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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
      ~
In the Matter of                    a PUBLIC SERVICE ELECTRIC &            :          Docket No. 50-311 GAS COMPANY                :          Proposed Issuance
:          of Operating License (Salem Nuclear Generating          :
Station, Unit No. 2)
AFFIDAVIT IN SUPPORT OF PETITION SEEKING ISSUANCE OF AN ORDER TO SHOW CAUSE AND STAY LICENSING
: 1. I am ful.y familiar with all the statements contained in the attached Petition Seeking Issuance of an Order to Show Cause and Stav Licensing of Salem Unit No. 2.      To the best of my knowledge, information and belief, the statements contained therein are true and accurate, submitted in good faith and not submitted for the purpose of delaying adjudication of this within proceeding.
: 2. My wife and I, together with our three children (ages ll, 14 and 18), live at 35 "K" Drive, Pennsville, New Jersey 08070, in a one-story ranch style house, which we own. Our home is located about ten miles north of the Sahm Station, near the Delaware River.      We have lived here for about six years, and have no present intention of moving.
3    I am employed by the Du Pont Corporation of Wilmington, Delaware, as a Distributor and Customer Service Supervisor with responsibilities for the sale and distribution of Du Pont paint products for international sales.      I am a graduat.e of Rutgers University, where I majored in economics. Also,'I hm a 1015 110          7 9092eo l2s
 
licensed real estate salesman / broker and licensed insurance solicitor /broket 3n the State of New Jersey. I engage in real estate and insurance on a part-time basis, mostly in the Salem County area.
: 4. Our interests, together with the interests of others similarly situated, potentially are affected by Public Service Electric and Gas Company (the Licensee) application and the lack or failure of the Nuclear Regulatory Commission (NRC) to analyze information already known, will adversely affect our electric bills and create a needless economic hardship prematurely.
5  Our interests, together with the interests of others similarly situated, potentially are affected by the licensee's Amendment No. 42 due to the prospect, as yet undetermined, of increased daily exposure to radiation releases from a multi-nuclear facility, together with the risk of exposure to signi-ficantly higher levels in the event of design, construction, or operational errors in the proposed expansion. These interests also extend to our children, prospective grandchildren, together with friends and relatives who might be expected to visit with us.
: 6. Additionally, our interests, together with the interests of others similarly situated, potentially are affected by public recognition of hazards, real or suspected, regarding a multi-nuclear center and nuclear fuel storage at the Salem installation which reasonably could be expected to affect property values and business activity wihin the vicinity..
1015 111
 
7    Finally, our interests, together with that of others similarly situated, cannot feasibly be protected in any reasonable manner, other than by our own active intervention and participation.
: 8. In conclusion, due to our close proximity to the facility, the potential hazards of nomal or accidental releases of radiation to ourselves, our children, relatives, and friends, and the con-current 'isk of adverse economic impacts, our health, safety, and welfare are affected by the licensee's application which is the subject of tas proceeding.
Dated:              7'Mf.,1979 7
4(        2.nM;1  h.
Alfged C. Co).eman, Jr. #
(l/ 4 #A'/ ]    ib%?1r      ~
                                                    " Eleanor G. Coleman Sworn and Subscribed to before me thi                  ay of    ,1979
                      ~
    .      r-DT R RcDoNoucs -
NOTARY PUBUC OF NDI JER$W
                #f " r 6,iasJr 20.134 W
                                                                                                                . 1015 112}}

Latest revision as of 06:52, 2 February 2020

Affidavit of Intervenors Coleman Re Issuance of Order to Show Cause & Stay Licensing.Claim Standing as Consumers of Electricity from Licensee & from Proximity of Facility. Forwards Petition Seeking Issuance of Order
ML19208C366
Person / Time
Site: Salem PSEG icon.png
Issue date: 08/02/1979
From: Coleman A, Coleman E
AFFILIATION NOT ASSIGNED, External Citizen/Individual/Media (Affiliation Not Assigned)
To:
Shared Package
ML19208C367 List:
References
NUDOCS 7909260125
Download: ML19208C366 (3)
v • d • e


Text

< .

143/k .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

~

In the Matter of a PUBLIC SERVICE ELECTRIC &  : Docket No. 50-311 GAS COMPANY  : Proposed Issuance

of Operating License (Salem Nuclear Generating  :

Station, Unit No. 2)

AFFIDAVIT IN SUPPORT OF PETITION SEEKING ISSUANCE OF AN ORDER TO SHOW CAUSE AND STAY LICENSING

1. I am ful.y familiar with all the statements contained in the attached Petition Seeking Issuance of an Order to Show Cause and Stav Licensing of Salem Unit No. 2. To the best of my knowledge, information and belief, the statements contained therein are true and accurate, submitted in good faith and not submitted for the purpose of delaying adjudication of this within proceeding.
2. My wife and I, together with our three children (ages ll, 14 and 18), live at 35 "K" Drive, Pennsville, New Jersey 08070, in a one-story ranch style house, which we own. Our home is located about ten miles north of the Sahm Station, near the Delaware River. We have lived here for about six years, and have no present intention of moving.

3 I am employed by the Du Pont Corporation of Wilmington, Delaware, as a Distributor and Customer Service Supervisor with responsibilities for the sale and distribution of Du Pont paint products for international sales. I am a graduat.e of Rutgers University, where I majored in economics. Also,'I hm a 1015 110 7 9092eo l2s

licensed real estate salesman / broker and licensed insurance solicitor /broket 3n the State of New Jersey. I engage in real estate and insurance on a part-time basis, mostly in the Salem County area.

4. Our interests, together with the interests of others similarly situated, potentially are affected by Public Service Electric and Gas Company (the Licensee) application and the lack or failure of the Nuclear Regulatory Commission (NRC) to analyze information already known, will adversely affect our electric bills and create a needless economic hardship prematurely.

5 Our interests, together with the interests of others similarly situated, potentially are affected by the licensee's Amendment No. 42 due to the prospect, as yet undetermined, of increased daily exposure to radiation releases from a multi-nuclear facility, together with the risk of exposure to signi-ficantly higher levels in the event of design, construction, or operational errors in the proposed expansion. These interests also extend to our children, prospective grandchildren, together with friends and relatives who might be expected to visit with us.

6. Additionally, our interests, together with the interests of others similarly situated, potentially are affected by public recognition of hazards, real or suspected, regarding a multi-nuclear center and nuclear fuel storage at the Salem installation which reasonably could be expected to affect property values and business activity wihin the vicinity..

1015 111

7 Finally, our interests, together with that of others similarly situated, cannot feasibly be protected in any reasonable manner, other than by our own active intervention and participation.

8. In conclusion, due to our close proximity to the facility, the potential hazards of nomal or accidental releases of radiation to ourselves, our children, relatives, and friends, and the con-current 'isk of adverse economic impacts, our health, safety, and welfare are affected by the licensee's application which is the subject of tas proceeding.

Dated: 7'Mf.,1979 7

4( 2.nM;1 h.

Alfged C. Co).eman, Jr. #

(l/ 4 #A'/ ] ib%?1r ~

" Eleanor G. Coleman Sworn and Subscribed to before me thi ay of ,1979

~

. r-DT R RcDoNoucs -

NOTARY PUBUC OF NDI JER$W

  1. f " r 6,iasJr 20.134 W

. 1015 112

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