ML20067C588
| ML20067C588 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/01/1991 |
| From: | Scrandis J SCIENTISTS & ENGINEERS FOR SECURE ENERGY |
| To: | |
| Shared Package | |
| ML20067C304 | List: |
| References | |
| 91-621-01-OLA, 91-621-1-OLA, OLA, NUDOCS 9102120125 | |
| Download: ML20067C588 (8) | |
Text
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'I UNITED STATES OF AKERICA l
NUCLT.AR REGULATORY COMMISSICH ATOMIC SATETY AND LICENSING BOARD G
Before Administrative Judge:
Morton B. Margulies, Chairman Dr. George A. Te m son Dr. Jerry R. Kline J
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In the datter of
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Docket No. 50-322-OLA Long Island Lighting Co.,
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Shoreham Nuclear Power Statient
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ASLBP No.
Confirmatory Order Modifying
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91-621-01-OLA Licenso (Effective Immediately)
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(55 Ted. Reg. 12758, April 5, 1990)
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f ATTIDAVIT OF JOSEPH SCRANDIS Joseph scrandis, being duly sworn, says an follows:
I 1.
I, Joseph Scrandis, have owned my present residence at 10 Walnut Street, Westbury, New York 11590 for twenty-tvo years, located some 43 miles from the Shoreham Nuclear Power Station
("Shoreham Plant").
Thus, I live within the fifty milt geographical tone utilized by the U.S. Nuclear Regulatory Commission ("NRC") to determine whether a party is sufficiently threatened by the radiological hazard and other environniental impacts of the proposal to establish the requisite inter est and standing for intervention as of right.
2.
I have been employed for the past five years at Aikido Computer Systems, Ltd., 150 Broad Hollow Road, Melville, New York 11747, located thirty milen from Shorcham.
My job tition are 9102120125 910204 PDR ADOCK 05000322 o
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Director of Maintenance and Installations, and Computer Systems Engineer.
I am responsible for developing new computer systans, the dution of a Chief Mechanical Engineer and Senior Electrical Engineer, and maintaining several computer systems for public service agencies.
I hold degrees in Electrical Engineering and Physics, and have been an active proponent of science and technology for 30 years via personal ef forts and debate, letters to the editor, and organizational affiliations.
I am familiar with both the benefits and risks of nuclear power plants and strongly support the use of nuclear power to meet our nation's energy needs in a safe, economical, and environmentally benign manner.
3.
I have been a member of Scientists and Engineers for
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Secure Energy, Inc. ("SE ") since before 1980.
I authorito SE g
2 f
to represent my interests, as described horcin, in any proceedings to be held in connection with the Immediately Effective Confirmatory Order, issued by the NRC on March 29, i
1990, prohibiting the Long Island Lighting Company ("LILCoa),
licensee of the Shoreham plant from placing fuel into the reactor vessel without prior NRC approval.
4.
I am concerned that the confirmatory order constitutes another step in the decommissioning process presently underway at Shoreham in violation of my rights under the National-Environmental Policy Act ("NEPA").
The order reaffirms the i
previous NRC decisions allowing LILCO to reduce staffing and maintenance to a level clearly inconsistent with thi terms of the i
full power operating license and several NRC regulations.
These very actions which the RRC explicitly allowed are now being advanced as presenting a health and safety threat of such a magnitude that an immediately effective order was issued to effnetively prohibit operation.
SE, submitted a section 2.206 request in conjunction with the Shoraham-Wading River Central school District in July of 1989 when the destaffing and plant disansembly activities had only just been announced and were yet to be implemented.
The Request asserted that these actions should not be allowed to go forward before publication et a Final Environmental Impact Statement ("FEIS") pursuant to the dictates of NEPA and because they woro inimical to the public health and safoty due to their inconsistency with LILCO's license obligations as a full-power licensoo.
Despito the fact that the conminnion denied the request for immediate relief and continuos to ignore the issues raised in the original section 2.206 request and the supplements thereto, it now relies on the results of the challenged actions to justify issuance of the immediately effootiv.9 Drder without ordering remedial measures or proposing fines.
5.
I do not believe that any steps in furtherance of the Shoreham Plant's decommissioning should be implemented until a L
FEIS evaluating the impacts of, and alternativos to, the entire
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decommissioning proposal has been completed in compliance with the terms of NEPA and the NRc8s own regulations in a single proceeding.
If the NRC allows steps which are clearly in furtherance of decommissioning, and have no necessary independent t
utility, to be implemented at the Shoreham Plant prior to the 1
necessary NEPA review, my rights, and the rights of those j
similarly situated, to have an opportunity for meaningful comment on the environmental consideration of the decommissioning proposal will be prejudiced, if not completely denied.
Besides reaffirming past actions aimed at ramoving the shoreham Plant from service and, therefore, in furtherance of decommissioning, the confirmatory Order also sets the stage for yet other actions in furtherance of decommissioning.
LILc0 has applied for a licenso amendment to recognize the defueled state of the plant which will in turn facilitate the transfer of the plant to the Long Island Power Authority.
The confirmatory ordar, which
- prohibits operation of the plant, is a first link in a chain of actions directed towards the issuance of a license amendment authorizing apossession and use, but not operation."
The-issuance of a possession only license would be, 2n turn,-a further step in removing the plant from service which in the first part of " decommissioning" es defined by the NRC regulations.
4 6.
The confirmatory order also represents a thretit to my personal radiological. health and safety and to my real end 4
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perconal property in violation of my rights under the Atomic Tnergy Act of 1954, as amended.
In direct violation of its own stated enforcement policy, the NRC has failed, in that Crder, to w
require LILCO to undertake remedial actions to bring the Shoreham Plant into compliance with the terms of its full-power operating license.
Thus, should a determination later be made to operate the shoreham Plant, deterioration allowed by LILCO and by that incomplete order will at the least move operation further away in time, and at the-sorst, increase the likelihcod and risk of a radiological accident.
7.
As a Long Island resident, I am also interested in actions which will have a direct effect on the availability of reliable, inexpensive, and environmentally benign electric generation to meet my noods and those of my family and the community as a whole.
As for reliability, it has been my observation that the quality of electricity supply has seriously degraded on Long Island over the last five years.
The office in I
which I work has recently suffered several brovnouts and outages during times of peak electricity usage.
Perviously these occurrences were quite rare, occuring at a rate of an incident every few years.
Although this problem is endemic to the section of Long Island where I live and work, it is not limited to it.
Being responsible for numerous computer systems in the New York city area.has made me aware that the whole region in dangerously close to being caught without sufficient electrical power 1
reserves.
As a computer engineer, I can testify that these power outages, brovnouts and sags can vreak havoc with the continuous and proper operation of computer systems. They have danaged and interrupted computers and can leave them in a chaotic ctate requiring (brute force) power resets which may result in a loss of data or a more serious loss of control.
These conditions are damaging to the economic well being of the people of Long Island und would be greatly alleviated by the operation of the Shorehas plant.
As for the consequences of Shoreham's decommissioning on the physical environment, I understand that Long Island is presently at the full capacity of the existing naturni gas pipelines which supply this area and that there is inaloquate reserve capacity for the growing electric energy deman1 of the area.
Thus, either the Shoreham plant must be operated or alternative generating fac111tien vill have to be built and operated.
Because natural gas supplies cannot easily be increased, oil-burning plants will inevitably be noodcit to replace the shoraham Plant thereby increasing our reliance on foreign oil and thus reducing the security of our energy supply, among other things.
Thane plants, in turn, will emit pollution lowering air quality in the region and contributing to global warming and acid rain.
These effects of the Shoreham Plant's 1
decommissioning will have detrimental effects on my health and on the quality of the natural environment in which I live day-to-day.
Finally, as for the economic implications of Sherehan's decommissioning, by acceding to the would-be dismantlers of the.
I shoreham plant, the NRC is wreaking havoo upon the economic well-l being of Long Island and, in turn, upon myself.
The huge debt a
1 incurred in the construction of Shoreham will fall upon the residents and consumers of electricity on Long Island.
Just as we are involved in the burden of servicing the debt, so will we
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have to pay it off, and suffer the indignity of not being able to reap any of the benefits of its use through the generation of much noodod electricity.
Further, besides suffering thu consequences of electricity shortage that Shoreham's non-use shall create, we residents will have to further pay for the construction of now power plants to replace shoreham's cloctricity.
This will throttic normal growth and expansion, and will make any normal overy-day operations involving electricity sporadic and problematic.
The value of my home and those of my neighbors will plummet.
My property on Long Island will be likened to that of many third world countriest 1111guid. devalued and very difficult to soll, radically different from the rest of the United States.
All of those negative effects of the decommissioning proposal emphasize the need for serious consideration of the alternatives to decommissioning.
8.
And if the scope of this proceeding is narrowed to its relationship to the choice among the alternatives fo.r cecommissioning modes, I believe my health, safety and environmental interests would be harmed by_any actions inconsistent with mothballing the plant ("SAFSTOR")..
JM4 31 'SI 15 15 FROM D.L.fi.
(JA$HlNGTON DO PAGE.039 l
9.
I understand that SE han boon joite d by tl e Shoreham-2 Wading niver central School District (" School Districta) in i
coeXing to intervono in a hearing to bo held not only on the
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l confirmatory order, but also in hearitsgs to conoidor the
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implications of LILco's license amendment requoste affecting both Physical Security and Offsite Emorgoncy Prepnrednoas.
I also understnnd that the issues raised by all of these actions significantly o'rerlap due to the fact that each of the attions constitute another stop in the deconmissioning process underway at the Shoreham P.lant.
I would incor the consolidation of these l
three prorceedings to consider tho innuon raised by the School District tand SE.
Consolidation would be the mout officiant and g
expeditious way to proceed for all concerned.
I niso submit that such consolidation is demanded by NEPA Pccause eli of these seguented proposals and actions arc, in. fact, part of a ningle proposal, are cumulatively significant, and have no uti.11ty independent of the decomminnioning proposal, h((h C/tGwb Josph st:randia SUBSCRIDED AND SWORN DEFORE 1G, on this d dayoffrOkeM N'i,I 1991.
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u ~m Not'try Public
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My Commiesion ekp.\\rcr.: d',
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RANCHE J. PAUSP/CM PM Strie of fun York
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