Free Response to Motion - District Court of Federal Claims - federal

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Case 1:98-cv-00126-JFM Document 792-9

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1962....
General ElectdcCo. General Manager, Waste Management Services,

~88

Responsible for Vallecitos Nuclear Laboratory, including operati' on, ,several test and isotopeproc:luction reactors ;
s~ipmerit of

irradiated leaa test assemblies from

.comniercial operating re~otors '

for destructive tests and examinations in hot cells.

Responsi~le for ' operation
Illinois, including
transport

of

Morris fuel s torage facility at Morris;
of

spent fuel fr~mcommercial

operating reactors for storage at MOrris using the 'IF-300

rail

casks.
Design/development and testing of

low- level waste volume reduction,

systems, including dry compactors and liquid waste solidification

, systems utilizing azeotropic distillation processes.
Manager, Field Services
i "

Commercial reactor original equipment installation, startup testing

i.-'

Site supervision for all GE~BWR nuclear steam systems operations.

Reactor ou~age planning, fuel loading, repair and maintenance
implementation at all , GE-BWR operating commercial plants.
Design, testing and installation of

reactor upgrade and retrofit

systems in compliance with NRC requirements and quality assurance

programs
'Manager, Engineering Consulting Services
Design/procurement/installation of

mechanIcal, electrical and

hydraulic systems to improve nuclear plant operating performance,
Design a~d operation of

remote, ultrasonic inspectiqn devices for

reactor pressure vessels and piping using state-of-the-art robotics
and computerized data recording sys

~s ,

Operated a design/procurement/warehousing s~stem for pooling
inventory of

large, long- lead procurement equipment for all
of

operating GE-BWR plants, including adapter kits for use

equipment

in multiple plants.

00094

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Document 792-9

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i~i

Manager, Ucenslng and Safety

NRC li.censing responsibility~or all GE-BWR plants, including

construction pe~ts ,and
thermal h~'drau1ic design.

operating

lid~es.

Prepared generic Topical Reports ' for

NRC approval of nuclear,

structural analytical '

techniques used iri plant

Operated the BWR owners group of utilities which owned/operated all
, U. s. BWRplants, designing and implementing all NRC g~neric

requirements resulting from the TN! post~a6cident analysis.

Education
Newark (New Jersey) College of Engineering. , B. S., Mechanical
Engineering, 1959
't'"

New York ,

University/U.S.

Air Force. Graduate Meteor;,logical Program,

1960

00095

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Case 1:98-cv-00126-JFM

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Document 792-9

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Memberships
Americ
Institute an Nucl~ar

Society
SPACGrOup

for JiluclearJ?ower Operation
Professional :

'Professional Certification
Register~d Engineer ,- Nuclear, State

of California

00096

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Case 1:98-cv-00126-JFM Document 792-9
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c'.
. to .

.,.d.' .'..

I. . '

Selected PubUcations and Speeches of Ivan
1. Safety Analysis

Stuart

Revisio~ ' RepOrt for theNAC Storable Transport ~ NumerouS

199()';1998 '
1990-

2. Safety

1998

Analysis Report for the NACLegal WeIght TruCk Cask, Numerous Revisions,
1-28,

, 3. Topical Safety

Analysis Report for the NAC srr

Numerous Revisions, 1990-

1992
, 4. Topical Safety Analysis

Report for theNAC srr

C-28,

N~eroU$ ReVisions~1990
Management'

5 . ' Owl

Creek Energy Project, 1998 Institute of Nuclear Materials

" Conference, Washington,

6. Universal Mu1ti~purpose Canister System,

Management Conference, Washington D.

7~ Owl Creek Energy Project. 1998Institute of Nuclear Materials Conference, Washington and D.
8. Owl Creek Energy

C. C.

1997 Institute of Nuclear Materials
Managemeil~

Project: A Solution to the Spent Fuel Temporary Storage Issue

1998 Iritemational Conference on Nuclear Engineering.
9. Owl Creek Energy

ProjeCt: A Solution to the Spent Fuel Temporary Storage Issue, RadwasteMagazine July 1998. .

10. Owl Creek Energy Project: A Solution to the Spent Fuel Temporary Storage Issue, 1998 ANS .Utility Working Conference
11. Owl Creek Energy Project, 1999 Institute of Nuclear Materials Management Conference, Washington D.

C.

, San Francisco.

12. Owl Creek Energy Project: A Solutio:l to t~e Spent Fuel Temporary Storage Issue 1999 \Vaste Management Conference . Tucson

. AZ.

00097

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Case 1:98-cv-00126-JFM Document 792-9 Filed 04/16/2004 Page 5 of 16

IN THE U. S. COURT OF FEDERAL CLAIMS

_"'.n__-

YANKEE . ATOMIC ELECTRIC CO.

\,~~'t

MAINE YANKE

ATO~.1IC POWER CO.,

CONNECTICUT YANKEE ATOMIC POWE
CO. ,
, Plaintiffs:

c,~~

o:.\\((.\~~

: No. 98- 126C

,8

vs'
UNITED STATES OF AMERICA.

98-474C

98- 1S4C

Defendant.

Washington, D. C .
Tuesday, August 26, 2003

Deposition of:
DR. JOHN BARTLETT

called for examination by counsel for the
defendant, pursuant to notice and agreement

commencing at

9: 30 a. m.,

at Department of Justice

1100 L Street N. W.,

before Virlana Kardash, RPR,

CSR, a Notary Public in and for the District of
Columbia, when were present ' on behalf of the
respective parties:

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Page 6 of 16

involved nuclear engineering or nuclear sciences?

Not at the

time.

What was YQur job title at Knolls
Atomic Power?
Staff engineer.

And you went there as soon as you

graduated in 1957?,

The day after'
What were your responsibilities at

Knolls?
We were working on the design of the
"'b
'.1

Navy' s first nuclear- powered surface ship, and I
was one of the design engineering

staff.

And

there were some, unique technical issues associated
with the materials that they wanted to make the

reactor system out

of.

And I was involved in
trying to weld materials

that.
before.

They were

different materials that

had never been put together

What materials were you working with?
Inconel and stainless steel.

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leave of absence from Knolls in order to get your

Ph.
Uh- huh.
And your Ph. D also came from RPI?

Uh- huh.
That was also in Chemical Engineering?

That I S right.
And did you go full-time for

your Ph.

Very full.
So you had no other jobs while you

were

t~ing

to do that?

No.

Many a long Saturday evening.

Do you recall what you worked on
you were getting your Ph.

while'

Well, my thesis was concerned with

what I s known

in' the business as simultaneous , heat
And Chemical

mass and momentum transfer.

Engineering is the only discipline that addresses

problems like

that.
When

And the application that was the b~sis for
my thesis had to do with drying a paper.
you I re

manufacturing paper, you start out with

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Page 8 of 16

this wet goop, and then it goes on a net

basically, and is dried to become

paper.

And it' s a classic problem , and you have to

drive the water out.

extracting heat, et

It you t re cetera. So simultaneously,
t s moving

it'

s a combination of all kinds of physics and

chemistry.

, It t S a common
others.
work.
Okay.

problem in that area and

But th1s was the subject of , my thesis

During you Ph. D

studies, did you

study nuclear engineering or nuclear sciences?

What happened at that time is not only

do you study it, but you teach

it.

Learn i t on~

year and teach it the next was the state of the

art at that

time.

What nuclear science or nuclear
engineering courses did you teach?

Reactor design.
thermal hydraulics

Wha t ' s known as

in other words, the issue of

how the reactor heats the

water.

Is it fair to say you were essentially

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Page 9 of 16

teaching many of the courses you had taken when
you got your Masters at RPI?

That'

s not far from the truth.

At this point did you take or teach any
classes that had to do with spent nuclear fuel?

No.
What did you do in 1962 after you got
your Ph.

I was given an opportunity to go back

to Rochester to

join, t~e faculty of the Chemical
and to teach
the nuclear

Engineering Department, where I had my
" 1

undergraduate degree ,

option at the U of
They had just started up a program under an

Atomic Energy Commission grant, and they offered
me the faculty position to teach the nuclear
courses as well as traditional chemical

engineering courses.
So did you not go back to Knolls, then?
I left Knolls as an employee in 1962

but I was

retained' there as

a consultant for all
I'd go

the time I was at Rochester, actually.

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Page 10 of 16

there in the summers occasionally during the

school year.
Starting with what you were doing at

,4

the University of Rochester, what were you

teaching specifically?
Unit operations, thermodynamics,

~dvanced , differential equations for engineers,
nuclear engineering, nuciear fuel cy~le.
Were you teaching undergraduates?

10,

Yes.
And graduates as well?

Uh- huh.
What did the nuclear fuel cycle course

involve?
The idea that you start actually with
the extraction 0f uranium, go through the reactor

design.

And at the time, of course, reprocessing

was essentially the expectation, which is very
straightforward chemical engineering.

So at the time, that was the only
possible end to the fuel cycle?

That'

s what was expected , uh- huh.

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Did you ' teach anything else while you

were at , Rochester?
It turned out that I developed
program jointly with a professor in the school of

Medicine for research in diabetes, and I had
several of my graduate students do theses on

problems in d~abetes.
And in addition, I had graduate students

doing theses on corrosion issues, what ' was

called

boundary layer theory associated with how the

water causes corrosion or deposition of corrosion

products.
So it was that kind of a

thin~.

Okay.
No.

Did you teach anything else?
Just basically the chemical

courses and the nuclear courses and then direction
, l7

of the theses.

Just so that you know, when I ask is there anything else, I don't mean to imply that

what you' ve

told me is not enough.

m simply

trying to get a complete list.

What we would do is rotate

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civilian effo~t, same sort of thing for commercial

power reactors, what was to be the application of
, 3

it.
And it h?ppened that in the -- during that

time frame, I had put in for a position as a

Fulbright professor, and then subsequently Hanford
offered me an opportunity to come : bapk
full employment.

there for

But what I did after that summer, which was
the basis, then, for the following year, is I went
, 11

back to university for a year.

When that year was
employee but
actually, in the

up, I went back to Hanford as . an
almost immediately left there

fall

to become a Fulbright professor of Nuclear

Engineering in Istanbul, Turkey.
Let me make sure I understand the time

line.

So in the

s~er of 1967, you were working

in this fellowship program at Hanford?

Uh- huh.
When you finished that fellowship
. 21

program, you went back to the University of
Rochester as a faculty member?

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Page 13 of 16

technologies for defense production operations.

And our group was involved in that kind of
. 3

development.

It I S essentially

laboratory

chemistry.
What' year would it have been,
when you left Hanford to go to Istanbul?

then,

1968, late 168.
, Q

What , did you teach in Istanbul?
Atomic physics" reactor

engineering,

reactor design.

Did you do anything else while you
taught, or was that your sole responsibility?

Well, they had , by definition , a
graduate program, but they were very impoverished 15,
with respect to being able to resource these

programs.

So rather than directing the students

in actual thesis- type work, I worked with

themih

an advisory capacity.
And it turned out that one of the major
responsibilities was to help get them into
universi'ties in the

United States.
kind of like a gUidance

So you I re

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of them were like embassy audiences, you know,
policy or government people.
some were public.
Some were technical

I went to Ankora, Izmia (ph. ) ,

Istanbul, et cetera.
, 5

This was essentially ~ mar~eting tool?

That'

s really ~hat NASA was

doing.
" And

"Space is wonderful for you" was the
look at all the side benefits.

theme.

So was your primary objective just
get people excited about the space program?

to,

To inform them, yes.
Did you do anything else while you were
in Istapbul?

No, not professionally.

And you were there for one year?

Uh- huh.
What did you do in 1969?
Came back to Hanford.

And during the

interval while I was in Istanbul, I was with
Battelle Memorial Institute, what is now Pacific
Northwest Laboratories.

During the time I was in

Istanbul, Battelle had formed a nuclear waste

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management program office.

When I came back t' o

Battelle, I was made

Manager of Systems Studies within that program

office.
m sorry. Can you give me that title

again?
System Studies.

What did that job entail?
Basically

~ing to determine

what

kind of a program made sense because everything
was just starting with respect to waste
t:::~;

management, et
, 13

cetera.

And they had no idea how

the pieces would fit together.

So what was needed at the time were the

these studies of how you could put together an
operational sys tem.

What do you mean when you say
everything was just starting?

Well , what has become the present

program, Office of , Civilian
eye at that

Radioactive Waste

Management, et cetera, was just a glimmer in the

time.
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I don

t t

know if you

t re aware, but the effort

to site a place for disposal had had some very
terrible failures up to that point.

And it was

disorganized

There was no organized effort.

was simply trying to find a place for disposal.

And no one had given any thought to anything
about how you get it there or what the , technology

would be, et cetera.

It was a siting effort

strictly.
Up until this point' , had you had any

involvement in nuclear waste disposal?
It started then in a sense because,

around that time frame, the Atomic Energy
Commission first formed the Division of Waste
Management and Transportation.

And they made

Battelle ' the contractor for that effort.
And the first job was to develop their

program plan.

And I was one of the two people

that did that, that drafted their initial program

plan for trying to, put
for getting stuff from

together a complete system

Actually, it was to ~e the reprocessing

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