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Robert L. Campbell
Washington, D.
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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 s
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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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:
Obj ection, vague.
I I m not aware of the
current chemical characterization of the GTCC waste
around the country.
BY MR. SKALABAN
So I don
It
I don
I t know.
- - you
Has it ever
corne up in
any of your
know, any of your work as the person in charge of
GTCC waste for DOE at this time, has it ever corne
up that GTCC waste may be
or some GTCC waste
that'
s out there may be mixed waste?
Yes, it has.
And how did that corne up?
Wha t
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
radioact i ve .
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; is
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
proj ect 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
was.
Okay.
then a month or so later, they
changed their minds and it went back to the way it
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 project 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' s
going to happen
So I do not know.
BY MR. SKALABAN:
Okay.
So you haven' t been involved in
any conversation - -
let me ask this question:
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
Yes.
review?
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 I 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
Objection, speculation.
Yes.
Jessie Roberson.
THE WITNESS:
would be her decision.
So that I 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
transfer of responsibility?
was your
conversation with Ms. Lazinski about this possible
Within the last two months.
It I s Rudzinski.
that?
Yes.
Do you want me to spell
Would you please?
R-u-
i-n-s-
Did you get any indication of how likely
this possibility was
MS. HERRMANN
Obj ection.
BY MR. SKALABAN:
-- the transfer of responsibilities of GTCC to OCRWM?
MS. HERRMANN
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 obj ection.
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 ' s - to be desired.
BY MR. SKALABAN
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.
I re referring
to
Yes.
In that answer, when you
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
Obj ection , speculation.
THE WITNESS:
BY MR. SKALABAN
I I m not aware of
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 I t have
wi thout some of it not being
a fuel assembly
s all
fuel. That'
spent fuel as far as I know.
BY MR. SKALABAN
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 I s why
I believe that to be
true.
I don
I t know
for
sure,
but that ' s - -
that' s the assumption I believe that
I I m making and everyone else is
making.
BY MR. SKALABAN:
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't know how many
request on the record - -
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
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
Sure.
MR. SKALABAN:
Let me ask you about -It has
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- 0049,
document,
you are
listed at the bottom with a phone number.
Okay.
Do you recognize this document,
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
Objection, foundation.
I believe
THE WITNESS:
so.
BY MR. SKALABAN:
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' 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:
Obj ection , the best
evidence.
THE WITNESS:
Yes, it does.
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THE WITNESS:
No.
BY MR. SKALABAN:
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:
THE WITNESS:
Same obj ection.
To the extent that I can
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
your way
it I s going
to look like
- - and filled
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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.
So it'
s your understanding that the
nuclear utility activated metal could be placed in
the backfill spaces of Yucca Mountain repository
under development?
MS. HERRMANN:
THE WITNESS:
Obj ection, speculation.
That has not been
specifically analyzed, but I' m not aware of
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?
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Yes.
Who were those
those conversations?
who was involved in
Conversation was with Dave
Zabransky.
And when was your conversation with
Mr. Zabransky?
At least a year
exactly when.
ago.
I don't remember
Did you have one conversation on this
topic or multiple ones?
ve had multiple conversations with
Mr. Zabransky, but I believe we only talked about
this one time.
And what did he tell you about putting
nuclear utility activated metal GTCC into the
backfill spaces?
MS. HERRMANN:
THE WITNESS:
Obj ection, hearsay.
He simply said it could be
done.
BY MR. SKALABAN:
And was he talking from a technical point
of view, capacity point of view, or both?
MS. HERRMANN
Obj ection, speculation.
THE WITNESS:
Both.
BY MR. SKALABAN:
1111
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Did you and Mr. Zabransky talk about any
other aspects of placing nuclear utility activated
metal into the Yucca Mountain repository?
Not that I remember.
Have you talked to him just generally
about this subj ect, other than this one
conversation, about the backfill
spaces -- utilizing the backfill spaces?
Have you
had conversations with him generally about
incorporating GTCC into the repository?
The other conversations I'
were - - had
ve had with him
more to do with the logistics of
packaging, transport to the repository, not
placement in the repository.
So you have had conversations with
Mr. Zabransky about the logistics and
transportation aspects of taking nuclear utility
activated metal GTCC to the repository?
Yes.
And why were you discussing with him the
logistics and transportation aspects of taking
nuclear utility activated metal GTCC?
The reasons for the conversations were
determining whether the spent nuclear
fuel/high- level
waste repository was a reasonable
1111
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disposal site for Greater- ~han- Class C and how that
could - -
you know , how that could be implemented.
And what did he say to you regarding the
logistical and transportation aspects of taking
nuclear utility GTCC to the repository?
MS. HERRMANN
Obj ection, hearsay.
Basically, you know, if the
THE WITNESS:
activated metal is packaged in a similar fashion to
the fuel, then there' s very little difference in
handling fuel canisters as opposed to activated
metal canisters and that he saw
- - he didn' t
see
anything that would make that difficult to do in
the same fashion that you would handle the
fuel.
We were speaking only in terms of the
physical and technical, not the administrative, you
know, political, legislative aspects; just purely the physical and technical issues
BY MR. SKALABAN
involved.
So with Lespect to the physical and technical issues, he told you that logistically and
technically the GTCC, if packaged like spent
fuel,
could be handled and transported without problems?
MS. HERRMANN:
THE WITNESS:
Obj ection , hearsay.
The GTCC activated metal,
yes.
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option.
I was looking to see if there were
physical or technical issues that would
prevent/cause problems with that as -- as a
disposal option as opposed to administrative
issues, which, as I state in this paper, everything
got an administrative issue associated with
it.
So Mr. Zabransky told you from logistical
and transportation issues, it would not be a
problem and from capacity and performance of the repository, it would not be a problem to put it in
the backfill spaces; is that correct?
MS. HERRMANN
Obj ection, hearsay.
I believe everything you
THE WITNESS:
said was correct.
I don
I t recall
if we discussed
I just -- we may
repository performance aspects.
have talked about that.
BY MR. SKALABAN
I don' t remember.
Did you talk about anything else other
than what I just mentioned about placing GTCC in
the repository -No.
with Mr. Zabransky?
that after your feeling, that
Not
recall.
you had
it would
talked to him what
was
fair
say
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that your feeling was it'
s not a problem from a
physical and technical point of view to take the
nuclear utility activated metal and dispose of it
in Yucca Mountain?
From a physical and technical point of
view, yes, that' s
correct, the conversation
resulted in that that would not be a
problem.
Did you explore with him at all
administrative roadblocks to Yucca Mountain for
GTCC waste?
We may have discussed
it.
ve had a
number of conversations with him on a variety of
topics.
Since he works in RW, it would all be
related to this
issue.
I do recall now that we did have
I do
an issue where it was a -- someone had suggested
that the NRC might
- - or someone
had requested in a
letter to the NRC that they reclassify
Greater- Than- Class C as high- level
waste.
And we
had a conversation in preparing the response
- - the
technical response to that and what would that
entail.
It would then become RW' s responsibility,
if it was high- level waste, commercial high- level
waste, that would fall within their realm of
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understanding it'
Yes.
s nuclear utility activated metal?
And the backfill spaces will be adequate
to dispose of the 1850 cubic meters that'
estimated?
MS. HERRMANN
Obj ect ion,
speculation.
THE WITNESS:
I don't know the answer to
that.
We discussed
it.
Mr. Zabransky did not
indicate there was a capacity problem, but we did
not discuss exactly how much backfill space there was versus how much nuclear utility activated metal
there was.
But my memory of the conversation is
that that -- because it didn't corne up, my memory
is that I believe there' s going to be more backfill
space than activated metal.
BY MR. SKALABAN:
Which is why you put it -- recognize it
in the paper?
Yes.
If there was a problem with only a
limited amount, yeah , I wouldn
I t have
recommended
it.
In fact, 1850 cubic meters
- - what' s
your
sense, is that a large volume of material or
relatively a fairly small volume of material?
MS. HERRMANN:
Obj ection , vague.
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Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 840-4
Filed 07/07/2004
Page 23 of 25
June 13 ,
2002
Washington, Do
Page 162
THE WITNESS:
It'
s small compared to the
spent nuclear fuel and high- level waste
that will be placed in the repository.
BY MR. SKALABAN:
Can you take the paragraph that reads
storage of nuclear utility activated metal?
still on page HQR092- 0049.
It'
I I ve read
Okay.
the paragraph.
Are you familiar with the report
to Congress required by the Public Law 99- 240?
Yes.
Do you understand in that report, DOE
committed to accepting GTCC for storage when
needed?
MS. HERRMANN:
Obj ection , best evidence,
calls for a legal conclusion.
THE WITNESS:
The report makes this
statement similar to that, yes.
BY MR. SKALABAN:
So that - -
I mean, that' s what you wrote
here on this page, correct
- - you wrote the
the Department
Department committed - - quote,
needed?
committed to accepting GTCC for storage when
Yes, that'
s what I wrote.
1111
14th Street ,
Alderson Reporting Company, Inc. N. Wo Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 840-4
Filed 07/07/2004
Page 24 of 25
June 13 ,
2002
Washington, Do
Page 163
And that'
s your understanding of the
report?
Yes, it
is.
Let I S make the record
MR . S KALABAN :
clear, I would like to make as Campbell Exhibit 2 a
February 1987 report to
Congress.
(Campbell Exhibit No.
was marked for
identification.
BY MR. SKALABAN:
My question for you is, is this the
report that you
paper, Exhibi t
I re referring
Let'
Yes.
to here in this issued
MS. HERRMANN
s wait until you get
it.
THE WITNESS:
MR. SKALABAN
Can you read back the
on the record?
question so it I s clear
THE REPORTER: " Question: My question for
you is, is this the report that you re referring to
here in this issued paper Exhibit
BY MR. SKALABAN:
I?"
Exhibit 2 is the paper referred to in the
section of Exhibit 1 that we' ve just been talking
abou t ?
Alderson Reporting Company, Inco
1111
14th Street, No W. Suite 400 1- 800-FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Robert L. Campbell
Document 840-4
Filed 07/07/2004
Page 25 of 25
June 13 ,
2002
Washington, D.
Page 165
you agree that the Department is obligated for the
final disposal of GTCC waste?
MS. HERRMANN: legal conclusion.
THE WITNESS:
Objection, calls for a
You sort of paraphrased
there, but in terms of the Department is not
obligated for the final disposal of GTCC
waste,
yes, I agree with
BY MR. SKALABAN:
that.
I was trying to avoid a double negative,
but thank you.
What do you mean here when you say a
reasonable approach would be that utilities are currently required to store their spent nuclear
fuel until the Department begins to accept it at
Yucca Mountain.
At that point, EM could have
identified and established a storage facility to accept and store nuclear utility activated metal
until such time as a disposal option is
available,
such as placement in a geologic repository for
SNF /HLW .
The intent of those sentences was that up
until the time that the Department begins accepting
spent fuel, we' ve got until then to come up with
some sort of an answer to this nuclear utility
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