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

Case 1:98-cv-00126-JFM

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EXHIBIT

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Plaintiffs ' July 7, 2004 Deposition Designations

Yankee Atomic Electric Company v. United States, 98- 126; Connecticut Yankee Atomic Power Company v. United States, 98-474; Maine Yankee Atomic Power Company v. United States, 98- 154.
Robert Campbell (Organized by Date of Deposition)
1) June 13

A.

2002

Tr. 11:12 - 12:6; Tr. 23:17 - 25:14; Tr. 27:5- 10; Tr. 30:23 - 31:15; Tr. 47:24 - 48:21; Tr. 52:17 - 54:11; Tr. 60:5 - 62:3; Tr. 84:19- 24; Tr. 94:3 - 95:22; Tr. 125:18 - 126:25; Tr. 150:12 - 152:24; Tr. 153:15 - 154:25; Tr. 156:18 - Tr. 157:7; Tr. 161:22 - 162:3 , Tr. 162:9 - 163:16; Tr. 165:10 - 168:16; Tr. 175:20 - 176:1; Tr. 204:2- 23; Tr. 205:18 206:16
2) June 14 , 2002

Tr. 285:23 - 286:10 , Tr. 286:23 - 287:18; Tr. 396:1- 17; Tr. 415:19 - 416:23; Tr. 444:20 445:3
3) January 29 , 2003

Tr. 465:1- 3; Tr. 494:3 - 495:2; Tr. 537:8- 20; Tr. 544:1 - 545:16; Tr. 546:13- 18; Tr. 549:5 - 552:15; Tr. 555:25; Tr. 606:18 - 610:23; Tr. 615:2- 9; Tr. 634:8- 13; Tr. 639:21 - 640:10
B.

Alan Brownstein (Organized by Date of Deposition)
1) April 9 ,

2002

Tr. 9:18 - 10:14; Tr. 13:15- 25; Tr. 18:17- 19; Tr. 27:22 - 29:11; Tr. 31:10 - 32:5; Tr. 33:7 - 36:19; Tr. 37:3- 9; Tr. 40:11 - 41:23; Tr. 57:1- 18; Tr. 58:8- 17; Tr. 61:16 - 62:12; Tr. 99:25 - 100:17; Tr. 144:142) April 10 , 2002

Tr. 343:17 - 344:8; Tr. 420:23 - 421:24; Tr. 439:4- 6; Tr. 441:5- 25 - Tr. 443:1- 19; Tr. 452:9 - 453:7; Tr. 455:24 - 457:14
3) May 23 2002
Tr. 104:18 - 107:13; Tr. 108:3-

4) June 14 , 2002

Tr. 342: 20 - 343:20

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C.

Nancy Slater- Thompson (Organized by Date of Deposition)
1) April 21 ,

1999

Tr. 4:20 - 5:1 , Tr. 5:25 - 6:13; Tr. 19:21 - 22:10; Tr. 137:9 - 138:9
2) April 22 ,

1999

Tr. 284:1 - 287:19; Tr. 289:73) June 13 , 2002

Tr. 5:2 - 6:25; Tr. 8:11- 15; Tr. 112:4- 15; Tr. 125:9D. Ronald A. Milner

1) May 1 , 2002

Tr. 73:10- 22; Tr. 129:22 - 130:18
2) May 2 , 2002

Tr. 378:33) May 3 , 2002

Tr. 499:16 - 500:16
4) May 7 2002

Tr. 14:17 - 15:13; Tr. 17:5 - 25:21
5) May 8 , 2002

Tr. 283:10 - 284:7
E. Lake H.

Barrett
2002

1) April 22 ,

Tr. 234:9 - 235:14
2) April 26 , 2002

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Tr. 763:18 - 764:3; Tr. 795:4 - 796:3
3) May 8 , 2002
Tr. 1050:1- 9;

Tr. 1064:19 - 1065:12

4) May 15 , 2002

Tr. 339:13 - 340:3
F.

Victor W. Trebules (Organized by Date of Deposition)
1) April 17

2002
Tr. 16:5-

Tr. 10:18 - 11:9;
2) April 19

2002

Tr. 4:22 - 5:20

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EXHIBIT

Case 1:98-cv-00126-JFM

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u.s. Department

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~ustice

FWH: DMC:

154- 98- 126

HDLester

Telephone:
UbshinglOn. D. c. 20530

(202) 307- 6288

March 1, 1999

VIA TELECOPY AND FIRST CLASS MAIL
Jerry Stouck Robert L. Shapiro spriggs & Hollingsworth 1350 I Street, N. Ninth Floor Washington, D. C. 20005- 3305

Re:

Yankee Atomic Electric Co. v. United States, No. Connecticut Yankee Atomic Power 98- 126C (Fed. Cl. ) Maine Co. v. United States, No. 98- 154C (Fed. Cl. Yankee Atomic Power Co. v. United States, No. 98- 474C

(Fed. Cl.

Dear Messrs. Stouck and Shapiro:
This letter is in response to your letter dated February 18, 1999, and its accompanying notice of deposition. As I agreed with Mr. Shapiro on February 26 , 1999 , we are provi~ing you with t,he Rule 30 (b) (6) deposition, which you

this letter in lieu of

had not iced for this morning. ~

In a letter dated February 26, 1999, Mr. Shapiro confirmed our agreement that we would provide this letter in lieu of the deposition noticed for today. He also asserted in his letter that we " agreed that if we did need to proceed with the deposition that it ,would take place by the end of the week of I have no recollection of any representation or March 1st. discussion that any deposition would take place "by the end of If, after reviewing this letter the week of March 1st. plaintiffs continue to seek a deposition upon the matters identified in the notice of deposition, we are willing to discuss the scope of that deposition and a date for such a deposition we made no agreement regarding a specific with you. However date for that deposition.

40'

:..

../

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Rule 30 (b) (6) deposition notice,

Prior to responding to the information requested in your we note that a Rule 30 (b) (6) deposition is not an appropriate vehicle for the discovery that you seek. First, there is no central record keeping system for the information that you seek, particularly with regard to of all (each individual' s) involvement of your request for "the nature In fact, the subject matter in question. of with and knowledge to respond completely to your requests for information about the II
nature" of

subject matter in question, " you would presumably have to depose each and every individual identified, as it would be impossible for us to extract all such information regarding each person and provide it either in written form or in a Rule 30 (b) (6)

each individual'

involvement and knowledge

of

the

deposition.
Further, in light

the documents that have already been of (including the contract files for the plaintiffs produced to you in these three cases), the documents that you presumably already your clients ' contemporaneous involvement in the of have in light matters at issue in this case, and the access that you will have documents maintained by the of to the electronic database Energy, you should be able to identify the of Department contracting officers assigned to th~se contracts and the the matters about which you seek of individuals with knowledge Further, the documentation produced to you should (each of provide you with adequate means to identify the " nature the identified of individual' s) involvement and knowledge

information.
Federal Rules

top~cs. The Advisory Committee Notes to Rule 30
within the organization has knowledge of of

(b) (6)

of

the

Civil Procedure indicate that the rule was of intended to assist parties otherwise unable to identify who

particular facts. Fed.

Advisory Committee on 1970 R. Civ. Pro. Rule 30' (b) (6), Notes Amendment. We have identified below the individuals who have knowledge " o'f'" t'he" parti' cular" fact s"" that" you '"'have- -ide=ntifi e=d Your request that we go beyond that task and identify " all" facts

known on every topic identified is beyond any reasonable the Rule 30(b) (6).
interpretation of Given that some of

information that you currently seek is similar in nature to
information that you sought in your second set interrogatories, it also conflicts with the purposes of of

Rule

Federal Claims, which allows of the Court the Rules ) of 33 us to produce business records through which you can obtain the information that you seek.

Without waiving these objections, we have attempted to identify eight or more individuals for the categories that you of clearly irrelevant have identified, with the exception information that are not designed to lead to th& of categories admissible evidence in the proceedings before the of discovery of Federal Claims. We specifically object to your reqllest Court (each individual' of for all information regarding "the nature
involvement with and knowledge of

the subject matter in

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-3question, "
Each ind i vidual listed under for the reasons set forth each topic has knowledge of the topic at issue, with the individuals listed in descending order of involvement in the (with the exception of contracting officers, who are lis ted after other Feder~l employees)
as

' vague, ambiguous, and unduly burdensome, as well as

above.

particular matter

Unless otherwise indicated below, the bu'siness address for all listed Federal employees is the Department of Energy, 1000 20585, (202), 586Independence Avenu~( S. W., Washington, D. Further, unless otherwise indicated below, the business TRW Environmental Safety address for all contractor personne'l Systems, Inc., 2650 Park Tower Drive, Suit~ 800, Vienna" Virgini

5000.

C.

22180. We

are precluded from:providing home addresses for
S U. S. C. ~
55ia

individuals, pursuant to the Privacy Act

(1994) '

QUESTION 1: The identities of the eight (8) PERSONS with the
most personal knowledge concerning the schedule (measured in terms of metric tons of uranium or assemblies per y~ar or by some other measure) by which DOE is obligated to remove SPENT FUEL from the site of PLAINTIFFS' reactors pursuant to PLAINTIFFS'

Spent Fuel Disposal Contracts.
Federal Alan Brownstein (1985
- 91, Nuclear Industry Specialist, Management & Support Division; 1991- 94, Supervisory Industry Specialist, Logistics & Utility Interface Branch, 1994- 95, Supervisory Industry Specialist, Waste Acceptance Division; 1995- present, Supervisory Program

Nancy Slater (1991-: 95, Industry Specialist, Logistics & Utility Interface Branch; March 1995 to August 1995, Supervisory Industry " Specialist , Waste AcCeptance "
Division; August 1995:to present, Industry

Analyst, Regulatory Integration Division)

Dave Zabransky (1991-

Regulatory Coordination Division)

Specialist.;

, General Engineer, Logistics & Utility Interface Branch; 1995 to 1997 , General Engineer, Waste Acceptance Division; 1997 to present, Industry Specialist , Regulatory Coordination Division)

Beth Tomasoni ,

Contracting Officer

Chris Jedrey, Former Contracting Officer (address unknown) Rich Leotta, Former Contracting Officer

Contractor

Billy Cole,

Manager, TESS Waste Acceptance Scott Vance (1988- 93, Research Engineer, Battelle PNL, Waste Management Department; 1993- 94, Consultant CH2MHill; Senior Consultant, JAI, Inc., TESS Waste Acceptance) ,

,,; ,

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-4Ed Benz (1979- 81, Project Manager, Battelle, Columbus; 1983- 88, Jacobs Engineering (Weston Te~mmate), Waste 1988 - 91, Jacobs Engineering,
Package Program Manager

current address: Nampa, Idaho 83687

JAI, Inc., 1210 Virginia Circle

Waste Acceptance Task Leader; 1994~96, Jacobs Engineering, Was te Acceptance Task Leader; 1997 to present, JAI, Inc. (TESS Teammate), Senior Consul tant w~ste Acceptance)

,

QUESTION 2 : The identities of the eight (8) PERSONS with the most personal knowledge concerning the d~te py which DOE is obligated to finish removing all of the SP,ENT F~L from I Spent Fuel Disposal PLAINTIFFS ' reactors pursuant to PLAINTIFFS

Contracts. .
Federal
Alan Brownstein Nancy Slater

Dave Zabransky
Beth Tomasoni Chris Jedrey

Rich Leotta Contractor

Billy Cole Scott Vance Ed Benz

: the e;ght (8L. p~RS():ti,S. with the QUESTION 3:. . The identi.ties.. most personal knowledge ~oncerning the effect that the
reactors pursuant to PLAINTIFFS' '

permanently shut down status of PIAINTIFFS I reactors has on the i, from the , site of PLAINTIFFS' timing of the removal of SPENT FUEL

Spent Fuel Disposal Contracts.

Federal
Alan Brownstein Nancy Slater Lake Barrett (1985- 89, Diredtor, Transportation & Waste Systems Division; 1989- 91, Deputy Associate Director for External Relations & Policy; 1993 - 97, Deputy Director of OCRWM; 1997 to present, Acting Director,
OCRWM)

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-5Ronald P. Milner (April 1984 to March 19B5, Supervisory Program Analyst, Operations Division; March 1985 to May 1986, Supervisory General Engineer, Finance & Cost Analysis Division; May 1986 to September 1986, Supervisory General Engineer; Analytical Services Branch; September 1986 to July 1988, Supervisory General Engineer, Financial Management Analysis Division; July 1988 to June 1991, Supervisory General Engineer , Program Control Division; June 1991 to January 1995, Associate Director for Office of Storage . and Transportation; January 1995 to May 1997 , Director, Office .~f Program Management & Transportation; May 1997 to June 1997, Director, Office of Waste Acc~ptance & Transportation; June 1997 to present, Acting Deputy

Dave, Zabransky
Beth Tomasoni Chris Jedrey

Director, OCRWM)
Vance

Rich Leot ta

Contractor
Billy Cole
Scot t

Ed . Benz

QUESTIq~ 4: The identitiea of the

e:i"ght (8) PERSONS with the

moat peraonal knowledge concerning DOE' s role, pursuant tb PLAINTIFFS' spent fuel diaposal contracts, with respect to agreements - between a PLAINTIFF and any other CONTRACT HOLDER that concern exchanges of approved delivery commitment schedules.

Federal
Alan' Brownstein
Nancy Slater

Dav~ Zabransky
Ronald P. Milner Lake Barrett Beth Tomasoni Chris Jedrey

Rich Leot ta

Contractor
Billy Cole
Scot t

Vance

Pat MacDuffee, Retired Principal Investigator PNL

unknown)

(address

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The identities of the eight (8) PERSONS with the most personal knowledge concerning the treatment or handling of Greater Than Class C Waste pursuant to PLAINTIFFS I Spent Fuel
QUESTION 5:

Disposal Contracts.
Federal
Alan Brownstein Nancy Slater

Dave Zabransky
Ronald P. Milner

Lake Barre t t

Beth Tomasoni Chris Jedrey

Rich Leot ta

Contractor
Billy Cole
Scot t

Vance
The identities of the eight
I S

Pat MacDuffee
QUESTION 6:

most personal knowledge concerning DOE

PLAINTIFFS I
Spent Fuel

obligations under Article IV
to prepare its

Disposal Contracts

PERSONS with the interpretation of . A. 2 (a) of PLAINTIFFS SPENT FUEL for
(8)

transport and/or storage.

Federal
Nancy Bla.ter,
Alan Brownstein

James Carlson (1983- 84, Nuclear Engineer , Office of Systems

& Storage Development; 1984- , Supervisory General Engineer, Storage & Engineering Division; 1988Supervisory General Engineer, Program Relations Branch; 1991- , Supervisory General Engineer, Transportation & , Supervisory General Logistics Division; 1994Engineer, , Systems Engineering Division; 1997 to present, Supervisory General Engineer, Waste Acceptance

Dwight Shelor, Acting Director, Office of Acceptance,
Beth Tomasoni Chris Jedrey

and Transportation Division) Transportation and Integration

Rich Leotta Contractor
Billy Cole

"'

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-7Ed Benz
Scot t

Vance

QUESTION 7: The identities of the eight (8) PERSONS with the
most personal knowledge concerning the effect of the annual capacity reports issued by DOE and me~tioned in Article IV. 5 (b) of , PLA,INTIFFS' Spent Fuel Disposal Contracts on the schedule which DOE is oQligated to remove SPENT FUEL from the site of

by,

PLAINTIFFS' reac

tors.

Federal
Dave Zabransky
Beth Tomasoni Chris Jedrey

Alan Brownstein Nancy Slater

Rich Leotta Contractor

Billy ' Cole
Scot t

Vance

Ed Benz

QUESTION 8: The identities of the eight (8) PERSONS with the most personal knowledge concerning DOE' s plans, projections and/or objectives, as . of June 30, 1983, with respect to the annual acceptance rate of SPENT FUEL at the DOE facility(ies) to which PLAINTIFFS' SPENT FUEL would be removed pursuant to

PLAINTIFFS' Spent Fuel Disposal CoIl,tracts.

Federal
Robert L. Morgan, Former Acting Director , OCRWM

address)

(no current

Michael J. Lawrence, Former Acting Deputy Director , OCRWM (no current address) Robert Rosselli , Former Acting Associate Director, OCRWM Management Development (no current address) Robert Bauer , Former Associate Director, OCRWM Storage and

J. William Bennett, Former Acting Associate Director, OCRWM Geologic Repository Deployment (no current address)

Systems (no

current address)

Contractor
Daryl Newman , PNL Principal Investigator

address)

(no current

.~~
Case 1:98-cv-00126-JFM Document 846-3 Filed 07/14/2004 Page 13 of 20

-8Bob McKee, Retired Principal Investigator PNL

(no current

address)

Billy Cole

most personal knowledge conce~ning the creation of or antendments to DOE' s plans, projecti~ns ~nd/or objectives with respect to the annual acceptance rate of SPENT FUEI. at the DOE facility(ies)"to which PLAINTIFFS' SPENT , FUEL would be removed pursuant to PLAINTIFFS' Spent Fuel Disposal Contracts.

QUESTION 9: The identities ~f the eight (8) PERSONS with the

Federal
Jeff williams, Director, Office of Acceptance, Transportation and Integration' s Systems Engineering and International Division

James Carlson
Nevada

Stephen Brocum, Acting Director for Licensing and Regulatory Integration, YMSCO, 1551 Hillshire Drive, Las Vegas,
Roger Hilley, title and address not currently available Christopher Kouts, Former Director Storage and Engineering Technology Division

89134

Contractor
Billy Coles
Scot t

Vance

Pat MacDuffee

QUESTION 10: The identities of the eight (8) PERSONS with the mo,st" "p.ersonal,,', knowledge ,'e~ncerni.,n,g:","thec, crea, ion~' O'E"'" or.", amendments" .
to the annual acceptance priority rankings issued by DOE and mentioned in Article IV. B. 5 (a) of PLAINTIFFS' Spent Fuel Disposa

Contracts.
Federal'
Nancy Slater Thomas Pollog (1988- 90, Nuclear Engineer , Office of System & , Nuclear Engineer, Storage Development; 1990Integration Branch; 1991- 92, Nuclear Engineer, Logistics & Utility Interface Branch; 1992 :95, detailed to IAEA; January 1995 to September 1995, Nuclear Engineer , Logistics & Utility Interface Branch; September 1995 to February 1997 , Nuclear Engineer, Engineering Division; February 1997 to present , Nuclear Engineer, Waste Acceptance and Transportation Division) Alan Brownstein

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Robert P. Milner James Carlson
Beth Tomasoni Chris Jedrey

Rich Leot

Contractor
Billy Cole
Scot t

Vance

Ronald MacDonald, Principal Investigator, TESS

address)

(no current

QUESTION 11: The identities of the eight (8) PERSONS with the
most personal knowledge concerning the acceptance priority rankings issued by Article IV . B. 5 (a) of PLAINTIFFS' Spent the schedule by which DOE is obligated the site of PLAINTIFFS' reactors. effect of the annu~l DOE and mentioned in Fuel Disposal Contract on to remove SPENT FUEL from

Federal
Alan Brownstein Nancy Slater Thomas Pollog

Dave Zabransky Beth Tomasolli

Rich Leotta Contractor
Billy Cole
Scot t

Chris Jedrey

Vance

Ronald MacDonald

pursuant to PLAINTIFFS I Spent Fuel Disposal Contracts, with respect to the approval or disapproval of delivery commitment schedules furnished by PLAINTIFFS pursuant to Article V. a . 1. of PLAINTIFFS I Spent Fuel Disposal Contracts.

QUESTION 12: The identities of the eight (8) PERSONS with the most personal knowledge concerning DOE I S rights and obliga.tions,

Federal
Alan Brownstein Nancy Slater

James Carlson
Beth Tomasoni

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Chris Jedrey

Rich Leot ta

Contractor
Billy Cole
Scot t

Vance
The identities of the eight (8) PERSONS with the

Doug Williamson, TESS Scientific Consultant

most personal knowledge concerning the factual grounds ' upon which
you base your denial of paragraph 1.6 of Yankee Atomic I

QUESTION 1.3:

Complaint.

Federal
Daniel A. Dreyfus, Former Director, OCRWM, current addr~ss : Smithsonian lnst it ute, Washington, D . C . John Bartlett, Former Director, OCRWM (no current address) Ben Rusche, J:t' ormer Director, OCRWM (no current address) Lake Barrett Frank Peters, Former Acting Director, OCRWM

Contractor
Robert Strickler, Former General Manager, TESS Robbie Robertson , Former General Manager, TESS Colin Heath, Assistant General Manager, TESS

QUESTION 1.4:
mos t

you. bas,e, your, denial of - paragraph1.:J,

personal
Federal

The identities of the eight (8) PERSONS with the knowledge concerning the factual grounds upon which

f.. Yankee; , Atomio,,' s

Complaint.

Alan Brownstein Nancy Slater Thomas Pollog

Dave Zabransky
Beth Tomasoni Chris Jedrey

Rich Leot

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most personal

QUESTION 15:

you bas e your Complaint.

The identities of the eight (8) PERSONS with the knowledge concerning the factual grounds upon which denial of paragraph 23 of Yankee Atomic'

Federal
Dave Zabransky
James Carlson

Thomas Pol log
Ronald P. Milner Beth Tomasoni

Contractor
Billy Cole
Scot t

Vance

Ed Benz

QUESTION 16: The identities of the eight (8) PERSONS with the most personal knowledge concerning the fac tua1 grounds upon which you base your denial of paragraph 24 of Yankee Atomic'

Complaint.

Federal
Dave Zabransky
James Carlson Thomas Pollog Ronald P. Milner Beth Tomasoni

Contractor
Billy Cole
Scot t

Vance

Ed Benz

The identities of the eight (8) PERSONS with the most personal knowledge concerning the factual grounds upon which you base your denial of paragraph 25 of Yankee Atomic'
QUESTION 17:

Complaint.

Federal
Dave Zabransky

James Carlson
Thomas Pol log

Ronald P. Milner

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Beth Tomasoni

Contractor
Billy Cole
Scot t

Vance

Ed Benz

The identities of the eight (8) PERSONS with the mos t personal knowledge concerning the factual grounds upon which you base your denial of paragraph 27 of Yankee Atomic I
QUESTION 18:

Complaint.

Federal
Dave Zabransky

Thomas Pol log
Ronald P. Milner Beth Tomasoni

James Carlson

Contractor
Billy Cole
Scot t

Vance

Ed Benz

QUESTION 19: The identities of the eight (8) PERSONS. with the " most personal knowledge concerning the factual grounds upon which you base your denial of paragraph 39 of Yankee Atomic'

Complaint.

Federal
Dave Zabransky

James Carlson

Thomas Pollog Ronald P. Milner Beth Tomasoni

Contractor
Billy Cole
Scot t

Vance

Ed Benz

, ' ; ;,

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QUESTION 20: The identities of the eight (8) PERSONS w1th the
most personal knowledge concerning the factual grounds upon which you base the contention in paragraph 21 of your Answer to Yankee Atomic I s Complaint that " plaintiff would have been reqUired to incur substantially all of its claimed additional costs even had the Department of Energy commenced disposal operations in 1998.

Federal
Dave Zabransky

James Carlson

Thomas Pollog Ronald P. Milner Beth Tomasoni

Contractor
Billy Cole
Scot t

Vance

Ed Benz

QUESTION 21: The identities of the _ eight (8) PERSONS with the
most personal knowledge concerning the extent and manner of the government I s current storage of SPENT FUEL originating from commercial nuclear power reactors.
For the same reasons specified in response to Interrogatory No. 46 of plaintiff' s second set of interrogatories, we obj ect to this request.
The identit (8) PERSONS with the most personal knowledge concerning movements , of SPENT FUEL into or wi thin the United States by or on behalf of the United States since January 1, 1990.

QUESTION 22:

ies of the eight

For the same reasons specified in response to Interrogatory No. 47 of plaintiff' s second set of interrogatories, we obj ect to this , request.

QUESTION 23: The identities of the eight (8) PERSONS with the
most personal knowledge concerning places in the United States in which SPENT FUEL has been stored since January 1, 1983 at a site other than at a commercial nuclear power reactor.
For the same reasons specified in response to Interrogatory No. 48 of plaintiff' s second set of interrogatories, we obj ect to this request.

;::)
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QUESTION 24: The identities of the eight (8) PER~ONS with the
most personal knowledge concerning DOE. s rights and obligations, pursuant to PLAINTIFFS. Spent Fuel Disposal Contracts, with respect to the timely provision of , casks necessary for the removal of SPENT FUEL from the site of PLAINTIFFS. , reactors.

Federal
William , Lemeshewsky, Team

Division

the Office of Acceptance, Transportation and Integration' s Waste Acceptance and Transportation

Leader for Transportation within

James Carlson Dwight Shelor Beth Tomasoni Chris Jedrey

Rich Leot ta

Contractor
Billy Cole Ed Benz Bill Teer, Senior Transportation Consultant, TESS

QUESTION 25: The identities of the eight (8) PERSONS with the
most personal knowledge concerning DOE. s physical capability to transport SPENT FUEL from PLAINTIFFS

I reactors.

We object to this' request as irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.
QUESTION: :26: :. The-- ;,

identi' ies"' of'"' the " eight';,

(8'

PERSONS '

with ' the

most personal knowledge concerning DOE. s physical capability to store SPENT FUEL removed from PLAINTIFFS I reactors.
We obj ect
as irrelevant and not reasonably to this request calculated to lead to the discovery of admissible evidence.

QUESTION 27: The identities of the eight (8) PERSONS with the
most personal knowledge concerning any effort undertaken by or on behalf of DOE to examine the manner in which DOE would remove SPENT FUEL from PLAINTIFFS I reactors.

Federal
James Carlson
Lake Barrett Ed Wilmont, title and address not currently available Thomas Pollog

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Jim Osborne, General Engineer, Engineering Division, 1551 Hillshire Drive, Las Vegas" Nevada 89134

Contractor
Bill Teer Nigel Mote, NAS, address not known Ron Kelly, Former TESS, address not known

We are currently attempting to locate additional information about the employment histories of some of the individuals listed above and will supplement this letter with that information at a Otherwise, we presume that this information more than adequately responds to your requests for Additional information may be found in the documents that we have produced to you and in the electronic database to be made

later date.

information.

available to you.

ve y truly yours,
7A~, L-ct"

\/)7 '

7)

HAROLD D. LESTER, JR. Assistant Director Commercial Litigation Branch Civil Division

\0 ~/l