ML20073A604
| ML20073A604 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/05/1991 |
| From: | Musolino S AFFILIATION NOT ASSIGNED, BROOKHAVEN NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20073A495 | List: |
| References | |
| OLA-2, NUDOCS 9104230277 | |
| Download: ML20073A604 (6) | |
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UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Morton B. Margulies, Chairman-i Dr. George A. Ferguson Dr. Jerry R. Kline
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i 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 STEPHEN V. MUSOLINO, Ph.D.
Stephen V. Musolino, Ph.D.,.being duly sworn, says as follows:
- 1. -
'I, Stephen V. Musolino, reside at 6 Middle Cross, 1
-Shoreham, New York 11786 which is about two miles from the Shoreham' Nuclear Power l Station ("Shoreham Plant").
'I have-owned this property for five years.
Thus, I111ve within the: fifty mile-geographical zone utilized:by the U.S. Nuclear' Regulatory Commission ("NRC") to determine-whether a4 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 twelve years at Brookhaven National. Laboratory, Upton, New York 11786, located' about-five miles from the_Shoreham plant.
For the past nine 9104230277 910400
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_ years, I have worked as a Health Physicist.
I am Assistant for Safety to the Project Head of.the Relativistic Heavy Ion collider Project,-including radiation, industrial, industrial hygeine, and-cryogenic safety.
I am also a member of the Brookhaven Emergency Planning Staff.
I earned my BSET at Buffalo State, my Masters in Nuclear Engineering at Polytechnic Institute of New York, and my Ph.D. in Health Physics at Georgia Institute of Technology.
I am past President of-the New York Chapter of the Health Physics Society.
Through both my training and work experience, I am familiar with_both the benefits and risks of nuclear power plants.
I 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 Secure Energy, Inc. ("SE ") since January 3, 1989.
I authorize 2
SE to represent my interests, as described herein, in any
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2 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 l
and further the previous.lRC decisions allowing LILCO to reduce I
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i staffing and maintenance to a level clearly-inconsistent with the terms of the full power operating license and NRC regulations.
SE submitted a Section 2.206 request-in conjunction with the 1
2 Shoreham-Wading River Central School District in July of 1989 1
when the destaffing and plant disassembly 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 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 amendt.ent.
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 NEPA 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 review, 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 4
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danicd.- B3 sides roaffirming past actions ain3d at romoving tho Shoreham plant from service and, 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 l-i electric encrgy demand of the area.
Thus, either the choreham.
Plant must be operated or alternative generating facilities will 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").
9.
I understand that SE has been joined by the Shoreham-2 l
l Wading River Central School District (" School District") in l
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 5-
these proceedings to consider the issues raised by the School District 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 seg'mented propost.ls and actions are, in f act, part of a single proposal, are cumulatively significant, and have no utility independent of the decommissioning proposal.
L l
L Stephen V. Musolino SUBSCRIBED AliD SWORN BEFORE ME, on this.
day of Iddd 1991.
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