ML20003D660
| ML20003D660 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/23/1981 |
| From: | Ruoff J AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-A, ISSUANCES-OL, NUDOCS 8103300179 | |
| Download: ML20003D660 (71) | |
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occwr UNITED STATES OF AMERICA SE MAR 6 OOI >
NUCLEAR REGULATORY COMMISSION 7- ~3 c% g '
% kur;Ygy^,7 tranch Si Ex Parte: FAIRFIELD UNITED ACTION, ) Y &
g Detitioner, )
Docket Nos.
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In the Matter of: 50-395 OL e
- S SOUTH CAROLINA ELECTRIC AND GAS ) and COMPANY, ET AL. ) *
(Virgil C. Summer Nuclear Station, )
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Applicants. )
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PETITION TO INTERV?.NE AND REQUEST FOR HEARINGS Fairfield United Action, on its own behalf, on behalf of its mem-
%rs, and on behalf of others who are similarly situated, hereby peti-tions for leave to intervene in the above-captioned operating license and anti-trust review proceedings as a party of record, requests that public hearings be conducted at which it will be afforded an opportun-ity to be heard and requests this Application for an Operating . License
.be denied.or be so conditioned, as Petitioner will hereaf ter demonstrate, in order that the operation of the facility will be consistent with the terms of the anti-trust laws of the United States and with the protec-tion'of the health and safety of the public. In support of this Peti-tion and Request for Hearings, Fairfield United Action would respect-fully show:
- 1. That Fair?ield United Action is a not-for-profit membership organization incorporatad under the laws of the State of South Carolina T810 330 0 M G
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on September 5,1980, with its principal offices at Jenkinsville, Fair-field County, South Carolina. It was organized for the purpose of pro-tecting the health, safety and welfare of residents of Fairfield County and neighboring communities. Its members include persons who live, work and are actively involved in civic affair; 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 mem-bers. of Fairfield United Action are consumers of energy for residen-tial, recreational and business uses. All now purchase electric energy from commercial sources and would make use of energy sources which are
- reasonably interchangeable with electricity such as solar, wind, bio-mass, and. conservation techniques if such energy sources were more easi-
' ly available and competi tively priced. Petitioner's members include retail electric customers of South Carolina Electric & Gas Company, the Town of Winnsboro, Fairfield Electric Cooperative, and Newberry Electric l l Cooperative. -Fairfield United Action's membership includes.
shareholders of South Carolina Electric & Gas Company common stock.
- 3. Through participation in the program of Fairfield United Ac-tion, its members have educated themselves on: matters relating to the
- l. , design, construction, and the probable' effects on them, their families and the environment of the' operation of' the Summer Nuclear Station.
- . 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 desigr , construction and probable effects of operation of the Sunmer Nuclear Station which information 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 Application for Operating License in 1977 had knowledge that they had interests which i 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 April 18 , 1977, by the SecretaryLto the Commission.
- 4. That as a result of their participation in fairfield United Action Petitioner's members are informed and believe that the grant of an operating license to South Carolina Electric & Gas Company and its-operation of the V# /gil C. Summer Nuclear Station, Unit 1, will result in direct physi. al harm to tne health and safety of themse. as and their families and in direct injury to their economic interest.
- 5. That although Petitioner's members learned tnat the operation of the Summer Nuclear Station might adversely affect them. they remained unaware'of the rights and remedies available to them. Until about mid-L February:1981, Petiticner was informed and believed that it had no right 7
to participate as a party to this proceeding since the deadline for in-7.
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4 tervention had passed in May 1977. It was further informed and celiev-ed until then that its interests were being represented, to some ex-tent, by the existing Intervenor Brett Allen Bursey. Abcut mid-Feb-ruary 1981, Petitioner was informed of a letter dated February 10, 1931, from counsel for the Applicant to the Licensing Board asserting that Intervenor Bursey was precluded "from putting on any witnessas or exhib-its on his six admitted contentions," from raising any contentions re-lated to post-Three Mile Island requirements already addressed by Com-mission Staff, and that the Intervenor should 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.
Petiticr.er is further inforced that significant regulatory changes adocted by the Commis.sion in light of the lessons learned from the ac-
- cident at Three Mile Island, Unit 2, substantially expand the remedies available in an operating license proceeding beyond those available at the time of the filing of this Application in 1977 and that as to those matters as-well good cause exists .fo: Petitioner's failure to file un-til this time.
The ability of Petitioner's to inform themselves of developments i in this proceeding has been severely hampered by the aoserce of a local
. public ' document room in Fairfield County for several years. Peti tioner
, as informed.that what filir.gs exis were moved by the Applicant to the
- Richland' County Public Library in Columbia some twenty-five. miles from l
the plant, where inadequate shelf space and work space is available for i
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- ~5-j effective use, wnere the Applicant itself is responsible for maintaining the documents, but has left materials coopened and unfiled dating back several months, and where the library has c>ncelled 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 4
materials in South Carolina.
Petitioner believes that it has consistently exercised all due dili-t 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 members from harm to. their health and safety 'nd from injury to their economic interests can only be protected throug. 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-i 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-1 ticipation is now narrowly limited. The Applicant's interest is believed to be adverse to Petitioner's.
-7. That Petitioner is .infonned 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 upon which to reach i
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a reasoned and informed decision in this matter. That by reason of their
-life-long residence in proximity to the plant-site, Petiticner'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
. offe ing 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 number of issues the contentions sought to be litigated by Petitioner are no broader in scope than the issues already joined by contenticns raised by the existing Intervenor and issues raised by the Commission Staff and the Advisory Committee on Reactor Safeguards; and that the full and thorough litigation of these ' issues by Petitioner will not delay the
. proceeding any more than if fully litigated by other participants, but for the default of the existing Intervenor. As h the other issues raised by Petitioner, 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
application. Petitioner is prepared to cooperate with the Applicant, the Staff and the Licensing Board in the adoption of measures designed to expedite 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-plitants and their joint ownership and operation of the Virgil C. Summer Nuclie ar 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 application for the operating license or the conditioning of such license on such terms as are necessary to minimize adverse anti-trust impacts.
Petitioner .is informed 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, to acquire and maintain monopoly 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 cooperatives 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 such alternatives because of such conduct. The acts of the Applicants
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1 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 legislatis. and regulatory authorization for I joint ownership of the Summer Nuclear Station through the unla" a and improper manipulation of the state legislative and regulat ,.; cesses.
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 membership likely to result from the_ Applicants' conduct and the approval of the operating license application.
- 10. That based upon 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 participation in this proceeding.
WHEREFORE, having set forth its interest which will be affected in this proceeding, having shown good cause, and having submitted the contentions sought to be litigated and the' bases therefore in the Sup-plement hereto and .the Affadavits of eight of its members, which Sup-plement and Affadavits are incorporated herein, Fairfield United Action
respectfully requests leave to intervene in these proceedings, the con-duct of hearings and the denial of this application for an operating license onless so conditioned as to prevent injury to Petitioner's health, safety and economic interests.
Respectfully submitted, John C. Ruoff P.O. Box 96 0;/{'j f
Jeninsville, SC 29065 803,345-3514 AFFIRMED and subscribed to before me this.23 day of March 1981.
v (LO)
NOTARY PUBLIC FOR SOUTH" CAROLINA My Commission Expires //-/7-9d L
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )
PETITIONER ) SUPPLEMENT
) TO In the Matter of ) PETITION TO INTERVENE
) AND SOUTH CAROLINA ELECTRIC AND GAS ) REQUEST FOR HEARINGS COMPANY ET AL. )
(VIRGIL C. SUMMER NUCLEAR STATION, )
UNIT 1), ) DOCKET NO. 50-395 OL APPLICANTS )
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Under provisions of 10 CFR 2.714(a)(3)(b) Petitioner herewith submits as-a Supplement to' Fetition to Intervene and Request for Hearings a list of the contentions which it seeks to have litigated in this proceeding together with the basis for each such contention,
. reserving fully its right to amend and make additions to this Sup-plement prior to the completion of the evidentiary hearing in this-proceeding.
[ - The Petitioner asks that should the Licensing' Board construe
- any of these contentions as an attack upon any rule or ' regulation of the Commission, or any provision thereof, such rule' or regulation be
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identified and the Petitioner allowed to petition the Commission for exception. to or waiver of the application of such rule or regulation-for purposes of this particular proceeding, i
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Contenti n 1 The overall corporate management of the Applicant is insufficient-ly experienced in the operations of a nuclear power facility and is gen-erally deficient in management abilities essential to the safe operation of a nuclear power facility or properly to respond under accident con-ditions.
BASIS FOR CONTENTION 1_
The accident and response to that accident by the operators of Three Mile Island, Unit 2, amply demonstrated that the management abili-ties of the utility are crucial to safe nonnal operations and to proper response to accident conditions.
The Applicant is the first utility to come before a Licensing Board for an Operating License since TMI-2 which does not have experi-ence in the operation of a large nuclear power plant. This Apolicant's only nuclear experience was over 15 years ago with the 17 MW CVTR which it operated in consortium with .others.
In response to Staff concerns about organizational structure, the Applicant has undertaken significant steps to restructure corporate or-ganization-to consolidate corporate nuclear responsibilities under one senior corporate executive, the Vice President and Group Executive for.
Nuclear Operations.
The incumbent in that position, Thomas C. Nichols, is a long-time employee of the Applicant with-extensive' fossil plant experience. How-ever,-he has no training, background, or experience in nuclear opera-tions and is not qualified "to assure a continual understanding of plant
. o coriditions and safety considerations" (NUREG 0694, "TMI-Related Require-men ts for New Operating Licenses ," I .B.1.2). Under cross-examination in proceedings before the South Carolina Public Service Commission (Docket Nos. 79-196-E and 79-196-G), Nichols demonstrated a serious lack of understanding of technical issues relating to nuclear power opera-tion. He lacks the detailed knowledge and experience required to make informed decisions critical to the health and safety of the general pub-lic.
Examination of the resumes of nuclear operations personnel in the FSAR reveal serious deficiencies in the education, qualifications, and experience of management and operations personnel when compared to the Guidance Positions set forth in NUREG 0731 (" Guidelines for Utility Management Structure and Technical Resources"). Plant Manager Ollie S. Bradham does not hold either a bachelor's degree or an SR0 license.
Maintenance Supervisor Steve Smith does not possess the bachelor's de-gree called for there. The examples are numerous (see T.C. Nichols,
" Comparison of Management / Technical Resources to Regulatory Guidance,"
report to NRC Staff, January 31,1981). In comparing the education and experience of his staff to regulatory guidance, Nichols argues that the guidance for the Training Manager is met because Training Manager B.T. Estes, Jr. , and his deputy Al Sanders, if taken together, meet the regulatory guidance.
l Other persons with eminent qualifications hold positions for which those qualifications are irrelevant or insufficient. Mark Whitaker, Grcup Manager for Licensing and Nuclear Engineering, has held a number of responsible posts with the Applicant. He is a lawyer and an M.B.A.,
as well as a trained Electrical Engineer. However, he lacks the back-ground in nuclear engineering and nuclear operatiens adequately to super-vise the corporate Nuclear Engineering function. Likewise Emergency Coordinator, Ken Beale has extensive experience in Health Physics. How-ever, he has neither experience nor training in emergency planning.
At a number of critical positions, the Applicant has appointed ex-perienced and qualified assistants to a number of these unqualified mana-gers. That is laudable, but leaves the responsibility for decisions to men not qualified "to assure a continual understanding of plant con-ditions and safety considerations."
Examination of the management and tec' tical resources of the Appli-cant should extend beyond the scope of NUREG 0731 into the upper eche-lons of corporate management. Examination of senior corporate officials would reveal that they lack the experience and understanding of nuclear operations required to oversee and be involved in the normal or accident-condition operation of the Summer plant. No Operating License should be granted until responsible corporate management and operations posi-tions are filled by qualified individuals.
Hearings in other proceedings involving the Applicant (SCPSC Docket Nos. 79-196-E, 79-196-G, and 76-645-E) have raised serious questions about the general . management of the. Applicant. Evidence presented in those hearings suggests that the Licensing Board should have little faith in corporate procedural manuals as establishing effective administrative
. controls.
The Board has indicated its desire to have sanior corporate of-
ficials available during tre Operating License hearings. Petitioner would offer to build a recoi d on these issues through cross-examination of those witnesses as well i.s through discovery of recent studies of the Applicant's coorpordte operations referenced in other proceedings or which Petitioner is informed and believes to exist.
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j Contention 2_
The Applicant lacks sufficient " hands on" experience cmong its i reactor operator staff to safely run the Virgil C. Summer Nuclear Station, Unit 1, and no Operating License should be granted until adequate
" hands on" experience is had by the Applicant's reactor operations staff.
BASIS FOR CCNTENTION 2 During a July 8-10 visit by Staff members, Staff expressed major
- concern to the Applicant that "There appeared to be insufficient hands-
. on operating, experience with large pressurized water reactors in the operating organization (see SER at 22-13,16).
Examination of the resumes of Reactor Operators, Senior Reactor
- Operators, and Shift Supervisors reveals a. dearth of experience on large i
operating PWRs. A number of the SR0's total nuclear power plant ex-perience has been spent in training at the Virgil C. Summer Nuclear Sta-tion, Unit 1, with some additional simulator time.
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Contention 3 The Applicant lacks the financial qualifications necessary to safely operate and decomission the Sumer station in compliance with NRC rules and regulations.
BASIS FOR CONTENTION-3_
The Applicant's " Response to Request for Additional Financial Infor-mation," dated 12/31/80 makes clear that the Applicant still has no no-tion what decomissioning costs will be for the Sumer station (Response to Question 2). The proposed study of these costs has not been cam-pleted and Apolicant makes no claim that it will be completed in time for the Licensing Board to consider it.
- Applicant asserts that the anticipated costs of decomissioning "will ultinately be allowed to be recovered in the rate process," but offers no basis for that assumption.
Applicant has failed entirely to 'present evidence on its ability to safely maintain a spent fuel facility beyond the design life of the plant, despite the fact that no alternate facility for either temporary or perma-nent storage of Applicant's irradiated fuel assemblies is currently avail-able to the. Applicant. Assurances that a " political solution" will be found are-insufficient to insuring the health and safety of the public should the Applicant find itself unable to meet its financial obligations in that regard.
Applicant's presentations on Estimated. Annual Operating Costs fail to take into account potential major repair and/or replacement cost:, such as can reasonably.be expected for a' PWR with Westinghouse steam generators.
e 2 Contention 4_
The Applicant lacks the financial qualifications necessary to with-stand the costs of various contingencies, including extended shutdowns of the reactor caused either by problems arising at the Summer reactor (up to a maximum of a TMI-type accident) or by generic problems similar to those which have arisen at existing reactors and which have caused shutdowns at other reactors potentially subject to those problems.
BASIS FOR CONTENTION 4 The Applicant, South Carolina Electric & Gas Company, has com-mitted itself over the past decade to a program of construction which has required considerable financing. To finance the Summer station, the Applicant has incurred long-term debt of almost $673 million (SCE&G Annual Report, 1979, p. 21). The equity ratio for the Company described by Executive Vice President for Finance Oscar Wooten during the last rate proceeding before the South Carolina Public Service Commis-sion was only 36.3 % (common equity / capitalization), short of the goal of 40% which '"should be the objective of any prudently managed utility i
... " (Wooten, pre-filed testimony contained in " Response to Request for Financial Information," p.12). At that same place, Wooten notes that "In. light of the incident at Three Mile Island, a 40 % equity ratio
+ may soon be considered to be insufficient."
]
The Applicant, South Carolina Electric & Gas Company, lacks the j debt structure which would permit it to weather an extended shutdown or
'the costs of repair and cleanup from a TMI-type accident or worse. Even the costs of repairs or replacements to the steam generators because of
, the_ generic design problems of Westinghouse steam generators are likely 4
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to be more than the Applicant would be aule to bear. However, experience ;
suggests that such costs are not unreasonable to expect.
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Contention 5, Preliminary monitoring of seismicity in the vicinity of the Sumer plant suggests that an earthquake may already have occurred at the plant site which exceeded the Operating Basis Earthquake and equalled the Safe Shutdown Earthquake in the high frequency ranges which produce plant damage. Under such a circumstance, no Operating License should be granted.
BASIS FOR CONTENTION 5_
1 On August 27, 1978, a seismic event. produced a strong motion record I
of 0.25g peak horizontal compcnent for the 180 degree component. The ;
, Operating Basis Earthquake acceleration for the Summer plant is 0.15g i and the safe shutdown earthquake acceleration is 0.25g for structures founded on soil. (See discussion in SER, NUREG 0717, pp. 2-27 ff.)
- These high acceleration values resulted from the largest earth-quake yet measured at the-Monticello Reservoir (M(= 2.8). The Staff anal-ysis in the.SER states
- "there is no reason to believe that the largest earthquake induced by the Monticello Reservoir has already occured . . ."
(p. 2-31)~ .
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1 I Contention 6_
The studies conducted to date by the Applicant do not present suf-ficient data upon which to base a conclusion, which can be assigned a high level of confidence, that seismic activity in excess of the design basis of the Sumer plant will not occur in the imediate vicinity of the plant. Seismicity at the Summer plant should be monitored for a period of ten years from filling of the Monticello Reservoir and no Operating License should be granted until that monitoring study is com-pleted and reviewed for adequacy. Part of that monitoring study should involve a test unloading of the Monticello Reservoir to determine the seismic effects of such an occurrence.
BASIS FOR CONTENTION 6_
The Applicant has proposed that the maximum earthquake which can be expected to occur in the region of the Summer plant is of magnitude ML = 4.0. The Staff has proposed two different levels of maximum earth-quake magnitude, M = 4.5 and M = 5.3. Either level could generate high L L frequency ground motions in excess _ of SSE.
Applicant's consultant, Dr. Sheldon Alexander, admits: "First, I'll say up front we nave no precise probability that one can defend based on l all the data taken together (that the maximum magnitude will be M L
= 4.0)"
(Transcript, ACRS Subcomittee on Electric Power, February 26, 1981, pp.
84 05). The consultants to the ACRS Subcomittee noted in their comments on presentations by Staff and Applicants that there was insufficient data available (Isid., pp. 297-305).
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l Specific issues on which insufficient data has been assembled in-clude. an adequate definition of all the structures within a reasonable radius of the plant, the stresses at depths greater than 1-2 km, and the effects of unloading .the reservoir.
Seismic events at other reservoirs, s'ich as Clark Hill Reservoir (8/2/74), Lake Jocassee (8/25/79), and Oraville, California, suggest that seismicity related to reservoirs may not develop for several years af ter ' filling. Three years of monitoring is insufficient.
Further, the 1966 Indian earthquake, which occured in a region whose seismicity could'have been described in. terms similar to those advanced by 'the Applicant for the Monticello Reservoir, argues that proceeding on the basis of insufficient data is not consistent with protecting the health and safety of the general pullic.
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Contention 7 The Emergency Response Plans of the Applicants, the surrounding counties, and the State of South Carolina do not provide reasonable assurance that cdequate protective measures can and will be taken in the event of a radiological emergency and do not conform to the require-ments of NUREG 0654, Rev.1, in that:
a) (II.B.1'.) The Applicants plan does not meet the minimum staffing requirements as set forth in Table B-1.
b) (II.B.9.) The Applicants's plan includes agreements with local organizations which fail to delineate the authority, responsibilities, and limits on their actions.
c) (II.E.1.) The Applicants have failed to demonstrate the ability to notify local Emergency ' Preparedness officials, as distinguished frcm communications centers, within 15 minutes.
d) -(II.G.1.) The Applicants have not adequately planned for the distribution of informational materials.
e) (II.J.8 and Appendix 4.) The Applicant has not developed re-alistic estimates of evacuation times and has not employed the metho-dology -set forth in Appendix 4.
f) (II.J.10.c.) The Applicants have failed to provide adequate means for protecting those whose lack of mobility is impaired by lack of vehicles.
g)~ (II.J.10.e.) No plans have been made for the distribution and use of radiocrotective drugs, such as Potassium Iodice, as a Protective Response for the general public.
I h) (II.J.10.h.) Relocation centers are not located at least 5 i
i miles from the Plume Exposure Pathway EPZ, e.g. , Winnsboro High School l is a scant 2-3 miles from the EPZ. All of the relocation centers in Fairfield County are within 10 miles of the EPZ.
- 1) (II.J.10.) Table 6.2 in Applicant's Plan suggests that shel-tering is the only Protective Action contemplated for the general pub- ,
lic.
j) ((II.J.10.M.) The plans do not set forth the bases for the choice of recommended Protective Actions from the plume exposure path-way during emergency conditions.
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k) (II.L.1.) Hospital and redical services for the general pub-lic are not provided for.
- 1) (II.L.2.) On-site emergency first aid capability is inadequate.
m) (II.G.3.b.) The News Media Center is not located at the l Applicant's Emergency Operations Facility.
n) (II.H.2.) The Interim Emergency Operations facility does not comoly with'the. requirements of NUREG 0696, Rev. 1.
n) (Appendix 2.) The Applicant's meteorological monitoring equip- ,
- ment does not meet the requirements of Appendix 2. It lacks a viable back-up system with emergency-power and is not seismically qualified.
o) (Appendix 3.B.2.) The Applicant has failed to demonstrate that its siren system will meet the reouirements of Appendix 3, that
. the tests conducted by the Applicant on audibility were sufficient, and
!. that the siren system to be installed has a high level of reliability including under seismic conditions which might occasion a radiological c
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p) (Appendix 4.) The Applicant has failed to comply wi+.h the
! requirements of Appendix 4 for determining and describing evac, tion times, has failed to establish the acceptability of criteria used to .
establish evacuation times, and has failed to demonstrate the capabili-
- ty of Applicant and State and local governments to assure timely evacu-ation under accident conditions.
q) Applicant's and local plans demonstrate a lack t' cooperation in their development and planned implementation.
r) The Plume Exposure Pathway EPZ boundaries established in local plans are not based upon reasonable criteria which have been explicitly stated and demonstrated.
s) The failure to base Plume Exposure Pathway EPZs on rational and scientifically defensible bases which give reasonable assurance that the health and safety of the general public will be protected exposes students at Kelly Miller Elementary Schoci and Greenbrier Head Start Center in Fairfield County to unwarranted risks to their health and safety.
t) And in other ways the Radiological Emergency Response Plans of the Applicant, the State of South Carolina, and the surrounding counties fail to comply with the requirements set forth therein.
BASIS FOR CONTENTION 7 Petitioner and itsmembers possess unique knowledge of the people, i roads, traffic patterns, and topography of Fairfield County and nearby communities and would assist the Licensing Boardstl0 build a record on l ' the adequacy of emergency planning for the region.
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In addition to bases offered in the statement of the contention, Petitioner would show that: (bases are listed by sub-contention letter) a) Applicant's Table B-1 sets forth that Applicant would be un-able to provide back-up support for several functions within the re-qtdred thirty minutes. That the Chemistry / Radiochemistry function would rot be staffed at all times, d) Applicant plans only to mail informational materials to every postal holder. Many mail addresses in the area serve several house-holds, so that a single " Occupant" mailing to each postal box would r,ot reach every household. Posting of informational materials in local businesses will not sufficiently supplement inadequate mailings. Ad-ditional distribution methods should be required.
k) Arrangements for medical services at the Pinner Clinic in Parr, South Carolina, and Richland Memorial Hospital in Columbia, South Caro-lina, apparently apply only to employees of the Applicant and not to the general-public.
- 1) Applicant's plan calls for only one person qualified in first aid techniques on each shift. Injury to that person or accident con-ditions requiring first attention to accident control duties could nullify that capability.
n) The Interim Emergency Operations Facility is located on-site.
The facility is a temporary office structure which is not engineered for the design life of the plant, does not provide a protection factor equal to or greater than 5, and lacks adequate ventilation protection as' required in NUREG 0696, Rev.'1, Table 2.
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c' For example. All persons in Fairfield County are expected to evacuate to Winnsboro High School. Under typical wind conditions, that would be the least appropriate response for the majority of persons in the EPZ in Fairfield County. Those in the southern part of the County
) would be safer evacuating towards the Richland County facility. Those in the northern part of the EPZ would more wisely evacuate to the Newberry County center. No such coordinaticn exists, however. ,
s) Young persons are especially susceptible to radiation injury. '
However, the Plume Exposure Pathway EPZ, which extends to nearly 12 miles just norti, of Kelly Miller School in Fairfield County, swings in to *
- miss including that school in the EPZ by, quite literally, " shouting distance". Kelly Miller is an all-black elementary school. The Green-brier Head Start Center is located nearby and also withir. view of the EPZ but ntt included in it.
! t) Final plans have not been available to Petitioners from the
, four counties and the State of South Carolina.
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I Contention 8 Public Information Materials distributed by the Applicant relative to radiological emergency response planning are inaccurate, intentionally
- deceptive regarding the potential health effects of radiation, and pre-sent evacuation routes which could result in persons unwittingly evacu-ating through the plume.
BASIS FOR CONTENTION 8 The brochure entitled "V.C. Summer Emergency Information," which the Applicant says will be mailed to every household in the Plume Ex-posure Pathway, includes the following untruthful and inaccurate infor-i mation:
a) that the secondary water system in the steam li a is "uncontami-nated" and "polluticn-free";
! b) that radiation health effects can only be detected at levels of 25,000 millirems and above.
These statements and additional verbiage in the brochure are designed to give residents a false sense of security. By failing to l
accurately describe the genuine health hazards, which are recognized by the body of the ' scientific community,' the Applicant may lead residents
~
to believe that accidents with long-term health consequences are not sufficiently. important to warrant evacuation.
Further, the evacuation routes laid out in the brochure are ir-rational' and could result in individuals unwittingly evacuating through the plume. A resident of Southwest Fairfield County (Zones C-1 and C-2) is directed to drive towards Winnsboro, which is the direction the pre-vailing winds could be expected to carry the plume.
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Contention 9 The State of South Carolina and the counties surrounding the Sumer station do not have the capability for implementing protective j measures based upon protective action guides and other criteria as I
they apply to residents of the Plume Exposure Pathway who do not own or have access at all times to private vehicles, j BASIS FOR CONTENTION 9, l l
l The area within the Plume Exposure eathway is predominantly rural .,
4 and no public transportation system exists. Many of the residents of
- the area are old, sick, or poor and do not have transportation or are without transportation during significant periods of the day. Existing l
plans in Fairfield County, for example, call for the use of a) school busses when school is not in session, b) vans from the Council on Aging r and Community Action Program, or c) city busses brought in from Columbia.
y School busses in South Carolina are driven by high school students.
If school were not' in session, the drivers would not be available. The 4
, number.-of vans is limited and ' inadequate. The city busses from Columbia f
- could not arrive in time, are unsuited to many of our country roads, and
, would be-driven by drivers unfamiliar: with the many nooks and crannies-of the county.
Moreover,~ no door-to-door survey to identify the need has been under-taken. Newspaper ads were placed.in the Winnsboro papers asking people ,
- who meded transportation to_ call the Emergency Preparedness Director's of fice. , A ~ good many people in rural Fairfield < County .do not _ read. Few
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l pec;10 in western cairfield County read the Winnsboro papers. Many people in the area do not have telephone, and for many it is a long-distance telephone call to Winnsboro. tiot surprisingly, the ads drew no response.
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- Contention 10 Radiological Emergency Response plans of the Applicant, the State t
of South Carolina, and the surrounding communities have been formulated without reference to the Draft Environmental Statement, Supplement I
(NUREG 0534, Supplement) and thus fail to address appropriate protec- ,
tive measures needed to provide radiological protection to all residents ,
in the vicinity of the Summer station who might be threatened with in-4 jury or death from an accident greater than a design basis accident.
i BASIS FOR CONTENTION 10 During testimony before the ACRS Subcommittee on Electric Power j (February.26,1981), Emergency Coordinator Ken Beale conceded that no reference had been made to the Draft ES in preparing the emergency plans. ,
The first ES which evaluates the environmental impacts of a so-called Class 9 accident, this Supplement should have served as the cornerston of emergency planning. .Instead, it was ignored.
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Contention 11 The Applicant and the surrounding counties do not possess the experience and technical ability adequately to plan for emergency pre-paredness, to prepare for a radiological emergency, or the capability for implementing protective reasures based upon protective action guides and other criteria as required under NUREG 0654, Rev.1, at II.J.9.
BASIS FOR CONTENTION H The capability to plan and carry out protective measures in the event of a radiological emergency presumes the personnel with experience and training in emergency planning and an understanding of +,he characteristics of radiological effluents and their potential health effects.
The Applicant and the governments of the surrounding counties lack
, that capability.
Corporate Emergency Coordinator, Ken Beale, of the Applicant, has training and experience as a Health Phys'icist. His resume reveals neither i- training nor experience which would qualify him for his current position f
and responsibilities. His assistant, Site Emergency Coordinator, is-totally lacking in any qualifications for a role in emergency planning
.or any training beyond a brief practicum on nuclear power generation at f . an elementary level.., , ,
Fairfield County Director of Emergency Preparedness admits that he knows nothing about nuclear power or the health effects of radiation.
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- Contention 12 The Applicant and the surrounding communities lack Radiological Emergency Response plans which would permit quick and adequate response ;
to an accident involving the transportation of radioactive wastes, es-pecially irradiated fuel assemblies. Without such plans, the health and safety of the general public cannot be reasonably assured. The Ap-plicant should not be granted a license to operate the Summer plant until such plans are developed.
BASIS FOR CONTENTION g The counties surrounding the Summer station do not have plans for j responding to emergencies involving radioactive materials other than at ,
{ fixed sites. Operation of the Summer plant would require transshipment of ~ low-level wastes and, perhaps at some future date, irradiated fuel assemblies (FSAR 3.8-1 and 2).
. The counties lack the ability to respond to an accident involving such materials. No operating license should be granted the Applicant which could result in the movement of such materials until the affected counties are prepared to deal .with potential accidents.
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Contention 13 The NRC and the Applicant have failed to comply with the require-ment of NUREG 0694 IT'I.D.2.4) that 50 thermoluminescent dosimeters be placed around the site in coordination with the State and the Applicant.
The Staff should be required to demonstrate that those TLDs are capable of accurately reading Co 60 . By themselves, the TLDs are not adequate to providing emergency operations personnel with the information required to competently make the decisions required to reasonably assure the health and safety of the general cublic under accident conditions. Real-time monitors capable of reading gamma radiation levels should be required at the sites where TLDs are currently planned.
BASIS FOR CONTENTION 3 According to the SER (NUREG 0717) at 22-99, the NRC will only place 40 TL0s.
Under accident conditions, TLDs do not provide information quickly enough' to adequately assist appropriate decisica-making. Only real-time
~ monitors tied'into the Applicant's DAMS system with monitors placed at many locations and not just within 1,000 m. of the plant can provide those necessary inputs.
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4 Contention H The Applicant's FSAR fails to address the impacts of steam generator tube denting, cracking, leaking and rupturing on occupational exposure doses to employees required to conduct unusual maintenance or to replace steam generators. These occupational exposures may have been sufficient-ly understated to adversely affect the Benefit-Cost analysis conducted at the Construction Permit stages of this proceeding.
BASIS FOR CONTENTION H ;
The Summer statio1 Utilizes 3 Westinghouse Model 03 steam generators.
Westinghouse steam generators have demonstrated a generic tendency to denting, cracking, leaking and rupturing. Extensive repairs have been required at a number of plants. At Surry Power Station 1 and at Turkey Point Plant, Units 3 and 4, the effects have been so serious that the steam generators have had to be replaced.
The occupational exposure assumptions set forth in the Summer FSAR.
, (12.1-32) are based on occupational exposure experience from 1969 to 1974.
Significant steam generator tube degradation only began to evidence itself in Westinghouse steam generators in 1975. Since that has become a prob- -
lem at Westinghouse PWRs, the percentage of occupational exposure due .to
. Special Maintenance has increased from 19.0%.in 1975 to.35.9%.in 1978
- (NUREG 0618) at nuclear power plants.
NRC Staff generic estimates of occupational exposure in replacing steam generators' suggests man-rem / unit exposures of 3380-5840 (NUREG/
CR 0199). Experience at VEPCO's Surry Power Station, Unit 1, claims
. estimated exposure of. 2070 man-rem / unit and an actual exposure rate of; -
2140 man-remfunit (NOREG 0692, "FES Related to Steam Generator Repair at
Surry Power Station, Unit 1," p. 4-1). Florida Power and Light Corrpany has estimated occupational exposures of 1730-2480 person-rem / unit for replacing the steam generators at Turkey Point (NUREG 0756, "SER Rela-ting to Steam Generator Repair at Turkey Point Plant, Units 3 and 4,"
- p. 2-6,7).
Adding the assumed $1,000/ person-rem occupational exposure value to the Cost-Benefit equation is significant but inadequate. Additional costs must also be added to the equation to account for the large numbers of workers who would have to be brought in to carry out such a project, the additional wage costs of short-term employees, the social costs of their presence, and the personal costs of short-term employments which
" burn-out" workers by quickly exposing them to quarterly maximum doses.
In a letter of February 6,1981, analyzing NUREG 0743 discussion of occupational exposure hazards during the replacement of six steam
. generators at the Turkey Point Plant, Units 3 and 4, Or. Karl .Z. Morgan, Professor of Nuclear Engineering at Georgia Institute of Technology:
"I-do not believe.the VEPCO operation was carried out with only 2140 person rem. I mistrust their data." Further, "The upper dose esti-mates of 9.4 x 10 3 erson rem for the six generators will cost seve
. lethal cancers and .14 total cancers.by my esti ates. ,This is a mean
.value between the highest and lowest estimato ." (Letter, Karl Z.
Morgan to Ms. -Joetta Lorion, Floridians. United for Safe Energy, Inc.,
February 6, 1981.-)
Contention 15 The quality control of the Summer plant is substantially below NRC standards as evidenced by consistently substandard workmanship, in several aspects, during the construction of the plant.
BASIS FOR CONTENTION _15, Sworn testimony has been entered in courts and before the Public Service Comission of the State of South Carolina regarding substandard workmanship by the prime contractor Daniel International and its em-playees, paticularly in regards to welding and inspections done at the Sumer plant.
On August 31, 1979, Clarence Crider, an experienced welder, notified the NRC Atlanta Regional office of substantial substcndard welding and inspection practices by his employer Daniel International at the Sumer site. Investigation by the NRC revealed that a number of the allegations raised by Crider were true and a number of others remained unresolved (IE Investigation Report No. 50-395/79-35). Investigation of some of the allegations advanced by Crider would have required removing concrete and cement from the core pit liner area to examine welds, which Crider alleges ~was not done.
In pleadings filed in the Court of Common Pleas, of Richland County,.
South Carolina, Crider alleges that Daniels . International and its agents I
harrassed him for complaining about inadequate work, threatened his em-f ployment for reperting safety violations, slandered him,f and made attempts to murder him in order to silence his complaints about shoddy workmanship.
Numerous examples of Non-Cenformance Reports evidencing shoddy work-E
manship in several aspects were entered into the record before the South Carolina Public Service Commission. Those NCRs reveal patterns of sub-standard workmanship which were uncorrected by either the Applicant or its agent Daniel International. Concrete pours which did not meet speci-fications were left in place. Month after month, arc weld strikes were noted and formulaic " corrective action" supposedly taken to correct the errors. Unqualified welders time and again were assigned to safety-re-lated welds. Large numbers of failures by Quality Control personnel were later caught.
Conversations with employees of the Quality Control staff of Daniel International suggest that a review of QC resumes would show that short-ages of QC inspectors led to the employment of individuals who lacked the practical experience to examine welds and other craft skill products.
Turther, over-long work weeks seriously undermined the efficiency and attentiveness of QC staff.
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i Contention 16 The Applicant has failed to demonstrate that the diesel generators i which are critical to the safe shutdown and control of the reactor in d
the event of loss of off-site power are designed, constructed and ope-rated atstandards sufficiently high that they may be relied upon to
{ reasonably assure the health and safety of the general public. '
, BASIS FOR CONTENTION g Tho Sumer station employs two 12 cylinder, diesel engine genera-tors as their so"rce of emergency a-c power in the event of loss of off-site power. The FSAR cites the Joseph W. Farley Units 1 and 2 as having significant similarities to the Summer diesel generators (Table 1.3-1).
Diesel generator liability has beet a long-standing concern. An j
examination of LERs from 1969 to Septembe ?8, 1977 oroduced 610 failures and/or troubles. (NUREG/CR 0660, thancement of On-Site Emergency Diesel Generator Reliability"). e recently, a study of LERs from 1976-1978 produced 298 cases failure to start or failure to continue to run (NUREG/CR 1362, " Data Sumaries f Licensee Event Re-
! ports of Diesel. Generators at U.S. Commercial Nuc ir Power Plants.
January 1, 1976-December 31, 1978," p. 18).
NUREG/CR 1362 found-that 32% of the cases of failure to start came
~
from 4 plants, including the Farley 1 unit described as significantly
. similar to the Summer set up.
! A further examination of LERs for the past year shows numerous-diesel generator failures at the Farley station. On July 17, 1980, both diesels IC and 2C were inoperable at Farley 1.
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Contention 17 The " Draft Environmental Statement Related to the Operation of the Virgil C. Summer Nuclear Station, Unit 1, Supplement" (NUREG 0534, Sup-plement) grossly understates the probabilities of a severe Class 9 ac-cident and the consequent impact of the operation of the Summer plant on the environment.
BASIS FOR CONTENTION _1J7, The Draft ES for the Summer Plant is the first to address the impacts of an accident greater than design basis on the environment. In attempt-ing that, the Draft ES employs a probabilistic analysis which is in es-sence the same as that employed in the Reactor Safety Study (WASH 1400).
The Draft ES differs from the RSS in employing site specific data inputs to the RSS consequences model and in not-using the smoothing technique that associated the 10 percent from each side of the release categories.
Such serious issues have been raised and shown regarding the con-ceptual, methodological, statistical, and data underpinnings of the RSS that its use in licensing proceedings as a basis for decision-making is entirely inappropriate (See Statement of the NRC, January 19, 1979; NUREG/CR0400, " Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission, H.W. Lewis, Chairman," pp. vii-xi, and passim; Un-ion of Concerned Scientists, "The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400 (NUREG-75/014)," pp.
113-130).
The Lewis Committee notes in a recommendation endorsed by the Com-mission, "The consequence model used in WASH-1400 should be substantial-ly improvr1, and its sensitivities explored, before it is used in the
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regulatory process" (p. xi). Although two improvements in the methodolo-gy have been made in the Draft ES, those improvements do not overcome the ott ?r flaws in the WASH-1400 study and the probablistic estimates upon which the conclusions are based are of no probative value.
l Contention IE[
The Applicant and Staff have failed to demonstrate that the risk from an ATWS event is sufficiently reduced by interim measures prior to resolution of generic issues and Commission direction on corrective actions provides reasonable assurance that the Summer station can be operated prior to that resolution without endangering the health and safety of the public.
BASIS FOR CONTENTION 18 NUREG 0460 (" Anticipated Transients Without Scram for Light Water Reactors") set forth the Staff position that "the reliability of current scram systems cannot be shown to be adequate to meet the safety objec-tive considering the rate at which these systems are challenged by an-ticipated transients" (p. 39). The Staff position articulated in 1973, (NUREG 1270) was that the likelihood of an ATWS event was acceptably small given. existing conditions, including the small numbers of reac-tors operating in 1973. Since that time, the number of reactors has increased dramatically.
It is simply irrational and inconsistent to argue, at once, that there is a aroblem of sufficiently high risk-that changes ought to be made and that those' changes can be made down the road somewhere. Proba-balistic arguments that an event is likely to occur only once in-
. x many reactor years do cot make it any less likely that at y plant that event'will occur this year.
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Contention 20 The Applicant lacks adequate on-site storage facilities for ir-radiated fuel assemblies which would be produced during the design life of the Summer plant. The Applicant has failed to demonstrate that B
other storage and/or reprocessing facilities are or will be available to the Applicant at such time as current on-site spent fuel facilities are filled.
BASIS FOR CONTENTION 2C)
The spent fuel pool at the Summer station is designed to hold 13/3 core of irradiated fuel assemblies, approximately 10 years ca-pacity (FSAR 9.1-2,3.) In planning for the spent fuel pools, the Applicant assumed availability of other storage and/or reprocessing facilities by 1985 (FSAR 3.8-2). Such an assumption is no longer ten-able.
The most likely commercial reprocessing facility, Allied General Nuclear Services, studies suggest that reprocessing would not be a-vailable until 1990, at the earliest (" Scoping Studies of the . . .
Disposing of the TMI-2 Spent Fuel Core," AGNS 35900-1.5-79, September 1980). Recent-political decisions suggest that that schedule is too
[ optimistic.
There is little evidence of a Federal commitment to temporary or interim ' storage of irradiated fuel and " permanent" disposal appears to be decades off.
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Contention 21 The building of additional on-site irradiated fuel assembly sto-rage facilities which would store spent fuel for an indefinite period constitutes an unwarranted hazard to the safety and health of the residents of the area surrounding the station. Environmental effects of such a move should be addressed before granting of the operating license, since the need to construct such facilities may reasonably be anticipated at this time. The environmental impacts of such long-term additional storage facilities would adversely affect the positive Cost-Benefit analysis constructed at the construction permit phases of this proceeding.
BASIS FOR CONTENTION 21 Since no other storage facilities may reasonably be expected to be available to the Applicant for storage of spent fuel when current pool space is filled, then long-term additional pools will have to be constructed. In an area of uncertain seismicity, that constitutes reckless action.
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Contention j!2[
r j The transshipment of irradiated fuel assemblies on the roads and highways of the plant vicinity would constitute an unwarranted hazard
.l to the health and safety of the residents of that region. The Appli-cant has failed adequately to demonstrate the acceptability of the environmental impacts of such transshipments.
i BASIS FOR CONTENTION jj![
, Applicant proposes to ship by truck between 17 and 52 shipments of irradiated fuel each year, 73,000 pounds of highly radioactive material (FSAR'3.8).
1 Serious questions have been raised about the adequacy of spent
! fuel casks in accident conditions. The wreckage of a
- truck carrying such spent fuel on one of these country roads could result in the release of significant quantities of radionuclides to the environ-ment.
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j Contention 2_3, t
The following effects on a long-term basis have been sufficiently j underestimated by the Applicant and the Staff so as to comprcmise the validity of the favorable Benefit-Cost balance struck at the construc-
- ion phase of this proceeding.
a) The somatic and genetic effects of radiation reler.ses during normal operation, to restricted and unrestricted areas, said releases being within the guidelines and/or requirements of 10 CFR Part 20, and ;
Appendix 1 to 10 CFR Part 50.
b) The health effects of the uranium fuel cycle, given the release values of the existing Table S-3 of 10 CFR Part 51.
i BASIS FOR CONTENTION 23 P
The somatic and genetic effects of normal operation have been seriously. underestimated by the Staff and Applicant who have relied about estimates of health effects of low-level ionizing radiation s
which are too optimistic. Dr. Karl Z. Morgan of Georgia Tech and other
, have attacked the BEIR III report, for example, for seriously under--
estimating health effects. i Moreover, the studies of radionuclide uptake by plants carried t 4 ;
t out by Bernd Franke and others of the University of Heidelberg cast serious doubt on the validity of NRC food chain calculations. j J
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Contention 24, The potential impacts of systems interactions and particularly the safety implications of control systems and plant dynamics have not been sufficiently accounted for by Staff and the Applicant in their safety reviews and conclusions that the safety and health of the general public can be reasonably assured during the operation of the Summer station.
BASIS FOR CONTENTION 24 Demetrios L. Basdekis of the NRC Staff has, in a number of memoranda and appearances, addressed the inadequacy of current understanding of the safety implications of control systems and plant dynamics.
Those concerns should be addressed with specific reference to this plant.
In the ACRS study of LERs(NUREG 0572, " Review of Licensee Event Reports"), the ACRS found a number of systems interactions which only were revealed by their actually occuring. Significantly, all three of the examples given were of reactors of equivalent design to the Sum-mer reactor (Westinghouse 17 x 17).
A
Contention 25 The control room design of the Summer plant fails to take adequate note of human factors.
BASIS FOR CONTENTION 25, m
Comparison of the Summer station control room with the guidelines of NUREG/CR 1580 Draft reveals a number of def'ciencies which could lead to confusions and errors resulting in danger to the health and safety of the general public and on-site personnel.
Although some attempts have been made to analyse and address these serious deficiencies, the report prepared for the Applicant by the Essex consulting group recommends leaving a number of significant prob-lem areas for later correction in order to avoid delay.
All required changes should be made before initial fuel loading.
1
Contention 26 The hydrogen control measures in the reactor containment building are inadequate to deal with hydrogen production during an accident.
Pressures resulting from a hydrogen explosion or hydrogen deflagration could threaten the structural integrity of the containment. Purging of the containment to release some of that pressure would release unac-ceptable levels of radionuclides to the environment. Applicant should be required to install a filtered, vented containment system.
BASIS FOR CONTENTION H The accident at TMI demonstrated the very real dangers o. pro-duction during the course of any accident in which the core is un-covered. The combination of increased pressures from the steam, pres-sures from hydrogen deflagration, and a hydrogen explosion could exceed the design basis 59 psi of the containment.
If that pressure is to be relieved by purging, a filtered. vented containment system should be in place to reduce the adverse health ef-fects from venting of highly radioactive containment atmosphere to the envi ronment.
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!- A Contention 27 The Applicant lacks the technical and management resources to fulfill the post-TMI requirements set forth in NUREG 0660, NUREG 0694, and NUREG 0737.
BASIS FOR CONTENTION 27 The Applicant is a small utility, new to the nuclear field. Its
- management lacks experience in nuclear operations and its operators do not have sufficient " hands on" experience to safely run a plant.
The new requirements of post-TMI regulation have raised the skill 7
and resources level required for operation of a nuclear facility beyond the abilit.ies of the Applicant.
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f 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 (FIRGIL 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 i Highway 215, together with his wife, one minor chilo, e adult step-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. Summer Nuclear Station, Unit 1, on the edge of the Monticello Reservoir, coo'iing 4
lake for that facility ~.
- 2. That he owns the premise in which he resides and he is retired from !
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 $nd squirrels in that vicinity and consume the meat from that game. He fishes in the Monticello Reservoir
. and he and his . family consume those fish. He and his family grow-vege-v;* t,L'
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n 4 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 Directbrs 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 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 himself and his family.
- 7. ' That he is further. informed and believes th?t his interest in this matter can 'only be protected through pa'rticipation in this operating li-
' cense proceeding, and ti,at his interest will not be adequately protected by any of the present parties to the proceeding. He author'.zes Fairfield United Action, or its representative, to protect the interest of c
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himself and his family in this matter through carticipation in this proceeding.
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1 1 ,. s Robert A. Hollins S'40RN to and subscribed before me this' g' Fday of March 198d.
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" i. buu ':^ ?_ L~ t u ct : (L.S.)
NOTARY PUBLIC FOR SOUTH ,
My cocriission expires: u, CAROLINA,"'
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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 ) DOCKET NOS. 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-B, Winnsboro, South Carolina, on Highway 269 in Fairfield County, South Carolina, at a distance of approxi-mately 9h miles from the Virgil C. Summer 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. Summer Nuclear -Station, Unit 1. She grows vegetables and consumes. produce grown in a garden
- near her home and within ten miles of the Virgil C. Summer Nuclear Station, Unit. 1.
- 4. That she owns 10. shares of South Carolina Electric & Gas _ Company Common Stock.
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 N05. 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 from which he conducts his business and he is self-employed 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 from 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 -
(Docket Nos. 79-196-E and 79-196-G) involving South Carolina Electric &
Gas. Company and through that proceeding'became educated and informed
~a bout the organization, management and operation of the~ Applicant and-
-2_
- 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 April 1980. That through her participa-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. Summer Nuclear Station, Unit 1.
- 7. That she is informed and believes that the grant of an operating l license to South Carolina Electric & Gas Company and the operation of n this facility will result in direct physical harm to her health, safety 1
and economic interest.
- 8. 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 adequately represented by any of the present parties to the proceeding. She authorizes Fairfield United Action, or its representative, to protect her interest in this matter through par-ticipation in this proceeding.
Y& ff. kwd Helen A. - Barefoot f
SWORN ta and subscribed before me this day of March 1981.
s-e.
_./. /. / /.
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/bu ,'
(L.S.)
NOTARY PUBLIC F9R'50VTH CAROLINA My commission expires:
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_2 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 outdoor 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.
- 5. That he is a residential electric customer of South Carolina Elec-
'tric & Gas Company.
s
- 6. That he is a member of Fairfield United Action and has been active in the organization since 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 operating license to South Carolina Electric & Gas Company and the operation of
~
this facility will result in direct physical harm to his health, safety, and economic interest.
- 8. 1That'he is further informed and-believes-that his interest in this l matter can only be protected through-participation in this operating i
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license proceeding. He authorizes Fairfield United Action, or its representative, to protect his interest, qJ2La hnC.Ruoff ,bf AFFIRMED and subscribed to before me thid/ I ay d of March 198).
6 / (L.S.)
fMARY PUBLIC FOR SOUTH CADOLIfM My comission expires: /\ /9f/
)
UtlITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )
PETITIONER )
In the Matter of AFFADAVIT
)
SOUTH CAROLINA ELECTRIC & GAS )
(VIRGIL C. SUMMER NUCLEAR STATION, DOCKET NOS. 50-395 OL
)
UNIT 1), and
) .
APPLICANTS )00-395 A PERSONALLY APPEARED before me, Margie G. Moore, who, being duly sworn, 3ays:
- 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 approximately 7 miles from the Virgil C. Sumcer Nuclear Station.
- 2. That her family owns the premise in which she resides and 38 acres of land and that her priw pal 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 recreati)n-al actisities throughout Fairfield County, including areas in close proximity to the Virgil C. Summer Nuclear Station, Unit 1.
4 That she and her family are residential electric customers of South 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- L i 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 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 the operating li-cense proceeding, and that her interest is not adequately represented by 1
any of the present parties. She authorizes Fairfield United Action, or I
its representative, to protect the interest of herself and her family -in thi_s matter through participation in this proceeding.
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( Margie G. Moore l
SWORN to and wbscribed before me this C N day of i March 1984 i
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r c e w i(L'.S.)
l: -NOTARY PUBLIC FOR SOUTH CAROLINA
! My commission expires: /2 c o # 6 (. Y I
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: FAIRFIELD UNITED ACTION, )
- PETITIONER )
)
In the Matter of )
s ) AFFADAVIT t SOUTH CAROLINA ELECTRIC & GAS COMPANY, )
-ET AL. )
(VIRGIL C. SUMMER NUC?,t!AR STATION, ) DOCKET N05. 50-395 OL UNIT 1), ) end 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, i
, with his wife and three minor children, at a distance of approximately 15 miles from the Virgil C. Summer Nuclear Station, Unit- 1. He was born
- -_ and has lived in or near Winnsboro, South Carolina,. since his birth 35 years-ago.
- 2. That he' owns the above' premise where he resides -and is part-owner and L- Vice-President of Winnsboro Builders Supply, Inc., S. Vanderhorst Street, Winnsboro, South Carolina, a wholesale and retail-ousiness selling hard-l-
- ware and building supplies, which business is i.is principal employment and source of-income.
e_ - ,
- 3. That he-and his : family live, work and engage in outdoor recreational activities tnroughout Fairfield County, South Carolina, including areas 4
I g in close.oroximity to the Virgil C. ' Summer Nuclear Station, Unit 1~. He "c '
and his1 family grow vegetables and consume produce grown in a garden at z- -Winnsboro, South Carolina.
y
- 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 ar.d the-probable effects of the operation of the Virgil C. Sumer Nuclear Station, Unit 1.
~
- 6. That he is informed and believes that the grant of an operating license to South Carolina Electr c & Gas Company and the operation of this facili-i ty will . result in direct' 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 li-cense proceeding, and that his interest wi's not be adequately represented
- by any of the present parties to the. proceeding. He authorizes Fairf.ield i
United Action, or.its representative, to protect the interest of himself.
i
- and his familyfin this matter through participation in this proceeding.
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L James M."Bubba"-Lyles, III
~
I 'SWCRN to and'subscr,ibed L beforemethis7/M4 day of March-1988, i
.( - f,02n-ri: ./ ^',_
p , tev/ ! G.' -(L.S.)-
, : NOTARY PUBLIC FOR SOUTH CAROLINA
! My comission expires:[ met eb_t ;.'_ /77 i
f UNITED STATES OF AMERICA BEFORE iHE 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 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 14 miles from the Virgil C. Summer Nuclear Station, Unit 1. She has lived in Winnsboro, Scath Carolina, since' April 1980.
- 2. That'she owns the above premise where she resides.
- 3. That she h' olds 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 berself about the health effects of radiation exposure.
- 4. That she and her husband live, work, and engage in outdoor recreation-al' activities throughout Fairfield County, South Carolina,. including areas ir c' se proximity to the Virgil C. Summer Nuclear Station, Unit 1.
She and her 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. ' hat she is a metaber of Fairfield United Action and has been active in the organization since about October 1980. That through her partici-pation in the prograais 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, 4
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 i
this facility will result in direct physical harm to the health, safety, and economic interest of her and her husband.
- 8. That she is further. informed that her interest in this matter 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 i
!- through participation in this proceeding.
- u.0 'lleL- c 'b h
Janet H..Greenhut, M.D.
U SWORN to and subscribed before me thisynsday of March 1986.
'~ ',,.
/ c .x . a -(L.S.)
NOTARY PUBLIC. EOR 50VIH. CAROLINA .
- My commission expires
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! UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY CO MISSION Ex Parte: FAIRFIELD UNITED ACTION, )
PETITIONER )
) AFFADAVIT In the Matter of )
)
SOUTH CAROLINA ELECTRIC & GAS )
DOCKET N05. 50-395 OL
) and (VIRGIL C. SUMMER NUCLEAR STATION, )
UNIT 1), 0-395 A
)
APPLICANTS )
PERSONALLY APPEARED before me, Maryam Shareef, who does affirm 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. Sumer Nuclear Station, Uni.t 1. She has lived at this i residence for about 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 Fairf 6d County, including areas in close
. proximity to' the Virgil C. Surtner Nuclear. Station, Unit 1. She and her -
family grow vegetables for personal use and for sale to others and con
-sume produce- grcwn on their land. She and her family keep approximately-
' twelve chickens and consume eggs from those chickens. She and her family k'eep 11 milk cows and both consume some milk from 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 C'coperative.
s
- 5. That she is a member and on the Board of Directors of Fairfield i
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 informed and believes that tne 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 herself and her family.
- 7. That she is further informed that her interest in tnis matter can only be protected through participation in this operating license proceeding, and. that her -interest will' not be adecuately represented by any_ of the present parties to the proceeding. She authorizes Fairfield United Action, f!
or its representative, to protect the interest of herself and her family
,_ .in this matter through participation in this proceeding.
I j " '
/ID ? !_ l d 9 X y l/ 4 . / j
\
Maryam Shareef
(
AFFIRMED and subscribed'
- to before me this ',i day of March 1980. !
(
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/ , /
/
_/ // 7.'
, (L.S.)
F NOTARY PUBLIC FOR400TH CAROLINA My contr.ission expires:
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er- a 1- --werrv v v -- ee=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 )
COMPANY, ET AL. ) DOCKET NOS. 50-395 OL (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 ninor children, an adult daughter, and two minor 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 aLove 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-1 4
dence. -
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- 4. That she and her family are residential electric customers of New-berry Electric Cooperative.
- 5. That she is a member and member of the Board of Directors of Fai-field United Action and Co-chairperson of Blair United Action and has been ac-tive in the organization since about Aoril 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 w'll result in direct physical harm to the health, safety and economic innerest 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-I sented 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 by participating in this proceeding.
- .a -
( ,, ,1 1
/ fI .he W ~r Cora P. Jackson i
SWORN to and subscribed
' before_me 'this." day of' 4
March 198d.
t .m _, _
NOTARY PUBLIC FOR SOUTH CAROLINA My comission expires: [m_ (.u - /, f 9 9 p i
i
STATE OF SOUTH CAROLINA )
) VERIFICATION COUNTY OF RICHLAND )
l
- - 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 a
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.
'hohnC. Ruoffg.
AFFIRMED and subscribed before me on this 33 day of
' March 1981.
'& w .* ,
1 NOTARY-PUBLIC FOR SOUTH CAROLINA
- My Conmission Expires //-/?-fr
- NOTICE FOR SERVICE UPON PETITIONER I
Notice.is hereby given that pursuant to 52.708 of the l
'R lu es of Practice,-service upon.the aforesa.id petitioner should be made upon the undersigned John C. Ruoff at the fol-
- lowing address:
John C. Ruoff P.O. Box-96'
- Jenkinsville, Si? 29065
,- -, - r we . e., r. ~ , * - , + - - - .- ,er.- o-e ,e-,,. -+ # ,- * -,-.--m-%y-,. , , _ -, , 3-, ,.my y--.,r +e, --
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Petitioner, )
) Decke: Ncs.
In the Matter of: )
) a-c m=
v- e.
a SOUTH CAROLINA ELECTRIC AND CAS ) and CCMPANY, ET AL. ) 50-395 A
('lirgil C. Su=er Nuclear Station, )
Unit 1), )
Applicants. )
)
1,,..._O._,...3
- f. n 's t i r s..u PERSCNALLY appeared before ne, John C. Ruoff, who duly af firmed that copies of "?etitica Oc Intervene and Request for Hearing" and "Supplenent" in the above-captiened catter were served upon the folicving perscns by deposi: in the United S:ates ail, first class postage prepaid, this 23rd day of March 1931.
Herber: Gross =an, Esq. Chairpersen, A:cci: Safe:y and Chairperson, Atenic Saf ety and Licensing Scard Panel Licensing Scard U.S. Nuclear Regula:Ory Cc=issicn U.S. Nuclear Regula:Ory Cc=1ssica ~4ashington, DC 20535 aasnington, X. 20000 George Fischer Dr. Frank ?. Ecoper 'lic e-P res iden t & General Counsel School of Natural Rescurces Scuch Carolina Electric 5 Gas Cc:pany University of Michigan ?.0. 3cx 764 Ann Arbor, M1 15109 Columbia, SC 29202
r. Gustave A. Linenberger S teven C. Goldberg , Esq.
Member, Atc=ic Saf ety and Licensing Office of the Executive Legal Direc:cr 3 card Panel U.S. Nuclear Regulatory Cc =ission Washing:cn, DC 20535 Washingten, DC 20535 Chairpersen, Atc=ic Safety and Mr. Brer: Allen Sursey Licensing Appeal Scard Fane'. Faute 1, Box 93-C U.S. Nuclear Regula: cry Cc=ission Li::le Mountain, SC 29075 Washington, DC 20555 Joseph 3. Knotts, Jr.
Mr. Chase R. Stevens Debevcise L Liber- an Docketing and Service Section 1200 17th Street, N.W.
Office of the Secretary Washington, DC 20036 U.S. Nuclear Regulatory Cc=ission Washington, DC 20555 I
. . L.
Samuel J. Chilk Richard P. Wilson, Esq.
Secretary of the Coc: mission Assistant Attorney General U.S. Nuclear Regulatory Commission South Carolina Attorney Ganeral's Washington, DC 20555 office P.O. Box 11549 Charles McGlothlin, Esq. Columbia, SC 29211 General Counsel South-Carolina Public Service Leonard Bickwit, Esq.
Authority General Counsel P.O. Box 398 U.S. Nuclear Regulatory Commission Moncks Corner, SC 29461.
A C.-Pinckney Roberts, Esq.
Dial, Jennings, Windham, Thomas & Roberts Barringer Building Main Street-Columbia, SC 29201
/
hohnC.Ruoff ['
~
AFFIRMED and subscribed before =e this .2,3 day of -
March 1981.
, *v NOTARY:PUBLIC FOR SOUTH CAROLINA
//~ /2- 96 My Commission Expires e;
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