Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-14
Filed 07/07/2004
Page 1 of 25
May 23 2002
Washington, D.
Page 245
Thank you.
(Whereupon, at
4: 25 p. m., the deposition
adjourned.
Signature of the Witness
of
SUBSCRIBED AND SWORN to before me this
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(21 7'
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NOTARY PUBIl
My Commission expires:
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1111
14th Street
~W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Alderson Reporting Company, Inc.
//~
';)..
Case 1:98-cv-00126-JFM
Filed 07/07/2004 OF: EF--. ATA SHEET FOR THE TRANSCR
Document 840-14
Page 2 of 25
Notice Date: May 28 , 2002 Case Name: Yankee Atomic VS. United Case Number: 98- 126C- 987 4C
Dep. Date: May 23
States
Deponent:
Ref. No. :
Place: Washington DC
4269Line
Now Reads
2002 Alan Brownstein (continued)
CORRECTIONS:
Page
Should Read
Reasons Therefore
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- - - - - - - - - - - - - - - - - - Case 1:98-cv-00126-JFM
Alan Brownstein
Washington, D.
).
Document 840-14
Filed 07/07/2004
Page 3 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.
C~RTjFIED
Plaintiffs,
THE UNITED STATES,
COil
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- 8oo-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-14
Washington, D.
Filed 07/07/2004
Page 4 of 25
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
Well, you
m not a lawyer.
re not a lawyer.
But at this
time you were working on the program and you were
working on these matters.
their jobs.
I don
And sometimes nonlawyers
have understandings of legal things that relate to
Maybe you did and maybe you didn' t, but
that that
I t know
I s responsive to my question.
At this time did you have an understanding of the
legal significance of an approved DCS?
MR . CRAWFORD :
Objection 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 Browns tein, 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 840-14
Washington , D.
Filed 07/07/2004
Page 5 of 25
June 14
2002
Page 424
DCSs?
MR . CRAWFORD :
Same objection.
THE WITNESS:
BY MR. STOUCK
Not that I
recall.
you have
And subsequent to
that, in ' 95,
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
Yes.
Was
first
deposition?
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:
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 840-14
Washington , D.
Filed 07/07/2004
Page 6 of 25
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 I S been a long deposition, I just did
not recall that.
questions over.
I m not trying to ask you the same
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 I 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 I'
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
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-14
Washington , D.
Filed 07/07/2004
Page 7 of 25
June 14, 2002
Page 426
THE WITNESS:
Okay.
Well, that I s fine.
Is
think somewhere in that draft there was, you know,
some views expressed about what the government
Department of Justice I 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 :
Objection 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 DCSSi is that right?
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
Washington, D.
Document 840-14
Filed 07/07/2004
Page 8 of 25
June 14 ,
2002
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 DeS submittal and
approval process.
Okay.
Now, that' s a question that -- you know,
the words are different.
But it I 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 DeS 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. 1111 14th Street, N. W. Suite 400 1- 8oo- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Alan Brownstein
Document 840-14
Washington , D.
Filed 07/07/2004
Page 9 of 25
June 14 ,
2002
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?
Tha t'
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
wi th the utili ties 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, I'
m just asking if he knows if any of
them were ever amended.
MR . CRAWFORD :
Then maybe my obj ection
is
more appropriately objection, vague.
THE WITNESS:
Yeah, I believe there were
It would be hard for me to
Bu t
some
tell
some
modifications made. you wha they were. modifications made.
BY MR. STOUCK
I remember there were
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 840-14
Washington, D.
Filed 07/07/2004
Page 10 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 subject to what I just told
THE WITNESS:
MR . CRAWFORD :
you.
Thank you.
'll reserve any further
questioning of the wi tnes~
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.
(Wher~upon,
m., the takin~ of
the
instant deposition
ceased.
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
of
tJ;wJ;
day
CI
17e
, 2
o.ft!.
NOTARY PUBLIC
My Commission expires:
~jf/ob
Alderson Reporting Company, Inc. 1111 14th Street, N.'X"",~uite 400 1- 800-FOR- DEPO Washington, DC 20005
)..
Case 1:98-cv-00126-JFM
ER~
fA SHEET FOR THE TRANSCRIF
Document 840-14
Filed 07/07/2004
JF:
Page 11 of 25
Notice Date: June 17 , 2002 Case Name: Yankee Atomic VS. United Case Number: 98- 126C- 987 4C Dep. Date: June 14 , 2002 Deponent: Alan Brownstein Washington DC 4269-45 Ref. No.
States
Place:
CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
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Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 12 of 25
EXHIBIT
"'"
, ~
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. ,.
, ~
Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 13 of 25
) i~ ~1i~ ~ J't " ~t .I.f " l'f./ ,- "W' b~j
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206
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X
YANKEE ATOMIC ELECTRIC
COMPANY,
Plaintiff,
Case No. 98-126C
Senior Judge
Merow
THE UNITED STATES,
Defendant.
- X
Washington, D. C.
Thursday, April 22, 1999
Continued deposi tion 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
1350 I Street, N.
Spriggs & Hollingsworth,
Washington, D.
, at 2:10 p. m., Thursday, April
22, 1999, and the proceedings being taken down by
Stenotype by JAN A. WILLIAMS, RPR , and
transcribed under her direction.
2 3
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 840-14
Filed 07/07/2004
Page 14 of 25
244
aware that the utility industry did not support priority for shutdown reactors. In fact, their
stated consensus position was that priority should not be afforded to shutdown reactors.
So it was not intended that the delivery commitment schedule process be a gotcha
process?
A static process.
Right,
five and now
that, gee,
you only requested
even though we can accommodate 20, you ve wanted all along to do 20, we' re not going
to let you because you only asked for
was not the intention?
That
five, that
intention to
S correct do that.
it was not our
And we might have covered
yesterday, but let
this me just make sure it' s
clear
that the delivery commitment schedule was intended to indicate how much spent fuel the
utility wanted to deliver up to the limit of their allocation?
In part, because recall that the discharge date of the fuel earned you a slot in the acceptance priority ranking, but the fuel you could actually deliver did not have to be the
ALDERSON REPORTING COMPANY , INC.
1111 14th ST., N. W., 4th FLOOR
(202)289. 2260
(800) FOR DEPO
WASHINGTON ,
D.
C., 20005
""'\
Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 15 of 25
273
out its
scope.
I don t precisely recall which
section in the contract discusses the annual
capac i ty
report.
If you want to turn to page
10
the
paragraph above Article
Is that what you were
referring to?
Yes, because it establishes it as a
document for planning purposes only because
is a recognition that system capacity could
there
change up or down.
So the annual capacity report was not
intended to be binding on the parties?
It was not intended to be absolute in
the sense that again it'
And DOE,
s a planning
document.
and I distinctly remember saying
this
and I distinctly remember it being said to me
when I was on the utility
side,
DOE had always
stated that, if we were able to improve the system capacity, then the ACR would reflect those improvements in system capacity. And the APR would be used to readj ust
which utilities, when
and how much
fuel.
So,
a planning document, planning documents are
subj ect to change.
And the ACR as I understood it was to
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 840-14 Filed 07/07/2004 Page 16 of 25
274
communicate to the utilities what DOE believed
was the likely receipt rate at a repository,
likely acceptance
the
rate,
and to accept who was
likely to deliver during the first ten years of
system operation based on the APR.
What was the first ACR that you were
involved in?
Let'
1 0
s see.
I joined DOE in August of
, 91, and I don' t recall which ACR that was.
But
I would probably have been involved in the ACR
starting on the ACR that was issued in ' 92,
What would your role have been in
determining that amount that DOE was going
tell utilities DOE was expecting to -- what they expected the annual receiving rate for the
facilities to
17
be, what would your
role have been
in that?
None,
nothing.
the those receipt
Who would have made that determination?
2 0
I don' t recall who precisely made
determination because I believe
rates were established in ACR' s prior to my
23
advent with the
program.
And there were no
changes in those receipt rates for this document
25
that I' m aware of,
1111 14th ST., N.
So the document
the
ALDERSON REPORTING COMPANY , INC.
(202)289. 2260 (800) FOR DEPO , 4th FLOOR / WASHINGTON ,
D.
C., 20005
"""'. ...-...
~~
Case 1:98-cv-00126-JFM Document 840-14 Filed 07/07/2004
---
Page 17 of 25
2 05
MR. SHAPIRO:
Why don' t we stop for the
day here and discuss where to go
( Wh ere
up0
n ,
at
4: SO
next. p. m., the
depos i t ion adj ourned, to
be resumed on Thursday,
April 22,
1999, at 2: 00 p.
Signature of the Witness
SUBSCRIBED AND SWORN to before me
day 0
f ~~~~----------------
this -
~~:t~
My Commission
17
'1-
NOTARY PUBLIC
expires: ~~fl~i1QB__-
2 0
2 3
2 5
ALDERSON REPORTL\"G CO~"IPAXY , INC.
1111 14th ST. , N. W.,
12021289- 2260 /8001 FOR DEPO 4th FLOOR WASHINGTON ,
D.
C., 20005
Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 18 of 25
Page
ERRATA SHEET FOR THE TRANSCRI PT OF:
Notice Date: 04/29/99 Case Name: Yankee Atomic Electric Company v. The United States Case Number: 98-126C
Dep. Date: Deponent: Place:
TS#:
04/21/99 /
Nancy H. Slater
WashJ.ngton, DC
78077
CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
tZtr77vmf
----Case 1:98-cv-00126-JFM
Nancy Slater Thompson
-- -
---Filed 07/07/2004 Page 19 of 25
June 13
Document 840-14
2002
Washington , D.
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- X
YANKEE ATOMIC ELECTRIC
COMPANY , MAINE YANKEE ATOMIC
yertffied COpy
: Case No. 98- 126C
POWER CO. , and CONNECT I CUT
YANKEE ATOMIC POWER CO.
Plaintiffs
: 98-474C, 98-154C
(Senior Judge
Merrow)
UNITED STATES OF AMERICA
Defendant
- X
Washington ,
D.
Thursday, June 13 , 2002
Deposi tion of NANCY SLATER THOMPSON , a
witness herein , called for examination by counsel
for the Plaintiff in the above- entitled matter
pursuant to notice , the witness being duly sworn
taken at the offices of Spriggs &
1350 I Street , N.
Hollingsworth,
, at 9:40
, Washington , D.
a. m. , Thursday, June 13 , 2002 , and the proceedings
being taken down in Stenotype by DEBORAH
WILKINS , 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
Nancy Slater Thompson
Document 840-14
Filed 07/07/2004
Page 20 of 25
June 13 ,
2002
Washington , D. C.
Page 94
it calls for a legal conclusion.
Obj ect ion
foundation.
I do not recall.
Isn'
t such a limitation inconsistent
with the language that we just focused on , all
spent fuel or all SNF and/or HLW the purchaser
wishes to deliver?
MS. SULLIVAN:
Obj ection
argumentative.
Obj ection to the extent it calls
for a legal conclusion.
You may answer.
, I don' t believe it is
inconsistent.
to deliver.
16
It'
s all fuel that you wish to
deliver within the bounds of what you are entitled
17 ACR as a planning document. What did you mean by
tha t ?
MS. SULL IVAN :
Q.
A little while ago you referred to the
Obj ection.
The
documents speak for
themselves.
You may answer.
As we have discussed in my prlor
deposition and previously in this deposition , the
ACR represents a planning
basis. The acceptance
rates are subj ect to influences by future budget
Alderson Reporting Company, Inc.
1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Nancy Slater Thompson
Document 840-14
Filed 07/07/2004
Page 21 of 25
June 13
2002
Washington , D.
Page 95
constraints, lack of a facility, unavailability of
transportation casks.
For example, no one would have
contemplated at the time that I did these that we
would have an RSA , Regional Services Agreement,
that would in fact contract out with someone else
to provide the transportation which would have
financial effects and could have scheduling and
capaci ty
effects. It'
s a planning document.
And
in fact when I sat on the utilities side of the
table the industry recognized that not only was
the ACR for planning purposes
only, but that in
fact their DCSs were for planning purposes , and
they filled DCSs out consistent with that planning
presumption because providing a range of discharge
dates which might be over a 10- year period
certainly doesn
I t permit
a system to do more than
plan.
A couple sentences before the end of
your answer , you said it was understood by the
industry that both the ACRs and the delivery
commi tment schedules were for planning purposes
By using the word " only, " did you exclude - - what did you mean to exclude?
only.
mean to
That we viewed the DCSs as
fungible,
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Nancy Slater Thompson
Document 840-14
Filed 07/07/2004
Page 22 of 25
June 13 ,
2002
Washington , D. C.
Page 96
~nd we
have been through that in prlor deposition
as well; that the industry recognized that in fact
they wouldn
I t be
providing us with specifics about
what they wanted us to accept until they submitted
a final delivery schedule; and the final delivery
schedule actually does represent the commitment on
their part to this reactor , this time, this amount
of fuel, this age fuel, so greater specificity
wi th the FDS , ball park with the DCS.
It was important for the utilities to
glve us DCSs because of their very
fungibility.
I t exchange
I f you didn' t
submi t a DCS, you couldn
your slot in the cue, and given that those
exchanges were possible, I don
15 would perceive a DCS as anything other than for 16 planning purposes.
Let I S go back
purposes only.
When you say that ACRs were for
planning purposes only, does that mean that the
first just to the ACRs
I t know how one
and the statement that they are for planning
ACRs were not meant to be binding on the
Department of Energy?
MS. SULLIVAN:
Obj ection, vague.
Objection to the extent it calls for a legal
Alderson Reporting Company, Inc. I I I I 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 23 of 25
June 13 ,
Nancy Slater Thompson
Washington , D. C.
2002
Page 97
conclusion.
I can 't speak to that legal lssue or
speak for a contracting
officer.
In my
estimation, that I s a ask someone else.
question you would have to
When you published the 1995 ACR , did
you understand that you were committing the Department of Energy to accept the amount of spent
fuel noted in the waste acceptance proj
ections in
that document?
MS. SULLIVAN:
Obj ection to the extent
it calls for a legal
document speaks for
conclusion. Objection , the itself. Objection , vague.
My understanding is entirely
consistent with the sentence at the bottom of page
1 in the
I guess this would be Exhibit 3, which
is the 1995 ACR.
As specified in the Standard
Contract, the ACR is for planning purposes
only,
and this is not contractually binding on either
DOE or the purchasers.
And so were I to reason
this out
have
and not make
say as
legal decislon,
engineer my clear
would
simple
reading
that language
would say if
it'
in the
25
contract, everyone, including be well aware of that.
the utility, would
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
"'"
Case 1:98-cv-00126-JFM
Document 840-14
Filed 07/07/2004
Page 24 of 25
June 13 ,
Nancy Slater Thompson
Washington , D.
2002
Page 98
What about the delivery commitment
schedules?
Was it your understanding that those
similarly were for planning purposes only and not
contractually binding on either the utilities or
the department?
MS. SULLIVAN:
Obj ection to the extent
Obj ection,
it calls for a legal
conclusion.
vague.
In my personal opinion , they were for
planning purposes only and in fact were completed
in such a way that not much but planning could be
done based on the information contained in
them.
In addition, given the fungibility of the DCSs,
that'
s why there is a final delivery schedule
which is somewhat more than a planning
document.
And I do recall siting across the table from
numerous utility representatives, clearly
recognizing that the DCSs were planning purposes
and they in fact did not view themselves as
binding themselves to deliver specifically what
was described on the DCS.
During the time that you worked in the
waste acceptance division at the Department of
Energy, do you recall anyone either within DOE or
ln industry who thought that the delivery
Alderson Reporting Company, Inc. , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005 1111 14th Street
./I
Case 1:98-cv-00126-JFM
Nancy Slater Thompson
Document 840-14
Filed 07/07/2004
Page 25 of 25
June 13
2002
Washington , D.
Page 99
commi tment schedules were binding on either
industry or the department?
MS. SULLIVAN
Obj ection, vague.
Obj ection to the extent it calls for a legal
conclusion.
No, I don't.
You said something a minute ago that I
guess has me a little
confused.
You said that the
delivery commitment schedules are definitely for
planning purposes but they provided relatively little information so you couldn 't do much
planning with them.
I may be getting your
language a little wrong, but what did you mean by
tha t ?
The DCSs - - and
you need to put this
the DCSs,
in the context of their fungibility
were they to remaln as is, would provide you with
the location of the reactor to which you would
arri ve to pick fuel up,
cask to
so you know the type of
fuel, you can plan appropriately for the type of
send.
Given that they have submitted one
s assume
DCS for,
casks to
let'
10 MTU, you know how many
send.
The date on which you would show
up and schedule a pickup was not resolved until
the FDS because that was actually done ln
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