ML20079K692
| ML20079K692 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/27/1982 |
| From: | Matthews B AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8301100118 | |
| Download: ML20079K692 (25) | |
Text
, 7 *A I
U1!IC STATES CF A:GICA BEFCRS TC ITCL"AR REGUIATCRY CCICUSSICN C03. E.T Ex Parte FAR"5VILLE GROLT, Petitioner,
'83 JR1-3 P12:06 3CCET ITO. 50-261 In the Fatter of: . . . . .
n-
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t CARCLI:a PCWER A:D LIGHT CCUPAliY (E. B. Robinson Steam Electric Plant, Unit 2),
Applicant.
PE"TTICK TO II C VEliE AND REQUEST FCR HEARII!C Hartsville Group, on its own behalf, on behalf of its nenbers, and on behalf o' t' other persons who are similarly situated, hereby petitions -
for leave to intervene in the above captioned license amendment uroceedings as a party of record, requests that public hearings be l conducted at which it will be afforded an ouportunity to be heard, and requests that this Application for Anerdnent to Operating License l o. DD-23 he denied, or be so conditioned, as the Petitioner will hereafter demonstrate, in order that the operation of the facility will be consistent with the protection of the health ard safety of the public. This relief is sou6ht under provisions of the Atcmic Fnergy Act of 195h, as amended, h2 U.S.C.A. 25 2135 and 2239; c.F.R. 5 2 71h; ard pursuant to Iotice of Proposal Issuance of Anendment to Facility Operating License, published rovember 2h, 1082, E7 F.R. 53157. In l
supuert of this Petition and Request for Hearing, Eartsville Group
- would respectfully shows l 1. That Partsville Group is an unincorrorated association uith its urincital activities at Partsville, South Carolira. Its nenbers include 9ersons who live, wor'
- , engage in recreaticral activities arf parti-cimte in civic affairs in 0 arlington, Chesterfield ara "ershaw Counties, l
South CaroIira, i
C301100118 821227 l
6
- 2. "' hat nenbers of Fartaville Groun live, work, engage in outdoor recreati d activities including fishing, beating, swinning, vater-skiing, bm +1ng, hiking ard canping; consume local fruits ard vegetables, Fairy products, neat ard fish; ard breathe the air in close proximity to the H.B. Robinson Stean 21ectric Plant, Unit 2. Members of Earts-ville Group are concuners of energy for residential, businees ard recreational uces. All now purchase electric energy fron connercial sources and would nake use of alternative sources of energy and conser-vation techniques if they were more readily avai.lable and competitively priced. Petitioner's members include retail electric customers of Caro-lira Fower and Light Company ard electric cooperatives in the area.
3 That the Petitioner's interest in protecting its menters frcn erobable harn to their health, safety and economic interects can only be protected through full participation as a party to this proceeding vith the right to offer evidence ard to confront evidence offered by other r;arties. "he Petitioner's members possess unique knowledge as to local geography, flora ard faura, trancportation and traffic con-ditions, ard the ability of area residents to respond to a rediolcgical energency, due to the members' long time residence in close proxinity to the H. B. Robinson Plant. !!o other party can represent the Petitioner's interest, including the State of South Carolina, whose participation is expected to be limited, the Connission' Staff, which cannot represent the irdividual interests of the Petitioner's nenberc, ard the Applicant, whose interest is believed to be adverse to the Petitioner's.
- h. That the Petitioner is inforned ard believes that the grant of an Anendnent to Cuerating License ITo. DFS-23 to Carolira Fewer and light Cony.ny for retal of the steam generators by replacenent of najor cen-nonents including the tube burdles will result in significant hazards ar/ nhysical harn to the health, safety, ard econenic interests of its nenbers, their fan 111es, and other persons sinilarly situated.
l 5 1e Fetitioner is inferned and believec that such. a:iverse intact will result to its nenbers, in part, because; ard that the Cenniscion l
o
'I ..L should deny or condition the troposed Ameniment to Cuerating License for reasons including
- a. The repair of Robinson's steam generators will result in such high radiation extosure to plant site personnel ard the public that it will violate AIARA requirements,
- b. he Applicant cannot assure that Commission Quality Assurance ard Quality Control regulations and requirements can be met in that the number of workers needed to make the repairs will overtax the avail-able supply of qualified workers, resulting in the use of transient workers with unknown radiological exposure histories.
- c. The repair of the steam generators will result in the production of significant amounts of radioactive waste, including the primary coolant, denineralizer and the old generators, the handling, processing, on-site storage, discharging or transportation of which will pose health and safety problems.
- d. Pursuant to recuirenents of the ratioral Environmental Policy Act O' EPA), the Conmission should pretare an Environnental Impact Statement on the troposed Cuerating License Amerdment. A biological assessment should also be conducted,
- e. There is no reasorable assurance that the new stean generators now on order from Westinghouse will be of any better quality than their previous models ard therefore, repairs should not be nade until such l
i tine as the new units can be proven to be efficient and safe,
- f. The problems posed by tremature embrittlement of the reactor vessel, uhich may not be technically resolvable, will cont.inue to exirt and would be amplified by increased operation of the facility with new generators.
- g. The tronosed Crerating License Amendment would pernit activities which would sicnificantly affect and change the favorable cost-cenefit balance struc9 at the Construction and Crerating license stages, in that the ecsts of rerairs are creater than the costs of providing alternate
- sources of energy for the Apulicant's custeners, therefore, a cost-benefit
analysis of deconnissioning the plant, purchasing additional generatirs capacity elsewhere ard conservation techniques should be conducted, as cardated by the ratioral Envirersental Policy Act of 1969
- h. There is no reasonable assurance that the Applicant will cenply with applicable regulations urder C.F.R. 50.40 ard other regulatory requirements, since the Applicant has a history of repeated and treguent violations of regulations.
6 The Fetitioner reserves the right ard hereby asserts its intention to hereafter file a supplenent to this Petition to Intervene urder trovisions of 10 C.F.R..E 2.714, including a list of the contentions which it seeks to have litigated in thi.= proceeding, together with the bases thersfor. It further reserves its right if admitted as a party to this proceeding, to anerd this Petition in such manner as is deened necessary ard proter.
'IHEREFORE, having set forth its inter'ests which will be affected in this nroceeding, having set forth the aspects of the subject natter as to which it niches to intervene, ard having annexed hereto the Affadavits of more than one of its nenbers who will suffer injury in fact from the operation of this facility, which Affadavits are incer-u~~s.ted herein by reference, Eartsville Group respectfully requests
.. eave to intervene in these proceedings, the corduct of hearings, ard the denial of this AnerAcent to Operating License unless so cordi-tioned as to prevent injury to the Fetitioner's health, safety and economic interests.
"ecember 27, 1992 /[ --
7
- 3. A. Eatthews Post Cffice Sox 1089 Hartsville, South Carolina 29530 AFFIRMED and subscribg 803/332-2727 to before me this .27 day of December, 1982.
4 h g f'h .../ Authorized representative for NOTARY PUBLIC FOR the 7etitioner FisRTS7III2 GRCUP SOUTH CARCLINA My Commission Expires JkTarszM 5599il
1 ,
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N , chairnerson of the Hartsville Group, hereby authori e B. A. htthews to set as reuresentative of this group in an action to Petition th Intervene in the Amendment to Operating License for H. B. Robinson Steam Electric Plent Unit 2, before the' United States Nuclear Regulatory Commission, Doctcet No. 50-261.
Service should be made at: Post Office Box 1089 Hartsville, South Carolins 29350 l
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.fw _L G w m & -? fN dy y duu k> , /9f.t.
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g be ^!' ha & & d>'s My Commission Expires Janvory 26,1991 l
CERTIFICATE CF SERVICE d I hereby certify that I have this day served upon the perso.w below named at the addresses set forth the attached Pet'itidri~to Intervene 3
and Request for Hearing by depositing same in the United States Mail, postage prepaid, this 2-7 IdayI of December 1982.*33 J3.N -3 Pl2:06 .
Secretary of the Commission Georgc.F. Trowbridge, Esq.
United States Nuclear Regulatory Shaw, : Pittaut, iPqtts,and Trewbridge Commission 1800 M.; Street, %
Att Docketing & Service Section Wash $ngton, s.C. 20030
- Washington, D.C. 20555 Executive Legal Director H U.S. Nuclear Regulatory Commiasion 4 :
Washington, D.C. 20555 h& h =>
!:(~"A7v Pf2LIC 709 .# -A.; fatt. hews '
FctT H q act "A Authorized N rresentative for Petitioner Hartsville Group \
My Commission c e;7,, ,
Janucry 26,1991 .
d W . L n Au(
j g ggNOTICE FOR SERVICE M&*v /9ft- i
& efNotice is hereby given pursuant to 10 C.F..R. , 2.708 a that se.wice upon i Petitioner should be made at the following addrescs .
I Hartsville Group ' -
Post Office Box 1089 Hartsville, South Carolina 29550 -
l
1 s ,
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION
- b cr.-
Er Parte HARTSVILLE GROUP, )
)
i Petitioner, )
i' ) DOCKET 0.N'V '3 P12:05
)
) 50-261 l In the matter of: ) : 4 pp c;.--
t
) wL I CAROLINA POWER AND LIGHT )
i COMPANY, t
)
)
(H. B. Robinson Steam Electric )
Plant, Unit-2), )
)
l Apulicant. )
l l
PERSONALLY APPEARED before me, B. A. Matthews, who does affirm I and says
- 1. That he resides in Darlington County, South Carolina on Highway 15 approrimetely 5 miles from the H. B. Robinson Steam Electric Plant, Unit 2.
- 2. That he was raised in Hartsville, South Carolina and l sttended the oublic schools in the area. He has particirated in outdoor activities in the Hartseille area, including hunt-ing, fishing, golf and swimming since childhood. His child-l l hood agd-adolescence were spent living on or in close croI-l imity to Bisck Creek and he has unssed many hours on or near the Creek. He has observed chenges in the local environment which have given rise to concerns reprding the E. B. Robin-son Steam Electric Plant, Unit 2.
. . ?. .,
- 3. That he has been emeloyed with the Darlington County Decertment of Social Services for four and a half years, with his office in Hartsville, end works in a territory which includes the H. B. Robinson Plant.
- 4. That he is a residential customer of Carolina Power and Light Company.
- 5. That he has for several veers educated himself in ,
reference to the problems of nuclear tower generation in general and the H. B. Robinson Plant, Unit 2 in certicular.
- 6. That he engages in outdoor recreational activities in close proximity to the H. B. Robinson Plant end also works inside and out of doors near the Plant. He also con-sumes locally grown produce, fish end game taken in Darling-ton and Chesterfield Counties, and breethes the air in close proximity to H. B. Robinson- Unit 2.
l 7 That he is informed and believes that the grant of an Amendment to the Operating License to Carolina Power and Light Comrany for the continued overation of the H. B. Rob-inson Unit 2 will result in direct ehysical harm to his health, safety and economic interests.
I 8. That he is further informed and believes that his in-
, herest in this matter can only be erotected through carti-cication in this Amendment to Orerating License troceeding.
l l
a ..
He euthorizes Hartsville Groue,or its reeresentative, to crotect his interest.
9 B. A. Matthews AFFIRMED and subscribed to before me this 178 day of December, 1982. .
f% ), f% - .. 3 N h5 S & h Ja ,.)
My Commission Excires January 26,1991 l
l l
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: Hartsville Group ) ' O PETITIONER )
) AFFADAVIT $3
) '3 In the Matter of: ) DOCKET NO. 50-261- M2:06
) Li CAROLINA POWER AND LIGHT COMPANY O.y" I. -
) ~ j ifi 74,m. .
s (H.B. ROBINSON STEAM ELECTRIC PLANT, ) 1 " NC5 '9CE UNIT'2). )
APPLICANT )
PERSONALLY APPEARED before me, Jon C. Jicha and Elizabeth R. Jicha,
! who do affirm and say:
l 1. That they reside at 303 Chester Avenue, Hartsville, South Carolina in Darlington County, at a distance of about 6 miles from the H.B. Robinson Steam Electric Plant, Unit 2. They have lived at this residence about 5 years.
l l
l 2. That they own the above premise where they reside and from which Mr. Jicha conducts his business (art-retail) which includes paintings and drawings done from the surrounding I
wildlife.
- 3. That they are employed by Coker College in Hartsville, SC.
That they are concerned with the integrity of the H.B.
Robinson S team Electric Plant, Unit 2, with regard to the replacement of steam generator tubes and the overall embrittlement problems at the abovementioned plant. Also of concern are the long-range problems of nuclear waste resulting from steam generator replacement.
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ___ _ _ ._ _~_ _ __. - -
r . ~. . . '
- 4. That they live, work, and engage in outdoor recreational activities throughout Darlington and Chesterfield Counties including fishing in Lake Robinson, bicycling, walking, hunting, and camping in areas in close proximity to the H.B. Robinson Steam Electric Plant, Unit 2.
- 5. Thay they are residential customers of the Carolina Power and Light Company.
- 6. That they have been receiving and reading information about nuclear reactor safety issues since about 1978. That Elizabeth, as an employee of the Darlington County Department of Social Services did participate in the 1981 Emergency Evacuation Exercises in Darlington County, and that the apparent inadequacies of that exercise increased her concern for the health and safety of area residents in the case of a radiological emergency.
- 7. That they are informed and believe that the grant of an Amendment to the Operating License of Carolina Power and Light Company and the operation of this facility will result in direct physical harm to the health, safety, and economic interests of themselves and the community.
- 8. That they are further informed and believe that their interests can only be protected through participation in this operating license proceeding. They authorize Hartsville Group or its representative to protect their interests.
.: ?.
e AFFIRMED and subscribed to before me this d a day of December, 1982. * -
Jon w>a th ~
Elirabeth R. Jich U M
NOTARU PUBLIC FOR SOUTH CAROLINA k W >u.u a d L4 p Y g /0 9 99 1
4 l
l 1
UNITED STATES OF AIERICA ' ' <c y -
BEFORE THE NUCLEAR REGULATORY COMMISSION 3
E'l ~3 Pl2:05 f, Y!I -
Ex Parte: HARTSVILLE GROUP, )
Petitioner,
)
AFFADAVIT In the matter of: DOCKET NO. 50-261 CAROLINA POWER AND LIGHT COMPANY, (H. B. Robinson Steam Electric Plant, Unit 2),
Applicant.
PERSONALLY APPEARED before me, John Thatcher French, Ph. D., who being duly sworn, says:
- 1. That he resides alone at Branbury Cross, a National His-toric Register Property in Kershaw County, South Carolina, 15 miles from the H. B. Robinson Steam Electric Plant, Unit 2.
- 2. That he is a Professor of Philosophy at Coker Co11eSe in Hartsville, Darlington County, South Carolina, to which place he repairs five days of the week, passing within a stone's throw of Robinson Unit 2.
- 3. That he has restored and lived in the above named house for the past eight years, where he has bred and trained race horses on his small farm for major tracks in New York, Maryland and Delaware. That he has engaged in growing combination grasses, to wit, fescue, coastal bermuda and lespedeza, for the purpose of grazing his race horses.
- 4. That he is a customer of the Black River Electric Cooperative.
5 That he is knowledgeable about the workings and dif-ferent incapacities of the H. 3. Robinson Unit 2, which knowledge he has gleaned from a three year association with the Palmetto Alliance, a nonprofit public interest group based in Columbia, South Carolina, which provides information on nuclear issues. That he, as a faculty member, arranged for Palmetto Alliance representatives l to speak at Coker College in January, 1979 It was at this time that he also invited executive spokespersons for Carolina Power and Light Company, owner of the H.
- 3. Robinson Steam Electric Plant, Unit 2, to rebut the arguments of the Palmetto Alliance representatives.
l This offer was flatly turned down and no spokesperson l
appeared.
G. That he believes that the granting of an amendment to Facility Operating License No. DPR-23 issued to Caro-lina Power and Light Company for operation of the H.
- 3. Robinson Steam Electric Plant, Unit 2 will result in his physical and mental harm and economic deprivation for himself in his race horse business.
l l
- 7. That he is further informed that his interest in this matter can only be protected through participation in this amendment to operating license proceeding. He authorizes Hartsville Group, or its representative to protect his interest in this matter through participa-tion in this proceeding.
JP John Thatcher French, Ph.D.
AFFIR!ED and subs ' ed to before me this J+'N day of December, 1982.
w447 s na NOTARY PU3LIC FOR SOUTH CAROLINA
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: HARTSVILLE GROUP, PETITIONER AFFADAVIT d 82:06 DOCKET NO. 50.-261 : -
<>. p;.~ ,.
In the Matter of: C3 CAROLINA POWER & LIGHT COMPANY
( H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2) .
APPLICANT PERSONALLY APPEARED before me, Robert H. Willetts, who does af firm and says:
- 1. That he resides at 310 West Home Ave., Hartsville, South Carolina in Darlington County, South Carolina together with his wife and teenage daughter, at a distance of about 6 miles from the H.B.
Robinson Steam Electric Plant, Unit 2 and that he has lived at this residence about 3 years.
- 2. That he owns the above premise where he resides on about one acre of land and he is employed by the Hartsville Area Schools of the Darlington County School System, Hartsville, South Carolina.
3 That he and his family live, work, and engage in outdoor recrea-tional activities throughout Darlington County, including hiking, swimming, and sailing in close proximity to the H.B. Robinson Steam Electric Plant, Unit 2.
4 That he is a residential customer of Carolina Power & Light Company.
S. That he has recieved and read information on nuclear power plant safety issues and has become educated on the subject of the design
and operation of H.B. Robinson Unit 2, specifically steam generator problems, and the embrittlement of the reactor vessel of H.B. Robinson Steam Electric Plant, Unit 2.
6 That he is informed and believes that the grant of an ammend-ment to the operating license to Carolina Power & Light Company and the operation of this facility will result in direct physical harmLto the health, safety, and economic interest of himself and his family.
- 7. That he is further informed that his interest in this matter can only be protected through participation in this operating license proceeding. He authorizes Hartsville Group, or its representative, to protect the interest of himself and his family in this matter through participation in this proceeding.
AFIRMED and subscribed to /'7 -
before me this.httday of # /, / [/
December c N/ /N'@/N
///b V N,1982.
' gf f,///J Robert H. Willetts NOTARY PUBLIC FOR SOUTH CAROLINA 1
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ctyp-.-
Ex Partes HARTSVILLE GROUP, )
Petitioner, ) D ddy
) AFFADAVIT S;
)
) DOCKET NO. 50-261 . . . . . . .
In the matter of: . (l,c,[,gEk
. CAROLINA POWER AND LIGHT )
COMPANY )
)
(H. B. Robinson Steam )
Electric Plant, Unit 2), )
)
Anp11 cant. )
)
PERSONALLY APPEARED before me, Gus and Kathy Dunlap, who being duly sworn, says
- 1. That they reside at 523 East Home Avenue, Hartsville, South Carolina, in Darlington County at a distance of
- approximately 7 miles from the Carolina Power and Light Company's E. B. Robinson Steam Electric Plant, Unit 2.
.2. That they owrr the above cremise where they live with their 15-month-old son. That Gus has scent most of his life in close proximity to Black Creek.
3 That they live and work in close oroximity to H. B.
Robinson Steam Electric Plant, Unit 2. That he (Gus) is employed by Coker's Pedigreed Seed Comeany and spends many of his working hours outside.
- 4. That they engege in outdoor recreational activities at Prestwood Lake, Black Creek, Lake Robinson and many bther areas throughout Darlington, Chesterfield end Marlboro Counties.
5 That they consume locally grown vegetables and meat, including fish caught in Prestwood Lake and Lake Rob-inson, game taken in Darlington County and on Bleck Creek, and also vegetables grown in their home garden.
- 6. That they are residentail electric customers of Carolina Power and Light Comeany.
- 7. That they live in the house owned by his late grandmother, who lived there since 1916, and have a small son and hope to have other children who will also reside in this resi-dence and enjoy their heritage.
- 8. That for several years they have received and read infor-mation certaining to the H. B. Robinson Unit 2 and other nuclear facilities. That while a member of the ' Harts-ville Rescue Souad he was trained and certified as a Civil Defense radiological monitor.
9 That they are informed and believe th9t the granting of an amendment to the operating license for H. B. Robinson Unit 2 :and the continued overation of this facility will result in direct physical harm to the health, safety and economic interests of themselves and their family and future generations of their family.
- 10. Thst they are further informed that their interests in this matter can only be erotected through particiention l
in this amendment to operating license croceeding. They authorize Hartsville Group, or its representstive to protect their interests in this matter through partici-l pation in this proceeding.
l AFFIRMED and subscrib d ett w to before me this E day Gus Dunlan f of December, 1982.
C nW 0/ i J <br ge i ~ . , j, & - . , j
~
~
Kath QDunlau (
NOTARY PUBLIC FOR SOUTH CAROLINA
- .y Commission Exo!M9 January 26,1991 l
l l
l l
l .
UNITED STATES OF AMERICA 9 e.i;7 BEFORE THE NUCLEAR REGULATORY COMMISSION N ~3 gg.y Ex Parte: HARTSVILLE GROUP, PETITIONER, )
- ) AFFADAV.IT In the Matter of: DOCKET Nd.'D'- 1
)
CAROLINA POWER AND LIGHT COMPANY )
(H.B. ROBINSON STEAM ELECTRIC PLANT, )
UNIT 2), APPLICANT.
PERSONALLY APPEARED before me, John W. Martin, III, who does affirm and say:
- 1. That he and his wife and two children reside at 507 Pine St., Camden, South Carolina in Kershaw County, at a distance of about 25 miles from the H.B. Robinson Steam Electric Plant, Unit 2. They have lived in Camden about five years.
- 2. That they own the above premise where they reside.
- 3. That he is employed by Mar-Mac Mfg. Co., Inc. in McBee, S.C. That he is concerned with the integrity of the H.B. Robinson Steam Electric Plant, Unit 2, with regard to the replacement of steam generator tubes and the
' overall embrittlement problems at the abovementioned plant. Also of concern are the long-range problems of nuclear waste resulting from steam generator replacement.
- 4. That he and his family live, work and engage in outdoor recreational activities in Kershaw and Chesterfield counties including boating, swimming, and visting at Lake Robinson.
- 5. That he grew up in McBee and spent a great deal of time on and around
l l . ,
Lake Robinson throughout the year.
- 6. That they are residential customers of The City of Camden.
l
- 7. That he has been receiving and reading information about nuclear reactor l
safety issues and the related waste disposal problems, and has been increasingly concerned for the safety of himself and his family.
- 8. That he is informed and believes that the grant of an Amendment to the i Operating License of Carolina Power and Light Company and the operation of this facility will result in direct physical hann to the health, safety, and economic interests of themselves and the community.
- 9. That he is further informed and believe that his interests can only be protected through participation in this operating license proceeding.
He authorizes Hartsville Group or its representative to protect his interest. -
/
AFFIRMED and subscribed to
- before me this 27 day of /
December, 1982. / -
44A / . .
Johh 1." Ma rtTn ," FII' ' V
)sw9-ed da6 i NOTARY PUBLIC FOR SOUTH CAROLINA 1
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: HARTSVILLE GROUP, )
)
Petitioner, ) AFFADAVIT
) 83 p -3 R2 06
) DOCKET 50-531 In the Matter of ) _
) :. 's$dC:
CAROLINA POWER AND LIGHf ) u- - ',fy;;;g COMPA NY, )
)
(H. B. Robinson Steam Electric )
Plant, Unit 2), )
)
Applicant. )
)
PERSONALLY APPEARED before me, Edward Kent Segars, who does affirm and says
- 1. That he resides at Segars Mill Farm, Route 2, Eartsville, South Carolina in Darlington County, South Carolina. This property extends along Bisek Creek from approximately one half mile below the Lake Robinson dam to road S-1040, suproximately 4 miles from H. B. Robinson Unit 2.
- 2. That he, his wife and his mother now reside on the afore-mentioned crocerty which has been in the Segars family for at least four generations.
3 That he is emoloyed by Sonoco Products Company in the Forest Resources Division, working in the Society Hill area of Darlington County within 20 miles of H. B. Robinson Unit 2.
l That he and his brother intend to use a cortion of the family acreggeffor animal husbandry pureoses.
4 That he and his family engege in outdoor recreational
. . t. ,
activities including hunting, fishing, swimming and boating in areas throughout Darlington, Chesterfield, Lee and Kershaw Counties. They also consume locally grown eroduce, meat and diary eroducts and breathe the air in close proximity to H. B.
Robinson Unit 2.
5 That he is an electric customer of Carolina Power and Light Company.
- 6. That for several years he has received and reed informa-tion certaining to the H. B. Robinson Unit 2 and is aware of
-the steam generator and embrittlement eroblems at this facility.
7 That he is informed and believes that the grant of an Amendment to the Operating License for H. B. Robinson Unit 2 and the operation of this facility will result in direct physical harm to the health, safety and economic interests of himself and his family.
- 8. That he is further informed that his interests in this matter can only be crotected through earticination in this Amendment to Ocereting License croceeding. He authorizes Hartsville Grout, or its reeresentative to erotect his interests in this matter through certiclestion in this croceeding.
Q.<2 &> 1"' kd r ^LetJ Q y A /,,p u, m M MIc/y Edward Kent Segers h&, /9f.t.
- 8. & e ' - - L' T, 89 N" 4k M ha- s My Commissten Empires January 26,1991 1
UNITED STATES OF A!! ERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: HARTSVILLE GROUP, )
) . A .F' F A Waff1 T Petitioner, )
) DOCKET NO.
50-2p 2 -3 W In the Matter of: )
) L. . _. : u .h!A r. -
CAROLINA POWER AND LIGHT ) 00EggyERVIC.1
~
C0!!PANY, )
)
(H. B.' Robinson Steam Electric )
Plant, Unit 2), )
)
Anulicant. ) '
)
PERSONALLY APPEARED before me, Mary Lunn Kirven, who does affirm and say
- 1. That she resides at 813 West Home Avenue, Hartsville, South Carolina, in Darlington County, South Carolin'a at a distance of about 5 miles from the H. B. Robins.on Steam Electric Plant, Unit 2.
- 2. That she owns the above cremise where she has lived for 30 years, property on Lak'e Robinson in Che'ste' r field County on which stands a house built in 1961+ by her late husband, and 65 acres of farmisnd in the Auburn section of Earlington County, approximately 12 miles from the H. B. Robinson Plant.
3 That she is emoloyed as a teacher at Robert E. Lee Academy, Bishopv111e,in Lee County, located accroximately 13 miles from H. B. Robinson Unit 2.
- ..