ML20091L126
| ML20091L126 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/05/1984 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | |
| References | |
| NUDOCS 8406070342 | |
| Download: ML20091L126 (19) | |
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'I 00CMETED USNRC 1
UNITED STATES OF AMERICAC T,.p[
NUCLEAR REGULATORY COMMISSION ~ ' ' '
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s
In the Matter of
)
)
' TEXAS UTILITIES GENERATING
)
- Doc ket No s. 50-445-2 COMPANY, et al.
)
and 50-446-2
)
(Comanche Peak Steam Electric
)
Station, Units l' and 2)
)
CASE's Proposal Regarding The Use Of Cbnfidential Information The use of confidential information in this hearing has been j
a procedural thorn in the side of both the parties and the Board.
It is clear to CASE's counsel that each of the parties have struggled with the problem of how to balance the responsibility of continuing disclosure of relevant information required under j
10 C.F.R. 2.740(e), with commitments to those persons who provide such information in confidence (as protected by the j'
provisions o f 10 C.F.R. 2.740(2)(c )).
l Our proposal starts with a basic administrative due process i
premise upon which we believe all parties agree -- that the -
decision-maker should not rely in its evaluation process on any.
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information on which the parties have not h'ad an opportunity to present ' their respective cases.1 l
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' Applicants articulated in a May 10, 1984 Motion To Obtain Access To Information Regarding Investigations At Comanche Peak Or For Alternative Relief their concerns on the. matter of the i
Board's ex parte access to information from the Office of L
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' We believe that there is substantial merit to Applicants' concerns (Motion, supr a), and do not disagree with the initial response taken by the Board in its May 17, 1984 Order which prohibited the Office of Investigations from providing information to the Board "unless it provides all the same in formation, either publicly or subject to a protective order, to each of the parties to this case."
Although we agree in principle with the current posture of this procedure, we believe that some significant questions remain which must be confronted at the very onset of the harassment and intimidation proceeding.
Those questions are (1)
How do the parties balance their legitimate discovery needs and responsibilities with their need to be able to provide a promise of confidentiality to those persons who provide information, voluntarily or at the request of a party, about conditions or problems at the Comanche Peak construc tion site?
(2)
How does the Board deal with information, unknown to the parties, but deemed relevant to the proceeding by an office of the Commission?
Our proposal provides an approach to both of those dilemmas.
We recognito that an insoluable debate over a particular witness -
or incident may remain.
However, we believe that our proposal, if followed in good faith, will reduce those to the smallest possible number.
Investigations (OI) pursuant to the August 10, 1983 Statement o f Policy " Investigations and Adjudicatory Proceedings".
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4 PROPOSAL
- There is no argument with the requirement for a full
. administrative hearing on the harassament and intimidation
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issue.
Further, there is no acceptable argument for holding a hearing on 'any issue which does not address relevant information in the possession of any or all of the parties.
On this matter we strenuously object to the suggestions in Applicant's May 10, 1984 Motion (supra) which suggestad the exclusion of relevant information entirely.
(Mo tion, at 11).
In our opinion, all the parties and the. Board are on equal footing in this dilemma.
It is, ho wever, the ability of the Board to render an accurate and fair decision which should be'the a
greatest concern of the parties.
Our discussion of a proposal is premised on the belief that each party has relevant information, i
gleaned from persons who desire confidentiality for some reason unique to ;that individual, and that those persons do not wish to.
2 As the Commission. stated:
f We long ago reminded liensing boards of their duty not only j
to resolve contested. issues but to ' articulate in reasonable detail the basis for the course of action chosen.
[ citation omitted]
We, as well as the parties, should be
- able 'readily to. apprehend the foundation for the. [ Board's]
ruling' [ citation omitted].
For it. is a well-accepted principle of ' administrative law that 'the orderly functioning of.the process of review requires that the grounds upon which the administrative agency. acted be clearly disclosed and adequately sustained.'
[ citations omitted).1 A board must do more than reach conclusionst it must " ' confront the fac ts '.
[ citations omitted].
'P.S. Co.
of -N.H. (Seabrook Station, Units 1 &. 2), ALAB-422, 6 NRC 33, 41 (1977), affirmed, CLI-78-1, 7 NRC 1 (1978), affirmed sub nom. New England Coalition on Nuclear Pollution v. NRC, N#Y F.2d 87 (1st Cir. 1978 ).
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participate voluntarily in the hearing. process.
Those reasons, whether fear of further harassment and intimidation well-founded, a lack of sophistication about the litigation process, or con-cerns about the impact of testifying on their career, are signi-ficant factors to-each individual.
Those individual concerns cannot realistically be waived away by either counsel or the Board -in pursuit of the full disclosure obligation for the benefit of a full hearing record, when the cost could be the failure of the Applicants, Staff or some other. check and balance system set up to ensure a safe nuclear plant.
In fact, CASE is acutely aware that the inability of any or all parties to accept information, in confidence, about' the e
quality of construction or incidents of harassment and intimidation'could seriously impact the successful implementation o f any such program which attempts to open the door to the work 4
4 force about problems.
i Question 1 l
We propose the following in regards to discovery:
(1)
All parties make. a genuine effort to encourage any person who has relevant information to voluntarily participate in
.the hearing process, either publicly or _i_n, camera.3 n
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- We request that the Board consider the full use o f an Affidavit of Non-Disclosure (Attachment 1) by which the number of thosa individuals who have. knowledge of a confidential witness is limited to the minimum necessary for discovery purposes.
This l
procedure has baen used, apparently successfully, in both the Byron ar.d Catawba proceeding.
(We note that the number of utility employees in the Catawba proceeding who had signed the affidavit 'and therefore were privy to the identities and con-
.cerned the _i_n, camera witnesses exceeded 70, a number which n
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We acknowledge that the parties' attempts to convince all persons who have knowledge about harassment and intimidation will probably fail to secure 100% disclosure, for those remaining few witnesses we propose to deal with their information in the following manner:
(2)
All parties disclose to each other, through an informal process, those procedures used to determine what information is deemed " confidential," and upon what basis persons are granted
" con fiden tiality" ;
(3)
For each witness who refuses to participate in the hearing process, regardless o f the protec tions offered, the counsel should be required to submit an affidavit explaining what the prohibiting concerns of that witness are and to detail his attempts to persuade the witness to participate in this hearing.4 (4)
After a review of those procedures the parties should attempt to reach a stipulation through which the us,e of "confi-dentiality" (to protect the identities of certain persons) in the normal course of each other's business will be honored by each defeats the purpose of the affidavit.)
4 CASE is legitimately concerned that the process it proposes could be easily abused by any party who is not sincerely committed to the full disclosure of the incidents and evidence available to it regarding all aspects of harassment and intimidation.
As the Board and parties are acutely aware, the failure of the Staff to disclose information (names and sources who did not request confidentiality in the first place) under the guise of confidentiality is exactly the type of behavior which would undermine the implementation of this procedure to the point of making it a charade.
If similar conduct was employed CASE would urge the Board to take swift and immediate action to foreclo se such abuse.
par ty. 5 If the parties fail to reach a stipulation the proce-dures will be submitted to the Board with a request to establish an acceptable method of preserving the use of " confidentiality" by each party.
(5)
That all parties identify fully the substance of each witne ss' information in its entirety, exc ept for obviously identifying information; (6)
That a uniform coding system, following the lead of the NRC Staff's witness coding system, for confidential witnesses be developed and followed so that all parties and the Board have a clear understanding of how to address or discuss either _i_n, camera or confidential sources of information; and (7)
Any or all anonymous relevant information, where the identity of the source is unknown even to the party, be disclosed in its entirety.
Question 2 With regard to the information which is relevant to this proceeding but protected under the ambit of official ongoing NRC investigations (see, Statement of Policy, supra) we ask the Board to modify its May 17, 1984 Order in the following manner s (1)
Request that the Office of Investigations prepare a 5
It has become apparent through the discovery already engaged in that Applicant, as well as the NRC Staff, have a practice or procedure of protecting the identity of individuals who provide information to it.
Almost all of the documents received to date from Applicant are in an expurgated form -- removing names, dates, specific areas of problems, etc.
CASE's counsel has already asked for an explanation of the procedures employed by either the Applicant or his counsel in determining what informa-tion is disclosed and what is not.
1 l briefing for the Board and the parties (to be held n camera, but not ex parte) in which it identifies all ongoing investigations that are relevant to harassment and intimidation.6 (y,
acknowledge that in order to not compromise the investigation such a briefing may be, of necessity, somewhat shallow. )7 (2)
That such briefings should be held periodically throughout the course of this litigation with the scope of such briefings limited to an overview of any relevant information about incidents of harassment and intimidation.
Further, with regard to the issue of relevant information:
(3)
At the conclusion of any relevant investigations by any party the Board and the parties are immediately provided with copies of the investigation report or inspection.
(4)
If the hearings are concluded without the benefit of any relevant OI investigation reports an ex parte briefing of the relevant portions of the ongoing investigation will be given.
6 We believe that the requirement of disclosure under 10 C.F.R. Part 21 is relevant to all matters which the Staff, the Applic an t, and others investigate, including an ongoing investigation by the Government Accountability Project (GAP).
As the Board knows, GAP has in61cated that all of its information will be disclosed to OI (see Request filed March 16, 1984 pursuant to 10 C.F.R. 2.206, and submitted to the Board attached to a Limited Appearance Statement dated March 20, 1984).
7 CASE is particularly concerned with providing a structured acceptable method of exchanging relevant information, or the existence of such information, with OI is because (1) witnesses hao expressed a willingness to provide information to or cooperate with OI investigators while balking at undertaking similar risks with regional staff; and (2) since harassment and intimidation is a violation of the Energy Reorganization Act and also, in some cases, a criminal violation, it will be OI which is the recipient of the bulk of information relevant to these proceedings.
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8-4 Following this g parte briefing the Board will make a simple decision of whether or not the information contained in the,
investigation (1) would substantially enhance the record in some J
manner and therefore require a hearing, or (2) that the informa-tion is either cumulative of what is already on the record, or the Board.does not believe that the information is necessary to its dec ision.8 If the Board decides' that the information should be dealt l.
with in the hearing process it will become necessary for the Office of Investigations to precisely define the nature of the j
problem which is preventing the matter from being made public.9 i
It would be speculative to attempt to project beyond the possibilities outlined here.
CASE acknowledges, however, the very real potential that it may be impossible to close the record i
on this issue at-the conclusion of the hearing because of information known only to the Office of Investigations deemed to be relevant to this issue.
In such a case, given the Byron decision, we believe that t
8 The Board in this case has already been faced with an-analogous situation in which it exercised judgment similar to the type of judgment it would be faced with if CASE's proposal is ado pted.-
See Memorandum and order of the Board (Quality j- '
Assurance for - Design), Dec ember 28, 1983, foo tno te 35, in which F
the Board rejected the need for applicant to reply to information i
on a technical issue provided by CASE in response.to post-hearing l
submittals by the Staff because.the matters were fully covered in previous testimony.
9 The current confidentiality policy of the Staff is attached l
as Attachment 2.
It should be noted that the confidentiality statement makes a special provision for-the possible need to -
l disclose the identification of a. confidential witness under i
" orders or. subpoenas issued by courts of law, hearing boards, or-similar legal entities."
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- all the par ties have no choice but to wait until completion of the investigation or be faced with an appeals board decision to remand the matter for further hearings.
(See, generally, Commonwealth Edison Company (Byron Nuclear Power Station, Units 1
.and 2), ALAB-770, NRC slip opinion, May 7,1984).
CONCLUSION We submit that our proposal is a reasonable way to balance the parties requirements of full disclosure with their legitimate need to make and keep commitments of confidentiality.
Fur ther,
it provides a methodology which should narrow down to very specific matters or witnesses such insoluable problems as might develop.10 Further it requires all of the parties to explain to all of their potential witnesses the hearing procedures (including available protections), the scope of the issue, and the importance.of presenting a full and complete record on the issue 10 These types of problems have-arisen before, if not before hearing boards, then between the Staff,.the Applicant and witnesses who desired confidentiality and protection but were anxious to have their concerns known to those persons who could take corrective action.
For informational purposes only I have attached a letter from the Government Accountability Project
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(Attachment 3) of the efforts another utility company has undertaken 'in order to -have the concerns of an alleger i
identified.
Although the alleger mentioned in this corres-pondence ultimately revealed significant hardware defects to the staff. and utility management the fears of identification and industry " black balling" expressed by. the alleger.and the lengths.
to which all parties were required to go in order to convince the '
witness to disclose his specific concerns may be similar ' to the
. types 'of situations which will remain to be solved by'the parties j
.in this proceeding.
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of harassment and intimidation to this Board.
. CASE respectfully requests the Board adopt the propesal for dealing with confidential information outlined on pages 4 to 9 o f this mo tion.
Respectfully submitted, N 3.7ebout er ANTHONY %E. RQISMAN Trial Lawyers for Public Justice 2000 P Street, N.W.,
Suite 611 Washington, D.C.
20036 (202) 463-8600 June 5, 1984 AFFIDAVIT OF NON-CISCLOSURE I, __
, being duly sworn, state:
1.
As used in this Affidavit of Non-Disclosure, (a) " protected information" is (1) information revealed in connection' with M camera hearings in the Catawba operating license proceeding, including particularly the names of and identifying facts about g camera witnesses, and any other related information, particularly documents, specifically designated by the Licensing Board; or (2) any information obtained by virtue of these proceedings which is not otherwi.se a matter of public record and which deals with the M camera hearings.
(b) An " authorized person" is a person who, at the invitation of the Atomic Safety and Licensing Board (" Licensing Board"), has executed a copy of this Affidavit.
2.
I shall not disclose protected information to anyone except an authorized person, unless that information has prevously been disclosed in the public record of this proceeding.
I will safegtard protected information in written form (including any portions of transcripts of M camera hearings, filed testimony or any other documents that contain such information), so that it remains at all times under the control of an authorized person and is not disclosed to anyone else.
3.
I will not reproduce any protected infonnation by any means without the Licensing Board's express approval or direction.
So long as I possess protected information, I shall continue to take these
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precautions until further order of the Licensing Board.
4.
I shall similarly safeguard and hold in confidence any data, notes, or copies of protected information and all other papers which contain any protected i,nformation by means of the following:
(a) My use of the protected information will be made at a place approved by the Board.
(b)
I will keep and safeguard all such material in a locked facility approved by the Board.
(c) Any secretarial work performed at my request or under my supervision will be perfonned at the above location by one secretary of my designation.
I shall furnish the Board and parties an appropriate resume of the secretary's background and experience.
(d) All mailings by me involving protected information shall be made by me directly to the United States Postal Service or by personal delivery.
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5.
If I prepare papers containing protected information in order to participate in further proceedings in this case, I will assure that any secretary or other individual who must receive protected information in order to help me prepare those papers has executed an affidavit like this one and has agreed to abide by its terms.
Copies of any such affidavit will be filled with and accepted by the Licensing Board before I reveal any protected infonnation to any such person.
6.
I shall use protected'information only for the purpose of preparation, including any investigations which may be necessary, for
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this proceeding or any further proceedings in this case dealing with quality assurance and quality control issuest and for no other purpose.
7.
I will avoid disclosure of protected information to the best of my ability.
However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain i
protected information may be independently discerned incident to that investigation which might result in the inadvertent disclosure of protected information.-
.8.
I shall keep a record of all protected information in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Licensing Board or to a Comission employee designated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein.
When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated s
by the Board), together with all notes and data which contain protected information for safekeeping until further order of the Board.
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Subscribed and sworn to before me !
this day of 1983.
Notary Public t.
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OFFICE OF INVESTIGATIONS INVESTIGATIVE PROCEDURE MEMORANDUM NO.82-008 SUBJECT,:
CONFIDENTIALITY OF INFORMANTS / WITNESSES-
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OBJECTIVES (1) To provide the NRC with the broadest possible latitude in making use of infomation from infomants and witnesses while still providing those individuals with adequate assurances that their identities will be protected as fully as possible.
(2) To minimize the possibility of subsequent claims that individuals were offered ccnfidentiality, when it was not granted either as a matter of policy or because it was not specifically requested.
GENERAL POLICY Investigators will not routine 1v offer ennfidentiality to individuals making allegations or otherwise providino informatinn during the course of an Mc i
2 nyestia m on. ine avbje u oT confidentiality, i.e., the protection of the tdent' ty of an informant or witness, nomally should not be raised initially by the investigator during an NRC interview.
If an individual requests anonymity, or if in the opinion of the investigator the information will not otherwise be forthcoming, the investigator may then grant confidentiality.
EXTENT OF CONFIDENTIALITY AVAILABLE Before confidentiality has been granted, the individual should be informed that,-
although the pledge is nct absolute, it is NRC policy not to divulge to others the identity of people granted confidentiality, either during or subsequent to the' investigation; furthir, the individual should be told that his/her name will not normally appear in the publicly released report of. investigation. It should be pointed out, however, that the nature of the allegati6ris or the limited number of individuals privy to the subject information 'may provide a basis for guessing his/her identity.
Such " guesses" will, not be confirmed or otherwise responded to by NRC.
Finally, the individual shou 1d be made aware that, if the results of the o investigation fom the basis for an enforcement action, either-civil or criminal, and a hearing ensues, it may not be possible to maintain his/her anonymity. The individual should be informed that the information may be given to Congress and/or other Federal agencies. fle/she should also be advised of the protection afforded by section 210Tof the Energy Reorganization Act of 1974 to employees who may be discharged or otherwise discriminated against for providing information or assistance to the NRC.
CONFIDENTIALITY AGREEMENT When an individual accepts the offer of confidentiality, a " Confidentiality Agreement" (attachment 1) must be executed. This fom outlines the sc' ope of the. agreement and the responsibilities of each party. Investigators are not authorized.to grant confidentiality to anyone who refuses to sign an agreement
in substantially the same fom, The form provides a space for "other conditions" which may 'be used to address particular needs; however, investigators may not allow such. conditions to alter the general scope of confidentiality authorized.
After the form is signed by both the individual and the investigator, the original copy should be provided to the individual; the investigator should retain either a photoco'py of the executed agreement or a du'plicate original of the agreement.
The NRC copy will be retained in the 01 Field Office file for the investigation.
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,(0riginal to source of ir' nation, NRC to retain signed apy of duhlicite original) ~
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I have information that I wish to provide in confidence to the U. S. Nuclear i
Regulatory Commission (NRC).- 1 request an. express pledge of confidentiality as a condition of providing this infomation to the NRC.
I will not provide this information voluntarily to the NRC without such confidentiality being extended to me.
It is mf understanding, consistent with its legal obligations, the NRC, by
' agreeing to this confidentiality, will adhere to the following conditions:
(1) The NRC will not identify me by name or personal identifier in any NRC initiated document, conversation, or comunication released to the public which relates directly to th'e infor1 nation provided'by me.
I understand the term
'*public release" to encompass any distribution outside of the NRC with the exception of other public agencies which may require this information in futherance of their responsibilities under law or public trust.
(2) The NRC will disclose my identity within the NRC only to the extent required for the conduct of NRC related activities.,
(3) During the course of the inquiry or investigation the NRC will also make every effort consistent with the investigative needs of the Comission to avoid actions which would clearly be expected.to 'esult in the disclosure of my identity to r
persons subsequently contacted by the NRC.
At a later stage I understand that even though the NRC will make every reasonable effort to protect my identity, my identification could be compelled by orders or subpoenas issued by courts of law, hearing boards, or similar legal entities.
In such cases, the basis for granting this promise of confidentiality and.any other relevant facts will be
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comunicated to the. authority ordering the disclosure in an effort to maintain
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my confidentiality.
If this effort proves unsuccessful, a representative of d
the NRC will attempt to inform me of any such action before disclosing my identity.
I also understand that the'NRC will consider me 'to have waived my right. to confidentiality if I take any action that may be reasonably expected to disclose my identity.
I further understand that the NRC will consider me to have waived L
my rights to confidentiality if I provide (or have previously provided) informati6n to any'other party that contradicts the information that lprovided to the NRC or if circumstances indicate that I am intentionally pro.vidirig false information to the NRC.
Other Conditions:
(if any)
I have read and fully understand the contents of this agreement.
I agree with its provisions.
Date Signature of source of information
' Typed or. Printed Name and Address
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Agreed to on' behalf of the US Nuclear Regulatory Comission.
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Date Signature.
L Tvoed or Printed Name and Title i
GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies (202)234 9382 1901 Que Street, N.W., Washington, D.C. 20009 March 9, 1983 Mr. James E. Brunner Consumers Power Company P.O. Box 1593 Midland, Michigan 48640
Dear Mr. Brunner:
This letter is in response to your February 24, 1983 letter to me regarding the criteria under which an individual (" Individual A") who has provided a confidential af fidavit to GAP will be able to visit the Midland jobsite.
We appreciate the efforts that you have gone through to extend the opportunity to our client to visit the site and identify and explain his allegations to the Nuclear Regulatory Commission inspec-As I indicated in my December letter, as well tors / investigators.
as throughout our conversations, both GAP and Individual A are anxicus to have the problems on the site identified and resolved.
The major criteria that we have agreed upon are summarized below:
A site tour vill be provided for Individual A during non-(1) regular work hours (i.e., weekends, evenings, etc.).
Another individual, preferably a current or former plant (2) employee, or union representative, will be allowed to accompany the individual on the site tour.
4 The Company and contractor Bechtel will "not disclose (3)
We under-
. Individual A's identity to the media or general public."
stand that in fact Individual A's identity will not be disclosed 24, 1983 letter.
beyond the control group identified in your February The Company will not refer to the fact that Individual A (4) had supplied information, which was transmitted to the NRC, in any
' job reference or any other communication which the Company provides.
That any reference to Individual A's allegations or to (5)
Individual A in company documents will be limited to the control f-l-
s,
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Mr. James E. Brunner Consumers Power Company March 9, 1983 1983 letter.
(We group as identified in your February 24, strongly suggest that any reference to the individual, including Both the company internal documents, be done with discretion.
NRC and GAP use an alphabetical identification system in-house as well as in any external communication.
We believe following that procedure would eliminate the possibility of an internal leak.)
That the individual will not_ have to sign the usual (6) site procedural sign-in book, since he will be accompanied at all times by both NRC and company of ficials.
(This has been done at both LaSalle and Zimmer.)
That the issue of depositions and confidentiality within (7) the ASLB hearing process will be dealt with at some future time through the ASLB under such protective measures as are guaranteed by the Board.
That Individual A will not be subjected to any question-(8) ing by company officials attempting to challenge the validity of his/her allegations, or by technical consultants or employees.
The purpose of the site tour is to facilitate the NRC inspection Subsequent to the NRC effort we assume Consumers will effort.
take the appropriate corrective action.
We further wish to clarify the points raised in your February 24, 1983 letter, paragraph 3.
the affiant's "Despite the above protective measures, identity might be guessed or inferred by a co-worker or other person outside the ' control group' as a result of the identification, tagging (if necessary), or cor-rection of the identified hardware, or because of the required QA documentation pinpointing the problem.
Certain persons may already have guessed or been told by the affiant of his identity.
Obviously, neither CPCo nor Bechtel is in a position to guarantee that further disclosures have not or will not be made by such persons, or that they have or will abide by the tetins described below."
We assume that Consumers Power Company and your contractor, the Bechtel Corporation, are responsible for the actions of your On an issue as sensitive as this one it would seem employees.
appropriate that extra precautions would be taken to ensure that (1) the individual's identity is not released, and (2) that even if his/her identity were guessed or inferred by a co-worker or other person outside the " control group," that person would be aware of and familiar with the agreement made between your company We can conceive of only and us on behalf of the protected witness.
a very unusual circumstance where the knowledge of Individual A's
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Mr. James E. Brunner March 9, 1983 5
Consumers Power Company identity on the part of any of your employees would be beyond your control if the conditions agreed to are faithfully followed We would certainly expect that in the event an employee guessed or inferred the identity, such a guess or inference would not be verified or discussed by the company or contractor or its employees.
Finally, we wish to clarify your comments during our conver-sation in Midland about the number of people who would know theYr>2 o identity of the affiant. letter to James Keppler indicated that "not more than 28, 1983 However, in the February 24, two or three persons" would know.it appears that number may be expanding.
1983 letter and via the NRC, We wish to underscore that our agreement is predicated upon the promise that the smallest possible number of individuals know our client's identity.
Sincerely, Billie Pirner Garde l
Director, Citizens Clinic BPG/ea SLewis, Region III cc:
WPaton, OELD MIMiller, IL&B MHearny OL/OM Service List JWCook, Consumers DBMiller, Consumers RAWells, Consumers JRutgers, Bechtel O