ML20107K714

Third Set of Interrogatories to Applicant & Request to Produce Re Credibility.Certificate of Svc Encl.Related Correspondence

ML20107K714
Person / Time
Site:	Comanche Peak
Issue date:	02/25/1985
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#185-782 OL, NUDOCS 8502280379
Download: ML20107K714 (10)

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,3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ._

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l ,

Docket No F9 IS S

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TEXAS UTILITIES ELECTRIC 1  !

t COMPANY, et al. l '

l (Application for' an, l (Comanche Peak Steam Electric Operating License)~,

Station, Units 1 and 2) - - - ' - -m CASE'S THIRD SET OF INTERROCATORIES TO APPLICANTS AND REQUESTS TO PRODUCE RE: CREDIBILITY Pursuant to the Board's 12/18/84 MEMORANDUM (Reopening Discovery; Misleading Statement) (pages 9 and 10), CASE (Citizens Association for Sound Energy), Intervenor herein, files this, its Third Set of Interrogatories to Applicants and Requests to Produce Ret Credibility.

This is the third of several such requests which CASE intends to file under this Board Memorandum.

Please answer the following interrogatories and requests for documents ,

in the manner set forth herewith: ,

1. Each interrogatory should be answered fully in writing, under oath or affirmation. ,

2. Each interrogatory or document response should include all pertinent information known to Applicants, their of ficerr,,

directors, or employees, their agents, advisors, or counsel.

Employees is to be construed in the broad sense of the word, including specifically, Brown and Root, Gibbs & Hill, Ebasco, Cygna, O. B. Cannon, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.

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3. The term " documents" shall be construed in the bro'ad sense of the

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' word'and shall include any writings, drawings, gra'phs, charts, ., , ~ p 6 N>

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photographs, reports, studies, aud'its, slides, internal memoranda, - sc.- 4

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- informal notes, handwritten notes, tape recordings, procedures,. .

specifications, calculations, analyses,andanyoL[erdata-3 compilationsfromwhichinformationcanbeobtaine[d. - ,

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4. Each document provided should include a sworn statement of, its, _

authenticity.

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5. Answer each interrogatory in the order in which it: is asked,

• 0, 4m1 numbered to correspond to the number of the interrogatory.. Do not -

combine answers.

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6. Identify the person providing each answer, rerpons'e, or document 7 L,..- '.

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7. These interrogatories and requests for documents shall be 7 ..

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continuing in nature, pursuant to 10 CFR 2.740(e) and the past -

directives of the Licensing Board. Because of the, time a:

restrictions under which we are presently working. ,we request that , ,  ; .3 i.

supplementation be made on an expedited basis. . - --

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8. For each item supplied in response to a request fo'r documents, identify it by the specific question number to whi[ch it is in _

response. If the ite.n is excerpted from a documment, identify it also by the name of the document. Please also pr~I ide'the copies ,

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in the correct order (rather than in reverse order,).

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7 CASE'S INTERROGATORIES TO APPLICANTS AND REQUESTS TO PRODUCE

1. Please provide a copy of each and every . audit, report of audit findings, memoranda, and other compilations of information (from any and all sources) for the document control program which have ever been done regarding the document control program, document control center, or other document control-related activities at Comanche Peak.

2. Picase provide a copy of all responses and follow-ups to such documents for inspection and copying.

3. Please provide for inspection and copying all notes, memoranda, and other compilations of information documenting interviews with audit, superisory, or managerial personnel concerning the firings of Ms. Dobic Hatley, Ms. Billie Orr, and Ms. Meddie Gregory. (This information should include all information leading up each firing, and subsequent to each firing.)

4. Picase provide for inspection and copying all notes, memoranda, and

• other compilations of information documenting interviews with Phyllis Wells (head of audit team at the time of Ms. Hatley's termination) and Joan Swain (assistant head of audit team at the time of Ms. Hatley's termination) with Mr. Frand Strand regarding Ms. Hatley's work as super-visor of the satellite.

5. Picase provide for inspection and copying all notes, memoranda, and other compilations of information documenting interviews with Edie Hudson, Jim Tate, and Janice Day (workers in the 306 satellite section at the time of Ms. Hatley's termination) with Frank Strand regarding Ms. Haticy's work as supervisor of the satellite.

6. Please provide for inspection and copying all notes, memoranda and other compilations of information documenting interviews with Kay Norman and Pam Parker (both auditors with the audit team at the time of Ms.

Hatley's term'ination) with Mr. Frank Strand regarding Ms. Hatley's work as supervisor of the satellite.

7. Please provide for inspection and copying all daily reports provided to Mr. Frank Strand for the months of January and February, 1984 which log phone requests from satellite 306 into the phone bank regarding design changes. (Also provide this information for all other satellites for the same time period.)

8. Picase provide a copy of the memorandum from Frank Strand sometime during the end of January, 1984 requesting an audit of the design change log for satellite 306, as well as all follow-ups and responses to that request.

9. PicaseprovideacopyofthecompletE"abSii(includingallassociated memoranda and other compilations of ihformac' ion) which resultad from this request (see Interrogatory #8 above.)

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10. Please provide a complete copy of all audits conducted during January, 1984 on any phase of document control, including, but not limited to .

the satellites. (Include all associated memoranda, responses, follow- , . _ . . .

ups, and other compilations of information with the audit itself.).

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11. Please provide a copy of all responses'and follow-ups, including memor,- p.m3.,

anda and other compilations of information, etc. for the package audit a. : .u . m provided in response to Interrogatory #8 on the preceding page. -(Include n , .3,,g N with your response, copies of each and every daily update on the ongoingi~. 2 , . n audit which was provided to Mr. Frank Strand.) -

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12.~ Please provide a copy of all notds, memoranda, reports,Ietc. concerning yinw peow the meeting between Mr. Frank Strand and Mr. Boyce Grier concerning Ms. th -.t.;4 ~

Hatley's termination. (This refers to compilations of information by n~1,' c, Mr. Strand.) .

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13. Please provide a copy of each and every follow-up invest.gation by Mr:, m ,, m ,

Grier or any of TUGCO's, TU's, or TUSI's personnel concerning Ms. c e;.x u ;,,

Hatley's termination. Include with your response all memoranda, notes, ....

and other compilations of information along with any formal reports. .- .x ;

14. Please provide complete copies of each and every tape recording, trans.- "

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script of each and every tape recording, and notes of each and every .,_

tape recording of the meeting (s)'between interviews with employees t . .. . r. fi.

in satellite 336 and Mr. Frank Strand, other Brown & Root supervisors t. t .3 u . ;, q, or managers, TU/TUSI/TUGC0 supervisory personnel and/or attorneys concern

• rouaa.;,n ,1 ing the work of the satellite and/or Ms. Hatley's work and/or termination.,.. s.2 ..r.

15. Please provide a copy of all stop-work orders issued for any phaseo 'f , et uef net m work at Comanche Peak from September, 1983 to date. -

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16. Please' provide for inspection and copying all associated documentatiott C 2 %lpr,7 (including, but not limited to, memoranda, notes, and dther compilations :ac;u.,m,,,;

of information, responses, and follow-ups) to the information provided 3 c, I..; w.c.2 d in response to Interrogatory #15!above. j ,. , ..hCre:igmy

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17. Please provide for inspection and copying all reports, memoranda, audits,y'.c w j.

and all associated compilations of infonnation regarding documentation. aad ni w .

control center computer shutdowns from September,1983 through January,. ca.: pi,. ,m 1984. (Include with your response '

copies of all follow-ups, responses, w. er etc.) - iii. )

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18. Please provide a complete copy of NCR M-83-3049, including all revisipps,yt,w ,,..,,t a for inspection and copying. (Please include all associated documentation.). .a .,p , N

19. Please provide a complete copy of TCP-84 audit, including all associated a: . . . . . . n, responses,. follow-ups, memoranda and associated documentation for inspec , <

tion and copying. l

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20. . Please provide ~a complete copy of NCR M-83-01629 (dated 6/14/83), .induding a.m pcov all revisions and associated documentation (including but not limited to all . ce biu i.$ .

memoranda, 50,55(e) reports, etc.) for inspection and copying. . .. ~ r.m, . a , ,

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21. Please provide for inspection and copying a complete copy of NCR M-84-00082 dated 1/10/84, including all revisions and associated documentation (notes, memoranda, reports, 50.55 (c) reports, etc.).

22. Please provide for inspection and copying all follow-ups, responses, reports, memoranda, etc. concerning QAr #0003.

23. Please provide for inspection and copying all responses, correspondence, memoranda, notes and attachments to same provided to Mr. Eisenhut by

' TUGCO/TUSI/TU in response to BN 84-085.

Please provide for inspection and copying all' investigations, reports, 24.

notes, memoranda, and associated documentation developed in the course of Mr. S. Hartman's investigation of Ms. Hatley's version of how she obtained a copy of a list of documentation furnished in advance to Cynga personnel to Hayward Hutchinson.

25. Please provide for inspection and copying a complete copy of SDAR CP-84-01 including all revisions and associated documentation (notes, memoranda, reports, 50.55 (e) reports, etc.).

26. Please provide for inspection and ccpying each and every memorandum, notes, compilation of information and associated reports and documentation developed by Bob Spangler (or 5y his personnel) and documentation special-ists working from John Merrit .'s staff in response to Ms. Hatley's alle-gations as stated in BN-84-035.

27. Please provide for inspection and copying a complete copy of procedure DCP-3 (all revisions and associated documentation).

28. Please provide for inspection and copying all procedures (and all revisions to each and every procedure plus all associated documentation for each revision to each procedure) relating to the document control procedures for the paper-flow groups for the building task forces, beginning in December, 1983 through the present.

29. Please provide a complete copy of the memorandum #35-1195, dated 2/7/84 to Ray Yockey from H.A. Hutchinson/F.M. Strand re " Termination of Dobie Hatley (Badge B-993)". (This is a Brown & Root memo.)

30. Please provide a complete copy of the Memorandum for Record dated 2/7/84 the subject of which is " Termination of Dora D. (Dobie) Hatley" signed by Ray Yockey, Manager, Personnel Services. (Those present were: D.C.

Frankum, Ray Yockey, H. H. Hutchinson, and Dobie 'Intley.)

1 31. Please provide a complete copy of TUGC0 Office Memorandum CQA-001, to B. C. Scott from A. Vega, TUCCO Site QA Manager, dated June 13, 1984, on " Questions Arising from Investige.tions into D. Hatley Allegations."

32. Please provide a complete copy of TUGC0 Office Memorandum QIQ-766 dated June 14, 1984 to D. N. Chapman from R.G. Spangler on " Board Notifica-tion 84-085".

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33. Please provide a complate copy of TUGC0 Office Memorandum QAI #0003 to

" Distribution" re " Request for Assistance in Resolving Quality Assurance' Allegations". (This refers to an investigation requested by Boyce Grier on 2/9/84.)

34. Please provide a complete copy of the TUCCO Office Memorandum dated February 24, 1984 to A. Vega from Boyce H. Grier re " Allegations of Dobie Hatley".

35. Please provide a complete copy of the " attachment" noted at the close of'the two-page memorandum provided in response to Interrogatory #34 above. (" Attachment" appears right above cc: D.N. Chapman, R. G. Tolson.)

36. Picase provide a complete copy of the TUGC0 Office Memorandum dated May 22, 1984 to Michael D. Spence from D. N. Chapman re "Dobie Hatley Allegations".

" 37. . Please provide a complete copy of the TUGC0 Office Memorandum dated April 9, 1984 to Mr. David Chapman from David L. Andrews, Director of Corporate Security re " Response - Request for Investigative Assis-tance Regarding Allegations by Ms. Dobie Hatley".

38. Please provide complete copies of the books which were the personal property of Ms. Dobie Hatley, which Applicant or its attorneys presented to her during one of her depositions (sometime during the summer of 1984), but which Applicant or its attorneys have not */et returned to her.

Also, return the original books to Ms. Hatley.

39. If there are other documents (under the broad definition on page 2, item 3, of this pleading) which pertain or are relevant to questions 1 through

-38 preceding, supply them also.

40. Provide copies of the time cards or sheets (whatever record is kept on the time specific individuals worked) for all individuals who worked in the satellites at any time on 10/24/83 or in the morning on 10/25/87 up till the time Cygna came to review the~ information they had requested in their list .

41. Specifically what information was supplied to Cygna as a result of their supplying the list or which was listed by Cygna? Supply copies of all such information. -

42. At the time Cygna came on site in October 1983, were the document control center and the satellites the only ones who had control stamps showing i that documents were controlled?

If-the answer is no, provide complete details as to specifically who (specific name, title, organization) else had control stamps, how such control stamps were being used, any audits or investigations , etc. ,

which were made of such use, and all documents (as defined on page 2, item 3, of this pleading) regarding such use, investigation, etc.Give complete details, including whether or not deficiency paper was generated regarding such unauthorized use.

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l Is it Applicants' intention to put design change information for the site 43.

drawings on the computer rather than being handled manually? If so, has this been done? If it is planned but has not been completed, .what is the current status and when is it expected that it will be completed?

44. Is it Applicants' intention to put all design change Laformation (for site drawings and vendor drawings as well) on the computer rather than its being . handled manually? If so, has this been done? If it is planned but has not been completed, what is the current status and when is it expected that it will be completed?

45. Why'was the decision made to put design changes into the computer rather than being handled by hand? Why switch frcxn manual to computer? More specifically, was it because of problems in the manual system?

46. Who specifically (name, title , organization) inputs information into  ;

the computer regarding design changes? Indicate whether each such 1 individual inputs such information directly by actually typing it in l

or if each such individual provides the information to be input to someone else who then types it in. Include the name , title, and organization of all individuals who type in information provided by someone else as well. Also indicate which of thse individuals are with DCTG.

47. Are any of the individuals in the satellite system inputing information into the computer? If so, indicate in answer 46 which individuals are in the satellite system and exactly what their function is in the satellite system.

48. Provide documentation of the training regarding the use of computers each individual listed in answers 46 and 47 has had including the date of all such training, the specific types of training received, who taught each such individual and the qualifications of each such teacher to teach the use of the particular computer used at Comanche Peak (include the name, title, and organization of each such teacher) .

49. Do any of the computers used in the satellite systcm capable of having information input into them? If so, give specific and complete details, including but not limited to: which satellites have *.his capability, who (specifically name, title, and organization) has access to such computers, the purpose of such use by each such satellite, etc. ~

Include also whether or not each such computer has the capability for erasing information.

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50. If the information following has not already been supplied in response to other questions asked in the preceding, provide it now: Provide all documents (in the broad sense, as set forth on page ;, item 3, of this pleading) which have to do with any discussions, investigations, meetings, or other efforts to ascertain what happened regarding the list supplied by Cygna, the state of the satellites and the satellite system (whether or not it was functioning correctly, whether or not there were problems, what such problems were, to investigate allegations, the audit referred to by Heyward Hutchison at Tr. 9657/17, the rape recordings (and any others) referred to by Heyward Hutchison at Tr. 9666/20-9668/5, etc.),

any any other information which is relevant to any of the matters discussed in questions 1-50 of this pleading.

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51. Provide copies of all procedures which relate to any of the questions 50 asked in the preceding. Provide the original and all revisions.

52. Who "(name , title, organization) had access to input information into the cmputer at the time of the Cygna audit (10/24/83)? Who (name , title, organization) has access to input inforpation into the computer at this

' time? Provide copies of-all procedures which relate to this (original and all revisions) .

5 3. - Is access to the computer a controlled job? Supply documentation if the answer is yes.-

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54. Is Caroline Redding still the supervisor of the Computer Operations Group?

If not, who has been and is currently the supervisor? If_not, why did Ms. Redding quit or was she terminated? Supply documentation, such as termination slip, counseling report, and any other relevant documents.

If Ms. Redding Is no longer at the plant, supply her last know address and telephone number.

' 55. Provide the names, titles, and organizations of all individuals who were in the Design Change Tracking Group (DCTG) as of 10/24/837 At thin time?

56. ' Was there ever an investigation done by the NRC Office of Investigation or any other NRC organization into the matter of prenotific'ation of Cygna, potential problems with' the satellites or the satellite system -(other than the_NRC Technical Review Team)? If the answer is yes, supply all documents (in the broad sense of the word, as defined on page 2, item 3, of this pleading) relevant to' such investigation (s) .

d 7. Who (names, titles , and organizations) knew about or has now found out about the secret audit performed by Brown & Root just prior to the firing 2/7/84 of Dobie Hatley regarding the satellites and/or the satellite system?

Give complete specific details including when and how each such person found out about such audit. -

58. CAS2 believes Applicants should supply answers to all the questions, and all the documents requested herein, as well as the depositions of Heyward Hutchison on 2/11/85 and Frank Strand on 2/12/85 in the Dobie Hatley DOL hearing, to the Licensing Board as a Board Notification of new and significant information. Will Applicants agree to do this?

- Respectfully submitted, ,

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%.).JuanitaEllis,P' resident.

CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 8

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UNITED STATES OF AMERICA .. ...;

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/BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD) .~rjv.;cate l

'j f 4 :y .s ;cyM 1 n the' Matter of }{ i , , f '4 $6$., y "a

}{ l TEXAS! UTILITIES ELECTRIC. '} { Docket Nos. 50-445-1 . '7'-

and 50-446-1 - '* cm.M. v:Ji

' COMPANY,.et al. }{ >

'(Comanche ~PHk7 team Electric }{ _ m.f. , .,. : 1_.. , '

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CERTIFICATE OF SERVICE -

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-By my signature below, I hereby certify that true and correct copies'of CASE's Third Set of Interrogatories to Applicants and Requests to Produce; - w - w Re: . Credibility . .- a- ,

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o ' have been sent tc the naces listed below this 25th day of ' February!,198[,, ' ,( ((k ,

.by: . Express Mail where indicated by

• and First Class Mail elsewhere.1 ' ; t .- --#*a

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• Administrative Judge Peter B. Bloch

• Nichol'as S..Reynolds, Esq.; .

U. S. Nuclear Regulatory Commission Bishop,.Liberman, Cook, Purcell- 2 4350 Ea'st/ West Highway, 4th Floor & Reynolds "c Bethesda,-Maryland 20814 1200'- 17th St., N. W. .

Washington, D.C. ,~20036j ..

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• Judge Elizabeth B.' Johnson

1. i . C. w- 4

' Oak Ridge National Laboratory

• Geary S. Mizuno, Esq..

P. O. Box X, Ev.11 ding 3500- Office of Executive Legal Oak Ridge,iTennessee 37830 Director U. S. Nuclear Regulatory

• Dr. Kenneth A. McColloa, Dean Commission .

Division of Engineering, Maryland National Bank Bldg.

Architecture and Technology - Room 10105 -- -

Oklahoma State. University 7735 Old Georgetown Road. ... . ..

'Stillwater,' Oklahoma 74074 Bethesda, !!aryland 20814

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing '

881 W. Outer Drive Board Panel ' i

' Oak Ridge, Tennessee 37830 U. S. Nuclear Regdlatory Commission '

f Washington, D. C. 20555 r

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Chairman Renea Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General ,_ . .. .

Board Panel Environmental Protection Division a.. i n.1 U. S. Nuclear Regulatory Commission Supreme Court Building -

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Washington, D. C. 20555 Austin, Texas 78711 -- -.3, b-.

Mr. Robert Martin Anthony Z. Roissan,iEsq. '

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Regional Administrator, Region IV Trial Lawyers for Public Justice - . .

U. S. Nuclear Regulatory Co= mission 2000 P Street, N. W., Suite 611 . .

611 Ryan Plaza Dr., Suite 1000 Washington, D. C. 20036 L;;

Arlington, Texas 76011 2' ~; ; . ;n I

Mr. Owen S. Merrill!

Staff Engineer  ! - ,

Lanny A. Sinkin .. .

3022 Porter St., N. W., 6304 Advicory Committee for Reactor Washington, D. C. 20008 Safeguards (MS H-1016) .3.. ,

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. David 11. Bolt: **

2012 S. Polk ,

Dallas, Texas 75224 ., * .a s -

t Michael D. Spence, President Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B. 81 Dallas, Texas 75201 Docketing and Service Section (3 copies) 1

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Office of the Secretary ,

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l.

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/.s.) Juanita Ellis, President ASE (Citizens Association for Sound Ene*gy) 1426 S. Polk Dallas, Texas 75224

,' 214/946-9446 ,

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