of traffic that an EPZ evacuation could produce. 

~-;/{.2.-]Js -:::: J9 A~-.lJ .3 

~=X ;f~ 0-H;:<;z.j 
Appendix A

A-295

• 

-2- October 25, 2011 

• The NRC should consider requiring Exelon to enhance planning for day to day emergency situations 

that require a response from local emergency services. Often times, Fire and EMS access is delayed due 155-5-0S I 

to screening of vehicles and personnel This can cause delay in patient care to potentially life 

• 

• 

threatening illnesses . 

While recreation utilization is of importance and a major mission within this county, homeland security 

must be of a concern with any open access within the vicinity of LGS. However, we concur that with 1-:5:-:5=--=7=---,~ 

support of local law enforcement and a commitment from LGS to control and monitor access, trail OS 

thr<iughput may be accomplished. 

• In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon 

to reopen the LGS Information Visitor Center. As a result of the incident in Fukushima, Japan, the 

Montgomery County Department of Public Safety has a received a higher than normal volume of 1==--=--=-=-> 

inquiries concerning nuclear power generation from the public. The LGS Information Center, although 55-8-0S I 

dated, could be upgraded to provide this service to the community to raise awareness and promote 

education of the nuclear power industry. This center could also be incorporated as an educational stop 

on the County Trail system. 

If you have any questions please feel free to contact me. 

( t."'":~~ L ~omas M Sullivan 

Director of Public Safety 

CC: R. Graf, CO.O. 

M Stokes, Assistant Director of Planning 

S. Mickalonis, Deputy Director for Emergency Mgt. J. Wilson, Radiological Planning Specialist 
Appendix A

A-296

THE 

~·~c EARTH'S BEST DEFENSE 

October 28, 20 II 

Via Electronic Mail 

Ms. Cindy Bladey 

Chief, Rules, Announcements, and Directives Branch 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Washington, D.C.20555-000 I 

Electronic Mail: cindy.bladey@nrc.gov 

RE: Natural Resources Defense Council Comments on Limerick EIS Scoping Process 

NRC Docket ID NRC-2011-0166 

Dear Ms. Bladey: 

The Natural Resources Defense Council (NRDC) comments today on the Nuclear Regulatory 

Commission's (NRC) Notice of lntenl To Prepare an Environmenlal lmpact Statement and 

Conduct the Scoping Process for Limerick Generating Station, Units I and 2, (hereinafter 

"Limerick EIS Scoping Process"). 76 Fed. Reg. 53498 (August 26, 20 II ). 

Summary of Comments 

Our comments specifically address the NRC's National Environmental Policy Act ((NEPA) 42 

U.S.C. § 4321, et seq,) obligations and the need for any environmental analysis the agency 

conducts to include an up-to-date "Severe Accident Mitigation Alternatives" (SAMA) analysis 

that fully incorporates current insights into severe nuclear accident causation and mitigation. 

While we recognize that, as a private entity, the relicensing applicant, Exelon Generation 

Company, is not directly bound by NEPA, the same is not true for the NRC. Given that the 

applicant's ER generally serves as the basis for the Commission's eventual Draft Environmental 

Impact Statement (Draft EIS), and Exelon suggests it need not revise and update its SAMA 

analysis, we are raising this NEPA concern at this early stage in hopes that this matter may be 

addressed before the agency moves to relicense a facility based on a legally insufficient NEPA 

review. 
Appendix A

A-297

C'ommPnf<: 

The original SAMA analysis for the Limerick Generating Station (LGS) is a 1989 report that wa 

issued as the result of a ruling by the U.S. Court of Appeals for the Third Circuit, 

1 which 

concluded that the NRC had failed to consider a "reasonable set" of Severe Accident Mitigation 

Design Alternatives ("SAMDAs"). In 1989, the NRC subsequently adopted this SAMDA 

analysis and agency staff concluded they had "discovered no substantial changes in the proposed 

action as previously evaluated in the FES [Final Environmental Statement] that are relevant to 

environmental concerns nor significant new circumstances or infom1ation relevant to 

environmental concerns and bearing on the licensing of [LGS]". 

As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, 2 

the notion that an updated SAMA analysis need not be completed at the license renewal stage 

(for the exact reactor site that gave birth to the regulatory requirement) we find highly 

objectionable, particularly in light of the catastrophic nuclear accident that befell similar Boiling 

Water Reactor (BWR) units in Japan in March, 2011. It has become clear in the 770 years of 

combined U.S. BWR operational experience since 1989 that domestic and international events 

provide numerous examples of "new information" and make a strong case for the need to 

reconsider all that has been learned about newly discovered risks and vulnerabilities of nuclear 

power plants. 

It has been noted3 that global core damage events happen at a rate that exceeds NRC's 

presumptions of what should be considered safe at plants within the U.S., which implies that 

either the NRC estimates for domestic plants are wrong or that international nuclear plants have 

a core damage frequency much higher than what the NRC deems safe. Either scenario is 

troubling and deserves the industry's full attention and effort. Exelon's 1989 effo11 in response 

to the Court was, respectfully, less than one would have hoped for in light of the seriousness of 

the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to 

public safety over the total timeframe of a possible sixty year reactor lifetime. 

In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license 

renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the 

Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and addressed 

a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied by NRC4 

and aided by an industry-supplied gnidance document5

, most modem-day SAMA analyses are 

designed using a fairly prescriptive set of initial assumptions, baseline calculations, and costbenefit arithmetic recipes that employ the use of sophisticated codes in their evaluation of 

potential risk and the benefit of removing this risk. 

1 Limerick Ecology Action v. NRC, 869 F.2d 719 (3'd Cir. 1989) 2 Or SAl'v1DAs in this case, and we use the tenns interchangeably for the purposes of these comments. 3 Global Implications of the Fukushima Disaster for Nuclear Power, T. Cochran, M. McKinzie (NRDC). World 

Federation of Scientists' International Seminars on Planetary Emergencies. Erice, Sicily. Aug 2011. 4 NUREGIBR-0184 Regulatory Analysis Technical Evaluation Handbook, Jan 1997 5 NEI 05-01 [Rev A] Severe Accident Mitigation Alternatives (SAMA) Analysis- Guidance Document, Nov 2005 

156-1-PA I 
Appendix A

A-298

The most common code used is the MELCOR accident consequence code system (MACCS2)6

, 

which provides a modeling framework for calculating the off-site consequences of a severe 

accident. This code accepts an advanced set of input parameters, including population density 

distributions within 50 miles, detailed regional economic data obtained from multiple sources, 

nuclide release scenarios accounting for reactor core inventory, emergency response and 

exposure variables, and meteorological data for plume migration pathways. The current state of 

knowledge regarding the assumptions and understanding of severe accident events has expanded 

and improved in the intervening twenty-two years since the initial SAMDA analysis for LGS. 

While we acknowledge that this analysis was limited by the knowledge available at the time, the 

limitations and shortcomings of a previous era in no way disqualify the claim that, in light of 

numerous advances in modeling capabilities, a library of discovered cost-beneficial SAM As, and 

the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is 

there new and significant information, there are significant volumes of this information acquired 

since 1989. 

In the licensee's current environmental report, the identification and treatment of new and 

significant information (four items in total) were developed only in the narrow context of how 

they may affect the dated SAMDA analysis. It should go without saying that this approach does 

not comprise all of the applicable new and noteworthy severe accident mitigation strategies 

bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA 

analysis. 

The entire set of first-stage envisioned alternatives in the initial SAMDA analysis was no more 

than fifteen options. The "analysis" in the current environmental repor1 consists of perfunctory, 

"back-of-the-envelope" calculations in lieu of a proper SAMA analysis. The current operator 

Exelon referred to these considerations as representing an "abundance of caution." We disagree. 

One of the largest problems with the calculations offered, aside from only focusing on an 

arbitrarily limited number of alternatives, is that licensee evaluated each item of new information 

in isolation of the other factors that would also change the cost-benefit conclusion for a particular 

alternative. The effects of each changed parameter (e.g., population, offsite economic risk, cost 

per person-rem averted, and seismic hazards) should be evaluated in a comprehensive model that 

shows the aggregate benefit, as performed in all cmrent day SAMA analyses. Unfortunately, 

their analysis barely scraped the surface of how this new information should actually be 

considered in the context of environmental impacts. 

In comparison, a "reasonable set" of alternatives for another recently relicensed plant included an 

initial consideration of 128 SAMA candidates developed from previous lists at other plants, NRC 

documents, and documents related to advanced power reactor designs. 7 After screening this 

initial set for non-applicable or previously implemented designs as well as combining/dropping 

common-benefit options, the applicant was still left with a set of forty unique SAMA candidates, 

for which it was required to enter preliminary cost estimates in a so-called "Phase I Analysis." A 

6 NUREG/CR-6613, Vol. 1, Code ManualforMACCS2, User'sGuide, D. Chanin &M.L. Young, May 1998 7 Joseph M. Farley Nuclear Plant -Application for License Renewal, Appendix D. EnvironmentalReporl, 

Attachment F. Severe AccidentMitigationAlternatives, Sept 2003 

56-1-PAI 

Cont'd I 
Appendix A

A-299

total of fifteen SAMA candidates survived this screening to enter more detailed cost 

consideration in the Phase II aualysis, of which none were deemed cost-beneficial. However, in 

another renewal application, 8 the SAMA analysis found eleven potentially cost-beneficial 

options from au initial set of thirty-three. 56-1-PA I 

In an NRC report discussing insights on SAMAs in connection with plaut license renewals,9 th<I.._C_o_n_t_'d _ _, 

agency authors list numerous potentially cost-beneficial SAM As relating to station blackouts, 

protection and support systems, procedures and training, aud extemal events such as flood, fire 

and seismic hazards. The authors note that "averted onsite costs (AOSC) is a critical factor in 

cost-benefit analyses aud tends to make preventative SAMAs more attractive than mitigative 

SAMAs." This AOSC factor was not considered in either the original SAMDA or the recently 

submitted environmental report. 

Finally, NRDC believes that in addition to a comprehensively updated SAMA aualysis, the 

licensee or agency must conduct a study that, as part ofthe supplemental environmental impact 

statement, presents postulated accident scenarios showing the full range aud weight of 

environmental, economic, and health risks posed by these accidents. This type of study should 

model site-specific severe accidents and illustrate the full consequences of a rauge of severe 

accident scenarios so that the public aud their policy makers can make informed decisions 

whether to continue plaut operations after the existing licenses expire, thereby continuing to rur 

the risk of a severe nuclear accident, invest in additional accident mitigation capabilities, or 

altematively, avoid these risks altogether by relying on a portfolio of! ow carbon electricity 

generation altematives that could meet future electricity service needs over the license ell.1ensio 

period. 

l11e SAMA aualyses are inadequate in this regard because they only address isolated issues in< 

cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional 

economic losses, and environmental cleanup. These types of calculations do not present a clear 

picture of the potential hazards or costs experienced in the event of a severe accident. Instead 

they tend to mask the full range of accident consequences that policy makers may wish to avoic. 

Recently, NRDC produced an analysis, of the type we believe should be included in the 

Limerick NEPA aualysis, to inform ongoing relicensing efforts at the Indian Point nuclear piau 

site. 10 

In order to illustrate the full extent of a major accident, the NRDC study used the U.S. 

Department of Defense computer model HP AC (Hazard Prediction and Assessment Capability 

to calculate site-specific release radiological source-terms, resulting fallout plumes, and data on 

the effects on nearby populations. The results were compared to similar modeling of the 

Fukushima disaster to provide a sense of scale, aud to estimate the rough magnitude of financia 

8 Three Mile Island Nuclear Station Unit I -License Renewal Application, Environmental Report Appendix E. 

SAM4 ANALYSIS 9 Perspectives on Severe AccidentMitigationAltemativesfor U. S. Plant License Renewal, I. Gosh, R. Palla, D. 

Helton, U.S NRC, Sept 2009 (Accession No.: ML092750488) 10 Nuclear Accident at Indian Point: Consequences and Costs, M. McKinzie, Oct 2011 

(http :1 !www. nrdc. org/nuclear!inclianpoint/files/NRDC-1336 _Indian _Point_ FSr8medium.pdf) 11 Hazard Prediction and Assessment Capability (HPAC), version 4.0.4. Washington, D.C.: Defense Threat 

Reduction Agency, Apr 2004 
Appendix A

A-300

and economic damages that would be incurred if a severe accident were to occur at Indian Point. 

TI1is is not a hypothetical issue. Policy makers in several countries, including Germany and 

Switzerland, have made decisions not to grant nuclear plant license extensions to avoid having t 

endure the continuing risk of severe nuclear plant accidents. 

Regardless of Exelon's own corporate understanding of its legal obligations, NEP A is clear in it 

well-established mandates and what it requires of the NRC. NEPA requires that federal agencies 

characterize environmental impacts broadly to include not only ecological effects, such as 

physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, 

economic, and social effects.12 NEP A requires an agency to consider both the direct effects 

caused by an action and any indirect effects that are reasonably foreseeable. Effects include 

direct effects caused by the action and occurring at the same time and place and indirect effects 

caused by the action, but later in time or farther removed in distance, but still reasonably 

foreseeable. 

Most specifically, NEP A directs that NRC take a "hard look" at the environmental impacts of its 

proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional20 

years, and compare them to a full range of reasonable alternatives. "What constitutes a 'hard 

look' cannot be outlined with rule-like precision, but it at least encompasses a thorough 

investigation into the environmental impacts of an agency's action and a candid 

acknowledgement of the risks that those impacts entail." Nat 'l Audubon Soc. v. Dept of the Navy 

422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC's draft EIS 

the applicant's ER does not meet this standard. In taking the "hard look" required by law, the 

NRC must therefore address the potential environmental impacts of a range of severe 

accidents-and accident mitigation strategies-especially in light of the new information 

provided by the Fukushima nuclear disaster on the performance of BWR radiological 

containment in a prolonged loss-of-coolant, core-damage scenario. 

For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA 

analysis be conducted as part of (or supplement to) the required supplemental environmental 

impact statement, the draft of which is currently scheduled for August 2012 and the final SEIS 

currently scheduled for February 2013. Additionally, the full cumulative effect of severe 

accidents must be studied and presented as pat1 of these documents. These analyses must make 

every effort to meet the current expectations of what these studies should encompass and use the 

necessary guidance and tools commonly utilized by the industry and NRC. The NRC's legal 

obligation to consider new information and determine its nuclear safety significance exists 

independently of whether a SAMA has or has not been prepared previously: in the event a 

SAMA has not been prepared, then new and potentially significant nuclear safety information 

must be included in the initial SAMA; if a previous SAMA exists, then it must be updated to 

reflect this new information, and the resulting costs and benefits of the full spectrum of 

reasonable accident mitigation alternatives must be considered as part of the Draft Supplemental 

Environmental Impact Statement, and issued for public comment. 

56-1-PA I 

Finally, we have grave misgivings regarding the future time-dependence, accuracy, and '= l:-::--:-::::-1 

relevance of the licensee's current ER, as presumptively incorporated in the NRC's planned i56-2-LR I 

12 40 C.F.R § 1508.8 
Appendix A

A-301

SEIS for LGS license ell.iension, given that such license extension will not become effective unti 

the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for Unit 2. We submit 

that any decision to relicense these units must be supported by the most timely NEPA and 

SAMA analysis obtainable within a reasonable interval (e.g. five years) prior to actual expiration 

of the existing licenses. 

56-2-LR I 

Intervals of 12 and 17 years are not required for corporate planning purposes and are far too lomJCont'd 

to credibly sustain the accuracy and relevance of NEP A analyses, or for the NRC to accurately 

project both the future condition of the plant, the future state of nuclear safety knowledge, trends 

in local resource use, population, and the affected environment, and the future range of 

reasonable electricity supply alternatives to LGS license extension. By comparison, major 

government owned nuclear installations, such as nuclear laboratories and weapon production 

sites, are required to conduct site-wide NEP A reviews of their operations and facility plans ever 

five years. Using this federal standard for timeliness, the NRC's NEP A analysis for LGS 

relicensing should not commence before 2019, for Unit 1, and before 2024 for Unit 2, or should 

be subjected to mandatory reassessment and supplementation after those dates. 

We further note, given the extended timeframes for expiration of the existing LGS operating 

icenses, that they easily encompass the five year timeframe that the Commission has set out for 

ormulation and implementation of NRC staff safety recommendations to be undertaken 

'without unnecessary delay" in the wake ofthe Fukushima accident. In light of these important 156-3-0S I 

nuclear safety developments, we seek no reason why this proposed NEPA analysis, and hence 

he entire licensing proceeding that it is required to support, could not be deferred for at least five 

years, until the Commission has completed its decision-making and schedule for implementation 

of post-Fukushima safety upgrades. As noted above, to ensure the timeliness and accuracy of the 

NEP A analysis, the deferral could be even longer (on the order of 7 years for Unit 1 ), to allow 

or the inclusion of the results of the extended rulemakings contemplated under the 

Commission's regulatory response to the Fukushima accident. 

Preparation of the applicant's ER, and the NRC's subsequent SEIS, could then take account of 

these required safety modifications and enhanced severe accident coping strategies, and these 

would be reflected in a significantly revised SAMA analysis. In these comments, we are not 

formally advocating such a defen·ed pathway for the LGS relicensing proceeding, but merely 

note its plausibility and inherent advantages for all parties to the proceeding. Without such a 

deferral, the only sensible alternative course is to ensure the incorporation of the most up-to-date 

nuclear safety knowledge - "new and significant information" - regarding BWR Mark 2 reactors 

and severe accident mitigation into the current licensing proceeding. 
Appendix A

A-302

Thank you for your consideration of these comments. Please do not hesitate to contact us at 

(202) 289-6868 if you have any questions. 

Sincerely, 

G-z/t' !fF&, 

Geoffrey H. ettus 

C. Jordan Weaver, Ph.D. 

Program Scientist 

..I 

Christopher E. Paine 

Director, Nuclear Program 
Appendix A

A-303

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

lorraineruppe@aol.com 

Friday, October 28, 2011 6:33 PM 

Regner, Lisa 

Fwd:Faultlines close to Limerick Nuclear Plant JJ 

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Ms. Regner, I . . .. ' ' .. -._:,. ... , .. ' ' I 

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---- Please ::.:~ r r·, include this for the record concerning relicensing of Limerick Power Plant. 

----Original Message-----

From: lorraineruppe <lorraineruppe@aol.com> 

To: letters <letters@pottsmerc.com> 

Sent: Mon. Oct 24, 2011 9:09 pm 

Letter to Editor 

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Exelon is rushing the timeline to reissue a license(18 years ahead of time) to run Limerick Nuclear Plant into the unknown, I 

yet it took more than 5 months for the NRC to get back to me concerning an already known survey of fault lines. 14-13-LR 1 

It took five months for the Nuclear Regulatory Commission to answer my question concerning how close the nearest fault I 

line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Chalfont Fault is only 9 miles East. 14_

14_GE I 

Ramapo Fault is 17 miles Northwest. This is alarming! 1 

The 9-21-11 Mercurv article said" whether or not earthauake risk is a factor in the current relicensina reauest for Limerick 

remains to be seen". It would be grossly unacceptable for the NRC to ignore Limerick's extreme vulnerability to 

earthquake damage .. 

Earthquake risk should be on the top of of NRC's relicensing concerns for Limerick. Earthquake risks are far greater for 

Limerick than previously realized-increased by 141%. We now know Limerick is 3rd on nation's earthquake risk lis,_t :--:-::--:!:-::---, 

.Plus, evidence shows earthquakes in the East can be far stronger than Limerick's " design basis" can withstand. 14-15-P A 1 

There's a good chance that an earthquake can exceed Limerick's design basis, causing a severe nuclear accident. 

jeopardizing the health. safety and financial well being of our entire region. 

The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant .Since January there have been 2 small 

earthquakes in Philadelphia, only 21 miles from Limerick. 

Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to nuclear disaster. It's 

disquieting that NRC uses a "visual inspection" to determine damage on buried pipes. Problems may not be identified unt 

it's too late. 

For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on fires and earthquakes. 

To save money, Exelon typically concludes Limerick is "safe enough". This is unacceptable! 

10-5-11 , the Mercury reported a flaw was found in the mechanism to shut down the nuclear plant. The warning was tied t 

renewed focus on earthquake risk. It's difficult to see how Limerick's design flaws can be fixed, even if Exelon WOULD 

spend the money. 

There is no proof whatsoever Limerick's design can withstand other threats ranging from hurricanes. tornadoes. floods, o 

terrorist attacks to an impact from a jet airliner. 

We need precaution before there is a catastrophe. NRC should close Limerick as soon as possible. 

,£*!::6 = o?JH- z; 3 

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Appendix A

A-304

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

sunbeamsky [sunbeamsky@aol.com) 

Monday, October 31, 2011 2:28 PM 

Regner, Lisa 

power plant renewal 

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Appendix A

A-305

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Good Morning 

Smokowicz, April (Aprii.Smokowicz@graphicpkg.com) 

Wednesday, November 02, 2011 8:49AM 

Regner, Lisa 

msworkdog@verizon. net 

Pottstown Mercury article 10/27/11 

I know this is late according to your article, but I wanted to still send you some information. 

I feel that there is a lot of people that had not known to report anything because of not knowing who to go to. 

I don't understand why the hospitals don't give statistical information based on areas? 158-1-HH I 

Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's Hospital until she 

was 5. With several years of chemotherapy she is now 18 and in remission. We had lived on Limerick Center 

Road for most of our young lives and now with our kids. I don't know what other information you would need 

but I would be happy to get you whatever you might need. 

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Appendix A

A-306

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Appendix A

A-307

.,..... . 

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~U.S.NRC U nited Sr ~:s Nuclear Regul..:uor.y Co ssio ~ 

Proucting People and the Environmmt 

LIMERICK GENERATING STATION 

Environmental Scoping Comments 

Division of License Renewal 

N RC-2011-0166 

Written Comment Form 

Must be received on or before October 28, 2011.· Please print clearly. 

Name "\i r~ S-:\1\e· , c\J( 

Title. C \Y\ 7/< (\ 

organization: (At'\·, t'r<i-· L7t V\+e S of f-1- Mer; L-o__ 

Address: 2 q(" c.;- IJ~ /J-Mf-/1- tJ 17 Y <) -h City ~ Tf;/o t,..../ I"" State: / Jt: 1 

Zip Code: . / '1 Jl# ~ 
Appendix A

A-308