ML20059L675
| ML20059L675 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/18/1990 |
| From: | Watkins J ENERGY, DEPT. OF |
| To: | Carr K NRC COMMISSION (OCM) |
| References | |
| CON-#490-10851 NUDOCS 9009270253 | |
| Download: ML20059L675 (4) | |
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d The Secretary of Energy Washington, DC 20585 p
September 18, 1990 i
sb 32%
Admiral Kenneth M.
Carr
' Chairman,-Nuclear Regulatory Commission Washington, D.C.
20555 1
Dear Admiral Carr:
The ongoing events in the Middle East have underscored the importance of minimizing our nation's reliance on unreliable foreign sources of crude oil.
These events have heightened my concern _about the folly of-the plan concocted by New York State to dismantle the Shoreham nuclear plant, which
-received ~a full' power operating license from the Commission and has beeneready to operate since April, 1989.
Were the Shoreham plant now in operation, the Long Island Lighting i
Cornany-(LILCO) would be capable of saving between seven and H
eight million barrels of crude oil annually.
This savings would make an important contribution toward maintaining and ensuring the energy security of the United States.
- Further, the operation'of Shoreham as a nuclear unit would contribute.
significantly to the amelioration of the present energy
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situation in New York State, whose utilities in 1989 consumed 26% of all of-the oil used for the generation of electricity in the. United States.
It is with these considerations in mind that I would be particularly concerned were the NRC to_ grant.LILCO's recent application =for_a " possession-only" license amendment.
I am concerned that the issuance of such a license amendment
- would permit large: portions of the Shoreham facility to b'e effectively dismantled and rendered inoperable without any-i prior NRC approval, long before the NRC formally considers the request for an amendment to decommission the plant.
Thus, the_ approval of a " possession-only" license for LILCO by'the Commission could render the later transfer of the license to the Long Island Power. Authority (LIPA) and formal application to decommission the facility a mere formality because, for all practical purposes,.the facility would already have been decommissioned and rendered unusable as a nuclear generating station.
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While-it would obviously not be the Commission's intention,-
issuance of a "poswession-only" license may lead to the near-term destruction'of this important energy resource.
Particularly while the potentially volatile situation in the r
Middle East ~ remains unresolved, such a. result would be counterproductive to our nation's-efforts to oeal with that-situation in: the short term and to develop a sens.ible national energy strategy which decreases our dependence on imported oil in the long term.
As you may recall, Deputy Secretary Moore and I have both
-f corresponded with you previously to request that, before i
approving ~any action which would result in the destruction of the Shoreham facility, the Commission prepare an Environmental Impact' Statement (EIS).
The EIS should assess both the impacte nf dismantling the facility, includ1ng.the inevitable use of more polluting fuel cources to replace
_Shoreham's power, and the alternatives to such dismantlement,' including the alternative of near-term operation.
We requested the preparation of an EIS because it appeared to us that the actions of LILCO, even prior to
'y our original correspondence, were tantLmount to the beginning of piecemeal decommissioning of the facility._ In your September 15, 1989, response to me, you assured us that the Commission would not allow any action that would-constitute piecemeal decommissioning of the Shoreham plant or segmentation of the' environmental review. process for decommissioning, pending the submittal and approval by the NRC of a formal decommissioning plan for the facility.
On that ground, you essentially took the positian'that our request for preparation of an EIS was premecure.
There is little doubt at this time that the downgrading-of-LILCO's full power operating license to a " possession-only" license would effectively' result in the destruction of the
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Shoreham facility as aLpotential nuclear generating station long before the NRC formally considers'a decommissioning a
amendment.
Indeed, we-understand 1that certain-instrumentation and components have already been removed from the reactor vessel itself.
Thus, it can no longer be-t argued thLt it is premature to consider the Department's request that an EIS be prepared to consider all environmental impacts of, and alternatives to, the destruction of Shoreham, while there are still alternatives to consider.
i Therefore,,y urgently renew my request for preparation of an EIS regardirg decommissioning of Shoreham.
I-ask that the=
NRC complete this review prior to taking uny action on the issuance of a " possession-only" license.
I am concerned that'to do ctherwise would permit the segmentation of the environmental review process which the Commission has 2
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.previously-assured =us<it would avoid, because issuance of a-
^ possession-only" license would allow LILCO:to.make the destruction of the' facility a fait accompli..
With the electricity supply-picture in the Northeast worsening as tims goes on, and events in'the Middle East casting further doubt on that picture,for=the future, all feasible alternatives to-the destruction of a viable facility such as
-Shoreham should:be examined before any_ Federal decision is made which'results in squandering a resource that reduces.
our-dependence on foreign crude oil.
In voting on a Staff recommendation in the Commission paper designated _as,SECY-89-247, the Commission approved a-course of action which included a provision that, "[p]ending NRC approval _of-decommissioning, the staff will require all' systems needed.for safety in the defueled mode be i
maintained, and that all systems required for full power operation are to be preserved from degradation."
(Emphasis supplied).
At a minimum, I trust that the Commission _will enforce that condition.-
In any event, at least while the current situation in the Middle East _ remains unresolved, and while I am thus in the process of examining what measures are appropriate and feasible to maintain and enhance the nation's energy security, I hereby request that the NRC take no further regulatory action regarding Shoreham which would be inconsistent with the potential'near-term operationlof the facility as a nuclear unit.
i Sincerely, l
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s Y atkins i
d..ral, U.S. Navy (Retired)
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Commissioner:Kenneth
. Rogers Commissioner James R. Curtiss i
Commissioner Forrest,J. Remick j
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