Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 846-6
Filed 07/14/2004
Page 1 of 29
June 14
2002
Washington , D.
Page 416
would be sound policy or desirable to leave
Greater- Than- Class
been removed?
C waste at the site of
decommissioned reactors after the spent fuel has
MS. HERRMANN
Objection, vague as to
sound policy and desirable.
THE WITNESS:
I do not remember any such
conversation.
BY MR. SKALABAN
From a transportation perspective, prior
to 1998, did the technology exist to transport
nuclear utility activated metal for storage or
disposal?
That I S not my area of expertise, but I
believe it
did.
C waste or material comparable
Has the Government ever moved either
Greater- Than- Class Greater- Than- Class
prior to 1998?
under a DOE or Defense classification system of
C waste, has it ever moved it
MS. HERRMANN
Obj ection, foundation,
speculation, vague.
THE WITNESS:
BY MR. SKALABAN
Yes.
What do you think the effect of the
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Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 846-6
Washington , D.
Filed 07/14/2004
Page 2 of 29
June 14
2002
Page 444
Policy Act, and I' ve
not -- I don
t believe I'
read enough of the Nuclear Waste Policy Act to be able to imply something from the context of the
Act.
m not
- - I'
ve not looked at that before, so
I do not know.
BY MR. SKALABAN:
Is that a concept that you
I re familiar
with at all, any awareness of the permanent
isolation is the equivalent of deep geologic
disposal?
MS. HERRMANN
Obj ection.
It assumes
facts not in evidence.
It calls for a legal
conclusion.
THE WITNESS:
I don't believe I'
ve ever
tried to juxtapose those two in this manner
but I assume I' ve
--
they mean the same
before, thing.
That would be my assumption all along is that those
two would have been synonomous.
BY MR. SKALABAN:
Just as a general understanding as
working in the nuclear material field and
as someone that works in the industry and works at
DOE, your general understanding of that permanent
isolation would be the equivalent to deep geologic
disposal?
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Robert L. Campbell
Document 846-6
Washington, D.
Filed 07/14/2004
Page 3 of 29
June 14
2002
Page 445
MS. HERRMANN:
Objection, calls for a
conclusion.
THE WITNESS:
BY MR. SKALABAN
Yes.
In the second bullet point, it says
numerous provisions in the NWPA show that the term
high- level
radioactive waste is not limited to
DOE- generated weapons-related waste.
Do you see that?
Yes.
Do you agree with that statement?
MS. HERRMANN
Objection, calls for a
legal conclusion.
THE WITNESS:
Again, I I ve not
read the
Nuclear Waste Policy Act in its entire, especially
the sections on high- level radioactive waste.
But
my assumption is is that it was not limited to
DOE- generated weapons-related waste.
It was
broader than that.
BY MR. SKALABAN:
Is that assumption just based on kind of
a working knowledge of the law from having worked
at DOE and in the area of the industry?
Yes.
What about the next statement, it was
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'-"
,/
Case 1:98-cv-00126-JFM Document 846-6 , D.Filed 07/14/2004 Washington Page 4 of 29
Page 454
(Whereupon, at 5:05 p. m., the taking of
the instant deposition adjourned.
WIld#
Signature of the Witness
TO before me this
, 20 0,Z..
day of
NOTARY PUBIC
My Commission Expires:
l?~
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 846-6 Filed 07/14/2004 ER. TA SHEET FOR THE TRANSCRII. OF:
Notice Date: June 17 , 2002 Case Name: Yankee Atomic VS. United States Case Number: 98- 126C- 9874C Dep. Date: June 14 , 2002 Deponent: Robert Campbell (continued) Washington DC 4269-47 Ref. No.
Page 5 of 29
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Case 1:98-cv-00126-JFM
Robert Allen Campbell
Document 846-6
Washington, D.
Filed 07/14/2004
Page 6 of 29
January 29 , 2003
Page 455
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC
COMPANY
et al., Plaintiffs,
Case Nos.
THE UNITED STATES,
98- 126C, 98- 154C,
98-474C
Defendant.
Washington ,
D. C.
Wednesday, January 29, 2003
Continued deposition of ROBERT ALLEN
CAMPBELL, a witness herein , called for examination by
counsel for Plaintiffs Yankee Atomic, Maine Yankee
and Connecticut Yankee, in the above- entitled matter
pursuant to notice, the witness being duly sworn by
MARY GRACE CASTLEBERRY , a Notary ~ublic in and for
the District of Columbia, taken at the offices of
Spriggs & Hollingsworth , 1350 I Street, N.
W.
Washington, D. C., at 9:30 a. m., Wednesday, January
29, 2003, and the proceedings being taken down by Stenotype by MARY GRACE CASTLEBERRY , RPR , and
transcribed under her direction.
IIII
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Robert Allen Campbell
Document 846-6
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Filed 07/14/2004
Page 7 of 29
January 29 , 2003
Page 465
Are you still spending about 50 percent of
your time on GTCC matters?
Yes.
Who else is currently working with you on
GTCC- related issues?
Working with me?
one.
Is anyone supporting your work on GTCC?
Personnel.
m looking for names.
Are you asking for something different
than when we went through this before?
The current status, what the current
status is, who is working on GTCC issues in addition
to yourself at the Department of Energy at this time? For sealed sources and the recovery effort in the Department of Energy, it is Joel Grimm at the
Albuquerque office.
Other than that, other than our
management in terms of how we work on
isn I t
anything, there
anyone else who works for DOE.
Are there any contractors who are doing
work on GTCC waste for DOE at the present time?
Yes.
And who are
they, sir?
program.
The sealed source recovery at Los Alamos.
There are a number of employees in that
Who are the contractors?
What are the
_II
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Robert Allen Campbell
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Page 8 of 29
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paragraph.
All right.
Are there any efforts within DOE to
develop any kind of an intermediate disposal capacity
for GTCC waste?
And when I say intermediate disposal
capaci ty, I mean something less than geologic
disposal.
MS. HERRMANN
Obj ection, foundation,
speculation.
THE WITNESS:
I don
I t
know.
BY MR. SKALABAN:
To your knowledge, no?
MS. HERRMANN
Same objections.
THE WITNESS:
I don t know.
BY MR. SKALABAN
Has DOE ever made any proposals to NRC to
dispose of GTCC waste in a facility other than
geologic disposal?
MS. HERRMANN
Objection, foundation
speculation.
THE WITNESS:
I don
I t know.
proposals,
BY MR. SKALABAN
You are not aware of any such
is that correct?
MS. HERRMANN:
Asked and answered
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Robert Allen Campbell
Document 846-6
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Page 9 of 29
January 29 , 2003
Washington , Do
foundation, speculation.
THE WITNESS:
I I m not aware of
any.
(Campbell Exhibit No. 12 was
marked for identification.
BY MR. SKALABAN
In particular, if I can call your
attention
to the
first
paragraph.
All right.
What is your
the utility- generated
understanding
the extent
component waste
nonfuel- bearing
will be accepted by RW as part of the standard
contract?
MS. HERRMANN:
Objection, foundation,
Could you repeat the
speculation, calls for a legal conclusion.
THE WITNESS:
question?
MR. SKALABAN
Can you read that back?
THE REPORTER:
Question:
Wha t
is your
understanding of the extent the utility- generated
nonfuel- bearing
component waste will be accepted by
RW as part of the standard contract?"
BY MR. SKALABAN:
What is your understanding of the extent
that RW will accept greater than Class C waste that
are nonfuel- bearing components under the DOE spent
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Page 10 of 29
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Page 537
MS. HERRMANN
Obj ection, speculation.
I don
I t
THE WITNESS:
know.
BY MR. SKALABAN:
Did you ever talk about that subject with
him , other than what I s reflected here in this memo,
this note?
I may have.
I don't remember.
Do you ever recall Mr. Huizenga expressing
to you that it was DOE
I s plan to leave GTCC at
utilities beyond the date by which DOE begins to
accept spent fuel?
MS. HERRMANN
Obj ection, foundation.
THE WITNESS:
No.
BY MR. SKALABAN:
Has anyone -- in all of your time at DOE
has anyone ever expressed to you that DOE plans to
leave GTCC at utilities beyond the date by which DOE
begins to accept spent fuel?
MS. HERRMANN:
THE WITNESS:
Obj ection , foundation.
Not that I
recall.
MR. SKALABAN:
Let I S go off the record.
(Discussion off the record.
in the
(Whereupon, at 12 :25 p. m., the deposition above-entitled matter was recessed, to
reconvene at
1: 25 p. m., this
same day.
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Robert Allen Campbell
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THE REPORTER:
Question:
Have you ever
involved in any presentations to the NRC, either
giving them yourself or assisting in the preparation
of them , of any presentations to the Advisory
Committee on Nuclear Waste?"
THE WITNESS:
Yes.
BY MR. SKALABAN
Can you tell me about that?
I was invited to give a presentation to
the Advisory Committee on Nuclear Waste.
I prepared
a presentation and then my presentation was canceled
so I never gave
it.
who invited you
And how were you invited?
to give that presentation?
As I remember, Jim Kennedy from the NRC
called me and asked me to do
And when was this?
that.
To the best of my memory, it was sometime
in the first half of
2001.
m not positive , though.
When was the meeting of the Advisory
Committee on Nuclear Waste?
I don
When was that scheduled?
I t know.
Did you actually prepare your
presentation?
Yes.
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Page 545
When was it canceled?
Canceled right
before you gave it or was scheduled to give it?
Let
me ask you thi s
the presentation?
When were you scheduled to provide
I do not remember the exact
date.
Wha t
Okay.
Well , ballpark the date.
you think, in terms of the ballpark timing?
I think it was the first part of
2001.
It
Maybe it was the first part of
remember at this point exactly.
2002.
I don
Was it the summer?
summer of 2002?
MS. HERRMANN
Was it this year
Objection, asked and
answered.
THE WITNESS:
I just don 't remember.
sorry.
BY MR. SKALABAN
What happened to your presentation?
MS. HERRMANN
Obj ection , vague.
THE WITNESS:
m not sure I know what you
mean.
BY MR. SKALABAN
Did you prepare slides?
Yes.
Did you prepare any other material besides
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Page 546
slides?
No, I don t believe
so.
Now, the slides you prepared, did you
provide them to counsel here to give to us in
discovery?
I made them available for
But I did not give them specifically
discovery, yes. to counsel here.
when you said make them available for
discovery, you turned them over to someone who was
working on - -
or pointed it out to someone who was
working on collecting documents?
Yes.
Now, what were you planning to communicate
to the Advisory Committee on Nuclear Waste in your
presentation?
what DOE
what were the major themes?
The presentation was going to center on
I s plans were for greater than Class C at
that time.
And it I S your testimony
if that' s 2001 or 2002?
you don
I t remember
MS. HERRMANN:
THE WITNESS:
Asked and answered.
That'
s correct.
BY MR. SKALABAN
And what were the plans
- - what were
DOE'
plans that you were planning to communicate to the
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not in evidence.
THE WITNESS:
I believe it was Suzanne
Rudzinski.
BY MR. SKALABAN:
Was the reason this presentation to the
Advisory Committee on Nuclear Waste was canceled
, because of this litigation?
MS. HERRMANN
Obj ection, foundation
speculation.
THE WITNESS:
I don't know.
BY MR. SKALABAN
Did Ms. Rudzinski give you any indication
of that?
Yes.
What did she tell you?
Her discussion was with
MS. HERRMANN
counsel.
To the extent you have to
reveal communications with counsel , I instruct you
not to answer.
THE WITNESS:
I don't have an answer,
then.
BY MR. SKALABAN
Okay, Mr. Campbell.
Were you told not to
give a presentation to the nuclear regulatory
Advisory Committee on Nuclear Waste regarding DOE I
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Robert Allen Campbell.
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Page 550
disposal of GTCC waste because of this litigation?
MS. HERRMANN:
To the extent that question
requires you to reveal communications with counsel
,I
instruct you not to
that doesn
answer.
If you have an answer
I t implicate
those communications, you can
go ahead and answer.
BY MR. SKALABAN
m not asking for any specific legal
advice.
m asking for a
fact.
I want you to answer
my question, Mr.
Campbell.
Could you read the question back?
THE REPORTER:
Question:
Were you told
not to give a presentation to the nuclear
regulatory'
s Advisory Committee on Nuclear Waste
regarding DOE' s disposal of GTCC waste because of
this litigation?"
MS. HERRMANN:
Before you answer, if he
was told to or told not to or told anything of the
kind by an attorney, I am instructing him not to
answer that question.
BY MR. SKALABAN:
Go ahead and answer my question,
Mr. Campbell.
MS. HERRMANN
With my instruction in
mind.
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Robert Allen Campbell
Document 846-6
Washington, D.
Filed 07/14/2004
Page 16 of 29
January 29, 2003
Page 551
BY MR. SKALABAN:
I want the answer , Mr. Campbell , not a
qualification.
MS. HERRMANN
You don I
t
get to give him
I do.
permission to answer the question.
not going to answer at
MR. SKALABAN
And he I s
going to answer with my instruction in mind or he'
all.
m entitled an answer to
my question unless you re instructing him not to
answer.
MS. HERRMANN
m instructing him not to
reveal any communications that came from an
attorney.
you.
If he' s got another answer, he can give it to
That I s
fine.
THE WITNESS:
Could you read back the
question one more time, please?
THE REPORTER:
Question:
Were you told
not to give a presentation to the nuclear
regulatory
s Advisory Committee on Nuclear Waste
regarding DOE' s disposal of GTCC waste because of
this litigation?"
THE WITNESS:
MR. SKALABAN
Yes.
Could you read back that
question and answer?
THE REPORTER:
Question:
Were you told
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Case 1:98-cv-00126-JFM
Robert Allen Campbell
Document 846-6
Washington, D.
Filed 07/14/2004
Page 17 of 29
January 29 2003
Page 552
give a presentation to the nuclear
regulatory
s Advisory Committee on Nuclear Waste
regarding DOE
I s disposal of GTCC waste because of
this litigation?
"Answer:
Yes. "
BY MR. SKALABAN
And after that instruction , your
presentation was canceled, is that correct?
Yes.
Do you know, does DOE have any plans to
again talk to the Advisory Committee on Nuclear Waste
about GTCC waste disposal?
MS. HERRMANN
Objection, foundation,
I don
speculation.
THE WITNESS:
I t know.
BY MR. SKALABAN
You' re not aware of any?
MS. HERRMANN:
Same objection, asked and
answered.
THE WITNESS:
I I m not aware of
any,
correct.
MR. SKALABAN
Mark this as Campbell
Exhibit 22.
(Campbell Exhibit No. 22 was
marked for identification.
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that it be disposed of in a deep geologic
BY MR. SKALABAN:
repository.
I believe this -- putting aside that
opinion, what about the statement here that
says,
will likely require disposal in a deep geologic
repos i tory?
Do you see that?
Yes.
Do you think that GTCC waste will not
likely require disposal in a deep geologic repository
ultimately?
MS. HERRMANN:
Obj ection, foundation,
speculation, calls for a legal
THE WITNESS:
conclusion.
I donlt have an
Putting aside my own answer
to that question, what do I
think?
answer, then.
BY MR. SKALABAN:
Where do you think it' s likely that GTCC
will be required to be disposed of?
MS. HERRMANN:
Obj ection, foundation
speculation and we 'll add relevance.
THE WITNESS:
I don
I t
know.
Can we take a
break?
MR. SKALABAN:
Sure.
(Recess. )
(Campbell Exhibit No. 23 was
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Page 19 of 29
January 29 , 2003
Page 606
Since September 11th , there has been a lot
of meetings at a lot of different levels of
management above me concerning sealed sources, dirty
bombs and related issues that I I ve prepared my
management for in a variety of different ways.
Let I S 1 imi t it to nuclear - - anything
related to nuclear utility GTCC waste, GTCC waste at
commercial nuclear power plants.
Have you been
invol ved in any - - preparing your management for any meetings with NRC relating - - people higher than you
in the DOE management chain for meetings that related
to or would recover nuclear utility GTCC?
understand my question?
Do you
m trying to limit the
sealed sources and that kind of thing, put that
aside.
Other than what we ve already discussed,
m not remembering any other discussions.
MR . S KALABAN :
Let I S mark this as Exhibit
(Campbell Exhibit No. 32 was
marked for identification.
BY MR. SKALABAN:
Mr. Campbell
, I' ve
handed you Exhibit 32
Is this
which is Bates Number HQR 2510213.
teleconference call summary something you prepared?
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January 29 2003
Page 607
No.
Have you ever seen this document before?
It does not look familiar to me.
Do you see in the first sentence it makes reference to a teleconference call that was held
Thursday, June
22nd, 1999 at 11:30 a. m.
and do you
see that you are listed as one of the attendees of
the call?
Yes.
Who is MaryJane Wisenbaker?
She was a DOE headquarters Office of
Environmental Management employee.
Was she above you or below you or equal to
you in the management chain at EM?
Equal to.
And it says here , "Greg Duggan presented
an overview of the proposed strategy which will focus
in the following three areas.
Greg Duggan?
First of all, who was
Greg is a DOE Idaho employee.
And did he work on greater than Class C
waste issues?
Yes.
And was he involved in helping formulate a
proposed strategy for greater than Class C waste?
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I believe so , yes.
Now, there is a list of key points that
came from the discussion.
Three points down, it
said, "Mark Frei indicated that there is an
understanding between GC, RW and EM that GTCC waste
will go to the repository.
And do you recall, Mr. Campbell, a
teleconference where Mark Frei indicated that there
is an understanding between the Office of Civilian Radioactive Waste Management, the Office of
Environmental Management and the Office of General
Counsel that GTCC waste will go to the repository?
I recall this conference call , yes.
And you recall that being discussed?
I believe so, yes.
Do you recall Mr. Frei indicating that
there is an understanding between GC, RW and EM that
GTCC waste will go to the repository?
Yes.
And what did Mr. Frei say about that
understanding?
I don't remember specifically.
Did you have any understanding of what
this understanding entails between GC, RW and EM?
MS. HERRMANN
Objection to the
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foundation, speculation.
THE WITNESS:
No.
BY MR. SKALABAN
Now, underneath that, there is a bullet
point that says, "Options other than the repository
are considered politically undesirable in light of
overall DOE waste management objectives.
Do you see
that?
Yes.
Can you explain to me what
I s meant by
that
sentence?
MS. HERRMANN:
Obj ection , foundation,
speculation.
THE WITNESS:
No.
BY MR. SKALABAN
So participating in this conference call
it'
s not clear to you what
MS. HERRMANN
I s being referred to?
Same obj ect ions.
BY MR. SKALABAN:
Do you have any idea what' s being referred
to?
MS. HERRMANN:
THE WITNESS:
Same objections.
I can't explain this
sentence on this call summary.
In participating on
, the conference call , I do remember Mr. Frei
'C
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Page 610
discussing politics associated with
BY MR. SKALABAN:
this.
What did he say about it?
In reference to the second bullet on this
page where it says, "Mark specifically noted that
borehole disposal of GTCC waste in Nevada was not an
option
" was his main concern relating to politics.
So his concern was that politically,
borehole disposal of GTCC waste in Nevada was not an
option?
MS. HERRMANN:
Objection to the extent it
mischaracterizes his testimony,
THE WITNESS:
of 1999, yes.
BY MR. SKALABAN
foundation.
That was his opinion in June
Now, did he say anything more about this
understanding between GC, RW and EM, that GTCC waste
will go to the repository?
Did he give any more
information about it other than what
I s indicated
here, that there is that understanding?
My memory of this is that he directed
Mr. Duggan to not pursue any other disposal options
\ other than that at that
time.
did he
Did he say why, other than this
say the reason was because there was this
1I1I
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Robert Allen Campbell
"""'"
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Page 24 of 29
January 29 , 2003
Page 615
tern 1.
And the longer term disposal option would
be putting it in the repository?
MS. HERRMANN
Obj ection, foundation.
My memory is that Mr. Duggan
THE WITNESS:
presented a broader approach than that and that
according to the paper , Mr. Frei said no and left the
instruction that the only thing that would be pursued
at that point was the repository.
BY MR. SKALABAN
Has Mr. Frei provided any additional
guidance or any further guidance since that time
about what should be pursued?
Not that I' m aware of.
MR. SKALABAN
Let'
s go off the record
here.
(Discussion off the record.
(Robert Shapiro enters deposition room.
(Whereupon , a conference call was
commenced wi th the court.
BY MR. SKALABAN
Mr. Campbell, we were talking about the
presentation to the Advisory Committee on Nuclear
Waste.
Do you still have the presentation you
that was
prepared, the one that was canceled for
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Document 846-6
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Page 25 of 29
January 29, 2003
Page 634
disposal or handling of GTCC waste?
MS. HERRMANN
Obj ection, foundation.
My management.
THE WITNESS:
BY MR. SKALABAN
And who is that?
I think it would depend on the specific
aspects of the policy.
Who currently would you say is making
the storage or disposal or handling of GTCC
MS. HERRMANN
Same obj ection.
Jessie Roberson and higher
THE WITNESS:
than her in the Department of Energy.
BY MR. SKALABAN:
If there are questions that arise
regarding greater than Class C waste wi thin the
Department of Energy, are you one of the lead
contacts within DOE for answering those questions?
MS. HERRMANN
Obj ection, speculation,
vague.
THE WITNESS:
I don
I t know.
BY MR. SKALABAN
Is there anyone who spends more time
within DOE than yourself on greater than Class C
waste issues?
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January 29 2003
Page 639
In that
role
the whole
time?
No.
long has she been revJ.ewing document s on GTCC waste?
How
the role
There was a
, I I m sorry,
supervisor.
in that role?
period of six months where she was not my immediate
She was Patty Bubar'
s technical
assistant, but she was probably still in the role of
reviewing those same documents.
Since 1999?
Yes.
And how about Patty Bubar? She was not in my management chain in late
1999.
don I t
She came into that role a little
remember exactly when.
later.
How about Donna Atkins.
What does she
work on in the greater than Class C waste area?
She' s the secretary in the office I work
in, so any document
worked on by her.
I' ve ever
produced has been
Now, although you' ve
testified that you
don't make policy decisions on the storage of greater
than Class C waste, it is true, is it not , that you
do a substantial amount of work for those policy
makers?
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January 29 , 2003
Page 640
MS. HERRMANN
Objection ,
vague.
BY MR. SKALABAN
Relating to greater than Class C waste?
MS. HERRMANN
Objection ,
Yes.
vague.
THE WITNESS:
BY MR. SKALABAN
And that from time to time you make
recommendations to
them, isn 't
that correct , on
policy for greater than Class C waste?
Yes.
I think we
I re done.
(Whereupon , at 6:00 p. m., the taking of
the instant deposition ceased.
Signature of the Witness
SUBSCRIBED AND SWORN to before me this
day of
Notary Public
My Commission Expires:
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Document 846-6
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Page 28 of 29
January 29, 2003
Washington
Page 640
MS. HERRMANN:
BY MR. SKALABAN
Obj ection , vague.
Relating to greater than Class C waste?
MS. HERRMANN
Objection, vague.
THE WITNESS:
Yes.
BY MR. SKALABAN:
And that from time to time you make
recommendations to them , isn
I t that
correct , on
policy for greater than Class C waste?
Yes.
I think we' re done.
(Whereupon ,
at 6:
00 p. m., the taking of
the instant deposition ceased.
flu
Signature of the Witness SUBSCRIBED AND SWORN to before me this
c7(fJJ
day of
Notary Public
My Commission Expires:
~11~
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Page 29 of 29
ERRATA SHEET FOR THE TRANSCRIPT OF:
Notice Date: January 30, 2003 Case Name: Yankee Atomic VS. United States Case Number: 98- 126C- 9874C Dep. Date: January 29 , 2003 Deponent: Robert Campbell (continued) Washington DC
Place:
Ref. No. :
4269CORRECTIONS:
Page
Line
Now Reads
Should Read
Reasons Therefore
/lLM&://
ZCfJ
SIgna re of Deponent
c:;
Date of SiGnature