Friday, March 6, 2009

Open letter to DEP's David Allard - Nuclear Waste in Schuylkill River - Questions

The following is an open letter to David Allard from the DEP, received from Donna Cuthbert of The Alliance for a Clean Environment.

-------Original Message-----

From: aceactivist
Date: 3/5/2009 7:31:27 AM
To: DEP - David Allard
Cc: DEP John Hanger
Subject: Nuclear Waste in Schuylkill River - Questions

March 4, 2009

To: David Allard, Bureau of Radiation Protection

From: The Alliance For A Clean Environment

Re: Study Assessing Nuclear Waste In Schuylkill River

Mr. Allard,

Based on the article in the Mercury February 24 our group has questions about your study on nuclear waste in the Schuylkill River. You said you wanted “to be fully transparent”. We hope it is in that spirit that you will answer each of our questions. Has DEP published and made available to the public on line, all historical monitoring results, including specific radioisotopes, whether or not DEP considers them over or under limits? If so, please provide the link. If not, we ask that this be done as soon as possible.

We have long been concerned about the 3 sources of radioactive discharges into the Schuylkill River from Pottstown to Royersford.

We believe the major radiation threats come from the 5 billion gallons of radioactive wastewater discharged into the Schuylkill River each year from Limerick Nuclear Power Plant. This has been going on for decades.

1. Are Limerick Nuclear Power Plant’s massive radioactive wastewater discharges considered and included in your study? If not, why not? Limerick Nuclear Power Plant discharges 14.2 million gallons per day of radioactive wastewater into the Schuylkill River (over 5 billion gallons each year for decades). You can’t separate the radioactive wastewater discharged from Limerick Nuclear Plant operations from that discharged as a result of cleaning nuclear industry uniforms.

2. Is Phoenixville the nearest downstream user from Limerick Nuclear Power Plant? If not, which water intake is the first after Limerick’s radioactive wastewater discharges?

3. Mr. Feola said at no time did UniTech exceed its permitted discharge limits for radionuclides.

A. How can he be sure of that? What is the deciding factor? Show us the data.

B. Is DEP doing continuous monitoring out the discharge pipe from UniTech for all potential radionuclides associated with each nuclear plant whose uniforms are cleaned there?

C. Please provide a list of radionuclides that are permitted from UniTech, as well as the limits permitted for each.

D. You stated in the Mercury that 4 millirems is the drinking water standard of EPA. 4 millirems of what???...please specify the denominator: 4 millirems per liter of water? Per river??) Is this standard meant to include the sum total of all the different kinds of radiation associated with nuclear power plants and discharged from UniTech?

4. DEP is claiming that no radionuclides were detected above state and federal drinking water standards at Phoenixville. Please provide the data used to prove that and include all levels detected at all, not just those above state and federal standards. Please include all radionuclides tested with who did the testing and who paid for the testing. Is there continuous monitoring for all potential radionuclides by Phoenixville? If not, by DEP?

5. DEP said further study is needed. What is planned?

6. DEP said recreational contact including fish consumption poses no risk to human health. Please explain what data or method of study was used to make such a determination.

7. In the next paragraph Debra Fries said “although detected levels of radiation are not considered a threat to human health, that does not mean fish in the Schuylkill River are safe to eat based on PCBs, not radiation.”

Ø Is DEP actually making the claim that PCBs are more toxic than a toxic soup of radiation, or that the synergistic, additive, cumulative, harmful impacts of PCBs with radiation are not a factor?

8. UniTech released a 2-page statement claiming the state’s environmental enforcement agency said: “The report indicates absolutely no threat to the health and safety of human beings, animals and fish, and the environment”. Please send us the data and other documentation that was used to prove this conclusion. We believe this statement is both irresponsible and indefensible, especially in light of admitted findings reported in the Mercury, but we will review whatever data and documentation you send as proof. The Mercury reported:

A. Levels as high as 113 Pico-curies per gram in the aquatic vegetation near and downstream of the outfall. 133 Pico-curies per gram of what?

B. .24 Pico-curies per gram in the bass caught in the river near the outfall - .24 Pico-curies per gram of what?

C. Varying low levels of cobalt-60 and cesium-137 in the water.

9. The claim was made that, “We have our own biological treatment plant in the facility”.

A. Some read this to suggest that the wastewater is treated for radiation before entering the Schuylkill River.

1) What does treatment mean? Does it mean filtration or adding other chemicals?

2) Which types of radiation can be completely removed from the water with treatment referred to by this company? With Filtration?

3) Which types of radiation associated with nuclear power plants cannot be treated or filtered out prior to discharge into the Schuylkill River?

4) The company says it treats up to 70 thousand gallons per day. How much per day is discharged into the river?

5) This shows how much worse just in volume Limerick Nuclear Plant is. Exelon claims 14.2 MILLION GALLONS PER DAY (not thousands) (5 BILLION GALLONS PER YEAR) of radioactive wastewater are discharged into the Schuylkill River.

B. We understand that some types of radiation cannot be filtered at all. If true, which types?

C. If filters are used, where do they go? If they are not used and radiation can be filtered out, why aren’t they used?

10. Since PA just became an agreement state last March 2008, did DEP permit the radioactive wastewater discharge from UniTech in 2004? If so, why?

11. Do DEP inspections of UniTech include taking and testing samples of discharge for all types of radiation associated with nuclear plant uniforms washed at UniTech?

A. How often do DEP inspections take place?

B. Are inspections announced ahead of time or surprise inspections?

C. What kinds of things represent violations?

ACE is urging you to answer each and every one of the important questions and stated issues as soon as possible. We also urge you to include in your study all the harmful impacts of Limerick Nuclear Power Plant’s massive radioactive wastewater discharges. Of major importance to ACE is a comparison of all current data on water, sediment, fish, etc. to data from 1985, when Limerick Nuclear Plant started operating.

Thank You,

Dr. Lewis Cuthbert

ACE President

1 comment:

Karen said...

The following communication was also received from Donna Cuthbert.

Major Threat To Schuylkill River Ignored

It appears Exelon’s bottom line is taking precedence over Schuylkill River water quality and ecosystems. Unfortunately, agencies and water groups continue to ignore the 800 pound gorilla that threatens Schuylkill River quality and quantity, ecosystems, wildlife, people using the river for recreation and fishing, and health of 1 ¾ million people relying on the river for drinking water from Pottstown to Philadelphia.

Limerick Nuclear Plant is a MAJOR threat to the Schuylkill River, withdrawing over 20 billion gallons per year, returning only 5 billion gallons. Wastewater returned is radiated and heated. After decades, the Schuylkill River flow has been significantly reduced, concentrating Limerick’s radioactive discharges and other pollution. Since 2003, Exelon pumped over 6 billion gallons of unfiltered contaminated mine water into the Schuylkill River to supplement the flow for Limerick Nuclear Power Plant operations.

DRBC will soon hold a public hearing, followed by a decision with potential long-term devastating consequences to the Schuylkill River, related to Exelon’s request to minimize and even eliminate safeguards while adding more contaminated unfiltered mine waters to the river. Agencies continue to deny obvious harms based on data from the company with a vested interest in the outcome.

This recipe for disaster is being ignored by those who claim they want to protect the Schuylkill River. For 3 years ACE collected documentation from permits, dockets, and other official sources that identify significant cause for concern related to Limerick Nuclear Power Plant operational impacts on the Schuylkill River. We met with and presented summary packets to agency and elected officials, the public, and several water groups.

Chair Towne, heading the Schuylkill River branch of the Delaware Riverkeeper was informed of these concerns before last year’s event. So why in this critical decision year would she plan the Watershed Congress in Pottstown ignoring Limerick Nuclear Power Plant’s threats to the Schuylkill River? In 30 sessions there’s not one that addresses these serious threats or the need for Exelon to filter mine waters massively pumped into the Schuylkill River. Keynote speakers from the Natural Lands Trust and Texas are focusing on threats that we believe pale by comparison to the additive, cumulative, and synergistic radioactive and toxic metals threats to the Schuylkill River from Limerick Nuclear Power Plant’s operations. Why would area residents concerned about Limerick’s serious threats pay $50.00 to this well funded group to attend a conference that fails to address them?

Exelon’s contributions and influence could be a major factor in the failure to acknowledge reality and take meaningful action against Limerick Nuclear Plant’s overuse and poisoning of the Schuylkill River.

· NRC, DEP, and DRBC (agencies that should protect the river) are all unwilling or unable to provide full and accurate disclosure of obvious harms. Absent independent, comprehensive monitoring, testing, and reporting, no agency can accurately project future harms.

· 1/24/09 The Mercury reported that DEP is assessing nuclear waste levels in the Schuylkill River. Inexplicably, DEP appears to be ignoring Limerick Nuclear Power Plant, clearly the major source.

· 11/08 Clean Water Action spoke out in the Mercury about planting trees along the river to prevent pollution but has yet to speak out to prevent massive radioactive and heavy metal contamination of a vital water source.

· The Schuylkill Watershed Congress comes to Pottstown claiming to be making an effort to learn more about this watershed and what can be done to protect it, but long term massive radioactive and heavy metal poisoning of the Schuylkill River by Limerick Nuclear Power Plant is ignored.

History suggests Exelon will get what it wants, regardless of the outcomes, if the public does not get involved now.

Ø Are you willing to dedicate the Schuylkill River to Limerick Nuclear Power Plant operations? If not, call Donna Cuthbert at ACE (610) 326-2387.