ML23025A361
| ML23025A361 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse, Perry, 07201043, 07200069 |
| Issue date: | 01/25/2023 |
| From: | Hamilton D Energy Harbor Nuclear Corp |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23025A360 | List: |
| References | |
| L-23-014 | |
| Download: ML23025A361 (1) | |
Text
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
Energy Harbor Nuclear Corp.
168 E. Market Street Akron, Ohio 44308 January 25, 2023 L-23-014 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Docket No. 72-1043 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Docket No. 72-14 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant, Unit No. 1 ISFSI Docket No. 72-69 Request for Threshold Determination Energy Harbor Nuclear Corp. (EHNC), acting on behalf of itself and Energy Harbor Nuclear Generation LLC (EHNG and, together with EHNC, the Licensees), requests a determination by the Nuclear Regulatory Commission (NRC) that an amendment to the voting agreement between its parent company, Energy Harbor Corp. (EHC), and one of its stockholders does not constitute a change of control requiring prior NRC consent pursuant to 10 CFR 50.80 or 10 CFR 72.50.
I.
BACKGROUND Since the Licensees and their ultimate parent, EHC, emerged from bankruptcy on February 27, 2020, EHC has been owned by the previous creditors of FirstEnergy Solutions Corporation (FES) and FES debtor-affiliates who converted their claims into David B. Hamilton Executive VP, COO, & CNO 330-436-1360
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 2 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
equity in EHC in the bankruptcy proceeding. Nuveen Asset Management, LLC (Nuveen), through funds it manages, is the largest holder of voting shares of EHC. Avenue Capital Management II, L.P. (Avenue), through funds it manages, is the second largest holder of voting shares of EHC.
Under its corporate formation documents, the Board of Directors (Board) of EHC (currently eight members) is selected pursuant to a Stockholders Agreement in place among EHC and its stockholders.1 Nuveen and Avenue have certain director designation rights under this agreement. In particular, so long as Nuveen and Avenue hold a minimum threshold of outstanding EHC stock, Nuveen has the authority to designate two directors and Avenue one director. Of the two directors Nuveen can designate, one of those directors must be independent of any stockholder with director nomination rights, including Nuveen.
II.
PRIOR THRESHOLD DETERMINATION On May 4, 2020, EHNC submitted a threshold determination request (2020 TD Request) asking the NRC to confirm that EHC implementing a stock repurchase plan did not constitute a change of control that required NRC consent under 10 CFR 50.80 and 10 CFR 72.50.2 EHNC explained that the stock repurchase plan was likely to lead to an increase in the percentage of stock ownership by some stockholders of EHC, including Nuveen and Avenue, because the repurchase by EHC would reduce the number of outstanding shares. However, EHNC explained that Nuveen and EHC had entered into a Voting Agreement that prevented Nuveen from exercising voting rights in excess of the percentage of equity ownership it held at the time the Voting Agreement was executed. Any ownership rights above this percentage would only be held beneficially (i.e., Nuveen would not be entitled to exercise voting rights in the percentage above this cap but would continue to enjoy all economic benefits associated 1
EHNC has previously provided a copy of the Stockholders Agreement. Letter from D. Benyak, EHNC, to NRC Document Control Desk, Response to Request for Additional Information Regarding an Application for Order Consenting to Transfer of Licenses and Conforming License Amendments (EPID-L-2019-LLM-0000) Attach. 4 (Aug. 2, 2019) (ML19214A100).
2 Letter from D. Benyak, EHNC, to NRC Document Control Desk, Request for Threshold Determination (May 4, 2020) (ML20125A346).
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 3 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
with its stock ownership). The Voting Agreement also prevented Nuveen from exercising any additional Board of Directors designation rights associated with any increase in the percentage of stock beyond its then-current holdings.
At the time the Voting Agreement was executed, Nuveen held 39% of the outstanding stock of EHC, while Avenue held 14% of the outstanding stock. Accordingly, under the terms of the Voting Agreement, Nuveen was restricted from exercising any Board appointment rights associated with its acquisition of ownership rights above 39%.3 EHNC thus concluded in the 2020 TD Request that, even if Nuveen increased its equity ownership above its then-current 39% equity ownership in EHC, it would not be able to exercise control over the Licensees in a manner that would require NRC consent under 10 CFR 50.80 and 10 CFR 72.50.4 On July 1, 2020, the NRC issued a threshold determination (2020 Threshold Determination) agreeing that, so long as the Voting Agreement remained in effect, Nuveen would not have control over the Licensees that would require NRC consent.5 Specifically, the NRC determined that even though Nuveen could acquire additional equity ownership, including in excess of 50%, pursuant to the Voting Agreement and Stockholders Agreement, [Nuveen] will not obtain any increased voting power or ability to designate more [EHC] directors than it currently has. Therefore, Nuveen cannot exert majority stockholder control over [EHC], even if it accrues beneficial ownership of a majority of outstanding shares.6 3
Nuveen has received authorization from the FERC to own up to 58% of outstanding EHC stock.
Energy Harbor LLC, 172 FERC ¶ 62,062 (2020).
4 The 2020 Threshold Determination described the Voting Agreement and the request for a threshold determination as applying only to an Initial Stage of a two part transaction. In the second stage, the Licensees would submit a license transfer application and await the NRCs consent before terminating the Voting Agreement and allowing Nuveen to exercise its full voting rights. 2020 TD Request at 5-6.
5 Letter from S. Wall, NRC, to D. Hamilton, EHNC, Energy Harbor Nuclear Corp. - Beaver Valley Power Station, Unit Nos. 1 and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 - Request for Threshold Determination under 10 CFR 50.80 and 10 CFR 72.50 for the Interim Stage of the Proposed Stock Buy-Back Transaction (July 1, 2020)
(ML20164A230).
6 Id., Encl. at 3 (emphasis added).
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 4 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
III.
BACKGROUND ON PROPOSED REVISED VOTING AGREEMENT As is discussed further below, EHC and Nuveen have executed an Amended &
Restated Voting Agreement (A&R Voting Agreement) that allows Nuveen to exercise its voting rights in stock it owns up to the lesser of: (i) Nuveens actual percentage of the voting power of the issued and outstanding shares of voting stock of EHC held in the aggregate by all stockholders of EHC at the applicable time (the Voting Power), and (ii) the lesser of Nuveens percentage of the Voting Power (A) authorized by the Federal Energy Regulatory Commission (the FERC) and (B) authorized by the NRC either in the 2020 Threshold Determination or any subsequent order or threshold determination by the NRC granting approval for Nuveen to exercise voting rights as a stockholder consistent with such order or threshold determination (any such order or threshold determination, an NRC Approval); in each case, determined as of the date of the exercise of such Voting Power. EHNC requests a threshold determination that Nuveen may exercise up to 49.99% of the Voting Power (the Voting Power Increase) and such Voting Power Increase does not constitute a change in control that requires NRC consent under 10 CFR 50.80 or 10 CFR 72.50.
Certain confidential commercial and financial information is included in Attachment 3 to this submittal. EHNC requests that Attachment 3 be withheld from public disclosure pursuant to 10 CFR 2.390 and 10 CFR 9.17. A redacted version of Attachment 3 is provided in the publicly available version of this request as Attachment 1. The redacted information is identified by brackets [ ]. An affidavit from Nuveen supporting the request for withholding the proprietary confidential commercial and financial information from public disclosure is provided in Attachment 2.
The financial and technical qualifications of the Licensees to own and operate the four above-referenced reactors and independent spent fuel storage installations (the facilities) will not be affected by the Voting Power Increase. There will be no physical changes to the facilities, no changes in their day-to-day operations, and no material changes to equipment operating procedures in connection with the Voting Power Increase. The facilities onsite organizations will remain unchanged by the Voting Power Increase, and the onsite organizational structure, including lines of authority and communication, will not be affected by the Voting Power Increase. There will also be no changes to the EHC corporate structure as a result of the Voting Power Increase.
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 5 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
A.
Current Ownership of EHC Stock Since the 2020 Threshold Determination, EHC has made purchases contemplated under its stock redemption program. In addition, Nuveen has acquired additional stock from other EHC stockholders such that Nuveens beneficial interest in EHC has increased from approximately 39% to approximately 46.03% as of December 31, 2022.
However, consistent with the Voting Agreement and the 2020 Threshold Determination, Nuveen is restricted to only voting approximately 39% of its interest in EHC, notwithstanding the increase in its stock ownership.
B.
Description of A&R Voting Agreement EHC and Nuveen have amended and restated the Voting Agreement to authorize Nuveen to be able to exercise additional Voting Power above the 39% authorized by the 2020 Threshold Determination, subject to NRC Approval. Under the terms of the A&R Voting Agreement, Nuveen is authorized to exercise its stockholder voting rights in up to the lesser of: (i) Nuveens actual Voting Power, and (ii) the lesser of Nuveens percentage of the Voting Power (A) authorized by the FERC and (B) authorized by the NRC either in the 2020 Threshold Determination or any subsequent NRC Approval; in each case, determined as of the date of the exercise of such Voting Power.
Accordingly, should the NRC provide the requested threshold determination, (i) Nuveens Voting Power would currently be equal to its actual Voting Power of approximately 46.03% and (ii) if Nuveens actual Voting Power were to exceed 49.99%,
Nuveens Voting Power would be capped at 49.99% by virtue of the NRCs threshold determination authorizing Nuveen to exercise Voting Power up to 49.99%.
In addition, the Stockholders Agreement continues to restrict Nuveen to designating no more than two members of the Board of Directors of EHC, with one of those directors required to be independent of any stockholder with director nomination rights, including Nuveen. In the event that Nuveen acquires additional EHC stock above the 49.99%
threshold, Nuveen will hold only a beneficial (i.e., economic non-controlling) interest in such additional ownership percentage until necessary regulatory approvals are acquired. As a result of the provisions in the A&R Voting Agreement, Nuveen will remain unable to exert majority stockholder control over EHC even if it accrues beneficial ownership of a majority of outstanding shares, and will remain unable to exert
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 6 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
control over the Board of Directors of EHC due to the restrictions in the Stockholders Agreement.
Therefore, although Nuveen could potentially increase its proportional beneficial ownership of the EHC stock above 50%, pursuant to the A&R Voting Agreement it will be restricted to voting only 49.99% of its interest in EHC if the NRC provides a threshold determination authorizing Nuveen to exercise up to 49.99% of the Voting Power.
IV.
REQUEST FOR THRESHOLD DETERMINATION The Licensees request a threshold determination confirming that the Voting Power Increase does not result in a change of control of the NRC licenses. This position aligns with NRC case law and precedent concerning similar transactions, including the 2020 Threshold Determination.
Under NRC case law, control of an NRC license is to be found in the person or persons who, because of ownership or authority explicitly delegated by the owners, possess the power to determine corporate policy and thus the direction of the activities under the license.7 Thus, control requires actual power to determine corporate policy and thus the direction of the activities, and when there is no change in power to direct corporate activities, there is no change in control.
In the case of a typical holder of stock such as Nuveen, control is primarily exercised in two ways: (1) by choosing the members of the Board of Directors (either through voting of stock or agreement between the stockholders), and (2) by voting stock for those actions that require stockholder vote.8 With the Voting Power Increase, the A&R Voting Agreement and Stockholders Agreement together essentially freeze Nuveens ability to vote its stock beyond 49.99% and select Board directors at current levels unless Nuveen wishes to exercise its rights beyond such 49.99% voting cap, in which case the Licensees would submit license transfer application and await NRC consent before Nuveens rights above 49.99% would be exercised. The NRC has recently affirmed that 7
Safety Light Corp. (Bloomsburg Site Decontamination), ALAB-931, 31 NRC 350, 367 (1990).
8 See South Texas Project Units 1 and 2, Request for Threshold Determination Under 10 CFR 50.80, NRC Safety Evaluation Report at 3 (Nov. 1, 2012) (Accession No. ML12297A134) (the NRC staff looking to majority control of stockholders and board members as key indicia of corporate control).
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 7 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
similar restrictions can effectively mitigate change of control concerns. In 2018, Westinghouse Electric Company, LLC (Westinghouse), operator of the Columbia nuclear fuel fabrication facility, and its parent companies, engaged in a two-stage transaction with Brookfield WEC Holdings LLC (Brookfield).9 The NRC found that the interim transaction in the Westinghouse example, in which stock transferred but was subject to strict voting restrictions, did not result in a change of control until those restrictions were removed. The NRC concluded that voting restrictions effectively prohibited Brookfield from exercising the control that it would otherwise have over Westinghouse.
In the Westinghouse example, Brookfield retained certain reserved rights to vote its acquired stock during the interim transaction, which were closely reviewed by the NRC.
Under the A&R Voting Agreement, Nuveens voting rights will similarly be restricted to ensure that it will not possess majority stockholder control.
The Westinghouse Threshold Determination itself builds on a history of NRC evaluations that have relied on voting restrictions on investors to limit control concerns.10 This precedent also aligns with determinations made by other regulatory agencies indicating that stockholders who cannot vote or otherwise use their stock to control company activities do not have control of the company.11 9
See Evaluation of and Threshold Determination on the Share Purchase Agreement Between Toshiba Corporation and Brookfield WEC Holdings LLC (Mar. 22, 2018) (Accession No. ML18073A224)
(Westinghouse Threshold Determination).
10 See, e.g., Comanche Peak Steam Electric Station, Units 1 and 2, Safety Evaluation Report Re:
Threshold Determination Concerning Convertible Notes and Stock Transactions, at pages 3 and 5 (Apr. 14, 2003) (Accession No. ML031040532) (Use of independent voting trusts effectively limited Credit Suisse control of stock it owned.); Review of Phase 2 of the Toshiba American Nuclear Energy Corporation and the Babcock & Wilcox Investment Company Investment In USEC Inc., at page 1 (Feb. 8, 2011) (Accession No. ML103630746) (The NRC determined that an ownership interest transfer in the sale of nonvoting preferred stock did not cause a change of control.).
11 See AES Creative Resources, L.P., et al., 129 FERC ¶ 61,239, at PP 24-25 (2009) (For securities to be voting securities they must give an investor actual authority to manage, direct, or control the activities of the company.); Federal Power Act Section 203 Supplemental Policy Statement, 72 Fed.
Reg. 42,277 (Aug. 2, 2007), FERC Stats. & Regs. ¶ 31,253, at P 54 (2007), order on clarification and denying reconsideration, 122 FERC ¶ 61,157 (2008) (Investments in public utilities that do not convey control may be considered to be passive investments not subject to the change of control restrictions of Section 203 of the Federal Power Act.).
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 8 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
The NRC also agreed in the 2020 Threshold Determination that similar restrictions in the original Voting Agreement did not constitute a change in control that required NRC consent.12 Similar to the 2020 TD Request, the A&R Voting Agreement will prevent Nuveen from exercising unilateral control over EHC and, accordingly, the Licensees.
As noted above in Section II, supra, the 2020 Threshold Determination described the Voting Agreement and 2020 TD Request as applying only to an Initial Stage of a two part transaction.13 The Licensees stated in the 2020 TD Request that, prior to engaging in the second, Final Stage of the transaction and terminating the Voting Agreement to allow Nuveen to exercise its full voting rights in accordance with its holdings (potentially up to 58% of outstanding EHC stock), they would submit a license transfer application and await the NRCs consent.14 EHC and Nuveen are not proposing with this submittal to allow Nuveen to exercise control over the Licensees. Rather, similar to the 2020 TD Request, the Licensees are only seeking a determination from the NRC that raising Nuveens allowed voting cap from approximately 39% up to as high as 49.99% of the Voting Power does not constitute a change in control that requires the NRCs consent.
For the reasons described in thisSection IV, Nuveen does not have control of EHC based on the A&R Voting Agreement and Stockholders Agreement because, even if it can exercise up to 49.99% of its voting rights, Nuveen still will not have the ability to control EHC or the Licensees. This is because a voting interest of 49.99% does not give Nuveen sufficient voting control and the Stockholders Agreement will continue to limit its ability to designate members of the EHC Board of Directors.
In conclusion, just as it did in the 2020 Threshold Determination, the NRC should find that the increase in the ability of Nuveen to exercise voting interests in EHC up to 49.99% continues to mean that Nuveen will not obtain any increased voting power or ability to designate more [EHC] directors than it currently has. Therefore, Nuveen cannot exert majority stockholder control over [EHC], even if it accrues beneficial ownership of a majority of outstanding shares.15 12 2020 Threshold Determination, Encl. at 3 (emphasis added).
13 See n., supra.
14 2020 TD Request at 5-6.
15 2020 Threshold Determination, Encl. at 3 (emphasis added).
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 9 V.
REQUEST AND REQUESTED REVIEW DATE The Licensees request confirmation that the exercise of Nuveen's rights under the A&R Voting Agreement, pursuant to which Nuveen would be allowed to vote up to 49.99% of the Voting Power of EHC if the NRC provides a threshold determination authorizing Nuveen to exercise up to 49.99% of the Voting Power, does not constitute a change of control of the licenses in view of the restrictions of the A&R Voting Agreement and the Stockholders Agreement, including, without limitation, Nuveen being restricted to appointing two directors, one of which must be independent.
The Licensees request completion of the NRC's review within 60 days from this filing. 16 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager -
Nuclear Licensing, at (330) 696-7208.
Sincerely, David B. Hamilton Attachments:
- 1. Redacted Amended and Restated Voting Agreement
- 3. Unredacted Amended and Restated Voting Agreement 16 FERC approval under Section 203 of the Federal Power Act is not required for the A&R Voting Agreement. of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station ISFSI Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station ISFSI Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant ISFSI L-23-014 Page 10 of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.
Upon removal of Attachment 3, this letter is decontrolled.
cc: NRC Region I Administrator (without Attachment 3)
NRC Region III Administrator (without Attachment 3)
NRC Project Manager - Energy Harbor Nuclear Corp. Fleet (without Attachment 3)
NRC Resident Inspector - Beaver Valley Power Station (without Attachment 3)
NRC Resident Inspector - Davis-Besse Nuclear Power Station (without Attachment 3)
NRC Resident Inspector - Perry Nuclear Power Plant (without Attachment 3)
Director BRP/DEP (without Attachment 3)
Site Representative BRP/DEP (without Attachment 3)
Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) (without Attachment 3)
Utility Radiological Safety Board (without Attachment 3)