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,,Case 1:98-cv-00126-JFM
Alan Brownstein
Washington, D.

Document 840-8

Filed 07/07/2004

Page 1 of 25
June 14, 2002

Page 342

this document would be consistent with that is a

mischaracterization.
BY MR. STOUCK

Let me just ask this, is that true, that
DOE had made the decision to reject Yankee
before the meeting was held?
I don t think that

s position

I s a fair statement.

mean the purpose of the meeting was to hear what they

had to say and we were going to listen to

it.

And

perhaps there was something that we hadn' t considered
or known before.

We were trying to do what the

contract said. contract.

We were trying to implement the

To the extent that they could not bring to
our attention any information that was new or different, we objected to the position outright to
the extent that we were implementing the contract as

we understood

it. So I think that I s a
enough.

little

different characterization.

That I S fair

The next paragraph,

first sentence, says, DOE urged us to swap delivery

schedules with other contract holders as the most

equi table way for achieving accelerated
Do you see that?

deliveries.

Yes.
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 840-8
Washington , D.

Filed 07/07/2004

Page 2 of 25
June 14, 2002

Page 343

And is that an accurate report of one of
the things DOE said?
MR . CRAWFORD:

Same obj ection as I had

before.
THE WITNESS:

Urge is a little

subjective.

We certainly made it clear that the contract which
they were party to gave them the right to exchange

approved DCSs of which they can achieve their

obj ecti ves.
We wanted to make sure that they were
aware of that and, you know, we saw that as a way
that all parties could benefit.

So, you know, we

made them aware, I think we encouraged -- I don'
know if there

I s a difference between encouraged and

urged. But meeting.

we certainly discussed that at the

BY MR. STOUCK:

Encouraged swaps as a way -- as a possible

way of helping Yankee achieve its obj ecti

ve?

Yes, that'

s true.

MR . CRAWFORD :

Let me just state for the

record, okay,

if it is your intent to proceed in this

same fashion through this

document, I'

m going to

obj ect to best evidence because we have before us

Exhibits 96 and 97, two different memos reflecting

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 840-8
Washington , D.

Filed 07/07/2004

Page 3 of 25
June 14, 2002

Page 440

have been correct had that said ACR instead of

contract.
MR . STOUCK :

Mr. Browns tein, you are done

for today subj ect

to what I just told

you.

THE WITNESS:
MR . CRAWFORD :

Thank you.
We I 11

reserve any further

questioning of the witne&s until the time of
(Discussion off the record.
MR . CRAWFORD :

trial.

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.

(Where upon,

m., the takin~ 0

the instant deposition ceased.

Signature of the Witness

SUBSCRIBED AND SWORN to before me this
of

&;wJ;

day

t/17e

20111::

NOTARY PUBLIC

My Commission expires:

~;f 1/0 b

Alderson Reporting Company, Inc.

1111 14th Street , N. W~uite 400 1- 800-FOR- DEPO Washington, DC 20005

Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 JF: ER~ . fA SHEET FOR THE TRANSCRIF Notice Date: June 17, 2002 Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 987 4C Dep. Date: June 14 , 2002 Deponent: Alan Brownstein Washington DC

Page 4 of 25

Place: 4269-45
Ref. No.

CORRECTIONS:

Page

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Should Read

Reasons Therefore

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Signature of Deponent

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 5 of 25

EXHIBIT

"""

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Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 6 of 25
a. , ,~.
J.

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X

YANKEE ATOMIC ELECTRIC
COMPANY,

Plaintiff,
THE UNITED STATES,

Case No. 98-126C
Senior Judge

Merow

Defendant,
- X

Washington ,

D,

Wednesday, April 21

1999

Deposition of NANCY H, SLATER , a

witness herein,
pursuant to

called for examination by

counsel

for Plaintiff in the above-entitled

matter,

agreement, the wi tness

being duly

sworn by JAN A, WILLIAMS, a Notary Public in and

for the District of Columbia, taken a t
offices

the

Street,

Spriggs & Hollingsworth 1350 I N, W" Washington, D. C" at 10:10 a,
1999, and the proceedings

Wednesday, April 21

being taken down by Stenotype by JAN A, WILLIAMS,
RPR , and transcribed under her

direction.

ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W, 4th FLOOR / WASHINGTON ,
D.

C., 20005

-=:..:;;.

-..

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 7 of 25

Whereupon,
NANCY H, SLATER

was called as a witness by

counsel

for

Plaintiff

and having been duly sworn by

was examined and testified as

the Notary Public, follows:

EXAMINATION BY COUNSEL
FOR PLAINTIFF
BY MR,
1 0

SHAPIRO:
for

Would you state your name

the

record, please,
Nancy H, Slater, Ms. Slater , my name
we'
re here for

is Robert Shapiro,

your deposition,
before?

Have you ever

had your deposition taken

No,
Do you have some understanding

what' s going to happen today? Yes.
What do you understand is going to

happen today?

I understand that I'
2 3

m going to be a

factual deponent and that you

re interested in

24
2 5

asking me questions about my knowledge of the

waste acceptance area during the time I was in
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR! WASHINGTON, D.

, 20005

---..

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 8 of 25

waste acceptance.

And let me

tell

you

just briefly
ll be asking

procedurally how it will work,

you a series of questions and you will be

expected to answer the questions,

As we

discussed even before we went on the record,
court reporter is taking everything down and

the

'll get a written transcript of everything

that'
1 0

s said

today,

Do you understand that?

Yes,

And it

will also be helpful for the

court reporter' s

purposes so we get a clean
as you

transcript if you will respond

just did,

Verbally,
A nice verbal answer , yes or no or

whatever the appropriate response might
I understand.

be,

Also I would ask

if you don'

understand ~ne
what I'

of my questions, you re not sure
if

m asking in one of my questions,

you

would please ask me to rephrase it rather than
trying to answer a question you re not sure what

the question is,

will do,
I appreciate

that.

Whe re do you wo

rk?

ALDERSON REPORTING COMPANY , INC,
(202)289, 2260
1111 14th ST., N. W., 4th
FLOOR

(800, FOR DEPO

WASHINGTON, D. C., 20005

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 9 of 25

At the U,

S,

Department of Energy in

the

Office of Civilian Radioactive Waste Management

in the Regulatory Coordination

What' s your job

Division, title there?
of?

Team leader,
And what are you a team leader The entire division

lieu of a deputy division deal with the regulatory concerns
the EPA

basically, I serve director, And we
between

the

program and the Nuclear Regulatory Commission

National Academy of Science, and

dealings with the Nuclear Waste Technical Review

Board,
When you

say you deal with regulatory

concerns of EPA , NRC, and the other
what do you

agencies,

do on a day-to- day basis vis- a-vis
Let'
s see,

1 7

the NRC?

a typical example would be

the fact that we are involved in developing
2 0

safeguards and security policy guidelines for the eventual acceptance and disposal of a variety of

waste forms,
2 3

And those policy guidelines will be

translated into actual waste acceptance criteria

by another
25

group,

And the waste owners will then have
ALDERSON REPORTING COMPA.~ry , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR i WASHINGTON, D. C., 20005

...-

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 10 of 25

An 0 f

f ice, rig h t
of?
I think they may have

What office would it have been part
I don' t know

called it the waste acceptance storage and

transportation office,

Bu t again I don' t commi t

things like that to memory.

I feel there are

organization charts that I can go pull to look

up,

And, between 1991
Yes.

and 1993,

Mr. Brownstein was the branch

chief?

And after 1993 Mr, Brownstein became
1".

division director?

Director.
And, between ' 91 and ' 93, do you recall
who was the division director?

Jim Carlson,
And then who was the office director
above Mr. Carlson?
20

Ron Milner.

What were your duties in this 1991 to
1993 period when you were an industrial

specialist?
I was involved in the preparation
the annual capaci ty report , the acceptance
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260
1111 14th ST., N. W., 4th FLOOR
(BOO) FOR DEPO

WASHINGTON ,

D.

C., 20005

.-- . ---. .

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 11 of 25

ranking,

answering questions both

internal and external about the terms and

conditions of the contract,

Let'

s see.

And

whatever else may have arisen at the time.
I know, when we came in , we were on the

tail end of a ru1emaking, net versus gross, as
sold was that

clarification,

So I wrapped part

of that

up.

I believe I terminated a couple of

nonuti1ity contracts at the contract holder'

request because they either no longer had the

material or

had,

in fact,

in one case I believe

sold it to the government,

Do you remember any other issues you

worked on during that period?

91 to '
Would that be about

I think we began to discuss

delivery commitment schedules at that point.

right?

That would be about

right.
That would also have included exchange
of approved delivery commitment schedules?

Actually my recollection is that we discussed exchang~s not concurrently, because
there was the opportunity to do that a little

later.

And it

was more important given the

timing requirement in the contract to have
ALDERSON REPORTING COMPANY , INC.
1111 14th ST. ,

that

(202)289- 2260 (800) FOR DEPO N. W., 4th FLOOR WASHINGTON ,

D.

C., 20005

-:::-~ ,.-...",

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 12 of 25

guidance issue. And guidance as to what to do wi th delivery commitment schedules themselves?
How to fill them

the

believe,

if I' m not incorrect,
form,

out, instructions.

that that' s

an OMB

reviewed form.
to complete the

And you know that

process, that

takes time and there must be instructions on how

What was the time

concern?

I believe the contract requires

delivery commitment schedules to be submitted by

the purchaser 63 months in advance of the year in

which they have an

allocation.

So back it out

from 1998,
, 92

and they would have been submitting in

late ' 92.
Are there any other issues that you

recall working on in the

' 91 to ' 93 period?
And nothing else

Let'

s see.

I know we addressed

priority for shutdown

reactors,

comes to mind right now,
What about the period

' 93 to ' 95, what
I believe

issues did you work on?

During that time

period,

worked on delivery commitment schedule exchanges
many of the same things from '

91 and ' 93, the

ALDERSON REPORTING COMPANY, INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON ,
D.

C., 20005

-:,\

' .

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 13 of 25

acceptance, priori ty ranking,
report, DCS review and

the annual capaci

approval.

We began conversations about

final

delivery schedules and what would be included in

those,

safeguards and security, and that was

policy development.

I know tha t

I worked on

numerous reviews of system baseline

documents,
kept

system requirements documents primarily from a

waste acceptance standpoint. And I know we working on priori ty for shutdown reactors.
by just a couple of these categories.

Let me ask you to clarify what you mean

Safeguards

and security, what was involved with safeguards

and security?
NRC regulations require that a licensee
have in place a safeguards and security

system,

And that means physical security as in physical

protection.

And that physical protection
veness of the material

based on the at tracti

would someone want to steal it to make a bomb.
They also require as another subelement

material control and
if you

accounting.

That is

that,

as a utility tell me that you ' re giving me
you have to provide me with some

ten MTU,

documentation to give me confidence that you
ALDERSON REPORTING COMPANY , INC.
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON, D. C., 20005

are;

"'--"' ..---

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 14 of 25

137

reorganization, But otherwise it'
group?
Yes,

s basically the same

I do believe there was a separate

transportation program at the time that UNWMG

existed,

And I do not recall the name of the law

firm that managed that, but I believe that was
consol ida ted wi th UWASTE,

If you could turn to page 761 in the

compilation,

Do

you

see the first

issue listed
fuel

as being of a priori ty

to DOE was whether or not

there should be any exceptions to the oldest

first priority ranking; do you recall that issue?

Yes,

The issue there was do I have to

give you my oldest

fuel.

And, from the utility
I have fuel

perspective,
in the lower

I have fuel in my pool

forty,

I would prefer to give

you

the newer fuel which is in my pool and free up

space the.ce
20

m not interested

in giving

you

the

stuff I' ve

already

canned,

if my oldest fuel is what earns me

a place in the ranking based on its discharge
2 3

dates, must I give that you fuel that earned the

ranking,
2 5
you

And the answer was

no,
Bu t

That fuel earns

a space in the ranking,

on your DCS you

ALDERSON REPORTING CG:\'IPAtW , INC.
(202)289, 2260
1111 14th ST., N. W.. 4th FLOOR i WASHINGTON. D. C., 20005
(8001 FOR DEPO

-Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 Page 15 of 25

138
tell us that you want to give us a range of

fuels; and, as long as it

meets those minimum

conditions, five- year-o1d being the biggest one, So that' s what OFF was about, because
it could have been interpreted
utility perspective,
this was the

It could have been

interpreted to mean that I had to give you the

precise fuel that earned me the slot in the

ranking.
I think I understand,
Let me point

your attention to particular language in the

middle of that column,

Right about in the

middle,

it says the resolution of this issue will

focus on clarifying that the application of the

OFF principle is used only in establishing the
acceptance priority

ranking, should be no exceptions.

and as such

there

Then the next sentence

says, any basis
the
spot
in

other than OFF would result in inequitable
assignment of acceptance capacity among

purchasers,
in the queue?

Why would that be if you just said

that utilities,
the proper

they

ve already earned their

I think you'

re not reading tha t

context,

What they re saying is that

ALDERSO:\T REPORTING CO:\'IPMry , INC.
(2021289, 2260 1800) FOR DEPO 1111 14th ST., N. , 4th FLOOR WASHINGTON, D.

, 20005

"""""

~~
Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004

--Page 16 of 25

205
MR. SHAPIRO:
Why don' t we stop for the

day here and discuss where to go

next.

(Whereupon , at 4:50 p. m., the

depos i t ion adj ourned, to be April 22, 1999, at 2:00 p.

resumed on Thursday,

Signa ture of the Wi

tness

SUBSCRIBED AND SWORN to before me

this

day 0

f ~~~----------------

D2_

My Commission

expires: t~~iQ~-QL~---

NOTARY PUBLIC

Y-~~

ALDERSO~ REPORT~G CO~lPA:\Y , INC.
(2021289- 2260 /800, FOR OEPO 1111 14th ST. , N. W., 4th FLOOR WASHINGTON, D.

, 20005

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 17 of 25

Page
ERRATA SHEET FOR THE TRANSCRI PT OF:

Notice Date: 04/29/99 Yankee Atomic Electric Company v. The United States Case Name: Case Number: 98- 126C

Dep, Date: Deponent: Place:
TS#:

Nancy H, Slater

04/21/99 / Washington , DC
78077

CORRECTIONS:

Page

Line

Now Reads

Should Read

Reasons Therefore

fUrn

*:' ;.", " "~;
Case 1:98-cv-00126-JFM Document 840-8 Filed 07/07/2004 Page 18 of 25
!"~~1'~~,. ;;~~J
'.r.;J; 1 ;v h~"
:v;,;

Yf"'J

2 06

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X

YANKEE ATOMIC ELECTRIC
COMPANY,

Plaintiff,

Case No, 98- 126C
Senior Judge
Me row

THE UNITED STATES,

Defendant.
1 0

- X

Washington, D, C,
Thursday, April 22, 1999
Continued deposition of NANCY
SLATER, a witness herein , called for examination

by counsel for Plaintiff in the above- entitled

matter, pursuant to

agreement,

the witness being

previously duly sworn , taken at the offices of

Spriggs &

Hollingsworth,

1350 I Street, N,

Washington , D, C" at 2:10 p, m" Thursday, April 2 2 , 1999, and the proceedings being taken down by
Stenotype by JAN A, WILLIAMS, RPR, and

transcribed under her direction,

ALDERSON REPORTING COMPANY , INC,
(202)289- 2260 (800) FOR DEPO 1111 14th ST., NoW., 4th FLOOR WASHINGTON ,
D.

C., 20005

............ --..

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 19 of 25

284

Let' s focus on Yankee Atomic perhaps as an example, Was it really expected that DOE would
pick up from Yankee Atomic 9, 9 MTU in the first

year or at

least as

you

get closest to a full

cask that'

s 9, 9 MTU and then it would stop in the

first year and come back in year two, come back
for another 10, 1, year three come back for 9,

year four come back for 8,

and then do nothing

in year five and then have to come back yet again
in year six for 9, this chart?

4 strictly as it'

s indicated on

Yes, that would be my

strict

understanding of this table, yes,
But was that also how DOE expected the
program to work?

My understanding of how the program

would work again

if you accept the premise of

the round up or round down for full cask

loads,

might mean that in any given year

again the

following year is debited for the additional
amoun t ,
that you

might actually complete pickup

ahead of schedule if you made the optimistic
assumption that you were always rounding

up,

There was some discussion

about

campaigning.

Do you understand what I mean by

ALDERSON REPORTING COMPANY, INC,
(2021289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR WASHINGTON, D. C., 20005

...

Case 1:98-cv-00126-JFM

Document 840-8

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Page 20 of 25

285

campaigning?
I think I do,
it for the
But if you

could explain

record.

Campaigning would be that we might

like

to select rather than the first year as the basis for delivery the first three years and in

large

chunks work off three years of fuel for one

utility, work off three years of fuel for the

next,
And this was subject to negotiation
with the utilities obviously because this is not

the unilateral right as I understand it of DOE to

do this,

And in the second year accept the first

year and the second year and the third year from
another utility,

This was discussed with the utilities

and it was discussed as a matter of fact when

was part of the utility

industry,

And the

utilities were not averse to considering that

because again it'
for them.

s an operational consideration

Do I want you to come to my facility
every year and disrupt my operations because
won t be doing anything while we' re loading

fuel

I rather say don' t come the first year
ALDERSON REPORTING COMPANY, INC.
(202)289- 2260
1111 14th ST., N. W., 4th FLOOR
(800) FOR DEPO

WASHINGTON, D. C., 20005

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 21 of 25

286
show up the second year and take my first

year,

my second year, and maybe my third year,
So that was discussed when I was in the

industry,

And I don' t know where that went after

that,

So I have a recollection that the precise

schedule laid out in

here,

alterations to

that

schedule were discussed by the

utilities,
part I

And the campaign was premised in

think as you said on the notion that it would be
more efficient for utilities to have pickups done

in larger amounts than in a series of smaller

amounts?

In fewer years actually,
years, so tha t

in fewer

you weren t showing up every year

with the consequent interruption of operation,

And it was
I think it was DOE'

s understanding that

it would result in -- might result
efficiencies for the DOE transportation system
2 a

well,

So my recollection is that there were

discussions on both sides about efficiencies for

both sides by campaign,

But I' m

not the expert

on campaigning and you would have to talk to the

transportation folks about that.
Let me ask

a couple questions on that

ALDERSON REPORTING COMPANY , INC,
1111 14th ST., N.

(202)289- 2260 (800) FOR DEPO .. 4th FLOOR WASHINGTON, D. C., 20005

---"-""'

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 22 of 25

287
just so I make sure
I understood what you

were

saying, The efficiency from DOE' s perspective to campaigning would be, once you got the transportation campaign going, it was more efficient to keep it going at one time than to
stop it and start it five different times or a

number of different

times,

it doesn' t have to be

five?
I don t recall the

details,

I do

recall that some of the efficiencies included

not

having to retrain personnel on the specifics of
that site three years in a row because you might

not have the same personnel at the same site

again,
So there were efficiencies to be

obtained from that,

And that' s the one that

really sticks in

my mind,

m sure there were

others, but again I' m expert,

not the transportation

Do you recall discussions of this

notion of campaigning after you got to DOE?
I am aware that the issue was

evaluated, but I evaluations, So

was not part of those
I have no knowledge of what was

involved in the evaluation

inputs,

ou tpu t s

ALDERSON REPORTING COMPANY, INC,
(202)289- 2260 (800) FOR DEPO 1111 14th ST., N. W., 4th FLOOR / WASHINGTON ,
D.

C., 20005

. .,

Case 1:98-cv-00126-JFM

Document 840-8

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Page 23 of 25

289
such consideration of campaigning?
I don' t recall who specifically was in

the transportation group at that

time,

In fact,
the
I really

m having a tough time recalling who
transportation division director was,

don' t know,
Going back to this table 2 in Slater

Exhibit 23,

other than the notion of

campaigning,

do you recall any other ways in which DOE or

utilities for that matter might have expected
that actual acceptances of spent fuel might occur
in an order different than what is depicted on
this table?

Plus or minus 20 percent

campaigning,

DCS exchanges

rounding, because, if exchanges

occurred,

although the amount wouldn t change,

the individual utility that would be serviced
that year would,

So that would have represented

a departure from what' s published in
2a

here,

And it

was generally anticipated

that

there would be some amount of DCS exchanges?

Yes, I did anticipate that there would
be some amount of DCS

exchanges,

You said that was your

what extent did you understand

expectation, that that

ALDERSON REPORTING COMPANY, INC.
(202)289- 2260
1111 14th ST. ,
N. W.,

(800) FOR DEPO

4th

FLOOR

WASHINGTON, D. C., 20005

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 24 of 25

312

don t know,

I know that the receipt rates were
I have a vague knowledge of the

established,

basis for their

establishment,

and I know why

changed from 1998, 1999, to year one and year

two,

But I don t think that I can speak to

the

question you ve just asked me,
BY MR, SHAPIRO:

And the reason you changed again from
specific years, calendar years, to year one, year
two, was that you

weren t sure when acceptance

would start?
Yes,
MR.

SHAPIRO:

That'

s all we have.

MS. SULL IVAN:

We cons ider Ms.

Slater

deposition to be

closed,
at 5:10 p.

(Whe reupon,

the taking of

the instant deposition ceased,

Signature of the Witness

SUBSCRIBED AND SWORN to before me

this -

day of
NOTARY PUBLIC

My Commission expires:

~t--

fiQCil-

ALDERSON REPORTING COMPANY, INC.
(202)289- 2260 (800) FOR DEPO WASHINGTON. D. C.. 20005 1111 14th ST.. N. W.. 4th FLOOR

Case 1:98-cv-00126-JFM

Document 840-8

Filed 07/07/2004

Page 25 of 25

Page
ERRATA SHEET FOR THE TRANSCRIPT OF:
Notice Date: 04/29/99 Yankee Atomic Electric Company v, The United States Case Name: Case Number: 98- 126C

Dep. Date: Deponent: Place:
TS#:

04/22/99 /

Nancy H. Slater Washington, DC

78180

CORRECTIONS:

Page

Line

Now Reads

Should Read

Reasons Therefore

Urvd

- S'ign

.

, ure 0 Dep
f'-,,2 -

ent

Date o

Slgnature