ML20002B131
| ML20002B131 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/30/1980 |
| From: | Afifi S BECHTEL GROUP, INC. |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8012090483 | |
| Download: ML20002B131 (98) | |
Text
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124 4
I Ij THE UN!"'ID STATES 2!
NUCLEAR FIGULATORY COMMISSION 3.-
_________.____x 1
4!
In the Matter of:
t e
5 CONSUMERS POWER COMPA'iY n
(Mid'*-d o' ant, Unit 1 and 2) 6 ;l g
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _g i
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Bechtel Asscciates, P.C.
c 777 East Eisenhower Parkwav g
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5 Ann Arbor, Michigan 9
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Thursday, October 30, 1930
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10 i E
j Depcsition of i
E 11 SHER!? EL-SAYED AHMED AFIFI, 3
"E 12 the deconent, called for examination by the staff of the
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l Nuclear Regulatory Cc=mision, pursuant to notice, at ?:15 a.m.,
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when were present on behalf of the res=.ective.carties:
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l WILL'.AM D. PATCN a
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RONALD ERICKSON, Army Corps of Engineers 21 il JAMES W. SIMPSON, Ar=y Ccrps of Engineers i
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HAP ~ N. SINGH, Army Corps of Engineers 23j i
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ALDERSON REPORTING COMPANY. INC.
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on behalf of Censur.ers Power:
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SEAM, LINCOL:7 & BEALE 1 First National Plaza 8
3l Chicago, Illinois 60603 4l1 Sy:
ALAN S. FARNEL*, ESQ.
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_? _R _O C _E _E D _I N G S.
2' MR. PATON:
Dr. Afifi, you have been previously sworn.
3 This is the second day of the deposition of Dr. Sherif 4
Afifi, and we will fo13cw our practice of asking each person in g
5 the room to identify himself.
I guess we skipped over you, eN
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yesterday.
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7 SHERIF EI.-SAYED AHMED AFIFI n
g 8 ! havine. been c.reviousiv dulv sworn, was examined and testifie d as
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9 follows:
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MR. PATCN:
Would vou start, Dr. Afifi?
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Sherif 1.1-Sayed Ahmed Afifi, and I am with Bechtel.
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12 MR. FARNELL:
Alan Farnell, and I am representing
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13 ! Consumer's Power.
m 32 14 l MR. 3RUmiER:
James Brunner with Consumers Power.
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MR. SIMPSON:
James W. Simpson, Army Corps of Engineers, a[
16 North Central Division.
as 17
'g MR. KANE:
Joseph Kane, U. S. Nuclear Regulatory
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i MR. ?ATCN:
William Paton, attorney for the NRC staff.
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20f MR. JCFES:
3radley Jones, attorney for the NRC staff.
3 2I MR. SINGH:
Hari N. Singh, U. S. Ar=v Corts of j
i A1 Engineers Detroit.
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MR. ERICRSCN:
Ronald Erickson, U. S. Army Corps of 24 )gng 3,,73, 3,3;ggg, g
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MR. PATON:
Darl Hood, D-a-r-1, H-o-o-d, is with us, I
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1 but he stepped outside for a minute.
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EXAMINATION 3
3Y MR. PATCN:
1 4!
Q Dr. Afifi, do you understand that ycu are snill under I
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Yes, I do.
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7 MR. FAR'EII :
Bill, before we start, Sherif has M
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something he'd like to say.
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Yesterday you recuested the name of the censultant i
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that replaced -- is to replace Chuck Gould on the underpining z
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=atter for the Auxilliary Building, and here is the name of the l
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ccmpany.
I'll give you the piece of paper and I'll read it for i
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the record.
It's Johnson and Desmond Censulting Engineers.
The l
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name of the two persons who are involved are Jim Gould and l
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Ed Burke.
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Q Dr. Afifi, are you able to distinguish what const nction:
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activities were performed by Canonie as oppcsed to the construction i
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g activities performed by 3echtel?
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i 20l v.R. FARNE'I.:
Are ycu talking just soils?
I 21 MR. PATON:
Tet's start there.
I 22 !,
A Not exactly.
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4 23l SY MR. PATON:
1 24 Q
What do you knew abcut it?
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25 i A
I know that, I understand that Cancnie did the entire r
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ALDERSON REPORTING COMPANY. INC.
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j dikes around the plant, the dikas, and done some work in the 2!
extension of the dikes around the plant.
I do not know the 3'
l exact zones of what areas Canonie has done and the areas Bechtel l'
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6 has done.
That would be construction, construction would be able i
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to answer that,
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Q Who in Construction wculd know that answer?
N.
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I believe it would be A.
Scos.
That's the person that N
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I'm not sure he'd have the detailed M
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10 0
Q Oc vcu know the name of the organi:stion he is with, z
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i I mean what section, group, branch?
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My understanding, at the time, Mr. Scos was with the I
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13 i 3echtel Pcwer Corporation at the Midland Construction jcb site.
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E Q
He's with.3echteh at the site?
1 15 !
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At the site.
l 16 Q
He's in sc=ething you call Construction?
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A Yes, right, the Construction group.
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Q Construction group; is that what you call it?
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A It's what I call it, yes.
He is with Sechtel n
20 :
! Construction at the site.
i 21 Q
I want to ask you whether you know the name of the 22 h' specific name of the organization at the site that he's with?
23 A
I believe it is Bechtel Power Corporation.
I believe 24 i'
that's the name of the company.
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Q That, I understand, but I want to knew what section, ai ALDERSON REPORTING COMPANY. INC.
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group, branch?
2 A
I wouldn't know that.
3, Q
Did there come a time that Sechtel became disatisfied 4
with Canonie's work?
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A I'm not aware of this.
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Q Co you knew whether Canonie continued the werk that they R
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had centracted for, or was their work cut short pric: to the end N
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cf the centract ceried?
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I don't know.
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Who would know that?
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That would be either Sechtel Construction or Sechtel l
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Engineering.
T referred you to A.
Boos, as far as the Con-z 4
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The engineering department would be another source for
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information.
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Q Who might knew that in Engineering?
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'7 l that time, R. L. Castleberry, and he would know who would be able h_
18 to answer this question best.
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O Dr. Adifi, do you have any responsibility to knew what 3
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21 '
MR. '."ARNELL :
What time are you talking abcut?
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22 ;
MR. PATCN:
During plant fill operations.
I 23 '
MR. FARNELL:
Plant fill cperations were going on for a !
24 ' long time.
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25 MR. PATCN:
That's fine.
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11 3Y MR. PATON:
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Q Did you have any responsibility during plant fill 3
operations to know what was going on at the site?
4 A
- would like to try and identify the period, if you 5i would.
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During plant fill operations.
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A You mean at the time the plant fill was originally N
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During the time that the plant fill operation:, were 10 going on.
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5 11 MR. FARNELL:
You're talking from 1973
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12 MR. PATON:
No, that's all right.
I den't think you 13 should testified.
I'll ask the witness.
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14 MP. FARNELL:
I'm talline. vou --
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5 15 MR. PATON:
If the witness does not know when plant I
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17 3Y MR. ?ATON:
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-Q Do you know when plant fill operations were going on?
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! wouldn't know exactly when it was going on, but ! can l A
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20l tell you.that after the discovery of the Diesel Generator 1
21 ! Building problem, sometime after that, the Geotechnical group l
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22 -
became involved in assisting the remaining fill work at the site.
23 3efore that, I'm not aware of any involvement on our 1
24 l part in the plant fill placement.
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Q After the discovery of the settlement problem at the I.
1 1
3 ALDERSON REPORTING COMPANY. INC.
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Dicac1 G?ncretor Building, did you hava any roeponsibilitics.to 4
1 iknow what was going on at the site with respect to plant fill?
2 A
For sometime after the problem, the Geotechnical group 3
was not involved in the fill placement, but at some later date, we i
4 became involved, and I don't recall exactly.
Mr. Wancek was e
5 assigned as a coordinator, and his responsibility was to provide s
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Q Did Mr. Wan:ek report to you, activities at the site?
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A Mr. Wan ek reported to me activities as he felt necessary, d
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c 10 l Q
After the discovery of the problem at the Diesel z
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11 Generator Building, approximately how often would you visit the
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12 site yourself, approximately?
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A I have. visited the site e.robably two or three times a
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Thau's b
i 15 about the ac.c. roximatelv the number of times I have been at the 2
3
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- site, I
i 17 l Q
Do you consider that the frecuency of your visits to a=
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18 the site have been sufficient for v.ou to carry out v.our i
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g 19 j professional responsibilities with respect to the Midland Project?
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A I rely on the services of Mr. Wanzek who was assigned to l
21lthisjob, and he is supposed to be watching all these activities, d
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You say he was supposed to be watching?
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A He is watching these activities for me.
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So that the information you obtained from Mr. Wan ek, you l
25
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9believe is sufficient for your knowledge of activities at the i'
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I sitetoenableyoutocarrycutyourprofessionalresponsibiliciesf 2l A
Yes.
3 Q
You don't feel that your work suffers any by your 1
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isclation from the site?
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MR. FARNELL:
He didn't say he was isolated from the g
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site.
That question was e.gked and answered, and I don't want
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3Y MR. PATCN:
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Q Can you answer the question?
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i MR. FARNELL:
He didn't say he was isolated.
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Are you instructing him not to answer?
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No.
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I believe that Mr..Wa=mk sufficiently qualified to eversee g
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2 would have undertaken that involvement.
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BY MR. PATON:
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Oc you knew whether Canonie placed the plant fill 1
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- initially under the Diesel Generator Building?
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j 19l-A I do not know for a fact whether he participated, but I i
i 20l have heard statements that scme of that fill was placed by 21 I.Canonie, but I do not know for a fact.
1 22 i i
Q If you have heard that some of the fill was placed by 23 " Canonie, have you heard that some other part of the fill was 24 placed by someone else?
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l 25]s A
Yes, I have heard seme other part was placed by semecne j
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ALDERSON REPORTING COMPANY, INC.
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1 133 10 1
else.
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Who?
3 A
I believe it is Bechtel.
That's my understanding.
I, 4
again, don't know that #er a fact myself.
g 5
Q Do you know anything =cre than what you have airesdy n
2 6l stated about the division of work between 3echtel and Cancnie with a
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7 res=.ect to clann fill as to who did what?
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A I don't recall anything other than what I told you
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9 already.
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All right.
Dr. Afifi, I'd like to shew you a document z
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On the cover, 3
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it's dated August 3rd, 1979.
It's frem T. E. Johnson of Civil /
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13 l Structural -- and there may be another werd thr.t fo11cws that, but!
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14 l it.'s covered over, at the Ann Arbor Office.
It's to --
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15 : distribution is to E. Rumba, K. Weidner, J. Milandin, P. Martine::,
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g 16 I R. Castleberry, 3. Dhar, sp lied D-h-a-r, S. Blue, and 5. Afifi.
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I,et =e show you that dccument and ask you if you have w
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18 l seen it.
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19 l Why don't I mark that NRC Deposition Exhibit 2, 10-30-30 I
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20l (Afifi).
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A I couldn't read all of the last page.
The copies are s
t' 22 ' not quite clear.
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23 '
MR. PATCM:
Could we ask for another coc.v of Fac.e 3?
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24 If you will do that, I'll abandon that line of questioning right I
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25 )' now.
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4 i
3 ALDERSON REPORTING COMPANY. INC.
134 11.
'l MR. FARNELL:
I'll note for the record that that is one 2
of the documents we produced in response to the Notice of 3
i Deposition.
We produced those documents Monday =crning at i
4 i
approximately 11:30.
1 1
I 3Y MR. PATON:
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O Dr. Afifi, do you know whether data and drawings cen-g n
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! cerning separation of Canonie's work from 3echtel work by t
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n i Construction were ever forwarded to Gectechnical Services for d-c 9
z-review?
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A I recall scmetime that an attempt was =ade to do that, i
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O If it was forwarded to Gectechnical Services to whc=
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! believe the person that would know = cst about it would, 16 !
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' be Mr. Wanzek.
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(Discussien off the record.)
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BY MR..PATDN:
i 19 l 2
Q Dr. Afifi, I want to hand you a dccument which is n
20 ;
j numbered in the bwer right hand corner beginning with S3 801725 21 !
i and ending wi h SB 301745.
It's dated August 20, 1979.
It has i,
22 i sthe words, " Work File" written in the upper right hand corner, t
23 '
i land i==ediately below that, Bechtel Associates, professional
.i 243gecrporation.
It's from Karl Wiedner, W-i-e-d-n-e-r of Engineering 4
25 1 uit Ann Arbor.
It is addressed to Distribution.
There are seven a
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ALDERSOt J REPORTING COMPANY. INC.
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V 135 2
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names, the first one is, copies to P. Secnel, 3-e-e-n-e-1, with I
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- ke subject is Midland Diesel Genera:Or Task Group 3
Meeting Notes, j
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I turn to the second piece of paper which is numbered j
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S3 801725 and ask you te read the two sentences at the bottom of I
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6 the page beginning "This item enclosed," and follows another R
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7 sentence.
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' dave you read the two sentences, Dr. Afif_?
d y
9l A
Yes, I have read them.
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10 Q
As a matter of fact, I think for ease of reference, I'll z=
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11 I read the second sentence into the record since this may net be an m
J 12 exhibit.
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"The data and drawings concerning separation of
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warded to Geotechnical Services for review."
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16 i Does veur reading these two sentences refresh vcur 3
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d 17 l reccliection en whether the data and drawings referred to were, in,
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18 i f :ct, ever sent to Gecrechnical Servicer?
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19 l Cnly that I recollect that the attempt was =ade, and A
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n 20 l I'm not sure if such drawings were actually produced and sent, but.!
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21 I this says that they were sent, so as I say, the person who would i
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i 22 ' be mest familiar with these is Mr. Wan.
It's not incencei.vable t
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23 I that they had been forwarded and may be available semeplace.
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1 24 j Q
If they were available, would they be with Mr. Wan=ek l
25 jer under his control?
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ALDERSON REPORTING COMPANY. INC.
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A: would believe that they would be in the drawing files.
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Where are the drawing files 1ccated?
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The Geotechnical Group Files, the Central Files, if I
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4 they exist, such drawings exist.
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Who has custod.y of these files?
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A The custody of the Central Files is under the nanager.
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Who is that?
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A S. L. Blue.
These files are department files.
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t 9i S. PATON:
Are you willing to le us look at those z-t n
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Well, I think you have put it in -- we'll 5
-4 12 entertain any request but I think we 'd like it in writing and in z=
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MR. PATON:
You are not willing to let us lock a: these a
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15 ' files without an a-rropriate written request?
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,MR. FAIELL:
Right.
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R 17 MR. PATON:
Is that a change in the apercach to disccverv.,
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18 l that we have discussed?
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19 !
MR. FAP2 ELL:
I thcught that both sides would give a 5n 20 ! formal document production request that differentiated from the t
,I 21 ! request to produce that accc=panied each depcsition notice.
4 i
22 '
Are you talking about looking at these today, or in the i.
23.near future?
1 1
Do you know which document you want to see?
4 25 If vou'd clace a request for seecific drawings, we'll attempt to t
4 1
i I
I, ALDERSON REPORTING COMPANY. INC.
1
s l
137 I
I 14 4
i, locate them for you.
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2 MR. PATCN:
Would you be willing to provide us :cday with an i'dex to design and construction drawings related te i
3 n
i j
4l Leil structure foundations, to soils and structure foundations?
5<
(Discussion off the record.)
e i
6
!G. FA?0iELL:
At lunch time we'll attempt to ask the a
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7 apprcpriate people if there is such an index, and if thers is, 3
8i I'll locate it and provide it to you, a
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9 MR. PATCN:
We would like to accept the effer, and to i
~
ask that one of the Corps of Engineers, one or two of the Corps 10 l
z l
i 11 of Engineer people with us to lock at the specific data and
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12 '1 drawidgs referred to in this paragraph.
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13 i MR. 1ARNELL:
I don't know if we can get that for *vou
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E 14 i in two seconds or I den't know if we can get it for ycu today.
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5 15 :
'4R. PATCN:
Will you see, and if it is available, he can 2
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16 -- you have that request under advisement, a
er are you censidering
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p 17 !that last request?
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=g 13 MR. 3RC;NER:
I don't -- I must have lost ':he page you 're {
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l 19 : referring to.
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MR. PATCN:
The two sentence,. carac.rach at the bottom of i
21 the second piece of pape-i t
22 MR. BRCRTER:
The record should reflect that the re-i i
i i
23 quested drawings, the data and drawings concerning separation of i ll i
i 24 i Canancnie's work frc= 3echtel work by construction ' and their j
4 i
25 identified en document dated August ist, 1979 entitled Meeting
- 1 J
l ALDERSON REPORTING COMPANY. INC.
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138 I
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-a b
11 I Notes Number 1018, Midland P7. ant, " nits 1 and 2.
2i I'm not certain we'll be able to find the drawings i
3 but : thought you were referring to a specific set of drawings 41 and these may or may not be identified.
s.
5 MR. PATON:
It seems to me they referred to some V
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6, specific draw!.ngs.
We're asking you to see if that is true, and R
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if it is, could we icok at those drawings?
s 8
MR. 3 RUNNER:
The problem is that I am not sure who 1
d 9
separated out these drawings and frem this document, it's not E
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10 clear who is in possession of the drawings.
z Il MR. PATON:
Okay, we're just asking you to =ake an i
t i
y 12 atta=pt.
If you can't do it, you can't do it.
=
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5 (Discussion off the record.)
=
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m 3Y MR. PATON:
t
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- am marking as NRC Staff Deposition Exhibit 3, dated E
14 1 10-30-30 (Afifi).
It's a docu=ent that has a number at the icwer s
i y
17 richt hand corner, SB 30233 and continues to a document with the a
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18 numbers 53 800238 dated September 13, 1974.
It apesars to be 19 lfrom S. Afifi, but there are lines drawn through S. Afifi, and it'sj I
3 n
l 20! to R. L. Castleberry.
The subject, Plant Area Fill, and-there are t I
4 21 ! copies to five people and copies to 1320 and 3410, which I don't I
i 22 ! know what that means.
3 I
23 I hand you that document and ask you if you have ever f
24 iseen'that before?
4 25 :
MR. FARNELL:
Do you want him to read the whole thing?
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. ALDERSON REPORTING COMPANY. INC.
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1 MR. PATON:
Off the record.
- 9. o, 2l (Discussion off the record.)
I 3
MR. FARNELL:
He has seen the document.
i 4
3Y MR. PATCN:
g 5 I Q
Do ycu recall yesterday that we had a discussion, sc=e j
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questions and answers cencerning ce=paction criteria?
A 7
A Yes, sir.
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Q And do you recall there came a time in 1974 when you 3
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said you ad'rised people, you advised sc=ecne what you thcught 10 was the correct ec=paction criteria?
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Yes, sir.
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Is NRC Staff Deposition Exhibit Number 3 the document
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13 ! in which you advised Others what you thought was the ccrrect I
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Yes, sir.
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Q And I direct your attention to a sentence, the second j
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20 l "This infer =ation will allow a complete evaluation of 2Il any in-place "il'
'cr its preposed function in addition to pre-I 22 i viding information which will be needed for the FSAR.
It should l
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23 ' also clear up any questions as to how fill should be placed in j,
24 ', the future."
I 25 i Do you agree that that's what that second to last 1
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i ALDERSON REPORTING COMPANY. INC.
140 1
paragraph says?
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2 MR. FARNILL:
You're asking him if he read it 1'
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correctly?
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MR. PATON:
Yes.
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Let me ask you this, based on all of the knowledge you n
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MR. FARNILL:
Would you read that back?
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11 (Record read.)
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The document speaks of any questions and
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Your exception is to the fact that
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MR. FARNILL:
I'm saying that I thought you were trying
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to read off that document and you didn't have it phrased right.
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I said question instead of questions; is a=
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that the problem?
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MR. FARNILL:
Yes.
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20 i MR. PATON:
Okay, I'll ask it again.
21 3Y MR. PATCN:
1 22 C
Based on all of the knowledge you have today, is it your!
i 23 '
opinion that this letter -- excuse me, this Inter-office i
24 l Memorandum cleared up any questions as to how fill should be j
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25 1 placed in the center?
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Can you just explain it a little =cre, what the j
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All right.
Dr. Afifi, am I correct that you wrote in i
4 this letter, "It should also clear up any questions as to hew fill g
5 should be placed in the future"?
Are those your words?
A g
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- believe they are my words.
The meme is signed by me.
I M
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What does that mean?
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A okay, I believe the intent of the sentence is that it d
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sets forth the percent compaction that should be used for fill
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supporting structure.
That's the intant of the sentence in my, z=3 'll
=y -- the best of =y recollection.
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What does it =ean when it says, "It should also clear i
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The question at the time was, should it be 1557 15'l j
Method D, and that is referred to in the first paragraph of the i
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Specifically referring to this sentence, I wanu to ask 1
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to hcw fill should be placed in the future"?
What did you mean n
20 bv that?
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I thought I stated ! believe the sentence =eans that i
i 22 l new you know, in my opinien, how fill should be placed below I
23 -
structures, ! =ean, to what degree of ccmpaction it should be 4
24 { placed.
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l ALDERSON REPORTING COMPANY. INC.
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142
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You say, now you knew; new who knows?
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A The project, in =y opinion.
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A Yes.
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Q
- n your epinion this document should clear up any a
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And my M
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questien was, did it accc=plish that; did it clear up any
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questient, as to how fill eheuld be placed in the future?
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A Fr== reading the document you presented to =e yesterday, s
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Would you agree that, in fact, this document did not j
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MR. FARNELL:
! think he already answered that.
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lould you answer that?
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A Frc= =y standpoint, the intended purpose of the memo 1
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Q All right.
New frem the documents I showed you --
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A And also the fact that the fill was not, the percen of
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j ALDERSON REPORTING COMPANY. INC.
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143 20 1
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c I ccmpaction was no: used on site past that date.
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3 to how the fill should be placed were not resolved after this i
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memo?
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I found cut for sure during the FSAR operation process.
4 3
61 Q
When was that?
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- don't recall when we started and thatwas in the year i
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'76, '77 when we started working on the FSAR and started requesting 9-i i
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f all that.
Then it became evident that method was not used.
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o Is your statement correct:
It was not until apprcximated'y d
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clear up any questions as to how fill should be placed in the E
14 future" that you first discovered that questions as to hew fill
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i should be placed were not resolved; is that an accurate statement?l r
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Would vou read that back.
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0 (Record read.)
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20 ) I knew that during the FSAR operation period, but before that, 6
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22 1 1
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Q Dr. Afifi, I believe you told =e ence before, and we j
i 24 i jhad to go through the routine, when was the FSAR preparation done?
- 25 j A
That was --
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ALDERSON REPORTING COMPANY. INC.
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0 New you're going back to -- I'm trying to get time.
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I'm talking about for sure.
I don't recall if --
did 3
not have direct involvement during that period of time and one f
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not for sure, e
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Would.vour words,.vou didn't knew for sure, de vou aeree '
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Get the statement.
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- asked you, is it true.
Let =e ask you that again.
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Let's have that statement back.
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Is it true or net true?
It's either true er not true. -
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- would like to hear it with the modification.
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MR. PATCN:
Fine, let's hear it again with the
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17 modification.
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(Record read.)
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5 n
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I'm asking ycu, is it true or not true?
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A My answer, I didn't know for sure until two years later. i t
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Did you try and find out if it was accepted?
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A No.
2l Q
Dr. Afifi, that two year period, do you recall whether 3
you visited the site, whether vou persona 11v visited the site?
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A
- may have visited the site in connection with scmething i
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I recall visiting the site n
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=eeting for one of the, I believe, intake structure.
I don't 8l j
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Did you ever consider during this two year period, z_
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being used?
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- don't recall ever attempting to do that, and I don't t
_{ 15 l believe it is =y duty to verify which ccmpaction criteria is to
=
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project.
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Q Is it your duty to clarify any questions as to hcw
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to the project engineer.
I 22 '
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Q Are you indicating tha: the duty to provide an answer 24 l to this question only arcse because semeene asked you to do it?
1 25j A
And I became aware of it, so I -- I was asked to comment. l i !
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ALDERSON REPORTING COMPANY. INC.
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23 1 k and I ce=ented.
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Ycu became aware of what?
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A I became aware tha: the method of compacticn 1557 I
i 4i Method 3 may not have been used en site and as intended by the I
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engineer, wall structures.
The question came in frem construction nn g
6I which me hed should we use.
R 7
Q So it was your respcnsibility to provide them with I
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information, or with your opinien en which?
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Mv recomenda:icn.
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And then as I understand it, your responsibility j
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terminates?
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A The way I interpret it, yes.
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to make any determination as to whether or not your recommendation I
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We're still talking ahcut that two year g
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ceried?
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Yes.
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n Yes, for that -- there's no way I can force the project j g
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20 to do something the project will not accept.
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l 22)
Q when you visited the site, if you wanted to verify l
r 23 whether the correct ecmpaction tests were being used, what would a
24 ' you have to do; ask?
f I
25j A
I really don't knew.
I may -- maybe -- it might be a
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I ALDERSON REPORTING COMPANY. INC.
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l 147 24 fasking,yes,foroneofthethings.
2
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Who would you ask?
3' A
I would ask the Construction people, Construction crew.
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Do you know who, for example you would ask: Mr. Cock?
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A Who is Mr. Cook?
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Q Who at the site would vou ask?
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I would probably ask Mr. -- I don't recall who was in l
8i charge of Construction at the time, that I could have asked a
J l
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- during that period.
I wouldhave asked somebody in charge of E
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So in fact, if it had occurred to veu, vou could have a
4 12 -
I information by just asking somebody?
obtained that z
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MR. FARNELL:
He didn't say that at all.
What do you
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Co vou have trouble with that question?
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Yes.
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Q If you had been interested in finding cat whether the
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correct compaction criteria were being applied to the site, am I l
20 i
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correct that all you would have had to do is to ask semeene at the ;
i 21 I
site; is that correct?
i 22 !
A That is probably correct, yes.
j 23 i
O Is it your practice to review Construction records while !
1 24 j 3 you are visiting the site to see if required specifications on 25 i fill placement are being met?
i 4
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- t ALDERSON REPORPNG COMPANY. INC.
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148 l
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When are you talkine about?
2I MR. PATON:
During the two year period that we've been 3
discussing.
4, A
That has not been my responsibility and I have not been 5l e
assigned for it.
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(Discussion off the record.)
R R
7 MR. PATON:
There has been some discussion between n
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i cetnsel concerning sc=e records kept by Bechtel at Ann Arbor that 1 I
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! relate to soils at the Midland site.
There has been a reference
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- to sc=e large nn-ker, for example 170,000 documents.
The staff isl
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! net presentiv advised of the nature of these documents, and the
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1 Ann Arber with resc.ect to the soil matter in Midland.
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Mv. recollection was thr.t after Isham, Linccin & Beale n
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0 had the opportunity to leek at these documents, seme censideration{
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18 ;
was to be given to providing the staff an orportunity to look at I
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these documents.
I had thought that that opportunity was going to 20 ;
- be provided to the staff several weeks ago.
As understand the 21 '
m.
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I am making this statement on the record because there j
i 23 i
4 is apparently scme disagreement between counsel as to what they 24 j intend to offer in that regard.
That's the end of my statement.
25,
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MR. FARNELL:
-I'll attempt to talk to Mr. ::ameron over i
2 ALDERSON REPORTING COMPANY. INC.
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E-149 4
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I lunch.
.v.r.
Sa: erin was the attorney chiefly involved in some l
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2 conversations dealing wich this subject, and after I've discussed j i
3l this with hi=, I will make a statement.
i 4
3Y MR. PATCN:
r i
g 5l Q
Or. Afifi, did you state yesterday that ccmpacticn that a
et i,
j 6
=eets 95 percent of the 56,000 pound test is apprcximately equal 7
to compaction that meets 100 percent of the 20,000 pound test?
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A
- =eant this in the centext of the Midland clay field.
d 2
9 I,
Q Can you tell.'. me the basis en which you arrived at that 4
10 { conclusion?
j z
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The basis is, the first basis that was apparent frc=
8
'd 12 l the Danes and Mccre report that one =eched was substituted for the E
1 l
13 I other.
100 percent of the 20,000 pound in one report was sub-2 5
14 stituted for 95 percent of the other in the other repert.
That is i
$j 15 -
what one basi'.
The other basis is that frem this previous f
16 experience, I feel that way, and we have data right new and the
=
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17, data is available to the NRC of running both types of test on the
=
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clay field and the data to suppcrt the statement.
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19 l
,0 to you know whether there were any requirements for n
j 20 l qualifications of ccmpaction equipment that was used at the site?
i 1
21 l MR. FARNELL:
What time are we talking abcut now?
22 ]
MR. PATON:
During plant fill operations, i
23 MR. FARNELL:
Has anything changed over the time, if l
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24 ; you know.
5 i
25 MR. PATCN:
I don't want my question to be amended.
Y i
ALDERSON REPORTING COMPANY. INC.
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I I asked a questien.
I 2
Ifyou'regoingforalongperiodoftime,l MR. FARNILL:
3 I don't think it's an appropriate question.
Why don't you ask j
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! him for a year or two years?
MR. PATOM:
I'll ask the questiens.
3 6:
MR. FARNELL:
I'll make =y comments, too.
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Can you repeat the question, then?
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3Y MR. PATCN:
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Q Yes.
Do you know if there were any requirements for 1
y 10l' ccmpaction equipment that was used during plant fill operations; j
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i did they have to be qualified in any way?
12 1 f
A I recall that there existed requirements for qualifica-l i
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tien of cc=paction equipment, yes.
3 14 l 3
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Do you know whether those requirements were =et?
I
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9 15 i i
after the discovery of the unexpected settlement at the :
2 n
16 Diesel Generator Building, my people became involved in tests to 5
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qualify this equipment at t:ie Midland job site.
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All right, sir.
New please address the ceriod of time 4
i 19
.,i a crior to the discoverv of the problem at the Diesel Generator 20 Building.
21 '
Do you knew whether those equipment qualification re-22 I
quirements were met?
i 23 '
A I do nct know.
24 i
Q Do you know whether those equipment qualification re-t 25 I
quirements were met after the discovery of the problem at the i
i ALDERSON REPORTING COMPANY. INC.
i
I 151
,3 l
t l Diesel Generator Building?
l Ia s
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2l A
sometime after that period, we cenducted tests, =y l
3
.ceeple, under the supervision of =v. c. e c c. l e, and in =v. coinion, i
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4l these tests qualified the equipment for the use and placement of r
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I would like to take objection to the werd "qualifica-M 7 i tion of equipment."
I xm using it in the centext of qualifying I
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and a qualified construction precedure, but not a qualified piece.
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of equipment.
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Q Your statement is that there were required precedures; 3
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A qualified precedure for each piece of ec.uir. ment.
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Q There is a qualified procedure?
=
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For the compaction equipment.
I, N
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For the compaction equipment.
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m compaction ec.ui.cment," were vou referrinc, to lift thickness?
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A And number of passes.
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Q Would that also include =cisture centent?
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A That's an inherent part of the specification.
It's not j aj 23 I necessarily related.
That's a different sub'ect.
Meisture i
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conditioning has to be done.
It has nothing to do with it.
25 l, Q
s it vour testi=cnv. that after the discoverv. of the i
4 I
9 i
- l ALDERSON REPORTING COMPANY. INC.
l
l 152 1
29 l
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I problem at 'the Diesel Generator Building these qualified prece-21 dures were followed?
l t
31 A
To the best of my knowledge.
I 4I Q
And is it also your testimony that prior to the 5
discovery at the Ilesel Generator Building you de not knew a
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6 whether these qualified procedures were followed?
R i
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I believe I stated that prior to the discovery of the j
81 problem, I do not knew if the procedure was developed.
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okay, so you're not even sure whether there were 3
10 !
procedures -- strike that.
j
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II You're not sure whether there were precedures; is that n
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A I don't knew for a fact there were procedures.
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I4 Q-After the discovery of the =roblem at the Olesel ue f
=
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=
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16 sand and clays?
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A I believe that in Q-listed areas, the sands were a=
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18 qualified.
I don't believe we qualified the equipment for Q-i 1
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m A
20l Q
Would you tell me why not?
II!
A To my knowledge, the application did not exist, that 22 j sand was used in Q-listed areas.
23 j-Q Is optimum meisture the same for both the 56,000 and 24 y the 20,000 pound test?
1 25j A
No, sir.
I-4
~
i ALDERSON REPORTING COMPANY. INC.
l
30 153 1
MR. FARNELL:
Why don't we take a little break?
1 2
(Short recess taken.)
3 3Y MR. PATON:
I 1
4 O
Dr. Afifi, I show you a table 12-1 which is entitled 5
Su= mary of Supporting Soil Conditions and Planned Remedial e
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6! Measures for All Safetv RElated structures and Utilities.
I'm a
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I would like to see the entire response t
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I would also indicate that the table that u=
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19 it's dated 9-79.
5.e 20 !
By MR. PAron:
21l Q
In the sentence that I asked you to read, there is a I
22 ] reference to a possible local void.
My questien is, do you knew 23 ' whether or not that void is real?
24j gR, FARNg;L:
I don't think we have established that I
i 25 j Sherif wrote this letter.
I i
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ALDERSON REPORTING COMPANY. INC.
I
I 154 i
31 I
MR. PATON:
All right, I'll back up.
2 3Y MR. PATON:
3 Q
Do you know whether there is a possible local void under.
t 4,
concrete =at elevation 590 to 539 at boring AX o' t
l 5l H
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The best of my recollection, that has been reported en l
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It's one out of three borings j
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Mj 8
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Your answer is that it has been reported on the boring 0
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A To the best of my recollection.
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i 11 MR. FARNELL:
Would you read back the question.
3 N
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5 1
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1 3
3Y MR. PATON:
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=
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Does your response mean that there is a possible local l
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15 :
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I0 A
Yes.
17 Q
Mcw this next question specifically refers to the word,
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I'm asking you, is there, in fact, a local void in l
19 i d that. area?
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Is it i
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MR. FARNELL:
Or any other radiation, I gather.
23h A
Would you read the question again?
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24 3 J
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S, 25 0
Yes.
How do you know there is a possible 1ccal void j
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ALDERSON REPORTING COMPANY. INC.
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under concrete mud mat elevation 590 to 529 at boring AX-9?
2' A
! believe stated that that was reported on the t
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I say in my judgment it would have to be a possibility of a local 2
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12 :
is a possible local void in that area?
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I recall at the time the borings were drilled that that 5
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eliminate the void?
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19 2
there was a nossibility of a void.
Are you eli=inatine the 4
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a 20 possibility of a void?
II 3Y MR. PATCN:
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Q Has any action been taken to --
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Sure.
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i ALDERSON REPORTING COMPANY. INC.
1 I
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I' record, the propcsed remedial action is included on the fourth 1
2 column of the table and it states, "?ressure grouting, avoid i
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below concrete mud =at as needed."
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That would be apparent at the time grouting actually d
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takes place.
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No, I didn't say that.
I indicated already that the E
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local veid.
Grouting has not been accc=plished yet.
And greuting c=
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As need, isn't that what it says?
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A You just si= ply pump, continue to pu=p grout until 2} I
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o 22 Q
Have you conducted any other explorations at close a
t spacing te determine whether there are other voids or pcssible l
I 1
24l voids?
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i 25q xa. FAaNz;;:
nepeat that, please.
i ALDERSON REPORTING COMPANY,INC.
1 1
34 157 I
(Record read.)
2 MR. FARNELL:
I don't think he testified they did 3; explorations at c1cse basings.
4j MR. PATON:
I believe you are correct.
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5l BY MR. PATCN:
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Have you conducted any investigations to deter =ine g
R 7i whether there are other voids or possible voids within 50 feet I
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I' of the void, the possible local veid that is mentioned here?
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The borings conducted in this area, I do ne recall how o
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f 12 !
been nc, to =y knowledge, possible voids reccrded on any of the
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other berings in the vicinity.
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In your professional judg=ent, is the investigation l
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that has been conducted here sufficient to determine whether or w
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not there are other voids or possible voids within 50 feet of j
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MR. FARNE;;:
I don't believe he said they conducted
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Okay, if he didn't, that's fine.
That's a 1
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A Yes, we did not.
I don't believe we conducted investi-1 23 } gations just for that purpose, but there were borings drilled.
I 24j The dates on the boring legs would indicate when the horings were 1
25 3 drilled.
I don't recall how =any of these were drilled before and!
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158 35 i
1l how =any of these were drilled after.
i 2i 3Y MR. PATON:
l 3
0 Do you knew whether there are any voids or possible f
4, voids within 50 feet of the possible local void that is mentioned 5
in this paragraph I asked you to read?
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4
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Q Dr. Afifi, that's not =y question.
My question is, de d
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?
10 feet of the local, of the possible local void mentioned in this E
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paragraph?
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ARNELL:
I think he answered that.
5 a
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MR. PATCU.:
If he did, I'd like to knew the answer.
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The answer is that to the best of my kncwledge, nene
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15 were reported in the borings that were taken in that vicinity
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That's the same answer you gave mi 5efore.
You said
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18 none were reported.
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A Yes, sir.
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4 20 Q
My question is, do you know whether there are any there,l i
21l and I conclude from your ane er that you don't knew whether there i
22 ( are any there er you -- have you concluded that there are none 23 there, or what?
4 24 Q
My question is, to the best of your -- are there any 1
1 1
25 I
voids or possible voids within 50 fact of the possible local void l
ALDERSON REPORTING COMPANY, INC.
l l
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36
' 59 i
i I ; mentioned in this paragraph?
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A Can I speak with my counsel?
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Certainly.
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(Discussion off the reccrd.)
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My answer to your questien is that I den't knew.
H 6
BY MR PATON:
R f7 Q
Did knowledge cf this possible local void, was that n!
8, developed frem an exploration that was =ade?
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I think it has been stated that it's a z
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I don't understand your question.
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Q Did knowledge of this possible local void ceme-from l
=j 14 ! borings that were performed?
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From a boring.
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16l Q
Now, do you plan to require additional berings to i
17 investigate whether there are other voids or possible voids?
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Dr. Afifi, if I asked you whether voids are sometimes t
a n
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Yes, sir.
22 L Q
Could you explain to =e what that neans, of what your I
23 ; understanding of that werd means?
l 24lI A
A li=ited area that is -- it would not be extensive in l
25 l! size.
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1 5
ALDERSON REPORTING COMPANY. INC.
160 37 I
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11 6
Dr. Afifi, do you plan any borings or other
{
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3 other voids or possible voids within 50 feet of the possible 4
local void that is =entioned in this paragraph?
5 MR. FARNELL:
That's been asked and answered.
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MR. PATON:
Off the record.
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7 (Discussion off the record.)
A i
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I don't know at this time.
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9i BY MR. PATON:
z_'
10 Q
Dr. Afifi, I show you Pages 13-1 through 13-6 which z
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This is in volume 1 and it's z
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2 15 j MR. FARNELL:
Is there a revision date on that?
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16 i MR. PATON:
No ravision date on either 13-1 or 12-5.
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ou're just going to ask about 13-5' i
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19 L MR. PATON:
13-5 has no revision date on it.
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Fine.
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)
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fou can read any part of this that you want, but =y I
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"The l
3 J
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i 25 l based on the equations for beams on an elastic foundation."
i 4
i ALDERSON RE ORTING COMPANY, INC.
t
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161 1
I'll tell you =y question.
The first one is going to l'
l 2l be, what were the values of the modulus of sub-grade reaction 3
used in the analysis?
l 4l A
- don't know.
i 1
5l Q
Do you know who within 3echtel would know that?
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3 6i A
That would be Mr. Char, D-h-a-r.
Mr. Ohar, he would be l
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the person to refer to for that answer.
t 8l Q
Do you have any responsibility to determine these l
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Sometimes.
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When?
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When requested by project engineering in connection z=
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I don't know.
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He's talking about these values set forth !
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in 13.
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18 l 3Y MR- ?ATON:
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My question, and I'll state it again, the question was, 19 s
O 20l whau were the values of the modulus of sub-grade reaction used in 2; l the analysis?
1 22,
MR. FARNELL:
You're just talking this analysis on il
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MR. PATON:
Yes.
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don't recall if there was specifically asked about i
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ALDERSON REPORTING COMPANY. INC.
9 I
39 162 I,
this.
1 2
3Y MR. PATON:
3 i
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5 A
Yes, sir.
A 9g 6I Q
If you had been asked for these values, would there be g
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7 any records that would reflect that in the documents you have N
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9 z.
for the purpose of this deposition?
I i
10 A
Not necessarily.
E i
11 Q
Where would those documents be?
8 i
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A It's possible that it's a computation made and handed
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in to project.
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=
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And you would not keep a record of that?
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It would be in the calculations file.
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There is a calculations
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'kat you don't keep e
17 yourself?
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A That's correct.
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.Q Is there an index to that calculation file?
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20 !
A I believe so.
l 21ll I
MR. PATON:
Mr. Farnell, would you be willing to 22 ! provide a copy of that index?
23 '
MR. FARNELL:
At lunch we'll make an effort to locate l
i 24 '
it.
I would also like to put on the record that we are being I
l 25]1 cooperative in looking for the indexes, I would expect the same i
s i
d ALDERSON REPORTING COMPANY, INC.
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,,203 40 I
I treatment frc= the NRC.
I take it by your sound that you would 2I agree with that?
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MR. PATON:
No, I didn't make any ce==ent.
I think we 4,
have sc=e disagreement between us as to how much cooperatien each g
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n N
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MR. FARNELL:
If I ask you for certain indexes, are i
7 I' e
a l you going to say no?
A 8 ll MR. PATON:
I think that the NRC has been extremely e
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j of croviding handwritten notes in the persen's personal file.
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'that has been requested.
Right new I am not aware of anything
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i SY MR. PATON:
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15 2
Q Do you know whether anyone at Sechtel has re-evaluated
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f 16 l the value of the modulus of sub-grade reactions be use of 17 '
.M inadequatelv. ce== acted soils at the Midland site?
l 18l' MR. FARNELL:
Again, are we referring to Page 13-5?
4 19,
n (Discussien off the record.)
20l!
MR. PATON:
The question does not linit itself to
- 1 i 3
Page 13-5.
It references to any sei:=ic analysis that has been 1
I 22 i made.
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MR. FARNELL:
Another question.
Are you talking about j
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3 25 '
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MR. PATON:
I'm referring to buildings founded on the ALDERSON REPORTING COMPANY. INC.
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163 I
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Il inadequately c0=pacted plant fill.
2 MR. FARNELL:
Repeat the question.
i 3
37 33, 7;733, i
Q Dr. Afifi, do you know whether anyone at 3echtel has g
5l re-evaluated the value of the mcdulus of sub-grade reactions for !
H 3
6kinput into sei:mic analysis of structures founded en inadequately '
1 g
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I compacted scil at the Midland site?
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A The answer is, I don't knew for sure.
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Dr. Afifi, I want to =ake a statement and ask you whether E
10 ! vou agree with it or whether vou believe it is true.
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g 11l1 "The re=edial =easure for the inadequately compacted E
12 '
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=
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g Building is to bridge over the questionable scil utili:ing the 5
14 !
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15 0
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Do you agree with that?
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again?
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A Yes.
19 i
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20 '
l l soil under the electrical penetration creas of the Auxilliery 21 i I
! Building is to bridge over the questionable soil utilizing the 22 '
? structural capacity of the electrical penetration recms by 23 ' providing caissens at their extremities. "
s 24 )*
MR. FARNELL:
Your question is whether --
25 '
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MR. PATCN:
Whether he agrees that that is true.
i ALDERSON REPORTING COMPANY. INC.
165
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I l MR. FARNELL:
Word for word?
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A Can you explain to me what that means, please?
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The question is, is that a clear statement?
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MR. FARNILL:
Is it werd for werd true, in substance a
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j Z
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I 12 l Q
Can you answer the question?
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5 A
I am not sure the questien is technically ccrrect.
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Q Do you mean that you're not certain that all the facts i
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I read to you are true; is that what you're saying?
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I'm referring to the
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I'm not sure whether that j
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i 19 i
,Q You mean the proposed remedies, you're not sure I n
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21 i A
I'm not sure the entire statement you read accurately 3
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reflects, is technically, is correct technically to describe i
s 23 4 what will be done.
I'm not sure.
24 i
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Can you tell =e what part of it you are not sure of?
,\\
25 A
The reference to bridging and the structural capacity i
ALDERSON REPORTING COMPANY, INC.
I
,3 166
,s-i '
cf the structure, things that I can't answer.
I i
2 Q
All right.
Is there a problem with inadequately 3
compacted soil under the electrical penetration areas of the I
4l Auxilliarv. suilding?
i I
s 5
A In my opinion, yes.
n l
N l
g 6i Q
s there a proposed remedy?
j 7
A Yes, sir, s!
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Q What is that proposed remedy?
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To install caissons at both extremities of that, of
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, these two electrical penetrations.
10 t
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Q I will ask you about the very last thing you said, it 3
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Install caissens at the extremities of the two
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14 electrical penetration areas, at both ends of the two electrical I
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Do you agree that the preposed remedy you just recited i
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20 P.R. FARNELL:
Can I have that read back?
2I l (Record read.)
i i
i 22 l A
I don't know.
l 23j SY MR. PATCN:
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Do you know who would know that?
I 25 A
This is a structural questien.
I 4
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ALDERSON REPORTING COMPANY. INC.
I
l 167 44 j
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i 1-0 Is it true that the caissons would support part of the i
1 2
lead imposed by ths electrical penetration areas?
3 A
I believe so.
4 Q
And the centrol tower would support the other part cf e
5l that lead?
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MR. yam; ELL:
! think he said -- that's been asked and g
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I believe that response to that should be provided by d
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?
10 SY MR. PATON:
z=
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- Ilj, Q
Do you have any idea whether the control tower would j
l l
I2 l support part of the lead imposed by the electrical penetration
=
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1 13 areas?
g 1
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14,i MR. FARNELL:
I'm going to object to form.
i i
15 A
In my judgment, I'm not a structural engineer, but in i
j 16l
=y judg=ent, there would be sc=e lead transfer.
i N
I7 !
BY MR. PATON:
a i
3 l
1' w
i 18 1
3 Q
Is it correct that you don't know what portion of the i
19 l total load imposed by the electrical penetration area would be i
M 20l supported bv the control tower; is that correct?
21 A
Can you restate this, please?
5 I
22f Q
I believe you have stated that part of a load of the f
l 23 electrical penetration area would be supported by caissens; is 9
24 -
that correc-'
k i
25i A
Yes, sir.
i a
R i
d ALDERSON. REPORTING COMPANY, INC.
1
i I
l 163 1
,a l
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I believe you have also staced that part of the load 1
2 i= posed by the electrical penetration area would be supported by 3
the control tower?
4 A
-Yes.
I g
5l Q
Do you knew what =rocortion of the total 1 cad incased 4
N i
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by the electrical penetration areas would be supported by che g
u a.,
7.i' control tower?
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A I would not know how much of it.
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9l Q
Will the remedy you described for this prcblem result I
5 10 l in an additional lead on the control tower?
z 1
=
_i IIl MR. FARNELL:
Additional compared to what?
i d
I2 l MR. PATON:
Whatever was there before the remedy.
E 8
y 13l A
I thought I stated that the answer to that should come I4 :i
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i j
15 !
be some lead transfar and I didn't know hcw much.
e 1
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16 :
3Y MR. PATON:
a N
17 '
Q Will that additional lead that is transferred cauce the 5
18 1 centrol tower to settle?
o 4
1
=
i 19 l
=
A That depends on the magnitude of the load.
In my s
20 judgment, the material there is quite good and the settle =en:
I 21 ;
would have to be small.
t 5
22)
Q You mean the material below the control tower?
l 23 A
Yes, sir.
i i
'l l
1 24 j Q
Do you know of any investigation of the possible l
i i
25 ! settlement of the control tewer because of the additional weight i
'l 5
4
,1 ALDERSON REPORTING COMPANY. INC.
I
16 1'
169 1
imposed by the remedy that you have described?
2 A
I don't knew if one is planned at this time.
3 Q
Can you name a person who would be knowledgable with j
4
- respect to the scount of lead that would be transferred to the e
5 centrol tcwer because of tne remedy you have described?
2 6:
1, A
I believe I earlier stated that that would be Mr. Dhar M
I R
7' l who would be able to refer you to -- that information would be 8! under his control, the Civil Group Supervisor.
d d
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Q You indicated that he could give us the answer er that 6
10 8' he would refer us to sc=ecne else?
E l
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A This is his area of control.
He is in control of that d
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information, to my knowledge.
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5 O
I'm not sure I know what you mean by " control."
For E
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example, if I ask Mr. Dhar the cuestions I ask you, do you knew
'=
l 1-9 15 k E
if he wculd provide the answers or would he refer us to someone?
T 16 j
j I believe he would provide you an answer.
A F
17 i
d Q
Dr. Afifi, in recognition of the possible local void E
i E
18 1 g
l under the centrol tower, which we were discussing a few minutes l
t 19 5
I ago, -auui the additional load that will be imposed on the control n
20 tower caused by the remedy you described for the soil problem 1
21 i i
in the electrical penetration area, in your professional judgment, 1
22 ji is there a need to investigate the extent of possible voids and i
I 23 81 future settlement?
I 24.
1 MR. FAPrdI,I.:
Let's take them one at a time, j
a 25 BY MR. PATON:
3 ALDERSON REPORTING COMPANY, INC.
l
l.
I 170 I
Mt 1,
O Is there a need to investigate the exten of possible i
I 1
2l voids in that area?
i l
i 3 g' A
All of the information that is available to =e at this I
4i
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That's what I i
5 can recall frcm the informationse have.
On that basis, I believe e
e i
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t 6i that I wculd croceed with groutin~D as the remedy for that
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situation.
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O Do I take your answer to mean that you'd see no need e
i z,
9l for further investigatien of the extent of possible voids?
I 2
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10 l' A
Not at this ti=e.
z=
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11 Q
How about the need to investigate future settlement?
E l
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As soon as the lead is known, the future settlement can
=
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13 he calculated.
=
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=
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Q Can you tell =e what data you will use to calculate t
=
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15 that ecssible future settlement?
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=
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f 16 A
It would be the available results of the berin; '. cgs l
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O Would that include censelidation test results?
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A These are sands where we have standard penetration g
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tests.
i i
21 Q
Let =e just finish up this area.
I don't think it will l i
22 take =cre than ten minutes.
l 23 l Fith rescect to the use of caissens at the end of the l
4 1
e 24 l electrical penetration area, has Bechtel made an analysis to
]
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25 j deter =ine the a=ount of expected settlement of the caissens?
1 i
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i ALDERSON REPORTING COMPANY. INC.
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43 3 *3 1,
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A That analysis is being made and will be included as l'
1 2l part of the Responses to the 5054F.
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Q Can you tell us who is invclved in making this analysis?
3 A
That is being made by my group.
4!
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5 n
Are you doing it, or is someone under your supervision 0
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Someone under =y supervision.
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Who is.that person?
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A P. K. Chen.
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Can you tell us what kind of information he is using z
2-
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It's the soil properties that have been previously used ;
2 l
13 I I
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in the plant settlement analysis of the major structures at the I
5 j4 l I
2 plant site, such as containment in the Aux Building.
ak i
0 15 '
i i
j MR. PATCN:
Would you read that answer back.
=
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16 l (Record read.)
l 5
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17 2
MR. FARNELL:
Are vou referring to some data he talked 5
l I8 ;
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~'= asking him whether his answer included MR. PATCN:
g
+
20 '
settlement data from the Surcharge Program.
l I
2I MR FARNELL:
You're referring to soil property data?
l 22 '
MR. PATCN:
I'm asking whether his answer included --
23) j MR. FARNELL:
Respeat the question, please.
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L. cora reac.)
1 5
SY MR. PATCN:
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1-4 l
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- n your previous answer, you used the expressien, scil 2ll properties.
My questien is, when you used that expression, did 3'
i l you mean to include settlement data from.the Surcharge Fregram?
I 1
4i A
I did not mean that.
Q Do you plan to use settlement data frc the Surcharge n
6, o
. Program?
R b
2 7 lf A
The analysis is not complete, and it's possible that 2
g,
=n i that would be used.
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Off the recGrd.
s t
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i (Discussion of:. tn.e recorc.)
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11.
l 3Y MR. PATCN:
3 l'
12,
l Q
Is there a potential soil problem at the service water l
z 4
13 i i
2
. structure?
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14 i d
l A
Yes.
-u 15 2
Q Could vou describe briefiv and generally, the ecoc.esed i
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remedy for that.rchle=?
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A Thc cantilever pertion of that structure is supported
=
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18 '
i en fill.
T.'.e results of the berings in the area indicate that tP
=
19
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For that r,aseni, 20 'iJ i
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?.:iles are croc. esed to sup=. ort the cantilever, the end of.that t
21 i Lcantilever.
3 i
22 4 Q
Is there an analysis being made to determi.e the etcunt 23 i
,of the expected settlement of the piles?
i, 24 i I
j A
Yes, sir.
i 25
l O
Who is making that analysis?
i 0
j ALDERSON REPORTING COMPANY,INC.
I 50 173 I
A
?. K. Chen.
i 2
Q Can you tell us what kind of data he.is using in i
3
=aking that analysis?
4 A
The same type of data that is used for the analysis of I
e 5l the caissens.
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Q
- recall you just indicate, I believe, that you are u
n 7
going to use the same type of data?
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A Yes, sir.
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Q And I recall your answer to be with respect to -- I
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10 regall your answer to be that you were going to use soil z=
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12 soil properties, where did you get that information from?
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Soil properties were obtained originally by site w
j I4 l investigations by Oames and Moore, which are included in the FSAR, e
15 additional laboratory tests'that were conducted on plant fill afte/
f 16 i the disec rery of the Diesel Generator Building, and borings made d
i f
I7 after the discovery of the Diesel Generator Building problem, as j
I s
t f
I8 l well as before the discovery of the Diesel Generator 3uilding i
19 :croblem.
i 2
5 a-20 1
(Luncheon recess.)
II l MR. BRUNNER:
The record snould reflect this morning f
I 22 l that Mr. Paton made a request tor documents entitled "Drawir.cs i
23 i
jconcerning Separation et canonie Work from Bechtel Work."
l J
t 24 Consumers agreed to attempt to locate thoce documents at Bechtel's l
25 Ann Arbor offices today.
We were informed that the documents are j
i l
I ALDERSON REPORTING COMPANY. INC.
l
l
- 2,_
l : not available at Ann Arbor, and may be at the site.
l l
1 2'
Consumers has agreed to attempt to locate the requested !
i i
3 l documents at the site and to.crevide those documents, amonc. them l
i 4I which are discoverable.
e 5
- G. PATON:
Cff the reccrd.
i i
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6!
(Discussion eff the record.)
~
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7i MR. BRUNNER:
The documents I referred to are described I
i nj 8
cn Page 1 cf the document entitled, Meeting Notes Number 1013, d
9
- 9) date August ist, 1979.
Subject, meeting of the Diesel Generater z
c 10 I Building Task Group.
I will read frem the sentence of that z
i 1
E 11 l carticular document which describes the documents, which as I 4
I E
i
'i 12 I understand, have been requested.
If that sentence doesn't I
z i
d 13 I c.recerly describe the dccuments, then I request that a question l
w i
l
- i 14 he nade bv Mr. Paton.
The sentence which describes the do " ents t
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- r, 15 1 is as follows:
l i
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j "The Caia and drawings cencerning separation of Canonie's, 16 M
i d.: 17, work frc= 3echtel werk by construction."
I
-5 18j (Oiscussion off the record.)
i t.
19 '.
MR. PATCN:
The infor=ation that Mr. Brunner has iust x
=
f 20 f addressed is data and drawings concerning separation of Canonie's l l
4 21 l work from 3echtel work by construction, which is referred to on I..
22 l a page that has been marked as S3 801726, entitled Meeting Notes,
{
4 l1 l
23 ' which dacument was identified just now by Mr. Brunner.
The ex-l t.
24 e pression comes frem two sentences at the bottom of the document I
25 which reads as follows:
i l
a i
1j ALDERSON REPORTING COMPANY, INC.
i
I 175
-n 3.
1!
"This item is closed.
The data and drawings concerning l
i i
I 2l separatien of Cancnie's work frc= 3echtel work by constructicn l
i I
I 3'.have been forwarded to Gectechnical Services for review."
I i
4l MR. FARNELL:
This =crning you made a statement con-I i
i e
5! carning the large number of 3echtel documents that are at Ann j
i H
1 6
Arbor dealin; with soil.
I indicated that I would speak to i
~
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R 3
i I
.n 8l I spoke with Mr. Za= erin, and he indicated that we had told you n
t l
i t
9 these docu=er.ts dealt with the Midland soil issue and we have not i I
z-i j
1]
10 j read them yet.
He also indicated that we would respond to a z
l 4
=
5 11 ' proper document request asking for specific documents and the
<3 6
12, documents produced in response to the docu=ent request which would z
i
=
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13 ? come from this large nc=ber of soils documents at Ann Arber.
=
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We told ycu that we would produce a porr'.cn of the i
.9 15 ; docu=ents in Mr. Afifi's file or under his control, and we have 6
I x
=
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T 16 l done this.
You will note that the Notice of Deposition and the i
5 I
I n
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17 request to produce therein only calls for these documents, and we r
a 18 l
! have fulfilled that request.
E 1
C, 19 4,
Mr. Zamerin also told me that he had indicated to you a
i j
20 that we would provide a one page su==ary of the dccuments cen-s.
s 21 l tained in the large number of documents, not that we would I
22 jproduce the index to the docu=ents.
i I
23 '
I also note for the record that we have made a docu=ent
,j 24 production request set fcrth in each of our Notices of Deposition.',
i i
i 25
,1 Mr. Paton requested that we agree for the time being that he only u'I
. i s'
1 a
ALDERSON REPORTING COMPANY, INC.
i
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176 i
l 53 i
i i
produce those documents in'the possession or control of his 2'
NRc staff personnel or the Corps persennel.
We accommodated 3 f Mr. Paton for tde time being, but we also note for the ' record I
4 !
that our request is still outstanding for the other documents l
1 g
5l and has not been complied with yet.
e M
i I
j 6l MR. PATON:
I will state that that is my first knowledge M
d 7l ever that we'are now introducing a, fer the - time being, concept u
i g
8j. into this case.
It was :gr clear understanding that we had agreed
-J y
9 I that the document request in the Notice of Oeposition was to be zo l
's10l understood to mean the docu=ents within the control of each z
i
-=
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i 11 ' person, and if it is now being amended that that agreement is new l 3
g.
12,
amended to be "for the time being" that is my first knowledge of I
3g 13 i that subject, but if that is -- I have no further comment.
i 2
i 14 l BY MR. PATCN:
b i
l j
15 '
Q Dr. Afifi, I show you a letter dated October 22, 1979
=
1 16 g
from Mr. G. S. Keeley to Mr. J. A.
Rutgers of Bechtel Power i
s N
17 Corporation, and ask you if you've ever seen it before?
a
=
"a 18 :
A I do not recall seeine this letter.
I i,
C i
s 19 j Q
-I show you another document which I will not make a
~
M 20 i deposition exhibit.
This is in volume 1 of your response to the i
II!
5054, Question 2, and I ask you to read the question and the 4
22 i) response.
l 23 MR. FARNELL:
Did vou make that an exhibit?
1 1
4 t
i i
4 24 ;
MR. PATCN:
I have =arked the letter from Keelev to l
l 25 Rutgers as Deposition Exhibit Number 4, today's date, October 30, 4
i 8
ALDERSON REPORTING COMPANY. INC.
l i
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177 54 1,3980.
$_< _4 _e.4 2
BY MR. PATON.
l 3 !
O All right, sir, my question is, is there a problem with I
4, natural sar.ls under the service water structure?
5 g
A I am not aware of the problem below the.serfice water
-i
~
lll 6 l' structure.
_n*
7 Q
Are there loose sands under the ser-fice water pump Mj 8
structure between elevations 599 and 601.5?
9 z.
A Sir, I do not know this for a fact, but it is stated in o
(
10 I "b
the response that there are two and a half feet of loose sand z
t r
t,-
under the serfice water portion of the structure.
em 12 i
Q Other than this document which is Page 2.1 frc= the
=
13 g
- 5054 F response to volume 1, you have no knowledge that there are 2
1 14 lany -- do you have any knowledge that there are any loose sands si j
--=
m 15
,bader the service water pu=p structure?
I 4
=
if 16 j
~
A The fill portion, the fill itself contains loose sand
=
i i
j 3,l,and that's why the watering system is going to be implemented.
=
1
{
18 (Discussion off the record.;
r 19 M
i SY ?1R. PATON:
I 20l Q
A:te there loose sands below the structure?
1 2Il MR. FAR: ELL:
Are you referring to anywhere below, I l
i 22 lrean, depth-wise down to the center of the earth?
1 i
i t
j 23 '
P A
Available borings, so to =v recollection, there are t
. 24 l
31oose sands below the fill supported portion of the st ucture.
i 3,
25 j Q
Are the loose sands in the fill?
i t
N l
ALDERSON REPORTING COMPANY. INC.
1 1
55 j
As8 i
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I A
':'c =y recc.11ection, the fill contains leese sands and i
2 the response here, refers to two and a half feet.
It could be j
i 3
in the boundarv between Icese natural sand and fill 4ust at the l
4 i
I boring SW-6 as indicated at the ti=e the response was pre. tared.
i g
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5 i
Q Are you aware of any ec==it=ent in the PSAR to rmeve i
n i
e natural sands less than 75 percen: dense?
=
M R
7 A
Yes, sir.
m 8 i
=n Q
Did Le hcel re=ove natural sands less than 75 percent j
J l
z-9l~dense in the cower block area?
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ALDERSON REPORTING COMPANY, INC.
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179 1
Q What was your understanding of the committment in the.
l f
2-PSAR to remove natural sands less than 75 percent _ dense; to what 9
i i
3i did it extend, to whnt area did;it extend?
f 4
A I don't recall all of the details.
I just recall that 3
5, there was a committment to remove sands with a density of less R
l y
6! than 75 percent.
R 1
2 7
Q And your testimony is that you don't know whether that A[
8l was done or not?
f d
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2 9I Do you know whether it was done or not?
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I do not know, no.
J.
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l 11 Q
Under whose responsibility would.that fall, to know 1
2 l
I 12 whether that was complied with or not?
4 1
g 13 i (Discussion off the record) 4
=
i m
3 14,
A Please repeat the question.
u k
4 j
=
15,
SY MR. PATCN:
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=
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Whose responsibility would it be to determine whether i
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17 there was compliance with the committment in the-PSAR, discussed x
.x i
4
}
}
18 concerning natural sands with a density less than 75 percent?
i I
i-g - I9 A
Project Engineering.
i i
M 2
20 Q
Who, specifically, in Project Engineering?
?
21 A
I don't know specifically who in Project Engineering.
4 22 Q
Sir, I want to read you a sentence from the last para-
?
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23 ' graph of this letter, and if you'd like to see it, I'll hand you j
24 the document.
1 25',
"Therefore we de not accept the argument that because the r
-i i
ALDERSON REPORTING COMPANY. INC.
130 1
recent borings showed natural sands which had relative density n
u 2
greater than 75 percent, Bechtel has no liability for additional 3
costs."
l 1
4 My question is, are you aware that from time to time, j
i 5
there are discussions between Bechtel and Consumers as to who is
- e f
n n
6l liable for som( af the construction work done at Midland?
I
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7 MR. FARNELL:
I'd note for the record that you just read I
.n 5
8 from Afifi Deposition Exhibit 4.
n d
I
- i 9l A
Can you repeat the question, please?
i 4
I E
10 !
(Record read)
~
l f[
l1 MR. FARNELL:
Can you give a time frame?
i d
12 l MR. PATON:
In the last five years.
z=
E 13,
A I've heard that such discussions do exist.
=
x
=!
14 3Y MR. PATON:
C 15 l Q
Have you heard such discussions exist with regard to the w
l
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T 16 l plant fill at Midland?
3s
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g 17 MR. FARNELL:
Such discussions -- you're talking about x=
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18 : sand, and now you're talking acout scmething different?
j E
I 19 I MR. PATON:
Oh, come on.
The question was whether from I
E6
~
l i
20 i time to time there are discussions between Bechtel and Consumers i
l 21 j Power as to who is liable for work at the Midland site, and I then 22 i asked him were there such discussions with respect to plant fill.
l 23,
MR. FARNELL:
As to who is liable for the plant fill?
24 In other words, there's no context to it.
o 25 MR. PATON:
There was until you --
t i
i ALDERSON REPORTING COMPANY, INC.
I
- l
i 181
'3 1
3Y MR.'PATON:
i
'2l Q
I will read the sentence again from Deposition Exhibit 4.
t 3
"Therefere we do not accept the argument that because thei 4
recent borings showed natural sands which had relatives density l
s 5
greater than 75 percent, Bechtel has no liability for additional 2+g 6
costs."
R l
1 7l Do you understand what that means?
c
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A Yes, I understand what the sentence means.
4 9
E, Q
What does it mean?
10 A
I believe the sentence means that C=nsumers Power Company E
11 believe that Bechtel should pay for the borings, for the cost that 3
a E
12 lwas necessary to conduct evaluations.
E I
5 l3 i
Q All right.
Have you ever heard of any discussions be-
=
E I4 tween Consumers Power and Bechtel relating to who will pay for the w
'=j 15 cost of the remedial action at the Midland site, and I mean
=
j j
16 i remedial actions with respect. to the soil settlement problem?
i I
h I7 MR. FARNELL:
I'm going to let him answer this question,
=
~
I8 'but I don't think this is relevant to the scope of the hearing.
I.
19 A
I've heard it mentioned, but I'm not sure 6f the source g
i E
i 20 'cf the information.
2I Q
What did you hear mentioned?
j i
l 22 '
A I don't recall who mentioned it specifically, but I've 23! heard it mentioned that Consumers -- that Bechtel may end up having 24l to pay for the remedial work, but I don't recall exactly who said i
25l i or whether this information was speculation or fact.
i l
I ALDERSON REPORTING COMPANY. INC.
l
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182 i
4 1
Q Have you heard whether Consumers plans to sue Bechtel or 2
Bechtel plans to sue Consumers with respect to this matter?
I 3
MR. FARNELL:
I'm instructing him not to answer that 4l question on the ground of attorney-client priviledge.
g 5
SY MR. PATON:
E i
j 6i Q
Do vou know if there is any attempt being made to arbi-7l R
j trate any differeces that may exist between Bechtel and consumers s
i j
8! with respect to the soil settlement problem?
d 9
A No, sir.
i=
i y
10 -
Q Have you heard any figures as to the total cost of the z
=
j 11 l remedial action because of the soil settlement problem?
E i
f_
12 {
A Would pu repeat the question?
^
l g
13 !
(Record read)
=
5 14'l m
A Again, I've heard figures, but I don't recall where they M
g 15 l came from precisely.
I heard numbers on the order of 20 million l
=
j 16l dollars.
y 17 i Q
And you believe you heard that on the order of 20
$c z
18 I million dollars; was that the total cost for the remedial actions e
19,for the soil settlement problem at Midland?
g n
20 !
A I can't tell you exactly.
I have heard numbers on that 21! order, and I wouldn't know the contents, the ingredients of these l
22 i numbers or the scope.
That's pure -- that's the only thing I can 23 recall hearing.
24 C
Is there a figure that Bechtel uses to attribute to the 25 ] cost of delay of. the plant,.for example, so many dollars per day?
d 4
i
- )
ALDERSON REPORTING COMPANY. INC.
l
l 133 5
1, A
I'm not aware of such figures.
I i
2 Q
So many dollars per day for each day of delay?
1 3
A I'm not aware of such figures.
4 Q
Has the plant fill settlement problem affected 3echtel's e
5 willingness to submit information to the NRC?
eN 3
6:
(Discussion off the record) a 7l 2
MR..FARNELL:
What do vou mean?
I need some context Kj 8
with Bechtel's willingness to submit information to the NRC.
Are d
l 9
you talking about this project or other projects?
10,
MR. PATON:
It's my position that if the witness under-3 l
j 11 ! stands the question, the question should be answered unless you a
f 12 instruct him not to answer the question.
If he has difficulty with
=
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13 ) the question, I think he should say so, and I will try to change g
14 ' the question, but I don't think it is appropriate to stop the a
ws 2
15 deposition to answer question from counsel because counsel has i
a
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A 17 i MR. FARNELL:
You are flat-out wrong on your statement.
w
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.t 19 MR. PATON:
Are you instructing the witness not to n
20 ! answer the question?
i 21 MR. FARNELL:
No, it is unintelligible.
22 !
MR. PATON:
If the witness tells me it is unintelligible, i
23 ' I will try and rephrace the question.
24 A
would you please repeat the question?
25 3Y MR. PATCN:
ALDERSON REPORTING COMPANY. INC.
i
l 134 l
l 6
1 i Q
Do you understand the question?
I 2
A I don't understand the scope of the question, no.
I 3 \\.
0 You don't understand the scope?
i s
4 4
A I would like clarification on the cuestion.
I i
5l Q
You don't understand the cuestion generally?
I e
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I'll ask another question.
a R
R 7!
A Okay, go ahead.
1
-n 3
8 I Q
Is Bechtel willing to provide information to the NRC in I
=
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9' its review of the Midland facility?
i 10 l A
To my knowledge, Sechtel is providing information to the z
l 3"
11 ' NRC in review of the Midland f acility.
1 I
i 12 i Q
Whv do vou do that?
z_
1 5
13 j A
Secause of all the responses to the questions that have
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14 t heen prepared and all of the data.
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You naean you do that because we ask questions?
R t
1 16 !
A This question really cortends to Sechtel as a whole, and u
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17 l it's hard to say.
I would not know the answer to that.
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18 '
Q Are you willing to provide information to the NRC in its C
19 i review of the Midland facility?
I X
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20 !
A I am willing to provide information.
i 21!
Q Do you have any instructions with rescect to vour I
22 l providing infornation to the NRC in its review of the Midland l
l 23 '. facility?
j 24 -
A Yes, I received the instructions of what to provide from I i.
1 25 :the project or the task group leader connected with the job.
f i
i i
ALDERSON REPORTING COMPANY. INC.
l l
1 I
185 I
7 i
Q Dr. Afifi, I show you a document that I will mark as 2' NRC Exhibit No. 5, 10-30-90 ( Afifi), and ask you if you have ever 3 iseen that document before?
I 4
(Discussion off the record) l i
g 5
3Y ".R. PATON:
nN 6
Q I show you a document that I have marked NRC Deposition e
t o
E I
E 7l Exhibit No. 5, 10-30-80 (Afifi), which consists of a cover letter I
8l dated August 4, 1980, two pages long and signed by Mr. Schwencer of M
J I
E.
9{ the NRC with an attachment dated July 7, 1980; subject, Inter s
1 10 l Agency Agreement No. NRC-03-79-167, Task No. 1, Midland Plant, E
5 11 ' Units 1 and 2; sub-Task No. I letter report, that attachment being i l
5 1
d 12 l 16 pages long, and ask you if you have ever seen NRC Exhibit No. 5 z=
E 13 before?
=
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Yes, sir, I have.
W l
=
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15 j Q
Have you read it before?
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I 16 l A
I read certain cortions of it.
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j 17,
O I direct your attention to page 3 of the attachment a
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18 j which is the portion on the letterhead of the Corps of Engineers, i
=
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j 19 'specifically to the paragraph about seven lines from the top of l
e 1
20 lpage 3 that reads (2) Bearing Capacity, and ask you to read that 21 - four-line paragraph.
i.
I 22f A
Yes, sir, I read that.
i i
23]
Q Do you know whether Censumers or Bechtel have performed j
24]1 the bearing capacity computations that are referred to in that j
25 l paragraph?
i t
a ALDERSON REPORTING COMPANY, INC.
I i
I 136
{
1 i
i 1
8 1)
MR. FARNELL:
By this, I take it you mean after -- this
~l 2l request asks for, I believe, new bearing capacity computations.
I I
3l Are you asking whether the Bechtel or Consumers has sent l W
4l bearing capacity _ computations in response to this request?
I 5!
(Discussion off the record) 1
~
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6l SY MR. PATON:
~
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t 2
7l Q
Dr. Afifi, within that four-line paragraph, do you see n
3 8 !the three words, " bearing cacacity comcutations"?
n i
d i
t t
9i A
Yes, sir.
4 l
2 1
10l Q
Do you know whether Bechtel or Consumers Power has ever 2
i
=
j 11 made such bearing capacity computations?
3 I,
j-12 l A
Yes.
=
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13{
Q Who made them?
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A The computations have been made by the Soils Group.
9 j
3 j
15 0
Who, specifically?
y 16 l A
I believe the most recent computation was made by Mr.
=
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i 18 I Q
Do you know when those computations were made, 3
p i
r 19 ! approximate.ly?
gg 20 i A
They have been prepared as part of the response to i
21 !, Question 39.
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22 l Q
Do you intend to provide that information to the NRC?
l l
23 A
Yes, sir.
l 1
24 Q
Dr. Arifi, did you state that you had read portions of i
i I
25 J'this 16 page document from the Corps of Engineers?
]4 t
ALDERSON REPORTING COMPANY. INC.
l 187 I
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9 1 l A
Yes.
i j
2l Q
And did you read the portions applicable to your cwn i
?
3l l
responsibilities?
l I
4 A
Those are the ones I read in more detail, yes.
l g
5j Q
Do you recall within the portions that you stated that e
i l
4 i
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6 you read in more detail, are there any requests for information in i
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-n 8l intend to provide?
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i MR. PATON:
Off the record.
2 i
10 l (Discussion off the record) z
=
11 i 4
MR. FARNELL:
We don't have on the record what portions 3
y 12 he read, and the question is misleading and bad as to form, among
=
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I4 l MR. PATON:
All right, if you have instructed him net to
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If he can't, that's fine.
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MR. FARNELL:
We're not even cettine that far.
I'm i
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i 3
I w
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18 f
instructing-him not to answer.
It's misleadtng, anc I am willing i
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19 i i
to go; item by item, but not like that.
3 a
20l MR. PATON:
All right.
IIl BY MR. PATON:
22 l Q
Dr. Afifi, will you tell me, starting on page 1, which 23 ! sections you read more carefully because you felt it was within 4
'4 -;your scope of' responsibility?
A I believe I read the first two pages -- let's see.
There!
15 t
s i
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ALDERSON REPORTING COMPANY. INC.
i i
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l 188 10 1! are different degrees, really, how hard I read each part, but I i
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2' read the first page and the second and the third.
Evenwithineachj i
3 Ipage, there are certain areas that are not my resconsibilitv, and l
1 4I I can't identify them -- there are different pages, and I can tell !
5 l you that I read 4, 5, portions of 4 and 5 are not my entire e
n" i
6 Lresconsibiliev.
I read number 7.
1
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R 7 lI Q
You didn't read number 6?
nj 8
A I read 6, portions of 6.
I read the entire page 6, but I believe I stated that portians are not within =y area of responsi-l d
l 9l 10 bility.
I read 7 and certain portions of 7 are not within my area z
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11,l of resc. onsibilitv..
I believe 8 and 9 are not within
=v. area of
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12 ' responsibility.
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Q You have eliminated 8 and 9, pages 8 and 9; is that
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15 A
I believe that those portions, to the best I can recall a
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16 at this sement, they are not within my area of responsibility.
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Then the rest of page 10 and the top a
5 18 l of page 11, I read.
I I
19 !
The Question 47 which covers pages 11, 12 and 13 and the n
20 top of 14, I recall reading it sometime ago, but it's not within t
21j my area of responsibility.
I read the portion en page 14 and the i
22 ' top of page 15.
i i
23 The Question termed No. 48 on page 15 and 16, I believe i
I 24 l I read, but it's not within my area of responsibility.
When I say i i,
25 lit's not within my area of responsibility, I might provide certain l i
4 3
N ii ALDERSON REPORTING COMPANY. INC.
i 189 I
11 1 ' input at certain times, but it's not originated by my people.
j l
2!
Q Dr. Afifi, on page 3 near the middle of the large para-3 graph that follows (1), about two-thirds of the way down, you see l
4{ a se:'tence that begins on-the right-hand side, "To verify the e
cre load test..."?
nM s
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6-A Yes.
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O All right, continuing with that sentence, it says on the M
i 8
next line, " compute settlements based on test results on samples a
n 3
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frem new borings which we have requested in a' separate memo and i
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- c. resent results."
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First, is that subject within your area of responsibility?
1 is d
12 A
Yes, sir.
z=
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And do you know whether the settlements requested tnere E
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14 l are being prepared?
t:
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Would you repeat the question?
l
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With respect to the words " compute settlements," do you e
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17 i know whether those settlement computations are being prepared?
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18 A
No, sir, they are not being prepared.
=
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Do you know why they are not being prepared?
n l
20 l A
Yes, sir, I do.
1 21 ;
Q Why?
l 22 !
A Secause the Applicant's position paper has been presented',
i 23 ! stated, that in the opinion of the Applicant, there will be no i
l 1
24 l boring involved for that purpose.
l l
25j Q
Let me ask you, by that position paper, are you referring {
a I
i i
ALDERSON REPORTING COMP ANY. INC.
I
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190 4
12 1 Yto a document dated September 14, 1980?
l 2
A That's about the richt time.
I I
I 3
Q Dr. AFifi, I just want to show you Consumers Power I,
4I Exhibit No. 3, Heller Deposition on October 9.
There is a dccumenti I
l i
5 here dated September 14, 1980.
i e
H l
3 6:
Can you tell by looking, is that the document you were a
2 7
referring to?
I 8
A Yes, sir, n
s z,
9l Q
And your shorthand title for that is a position paper?
Oh 10 !
A Yes, that's it.
E
=
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To your knowledge, has there been any recent discussions 3
I f
12 ; concerning Consumers' position with respect to this request here
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13 ! to compute settlements to verify the pre load test settlement
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14 j conditions, compute settlements based on test results, on samples-b l
=g 15 : from new borings which we have requested in a separate memo and e
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17 i
.MR. FARNELL:
Discussion with who?
2=
l 18 i MR. P ATON :
Discussion with anyone.
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19 A
I don't recall any recent discussions.
l a
20.f Q
When you say, position, you mean Consumers Power's I
i l
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21 ! sosition?
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22 '
A I meant the -- I was referring to the document, yes.
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23 '
Q I'll show you the document again, if you want to, but 24 l vas that document prepared by Consur.ers Pcwer?
i A
That document was prepared by Bechtel with some input 25 li 1
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1 a
ALDERSON REPORTING COMPANY,INC.
l
l 191 4
t f.
13 1, from Consumers Power.
I 1
2 Q
And is the essense or the summari:ing the position, is i
3 I it that there is no need for new borings?
I 4
A Yes, we have discussec that previously with the Staff, e.
5 Dr. Peck, and I have participated in these discussions.
That's i,
nN i
8 61 how we feel from an engineering. standpoint.
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[
7 Q
Can you tell me whether that was sechtel's decision or N
, Consumer Power's decision?
8 8l i
4 5
9 A
With aspect to the subject of settlement, I personally i.
10 l recommended strongly that is not the way to go, and that's all I z
5 11 ' can tall you.
The decision ultimately is the client's decision.
1 3
I i.
12 l Q
You said you recommended strongly.
Can you tell me why t
E l
j 13 l you said, strongly?
j 14l A
Because I believe that the full scale measurement that I
i 15 l wemadeontheDieselGeneratorBuildinecrevidedsufficientbasisl w
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17 ' to settlement.
I believe this is reliable and gives us the answers g'
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Q The need for additional borings -- strike that.
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There is no clan to have a Surcharge Program at the 1
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=
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21 l Auxiliary Building, is there?
i I
22 l A
No, sir.
i 23 '
Q Do you plan to take new borings in response to request I
i 24 ] from the Corps cf Engineers with regard to the remedies at the I
l 25 : Auxiliary Building?
-l 1
ALDERSON REPORTING COMPANY. INC.
l 192 I
l 14 1 -
MR. FARNELL:
Would you repeat that, please?
1 i
2i (Record read) l 34 A
I don't recall that the remedy, that the Corps of l
l 4< Engineers requested settlement evaluation for the Auxiliary I
I e
5, 3uilding, with respect to fill.
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3 61 SY MR. PATON:
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You have been requested to take additional borings by
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9i at the Aux Building; is that correct?
z m
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Yes, sir.
=
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Q And did you have a recommendation with respect to those
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12 borings?
z:
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Mv recollection is that the request was in relation to
=
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=
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Both bearing capacity and settlement --
a-l i
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So what's the question?
I d
17 Q
Do you you have a recommendation as to whether or not E
5 18 l those additional borings should be taken?
l
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19 l A
Where?
Are we talking the Auxiliary Building?
5 20 l
Q Yes.
l l
21 A
Deep in my heart, I do not feel that these borings were l
l i
i l
22 l necessary.
I have no objection to taking them or not taking them.
I 23[ Deep in my heart, I don't believe they were necessary.
l 24)
Q Can you tell me why?
1 25 ;l A
Because the caissons would be succorted on the natural
)
i 1
ALDERSON REPORTING COMPANY. INC.
_ =
i 193 a
i d
15 1 ifill at the site.
There would be excavations made, the opportunityt I
2 to inspect the excavations, there would be lead tests done on j
3 these caissons during construction, and there is opportunity to 4
take samples from the tip of the caissons, if we needed to do that,l e
5 right below the tip of the caissons, and get the information we n
N I
3 6' want.
It would be better information than drilling a hole 25 or e
R l
A.
7 i, 30 feet away from the building.
.n j
8 0
Do load tests provide information on long term settlement?
f U
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=
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No, sir.
\\
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10 Q
Do you believe that if you took these borings requested.
z=
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11 ' by the Staff and the Corps of Engineers, you would be provided any 3
y 12 j information with respect to settlement predictions and bearing E
i s
13 ; capacity at the Auxiliary Building?
=
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14 lI MR. FARNELL:
Read that back, please.
2 i
-=
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15 '
(Record read) a=
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Can you clarify the question, please?
a 3Y MR. PATON:
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Q You_ don't understand the question?
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Yes, if you would clarify it, please.
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Q
- n what way?
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A Are you saying any information at all?
I 22 ;
Q Yes, that's what I want you to say.
i 23 A
Any information whatsoever?
l I
24 Q
Yes, that relates to a settlement prediction.
k a
25 A
Irrespective of whether it's valuable information or not?i i
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s ALDERSON REPORTING COMPANY. INC.
i
p 194 16 1 1 O
You can start there.
That's what I asked you, would you 1
2 jreceive any information --
l 3,
A There will be information obtained from the borings.
1 44 Q
Will that information be of any value in predicting i
I 5, settlement?
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1 Q
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6i A
It could be of some value.
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A 7.
O could it be of some value in predicting bearing capacity?
j 8j A
Yes, sir.
i d
2 9
Q Dr. Afifi, are there any requests for information in the
?,
10 document submitted by the Cerps of Engineers dated July 7, from z
1 i
=
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j 11 I pages 1 through 16, within your area of responsibility that you do R
I i
0-12 not understand?
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3 i
j 13 l MR. FARNELL:
Same objection.
=
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(Discussion off the record) m=
1 i,
2 15 !
3Y MR. PATCN:
i i
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Q I'll say page 1 and he can answer, and then I'll sav i
I i
17 j page 2.
As a matter of fact, starting from page 1 at your attorney ls x
s
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18 ! request and going through page 16, would you answer for each page?
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19 i MR. FARNELL:
I want better than that.
I want each i
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20 l individual request.
21 MR. PATCN:
Are you instructing him not to answer the i
I 22 ) question?
l 4
23 MR. PARNELL:
The way you have it phrased, yes.
24b MR. PATCN:
ill ri7ht.
4 25 MR. FARNELL:
I am willing to have him answer as to each a
.h Nj ALDERSON REPORTING COMPANY. INC.
I
I 195 L 17 1: individual specific request.
I think it is a compoind question.
l
.I 2
MR. PATON:
That's fine, you have instructed him not to 3
answer, so I don't see the need for --
I I
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4 MR. FARNELL:
He's here to answer your questions.
l I
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MR. PATON:
All right, you instructed him not to answer l
R g
6;and I'll ask him another question.
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7 SY MR. PATON:
-nj 8
0 Dr. Afifi, I direct your attention to page 1 of the U
9 Corps report dated July 7,1980.
,z 10 A
Are you referring to page 1, sir, where the letterhead 5=
II exists?
Q3 f
I2 l Q
Yes, sir, the page that has at the top in all caps, I
=
13 '! SU3JEC"':
INTER AGENCY AGREEMENT, et cetera.
5
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Are there, in your opinion, any requests for information e
i 15 on that page?
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16 {
A Okay, I nave difficulty with pages 1 and 2, in general.
e 1/ '
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Q In understanding them?
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18 :
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MR. FARNELL:
I think he's indicating there's something i
I9 I
g about,them he didn't understand.
n l
20 l MR. PATON:
I'll ask another question.
21 BY MR. PATON:
22l
.Q Dr. AFifi, would your address page 1 of the Corps docu-I a
4 23 ment dated July 7, and I ask you, do you understand, is there any-i I.
kthing on page 1 that you do not understand?
fJ i
15 MR. FARNELL:
Take it line by line.
i i
i 3
ALDERSON REPORTING COMPANY. INC.
1
196 18 1
(Discussion off the record) 2 (Recess taken) 3 BY MR. PATCN:
4l 0
Dr. Afifi, I believe you testified that you had recom-1 g
5 'nended strongly that consumers not provide the Staff with e
M j
6, additional borings that were requested by the Staff and the Corps i
-n R
7 cf Engineers; is that correct?
A I
8l MR. FARNELL:
I don't believe that was correct.
n Ud 9
A I don't believe I said that, no.
zo l
10 i BY MR. PATON:
I z
i
=
+
j 11 Q
Is it correct that you recorr. ended strongly that the 8
1 y
12 borings not be taken; is that what you said?
=
i m
l l
13 i A
No, I didn't say that.
=
=
5 14 0
You referred to a strong recommendation, which you made
=
1 c
15 about 10 minutes ago.
Can you tell me what that strong recommenda-az l
I 16 tion was?
g i
I 17 A
I believe I was referring to the method of predicting 5
l r
18 : settlement, "tbi be based on the full scale measurements.
=
=
I i
19 ; settlement prediction is best obtained from full scale measurements) a M
20 ! n my opinion, if that access is available.
i i
1 21!
Q Do you know whether Dr. Peck concurred. in that l
4
.f 22 8:eco=mendation?
4 23 '
A I believe Dr. Peck agrees with that.
I 24 l Q
Did you ever hear Dr. Peck made any statement concerning !
I 25 the advisability of taking additional borings,for predicting i
i i
ALDERSON REPORTING COMPANY. INC.
I
\\
1 197 I
19 1 2 settlement?
i 2
A I don't recall hearing Dr. Peck talk to me about that.
3 Q
Did you hear him talk to anybcdy about that subject?
4 A
I believe there was a statecent made once that if the 5 ' Staff is concerned about the three feet of fill just below the l
g H
I 2
6 foundation, that may be tried, and the only way to satisfy the e
E 7li Staff along these lines would bi to run a consolidation test to i
n j
8 verify there would not be additional settlement, or something d
E.
9l along these lines.
I
~
10
'j Q
Are there any other state =ents by Dr. Peck that you
=
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5 II i recall he made at any time, with respect to taking additional l
5 3,',
5 borings for the purpose of predicting settlement?
_=
13 I 5
A I don't recall any others,.and I'm not actually sure i
i 1
3 14 '
i I
that the first statement was made by Dr. Peck.
I re= ember in the i
t
=
15 b
l back of my mind it was made as to, was made to me by Walter i
=
7 16 Ferris, and I don't recall if that was from Walter Ferris or was i
s i
17 '
s a result of a discussion between 11ter Ferris and Dr. Peck.
l i
E i8
=.
j Q
Have you told us all of the statements that you can recall j9l' hat, to your knowledge, were made by Dr. Peck to anyone con-
-j t
20 ' cerning taking additional borings for the purpose of credictine I
21!
4 settlement?
a 4
1 i
n3 4
Well, with respect to shear strength -- would you A
23 please repeat the question?
1 24j#
Q Have you told us all of the statements that you can i
25 l recall having heard from Dr. Peck concerning his recommendations l
3'
'l ALDERSON REPORTING COMPANY. INC.
f
198 20 1 lfor taking additional borings for the purpose of predicting i
2 tsettlement?
l 3 :I MR, FAanz;;:
I don't think it was his recom=endation I
4, concern ng -~
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BY MR. PATON:
s_
i H
?
j 6,'
Q Recommendation for or against taking the borings for the E
I i
g 7' purpose of determining --
1
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8 A
My understanding is that Dr. Peck is not in favor of l
J i
9' predicting settlements from borings.
He, himself, is not in faverd u
10 Q
Is that statement applicable to the plant fill at z=
il j Midland, or is that generally his position?
i a
i N
I2 A
I thought I understood your question, you were referring:
-o i
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E to predicting of the general settlement.
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Okay, I'll accept your answer with that understanding.
I h
II l Do you recall Dr. Peck ever making any statements about
=
1 i,
16, the desirabiliev. of takinc. additional borine.s for the o.urpose of N
I7 x
, determining bearing capacity?
2 i
j 18l A
I have difficulty with the word " desirability."
i k
I9 '
Q Advisability?
l 4
20l A
I believe one of the times we have discussed that if f
1 21 i the Staff is insisting on the borings for the bearing capacity,
!l i
22 g there would be nothing wrong with doing them, as far as the 23 l bearing capacity is concerned.
+'
'4 l
l 1
24 4 i
1
(
i
-Q Oo you plan to do them for that purpose, for revealing
)
25 4 information about bearing capacity?
l i
ALDERSON REPORTING COMPANY, INC.
1
i 1
199 i
i l'
4 l
21 1I A
I believe that we have estimates, sufficiently l
l i
i 2i estimated bearing capacity with available information that we have..
Ii 3 lI believe that the additional data that we would get would no l
4j result in any significant alteration in our estimates, but : would O
g 5
have no objections to doing it.
1
- i I
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You would have no objections to doing it, but right now R
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you have no plans for doing it; correct?
I "j
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That's right.
d 2
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Is there any difference between your position and Dr.
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10 l Peck's position concerning the advisability of taking aIC'.cional i
z t
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m 8
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12 A
As far as I know, I don't believe there is a difference a
5 13 : as far as I know..
t i
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5 I4,
Q Co.you know what the standard review plan is?
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15 A
Yes.
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16 l Q
Generally, what is it?
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2 A
It's list of, check list of items which are recuired, a
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5 19 !
analysis report.
i 4
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1 Q
Does Bechtel use the standard review plan for any l
20 21
- purpose?
22 '
A I believe I recall that we used it in the proc 6; Tf 23 preparing the Midland FSAR.
i 24)1 Q
Co you use it to help pu determine what information to 1
25 13 provide.the NRC?
A h'
li ALDERSON REPORTING COMPANY. INC.
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I 200 2'
1I A
To the best of =y recollection, this has been done, i
2!
Q Do you eveh provide the NRC with information in the I
a 3 : absence of a request for that information from the NRC?
4l MR. FARNEI.I. :
Are you talking about the Midland project?
I 5
MR. PATON :
The Midland project.
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A I don't -- I can't recall exactly.
I believe that in t
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7 many cases, some of the responses to the question -- I'm talking i
i Mj 8! in =y area, went beyond the questions, somewhat beyond the d
i z,
9l question, in my area that I can recall, but I can't speak for the 2
i g
10 i rest.
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Your answer is that youcare speaking for ycurself only; s
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Yes, I want to make you aware that I am speaking from l
5 14 one area only in responding to the soil question.
I do recall i
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15 that we attempted, in every case, to respond to the question, and
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H complete the subject that was brought in.
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1 3
I8 Q
With respect to the soils issue, I'm not talking about I
g 19 ' this, litigation or these depositions, but with respect to the i
20 ; soils issue in your normal review process, have there been any i
4 21 change, have you received any different instructions on the i
22 amount of information you should provide to the NRC than you had i
23 3 prior to the soils issue?
a 24!
A Well, prior to the soils issue, we were preparing an i
j r
25,' FSAR, working on an FSAR, and that is a standard review plan for I
l l
d ALDERSON RE.mORTING COMP ANY. INC.
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I i
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01 4
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e 23 1 sthe FSAR.
In this particular matter, to the best of my knowledge, a
2 elwe are working with 50-54 F and I am not -- I am ' unde.- the system t
i i
3l where we respond to all of the questions and provide all of the i
i 1
4 l factual information.
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Q In the last four years, and I am excluding from my i
m" i
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7 with the deposition today, I'm excluding that, have you received j
i n
8i any instructions that bear on providing the NRC infornation?
I n
9' MR. FARNELL:
Witn respect to Midland?
I z.
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10 MR. PATON:
With respect to Midland.
l z
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A Sure, I have received instructions.
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Q Oan you tell us what the instructions were ?
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5 14 l A
I cannot possibly recall all of the instructions, but
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=
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N I7 various NRC questions and provide response for additional l
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=
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mformation that has been included in the 50-54 ? Volumes.
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Q All right, again, I'm not asking you about any instruc-n a
20 tionthatyoumaycemaynothavereceivedinconnectionwiththisl 21!
deposition.
Have you ever received an instruction in the last four 22 23 years with respect to Midland and with respect to the soils 1
24 l problem to refrain or to not provide certain information to the i
)
25 ( NRC?
q k
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- 1 ALDERSON REPORTING COMPANY. INC.
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I A
I have been instructed to respond to the questions 24 1
J s
i 2 ifully and to the best of my knowledge.
f 3i Q
And you have not received any change in that instruction,
4 with respect to the soils issue in the Midl.tnd case in the last I.
3 5 ! four years?
e N
j 6l A
Can I speak with my counsel?
R 2
7' Q
Surelv.
w 1
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8 (Discussion off the record) d i
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There has been a change, and that is the difference z'
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10 ' between working in an FSAR system and the 50-54 F system.
These r
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11 i are two different matters.
In my working with the FSAR, updating l 3
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12 FSAR constantiv is one matter, and the 50-54 F agreement that E
I 13, understand we are working on, that is a different =atter.
I a
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14 '
BY MR. pATON:
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15,
Q Okay, keeping the FSAR up to date calls for you to 2
i j
16 l volunteer information; is that correct?
t M
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Calls for you to comply with the standard review plan d
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18. and the section 1.70 step by step and to respond to every single I
19 l step on those.
n an l
20 l Q
And in responding to the 50-54 F requests, do you re-i 1
21l spend to the question -- you do not additionally volunteer any I l 9
22 l information; is that correct?
d l
23 A
I respond to the question in full, and we have, I 24 ;
believe, provided a factual data.
1 Q
In the 50-54 F process, do you feel that there is a 25 1
4 l
,1 ALDERSON REPORTING COMPANY. INC.
t
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203 l
25 1,,need to freely submit geotechnical information to the NRC in a manner similar to the manner in which you respond to the standard 2lI 3 I review plan?
4 A
I am not familiar with the rules of the 50-54 F myself.
i l
e 5, Maybe I'm not understanding the question.
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Q By 50-54 F, I'm just referring --
i 4
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Are you asking me to change the 50-54 F method of n
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MR. PATCN:
He understands very well.
l' z
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10 l BY MR. PATON-z i
=
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Q Dr. Afifi, I show you what I previously marked as NRC E
11 '
a f
12 I Deposition Exhibit 2.
It is a document dated August 3, 1979.
=
j 13 l The subject is Problem Alert, Incorrectly Placed Back Fill.
The i
=
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3 14 l document has a number on it, S3 301598 through SB 301600.
The
=
15 last page should probably be numbered 601.
Ihe last page I have
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16 has no number cn it, but it was substituted because the original s
y 17 ' last page could not be read.
Let me ask you to icok at that t
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18 ; docu=ent.
i 19 l You can look at it again, Doctor, but let me ask you, M
i 20 i have you ever seen this before?
i 21 A
I believe I saw either this one or something similar to k
22)it.
It's possible that it's *h4.s one because it has my initials i
23 on it.
24 j Q
Do you know wha' 4~
is?
.]
25 '
A Yes.
i i
ALDERSON REPORTING COMPANY INC.
i
1 204 i
l i
26 1:
O What is it?
)
2l A
It's a document that I understand is supposed to be i
I 3
sent to Bechtel to alert from recurrence of si*:llar problem as 4l what happened in Midland.
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O Is it an attempt on Bechtel's part to summari:e the 2
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6 problems that occurmed at Midland?
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I did not prepare the document.
I may have had some u
8l input into reviewing the initial draft of it.
I don't believe g
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9i the document is intended to sum =arize the problem at Midland, but !
t o
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10 my understand, the document is intended to provide the lessons as z
1
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a 12,
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Q You don't have any trouble applying the words, lessons
=
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. 5 13!' learned to the document, things that Bechtel doesn't wish to have
=
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m i happen again?
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15 l (Discussion off the record).
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(Record read) l i
I 17 2
MR. PATON:
I'll strike the question.
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18 i A
I believe I intended to state ?he Midland experience.
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3Y MR. PATCN:
6 P
20 'i i
Q All right, you did not view that as a summary of the i
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21 i i
L problems that were encountered at the Midland site?
3 22 A
I don't believe it is.
23 '
1 Q
But you do think it is a check list of items that j
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24 ;. Sechtel doesn't want to have receated at other site 0?
,1 1,
25 1 i
i MR. FARNELL:
Oon't answer.
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ALDERSON REPORTING COMPANY. INC.
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t (Discussion off the record) 27 1 5 l
4 2l BY MR. PATON:
3i O
Dr. Afifi, is it correct that after the settlement i
)
4 ' croblem was discovered, Bechtel took a series of borings and i
5 ! conducted laboratory te'sts which included consolidation testing?
e i
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A Are you referrine. to the Diesel Generator Building 3a
=n a
g 5
7 problem?
i f
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Yes.
l c
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Yes, sir.
c I
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10 l Q
With settlement computations and predictions made based !
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11 I en those laboratory test results?
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3 4
1 i
5-12 -
A I don't recall that anv were made.
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Q Do you know why thev. were not made?
I
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5 I4 '
A I believe I responded to that question yesterday once.
1 i
2 E
15 l Q
You gave a lot of answers yesterday, and I'm not sure
.=
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16 ' I can sort out what answer you're referring to.
s I
N 37 '
A The very initial intant of the test was to diagnose the e
i, 1
E 18 i problem and cerhaps if it was possible, to predict settlement and i
i 19 '
m s
1 be able to get reasonable settlements without any remedial action.
5 i
i 20 ] That would b 3 cne action to take.
That was the immediate thought 21 ' that was, I believe, that occurred to me is to investigate and see; I
4 22 the quality of the fill as it exists, but it became apparent that I 23 a fix is required, and the full surcharge method provided a 24 superior method for consolidating the fill, the. land fill together;.
s i
25 j For that reason, this data lost its meaning, in my opinion.
l ALDERSON REPORTING COMPANY. INC.
i 1
I 206 s
i I
s 4
28 15 Q
Can you answer e.y question, yes or no, "ere settlement i
2 l ccmputations and predictions made bas ed en these laboratory test j
3 lresults?
i i
4.
MR. FARNELL:
I think he answered.
i 1
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5; A
I thought I said, I don't know.
W l
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6,;
BY MR. PATON:
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You don't remember?
l t
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8l A
I don't' remember.
l d
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9I Q
You said it became apparent that a fix was required.
{
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i 10 i Almost immediately it became apparent that a fix was required?
l z
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A Almost immediately?
I didn't use the words, al= cst 3
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12 ! i=1 ;ciately.
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You said that there was an 1::itial --
=
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I4 f A
In initial reaction was to take the berings and take the
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.5 4 regular types of tests everybody goes cut and runs on site where
=
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16, scil conditions are unknown.
Later, our thought developed rather a
i 17 N
racidiv into the surcharge program and there was no reason not to !
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=
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18 l proceed with the tests.
r 8
i 3
I9 (
Q Ycu went out and tock a series of borings and you
=
20li conducted laboratory tests, but then you stopped just short.
You i l
2I h stepped short of making the computations; is that correct?
4 a
1 22j MR. FARNELL:
I don't think he took the tests to make e
3 i
23 j eenselidation, to make settlement with.
i 2#
A Not necessarily.
y1 BY MR. PATON:
J i
4 i
i ALDERSON REPORTING COMPANY, INC.
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1 207 1l*
O Well, tell me the purpose of taking the series of 2
borings that you took?
3, A
It was to evaluate the conditions of the fill.
4 Q
And you conducted laboratory tests?
s 5
A Yes.
e" 1
2 6{
Q And those included consolidation tests?
o i
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7 A
They did.
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Q How much ef foru would have required -- strike that.
d I
9l Dr. Afifi, do you know who within Bechtel would know I:'j to ; whether or not any settlement computations and predictions were l
i i
II made based on the laboratorv tests?
3 12 '
E_
A I can check for ou.
It would not be a croblem.
Cver- !
o e
I 13 i 5
5 nicht I can check it out.
t t
I4 '
Q Would you be willing, with the consent of your lawyer,
[
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15 l to provide that information tomorr w if he agrees to it?
j i
f 16 7 11 check and see.
i 2
17 '
MR. FARNELL:
If you can check, fine.
=
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3Y MR. PATON:
i 19 i i
i
.O If these computations had been made, where wculd they n
v i
20i be located?
l 21 :
A They would be in our computations files.
1 i
3 I
22 4e Q
How long would it take a person who is qualified to f'
i 23 makesettlementcomputationsandpredictions,to.havemadesettle-j 24 3d ment computations and predictions having in his possession the f
4 I
25lt results of the laboratory tests?
l 1,
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ALDERSON REPORTING COMPANY, INC.
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l 208 l
1 i
I!
MR. FARNELL:
Is this in relation to a specific 2l building or plan?
l, 3i MR. PATON:
The Diesel Generator Building.
i 44 MR. FARNELL:
What laboratory tests are we talking about?
5l MR. PATON:
The lab tests you just referred to.
g R
j 6
A The process includes evaluating the data very closely R
t i
7, and selecting the parameters and conducting the tests.
It's not i
l i
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8l n
a lot of work.
t i
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10 0
Would it take less than a day?
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A Not in the case of the Diesel Generator Building.
It j
4 s
i a
t f
12 l would take less than a day in another si:uation, but not in the
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case of the Oiesel Generator Building.
5 34 '
2 In order for me to come up with something reasonable, I e
[
I*fhavetoputsomebodyfortwoweeks,lookatitverycarefully, j
=
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17 l
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M where he samples were taken and be careful about doing it.
It's t:
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w i
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So your estimate today is that to make the settlement n
i 20l computations and predictions with respect to the Diesel Generator i i
i I
2I [ Building, would have take n approximately two weeks?
22 ;
A A careful evaluation.
A crude evaluation would take 1
23 i
4 less than a day.
I 24 Q
Oid you learn anything from the laboratory test results 1
25 that indicated to you, that gave you any reason that you should 3
j
. l 4
d ALDERSON REPORTING COMPANY. INC.
I l
209 i
t 4
i 1 ? not make the settlement computations?
i 2{
MR. FARNELL:
I think he said he didn't recall whether i
3 j
they made them or not.
4f MR. PATCN:
Okay, that's not the answer to my question. I i
1-t.
5; MR. FARNELL:
Would you read that back, pisase.
i e
R j
6 ';
(Record read)
R 2
7!
A I don't believe so.
I 8j c
A l
3Y MR. PATON:
l t
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i 9l Q
Oo you know who -- if a decision was made not to make z
10 lj settlement ecmputations and predictions, is that within the scope o
i 5
l
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11j of your respeensibility at that time?
I n
I 5-I2 I A
Yes.
1 j
13 !
O Is that the type of thing that you would have discussed }
=
1 x
.g 14 l with anybody higher than you in the organization, or is that a i
=
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1
=
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I6 l A
I would say it's a decision that I would make.
I 17 '
y Q
Is there, as opposed to the careful analysis you j
=
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18 '
3 described, is there a crude estimate of settlement computations i
"g 19 '!
that.could be made in approximately a half a day?
l 20 !
MR. FARNELL:
- believe he said less than a day -- okav.
i i
21 1 I
BY MR. PATON :
i 22I' Q
s there such a thing?
l k
i 23 '
A I need to Pecw what settlement computations you are i
t i
24 { talking about now.
I J
l 25.j Q
An estimate of the settlement at he Diesel Generator k
3 3
ALDERSON REPORTING COMPANY. INC.
I
~
I 210 1 ' Building would have under the surcharge?
1 l
2i A
That would be --
that can be made crudely and one would, d
1 3$ be able to arrange, a rather crude range.
P i
4i Q
Do you know whether any crude estimate was made?
f g
5 A
I recall that by comparing the lab data, a range, the I
n j
6 range and the actual complicibility range, you would back figure m
t s
a 7i from the tests from the full scale measurement, that the number i
I j
8l would be, it would be higher, could be higher, but that accounts d
9l for the fact that most, a lot of the samples were on the soft side ~,
z h
10 !
so that makes me return again to the connection about the careful z_
=
i g
11 analysis of the data that would be required in case one wants to a
i i
12 l make an estimate to verv. carefully look at it.
It's not a big
-=
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problem.
1 x
5 14 <'
Q Okay, I'm not sure I understand your answer to my
+
=
2 15 l cuestion about the crude estimate.
\\
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j j 16 l Was a crude estimate made?
j m
17 !
A There is a crude estimate made of the range of the x
5 I
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18 !
complicibility parameters.
I cannot recite 1: fer you at the 2 moment, but I can get it for you.
l' s
19 5
a 20l 0
All right, would you do that?
i I
21l A
Yes.
t, 22 '
Q Was the crude estimate you just referred to of a 23 :} compressibility index?
s 24j A
Yes, sir.
i 25)
Q Did vou make any crude estimate of settlement?
i I
f' h
ALDERSON REPORTING COMPANY. INC.
i t
.v. 3 i
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L 1 4 A
No, I stated before, I don't recall if that was done or '
i l
2; not.
l 3
MR. FARNELL:
Cff the record.
I i
4i (Discussion of f the record) 4 l
5l MR. PATON:
The request for the ccmpressibility index, i
3 e
i n
j j
6 we do not need it overnight.
- f you are willing to give it to 1
"2 7 l us, wculd v.ou just indicate seme reasonable time that vcu can i
i M
j 3
8' succiv it to us?
n J
t I
t 9!
MR. FARNELL:
We'll provide it within two weeks.
i:h 10 I BY MR. PATCN:
E=
E 11 i Q
Were six borings made near the Diesel Generator Building i
3
'y 12 l after remeval of the surcharge for shear wave -relocity measurements-
=
g 13 '
A Can you explain what ycu mean by, near?
=
2 l
i 5
14 (Discussion off the record)
_t 2
15 i BY MR. PATON:
l 5
i j
16 Q
All right, let me amend the question, s
I y
17 Were six borings made -- Dr. Afifi, I read to you f cm e
i C
I a
18.
l ge 1 of Censumers'Pcwer Exhibit No.
3, Heller Deposition, i
=a
=
19,
October 9, 1980.
g 5
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20 <
"After removal of the surcharge, six additional borings 21f were made to ccnduct in-situ shear wave velocity measurements,'
- I
'lI 22 h and I hand you that document if you want to read that statement.
s I
23l A
Yes.
lH 24 0
Is that a true statement?
l 25j A
Yes, sir.
?
4 3
ALDERSON REPORTING COMPANY. INC.
1
212 I
i 1 h Q
Did you cempare the blew counts obtained from berings f
i 1
2l before and af ter surcharging the Diesel Generator Building?
i 3l MR. FARNELL:
Would you read that back?
4 l;.
(Record Raad.)
l
~
g MR. PATON:
Off the record.
4 l
j 6j (Discussion off the record)
R 7<
BY MR. PATCN:
I N
I j
8l Q
Let me read it again.
Did you compare the bicw counts dn 9
obtained from borings before and after surcharging the Diesel z,
g 10 '
Generator Building?
z=
11 !
A Yes, sir.
E t
j 12 ;
O Do you knew if that comparison has been p Ovided to the
=
i g
13 NRC?
=
14 !
A No.
i j
15 Q
Do you plan to provide that information to the NRC?
i 3
l I
16j gg, yAang;L:
You asked him, did he know, and he said, j
i d
17 <
no, he didn't knew.
a=
18 MR. PATON:
I asked him, has he provided it, and I guess i
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he said he didn't know.
New I asked him, does he plan to provide' M
20 1 4
21h MR. FARNELL:
It already =sy be provided, he doesn't l
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know.
23 MR. PATON:
Okay, if he's already provided it, maybe he 24 ! doesn't plan to provide it.
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25 i MR. FARNELL:
Can you ask the question again?
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ALDERSON REPORTING COMPANY. INC.
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3Y MR. PATON:
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To repeat my question, I have to back up ancther 3
question.
I ask you, did you compare the bicw counts obtained j
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A Yes, sir.
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Have you provided that information to the NRC?
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A I have not.
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Oc you plan to provide that information to the NRC?,
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I have no immediate plans for that.
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Do you consider that information to be significant?
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To what?
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I'm asking him.
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It's too general.
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I don't believe the information is very significant.
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MR. PATON:
Mr. Tarnell, would you be willing to have
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23 Mr. Afifi provide us the information he has just described on the 24 comparisen of blew counts obtained frem borings before and after 25 the surcharce?
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MR. FARNELL:
We'll provide you with that c0= arisen f
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Well, I think, rather than, you knew, i
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We'll work on it now, but I want something z
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Well, let's do it right now.
I don't want !
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If you want a list, put it on the record t_
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All richt.
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Number 1 is the matter we have just dis-i e
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want me to state what that is?
21,
MR. FARNELL:
Yes.
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All right, blow count ecmparison.
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23 second is, index of construct _en and design drawings.
Certainly, '
a 24 #l if I have not
- escribed it accurately, as far as you're cencerned,:
25 please correct the record.
ALDERSON REPORTING COMPANY. INC.
I 215
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i 1f (Discussion off the record) l 2 I MR. PATON:
The Staff has requested that Censumers and/ l l
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Then Mr. Farnell will respond, i
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with their reply to our request.
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7 f cm borings before and after surcharging the Diesel Generater t
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9l (Discussion off the record) l
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MR. PATON:
The second item is an index of construction E
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The fourth item is to advise us whether settlement
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The last item is a list of
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18 MR. FARNELL:
With respect to item four, we understand i
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this.to be, to relate to the Diesel Generator Building and prior n
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4 2I We'll provide the information set forth by Mr. Paton in 22 I items one through five to the extent that it exists and is dis-i 23 coverable.
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Off the record.
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l 25I (Discussion off the record) i i
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11 MR. FARNELL:
We will either provide you with the a
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3 weeks.
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BY MR. PATCN:
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With respect to the six borings that we have been nN i
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A I believe they were intermittent.
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If they were -- all right.
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I don't recall the spacing.
These borings have been a
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Logs of these borings have been provided to l
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O Considering the use of intermittent standard penetration a
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Would you read that back, please.
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The question is compound.
It deals with 20 either soil shear strength or compressibility characteristics, onei a
2I ' or the other.
I 22 MR. PATCN:
All right, I'll take then
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o oc you want =e to read the question again?
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A Yes.
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Q Considering that the standard penetration tests were j
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By, from all of the borings, do you mean all six borings?
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!s the data gathered from those six borings sufficient l
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What was their purpose?
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To determine shear wave velocitv.
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Do you know the shear strength and compressibility l
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Again, one at a time.
Shear strength and d
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De vou knew the shear strength characteristics of the l
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24 l elant fill under the Diesel Generator Building since the surcharge l 4 -
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A Yes.
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What are they?
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A We predicted the friction angle te he 29 degrees and j
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Did the shear strength used in bearing capacity analysis i
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Yes, sir.
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Would you read that back, please.
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Acceptable in what regard, to whcm, for
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BY MR. PATON:
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Is it acceptable to use shear strength from as far away a
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. as the bore rated water tank in bearing capaci5y analysis?
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MR. FARNELL:
I have the same --
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For the purpose of making your bearing capacity analysisj I
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MR. FARNELL:
I have the same questions, for what, to 22 f whom, for what purpose?
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MR. PATON:
Acceptable for the purpose of making a 1
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I don't understand it.
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ALDERSON REPORTING COMPANY, INC.
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A on the basis that the soil material has been used and the:
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clay fill is the same and that is the eccling pond area and that l'
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those found under the Diesel Generator Building and the fact that i
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BY MR. pATCN:
Dr. Afifi, I show you a document entitled, d
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9l a one-page document entitled, Trip Report.
It has at the top, 10 Midland Units 1 and 2, Job 7220-001, dates January 30 to March 24, z
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I direct your x
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I don't recall exactly what is meant by, as built l
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j ALDERSON REPORTING COMPANY. INC.
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Q The sentence also refers to, daily reports.
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remember whether you received daily reports as indicated in this
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letter?
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Normally on this type of assignment, people prepare i
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reports and whatever data they collect, and they are filed in the n
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6 ;i Gectechnical Files.
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Is your statement that that is not the type of informa-A
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Yes, I may have received it and I gave it to sc=eone a
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If this information:
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MR. PATON:
Mr. Farnell, there's a reference here to a=
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I'd like to recuest I
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I'm specifically referring to the hering
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f d to in Staff Exhibit 6.
19 l ogs re erre "g
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May I make a -ccmment?
n 20 MR. PATIN:
Yes.
2I !l A
In response to the September 15 report, specifically o
l 22 3 refers to the boring logs, and I have already indicated that the i
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SY MR. PATON:
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Approximately when do you think those logs will be f
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provided?
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I do not know the schedule for submitting this upcoming 3
amendment.
4-MR. PATCN:
Based on that information provided by Dr.
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MR. FARNELL:
I accept vour recuest.
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Dr. Afifi, with reference to staff Exhibit 6, do ycu know:
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Ch 10 the level of the cooling pond?
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To the best of =v recollection, that was before the 3
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A Well, there would be no water in the nume.
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Not at all?
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A No, but I can check.
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Do you have any concern for future hydrolic fracturing 4
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Read that back.
t 22k (Record readsi a
4 23 MR. FAP"%jL:
Are you talking about the past pie::ometer j 24 l drillings that w tre tc.a0?
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The answstr, yes.
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ALDERSON REPORTIP4(i COMP ANY, INC.
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I don't know, sir.
2f Q
Am I correct that you do no: consider that in your area. l l
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A Yes.
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MR. PATON:
Off the record.
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6]j (Discussion off the record) s R
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Okay, that's the end of today's deposition.
n i
j 8l (Whereupon, at 5:00 p.m.,
the taking of the depositien U
z, 9fadjourneduntilFriday, October 31, 1980 at 9:00 a.m.)
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