Case 1:98-cv-00126-JFM
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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
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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
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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
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Case 1:98-cv-00126-JFM
Document 833-5
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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
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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
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Case 1:98-cv-00126-JFM
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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
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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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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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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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Susan Klein (vol
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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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Page 12 of 23
Susan Klein
Page 274
ESQUIRE DEPOSITION SERVICES
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Witness Name:
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ESQUIRE DEPOSITION SERVICES
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Case Name:
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ESQUIRE DEPOSITION SERVICES
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Case Name:
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ESQUIRE DEPOSITION SERVICES
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ESQUIRE DEPOSITION SERVICES
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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
Filed 06/28/2004
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:
Job No.
April 24,
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