,,Case 1:98-cv-00126-JFM
Alan Brownstein
Washington, D.
Document 840-8
Filed 07/07/2004
Page 1 of 25
June 14, 2002
Page 342
this document would be consistent with that is a
mischaracterization.
BY MR. STOUCK
Let me just ask this, is that true, that
DOE had made the decision to reject Yankee
before the meeting was held?
I don t think that
s position
I s a fair statement.
mean the purpose of the meeting was to hear what they
had to say and we were going to listen to
it.
And
perhaps there was something that we hadn' t considered
or known before.
We were trying to do what the
contract said. contract.
We were trying to implement the
To the extent that they could not bring to
our attention any information that was new or different, we objected to the position outright to
the extent that we were implementing the contract as
we understood
it. So I think that I s a
enough.
little
different characterization.
That I S fair
The next paragraph,
first sentence, says, DOE urged us to swap delivery
schedules with other contract holders as the most
equi table way for achieving accelerated
Do you see that?
deliveries.
Yes.
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-8
Washington , D.
Filed 07/07/2004
Page 2 of 25
June 14, 2002
Page 343
And is that an accurate report of one of
the things DOE said?
MR . CRAWFORD:
Same obj ection as I had
before.
THE WITNESS:
Urge is a little
subjective.
We certainly made it clear that the contract which
they were party to gave them the right to exchange
approved DCSs of which they can achieve their
obj ecti ves.
We wanted to make sure that they were
aware of that and, you know, we saw that as a way
that all parties could benefit.
So, you know, we
made them aware, I think we encouraged -- I don'
know if there
I s a difference between encouraged and
urged. But meeting.
we certainly discussed that at the
BY MR. STOUCK:
Encouraged swaps as a way -- as a possible
way of helping Yankee achieve its obj ecti
ve?
Yes, that'
s true.
MR . CRAWFORD :
Let me just state for the
record, okay,
if it is your intent to proceed in this
same fashion through this
document, I'
m going to
obj ect to best evidence because we have before us
Exhibits 96 and 97, two different memos reflecting
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-8
Washington , D.
Filed 07/07/2004
Page 3 of 25
June 14, 2002
Page 440
have been correct had that said ACR instead of
contract.
MR . STOUCK :
Mr. Browns tein, you are done
for today subj ect
to what I just told
you.
THE WITNESS:
MR . CRAWFORD :
Thank you.
We I 11
reserve any further
questioning of the witne&s until the time of
(Discussion off the record.
MR . CRAWFORD :
trial.
I will reserve the right to
ask questions should Mr. Stouck succeed as he states
that he intends to do in getting Mr. Brownstein
before him again.
But I will say that we will oppose
that.
MR.
STOUCK:
Okay.
3: 30
Good.
Thanks
a lot.
(Where upon,
m., the takin~ 0
the instant deposition ceased.
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
of
&;wJ;
day
t/17e
20111::
NOTARY PUBLIC
My Commission expires:
~;f 1/0 b
Alderson Reporting Company, Inc.
1111 14th Street , N. W~uite 400 1- 800-FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 JF: ER~ . fA SHEET FOR THE TRANSCRIF Notice Date: June 17, 2002 Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 987 4C Dep. Date: June 14 , 2002 Deponent: Alan Brownstein Washington DC
Page 4 of 25
Place: 4269-45
Ref. No.
CORRECTIONS:
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Should Read
Reasons Therefore
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Signature of Deponent
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 5 of 25
EXHIBIT
"""
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Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 6 of 25
a. , ,~.
J.
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X
YANKEE ATOMIC ELECTRIC
COMPANY,
Plaintiff,
THE UNITED STATES,
Case No. 98-126C
Senior Judge
Merow
Defendant,
- X
Washington ,
D,
Wednesday, April 21
1999
Deposition of NANCY H, SLATER , a
witness herein,
pursuant to
called for examination by
counsel
for Plaintiff in the above-entitled
matter,
agreement, the wi tness
being duly
sworn by JAN A, WILLIAMS, a Notary Public in and
for the District of Columbia, taken a t
offices
the
Street,
Spriggs & Hollingsworth 1350 I N, W" Washington, D. C" at 10:10 a,
1999, and the proceedings
Wednesday, April 21
being taken down by Stenotype by JAN A, WILLIAMS,
RPR , and transcribed under her
direction.
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W, 4th FLOOR / WASHINGTON ,
D.
C., 20005
-=:..:;;.
-..
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 7 of 25
Whereupon,
NANCY H, SLATER
was called as a witness by
counsel
for
Plaintiff
and having been duly sworn by
was examined and testified as
the Notary Public, follows:
EXAMINATION BY COUNSEL
FOR PLAINTIFF
BY MR,
1 0
SHAPIRO:
for
Would you state your name
the
record, please,
Nancy H, Slater, Ms. Slater , my name
we'
re here for
is Robert Shapiro,
your deposition,
before?
Have you ever
had your deposition taken
No,
Do you have some understanding
what' s going to happen today? Yes.
What do you understand is going to
happen today?
I understand that I'
2 3
m going to be a
factual deponent and that you
re interested in
24
2 5
asking me questions about my knowledge of the
waste acceptance area during the time I was in
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR! WASHINGTON, D.
, 20005
---..
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 8 of 25
waste acceptance.
And let me
tell
you
just briefly
ll be asking
procedurally how it will work,
you a series of questions and you will be
expected to answer the questions,
As we
discussed even before we went on the record,
court reporter is taking everything down and
the
'll get a written transcript of everything
that'
1 0
s said
today,
Do you understand that?
Yes,
And it
will also be helpful for the
court reporter' s
purposes so we get a clean
as you
transcript if you will respond
just did,
Verbally,
A nice verbal answer , yes or no or
whatever the appropriate response might
I understand.
be,
Also I would ask
if you don'
understand ~ne
what I'
of my questions, you re not sure
if
m asking in one of my questions,
you
would please ask me to rephrase it rather than
trying to answer a question you re not sure what
the question is,
will do,
I appreciate
that.
Whe re do you wo
rk?
ALDERSON REPORTING COMPANY , INC,
(202)289, 2260
1111 14th ST., N. W., 4th
FLOOR
(800, FOR DEPO
WASHINGTON, D. C., 20005
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 9 of 25
At the U,
S,
Department of Energy in
the
Office of Civilian Radioactive Waste Management
in the Regulatory Coordination
What' s your job
Division, title there?
of?
Team leader,
And what are you a team leader The entire division
lieu of a deputy division deal with the regulatory concerns
the EPA
basically, I serve director, And we
between
the
program and the Nuclear Regulatory Commission
National Academy of Science, and
dealings with the Nuclear Waste Technical Review
Board,
When you
say you deal with regulatory
concerns of EPA , NRC, and the other
what do you
agencies,
do on a day-to- day basis vis- a-vis
Let'
s see,
1 7
the NRC?
a typical example would be
the fact that we are involved in developing
2 0
safeguards and security policy guidelines for the eventual acceptance and disposal of a variety of
waste forms,
2 3
And those policy guidelines will be
translated into actual waste acceptance criteria
by another
25
group,
And the waste owners will then have
ALDERSON REPORTING COMPA.~ry , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR i WASHINGTON, D. C., 20005
...-
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 10 of 25
An 0 f
f ice, rig h t
of?
I think they may have
What office would it have been part
I don' t know
called it the waste acceptance storage and
transportation office,
Bu t again I don' t commi t
things like that to memory.
I feel there are
organization charts that I can go pull to look
up,
And, between 1991
Yes.
and 1993,
Mr. Brownstein was the branch
chief?
And after 1993 Mr, Brownstein became
1".
division director?
Director.
And, between ' 91 and ' 93, do you recall
who was the division director?
Jim Carlson,
And then who was the office director
above Mr. Carlson?
20
Ron Milner.
What were your duties in this 1991 to
1993 period when you were an industrial
specialist?
I was involved in the preparation
the annual capaci ty report , the acceptance
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260
1111 14th ST., N. W., 4th FLOOR
(BOO) FOR DEPO
WASHINGTON ,
D.
C., 20005
.-- . ---. .
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 11 of 25
ranking,
answering questions both
internal and external about the terms and
conditions of the contract,
Let'
s see.
And
whatever else may have arisen at the time.
I know, when we came in , we were on the
tail end of a ru1emaking, net versus gross, as
sold was that
clarification,
So I wrapped part
of that
up.
I believe I terminated a couple of
nonuti1ity contracts at the contract holder'
request because they either no longer had the
material or
had,
in fact,
in one case I believe
sold it to the government,
Do you remember any other issues you
worked on during that period?
91 to '
Would that be about
I think we began to discuss
delivery commitment schedules at that point.
right?
That would be about
right.
That would also have included exchange
of approved delivery commitment schedules?
Actually my recollection is that we discussed exchang~s not concurrently, because
there was the opportunity to do that a little
later.
And it
was more important given the
timing requirement in the contract to have
ALDERSON REPORTING COMPANY , INC.
1111 14th ST. ,
that
(202)289- 2260 (800) FOR DEPO N. W., 4th FLOOR WASHINGTON ,
D.
C., 20005
-:::-~ ,.-...",
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 12 of 25
guidance issue. And guidance as to what to do wi th delivery commitment schedules themselves?
How to fill them
the
believe,
if I' m not incorrect,
form,
out, instructions.
that that' s
an OMB
reviewed form.
to complete the
And you know that
process, that
takes time and there must be instructions on how
What was the time
concern?
I believe the contract requires
delivery commitment schedules to be submitted by
the purchaser 63 months in advance of the year in
which they have an
allocation.
So back it out
from 1998,
, 92
and they would have been submitting in
late ' 92.
Are there any other issues that you
recall working on in the
' 91 to ' 93 period?
And nothing else
Let'
s see.
I know we addressed
priority for shutdown
reactors,
comes to mind right now,
What about the period
' 93 to ' 95, what
I believe
issues did you work on?
During that time
period,
worked on delivery commitment schedule exchanges
many of the same things from '
91 and ' 93, the
ALDERSON REPORTING COMPANY, INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON ,
D.
C., 20005
-:,\
' .
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 13 of 25
acceptance, priori ty ranking,
report, DCS review and
the annual capaci
approval.
We began conversations about
final
delivery schedules and what would be included in
those,
safeguards and security, and that was
policy development.
I know tha t
I worked on
numerous reviews of system baseline
documents,
kept
system requirements documents primarily from a
waste acceptance standpoint. And I know we working on priori ty for shutdown reactors.
by just a couple of these categories.
Let me ask you to clarify what you mean
Safeguards
and security, what was involved with safeguards
and security?
NRC regulations require that a licensee
have in place a safeguards and security
system,
And that means physical security as in physical
protection.
And that physical protection
veness of the material
based on the at tracti
would someone want to steal it to make a bomb.
They also require as another subelement
material control and
if you
accounting.
That is
that,
as a utility tell me that you ' re giving me
you have to provide me with some
ten MTU,
documentation to give me confidence that you
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON, D. C., 20005
are;
"'--"' ..---
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 14 of 25
137
reorganization, But otherwise it'
group?
Yes,
s basically the same
I do believe there was a separate
transportation program at the time that UNWMG
existed,
And I do not recall the name of the law
firm that managed that, but I believe that was
consol ida ted wi th UWASTE,
If you could turn to page 761 in the
compilation,
Do
you
see the first
issue listed
fuel
as being of a priori ty
to DOE was whether or not
there should be any exceptions to the oldest
first priority ranking; do you recall that issue?
Yes,
The issue there was do I have to
give you my oldest
fuel.
And, from the utility
I have fuel
perspective,
in the lower
I have fuel in my pool
forty,
I would prefer to give
you
the newer fuel which is in my pool and free up
space the.ce
20
m not interested
in giving
you
the
stuff I' ve
already
canned,
if my oldest fuel is what earns me
a place in the ranking based on its discharge
2 3
dates, must I give that you fuel that earned the
ranking,
2 5
you
And the answer was
no,
Bu t
That fuel earns
a space in the ranking,
on your DCS you
ALDERSON REPORTING CG:\'IPAtW , INC.
(202)289, 2260
1111 14th ST., N. W.. 4th FLOOR i WASHINGTON. D. C., 20005
(8001 FOR DEPO
-Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 Page 15 of 25
138
tell us that you want to give us a range of
fuels; and, as long as it
meets those minimum
conditions, five- year-o1d being the biggest one, So that' s what OFF was about, because
it could have been interpreted
utility perspective,
this was the
It could have been
interpreted to mean that I had to give you the
precise fuel that earned me the slot in the
ranking.
I think I understand,
Let me point
your attention to particular language in the
middle of that column,
Right about in the
middle,
it says the resolution of this issue will
focus on clarifying that the application of the
OFF principle is used only in establishing the
acceptance priority
ranking, should be no exceptions.
and as such
there
Then the next sentence
says, any basis
the
spot
in
other than OFF would result in inequitable
assignment of acceptance capacity among
purchasers,
in the queue?
Why would that be if you just said
that utilities,
the proper
they
ve already earned their
I think you'
re not reading tha t
context,
What they re saying is that
ALDERSO:\T REPORTING CO:\'IPMry , INC.
(2021289, 2260 1800) FOR DEPO 1111 14th ST., N. , 4th FLOOR WASHINGTON, D.
, 20005
"""""
~~
Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004
--Page 16 of 25
205
MR. SHAPIRO:
Why don' t we stop for the
day here and discuss where to go
next.
(Whereupon , at 4:50 p. m., the
depos i t ion adj ourned, to be April 22, 1999, at 2:00 p.
resumed on Thursday,
Signa ture of the Wi
tness
SUBSCRIBED AND SWORN to before me
this
day 0
f ~~~----------------
D2_
My Commission
expires: t~~iQ~-QL~---
NOTARY PUBLIC
Y-~~
ALDERSO~ REPORT~G CO~lPA:\Y , INC.
(2021289- 2260 /800, FOR OEPO 1111 14th ST. , N. W., 4th FLOOR WASHINGTON, D.
, 20005
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 17 of 25
Page
ERRATA SHEET FOR THE TRANSCRI PT OF:
Notice Date: 04/29/99 Yankee Atomic Electric Company v. The United States Case Name: Case Number: 98- 126C
Dep, Date: Deponent: Place:
TS#:
Nancy H, Slater
04/21/99 / Washington , DC
78077
CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
fUrn
*:' ;.", " "~;
Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 Page 18 of 25
!"~~1'~~,. ;;~~J
'.r.;J; 1 ;v h~"
:v;,;
Yf"'J
2 06
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X
YANKEE ATOMIC ELECTRIC
COMPANY,
Plaintiff,
Case No, 98- 126C
Senior Judge
Me row
THE UNITED STATES,
Defendant.
1 0
- X
Washington, D, C,
Thursday, April 22, 1999
Continued deposition of NANCY
SLATER, a witness herein , called for examination
by counsel for Plaintiff in the above- entitled
matter, pursuant to
agreement,
the witness being
previously duly sworn , taken at the offices of
Spriggs &
Hollingsworth,
1350 I Street, N,
Washington , D, C" at 2:10 p, m" Thursday, April 2 2 , 1999, and the proceedings being taken down by
Stenotype by JAN A, WILLIAMS, RPR, and
transcribed under her direction,
ALDERSON REPORTING COMPANY , INC,
(202)289- 2260 (800) FOR DEPO 1111 14th ST., NoW., 4th FLOOR WASHINGTON ,
D.
C., 20005
............ --..
Case 1:98-cv-00126-JFM
Document 840-8
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Page 19 of 25
284
Let' s focus on Yankee Atomic perhaps as an example, Was it really expected that DOE would
pick up from Yankee Atomic 9, 9 MTU in the first
year or at
least as
you
get closest to a full
cask that'
s 9, 9 MTU and then it would stop in the
first year and come back in year two, come back
for another 10, 1, year three come back for 9,
year four come back for 8,
and then do nothing
in year five and then have to come back yet again
in year six for 9, this chart?
4 strictly as it'
s indicated on
Yes, that would be my
strict
understanding of this table, yes,
But was that also how DOE expected the
program to work?
My understanding of how the program
would work again
if you accept the premise of
the round up or round down for full cask
loads,
might mean that in any given year
again the
following year is debited for the additional
amoun t ,
that you
might actually complete pickup
ahead of schedule if you made the optimistic
assumption that you were always rounding
up,
There was some discussion
about
campaigning.
Do you understand what I mean by
ALDERSON REPORTING COMPANY, INC,
(2021289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON, D. C., 20005
...
Case 1:98-cv-00126-JFM
Document 840-8
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Page 20 of 25
285
campaigning?
I think I do,
it for the
But if you
could explain
record.
Campaigning would be that we might
like
to select rather than the first year as the basis for delivery the first three years and in
large
chunks work off three years of fuel for one
utility, work off three years of fuel for the
next,
And this was subject to negotiation
with the utilities obviously because this is not
the unilateral right as I understand it of DOE to
do this,
And in the second year accept the first
year and the second year and the third year from
another utility,
This was discussed with the utilities
and it was discussed as a matter of fact when
was part of the utility
industry,
And the
utilities were not averse to considering that
because again it'
for them.
s an operational consideration
Do I want you to come to my facility
every year and disrupt my operations because
won t be doing anything while we' re loading
fuel
I rather say don' t come the first year
ALDERSON REPORTING COMPANY, INC.
(202)289- 2260
1111 14th ST., N. W., 4th FLOOR
(800) FOR DEPO
WASHINGTON, D. C., 20005
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 21 of 25
286
show up the second year and take my first
year,
my second year, and maybe my third year,
So that was discussed when I was in the
industry,
And I don' t know where that went after
that,
So I have a recollection that the precise
schedule laid out in
here,
alterations to
that
schedule were discussed by the
utilities,
part I
And the campaign was premised in
think as you said on the notion that it would be
more efficient for utilities to have pickups done
in larger amounts than in a series of smaller
amounts?
In fewer years actually,
years, so tha t
in fewer
you weren t showing up every year
with the consequent interruption of operation,
And it was
I think it was DOE'
s understanding that
it would result in -- might result
efficiencies for the DOE transportation system
2 a
well,
So my recollection is that there were
discussions on both sides about efficiencies for
both sides by campaign,
But I' m
not the expert
on campaigning and you would have to talk to the
transportation folks about that.
Let me ask
a couple questions on that
ALDERSON REPORTING COMPANY , INC,
1111 14th ST., N.
(202)289- 2260 (800) FOR DEPO .. 4th FLOOR WASHINGTON, D. C., 20005
---"-""'
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 22 of 25
287
just so I make sure
I understood what you
were
saying, The efficiency from DOE' s perspective to campaigning would be, once you got the transportation campaign going, it was more efficient to keep it going at one time than to
stop it and start it five different times or a
number of different
times,
it doesn' t have to be
five?
I don t recall the
details,
I do
recall that some of the efficiencies included
not
having to retrain personnel on the specifics of
that site three years in a row because you might
not have the same personnel at the same site
again,
So there were efficiencies to be
obtained from that,
And that' s the one that
really sticks in
my mind,
m sure there were
others, but again I' m expert,
not the transportation
Do you recall discussions of this
notion of campaigning after you got to DOE?
I am aware that the issue was
evaluated, but I evaluations, So
was not part of those
I have no knowledge of what was
involved in the evaluation
inputs,
ou tpu t s
ALDERSON REPORTING COMPANY, INC,
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR / WASHINGTON ,
D.
C., 20005
. .,
Case 1:98-cv-00126-JFM
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289
such consideration of campaigning?
I don' t recall who specifically was in
the transportation group at that
time,
In fact,
the
I really
m having a tough time recalling who
transportation division director was,
don' t know,
Going back to this table 2 in Slater
Exhibit 23,
other than the notion of
campaigning,
do you recall any other ways in which DOE or
utilities for that matter might have expected
that actual acceptances of spent fuel might occur
in an order different than what is depicted on
this table?
Plus or minus 20 percent
campaigning,
DCS exchanges
rounding, because, if exchanges
occurred,
although the amount wouldn t change,
the individual utility that would be serviced
that year would,
So that would have represented
a departure from what' s published in
2a
here,
And it
was generally anticipated
that
there would be some amount of DCS exchanges?
Yes, I did anticipate that there would
be some amount of DCS
exchanges,
You said that was your
what extent did you understand
expectation, that that
ALDERSON REPORTING COMPANY, INC.
(202)289- 2260
1111 14th ST. ,
N. W.,
(800) FOR DEPO
4th
FLOOR
WASHINGTON, D. C., 20005
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 24 of 25
312
don t know,
I know that the receipt rates were
I have a vague knowledge of the
established,
basis for their
establishment,
and I know why
changed from 1998, 1999, to year one and year
two,
But I don t think that I can speak to
the
question you ve just asked me,
BY MR, SHAPIRO:
And the reason you changed again from
specific years, calendar years, to year one, year
two, was that you
weren t sure when acceptance
would start?
Yes,
MR.
SHAPIRO:
That'
s all we have.
MS. SULL IVAN:
We cons ider Ms.
Slater
deposition to be
closed,
at 5:10 p.
(Whe reupon,
the taking of
the instant deposition ceased,
Signature of the Witness
SUBSCRIBED AND SWORN to before me
this -
day of
NOTARY PUBLIC
My Commission expires:
~t--
fiQCil-
ALDERSON REPORTING COMPANY, INC.
(202)289- 2260 (800) FOR DEPO WASHINGTON. D. C.. 20005 1111 14th ST.. N. W.. 4th FLOOR
Case 1:98-cv-00126-JFM
Document 840-8
Filed 07/07/2004
Page 25 of 25
Page
ERRATA SHEET FOR THE TRANSCRIPT OF:
Notice Date: 04/29/99 Yankee Atomic Electric Company v, The United States Case Name: Case Number: 98- 126C
Dep. Date: Deponent: Place:
TS#:
04/22/99 /
Nancy H. Slater Washington, DC
78180
CORRECTIONS:
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Line
Now Reads
Should Read
Reasons Therefore
Urvd
- S'ign
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, ure 0 Dep
f'-,,2 -
ent
Date o
Slgnature