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

Case 1:98-cv-00126-JFM

Document 846-4

Filed 07/14/2004

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EXHIBIT

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Case 1:98-cv-00126-JFM
. Robert L.

Document 846-4
Washington, D.

Filed 07/14/2004

Campbell

2002

Page 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

YANKEE ATOMIC ELECTRIC COMPANY, CONNECTICUT YANKEE ATOMIC POWER COMPANY, MAINE YANKEE ATOMIC POWER COMPANY,

CE~T~f~ED COpy
CASE NO.

vs.

Plaintiffs,
98- 474C

98- 126C 98- 154C

UNITED STATES OF AMERICA,

Defendant.
Washington, D.
Thursday, June 13, 2002
Deposition of ROBERT ALLEN CAMPBELL
a witness, called for examination by counsel for Plaintiffs in the above-entitled matter , pursuant

to notice, the witness being duly sworn , taken at
the offices of Spriggs & Hollingsworth, 1350 I
Street, N. W., Suite 1010, Washington , D. C, at 9:32

m, on Thursday, June 13, 2002, and the
proceedings being taken down by Stenotype by CINDY

L. SEBO, and transcribed under her

direction.

Alderson Reporting Company, Inc.

1111 14th Street, N. W. Suite 400 1- 800- FOR-DEPO Washington , DC 20005

~.)

Case 1:98-cv-00126-JFM
Robert L. Campbell

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Page 11

and C which can go to commercial low- level waste

disposal sites.
Class C has an upper limit, and it'

s --

it'

s in two tables in the regulation, and if you

exceed that

limit, it'
did not

s then Greater- Than- Class

And if I understand correctly, your work

with the Navy
Yes.

involve

GTCC

that correct?
Yes.
did not work

with

Greater- Than- Class

C in the Navy.

Thank you.

And then in 1992 , you joined

the Department of Energy?

Yes.
What was your position with the Department of Energy at that time?
I was a nuclear engineer program manager.

And what was the program you were

managing?
Well, basically everyone is called a
program manager. So I was dealing with what'

called off-site waste, which was anything -- any
materials or waste that was outside the Department

of Energy complex, maybe on loan to a university or to a private company, that needed to come

back, I

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Case 1:98-cv-00126-JFM
Robert L. Campbell

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worked on.

And I al so worked

on the acceptance of

Greater- Than- Class

C sealed sources.

And what branch of the Department of

Energy did you begin work at as a program manager

in '92?
The Office of Environmental Management.

And what EM number is that, that office?

They ve reorganized a couple times.
was EM32 then.
Okay.
And what was the title of that

branch of the office?

It was

that was the Office of Waste

Opera t ions.
And, in general, what were the areas of

responsibility of EM32, the Office of Waste

Operations?
That office was responsible for any waste

management activities at all DOE

sites.
I guess you

So, organizationally, your - would call it an office

EM32 is called an

office?
Yes.
So the EM32 office underneath it had
different programs?

Yes.

There were three different

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Robert L. Campbell
Washington, D.

-June 13 ,

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there was a transition from taking sealed sources to the nearest DOE site to centralizing the storage
out of Los Alamos?
MS. HERRMANN:

Obj ection, foundation

speculation.
THE WI TNES S :

When we started, we didn't
We didn t know the scope

have a program in

place.

of the program or how many requests we were going
to get from the NRC.

As we began to respond to

more requests, it was obvious that this trend was

going to continue and that we needed a more
more routine ability to accept

--a

sources.

And so the decision was made to
pick a single site that had experience in this area
and use a single location.
BY MR. SKALABAN

How many sealed sources

- - I'

m not

limiting my question to just 1992 -- from 1992
forward to the present, how many sealed sources

have been moved from the original site to a DOE

si te?
From 1992 forward, over 3,

000.

And how large are the sealed sources

mean, what' s the fit -- what' s the average kind of
physical characteristics of a sealed source?

What

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does it look like?

What' s its size?
Obj ection , vague.

MS. HERRMANN

THE WITNESS:

There'

s a wide variety.

Some are

come out of gauges and portable

equipment and they'

re very small, maybe an inch

high or even smaller, you know , maybe the size of a

pencil eraser, up to - a 12 -ounce soda can.

the sources are the size of

They' re basically radioactive material
encompassed in metal, usually double encased with welds, and, typically one of the layers is

stainless steel.
BY MR. SKALABAN

How are they -- what' s the mode of

transportation that' s

used to take the sealed

sources from a site to a DOE facility for storage?
Commercial carrier.

Is that truck?

Typically.
Do you know if there' s been

transportation of GTCC sealed sources other than by

truck?
It is

- - no, I

don

I t know.

It I

possible

that they could go by

rail.

But in most cases, we

have the owner of the source arrange for the

Alderson Reporting Company, Inc.
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shipment to us.

In the cases where we do the

shipment, it goes by truck, commercial carrier.

And with approximate -- I realize it'

approximately - -

approximately 3, 000 sealed sources

that have been moved, would that be 3,

000 separate

shipments have been made or would that be -- what'
the number of shipments that have been made of
sealed sources?
It would not be 3, 000 individual

shipments.

Some of the shipments have been 200
Some have been one.

sources in a drum.

It I s

probably been more than a

thousand, probably less

than 2, 000,

but I don't have -- I don't know the

exact answer.

Have there been any problems that you'
aware of in the approximately 1,

000 to 2, 000

shipments of GTCC sealed sources?
MS. HERRMANN

Objection, vague as to

problems.
THE WITNESS:
BY MR. SKALABAN

m not aware of

any.

Have there been any planned shipments of

GTCC sealed sources that have been stopped because
of a transportation issue?
MS. HERRMANN
Obj ection , vague.

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a shipment of GTCCs in sealed sources?
MS. HERRMANN:
THE WITNESS:
BY MR. SKALABAN

Objection, vague.

Not that I I m aware of.

In 1992, you testified you began work at
EM32 under Mr. Harmon.

How long did you work in

that position as a program manager?
m still a program manager.

Basically

the same job, but I have more responsibilities now.

But I continue to do that.
Okay.
Well, did your responsibilities
have your responsibilities changed over time?

What'

s the - -

can you let me know when the

starting in 1992 when you were program manager, one

of your responsibilities was for GTCC sealed

sources.
What has been the next substantial change
in any of your responsibilities?
When did that

occur?
I received a paygrade promotion in 1994,
and I took on additional responsibilities dealing with DOE waste management and interfacing with the
Department of the Navy' s Office of Naval Reactors.

And, in general, what did - -

your duties

and responsibilities, what were they in connection

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Robert L. Campbell

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interfacing with the Navy and your prior

responsibilities which included GTCC sealed

sources?
Nothing significant.
I mean, we'

always assigned short- term
Okay.

proj ects, but I don

believe I had a major change in

duties.

And during this period of '92 to

'95, outside of GTCC sealed sources, who was

responsible - -

who had responsibility for GTCC for

other - -

other types of GTCC waste?
MS. HERRMANN:
THE WITNESS:

Objection, foundation.
Terry Plummer.

BY MR. SKALABAN

Was there a name of Mr. Plummer' s office
that you recall?
I don

I t remember.

He was effectively in

the same organization he was before, but I don

remember what they were

called. That organization
I don't remember.

didn't last a long

time.

Now, in the ' 95 reorganization, you were
still an EM32?

No, I was now an EM35, I believe.

Okay.

Okay.

How about in 1995

forward,

when was the next time you took on a new duty or
responsibili ty or

actually, let me rephrase

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that.
From 1995 forward, when was the next time

that your responsibilities changed in any
substantial way?

In 1999, I became responsible for the
rest of the Greater- Than- Class C program.
I also

became the Department' s liaison to a group called

the conference of radiation control program

directors, and I also picked up responsibility

for - - with - -

what we call orphan waste.

They'

basically DOE waste that lack some sort

- - there I

some sort of barrier to either treatment or

disposal.

And so the work there is to figure out

how to take these waste and get them treated and
get them disposed.

Okay.

In 1999 when your duties changed

and you became responsible for the rest of the GTCC

program, was there a corresponding change in the
organizational structure that went along with that?

Yes.

Yes.
Can you

Can you tell me about that?

please tell me about that change?

Sure.

That was a rather dramatic

reorganization.

We shifted from

we shifted from

a more or less straightforward waste management

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Page 47

Okay.

So to make sure my question and

your answer is clear, I want to

ask:

To your

knowledge, all the GTCC waste that exists today is
not mixed low- level waste?
MS. HERRMANN:
THE WITNESS: Objection, vague.

m not aware of the

current chemical characterization of the GTCC waste
around the country.
BY MR. SKALABAN:
So I don

It

I don't know.

Has it ever come up in any of your

- - you

know, any of your work as the person in charge of

GTCC waste for DOE at this time, has it ever come

up that GTCC waste may be

or some GTCC waste

that I s out

there may be mixed waste?
Yes, it has.

And how did that come up?

What was the

context of that discussion or analysis?
Simply that it' s possible.

I mean, the

Department of Energy deals with mixed waste all the

time.

And so any -- any system or just in looking

at Greater- Than- Class C waste, one would need to

assume that some of it could be mixed waste as

well.
To your knowledge, are you familiar with
the term activated metal GTCC waste?

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Robert L. Campbell

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Yes.
Okay.
And can you explain for the record

what that means to you?

It is stainless steel typically that has

been in contact either with the fuel assembly or
the fuel basket in the reactor.
And it'

s--

as

metal is in close proximity to the nuclear
reaction, it becomes activated.
It becomes

radioactive.

The iron, various impurities and the

stain cobalt, things like that, become radioactive
forms of those elements, and that is basically what
is activated metal.

And due to the typical run time of a commericial nuclear power plant, it becomes highly
enough activated that it exceeds the Class C

limits.
So if we refer to nuclear utility

activated metal GTCC in this deposition, we will be
referring to that description you just gave me

that fair?
Yes.
To your understanding, is any of the

nuclear - -

and I do want to make sure

actually,

let me back up one

second.

Nuclear utilities are the source of the

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Page 52

Who took over for Mr. Rhoderick?
Karen Guevara.

And can you spell that last name for me,

please?
G-u-e- v-a-r-a.
And when did Ms. Guevara take over?

This was a year and a half ago

roughly.

So approximately the beginning of 2001?

Yes.
And she took over from Mr. Rhoderick?

Yes.
What happened to Mr. Rhoderick, did he
retire or move on?

No.

He was promoted to the Richland

he was the office director for the Richland

office,

which would be in the Office of Project Completion.

So prior to 1999, when your program
manager responsibilities included all of GTCC
waste, did you work on any other GTCC waste
projects other than sealed sources prior to 1999?

Yes.
Can you tell me about that?

For a brief time period in about 1997

they reorganized responsibilities for

Greater- Than- Class

C.

And -- and in the process of

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doing that, they had decided that they wanted it
all under one person.

They had put it under me.

We began

- - and then a

month or so later, they

changed their minds and it went back to the way it

was.
Okay.
And when did that occur?

I believe it was

1997.

1997.

And that lasted, I believe you

said, about a month?

About a month, maybe two

months.

So for that one month or two months in
1997, you had full responsibility for all GTCC

waste?
Yes.
And then after that time period, there
was another reorganization and you went back to

just working on sealed sources, the sealed source
end of GTCC waste?

Yes.
Okay.
And then in 1999, there was the

reorganization, you became proj ect manager, and

that included all your responsibilities

- - and you

had full responsibility for all GTCC waste?

Yes.
Okay.
In 1990
in the 1999 period

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forward, who do you

who have you worked

GTCC waste issues within the Department of Energy
or its contractors?

Out at the Idaho site, contractors Bob Hansson, Phil Wheatley and the Department of

Energy; but at the Idaho site, Mark Arenaze.

And

then I I ve worked

with my management.

ve also worked with Lee Lenard at the

Los Alamos site; Joel Grimm, who is DOE

Albuquerque; and Jim Orbin, who is DOE Those are the main people I worked
m sorry.

Albuquerque.

with.
s

What was Mr. Orbin '

first

name?

Jim.
Jim.
No.
And what part of DOE does Mr. Grimm
Are they part of EM?

and Mr. Orbin work for?

Our field -- well, our field sites

don't really fall into those categories

exactly.

But they do work on environmental management

programs.
Mr. Orbin is the waste management division director for the Albuquerque operations

office, and Joel Grimm is a program manager who

works for him in that

division.

And so Mark Arenaze is similar to

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stopping that.
to the program.

I do not know what

I I m not part

of the discussions on

- - on what I s going

to happen

So I do not know.

BY MR. SKALABAN:

Okay.

So you haven't been involved in
let me ask this question:

any conversation - -

Have

you been involved in any questions where it was

discussed what would happen to the GTCC program in
view of the top- to- bottom review?

Yes.
And can you tell me about those
conversations, what was discussed?

There was at least one conversation where

the -- it was reported to me that management had
discussed the idea of transferring the

Greater- Than- Class

C program to the Office of

Civilian Radioactive Waste Management and the

sealed source program to the National Nuclear
Security Administration, which is another part of
DOE.

And who was involved in this conversation

besides yourself?

Susan Rudzinski.
office director.

She' s the current EM22

Was there anyone else involved in that

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conversation?
I do not believe

so.

Okay.

Did she give you any indication
well, first of all, do you have

where management - an understanding - -

when Ms. Rudzinski told you

that management was considering transferring GTCC

responsibilities to OCRWM, did you have any
responsibility of what management she was referring
to, who the managers were that were talking about

this?
MS. HERRMANN:
THE WITNESS:

Obj ection, speculation.

Yes.

Jessie Roberson.

would be her decision.

So that'

s who she was

referring to.
BY MR. SKALABAN:

The

assistant secretary?

Yes.
Did she give any indication of whether
Jessie Roberson was talking to OCRWM about
this matter?

- - about
that

Yes.

I believe she said that the - -

she had met with the director of OCRWM.

that your

So that Ms. -- I just want to make testimony is clear. Ms. Rudzinski

sure

indicated to you that Ms. Roberson had talked to

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the director of OCRWM about the potential transfer

of GTCC responsibilities to them, to OCRWM?

Yes.

And when was - - when

was your

conversation with Ms. Lazinski about this possible
transfer of responsibility?
Within the last two months.

It'
that?

s Rudzinski.

Do you want me to spell

Yes.

Would you please?

d-z- i-n-sDid you get any indication of how likely

this possibility was
MS. HERRMANN:

Obj ection.

BY MR. SKALABAN:

- - the transfer
GTCC to OCRWM?
MS. HERRMANN

of responsibilities of

Obj ection, speculation.
Yes, I did.

THE WITNESS:

BY MR. SKALABAN:

Can you tell me about what your sense of
that was?
MS. HERRMANN:
THE WITNESS:

Same objection.

I need to ask you a

question.
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So the problem with sealed sources and

with other is that they can have things that are
transuranic; they can have things that are not

transuranic, and so there
to be desired.
BY MR. SKALABAN

s--

it leaves something

So when you were referring earlier to
I think it was about two or three questions ago

when I asked you about any other problems besides
the neutron- generating sealed sources , I believe

you identified multiple waste forms and the
possibility of hazardous wastes.

Yes.
In that answer, when you

I re referring

to

the multiple waste forms and the possibility of

hazardous wastes, are you referring to the sealed
sources and the other category of GTCC waste?

Yes.
And to your knowledge, are you aware of

any technical obstacles of putting nuclear utility
activated metal GTCC waste in the Yucca Mountain

repository?
MS. HERRMANN

Objection, speculation.
m not aware of

THE WITNESS:
BY MR. SKALABAN

any.

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That would be parts of the fuel assembly
that aren

I t actually the fuel.
And are nonfuel- bearing components with

respect to spent fuel, are they understood to be

Greater- Than- Class
legal conclusion.

C waste?

MS. HERRMANN:

Objection, calls for a

THE WITNESS:

My understanding is that

spent fuel is spent

fuel.

So the fuel assembly

would be spent fuel, including the nonfuel bearing
components, because you can t have a fuel assembly

without some of it not being
spent fuel as far as I know.
BY MR. SKALABAN:

fuel.

That I S all

And as far as you

know, that I s going to

be accepted and disposed of by OCRWM along with the

spent fuel?
MS. HERRMANN

Obj ection, foundation,

speculation, calls for a legal conclusion.
BY MR. SKALABAN

And, again, I' m
nonfuel- bearing
MS. HERRMANN:
THE WITNESS:

talking about

components.

Same obj ections.
My understanding is that

assembly is being put into the canister by

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most utilities.
of a storage.

Those are being put into

And OCRWM has not formally

published, to my knowledge, exactly what it is they

are and are not going to

accept, but I believe it'

the assumption that everything that is placed into

the canister is - -

that those canisters are not

going to be reopened again.

But that is simply, I think, a common
assumption that enough people make that that' s why
I believe that to be true.

I don't know for

sure,

but that I S

- - that' s the assumption I believe that

m making and everyone else is
BY MR. SKALABAN:

making.

What you say everyone else, you '
referring to DOE, people at DOE?
And of the utilities.
I don' t believe

that the utilities would be packaging up their fuel

that way if they thought that that was not how it
was going to be accepted.

So, to your knowledge -- I mean, that' s a
commonly shared assumption by utilities and DOE?

Yes.
MS. HERRMANN

Obj ection, foundation.

BY MR. SKALABAN:

Do you know, are nonfuel- bearing

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to this area?

Yes.
MR. SKALABAN

Just to make clear my
I don

request on the record - -

I t know

how many

drafts of this policy analysis paper there
It may be too many to produce to us to ask

were.

questions on them tomorrow, but if it is a
manageable amount, we would like to see whatever is

available so we can try and ask him the

questions.

It seems clear there was one on paper and then

iterations and then a final
MS. HERRMANN

paper.
I don t know how

Yes.

many there are, but I would make a call on our next

break.
MR. SKALABAN

Thank you.

I appreciate

that.
MS. HERRMANN:
MR. SKALABAN

Sure.

Let me ask you about -It has

I I m going to introduce an exhibit to your

deposition.

Let'

s mark this as Exhibit

Bates numbers of HQR092- 0045 through 0052.
(Jones Exhibit No.

was marked for

identification.
BY MR. SKALABAN

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Page 126

Mr. Campbell, just review this
and I will point out on page 092

document,

- 0049, you are
document,

listed at the bottom with a phone number.

Okay.

Do you recognize this

sir?
Yes.
And can you identify what it is for the

record?

It'
issued paper.

s a Greater- Than- Class C waste program

Is the paper intended to assist in

determining the content and direction of the EM
GTCC program?
MS. HERRMANN:
THE WITNESS:
BY MR. SKALABAN

Obj ection, foundation.
I believe

so.

If I can turn your attention -- first of

all, does this break up the

- - does this

paper

break up the different types of GTCC sources along
the lines we

I ve been talking about earlier as a

sealed source GTCC, nuclear utility activated metal

GTCC, and other GTCC for purposes of the analysis?
MS. HERRMANN

Objection, the best

evidence.
THE WITNESS:

Yes, it does.

Alderson Reporting Company, Inc.
1111

14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

Case 1:98-cv-00126-JFM
Robert L. Campbell

Document 846-4

Filed 07/14/2004

Page 24 of 25
June 13 ,

2002

Washington , D.

Page 150

THE WITNESS:
BY MR. SKALABAN

No.

Do you think, even if it

was, for

example, Hanford you would still have the same
level of opposition to storing the activated metal

there that you would if you picked an area with no
nuclear connection?
MS. HERRMANN

Same obj ection.
To the extent that I can

THE WITNESS:

compare a specific to anything else, yes.
BY MR. SKALABAN:

Now, in Option 1 , there' s a reference

to the metal could be placed in the backfill

spaces according to RW.

What does that mean, that the metal could
be placed in the backfill spaces?
What does that

mean?
My understanding is that when they place
the fuel in the repository that there will be space

between the fuel and then there will be corridors

leading in for forklifts and things like

that.

As you place the fuel in, you could then
take activated metal and place it in as you, you

know, started in the back of a room -- or whatever

it I s going

to look like - - and filled your way

Alderson Reporting Company, Inc.
1111

14th Street, N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005

-Case 1:98-cv-00126-JFM
Robert L. Campbell

-Filed 07/14/2004 Page 25 of 25
June 13 ,

Document 846-4

2002

Washington , D.

Page 151

forward, as opposed to putting fill dirt or
something in there.

So anywhere that you were

going to backfill with dirt as opposed to fuel, you
could put the metal there

instead.
that the

So it I S your understanding

nuclear utility activated metal could be placed in
the backfill spaces of Yucca Mountain repository
under development?
MS. HERRMANN

Obj ection, speculation.
That has not been
not aware of

THE WITNESS:

specifically analyzed, but I' m anything prohibiting that. If

you analyzed

it,

included it in the license application and did all

the other administrative things, I'

m not aware of

anything that would prevent you from

from

physically doing that that would inhibit the
performance of the repository.
BY MR. SKALABAN
You I re

not aware of any technical

problems from putting it into the backfill spaces?

No.
When you say
it says according to RW,

did you have any conversations with RW where they
said that the nuclear utility activated metal could
be placed in the backfill spaces?

Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005