-Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 840-5
Filed 07/07/2004
Page 1 of 25
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Washington , D.
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
Filed 07/07/2004
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June 13, 2002
Washington , D.
Page 167
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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Page 168
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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Robert L. Campbell
Document 840-5
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June 13 ,
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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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Robert L. Campbell
Document 840-5
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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
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June 13 ,
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Washington, D.
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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Robert L. Campbell
-Page 7 of 25
June 13 ,
Document 840-5
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2002
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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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Robert L. Campbell
Document 840-5
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June 13 ,
2002
Washington , D.
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
Filed 07/07/2004
Page 9 June25 , 2002 of 13
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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June 13 ,
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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
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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
Page Line
CORRECTIONS:
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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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U U~=
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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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Robert L. Campbell
Document 840-5
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June 14
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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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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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Page 396
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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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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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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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
Place: 4269-47
Ref. No.
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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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