ML19332A494
| ML19332A494 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 09/15/1980 |
| From: | Chanania F, Fabrikant R, Stahl D HOUSTON LIGHTING & POWER CO., JUSTICE, DEPT. OF, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19332A493 | List: |
| References | |
| ISSUANCES-A, NUDOCS 8009160160 | |
| Download: ML19332A494 (17) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter Of
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HOUSTON LIGHTING & POWER
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Docket Nos. 50-498A COMPANY
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50-499A (South Texas Project, Units
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1 and 2)
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STIPULATION It is hereby stipulated and ag"eed by and among the United States Department of Justice (" Department"), the Staff of the Nuclear Regulatory Commission ("NRC Staff") and Houston Lighting and Power Company ("HL&P"), Central and South West Corporation ("CSW"), acting for itself and its subsidiaries including Central Power and Light Company
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("CP&L"), the City of Austin, Texas (" COA"',
and the City Public Service Board of San Antonio, Texas ("CPSB") [herein after referred to collectively as " Applicants"], as follows:
1.
Applicants hereby consent to incorporate into the license for South Texas Project, Units Nos. 1 and 2, the conditions set out in the attached document, entitled
" License Conditions for South Texas Project Units Nos. 1 and 2".
2.
The Department, the NRC Staff and CSW are of the opinion, which they will communicate to the Board, that the licensing of the South Texas Project, Units Nos. 1 and 2,
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under these conditions will not create or maintain a situa-tion inconsistent with the antitrust laws or the policies thereunder in accordance with the standards set forth in Section 105 of the Atomic Energy Act, and will withdraw their requests that the NRC conduct a hearing pursuant to Section lO5c of the Atomic Energy Act in these dockets.
3(a).
The Department, the NRC Staff, HL&P, COA and CPSB agree that none of them will seek or take any position in support of any modification of the attached conditions in this proceeding, and no Applicant listed in this sentence shall withdraw its consent to incorporation of these condi-tions into the license for the South Texas Project notwith-standing the outcome of any.further proceedings herein.
To the extent that the Department, the NRC, HL&P, COA or CPSB participates further'in this proceeding, it will defend these conditions should they be challenged.
3(b).
CSW will not seek or take any position in support of any modification of the attached conditions in this proceeding as those conditions apply to it (without prejudice to the right of CSW to seek a hearing before the NRC pursuant to paragraph B.(6)(a) of the attached condi-tions), and CSW shall not withdraw its consent to incorporation of these conditions as they apply to it into the license for the South Texas Project notwithstanding the outcome of any further. proceedings herein.
To the extent
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. - that CSW participates further in the proceeding, it will defend these conditions as they apply to it should they be challenged, but this ~ obligation of CSW shall not extend to any issue raised by it in any proceeding initiated by it under paragraph B.(6)(a) of these conditions.
4.
Each of the Applicants denies that its past conduct and/or its proposed activities under the license for the
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South Texas Project without these conditions are inconsistent with the antitrust laws in any respect, and nothing in this Stipulation or in these conditions constitutes any admission or evidenme of inconsistency with or violation of any law or regulation, state or federal.
Nothing in this Stipulation or in these conditions constitutes any evidence against any Applicant or any admission by any Applicant as to any issue in this or any other proceeding.
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UNITED STATES DEPARTMENT OF JUSTICE 4
By 1)# u) qk STAFF OF THE NUCLEAR REGULATORY COMMISSION By
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d#L CENTRAL AND SOUTH WEST CORPORATION acting for itself and its subsidiaries including Central Power and Light Company By
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HOUSTON LIGHTING AND POWER COMPANY By
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OF AUSTIN, TEXAS By CITY PUBLIC SERVICE BOARD OF SAN ANTONIO, TEXAS By Dated:
September 12, 1980
1 September 12, 1980 LICENSE CONDITIONS FOR SOUTH TEXAS PROJECT UNITS NOS. 1 AND 2 I.
A.
The following definitions apply to paragraph I.B:
,(1)
" Applicants" means severally and jointly Houston Lighting and Power Company (HLP), Central Power and Light Company (CPL), City Public Service Board of San Antonio (CPSB), and the City of Austin Electric Utility Department (COA) and any of their respective successors, assignees, or subsidiaries engaged in the generation, transmission or the distribution of electric power.
Where a license -
condition is directed to a specific Applicant, that Applicant is identified.
(2)
" South Texas Area" means (a) those counties in which Applicants serve electric customers at wholesale or retail, and (b) those other areas, if any, surrounded by the areas in (a) above.
(3)
" Entity" means an el'ectric utility which is a person, a private or public corporation, a govern-mental agency or authority, a municipality, a cooperative, or an association of any of the foregoing owning, operating, or contractually' controlli:ig or proposing in good faith to own, operate, or contractually control facilities for generation, transmission or distribution of electric power and energy for the purpose of providing electric utility service.
(4)
" Bulk Power" means the electric power and/or electric energy supplied or made available at transmission or subtransmission voltages.
(5)
" Costs" means all appropriate operating and maintenance expenses and all ownership costs where applicable.
(6)
The terms " connection" and " interconnection" are used interchangeably.
The Applicants defined in paragraph I.A.(1) are subject B.
to the following antitrust conditions:
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I.
B.
(1)
(a)- CPL shall afford to the Public Utilities Board of the-City of Brownsville an opportunity to participate in the South Texas Project, Units 1 and 2, on reason-able terms and conditions and in accord-ance with the South Texas Project Partic-ipation Agreement and on a basis that will fully compensate CFL for its actual t-costs, provided that Brownsville must enter into a firm commitment to acquire the ownership interest made available to 4:
it by the terms of this paragraph no later thar. January 1,1983.
The owner-ship interest.which CPL shall make avail-able to Brownsville shall be computed by-multiplying CPL's Generation Entitle-ment Share in STP Units 1 and 2 by the ratio of Brownsville's peak demand for 1980 to CPL's peak demand for 1980.
In the event-Brownsville obtains an owner-ship. interest from any Applicant other l
than CPL, the ownership interest which CPL must make available to Brownsville hereunder shall be reduced by one mega-watt.for each megawatt in excess of 12
. megawatts that Brownsville acquires from other Applicants.
Applicants shall not exercise any rights of first refusal over Brownsville's efforts to participate in the South Texas Project to the ex-tent offthe first 50 MW of such owner-i ship share.
(b)
CPL shall afford Brownsville reasonable
' transmission services.to enable it to l
obtain delivery of power.from the STP, provided that CPL is fully compensated i'
'for its costs-of'such transmission ser-vices plus a reasonable return on invest-4 ment, and provided further that in the event transmission capacity is not avail-ablerto provide such transmission ser-1 vices, the provisions of Paragraph I.B.
t (4) hereof define the extent of the obli--
gation which CPL has with respect torthe construction of additional transmission.
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facilities necessary to provide such' transmission service.
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(c)
CPL will also afford all reasonable coordinatian services (including but not limited to reserve sharing, back-up power, maintenance power and emer-gency power) necessary for Brownsville to have effnctive access to power from STP obtained from CPL, provided that CPL is fully compensated for its costs of providing such coordination services plus a reasonable return on investment.
(d)
Each Applicant shall facilitate where necessary Brownsville's obtaining the participation interests and services specified~in paragraphs 1(a), 1(b) and 1(c) above.
(2)
The Applicants, as long as they are members of the Texas Interconnected Systems (TIS) or any other organization which considers the planning for or operations of ERCOT-TIS electric utili-ties, shall support reasonable requests by Entities in the South Texas Area having gener-ation capacity for membership in TIS or such other organizations.
The Applicants shall also propose and actively support, as long as they are members thereof, the creation of one or more additional classifications of TIS member-ship, based on non-discriminatory criteria to afford access to data, studies and recommendations to all Entities in the South Texas Area who desire membership.
The Applicants shall share information with other Entities with respect to, and shall conduct with other such Entities through any electric utility planning organiza-tions of which the Applicants are members, joint studies and planning of future generation, transmission and related facilities; provided, however, that this condition shall not obligate the Applicants to conduct such joint studies or joint planning unless (1) the studies or planning are requested and carried out in good faith and based on reasonably realistic and reasonably complete data or projections, (2) the studies or planning are reasonably justi-fied on the basis of sound engineering prin-ciples, (3) appropriate protection is accorded l
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4-prop'rietary or'other confidential-business and financial information, and (4) the costs for such studies or planning are allocated on l
a fair and equitable basis.
(3) -Each Applicant shall participate in and facil-itate the exchange of bulk power by trans-mission over its own transmission facilities between or among two or more entities in the J
South Texas Area with which the Applicant is connected; and between any such Entity (ies) and any Entity (ies) outside the South Texas Area between whose facilities the Applicant's transmission lines and other transmission lines, including direct current (asynchronous) trans-mission lines, form a continuous electrical path; provided, tha't (i) permission to utilize such other transmission lines has been re-quested by the proponent of the arrangement, (ii) the: arrangements reasonably can be ac-commodated from a functional and technical standpoint, and (iii) any Entity (ier) request-ing such transmission arrangements shall have (their) given reasonable advance notice of its schedule and requirements.
Such transmission shall be on terms that fully compensate an Applicant for its costs including a reasonable' return on investment; provided, however, that such transmission services and the rates to be charged therefor shall be subject to the jurisdiction of the appropriate regulatory agency (ies).
Where the rates to be charged are subject to the jurisdiction of an appro-priate regulatory authority, the Applicants shall not refuse to provide such transmission services merely because the rate (s) to be charged therefor are the subject of dispute with such Entity (ies).
An Applicant shall not be required to enter into any arrangement which would unreasonably impair system reli-ability or emergency transmission capacity, it being recognized that while'some transmis-sion may be operated fully loaded other trans-mission may be for emergency use and operated either unloaded or partially loaded.
(45.Each Applicant shall include in its planning and construction programs sufficient trans-mission capacity as required-for the trans-actions referred to in paragraph I.B.(3) (and I.B.(5) for CPL), provided any Entity (ies)
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in the South Texas Area gives an Applicant sufficient advance notice as may be.necessary
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to Accommodate its (their) requirements-from a functional and technical standpoint and that such' Entity (ies) fully compensates an Appli-cant for its costs including a reasonable re-turn on investment.1/An Applicant-shall not be. required to construct transmission facili-
-ties if construccion of such facilities is infeasible, or df such would unreasonably im-
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pair system relsability'or' emergency trans-mission capacit3 In connection with the performance of the obligations above, an Applicant shall not be foreclosed from requir-
-ing a reasonable contribution in aid of con-struction or from making arrangements for coordinated construciton of future transmission lines such that'each of the parties to the transaction would own an interest in or a segment of the transmission addition in pro-
. portion to its share of the cost of the addi-tion.
Any such contribution made in aid of construction or ownership interest shall also be properly credited in determining any wheel-ing charges.
If an Applicant engages'in joint ownership of transmission lines with any other Entity (ies), it shall not refuse to engage in similar transactions in comparable circumstances with other Entities, subject to the provisions limiting an Applicant's obli-gations above.
I.
B.
(5)
CPL shall, upon reasonable advance notice, enter into arrangements for the sale of-full and partial requirements bulk power pursuant to a filed tariff to any requesting Entity having a non-aggregated generating capacity of 200 megawatts or less under reasonable '
terms and conditions which shall include a provision ~for CPL to recover its costs of providing-such service plus a reasonable re-turn on investment.
Such tariff shall not require CPL to enter into any arrangement for such' sale (s) if -(a) it does not'have available sufficient' bulk power or adequate transmission to provide the requested service; or (b) the sale would impair CPL's ability to render adequate and reliable service to its own customers or itsLability to discharge prior commitments.
It is expressly recognized, 1/-
Nothing in.this paragraph shall require CPSB or COA to
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undertake any action (s) which may be contrary to any
-state constitutional. provision.
and'such tariff may reflect, that the deter-mination whether sufficient bulk power or adequate transmission is available to accom-modate a request for full or partial require-ments-bulk power will consider and recognize that (1) CPL will be engaging in centralized economic dispatch with its affiliates in accordance with, and pursuant to the require-ments of, the Public Utility Holding Company Act of 1935, (2) pursuant to such require-ments CPL may first. utilize its generating and transmission capacity to accomplish such centralized economic dispatch before its generating and transmission capacity is made available for full or partial requirements bulk power sales under the tariff, and (3) if other CSW system capacity becomes available by reason of CPL's participation in such cen-tralized economic dispatch, then such other CSW system capacity will, at the option of CSW, be made available in lieu of CPL's obli-gation to provide such capacity.
Any curtail-ment of CPL's full or partial requirements sales shall be on a reasonable and non-dis-criminatory (where possible) basis.
(6) (a)In corinection with the performance of its ob-ligations herein and subject to the provi-sions of this paragraph, HLP shall not dis-connect from or refuse to connect its then-existing or proposed facilities with the facil-ities of any Entity used or proposed to be used for the transmission of electric energy in interstate commerce by reason of the inter-state character of such facilities, and HLP will not prevent any Entity with which it maintains connections from establishing, main-taining, modifying or utilizing a connection with facilities used or proposed to be used for the transmission of electric energy in interstate commerce by reasons of the inter-state character of such facilities, provided that, anything in these license condition,s to the contrary notwithstanding @ut subject to subparagraphs 6 (b) and 6 (d) below) any Entity seeking to establish, maintain, modify or utilize any connection which could affect the nonjurisdictional status of HLP under the Federal Power Act shall have filed an appli-
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cation with and used its best efforts to ob-
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-tain an' order from the FERC,. applicable to HLP under Sections. 210, 211 and 212 of such requiring the establishment, maintenance,
- Act, modification:or utilization of such connection.
In the event that an Entity files an applica-
. tion pursuant to this subparagraph, HLP agrees
.that it will not unreasonably oppose any such application.
In the event ~such application is deniied by a valid order of the FERC, any continuing refusal by HLP to establish, main-tain, modify or utilize such connection with such Entity.shall be subject to review by the.NRC in accordance with the Atomic Energy Act of 1954, as amended, and the rules and regulations thereunder, to determine whether any such refusal would create or maintain a-situation inconsistent with the antitrust laws or the policies thereunder in accordance with the standards set forth in Section 105 of such provided that all-factual determinations Act; by the FERC on any cost or-system reliability reason (s) for any such refusal shall not be The subject to redetermination by the NRC.
burden of proof will be on the HLP in such NRC proceeding.
(6) (b)HLP shall not enter into or maintain any agree-ment or' understanding with another Entity or Applicant to refuse to deal with any other or Applicant (s) with the purpose Entity (ies) of--maintaining an exemption from jurisdiction under the Federal Power Act, and in the event that'HLP refuses to make an interconnection with or chooses ta disconnect from any Entity (ies), ~ such decision and/or action by HLP will be undertaken unilaterally, not jointly, and without consultation with any~other En-tity (ies), provided, however, that after HLP decides to undertake such action, it may notify any affected Entity of its decision.
.(6) (c)In the event that an Entity files an applica-of this tion pursuant to subparagraph (a) paragraph solely by reason of HLP's desire to maintain its exemption from jurisdiction under the Federal Power Act, HLP agrees to pay such Entity's reasonable expenses in connection-
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~with such application 1and the ensuing pro-ceeding,1/.provided, however, that HLP shall not be required to pay for any-expenses of such Entity if that Entity's application is denied by FERC for: reasons advocated by HLP at FERC, and provided_further, that HLP shall not be required to pay for-any costs or ex-penses of such Entity which that Entity would have incurred had it not filed an application solely by reasons of HLP's desire to maintain its exemption from jurisdiction under the Federal Power Act.
(6) (d)Nothing in these License Conditions shall im-pair the right of the Department of Justice or any other Entity, public or private, to file an antitrust action in any Federal Court in
-the event any Applicant refuses to establish, maintain, modify or utilize any connection with any Entity (ies), provided that nothing herein shall preclude any Applicant from raising any legal or equitable defense that may be available to it.
(7)
HLP agrees to use its best efforts to amend any agreements'with all Entities to ensure that.such agreements are not inconsistent with paragraphs L(6) (a) and (6) (b) hereof.
(8)
If Applicants participate in any future nu-clear units other than those which are now under construc' ion or for which an application for a construction permit has been filed, they will' afford sf.milar participation to Entities in the-South.'exas Area on a reasonable basis.
(9)
Applicants agree that the reliability of power delivered into TIS-ERCOT over DC asyn--
chronous connections shall not be treated dif-ferently by the Applicants, for purposes of 1/_
This obligation shall not apply to the-expenses of Central and South West Corporation.or Texas Utilities Company or any of their respective -subsidiaries, including but not.
limited to_the expenses of CSW and any of its subsidiaries incurred in FERC Docket No. EL79-8.
spinning and installed reserve calculations and requirements, than would be the case if such power originated within TIS-ERCOT.
Outages on DC asynchronous connections shall be treated by the Applicants in the same way as losses of generation within TIS-ERCOT.
Appli-cants agree to support the adoption of prin-ciples involving DC asynchronous connections contained in this paragraph within any TIS or ERCOT organization.
(10) HLP and CPL shall use their best efforts to modify the Offer of Settlement filed in FERC Docket No. EL79-8 to include each of the undertakings set forth in the letter agree-ment among HLP, Central.and South West Corpor-ation, Texas Utilities Company and the FERC staff, dated September
-, 1980.
HLP and CPL shall thereafter use their best efforts to secure approval thereof by the FERC, and shall abide by any valid order (s) of the FERC issued pursuant to the Offer of Settle-ment.
Nothing herein shall preclude the-Department of Justice from instituting or intervening in any proceeding at FERC, includ-ing Docket No. EL79-8, and from presenting such arguments and evidence that it deems
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appropriate.
(11) The foregoing conditions shall be implemented (1) in a manner consistent with applicable Federal, state and local statutes and regu-lations, and (2) subject to any regulatory agency having jurisdiction.
Nothing herein shall preclude the Applicants from seeking an exemption or other relief to which they may be entitled under applicable law or shall be construed as a waiver of their right to con-test the applicability of the license condi-tions with resper c to any factual situation.
Tr-'
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S
. HOUSTON LIGHTING & POWER COMPANY, S
Docket Nos. 50-498A et al.
S 50-499A 5
(South Texas Project, Units S
Nos.1 and 2)
S S
TEXAS UTILITIES GENERATING S
Docket Nos. 50-445A COMPANY, et al.
S 50-446A S
(Comanche Peak Steam Electric S
Station, Units 1 and 2)
S CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the foregoing:
STATUS REPORT ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY; STIPULATION; and LICENSE CONDITIONS FOR SOUTH TEXAS PROJECT
't UNITS NOS. 1 AND 2 were served upon the following persons, first by hand *, or by deposit in the United States Mail, class postcge prepaid, this 15th day of September,1980.
Peter G. Flynn /
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Alan S. Rosenthal, Chairman
- Jon C. ~ Wood, Esquire Atomic Safety & Licensing Appeal Matthews, Nowlin, Macfarlane
& Barrett Board Panel U.S. Nuclear Regulatory Commission 1500 Alamo National Building 1
Washington, D.C.
20555 San Antonio, Texas 78205 Charles G. Thrash, Jr., Esquire Thomas S. Moore Atomic Safety and Licensing Appeal E.W. Barnett, Esquire Theodore F. Weiss, Esquire
. Board Panel U.S. Nuclear Regulatory Commission J. Gregory Copeland, Esquire Washington, D.C.
20555 Baker & Botts 3000 One Shell Plaza Michael C. Farrar.
Houston,' Texas 77002 Atomic Safety & Licensing Appeal R. Gordon Gooch, Esquire Board Panel U.S. Nuclear Regulatory Commission Steven R. Hunsicker, Esquire r
Washington, D.C.
20555 Baker & Botts 1701 Pennsylvania Avenue
- Marshall E. Miller, Chairman Washington, D.C.
20006 Atomic Safety & Licensing Board
- Frederic D. Chanania, Esquire Panel U.S. Nuclear Regulatory Commission Michael B. Blume, Esquire Washington, D.C.
20555 Ann P. Hodgdon, Esquire U.S. Nuclear Regulatory Commission Michael L. Glaser, Esquire Washington, D.C.
20555
'1150 17th Street, N.W.
Washington, D.C.
20036 Roff Hardy Chairman and Chief Executive Sheldon J..Wolfe, Esquire Officer 2
- Atomic Safety & Licensing Board Central Power and Light Company Post Office Box 2121 Panel U.S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington,.D.C.
20555 G.K. Spruce, General Manager Atomic Safety and Licensing City Public Service Board Post Office Box 1771 Appeal Board Panel U.S. Nuclear Regulatory Commission San Antonio, Texas 78203 i
Washington, D.C.
20555 Mr. Perry G. Brittain
- Chase R. Stephens, Supervisor (20)
President
-Docketing and' Service Branch Texas Utilities Generating Company U.S. Nuclear Regulatory Commission 2001 Bryan Tower Washington, D.C.
20555 Dallas, Texas 75201 Mr'. Jerome D.-Saltzman-G.W. Oprea, Jr.
Chief, Antitrust and Indemnity Executive Vice-President Houston Lighting & Power Company Group U.S. Nuclear Regulatory' Commission Post Office Box 1700
-Washingtol,.D.C.
20555 Houston, Texas 77001
- J.
Irion Worsham,' Esquire R.L. Hancock, Director Merlyn D. Sampels, Esquire City of Austin Electric Utility Spencer'C. Ralyea, Esquire Post Office Box 1086 Worsham, Forsyth & Sampels Austin, Texas 78767 2001 Bryan Tower, Suite 2500
' Dallas,--Texas 75201
I
_2-Kenneth M. Glazier, Esquire
. Don R. Butler, Esquire David A..Dopsovic, Esquire Frederick H. Parmenter, Esquire 211~ East Seventh Street Austin, Texas 78701 Susan B. Cyphert, Esquire Nancy A. Luque, Esquire l
Mr. William C. Price Robert Fabrikant, Esquire Central Power & Light Company Energy Section Antitrust Division Post Office Box 2121 U.S. Department of Justice l
Corpus Christi, Texas-78403 P.O. Box 14141 Washington, D.C.
20044 Mr.
G. Holman King West Texas Utilities Company Morgan Hunter, Esquire Post Office Box 841 Bill D.
St. Clair, Esquire Abilene, Texas 79604 McGinnis, Lockridge & Kilgore Fifth Floor Jerry L. Harris, Esquire Texas State Bank Building Richard C. Balough, Esquire 900 Congress Avenue City of Austin Austin, Texas 78701 t
Post Office Box 1088 Austin, Texas 78767 W.S. Robson General Manager 4
- Joseph B. Knotts, inc., Esquire South Texas Electric Cooperative, Nicholas S. Reynolds, Esquire Inc.
C. Dennis Ahearn, Esquire Route 6, Building 102 Debevoise & Liberman Victoria Regional Airport 1200 Seventeenth Street, N.W.
Victoria, Texas 77901 Washington, D.C.
20036
- Robert C. McDiarmid, Esquire Don H. Davidson George Spiegel, Esquire Robert A. Jablon, Esquire City Manager Marc R. Poirier, Esquire City of Aust,in P.O. Box 1088 Spiegel & McDiarmid y
Austin, Texas 78767 2600 Virginia Avenue, N.W.
Suite 312 Jay Galt, Esquire-Washington, D.C.
20037 Looney, Nichols, Johnson & Hays 219 Couch Drive Leon J. Barish, Asst. Atty. General Oklahoma City, Oklahoma 73102 Texas Attorney General's Office Post Office Box 12548 Knolant J. Plucknett Austin, Texas 78711 3
Executive Director Committee on Power for the South-
- William H. Burchette, Esquire west, Inc.
Frederick H.
Ritts, Esquire 5541 East Skelly Drive Law Offices of Northcutt Ely Tulsa, Oklahoma 74135 Watergate 600 Building Washington, D.C.
20036 John W. Davidson, Esquire Sawtell, Goode, Davidson & Tioili Tom W. Gregg, Esquire a
1100 San-Antonio Savings Building Post Office Box. Drawer 1032 San Antonio, Texas 78205 San Angelo, Texas 76902 4
- Douglas F. ' John', Escuire-Leland F. Leatherman, Esquire McDermott, Will and Emery McMath, Leatherman & Woods, P.A.
1101 Connecticut Avenue,.N.W.
711 West Third Street Suite 1201-Little Rock, Arkansas 72201
. Washington, D.C.
2003,6
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Paul W. Eaton, Jr., Esquire Hinkle, Cox, Eaton, Coffield & Hensley 600 Henkle Building Poat Office Box 10 Ro2well, New Mexico 88201 Robert M. Rader, Esquire Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 W.N. Woolsey, Esquire Klcherg, Dyer, Redford & Weil 1030 Petroleum Tower 78474 Corpus Christi, Texas Donald M. Clements, Esquire Gulf States Utilities Company Post Office Box 2951 B3aumont, Texas 77704 Dick Terrell Brown, Esquire 800 Milam Building 78205 San Antonio, Texas Robert E. Cohn, Esquire Richard J. Leidl, Esquire Butler, Binion, Rice, Cook
& Knapp 1747 Pennsylvania Avenue, N. W.
Ninth Floor Washington, DC 20006 Stephen H. Lewis, Esquire S. Nuclear Regulatory Commission U.Office of the Executive Legal Director Washington, DC 20555 Robert A. O'Ncill, Esquire Miller, Balis & O'Neil, P.C.
776 Executive Building
- h. h, 'g 1030 Fifteenth' Street, N.W.
Washington, D.C.
20005
/
Peter G. Flynn i