Case 1:98-cv-00126-JFM
Document 846-4
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EXHIBIT
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June 13 ,
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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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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Washington, D.
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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
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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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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
1111
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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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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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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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Page 95
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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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