ML20028C429
| ML20028C429 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/26/1982 |
| From: | Kirven J AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8301100122 | |
| Download: ML20028C429 (13) | |
Text
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION.
Ex Parte:
Conaerned Fools
)
of Darlington County,
)
Petitioner,
~
)
DOCKET NO. 50-261 83 3 33 N0:47 In the Matter of:
J a*4 CAROLINA POWER & LIGHT COMPANY ))
.,.y.
(H.B. Robinson Steam Electric
' "C *" 3 O
.Y
)
Plant, Unit 2),
3 RANCH Applicants,)
)
)
PETITION TO INTERVENE AND REQUEST FOR HEARINGS Concerned Fools of Darlington County, on its own behalf, on behalf of its members, and on behalf of all similarly situated fools, hereby petitions for leave to intervene in the above-captioned license amendment proceeding and begs that a h' earing be held on this foolishness af ter which the amendment -
be turned down.
This relief is sought pursuant to Notice of Proposed Issuance of Amendment to Facility. Operating Li, cense, published November 24, 1982, 47 FR 53157.
The Concerned Fools _of Darlington' County is a group of folks living near the H.B. Robinson facility.
As any fool can see, only a fool would live ~near a leaky rattletrap nuclear l
plant like that.
The Concerned Fools -(hereaf ter " Fools") formed in 1978 in recognition that admitted foolishness was saner than I
unadmitted foolishness.
All of the Fools are lifelong residents of this county, where they live, work and engage in recreational activities.
8301100122 021226 gDRADOCK 05000261 fDg PDR
I. '*
4.
That she is a residential electric customer of Carolina Power and Light Comesny.
5 That she 'and her family have for many years engaged f.n recreational activities at their lake house.
Her sons hunt an~d fish in parts of Darlington, Lee, Sumter,. Chesterb -;
field and Kershaw Counties in close oroximity to the H. B.
Robinson Plant and her family consumes game taken from these areas.
They als.o consume locally grown fruits, vegetables,.
incat and dairy products and breathe the air in *close proximity to H. B. Robinson' Unit 2.
6.
That she has read with interest and concern material certaining to the nuclear facilities in South Carolina since the late 1970's and she has become educated on the orobable offecte of operation of H. B. Robinson Unit 2.
7 That she is informed and.bcl'ieves that the grant of an Amendment to Opeating License DRP-23 to. Carolina Power and Light Company for the operation of H. B. Robinson Unit 2 will result in direct physical harm to her family's health, safety and economic interests.
l 8.
That she is furhter informed that her interests i~n this matter can only be protected through particitation in this Amendment to operating License troceeding.
She
2 Fools believe that repairing the steam generators at Robinson will threaten them with immediate, harm to the health and safety.
Only a fool would continue to pour money down a rathole, and Fools allege that repairing the steam generato'rs at Robinson will turn on its head the cost-benefit analysis struck at the Operating License stage.--~ Fools further allege that it is foolishness to expose so many workers to high radiation when less foolish energy is available more cheaply.
Fools believe that only by participating in these proceedings can their health, safety and economic interests be protected.
Commission policy has created an Alice-in-Wonderland regulatory scheme.
There should be Fools in every proceeding to point out when that the NRC is wearing no clothes.
And as we know from History, Fools may speak what others - like the State l
of South Carolina, the Applicants, and the NRC Staff may not.
For Fools can speak the truth.
And who but a Fool would invest time and energy in a regulatory process that had never ultimately denied the grant l
of a license?
Who but a Fool would act as if this w'ere a legitimate process when even the. kings decry the blinkering of judges?
Only a Fool should be allowed to intervene.
Fools will supplement this petition unde ~r provisions i
of 10 CFR 2.714 (b).
Having submitted the required information to Intervene, rools respectfully requests leave to intervene in these. proceed-O
e,s.e 3
ings and the denial of,this applipation for an amendment to the Operating License.
Stop this foolishness.
M/4
(
/
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a '. u< ine Kirven x 835 Hartsville, SC 29550 Authorized Representative December 26, 1982 Concerned Fools of Darlington County h
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3 g Des 9,1991
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AFFIDAVIT OF AUTHORIZATION PERSONALLY appeared before me Jacqueline Kirven who does affirm that she is the Veriest Fool of the Concerned Fools of Darlington County and that those Fools have-conferred upon her the role of Authorized Representative in':thh CP&L Robinson Unit 2LicenseAmendmentProceedings.
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v0Crilthu i. SERV!CE SRANCH DONE before me this.27 day of December 1982 at Jldm//2)
SC.
LNy M M
NOTARY P @ LIC FOR SOUTH CAROLINA (L.S.)
& L%plive Act ?, /99l NOTICE OF SERVICE TAKE NOTICE that all papers in this proceeding should be served upon Concerned Foolc of Darlington County'at P.O. Box 835, Hartsville, SC 29550.
1
/SADI l Sk J
el e Kirven 9
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UNITED STATES OF AMERICA-BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of :
)
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CAROLINA POWER & LIGHT COMPANY AFFADAVIT (H.B. Robinson Steam Electric Jhd
)
ggigpogg5g261 Plant, Unit 2)
)
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CCC/.:.i:..G & SERVICE 3 RANCH
\\
PERSONALLY APPEARED before me, Jacqueline Kirven, who does ffirm and say:
1.
That she, Jacqueline Kirven resides above her mother's garage at 813 West Home Avenue in Hartsville South Carolina, approximately g
six miles from the H.B. Robinson Steam Electric Plant, Unit 2.
She is self-employed as a sign pointer.
2.
That she keeps honey bees on propert owned by her family adjoining Lake Robinson.
3.
That she truck f arms on land approximat,ely 11 miles East of the H.B. Robinson Steam Electric Plant, Unit 2.
4.
That she is a member of Concerned Fools of Darlington l
County.
5.
That she is informed and believes that the grant of an i
l amendment to the operating license of Carolina Power & Light Company for the operation of the H.B. Robinson, Steam Electric
~
Plant, Unit 2, and the subsequent operation of Robinson will i
result in direct physical harm to the health safety and economic interests of her and her family.
6.
That she is further informed and believes that their ' interest in this matter can only be protected through participating in this operating license amendment proceeding, and that this interest will not be represented by any of the other partie.s to
,.s...
the proceedings.
She authorizes Concerned Fools of Darlington County, of which she is a member,'or its representative to protect her interest in this matter through participation in this proceeding.
I s
)Mrs /dk$ Mk
~
Ja b.
e Kirven AFFIRMED and subscribed before me this J7 b day of December 1982.
Yv'2t n
/ Jim t NOTARY pOBLIC FOR SOUTH CAROLINA (L.S.)
Y' whek Mpivo Ockgiq91 4
e e
N.
6.,
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte:
Concerned Fools
)
of Darlington County,
)
Petitioner,
' S
)
DOCKET NO. 50-261 23 ggl3g MOM 7 In the Matter of:
JhN CAROLINA POWER & LIGHT COMPANY )
b i&iiCE.
(H.D. Robinson Steam Electric
'* " 'Tfdh[CM Plant, Unit 2),
~
Applicants,)
)
PETITION TO INTERVENE AND REQUEST FOR HEARINGS Concerned Fools of Darlington County, on its own behalf, on behalf of its members, and on behalf of all similarly situated fools, hereby petitions for leave to intervene in the above-captioned license amendment proceeding and begs that a hearing be held on this foolishness after which the mnendment be turned down.
This relief is sought pursuant to Notice of Proposed Issuance of Amendment to Facility Operating License, published November 24, 1982, 47 FR 53157.
The Concerned Fools of Darlington County is a group of folks living near the H.B.
Robinson facility.
As any fool can see, only a fool would live near a leaky rattletrap nuclear j
plant like that.
The Concerned Fools (hereafter " Fools") formed in 1978 in recognition that admitted foolishness was saner than unadmitted foolishness.
All of the Fools are lifelong residents of this county, where they live, work and engage in recreational activities.
l l
- ,,s, 2
Fools believe that repairing the steam generators at Robinson will threaten them with immediate harm to the health and safety.
Only a fool would continue to pour money down a rathole, and Fools allege that repairing the steam generators at Robinson will turn on its head the cost-benefit analysis struck at the Operating License stage.
Fools further allege that it is foolishness to expose so many workers to high radiation when less foolish energy is available more cheaply.
Fools believe that only by participating in these proceedings can their health, safety and economic interests be protected, Commission policy has created an Alice-in-Wonderland regulatory scheme.
There should be Fools in every proceeding to point out when that the NRC is wearing no clothes.
And as we know from History, Fools may speak what others - like the State of South Carolina, the Applicants, and the NRC Staff may not.
For Fools can speak the truth.
And who but a Fool would invest time and energy in a r
regulatory process that had never ultimately denied the grant of a license?
Who but a Fool would act as if this were a l
legitimate process when even the kings decry the blinkering of judges?
Only a Fool should be allowed to intervene.
Fools will supplement this petition under provisions of 10 CFR 2.714 (b).
Having submitted the required information to Intervene, Fools respectfully requests leave to intervene in these proceed-
, =. s.
3 ings and the denial of this application for an amendment to the Operating License.
Stop this foolishness.
)
/
lLh I l
l s a
qu<
ine Kirven x 835 Hartsville, SC 29550 Authorized Representative December 26, 1982 Concerned Fools of Darlington County k
R1d
&'y h aa Q conuruwev yp u) Oct 9,1991 k
l l
l
s.
AFFIDAVIT OF AUTHORIZATION PERSONALLY appeared before me Jacqueline Kirven who does affirm that she is the Veriest Fool of the Concerned Fools of Darlington County and that those Fools have-conferred upon her the role of Authorized Representative in:the CP&L Robinson Unit 2LicenseAmendmentProceedings.
JAM <
NAD I
J
'qtfel e. Ki'fvenk FCL..;.:,G a SERV'Cf 5?. A NCH DONE before me this.2 7 day of December 1982 at J)etbt/h)
SC.
80L Th Jl.wx2 NOTARY P@LIC FOR SOUTH CAROLINA (L.S.)
& & J y/ rx dct R /99/
d NOTICE OF SERVICE TAKE NOTICE that all papers in this proceeding should be served upon Concerned Fools of Darlington County at P.O.
Box 835, Hartsville, SC 29550.
l
/Wkil usk
\\f J
uel e Kirven l
- ,o.
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of :
)
C C..;p CE CAROLINA POWER & LIGHT COMPANY AFFADAVIT (H.B. Robinson Steam Electric g
Plant, Unit 2) g t3f A10 8T261 5
)
..t!,..
I:C...... L c4 SLt v!CE
?
iIACH PERSONALLY APPEARED before me, Jacqueline Kirven, who does ffirm and say:
1.
That she, Jacqueline Kirven resides above her mother's garage at 813 West Home Avenue in Hartsville, South Carolina, approximately six miles from the H.B. Robinson Steam Electric Plant, Unit 2.
She is self-employed as a sign painter.
2.
That she keeps honey bees on propert owned by her family adjoining Lake Robinson.
3.
That she truck farms on land approximately 11 miles East of the H.B.
Robinson Steam Electric Plant, Unit 2.
4.
That she is a member of Concerned Fools of Darlington Count.y.
5.
That she is informed and believes that the grant of an amendment to the operating license of Carolina Power & Light l
l Company for the operation of the H.B.
Robinson Steam Electric l
i Plant, Unit 2, and the subsequent operation of Robinson will result in direct physical harm to the health safety and economic interests of her and her family.
l 6.
That she is further informed and believes that their interest in this matter can only be protected through participating in this operating license amendment proceeding, and that this interest will not be represented by any of the other parties to
4-the proceedings.
She authorizes Concerned Fools of Darlington County, of which she is a member, or its representative to protect her interest in this matter through participation in this proceeding.
I
~
lAfd (1L E klY Ja el e Kirven AFFIRMED and subscribed before me this J7 _b day of December 1982.
/
Mat 1h Ilwx1 NOTARY pUBLIC FOR SOUTH CAROLINA (L.S.)
Crnuw;wY Lypuuo 0ctgIq9/