Case 1:98-cv-00126-JFM
Document 833-12
Filed 06/28/2004
Page 1 of 21
EXHIBIT
~:~ ,, "'"
-Case 1:98-cv-00126-JFM
---Document 833-12
---Filed 06/28/2004 Page 2 of 21
May 1 , 2002
Ronald A. Milner
Vol I McLean , VA
Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
- -x
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
(Merow ,
S .
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98- 154C) (Merow, S .
FLORIDA POWER & LIGHT COMPANY
(98- 483C) (Wilson ,
(98 - 484C) (Wiese, J.
DUKE
J.
NORTHERN STATES POWER COMPANY
POWER, A Division of
CERTIFIED COh3~tf
, J .
DUKE ENERGY CORP.
( 98 - 4 8 5 C) (Sypo 1 t
INDIANA MICHIGAN POWER COMPANY
(98 - 486C) (Hodges, J.
SACRAMENTO MUNICIPAL UTILITY DISTRICT
( 98 - 4 8 8 C) (Yock,
S. J
SOUTHERN NUCLEAR OPERATING COMPANY,
et al.
( 98 - 4 8 8 C) (Yock,
S. J.
COMMONWEALTH EDISON COMPANY
(98- 621C)
(Hewitt, J.
BOSTON EDISON COMPANY
(99 - 44 7C) (Allegra,
J.
GPU NUCLEAR, INCORPORATED
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 833-12
Filed 06/28/2004
Page 3 of 21
May 1 , 2002
Vol I McLean , VA
Page 2
(00- 440C)
(Bush, J.
WISCONSIN ELECTRIC POWER COMPANY
( 0 0 - 6 9 7 C) ( Me row , S. J.
POWER AUTHORITY OF THE STATE OF NEW YORK
(00- 703C) (01- 115C) (01- 116C) (01- 249C)
(Damich, J.
OMAHA PUBLIC POWER DISTRICT
(Bush, J.
NEBRASKA PUBLIC POWER DISTRICT
(Sypolt, J.
TENNESSEE VALLEY AUTHORITY
(Bruggink, J.
Plaintiffs,
Discovery
THE UNITED STATES,
: Judge:
Defendant.
McLean, Virginia
: (Judge
- -xSypol t)
Wednesday, May 1, 2002
Deposition of RONALD A. MILNER, a
witness, called for examination by counsel for Plaintiffs in the above-entitled
matter,
pursuant to notice, the witness being duly sworn
by CATHERINE S. BOYD, a Notary Public in and for
the Commonwealth of Virginia, taken at the
offices of Shaw Pittman, LLP, 1650 Tysons
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 833-12 Filed 06/28/2004 Vol I McLean , VA
Page 4 of 21 May I , 2002
Page 12
Officer for the Civilian Radioactive Waste
Program.
And how long have you held that
position?
About two and a half
years.
And to whom do you report?
Lake Barrett, who is the deputy
director.
And how many people report to you as
the Chief Operating Officer?
I guess approximately 150 federal
staff.
Are there contractors that report to
you also?
Not directly, but there are
contractors in the orGanization.
Q. Can you describe for me your duties as
Okay.
the, what I'll refer to as the COO for OCRWM?
Basically it'
s to manage the
operational aspect of the
program.
What do you mean by operational
aspect?
Can you tell me what you mean by that
term?
Day-to- day
operations of the program
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 833-12 Filed 06/28/2004 Vol I McLean , VA
Page 5 of 21
May 1 , 2002
Page 13
administrative principally. All right. When you
say
administrative, do you mean you' re primarily
involved in personnel matters, or am misunderstanding what you mean by that term?
Personnel matters, contractual
matters.
When you say contractual matters, what
do you mean by that?
Matters relating to our support
servlce contracts, our contract with our M&O.
What is your educational background? I m a mechanical engineer by
education.
Okay.
obtain a degree?
University of Mississippi.
From what institution did you
And that was a Bachelor of Science
Degree?
A Bachelors and a
Masters.
What year did you obtain your
Bachelors Degree?
1966.
And in what year did you obtain your
Masters Degree?
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 833-12
Filed 06/28/2004
Page 6 of 21
May 1 2002
Ronald A. Milner
Vol I McLean , VA
Page 59
Amendment was issued?
I can't recall.
Can I direct your attention to the
last page of this exhibit, Mr. Milner?
This has printed on it the date of
8/10/99 in the lower right- hand
corner.
As of that date, what was your
position on this organization chart?
(The witness reviewed the document.
THE WITNESS:
I believe it was acting
deputy director.
I can't recall exactly when I became
Chief Operating Officer.
15 like marked as Milner Exhibit No.
Radioactive Waste Management.
14 r"
MR. TOMASZCZUK:
Ms. Reporter ,
I would
2 a one- page
document which we have downloaded from the DOE
Web site, and it is entitled Appendix
organization chart, Office of Civilian
(Milner Exhibit No.
was marked for
identification.
BY MR. TOMASZCZUK:
Are you familiar with this
Mr. Milner?
document,
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 833-12
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Page 7 of 21
May I , 2002
Ronald A. Milner
Vol I McLean , VA
Page 60
Yes.
All right.
And does it accurately
depict OCRWM' s current organization?
Yes, it does.
And you' re serving as Chief Operating
Officer, correct?
Correct.
This organization chart shows that
everybody reports up to you , is that fair?
Correct.
And in that capacity, you'
responsible for all of OCRWM' s
publications?
Yes.
Including but not limited to the TSLCC
reports and the fee adequacy reports, right?
Correct.
(There was a pause in the
proceedings.
BY MR. TOMASZCZUK:
I understand that Mr. Barrett is going
to retire.
Is that your understanding?
That'
him?
s correct.
Do you know who is going to replace
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1-800- FOR- DEPO Washington , DC 20005
..,
(~.
Ronald A, Milner
Case 1:98-cv-00126-JFM
Document 833-12
McLean , V A
Filed 06/28/2004
Page 8 of 21
May 1 2002
Page 194
Page 196
Annual Capacity Report.
I can represent that I believe it' s
a
that.
MR. SHIJL TIS: Okay.
draft document.
(Milner Exhibit No. 19
3 (Whereupon , at 6:00 p.
was marked for identification. BY MR. TOMASZCZUK: Q. Have you seen this document before today, Mr. Milner? A. I don t recall. Q. My characterization of the document as a draft is, seems fair to you? A. It appears to be , yes. Q, Do you know whether a , an ACR was issued in final form for 1989? A. I don t know. Q. In June of' , were you or personnel in your office responsible for ACRs? A. I believe it was. Q. Do you know who prepared this draft? A. No , I don Q, Who In your office at this time would have been working on ACRs? A. I don t recall. Q, Was Mr. Brownstein reporting to you at
, the deposition was recessed , to reconvene Thursday, May 2 , 1002 , at 9:15 p.
RONALD
~-Yv:~ER
20-
SUBSCRIBED AND SWORN to before me this;:7Y.1
day
of-----__ LL..k:"""k------------
'VA I
.r7
NOTARY PUBLIC
i7
18 My
commissIOn expires:
j/'
,i
Page 195
Page 197
this time?
A, I don
t recall offhand, He may have
been.
whether there was anything about this draft that
CERTIFICATE OF NOTARY PUBLIC , Catherine S. Boyd , the Notary Public before whom the proceeding occurred
pages I through 196, do hereby certify that the witness was duly sworn , that the testimony, of
Q. Sitting here today, do you recall
caused an ACR not to be issued in 1989 in final form? MS, HERRMANN: Objection -- vague foundation. THE WITNESS: I don t recall , no, MR. TOMASZCZUK: Let' s mark as Milner 20 a November 1989 report to Congress on reassessment of the Civilian Radioactive Waste
Management Program.
(Milner Exhibit No, 20
was marked for
said witness was taken by me and thereafter reduced to this typewritten transcript under my supervision , that said transcript is a true record of the testimony given by said witness that I am neither counsel for, related to , nor employed by any of the parties to the proceeding, and further, that I am not a relative or an employee of any attorney or counsel employed by the parties thereto , or financially or otherwise interested in the
outcome of the proceeding, or any action
identification, MR, TOMASZCZUK: Actually it' s six clock.
I propose we adjourn.
involved therewith. Witness my signature and seal:
(The transcript continues on tbe
following page,
CATHERINE S. BOYD
Notary Public in and for
MS. HERRMANN: We have no problem with
The Commonwealth of Virginia My commiSSIon expires: February 28, 2006
50 (Pages 194 to 197)
II1I ' 14th Street, N,
Alderson Reporting Company. Inc. , Suite 400 1- 800- FOR- DEPO Washington , DC 20005
-Case 1:98-cv-00126-JFM Document 833-12 Filed 06/28/2004
- Page 9 of 21
May 2 , 2002
Ronald A. Milner
McLean , VA
Page 197
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98 - 126C) (Merow , (98 - 154C) (Merow ,
S. J.
CONNECTICUT YANKEE ATOMIC POWER COMPANY
S. J.
FLORIDA POWER & LIGHT COMPANY
(98- 483C) (98- 484C)
DUKE ENERGY CORP.
(Wilson, J.
NORTHERN STATES POWER COMPANY
(Wiese,
DUKE POWER, A Division of
ClrliftedCopv
(Sypolt,
(98- 485C)
(98- 486C)
INDIANA MICHIGAN POWER COMPANY
(Hodges, J.
SACRAMENTO MUNICIPAL UTILITY DISTRICT
(98- 488C) (Yock ,
S.
SOUTHERN NUCLEAR OPERATING COMPANY,
et al.
( 98 - 4 8 8 C) (Yock ,
S. J.
COMMONWEALTH EDISON COMPANY
(98- 621C)
(99- 447C)
(Hewitt, J.
BOSTON EDISON COMPANY
(Allegra, J.
GPU NUCLEAR , INCORPORATED
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
McLean , VA
Page 198
Document 833-12
Filed 06/28/2004
Page 10 of 21
May 2 , 2002
(00- 440C) (00- 697C)
(Bush, J.
WISCONSIN ELECTRIC POWER COMPANY
(Merow , S.
POWER AUTHORITY OF THE STATE OF NEW YORK
( 0 0 - 7 03 C) (Dami ch , J.
OMAHA PUBLIC POWER DISTRICT
(01- 115C) (01- 116C) (01- 249C)
(Bush, J.
NEBRASKA PUBLIC POWER DISTRICT
(Sypolt, J.
TENNESSEE VALLEY AUTHORITY
(Bruggink, J.
Plaintiffs,
THE UNITED STATES,
Discovery Judge:
: (Judge
xSypo 1 t
McLean, Virginia
Defendant.
Thursday, May 2, 2002
Continued deposition of RONALD
MILNER, a witness, recalled for examination by
counsel for Plaintiffs in the above- entitled
matter, pursuant to notice, the witness being
duly sworn by CATHERINE S. BOYD, a Notary Public
in and for the Commonwealth of Virginia, taken
at the offices of Shaw Pittman, LLP , 1650 Tysons
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 833-12
Filed 06/28/2004
Page 11 of 21
May 2 , 2002
McLean , V A
Page 217
MR. SHULTIS:
legal conclusion.
Obj ection.
Calls for a
Mr. Milner is not a
THE WITNESS:
don I t
30(b) (6)
witness.
At this point in time
,I
recall any I was aware of at that point in
time.
BY MR. TOMASZCZUK:
Isn
t it true, Mr. Milner, that the
9 I DOE' s intentions with respect to repository
10 \ design receipt rates have stayed constant over
11 the years at 3, 000 metric tons?
MR. SHULTIS:
legal conclusion.
Obj ection.
Calls for a
Mr. Milner is not a
THE WITNESS:
30(b) (6) witness.
It indicates that the
steady-state rate stayed at 3, 000, yes.
BY MR. TOMASZCZUK:
Q.
years, has it? 22
And that hasn
t changed really in
MR. SHULTIS:
THE WITNESS:
The same obj ection.
Would appear not to
\have.
MR. TOMASZCZUK:
Give me just one
second.
THE WITNESS:
Sure.
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington, DC 20005
Case 1:98-cv-00126-JFM
Document 833-12
Filed 06/28/2004
Page 12 of 21
May 2 , 2002
Ronald A. Milner
McLean , VA
Page 232
Mr. Milner is not a
THE WITNESS:
30(b) (6) witness.
Well , again, given that
they are assumptions for different depending on which case was assumed would have reflected DOE I S goal.
cases,
, yes, it
May
Q.
MR. TOMASZCZU
At or about this point in time
1989, are you aware of any documents published
by DOE which would have indicated a design rate
other than 3 000 metric tons for the
steady-state operation?
No, not that I can
recall.
And would I be fair in assuming that
if there were such documents, you would be aware
of them?
I certainly would have ho ed
MR. TOMASZCZUK:
so.
This could be off the
record.
(A discussion was
held off the
record.
BY MR. TOMASZCZUK:
Mr. Milner , I would now like you to
get in front of you Exhibit 20, which was the
last exhibit that we marked yesterday
but we
adj ourned and I didn't ask you any questions
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 833-12
McLean. V A
Filed 06/28/2004
Page 13 of 21
May 2 , 2002
!'~ge 402
does.
Q, It appears that these ;ales are b~s~d
on the existence of an MRS? A, Apparently so. MR. TOMASZCZUK: It' s 6:~O. (Whereupon, at 6:20 p. , the deposition was recessed, to reconvene at 9:00
.mM
SUBSCRIBED AND SWORN to before me this_
day Of----
1'
r:;li-
RONALD A. MILNER
2!~
, 20~::
r;::.if-/+:'__-/
My commission expires:
1'-'
NOTARYPUBLIC
:'5
~1.I III.
1t
t::'
Page 403
, 10
CERTIFICATE OF NOTARY PUBLIC , Catherine S. Boyd , the Notary Public before whom the proceeding occurred pages through , do hereby certify that the witness was duly sworn , that the testimony of said witness was taken by me and thereafter reduced to thi!; typewritten transcript under my supervision , that said transcript is a true record of the testimony given by said witness that I am neither counsel for, related to , nor employed by any ofth~ parties to this proceeding, and further , that I am not a relative or an employee of any attorney or counsel employed by the parties thereto, or financially or otherwise interested in the outcome ofthe proceeding, or any action involved therewith. Witness my signature and seal:
CATHERINE S, BOYD Notary Public in and for The Commonwealth of Virginia My commission expires: February 2S , 2006
53 (Pages 402 to 403)
J J II
Alderson Reporting Company, Inc. 14th Street , N, W, Suite 400 J- 800- FOR- DEPO Washington. DC 20005
:..
.'
------------------Case 1:98-cv-00126-JFM
Ronald Milner
Document 833-12
McLean, V A
Filed 06/28/2004
Page 14 of 21
May 3 , 2002
. 1;~
Page 403
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
CONNECTICUT YANKEE ATOMIC POWER COMPANY
(98 -154C)
MAINE YANKEE ATOMIC POWER COMPANY
(98- 474C)
FLORIDA POWER & LIGHT COMPANY
(98 - 483C)
NORTHERN STATES POWER COMPANY
(98 - 484C)
DUKE POWER , A Division of DUKE ENERGY CORP. (98- 485C) INDIANA MICHIGAN POWER COMPANY
(98 - 486C)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
(98 - 488C)
SOUTHERN NUCLEAR OPERATING COMPANY
et al. ,
,,~;,J
(98- 614C)
COMMONWEALTH EDISON COMPANY
(98 - 621C)
BOSTON EDISON COMPANY
,r
(99- 447C)
GPU NUCLEAR , INCORPORATED
(00 - 440C)
WISCONSIN ELECTRIC POWER COMPANY (00 - 697C) POWER AUTHORITY OF THE STATE OF NEW YORK (00- 703C) OMAHA PUBLIC POWER DISTRICT ( 01- 115C) NEBRASKA PUBLIC POWER DISTRICT ( 01- 116C) TENNESSEE VALLEY AUTHORITY
(01- 249C)
Plaintiffs
Defendant.
UNITED STATES OF AMERICA,
Washington, D. C .
Friday, May 3, 2002 Continued Deposition of RONALD MILNER, a witness herein , called for examination by counsel for
Alderson Reporting Company, Inc. N. W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
1111
14th Street ,
Case 1:98-cv-00126-JFM
Ronald Milner
Document 833-12
McLean , V A
Filed 06/28/2004
Page 15 of 21
May 3 , 2002
Page 418
for such priority be deleted, that the Department had not accepted that recommendation because again it
states that this type of priority is necessary to
prevent reactors from waiting 20 or 30 years to be decommissioned after they finish generating
electricity.
And, again, my question is, was avoiding
that kind of delay a goal or objective of the
Department?
MR. SHULTIS: THE WITNESS:
Objection, same objection.
No, and again, my
recollection of the situation is that the Department
preferred not to preclude the ability to give some
priori ty to shutdown
how comments were
reactors.
But of course we are
reading from the preamble to the rule and discussing
addressed.
BY MR. NESLIN:
That I S
correct.
Did the Department have
any interest in the timely decommissioning of
shutdown reactors?
It did.
MR. SHULTIS:
Same objection.
BY MR. NESLIN:
That was an interest of the Department I s?
It was an interest, yes.
Alderson Reporting Company, Inc.
1111 14th Street, N. W. Suite 400 1- 800-FOR-DEPO Washington , DC 20005
~~j
Case 1:98-cv-00126-JFM
Ronald Milner
Document 833-12
McLean , V A
Filed 06/28/2004
Page 16 of 21
May 3 , 2002
Page 419
The Department , would it be fair to say
that the Department had an obj ecti
ve of allowing
shutdown reactors to decommission in a timely manner?
MR. SHULTIS:
THE WITNESS:
Same obj ection.
Well, again , I think it was
more a case that the Department preferred not to
preclude that ability.
BY MR. NESLIN:
What do you mean by not preclude that
ability?
The Department did not as I recall have an
objective to give priority to shutdown reactors, it
simply preferred not to preclude that ability in the
future.
My question isn t about asking granting priority, my question is simply did the Department
have an obj ecti
ve of allowing
shutdown reactors to
decommission in a timely manner?
MR. SHULTIS: THE WITNESS:
Same objection.
It did, yes.
BY MR. NESLIN:
And would that remain an objective of the
Department I s today?
I believe
so.
If we could turn to page
16606, do you see
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 Milner
Document 833-12
McLean, V A
Filed 06/28/2004
Page 17 of 21
May 3 , 2002
Page 447
No.
I thought that you testified that you also
considered the potential for brokering exchanges
between utilities?
Yeah, as a
concept, yes.
What do you mean, what do you mean by as a
concept?
We were
well, looking at the concept of
was it appropriate for the Department to do that sort
of thing.
What was your opinion?
My personal opinion was that it potentially could serve a useful purpose if the
utilities desired such an
activity.
purpose,
And what do you mean by useful
what would that purpose be?
Well , certainly one purpose could have
been if
storage another
one utility that was needing to build a dry
that was
farther
down in the
queue, and
utility that had a higher priority that
either didn
I t at
that particular time or perhaps
t recall
even life of plant storage, which I don
anybody was that high in the queue that they had life
of plant, but you could preclude the need for
constructing dry storage if such an exchange were
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 Milner
Document 833-12
McLean, V A
Filed 06/28/2004
Page 18 of 21
May 3 , 2002
Page 448
(acte,
And that would be beneficial to the
utilities?
Certainly to the utility that would have
had to build the dry
storage.
Would it also be beneficial to the
program?
Not necessarily,
no.
When you refer to brokering, what do you
mean by that?
If we had done comparisons and saw a
situation where , as I just described, that occurred,
I guess one concept might have been that we would contacted both utilities and inquired as to their
15
interest in exchange and trying to bring it
Was this concept memorialized or
documented in any way?
about.
16 .
Not that I recall, no.
Do you recall any documents discussing how
this brokering might work?
MR. SHULTIS:
Obj ection, asked and
answered.
THE WITNESS:
Not that I recall other than
what we just looked
at.
BY MR. NESLIN:
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 Milner
Document 833-12
McLean, V A
Filed 06/28/2004
Page 19 of 21
May 3 , 2002
Page 476
reactor in the queue?
Correct.
And certainly there were
discussions at that point in time and at various
points in time with industry representatives as to
whether there was any desire on the part of the
industry in general to give priori ty reactors. Other than --
to shutdown
The Department raised that issue a number
of times with the industry and the in~ustry consensus
al ways was no.
By consensus, do you mean it was
uniform,
everyone in the industry took that position or
something else?
Well, certainly the majority.
16
Other than the effect on other utilities,
were there other reasons that the Department would be
unwilling to grant priority to a shutdown reactor?
MR. SHULTIS:
a 30(b) (6) witness.
Objection, Mr.
Milner is not
THE WITNESS:
Well, my opinion, yeah,
there would be
several.
Well, if approval somehow
adversely - -
I can t necessarily think of a situation
where that would occur, but if somehow approval or
doing that would have adversely affected the
system,
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 Milner
Document 833-12
McLean, V A
Filed 06/28/2004
Page 20 of 21
May 3 , 2002
it would have been.
BY MR. NESLIN:
Sitting here today can you think of a way
of which approving authority to shut down a reactor
would have adversely affected a syst~m?
The federal system, I can not, no.
Any other reasons why the Department would
be unwilling to grant priority to a shutdown
MR. SHULTIS:
a 30
reactor?
Obj ection, Mr. Milner is not
(b) (6) witness.
Calls for speculation.
I can' t think of
THE WITNESS:
any.
I can
I t
In my
opinion, the chief one would be
think of any others.
equity.
(Milner Exhibit No. 59 was
marked for identification.
BY MR. NESLIN:
Mr. Milner , Exhibit 59 is a report by S. R.
Rod, Pacific Northwest Laboratory, entitled, Cost
Estimates of Operating onsite Spent Fuel Pools After
Final Reactor Shutdown.
Uh- huh.
Now I note on page HQR- 025- 0904,
under the
distribution list,
this report.
you re listed as a recipient of
Do you recall this report?
No, I don' t specifically recall this
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 833-12
Filed 06/28/2004
Page 21 of 21
CERTIFICATE OF REPORTER
UNITED STATES OF AMERICA)
ss.
COMMONWEALTH OF VIRGINIA)
, CYNTHIA R. SIMMONS, RPR, CRR, the officer before whom the
foregoing deposition was taken, do hereby certify that the witness whose testimony
appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken by me to the best of my ability and thereafter reduced to
typewriting under my direction; that I am neither counsel
for
related to ,
nor
employed by any of the parties to the action in which this deposition was taken , and
further that I am not a relative or employee of any attorney or counsel employed by
the parties thereto , nor financially or otherwise interested in the outcome of the
action.
Notary Public in and for
the Commonwealth of Virginia
My Commission expires: 11/3012004