ML20072D624

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Motion for Immediate Reconsideration of Commission 830610 Order CLI-83-16 Permitting Continued Plant Operation. Commission Did Not Consider Current Status of Emergency Planning in Decision.Certificate of Svc Encl
ML20072D624
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/22/1983
From: Holt J
PUBLIC INTEREST RESEARCH GROUP, NEW YORK
To:
NRC COMMISSION (OCM)
References
CLI-83-16, NUDOCS 8306230346
Download: ML20072D624 (12)


Text

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NEW york pUblIC INTEREST RESEARCl1 OgR30p,IN NYPIRG 9 Murray Street e New York, N.Y.'10007 (212) 349-6460 n

ofaces ire Acany. Boghannon. Bu aio. Carnand. Frodorma. Long Island. New Pena New York Cay, magara Fa s.

s Syracuse. Utca

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UNITED STATES OF AMERICA C NUCLEAR REGULATORY COMMISSION g [ t Q d(jj; -

Before the Commission:

NunziotJ.Palladino,Chairma[n- g 19gy# b t:./e Victor Gilinsky q "e John F. Ahearne en$(% @ '

Thomas M. Roberts cv /

James K. Asselstine N

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In the Matter of (

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CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (

(Indian Point, Unit 2) ( Docket Nos.

( 50-247 POWER AUTHORITY OF THE STATE OF NEW YORK ( 50-286 (Indian Point, Unit 3) (

(

June 22, 1983 NYPIRG MOTION FOR IMMEDIATE RECONSIDERATION COMMISSION ORDER OF JUNE 10,1983 (CLI-83-16)

Based on the following considerations, the New York Public Interest Research Group, Inc. (NYPIRG) urgently requests the Commission to reconsider its June 10,1983 order (CLI-83-16) permitting continued operation of the Indian Point nuclear power plants:

1. In the absence of either sufficient time to review the specific findings contained in the FEMA /RAC review of June 8,1983 (received one day prior to the Commission vote), or a briefing by FEMA representatives regarding these findings, the Commission could not have based its decision on a detailed understanding of the current status of emergency planning and preparedness at The New York Public Interest Research Group, Inc., (NYPIRG)is a not-for-proftt, nonpartlaan research and advocacy organization established, directed ered supported by New York State College and university students. NYPIRG's staff of lawyers, researchers, scientists and orDanizers works With Studer 1t3 and other Citizens, dowe60 ping Citizenship S3dlis and shaping A policy. Coneumer prOtsClictb energy, MaCal rW9ponsibili political refosm and ancial instica are NYPfRG'e atrincipal areas of Concern B306230346 830622 / Co PDR ADOCK 05000247 G PDR 4 QU ) -

- * . . NYPIRG Motion paga 2

~ Indian Point. Indeed, the wording of the order itself and the additional views of Chairman Palladino and Commissioners Roberts and Ahearne make it clear that the majority based its June 9th decision not on the detailed item-by-item ratings and comments contained in the FEMA /RAC review, but rather on the subjective, inconclusive, and conditional statements of the FEMA cover letters. It is noteworthy that these statements were interpreted in totally opposite ways by the Commission majority and the Commission minority. NYPIRG finds it incredible i

that a decision in which one Commissioner's vote determined the outcome of a matter affecting the health and safety of over a quarter of a million people, could have been made without a careful analysis of the FEMA /RAC findings.

2. What the FEMA /RAC review of the interim State compensating measures for Rockland County reyeals, -is that the State plan is seriously inadequate in many of the planning areas most crucial to successful emergency response capability.

For example, Planning Standard (0), Radiological Emergency Response Training, was rated inadequate by the RAC on all elements for the simple reason that the State failed to include provisions for training of emergency response personnel in its compensating plan for Rockland County. No plan can possibly be deemed implementable until training procedures have been fully developed and all necessary personnel have been trained.

Planning Standard (J), Protective Response, gets to the heart of whether or not a capability exists to evacuate or relocate the public in the event of a serious radiation release. An analysis of elements in this area rated unacceptable by the RAC shows that: (1) Evacuation routes have not been fully developed nor evacuation route maps yet been made available. (2) Incon-sistencies exist in the plan wi a respect to the numbers of buses and drivers required to ' evacuate the transit-dependent population--i.e. , the State plan-

NYPIRG Motion - page 3 does not provide for enough drivers, enough vehicles, or enough evacuation routes or pick-up points. "The total number of bus routes and pickup points identified is apparently fewer than in the original plan. Similarly, it is not clear that sufficient ambulance transportation is available for the popu-lation identified as mobility-impaired requiring special transportation."

(FEMA /RAC review, page 11) The Commission should note that element J.10.g, "Means of Relocation," is not only rated inadequate at this time by the RAC, but is likely to remain so until a new transportation study is concluded and tested for Rockland County.

Planning Standard (N), Exercises and Drills, is rated inadquate l

across the board--i.e., the plan lacks written provisions for testing the State's capability to implement its compensating plan for Rockland County. Not only is a full-scale exercise required, but provisions must be developed for periodic drills of a variety of emergency response components. The bottom line is that until the State has fulfilled the requirements of this planning standard, and it has been re-evaluated by FEMA /RAC, the State's compensating

. plan for Rockland County cannot be considered implementable.

NYPIRG cannot understand why the FEMA /RAC review did not rate Planning Standard (G), Public Education and Information, inadequate, particularly in light of its comments that "...the public information brochure has not been developed and distributed" and "...the final development of this material must await finalization of the plan /and/ has not been included and cannot be

-evaluated at this time." Although some sort of " alternate" public education and information program is apparently contemplated, this has not yet been revealed or evaluated. If the State manages to fulfill its 30-day commitment regarding this planning element (on paper), NYPIRG doubts that an " alternate" public information program can be effectively implemented in a timely fashion.

NYPIRG Motion - pagg 4

. Nor can we imagine how it can ever be considered an adequate compensating substitute for a program which is based on a final plan and which meets the criteria of NUREG-0654 (i.e., annual distribution of brochures, etc.).

Finally, NYPIRG believes that there are a number of errors and inconsistencies in some of the FEMA /RAC ratings which might have become apparent had the Commission availed themselves of the opportunity to be briefed by and ask questions of FEMA. But, even without such a briefing, had the Commission i

majority based its decision on the ratings and comments contained in the FEMA /RAC review (instead of on the ambiguous and qualified statements in FEMA's cover letters), it could not have concluded that deficiencies in preparedness have been corrected or that the compensating measures proposed for Rockland County are adequate at this time to assure the protection of the public in the event of an accident at Indian Point.

(Attached is our letter to the Commission of June 3,1983, which contains additional NYPIRG comments regarding the current state of emergency preparedness at Indian Point.)

3. The issue before the Commission on May 5, 1983, was FEMA's conclusion that emergency preparedness at Indian Point is inadequate to assure the protection of the public in the event of ar, accident. A decision on that matter was postponed until June 9th. In its June 8th report and cover letters, FEMA did not alter its conclusion regarding inadequate preparedness. Furthermore, FEMA's statements about the adequacy of interim compensating planning efforts were explicitly conditional and subject to further evaluation based upon anticipated plan revisions, tests, and exercises. Yet, on June 9th, the Commission majority side-stepped the issues of implementation and preparedness entirely. Instead, the majority based its decision on progress in the planning effort, thus setting the enforcement clock back to December, 1982.

NYPIRG Motion - page 5

4. In reaching its decision, the Conunission majority relied heavily upon expectations that a full-scale exercise would be conducted in Rockland County in approximately 60 days and that the required corrections to the State's compensating plan would be complete within 30 days. The history of emergency planning at Indian Point, however, has been one of missed deadlines and repeated delays. NYPIRGwas, therefore, not surprised to learn, less than one week after the Commission's decision, that there are already indications that.9 full-scale exercise will not be possible before 75 or 90 days. We also anticipate slippage regarding the 30-day commitment for State plan corrections and their implementation.

(See attached Reporter Dispatch article, June 15,1983, "DelBello: Evacuation plan test unlikely in 60 days")

5. On June 18th, Con Edison employees went on strike. Al though' the licensees and presumably the NRC Staff were well aware that this strike was threatened, the Commission was either not informed of this development or chose to ignore it. So far as we can tell, the Commission did not even consider the significance of the Con Ed strike for emergency preparedness at Indian Point in arriving at its June 9th decision. If the strike had begun on the 8th of June, the Commission could not possibly have concluded, the next day, that the compensating off-site emergency measures--which now depend to a large extent on the participation of hundreds of utility employees--are adequate to permit continued operation of Indian Point.

l For the duration of the current strike, Con Ed employees will not be available for off-site emergency response training, participation in drills and exercises, or response during an actual emergency. Should an accident occur during the strike, or before Con Ed employees have been trained and tested in their substitute emergency roles, it stretches credibility to believe that l management personnel could drive evacuation buses, staff reception centers,-man i

. . NYPIRG Motion - p ge 6 traffic control points, and perform all the other off-site emergency response tasks now assigned to utility employees--while, at the same time controlling the accident and bringing substitute generating facilities on line to guarantee that there is no loss of off-site power. The Commission cannot responsibly deem emergency procedures to be adequate which at this time depend on personnel who are substitutes for substitutes. (See attached Reporter Dispatch article on the strike)

In light of the above considerations, NYPIRG believes it incumbent upon the Commission to immediately reverse its order of June 10th by ordering the suspension of operation at Indian Point II and III until such time as FEMA is able to conclude that both planning and preparedness is adequate to assure the protection of the public in the event of an accident.

The Connission's June 10th order stated that " improvements have narrowly tipped the balance in favor of continued operation." Existing deficiencies in the State's compensating plan for Rockland, the likelihood that a full-scale exercise will not be conducted within 60 days of the June 10th order, and the current strike of Con Edison employees dictate a decision for ininediate shutdown the need for which should be obvious and clear-cut--neither " difficult" nor " razor-thin." ,

R ,pectfu ly submitted, j M &

Uoan Holt jDirector,IndianPointProject New York Public Interest Research Group June 22,1983

2 newyoRk pubhc mrcREST RESEARCb Q ROUpp lNC. .

I NYPIRG 9 Murray St. e New York, N.Y.10007 (212) 349-6460 o = a-,. se ua. r e= t., wo - v.e c.,. e r w. w.

June 3, 1983 Commissioners:

Nunzio J. Palladino, Chairman John F. Ahearne Victor Gilinsky James K. Asselstine Thomas Roberts U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington , D.C. 20555 Gentlemen:

I hope that you will have a moment between now and June 9th to consider NYPIRG's views about the current state of emergency preparedness at Indian Point in light of (1) the newly submitted New York State " Interim Plan for Implementing ,

Compensating Measures for Rockland County,"(2) the Westchester bus company and bus driver situation, (3) other deficiencies in planning and preparedness not identified as "significant" by FEMA which in our view represent serious obstacles to assuring preparedness, and (4) "other factors."

, I will try to be brief because I realize that you already have a great deal of

( material before you and very little time remaining in which to read more.

i I. New York State's " Interim Plan" A. It represents a new set of planning concepts quite different in many key respects from either the plan prepared by the Licensees for Rockland or the " Draft Plan" under development by the County. It thus requires extensive review and evaluation by FEMA simply as a plan. We have already identified numerous conceptual problems and inaccuracies in the plan--more than we can list here.

B. It has neither been implemented nor will it be implementable in the near future. It is simply another plan, which will require FEMA review, major correction, implementation, verification, and some time down the road, exercising.

    • Large numbers of newly designated individuals and agencies will have to receive specialized training.
    • Equipment identified in the plan will have to be procured and distributed.
    • Accuracy will have to be checked re: designated evacuation and bus routes; listed schools and institutions; identified reception, l The New York Public Interest Reseaech Group, Inc. (NYPIRG) le a not-for-proht, renpartisan researci and advocacy organization established.

l directed and supported by New York State college and university students. NYPIRG's staff of lawyers, researchers, scientists and organizers works with students and other cdzens, developsng cittzonehsp skills and shapsng pubiec p.4 icy. Consurner protection. higher education, energy, fiscal tssoonsabehty, pohtecal reform and sooal justece are NYPIRG's pnnopal areas of concern

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NYPIRG - paga 2 congregate care, and deconiamination center locations; availability of emergency vehicles (buses,~ ambulances, etc.) (Already, local residents of Rockland have discovered inaccuracies.)

    • New brochures, conforming to this new plan, will have to be written and distributed. The old brochures, distributed in

! February 1982, do not conform and thus constitute mis-information.

'** Posters and signs for roads, parks, and other public places are not up; phone books do not have the required emergency information.

    • Large numbers of emergency personnel, listed simply by number of peogle from various organizations, including the utilities, will have to be assigned and identified by name, address, and phone number.

C. There has been no exercise of any element of the interim-compensating State Plan for Rockland. The proposed Command and Control structure is is so c.omplex and multi-layered, with so many alternative chains of command and control, as to constitute a major flaw in itself. Indeed, this complex structure proposed by the State may be virtually untestable.

A pre-scheduled drill of a Command and Control system that relies on local officials whose routine jobs and expertise conform with their emergency roles, under the plan is one thing; a pre-scheduled exercise of a Command and Control system that depends on personnel not normally assigned similar functions in the County is quite another matter.

Furthermore, since the entire compensating Command and Control system depends on the momentary availability of a long list of possible alternates for each major responsibility, only a surprise drill could test its feasibility and workability. The proposed State compensating plan is nothing short of a blue-print for confusion and chaos of Command and Control.

Finally, the plan relies largely on personnel who have key responsi-bilities in State institutions in Rockland County, and who--though they are not free, as State employees, to refuse the roles assigned to them by the State--cannot and should not be required to abandon their usual posts. As administrators and safety personnel of large institutions, they would be required, during an emergency, to tend to their own patient populations--their absence would jeopardize the safety of their primary charges. Borrowing from Peter to pay Paul in this situation is grossly irresponsible.

D. The use of the National Guard has already been determined to be unrealistic based on their own time-of-arrival estimates (of 4 or more hours).

E. The use of utility employees from outside the County to perform l emergency roles requiring specialized training and a familiarity with the County is unacceptable from every standpoint. The public would have no more confidence in utility personnel driving local buses and ambulances, manning traffic control points, and staffing reception or other emergency centers than would the utilities have confidence in turning the operation of their reactors over to Rockland firefighters, bus and ambulance drivers, policemen and social workers.

NYPIEG - paga 3 Furthermore, NYPIRG cannot accept the precedent of ' letting'. our electric utility companies take 'over any aspect of our local govern-mental function. This is, after all, a Democracy in which we elect those officials to whom we chose to entrust our safety!

F. The proposed school dismissal procedures are gravely inadequate and will not be accepted by parents. The State has ignored the public outcry about the "early dismissal" concept and has proposed emergency measures for school children which could leave them in great danger.

A nuclear emergency is not the same as a snow-day. dismissal or sending a child home with a toothache. Children should not be sent home on foot or dropped off at unattended road intersections; they must be taken directly to a waiting adult. Parents must be provided the opportunity to designate a surrogate adult (name, address, and phone) who is able and willing to accept the responsibility of sheltering or evacuating the child in a nuclear emergency. The teenage baby sitter or grandmotherly neighbor who can care for a child sent home with a sore throat, during a snow storm, or af ter school may not have a car or be an appropriate person to handle an evacuation. And the one non-working mother en the block may not be able to cope with the dozen or more children for whom she is listed on the schoolfs emergency cards. A nuclear emergency ist different, and we are tired of being told otherwise!

G. The State's compensating plan--even if it were not gravely flawed as

. a plan--does nde constitute preparedness unless and until it has been implemented and fully exercised. We are back in December, when FEMA informed you that they could not assess preparedness until after an exercise. FEMA's conclusion of April 15, that preparedness is currently inadequate to assure the protection of the public in the event of an accident still stands. The situation in Rockland County has not been altered by the State's unrealistic compensatory plan.

O The bottom line is that were an accident to occur tomorrow, there is no implemented plan and no preparedness in Rockland County.

I would remind the Commission that its emergency planning rule does not contemplate ad hoc measures for the 10-mile EPZ.

II. The Westchester Bus Company / Bus Drivers Situation A. We do not know whether written agreements have been signed with bus companies or bus driver unions. Thy were not as of May 26th.

B. The much-touted " training" sessions for bus drivers have been nothing l of the kind. They have, rather, been " introductory orientation" sessions conducted by the utilities and designed to elicit lists of volunteer drivers who will later receive their training.

Independent observers of the orientation sessions report that the information provided to the drivers deals primarily with background and other sources of radiation, including routine emissions from nuclear plants--with booklets and films provided by the nuclear industry.

Reassurance is the name of the game.

NYPIRG - paga 4 The drivers are given no information about possible levels of radiation during accident conditions. Instead, they are told that they will not be asked to drive except in very slow-moving accident situations in which there will be many hours lead-time and no exposure.

The drivers are not being informed about what is in the plans:

provisions to decontaminate exposed emergency workers and the public (and buses and other vehicles); recommendations that women of childbearing years and individuals under 45 years of age should not be used, if possible; and that under certain scenarios emergency workers may have to be permitted to receive radiation doses surpassing PACS..p NYPIRG believes that volunteers elicited through these less-than-forthright orientation sessions cannot be counted on unless, perhaps, it can be guaranteed that they will be insulated from any additional information prior to the moment they may be called on to drive.

Finally, the drivers have not yet been trained; nor have their assignments been rehearsed. Thus, preparedness for an accident still does not exist.

III. Other Deficiencies A careful reading of FEMA's Post-Exercise Assessment, the Argonne verifi-cation report (not done for Rockland, of course), and submissions to the Commission from ASLB parties must convince the Commission that many, many elements necessary for adequate preparedness are not yet in place (just watch for tha word like "should," "must," "will be," etc.)

An accident any time in the near future (at least prior to the end of 1983) will still require g hoc measures utilizing untrained personnel lacking necessary equipment. Furthermore, the public is neither educated nor adequately info: med in either Westchester or Rockland--which contain 90% of the EPZ population.

I l IV. "Other Factors" NYPIRG insists that there are no "other factors" relevant to the Commission's l June 9th decision beyond the fact that you cannot assure that the public can l and will be protected in the event of an accident at Indian Point. Only the number of words on paper has changed since April 15th or.May 5th.

The only issue before the Commission, then, is whether its emergency planning regulation is going to be upheld and enforced. And if it is not at Indian Point--the nation's most densely populated plant site--

noncompliance elsewhere will become the order of the day and public trust in the Commission will reach an all-time low.

Resp ,ctfull '

dC( n b J, Holt Di ector, Indian Point Project NYPIRC

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  • 9 met Tuesday night.with of stan h'

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'i ; committee elopi

. a: Rockland's, responsible - for A proposed state radiological emergen . emergency:own . plan for coping,with an' J at ithe Indian ; Point ,pucleary cy plan for Rockland County isn't likely to ' power p[aqit ' ' ; . '

J be reedy for; testing.within

-nest'600 ' But the" ul atmospher% 4 ')'

days, Lt. 0gfcAlfred DelBello jToes ?" meeting;'at?tbe County' Office BalW

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New City l was~tnomentarilyl bi%en

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an.exercisel,ottest:the practicality of the W! JIowever DelBello said be lioped

. plan could(be. scheduled withins two to his threat to launch a court' battle against i the state's presence in Rockland.-

' three mon ..h 2 1 '

s iIn a . clumsMarized candid i- t talk and aispirit,o(cooperation,. Ilo .

~ said thd st$let . two Milities 'that,.  !

dedslon Itr ewur bteployees the Indian cho-lef Pokreactors.' All hnW 186

  • see;for the plan:would live in or near munici '? F Rocklanda _ .- e' . i P DelBello, e __ orded last ' Rockland, which withdrew last year yIsek by Gov.'lWa'rio Cuomo to complete from 'a' regional disaster plan drawn by and administer a state emergency plan constitants for :the utilities, has no

' for Rockland, repeatedly stressed that formal plan of its'own. The committee he had no latention of undermining formed by'the Rockland Legislature to j local control over disaster planning: . develop such.a plan does not expect to i The former Westchester county 'ex- complete its work until early 1984. l ecutive said his role would be " parallel DelBello confirmed that neither or supplemental" efforts to develop an emergency plan, to Rockland's own . state nor federal-officials expect the "It's' going to be a horrendous ef- state's " compensating plan"; ;essen.

fort," he said. tiall identical to d draft'Jplan.devel-County officials and member,9 . w.

-WA last year by cointy.officialsu to s of the.2 committee wished DelBello luck.buti n. tested for at least anothe(60 ,, .

- - days. .

l m u co tee, re anage enc'y i

devising's practical plan for evacuating the date for an exercise,".DelBello said.,

inore than,a quarter ofi Rock- i Reisnian said'he doubled.' thel land residents la the eventi full- makers would back Gdanski's, ,to plan'K'y,,

Buchanan.s sue the state. '- .,

sgale reacfors,nuclear disaster h at the(Mli in"The. worst thing klandRoc,p could do% y-

- "You are embar t on an fin  :.'now is go to war with New York state," 7

  • ble hourse,".said ature

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the' chairman said. A BerbertReisman. 4 > d .$ Reisman /said'. a 'seri 2

After thequeeting, of 'recent A e thwithistate officials had convinced "

wakebf last; Thursday's "

him:that~

the state warmakin "

gr Regulatory.

. Point remalaitopen CR- -. , _ _

.- effortt to provide. financ fflaws - stricy, equipment;,comm id emergency,plann!ng c6 sides oy and specially equipped vshli:1 the Hudson Ittver, DelBelig said be ed f M 9.y". by tiWdepth an ash (9 carry out a disaster plan.Q.4  !

of the committee's effortsp M{ d% . jf,1;j.~He 'said'the me county .w"o'did.W

+ He offered assurances thatlhe state,.M to work on its own Ia 5 plan would not be a " charade &fdeally.)C works on the state pfan.n whilsD .s he explained, the state planiwdald besa - ; During the meeting, lahd Sher.?-34 foradation upon which Rockland'could, iff's Patrol Chief James _

who.7 Jf it chose'" build"its own planG#fL - also -serves ja ,ther,, told .

The state plan would be carriN! out DelBello;thefcounty:;cou l  ;

3 b'y about 50. state workers and some 500 worka .p,lan if given engu ~

employees of Consolidated Edison and, $t'I .3 bohre" .{

the.N.e.w York Power Authority  !- the  :: e a, .m@Pte '

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fb$[f dP/l11k EI] Gannett Westchester Newspapers g

8 Sectionts ,

Sunday, June 19,1983 Relations appear cordial .

among pickets, supervisors If a man gets hurt on the job, Con Ed i By Edward Frost .g wants to lessen his pay when he comes Staff Writer back to work or even hire someone The picket lines were up at many else."

Consolidated Edison plants in Westches- Two workers at the Rye plant com-ter Saturday afternoon, but relations plained that their health benefits didn't between striking workers and the su- cover their medical expenses.

pervisors replacing them seemed cor- "You send in a lab bill for $29 and dial. you get $8 back. That's not the best "We're all very amicable here," said medical coverage," he said. "The only Sophie Vinokur, a stenographer who thing they treat you good for here is was carrying a picket sign outside Con can,c,er, and who wants cancer?"

Edison s 210 Westchester Ave. office m The company made tremendous Whi,te Plains, where she works. rofits last year," said his rtner, who We're all friends, all the ily. Its a warm group here,,same she [as worked for Con Edisoa 14 fears. "If they had lost money, we wouldn't be out here. You make no money from Rubin Burns, a maintenance worker them standing nearby, agreed. C e f*,,You hve week-to-week on each Unlike the last strike against Con Neither man would give his name, Edison - a 13-day walkout in Decem-ber 1968 that was punctuated with fearing reprisals from management af-incidents of shooting and arson - there ter While the strike.

they were p,cketing i at about were no reports in Westcheste Satur- 4:30 p.m., two supervisors drove a day of violence or vandalism.

Across the county, several strikers " cherry picker" truck into the plant, worried about whether keeping Con and the four had a polite conversation.

Edison's Indian Point nuclear reactor The two, employees asked how thing

.open was safe, since most of the 700 were going, and one foreman said it was quiet.

employees who volunteered for the Both Rye workers wondered what

'utihtys evacuation program are on would happen if an emergency hit, and strike.

"The strike includes the bus drivers one speculated that management might

. who " evacuate people from Indian make arrangements to get the strikers Point" said a 14-year veteran outside back on the job.

the Rye Service Center. "Those guys inside are not spring "With no evacuation plan, I believe chickens any more," said the 27-year the plant should close," said a worker man, referring to the foremen. "If there from Peekskill on a picket line in were a massive thunderstorm, we'd go Buchanan near the reactor. lie said he back to work, no doubt about it. People would welcome anti-nuclear demonstra. want their power.

tors who wanted to march with the "There's not enough of them to go strikers because of the danger of not around if there's a major storm," he having an evacuation plan under way, added.

"Without the proper people in there, , At the Buchanan generating station

' i.t's just not safe " another Peckskill and Indian Point 2, the supervisors striker said. were locked in to maintain safety, a But the primary consideration for shop steward at union headquarters in I the strikers, who walked off their jobs Buchanan said.

1 . at 12:01 a.m. Saturday, is getting a The supervisors were told to pack better contract. enough clothes for two weeks, and are "We want to maintain what we've working 12-hour shifts.

gotten and get a fair raise for the It won't be anything like a vacation economy al.d a benefits package," said trip. There's no showers here," noted a shop steward at the Buchanan strike one supervisor entering the Pleasant-headquarters. ville substation on Manville Road.

" Cost of living, that's all we're asking for," said a Peekskill man who Staff writers contributing to this works at Indian Point. "They (Con story were Greg Burke, Ruth Glachino Edison) want to take away our security. and Nancy McCann.

7

.i L .*bl UNITED STATES OF NtERICA NUCLEAR REGUUsTORY COMMISSION -

BSPORE THE ATOMIC SAFETY AND LICENSItG B(RRD

)

In the matter of -).

)

CONSOLIDATE'D EDISCN COMPANY. OF NBf YORK, ItC. ) Ibcket tbs.

- (Indian Ibint, Uhit lb. 2) ) 50-247 SP

) 50-286 SP

( PCWER AUT!!ORITY OF THE STATE OF NEW YORK

~

)

y(Indian Ibint, Unit tb. 3) ) 9th May, 1983 f

)

CERTIFICATE OF SERVICE I:hereby certify-that copies of the NYPIRG MOTION FOR IMMEDIATE RECONSIDERATION COMMISSION' ORDER OF JUNE 10, 1983 (CLI-83-16), has been mailed first' class,~ postage-paid ~or hand delivered as indicated-to the following this 22 day-of June,-1983.

L/ '

' *trunzio Palladino, Chainnan

  • Victor Gilinsky, Comnissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission -

Washington, D.C. 20555 Washirgton, D.C. 20555 ,

-* John Ahearne, ~ Commissioner *Ihomas Roberts, ccanissioner

U.S. Nuclear Regulatory Comnission

~

U.S. Nuclear Regulatory Comnission F Washington, D.C. 20555 Washington, D.C. 20555

!

  • James Asselstine,' Comnissioner . James P. Gleason, - Esq. , Chairman U.S. Nuclear. Regulatory Commission . Mainstrative Judge itishington, D.C. 20555 Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Frederick J. Shon

. Administrative Judge f

' Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission p'

Washington, D.C. 20555

. j i ...

N 4

7 \

4. ;, I l' -
  • l Ezra I. Dialik, Esq.

Andrew S. Ibffe, Esq.

Steve [cipsiz, Esq. thw York State Assembly

Environmental Protection Bureau Albany, t# 12248

'( tbw York State Attorney General's Of fice Ibnorable Richard L. Brodsky Member of the County [rgislature Tm W]rld Trade Center thw York, NY 10047 Westchester County Cc nty Office Building

[bnald Davidoff, Director hhite Plains, NY 10601 t'ew York State Radiological Ehergency Preparedness Group Spence W. Perry, Esq.

Dnpire State Plaza Office of General Counsel Tower Building, Poom 1750 Federal Dnergency Management A3cncy Albany, IN 12237 500 C Street, S.W.

K3shington, D.C. 20472 Ibvid H. Pikus, Ecq.

Richard F. Czaja, Esq. Stewart M. Glass, Esq.

91ea ard Could Regional Counsel Federal Onergency ftnagement lgency 330 Madison Avenue thw York, in 10017 Poom 1349 26 Federal Plaza Ihyllis Podriguez, Spokesperson thw York, !!Y 10278 Parents Concerned About Indian Ibint Charles A. Scheiner, Co-Chairperson P.O. Box 125 Croton-on-Hudson, IE 10520 Westchester People's Action Coalition, Inc.

Richard M. Ibrtanan, Esq. P.O. Box 488 hhite Plains, tW 10602

[orna Sal: man Friends of the Earth, Inc.

Idan tatman, Esq.

208 West 13th Street thw York, NY 10011 44 Sunset Drive Croton-on-Hudson, tW 10520 Jtdith Fessler, Coordinator Rockland Citizens for Safe Biergy Zipporah S. Fleisher 300 thw itempstead Ibad tbst Branch Conservation Association New City, tN 10956 443 Buena Vista Poad thw City, t& 10956 Renee Schwartz, Esq.

Paul Otessin, Esq. Melvin Coldbe,rg, Staf f Attorney Laurens R. Schwartz, Esq. Joan iblt, Project Director Margaret Cppel, Esq. New York Public Interest Botein, Ibys, Sklar & Ibetzberg Research Group, Inc.

200 Park Avenua 9 Murray Street thw York, tU 10166 thw York, in 10007 tbvid B. Ebboff Craig Kaplan, Esq.

Westchester People's Action National Dnergency Civil Coalition, Inc. Liberties Cbmmittec 175 Fifth Avenue, D3ite 712 255 Grove Street New York, IU 10010 hhite Plains, IE 10601 m

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g Dr. Q: car IL Paris James A. Laurenson Administrative Judge A$ninistrative JWge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. toclear Regulatcry U.S. tbclear Bcgulatory Comission Comission Washington, DC 20555 Washington, DC 20555 .

David Lewis, Bq. (* Cbcketing and Service Section Atcaic Safety and Licensing Board Cf fice of the Secretary U.S. Nuclear Regulatory Cocmnission U.'S. Nuclear Regulatory Comission Washington, D.L. 20555 Washington, D.C. 23555' Janice E. Fbore, Esq. Atanic Safety and Licensing Board Panel Donald F. Ibssell, Esq. U.S. Nucicar Regulatory Comission Henry J. FbCurren, Esq. Washington, D.C. 20555 Office of the Exccutive legal Director Atomic Safety and Licensing Ippeal U.S. Ibclear Regulatory Comission Board Panel Washington, D.C. 20555 U.S. Ibclear Pegulatory Commission Washirgton, D.C. 20555 Bernard Sanoff, Esq.

Assistant General Counsel Paul P. Colarulli, Esq.

Consolidated Edison Company of Joseph J. Irvin, Jr. , Esq.

New York, Inc. Pamela S. Ibrowitz, Esq.

4 Irving Place Garles Fbrgan, Jr. , Esq.

New York, NY 10003 bbrgan Associates, Chartered 1899 L Street, N.W.

Charles M. Pratt, Esq. Washirgton, D.C. 20036 Stephen L. Baum, Esq.

Pow 2r Authority of the State bbyor F. Webster Pierce of thw York Village of Buchanan 10 Colunbus Circle 236 Tate Avenue ibw York, NY 10019 Buchanan, NY 10511 Jonathon D. Feinberg .

Stanley B. Klimberg , Esq.

lbw York State Public Service General Counsel Commission New York State Energy Of fice Wree Dupire State Plaza 2 Rockefeller State Plaza Albany, NY 12223 Albany, NY 12223 1

Charles J. Kaikish, IMq. Marc L. Parris, Esq.

Litigation Division Eric Worsen, Esq.

The Ibre Authority of tbw County Attorney York and Ibw Jersey County of Pockland QTe vbrld Trade Center 11 thw liempstead Poad thw York, IN 10048 thw City, NY 10956 lbnoraole Ruth tbssinger Andrew P. O'Rourke>

Member of the Council of the Westchester County Executive l4 Laurie Vetere, Esq.

l City of thw York District #4 148 Martine Avenue White Plains, NY 10601 City Ibli thw York, IN 10007 W y-n

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4 Ms. Amanda letterfield, Esq. Jef frey M. Blun, Esq.

Johnston & George, Attys-at-taw tbw York thiversity law School 528 Iowa Avenue 423 Vanderbilt liall Iova City, IA 52240 40 Washington Square South New York, PIY 10012 Joan Miles Creater !bw York Council on Ehergy Indian (bint Coordinator c/o Dean R. Corren, Director New York City Audubon Society New York thiversity 71 West 23rd Street, Suite 1828

!bw York, NY 10010 26 Stuyvesant Street New York, tiY 10003 Steven C. Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N.W., Suite 1101 Washirgton, D.C. 20036 A

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