ML20067C491
| ML20067C491 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/01/1991 |
| From: | Todorovich M SCIENTISTS & ENGINEERS FOR SECURE ENERGY |
| To: | |
| Shared Package | |
| ML20067C304 | List: |
| References | |
| 91-621-01-OLA, 91-621-1-OLA, OLA, NUDOCS 9102120086 | |
| Download: ML20067C491 (7) | |
Text
C i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Morton B. Margulies, Chairman Dr. George A.
Ferguson Dr. Jerry R.
Kline
)
In the Matter of
)
)
Docket No. 50-322-OLA Long Island Lighting Co.,
)
Shoreham Nuclear Power Station;
)
ASLBP No.
Confirmatory Order Modifying
)
91-621-01-OLA License (Effective Immediately)
)
(55 Fed. Reg. 12758, April 5, 1990)
)
AFFIDAVIT OF ORGANIZATIONAL INTEREST BY MIRO M. TODOROVICH, EXECUTIVE DIRECTOR OF SCIENTISTS AND ENGINEERS FOR SECURE ENERGY, INC.
Miro M.
Todorovich, being duly sworn, says as follows:
1.
I, Miro M. Todorovich, am the Executive Director of Scientists and Engineers for Secure Energy, Inc. ("SE ")*
I 2
reside at Ravina Road, Rt.
1, Box 321, Patterson, New York 12563.
I was a founding member of SE in 1976 and have been the duly 2
elected Executive DirecL0r since thet time.
As Executive e
Director, I: collect data and information about events of interest to SE 's members; receive and summarize members' views 2
on matters of commen concern covered by the charter and bylaws of the organization; help formulate positions reflecting the knowledge, views and sentiments of SE raembers; engage the 2
organization in educational, informational, litigation or other activities implementing the wishes of the membership and SE 's 2
91021200B6 910204 I
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Board of Directora for actions in the public interest.
In this instance, I have been directed to seek intervenor status for SE, in tho various segmented NRC proceedings related to the decommissioning.of the Shoreham Nuclear Power Station
("Shoreham") so that SE oan fulfill some of its authorized 2
purposon by representing its organizational interests and the health, safety and environnontal interests of its members in those proceedings as authorized by those members.
2.
SE, is a not-for-profit organization formed under the laws of the State of New York and qualified under IRC 4 S01(c)(3).
The organization's membership includes over 1200 scientints and engineers.
SE alse receives additional support 2
from layperson sponsors who support to organization's mission.
3.
SE, is a group of professionals, all experts in their choscn fields, who are doc-sted, among other things, to the correction of the alarming degree of misunderstanding that permeates national energy debate.
Through public forum s, interaction with government leaders, internal communication about technical issues and active liaison with the nation's journalists, SE seeks to show that a majority of respor.sible 2
scientists support the value of technical innovation in all fields and, particularly, in energy. ----------------.
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The-use of electricity continuou grow.- Non-renewable fossil-fuels face-inevitable depletion-and their combustion contributes to acid rain,-the greenhouse effect, apparent changes
- in our weather pattern,-and air pollution-generally.
Thus, SE2 supports the utilization of atmospherically clean and domestically necure nuclear power to safely meet our electric energy needs.
5.
'In-the-Northeastern part of the United States, the increasing demand for electricity has been thus far met by increased reliance on imported oil and hydro and nuclear electricity imported'from canada.
The adjacent Canadian provinces have responded to the American appetito for electrical power by-planning construction of ten more nuclear power plants in Ontario and at:least two others in Quebec..
If Shoreham is not put-on line, the canadians will be able~to further increase the U.S.
foreign trade imbalance.
This increase is likely to be particularly dramatic because the-cost of canadian electricity export is tied to the avwrage cost of American oil-produced electricity and that cos t Js expected to continue to rise.
In short then, while our neighbors to the north are expanding their nuclear power production, we in the' power-thirsty Northeast are-
~
not only bent on diamantling a perfectly operablo, state-of-the-
-a rt, nuclear power installation but also contemplate, according to the current New York State agreement, replacing it by a combination of new U.S.
fossil-fuel plants and-purchases from 3_
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Canada.
This plan will foul our atmosphere, increase the average cost of electricity, and provide the canadian economy with a windfall profit.
In the view of SE members, this course of 2
action with the Shoreham plant makes neither health, safety, environmental nor economic sense.
6.
Since its inception, SE has participated extensively 2
in the debate of issuos in the nuclear industry.
Besidos having been invited to advise administrators, logislators and agency and commission officials throughout the country on such isuues as the Three Milo Island cleanup, nuclear insurance programs, reprocessing of spent fuels, vaste disposal, materials transportation, the breeder reactor. program, nuclear licensing has delays and regulatory reform of the licencing process, SEz previously participated in stages of nuclear power plant licensing proceedings in favor of the utilization of nuclear
.powerffor the safe and economical production of electrLeity.
has been a participant in the ongoing-dobate In particular, SE2 on various issues in connection with Shoreham and has continually favored utilization of the facility.
7.
Givon the organisational interests described above, SE2
-is naturally-intorested in and concerned about the present proposal to decommission the recently liconnod, brand now, state-of-the-art Shoreham. _____
8.
SE is concernod that the decommissioning of Shoreham 2
is presently underway despite the lack of prior safety or onvironmental review evaluating the safety or environmental impacts of, and alternatives to, the decommissioning proposal as required by the National Environmental policy Act ("NEPA").
SE2 has a right to comment upon an environmental impact statement
("EIS") to be prepared on the decommissioning proposal before that proposal is implemented or before steps are taken which tand to limit the choice of alternativos to that proposal.
The actions taken by Shorch-2 s licensee, the Long Island Lighting Company ("LILCO"), and permitted by the Nuclear Regulatory Commission ("KRC"), to date have already begun to sericusly prejudice consideration of the alternative of operating Shoreham.
The most recent actions in the cteadily lengthening chain of actions in furtherance of, or premised upon, decommissioning, include the NRC's issuance an immediately effective confirmatory Order and proposed license amendments allowing LILCO te reduce its commitments to physical security and.to cease its cffsite emergency preparedness activitics.
Both the NRC and LILCO are content to ignore the mandate of NEPA and thereby deny SE its 2
right to participate in the decisionmaking process.
Ov er submitted a request for NRC action seventeen months ago, SE2 under the provisions of Section 2.206 of the NRC regulations.
SE is left with no alternative but to pursue its organizational 2
interests through administrative hearings offered on the segmented decommissioning actions. --
9.
SEg also has an organizational interest in eliciting information on the decommissioning of Shoreham for the benefit of its members who live and/or work near the plant so that they can carry out SE 's mission on a local lovel by informing the local 2
governanntal leadorn and the other interested individuals and groups in the Shoroham area of the environmental implications of the proposal to decommission Shorcham.
10.
And if the scopo of this proceeding is narrewed to its relationship to the choice among the alternatives for decommissioning modo, I believe the health, safety and environmental interests of the SE members wo are authorized to 2
represent would be harmed by any actions inconsistent with monthballing the plant ("SAFSTOR").
11.
SE has joined the Shoreham-Wading River Contral School 2
District (" School District") in socking to intervene in hearings to be held on the Confirmatory Order and the license amendment requests affecting both Physical Security and offsite Emergency Preparodness.
The issues raised by all of thono actions significantly overlap due to the fact that they all are either in furtheranco of the decommissioning proposal or dopond on that proposal for their justification.
SE favors the concolidation 2
of those three proceedings as the most of ficient and expeditious way to consider the issuen raised by the School Distri:t and SE.
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SE, also. submits that such consolidation is demanded by NEPA becuase all of these segmented proposals and actions are, in fact, part of a single proposal, are cumulatively significant, and havm no utility independent of the decommissioning proposal.
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Miro M. Todorovich
/
Executive Director J'
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i SUBSCRIBED AND SWORN BEFORE ME, on this -
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c 1991.
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y, 6As?:+1 O Qi,.;w.m / l Notary Public My commission expires:
TRANCIS DENNETT Notary Putinc, state of New York No. 314347001 Quahtsed in Queens County Commission Errires Aug 30,1991 1
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