Free Motion for Leave to File - District Court of Federal Claims - federal

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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Case 1:98-cv-00126-JFM
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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6
Washington , D,

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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.............

Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6

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Page 8 of 29
January 29, 2003

Washington , D.

Page 494

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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6

Filed 07/14/2004

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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6
Washington, D.

Filed 07/14/2004

Page 10 of 29
January 29 , 2003

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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6
Washington , D.

Filed 07/14/2004

Page 11 of 29
January 29 , 2003

Page 544

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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Robert Allen Campbell

Document 846-6
Washington , D.

Filed 07/14/2004

Page 12 of 29
January 29 , 2003

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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Robert Allen Campbell

Document 846-6
Washington , D.

Filed 07/14/2004

Page 13 of 29
January 29 , 2003.

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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Robert Allen Campbell
Washington , D.

Document 846-6

Filed 07/14/2004

Page 14 of 29
January 29 , 2003

Page 549

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.

Document 846-6
Washington , D.

Filed 07/14/2004

Page 15 of 29
January 29 , 2003

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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Case 1:98-cv-00126-JFM
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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6

Filed 07/14/2004

Page 18 of 29
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Washington , D,
Page 555

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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Robert Allen Campbell

Document 846-6
Washington, D.

Filed 07/14/2004

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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Robert Allen Campbell

Document 846-6
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Filed 07/14/2004

Page 20 of 29
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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Robert Allen Campbell

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Page 21 of 29
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Page 608

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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Document 846-6
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January 29 , 2003

Page 609

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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Document 846-6
Washington, D.

Filed 07/14/2004

Page 23 of 29
January 29, 2003

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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-Case 1:98-cv-00126-JFM
Robert Allen Campbell

"""'"

Document 846-6
Washington, D.

Filed 07/14/2004

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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6
Washington , D.

Filed 07/14/2004

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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Case 1:98-cv-00126-JFM
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Document 846-6
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Page 26 of 29
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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Case 1:98-cv-00126-JFM
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Document 846-6
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Filed 07/14/2004

Page 27 of 29
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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Case 1:98-cv-00126-JFM
Robert Allen Campbell

Document 846-6

Filed 07/14/2004

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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Case 1:98-cv-00126-JFM

Document 846-6

Filed 07/14/2004

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