- - - - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
---------Filed 07/07/2004 Page 1 of 25
April 10 ,
Document 840-7
2002
McLean , V A
Page 243
(00-440C) (Bush, J.
WISCONSIN ELECTRIC POWER COMPANY
(00-697C) (Merow, S.
POWER AUTHORITY OF THE STATE OF NEW YORK
(00-703C) (Damich, J.
OMAHA PUBLIC POWER DISTRICT
(01- 115C)
(Bush, J.
NEBRASKA PUBLIC POWER DISTRICT
( 0 1 - 11 6 C) (S
yp 0 1 t , J.
TENNESSEE VALLEY AUTHORITY
(01-249C) (Bruggink, J.
Plaintiffs,
Discovery
THE UNITED STATES,
: Judge:
Defendant.
McLean, Virginia
: (Judge
x S yp 01 t )
Wednesday, April 10, 2002
Continued deposition of ALAN
BROWNSTEIN, a witness, recalled for examination
by counsel for Plaintiffs in the above- entitled
matter, pursuant to notice, the witness being
previously duly sworn by CATHERINE S. BOYD, a
Notary Public in and for the Commonwealth of
Virginia, taken at the offices of Shaw
Pittman,
1111 14th Street , N. W.
Alderson Reporting Company, Inc. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
"""",
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Case 1:98-cv-00126-JFM
Alan Brownstein
.,
Document 840-7
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Page 2 of 25
April 10 ,
2002
McLean , V A
Page 343
goal of trying to get a reposi tory approved and
buil t at Yucca Mountain?
Completing the mission of the
program.
Right.
In your view, how likely
is it
that the reposi tory will be designed and
constructed to accept 900 metric tons a year?
MR. BANES:
Obj ection.
Calls for
speculation; lack of
foundation.
The question
THE WITNESS:
confusing to me.
Wha tever the acceptance, whatever the
long term if you will acceptance rate
a several year ramp- up
is,
whatever that number would be, you would expect
period.
Can you read my
MR. TOMASZCZUK:
question back?
THE REPORTER:
Question:
In your
Vlew, how likely is it that the repository will
be designed and constructed to accept 900 metric
tons a year?"
MR. BANES:
Obj ection.
Calls for
speculation; lack of
foundation.
As a steady state? implies?
THE WITNESS:
that what your question
BY MR. TOMASZCZUK:
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 840-7
Filed 07/07/2004
Page 3 of 25
April 10 ,
2002
McLean , V A
As a steady state, I' ll take that
answer.
That'
s fine if you want to put that
clarification on it to help you
answer.
I believe we would, I believe that
would be a low
figure.
I mean every document that you have
shown me shows a higher figure than that for
steady- state
proceedings.
operation.
(There was a pause in the
BY MR. TOMASZCZUK:
Mr. Brownstein, going back to the ACR,
this 1991 ACR, still on page 4, third paragraph
on this page, and there lS a reference in the
first sentence to Table 2.
1.
I think I have asked you some
questions about that.
Yes.
And then the sentence appears this
table, that is, the Table 2. 1, provides only an
approximation of the system throughput rates and
is subj ect to change depending on the system
design and configuration and Congressional
action regarding the condi
of an MRS facili
tions for the si ting
ty?
Alderson Reporting Company, Inc.
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
CaseBrownstein 1:98-cv-00126-JFM Alan
Document 840-7
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Page 4 of 25 10 , 2002 April
McLean , V A
Page 420
utilities assumed.
I mean the statement as I wrote it and
as I meant it, the utili ties started looking
from a planning perspective, assuming that DOE
would begin acceptance in ' 98.
It doesn t mean anymore than
that.
BY MR. HIRSCH:
Now you said, went on to say by the
end of 1998, it is projected that approximately
38, 200 metric tons of spent nuclear fuel will be
in storage at reactor si tes
Um- hm.
across the country?
Do you know where you got that
information?
I probably got that from one of two
sources.
Probably I ei ther got it from an EIA
document, or -- the DOE Energy Information
Administration analysis or report, or a PNL
document.
Now --
the best of
Okay.
my recollection.
until the spent nuclear fuel from utili ties,
1111 14th Street , N. W.
Thanks. goes on to say the federal government begins accept
available
Alderson Reporting Company, Inc. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
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Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 5 of 25
April 10 ,
2002
McLean , VA
Page 421
storage capacity at each reactor site will
continue to decrease, and other alternatives
such as dry storage will be
needed.
Do you know what your basis for making
that statement was?
As each day goes
on, spent fuel is
as they undergo,
produced, and the utili ties,
basis.
have to replace that spent fuel on, on a regular
That spent fuel has to go somewhere on
their si te,
and the first line defense of the
utili ties if
alternatives.
you will is their storage pool, and
space was running out in their storage
pools,
and they were going to have to look at, at
Once they looked at alternatives like
reracking, they would then have to look at
alternatives beyond the storage
pool.
So as of the time you wrote this
document, you recognized that, that nuclear
utili ties were
Tha t
running out of, out of space In
their storage pools, is that correct?
was no
secret.
Eve ryone
understood that.
Okay.
And then you go on to
say,
" As
Alderson Reporting Company, Inc.
111I 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 840-7
Filed 07/07/2004
Page 6 of 25
April 10 ,
2002
McLean , V A
Page 439
MR. HIRSCH:
Sure.
That' s fine.
(A recess was taken.
BY MR. HIRSCH:
Mr. Brownstein, will you look back at
Brownstein Deposi tion
Okay.
Exhibit 38?
Will you look at page 2390?
There
also appears to be a drawing shown here, and
then beneath that, there s some text with four
bullet points.
Do you see that?
Yes, I
do.
Somebody drew through the last bullet
point.
Is that something that you did, Mr.
Brownstein?
I probably would have done
that.
fees
And why did you strike determine
in terms of payment?
It is, in my mind, the waste
acceptance process, the fees in terms of payment
while they
separa te,
re part of the contract,
separate subj ect
Look at page 2391.
Alderson Reporting Company, Inc.
is, is a
from the was
acceptance process.
At the top of
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 7 of 25
April 10 ,
2002
McLean , VA
Page 441
group of utili ties,
know, addi tional
BY MR.
that they were going to have
to, to make those decisions wi th respect to, you
storage at their
HIRSCH:
sites.
ties
And what kind of spent fuel decisions
or commi tments did you understand the utili
were going to have to make?
Oh, as an example, commitments to dry
storage.
And then the last bullet point on this
page is " The
hardships resul ting
from the
uncertainties in the start of acceptance.
What did you understand were the
hardships to the utili ties
MR. BANES:
resul ting from the
uncertainties in the start- up?
Obj ection -- vague.
Calls
for speculation.
THE WITNESS:
To the extent that we
could not identify a particular point in time
when a facility would commence
would put a burden on the
operations, that utilities of what, of
internal decisions that they needed to make in
order to continue to keep their plants runnlng
to accommodate the spent fuel, and so this
statement recognized --
again, I' m
not sure that
II1I 14th Street ,
Alderson Reporting Company, Inc. N. W. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
--..,
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 8 of 25
April 10 ,
2002
McLean , V A
hardships is a word that I would have used, but
purports to indicate in this draft that the
department at least has a recognition if in
fact
not a clear, in fact a clear understanding of
that the utili ties have
BY MR. HIRSCH:
been affected by
that.
The DOE recogni zed that the
uncertainties about when the DOE would start
acceptance would cause burdens on the utili
ties,
is that correct?
Sure. There
Yes.
s a -- strike
that.
And one of
the burdens would be, would it not, having to
determine or provide al ternati ve storage, is
tha t
correct?
MR. BANES: THE WITNESS:
Obj ection -- vague.
Maybe I can use an
example, and the way best way to respond to you,
if we were going to be 30 days or 180 days or
360 days beyond a certain date, and then begin
the waste acceptance
process, the utili ties
would find a, a low capital cost alternative to
accommodate their spent fuel, whether it be
reracking or transferring to another facili ty.
It would not invest in mul ti- million
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 840-7
Filed 07/07/2004
Page 9 of 25
April 10 ,
2002
McLean , V A
Page 443
investment in dry storage
BY MR. HIRSCH:
capability.
But if the DOE was golng to miss the
acceptance date by a long period, say
12 years,
then the utili ties might be forced to engage in
those high- cost,
high- capital alternatives,
correct?
MR. BANES:
Obj ection.
Calls for
speculation.
THE WITNESS:
It, it is, it is
possible.
Again, we made no secret of this
program, where we were and the difficul ties of
commencing facility operations, and we also made
it clear in all the documents that we reviewed
that until that time, we believed it was the
utilities '
responsibility, so you know, that
burden exists on the, existed on the utilities.
I should say that responsibility.
BY MR. HIRSCH:
And so in DOE' s Vlew , if the
government was going to miss the 1998 acceptance
date by 20 years say, that entire burden of
storing waste was the utili ties
The, the statements, and if
necessary,
1111 14th Street , N. W.
Alderson Reporting Company, Inc. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
--""
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 10 of 25
April 10 ,
2002
McLean , V A
Page 452
reporter mark
something.
42.
This is an accompanYlng document to
this, so let' s go ahead and mark this as
(Brownstein Exhibits Nos. 41
and 42 were marked for
identification.
THE WITNESS:
Okay.
BY MR. HIRSCH:
Mr. Brownstein, I have handed you what
has been marked as Brownstein Deposition Exhibi
41 and Brownstein Deposition Exhibi t
42.
Brownstein Deposition Exhibit 41 is a
memorandum for the Secretary from Dan
Dreyfus.
It has Bates labels HQR-00I-0339 and
HQR- 001-311 through
312.
Can you identify these documents?
Can I?
Wha t
they are.
Yes.
Can you tell me what you understand
they are?
Sure.
They re, as I said, they
recommendations to the Secretary to approve the
department'
s issuance of a Notice of Inquiry
regarding waste acceptance lssues.
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 840-7
Filed 07/07/2004
Page 11 of 25
April 10 ,
2002
McLean , VA
Page 453
And did you prepare Exhibi t
the text, that is?
41 and 42,
Yes.
And I guess Exhibi t
the Secretary of Energy?
42 shows that it
was approved by the Secretary, is that
correct,
Yes.
That would have been Hazel 0' Leary, is
that right?
Yes. Yes.
That doesn
t look like
yes.
column of
And on the right- hand
Exhibi t 41, on the second page, everybody signed
off on this memo before I guess it went to the
Secretary, is that correct?
That' s correct, um-hm.
You see in the discussion section
Looking at 41 or 42?
m sorry.
first page.
Let'
s look at 41, the
Okay.
On the discussion section, first
paragraph ,
second sentence, it
says, " While
it
is the Department' s preliminary view that the
Act does not impose a statutory obligation to
1111 14th Street , N. W.
Alderson Reporting Company, Inc. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
--,
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 12 of 25
April 10 ,
2002
McLean , V A
Page 455
the mission plans and the ACRs, the DOE had
created an expectation it would begin accepting
spent fuel in 1998, is that correct?
I would not
MR. BANES:
Calls for legal
conclusion.
THE WITNESS:
No, I would not include
the mission plan in that because the mission
plan was part of the statute, not part of the
contract, but the rest of that statement was
accurate.
BY MR. HIRSCH:
All right.
So for example, by issuing
the ACRs, the department could have created an
expectation it would begin accepting spent
in 1998, is that correct?
MR. BANES:
fuel
Obj ection.
Calls for a
legal conclusion.
THE WITNESS:
May have created an
expectation.
(There was a pause in the
proceedings.
BY MR. HIRSCH:
25 the on the first page of Exhibi t 41 -Alderson Reporting Company, Inc.
I1I1 14th
24 I
Q. At the, under the lssue heading at
Street, N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
-.
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 13 of 25
April 10 ,
2002
McLean , V A
Page 456
Okay.
Do you see a reference to eliciting
the views of interested parties on several
issues, one,
three?
they re listed as one, two and
Yes.
And the third option is options
through the nuclear waste fund to offset a
portion of the financial burden which may be
incurred by utili ties
is that right?
in continuing to store
spent nuclear fuel at reactor sites beyond 1998,
Yes.
What was your understanding at that
time of what the financial burden was to the
utili ties for
1998?
storing spent nuclear fuel beyond
MR. BANES:
Objection -- asked and
answered, and calls for
THE WITNESS:
speculation.
Things like adding dry
storage to accommodate the spent
BY MR. HIRSCH:
fuel.
Q. Mr. Brownstein, did you have any
discussions at the DOE that the DOE'
s inability
to start accepting waste could delay reactor
1111 14th Street , N. W.
Alderson Reporting Company, Inc. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
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Page 14 of 25
April 10 ,
2002
McLean , V A
Page 457
decommissioning?
I was aware of that, and you know,
over ten years dealing wi th
the subj ect,
considered I would certainly have had a
discussion about that, but I don t recall a
specific discussion, but I may
have.
You
Well, let me put it this way.
were aware I take it of the possibility that the
DOE' s failure to pick up spent nuclear fuel
could cause utili ties
MR. BANES:
to delay reactor
decommissioning, is that correct?
Obj ection -- misleading.
Calls for speculation.
THE WITNESS:
Yes.
BY MR. HIRSCH:
Were you informed of that by
utilities?
I don t have a specific recollection
of that.
Did your contractors study those
issues?
They may have.
Do you recall any particular studies
done by PNL or your other contractors on that
issue?
1111 14th Street , N. W.
Alderson Reporting Company, Inc. Suite 400 l- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
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Filed 07/07/2004
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April 10 ,
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Page 467
CERTIFICATE OF NOTARY PUBLIC
I, Catherine S. Boyd, the Notary
Public before whom the proceeding
occurred,
pages 242 through 466, do hereby certify that
the wi tnes
s
was duly sworn, that the testimony
of said witness was taken by me and thereafter
reduced to this typewritten transcript under my
supervision, that said transcript is a true
record of the testimony given by said
witness,
that I am neither counsel for, related to, nor
employed by any of the parties to this
proceeding, and further, that I am not a
relati ve or an
employee of any attorney or
counsel employed by the parties thereto, or
financially or otherwise interested in the
outcome of the proceeding, or any action
invol ved therewith.
Witness my signature and
seal:
CATHERINE S. BOYD
Notary Public in and for
The Commonwealth of Virginia
My commission expires:
February 28,
1111
2006
Alderson Reporting Company, Inc. 14th Street , N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 840-7
Filed 07/07/2004
Page 16 of 25
CERTIFICATE OF NOTARY PUBLIC
I, Cather
Pub 1 i c
i ne S. Boyd,
the Notary
befo re whom the proceed
i ng occu r red,
pages ---- through ---- '
the wi tness was duly
do hereby cert i fy that sworn, that the test i mony
of sai d wi tness was
reduced'
taken by me and thereafter
to this typewritten transcript under my
supervision, that said transcript is a true
reco rd of
the tes t i mony gi yen by sa i d wi tness ,
i es to the
that I am nei ther counsel for, related to, nor
employed by any of the part
proceedi ng, and further, that I am not a
re la t i ve 0 r an employee of any at to rney 0
counsel employed by the part i es thereto,
financially or otherwise interested in the
outcome of the proceeding, or any action
i nvo 1 ved the rewi th .
Witness my signature and
seal:
r1;
CATHERINE S. BOYD
Notary Publ i c in and for
The District of Columbia
My commission
expires:
August 31, 2002
. ..:',.
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- - - - - - - - - - - - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
Washington, D.
Document 840-7
Filed 07/07/2004
Page 17 of 25
May 23, 2002
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98-
126C)
(Merow, S.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C) (Merow, S.
MAINE YANKEE ATOMIC POWER COMPANY
(98- 474C) (Merow, S.
Plaintiffs,
CERTIFIED CC
THE UNITED STATES,
Defendant.
Washington, D . C .
Thursday, May 23, 2002
Deposition of ALAN BROWNSTEIN, a witness
herein, called for examination by counsel for
Plaintiffs in the above-entitled matter, pursuant to
agreement, the wi tness
being duly sworn by JAN A.
WILLIAMS, 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.,
20005- 3305,
at 8:40 a. m.,
Thursday, May 23, 2002, the
proceedings being taken down by Stenotype by JAN
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
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,,Document 840-7
Washington, D.
Case 1:98-cv-00126-JFM
Alan Brownstein
Filed 07/07/2004
Page 18 of 25
May 23 , 2002
Page 104
the contract, the DOE would make adjustments from
time to time in the queue, if you will, the APR
ranking, based on reinserted fuel
is that right?
Yes.
And that was -- as I recall that was
one of the issues.
To get in the queue, it had to be
based on the date of final
discharge. Utili ties
could have, you know, subsequent to its, you know,
final discharge date decided for other reasons to
reinsert that fuel.
there.
And then that fuel which created
the place in the queue was no longer -- no longer
So what do we do.
That was an issue.
Was that issue ever resolved?
To the best of my recollection somewhere,
whether it was in the APR or some
think we addressed
instructions, I
I don t remember the
it.
I don t recall offhand, but I
think we addressed the subj ect .
details.
It was published, whatever we did.
Now, you said earlier, when we were
talking -- when we were discussing
exchanges, that
you were aware or the department was aware that these
approved DCSs had different value to different
utilities?
Well, what I said was could
have.
Okay.
What do you mean by that, why did
25
you have an understanding, why did the department
Alderson Reporting Company, Inc.
tIll 14th Street ,
N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
'--Case 1:98-cv-00126-JFM
Alan Brownstein
.-.
Document 840-7
Washington , D.
Filed 07/07/2004
Page 19 of 25
May 23 , 2002
Page 105
have the understanding that the approved DCSs could
have different value to different utilities?
MR . CRAWFORD:
Objection, compound; and
objection, vague;
objection, foundation.
If you take two utilities
THE WITNESS:
that had, you know, different places in the
queue,
a
their situations on, for instance, their cost of
storage could have been different.
couple of examples.
I I 11 give you
Maybe one utility had an early allocation
that would have been easy for them to rerack or, you know, they had already made the capital costs for a storage facility or had excess storage capacity
wi thin their pool.
The value -- we believed the value of that
place in the queue to that utility was less than a
utility that,
maj or capi tal
if they did not receive the services in
that particular year, they would have had to make a
expense.
So you can see a natural
imbalance to the utilities themselves and the value
of receiving fuel at any particular
time.
And, if there was that imbalance, we
assumed, certainly the contract allowed for, you
know, a market to develop.
And we were going to then
be a part of that because the contract required us to
Alderson Reporting Company, Inc.
IIll 14th Street ,
N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
'-Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Washington , D.
Filed 07/07/2004
Page 20 of 25
May 23, 2002
pprove it,
~en the
gover=en t has to approve
it.
Page 106
We wanted to be careful how
interfered with the marketplace.
we, quote,
And there were
these issues, these technical issues that, if we
resolved together, would have -- again, since these
were primarily equity issues, not issues of key
importance to us, we wanted to do as little as
possible in interfering with the
market.
That was my
rationale in how these -- how this subject
BY MR. STOUCK
developed.
And that was a subject that
12 '
you, that
being a subj ect
of exchanges of DCSs, approved DCSs,
that was something you certainly had responsibility
for?
Yes.
And you wanted to be careful in not
interfering too much with this marketing DCS
exchanges because, as a general proposition, you know
markets are good, you wanted to allow the utilities
to pursue presumably their self interest in making
economic exchanges; is that what was behind it or was
there something else behind it?
MR . CRAWFORD:
Objection, compound.
THE WITNESS:
Markets are efficient.
And
the efficiency of that market increases with the
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Washington, D.
Filed 07/07/2004
Page 21 of 25
May 23 , 2002
Page 107
information that I s available.
Whether it
be the -- who has got what place in the queue or how
the rules are going to be interpreted and
applied.
It I S one of
went out of our way.
the reasons we did some -- we
When we decided to move forward
wi th the APR process, we did something very strange I
think.
hey, we
We went out and published a draft APR and
sort of alerted to the utili ties as
I re going
look at this.
best as we
could,
to do this, please take a serious
We tried to do everything we could that
the department would minimize its interference in the
markets.
I hope that I s responsive
BY MR. STOUCK
Tha t'
to your question.
s very respons i ve .
But I guess we
still left with the fact on this same subject that
there were these -- it I S my understanding that this
ACR issue resolution process, and my recollection is
34 or maybe 36, but some number like that, those
issues were never resolved, at least many of those
issues were never resolved?
MR. CRAWFORD:
THE WITNESS:
Objection, overbroad.
First of all of
those,
whether it was 34 or 36, did not -- were not
associated with this particular
issue. Let me see.
Alderson Reporting Company, Inc.
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Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Washington, D.
Filed 07/07/2004
Page 22 of 25
May 23, 2002
Page 108
There I S another part of the question.
There was some number, yeah.
You did what
with the APR in terms of getting
information out to as I understand your testimony sort of lay the groundwork, if you will, to the
extent possible for an efficient market mechanism?
Tha t was certainly our mot
i ve .
Okay.
That was your motive in getting
this APR out, at least getting the APR out for
comment and making sure people took it took
seriously, took their obligations to give you the
best data you could getting the RW- 859s?
Right. But nonetheless, notwithstanding that
motive and those actions with respect to the APR,
there were, , were there not, some number of issues in
the issue resolution process that did have a bearing
on exchanges or at least could that were not
resolved, right?
MR . CRAWFORD:
Objection, vague,
overbroad.
BY MR. STOUCK:
Is that right?
Yes, the subset of those 34 issues that
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 I- 800- FOR- DEPO Washington , DC 20005
110.
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-7
Filed 07/07/2004
Page 23 of 25
May 23, 2002
Washington, D.
Page 245
Thank you.
(Whereupon, at
4: 25 p. m., the
depos
i tion
adjourned.
/LJ
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
:J u.
1/')
i I;
day
IJ-I!.-
20
4uScO(;; t~ I/.
NOTARY PUBLIC
My Commission expires:
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1111 14th
Streef~. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Alderson Reporting Company, Inc.
Case 1:98-cv-00126-JFM
Document 840-7
Filed 07/07/2004
Page 24 of 25
Eh ATA SHEET FOR THE TRANSCR. .. OF:
Notice Date: May 28 , 2002 Case Name: Yankee Atomic VS. United Case Number: 98- 126C- 987 4C Dep. Date: ' May 23 , 2002
States
Deponent: Alan Brownstein (continued)
Place: Washington DC
Ref. No. : 4269-
CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
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Signature of Deponent
Date of Signature
0L-
.-'
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
Washington, D.
Document 840-7
Filed 07/07/2004
Page 25 of 25
June 14, 2002
Page 246
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C) (Merow, S.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C) (Merow, S.
MAINE YANKEE ATOMIC POWER COMPANY
(98- 474C) (Merow, S. J. )
C2:RTHFIED CO~iy
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
Plaintiffs 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. 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