ML20154E983
| ML20154E983 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/02/1988 |
| From: | Ellis J, Garde B Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6327 CPA, OL, NUDOCS 8805230051 | |
| Download: ML20154E983 (19) | |
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- S32 7 4
- f. 4 Filed: May 2, 1988, ndie st UNITED STATEJ NUCLEAx HEGULATORY COMMISSION 88 my -6 P411 before the ATOMIC SAFETY AND LICENSING BOARD . ..
GFf Kt t 't u L A 00CM I M A %"V"C)I-9RANCM
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In the Matter of )
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TEXAS UTILITIES ELECTRIC )
COMPANY, et.al., ) Docket Nos. 50-445-OL
) 50-446-OL
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) Docket No. 50-445-CPA (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
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CASE'S RESPONSI: TO RECONSIDERATION REQUEST OF APRIL 5, 1988, BOARD ORDER DENYING CONSOLIDATION The Citizen's Association for Sound Energy ("CASE" or "Intarvenor") herein opposes the April 15, 1988, Motions for Reconsideration of the Atomic Safety and Licensing Board's
("ASLB" or "Board") April 5, 1988, Order denying consolidati n of the Construction Permit Amendment proceeding ("CPA") and the Operating License ("OL") proceeding filed by the Nuclear Regulatory Commission's Staff ("NRC" or "Staff") and the Applicants; and, for the reasons stated herein request that the Board deny the reconsideration rtquest.1/ In the alternative, CASE requests that the Board portpone any ruling on 1/ This brief is filed on May 2, 1988, five days beyond the original due date with the acquiesence of the parties and the permission of the Board.
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tecanuideration of the c asolidation request at this time, and suggesta that an appropri2te time to reconsider the request would be upon completion of the discovery phase.of the OL and CPA proceedings.
Additionally, after some reflection, CASE opposes Applicants' request for oral argument on this matter and asks the Board to make a ruling on the pleadings. CASE understands that the Board was interested in discussing other matters at the pre-hearing conference. However, as discussed below, CASE simply is not in a position to discuss modification of the current schedule at this time, and seeks a delay of any additional "pre-trial" discussions to modify or streamline the hearing proceedings for at least six weeks.
] BACKGROUND As a result of the strong arguments made by the Applicants j and the NRC Staff in opposition to the Board's Order denying j consolidation, CASE felt it necessary to summarize the relevant
! history of the Construction Permit Amendment proceedings. The l
summary is not intended to be a citation to the record of the case, but rather to put the issue before the Board in procedural perspective.
i On August 1, 1985, the construction permit for Unit One of the Comanche Peak Nuclear Power plant expired without any requect i
for an extension being filed by the Applicant-Permittee. On or about January 28, 1986, the NRC discovered the fact that the construction percit had expired and notified officials at Texat i Utilities, the Intervenors, and the Board. On January 29. 1986, l
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t TU tequested a retroactl'e extension of the construction perutit.
Within days the NRC utaf: approved, retroactively, the permit amendment.
On January 31, 1986, CASE sought a suspension of all work activities at Unit I and started a legal challenge to the a retroactive granting of the construction permit and the continuation of the work at the unit. CASE requested a special hearing to be set on the relevant issues. (See, generally, CASE's January 31, 1986, Request for Imposition of Fine, For Suspension of Construction Activities, and for a Hearing of Application to Renew Construction Permit, and the February 11, 1986, Request for Stay of Effectiveness of Construction Permit Extension and Other Pelief.)
After a series of challenges to the request, the Commission referred CASE's request for a hearing to the Board for a post-extencion hearing. The Licensing Board began proceedings. CASE started discovery. TU and the NRC Staff moved to stay discovery
- and appealed, to the NRC Appeals Board, the decision of the Board
{ to admit the CPA contention. The Appeals Board certified the i
question to the Commission. The Commission considered the question and remanded to the Appeals Board the discretion to
! determine the admissibility of the contention in accordance with I
its reasoning that:
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We believe that the appropriate balance is struck by holdina that if there was a corporate policy to speed construction by violating NRC requirements, and that policy was discard, t J and repudiated by the permittee, any delays arising from t h-J need to take corrective action would be delays for good cause.
Co,cmission Order, CLI-86-15, September 19, 1986.
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Meanshile, CASE's e u11enge to the legality of the NRC's action in granting the an nded permit without granting CASE a prior hearing was considered by a three-member panel of the United States Court of Appeals for the District of Columbia. The Court of Appeals, after oral agreement, did not decide the question of whether the Commission was required to grant CASE's request for a hearing; at least in part, because the NRC had already decided that CASE was entitled to a hearing on the narrow "good cause" question which had the potential, if CASE were to l
prevail, of leading to an order stopping construction on Unit I.
Additionally the Court, in reaching its June 26, 1987, decision, stated:
Finally, we emphasite that our decision does not constitute approval of TUEC's past construction activities or serve as a prejudgment of any issue in the operating license proceeding. As the NRC concedes, whether TUEC will eventually be allowed to operate the facility is an entirely different question from whether to extend the completion 3
date of the construction permit. (citation omitted)
Slip. Op., at 10.
{ By this time CASE had amended its contention to incorporate f the CPA issues, as defined by the Commission. Recognizing that '
i much of the same information would be relevant and material to prepare for hearings in both the OL and the CPA, CASE filed the
,! silailar discovery requests in both proceeding. Applicant's I
strenuously objected to responding to the similar discovery requests on the bases that the two proceedings were "distinctly l different," and discovery was stayed in the CPA proceeding. Tb ,
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i /pplicants stated:
Contrary to CASU's ovious assertions, the two dockets are not "companion" proceedings. The issues in the two proceedings are distinctly different, albeit involving the same plant. Whereas some overlap of relevant information is inevitable, in no way can either the scope or nature of the issues be descrioed as identical. Indeed, we believe the Commission has made clear its view that the borders of construction permit extension litigable issues are marked primarily by the consideration that construction permit extension cases and operating license cases are not intended to overlap into the same area. (citing Washington Public Power Supply System (WPPPS Nuclear Project Nos. 1& 2), CLI 82-29, 16 NRC 1221, 1228-29 (1982).)
Applicant's Response to CASE Request For Production of Documents (June 27, 1986) and Motion for Protective Order, August 1, 1986.
Now. after slightly less than two years, Applicant's have taken the exact opposite position on the similarity of the issues in the two cases. As stated in their Motion for Reconsideration:
...it should be noted that there is no serious dis-agreement that many of the issues in the OL docket are substantially the same as those in the CPA docket."
Motion, at 2.
l Notwithstanding the Applicants' assertions regarding the issues in front of the Board, the central argument to both the Staff and the Applicant's Motion for Reconsideration is not similarity of issues, but rather preservation of hearing rights, efficiency, resource allocation, and the Fear of Delay- It is these arguments that CASC addresses below.
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I. 'lHE ALLEGED ADVERSE EPPECTS OF NOT COMBINING THE DOCKETS Neither the Applicanis or the NRC Staff raise any new arguments in their reconsideration requests. Both parties devote their briefs to the imagined and potentially disastrous consequences of not combining the operating license proceeding and the construction permit proceeding, which they apparently believe that the Board did not realize when it denied the request for consolidation.
For example, the Applicants state that "the Board failed to i
consider the serious potential delays and other adverse effects attendant to a schedule calling for consecutive rather than consolidated hearings." (Applicants' Motion, at 1-2). They cite as examples the following imagined horrors which will occur absent consolidation:
Under the circumstances present here, the resolution of the OL and the CPA issues in two separate hearings will result in procedural confusion and inevitaole and unnecessary delay,... (Id, at 4)
... serious substantive disputes (will erupt) over the extent to which matters that were addressed or should have been addressed in the OL docket can be relitigated in the CPA proceeding. (Id., at 4-5.)
! ... attempts to relitigate matters already encompassed within the OL..(Id., at 5.)
... interpretation of the scope of the single Contention j admitted in each separate docket will persist as a source of dispute between the parties. (Id.)
l The Board will be continually confronted by objections by all parties in both proceedings as to the scope of the proceedings and the relevancy of evidence. (Id.)
... separate hearings will strain the resources of all 1
parties and require the repetitive use of witnesses. (Id.)
... the delays attendant [on two hearings] could be substantial because of the time involved in conducting an l -s-
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additional round or ore-hearing procedures, resuming a ;
hearing and recalli" witnesses, filing proposed findings i and conclusions anc <riting a separate decision. (Id.) ,
Likewice, the Staff lists four alleged consequences of the l J
Boards' refusal to take affirmative action to consolidate the !
i operating license hearings and the construction permit hearings. ;
1 See, Staff's . Motion, at 2-3. Those consequences are summarized below as:
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- l. Unnecessary uncertainties concerning the status of a construction permit after it has been determined that an operating license should issue. ,
, 2. Evidence taken in a construction permit proceeding which j
follows an operating license proceeding creates a situation which could result in reopaning and relitigation of operating license issues; j
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- 3. The OL proceeding is turned into on-the record disecvery proceeding for the CPA proceeding; and l 4. Substantial delay will accompany the CPA proceeding.
Both the Applicants and the Staff argue that the consequences described above are in violation of the Commission's policy statement on the conduct of licensing proceedings.
Statement of Policy on Conduct of Licensing Proceedings, CLI 8, 13 NRC 452 (1981).
Similar arguments by both parties were made to the Commission and the U.S. Court of Appeals prior to the present hearing being established, and were rejected. Similar arguments were made in the first motions to consolidate the proceedings filed in March, 1988. CASE has already addressed the adverse consequences concern in its initial brief, and adopts herein by reference those arguments. However, in response to the
.beightened fearn of oppa ng parties CASE raakes the following ebee rvations on the potem. ial f or delav, the likelihood of coniusion, and possibility that CASC will get more "due process" than it is entitled to.
First, as to the issue of CASE achieving through the CPA process more than it is entitled to already, CASE asserts that
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the argument has no merit. CASE has no interest in abusing the CPA proceeding, or to utilize the OL hearing itself as a forum for discovery for the CPA proceeding. CPA discovery is still open and ongoing.
Additionally, CASE already has a substantial body of evidence which is in the record of the OL proceeding, and which the Applicants have never with?.cawn or explained that serves to nupport the first element of the CPA contention that management had an improper purpose in obtaining a delay for completing construction of Unit 1. Further, the evidence is quite clear that many of the mananers responsible for the condition of the plant and the improper purpose are still there, and/or TU has not repudiated old practices or policies. In addition, there is substantial new evidence available to CASE frcm those recently terminated or separated workers who have a window into the current management of the reinspection and corrective action activities that support CASE's contention that TU has not repudiated its past management attitudes toward regulatory conptiance and saf ety ve eus cost and ncheduling pressures.2/
Second, as to the i, ae of Deley, CASE, which has tne most
! lin ited resources (both time and money) of all parties has no interest in or motivation for delay. Since at least the early summer of 1984 CASE has been urging that all matters regarding the Comanche Peak plant be heard in as short a time as possible, as soon as possible, once and for all. Since summer of 1984 it
, has been the Applicants, followed by the Staff, that have repeatedly delayed all the proceedings, hearings, and serious courtroom confrontations over the ultimate issues in this case.
Applicants are now on their third generation of lawyers in this case, the second generation having never brought to hearing any of the dispositive issues. They are on the second mcjor architect / engineer, the second construction contractor, and the r
f ourth major desig.: reinspection and corrective action
- coatractor.
CASE, however, is still doing exactly what it set out to do a decade ago in the operating license hearings, and over two l years agc in the construction permit hearing, and has no
! intention of voluntarily changing its course or its speed to accommodate the unfounded fears of opposing counsel.
l Particularly where, as here, it is CASE that has the most to lose i
l should its scheduling views be inaccurate.
As the Board noted in its April 5, 1988, Order, it was l
r j 2/ See, CASE's April 15, 1988, letter to the Board enclosing t ,.
l Section 210 complaints against EBASCO, which name3, among otherc
! the involvement of C. Thomas Brandt.
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"explicitly not deciding :hether the CPA proceeding may become j :
aco: should construct ion i e completed bef ore the time for a hes: ing ar rives. " Order , at 2; and, as the Staff noted in its l
Motion for Reconsideration, the CPA case becomes moot after the l
- OL is granted. =
1 CASE does not want to have the issue become "moot by a
- default however, and asserts that none of the potential or i
] hypothetical concerns are persuasive enough to combine two i
distinctly different issues into one docket with the inherent forfeiture of rights that CASC faces in that situation. r CASE wants to create one record in the CPA docket, have one 4
hearing in the CPA docket, write separate proposed conclusions of
- lau and findings of fact, and handle the imminent appeals of the ;
t j Ci% issues separately. To do otherwise would turn the CPA issue
- E into just another OL contention, which it clearly is not. Yet !
i this is precisely the process that Applicants seoK to avoid, t 2
i Motion, at 5. !
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Finally, as to the concerns over procedural confusion, f i
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neither the Applicants nor the Staff offer any basis for their I fears that there will be procedural confusion. CASE asserts that
) there is none, and that this reconsideration motion is yet i i t another attempt to deprive CASE of its substantive procedural l
! rights, and guarantees of adequate time to prepare its case, by t I i "tarring and feathering" the intervenor with the standard [
l intervenor accusations. Such criticism is unfounded, !
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e unappreciated, and unnee- 2ary.3/ As discussed below CASE i c upports case manager.ent }rinciples in the CPA and the OL docket, ,
and is confident that those issee; can ce resolved, but opposes !
doing so by combining the trial and post-trial process for the f
l CPA issue. !
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It is ironic that CASE now finds itself in the position that i the Applicants asserted they were in during the fall of 1985, i when they sought directed certification to the Appeals Board in :
order to protect their substantive and procedural rights frou "procedural chaos" and an "incomprehensible record," when and if the case ever went to the Appeals Board. '
In fact, Applicant's current position in favor of consolidation is in direct opposition to their previcusly capoused position in opposition to consolidation of evidence from I i
the technical and harassment and intimidation dockets in the i earlier OL proceeding. (See, especially Applicants' November 4, !
1985, Petition for Directed Certification of Licensing Board i Order of October 31, 1985). Further, in Applicants' November 14, -
1985, Memorandum in Response To Appeal Board Order of November 8, 1985, Applicants argued against adoption of a position similar to ;
that they are now advocating regarding the two separate issuos in !
the OL proceeding, stating that no matter how articulated the procedures and rights of the parties i n the two dockets were, that the ccmbination of the two proceedings would "... lead to an I I l
3/ Comments such as "CASC...has had more than ample time to ,
determine the "mistakes" it believen were committed...," and CAS. i will attempt to relitigate "under the quise" of the CPA issues.
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unnecessarily confused a w complex trial and appellate record."
(Brief, at 3) 1~ Neither the Appliennts nor the Staff have raised the spectre i
of confusion, Delay, or abuse of process so strong that the Board 1
j should reverse itself and take away CASE's hard fought right to a ,
t separate hearing, separate decision, and separate appellate i process on the issues of management motive and repudiation.
II. THE BENEFITS OF CONSOLIDATION r l Both the Applicants and the Staff extol the numerous ,
benefits of consolidation, arguing in sum that consolidation will produce efficient proceedings, eliminate discovery and .
evidentiary disputes, insure that CASE doesr.'t abuse one proceeding in an attempt to take discovery it is not entitled to or_relitigate and reopen issues from the other proceeding once closed, or delay Unit I of Comanche Peak from going into j operation.
CASC supports in theory and practice the notion of
{ organized, efficient, and focused hearings. It has been CASE's
! experience in the OL proceedings that the best way to achieve c i
that type of focus to have a final position from the Applicant as to their affirmative case, to complete discovery into that
, affirmative case, to thereafter identify issues in dispute, write
] dispositive motions, and go to trial on those issues that remain [
4 i in dispute. ;
I In the CPA case the applicants have not yet taken their i affirmative position on the issues in dispute. Thus, it is a difficult to engage in su;>stantive discussion on ways to l o
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com.oliuate the evidence o be relied upon wherever possible, j lt has always been SC's position that much of the evidence un :he issue of past practices has already been developed. The Applicants have made no affirmative disclosures or statements other than that publicly available to CASE on which to base a final caso develcpment plant, i.e., no management repudiation
' statement, per se, has been made. No new management team has
] swept away the ghosts of past practices or patterns of pressure i
- to achieve scheduling and cost constraints, at the price of j quality. There is no new era in worker-management communications that is evident to CASC.
CASE anticipates that the CPA proceeding itself will provide the only forum for Applicants to either repudiate or adopt the past practices of TU management or continue to insist that nothing was ever wrong with management in the first place.
On the technical issues there are a number of viable options of the use of evidence gathered in one docket and applied to another docket, both as to the ultimate issue in the case and on the evidence developed in other docket.
CASE supports any meetings, discussions, working sessions, or any other similar undertaking in which the parties attempt to craf t a management program for the massive atuounts of evidence to be presented. In this proceeding such an undertaking was the backbone of the harassment and intimidation proceedings wherein lawyers representing all parties met over a series of weeks to work out procedures and process for the evidentiary deposi t icm that served as the record support for that docket. Only one l
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- t finot pre-nearing confel- ce was necessary in that cane, f
'Similar, and even u e2ter case management problems face all [
esutsel in this case. As discussed below, CASE respectfully f i
suggests that the best way to Foster the dialogue between the [
v parties on these issues is to deny the motion for reconsideration and require counsel for all parties to meet, talk, and suggest some case management salutions for those problems which are facing each of the parties.
III. CASE AGREES WITli APPLICANTS AND STAFF THAT EPPICIENCY AND EXPEDIENLlY ARE IMPORTANT CONSIDERATIONS IN DETERMINING SCllEDULING MATTERS.
CASE agrees with Applicants that, in reality, the CPA prceeeding should come first. It should have came in 1985 or 1986. We note that on August 1, 1988, the permit extension now being challenged will itself be up for renewal.
Ilowever, given the posture of the case at this stage, and the likelihood that the OL proceedings will themselves focus of the extent of the breakdown at Unit I of the Comanche Peak plant it seems most logical to CASE that the extent of the breakdown be conceded or determined before the effort is expended into proving that this occurred because of some improper purpose, and that the management that fostered the improper purpose has not yet been repudiated.
Like any case of this magnitude there are a number of case management approacheu whi.:h accomplish the same end. Two of those approaches are now before the Board in this Motion and Opposition for Reconsideration.
1 if counsel for all - irties were required to discuss the f
nanagement of the case, (* moved f rom the oral argumer.t advocacy
- utyje, and propose a variety of alternatives to each other and i
then to the Board for resolution CASE believes that an accommodation could be reached on many of the concerns r-ised by Applicants and Staff in these motions. L CASE respectfully proposes that such a discussion would be ,
most beneficial at the completion of discovery in the CPA and OL proceedings since the factual record will be closed and the !
evidence that all parties intend to rely on at the hearing will ;
be identified.
i IV. CASE REQUESTS THAT THE BOARD ISSUE ITS RULING ON THE !
THE PLEADINGS ON THIS MOTION, AND POSTPONE i THE MAY 11, 1988, PRE-HEARING CONPERENCE CASE does not believe that it is either necessary or f
desirable at this time to have proposed pre-hearing conference ;
i currently, but tentatively scheduled, for May 11, 1988. It is i CASC's position there is no need for oral argument on the consolidation issue either, since the Board would in effect be f
i attempting to serve as a mediator or arbitrator between two !
viewpoints on a matter that is, frankly, not pressing. ;
1 Although CASE believes that the presence of the Chairman i
might be beneficial at some stage of a working session it is our {
c position that May 11 is premature, and oral argument and a ruling will only inevitably lead to further delay as one party or the f
other attempts to seek interlocutory relieve on this matter. }
CASC believes that the Board has sufficient information nt ;
before it to rule on the Consolidation Reconsideration motions . t f i
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- t u d e:.,i r e u , and for t reasonu stated herein oppose oral 4re.uaent.4/
As discucced in recent filings CASE is simply not at the point in its hearing preparation to have an in depth discussion on possibly modifying the procedures agreed to in November, which are just now underway on some issues. Further, numerous new documents have been disclosed recently and more are anticipated.
CASE's representative is in discussions with Applicants and the NPC Staff on stipulations regarding some portions of 'ssues to be litigated. Finally, CASC is still awaiting the additional reports frcm CYCNA.
CONCLUSION CASC opposes the Motions for Reconsideration filed by the NRC Staff and the Applicant and urges the Board to deny the motions outright; in the alternative, CASE requests that the Board postpone ruling on the issue until the completion of discovery in the OL and CPA proceedings.
CASE also opposes a pre-hearing conference at this time, recognizing that the subject of the pre-hearing conference would be scheduling and case management propesals, as well as oral argument on this matter. The basis of CASE's onposition is that there is nothing to reconsider in the opposing parties briefs that was not raised earlier, and that the pre-hearing conference would oc costly, time-consuming and would delay CASE's being ablo 4/ CASC is concerned with the cost to all parties of a hearin<
limited to oral argument on consolidation, and suggests that funds would be better spent for a working session.
tv continue work which i essential.for CASC to reach any point where serious diccuacion: 2n ntipulations, case management and rectganization issues, can be substantively and productively addressed.
Respectfully submitted, (c' 'g -(a t c., /
Billie Pirner Garde Government Accountability Project Midwest Office 104 E. Wisconsin Ave.
Appleton, WI 54911 (414) 730-8533 Counsel for CASE c d u t .a. ,o b Gis Juantia Ellis 1426 S. Polk Street Dallas, TX 75224 (214) 946-9446 Co-Representative for CASE cc: Service List o *
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'/ M . A.; UTII.I TI CS ULUCTRIC ) Dochet Nos. 50-445h*fi'.6si s. 2, Ve v.,irl CU::P A N Y , ~e t. al. ) 50-446-OL BR A N%
(Cci unche pe'ak Steam Elect ric )
m a tion, Units 1 and 2) ) Docket No. 50-445-CPA
_Cl;RTLFICATH OF SERVICC By niy signature below, I horeby certify that true and correct copie:. of CASC'S RUSPONSM TO RECONSIDERATION REQUEST OF l.PRIL 5, 1988, BOARD ORDER DENYING CONSOLIDATION Have h o e r. cent to the nam"" listed below this 2nd day of May_ lu8H,
. .y : Fod e n.1 Exprens whero indicated by
- and First Class Mail a.:h> t u .
.J;inict;ative JuJge liner . Bloch J ack R. Newiaan , Esq.
U. F. . h el ea r Re;,a' at u r:. ro..alssion 14eunan & Hol t r i nge r , P .C.
4350 :.u.t/ West Ilir.hway . A t h Ploor 1615 L. St., N.W., Suite ll00 b e t he c c.a . Maryland 'i U J 1 . Washis.gton, D. C. 20036 Dr. Ker.neth A. McColl w Ms. Janice hoore, Esq.
1107 We:t Knapp Street Counsel for NP.C Staff Stillwater, Oklabona 74U75 office of the General Counsel U. S. Nuclear Regulatory Dr. Walter 11. , Jordan Cotr.ai s s io n 881 W. Outer Drivt. One White Flint North Dak Ridge, Tennessee 37830 11555 Rockville Pike Rockville, Maryland 20 52 Judge Elizabeth 3. Johnson Oak Ric;e National Laboratory Chaircan, Atomic Saf e ty and P. O. M:: X, Building 3500 Licensing board Panel Oak R g c, Tennessee 37U30 U. S. Nuclear Regulatory Con. mission Ds c ke :. u ..J Service '
in Washington, D. C. 20555 (3 a; ie .)
utiitc v. t i.s W: < Ch a i r a,.i n U. 4 .meleat D ;; u '. . i o s . uission Atowie Safety and Licenr.ior. "c
. .na.e ..p a , L. C. a;> Board Panel' U. S. f.uclear negulatory Cocaission Washington, U. C. 20555 1
fir . Robert A r t- i n Anthony Z. Roisman, Esq.
,' e ;inna 1 Ad:ai a i st ra*or , r 1 ion IV 1401 New York Ave., N.W. Suit-
- If S . Nuclear Reaulatory *emm. Washington, D.C. ;0005 611 Ryan Plaza Dr., suit -
1000
,irlington, TX 76011 Mr. llerman Alderman Staff Engineer Lanny A. Sinkin Advisory Committee for Reactor Christic Institute Safeguards ( MS-II-1016 )
1324 North Capitol Street U. S. Nuclear Pegulatory Comm.
Washington, D.C. 20002 Washington, D.C. 20555 Dr. David !!. Boltz Robert A. Wooldridge, Esq.
2012 S. Polk Wor s ha;n , Forsythe, Sampels Dallas, Texas 75224 & Wooldridge 2001 Bryan Tower, Suite 3200 William G. Counsil, Vice Pres. Dallas, Texas 75201 Texas Utilities Electric Co.
Skyway Tower Robert A. Jablon, Esq.
400 North Olive St., L.B. 81 Spiegel & McDiarmie Dallas, Texas 75201 1350 New York Ave., NW Washington, D.C. 20005-4798 (Mrs.) Juanita Ellis, Pres.
CASE (Citizens Association for Ms. Nancy li. Williams Sound Ener3y) Project Manager 1426 S. Polk Cygna Energy Services Dallas, Texas 75224 101 California Street, Suite lot San Francisco, CA 94111-5894 Mr. Chrisophcr I. Grimes, Director William 11. Burchette, Esq.
Comanche Peak Project Div. IIe r on , Burchette, Ruckort &
Office of Special Projects Rothwell U.S. Nuclear Reg. Comm. 1025 Thomas Jefferson St. NW, One White Flint North Suite 700 11555 Rockville Pike Washington, D.C. 20007 Rockville, Maryland 20852 Adjudicatory Pile (2 copies)
Assistant Director for Inspection Atomic Safety and Licensing Boar Programs Panel Docket Comanche Peak Project Division U.S. Nuclear Regulatory Comm.
U. S. Nuclear Regulatory Comm. Washington, D.C. 20555 P. O. Box 1029 Granbury, TX 76048 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Div.
P. O. Box 12548 Austin, TX 79711-7548 r ,
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dUlle Pirner Garde Government Accountability Proje 104 E. Wisconsin Avenue Appleton, WI 54911
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