Alan Brownstein Case 1:98-cv-00126-JFM
Document 840-6
Filed 07/07/2004
April Page 1 of 26 9, 2002
McLean, VA
Page 9
Whereupon,
ALAN BROWNSTEIN,
was called as a witness by counsel for
Plaintiffs, and having been duly sworn by the Notary Public, was examined and testified as
follows:
EXAMINATION BY COUNSEL FOR PLAINTIFFS
FLORIDA POWER AND LIGHT COMPANY,
NORTHERN STATES POWER COMPANY, DUKE
POWER, INDIANA MICHIGAN POWER COMPANY, BOSTON EDISON COMPANY, GPU NUCLEAR,
INCORPORATED, POWER AUTHORITY OF THE
STATE OF NEW YORK, OMAHA PUBLIC POWER
DISTRICT, NEBRASKA PUBLIC POWER
DISTRICT:
BY MR. TOMASZCZUK:
Mr. Brownstein, would you state your
name for the record, please?
Alan Brownstein.
And by whom are you employed, sir?
Department of Energy.
And what is your title? I m a director of the Regulatory
Coordination Division, and Il m
Alderson Reporting Company, Inc.
on detail right
111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM Alan Brownstein
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1 ~now as a
special advisor to the, special, senior
policy advisor to the director.
You said director of regulatory
enforcement division?
Regulatory Coordination. And I I m sorry -- senior policy
advisor?
Right, to the director; that I s
detail right now.
To the director of OCRWM?
Of OCRWM.
13 of Energy, correct?
And that is all within the Department
15
14
A. Right. Um- hm. Q.
My name is Alex Tomaszczuk.
We met
prior to going on the
record.
m counsel for various of the utility
plaintiffs in this
case.
I I m going to ask some questions about
your knowledge with respect to the management of
spent nuclear fuel.
If you don
t understand my question,
please tell me, and I I 11 try and rephrase it so
that -Okay.
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Case 1:98-cv-00126-JFM Alan Brownstein
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economics from the Pennsylvania State
University.
And what year did you obtain your
Bachelors Degree?
1973.
And in what year did you obtain your
Masters?
1975.
Did you undertake course work for a
Ph.
I did not.
So you stopped your formal educational training after obtaining your Masters Degree?
That I S correct.
15
Can you summarize for me your
employment history after graduating from
college?
I worked at Penn State in a research
unit, was a consultant to the Pennsylvania
governor I s energy
council from 1 75 to 1
78.
In 1978, I went to, moved to General
Public Utilities, and worked there until 1980;
1980 to 1985, I worked for the General
25 I have worked for the Department of Energy.
Alderson Reporting Company, Inc.
24 Accounting Office, and from 1985 to the present,
111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
....
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And that was a promotion for you at
the time?
Yes.
And what GS position or SES position
are you in now?
Fifteen.
And at what point in time did you get
promoted from a GS- 14 to a 15?
In the early
the exact date.
' 90s;
I don' t remember
It' It'
position.
s a GM.
m sorry.
Say that again.
s a GM- 15.
It'
s not an SES
It'
17 ,.
s a GM- 15?
Yes.
Now you re here today as a Department
of Energy employee, correct?
Correct.
And you' re represented by counsel for
the Department of Justice?
I am.
Do you hold any professional licenses?
I do not.
Subsequent to the receipt of your
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since moved on to other positions.
Okay.
And are there individuals that
are employees of contractors that provide
support to DOE with whom you work closely?
We' re talking about the Regulatory
Coordination Division.
Yes.
Is that correct?
Correct.
I have contractors both at Booz Allen
and at the M&O, BSC.
What periods are you talking about?
Why don' t we take today?
going to work backwards a little
And I'
bit.
people,
At Booz Allen, my main contracting support is Richard Goffi and his team of
but mainly Richard, and the current M&O
contractor, BSC,
would be David Siefkin, but
understand I have been on detail for the past
eight or nine months, so I have not worked very
closely with Siefkin.
Okay.
You have been on detail for the
last eight or nine months as a senior policy
Right, since July I
believe, of last
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1 hear.
So since July of 2001?
Page 28
That'
s correct.
It has been longer
than eight months, yes.
And since that period, you have been
on detail as a senior policy advisor to the
director of OCRWM?
Correct.
And who has been that person?
Lake Barrett.
And is Mr. Barrett still serving as
the director of OCRWM?
No.
He is deputy director.
So are you now reporting to someone
else in that, in your capacity as senior policy
advisor?
The new director was conf irmed two or
three weeks
ago.
Her name is Margaret Chu, C- h-u.
And my question , sir, is are you now
reporting to Ms. Chu?
Well, my direct, my first level
supervisor is Ron Milner.
25 advisor to the director of OCRWM, your first
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
In your capacity as a senior policy
Case 1:98-cv-00126-JFM
Alan Brownstein
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level supervisor is Mr. Milner?
That I s correct.
All right.
He is the chief operating officer.
And then above him, you report to Mr.
Barrett?
That'
s correct.
The reporting chain
is Milner, Barrett, and now Chu.
And so would it be fair to say that
you
re also reporting to Ms. Chu at this time?
11 ,
A. Q.
It would be.
What have been your duties as a senior
policy advisor to the director of OCRWM?
Principally I have been responsible
for site recommendation
activities.
What do you mean by site
recommendation activities?
All the work leading up to the
Secretary
s recommendation to the President and
the President' s decision to recommend a site for
development of deep geologic disposal , which he
did in February.
And when you say the site , you
referring to Yucca Mountain, correct?
I am.
Ii'
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Is Mr. Barrett retiring?
He is.
Are you considering leaving DOE?
I am not.
Have you discussed the possibility of
leaving DOE with Mr. Barrett?
Of my leaving DOE?
Yes.
No.
Mr. Brownstein,
would like to go back to 1985 when you first became a DOE
employee.
Okay?
What position did you assume at that
time?
Position title in ' 85 was a nuclear
industry specialist.
Do you recall in what month in 1985
you began service at DOE?
September.
What were your duties as nuclear
industry specialist?
I was responsible for implementing the
terms of the standard disposal
contract.
I ran the, was responsible for the
data inputs that we received from the utilities
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called the RW- 859
information.
I also ran the graduate fellowship
program.
Those were my primary
responsibilities.
What were your duties with respect to
the graduate fellowship program?
Running it;
I mean I had
responsibili ty for selecting candidates to
serve, you know, in the fellowship program, so you know, I was the man responsible for
implementing it and running
Q.
positions?
it.
And that' s a program under which DOE
brings in talented people to work in fellowship
We support -MR. BANES:
Objection -- vague.
BY MR. TOMASZCZUK:
Do you understand my question?
just trying to get a feel for what the program
is.
A. We, we supported 20 fellows a year in
So these would be graduate fellows
their graduate work in fields of importance to
our program.
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working on nuclear engineering projects?
It could be.
We supported people
in,
I believe in health physics.
I believe we supported people in
policy-related positions, so it was not limited
o just engineering.
Q. What were your duties with respect to ,
implementing the terms of the standard disposal
contract?
MR. BANES:
Objection -- overbroad.
BY MR. TOMASZCZUK:
I believe that' s the term that you
used.
You said one of your duties was to
implement the terms of the standard disposal
contract, is that correct?
Sure.
And what --
Well, let me give
examples.
The
contract required issuance of something called
the Annual Capacity Report.
Tha t had never been
done before, and so as an example, I was responsible for developing
that.
I was responsible for interacting with
25
~he utilities and
ans_ring their questions.
--"""II
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I was responsible for implementing
various items as a refund program as we had lost
a lawsuit, actually we lost two lawsuits, and I
was responsible for refunding money to the
utilities, responsible for collecting data on
spent fuel from the utilities, the RW- 859.
Those are examples.
Did there come a point in time in your
career at DOE when you, when your duties changed
from your duties that you just described as a
nuclear industry specialist?
The, the position itself evolved over
time.
Let me give a broad outline, see if
that'
s responsive to your question.
Please.
In 1985 when I started that position,
I was basically a one- person show doing these
type of activities with contractor
support.
Over time, that position evolved into
a branch of which I was the branch chief, and
eventually that position evolved into a
division, and each time, the responsibilities
got a little bit broader.
Okay.
Thank you for that.
That' s .-J
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helpful.
When did the duties that you were performing as a specialist evolve into a branch
chief position.
I do not recall the exact dates.
believe in the late
' 80s,
it went to a branch,
and I believe in the early '
division.
90s, it went to a
I just don' t recall the exact times.
And when it became a division, what
was the name of the division?
Well, let' internally.
s see.
They do this
The branch was called I believe
Utility Interface and Logistics
Branch.
m hesitating because I believe the
division underwent several names, and I actually
just don' t recall
it.
I have to review my
resume.
I didn' t do that before I came
here.
Does the division, whatever its name,
still exist today?
It does.
I mean it' s continued to
evolve.
And is it the Regulatory Coordination
....oil
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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1 j Division?
It is not. It is not.
Okay.
What is its current
name, if you know?
I don
t know.
I left, I left that
area in early 1
95.
When you say you left that area, what
area are you referring to?
m sorry.
I left the, my, my
responsibilities, talk about it
broadly,
interacting with the utilities, and
responsibility for the contract, I left that I
believe in March of 1 95 to go into the division
director for the Regulatory Coordination
Division.
Over this long span of time, names of
divisions have changed and evolved and
responsibili ties, and I have not kept very
I closely associated
Okay.
or attached to
that.
You assumed the position of the
director of the Regulatory Coordination Division
in March of ' 95?
To the best of my recollection.
Okay.
That I S fair.
It has been a
little while I understand.
All I can ask you is
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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your best recollection, and I thank you for
it.
Page 37
Okay.
SO it I S fair to
ten- year per iod ,
That I
you were
say then for roughly responsible for
a
implementing the terms
of the standard contract?
fair.
that regard, you were
And in
wi th
dealing
the
utility industry?
That I S
fair.
And in or about March of 1985, your
duties changed?
95.
95 -- I' m
sorry.
That I S correct.
In March of 1995 when you assumed the
position of director of regulatory
was that a promotion for you?
coordination,
No.
Was it a lateral move?
That I S correct.
And why did you make that move?
The director asked me to take on those
responsibilities, Lake
Barrett.
There was, there was other, as I 1
thinking back on it, there was other periods.
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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That would it
be fair to say that in
dealing with regulatory matters, you have less
contact with the utilities and more contact with
the regulatory agencies?
In a relative sense,
sense, yes.
not absolute
You testified, Mr. Brownstein, that
you were responsible I believe for preparing the
ACRs, is that right?
Correct.
11
:::e r
~he ~~s f :::
prepare?
Over time, responsibility for the
i c
;:u t
1 :::e :o
than
Annual Priority Ranking, those were two separate
independent -- the Delivery Commitment
Schedules, it
was a separate document, so those
were the two, in the
I 80s, those
were the two
documents I was responsible
for.
You said the Delivery Commitment
Schedule you view as part of that process?
Yes, but not as a separate independent
report like the ACR and APR.
25 process?
But you had responsibility for the DCS
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
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Yes.
other than the ACRs, the APRs, and the
DCS, were there other documents for which you
had responsibility to prepare?
When you say responsibility to
prepare, those never, those two documents didn
exist, so when I say had responsibility to prepare, I mean starting from conceptually to
how we I re going to do
it.
Those were unique
documents.
I had responsibilities, for
instance,
on the RW- 859 form and worked with utilities in
trying to modify that and trying to implement
those terms.
The Energy Information Administration
was responsible for implementing that, but that
in essence worked as a contractor for my
office,
so we worked closely with the utilities to try
to streamline the information that we felt we
needed and minimize the burdens on the
utilities.
I view that as a different category of
document.
You had no role, if I understand your
testimony, when you came on the scene, you had
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MR. TOMASZCZUK:
Ms. Reporter, I'
going to hand you and ask you to mark as
Brownstein Exhibit 2 an excerpt of a June 1985
document entitled, " Mission Plan for the
Civilian Radioactive Waste Management Program,
and I think I can represent it reflects the
Table of Contents and the, I believe the first
28 pages of that mission plan.
(Brownstein Exhibit No.
was marked for
identification.
BY MR. TOMASZCZUK:
Do you recall that
Brownstein Exhibit 2?
document,
Yes.
And it is an excerpt of the June 1985
mission plan, is that correct?
To the best of my recollection, it is
All right. And
m aware of
you I re
familiar with
this document, are you not?
it.
I have read pieces
of it.
You didn'
t prepare it, did you?
That I s correct.
Do you know who did?
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Page 58
I do not recall.
This
is, the date is
recall
June
85.
It was before my
I appreciate that.
time.
Do you
whether you read this document at or about the
time you became a DOE employee or shortly
therea f ter?
I believe I read excerpts from
it.
Did you use the document to implement
the terms of the standard contract?
I used -- yes, in
part.
And what parts did you use?
I used the waste acceptance
rates.
Hesitation in the response is whether I used the
I 85 or the subsequent mission
plan.
I don' t recall which, but I certainly
used the mission plan or its predecessor
documents for the waste acce
Q. Do you know whether there was an
earlier version of this mission plan?
I don
tance rates.
t believe there was.
The reason I ask, sir, is because I
believe you used the term this document or its
predecessor. I was trying to -Subsequent documents; it I S amended
documents after.
m sorry.
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THE WITNESS:
It may have been a
goal.
I mean I was not with the program and had not
seen this document.
May have been a goal, but in terms of
the policy with respect to the contract, I don'
believe that reflects
that.
testimony that you
BY MR. TOMASZCZUK:
And it I S your
you can recall?
haven I t seen this document before today as best
As best I recall, I have not seen this
document.
(There was a pause in the
proceedings.
BY MR. TOMASZCZUK:
Let I S go back
to Brownstein Exhibit
which was the June 1985 mission plan.
And I believe you testified if I
understood it,
Mr. Brownstein, that you used the
waste acceptance schedules in the mission plan
to implement the terms of the contract?
And -MR. BANES:
Obj ection
.
Go ahead.
BY MR. TOMASZCZUK:
I understood that to be your
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testimony?
In the mission plan or the mission
plan amendments.
Okay.
And how did you go about doing
that?
Explain to me what you mean by
that.
My responsibilities did not include developing a waste acceptance rate that was done
by other parts of the program, and in order to
complete the things that I was responsible
for,
we needed a waste acceptance rate, and I used
documents available elsewhere in the
program.
Who was responsible for developing the waste acceptance rates reflected on page 26 of
Exhibit 2?
I don' t recall.
As I testified, this
document came out before I was an employee, so I
don I t know who, who was responsible for
I don
that.
t recall who was responsible for
that.
What office within DOE was responsible
for preparing this data, do you know?
OCRWM .
Was there a division or branch within OCRWM that was responsible for preparing the
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it not?
It does.
MR. BANES:
Obj ection.
Calls for a
legal conclusion.
THE WITNESS:
Okay.
m sorry.
does.
It says that in the
contract.
BY MR. TOMASZCZUK:
Do you have an understanding of what
that term means, planning purposes only?
MR. BANES:
Obj ection
.
Calls for a
legal conclusion.
You can answer.
THE WITNESS:
Okay.
I believe I
do.
I believe I did, and I believe I do, and I tried
to take my beliefs, the department
I s beliefs,
and write them into this document, which is
under, under the entire Chapter One of the
document, so we tried to explain what it
meant,
what its purpose was, what it did, and what it
didn
t do.
BY MR. TOMASZCZUK:
When you say Chapter One of the
document, what were you referring to?
The beginninq on page 1.
25 ~
Is there a particular language that
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1 ~ explicates
means?
what the term planning purposes
MR. BANES: legal conclusion.
Obj ection
.
Calls for a
You can answer.
THE WITNESS:
I believe the key
sentence in my mind is under Section 1. 1 .
The last, the next to last sentence in
that first paragraph says as specified in the contract, the ACR is for planning purposes only
and thus is not contractually binding on either
the DOE or the purchasers.
So it was a planning document.
BY MR. TOMASZCZUK:
Just -- so it I S a planning
required by the
Yes.
understand your
you under
con tr
document
act?
testimony; were
time
pressure to get this document
out?
The contract, if I recall correctly,
specified I believe both a, a month and a day
and a year for the document I
believe.
If I told you the contract in part
said beginning not later than July 1 , 1987, DOE
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Were those rates consistent with the
let ter
and spirit of the NWPA and the
MR. BANES:
con tr
act?
Obj ection.
Calls for a
legal conclusion, and vague.
THE WITNESS:
The letter and spirit
you I re referring to in that paragraph was
responding to Mr. Kraft I s concern
of his
letter.
His concern was that the department
would fulfill whatever its obligations were
through accepting a single
assembly.
We tried to address that concern in
this paragraph in those words, so -BY MR. TOMASZCZUK:
And as I understand it, acceptance of
one spent fuel rod would not be consistent with
the letter and spirit of the NWPA in the
contract in your mind?
18
I would agree with that
statement.
All right.
A little further down on
this same page, in paragraph, page 2, there is a
reference and a sentence that reads as required
by the contract, these schedules will serve as
the basis for developing contractually binding
Delivery Commitment Schedules in 1991?
Yes.
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Page 242
CERTIFICATE OF NOTARY PUBLIC
I, Catherine S. Boyd, the Notary
Public before whom the proceeding
occurred,
pages 1
through 241, do hereby certify that the
witness 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 relative 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
involved therewith.
witness my signature and seal:
CATHERINE S. BOYD
Notary Public in and for
The Commonwealth of Virginia
My commission
expires:
February 28, 2006
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CERTIFICATE OF NOTARY PUBLIC
I, Cather
Pub 1 i c
i ne 5. Boyd,
the Notary
befo re whom the proceed
i ng occu r red,
pages
th rough
duly swo
, do hereby cert i fy that the
wi tness was
rn, that the tes t i mony of
ten t ransc
r i pt
sa i d wi tness was taken by me and thereafter
reduced to th is
typewr it
under my
supervision, that said transcript is a true
record of the testimony given by said
witness,
that I am nei ther counsel for, related to, nor
emp loyed
by any of the part i es to th
proceedi ng, and further, that I am not a
relative or an employee of any attorney or
counsel employed by the part i es thereto, or
f i nanc i ally
0 r otherwi se
i nteres ted in
the
outcome of the proceedi ng, or
any act ion
i nvo 1 ved the
rewi th.
Wi tness
my s i gnatu re and
seal:
s: ;J
CATHERINE S. BOYD
Notary Publ ic
My commission
February 28,
in and for
rgi n
The Commonweal th of Vi
ia
expires:
2006
-J
,....-- . ' ,......., """"
- - - - - - - - - - - - - - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-6
Filed 07/07/2004
Page 26 of 26
April 10 ,
2002
McLean , V A
Page 242
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
( 98 - 12
6C) (Me
row, S. J.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C) (Merow, S.
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) (Sypolt,
J.
Certified Copy
INDIANA MICHIGAN POWER COMPANY
( 98- 48 6C) (Hodge s , J.
SACRAMENTO MUNICIPAL UTILITY DISTRICT
(98-488C) (Yock, S.
SOUTHERN NUCLEAR OPERATING COMPANY,
et al.
(98-488C) (Yock, S.
COMMONWEALTH EDISON COMPANY
(98-621C) (Hewitt, J.
BOSTON EDISON COMPANY
(99-447C) (Allegra, J.
GPU NUCLEAR, INCORPORATED
Alderson Reporting Company, Inc. N, W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
IIII 14th Street ,