Case 1:98-cv-00126-JFM
Document 833-6
Filed 06/28/2004
Page 1 of 23
EXHIBIT
..
Case 1:98-cv-00126-JFM Document 833-6 Filed 06/28/2004 Page 2 of 23
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY;
CONNECTICUT YANKEE ATOMIC POWER
COMPANY; MAINE YANKEE ATOMIC
POWER COMPANY;
: Case Nos. 98-126C,
: 98- 1S4C,
98-474C,
98- 483C, 98-484C,
FLORIDA POWER
98- 48SC, 98-486C,
98-488C, 98- 614C,
LIGHT COMPANY; NORTHERN STATES
POWER COMPANY; DUKE POWER , a
Di vision of DUKE ENERGY CORP.
98- 621C, 99-447C,
00-440C, 00- 69SC,
INDIANA MICHIGAN POWER COMPANY;
SACRAMENTO MUNICIPAL UTILITY
00- 703C, 01- 11SC,
01- 116C, 01- 249C
(Caption continued on the next
page)
Deposi tion of LAKE H. BARRETT
Washington, D.
C.
Monday, April 22 , 2002
9:31 a.
Job No. : 11792-4
Pages 1
through 272, Volume
Diane Gomez, RPR
Reported by:
D. REPORTING COMPANY, INC.
1100 Connecticut Avenue, NW . Suite 1150, Washington, D. C. 20036 . 202. 861.3410
Fax: 202. 861. 3425
. 800. 292. 4789 . Website: ladreporting. com . E-mail:
lisa~ladreporting. com
NATIONWIDE COURT REPORTERS AND VIDEOGRAPHERS
--------------Case 1:98-cv-00126-JFM Document 833-6 Filed 06/28/2004 Page 3 of 23
DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
DISTRICT; SOUTHERN NUCLEAR OPERATING COMPANY , et al.
COMMONWEALTH EDISON COMPANY;
BOSTON EDISON COMPANY; GPU
NUCLEAR , INCORPORATED; WISCONSIN
ELECTRIC POWER COMPANY; POWER
AUTHORITY OF THE STATE OF NEW
YORK; OMAHA PUBLIC POWER DISTRICT;:
NEBRASKA PUBLIC POWER DISTRICT;
and TENNESSEE VALLEY AUTHORITY
Plaintiffs
THE UNITED STATES,
Defendant
- - X
(301) 762-8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292-4789
(703) 288- 0026
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY , APRIL 22, 2002
LAKE H. BARRETT
having been duly sworn , testified as
follows:
EXAMINATION BY COUNSEL FOR PLAINTIFF
SACRAMENTO MUNICIPAL UTILITY DISTRICT
BY MR. CAYNE:
Good morning,
Good morning.
Mr. Barrett.
Have you been deposed before?
No.
First time?
Yes.
Has your counsel explained to you the
process?
Sort of.
I will ask you questions, you give me your
best answer.
If you don t understand my question,
please feel free to ask me to repeat the question or
clarify it.
Okay.
What is your current position , Mr. Barrett?
m the deputy director of the Office of
REPORTING COMPANY , INC.
861-
(301) 762-
8282 (202)
D.
3410 (800)
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
Ci vilian Radioactive Waste Management.
For how many years have you been employed
by the Department of Energy?
Since mid-
' 85 in
various different
positions.
And prior to 1985 what was your position?
I worked for the Nuclear Regulatory
Commission since the end of ' 74 in various positions.
Have you participated, Mr. Barrett, in the
preparation of the briefs filed in the various spent
nuclear fuel cases?
No.
Have you reviewed briefs filed by the
Department of Justice in this case prior to being
filed?
No.
Have you ever reviewed any briefs filed in
this case?
No.
By this case I' m
the United States.
right now referring to the
case of Sacramento Municipal Utility District versus
(301) 762-
8282 (202)
D.
REPORTING COMPANY , INC.
861-
3410 (800) 292-4789 (703)
288- 0026
--
Case 1:98-cv-00126-JFM
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H.
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DEPOSITION OF LAKE
BARRETT, VOLUME CONDUCTED ON MONDAY , APRIL 22, 2002
recall specific receipt
rates.
Were you attempting to accept more than a
single spent nuclear fuel assembly?
Yes.
Was it ever the intent of your office to be
able to accept a single spent fuel assembly by January
31st, 1998?
MR. CRAWFORD:
Obj ection , vague.
Obj ection
to the extent it might call for a legal conclusion.
From a systems perspective it was our
intention to build a system that would take more than
one fuel assembly.
Fro~ a systems perspective was it ever your
intention to build a system that would take only -- be
able to take only a single fuel assembly by January
31st, 1998?
That was never our intention, to do just
one fuel assembly.
Was it ever the intention of your office at
any time subsequent to the period in which you held
the posi tion was it director of
Di
vision director.
D.
(301) 762-8282 (202) 861-3410 (800)
REPORTING COMPANY, INC.
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY , APRIL 22 , 2002
Was it ever the position of your office
subsequent to that time that the goal would be to be
ln a position to accept a single spent fuel assembly
by January 31st, 1998?
MR. CRAWFORD:
Obj ection, vague.
Objection, foundation,
and objection to the extent it
calls for a legal conclusion.
It was never our plans to take one
assembly to my recollection.
fuel
Do you recall ever having any discussions
internally whether the acceptance of a single
fuel
assembly would satisfy the department' s obligations
under the contract, the standard contract?
I never recall any discussions from a
systems perspective about the
contract, so, no, I
systems
don t recall ever having a
discussion.
What do you mean from a
perspecti ve?
We were -- our job was to develop the
systems to recelve the material, and we never, to my
recollection, we never discussed about a system that
would receive one fuel
assembly.
Okay.
We always
(301) 762-
8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292- 4789
. (703) 288- 0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22 , 2002
That'
s probably about ri
ht.
And how did you come to the 3, 000 number?
MR. CRAWFORD:
Obj ection, foundation.
d have to go back and look at
which I have not
records,
done.
It is the evolution of the
design receipt rates for the first repository, second
reposi tory, the MRS in the
system.
My recollection is
the MRS was to receive 3 000 tons a year circa that
time prior to the amendments act, which was ln excess
of the generation rate of around 2 000.
That was important, wasn t it, that it be
in excess of the generation rate?
MR. CRAWFORD:
Obj ection, vague.
Yes, in my opinion it was
Well, important?
significant that you design a system to remove the
backlog of materials that were accumulating under the
intent of the act.
And why was that significant in your view?
Because the concept of a Nuclear Waste
Policy Act was to -- for the federal government to take the materials from the high-level waste and spent
fuel sites into federal
custody.
(301) 762-8282 (202)
D. REPORTING COMPANY , INC.
861-
3410 (800) 292-4789 (703)
288-0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22 , 2002
And based on that concept it was
significant or material that you be able to design a system to remove the backlog of materials that were
accumula ting,
correct?
Wi thin a reasonable -- wi thin a reasonable
sense, correct.
What do you mean by within a reasonable
sense?
Well, you can -- there is no automatic
number that you would
calculate.
The higher the
numbers, the more the complexity of the
system, the
more the system costs.
So there was a balance, and we
did studies that I recall in a general sense as to what would be the appropriate receipt rates for
planning designing purposes.
The goal was to make the take rate high
enough so that you could eliminate the backlog wi thin
a reasonable amount of time without making the rate so high that the complexities would send the cost through
the ceiling, correct?
MR. CRAWFORD:
Obj ection, vague.
Obj ection, foundation.
D. REPORTING COMPANY, INC.
(301) 762-8282 (202) 861-3410 (800) 292-4789 (703)
288- 0026
, ,
Case 1:98-cv-00126-JFM
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY , APRIL 22, 2002
In a general
sense.
Again, what do you mean when you say in a
general sense?
We did not -- you all get into the
contract.
We did not consider the contract issues at
that time, so we were balancing the size of the
system, the uncertainties of an MRS would or wouldn
be approved, the repositories, where they might
how many we would
be,
have.
So it was a complicated
balancing of many interests, and so to -- it would be
inappropriate to say that we had a numerical number to
move the backlog or anything like that because I don
recall anything like
that.
backlog,
You didn t have a numerical number to move
the backlog but you had a goal to move the
correct?
wi thin a reasonable -MR. CRAWFORD:
Obj ection, vague.
Wi thin a reasonable
sense, yes.
In a
general sense I mean.
And in establishing these goals you were
considering the requirements, of course, of the
(301) 762-8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800) 292-4789 (703)
288- 0026
Case 1:98-cv-00126-JFM
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Filed 06/28/2004
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY , APRIL 22 , 2002
55 .
Nuclear Waste Policy Act of
MR. CRAWFORD:
1982, correct?
Obj ection,
foundation.
We knew that the general policy laid out in
the act for the federal, you know , intention to
dispose of the nation
s waste and spent fuel.
And you understood the policy behind the
act would call for the elimination of the backlog of
spent nuclear fuel wi thin
a reasonable amount of
time,
correct?
MR. CRAWFORD:
Obj ection.
Foundation.
Reduction as opposed to
elimination.
long as they operate, you don t eliminate
it.
reduction ,
yes.
And just explain what you meant by as long
as they operate you don t eliminate it?
Well , when -- when reactors operate, there
is always g~ing to be some inventory of spent fuel
there.
We were working to minimize the backlog and
reduce the backlog that was at the
sites.
So in order to be able to minimi ze the
backlog, the acceptance rate would have to be at some
level higher than the rate at which spent nuclear fuel
(301) 762-8282 (202)
L. A. D. REPORTING COMPANY ,
861-
3410 (800) 292-4789 (703)
INC.
288-0026
Case 1:98-cv-00126-JFM
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY , APRIL 22, 2002
was being produced, correct?
MR. CRAWFORD:
Obj ection to the form.
Obj ection, vague.
Our intention was to design a system that
would reduce the backlog to a reasonable
sense.
And in order for that to happen , as a
matter of mathematics or simple equation, the
acceptance rate would have to be something in excess
of the rate at which new spent nuclear fuel was being
created, correct?
MR. CRAWFORD:
Objection to the extent it
mischaracterizes his prior
In a general
testimony.
sense, yes.
And in 1986 you believed that the 3, 000
take rate that you were targeting at that point would
accomplish the goals you have been alluding
to,
correct?
MR. CRAWFORD:
Obj ection.
I 1
And the goal
m referr~ng to is the
reduction of the built up
MR. CRAWFORD:
backlog.
Obj ection to the
foundation.
Objection to the extent it mischaracterizes his prior
(301) 762-8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
-=--,
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
testimony.
Yes.
Can you describe for me how the department
actually arrived at the 3, 000 number?
I don t --
MR. CRAWFORD:
Objection ,
foundation.
I don t recall how it was
done.
Do you recall the general lssues that were
considered?
No more than what I' ve just said to you
before.
Well , would you please state for me your
understanding of the issues that were considered in
establishing the 3, 000 rate.
The 3, 000
number was there prior to my -My understanding of my
didn
t do the 3, 000 number.
predecessor
s was that 3 000 -MR. CRAWFORD:
m going to obj ect to the
extent the question calls for
MR. CAYNE:
speculation.
going to obj ect
Again
, I' m
counsel'
s continuing the interruption of the
witness.
Please continue.
(301) 762-8282 (202)
D. REPORTING COMPANY , INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
000 that existed was chosen in consideration with
the production rate, you know , the cost and the
transportation and the other issues So based on your prior
involved.
testimony,
Mr. Barrett, the 3, 000
rate would be consistent with
your understanding of the intent of the act to reduce over a reasonable period of time the backlog of spent
nuclear fuel throughout the nation , correct?
MR. CRAWFORD:
Obj ection , speculation.
Objection ,
foundation.
Yes.
MR. CRAWFORD:
MR. CAYNE:
Can we take a break
here.
Certainly.
(There lS a recess from the record.
Mr. Barrett, how long did you hold the
director position that you discussed?
The division director?
Yes.
I don t recall.
Somewhere -- when I first
came to the department, so that would have been ' 85,
spring of ' 85 think. I don
(301) 762-
until I was assigned to be QA d~rector
t know, a couple of
years.
288-0026
8282 (202)
D. REPORTING COMPANY , INC.
861-
3410 (800) 292-4789 (703)
,"""="",,,
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
Until January of '
take?
93.
And in January 1993 what position did you
Admiral Watkins made me acting director of
RW.
And RW stands
for?
Offices of Civilian Radioactive Waste
Management.
And what were your duties in that position?
MR. CRAWFORD:
Obj ection, vague.
Obj ection, lack of
foundation.
The duties of the director of the Office of
Radioacti ve Waste
Management.
You ran the program at that point, correct?
That'
s correct.
And have you basically held that position
ei ther as
acting director, director, or deputy
director through today?
MR. CRAWFORD:
Obj ection, vague.
I was either the
I was never the director.
acting director or the deputy
director. director,
288- 0026
And today you are the deputy
(301) 762-
8282 (202)
861- 3410
(800) 292-4789 (703)
MPANY, INC.
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
correct?
Correct.
..J
When you took the position as acting
director, was the development of an MRS still under
consideration?
Yes.
And how did you envision or how did you
plan for the MRS to operate at that point in time?
believe it was you said December ' 93?
January.
Excuse me.
January
' 93.
MR. CRAWFORD:
Obj ection, lack of
foundation.
The plans then were to pursue a volunteer
MRS site and to have the volunteer present their
proposal for site and congressional
approval.
Did you envision the MRS as a stand- alone
facili ty at that time,
not operating in conjunction
with a repository to be built?
MR. CRAWFORD:
Obj ection, foundation.
My understanding was it was still an
integrated facility with a
repository. The only
288- 0026
(301) 762-8282 (202) 861-3410 (800) 292-4789 (703)
D. REPORTING COMPANY, INC.
.....
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22 , 2002
116
Tha t
was an obj ecti ve,
okay, to recel
was te in 1998 and along with the acceptance schedule
it'
s -- in accordance wi th the acceptance schedule
provided in the standard
the goal.
contract, okay.
So that was
And you
re comfortable wi th
Obj ection.
that goal?
MR. CRAWFORD:
It wasn t mine.
It wasn t my goal.
But you understand that was a goal of the
program?
Yeah.
In 1985, correct?
That'
II"""""
s correct.
And what acceptance schedule did the
standard disposal contract provide for?
MR. CRAWFORD:
Obj ection,
Obj ecti0D to the extent it calls for
foundation. speculation.
I think the contract references other
documents that references things, and I don
specifically know.
So is it your testimony that it provided
~or a schedule but you don t sitting here today know
D. REPORTING COMPANY , INC.
(301) 762-
8282 (202) 861-3410 (800) 292-4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
117
what that schedule is?
MR. CRAWFORD:
Obj ection.
Argumentati ve.
The receipt rate of January -- excuse me,
the receipt date of January 31, 1998, clearly was
always a goal.
Okay.
Regarding the acceptance rate
of so many tons year
one, year two,
year three,
okay,
you know, that has changed over time. My focus has always been to create a si ting process that got us a si te to allow us to have the -- a reasonable receipt rate going toward the steady state 3, 000 tons per
year, and that' s
engineer ,
where my focus has always been, not
on contract details.
Okay.
I am not a
lawyer,
m an
okay, so I have not gone into the contract
in any great detail at
all.
contract,
Okay, now regarding your question here
about the acceptance schedule in the
actually I don t recall seeing a metric ton per year
in the contract.
Let me step back a
second, Mr. Barrett.
You just referred to a reasonable receipt rate going
toward the steady state 3
000 tons per year.
Right.
(301) 762-
8282 (202)
L. A. D. REPORTING COMPANY ,
861-
3410 (800) 292-4789 (703)
INC.
288-0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
118
That' That'
s where my focus has always been.
Do you recall that testimony?
s what I just said I think.
Does that continue to be your focus to this
very day, sir?
Yes.
And
does that continue to be the focus of
Obj ection to the form.
Obj ection , vague.
the Department of Energy s spent nuclear fuel program?
MR. CRAWFORD:
Obj ection to the
foundation.
We are still trying to perform under the
Nuclear Waste Policy Act to receive the waste into the
federal system as soon as we can under the constraints
of the law.
organization
So, yes, that remains my goal and the
s goal.
Again, just so the record is clear , your
goal and the organization s goal is to achieve a
reasonable receipt rate going towards the steady state
of 3, 000 tons per year, correct?
MR. CRAWFORD:
Obj ection
to the extent it
mischaracterizes prior
testimony.
Obj ection,
foundation.
(301) 762-
Obj ection, vague.
N""""~~',"
D.
8282 (202)
REPORTING COMPANY, INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
119
That has been our goal to do
that.
today,
And it continues to be your goal
correct?
Correct.
And it was your goal in
1985, correct?
Correct.
And it was the goal of the department in
1982 when the standard contracts were signed, correct?
MR. CRAWFORD:
Obj ection, vague.
Obj ection to the
Obj ection , calls for speculation.
extent it mischaracterizes his prior
I wasn
testimony.
t there in ' 82
so I don t know about
82, but in ' 85
and today it has always been our
intent to try to do what we can from a technical point
of view to recel ve
the materials at a reasonable
rate.
And the reasonable rate is the rate that
would ramp up -- is a rate that would ramp up towards
3, 000 MTUs per year, correct?
MR. CRAWFORD:
Obj ection, vague.
And
foundation.
I believe your counsel cut you
was your answer, sir?
off.
What
(301) 762-
8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT, VOLUME 1 CONDUCTED ON MONDAY, APRIL 22, 2002
120
That has been our
intent.
three, page
Let'
back
to paragraph
seven.
You
Was
goal.
being referred to January 31st, 1998, contractual something more, wasn
MR. CRAWFORD:
commi tment and a statutory command?
Obj ection,
argurnentati ve.
Obj ection, best evidence.
Objection to the extent it
calls for a legal conclusion.
As an engineer, okay, and as a program
administrator, okay,
and dependent on what the
contract said or what courts said, we were always
trying to achieve that
goal.
And why did you establish that goal for
yourself?
Because --
And your department?
It was set in the law, okay, that our goal
was to try to create a facility and to create a system
that would meet that goal of January
start to receive
31st, 1998, to
fuel.
And it has always been an
important obj ecti ve and goal.
To start to receive fuel on January
31st,
288- 0026
(301) 762-8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800) 292-4789 (703)
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DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
121
1998, at a ramp- up level that would -- in a reasonable
amount of time and at a 3, 000 per year MTU acceptance
ra te,
correct?
MR. CRAWFORD:
Obj ection to the form.
Obj ection to the mischaracterization of prior
testimony.
Obj ection to the extent it assumes facts
not in evidence.
It was a systems goal to receive the
material at a reasonable rate, okay, of which the
000, ramp up to 3
000 tons was a reasonable rate.
It was never a -- ln my opinion it was never a legal
requirement to do 3, 000
That'
tons per
year.
You base the goal on the statute, correct?
s what you ve testified to, correct?
Yes.
Back to paragraph three -Excuse me.
Let me go back to
that.
When
you say the statute does not say 3, 000,
a judgment part.
1998, is in the
okay, that was
It is the receipt in January 31,
The rate to my knowledge is
statute. not in the statute.
So why did you set the 3, 000 MTU goal?
(301) 762-
8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800) 292-4789 (703)
288- 0026
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DEPOSITION OF LAKE H. BARRETT , VOLUME CONDUCTED ON MONDAY, APRIL 22 , 2002
122
That was a -MR. CRAWFORD:
Obj ection to the fact that
that question assumes facts not in
evidence.
That was in our judgment a reasonable
steady state rate to move up to under the
rate,
circumstances we were in. Paragraph three.
understand your testimony.
m not certain
m still unclear what
you re referring to with respect to the acceptance
schedule.
You see that language, acceptance schedule
in paragraph three?
You asked me to interpret this paragraph
three which I never
wrote.
s asking you whether you
MR. CRAWFORD:
see that.
Do I see it?
I see that
line.
And what do you understand that to be
referring to?
What acceptance schedule did the
standard disposal contract provide
MR. CRAWFORD:
for?
Obj ection to the foundation
of the question and obj ection, best evidence.
I don t know because I do not recall an
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