there are several source edit/change tools that could do this rather simply...fileaid, ispf/rexx, and even a batch sort (icesort or syncsort) come to mind.
Try this ISPF command to comment 2000 lines of COBOL code.
1. In the first line give .a in the line number area. (To label it as line number 1)
2. In the last line give .b in the line number area. (To label it as last line)
3. Give the following command in the command line.
Alternatively, make the point 3 as a REXX edit macro and run it.
Post if you have any questions. Arun.