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 n ,
CONSUMERS POWER COMPA'iY (Mid'*-d o' ant, Unit 1 and 2)
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7
." Bechtel Asscciates, P.C.
c= 777 East Eisenhower Parkwav g -
5 Ann Arbor, Michigan 9
- z. Thursday, October 30, 1930
. =
10 i E j Depcsition of
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< SHER!? EL-SAYED AHMED AFIFI, 3
12 "E
the deconent, called for examination by the staff of the r 13 i E
l Nuclear Regulatory Cc=mision, pursuant to notice, at ?:15 a.m.,
3 14 '
2_ when were present on behalf of the res=.ective .carties:
' I b j ror the Nuclear Reculatcry Ccemissicn.. ;
- 4 i
i ii[ l WILL'.AM D. PATCN a
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i a OARL HOCD n i 20 !
.' : RONALD ERICKSON, Army Corps of Engineers 21 il JAMES W. SIMPSON, Ar=y Ccrps of Engineers i 1 !
22 l. . HAP ~ N. SINGH, Army Corps of Engineers '
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h ALDERSON REPORTING COMPANY. INC. l
_i 125 1, on behalf of Censur.ers Power:
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2 j SEAM, LINCOL:7 & BEALE 8
1 First National Plaza 3l Chicago, Illinois 60603 Sy: ALAN S. FARNEL*, ESQ.
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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, e
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2 6 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
- J l 9 follows:
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- 1 5 10 ' MR. PATCN: Would vou start, Dr. Afifi?
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II 5 A Sherif 1.1-Sayed Ahmed Afifi, and I am with Bechtel.
m "E 12 MR. FARNELL: Alan Farnell, and I am representing
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2 14 l MR. 3RUmiER: James Brunner with Consumers Power.
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MR. SIMPSON: James W. Simpson, Army Corps of Engineers, 16 a[ North Central Division.
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- 17 g MR. KANE: Joseph Kane, U. S. Nuclear Regulatory
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Commission. !
2 I9 i MR. ?ATCN: William Paton, attorney for the NRC staff.
E i 20f 3 MR. JCFES: 3radley Jones, attorney for the NRC staff.
2I MR. SINGH: Hari N. Singh, U. S. Ar=v j Corts of i
A1 Engineers a Detroit.
i 23 ' MR. ERICRSCN: Ronald Erickson, U. S. Army Corps of !
24 )gngg3 ,,73, i
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4 25l. MR. PATON: Darl Hood, D-a-r-1, H-o-o-d, is with us, !
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1 but he stepped outside for a minute.
f 2 EXAMINATION 3 3Y MR. PATCN:
1 4! I Q Dr. Afifi, do you understand that ycu are snill under g 5 cath?
n M d g 6 I, A Yes, I do.
g 2 7 MR. FAR'EII : Bill, before we start, Sherif has M
j 8 something he'd like to say.
"J 0 9l ; A Yesterday you recuested the name of the censultant z, i O
y 10 ! that replaced -- is to replace Chuck Gould on the underpining z i
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11 ,l i =atter for the Auxilliary Building, and here is the name of the a
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d I'll give you the piece of paper and I'll read it for i i j 13 ' the record. It's Johnson and Desmond Censulting Engineers. The l
23 i t E 14 ! name of the two persons who are involved are Jim Gould and
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= i g 15 ' Ed Burke.
t y 16 sy gg, pA ::h .
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.. I, E 1/ ' Dr. Afifi, are you able to distinguish what const nction:
Q a
a E 18 ! activities were performed by Canonie as oppcsed to the construction
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g 19 l; activities performed by 3echtel? l i
a i 20l v.R . FARNE'I.: Are ycu talking just soils?
. I 21 MR. PATON: Tet's start there. .
I 22 !, A Not exactly. l l 4
- . 23l 1 SY MR. PATON
24 Q What do you knew abcut it? !
1 j 25 i ,
A I know that, I understand that Cancnie did the entire :
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123 s
I 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'.
I 4' 6 has done.
i That would be construction, construction would be able i
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n i to answer that, M i 3 : Who in Construction wculd know that answer?
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6 '3 Q
" 7 A I believe it would be A. Scos. That's the person that N
i M 8 3 I would refer you to. I'm not sure he'd have the detailed d !
9 z-information, but he's the one.
10 0
z - Q Oc vcu know the name of the organi:stion he is with,
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11 'i I mean what section, group, branch?
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A My understanding, at the time, Mr. Scos was with the
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= 3echtel Pcwer Corporation at the Midland Construction jcb site.
2 14 l .
E ! Q He's with .3echteh at the site?
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- 15 !
h ! A At the site.
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- Q He's in sc=ething you call Construction?
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i A Yes, right, the Construction group.
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- i Q Construction group; is that what you call it? l i
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n ! A It's what I call it, yes. He is with Sechtel 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. j j 25 '
a Q That, I understand, but I want to knew what section, i
ALDERSON REPORTING COMPANY. INC. l
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I 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?
. e 5 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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R 7 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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= 9' A I don't know.
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@ 10 0 Who would know that?
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E 11 ll A That would be either Sechtel Construction or Sechtel 8 I z 12 ! Engineering. T referred you to A. Boos, as far as the Con-4
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- 13 l struction.
, The engineering department would be another source for
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w 15 j Q Who might knew that in Engineering?
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j 16 i A I would have to refer you to the Project Engineer at a !
p '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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. I 19 . O Dr. Adifi, do you have any responsibility to knew what 3 i .
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is going on during plant fill operations at the site? l i
21 '
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MR . '."ARNELL : What time are you talking abcut?
22 ; MR. PATCN: During plant fill operations.
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23 ' MR. FARNELL: Plant fill cperations were going on for a !
24 ' long time.
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i 25 MR. PATCN: That's fine. i 4 i
- l ALDERSON REPORTING COMPANY, INC. !
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l I 11 3Y MR. PATON:
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2! 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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n I j 6 Q During plant fill operations.
. n E 7 ;i, A You mean at the time the plant fill was originally N i i
n 8 claced?
1 l 3
- 9 Q 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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a 15 MR. PATON: If the witness does not know when plant I
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g 16 fill operations were going on, that's his business.
A y 17 3Y MR. ?ATON:
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= i 5 18 ; -Q Do you know when plant fill operations were going on?
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$ 19 l -
A ! wouldn't know exactly when it was going on, but ! can l M l 20l tell you.that after the discovery of the Diesel Generator
! 1 21 !i Building problem, sometime after that, the Geotechnical group l 3
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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I 25}j Q After the discovery of the settlement problem at the I. !
1 1
3 ALDERSON REPORTING COMPANY. INC. l
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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 s e 5 assigned as a coordinator, and his responsibility was to provide R i j 6I engineering guidance to the ensite Geotechnical soil engineer.
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$ 7 Q Did Mr. Wan:ek report to you, activities at the site?
A j 8 A Mr. Wan ek reported to me activities as he felt necessary, d
d 9 v. e s .
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$ 10 l Q After the discovery of the problem at the Diesel z I
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'n 11 Generator Building, approximately how often would you visit the g 12 site yourself, approximately? ;
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_E 13 ' A I have . visited the site e.robably two or three times a
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3 14 year except for meetings that I had to go to with NRC. Thau's b
i 2
3 15 about the ac.c. roximatelv the number of times I have been at the
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j 16 site, I
i 17 l Q Do you consider that the frecuency of your visits to a
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" l w 18 the site have been sufficient for v.ou to carry. out v.our i
= i g 19 j professional responsibilities with respect to the Midland Project?
n ;
20 : 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 I 22 l i Q You say he was supposed to be watching? l 23 ' A He is watching these activities for me.
24 l 0 So that the information you obtained from Mr. Wan ek, you l
25 9believe is sufficient for your knowledge of activities at the
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ALDERSON REPORTING COMP ANY. INC. l
132 9
I sitetoenableyoutocarrycutyourprofessionalresponsibiliciesf 2l A Yes.
3 1
i Q You don't feel that your work suffers any by your 4
isclation from the site? l g
5l! MR. FARNELL: He didn't say he was isolated from the l
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- I g 6 site. That question was e.gked and answered, and I don't want n
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." you to argue with the witness.
M k 3Y MR. PATCN:
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9! Q Can you answer the question?
5 10 r i MR. FARNELL: He didn't say he was isolated.
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< MR. ?ATCN: Are you instructing him not to answer?
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= 1 13 i g . A I believe that Mr..Wa=mk sufficiently qualified to eversee 14 I E
I the work and if any need for further involvement en my part, I
= i 0 15 !
2
= l would have undertaken that involvement.
E 16 !
- i BY MR. PATON:
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J 17 '
3 0 Oc you knew whether Canonie placed the plant fill 1
= I E 18 i
= ; initially under the Diesel Generator Building? i
- " i 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? I i l 25]s A Yes, I have heard seme other part was placed by semecne j d
l ALDERSON REPORTING COMPANY, INC.
1 1
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133 10 1 else.
2 C 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 a 6l stated about the division of work between 3echtel and Cancnie with n
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7 res=.ect to clann fill as to who did what?
n j 8, A I don't recall anything other than what I told you
- .5
= 9 already.
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@ 10 i C All right. Dr. Afifi, I'd like to shew you a document z i
- i j 11 j that has been covered with three attached pages. On the cover, 3 i d 12 } it's dated August 3rd, 1979. It's frem T. E. Johnson of Civil / i E - !. I
= Structural -- and there may be another werd thr.t fo11cws that, but!
13 l,
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14 l it.'s covered over, at the Ann Arbor Office. It's to --
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l' ca 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 ,
= l 5 18 l seen it. ;
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Why don't I mark that NRC Deposition Exhibit 2, 10-30-30 I 20l (Afifi) .
I 21 ! A I couldn't read all of the last page. The copies are ,
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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 i
i 25 )' now.
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3 ALDERSON REPORTING COMPANY. INC. '
134 11.
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. 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
Deposition.
i i
We produced those documents Monday =crning at 4 i 1
approximately 11:30.
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$ I 3Y MR. PATON:
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g n O Dr. Afifi, do you know whether data and drawings cen-2- 7i t
cerning separation of Canonie's work from 3echtel work by E 8' n i d- Construction were ever forwarded to Gectechnical Services for c 9 z- review?
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- 10 E A
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i I recall scmetime that an attempt was =ade to do that, E
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! but I don't -- I am nct fully -- ! can't ecmeletely re= ember if it d 12 i z . was ever ccmpletely done.
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i If it was forwarded to Gectechnical Services to whc
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would it have been forwarded?
7 15 A
g ! believe the person that would know = cst about it would,
! 16 !
- i be Mr. Wanzek.
= '
- 17 i
3
= ! (Discussien off the record.)
G 18 '
i BY MR..PATDN:
2 19 l n ',
- Q Dr. Afifi, I want to hand you a dccument which is 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.
i, It has 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 243 gecrporation. It's from Karl Wiedner, W-i-e-d-n-e-r of Engineering 4
25 1 a
uit Ann Arbor. It is addressed to Distribution. There are seven i
[ ALDERSOt J REPORTING COMPANY. INC. i
V 135 I
2 1 names, the first one is, copies to P. Secnel, 3-e-e-n-e-1, with I
i 2 I attachme=" *ke subject is Midland Diesel Genera:Or Task Group I
3 Meeting Notes, .
j 4 I turn to the second piece of paper which is numbered l j
b
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5 S3 801725 and ask you te read the two sentences at the bottom of I I
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j 6 the page beginning "This item enclosed," and follows another R
R. 7 sentence.
9 N
j 8 ' dave you read the two sentences , Dr. Afif_?
d !
y 9l A Yes, I have read them.
z.
@ 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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13 ' "The data and drawings concerning separation of
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I Canonie's work frc Bechtel work by Ocnstruction have been for- i C
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a i warded to Geotechnical Services for review." '
= !
3 16 i i Does -veur reading these two sentences refresh -vcur
- l d 17 l reccliection en whether the data and drawings referred to were, in ,
x '
= I i
5 18 ii f :ct, ever sent to Gecrechnical Servicer? ! .
- I i
3.
n 19 l A Cnly that I recollect that the attempt was =ade , and l l 20 l I'm not sure if such drawings were actually produced and sent, but .!
I i i i
21 I i
this says that they were sent, so as I say, the person who would i i
i t
22 ' be mest familiar with these is Mr. Wan. It's not incencei.vable i
, 1
=
23 I that they had been forwarded and may be available semeplace. !
1 ,
24 j Q If they were available, would they be with Mr. Wan=ek l
l 25 jer under his control?
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1 '
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3' ALDERSON REPORTING COMPANY. INC. i
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j! A: would believe that they would be in the drawing files.
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2' O Where are the drawing files 1ccated? .!
j i
3j A The Geotechnical Group Files, the Central Files, if
- I I I 4 they exist, such drawings exist. i
. i.
. e 5 0 Who has custod.y of these files?
e O
3
- 6} A The custody of the Central Files is under the nanager. L i
. n' R 7 Q Who is that?
N 3
n 8! A S. L. Blue. These files are department files.
i d i t 9i S. PATON: Are you willing to le z-t us look at those n
F .
10 files?
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< 11 MR. FA?2 ELL: Well, I think you have put it in -- we'll 5
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entertain any request but I think we 'd like it in writing and in
- 13 ;j an apprcpriate manner.
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a 14 ' MR. PATON: You are not willing to let us lock a: these w
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- 15 ' -
files without an a-rropriate e written request? I E_ ,
3 T 16 <
,MR. FAIELL: Right.
= !
R 17 MR. PATON:
z i Is that a change in the apercach to disccverv.,
= i e 18 l that we have discussed? I
= i i
- ! I 2 19 ! MR. FAP2 ELL:
5 n
- I thcught that both sides would give a 20 ! formal t document production request that differentiated from the
,I 21 ! request 4
to produce that accc=panied each depcsition notice.
i 22 '; Are you talking about looking at these today, or in the i.
23 1.near future? !
1 1 '
MR. SRC;ER: Do you know which document you want to see?
24l 4 25 If vou'd clace a request for seecific drawings, we'll attempt to 4
1 t
i
, I I, l ALDERSON REPORTING COMPANY. INC. 1
s-l !
137
' I I
14 locate them for you.
4 i,
i !
i 2 MR. PATCN:
Would you be willing to provide us :cday i
3 with an i'dex n to design and construction drawings related te i j
4l Leil structure foundations, to soils and structure foundations?
e 5<
(Discussion off the record.) i a 6 !G . FA?0iELL: At lunch time we'll attempt to ask the
. n R 7 apprcpriate people if there is such an index, and if thers is, 3
a 8i !
i I'll locate it and provide it to you, d i
= 9 MR. PATCN:
i We would like to accept the effer, and to 10 z~
ask that one of the Corps of Engineers, one or two of the Corps l l
i 11 of Engineer people with us to lock at the specific data and m
d
= 12 '1 drawidgs referred to in this paragraph. i 8
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- 13 i MR. 1ARNELL:
= I don't know if we can get that for *vou E 14 i l w
e in two seconds or I den't know if we can get it for ycu today.
~
I 5 15 : '4R . PATCN:
2
=
! Will you see, and if it is available, he can a
.- 16 -- you have that request under advisement, er are you censidering
= ;
p 17 !that last request?
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= 1 g 13 MR. 3RC;NER: l
=
l I don't -- I must have lost ':he page you 're {
. 19 : referring to. i I
- R 2, MR. PATCN: The two sentence,. carac.rach at the bottom of i
21 the second piece of pape-i t
22 MR. BRCRTER:
i The record should reflect that the re- i i
i 23 quested drawings, the data and drawings concerning separation of i ll i
24 i Canancnie's work frc= 3echtel work by construction ' and their i 4 j 25 i identified en document dated August ist, 1979 entitled Meeting - 1 J
l
. ALDERSON REPORTING COMPANY. INC. i I
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! 138 l
se -
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11 Notes Number 1018, Midland P7. ant, " nits 1 and 2.
I 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 i MR. PATON: It seems to me they referred to some V
R l 6,
g ,
specific draw!.ngs. We're asking you to see if that is true, and
. R-M 7 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
}; 10 clear who is in possession of the drawings.
z-Il i
t MR. PATON: Okay, we're just asking you to =ake an i
- y 12 atta=pt. If you can't do it, you can't do it.
= t 4 I l ',
5
, = (Discussion off the record.)
. m i I4 3Y MR. PATON: k
=
t j-15 l '
C : 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 a , richt hand corner, SB 30233 and continues to a document with the x
m i ;
m 18 :
. - numbers 53 800238 dated September 13, 1974. It apesars to be !
,- 3 I n 19 lfrom S. Afifi, but there are lines drawn through S. Afifi, and it'sj 20! to R. L. Castleberry. The subject, Plant Area Fill, and-there are t l
. . I 4 !
21 ! copies to five people and copies to 1320 and 3410, which I don't I
i 3 22 ! know what that means.
I !
23 I hand you that document and ask you if you have ever f 24 iseen'that before?
4 i
25 : MR. FARNELL: Do you want him to read the whole thing? !
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?
I I
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l l
- 9. o, 1 MR. PATON: Off the record. !
2l (Discussion off the record.)
I 3 MR. FARNELL: He has seen the document.
i 4 3Y MR. PATCN: .
. g 5I Q Do ycu recall yesterday that we had a discussion, sc=e j n ,
N j 6 questions and answers cencerning ce=paction criteria? :
A 7 A Yes, sir.
n j j 8 Q And do you recall there came a time in 1974 when you 3
= '
9 said you ad'rised people, you advised sc=ecne what you thcught I,
@ 10 was the correct ec=paction criteria? '
z l
= 1 i j 11 A Yes, sir.
8 l i
$ 11 1 Q Is NRC Staff Deposition Exhibit Number 3 the document {
=
i i I
j 13 ! in which you advised Others what you thought was the ccrrect I
= 1 m t 5 14 ! ce=paction criteria? i W I l
= .
t 2 15l A Yes, sir. I w
= l !
g 16 Q And I direct your attention to a sentence, the second j d i !
$ 17 to last sentence in this document -- excuse me, the second to las:
l f, j
18 ) paragraph which appears en Page SB 300235. I'll read it and then :
4 I
8 :
g 19 l :'11, hand it to you. j n .
I 20 l "This infer =ation will allow a complete evaluation of 2Il I any in-place "il' 'cr its preposed function in addition to pre- '
22 i viding information which will be needed for the FSAR. It should l i
j, i
23 ' also clear up any questions as to how fill should be placed in 24 ', the future." I 25 i Do you agree that that's what that second to last 1
.1 .
3 i ALDERSON REPORTING COMPANY. INC. ,
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- q. 1 paragraph says?
2 MR. FARNILL: You're asking him if he read it 1' l 3 correctly? l 4 MR. PATON: Yes.
g 5 A I believe you read the paragraph cor ect, yes.
E i 3
e 6l 3Y MR. PATON: ,
a n n Q Let me ask you this, based on all of the knowledge you 7l j I 8, have today, is it your opinion that this docc=ent cleared up any d j l ; 9i question as to how fill should be placed in the future?
l
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a 10 ! '
MR. FARNILL: Would you read that back?
E E
11 (Record read.)
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12 , MR. FARNILL: The document speaks of any questions and
~
13 i you said question. .
=
x g 14 ,; MR. PATON: Your exception is to the fact that --
=
j 15 ) MR. FARNILL: I'm saying that I thought you were trying
=
g 16 ! to read off that document and you didn't have it phrased right.
= 1 y 17 MR. PATON: I said question instead of questions; is a
= l 5 18 . that the problem? ,
i t'
C 19 ' MR. FARNILL: Yes.
5 n ,
1 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 l 24 l Memorandum cleared up any questions as to how fill should be j i l 25 1 placed in the center? I 4
2 E
a ALDERSON REPORTING COMPANY. INC. l l
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1' I la 141 l 1
j 1I A Can you just explain it a little =cre, what the 2 question is, please?
i 3l 0 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 6
. I A : believe they are my words. The meme is signed by me.
M
$ 7I Q What does that mean?
. I i
j 8 A okay, I believe the intent of the sentence is that it
- d i z
, 9! sets forth the percent compaction that should be used for fill
@ 10 ' supporting structure. That's the intant of the sentence in my, z
=
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'll =y -- the best of =y recollection.
j 12 i Q What does it =ean when it says, "It should also clear i
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- 1, j 13 l up any questions"?
= :
a g 14 i A The question at the time was, should it be 1557 j
15'l Method D, and that is referred to in the first paragraph of the i
E I6 letter. l
= 1 i
17 0 Specifically referring to this sentence, I wanu to ask 2(
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- la i, veu what does it =ean, "It should also clear up any c.uestions as
- i Q 19 ! to hcw fill should be placed in the future"? What did you mean n '
20 bv that?
l >
2I A 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. I i
25 !
4 l
ALDERSON REPORTING COMPANY. INC. l
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142 9e )
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1 ,1 Q You say, now you knew; new who knows?
3 2 A The project, in =y opinion.
I i i
3- i' 0 In your cpinica' t
I 4 A Yes. I 1
g 5 Q :n your epinion this document should clear up any a :
I j 6i questiens as to hcw fill shouldha placed in the future. And my M
7 I questien was, did it accc=plish that; did it clear up any n
j 8, questient, as to how fill eheuld be placed in the future?
d I s
z, 9{ A Fr== reading the document you presented to =e yesterday,
- i,
@ 10 I the s"--ary docu=ent and all of those various questions abou: fill z l
. = l j 11 j place =ent, I don't believe that the questions were clear. The m
j 12 , intent of the document was to convey my opinion to the prcject
=. 1 j= 13 l engineer, and then the project engineer from then en wculd
=
3 14 l pecceed with the required action, t-I j 15 0 Would you agree that, in fact, this document did not c
- 1 i
g 16 j clear up questions as to how fill should.be placed in the future? .
I d IT . MR. FARNELL: ! think he already answered that.
E-i, E 18 : mY MR. PATCN: i
=
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' t i 19 l ~
0 lould you answer that? '
A l l 20 ' A Frc= =y standpoint, the intended purpose of the memo 1
21 h was to advise the project engineer so that action would be taken.
l l t
22 ' To =y kncwledge, based upon the information you shewed me, it {
3 23 3 ypears the action was not taken. i 24 ) Q All right. New frem the documents I showed you -- l 1 1 25 ! A And also the fact that the fill was not, the percen of f
{
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j ALDERSON REPORTING COMPANY. INC. l
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143 :
20 1 l
1:
c I ccmpaction was no: used on site past that date. '
I 2
O When did you first ceme to reali:e that que stions as 3
f
to how the fill should be placed were not resolved after this i i
4 '
memo?
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A
' 5l 4 A I found cut for sure during the FSAR operation process. ;
3
- 61 '
. n Q When was that?
2 7 A : don't recall when we started and thatwas in the year i a 5 & i
! '76, '77 when we started working on the FSAR and started requesting 9- i i ! infor=atien, detailed information as to what metheds were used and h 10 L i
=
f all that.
i Then it became evident that method was not used.
i E
11 l
, j o Is your statement correct: It was not until apprcximated'y d 12 !
Z j two years after you sent cut a memo which states, "It should also i
- 13 i i 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
=
7 15 i E
i should be placed were not resolved; is that an accurate statement?l r
? 16 l i 5
l 1
MR. FARNELL: Would vou read that back.
M 17 l l 0 (Record read.)
= 1 E 18 !
g I A believe ! stated that I knew for sure after that l
' T 19 I !
i l the meth:d was, that my recommendation would not fellow for sure, j
20 ) I knew that during the FSAR operation period, but before that, I 6
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21 ldid not knew cne way or the other. ;
i
! 4 22 1 1
j 3Y MR. PATON:
23 1 l' i
j Q Dr. Afifi, I believe you told =e ence before, and we j 24 i !
jhad to go through the routine, when was the FSAR preparation done?
- 25 j A That was -- i '
- ! i ij ALDERSON REPORTING COMPANY. INC. I
i 144 21 1 0 New you're going back to -- I'm trying to get time.
i l
2l A 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 I !
4I way or another I didn't know if my rec ===endatien was follcwed er '
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N 3
. 6I O Would .vour words, .vou didn't knew for sure, de vou aeree '
R-5, 7lt with =y statement that my statement is accurace?
M n
I 8 MR. FARNELL: Get the statement.
~
9l SY MR. PATCN:
i l I
- i y 10 j '
Q : asked you, is it true. Let =e ask you that again.
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= i 2 11 Is =v. statement true?
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'y 12 i MR. FARNELL: Let's have that statement back.
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s 13 ' sy MR. PATCN- I i
z g 14 1 0 Is it true or net true? It's either true er not true . -
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15 , A : would like to hear it with the modification.
g 16 ' MR. PATCN: Fine, let's hear it again with the z {'
O. 17 modification.
5 i
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G 18 ,
(Record read.) i E i U 19 k SY MR. PATCN:
5 n -
20 I Q I'm asking ycu, is it true or not true?
h 21 ' A My answer, I didn't know for sure until two years later. i t
i 22 [ Curing that period, within that period, I didn't know sc- '2y er j
j i 23 .i another for sure if my recemmendation was accepted or net, one way 1 a
1 24 } or another. I a
{ i 25 0 Did you try and find out if it was accepted? l f
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8 I I
4 ALDERSON REPORTING COMP ANY. INC. I i
145 22 I 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?
i 4 A : may have visited the site in connection with scmething i
sn 5; else othar than the f _11 placement. I recall visiting the site ,
c 4 ,
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. 3 6 h once in connection with the pre-award meeting or pre-bid .
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$ 7l =eeting for one of the, I believe, intake structure. I don't j 8ll recall being involved in fill or questions on fill during that J l 91 period, z.
, @ 10 0 Did you ever consider during this two year period, z_
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4 i
- l 12 I attempt to verify whether the ccrrect compacticn criteria were i_
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i being used?
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! I' A : 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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s 16l be used from =y understanding of my duties, my assignment en this ,
s
- 17 M project.
c ,
c 18 :: Q Is it your duty to clarify any questions as to hcw c !
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19 l fill,should be placed? l 20! A ' My duty at the time, since the question was raised and
,1 t
2I ;
I was asked to provide input, to raccmmend, make a racem=endation I
i i 22 ' to the project engineer. I i
2 I
23 '
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. i a , - , - , - --
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23 1 k and I ce=ented. l I
2 0 Ycu became aware of what?
l 3 A I became aware tha: the method of compacticn 1557 !
I 4i Method 3 may not have been used en site and as intended by the i I
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e 5 engineer, wall structures. The question came in frem construction n
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g 6I which me hed should we use. '
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$ 7 Q So it was your respcnsibility to provide them with I
g 8 information, or with your opinien en which?
J 1 9l A Mv recomenda:icn.
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z 5 10 Q And then as I understand it, your responsibility j
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it i l 12 { A The way I interpret it, yes.
- i I g 13 ! O You did not understand that you have any responsibility
=
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14 ! to make any determination as to whether or not your recommendation
- I
- 15 ,l is beine- followed?
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= l l j 16l MR. FARNELL: We're still talking ahcut that two year !
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z MR. PATON: Yes. :
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g 19 ': A Yes, for that -- there's no way I can force the project j n
- l 20 to do something the project will not accept.
l' 1
21l 3Y MR. PATON: I l
22)r Q when you visited the site, if you wanted to verify l <
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 r l
I ALDERSON REPORTING COMPANY. INC. I 1
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147 24 fasking,yes,foroneofthethings.
2 ~l Q Who would you ask?
3' A I would ask the Construction people, Construction crew.
i 4i
! O Do you know who, for example you would ask: Mr. Cock? i i i e 5 :
- i A Who is Mr. Cook? I n ,
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- 6: '
- Q Who at the site would vou. ask?
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- ! A I would probably ask Mr. -- I don't recall who was in l
a 8i charge of Construction at the time, that I could have asked J
l t 9i 2-
- during that period. I wouldhave asked somebody in charge of E 10 I i
Construction at the time. l E 11
< Q So in fact, if it had occurred to veu, vou could have a - - ,
4 12 - '
z I
obtained that information by just asking somebody?
- 13 !
j i MR. FARNELL: He didn't say that at all. What do you !
= .;
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= 14 1 5 ! =ean, if it occurred to him? !
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- i f
3
.- 16 ' '
z i Q Co vou
- have trouble with that question? l i
R 17 l i 2 A Yes. -
= !
E 18
=
i Q If you had been interested in finding cat whether the
. 6 j 19 l!correct compaction criteria were being applied to the site, am I !
l
~ 20 correct that all you would have had to do is to ask semeene at the ; i i
21 I i
site; is that correct? !
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 '
4 fill placement are being met? i i
- t ALDERSON REPORPNG COMPANY. INC. 1
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148 l
' I 1! 1 I MR. FA? SELL: 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 ,
e
- 5l i assigned for it. !
N I 1
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- 6lj (Discussion off the record.)
R R 7
- MR. PATON
- There has been some discussion between n .
s 8!i l '
cetnsel concerning sc=e records kept by Bechtel at Ann Arbor that 1 I
- 9I y ! relate to soils at the Midland site. There has been a reference b 10 ;t i E
=
1 to sc=e large nn-ker, for example 170,000 documents. The staff isl 2
11 ' '
3 ! net presentiv- advised of the nature of these documents, and the i
d 12 l E I those documents.
4 13 l staff has requested that we be al10wed to inspect
- l i .
The staff has also requested that so=e brief summary be provided l t
E 5
u lal' to let us knew what kind of documents are kept by 3echtel in l
l 7 15 i 2 1 Ann Arber with resc.ect to the soil matter in Midland.
=
? 16 , i S, Mv. recollection was thr.t after Isham, Linccin & Beale !
n 17 l
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i had the opportunity to leek at these documents, seme censideration{
5 18 ; '
I was to be given to providing the staff an orportunity to look at I O 19 j these documents. I had thought that that opportunity was going to 20 ;
be provided to the staff several weeks ago. As understand the m.
21 ' !
l situa: ion -- st:,3 a as I understand the situation.
- i I
22) i 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 , '
] MR. FARNELL: -I'll attempt to talk to Mr. ::ameron over
. i 2
ALDERSON REPORTING COMPANY. INC. !
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E-149 4
.o t I lunch. .v.r. Sa: erin was the attorney chiefly involved in some l I
l 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 -
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5l i, Q Or. Afifi, did you state yesterday that ccmpacticn that et 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?
j 8' A : =eant this in the centext of the Midland clay field.
d 2 9 4
Q Can you tell.'. me the basis en which you arrived at that I,
z 10 { conclusion? j
!8 11 A The basis is, the first basis that was apparent frc=
'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
(=
17 ,
data is available to the NRC of running both types of test on the Si 18 ' clay field and the data to suppcrt the statement.
{n 19 l
,0 to you know whether there were any requirements for 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 ]i MR. PATON: During plant fill operations, 23 MR. FARNELL: Has anything changed over the time, if t
l
! I'
- 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 asked a questien.
I 2
MR. FARNILL: Ifyou'regoingforalongperiodoftime,l 3 '
I don't think it's an appropriate question. Why don't you ask j i
4i
! him for a year or two years?
MR. PATOM: I'll ask the questiens.
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, . l MR. FARNELL: I'll make =y comments, too.
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A Can you repeat the question, then?
i n
r 8l 3Y MR. PATCN:
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1 Q Yes. Do you know if there were any requirements for
=
y 10l' ccmpaction equipment that was used during plant fill operations; j
E 11 g 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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3 14 l '
3 i Q Do you know whether those requirements were =et? I
= l 8 9 15 i i 2 n after the discovery of the unexpected settlement at the :
16
- Diesel Generator Building, my people became involved in tests to 5 i
- 17
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d qualify this equipment at t:ie Midland job site.
= 1 {
$ 18 !
.- 4 i Q All right, sir. New please address the ceriod of time 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 ' - 1 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 l
I 151 :
,3 t
l Ial Diesel Generator Building?
s l
i l 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, !
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these tests qualified the equipment for the use and placement of !
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I would like to take objection to the werd "qualifica-M '
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I I xm using it in the centext of qualifying ,
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3 Q Your statement is that there were required precedures; ;
I E 12 l is that correct?
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5, A A qualified precedure for each piece of ec.uir. ment.
m 5 I4 That is a technical significance.
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5 ' h. ' ! Q There is a qualified procedure?
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y 16 A For the compaction equipment. -
- I, N I7 Q For the compaction equipment. !
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When .vou use the exc.ression " qualified precedure for the!
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A And number of passes. l i
21 ; Q Would that also include =cisture centent? !
a .
- I
- 22) a A That's an inherent part of the specification. It's not j j
23 I necessarily related.
.i That's a different sub'ect.J Meisture i
- 1 24 , 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 1 152 29 l l
l I problem at 'the Diesel Generator Building these qualified prece-21 dures were followed?
l t
- 31 A To the best of my knowledge.
4I Q And is it also your testimony that prior to the I a
5 discovery at the Ilesel Generator Building you de not knew i
~
6 whether these qualified procedures were followed?
R i 7l A I believe I stated that prior to the discovery of the j 81 problem, I do not knew if the procedure was developed.
, l
- i 9' O okay, so you're not even sure whether there were 3
j 10 ! procedures -- strike that.
=
!n II You're not sure whether there were precedures; is that
' d E 12 l the idea?
= ,
13 A I don't knew for a fact there were procedures.
@* l 4
E I4 i Q- After the discovery of the =roblem at the Olesel u ! -
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= 15 ,
g i Generater Building, were qualified procedures followed for both
= !
16 a[ sand and clays?
" i N I7 ' I believe that in Q-listed areas, the sands were !
a A
= :
}: 18 1
qualified. I don't believe we qualified the equipment for Q- i s
~
m I9 ' ,
listed placement of clay.
I 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- Is optimum meisture the same for both the 56,000 and Q
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 !
. e 5 Su= mary of Supporting Soil Conditions and Planned Remedial n i N i
~
a 6!
s Measures for All Safetv RElated structures and Utilities.
. I'm n
7 not going to = ark it as a deposition exhibit unless your counsel n
j
~
8l requests =e to do it, because it is in vclu=e 1 of NRC responses j d I l
- [ 9l -- of your responses to NRC 5054 ? requests, in response to Z
5 10 Ouastion 12.
z
= i j 11 I want to direct your attention specifically to the s ,
I f 12 I paragraph under Supporting Scil Conditiens i==ediately to the '
~
l
=
13 l right of AX 6, 9, 13.
I'd like you to read the entire document. j e
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I g 14 i MR. FARNELL: I would like to see the entire response
- t 2 I
$ 15 l to the Ouestion 2 to see where this came from and put it in con- ;
e.
i i.
j 16 g text.
- i i 17 i MR. PATON: I would also indicate that the table that u
= ;
{ 18 l I have referred you to is Table 12-1, Page 1 of 5, revision I and i
t
. E 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
d !
3 ALDERSON REPORTING COMPANY. INC. I
I 154 i 31 I MR. PATON: All right, I'll back up.
2 3Y MR. PATON:
3 Do you know whether there is a possible local void under.
Q t
4, concrete =at elevation 590 to 539 at boring AX o'
, . t g 5l i a The best of my recollection, that has been reported en l
H i l
2 6' the boring leg for that boring.
i It's one out of three borings j R
i 7 in the area.
M j 8 j Q Your answer is that it has been reported on the boring 0 !
- 9l log?
z 0 10 5 A To the best of my recollection.
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- l 11 i MR. FARNELL
- Would you read back the question.
3 N I2 l (Record read.)
5 1
1 3 13 ' '
3Y MR. PATON:
i = l E
2 14 l' Q Does your response mean that there is a possible local l
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15 :3 void under concrete mud mat elevation 590 to 589 at boring AX-9? !
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E I0 A Yes.
17
$' Q Mcw this next question specifically refers to the word,
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. 19 i !
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20 ' My question is your degree of certainty.
. i Is it 2I pcssible or are you certain that there is one there? i J l
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MR. FARNELL: Or any other radiation, I gather. !
23h A Would you read the question again? ,
1 i 24 3J 3Y MR. PATON:
S, 25 0 Yes. How do you know there is a possible 1ccal void ! <
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i ALDERSON REPORTING COMPANY. INC. I
i l 155 i
32 I under concrete mud mat elevation 590 to 529 at boring AX-9?
2' A ! believe stated that that was reported on the t
3 boring log to the best of my recollection. {
l 4 Q Did the boring log indicate to you that there was a 1
e cessible void or that there is a real void?
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3 6' , A I did not personally drill the boring, so I don't think R \
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8 words -- you have said possible local void, and I would have to
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Ii say in my judgment it would have to be a possibility of a local t 10 '; void.
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11 '! Q Cn what infor=ation do you base your answer that there 3 !
5 12 : is a possible local void in that area?
j 13 A I recall at the time the borings were drilled that that
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5 I ". Il method came and was cons.dered important enough to include in j=
_ t 15 l the response to the NRC question. !
l g 16 ! O Do you know what, if anything, has been done to e ,
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f-18 l MR. FARNELL: He didn't say there was a void. He said j 19 2 4 there was a *nossibility of a void. Are you eli=inatine the a {
20 possibility of a void?
II 3Y MR. PATCN: ,
i i
i 223' Q Has any action been taken to -- ;
d 23] -A Can : take a look at this?
I 24 1 Sure.
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l A The remedial action, I would like to include for the !
25] .
I i j l 9 i i ALDERSON REPORTING COMPANY. INC. 1 I
3 c o- l i I 33 ' i I' record, the propcsed remedial action is included on the fourth !
1 2 column of the table and it states, "?ressure grouting, avoid i
3! below concrete mud =at as needed." '
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TO =y kncwledge, that has not been done yet.
I jn S Q Co you know whether you plan any further investigation !
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real void?
N I j 8l A That would be apparent at the time grouting actually d i 9 '. takes place.
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i y 10 ! Q You mean at the ti=e you start grouting ycu will not z i
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E 12 l; A No, I didn't say that. I indicated already that the
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5 I4 ;; local veid. Grouting has not been accc=plished yet. And greuting c
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W A Yes. 'I
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Q Ecw are you going to deter =ine whether or net it is l
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20 ! A You just si= ply pump, continue to pu=p grout until 2} I;- you cannot accept anymore grout, in my cpinton.
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 24li voids?
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25q xa. FAaNz;;: nepeat that, please. ! '
i ALDERSON REPORTING COMPANY,INC. 1 1
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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. J i
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BY MR. PATCN: !
l g 6, 0 Have you conducted any investigations to deter =ine R
$ 7i whether there are other voids or possible voids within 50 feet N I j 8 I' of the void, the possible local veid that is mentioned here?
J c 9 A The borings conducted in this area, I do ne recall how z, .
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0 In your professional judg=ent, is the investigation
= i 2 15 ; that has been conducted here sufficient to determine whether or l w i s
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g 16 ' not there are other voids or possible voids within 50 feet of j l =
d 17 the void that is menticned here?
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= 18 , MR. FARNE;;: I don't believe he said they conducted i
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i p I 19 'a investigations as to that possible veid.
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i 20l MR. PATON: Okay, if he didn't, that's fine. That's a 1
21 good L_
22] 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! i i !'
l ALDERSON REPORTING COMPANY, INC. !
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158 35 i
1l i how =any of these were drilled after. !
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 e 5 in this paragraph I asked you to read?
E
. I g 6 A gell, ; knew that to the best of my kncwledge, ncne was
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$ 7I reported on the boring legs.
n j 8 Q Dr. Afifi, that's not =y question. My question is, de d i 8
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9l you knew whether'there are any voids or possible voids within 50
@ 10 feet of the local, of the possible local void mentioned in this E i
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- i Y I2 l MR. ARNELL: I think he answered that.
5 a
I 5 13 ! MR. PATCU.: If he did, I'd like to knew the answer.
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g I'4 l A The answer is that to the best of my kncwledge, nene
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were reported in the borings that were taken in that vicinity i I6 I 3Y MR. PATON:
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j 18 none were reported.
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-. 1 I9 , A Yes, sir.
4 a j 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.
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i I ; mentioned in this paragraph? '
i 2 A Can I speak with my counsel? !
t 3 MR. PATON: i Certainly. l I
4 t' (Discussion off the reccrd.) i i
l g 5 A '
My answer to your questien is that I den't knew.
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$ 6 BY MR PATON:
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Q Did knowledge cf this possible local void, was that
! 8, developed frem an exploration that was =ade?
d-I z
9 li MR. FARNILL: I think it has been stated that it's a h 10 z ,
boring log and the boring log developed the knowledge of a
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Q 11 i possible local void. I don't understand your question. I 8 i f_ 12 l BY MR. PATON:
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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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- A From a boring. '
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- i Q Now, do you plan to require additional berings to '
17 investigate whether there are other voids or possible voids? l G 18 )
= i x ge,
- 1 N
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Q Dr. Afifi, if I asked you whether voids are sometimes t n i 20i discentinuous, do you understand ny question?
e 21 A 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. .
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37 160 I
I i 11 6 Dr. Afifi, do you plan any borings or other
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2l explorations fc the purpose of deter =ining whether there are l 3 other voids or possible voids within 50 feet of the possible !
- 4 local void that is =entioned in this paragraph?
.. e 5 MR. FARNELL: That's been asked and answered.
n N
e e 6?: MR. PATON: Off the record. i
. R ;
7 R. (Discussion off the record.)
A n
i 81 i
\ I don't know at this time.
d l 9i BY MR. PATON:
z_' !
z 10 i
Q Dr. Afifi, I show you Pages 13-1 through 13-6 which
= 1 g 11 l has attached to it, several figures. This is in volume 1 and it's z i 4
z_ 12!. Conscmar's Answer to Staff Question 13.
= !
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13 l 4 I specifically address your attention to Page 13-5. ,
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3 14 ! Near the top of the page, there's a Paragraph Number 2.
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15 j MR. FARNELL: Is there a revision date on that?
= l g 16 i MR. PATON:
s No ravision date on either 13-1 or 12-5.
i 17 There is on 13-2.
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, E 18j MR. FARN-**- v ou're just going to ask about 13-5' -
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. E 19 L MR. PATON: 13-5 has no revision date on it.
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n 20 ! "R. FARNELL:
. Fine.
l i 21j 3Y MR. PATON: )
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22 i Q fou can read any part of this that you want, but =y I i
23 question is gcing to specifically address this sentence: "The 3
J l 24 ) analysis of buried structures with bends or restrained ends is !
i i 25 l based on the equations for beams on an elastic foundation." i 4
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- ALDERSON RE ORTING COMPANY, INC. t l l
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38 l 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 1 A : don't know. i
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- 5l 1 Q Do you know who within 3echtel would know that?
i M I 3 6i A That would be Mr. Char, D-h-a-r. Mr. Ohar, he would be .
. # l g 7 the person to refer to for that answer.
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!" 8l l Q Do you have any responsibility to determine these l l
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i b 10 A Sometimes.
5 ! i 3 11 ll C When?
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i d 12 i A When requested by project engineering in connection z
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16 l MR. FARNELL: He's talking about these values set forth !
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. 17 ! in 13 E 3Y MR- ?ATON:
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. 19 Q My question, and I'll state it again, the question was, s ,! .
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20l whau were the values of the modulus of sub-grade reaction used in 1
. I 2; l the analysis? ,
!. 1 22 , MR. FARNELL: You're just talking this analysis on il
,i 23 . Page 13-5?
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MR. PATON: Yes.
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25 l A don't recall if there was specifically asked about :
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39 162 I, this.
1 2 3Y MR. PATON:
3 i g If I were to ask you how were these values determined, '
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44i would you again refer me to Mr. Dhar? t g 5 A Yes, sir.
A ;
9 g 6I Q If you had been asked for these values, would there be
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6 7 any records that would reflect that in the documents you have N
I j 8 provided to the NRC, that you have personally provided to the NRC J
- 9 for the purpose of this deposition?
z.
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11 Q Where would those documents be?
8 i y 12 ! A It's possible that it's a computation made and handed
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E i a 18l' A That's correct.
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19 Is there an index to that calculation file?
.Q
- i. n i 20 ! A I believe so.
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21ll 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 li 24 ' it. I would also like to put on the record that we are being I l
cooperative in looking for the indexes, I would expect the same l 25]1 s i
i d ALDERSON REPORTING COMPANY, INC. l
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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?
i 3! 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 5 side is extending to the other side. ,
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N J 2 6 '. i MR. FARNELL: If I ask you for certain indexes, are e a 7 I' you going to say no? !
- l A 8 ll MR. PATON: I think that the NRC has been extremely e i
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@ 10 of -croviding handwritten notes in the persen's personal file.
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14 I' SY MR. PATON:
E i Y h 15 2 ! Q Do you know whether anyone at Sechtel has re-evaluated
= 5 I
f 16 l the value of the modulus of sub-grade reactions be use of
- 17 '; inadequatelv. ce== acted soils at the Midland site?
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- 18l' ,
MR. FARNELL: Again, are we referring to Page 13-5?
" 4
! 19 , . (Discussien off the record.) ;
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20l! MR. PATON: The question does not linit itself to ;
3 i
- 1 ; Page 13-5. It references to any sei:=ic analysis that has been ,
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22 i made. !
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j MR. FARNELL: Another question. Are you talking about j i
24)i all buildings, specific buildings? !
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25 ' '
1 MR. PATON: I'm referring to buildings founded on the l
!! ALDERSON REPORTING COMPANY. INC. i l
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Il inadequately c0=pacted plant fill.
I 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
H 5l re-evaluated the value of the mcdulus of sub-grade reactions for !
1 3
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into sei:mic analysis of structures founded en inadequately '
=
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= 3 A i A The answer is, I don't knew for sure.
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- 9l z-1 Q Dr. Afifi, I want to =ake a statement and ask you whether E 10 !
z 1 vou
- agree with it or whether vou-believe it is true.
= !
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"The re=edial =easure for the inadequately compacted 12 '
I
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soil under the electrical cenetration areas of the Auxilliary 1
13 !
g Building is to bridge over the questionable scil utili:ing the 5 14 ! !
E structural capacity of the electrical penetration recms by I 0 15 h j providing caissens at their extremities." l
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= i Do you agree with that? Cr do you want =e to read 10 i t
6 17 2 , again?
= 1 N 18 I A Yes. !
- 19 '
i n
G "The remedial measure for the inadequately ===pacted I 3
20 ' ,
. l soil under the electrical penetration creas of the Auxilliery l-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 ' I j MR. PATCN: Whether he agrees that that is true. i ALDERSON REPORTING COMPANY. INC. !
,. .3 165
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MR. FARNELL: Word for word?
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i 2 A Can you explain to me what that means, please?
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4 4 No, I get to aM. One questicas and you get to answer '
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" 7 The question is, is that a clear statement?
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j 8 MR. FARNILL: Is it werd for werd true, in substance a <
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j Z l i l
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=
(Discussion- off the record.) l
! IIl t
3Y MR. PATON:
- I g 12 l Q Can you answer the question?
I 5 13 ! A
=
, I am not sure the questien is technically- ccrrect.
i 1 3 14 i
? Q Do you mean that you're not certain that all the facts i I
15 b I read to you are true; is that what you're saying? !
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i 16 i A No, I'm not referring to facts.
- I'm referring to the !
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is technically correct. '
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' 19 !'
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,Q You mean the proposed remedies, you're not sure I I
20 {' accurately stated the proposed remedy? '
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I'm not sure the entire statement you read accurately 3 i
22 I f reflects, is technically, is correct technically to describe i s
23 !
4 what will be done. I'm not sure. ;
24 i !
i 0 Can you tell =e what part of it you are not sure of? *
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25 A The reference to bridging and the structural capacity ;
ALDERSON REPORTING COMPANY, INC.
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,s- 166 i ' cf the structure, things that I can't answer.
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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 5 I s A In my opinion, yes.
n N l l
g 6i , Q s there a proposed remedy?
. j
$ 7 A Yes, sir, s
! 8! Q What is that proposed remedy?
=
2 9 A z, To install caissons at both extremities of that, of j
10 these two electrical penetrations.
= t j 11 l Q I will ask you about the very last thing you said, it 3
Y 12 ' is to provide caissons where?
=, I.
g 13 i A Install caissens at the extremities of the two
=
5 14 electrical penetration areas, at both ends of the two electrical l
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15 penetration areas.
t j 16 i
O Do you agree that the preposed remedy you just recited i l
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would transmit half of the load frem the electrical renetration
= 1 1 m 18 j rec =s en the proposed caissens and the remainine '
half en the
=_ ;
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- g 19 i contr.cl tower?
5 '
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:
I!
24 i 0 Do you know who would know that? I 25 A This is a structural questien. I 4
l d ALDERSON REPORTING COMPANY. INC. I
l 167 44 j i
1 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
sn 5l that lead?
I
- 1 g 6; MR. yam; ELL: ! think he said -- that's been asked and g i 2 7 answered.
"g 8 A I believe that response to that should be provided by I
d i c; 9 a structural engineer.
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$ 10 SY MR. PATON:
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= 1 g Ilj, Q Do you have any idea whether the control tower would j
- l l
=
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3 1 g 13 areas?
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i 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 a
I7 ! BY MR. PATON:
i 3 l w i 1' 1
18 Q Is it correct that you don't know what portion of the ;
3
- 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 Q I believe you have stated that part of a load of the 22f f 23 electrical penetration area would be supported by caissens; is
, l 9
24 - that correc-' !
k i 25i A Yes, sir.
a i
R i d ALDERSON. REPORTING COMPANY, INC. 1
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! l , O 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 4 Q Do you knew what =rocortion of the total 1 cad incased !
N i 6, -
by the electrical penetration areas would be supported by che a
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.!! 8: A I would not know how much of it.
- j l 9l I Q Will the remedy you described for this prcblem result
?.
5 10 l in an additional lead on the control tower?
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- IIl i MR. FARNELL: Additional compared to what?
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
= -
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- i .
j 15 ! be some lead transfar and I didn't know hcw much.
e 1
i j 16 : 3Y MR. PATON:
a N 17 ' , Q Will that additional lead that is transferred cauce the 5
o
=
18 1 centrol tower to settle? 4 1
- ,! i s 19 l A That depends on the magnitude of the load. In my
= -
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 9 y
Q You indicated that he could give us the answer er that 6 10 8 '
E he would refer us to sc=ecne else?
= l t 5 11 j A This is his area of control. He is in control of that d 12 i g information, to my knowledge.
l m 13 l 5 ,
O I'm not sure I know what you mean by " control." For -
E 14 l d , 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 A I believe he would provide you an answer.
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 19 ! !
t I 5 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, l 1
22 j ,
i is there a need to investigate the extent of possible voids and i I
23 8 1 future settlement? '!
I 24 . 1 MR. FAPrdI,I.: Let's take them one at a time, a j 25 '
3 BY MR. PATON: ,
- ALDERSON REPORTING COMPANY, INC. l
- l. I 170 !
.- I Mt 1, i O Is there a need to investigate the exten of possible 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 '4 e indicates that this possible void is local. That's what I i e 5 can recall frcm the informationse have. On that basis, I believe e i n ; i
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e 6i that I wculd croceed with groutin~D as the remedy for that i
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$ 7 situation.
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,q 8! O Do I take your answer to mean that you'd see no need e i 2
z, 9l i for further investigatien of the extent of possible voids? I I
$ A Not at this ti=e.
z
=
10 l' l j 11 Q How about the need to investigate future settlement?
E l
g 12 A As soon as the lead is known, the future settlement can
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13 he calculated.
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3 14 : Q Can you tell =e what data you will use to calculate t l
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15 I
that -ecssible future settlement? i
= t i.
16 A It would be the available results of the berin; '. cgs f
= i l i I
$ 17 i below the area, in this area. i S
i !
i >
E la ' O Would that include censelidation test results? !
=
=
1
. e ,
g 19
k i 0 15 'j i i MR. PATCN: Would you read that answer back.
= ,
1 f
5 16 l (Record read.) l i
- 17
}-
2 MR. FARNELL: Are vou referring to some data he talked 5 -
l I8 ; ,
3 l about3 i H
g I9 l! MR. PATCN: ~'= asking him whether his answer included n -
+
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.
i l 24 ll1
. .c cora reac.)
L.
t 5 '
SY MR. PATCN: i
- t ALDERSON REPORTING COMPANY. INC. 1-4 l
,o s 9 e .,
I I
i 1
I l
1i 1
! C :n your previous answer, you used the expressien, scil '
2ll properties. My questien is, when you used that expression, did i 3' 1 l you mean to include settlement data from.the Surcharge Fregram? I 4i
! A I did not mean that.
n ,
Q Do you plan to use settlement data frc the Surcharge o 6, .
Program?
R b 2
- A The analysis is not complete, and it's possible that 2
=
n 7
g, lf
-J i that would be used.
i
- 9i s
t MR. PATCN: Off the recGrd.
E 10 l (Discussion of:. tn.e recorc.)
E i
= i E
< 11 .
3 l
3Y MR. PATCN: !
. l' ,
12 , .
z Q Is there a potential soil problem at the service water l
_ 4 l
- 13 i i 2
- i structure? -
i l
E 14 i d l A Yes.
-u 15 '
2 Q Could vou describe briefiv and generally, the ecoc.esed i
= . . .
E 16 i
= remedy for that .rchle=?
- 17 d
= 1 A Thc cantilever pertion of that structure is supported E 18 '
= i en fill. T.'.e results of the berings in the area indicate that tP
" ; 1
~
j 19 ~
naterial is inadequate, has inadequate p cperties. For that r ,aseni, i
20 'iJ
. ? .:iles are croc. esed to sup=. ort the cantilever, the end of .that i
t 21 i !
Lcantilever.
3 22 4' i Q Is there an analysis being made to determi.e the etcunt ,.
i 23 -
,of the expected settlement of the piles? i, 24 i I j A Yes, sir. i l
25
O Who is making that analysis? i 0 ;
j ALDERSON REPORTING COMPANY,INC. !
I 50 173 I A ?. K. Chen.
i 2
i Q Can you tell us what kind of data he.is using in 3
=aking that analysis?
4 A The same type of data that is used for the analysis of I
. e e
N 5l the caissens.
I j 6> Q : recall you just indicate, I believe, that you are u
n 7 going to use the same type of data?
n j 8: A Yes, sir.
d i
z.
9 l: Q And I recall your answer to be with respect to -- I
)z 10 regall your answer to be that you were going to use soil
=
~
\
4 a 11{ properties, and I have forgotten where you said you obtained those
" j 12 i
=
i soil properties, where did you get that information from?
?
~
13 g A 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 I
after the discovery of the Diesel Generator Building problem, s
as j t
f*
I8 l well as before the discovery of the Diesel Generator 3uilding i
. 2 5
19 a- :croblem.-
i 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."
J l t
24 Consumers agreed to attempt to locate thoce documents at Bechtel's 25 l 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>
H i
~
a 6! . (Discussion eff the record.)
. R \
$ 7i MR. BRUNNER: The documents I referred to are described I
n i j 8 cn Page 1 cf the document entitled, Meeting Notes Number 1013, d
9 z;
- 9) ,
date August ist, 1979. Subject, meeting of the Diesel Generater !
c 10 I Building Task Group. I will read frem the sentence of that z i
- 1 E
4 11 l carticular I
- document which describes the documents, which as I ,
E i
'i z 12 I understand, have been requested.
i If that sentence doesn't I d 13 I c.recerly describe the dccuments, then I request that a question l
w i 14 l
- i
. he nade bv Mr. Paton.
- The sentence which describes the do " ents ,
t \
I r, 15 1i is as follows:
l
- i I "The Caia and drawings cencerning separation of Canonie's, 1
g 16 j M :
i 17 , work frc= 3echtel werk by construction." -
d.:
I
-5 18j (Oiscussion off the record.) , .
i t.
x 19 '. ,
MR. PATCN: The infor=ation that Mr. Brunner has iust
= f 20 f addressed is data and drawings concerning separation of Canonie's l 4
l 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 1
j ALDERSON REPORTING COMPANY, INC. i
I 175
-n 3.
1! "This item is closed. The data and drawings concerning l
i i I
2l i separatien of Cancnie's work frc= 3echtel work by constructicn '
l I I 3' .have been forwarded to Gectechnical Services for review." !
I i 4l i MR. FARNELL: This =crning you made a statement con- I i
. e 5! carning the large number of 3echtel documents that are at Ann j
- i H : 1
~
e 6 Arbor dealin; with soil. I indicated that I would speak to i R
3 7 l Mr.
i xmerin over the break and to discuss this matter with him.
. I n <
n
! 8l I spoke with Mr. Za= erin, and he indicated that we had told you i
t l 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 i s 13 ? come from this large nc=ber of soils documents at Ann Arber. '
= ,
- k. 14 ! We told ycu that we would produce a porr'.cn of the i 9
!x 15 ; docu=ents in Mr. Afifi's file or under his control, and we have I
6
= 1 l
5 T 16 l done this.
I You will note that the Notice of Deposition and the i n i I i 17 request to produce therein only calls for these documents, and we a r E
18 ! l have fulfilled that request. .
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 ',j I also note for the record that we have made a docu=ent <
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 !
l u'I s. i 1
a ALDERSON REPORTING COMPANY, INC. i
i i
i 176 l 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
e 5l :
and has not been complied with yet. !
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 z
o l
's10l z i understood to mean the docu=ents within the control of each i
-= i, 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 3
g 13 i that subject, but if that is -- I have no further comment.
i 2 -
i 14 l BY MR. PATCN:
b i j= >
l 15 ' Q Dr. Afifi, I show you a letter dated October 22, 1979
- 1 g 16 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. :
23 l
4 t
MR. FARNELL: Did vou
- make that an exhibit? 1 i
1 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 l i
t
.r --y, -
.w.. . . _ . . . _ - . , . _ .,.,.._n - , _ . _ _ _ . , , ..% .,
177 54 1 ,3980 .
. $_< _4 _e .4 .
2 BY MR. PATON.
3! l I
O All right, sir, my question is, is there a problem with '
4, natural sar.ls under the service water structure?
g 5
-i A I am not aware of the problem below the.serfice water
~
lll 6 l' structure.
n
" 7 M
Q Are there loose sands under the ser-fice water pump j 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
(
b 10 I z , the response that there are two and a half feet of loose sand t r
- t ,-
m e under the serfice water portion of the structure.
12
=
i Q Other than this document which is Page 2.1 frc= the g 13
- ;5054 F response to volume 1, you have no knowledge that there are 2 1 14 si
=
-- lany -- do you have any knowledge that there are any loose sands j m
15
=
,bader the service water pu=p structure?
4 I
~
if= 16 j i A The fill portion, the fill itself contains loose sand j=
i 3,l,and that's why the watering system is going to be implemented.
1
{r 18 (Discussion off the record.; '
19 M
I . SY ?1R. PATON:
i 20l Q A:te there loose sands below the structure?
1 2Il i MR. FAR: ELL: Are you referring to anywhere below, I l 1
22 lrean, depth-wise down to the center of the earth?
i i t
23 '
P j
A Available borings, so to =v recollection, there are t
. 24 l
, 31oose sands below the fill supported portion of the st ucture.
3, i 25 j -
t Q Are the loose sands in the fill? i N !
1 l ALDERSON REPORTING COMPANY. INC. 1
55 j As8 i
}.
I A ':'c =y recc.11ection, the fill contains leese sands and i
2 It could be j the response here, refers to two and a half feet.
i 3
in the boundarv between Icese natural sand and fill 4ust
. . at the l 4 i I
i boring SW-6 as indicated at the ti=e the response was pre. tared. .
g I
e i
- 5
- 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 n
= 8i Did Le hcel re=ove natural sands less than 75 percent j Q J l z-0 9l~ dense in the cower block area?
,. 1
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A : een t acw. i 2 11 i
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- i 12 l z ;
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25 i 8 4
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J ALDERSON REPORTING COMPANY, INC. I
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?
4 A I don't recall all of the details. I just recall that f
- . 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 i 2 9I Do you know whether it was done or not?
l ,
s z-
} @ 10 A I do not know, no.
J.
z l
1 l2 11 Q Under whose responsibility would.that fall, to know 12 whether that was complied with or not?
4 l I-1 4
g 13 i (Discussion off the record)
= i m
- 3 14 , A Please repeat the question.
u ,
4 k
= 15 ,i j
w SY MR. PATCN:
l
, = i
] g 16 l Q Whose responsibility would it be to determine whether i
- d 17 there was compliance with the committment in the-PSAR, discussed
- i. x ,
4
.x i
}
}: 18 concerning natural sands with a density less than 75 percent? i g - I9 I
i- i A*
Project Engineering.
i M 2
20 Q Who, specifically, in Project Engineering?
?
- 4 21 A I don't know specifically who in Project Engineering.
22 Q Sir, I want to read you a sentence from the last para-
? i l 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
f
, -e 5 there are discussions between Bechtel and Consumers as to who is n ,
n ,
6l
~
liable for som( af the construction work done at Midland? I e
2 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 l1 MR. FARNELL: Can you give a time frame?
f[ "
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
!w 15 l Q Have you heard such discussions exist with regard to the
~ l t i 3
T 16 l plant fill at Midland?
- s \
i g 17 MR. FARNELL: Such discussions -- you're talking about x
= ! j E 18 : sand, and now you're talking acout scmething different? j E ! !
I
. I E
19 I MR. PATON: Oh, come on. The question was whether from
~
6 i l 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. <
1 o
25 MR. PATON: There was until you -- ,
t i
i ALDERSON REPORTING COMPANY, INC. I 1
1
. _ - , - - -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 \
g 8' A Yes, I understand what the sentence means.
4 9 Q What does it mean?
E,
@ 10 A I believe the sentence means that C=nsumers Power Company E
!3 11 believe that Bechtel should pay for the borings, for the cost that a !
E 12 lwas necessary to conduct evaluations.
E I l3 All right. Have you ever heard of any discussions be-5 i Q
=
I4 tween Consumers Power and Bechtel relating to who will pay for the E
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 I7 '
MR. FARNELL: I'm going to let him answer this question, h=
I8 'but I don't think this is relevant to the scope of the hearing.
~
g 19 A I've heard it mentioned, but I'm not sure 6f the source I.
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
__ _ -~ _ _ _ . _ , . . _ . _ y , ,_ ,, , _ _ , .._,_ ,-
I l
i 182 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-
. R
$ 7lj 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 A Would pu repeat the question?
f_ 12 {
^
l g 13 ! (Record read)
=
m 5 14'l 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
. g 19 ,for the soil settlement problem at Midland?
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?
e N
3 (Discussion off the record) a 6:
2-7l MR..FARNELL: What do vou
- mean? I need some context K
j 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 i
g 13 ) the question, I think he should say so, and I will try to change a
g 14 ' the question, but I don't think it is appropriate to stop the w
s 2 15 deposition to answer question from counsel because counsel has a i
= .
j 16 difficulty with the question.
A
- $ 17 i MR. FARNELL: You are flat-out wrong on your statement.
w .
= \
E 18 ! I am going to continue what I am doing, and it is proper.
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 1i Q Do you understand the question?
I 2 A I don't understand the scope of the question, no.
I 0 You don't understand the scope? i 3 \. s 4
A I 4 I would like clarification on the cuestion.
, i
. e n
5l 1 Q You don't understand the cuestion generally? I N i i i 3
a 6! I'll ask another question.
- R :
R 7! A Okay, go ahead.
- 1 n
3 8I Q Is Bechtel willing to provide information to the NRC in I
= !
O i l' d 9' its review of the Midland facility?
i
@ 10 l A To my knowledge, Sechtel is providing information to the z :
l 3" 11 1' NRC in review of the Midland f acility.
i 12 iI Q Whv
- do vou
- do that?
z_
1 5 13 j A Secause of all the responses to the questions that have
=
\
z i
=
w 14 t heen prepared and all of the data.
t I
R 15 0 You naean you do that because we ask questions? -
t 1
u 16 ! A This question really - - cortends to Sechtel as a whole, and N !
i 17 l it's hard to say. I would not know the answer to that.
w
= ;
$ 18 ' Q Are you willing to provide information to the NRC in its -
. C 19 i review of the Midland facility? I X l n :
20 ! ,
A I am willing to provide information.
. i 21! '
Q Do you have any instructions with rescect to vour ,
I providing infornation to the NRC in its review of the Midland l 22 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
1 I
l l
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:
n N
e 6 Q I show you a document that I have marked NRC Deposition t
o E I E
7l Exhibit No. 5, 10-30-80 (Afifi), which consists of a cover letter I
M 8l dated August 4, 1980, two pages long and signed by Mr. Schwencer of J I s 9{ the NRC with an attachment dated July 7, 1980; subject, Inter E. 1
@ 10 l Agency Agreement No. NRC-03-79-167, Task No. 1, Midland Plant, E !
5 11 'l Units 1 and 2; sub-Task No. I letter report, that attachment being i 5 1 d 12 l 16 pages long, and ask you if you have ever seen NRC Exhibit No. 5 z
=
E 13 before?
=
! Yes, sir, I have.
E 14 A W
l
= l E 15 j Q Have you read it before?
w i
~
I n
16 l A I read certain cortions of it.
~
mi i j
17 , O I direct your attention to page 3 of the attachment a ,
E !
E 18 j which is the portion on the letterhead of the Corps of Engineers, i
= ;
i j
i 19 'specifically to the paragraph about seven lines from the top of e .
l 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
Q Do you know whether Censumers or Bechtel have performed j 23]
24]1 the bearing capacity computations that are referred to in that j 25 l paragraph?
i t
i a ALDERSON REPORTING COMPANY, INC. 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.
II 3lW Are you asking whether the Bechtel or Consumers has sent l 4l bearing capacity _ computations in response to this request?
I
~
e 5! (Discussion off the record) 1 n I
~ l'
- e 6l SY MR. PATON:
l
" t 2 Dr. Afifi, within that four-line paragraph, do you see 7l -
Q n :
3 n 8 !the three words, " bearing cacacity comcutations"?
i d i t
t 9i A Yes, sir.
l 4
2 1 2
10l Q Do you know whether Bechtel or Consumers Power has ever
= i j 11 made such bearing capacity computations?
3 j- 12 l A Yes. I,
=
i !
~ I 13{ Q Who made them?
= l m
5 14 ;l 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.
= !
i 17 ! Givens, G-i-v-e-n-s.
a
=
i 18 I Q Do you know when those computations were made, 3 !
p i
. r g 19 ! approximate.ly?
g , -
, 20 i A They have been prepared as part of the response to i
21 !, Question 39.
ap 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 i i i i -
I t
9 1l A Yes. j i
2l i Q And did you read the portions applicable to your cwn !
?
3l responsibilities? l l
I 4 A Those are the ones I read in more detail, yes.
5j l
g Q Do you recall within the portions that you stated that !
e i
" l 4
- i 6 i 2 i you read in more detail, are there any requests for information in l R ,I
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'i there that you do not intend to comply with or that you do not n !
- 8l intend to provide?
d s
l
", 9<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
=
g 13 'i cther things, and I am going to instruct him not to answer that.
- i m
E I4 l MR. PATON: All right, if you have instructed him net to
.i j=
15 j answer, all I'm saying is either the witness can answer the
! n E I6 l question or he can't. If he can't, that's fine. !
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- 17 ' i 2
s i MR. FARNELL: We're not even cettine that far. I'm i i
3 : I w I i 18 f instructing-him not to answer. It's misleadtng, anc I am willing !
c j i
19 i i' 3
a to go; item by item, but not like that.
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?
15 A I believe I read the first two pages -- let's see. There!
t .
s i l l ALDERSON REPORTING COMPANY. INC. i i
i
l 188 10 1! i' are different degrees, really, how hard I read each part, but I _
e l
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 !
- e n
5 l you that I read 4, 5, portions of 4 and 5 are not my entire
" i
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e 6 Lresconsibiliev.- -
I read number 7. 1
- g 4 i R 7 lI Q You didn't read number 6?
n j 8 A I read 6, portions of 6. I read the entire page 6, but d l
- 9l I believe I stated that portians are not within =y area of responsi-l
@ 10 bility. I read 7 and certain portions of 7 are not within my area z
i I
< 11 ,l of resc. onsibilitv. . I believe 8 and 9 are not within =v. area of 3 l I
- g. 12 ' responsibility.
E i 13 ! Q You have eliminated 8 and 9, pages 8 and 9; is that
= l ,
n I g 14 ! correct? I
- ! l E 15 A I believe that those portions, to the best I can recall a ,
= 1 ,
j 16 at this sement, they are not within my area of responsibility. i s
d 17 - Portion F of page 10, I read. 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,
1 25 lit's not within my area of responsibility, I might provide certain l i l
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..."?
n M s
~
e 6- A Yes.
$ 7' O All right, continuing with that sentence, it says on the M
i n
8 next line, " compute settlements based on test results on samples .
a 3
d 9 i frem new borings which we have requested in a' separate memo and i >
.c 10 c. resent results."
_E I 11 ! First, is that subject within your area of responsibility?
< 1 is d 12 A Yes, sir.
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Q And do you know whether the settlements requested tnere E ;
a g 14 l are being prepared?
t:
I' i E 15 i A Would you repeat the question? l
?i l <
i 16 With respect to the words " compute settlements," do you l' j Q e
i 17 i know whether those settlement computations are being prepared? l a i E !
E 18 A No, sir, they are not being prepared.
=
3 19 i Q 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 i
23 ! stated, that in the opinion of the Applicant, there will be no 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
I l
190 12 1 4Yto 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
- e 5 here dated September 14, 1980.
- i H l 3
a 6: Can you tell by looking, is that the document you were 2 7 referring to?
I 8 A Yes, sir, n
s And your shorthand title for that is a position paper?
z, 9l Q O
h 10 ! A Yes, that's it.
E !
= :
j 11l Q To your knowledge, has there been any recent discussions 3
f 12 ;
I concerning Consumers' position with respect to this request here
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1 13 ! to compute settlements to verify the pre load test settlement i
t 5 14 j I
conditions, compute settlements based on test results, on samples-b , l
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g 15 : from new borings which we have requested in a separate memo and e
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g 16 l present the results?
o d 17 i .MR . FARNELL: Discussion with who?
2
= l
$ 18 i MR. P ATON : Discussion with anyone.
= 1 3
[a 19 A
I don't recall any recent discussions. !
l 20 .f Q When you say, position, you mean Consumers Power's !
I i
i l i
21 ! sosition?
- i i i i
22 ' A I meant the -- I was referring to the document, yes. j i
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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 i
I 1
a ALDERSON REPORTING COMPANY,INC. l
l .
191 4 t
13 1, from Consumers Power.
I f.
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,
- 5 Dr. Peck, and I have participated in these discussions. That's
- e. .
n i, N i 8
e 61 how we feel from an engineering . standpoint.
i g ,
[ 7 Q Can you tell me whether that was sechtel's decision or N ,
8
" 8l Consumer Power's decision?
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 12 l Q You said you recommended strongly. Can you tell me why
- i. t E l j
13 l you said, strongly?
j 14l A Because I believe that the full scale measurement that
- i I
w 15 l
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wemadeontheDieselGeneratorBuildinecrevidedsufficientbasisl
= , l j 16 l to predict what the performance of'the building was with respect s \
17 ' to settlement. I believe this is reliable and gives us the answers g'
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E 18 ' we are locking for.
=
l 19 , Q The need for additional borings -- strike that. l
= ,
, n . .
l 20 !\ There is no clan to have a Surcharge Program at the 1
= 1 l
1 l 21 l Auxiliary Building, is there? ,
i I
22 l i A No, sir.
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) 34l 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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e 61 i SY MR. PATON:
R 2 7l 0 You have been requested to take additional borings by n \
I n 8l the Corps of En=ineers and the Staff, with respect to the remedies d l
@ 9i at the Aux Building; is that correct?
z m
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@ 10 l A Yes, sir.
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= i E 11! Q And did you have a recommendation with respect to those 3
d 12 borings?
z E 13 l A Mv recollection is that the request was in relation to
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= 14 < boring cae. acitv. -- can v.ou --
a j D
_E 15 i 0 Both bearing capacity and settlement --
a-l i
j 16 l A 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 n
g 19 l A Where? Are we talking the Auxiliary Building?
5 '
20 Q Yes.
l ,
l l 21 A Deep in my heart, I do not feel that these borings were l '
i i l 22 l necessary. I have no objection to taking them or not taking them. l 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 3 I e
6' want. It would be better information than drilling a hole 25 or 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 I t
= 9i A No, sir. '
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$ 10 Q Do you believe that if you took these borings requested.
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y 12 j information with respect to settlement predictions and bearing E i s
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13 ; capacity at the Auxiliary Building?
4 2
g 14 lI MR. FARNELL: Read that back, please.
- i
= 1 2 15 ' (Record read) a
= .
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a p 17 '
3Y MR. PATON: l M i
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A Yes, if you would clarify it, please. I l
20{ Q :n what way? l
! i 21 ! 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 24 I Q Yes, that relates to a settlement prediction. '
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25 A Irrespective of whether it's valuable information or not?i
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i U l s ALDERSON REPORTING COMPANY. INC. i
p 194 16 11 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
. e 5, settlement? 1 i
l Q t i
3 e 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
= i i j 11 I pages 1 through 16, within your area of responsibility that you do R ! I i
0- 12 not understand?
z i 3 i j= 13 l MR. FARNELL: Same objection.
l m 14 ;1
= (Discussion off the record)
- i, 2 15 ! 3Y MR. PATCN: !
i i
j 16 , Q I'll say page 1 and he can answer, and then I'll sav i I
i x 17 j page 2. As a matter of fact, starting from page 1 at your attorney ls s
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18 ! request and going through page 16, would you answer for each page? -
! l i
"g 19 ii MR. FARNELL: I want better than that. I want each l n p .
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 4 MR. PATCN: ill ri7ht.
25 MR. FARNELL: I am willing to have him answer as to each ;
a
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j 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 I t 4 MR. FARNELL: He's here to answer your questions. !
l
. I g 5 MR. PATON: All right, you instructed him not to answer R
l g 6;and I'll ask him another question.
n b 7 SY MR. PATON:
n j 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?
Q 3
f=
I2 l Q Yes, sir, the page that has at the top in all caps, ,
I 5 13 '! SU3JEC"': INTER AGENCY AGREEMENT, et cetera. ,_
= :
2
- E I4 l Are there, in your opinion, any requests for information i
e E 15 on that page?
t-4 j 16 { A Okay, I nave difficulty with pages 1 and 2, in general.
e N 1/ ' Q In understanding them? l e i I e l 18 :
l MR. FARNELL: I think he's indicating there's something i g
I9 about,them he didn't understand. I n ,
l
. 20 l MR. PATON: I'll ask another question.
21 BY MR. PATON:
22l a
.Q Dr. AFifi, would your address page 1 of the Corps docu- I 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 !
n I 8l MR. FARNELL: I don't believe that was correct.
U d 9 A I don't believe I said that, no.
z o l
$ 10 i BY MR. PATON:
z I 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?
=
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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
a 15 about 10 minutes ago. Can you tell me what that strong recommenda-z l
. I g 16 tion was?
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. !
=
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M 19 ; settlement prediction is best obtained from full scale measurements)
. 20 ! i n my opinion, if that access is available.
i 1 21! Q Do you know whether Dr. Peck concurred. in that l
4 22 8:eco=mendation? .f 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
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 g 5 l' Staff is concerned about the three feet of fill just below the 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
~
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9l along these lines. I
- 10
'j Q Are there any other state =ents by Dr. Peck that you
= \
II 5 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 A I don't recall any others,.and I'm not actually sure 5
i i 1 3 14 ' that the first statement was made by Dr. Peck. i I I re= ember in the i t -
= !
15 b back of my mind it was made as to, was made to me by Walter i
= l
- 7 16 Ferris, and I don't recall if that was from Walter Ferris or was s i 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
=. .
j j9l' hat, t to your knowledge, were made by Dr. Peck to anyone con-20 '
cerning taking additional borings for the purpose of credictine I 21!4 settlement?
a 4 1 i
' n3 A Well, with respect to shear strength -- would you '
4 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 -~
\ .
i 5; 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 n
j 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
= ,
a
! il j i
Midland, or is that generally his position? !
i I2 A I thought I understood your question, you were referring:
N o
~
i E 13 I to predicting of the general settlement.
= -,-
h I4 i O Okay, I'll accept your answer with that understanding. !
-: I h
=
II l 1 Do you recall Dr. Peck ever making any statements about i, 16 . , the desirabiliev. of takinc. additional borine.s for the o.urpose of -
N I7 determining bearing capacity?
x ,
2 i j 18l A I have difficulty with the word " desirability."
- i I9 '
k 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 !
+'
l 23 l bearing capacity is concerned. '4 l 1 !
1 24 4 i 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..
I i
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 j
R 6l 0 You would have no objections to doing it, but right now
=
7 l' you have no plans for doing it; correct? ' '
I j 8l ! A That's right. !
d '
2 9 0 Is there any difference between your position and Dr.
z, i O I j y 10 l Peck's position concerning the advisability of taking aIC'.cional i z ! t
= ! ,
borings for the purpose of determinine bearine capacity?
m II l 8
. t 3 12 A As far as I know, I don't believe there is a difference a i t 5
13 : as far as I know. . ,
i 5 I4 ,1 Q Co .you know what the standard review plan is?
c l
j j 15 A Yes.
, =. I i 16 l Q Generally, what is it? +
- I C 17 ' !
2 a A It's list of, check list of items which are recuired, .
5 I
{
18 l which are used as bases by the Staff for reviewing the safety i
- 5 19 !4
- i analysis report.
n n ,
1 20
- . Q Does Bechtel use the standard review plan for any l 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 1 3 provide.the NRC?
A h'
li ALDERSON REPORTING COMPANY. INC.
- - ---mv - e -p s- , , , , , , - , - - - . . . - , - - , - - - _, , , - , - - - --ev ,, - - ~ -
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 g 5 i
MR. PATON : The Midland project.
H 1 j 6! A I don't -- I can't recall exactly. I believe that in c
t-i 7 i many cases, some of the responses to the question -- I'm talking '
- i M
j 8! in =y area, went beyond the questions, somewhat beyond the d i 2
z, 9l question, in my area that I can recall, but I can't speak for the '
- i g 10 i rest. !
z i
= ,
IIl, 4 Q Your answer is that youcare speaking for ycurself only; ;
s 1 g 12 j is that correct?
~
13 i j A Yes, I want to make you aware that I am speaking from !
14 l 5 one area only in responding to the soil question. I do recall ;
i .
- 1 15 '
{
=
that we attempted, in every case, to respond to the question, and g 16 in some cases, we went beyond the items in the question to x .
cH ' 17 complete the subject that was brought in.
i
~
t i
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 :! .
I 25 ,' FSAR, working on an FSAR, and that is a standard review plan for ,'
l l d ALDERSON RE.mORTING COMP ANY. INC. l i
1 l
I i i1 4
01 i .
I e
23 1 sthe a FSAR. In this particular matter, to the best of my knowledge, 2 elwe are working with 50-54 F and I am not -- I am ' unde.- the system t i i
3l i where we respond to all of the questions and provide all of the i'
1 4 l factual information.
i I.
s 5 Q In the last four years, and I am excluding from my .
m i
" i
~
j 6 !, question any instructions you may hava received in connection i
- j 1 6, 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. .
o ,
y 10 MR. PATON: With respect to Midland. l z !
= !
j 1; A Sure, I have received instructions.
l a: i
. 1 j z 12 1 3Y MR. PATON .
=
1 1
g 13 , Q Oan you tell us what the instructions were ?
= i M
5 14 l '
A I cannot possibly recall all of the instructions, but '
= ?, \
- s
- s 15 i ,! we have received instructions to provide information in connection l
= !
- I 16 to responding to various NRC questions and make amendments to i ai
- I l N I7 various NRC questions and provide response for additional l e '
= i i
- c 18 : mformation that has been included in the 50-54 ? Volumes.
1 19 All right, again, I'm not asking you about any instruc-g Q n a 20 tionthatyoumaycemaynothavereceivedinconnectionwiththisl 21! deposition.
22 Have you ever received an instruction in the last four !
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 i
- 1 ALDERSON REPORTING COMPANY. INC. j
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I 202 !-
I I-24 1 A I have been instructed to respond to the questions 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 w
7' Q Surelv.* 1 j 8 (Discussion off the record) l d i ;
- 9i A There has been a change, and that is the difference !
z' I i 0 i i e 10 ' between working in an FSAR system and the 50-54 F system. These !
r !-
=
] 11 i are two different matters. In my working with the FSAR, updating l 3 l !
i 12 FSAR constantiv is one matter, and the 50-54 F agreement that E.. -
E I
- 13 , understand we are working on, that is a different =atter. I a i 5 14 ' BY MR. pATON:
_b ,
j 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 i '
$ 17 A Calls for you to comply with the standard review plan d
i G 18 . and the section 1.70 step by step and to respond to every single !,
I
- n a 19 l step on those.
n .
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 Il 9 .
is that correct?
22 l information; d
23 A I respond to the question in full, and we have, I l
24 ; believe, provided a factual data.
1 ;
25 Q In the 50-54 F process, do you feel that there is a !
1 !'
4 l
,1 ALDERSON REPORTING COMPANY. INC. t
i l 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 3I 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.
i a >
j 6' Q By 50-54 F, I'm just referring --
- - 4 i n .
E, 7l A Are you asking me to change the 50-54 F method of !
n l n
E 8: reportine. into an FSAR: is that what vou're asking?
J '
9! MR. PATCN: He understands very well. l' z- i, i
@ 10 l BY MR. PATON-
- z i
= ' i E
11 'i Q Dr. Afifi, I show you what I previously marked as NRC .
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
= i l
z i 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 .>
=
g 16 I 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
l E 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. i It's possible that it's *h4.s one because it has my initials 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 i
l
! 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. !
e
~ '
g 5, O Is it an attempt on Bechtel's part to summari:e the 2 ,
l t
j 6 problems that occurmed at Midland? ,
> R ;
7I A I did not prepare the document. I may have had some ,
u g 8l , input into reviewing the initial draft of it. I don't believe d I 9i the document is intended to sum =arize the problem at Midland, but !
- z. t o
1 g 10 my understand, the document is intended to provide the lessons as z 1
= ! .
3 II I to what may have had to be learned from the experience at Midland.'
a , !
- t j 12 ,! ;
Q You don't have any trouble applying the words, lessons
=
_ i.
S $
.5 13!' learned to the document, things that Bechtel doesn't wish to have
= l m
I4 ; happen again?
% i .
c j 6 j
= 15 l (Discussion off the record).
E I0 ! (Record read) !
- l i
- 17 I
2 a MR. PATON: I'll strike the question.
=
~
I 18 i I believe I intended to state ?he Midland experience.
$ A ,
e i ,
E 19 'i 3Y MR. PATCN:
6 P 20 'i All right, you did not view that as a summary of the i
Q i I
i 21 iL problems that were encountered at the Midland site? '
' i 3 .
22 !
A I don't believe it is.
23 ' But you do think it is a check list of items that j 1 Q
, \
24 ;. Sechtel doesn't want to have receated at other site 0?
- ,1 1, ,
25 1i i MR. FARNELL: Oon't answer. ;
l !
4
' t I
, ALDERSON REPORTING COMPANY. INC. i L
r - - ., , - - . . ..-r. . , , . .
.l 205 !
I i
- i t
27 15 (Discussion off the record) ;
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 ,
e i n r 3
a 6l- ,
A Are you referrine. to the Diesel Generator Building
= !
n a g 5
7 problem? i f
3 I
8l l 0 Yes.
I c : ,
c E,
9l A Yes, sir.
I i
E 10 l Q With settlement computations and predictions made based !
z -
= I :
E 11 I en those laboratory. test results?
i
< i 3 4 !
i 1 5-u 12 - A I don't recall that anv were made.
- 1 6
E 13 : Q Do you know why thev. were not made? !
I
= . :
M 1 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 !
=
i j 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 ,
. m s 19 '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; 4
I 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 !
i s
I !
s 4 28 15 Q Can you answer e.y question, yes or no, "ere settlement l i
2 l ccmputations and predictions made bas ed en these laboratory test j 3
lresults? i i
- 4. i MR. FARNELL: I think he answered. ;
1
. i .
g 5; A I thought I said, I don't know. ;
W l i 6,; BY MR. PATON: l
' 3 '
- l
$ 7 g You don't remember? l t . h
- 2 8l A I don't' remember. l d i i
! $, 9I i Q You said it became apparent that a fix was required. {
i 5 i i
$ 10 i Almost immediately it became apparent that a fix was required? l z
- ,. i.
= 11 , .
i i A Almost immediately? I didn't use the words, al= cst 3 i
. I g- 12 ! i=1 ;ciately. i s
O l 4 4
= 13 '4 You said that there was an 1::itial --
O
= :
n 5
I4 f A In initial reaction was to take the berings and take the
=
.5 15 4 regular types of tests everybody goes cut and runs on site where ;
I
= r j 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 !
)
= .
}: 18 lr proceed with the tests. ,
. 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 i
23 j eenselidation, to make settlement with. ,
2# A Not necessarily.
y1
- BY MR. PATON: *
'. J i 4 i i ALDERSON REPORTING COMPANY, INC. ;
- we -.- w w - c - -e ,
I . !
s 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 o
2 6{ i Q And those included consolidation tests?
u ,
6 7 A They did. !,
u '
g
- 8) 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
II i made based on the laboratorv - tests?
3 !
12 ' A I can check for ou. It would not be a croblem. Cver- !
E_ - ,
o e I 5 13 i nicht I can check it out. t 5
t I4 '
$ Q Would you be willing, with the consent of your lawyer, I, [.
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15 l to provide that information tomorr w , if he agrees to it? ,
i :
16 ;
f 7 11 check and see. ;
2 i
17 ' MR. FARNELL: If you can check, fine.
= i I 3Y MR. PATON: ,
i ,
19 i i
n iv .O If these computations had been made, where wculd they .
i 20i be located? l 1
21 : A They would be in our computations files. 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 3 d ment computations and predictions having in his possession the f 4
I 25lt results of the laboratory tests? l 4
1,-
i
!! ALDERSON REPORTING COMPANY, INC. i
,m, v ~ ---- ,-e r , ,
i l
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?
g 5l MR. PATON: The lab tests you just referred to.
R !,
j 6 A The process includes evaluating the data very closely R
, t i
i 7, and selecting the parameters and conducting the tests. It's not .
l
. i n
j l
8l ,
a lot of work. ;
t i i n 9I SY MR. PATON: '
@ 10 0 Would it take less than a day? i
_? ,
4
{s II , i A Not in the case of the Diesel Generator Building. It j
a t f 12 l would take less than a day in another si:uation, but not in the ,
= i !
- I g 13 i 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
j
=
16 l evaluate the data, to see the availability of the soil properties,I
' ~
17 l where he samples were taken and be careful about doing it.
M It's t
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18 l not a uniform deposit.
- i
'g n
I9 l 0 So your estimate today is that to make the settlement ,
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 l 209 i t
4 1 ? not make the settlement computations? i 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 t
. 1- .
e 5; MR. FARNELL: Would you read that back, pisase. i R ! !,
. j 6 '; (Record read)
R ,
2 7! A I don't believe so. !
- ; I c 8j A l 3Y MR. PATON: lt d I i 9l Q Oo you know who -- if a decision was made not to make z '
o
@ 10 lj settlement ecmputations and predictions, is that within the scope ,
i 5 l
{n 11j of your respeensibility at that time? I 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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15 l decision you would have made?
1 l
E 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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1 18 ' described, is there a crude estimate of settlement computations i 3 ,
"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; BY MR. PATON :
I 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 !>
n I ,
. 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
=
i
$ 10 ! problem.
1 x
14 <' Q Okay, I'm not sure I understand your answer to my 5
+ ,
=
2 15 l cuestion about the crude estimate. !
u \
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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 I E 18 ! ,
complicibility parameters. I cannot recite 1: fer you at the s
- 19 2 moment, but I can get it for you. l' 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 Did vou make any crude estimate of settlement?
- 25) Q . . ;
' i I
h ALDERSON REPORTING COMPANY. INC. f'
$ i t
.v. 3 !.
i l I
L 14 A No, I stated before, I don't recall if that was done or '
i 2; not. l, l
3 MR. FARNELL: Cff the record. ,
I-i 4i 4
(Discussion of f the record) .
. l 3
e 5l ,
MR. PATON: The request for the ccmpressibility index, i 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
n 8' succiv
-- - it to us?
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 i Q Were six borings made near the Diesel Generator Building 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 i l 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
17 I y Were six borings made -- Dr. Afifi, I read to you f cm -
e i C I a 18 . =a ge 1 of Censumers'Pcwer Exhibit No. 3, Heller Deposition, i
. = l ;
g 19 , October 9, 1980. :
5 l i
. 20 < "After removal of the surcharge, six additional borings 21f were made to ccnduct in-situ shear wave velocity measurements ,'
- I 22 h and I hand you that document if you want to read that statement. lI s
23l A Yes. I lH
' ' 1 24 0 Is that a true statement?
l !
25j A Yes, sir. !
?
4 3 ALDERSON REPORTING COMPANY. INC. 1
212 I i
1h 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< I BY MR. PATCN:
N j
I 8l Q Let me read it again. Did you compare the bicw counts d
n 9 obtained from borings before and after surcharging the Diesel z, .
g 10 ' Generator Building?
z
= :
$ 11 ! A Yes, sir.
E :
. t j 12 ; Do you knew if that comparison has been p Ovided to the O
=
i g 13 NRC?
=
$ 14 ! A No.
i j 15 ! Q Do you plan to provide that information to the NRC?
- i 3 l j
16j gg, yAang;L: You asked him, did he know, and he said, I
- i d
a 17 < no, he didn't knew.
=
18 MR. PATON: I asked him, has he provided it, and I guess
. : ; i e
a 19 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 1
22 ' know.
23 MR. PATON: Okay, if he's already provided it, maybe he 24 ! doesn't plan to provide it. l 1
25 i MR. FARNELL: Can you ask the question again? ,
i
). I 3 ALDERSON REPORTING COMPANY. INC. I
.-. -.._ - . . ~ .
l i l 213
- 1. 3Y MR. PATON: l 1 i i i 2I Q To repeat my question, I have to back up ancther
, 3 question. I ask you, did you compare the bicw counts obtained j i
, I l .4; frem borings before and after surcharging the Diesel Generator g 5l Building: did you answer, yes?
R !
3 4
6' A Yes, sir.
R ;
A 7i 0 Have you provided that information to the NRC?
M i
I j 8 A I have not.
, d l l c; 9i O Oc you plan to provide that information to the NRC? ,
i I
@ 10 A I have no immediate plans for that.
z
= i
{
11 , Q Has the NRC, to your knowledge, asked you fer that j 12 l information?
l
=
- 1 l g 13 i A No.
t
=
= i l l g 14 l Q Do you consider that information to be significant? l t
. i, I i 15 l MR. FARNr;L: To what? I
. 1 l
/ 16 l ,
MR. PATON: I'm asking him. I
= '
, 1 l d 17 MR. FARNILL: It's too general.
a l
= \ :
E 18 ! SY MR. PATON.
1 5 I l r . , .
g 19 l ,Q Oc you consider that information to be significant for a .
20l any purpose?
21 A I don't believe the information is very significant.
22 ! MR. PATON: Mr. Tarnell, would you be willing to have
)
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? !
~
t I
h j ALDERSON REPORTING COMPANY. INC.
l l
1 s ,,
I' MR. FARNELL: We'll provide you with that c0= arisen f i
I i 2I you asked for, but we would like you, at the end of this deposi- !
I i
i 3i tion when the transcript =cres in, to submit to us a list of what, 1 i 4I vou had requested so that we can have it all in one place, and I
l g 5 also, we are doing this on the assumption that we will get the ,
M i n l
~
, e 6! same treatment frem .vour witnesses as to providing documents thatI R :
E.
7 are asked for'durina. de=.ositions.
"3 8l i l
MR. PATON: Well, I think, rather than, you knew, i d i !
- postpone that problem and wait until the deposition comes in -- '
% 9i i i n 10 i MR. FARNELL: We'll work on it now, but I want something z l '
= '
i 5 11 !, so that it will be fairly i=moutalized in one clace. i E l s
i 12 l MR. PATON: Well, let's do it right now. I don't want !
= i
=
= 13 ! to :o home and wait for that to ccme in and then vou read the
=_
- 1 g 14 ; transcript and go through all of that --
I think we've only got !
- i g I R 15 two or three ite=s here. If you want a list, put it on the record t_ , ,
s 16 - I richt new.
e
$ 17 MR. FARNELL: All richt. !
u *
=
3 lb l MR. PATON: Number 1 is the matter we have just dis-
- i
. e <
r 19 : cussed, and that's in the transcript right at this point. Do ycu n 4 .
, 20 : want me to state what that is? !
21 , MR. FARNELL: Yes.
I g ,
22 1 MR. PITON: All right, blow count ecmparison. The i
23 second is, index of construct _en and design drawings.
Certainly, '
a 24 # *escribed it accurately, as far as you're cencerned,:
l if I have not 25 please correct the record.
ALDERSON REPORTING COMPANY. INC.
I 215 )
i 1f (Discussion off the record) !
l !
2I l
MR. PATON: The Staff has requested that Censumers and/ l i i 3l or Sechtel =rovide several items, and the parties new wish to place i
i I '
4:
i on the record what those items are. Then Mr. Farnell will respond, g 5 with their reply to our request.
U ;
j 6; The first item is a ecmparison of bicw counts cbtained
- I 7 f cm borings before and after surcharging the Diesel Generater t
g 84\ Building.
d 2
n
, 9l (Discussion off the record) l
- 4,
@ 10 ! MR. PATON: The second item is an index of construction E l.
II
-3 and design drawings limited to soils and structural foundations.
m i f 12 ) The third item is an index of computations made by Geotechnical 5 i 13 j
= 1 Services. The fourth item is to advise us whether settlement T I i 14 j cceputatiens and predictions were made after a series of berines
=
~
l j 15 , were taken after discovery of the settlement problem and after \
I g 16 laboratory tests were conducted. The last item is a list of '
= .
I N 17 ccmpressibility indexes.
4 g 18 MR. FARNELL: With respect to item four, we understand !
- i
. - l.
I9 s
n this .to be, to relate to the Diesel Generator Building and prior '
f 20
, to position of the surcharge on the Diesel Generatcr Building. !
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.
i l 24)j MR. PATON: Off the record. I I
l 3 l
25I (Discussion off the record) ;
i i
l 4 l
ALDERSON REPORTING COMPANY. INC. !
8 I' l
I 216 i
11 MR. FARNELL: We will either provide you with the a
i information or the answer that it is not available within two i 3 weeks.
I 1
4! BY MR. PATCN: I '
g 5 0 With respect to the six borings that we have been n
N i o 3 6,: discussing in connection with the Diesel Generator Buildi.95, were R \
$ 7 these continuous standard penetration tests or intermittent?
s
$ 8 A I believe they were intermittent.
i d ,
=; 9 Q If they were -- all right.
?
@ 10 Do you know the spacing?
_I a
II A I don't recall the spacing. These borings have been
. t j
=
I2 l provided to the NRC.
l Logs of these borings have been provided to l 5 13 1 <
teh NRC.
=
f" I4 ;I O Considering the use of intermittent standard penetration a <
z j=
15 tests, can you determine soil shear strength and compressibility 16 d characteristics of the soils between the sampled intervals?
m
- 17
~
MR. FARNELL:
3 Would you read that back, please.
= .
$ 18
_ (Record read.)
S ,. :
- ,,! l MR. FARNELL: The question is compound. It deals with n
20 a
either soil shear strength or compressibility characteristics, onei 2I '
or the other.
- I 22 MR. PATCN: All right, I'll take then 'e at a time.
23 SY MR. PATCN: l l
24 ' o oc you want =e to read the question again?
i 25 4 A Yes.
A: b, J '
t ALDERSON REPORTING COMPANY. INC. i
l l
217 1, Q Considering that the standard penetration tests were j j i
8 l 2l inter =ittent, can you determine soil shear strength of the soil 1
3 i between the sampled intervals?
4, A on the basis of the collection of the berings =ade, it is
. 1 e
~
5l usual to be able to interpret shear strength behavier based on all
\
n n :
o 2
e 6l of the data put together from all of the herings.
R i 2
7l \
0 By, from all of the borings, do you mean all six borings?
j 8>I A If we are talking about only those six borings, it would d
- 9 cnly be these six berings.
Y
@ 10 Q !s the data gathered from those six borings sufficient l z
- l j 11 to determine soil sheer strength of the soil between the sampled a ! I' i 12 l intervals? .!
z
,=
g 13 ; A These borings were not intended for determination of
= !
a i 3 14 j shear strength.
e_
2 15 i Q What was their purpose? :
a i i
= -
e 8
? 16 l A To determine shear wave velocitv. l
- I i
i 17 Q Do you know the shear strength and compressibility l 3
~ i I i
E 18 l characteristics of the plant fill under the Diesel Generator
= l
. - j !
n .
g 19 i Suilding since a surcharge was removed? '
n y
, 20 MR. FARNELL: Again, one at a time. Shear strength and 2i d then compressibility.
j i 22l BY MR. PATCN- !
1 !
23 I Q De -vou knew the shear strength characteristics of the !
4 l
I 24 4l -elant fill under the Diesel Generator Building since the surcharge l 1 i 25 l was removed' i
' i j l 1
.1 ALDERSON REPORTING COMPANY, INC. !
I
.u. C A Yes.
II. I 2l 0 What are they?
I 3 A We predicted the friction angle te he 29 degrees and j I
4i the conservatively, the cohesion intercept to be taken as :ere er !
l g 5 greater as reported previously in the September 14 submittal. l H ,
0 Did the shear strength used in bearing capacity analysis j
6l i 7 cc=e frem samples as far away as the bore rated water tank?
. c n
j 8l A Yes, sir.
J l n 9 C In recognition of the heterogeneous plant fill, is that z
- 1 c 10 ! acceptable?
z
- = ,
, j 11 MR. FARNELL: Would you read that back, please.
3 d 12 (Record read) .i z i'
=
y 13 l MR. FARNELL: Acceptable in what regard, to whcm, for
=
m 5
u 14 l. what purpose?
= !
i a 15 ; BY MR. PATON:
= l i 10 j Q Is it acceptable to use shear strength from as far away a i d
w I7 as the bore rated water tank in bearing capaci5y analysis?
= l E 18 . MR. FARNELL: I have the same -- ! '
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g 19 ! 3Y MR. PATON: l n n I , 20j Q For the purpose of making your bearing capacity analysisj.
I MR. FARNELL: I have the same questions, for what, to 2I[
22 f whom, for what purpose? l Il !
23 iJ MR. PATON: Acceptable for the purpose of making a I
1 l
24 ) bearing capacity analysis.
9 l
i i i 25j 4 MR. FARNELL: I don't understand it. I i
s ALDERSON REPORTING COMPANY, INC. i
f i I1 219 l 1
1 A on the basis that the soil material has been used and the:
I ,
2 clay fill is the same and that is the eccling pond area and that l' 1: , i t
- 3i the plastistic characteristics of the sampled tested are similar to.I ;
4 those found under the Diesel Generator Building and the fact that i i
- sa 5 the calculated safety factors are on the order of six or more, the i i
n ,
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. 6 ', resulting bearine capacity evaluation shculd be censidered satis-
! R I
$ 7' factory.
s 4
j 8 BY MR. pATCN: Dr. Afifi, I show you a document entitled, d I
- 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
1
=
E 11 ; 1973.
- l E i j 12 The guestion am going to ask you specifically refers t
j 13 i to a sentence in the middle of the second paragraph that begins
=
l $ 14 with the words , "As built drawings."
i I j = 1 2 15 l Dr. Afifi, did you read the sentence -- the document e I
- i j 16 that I have just asked you to look at is NRC Exhibit 6, which I
- i i 17 have marked and dated October 30, 1980 (Afifi). I direct your x
= i 5 18 attention to the sentence which I will now read.
- I M
.19 l '
"As built drawings as well as boring legs, daily reports 20 i and c:her miscellaneous data were transmitted to S. S. Afifi as
- 21 ui they became available."
I x 22 Did you receive these, do you remember whether you 23 $ received those as built drawings?
I I l 2 24 i A I don't recall exactly what is meant by, as built l l
a . I 1
25 j drawings, in this memorandum.
l'l l !
j ALDERSON REPORTING COMPANY. INC. I
I 220 l l
1 Q The sentence also refers to, daily reports. Oc you l
. I 2 remember whether you received daily reports as indicated in this
,i 3 letter?
I 4
41 A Normally on this type of assignment, people prepare :
, i g 5 reports and whatever data they collect, and they are filed in the n .
" i se s a 6 ;i Gectechnical Files.
i,
$ 7 Q Is your statement that that is not the type of informa-
- A
.4 8 ,l tion you would specifically remember receiving; is that what you
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=, 9 are saying, that you may have received it, but you don't remember z-
@ 10 particularly that you received this information?
1, z
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A Yes, I may have received it and I gave it to sc=eone 12 !else to take care of it, de something with it.
i Y.
If this information:i
$ 1
- g 13 ' existed, it would be in the Geotechnical Files.
m n
5 14 ' MR. PATON: Mr. Farnell, there's a reference here to a
= i
.j 15 i borin9 legs that were forwarded to Mr. Afifi. I'd like to recuest I
- I 16 that if those boring logs are in Mr. Afifi's files, we'd be ai i n
II N. :
provided copies of them. I'm specifically referring to the hering
= !
I8 5 l f d to in Staff Exhibit 6.
"g 19 l ogs re erre l A 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 i
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23 l Applicant will provide the logs in response to the question. f.
4 24! SY MR. PATON:
s i
25l Q Approximately when do you think those logs will be fi
.i, i il ALDERSON REPORTING COMPANY. INC. I y ---, , , - - - - - ,, - - , , , - - - , - ,, y--g-
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t i provided? I i
2 A I do not know the schedule for submitting this upcoming 3 amendment.
4- MR. PATCN: Based on that information provided by Dr. i
. e 5 Afidi, I'd like to withdraw our recuest. I e
N e
e 6 MR. FARNELL: I accept vour
- recuest.
s - ,
M R- 7- SY MR. PATCN: I n
n i 8l Q Dr. Afifi, with reference to staff Exhibit 6, do ycu know: l d
9 at the ti=e the borings for the piecometers were drilled, what was i
C h 10 the level of the cooling pond?
z .
= t i
E
< 11 A To the best of =v recollection, that was before the 3 i d 12 = ounc. ine. started, or very shortiv after the c.um. ine. started, so I l z 4
= 1 s 13 i do not know the crecise level. l 5 #
n
=
x 14 : Q Before the c.umc.ing sta_.ed, what was the level, the !
_- i 2 15 ' a 7roxi= ate: level?
x x +
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- 16 , A Well, there would be no water in the nume. - -
i l
n '
d 17 Q Not at all? l 5 I i
=
18 ,.
a A No, but I can check.
=
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4 4 I x
19 l Q Do you have any concern for future hydrolic fracturing '
5 j
. 20 4 because of the drilling for the berings fer pie:cmeters? l t
li MR. FARNELL: 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? i
. i a ,
25 i MR. PATCN: The answstr, yes . l i
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i 1l A I don't know, sir. !
2f Q Am I correct that you do no: consider that in your area. l l !
l 3 i of expertise? ;
I i 4
4: A Yes. t
- 1 g 5. MR. PATON: Off the record. l
_ i H !
s j 6]j (Discussion off the record) !
R \
l
$ 7l MR. PATON: Okay, that's the end of today's deposition.
n j 8l i
(Whereupon, at 5:00 p.m., the taking of the depositien '
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z, 9fadjourneduntilFriday, October 31, 1980 at 9:00 a.m.)
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