ML19345G842

Petition to Intervene & Request for Hearing.Affidavits & Certificate of Svc Encl

ML19345G842
Person / Time
Site:	Summer
Issue date:	03/22/1981
From:	Ruoff J AFFILIATION NOT ASSIGNED, FAIRFIELD UNITED ACTION
To:	NRC COMMISSION (OCM)
References
ISSUANCES-A, ISSUANCES-OL, NUDOCS 8104220493
Download: ML19345G842 (30)

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UNITED STATES OF AMERICA ~

4 NUCLEAR REGULATORY COMMISSION

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. APRh193,,Q Ex Parte: FAIRFIELD UNITED ACTION, ) \;(n 7

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Petitioner, Docket Nos.

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In the Matter or: ) '

FO-395 OL

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SOUTH CAROLINA ELECTRIC AND GAS ) and COMPANY, ET AL. )

(Virgil C. Sumer Nuclear Station, 50-395 A [N

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PETITION TO INTERVENE AND REQUEST FOR HEARINGS Fairfield United Action, on its own behalf, on benalf of its mem-

ers, and on behalf of others who are similarly situated, hereby peti-tions for leave to intervene in the above-captioned coerating license and anti-trust review proceedings as a party of record, requests tnat public hearings be conducted at which it will be afforded an cocortun-ity to be heard and requests this Application for an Operating License be denied ot be so conditioned, as Petiticner will hereafter demonstrate, in order that the operation of the facility will be consistent with the f

terms of the anti-trtiH' laws of the United States and with the protec-tion of the health and safety of the public. In suoport of this Peti-tion and Request for Hearings, Fairfield United Action would respect- g fully show: 5

1. Tha*, Fairfield United Action is a not-fer-crofit mem:ersnip

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organi:ation incorocrated under the laws of the State of South Carolina i+

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2-I on Seotemoer 5,1980, with its principal offices at Jenkinsville, Fair-field County, South Carolina. It was organi:ed for the p" pose of pro-tecting the health, safety and welfare of residents of P.erfield County and neighboring communities. Its members include persons who live, work and are actively involved in civic affairs in rural Fairfield County and in the communities of Winnsboro, Jenkinsville, Greenbrier, and Blair.

2. Many of the members of Fairfield United Action live, work, en-gage in outdoor recreational activities including fishing, boating, swim-ming, hunting, hiking and camping, consume vegetables, dairy products and meat, and breath the air in close proximity to the Virgil C. Summer Nuclear Station, Unit 1, under construction near Jenkinsville. All mec-bers of Fairfield United Action are consumers of energy for residen-tial, recreatienal anc business uses. All now curchase elec ric energy frcm ccmmercial sources and would make use of energy sources whicn are reasonably intercnangeable with electricity such as solar, wind, bio-mass, and conservation techniques if such energy sources were more easi-ly available and comoetitively cr1ced. Petitioner's members include retail electric custcmers of South Carolina Electric & Gas Company, the Tcwn of Winnsboro, Fairfield Electric Cocperative, and Newberry Electric Cooperative. Fairfield United Action's memoership includes sharenolders of South Carolina Electric & Gas Ccmpany common stock.

3. Througn participation in the program of Fairfield United Ac-tion, its memcers have educated themselves on matters relating to the design, ccnstruction, and the ceabable effects on them, their families and the environment of tne coeration of tne Summer Nuclear Station.

1 Some of Petitioner's members have only recently moved to Fairfield County. Many of Petitioner's members who have lived in Fairfield County for many years have until recently relied on information from South Caro-lina Electric & Gas Company or others acting on the Company's behalf concerning the design, construction and probable effects of operation of the Sumer Nuclear Station which infonnation they now believe to be false and misleading.

None of Petitioner's members who resided in proximity to the Sum-mer Nuclear Station at the time of the filing of the Aoplication for Operating License in 1977 had knowledge that they had interests which might be adversely affected by the granting of the license sought in this proceeding, of their rights and remedies then available to them, or of the Notice published in the Federal Register on Acril 13, 1977, cy the Secretary to the CommissST.

4 That as a result of their participation in Fairfield United Action Petitioner's mencers are infonned and believe tnat the grant of an coerating license to South Carolina Electric & Gas Company and its coeration of the Virgil C. Summer Nuclear Station, Unit 1, will result in direct physical harm to the health and safety of themselves and their families and in direct injury to their economic interest.

5. That although Petitioner's members learned that the operation of the Summer Nuclear Station might adversely affect them they remained unaware of the rights and remedies aveilable to them. Until about mid-February 1981, Petitioner wa2 informed and believed that it had no right to carticipate as a partv to :his proceecing since tne deadline for in-

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tervention had passed in May 1977. It was further informed and believ-ed until then that its interests were being represented, to some ex-tent, by the existing Intervenor Brett Allen Bursey. About mid-Feb-ruary 1981, Petitioner was informed of a letter dated February 10, 1981, from counsel for the Applicant to the Licensing Board asserting that Intervenor Bursey was precluded "from putting on any witnesses or exhib-its on his rix admitted contentions," from raising any contentions re-lated to post-Three Mile Island requirements already addressed by Com-mission Staff, and that the Intervenor 2hould be in " total default."

Upon being so informed Petitioner undertook an immediate and thorough inquiry into the status of this proceeding and its rights and remedies.

Petitioner is further informed that significant ragulatory changes adcoted by the Commission in light of the lessons learned frem -he ac-cident at Three Mile Island, Unit 2, substantially expand the remedies available in an operat'ing license proceeding beyond those available at the time of the filing of this Apolication in 1977 and that as to those matters as well good cause exists for Petitioner's failure to file un-til this time.

The ability of Petitioner's to inform themselves of developments in this croceeding has been severely hampered by the absence of a local public document room in Fairfield County for several years. Peti tioner is informed that what filings exist were moved by the Applicant to the Richland County Public Library in Columbia some twenty-five miles from the olant, where inadequate sh61f soace and work space is available for

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effective use, wnere the Applicant itself is responsible for maintaining the documents, but has left materials unopened and unfiled dating back several months, and where the library has cancelled its subscriptions to Commission filings of general interest on technical studies and of Commission rulings and decisions due to lack of space. The partial col-lection on file is maintained in a locked cage with limited access due to lack of staff. Petitioner is aware of no other public source for these materials in South Carolina.

Petitioner believes that it has consistently exercised all due dili-gence in this matter and that good cause exists for its failure to file this petition until this time.

6. That Petitioner's interest in protecting its memoers from harm to tneir health and safety and from injury to their economic interests can only be protected througn full participation as a party to this pro-ceeding with the right to offer evidence and to confront evidence offered by other parties. No existing parties will represent Petitioner's in-terest including the State of South Carolina whose participation has been limited, the Commission Staff which cannot represent the individual in-terests of Petitioner's members, and the existing Intervenor whose par-ticipation is now narrowly limited. The Applicant's interest is believed to be adverse to Petitioner's.

7. That Petitioner is informed and believes that only by its par-ticipation will the Licensing Board have a complete and sound record produced as a result of a full adversarial process uoan whicn to reach

I 6-4 a reasoned and informed decision in this matter. That by reason of their life-long residence in proximity to the plant-site, Petitioner's members can offer unique working knowledge as to local geography, transportation, traffic conditions, and the ability of local residents to properly re-spond in the event of a radiological emergency. Petitioner's members also possess a unique knowledge of the organization and management of the Applicant gained through participation in other proceedings. Petition-er's members also include persons with training and experience in gener-al medicine, demography, statistics, economics, and advanced research.

Petitioner believes it will have access to valuable expert assistance in offering evidence in support of its contentions, herewith submitted and in preparing cross-examination for witnesses of other parties.

8. Petitioner is informed and believes that as to a large numcer of issues the contentions sought to be litigated by Petitioner are no broader in scope than the issues already joined by contentions raised by the existing Intervenor and issues raised by the Comission Staff and the Advisory Committee on Reactor Safeguards; and that the full and thorougn litigation of these issues 'by Petitioner will not delay the proceeding any more than if fully litigated by other particicants, but for the default of the existing Intervenor. As to the other issues raised by Petitior.er, the amount by which issues are broadened or the proceedings are delayed will be insignificant in the light of the bene-fits gained through the development of a sound record and the public interest to be served in a thorough review of this operating license i

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I application. Petitioner is prepared to cooperate with the Applicant, the Staff and the Licensing Board in the adoption of measures designed to excedite the proceedings 'and minimize delay.

9. That Petitioner is informed and believes that a reasonable probability exists that the granting of the license sought by the Ap-plicants and their joint ownership and operation of the Virgil C. Summer Nuclear Station, Unit 1, will contravene the anti-trust laws of the Unit-ed States and the policies clearly underlying those laws. .That signif-icant changes attributable to the Applicants have occurred since the issuance of the construction permit for this facility warranting the conduct of an anti-trust review and hearing in this matter and either the denial of the aoplication for the operating license or the conditioning of sucn license on sucn terms as are necessary to minimize adverse anti-trust impacts.

Petitioner is infornsd and believes that the Applicants South Caro-lina Electric & Gas Company and South Carolina Public Service Authority have engaged individually and together in acts and conspiracies in re-straint of trade, Oc acquire and maintain monocoly power, and to com-mit unfair trade practices to the direct injury of Petitioner's members who are consumers of electric energy sold by South Carolina Electric &

Gas Company, rural electric cocoeratives and municipal power systems purchasing power from the Applicants. Petitioners members are forced to pay higher prices for such electricity and are denied access to reasonably interchangeable alternate energy sources or must pay higher prices for sucn alternatives because of such conduct. The acts of the Applicants

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I which effect such a contravention of the anti-trust laws and underlying policies include the wielding of monopoly power by South Carolina Elect-ric & Gas Company in compelling the South Carolina Public Service Au-thority to join with it in improperly securing passage of territorial as-signment legislation and legislative and regulatory authorization for joint ownership of the Summer Nuclear Station through the unlawful and improper manipulation of the state legislative and regulatory processes.

Petitioner is informed that the Central Electric Cooperative and the South Carolina Public Service Authority have recently entered into a power system coordination agreement disposing of some matters of dis-pute between them. Petitioner would respectfully assert that such an agreement between them does not cure or mitigate the injury suffered to its memoershio likely to result from the Acolicants' concuct and :ne accroval of the operating license application.

10. That based uoan the foregoing Petitioner Fairfield United Action asserts a significant ability to contribute for the Licensing Board's consideration on substantial issues of law and fact which will not otherwise be properly raised or presented absent its carticipation in this proceeding.

WHEREFORE, having set forth its interest which will be affected in this croceeding, having shown good cause, and having submitted the contentions sought to be litigated and the bases therefore in the Suo-plement hereto and the Affadavits of eight of its members, which Sup-plement and Affadavits are incorporated herein, Fairfield United Action i

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respectfully requests leave to inter /ene in these proceedings, the con-duct of hearings and the denial of this application for an operating license unless so conditioned as to prevent injury to Petitioner"s health, safety and economic interests.

Respectfdlly submitted,

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Jonn C. Ruoff //

P.O. Box 96 s' L '

Jenkinsville, SC 29065 803-345-3514 AFFIRMED and subscribed to before me :nis.23 day of Maren 1981.

E I (L M NOTARY PUBLIC FOR SOUTH # CAROLINA My Cen:nission Excires //- / 7- 9 0 Y

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UNITED STATES OF AMERICA ,

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" " ' ' i; BEFORE THE NUCLEAR REGULATORY C019tISSION APR 13193; . -

Ex Parte: FAIRFIELD UNITED ACTION, )

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F ETITIONER ) ~A

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In tne Matter of ) A F F A 0 A V 'I-T27

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SOUTH CAROLINA ELECTRIC & GAS ) .

COMPANY, ET AL. ) DOCKET NOS. 50'-395 OL (VIRGIL C. SUMMER NUCLEAR STATION, ) and UNIT 1), ) 50-395 A APPLICANTS )

PERSONALLY APPEARED before me, Robert A. Hollins, who, being duly sworn, says:

1. That he lives at Rt. 1, Box 86, Jenkinsville, South Carolina, on Highway 215, together with his wife, one minor child, an adult stap-daughter, 2 minor step-grandchildren, and an infant step-grandchild who is kept days, at a distance of about 2 miles from the Virgil C. Sumer Nuclear Station, Unit 1, on the edge of the Monticello Reservoir, cooling lake for that facility.

2. That he owns the premise in which he resides and he is retired fecm the insurance business after serving a partial-term as Treasurer of Fair-field County.

3. That he and his family live, work, and engage in outdoor recreational activities throughout Fairfield County, South Carolina, including areas in the immediate vicinity of the Virgil C. Summer Nuclear Station, Unit

1. He and his family hunt rabbits and squirrels in that vicinity and I

consume the meat frem that game. He fishes in the Mc:mticello Reservoir and ne and his family consume those fish. He ar.d his family grow vege-l;i.. .- L Q ' '

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tables and consume produce from a garden on his land, near the Monti-cello Reservoir.

4 That he and his family are residential electric customers of South Carolina Electric & Gas Company.

5. That he is a member, incorporator, and on the Board of Of rectors of Fairfield ' United Action and he has been active in the organization since about March of 1980. That through participation in the programs of the organization, he has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the opera-tion of the Virgil C. Summer Nuclear Station, Unit 1.

6. That he is inforred and believes that the grant of an coerating li-cense to South Carolina Electric & Gas Comoany and the operation of this facility will result in direct physical harm to the health, safety, and economic interest of himself and his family.

7. That he is further informed and believes that his interest in this matter can only be protected through participation in this operating 11-cense proceeding, and that his interest will not be adeouately protected by any of the present parties to the proceeding. He authorizes Fairfield United Action, or its representative, to protect the interest of t

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himself and his family in this matter through participation in this proceeding.

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a Robert A. Hollins L

t n.r.m /f l w S'@RN to and subscribed before me this(2Mday of March 198d.

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NOTARY PUBLIC FOR SOUTH CAROLINA My commission expires: G a m!"' ' / IM t

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

PETITIONER AFFADAVIT In the Matter of: )

)

SOUTH CAROLINA ELECTRIC & GAS COMPANY, ET AL. ) DOCKET NOS. 50-395 OL (VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1), ) and APPLICANTS ) 395 A PERSONALLY APPEARED before me, John C. Ruoff, who does affirm and says:

1. That he resides on Highway 215, south of Jenkinsville in Fairfield County, South Carolina, at a distance of approximately 4 miles from the Virgil C. Summer Nuclear Station, Unit 1. He has lived at the above residence and in Fairfield County since June 1,1980.

2. That he leases the above premise where he resides and frem which he conducts his business and he is self-emolayed as a research consultant to a variety of non-profit and community-based organizations, which busi-ness is his principal employment and source of income.

3. That he holds a Bachelor of Arts (History) degree from Seattle Uni-versity in Seattle, Washington, and Master of Arts (History) and Doctor of Philosophy (History) degrees frem the University of Illinois at Urbana-Champaign and that he took part as an Intervenor on his own behalf in proceedings before the South Carolina Public Service Commission (Occket Nos. 79-196-E and 79-196-G) involving South Carolina Electric &

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Gas Company and through that oroceeding became educated and informed about the organization, management and operation of the Apolicant and l

. the design, construction, and plans for the operation of the Virgil C.

Summer Nuclear Station, Unit 1.

4 That he lives, works, and engages in outdocr recreational activities, including walking and bicycling, throughout Fairfield County, South Carolina, including areas in close proximity to the Virgil C. Summer Nuclear Station, Unit 1.

S. That he is a residential electric customer of South Carolina Elec-tric & Gas Company.

6. That he is a member of Fairfield United Action and has been active in the organization s1nce about March 1980. That through his carticipa-tion in the programs of the organization he has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Summer Nuclear Station, Unit 1.

7. That he is informed and believes that the grant of an ocerating license to South Carolina Electric &. Gas Comoany and the operation of this facility will result in direct physical harm to his health, safety,

! and economic interest.

8. That he is further informed and believes that his interest in this matter can only be protected through particioation in this operating

3-license proceeding. He authorizes Fairfield United Action, or its representative, to protect his interest.

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[dnC.Ruoff ,8/

AFFIRMED and subscribed to before me thiEJ/5-- day of March 198$.

//e (L.S.)

FrARY PUBLIC FOR SOUTH CA LINA My comission expires: /\ /ff7

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACT10N, )

PETITIONER )

) AFFA0AVIT In the Matter of )

)

SOUTH CAROLINA ELECTRIC & GAS ) DOCKET N05.~50-395 OL COMPANY, ET AL. ) and (VIRGIL C. SUMMER NUCLEAR STATION, ) 50-395 A UNIT 1.), )

APPLICANTS )

PERSONALLY APPEARED before me, Helen A. Barefoot,,who, being duly sworn, says:

1. That she resides at Rt. 3, Box 76-8, Winnsboro, South Carolina, on Highway 269 in Fairfield County, South Carolina, at a distance of apcmxi-mately 9h miles from the Virgil C. Sumer Nuclear Station, Unit 1. She has lived in that home for 2 years and in the immediate area for 3 years.

2. That she owns the above premise and 2 acres of land and she is an employee of the State of South Carolina.

3. That she lives, works in and engages in outdoor recreational activi-ties, including walking, throughout Fairfield County, South Carolina, in-cluding areas in close proximity to the Virgil C. Sumer Nuclear Station, l

Unit 1. She grows vegetables and consumes produce grown in a garden near her home and within ten miles of tne Virgil C. Summer Nuclear Station, Unit. 1.

4 That she owns 10 shares of South Carolina Electric & Gas Ccmpany l

Comon Stock.

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5. That she is a residential electric customer of South Carolina Elec-tric & Gas Company.

6. That she is a member of Fairfield United Action and has been active in the organization since about Aoril 1980. That through her particica-tion in the programs of the organization she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the V.C. Sununer Nuclear Station, Unit 1.

7. That she is informed and believes that the grant of an operating license to South Cat olina Electric & Gas Company and the operation of this facility will result in direct physical harm to her health, safety and economic in*.erest.

S. That she is further informed that her interest in this matter can only be protected through participation in this operating license proceeding, and that this interest will not be adeouately represented by any of the present carties to the proceeding. She authorizes Fairfield United Action, or its representative, to ;1rotect her interest in this matter through par-ticipation in this proceeding.

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Helen A. Barefoot j

SWORN to and subscribed before me this day of March 1981.

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}chu (L.S.)

D.?S.

ARY PUBLICF9R'50UTHCAROLINA

• My commission exoires:

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

PETITIONER )

) AFFADAVIT In the Matter of ).

)

SOUTH CAROLINA ELECTRIC & GAS )

COMPANY, ET AL. )

(VIRGIL C. Su m ER NUCLEAR STATION, DOCKET NOS. 50-395 OL

)

UNIT 1), and

)

APPLICANTS )

50-395 A PERSONALLY APPEARED before me, Margie G. Moore, who, being duly sworn, says:

1. That she lives at Rt. 3, Box 132, Jenkinsville, South Carolina, on Highway 215, south of Jenkinsville, South Carolina, together with her mother, her uncle, two minor children and a minor first cousin, at a distance of aporoximately 7 miles from the V1rgil C. Sumer Nuclear S tation.

2. That her family owns the premise in which she resides and 38 acres of land and that her orincipal employment and source of income is as the Home-base Coordinator for Head Start for Midlands Human Resources Develop-ment Comission.

3. That she and her family live, work, and engage in outdoor recreation-al activities throughout Fairfield County, including areas in close proximity to the Virgil C. Sumer Nuclear Station, Unit 1.

l 4 That she and her family are residential electric customers of South l

Carolina Electric & Gas Company.

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5. That she is a member, incorporator, and Secretary of the Board of Directors of Fairfield United Action and has been active in the organi-zation since about March 1980. That through her participation in the programs of the organization, she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Summer fluclear Station, Unit 1.

6. That she is infonned and believes that the grant of an operating li-cense to South Carolina Electric & Gas Company and the operation of this facility will result in direct physical hann to the health, safety and economic ir.terest of her and her family.

7. That she is further informed and believes that her interest in this matter can only be protected through participatial in the operating li-cense proceeding, and that her interest is not adequately represented by any of the present parties. She authorizes Fairfield United Action, or its representative, to protect the interest of herself and her family in this matter through participation in this proceeding.

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• Margie G. Moore r

SWORN to and subscribed l

before me this C.. 'uday of March 1984.

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NOTARY PUBLIC FOR SOUTH CAROLINA l My coninission expires

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1 UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

PETITIONER )

)

In the Matter of )

) AFFA0AVIT SOUTH CAROLINA ELECTRIC & GAS COMPANY, )

ET AL. )

(VIRGIL C. SUMMER NUCLEAR STATION, ) DOCKET NOS. 50-395 OL UNIT 1), ) and APPLICANT ) 50-395 A PERSONALLY-APPEARED before me, James M. "Bubba" Lyles, III, who, being duly sworn, says:

1. That he resides at 202 Carlisle Street, Winnsboro, South Carolina, with his wife and three minor children, at a distance of aporoximately 15 miles frem the Virgil C. Summer Nuclear Station, Unit 1. He was born and has lived in or near Winnsboro, Scuth Carolina, since his birth 35 years ago.

2. That he owns the above premise where he resides and is part-owner and Vice-President of Winnsboro Builders Supply, Inc., S. Vanderhorst Street, Winnsboro, South Carolina, a wholesale ared retail business selling hard-ware and building supplies, which business is his principal emoloyment l

and source of inccme.

3. That he and his family live, work and engage in outdoor recreational activities throughout Fairfield County, South Carolina, including areas in close oroximity to the Virgil C. Summer Nuclear Station, Unit 1. He and his family grow vegetables and consume pr; duce grcwn in a garden at Winnsboro, South Carolina.

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4 That he and his family are residential electric customers of the Town of Winnsboro.

5. That he is a member of Fairfield United Action and has been active in the organization since about September 1980. That through his parti-cipation in the programs of the organization he has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Sumer Nuclear Station, Unit 1.

6. That he is infonned and believes that the grant' of an operating license to South Carolina Electric & Gas Company and the operation of this facili-ty will result in direct hann to the health, safety, and economic interest of himself and his family.

7. That he is further informed and believes that his interest in this matter can only be prctected through participation in this operating li-cense proceeding, and that his interest will not be adequately represented by any of the present parties to the proceeding. He authorizes Fairfield United Action, or its representative, to protect the interest of himself and his family in this matter through participation in this proceeding.

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Kmes M."Buooa" Lyles, III SWORN to and subscr,1 bed before me this .Mday of March 1980.

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' ,- P:.' (L.S.)

N0iaRY PUBLIC FOR SOUTH CAROLINA My comission exoires: /h ..t :Q, ' / 77'

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, PETITIONER '

)

In the Matter of ) AFFADAVIT

)

SOUTH CAROLINA ELECTRIC & GAS )

COMPANY, ET AL. ) DOCKET N05. 50-395 OL (VIRGIL C. SUMMER NUCLEAR STATION, ) and UNIT 1), ) 50-395 A APPLICANTS )

PERSONALLY APPEARED before me, Janet H. Greenhut, M.D., who, being duly sworn, says:

1. That she resides at 209 W. High Street, Winnsboro, South Carolina, together with her husband, at a distance of approximately la miles from the Virgil C. Summer Nuclear Station, Unit 1. She has lived in Winnsboro, South Carolina, since April 1980.

2. That she owns the above premise where she resides.

3. That she holds a Doctor of Medicine degree from Wayne State Univer-sity in Detroit, Michigan, and has practiced community-based medicine in Fairfield County, and has educated herself about the health effects of radiation exposure.

4 That she and her husband live, work, and engage in outdoor recreation-al activities througnout Fairfield County, South Carolina, including areas in close proximity to the Virgil C. Sunner Nuclear Station, Unit 1.

She and ner husband grow vegetables and consume produce grown in a garden at their residence.

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5. That she and her husband are residential electric customers of the Town of Winnsboro.

6. That she is a member of Fairfield United Action and has been active in the organization since about October 1980. That through her partici-pation in the orograms of the organization she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Summer Nuclear Station, Unit 1.

7. That she is informed and believes that the grant of an operating license to South Carolina Electric & Gas Company and the operation of t.kis facility will result in direct physical harm to the health, safety, and economic interes t of her and her husband.

8. That she is further informed that her 16terest in this T.atter can only be protected through participation in this operating license pro-ceeding, and that her interest will not be adequately represented by any of the present parties to the proceeding. She authorizes Fairfield Uni-ted Action, or its representative, to protect her interest in this matter through participation in this proceeding.

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Janet H. Greenhut, M.D.

SWORN to and subscribed before me this ff...m. day of March 1986.

(L.S.)

NOTARY FU5 LIE t0R 50Uid. CAROLINA My commission expires: / su /--, . , ,' y

e UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

PETITIONER )

In the Matter of AFFADAVIT

)

SOUTH CAROLINA ELECTRIC & GAS ) DOCKET N05.;50-195 OL CCMPANY, u AL.

(VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1), 50- 95 A

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)

APPLICANTS PERSONALLY APPEARED before me, Maryam Shareef, who does affinn and says:

1. That she resides at Rt. 3, Box 99, Winnsboro, South Carolina, on Road 48 in Fairfield County, South Carolina, together with her mother and seven minor children, at a distance of approximately 8 miles from the Virgil C. Sumner Nuclear Station, Unit 1. She has lived at this residence for nout 5 years.

2. That she lives on family land of about 90 acres held in her mother's name and she is employed by the State of South Carolina.

3. That she and her family live, work, and engage in outdoor recreation-al activities throughout Fairfield County, including areas in close proximity to the Virgil C. Sunner Nuclear Station, Unit 1. She and her family grow vegetables for personal use and for sale to others and con-sume produce grown on their land. She and her family keep approximately tw91ve chickens and consume eggs from those chickens. She and her family keep 11 milk cows and both consume some milk U# those cows and eat meat from animals slaughtered from that herd. She and her family keep a horse.

4. That she and her family are residential electric customers of the -

Fairfield Electric Cooperative.

5. That she is a member and on the Board of Directors of Fairfield United Action, Secretary of Greenbrier United Action, and has been active in the organization since about April 1980. That through her partici-pation in the programs of the organization she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Summer Nuclear Station, Unit 1.

6. That she is infonned and believes that the grant of an operating 11-cense to Su sth Carolina Electric & Gas Company and the operation of this facility will ;esult in direct physical hann to the health, safety and economic interest of herself and her family.

7. That she is further infonned that her interest in this matter can only be protected through participation in this operating license proceeding, and that her interest will not be adeouately represented by any of the present parties to the proceeding. She authorizes Fairfield United Action, or its representative, to protect the interest of herself and her family in this matter through participation in this proceeding.

/ A dilC W. / / .-/

Maryam Shareef '

, 7 AFFIRMED and subscribed to before me this ' - day of March 1980.

.'/ <7 7' '

(L.S.)

NOURY PUBLIC FOR SOU'TH CAROLINA My comission expires:

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

PETITIONER )

)

In the Matter of ) AFFADAVIT

)

SOUTH CAROLINA ELECTRIC & GAS )

COMPANY, ET AL. ) DOCKET NOS. 50-395 0; (VIRGIL C. SUMMER NUCLEAR STATION, ) and UNIT 1), ) 50-395 A APPLICANTS )

PERSONALLY APPEARED before me, Cora P. Jackson, who, being duly sworn, says:

1. That she resides at Rt. 2, Box 16, Blair, South Carolina, on Road 99, together with her husband, 2 minor children, an adult daughter, and two minar children kept during the days, at a distance of approximately 9h miles from the Virgil C. Summer Nuclear Station, Unit 1.

2. That she owns the above premise in which she resides and two acres of

(

land on which it stands together with a store which she owns, which busi-ness sells general merchandise, primarily food items, to local community members. Her principal employment is as a nurse's aid in a convalescent center in Newberry, Newberry County, South Carolina, approximately 24 miles from the Virgil C. Summer Nuclear Station, Unit 1.

3. That she and her family live, work, and engage in outdoor recreation-al activities throughout Fairfield County, including areas in close proximity to the Virgil C. Summer Nuclear Station, Unit 1. She and her family grow vegetables and consume produce grown in a garden at her resi-i dence. ,

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. .2 -

4 That she and her family are iesidential electric customers of New-berry Electric Cooperative.

5. That she is a memeer and member of the Board of Directors of Fairfield United Action and Co-chairperson of Blair United Action and has been ac-tive in the organization since about April of 1980. That through par-ticipation in the programs of the organization she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Virgil C. Summer Nuclear Station, Unit 1.

6. That she is informed and believes that the grant of an operating li-cense to South Carolina Electric & Gas Company and the operation of this facility will result in direct physical harm to the health, safety and economic interest of her and her family.

7. That she is further informed and believes that her interest in this matter can only be protected through participation in this operating li-censing proceeding, and that her interests will not be adequately repre-sented by any of the present carties to the proceeding. She authorizes Fairfield United Action, or its representative, to protect the interest of herself and her family in this matter by participating in this proceeding.

• /1 l <s ( ~ ;-

Cora P. Jackson SWORN to and subscribed before me this - " ' day of March 1980.

NOTARY PUBLIC FOR SOUTH CAROLINA My cocinission exoires: 4.u _ (+ . .' ' f 9 ,-

STATE OF SOUTH CAROLINA )

) VERIFICATION COUNTY OF RICHLAND )

Before me personally appeared John C. Ruoff, who does affirm and says that he is the authorized representative of Fairfield United Action; that he has been duly authorized to be the official representative of the above-named petitioner in this proceeding; that in his capacity he has knowledge of the facts and matters herein contained; that he has read the foregoing Petition to Intervene and Request for Hearings and Supplement and that to the best of his knowledge and belief, the matters stated herein are true and correct.

ri Af

, John C.

. 4/

Ruo f.f. , , -

AFFIPJ1ED and subscribed .- ; T,"cy,N before tc.e on this .13 day of '

March 1981. 3 ' 0007 n p,g- .!

, . A =

$ 0 0$f e F" nmc m.ss m ,

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NOTAP.Y PUBLIC FOR SOUTH CAROLINA ,

My Commission Expires ~',-?" ,

.. sr Nd' NCTICE FOR SERVICE UPON PETITIOMER No.tice is hereby given that pursuant to S2.703 of the Rules of Practice, service upon the aforesaid petitioner shculd be made upon the undersigned John C. Ruoff at the fol-lowing address:

John C. Ruoff P.O. Box 96 Jenkinsville, SC 29065

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )

Petitioners, )

)

In the Matter o#: )

)

SOUTH CAROLINA ELECTRIC AND GAS )

COMPANY Docket No. 50-395 A

)

(Virgil C. Summer Nuclear Station, )

Unit 1), )

Applicants. )

)

AFFADAVIT OF SERVICE PERSONALLY appedred before me, John C. Rucff, who duly affirmed that copies of " Petition to Intervene and Request for Hearings" in the above-captioned matter were served on the following persons by deposit in the United States mail, first class postage pre-paid, this 9th day of April 1981.

Chairman Ahearne Jerome Saltzman, Chief Office of the Commission Utility Finance Branco U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Commissioner Gilinsky Hugh P. Morrison, Jr., Esq.

Office of the Commission Charles S. Leeper, Esq.

U.S. Nuclear Regulatory Commission Michael Rand McQuinn Washington, DC 20555 Cahill, Gordon & Reindel 1990 K Street, NW, Ste. 650 Commissioner Hendrie Washingto6, DC 20006 Office of the Commission U.S. Nuclear Regulatory Commission Mr. P.T. Alien Washington, DC 20555 Executive Vice-President and General Manager Commissioner Bradford Central Electric Power Cooperative Office of the Commission P.O. Box 1455 U.S. Nuclear Regulatory Commission Columbia, SC 29202 Washington, DC 20555

Robert Fabrikant, Esq. Wallace E. Brand, Esq.

Donald A. Kaplan, Esq. Edward E. Hall, Esq.

Janet R. Urban, Esq. Brand & Hall -

P.O. Box 14141 1523 L Street NW Washington, DC 20044 Washington, DC 20005 Robert Medvecky, Esq. Joseph Rutherg, Esq.

Reid & Priest Frederic D. Chanania, Esq.

1111 19th Street NW, Ste. 1100 Office of Executive Legal Director Washington, DC 20006 U.S. Nuclear Regulatory Commission Washington, DC 20555 dohnC.Ruoff [

AuthorizedRepresen[tative Fairfield United Action P.O. Box 96 Jenkinsville, SC 29065 AFFIRMED and subscribed before me this day of I

April 1981.

h L.S.)

NDTARYIb8LICFORSOUTHCAROLINA My Comission Expires I-R B-- S'7 a