Case 1:98-cv-00126-JFM
Document 846-14
Filed 07/14/2004
Page 1 of 15
EXHIBIT
~"-~ ,.
~:'
Case 1:98-cv-00126-JFM
Victor
. )
Document 846-14
W.
Trebules Jr.
Filed 07/14/2004
Page 2 of 15
::;X~i'
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
(Merow, S. (Merow, S.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C)
MAINE YANKEE ATOMIC POWER COMPANY ( 98 - 474 C) (Merow, S. J FLORIDA POWER & LIGHT COMPANY
(98- 483C)
(Wilson, J.
NORTHERN STATES POWER COMPANY
(98- 484C)(Wiese, J.
DUKE POWER, a Division of DUKE ENERGY CORP.
(98- 485C) (98- 486C) (98- 488C)
(Sypolt, J.
(Hodges, J.
(Yock, S.
INDIANA MICHIGAN POWER COMPANY
SACRAMENTO MUNICIPAL UTILITY DISTRICT
SOUTHERN NUCLEAR OPERATING COMPANY, et
ale :
(98- 614C)
( 98 - 62 1
(Merow, S.
COMMONWEALTH EDISON COMPANY
C ) (H ew
it t , J.
BOSTON EDISON COMPANY (99- 447C) (Allegra, J. GPU NUCLEAR, INCORPORATED
(00- 440C)(Bush, J.
WISCONSIN ELECTRIC POWER COMPANY
(00- 697C) (Merow, S. J. )
POWER AUTHORITY OF THE STATE OF NEW YORK
: VOLUME
(00- 703C)(Damich, J.
OMAHA PUBLIC POWER DISTRICT
(01- 115C) (01- 116C)
(Bush, J.
NEBRASKA PUBLIC POWER DISTRICT
(Sypolt, J.
: Discovery
: Judge: : (Judge
TENNESSEE VALLEY AUTHORITY
(01- 249C)(Bruggink, J.
~O;\
Plaintiffs,
: Sypolt)
: PAGES :1 - 241
Esquire Deposition Services
800-441-3376
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Document 846-14
Victor W. Trebules, Jr.
Page 2
THE UNITED STATES,
Defendant.
Deposition of victor
W. Trebules, Jr.
washington, DC
Wednesday, April 17, 2002
Reported by:
JOB NO.
Denise Dobner Vickery, RMR, CRR
144458
800-441-3376
Esquire Deposition Services
Case 1:98-cv-00126-JFM
Document 846-14
Filed 07/14/2004
Page 4 of 15
Victor W. Trebules, Jr.
Page 10
whatever reason, as long as a question is not pending,
I would be more than happy to accommodate you in taking
a break.
(Nods head).
Could you just quickly just describe your
education after high
school.
I went to Ohio University for
All right.
five years.
I got a degree in engineering and a
I then did graduate
bachelor'
work
s degree in physics.
Lehigh University in
Bethlehem, Pennsylvania.
got
master
s degree in mechanical engineering.
And when did you receive that final degree?
1972 I graduated from Lehigh.
And that was the master
Yes.
Master
s degree in mechanical
engineering.
Okay.
When did you first -- strike that.
. Do you presently work for the Department of
Energy?
Yes, I do.
Okay.
When did you first -- when did you
start working for the Department of Energy?
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Case 1:98-cv-00126-JFM
Document 846-14
Filed 07/14/2004
Page 5 of 15
Victor W. Trebules , Jr.
Page 11
Actually, I started working for the Atomic
Energy Commission in 1972, which became the Energy
Research and Development Administration , which became
the Department of Energy.
I don' t remember the exact
year ERDA became the Department of
was about -- I don t remember.
Energy.
I think it
Okay.
But you were there when the Department
of Energy was first formed it sounds like?
Yes.
Yes.
What was your first position in the Department
of Energy?
The Department of Energy or the Atomic Energy
Commission?
m going to start with the Department of
Energy.
Okay.
Again, I don' t remember exactly when
name changed, but I spent the first five years working
for the Pittsburgh Naval Reactors Office after I
graduated from college, and then I transferred to the
Atomic Energy Commission headquarters in Germantown,
Maryland and I worked in the Office of Nuclear Energy
Programs.
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Case 1:98-cv-00126-JFM
Victor
Document 846-14
W. Trebules,
Filed 07/14/2004
Page 6 of 15
Jr.
Page 16
Radioactive Waste Management?
I don t remember the title of my first
position.
It was probably program analyst or
something like that, but I' m not exactly
sure.
What were
What did that position entail?
your responsibilities in that position? First major assignment I could remember was
coordin~ting the preparation of the mission plan for
the Civilian Radioactive Waste Management
Program.
Was there anything else that your role
entailed in that position?
MR. SHULTIS:
THE WITNESS:
Objection, vague.
That preparation of the
mission plan was pretty much a full-time activity for a
number of years.
So there might have been other minor
assignments I was given, but, you know, overall it was
primarily the mission plan.
BY MR. EIDUKAS:
Okay.
Did there come a time when your
position at the Office of Civilian Radioactive Waste Management changed from program analyst working on the
mission plan?
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Case 1:98-cv-00126-JFM
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Page 7 of 15
Document 846-14
Filed 07/14/2004
Victor "V. Trebules , Jr.
Page 241
ESQUIRE DEPOSITION SERVICES
1020 19TH STREET, NORTHWEST
SUITE 620
WASHINGTON, D. C.
20036
ERRATA SHEET
Case Name:
Yankee Atomic Electric Co. , et ale V.
The United States Witness Name: Victor W.
Depos it ion
Trebules,
2002
Jr.
Date:
April 17,
Change
Job No.
144458,
Line No.
Page No.
Page 13, Line 17, change " Fish"
to " Fission
; Page 14, Line 11,
change II Fish" to Fission ; Page 15, Line 4, change " Whitewater " to
Light Water
; Page 17, Line 19, change II technical"
one
to
executive
Page 33, Line 1, change to read "
Line 3, place a period after " that.
whi ch was our.. ~; Page 33,
delete " where , start new
II ,
sentence with "
; Page 56, Line 11, change "
field" to " fuel"
would
Page 64, Line 16, change " Al"
to " Alan
; Page 82, Line 11, change
" to " and" ; Page 98, Line 3, change to read "
more
than...
; Page 102, Line 10, change "
" to " were ; Page 117,
Line 5, change " ground"
to " round" ;
Page 126, Line 17, change
overview "
to " for review ; Page 138, Line 12, change " 199411 to
1984" ; Page 153, Line 14, change II change " to " changed" ; Page 168,
Line 4, delete " fold" ;
Page 192, Line 1, change " 1995"
to " 1985"
22
Page 205, Line 15, change " 50, 000"
to " Then " and delete
to " 15, 000" ;
" in here
Page 226, Line 16,
d on 241a)
change " When "
(Cont'
Signa ture
- 0.w.
Da te
J;; ,s--- zo-()
1.
Esquire Deposition Services 1- 800- 441- 3376
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...
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Case 1:98-cv-00126-JFM VICTOR W. TREB(jLS, Filed 07/14/2004 Document 846-14 Jr.
ERRATA SHEET (CONTINUED)
Page 24l a
\Vltness Name: Victor W. Trebules, Jr.
Page 226, Line 17 and 18 ,
bring Line 18 up to Line 17 , should be incorporated as
same paragraph , should read as " ... Waste Negotiator. \Vhen Congress created... "
Page 236 , Line 13 , change " WIP" to " WIPP" ; Page 188, Line 10 , delete " past or
Page 188 ,
Line 16 change " " to " not
Signature
Jt11
S"-
Date
~o -
or.-
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Victor Trebules
Document 846-14
Filed 07/14/2004
Page 9 of 15
ORIGINAL
In the u. s.
Court of Federal Claims
---x
Yankee Atomic Electric
et al
NO.
Co.,
98- 126C
98- 154C
98- 474C
United States of America
-----x
April 19,
"J;
2002
DEPOSITION OF:
Victor W. Trebules,
Jr.
notice,
a witness, calied by counsel pursuant to
commencing at
9: 00 a. m., which
was taken at
I St., NW,
Spriggs and Hollingsworth, 1350
Washington, DC
;'l
, 21
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Case 1:98-cv-00126-JFM
Document 846-14
Victor Trebules
Filed 07/14/2004
Page 10 of 15
, 1
Page 4
(Morning Session)
Stipulations
(It is stipulated and agreed by and
between counsel for the respective parties that
the reading and signing of this transcript by the
witness are not waived.
It is further stipulated and agreed
that the filing of this transcript with the clerk
of the court be and the same is hereby waived.
Whereupon,
Victor W. Trebules,
Jr.
and,
was called for examination by counsel
having been previously sworn, was recalled and testified as
follows:
20.
DIRECT EXAMINATION:
BY MR. STOUCK:
Good morning,
Esquire Deposition Services
Mr. Trebules.
Would you
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Case 1:98-cv-00126-JFM
Document 846-14
Victor Trebules
Filed 07/14/2004
Page 11 of 15
Page 5
agree that at the time that you were working on the
plan in 1984 and 1985 it was an objective of the
spent fuel program that that program be operated in
an economically efficient manner?
MR. SHULTIS:
Objection as to
economically efficient.
It'
s vague.
I believe we said words to that effect in
the mission plan, that'
s correct.
Why was that an objective?
To the best of my recollection, I think
we used phrases like fiduciary
responsibility.
People working in the program felt that they had an
6bligation to try to execute the program
efficiently and effectively.
Why was that an objective?
We knew the program was going to cost a
lot of money over its lifetime.
I gues s
it. s my
opinion that the people
felt they ought to try to be efficient in carrying
program.
Let'
~o/
s pull out the mission plan which I
think is exhibit six , if you would , please.
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Victor Trebules
Filed 07/14/2004
Page 12 of 15
In the u. s.
Court of Federal Claims
-- - --x
, Yankee Atomic Electric
et al
NO.
Co.,
98- 126C 98- 154C
98- 474C
United States of America
--x
April 19,
DEPOSITI'ON OF:
2002
Victor W. Trebules,
Jr.
notice,
a witness, called by counsel pursuant to
commencing at 9:00 a. m., which was taken at
Spriggs and Hollingsworth, 1350 r'
Washington, DC
St., NW,
Esquire Deposition Services
1~800- 441- 3376
.. .
Case 1:98-cv-00126-JFM Document 846-14 Filed 07/14/2004
...
Page 13 of 15
Victor Trebules
Page 59
Errata page of Deponent
Please note any errors on this sheet. The
reasons may be
general, such as " to
correct
stenographic error " or " to
clari~y. the record.
When completed, send this page to the attorney
who took your deposition, NOT the court
reporter.
Page
Line
Correction
to "
Reason For Change
Page 8, line
1, change II depository "
to II repository
; Page 10,
to
Line 5, change lI andll
" and change lI operations "
operation
; Page 20, Line 17, change " some whatll to " somewhat"
5, change " cast"
Page 22, Li ne
to " cask" , Page 22, Li ne
9, change
castll to " cask" ;
Page 26, Line 19 and 20, should be
incorporated"Robert
as same paragraph and same sentence, change to read as II
Rosselli in the early...
stages
; Page 26, Line 20, delete 11 " after
; Page 30, Line 10 and 13, change " Wellington " to
Mell i ngton ; Page 30, Li ne 22, change " Troutner " to " Trautner
Page 35, line 21, change lI
to ' read as "
ll to " andll ;
It wou 1
Page 52, line 6, change
that part of it.
d be...
b -2
()~OZ
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Case 1:98-cv-00126-JFM
Document 846-14
Filed 07/14/2004
Page 14 of 15
EXHIBIT
Case 1:98-cv-00126-JFM
Document 846-14
Filed 07/14/2004
Page 15 of 15
Plaintiffs ' July 7, 2004 Possible Rebuttal 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.
A.
Alan Brownstein (Organized by Date of Deposition)
3) April 9 ,
2002
Tr. 54:1 - 55:20; Tr. 64:5- 16; Tr. 146:23 - 148:9; Tr. 150:7 - 151:17
4) April 10 , 2002
Tr. 376:22 - 378:5
5) May 23 2002
Tr. 152:6 - 155:25; Tr. 165:7 - 167:3; Tr. 214:17 - 220:17
6) June 14 , 2002
Tr. 423:20 - 428:5
B.
Nancy Slater- Thompson (Organized by Date of Deposition)
1) April 22 ,
1999
Tr. 244:5- 15; Tr. 273:11 - 274:5
2) June 13, 2002
Tr. 94:16 - 96:16; Tr. 97:6 - 99:6; Tr. 109:3 - 110:13; Tr. 159:7 - 160:2; Tr. 161:2C.
Ronald Milner (Organized by Date of Deposition)
1) May 3 2002
Tr. 574:5 - 575:19
2) May 7 2002
Tr. 28:11- Tr. 32:11
3) May 8 , 2002
Tr. 155:4- 156:1