Case 1:98-cv-00126-JFM
Document 846-18
Filed 07/14/2004
Page 1 of 20
EXHIBIT
Case 1:98-cv-00126-JFM
Ronald Milner
Document 846-18
McLean, V A
Filed 07/14/2004
Page 2 of 20
May 3 , 2002
Page 403
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98 - 126C) CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C)
MAINE YANKEE ATOMIC POWER COMPANY (98 - 4 74C) FLORIDA POWER & LIGHT COMPANY
(98 - 483C) NORTHERN STATES POWER COMPANY (98 - 484C) DUKE POWER, A Division of DUKE ENERGY CORP. (98- 485C) INDIANA MICHIGAN POWER COMPANY (98 - 486C) SACRAMENTO MUNICIPAL UTILITY DISTRICT
(98- 488C)
SOUTHERN NUCLEAR OPERATING COMPANY, et al., (98- 614C) COMMONWEALTH EDISON COMPANY
(98 - 621C)
BOSTON EDISON COMPANY
(99- 447C)
GPU NUCLEAR, INCORPORATED
(00- 440C)
WISCONSIN ELECTRIC POWER COMPANY,
(00- 697C)
POWER AUTHORITY OF THE STATE OF NEW YORK (00- 703C) OMAHA PUBLIC POWER DISTRICT ( 01- 115C) NEBRASKA PUBLIC POWER DISTRICT ( 01- 116C) TENNESSEE VALLEY AUTHORITY
(01- 249C)
Plaintiffs,
Defendant.
UNITED STATES OF AMERICA
Washington, D.
""/1/1
Friday, May 3 , 2002 Continued Deposition of RONALD MILNER, a witness herein , called for examination by counsel for
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Ronald Milner
Case 1:98-cv-00126-JFM
Document 846-18
McLean , V A
Filed 07/14/2004
Page 3 May 3, 2002 of 20
Page 574
Department goes and prepares an APR, all the
allocations for the fifth year will be different than
they were originally in the ' 90s?
Yes, okay.
5,,forecasts?
Okay.
So a utility that submitted a DCS
for an allocation based on the rates in the early
'90s may have a different allocation under current
MR. SHULTIS:
THE WITNESS:
Calls for speculation.
I would assume, yes.
BY MR. TOMPKINS:
Okay.
Do you know what the Department
is,
or the program OCWRM is currently planning on doing
about the fact that the allocations may be different
wi th the DCS forms?
Are they going to go
back and
have utilities prepare a new DCS form based on these
ra tes?
Actually we' ve not addressed that yet. MR. SHULTIS:
Obj ection.
BY MR. TOMPKINS:
Haven't addressed
it.
Would it be
reasonable to assume that utilities will have that
option?
MR. SHULTIS:
Objection, calls for
25 ~peculation.
Mr. Milner s not a 30
(b) (6) witnes
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald Milner
Document 846-18
Filed 07/14/2004
Page 4 of 20
May 3 , 2002
McLean , V A
Page 575
THE WITNESS:
The Department simply has
We decided we should
not addressed that yet.
probably focus our efforts on getting a site first
and then work out the details.
BY MR. TOMPKINS:
I'd like to turn your attention back to
Milner Exhibit 43 which are the DCS
instructions.
Under the general instructions which start
on page one and go on page two, item 7C, we had
discussed this yesterday but I just want to now apply
this to the situation we ve just been talking
about.
It states that in the event that such circumstances
change, all DCS' s previously approved by DOE may need
to be reevaluated by DOE and the purchaser.
Would this type of change of allocation be
the type of event that may implicate this instruction?
MR. SHULTIS:
Obj ection, calls for a legal
conclusion and also speculation.
THE WITNESS:
In my opinion it would.
BY MR. TOMPKINS:
One final question on this DCS form and
believe you testified about this earlier
too.
Instruction 7B states that once a purchaser has an
allocation, any SNF owned by the purchaser can be
designated for delivery against the allocation.
Alderson Reporting Company, Inc.
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 846-18
Filed 07/14/2004
Page 5 of 20
CERTIFICATE OF REPORTER
UNITED STATES OF AMERICA) ss.
COMMONWEALTH OF VIRGINIA)
, CYNTHIA R. SIMMONS, RPR, CRR the officer before whom the
foregoing deposition was taken, do hereby certify that the witness whose testimony
appears in the foregoing deposition was duly sworn by me; that the testimony of said
witness was taken by me to the best of my ability and thereafter reduced to
typewriting under my direction; that I am neither counsel for , related to , nor
employed by any of the parties to the action in which this deposition was taken , and
further that I am not a relative or employee of any attorney or counsel employed by
the parties thereto , nor financially or otherwise interested in the outcome of the
action.
Notary Public in and for
the Commonwealth of Virginia
My Commission expires: 11/30/2004
,'~: ," ,
---------------Case 1:98-cv-00126-JFM Document 846-18 Ronald A. Milner
- )
Filed 07/14/2004
Page 6 of 20 May 7 , 2002
m: L
Washington , D.
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98-126C) (Merow, S.
COMPANY
CeRTIFiED COP
) Volume I
f,f
CONNECTICUT YANKEE ATOMIC POWER
(98-154C) (Merow, S.
(98- 474C) (Merow, S. J.
MAINE YANKEE ATOMIC POWER COMPANY) Washington, D. C.
) Tuesday
Plaintiffs,
THE UNITED STATES,
) May 7, 2002
Defendant.
Deposition of RONALD A. MILNER, a witness
herein, called for examination by counsel for
Plaintiffs in the above- entitled matter, pursuant to
agreement, the witness being duly sworn by CHERYL
LORD, a Notary Public in and for the District of
Columbia, taken at the offices of SPRIGGS &
HOLLINGSWORTH, 1350 I Street, N. W., Washington ,
D. C.
at 3: 48 p. m., Tuesday,
May 7, 2002 , and the
proceedings being taken down by Stenotype by CHERYL
A. LORD, RPR, CRR, and transcribed under her
direction.
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM Ronald A. Milner
Document 846-18
Washington , D.
Filed 07/14/2004
Page 7 of 20
May 7 , 2002
Page 28
department I s position
at the time that the delivery
commitment schedule submitted by purchasers had to be
based upon the waste acceptance schedule reflected
here on page 5?
MR. SHULTIS:
Obj ection.
The document
speaks for itself, Mr. Milner is not a 30(b) (6)
wi tness, and
calling for a legal
conclusion.
In my opinion, that' s what this
states,
yes.
BY MR. SKALABAN
And then also, sir, if you could please
take out Exhibit
43.
And on page - - for
the record,
s entitled,
Exhibit 43 is the DCS
instructions. It'
uni ted States
Department of Energy instructions for
completing the appendix C delivery commitment
schedule general instructions.
And item two, it says, who should
submit.
And it states there, the DCS should be submitted by
all purchasers with allocations in the 1991 annual
capaci ty
report.
And that further suggests, does it
not,
that the department was requirlng the purchasers to use this waste acceptance schedule here on page 5 of
the -- of Milner 42 as well as the individual
25 breakdown of allocations which appear on page 9 of
1111
Alderson Reporting Company, Inc. 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 846-18
Washington , D.
Filed 07/14/2004
Page 8 of 20
May 7 , 2002
Ronald A. Milner
Page 29 ,
the 1991 ACR?
MR. SHULTIS:
Objection.
The document
speaks for itself, calls for a legal
conclusion.
In my opinion, that' s what it states.
BY MR. SKALABAN
And if I could turn your attention to the
specific instruction portion of this document, Milner
43 of the DCS instructions, there I s a paragraph
entitled, 2. 7, on page
And if you could just take
a moment to read paragraph 2. 7 .
Okay.
This paragraph says - - or comma, it states, quote:
- I I m sorry.
In the second sentence of this paragraph after a
The total quantity of SNF
designated for delivery must not exceed the
allocation in the ACR,
MR. SHULTIS:
the documen
semicolon, exceeding the
allocation will result in the approval of the DCS.
Obj ection, mischaracterizes
t.
MR . S KALABAN :
, I' m
sorry.
Okay.
Thank you, counsel.
BY MR. SKALABAN
Exceeding the allocation will result in
the disapproval of the DCS.
And doesn I t
this part 2. 7 further confirm
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 846-18
Filed 07/14/2004
Page 9 of 20
May 7 , 2002
Washington , D.
Page 30
that the department will require the purchasers to follow the waste acceptance schedule in page 5 and
page 9 of the 1991 ACR?
MR. SHULTIS:
Obj ection.
The document
(b) (6)
speaks for itself, Mr. Milner is not a 30
witness, calls for a legal
conclusion. In my opinion, that I s what it
says
indicating here.
BY MR. SKALABAN
And is therefore, assuming that purchasers
followed the instructions and submitted DCSs on the
basis of the 1991 ACR -- the delivery commitment
schedules would then be based upon a waste acceptance
schedule that was not consistent with the Nuclear
Waste Policy Act?
MR. SHULTIS:
Obj ection, calls for a legal
conclusion and - -
objection , calls for a legal
(b) (6)
conclusion, and also Mr. Milner is not a 30
witness.
MR. SKALABAN
Specifically to give you further clarification, I mean the Nuclear Waste Policy Act
schedule linkages between the MRS and the
MR. SHULTIS:
repository.
Same obj ections.
BY MR. SKALABAN
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
: ."'
"'-Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 846-18
Filed 07/14/2004
Page 10 of 20
May 7 , 2002
Washington , D.
Page 31
The DCSs were
- - do you
understand my
question?
No, I don
It.
I mean, assuming then, that the purchasers
followed the instructions and submitted DCSs based on
the schedules in the 1991 annual capacity
report,
then the DCSs would be based upon a waste acceptance
schedule that was inconsistent with the statutory
linkages in the Nuclear Waste Policy Act?
MR. SHULTIS:
legal conclusion.
You I re talking schedule linkage?
Obj ection.
It calls for a
BY MR. SKALABAN
Yes, sir.
Well, I just don
I t view
it as inconsistent
in the sense that certainly in my opinion at the time
there was a possibility of that schedule linkage
be ing
removed.
But it was -- but the schedule linkage was
there?
Yes.
And so as the law then existed and as it exists now, because I don
I t believe - -
scratch that.
As the law then existed, the DCSs were
25 based on a waste acceptance schedule that was
Alderson Reporting Company, Inc.
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 846-18
Washington , D.
Filed 07/14/2004
Page 11 of 20
May 7 , 2002
Ronald A. Milner
inconsistent with the Nuclear Waste Policy
schedule linkages as they existed at this time?
Sitting here today looking at that, that
would be my opinion.
And to your knowledge, the schedule
I inkages have never been
changed.
There' s - -
I Im
sorry.
Let me ask a more artful question.
There hasn I t been
a change in the law
removing those schedule linkages?
No, there has not.
Mr. Milner, if you could just give me a
general overview of how
as the chief operating
officer of OCRWM, how you envision the actual overall
process of waste acceptance, transportation, disposal
unfolding when it begins in approximately
as you
anticipate in 2010, an overview, just kind of a
general overview of the
process.
I I m sorry.
How do you envision that working?
MR. SHULTIS:
MR. SKALABAN
Which process?
The process of the
well,
let I S say
the real logistical process of sort of
waste acceptance, transportation,
BY MR. SKALABAN
disposal.
How do you envision that happening in
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 846-18
Washington , D.
Filed 07/14/2004
Page 12 of 20
May 7 , 2002
Page 42
Page 44
fuel for purposes of the schedule. BY MR. SKALABAN: Whether it would be technically feasible
to accept that spent fuel?
course.
On the currently agreed- to schedule. Do you have an understanding of what would happen if the department thought it wasn
technically feasible to do it at that point in time
on the currently agreed- to schedule? MR. SHULTIS: Objection , vague , calls for a legal conclusion. Mr. Milner is not a 30(b)(6) witness. I guess in my opinion if the department detennined that it wasn t technically
feasible on the schedule and since we ve
already
BY MR. SKALABAN: And in the extreme case , do you know whether or not the technology has been developed to put that into a safe , licensed container? MR. SHULTIS: Objection , calls for a legal conclusion. I don t know. That would be a utility operation responsibility in any event. BY MR. SKALABAN: But it' s possible that that kind of situation would be dealt with? As an engineer, I like to think
that most things are technically
stated that we would accept it , it would move back in the queue. BY MR. SKALABAN: Well , does this read to you more like just a basic operational provision , whereas the department is going to look at the individual case , if it can accommodate it at that time , it' s going to move it back a little bit? That s the way I would read it. MR. SHULTIS: Asked and answered.
feasible. And you have no reason to believe that it wouldn t be technically feasible to develop a safe , NRC- licensed container to handle that extreme situation you posited? MR. SHULTIS: Objection , calls for a legal conclusion. I can t think of any. MR. SKALABAN: Can we go off the record a
Page 43
Page 45
BY MR. SKALABAN: This doesn t suggest to you that failed fuel is going to be put back years later in the queue , does it? MR. SHULTIS: Objection , asked and answered , calls for a legal conclusion. I couldn t say on that. It would depend on the nature of the fuel. BY MR. SKALABAN: Well , assuming that there was an NRC- licensed container for that failed fuel , would the department then accept it upon the currently
agreed schedule?
:~Cl'
/)lI
ryPublic My Commission Expires:
second? (Whereupon , at 5:08 p. , the taking of the instant deposition adjourned.
Signature of the Witness
/d2IJ.- day of
SUBSCRIBED AND SWORN to before me this
t:.1:1:
/2 ~~/
::J I '/Ir-
MR. SHULTIS: Objection , calls for speculation , asks for a legal
conclusIOn.
I guess in my opinion , if for that , if there were an NRC-certified container , the NRC said , yep, that particular fuel is okay to move in that container, then , yes. There s all kinds of failed fueL You can
specific failed fuel
have a fuel rod that goes -- the cladding is
slightly unzipped , or it can have it totally failed and a bunch of pellets laying at the bottom of the pool. That' s the extreme case , of
12 (Pages 42 to 45)
Alderson Reporting Company, Inc.
1111 14th Street , N~~ Suite 400 1- 800- FOR- DEPO Washington , DC 20005
---------------Case 1:98-cv-00126-JFM
Ronald A. Milner
(~
-'-'
Document 846-18
Washington , D.
Filed 07/14/2004
Page 13 of 20
May 8, 2002
Page 47
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
COMPANY
(Merow, S.
CONNECTICUT YANKEE ATOMIC POWER
) Volume II
(Merow, S.
(98- 154C) (98- 474C)
) Washington, D. C .
MAINE YANKEE ATOMIC POWER COMPANY) Wednesday
(Merow, S.
) May 8, 2002
Plaintiffs,
THE UNITED STATES,
CERTIFiED ~Uii
rT)\ F"") \~
Defendant.
Continued Deposition of RONALD A. MILNER,
a witness herein, called for examination by counsel for Plaintiffs in the above-entitled matter, pursuant
to agreement, the witness being duly sworn by CHERYL A. LORD, a Notary Public in and for the District of
Columbia, taken at the offices of SPRIGGS &
HOLLINGSWORTH, 1350 I Street, N. W., Washington, D. C . ,
at 9:20 a. m., Wednesday, May 8, 2002, and the
proceedings being taken down by Stenotype by CHERYL
A. LORD, RPR, CRR, and transcribed under her
direction.
Alderson Reporting Com r.any, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR-,pEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 846-18
Washington, D.
Filed 07/14/2004
Page 14 of 20
May 8 , 2002
Page 155
schedule at that point.
It did not disapprove
it.
It just did not act on it, did not approve
BY MR. SKALABAN:
it.
Was the department intending to convey to
purchasers at this time that the DCS and final
delivery commitment schedule process had been in
effect suspended?
MR. SHULTIS:
Objection.
The document
speaks for itself, calls for a legal conclusion, and
Mr. Milner is not a 30
(b) (6) witness.
Well, I guess in my opinion, the -- when
you got to the point of final delivery schedules, you
then specified specific
dates.
Since the department
didn
t have a facility in operation, it felt that it
approve or disapprove final schedules since
couldn I t
we didn
t know when a facility would be in
BY MR. SKALABAN
operation.
20
25 I
Well, would DCSs in your view be binding
19 t if no final delivery schedule had been finalized?
MR. SHULTIS: Objection, calls for a legal
conclusion.
I guess my understanding of the process of
the contract is that, no, if a final delivery
schedule had not been approved, then nothing in the
DCS binds either party to accept or deliver waste on
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 846-18
Washington , D.
Filed 07/14/2004
Page 15 of 20
May 8, 2002
Page 156
specified date.
BY MR. SKALABAN:
So if no final delivery commitment
schedules had been approved for Yankee Atomic, Maine
Yankee, or Connecticut Yankee, there would be no
binding commitments on either party?
MR. SHULTIS:
Objection, calls for a legal
conclusion.
BY MR. SKALABAN:
Either DOE or Maine Yankee, Connecticut
Yankee, on Yankee Atomic?
MR. SHULTIS:
Objection, calls for a legal
conclusion.
I don t understand the question.
BY MR. SKALABAN:
Well, if I -- following up on your last
answer and if I understood it, what you just
testified to was that if an FDS had never been
approved, there wouldn t be a binding commitment
between Yankee Atomic and the department, and I'
asking, would that hold true for Connecticut Yankee
and Maine Yankee if they never had a final commitment
delivery schedule approved for the department?
MR. SHULTIS:
Objection, calls for a legal
conclusion ,
asks for speculation.
Alderson Reporting Company, Inc.
111114th Street , N. W. Suite 400 1- 800-FOR-DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A, Milner
Document 846-18
Washington, D,
Filed 07/14/2004
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May 8 , 2002
Page 2g4
Page 286
which fuel the utility shipped to us.
Q, How so
f\.
Utilities verbally n I don t recall
3
MR, SHULTIS OITthe record, MR, SKALABAN: We are concluded, (Whereupon . at 6:02 p, m" the taking of
the instant deposition ceased,
anything in writing -- but I think utilities verbally
indicatcd to us that i I' they placed fuel in dry
storage. they would more likely give us fuel out of spent fuel pool than pull it out of dry storage, Q, I see. I 1'1 can call your attention to Bates No. HQ 0013570 , and it' s a page entitled , dry
storage requirements, 1998 to 2002. Yes. In the I guess the third paragraph, it says: Therc are eight shutdown reactors prior to
; 1~re
10 1\
SUBSCRIBED AND SWORN to before me this
2t~
;;)7/;/
V'
day of
1)1
I::
A. Q,
12
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(J
20
Vr":bli
~:;ir
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.J,k, .2:'1(/
All.
1998. No additional reactors shut down during the period 1998 to 2002. The annual maintenance cost at each of these reactors is assumed to be 4.5 million. Do you know where the 4, 5 million figure
came from? A. No, specifically I don
t. 1 vaguely recall at some point in time that utilities were
: ~ My commiss
basically asked what their costs were. Whether that
is the basis of this figure, I don t know, Q, Okay. Do you have any reason to believe s -- or it s an accurate estimate? I mean , do you believe it' s an accurate
Page 285
Page 287
estimate at the time
A, I don t know, Q, Just don t know,
Why was the department looking for this information about the number of shutdown reactors and the annual maintenance cost of those reactors? MR, SHULTIS: Objection , asked and answered.
A, The department was interested in the
4I
II
CERTIFICATE OF COURT REPORTER UNITED STATES OF AMERICA DISTRICT OF COLUMBIA , CHERYL A. LORD , the reporter before whom the foregoing deposition was taken , do hereby certify that the witness whose testimony appears in the foregoing deposition was sworn by me; that the testimony of said witness was taken by me in machine
shorthand and thereafter transcribed by
10 status of reactors and storage, and certainly we had
II been interested in utility cost.
12 13
10 computer-aided transcription; that said deposition is
a true record of the testimony given by said witness;
BY MR, SKALABAN:
Q. And part of your interest in utility cost
16 17A, 18 19 20 21 23 2'1 25
14 was to help promote efficiency in the overall system 15 and at the individual reactor sites
Yeah,
MR. SHULTIS: Asked and answered, A, It had been a goal of the department to minimize those costs to the extent possible, looking at the industry as a whole. MR, SKALABAN: Mr, Milner , I have no further questions THE WITNESS: Okay. MR, SHULTIS: I don t have any redirect. MR, SKALABAN: Great.
12 that I am neither counsel for, related to, nor 13 employed by any of the parties to the action in which 14 this deposition was taken; and , further , that I am 15 not a relative or employee of any attorney or counsel 16 employed by the parties hereto, or financially or 17 otherwise interested in the outcome of this action.
CHER YL A. LORD Notary Public in and for the District of Columbia My Commission expires April 30 , 2006
6\ (Pages 284 to 287)
11I1 14th Stree~.
Alderson Reporting Company, Inc. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
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Filed 07/14/2004
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EXHIBIT
Case 1:98-cv-00126-JFM
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III
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
CONNECTICUT YANKEE ATOMIC POWER COMPANY
Plaintiff
No. 98- 154C (Senior Judge Merow)
UNITED STATES OF AMERICA
Defendant.
DEFENDANT' S WITNESS LIST
Pursuant to the Court' s pretrial order issued ~ovember 4 , 1998 , as amended by
subsequent orders , defendant submits the following list of witnesses. This list does not contain
witnesses that the defendant may choose to use for impeachment. Defendant reserves the right to
amend this list as described in the Court' s rules. , Defendant also reserves the right to call all
witnesses listed on plaintiffs witness list.
Fact Witnesses
Government. Contractor or former Government employees
Christopher S, Bajwa Thermal Engineer Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville , Maryland 20852- 2738
Mr. Bajwa will testify concerning the licensing process and requirements for fuel storage
and transportation,
Case 1:98-cv-00126-JFM
Document 846-18
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Page 19 of 20
Lake Barrett 7805 Potters Mill Court Derwood , Maryland 20855
Mr. Barrett , fonner Director of the Office of Civilian Radioactive Waste Management
will provide testimony concerning the Government' s implementation of the Standard Contract
including acceptance rates , priority for shutdown reactors , the Annual Capacity Report (" ACR"
issue resolution process conducted with industry representatives , the issuance and content of the
ACRs , the issuance and content ofthe Acceptance Priority Rankings ("APR" ), delivery
commitment schedules , schedule negotiations , exchanges , and other relevant matters,
Edward Benz
IAI Corp.
955 L' Enfant
Plaza
Suite 8000
Washington D.
Mr. Benz , based upon his position as a contractor for DOE , will testify about the
technical aspects of the Standard Contract , including the ACR issue resolution process conducted
with industry representatives and the technical and legal basis for acceptance rates contained in
the ACRsl
APRs,
Alan Brownstein Senior Policy Advisor Office of Civilian Radioactive Waste Management United States Department or'Energy RW1000 Independence Ave. , SW Washington, DC 20585
Mr. Brownstein will provide testimony concerning the Government's implementation of
the Standard Contract , including acceptance rates , priority for shutdown reactors , the ACR issue resolution process conducted with industry representatives , the issuance and content ofthe
Case 1:98-cv-00126-JFM
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ACRs, the issuance and content of the APRs , delivery commitment schedules
negotiations , the exchange approval process , and other relevant matters.
, schedule
Patrice Bubar Deputy Assistant Secretary Integrated Safety Management & Operation Oversight Office of Environmental Management United States Department of Energy 1000 Independence Ave. , S.
Washington D. c. 20585
Ms. Bubar will testify regarding the development of DOE' s plans to accept " greaterclass- C" low- level radioactive waste fTom commercial utilities pursuant to the
than-
Low Level
Radioactive Waste Policy Act Amendments of 1985 and other relevant matters.
J ames Carlson 4008 Glenrose St. Kensington , MD 20895
Mr. Carlson , former Director of the DOE Waste Acceptance and Transportation Division,
will testify about the implementation of the Standard Contract , including transportation issues
, well as other relevant matters.
, as
Billy Cole Senior Consultant
JAI Corp.
11350 Random Hills Road
Suite 440
Fairfax , VA 22030
Mr, Cole , based upon his position as a contractor for DOE , will testify about the
Government's implementation of the Standard Contract , including the ACR issue resolution
process conducted with industry representatives and the technical and legal basis for acceptance
rates contained in the ACRs/ APRs , the exchange approval process
, and other relevant matters.