ML20073B782

Affidavit of J Scrandis Re Whether Party Sufficiently Threatened by Radiological Hazard & Other Environ Impacts of Proposal to Establish Requisite Interest & Standing for Intervention as of Right

ML20073B782
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/17/1991
From:	Scrandis J AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20073B697	List: ML20073B693 ML20073B707 ML20073B716 ML20073B721 ML20073B746 ML20073B761 ML20073B782 ML20073B794
References
NUDOCS 9104240364
Download: ML20073B782 (6)

Text

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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) ) (56 Fed. Reg. 11781, ,

) March 20, 1991)

AFFIDAVIT OF JOSEPH SCRANDIS Joseph Scrandis, being duly sworn, says as follows:

1. I, Joseph Scrandis, have owned my present residence at 10 Walnut Street, Westbury, New York 11590 for twenty-two years, located some 43 miles from the Shoreham Nuclear Power Station

("Shoreham Plant"). 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 r4ufficiently threatened by the radiological hazard and other environmental impacts of the proposal to establish the requisite interest and standing for interventien as of right.

2. I have been employed for the past five years at Aikido Computer Systems, Ltd., 150 Broad Hollow Road, Melville, New York _

11747, located thirty miles from Shoreham. My job titles are Director of Maintenance and Installations, and Computer Systems Engineer. I am responsible for developing new computer systems, the duties of a Chief Mechanical Engineer and Senior Electrical Engineer, and maintaining several computer systems for public 9104240364 910419 PDR ADOCK 05000322b O PDR

service agencies. I hold degrees in Electrical Engineering and Physics, and have been an active proponent of science and technology for 30 years via personal efforts and debate, letters to the editor, and organizational affiliations. I am familiar with both the benefits and risks of nuclear power plants and 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 2") since before 1980. I authorize SEg to represent my interests, as described herein, in any 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 ("NFPA"). The transfer would reaffirm and further the previous NRC decisions allowing LILCO to reduce staffing and maintenance. to a level-elearly-inconsistent with the terms of the full power operating license and NRC regulations.

- SE2 submitted a Section 2.206 request in conjunction with the Shoreham-Wading River Central School District in July of 1989 f

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-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 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 amendment.

5. . I do not believe that any steps in furtherance of the Shoreham Plant's decommiasioning 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 rus 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 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. l

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 i

transferee of the Shoreham Plant license. Thus, transfer of the 1 license 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 statutorily barred from operating that plant and-thus I will be 4

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

.suppl y thi s 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 altern .ve generating facilities will have to be built and operate 6 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. 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 the existing Agreement between LILCO and the State of New York, the cost of electric energy will probably double over the next ten years.

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").

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10. I understand that SE, has been $oined by the Shoreham-Wading River Central School Distric-.t%r W District") in seeking to intervene in hearings .:,3 ot'n 31 sues. I also understand that the issues raised Df < *, 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 District and SE. 2 Consolidation would be the most efficient and 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 independent of the decommissioning proposal.

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(psepM Scrandis SUBSCRIBED AND SWORN BEFORE ME, on this /M9ay of April, 1991.

Nenary g M

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