ML073390324
| ML073390324 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/28/2007 |
| From: | Kremer A New York Affordable Reliable Electricity Alliance (NYAREA) |
| To: | Annette Vietti-Cook NRC/SECY |
| SECY RAS | |
| References | |
| 50-247-LR, 50-286-LR, RAS 14726 | |
| Download: ML073390324 (8) | |
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A November 28, 2007 DOCKETED USNRC November 29, 2007 (8:55am)
Advisory Board Arthur J. ("Jerry") Kremer Advisory Board Chairman Kenneth Adams The Business Council of New York State Richard T. Anderson New York Building Congress Patrick Curran The Energy Association-of New York State Thomas DeJesu KeySpan Energy Gavin J. Donohue Independent Power Producers of New York, Inc.
Dr. Marsha Gordon The Business Council of Westchester Anthony R. Katz Harbor Group Communications Tom Klein Boilermakers Local No.5 Jim Knubel Board Member Norris McDonald African American Environmentalist Association Ralph Ranghelli International Brotherhood of Electrical Workers, 1049 Kathryn Wylde Partnership for New York City The Honorable Annette L. Vietti-Cook OFFICE OF SECRETARY Secretary of the Commission RULEMAKINGS AND U.S. Nuclear Regulatory Commission ADJUDICATIONS STAFF Washington, D.C. 20555-0001 Docket Nos. 50-2471286-LF
Dear Secretary Vietti-Cook:
The New York Affordable Reliable Electricity Alliance (New York AREA) hereby requests approval by the U.S. Nuclear Regulatory Commission (NRC) and all appropriate agencies that we be recognized as a party to any proceeding dealing with the license renewal application of Indian Point Unit 2 (DPR-26) and/or Indian Point Unit 3 (DPR-64).
I.
After reviewing the application submitted by Entergy and after reviewing the NRC's process to review that application, we conclude that a formal hearing is not necessary to assure Public Health-and Safety. However, knowing that others may raise issues that the Licensing Board may conclude merits a formal hearing, we formally request acceptance as a party to any such proceedings.
New York AREA, located at 347 Fifth Avenue, Suite 508, New York, NY 10016, with the phone number (212) 683-1203, is a 501(c)(6) not-for-profit trade association established to conduct business in the State of New York. Our mission is to advocate for our members on energy-related issues in the State of New York.
We have a diverse membership that includes business, organized labor, community-I 4eMP Fce-.c*
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New York AREA should be a party to any proceeding concerning the Indian Point power plants for the following reasons:
- 1. Two of our members (Con Edison and the New York Power Authority) are wholesale purchasers of the output from the Indian Point units and have a vested interest in license renewal of these units.
- 2. Mr. James Knubel, 14 Angela Drive, Putnam Valley, NY 10579, is a member of our Advisory Board and lives approximately six (6) miles from the Indian Point site. Other Advisory Board and regular members of New York AREA also reside within close proximity to the site.
- 3. As parties who will be directly affected by any decision with respect to license renewal and the direct impact any Licensing Board decisions would have on our members, and the fact that our members live and do business in close proximity to the Indian Point site, we conclude that we have a right and obligation to participate in any proceedings.
Among the many business organizations from throughout the state that are in our membership, the Business Council of Westchester and the Westchester 47 Fi th e,,i uE,5it& 52
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County Association are two local groups that represent the business community in Westchester County. Together, they represent over 1,500 businesses and organizations that employ thousands of Westchester and Hudson Valley residents, many who live and work near Indian Point. Other local business organizations include the Rockland Business Association, the African-American Men of Westchester, and the Westchester Hispanic Chamber of Commerce.
Additionally, there are many labor unions who are members of our coalition whose members work at Indian Point and live in the vicinity of the plant. The Carpenters, Millwrights & Machinery Erectors, Boilermakers, and Utility Workers of America represent hundreds of families whose livelihood depends on Indian Point's continued operation.
- 4. Any decision by the Licensing Board with respect to the license renewal of the Indian Point plants will have an immediate and direct impact on our organization and its members.
A. A decision to not grant license renewal will cause two of our member organizations to lose their low cost supplier of bulk power and will require that they seek higher priced alternative suppliers.
B. As shown in an April 2004 study conducted by the Nuclear Energy Institute
("Economic Benefits of Indian Point Energy Center," attached), there will 4? !'/ifth i~n.
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'At be a severe economic impact on the community should the Indian Point units be required to shutdown.
C. An April 2002 study by National Economic Research Associates
("Electricity System Impacts of Nuclear Shutdown Alternatives") shows that without the Indian Point plants, grid reliability will suffer and the likelihood of blackouts will increase by 700 percent.
D. The National Academy of Sciences (NAS) published a report in 2006 which concluded that even with both of the Indian Point units operating that there would be a severe shortfall of electric supply for the lower Hudson Valley region of New York.
NAS also concluded that it would be POSSIBLE (emphasis added) to meet the region's electrical supply needs without the Indian Point plants. The report went on to state that this could only be accomplished if eight actions/steps were taken and all eight steps would have to occur for even the possibility to exist. To date not one single action deemed necessary by the NAS to replace Indian Point's energy has occurred.
E. The southeast portion of New York State is a "non-attainment" region from an air quality standpoint. Any alternative to License Renewal for the Indian Point units would adversely affect air quality in the region.
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F. From the perspective of Environmental Justice, any decision that denies License Renewal or reduces total plant output will have a disproportionately adverse impact on lower income and minority communities. This will take the form of higher electric bills and increased air pollution.
This is of particular interest to a number of our member organizations, including the African American Chamber of Commerce of Westchester, the African American Men of Westchester, and the African American Environmentalist Association.
Finally, the Indian Point nuclear power plants have operated with an excellent safety record. The NRC's Reactor Oversite Process (ROP) has shown that the units are operated in a fashion that meets NRC requirements and ensures the "Health and Safety" of the public.
The current regulatory procedural template used by the NRC for License Renewal is a good one. There are those who have demanded that the process be changed.
We whole-heartedly disagree. New York AREA and its members feel strongly that the process used by the NRC on more than 48 plants nationwide is proven, technically sound and will result in a fair review of the plants.
In summary, we, New York AREA, support the License Renewal for Indian Point Units 2 & 3. We support the current methodology used by the NRC for License 34 F7if t h A ve u *
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Renewal. We do not believe a formal hearing is necessary nor would it add any value to the process. If, however, the Licensing Board concludes that a hearing is required, as an organization with a vested interest in Indian Point we hereby request that we be granted full-party status as an interested party in any and all proceedings.
We appreciate your consideration in this important matter.
S* ce ely, Arth r" rry" Kremer Chairman New York AREA 347 5h Avenue, Suite 508 New York, NY 10016 kremer@ area-alliance.org 347 ift Ah e u.
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CERTIFICATE OF SERVICE I hereby certify that on November 28, 2007 copies of the foregoing Petition to Intervene from New York Affordable Reliable Electricity Alliance (New York AREA) have been served upon the following persons by first class mail and email as shown below:
Office of the Secretary (original and two copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Rulemakings and Adjudications Staff (E-mail: hearingdocket@ nrc.gov)
Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: ocaamail @nrc.gov)
Administrative Judge Richard E. Wardell Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: rew@nrc.gov)
Administrative Judge Lawrence G. McDade, Chair Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: lgml @nrc.gov)
Sherwood Martinelli Friends United for Sustainable Energy USA, Inc.
351 Dykman Street Peekskill, NY 10566 (E-mail: roycepenstinger@ aol.com)
Michael J. Delaney, Vice President - Energy New York City Economic Development Corporation 110 William Street New York, NY 10038 (E-mail: mdelaney@nycedc.com)
Administrative Judge Kaye D. Lathrop Atomic Safety and Licensing Board Panel Mail Stop -T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: kdl2@nrc.gov)
Sherwin E. Turk, Esq.
Lloyd B. Subin, Esq.
Beth N. Mizuno, Esq.
Office of the General Counsel Mail Stop 15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: set@nrc.gov)
(E-mail: lbs3 @nrc.gov)
(E-mail: bnml @nrc.gov)
Martin J. O'Neill, Esq.
Kathryn M. Sutton, Esq.
Paul Bessette, Esq.
Mauri T. Lemoncelli, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 (E-mail: ksutton@morganlewis.com E-mail: pbessette@morganlewis.com E-mail: martin.o.neill @ morganlewis.com)
Susan Shapiro, Esq.
21 Perlman Drive Spring Valley, NY 10077 (E-mail: Palisadesart@aol.com mbs@ourrocklandoffice.com)
Zachary S. Khan, Law Clerk Atomic Safety and Licensing Board Mail Stop: T-3 F23U.S.
Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: zxkl@nrc.gov)
-/Arthur "Jeo 6mer Chairman, New York AREA 347 Fifth Avenue, Suite 508 New York, NY 10016 (212) 683-1203 kremer@ area-alliance.org