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

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

Document 840-5

Filed 07/07/2004

Page 1 of 25
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2002

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Page 166

activated metal question.

If we have not solved it by then, then

utilities are then storing the activated metal and

they'

re not storing spent fuel any

longer.

I think that would be an unreasonable or

an untenable situation, that we should have been

able to solve the problem by

then, such that --

particularly a decommissioned utility could then

finally close out as opposed to having to
store this Greater- Than- Class C activated metal.

So it'

s important for the Department to

have a solution in place by the time the nuclear
by the time the spent fuel is being removed from
the site -- a solution for the GTCC waste?
MS. HERRMANN:

Obj ection, foundation,

vague.

Go ahead.
THE WITNESS:

I think it'

s -- I think

it I S important, yes.
BY MR. SKALABAN
And it' s important -- tell me the reasons

why you think that

I s important.

MS. HERRMANN

Asked and answered.
Well, first of all, the

THE WITNESS:

amount of Greater- Than- Class C activated metals

compared to spent nuclear fuel is

small.

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

Document 840-5

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al though you could disagree with

this, the impact

of the utility storing that while they have to
store their spent fuel is smaller than the impact

of having to store the spent fuel.
So given that situation, storing the

activated metal while they store the spent

fuel, is

not an unreasonable situation in -- from my point
of view.

Once the spent fuel is gone, though, then

you' ve - - I think that creates a problem.

The

Public Law 99- 0240 was amended in 1985, an estimate

of the opening of the repository is approximately

2015.

If we ve not come up with some kind of

answer for that by 2015, I just think that leaves

the Department in an untenable
I don

situation.

I t know

how you explain to anybody

why they still have to store their waste at that

point.
BY MR. SKALABAN

So the urgency to have an off-site
when I say off- site, I mean off- utility site, so

the urgency to have an off-site
me start again.

-- I' m sorry.

Let

So the urgency to have an off- site

option

available becomes much greater once the spent fuel

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

Document 840-5

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is being removed from

the utility reactor sites?
Obj ect ion

MS. HERRMANN

mischaracterizes the prior
THE WITNESS:

testimony.

Yes, once the fuel is

left,

the urgency would
BY MR. SKALABAN

increase.

And is it important to have an off-site
option available once the spent fuel has left the
utility site in order to allow for

timely

decommissioning of the facility?
MS. HERRMANN:

Obj ection, foundation,

vague.
THE WITNESS:

Yes.

It'

s certainly

important to the utilities, but I think in terms of

DOE providing a solution to this

problem, it I S also

important.
BY MR. SKALABAN
So from

a policy perspective, in your

view, it'

s important to have an off- site option

available once the spent fuel is removed so
reactors can complete their decommissioning?
MS. HERRMANN:

Objection, foundation,
I don

vague.
THE WITNESS:

It

know

from

a policy

point of view.

I mean , to have a policy that -- to

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

Document 840-5

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which says in the absence of specific

requirements,

in thi s

part.

Yes.
Is it your understanding that GTCC waste

must be disposed of in a geologic repository unless

proposals -- unless a proposal for disposal of such
waste in a disposal site licensed by the NRC is
approved by the NRC?
MS. HERRMANN

Obj ection, calls for a

legal conclusion.
THE WITNESS:

Yes.

BY MR. SKALABAN:

What' s your understanding of the timing
of that?
When is - - when must the GTCC go into a

geologic repository?
MS. HERRMANN
Obj ection , calls for a

legal conclusion, foundation,
THE WITNESS:
BY MR. SKALABAN
I don

speculation. I t know.

Take a look at Bates page HQR092 - 0052,

the very last page, attachment
In the very last sentence, it says DOE

did not meet its commitment to begin accepting GTCC

waste for storage by February 1989.
Do you agree with that statement?

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

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Yes.
What was the purpose of offering, putting
together this issue paper?
MS. HERRMANN:
Obj ect

ion, asked and

answered.
BY MR. SKALABAN:

What was it used for?
MS. HERRMANN

Same obj ect ions,

speculation.
THE WITNESS:

I would

I wrote this

issue paper to give my management information on
what the Greater- Than- Class C waste was and what

the issues surrounding it were.

I do not know what

they used it

for.

BY MR. SKALABAN:

Now, was there a specific question or
a specific question or event that was on the table
that caused you to draft this issue paper , this

Exhibit I?
I don

I t recall.

Typically, if there I s a

specific question or issue, I would have included
that in the first couple of paragraphs because that

would have been the genesis of the issue

paper.

didn

It'

s more of a general information paper.
don't recall the

So I don' t know - - I

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

Document 840-5

Filed 07/07/2004

Page 6 of 25
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Page 204

from that point of view.

So the - -

in other words, the waste form

is the same as material that

- - I' m sorry.

Le t

ask a more precise question, and let me start

over.

The activated metal, the nuclear utility
activated metal GTCC is the same material that has already been analyzed in the repository performance

models?
Yes.
So assuming that material gets licensed

to be put into the repository, it would

be,

presumably, easy to get the same material, the GTCC
waste, also licensed for the repository?
MS. HERRMANN:
THE WITNESS:

Obj ection, speculation.
I was not addressing

licensing issues.

What I was saying is if you can

dispose of spent nuclear fuel in the repository
from a technical performance basis, then you can
also dispose of activated metal because spent

nuclear fuel is activated metal plus
So one is a component of

fuel. the other.

Therefore, if it can perform for one, it will
perform for both because they' re the same thing.
BY MR. SKALABAN:

Did you give consideration to licensing?

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

-Page 7 of 25
June 13 ,

Document 840-5

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2002

Washington, D.

Page 205

I understand what you were saying

- - the answer

you

just gave me, but did you also give consideration to licensing -- getting licenses for activated

metals and spent fuel, presumably it would be

easier to - -

or easy to get licensing for activated

metal as GTCC?

I wasn't discussing that in this

particular paragraph, but I
basic statement, that I don
I t

I agree with that

foresee a licensing

issue.

If the NRC was going to issue a license for

the one, I don t know.

From a performance standpoint in terms of
how the metal' s

going to perform in the repository,

I would be surprised if they would have an
objection to it on that basis.

Because they'
Yes.

re one and the same?

You go on to say the additional volume is

small

insignificant
Why did you

when compared

the volume

SNF and HLW planned

let me ask you

this:

for the repository. include that first all The additional volume you'

referring to, the additional volume of material
that is nuclear utility activated metal , that would
be included into the repository?

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

Document 840-5

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Page 206

Yes.
And why did you include this statement

that the volume is small to insignificant when compared to the volume of SNF and HLW planned for
the repository?

I included that to point out that it

would not be a major undertaking and that it would
not significantly affect the planning for the

repository.
And was it your understanding that the

additional volume required to add the nuclear

utility activated metal GTCC in the repository
would not create a capacity problem at the

repository?
MS. HERRMANN:
Obj ection , speculation.

THE WITNESS:
BY MR. SKALABAN

That'

s correct.

Now, Option Number 4, this is an
evaluation of other existing disposal facilities

that are currently in existence that are used to

disposal of waste forms that are greater than

low- level waste; is that right?
can you correct what I just said?

Or if I'

m wrong,

Well, I list them out, I said evaluation

of other existing disposal

facilities.

It would

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

Document 840-5

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Washington , D.

Page 242

estimates.
periods.

It also gave estimates over time

And this, as far as I can tell by
glancing at this document, I can't tell over what

time period or over what part of the report they
took that number from.
And I also don' t recall
So I really don' t know why

what ACA stands for.

they picked that number.
MS. HERRMANN

Off the record.
, the taking of

(Whereupon, at 5:15 p.

the instant deposition adjourned.

fJ/d(l

Signature ' of the Witness

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

Document 840-5

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SUBSCRIBED AND SWORN TO before me this

day of

11/
~ co~ssi=
e~ires,

, 20

NOTARY PUBtc

O~ff~

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Case 1:98-cv-00126-JFM

Document 840-5

Filed 07/07/2004

Page 11 of 25

ER ' TA SHEET FOR THE TRANSCRII . OF:
Notice Date: June 17 2002 Case Name: Yankee Atomic V5. United States Case Number: 98- 126C- 987 4C
Dep. Date: June 13

2002

Deponent: Robert Campbell

Place: Washington DC
Ref. No.

4269-46

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CORRECTIONS:
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Filed 07/07/2004 TA SHEET FOR THE TRANSCRL OF:

Document 840-5

Page 12 of 25

Notice Date: June 17 , 2002 Case Name: Yankee Atomic VS. United Case Number: 98- 126C- 9874C Dep. Date: June 13 , 2002 Deponent: Robert Campbell Washington DC

States

Place:

Ref. No.

4269-46
CORRECTIONS:

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Date of Signature

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

Document 840-5

Filed 07/07/2004

Page 13 of 25
June 14 , 2002

Washington , D,

Page 244

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
--------X

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

C~l.~

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CASE NO.

vs.

Plaintiffs,
98- 474C

98- 126C 98- 154C

UNITED STATES OF AMERICA,

Defendant.
Washington, D. C .
Friday, June 14, 2002
Continued Deposition of ROBERT ALLEN CAMPBELL,

a witness herein, called for examination by counsel
for the Plaintiffs in the above-entitled matter,

pursuant to recess, the witness having been
previously duly sworn, taken at the offices of
Spriggs & Hollingsworth , 1350 I Street, N. W. ,
Suite 1010, Washington, D. C, at 9:33 a. , on

Friday, June 14, 2002, and the proceedings being

taken down by Stenotype by CINDY L. SEBO, and
transcribed under her direction.

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

Document 840-5

Filed 07/07/2004

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2002

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regulatory mission then is hampered if it

-- if

there I S no ability to dispose of GTCC waste?
MS. HERRMANN:

Objection, foundation,
conclusion.
anywhere

speculation, calls for a legal
THE WITNESS:

The particular things I had

stated are hampered.

Their overall - -

where disposal doesn' t affect their regulatory
framework, no, it doesn' t hamper them.

It is only

in the areas where disposal plays a
BY MR. SKALABAN:

role.

Now, in addition to public safety and
heal th and properly maintaining their regulatory

framework, would you also agree it I S

undesirable,

just from a sound nuclear management perspective,
if waste that needs a home doesn' t have a home

that is unsound nuclear management practice?
MS. HERRMANN:
Objection, vague,

foundation, speculation.
THE WITNESS:

I believe the regulatory

framework is the nuclear management foundation , so

I don't think my answer
BY MR. SKALABAN:

changes.

Well , how about promoting timely
decommissioning, is that also a factor why the
existing status quo is not an acceptable state of

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

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MS. HERRMANN

Objection, vague,

foundation, speculation.
THE WITNESS:

The Congress of the United

States determined that there should be disposal for

Greater- Than- Class

C waste, and they directed the

Department of Energy to make it

happen.

Therefore,

it' it'

s undesirable if it' s not happening, because

s the policy of the Government of the United

States to dispose of Greater- Than- Class C waste.

BY MR. ' SKALABAN:
Are you familiar at all, in any of your
conversations or discussions within EM or with the
NRC, of the concept that' s reflected here, that NRC

staff considers DOE derelict in not having taken
action on the GTCC issue already?
MS. HERRMANN:
Obj ection , assumes facts

not in evidence,

foundation, speculation.
m sorry.
Coul d

THE WITNESS:
repea t

you

that?
MR. SKALABAN:

Can you read the question

back, please?
THE REPORTER:

Question: Are you

familiar at all, in any of your conversations or

discussions within EM or with the NRC , of the

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concept that'

s reflected here, that NRC staff

considers DOE derelict in not having taken action
on the GTCC issue already?"
THE WITNESS:
BY MR. SKALABAN

Yes.

And can you tell me about those

conversations?

How has that

how has that issue

come up that NRC staff considers DOE derelict in
not having taken action?
MS. HERRMANN

Objection, vague,

foundation ,

speculation.

THE WITNESS:

In a meeting discussing

this issue with the NRC, they expressed -- my

management was explaining why we were unable to do
certain things.

And they expressed - -

what' s the

word I I m looking for - -

a certain amount of

amazement that 15 to 17 years had gone by and we

weren't well on our way to developing disposal.
BY MR. SKALABAN:

And this meeting you' re referring to

between DOE and NRC staff, when did this meeting
occur that you just referred to?

It would have been the 2001 time

frame.

And who from the NRC was at that meeting?
I was tied in on a conference call , so I

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BY MR. SKALABAN

Okay.

Let'

s assume that the Yucca

Mountain repository was available in

1998, and in

1998 nuclear utility spent fuel had begun to be

removed to that

site.

In that scenario, is it your opinion that

the Department should then have had a disposal path
identified and available for GTCC waste?
MS. HERRMANN

Obj ection, speculation,

relevance.
THE WITNESS:

Yes, I think there was

ample time between 1985 and 1998 for DOE to

determine what disposal path they

wanted, had -

- if

the repository was available, then -- you know
based on the suitability of that repository to
dispose of Greater- Than- Class C waste, yes, a path
should have been in place.
BY MR. SKALABAN:

Do you think

putting aside politics

and funding, from a technical and engineering point
of view, is a 13 - year period from 1985 to

1998, is

that ample time to identify and develop and have

available a storage or disposal path for nuclear
utility activated metal Greater- Than- Class C waste?
MS. HERRMANN

Objection ,

speculation,

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activity or if Congress didn't appropriate the
funding for that activity.

Can you think of any other policy

justification other than

funding, licensing
Objection ,
speculation

incapabilities and legislation?
MS. HERRMANN

relevance.
THE WITNESS:
BY MR. SKALABAN
, I can' t think of any.

In your various conversations and

dealings with the NRC, has the NRC ever given you
any indication that it would be an acceptable or a
desirable policy to leave Greater- Than- Class C

waste at the site of decommissioned reactors once
the spent fuel has been removed?
MS. HERRMANN

Objection ,
No.

vague.

THE WITNESS:

BY MR. SKALABAN:

Has anyone in any of the conversations

you ve ever been involved in with the Department of

Energy - - and

we' ve talked about many of them, but

m not limiting it to the ones we' ve talked

about -- have any of the conversations that you
been involved with with members of the Department
of Energy, has anyone ever expressed to you that it

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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'
believe it
s not my area of expertise, but I

did.
Has the Government ever moved either
C waste or material comparable

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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Robert L. Campbell

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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' re familiar
wi th 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 I ve ever
thing.

tried to juxtapose those two in this manner before
but I assume I' ve

--

they mean the same

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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Page 445

MS. HERRMANN:

Objection ,
Yes.

calls for a

conclusion.
THE WITNESS:
BY MR. SKALABAN

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' 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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DocumentWashington , D. 840-5 Filed 07/07/2004

Page 22 of 25
Page 454

(Whereupon, at 5:05 p. m., the taking of

the instant deposition adjourned.

W!24#
Signature of the Witness

TO before me this

day of

NO:rARY PUBIC
My Commission Expires:

l/;l ;l)

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Case 1:98-cv-00126-JFM SHEET FOR THE TRANSCRII OF: Document 840-5 Filed 07/07/2004 TA
Notice Date: June 17 , 2002 Case Name: Yankee Atomic vs. United States Case Number: 98- 126C- 987 4C Dep. Date: June 14 , 2002 Deponent: Robert Campbell (continued) Washington DC

ER

Page 23 of 25

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

Document 840-5

Filed 07/07/2004

Page 24 of 25
January 29 , 2003

Washington, D,
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,

Defendant.

98- 474C

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 Public 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.

Alderson Reporting Company, Inc,
I II I 14th

Street, N. W, Suite 400 l- 800- FOR- DEPO Washington , DC 20005

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

Document 840-5
Washington, D,

Filed 07/07/2004

Page 25 of 25
January 29 , 2003

Page 4

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't anyone else who works for DOE.

anything, there

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

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