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

Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 1 of 23

Susan Klein (vol
Page 448
don I t know.

BY MR. MACDONALD:

Do you know if DOE is considering a proposal
to the NRC to dispose of GTCC somewhere other than
Yucca Mountain?

6 \.

Not at this

time.
you.
That I s the draft

If you take a look at Klein Exhibit 40, which

you may still have before

letter, the draft position from

JAI.

Yes.
I would direct your attention to the second

bullet point, which states

that:

The regulations of

the Nuclear Regulatory Commission issued subsequent to
the Standard Contract, require that low- level

radioactive wastes that contain concentrations of

radionuclides that exceed the limits for Class C waste

as defined in 10 CFR 61. 55 must be disposed of in a
reposi tory.

Do you see that?

I see that sentence, yes.

And you I d agree with that statement, correct?
No, I would not agree with that

statement.

What aspect of that statement would you
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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 2 of 23

Susan Klein (vol
Page 492

That I S true.

They also haven

t proposed to

put it in a repository either, yes.
But you

I re aware

of studies suggesting -- DOE

studies suggesting that the most economical place to
put commercial GTCC is in the repository?
I can

I t cite

you to any

studies, but that I s an

understanding I have from conversations with people

that it could be economical to put it in the repository

when we are authorized to do

that.

And it would be difficult to get -- to site

another repository for disposal of GTCC, correct?
Yes, that is correct.
(Discussion off the record.
MR. MACDONALD:

46.

(Thereupon, the reporter marked for
identification Deposition Exhibit No. 4 6. )
BY MR. MACDONALD:

Ms. Klein ,
document entitled

I I ve had

marked as Exhibit 46 a

Teleconference Call Summary.

is Bates page SNL- 00I- 0227 and it refers to a

teleconference call held on June 22, 1999.

Do you

22 ~ave that

before you?

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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 3 of 23

Susan Klein (vol
Page 493
Yes, I

do.
I ve had a chance to review

Please take a minute to review that document
and let me know when you

it.

I I ve read

it.

CouLd you identify -- well, first, the
document lists several people participating in the

telephone conference call,

including Mary Jane

Wisenbaker, Rob Campbell , Joe Coleman, Larry Ball, Mark
Frei, F-r-e- i, Greg Duggan, Sandy Birk and Bob
Do you know -- we

Hanson.

I ve already spoken about Mr. Campbell.

Do you know the other people listed as being on this
conference call?

I know Joe Coleman and I know Mark Frei and I
believe I have spoken to Mary Jane Wisenbaker.

Could you tell me who first
I believe she works for EM.

Ms. Wisenbaker is?
I think most of

these people work for the Environmental Management
group in DOE.
But I can

t remember.

I have spoken

to Mary Jane, but I can t remember. Rob Campbell

I told you who

is.
re referring
to?

When you say EM, you I

It I s within -Esquire Deposition Services

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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 4 of 23

Susan Klein (vol 2) .
Page 494

Environmental -It I s wi thin the Department of Energy and it I
called Environmental Management.
Environmental Management.

We call it

I think

it. s a

longer name.

It. s

in charge of the cleanup of DOE facilities, and

they also have historically been in charge of the

low- level waste programs.
And Mark Frei you
Mark Frei.

said?

You said is who?

He I S in the Environmental Management
Have you spoken with him before?

group.

Yes.
On what issues have you spoken with

Mr. Frei

about?
I don

t know if I I ve actually spoken to him
Mostly I have seen him in the hall

about this

issue.

and said hello and talked to him about his transfer and

where he -- I mean, I don t remember discussing

anything substantive with him in years.
Management.
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He used to be

in my Office of Civilian Office Radioactive Waste

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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 5 of 23

Susan Klein (vol
Page 495
Mr. Frei used to work in OCRWM?

Yes.

Do you know when he trans ferred to DOE'
Environmental Management?

No, I don' t know.

You'

ve identified Ms.
Mr. Frei.

Wisenbaker,

Mr. Campbell,

Is there anyone else on that

list?
I know Joe Coleman.

He used to be head of

the low- level waste program when I was their
I don' t know whether he still works for DOE.

lawyer.
He could

be a contractor now.
to him in years.

I don t know.

I haven' t talked

Any

the other people?
know the

don'

And we were

other names, no. just talking about the difficulty

in siting another repository for disposal of GTCC

waste.

Do you remember our discussion just a few

minutes ago?
Yes,

do.

you look down at the bullets, the fourth
bullet on Exhibit
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46 states that:

Options other than

800- 441- 3376

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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 6 of 23

Susan Klein (vol
Page 496

~:he repository

are considered politically undes irable ~

in light of overall DOE waste management objectives.
Do you see that?

I do see that,

yes.
about?

Is that consistent with your view in your

prior testimony that we just talked

Well, I would say this is EM'
understand EM' s view to

s view as I

be.

It has at times been RW' s

view.

I don' t know that it' s RW' s view right now,

but...
Do you have any reason to disagree with this

statement?
Well, as you stated, it would be difficult to

site another disposal facility for greater than Class So, politically undesirable. Those aren' words that like to use. But it would difficult. think that. s fair to say. It would be di f f icul t to -Site a greater

than.

-- site a greater than Class C repository?

Uh- huh.

It would be difficult.

The bullet point just above the one we'
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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 7 of 23

Susan Klein (vol
Page 497

talking about states:

Mark Frei indicated that there

is an understanding between GCRW and EM that GTCC waste
will go to the repository.

Do you see where

I' m

reading?
I do.

RW obviously refers to the Office of
Civilian -- OCRWM?

Yes.
The Office of Civilian Radioactive Waste

Management?
Tha ti

s correct.

EM is DOE' s Environmental Management?

That I S correct.
And GC.

Do you know what that refers to?

General Counsel.

Do you know whether there is an understanding
between the General Counsell s Office, RW and EM that
GTCC waste will go to the repository?
Is that your

understanding?
I think there

I s an understanding

that if we

were required to do so, authorized to do so and there

22 ~was

a method to pay for it, we would do

that, but

Esquire Deposition Services 1-800-441-3376

...-Case 1:98-cv-00126-JFM Document 833-5 Filed 06/28/2004 Page 8 of 23

Susan Klein (vol
Page 498

there I S no written
wha t do you mean?

understanding that I I m

aware of.
so,

When you say that " we were required to do

If Congress passed a law and said take GTCC in
the repository, we wouldn

t necessarily object to that

leg is lation,

for example.

We would not object to that

legislation as long as there was a way for generators

to pay for

it.
t require a Congressional statute to

It wouldn

have GTCC go to the repos

i tory, would

it?

Either that or NRC by rule under those

particular terms.

I think

it. s either

a NRC rule or a

statute, and I personally think it will eventually be a

statute, but I think it will be

legislation.

And do you know if RW , EM and the General
Counsell s Office all have an understanding that there

will either be a statute or a NRC rule that GTCC will
go to the repository?

Well, I think at the levels and the people

that I spoke to, yes.
somebody in the

don I
don I

know if you asked
know how educated

staff.

they

22 are to the issue.
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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 9 of 23

Susan Klein (vol
Page 499

At the high- level
Yes, I think.

--

-- policy level , all three branches, General

Counsel, OCRWM and EM have an understanding that GTCC
waste will ultimately go to the repository?

If it' s authorized.
must be authorized.
be authorized?

If, but that it first

And do all three branches believe that it will

Well, I don' t know whether each individual

believes, but I believe that we will need new
legislation after the site is designated, and we have a

whole series of issues that need to be resolved by

legislation and that will be on the
of many.

list.

So it'

s one

I think that it will -- if the site is

designated, I think we ll get legislation that will

take care of other cats and

dogs.

Among the cats and dogs would be the disposal
of GTCC waste in the repository?

Yes.
At the bottom of Exhibit

46, there' s

a

handwritten notation, II Keep
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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Page 10 of 23

Susan Klein (vol
Page 524
My question

is:

Was the reason this

provis~on was included, the priority shutdown

prov~sion, that is because it was necessary to prevent

reactors from waiting 20 or 30 years to be

decomm~ssioned?
Yes.
And DOE included this prov~sion despite the
fact that four commenters recommended the deletion of
the provision?

Yes, that. s correct.
And as you explained I believe earlier,
acceptance of fuel from a shutdown reactor would allow

that reactor to go to green fields I believe is the

word that you used; is that correct?
Yes, it would.

In most cases, it would allow

them to go to green fields, yes.
17

If DOE had begun accepting fuel in 1998 at a
000 MTU rate or a ramp-up, a reasonable ramp-up to a
000 MTU rate, do you have an opinion as to whether

DOE could have given priority to shutdown reactors

without harming or prejudicing the rights of operating
22 \.utili ties.
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Case 1:98-cv-00126-JFM

Document 833-5

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Susan Klein (vol
Page 525
MS. POWELL:

Object to beyond the

scope,

but you can

answer.
THE WITNESS:

It could have given.

think that would be policy considerations that would be
looked at, but it would make it certainly -BY MR. MACDONALD:

Would have made it easier?

Much easier,

yes.

(Discussion off the record.

(Thereupon, the reporter marked for

identification Deposition Exhibit
BY MR. MACDONALD:

No. 50.

Ms. Klein,

I' ve just

marked -- had marked for

you Exhibit 50, which is a memo dated June 28, 1991
from P. N. McDuffie and S. A. Vance to D. C. Langstaff

and A. B. Brownstein.

Do you have that there before

you?
Yes, I

do.

I believe we discussed earlier Mr. Vance,
20 .

Scott Vance, who you know; is that right?

That'

s correct.

And Mr.

A. B.

Brownstein is Alan Brownstein;

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Document 833-5

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Susan Klein

Page 274
ESQUIRE DEPOSITION SERVICES
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Case 1:98-cv-00126-JFM

Document 833-5

Filed 06/28/2004

Susan Klein

Page 274
ESQUIRE DEPOSITION SERVICES
1020 19TH STREET, NORTHWEST

SUITE 620
WASHINGTON, D. C.

20036
ERRATA SHEET

Case Name:

Yankee Atomic Electric Co., et ale V.

The United States
Witness Name:

Susan Klein

Deposition Date: April 24, 2002
Job No.

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Case 1:98-cv-00126-JFM

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Page 23 of 23

Susan Klein

Page 274
ESQUIRE DEPOSITION SERVICES
1020 19TH STREET, NORTHWEST

SUITE 620
WASHINGTON, D. C.

20036
ERRATA SHEET

Case Name:

Yankee Atomic Electric Co., et ale V.

The United States
Witness Name:

Susan Klein

Deposition Date:
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