Free Motion for Leave to File - District Court of Federal Claims - federal

-Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington , D.

Filed 07/14/2004

Page 1 of 27
June 13 ,

2002

Page 152

Yes.
Who were those
those conversations?

who was involved in

Conversation was with Dave

Zabransky.

And when was your conversation with
Mr. Zabransky?

At least a year
exactly when.

ago.

I don 't remember

Did you have one conversation on this
topic or multiple ones?

I I ve had multiple conversations with
Mr. Zabransky, but I believe we only talked about
this one time.

And what did he tell you about putting
nuclear utility activated metal GTCC into the
backfill spaces?
MS. HERRMANN:
THE WITNESS:

Objection, hearsay.

He simply said it could be

done.
BY MR. SKALABAN:

And was he talking from a technical point

of view, capacity point of view, or both?
MS. HERRMANN:
THE WITNESS:

Obj ection, speculation.

Both.

BY MR. SKALABAN:

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington, D.

Filed 07/14/2004

Page 2 of 27
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2002

Page 153

Did you and Mr. Zabransky talk about any
other aspects of placing nuclear utility activated
metal into the Yucca Mountain repository?
Not that I remember.

Have you talked to him just generally
about this subj ect, other than this one

conversation, about the backfill

spaces - - utilizing

the backfill spaces?

Have you

had conversations with him generally about
incorporating GTCC into the repository?

The other conversations I I ve

had with him

were -- had more to do with the logistics of

packaging, transport to the repository, not
placement in the repository.

So you have had conversations with

Mr. Zabransky about the logistics and
transportation aspects of taking nuclear utility
activated metal GTCC to the repository?

Yes.
And why were you discussing with him the
logistics and transportation aspects of taking
nuclear utility activated metal GTCC?

The reasons for the conversations were

determining whether the spent nuclear

fuel/high- level

waste repository was a reasonable

IIII 14th Street ,

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 3 of 27
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2002

Washington , D.

Page 154

disposal site for Greater- 1han- Class C and how that

could -- you know, how that could be

implemented.

And what did he say to you regarding the
logistical and transportation aspects of taking
nuclear utility GTCC to the repository?
MS. HERRMANN:
THE WITNESS:

Objection, hearsay.

Basically, you know, if the

activated metal is packaged in a similar fashion to
the fuel, then there' s very little difference in

handling fuel canisters as opposed to activated

metal canisters and that he saw

- - he didn't

see

anything that would make that difficult to do in

the same fashion that you would handle the

fuel.

We were speaking only in terms of the

physical and technical, not the administrative, you
know, political, legislative aspects

just purely

the physical and technical issues
BY MR. SKALABAN:

involved.

So with Lespect to the physical and

technical issues, he told you that logistically and

technically the GTCC, if packaged like spent

fuel,

could be handled and transported without problems?
MS. HERRMANN:
THE WI TNES S :

Objection, hearsay.

The GTCC activated metal,

yes.
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-Page 4 of 27
June 13 ,

Case 1:98-cv-00126-JFM
Robert L. Campbell.

Document 846-5
Washington, D.

Filed 07/14/2004

2002

Page 156

option.

I was looking to see if there were

physical or technical issues that would

prevent/cause problems with that as -- as a
disposal option as opposed to administrative
issues, which, as I state in this paper, everything

got an administrative issue associated with

it.

So Mr. Zabransky told you from logistical and transportation issues, it would not be a

problem and from capacity and performance of the repository, it would not be a problem to put it in
the backfill spaces

is that correct?
MS. HERRMANN

Obj ection, hearsay.
I believe everything you

THE WITNESS:

said was correct.

I don

I t recall

if we discussed

repository performance aspects.

I just

we may

have talked about that.
BY MR. SKALABAN

I don' t remember.

Did you talk about anything else other than what I just mentioned about placing GTCC in
the repos

i tory -No.

with Mr. Zabransky?
Not

that

recall.
you had

after
your feeling, that

talked to him what

was

would

fair

say

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-Case 1:98-cv-00126-JFM
Robert L. Campbell

-Filed 07/14/2004 Page 5 of 27
June 13 ,

Document 846-5

2002

Washington , D.

that your feeling was it'

s not a problem from a

physical and technical point of view to take the
nuclear utility activated metal and dispose of it
in Yucca Mountain?

From a physical and technical point of

view, yes, that' s
resul ted in

correct, the conversation

that that would not be a problem.

Did you explore with him at all

administrative roadblocks to Yucca Mountain for
GTCC waste?

We may have discussed

it.

ve had a

number of conversations with him on a variety of

topics.

Since he works in RW, it would all be

related to this

issue.
I do recall now that we did have
someone had suggested had requested in a

I do

an issue where it was a
that the NRC might

- - or someone

letter to the NRC that they reclassify

Greater- Than- Class C as high- level

waste.

And we

had a conversation in preparing the response

- - the

technical response to that and what would that

entail.
It would then become RW' s
if it was high- level waste ,

responsibility, commercial high- level

waste, that would fall within their realm of

Alderson Reporting Company, Inc.
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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington, D.

Filed 07/14/2004

Page 6 of 27
June 13

2002

Page 161

understanding it'
Yes.

s nuclear utility activated metal?

And the backfill spaces will be adequate
to dispose of the 1850 cubic meters that I s

estimated?
MS. HERRMANN:

Objection, speculation.
I don't know the answer to

THE WITNESS:

that.

We discussed

it.

Mr. Zabransky did not

indicate there was a capacity problem, but we did

not discuss exactly how much backfill space there was versus how much nuclear utility activated metal
there was.

But my memory of the conversation is

that that -- because it didn't come up, my memory
is that I believe there

I s going to be more backfill

space than activated metal.
BY MR. SKALABAN:

Which is why you put it
in the paper?

- - recognize

Yes.

If there was a problem with only a

limited amount, yeah, I wouldnl t have recommended

it.
In fact, 1850 cubic meters -- what' s your
sense, is that a large volume of material or
relatively a fairly small volume of material?
MS. HERRMANN:

Objection, vague.

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington , D.

Filed 07/14/2004

Page 7 of 27
June 13, 2002

THE WITNESS:

It'

s small compared

spent nuclear fuel and high- level

that will be placed in the
BY MR. SKALABAN:

repository.

Can you take the paragraph that reads
storage of nuclear utility activated metal?
still on page HQR092- 0049.

It'

ve read the paragraph.

Okay.

Are you familiar with the report

to Congress required by the Public Law 99- 240?

Yes.
Do you understand in that report, DOE
committed to accepting GTCC for storage when

needed?
MS. HERRMANN:

Obj ection, best evidence,

calls for a legal conclusion.
THE WITNESS:

The report makes this

statement similar to that, yes.
BY MR. SKALABAN:

So that -- I mean, that' s what you wrote
here on this page, correct

- - you wrote the
the Department

Department committed - - quote,
needed?

committed to accepting GTCC for storage when

Yes, that'

s what I wrote.

1111

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington, D.

Filed 07/14/2004

Page 8 of 27
June 13 ,

2002

Page 163

And that I s your

understanding of the

report?
Yes, it

is.
Let'
s make the record

MR . SKALABAN :

clear, I would like to make as Campbell Exhibit 2 a
February 1987 report to Congress.
(Campbell Exhibit No.

was marked for

identification.
BY MR. SKALABAN

My question for you is, is this the
report that you' re referring to here in this issued

paper, Exhibit I?
MS. HERRMANN

Let I S wait until you get

it.
THE WITNESS:
MR . S KALABAN :

Yes.
Can you read back the
on the record?

question so it I s clear

THE REPORTER: " Question: My question for
you is, is this the report that you' re referring to

here in this issued paper Exhibit
BY MR. SKALABAN:

I?"

Exhibit 2 is the paper referred to in the
section of Exhibit 1 that we' ve just been talking

abou t ?

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington , D.

Filed 07/14/2004

Page 9 of 27
June 13 ,

2002

Page 165

you agree that the Department is obligated for the
final disposal of GTCC waste?
MS. HERRMANN:

Objection, calls for a

legal conclusion.
THE WITNESS:

You sort of paraphrased

there, but in terms of the Department is not

obligated for the final disposal of GTCC

waste,

yes, I agree with
BY MR. SKALABAN:

that.
negative,

I was trying to avoid a double
but thank you.

What do you mean here when you say a reasonable approach would be that utilities are currently required to store their spent nuclear
fuel until the Department begins to accept it at

Yucca Mountain.

At that point, EM could have

identified and established a storage facility to

accept and store nuclear utility activated metal

until such time as a disposal option is

available,

such as placement in a geologic repository for
SNF /HLW .

The intent of those sentences was that up

until the time that the Department begins accepting
spent fuel, we ve got until then to come up with

some sort of an answer to this nuclear utility

IIII

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Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 10 of 27
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Page 166

activated metal question.

If we have not solved it by then, then utilities are then storing the activated metal and

theyl re

not storing spent fuel any

longer.

I think that would be an unreasonable or

an untenable situation, that we should have been

able to solve the problem by then, such that
particularly a decommissioned utility could then

finally close out as opposed to having to
store this Greater- Than- Class C activated metal.

So it I S important

for the Department to

have a solution in place by the time the nuclear
by the time the spent fuel is being removed from
the site -- a solution for the GTCC waste?
MS. HERRMANN:

Obj ection, foundation,

vague.

Go ahead.
THE WITNESS:

I think it'

s -- I think

it I S important, yes.
BY MR. SKALABAN:
And it' s important -- tell me the reasons

why you think that' s important.
MS. HERRMANN

Asked and answered.
Well, first of all, the

THE WITNESS:

amount of Greater- Than- Class C activated metals

compared to spent nuclear fuel is

small.

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 11 of 27
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2002

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Page 167

al though you could disagree with

this, the impact

of the utility storing that while they have to
store their spent fuel is smaller than the impact

of having to store the spent fuel.
So given that situation, storing the

activated metal while they store the spent

fuel, is

not an unreasonable situation in -- from my point
of view.

Once the spent fuel is gone, though, then

youl ve -- I think that creates a problem.

The

Public Law 99- 0240 was amended in 1985, an estimate

of the opening of the repository is approximately

2015.

I f we'

ve not come up wi th some kind of

answer for that by 2015, I just think that leaves

the Department in an untenable
I don

situation.

I t know

how you explain to anybody

why they still have to store their waste at that

point.
BY MR. SKALABAN

So the urgency to have an off-site
when I say off-site, I mean off-utility site, so

the urgency to have an off -site me start again.

- I' m

sorry.

Let

So the urgency to have an off-site option
available becomes much greater once the spent fuel

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5
Washington , D.

Filed 07/14/2004

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Page 168

is being removed from the utility reactor sites?
MS. HERRMANN:

Objection,

mischaracterizes the prior
THE WITNESS:

testimony.

Yes, once the fuel is

left,

the urgency would
BY MR. SKALABAN

increase.

And is it important to have an off-site
option available once the spent fuel has left the utility site in order to allow for timely
decommissioning of the facility?
MS. HERRMANN:

Objection, foundation,
Yes.

vague.
THE WITNESS:

It I S certainly

important to the utilities, but I think in terms of

DOE providing a solution to this problem

, it' s also

important.
BY MR. SKALABAN

So from a policy perspective, in your

view, it'

s important to have an off- site option

available once the spent fuel is removed so
reactors can complete their decommissioning?
MS. HERRMANN:

Objection, foundation,
I don

vague.
THE WITNESS:

I t know

from a policy

point of view.

I mean, to have a policy that -- to

IIII

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-Case 1:98-cv-00126-JFM
Robert L. Campbell
Washington , D.

Document 846-5

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Page 175

which says in the absence of specific

requirements,

in thi s

part.

Yes.
Is it your understanding that GTCC waste

must be disposed of in a geologic repository unless

proposals - -

unless a proposal for disposal of such

waste in a disposal site licensed by the NRC is
approved by the NRC?
MS. HERRMANN:
legal conclusion.
THE WITNESS:
BY MR. SKALABAN

Obj ection, calls for a

Yes.

What 1 S your understanding of the timing
of that?

When is

when must the GTCC go into a

geologic repository?
MS. HERRMANN:

Obj ection, calls for a

legal conclusion, foundation , speculation.
THE WITNESS:
BY MR. SKALABAN
I don

I t know.

Take a look at Bates page HQR092- 0052,

the very last page, attachment
In the very last sentence, it says DOE

did not meet its commitment to begin accepting GTCC

waste for storage by February 1989.
Do you agree with that statement?

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Robert L. Campbell

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Page 176

Yes.
What was the purpose of offering, putting
together this issue paper?
MS. HERRMANN:
Obj ect

ion, asked and

answered.
BY MR. SKALABAN:

What was it used for?
MS. HERRMANN

Same obj ections,

speculation.
THE WITNESS:

I would

I wrote this

issue paper to give my management information on
what the Greater- Than- Class C waste was and what

the issues surrounding it they used it

were.

I do not know what

for.

BY MR. SKALABAN:

Now, was there a specific question or
a specific question or event that was on the table

that caused you to draft this issue
Exhibi t I?

paper, this

I don't recall.

Typically, if there s a

specific question or issue, I would have included
that in the first couple of paragraphs because that

would have been the genesis of the issue

paper.

didn't.

It'

s more of a general information paper.

So I don I t know - - I don t recall the

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 15 of 27
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2002

Washington, D.
Page 204

from that point of view.

So the - -

in other words, the waste form

is the same as material that

- - I' m sorry.

Let me

ask a more precise question, and let me start

over.

The activated metal, the nuclear utility
activated metal GTCC is the same material that has

already been analyzed in the repository performance

models?
Yes.
So assuming that material gets licensed

to be put into the repository, it would

be,

presumably, easy to get the same material, the GTCC
waste, also licensed for the repository?
MS. HERRMANN:
THE WITNESS:

Obj ection, speculation.
I was not addressing

licensing issues.

What I was saying is if you can

dispose of spent nuclear fuel in the repository
from a technical performance basis, then you can

also dispose of activated metal because spent

nuclear fuel is activated metal plus

fuel.

So one is a component of the other.

Therefore, if it can perform for one, it will
perform for both because they' re the same
BY MR. SKALABAN

thing.

Did you give consideration to licensing?

1111

Alderson Reporting Company, Inc. 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

-Case 1:98-cv-00126-JFM
Robert L. Campbell
Washington, D.
Page 205

Document 846-5

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Page 16 of 27
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2002

I understand what you were saying

- - the answer

you

just gave me, but did you also give consideration

to licensing -- getting licenses for activated metals and spent fuel, presumably it would be easier to -- or easy to get licensing for activated
metal as GTCC?
I wasn

I t discussing

that in this

particular paragraph, but I -- I agree with that
basic statement, that I don

I t foresee

a licensing

issue.

If the NRC was going to issue a license for

the one, I don't know.

From a performance standpoint in terms of

how the metal I s going to perform in the repository,
I would be surprised if they would have an
objection to it on that basis.

Because they'
Yes.

re one and the same?

You go on to say the additional volume is

small

inslgnificant
Why did you

when compared to the volume

SNF and HLW planned for the

repository. first include that

all,

let me

ask you this:

The additional volume you'

referring to, the additional volume of material

that is nuclear utility activated metal, that would
be included into the repository?

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 17 of 27
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2002

Washington, D.
Page 206

Yes.
And why did you include this statement

that the volume is small to insignificant when compared to the volume of SNF and HLW planned for
the repos

i tory?
I included that to point out that it

would not be a major undertaking and that it would
not significantly affect the planning for the

repos i tory.
And was it your understanding that the

addi t ional volume

required to add the nuclear

utility activated metal GTCC in the repository
would not create a capacity problem at the

repository?
MS. HERRMANN:
THE WITNESS:

Objection, speculation.
That'
s correct.

BY MR. SKALABAN:

Now, Option Number 4, this is an
evaluation of other existing disposal facilities

that are currently in existence that are used to

disposal of waste forms that are greater than

low- level waste; is that right?
can you correct what I just said?

Or if Il m

wrong,

Well, I list them out, I said evaluation

of other existing disposal

facilities.

It would

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../

Case 1:98-cv-00126-JFM Robert L. Campbell

Document 846-5

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Washington , D.

Page 242

estimates.
periods.

It also gave estimates over time

And this , as far as I can tell by

glancing at this document , I can' t tell over what

time period or over what part of the report they
took that number from.

And I also don't recall
So I really don

what ACA stands for.

I t know

why

they picked that number.
MS. HERRMANN

Off the record.

(Whereupon, at 5: 15 p. m., the taking of
the instant deposition adjourned.

fl/d(J

Signature ' of the Witness

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

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Page 243

AND SWORN TO before me this -Jt- day of

11:
co~ission e~ires,

NOTARY PUBtc

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IIII 14th Stt~N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

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Page 20 of 27

Case 1:98-cv-00126-JFM Document 846-5 Filed 07/14/2004 ' TA SHEET FOR THE TRANSCRII ' OF: ER :
Notice Date: June 17 , 2002 Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 987 4C Dep. Date: June 13 , 2002 Deponent: Robert Campbell Washington DC

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Page 21 of 27

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-------

Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 22 of 27
June 14

2002

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Page 244

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

YANKEE ATOMIC ELECTRIC COMPANY, CONNECTICUT YANKEE ATOMIC POWER COMPANY, MAINE YANKEE ATOMIC POWER COMPANY,

~f!

CEL~TlirFb~UJ

?J"

Plaintiffs,
98- 474C

CASE NO.

vs.
UNITED STATES OF AMERICA,

98- 126C 98- 154C

Defendant,
Washington, D. C ,

Friday, June 14,

2002

Continued Deposition of ROBERT ALLEN CAMPBELL,

a witness herein, called for examination by counsel
for the Plaintiffs in the above-entitled matter,

pursuant to recess, the witness having been
previously duly sworn, taken at the offices of

Spriggs & Hollingsworth, 1350 I Street, N.
Suite 1010, Washington, D. C, at 9:33 a. m, on

Friday, June 14, 2002, and the proceedings being

taken down by Stenotype by CINDY L, SEBO, and
transcribed under her direction.

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Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-5

Filed 07/14/2004

Page 23 of 27
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2002

Washington , D.

Page 285

regulatory mission then is hampered if it

there I S no ability

to dispose of GTCC waste?

MS. HERRMANN:

Obj ection, foundation,

speculation, calls for a legal
THE WITNESS:

conclusion.

The particular things I had

stated are hampered.
where disposal doesn

Their overall - - anywhere I t affect their regulatory
It is only

framework ,

no, it doesn' t hamper them.

in the areas where disposal plays a
BY MR. SKALABAN:

role.

Now, in addition to public safety and

health and properly maintaining their regulatory
framework, would you also agree it' s undesirable,

just from a sound nuclear management perspective,
if waste that needs a home doesn' t have a home,

that is unsound nuclear management practice?
MS. HERRMANN:

Objection, vague,

foundation, speculation,
THE WITNESS:

I believe the regulatory

framework is the nuclear management foundation , so
I don' t think my answer changes,

BY MR, SKALABAN:

Well , how about promoting timely
decommissioning, is that also a factor why the
existing status quo is not an acceptable state of

Alderson Reporting Company, Inc,
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Case 1:98-cv-00126-JFM
Robert L. CampbelI

Document 846-5

Filed 07/14/2004

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2002

Washington, D.
Page 286

MS. HERRMANN

Objection, vague,

foundation, speculation.
THE WITNESS:

The Congress of the United

States determined that there should be disposal for

Greater- Than- Class

C waste, and they directed the

Department of Energy to make it

happen.

Therefore,

it I S undesirable if it' s not happening, because it I s the policy of the Government of the United
States to dispose of Greater- Than- Class C waste.
BY MR. SKALABAN

Are you familiar at all, in any of your
conversations or discussions within EM or with the
NRC, of the concept that' s reflected here, that NRC

staff considers DOE derelict in not having taken
action on the GTCC issue already?
MS. HERRMANN

Obj ection, assumes facts

not in evidence,

foundation, speculation.
m sorry.

THE WITNESS:

Could you

repeat that?
MR. SKALABAN

Can you read the question

back, please?
THE REPORTER:

Question: Are you

familiar at all, in any of your conversations or

discussions within EM or with the NRC, of the

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-Case 1:98-cv-00126-JFM
Robert L. Campbell

-Page 25 of 27
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concept that I s reflected

here, that NRC staff

considers DOE derelict in not having taken action
on the GTCC issue already?"
THE WITNESS:
BY MR, SKALABAN

Yes.

And can you tell me about those

conversations?

How has that

how has that issue

come up that NRC staff considers DOE derelict in
not having taken action?
MS. HERRMANN:
Obj ect ion,

vague,

foundation, speculation.
THE WITNESS:

In a meeting discussing

this issue with the NRC, they expressed

management was explaining why we were unable to do
certain things.

And they expressed - -

what

I s the

word I'

m looking for

- - a certain

amount of

amazement that 15 to 17 years had gone by and we
weren I t

well on our way to developing disposal.
And this meeting you

BY MR. SKALABAN:

re referring to

between DOE and NRC staff

when did this meeting

occur that you just referred to?

It would have been the 2001 time

frame.

And who from the NRC was at that meeting?

I was tied in on a conference call, so I

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-Case 1:98-cv-00126-JFM
Robert L. Campbell Washington , D.

Document 846-5

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Page 26 of 27
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Page 396

BY MR. SKALABAN:

Okay.

Let'

s assume that the Yucca

Mountain repository was available in

1998, and in

1998 nuclear utility spent fuel had begun to be

removed to that

site.

In that scenario, is it your opinion that

the Department should then have had a disposal path
identified and available for GTCC waste?
MS. HERRMANN:

Obj ection, speculation,

relevance.
THE WITNESS:

Yes, I think there was

ample time between 1985 and 1998 for DOE to

determine what disposal path they

wanted, had -

- if

the repository was available, then -- you know,
based on the suitability of that repository to
dispose of Greater- Than- Class C waste, yes, a path

should have been in place,
BY MR. SKALABAN

Do you think

putting aside politics

and funding, from a technical and engineering point
of view, is a 13 - year period from 1985 to

1998, is

that ample time to identify and develop and have

available a storage or disposal path for nuclear
utility activated metal Greater- Than- Class C waste?
MS. HERRMANN
Obj ection , speculation,

Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005

Case 1:98-cv-00126-JFM
Robert L. Campbell

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Filed 07/14/2004

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Page 415

activity or if Congress didn't appropriate the
funding for that activity.

Can you think of any other policy

justification other than

funding, licensing
Objection, speculation,

incapabilities and legislation?
MS, HERRMANN

relevance.
THE WITNESS:
BY MR. SKALABAN

No, I can't think of

any,

In your various conversations and

dealings with the NRC, has the NRC ever given you
any indication that it would be an acceptable or a
desirable policy to leave Greater- Than- Class C

waste at the site of decommissioned reactors once
the spent fuel has been removed?
MS. HERRMANN

Objection, vague.

THE WITNESS:
BY MR. SKALABAN

No.

Has anyone in any of the conversations

you ve ever been involved in with the Department of

Energy - - and
about - -

we' ve talked about many of them, but

m not limiting it to the ones we ve talked
have any of the conversations that you'

been involved with with members of the Department
of Energy, has anyone ever expressed to you that it

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