ML20096B855
| ML20096B855 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/27/1984 |
| From: | Kelleher R LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20096B851 | List: |
| References | |
| OL-3, NUDOCS 8409040380 | |
| Download: ML20096B855 (4) | |
Text
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k LILCO,-August 27,-1984 f,3 UNITED STATES OF AMERICA NUCLEAR REGULATORY ColgtISSION.
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'Before the Atomic Safety and Licensing Board uunue
.l:3nRC In the Matter of
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i LONG ISLAND LIGHTING. COMPANY.
) Docket 0 b2hN-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
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unanot AFFIDAVIT OF ROBERT'X. KELLEHER Robert X. Kelleher, being duly sworn, deposes and says as follows:
1.
My name is Robert X. Kelleher.
I am Manager of the Employee Relations Department at the Long Island Lighting Company.
My business address is 175 East Old Country Road, Hicksville, New York, 11801.
2.
I make this affidavit in response to the July 3, 1984 motion of Suffolk County for admission of a new contention on the effect.of the recent strike by labor unions representing LILCO employees on the future vitality of LERO.
This affidavit has two primary purposes.
The first is to dispel some of the clearly incorrect factual assertions contained in Suffolk County's motion, and.second, to demonstrate that much of the factual information presented in Suffolk County's motion was available considerably before the commencement of the LILCO strike on July 10, 1984.
3.
.On March 6, 1984, LILCO implemented its austerity program.- Contrary to.Suffolk County's suggestion this program did Oh
o i., L not drive a wedge between labor and management.
The union layoffs that resulted from the austerity plan were not the approximately 20% as alleged by Suffolk County, but rather about 8%, allocated as follows:
(a) Clerical union:
245 layoffs outs of a union force of-1574 (or a 15.6% layoff)
'b) Physical union:
90 layoffs out of a union force of 2665 (or a 3.4% layoff).
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In' addition, a large number of these union layoffs were fron a group of workers classified as " temporary indefinites."
Employees in this classification understand they have the highest potential
{o,rbeinglaidoff.
Since these March 6 layoffs, a sizable number of-these union members have been rehired.
4.
In early June 1984, representatives of labor and manage-ment exchanged statements of their respective positions regarding the renewal of the union contracts.
While the LILCO management position included a proposed 5% wage cut, it also offered a stock plan basically identical to that offered LILCO's management per-sonnel. -LILCO's management bargaining position was premised on a desire to treat LILCO's union and non-union personnel as identi-cally a's possible.
Theee bargaining positions appeared in locdl l
i l
newspapers at varisus times from early to mid-June.
5.
Other items asserted.by Suffolk County to have caused the resentment of LILCO's union employees are inaccurate as a result l
of the recent strike settlement.
Union employees did not suffer a pay cut, but rather will receive the same wages they had been
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receiving for the-prior year.
In addition, no union worker has ever been without his/her insurance benefits, including health L
benefits.. All benefits were retroactively restored a part of the striko settlement.
6.
'Suffolk County's assertions regarding the en masse 6
resignation of LERO workers is simply incorrect.
Workers volunteer'for LERO individually by signing a written agreement; workers resign by tendering written notice individually.
From
. July 1 to the commencement of the strike on July 10, 23. union workers submitted written resignations from LERO; during the strike, 1 additional union worker tendered his written resigna-j tion; and following the strike, 2 other workers have formally resigned.
In addition, following the strike, 7 union workers have given oral resignation notices to their supervisors, but have yet to tender written notice.
Following the strike, 2 new union workers have also joined LERO.
Thus, the total lors to LERO, out i
j of 1246 union members, was 31.
7.
During the strike, business managers for the two LILCO unions did not present single, en masse resignation notices for i
j LERO workers who are also members of their unions.
Nor would such a notice have been effective since LERO is a voluntary organiza-tion outside normal-LILCO job functions.
Indeed, following the l-acceptance vote on the latest union contracts, the business manager.for the clerical union signed a. statement recognizing that g-i.
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l LERO is-s voluntary organization outside the scope of LILCO's normal busi$ess and outside the coverage of the collective bargaining agreement.
(Attachment 1).
The business manager for the physical union, although he has yet to formally uign such a statement, has stated that he stands behind it.
8.
Even during the just completed strike, there were clear indications that union workers will carry out their voluntary obligations, even if they are on strike from their normal jobs.
For example, union members who are members of local voluntary fire departments continued to serve as voluntary firemen.
In many cases, these voluntary functions were performed side-by-side with LILCO management personnel who were also members of those voluntary fire companies.
\\
s Robert X.\\Kelleher COUNTY OF NASSAU )
STATE OF NEW YORK) me this. $ day ofSubscribed and sworn J[o beforetu.aso f 1984.
A il n (L 5t.LLG u L.
/
NOTARY PUBLIC GINIV1 EVE T. FAULS NOTARY PUBLIC,5 tete Of New York No. 30 6245400 Qualified in Nossou County My Commission Expirea on Conmss:cn Expires Merch 30,1986 l
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