ML20137X161

Affidavit of P Chang Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to mid-1985.Related Correspondence

ML20137X161
Person / Time
Site:	Comanche Peak
Issue date:	12/02/1985
From:	Chang P BLACK & VEATCH
To:
Shared Package
ML20137W974	List: ML20137W969 ML20137W997 ML20137X020 ML20137X060 ML20137X088 ML20137X129 ML20137X161 ML20137X183 ML20137X210
References
OL, OL-2, NUDOCS 8512100424
Download: ML20137X161 (2)

Text

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AFFIDAVIT OF PETER CHANG THE STATE OF e r+s  :

COUNTY OF Se-e*/eu c  :

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BEFORE ME, the undersigned authority, a Notary Public in and for 5a=m-vecc County, Texas, on this day personally appeared PETER CHANG, who by me being duly sworn upon his oath deposes and says:

My name is Peter Chang. I am presently employed by Black & Veatch, Inc. in the Civil Engineering Group at Comanche Peak. In 1978 J was employed by Black

& Veatch in Kansas City. I began working at the Comanche Peak site.in March, 1981. In December, 1984 I was in the Pipe Support Engineering group.

==.

I first became aware of the MAC report from the newspapers in mid 1985. Prior to that time, I did not know that Management Analysis Company ("MAC") had conducted

'a review of the Comanche Peak project. I have never-seen or read their report and did not participate in any discussions regarding whether the MAC report should be produced in response to the discovery request by the Intervenor, CASE, in the Comanche Peak licensing proceeding.

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SUBSCRIBED AND SWORN TO before me by the said PETER CHANG on this, the r */ day of Dece-s m , 1985.

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