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with the MRS concept at the
just don
time.
You know
I t know.
,I
So your testimony is DOE did not have
the capability during the IS- year period between
1983 and 1998 of developing whatever special
handling procedures for failed fuel may have been
necessary to commence operations and acceptance of
failed fuel commencing in January 1998; is that
what you I re telling me?
MS. HERRMANN:
Obj ection.
what the plans
Tha t ' s a
mischaracterization of his prior
I don
testimony.
were.
I t know
don' t know what the intentions were because that
wasn I t
the - -
failed fuel was not standard fuel
and I don't know what the plans
17 just asking about - - plans are included in my
question.
Plans could have been developed to
16
Q. Okay. I' m not asking about plans.
were.
address the problem , study the problem, or if it
was a problem study the issue of failed fuel and
how to accept
it.
And whatever special handling
procedures may have been or may be necessary in
order to accept spent fuel , the DOE had the
capability, the technical expertise of developing those special handling procedures and implementing
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1 ~ them by January 1998 when the acceptance of spent
fuel was supposed to begin, correct?
MS. HERRMANN:
Obj ection.
Vague.
Speculation.
In a IS- year time period, if there is a
will and finances, et cetera , from the
technological point of view you can develop a
system to accept failed fuel in a IS9 year period.
m going to hand you what the reporter
is about to mark as Exhibit
81.
(Barrett Deposition Exhibit
No. 81 was marked for
identification.
BY MR. STOUCK:
Let me identify this for the
record.
It is entitled, Transportation Business Plan
January 1986,
0311.
Bates number HQR- 037- 0258 through
Is that the document that you have?
It is.
Have you seen this before?
Yes.
What is it?
It is Transportation Business Plan from
long ago , January ' 86 .
1111
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Yes.
Do you consider yourself to be
knowledgeable about " the schedule
DOE would have
followed had it begun to take SNF from purchasers
by January 31 , 1998 pursuant to the contract.
MS. HERRMANN
Objection.
Vague.
I suppose I have as much knowledge as
many.
As many?
Your last word was M-
is that what you said?
Yes.
What schedule
I never said I know as much as one
might know. view.
I know it from a policy point of
Could you give testimony under oath
about the schedule that DOE would have followed
had it taken SNF from purchasers by January 1998?
MS. HERRMANN
Obj ection.
Vague.
I will answer questions under
I can.
oath, if
What schedule would DOE have followed
had it begun to take SNF from purchasers by
January 31 , 1998 pursuant to this contract?
MS. HERRMANN
Obj ection.
Foundation.
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Lake H. Barrett CONTAINS CONFIDENTIAL INFORMATION PURSUANJ TO THE PROTECTIVE ORDER May 14 2002
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Mr. Barrett is not here as a 30
(b) (6) witness.
We would have operated our system at
our plant which was, you know , whatever the
operation rate which transiented and leveled
out at
3, 000 metric tons
That I s what That' s what
per year after five
years. . That'
s what we were planning to
do.
you would have done?
we would have done if we
could have gotten the , you know , the sites
approved, et
cetera.
do you happen
And in what sequence
to know, can you just generally tell me a ramprate up to that 3, 000 ton rate that might have
been realistic?
MS. HERRMANN
Obj ect ion.
Foundation.
I don't know what system we are
referring to or what time because those are
changes as a function of
time.
So if you give us
the time frame
The government has told us that you are
one of the most knowledgeable people about how
the schedule would have been
asking about any documents.
I m not referenced. I m asking what the
schedule would have been.
You already told me it would have
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leveled out at a steady state of about 3,
000 tons,
and I I m trying
to find out your best testimony
about what the ramp- up rate would have been had
DOE gotten to take spent fuel by January 31, 1998.
MS. HERRMANN
Obj ect
ion.
If you want to answer by reference to
the current program plan or some other program
plan, that' s fine, or if numbers, that' s fine, or don t know , that' s fine.
what your answer
you want to answer with
if you want to tell me you
But it says here that you
are knowledgeable about this and I want to know
is.
Obj ection.
MS. HERRMANN
Foundation
speculation, and now it is vague.
It would have been whatever the rate
was for the MRS that we could have potentially
put in place in 1993 with whatever was in the
reference documents then which was something like
4-6-
12, 2
000, 3, 000.
And in what sequence would DOE
have accepted spent fuel from the various utility
contract holders had DOE begun to take SNF from
purchasers by January 31, 1998?
MS. HERRMANN
Obj ection.
Foundation.
Speculation.
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We would have
first of all it was
nonstandard fuel ,
and then use the oldest fuel
first table we looked at earlier by the contract
holders and worked out the details , or waste
acceptance issues ,
I think, was the name we used
to actually go down to shipping
campalgns.
so the
When you say worked out
actual sequence would not have been oldest fuel
. 9
first ,
it would have been some adjustment or
rearrangement of oldest fuel first; is that what
you are telling me?
MS. HERRMANN:
Obj ection to the extent
it mischaracterizes his
testimony~
It is my understanding that utilities
did not have to automatically ship the oldest fuel
first. first.
They had allocations based on oldest fuel
What fuel was shipped was an issue that
needed to be worked out between the contract
holders and the Department.
And as of today
- - well ,
would what
fuel have been shipped , have been worked out in
the manner you just described by January 31 , 1998 if DOE had begun to take SNF by that date from the
purchasers?
MS. HERRMANN:
Obj ection.
Foundation.
1111 14th
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~eCulation.
2 ~
A. Yes. Q.
No.
Do you know what the outcome of that
working out of the ultimate schedule for
acceptance would have been?
MS. HERRMANN
Same obj ections
Thank you.
Now , if you turn to Page 65 you are
again - -
now see how this document works.
You are
again listed as one of the individuals under
Interrogatory Number 65 , one of the individuals
within DOE with the most knowledge of whether DOE
would have given priority to purchasers with
shutdown facilities" -- 11 m sorry, would have
glven -- strike all
that.
The diction of this is
not very good, but let me start
over.
What this interrogatory says, at least
according to this page
is,
"Identify the three
individuals within DOE with the most knowledge of
whether DOE would have given priority to
purchasers with shutdown facilities priority in
the utility queue pursuant to the Standard Contract Articl~
VI. B .
1. b.
Do you see that?
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inside at Hanford?
Yes.
Paid the fee to the government?
No.
They paid a
fee.
Who did they pay the fee to?
The operator of the facility, which
think is U. s. Ecology
Okay.
Thank you.
Now , tell me what effect this
litigation has had on RWI s consideration of
whether or not to accept GTCC wastes for disposal
in the repository.
MS. HERRMANN:
Obj ect
ion.
Vague,
foundation.
And let me caution you, if this requires
disclosure of communication between you and
counsel you should not answer~
All the litigation issues have just
made it very complex to make decisions that are in
shades of gray such as our authority to dispose of the greater than Class C waste, as well as the
22 t
financial equities between the government and the
individual contract holders, so that has made it
~ more difficult to reach closure on this
matter.
When you say has made it more
difficult,
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has this litigation caused the consideration by RW
of whether or not to accept GTCC wastes for
disposal in the repository to cease?
Has the
litigation caused consideration to essentially
stop or lS consideration of that matter ongoing?
As I said , it just makes it much more
complex.
Well, is consideration of disposing of
GTCC waste in the repository currently ongoing
within RW or has that consideration essentially
stopped because of the litigation?
It is being addressed.
It is in the
FDIS, but there is very little progress I think
toward resolution of the issue due to the
complexities that we talked
about.
Which is the litigation?
And current litigation , possible future
litigation and the whole legalities of the
situation.
Primarily the litigation and the legal
lssue of whether GTCC waste is covered or not by
the contract?
MS. HERRMANN
Obj ection to the extent
that it mischaracterizes his
testimony.
Is that what you are referring to?
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And also covered by the And also covered by the
Act.
Act, but that'
what you are referring to when you talk about
complexi ties?
Those are the
complexities, yes.
complexities.
Those are the complexities?
Those are the major
Are there any others that have led it
to be very difficult to address the matter at this
time?
I haven
I t thought
about
it.
m sure
there are others.
The state of Nevada comes to
mind.
Q.
But the major ones are this litigation
and the legal question about whether GTCC waste lS
covered or not by the contract?
And also if we are
authorized to dispose of
if we are
authorized under law,
waste.
clearly, to dispose of highly radioactive
I can argue that greater than Class C
lS low- level waste and not high- level waste and
23 That I s a complicated matter that lS currently 24 being litigated t being litigated
, and if it wasn
therefore we are not authorized to dispose of
it.
there would be debate amongst lawyers and
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1 ( politicians if we are authorized to dispose of it
I or not.
Q.
I understand your testimony to be that
absent litigation over the question of whether GTCC should or should not be disposed of in the
repository, absent that litigation, RW would be more actively and with less difficulty considering
that matter; is that right?
MS. HERRMANN
Obj ection to the extent
it mischaracterizes his testimony.
We might have.
Specula t ion.
Okay, then there must be some other
factor other than the litigation that is
inhibiting the act of consideration, and I would
like to know what that factor
is.
The authorization question, are we
authorized under the law to dispose of what is
essentially low- level waste in a high- level waste
repository.
That will be a question that will be
very likely litigated independent of the current
litigation.
Okay.
That I
your Vlew.
Why do you
Yes.
Why do you
think that?
think that there is some question about whether or
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not GTCC is covered by the contract that is not
going to be resolved in this
I mean your
distinction is between the statute and the
contract; is that what you
I re saying?
just a contract issue
Yes.
It I S not
that is at issue here, it is also are we
authorized to dispose of low- level waste in the
high- level
waste repository.
Assume that that question is exactly
the same question that is being litigated in this
case.
Just assume
that.
You don I
t have to
agree with it,
just assume
it.
Okay?
Go ahead.
Then is litigation over t at questlon
combined question, 11 m to assume they are -- 11
telling you to assume they are the same
thing.
that the factor that is inhibiting and making more
difficult RWI s consideration
MS. HERRMANN
of whether or not to
put GTCC waste into the repository?
Speculation in all
capital letters ,
I don
calls for a legal conclusion , and
assumes facts not in
evidence.
I t know.
It I S confusing
to me.
Okay.
But in any event , this
25 \..litigation is having some depressive effect on
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1 ~ RW I S consideration
eighteen times.
4 ,
of the matter?
MS. HERRMANN
Asked and answered about
Yes.
MR. STOUCK:
5 T
Can you mark this for me
please.
(Barrett Deposition Exhibit
No. 82 was marked for
identification.
(Discussion off the record.
BY MR. STOUCK:
You have been handed a document that is
marked Exhibit Number 82 , Mr. Barrett.
This is a
printout from an electronic database of a
publication ,
at least a portion of the publication
entitled Nuclear Wapte News.
The date is Thursday
March 14, 2002.
Do you see that?
I see it.
Do you know what that publication
I don
is?
I t know.
You don I
Okay.
is that because
t know?
If you read
it,
is that because if you read it
you don I t
don I t
read it in this electronic format?
You
recogni ze it?
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beglnning January 31 , 1998 , DOE could have readily
developed a transportation cask fleet in time to
commence that level of acceptance at that time?
MS. HERRMANN
Obj ection.
Speculation.
We talked about this to some extent
earlier today.
And this lS starting at what time?
You
said the early 1990s.
There is no time frame to this
question.
DOE could have developed, could have
deployed a transportation cask suitable to the
task to the extent that task - not already available.
so, yes.
that casks were
That you had at least eight years or
16 r
And would you also agree that
there was adequate time prior to
there lS
well,
adequate time from the enactment of the statute ln
1983 to the planned January 1998 acceptance
commencement date for DOE to have developed a
transportation cask or casks for nonstand~rd
fuel,
failed fuel and GTCC wastes, obtained the necessary
licenses from the NRC and procured enough such
casks in time to accept these materials commencing
in January of 1998?
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MS. HERRMANN
Obj ection.
Vague.
Speculation.
That
Okay.
that
could have been
have been done.
done?
could
technically
Now
could have been done.
you again
some of these things
I know we touched on earlier
, I I m just
attacking
it from a different angle
here.
You mentioned earlier today shipping
campaigns.
Do you recall that?
Yes.
Now, would you agree that there are
advantages to shipping campaigns versus moving
over only a small number of assemblies at a
time?
Yes.
Would you
agree
that one of
the
important advantages
be realized?
MS. HERRMANN
shipping campaigns
that
efficiencies in transportation operations tend to
Obj ection.
Vague.
Yes.
Okay, and would you agree that
repetitive operations such as cask
handling,
loading, decontamination, receipt and turnaround
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are all more efficiently accomplished per cycle
a campalgn versus individual cask transport?
MS. HERRMANN
Obj ection.
Vague,
compound.
Yes. Okay.
Good.
Now, also earlier today I believe you testified that you thought it was possible
looked at I think it was Page 8 from one of the
ACRs which had the oldest fuel first queue, if you
will.
Do you recall that?
Yes.
And the question
was, do you think it I S
possible that when DOE commences fuel acceptance
in 2010 or some other time that that queue, with
minor variations that we put to one side for
purposes of the earlier question and I will put
aside here, did you think it was possible that
that queue would be the actual sequence of pickup
of spent fuel.
Yes.
Do you recall that?
And you said you thought that was
possible?
It was possible.
Unlikely.
Unlikely.
That would be my next
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question.
We are back to that now.
Now , would you agree that an acceptance
sequence that strictly followed the OFF
queue, if
you will
- - do you
Yes.
understand that reference?
would be economically inefficient?
MS. HERRMANN
Obj ection.
Vague.
Not as economical nor efficient as
other alignments might
be.
Okay.
It would be relatively
economical and efficient, relative to some other
alignments.
Yes.
an you t ink of any -- do you know of
any - - would there be some alignments that might
be even less economically efficient than the OFF
queue?
Well , I suppose you could make them less efficient. You could spread them out.
Everybody has a right to go smaller amounts or
something like that
, but it'
s just speculative.
Do you think it would make any economic
sense to follow that queue for the actual sequence
of pickup?
MS. HERRMANN
Obj ection.
Vague.
1111 14th
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The one that is in that table?
Yes.
Do I think it would -- what is the
question?
Would it be economically
sensible.
I mean, it
Yes , it could be sensible.
is not desirable, but, all things
considered, if
there is a strict adherence to certain
interpretations of the contract, you could do
it.
Okay.
Your answer is it would be
sensible, because it might be required by the
contract?
Yes.
But that I s not - economical sense.
that
I s different from
It would be economically
relatively inefficient you already testified?
could be
would be would be
inefficient. inefficient? inefficient.
ve in the
I think much earlier today we looked at
the mission plan and there was an obj ecti
mission plan to conduct the program in a
cost-effective manner; do you recall
that?
ves
Yes.
And that is still one of the obj ecti
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of the program?
Yes.
What is your understanding of the
relationship between the obj ecti
ve of economic
efficiency and the fuel cost recovery nature of
the contract?
MS. HERRMANN
Obj ection.
Calls for a
legal conclusion.
I believe it is the f~deral
government' s responsibility to prepare a
cost-effective system to minimize the costs on the
waste generators for societal
good.
do you
Is that related to the
understand the term fuel cost recovery?
MS. HERRMANN
Obj ection.
Calls for a
legal conclusion.
I believe I
do.
the costs incurred
What is your understanding?
That the cost for
by this program are fully paid for by the waste
generators, in this case the utility contract
holders and the defense acti vi ties Department of Energy.
testified was
of the
And is that related to what you just
I think you just testified was
1111
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Page 238
Page 240
Right. It' s moved now. All right. MR. STOUCK; Can you mark this one please , Number 92. (Barrett Deposition Exhibit No. 92 was marked for identification.) BY MR. STOUCK; Okay. This is a one- pager , Mr. Barrett. It has been marked Exhibit 92. It looks like a Memorandum of Agreement. It says , Subject; Multipurpose Canister Program , date April 30 , 1996 Bates number HQR- 045- 26 I 2. It has got your signature on it, and a Ms. Jill Lyte? Correct. Do you recall this document? Vaguely. Okay, what is it? And please review it before you answer. This was when we -- we had a very bad budget year in FY96 , and we were in the midst of finishing the Westinghouse design for the
multipurpose canister. And we wanted to finish
the instanl deposition ceased,
ness
1'-"
My Commission Expires:
Pat
L. Austin
Notary Public. DIstrict of Columbia My Commission Expli'eS 05- 14-2006
the design and complete the design before the design team disbanded to allow it to continue to
Page 239
Page 241
be of some use in the industry.
We asked the Office of Environmental
UNITED STATES OF AMERICA)
STATE OF MARYLAND
, CAPPY HALLOCK , the reporter before whom the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was sworn by me; that said deposition is a true record of the testimony given by said witness.
Management to try to support us with that and they agreed to do so , and this was the agreement that they provided a million dollars to us to help us finish that design. Why would they do that? MS. HERRMANN: Objection. Speculation. So they could use the technology and storage that they have. They have storage needs and that technology would be helpful to them as well. What are their storage needs? They store commercial fuel at Idaho as well as West Valley, New York and also DOE fuel in the end reactor. And the technology being developed in
the MPC program could be useful to EM in
I further certify that I am neither
counsel for , related to. nor employed by any of
the parties to the action In which tbis deposition was taken; and furtherthat I am not a relative or employee of any attorney or counsel employed by
the parties hereto , or financially. or otherwise
interested in the outcome of this action.
connection with its responsibility for the storage ofthat fuel you just mentioned? Correct. Okay. MR. STOUCK; Let' s quit for the day. (Discussion off the record. (Thereupon , at 5;40 p. , the taking of
CappyHallock , RPR , CRR
My Commission expires January I , 2005
61 (Pages 238 to 241)
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Filed 06/28/2004 Page 21 of 21
Case 1:98-cv-00126-JFM
Document 833-10
ERRJ.... A SHEET FOR THE TRANSCRIPl
0F:
Notice Date: May 16 , 2002 Case Name: Yankee Atomic VS. United States " Case Number: 98- 126C- 987 4C )/0 May 15 , 2002- .!J 2..Dep. Date: Deponent: Lake Barrett (cont) Washington DC
Place:
Ref. No. : 4269-
CORRECTIONS:
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