'-.
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
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Page 154
not involve a time frame of when they are obligated
to accept it, just whether they are obligated to
accept it?
MR. CRAWFORD
Obj ection to the
foundation; objection to the extent it calls for a
legal conclusion.
THE WITNESS:
I I m going to try to ask a
clarification.
BY MR. STOUCK:
Sure.
Are you saying -- let me try this
Are you saying, if there is an approved DC
S,
again.
irrespecti ve of anything
accept that fuel?
else, do we have an
obligation, does the department have an obligation to
Is that what you
I re asking
me?
Actually the question I just asked was
about all of the fuel that' s not described and
approved.
Okay.
The fuel that I s not
described in an
approved DCS, do you have an obligation under the
contract as DOE to accept that spent fuel for
di sposal ?
MR. CRAWFORD
Same obj ections .
I really don
THE WITNESS:
I t know
because
Alderson Reporting Company, Inc.
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 223, 2002 of 23 May
Page 155
that I S a si tuation that we never looked at.
You
know, the expectation is that both sides would
complete the contractual requirements for both the
delivery commitment schedules and then final delivery
schedules, you know, as we did the dance to the waste
acceptance - - you know, to actual waste acceptance. I don I t recall ever addressing the question of what
happens if,
you know, a utility did not do
I t
that.
the answer is I don
know.
BY MR. STOUCK:
So would it be fair based on that answer
to say that, during your tenure at RW, when you had
responsibility for these waste acceptance matters
which as we
I ve said or I have said many times I think
during that time you
is from 1985 to March of ' 95,
did not have any understanding one way or the other about whether or not DOE was obligated under the
standard contract to accept spent fuel that was not described in an approved delivery commitment
schedule; is that right?
I thought you said you
never thought about it.
Yeah.
As I recall my assumption was that
both sides would do
it.
What happens if somebody did
I don
I t
not do it?
I don
I t --
believe we ever really
had that discussion.
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 846-16
Washington, D.
Filed 07/14/2004
Page 323, 2002 of 23 May
Page 165
And then 1' m
going to follow that up with a question
about what you knew at the
time.
I s a legal
Well, today,
I mean to me that
call, you know, in light of the court decision
you know, occurred after my responsibilities.
which,
that I S a legal
clear record.
question.
At the time --
Let me ask the question just so we have a
At the time you were working on waste
acceptance matters at RW from
' 85 to '
95, did you
have an understanding with respect to the spent fuel
that is described in an approved delivery commitment
schedule whether or not DOE had a binding obligation to accept that spent fuel pursuant to the standard
contracts?
MR. CRAWFORD
Obj ection to the extent it
calls for a legal conclusion.
THE WITNESS:
First of all at the time I
and I believe the department viewed the obligation as
a conditional obligation.
Now, putting that
The final
aside,
the contract required other steps.
delivery commitment schedule, because the specific
fuel was often not described, you know, in the
approved delivery commitment schedules which was fine
under the instructions.
So, with those two caveats, no, if we
Alderson Reporting Company, Inc.
1111 14th Street, No W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
/""-"
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington , D.
Filed 07/14/2004
Page 423, 2002 of 23 May
:a,. 166
1 ' didn' t have a facility, with respect to the firs
caveat; with respect to the second, what would happen
if they had an approved DCS but took no action to
submit an FDS,
we never really addressed
that, I
never really addressed
that.
know, whether
You know, every stage -- you
it was the APR or the DCSs, I know in correspondence
we urged -- we told the utili ties this was consistent
with the contract, but we never said -- well, we
never did the what- if questions.
BY MR. STOUCK
So you didn'
the DCS, but you don
t have any understanding one
way or the other about my question which is you have
I t have
anything subsequent, you
just never thought about it, never focused on it; is
that fair?
MR. CRAWFORD:
Same
objections.
THE WITNESS:
did not think we had a
binding
obligation with
respect
first
caveat
which is because the commencement of facility
operations.
We never really addressed the second
caveat situation, where we had that and it
BY MR. STOUCK
stopped.
You never formed that understanding?
No.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
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Document 846-16
Washington , Do
Filed 07/14/2004
Page 523, 2002 May of 23
Page 167
You agree with my statement, never
an understanding?
Yes.
And you expected that utili ties, you
expected them in the course of the processes
discussed in the standard contract, that at some
point in time utilities would submit final delivery
schedules, that I s the
way you thought about it?
I had every reason to expect that
utilities, you know, participated, if you will, in
both the ACR, in the development of the APR, and in
responding to our instructions on the DCS.
Okay.
So you did expect that there would
be FDSs for all spent fuel described in a DCS?
I did.
And do you know whether it would be
possible for DOE to accept spent fuel from a utility
if that utility had submitted a DCS to DOE, proper
DCS, completely filled out, but had not submitted an
FDS?
And, just to amplify my question, is there
enough information specified in the DCS to allow DOE
to accept spent fuel for disposal even if DOE does
not subsequently get the addi tional
spec if i ed in
the FDS?
information
MR. CRAWFORD:
Objection, compound, vague,
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 623, 2002 of 23 May
Page 214
Okay.
Were there ever similar or
comparable instructions given to the purchasers regarding completion of final delivery schedules?
There were not.
Why is that?
At least through March of ' 95, we were
just in the DCS process, in the very -- I mean in the
very early stages of addressing FDS
issues.
Do you know whether subsequent to your
leaving FDS instructions were finalized and given to
the purchasers?
MR. CRAWFORD:
Objection, calls for
speculation.
THE WITNESS:
To the best of my knowledge,
they were not.
BY MR. STOUCK
Okay.
Now, on page 27 C of these
instructions please, Exhibit 34, take a look at that
for a moment.
Yes.
Okay.
It says in the second sentence the process
described herein assumes --
well, strike that.
Let I S go actually up to 7A and take a look
at 7A for a minute.
last sentence.
I I ve got a question about the
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington, DC 20005
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Case Brownstein 1:98-cv-00126-JFM Alan
Document 846-16
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Okay.
In this last sentence, quote, due to the
limited annual acceptance capacity of the FWMS,
federal waste management system that stands for?
Yes.
Continuing on, reading, only DCSs
submitted by purchasers with an allocation in the
delivery year will be considered for
approval,
parentheses, e. g., in order for a purchaser to have a
DCS considered for approval for delivery in
1998, the
purchaser must have an allocation in
1998, correct?
Yes.
Okay.
Must have an allocation as shown in
the ACR, APR, current at the time of submittal of a
delivery commitment schedule, is that what this
means?
In the APR, yes.
Well, in one of those
documents, yes. Right.
at the time?
Okay.
Whichever one was current
Yes.
Okay.
And so here, in C now, it
says, in
the second sentence, the process described herein assumes that the FWMS will be able to accept the
purchasers I
SNF beginning in 1998 according to
the
IIII 14th Street ,
Alderson Reporting Company, Inc. N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 8 23, 2002 of 23 May
Page 216
acceptance rate reflected in the 1991
A. Yes.
ACR, right?
Okay.
Next sentence, in the event that
such circumstances change, all DCSs previously
approved by DOE may need to be reeval ua ted by DOE and
the purchasers.
I do.
Do you see that?
Those circumstances have changed, right?
Yes.
Okay.
In other words, DOE did not -- was
not able to or in any event did not begin accepting
purchasers' SNF beginning in
1998, right?
Yes.
And it follows that then that DOE did not
begin accepting fuel in 1998 according to the
acceptance rate reflected in the ' 91 ACR, right?
Yes.
Okay.
So, in light of those changed
circumstances, do you have an opinion whether DCSs
previously approved by DOE need to be reevaluated by
DOE and the purchasers?
This sentence says may.
asking you whether in your view they need to be?
MR. CRAWFORD:
Obj ection to the extent it
calls for a legal conclusion; objection, asked and
25 answered.
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington, DC 20005
.---.
CaseBrownstein 1:98-cv-00126-JFM Alan
Document 846-16
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Page 217
THE WITNESS:
I would think that we would,
think both sides would want to do
BY MR. STOUCK
that.
Okay.
Why would you think that?
re going to jump from the time period
we I re talking about to today, for example?
Let I S
not
do thi s year by year.
Let I S talk about the
utilities.
If the utilities had submitted and gotten
approved DCSs, and let' s say they were very specific
about the fuel that they wanted to
deliver. Their
And it seems to
situation and views on what they want to deliver to
us could have substantially
changed.
me that that should give you -- we should in my
opinion give the utilities another opportunity to
review and see if that' s same fuel.
And I especially feel that way because the
department has not, you
know, procured casks.
example.
I may
feel differently if casks had been purchased based on
that information as an
Okay.
As an example would you agree wi th
the categorization that that would be a kind of
updating of the DCS information to deal with current
circumstances?
MR. CRAWFORD:
Objection, vague.
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D,
Filed 07/14/2004
Page 10 of 23
May 23, 2002
Page 218
THE WITNESS:
MR . CRAWFORD:
I think both sides --
And to the extent it calls
for a legal conclusion.
THE WITNESS:
I think both sides should
have the opportunity to update that
BY MR. STOUCK
information.
And you gave me an example of a reason why
utilities should be given the opportunity?
Right.
Can you give an example of reasons why DOE
should be given the opportunity to update that
information to deal with current circumstances?
The department may have better information
on the rate or the timing, both of which I would
think would influence utilities ' decisions.
Right. Well, you recall that the ' 91 -excuse me, the ' 91 ACR -- do you recall the rate in the ' 91 ACR?
No.
This has been previously marked as Exhibit
30.
It' s the ' 91 annual capacity report.
I have a
copy for you and your counsel.
look for the rate, right?
You know where to
Yes.
Page 5.
This was the so-called or I'
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005
\..
Case 1:98-cv-00126-JFM Alan Brownstein Document 846-16
Washington , D,
Filed 07/14/2004
Page 11 of2002 23 May 23,
~all it 400, 600, 900, and then 900 steady state
rate, right?
Page 219
Right.
And so that is not the acceptance rate
that is specified in DOE' s current planning
documents; is that correct?
MR. CRAWFORD
Objection, vague.
I believe you
THE WITNESS:
BY MR. STOUCK
I re accurate.
Okay.
The current planning documents for
the program indicate an acceptance rate that ramps up
to a steady state of 3, 000 tons per MTU per year?
MR. CRAWFORD:
THE WITNESS:
Obj ection.
I don
I t recall
what the
rampup rate is, but the steady state I believe is
000.
BY MR. STOUCK
Okay.
And so presumably, according to
your testimony earlier today, those current planning
documents are DOE' s current best estimate of what the
acceptance rate will be when the program actually
starts, correc
t ?
MR . CRAWFORD:
Objection, vague; and
objection to the extent it mischaracterizes prior
25
testimOny.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington , D.
Filed 07/14/2004
Page 12 of 23
May 23 , 2002
Page 220
THE WITNESS:
BY MR. STOUCK
I believe that'
s accurate.
Okay.
And so that change in projected
acceptance rates, is that another reason why in the
language -- why in your view, in the language of
paragraph 7C of the instructions, Exhibit 34, all
DCSs previously approved by DOE need to be
reevaluated?
MR. CRAWFORD:
Objection to the
foundation; objection, asked and answered;
objection,
vague.
THE WITNESS:
So I agree.
BY MR. STOUCK
I use that as an example.
Okay.
as an example?
You used the acceptance rate change
Yes.
We have now got it in more detailed form
on the record.
That' s fine.
Do you expect that others in RW would
share your views about this need to reevaluate
previously approved DCSs in light of changed
circumstances as the instructions contemplate?
MR . CRAWFORD:
Obj ection to the extent it
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005
')
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 13 of 23
May 23, 2002
Page 245
Thank you.
(Whereupon, at
4: 25 p. m., the deposition
adjourned.
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
of
i I;
day
u.
20
;2-
t-t
My Commission expires:
Iv/. lk5.~
r/I ~/:J. tJd6
. e.
.~JU
'" NOTARY PUBLI
IIII 14th Street,
~W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005
Alderson Reporting Company, Inc.
Case 1:98-cv-00126-JFM Document 846-16 Filed 07/14/2004 OF: Ef-.. ATA SHEET FOR THE TRANSCR.
Page 14 of 23
Notice Date: May 28 , 2002 Case Name: Yankee Atomic V5. United States Case Number: 98- 126C- 9874C Dep. Date: May 23 , 2002
Deponent: Alan Brownstein (continued)
Place: Washington DC
Ref. No. :
4269-
CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
;2.3
frl'()(/
e. Oc.
?fl'dr/C
JJ ve.J
"J /?CS.J.
Cf'c.7
/IS rA/'(;
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l1~kf'r "d .s~J
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~L-
Date of Signature
. , ,....
""-
- - - - - - - - - - -) - - - - - - - - - - - - - - - - - .- - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
).
Document 846-16
Washington, D.
Filed 07/14/2004
June 14, 2002
Page 15 of 23
Page 246
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98-
126C)
(Merow, S. J
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C) (Merow, S.
MAINE YANKEE ATOMIC POWER COMPANY
(98- 474C) (Merow, S.
C~RTjFIED
CO.
Plaintiffs,
THE UNITED STATES,
Defendant.
Washington, D. C .
Friday, June 14, 2002
Continued deposition of ALAN BROWNSTEIN, a
witness herein, called for examination by
counsel for
sworn,
Plaintiffs in the above-entitled matter, pursuant to
agreement, the witness being previously duly
taken at the offices of Spriggs & Hollingsworth, 1350
I Street, N. W., Washington, D. C., 20005- 3305,
at
8:40 a. m.,
Friday, June 14, 2002, the proceedings
being taken down by Stenotype by JAN A. WILLIAMS, RPR, 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
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 16 of 23
June 14
2002
Page 423
legal significance of an approved DCS?
MR . CRAWFORD :
Objection to the extent it
calls for a legal conclusion.
THE WITNESS:
BY MR. STOUCK
m not a
lawyer.
But at this
Well, you re not a lawyer.
time you were working on the program and you were
working on these matters.
their jobs.
And sometimes nonlawyers
have understandings of legal things that relate to
Maybe you did and maybe you didn
t, but
I don t know that that
I s responsive to my question.
At this time did you have an understanding of the
legal significance of an approved DCS?
MR . CRAWFORD :
Obj ection to the extent it
calls for a legal conclusion.
THE WITNESS:
Probably not, because I
don t recall having a discussion with anybody about
that.
BY MR. STOUCK
Okay.
What about at some subsequent time
prior to the time that you ceased working on these
matters?
I I m looking for my notes here.
I think it
was March 1995.
Did you have any discussions with
anyone that would have given you, Alan Brownstein, an
understanding of the legal significance of approved
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 17 of 23
June 14, 2002
Page 424
DCSs?
MR . CRAWFORD:
Same objection.
THE WITNESS:
BY MR. STOUCK
Not that I recall.
And subsequent to
that, in ' 95,
you have
had no such discussions; is that right or is that not
right?
MR . CRAWFORD:
Same objection.
THE WITNESS:
I think I testified earlier
that I may have reviewed a DOJ, you know, document, a
reply.
BY MR. STOUCK
In this litigation?
In this litigation.
Was that subsequent to the last time we
were here in this deposition room?
No.
It was
prior
prior
that?
to your first deposition?
Yes.
Was
Yes.
Do you know
whether
it was
prior
after the DOJ document was filed in court or was it a
DOJ document that was filed in court?
MR . CRAWFORD:
Objection to the extent it
1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Alderson Reporting Company, Inc.
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington, D.
Filed 07/14/2004
Page 18 of 23
June 14, 2002
Page 425
calls for speculation.
THE WITNESS:
I reviewed it -- a draft DOJ
document.
And I testified to that before
BY MR. STOUCK
too.
Okay.
Again I really apologize.
Yeah.
It'
s been a long deposition, I just did
I I m not trying to ask you the same
not recall that.
questions over.
And I believe, you know, that addressed
some of that
issue.
So that I s what
jogged my memory.
So based on that you have an understanding
or at least at the time you read this you had an
understanding of what DOJ' s current position about
the legal significance of this is?
MR . CRAWFORD:
Well, objection, asked and
answered and to the extent that that may have
mischaracterized anything he previously testified
THE WITNESS:
to.
There was discussion
about -MR . CRAWFORD:
And 1' m going to instruct
the witness not to reveal anything about any
discussions with any DOJ lawyers about any kind of
matter discussed with respect to this litigation at
25 all.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005
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'"Case 1:98-cv-00126-JFM
Alan Brownstein
Document 846-16
Washington , D.
Filed 07/14/2004
Page 19 of 23
June 14, 2002
Page 426
THE WITNESS:
Okay.
Well, that' s fine.
think somewhere in that draft there was, you know,
some views expressed about what the government' s
--
Department of Justice s views were with respect to
the legal effect of the DCSs.
BY MR. STOUCK
I read those words.
Approximately when was that, do you
recall, within the last year?
MR . CRAWFORD :
Obj ection to the extent it
calls for speculation.
THE WITNESS:
Yeah, wi thin
a year, wi
thin
the las t year.
BY MR. STOUCK
Okay.
Can you place it any more
specifically than that in time?
MR . CRAWFORD :
Objection, asked and
answered.
THE WITNESS:
BY MR. STOUCK
No.
But, prior to reading that draft and prior
to whatever discussions grew out of that draft, you
had no understanding of the legal significance, you
had no discussions with anyone who would have given
you any other basis for having any understanding of
the legal significance of the DCSs; is that right?
Alderson Reporting Company, Inc. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005 1111 14th Street, N.
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Page 427
That I S right.
And why I brought that up
is because, you know, my reaction was, well, that'
interesting, when I read that it was
interesting.
before.
never discussed it or thought about that
Directing your attention to the very last
sentence of Exhibit No. 109, I'll read it, it says
what liabilities and obligations on the part of both
parties are locked in by the DCS submittal and
approval process.
Okay.
Now, that' s a question that -- you know,
the words are different.
But it'
s very similar to
this question about the legal significance, is that
right, do you agree with that?
I agree with your statement.
So, therefore, you had no understanding of
what liabilities and obligations on the part of both
parties are locked in by the DCS submittal and
approval process contemporaneous with this document
in August of '91; is that right? That I S right.
And you had no understanding about those matters as of the time you stopped working on waste
acceptance matters in March 1995?
That I S accurate.
Alderson Reporting Company, Inc. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005 1111 14th Street, N.
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Page 428
And you had no understanding about those
matters at least prior to the time that whatever
understanding you gained by reading this draft that
you just referred to?
That I S correct.
(Recess. )
BY MR. STOUCK
Do you know whether the standard contract
or any of these -- not these standard contracts but
any of these individual waste acceptance contracts
with the utilities were ever amended?
MR . CRAWFORD :
Well, object to the extent
of lack of foundation and to the extent it would call
for speculation.
Bu t go ahead.
MR. STOUCK:
m not asking for
speculation, 1' m
just asking if he knows if any of
them were ever amended.
MR . CRAWFORD:
Then maybe my obj ection
is
more appropriately obj ection, vague.
THE WITNESS:
Yeah, I believe there were
It would be hard for me to
Bu t
some
tell
some
modifications made. you what they were. modifications made.
BY MR. STOUCK :
I remember there were
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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Washington, D.
Filed 07/14/2004
Page 22 of 23
June 14, 2002
Page 440
have been correct had that said ACR instead of
contract.
MR. STOUCK:
Mr. Brownstein, you are done
for today subject to what I just told
THE WITNESS:
MR . CRAWFORD :
you.
Thank you.
'll reserve any further
questioning of the wi tne&s
MR . CRAWFORD :
until the time of
trial.
(Discussion off the record.
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.
(Whereupon,
m., the takin~ of
the instant deposition ceased.
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
of
rJ;W!;
day
lIllf"
20u.
NOTARY PUBLIC
My Commission expires:
~jf/ob
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
ER~
Document 846-16 Filed 07/14/2004 fA SHEET FOR THE TRANSCRIF JF:
Page 23 of 23
Notice Date: June 17 , 2002
Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 9874C Dep. Date: June 14, 2002 Deponent: Alan Brownstein Washington DC
Place: 4269-45
Ref. No.
CORRECTIONS:
Page
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Should Read
Reasons Therefore
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Signature of Deponent
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