ML19329F728

Amended Petition to Intervene & Request for Hearing Re AL Nuclear Fuel Fabrication Plant Application.Certificate of Svc,designation-authorizations in Lieu of Notice of Appearance & Board of Directors Resolution Encl

ML19329F728
Person / Time
Site:	07002909
Issue date:	06/11/1980
From:	Campbell R, Mcphillips J MCPHILLIPS, J.L., SAFE ENERGY ALLIANCE
To:
References
NUDOCS 8007110003
Download: ML19329F728 (9)

Text

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BEFORE THE U.S. NUCLEAR REGULATORT COMMISSION OFFICE OF NUCLEAR.".ATERIAL SAFETY AND SAFEGUARDS N

DIVISION OF FUEL CYCLE AND MATTiIAL SAFETY g

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URANIUM FUEL LICENSING BRANCH ll

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ous et ne Sc88f x APPLICATION of Westinghouse p & $s*8 -

Electric Corporation for a Special Nucl'ar Material

. DOCKET NO.

/0-2909 fo e

License for the Alabama m,

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• ?uclear Fuel Fabrication W

N*- T N $ h-a' Plant to be located near w-Prattville, Alabama

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AMENDED Pr*ITION FOR LEAVE TO.'{ f 77-i INTERVENE AND REQUEST FOR A HEARING

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.yi Comes T.ow the Petitioner,' The Safe Energy Alliance of. Central @

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Alabama, Inca (hereinaf ter "f CACA") and hereby files 'this amended ;i7 k

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.m-petition for leave to intervene'in the above-styled and'numberei @ Q y 2: ' :.

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proceeding and states unto this Honorable Commission as followst; 'M

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The petitioner is a duly-incorporated non-profit.

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corporation, having been properly incorporated in the Office of,7Q4.

the Judge of Probate, Montgomery County, Alabama on June 10," 1950 Q p t..

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The petitioner has. been authorized by 18 of its members clj. c,

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s to represent them in opposing the construction and operation by; [f, i

Westinghouse Electric Corporation of a nuclear fuel fabricatidn R4.Q [;

plant to be located near Prattville, Alabama..All such members gy 9

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d-have cognizable interests as more specifically stated in Exhibits I an'd II attached hereto and incorporated herein. One set cf said Dt membert, consisting of 10 in number, have previously filed JL individual petitions to intervene on April 7, 1980 and by the pleading I

embodied in Exhibit I have authorized and designated SEACA to

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represent its common interests in the above-styled proceeding, f

hI The second set of said members, consisting of 8 in number, L

have not previously filed individual petitions but all of said members snare the same common interests of the first set of

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members, and all have duly authorized and designated SEACA to represent their interests. See Exhibit II attached hereto.

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All of the individuals named in the two pleadings attaened

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nereto as Exhibits I and II are members or SEACA and all live and j

werk in the vicinity of the prcposed site of tne Westingnouse plant g

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n a h e prcxi.m ty of less

• ha. So mies f rom the sit.o.

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addition, those individual members of SEACA named in Exhibits I and II have the following ecgnizable interests which would be affected by a release of radiation into the environments

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(a) The named SEACA members would be af fected by any release of radiation into the environment my tne proposed Westinghouse nuclear fuel fabrication plant to be located in Prattville. This environ-ment includes air, ground, and water, especially the Alabama River.

(b) The named SEACA members would be affected by any acci-dent involving transportation of uranium to the proposed f acility or transportation of nuclear fuel pellets from the facility.

J (c) The named SEACA members would be affected by releases of radiation from waste storage containers to be located at the pro-posed facility.

(d) The named SEACA members *Would be affected by any acci-dont or other incident involving the proposed Westinghouse plant W

t which occurred as the result of sabotage, geological upheavals, flooding, tornadoes, or for any other causes.

(e) The namad SEACA members' enjoyment of their property may be adversely affected by the construction and operation of the proposed Westinghouse plant.

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One general purpose of SEACA which is stated in Article II (a ) of its Articles of Incorporation is:

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" Promote a concrehensive educational program educating the public of Alabama as to the benefits of safe energy and at to the hazards of unsafe energy sources, including especially i

e those which emit radioactive wastes."

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Another specific purpose of SEACA stated in Article II(b)

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" File a petition to intervene before the United States

)l Nuclear Regulatory Commission in the application of Westing-

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house Electric Corporation for a Special Nuclear Material license for the Alabama Nuclear Fuel Fabrication plant to be located near Pr.attville, Alabama fcr the purpcse of L*

opposing said license and plant as being detrimental to the

{b health and life interests of the pecple of Central Alabama

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and other forms of animal and plant life in said vicinity."

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As is indicated by Exhibit III attached hereto and incor-i, pcrated herein, the president of SEACA, namely Robert M. Ca*p5 ell, has been authorized by tne Board of Directors of SEACA to sign this rotitic, in the name of SEACA.

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The petitioner snould be permitted to intervene in this cause because the interests of petitioner's members may be affected

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by the results of the proceeding in all the aspects listed in *W.i A

paragraph #3.

Any order which may be entered in the proceedings j.

may affect Petitioner's members' safety, health and enjcyment.

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of property

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Pursuant to S2.714 (a) (3) (b), Petitioner will: file a '

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supplement which specifies with perticularity-the contentions -

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'fij,-[ID with regard to each aspect lon which intervention is reque.sted.

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. uch supplement will be filed not later than 15 days _ prior to any y d[, h. ghk

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.j pre-hearing conference.

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Pursuant to S2,714,' Petitioner'fdrther' requests that a % k k hearing be coriducted as to all issues raised herein..

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m h ~ // ~ /980 Safe Energy Alliance of Central e f.!

CATE Alabama, Inc. PETITIONER, by

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^:[W:M ROBERT H. CAMPp tI.

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O M %# D M 516 So. Perry St.

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Address

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Attorney at I,aw

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P.O. Box 64

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Alabama 36104 W

Montgomery, Ala. 36101

City, State Zip (205)-262-1911

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VERIFICATION i

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I, the above-naned petitioner, bclieve the foregoing state-j

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ments to be true and correct in every particular.

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b - / / - / </ fC Safe Energy Alliance of Central DATE Alabama, Inc.,. Petitioner, by

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• FATE OF ALABAMA COUNTY OF MO' TGOMERY

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Before me undersigned Notary Public, appeared Robert A. Campbell,

.cwn to me, who did sign the above verification as testar.ent that his statements in the foregoing petition are true and correct in every particular, on this the ;/f(( day of June, j

1980.

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ROTARY PUBLIC

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I hereby certify that copies of the foregoing Amended sk Petition For Leave to Intervene and Request For a Hearing have

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.s been served on the following at the addresses noted:

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John F. Wolf, Esq., Chairman Donald R. Marcucci, Esq. +

Atomic Safety and Licensing Board Law Dept.

3409 Shepherd Street Westinghouse Electric Corp.

Chevy Chase, MD 20015 P.O.-Box 355 Pittsburgh, PA 15230 Dr. Harry Foreman Member Atomic Safety and Licensing Board Sherwin Turk, Esq.

Box 395, Mayo U.S.

Nuclear Pegulatory Comm.

University of Minnesota Washington, D.C.

20555 Minneapolis,2t3 55455 David L. Allred Dr. Mar tin J. Steindler, Member 231 Oak Forsst Drive Atomic Safety and Licensing Board Montgt.nery, Ala.

36109 Argonne National Laboratory 9700 South Cass Avenue Dr Ira L. Myers, M.D.

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Argonne, Il 60439 State Mealth Officer State of Alabama Barton Z. Cowan, Esq.

Dept. of Public Health j

John R. Kenrick, Esq.

State Office Bldg.

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Jckert, Seamans, Cherin & Mellot Montgomery, Ala. 361J4 Forty-Second Floor 600 Grant Street Docketing and Service Section*

Pittsburgh, Pa.

15219 Office of the Secretary U.S. Nuclear Regulatorv Comm. d ;

Atomic Safety and Licensing Board Panel Washington, D.C.

20555 gl U.S. Nuclear Regulatory Comm.

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Atomic Safety and Licensing Appeal Panel h

U.S. Nuclear Regulatory Comm.

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on this the /5[ b day of June, 1980.

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BEFORE THE U.S. NUCLEAR R1:GULATORY CO.*4 MISSION i

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OFFICE OF NUCLEAR MATERIAL SAFETY A'19 SAFEGUARDS i -

DIVISION OF FUEL CYCLE A37 MATE *tIAL SAFETY UR'ANIUM FUEL LICENSING BRANCH

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APPLICATION of Westing.ouse Electric Corporation toi a Special Nuclear Material DOCKET NO.

70-2909 Lictense for the Alabama 1

Nuclear Fuel Fabrication y

Plant to be located near Prattville, Ala.;

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DESIGNATION-AUTHORIZATION OF T'!E

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-il SAFE ENERGY ALLIANCE OF CENTR.*4 ALABAMA, INC. TO REP 8tESENT INTERESTS OP THE NAMED INDIVIDUAL PETI'PIONF'IS i'

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W, the ' individuals named and addressed at the bottom ot this y_

pleading, do hereby authorize and designate the P.fe Energy Alliance of Central Alabama, Inc and its president Robert H.

Campbell to serve as a single spokesman to, represent our courion "

interests in the above-captioned prceeedings, and we' further authorize i

and direct attorney Julian McPhillips to continue 'as our individual l

and corporate attorney in his representation of the Sate Energy Alliance of Central Alabama, Inc. (hereinatter "SEACA").

As grounds therefore, we show unto this Honorable Conmission the following:

1.

We all filed petitions for leave to intervene and re-quested a hearing in the above-captioned proceedin7s on April 7,

1980, in which we all stated as petitio.ers that:

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Petitioner 11h ? and works in close proximity tc 3'

the proposed facility.

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Petitioner would be affected by any release of fl radiation into the environment.

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Petitioner would be affected by any accident in-d$

volving transportation of uranium to tne facility or of fuel l'

pellets from tne facility.

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Petitioner would be affected by releases of rad-3(

iation from waste storage containers which are to %:n located 4

at the proposed facility.

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Petitioner would to affected by any accident which occurred as a result of sabotage, geolocical upheavals, J

flooding, Mrnadoes, or for any other causes, f

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Pet..tioner's enjoyment of nis property may be 4i af tected by the proposal.

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'fe all have been represented by attorney Julian Mc-J J

h Phillips and wian to continue to be represented by him.

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We are all members of the SEAct and beli'*ie that SEACA l

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1 Exhibit I, Cont'd.

.s NAME RESIDENCE WORK LOCATION M[I'd 1245 Glen Gratton Randy Aro,hov Montgomery, Ala. 36111 Stmhine Grocery ~'~

Montgomery County, Ah C LYA Alabarra P.O. Box 66 Charles O. Butler Elmore, Ala. 36075 Elmore, Ala.

$1 P.O. Box 66 Marilyn F.

Butler Elmore, Ala. 36075 Elmore, Ala.

_'j ug. T r.-///. TJ l ( - P.O. Box 11731 Robert H. Gempbell Montgomery, Ala.

36116 Montgomery, Ala.

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2296 Country Club Dr.

Sarah (S.N.) Draut Montgomery, Ala. 36106 2296 Country Club Dr.1

~l Montgezery, Ala. 36106 3211 Wilmington Road Robert E. Ely Alabama State Univ.

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l-ohn A. Jephson % g 50 Lamar Ave.

Selma, Dallas County, Alabama Stat e Dept.-

Ala. 36701 of Education Montgcmery County, Ala.

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AO w's 1801 W. 2nd Street Linda G. Moore Sunshine Grocery Montg u ery, Ala. 36106 Montgomery County, Ala.

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Ann Toledo 2537 Bay Street Southlawn Elementary --

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Montgomery, Ala. 36107 School - Montgomery C//////[L /-t'x_4 320 W. Magnolia County, Alabama

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WilIlam Carroll Auburr., Alabama 246 S'outn Port Montgomery, Ala.

CO"NTY OF MON'"CCf ERY STATE OF ALABAMA Before me, the undersigned Notary Public, appearr' the individuals na. rod and addressed aboie, who, af ter being duly i

sworn, did si,n the above as a cesign stion-authorization of i

i' SEACA to represent their interests in the above-captioned pro-1i

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ceedings.

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BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS DIVISION OF FUEL CYCLE A'ID MATERIAL SAFETY

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URANIUM FUEL LICENSING BRANCH

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APPLIC.\\ TION of Westinghouse Electric Corporation for a 9

Special Nuclear Material

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f. y q License for the Alabama DOCKET NO.

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u Nuclear Fuel Fabrication

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'7' trattville, Ala.

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jQ DESIGNATION-AUTHORIZATION OF THE Nkh y

1 SAFE ENERGY ALLIANCE *>F CENTRAL e.g,' hip @1 j

' 96 ALABAMA, INC. TO REPRESENT INTERESTS OF 1

THE NAMED INDIVIDUAL MEM9ERS f

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We, the individuals named and addressed at the bottosa of this '95 -

j pleading, do hereby authorize and designate the Safe Energy _

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Alliance of Central Alabama, Inc. and its president Rcoert H.'

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. Ut C Campbell to serve as a single spokesman to represent our common T 'jf C

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and direct attorney Julian McPhillips to act as our indiv', dual andy p"

corporate attorney in his representation of the Safe Energy Alliance of Central Alabama, Inc..(hereinafter "SEACA*).

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al- $ Q grounds therafore, we show unto tnis corunission tras following:

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1.

We all filed petitions for leave to intervene and re-

~ 71 quested a hearing In the above-captioned proceedings on April

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7, 1980, in wnien we all stated as petitioners that:

A.

Petitioner lives anc works in close proximity to the proposed facility.

B.

Petitionar would be affected by any release et rsdiation into tne environment.

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Petitioner woula be affected by any accident in-j volving transportation of uranium to the facility or of tuel g

pellets from the facility.

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Petitioner would be af fected by releases of rad-iation from waste storage containers which are to be located j

at the proposed facility.

E.

Petitioner would be affected by any accident which

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occurred as a result of sabotace, geological upheavais, 21ood ing, tornadoes, or for any other causes.

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Petitioner's enjoyment of his property may he affected by t..a proposal, n

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Ne all desire to be represented by attorney Julian McPhillips.

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de all believe that SEACA, its pre ndent and othe.

officers, sill well renresent our interests.

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We hereby attest this pleading by cur respective signatures above our printed name and notorize below.

NAME RESIDENCE WORK I,0 CATION 0&, /,

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COUNTY OF MONTGOMERY 9{

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Before me, the undersigned Notary Public, appeared the in-dividuals named and addre-sed above, wno, after being duly sworr.,

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k did sign the above as a. designation-authorf tation of SEACA to

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f SAFE ENERGY ALLIANCZ Exhibit III OF June 10, 1990 CENTRAL ALABAMA

.. 516 So.. Perry St.

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-4 Montgomery, Alabama 36104 t,,

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_,3J OF SAFE FNERGY J.LLDNCE OF CENTRAL -

ALABAliA, INC. (SEACA) AUTHORIZING ROBE *tT

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H. CAMPfELL, AS PRESIDENT OF SEACA, TO

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-a SIGN PETITION TO INTERWNE OF SPACA.

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j) e, the undersigned members of,the Board ofl Directors.of.ithe Q %

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d Safe Energy Alliance of Central' Alabama,<Inc... do hereby resolve,gi'Mf 1:J t L n' m,

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i authorize, and direct Robert.H. Campbell, as president of-the Safe 74 e. M.Q. o Pj $'

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Energy Alliance of Central' Alabama, Inc. -(SEACA) to sign inL,

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the name of SEACA a petition for~ leave to intervene and request'

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for a hearing,in the application of Westinghouse Electric' Corporaths p '.

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H Fyel Fabrication plant to be located near Prattville,' Alabama, gt

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sa.id intervention to be before the Urarf.um Fuel Licensing Branch ~ pnig b.

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y; of the U.S. Nuclear Regulatory Comission, Office of Nuclear MateriaIY p Safety and Safeguards, Division of Fuel Cycle and Material Safetyyhr.Q s

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Frank Mills

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Albert Jackson Naf tel

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