ML20100M639
| ML20100M639 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/15/1985 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-574 OL, NUDOCS 8504170673 | |
| Download: ML20100M639 (21) | |
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April 15, 1985 D8LKETED USNRC 15 Am 17 N0 55 UNITED STATES OF AMERICA GFFICE OF SECDETARY-NUCLEAR REGULATORY COMMISSION 00CKETgr ERVICE 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424
) 50-425 (Vogtle Electric Generating Plant, ) (OL)
Units 1 and 2) )
APPLICANTS' ANSWER TO JOINT INTERVENORS' MOTION FOR A PROTECTIVE ORDER I. Background On March 12, 1985, Applicants deposed Mr. Tim Johnson, the Executive Director and sole employee of Intervenor Cam-paign for a Prosperous Georgia (CPG). During the course of the deposition, Mr. Johnson's personal counsel instructed Mr.
Johnson not to answer questions on a number of topics: (1)
CPG's financing; (2) Mr.. Johnson's sources of income; (3) Ed-ucational Campaign for a Prosperous Georgia (ECPG); (4) CPG's relationship with ECPG and Southern Regional Council (SRC);
and (5) CPG's past and present membership. Mr. Johnson's 8504170673 850415 PDR ADOCK 050C0424 Q PDR g@
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t-6 attorney objected to questions on these topics solely on the grounds of relevance. Counsel for Joint Intervenors only joined in objecting to questions concerning ECPG.
On March 22, Applicants filed " Applicants' Motion to Compel Answers to Deposition Questions" (hereinafter Appli-l i
cants' Motion to Compel). Therein, Applicants addressed Mr.
l Johnson's objections and the impropriety of his refusal to 1
respond. Applicants explained that their questions were de-I signed to elicit information relevant to Mr. Johnson's credi-bility. Mr. Johnson had been designated by Joint Intervenors as a potential witness in this proceeding. Johnson deposi-tion, Tr. at 6-7. See also Letter from B. Churchill to L.
Fowler (March 5, 1985). Applicants' questions were also asked to ascertain the identity of CPG, to explore the factu-al basis for statements in CPG's Petiton for Leave to Inter-vene, and to determine whether CPG had standing to intervene in this proceeding. All of Applicants' questions were gener-ally relevant to the subject matter of the proceeding. See Applicants' Motion to Compel at 4-10.
On April 1, 1985, Joint Intervenors filed "Intervenors' Motion for a Protective Order in Opposition to Applicant s' Motion to Compel Answers" and "Intervenors' Brief in Support of Motion for Protective Order and Response to Applicants' Motion to Compel" (hereinafter Joint Intervenors' Brief). In their Brief, Joint Intervenors raised new objections an6
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i arguments. Applicants now respond and submit that Joint In-tervenors' Motion for a Protective Order should be denied.1!
II. CPG's Relevance Arguments Although Joint Intervenors only joined in objecting dur-ing the deposition to questions concerning ECPG, Joint Inter-venors now join in all of Mr. Johnson's attorney's relevance objections. Joint Intervenors' Brief at 3. However, Joint Intervenors do not deny that a relevance objection was an im-proper basis for refusal to respond to deposition questions.
See Applicants' Motion to Compel at 4. Applicants submit that the grant of Joint Intervenors' Motion for Protective Order on the basis of relevance objections would sanction an improper refusal to respond at the time of the deposition and would permit circumvention of the rules of practice. Never-theless, Applicants address each of Joint Intervenors' rele-vance arguments below.
1/ Since Joint Intervenors' Motion for Protective Order is a new motion based on new objections and arguments, Ap-plicants believe that an answer is permitted by 10 C.F.R. S 2.730(c). However, if the Board considers Joint Intervenors' Motion to in fact be no more than a response to Applicants' motion to compel, Applicants would move for leave to file a reply. Joint Interve-nors' having filed a motion and having raised new objec-tions constitute good cause for such reply.
t 1
4 A. Questions Concerning Membership During Mr. Johnson's deposition, Counsel for Joint In-tervenors specifically stated that it was not her position that questions concerning membership should not be answered.
Johnson deposition, Tr. at 48. Nevertheless, Joint Interve-nors now argue in support of their Motion for Protective Order that questions concerning membership are irrelevant be-cause CPG has already been " adjudged" a party. Joint Inter-venors' Brief at 6.
The Board's Prehearing Conference Order should not fore-close. discovery on the subject of standing. The Board's rulings on standing were for all practical purposes no more than rulings on the sufficiency of pleadings. Applicants were not entitled to conduct discovery prior to the Board's prehearing conference (10 C.F.R. S 2.740(b)) and thus had no opportunity to explore the factual bases of Joint Interve-nors' claims regarding standing. The factual bases of Joint Intervenors' claims regarding standing have not been "ad-judged."
- Moreover, since then, new information -- coupled with Mr. Johnson's curious reluctance to discuss the new informa-tion -- has raised questions about the accuracy and continued validity of information contained in CPG's Petition for Leave to Intervene. For example, the petition stated that CPG was s
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formed by a coalition of consumer groups, environmental orga-nizations, and individuals; but Mr. Johnson testified that this statement merely meant that representatives of the orga-nizations took part in the formation of CPG. Johnson deposi-tion, Tr. at 46. Mr. Johnson further testified that CPG is now a corporation (Tr. at 46-47), and suggested that the af-fiants who claimed membership'in support of CPG's Petition for Leave to Intervene have no closer relationship to CPG than that relationship any and every citizen in Georgia has to CPG. Tr. at 64-65. Mr. Johnson nevertheless has refused to discuss how membership was determined at the time CPG filed its petition or whether CPG currently has any members.
Tr. at 61, 183-84.
Applicants should not now be denied the only meaningful opportunity (discovery) they have to evaluate the accuracy of the claims in CPG's Petition for Leave to Intervene. The in-quiry is necessary not only to preserve Applicants' procedur- :
al rights but also to protect the integrity of the licensing process. CPG's claim to standing has been compromised by both the statements Mr. Johnson has made and those he refused to make. The Board should not ignore the possibility that
! CPG's claim was inaccurate and that the Board's jurisdiction l
has been improperly invoked.
In addition, questions concerning membership are rele-vant apart from standing -- a fact Joint Intervenors ignore.
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a In order to explore potential bias stemming from affiliation with certain organizations, Applicants sought the factual basis for the statement in CPG's Petition that CPG was a co-alltion formed by consumer groups and environmental organiza-tions. Moreover, Mr. Johnson's partial responses raised the possibility that CPG's Petition for Leave to Intervene was inaccurate -- a fact that would also reflect adversely on CPG's and Mr. Johnson's credibility. Applicants' Motion to Compel at 9, 10.
B. Questions Concerning Mr. Johnson's Sources of Income, ECPG, AND SRC Joint Intervenors do not deny that questions concerning the credibility of Mr. Johnson, whom Joint Intervenors had designated as a potential witness, were proper. Instead, Joint Intervenors now announce: "[ alt the present time, joint intervenors do not plan to call Mr. Johnson as a witness for any of the contentions admitted thus far."2/ Joint Interve-nors' Brief at 2. Having thus purported to withdraw Mr.
Johnson as a witness (at least for the time being), Joint In-tervenors argue that Mr. Johnson's credibility is no longer at issue. Based on this argument, Joint Intervenors claim 2/ Joint Intervenors f'rther u remark that "Mr. Johnson has not submitted direct testimony." Joint Intervenors' Brief at 8.
that Applicants' questions concerning Mr. Johnson's sources of income, ECPG, and.SRC are no longer relevant. Joint In-tervenors' Brief at 8.
The Board should not countenance such legerdemain.
First, Mr. Johnson was designated as a potential witness at the time of the deposition, and Joint Intervenors' carefully-worded announcement intimates that he may again be proposed as a witness.
Second, even if Mr. Johnson were unequivocally withdrawn as a witness, his credibility would remain relevant. Joint Intervenors have also identified Mr. Johnson as an individual upon whom they relied to substantiate their contentions.
CPG /GANE's Response to NRC Staff's Interrogatories (Dec. 10, 1984) at 2-3. Joint Intervenors identified Mr. Johnson as an individual who had knowledge about "each of those [conten-tions] accepted by the ASLB," who provided information used in developing the basis for "all of those [ contentions) ac-cepted by the ASLB," and who provided information used in re-sponding to "all" the interrogatories. Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy Response to Applicants' Third Set of Interrogatories and Re-quest for Production of Documents (Feb. 5, 1985) at 8. Mr.
Johnson has also provided attestation to interrogatory an-swers. Applicants are entitled to probe the accuracy and va-lidity both of the bases for admitted contentions and of
interrogatory answers. The qualifications and credibility of the individual sponsoring such information is an integral part of this inquiry.
Applicants are also entitled to ascertain the identity of intervening parties. This information has direct bearing on the issues in this proceeding. For example, Joint Inter-venors' contentions and CPG's intervention have been dis-cussed in ECPG newsletters. If ECPG and CPG are'the same en-tity, statements in the ECPG newsletters might be admissions.
CPG has in fact used ECPG letterhead in filings in this very proceeding.
Accordingly, despite Joint Intervenors' "present" plan not to offer Mr. Johnson as a witness, Applicants' deposition questions concerning Mr. Johnson's sources of income and CPG's affiliation with ECPG and SRC are generally relevant and should be answered.
C. Questions Concerning CPG's Financing Joint Intervenors also object to questions concerning the sources of CPG's financial support as irrelevant. Joint Intervenors' argument is that because the Board "has ruled that the financial qualifications of applicants are irrele-vant . . . [i]t is hard to see why the financial resources of the intervenors have any relevance." Joint Intervenors' Brief at 7.
o-Joint Intervenors' argument not only is illogical but also misinterprets the Board's ruling. The Board ruled that CPG had failed to justify a waiver of the Commission's finan-cial qualifications rule -- a rule that presumes that an electric utility is financially qualified to operate a nucle-ar power plant. This ruling cannot be construed to suggest that financial interests are irrelevant to matters of credi-bility. Applicants' questions were asked to determine the nature and character of CPG, including whether CPG has a fi-nancial stake in the outcome or pursuit of the Vogtle licens-ing proceeding, a stake that could also be imputed to Mr.
Johnson, CPG's sole employee and chief executive officer.
III. Joint Intervenors' " Privilege" Arguments -
Joint Intervenors also claim that the information Appli-cants seek is privileged for various reasons. Joint Interve-nors, however, never raised privilege objections during Mr.
Johnson's deposition. Such objections are untimely and have been waived.
Joint Intervenors state that 10 C.F.R. S 7.740a(d) "sug-gests" that it would have been inappropriate for them to have objected to any questions at the deposition. Joint Interve-nors' Brief'at 3. Joint Intervenors misconstrue 10 C.F.R.
S 2.740a(d), which clearly contemplates just the opposite --
that " objections on questions of evidence shall be noted in L
short form without the arguments." Moreover, certain objec-tions if not raised are waived. 10 C.F.R. 5 2.740a(d) states: " Objections on questions of evidence not made before the officer shall not be deemed waived unless the ground of the objection is one which-might have been obviated or re-moved if presented at that time." From examination of the Federal Rules, it is evident that only objections to the com-petency of a witness or to the competency, relevancy, or ma-teriality of testimony are preserved. See Fed. R. Civ. P.
32(d)(3)(A). Claims of privilege are not. Accordingly, a claim of privilege should be raised when the deposition is taken or'not at all.S! 4A J. Moore, Moore's Federal Practice 1 30.59 at 30-139 (2d ed. 1984). See Perrignon v. Bergen Brunswig Corp., 77 F.R.D. 455, 459 (N.D. Cal. 1978) (by failing to make a timely objection, party waived any privi-lege that existed); Shapiro v. Freeman, 38-F.R.D. 308, 311-12 (S.D.N.Y. 1965) (if attorney believed that information sought was privileged,lhe should have halted the examination and immediately applied for a protective order).
3/ By failing to raise privilege objections, Joint Interve-nors denied Applicants the opportunity to establish by questions during the depositions the applicability or inapplicability of the privilege. Such questioning would have been permissible. In re Treacher's Franchise Litigation, 92 F.R.D. 429 (E.D.Pa. 1981). Joint Inter-t venors' failure to raise privilege objections also de-
! nied Applicants the opportunity of phrasing questions
- that avoided or minimized inquiry into matter claimed to l be privileged.
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Applicants also submit that Joint Intervenors' privilege objections are unfounded in law and fact. In this respect, Joint Intervenors, as the party asserting privilege, have the burden to establish the existence of the privilege. Public Service Co. of New Hampshire (Seabrook Station, Units.1 and 2), LBP-83-17, 17 N.R.C. 490, 495 (1983); Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit No. 1),
LBP-82-82, 16 N.R.C. 1144, 1153 (1982); Boston Edison Co.
(Pilgrim Nuclear Generating Station, Unit 2), LBP-75-30, 1 N.R.C. 579, 583 (1975).
Joint Intervenors claim that Applicants are seeking to identify the past and present membership of CPG. CPG cites Bates v. City of Little Rock, 361 U.S. 516, 524 (1960), for the proposition that discovery of membership lists has been disallowed. Bates, however, did not involve a discovery dis-pute, but rather addressed the constitutionality of a munici-pal law that required disclosure of the identity of members of a local NAACP branch. The Bates Court, finding that the record of the case established that NAACP members had been harassed and threatened, concluded that compulsory disclosure of membership lists of local NAACP branches would work a sig-nificant interference with the freedom of association of NAACP members. 361 U.S. at 523-24. The Court then considered whether such interference was justified. Finding no compel-ling justification, the Court concluded that the disclosure
could not constitutionally be required. 361 U.S. at 524-27.
The holding in Bates is essentially'the same as reached in the more celebrated case, NAACP v. Alabama, 357 U.S. 449 (1958).
The Bates and NAACP decisions are significantly dissimi-lar from the case at bar and hence do not support CPG's mo-tion for protective order. First, Applicants are not seeking a membership list -- the identity of all CPG members. Rath-er, Applicants are only inquiring (1) about membership as it pertains to CPG's standing-to intervene and (2) about the identity of consumer groups and environmental organizations that are or were CPG members.A! With respect to standing, Applicants wish to know whether the " membership" of the affi-ants who supported CPG's petition for leave to intervene (in-dividuals whose identity has already been disclosed and is therefore not privileged) is legally sufficient to support CPG's standing. In this regard, Applicants would ask when these individuals became " members," what constituted " member-ship," did CPG have any other " members," and did CPG.know at f the time it filed its petition that it was shortly going to
! change to a non-membership organization. Applicants would 4/ Consumer groups are not entities that shun publicity or are likely to feel intimidated, and Mr. Johnson has in fact disclosed the names of several organizations that might be or have been CPG members. Tr. at 45-46.
also inquire whether CPG today as a non-profit corporation has anybody it considers to be a " member;" and if.so, Appli-cants would inquire what today constitutes membership and whether CPG today has standing. Applicants are only inter-ested in the names of individuals upon whose membership CPG bases its claim to standing.
Second, NAACP and Bates are distinguishable'from the present controversy by the frivolous and unfounded nature of Joint Intervenors' claim of potential harassment. Joint In-tervenors attach an eight-year-old Atlanta Journal article (Sept. 9, 1977), which reported charges two Georgia Power se-curity department employees made after they had been dis-charged and several subsequent news clippings that repeated the charges. Joint Intervenors conveniently omit describing the outcome of lawsuits that arose from or were related to the charges -- lawsuits whose outcome exhonerated Georgia Power Company.
The former Georgia Power Company security department em-ployees were William D. Lovin and John H. Taylor. Each filed a lawsuit against Georgia Power in which their claims were based, in part, on the charges of improper information gath-ering by Georgia Power Company which had appeared in the ar-ticles Joint Intervenors attach to their motion. When pro-I vided with opportunities to verify their charges under oath neither was able to support any charge of harassment of private individuals. ,
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Mr. Lovin's lawsuit was dismissed on the merits on Georgia Power's Motion for Summary Judgment. In its order, the Court made the specific finding that Lovin had failed to identify any specific criminal activity and had failed to place any evidence in the record that Georgia Power engaged in any criminal conduct. (William D. Lovin v. Georgia Power Company, In The Superior Court of Monroe County, Georgia, Civil Action No. 8961, Order dated March 10, 1978). Mr.
Lovin's subsequent appeal was dismissed. (Action No. 8961, Order dated January 4, 1979). A similar summary judgment order in a companion case was affirmed by the Georgia Court of Appeals. Goodroe v. Georgia Power Company, 148 Ga. App.
193, 251 S.E.2d 51 (1978).
Mr. Taylor's lawsuit is of special significance because he was identified as a main source for the original Atlanta Journal article in question, because he provided the list of file categories maintained by Georgia Power and because he
! made the statement that a " subversive" was "anyone who spoke i
j out against Georgia Power." (See Deposition of Atlanta Jour-nal reporter Thomas R. Baxter, Jr., taken on October 13, 1978, p. 31, in John H. Taylor v. Georgia Power Company, In the Superior Court For the County of DeKalb, State of l
l Georgia, Civil Action File No. 77-3246.)
When placed under oath and questioned extensively about the basis for his claims that Georgia Power harassed i
opponents or conducted improper information gathering, Mr.
Taylor was unable to support a single charge. (See Deposi-tion of John H. Taylor in Civil Action No. 77-3246.) He ad-mitted that many of his claims were based on information he had received from Mr. Lovin. Mr. Taylor's lawsuit was dis-missed for failure to prosecute.
Joint Intervenors also attach an affidavit of Tim Johnson who claims that some CPG supporters have stated they fear being pushed into a higher rate bracket if they are identified with CPG. This affidavit is hearsay and rank speculation. Joint Intervenors make no showing that such re-taliatory action has ever occurred or even could occur under Georgia law and the regulation of the Georgia Public Service Commission. Mr. Johnson's affidavit falls far short of es-tablishing even a possibility of harassment. Compare Houston Lighting and Power Co. (Allens Creek Nuclear Generating Sta-tion, Unit 1), ALAB-535, 9 N.R.C. 377, 399 (1977).
These two distinguishing factors, the very limited na-ture of Applicants' inquiry concerning CPG's membership and Joint Intervenors' failure to demonstrate that the inquiry would result in repression, are dispositive. They belie any claim that disclosure would invade the right of association of CPG's members. Houston Lighting and Power Co. (Allens Creek Nuclear Generating Station, Unit 1), ALAB-535, 9 N.R.C.
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377, 398-400 (1977).
a
D Even if there were a possibility that disclosure would invade the right of association of CPG members, Bates and NAACP are further distinguished by the absence in those cases of justification for such invasion. Here, the need to ascer-tain whether an intervening party has standing (a statutory requisite) provides compelling justification for the limited inquiry. Cf. Houston Lighting and Power Co. (Allens Creek Nuclear Generating station, Unit 1), ALAB-535, 9 N.R.C. 377, 398-400 (1977). In federal practice, courts recognize the needs of litigants and permit discovery of a party's member-ship where such inquiry relates to specific allegations in that party's complaint. Savala v. Webster, 644 F.2d 743, 747 (8th Cir. 1981); Grinnell Corp. v. Hackett, 20 Fed. R. Serv.
2d 668 (D.R.I. 1974), appeal dismissed, 519 F.2d 595 (1st Cir. 1975), cert. denied sub nom., chamber of Commerce v.
United Steelworkers of America, 423 U.S.1033 (1975) (where l plaintiff had alleged injury to its members, defendant could inquire into such injury and ple.intiff's membership was dis-coverable); Dow Chemical Co. v. Taylor, 20 Fed. R. Serv. 2d 673 (E.D.Mich. 1974), appeal dismissed, 579 F.2d 352 (6th Cir. 1975), cert. denied sub nom., Chamber of Commerce v.
l United Steelworkers of America, 423 U.S. 1033 (1975) (where plaintiff had sued only on behalf of its members, identity of its members was discoverable). In the same vein, Applicants'
! need to explore questions of credibility provides l
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justification for inquiry into CPG's affiliation with consum-er groups and environmental organizations, and the concomi-tant accuracy of CPG's petition.
Joint Intervenors also object to questions concerning CPG's finances on the ground that the information is propri-etary. Joint Intervenors' Brief at 7. Joint Intervenors, however, make no effort to address the factors necessary to establish entitlement to protection. See Kansas Gas and Electric Co. (Wolf Creek Nuclear Generating Station, Unit No.
1), ALAB-327, 3 N.R.C. 408, 416-17 (1976). ! Joint Interve-nors offer no affidavits to establish that the information sought is proprietary. See Virginia Electric and Power Co.
(North Anna Nuclear Power Station, Units 1 and 2), ALAB-555,
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10 N.R.C. 23, 27-28 (1979). Instead, they merely make vague speculation that "other individuals may solicit [ CPG and GANE] donors to the detriment of the joint intervenors."
Joint Intervenors' Brief at 7. Joint Intervenors have not satisfied their burden to establish entitlement to protec-I tion.
5/ To establish that information is confidential commercial information subject to protection, Joint Intervenors are required to demonstrate that (1) the information in question was of a type customarily held in confidence by its originator; (2) there is a rational basis for having customarily held it in confidence; (3) it has, in fact, i been kept in confidence; and (4) it is not found in pub-
! lic sources. Wolf Creek, ALAB-327 supra, 3 N.R.C. at 416-17.
l
Finally, Joint Intervenors claim that information con-cerning Mr. Johnson's finances is " privileged," presumably because of an " expectation of privacy." See Joint Interve-nors' Brief at 7-8. How Joint Intervenors can argue that Mr.
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Johnson has an expectation of privacy in this respect is unfathomable. In a recent motion to compel signed and filed by Mr. Johnson, Mr. Johnson stated that financial ties of persons who provide information used in responding to inter-rogatories "are very relevant because . . . it can skew the results (of their judgment]." Intervenors Campaign for a Prosperous Georgia / Georgians Against Nuclear Energy Motion to Compel Applicants' Response to Interrogatories and Requests to Produce Documents (March 1, 1985) at 2-3. With this phi-losophy, Mr. Johnson, who also provided information used in L answering interrogatories in addition to having been desig-nated as a witness, could not reasonably have believed his financial ties would be immune from disclosure.6/
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6 New York Stock Exchange, Inc. Sloan, 22 Fed. R. Serv. 2d 500 (S.D.N.Y. 1976), which Joint Intervenors cite, is readily distinguishable. That case involved the privacy rights of non-litigants and its result was based on pub-lic policy that disclosure of the performance evalua-tions of accountants would deter candid evaluation to the detriment of that profession.
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y IV. Conclusion For all the reasons discussed above, Joint Intervenors' new arguments and objections should be rejected, and their motion for protective order should be denied.
Respectfully submitted,
, ,f
( . -
'GeefW Trowbridge, P.C.
Bruce W. Churchill, P.C.
David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN^
& ASHMORE Counsel for Applicants Dated: April 15, 1985 A
CON' Ap44h d), 1985 USHMC 35 .VE 17 N0 WS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION bFFIC# OF SECRtiTAR f DOCKlilNG & SERVICE BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424
) 50-425 (Vogtle Electric Generating Plant, ) (OL)
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Answer to Joint Intervenors' Motion for a Protective Order," dated April 15, 1985, were served upon those persons on the attached Ser-vice List by deposit in the United States mail, postage pre-paid, this 15th day of April, 1985.
A BMce W. Churchill, f.C.
Lu Dated: April 15, 1985
r.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-Before the Atomic Safety and Licensing Board In the Matter of )
)
GEORGIA POWER' COMPANY, et al. ) Docket No. 50-424
) 50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2) )
SERVICE LIST Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Commission Atlanta, GA 30306 Washington, D.C. 20555 Laurie Fowler & Vicfi Breman Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U.S. Nuclear Regulatory Commission 1102 Healey Building Washington, D.C. 20555 Atlanta, GA 30303 Dr. Oscar H. Paris Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory Commission Georgia Washington, D.C. 20555 175 Trinity Avenue, S.W.
Atlanta, GA 30303 Bernard M. Bordenick, Esq.
Office of Executive Legal Director Docketing and Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel
- U.S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C. 20555 Regional Counsel U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C. 20555 Atlanta, GA 30303 Gary Flack, Esq.
1515 Healey Building 57 Forsyth Street Atlanta, GA 30303
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