ML20073B761
| ML20073B761 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/17/1991 |
| From: | Musolino S AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20073B697 | List: |
| References | |
| NUDOCS 9104240355 | |
| Download: ML20073B761 (6) | |
Text
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of
)
Docket No. 50-322
)
LONG ISLAND LIGHTING COMPANY
)
(License Transfer
)
Application)
(Shoreham Nuclear Power
)
Station, Unit 1)
)
)
March 20, 1991)
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, Shoreham, New York 11786 which is about two miles from the Shoreham Nuclear Power Station ("Shoreham Plant").
I have owned this property for five years.
Thus, I live within both the ten and fifty mile geographical zones 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 twelve years at Brookhaven National Laboratory, Upton, New York 11786, located about five miles from the Shoreham plant.
For the past nine 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 9104240355 910419
/
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 2
proceedings to be held in connection with the Long Island Lighting Company ("LILCO")-application to transfer the Shoreham Plant license (" transfer") to the Long Island Power Authority
( LIPA").
4.
I am concerned that the transfer 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 transfer would reaffirm and further. the previous NRC decisions-allowing LILCO to reduce 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 2,
,_i,___.;.m_.
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.
The Request, which has been denied, asserted that these actions should not be allowed to go forward before publication of a Final Environmental Impace Statement ("FEIS") pursuant to the dictates of NEPA and because they were inimical to the public health and safety due to their inconsistency with LILeo'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 NEPA and the NRC's own regulations ir 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 necer,sary 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 denied.
Besides reaffirming past actions aimed at removing the Shoreham Plant from service and, therefore, in furtherance of decommissioning, the transfer would also set the stage for yet _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
other actions in furtherance of decommissioning.
The transfer would be a further step in removing the plant from service which is part of " decommissioning" as defined by the NRC regulations.
6.
The transfer 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, among other things, LIPA lacks the financial, technical and management qualifications to become the transfc.ree of the Shoreham Plant license.
Thus, transfer of the licenne to LIPA would unreasonably endanger my health and safety.
7.
As a Long Island resident, I will be injured if the Shoreham Plant license is transferred to LIPA because LIPA is ststutorily barred from operating thst plant and thus I will be denied the benefit of that plant as an electric generating facility in violation of the purpose of its license.
I am further 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 have to be built and operated.
Because natural
-4
gas supplies cannot easily be increased, oil-burning plants will
-inevitably be needed to replace the Shoreham Plant thereby increasing our reliance cn1 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.
-I-am also concerned about the adverse economic consequences which will automatically flow from the decommissioning'of the Shoreham Plant and injure me.
These injuries include depriving me of a reliable electrical supply with ensuing damage-to my health,-loss of economic growth in the
~
area and hence damage to my property values.
Also, under the terms of thelexisting Agreement between.LILCO and the State.of New' York, the cost-of electric energy will'probably double over the next ten years.
In-addition to these outrageous electric rate-increases, the transfer to LIPA would involve a drastic reduction in real property tax income for the Town-of Brookhaven
-(about~28%) and the~ County of Suffol'X~1about: 10%) injuring me both by a precipitous-decline in government services for me and by_ imposing significant real estate tax increases on me. _ _.. _.. _ _ _., ~. _, - _. -. _ _. ~... _ -
9.--
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").
i 10.
I understand-that SE has been joined by the Shoreham-2 Wading River Central School District (" School District") in I
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 i
. 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 segmented-proposals and actions are, in fact,-part of a single proposal', are cumulatively =significant, and have no utility _
a independent of the decommissioning proposal.
Stephen V. Musolino SU3?CRIBED AND SWORN BEFORE ME, on this / M day of April, 1991.
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