ML20115J478

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First Supplemental Response to Joint Intervenors First Set of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence
ML20115J478
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/19/1985
From: Joiner J
GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:
Shared Package
ML20115J460 List:
References
OL, NUDOCS 8504230561
Download: ML20115J478 (20)
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Text

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F.LAIED CORRE.SPONDEf44

' April 19, 1985 00CMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 15 5M122 Mi:24 Before the Atomic Safety and Licensing Board 6FFICE GR SECRE3ni 00CKE T; fig & SEBV; .

SHANCd In the Matter of  :

GEORGIA POWER COMPANY, et al. : Docket Nos. 50-4240'

30-4250L-(Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

APPLICANTS' FIRST SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS On October 25, 1984, Joint Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy served upon Applicants by mail their First Set of Interroga-tories and Requests to Produce. The Applicants served the Joint Intervenors with their responses to those discovery requests on November 29, 1984. Applicants provide arein a supplemental response to interrogatory A-1(b) of the Inter-venors First Set of Interrogatories and Requests to Produce.

INTERROGATORY A-1(b)

SUPPLEMENTAL RESPONSE: (b) The Applicants supplement their prior response to interrogatory A-1(b) of the Inter-8504230561 850419 PDR ADOCK 05000424 Q PDR .

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O venors First Set of Interrogatories with the following information which briefly describes the educational and professional background of Dr. Morton Goldman.

Dr. Goldman graduated from New York University in 1948 with a B.S. degree in Civil Engineering. He subsequently attended the Massachusetts Institute of Technology and received the following additional degrees: in 1950 an M.S.

degree in Sanitary Engineering, in 1958 an M.S. in Nuclear Engineering, and in 1960 an Sc. D.

Dr. Goldman is a registered professional engineer in New York (1955), the District of Columbia (1965), Maryland (1972), Arizona (1974), California (1977), and South Caro-lina (1982). He is a member of the American Society of Civil Engineers, the American Nuclear Society, and the American Academy of Environmental Engineering.

Since his employment by NUS Corpor= tion in 1961, Dr. Goldman has held a series of positions from Technical Associate to Senior Vice President, Environmental Systems Group. He has performed and managed work in safety and environmental areas, including site selection and evalua-tion; safety analyses for commercial, military, and aero-space nuclear applications; waste management systems evaluations; environmental assessments; and impact analysis for nuclear and fossil fueled electric generating plants and

industrial facilities. In his current position as Senior ,

Vice President and Technical Director of NUS Corporation, Dr. Goldman has responsibility for auditing and guiding NUS Corporation's technical capabilities, serving as senior corporate spokesman on environmental and nuclear safety issues, and providing senior level consulting and project direction for different clients of NUS Corporation.

Prior to being employed by NUS Corporation, Dr. Goldman served eleven years with the U.S. Public Health Service,

- Division of Radiological Health. While with the USPHS he worked on a variety of assignments, including serving as a training instructor, conducting research on disposal of radioactive wastes-at ORNL and at MIT, participating in a working group responsible for radioactivity standards in the 1960 USPHS Drinking Water Standards, and providing technical I

consultation and assistance to state and federal agencies on health and safety problems of nuclear facilities.

Dr. Goldman has testified as an expert witness in a variety of proceedings. Between 1972 and 1975, he served as a consultant to and expert witness for the Consolidated Utility Group in the AEC/NRC rulemaking proceeding on "as low as practicable" radioactive waste discharge standards, i

and from'1975 to 1977 he acted as a consultant to and expert witness for the GESMO Utility Group in that same proceeding.

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He-was an expert witness for Duke Power Company concerning

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the Table S-3 radon issue in the Perkins' proceeding from 1979-through 1982.- On the. subsequent appeallof that issue he acted as an expert. witness for a. consolidated utility group. In addition, Dr. Goldman has appeared as an expert witness on environmental, issues in more than two dozen administrative-proceedings for nuclear and non-nuclear power

~ plants, including cooling tower environmental impact issues for the Trojan, Davis Besse, Perry, and Palo Verde electric generating plants.

Dr. Goldman has in the past served as U. S. representa-tive to and chairman of an IAEA expert panel on Radioactive Waste Management at Nuclear Power Plants, resulting in IAEA Safety Series No. 28 of that title. Currently Dr. Goldman' is chairman of the Atomic Industrial Forum Ad Hoc Committee on the Clean Air Act and is a member of the Steering Group, AIF Committee on-Environment and of the Standards Committee ANS-2 " Site Evaluation." He is also a member and the former chairman of the Nuclear Effects Committee, Environmental

' Engineering Division, ASCE.

_4-

o Respectfully submitted, J$ps E. Joiner, f.C.

ChW ies W. Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS &

TROWBRIDGE Counsel for Applicants DATED: April 19, 1985 i

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April 19, 1985 00tKETED

.9tPr UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 5 p 22 m! :2'4 Before the Atomic Safety and Licensing Board GFFICE OF 5ECREIA.

00CKETmG & SERVICI BRANCH In the Matter of  :

GEORGIA POWER COMPANY, et al. : Dccket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' First Supplemental Response to Intervenors' First Set of Interrogatories and Request for Production of Documents, dated April 19, 1985, were served upon those persons on the attached Service List by deposit in the United States Mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 19th day of April, 1985.

r J E. Joiner, .

Counsel for Applicants DATED: April 19, 1985

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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, )

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, Georgia 30306 Washington, D. C. 20555
  • Laurie Fowler & Vicki Breman i

, - 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, Georgia 30303 Dr. Oscar H. Paris

  • Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.

Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Bradley Jones, Esquire l

U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 i

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UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board S C In the Matter of:  : l

g j GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424 0FF!CE OF SECRETARY l
50-4 2 5tL-C0ChETl :g ,hjEN.i..

(Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, NORA DLUM, being duly sworn, hereby state that I am employed by Bechtel Power Corporation as Engineering Supervisor-Environmental. - -- - - - - -- -- -

The information reflected in the following interrogatory responses or parts of interrogatory responses:

(1) response B-37 (first paragraph) contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents, and (2) response B-8 contained in the Applicants' First Amended Response to Intervenors' Third Set of Interroga-l tories and Request for Production of Documents, is true and correct to the best of my knowledge, information, and belief.

M NORA BLUM Sworn to and subscribed "/"%g before me thisc4(M day ^^^^^ ~ ~

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of 9 W ,1 3 d , 1985. OFF M 2E d'~ ]

JOANNE E HENRY y , .. M '

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&f.D UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION . .

90CKETED USNRC Before the Atomic Safety and Licensing Board --

h N. N1 b In the Matter of:  :

GFFICE OF SECREit ET

GCCXETWG & SEiWICI.

GEORGIA POWER COMPANY, et al. : Docket Nos.54-424  ??.EF.

50-425 (Vogtle Electric Generating  :  ;

Plant, Units 1 and 2)  :

AFFIDAVIT I, WILLARD L. BOWERS, being duly sworn, hereby state

. _ . _ that I am employed by Alabama Power _ Company _as. Manager,_ . _ _ _

Environmental Compliance.

The information reflected in the following interroga-tory responses or parts of interrogatory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents:

B-2, B-4, B-9 (a) , B-12, B-18, B-31, B-37 (second paragraph),

and B-38 is true and correct to the best of my knowledge, information, and belief.

h&dWh WILLARD L. BOWERS

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Sworn to and subscribed before e this / d day of , 1985.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, DeCKETED

- USNRC Before the Atomic Safety and Licensing Board ..

p APR 22 N1:25 In the Matter of:  :

GFFICe OF SEC?ETAF:

r-eg GEORGIA POWER COMPANY, et al. : Docket Nos. 50-4I4 ['79G i;Ui!C'!t SEF /".2
50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, THOMAS W. CROSBY, being duly sworn, hereby state that I am employed by Bechtel Civil and Minerals, Inc. as Senior Geologist.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-3, B-5, B-ll, B-13 through B-17, B-19 through B-24, B-28 through B-30, and B-32 through B-36 is true and correct to the best of my knowledge, information, and belief.

.tk b.bh THOMAS W. CROSB Sworn to and subscribed before e this gh day of i ARe A , 1985. ,,,,,,,,,,,,,,,,,,,,,,,,,.,,,,,,,,,,,,,,,,,

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MAVIS M. LYNDE NOTau PU3UC-CAUFORNIA kkde Notary Public

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UNITED STATES OF AMERICA' ggCKETES NUCLEAR REGULATORY COMMISSION ,

USHRC BeforetheAtomicSafetyandLicensingBoark N In the Matter of:  : fg HG '

GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, C. R. FARRELL, being duly sworn, hereby state that I am. employed by Bechtel Civil and Minerals, Inc. as Senior Supervising Hydrogeologist.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-3, B-5, B-ll, B-13 through B-17, B-19 through B-24, B-28 through B-30, and B-32 through B-36 is true and correct to the best of my knowledge, information, and belief.

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j7L C. R. FARRELL Sworn to and subscribed before me this @h day of Ni? e_\-\ .

~, 1985.

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MAVIS M. LYNDE N01 2f PU3UC - CALIFORNIA Notary Public Q ..

on a Couun 0F SAN RANC5CO Mr Comehmen Egins Apil 241985 p ..

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CMETED

. USNRC Before the Atomic Safety and Licensing Bog &d h 22 si:25 r ncq re !ECRETARY In the Matter of  : E!CniT SG A SERVICf.

. '. .NICH GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, MORTON I. GOLDMAN, being duly sworn, hereby state that I am employed by NUS Corporation as Senior Vice Presi-dent and Technical Director.

The information reflected in the following interroga-tory responses:

(1) responses B-1, B-9 (b) , and'B-37 (2nd paragraph) contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents, (2) response B-49 contained in the Applicants' First Amended Response to Intervenors' Third Set of Interroga-tories and Request for Production of Documents, and (3) response A-1(b) contained in the Applicants' First Supplemental Response to Intervenors' First Set of Interrogatories and Request for Production of Documents,

is true and correct to the best of my knowledge, informa-tion, and belief.

Wo~rton I. 'Gbldman Sworn to and subscribed before me this f % day of /M , 1985.

At fHi am Notp y fublic f.

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' T UNITED STATES OF AMERICA SfgC NUCLEAR REGULATORY COMMISSION -

Before the Atomic Safety and Licensing Board CFFICE OF SECREifM In- the Matter of:  : 00CKETgjEFVL-GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, JOE L. LEAMON, being duly sworn, hereby state that I am employed by Southern Company Services, Inc. as Project Quality Assurance Engineer.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-6 (o) and (q) is true and correct to the best of my knowledge, information, and belief.

JOE L. LEAMON Sworn to and subscribed before me this h d day of // fore 4 , 1985.

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UNITED STATES OF AMERICA 7 NUCLEAR REGULATORY COMMISSION 90CKETED USHRC Before the Atomic Safety and Licensing Board

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15 IPR 22 Ni:25 In the Matter of:  : "-

GEORGIA POWER COMPANY, et al. iA Docket Nos. 50- gDF S{tCR[gvig{ 5

50-4 5 BRANCH (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

l AFFIDAVIT I, ROGER MOORE, being duly sworn, hereby state that I am employed by Georgia Power Company as Contracts and Support

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Manager.

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The information reflected in the following interroga-tory respon,se contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-6(r) is true and correct to the best of my knowledge, information, and belief.

OdiAd Ad// ~

ROGE OORE" --

Sworn to and subscr' bed befo e me this _. day o , 1985.

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GLwamaammeen UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION "tT4P Before the Atomic Safety and Licensing Board UNN3 In the Matter of:  :

CFFICE OF SECRETAR F GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424 00CKETg ERVICF.
50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, STEVE PHILLIPS, being duly sworn, hereby state that I am employed by_ Georgia. Power Company as_ Maintenance ,_

Supervisor.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-6(a) through (n), (v), (w), and (z) is true and correct to the best of my knowledge, informa-tion, and belief.

M-, M @ #p iAP Y STEVE PHILLIPS Sworn to and subscribed before me t is /2- day of Y?fo,p), , 1985.

ann $  ?/ o -> db j'

'Ndtary Public

..otary Put>Iic, Georgia, State a*. Larg-W Ounmiss;on Expires Oc:. 26,19a?

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OtCKETED USHRC Before the Atomic Safety and Licensing Board . . .

p WR 2231 f25 In the Matter of:  :

GEORGIA POWER COMPANY, et al. E -

Docket Nos. 50 C

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, JOSEPH R. SCHULTIES, being duly sworn, hereby state that I am employed by Westinghouse Electric Corporation as Lead Engineer for Steam Generator Evaluation, Reactor Coolant System Components Licensing, Nuclear Technology Division.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-45 through B-47 is true and correct to the best of my knowledge, information, and belief.

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  • D QSEPHR. SCHULTIES  ;

Sworn to and subscribed before me this 7%A day of V h - , 1985.

O Was %f.f fTotary Public '

LORRAINE M. PIPLICA. NOTARY PUBLIC MONROEVILLE BORD. ALLECliENY COUNTY ,

NY COMMl!SION EXPIRES DEC 14.1987 Member. Pen 1sylvania Association of Notaries

M_. TEDCORRESPQWEME UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Detg,TED Before the Atomic Safety and Licensing Board

, g gg In the Matter of:  : OFFICE OF SECRETAB

00CKETING & SERviCL GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424 BRANCH
50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, DANIEL H. WARREN, being duly sworn, hereby state that I am employed by Southern Company Services, Inc. as Environmental Licensing Engineer.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-10 and B-50 is true and correct to-the best of my knowledge, information, and belief.

0Y DANIEL H. WARREN

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Sworn to and subscrit ,

before me this / 4 da; of M , 1985.

Not&ty Public U

UNITED STATES OF AMERICA asunsoW NUCLEAR REGULATORY COMMISSION DOCMETED USNRC Before the Atomic Safety and Licensing Board 15 APR 22 N1:25 In the Matter of:  :

OFFIC 0F SECRETA" GEORGIA POWER COMPANY, et al. Docket Nos. W m DOCK g g ERVICl.

(Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, JOHN WHELESS, being duly sworn, hereby state that I am employed by Southern Company Services, Inc. as Nuclear Projects Engineer.

. The information reflected in the following interroga-tory response contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for 4

Production of Documents: B-6 (u) is true and correct to the best of my knowledge, information, and belief.

J N WHELESS Sworn to and subscribed before me this s7// day of d/m- , 1985.

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..lJ N6tary Pul2iic My Commission Expires November 27.1988

atELATED 6 UNITED STATES Or AMERICA NUCLEAR REGULATORY COMMISSION 00CMETED USNRC Before the Atomic Safety and Licensing Board

'85 APR 22 N1:25 In the Matter of:  :

0FFICE OF SECRETAR r GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424 00CKETING & SEftvlCf

50-425 BRANCH (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, L. R. WEST, being duly sworn, hereby state that I am employed by Bechtel Civil and Minerals, Inc. as Senior Supervising Hydrogeologist.

The information reflected in the following interroga-tory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-3, B-5, B-ll, B-13 through B-17, B-19 through B-24, B-28 through B-30, and B-32 through B-36 is true and correct to the best of my knowledge, information, and belief.

/ i- >-z W. R. WE Sworn to and sub ribed h

before me this ') day of pap M , 1985.

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"%.c MAVIS M. LYNDE NOTGY PU30C-CAUFWu W & C M 0Fseps Rl"Q:C0 r Apr126,1933 , ,

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MLATEDN UNITED STATES OF AMERICA 00CKgTED U

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boar e OF SECRETAP In the Matter of: C(T }ERVIC1.

GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, PING WONG, being duly sworn, hereby state that I am employed by Bechtel Power Corporation as Mechanical Engineer.

The information reflected in the following interrogatory responses contained in the Applicants' Response to Intervenors' Third Set of Interrogatories and Request for Production of Documents: B-6(t) and (y) is true and correct to the best of my knowledge, information, and belief.

Y Sing y ng m Sworn to and subscribed before me this ' 7 # day of)//f teI , 1985.

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/c 2 w Not Public i

OFFICIAL SEAL '

l NANCY A GETMAN l NOTARf PUDUC - CAUFORNIA ,

< LOS ANGELES COUNTY

< Wr gunsL usires GCT 1,1988

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