ML20028D194

Testimony of DC Bley & DC Richardson Re Commission Question 2 & ASLB Question 2.2.1.Risk from Plants Extremely Low Due to Safety Features in Plant design,NRC-ordered Safety Improvements & Util Improvements.Certificate of Svc Encl

ML20028D194
Person / Time
Site:	Indian Point
Issue date:	01/12/1983
From:	Dennis Bley, Richardson D CONSOLIDATED EDISON CO. OF NEW YORK, INC., PLG, INC. (FORMERLY PICKARD, LOWE & GARRICK, INC.), POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
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ML20028D192	List: ML20028D191 ML20028D194
References
ISSUANCES-SP, NUDOCS 8301170221
Download: ML20028D194 (18)

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UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION 1

l

' ATOMIC SAFETY AND LICENSING BOARD '

Defore Administrative Judges:

James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris i

)

In the Matter of )

l )

CONSOLIDATED EDISON COMPAtlY OF ) Docket Nos.

NEW YORK, I!!C. ) 50-247 SP (Indian Point, Unit No. 2) ) 50-286 SP

! )

POWER AUT!!ORITY OF THE STATE OF ) Jan. 12, 1983 NEW YORK )

(Indian Point, Unit No. 3) )

{ LICENSEES' TESTIMONY OF DENNIS C. BLEY AND DENNIS C. RICHARDSOli ON COMMISSION OUESTION 2 AND BOARD OUESTION 2.2.1 ATTORNEYS FILING THIS DOCUMENT:

i Brent L. Brandenburg Paul F. Colarulli CONSOLIDATED EDISON COMPANY Joseph J. Levin, Jr.

OF NEW YORK, INC. MORGAN ASSOCIATES, CHARTERED 4 Irving Place 1899 L Street, N.W.

New York, New York 10003 Washington, D.C. 20036 (212) 460-4600 (202) 466-7000 8301170221 830112 PDR ADOCK 05000247

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I. TESTIMONY ON COMMISSION OUESTION 2 --

DIRECTOR'S CONFIRMATORY ORDER A. INTRODUCTION My name is Dennis C. Bley. I am a consultant in reliability, risk, and decision analysis for electrical generating plants at Pickard, Lowe and Garrick, Inc. I was a principal investigator on the Indian Point Probabilistic Safety Study. A statement of my profesional qualifications is attached.

My name is Dennis C. Richardson. I am the Risk Assess-ment Technology Manager in the Nuclear Safety Departmen,t of the Nuclear Technology Division of Westinghouse Electric Corporation. I was a principal investigator on the Indian Point Probabilistic Safety Study. A statement of my pro-fessional qualifications is attached.

This section of the testimony addresses the following portion of Question 2 of the Commission's Memorandum and Order.

Uhat improvements in the level of safety j will result from measures required or referenced in the Director's Order to the licensee, dated February 11, 1980?Ill l

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1. The parenthetical portion of Commission Question 2 is omitted herein. The contentions undet that portion of j Commission Question 2 are addressed in other testimony.

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B. IMPACT OF DIRECTOR'S CONFIRMATORY ORDER ON THE SAFETY OF INDIAN POINT At the time of the Director's Confirmatory Order, February 11, 1980, no plant-specific probabilistic risk assessment (PRA) of the Indian Point nuclear power plants existed. Lacking a plant-specific PRA, a broad approach addressing potential risk contributors was ordered by the Commission. That order concentrated on important contrib-utors to risk identified in previous generic. risk studies, as well as contributing causes in reactor plant accidents such as the one at Three Mile Island. Additionally, these previous risk studies did not concentrate on external initiating events. Therefore, the measures contained in the Order primarily focused on reducing the risk from internal initiating events.

Now that the plant and site-specific PRA, the Indian Point Probabil.istic Safety Study (IPPSS), is completed and the dominant contributors to risk from Indian Point have been identified, the items ordered by the Director have been assessed to determine their impact. For the dominant t scenarios in earlier generic studies, the items in the Director's Order dealing with improved training and onsite technical capability are important. The new diesel gener-ator testing requirements will enhance reliability should failures begin to be observed. Such failures have not yet occurred at Indian Point. The use of the gas turbines <

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I provide reduction factors of 40 and 7 in the frequency of late overpressurization containment failures from internally I

initiated events for Unit 2 and Unit 3, respectively.

Improvements in gas turbine reliability would reduce the already low latent health effects contribution attributable to loss of AC power (1.0 x 10-6 per reactor year at Indian Point 2 and 4.8 x 10-7 per reactor year at Indian Point 3). Prior to the Director's Order, reliability data for the

! gas turbines were not recorded; thus, reductions in risk have not been quantified. The improvements in auxiliary feedwater system reliability are substantial but do not significantly affect the risk because the IPPSS found that rare " external events" dominate the risk at both units.

Because external events were not specifically addressed i

in the Director's Order, the overall quantitative impact of the Order on plant risk is modest but positive. These con-clusions are consistent with results of a previous Commis-l sion evaluation (Task Force Report on Interim Operation of Indian Point, NUREG-0715, Aug. 1980).

C. MODIFICATIONS IN EOUIPMENT AND PROCEDURES The Indian Point plants are under continuous review by both the utilities and the Commission to determine if mod-ifications to equipment or procedures would result in signi-ficant safety enhancement. When warranted, such changes have been implemented.

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During the course of performing the IPPSS, certain areas were identified for improvement. Both Con Edison and 4

the Power Authority have undertaken to implement these plant improvements and have accordingly f actored them into the IPPSS plant model. These improvements were identified with the submittal of the IPPSS.

The following improvements were made at Indian Point 2 and 3:

' (1) Implementation of a refueling interval surv,eil-lance test to verify disc integrity for RHR valves MOV-730 and MOV-731.

(2) Implementation of a refueling interval surveil-lance test to verify disc to stem integrity for spray valve 869A (such verification is already accomplished for redundant valve 869B in the course of performing normal refueling operations).

(3) Implementation of changes to refueling interval surveillance test to clarify test method and data recording for accumulator discharge valve flow '

verification check.

(4) Implementation of procedures to periodically verify that: (a) the service water pumps designated for essential header service are in fact aligned to the required essential services (i.e., field valve alignment check), a r.d (b) the position of the control room service water system mode selector switch is such that the correct set of service water pumps is selected for automatic essential header service.

(5) System modification, procedural change or verifi-cation testing to ensure that sufficient backpres-

' sure will be maintained in the service water system to prevent service water pump overload for cases in which only one service water pump is operating with the system in accident configuration.

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The following improvements were made at Indian Point 2 only:

(1) Rearrangement of diesel generator fuel oil trans-fer pump power supplies such that the primary transfer pump for each diesel is powered from one of that diesel's electrical buses.

(2) Replacement of manual isolation valves with motor operated isolation valves in certain of the fan cooler service water discharge lines.

(3) Seismic cushioning of the control building roof.

(4) Enhancement of installed alternate shutdown system.

Examples of Commission-initiated safety improvements which are modeled in the IPPSS and are being implemented at the plants include:

(1) Implementation of masonry wall upgrading modifica-tions for station batteries in response to IE Bulletin 80-11.

(2) Additional fire protection as specified in Appendix R to 10 C.F.R. Part 50.

(3) Items covered in the Director's Order.

(4) Various post-Tf1I requirements.

1 D. CONCLUSIONS Based upon the safety features in the basic Indian Point designs, the safety improvements ordered by the Director and other Commission-initiated improvements, and the equipment and procedure improvements made by the utilities as a result of the IPPSS analysis, the risk from the Indian Point plants is extremely low, l

II. TESTIMONY ON BOARD OUESTION 2.2.1 The implementation of the July 29, 1982 draft of the proposed generic Steam Generator Owner's Group requirements at the Indian Point units would not perceptibly change the risk posed by the units as set forth in Figures 8.1-3 and 8.1-6 of the IPPSS, nor change in any way the conclusion of IPPSS that steam generator tube rupture events are not dominant risk contributors at these units.

N A'E DENNIS 0. ELEY EDUCATION Pn.0. , Nuclear Reactor Engineering, Massacnusetts Institute of Tecnnci o gy , 1979.

C0urses in nuclear engineering and ccmouter science, Cornell Universi y, 1972-1974 4

U.S. Navy Nuclear Pcwer School,1968.

Universi y of Cincinnati, 3.5.E.E. ,1967.

Courses in Ma:nematics and Physics, Centre C0llege of Kentucky, 1961-1963.

PRCFESSIONAL EXPERIENCE General Summary A consultant at ?ickard, Lowe & Garrick, Inc.,1979-present. Technical analysis of power plant availaoility and risk. Cost-benefit analysis of poser plant system changes. Preparation of technical recor:s, excer:

testimony, and proposals. Supervision Of the tecnnical quality of PLG reports and direction of some ?LG projects. Instruct:r at avaiiacility, ri sK , and decision analysis courses offered by PLG, Oyster Creek Probabilistic Risk Assessment (OPSA). Assisted in the comoletion and l

review of this complete risk assessment of an operating SWR cerformed for

! Jersey Central Pcwer & Lign:. Work Order Scheculing System (WOSI).

Assisted in cavelocing the San Onofre 2 and 3 plant mocel for a ccm:u er cased work order orioriti:ing, scheduling, and record keeping system for Soutnern California Edision Ccmpany. Steam Tur:ine Diagnostics Cost-Benefi: Analysis. Developed and applied a procedure for evaluating diagnostic alternatives for E?RI. Reliability Analysis Of Diaolo Canyon Auxiliary Feedwater System for Pacific Gas & Electric. Midland Plan Auxiliary Feedwater System Rel f acility Analysis for Consumers Pcwer.

Tecnnical Review of the "Offi.ce of Emergency Services Recommended Emergency ?lanning Zone Considerations..." for Soutnern California Edison. Prioriti:ation of NRC Acticn Plan for NSAC. Development of a metnodology and participation in an AIF workshop to apply it for EPRI/NSAC. Zion and Indian Point Probabilistic Safety Stucies. Me:ncds develo; ment, systems analysis, and plant modeling. 0:ner ? ras--LaSall e, 3rcwns Ferry, Midland, Pilgrim 1, and Ocenee.

On USS Enterprise, Reactor Training Assistant, E months, 1971.

Res onsible for tecnnical training of approximately 400 nuclear trained officers and men prior to annual safeguards examination. Propulsion Pl an Station Officer, 9 months, 1970-1971. Responsible for maintenance and operation of one propulsion plan: (:wo reactors, eight steam generators, and associated ecuipment) during pcwer range testing of new reactors and curing deployment. Approximately 50 enlisted personnel were assigned to the olant. Shift ?reculsion Plant Wat:h Officer,15 months, 1969-1970. Supervised a crew of acou: 20 navy enlisted operat:rs anc many shioyard workers en 5-hcur shift rotation conducting maintenance e eak

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. . v. 9 and testing in one procuision plant during refueling-overnaul. Shioboarc cualifications: Propulsion Cuty Officer, responsiole for all cropulsion ecutoment during absence of Reactor Officer and Engineer Officer.

Engineering Officer of ne Wat:n, coerational aat:n in Centrai Control, resconsible for all procuision and engineering scuipment and wa :n stancers. Propuision Plan- Wat:n Officer, operational wa :h in one crocuision plant, directed and responsible for all operations in ne plant.

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A: Cincinnati 3 ell, Plant staff assistant, 4 mon hs,1967. Worked in central office and transmission grous sucolying technical assistance ::

the line organization. Cooperative trainee, 3 years,1964-1967, work-study program with alternate three montn periods at the University of Cincinnati.

Chronological Summary '

1979-? resent Consultant, Pickard, Lowe and Garrick, Inc.

1374-1979 Massacnusetts *nstitute of Tecnnology.

Research assistant for Department of Energy LWR Assessment Project. Teacning assistant in engineering of nuclear reactors.

Summer 1976 Nortneast Utilities.

Engineer: economy studies, plant startup, analysis of i physics tests.

1967-1974 U.S. Naval Reserve, active duty.

Instructor of naval science, Cornell University, 1971-1974; Reactor Department of USS Enterprise, deployment and refueling-overhaul, 1969-1971;

. Nuclear ?cwer training program and Officer Candidate l

School, 1967-1969.

1964-1967 Cincinnati Bell.

Plant staff assistant and work-study program trainee.

MEMBERSHIPS, LICENSES. AND HONORS The Society for Risk Assessment.

Institute of Electr: cal and Electronics Engineers.

American Nuclear Society.

Anerican Association for the Advancement of Science.

The New Yor< Acacemy of Sciences.

U.S. Naval Reserve, Commander.

Registered Nuclear Engineer, State cf California.

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BLEY - 3 Sigma Xi (national science henors society),1975.

Sherman R. Knaco Fellcwsnip (Northeast Utilities), 1975-1975.

Sl oan Research Traineesnip, 197'-1975.

E a Kappa Nu (national electrical engineering hences society),1957.

REPORTS AND PUBLICATIONS "Seabrock Procabilistic Safety Assessment," Puolic Service Company of New Hampshire, to ce puolished in 1933.

Pickard, Lowe and Garrick, Inc., "Midlano Pr00acilistic Risk Assessment,"

Consumers Power Company, to be puolished in 1982.

Cconee Probabilistic Risk Assessment," a joint effort of the Nuclear Safety Analysis Center, Duke Pcwer, and otner participating utilities, to be published in 1932. .

Tennessee Valley Authority and Pickard, Lewe and Garrick, Inc., "Br wns Ferry ?rcoacilistic Risk Assessment," :: be puolished in 1932.

Acestelakis, G. , M. Ka:arians, anc D. C. Bley, "A Methodology for Assessing the Risk from Caole Fires," accepted for puolication in Nuclear Sa fe ty, 1932.

Kaplan, S. , H. F. Perl a, and D. C. Sley, "A Methodclogy for Seismic Safety Analysis of Nuclear Power Plants," procosed presentation at tne International Meeting on Thermal Nuclear Reactor Safety, Chicago, Illinois, August 29-September 2,1932.

Sl ey, D. C. , S. Kaolan, and B. J. Garrick, " Assembling and Deccaposing FRA Results: A Matrix FormaTism," proposec presentation at the International Meeting on Thermal Nuclear Reactor Safety, Chicago, Illinois, August 29-Septemoer 2,1952.

Garr1c<, 3. J. , S. Kapl an, and D. C. 31 ey, "Recent Advances in Probabilistic Risk Assessment," prepared for the MIL Nuclear Pcwer Reactor Safety Course, Camoridge, Massacnusetts, July 19, 1982.

Fleming, K. N. , S. Kaplan, and 5. J. Garrick, "Seabrock Precabilistic Safety Assessnent Management Plan,"PLG-0239, June 1982.

Garrick, S. J. , " Lessons Learned From First Generation Nuclear Plan:

Probabilistic Risk Assessments," to be presented at the '4crkshco en L w-Procacility/High-Consequence Risk Analysis, Arlington, Virginia, June 15-17,1952.

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3arrick , 3. J. , S. Xaol an, D. C. Iden, E. 3. Cl evel and, H. F. Perl a, D. C. Bley, D. W. Stillwell, H. V. Scnneicer, and G. Acostolakis, "P0wer Pl ant Avail ability Engineering: Methods of Analysis Program Planning, and Applications," EPRI NP-2153, PLG-0165, May 1932.

Sl ey, D. C. , anc R. J. Mulvihill, "Ccmments en Evaluation of Availacility Imorovemen: Options for Moss Landing Units 5 and 7," PLG-0225, Maren 1932.

Stillwell, D. W. , G. Acos:clakis, D. C. Bl ey, P. H. Raabe, R. J. Mulvinill, S. Kaolan, and 3. J. Garricx, "EEI Avail ability HancbocK," ?LG-0213, January 1932.

I Bley, D. C. , L. G. H. Sarmanian, and D. W. Stiliwell, "Reliacility Analysis of Safety Injecticn System Modification, San Onofre Nuclear Generating Station - Unit 1," PLG-0205, October 1931.

" Zion Pr:bacilistic Safety Study," Commonwealth Edison C:mpany,

), Septemoer 1931.

Su;temer, D. R., "Anclysis of Postulated Accicents During Lcw Power Testing at :ne San Cncfre Nuclear Generating Station--Unit 2," PLG-0199, Seo:emoer 1981.

Sl ey, D. C. , D. W. Stillwell, and R. R. Fray, "Reliacility Analysis of Diablo Canycn Auxiliary Feecwater System," presented at the Tentn Biennial Tooical Conference en Reactor Operating Experience, Cleveland, Ohi o, August 17-19, 1931.

Garrick, 3. J. , and D. C. Sl ey, " Lessons Learned from Current PRAs,"

presented :: :ne ACRS Subc:=mittee on Reliacility and Probabilistic Risk

As sessnent, Los Angeles, California, July 23, 1981.

Kapl an, S. , G. Apost:lakis, 3. J. Garrick, D. C. Bley, and K. Woodard, "Metnodology for Procacilistic Risk Assessment of Nuclear ?:wer Plants,"

draf t version cf a book in precaration, ?LG-0209, June 1931.

Pe rl a, H. .~. , "Proj ect Pl an: Precasilistic Risk Assessment, Midland Nuclear Pcwer Plant," PLG-0150, May 1981.

31 ey, D. C. , C. L. Cate, D. W. Stillwell, and B. J. Garrick, "Midl and Plant Auxiliary Feecsater System Reliability Analysis Synopsis,"

?LG-0155, March 1931.

Pickard, Lowe and Garrick, Inc., "A Me nodology :: Cuantify Uncertainty cf Cos: cf Electricity for A1: err. ate Designs of (00m:us ion) Turoine Comsined Cycle Pl ants," PLG-0152, Maren 1931.

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Garrick, 3.. J. , S. Ahmed, and D. C. Bley, "A Methodology for Evaluating 4

the Costs and Senefits of Power Plant Diagnostic Tecnnicues," suomitted for presentation a: the Nin:n Turocmacninery Symposium, Houston, Texas, Decemoer 9-11, 1980.

Pickard, Lowe anc Garrick, Inc. , " Seminar: Probacilistic Risk Assessmen:

of Nuclear Power Plants," PLG-0134, Novemoer 1980.

li l Pickard, Lowe and Garrick, Inc. , " Project Pl an: Procacilistic Risk

Assessment, Browns Ferry Nuclear Plant Uni

1," PLG-0149, October 1930.

1 Garrick, 3. J. , S. Kapl an, D. C. Iden, E. 3. Cl evelanc, H. F. Perl a, D. C. Bley, and D. W. Stillwell, "Pcwer Plant Availability Engineering, i

Methods of Analysis - Program Planning - Applications," 2 Vols.,

PLG-0148. October 1980.

Bl ey, D. C. , C. L. Cate, D. W. Stillwell, and 3. J. Garrick, "Midl and Plant Auxiliary Feecsater System Reliability Analysis," PLG-Ola7, Octocer 1980.

Sl ey, D. C. , D. M. Wheeler, C. L. Cate, D. W. Stillwell . and l 3. J. Garrick, " Reliability Analysis of Diaolo Canyon Auxiliary Feecwa ar

! Sy stem," PLG-0140, September 1930.

4 Garrick , 3. J. , et al, " Project Plan: Oconee Probacilistic Risk i As sessnent," PLG-0138, August 1980.

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! Garrick, 3. J. , D. M. Wheel er, E. 3. Clevel and, D. C. Bl ey, i L. H. Reichers, and C. 3. Morrison, "Goerating Experience of Large i

U.S. 5:aam Turoine-Generators; Volume 1 - Data, Volume 2 - Utility Di rectory," PLG-0134, June 1980.

1 Garrick , 3. J. , S. Xaplan, and D. C. Bl ey, " Seminar: Pcwer Pl an:

Procabilistic Risk Assessment and Reliability," PLG-0127, May 1980.

i Garrick, 3. J. , and S. Kaplan, "0yster Creek Probacilistic Safety Anal-ysis (OPSA)," presented at the ANS-ENS Topical Meeting on Thermal Reactor Safety, Knoxville, Tennessee, April 3-11, 1980.

Garrick, 3. J. , S. Xaplan, G. E. Apostolakis, D. C. 31ey, and T. E. Potter, " Seminar: Probacilistic Risk Assessment as Applied to l Nuclear Power Plants," PLG-0124, March 1980.

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Garrick, 3. J. , S. Ahmed, and D. C. Bley, "A Metnodology for Evaluating tne Costs and Benefits of Pcwer Plan: Diagnostic Tecnnicues," PL3-01'S, January 1930.

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i Kacl an, S. , 3. J. Garrick, and D. C. El ey, "No tes on Ri sk, ?rcoacili ty, and Decision," ?L3-0113, Novemcer 1979.

i Bl ey, D. C. , C. L. Cate, D. C. Iden, 3. J. Garrick, anc J. M. Mucson,

" Seismic Safety Margins Research Program (?hase !), Prcject VII - Systems Analy si s," PLG-0110, Se:::emoer 1979.

.) Ca a, C. L. , and 5. J. Garrick, "W-501 Comoustion Turcine Star-ing P.el f acility Analysis," PLG-01C3, June 1979.

j Pickard, Lcwe and Garrick, Inc., " Plan: Availacility Program Scecifica-tien, San Oncfre Nuclear Generating Station," Marcn 1979.

I Pickard, Lcwe and Garrick, Inc. , " Work Order Scheduling System, Design j Speci fication," March 1979.

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Dennis C. Richardson - Risk Assassrent Technology Manager Penn State Universi y, B.S. Aerorpace Engineerir.;

19c3 M.S. Controi Engineering 1965 ,

San Giego State University, M.S. Mathmatics 1970 Unf verstty of P1ttsburgh, MBA 1980 Mr. Richardson has many years of professional and canagement experierce in the nuclear field. He joirad the Pressurized Water F4 actor Division of Westinghouse in 1972 where he manaced the Reactor Protection Analysis Group for perfoming nuclear plant safety analysis and, most recencly, has canaged the Risk Assess = enc Technology Organization.

Prior to this, Mr. Richardson was wi ,h Gulf General Atomic where ne worked on design of contrei and safety systecs for the gas-cooled nuclear plant. At Westinghouse, he has parcicipated in and directed a mober of risk assessment and safety analysis studies for a wide variety of applications. He was a. principal investigator in both the Zion Sta-tion and Indian Point Station Resctor Safety Studies. He directed tne PRA studies for the Westin;nouse Owrers Group that addressed the Post-TM1 NUREG requirecents on ecergency procecures and operator display requi recents. Mr. Ricnardson was tecnnical and program manager for the Britisn (NHC) Reference Water Reactor Safety Stuoy. He has aise led the development of econocic and financial rf sk assess =ent techniques for the use in new reacter model design concepts.

Mr. Richardson is a mecber of the IEEE and ANSHe andishas se-vedthe reviewing on sec-the Wrking groups for two standards corrittees.

tions for the PRA canual directed by MRC to be finished in 1981. He is author or co-author of more than 15 reports and papers dealing with risk l assessment and varicus aspects of nuclear plant design l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P. Gleason, Chairman Frederick J. Shon Dr. Oscar H. Paris

)

In the Matter of )

)

CONSOLIDATED EDISON COMPANY OF ) Docket Nos.

NEW YORK, INC. ) 50-247 SP (Indian Point, Unit No. 2) ) 50-286 SP

)

POWER AUTHORITY OF THE STATE OF ) Jan. 12, 1983 NEW YORK )

(Indian Point, Unit No. 3) )

)

CERTIFICATE OF SERVICE l

I hereby certify that on the 12th day of January,1983, I caused a copy of (1) Licensees' Testimony of Dennis C.

Bley on Contention 2.2(a) and (2) Licensees' Testimony of Dennis C. Bley and Dennis C. Richardson on Commission Ques-tion Two and Board Question 2.2.1 to be served first class mail, postage prepaid, on the following:

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James P. Gleason, Chairman Charles M. Pratt, Esq.

Administrative Judge Stephen L. Baum, Esq.

Atomic Safety and Licensing Board Power Authority of the 513 Gilmoure Drive State of New York Silver Spring, Maryland 20901 10 Columbus Circle New York, New York 10019 Mr. Frederick J. Shon Administrative Judge Janice Moore, Esq.

Atomic Safety and Licensing Board Counsel for NRC Staf f U.S. Nuclear Regulatory Of fice of the Executive Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Oscar H. Paris Administrative Judge Brent L. Brandenburg, Esq.

Atomic Safety and Licensing Board Assistant General Counsel U.S. Nuclear Regulatory Consolidated Edison Company Commission of New York, Inc.

Washington, D.C. 20555 4 Irving Place New York, New York 10003 Docketing and Service Branch Office of the Secretary Ellyn R. Weiss, Esq.

U.S. Nuclear Regulatory Commission William S. Jordan, III, Esq.

Washington, D.C. 20555 Harmon and Weiss 1725 I Street, N.W., Suite 506 Joan Holt, Project Director Washington, D.C. 20006 Indian Point Project New York Public Interest Research Charles A. Scheiner, Co-Chairperson Group Westchester People's Action 9 Murray Street Coalition, Inc.

New York, New York 10007 P.O. Box 488 White Plains, New York 10602 Jeffrey M. Blum, Esq.

New York University Law School Alan Latman, Esq.

423 Vanderbilt Hall 44 Sunset Drive 40 Washington Square South Croton-On-Hudson, New York 10520 New York, New York 10012 Ezra I. Bialik, Esq.

Charles J. Maikish, Esq. Steve Leipzig, Esq.

Litigation Division Environmental Protection Bureau The Port Authority of New York New York State Attorney and New Jersey General's Of fice One World Trade Center Two World Trade Center New York, New York 10048 New York, New York 10047 Alfred B. Del Bello l Westchester County Executive Westchester County 148 Martine Avenue White Plains, New York 10601

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Andrew S. Roffe, Esq.

New York State Assembly Albany, New York 12248 e -

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1 Marc L. Parris, Esq. Atomic Safety and Licensing Eric Thorsen, Esq. Board Panel County Attorney U.S. Nuclear Regulatory Commission County of Rockland Washington, D.C. 20555 11 New Hempstead Road New City, New York 10956 Atomic Safety and Licensing Appeal Board Panel Phyllis Rodriguez, Spokesperson U.S. Nuclear Regulatory Commission Parents Concerned About Indian Washington, D.C. 20555 Point P.O. Box 125 Honorable Richard L. Brodsky Croton-on-Hudson, New York 10520 Member of the County Legislature Westchester County Renee Schwartz, Esq. County Of fice Building Paul Chessin, Esq. White Plains, New York 10601 Laurens R. Schwartz, Esq.

Margaret Oppel, Esq. Zipporah S. Fleisher Botein, Hays, Sklar and Hertzberg West Branch Conservation 200 Park Avenue Association New York, New York 10166 443 Buena Vista Road New City, New York 10956 Honorable Ruth W. Messinger Member of the Council of the Mayor George V. Begany City of New York Village of Buchanan District #4 236 Tate Avenue City Hall Buchanan, New York 10511 New York, New York 10007 Judith Kessler, Coordinator Greater New Ycrk Council Rockland Citizens for Safe Energy on Energy 300 New Hemstead Road c/o Dean R. Corren, Director New City, New York 10956 New York University 26 Stuyvesant Street David H. Pikus, Esq.

New York, New York 10003 Richard F. Czaja, Esq.

Shea & Gould Joan Miles 330 Madison Avenue Indian Point Coordinator New York, New York 10017 New York City Audubon Society 71 West 23rd Street, Suite 1828 Amanda Potterfield, Esq.

New York, New York 10010 Johnson & George 528 Iowa Avenue Richard M. Hartzman, Esq. Iowa City, Iowa 52240 Lorna Salzman Mid-Atlantic Representati're Ruthanne G. Miller, Esq.

Friends of the Earth, Inc. Atomic Safety and 208 West 13th Street Licensing Board Panel New York, New York 10011 U.S. Nuclear Regulatory Commission Stanley B. Klimberg, Esq. Washington, D.C. 20555 General Counsel New York State Energy Office 2 Rockefeller State Plaza Albany, New York 12223

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Mr. Donald Davidoff Director, Radiological Emergency Preparedness Group Empire State Plaza Tower Building, Rm. 1750 Albany, New York 12237 Craig Kaplan, Esq.

National Emergency Civil Liberties Committee 175 Fifth Avenue, Suite 712 New York, New York 10010 Michael D. Diederich, Jr., Esq.

Fitgerald, Lynch & Diederich 24 Central Drive Stony Point, New York 10980

Steven C. Sholly j Union of Concerned Scientists 1346 Connecticut Avenue, N.W.

Suite 1101 Wa shing ton , D.C. 20036 Spence W. Perry Office of General Counsel j Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472 Stewart M. Glass

. Regional Counsel Room 1349 Pederal Emergency Management Agency 26 Federal Plaza New York, New York 10278 i

Melvin Goldberg Staff Attorney New York Public Interest Research Group j

9 Murray Street New York, New York 10007 Jonathan L. Levine, Esq.

P. O. Box 280 New City, New York 10958 Paul F. ColaYDlli

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