ML19345E554
| ML19345E554 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/13/1981 |
| From: | Peck R BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102050145 | |
| Download: ML19345E554 (142) | |
Text
l i
- , 7' ;-
NCC:J.AR RIGCI.ATORY CCMMISSICN [C' 'c,sN l@p_,>
g>lO,, % ,
'<.3, In the . Mat:::ar cf:
CONSUMERS POWER COMPANY : DOCKET NOS . 50-323 OM
- 50-330-CM (Midland Plant, Units 1 and 2) : 50-329-CL 50-330-OL i
l l Deposition of RALPE 3. PECK l
( CACI: Januarv 13, 1980 PA M : 1 - 140
,g . Albuquerque, New Mexico js - ,
gv7 sv:
, g.~ < ,-( <- .
, ., .. < - r t* ' y u _ ';, -
5 %s.,,Y; 7 '
- -o
~l Q %, ~l 1> 'b, % .;
~
4 n . ,/
&b \ '
i l
l
.-U DE%T '
E M 36 L F.
40 0 71. gd d .a.
Ave. , 5.W. Washing ::::. , D . C. 20024 l ~
' Talach==a : (2007 554-2245 j
l i
l 1 BEFORE TIE NUCIZAR REGUIAT01E COMMISSION 2< I l i l
3' In the Matter of: ) Docket Nos . 50-329 OM
) 50-330 OM 4 CONSUMERS POWER CCMPANY )
l '
) 50-329 OL r g 5 (Midland Plant, Units 1 and 2 ) 50-330 OL !
l l
R ) '
l 3
6 E
. [ 7, EPOSITION OF 3ALPH B. PECK, a witness produced l
!a e
and examined on Tuesday, the 13th day of January, in the l l = 9, year of Our Lord 1981, between the hours of 8 o' clock in ,
, i !
O f a 10 the forenoon and 6 o' clock in the afternoon of that day, j z , i j 11 at the Zia Conference Room II, Hilton Inn,1900 University,
- I g 12 ' in the. city of Albuquerque and State of New Mexico, in a l
=
3 13 certain cause, Consumers Power-Company, now pending before l
- I
$ 14 ' the Nuclear Regulatory Commission.
! 15 l g -
16 APPEA BA NCES n
- j 17 For the Nuclear Regulatory Commission:
E
$ 18 BRADIJ.Y JOES, Esq. i I
g 19 ! For Consumers Power Company and The Witness : I n <
20 l ALAN S . FA RNELL, Esq. ,
Isham, Lincoln & Beale, 21 One Nationa1 Plaza ,
- Chicago, Illinois, 60603.
23 ,
~
24 !
25 !
ALDERSON REPORTING COMPANY, INC.
2 I S11111ES 2 'ilETZSS3S: DI?SCT CFCSS #3DQ3g SCFCSS 3 ?.alph 3. Peck, Ph.D. 3 4
g 5 2
j 6 3gg;g;;s a
@, 7 NNE M_APIED_FCE_ CENTI?;CATICN x
j 8 P eck No . 1 93 d
n 9 Feck No. 2 '15 I
E
~
10 z
E 11 3
4 12 Z
=
$ 13 '
E E 14 '
d
^
c a
15 z
g* 16 m
,' Y 17 l a r z E 18
?
19 2o :
21 s 1
22 i
23 24 D 0
( [1 b 1
ALDERSON REPORTING COMPANY, INC.
l i
i
3 j MR. JCSES : By agreement of the parties, we are 2 stipulating that Dr. Peck is testifying under cath and we will 3' have the deposition signed as has been d ne in the past.
4 RA~PH 3. PECF, Ph.C. '
f, 5 cf lawful age, being produced. and ex' 4 .ed on the part of i 3 t n
N f 3
a 6 the SRC, depcseth and saith:'
R 3 7 CIRECT EXA2CSACCN s
n 8 3Y MR. JCNES : l 4
- 9 Q 5 tate your nace fc the recc d, please.
I ;
e i g 10 A Ralph 3. Peck. !
e t-E 11 Q And .vcur address? I 3 I i-12 A 1101 Wars Sands Drive Southeast, Albuquerque.
- i p 13 Q When did ycu begin wc:k on the Midland .c c'ect
> with i
=
x .t l
=
- s 14 respect to the scils? !
i r
= f c 15 A I think it was Septe=her, 1978. !
- a
= !
- s T 16 Q Will .vcu approxi-ata hcw =any hours .vcu scent wc k-
. l i
y 17 ing en the Midland p cject? !
1
=
a
- n 18 A It would be a very rough acercximation, but I wculd !
l -- -
t 19 m think perhaps between 50 and 100, well, that is not a very l n
20 accurate apprcximation. It wculd scre likely be herseen 200 t
21 '
l and 300. i t
22 And during that app cxi= ate 200 c 300 hccrs :nat 1
Q l
23 j <
you have wc ked en the Midland .c cject, hcw nany ti=es have vcu '
t 24 ~
j actually visited the Midland site?
i l 25 l ..
A : believe three or fcur.
ALDERSON REPORTING COMPANY, INC. ;
i
4 i
- 1. Q During those visits , did you actually tour the site :
\
2' itself ?
3 Yes, in part.
4 Q And what else occurred during these visits?
e 5 A Each time there was a meeting at which the condi- ,
R e
6 tions wars discussed and considered. i 19 7' Q Did these visite usually last one day or two days?
E 8 A Cne day.
- 5 N 9 Q What were your responsibilities as you undersand I
$ 10 them with respect to your serving as a consultant on the Mid-E I3 11 land project?
3
( 12 MR. FARNELL: Are you talking about new or any s;Acific I E i E 13 time?
= 1 h 14 , MR. JCtCS : I am talking about his responsibility 15 during the period from September 1978 until the orssent.
=
y 16 A As I understood them, they were to advise Bechtel mi s
17 who was my client of my thinking concerning remedial measures,
=
j 18 particularly with respect to the diesel generator building.
19 SY MR. JCNES:
2 M ,
20 g In the course of advising of 3echtel, did you work on 21
, designs of fixes for the diesel generator building?
22 This depends on what you mean by design.
A 23 Q Were you involved in advising on the details of the 24 fix to take place on the diessi generator building?
25 ' A To some extent on the details.
ALDERSON REPORTING COMPANY, INC.
5 I Q And what details did you advise them specifically 2 on with respect to, let's say, the diesc.1 generator builing?
3 A The manner in which the surenarge might be placed 4 and its general dimensions, the type of instrumentation that 5 would be necessary to sinctor the progress of events following 6
2 , a surcharging, and advice concerning the time at which the 7
5 surcharge might be removed.
A i 8 A Q Now, a .Icment ago you said that you were particular-
-J
= 9 j
ly concerned with the diesel generator building. Did you pro-E 10
$ vide more detail with respect to the diesel generator building
=
3 11 j than with respect to other structures that were having i 12 iE remediai actions?
=
= 13 3 ,
A Yes.
x
= 14 i'd Q Approximately what percentage of your time was spent
=
9 15 j en the diesel generator building?
, 16
, A Of what time?
F 17 d Q of the total time you spent on the project.
=
5 18 g '
A I would judge between 80 and 90 per cent.
I 19 A
Q Cf the remaining 10 to 20 per cent of ycur time, hcw 20 !
much of that time was spent with respect to the remedial acti:n 21 for the service water pump structure?
22 A very little.
23 Q Would the same be true of the auxilliary building?
24 ,
A Yes.
25 Q And the chlorinated water tanks?
ALDERSON REFORTING COMPANY, INC.
l 6 l 1 A Yes.
2 Q Did you personaally perform any test at the Midland i
3 site with respect to the scil? ,
I 4 3 go, g 5 Q Did you request any specidic soil test that had not j n
lll 6 previously been made at the Midland site?
n i R-7 A I suggested some.
X a
3 8 Were they ;aarfc:med?
Q d I
- 9
, .j A Yes.
A 10 j Q What tests were they that you recommended?
iii g
11 A They were pccket penit cmeter tests in one er more ,
- i 12 l i!! test pits. ,
^
- 13 Q And when were these requested?
i I
= i
= 14 t
I d A They were suggested, not requested. .
1 I g i
l 9 15 l j Q When were they suggested?
16 i
l l* A very early in the effort, probably about Cctchtar 1978.
17
!ll Q Why did you suggest these particular tests be taken?
s E 18
=
A secause they would give some indication of the 19 l A 4 variaticn in strength of the fill material as actually placed. g 20 Q Were these taken arctutd the diesal generator buildi:q ?
21 To my recc11ection, one of the pits was in er around A ,
22 the diesel generatcr building, but I am not sure in which pits.
23 1 think there were perhape three at the time that these tests ;
24 . i were made er if they were made in all cf them. l 25 i l '
Q What variation was discovered, if any, via these ALDERSON REPORTING COMPANY. INC.
7 pocket penitrometer tests?
A I don't recall precisely, but I believe the penitra-2 tion readings varied from perh;n a half a ton a square foot to four tons per square foot.
Q Eave you had any meeting or contact with Sechtel si:r e
~
n
" August of 1980 regarding the Midland Plant?
g 6 E A Yes.
} 7 6 Q Eow many meetings?
- s 8 n
d A I don't recall exactly. I should think about three,
- 9 I
b 10 but that can be checked if I kick at a calendar.
~
z j Q Were those meetings, what was the purpose of those 3
.j g2 meetings?
z A Do you mind if I look at my calendar? It would help 13 '
E E 14 me to know. l l N
! 2. JCIES : For the record, Dr. Peck is referring to
, h.
. 15 ,
l s
! T 16 a set of h.'.s own calendars on which he has recorded his 1 5 1 a p 17 activities.
w z
$ 18 A Since August of 1980.
=
19 SY MR. JCNES:
8 a
20 ; Q Yes.
l l 21 A I had a meeting on October 2 with attorneys present.
22 I had another meeting on November 25 with attorneys present a:d I had a meeting p sterday with attorneys present. I'should sy '
23 l
l 24 the purpose of these meetings was to provide information the l
I 25 the attorneys requested.
I I ALDERSON REPORTING COMPANY, INC.
l
8 I
Q In this providing attorneys on information they had 2I requested, did this help in their questions for the depcsitions?
3 I as going to instruct Dr. Pedc not MR. FARNELL:
4 to answer any questions concerning what went on at that mee t-e 5 It is also due to the attorney-client privilege.
- ing.
n 3 6 Let's go off the record.
- MR. JCNES :
R R 7
- (Discussion off the record.)
n 3 8'
" MR. JCNES : Back on the record.
d
- 9 i, 3Y MR. JCNES :
E 10 E Q Do you have any questions the. you feel Consuem: Pcwer
=
5 11 i
or Bechten should ask the NRC experts involved in the soils e
d 12 '
i proceeding bid?
s 13 I don't think I really understa nd that question.
3 A i ,
E 14 i y Q Have you in the past hac' any input to questions to i
15 2
y ,
be asked of the Corps of Engineers or NRC personnel? ,
i T 16 MR. FARNELL: That calls for a yes or no answer, if l $
i 17 l g you unders*m d it.
$ 18
~
I don't understand what you have in mind when you
{t 19 A
A say questions put to these people. What questions sight you 20 '
be referring to?
21 l
SY MR. JONES:
22 Q Perhaps . questions your attorneys, secHtel's or 23 consumer's attorneys were going to ask in depositiers .
24
'~
MR. FARNELL: It is still calling for a yes or no 25
, anrwer, if you understand it.
I I ALDERSON REPORTING COMPA>p wi tyN J. kre
- q. . , - .
(
t i
9 I A I should say no.
2 SY MR. JCES : {!
3 Q In these meetings en Cctober 2, Nove=ce 25, and 4 January 12 in wnich attorneys were present, you stated that j
5 the curpose of these meetings were to provide information ;
3' 6 to the attorneys, do you have any idea as to what they informa-R C 7 tion was going to be used for?
- ll i 8 M MR. FAREG
- It calls for a yes or no answer.
t 'l c 9 A Yes. l z-
- i i
10 4 MR. JCNES : I think the questions are Obvicusly yes e j j
= ;
E 11 +
g no and you do not have to instruct the witness hcw to answer c' 12 z the questions.
~
- 13 5, MR. FARE 2: I can instruct my witness to do what E 14 d
he is suppcsed to do and that is what I as doing.
9 15
@ MR. JCNES: You are not testifying, he is.
16 i
! MR. FAREC: I did not ask his the question. I had i I
G 17
- to clarify the question. And if you do not like it, cut vour l l - i 5 18
- ;: objection en the record.
19
$ MR. JCNES: I think it is on there.
~
l 20 < i SY MR. JCNES: t 21 i Q What do you believe was the purpcse of it? :
4 22 -
MR. JCES : I will withdraw that question. ,
23 t 1
3Y MR. JCES : ;
24 :
Q You stated you do have some idea of what the ,curpcse l i
was for which the attorneys were seeking infor=ation, wnat do ;
ALDERSON REPORTING COMPANY. INC. i
l 10 you understand that purpose to be?
MR. FARNELL: I instruct the witness not te answer 2i on the basis that any information he would have would have 3
been imparted te him during the meetings at wnich the atter-4
- Y* **#* -cresent and,derefore, h b attemyWent g 5 i n l 6 F#i#i189'*
E SY MR. JCES : ,
" 7 Q Wa S pes M on transcr W , U any, have you read n
8
_ 9 w ith respect to the Midland scils proceeding?
z' A I have read scme er all,because I don't knew if I
~
10
=
!< 11 have seen all of Mr. Kane's, some or all of Dr. Heller's, some 3
d CZ' all of Dr. Afifi's. I believe that is all.
12.
5 5
13 Q With respect to the transcripts you read of Dr. .4
~
=
E 14 Afifi, did you disagree with any of the technical ccaments made ,
N i :::
E 15 ' by Dr. Afifi in those transcripts?
E
.- 16 MR. FARELL: I object to that question as being 3
m i 17 infinitely compound and vague, but. I will let the witness 2- t E 18 answer, if he can.
c:
i
)9 A I don't recall any specific disagreements.
X 5 >
t 20 SY MR. JCNES:
21 , o Have you assisted in the preparation of the questiers 22 f or anycne's depcsition?
23 A No.
24 Q Eave yca tsd any discussions with other censultants 25 working en the Midland project relative te past and future ALDERSON REPORTING COMPANY. INC.
11 y
depositions?
MR. FARNELL: W uld you repeat that, please? !
2, .
l (Thereupon the following question was read by tne 3' 1 i
4 reporter:
o 5 "Have you had any discussions with other censultants
~
n n
- 6 wc king on the Midland project relative to past and future e
M 2
7 depositiens?")
5 3' A Perhaps discussion is not the right word, but I n
.4 '
~
n 9 have seen both Cr. Hendron and Dr. Davissen and said seme-z' 6 10 I thing to the effect, "I understand you are about to be i
E 11 decosed."
i 1
3 i 12 SY MR. JCNES:
z Was that the extent of your conversations?
f* 13 Q i l l!: 14 A That was about the extent of it. I 2 15 Q Eave you been requested to provide testinony input a
x j 16 ASLB en the Midland soils problem? [
s i 17 A I have not been requested to prepare testimony as i a ,
=
- i iii 18 yet.
~
I 19 ,
Pe: haps since I am not a lawyer, you should tell me a
~
20 what you mem by precaring testimony.
21 '
Q Eave you been advised that at scme point during the i
j 22 p cceeding you will be asked to prepara ter'.imny?
23 A 'tes.
i
) ,
24 Q Eave you been provided with any statements as to wna:
D that testimony will be with regard to specifically? ;
I l
i ALDERSON REPORTING COMPANY, INC. .
i o .
12 I' A No .
2 Eave you been requested to provide your services Q
3 as an expert. witness for the ACRS, any ACRS hearings on the t
4 Midland project?
3 A Unfortunately, I don't know what is an ACRS hearing n
3 6 a
and what is sc:na other hearing.
n R 7
- Q I will clarify the questien. The ACRS hearing is f
n i 8 I
" t he At;mic Committee en Reactor. Safety, I am sorry, the Advisory j 9
i Ccmmittee en Reactc Safety, i I
E 10 5 They will review the Midland ccerating license prior '
= '
E 11 j to the operating license being issued. My questien is have d 12 y ou been asked to provide any services with respect to the CL, E 13 5 to obtaining the operating license fcr the Midland Plant?
= '
= 14 d
l
- A No.
2 2 15 ;
l y MR. FARNELL: Just for the record, I want to put in 16
$ that the soils hearing is CMOL which means it is Operating F
d 17 i g an order =cdifying construction per=it.. He may not understand ;
$ 18 E that.
I I 19
! $ MR. JCNES: I will ask a clarifying question.
! 20 BY MR. JCNES: i l 21 l
l Q Cther than with respect to the ecming hearing on f
- 1 22 the soils issue, have you been asked to provide any input
- 0: l 1
23 any other p cceeding with respect to Midland? l i
24 .
s
)
A No. ;
25 4
+
ALDERSON REPORTING COMPANY, INC. I i
l I
l i
I 1
13 1 Q cr. Peck, are you familiar with the request of the 2I Corps of Engineers of the NRC for borings to be taken at the !
I 3 Midland site? ,
4 A I knew something about them.
g 5 o Are you familiar with the number of borir.es era t ha'a R
2 6 been requested?
"., 7 A I don't recall specidically what the nu=her was.
j 3 Q I will represent to you that there have been la I
'J !
9 borings requested by the NRC and uhe Corps of Engineers. I will,,
2 O
l 10 ask you this question, based on your professional experience, g {
= ,
4 3
II do you feel that a cost of S400,000 to complete the la borings l i t
" i 12 j requested by the Corps of Engineers and the NRC staff is a
- 13 E
realistic cost?.
E 14 d MR. FARNELL: Can you read that back, please?
i h:
9 15 l 2 (Thereupon the last qte rtion was ready by the z
16 1 3 reporter.)
m i 17 a 3Y MR. JCNES : I
- i E 18 '
= Q And I will add that when I say complete the borings, C 19 g I will include running the consolidation request that had been
~
20 requested on those samples. j 21 MR. FARNELL: I have a question as to what you mean i 22 by ces:. We have had some discussions as to what costs include ;
23 i and I don't tni.s your question is-- l 24 ,
MR. JCNES (interrupting): The cost I am referring ,
i 25 1
- to is the cost of taking la herings and running the tests that ;
i l .
ALDERSON REPORTING COMPANY, INC. .1 i
[- -
I 14 I have been requested by the Corps of Engineers, the NRC on 2 .
samples obtaired c:. those borings.
l 3' MR. FARNELL: And the cost to Consumers Power includ ,
4 ing 3echtel overhead, et cetera?
5l MR. JONES: I ta talking about the cost as in his j
~
6 professional experience and I assume that would include the n
Il overhead in any project.
n E 8 A A I think I would have to say that I really don't d
- 9 j .< new.
E 10 3 SY MR. JCNES:
- i 5
g 11 Q Do you ::onsider the qualty of work, both design and I d 12 I E construction completed for the Midland Nuclear Plant to be of 13 ,
i good quality in your professional opinion?
i E 14 i d MR. FARNELL: I will object.to the foundation. Dere x ,
P 15 '
i l
j has been no testimony that Dr. Peck has worked on anything 16 '
d other than seme remedial soils problem at Midland. Your i 17 g question gces way beyond that. It goes apparently to every 5 18 g l b uilding, every structure, every subcomponent of Midland and 19
$ there is just no foundation for that testimony. I object 20 .
I to it on that basis. l l
21 i BY MR. JONES : l 1
22 ' '
j Q Dr. Peck, do you have any opinion as to the quality -
t 23 i of werk, both design and construction, completed for the Midimd !
24 .
) Nuclear Plant? 4 25 :
MR. FARNELL: Same objection. l ALDERSON REPORTING COMPANY. INC. !
L
15 1 MR. JCNES : Does he know if he has an opinion?
2 MR. FARELL: There is no foundation for the opinion. ;
3 A : have an opinion with respect to those portions of 4 the project with which I have had a close relation. .,
e 5 3Y MR. JCES : .
n lll 6 Q What is your opinion of the quality r.f the work with R
t.
7 respect to the portien s of the project with which you were E closely associated?
5
[.
9 A My opinion is that the quality varies, has varied i
= >
g" 10 ! in hcth with respeet to time and speci fic aspects of the work.
- l II Q When you first became associated with the project >
5 .l i 12 ' in Cctober of 1978, what was your opinion of .the work from j 4 i
- 13 g your chservations of the areas in which you were specifically l 3 14 3 concerneid,_.what was your opinion of the work done on these ;
e i 9 15 2 areas prior to your being ther+? j z
j 16 A could you define .what' you mean in thi.s instance by l
- 17 y work?
- i E
18 Q All right. What is your opinion of the quality of l
_= ,
I 19 I l the soil.! placement that had takan place prior to your being l 1
~
j 20 '
hired on the Midland project? , ;
21 MR. 7ARELL: Are you talking about the whole power pl. ant? Or are you talking about specific parts of it?
23 -
MR. JCES : The soils portions of the projact with 24 which he was closely associated.
25 A Mf opinion, or perhaps you could sr.y it was my ALCERSON REPORTING COMPANY. INC.
l
1 !
16 1
conclusion was that the fill beneath the diesel generator 2 building area and sore neighboring areas was not a satisf actory l 3
fill.
4 Q During your association with the Midland project, i e
j 5l have you come to any conclusion as to what was the cause of l 3
6 that fill not being adequate?
"o r s 7
! A No, I have not.
n 3 8 .
, Q Did you :nake any investigation of any kind to ,
_I 9 y deter:nine why the soils were inadequate? I E 10 i 1 5 A I did not, no. ,
2 11 :
Q Have you read any investigations or studies which -
d 12 z e xa:nined what was the cause of the poor soil?
=
s 13 3 A I have read som documents that were concerned with j 14 the nature of the fill. But I don't recall that they speci-t i 15 , !
fically went to what the cause of the unsatisfactory quality s -
16
(
j
- was.
y 17 5 Q Do you know of any ' stability problems wit.h scils ,
a 18 i
at the Midland Plant other than with placed plant fill?
E
, 19 3 MR. FARNELL: I object to that. That appears to l 20 h e beyond the scope of the CLCM hearing, but if he can z.wer, I will let hi:n.
22 i A No, I don't.
23 BY MR. JCNES: -
24 !
Q Eave you ever, during your association with Midland, l experienced any difficulty in persuading either the cwner or ALDERSON REPORTING COMPANY. INC.
I 17 1 his designers to do so.uthing which you felt was necessary 2 to insure plant safety?
3 A No.
4 Q And have you personally made any kind of detailed i g 5 s'udy of the lab and field data with respect to the soils j 6 problems at Midland or have you relied on briefings by designer R
6, 7 cons truction groups at the meetings that you have described?
A ,
2 s 8 MR. FARSELL: May I have that read back, please? ,
I.
0 I
~.
9 (Thereupon the last question was read by the 5 10 reporter.)
i g "
-3 11
< MR. FARNELL: I object to that as being compound !
" 12 i and also calling for an either or answer which may not be the
- 13 only answer that Dr. Peck can testify to.
j l .
I 14 ~
l t A T!n re are two questions in that question. ;
s '
9 13 2 BY MR. JCNES. i
- r j
16 Q I will break them up. Have you corsonally made a l' 1
- 17 3 cletailed study of the lab and field data with respect to the >
z i E 18 ,
=
w soils problems at Midland? l
" i 19 j .
A I have of some of the lab and field data. ,
1' Nl Q All right, which data have you reviewed in some 21 detail? l 22 A I have reviewed in some detail the various field 23 observations concerning the settlement and pore pressures at 24 ~
the diesel generator building.
25 I have reviewed in less detail some of the sub-ALDERSON REPRTING COMPANY. INC.
m
1 l.
18 I surf ace information in connection with that same structure. !
2 Q You have not done any detail studies of lab and field i 3 data for the other structures that have new been panned for 4, remedial action' i i
e 5 A That is correct. ,
2 j 6 Q Eave you reviewed any of the data for these that you j I
C I. have not in detail?
i
."n i
s 8 A Yes, I have reviewed data in a general way.
u-9 Q New, the second part =f the question, to what extent z-10 have you relied on briefings by design and construction g cups i.
e i
5 II at meetings,at which you have described, to infers you of !
( a -
d
=
12 ' data?
~
13 4 MR. FARIELL: I will object also to that questicn.
i 3 14 E It is compound in enat there may be sny different briefings, ;
i
( =
9 15 !
2 many -
different data. ;
x j 16 i A It would be difficult to answer that question with t
- 17 I have, of course, 3- knowing just what you meant by relied on.
5 18 been informed in briefings and I have accepted seme infornatial i
=
9 C 19 :
5
" and I have checked on the information that seemed to interest l 20 me.
21 Q With respect to the detailed studies of field l
22 observations and pere pressures, and I believe subsurface t
23 detail, subsurface infer =ation that you say you reviewed, 1 -
24 l and also with respect to any of these pc tions of data at 25 l
these meetings which you just indicated that they interested l
ALDERSON REPORTING CO P Y,
1 i I
19 :
l I f
1 you, you reviewed them and you checked them, are you satisfied l 2 that the data that you reviewed was correct?
3 MR. FARELL: I will objec- to that. That is jus t 4 herrendously compound. What data? Cats is just too much, too i
e 5 br::ad. f a
j 6 MR. JCNES : I said field observations, pore pressures, R
^
" 7 i subsurface information and infor=ation which he just defined S 8' a as what interested himin meetings. It is pretty specific ,
-J i 9' fer him, if not for you.
2, s
j to '
MR. FARNELL: It sounds pretty bread to me. !'
= l E 11 '
< A I am generally satisfied that it was either correct
- i 4 jg !
3 i or correctable by making appropriate studies and corre?.ations.
=
= 13 g 3Y'MR. JONES:
E 14 l Were there any areas of data which you reviewed with d Q ,
u 15 g
respect to field observations and pere pressures or subsurrace ;
16 l l infcrmation en which you had any particular problem with the f 17 ,
d data, the accuracy of the data? ,
= .
l E 18 MR. FARIELL: The same objection as before, it being l g
I 19 '
l g indinitaly compound. 4 20 I always had particular problems when I am study 4 ng l
A 9 21 data and usually and:in this case, I think generally .,
22 4 succeeded in resolving the problems.
23 I I 25 ,
ALDERSON RCPORTING COMPANY,INC.
{
20 2:1kjm j BY MR. JONES:
2 Q. To your knowledge did the other consultants, have 3
you had discussions with the other consultants which have 4 been hired to work on the remedial actions at the Midland >
e 5 Plant? l A !
n 3 6 A. Hired is a nasty word.
a 7 Q. Retained?
E 3 A. Yes, L-have had discussions with them. ;
" \
3
= 9 Q. From those discussions do you know if any of the i
E 10 other consultants did any detailed reviews of the data with ,
i
= I g 11 respect to the other buildings? -
a y 12 MR. FARNELL: Objection. j 3
E 13 MR. JONES : Where remedial actions were taking 3
l$ 14 place?
I 2 15 i MR. FARNELL: Same thing, compound. I l
i .
4 y 16 Objection. ,
s
, i 17 A. I do not know.
l 1 :
I $ 18 ' BY MR . JONES :
=
l g
19 ! Q. Do you have any idea as to what your future in-20 ; volvement with the Midland Elant will be?
21 : A. Too extensive. l 22 I presume I will continue to provide requested 23 ' information to the attorneys and I would hope the technical 24 pecple. .
l D Wha't do you view as the areas at the Midland ?lant Q.
I I
ALDERSON REPORTING COMPANY.-INC.. ;
21 2:2 in which you are ultimately responsible for assuring safe perati n the plant?
2 MR. FARRELL: Read that back, please and, then, I 3
will have an objection. :
4 i
f 5,
(Thereupon the following question was read by a
n '
b the reporter:
a 6
"What do you view as the areas at the Midland
"{ 7 8
Plant in which vou are ultimately responsible for assuing safe operation of the plant?")
N 9
$ 10 MR. FARRELL: The-objection is to vagueness. I 1
! 11 don't know what you mean by ultimately responsible for and g 12 there is also a lack of foundation that he is in any way l 13 responsible for whatever you mean by the safe, reasonable E
I lt: 14 assurance or safety of the plant.
1 2 15 MR. JONES : I will withdraw the question.
E.
g 16 BY MR. JONES: j
- I y 17 q. In your opinion why has it been necessary for the j i
! 18 owners and designers at Midland to fortify themselves with 5
19 so many noted consultants?
R 20 MR. FARRELL: May I have that read back, please?
21 (Thereupon the last question was read by the ,
22 reporter.)
23 MR. FARRELL: . Objection, as to foundation. I don't 24 think it has been established anywhere that the owners fortif 25 themselves . I have no idea what you mean by that question.
i ALLS ^.RSON REPORTING COMPANY..INC.. i
l 22 2:3 i, It appears to be argumentative and highly objectionable.
2 A. I think I can- answer the question because I don't 3
agree with the premises, other than they have scme noted
- 4 consultants perhaps.
I e 5 BT MR. JONES :
N li 3 6 Q. In your opinion why has it been necessary for the l a
l R 2
7 cwners and designers of Midland to retain the services of 8' a number of, what we will grant, noted consultants? ,
!! A. I don't know that it has been necessary. I 9
4 E 10 Q. If it has not been necessary why do you believe E
ja 11 that they were retained?
j 12 MR. FARRELL: That, also calls for speculation, his 13' belief as to why the owners and designers retain these es-l l 14 teemed noted consultants.
e E 15 , A. All I know is that consultants were retained.
s j 16 BT MR. JONES:
s y 17 Q. Are you familiar with the term observational :nethod,
! 18 as used in foundation engineering * -
C 19 A. I think so.
g 3 Q. Will you explain the meaning of the term obser-21 vational method?
22 A. I will try to do it briefly.
i 23 First of all, it is a rather flexible method. It i is an approach and it is and should be altered for tiealing f
, 25 Essentially it consists of i
with various kinds of projects.
ALDERSON REPORTING COMPANY, INC. i
23 2:4 determining in advance, at least some information, concerning the the subsurface features at a project and I am talking 2
nly about the observational method in connection with geo-3 4
technical projects. I'm establishing a course of action of, ,
e 5 in some instances, at least, establishing ordinate courses ,
A l 6 of action, if they should become necessary, of making such l
l f7 field observations as will indicate the extent to which the 8 original course of ac2 ion is being verified and making such l '$ 9 changes as might be necessary if the field observations lead l l .j '
$ 10 to the conclusion thae the original course of action should !
5 l 5 11 be modified. l 5
-f 12 Q. Then is it necessary when using the observational E
h 13 method to devise, in advance, a positive means for solving l
5 j
i 14 any problems that may develop while you are using the method?
! 15 ; A. It is sometimes necessary. It is often desirable I E :
j 16 4 and sometimes not necessary. This is part of the flexibility 1 e I
y 17 that is inherent in the method.
E
$ 18 Q. Was the observation method used in surcharging the E
19 diesel generator building?
k 20 A. It was used, although the whole suite of steps tha t l t 21 I mentioned in the general observation procedure were not l 1
22 ,
necessary and were not all used.
23 Q. Since it is a flexible method could you describe i i
24 how the observation method was used, for the diesel ~ generator 25 building? .
I l ALDERSON REPORUNG COWANY.-INC.-- - ;
_B -- *'
24 2:5 A. To begin with, there were certain facts available 3
at the ti:ne that I became involved in the project. There 2
was some information about the. subsurface conditions. Thers 3
was a settlement record and there were scue general require-g 5 ments, p ssibly not specifically stated, but general require-ments about what the future behavior of the building ought to 6
t i
be. In other words, it wasn't necessary to start at the be-7 8 ginning of the complete observational procedure, there was i
l' l N 9 already information.
l i 0.. This information on subsurface conditions the you
! $ 10 ,
11 met.tioned uas present was that obtained via borings?
E d 12 A- S0"* Of it-E
! S 13 The next step was the consideration of various h
l 14 alternatives for providing a satisfactory foundation, and 15 af ter considering these alternatives the surcharging pro-l g 16 cedure was considered to be the desirable one.
, si g 17 Then an observational program was laid out that 5
E 18 would give the necessary information concerning the progress f* 19 of consolidation of the underlying materials and to permL 20 i a forecast of, to permit a, I can't think of the right word, 21 an outside forecast of the settlement that might occur after l
22 the surcharging operation was completed.
23 The observations did, indeed, indicate that the 24 surcharging procedure had been successful so the st tcharge 25 was removed and the foundation conditions were considered by J
ALDERSON REPORTING COMPANY;-INC.
25 2:6 3 me, at least, to be, then, acceptable.
2 Q. When you were using the observational program to s nit r progress were you observing pie =ometer readings?
3 4
i A. They were being observed. I wasn't observing.
Q. Did you at some point review the data from the g 5 6 piezometer readings?
f7 A. Yes, at many points, I should say.
3 g Q. Would the same be true of the settlement markers?
a d
i
= 9 L Yes.
l $
l
. E. 10 Q. Force anchors?
I
.5 5 11 A. Yes.
E ci 12 Q. And the settlement plates?
E a
i s 13 A. Yes.
E j 14 ' Q. In surcharging the diesel generator building what g 15 was the maximum amount of total and differential settlement E
j 16 which had been determined in advance that would indicate e
t; 17 there was a problem with the diesel generator building?
E
}5 18 MR. FARRF.LL: May I have that read back?
c 19 (Thereupon the last question was ready by the
~
20 reporter.)
21 MR. JONES:: Lee me preface that with another ques-22 tion, to make it cleer.
23 ' 3Y MR. JONES:
24 You indicated that in some circumstances under the j Q.
D observational method a positive means for solving any coblem ALDERSON REPORTING COMPANY.-INC.
26 2:7 that may arise when using the method is developed beforehand, 3
was there any prior positive means established for determin-2 3
ng w .en t .ere was a proMem wM. tb.e diesel generator bum-ing due to differential settlement?
4 MR. FARRELL: Let me have that back too, please.
e 5 5< (Thereupon the last question was read by the 6
{7 reporter.)
8 THE WITNESS : I don t unJerstand the question.
$9; MR. JONES: All right.
i
$ 10 3" MR. JONES :
E i 11 ; Q. You stated earlier, if I understood correctly, 5
d 12 that during the observational method it is sometimes done 5
E 13 that in advance a positive means for solving any problem E
" that may develop is prepared. Was that done with respect g 14 t:
2 15 to the observational zethod that was used at the diesel 5
fe 16 generator building?
g 17 L I think I said alternative means, not positive E
5 18 means.
I 19 '
Q. Alternative means?
~
! I 20 L I believe so.
21 With respect to the diesel generator building the 22 only alternative to what was planned initially, if the con-23 solidation had not proceeded satisfactorily, wculd have been a
M to wait longer until it had.
25 Q. With respect to the diesel generator building, i
ALDERSON REPORTING COMPANY, INC.s . -
27 2:8 j prior to placing the surcharge, was any, was there establish-ed any amount of cracking which would be unacceptable that 2);
3
- ***'0 Y * '***h**8 *8 4
MR. FARRELL: I object.
. 5 bek of foundation.
~
n 3 6 A. I don't know.
[7 BY NR. JONES:
8
- q. Do you know whether the surcharging of the diesel N 9, generator building widened any of the cracks in that build-l I E 10 ing?
z
~_
i it A. Yes.
l 5 l d 12 q. Did they widen the cracks?
E-
- j 13 A. Some widened and some closed.
E
! 14 Q. For those that did widen do you recall the magni-a t.
! 15 tude of the increase?
s j 16 A. No.
s y 17 Q. Do you have a concern that if the NRC and Corps E
l E 18 of Engineers request for lab consolidation of tests were per-t 19 formed that the results would indicate larger settlement in
?
a
~
20 the future, than indicated by the surcharge field data?
21 MR. FARRELL: May I have that read back, please.
22 (Thereupon the last question was read by the 23 reporter.)
l 24 A. I have a conviction, I might say, that teat is the 25 way the results would ccme out and I have a concern as to what ALDERSON REPORTING COMPANY;4NC. - -
28 2:9 j the implications would then be.
i BT MR. JONES :
2 3
Q. Why are ycu confident that the lab data will indi-4 cate that larger settlements can be expected?
. 5 A. Because whatever happens to the soil during 6'
sampling and testing decreases the ability to make a satis-h 7 factory calculation.
3 8 Q. Does that problem always result in the calculation a
N 9, being higher than the observation of the field data?
i
$ 10 A. It always results, at least within my experience E
! 11 and knowledge, in a prediction of greater settlements than 5
d 12 actually occur.
E 3 13 I should perhaps modify that. Bere are a number 5
j i
14 of other v;ays in which calculations can be done incorrectly i
2 15 ' or laboratory procedures carried out inecrrectly and so on.
l 5 i j 16 So I would say that if the entire procedure is carried out s
y 17 exnertly you still come out with a settlement prediction E l 5 18 ' that is greater than the actual settlement. Anybody can goof E
19 it up, but that is not included in the answer.
1 Turn now to the dewatering system that has been
! 20 Q.
21 prooosed for the Midland site. Are you familiar with thae l
22 proposal?
l 23 A. I am aware of it. I know roughly what is planned.
I 24 i Q. In your view, in view of the permanent dewatering 25 system now planned, do you have any concern for liquidfac-ALDERSONiREPORTtNG COMPANY iNCr '---
l
I 29 1
2:10 ;
tion of loose. sand around the pipes at the Midland site?
21 A* N*
3 Q. Are y u aware that lean concrete was placed in 4
some fill areas, during placement of fill?
. 5 A. I have been told that.
A 3 6 Q. 9 uld the placement of lean concrete in plant fill 4
give you any cause for concern for differential settlement f7 y 8 in those portions where the concrete was disposed?
a
$ 9 MR. fan m i.: May I have that read back, ples se .
z_
$ 10 ' (Thereupon the last question was read by the E
g 11 reporter.)
3 y 12 MR. FARRELL: Are you talking about before or af ter 13 surcharge with dewatering, presently?
l 14 MR. JONES: I am referring to at any time and, now,
! E 15 , I am not referring to solely the diesel generator building, i
, g 16 3Y MR. JONES :
m i 17 Q. Is it your understanding that the concreto was E
$ 18 placed in fill areas other than just the diesel generator c
19 building
- 20 <
A. Yes, I think so.
21 Q. With respect to any of those areas , would the i 22 placement of that concrete cause you any concern for 23 differential settlement, in the future?
l 24 A. Does this have something to do with dewetering yet?
i Q. Not yet.
l ALDERSot+REPORTINGtOMPANY 4NC.= -
30 2:11 A. O.K. I didn't know whether it was a carry over from 3
the preceding question.
2 3
Q' N'" **r=7 "*#*
4 A. I believe there could be some circumstances where it might, but certainly not necessarily.
g 5 i
h6 4 W uld you have preferred that the concrete have not j 7 been placed in the settlement?
E 3 A. I would have to know the specific circumstances.
9
- q. Do you know of any relationship between brine re-i
! 10 moval at :he site and the soil settlement which has been ex-i_
i 11 perienced? .
s d 12 MR. FARRELL: I will object to that as being beyond 5
5 13 the scope of the OM OL Hearings, but he can answer.
i 5 l 14 A. I do know that brine has been removed from beneath 5
i 15 ene site and I also raised the question at one time whether s
g 16 it might have a reflection on the surface settlement. The m
I ti 17 , investigations that were made satisfied me, at least, and.
I E 18 the information thae I reeeived about the investigations thae 5
C 19 ' were made satisfitd me that it was not a problem in connec-l N l
~
20 tion with the surficial structures, as the plant that we are l
21 building is much above the brine producing zonets at the Mid-22 land area.
23 BY MR. JONES :
l 24 Q. What types of information did you receive. that 25 alleviated your concern?
ALDERSON REPORTING COMPANYclNC.~ w- --
s 31 2:12 ; A. I saw some levels of Dcw Chemical Ccmpany, I be-lieve, indicating where their bench marks were and what sub-2 sidences they had observed.
3
- q. Would that information be in the documents you have 4
. 5 pr vided to us today?
b 6 A- N*
Did you have any input into recommending that a f7 Q.
8 dewatering system be used, at one time?
J 9 A. Yes.
i
$ 10 Q. Did you have any input into the actual design of i
! 11 the system? -
E d 12 ' A. No . Yes, in this sense, that the concept of the 5
E 13 system was discussed at one or perbaps more meetings at which E -
l 14 consultants were present and I think we all discussed the E
E 15 general characteristics that the system should have. To that j 16 extent I participated.
s ti 17
- q. Do you know who did the detailed design of the de-s i
$ 18 watering system?
E
$ 19 '
A. No. I understand that both staff and Dick. Loughney M
^
20 ,
had participated, but I don't know the extent of parricipatien 21 by either.
l 22 c. By staff you mean Bechtel staff?
23 A. Bechtel staff.
~
24 Q. Do you understand what the phrase "Q" lisced means?
25 g, yo, ALDERSON REPORTINGCOMPANYrtNE.~ e-~~. -
32 2:13 q. Do you understand what I nean v'nen I use de p'nrase 3
2 soils that were quality listed?
3 A. No. ,
4 r 4 q. Do you know whether the soils beneath the fuel oil e 5 tanks at Midland were subject to a quality control and/or h6 quality assurance program in their placement?
7 MR. FARREI.L: I am going to object to that.
E a I don't think we have the definition of quality em-a N 9 trol or quality assurance program.
Y 5 10 3Y MR. JONES : ,
E ja 11
- q. Dr. Peck, are you aware of what the phrase quality y 12 control generally means in the field of soils engineering?
=
l= 13 . Mt. FARRELL: You are not talking about nuclear l+ 14 plants now?
=
2 15 MR. JONES: No. I said general knowledge of -h.at a
2 g 16 that phrase means.
e
!! 17 A. In a general way I do, but the terms quality control a
3
$ 18 and quality assurance, I think both have somewhat different 19 connotations to experts in those fields and to others , and g
~
20 I don't know those distinctions .
21 BY MR. JONES:
22 q. Did you have any input into the evaluation of the 23 acceptabili::7 of the soils underneath the oil tanks, for NRC 24 purposes?
25 j A. No. In fact, I'm sorry I really don't know what you ALCERSON REPORTING.GOMPANYANC.----- - -
l 4
33 2:14 y mean by acceptability for NRC purposes.
Q. Do you have any concern for the adequacy of the 2
3 foundations that support transmission towers and transformers 4< located on the plant fill which provided the require alter-native source of emergency power for the plant?
g 5 5 6 MR. FARRELL: Read that last question back, please.
a (Therefore the last question was raad by the f7 8 reporter.)
N 9 !!R. FARRELL: I dente particularly know what struc-I
!! 10 ture you are talking abour. There may be a shorthand for it, E_
i 11 give me better information.
E d 12 ' A. I don't really know anything at all, specific, abot; E
i ! 13 these foundations.
l 4
14 BY MR. JONES:
1 2 15 Q. Do you know of any study of the consequences of i
j 16 failure of the dikes ae Midland?
m i 17 A. Of any study, no.
1 i 5
18 Q. Do you know any study of the probability of failure l
3 19 of the dikes?
M 20 '
A. No.
21 Q. Are you familiar with the document entitled "Stan-1 l
22 dard Review Plan", put out by Nuclear Regulac q Commission?
23 g, yo, M Q. What is your present assessment of the adequacy of 25 the soils in and under the berated water tanks of ring
, ALC ERSON REPORTING GOMP A?+Yv4NC.-- ------ --
1 34 l
2:15 y foundation?
A. I haven't studied that.
2 3
Q. Did ycu have any input into the pre-loading of the borated water tank by filling ie with water?
4
, 3 A. I participated in some discussions about it.
h6 Q. hve you in any way been involved in reviewing the l
I f7 results of that pre-load?
j g A. No.
n N 9 Q. Did you have any responsibility with respect to i
E 10 deciding what information should or shculd not be sent to 5
i 11 the Nuclear Regulatory Commission on the soils matters?
5 5 12 MR. FARRELL: Read that back.
3-5 13 (Thereupon the last question was ready by the E
j 14 reporter.)
E 15 A. Probably not. The only possibility I can see is E
j 16 that I was asked at times to comment on draft answers to some h 17 of the questions. I don't recall that any of my comments s
5 18 ever had anything to do with what should be sent co the -
=
19 , Nuclear Regulatory Commission, but I don't know, of course, 20 . what might have been done with any of my cements.
21 ! BY MR. J01C.3 :
22 c. Do you recall which issues you reviewed that were 23 sent to the NRC, either by number of subject matter?
~
24 A. Certainly not by number.
25 By subject matter, what I recall specifically, at
. ALDERSONREPORT4NG GCMPANYWNC.- - - - - -
i
1 35 2:16 3 least, is ansvars concerning the need or lack of.need for additional borings and tests under the surcharge area.
2 3 Q. Did you add anything, reccc: mend anything be added 4 to those replies, answers?
o 5 MR. FARRELL: Object.
N
- 6 Compound.
7; A. I don't believe I suggested any :nore than a change 8 in wording here or there, and I don't remember what that e
a '; might have been.
Y E 10 3Y MR. JONES:
E j
11 Q. What is your understanding of the safety function l
f= 12 of the diesel generator?
E 13 A. It is probably very Ancorrect.
E l 14 MR. FARRELL: I will put in an objection as to i 15 foundation, but go ahead.
l E
j 16 A. What I have perceived to be the requirements are s
!! 17 that the building provide shelter for the generators and .
I s
E 18 that nothing with respect to the building that might go wrong ,
E 19 or interfere with the ability of the diesel generators to l 20 serve their function, which I believe is in the case of a 21 : shutdown.
1 22 Q. Are you aware of how the power from the diesel 23 generator building is transported to the planc?
M . A. Not specifically. -
l 25 Are you awars generally of how it is transported?
Q.
i
.r. 2 _
- ALDERSONREPORTING COMPANY..lNC. ~ - - -
1 1
I 36 2 :1.7 1
A. It must go through cables, througa ducts.
2 i i 4
3 5 .
E j 6, R
R*
7 3
5 8 a
J
= 9 Y
E 10 i
=
j 11 m
d 12 Z
E 13 .
E E 14 3z i 15 a
z ls 16 i t
ll a
17 z
$ 18 '
19 I
20 21 i
22 23 '
24 i ,
f 21
~ ~ ^ ~ ~ ' '
ALDERSON REPORTINGCMPANYHMC::v~~-c - ,.
l l
J
aa m m_ _s _ __
.q
) 37 ,
3:1sfg 1 O In designing and =aking recocnendations with re-2 spect to ti. remedial action for the diesel generator 3 buildinr was one of the considerations, i: ycur nind, i:
4 =aki:g that advice or recc =e datic=, the effect := these e 5 cc duits carrying the electrical cable?
9 Tes.
3 a 6 A N ,
l i 7 C Do you have any u:derstandi:g of what the safety j 8 functics of the borated water tank is?
e
- 9 MR. FARNILL: Objection, lack of founda icc.
i- .
5 10 A It is undcubtedly a very 1 perfect understanding.
3 l
l5 11 I u=dersta:d they need the water if sc=ethi g goes wro:g. I f 12 ' don't k=cw what that "so=ethi=g" is.
=- ,
E 13 3! MR. JORIS:
i E i
a i 5 14 C Is it your u:derstanding that the borated water j E 15 tank should be designed to withstand the SS3 or design M_
j 16 i basis earthquake?
3 d 17 MR. FARNZLL: Objection, lack of foundation.
a
=
~
18 A I don 't really know.
3 t
c ; ;
a to '
C Lo you have any u=derstanding of the safety
! 21 'u=ction of the emergency cooling pond and pipi:g?
l l
22 MR. FARNELL: Objection, lack of foundation.
! 23 A I have a vague understanding.
l
\
24 3f 33, gag 33:
25 2 ~4 hat is your understanding of the safety function i
ALDERSONREPORT(K" " ;r}[@ ---
D .
D Agy)-q lD .
w- o b u. L Mbb
i 38 .
1 i
t 3:2 1 of the e=ergency cooling pcud and piping" :
1 ,
2 E. 7. GELL: It is also compound. .
3 A M7 vague understa:: ding is that the water is needed 4 in the event there is some sort of an incident, I suspect, e
5 in the reactor a_f .t is =ecessary to cec 1 things down to
~
n 3
6 rest:ce safer conditions.
l "A,7 3Y E. JOIGS:
~ i '
j 8 2 Do you have any unde _itanding of the safety N 9 function of the electrical penetration areas at the plant?
21 E 10 E. UPMI: Objection, lack of foundation.
i-j 11 1 I certainly have a nimisal understanding.
is 4 12 3Y S. J02GS:
z
=
What is your understanding of the safety function 5 13 2
=_
i
$ 14 of the electrical penetration ares?
1 It 2 15 E. yAF?mi: Objection, lack of foundation.
a
=
j 16 ' sight even go to speculation.
s
! tia 17 TE WIT.GSS: You are right, I think it would go n
5 18 to speculation.
=
19 , A I have assumed simply that if there are penetra-20 tions from the structures into the contain=ent vessels or 21 the reactors that they are supposed to recais functional 22 during anything that =ight happen.
23 3Y E. JOES:
24 O Are you aware of the phrase ":ain feedwa~ter 25 isolation valves"? , y F
.E b:
ALDERSON REPORTING COMPANYMNGe- t--
1 1
1 i j 39 I s
l l l 3:3 1 1 I have heard it. ;
i i'
2 2 to you know where these valves are located?
3 i No.
4 0 Oo you have any unders;anding of their func 1cs? .
i e 5' A Not really. I know what a valve is fo: .
n j 6 O Are you aware of the fact that there are fuel oil
,-- i 3 7 tanks located at the Midland site? ,
1 n
8 i Tes.
.i
- 9 2 Are you aware of whether or co: they supply oil '
( i E 10 to the diesel generators?
z-5 11 A It would seem reasonable. ;
a f 12 ' 2 Do you believe that the fuel oil tanks are es-
=
E
~
13 sential to the operation of the diesel generators? .
a i a
p 14 E. 7A3.'GLL: Objection, lack of foundation.
i E 15 A I don't kucw.
a
= ',
j 16 3! E. J0 LGS: '
a l d 17 C Are you faciliar with a retaining wall that runs ,
a
= '
5 18 ' along the pond in the vicinity of the fue?. oil tanks? ,
I jv.
19 A I know there is one. 1 20 '
C If that retaining wall failed during a design :
l 21 basis earthquake, an SSE, would there be.an effect on the 22 soil located behind that retaining wall?
1 23 E . ?A3: W L: Objet' ion, lack of fcundazion.
24 ,
1 I would only say that whenever a retainits wall 25 fails you expect the scil behind it to be affected.
A LD E R SO N RD""]D EPORENG.COl lD [}33 jM PANY so m o NU1UX >
40 '
3:4 1' 3Y M2. JON3S:
2' C If the retaining wall along the pond in the 3 vicinity of the fuel oil tanka did fail during a safe shut-
- down earthquake, could there be an effect on the tanks and a 5 z$ogg 3 ce a go$1 gz$3,g a
j 6' A I don't know.
% 4
$ 7 4 C Is a soil slide one possible result of a metaining
- 8 A wall failing at the pond at Midland?
J
$ 9 MR. FARNZLL: May I have that read back, pleace?
?
10 (The pending question was read by the reporter.)
!a II 1 It is conceivable, but I don't know for sure. It I .: gg E
depends on the specific conditions there, which I don't
- 13 ' recall.
, j 3
f 2 14 MR. JON23: Let's take a five-cinute break.
t_
h 15 (Thereupon a short recess was had.)
, s.
? 16 Back on the record, 3 MR. JONIS:
s '
17 3T MR. JONIS:
1 l "3 E _l a
=
in C What maxizum amount total or differential settle-a 19 8
n ,
nest was determined in advance that would indicate when 1
20 there was a problem with the safety related piping under-i 21 neath the diesel generstor building?
l i
l 22 l
1 I don 't know that there was a deter =ination there.
23 If it was, I don't know what the number was,
~
l 24 2 If such a deter =ination of a nazi =um amount was 25 nade, who would have that information?
l
)
= , ALDERSON-REPORTING G . NYg yy gp f .S
I 1
41 :
I 3:5 i A I don't know. l' 1
2 C With respect to the conduit underneath the 3 building, which you said were considered in designing the 4 surcharge, what =sxi:us accunt of total and differential 4
e 5' settlement had been determined in advance that would in- ;
a 6 dicate when there was a problem with the conduits under-E, 7 neath the diesel generator? f 5 8 A I don't know.
n 5
2 9 C Do you know if any prediction was made?
Y E 10 A No, I don't know.
z-I 11 2 Returning to the concrete, the lean concrete 3
y 11 that was placed in the fill, with respect to--new I as ,
=
E- 13 focusing on the diesel generator building--is it your under .
i
=
=
g 14 standing--strike that.
~
n E 15 With respect to the concrete under the diesel a
=
g 16 generator building, do ycu believe that the concrete was t e
! i a
17 one of the causes of the differential settle =ent at the i =
l j 18 )
diesel generstor building?
n j
19 , A Initially the concrete ducts pasrd.ng underneath l
l 20! the generator, diesel generator building, did contribute to 21 ' the differential settlement. Whether any other sasses of 22 concrete contributed or were even present, I don't know.
) 23 C You are not aware of any concrete underneath che 24 diesel generator building other than the conduits 'you have 25 just described, is that correct?
- ALDERSON REPORTING COMPANY INC.
i
l 42 l
i 3:6 1 A I am aware that there may hav3 been = asses of I i
1 2< concrete at various places in the fill, yes. ;
I 3 C Could those : asses of concrete have in sc=e way j
4 contributed to the differential settle =ent underneath the l '
l g 5 generster building?
n '
N j 6 A Prior to surcharging? l
@ l 2 7 C Prior to surcharging. l
~
l
- 7. '
I 8 MR. ?iRNIEL: Objection, calls for speculation.
U
, = 9 A It is possible that they could have, j t E 10 3Y MR. JON3S:
i 5 5 11 O If such sections of lean concrete are present l , l, 3
l underneath the diesel generator building in the fill, do 12 ,
f i
I E g 13 ' you believe, based on your personal experience, that their i
=
n 3
14 , presence could lead to any-differential settle =ent.in the ,
m
=
2 15 future? ,
a -
=
j 16 A Not in the future, no. !
= i t
i 17 C Do you feel there are any li=1tations on correcting i 4 E} 18 soil samples for sample disturbance that would permit a I n i
! $ 19 good estimate of this settlement to be cade? i n
20 MR. ?ARNZLL: May I have that read back' ,
21 (The pending question was read by the reporter.)
22 MR. ?ALTILL: I don't understand the question.
23 A I don't either because I don't knew how you can
~
24 - ccrrect a sample.
l ,
25 3Y MR. JON3S:
1 ALDERSON.REPORIING.COMEAbtY INC.. . . . - - -
l
- 1
-s 3:7 1 2 I believe earlier you have =cted that c=e Of the 2 proble=s with taki:g soil consolidatics tests 3:d =aki:g 3g predictic s was tha: dere is sa=;1e disturbanc<s 1: ta%ing 4
4 te beri:gs. I a= asking you if ycu fee' "-a-a are a::y e
5 limita:ic:s on correcti g fer the sa:ple disturbance to reach.
M 3 6 a goed esti= ate of the settlece: cr as accurate esticate of a '
m N
ji 7 the se -le=enr.
! 3 E. Fi W I: Are you sayi::g that the ll=ita:ic=s n
=
vculd cause a good estimate? It doesn'; appear :: :a%e a::7 0
z, 9;
10 sense.
2:
E 11 3Y E. JON3S:
s y 12 1 I a: aski:g if dere are any li:1:atic=s on cor-
=
E 13 recti:g for the sa=;1e disturbance se that you can a=ive a:
=
r
=i 14 a good esti= ate?
!x 15 A Tes. The princi;1e of li:itatics is ca all de j 16 setods of co=ection dat I k=cw of fail to work u: der a
i 17 certais circu=sta:ces, but you dc 't 2:cw which circu:-
l 6 a 18 stances.
3 19 , 1 2 you thi:% that a reascrable 1::erpretation can M
20 be rade of lab co:solidatic: data to predict future settle-21 , resto 22 n. .?Ar s;L: Are you talki:g about just in 23 gener31?
24 E. JOES: In general.
25 g , yang;L: Cbjectics as to pcssibly calli:4 fer ALCERSCN.REPCRTING CCMRANY.INC .. . ..- ._
1 44 i
3:3 i cany different conclusicus for different cases.
2 A Under sone circu= stances, even under =any circu=- ,
i 3 stances, good esti=ates can be cade, better esti=stes 4 usually of the total se**'e=ent than of the rate of settle-i 5' ent. Under other circu= stances, predictions can be very e r a
n j 6 poor. l
- l A 7 3! MR. JON3S- 1 j 6 C I believe earlier you ritated that you 5 leved L
- 9 predictions would be peor for the t'iesel generater building?
Y E 10 A Tes. '
E 5
11 C What is the circu= stance at Midland that makes .
i 3
12 predictions fres lab consolidation data there unreliable? 1 4
E 13 1 Ihere are probably several, but one is that the !
E 14 soil is a fili nnd fills are, at least to some extent, non-t 2 15 hemogeneous. To be assured that one had representative ,
=
g 16 i sasples or knew how to account for the homogeneity, is, in ,
a i 17 y view, impractical, if not i:possible, at that site. 2 hat, a
='
a 18 is one reason. ,
= ,
H
$ 19 0 0.I. Are you fan 111ar with a document, entitled a ,r 20 " Standard Review Plan for the Review of Safety Analysis 21 aeports of Nuclear ?cwer Plants," and it is also identified 22 someti=es as NU23G-73/087?
23 A I don't think I ever heard of it.
24 C What professicnal experiences have you i'ad per-25 sonally with prele. ding sr surcharging? ,
ALDERbv. ORTINGCOMPANY. INC. - --
.c .
- e )
I have had quite a few. Perhaps the earliest was 3:3 1 A 2 in about 1942 1: cc=:ection with the design, constructio:
3l and cperstic: Of an ire: cre s :: age yard in Cleveland.
4 2his =ay not have bee: strie:17 a surcharge proble=, but 5 the ore placed i s:crsgr during the first year ce=stituted n
M ,
2 4
6 a surcharge with respect to t e ore that was going to be !
2 I.
E 7 stored the second year a d i c der to deter = ire wra future 4 t
M i
n a loadings could be the subsoil, which was a deep clay, was N
9 i stru=ented with piezo eters, observatic s Of covecents weree s
5 10 =ade. Zhis is a rather extensive investigation and project.
t 5 11 C Were settlement Oc=u=ents placed alse? h 3
12 A 2here were settle =ent =c=ucents, but they did= 't ;
{f
=
$ 13 work. -
E l 2
3 14 Why did= 't they verk?
s E 15 ,
A 3ecause they were water level type conu ents a:d a
=
j 16 the cc::ecti=g pipes frc: the o=uce: s to the Outside of m
i 17 the stcrage area were subjected to tensic: and the pipes a
=
5 18 broke before the settle =ent reached its =azi=u . Sc e i=-
=.
$ 19 , for:ation on settle =e=t was obtai=ed after the yard was u=-
~
M 20 leaded, but the devices did='t work. Zhe pere pressure 1
21 devices, c= the other ha d, worked very nicely for abcut 10 l
I 22 years.
f l 23 Ihe next one that I can think of was the reloca-24 tics of :sil cad tracks arcu=d what is ccw 0'Eare ?ield in l
l 25 Chicago where two rsilroads had to be relocated Over a pea l
%Wg1NG ALDERSON REPORT 4NG CCg fM dML
46 3:10 1 bog several thousand feet long and where surcharging of the ,
1 2 sand drains was used. Ihis was in about 1954 I advised e 1
the Illinois Division of Eighways, through ny connections 3,
4 wi,a the University of Illinois,on a number of surcharging i l
Cne in LaSalle, 1111so13,I o
a 5' jobs under a variety of conditions.
n 3 6 a series of them up around 3arington, Illinois, scoe with a
M R 7 sand drains and some without. I would make an offhand j s judg=ent that probably I have been concerned with, to some N 9 ernent, 20 or 30 or 10 surcharging projects at one time or I:. ,.
@ 10 another. j z
i 11 2 With respect to the first one ycu have listed i m
d 12 , here, the iron ore storage yard, did that involve a i E i
=
s 13 structure of any kind? l' 5
E 14 A Tes. It involved a series of retaining walls, one
, d :
l e E 15 of which was about 70-feet high. It involved the inter-l a i
=
16 connection of these retaining walls by tie rods and in j l f c e l d 17 some places by floor slabs on which the ore was piled. ' l
' I
= .
~
18 The portion of this complex adjacent to the river was a l l,
- i y 19 relieving platform and dock structure on which iron ore was ;
. a i 20 1 placed and behind which iron ore was pilad., l 21 2 With respect to the relocation of the railroad at 22 0'Eare, were any structures involved in the preload there?
23 A yo, 24 2 With respect to your work with the Illinois Eighway: .
25 Commission-- '
m '
O
- ~
ALDERSON REPORTING COMPANY,'tNC.':-- -
. i
- 47 3
- 11 1 A (Interrupting) Illinois Division of Eighways.
2 C (Continuin6) - -was th e =aj ority of your work l 3 involved with surcharging areas where reads were going to 4 be placed?
e 5 A Yes, but in several instances involving bridge N l j 6 approaches or culverts. ;
I R
& 7 C With respect to the 30 or 40 other surcharging j 8' experiences you have indicated you had, were any o' those j
._a
- 9 concerned with essentially concrete buildings or structures?
i E 10 A No. ,
f
=
j 11 4 1 Were any of thec. concerned with surcharging steel j m ' ,
f 12 tanks? t E
E 13 A Yes. l
=
M-g 14 2 Would you say the majority of them were concer ed ;
I c
f E 15 with surcharging steel tanks? :
a
=
j 16 A. Ihat would probably be true. ,
w I
l U 17 2 With respect to those structures which were not
=
5 18 concrete structures or steel tanks, can you give se some ,
I 19 of those experiences? .
t n ,
i t
20 A l All ri6ht.
21 2 You have indicated there were no concrete struc-22 tures so elisinating that and elisinatind the steel canks, 23 which were the =ajority, what were so=e of the others?
~
24 .. A I think there are none left.
15 2 Would you say substantially all of the 30 or 10 ALDERSON REPORTING COMPANY. INC. .
g- ---*-g-ww+ - --u-- -g- y op w y er
43 I
3:12 1 are involved with steel tanks other than these first ones i l
l 2 70u mentioned? t i 1 Cr ectank=ents of one kind or ano;her. l 3 A l
4, 2 Would you give the techni, cal definition for pre- ,
)
t e 5' loading? ,
3 6 A I don't think there is a single technical def.tni- 1
- I 2 7 tion of preloading. l 9
j 8 O Can you give ne what your definition of preloading l
= 9 is? ,
i 5 10 A I understand it to =ean placing a lead o= a sub- ,
E
=
j 11 grade, if we are again talking technically, to i=preve its i a
j 12 p;cperties either.before some other construction has taken j
13 place or, in some instances, during or after some other
- i M
g 14 construction. Preloading are surcharging are oft,en used 1 I don't 2 15 interchangeably. I use the= interchangeably. ,
a z
j 16 . incorporate into the definition of preloading the necessary ;
n i 17 requirement that it be done before all other things are a
= ,
a 18 dcne. ,
t
$ 19 : C Lo you believe that definition is one that is n 1 20 , widely accepted within your field of expertise?
21 1 I think it is widely accepted and rather loosely 22 used.
23 C Are you aware of projects where certain surcharging 24 or preload was applied af ter the building was subs'tantially
, 25 completed?
1 i
. ALDERSON-REPORTING.EGMEANYHNC.~ ~ e .
49 ,
3:13 1 A Tes.
2<
1 0 Are you aware of any kind of reference list which ,
3I would refer :: buildings that would fall ist this category?
4 E. FA3E: Le you =eam a tech 1 cal jour:al?
a 5 E. JCIriS: A tech =ical jour::a1 or amyplace as a
n j 6 indez right appear. .
, $ 7 A There are several listed in Geotechnical Abstracts.-
j 3 3T E. JONES:
- 9 0 Le you recall specifically which Abstract?
I
@ 10 A No. They ecver a period of 10 years.
E
!3 11 C 'dhat 10-year period is that?
y 12 A 1970 tc 1950.
=
! 13 C. Are those Abstrsets ge=erally available te the m
public'i= a tech =ical library?
i 5 14
's R
15 A They should be.
=
f 16 2 3 ave you personally had any experience with sur-e j: chargi g a buildi=g, buildinz cr structure, that was sub-7 3
18 stantially cocpleted when the surcharge was applied, other "m 19 than this one at Midland?
a
~
M A No.
- 1
' O ~4ith respect to the Abstracts. you have indicated 22 4 that ray refer to structures that were surcharged af ter 23 corpletion, would those Abstrsets give any inferration as to 94
- hev these structures perforred af ter a surcharge? -
25 ! M. ?ARE: They will speak for therselves.
ALDERSON REPORTINGCOMPAN.YDll ,,
31, 39 h
& N .1. A}in%
~: - --
.. , g i
SC l
I 3:14 1 Whatever you can recall. l l
2 A Some do and some don't. >
, I 4
3, 3T MR. JOITIS:
n 4 2 Can you nace any of the specific projecta which s 5 are referred to in those Abstracts?
9 i
6 A Cne, which was a partially completed structure at 3
3
! R 7; the tire of surcharging, was the American Stores Warehouse ;
X i j 8 structure in New Jersey. That one has actually appeared in '
5 9 the literature in several places.
< Y
@ 10 C Are you aware of how that structure perfor:ed !
E 2 11 after the surcharge was removed?
a f= 12 A The article, as I recall, said difficulties had E 13 been observed after the structure was put in use. ;
i
[ 14 '
C Do you recall how long that structure has bee = in l l 3 l
2 a
15 , use?
i E . !
g 16 ,
A If it still exists, it would now be about 25 !
= ; i i 17 years old. l i
a
= !
E 18 C Any other projects? ;
=
- l 19 A I can't recall names and locations at present.
20 \
C Are you familiar with NATICCIS LM-7 Design Manual? !
21 A I know that it exista. I have probably seen it. ,
22 C Are you familiar with the design guidance provided 23 in LM-7 with regards to preconsolidation by surcharging?
24 4 yo, .
l 25 2 What sethod was used--do you %=ow whether the l
I l
ALDERSCRRERORTING. COMPANY 1NC. !
--r 31 i sethod d.escribed in 1M-7 for predicting surcharge lead was )
3:15 1 21 used in the Midland project?
MR. 7ARNILL: Objection, lack Of f:undation. Ze 3'
4 stated he was.not fa=iliar with it.
e 5, -
A No.
N
~
6 3? MR. JON3S: ;
I R n 7 q Do you k=ow what =ethod was used to determine the ;
j 8 required surcharge at the Midland project?
.c
- 9 A '4 hat do you =ean by the " required surcharge"*
i E 10 0 Ihe load.
i
=
{ II A As far as I know, the way that the used surcharge a
y 12 was determined didn't follow any published =ethod per se.
=
E 13 O Are you familiar with the method that was used?
E a
.g 14 A Tes.
1-Could you describe the method that was used?
I l 2 15 2 I
E_ .
g 16 A Tes.
a
$ 17 I shoula say therp were three principal steps.
a
=
E 18 The first was a determination of the maxi u: height of fill
=
19 that could te practically be placed in and around the area.
A 20 The second was a determination that the stresses at all 21 depths beneath that fill would not be exceeded by the future 22 load frem the structure and the third was a conclusion tha:
23 the odds were good that the consolidation necessary to co=-
24j solidate the soil under the weight of the surcharge would 15 consolidate rapidly enough to allow us to re=cve it ALDERSON REPORTING COMPANY. INC.
l 1
l
52 t
3816 1 in a practical length of ti=e.
2 2 With respect to the determination of the axi us 3 height that could be placed in the diesel generator building 4 area, at the ti=e that this initial deter =ination was being g 5 =ade,- do you recall whether the construction of the diesel n
j 6' generster building had proceeded to a point where there was A 7 any linitation due to the structure at ths: particular
~
n i
n 8 point in ti e as to height?
'di
- 9 A Li=itation on height was no associated with this i
5 10 stage of construction of the building.
E j 11 < 0 What consideration, then, did deter =ine the razizu :
m j 12 height that could be placed?
=
E 13 A There was a limitation on the a=ount of the sur-E
=
5 14 rounding area that could be occupied or obstructed by the c_
f 15 fill and since fills have slopes on the sides, when that a
3 .
g 16 was determined we determined the =axi=u= heigh: that would s
l d 17 be practical to carry the fill.
- a l 5 l
E 18 C Was this consideration of the construction ac-1 m i
- "a 19 tivities that would be taking place around the building M ,
20 l that it wouldn't be interfered with if it was--
21 A (Interrups ag) On some sides of the building 22 that was a consideration. On the north side there was a 23 limited space between this building and the auxiliary 24 building.
j 25 2 Was the height of the surcharge in any way r's, 1
f ALCERSON REPORTING COMPANY. INC.
l
b.' 53 f
3:17 i trolled by the internal height of the diesel generster I 2 buildingo l A ! dc='t believe tha was a con::cIling condi:10 .
3 4 2 ~4ith respect to the secc=d step, which was a 1
a.
5 deter =inatics that the st- ess c: the soil eculd =ct exceed--
2 3 6 could not be exceeded by the future lead to be expected, was ;
R A 7 there any factor that you increased the final desig: lead I M
4 j 8 ,
by =aking the prediction of future loads i: order to compare ,
- 9 it to yeu: surcharge lead?
z_
5 10 MR. 713 ELL: Ma7 I have that read back, please?
~
ja 11 (The pending questien was tead by the reporter. ) ;
1
-5 12 A No. ;
E.
)
i s 13 i E
j 14 i
= 4 E 15
.a ,
3 .
? 16 ;
3
- a -
d 17 i
j $
$ 18 1 t
=_ 1 l
a 19 ,
[
a < -
10 21 22 l r
y 24 .
25 ALDERSON REPORTING COMPANY.~lNC. -
mm o
'%y" J dc Ju c JL U J
i i' 54 I
4-1 1 3Y Ma. JCIES : .
l 2 Q Sy what method did you reach your conclusion as to j 3 whether the langth Of time which the surenarge would determtne 4 was going to be used would have to be left on a site? ,
1 e,
5, .
Ma. FAasr.LI.: cbjection, no foundation that any i M
j 6 determination was =ade prior to the surcharge. ,
l R , 1 2
7, A It was not a mathed. It was judgment. i 8 3Y M. JO!ES:
d 2 9 Or. Peck, I shew you a dccu=ent chat is labeled Q
z.
- i
@ 10 Figure 2 and in parenthesis it says,"(See Referenes 1)", I '
E .
I Il r epresent to you that this is also contained in Kane Exhibit 3 ,
i 12 No. 3 and ask you if you have ever seen this chart before?
=
m E
=
13 A I have seen one that looks like it. I am not sure ,
8 H 14 '
that there is only one such figure.
3 s
- 15 i Q I will represent to you that I believe that that is ,
= !
a[
16 a reproductica of a viewgraph that you used at an August 29 ;
- 17
$ meeting. Oces it appear to be a copy of that viewgraph? ,
) = '
5 18 A It could be. 1 5
19 i
Q With respect to the loading stresses which are plotted: .
I on the viewgraph again, I believe that is the representation 21 i '
of the viewgraph, did you complete the leading strasses which l 22 areIictted On the chart?
23 l A No.
24 Q Who did compute them to your knowledge? -
25 A sometime in that Sechtel gectachnical g Oup.
i I
' i j ALDERSON REPORTING COMP ANY. INC, i
.a 1
- 1 Q Did you in any way check sechtel's computa:icns with ,
l 2' respect to the stresses pictted cn Figure 2? i 3 A : locked at and sade sera c0= rents about what was 4 p:chabl7 an earlier version of this *.iawgraph in Order that they i e 5 would make into account the facters that I thought **ere signi- l t
a 6 l a ficant.
b 7
, Q What facts:s did you point out to them that you M
j 8 thought'should be taken into censideratien? ,
t I The principal thing that : recall that we discussed ;
[
A i I
E 10 i was ene determination of what =castituted the live 1 cad and ,
= ',' what would be a long-term value of live lead which would be 1
j l
d 12 the appropriate thing to use in such a calculation. ;
z
= 13 Lccking at Figure 2, what is the app:0ximata i Q
=
z s
14 increment due to structural load, and I mean the dead lead at h: , ,
b"'
z Ilevation 62S?
? 16 of course, it will speak for itself.
3
=
MR. fan w nt: l j
F 17 Atc.,ut three and ene-half kips per aquare fcct. i d A t 7: ;
3ll 18
- SY MR. JONES
s j
19 Q was.this value of three and one-half kips per square ;
i 20 foot your understanding of the structural leading of the diesel i ,
21 generating building at the time the surcharge was placsd in 22 January 1979?
23 The time it was initially placed?
MR. FAREELL:
24 -
- A Would you repeat that?
25)! -(Thereupon the last question was read by the ALDERSON REPORTING COMPANY. INC.- .- ;
56 4 -3 reporter.)
1 A No.
2 SY MR. JCNES:
3 Q What was your understanding of the structural leadi.g 4
of the diesel generator building at the time that the sur-g 5
- charging was placed in January of 1979? l e
6
( A I am sorry, would you repeat that?
{
" 7 j
n (Thereupon the last question was read by the y reporter.)
- 9 l
i I don't knew and it really was of no significance ;
- A ,
r:
10 i z '
5 at that time.
a 11
< i 3
! SY MR. JONES:
- 12 3
^
Q I nw shcw you We 4-1-A which appears b the j j3
~
=
3 j, 50-54 (f) response of the Consumers Pcwer in Questien 4 and ;
t 2
t a ed Redsion 5, F&rury of M80. I ask you to note l
B 15 i
under Surcharge the explanation of the dead load on several 7 16 i 3 i e
g- j7 dates there, including when the surcharge was placed. l 2 '
a t s I 5 18 A O.K.
~--
E j9 Q My question is can ycu explain why there is a varia-R 20
- tien f cm 2.2 kips per square foot to the chart,which we have 21 been referring to as Figure 2,which refers to 3.4 kips per 22 second as the dead load? 4 n A No.
24 Q Are you aware of what method was used to comcute the
- t 25 stress leads that were plotted on Figure 2, tne first. diagram?
l ALDERSON REPORTING. COMP ANY, INC. , !
l r
57
-4 I A It is my understanding that the stresses were dis-2 tributed in accordance with the scussinesq. distributions.
3j Q Were you previously aware before referring to these 4 two documents that there was a difference in the result of the s
n 5 cementation of the dead lead at the time tne surchar e was -
n g 6 placed?
R
" 7 MR. FARNELL: I am going to object to this and the M
i a
8 previous question that he did not have, there is no foundation ;
- 9 that he worked on this.
t z.
10 j MR. JCNES: I did not ask if he nade it.
=
MR. FARIELL: Well, there is no foundacien, no real 5 11 3
-i 12 2 explanatien of what it deals with.
= i s 13 EZ ..W; . JCEES : f E '
14 u o My question is were.you aware of tais discrepancy ,
r 15 j before I just pointed out these two documents? j 16 A Yes. [
$ t
'. i r- 17 d Q In your opinien, which Icading is the correct i
= i
. $ 18 >
7 ;:- representation of the dead load at the time the surcharge is I 19 !
i closest to the correct? e 1
20 i A I don't know. :
i 21 Q cces this discrepancy change your opinion er the ,
22 adequacy of the magnitude of the surcharge that was imposed?
23 A No. .
24 Q Referring again to Figure 2, why is it that the descrepancy dees net change your opinien as to the adequacy of l
ALDERSON REPORTING. COMPANY. INC . .
- 3 D 4 1 DD D = O
g 58 4 -5 i the surcharge, the lead that was imposed?
2 A Secause the value of the building lead pric: to and 3 during the surcharging is of virtually no significance in cen-4 puting the stresses due to the surcharge.
i 1
e 5 Q Do you know whether the stress difference between i a
n I
+
3 6 curves 2 and 4 as related on Figure 2 is the full, live lead?
e l R i R 7, MR. FARIELL: May I have that repeated?
A i
a 8 (Thereupon the last questien was read back by the .
d i d 9 .repor'er.) !
i
?-
@ 10 A could you define full, live load?
z
=
~
i 11 > 3Y MR. JCIES : (
3 t j 12 Q sy full, live lead, I mean the live lead that can be
=
g 13 exuece,d to occur during the life of the plant according. to the
=
a 14 building codes. l 5_
j
_+
15 A I hope it dcasn't.
z j 16 Why?
Q s
I7 A Secause in t he building code live loads, there is a h
2 y 18 great deal of transient icading or provision for a given lead 19 a '
that may exist in different places at different times in a a >
20 '
building that does not centribute to the average long ti=e lead ;
I 21 on the foundation in propertion to its code magnitude. And i 22 therefore, it dees net contribute to the settlement in that i
23} .
c ccortion.
i 24 Q Do you knew what =akes up the live lead of t% diesal f 25 j generater building? l' 1
i 1 ALDERSON REPORTING COMPANL.INC. .
h( -
l, 59
.;-6 A In a general way. : requested when this was done that careful consideration be given to evaluating what the 2
accual long-term live load would be and : trust that is what has been done, f
Q s it custc=ary to use the full, live 1 cad as I have ;
5 e,
" ccmputations Of I described in referring to building codes fc '
.o. 6 '
e stress?
a 7 c
5 8 A Nct of settlement. -
t, n
9 Q Is it custc=ary to use the full, live lead f er cc=put--
- 9 ing hearing capacity?
.$. ;g ,
5
=
A That depends very nuch en the character Of the >
11 :
<c s t 12 structure.
=
~
! 13 Q You indicated that you have a general idea of what ;
! j4 =akes up the live lead of the diesal generator building. Can l'
a l D
5 15 ; you go into what your general understanding is?
a t
What we discussed when this question was under 3 16 B
A l i
2 g
. 17 cenreideration was that sc=a cf wnat is censidered live lead 1
a,.
E 18 it equipment, the weight of which presumably could he
_ i
=
t 19 reasonably estimated and evaluated. Some is such transient f I: g rs '
20 things as supplies that may be moved arcund c: even people. ;
i 21 That comes in a different category. ,
22 0 on a typical p;cject, don' t you usually exceed the 23 b >J.1 ding 1 cad by a facter of, say, one and ene-half when you ,
24 are placing the surcharge? -
i Cbdecticn to the tv.c.ical c 0 ject. I 25 ta :Ct. FARELL. s .
- ALDERSON REPCRTING COMP ANY. INC. _ . 1
60 don't knew what you mean by that.
.-7 ; ,' -
1 A I was going to ask what you meant by typical project 2 l 3Y MR. JCSES :
3 Q In the majority of cases in which 'ycu have used a surcharge load, have you usually exceeded the buildin, lead f g 5 l n
l
" by a factor of 1.5 with the surcharge, or around 1.5? I l
e a
6 t
1 i
e g MR. FARIELL: Lack of foundation. ,
- n. 7 j
3 g,
A Did you say have I usually exceeded the factor of l 9 safety by 1.5?
5 to i 5 No, have you usually exceeded the building lead of a j y; Q 3
- factor by, say, 1.5.
12 i
= Suilding load? l 0 MR. FAR ELL: i
= 13 !
3 MR. JClES : Building lead, the dead lead. l l E 14 I
- i Could 'pu read that back
t MR. FAR2 ELL:
!a 15 '
l e
3 (Thereupon the last question was read back by the 16 3
3 j 17 re porter . )
-l w l 3 !
A NC-
! $ 18 I r j
- 19 3Y MR. JCNES:
l 1 ' l M
l 20 ; Q Cn the :najority of the projects that you have placed 21 a surcharge lead, have you usually exceeded the deal load by ,
22 s ome factor?
23 A Whether I did or not was determined by the require-ments of the project. There is nothing =agic about any of ,
24 1 these numbers, whether the surcharge is placed to reduce futum l 25 ,
i ALDERSON REPORTING. COMPANY,.!N ..~ ' ,
m m, - e D 0 ea o .P S . .
o
61 4-8 1 settlements, if that governs the load, or whether you want 2 to :nake sure the surcharge is going to cause a failure of the i
3 soil c that the future structure will not fail, all of these 4 f actors influence the choice Of this ratio y=u speak 05. Them s-> 5 . is no standard number.
- 9
=p g 6 3Y MR. JCNES : i
.~.
$ 7 0 In referring to the three steps that you use in 3
j 8 determining the method for computing the a= cent of the sur-u
$9 charge lead and whether you refer to the third part, to a
{
I
$~
10 c cnclusion that the cdds were gecd, that the censolidation ;
- I k"
a necessary would cccur seen after a practical length of time, i 12 iE when you say removal in a practical length of time, were you t m
13
- cvided any limits as to the period of time for which the E 14 I d surcharge could be left in place at tne Midland site? I 1
e !
0 15 2* A Not in any f cr=al way. l 1
~
' t j 16 '
Q Were you provided in any informal way?
? 17 imp'ression of what the ti:aa d A My recollection of =y m .
$ 18 .
1 frame was is that two or three mnths would be quite acceptable, j
=-
l 19 i j j
one year would be quite c Icng time.
20 !
l ,
Q Who p cvided you with the se informal times? ,
21 There were several peoph A specifica]ly I don't knot.
22 i who had thoughts en this subject and expressed them.
l 23 '
l Q Do you remember who any of thcs e were?
4 .
A : don' t knew their names. They were people ccnces ned .
l 25 l
with scheduling and I don' t knew who they are.
1 l - ALDERSCN REPORTING _ COMP ANY. INC. t h T l0 90 0303 h
- wM JURXL
I i 62 i 4-9 Q Were they Bechtel personnel?
I i A They may have been Sechtel. They may have been l i
2 Consumers, I d0n't know.
3 Q Were they one or the Other thcugh?
4 t A Mest likely. f
- e 5 i n
" Q If a schedule had not been a significant consideratic nii 6
e e
{n in selecting of options, in your opinion, sight a different 1 -
7 3 remedial action have been chosed for the diesal generator 3 8 i.
n
! J building?
l : 9 I i !
1
? MR. FAR! ELL: W3uld 'vou read that back?
' i
- 10 '
E (Thereupon the last question was read back by the
= 11
< i i 3 . reporter.)
.E 3 : MR. FARIELL: Cbjecin, there has been no testimony I
= 13 a
3 that the schedule was a significant facter in consideration Ti 14 I i 15 and, therefore, your question has a faulty premise. l i
E
~. MR.. JONES: I withdraw the question. !
l 16 a
4
! M I
,- SY MR. JCIES:
)
a j7 You indicated that you received some informal informa ;
~
18 Q t tien as to time limits for the surcharge remedial action. Was E 19 x j M
20 scheduling therefore a consideration in your checsing the j 21 remedy to be used at the Midland site?
22 A Yes.
23 o Was it a significant consideration?
24 A Yes.
! 25 o If scheduling had not been a consideration in ALDERSON REPORTING COMPANY. INC.. --
i
. . l
~
! 63 1
4-10 1 selecting of options, in your opinien might a different remedAl !
i 2' action for the diesel generater building have been chosen? l.
3 A It wculd be pure speculation. It is pcssible.
4 Q Would you have preferred,from a gectachnical stand- .
, s 5 point, a different remedial action if scheduling had not been i i
l M t 1
2 6 a signficant censideration?
R R 7 ! A No. .
.- \.
l "s 3 ::o you feel transient future leads in the diesal ;
' 5 Q 1 i e l, ; 9 generater building such as an earthquake can cause additional !
i 2i y
10 cracking of the structure foundation involved? {
=
!3 II MR. FARIEM: Chjecdion, lack of fcundation. !
f 12 A I doubt if it would cause additional cracking. It i =
l
'E: 13 might change the size of some existing crac:u.
m ;
l = 14
! d 3Y MR. JCNES: ,
t g ,
15 Q Would you say it is nor=al engineeri.'g practice in j
- l.
~
16 l surcharging operations to =ake an estimate ci the amount of I I
F 17 settlement and the rate of settlement before doing the werk in d
= j!
s 18 the field? l
=.
- t I 19 j MR. FARNEG: Cbjection, compound and no definition 20 '
of normal engineering practice. ;
21 I hope he kncws what MR. JCNES: He is an expert.
! 22 l
normal practice is.
23 What is normal to you might not be MR. FARIE ,I,:
24 .
normal to him.
MR. JQ:ES: .You are not answering.
l 25l i
ALDERSCM RERORTING COMPAN't. INC._ _ . __ __. .
64 n 19 1 MR. FARE' L: Would ycu read back the question? !
i 2 (Thereupon the fellcwing question was read by the i 3 :spc ter:
4 '"iculd you say it is ner=al engineering practice ,
g 5 in surcharging Operatic::s te =ake an esti= ate of the I
N
- 1 2
6 -a= cunt of settlement and the rate of settle =ent bef ore 3
" i b 7 doing the wc k in the field?") !
l M i g 8 A I would say it is ac:=al practice when the results c
- 9 would be of some benefit and net when the results are not i .
4 10
~
j necessary. 1
_ t E 11
< 3Y MR. JCES - : ,
3 12 With respect to the diesel g anerater building of -
"f Q
- i 13
- Midland, in youn opinion, was it necessary fc esti=ates te ,
= <
= 14 H.
be made of the a= cunt and rate of settlement befcre starting
=
r 15 !
2 tc wc k in the fleid?
i
? 16 3 A Yes.
I a a 7 d
Q 3efere starting the surcharge program at Midland, ;
= ,
ili 18 i
=
were estimates made of the amcunt of settlement which could be 1
E 19 expected?
+
A 20 4 j A '
..t ". east one was made.
t 21 Q Who made that prediction?
i n l A I did.
23 C cc you recall what ycur prediction was?
24 MR. FARE *J : Objection. .Ee said estimate, net l Bi l p redictien.
( 4 1
I ALDERSON6EPORMeGiiAOMPAt+YcWG., --- .
a I, 65 l I
i 1
SY MR. JCNES: 3 2 Q De you recall what your estimate was?
t2 I l
3' A My estimate was that the range af settlement of 4
6 to 13 inches wculd be a pess '+= tic range, 3
Q 3efcre starting the surcharge p;cg:sm at Midland, o 5 M to occur?
3 6 were estimates made of the rate for settlement 2 7 A Yes.
i, 3 Q Did you make that prediction?
.: Estimate, please.
I 9 MR. FARELL: ;
z.
h 10 ' EZ..W .JCES :..: .
z i j 11 Q Esti:nate?
3 I I2 A Yes.
t
- li E 13 Q Do.you recall what your estimate was?
=
l n
5 14 A Yes, it vocid he fast encugh. I.
5 Fast enough for what purpcse? !
15 Q l 3
=
To acecmplish r he pe pese within..a reasonable length l g 16 A l 3
$a 17 of ti=e.
?
18 Q What was the basie fer your prediction of the 6 to 13 j 5
I Let :se ask you this.
- Is there a s 19 inches, yeux estimate.?
a I 3 difference between an estimate and a predictien? t 21 A Perhaps the terminclogy we want to really straighten 22 out is there is not a calculation implied in either the esti-9 23 mate c: the prediction, i 24 Q All right, with respect to the amount of settiament 25 i
ALDERSQN REECRTINCLCQhiPANY. I n g n u bd
I i
66 i
4 13 1 that could be predicted, what was the basis for your estimate 2 of 6 to 13 inches?
3 A The basis was in large put au least the knowledge 4 of the settlement that had cccurred and been reasured od the !
i g 5 diesel generator building and the rate at which it had cccurred W
j 6 during the period since the start of -its construction the
" 7 ,
time the discussions about remedial measures were going on.
j 8 In addition, of course, there was a general knowledge d
i 9 of the dimensions involved, the thicknesses of the fiil, and
~. l3
? .
l E 10 j the general character of the fill. l
!' Q Was lah data available to you to make your estimate s
\ .;
3 ,^
i
@ or had you looked at lab data?
- I
.g 13 A I did not u e any. I do not remember whether it was E 14 j g available er not. t F 15 l 2 Q Since you stated there is a difference between a t =
~
16 l compute *.icn and an estimate, did you make any computation r
E 17 on the amount of settlement which could be expected?
I G
=
$ 18 i . i
=
- A No. i i
C 19 l ,1 Q Ecw did you ccme to arrive at the esti.aate that the >
j 20 '
rate of settlement which would occur would proceed rapidly i 21 -
i I l enouch?
22 A Cn the same basis that I explained for the magnitude 23 of settlement. We knew something of the rate of settlement -
l 24 l
l of the rail structure in the early stages of the construction ;
l' 25 l
and that was a substantial piece of information. ;
- - ALDERSON fHEPOR-T4NG40MPANYMe -.. . ,
~' -
E
t 67i i
I
- -14 I Q Did you make any computation of the rate of settlematt i i
2 which would cccur? l 3 3 ge, 4 Q Sefera starting the surcharge program at Midland, ,
e 5 did you =ake any esti=ates of the response to be expected of i n ;
=e -
lll 6 the pieccmeters during and after 'surchargo?
R
= -
A 2. !
i 2 i
=
M 3
Q And did you make any ecmputation? 4 d
n 9 No, der _inttely =ct.
A z.
3 10 Q Why was not estimate or computation =ade of the :
e i
_ l I expected response to the piecemeters during and after sur-E 3
i 12
' z chargLng? '
-- i
- 13 It would have served no useful purpcse. !
j A I
E 14 0 Why? ,
i t.i
=
9 15 Whatever respense was observed,would be cbserved, ;
j A
~
E 16 there would be. nothing that cculd be dene about that'. The
= !
- 17 If equipment that was placed to measure the response was adequate '
E 18 ~
= to measure responses within a =uch wider range of expected values than was expected here. Perhaps you might say that that .
a 19 i n i 20 was an estimate in itself. sut it is a:.rathee obvious l 21 situation.
22 So in order to observe what was happening was c$1y 23 necessary to make that cbservation.
24 Q
Would it have been possible that you could.have developed high enough pere pressures to cause a slide of this 4
ALDERSON<REFORTING COMPANLINC.. . ~
t
"*w >===#
4 _ . , - . - - , _ _ + - - . . ,, , , _ , _ - - _ .-,
68 4 -15 I surcharged slope at the Midland site?
2 MR. FARNELL: Cbjection, speculation.
3 A I did not think so. 1 4 3Y MR. JONE:S :
e 5 Q Would making a ec=putation of the expected response n
l 9 g be forewarned of that possibility l 2 of piecometers allow you to R
b I during the scrcharging?
's S 81 M MR. FARE LL:
Read that back.
3
~.
9 (Therefore the last question was read by the 10 <
]j_
reporter.)
E 11 ^
No foundation and speculation.
3
< MR FARNELL:
" 12 f_ A Had I been concerned about a slide during construc-
^
- 13 i tion, I would_have cc,nsidered it as a problem in undrained E 14 ,
d' sheer strength, and I had a rough idea of what the undrained s,
15 j ; sheer strength was, and knowing the pere pressure under those 16
, l circumstances would have been irrelevant.
I
@ 17 I
a BY MR. JONES:
E 18
=
Q Sidn't Dr. Eendron express concern for a slide near l
19 l l' this surface water valve pit?
20 .
A I don't know. I don't recall.
+
21 .
Q Did you maLke any computation of the hearing capacity {i 22 ,
before the surcharge?
\;
23 A No, that is essentially the same question. I 24 . !
Q Was any computati:n made during the surcharge of the j I
25 i bearing capacity? ;
t
.. . ...,.. i.
QQ Ntg ALDERSON REPORTING.COMRAMY 6 Ig,R3
69
- -16 A l'ct that I knew of. j 1 .
4 2 Q At previcus meetings with the_ IEC staff, it was cc:
3 understanding that there was considerable pressure to re=cve 4 the surcharge as quickly as possible, is that understanding l 1
g 5 cc: rec *' .
i M i j 6 MR. FARSELL: Could' I have that repeated, please? !
~
m
$ 7 (Theraupen the last.questien was read by the
! E repcrter.)
d-9 A I would have characterized it as pressure. Ihere z I O '
5 10 was certain1v- a desire to get the surcharge off as seen as i z i
- I 11 it had acecmplished its purpcse. j
-i m
" l 12 What form did that crassure take? i E Q -
i
= i-9 13
=
=
MR.'?ARNELL: Please, pleas e .
l 3 14 2
BY MR. JCNES : i
= i 0
g
'15 What form did the expression of their desire to you Q t,
- i B
T 16 ' And by they, I mean 3echtel er Consumers. l take? .
4 t 9 17
+
d A I would say that on varicus cecasiens, varicus people,'l
= 1
-$ 18 and I certainly could not say who, would say, '"then can we take !'
=
" 1 19 j the lead off?"
20 Q Did they express a particular date by which they 21 desired that the surcharge, if at all possible,he re=cved?
22 A I recall that as we got further along in the p:cgram, 23 say, June c: thersahout, that people were mentiening August
- i 24 as being a desirable time to try to get it off. But I would .
l.
! 25 j j not c did not attach any particular significance to these ,
i 4
i IMP N ALCERSON' REPORT 4NC 1 t-
! J -oM o N. 20.
t 1
4 -17 70 1 circumstances. We were all anxious to get it off as soon as i 2' was reasonable, f i
3< Q Do you knew whether any computation of building stress l
l 4 due to the surcharge load was made in advance of placing the 5 surcharge on the diesel generator building?
g l; l
9 2 6 3 go ,
~
- n
" 7 Q No, you don't kncw, or no, one wasn't made?
- a n
a g' M A To answer your question, no, I don't know.
- 3
- 9 In your prafessional experience, have you been Q ,
- z. .
= '
faced with other profects where the foundation conditions were 10 '
g ,
=
5 II just as hetarogeneous as Midland's site? I a
" 12
@ A There are a good many varieties of heterogenity. and
= i
- i 13 l
g I would say, yes, probably many times. -
E 14 2
Q Cn those Fmjects, did you have to make estimates s
9 15
@ of settlement in spite of those conditions by using engineer- ,
- , p 16
{ ing judgment? {
F 17 l d MR. FARNELL: Objection. ;
c '
- o 18
=. ,
SY MR. JCNES: !
19 I l A For weight of soil properties? t 20 MR. FARNFLL: Cbjection. There is no testimony that ,
i 21 he has had to do anything with the surcharging which, I beljave,i 22 your question goes to. You asked him in general about his 23 experience. ,
94
^
MR. JONES: I did not use surcharging in the* first ,
25 question. l ALDERSON RERORTd4Mii.CCMPANY ANG. e m
< - . , - , ., ,-v -
- \
71 4-18 1< A Could you repeat it, please?
2 (Thereupon the following question was read by the 3I reporter:
4' "Cn those projects, did you have to =ake estimates '
g 5 of settlement in spite of thase con c , by using engineering a
j 6 justment for weight of soil properties?"?
~
n 3 7 MR. FARELL': Also another objection as to what, if
'n j 8 any, time you are talking about, i i
9 MR. JCES : I said in working with other projects. 3,
@ 10 . . MR. FARELL: At any time he was working on these z '
= '
II projects?
s
" 12 i MR. JCES : Projects he just referred to in the answ i
=
3 13 5 before. Listeh to the answers.
m lr 14 MR. FARELL: I will do my best.
j=
I 15 A I had made estimates of settlemerts on quite a few l
i E I0 =rojects.where it was imect tant to knew the settlement in I s ~
f i
' 17 advance even when the conditions were quite heterogeneous. !
'd_ ! i II These estimates general involved a rather wide range of results :
19 5 and judgement did not always succeed in telling whers; within_ i l
i 20 that range, the best answer might be. !
21 3Y MR. JOES: ,
22 Why was it so difficult at the Midland site to estah.-
'~'
Q 23 d Lisha. range cf foundation conditions that estimates future seta- ,
I i 24 ment if it was done in these other cases in similar situations ? , l 25 MR. FARELL: Could I have that read back, please? ;
1 ALDERSCN REPORTING COMRAN.Y.-INC ~...
l
. i 72 s
1 (Thereupon the following question was read by the 2 reporter:
3 "Why was it so difficult at the Midland site to !
l I
4 establish a range of foundation conditions that estimates g 5 future settlements if it was done in these other cases in R
l g 6 s?lar situations?")
I g i
' 2- 7 MR. E'ARSELL: I do not tbiak that is what he tes::ified X
3 8
' to.
- 9
.j A It would not have been so difficult to establish a 10 range, but the range would have been a very large one and them l i_
= 11 is was no need to have that information. -
- i 12 iE
^
SY MR. JCNES: ,
i 13 Q sut in these other projects that you menticned, you
=
=: 14 d ultimately did make a decision en settlement in spite of the h:
F 15 j heterogenecus nature of the involved soils, is th.it correct?
- 16 I did not ultimately make a decision on settlement.
$ A l
17 i
3 I arrived at a range and if the range was within what I or l E 18 '
- my clients might consider tolerable, I might adopt one ty e
" 19 of construction or proceed, or if it came outside of their range, 20 '
I might do scmething else. ,
i 21 !
Q When you say you might do something else if it ,
22 exceeded the range, what would you do?
23 A There were no two foundations in this world that are i l
ali%e and I would have done something-different than what I might 25 have done had the settlement been within the range that I ALDERSON REPORTING COMPANY, INC. :
l 73 5-20 1 thought acceptable.
2 Q could establishing a range for the Midland project 3' have provided that same function?
4 MR. FARNE Z- Cbjection, speculation, it is hypothe-g 5 tical, e
n j 6 3Y MR. JCNES :
R
& 7: Q In your expert opinien2 X
j 8 A I think it would have served no useful purpcse.
U 9 That same f.:nction dces act really exist in connecti:n with tii s !
i
=.
= I g 10 site. We already had part of the building. It was there.
z
!S II There is no question about how you would p cceed
" 12 !
E f rom the beginning. The questi:n is hcw we p cceed from wra re
=
1.
5 13 y,y,7,,
=
2r I# AM the seismic analysis of the analysis of the plant 5 -
Q !
= ;
j j= 15 fill; at Midland, don' t you have to model the difficult soil 16 stratificatien and assign representative soil parameters such i i e
I C 17
'd as sheer sedulists and elastic medulists and dampening ratio? i i =
18 Would you read back the last question?
_ MR. FARNE Z:
c 19 j (Thereupon the last question was read by the reporter.) I l 21 i
MR..FARNE Z: Cbjection as to foundation and also the !
l 22
! premise considering the difficult soil stratification. I don't 1
23 belia ve we have had any tee',cny regarding that.
24 . t A It is a compcund question. I think the answer to the s 25 second part is that you have to assign some values to these l
ALDERSON REPORT. LNG.COMPAbiY,.lNC_ .. ..- . _.
74 5-21 j properties in order to make the analysis.
2 In the first part, I agree that, I don't really 3 k.ar; what One means by modeling the difficult conditions of 4 stratification. l i
g 5; ay 3g, gogs:
j 6 Q Can you indicate for us what limitations in predicting
^
n
@, 7 future settlement at the Midland site, what limitations in s
j 8 predicting the future settlement are for a full scale test
- d. 1 9
j that was completed at the Midland site? i i
0 1
- 10 MR. FER.NELL: I Object to the word limitations.
5_
~
E g
11 A I think I have the question but could you repeat it d 12 '
j again?
m
- 13 ,
i (Thereupon the last questien was read by the E 14 i'! reporter.)
s
- 9 15 j MR. FARELL
- Are we talking about the diesel 16
$ generator building? I i 17 MR. JCES : For the diesel generator building. l 3_ I
$ 18 t
3 ,
MR. FARELL: My cbjaction stands because I do not !
l
- 19
$ know what you :nean by' limitations.
20 i A Limitations on the accuracy?
21 '
3Y MR. JOES : .
22 !
Q Yes.
23 A The predicted settlements as they have, I think, 24 l
generally been understccd and the answers to the questions 25 and so on have been determined largely by extrapolating the ALOERSON.RERORTJNG.COMRAblY.4NC . ... . -. s ..
i 75 22 1 straight line portion of tne semi-log settlement curves as if 2 the surcharge were going to remin in place.
3 The surcharge, of course, has been removed and will 4 stay removed and the permanent stresses underneath the structure!
5; in the sub soil will by and large be greater, will be less that 6 those that existed under the surcharge. Therefor 3, the settle-2 R
b 7, ments predicted on that basis , I think, are bound to be on M
j 8 the: conservative side. The real settlements should be d
~ 9 smaller. I would expect them to be appreciably smaller.
?
g 10 Q In ~ describing the diesel generator building program,
_E
' have you ever indicated that the building would go along for
-3
- 5 12 z the ride?
=.
j 13 MR. FAR3ET.J.,: Would you read that back, please?
E 14 l
i d (Thereupon the last question was read by the E 15 ,
n .
a reoorter.)
=
16 l' A My recollection is that I may very likely have 17 d said something like that as describing the situation before !
=
5 18
=- i we embarked on the surcharge program.
19 l There was a question at the time among some geople 20 on whether the weight of the building was causing some settle- ,
21 l
It was the settlement of the fill that was occurring
! : ment.
22 und.er its own weight that was causing the building to settle 23 and I think that is what I had in nind.
I 24 '
l SY MR. JCliES:
25 l
Q From. July 2, 197 9, to August 15, 1979, wnich I l
( ALC ERSON.REFORTING_CO M P ANY. INCs_ !
t
, , , . , , _ . , . . . _ _ _ _ . -e
76 5-23 believe was when toy started to remove timsurcharge, was there 1
any significant change in the piscometer levels to your 2'
recollection?
3 ;
~
2G. FAR3 ELL: Would you read that back' l
4 <
(Thereupon the last question was read by the e 5
% reporter.)
k 0 g A I would have to accept that that July 2 date is the 2
7 I g right date. I just don't recall that. Is that the right date?
2 8 N
d SY :G. JCNES : '
= 9 i Q Approximately early Ju?.y.
@ 10 .
j A The answer then if tMt is the right date would be j 11 3 yes.
ti z
12 5 Q What was the significance, if you recall?
d 13 m
- A There ware 40 piscometers so there were 40 changes, E 14
=
$ i and they weren't all the same in all the observations so I can 2 15 !
a i answer your question flatly mest of the piacometers indicated T 16 3
S at about that time a decrease in piecometric level, the order g, 17
$ of magnitude variable, but, say, up to a couple of feet, and a 18 4 A
" then a return to about the same level that had existed before 19
$ that time.
i I would say that approximately half of the 20 functioning piecometers at that time exhibited that behavior.
21 -
t
- Q Just to make sure that we are talking about the same ,
y thing, I as talking ahcut the month and one-half just prior to l 3 removal of the surcharge.
.g. A Excuse ae, I completely misunderstood it. j ALDERSON REPORTING COMPANY. INC. i
( . ;
i 77 5-24 Q You are describing after the surcharge was removed?
1 A Yes.
2 a F0m early July to August 15, and August 15 was !
l 2 when the surcharge-- :
4 ,
A (Interrupting) "' hat is why I don't think I un i t r-
" stood the question.
3 6 f
Q Was there any significance to the change of the 1 7, jn 8l pie mater levels during that period?
3 A The piecometer levels, as I recall in that period, ;
- 9 i 4
were genera y a y c ns an , u ey decreased s ugh Q j
$ 10 E
g ;;
with time in nuch the same fashion as the pond level decreased j m
d in that period.
12 E
@ Q I new show you a document that is labeled at the 13 a
E 14 b ttom, " Midland plant diesel generator building piecemetric a
h elevation versus time Piecometer 40, tip elevation 609.5,*
u 15 a
=
? 16 and this is part of Kane Exhibit No.12. I am marking in red ,
m A
g 37 the approximate period we have been talking about from early a
! 18 July to the surcharge rule and the surcharge rule is marked 5 19 on the document. I ask you to lock at that portion of that .
e n
Io piacometer data. I will ask if you can explain the behavior 21 of that piecometer during that period.
22 A The qnswer is a not quite flat Ott no.
23 Q Not glite flat out, dces that mean that you can 24 pcssibly explain what was happening in that perled? ,
i This is one of the deeper piaccmeters. That is , its 25 A ALDERSON REPORTING COMPANY..INC.
l 78 5-25 Its point was, I think, below the plant 1
i point is f airly deep.
2, fill or very ::aar the base of it.
3' It is my impression that =any of the deep piecometers 4 exhibited patterns or local variations that were somewhat e 5 different from those of the piacometers that were up in the 3
e j 6, consolidating fill itself.
a R
7' That is not an explanation, but it is a suggestion 1
2 i ,
j 8! of a reason for a difference d .
~
9 Q During the same period that we have been talking z,
@ 10 ' about, was there any significant change in the settlement z
!s II. readings to your recollection?
I II MR. FARNELL: Of the settlement markers?
13 MR. JCNES: The settlement markers.
m l:: 14 A Again, there are a lot of settlement markers and j*
15 ; sometimes the records differ a little bit from each other.
g 16 ' However, during this period it is my general recollectLon that 1 s N II all of the settlement markers were following the straight i_
E I8 l Line semi-log path that had been reached by most of them after 19 "g about Day 100.
l I believe that you said that the end of your period f t
1 21 was before the beginning of the streharge removal. ,
i t 22 3Y MR. JCNES:
J l
3 Q That is correct.
24 Then, yes, my answer is all right.
A g
25 Q I new show you what is marked as Figure 1. It is
- ALDERSON REPORTING COMPANY. INC.
79 M6 1 attached to Kane Exhibit No. 8, and at the bottom, it is 2 labe led, " Midland Power Plant diesel generator building, typi-3, cal settlement cooling pond level, piecometer level, and sur- .
4 charge load history. " I ask you to look at the first graph g 5 on the page which is labeled, " settlement in inches," and I 2
+
g.6 have ::;arked in pencil the approximate period we have been C
. $ 7l talking about and I ask you if that period is consistent with N
! 8 what you have described as the action of the piecometers duri:q l 0 l .
9 the period, or the settlement markers during the period we z
c y 10 l have been discussing.
z II Well, in the first place, this isn't a semi-log plot i A i
- a d
i 12 ; so that you can't very well detect that characteristic. And.
e l 13 the points as I would see them on this lina indicats'slightly E 14 i irregular readings, mostilikely indicative of survey inaccura-g '
0 15 h cies or survey limitations.
m j 16 I would suggest that if we are going to test the I " 17 l 3 ,
accuracy of my former statement we ought to look at the semi- r g
a 18 log ph: for this same settlement marker which is DG-3.
i
= t ,
19 l Yes, this Figure 3 in. the same deposition is a semi- l I 20 I f log plot, not a very clear one to me. It suggests that the .
21 !
points in this area we are talking about are indeed on a linear l ;
22 I think one might see the relation on the semi-log scale. f e
23 order of accuracy of the variations and their implication is j (
l 24 ;
a little better if we look at one of the larger plots.
I, 25 Q Did you,hefore deciding to remove the surcharge, !
ALDERSON REPORTING COMPANY, INC.
80 5-27 have an opportunity to review all settlement and piecometer 1
2; records?
3 A Yes.
4 MR. JCNEC: We will now adjourn for lunch. We will
= 5 return at 1:30.
A n
j 6 (Thereupon at 12:20 o' clock p.m., the deposi, tion n'
2 7 was recessed,to reconvene at 1:30 o' clock p.m., the 3
j 8 same day.)
d d 9<
2l ,
E 10 '
E E 11 d 12 z'
i 3
13 .
a l 3 14 I )
a t $
^
I ca 15 <
l z
~
5 16 l l
I e !
i 17
! a a
l 5 18 c.
19 l
20 '
i 21!
! 22 l
23 4 4
I l -
I l .
24 i
l I
25 i
1 i l
ALDERSON REPORTING COMPANY. INC. -
i
31 1 AFTERNCCN ';ESSION i
2 1:30 p.m.
i 3< MR. JONES : On the record.
4 4 BY MR. JCNES:
t 5 q. I am now referring to a document in Volume No. 3 2 1 3 6 of the 50-54 (f) responses, and on that Tab 70 which is 7, containing a letter from Dr. Afifi to--Irm sorry, a letter j 8 to Dr. Afifi from the consultants and it is signed by con-d 9 sultanc2 Davisson, Gould, Hendron, Lcughney and Dr. Peck.
to ' I have underlined a stacament on Page No. 4 of h
II that letter. I would ask you to look specifically at the g 12 l '
section I have underlined there in. red and could you just l:
E 13 read that line into the record after you are through reading E 14 !
, d it, pleasef i
e A. The sentence you asked for is, "If a suitable
? 16 j means is developed for making reliable temperature correc-
' 17 d tims to the readings of the precise settlement gauges, we
=:
5 18
= believe that removal could, if necessary, begin in August."
+
19 p, q. 0.K., my question is, were those reliable terapera-20 ,
i ture corrections made to your satisfaction before removing j 21 l l the surcharge in August?
- 1. I don e remember just what that situation was.
8 Ihere were temperature corrections made on some of the
- I think we decermined that at least some Borros anchors.
l of them didn't require the temperature correction because ALDERSON REPORTING COMPANYMG. - . -
_ _ _ _ . . _ . _ _ . _ _ . ~ .
32 6
5:2 1 the extent to which the exposed part was exposed to air 2' varied and in any event I was satisfied the readings were 3 precise encugh to go ahead and recove the surcharge in 4 August.
5 q. With respect to the Borros anchors which you in-j 6' dicated you did make some temperature corrections on those, R
$ 7 what procedure did you use on those? !
j 8 A. I don r t know what the procedures were.
e
- 9 q.' Do you know who made the corrections?
2.
A. I think the installation fn making the correc-h10
=
5 II l tions was done by John Dunnicliff or his organization. ;
a 12 Are you aware that John Dunnicliff has expressed !
{
~
l q.
l concerns on temperature corrections as late as February 8, ,
i n
I4 N . 1380?
15 i MR FARNELL: Objection, lack of foundation.
iE m
I' A. No, I am not aware of that.
II h 3T MR. JONES :
x
- q. Are you aware of any survey accuracy preblems at f.
j 19 l the Midland sita?
20 '
A. Well--
21
- q. Survey accuracy problems with respect to settle-22 ment markers and monuments?
23 A. Yes.
l 24 q. What is your understanding of what the problem 25 with the survey accuracy was?
ALDERSCfT REPORTING ~COMFAN"f 1NC.""' ""
83 6:3 1 A. I know there was a problem of transferring refer-2 ence points on the settlement gauges, the D.G. points pri-3 marily, where the surcharge was being raised to its final 4 height and another problem in transferring reference points, s 5' again, when the surcharge was removed, a
j 6 q. h t effect did these problems have on the accu-t k7 racy of the survey results?
j a' A. Very little after appropriate corrections were 9 made.
?
5 10 q. Is it your understanding that appropriate correc-II tions have been made for these survey accuracy problems?
l M
f 12 A. I made my own corrections. l
=
y 13 q. What method did you use for making your correc-n I4 ,
$ tions to the survey? l j 15 A. I was able at a few. critical, in a few critical, records, to relate to the measured settlement across the f16 3
17 interval which the transfer reference points occurred, to
?
I defend observations made by the deep Borros anchors. >
w i 19 ' What was the problem that had occurred in trans-j q. ,
20 ferring the benchmark allegations?
21 A. What appeared as the result of the transfer was a 22 step or break in the settlement curve that one might have 23 expected to be continuous. .
24
- q. When did this break occur?
25 !
j A. When the node was removed.
ALDERSON REPORTING COMPANY. INC. ~ --
84 When you made the comparison with the Borrus 6:4 1 4
2 anchors to sale your correction, what did your correction j 3 consist of?
l i
4 I am saying was this a mathematical correction?
l 5 L It was primarily a graphical correction with a g
n j 6 little arithmatic.
E 6 7 q. Can you explain the method you used to arrive at i
A 8 the change to make in the graph?
J
' L The record of each of the deep 3erros anchors
[.
10 was continuous from before the gap until after the gap j
II and it was possible to match the two portions of the curve 12 5 obtained from the ordinary reference points by assum{ng t :; '
l : 13 i that in the gap they followed the same path as indicated E 14 :
g by the Borros anchors.
=
^
15 g q. Are the deep Borros anchors located in the glacial f' till?
"1 d
=
L I'm not sure.
5 18
- q. If they were, would the action of the Borros 19 j anchors be related to the more compressible plant till?
20 L I don st understand chat.
21 q. If the deep 3ctros anchors were located in the 22 glacial till, would they give you any information as to 23 how the more ecmpressible plant till would react?
u L The deep 3erros anchor, each deep Borros anchor, i was associated with a surface point equivalent to a reference 1
l ALDERSON REPCRTING.COMRANL INC. . . .. .._.
i
85 3:5 1 point on the building, so'in effect they gave the same iaior-
! 2 mation as the reference points on the buildings would.
3 q. Are you familiar with the various types of settle-l l
l 4 ment markers and monuments which have been installed at the j g 5 Midland plant?
l N 1 -
6 To some extent.
l A.
+ 7 q. Could you identify the various types of markers l n l ! 8 that have been used at the Midland plant?
l e-l 9' E . FARNELL: All over the site?
l ;.
=
u 10 Yes, for measu & g seven.
i MR. JONES :
hII d 12 A. You mean just markers or various means of measur- ,
i ,
ing settlement? ;
}2 13 BY MR. JONES:
E 14 id q. All right, the types of installed markers and
=
E 15 r-y monuments.
~
16
.I know there were on the building, the Diesel 8 A.
l e 17 l5 18 Generator Building, scribe marks. There were other points
=
~
called reference points and I don't know what they were.
1 19 '
. A There were what we might call a shallow Borroe 20 '
anchor. There were settleeent places, more or less at the 21 foundation level. There wcre some Sondex devices that 22 turned out not to be very satisfactory.
23 Could you briefly describe what a sciibe mark q.
24 is ?
25 A.
A scratch on the wall.
ALDERSON REPORTING GCMPANYHNC: ~~- - -
86 i
5:6 1 q. That's briaf enough. Would you describe what a 2i settlement plata is?
l 3 A. I don't knew what they were specifically on this 4 project.
j 5 q. Can you briefly describe what a Sondex is?
j 6' g, 7gss a device in which a series of rings is
,~ ,
=
" 7c establishedin the ground with a tube dcwn the middle and
- i I E 8 a by probing through the tube with a transducer one can, d
) with luck, pick up the elevation at which the cransducer 10 i passes each ring.
j Q. Are you aware of something called a settIement i d 12 ,
- i rod on pedestal? i E 13 i A. What do you mean aware of it?
E 14 Have you heard that phrase?
t g q.
l E IS j A. I've heard the phrase.
T 16 j ,
- q. Can you describe what a settlement rod is?
" 17 l A. I can only tell you what I think it might be.
E 18
= q. Would you tall me what you think it might be?
5 19 l It would be a rod that goes dcwn through some
] A.
20 !
material that is obstructing a reference point on the 21 pedestal, say backfill, probably inside a pipe, where one 22 can read the elevation at the top of the rod and, thereby, 23 deduce the elention of the reference point.
24 -
- q. Do you know approximately when the major portion 25 of the markers and monuments which were installed at Mid-ALDERSON REPORTING 4CMPANYANC ... - -- . . . . -
1 l
87 6:7 1 land were placed?
2 L In the whole plant?
3 q. With respect to the areas where recedial action 4 was to take place.
5 L Only in a Very general way. I know there were some n
j 6 reference points on the building that were placed at an early R
" 7 I knew there were more established
- stage of the settlement.
- j 8 as the prehlem began to be appreciated and before the sur-l 1
a 9
l . - charge was placed. I don't knew any more than that.
10
$ q. That would have been that a larger number were E
l j II installed in the fall of 1978, that period?
d 12 i E
L That would seem reasonabla. ;
h q. Have the installed monitors and markers and I i E 14 l g guess I am referring to markers we have been describing, l 5 15 j been periodically monitored from their initial installa-T 16
} tion to the present time?
- 17
$ L 37 and large, yes.
E 18 ,
= MR. JCNES: Off the record.
+
j 19 (Discussion off the record.) ,
20 :
MR. JONES : On the record.
l 21 -
1 BY MR. JCNES:
22
- q. By and large, yes, they weee monitored. Does that 23 indicate that some of them were not monitored until the ,
24 present time?
25 L I intended to indicate that some of them were ALDERSOffREFORTINGCOMPAMY;'iNC.""" - ---- '
1 .
I 38 63 1 destroyed and, therefore, were not =enitored.
2 q. I now show you four documents. These are frem 3 the 50-54 (f) responses of Consu=ars Power Company and they I 4 have figure numbers and figure numbers are 27-83,27-113, e, 5,27-115 and 27-118. ,
M j 6 I ask you to look at those, noting in particular ;
7 the last date on which points are plotted for these resettle- ;
A 8 ment versus curves for the settlement =arkers, these various
{ 9 settlement markers, z
10 ' For the record these charts are settlement versus h
5 i j
II time markers for, I believe they are all 3ceros anchors. j-l d
- g. 12 -
MR. FARNELL: And they are dated 11/80 with the I
?
I# notation Revision 10. ;
i
[e I4 MR. JONES: Right, i j
=
15 BT MR. JCNES: [
My question is, do you know why the information f16 q.
17 submitted to the N.R.C. in November of 1980 presents records ,
5 18 for Borros anchors and settlement plates only up to the l
l E 19 A fall of 19797 f 20 I would assume this is not A. No, I don't know that.
21 all the information. You are talking specifically about 22 l these four graphs?
23 Right, as an example of what exists that =1ght
- q. ,
24 represent the entire series of graphs.
25
, Have you seen records for Borres anchors and ALDERSONWORT} NGL *CMPANY 1NC:
l 89 l
6:9 I settlement places as well as the other building =arkers we 2 have discussed that indicate measurements since the fall of 3
19797 A. No, I don't think so.
! $ q. Are you aware of whether any such records exist?
l 6
j A. No, I don't know.
- q. But it is your belief that they are being perio-3
- j 3
dically monitored at the present time?
I
- 9 g A. I have no infor=aticn, but I think this is pro-i 6 10 <
i bably so.
i' 11 q. In your opinion, is it still important to know s
i 12 :
l 5
how settlement is occurring within the various depths of
~
e 13 E the plant fill foundation soils?
l E 14
$ A. It is certainly of interest and it may be impor-
} 15 '
e tant.
( : 16 3 q. In what instances would it be important to know y 17 g this information?
5 18
- A. I would think it would be more important where i t 19 '
l A settlements under such things as water loads and the like 20 l
' might still be going on,if this is, indeed, happening, in i 21 <
contrast to, say, the Diesel Generator Building or where l
22 l
significant loads are no longer being added.
23 I think I should say, too, that even in the case 24 of the Diesel Generator Building, it is certainly of in-25 terest to see what is happening at this _ stage.
ALDERSONREPORTING COMPANY.' PNC" " *"- '
90 6:10 .
I q. Are there any areas in particular that you know of 2 at the Midland site that would fit your description of plant 3 fill areas where it might be important to measure, continue 4
to measure or monitor the markers?
j 5
, MR. FAMELL: Objection. It calls for an answer 6
5 that is possibly beyond the scope of this CM 10L / hearing.
x 4 7
- A. The part of the remedial measures I have been pri-E 8 5 marily and almost exclusively concerned with 1ses1, 7 is the i a 9
l j Diesel Generator Suilding . I don't really know what is
\ =
i: 10 g going on"elsewhere.
I 11
- q. Did you say you worked almost exclusively on the i 12 i Diesel Generator Building recently?
I --
13 ;
i A. Thats's right.
E 14 y q. What, besides the Diesel Generator Building, have I 15 j you worked on?
? 16 i
j A. Perhaps worked on isn't the right word. I have i 17 g b een kept somewhat casually informed about what is going on
$ 18 5 elsewhere and I have worked on the diesel generator.
I 19 A q. In your review of the settlement records of the 20 l Midland project, did you observe larger settlements in the 21 ene-depth interval of the plant versus other depth inter-22 vals ?
IJ MR. FAMELL: let me hear that back, please.
24 (Thereupon the last question was read by the re-porter.)
- ALDERSON REPORT 4NG COMPANY,1NC.~ -~ - -
91 ,
6:11 1 A. Do you mean by larger settlements larger coc: pres-2 siens in those depth intervals?
3 BY MR. JCNES :
4 q. I am referring to the ratio of given settlement or e
5 given depth interval. I am referring to the ratio of a j 6 given settlement over a given depth interval.
R
$ 7' A. I'm afraid I still don't understand. A point can n'
.4 8 settle but how an interval can settle, I can't quite--
e l .
9 MR. JOIES : Off the record, iE
@ .10 (Discussion off the record.)
=
5 II MR. JONES: On the record, a
12 '
{.- 3Y MR. JCNES :
I am referring to compression in those layers f
m I3 '
Q, .
N I4 as indicated.
=
= 15 h A. The broad answer would be yes. '
=
16 g
T
- q. Do you recall approximately what depth interval
- 17 3 showed the greatest amount of settlement?
=
E 18
= A. Compression?
i-19 ji q. Compression, the greatest amount of compression.
l A. My recollection is that the upper two depth in- -
21 tervals, which would be roughly the upper six or seven r 22 feet and then the next six or seven feet, settled or coc.
I 23 pressed about equally along given vertical lines, but at
~
24 l
the compression, it increased in both in a general way as 25 you wiigh from west to east beneath the structure.
l l
ALDERSON REPORTING'COMPANYPNG.e ** -"- ~-
l l .- __ _ _ _
92 i
6:12 1
- q. Do you know why this zone showed this variable '
2 ccepressibility?
3 A. Because it was more compressible.
4
- q. Do yort have any opinion as to why it was more 5
3 n
compressible at the time the surcharge was placed?
3 6 1 A. I th hk it was always more compressible and it !.
A 7
- became more equally compressible with respect to having '
E 3 A the materials under the action of the surcharge.
J
= 94 g q. ~4as the material in these particular intervals E 10 g generally homogeneaus?
i 11 l E A- NC. ,
d 12 :
g q. Do you know why the settlement curve for Building j E 13
, i Mrrker DG-1 was not provided to the N.R.C.?
2 14 f
=
A. At the moment I wasn't even aware it wasn't.
15 j q. Do you know of any building settlement marker 16 l
$ or settlement plate or Borros anchor within the plant fill G 17 y area which was surcharged that was directly monitored from 18 E the time of its initial installation in 1978 to the present i t 19 l
A time?
20 No, I don r t know.
A.
21 '
MR. JONES : I am now going to hand Dr. Peck a 22 document entitled Settlement Versus Logirhythm of Time Dur-23 ing and After Surcharge. This is for Marker DG-6. It was, 24 this chart, .:omes from Division 10 submitted to the N.R.C.
25 in response to 50-54 (f) responses and it is dated November
-- ~
A LD ERSO N *ME! PORTING C-G MP'A NYMMCF e~ '
- i 93 f l
6:13 1 of 1980 2 In the note en this chart it refers to a period 3 when temporary =a kers were used to esti= ate the settle =ent 4 of the per=anent markers, g 5 BY MR. JONES:
a 6 q. I would ask you if you could, on this chart, in-i l R
"- 7 dicate the period during which temporary =arkers were used !
3 A
8' comake the esti= ate.
J 9
[. MR. JCNES: I will ask the repcreer to = ark that h10 as Peck Exhibit No.1.
=
II 3 (TEEREUPON A CHART WAS MARKED BY THE REPORTER ,
a s y 12 AS PECK EIHIBII NO.1 FOR IDCCIFICATION.) !
E 13 g A. Cculd you review the question?
I#
l $ BY MR'. JONES : l u
-: 15 g q. The:nte is right at the bottom of the page there 16 l and 'a refers to a pericd of time when temporary =arkers
' 17
!! were used to estimate the settlement of permanent markers.
.E 5- 18
=
I ant interested in what period of time that was on that i 19
$ chart.
20 .
That s not so easy because I have to correlata 8
A.
21 days to dates.
l
- q. It was approximately 54 days to 230 days ?
23 -
A. That s about right. I am going to draw the red line 24 at about 53 days, right apprcxi:u ::aly under it, sini:e I 25 didu 8 t subtract, but that is about right.
ALDERSON REPORTING C43MPANYvifC.<- *~ - -'
l 96 6:14 1 q. I believe it goes to about 230 days.
2 A. Yes, 230 days is right about in here (indicating) .
3 ;. As I understand it, during that period temporary 4 markers were used to estimate settlement of per=anent =ar-5
$ kers, is that correct?
j 6 A. That is what it says.
R
$I q. Can you explain for us the procedure that was used "3
a 3' to estimate the settlement of the permanent markers?
- 9 g A. I can only tell you what I think was done.
E 10 i q. 0.K., would you do that, please.
25 11 g A. I think that sometime arcund March 22nd, the d 12 g permanent markers became obstructed by the fill, which was 5 13 l i rising up around all the markers, so new points, so-called i E 14 l y temporary points, were established above these markers 5 15 j and the elevation of those new and higher points was maa-
? 16
$ sured during this interval.
G 17 s Then when the fill was removed and the points are l E 18 l 5 again exposed, the levels were again transferred to the I 19 -
A original reference point.c. --
29 l 4 How would the curve at DG-6, how would the curve 21 for DG-6 have been developed based on the temporary markers ?
22 A. Some sort of a correlation would have to be made 23 between the elevation of the permanent reference point, 24 the permanent marker, and the elevation of the new ene at 25 ..
or about the time the transfer was made. This would involve i ALD ERSON@EPOR71NGJ3OMF3ANYWNC.vv-- -
- 95 5
- 15 1 determining in some way the difference in the elevation be-j 2 tween the old and the new cr the temporary and the per:.anent t
3 points.
l 4 q. Ceuld the opening or widening of any cracks in l 2 5' the Diesel Generator Building have affected the settlement l
j 6 of the higher markars?
I *9
$ 7 4 A. Yea. ,
! 8 q. In -he way?
\
J -
9 A.
l $ Very slightly.
, z 1 =
10 q. Is that = ore than an inch, less than an inch?
3 II A. Oh, I would think a small fraction of an inch. l a
l E 12 ' q. I show you a document that is entitled Settlement 1 ; ,
13 l Ve-sus Logarithm of Time During and After Surcharge and m
I# this is for marker DG 16. It is numbered Supplemental I
u h
15 Figure 27-64. This is also f om Division 10 submitted in 16 ;
l g
=
November of 1980, in the 50-54 (f) responses.
17 l hi 1 ask you if the rebound which occurs at the
- ~ '
N 18
=
pointin time which--and you.may want to correlata the j 19 dates and I believe it is again at approximately the time .
20 l
when you went back to the persanent markers rather than J
21 the temporary markers. ,, ,, ,,
22 My quastion is, could that rebound, large rebound i
of approxima.tely one inch which is indicatad on that figuve, 24 be the result of the procedure which was used in using the 25 tempor:2ry markers to make an estimate? l 1
A LD ERSON-REPORTING.GOMPANYr4MC3. - -- - --
j
96 5:16 1, MR. FARNELL: May I have that read back, please.
2 (Thereupon the last question was read by the 3 reporter.)
4 MR. FARNELL: I note for the record that this t e 5 document has some handwriting, the numbers, soc:ething, A
3 6 Revision No. 6 that apparently wasn t in the original.
8 i 3 .
i " ' Also, I am going to object to that questien on
$ 8 the basis of the lack of foundation and speculation.
J .
U 9 A. My answer is that a part of that apparent re-l 5.
h 10 bound, I will call it, is probably actual rebound and the -
II rest could well be a result of this adjustment or transfer 5
a g 12 ' of reference points.
- I g 13 3Y MR. JONES
n m
l i
le I# '
1 q.
Could the majority of it be explained by the 15 l
$ different, by the procedure that wasused in using the ..
16 ;
j temporary markers to estimate the level of the permanent d ;~' , markers?
! 18 i MR. FA*W.LL: Objectim, speculation.
g 19 J, A. Yes.
~a BY MR. JONES:
21 '
- q. Would the fact that part of this rebound could be 22 accounted for possible due to the procedure that was used in converting a temporary marker to a figure for the settle-ment figure for the permanent marker, does that affect the 25 eliability or would 0130 indicate there is a problem with ALDERSON REPORTING GOMPANY.-ING., . --- >- --
97 7:17 1 the reliability of the estimates ?
2, L No.
3
. Is it usually the case in dealing with surcharges 4 that--strike that.
e 5' Is it that period of time that we have been in-g .. .. .. ..
j 6 dicating on these charts when temporary markers were used, E 7 a period of time in which you have alleged--is it the ..
A 8 period of time in which the action of the settlement markers 3
9 has been used to reach the conclusion of secondary consoli-
- 3. ..
5 10 dation, that it was reached?
5 5 11 MR. FARNELL: Would you read that back, please.
l f
=
12 (Thereupon the last question was read by the
\
j-13 ,,pote,7,) ,
n ju I4 MR,FARNELL: Do you mean was that the exclusive j= 15 ' period during which or upon which the basis of secondary j 16
, consolidation--
1 s h
17 MR. JONES : (Interwpting) I asked him if that was
=
[!: 18 the period. I guess that was the question.
g 19 MR. FAENFU-: You asked him what, a period or n .
20 the period?
21 I asked him if it was the period.
l MR. JONES:
22 The exclusive period.
MR. FAANELL:
23 L Tes. .
24 3Y MR. JCNES :
25
- q. Is it unusual in your experience with aurchaving l ALDERSONREPORTiNG GOWANYt4NG.s ~n>.m ~
9S I that the section--that the period which is looked at to 2 determine whether the subject structure, subject soils, 3 are in secondary censolidatien wculd be predicted by 4
temporary marke-s?
5
$ A. No, it 8 s not unusual.
n .
l k6 E
Would you have more confidence in the prediction that the plant was in secondary consolidation if the maa- ..
I j a surement of settlement during that period had been on the 5 9 l g permanent settlement markers'vacher thanen the temporary
~
E 10 5 markers ?
=
5 11 l y L So,
- i 12<
$ q. If tha temporary markers could lead to some error
- 13 5 in prediction of the actual settlement, which I believe was l .. .. ..
g y indicated could be ene of the reasons for the cebound you P 15 j described en DG-16, would that not have an effect on whe-
.- 16
$ ther or not--st-ike that question.
~
p 17 1
s We will take a five-minute break.
~ ~
E 18 E (A brief recess was taken.)
19 l A E JONES: On tha record.
20 3Y MR. JCNES:
21 2 seferring again to the figure you have identi- --
22 .
fied earlier as 27-64, which is the settlement ve-sus 23 logarit.un 5 time for marker DG-16, my question is this. -
24 .
If the majority of the rebound exhibited on that 25 ..
diagram is attributable to the method which was used to l
ALDERSON REBORT4MG.GOMPANMdNGor: -m. . .i . .< u
._ . - _ _ - . . _ . , . . . _ . . . - _ . - - . . - . - . . . . ~ . . - .
l 99 1l co--elate the settlement from the tempora-y markets to the 2' pe-manent markers, doesn r e it follow that the portion of 3 the plot that relies on the temporary ma-ke-s is in c ov?
l i
4 L No, it doesn't.
g 5 4 Why would that not be the case?
u .. ..
j 6 L The only thing that counts is the relative ele-
". 7 vation of the points during this period. If the portion
! $ 8 nad f*om the so-called temporary points which are pechably l 2 9 in the structure today, was read cor-ectly with *eference
- 10 l g to, perhaps, an ineov-ect base elevatim , the slope of the l
lII line, the relative positica of all the points, is still 1
l 12 i i cor-ect. The slope is all we need.
1 l _
4 If an error is being made in a cor-elation be-tween the tempova-y markers and the permanent cavkars, wculd
= - - _ .... _ ... . -
15 h it follow the same error would be ma:! a with respect to each E _ .. _
~
16 l* temporary marker?
17 ili A Tes.
= 1 _ .- __ _ __ _ . . _
E 18
= 4 Have you rev4 eu the settlement ve-sus log time j plot for the bui
- sectiemec. markews, settlement plates, Bowres anchoes that were submitted to the N.R.C. in November 21 of 1980?
~
n
- L Tes. _ _ _ __
23 4 Do these plots of settlement for plant fill ma-24 I te-ials exhibit a rebound behavior ycu anticipated?'
25 L Tes, except fo- the magnitude of that break which ALD ERSON REPC RTINGrGOMPAMYMMC;.v" * * ~ * "-
D '" lD 9I
. M li)l Nfl1I[55KUL
100 ,
I includes sore than the rebound.
2' q. That would apply to other markers besides the ;
3 DG-16 m f ve been talking about?
l 4 MR. FARRELL: Your question was, I believe, to g 5 all settlement markers.
i N j 6 MR. JONES: I just wanted to make sure there was R
3 7
i no error, that he dida t think I was just talking about f
3 just this one.
e
^
l .
9 L Yes.
j 2_
10 BY MR. JONES:
=
- q. What amcunt of rebounding did you anticipate ,
lII d 12 z would occurt '
I a !
j I3 '
L I anticipated it would be a fraction of an inch. :
n !
!e I#
- q. What was that based en?
15 j L I guess you would have to say experience. It is
? 16 g i a fairly standard number for surebarging about 20 feet on F 17 j quite a variety of soils.
E 18
! = q. Would you say that is--strike that.
$ 19 j Is that approximately the magnitude of rebound 20 ,
l on which you observed in the steel tanks that you had ex-21 perienced surcharging in situations where there was a sur-22 charge of approximately the same size?
23 MR. FARNELL: Objection, lack of foundation.
24 -
L Yes.
25 BY MR. JONES:
- ALDERSONcREERORT4NG_GGMRANY vl%C.*: -~..:.
1 l
101 1 q. Do you recall whether, with respect to your past 2 experience, what the amount of rebound was in those cases, 3 in a general senset 4 A. Yes, in a general sense, a fraction of an inch.
) e 5, 4 When you say a fraction of an inch, are we talking j 6 about a quarter of an inch or a half-incht R
I E 7 A. , We are talking about something between zero and
,$ 8' one.
J 8 9 q. Fine. In your past experience, what was the time 2.
10 ' period during which the rebounding occurred?
h
=
l 5 II 'A. In :nost instances, it occurred during removal of 3
12 the surcharge and within one or two weeks afte:: ward. There
}f
=
l 13 are, of course, quite a few jobs with what I would call
!s I' appreciably different subsurface conditions where the re-j 15 bound takes longer and reaches greater magnitudes. i
? 16 3 q. In your experience, have you been involved with
- 1I d a project which was surcharged where the rebounding behavior E
18 <
l
- n
= was occurring one year after the removal of the surcharge? '
E 19 '
j A. Was still occurring one year after?
20 : q. Yes.
21 A. I don rt think on any surcharge job that I worked 22 on measurements were continued that long.
23
- q. Do you know with respect to Midland how long re-
~
l 24 hounding has occurred? -
A. No 25l
<. ALDERSON REPORTING.COMPAbiblNCevn.- ,. ... s.
l - .- --- --....- .-.- _. - . - - - .-..-. - - ---. -.. - , .-.
t i
102 -
l 1 q. What causes rebounding of a soil section after 2 surcharging? !
3 A. Usually rebounding is attributed to two phenomena.
4 One is an elastic recovery when the load is removed, like 5, any material.'When stresses: decrease, the material stretchas j 6' in the direction of that stress decrease and very often in .
- l h7 4
a rebounding job, this sc-called elastic removal isn te in- l, j 8 stantaneous and sometimes is called quasi-elastic and takes 9
- . a couple of weeks.
~
10 ' Beyond that there may be actual swelling, which is h
=
the reverse process of consolidation. Water has to migrate l lII E
12 into the matarial and be furnished to the soils so it can 13
,,,77, , ,
n i I# '
l3 q. Would you be surprised to learn that rebounding l g' 15 was occurring at the Midland plant as much as one year af- >
7 16 j ter the surcharge was removed?
" 17 '
d A. I would be surprised if it were very large.
x l
E 18 '
l
- q. But you would not be surprised it was occurring? ,
5 39 j A. I would be surprised if it were occurring--I would i 20 not be surprised if it was occurring at an extremely slow 21 i rata. You have to associate magnitude with the time in one 1 22 i sense, and it would be correct to say that rebound goes on 23 forever. But significant rebound doesn 8t.
~
- q. If rebounding was, in fact, occurring at the Mid l land sita ene. year after the surcharge removal, what would l ALDERSON REBORT4NG.GOh4P:ANYdNCm.w*sm -~ -
l l
. . ~ . _ . . _ . , , . , , . . . - . , , - . _ , , - _ . , - _ _ - - . . , - - . , , _ . . - - - , , - - - . - _ _ .
103 I that indicate to you?
2 A. Just that.
3 q. Would it in any way affect your conclusion that the 4 plant was in secondary consolidatien?
e 5 .
A. When?
i R
j 6 q. At the present, if rebcunding was cccurring one-R E
7 year after the surcharge removal.
j a! A. I dan s t think it is in secondary consolidation.
e 9 If it is rebounding, it certainly isn't.
[.
10 Rebounding and censolidation are contrary pheno- '
E
- " nena.
g 12 ' q. Could some of the rebounding behavior be caused by t
- g 13 ' pore pressures that have not been totally disapated by the E 14 d surcharge?
s
^
15 2 A. No.
?
j 16l q. Why not?
= 17 3 A. Bacause thar is a condition contrary to fact, as
=
5 18 l
\
=u far as Ira concerned.
l "
19 j q. Contrary to fact in what way?
A. There are no excess pore pressures there now.
I 21; q. 0.K., hypothetically, if excess pore pressures 22 existed, would they cause some rebound behavior?
~
23 A. No, if rebounding were cecurring the pore pres-24 sures would be negative with respect to the original pres-25 sures, not positive.
l ALDERSON' REPORT 4NGrCOMPANT.H*2.v tm - '-
1
i 104 I
Q. I am going to give you two sets of documents and 2 a fifth document to look at along with them. The first cue l
3 I am gong to give you and, again, these are from the res-l 4 penses to 50-54 (f) and they are all from Revision 10 sub-g 5 mitt d in November of 1980.
I R I '
2 6' The first one I give you is the settlement versus R
" I,
- logarithm of time for marker DG-14 and the number figure is "a 3 5
27-62. Along with that, I give ycu the settlement versus I
9
~
- time for the settlement plate, PL-13, and this is referred 3 to y to as figure 27-151. ,
l" Those two documents, along with Figure 27-79, from
- i 12 g the same responses, which is instrument location plan and
- 13 i surcharge boundries, so you can see the relationship of E 14 d the e two markers to each other.
e I
7 15 j I ask you to note the rebcund behavier with res-16 <
7 8 pect to each marker and then I give you the next set of i 17 y docments which is Figure 27-54, which is DG-6. We have
$ 18 g looked at it earlier and Figuee 2.7-158, which is the settle-19
! ment versus ti:re for settlement plate PL-21 and I knew this 20 was originally labeled PL-20, and it has been crossed out l
21 with pencil and corrected to PL-21.
22 l I note that on the computer printout pcrtion of 23 this diagran it is identified as PL-21. I will ask you to 24 make the same comparison of the rebound behavior with res-25 pect to those two.
A LD ERSCM B EPORTI NG.COM PANYeANG4. n-a- s.a - m. .
. - , = w -_-u;-_ _ a - A ._
I 105 1
Q. With respect to both those sets of documents, is 2 the rebound behavior for the DG markers greater or Inss than 3 the rebound for the plate markers ?
l 4
, MR. FARNELL: Objection, ccmpound.
jn 5 A. The offset in the curves is greater for the DG j 6 pistes than it is for the settlement plates. I den e under-8 i R 7 stand when you say the rebound that it includes somethi=g 8 that is not rebound and the answer would be yes.
a 9
- BY MR. JONES:
g to q. What is that something it would include that wculd 4 _
h not be rebound?
i 12 g A. That's the survey adjustment we were talking about, E 13
% an error in changing from the so-called temporary to the E 14 d
permanent reference plates.
? 15 g q, My question is, wouldn't it be more reasonable
? 16 S for- ell, let me ask you chis.
17 d
=
The DG markers are attached to the Diesel Generator E 18 g Building, is that correcci 19
$ A. Yes.
20
- q. The sectiement plates are located in the soil 21 themselves.
22 A. I chfn1r not necessarily. Some of them are. I 23 believe scue are on the msd mat.
~
24
- q. Assuming that to be the case, that the sectlement 25 plates are either on the std mat or located in the soil, ALDERSCN REPORT 4NdELC<.44PANW4NEn - ---
- - - , _ _ . . _ _ . . - _ . _ . . _ _ __ . _ . ~ _ _
106 ;
i !
I Wouldn 8 t it be more reasonabla for the lighter 2' settlement places to haie had a larger rebound than the 3 building settlement markers which are imbedded in the heavy 4 concreta struetures? P P
t 5 MR. FARNEI.L: Please read that back.
A j 6 (Thereupen, the last question was read by the re-
- I d I -
porter.)
j 8 MR. FARNELL: Objectien, I don t know what you 8
d 9,
mean by lighter settlement plates. I have no idea what
}
10 you meerr by more reasonable.
II MR. JCNES: By more reasonable I mean it had been
- i 12
-~ ,
y expected.
E 13 ,
g A. No. I I# I BY MR. JONES:
sr 15 j Q. Why nott
? 16 j A. Because the rebound of the building is a result
' 17 3- of the rebound of the soil beneath and around it; the rebound 5 18 g of the settlement plates is a result of rebound of the same ,
39 j mass of soil undergoing its distortion or volume change, so 20 !
that within the limits of any kind of accuracy that would be 21
- of interest to us, there would, I think, be no perceptible 22 difference and certainly if the settlement plates are on the 23 med met.; I would expect there would be no difference.
24
- q. Can you explain then why there appears to be a 25 larger rebcund for the DG markers than for the settlement l .- - ALDERSON. REPORTING.COMRAA&Y.-INC -.- . ,
I l
\ - . . . - _
107 1
plates?
2 MR. FARNELL: Objecticn. He also testified part 3' of the so-called rebcund was not really rebcend, as I recall.
4 A. Well, that was the answer to my questien. As far j 5 as I knew or have been able to determine, the transfer of 5
reference points that caused the discrepancy in the building l 3
" I
- markers did not apply to the readings en the settlement n
i 8 A plates.
J
= 9 j q. Does this behavic , which is at least partially 10 i the result of rebound behavior, lead ycu in any way to ques-
=
h" tion the accuracy of the data for the DG series of markers ?
l
! d 12 l z This is during the peried--
- 13
, i A. Only in the sense that it is necessary to allcw
. E 14 f
=
for the correction where the transfer was =ade.
^
15 j q. But that would still not affect ycur cenclustet.
~
16
$ that the secondary consolidation based en the explanatien ycu l $ 17 g gave earlier, is that correct?
E 18 5 ,
A. Thae8s right.
l $ 19 l
^
20 21 I
22 23 24 25 I
A LD E RSO N RE.=O RTING.3OMR ANYM NCa.w ow ..w - --
108 S 1=fg j C I will now show you a diagram, labeled 27-113.
2 Again, this is from the 50-54(f) responses. #s in the 3
settle =ent versus tire plot for Sorres anchor 3A-46. I 4 ask you to particularly note what I will call for the =cment j
' l 3
rebound behavior that occurred at surcharge re= oval. My j u
6 question is this. Can you exp1 in that large rebound be-a f7 havior? I assume a portion of it is due to the--
A (Interrupting) Well, first, I think you have to 5,
8
.a j s 9 explain two things in this disgrs=. It became ino'perable I i
I
.6 10 for some unstated reason af ter April 20th. Thenitwasreadj i i
!< 11 agnin, operable or not, when the surcharge re=cval took !
i a
d 12 place. I would have.to speculate as to what happened, but ;
Z !
5 13 , it is conceivsble, for example, that--
~
a l E 14 MR. ?AMV7tt (interrupting): I would ask you not d
u ,
2 15 to speculate.
l ;
6 : '
3 16 , IE3 WITNISS: 0.I.
t t a j I
d y BY MR. JON3S: l
(
l N
17 i
E 18 ' C I believe you started to say there were several I r
19 reasons and you gave us one. What is the other? !
i A
20 A The other la that there was some rebound, but l I
21 when a gauge is indicated to be inoperable we need to know l 22 why it is inoperable before you judge what the readings mean.
23 2 Do you have any knowledge why that 3orros 24 Anchor became inoperable? -
l, 25 A No.
\
, ALDERSCNJEPORT g ,
ww w Ju SU . \. fru o l - .
109 !
I s
3:2 1' 2 2 you have any kncwledge why any 3crros anchors 1
2 at the Midland site beca=e inoperable? l l
3 1 No.
, 4 2 Can you explain any reascn for the large rebou::d ,
a 5' tehavic:~?
n
~
6 A I don't k=cw if it is a large rebcund behavior. f a ,
1 -.
5, 7 C Assuming for the co=ent that large cebound behavio
~
n *
! 8 ras exhibited at 3erros Ancher 46, can you ::cw, in your pro n
.c
- 9 fessional expertise, tell ne what night have caused that Y
E 10 ' large rebound?
5 2 11 MR. Fla.N : Ihat is double speculation. Sece-i n
12 thing he said he doesn't know occurred then you asked--
4 E 13 MR. JOES (inte:rupting): I gave that as a ;
a :
14 hypothetical.
w 2 15 MR. 71 M *: It is double objectionable, a
5 e j 16 I would ask the witness ::ot to speculate.
- 2 l 6 17 TE3 WIIESS: If I don't speculate, I can't answer
, w
, z 5 18 the question.
, ? 19 , 3Y MR. JON33:
M i 20 < 0 0.I., Dr. ?eck, I am going to give you a hypc-21 thetical. As an expert witness, you are allcwed to answer 22 hypotheticals. I want you to answer the question af ter I 23 have laid out the facts of the hypothetical. I have a 24 building which has been surcharged with apprcx1=at"ely 20 25 feet of sa::d, which has re=ained on the site for approximate-ALDERSON BEPORM.GOMRAhL%lNG -Y ovAo we Y
ss A x -
110 3:3 1 17 six sonths. I have a 3erros Anchor that is placed in i
2 that site to seasure the settle =ent of the soil which is 3 being surcharged. I:sediately after re= oval of the sur-4 charge, there is a large rebound caused by--a large rebound e 5 in the 3orros Anchor. In your professional experience, in
?,
j 6l those circumstances, do you know of any explanation for the j a
a 7, large rebound behavior of that 3orros Anchcr?
M j 8 MR. ?A3 N : May I have that read back, please? l I
c n 9 .(The pending question was read by the reporter.)
i E 10 MR. ?A3.TELL: That =ay be a hypothetical question, !
E
=
j 11 but it appears, does it, not to have enough facts on which i a
y 12 ar intelligent answer could be based. In that position it ;
=
E 13 is vague and sisleading and highly objectionable. It also !
l l
l m
s 14 calls for speculation. l i
I i
E 15 BY XR. JONES:
a ,
E. t j 16 C Dr. Peck, do you have enough information on which e
i 17 to base an answer to that question?
x z
. E 18 A No. . ,
i l f& 19 C I will give you sore infor=ation. The soils, ,
I l 20 ' which are being surcharged, are identical to those which j 21 appear at Midland and, in fact, all cd:cumstances in this i
22 hypothetical are identical to those which occurred at the 23 Xidland plant and the only hypothetical part of this ques-l 24 tion is that I as asking you to assume in this hypothetical 25 that there is, in fact, a large rebound behavior with respect
- A LD ERSCE REPCRT4 m COM PML 4NC.s.-.,--- -
Um
I 111 3:4 I to that 3orros Anchor. Therefore, you can assume you have l 2 all the infor:ation you have ever reviewed on the Midland {
3 plant. 2, you have any explanation, based on your pro-4 fessional experience, as to what say be the cause of that i j
5 large rebound behavior? 5 I
g 6 MR. ?ARNILL: May I have that read back, please? f:
R
$ I (Zhe pending question was read by the reporter.)
~ l i 8 !
M MR. ?ARNELL: I as still going to object to it 9 j
[ . as being highly speculative.
i '
'j 10 A If part of the given information includes the
=
lU 11 '
earlier part of the 3erros Anchor record, I would suspect i that having four identical readings before the gauge became <
4 1
- 13 g inoperable =ight mean that the rod got stuck in the caisson E 14 E
and when the surcharge was re=cved it sacehow got unstuckin !
e 9
E 15 the caisson and it st:31ghtened out af ter being bent and the ,
T 16 , '
3 s
instruaent reacted.
F 17 I think =y objection was well-fou=ded d MR. FARNZLL:
=
$ 18
= as to speculation. ,
i b t 19 2
n 3! MR. JONIS: 1 20 ,
O If pore pressure still existed in the soil at the 21 time of the surcharge, what part would it play in causing 22 any rebound?
23 A If by a pare pressure" you nean excess pore 24 pressure, which would be positive, if it re=ained after the 25 surcharge was re=oved, the soil would still continue to
-- - - ALDERSON, RERORT4NG.COMBANL4NC..,, --w . _
n
, . I 112 !
9:5 i settle, then, until that pore pressure dissipated.
2, O What effect would that have on the rebound?
A It would be a negative instead of a positive re-3' 1
4 hound.
e 5 2 Dr. Peck, are you aware of whether there is a l M
3 6 significant difference in the a=ount of rebound on the east i, a
M 2 7 and west sides of the pedestal in 3ay I? >
I l 8 8' A 'Jo .
- M 1
I will now show you what is =arked figure 27-76, J
l c 9 C I '
5~
to which is again from aevision lo subeitted on 11/30 to the 1
2-i 11 50-54(f) responses. It is entitled " Settlement versus
\. u l j 12 i
los rhyths of time during and after surcharge."
Thin is 13 for Marker DG-28. I would ask you to direct your attention E
3 ll 14 to.the behavior of this settlecent marker between Days 300 2 15 and 400 on that plot. l a
z
? 16 A O.I. r n ,
2 i
i 17 C And I would ask how you would describe that be-a
=
l $ 18 < havior.
19 A 'Well, first, I would read the two ::otes associated 4
'M 4 with those dates approximately from which I would deduce 21 that there had been another transfer of reference point in 22 effect somewhere around Day 400. So there are really three 23 separa a sections of settlement curve depicted here, each 24 being separated from the other by a' discrepancy or. adjust =ent 25 in the reference bench = arks.
ALDERSON REPORTING. COMPANY..lNC.. . .. _.
i
113 936 1 2 Within that period, the 300 to 100 day period, ,
i 2 reccgnining that as a separate section, approx 1:stely a 3' separate section, c' '"a '"-ae separate sections that you 4 have described, how would you describe the behavior of the i
e 5
=arker within that period? f l a :
l
"* j 6 A For practical purposes, I would say that there i
, e l $ 7, was no significant settle =ent either positive or negative
\
j 8, going on, d
- 9 C And for the pericd i=cediately after the AC0th ;
j i .
=
y 10 day, would your description be the sace? ;
E i
}3 11 A Yes, it would be the same. .
y 12 2 What is your explanation of the reason for the f
_n 5, 13 difference in the level those two areas are plotted at?
s l 2 14 MR. FinntrI: Asked and answered.
, - c 1 1 '
- ; 15 A That 2 tells us that the reference point was
l w i j 16 destroyed and reins'talled. Ehat introduces the likelihood f a
17 at least of an adjust =ent or an error associated with the !
- r l j 18 1,7,113g, ;
n I s 19 3! Ma. JONES:
3 l 20 0 Isn't the a=ount of settlement plotted between l 21 the 300--approx 1:stely the 300th and 100th day? I am re-l 22 ferring to the periods as are indicated by the arrows.
23 Isn't the a= cunt of settle =ent plotted there independent of 24 the change in reference points?
25 A Ihe change in settlement, which I determined to be i
ALDERSON REPORTIN C_O M P N L 7
Q. ,
J WJu 4 ju , Jk
, t} ,
1 1 114 S:7 1 zero, is independent of the reference points. The a=ount i 2 of settlecent, asindicatedonthescale,isprobablyhigher,j t
3 at less; requires cor ection.
4 C Would you consider the behavior in this period to g 5 he indicative of secondary consolidation? i n ,
6 E. FiWUM : What period? !
- h 1 7 MR. JONIS: The 300-day to 400-day period. t i
j 8 A No. !
-J n 9 3? X2. JON33: <
- - i 5 10 ' C Wat is it about the settle =ent behavior that is '
3 11 indicated in that period that would be inconsistent with -
n 12 secondary consolidation?
I
{4 .
13 A I would interpret this as saying nothing is j 5 ~
= , i
= '
happening, it is neither settling or swelling so it is just l
l i 14 ,
l l L:
15 , sitting there. l l }= i j 16 C It indicates on the bottom of this chart that the ;
l = t d,
17 settlement marker was destroyed some ti=e after February .
- E l 3 18 19, 1980. Do you know how or why that was destroyed? '
n
- r=
19 A No. !
a t n t
~ '
20 C In this same area, are you aware--in this sa:e ,
21 area, I represent to you that Settlement Plate 2L-1, which 22 appears in Figure 27-140 of the 50-54(f) responses, became 23 -inoperable. This would have'been in March of 1979. Are you 24 familiar with why that particular plate became inc;erable?
25 y yo, A LD ERSON .5LEPCETING.COM PAN Y., INC_ . _ _ _ _ .
. . . . . . - - . . . . . - . . _ . . . .. - _. . . - . . . - . - . ~ --, .
i 115 ;
l i
i C In y ur pinion, do you believe there should be S:3 2 a monitoring, settle =ent monitoring plan for the Category I 3 One structures at Midland?
4 A Yes.
i a
~
5 C ?or future settlement?
n
~
e 6 A Tes.
e
- R
, A. 7 C Why do you believe there should be such a plan? l 7,
j S A After the considerable effort that has been de-
$ 9 voted or will have been devoted to various kinds of recedial i
E 10 seasures, I would consider it good practice to see what ,
E j
11 actually does happen.
3 :
(= 12 C What paraceters would be sonitored in such a plan? i 5 13 A I thought we were talking about settlements.
E i E 14 ' MR. JON35: Let's take a five-cinute break before d
u i 15 I launch into a new area.
a
=
j 16 (Thereupon a short recess was had.)
^ ,
i 17 MR. JON3S: Back on the record.
a x
$ 18 3Y MR. JONIS: ?
- i 9
j n
19 C I will now hand you a document that is a letter from R. Castleberry, project engineer, to Consumers Pcwer 20 21 ', Company addressed to the attention of Mr. Baucan. It is a 22 one-page letter dated Septe=ber 27, 1973.
23 MR. JON35: I would ack. that this be =arked as 2eck 3xhibit No. 2.
24 .
1 25 (IF3R3U?ON A L3TT3R WAS MA333D 3Y IE3 R320RT3R ALDERSON REPORT 4NG40MPAN%4NG. e - ..- -+
l l 116 :
i 3:o i AS PECI trwrsIT NO. 2 FOR IDENTIFICATION,) !
?..
21 3Y MR. JONIS:
3 2 I would invite you to look this over. 31 ease 4' direct your attention to the second paragraph.
i e 5, A All right. !
E <
n i 3 6 C In the second paragraph it reads that both Ir. .
e i i
i g
3 7 ?eck and Dr. Hendron have a hydro and coccunity facilities j 8' division consulting services agreement with the Geotech !
d
- 9 Department, and the rest of the sentence refers tc rein-g . I
@ 10 bursement. Are you faciliar with that consulting services z
11 a greement?
E ,
4 12 ' A Tes. l Z i g 13 C Does that agreement define the services you are j
= l lb 14 or were to perfors for the 3echtel Corporation?
!a 15 ' A Yes. '
3 g 16 ' C Is a copy of that agreement in the documenta you s
i 17 have provided to us?
a
= ,
E 18 A No. ;
3 19 C Would you provide us with a copy of that document? '
1 a . ,
20 ! A Tes.
21 '
2 I might note that we are not concerned with the 22 amount of rei=bursecent. If you wish to sanitize the docu-23 sent as far as figures, that is 0.I. wi.th us.
l 24 A Sanitize sight not be the appropriate verd, but I 1
25 get your drif t. I can bring it in ,tecorrow.
l l
ALDERSON REPORTING GOMPANM.4NC.~ ~~c> ,
D* 10 lD 0 3 l@
._ . - .o m M :o MU A AlnL.
~
, 1 117 !,
i S:10 1 XR. JOES: Off the record. ,
2 (Discussion off the record.)
3 E. JOES: 0: the record.
4 3Y E. JONIS: ,
e 5 O. Are you fa= illa r with Ter:aghi's one-di=ensic:a1 ft a
6 theo n- of consolidation? -
k A_ 7 A To a reasonable degree. l j 3 C. Could you tell =e what are sc=e of the i=portant
.g
- 9 condi* ions which are assu=ed in Tersaghi's cue-di=e sic:a1 i-
@ 10 theory of ccusclidation?
z The assu=ptions are that the volu=e cha=ge of a j 11 1 3
12 ele =ent of soil is equal to the volu=e of =aterial that i.=
~
E 13 flows into or out of it, the net volu=e. That the fluid, a Ihat the per=eability 5 14 which was water, is i=co=pressible.
-2
- a 15 of the soil is constant and that the flow of water into or
- i:
f 16 out of the soil takes place in accordance with rarcy's Law.
s d 17 0. Is the typical lab--I =cw hand you a docu=ent, E-i entitled "T7pical Labcratory Ti=e Settle =e:: 3ehavior Under 5 18
=-
? 19 ' Ocastant ?ressure," ?igure 27-1, and it is part of the 50-54 t
h .
20 ' (f) responses. This is frc= Revision 5 sub=itted in Februarf 21 of 1960. My question is is the typical lab ti=e settle =e=t i
22 curve prese=ted on Figure 27-1 based on the results and 23 observations of =any o=e-di=ersional lab :onsoli:f atio tests?
l 24 A Tes.
I now refer you to Iane Tahibi; No. 3, Iane 1
j 25 0,
! j -
l -
1 1
1 1
ALDERSON REPORT 4NG.GOMPANYdNG:e- r .e- ..
l 1 -
0**AD n *A0OS3Jk't.
- 118 3
- 11 1 Deposition'3xhibit No. 3, Page 3, and at the botta= of the 2 page I have underlined i= pencil a phrase which reads 3 "?ri=ary settlecen; occurred rapidly and settle:ent sessure-4 ments indicated secondary consolidation was occurring, as i
5 verified by the straight line on the semi log plot show
j 6' on ?igure 3. "
$ 7 i A I have read it.
~ i 5
i a 8 2 My question is is your statement on ? age 3 of 2
9 Iane Ezhibit No. S based on the typical shape curves for .
[.
0 y 10 establishing a primary and secondary consolidation that j l
E I;
comes from =any years of observing lab results and .fiel'd
. 5 i
@ behavior? l'
= .
= 13 I want it read back, but first of !
a MR. ?ARNILL: q
- 1 a
=
d 14 all, there is an objection of no foundation that Dr. ?eck ,
u 9 15 sz prepared this document. i
~
16 l* (Ihe pending question was read by the reporter.) {.
17 3 3T MR. JON33:- ;
E 18 You
= Q Do you know whether that is your statement? :
f
- 19 j '
can look at the whole document to establish this. !
20 I take it that this is sy written sus =ary A Tes.
21 of a verbal summary that I gave at a meeting.
22 1 Well, let se ask ycu if you agree with that state-sent. Maybe we don't need to worry 1 bout who =ade it.
~
24 t Tes, I gave the statement.
25 C ?ine. Is your agreement with that statement based 1
ALDERSCt+BEPQRENG)~ D Q q'~D
- m y --s..
"D c o.
of S. n
i i 119 Ss12 1 on the fact that the typical shape curves for establishing ,
2 primary and secondary consolidation, are they based on 3 typical shape curves for establishing pri=ary and secondary 4 consolidation that coces fres =any years of observing la'c i e 5 results and field behavior
- N 3
a 6 Ma.?n N : Objecticn. I don't understand the i I
R ~
$ 7 question.
j 8 A I ' thought that was what I just answered so I must i
e n 9 have missed the distinction. l,
( !
i 10 3! MR. J02GS: i' 11 ,
0, 0.I. , you are saying it is- the same as with your a
f 12 answer with respect to this curve, that they are both based l
=a
= 13 .on-- i
~
=
n 5
14 , A (Interap' ting) Oh, the statement and the curve
~
_E 15 a
are both based on laboratory and field experience?
=
j 16 Q, Yes. I an asking--you have stated that this .
s .
- 5. 17 document, which is 27-1, you have stated that that curv.e [
l
- o 18 is based on a number of one-dimensional lab consolidation ;
I : i
~
l 3 19 tests and I an asking if that statement is based on curves er 20 which have been established using =any years of observing 21 lab results and field behavior.
22 A With respect to the first question, assin, the 23 1 shape of that curve, at least part of it, the first part, 1
l 24 is based not only on the results of labcretory tests, but i-25 is also based on thecry, which agrees reasonably well in the 1 '
i ALDERSON REBORTING.C MEANLINC .. .-
99 0 P "9" '
b d 1. _
l i 1 l ' 120 l l l
i S:13 j pri=ary range. I guess I have lost the question.
l 2, C. In this statement where you indicate that pri ary 3 settlecent occured rapidly and settlement =easurecents in-i 4 dicated secondary consolidation was occuring as verified o 5 by the straight line, which occured on ?tgure 3, is tha; i ,
N 2 6 statement based on your corelating the actions observed at a
M E 7 the site with the typical curve exhibited in 27-1? ;
l X
! 8 MR. JOES: Off the record, n
s d 9 (Discussion off the record.)
i i: 10 MR. JOES: On the record.
E-5 11 3Y MR JOES:
m i 12 Q, Is your statement there by studying Figure 3 you !
i E h 13 ! reached a conclusion that there was rapid pri=ary consolida- ,
E '
E 14 ' tion, I have fo; gotten the phrase, in which you reached M ,
E E 15 secondary consolidation, is that cenclusion reached by '
a-g 16 ' comparing the Figure 3, which is, I believe, a plot of the s
y 17 actual action of one of the LG =arkers, diesel generator u
5 18 building markers, to a typical curve such as appears in ,
=
l )M 19 ,
Figure 27-1?
l .
I 20 ' A Tes, in a general way.
21 O If I understand correctly what you stated earlier i
l 22 in the deposition, you are opposed to taking borings and 23 runni::g consolidation tests with respect to the diesel 24 generator building because you believe they would : esult in 25 inaccurste predictions of future settlecent, is that ccrect?
ALDERSON-REPORTH9G g NC- g -
Me -.
n of A X ft h
121 !
4 1
i 3:14 1; A Tes.
l 2 O My question is isn't it contradic cry to rely c l 3 those sa=e types of test to both plo --: plot a ypical 4 curve which you rely on in reaching the conclusics that g 5 secondary consolidation has been reached, and yet to say 1 l
n j 6 tha: thos9 sa:e tests are too unreliable to =ake a presen:
9*
a 7; prediction of future settlecent? ,
l n
! 8 M2. 212N3LL: May I have that read back, please?
Y 9 (Ihe pending question was read by the reporter.) ,
l Z:
y 10 Ma. F13 NILL: Ihat is contradictory.
2
- e
!5
' ~
Il MR. JONES: 'dhy is it contradictory? ;
l 12 MR. ?iRNILL: It is cecparing apples and oranges.
E l
13 In the, field we are testing, in effect, the be-5 .
A m
5 I4 ' havior of the ecttre = ass of soil that is censolidating. l t
j=
15 - The real foundation :sterial in its precise state in which j 16 it exists. If we ran a series of loberstery tests on sa:ples 2 .
- 17 taken froc that deposit, we wculd get a whole series of 3
=
18 j curves that wculd be different from each other and we would i
n i 19 O
5 not be able to sort cut what is the resultant curve that l
- O should apply to the = ass of soil in the field for a nu=ber 21 cf reasons.
22 3Y M2. JON3S:
l 23 2 0.I. Ecw has that proble=, that individual con-
, ~
- solidation test results can vary and would not necessarily 25 nesult in the ';7pical curve, how is *he problec of the un-
)- - ALDERSON REPORT 4NGGOMPARYWNC.w ~u --
DnR 0 8 1
' N .i;lJiu
122 3:15 1 reliability of those tests, how come that problem does not 2 :nke the typical curve, typical laboratory tina settlecent ;
3 curve, inaccurate?
4 MR. FARNELL: May I have that read back, please?
I g 5 (The pending question was read by the reporter.)
a j 6 ,
MR. FA3.YZLL: I would object to it on vagueness.
R i E 7 3T MR. JON3S:
} 8 C Did you understand my question?
.s
~
9 A I th'.nk so. I 2.
8
@ 10 ' Q, All right.
z_
, !3 11 - A There is probably nothing wrong with any given i i
j
- 12 laboratory curve in representing that stage of consolidation -l g 13 of the particular sample that is being tested, but that
=
a 5
14 6 particular sample is not representative of the deposit in i i
=
j= 15 the field. It went through a disturbance in getting cut !
i j 16 ' of the ground and into the sampler. It went through a l'
- n
$ 17 process of selection. It represents a very tiny fraction !
13 of the whole' mass whose behavior we observed in the field. i n .
s 19 i So it csn't possibly represent the field behavior as ac- .
M 20 '
curately as' the field behavior itself. !
21 Q, But the typical curve is based on those types 22 of tests, is that correct?
23 1 Tes, to a large degree.
24 2 I guess my question comes down to why deess't the 1
25 problem that exists for predicting future settle =ent via a ALDERSCM BERORT1!9G cf MPANY INC-.... .._.. . .. , .
my % }'
Jus #
6 -
l l
1 123 a
3:16 1 curve plotted based on consolidation tests, why doesn't that 2 problem also =ake this an inaccurate prediction of the type 1
3 of curve to be expected? 37 "this" I nean Figure 27-1 t
4 A I could use curves of this sort frca a typical 4
5 test to predict with high accuracy the settle =ent of that n
5 6 i particular test, but that is not the settlement of the
" 7 deposit in the field.
A j 8' C Is the problem that the field is heterogenecus e
9 =aterial?
E.
Zhat is part of the probles.
h10 A
5 5
Il C 0.I. ' 4 17 is it that the variable foundation l
' " 12 E - soils 'in the field with their different cocpressibility
, 5 -
5 I3 charscteristics can be expected to exhibit the over-all
=
I4 typical settlement log ti=e curve shape, which is based on s
j* 15 sany lab tests, but yet if we were to take the best un-l g 16 disturbed samples from the representative soil zones and s
- 17 '
3 run the sade type of laboratory consolidation tests that z.
f5 18 ; the shape in Figure 27-1 is based on, you would not have 19
~
j '
confidence in those resulta?
20 Would you read that back?
MR. FAEGLL:
21 I
l (Zhe pending question was read by the reporter.)
22 I would object to that question.
MR. ?iMELL:
23
' There are =any different assumptions in that question. It 24 is of such a compound and convoluted nature that I don't 25 think Lt can be answered in a neaningful way.
ALDERSON. REPORTING C CMPAMLING -. .., , .. .
' l 124; i
l S:17 3 3! MR. JONIS:
2 2 Dr. Peck, do you understand the question?
3 A I understand some parts of it.
4 C Let's go through it part by part.
e 5 A That would be helpful.
a n
3 6 .C Would you agree that there are highly variable -
R l 3- 7 soils, foundation soils, at the Midland plant, which would l i i
'n 8
n 8 nor= ally be expected to have different ccepressibility d
= 9 characteristics?
I E 10 A I would agree with everything in that except the E
i 11 word " highly."
S i d 12 C 0.I., .we will take that out and call it variable ,-
z 4
E 13 ; foundation soils. !
- l,
= .
a E 14 < Af$er,.the surcharge, is it now your belief that ,
i 2 15 these soils can be expected to exhibit the over-all typical S i
^ ,
j 16 settlement log time curve shape in the future?
s i 17 A They exhibit it at present and I see no reason
- a x
y 18 why they wouldn tt. in' the future.
n
}M 19 C And they are exhibiting that typical behavior
- which was based on m/any lab test results?
20 ,
The typical 21 .
behavior was based on =any lab test results, is that correct?-
1 22 A Originally I think you could say the shape of that 23 curve was based on theory on typical lab results. We have 24 so many field observations today I think you can say that 25 the curve is also . typical for field behavior.
- m. A L D E R SO N R EPO RENGLGO MPJubiY el NC.,~ ~w.. . - . -
125 ,
i 2 V:7 1' *:--let's go one step further. I believe ycu 9:13 1 2 have 1:d'.cated that even if we teck the best undisturbed 3j sa:ples t:c: representative 3011 =cres i: the '-2d12nd site 4 and we were to :.:= the sa e type of labernicry ec=sclidatic:
e_ 5 tests on those sa=ples as was used to origi:: ally fer: ::e n
N
~
- 6. .
t7pical curve in yigure 27-1, that you wculd =ct have ec:- .
M A_ 7< fidence in those results? .
3 8 E.?i3m: May I have that read back, please?
n
- J
- 9 (Ihe pending questic: was read by the reporter.)
i F to E. ?A2 ELL: Dr. 2eck has ::c: testified ca:
5- 11 there is such a thi::g as representative soil cc=es. Indeed, s
d 12 1. celieve he testified quite to the opposite. There is a:
z
- i assu=ptic: in your questic: that is unicunded.
E 13
=
m 3 14 A Could ycu clarify specifically what you :es= by i:
~
2 15 "those results"?
x
=
3! M . JONTS:
r 16 f
a l ij- 17 0 37 "those results" I a: refer:1:g to the use of a
E 18 the results to predict future settle e=0 by for:1=g a ,
E 1 k 19 curve.
A 20 A If you are going to predict futu:. aettlements 1
t 21 c: the basis of consc11datic tests, you have to have cre l }
22 ' tha just that curve. Yeu would have to have a whole fa:lly l
23 of curves icoking sccethi::g like this frec the ccusclidatic:
24 tests in which you put a series of Icads c=. You -would have 25l o ec=sr.:ct frc= that family cf x27es the prt ssure void 1
l i A LC ER SO N iME90RT4tMii.COM PA e&4 o NCa a , - -
qmD D D wsS w I .$ $3 .a
}
I 126 e
i 3:19 I .
rstic curve. You have to decide on what lead or what stress 2 is going to be acting in the ground that is the equivalent 3' to--that represents the settle =en: that ycu want to co pute.
4 Tou put all those things tode:her to get a settle:ent fore-e 5 cast. With the field curve, all I need is that field M
~
2 e
6 curv'e .
o
~
?
7; 2 3ut you would get those curves you have described i M
S s 8 and values from the ccusolidatics tests?
d 9 Tes, a lot of curves.
!. A
=
10 Doesn't the large-scale field test, I a:
g 2 0.I.
!a II . referring to the surcharge,. have limitations as far as
" 12 E
predicting future settle =ent?
- 13 A Tes.
3 14 3 2 What are some of those ll=itations?
> =
l = 15 l t A First of all, under the conditions we have at
=
I' Xidland these li itations are of negligible i=portance.
E l
M 17 With the lisitations, however, that the field cbservations
=
18 should be reliable to the extent that the necessary quantity n
i
,z 19 that you collect from the data would permit a reliable fore-20 '
The second li=itaticu would be that the leading cast.
21 conditions in the field ar.e properly related to the leading 22 conditions that will er.is: under the structure.
2 Would the effect of irregularities in fmundations l
24 1 such as conduits or pipes affect the reliability cf the
- 25 large-scale field test?
i . ALDERSCN BEBORTING4CMEAhl% 1NC . ._. .
D""D
- w ]A)fg' SU M
3 127 ,
I 3:20 1 A No, I don't think so because all of these things 2 are included in the nass of soil that has been subjected to 3 this large-scale field test. The test, in effect, inte-4 grates all of these things.
e 5 2 If any of those conduits or pipes went down to j 6 glacial till such that the glacial till was providing so=e l
R
$ 7' support for the=, would that then affect the reliability of j 8 the large-scale field test?
-J 9' A No. I think it would affect the reading that Y
@ 10 you got frcm the instru=entation so that you would be looking:
3
)3 11 ' at a different set of data to evaluate.
12 Is it possible that the piping or conduit could
{ ,
C.
g 13 cause a bridging effect over hard spots, over soft spots a
n
- 5 14 ' in the soil?
t:
j=
15 MR. FAE N : Objection. That calls for specula-E I6 tion.
s 17 A Would you like to define " bridging effect"?
=.
g 18 ' 3Y MR. JONIS:
19 "s C I am referring to the situation where a pipe, a 3
20 horizontal pipe, passes frec a hard spot or less compressible 21
, soil and passes over a ore compressible soil and then 22 passes over a less compressible soil again, such that the 23 soft soil settles away from the pipe, but the pipe is sup-24 ported by the two hard spots and, in effect, forns a bridge D over that.
ALDERSON CCEORTING.c NYv4NCrn wem - --
- q' A'
D"'"}D o e Ju aju,J fjh ,
_ . . - _ __ .~ _. . - . . - . _ . __.
< l 123 i i
i C:21 1 A No.
I 2 2 Why wouldn't that affect the reliability of the 4
31 4 field test?
4 A 3ecause there is no co'.1vation for the soft soil i
e 5 to settle away fros under the pipe during the surcharging n
n 3 6 when everything is settling under the weight of the sur- ,
a ,
I 3 !
. # 7 charge. l
~
Isn't the soil at the Midland site settling under N
8 n
a C
-J
= 9 its own weight pric: to the placing of the surcharge?
Y E 10 A Tes. -
5 5 11 O Why. would that still not be taking place in the a
y 12 ci:.cumstances of the pipe I have given with respect to sof t
.=.
s- 13 esils?
- 5 14 A 3ecause we put on such a large surcharge that we .
w 3:
2 15 have consolidated everything.
a
=
g 16 C Woulc the difference in the caterial compressibili:
s i 17 -
have any effect on the reliability of the large-scale field a
=
s.
= 18 test? '
=-
t 19 A No.
5 20 0 Is that assusing that the surcharge was lef t on 21 long enough it would ::ot have any effecM 22 A Yes.
23 C Wouldn't the bridge effect that I have described 24 prevent the full load of the surcharge fres being.ingesed on 25 those soft spots that were being bridged?
-._..x 1 ALCERSONrREPORTING.EOMRAN_YvJNC.e .- m .-
Y -w,e- -
-- w- % - -
y -
129 >
9:22 1 A Tes.
2 2 Under those circu= stances, would the result then 3 no t possibly be that those soft spots wculd Oct have been 4' surcharged to the poi = that they have reached secc=dary o
5 consolidation?
M o 6 MR. FARELL: Objection. That calls for specula-a n
5 7 tion.
If the load never got under those soft spots, but 8 8 A
$ 9 was car:-ied elsewhere, then it is tha: :sterial elsewhere i-10 that is carrying the load and there is sc o:ivation for z
j 11 the sof t spots that cidn't ca: ry the lead to ever pick up a
l 12 , any future 1 cad.
=
3! MR JOES:
- 13
=_
j j 14 1 Do you feel, with respect to the lab cc=solidation
=
E 15 tests, which you have expressed scre doubt as to their re-s g 16 4 '
- ability for predicting future settle =ent, do you feel 1
ifa 17 ' that you could' ccce to a reasonable interpretatien of those
=
$ 18 censo11dation test results with the Corps of Engineers and 2X 19 the NRC staff?
w 20 MR. FA3NELL: Could I have that read tack, please?
l 21 (The pending question was read by the reporter.)
l Do you mean a reasocable settle =ent t
22 MR. ?AITSLL:
I 23 predictic ?
24 3Y MR. JOES: -
25 2 Let's change that to could you cc=e to a rutually i
. i ALDERSON.REPORIING.CCMP.ANLJNC .. ..
1
130 l 9:23 1 agreeable interpretation?
2 E. ?AR:GLL: That doesn't satisfy y objection.
3I It is speculation of the rankest sort.
4 S. JO?GS: I believe " rankest" is an injustice o 5 to the Inglish language, n ,
j 6 3T E. J02GS: i M
= l' 7
l
}
3 C. Would the fact that the soil was cc=pacted dry ;
i i 8 a opti=un affec: the reliability of large-scale field tests?
-J 9
E. ?i W I: Objection. There is nothing in the E.
- 10 g record that indicates they were co=pacted dry opti=u=.
II 3 E. J0!GS: I have a contact problem so we will a
" 12 1 E just have to hold up for a second. i E 13 t 2
E 14 ,
u E
E 15 a
z 16 i 3
a i i
f-'
a 17 a
t =
$ 18 i i
t E 19 n l l 20 .
21 i
22 '
23 24 ,
25 ALDERSCN MPORTING mMPANL.INC..- . . .
131 10:lkjm j Q. Did you at any time have a concern that the soil at the Midland site may have been compacted dry of opti mun?
2 3
MR. FARRELL: What do you mean by concern?
4 A. It wasn't a concern. It was a question or a hy-
. 5 pochesis.
A h6 BY MR. JONES :
. 7, Q. Did you ever get an answer to that question or j 8 phypthesis?
d t
l d 9 A. Yes.
Y 6 10 Q. What was the answer?
E
_I 11 A.- The answer ultimately turned out to be that it i :i 12 wasn't compacted dry of optimm.
l 5 5 13 - Q. How'did you come by that information?
E
] 14 A. There are, at least, two pieces of information.
E 15 , Que is that there were determinations from borings of water 5
g 16 contents, plastic limits and liquid limits, af ter pl.acement s
i 17 of the plant fill and when those are plotted against depth 5
E 18 they demonstrated that the water content in the fill, as 1 a 19 ,
placed and as compacted to whatever extent it was compacted, 20 ,
varied from slightly below to somewhat above optimum.
21 ,
The second piece of information was a correction of 22 ,
some misinformation in my earliest meeting there, that this 23 had been an unusually dry season.
24 Q. If the soil had been commacced dry of opcimum would 25 that affect the reliability of a large scale field test?
) ALCERSchtHEBCRENGGCMPANE4Nfue. mr. -
i 132 10:2 j A. You mean the surcharge?
2, Q. Yes.
3 A. This would decend on several circumstances.
4 Q. What are chose circumstances?
A. One would be the extent to which the compacted fill g 5 n
b was exposed to water, after ecmpaction.
a 6
Another, and the most important one would be how f7 j g dry of optimum that was compacted..
N 9 Another would be to what extent the material had i
$ 10 been dissociated or fragmented during compaction, if it was E_
5 11 dry of optimum.
d 12 At least those factors would have some influence.
E
$ 13 -Q. Would borings enable you to ascertain the informa-Ei
[ 14 tion which you have just described as being necessary to 15 ! determine whether or not the large scale fiald tests would s
f 16 be reliable? We are still assuming that if it was placed e
i 17 dry optimum.
$ i 5 18 MR. FARRELL: Let me have that question back.
ii
$ 19 i (Thereupon the last question was ready by the A
20 reporter.)
21 A. They would have provided some useful information 22 on this point. -
23 BY MR. JONES : ;
24 Q. Did you ever indicate at a July 1980 meeting with t 25 the NRC that a pessible explanation for not reaching high i
f ALDERSON:REPORTINGCOMPANYu4NO.wrrm ' ~
133 10:2 3 pore pressures in the piezometers was because the soil :nay have been placed dry of optimum?
2 MR. FARRELL: Read it back, please.
- 3 4
(Thereupon the last question was ready by the e 5 reporter.)
l July 1980, I think we discussed or I may have said h6 A.
. 3 7 that if the soil had been. placed dry of optimum this might 8 be a reason for developing ratber low pore pressures.
N 9 BY MR. JONES:
i 5 10 q. Would raising the water table concurrently with E
runnin'g the full scale field tests affect the reliability i 11 5
d 2
12 of the results of the field tests?
13 3. , Not to an appreciable degree. It would have had to i
lt 14 be taken into account in the interpretation of the results.
f 15 q. Did you take it into account when, you were inter-A j 16 preting the results?
s y 17 A. Yes. I took it into account by deciding it wasn't a
l s la significant.
i:
{ 19 ,
- q. What led you to the conclusion that it, in fact, "J
20 was not significant?
l 21 A. Well, first of all, because I decided that the water 22 content was not below opef men or not appreciably below opti-l 23 mum.
24 c. Before the surcharge load was applied in danuary of
- 25 1979, had the settlement of the plant fill soils reached a i
l ALDERSON SEPORTING.GOMPANY.4NC , , ms, . e nt. -
134 10:4 very small rate of deformation?
3 A. Very small is not very quantative. It was still,
- * * 'S"# 7 "M "*" ' * "" ' *EE * * **
3 Q. O.K.
4 en nnn ng consoM dation tests is it numal prac-3 5 n
y tice t wait until the rate f deformation under a given 6
7 loading increment becomes a very small rate , relatively small
} rate? ,
M 8 A. There are really several normal practices. In one N 9 t
$ 10 type of consolidation testing,possibly the commonest one,
~
z
! 11 one waits until the straight line plot on semi-log time curve E
- d 12 becomes. evident. That does generally indicate the end of 5 13 primary consolidation, but one may leave the load increments -
5 I 14 on considerably longer.
it 15 ' q. If the plant fill at the time that the surcharge i
.' 16 was placed was still settling at an appreciable rate wouldn't t 3 1
i 17 this then sake it difficult at Midland to estimate when 5
li 18 secondary consolidation was reached under the surcharge, be-E O 19 cause we still had settlement remaining in the plant fill R
20 due to its own weight?
21 A. No.
i 22 q. Why*
l 23 A. It would make it difficult to sort out what was goin l
l 24 on during the primary consolidation, but there would be no 25 cuestion about when one entered secondary consolidation.
l
.- . ALDERSONRERCRTMmWPM.1C m, . . . .
1 l
1 135 10:5 Q. What would ycu estimate would happen to the semi- !
3 log time curve that Bechtel has provided, if the log of ti=e i
egan w e emp et n p acem ne, rather tb n 3
with the start of the surcharge?
4 e 5 MR. FARRELL: May I have that back, please.
~
3 6 (Thereupon the last question was read by the 4
f7 reporter.)
3 MR. FARRELL: I object to thac.
$ 9 There are a lot of different curves that 3echtel i
$ 10 provided, this question, therefore , is highly compound and 11
-I think probably you are comparing apples to oranges, if d 11 4 you are comparing soils and diesel generator buildings.
E j 13 ,
3Y MR. JONES:
E E 14 Q. Did you understand the question, Dr. Peck?
a E 15 A. I think so.
s j 16 If one had plotted the same data to a different
=
, i 17 log time scale, to a shif t in the ti:ne access , which is really E 18 what you are saying, the shape of the curve would have been E
D 19 slightly different. The slope of the secondary portion would
. N 20 have been slightly different, but the extrapolated value of 21 the settlement after a very long ti:ne would have been about 22 the same, irrespective of the origin of the time curve.
23 Q. Then I believe what you are saying is, it would 24 alter the time for primary consolidation as you were to plot 25 4 the curve?
ALDERSON REPORT 4NG 60MPANY.6% smw . e-t . - _ _ _ . . _ _ _ _ _ _ _ -
136 10:6 A. No, I didn't say anything like tha t.
Q. O.K.
2 A. The time at which the transition occurred frem 3
primary to secondary , the day at. which it occurred, would 4
n t have changed.
5 Q. That v uld change?
6 Would not have changed.
{7 A.
8 4* - Did you previously indicate that you used current
$ 9 borings to assess the fill moisture content?
i
$ 10 A. No, the borings I was referring to were, I believe, E.
E 11 made.in 1978 12 Q. Do you know when the moisture content tests were i
~
5 13 'run?
E E 14 A. No.
d
=
i l 2 15 Q. Do you know if it was in 1979 sometime?
5 j 16 A. I don't know.
e i i
l
's. 17 Q. Wouldn't current borings show the effect of the E
18 present water table and not compaction moisture? By current t*
i 19 , I mean the ones that have been proposed.
a 20 , A. They would show the final result of whatever has 21 happened, up to this point.
22 Q. In your professional experiences do you know of any 23 cases where a structure founded on soils stopped settling for 24 a period, a long period, and then began settling once again 25 with no additional increase in loading?
ALDERSON:fMERORT4NG.GOMP.ANYe+NCw~s.s . -A
l 1
4 137 10:7 A. Yes.
3 2
Q. Could you identify the ciret=nstances in which that 3 i occurred?
A. One st=ucture was the Auditoriu= Suilding in 4
. 5 Chicago, which had virtually stopped settling after several n
2 6 decades and, then, settled again by a s:sall a:nount.
7 Q. Do you know what the reason for that renewed settle-3 3 :nent was?
n
$ 9 A. I think so.
I E 10 Q. What was it?
5 11 A. An all ti:na low in the level of Lake Michigan which a
d 12 is, across the street from the structure.
E_.
E 13 Q. Any other situations?
E
(
j-14 A. Could I get the precise wording of that question, E
e 15 once :nore?
a i
g 16 MR. FARRELL: Read it back.
s i 17 MR. JONES: I can repeat the questien.
a 3
E IS BY MR. JCNES:
c
$ 19 Q. I am referring back now to the first question where s
a 20 I asked, in your professional experience did you know of any l 21 cases where structures founded on soil stopped settling, for l
22 a long period of ti:ne and, then, began settling once again 23 withsno additional increase in loading? Ycu have indicate 24 the Chicago Auditorium. I want to know if there are any 1 I l
25 other cases that fit that description with which you have 1
ALCERSCbHHERCRTING60MfBAN.YnWCa =ww - - --
1 l
138 ;
10:8 3 had experience?
I A. Yes.
l 2 Q. Could you give me the names?
3 A. There are probably dozens of structures. In Oslo, 4
n St ekholm, for example, they started settling although e 5 3 6 they were founded on clay, when tunnels were excavated a
in rock beneath them.
f7 8
0, Any others.
n d There are many examoles I can think of, of settle-9 A.
i
$ 10 ments initiated by construction activities , nearby construc-l 5 5 11 tion tunnels, open cuts , sewers .
E d 12 Q. Do you know of any cases where such settlement oc-l E
3'13 . . curred where no explanation was ever found for the renewed E
l 14 settlement?
15 , A. I think the answer is no, when anybody was actually f 16 seeking an explanation.
s i 17 Q. Are you familiar with the settlement problem at the 5
$ 18 North Anna Pump Station, Pump Structure?
, E I
" I know something about it.
! 19 A.
20 Q. Would the North Anna Pump Structure fall within the l
21 definition of circumstances?
22 A. I didn't mention it, because I didn't think it did.
23 I wouldn't say it had scooped settling for a long time.
24 Q. How long, to your recollection, had it s t;.opped 25 settling before it resumed settlement?
- ALDERSONdiHEPORTdNG4CMRAMW4NG.wm, e < -v. ,
l 139 10:9 A. I would have t.o refresh my memory as to whether 3
it actually, you would say it actually stopped. I don't 2
- ll' 3
4 Q. Would you refer to the predictions of settlement
. 5 which were made for the North Anna Pump Structure, as predic-t
(
6 tions based on a field test?
1 l . j 7. MR. FARRELL: I don't think it has been established l 8 that he knows about this.
N 9 There is a lack of foundation.
i Y i5 10 A. It would be stretching the definition of a field i
5_.
i 11 test.-
l 5
- i 12 BY MR. JONES:
3
$ 13 q. Do you have any opinion as to what caused the 5
lt: 14 < resumption of settlement at the North Anna Pump Structure?
2 15 A. I think you would have to be more specific about i 4 j 16 what you :nean by the resumption of the settlement, because e
i 17 there were several resumotions, as I recall.
E
$ 18 , Q. Thellast resumption of settlement--
5 I 19 i MR. JONES : Off the record.
R 20 (Discussion off the record.)
21 MR. JONES : On the record. -
22 BY MR. JONES:
23 q. Referring to the North Anna Pump Structure do you 24 have any opinion as to what caused the resumption of settle-25 ment, the first time settlement resumed at the Pump Structure ,
ALDERSON REPORTiNEM3CMPANY.'4NOMNn"* ' e -
- __ . _ _ _ _ _ . - _ . ~ - _ _ _
1 +
140 l 10:10 ;
af ter having leveled off?
2; MR. FARRELL: That may be contrary and probably is contrary to what he testified to, as to whether it 3
4 leveled off.
5 A. My rec llection is that I thoughtat the time that a
3 6 I was looking at this information that the subsurface mater-7 ials, which were totally unlike chose at Midland, might be ;
becoming saturated for the first time with the rising pond.
) 8 d
= 9 BY MR. JONES:
i 10 q. Do you have any opinion as to what caused the h
z_
j 11 ' second resumption of settlement and, assuming I am correct a
j 12 in stating that after the first resumption it leveled off -
f E 13 _for a period of time?
E l j 14 A. Again, if my recollection is correct, and it may !
l E
! 2 15 , well not be, the second episode of settlement did not seem 5 '
j 16 to have an explanation.
l MR. JONES : I think that's it for today. We will l !i 17 s
5 18 resume tomorrow at 8:30 a.m. j e
(Wbureupon, the taking of this deposition was ia 19 i 20 4 adjourned until 8:30 a.m. , Wednesday, January 14, 1981, 21 at which time counsel as first here and before set forth 1
22 appeared and the following further proceedings were had.)
23 24 -
25 ALD ERSOM REPCam c6bkEE-#.< - ,4 .,
u.
\
= .
-.a
. . . . . <3
.... . .u. g .. ... u. ,. g..g ..
. . . . ....,<.3
..... . 3 .- ,.. .r .. ...,. ..,. .
'it".'.:.F.A 3 ?IG'1\TOF.Y CC;C TISSIC3
- s. ..,
. . . . . ,a..e ..
sa., .. ..
.. .s.,c.,,..4 .. Jan. 13, 1931
. . .3 aC C A:,.
.. g..
. - - . . e 50-329 OM, 50-330 OM: 50-329 CL,50-33C CL 2 .
3%,. .. . , s. . ...
.....4.. . ,.. A lbuquerque, New Mexico
.u.,- a) ... ,
.,<. ..e,.
4.. . .. . . yy 3, , .s. . . . - .. ... u. .s 3 a. 3 .. . u. ,.. ., . .. .. .. . ._ . . ., . -. ...
. 3. ..<
...u. ,. , n. - .. .., ~. .
...a. ,. ..3..
Ja:es 57. Hi;;gons c e r. . a .,. c .e
... /. ,. .. ,. s,
..... . s.
/ /
J/l'$ t &ash24
.- r 4.
- 2. ,. . . . , . / F .o. .
V 3
e M o n JU. Ho