CCAM NEWS 2003
Connecticut Coalition Against the Millstone Nuclear Power Reactor
STATE
OF CONNECTICUT
CONNECTICUT SITING COUNCIL
IN RE: : DOCKET NO. 265
PROPOSAL OF DOMINION NUCLEAR :
CONNECTICUT, INC. TO MODIFY THE :
EXISTING MILLSTONE [NUCLEAR] :
POWER STATION TO ESTABLISH :
AN INDEPENDENT SPENT FUEL :
STORAGE INSTALLATION (DRY :
STORAGE SYSTEM) ON PROPERTY :
LOCATED OFF ROPE FERRY ROAD :
IN THE TOWN OF WATERFORD, :
CONNECTICUT : SEPTEMBER 16, 2003
AFFIDAVIT OF LAWRENCE H. ROBERTS
I, Lawrence H. Roberts, having been duly sworn, do hereby depose as
follows:
I am above the age of eighteen (18) years and I believe in the obligation
of
an oath.
I am a member of the Connecticut Coalition Against Millstone.
The Connecticut Coalition Against Millstone is an organization whose
membership consists of statewide safe-energy and environmental organizations,
Millstone whistleblowers and families throughout the State of Connecticut
including families residing within the priority emergency evacuation zone
of the Millstone Nuclear Power Station.
Since its creation in September 1999, the Coalition has participated as
a
party and as an intervenor in numerous proceedings before the U.S. Nuclear
Regulatory Commission, the Connecticut Department of Public Utility Control
and in proceedings brought to the Superior and Supreme Courts of the State
of Connecticut.
I submit this affidavit as a member of the Connecticut Coalition Against
Millstone in support of its petition to intervene as a party in the above-referenced
proceedings before the Connecticut Siting Council.
I reside with my family at 4 Jordan Cove Circle in Waterford, Connecticut.
My home is located within one (1) mile of the Millstone Nuclear Power
Station.
My home is located northeast from and directly downwind from the
Millstone Nuclear Power Station and thus is in the path of the prevailing
winds traveling north from Millstone.
Given the location of my home and its close proximity to the Millstone
Nuclear Power Station, my family and I are at significant risk of harm
in the event of an accident involving dispersal of radiological emissions
emanating from Millstone as well as from routine radiological emissions.
I am familiar with the above-referenced application by Dominion Nuclear
Connecticut, Inc., owner and operator of the Millstone Nuclear Power Station,
to the Connecticut Siting Council for approval to construct an “interim”
storage facility for high-level radioactive waste in the form of spent
fuel rods at its site on Rope Ferry Road in the Town of Waterford, less
than one (1) mile from my home.
I understand that the spent nuclear fuel will routinely emit radiation
to the
environment even if the facility is built and maintained properly, and
that because of the location of my home to the northeast of Millstone
and the direction of prevailing winds, my family and I will suffer greater
exposure to radiation than presently if the facility is approved.
My family and I enjoy recreational use of Jordan Cove and surrounding
coastal areas.
Our enjoyment of such recreational use will be diminished if the facility
is
approved because of the potential adverse effects, including thermal pollution,
from locating the facility upslope from wetlands and groundwater which
drain into such coastal areas.
In the event of an accident or terrorist attack upon the proposed facility,
my
family and I will be at grave risk of harm, given the proximity of our
home to Millstone, because of the likely dispersal of unsafe levels of
radiation.
_________________________
Lawrence H. Roberts
STATE OF CONNECTICUT
ss: East Lyme
COUNTY OF NEW LONDON
Sworn to and subscribed before me this 16th day of September, 2003.
___________________________________
Commissioner of the Superior Court
STATE OF CONNECTICUT
CONNECTICUT SITING COUNCIL
IN RE:
: DOCKET NO.
265
PROPOSAL OF DOMINION NUCLEAR :
CONNECTICUT, INC. TO MODIFY THE
:
EXISTING MILLSTONE [NUCLEAR] :
POWER STATION TO ESTABLISH :
AN INDEPENDENT SPENT FUEL
:
STORAGE INSTALLATION (DRY
:
STORAGE SYSTEM) ON PROPERTY :
LOCATED OFF ROPE FERRY ROAD :
IN THE TOWN OF WATERFORD,
:
CONNECTICUT
: SEPTEMBER
17, 2003
PETITION OF CONNECTICUT COALITION AGAINST MILLSTONE
TO BE DESIGNATED A PARTY
In accordance with the provisions of the Regulations
of State Agencies §16-50j-14, the Connecticut Coalition Against Millstone
(“CCAM”) hereby petitions to be designated a party to these
proceedings.
In support of this petition, CCAM represents
as follows:
1. The Connecticut Coalition Against Millstone
is an organization whose
membership consists of statewide safe-energy and environmental organizations,
Millstone whistleblowers and families throughout the State of Connecticut
including families residing within the priority emergency evacuation zone
of the Millstone Nuclear Power Station.
2. Since its creation in September 1999,
the Coalition has participated as a
party and as an intervenor in numerous proceedings before the U.S. Nuclear
Regulatory Commission, the Connecticut Department of Public Utility Control
and in proceedings brought to the Superior and Supreme Courts of the State
of Connecticut.
3. CCAM is presently based in Niantic, Connecticut,
where it maintains a post
office box, P.O. Box 415, Niantic, Connecticut.
4. These proceedings concern the application
of Dominion Nuclear
Connecticut, Inc. to establish a dry storage system for spent nuclear
fuel at the Millstone Nuclear Power Station in Waterford.
5. CCAM submits the following contentions
regarding the application:
a. The application violates the Town of
Waterford Zoning Regulations, which
prohibit new facilities for long-term storage of high-level radioactive
waste. As there is presently no “permanent” location available
for storage of the
spent fuel rods, and none is presently planned nor approved for construction,
the application is in reality an application for de facto long-term storage
of radioactive waste, which is forbidden by the Town of Waterford Zoning
Regulations. (See sections 2.4, 3.1 and 11.2 and Memorandum of Thomas
V. Wagner, Planning Director, Town of Waterford, August 1, 2003.)(“The
Millstone site has not been approved for long term storage of spent fuel.”)
b. The applicant cannot demonstrate environmental
compatibility for the project, given its projected increase in routine
radiation emissions to the environment and the potential for thermal pollution
of the groundwater and nearby wetlands.
c.The applicant cannot demonstrate public need for
the project, given the recent entry of new electricity generators in the
State of Connecticut and their contribution of in excess of 3,000 megawatts,
far in excess of the generating capacity of Millstone Units 2 and 3 combined.
d. To the extent that the application is
intended to extend the life of Millstone
Unit 2 by providing storage capacity for nuclear waste to be generated
after 2005, when Unit 2 will have been in operation for 30 years, the
application should be rejected. Given the trouble-plagued operational
history of Unit 2, its repeated interruptions in service, its repeated
equipment failures, its repeated unplanned releases of radiation to the
environment, and its ongoing difficulties in maintaining the operability
of the reactor cooling system components, Unit 2 should be retired as
soon as possible.
e. The application increases levels of airborne
radiation emitted from the
Millstone Nuclear Power Station to the community, according to Dominion
officials. Given that any exposure to radiation increases the risk of
biological harm, and given the population density in the immediate vicinity
of the plant, this poses an unacceptable risk.
f. The application assumes continued,
unmitigated harm to the environment
due to ongoing Millstone operations. These adverse impacts include devastation
of the native fish stocks, illegal releases of deadly chemicals to the
environment, and routine releases of radioactive effluent to the air and
water. CCAM contends that the high incidences of cancer and immune system
disorders within the Millstone community are directly linked to these
activities.
g. The application is incomplete. It fails
to provide sufficient information by
which the Siting Council can adequately assess whether the new facility
is appropriately designed to withstand terrorist attack.
h. CCAM reserves the right to submit additional
contentions during the
course of the proceedings.
i. To the extent that CCAM’s
membership includes families and individuals
who reside and work in close proximity to the Millstone Nuclear Power
Station and the site of the proposed nuclear waste storage facility, and
thus are within a zone of heightened danger from the nuclear installation.
CCAM possesses legal standing to be designated a party in these proceedings
to represent their rights and interests.
6. CCAM respectfully represents that the
rights and interests of its
membership are not adequately represented by other parties to these proceedings.
The applicant and the Town of Waterford favor approval of the application
without adequate consideration of the pertinent issues.
7. CCAM intends to present the testimony
of its membership and pertinent
documents during the course of the proceedings. CCAM reserves the right
to present expert testimony in further support of its contentions.
8. CCAM’s participation will be devoted
to advocating rejection of the present
application by Dominion Nuclear Connecticut, Inc. on grounds there is
not a public need for the facility and the nature of the probable environmental
impact conflicts with the policies of the state, without prejudice to
the submission of a detailed application to phase out the Millstone operations
and construct a terrorist-proof dry storage facility should the Town of
Waterford approve necessary enabling amendments to its Zoning Regulations.
9. The Council possesses statutory authorization
to designate CCAM as a
party to these proceedings (see Connecticut Regulations of State Agencies,
Sec. 16-50j-15a) as well as to reject the present application (see Connecticut
General Statutes §16-50p.
11. The Affidavit of Lawrence H. Roberts accompanies
this petition.
Respectfully submitted,
CONNECTICUT COALITION AGAINST
MILLSTONE
By: _________________________
Nancy Burton, Esq.
147 Cross Highway
Redding Ridge CT 06876
Tel.: 203-938-3952
Fax: 203-938-3168
Email: nancyburtonesq@aol.com
CERTIFICATION
This is to certify that a copy of the foregoing was mailed on September
17, 2003 to the following via U.S. Mail, postage pre-paid:
Robert L. Marconi, Esq.
Assistant Attorney General
Ten Franklin Square
New Britain CT 06051
Daniel A. Weekley
Director,
Northeast Government Affairs
Dominion Resources Services, Inc.
Millstone Nuclear Power Station
Rope Ferry Road
Waterford CT 06385
Kenneth C. Baldwin, Esq.
Robinson & Cole, LLP
280 Trumbull Street
Hartford CT 06103
Lillian M. Cuoco, Esq.
Senior Counsel
Dominion Resources Services, Inc.
Millstone Nuclear Power Station
Rope Ferry Road
Waterford CT 06385
Robert A. Avena, Esq.
Kepple, Morgan & Avena, P.C.
Box 3A Anguilla Park
20 South Anguilla Road
Pawcatuck CT 06379