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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20203B9761998-02-23023 February 1998 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Requires That Mcgriff Be Prohibited from Any Involvement in NRC-licensed Activities for Period of 3 Yrs from Date of Dismissal from SNC on 970305 HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20132A9171996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Stds Format & Content for Applications to Renew NPP Ols ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116D6491996-07-31031 July 1996 Exemption from Requirements of 10CFR70.24 Re Criticality Monitoring Requirements ML20116G9271996-07-29029 July 1996 Comment Supporting Proposed Rule 10CFR26 Re Mods to Fitness-For-Duty Program Requirements ML20115D1911996-07-0505 July 1996 Comment on Final Rule 10CFR51 Re Environ Review for Renewal of Nuclear Power Plant Operating License.Supports NEI Comments ML20115H1951996-07-0303 July 1996 Comment Supporting Proposed Rule 10CFR50, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment ML20113C6691996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20100D1871996-01-29029 January 1996 Comment Opposing Petition for Rulemaking PRM-50-63, Recommending That Planning Std for Protective Actions for General Public Include Stockpile or Predistribution of Ki for Prophylactic Use ML20095D9801995-12-0808 December 1995 Comments on Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks ML20094M9691995-11-13013 November 1995 Comment on Proposed Rules 10CFR60,72,73 & 75, Safeguards for Spent Nuclear Fuel or High-Level Radioactive Waste ML20091Q2711995-08-28028 August 1995 Comment Opposing Review of Revised NRC SALP ML20086N6141995-07-10010 July 1995 Comment on Proposed Generic communication;10CFR50.54(p), Process for Changes to Security Plans W/O Prior NRC Approval. Endorses NEI Comments ML20086M8011995-06-28028 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Util Applauds NRC for Undertaking Endeavor to Make Insp Rept More Effective Tool for Communicating W/Licensees & Public ML20083N4921995-05-0404 May 1995 Comment on Proposed Rule 10CFR50, Primary Reactor Containment Leakage Testing for Water-Cooled Power. Util in Total Agreement W/Nei Comments ML20082K0461995-04-10010 April 1995 Comment on Draft Policy Statement, Freedom of Employees to Raise Safety Concerns W/O Fear of Retaliation. Endorses NEI Comments ML20078J8101995-02-0303 February 1995 Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors ML20080G8471995-02-0101 February 1995 Comment on Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees.Recommends That New Definitions Be Applicable & Consistent to Licensees Who Hold Other Licenses as Well as Part 50 License ML20085E5381995-01-0505 January 1995 Comment on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control. Supports NEI Comments ML20077F6561994-12-0101 December 1994 Comment on Proposed Generic Ltr Re Reconsideration of NPP Security Requirements for Internal Threat.Util in Total Agreement W/Nei Comments ML20077E9171994-12-0101 December 1994 Comments on Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal,Proposed Revs.Informs That Util in Total Agreement W/Nei Comments to Be Provided to NRC ML20072T6651994-09-0202 September 1994 Comment on Supplemental Proposed Rule 10CFR51 Re Environ Review for Renewal of Operating Licenses.Util in Agreement W/Nei Comments to Be Provided to NRC ML20072K3331994-08-17017 August 1994 Comment Supporting Petition for Rulemaking PRM-9-2 Re Ohio Citizens for Responsible Energy,Inc Petition ML20072B3711994-08-0909 August 1994 Comments on Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee in Total Agreement W/Nei Comments ML20071H1321994-06-27027 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Virginia Power;Filing of Petition for Rulemaking ML20069J5901994-06-0909 June 1994 Comment Supporting Proposed Rule 10CFR170 & 171 Re Rev of Fee schedules;100% Fee recovery,FY94 ML20065P4631994-04-25025 April 1994 Comment Supporting Proposed Rule 10CFR50 Re Codes & Stds for Npps;Subsections IWE & Iwl ML20065P4541994-04-0505 April 1994 Comments on Draft NUREG-1022,Rev 1, Event Reporting Sys (10CFR50.72 & 50.73) Clarification of NRC Sys & Guidelines for Reporting. Util in Total Agreement W/Nei Comments ML20064L8671994-03-11011 March 1994 Comment Supporting Proposed Amends to 10CFR20 Re Radiological Criteria for Decommissioning of NRC Licensed Facilities 1999-06-28
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20096D0201992-05-0707 May 1992 List of Exhibits to Alabama Power Co Surrebuttal Testimony.* Lists Exhibits for Use in Util Testimony.W/Certificate of Svc.Related Correspondence ML20090F4591992-03-0505 March 1992 Rept of Util on Level of Silicone Oil in Gems Level Transmitters & Grease Used in Fan Motors on 851130.* Util Has Reasonable Assurance That as of 851130,premium RB Grease Being Used in Motors at Issue in Enforcement Action ML20066A3921990-12-19019 December 1990 Notice of Appearance.* Notifies That Author Enters Appearance in Proceeding on Behalf of Licensee.Notices of Appearances for DA Repka & Ns Reynolds & Certificate of Svc Encl ML20248D2401989-09-27027 September 1989 Second Joint Status Rept.* Discovery in Proceeding Commenced W/Each Party in Proceeding Responding to Initial Request for Production of Documents & Four Preliminary Depositions Taken by Licensee During Wks of 890904 & 11.W/Certificate of Sv ML20246J7881989-08-28028 August 1989 Joint Status Rept & Stipulation.* Advises That NRC Depositions of Witnesses Other than Staff Consultant Scheduled for 890906-08 & Licensee Depositions Scheduled for Middle of Oct.W/Certificate of Svc ML20247E0251989-07-20020 July 1989 Notice of Appearance.* Advises That Author Will Enter Appearance in Proceeding on Behalf of Licensee.W/Certificate of Svc ML20247Q5511989-07-20020 July 1989 Notice of Appearance.* Advises That Author Will Enter Appearance in Proceeding on Behalf of Licensee.W/Certificate of Svc ML20247B7871989-07-11011 July 1989 Notice of Appearance.* Advises That Author Enters Appearance in Proceeding.W/Certificate of Svc ML20247B7951989-07-11011 July 1989 Notice of Appearance.* Advises of Author Appearance in in Proceeding.W/Certificate of Svc ML20245J4061989-06-22022 June 1989 Notice.* Notifies of 890621 Prehearing Conference in Birmingham,Al.W/Certificate of Svc.Served on 890623 ML20245A6711989-06-14014 June 1989 Establishment of Aslb.* Board Will Consist of Jh Frye, Chairman & Jh Carpenter & Wh Jordan,Members.W/Certificate of Svc.Served on 890619 ML20244B6761989-06-0101 June 1989 Requests Enforcement Hearing on Issues Raised by NRC 890328 Order Imposing Civil Monetary Penalty in Amount of $75,000 Re Inoperability of Train a ECCS Subsystem Charging Pumps on 880226 ML20211C2211986-10-17017 October 1986 Reply Opposing Alabama Power Co 860827 Response to 860616 Notice of Violation of Antitrust License Condition.Further Enforcement Action by NRC Required ML20199B3691986-06-16016 June 1986 Notice of Violation of Antitrust License Condition 2,by Setting Unreasonable Terms & Conditions for Sale of Facility,Per Alabama Electric Cooperative,Inc 840629 Petition ML20093H5741984-10-15015 October 1984 Memorandum Opposing Alabama Electric Cooperative,Inc 840629 Request for Enforcement Action ML20093H9371984-07-24024 July 1984 Reply to Alabama Electric Cooperative,Inc 840718 & DOJ 840720 Responses to Commission 840709 Order.Certificate of Svc Encl ML20093H6321984-07-20020 July 1984 Response to Commission 840709 Order Re Alabama Power Co Petition for Declaratory Order.Commission Should Deny Petition & Proceed on Alabama Electric Co Request for Enforcement Action.Certificate of Svc Encl ML20092N8761984-07-0303 July 1984 Petition for Declaratory Order Clarifying Util Obligations Under Antitrust Condition 2.F.(2) Contained in Licenses NPF-2 & NPF-8.Notice of Appearance & Certificate of Svc Encl ML20065J7241982-10-0101 October 1982 Notifies of Debevoise & Plimpton Change of Address as of 821001.Affirmation of Svc Encl 1992-05-07
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION U 00cYhD Before the Commission Y 24
) '59 In the Matter of $.$' ,
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ALABAMA POWER COMPANY ) Operating'L'icenses
) Nos. NPF-2 and (Joseph M. Farley Nuclear ) NPF-8 Plant, Units 1 & 2) ) cm - - -
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So-34r A RESPONSE OF DEPARTMENT OF JUSTICE TO ORDER CONCERNING PETITION OF ALABAMA POWER COMPANY FOR A DECLARATORY ORDER Pursuant to Subpart G of Part 2 of the Nuclear Regulatory i
Commission (NRC) Rules of Practice for Domestic Licensing Proceedings, 10 C.F.R. 5 2.700, and the Commission's July 9, 1984, order requesting the views of interested parties, the Department of Justice files this response stating its views on the choice of procedures to follow in resolving a dispute created by two conflicting filings in the subject proceeding.
On June 29, 1984, Alabama Electric Cooperative, Inc. (AEC) filed a request under 10 C.F.R. S 2.206, to enforce an antitrust license condition requiring Alabama Power Company (APCO) to sell ownership in the two Parley Units to AEC. AEC alleges that APCO has violated the license condition by negotiating in bad faith and by trying to impose extraordinary and unreasonable cost burdens on AEC. On July 3, 1984, APCO 8407250214 840720 PDR ADOCK 05000348 M PDR l 3 S03
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sent to each Commissioner a " petition for a declaratory order,"
that set forth its version of the negotiations. APCO's petition, acknowledging the existence of the AEC request for enforcement action, seeks to have the Commission hold AEC's request in abeyance while proceeding with the declaratory order procedure outlined in APCO's petition. The Commission, faced with these two conflicting filings, is seeking views on the appropriate procedure to follow. The Department recommends that the NRC deny APCO's " petition" and proceed on AEC's properly filed request for an enforcement action.
The Department's interest in this matter is that of a statutory party. The Department has participated in all antitrust proceedings involving the Parley Units both at the NRC and the subsequent appeals. 1/ In those proceedings, the form of access to the Farley units was probably the single most important issue. The Department took the position that APCO's continued refusal to grant reasonable ownership access to AEC was inconsistent with the antitrust laws. We actively sought, at the initial hearing and through the appellate process, the license condition that AEC now seeks to have enforced.
1/ The Department has not, however, participated in any of the negotiations between AEC and APCO to implement the license conditions.
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y - . . . _ _ _ , . _ _ _ . _ _ . . . _ - _ . . . .
t Subpart B of Part 2 of the Rules of Practice, 10 C.F.R. 5 2.200 et, seq., sets forth the procedures for seeking enforcement.of license conditions. 2/ Section 2.206(a) allows any person to " file a request . . . to institute a proceeding pursuant to S 2.202 to modify, suspend or revoke a license, or such other action as may be proper. . . . The requests shall specify the action requested and set forth the facts that constitute the basis for the request." Section 2.206(b) provides that "Within a reasonable time after a request pursuant to paraaraph (a) of this section has been received, the . . . Director, Office of Inspection and Enforcement, . . .
shall either institute the requested proceeding in accordance with this.subpart [i.e., S 2.200 et. seq.] or shall advise the person who made the request in writing that no proceeding will be instituted in whole or in part, with respect to his request, and.the reasons therefor."
AEC has' filed its enforcement petition pursuant to S 2.206
! alleging that APCO (the licensee) has violated a specific applicable license condition. It appears to the Department I
! that the NRC must, under the above-stated Rules of Practice,
(
2/- Appendix C to Part 2, the General Policy and Procedure for l
NRC Enforcement Actions, does not contain any specific guidance for enforcement of' antitrust license conditions. Appendix C simply states that Antitrust enforcement matters will be dealt with on a " case-by-case basis". (Footnote 1).
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review the merits of and take action on AEC's petition. In the absence of any allegation that the AEC request for an enforcement proceeding was made in bad faith--and none has been made--the NRC should investigate the allegations that AEC has raised and notify the licensee of its finding. The licensee is afforded an opportunity to reply, and may request a hearing.
Indeed, Section 2.202. requires a hearing only if the licensee requests one.
APCO, with its petition, seeks to avoid the procedures (and :
possible sanctions) in subpart B by establishing a completely different procedure--one not found in the NRC's Rules of Practice. APCO's suggested approach is that it, AEC, other interested parties, and the NRC staff submit memoranda to a special master to be appointed by the Commission, who will review the memoranda, conduct any further investigation and
" create-a record." The special master would then submit to the commission a "repor. --something short of an " initial decision," in that it~would not " recommend policy," thereby enabling the commission to " reach the policy questions efficiently." APCO. Petition at 10 n.6.- In turn, the Commission would then issue a declaratory order " interpreting" 1
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the license condition. 3/
APCO's justifications for its proposed departure from the established dispute resolution mechanism do not withstand scrutiny. APCO's estimate that an enforcement proceeding would take 5 to 110 years to complete appears grossly inflated. The
- issues are sufficiently defined and the facts relating to the positions that AEC and APCO have taken in negotiations are reasonably easy to establish. An evidentary hearing, should APCO request one, should not take more than a few days. APCO need only show that its offers were reasonable and consistent with the license condition. AEC, on the other hand, is entitled to an. opportunity to cross-examine APCO witnesses and
> put in its own evidence.
3/ It should be noted that conditions dealing with the
- ownership issue in numerous other nuclear plant licenses have used language similar to that used by the Appeals Board in this proceeding. See e.g., Toledo Edison Company and the Cleveland Electric Illuminating Company, (Davis-Besse Nuclear Power
, Station, Units 1, 2 and 3) 10 NRC 265, 408 (1979). Also, as AEC points out in its request, the Appeals Board gave specific guidance in its opinion as to why and how the APCO ownership condition should be applied. APCO, on the other hand, points to no specific ambiguity in the license condition requiring interpretation, thereby undermining its proferred rationale for Indeed, APCO's proposed declaratory order does
! this approach.
I not purport to explain or interpret the license condition; it merely seeks the NRC's endorsement of its conclusion that APCO's offer to AEC does not violate the license condition or, alternatively, the NRC's " guidance" on what APCO is required to l do to comply with the license--the exact issue properly raised by AEC in its enforcement petition.
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By contrast, APCO proposes that the various parties file essentially self-serving " memoranda," without any party being able effectively to cross-examine or rebut statements in others' memoranda. Just how such an approach can create a complete and reliable record as the factual predicate for the conclusory order APCO seeks from the Commission is nowhere explained. This deficiency is all the more problematical, i given that there is an issue of good faith involved. That issue cannot be properly resolved in the absence of a hearing.
Indeed, if APCO's novel approach is adopted, the Commission is likely to find at some point well into the future--after struggling to resolve the many uncertainties likely to be encountered by deviating from familiar and accepted procedures--that.it has no basis upon which to make an informed decision.
In summary, APCO's assertions that a declaratory order will save time are illusory'at best. More likely, its novel I
procedure will delay an informed resolution of this dispute.
The relief sought by both sides makes clear that_there is
{ nothing to be resolved that cannot be dealt with in an enforcecent proceeding--the traditional, familiar and most l
suitable means to resolve disputes of this sort. APCO has totally failed to justify a departure from established procedure, and its petition should be denied, i
l
D' Respectfully Submitted,
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Charles F. Rule M ie Ste Wrt Cutler Acting Assistant Attorney Chi , Energy Section General Antitrust Division Antitrust Division David W. Brown
- Assistant Chief, Energy Section Antitrust Division D-John D. Whitler Attorney, Energy Section Antitrust Division Washington, D.C.
July 20, 1984 i
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CERTIFICATE OF SERVICE I hereby certify that copies of the attached RESPONSE OF DEPARTM"NT OF JUSTICE TO ORDER CONCERNING PETITION OF ALABAMA POWER COMPANY FOR A DECLARATORY ORDER have been served on the following by United States Mail, postage prepaid, this 20th day of July, 1984.
~ Docketing and Service Section
' Office of the Secretary U.S. Nuclear Regulatory Commission lith Floor 1717 H Street, N.W.
Washington, D.C. 20555 t Frederick M. Bernthal, Commissioner U.'S. Nuclear Regulatory Commission 1717 H Street, N.W.
Room H-ll56 Washington, D.C. 20555 .
James K. Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Room H-ll36 Washington, D.C. 20555 Thomas M. Roberts, Commissioner
'U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Room H-1103 s Washington, D.C. 20555 :
Nunzio J.-Palladino, Commissioner U.S. Nuclear' Regulatory Cormission 1717 H Street, N.W.
Room H-lll4 Washington, D.C. 20555 William J. Dircks Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herzel H.E. Plaine, Esquire
-General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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l Guy H. Cunningham III, Esquire Office of Executive Legal Director U.S. Nuclear' Regulatory Commission Washington, D.C. 20555 Martin G. Malsch, Esquire Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Joseph Rutberg, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Benjamin H. Vogler, Esquire Deputy Antitrust Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- S. Eason Balch, Esquire Robert A. Buettner, Esquire Balch, Bingham, Baker, Wood, O Smith, Bowman & Thagard P.O. Box 306 -
Birmingham, Alabama 35201.
Harold F. Reis, Esquire Holly N. Lindeman, Esquire .
J.A. Bouknight, Jr., Esquire Newman &'Holtzinger, P.C.
1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 D. Biard MacGuineas, Esquire Volpe, Boskey and Lyons 918 - 16th Street, N.W.
Washington, D.C. 20006
-Charles R. Lowman General Manager Alabama Electric Cooperative, Inc.
P.O. Box 550 Andalusia, Alabama 36420 D.h h John D. Whitler Attorney, Energy Section Antitrust Division U.S. Department of Justice (202)724-6616
-9_