ML20073B716
| ML20073B716 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/17/1991 |
| From: | Todorovich M SCIENTISTS & ENGINEERS FOR SECURE ENERGY |
| To: | |
| Shared Package | |
| ML20073B697 | List: |
| References | |
| NUDOCS 9104240339 | |
| Download: ML20073B716 (6) | |
Text
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UNITED STATES OF AMER 1CA NUCLEAR REGULATORY COMMISSION 9
)
In the Matte.t of
)
Docket No. 50-322
)
LONG ISLAND LIGHTING COMPANY
)
(License Transfer
)
Application)
(Shoreham Nuclear Power
)
Station, Unit 1)
)
(56 Fed. Reg, 11781,
)
March 20, 1991)
AFFIDAVIT or 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 g
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 2
organization in educational, informational, litigation or other activities implementing the wishes of the membership and SE '8 2
Board of Directors for actions in the public interest.
In this
' instance, I have been. directed to seek intervenor status for SE, in.the various segmented NRC proceedings related to the decommissioning of the Shoreham Nuclear Power Station
("Shoreham") so that SE, can fulfill some of its authorized purposes by representing its organizational interests and the 9104240339 910419 s
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health, safety and environmental interests of its members in i
those proceedings as authorized by those members.
2.
SE, is a not-for-profit organization formed under then laws of the State of New York and qualified pnder IRC $
501 (c) (3 ),
The organization's membership includes over 1200 scientists and engineers.
SE, also receives additional support from layperson sponsors who support to organization's mission.
3.
SE, is a group of professionals, all experts in their 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 (including judicial and administrative proceedings), 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 responsible scientists support the value of technical innovation in all fields and, I
particularly, in energy.
-4.
The use of electricity continues grow.
Non-renewable fossil-fuels face inevitable depletion and their-combustion contributes to acidLrain,-the greenhouse effect, apparent changes-in our weather 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.
L
}.. m....
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 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 put on line, the Canadians will be able to further increase the U.S.
forelan trade imbalance.
This increase is like?y to be particularly dramatic because the cost of Canadian.4ectricity 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 atmosphere, increase the average cost of electricity, and providt 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 oconomic sense.
6.
Since its inception, SE, has participated extensively in the debate of issues in the nuclear industry.
Besides having _ _ _ _ _ -
been invited to advise administrators, legislators and agency and commission officials throughout the country on such issues as the Three Mile Island cleanup, nuclear insurance programs, re.1ocessing of spent fuels, waste disposal, materials transportation, the breeder reactor program, nuclear licensing delays and regulatory reform of the licensing process, SE, has 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.
In earticular, SE, has been a participant in the ongoing debate l
in connection with Shoreham and has continually favored utilization of the facility.
7.
Given the organizational interests described above, SE g
-is naturally interested in and concerned about the present proposal to decommission the recently licensed, brand new, state-of-the-art Shoreham.
8.
SE, is concerned that the decommissioning of Shoreham is presently underway despite the lack of prior safety or environmental review evaluating the safety or environmental impacts of, and-alternatives to,-the-decommissioning _ proposal as required by the National Environmental policy Act ("NEPA").
SE2 and its members have 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 alternatives to that l
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I proposal.
The actions taken by Shoreham's licensee, the Long Island Lighting Company ("LILCO"), and permitted by the Nuclear Regulatory Commission ("NRC"), to date have aircadi 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 transfer LILCO's license
(" transfer") to the Long Island Power Authority ("LIPA").
Both the NRC and LILCO are content to ignore the mandate of NEPA and thereby deny SE, and its members their right to participate in the NEPA process.
Over twenty months ago, SE submitted a request for NRC action under the provisions 2
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 nearings offered on the segmented decommissioning actions.
9.
SE also has an organizational interest in eliciting 2
information on the decommissioning (including the instant proposal to transfer the Shoreham license to LIPA) 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 level 2
by informing the local governmental leaders and the other interested individuals and groups in the~Shorehhm area of the environmental implications of the proposal to decommission Shoreham.
10.
Members of SE, who otherwise would have standing to intervene in their own right have authorized SE to represent 2
their interests as demonstrated by their separately submitted affidavits.
11.
I further submit that the interests that SE seeks to 2
protect under both the Atomic Energy Act of 1954, as amended and the National Environmental Policy Act of 1969, as amended, are germane to SE 's purpose.
For example, SL', and its members 2
believe that LIPA is not financially, technically, nor mangerially qualified to be the transferee of the Shoreham license.
The NRC, the people of Long Island and other decision-makers need to be informed of these circumstances and providing such information in the NRC proceeding is part of SE 's mission.
y 12.
I further assert that neither the claimu asserted nor the relief requested requires the participation of those individual members in the proceeding.
13.
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")...
14.
SE; has joined the Shoreham-Wading River Central School 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.
SE, f avors 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 SE also submits that such consolidation is demanded by NEPA 2
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.
F
'A
[.e-Miro M. Todorovich
/
Executive Director SUBSCRIBED AND SWORN BEFORE ME, ojnhiskMdayofApril, 1991.
fw wuc Notary Public h'3# k My commission expires:
FRANCIS MNNETT f f ew York Notary P t!i. Sjate prdkvg 991 Commiss n
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