ML20004C438

Testimony That Facility Emergency Info Brochure Is Not Effective Tool to Provide Reasonable Assurance That Residents Would Be Able to Respond Appropriately to Emergency.W/Prof Qualifications & Certificate of Svc

ML20004C438
Person / Time
Site:	Summer
Issue date:	05/28/1981
From:	Andrews A FAIRFIELD UNITED ACTION
To:
Shared Package
ML20004C433	List: ML20004C432 ML20004C435 ML20004C438
References
ISSUANCES-OL, NUDOCS 8106040058
Download: ML20004C438 (16)

Text

- n c v,+ _t , _

7,. -

. dj ; _ 6))

. , UNITED STATES OF, AMERICA'

; = NUCLEAR

REGULATORYJCOMMISSIONi 4

In fthe Matter of: ,

1))

.m

' ~  : SOUTH CAROLINA ELECTRIC'AND GAS- J) Docket No.L50-395 OL

,. . COMPANY, et al. 1 lj.' -

- (Virgil _ C.'i Summer' Nuc ' ear. Stati0n,- ). '

May 28p 1981l

? Unit 1) -)

')-

~ DIRECT TESTIMONY.OF .

~

ARLENE B0WERS ANDREWS l'- Q. LPLEASE STATE YOUR NAME AND ADDRESS.

2. A. My name-is Arlene Bowers Andrews. My' business address is De-3- partment of Psychology,-University of-South Carolina Lolumbia, 4 South Carolina 29208.

S 'Q. PLEASE DESCRIBE:YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL 6 EXPERIENCE.

7- :A. 'I received 'a Bachelor of Arts degree in Psychology fro- Juke-8 - University in Durham, North Carolina. I hold a Master. of Social 9 ~ Work degree from the University of.Soutt "arolina, with a major 10 ' area of concentration in Consnunity Social Work. I am currently 11 enrolled in the doctoral program-in Clinical and Contuunity Psy--

12 chology in the Department of Psychology at the University of

-13' -South Carolina in the field of Community Psychology. As part C of my doctoral work, I have taken training in crisis intervention 15 in coninunities affected by natural and man-made disasters. I 16 am familiar with the limited available literature on the psycho-

[ _17- , logical effects of accidents at nuclear faciliues, I am co-18 authoring a chapter on " Effects of tha Physical Environment on E

~19 Mental Health" for a textbook on preventive mental health.

i

,:s10'so4oOSB:

.i__ . .

3 i ~

1 ..In 1973, I was employed as a Social Worker for the South Carolina 2 ' Department.of Mental Ret &rdation, responsible ~for working with 3 ' rural, and generally poor, families across the State.. . From 4 .1973' tc 1977, I was employed by- the 0ffice of the Governor of 5 South Carolina.in a number of positions in the Office.of Social

6. Development. I began as a Planner, in which position I conducted

~

7. in-depth studies of rural transportation. From August 1976 to 8 ~ April 1977,'I was Director of Research and Evaluation. From May.

9. 19'7 to August 1978,'I was Coordinator of the Richland County 10 Coordinating Committee on Child Abuse and Neglect. .I have,been 11 - an Instructor in Psychology and an Assistant Adjunct Professor 12 of Social Work at the University of South Carolina, as well as a 13 Training Consultant.to the College of Education on parent / citizen 14 participation on school advisory councils.

15 I am currently a Board member of the Richland County Department of 16 Social Services.

17 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?

18 ' A. The purpose of my testimony is to evaluate the public information .

19 materials distributed by the V.C. Summer Nuclear Station regarding 20 actions which residents in the vicinity of the Summer plant would 21 need to take to protect their health and safety in the event of 22 a nuclear accident at the plant. My examination of the public 23 information brochure entitled "V.C. SUMMER EMERGENCY INFORMATION" 24 has focused on three issues:

y.

3 ,

Y

-3.

Lc

.1 1)'whether persons living near.-.the Summer Station would

.2 -~be able to read,the' brochure;

-3. 2)'whether they would be able to.cognitively _ comprehend, 4~ that is- understand, what they had read; and 5_ 3) whether they would'be able behaviorally to act upon the-

'6- information. '

T .Q. WOULD YOU PHYSICALLY DFSCRIBE THE EMERGENCY INFORMATION BR0CHURE.

cA. -One side of the brochure consists of a multicolored, circular-

~9 map. The map is broken into different colored patches which are

-10 coded to " Primary Evacuation Routes" 'at the bottom of the page.

11- Those " Primary Evacuation Routes" direct residents of coded sec-12 tors to reception centers by way of.one or two designated road 13 routes. All roads are designated by road number.

'14 15 One half of the other side consists of four panels of dense text, 16 together with what appears to be a scherratic drawing of a nuclear 17 plant and a chart setting forth various sources of low-level radi-18 ation. Another quarter of that page is devoted to a picture of 19 the nuclear facility with some additional text. The final quarter 20 is comprised of a cover with title and a mailing panel.  ;

21 Q. HAVE YOU EXAMINED CENSUS DATA ON THE EDUCATIONAL LEVEL 0F PERSONS 22 RESIDING NEAR THE SUMMER STATION?

23 A. Yes, I have. From the 1970 Census of, Population, which is the l 24 most up-to-date published source based on an actual enumeration, 25 it appears that the educational level is quite low. In Fairfield t

[

- .- -e. .

e- -e

, . :4 - -

if

1~ . County, where the' plant.is located, the median educational level 2 - forLadult males: is .only 8.5 years. : For females :it is only 9.4 3 / years; -Fewer than one-fourth of the. adult males in the county-14' L(24.3%) 'and only 29.4% of the. adult females are high school. gradu-5 ates.

6- Q. BASED UPON YOUR EXPERIENCE,1WilAT EDUCATIONAL-LEVEL WOULD A PERSON 7 llAVE T0 liAVE ATTAINED BEFORE ilE OR SilE COULD BE EXPECTED TO BE.

-8 ABLE- TO READ AND COMPREllEND Tills.BROClluRE?

9 A. At a minimum, a high :hool education would be needed. It would 10 probably require some college and, in order to read and understand -

11 the chart of low-level radiation sources, you would probably. need 12 . specialized education.

13. Q. WilAT PROPORTION OF Tile POPULATION OF FAIRFIELD COUNTY COULO PROBABLY 14 NOT READ AND COMPREllEND Tile WRITTEN INFORMATION CONTAINED lil Tills 15 DROCHURE7 16 'A. Three-quarters of the population.of Fairfield County could probably 17 not read and comprehend the written information: contained in the 18 brochure. Based upon my experience in working with persons' who 19- have not graduated from high school, I have no doubt that they 20 would not be able to read and understand it.

21- Q. WOULD Tile TYPICAL RESIDENT IN Tile VICINITY OF Tile SUMMER PLANT BE

~22 A".E TO UNDERSTAND Tile MAP IN Tills BROCilVRE7 23 A. No. Maps are a form of symbolic representation as are the codes 24 to this map. Understanding symbolic representation requires a 25' - higher level of education and specific training in the skill of, 26 in this instance, map reading.

-- fr - , . y , - -*-c- --- -yr- -y w- , w vr an.. g

C '

_. S. .

1: Because'of the several zones 'and the Evarious. colors and codes,.

-2 . this map is even nere complex and difficult to understand than 3- nest for the' untrained person. This map would tua very difficult ~ '

4'. for1the great najority of resident; of. the vicinity _ of! Summer-to .

5: understand and use.

6 Q. WHAT WOULD BE THE PRACTICAL EFFECT OF A PERSON'S NOT BEING ABLE 7- TO UNDERSTAND THE DIRECTIONS OR THE MAP?.

8 LA. They would not be likely to follow:the instructions and, thus, would be less likely to act to' protect.themselves.

~

91 10 .Q.. WOULD RESIDENTS OF THE. SUMMER VACINITY BE LIKELY T0 UNDERSTAND-11 THE CHART ON SOURCES OF LOW LEVEL RADIATION?

12 A. The chart is very' difficult to understand. Most of the people 13 near the plant would probably not be able to understand it- .

14 Q. IF A PERSON WHO WAS ABLE TO UNDERSTAND THE CHART ON SOURCES OF 15 LOW LEVEL RADIATION WERE INFORMED THAT AN ACCIDENT AT THE SUMMER 16 PLANT HAD RELEASED SUFFICIENT RADIATION TO THE ENVIRONMENT TO

- 17 . DELIVER A DOSE OF 1,000 MILLIREMS TO A PERSON FIVE MILES FROM 18 THE ACCIDENT, IN YOUR OPINION, WHAT WOULD THAT PERSON CONCLUDE 19 ABOUT THE DANGER TO THEIR HEALTH OR SAFETY?

20 A. The chart says that the " level at which health effects can first 21 be detected" is 25,000 millirems. Given that the person could-22 read and understand the chart--and did not have independent infor-l 23 mation on the health effects of radiation--they would conclude 12 4 that their health was not in danger.

4 m

-e , .

--<g y .,. ,-r---, , ,m -

,- - p-.-. ,-- ,,,w , ~-

,,m . , - , , ,,,--.,_,,a -ww.-

'.. m 1!

"1 -

Q.- _ H0W WELL' D0 PEOPLE 'JEAL' WITH- INSTRUCTIONS IN A STRESS SITUATION? -

2. ' A. 'Whe'n =a person is~ aroused by stress or anxiety, their normal 3 capacity to comprehend and-follow a rational plan of action is - ,

~

4 s impai red.'

5- Q. ?ARE.THERE WAYS TO COMPENSATE'FOR THAT LOWERED CAPACITY TO COMPRE-6 HEND AND 40LLOW-A' RATIONAL PLAN OF ACTION IN A BR0CHURE?.-

.7 A. Certainly. One thing which.would help would be a much clearer 8~ ' set of instructions on what to do. We have.all seen first aid 9' f books or poison response brochures that~ do this very well. The

.10: . posters:in restaurants showing you how'to handle a choking victim 11 are excellent.

12

-13 This set of instructions must be written simplistically. They 14 should be visually displayed in a way that is easy .to follow.

15 For_ example, large letters should highlight the most'important  :

16 parts. The actions you should take should be set out step-by- ,

17 step. -And there should be visual space between the steps.

18

~

i 19 The necessary emergency information should tell people to tack it

'20 - up in a prominent place where you will be able to find it-in an 21- emergency, like o'n a door or the refrigerator. I am told that at 22' one nuclear plant, the brochure has a piece of " stickum" on it ,

i 23 so that you can stick it nn your refrigerator. You cannot expect '

24 or rely upon people to go searching through drawers or piles of

~

25 paper to find needed emergency instructions at a time of stress. ,

t w - w e v ,

g-. e.e-, .m r ys-e -- - ~ >wep--- e n ,,4 -

p e , pa , 4---

'n % .

e ~

m

,, -.:7-

1 .;Q. 00ES.THE. SUMMER BROCHURE' MEET-THESE CRITERIA 7' 2- ' A.: Definitely' noti. :The. instructio'ns on what to do in case of a

' 3 :- :n'uclear accident are left to the:last panel of four panels of.

.4 , dense text with small type. Few people are likely to' read that

-5 - far when they get the brochure.

64 ,

.7- The instructions are all run together.- The language, as-I noted 18 .before, would not be comprehensible to many people. The instruc-9- 2 tions are not set out clearly step-by-step. : They are not separated 10 ' by; visual space. Large type. is not used effectively.-

11.- ~Q. HOW BESIDES A BR0CHURE OF THIS TYPE COULD PEOPLE'BE INFORMED:

12- ABOUT-WHAT TO DO IN AN' EMERGENCY. SITUATION AND PREPARED TO ACT 13 APPROPRIATELY AND RATIONALLY IN AN ACCIDENT SITUATION 7 14 A. 'One of the test ways to prevent the stress induced confusion is 15 to train people by behavioral techniques in responding to '.ife 16 .or health threatening situations. As in good first aid training, 17- if you have been through the step-by-step process in training, 18 you can go tnrough it much more effectively when those learned 19 behaviors are called upon in an emergency situation.

20 21 A full-scale evacuation drill in which people step-by-step went

22. through all of the procedures as if there were a real accident 23 would provide that kind of training.

_24 Q. IF A PERSON COULD COMPREHEND THE MAP AND ITS CODES AND INSTRUCTIONS 25- BUT THE INSTRUCTIONS GIVEN OVER THE RADIO OR TELEVISION TOLD  :

1

'26 HIM OR HER TO TAKE A DIFFERENT EVACUATION ROUTE TO A DIFFERENT l

m ga -;

+ - . .

c - .~

q' m, ,g ~

' ~ ~

.' i.J ..

,g. .

g

, - tw ,4 _

m s- .

~

A

~

[

I'

RECEPTION CENTERL(BECAUSE10F; UN SUAL} WIND C ' ONDITIONS, FORfEXAMPLE),

r y

[ 2L ?WHATRES)0NSEC0dLDl,YOUEXPECTFROMTHAtPERSON?J 3 z Ah - Firs't,1they would- be confused and.much less likely to~act,in' a~- f y

'4 1wa'y td protect themselves. 1Thistedid'le'ad themitol mistrust both:

5 .. sources of information, which would in . turn' increase th'eir-Lan--

~6 Lxisty: level.__ . At worst, this:could lead:to_~a . state of panic.

' !7 i0r;they might simply act_ on- their owni judgement, which will lead ' '

'8 : to confusion as people' run every-which-way. .

i 'Q.-iH0W MIGHT THAT CONFOSION BE-ALLEVIATED?

, l10 :A. The map and theiaccompanying' route designations should be clearly ill. . labelled so. tha.t people willl be' told--as they look at and a're -

12; using the map--that the' designated routes are dependent on the 13' direction 'of- the wind and that the radio is the primary; source of.

x 14 information on which route to take.

g (15  ; Q. 1 WOULD PERIODIC BULLETINS-0N'THE RADIO OR TELEVISION.BE SUFFICIENT.

~

16 'TO KEEP PEOPLELINFORMED~ABOUT EMERGENCY ACTIONS THEY SHOULD TAKE?

17 'A. . Unless the emergency. radio stations are continuously broadcastingL g

18 the informa. ion.which people need to act upon, many people will-

-19 not wait 'around until' the radic iold them which evacuation route ic ,

,20 to follow. instead, they would follow the map even if that- took~

i .-

21- them into the area of danger.

22. Q. WHAT IS.YJUR. ASSESSMENT OF THIS BROCilVRE?

"23- A. This brochure at: pears designed to allay people's fears about radi-I24: c ation ant. nuclear power. There are numerous representations about 25 ' the safety of the plant and abouti the commonplace nature of radi-26~ - atier. That could cause residents in the vicinity of the plant i' ,

1

-t i t h

• , >-.w y re ,q ) . o ..-,y~.,%,.-c= v.,y----.y er,-+, - w,w,- ,,-w#, -, % w kr , r,c,,.y--.e..,,wyy.- -vw.-,-. 6,-%,- w-,v.- - ,_.,i.~,y

.c

_ : 9_

B l'- snot to take seriously.a-dangerous " situation or' to overreact.to

~

T2 . a; dangerous situation. cacause of not anticipating a ' grave ~ situation.>

3- - -

14' LSome -anticipatory stress _ is1a motivating _factoriin: acting ~ to pro -

~ ~

5 -tect oneself. Too little anticipatory ' stress could cause people 6- to'be unmotivated and to' respond inappropriately through inaction

~7 Lin a situation lwhere one's health and safety might be in danger.

81

~9 - -1It's 'just a matter of having respect for the nuclear facility.

10 EQh WHAT~ STAGES OF_ EMERGENCY ACTION DOES THE BROCHURE. CALL ON PEOPLE:

11 - T0 'TAKE IN CASE THEY HEAR THE WARNING SIRENS SOUNDED?

12 A. The brochure-tells them to go inside and tune 'into one of the 13 emergency broadcast radio stations.

14 15 They are then told that they_might be asked to evacuate or they 16 - might be told to remain indoors for awhile after closing all out-17 side doors and windows and shutting off all fans or air conditioners 18 which bring in outside air.

19 Q. -IN YOUR OPINION, WOULD PEOPLE BE LIKELY TO CLOSE THEIR D0 ORS AND 20 - WINDOWS AND TURN OFF FANS AN') AIR CONDITIONERS IF TOLD TO 00 S07 21 - A. No.' Many might try it for en hour or so. However, as anyone who 22 has spent a summer in South Carolina knows, it would the very dif-  ;

23 ficult to remain in that situation during the summer. After an

' 24- h'our of the heat-and humidity, most people would be more concerned 25 -about their need for fresh air than about the threat to their health from radiation. This is especially true for the many rural 27 people who live in robile homes.

e - e s ,

e , v ~ w - -, --ng - .-- - , +.r,,- - ~~~ ,

e-

g. .- , ,__

j--

, c I ' /.

~ -

110 ;.. <

j,' .,. ,

~

._ / ., ,

p _ _

1- )Q. ... IN

- -YOUR PROFESSIONAL 0 PINION AS 'A COMMUNITY SOCIAL WORKER ANDL A -

2, 1 COMMUNITY PSYCHOLOGIST, WOULD THIS-BROCHURE:BE AN EFFECTIVE TOOL-

~

13-1FOR PROVIDING-REASONABLE ASSURANCE THAT THE RESIDENTS IN;THE-

?4. -VICINITY 0F THE V.C. SUMMER NUCLEAR STATION WOULD BE ABLE~TO

~

5< RESPONDd'PPROPRIATELY-TOARADI'0LOGICALEMERGENCYANDTOACTT'0'

-6, ;PROTECTETHEIR HEALTH AND SAFETY?

7:

A .- No . .

8~ 'Q. DOES THIS CONCLUDE YOUR TESTIMONY?

19 1A.M Yes, it does.

+

I

• f f

i

.I J

-- 1

^'

d; .

1 VITA ,

~

'Arlene Bowers Andrews. Fall 1980-

Business Addre'ss: University' of: South Carolina

. Department of Psychology-Coltabia, S.C. 29208 ' .

Phone: 777-4864 Home Address: 1017 Wando Street Columbia, S.C. 29205 Phone: . 799-7377

~ Educational History University of South Carolina, Columbia, S.C. -29208 Major: EComunity. Psychology Degree: Currently working toward Ph.D.

= University of South Carolina, Coltabia, S.C. 29208

- Major: Community Social Work ~

Degree: M.'S.W., 1974-Thesis: . A Study of Coordination Efforts Among Agencies Serving-Delinquent-

-Youth in South Carolina Duke University, Durham, N.C. 27708 hhjor: Psychology Minor: Sociology Degree: B.A., Magna Cum Laude

, Honors: Phi Beta Kappa; Junior Class Honors; Dean's Li'st Professional Positions Coordinator, Richland County Coordinating Committee on Child Abuse and Neglect, Columb.ia, S.C. May 1977-August 1978

.- Duties: Solitar,'r staff to interagency committee; developed and coordinated implementatica of action plan for emergency, treataent, preventive, and educative programs aimed at child abuse and neglec., sponsored multi-disciplinary case consultation team for child protective service agency; liaison to promote interagency cooperation and policy change; grant writing; volunteer coordination; work with media; public speaking.

~

S.C. Governor's Office, Office of Social Development, Columbia, S.C.

Positions:

Director of Research and Evaluation, August 1976- April 1977

- Duties: Managed research and evaluation efforts of the Office of Social Development, including statewide needs assessment, routine performance monitoring, and plans for service evaluations; supervised interdisciplinary staff; coordinated with Director and Planning Director to develop office direction and management pitm.

e e.- J -,- ~y y .,m-, -e. ,,-+ v- -y w w%.-n ,y. * --.m, , - - - y g++e :-f

.0 , .

f

p. 1 Evaluation Coordinator, December 1975 - August 1976 Duties: Responsible for. design of evaluation process for the state

. Title XX social services' program; supervision and training of evalua--

tors; oversight of program reports; management of consultant contract;

.research and staff support to Administration and Evaluation Subcommittees

, of the State Social Services Advisory Comittee; participation in

. state,~ regional, and national meetings.

Social Services Planner, January 1975 - December'19_75' Duties': Participated in development of first state Title XX social services plan; contributed to design of planning and budgeting pro-cesses;. coordinated policy development for selected aspects of the

. program.

Planner, July.- 1974 - December 1974 Duties: Services integration and coordination . specialist;" staff support

.to State Social Develiment Policy Council; in-depth study of two arens -

information and referral and transportation; liaison between Council and state agencies.

Social Work Intern, S.C. Governor's Office, Office of Citizen S'ervices, Coltznbia,' S.C. September 1973 - May 1974 Duties: Involved frequent contact with state agencies for. response to a wide variety of citizen requests; served as a facilitator for state-

. wide workshop on comprehensive planning for human services.

Social erker, S.C. Department of Mental Retardation, Midlands Center for the Retarded, Columbia, S.C. Sumer (full time) and Fall (part time) ,1973 Duties: 'Re-establishing agency contact with families of 80 residents as part of de-institutionalization program; included home visits, social histories, parent training -workshops.

Social Work Intern, Columbio Area Mental Health Center, Child and- Adolescent Unit, Coltanbia, S.C. September 1972 - May 1973 Duties: Individual and family therapy with children, adolescents, and parents.

~ Professional Activities Academic Instructor,. University of South Carolina, Department of Psychology. Taught

" Psychology; of Marriage." July - December 1980.

Research . Assistant, University of South Carolina, Department of Psychology.

Design, compilation, coding, and programing for data analysis. September 1978 -'present.

Assistant Adjunct Professor, University of South Carolina, College of Social Work. Field instructor for graduate students. September 1976 - May 1978.

1<

l Consultation l South Carolina Stata Comittee for the International Year of the Child, 1

1

, e ., , , _ . . , .. .m,- , - - - .

7-

[o y. .

l*f L

k . . .

Columbia, S.C. Produced the report " Children in South Carolina: . Goals

/for.the 1980's" on behalf of the Comittee. Fall 1979.: Spring 1980.

South Carolina School Advisory Council Assistance Project, University of South Carolina, Department-of Education. With L.F. McClure and D. Kimbrell.

Prepared and conducted training-for school and citizen participants on school' advisory councils. Fall -1978.. - Spring -.1979.

^w . .

'U.S. Department of Health, Education, and Welfare, sub-contractee' to Susan.

Herzog, consultant. Develop model guidelines for. Title XX planning and evaluation. . Spring 1976. '

Selected Presentations .

" Child Abuse." S.C. ' Correctional . Association Annual Fall Conference, Columbia, S.C. With J.- Elliott, K. Jennings, and B. Chappell. Fa11 1980.

" Preventing Child Abuse and Neglect: Developing Natural Support Systems.'T

, Carolinas Primary Prevention Confernece, Myrtle Beach, S.C. Spring 1980.

"' Coordinating Comunity Service Systems - Building the Council on Child' Abuse and Neglect." South Carolina Psychological Association, Myrtle-Beach, S.C. Fall 1979.

" The Role of Law Enforcement in Child Abuse and Neglect." With L.F. McClure and D. Murday. Sponsored by the Council on Child Abuse and Neglect for ..

Midlands area, S.C., law enforcement agencies. Fall 1979.

Parenthood training:. working with parents of children under age 3. With R.A. Randolph. - For life skills workers, S.C. Department of Social Services, 1979. For homemakers in training, opportunities Industrial Center, 1978.

Selected Community Activities Board member (vice-chairperson), Richland County Department of Social Services, June 1979 - present.

Board member, Council on Child Abuse and Neglect, Inc., September 1978 - present.

Member, 5.C. State Committee for the International Year of the Child,1979.

Member, State Advisory Council, Alston Wilkes Advocacy for Youth, Sepember 1980 -'present.

Volunteer with Providence Home Women's Shelter, Fall 1979 - Spring 1980.

Board member, Palmetto Place (children's emergency shelter), Summer 1977-

~

Staner 1980.

Volunteer experience at group home for adolescent girls (1972); as " Big Sister"' to mildly retarded adolescent girl (1972-1974); with lleadstart

.(1969-1971); and as supervisor of two Neighborhood Youth Corps employees (1972).

g n.;

~

.3:,

'. 7  ! Research Activities i_nnProgress-Project tol train school children in social problem solving skills.- I..F. McClure,.

principal investigator, j

" _Research on attitudes and beliefs'about the use of physica] force in: intimate relationships- D. Fo11ingstad,; principal investigator..

' Contributor'to chapter on effects of. the physical environment for. book ':

on preventive psychology.f -A. Wandersman, principa1' investigator.

>g

-0

=

N s

L h

• I 4

9 s

s 4

-- , , , , - s-. .. ,, .., . -.an,, ,,.n,,... , . _ . . ~ , , , ,, .,.,.n

~

y, _ . - _

. ey;.- .

~~ - w UNITED STATES OF AMERICA' A NUCLEAR REGULATORY COMMISSION _'

7

,. ;In the hatter 0f:

'))L

~

1500TH CAROLINA ELECTRIC AND GAS

' )L Docket:No.-50-395 OL1 .. .. , ,

~ COMPANY,iet'al.

,)

-)

.(Virgil C. Summer Nuclear.-Station,

- ) .: :May 28, 1981' Unit'1)- )

)

s i

AFFIDAVIT OF SERVICE.

- PERSONALLY: appeared _ before me, John C. Ruoff, who duly affirmed that copies-of " Direct Testimony of- Arlene Bowers Andrews" and " Direct Testimony

~

of Janet H. Greenut, M.D." in.the above-captioned proceeding were served

~

upon the following persons by deposit, first class: postage pre-paid in' the United States mail this 28th day of Mayfl981.

, Herbert Grossman, Esq. Chair, Atomic Safety and Licensing Chair, Atomic Safety and Licensing Board: Board Panel

. Panel. ,

U.S. Nuclear Regulatory Connission.

U.S. Nuclear Regulatory Commission- - Washington, DC 20555 Washington, DC' 20555 George Fischer

'Dr. Frank F. Hooper Vice President-Legal Member, Atomic' Safety and Licensing - South C3r-'.ina Electric & Gas Co.-

Board Panel .

P.O. Box 764~

U.S. Nuclear Regulatory Commission columbia, SC ~29218 Washington,-DC 20555 Steven C. Goldberg, Esq.

Mr. Gustave A. Linenberger, Jr. Office of the Executive Legal Director-Member, Atomic Safety and Licensing U.S.' Nuclear. Regulatory Commission '

[ Board Panel Washington, DC 20555 U.S. -Nuclear Regulatory Commission i

Washington, DC' 20555 Mr. Brett Allen Bursey Rt. 1, Box 93-C Alan S. Rosenthal Little Mountain, SC 29075

• Chair, Atomic Safety and Licensing .

Appeal Board Panel Joseph B. Knotts, Jr. l i _ U.S. Nuc? ear Regulatory .Conmission Debevoise & Liberman JWashington', DC 20555 1200 17th Street NW Washington, DC 20036 .

Chase R. Stephens

. Docketing ~ and Service Section Office.of-the Secretary U.S. Nuclear Regulatory Connission Washington,.DC .20555

+

P r

f a

~c. /,.. ..~.) - _. , ,y.,,,,_,m c .p.. . . . . - -.,.v,-,._ _ . _ . , , , ,,,%9 p ,.,-r 4

6' ' -

ia m ,

' . e Richard P..-Wilson,'Esq.

~

.. Randolph R..Mahan, Esq. ~

. Assistant Attorney-General- .

South Carolina Electric & Gas Co.~

South-Carolina Attorney General's P.O.-Box 764 -

Office ~ Columbia, SC'-29218-P.O. Box-11549 Columbia,1.SC 29211-q'

/-

John C. Ruoff [/[

AFFIRMED and subscribed to before me '

this-LMf day of h A 4 1981.

J- ,

Y bb$ '

N'0TARY PUBLIC FOR SOUTH CAROLINA.

My Commission Expires: Y h, [Y[7 J

f

,