ML20073A530
| ML20073A530 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/05/1991 |
| From: | Todorovich M SCIENTISTS & ENGINEERS FOR SECURE ENERGY |
| To: | |
| Shared Package | |
| ML20073A495 | List: |
| References | |
| OLA-2, NUDOCS 9104230247 | |
| Download: ML20073A530 (7) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges Morton B. Margulies, Chairman Dr. Guerge A. Ferguson Dr. Jerry R. Kline
)
In the Matter of
)
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Docket No. 50-322-OLA-2 14HG ISLAND LIGHTING COMPANY
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Shoreham Huclear Power
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(Possession only License)
Station, Unit 1)
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ATTIDAVIT OT ORGANIZATIONAL INTEREST BY MIRO M. TODOR0VICH, EXECUTIVE DIRECTOR OF SCIENTISTS AND ENGINEERS FOR SECURE ENERGY, INC.
Miro M. Todorovich, being duly sworn, says as follows:
1.
I, Hiro 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 elected Executive Director since that time.
As Executive
-Director, It collect data and information about events of interest to SE 's members; receive and summarize -members' views 2
on matters of common concern covered by the charter and bylaws of the organization; help formulate positions reflecting the knowledge, views and sentiments of SE, members; engage the organization in educational, informational, litigation or other activities implementing the wishes of the membership and SE 's 2
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Board of Directors for actions in th3 public interost.
In this J
l instance, I have been directed to seek intervenor status for SE, in the various segmented HRC proceedings related to the 1
decommissioning of the Shoreham Nuclear power Station
("Shoreham") so that SE, can fulfill some of its authorized i
purposes by representing its organizational interests and the i
health, safety and environmental interests of its members in those proceedings as authorized by those members.
1 l~
2.
SE is a not-for-profit organization formed under the 2
laws of the State of New York and qualified under IRC $
7 501(c)(3).
The organization's membership includes over 1200 F
scientists and engineers.
SE2 also receives additional support from layperson sponsors who support to organization's mission.
3.
SE, is a group of professionals, all experts in their
[
j chosen fields, who are dedicated, among other things, to the correction of the alarming degree of misunderstanding that
).
permeates national energy debate.
Through public forums, interaction with government lead 6rs, internal communication about technical issues and active liaison with the nation's journalists, SE, seeks to show that a majority of responsible scientists support the value of technical innovation in all fields and, particularly, in energy.
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The use of electricity continues grow.
Non-renewable fossil-fuels face inevitable depletion and their combustion contributes to acid rain, the greenhouse effect, apparent changes in our vaather pattern, and air pollution generally.
Thus, SE, supports the utilization of atmospherically clean and domestically secure nuclear power to safely meet our electric energy needs, i
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
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provinces have responded to the American appetite 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 I
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 average cost of American oil-produced electricity and that cost is expected to continue to rise.
In short, while our neighbors to the north are expanding their nuclear power production, we in the power-thirsty Northeast are not only bent on dismantling a perfectly operable, state-of-the-art, 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 -,-..-:. -...
Canada.- This plan will foul our atmosphero, incromos the overage cost of electricity, and provide the Canadian economy with a members, this course of windfall profit.
In the view of SE2 actier, with the Shoreham plant makes neither health, safety, environmental nor economic sense.
i has participated extensively 6.
Since its inception, SE2 in the debate of issues in the nuclear industry.
Besides having been invited to advise administrators, legislators and agency and commission officibls throughout the country on such issues ast the Three-Mile Island cleanup, nuclear insurance programs, reprocessing of spent fuels, waste disposal, materials transportation,-the breeder reactor program, nuclear licensing has-delays and regulatory reform of the licensing process, SE2 previously participated in stages of nuclear power plant licensing proceedings-in favor of the utilization of nuclear power for the safe and economical production of electricity.
has been a participant in the ongoing debate In particular, SE2 in connection with'Shoreham and has cantinually favored utilization of the facility.
Given the organizational interests described above, SE2 7.
is naturally interested in and concerned about the present proposal to decommissieu the recently licensed, brand new, state-of-the-art Shoreham..
8.
SE is concerned that the decommissioning of Shoreham 2
is presently underway despite the lack of prior safety or environmental review cvaluating the safety or environmental impacts of, and alternatives to, the decommissioning proposal as required by the National Environmental policy Act ("NEFA").
SE 2 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 tend to limit the choice of alterr.atives to that proposal.
The actions taken by Shoreham's licensee, the Long Island Lighting Company ("LILC0"), and permitted by the Nuclear Regulatory Commie. ion ("NRC"), to date have already begun to seriously prejudice consideration of the alternative of operating Shoreham.
The most recent actions in the steadily lengthening chain of actions in furtherance of, or premised upon, decommissioning, include the proposed license amendment to convert LILCo's license to a possession only license.
Both the NRC and LILCO are content its right to to ignore the mandate of NEPA and thereby deny SE2 participate in the decisionmaking process.
Over twenty months submitted a request for NRC action under the provisions ago, SE2 of Section 2.206 of the NRC regulations which has been denied.
SE is left with no alternative but to pursue its organizational 2
interests through administrative hearings offered on the segmented decommissioning actions. l
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9.
SE clso has on organizational intorost in oliciting 2
information on the decommissioning (including any possession only license amendment) of Shoreham for the benefit of its members who live and/or work near the plant so that they can carry out CE
'8 2
mission on a local level by informing the local governmental leaders and the other interested individuals and groups in the Shoreham area of the environmental implications of the proposal to decommission Shoreham.
10.
And if the scope of this proceeding is narrowed to its relationship to the choice among the alternatives for decommissioning mode, I believe the health, safety and environmental interests of the SE members we are authorized to 2
represent would be harmed by any actions inconsistent with monthballing the plant ("SAFSTOR").
11.
SE has joined the Shorehnm-Wading River Central School 2
District (" School District") in seeking to intervene in hearings to be held on a number of license amendments and other actions affecting Shoreham.
The issues raised by all of these actions significantly overlap due to the fact that they all are either in furtherance of the decommissioning proposal or depend on that proposal for their justification.
SEg_ favors the consolidation of these three proceedings as the most efficient and expeditious way to consider the issues raised by the School District and SE' 2
1 S F.2 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 have no utility independent of the decommissioning proposal.
JN E /Aw Miro M. Todorovich
/
Executive Director
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SUBSCRIBED AND SWORN BEFORE ME, on thi 1991.
. M& d kw Notary Public
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