ML19345E552
| ML19345E552 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/14/1981 |
| From: | Peck R BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102050132 | |
| Download: ML19345E552 (66) | |
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CCNSUMERS POWER CCMPANY : DCCKET NOS . 50-329 CM
- 50-330-CM (Midland Plant, Units 1 and 2) : 50-329-CL 50-330-CL Deposition of RALPH 3. PECK OATE: Januarv 14, 1980 PA M : 141-205
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VOLIDE II 141 I BEFORE ThT. NUCEAR REGL7.ATORY COMMISSION i 2
3 In the Matter of: } Decke t Nos . 50-329 CM
) 50-330 OM 4 CONSIDERS POWER COMPANY )
) 50-329 CL ,
s 5 (Midland Plant, Units 1 and 2) ) 50-330 OL :
2 )
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1 7) Continuation of DEPOSITION OF RALPH 3. PECK, a j 8 witness produced and examined further on Wednesday, the lith e
9 day of January, in the year of Our Lord 1981, between the '
E h10 hours of 8 o ' clock in ene forenoon and 6 o 'clecicff$ the after-
- i II 5 soon of that day, at the Zia Conference Room II, Hilten Inn, -
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"E 12 1900 University, in the city of Albuquerque and State of l j 13 New Mexico, in a certain cause, Consumers Pcwer Company, l E 14 ' l 4
now pending before the Nuclear Regulatory Commission. .
2 15 :
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A PPEA RA NCES j g j7 i
! 18 , F r the Nucler Regulatory Commission: !
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l l E 3RADGY J0W.S , Esq. ;I a 39 t l M 20 i For Consumers Power Company and The Witness :
21 AIA N S . FA RNELL , Esq . ,
I Isham, Lincoln & Beale, -
One National Plaza, i 22 Chicago, Illinois, 60603.
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ALDERSON REPORTING COMPANY. INC. !
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i 142 i 1' .C _0 _N. .T _E _N _T .S 2 WITNESS DIRECT CROSS REDIRECT RECROSSI 3 Ralph B. Peck (continuing) 143 4
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A 7 NUMBER MARKED FOR IDENTIFICATION j
% l j 8 Peck No. 3 143 J
U 9 154 Peck No. 4 3.
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ALDERSON REPORTING COMPANY. INC. !
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1 3ALTH 3. 23CI l 2 of lawful age, having been previcusly duly produced, sworn 3, and ex3 ined on the part of the Nuclear Reg:lato y 2=-
4 =ission, further deposeth and saith:
)
e 5 M2. JON35: Or. Peck, you are still under cath. ;
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6 THE WITN3SS: All right. .
~
i i 7 MR. JON3S: Would you mark this for identification l 3 f I
n 8 as ?eck Exhibit No. 3. .
9 (IFI23U20N A IOCUMINT WAS MAu m mY IEI RI?OR221 i
.t 10 As ?ICI RT=TRI2 NO. 3 FOR I2ZNTI2'IOATION. )
E OIRECT ?J.AZINATION (Con 't) 11
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j 12 3Y MR. JONIS: ,
5 13 C. Dr. Peck, I will hand you a docu=ent that has l
=
!U 14 been =arked as Peck 3xhibit No. 3. It is a semorandum and !
2 15 in the lefthand corner is the 3echtel symbol with Ann Arbor .
5
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j 16 written on there. It has an identification number at the ;
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a 17 bottoc, which is S3'706490. According to the notation at -
i y: 18 the top, it is a semorandu= to S.12121 frer. 3. Char. ;
"g 19 I would ask you to read this memorandus and then I will i t
n 20 ask you sace questions about it. ;
21 A c,g, 22 0. PJ.s se=orssdu: refers to a neeting in which, ac-23 cording to this docu:ent, you and Dr. Hendron pointed out 24 that the reinforcing of the wings of the auxiliary building 25 would not be necessary during dewateri::g. It also states 2
ALDERSON REPORTING COMPANY, INC. ;
03 : 11M_
i 144 1
1 that an analysis by 3echtel indicates that this sight result ;
1 2; in an overstressing at the wings at the control tower !
3 junctions. Were you aware of this disagreecent.
4 MH. ?AR'i3IG: The docu=ent speaks for itself.
t e 5 X2. JONIS: I asked if he was aware of it.
4 i n -
e 6 X2. FARN3LL: I am no: sure that that is what the '
1 5
$ 7 document says.
N j
I 8 A Tes. l J
9 3! M2. JCNIS: '
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$ 10 C Do you know if that disagreement was resolved? ,
E_
j 11 A No. .
3 y 12 C Do you know whether the building is, in fact,
= 1 13 going to be reinforced during dowatering, the wings?
= ,
n 5 14 A I do not know. i
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15 - Q How did you arrive at your conclusion that--strike g 16 that.
- i i 17 Ihis document says, "Dr. Peck and Dr. Ecadron a ,
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id pointed out that the auxiliary building wings were con-i n
p 4
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19 structed under dry conditions." 3ces that refer to the :
a 3 i 20 ' soil being dry? I I
21 g yo, 22 ' C What does that =ean when it nef ers to " dry con-l 23 ditions"?
24 A It means there was no water on the excathtion when 25 i the building was constructed.
l I
ALDERSON REPORTING COMPANY. INC.
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145 i I
11:3 1, 2 Is it still your position that because of that it 2 would not be necessary to provide any additio:a1 support for 3 the wings during dewatering?
4 A I don't have any position en that, no.
g 5 2 What has subsequently caused you not to have any N i j 6' position on that facto-*
l R
7
$ A Ihe analyses that =sy have been cade on the l s !
8 auxiliary buildi g should have provided further infor:ation
-J t 9 abou t which I don ' t %=ow. That =ay or =ay act have changed 3.
@ 10 the situation.
3
!s 11 C Let =e refer you to the analysis that was con-(= 12 ducted. You have not seen the results?
g 13 A That's right. !
2 e
5 14 C Dr. ?eck, have you ever sem a docu=ent identified i I
g 15 as Regulator 7 Guide 1.132, entitled " Site Investigatio:s
= ,
j 16 for youndations of Nuclear Power Plants. "
d l
I7 A I presume such a document exists. I have never ![
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l 'S seen it.
2 <
- ; i "s 19 ' 2 Dr. ?eck, has it been your experience when pre-a 20 senting advice or recom=endations to 3echtel that follow-up ,
l 21 ~
- questions fro = 3echtel on that advice have been given to you?'
22 Ocepcund.
MR ?ARNZLL: Objectio .
23 A Are you talking about Midland?
24 y
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.dith respect to Midland.
25 A Could I have the question again, please?
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146 11: 4 I (The pending questien was read by the reporter.) ,
2 A I think there eften er always has been further 3 discussion, including questio::s, in response to a::ythi::g 4 I have co==unicated to Bechtel.
3 5 3Y MR. J0:ES:
2 j 6 2 2 rom these discussions or follow-up questions on 7 your advice to 3echtel with respect to the Midland plant, 4
$ 8 hcve you for=ed an i=pression of whether 3echtel is closely e
9 scrutinising your recc==endations or advice before ceciding
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10 ' whether or not to implacent those reccc=endations?
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!a II MR. 7A3? ELL: Objection. Ccepound question. Calls;
- i 12 z
for speculation.
- 13 g 3? IG. J0!GS:
3 E
14 q I asked if you had for ed an i=pression which is a s
9 15 g yes or no and isn't speculation.
? 26 3
s 1 Tes.
" 17 d O Vast is that impression?
=
18
$ 4 A They do scrutinise my recoc=endations or sugges-19 3
n tions.
C Ecw such, settle =ent has occurred at the Midland 21 site as a result of the temporary dewatering systems 22 operation?
23 A I don't have any specific nu=bers in =ind.
24 2 Eas there been some settlement as a result of that 25 dewatering" ALDERSON REPORTING COMPANY. INC. '
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147 1< A I understand there has. -
2 C to you know wLether it has been more or lese *han 3 ene inch?
4' A No, I don't.
e 5 C Dr. Teck, do you know the sazimum amount of R
j 6 settlement that has occurred in the sessurement of the A 7 pedestal settlement rods at the diesel generator building?
! 8 A I don 't know the number, no.
J 9 2 Do you know whether it is more or less than one 3.
@ 10 inch?
- E
i II A Settlement since what time?
s '
y 12 2 Since the pedestal settlement rods were placed.
5 j 13 A No , I don 't know.
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$ 14 Q Dr. Peck, were you ever requetted by 3echtel to j= 15 specify the tolerable rate of settlement for any Class I j 16 ' structure at the Midland site?
4 E 17 A I don 't believe so.
E
$ 18 , G Were you ever requested by 3echtel to specify the tolerable maz1 mum settlement for any Class I structure "g 19 n
20 at 3echtel?
21 A I don 't believe so.
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22 C Do you know if 3echtel ever made such requesta 23 of anyone else?
24 A I don't know.
25 C Have you ever requested of 3echtel or anyone else ALDERSON REPORTING COMPANY,INC.
148 as to the tolerable rate of settlement that would be per- I 1
2, missible for the Midland diesel generator building?
3' A I doubt it.
1126 4 C Eave you ever requested of 3echtel or anyone their e 5 assessment as to the tolerable maximum settlement that would 6 he permissible for the Midland diesel generator building?
3 7 A I don 't believe so.
3 j 8 C How does total settlement affect a structure's 9 int *6:it7? '
E E 10 M3. ?A3TELL: This is in general, I take it?
E 3 11 < MR. JONES: In general.
m d 12 A In genersi it affects it in extremely different z
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l= 13 ways, depending on the circumstances.
E 14 3! MR. JONES:
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2 15 C In the circumstances of the diesel generator a
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j 16 building, how would " settlement" affect the structural a
p 17 integrity of the building?
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5 18 A Is this a hypothetical or are you ask13C how did n
- 19 it?
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20 C How would total settlement affect the suructural 21 integrity?
22 A I don't believe that total differential settle-23 ment has a specific meaning in your question. I should say 24 what do you =ean by " total differential 3ettlement."
25 C I first referred to just total settlement, not ALDERSON REPORTING COMP ANY. INC.
1 i
i 149 I i
1137 1 differential. k i
2 A What is " total"? I 3 C The total ancunt the building bas settled under 4 the surcharge.
S 5 A The maxirus amount?
R j 6 C Yes.
g t 7l A Ch.
j 8 2 Ecw would that affect the structural integrity e
9 of the buidling.
?
@ 10 MR. FA3NELL: Objection for lack of foundation.
3_
l!n II I
A It would not affect it at all if thIe base of the :
d 12 foundation remained a plaint.
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13 3Y MR.. JONES:
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I4 C If there was differential settlement such that
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g 15 < the base foundation did not remain a plaint, is there a {
r j 16 point at which differential settlement will affect the e
' " 17
- j structursl integrity of any building?
E 18 MR, FARNELL: I hate to do this, but would you 3
! n -
n 39 g repeat the question, please? ,
I 20 J
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(The pending question was read by the reporter.)
21 I will object to that question.
MR. ?ARNZLL:
22 The first part of it appeared to relate to the prior ques-l 23 l
tion dealing with the diesel generator building, but the last part of the question appeared to bring it out of i
25 l specifies and into the genersi class of any building. I l
i ALDERSON REPORTING COMPANY. INC.
1
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.l 150 l 1
1 think you would be talking about apples and orsnges. l l
1 4
2 3T MR. JONIS: ;
3 Q. Obviously, Or. Peck, I asked you the questics for 4 any building so it is a genersi questic=.
5 A Structural integrity also is subject to con-e 9
j 6 sidersble interpretation. The deceral answer to the questics:
^ i 5, 7 has to be yes. l
'n j 8 2 0 I. With respect to the diesel generator J
- 9 building. has there been any computation of a point at i.
E 10 which differential settlement would adversely affect the E
=
{a 11 s m etural integrity of that building, to your kncwledge? ,
j 12 A It is 27 understanding that ec=putations have been E 13 made of stresses associated with deformations of the build-5 25 5
14 ing, but that is not the same as s=2ctural integrity. I n
j 15 don't know how you would sake a computation concerning a
m j 16 s m etural integrity.
as y 17 C Eave you reviewed these computations of stress?
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5 18 A No.
=_
"g 19 O. Do you know who performed the analysis to reach n
20 those computations?
21 ; A yo, 22 0. Or. Teck, do you have any real concern that 23 hydraulic frseturing will happen if borings are taken in the 24 dike at Midland as have been requested by the Cor2s of 25 3ngineers and the Nuclear Regulatory Commission?
ALDERSON REPORTING COMPANY. INC.
151 .
11:9 1 A I think it is possible that fracturing may 2' occur if these borings are taken. i 3 0 Would you define hydraulic fracturing for =e?
4 A It is the cracking or separation of a mass of 5 soil caused by the injection of a fluid under pressure.
e n
j 6 C Is there any way to take borings that would R
R 7 eliminate this problem?
n j 8 A Tes.
L 9 C What method er methods would do it?
I 5 10 A If the depth to which the boring would go does i
j 11 no.t' extend below the water table, it may be possible to make a
f 12 a : boring in the dry by means of an auger possibly and with ,
g 13 the use of caissing probably to keep the hole open. It may
[ 14 also be possible, under some circumstances, to make a boring '
15 with a very viscous fluid as the drilling agent. It may j 16 sometimes be possible to do it by means of compressed air s
lI 17 as the means for removing material from the hole. All of w 18 these methods are applicable under some conditions and are l E 19 likely to be unsuccessful under others.
20 C With respect to the drilling using an auger and 21 caissing, why can that not be done below the water table?
l 22 A Sometimes it can if the material is cohesive and 23 relatively impermeable.
24 C What happens if the material isn't cohesive or 25 relatively i= permeable?
l ALDERSON REPORTING COMPANY, INC.
l
! s i 152
- A It tends to run into the hole. !
I O Would it be possible after the hole was drilled l 2
to, and with the caisson around it,to so=ehow cap the botic 3
4 of the hole to prevent it from running in?
A It runs in while you are =aking the hole.
5 R
6 % In your opinion, could any of these three nethods ,
a 7
be used at Midland to take borings in the dike?
I 8 A Quite possibly.
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$ 9 O And if done properly, would that eliminate your z
- $ jo concern for hydraulic fracturing in those dikes?
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z i 11 A' 7ery likely. ,
3 3 12 ' C Which one of these three do you think can !
z 3
s 13 ; successfully be uscJ if done properly at Midland?
E j,
I don't know, i E 14 A a
t a
! 15 C Could they all be used?
2 '
16 , A Perhaps. You would only know. if you tried.
s I i 17 2 Eave you had any experience with drilling borings !
E 18 in completed dama that were retaining reservoirs? ,
c ,
3
- A Tes. !
s 19 ,
n 20 C Eave you had a great deal of problem with hydraulic l 21 ,
fracturing in t,aking those borings?
22 A Tes.
23 2 Were you able to use one of these methods to take 1
l 24 those borings such that you eliminated the problem,? :
25 A No.
ALDERSON REPORTING COMPANY. INC.
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153 1 C Were you able to use one of these =ethe'ds so 2 that the problem was greatly reduced?
3 A No, d C Eave you had any experiences where borings were s 5 safely drilled and hydraulic fracturing did =o beceme a a
j 6 problem? I am not referring to a potential problem, but R .
E 7 actually occurred in ecmpleted dams that were retaining
! 3 reservoirs?
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9 A Tes.
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@ 10 C Do you k=ow in the dams where you did have a
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a II problem with hydraulic fracturing what caused the hydraulic j
12' fracturing i= those dams?
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4 a
14 C What was it?
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15 A Wa.ter pressure. l j 16 m
c Was it solely the water pressure from the
" 17 3 drillisgo
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I8 l; A It was the water pressure frem the permeability j I' testa that were being conducted in the holes.
20 C Was the water for the permeability testa under 21 pressure?
22 A Tes.
23 C I have a document that is labeled ' Meeting Notes 24 No. 866"and it is a 3echtel Associates Professions 1 Corpora-25 tion document. That name appears at the very top of the ALDERSON REPORTING COMPANY,INC.
l 154 1 paper. It has an identification number of S3703305. It 2 purports to be a summary of a meeting held on October 20. i 3 1979. I will show you this document and address your atten-4 tion to Itecs 1 and 2.
e 5 E. JON35: Vould you = ark this as Exhibit No. 4, a
3 6 please.
~
n i 7 (tea 3!T20N A DOCUENT WAS Man AS 23CI ne t 3IT n
j 8 No. 4 FOR ID3NTI?ICATION.)
-J 9 3Y E. JON3S:
Y 5 10 G I will show you this document and ask you to E
!3 11 particularly address your attention to Items 1 and 2 under f=
12 ' items discussed at the meeting.
g 13 A o,g, m
! I4 Q Or. Peck, do you know whether you were in at-15 , tendance at that meeting?
16 A It says I was.
a[
s y 17 C I am asking because Item 2 refers to a recommenda-18 tion you made.
5 7.
im s I9 , A Yes.
n 20 C I am wondering whether you made it in person.
21 A No, I was not at this meeting.
22 2 Dr. Peck, did you have any input into Consumers 23 2cwer Company's decision not to take borings in the dike 24 at that time?
j A At that time, I don't recall.
ALDERSON REPORTING COMPANY,INC.
i l 155 .
i l 11:13 i C Do you have any idea why the borings were to be i 2
taken by Consumers Power Company that are referred to in 3 II82 17 4 MR. FARNILL: It doesn't say they were to be e 5 taken. It also calls for speculation.
n
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6 MR. JON33: It is a yes or no question.
a k7 A No. There is one answer that I gave yesterday ,
E n 8 that I think should be amended. You asked me, I believe, N 9 whether I had ever prepared a=y answers to the 50-54 ques-Y
.6 10 tions and I said no, that I had only suggested changes in E
3 11 language and reviewed answers that had been prepared. I a
d 12 think in one instance sy participation went beyond that. It E
=
s 13 had to do with the applicability of the compaction require-5 ments stated in 3he ?SAR to the diesel generator building l 14 15 area.and the consideration that these requirements should 5 .
3 16 no longer be applicable because of the placement of the l g 17 surcharge fill. I phrased some parts of that responso--in u
=
, $ 18 ' fact, I think much of that response was taken from some of
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y 19 the commentn I =ade at meetings with the NHC and I believe 5
20 that phrasing goes a bit beyond changes in the language.
21 3T MR. JONES:
22 C What was the reason that you felt the compaction 23 requirements were not necessary to be i=plemented because 24 of the surcharge?
25 A The surcharging of the fill had proved the ALCERSON REPORTING COMPANY. INC.
i 156 11 14 I capability of the site to carry the loads without settlement. )
2 MR. JONES: Off the record. l (Discussion o'f the record.)
4 Back on the record. -
MR. JONES:
3 BT MR. JONIS: :
3 6 Dr. Peck, I will show you what is the answer to ,
CL R
7 R
- Question 4 and ask you if that is the answer you are re- !
n
- 8 5 ferring to. It starts on the previous page.
J d 9 j A Tes, that is what I am referring to.
6 10 Dr. ?eck, were piezameters installed in the g C
=
5 11 ' diesei generstor building area prior to the surcharge g
d 12 j operation in January?
I: 13 ji A Yes.
E 14 y C. What was their purpose?
^
2 15 A Primarily to =enitor the behavior of the subsoil
=
16 during surcharge.
y 17
'4are the piezameters sealed . in individual single a C
=
' E 18 l = : layers in the plant fill soils? '
5 19 f
l A fes. ,
20 Dr. Peck, I will new show you whst has been C
j 21 labeled as " Supplemental Table 27-1." The document is 22
" Supplemental Information' to Question 27" so it is a 50-54(fl 23 response. ItisRevision6submittedinApril19-}0. I 24 would ask you to look at that table. My question is was 25 that table the basis for your answer that piezameters were 4
ALDERSON REPORTING COMPANY. INC.
157 11:15 1 sealed in individual single layers?
MR. FARNELL: Are you asking whether he relied 2
3 on this or this is the sole substance of his information?
MR. JON3S: Yes. I am asking whether he relied i 4 i i
o 5 on that diagram as all or part of the basis for his answer.
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n M
j 6 A I relied on it for part of the basis for my
. Q 7 answer.
3! MR, JONIS:
E, S J
= 9 C What else did you rely on in reaching your answer? :
I i
h 10 < A Information in the report, in a report prepared l 1
5 j 11 , by Mr. Donnecliff describing the instrumentation installa-a i i 12 tions. !
,5 j 13 Q Do you know whether borings.which were drilled to l i
=
n g 14 install piecometers included sampling and descriptions of E 15 soil types encountered in the borings?
=
j 16 A My recollection is that in genersi they did not, s
d 17 C Again refe ring to Table 27-1 in the supplemental f i s
5 18 information to Question 27, I would ask you to look at the n
g 19 , last column, which is labeled " Soil type near tip of pie-n 20 somete'r."
21 A 7es, t
22 C My question is do you know how the information in 23 that colu=n which describes the soil type near the tip of 24 the piezameter was established if the sampling was not taken?
25 A Tes. In my previous answer I assumed core to your ALDERSON REPORTING COMPANY. INC.
l l
158 ' l 11:16 l' , question than you asked. I assumed that you were talking ,
l 2 about a complete sampling of soil profile through each 3 boring and that was not done, I think. The descriptic=s 4 given in some of these borings are taken, I believe, by e 5 extrapolation from nearby borings. Indeed it says that in n
j 6 Note 6 on the last page of the table. ,
R i
$ 7 C Eave you checked the logs of adjacent borings and i j 8 the results of the lab soil tests to reach a correlation d
2 9 with the soil types listed in the last column of Iable 27-1?
z,
@ 10 MR. ?13Y3LI.: Objection. Compound.
z 11 h A No, not for each piezameter.
m j 12 3! MR. JON3S:
=
h 13 , C Eave you checked the logs of adjacent borings i
= .
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I'4 and the results of the lab classification soil tests to [
}=
15 < reach an a greement with some of the identifying soil types l j 16 on Table 27-1. !
i l N 17 A I have checked them. I am not quite sure what i
d l 3 I8 , you mean by "to reach antagreenent" with it. I didn't check'
- , i "s 19 , them with a foregone purpose in sind, then, to reach an n <
20 agreement or disagreement.
21 When you referred to extrapolating infor=ation 2
22 from nearby borings to reach the soil type, what does that 23 process involve?
24 A I didn't do this extrapolation so I des *t know hew 25 l 1 it was done.
l l
l ALCERSON REPORTING COMPANY. INC,
l 1
i I' l l 159 l 1
11:17 1 'l Do you know, in your professional expertise, a :
1 method of extrapolating :
2 3 :G. ?AR:r!.:L1: Objection. Calla for speculation.
4 A 'fes.
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- ALDERSON REPORTING COMPANY. INC. ;
160 12.1 1 Continuing that answer for a moment, Table 27-1 2 states that the soil types of piezometers 1 through 16 are 3 estimated based on the nearest borings, but doesn't say any-1 4 thing about the others, how that was arrived at. I g 5 Q. Yesterday you testified as to the variability of a
j 6 the soils at the Midland site. Would that variability place R
S 7 any doubt in your mind as to the accuracy of the extrapolations p
! 8 with respect to the soil type in which the piezameters were 9
)
located?
10 y A. Yes.
=
' Q. Would it be extremely difficult to extrapolate, d
12 i based nearby-borings because of that variability?
4 I3 A. It would not be difficult but it might be inaccurate.
E 14 id Q. Would it surprise you to a check of information of w
15 -
g nearby borings would indicate layers and lenses of sand within 16 l
the depth of most piezameter pmza tubes?
17 d A. No.
=
5 18
- MR. FARNELL
- Objection. Calls for speculation.
5 19 '
] BY MR. JONES:
20 4 Idit us asst.me that a piezameter pozma tube, approx-21 imately two feet long, is placed in a five-foot thick zone of 22 pervious sand, which is founded in an impervious clay layer, 23 with less than two-inch pervious sand layers within the five-24 ~
foot interval. What is the likelihood that the pore pressures 25 i measured in that piezemeter installation would accurately ALDERSON REPORTING COMPANY. INC.
161 1202 1
reflect the pore pressure in the impervious clay level, and, 2 of course, you can have it repeated. I have it written down
- 3. if it would be easier to read it back.
4 A. Please.
S 5 Q. Let us assume that a piezometer porcus tube, approx-l'i j 6 imately two feet long, is placed in a five-foot thick zone of R
~
"- 7 previous sand, which is founded in an inpervious clay layer
$ 8 that has several thin, pervious sand layers within that five-
^
9 foot interval. What is the likelihood that the pore pressures
?.
@ 10 measured in that piecometer installation would accurately E
!a II reflect the pore pressures in the impervious clay level?
d 12 Objection. Speculation.
i MR. DARNELL:
~~
- 13 g And I don't know if it has encugh facts upon which E 14 ti a reasonable answer could be made, u
.: 15 j A. The pore pressure in the clay zone would be accurate-l 16' l 17 reflected after a period of time, following the time when
-@ 17 3_
externa]: 11tions became constant. That is after the
$ 18
= surcharge t been in place for a certain period of time !
l E 19 adjustments would take place so the pore pressure would be A
I 20 ,
correctly reflected. !
j 21 MR. FARNELL: I will state for the record, I dcn't ;
1 22 1 think the questien had anything to do with the surcharge and j 23 that is part of the reason why I think that questien is i=-
24 proper.
25 ;
1
' 3Y MR. JCNES:
ALDERSON REPORTING COMPANY. INC.
162 12.3 Q. Absent the surcharge would the piezemeter accurately 1
2 reflect pore pressures in the impervious clay layer?
3' A. Yes. It is the requirement of constant conditions >
for a certain period of time, constant external conditions.
4 2 5 Q. Is it possible that the major reason that piecometers n
6 at the Midland. site never reflected anticipated levels under 7 the surcharge flow was because the conditions that I have 3 described, predominantly existed?
- J
~.
9 MR. FARNELL: First.ofcall, that question calls for E
10 speculation. Second of all, it assumes a statement as to the g
=
II piezometers never having reached anticipated levels, which I a
i 12 ,
z don't recall.
m
- 13 . MR. JONES
- I think we have documentation that Dr.
= i I
$ 14 d Peck- l
= l 9 15 MR. FARNELL: It might be a nice idea to bring it i
'l j 16 out.
M 17 BY MR. JONES:
l C
, = ,
i 5
=
18
- 4. Dr. Peck, did the piezometers every reach the anti- :
I 19 l r
4 cipated level under the surcharge?
l l' l
20
. MR. FARNELL: Objection, to anticipated. '
- 21 4 3Y MR. JONES:
22j Did they ever reach the level you anticipated they Q.
23 would on this surcharge?
24 A. They never reached the maximum level--I would strike 25 t
that and say no.
ALDERSON REPORTING COMPANY. INC.
1o3 ,
12.4 1 4 Is it possible that the ma*or reason that the 2 pie:cmeters never reflected your anticipated levels under the 3 surcharge load at the Midland site is because the condition 4 I described in the previous questien eculd not have existed?
u 5 A. No.
R :
j 6 4 Would pie:cmetric pressure still be correct if the i R
=
" 7 sand tras permitting drainage to outside areas, in the area j 8 that I have described?
9 Is this a hypothetical, or what are
~. MR. HARNELL:
3 10 f we doing?
=
!a II MR. JCNES: I am referring to the previous question
- i 12 '
E which was a hypothetical situation.
4
- 13 i A. That would depend on the circumstances. I can't
! $ 14 l id answer that one flatly.
l 4 r 15 l j 3Y MR. JONES:
16 l 4 'What circumstances would affect whether or not the i 17 3 drainage would affect the pie ometer pressure accurately?
c a 18 A. That's not the same question. New you are talking l C 19 l A about drainage and a moment ago you were talking about-I have 20 forgotten how you stated it.
21 4 Let me restate it. I said would pie:cmetric pres-22 sures still be correct if the sand, which I have described as 23 the thin layers of sand in the hypothetical, were permitting 24 .
drainage to cutside areas?
l A. If they were meaty permitting drainage the answer ALDERSON REPORTING COMPANY. INC.
I i i 164 12.5 1 could be yes.
2 Q. When you stated that the piecometers did not reach ,
3' the level you had anticipated at :.te Midland site, what level 4 did you anticipate that they would reach, or approach?
g 5 A. I had rather expected that the pie:cmeters would show N i j 6 sometHng like a five to fifteen-foot rise. ;
a l 7 Q. How did you arrive at that level? I n
i A
8 A. The maximum level to which they could have arisen
" l j
9 had there been no drainage at all, would be a height corres-s 5
10 pending to the weight of the fill which I think was on the 1 2
g 11 order of 30-odd feet. I don't remember what the number should '
d be, now. I expected the piecometers to :ise a half of that 12 E
, 4
= 13 i i height, most likely. i E
id 14 Q. What information is available to you that demonstrates
- i 9 '
15 j that the plant fill was saturated when the surcharge load was 16 j applied in January of 1979? ,
-i 17 a
=
A. I know of no such information. ;
18 Si g MR. JONES: Ist's take a five-Minute break. l t
- 19 (Thereupon a short recess was had.) t 4 9 20
- MR. JCNES: Back on the record.
21 THE WITNESS: In that last question when you said 22 saturated I' assumed you meant saturated 100 per cent?
23 MR. JCNES: Yes. ~
24
] THE WITNESS: 0.K.
25 :
1 BY MR. JONES:
ALDERSON REPORTING COMPANY, INC.
i 165 12.6 I 4 Dr. Peck, do you believe the soils were saturated i 2' when the surcharge was placed? f 3 When the surcharge was placed?
A.
4 Q. Yes.
e 5 g A. I believe the soil was practically saturated.
3 6 Q. What information leads you to believe that it was R 7 practically saturated when the surcharge was placed?
3 8 A. That part of the soil belcw the water table was
}a 9
y submerged and the degree of saturation below the water table is E 10 E 100 per cent in those soils.
5 II
$ Q. Dr. Feck, earlier you referred to the compaction i 12 5
requirements in the Midland PSAR to which you stated that the 3 5 13 E 50-54 question 4 resonses, you participated in their prepara-E 14
$ tion. Is your response, as you described it in Question 4, 2 15 s does that suggest that the surcharge approach no longer re-g 16 a quires the compaction requirements in the PSAR to be met?
j
- 17 '
s A. Yes.
i E 18 E Q. Is it your position that the fill beneath the y 19 M 1 diesel generator building is now equivilent to, or better than 20 the compaction requirements which would have resulted had the 21 fill orginally compated to CTM 1557 Method D?
22 A. May I have that back, please.
23
! (Thereupon, the last question was read by the re-l 24 porter.)
ALDERSON 9EPORTING COMPANY. INC.
i 166 i 12.7 , MR. FARNELL: I would object to foundation. I !
1 think you have to establish that Dr. Peck has dealt with ASTM 2
3 3Y MR. JONES:
4 Q. Dr. Peck, have you ever heard of ASTM 1557 Method D?
e 5
- s i b A. Yes. ,
a 6
7 4 Can you answer the previous question now, please?
A. With respect to performance, yes.
8
$ 9 4 How about with respect to per cent compaction?
i
$ 10 A. It may or may not E
l< j; 4 Would the gn uular soils at the Midland site be a
4 12 compacted to ASTM 1557 Method D?
5 h 13 A. You would not use that unless it was for granular E .
' E 14 soils, i d.
E 15 Q. Would the granular soils be compacted to the originali s
j 16 compaction requirements of PSAR?
=
g 17 MR..FARMELLa I assume you are talking about under
! a -
t =
5 18 the diesel generator?
i 2x 19 MR. JCNES: Under the diesel generator.
i 5
20 MR. FARNELL: I think that has been asked and answer-21 < ed.
22 Mr. Jones: I have not used the term granular soils l 23 in two days.
24 MR. FARNELL: But you used the word soils, which I 25 assume would take in granular soils, among other things.
4 ALDERSON REPORTING COMPANY. INC.
l t
I l
167 ;
12.8 A. They may or they may not. ;
I 2 BY MR. JCNES:
3 Q. Dr. Peck, I will give you a pad of paper and I 4 would like you to sketch the behaviour of a pie:c=eter founded a 5 in the diesel generator building foundation soils, assuming 9
j 6 that excess pero pressure still existed in the pie::ometer at
^
k7 the time of surcharge removal, j
3 n
8 MR. JONES: Off the record.
u 9 (Thereupon a short discussion was had off the
?
5 z
10 record.)
j 11 , MR. JONES: Cn the record.
3 g 12 3Y MR. JCNES: !
~
I g 13 i 4 Dr. Peck, I also show you a pie:ometer versus time 2 .
2 14 , chart for piezometer No. 6, and this is also part of _ Revision l'
{ 15 10 to 50-5h ? questions submitted in November of 1980, and I ,
j 16 ask you to, for the same ti=e period, sketch the action of a s I 17 pie:cmeter if at the time of surcharge removal excess pore j
' 18 pressure still existed in the pie:cmeters. ,
. - i,
! i=
99 j ; MR. FARNELL: I as.Sume that you want an idealized--
0 Yes, I do.
( MR. JCNES:
21 MR. FARNELL: Version, not taking into acccunt any i I 22 l variations that may occur due to the many variances? -
f 23 I MR. JONES: I want an idealized version of what wculd.
24 happen in a pie:cmeter if excess pore pressures were not all I 25 l l ; dissipated.
! i -
} ALDERSON REPORTING COMPANY. INC. :
l l . - - - - - -
i i
168 l 12.9 A. First of all, we will label it horizontal access timei 1
Vertical access will be pie:ometric elevation. I won't put 2
any numbers on this because I don't think that is necessary.
3 I will draw a vertical line representing the time when the 4
surcharge was added and if you don't mind, since this is an a 5 3 idealization, I am going to assume it was added instantly. If j 6
- you want some modifications of that later, we can talk about iti i 7 i
- later. I
! 8 5 I will draw another line representing surcharge re-
= 9
- 5. :noval and, again, instantly. I am going to draw a line repre--
10 ,
i senting what I conceive to be the elevation of the pie:ometric 1
=
p 11 surface, corresponding to the elevation of this piezometer that i_
would have existed if there had been no surcharge. I can see
= 13
~
h a that line to be a curve of this sort. I am going to label it ,
g 2
ase lhe and h parenWsis, R is the piezometMc len1 15 without surcharge. At the ti:ne of placement of the surcharge
- f. 16 3
A there wou2d be a rise of piezometric level above this base
.g 37 a
!= 18 line which you might call a blip on the curve. I will draw the first blip, which I will shade for the condition of com-
{ 39 A
20 plate dissipation during the surcharge period.
I will draw another line which I will dash, which I 21 22 will be one corresponding to less than complete dissipation 23 after the surcharge period. I would have to draw it more some-.
l 24 thing like this, higher than the first one because f* the re 1
25 were not dissipation in this period there would-have been a ALDERSON REPORTING COMPANY. INC.
l I
169 ;
I 12.10 I higher pore pressure to start with and it would approach the 2 end of the surcharge in some fashion as indicated by the dash 3
line. I will stop the diagram at the end of the surcharge 4
period, as that is in compliance with your question.
E 3Y MR. JONES:
.4 Q. Could I now supplement the question and ask you to E
continuedthe dash line for a period beyond surcharge removal? '!
n .
- 8'
]
A. If the surcharge was removed, again, instantaneously
- 9 j there should be a decrease in pie:ometric level of a magnitude E 10 i that would probably be of the same order as the peak positive
= '
i 5 11 j pressure under surcharge. Then a return in some fashion, i
-4 12 i approaching the barr: line again. !
-e 5 13 '
3 Q. On the plot you have sketched,in red pen, so it can ,
E 14 !
$ be identified easily, could you indicate the influence of pond i
! 15 seepage on piezometer readings? If you can do it on that s '
T 16
$ sketch.
p 17 y A. The influence of pond seepage is expressed by what
$ 18 5 ,
I have drawn as the base line. ,
C 19 i A MR. JONES: I wou1ld now like the reporter to mark i 20 j this as Peck Exhibit 5.
21 (THEBEU20N A SKETCH WAS MAHMED BY THE REPORTER 22 AS PECK'S EXHIBIT NO. 5 FCR II:ENTIFICATION.)
23 3Y MR. JONES: ,
24 Q. Dr. Peck, I now show you a diagram from Kane. Exhibit 25 ,
No.12, and it is labeled Midland Plant Diesel Generator ALDERSON REPORTING COMPANY, INC.
. _ _ . . . ~ . . - _
170 12.11 ;
Building, Pie =ometeric Elevation Versus Time", and it is for piezometer No. 40. It has two red marks on it. !
t The question I would like to ask you about that diagram, during the months of May, June and July 1979, when 4
" *"' * *** * 'E *EE * * *** *** E ##
.e 5 4 increase in the piezometric elvation, the pie =ometer elevation?!
$ i 2 A. In that period frca 1 May to 31 July this piezometer
" I indicated a rise in pie =ometric elevation. !
g
$ 9 Q, 51d you anticipate this kind of behaviour for the i
$ 10 pie:ometers during full surcharge load?
E j gj MR. FARNEII: I think he testified as to this a
.i 12 piezometer. Your question was improper that you assumed the 5
3 13 answer for all pie:ometers. ,
E E 14 MR. JONES: I believe my question was, did you a t t:
! 15 anticipate this for any pie emeter. ;
! M . i 16 , A. I would like to answer that yes or not, but I don't a
W i g 17 think I can. I didn't anticipate this for the pie =ometers in -
5 l 5 18 general. It doesn't surprise me that this pie =ometer might ,
E -
$ 19 show it.
n l 20 ' 3Y MR. JONES. ,
21 Q, In general, would you have anticipated a further 22 decline in pie =ometer elevations as pore water seeped from 23 the soils do to this surcharge load?
~
24 A. Yes.
i 25 Q. I ask you to look at the other graphs of pie ometers '
ALDERSON REPORTING COMPANY. INC.
. - . - - . . - ~ ~ . - - - .- . - . . - . - . ..__ .. , - . - - - . .
I E
171 12.12 L in Kane Exhibit --I ask you to look at the other piecometer f
2 tables in Kane hhibit 12, and ask f you could indicate on i 3 those graphs by making a red mark where you feel seconda.~/
4 consolidation was reached?
e 5 MR. JONES: Off the record.
i 9
j 6 (Thereupon a short discussion was had off the ,
- h
! 7 ,' record.)
[ 8 MR. JONES: On the record.
I a
- 9 3Y MR. JONES:
i
- 5. '
l 10 4 For piezometer No. 30, would you indicate on the
~
4 II ;
time-elevation graph, would you state which day on the time-n d
12 elevation graph is approximately when the secondary consoli-E h13 dation is indicated? l
' 3 14 3 MR. FARNE E: I am going to object to this line of l
E e 15 questioning. I think Dr. Peck has testified that ycu need to
, g .
i 16 j look at more than one piezometer in order to make a determina !
- 17
- s tion such as secondary consolidation. By asking questions j
!= 18 such as this you are tempting to get some misleading answers.
5 19 j MR. JONES: Off the record. t 20 l
, (Thereupon a short discussion: was had off the 21 record. )
22
~ MR. JONES: On the record.
23 MR. FARNE E: I4t's hear the question back,
~
j 24 l 3Y MR. JONES:
1 25 l 4 The question was, could you indicate on pie:cmeter--
ALDERSON REPORTING COMPANY,INC.
_ _ . _._.. _ _ _._. -~ . , . _ _ . . . ~ _ __ , - .
i 172 12.13 1 the graph for piezometer No. 30, where you feel secondary i
2 consolidation was reached?
3 A. I can indicate it en this graph but only because 4 I have other infomation, also, I don't believe one can tell g 5 from this graph, just this graph, where secondary censolidation-3 j 6 begins.. '
R
- i
" 7 Q. I4cking again at the chart and time for pie::ometer n
l
$ 3 No. ho, can you explain what caused the decline in piecometric d
9 level after the surcharge removal? !
?.
5 'O A. No.
- 5 II 5 MR. JONES: Off the record.
a 12 E
~
(Thereupon a short discussion was had off the 13 '
h record.)
n ,
I4
!=
~
MR. JONES: On the record. l-9 15 :
2 3
3Y MR. JONES: ;
j 16 Q. There is a mark that indicates when the surcharge I
" 17 d was removed, and there is a decline that takes place immediate-j
= -
j E 18 i
=
17 after that indication. My question is, do you know what l.
I 19 3 caused the decline in piezemetric level after the surcharge :
20 removal, as indicated on that graph?
21 '
A. There are two lines indicating surcharge removal, do 22 7ou mean after the beginning of surcharge removal?
23
, Q. After the first one, indicating the beginnpg of '
24 surcharge removal. '
25 A. Part of this decline may be the reduction in pore ALDERSON REPORTING COMPANY. INC. .
i i
173 l l
I 12.1h pressure, associated with the reduction of the surcharge load. i 2 I would be suspicious of the record in that period and follow-3 ing, because of the subsequent rise to nearly tha same value 4
at the end of surcharge removal as we had at the beginning e 5
- and then another decline. I am suspicious of it, primarily n
3 6
- because I think this is the only pie:ometer that shows this l 5 7 i
- behaviour and of this magnitude. l n i E
8 Q. Is the level to which the piecometer rebounds as it c
- 9 y approaches the indication where surcharge remval was complete, E 10 E is it possible that was being controlled by the ground water .
5 11 s regime as the influence of the excess pore pressure due to the
- ! 12 '
5 surcharge removal?
5 13 l E A. I don't know.
E - !
14
$_ Q. I now show you the chart for piezometer No. 36, !
i E 15 s again appearing in Kane Exhibit No.12. I ask you if you y 16 w know what caused the decline in the piezometric level after l
- -l 17 i y .
the point at which the chart indicates surcharge removal began?:
$ 18 ' ;
E A. I would attributethat to the reduction in consolida- ;
l C=
19 i.
l 5 tion stress, which is creduced by the surcharge removal. ;
20 i ;
Q. Do you know what causes the second drop in piezo- I 21 meter elevation after the completion of the surcharge removal?
l 22 A. The drop that is indicated near the end of Septe=ber?
(
Q. Yes.
24 - !
t
} A. No, I den ' t.
Dl l
l t i
ALDERSON REPORTING COMPANY. INC. ;
i I t
174
- f 4 Could it be excess pore pressure as the level drops ,
2 to the elevation, being controlled by the seepage from the ;
3 pend?
4 A. No. ;
e 5 4 'ihy not?
9 i j 6 A. It could be pore pressure being centro 11ed by the
- l 7 seepa6e from the pond but not excess pore' pressure. '
] 8 4 '4hy couldn 't it be excess pore pressure?
2 9 A. Because the excess pore pressure has long since been
$ i y 10 dissipated. !
z !
3 3
II , 4 If the excess pore pressure had not been dissipated l g 12 could that be an indicatdon of excess pore pressure being
- i l
m 13 affected by seepa6e from the pond?
E -
A. The excess pore pressure is not affected b7 seepa6e !
x 0 15 I h frca the pond. Excess pore pressure is caused by surcharge. ;
z 16 g 4 Dr. Peck, nea$ the end of the chart there is a C 17 t d gradual rise in piezometric elevation. Can you explain this E -
- = 18 ;
g gradual rise in piezametric elevation? ,
t 19 g A. No. l 4 Could this be the development of steady seepage from l 21 the pond?
22 A. It could be associated with seepa6e frcm the pend.
23 4 Do you reccgnize that the pend was essentially at a 24 constant level during this time?
25 A. It may have been. I don't knew.
ALDERSON REPORTING COMPANY. INC.
i
)
175 !
I 13 16 1 4 If that was the case, is it still possible that !
2 the continuing development of seepage from the pond would 3 account for some or all of the gradual rise in piecometric 4
elevation?
3 A. It is possible that it could be associated with some 3
6
~
of that rise. ,
n R 7
- 4 Dr. Peck, do you recall what safety-related pipes !
t n
li 8 and conduits are found in a plant fill near and beneath the
]
- 9 i diesel generator building?
5 10 5 MR. FARNELL: Cbjecticn to the word safety related.
=
5 11 i A. I recall that there are some, d 12 5 BY MR. JONES:
E 13 E 4 Can you identify the types of pipes? I am now ;
E 14 :
$_ referring to purpose, not constitution.
i 2 15 s '
A. I have seen plans of some of the layouts and I have j g 16 l l = seen and heard references to these pipes but I could not
\ G 17 l s detail for you which pipes serve what purpose or what all the ,
5 18 i E l
purposes are. .
I 19 A . 4 Dr. Peck, do you Ictow what is ther range and elevation; 20 at which most of the Category 1 pipe inverts were placed?
21 A. No.
22 l 4 Dr. Peck, do you have any information with respect
! 23 l to past project reports that would show the behavious of, piezameters at the time of surcharge removal?
l l ALDERSON REPORTING COMPANY. INC.
l l
l
4 i
176 l 13 17 A. I don't understand that question. ;
1 ,
I Q. My question is, do you have any reports or studies l
1
- 8 * * * * *" * * * *~
3 haviour of pie ometers at the time of surcharge removal?
4
. cu man any pmjects 4n . general? ,
e 5 b 6 h general. ;
- I
{: 7, A. Tes.
i What reports would contain that information or f8 Q. !
N 9 studies?
i
!E 10 A. I suppose the oldest one might be the one in Cleve- ,
! 11 land that I mentioned yesterday. You will find a published a
d 12 version of Ter aghi's report, T-e-r-::-a-g-h-1, on that project,i z ;
I 13 that he wrote in 19h8 2 which not only the piezometric results ; -
a E 14 are given on load removal but a theoretical explanation as to i N ,'
C i
! 15 why it did what it did. It is published in the so-called ;
E i j 16 Terzaghi anniversary volume from theory to practice in soil j
- i g 17 mechanics, j a t
= '
E 18 There is a very goed set of records of this kind ,
5 .
in a paper in the Conference on Pore Pressure and Suction e.nd
{" 19 20 Soils.. I think the senior author of the paper was Gibson.
21 Q, Do you know about what year that conference was?
l 22 A. I think in the 1960 's. There is a published proceed-23 in g that you should be able to find, that dealt with loading l 24 and unloading some tanks. There is another rather similar 25 paper and a ve:/ good record, one of the authors being Marsland' .
i ALDERSON REPORTING COMPANY. INC. '
l
I i
1TT !
i 13 16 In the European conference proceedings on soil 1 i 2' =echanics and foundati:n engineering, that was held in 3 '4eissboden.
J 4 4 That is in '4est Germany? ,
5 j A. Yes. '
n 6
3' 4 Do you know the approximate date that took place? l R
=
7
- 1 That was probably in the '60 's, also.
n 2 8' n 4 Dr. Peck, would you have any cencern for the integ-0
- 9 g r107 for the pipes under the diesel generator building if they
-A 10 '
5 were initially installed in compressable foundation =aterial?
E 11 g 2. FARMELIa Cbjection. Iack of fcundation.
i 12 <
j 3Y M. JONES:
13 5 4 I am referring to concern during the period of sur-E i4 i
charge., for those pipes.
E 15 '
j A. That is the enti of the questic'
?
3*16 4 Yes. l'
@ 17 s A. Do you want to give it to me again? ,
$ 18 ' ,
5 4 If pipes were installed in a compressable foundation l 19
! material under the diesel generator building, would you ever i 20 ,
have any concern for their integrity as a result of the sur- !'
21
- charge operstion?
22 E. FARNELI4 Cbjection. Iack of fcundation.
23 A. No. -
24 B BY 2. JONES: '
25 ,
4 '4hy not?
ALDERSON REPORTING COMPANY. INC.
1 l
178 l 13.19 A. The only condition I could think of that could cause !
1 a distortion of pipes under those circumstances would be an valing f the pipe and pipes are very tolerent to ovaling.
3 Q. Couldn't differential settlement be so large in those l 4 .
i l
soils as to cause overstressing of the pipes? -
g 5 ,
" Calls for speculation.
MR. FARNEII: Objection.
6
( A. If, indeed, there were differential settlement and f 7 i if it was large enough, it could cause-it would cause stress !
3
$ 9 ing in the pipes, or would cause overstressing. '4hether over-i
$ 10 stressing would be of any significance, would depend on the ;
E g
< n circu= stances. l i
3 '
Q. At the Midland diesel generator building, prier to d 12 E
=
s 13 placing the surcharge did you make any invesitation as to wheth-E 14 er or not the pipes might be overstressed because of differen-d
!a 15 tial settlement during the surcharge? i i
=
16 A. No. l 3
f i 17 Q. Do you know if Bechtel made such a study or inves- ;
w x I
!ii 18 tigation?
=.
1 A. I think they did.
}R 19 ' ;
20 ,
Q. D'.d. you ever see the reo:lts of those? That inves- l l
21 tigation? '
22 A. I don't think so.
23 Q. Do you know who prepared that investigation?
24 <
A. No.
25 Q. Dr. Feck, I believe you said yesterday that you had ALDERSON REPORTING COMPANY. INC.
1 i
l 179 23,20 l 1 estimated that settlement daring the surcharge would be from 2 six to eighteen inches, is thatecorrect?
3 A. No, that is not correct.
4 Q. Did you make an estimate of what the range of settle-g 5' ment might be during differential se.ttlement, during surcharging n
j 6 prior to placing the surcharge on the diesel generator building?
R
- 6. 7 A. Pardon?
N j 8 Q. Prior to placing the surcharge on the diesel ' genera-J
- 9 ter building did you make an estimate of the range of settle-
?.
5 10 ment which could be expected during the surcharge?
II
! A. I made an estimate prior to placing the surcharge, a
i 12 3 yes. ,
a l3 13 Q. 'nhat was thr.t estimate?
14 The estimate was that a range of six to eighteen 3 A.
s 9 15 g inches would be pessimistic. ,
7 16 j i Q. What was the basis for arriving at that range?
" 17 d MR. FARNELL: This has been asked and answered. We
=
5 18
=.
went into this in detail yesterday.
E 19
) l A. Part of the basis, and a principal part, was the 20 knowledge of differential settlemer's and total settlements 21 that had occurred during the period when settlements were ob-22 served en the portion of the building that had been constructed.
23 3Y MR. JONES: -
24 Q. Ecw did you take that information and use it to 25 arrive at this six to eighteen range?
ALDERSON REPORTING COMPANY,-INC.
~. , . - - . . - . _ . - ..
i i
180 1 13 21 MR. FARNELL: I don't think he testified that he used it exclusively. That question implied that and it is inaccurate.
3 4 MR. JONES: Ha said he used it and I asked how.
e A. Do you want my mental process?
5 I
y 6 BY MR. JONES:
a 7 Q. Yes, if you can.
- ; i
.. j 8' A. It went something like this, and I think you will !
n N 9 appreciate that the question and the approximate answer were I
E 10 separated by an interval of maybe 15 seccnds or so. ;
i j
a jj The settlement of the building on the average have :
I 12 been, I think, about two and a half inches. mat was caused, i
E ,
3 13 I believe, by the settlement of the fill under its own weight. ;
Ei i l
1 E
if 14 , mere might have been, say, 20 feet of this fill participating l l e '
i 0, 15 in the settlement, more or less. We were talking about a sur-li l g 16 charge of about 20 feet. mesurchargewouldbealeadappliedj i 17 over the entire area, therefore that entirs surcharge lead would i
si 18 affcet and cause settlement in the entire 20 feet, more or less, 3 i
$ 19 ' of subgrade. The settlement of a fill under its own weight l 5 l l 20 l and its unit weight was probably about the same as that of a j 21 surcharge. It would be about a quarter of that, that the same 22 fill would experience under a surcharge of the same total
~
.3 magnitude. Four times two and a half is about ten. The settle-1 24 ment had not quite stopped so ten isn't quite large enough, !
25 so the average settlement might be something more than ' ten I ALDERSON REPORTING COMPANY. INC. l
l ,
, 181 !
13.22 1 inches and I thought the differential would be probably, the 2 error in that and the offhand calculation, might be consider-3 able.
4 So with ten inches plus as a central point, I arrived e 5 at about six to eighteen inches.
R j 6 BY MR. JONES:
,- i
& 7; Q. Are you aware that this six to eighteen inch estimate;
~ :
I
$ 8 of the range of settlement resulted in Sechtel's decision to J
9 disconnect the condensent line between the deisel generator 5
@ 10 building and the turbine building?
E 5 II A. I am not aware that that was the reason, thi sole
! a g 12 reason.
s 13 5 What maximum settlement actually occurred under the a
5 I# sufcharge at the diesel generator building?
G 15 I think about five inches, but that is just my A.
16 3 present recollection.
17 Do you have any explanation for the difference be-l "d Q.
E 18 ' tween the six to eighteen inch prediction, particularly since
{*
19 l ten inches you indicated a few moments ago was a central point,,
20 and what actually took place as a maximum settlement?
l '
l 21 MR. FARNELL: It was an estimate, not a predicticn, 22 and it was pessimistic which he testified.
23 MR. JONES: I am sorry, I meant estimate.
~
24 A. Do I have an explanation? I thought it was a pretty 25 good estimate.
1 ALDERSON REPORTING COMPANY. INC.
i 182 13.23 i I am not even sure you would say there is a dis-t 2 crepency.
3 BY MR. JCNES:
4 Q. I think you just indicated, and I reali::e you were e 5 recreating the 15-second mental process, but your factoring .
A j 6 of what had taken place in the past led you to arrive at a l R
A 7 .
ten-inch possible level of settlement and that you gave it .
j 8' a plus or minus to take account of your error, possible error.
d 2 9 z,
MR. FARNELL: Let 's stop there, let's just let the 5 10 record speak for what it said before.
z I don 't think that is ;
ll ' proper characterization.
3 1 g 12 '
BY MR. JCNES:
3l I 13 '
g Q. There is, therefore, a five-inch difference between a
14 the maximum settlement and the ten-inch central point which
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you indicated was where you started with your estimate.
Iwant{
16 '
, 3 to make sure I understand correctly, you are saying that that n
a 17 3 difference wculd nct be of any significance? i
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E 18 g A. I think you may have misinterpreted what I said. {
19 j When I said a range of six to eighteen inches that didn 't mean 20 , . !
a differential settlement between six and eighteen inches. It 21 '
meant the settlement, thinking in terms of the average settle-22 ment, might be somewhere between six and eighteen inches and l the whole range, including the six inches, might be pessimistic.
24 So I think I am within what I meant by that statement.
25 4 Was the actiement of the diesel generator building
- ALDERSON REPORTING COMPANY. INC.
i
I t
183 l 13.24 uniform. curing the surcharge? !
i ,
2 A. No, it tilted somewhat.
3 Q. 'ihich directicn did it tilt, do you recall?
4 A. My recollection, which may be faulty, is that the e 5' northwest corner settled the least and the southeast corner a
j 6 the most.
R t
& 7 Q. Do you Ic2cw whether the settlement for piping under- l 3 I j 8 neath the diesel generator building was uniform during the J
9 surcharge? '
Y
@ 10 A. I don't knew but I expect it was not.
E
!a 11, Q. Isnt there a differential settlement limit beyond
( 12 which structures and components will be overstressed? l I
E j 13 MR. FARNELL: Objection, compound.
I assume you
$ 14 are talking in vague generalities. '
j=
15 A. First, somebody has to define overstress.
1 f 16 ' BY MR. JONES:
l s ,
I7 Q. I would define overstress as the point at which the h ,
5 :
18 ' structure fails so that it cannot serve the purpose for which 3 ,
n 19 3 it was designed. j 20 That definition I can't buy. I A.
21 I will define overstress as not meeting allowable i
Q.
22
, building cede limits.
1 23 A. That is quite possible, yes.
l Q. Prior to surcharge were estimates of what level of 1
25 differential settlement would cause the diesel generator build--
ALDERSON REPORTING .I h tg W]XW 4
L A
I 184 !
13.2 ing to reach a point of being overstressed, as ? have defined verstressed?
2
. II: Cculd ycu read that one back, please?
3 4
(Thereupon the last question was read by the re-g 5 E0#**#*)
n 6 A. I don't know.
a . j
[ 7
~
3Y MR. JONES: !
Do ycu ::hink such estimates should have been made,
!8 e
4 c 9, in your professional opinion?
i '
k 10 A. No.
E 3 11 Q. Why not?
5 i j A. For at least two reasons. The function of the 12 { -
5 l '
e 13 building is act governed by whether or not allowable stress E
j 14 ' is established by building codes are met, since the building i E
2 15 already had cracks it was obvious that the building code i s .
j 16 stresses had been exceeded. So as far as I was concerned, s '
d 17 as an engineer, I would be interested. in whether the building s
E 18 could serve its purpose after the remedial operations. Stresses 5
h 19 are very poor indication of how a building will actually carry '
5 I 20 out its function.
21 ' Q. Do you feel a nuclear plant should be required to l 22 meet allowable code limits?
l
- U MR FARNELL
- Cbjection. Iack of foundation.
24 A. That is a very bread question and I am cer'tainly D not qualified to talk about most aspects of nuclear plant ALDERSON REPORTING COMPANY. INC.
I 185 l 13.263 safety. If I understand the functicn of the diesel generator 2 building, for that specific structure I would say I think the 3
answer would be no.
4 BY MR. JCNES: ,
a g
5 4 Why for that specific structure would the answer be ;
l 2
6 no? .
n i
R 7
- A. Because if I understand its function correctly there ;-
e
! 8'
" is no reason why the proper perforaance of that structure when
= 9 j it is called upon to serve its function, :nostly to keep the 5 10 i rain off the generators and so cc, would be influenced by a 2 11 '
$ few cracks.
l 4 12 5,
- Q. Do you 'ccw tcday whether the diesel generator build .
E 13 '
E ing and safety related piping have been overstressed because ofl E 14
$ the settlements which have cccurred at the Midland plant? f
~
2 15 s
A. I think I just testified that' it had cracks in it.
g 16
= 4 How about with respect to the piping and ccnduits, y 17 s do you knew whether they have been overstressed, as we have
$ 18 E defined that terms as not :neetir4 allowable ecde limits? ,
t 19 '
A MR. !3XENEII: Cbjeetion. Iack of fcundation. l 20 A. I do not know what pipes that will be used in the 21 future that are safety related, if any, still exist beneath 22 the building.
23 BY MR. JONES: -
24 4 Do you knew, today, of any tolerable limits of total 25 ALDERSON REPORTING COMPANY. INC. ~
D*"OD *D T i mwM o if L 1 1 o
. 1 1
186 ,
13.27 i settlement which have been established for the diesel generator 2 building?
3 A. I den 't know of any.
4 Q. Do you know, today, of any tolerable limits of f' 5 differential settlement that has been established for the n '
j 6 diesel generator building?
n
& 7' A. I don't know of any.
- il
- j 3' 4 Do you know, today, of any tolerable limits of total J
= 9 settlement for safety related piping and conduit that have been
@ 10 established for the Midland plant?
z - ,
)5 II A. I don't know of any.
I y 12 q. Do you know of any practical means for measuring
=
7 13 future settlement of sa.fety related piping and conduits ia !
j 14 I the soil while the plant is in operation?
2 I think there would be several means that would l
f15 A.
j 16 depend upon the location and general surroundings of the pipe II in which you are interested. The answer would be yes.
h 3
I8 ' 4 Can you tell me what method might be used forpipes ,
P j 19 located under the diesel generator building, to measure future ,
i 20 :
settlement?
. A. I think I personally wouldbe happy to know what the 22 settlement of the building is as the principal basis for 23 I
l judging what the settlement of the pipes might be, but if one 24 wanted to know the pipes independently, it would be possible to l 25 I establish some sort of a probe system, somewhat similar to the l
l ALDERSON REPORTING COMPANY. INC. .
1 187 l l 13.28I i l settlement reference points that were in the diesel generator 1 2 building originally, and ca= / out observations en them.
l 3
Q. Did surcharging actually increase the amount of dif-4' ferential settlement as reflected in these settlement markers l placed at the diesel generator building?
' 3 6 i A. I don't know.
5 7i Q. In your opinion did surcharging increase or decrease '
n
! 8' c
the level of induced structural stresses on the buried ccnduits
- 9 i and pipes underneath the diesel generator building?
= t i: 10 i MR. FARNELL: Objection. Lack of foundation. ,
!j 11 A. Could you read that to me ence more, please.
i l
d 12 5
BY MR. JONES:
E 13 E Q. In your opinion did aurcharging increase or decrease I E 14
$ the level of the induced structural stresses en the buried i
! 15 ;
conduits and pipes underneath the diesel generator building?
s , ;
g 16 - ;
e MR. PARNELL: Also compound.
p 17 s A. I don't know, in part because I have the impressicn :
E 18 -
E that some measures were taken to permit defernations, reduce '.
e-e 39 '
5 contact and so on. The best answer is, I don 't know. ;
20 l i
BY MR. JCNES-21 Q. To your knowledge has Bechtel any plans, as of today,'
22 for monitoring the pipes under and around the diesel generator 23 building? . .
24 -
A. I believe there are-I believe it is the intentien ;
25 that monitoring be done but I dcn't know if they have any plans.
1 1 ALDERSON REPORTING COMPANY. INC. ;
l 13.29 188 l I
\
l 1 today. ! i l
i 2 Q. In your opinion did surcharging increase or decrease ;
3' the level of induced structural stresses en the diesel generator 4 building?
g 5' MR FARNEII: I think that has been asked and answer-;
N !
j 6 ed. I 2
6 I
- d. I dCn 't ' cow.
- . i 8 I
$ BY MR. JCNES:
J 9 Do you ha's an opinion as to the extent of cracking
[.
=
Q.
E 10 g which cculd develop in the diesel generator building and still
= 4 h", ,
permit the diesel generator building to operate? l i MR. FARNELL: Objection. Lack of foundation.
- t l 13 A. I have an opinion but it night not be worth much. '
E 14 d BY .!H. JCNES:
E !
v 15 j Q. *dhat is your opinion? ;
16 I l A. My opinion is that the amount of cracking I saw when I
d 17 g the surcharge was on the building, it seems to me wculd not j
$ 18 have caused any cifficulty in operation and it is my impressioni 19
$ that the present cracking is less, that is the by and large j 20 l cracks have closed up-have close partly, at least, en removal !
21
& surcharge. I see no reason why they should increase in size 22 1 j again.
23 Q. In your professional experiences do you ' cow of any ;,
24 structures that have been subjected to the extent of cracking ,
25 i
! because of settlement of compacted fill, that the diesel ,
ALDERSON REPORTING COMPANY. INC. !
(
189 f 13.30 generator building has experienced?
i l 2 MR. FEELL: Could I have that back.
3 ('Ihereupon the last question was read by the re-4 porter.)
g 5 MR. FARNELL: I think your question centains an a
j 6 assumption that the cracking was due to settlement of dif- !
R I
$ 7 ferential fill, exclusively due b that, and I don't think that l N !'
] 8' is in evidence. It is an improper assumption.
d 9 A. I can't think of any, 9
if
@ 10 BY MR JONES:
E ;
!3 1I Q. In your opinion did the aracking in the diesel l y 12 generator building weaken this building with respect to its 5 -
13 ability to withstand static load? !
5 I4 '
MR. FARNELL: Cbjection. Iack of foundation. !'
jz 15 , A. I would say no.
I' d BY MR. JONES:
s II h=
Q. Did the cracking in the diesel generator building l 1
18 !
h weaken the building with respect to its ability to withstand e
19 i-8 i seismic icad, int.your opinion?
a !
MR. FARNELL: Objection. Iack of foundation.
21 A. I doubt it but I don't know. ;
i n
MR. JONES: Let's take a five-minute break. '!
23 !
(Thereupon, a short recess was had.) ;
24 MR. JONES: On the record. ;
25 i BY MR. JCNES: ;
ALDERSON REPORTING COMPANY. INC. l
I 1
190 l i
14.31 4 Dr. Peck, would you say that it is generally de- i 1
sirable to have a geotechnical specialist present at the -
2< j 3
j bsite when fills are being placed in preparaticn for cen-structicn of a heavy concrete structure such as the diesel 4
t generator building?
a 5 A
MR. FARNEE: Are you referring specifically to the b
6l ,
j instance at the Midland site or are you talking in general j
~
7 !
8l with a structure -
J I will read the question, I said, Dr.
c 9 MR. JONES:
i
$ 10 1 Peck, wculd you say that it is generally desirable to have a 1 5 1 5 ji , geotechnical specialist present at s' site'. when fills are being 8 i placed in preparation for construction of a heavy concrete i 12 N '
structure such as Midland diesel generator building.
5 13 ; '
E E 14 MR. FARNE G: Your inflection made it perfectly i l
d.
E 15 ' clear, '
y 1 16 A. If you would include in among your technical special ;
f s
i 17 ists, experienced inspectors of earth-work projects, I would '
E 18 say yes. He doesn't have to be a PhD in soil mechanics.
3 4 19 ,
BY MR. JONES:
20 ; Q. Is it your opinion that the minimum requirement ,
21 : should be experienced with :spectorst?
22 A. I would say that is a requirement.
23 Q. If someone did not have any experience with spectors 24 or had not studied them in an economic sense of expetience 25 would they be qualified to serve as an onsite, geotechnical ALDERSON REPORTING COMPANY. INC.
e 191 ,
1 specialist?
l
. 44.32 2 Excuse :ne, you used the word spectors. i M. FARNELL:
3 MR. JONES: He used the word.
4 MR. FARNELL: He used the word inspectors, I believe.
a 5 THE WITNESS: Inspectors .
3 3 6 I am going to have to go back to that j
}A 7' MR. JONES:
l j ;
original answer. l 8
yl MR. FARNELL: Let's get it read back.
- 9 i, MR. JONES: I thought he said spectors.
E 10 '
5 (Thereupon the following answer was read by the '
j 11 is reporter: ,
d 12 '
I "If you would include in, among. the geotechnical y 13 j specialists, experienced inspectors of earth work pro-
=
ly 14 l jects, I would say yes. That is, he doesn 't have to be 2 15 _
E ,
a PhD in soil mechanics.") I j 16
- BY MR. JONES:
i 17 <
$ 4 Do you have any opinion as to what the minimum E 18 g requirements for such geotechnical specialists should be?
19 l I A. Yes.
20 ;
4 What are those minimum requirements, in your opinion?
21 A. They should have a basic knowledge of those aspects of soil mechanics that deal with fills and compaction require-23 ment and compaction processes, and they should also have field 3
experience on fill placement jobs where he has had a chance to4 g
ALDERSON REPORTING COMPANY, INC.
102 14.33 uti.'.1:e this information for at least a few months, under the l j
guidance of a more experienced man. Cr for somewhat longer if 2,
he has less guidance.
3 4 4 Dr. Peck, would you say that it is generally advisabl -
. 5 desireable to have a geotechnical specialist present at the
~
A j 6 jobsite when performing removal actions such as those that have
- l 3- 7 been proposed for the service water intake structure at Midland?
8' A. I would say it would be desirable that there should N 9 be such a person who can be present at the site whenever the I
E 10 inspectors or others who are actually controlling the work, E
1 think it necessary and who would visit the site often enough l3 11 j 12 to convince himself that he knew what was being done. ,
13 4 Would he have the same minimum requirements as the E
j 14 geotechnical specialist we havedescribed for the concMte E '
E 15 structun?
I l j 16 A. I would think of him as being a somewhat more ex-s ti 17 perienced person, s
y 18 j Q. More experienced in speficially what area?
n
$ 19 '
A. There are so many contingencies involved in this a
20 question it is hard to answer, because you could have an ex- l 21 tremely good man who could do the job who never went to college i
22 but he understands the earth-work game and he has been in it ,
3 1 a long time. Cr you can have a very bright PhD who has had ,
'4 very little field experience but what little he has had means D a lot to him and he understands the problems involved so that .
ALDERSON REPORTING COMPANY. INC.
D**D oo *D'S o $ o
e 4 193 !
14.34; I would simply hate to have to write a job description to 2 accomplish what you want, depends on the man. l 3 4 Dr. Peck, would you say that it is generally de-4 sirable to have a geotechnical specialist present at a jobsite g 5 when a remedial action is being performed such as that pro-j 6 posed for the auxiliary building at Midlanci, Sr.d specifically i
i 7 I am talking about the placing of Caissone. !
I e
j 8 A. Ye:S but I still have a 11tt2 a bit of difficulty with '-
3 a 9 appreciating just what you mean by a geotechnical expert. I
@ 10 think I have tried to indicate that a geotechnical expert does
=
{a II , not necessarily have to be a highly academically educated: per ;
y 12 son, and if we understand that I would say yes.
5
~
13 4 And this person should have the minimum requirements 5
I *. , < that you described for the construction of a heavy concrete f 5 15 ; structure?
~
16 A. I am sorry. :
a[
= l II
_ 4 Do you believe he should have the same requirements E
3 18 as a geotechnical specialist, which we referred to as being 19 ' present for the placing of fills for construction of a heavy ;
"g !
20 ' concrete structure?
t 21 '
A. If we are talking txbout the auxiliary buildinga:d we 22 talling about-23 MR. FARNELL (interrupting): I think we are talking 24 in generalities, not about specifiatlly the auxiliary building,!
25 as I understand it.
ALDERSON REPORTING COMPANY,INC.
i ;
194 14.35 A. (Continuing) All right, if he is in whatever type ;
i of operation is being carried, he should have had some ex-I perience in that t77e of operation. Earth moving and caisson construction are two different things. I e 5
- i Q. Dr. Peck, have you provided any advice or recommen-6 f dation to Bechtel with respect to the effects of dewatering !
n 7 ;
- : I N
8 up n the containment building for Midland?
A. I have had some discussions about this subject.
's 9 i '
MR. FARNELL. I will object to this subject as being
$ 10 ,
i
! 11 i outside the scope of the OM-OL proceeding.
d 12 3Y MR. JONES:
E i 13 Q. What was your input, if you recall, in those dis- {'
S 2
a 14 ' cussions? j l
s i y
15 A. I think the input was mostly to me, as I recall. I ;
16 was told that there was some concern on somebody's part that i 3
zi ,
2 g 17 lowering the water table might induce settlement of the con-s 5 18 tainment building. My reaction was that this would be negli-E gible and area-wide, and hence totally of no real concern.
19 1 20 l Q. Did you provide any advice or recommendations to .
t 21 Bechtel with respect to the effect of dewatering for any other
! 22 Category 1 structures at the Midland site?
23 A. We discussed these effects. When I say we, I mean
~
. 24 3echtel and the censultants, in connection with all of che 1
1 l 25 various proposed remedies that we did consider because dewater-l i 1 ALDERSON . REPORTING COMPANY. INC.
l i l 1
! 195 i -
14.36 ing would be required to accomplish several other remedies l I 1 ,
that we had in mind. We considered those effects from two !
2 , l points of view, one was whether there would be any adverse effect during the dewatering and the other was the benefit of being able to find out what the effects of dewatering were
" during temporary dewatering, if we were considering a pernanent a 6 i system.
" I
- * "88 8 7" * * ""7 * * # '
8 9 as to what you believed the effect would be on those Category
- 9 i
1 structures, that were discussed? l
$ 10 I !
! 11 A. I am sure I did. f 5
d Q. Do you recall what that input was?
12 z ;
=
E 13 ; A. Well, because these discussions were perhaps best j E ,
E 14 ' described at that time as give and take, brainstorming dis- !
4
! 15 cussions about whole remedial processes. ,
s
~
16 Q. In your opinion, Dr. Feck, will the dewatering system;:
3 A
i 17 proposed for Midland cause any settlement cf Category 1 struc-s E 18 tures at the Midland site? ;
a
- 19 MR.FAhNEII
- Objection. Compound.
, n 20 A. Yes.
21 BY MR. JONES:
22 Q. Which buildings will it cause settlement of?
23 A. All of them.
24 Q. To what extent?
l 25 A. Negli;giMe, in most instances.
ALDERSON REPORTING COMPANY. INC.
l 196 j 1 4 By negligible, do you mean less than an inch? l 14.37 2 A. Most certainly less than an inch. For any Category 1l 3, buildings that I can think of--I perhaps should take a icok and 4 see if I knew all the Category 1 buildings are that might be e 5 affected. Shall we do that or can somebody name the buildings a
j 6 so I can be sure I have not misspoken?
l 3
5 7, 4 Your answer is sufficient.
"! 8 Dr. Peck, are you familiar with the term seismic J
- 9 shakedown?
E.
5 10 4, 7,,,
E
! II 4 Would you define what you understand the term >
n "E 12 seismic shakedown to mean, please?
=
{
13 A. I think it means the settlement associated with the I 14 increase in density of the granular or cohesienless material I d
- 4 <
r 15 i 2 during a seismic event.
= !
? 16 ' Would you describe in general, the state of the art 3 4 .
- 17 3 as it exists today with respect to predictions of settlement l
=
f_ , resulting from seismic shakedown? !
E 19 g A. Could you read that back, please? i 20 ,
i (Thereupon the last question was read by the re-21 porter.)
22 '
A. I would say the state of New York is rather rudimen-23 tary and extremely overconservative.
24 '
3Y MR. JCNES:
25 4 Do you have confidence in the accuracy of predicticns-ALDERSON REPORTING COMPANY. INC.
+ - ,
i 197 :
I 14.38 made of the settlement resulting from seismic shakedown based 1
1 l
2, on the present-day state of the art? ,
3 MR. FARNELL: Objection, compound. ;
I 4, Are we getting specific or is in general?
c 5 * . M.,: JONES: General.
N j 6 A. In general I have confidence that the predictions j
- l
$ 7 are overconservative and probably greatly overconservative. ;
p
$ 8 BY MR. JONES:
d 9 Q. What do you base your belief en that these predic-5.
10 i l= tions are conservative? ;
5 3
II ! A. First of all, the predictions of seismic shakedow',
i N 12 l by, at least any method that I have heard of, are based on 4 4 l 13 laboratorytestswhendryrathercarefullyselected, generally!
= i l
$ I single sized samples. These would be materials that when 5 :
lI being vibrated would have no cohesion whatsoever to tend to l t 16 l
g hold the grains together. D11s is a condition that rarely G 17 1 d exists in nature except perhaps in the Mohave Desert or the ;
i ;=
18 '
h
+
Saham , or something of this sort, i
j 19 '
4 Do you know whether a prediction or estimate of ,
20 ' -
l ; seismic shakedown has been made for the Midland site? !
21 ' '
l l A. Tes.
I 22 Q. Did you make that prediction?
l 23 l
A. No.
~
24 '
Q. Is prediction the proper term?
25 A. You can use either term, I don 't object.
ALDERSON REPORTING COMPANY. INg y D
I D D g
198 i I !
14.39 Q. Do you feel that that estimate is also conservative?
A. Yes.
l 3
4 Do you have any personal experience with projects 4
that have been subjected to seismic shakedown?
S 3 g MR. FARNEII: Ycu mean acutal, shook dcwn seismically?
3 6 i MR. JONES: Yes, that is the only way they could be n '
. R 7
- l subjected. j
= l 5 8'
" A. Yes.
a d 9, g 3Y MR. JONES: ,
i E 10 5 Q. And was there action under the seismic shakedown .
=
3 11 j condition; corresponding to what would have been predicted usir4 8
12 ,
j
- i
- the state of the art? !
s 13 l 5 MR. FARNEII- Read that back, please. -
E 14 '
l ('Ihereupon the last question was read by ';he re-E 15 ,
i porter.)
j 16 ,
z MR. FARNELL: By action, I assume you are referring f 17
- y to the settlement? '
! E 18
!! l MR. JONES: Their shakedown. ;
i 19 i -
$ MR. PARNEII: Their settlement. O.K. !
20 A. I don't know what would have been predicted at these 21 i -
projects if the state of the art had been used. The shakedown 22 l occurred before the state of the art reached its present state.
23 BY MR. JONES:
s 24 Q. I believe earlier you stated that the diesel genera-25 tor building would not meet allowable code limits as evidenced ALDERSON REPORTING COMPANY. INC. :
i !
- l 199 14.40 l
<- I by the fact that there are even cracks p:tduced in the build- {
2; ing. Is that correct? l 3 Yes, that would be =y inference, at least.
A.
4 Q. Do you also believe that the service water structure ,
5 at Midland clay not have-may not be able to meet allowable n
5 0 >
code limits?
i
~ " 7 I
, MR. FARNELL: Objection. Iack of foundation. t n
2 8'
- A. I don't know of any.
d h- 3Y MR. JONES:
- 10 E ! Q. Do you have any opinion as to whether or not the f I
5 11 !
g auxiliary building founded up-the portion of the auxiliary l Ci 12 I i_
building founded upon fill at Midland, would meet allowable
$ 11 E code limits? '
E 14 -
MR. FARNELL: Same ebjection. j f 15 y . A. I don't know. 'l
~ - I 16
$ BY MR. JCNES:
$ 17 g Q. Do you have any opinion as to whether or not the .
! $ 18 '
E ring supports for rhe borated water storage tanks at Midland j i I 19 A would meet allowable code limits? l l 20 '
l MR. FARNELL: Same objection.
21 A. I don't know.
22 -
l MR. JONES: I have no further questions.
23 Off the record.
24 ~
(Thereupon a short recess was had.)
25 MR. JONES: Cn the record.
ALDERSON REPORTING COMPANY. INC.
200 :
14.41 3Y MR. JCNES:
4 Dr. Peck, I note that the agreement that you provided l to us this morning expired in recember of 1980. Has that been
- enewed?
A. I am told it has but I haVS not seen it yet.
n 0
4 Do you have, with respect to the remedial actions 2
{.~. 7 taking place at Midland, lead responsibility for coordinating l 8
the vartous consultants hired?
j
$ 9 A. Not to my knowledge.
i
$ 10 4 Do you know what the bearing capacity of these soils ;
E j
3, n, under the dies:a1 generator building is?
i d 12 A. 'I think so, i 5
5 13 ' 4 Can you tell me what it is?
E \
E 14 A. You mean you want a numbe-~' i i
a t
! 15 4 Do you know the number offhand?
i j 16 A. No. ,
vi '
i 17 4 Is it recorded in documents wHch tt2 NRC has?
s !
5 18 A. There are several bearing capacities, I thi:*, record-E :
y 19 , ed in documents that the NRC has. l M :
20 4 Do you know what factor of safety for failure of the j 21 bearing capacity is available under static loads at the diesel 22 generator building?
23 A. I think I do.
- 24 , 4 Do you know what. that is, offhand? ,
25 A. No, not precisely.
ALDERSON REPORTING COMPANY. INC.
4 l 201 l , 14.42 1 Q. Do you ' mow if that number is contained in documents l 2 which have been submitted to the NRC, either in your deposition !
l :
3 or 4 A. (Interrupting} I don 80 think so.
g 5 Q. Is that facter contained in scme document someplace ,
.4 5 0 that you are aware of?
g ;
I 2- 7 It is a document that Dr.Hendron prepared for the A. .
2 8 a attorneys.
d
- 9
.g 4 Does that document have a title?
10 y 4 It probably does but I don't know wha: it is . ,
i 11 g Q. Do you ' cow what factor of safety with respect to
'J 12 >
j bearing capacity, is available under the diesel generator j 5 13 i '
i building for seismic load?.
E 14 ; l!
A. I think so. l E 15 y Q. Would that also be in Dr. Hendron 's document?
? 16
! A. I think so.
!i 17 Do you ' mow if it is located anywhere else?
s Q.
E 18 i
I E ,
A. Not that I ' mow of.
l 19 a . 4 Do you know what that factor 137 :
20 l l A. I don 't remember.
l 21 ! -
- 4 Do you know how the bearing capacity was arrived at
' I 22 for the soils under the diesel generator buildir4?
- 23 A. By calculation.
y 24 _
l Q. Did those calculatbns involve an extrapolation of 25 laboratory shear strength test results?
l } ALOERSON REPORTING COMPANY,INC.
y g -g - p-- g --- ay- y-4 ,m s,
<_w y w v.,,,. y- ,,s v- m r, - , _, , ---
i 202 9 .43 1 A. An extrapolation?
2 Q. Yes.
3 A. I guess I don't quite understand ycur use of the 4 word extrapolation in this contest. ,
j Q. I will ask further questions and come back to it. i
. n ,
j 6 Who do you report to at Bechtel Corporation when a
f7 4 you are reporting your advice?
8 A. I am not sure that I really report officially or !
e e
i
~ 9 ,
formally to anyone except by contractural arrangements as in .
- l H 10 j effect I am working for Harris Burke. That is the understand t}
= I ing. I h
- ! 12 ' .
j Q. Who, at Bechtel, do you have contacts with most 5 13
% often with :sspect to the Midland plant? ,
i E 14 l l d A. Dr. AFiF1. i s
l E 15 1 g 4 Is there anyone else that you come into contact with i6
$ frequently at Bechtel with respect to the Midland project?
Ij 17 ,
y A. Yes, not as frequently, but Mr. Farris and rather l'
$ 18 E rarely with two people that work for Dr. AFiF1. I can 't 19 , -
l n remember their names right now.
20 ; j
! Q. Were shear strength tests used in computing the ;
21 :
bearing capacity for the soils underneath the diesel generator 22 building?
23 l A. Yes.
s 24 . i Q. Were the shear strength test results used in com-25 puting the bearing capacity based en testing of soil samples ALDERSON REPORTING COMPANY. INC.
! 203 !
l 14*W4 directly within the diesel generator building limits?
i i j 2 A. I den 8t know.
3 Q. Do you think the diesel generator building could 4, withstand a design basis or SSE earthquake?
5' g d. Yes.
. A i
- 6 Q. 'nhat is the basis for your statement that the diesel M
i 7; generator building can withstand a SSE earthquake?
n a j 3' A. An accumulation of judgment. .
J 2 9, Q. Would you accept an extrapolation of shear strength 5,
y 10 values for computing their capacity under a building such as !
\
E
!a 11 the diesel generator building if the shear strenth test could !
f 12 50t be conducted on samples taken directly under the building?
E g 13 A. It depends on how the extrapolation is made, a
l' Q. Do you know if any such extrapolations were made 15 incomputingthebearingcapacityofthesoilsunderthediesell
. i l' ' generator building?
ai !
w
$ 'l A. Yes.
I E l
{
n 18 Q. Were such extrapolations made?
h A. Yes. +
l 0 What method was used to make those extrapolations?
, Q. l l
21 A. I don't know, in detail.
l 22 Q. Are you satisfied with the accuracy of the extrapo-lation?
~
I am satisfied with the adequacy of it.
A. ,
25 Q. In computing the bearing capacity for the diesel l ALDERSON REPORTING COMPANY. INC. i
I 204 14.45 generator building would you put more dependence on actual 1
2' borings and tests undsr the building rather than extrapolated l
3' tests, if they were available?
4 MR. FARNELL: Cbjection, what do you mean by more e 5! dependence?
j 6 A. Not necessarily.
1 7 BY MR. JONES: {
) 8 4 Why is that?
e .
9 A. Again, it would depend on how the test values obtained.
z 10l elsewhere were incorporated into the analysis.
i 5 II 4 In the case of the dieselsmerator building at Mid-a 32 land, considering the method of extrapolating infomation from s
j 13 tests outside the generator-the diesel generator building for I
!M a:
computing bearing strength, would you have an'; more confidence j
3 15 i in the results taken inside the building?
. j f" MR. FARNELL: Same objection. i 17 I have more than adequate confidence in the extrapo-d A.
3 5 18
= lations so far but the answer would be yes. ,
" i T 19 3 BY MR. JONES. .
I i
i 4 Dr. Peck, are there any questions that you thought 21 I i I would ask you that I have not asked?
l l 22 >
MR. FARNEII: I am going to have to object to that.
23 A. I never try to guess what an attamey is scing to l 24 .
ask me.
25 BY MR. JONES:
ALDERSON REPORTING COMPANY. INC.
.. e 1 205 14.46 1 4 Now, you have testified as to the variability of 2 the soil at the Midland site. '48uld that variability make 3 it more difficult to extrapola the information, the shear 4 weight value ascertained in tests outside the diesel generator g 5 building for computing bearing capacity?
R j 6, A. Shear strength?
9
. @, 7 4 I am sorry, shear strength values.
j 8
. MR. :FARNELL:
Also, you use the term more difficult, e
8 9 we haven 't got that isolated.
g 10 ' BY MR. JCNES:
z
= i 3 II j 4 More difficult if the soil was not so variable? ,
a j 12 l A. Of course.
E g 13 MR. JONES: I have no further questions.
l 14 MR. FARNELL: I have no questions.
.g 15 , MR. JONES: This transcript will be for signature.
x g 16 w
- 17 3 Subseribed and sworn to before me this day of E
w 18
= i 1981.
j 19 My commission will expire the day of 20 19 .
21 !
22 Notary Public 23 24 .
25 ALDERSON REPORTING COMPANY. INC.
. .- 4 This is :: certify ::a: the attachec ;r:ceecings ':ef:re ne
- ICLIA ?. 72Gi.LCO3'l CO.C4ISSIC;I
- a. . ...,
. . . m a..,.
.r.
., a . e 3 .' .s .c..r.
3 Jan. 14, 1981 Occket : lust er: 50-329 OM, 50-330 OM; 50-329 OL, 50-330 OL
- 2. ac.. ...e . . . s..c..s.,
A lbuquerque, New Mexico
~44.*e held a3 h e.* e i n 3 ; ; e a.* s , 3Cc 0030 this is the 0.~iginal :.303cri;-
thereof f:e ce file of ne : ==135t:n.
Louise Loc'sood e
Official Repce:ar 'Typec)
/c s-,oo ~4A
^
c - - ~
Cfficial Repc.*: r (Signature) 1 i
i i
6 t
s on e lP . LL