ML20100G636

Supplementary Affidavit in Support of Comments Filed 841129 & Request for Oral Argument Filed 841129

ML20100G636
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/05/1984
From:	Brown H, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY
To:
Shared Package
ML20100G638	List: ML20100G636 ML20100G645
References
CON-#484-475 OL-4, NUDOCS 8412070340
Download: ML20100G636 (3)

Text

4 79 o o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission gg.gg7gg ,

USNRC

) '84 DEC -5 PS:14 In the Matter of )

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LONG ISLAND LIGHTING COMPANY )

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Uff Docketho.h7khk$'2h0L-4 N['

(Shoreham Nuclear Power Station, ) (Low Power)

Unit 1) )

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NEW YORK STATE AND SUFFOLK COUNTY SUPPLEMENTARY AFFIDAVIT IN SUPPORT OF COMMENTS FILED NOVEMBER 29 AND REQUEST FOR ORAL ARGUMENT FILED NOVEMBER 29 On November 29, New York State and Suffolk County submitted comments concerning the Licensing Board's decision which, in effect, recommended issuance of a low power license for Shoreham.

The State and County also filed a Request for the Commission to reconsider its decision denying an opportunity to the State and County to present oral arguments against issuance of a low power license. The instant pleading is to transmit to the Commission an affidavit in support of the State and County's November 29 filings.

The enclosed affidavit is the sworn statement of Eugene J. Gleason, Director of the New York State Energy Office, Bureau of Planning.

Mr. Gleason is responsible for the management of electricity supply planning studies.

' Mr . Gleason concludes that, "the electricity capacity represented by the Shoreham nuclear power plant does not appear to be needed to meet anticipated near term electricity demand, either 8412070340 841205 .k m PDR ADOCK 05000322 a eDR g((bxg o(1 c 0 (e) 3 s03

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'on a statewide or individual' electric service territory basis."

(Affidavit,'p. 2). Exhibit EJG-2, attached to Mr..Gleason's e -

,g affidavit, shows that'"the electricity reserve margin for'the w.

ELILCO electric service. territory would be adequate through 1997 3

without comadreial operation of the Shoreham plant."

, Mr.'Gleasonjsconclusionisbasedbnthreeanalysesperformed.

by-the planning staff of'the State Energy Office under his super-vision.' His conclusion is further supported by analyses conducted r '

by LILCo.itself~and by economic consultants to Suffolk County.

4.Given that the quantity of electricity represented by Shoreham will not be needed for 13 years, there is no reason why the Commission

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n i shoul'd consider' issuing a low power license to LILCO that would 1

permiticontamination of the Shoreham reactor while determinative-emergency preparedness issues are pending in New York State Supreme Court. What conceivable public purpose could justify the NRC failing to wait several months'in deciding whether to license a i plant which is not needed for 13 years?

' Respectfully submitted, Martin Bradley Ashare 4 Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 KIRKPATRICK & LOCKHART i

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/H4rbert H. Brown Lawrence Coe Lanpher Karla J. Letsche 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 i

Attorneys for Suffolk County l

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- Fabian G. Palomino Special Counsel to the Governor of New York State Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Robert Abrams Attorney General.of the State 4of New York Two World Trade Center '

- New York, New York 10047 Attorneys for Mario M..Cuomo December 5, 1984 Governor of the State of New York 9

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