ML19329C402
| ML19329C402 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 03/27/1975 |
| From: | Henry L, Klee R TOLEDO EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8002130769 | |
| Download: ML19329C402 (27) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of .)
THE TOLEDO EDISON COMPANY and )
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Davis-Besse Nuclear Power Station) ) AEC Docket No. 50-346A
)
THE CLEVELAND ELECTRIC ILLUMINATING ) -
COMPANY, et al. )
(Perry Nuclear Power Plant, Units ) AEC Docket Nos. 50-440A 1 and 2) ) 50-441A THE TOLEDO EDISON COMPANY'S ANSWERS TO SUPPLEMENTAL INTERROGATORIES BY THE DEPARTMENT OF JUSTICE TO THE TOLEDO EDISON COMPANY AND OTHERS, DATED FEBRUARY 14, 1975 Pursuant to Section 2-740 of the Commission's Rules of Practice, The Toledo Edison Company (" Company") s ubmits the fol-lowing responses to Supplemental Interrogatories 1 through 6, as propounded by the Department of Justice under date of February 14, 1975, and pursuant to the definitions therein contained and referenced.
Supplemental Interrogatory No. 1 Since September 1, 1965, has Company ever directly or 80021307[} F,
indirectly transmitted electric power and/or energy -(whether originating inside or outside Company's system) from its trans-mission' system to the transmission system of any electric utility (whether directly interconnected with Company or not) engaged in 4
the utilization, sale or'further transmission of that power and/
or energy? If so, describe each situation, stating (a) the parties j
involved, (b) the time period (s) involved ~ (c) the amount of energy and/or power in MWH involved annually, (d) the reason (s) for the transmission (s) , (e) the date of and signatories to any agreement relating to each such situation, (f) the rate (s) at which the Company billed the other electric utility (s) for each transaction, and (g) the method and factors used to determine the rate (s) listed in response to part (f) above.
Answer From time to time, since September 1, 1965, the Company has directly or-indirectly transmitted electric power and/or 4
energy (whether originating inside or outside Company's system) from its transmission system to the transmission system of other electric utilities (whether directly or indirectly interconnected with Company) engaged in the utilization, sale or further trans-mission of that power and/or energy as follows:
f
4 (a) Parties involved:
Parties to following contracts with the Company:
(1) Ohio-Power Company, informal con-tract, replaced by contract dated December 1, 1965 (Ekhibit A);
(2) Ohio Edison Company, dated December i
31, 1945, as amended January 21,
) 1952, October 27, 1955 and August
- 1, 1968; (3) Consumers Power Company and The Detroit Edicon Company, 345kv con-tract dated March 1, 1966 (Michigan 1 Companies) (Exhibit B);
(4) Ohio Edison Company, The Cleveland Electric Illuminating Company, Pennsylvania Power Company and Duquesne Light Company under CAPCO Basic Operating Agreement dated as of January 1, 1975 (Exhibit C);
(5) Ohio Edison Company, The Cleveland Electric Illuminating Company, Pennsylvania Power Company and Duquesne Light Company under an agree-ment for delivery of power purchased from the Michigan Companies pursuant to the short term power schedule D attached to the contract listed in (3) above, dated May 29, 1969, as amended May 26, 1971 and November 1, 1973, cancelled as of October 6, 1974 (CAPCO short term);.
(6) Intercompany Power Agreement among the company, Ohio Valley Electric 4
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.._~ ,- ,_ , _ .. - - . -
.y Corporation, and others, dated July 10, 1953, as modified. June 3, 1966,
. January 7, 1967 and November 15, 1967, with reference to backup and purchase of excess power (Exhibit D) ;
+and certain service schedules attached hereto. Copies of all of the above contracts are attached hereto as exhibits, marked as above indicated, except for the contracts describcd in (a) (2) and (a) (5) above which have been made available for inspection and copying at the Central Depository in Washington, D.C. by Ohio Edison Company. In addition, except for the contract described in (a) (4) above, which is attached hereto as Exhibit C, all of the above contracts are on file with the Federal Power Commission.
e (b) The time periods involved were from the dates of the respective contracts listed under (a) above to the present, ex-cept where shown that contracts have been terminated.
(c) Annual quantities in MWH:
The information set forth in its FPC Form 1 reports for the years involved is as follows:
1966 Ohio Edison Interchange Power 1,086 Ohio Power Interchange Power 550
7_
1967 Ohio Edison Interchange Power 400 Ohio Power Interchange Power 5,163 1968 Ohio Edison Short Term Power 720 Interchange Power 1,625 2,345 Ohio Power Short Term Power 313,025 Interchange Power 3,133 316,158 1969 Ohio Edison Short Term Power 102,630 Interchange Power - 20,385 123,015 Ohio Power Short Term Power 194,387 Interchange Power 15,900 Suspense 2,753 213,040 Michigan Companies Short Term Power 192,400 Interchange Power 540 Suspense 1,150 194,090 a
1970
. Ohio Edison Short Term Power 114,467 Interchange Power 43,736 158,203 Ohio Power '
Interchange Power 12,283 Suspense 7,852 20,135 Michigan Companies Short Term Power 208,025 Suspense 1,295 209,320 1971 Ohio Edison Short Term Power 188,297 Interchange Power 27,318 215,615 Ohio Power Short Term Power 5,675 Interchange Power 10,499 16,174 Michigan Companies Short Term Power 97,633 Interchange Power 21,792 Suspense 2,275 121,700 1972
. Ohio Edison Short Term Power 6,546 Interchange Power 44,664 Losses 1,530 52,740
c
. 1972 Ohio Power Short Term Power 74,360 interchange Power 265 Suspense 820 75,445 Michigan Companies Short Term Power 194,157 Interchange Power 26,415 220,572 OVEC 1,684 1973 Ohio Edison CAPCO Short Term CEI 52 CAPCO Short Term DL 41,692 CAPCO Short Term OE 988 Short Term Power 16,972 Interchange Power 118,497 Losses 5,185 183,386 Ohio Power Interchange Power 5,614 Suspense 1,539 7,153 Michigan Companies Interchange Power 452,435 Suspense 1,758 454,193 OVEC 1,542 1974-Ohio Edison CAPCO Short Term DL 154,693 l l
~7-
1974 CAPCO Short Term OE 11,066 Short Term Power 19,343
. Interchange Power 256,929 Losses 5,916 447,947 Ohio Power Interchange Power 4,513 Suspense 949 5,462 Michigan Companies Interchange Power 304,763 Suspense 696 305,459-OVEC 8,613 (d) The reason (s) for transmission (s) were as set forth in the contracts or service schedules to. contracts and may consist of any one or more of the following:
(1) Ohio Power Company (Exhibit A page references) : Emergency service (p.
22-24); Coordination of scheduled maintenance of generating facilities (p. 25-27); Interchange power (Economy and Nondisplacement Energy)
(p. 28-29) ; Short term power (p.
30-31);
(2) Ohio Edison Company (Item 1(a) (2)
, above) : Firm power, Interchange power, Short tern power and Economy interchange power; (3) Consumers Power Company and The Detroit Edison Company (Exhibit B l page references): Emergency-service
(p . 15-17 ) ; Coordination of scheduled maintenance of generating facilities (p . 18-20) ; Interchang'e power (Economy and Nondisplacement Energy) (p. 21-23); Short term power (p . 24-25);
(4) Ohio Edison Company, The Cleveland Electric Illuminating Company, Penn-sylvania Power Company and Duquesne Light Company (CAPCO Basic Operating Agreement) (Exhibit C page references) :
Articles 5 and 6 (p. I3-29); Schedule A (Replacement Capacity and Replacement Energy) (p. 1-5) ; Schedule B (Short term Power and Energy) (p. 1-2); Schedule C (Interchange Capacity and Energy)
(p. 1); Schedule D (Economy Interchange of Operating Capacity and/or Energy)
(p. 1-3); Schedule E (Specific Unit Capacity and Energy) (p. 1-5) ; Schedule F (Out-of-Pocket Cost) (p. 1-12);
Schedule G (Precommercial Equivalent Energy) (p. 1-2) ;
(5) Ohio Edison Company, The Cleveland Electric Illuminating Company, Penn-sylvania Power Company (CAPCO Short Term): Short term power; (6) Ohio Valley Electric Corporation (Ex-hibit D): Interim Power (p. 8-9);
Supplemental power (p. 10-12).
(e) For dates and signatories to agreements, see answer to (a) above.
(f) For rates, see pages of contracts or service schedules to contracts referenced in (d) above, except as to contracts placed
_9-
e in Central Depository by Ohio Edison Company, as to which reference is made to its references.
(g) For methods and factors used to determine rates, see contracts or service schedules to contracts referenced in (d) above, which were the result of arms-length bargaining and, except Exhibit C, Federal Power Commission action. Exhibit C will be submitted for such action.
NOTb: In responding to this and Supplemental Intertogatory
'3, answers are.made on the basis of delivery and receipt.of pcwer and/or energy as scheduled to a connecting utility or to another CAPCO Company under a direct contract with it. In some instances the company was advised that power was scheduled for delivery to a remote utility, but it has no knowledge as to disposition by the connected utility to which it delivered the power. It is also recognized that in interconnected system operation it is physically impossible to determine the source of any power delivered to any point of utilization, and that consequently the Company may have transmitted power and/or energy through its system from one system to another without knowledge of the fact and without having con-tracted for or scheduled such.
Supplemental Interrogatorv No. 2 Since September 1, 1965, has Company ever refused any request, either formal or informal, to transmit electric power and/or energy in the manner described above in Interrogatory No. l?
If so, de scribe each such request by (a) the date of the request, (b) the p arty making the request, (c) the~ proposed supplying and receiving parties, (d) the requested transmission route, (e) the amount of power involved, (f) the time period involved, (g) the reasons for Company's decision with regard to this request, and (h) the identity by date, author (s) and subject matter of any documents relating thereto.
Answer Since September 1, 1965, the Company has not refused any request, either formal or informal, to transmit electric power and/
or energy in the manner described in Supplemental Interrogatory No.
1 (i.e., "(whether originating inside or outside Company's system) from its transmission system to the transmission system of any electric utility (whether directly interconnected with Company or no t) ) " .
l
4 Supplemental Interrogatory No. 3 Since September 1, 1965, has Company had electric power and/or energy transmitted to it either directly or indirectly from the transmission system of any other electric utility (whether or not said utility is directly interconnected with Company)? If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amounts of energy and/or power in MWH involved annually, (d) the reason (s) for the transmission (s),
(e) the date of and signatories to any agreements relating to each such situation, and (f) the rate (s) at which Company was billed for each transaction.
Answer This interrogatory is the converse of Supplemental Interrog-atory No. 1, inquiring as to transmission directly or indirectly to the Company from the transmission system of any other electric utility (whether or not directly interconnected with the Ccmpany) instead of from the Company. From time to time, since September 1.
1965, the Company has so received electric power and/or energy as follows:
(a) The parties involved were those parties to the follow-i ing contracts with the Company:
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(1) Those listed in (a) (1) , (2), (3), (4) and (6) in response to (a)- of Supple-mental Interrogatory No. 1; (2) Ohio Edison Company (Interim supplements to the contract described in (a) (2) in response to Supplemental Interrogatory No. 1) dated September 20, 1971, which was replaced by contract dated August 1, 1972 and thereafter terminated December 31, 1974 for sale of power from the Sammis No. 7 Unit on the system of Ohio Edison; (3) The Cleveland Electric Illuminating Com-
. pany dated July 25, 1972 and terminated December 31, 1974 (Exhibit E) ;
(4) Various short lead time contracts and service schedules attached thereto.
A tabulation of those agreements are as follows:
(a) Allocation of short lead time capacity pursuant to (a) Mem-orandum dated October 7, 1970 (SLTC No. 1), and (b) Memoran-dum Agreement dated July 30, 1971 (SLTC No. 2) , as amended and supplemented by Memorandum Agreement dated January 5, 1973 (SLTC No. 3) , both of which have been amended and supplanted by Memorandum dated as of July 6, 1973 (Ex-hibits F, G, H, I);
(b) Between the CAPCO Companies
- dated October 1, 1973 through December 31, 1974; (c) Ohio Edison Company and
Pennsylvania Power Company dated October 1, 1973; (d) Ohio Edison Company (Interim
. supplement t'o the contract described in (a) (2) in response to Supplemental Interrogatory No. 1) dated January 1, 1973 covering the entitlement of the Company to receive capacity and energy during the period beginning January 1, 1973 and ending September 30, 1973 from 125mw of short lead time capacity installed on the Ohio Edison system.
Copies of all of the above contracts are attached hereto as exhibits except for the contracts described in (a) (2) , (a) (4) (b) , (c) and (d) above which have been made available for inspection and copy-ing at the Central Depository in Washington, D .'C . by Ohio Edison Company. In addition, except for the contract listed in (a) (4) in response to Supplemental Interrogatory No. 1, which is attached hereto as Exhibit C, all of the above contracts are on file with the Federal Power Commission.
(b) See response to (a) for time periods involved.
l l (c) Quantities in MWH involved annually:
The information set forth in its FPC Form 1 reports for the years involved is as follows: .
. ..s 1966 Ohio Edison Interchange Power 327 j Ohio Power
. Firm Power 73,910 Interim Power 100,669
. 174,579 1967 Ohio Power Firm Power 837,015 .
Interchange Power 540 837,555 1968 Ohio Power Firm Power 853,665 Interchange Power 450 854,115 OVEC 24,074 1969 Ohio Edison Interchange Power 945 Ohio Power Firm Power 864,310 Interchange Power 3,978 Suspense 1,966 870,254 Michigan Companies Suspense 734 OVEC 303,978
1970 Ohio Edison Short Term Power 11,400 Interchange Power 1,050 12,450 :
Ohio Power Firm Power -
869,358 Short Term Power 4,000 Interchange Power 75 Suspense 5,442 878,875 Michigan Companies -
Interchange Power 1,046 Suspense 1,144 2,190 OVEC ,
439,010 1971 Ohio Edison Sammis No. 7 167,754 Interchange Power 1,075 168,829 Ohio Power Firm Power 872,530 Interchange Power 2,938 Suspense 2,498 877,966 Michigan' Companies Suspense 1,138 OVEC 441,202 i
1972 Ohio Edison ;
l Sammis No. 7 452,7,50 ;
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1972 CEI Eastlake No. 5 162,753 Short Term Power 56,192 Interchange Power 9,134 680,829 Ohio Power Firm Power
- 876,367 Interchange Power 4,765 Suspense 1,652 882,784 Michigan Companies Interchange Power 12,472 Suspense 2,110 14,582 OVEC 327,827 1973 Ohio Edison Sammis No. 7 326,045 Short Lead Time 7,333 CEI Eastlake No. 5 604,836 Interchange Power 11,780 Losses 870
__950,864 Ohio Power Firm Power. 875,247 Interchange Power 2,721 Suspense 1,176 879,144 Michigan Companies CAPCO Short Term CEI 52 CAPCO Short Term DL 41,692 CAPCO Short Term OE 988 Short Term Power 30,714 Interchange Power 11,098 Suspense 1,406 85,950 OVEC 382,023 l
j 1974 Ohio Edison Sammis No. 7 348,263 Short Lead Time 19,653 CEI Eastlake No. 5 523,469 Interchange Power 2,311 Losses 235 893,931 Ohio Power Firm Power 873,078 Interchange Power 9,040 Suspense 300 882,418 Michigan Companies CAPCO Short Term DL 154,693 CAPCO Short Term OE 11',066 Short Term Power 169,500 Interchange Power 4,364 Suspense 225 339,848 OVEC 369,861 (d) The reason (s) for transmission (s) were as set forth in the contracts or service schedules to contracts and consist of any one or more of the following:
4 (1) Contracts described in (a) (1) (Exhibit A); (a) (2) ; (a) (3) (Exhibit B) ; and (a)
(4) (Exhibit C) (in response to Supple-mental Interrogatory No. 1) also apply to this Interrogatory. In addition, the contract described in (a) (1) (in response to Interrogatory No. 1 (Exhibit l A)) contains certain service schedules e
o which apply only to Interrogatory No.
3: Firm Power to Toledo (p . 14-18);
Interim Power to Toledo (p . 19-21) ;
(2) Ohio Valley Elect'ric Corporation (Ex-hibit D page references): Surplus Power (p. 12-32);
(3) Ohio Edison Company: Entitlement of Capacity and Energy from Sammis No.
7 on the system of Ohio Edison; (4) The Cleveland Electric Illuminating Company (Exhibit E , p. 1-4) : En-titlement of Capacity and Energy from Eastlake No. 5 Union on the system of The Cleveland Electric Illuminating Company; (5) Contracts listed in (c) ( 4 ) above in response to (a) of Supplemental In-terrogatory No. 3 (Exhibit F, p. l-5; Exhibit G, p. 1-8; Exhibit H, p.
1-3; Exhibit I, p. 1-3): permit utilization by the parties thereto of their various capacity entitle-ments from certain short lead time capacity units.
(e) For dates and signatories to agreements, see answer to (a) above.
(f) For rates, see pages of contracts or service schedules referenced in (d) above, except as to contracts placed in Central Depository by Ohio Edison, as to which reference is made to its references.
(g') For methods and factors used to determine rates, see contracts or service schedules to contracts referenced in (d) above, which were the result of arms-length bargaining and, except Exhibit C, Federal Power Commission action. Exhibit C will be submitted for such action. .
Supplemental Interrocatorv No. 4 State each request, either formal or informal, since September 1, 1965 made by any electric utility to Company for a new or altered interconnection arrangemen,t, giving (a) the name of the entity, (b) the date of the request, (c) the date of any agreement to interconnect, (d) the reasons for any refusal to interconnect and (e) the date and author (s) of any document relating to any such refusal.
Answer This interrogatory is identicN1 to initial Department of Justice Interrogatory No. 1. There were inadvertent omissions in the Company's prior answer and accordingly the answer thereto is hereby restated in its entirety as to interconnections between the transmission system of the Company and other transmission systems since September 1, 1965. Interconnections were made pursuant to:
(a) The names of the parties involved appear in the fol-lowing list of contracts with the company:
(1) Facilities Agreement dated March 1, 1966 and amended September 1, 1967 with Ohio Power Company, Consumers Power Company and The Detroit Edison Company, and others, involving 345 kv interconnections with Ohio Power Company and the Michigan Companies; (2) Facilities Agreement dated March 1, 1973 with Consumers Power Company and The Detroit Edison Company for Allen Junction interconnection; (3) CAPCO Transmission Facilities Agree-ment dated as of September 14, 1967, including a 345kv interconnection with Ohio Edison Company; (4) Facilities Agreement. dated as of December 1, 1965 with Ohio Power Company and Indiana and Michigan Electric Company relating to Defiance interconnection.
All of the foregoing agreements have been made available to the Department of Justice and are on file with the Federal Power Com-mission.
(b) The interconnections were the result of mutual dis-cussions and contract negotiations with the parties to the con-tracts listed in response to (a) above so no specific date of request or author can be stated.
. ~ _
(c) See dates of agreements listed in (a) (1) , (2), (3) and (4).
(d) and (e) No refusals to interconnect.
Supplemental Interrogatory No. 5 Since September 1, 1965, has Company ever purchaced a discernible quantity of electric power and/or energy from another electric utility at one point on its system and, within about 48
. hours, sold a comparable quantity of electric. power and/or energy to that same electric utility at another point on the Company's system? If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amount of power and/or energy in MWH involved annually., (d) the reason (s) for the transaction (s), (e) the date of and signatories to any agreements relating to each situation, (f) the rate at which Company billed the other electric utility, (g) the rate at which the other elec-tric utility billed'the Company, and (h) the method and f actors used to determine the rates listed in response to parts (f) and (g).
a--e-
s -
Supplemental Interrogatory No. 6 Since September 1, 1965, has Company ever purchased a dis-cernible quantity of electric power and/or energy from another electric utility at one point on its system and, within about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, sold a comparable quantity of electric power and/or energy to another electric utility (or utilities) at another point (or points) in Company's system? If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amount of power and/or energy in MWH involved annually, (d) the reason (s) for the transaction (s) , (e) the date of and cignatories to any agreements relating to each situation, (f) the rate at which Company billed the other electric utility (or utilities), (g) the rate at which the other electric utility billed the Company, and (h) the method and factors used to determine the rates listed in response to parts (f) and (g).
Answer Supplemental Interrogatories Nos. 5 and 6 are concerned with balanced purchases from one electric utility and sales to either the same utility or a third utility within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
The questions are incapable of being answered because the time 1
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within which the purchase was made is not specified; whether an hour, part of an hour, or day, or what. Likewise, there is no in-dication whether the questions relate to a single purchase or a series of purchases, either consecutively or intermittently, over some period of time. As a result, there is no way of knowing what kind of a comparable sale is inquired about. The important thing is that the company does not have any arrangements for reciprocal purchases and sales of comparable amounts of power within any fixed time period. The closest to anything of this kind was the purchase by the Company over a period of about one year of 200mw of short term power from the Michigan Companies and a simultaneous sale of part of this purchase to other CAPCO Companies. See response to Supplemental Interrogatory No. 1.
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
THE TOLEDO EDISON COMPANY and )~
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Davis-Besse Nuclear Power Station) ) AEC Docket No. 50-346A
)
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Perry Nuclear Power Plant, Units ) AEC Docket Nos. 50-440A 1 and 2) ) 50-441A AFFIRMATION We, LESLIE HENRY, and ROGER P. KLEE, are counsel for The Toledo Edison Company (Company) and hereby affirm that the Responses of the Company to Supplemental Interrogatories 1 through 6 of the U. S. Department of Justice are based on information supplied by the Company, and are true and correct to the best of our knowledge and belief.
S/
Leslie Henry /
/ N4 RO'ger P. Klee WITNESS my hand and notarial seal.
JMin&
Nopry[ublic WYYMI McCORMICK Nefary Public, Fulton & Luc.x Counti,,
Conuna' don Expires June 25, 1975
, . s, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
THE TOLEDO EDISON COMPANY and )
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Davis-Besse Nuclear Power Station) ) AEC Docket No. 50-346A
)
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Perry Nuclear Power Plant, Units ) AEC Docket Nos. 50-440A 1 and 2) ) 50-441A CERTIFICATE OF SERVICE I hereby certify that copies of "The Toledo Edison Eom-pany's Answers to Supplemental Interrogatories by the Department of Justice to The Toledo Edison Company and Others, Dated February 14, 1975", were served upon each person listed on the attached service list, by mailing the same, postage prepaid, this 27th day of March, 1975.
t~
Leslie Henry /
I 1
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--__o___
. s .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ).
THE TOLEDO EDISON COMPANY and )
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY )
(Davis-Besse Nuclear Power Station) ) AEC Docket No. 50-346A
)
THE CLEVELAND ELECTRIC ILLUMINATING ) .
COMPANY )
(Perry Nuclear Power Plant, Units ) AEC Docket Nos. 50-440A 1 and 2) ) 50-441A SERVICE LIST
' Douglas V. Rigler, Esq. Mr. Chase R. Stephens Chairman, Atemic Safety and Docketing & Service Section Licensing Board U. S. Nuclear Regulatory Foley, Lardner, Hollabaugh Commission and Jacobs 1717 H. S treet , N.W.
Schanin Building Washington, D. C. 20006 815 Connecticut Avenue, N.W.
Washington, D. C. 20006 Steven M. Charno, Esq.
Antitrust Division John H. Brebbia, Esq. Department of Justice Atomic Safety and Licensing Washington, D. C. 20530 Board Alston, Miller & Gaines (One copy of the Company's An-1776 K Street, N.W. swers to these Supplemental In-Washington, D. C. 20006 terrogatories, with Exhibits l attached, is being sent to each )
individual listed above. In John M. Frysiak, Esq. addition, nineteen copies of the Atomic Safety and Licensing Company's Answers, without Ex-Board hibits attached, are being sent U. S. Nuclear Regulatory Commission to Mr. Chase R. Stephens.)
Washington, D. C. 20555 I
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