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UNITED STATES OF AMERICA f
// '7 ATOMIC ENERGY COMMISSION In the Matter of
' LONG ISLAND LIGHTING COMPANY Docket # 50-322 (Licence Application,'Shoreham Nuclear Porter Station. Plant Unit No. 1) gp PETITION FOR INTERVENTION Connecticut Action Now, Inc. and Fairfield County Citi-zens for Environmental Control, Inc. herewith petition the Atomic Encrcy Commission for leave to intervene in the above matter.
1.
Petitioner Connecticut Action Now, Inc. (CAN) is a non-profit, non-stock corporation organized under the laws j
l of the stato of Connecticut to stimulate and mobilize volmi-l tary citizen' action'in the solution of pressing environmental problems.
2.
Fairfield County Citizens for Environmental Control, Inc. (FCCEO) ic a non-profit, non-stock membership organiza-tion, incorporated under the laws of the state of Connecticut with the purpose of engaging in any lawful activity for the purpose of preserving and protecting the environment.
Member-ship of FCCEC is approximately 350 persons.
3 The petitioners have by their activities and con-duct exhibited.a special interest in assuring the preserva-8709250210 870921 PDR FDIA MENZ87-111 PDR
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tion of the potential of Long Island Sound' for its conserva-tional, recreational, economic, and unique environmental' 1
qualities.
4 The petitioners are concerned with the preserva-tion of the ecology of Long Island Sound, its marine and plant life, aquatic habitat and supporting ecosystems, and the usefulness of the ' marine environment of Long Island Sound for recreational.and other beneficial' purposes.
5 It is of prime importance to the petitioners that the full range of environmental effects of nuclear power
., plant development on the, borders of Lon6 Island Sound be analyzed so that a deter,mination can be made whether this project,. singly as well as in concert with other proposals for nuclear power development in thic area, will further the public interest of the citizens of the state of Con.necticut.
6.
The proposed project and other. anticipated. nuclear 1
. power developments borderin6 the Sound will upon information I
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and belief a'dversely affect petitioners' interests through i
l danage to the ecology and diverse ecosystems of Long Island Sound because of thermal and radioactive discharges into
,the water and air and because of safety hazards to the human and natural environment, t
7.
More specifically, in the area of thermal discharge, 1
the pot,itionerst interests are affected when damage to aquatic life is caused by,the heated effluent from this project.
The
.Shorcham proposal involves a macsive discharge of h,eated offlu6nt into the Sound at a rate of 600,000 Callons per i
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minute.
At that rate the.Shoreham plant along would contrib-
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ute 6 bill' ion gallons per week to the waters of the Sound.
The discharge of such large volumes of heated water into Long Island Sound not only may be detrimental to the fish directly, but may affect these resources indirectly through ecological changos, particularly in the food organisms on I
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which the fish depend.
Since Long Island Sound is a narrow l
body of water involving conside,rable interchange through circulation, any such adverse conditions originating at the site of the proposed project would produce adverse offects on the existing ecosystems on the Connecticut side of the Sound, counter to the interests of petitioners.
8.
If for example certain migratory species of fish woro stimulated into early migration as a result of changes I
in temperature near the point of thermal discharge, such a i
condition would kill, damage, or upset the reproductive cycle, i
I or food chain of fish, plant, animal life, aquatic biota and
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supporting ecosystems of Long Island Sound, to the injury of
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t the interests of petitioners, j
9 The discharge of heated effluent would cause a speed up of eutrophication and algae growth near the point of discharge. Unless current trends change, we can unfor-tunately predict a significant increase in the nutrient con-1 j
tent of the water of the Sound as a result of this proposed dischargo as well as from all other sources discharging heat l
and sewage from both the Connecticut and Long Island shore-l 1.
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4 fronts.
Any discharge of heated offluent from the proposed project which speeds eutrophication on the Connecticut shore-line would adversoly affect the interests of the petitioners.
10.
To the extent that diluted. radioactive isotopes become concentrated in aquatic organisms, enter into the food chain in Long Island Sound and eventually are consumed by Connecticut citizens, such a condit' ion would constitute
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an injury to the petitioners' interests.
11.
The exposure of aquatic biota, fish and wildlife organisms to radiation as a result of this project and as a result of the emission of radioactive wastes to the cooling I
water from other nuclear power development sources, or from the abnormal increase of radioactivity due to an accident
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at or in the neighborhood of the proposed facility, would j
i result in the occurrence of a concentration of radioactivity harmful to fish and wildlife which use the Sound, and there-fore adverse to petitioners' interests'.
1 12.
Qualitative and quantitative studies of bottom biota, plankton, crustacea, fish, temperature, salinity, bottom composition and water chemistry must be made in order to dotormine what environment 1' radioactivity in Connecticut i
i would occur as a result of the normal and abnormal operation t
i of the proposed facility at Shoreham.
13 Stratford Connecti' cut is the nearest municipality to the Shoreham facility, having a population of over 25,000 persons.
It is eighteen miles northerly of the proposed site
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l across the Sound.
It and other communities along the Con-j nocticut' shoreline must be protected from emission of radioactive gases under normal and abnormal conditio'ns.
- i Stratford and the other Connecticut communities must be
,. assured of the operational reliability of the Shoreham
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facility since it is in such closo proximity to these popu-lation conters.
i 14 Transportation of radioactive wastes from the propocod Shoreham facility to their pormanent disposal point, if transported by sea, would directly and serioucly endanger the wators of Long Island Sound and the Connecticut shorelino l
in the event of an accident.
.15 Uniccc the above cited dancero to the environment i
and ocology of Connecticut can be provented, eliminhted, or l
adequatoly controlled, then the petitioners and their members' 1
richt to livo in and onjoy an environment free from improvi-dont doctruetion, pollution or imnocessary radiation would be irreparably damaged, and their rights to the use and enjoy-ment of property free from unnecessary invasion or impairmont, i
which rights are protected by the Fifth Amendment to the United States Constitution., would be violated.
The petiti6norc also ascert the interasts of other Connecticut citizens cimilarly situated.
i 16.
Upon information and belief, no Connecticut offi-I cials, much loss private residente along the Connecticut i
chore 11ne, had actual or effective knowledge of the Shoreham L
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proposal in time to comply with the technical filing pro-i codur,es.
The petitioners observe that the Atomic Energy Commission (horoafter the Conmission) itself has on a I
i prior occasion postponed the scheduled hearings and that I
other parties, including the Attorney ~ General of the 1
State of New York, have been pormitted to int.ervene with-
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out being foreclosed by a filing technicality.
The. peti-
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tioners thorofore must not be arbitrarily denied their l
1egal right to present their interests and concerns be-l fore the Commisolon.
Jurisdiction and Obligations of the Atomic Energy Commission 17 The National Environmental Policy Act of 1969, Public Law 91-190; 83 stat. 852 (hereafter NEPA), marked a major departure in the heretofore often passive role of
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governmental responsibility for preventing and correcting environmental wrongs.
NEPA places an. affirmative procedural l
duty on government agencies to analyze proposals under their jurisdiction in terms of their environmental impact.
18.
NEPA places upon the Commission the duty of concidoring the thermal, ecological, radiological, and other l
environmental offects of the propoced Shoreham facility on Long Island Sound and the Connecticut shoreline.
i 19 NEPA establishes a national policy to, among other l
thingp, "provent or eliminato damage to the environment and j
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biosphere" (Soction 2, NEPA).
In Section 101 (a) the United States, Congress
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i recognizing the profound impact of man's _ activity q
on-the'interrela';1ons of all components of the i
natural environment...andi..the critical importance
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of restoring and maintaining'env1ronmental quality to the-overall welfare and development of man declares that it is the continuing policy of khe
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Federal Government, in cooperation with State and local governnentn, and othey concerned nublic and privato_ organizations,, to use all practicable-means and measures...to create and maintain condi-tionc under which man and-nature can exist in pro-ductivo harmony, and fulfill the social, economic j
and other requirements of present and future gener,a-tiona of Americans.
(emphasis added)
- 20. - Under,Section 101 (b) of-NEPA, the' Atomic Energy i.
Commission has the-a
-l continuing rospons' bility...to uso all practicable j
i consictent with other essential considerations meanskional policy, to _ improve and coordinate Federal l'
of na plans, functions, programs '
end that the. Nation may..., and resources to the j
(3) attain' the widest range of beneficial uses of the environment without ^ degradation, risk to health or safety,'or other undesirable and unintended consequences; i
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preservo importan)... natural aspects of our i
nhtional heritage, and maintain, wherever possible,
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an environment which supports diversity and variety j
of individuni choice:
21.
In Section 101 (c) of NEPA Congress recognized Hthat each person'should enjoy a healthful environment and i
that each person has a responsibility to contribute to the i
precorvation and enhancement of the environment."
22.
In ordor to carry out tho above cited purposes and policies of NEPI, Congress authorized and directed that, to i
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the fullost extent possible, "the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the pol'ciec set forth in this Act".
(Section 102 (1) of NEA).
23 In furtherance of such Haction-fercing" imple-montation, Section 102 (2) thereof requires in part that:
. all. agencios of the Federal Governnent shall--
i (B)... insure that presently unquantified environ-montal amonities and values may be given appropri-ato concidoration in decision making along 171th oconomic and technical considerations; (C) includo in every recommendation or report on propocals for legislation and othe: major Federal actions si6nificantly affecting the quality of the the human environment, a detailed rtatement by the responsible official on--
(i) the environmental impact of the proposed action (iih any adverse environmental effects which cannot be avoided should the proposal be imple-mented,)
(iii alternatives to the propesed action, (iv) the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable conmit-monts of resources which would be involved in the proposed action should it be impinnented.
Prior to making any detailed statenent, the respon-sible Federal official shall consult with and obtain the comments of any Federal agency which has juris-diction by law or special exportise with rbspect to any environmental impact involved.
Copios of such statement and the comments and viers of the appro-priate Federal, State, and local agencies, which are authorized to develop and enfor:e environmental standards, shall be made available to the President,
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tho. Council on Environmental Quality and to the I
public as provided by section 352 cf title 5, United States Code, and shall accompany the proposal through the existing agency review processes; l
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'24 On its. face therefore, NEPA requires the Commission to moko detailed environmental dtatements~on the full range.
of environmental effects involved'in nuclear. power plant li-censing proceduros.
25 Throuch its regulations implementing the NEPA and its interpretation of its jurisdiction under the Water Quality Improvement Act of 1970 (Public Law 91-224 and hereafter WQIA),-the Atomic Enorcy Commission has attempted to restrict its jurisdict on and obligations under HEPA, with tho recult J
that it is not operating in compliance with the comprehoncive directives which HEPA places upon fedoral agencies, and accor-dingly dooo not intend to do so for tho'Shorcham proposal.
26.
So,ction 21 (b) of UQIA requires the applicant Long Island Lighting Company to provido the licensing agency (the Commiscion) with a certification from the state in which a discharco originntec or will originate (or "from the inter-stato water pollution control agency having jurisdiction over the navigable waters at the point where the discharge origi-natec br 17111 oricinate") that there 1s reasonable assurance "that such activity will be conducted in,a canner which.will not violato applicable water quality standards."
27.
In 35 Federal Register 8594-8597, published.on l
Juno 3, 1970, the Commission's proposed rulo making for imple-mentation of NEPA ctates as follows:
c 6.
With respect to water quality aspects of tho l
propocod action covered by section 21 (b) of the s
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I federal' elater Pollution Control Act, the require-merits of section 21 (b) supercede pro tanto the more general environmental requirencnts of sec-tions 102 and 103 'of the National Ihvirondental Policy Act of 1969 With respect to such aspects, therefore, the environmental reporic submitted by app 11cante nursuant to paragraphs 1. and 2 and the detailed statements prepared pursuant to paragraph 5 need includo only a reference to the certification issued pursuant to section 21 (b) or to the basis upon which such certification is not required.
28.
In volune 35 Federal Registor 8594-8597, cited above, the Corniscioh' asserts in paragraph 9 and paragraph 11 thoroof that the licencing and regulatory jurisdiction of the Commiccion has not boon extended to require it to j
mako indopondent dotorminations on matters such as water qun11ty, and accordingly the Commission considers such policy operative for the Shorehan propocal.
29 Such an interpretation of its responsibilities and jurisdiction is a misreadin6 of and violation of, among other sectionc, section 102 (C) of NEPA which requires the Commiccion to molte a detailed state ment on "the environmen-tal impact of the proposed action" and to censult with and j
'obtain the commente of any federal agency "cith respect to
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Ig)y_onvivonnantn1 imnnet involved", prior to making any detailed ctatencnt.
(emphasis added)
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30.
In 35 Federal Register 7390, published on May 11, 1
1970, the President'd Council on Environmental Quality
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incued interim guidelines for federal agencics under the National Environnontal Policy Act.
In paragraph 7 thereof, tho' Cpuncil refers to the points which are to be ' covered t
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in the content of the Environmental Statement:
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.1) the probablo 16 pact of the proposed action on the onv ronment, including impact on ecological _
l syntomo such as* wild 11fe, fich and marine Tife.
Both priddry and secondary significant consequ'en-i ces for the environment should be included in the analysis...(omphasis added) j ii) any probable adverso environmental effects I
which cannot be avoided (water or air pollution, damage to life cystems... threats to health or other consequence adverse to the environmental goals set out in coction 101 (b) of P.L.91-190.)
iii) alternatives to the propoced action...
iv) the relationship between local short-term uses of man's environment and maintenance and l
enhancenont of long-term productivity.
This in esconce requirca the agency to assecs the action
-for cumulative and 1,o_ng-f.orm effect.s from the per-spective that ce.ch generaT' ion is trustee of the 1
environment for succeeding generations.
(omphasis I
added) i v) any irreversible and irretrievably commitments of resources which would be involved in the proposed l
action should it bo implemented.
This requires the agency to identify the extent to which tho action I
curtailo the rance of beneficial ucos of the environ-mont.vi) where appropriate, a discussion of problems an6 objections raised by other federal agencies and state and local entities in the review process...
'With respect to water qualiby aspects which have received certification under section 21 (b) of the Unter Quality Im-provement Act, the C'ouncil's Guidelines pernit mere reference to the certification.
1 31.
The Council guidelinea under the NEPA clearly 11-lustrato the breadth of jurisdiction and responsibility placed l
f upon the Commicsion by NEPA.
Reliance upon the certification l
l proceduro as to' water quality standards c1carly doos'not l
rolicyc the Commission of responsibility to prepar'e. detailed i
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statements on. impact'of the proposal on ecological systems j
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(See paragraph 7 (1) of j
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Council'c interim guidelines abovo.)
32.
The Commiccion's rules indicato that it will look only to tho water quality stcndards of New York State.
1 As n' federal agency, the Commission abdicates its national
' i responsibility when it interpretc that'its environmental roopericibilitios under NEPA are satisfied by having an ap-plicant snow compliance with the water' quality standards of
-one stato only (New York) where the waterway involved is.an 1
.s intorstato _ body of water to which the citizens of Connecticut f
and Rhode Island have a legal intorest.
33 The Commission's attempt to restrict its juris-diction through its rules and procedures as stated abovo i
and its roliance on the Water Quality Improvement Act is j
most obviously shown to be in error in a situation where two or more states are involved.
Long Island Sound is an
,interstato naviCablo body of water adjoining the states of Now York, Connecticut and Rhode Icland.
Any adverse changes in the quality'and ecology of Long Island Sound caused by
,,thermo.1 additions from tho proposed Shoreham plant are there-fore antagonistic to the interests of Connecticut citizens who look to the entiro Sound as a uniquely valuable conser-q vation, recreation, and commercial resource.
3h.
The whole policy and thrust of EPA set f, orth in i
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I' 13 detail above rejects such a confined and restricted interpre-tation of the Commission's responsibility.
Under the Com-mission's interpretation it would be complying with NEPA if the Conmission merely required an applicant to m'eot*the water quality standards of ctate A even if state A had set a low thorual pollution standard.
State B, with a higher standard, i
would under the Commission's interpretation have no recourse to the procedural preconditions of NEPA requiring the Commis-sion to make detailed statements on'the effects of thermal discharco in so far as they affected state 3.
Thid situation exista in fact in tho Shoreham proposal, where Connecticut's water temporaturo standards are more strict than those of i
Now York.
1 35 In licht of the comprohonsive mandate of NEPA on
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fodoral aconcies to bring their procedures into conformity j
1 with the purposes of the Act, the correct reading of the relationship of iTEPA to WQIA is that the requirement of stato certification under WQIA means that the water quality stan-dards of the originating state are d minimun below which the Commission cannot approve a license or pernit.
The directivos of HEPA clearly do no set a* maximum on udter quality standards, and in the case whero more than ono jurisdiction is involved, NEPA and the Interim Guidelinos of the President's Council, cited above, are m*caningless unlesi the Corniscion assumes its national responsibility and obligation to nake'i'ndepen-I
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,,dont dotorminations on whether a propocod project will.
rocult in thormal, pollution of interstate waters..(See NEPA cection 101 (B), 102 (1), 102 (2) (B), and 102 (2)
(C)(ii).)
- 36..The effect of any in'orpretation to the contrary t
is to loave it solely to How York state to determine the fato of Long Island Sound's ocology and environmental quality, doopite the legal interest of Connecticut citizens i
to such.a body of water.
I 37 A certification that New York's water quality j
standardo.have boon mot does not relieve the Commiscion of ito obligation to mohe indopondent determinations on the e
indiredt effopts which the heated offluent of the proposed.
Shoreham plant may have on the fish, wildlife, water fowl, vogotation, ctc. of the Sound.
Analysis of water quality l
cannot bo separated from analysis of the indirect effects of thermal dicchargec, and this undorlinoc the directive of section 102 (C) (i) that the full range of environmental impact must be reviewed.
This conclusion is reinforced and i
amplified in paragraph 7 (1) of the President's Council's
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Interim Guidelinco.
If the Commission does not take ovidence l
on thernal pollution, it is therefore making an incomplete l-
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analysis.of environmental effect, and is not in compliance i
L with 102 (C) (i) of l! EPA.
t 38.
Compliance with the water quality standards of one stato says nothing about the specific environmental 4
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_ _. _7 15 effects of a particular project.. The absence of detailed statements for the Shoreham proposal therefore is in viola-tion of all provicions of 102 (C).
39 Section 102 (C) (iv) requires the Commission to i
make specific findings on the cumulative and'1ong-term ef-focts of nucionr power plant development on the Sound, and the reintionship of this Shoreham proposal to all other sourcos of heated effluent, and the effect that such con-corted development vill have upon the ecology and environ-montal quality of the Sound.
40.
Section 102 (c) (v) requires the Commicsion to onalyze whether any irreversible commitments of resourceo would be involved.
There is on affirmative duty thereforo on the Commicsion to analyze what portion the nuclear power inductry, es one of the many courcoc of ionizing radiation exposuro, should be permitted to appropriate to itself out of the permissable radiation budget of the Sound.
This would include a determination on whether any monopoly and other enti-trust iccuos are being raised.
Il.
Unions the Commiscion ic required to make indopon-l dont dotorminationc on such matters as have been discussed chovo, the Commiccion avoids its responsibilities to expand its oblication to encuro environment.1 protection.
Such an interpretation which would loavo the Conniccion role in this area virtually unchansed by the enactnent of HEPA, would do
,i vio'logce to the purpose ~ and the requirements of that legis-i 1
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lation.
42.
Upon information and belief the Commission has not requested comments from the appropriate Connecticut egencies and interested parties on the range of environ-montal offects anticipated by the Shoreham proposal.
13 The NFPA's requirement for detailed statements from the federal aconcies has the salubrious purpose of permitting the concral public to appraise the extent to which a proposal affects their interests.
It therefore provides the public with information at a time when it is pocciblo 'for them to make their concerns felt instead of being confronted by a fait accompli.
As cuch it has the important offect of increasing public awareness of, parti-cipation in, and ultimately acceptance of, decision making.
i In so doing it reverses earlier practices chich placed the l
i burden on the general public to show how they are affected by proposals with potential adverse environmental consequen-
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Under ITEpA the procedure places the burden.first upon ces.
the governmental agency through the requirement of. detailed l
ctatomonts, and then if the aconey concludes that there is l
no offect upon a petitioner, that petitioner must come forward with proof supporting his claims.
i 44 While recognizing that the Commission has made no final order on this application, it is cost important thet $ho Commission's, the applicant's, and the petitioners' i
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'timo not be wasted if the Commission'were to grant'the li-I conco without preparing the detailed statements in confor-mity with NEPA.
Such a position by the Commission would be futile it it woro inter determined,that their position re-1 flected local error and that thereforo the order would havo
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' to be vacnted and the caso romanded for further consideration.
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1 Therefore, the petitioner respoetfully requests (1)
That the licencing hearing before the Atomic Safoty and Idcensing Board, scheduled for September 21, 1970 at Rocky Point, Long Icland, New York be postponed or continued until detailed statements have been prepared by the Commic-sion on tho full rango of environmental impact of the proposed
'Shoreham facility, in compliance ylth the directives of NEPA.
(P.)
That prior to the competition of analycis;and the preparation of the detailed statemente, the Commission
, request roports from the Connecticut aconcies authorized to develop and enforce environmental standards, including but
'not limited to the Connecticut Water Ros.. trees Commission, the Connecticut Stato Board of Fisherios and Game, the Con-I nocticut Department of Health, the Clean Air Commission, the Interin Comaittoo to Study Electric Power Plant Hoquiremonto, and any other appropriate Connecticut agencios, as required t
by coction 102 (C) of NEPA.
These Connecticut reports would bo in addition to the reports of appropriate fodoral,agencico as required by coction 102 (C).
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2, (3)
That the Commission institute a moratorium upon power plant development bordering the Sound until the pro-7 posed study.of the New England River Basim Commiccion on the mactor plan for the use of the resources of the Sound has boon c,ompleted.
(I )
That copies of the detailed statomonts and t
supporting reporta be mado available to the petitioners, and that they be civon reasonable time to review said re-porta to dotormino the offects upon Connecticut interests.
UUEREFORE, the petitioners respectfully request the Commiccion'to issue an order permitting their intervention ao parties to this. proceeding.
The neue and address of the person on'whom servico may be mado ic ' PETER D., COOPER, ESQ., Socuoff, Cooper & Whitney, Ecqc., 35 Eln Stroet, Ucw Havon, Connecticut 06510.
Dated:
Septonbor 10, 1970 CONNECTICUT ACTION NOU, INC.
and FAIRFIELD COUNTY CITI7, ENS FOR l
ENVIR0HMD!TAL CONTROL, INC.
by:
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by:
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l-Peter B. Cooper, Partner 1
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Attorneys for Petitioners 35 Elm Stroot New Havon, Connecticut 06510
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Cortiftento_ of Sefvic_o., f.
,I I hereby cortify that a copy ot thi dPetit't'd to i
i Intervention has been nerved by first class mail upon the LONG ISIAl'D I,IGHTING COMPANY at 250 Old Country Road 111neola, lier York, 11501,,attentio of Eduard J. Walsh, Jr.,
Esq.
Datod:
September 11, 1970.
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Petoi D. Cooper q
Certifiento of Servico I hereby cortify that a copy of thic Petition for Intervention has bocn corved by first clasc nail upon 11AMTIll G. DI,SCH, Eaq., Trial Counsol for the AEC Recu-latory Staff; by doposit thereof in United Statec Mail, pootnco prepndd, addreccod to him at the Atomic Energy Comri coion, Unchington, D.C.
Ik i Dated:
September 11, 1970.
Peter B. Cooper State of Connecticut County of Ren Haven DAVIDD.DEIbiG,beingdulycuorn,deposesandsayo that he ic IMecutive Director of CONNECTICUT ACTIOIT NOU, Ii!C., one of the petitioners herein; that he hac road the forocoing Petition and knows the contents thoreof, and that to the best of hic kno.wledge information, and belief state-nonto made in it are truo, an,d that it is not interposed for delay.
David B. Beizer Stato of Connecticut I
County of Fairfield i
SYDHEI EVAHS, boinc duly sworn, deposes and says that l
ho ic President of FAIRFIELD COUIITY CITIZM!S FOR E?iVIR0l'MEiTTAL i
ColiTHOL, 17?C., one of the petitioners herein; that he has read the forosoins Potition and knonc the contents thereof, and that to the best of his knowledge, information, and belief statenonts nado in it are true, and that it is not interposed for delay.
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State of Connecticut County of Net 7 Haven:
- g Perconally appeared David B. Beizer and, Sydney Evano,
.nigners of the foregoing etition and acknowledged the same to bo their free act and eed' before me.
Q.&%
siis mo Commissioner,of the Superior Court e
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