ML20091J215
| ML20091J215 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/01/1984 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | |
| References | |
| OL-2, NUDOCS 8406050435 | |
| Download: ML20091J215 (20) | |
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JDWWTE4 1984 UNC
'84 JUN -4 P2:16 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In tne Matter of )
)
TEXAS UTILITIES GENERATING )
COMPANY, et al. ) Docket Nos. 50-445-2
) and 50-446-2 (Comancne Peak Steam Electric )
Station, Units 1 and 2) )
CASE'S PROPOSED SCHEDULE AND PROCEDURES FOR RESOLUTION OF HARASSMENT AND INTIMIDATION ISSUES Tne following proposal for the conduct and scheduling of the hearings on harassment and intimidation is suomitted at the request of the Atomic Safety and Licensino Board (" Board").
CASE's proposal, if accepted, would (1) most ef fectively utilize the valuaole time availaole for the development of a complete and accurate record on enis issue; (2) insure that the oral hearing was devold of extended, repetitive or meaningless cross- '
examination of numerous witnesses; and (3) realistically e rovide for the " human factor" in this tasue which differentiates allegations of harassment and intimidation and its effects from specific technical or engineering allegations and their resolutions.
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2-BACKGROUND:
Pending uefore this Board are a series of motions oy
. Applicant regarding the seneduling, scope, cut-off date, and some discovery matters on the issue of harassment and intimidation.
During a conference call on May 24, 1984, the Board estaolished a schedule for CASE's counsel to respond to these matters. This is
.tne first of three pleadings which will address (1) scheduling and procedural matters; (2) the use of confidential information; and (3) the proposed scope of the harassment and intimidation issue. Tne second and third pleadings will oe filed June 5 and June 12, respectively. (CASE, Applicant and Staff are also actively engaged in discovery on this matter through ooth document requests and interrogatories.)
Tnis Motion specifically addresses the following f rom Applicant's M ay 8, 1984 Suomission of Af fidavit Regarding Fuel Loading for Unit One and other motions: Item III -- Applicant's Motion For Revision of Hearing Schedule, pp. 3-6; and Item IV --
Applicant's Motion for Adoption of Special Procedures regarding A " Cross-Examination Plans," B "Use of Documents In Cross-Examination, " and E "Close of Discovery."1 It also addresses Applicant's May 18, 1984 Proposed Schedule for Litigation-of Remaining Issues and Filing of Proposed Findings.
1 It does not address Item C - " Cross-Examination Limits" as a result of the comment made oy Applicant's counsel during the May 24, 1984 conference call, supra, that such time _ limits would 'not ce necessary_since CASE now nas counsel, or D -- " Board Cross-Examination of Witnesses" oecause that is most appropriately addressed oy._the Board. CASE has no oojection to the Board asking any questions at any time in this proceeding out does favor as much advance notice as possiole from the Board. '
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. PROPOSAL:
CASE suomits that the record on the narassment and intimidation issue can oe suostantially developed through an expansion of the use of depositions, including cross-examination during depositions, in lieu of the oral hearings. Further, that
'for reasons set forth in this motion the proposed schedule and procedures will enaole the Board to have all of the relevant facts and arguments oefore it soon after the conclusion of the discovery and depoG1 tion phase. The oral hearings will oe limited to only those matters which, for reasons of excusaole neglect (i.e., newly discovered information) were excluded f rom the depositions the parties wish to present, or for purposes of estaolishing credlollity, or for those witnesses or matters.which the Board indicates it wants to pursue.
If the procedures and schedule are adopted and implemented all parties should know all of the f acts regarding each witness and all relative incidents at the ' conclusion of the taking of depositions.2 The parties would then file proposed findings of fact, wnich would include as exhioits the-relevant portions of depos itions . and those documents which support each party's case.
Tne proposed findings would also indicate what matters remained to_ oe proven or disproven at oral hearing, and how each party was
' prepared to demonstrate that.
CASE oelieves that the time for surprise is over. Our l proposal is consistent 'w ith the admonisnments of the Board to the 2 ~
The success of this procedure, as well as the aoility of the parties to adhere.to:the proposal' schedule, is ooviously
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dependent upon the full cooperation of.the parties through exchange of document discovery and interrogatories.
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l parties to resolve as many of the issues as practicaole through a settlement or oriefing process.3 Finally, CASE's proposal and schedule is consistent with the desires of all of the parties to avoid tnis pnase of tne nearing oecoming an evidentiary circus.4 CASE proposes a three-step process, as follows:
Step One: Completion of Discovery (Documents and Interrogatories)
All parties, including the Staff, would expeditiously exchange all relevant documentation and answer all outstanding interrogatories not later than June 15, 1984.5 Specifically, as was informally discussed oetween the parties at the May 30, 1984 meeting (supra), CASE will proceed in the following manner. On Friday, June 1 the Applicant will De provided -- oy telephone --
3 Most recently, during a conference call on May 24, 1984, the parties agreed to resolve the remaining issues on design questions through a oriefing process, as opposed to the hearing process. The Board stated its agreement with this process.
4 The Staf f, Applicant and CASE met on May 30, 1984 to discuss seneduling and procedural matters. The parties did not reach any agreement. Tnroughout this motion CASE will identify the oojections of the Applicant as expressed to us and CASE's response to those oojections.
5 Current outstanding discovery ' requests are Applicant's Eignth Set of Interrogatories and Requests for Production of Documents, 4/9/84, and Questions 1-13 of Applicant's Ninth Set of Interrogatories to CASE and Requests to Produce, 4/16/84. Also outstanding on-this issue are CASE's Seventeenth and Eighteenth Sets of Interrogatories, . dated M aren 12, 1984 and March 14, 1984, respectively, and several- questions f rom CASE's Nineteenth Set, dated March 14, 1984, and Twentieth Set, dated March 15, 1984.
L _ As a result of current discovery exchanges we request the Board to hold CASE's Motion to Compel in aceyance. Such a
, . hearing will oe requested if informal exchange fails. CASE also l
expects the Staff to participate in discovery, either formally or informally, and is . pursuing this with the Staf f.
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w Ith a list of all persons known to CASE's counsel at this time who have knowledge of harassment and intimidation who might oe called as witnesses, and a list of all specific classes of documents it requests to oe searched or provided for documentary evidence responsive to CASE's interrogatories on this issue.
CASE will also informally notify the Staf f of the scope of discovery it requests of the Staf f telephonically on June 1.
That request will suosequently oe suomitted in writing on June 4.
On June 5 CASE will file its initial response to Applicant's ciscovery requests and interrogatories, and supplement that as soon as is possiole.
In order to move f rom the document and interrogatory stage of discovery into the taking of depositions of any witnesses, full discovery must have occurred. Any inadequate or incomplete responses will, of course, delay the proposed schedule oy an equal amount of time spent waiting for or disputing relevant material.6 6
If the Applicant persists in engaging in tne type of " cat and mouse" discovery game it has to date it will De impossiole for CASE to proceed on any reasonaole' schedule. For example, on Thursday May 31, 1984 M rs. Ellis, President of CASE, was informed that an August 19, 1983 report entitled " Cover Up and Intimidation oy TUGCO, Dallas Quality Assurance" and some related cocuments were ceing provided to CASE in response to their discovery request. This was the day af ter an informal meeting oetween the parties at which counsel represented that a one-inch stack of documents provided to CASE May 25, 1984 was all Applicant oelieved was relevant to the requests articulated in Interrogatories -17 and 18 regarding information Applicant has on harassment and intimidation at Comanche Peak. Nothing could De more relevant to this issue, or more specifically identified as responsive.- Continued failure to produce such relevant material (under the guise of a question of relevancy) guarantees this nearing will oecome protracted, exceedingly -expensive, and
. unnecessarily . adversarial.
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. Step Two: Witnesses and the Deposition Process Not later than June 15 the Applicant will oe provided with an updated list of those persons CASE may call as witnesses on this matter. (A preliminary list of all persons known to CASE who may have information relevant to harassment and in tim idation will oe provided to the Applicant on Monday, June 4, 1984.) CASE proposes that commencing on June 26, 1984, running four days a week (Tuesday-Friday, excluding the week of July 4), and continuing until the completion of the deposition process the parties would engage in open depositions of proposed witnesses in the following order: Applicant's witnesses, Staff witnesses, CASE w itnesses.
These depositions will contain ooth direct and cross-examination, as appropriate, and incorporate the documentary evidence avallaole to the parties regarding each witness.O 7
Counsel for CASE has a prior and unavoidaole ousiness commitment for the week of July 23. Should depositions continue that long, the week of July 23 would not ce availaole.
O When CASE oroached the essence of this proposal during the informal scheduling meeting, supra, the Applicant indicated his oojection cased on his desire to immediately oegin taking the
' depositions of anyone availaole. We attempted to explain, and reiterate here why that is inappropriate in these circumstances.
l First, our .wltnesses are all lay presons who have virtually no previous experience with the litigation process. Each witness must have the Denefit of meeting and working with CASE's counsel, and equally CASE's counsel must have the opportunity of hearing first-hand the information and experiences of each witness prior to the exposure of the witness to the deposition process. This will ce particularly true under the proposed procedures in which j witnesses will f ace cross-examination oy Applicant and ;
questioning oy the Staff. With the very real possiollity that !
CASE will oe providing oetween forty and fif ty witnesses the preparation time for the oulk of these witnesses is an enormous
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Before tnat task ~can oegin however it will oe necessary for CASE to nave all of the documents of the S taf f and the Applicant aoout wnat these witnesses have said, or nas oeen said or decided aoout them. The Applicant also legitimately needs for CASE to produce all relevant documentation that it has, and that search is in process; finally, CASE's counsel must himself oecome f amiliar witn the voluminous amount of material in this case on tnis issue prior to the oeginning of the critical deposition pnase. Thus CASE proposes the depositions oegin as soon as possiole, out that it properly oegin with Applicant's witnesses wno can oe deposed during the day while CASE. simultaneously prepares CASE . witnesses during the hours not filled with the actual taking of depositions.
Second, since CASE is proposing a procedure wnich in effect makes the deposition the equivalent of a nearing, it is appropriate that' Applicant proceed first. Harassment and intimidation is an accepted contention in this proceeding, the ourden of proof on this matter, as in technical matters, is on the Applicant.
Because tne ultimate ourden of persuasion rests with Applicant and witn the NRC Staf f to the extent the Staf f supports the Applicant's position, it is accepted practice that these parties proceed first. Philadelpnia Electric Company, et al. (Peach Bottom Atomic Power- Station, Units 2 and 3), ALAB-566, 10 NRC 527, 529 (1979).
Finally, oecause Applicant's witnesses could oe excluded f rom the hearing room at the request of CASE under the provisions of Rule 615 of the Federal Rules of Civil Procedure, having tnelt depositions first essentially achieves the same oojective. Rule 615 provides:
At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion.
Tnis rule does not authorize exclusion of (1) a party who is a natural person, or (2) an officer or employee of a party which is not a natural person designated as its representative oy its attorney, or (3) a person whose presence is known oy. a party to De essential to the presentation of his cause.
Tne purpose for invoking the rule, as explained in 6 Wigmore S 1837-1838 and cited in the Notes of Advisory Committee on Proposed Rules is to exclude or sequester witnesses "as a means c of discouraging and exposing f aorication, inaccuracy and collusion." Such a request was accepted on a Motion For Reconsideration of Intervenor Palmetto Alliance in the Catawoa
8-Step Three: Pre-hearing Filings Two weeks af ter the completion of the deposition process each party will file, simultaneously, the following documents:
(1) Proposed findings of fact in which the parties will present their respective affirmative cases, including all exhioits and portions of depositions relied upon and also identifying any gaps in the record which the parties propose to fill in the suoseguent hearing process and how they will attempt to do that; (2) Motions for summary judgment; (3) All exhioits (documentary) which the parties intend to rely upon or use in any way during the nearing;9 (4) Pre-filed testimony for any relevant matters which develop suoseguent to the deposition process or that was not covered oy either party for excusaole neglect. (CASE invites the Board to instruct all parties to adhere to the expanded use of deposit 1<.n as a.suostitute for the hearing process, and upon Indication that any party fails to do so, require an explanation and then decide upon tne validity of that explanation oefore allowing the party to proceed with witnesses or cross-examination proceeding where the Quality Assurance manager was sequestered, and prevented rrom having either direct or transferred knowledge of the testimony of certain Quality Control inspectors who testified aoout harassment and intimidation and its effects on the Catawoa construction site. Order of the Board on Palmetto's Motion for Reconsideration, 13 Octooer 1983, Duke Power Company, et al. (Catawoa Nuclear Station, Units 1 and 2).
9 r . CASE proposes that the parties stipulate that all documents produced in discovery are deemed to De genuine unless a specific oojection is filed as to a particular document and that the parties. provide-only enough copies for the court reporter, Board-memoers and other parties.
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during the nearing); (5) Cross-examination plans for all witnesses and all matters whlen any party intends to prone during the nearing itself with respect to those witnesses whose depositions nave oeen taken. j One week af ter tne suomittal of the aoove-listed items the parties would file cross-examination plans for any new matters or otner witnesses prof fered oy anotner party, as well as any cojections to opposing parties' witness list on the grounds of the offered testimony oeing repetitive of that offered in discovery.
One week af ter tne supplemental cross-examination plans and suomission of the completed witness list the Board would rule on the witnesses and the scope of their testimony and summary judgment motions.
Finally, the parties would have one final preparation week af ter the ruling of the Board on witnesses and matters to De presented in nearing.
Five weeks af ter -tne close of the deposition period the hearing into the issue of harassment and intimidation would commence and continue (4 day weeks, Tuesday-Friday) until completion.
I ARGUMENT CASE-oelieves that there are . numerous advantages to the adoption of these procedures, first and foremost it is efficient, second it is more likely to produce 1a oetter record, and third it is consistent with the desires of the Applicant and the S taf f to-l complete tne nearing' process fully utilizing all the time availaole.
l-.
. This is a proceeding in which numerous witnesses will oe
.giving their perception, understanding, or explanation of a ;
1 series of incidents which are collectively oeing referred to oy the parties and Board in this case as harassment and intimidation.10 By its nature this hearing is going to De quite different from the hearings on specific technical issues or the questions of aesign engineering or construction practices and procedures usually litigated in front of the Board. Most significantly there will oe conflicting testimony regarding oojective f acts and conflicting judgments regarding the implication of those f acts where tha judgments are cased more on human experience than technical experience.II It is also, oy definition, a " people" issue in wnich the Board must have availaole to it a suostantial amount of information regarding the experiences of numerous-workers and the explanation of those experiences oy Applicant.
The Board certainly can choose to hear each and every witness tell their story, and each party could decide to put on direct testimony of each and everi' witness. However, CASE oelieves that this is unnecessary and that the expanded use of depositions in this case is a logical alternative to a lengthy protracted 10 The definition of harassment and intimidation and the scope
> of that matter as it relates to the implementation of a 10 CFR 50 Appendix B and the ultimate reasonaole assurance that Comanche Peak -can operate without endangering the puolic health and safety will oe decided in the near future oy the Board, af ter a oriefing ,
on the suoject oy the-parties.
II These differences are apparently reflected in part in the different ooard used for this issue - one additional lawyer, one j
- less technical expert.
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evidentiary hearing.
CASE suomits tnat ef ficiency will oe increased Decause a deposition does not require attendance of the Board, eliminates argument over the form of questions and admissioility,13 increases the availaole information to parties and the Board oefore the hearing and provides a mechanism for ootaining cral testimony on this suoject that is ce superior to the hearing itself.
CASE oelieves tnat this is an issue which should first ce tried among the parties, organized oy the parties, and then orought to the Board in its entirety in the form of proposed findings of fact. The proposal of CASE is that the depositions
- suostitute for cross-examination -- leaving for the hearing only those matters of witness credioility or valid new relevant information not availaole during discovery, those contested facts which the parties concur should De developed through the open nearing, and any testimony the Board specifically requests ce neard live.
It will also reduce the amount of pure verniage placed into the record, and-narrow the amount of information the Board will 12 One oojection raised oy the Applicant during the informal meeting was that tne scope of the cross-examination during depositions could not ce limited as it could oe during the oral hearing process. CASE oelieves that this concern would De allayed oy.two significant factors. First, when the Board issues its definition of harassment and intimidation the scope of ooth direct and cross-examination will oe materially clarified.
Second, if the situation arises the Board can always ce called oy any party to rule on an oojection or a question of relevancy (CASE would encourage the Board to encourage the parties to let more, instead of less, information in the deposition record).
13 Suen oojections can ue raised at the time the deposition'is offered into evidence.
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I oe required to review. It is axiomatic that this type of proceeding will also reduce suostantially the resource intensive hearing days which are the most expensive for all parties, and insure that the amount of time spent in hearing will De as valuaole as possiole.
Further, CASE suomits that such proceedings would produce a more accurate record. We oelieve that " amateur" witnesses on this matter are less likely to oe inhioited and therefore to De more forthcoming in the atmosphere surrounding the taking of a deposition than in the more formal hearing.
Tne deposition pt) cess is a less complicated one, with a f ar less innlolting setting than the hearing process. CASE's witnesses will oy and large not ce professionals, out instead will oe a composite of construction, quality control, and administrative employees who have had experiences at Comanche Peak which evidence CASE's contention. CASE wants the Board to hear their stories, out it does not oelieve it is necessary or desiraole to h- e three or four dozen witnesses personally address the Board in order for the Board to assess the reality of the situation or the results.14 Clearly, where questions of credioility are at issue any party, or the Board, could and should request live testimony. We do not oelieve that will oe the case for the- majority of our witnesses.
~l4 Should the Applicant and/or Staff insist on having their witnesses appear at the hearing and should the Board agree to that, CASE, of' course, reserves the right to similarly oring all its witnesses to the hearing as well. What we are propos'ing is E '
that'in the interest of efficiency all parties agree to use-the deposition in lieu of the hearings procedure.
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, Finally, on the issue of timeliness, it is CASE's proposal that every reasonaoly availaole day oe used in a logical, ,
I intelligent order to oring aoout resolution of the harassment and i intimidation issue. First completing document discovery, then proceeding with the deposition of witnesses, and then fully utilizing ootn the documents and depositions to increase the quality and reduce the length of actual hearing days.
Should Applicant's resistance to CASE's proposal prevail, the scenario for resolution of this issue would oe suostantially different. Applicant would first notice CASE's witnesses for deposition, and CASE would then resist those notices until completion of full document discovery and an opportunity for counsel to review the documents and prepare each witness. The production of CASE's witnesses would undouotaoly oe complicated oy the short nctice and resultant scheduling proolems including many expensive flights to and f rom Fort Worth. In addition to the confusion that will surround the process is the reality that all the witnesses of all the parties are going to oe deposed oefore the hearing regardless of what procedures are followed.
The process of depositions will take just as long -- if not longer -- and the hearing will, as is traditionally the case, ce a rerun of the deposition' process, with'suf ficient modification to avoid oojections thus virtually doucling the total amount of time spent up to the completion of the hearing. Add to that the post-hearing time for proposed findings of f act and conclusions of law, and the suosequent review time for the Board and -it is
- apparent that. resolution of this phase of the hearing will not ce s
.. completed until late f all and procaoly not until early winter.15 The schedule we have proposed will accomplish more in less time out it~ is an optimistic and dif ficult one for us to meet.
We have proposed it oecause we oelieve that it will De advantageous with limited resources. Were we forced to use a j 'suostantially more resource intensive and expensive process as desired oy Applicant (i.e. taking depositions of CASE's witnesses at a prematurely early date and on a " catch as catch can" oasis) our aallity to meet that kind of tight time schedule would oe suostantially destroyed.
4 Thus what we of fer is a f air cargain that is ultimately
! oeneficial to the interests of all parties and the Board. We 15 CASE is legitimately concerned that the results of a positive presentation oy CASE will result in a second hearing
- oeing requested oy Applicant or scheduled oy the Board, and desires to avoid the possioility of relitigating issues it has prevailed on. .The process suggested here should eliminate that danger oy making the first hearing the only hearing on harassment and intimidation except for suoseguent hearings on the yet to oe completed analyses oy and any other similar reviews. See Lyron, infra.
16 Tne proposal offered oy CASE incorporates the very real resource restraints faced oy Intervenor and Intervenor's counsel.
There is_one volunteer lawyer and one volunteer law clerk
-handling this matter, ooth lawyer and law clerk have full-time responsioilities to other cases which -they have agreed to place
, ~"on hold", to the' extent that is possiole. The-organized approach of CASE to incorporate the deposition of Applicant's well prepared and well-counselled witnesses first, and at the same time - =in the evenings and on weekends - preparing CASE's witnesses would allow a concentrated use of time commencing at the. onset of the taking of depositions. Applicant's proposal, to proceed without organization, will require numerous -trips netween Washington, D.C. and the Dallas area, and disjointed efforts of w itness - p repa ration. Although CASE recognizes that funding assistance for intervenors is not possiole, the lack of funding should oe taken into consideration in decisions such as this so as not to oias Intervenor.
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oelieve our proposal is entirely consistent with the legitimate l Interests of timely and effective nearings. However, CASE wishes the record to oe clear aoout our position on the concerns of i timeliness. We reject categorically the notion that the issue of whetner Comanche Peak should oe allowed to operate can ce compromised oy a demand for early resolution to meet a mythical senedule.17 We oelieve it is Applicant's own f ailure to ensure that Comanche Peak was designed and constructed in accordance with the requirements of 10 C.F.R. 50 Appendix B which has resulted in the leng th of these hearings to date. (See, e.g., the Board's 12/29/84 Memorandum and Order (Regarding Quality Assurance in Design) in which the Board has already demonstrated its commitment to requiring a full hearing on the issues oefore it, including the incoporation of the results of the inspection or investigation currently underway oy the various oranches of the
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Staff and/or its consultants. The Atomic Safety and Licensing Appeals Board (" Appeals Board") has recently and significantly confirmed the oovious need to leave the hearing record open until undenlaoly relevant investigations, such as the ongoing OI investigations in this case, have Deen completed.10 To do less is 17 We oelieve " judicial notice" should oe taken of the fact that f rom " time immemorial" Applicants have Deen more efficient at-constructing artificially premature start-up dates than they nave oeen at constructing nuclear power plants. We urge the Board to not ce victimized oy Applicant's overly optimistic fuel load date.
10 In Byron the Licensing Board issued its initial decision
'without waiting for _ relevant ongoing inspections oy the Staff and Applicant 2nto the area of dispute to De completed. The Appeals' Board noted in footnote - 62 "In sum, it seems to us that the
to rely on the Staff's resolution of matters in litigation, which is not acceptaole.19 Thus our view on the issue of timeliness is not to finish tne hearing oy some aroitrary date, out rather to utilize all of the time availaole as efficiently and effectively as possiole.
4 CONCLUSION CASE suomits that our proposal for the expanded use of depositions and the adoption of the proposed procedures will result in an expedited, efficient hearing process, with minimum post-hearing time, and maximum utilization of the time and resources of all parties and the Board and will simultaneously increase the quality of the record on the issue of harassment and intimidation and its effects on the Comanche Peak site.
puolic' interest would oe ill-served were final judgment to.oe passed on the operating license application without a full evidentiary -consideration of the reinspection program and its results." This situation is parallel to the issue of harassment and intimidation, and the numerous ongoing investigations and inspections into this matter oy the Staff (and Applicant).
Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2), ALAB-770, NRC , Slip Opinion at 27-28 (May 7, 1984).
19 A Licensing Board may not delegate'its ooligation to decide issues'to the Staff. Cleveland Electric-Illuminating Co. (Perry Nuclear- Power. Plant, Units 1 & 2); P.S. Co. of I nd. (Marole Hill Nuclear Generating Station, Units 1 & 2), ALAB-4 61, 7 NRC 313, 318 (1978).
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For the aoove reasons, CASE requests the Board adopt the i'
. proceedings outlined on pages three to five of this Motion, t
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'ANTflONY Z . I MAN (
Trial Lawy r for Puolic Justice 2000 P .S t ee , N.W. , Suite 611 Washington, D.C. 20036 (202) 463-8600 ,
f Dated: June 1, 1984 e
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4 June 1, 1984
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
! BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD
'In the Matter of )
I TEXAS UTILITIES GENERATING ) ,
COMPANY, et al. ) Docket Nos. 50-445-2
) and 50-446-2 (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
4 CERTIFICATE OF SERVICE
' -By my signature celow, I hereoy certify that true and 3
correct ' copies of . CASE's Proposed Schedule And Procedures For Resolution Of Harassment And Intimidation Issues has oeen sent to the names listed Delow this 1st day of ' June, 1984, Dy: Express mail where indicated oy *; Hand-delivery where indicated oy **;
and First' Class Mail unless otherwise indicated.
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- Administrative Judge Peter B. Bloch U.S. ' Nuclear Regulatory Commission Atomic Safety :and Licensing . Board
_ Washington, D.C. 20555
- Heroert Grossman, Alternate Chairman.
- Atomic Safety and ' Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C., 20555 Dr. Kenneth A. McCollom, Dean Division of Engineering,' Architecture
- and Technology
, Oklahoma ' State University :
Stillwater,~ Oklahoma ~74074.
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Dr. Walter H. Jordan -
881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms.- Ellen Ginsoerg, Law Clerk Atomic Safety and Licensing Board l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 f
- Nicholas S. _ Reynolds, Esquire Bishop, Lioerman, Cook, Purcell
& Reynolds 1200 17 th S treet, N.W.
Washington, D.C.. 20036
- S tuart Treoy, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .
. Chairman Atomic Safety and Licensing Board-Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas' 78711 John Collins Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Docketing and Service Section (3 copies)
Office of the Secretary
. .U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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f Ms. Billie P. Garde
- Government AccountaDility Project 1901 Que Street, N.W. -
l Washington, D.C. 20009 Mrs. Juanita Ellis, President 1 CASE (Citizens Association for '
Sound Energy)
. 1426 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7 th , Suite 220 Austin, Texas 78701 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201
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/ Anthony Z R isman Trial L ers for Puolic Justice 2000 P< treet, N.W., Suite 611 Washington, D.C. 20036 (202) 463-8600 f
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