ML20073A551
| ML20073A551 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/05/1991 |
| From: | Scrandis J AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20073A495 | List: |
| References | |
| OLA-2, NUDOCS 9104230254 | |
| Download: ML20073A551 (6) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judge:
Morton B. Margulies, Chairman Dr. George A. Ferguson Dr. Jerry R. Kline
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In the Matter of
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Docket No. 50-322-OLA-2 LONG ISLAND LIGHTING COMPANY
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Shoreham Nuclear Power
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(Possession Only License)
Station, Unit 1)
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AFFIDAVIT OF JOSEPH SCRANDIS Joseph Scrandis, being duly sworn, says as follows:
1.
I, Joseph Scrandis, have owned my present residence at 10 Walnut Street, Westbury, New York 11590 for twenty-two years, located some 43 miles from the Shoreham Nuclear Power Station
("Shoreham Plant").
Thus, I live within the fifty mile geographical zone utilized by the U.S. Nuclear Regulatory Commission ("NRC") to determine whether a party is sufficiently threatened by the radiological hazard and other environmental impacts of the proposal to establish the requisite interest 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 miles from Shoreham.
My job titles are 9104230254 910408 ADOCK05000g22 DR h
Director of Maintenance and Installations, and computer Systems Engineer.
I an responsible for developing new computer systems, the duties 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 efforts 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 nanner.
3.
I have been a member of Scientists and Engineers for Secure Energy, Inc. ( S E " ) since before 1980.
I authorize SE 2
2 to represent my interests, as described herein, in any proceedings to be held in connection with the Long Island Lighting Company ("LILCO") application for a possession only license amendment ("the amendment") for the Shoreham Plant.
4.
I am concerned that the amendment would constitute another step in the decommissioning process presently underway at Shoreham in violation of my rights under the National Environmental Policy Act ("NEPA").
The amendment would reaffirm and further the previous NRC decisions allowing LILCO to reduce staffing and maintenance to a level clearly inconsistent with the !
l tcrms of tho full powar op3 rating liconso and NRC rogulations.
I SE submitted a Section 2.206 request in conjunction with the 2
Shoreham-Wading River Central School District in July of 1989 when the destaffing and plant disassembly activities had only just been announced and were yet to be implemented.
Tha Request asserted that these actions should not be allowed to go forward before publication of a Final Environmental Impact Statement
("FEIS") pursuant to the dictates of NEPA and because they were inimical to the public health and safety due to their inconsistency with LILCo's license obligations as a full-power licensee.
I separately reaffirm that principle with respect to the amendment.
5.
I do not believe that any steps in furtherance of the Shoreham Plant's decommissioning should be implemented until a FEIS evaluating, among other things, the direct and indirect impacts of, and alternatives to, the entire decommissioning proposal has been completed in compliance with the terms of HEPA and the NRC's own regulations in a single proceeding.
If the NRC allows steps which are clearly in furtherance of decommissioning, and have no necessary independent utility, to be implemented at the Shoreham Plant prior to the necessary NEPA revjew, my rights and the rights of those 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 removing the d
4 Shorcham plant from corvico end, therefore, in furtherance of decommissioning, the amendment also sets the stage for yet other actions in furtherance of decommissioning.
LILCO has applied for a license amendment to transfer the plant to the Long Island Power Authority.
The amendment is a further link in a chain of actions directed towards decommissioning.
The issuance of a possession only license would be a further step in removing the plant from service which is part of " decommissioning" as defined by the NRC regulations.
6.
The amendment also represents a threat to my personal radiological health and safety and to my real and personal property in violation of my rights under the Atomic Energy Act of 1954, as amended, since neither the financial responsibility nor safety planning requirements of the regulations have been approved although they are prerequisites for the amendment.
7.
As a Long Island resident, I am also interested in actions which will have a direct effect on the availability of reliable and environmentally benign electric generation to meet my needs and those of my family and the community as a whole.
I understand that Long Island is presently at the full capacity of the existing natural gas pipelines which supply this area and that there is inadequate reserve capacity for the growing electric energy demand of the area.
Thus, either the Shoreham Plant must be operated or alternative generating facilities will l l
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have to be built and operated.
Because natural gas supplies cannot easily be increased, oil-burning plants will inevitably be needed to replace the Shoreham Plant thereby increasing our reliance on foreign oil and thus reducing the security of our energy supply, among other things.
These 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 decommissioning will have detrimental effects on my health and on the quality of the natural environment in which I live day-to-day.
This calls 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 for decommissioning mode, I believe my health, safety and environmental interests would be harmed by any actions inconsistent with mothballing the plant ("SAFSTOR").
has been joined by the Shoreham-9.
I understand that SE2 Wading River Central School District (" School District") in seeking to intervene in hearings on other issues.
I also understand that the issues raised by all of these actions significantly overlap due to the fact that each of the actions constitute another step in the decommissioning process underway at the Shoreham Plant.
I would favor the consolidation of all of these proceedings to consider the issues raised by the School _ _ _ - _ _ _ _ - _ _ - -
D*istrict and SE.
Consolidation would be the most efficient and 2
expeditious way to proceed for all concerned.
I also submit that such consolidation is demanded by NEPA because 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.
bM(
Josep(scrohdis SUBSCRIBED AND SWORN BEFORE ME, on this.W b day of
'A F
1991.
1 fib- /
Notarypublic-
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// j/ 9.3 4
My Commission expires:
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