'"~' .
Case 1:98-cv-00126-JFM
Document 833-13
Filed 06/28/2004
Page 1 of 23
May 7 , 2002
Ronald A. Milner
Washington , D.
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C) (Merow ,
COMPANY
S .
CeRTIFIED COP
CONNECTICUT YANKEE ATOMIC POWER
(98- 154C) (Merow ,
S.
) Volume I
MAINE YANKEE ATOMIC POWER COMPANY) Washington , D.
(98-474C) (Merow , S.
) Tuesday
Plaintiffs
THE UNITED STATES
) May 7, 2002
Defendant.
Deposition of RONALD A. MILNER , a witness
herein ,
called for examination by counsel for
Plaintiffs in the above- entitled matter, pursuant to
agreement, the witness being duly sworn by CHERYL
LORD, a Notary Public in and for the District of
Columbia, taken at the offices of SPRIGGS &
HOLLINGSWORTH , 1350 I Street , N.
at 3
, Washington, D. C.,
:48 p. m.,
Tuesday, May 7 , 2002 , and the
proceedings being taken down by Stenotype by CHERYL
A. LORD , RPR , CRR, 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
Document 833-13
Filed 06/28/2004
Page 2 of 23
May 7 , 2002
Ronald A. Milner
Washington , D.
Page 37
That were not rail-accessible?
That were not rail- capable, and I may be
wrong.
So an approximation is ten?
It'
s not 50- 50.
Right.
rail, approximate?
So about ten , 15 percent are not
That'
Okay.
s my very general recollection, yeah.
I recognize it'
s kind of a -- a
rough approximation.
I s the department
sites there indefinitely?
MR. SHULTIS:
of energy planning to or
intending to leave failed fuel at the utility reactor
Obj ection, calls for a legal
(b) (6)
conclusion. witness.
Also Mr. Milner is not a 30
In my opinion, the department does not
plan to leave it there
definitely.
BY MR. SKALABAN
Is there any -- well, actually, in your
opinion, that wouldn
't be a
good policy, would it?
Not in my opinion.
MR. SHULTIS:
Same obj ection.
BY MR. SKALABAN
In actuality, failed fuel is moved in this
1111 14th
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Case 1:98-cv-00126-JFM
Document 833-13
Filed 06/28/2004
Page 3 of 23
May 7 2002
Ronald A. Milner
Washington , D.
Page 40
speculation.
m certainly not an expert in that
but I don
area,
I t know
of any.
BY MR. SKALABAN
And having worked in the office of storage
and transportation in OCRWM and now as its chief
operating officer, have you ever heard anyone express
the opinion that within OCRWM that failed fuel
couldn I t
to move?
be moved or would be technically infeasible
No.
Are you aware of any current OCRWM plans
~.e
to defer the acceptance of failed fuel?
MR. SHULTIS:
Objection ,
calls for a legal
conclusion.
I guess my understanding of the current
situation ~- and I think that I s provided
the standard contract - further in the queue.
BY MR. SKALABAN
for under
that the failed fuel is back
Okay.
Maybe we can take a look at
that.
And
If you could please take out Milner Exhibit
in particular, article six on Milner Exhibit
criteria for disposal , page 16602 , if you could take
a look at article 6 A , 2 B.
111114th
Alderson Reporting Company, inc. Street, N. W. Suite 400 1- 800- FOR-DEPOWashington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Filed 06/28/2004
Page 4 of 23
May 7 , 2002
Washington
Page 42
Page 44
"r"
fuel for purposes of the schedule. BY MR. SKALABAN: Whether it would be technically feasible
course.
BY MR. SKALABAN:
Q.
Q. ' And in the extreme case , do you
know whether or not the technology has been developed to put that into a safe , licensed container? MR. SHULTIS: Objection , calls for a legal conclusion. A. I don t know. That would be a utility operation responsibility in any event. BY MR. SKALABAN: Q. But it's possible that that kind of situation would be dealt with? As an engineer, I like to think that most things are technically feasible. Q. And you have no reason to believe that it wouldn t be technically feasible to develop a safe , NRC- licensed container to handle that extreme situation you posited? MR. SHULTIS: Objection , calls for a legal conclusion. A. I can t think of any. MR, SKALABAN: Can we go off the record a
to accept that spent fuel?
A. On the currently agreed- to schedule. Q. Do you have an understanding of what would happen if the department thought it wasn technically feasible to do it at that point in time on the currently agreed- to schedule? MR. SHULTIS: Objection , vague , calls for
a legal conclusion. Mr. Milner is not a 30(b)(6) witness. A. I guess in my opinion if the department determined that it wasn t technically
feasible on the schedule and since we ve already
A.
stated that we would accept it , it would move back in the queue. BY MR. SKALABAN: Q. Well , does this read to you more like just a basic operational provision , whereas the department is going to look at the individual case , if it can accommodate it at that time , it' s going to move it back a little bit? A. That' s the way I would read it. MR. SHULTIS: Asked and answered.
Page 43
Page 45
BY MR. SKALABAN:
fuel is going to be put back years later in the queue , does it?
Q. This doesn t suggest to you that failed
second? (Whereupon. at 5:08 p. , the taking of the instant deposition adjourned.
MR. SHULTIS: Objection , asked and answered , calls for a legal conclusion. A. I couldn t say on that. It would depend on the nature of the fuel. BY MR. SKALABAN: Q. Well , assuming that there was an NRC- licensed container for that failed fuel , would the department then accept it upon the currently
agreed schedule?
Signature ofthe Witness SUBSCRlBED AND SWORN to before me this
day of
12
r)1 il1
20
L.v,
ry
13 My Commission Expires:
f/t'-
MR. SHULTIS: Objection , calls for speculation , asks for a legal conclusion. A. I guess to my opinion , if for that specific failed fuel , if there were an NRC-certified container , theNRC said , yep, that particular fuel is okay to move in that container, then , yes. There s all kinds of failed fuel. You can have a fue! rod that goes -- the cladding is slightly unzipped , or it can have it totally failed and a bunch of pellets laying at the bottom of the pool. That' s the extreme case , of
12 (Pages 42 to 45)
IIII 14th Street ,
Alderson Reporting Company, Inc. N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
.!
---------------- - - - - - - - - - - - - - - Case 1:98-cv-00126-JFM
Ronald A Milner
Washington , D.
Document 833-13
Filed 06/28/2004
Page 5 of 23
May 8 , 2002
Page 47
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
(Merow, S.
COMPANY
CONNECTICUT YANKEE ATOMIC POWER
Volume II
) Washington ,
D. C
(98- 154C) (98- 474C)
(Merow, S.
MAINE YANKEE ATOMIC POWER COMPANY) Wednesday
(Merow, S.
) May 8 , 2002
Plaintiffs,
CERTIFiED COP"
THE UNITED STATES,
tf'
Defendant.
Continued Deposition of RONALD A. MILNER,
a witness herein, called for examination by counsel
for Plaintiffs in the above-entitled matter, pursuant
to agreement, the witness being duly sworn by CHERYL A. LORD, a Notary Public in and for the District of
Columbia, taken at the offices of SPRIGGS &
HOLLINGSWORTH, 1350 I Street, N.
W.
, Washington, D. C . ,
at 9:20 a. m., Wednesday, May 8, 2002, and the
proceedings being taken down by Stenotype by CHERYL
A. LORD, RPR , CRR, and transcribed under her
direction.
if?
Alderson Reporting Com r.any, Inc. 111114th Street, N. W. Suite 400 1- 800- FOR",
PEPO Washington
, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 6 of 23
May 8 W02
Page 59
And I believe you testified earlier that
that was -- even though the MPC program had been canceled, that that was a positive that came out of
it, is that industry did look and develop this
technology?
In my opinion, that was a positive,
And I mean, if it I S not going to be
yeah.
compatible with the waste management system that RW
is developing, then that wouldn t be a positive,
would it?
That would be a negative.
.13
That'
s right.
And so I mean as you sit here today, are
you aware of any DOE plans to cut off that kind of
technology from the system and not integrate it into
the system?
MR. SHULTIS:
Objection ,
asked and
answered.
I think the department is certainly
considering that it may have to open those canisters.
BY MR. SKALABAN
So at this point in time, there s a
possibili ty in your mind that the DOE is not going to
integrate multipurpose canisters into its system?
I think that I s a mischaracterization.
We I re
certainly going to be able to integrate and
Alderson Reporting Company, Inc.
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Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 7 of 23
May 8 , 2002
Page 60
handle multipurpose canisters.
The decision as to
whether or not that canister gets disposed of in the
repository is not the department' s decision.
That I
the Nuclear Regulatory Commission s decision.
I see.
Again, I'
m not trying to
mischaracterize.
Yeah.
I I m trying to understand.
And again -- so if I understand
correctly,
I mean, it' s your understanding, I mean, as COO of
OCRWM ,
that the system is going to accept those kind
of canisters.
It'
s just a matter of whether or not for
disposal the NRC will let you dispose of them as is
or in an overpack, I guess?
Correct.
You re not planning to go just cut that
technology off and kind of leave the utilities
hanging so to speak?
No.
MR. SKALABAN
I I d like to mark as Milner
Exhibit 96 the 1992 annual capacity
BY MR. SKALABAN
report.
And Mr. Milner, if you can look at
this,
and also Milner 51 , which is the 1995 annual capacity
report, and Milner
42.
So the numbers are 42, 51
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR-DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 8 of 23
May 8, 2002
Page 61
and 96.
(Milner Exhibit No. 9 6
was marked for
identif ication.
BY MR. SKALABAN
And Mr. Milner, before we start on these documents, I want to ask you a followup about what we
just talked about.
And I understand your testimony
to be it'
s not the department
I s intent to not accept
this kind of multipurpose canister technology that I s
being implemented by
utilities.
It plans to accept those kind of waste
packages?
That'
s correct.
MR. SHULTI~
Objection, calls for a legal
conclusion.
BY MR. SKALABAN:
And if you weren t going to do that, that
would potentially create some very serious problems
for the industry, wouldn t it?
MR. SHULTIS:
Objection ,
calls for
speculation.
If we were
riot going
to accept
multipurpose canisters, I think it would certainly
cause some problems for the
utilities.
They would
Alderson Reporting Company, Inc.
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Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 9 of 23
May 8 , 2002
Page 194
So if -- when the department starts
performing presumably in 2010, if there ' s no
alternative disposal site proposed and approved by
the commission,
it' s
going to consider taking GTCC
waste in your opinion?
MR. SHULTIS:
Objection, calls for a legal
conclusion, asked and answered.
Well, let me go to the matter of tlming
again.
To me, you seem to be inferring that when we begin accepting waste in the year 2010 that you
can infer from the NRC regulation that at that time
we I d
begin accepting GTCC, and I' m saying in my
opiniort I don
t think you can infer
that.
not
By the same token, there I s certainly
a reactor site for a hundred years
been any discussion or intent that GTCC would sit at
either.
The
department has simply not addressed that.
This
program has certainly not addressed that at this
point.
BY MR. SKALAB
As a matter of policy, wouldn t it be
to see that the GTCC waste goes somewhere
when the department begins performing, that it goes
ither to the repository, or alternatively, if an
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR-DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 10 of 23
May 8 , 2002
Page 195
alternative disposal site is developed, that it would
go there?
MR. SHULTIS:
Objection, vague, calls for
speculation.
In my personal opinion, I think there
should be an agreed-upon path forward for the
disposal of GTCC.
Again, my personal opinion, I
think it would not be good to leave it sitting at the reactor site or any site for any length of time, any
significant length of time.
BY MR. SKALABAN
I mean, that would be a bad policy,
wouldn t it, to leave GTCC waste at reactor sites for
an extended period of time even when all the -- even
when the rest of this -- well, let me rephrase.
It would be bad policy to leave GTCC waste
at reactor sites for an extended period of time if
the department has otherwise picked up all the spent
fuel from the site?
MR. SHULTIS:
Objection, mischaracterizes
prior testimony.
BY MR. SKALABAN:
Do you agree with that?
My personal opinion, in this mechanical
engineer I s opinion,
I think it would be bad policy to
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1- 800-FOR-DEPO Washington, DC 20005 .
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 11 of 23
May 8 , 2002
Page 196
leave GTCC sit at a reactor site long after all of
the spent fuel has been removed from that reactor
site.
MR. SKALABAN
Off the record.
(Recess. )
MR. SKALABAN:
Back on the record.
BY MR. SKALABAN:
We were just looking at the definition
of -- standard contract of high- level waste, and in
particular the provision about other highly
radioactive material that the commission consistent with existing law determines by rule requires
permanent isolation.
Would you agree that there
I s some
ambiguity in the application of that definition of
high- level
waste when it' s applied to the NRC
regulation that we ve just been looking at, which
requires disposal in a geologic repository in the
absence of an al ternati
MR. SHULTIS:
ve?
Objection, calls for a legal
conclusion, asks for speculation.
I guess
it' s
my understanding that the NRC
has not determined that GTCC requires disposal in the
Yucca Mountain repository.
BY MR. SKALABAN
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1-800-FOR-DEPO Washington , DC 20005
,.",
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 12 of 23
May 8 , 2002
Page 221
for disposal, you ve created a fairly large secondary
waste stream to deal with
canisters.
Any other disadvantages that you can think
of?
Not offhand,
no.
And at this point, if I understand again I don t want to -- I want to make sure I'
correctly testifying -- or correctly representing
your prior testimony -- at least currently the
department I s plans
are to accept canister systems and
to dispose of them if possible?
Certainly the department plans to accept
canister systems.
The department certainly hopes to
be able to dispose of
those.
Obviously, we would
prefer not to have to open them and create another
waste stream.
MR. SKALABAN:
Let me go ahead and mark
102
this.
I believe we re on Exhibit
is that
correct?
MR. SHULTIS:
MR. SKALABAN
103.
Thanks.
(Milner Exhibit No. 103
was marked for
identification.
BY MR. SKALABAN:
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 13 of 23
May 8 , 2002
Page 222
103 is a memo from Mr. Ronald Milner dated
March 8, 1994, to a series of people listed on a
distribution list,
and it contains an attachment.
And the subject of the memo is, modification of the
CRWMS program baseline to a multipurpose
canister- based system.
Are you familiar with this document,
Mr. Milner?
am,
What
yes. was the purpose
of this
document?
Essentially,
it'
stated here,
that
this was advising staff within the program that the
director of the program had approved a change to the
baseline to incorporate multipurpose canisters into
the baseline.
And what does that mean, to be
incorporated into the baseline?
That means that essentially that we expect and would accept canisters into the
system.
That was
part of the operation that we envisioned.
Was the intent of this at this time to
actually furnish multipurpose canisters to all of the
utilities?
To the best of my recollection, time
frames are unclear.
Certainly at one point, which
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR-DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 14 of 23
May 8 , 2002
Page 223
would be this approximate time frame, the department
gave consideration to furnishing multipurpose
canisters to utilities as a potential means to
mi tigate any delays.
Whether it was actually this
exact time frame,
I can t recall.
Certainly what this baseline change is
dealing with is not the provision of canisters to
anyone.
It I s simply
a change in the baseline so that
as part of the design process, designers will begin
to take into account multipurpose canisters in the
design of the system.
And is that baseline still in effect?
I believe it
MR. SKALABAN
is.
If I could mark now as
Exhibit 104.
(Milner Exhibit No.
104
was marked for
identification.
BY MR. SKALABAN:
Can you tell me what this -- and just for
the record, 104 is a memo, although I will indicate
there
s no approval signature on the memo, but it
appears to be a memo from Mr. Milner to Daniel
Dreyfus, the director of OCRWM.
Do you recall this memo?
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR-DEPO Washington , DC 20005
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Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 15 of 23
May 8 , 2002
Page 224
I do vaguely,
yes.
Did you send it Mr. Dreyfus?
My recollection is that I
did.
And what was the purpose of the memo?
Essentially to get the formal approval of
the director to terminate funding for the MPC
development program.
And was this in response to Congressional
appropriations?
It was.
So the effect of this memorandum is that
the department was no longer going to directly fund
the development of MPCs?
Correct.
Now, the second page, it says that the -at the top:
The technical and operational objectives
and advantages of standard canistered SNF defined in
the attached MPC approval memo are still
applicable.
Recognizing that I don t have the attached
memo, but at that time, do you agree with that
statement that the general -- or do you agree with
that generally that technical and operational
objectives and advantages of standard canister SNF
would still be applicable?
Yeah, I do.
Alderson Reporting Company, Inc. 1111 14th Street, N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 16 of 23
May 8 , 2002
Page 225
And it says at the very bottom:
The
will continue actions that are necessary to encourage private industry development and
utilization of casksl
slash ,
canister technologies
that provide the technical and operational objectives
and advantages that were anticipated with the MPC.
Do you see that?
Yes.
And that was your understanding of the
program -- of a program goal at that time?
Yes.
And to this day, does the program -- is -are -- excuse me.
Scratch that.
To this date, is the department still
encouraging the development and utilization of
cask/ canister
not a 30
technologies?
MR. SHULTIS:
Obj ection.
Mr. Milner is
(b) (6) witness.
I believe it
is.
I guess I would add that
at least in my opinion the work that DOE had done on
MPC technology development I think provided the seed
and the impetus which ultimately resulted in at least
a couple of canister systems being so far certified
for storage and transportation.
BY MR. SKALABAN:
Alderson Reporting Company, Inc.
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Ronald A. Milner
Document 833-13
Washington, D.
Filed 06/28/2004
Page 17 of 23
May 8 , 2002
Page 226
Such as some of the NAC systems?
Yeah.
And that' s a positive development?
It is.
MR. SKALABAN
d like to mark
defendant'
105.
s proposed stipulation of fact as Exhibit
(Milner Exhibit No. 105
was marked for
identification.
BY MR. SKALABAN:
I I m going to represent to you, Mr. Milner,
that this is the government' s proposed statements of
~'1
fact in the Yankee Atomic
litigation.
Do you -- have you ever reviewed or seen
this document?
I don t recall that I did, no.
Do you recall or have you reviewed any
pleadings in this litigation or filings in this
litigation other than interrogatories that we talked
about yesterday?
I have not.
And I'
m sorry.
Let me clarify my question
m saying, in this
also a little bit:
What I'
litigation, 1' m not limiting it just to Yankee
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Ronald A. Milner
Document 833-13
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Page 18 of 23
May 8 , 2002
Page 228
your understanding, are those canister systems that
are an outgrowth of what we ve just been talking
about, the multipurpose canister program that DOE was
looking at?
Actually, I' m
designation UMS.
not familiar with the
Certainly the NAC MPC is -- my
understanding suggests a canister
system.
Okay.
So you re -- just with respect to
the NAC UMS, you re just not sure if that is a
multipurpose canister- type system?
Yes.
Now, here the assertion is made that it is
a multipurpose element sealed canister.
Does that suggest to you that
it' s
canister- type
system?
m talking about the Maine Yankee part.
Yeah.
It suggests that certainly.
simply indicated I had not heard the term OMS
before.
Now, part 114, can you take a look at that
paragraph.
( Pause. )
BY MR. SKALABAN:
Do you agree with that?
MR. SHULTIS:
Obj ection, calls for a legal
conclusion.
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Document 833-13
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Page 19 of 23
May 8 , 2002
Page 229
To the best of my recollection, there is
no provision in the contract that requires disposal
of a canister.
BY MR. SKALABAN
Is there anything in the contract to your recollection that excludes acceptance of a canister?
MR. SHULTIS:
Same objection.
In my recollection, nothing excludes
it.
That I S my opinion.
BY MR. SKALABAN
So is the contract kind of open on the issue of whether or not a canister has to be
accepted?
MR. SHULTIS:
Objection, calls for a legal
conclusion, asked and
answered.
You know, in my opinion --
well, in fact,
when the contract was written and were no such things as
executed, there multipurpose canisters, so I
would have been surprised if they
in the contract in one way or
BY MR. SKALABAN
another.
d been referenced
Can you take a look at proposed finding of
fact 145,
which is on page 70 of this document.
Mr. Milner, what I'
d like to ask you first
is, as a general matter, do you think it' s an
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May 8 , 2002
Page 262
If I could call to your attention Milner
For the record this is the draft 1988
mission plan amendment.
If you could take a look at page 16.
the section 2.
it says:
, transportation, in the second
paragraph under that heading in the second sentence
The casks be be developed for shipments
from reactors will differ from the casks currently
used for spent fuel shipments in that they will have
considerably greater capacities.
Do you see that?
I do.
Does that reflect the department
I s intent
at the time to either directly develop or encourage
the development of larger-capacity casks?
MR. SHULTIS:
Objection.
The document
speaks for itself.
I believe at that point in time, the department was involved in development effort to
develop higher-capacity casks.
BY MR. SKALABAN:
So that was -- the department was
intending to use greater-capacity casks in its
program?
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May 8, 2002
Page 263
The department certainly had an obj ecti ve to utilize higher-capacity casks. And still has that objective today? Certainly. What are the reasons for that? utilization higher-capacity casks, you make less shipments. And so it I S more cost-effective?
Yes.
And there
s less repetitive visits to
individual utility sites?
Correct.
What' s the estimated average turnaround
time for one rail cask trip to a reactor to a
reposi tory?
I don
t recall.
Would a month sound right, or is it longer
than that?
I guess to me a month would be to the best
of my recollection.
It may be a little on the high
side, but I really don t recall.
You I re thinking it could be a quicker
turnaround time from a trip from the repository to a
site and like a complete round- trip?
My recollection is, the estimate is a
Alderson Reporting Company, Inc. 111114th Street, N. W. Suite 400 1-800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington
Filed 06/28/2004
Page 22 of 23
May 8 , 2002
Page 264
Ii ttle bit less
than that, but again I really don
If I wanted to find out the answer to that
question, who would I ask in the department?
Well, I believe that the estimates of turnaround times and so forth are embodied somewhere
in the TSLCC analysis.
Whether it' s specifically
stated in the published report, I don t recall.
person responsible for the TSLCC analysis is
The
currently the acting director of the -- I forget what
we call it now -- acceptance transportation and
integration office.
And who is that?
That'
s Jeff Williams.
Does the department anticipate any
problems handling higher burnup
fuel?
What I mean by that is fuel -I understand the term higher burnup, yeah.
MR. SHULTIS:
Objection, vague.
I guess I' m vaguely aware that somebody
has raised the question as to whether or not there
would be any difficulty in handling higher burnup
fuel.
I don t recall any specifics or any specific
concern.
BY MR. SKALABAN
't;.'l.;,V)
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR-DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Ronald A. Milner
Document 833-13
Washington , D.
Filed 06/28/2004
Page 23 of 23
May 8, 2002
Page 266
capacity report.
d like to call your attention to the -inside the first page, there
I s a letter from Ben
Rusche, or a statement signed by Mr. Rusche.
Do you see that there
I s a statement there
where Mr. Rusche says:
Even more importantly, comma,
it activates a mechanism through which contract
holders can express their views on how the waste
management system can achieve maximum efficiency
while assuring equity among the parties?
What did Mr. Rusche mean to your knowledge
about achieving maximum efficiency?
MR. SHULTIS:
Objection, calls for a legal
conclusion, calls for
speculation.
I don t know what specifically what
Mr. Rusche was referring
to.
I can form an opinion
in my own mind at this point in time reading that
that the start of issuing this document indicated to
the utilities at that time what the capacity in the
rankings plans were, and that could be the basis for
comment on how efficiencies might be improved
BY MR. SKALABAN
Has it been the objective of OCRWM to
the waste management system in a way that can
maximum efficiency?
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005