Free Motion for Leave to File - District Court of Federal Claims - federal

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

Case 1:98-cv-00126-JFM

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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

Document 833-6
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

Case 1:98-cv-00126-JFM

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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

, ,

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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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Page 11 of 23

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

Case 1:98-cv-00126-JFM

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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

Case 1:98-cv-00126-JFM

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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)

Case 1:98-cv-00126-JFM

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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

Case 1:98-cv-00126-JFM

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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

(301) 762-

8282 (202)

D. REPORTING COMPANY, INC.
861-

3410 (800)

292-

4789 (703)

288- 0026