ML20010H062
| ML20010H062 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 07/28/1981 |
| From: | Bohn R NORTHERN INDIANA PUBLIC SERVICE CO. |
| To: | |
| References | |
| NUDOCS 8109230126 | |
| Download: ML20010H062 (182) | |
Text
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l UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFET.
.m D LICENSING BOARD IN THE MATTER OF:
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NORTHERN INDIANA PUBLIC SERVICE i Docket No. 50-36 7 COMPANY (Bailly Generating Station,)
g a Nuclear-1), Construction Permit Extension
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t The deposition of RUSSELL J.
BOHN, taken Ru
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i the above-entitled case, before Susan Soble, a tary public of Cook County, Illinois, on Tuesday, 1
N he 28th day of July, A.D.
1981, at 109 North
Dearborn Street,
Suite 130v Chicago, Illinois, at the hour of 10:00 o' clock e.m.
i f
PRESENT:
i f
Mr. Stephen H.
- Lewis, Office of Executive Legal Director
{
United States Nuclear Regulatory Commission Washington, D.C.
- 20555, j
appeared on behalf of the United States Nuclear Pegulatory Commission; 6
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Mr. Robert J.
Vollen, and Ms. Jane M.
Whicher l
109 North
Dearborn Screet,
Suite 1300 j
Chicago, Illinois, appeared on behalf of Porter County Chapter of The Isaac Walton League, Inc.,,
Concerned Citizens Against Bailly Nuclear Site, Businessmen for the Public
- Interest, Inc.,
James E.
Newman and Mildred Warner; l
l Longoria dc Goldstinu so sousa z s.u. sir :
8109230126 810728 PDR ADOCK 05000367
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PRESENT:
(Continued) 1 Mr. William H.
Eichhorn (Eichhorn, Eichhorn & Link) 5243 Hohman Avenue Hammond, Indiana, appeared on behalf of the Northern Indiana Public Service Company; i
Hon. Tyrone C.
- Fahner, l
-[
Attorney General of the i
State of Illinois, by:
Ms. Anne L.
- Rapkin, j
Assistant Attorney General, i
188 West Randolph Street, Suite 2315 Chicago, Illinois, C
g appeared on behalf of the 3
State of Illinois.
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.E.__X Deponent:
RUSSELL J.
BOHN Direct xamina tion by Mr. Vollen I
1 Morning Session......................Page 4
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Afternoon Session....................Page 83 i
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EXHIBITS I
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- Bohn Deposition Exhibits For Identification 7
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MR. VOLLEN:
For the record, the Porter County l Chap'ter, intervenors, arelabout to-take._the deposition F-of1 Russell Bohn..
(Witness' sworn.)
RUSSELL-J. BOHN, l"
_ having1been first duly sworn,.was examined and I testified as?follows:
j DIRECT EXAMINATION e
.By Mr, Vollen:
I O
What is.your full name-and would you spell 3
'31it for the record, please?
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'A
- Russell, R-u-s-s-e-1-1, J.
Bohn' B-o-h-n.
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.0 What is your business or occupation, Mr.
ze
.Bohn?
I..j A
Manager of the Nuclear Staff for Northern
- l. Indiana Public Service Company.
4i l
0 What is the current size of the nuclear j
5' s'ta f f for NIPSCO?
i
~
A Sixteen.
O Sixteen people.
Has there been a recent increase in that size?
s a
5 A
No, the number includes se'cretarial and that's the total number.
O How many of those sixteen people are i
l secretarial people?
E I
i A
Two are clerks, plus one secretary.
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That leaves thirteen others.
.i A
Yes.
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O Are you one of the thirteen others?
?
A Yes.
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What do the other twelve do?
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The twelve are involved in the day to day l
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! things that we're required to do.
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G What are those things, Mr. Bohn?
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A We have an environmental monitoring program!
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i that requires attention weekly and also licensing 5
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l support for the present proceedings.
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i G
The present proceedings before the Nuclear i i
I ll Regulatory Commission?
l lj A.
Yes.
I I
I G
How many of the twelve are involved in the i
environmental monitoring program?
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l A
Two about full-time plus one or two others -
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6 part-time'.
G What do their activities in the'environmentitl monitorinn' program consist of?
'A We have a number of groundwater monitoring C'i ' wells. :The U.S.G.'S.
has a number of' groundwater N
{. monitoring wells'and many of these have continuous 5
- recording charts on~them, and'those charts must be 2 '.
j
- changed'once a week.
a E
.s The wells, the monitoring wells that do not I have-char,ts-must be read at least once a week.
4 So these two full-time people and one or
- 4
" two part-time people go out and physically change the
.:j charts on'the mechanism on the well and the recorder 2
and physically read and record the data on the other i
i, -
5 kinds of' wells.
Ec A
Yes.
E s
i
-Q NIPSCO employees are reading the data on the U.S.G.S.
wells?
A Yes.
G What do you do e.>ith that data, your people,
'that is?
A Well, we use the date from U.S.G.S. wells tg
c.,
7-y compare to the information we get from our own. wells
.and the U.S.G.S.,'of. course, is= aware we-are doing Ethis.
We share informat' ion with them on_a weekly basis, I.believe.
.g G
.Who are the two full-time people' involved
?
_" E in - the - e nvi ronmen tal monitoring program?
~.:
A
_ Don Young and Dale Bell.
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How long has Mr. Young been doing that?
j A
We've been alternating the people that are 2
l doing that on a several months on, severa' months off i
to koop them, or rather I should say to F basis just
< make sure that all of our people understand the
- mechanism for taking the data, verifying that the
- . charts, in fact, are reading correctly, reducing the data and sending it in to the NRC-on a weekly basis x.
3
. solthis is not a permanent arrangement.
1-l These-people are the ones that are doing it presently, but it's about a full two-man job.
O What is Mr. Young's background and training?
A He has a Bachelor's Degree in Aechanical i
Engineering, I believe.
I
8 O
What about Mr. Bell?
A I believe he also has a Bachelor's Degree in Mechanical Engineering.
O If I understand it, that leaves eight people
! on the nuclear staff.
Well, I guess it leaves six people who are
.?
full-time and one or two people who are part-time i
i ij that are involved in licensing support for the i present proceedings, is that correct?
6 A
There are other things, of course, that I
{we' redoing such as we have a member of t'h e staff fthat' son the Mark II BWR Owners Group.
We have a member of the staff that's involved in the Owners C
- Group on intergranular stress corrosion cracking, i
[ We have a member of the staff that's a memPar of the E
l BWR/TMI Group.
One of our members also serves on a,
j it's one of the reg guide committee groups.
I can't remember which one.
G Reg guide?
A Yes.
There is one other of our people, Bob Kramer is in a group the name of which eludes me at j
1 9
the moment.
Has to do with fuel inventory types of things.
I can't remember the name of the group.
4 Some groups outside of NIPSCO?
i A
Y e.e 8
5 O
That deals with fuel inventory and nuclear I
I power industry?
a
,?
A Yes.
I believe that is about the extent of i
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- our involvement.
5 0
Are any of these five activities that you've l
V:
- just described full-time activities for any of the I
i people who do them?
i 5
A None of them are full-time, no.
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I G
Are tNY carried out by five separate nuclead staff people?
i A
Yes, I believe they are.
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There may be two common ones, I'm not sure i
I l -
yes, there are, Adam Shahbazi is on the BWR/TMI 5
{ Group and also e che reg guide group.
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G What are the licensing support activities l
inwhich members of the NIPSCO nuclear staff are engaged?
l A
Various filings that come in such as 6
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-interrogatories which require considerable perusal of the4 files to find the proper records to, respond to those' interrogatories'and that's a typical example of the typeslof things involved in-the jlicensing-support.
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.What ~ other things beside the preparation of i
p or^the; gathering of_information to helt prepare I
) answers to interrogatories?
-i 3
A We also: review practically everything that's
}
' submitted to the Licensing Board in this proceeding i
i~for technical' content and, as you're aware, there i
fhasbeena large number of those things, several i hundred of documents.
7 I don't believe I can give you any other
!5 specific examples at the moment.
5 G.
So aside from these five activities and l
l the environmental monitoring work that you have described,- the entire work of the nuclear staff is involved-in the' review and preparation of legal papers submitted or to be submitted in the Licensing Board' proceeding.
Is that an. accurate statement, Mr. Bohn?
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A There are other. ongoing activities of the company I'm sure we get involved in from time to time.
("I For instance, I personally am a member of C'
I the Nuclear Power Subcommittee of he Edison Electric
-l Institute.
There'is a certain amount-of. work involved
?
1 in'our participation in that other members would y
I'
- get involved in providing support for.
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0 Any other. activities in which members of j
1 the NIPSCO nuclear staff are involved?
i 3
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AI There would be annual budgets, of course, 4
l that'would come out that we'd be involved in preparation of any input required from the nuclear unit, review, of course, of new estimates put out i
I E by>Sargent & Lundy Engineers would be one of our i
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l responsibilities, and I'm sure there is other things i
i we do that I can't reiterate at this moment.
i.
O Are there any activities now going on by l
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- l members of the nuclear staff apart from the dealinc with legal papers that are directly related to the design'or construction of the proposed Bailly Nuclear Plant?
A No, I don't think so.
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12 Obviously, these owner groups are all involved in the design.
O Yes, sir, but those owner groups are j essentially dealing with generic problems which will I i
[ have applicability to Bailly.
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A Yes.
k O
But they are not directly and explicitly i
- and solely related to the proposed Bailly plant.
S A
That's correct.
ia G
When was the first time, Mr. Bohn, that you I had any involvement -- strike that.
Aside from what the nuclear staff is doing, j is there any construction activity now ongoing at the
?
.!Bailly site?
}I A
No construction activity.
?;
O Is there any activity being carried out by
!others than the nuclear staff directed toward the l
I design or construction of the Bailly plant?
3 r
A No, I don't believe there is.
l O
None of NIPSCO's contractors are doing anything about Bailly, is that correct?
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A The only thing that could possibly qualify,i i
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A, 13 and I don't consider it myself, but I will explain what I'm thinking, is the work on updating the QA/QC Manual anc :he pile driving procedures.
There is nothing in a design phase there, so I don't think it qualifies for your question.
I O
Who's-doing work on updating the QA/QC i
{proceduresand the pile driving procedures?
i
~;
A Work has been done by our own staff, by i
0 Sargent & Lundy, by Dames & Moore and by Thatcher 1
{l Engineering.
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G You say work has been done, i
Is there-currently-any work being done?
E.j A
'The revised pile driving procedures that 9
.i are part of the QC Manual are going to their final i
E' iteration.
n O
By whom?
A By NIPSCO nuclear staff at the moment.
We will'need to go back for approval by the other parties.
O The other parties being?
A Sargent & Lundy.
i O
Dames.& Moore and Thatcher?
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A Right.
4 Well, that's an ongoing activity, then,.
.n of the NIPSCO nuclear staff.
A-To that extent, yes.
O' That's 1
a leview of the pile driving
_"._ pr oc ed ure s.
.?.
A It's a modification of the pile driving 4'
[ procedures to accommodate the SER.
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0 "SER" refers to what?
- t-l A
Sa fe ty Evalua tion Report on the piles.
i 5
0 That's the document that was issued by the
{NuclearRegulatoryCommission staff on March 5,
1981?,
1 i.
A
'Yes.
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- ~
i O
Is the nuclear staff review of those
- modifications the last step in the process of
-x completing the update or the modification?
.:i A
No.
2, -
I As I stated, what we are doing will have to be reviewed by the other parties involved, Dames &
Moore, Sargent & Lundy and Thatcher.
0
.Do you know how long it will be before the
. staff,.your staff, completes its review?
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15 A
No, hot my best estimate is one to two weeks.
O From now?
A Yes.
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G Who in your staff is involved in that?
i A
Mark Maassel.
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O He's the only one?
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A Currently, yes.
f G
How about yesterday?
A Well, he's the only one.
G The staff is reviewing procedures or i modifications that were prepared by whom?
i A
The procedures were originally prepared by i
7
{ Thatcher.
Ij 9
What do you mean by " originally"?
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A Delete " originally."
Procedures were ij prepared by Thatcl.er.
G Subsequent to the receipt of the March 5,
I i
l 1981 document about which you and I talked a moment I
ago, what has been done by whom with respect to modifying the OA/OC Manual and the pile driving procedures to satisfy the staff requests or positions 4
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16 Lindicated in tnat document?
rjf A
'IEcan.only answer in that we had a group r,..
discussion, shall we'say, between the parties involved I
and there were draftsLprepared by different parties t
l and submitted-to.the.others for review and approval.
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0; The groups involved were the same four that
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you mentioned?
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. R'i g h t.
E" I-: don't know-wh.t I -- nor if I had the
procedures'before me, I don't believe I could tell you
. : who prepared 'specifically what, but, obviously, it's i
j j all"part--of Thatcher's at this time because they are j their' procedures.
They would be their responsibility
- to-implement.
E i
5 G
We've been talking about a QC Manual and
- ; pile driving procedures.
. 3-I A
Yes.
G-Is that all one package?
A Yes.
4 It's the QA/QC procedures for pile driving that we're talking about?
A The~0C~ procedures for the pile driving, right.
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G As reflected in the QA/QC Manual?
A Yes.
G Who from your staff has been involved in that process of meeting and preparing drafts on those lProceduresother than Mark Maassel?
i A
Al Severance and myself.
G Do you have any expectation as to how long i
ij after your staff finishes its current review of those procedures that the other participants will indicate l their position to them?
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A I would be disappointed if the process t
wasn't completed within two weeks of our present i work.
G Which process is that, Mr. Bohn, the process iI of the other three reviewing it or the 5
A Yes.
1j G
Or the process of having a package of 5
procedures which all four pacticipants are satisfied with?
A The process of the other parties reviewing what we're doing within a couple weeks of the time we complete it.
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You said you'd be disappointed if it didn't happen within a couple weeks?
A Yes.
Q What's your expectation?
?
?
A About two weeks.
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0 I think you have had disappointme.:ts in l
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, terms of anticipated dates before, haven't you, Mr.
? Bohn?
y A
Many times.
G After all four participants are satisfied
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'. with these procedures, what do you intend to do with i
h them?
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A Nothing at this time, i
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l They must be available ior the staff or l
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in the inspection and enforcement division to review l
l in the field by the time pile driving resumes.
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j G
Do you know when that will be?
i A.
I do not.
,1 1
G After you complete who is the final, whoj I
makes the final decision on the acceptability of these procedures?
I A.
In that they would be Thatcher's responsibility, o
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', g-their procedures,,they.would have to be the ones
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to give the' final approval.
O Although', if you didn't approve of them --
strike that.
.)
After-Thatcher has approved them, do you-j
.[ intend to submit them - t'o the Nuclear Regulatory 1
' Commission.staf f ?
I' I
A No.
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.. G Why not?
C-
.A
.There is no requirement to do so.
3 O
Does NIPSCO evar do things in connection with j Bailly that it's not required to do?
Ej A
I'm sure we have.
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9 O.
How do you decide whether you do something
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$ that isn't required or not?
I
.A On the basis cf the information that you i
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j have on the specific issue that you'd be looking at at the time.
O What specific informatior. on the pile drivigg procedures leads you to conclude not to submit them to
.the--staff because you're not required to do so?
A The staff specifically said in their SER
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that theF3NQA/QC procedures must be ~ available in I@
the field'ati the. outset'of pile resumption,.to the bestlof my; knowledge.
G ;..
Andifrom thatfyou inferred that the staff L
ej did not want'to see them prior to looking at them k
{ in the field?
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A Yes.
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.Did_you discuss that with anybody on the i
L
- j staff.of the1 Nuclear Regulatory Commission?
Y A
I~ assume that that's been discussed in i
telephone conversations with Mr. Lynch.
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[
- j G-Have you discussed-it'with Mr. Lynch?
I
.A No, I have not.
7 E
G Why do you assume that it's been discussed 1 with Mr.~ Lynch?
[
A' Because there were several conversations
- i
. j held with Mr. Lynch after the issuance of the SER t
on what the specifics may be, and I would assume that'
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was_one of the things discussed, even though I'm not sure that it was.
G How do you know there were such conversations i
l with Mr. Lynch?
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21 A
I know there was because Mr. Severance had them at my direction.
O Did he tell you what was discussed with i
Mr. Lynch?
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5 A
I'm sure he told me in general terms at the i
- htime, yes.
I 0
You don't recall now?
?
A No, not specifically.
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0 Do you recall generally?
A.
Just that they had the discussions and, i
Ias far as I know, it's a clean SER, nothing that i.
i we're required to do other than the things that we've
! discussed.
3 O
Aside from your evaluation of the SER, what'
!.j do you recall Mr. Severance told you about his
' conversations with Mr. Lynch?
l 5
I j
A I don't recall anything other than that, I'even though I'm sure there were things.
l O
Whe.' did the process o f the group discussions and dra f ting of modifications to the OA procedures for pile driving start?
A Very shortly after the issuance of the SER.
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Was'there any acti'vity in that regard prior.to March 5',
1981?
.A'
-I don't'believe there was, no.
G
~Did you have any conversations with anybody g
.j.about. modifying lthe pile driving QC procedures?
N
~ _ " ~
.A ILthink we probably had conversatiens with
- -likeJSargent & Lundy, for instance, as this-is one a.
i chings we' recognized would probably have to i of'the e$ be done, but.we were going to wait for the specific I
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{wordingcin the SER before we were going to start i
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- 2.doing anything.
i that this was
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0 When did you recognize
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Li.probably something that would have to be done?
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'A I think 3.'s something that we've known I.l-'ever-since we knew the staff would have to issue a l-
- ,SER, that'there would likely be things in there that i.
j we would have to modify our existing program to accommodate.
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G
~ Existing program with regard to the pile driving QC procedures?
-A The procedures, yes.
G When was it that you knew that the staff o
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23 was going to issue a SER?
A I don't know specifically.
It's been some time.
G Approximately.
E A
Whenever the staff iss,ued a letter saying E
! that they wanted to complete a safety review; that's t been sometime back, I don't recall when it was.
I f At that time I guess it was obvious they would issue ka SER.
i O
When was the first such letter that you
$ have in mind, Mr. Bohn?
A I don't know.
G The staff said they wanted to complete a
. saf ety review of what?
j Ij A
Of the pile design.
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~
Q If I suggest that it was in 1977, does that i
refresh your recollection as to when the first such
' letter was?
l A
That could very, very well be what it was, yes.
O So ycu've known since 1977 that the staff was going to do a safet1 evaluation review of the
24 l:.
i-"
'e pile. design andLyou have known since then you were going to have to.do. modification of the pile driving l
QC procedures., is that correct?
A
'If, in fact, that is the date of the letter e
L
.@ yes.
I
{
G.
Do you have any recollection of when the staff wrote a letter to NIPSCO.saying they were E.
t-i going to do'a safety review of the pile design?
A It's.probably in the approximate time frame 2:that~you mentioned.
I have no,-I can't verify it for sure, but
%~".tha t's probably about right.
3 I-i j
Q Let me show you a document, Mr. Bohn, which previously'has been marked as Shorb Deposition I
5 Exhibit 2 in another deposition in this proceeding i.
and ask you to take a look at that document and see i} if it refreshes your recollection as to when it was the sta f f wrote to the company, to NIPSCO, and
. told it that it was going to do a safety review of the pile design?
MS. RAPKIN:
This is the February 7,
1979 letter
.s-to-Harold Denton?
c
o 25 THE WITNESS:
I don't see a date on here showing this is the letter to which you referred.
l By Mr. Vollen:
l i
i l
G The question is, Mr. Bohn, does that l
l l refresh your recollection as to the approximate time
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_' when the first letter to which you re ferred, of the
- staff writing to NIPSCO saying it was going to do i
ei a safety review of the pilings, was received?
j
)
A As I recall, the letter issued shortly I
f
} after this date referenced here as September 28, 1977.
-i I believe the letter came out not too long after
- l that.
~.
j 4
So, is your recollection now refreshed
~ and do you now recall that it was in 1977?
Ij A
I think so, yes.
5 O
When was the first time that you had any
}
1j knowledge of the proposed design of the foundation l of the proposed Bailly Nuclear Plant?
l A
1970.
I i
O What was the knowledge you had at that time?
A A preliminary design that was considered at that time was that piles would be installed under 4
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avy-s pa o F 5,
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26 the foundation down to glacial'till or be'drock.
G' Would you read back the answer, please.
(Answer read by reporter.)'
1 I-By-Mr. Vollen:
E E.
G By whom was that design considered?
A L
A ~
It was the design recommended by Dames &
IMoore to Sargent Lundy which, of course, is a
~
.i I contractor:to NIPSCO.
ii,
.O What did Sargent & Lundy do with that
~
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- 1 recommendation of Dames & Moore?-
i i
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' A.
They incorporated it as the preliminary i
! design in the preliminary safety analysis report.
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l 0
Sargent & Lundy did the preliminary safety 9
analysis report?
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[
A.
-They were responsible for its preparation, 5
l putting together all the input from the various I
s l'
! organizations and so forth, yes.
~
l G
That document which is often referred to as!
the PSAR was, in fact, submitted to the then Atomic Energy' Commission by NIPSCO, wasn't it, Mr. Bohn?
.A That's correct.
O Did NIPSCO, strike that.
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l
27 Did Sargent & Lundy then, in effect, make the:sameLrecommeniation to NIPSCO~about piles going to glacialitill or bedrock that Dames & Moore had made to_Sargent & Lundy?
A To the best of my.k'nowledge, yes.
4 G
.Did NIPSCO a ccept that. recommendation?
h A
As a preliminary design, yes.
i G
For what part of the proposed Bailly y-Nuclear Plant was such a foundation design preliminar.ly 1
jimade?-
r-A I believe~for all of the safety-related i
! structures in the main power block.
I G'
And at that time, didn't such proposed
' d e sign,. wasn ' t such a proposed design contemplated I
i
- } for the turbine room as well?
l 3
l A
The contemplated design for the turbine i
! room was for piles.
p Whether it specifically was included with
-the others'as going down to till or bedrock, I'm not sure.
It may have been or may not have been.
I don't recall that for sure.
O Let me show you a document, Mr. Bohn, which 6
l
. =.
s 28 appears to be a copy of a three page memorandum, ask you to look at that and see if it refreshes your recollection as to whether the preliminary design g
that you have described of piles going to bedrock or glacial till included the turbine room as well as
_" the rest of the portions of Bailly in the main power block.
i I
ij Show it to your lawyer first.
A Yes, this indicates that the turbine room Iu
- piles were considered as Class 1 piles at that time t
and we apparently felt that we would need NRC recognition, at least, that the piles would not go i to till or bedrock.
e t
e O
My question, Mr. Bohn, is not what does j that document indicate, but does looking at that document refresh your recollection as to whether the s
j proposed preliminary design in 1970 and in the PSAR of a foundation of pilings which would go to bedrock or glacial till included the turbine room; A
I would assume it did include the turbine room.
G The question is is your recollection refreshed?
l
29 6
e Do you recall, Mr. Bohn?
A Without looking at the PSAR, I would not, but I would assume MR. EI CHilO RN :
Don't assume.
Just answer his D; question.
i i
2 THE WITNESS:
A No, I don't.
By Mr. Vollen:
i e
!j G
This does not refresh your recollection?
f A.
It, in spite of counsel's advice, I will assume that that accurately reflects what's in the
- PSAR, but without looking at the PSAR, I don't know I
t
- that.
f G
What I want you to do is tell me if that a
reflects what's in your recollection.
What do you I[ recall?
5 A.
I don't recall that detail, whether or not I
j it was the same, the turbine room, as the other i
Class 1 structures.
I do not.
G Was there, did there come a time when there!
l was a change from the preliminary design of a i
l foundation of piles which would go to bedrock or glacial till to some other foundation design?
i
Y 7
30 A
Yes.
G When was that time?
A When was the I'd like to clarify the question in that you want to know when the change was
! made or when it was contemplated?
?*
O When was a that's a fair question.
It
.E was a confusing question.
My question was confusing.
Ij What was the next step in the proposed
- j design of the foundation for the Bailly Nuclear Plant i
after the PSAR was submitted describing the i
2 preliminary design that you've referred to?
j A
There was additional soils work done in I
i 1972.
?
G What was that?
What did that additional I
j soils work consist of?
A I believe there were ten additional borings I
j taken at the location of the, the actual final l
f i
location of the plant.
I G
Do you know what the results of those en additional borings were?
A The conclusion of the analysis of the ten borings indicated that the materials above the glacial C
31 till were very competent or dense materials and that it would be difficult, probably, to drive piles through it.
O By whom was that conclusion reached?
A By Dames & Moore.
I r,
O When?
l 5
A In 1972.
I.;
O What did Dames & Moore do about that 0
i conclusion, Mr. Dohn?
l A
They sent it to Sargent Lundy and I believe
.i
- Sargent Lundy put it in a report which was sent to i{ NIPSCO and subsequently to the staff.
I j
0 Approximately when was that report sent i
' to NIPSCO and to the staff, if you recall?
i A
I don't recall, but it was submitted for l some urpose in the hearing in 1973, I believe.
5 i
O The hearing to which you refer is what, j sir?
A
'c construction permit hearing.
O Before the Atomic Energy Commission?
A Yes.
O What, if anything, was done next with regard
m:
o, 32 1
i to the proposed-design of the foundation for the 1
Bailly plant?'
A Infl974, piles were driven and pile load tests conducted.
l R
' Now, betwee,1 the time that this report to pf G
'l I which you' referred a moment ago was submitted to" I
i
- NIPSCO and to the Nuclear Regulatory Commission staff l; and the time in 1974.when piles were driven, was
=
J there any change in the' preliminary or final design
[orproposeddesign of the foundation.for the Bailly r
(
plant?
l t
L
[
A~
No, I don't think there was.
i I
l i
G Do you know why not?
e C.
I i
A The pile design or, I should say, the I
E installation of piles in the field was far enough I
l away from taking place to allow additional work to i
! be done on which positive conclusions could be made, l
and that work that I'm referring to is the pile i
work that was done in 1974.
We didn't get our
. construction permit until May 1, 1974.
G But it was the 1972 Dames & Moore report f'
that concluded that it would be difficult to drive
,c-
,.,._m.
._m_,
-~,~.,--.,<,.e.
7
.o 33 piles through the materials above the glacial till or bedrock, correct?
A I'm not sure I have my reports I'm not I
! sure that I do not have the reports confused, but I E
E believe the 1972 report is the one that identified
,I b
the 3
competency of the materials, t
l
(.
O And the difficulty of driving piles through !
- those materials to glacial till or bedrock?
E l
{
A That's what I recollect, yes.
i Now, the next question waL, I'm sorry, I i
. didn't answer your last question.
I
?.
G I'll be right back.
1 (Interruption.)
By Mr. Vollen:
i G
Mr. Bohn, I show you a document entitled l " Report - Supplementary Foundation Investigation -
i
! Proposed Nuclear Power Plant and Cooling Tower, l Bailly Generating Station, Baillytown, Indiana for Northern Indiana Public Service Company," bearing the number 5676-005-07, and appearing on the cover the name " Dames & Moore," ar.d ask you whether that's the 1972 report to which you have been referring.
l d
a
r s'
34 A
Yes, I believe it is.
O Thank you.
When in 1974 were the piles driven and load tests done to which you referred?
E A
I believe in the spring of
'74.
2 0
What, if any, conclusions were reached from t
- that pile driving and pile load testing?
5 l
A The conclusions reached were that the piles
! founded in the glacial and lacustrine deposits would l
I provide an adequate foundation design.
i 0
Who reached that conclusion?
3 A
Dames & Moore, I believe, reached that 5
! conclusion.
!j O
Did they convey that conclurion to Sargent ig Lundy?
I
=;
A It was ultimately incorporated in a Sargent i! Lundy report.
I O
That was conveyed to NIPSCO, I take it.
A And to the staff.
O And to the staff.
Where physically on the Bailly site were these piles driven in 1974?
c
a 35 A
In the location of the Class 1 structures, roughly.
I I
O Within the excavation?
l A
There was no excavation in 1974 when that t
Ey started.
1 i
.)
O I see.
Okav.
i Were they driven before May 1, 1974 or after?
Y I
A l'm not sure.
There could have been some E
! before.
l t
l The work started maybe in April, and I'm not i
}sure whether there were actually piles driven before ijthe May 1 date or not, but I'm sure there was work jstarted in the field before May 1.
I 0
How many such piles were driven, approximate ly?
i I
.j A
Six or eight.
t O
Were the load tests done on all of these l.
I that were driven at that time?
h A
Let me explain just a little bit more.
u 1l.
There were six or eight piles that were I
! driven as test piles.
There has to be piles driven
!around test piles for anchor piles.
I'm talking aboud I
i
' test piles only, not anchor piles.
c i
i a
-e
_s a
36
?
'Your-question was, I'm sorry.
4 Miss Reporter.?
I (Question read by reporter.)
THE WITNESS:
A I believe all the. test piles l were load tested.
i By Mr. Vollen:
t O
Did th'e conclusion f rom these 1974 tests i
I
.. ~
j-that piles founded in the glacial lacustrine deposits
-5g would provide an adequate foundation also confirm i.
l the information that it would be difficult to drive 1
5 piles to the glacial till or bedrock?
a.
.~
i
'j A
Yes, it did confirm that.
However, I am
- t positive that those i precise words are i s.
'eport.
4-i
[
g I use the woro fifficult," Mr. Bond, E
because I think you did when you first were describing i what was in the 1972 report.
?
Can you. explain a little bit :aore about what you mean by "dif icult"?
A By " difficult" in this particular context -
I mean,-perhaps I'm practical.
It was extremely difficult and perhaps I'm practical, I'm practical
+
m 1
A~2,s NJ,"- :
j[
.qd ;
<c 37 s
because. the. materials are: so competent'that_you may-damage the piles.in tryingLto~ drive them through it.
y;
=
G-
-Would you say that the two reports that we've been discussing indicated that-it would be ll' impossible to drive the piles to_ glacial till or 2
]- bedrock?-
5 1L -
.I'm reasonably _ certain that the word i
i " impossible" is not used.
s
- d' G
Right.
1, u
Even though the'words are not used, to you
)i as an engineer orfto you as the manager of the il NIPSCO nuclear _-staff, was the conclusion reached
.j ~from those_ reports that-you couldn't use, that NIPSCO i
couldn't'use a-pile foundation that went to bedrock i-for glacial till?
.i l
A
. Utilizing impact hammer driving only, y e.a.
-i O
One more second.
Excuse me, please.
(Interruption.)
By Mr. Vollen:
G
-Mr. Bohn, I show you two documents, one entitled " Pile Testing Analyses Bailly Generating Station - Nuclear-1 Report Prepared for. Northern
s.
>, e %.;
g
- ~,.
l 38 Indiana Public Service Company, Report SL-3109, (September. 16, 1974," bearing the name Sargent & Lundy, Engineers, Chicago.
The other ~ is entitled " Supplementary
- h. Foundation Evaluation
.Bailly. Generating Station -
.)^
-{ Nuclear-1 Report Prepared f or Nor therr. Indiana Public i
' Service Company, Report SL-3130, dated September 16, I'
[1974," also bearing the name Sargent & Lundy,
~
gEngineers, Chicago.
u
.f I ask:you whether either or both of those s'
}-documents together are the 1974 report to which you i
j' referred in your testimony a few moments ago.
2 l
.They are both reasonably thick documents,
- Mr. Bohn.
Do you want to take a few minutes and...
}
A Please, if I might.
G dure.
i
~!
I don't.want to interrupt your review, Mr.
.Bohn, but I want to remind you the question is whether those either individually or together are the 1974 report to which you referred.
A Yes, they are.
4 Thank you.
b n
l l
39 What, if anything, next happened with respect to t he proposed design of the foundation for the Bailly Nuclear Plant?
A These reports were transmitted to the s ta f f,,
S E as I believe I've already stated, and we discussed 4
l with the staff the content of the reports probably l
[ by telephone, even though I'm not sure of that, i.
- had a meeting with the staff and sat down in a head s
to head meeting and discussed the contents of the
- repor ts.
k h
G When was that, approximately?
a A
It would have been, I believe, in the fall i of
'74.
s l
G This was after the Atomic Energy ( 7mmission ghad issued a construction permit to NIPSCO?
d A
Yes.
1 2
2 I think the first meeting we had with the
, staff was probably earlier than fall, like, I think, I
I perhaps before this final report was issued, in other words, before the September 6 date.
I think it may have been like July or i
someplace in there we had a first meeting with the l
-e. 3 si 40 staff.
I ~ think'it was earlier than the final report.
^
Were any conclusions with respect.to the design of the foundation for the Bailly' plant reached L
as a result of this meeting or these meetings with l-~thestaff'in1974 to which you've just referred?
i h
A No.
i 0~
What, if anything, had been done next with
!.;. respect to the proposed design of the foundation for
- g.
a the Bailly~ plant?
Iu
{_
A
~ The sta f f had several questions about i.
- information contained therein.
i G
Therein Ij A
In the reports to which we're referring.
o
.I.
O The 1974 Sargent Lundy reports?
i E-A Yes, and I don't recall whether we had
-E O
- *provided answers to those questions or were in the s
s i process of generating answers for those questions.
think we certainly answered some of them I
at least, if not all, before we were shut down in October of
'74.
O So these meetings that you've been referring to occurred before October of 1974?
4 m-ie ii n r i
',0 41
- A.
II'm sure one of them did.
I'm_not,sure there was more than one, but I know we had at least one and I1believe it' occurred b' fore October _'74, yes.-
e As I mentioned, I think July or something
,y like that.
k G
When-you refer to being shut down in July E-of
'74, are you referring to--the court order, the a
ii effect of'which was to halt the construction of the
$[ Bailly plant?
3.
A Yes.
1 O
Subsequent to that court order, what, if Ij anything, happened or-was done with respect to the
-!j. proposed design of the foundation for the Bailly
?
plant?
j i
'5 A-It was our understanding from the meeting 5
with the staff that we would be required to have a I
i hearing on the short pile design if we pursued it.
I O
What meeting was that, Mr. Bohn?
-A I believe it was a meeting in the fall of
'74, I'm not certain.
O Who had that understanding?
A Those of us that attended the meeting with C
l-
7 0
42 the staff.
O Who were those?
Yourself?
A Yes.
G Who else?
8 A
Our attorneys.
i G
Who is that?
A I believe Bill Eichhorn was involved.
I'm
?
ij not positive whether one of the Washington attorneys.
I was involved.
i It's my recollection hat there was one 3
' of those involved.
G Is that Maurice Axelrad?
A I'm not certain.
I O
Someone from his law firm?
I I
i A
Yes.
I think so.
5 I'm not absolutely sure there was someone Ei there from that staff, but I think so.
I believe 4,
I s
i John Dunn and, I believe, Mr. Lyle.
{
l G
In describing the understanding, you referred I
i to a short pilings design.
Is that the foundation design in which i
the pilings would be founded in the glacial lacustrine i
1
43 i
deposits to which you referred before?
1 A
Yes.
O For convenience of reference, when you use the phrase "short pilings design," -- and I do
!well understand what we both mean -- is that okay with i
l n
c
- you?
l f
f l
A Yes.
I I
O And when we use the phrase "long pilings," l j can we understand we are talking about pilings that
[would go to bedrock or the glacial till immediately i
f.above it?
?
I A
Yes.
O Do you recall what the basis was for your i
I understanding with the staff that you would have to i
jhave a hearing if you pursued the short pilings design?
s
- j A.
Generally, I believe there was a discussion aljabout the preliminary design in the PSAR about the i
l safety evaluation report which indicated that the I
i l; staff would follow the design during conotruction, and it was our feeling that the staff felt because i
l of the highly contested nature of the proceedings to 3
I i
l
u.
S.
_44
.w
- g7 ~
7
+
date'that itlwould require a hearing for this change.
.Who_was-there.for the staff, Mr. Bohn?
o Ge*
p
'A I believe, I will.further expand on.the previous question first, if I may.
O How'about if.you expand on the answer;
,';I'll' expand on the questions.
- L A
I'm sorry.
i The conclusion that was reached and that
<jI mentioned was one that we arrived at, NIPSCO arrived
.E l
l --
at.
i
^
~;
O I understand.
3 A
I don't know.that the staff necessarily 1
i ~used those specific words, but that was the 1
L
) conclusion-tha t we arrived at.
I. '
E Now, would you repeat the question?
k-G I think the pending question is who was at j_
l this meeting from the NRC, excuse me, I think it was still the AEC staff.
i.
A It was the AEC staff, yes.
I-don't recall.
I'm reasonably certain Dave-Lynch was there and I assume, well, I won't assume,.I don't'know.
I'm reasonably certain Dave O
pg
,=
p 4 5l
.N
- Lynch was there andlI, don't: recall others.
nG.
Do'Lyou think there was a~ lawyer from the:
i
' staff there?
. A..
-I' don't'know.
l
..They'usually do have one at those types r
Li,.of. meetings,-but ILdon't know if there.was or not.
a E
i e
i E
G Stuart'Treby there?
5.
L A
I don't know.
1 i
d j'
0' What, if anything,. happened next with i
V
- 7) respect.to the' design of the foundation-for the
- Bailly plant after1you had this. meeting where you L
-e formedEthe. understanding! that you'd -have to have a 2
- .i. hearing if you made the change to short pilings?
l f
A In evaluating the time it would take in i
i t
L i=our.-opinion to have a hearing, we determined it was I
t'
-l not in the company's best interest to go to the short I
l pile design,.so we proceeded in 1975 to determine what the most expediti~ous and practical way would l
t j
b'e_to install'long piles.
f.
0 How did you go about that exploration?
A.
We retained Thatcher Engineering to come onfsite and attempt a number of different ways to o
I h
.,e,
--r r,e-,-3 y tv y
-.w,-v-
--,-r v---,,r
- 5
y.
.m
~
46 putDdown.long piles.
0; You. retained Thatcher to do that and d id,
r~
in. fact,-do it?
A.
Yes, they.' installed,-I.believe, eleven piles.
O.
When?
X" A
In 1975.
.I don't recall what part of the 2
- year.
i Ij 0
Those were all long piles?
e 3
A-I believe they were all long piles.
i iW-0 What methods did.it try to use t'o do that?
e 3
FL A' combination of methods using vibratory L
. hammers, impact-hammers, drilling, jetting and
- j. combinations thereof, in other words, combinations t
c 3-; of different hammers with jetting and a combination
?
tI of. drilling w'ith jetting.
Ec L
O What, if any, conclusions were reached as a 1-j result of that-activity by Thatcher Encineering?
~
t A
The conclusions were that the soils, the glacial lacustrine deposites were, indeed, very dente i
and verified it would.not be practical to drive piles'through it, that-the most efficient way of installing the long piles was using a combination of a
p
.(
21; 47 s
e e
w 3,
a vibratory hammer'and jetting-until you reached' approximatelyfthe. foundation or bearing' level, glacial till,:and use an-impact-hammer for the final
'se t: on the pile.
t v
f G
Do_you remember when in -- was it in 1975 1
h!
--fthat those conclusions were reached?
N
- [
A IJbelieve so.
0 1
I 0"
Do you remember when in 19757
/
0 :-
A' I really. don't.
y MS. R A P K I ti:
I'm sorry.
I.didn't catch the I
year.
'75.
)
0~
By whom were those conclusions reached,
.' Mr. Bohn?
A Again, by Dames & Moore in conjunction with l Sargent & Lundy and ourselves.
i G
What, if anything, did you ?.o about those l
conclusions?
A I believe a letter was submitted to the staff saying that we would no longer pursue the short' pile design, and-I don't recall what else we
-said-in that letter, if anything, but I know we did a
Y er a
k s
~
48 H
'the' review of the short pile design.
__ Q.
-Do.you~ remember when that letter was sent?
f:
4 A
No,'I don't.
- 0. '
.And.the staff' review of the short piling design-to.which you just referred, was that essential ly
~
i lafreview-of-the.two1974 Sargent'& Lundy reports that i-we identified-earlier and which you said were discussed I at head.to head meetings-with NIPSCO staff and the i
AEC. staff?
h
.A Yes,-I-believe we had also submitted some i
f-additional information'in response to some questions H
- that'they-had had.
- . :j G
And you believe.this atter from NIPSCO E
i to'the staff withdrawing the short pilings proposal i
j was in 1975?
5 l
j A
To the best of my recollec tion.
I really
. { don't have a good handle on when that was done.
.G Why don't we take a short recess.
(Whereupon, a short recess was taken.)
MR. VOLLEN:
Back on the record.
O Subsequent.to the letter that you r ef erred
Gd:
' u.:
49
~
to,'Mr.1Lohn, to the'AEC staff in which NIPSCO withdrew-its short pilings proposal, w at happened next with respect to the design:of the foundation of Lthe Bailly plant?
o
.9-
- A.
We31., in view of the fact that we were
~ s
[ shut'down for a considerable period of time there f
[ and. engineering, of course, was stopped during that z.
- period also, the-next-thing that I recall is we the staff in December of 1976 the jetting j; submitted.to 0
I
'. me thod i.wi th the proposed driving criteria.
j j,
i G
I'think that was. December:of 1976, Mr. Bohn i
i i
s.j A
.That's what I recall, yes.
l-
. ~
show you a document purporting to be l
.)
'O Let me
?-
i a letter from NIPSCO to the Nuclear Regulatory i
!' Commission dated December 29, 1976 and ask you if 5:
that-letter e Sles you to have a better recollection i! or a different recollection as to when NIPSCO informed I
the staff that it was withdrawing its short pilings l
. proposal.
l Let me show it to your lawyer first.
I I
A This would indicate that we didn't formally, I
- Jvise the staff tha t we would not pursue the short i
\\
)
4 4-47,
,-n
y.
7
- c 1cv
-50 4
I
,y p il e s -.un tili December'29, 197f.
G Is that document the. letter to which you
. referred. earlier when:you-said that NIPSCO sent the staff'a let'ter withdrawing the short pilings proposal?
JL
.I thougnt;we had submitted something earlier d.
I i than.this telling them we'were-withdrawing
'he-5 lI short;pi'.ings proposal, but in reading this letter
- I-apparently--was mistaken.
N O
So your best recollection now is that that hletter,- the December. 29, 1976 letter, is the one
!* withdrawing ~the short pilings proposal?
I g4
)
A.
Yes.
j.
G Now, between the time that Dames & Moore 9
' and Sargen t & Lundy and NIPSCO reached the l
.I.{. conclusions based upon Thatcher's driving of the E-1 eleven test piles in 1975 to which you testified a.
s l
9 i few~ moments ago and the sending of this letter on
-December 29, 1976 in which NIPSCO withdre'.: the short pilings proposal, what, if anything, was done with
-respect.to the pile design and the design of the
-foundation of the Bailly plant?
A Very 13ttle in that we were shut down, we l
i 1
6
-n.
e -
w
,o w
4
[g _
42 51 l
d.
? stopped our engineering effort for a considerable period of time.
O What-was included in-the "very little" that
-was done during that time period, Mr. Bohn?
l A.
The' letter of' December 29'to the staff k
-[ withdrawing the short pile design and substituting
~[. therefor the long~ jetted pile design has criteria I-I attached to.it and it would have, one of the things
- 8s that woulduhave been going on would be the developmen 5
of those criteria,-but it would not have been a major 8
iI' amount of' work.
{
- O I think for convenience we'd better mark I
E this.
I ask the reporter to mark this Bohn Deposition
.i Exhibit 3 for identification.
i.
- i (Whereupon,'the document above
'5 referred to was marked Bohn 1
t l-i Deposition Exhibit No. 3 for identification.)
MR'. ' EICHilORN :
Is that the 12-29 letter you're marking as 3?
By Mr. Vollen:
l O
Do you recall who was involved in the t
i
y e
n:..,
7,;.
r:-
52.
-3q e
'#' l development of the'criteriasto which you just-referred?
A.
Onlyfso far as organizing, I'm sure it would have been Dames &EMoore and Sargent Lundy.
I-a don't recall : individuals.~
11" O-Was theLstaff of the, I guess by that time E
$ Lit :was the. Nuclear -Regula tory Commission, involved in
.that process?
mi A-
'In the development of the criteria?
- u i
5 G
Yes, sir.
m l
.A
.No.
O-To what extent, if any, was the staff
.
- of NRC apprised of what it was NIPSCO and ite
?
E contractors and subcontractors were doing during t
ij this period between the conclusions reached as a L
result of the. pile driving in '75 and the submission
'9s of December 29,-1976 letter?
-A What was the staff informed that we were doing?
O
.Yes, sir.
A I believe they were aware that we were y
basically shut down as far as engineering goes and were vw
b-p g
9 4m-
-*m--
y--r.
-y,,
,m--y
bx
~.-
1 53
~doing:very little.
1 0
When_you say " shut down as.far as engineering 4
~
_ oes,'" is that on. the entirei projec t or-just on the g
design.of the foundation?
A It would have beenLon the entire project.
i i
h 0
And that was as a' result of the court order?
A.
Yes, a result thereof.
I don't mean to imply that the court order 5
s directed engineering to be shut down.
I'm saying 1-
$.that we directed. engineering to be shut.down as a
, E
- resulttof the court order.
- 5~
G I. understand.
1
(
Other than the development of-the criteria,
' was there.other engineering going on, other design
- 1, E' activity-going on
.5.
in this time period that we're
- talking about?
A.
.I don't believe there was any e ngineering going on during that period of time that we're discussing at the moment.
G.
My secretary should be back with the copies of those documents in just a minute.
Was the development of the criteria to O
.-.-,,-.,.wr e
- nEs v
I 54 which you_have referred based.upon'information which was'already_in the hands of NIPSCO, Sargent Lundy and. Dames J & Moore?
' A.
-Yes.
g i
G LSo th at Eduring' 'the period that we're.
. l.-[1talkingabout from the reaching'of the conclusion 4
l based on the Thatcher pile driving in '75 until
' I.
' ; December of
'76, no new tests or borings or pile 3e driving was done, is that correct?
5 1
1L That's correct.
2 Q
'Just one second.
. f Off the record.
Ii (Discussion had off the record.)
By Mr. Vollen:
i i
5:
0 Mr. Bohn, I show you a document which the 5
- reporter has marked Bohn Deposition Exhibit 3 for 5-3 i
i identification and ask you whether that
's the
' December 29, 1976 letter from NIPSCO to the NRC staff to which you and I have been referring in this deposition this morning.
A Yes, it is.
G And are those criteria to which you l
-,-r
- - O #
9:."
~
.)
~
55
-s.
referred.in'the two page attachment to1that document?
A--
Yes.
h
.Mr.
Bohn, why was it not until December 29 h1976:that NIPSCO-informed the staff that it was
.i.
-3. withdrawing thefshort piling proposal if NIPSCO's l
. ; conclusion. to do :so was based on the Thatcher pile l
'i -
.. driving' activities carried out in 1975?-
-i thi's litter would have been in the T
A
- Well, 1
1
[-month following the Supreme Court decision and prior
'l
- ' to the Supreme Court decision there was nothing that 4
L
.! w e could-do.
-j~
As I previously said, our engineering was shut down and I'm cure our staff was aware of that.
.i
{
4' Over.what period of time were the criteria i-5, L
contained in the attachment to Bohn Deposition L
E
-.. -!~ Exhibit 3 developed and prepared?
o
.A
-I-don't know.
O Approximately.
A I.really don't know.
1 1
I don't recall whether it was done immediately prior to submitting the letter or whether it had been o
m e-e
-y-m' e-
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.-,-a-e-
a
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l 56
~
n
.-4 done back-linJ'74 and-just'hadn't-been submitted.
I Edon't recall 1when--that was done.
-0 I see.
Were ~ there, tua your knowledge, informal communications from-NIPSCO to the staff prior to this i:
".Bohn-Deposition Exhibit 3'in~which NIPSCO informed 5
' the staff of its intention to withdraw the short 5:*.
'; pilings proposal?
?'
A
-I'm sure there-were telephone conversations 6
yduring that period of time with the staff, and I
~
L would assume that we had made them aware of that 2:
5{'during those-conversations, but I'm not positive of
'i'that.
e 2
O'
-Who is F.
G.
Hiple?
e A
He's-Vice President of Electric Operations 5.
j
] for NIPSCO.
z 1
O Is Bohn Deposition Exhibit 3 signed by him?
A Yes.
O Subsequent to 1-A Simply because Mr. Lyle was unavailable at this' time to sign it, I believe he was in F'.orida on c.
vacation at the time.
4 i
s i
"M.E q
4
- v..
~
57
.. s -
Y1 G
.In. December of 1976?
i A.
Yes.
- 0. -
. Subsequent.to the submission of Bohn Deposicion
~ Exhitsit. 3'Uby:NIPSCOLto the NRC staff, what next l.:happenedwithrespect to--the design'of the foundation
- $..of-the Bailly plant?
l c!
A..
We had advised them in.this letter, last
- paragraph, when we. anticipated that pile driving C
!- 5 would begin that this -- we had pursued with them 4
! more.than once, several times, I don't know how n
r
=
.= many. times, from the time this was submitted until 4
l
. {;the time that we were ready to install piles by the V
! jetting method that j
we were proceeding with this
' L method ~and'was interested in any comments they may s
i i
j have about the method, and we never got a reply from
- 2
- Lthose inquiries.
i L
i 0
-You said-from the time you s ubmitted Bohn I:
?
~ Deposition ~ Exhibit No. 3?
?
lj.
A
'Yes.
g Does Bohn Deposition Exhibit 3 contain
.information to the staff that you prepared to install the piles with the jetting method of installation?
j i
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l 4
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3
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Yes.
4 10 Uhere is tha*. contained?.
A In E the ' l~etter. 'i tself.
Was that,the-question?
O
- E
?Anywhere in Bohn Deposition Exhibit 3,
which i
} is both the letter and the Attachment 1.
- 5
.A
- First paragraph of'the attachment says, 5
E-j "The long: steel piles will be driven using a vibratory i
impact-hammer'in combination with jetting."
Is that, Mr. Bohn, the first time that t[NIPSCO informed the staff that it proposed to install i
'.the piles with a jetting method?
!j A
'I believe it's the first time ~we formally
=I advised them of that, yes.
We may have had previous i5 informalLdiscussions with them, I'm not sure.
E.
O When, if you know, had NIPSCO decided that i! it wanted to use a jetting methoC of installing the piles?
A After the conclusion of the 1975 tests that
-w.re run.
O By Thatcher?
A By Thatcher.
d i
a
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~
.: g '
59 s
~*
4
-Do you remember approximacely when those tests were run and when'the conclusic's.from them K i-about what'you've testified were reached?
A. -
'I'm sorry,.I-d'o n o t'.
ll..
.ILwould assume ~that it was in the warm R:
,' weather months because I don't' recall it being done
> under adverse weather conditions, but I don't recall.
. ?
5
. j G-At.this time, December 1976, under what part ejlof the'Bailly Nuclear Plant were you proposing to
~
iu i install long piles using the jetting method?
'1; A1 The Class'l structures of the main power
' plant.
I
~4 IWha t-were the Class 1 structures of the 3
o; main power block at that time?
I j
A-Reactor bu ilding, auxiliary building, i
} service building and rad waste building and off gas 1
filter building.
G But not the turbine room.
. A. -
Not the turbine room.
G What led to the change from the turbine rcom being included as a Class 1 structure to it being excluded f rom t he listing of Class 1 structures?
(
- e. MH W M9
'+%
+
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rl
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.60
{
s i
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co A
The1 ins'tallation of a third main steam' isolation-valve.
O AtLleast,'the'--
k, The-commitment to install.the. main steam-e..! isolat' ion valve' i"'
4 When was that commitment'made or when was j-
[ the decision to install that third main ' steam isolation
- 1. I
. ;l valve made?
s A
I don't' recall that.
-}
h G.
I ask the reporter'to mark this three page t-memorandum _as Bohn Deposition Exhibit.4 for identificttion.
(Whereupon, the document above r
referred to das marked Bohn i-
}
Deposition Exhibit No. 4 for 9-identification.)
i
. k.*..
By-Mr.Vollen:
Mr. Bohn, I~show your lawyer who I think will_show you the document which the re; sorter has just marked Bohn Deposition Exhibit 4 for identificat:.on and ask~you if you~can tell me what that is.
A les, I reviewed the document.
s
. L s.E M 4. -...~.--
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w
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i 61 G
,The~ question.is'can you tell-.me what it is?
A I believe it's a memorandum-that Mr. Lyle
.made afterrhe and I'had discussions on the matter
~
contained in that memor'andum.to be put in.the file.
'l Does Mr. Lyle's name appear in that memorandum?
.. g A-No, it does not or, at least, I didn't notice
~
if it does.
L ii G
'What makes you think it.was prepared by i1. Mr. Lyle?
5' ll A.
It. starts out saying, "This memorandum of t
5 November 15, 1976 is an update of one that R.
J.
1 Bohn and I prepared," so obviously that's not
!; prepared-by me and I recall having discussions like 3
i this with Mr. Lyle.
.i.
E.
.I would assume it came from his file.
x
.E O
All right.
5 l
Let me direct your attention to the last page of that memorandum --
A.
Which contains my initials, that's true.
G At the lower lefthand corner of Page 3,
" R. J. B. " a re you r initials?
A.
Yes.
4 I
' ll
.9 c -,
e
. :e -
i 62 h
L-9 t
O Those,are followed-by'some other initials,
' " V. I '. T. " 'Who-is V.L.T.?-
7 A
That'was'my secretary at that_ time;
.G
'What, if any, light does-that cast-in;your
[.mindlabout who prepared the document?
E A..
None.' 'It doesn't change my previous z.!, statement.-
ra f'
.You believe that Mr. Lyle prepared this?
s.
.?-
A Yes.
.Y.
.It.was.obviously retyped:by my secretary, I'butI be'lieve it was prepared by Mr. Lyle.
tif G-Does'Bohn' Deposition Exhibit 4 refresh your
[ recol'lection as to when NIPSCO decided to commit to
-1'
,t
..j adding.a. third main. steam line isolation valve and i
i I
j to thereby exclude the turbine room from the listing 4
8
=
~
- -of' Class 1 structures at the Bailly plant?
-l.
_j' A.
It was apparently prior to November 15, 1976.
O Do you remember how much prior?
1 A:
I do not.
G Do you remember what the considerations were which led NIPSCO to make that dece
- n?
-A Considerations that led to the decision to 1
=
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g,
.9;;
,o e 63
-put-in the' third MSIV7
.O Yes, _ sir.
- A It'would certainly be in the utility's
-best ! interest to-keep any-building from being a j Classi1 structure if they could, and if installing
.I
[ -a third valve removed the' entire turbine building iI from.being a Class l' structure, it would be the e
=
_'i_ proper' thing to do in my opinion.
s 6
,?
O Why.would it be in the utility's best 1>-interest to keep any building from being a Class 1 i; structure ~if it could?
A Because all of the things that are applied,
=. ] all of the regulations, et cetera, that are applied 3
0
- to a Class 1 structure are not applied to a structure 1
- { that is not Class 1,
not safety-related.
..E C
0 So there would be fewer safety criteria with i
j which a company had to comply to fewer portions of
~its buildings that were Class 1 structures.
A Yes.
G And that would be in the utility's best interests?
A Economically, yes.
61 i
J
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w -.
g
_~,
.,y
7 64 G
Did NIPSCO go to the NRC and get permission to use short piles in the turbine room as is indicatect the author of Bohn Deposition Exhibit 4 believed?
A You dov< t need to go to the NRC for non-E safety-related structures.
t G
Did NIPSCO go "o the NRC to get permissich i
5 to use short piles in the turbine room?
?Ij A
Only to the extent that it's reflected in this letter, in my Deposition 3.
c l
D Deposition Exhibit 3?
t; A
We made them aware of it, yes.
,I G
And that's the first -- did NIPSCO seek h
j permission from the NRC to add the third main steam i
- isolation valve?
1 i
A.
No.
l 1
O Now, subsequent to the submission to the
- I lNRC of Bohn Deposition Exhibit 3,
the letter of December 29, 1976, you testified that you did not hear from the staff with regard to ycur proposal to use a jetting technique to install the long pilings, is that correct?
A That's my recollection, ye:-
i l
65 O
Why did you want to hear from the staff?
A Lecause one of the items referred to in the safety evaluation report that they would followdurind construction, we wanted to make ure that they were i doing that.
i j
O Did you assure yourselves that they were I
.~.
!doing that?
?
A We attempted to.
f G
And did you obtain the assurance that you
! were seeking?
i; A
We did not.
3 0
liow did you attempt to obtain that assuranco?
A.
By discussing with them from time to time
! on t he telephone that we were still proceeding along 7
[this line.
l 7
O Who is "them"?
Who did you talk to?
A I don't, I would assume that the conversations E:
were with Pave Lynch.
l G
You didn' t have them?
i, A
I don't believe I did, no.
O Who did?
A At thet time I think it would have been John 6
e
I o
f 66 I
I I
Dunn.
0 You think John Dunn was talking to Dave Lynch saying are you following, are you reviewing our jetting proposal, or words to that effect?
i A
Yes.
?
2 Q
And what do you understand that Mr. Dunn iI received in response t<
his question of Mr. Lynch?
?Ij A
To the best of my knowledge, we never s
! received any comments pro or con.
la There was no positive feedback, no negative I
F feedback.
It was something we knew they were aware
- fof, and as far as t a knev they were not doing
!anythingabout it.
F O
And what did you do?
Ij A
Further down the line in 1977, we advised
- i. them when we were going to start with the jetting l process and I believe invited them to come to the
-I' field to coserve the process.
G When was that?
A I don' t recall.
I would assume it would have been summer of
'77, keeping them apprised of how the pile driving was going under the turbine r o o m;.
d 6
e
-W
a 67 O
How was the pile driving going under the turbine room?
A on schedule, essentially.
O When did it begin?
l A
I believe June of
'77.
O And that-was the driving of short piles,
?:* was it not, under the turbine room?
Ij A.
Yes.
f G
And those short piles were driven or installed without jetting?
5 A
That's correct.
i; G
Was it completed on schedule, the driving
- .j of the turbine room short piles?
A Cssentially, I believe.
It may not have i
i been right on.
I don't recall what the exact schedule was, 4i l but it went along about as we had anticipated it would.
i l}
G Then later in the summer -- was it after i
you completed driving the short piles for the turbine room that you invited the staff to come out and see the pile driving of long piles with the jetting method for the Class 1 structures at Bailly?
c
~
'E C
t i
68 A
I'm not certain.
I think we were keeping them apprised of the progress of the short piles.
When we anticipated I when the jetting would commence and when we had a
!finaldate on the commencement of jetting, we made 3 them aware of that.
{
Q Did they accept your invitation to come out ?
i_
i A.
They did.
G.
What happened?
k A
They observed the process.
.i l
0 What, if anything, did they do after they i
! observed the process?
!j A
They apparently had concerns about the 9
l process because they requested a few days la te r that i{ we discontinue installing piles until we had further 5
l input from them.
i i
2 0
And that request that you discontinue driving was in September of 1977, was it not?
A Yes.
O What did you do in response to that request?
A We stopped jetting.
O Why?
o 1
69 A
Because they had directed us to do so.
G Then what happened next with r espect to the driving of piles or the design of the foundation for the Class I structures at the Bailly plant, Mr. Bohn?
E E
A Subsequently they issued a letter, I
,x
- believe early in October, saying that we should not
[ continue the process, and I think they also at that i.; time mentioned that they would conduct a safety review.
h G
That letter was confirmatory of oral
.r
[ advice given to you in September, is that correct?
i e
A Yes.
I y
I don't know that the ora] advice said E
anything about safety review specifically, but the
![ letter did.
I l
G Who gave you that oral advice?
i i
A I don't know.
I was out of town at the tite.
L li G
Who told you about it?
!o
)
II A
As I recall, I was informed by John Dunn ll by phone that this had happened.
G After you received the confirmatory letter, what, if anything, did you do about pile installation l
o-
-o 70 or pile design?
What happened next?
A We proceeded to submit additional informati on
.o the staff to attempt to convince them that this was a satisfactory method of installing piles and dia
- that, that additional information, and then had at
"_ least one, if not two, meetings with them to discuss f
the process.
i i
Ij 0
What was that additional information?
E A
Their specific concerns on the jetting l
l process had to do with lateral support or loss of lateral support because of the jetting process and I believe we submitted additional information attempting to allay their concerns about lateral i
support.
.i t
I don't recall what the specifics of the a
3 information were.
1 i
G Was it test information based on newly i
done tests or was it information that you had generated by the previously done tests or pile driving?
i A
There was some additional work done, at i
i least an additional uplift test performed on a pile that had been jetted.
c
.... ~.
L
I-
~
s
'l I don't recall that there was anything else done on that.
O After you submitted this additional data information, what happened next, Mr. Bohn?
l A
The staff's concerns were still present i
," and major in our thinking about the lateral support
- of the piles during a seismic event, should one take E
i j place.
O Ilow was that staff concern manifested to yob?
Iu A
Certainly during the meetings verbally.
I I don't recall if there was additional fletters from the staff in that period of time or not, but I know the concerns were serious enough, as far
- I as we were concerned, that we withdrew the jetting I
i process.
\\.
0 The concerns that the staff had were serious i
Ci enough in what respect?
E A
In being able to generate the information that would be required to allay their concerns.
Our evaluation of their concerns at that time, and they were not our concerns, we thought then and think now that the process is absolutely good I
1.-
r
~'
72
^
I and-the piles were absolutely good and would be, but ta satisfy the staff's concerns on lateral support during a seismic event it was the conclusion of our contractors and conFultants and ourselves that it e
? would be necessary to probably take a t.1. e a s t one N
3 boring, if not more than one boring, beside each
[ pile after it was driven, which would require years i.; of construction effort and time, and we thought it i
would not be practical to pursue it.
O You and your contractors thought that the
.cl staff's concerns about the jetting method of i$ installation were unjustified, is that correct?
?
)
A Yes, that's correc':.
E O
Nonetheless, you withdrew your plan to l
install the piles by the jetting method, is that l correct?
i A
Yes, that's correct.
n O
Why?
A I've already stated that it wai our opinion that the time required to satisfy their concerns would have been far longer than going back to the shorter piles and pursuing that sort of thing.
e i
I
4 73 G
What time would have been required to satisfy their concerns. Mr. Bohn?
i A.
We don't know that.
It was our opinion
- I that it would have been probably years.
o.
B Before you could proceed to install such t
h 3 pilings, long pilings with the jetting method?
l 1
[
A.
I don't believe we made the determination
= separately of the time required to describe the methods 5
} to them, but rather as an overall period of time, fwhichwould include all the time after the piles I,
were driven to verify that, in fact, the lateral i support had been restored which, in our opinion, was Iy years.
?
O When did you, for the reasons you've i'
indicated, withdraw the proposal to install long piles with a jetting method?
i A.
I believe by Mr. Shorb's letter in December n
U of 1977.
i i
l l
G I ask the reporter to mark this document i
l as Bohn Deposition Exhibit 5 for identification, i
l i
il wg
l 74 (Whereupon, the document above referred to was marked Bohn Deposition Exhibit No. 5 for identification.)
g By Mr. Vollen:
E i
0 Mr. Bohn, I show you a document marked
~
$ Bohn Deposition Exhibit No. 5 for identification and I
i ask you whether that is the letter from Mr. Shorb j dated December 7, 1977 to which you referred a moment
$7 ago?
l A
Yes, it is.
tj G
What, if anything, next happened with
{ respect to the design of the foundation for the P Bailly plant?
f A.
We submitted the previous information that s
!wehaveon short piles a nd ran additional pile load
! tests to verify the competency of the short piles.
L l
0 Over what period of time did you do that?
A We started in the spring of
'78, I think, and submitted the information to the staff in
'78, along with additional responses to questions that they had, and, then, along towards late summer or fall of e
e
- M4
75
'78 they directed us to perform an indicator pile driving program, which we did.
i l
B And then what happened?
{
j A
on the basis of the additional information i i
c.; that we submitted in fall, late fall
'78, the staff
_fhad further questions, as I recall, which we 3
I
> answered.
i j
I think we answered questions on into, and 1,
I
! submitted additional information on into
'79, early i
i
'79, and we were well, period.
c O
And then what happened' i
j-I i
6 A
The staff continued to review the I
I t
j information that we had sent to them and about the l
i 1
e l
l I time that w e, thought, based upon telephone conversations l
I l
with the staff, they were ready to approve the design, we felt that it was very, very close to be 4
a J
i j approved in early
'79, and about the time we expected l 1
I o
i j
p it to be issued TMI took place, which we assume
'l 5
1 j
was the cause of termination of the review.
i 1
0 Then what happened?
j l
A.
After pursuing the matter with the staff I'
l q
t l from time to time in trying to determine what they i
i I
e
=
.g
=
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SK 3e p-76
..p=.',
,u
' ' (were doing on.the review and determining that
[
Lapparently.their_ reviewers'had been removed from'the-projectito".a other-things that were TMI-related and we.no tlonger had any priori ty if, in fact, we j had ever had any: priority to get v.he review complete, b staffEthen' indicated in the fall of 1979 that they V
.3 were going [to turn it1over to the Corps of Engineers s
l for review.bebause they didn't have the manpower-to i
it themselves,.which they did, turned it
'I_ complete v
y-over.to the. Corps of' Engineers, that i s.
t O
'Then what happened?
..a' A
We were very concerned about the Corpsoof j Engineers having to start from scratch on the review a
0; and taking another substantial period of time to l
I it g compl'ete a
5 To the extent that Mr. Schraer went in.and discussed.our project and-priorities witn Mr. Denton,
'which did not get it removed from tie Corps of o
. Engineers, they continued their review for another year or:so or longer.
.I don't presently know whether
---well'. period.
G-What don't you presently know, Mr. Bohn?
r c
k O8^N a
w w
v w
v, isi w---
w vn y-y, v
w.
w--y y
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v.
o.
77 A
All I know is we finally got the SER in March of this year.
G What don't you presently know about the Army Corps of Engineers?
f A
The SER, of course, is a staf f document.
1 Whether the Corps of Engineers had any
}
', specific input into it or were helpful in its
?
.; preparation, I don't know.
G Ever seen a report from the Army Corps of
.' Engineers about any review they did in connection t
[withNIPSCO's short pilings proposal?
I A
We had a couple meetings with the Corps of 2
Engineers.
We sent them volumes of information that ii we had sent to the staff.
We were aware that they
.i E apparently made at least one complete personnel 5
l change and started from scratch a second time.
i f
As far as having seen any specific review,
! conclusions, recommendations for the Corps, I don't f
believe we have.
O Did you ever ask anybody what, if anything, the Corps did by way of producing a report?
A It was discussed with Mr. Lynch.
I'm sure
e e
a 78
~
I don't know i. Se ever said what the C9rps had done specifically.
O Did you discuss that with Mr. Lynch?
1.
No, I don't believe I did.
2 O
Who did?
A It would have been Mr. Severance, I believe II at that time.
!Ij g
When is this?
A I don't know-specifically.
b I
O You said it would have been Severance at I
E that time.
What time did you have in mind?
i*
A Well, as I stated, the Corps began their hreview in fall
'79, so at that time time I believe 3
o
- Mr. Severance was the licensing supervisor that i
j would have been involved in that circuit.
(.
O In that circuit?
t 1
l A
In that relationship wid1the staff.
i O
All right, sir.
What else happened, what next happened with respect to the short pilings?
A The issuance of the SER in March of 1981.
O During all of this time, since September of
a a.
o 79 s
s 19 7 ~/, there was no construction under way, is that correct?
A That's correct.
O Why did NIPSCO not proceed to install the lshort pilings in accordance with its plan subsequent i
-l to its withdrawal of the long pile jetting method
}
in December of '777 l;
Would you read that back.
6 (Question read by reporter.)
MR. VOLLEN:
Withdraw the question.
t 4
After NIPSCO withdrew its proposal to
~
ij install long piles with the jetting method in I December of 1977, why did you not commence the 9
i installat.on of the short piles?
I A
We were still under the staff order not to 5
- install piles until they completed a safety review.
i O
Was that order in your view justified based on safety concerns in connection with the short piles?
A No.
G Why did you then not proceed to install the piles notwithstanding that order?
o
e o
80
\\
~
A It was our opinion that had we proceeded without the staff completing a SER, we'd have received an order from the Commission stopping us.
O Did you know what your legal recourse would EE have been had you received such an order from the i
=
- Commission?
A No, I do not.
I.
I O
Did you ever ask anybody?
i A
I don't recall specifically asking, no.
t 0
Off the record.
I i'
e (Discussion had off the record.)
ie:
MR. VOLLEN:
Back on the record.
E At this time we'll recess for lunch until 9
' 2:00 o' clock this afternoon.
I
[
(Whereupon, the deposition was 5
W recessed until 2:00 o' clock p.m.
I l
this day.)
6 12-__
m..
e
m w
81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF:-
)
)
NORTHERN INDIANA PUBLIC SERVICE
) Docket No. 50-36 7
i' COMPANY. (Bailly Generating Station,)
- Nuclear-1), Construction Permit
)
Extension
)
Tuesday, July 28, 1981 2:00 o' clock p.m.
109 North Dearborn Street Suite 1300 Chicago, Illinois The deposition of RUSSELL J.
BOHN was resumed pursuant to recess.
l-PRESENT:
l Mr. Stephen H.
- Lewis, Office of Executive Legal Director United States Nuclear Regulatory Commission appeared on behalf of the United States Nuclear Regulatory Commission; Mr. Robert J.
Vollen, and Ms. Jane M.
- Whicher, appeared on behalf of Porter County Chapter of the Isaa. Walton League, Inc.,
Concerned Citizens Against Bailly Nuclear Site, Businessmen for the Public
- Interest, Inc., James E.
Newman and Mildred Warner; i
?
- Longoria es Goldstine no semen m aw.m case e., m m ese seees f ata) sae-seso m
7_
~
82 l
PRESENT:
(Continued)
Mr. William H.
Eichhorn (Eichhorn, Eichhorn & Link) appeared on behalf of the Northern Indiana Public Service Company; I
Hon. Tyrone C.
- Fahner, g
i Attorney General of the i
State of Illinois, by:
Ms. Anne L.
- Rapkin,
{
Assistant Attorney General, y
appeared on behalf of the i
State of Illinois.
E
.I i
i I
1 e
f i
3 d
f ki:
1 k
i I
f 4
83 MR. VOLLEN:
Back on the record.
RUSSELL J.
- BOHN, having been previously duly sworn, was examined and testified as follows:
l DIRECT EXAMINATION (Continued)
By Mr. Vollen:
~
G Mr. Bohn, to whom in the NIPSCO management i
j do you report?
A Mr. Shorb.
Iu G
For how long have you reported to Mr. Shorb?
2 7
A Fall of
'77.
t O
To whom did you report prior to that?
i A
Mr. Lyle.
7 e
O Do you know why a change was made in the i! order of reporting at that time?
E A
No, I do not.
1j G
Did you ever discuss it with anybody?
A No.
G Did you ever ask Mr. Lyle why there was a change made so that you as manager of the nuclear staff did not report to him any longer?
I A
No, I don't remember ever asking the question.
i l
l
84 G
Did you ever ask Mr. Shorb that question?
A No, never did.
O Did you ever ask Mr. Schraer that question?
A No.
O Nobody?
Weren't you curious about it?
A I couldn't say I wasn't curious.
l O
Did you do anything to satisfy that
- curiosity?
$j A
No.
g 0
Did you ever talk with anybody on your staff i;' about why that change took place?
- ~
{
A I'm sure I told them it took place.
I
!j don't know that I ever told them why, because I E
really didn't know.
As far as I can recall, I didn't, i
r.I anyway.
O Do you recall anybody on your staff ever i
I asking you why?
l' A
I don't recall any such question.
O Mr. Severance never said:
"Why do you think I
,l Lyle's out and Shorb is in?"
1 6
A I am sure he didn't say that.
{
. y G
Well, words to that effect.
Did he ever ask l
1 4
A 85 you why the change took place?
A I don't recall that he did.
I.
O Do you recall anybody ever asking you about that?
l A
No, I don't.
Even though it may have i
happened.
5 O
Why do you think the change took place?
Ij A
I have no reason to think anything other 6& than what both Mr. Lyle and Mr. Shorb stated in b
l their deposition, that because of the work load there i
5 were reassignments made.
3 0
I asked you what do you think, why do you think the chaage took place?
A I agreed with the reasons they gave.
Sob.idh i
{ logical to me.
5 I know Mr. Lyle had a very heavy work load.
.I
~
G You a re referring to the deposition testimony
+
lll that Mr. Shorb gave and Mr. Schraer gave in this proceeding in the last seseral months?
A Yes.
G In 1981, is that right?
i A
I think Mr. Shorb's deposition was in 1980.
4
86 O
Prom 1977 until 1980 you had no information about why that change took place?
l A
1 have no memory of it, no.
I i
0 Prior to the time Mr. Shorb testified in his E
5 deposition in the fall of 1980, did you have any
- thought, idea as to why the change from Mr. Lyle to
- Mr. Shorb took place in the fall of 19777
)
A I would assume it's inevitable that I would 5
have been curious, but I don't know that I ever, I i
hhave no memory of ever pursuing it.
I.
[
0 What thought did you have as to what the 5 reasons for that change was before you heard Shorb I_
j testify last fall?
N A
I have no recent recollection of what that !
I might have been.
I don't recall what it would have lbeen four years ago.
B What about a year ago?
Summer of 1980.
l Why did you think that Shorb had replaced e
Lyle as the person to whom you report?
l J
A I wouldn't hypothesize, I guess.
I have no memory of what I thought even though I obviously must have thought something, f
j 1
l
I.
87 O
I imagine so.
A I don't remember what it was.
O What did you think of Mr. Lyle's handling of the responsibilities within NIPSCO for getting the 2s Bailly plant built?
h A
I think he did the very best he could.
f O
Yes, sir.
2 i;
Do you think that was good enough?
8 A
I don't know what else could have been done
{
G Do you think that he was replaced by Mr.
I Shorb as the person to whom you report because of the i{ status of the effort to build a Bailly plant in the j fall of 1977?
E A
I have no reason whatsoever to think that.
i l.
O Do you think that Mr. Shorb brings to the 5
- job any qualities that Mr. Lyle didn't have?
i, A
No two personalities are precisely the
!lsame.
I'm sure he has qualities that Mr. Lyle doesn' t have, and conversely.
l i
0 What qualities do you think that Mr. Shorb has with respect to being the management person at i
b NIPSCO responsible for getting Bailly built that Mr.
c bl L
88 Lyle didn't have?
A I don't know of any specific ones.
0 You just said you were sure he had some.
l A
Well, I think there are no two people alike d
E is the basis of my statement.
O As you sit here now, are you aware of any
- specific differences between the two people, Shorb I! and Lyle?
E C
?
A Yes, I would say I'm aware of differences.
V
~.
O What are they?
}
A I would say Mr. Shorb makes decisions more i quickly.
5
{
A What other differences?
A That's the only one that comes to me at the ij moment.
O What decisions did you have in mind when
!! you say "Mr. Shorb makes decisions more quickly"?
I.
A I don't have any particular one in mind,
)I don't believe, but just on the basis of my Ijreporting to him I think he probably makes decisions more quickly than Mr. Lyle did, i
0 All kinds of decisions with respect to i
)
89 aspects of the design and construction of the Bailly plant?
A.
Since that's the only thing I report to him for, yes.
E g
Do you think it desirable from the standpoint 5
k of getting the Bailly plant built to have the person t
a
! you report to make decisions more quickly rather than
![lessquickly?
A.
Yes and no.
u O
In what respect yes?
r A
To the extent that it's necessary sometimes
},
I to make decision quickly to keep from holding any a
i
! specific function up, it would be desirable.
{
To the extent that there would be any ij possibility of making a decision that could be later k
~ challenged because of additional information becoming available had the decision not been made as quickly j as it was, then it wo uld probably be detrimental.
t I don't have any specific examples of either.
G Are you aware of any decisions, excuse me, any decisions which Mr. Lyle made that you felt were not made quickly enough?
i I
I i
=.
E
.o 90 A
No, I don't.
I think the decisions that were made were made in good conscience and after the facts were known they were well made.
l 0
Do you think any decisions were made too
$_[ quickly when Mr. Lyle was in charge of Bailly?
A I can think of none.
?
1j G
Do you think any wrong decisions were made
".,3 when Mr. Lyle was in charge of Bailly?
I I
A I think anyone would make wrong decisions Ii on occasion, but if you ask me specifically what l decisions he made thet were incorrect, I can't think t
i of any.
3 i
O Can you think of any criticism at all of i Mr. Lyle's performance as the management person in
.s charge of Bailly prior to the fall of 1977?
a I
j A
That criticizes, a negative evaluation of the way he handled it?
No.
4 i
G No criticism at all?
l A
No.
f G
You can't think of any respect in which a management person should have done something other or m
m 91 different than Mr. Lyle did during all that time, is that correct?
There are other decisions that could have been made, both by Mr. Lyle and Mr. Shorb that, had Re they been made differently, may have been a better i
fdecision, but since they had been made and as far as
- subsequent things that would have happened, I can't 5!
i evaluate that.
G Jut your belief is that there was no room
{forimprovcment in Mr. Lyle's performance as the
.I
- management person in charge of Bailly up until the time i* he was replaced in that position in the fall of 1977?
Ej A
If I were to answer affirmatively I would
? have to give examples of those places and I can't i
}
! think of any.
l G
Is it the case that you can think ef no i
$ area where things, you think things should have been donc differently than Mr. Lyle did them?
A The only way I could answer affirmatively would be getting into my previous response which --
G The way you could answer affirmatively is if that's the honest answer, Mr. Bohn.
c
92 A.
What's the questic.'*i, please?
(Questice read by reporter. )
Ti!E WITNESS:
A Tnat's correct.
By Mr.Vollen:
2 0
What about in the period since Mr. Shorb e
- has been the management person in charge of Bailly?
Can you think of anything that Mr..Shorb II has done that you think should have been done g
! differently?
ia A
No.
).
G Do you ever criticize anybody?
- ~
A On occasion.
5
{
0 Anybody who works fcr NIPSCO?
e A
Cccasionally.
j I
j-O Superiors of yours at NIPSCO?
=;
A No.
Those are exercises in counter-ii productivity.
i j
~.
G lla ve you ever heard any NIPSCO employees criticize the performance either of Mr. Lyle or of Mr. Shorb with respect to their handling of the responsibilities for the Bailly plant?
I A
I don't think it's untypical of employees O
/
\\
~
O O
93 that are relatively new and inexperienced to question decisions of people higher up in a company as far as responsibilties go.
I'm sure I've heard them, I'm sure they I have been made, and I'm sure I have heard them.
2 G
What criticisms of the performance of Mr.
?:
Lyle and Mr. Shorb have you heard?
?
ij A
In all likelihood, I have heard criticisms Cl of the majority of the decisions that have been made I
w
- on this project, but I can't tell you specifically 3 any given time when any given person made any specific t; criticism.
O Did you ever hear any criticism that you
- shared?
I
[
A 11o t that I recall.
5 G
When was the first time that you had knowled.g e sI of NIPSCO's plans withrt; ect to dewatering in g
conjunction with construction of the Bailly plant?
A It was certainly discussed in some detail I
during the construction permit hearings.
I can't at this moment recall whether there was any mention specifically of dewatering in the
q
- ,9, 4.'
(
94-
^
l
..!+
, kh-
$PSAR or.not, 20'
,,nen-were the construction permit hearings p
to' _ which..you ' ve-j us t referred?
s AJ That woulel have been'1973.
. 3.
O Do you have any recollection of having r.
4 K
{known-Lab'out'.NIPSCO's dewatering plans in conjunction
-- e I1with building.Bailly prior to thocehearings in 1973?
[
1
,A.
Well point ~ dewatering is the normal
- !_ dewatering procedures that are used on'most V_
t, u
.i_ cons:ruction-projects._and even though it may not P
3-have'been-in~the-PSAR, and I don't know if it was or
?
_not; I.~was, certa. inly aware-of-that type of procedure
-2= j _ and ~would have assumed that_was going to be used
.e O
L.
- whether.it was in the PSAR or not.
'I l
l-l CL So you either knew that NIPSCO planned to E-3 ~use-a,well point dewatering system or assumed that L[ it' intended to, from your first knowledge of its l_-
l C
plans ~,-to build a nuclear plant a t - Bailly.
~
-A.
Yes.
0-When was that?
I
' A.
That would have been 1970.
i (L
Can you describe what you knew about NIPSCO 's 4
5.
. d A wm
E
_ _.. ~. _. _ _., _
c
~
.4.-
=
95
+
.,~
fplans' with7 respec'tlto dewatering at the time you firs had knowledge of.that subject?
A1 As I mentioned,-I was and am familiar with-
~ the well pointidewatering procedure, what's involved,
~
!;and I' don't' recall whether it's in the PSAR, but I
.g-
- am aware it was-exactly the same procedure ' hat was e
P I~ used on' Uni ts 7 and~8 which were constructed at the 1
[i Bailly site, and.to the best of my-knowledge without
~
.! any off1sito effect.
y-U O
-What' procedure was it that you understood
<r-l 5.was planned to'be used'that was exactly the same
!?
f as the procedure used on Units-7 and 87.
l A
It'would be encircling the excavation with 3
o o
(;
- ' rings of well
- points to draw the groundwater down
[-
I tolthe elevation required for the construction process.
O To draw the groundwater down to what level?
i 1
g.
A' It would have to be at least a couple feet below'the lowest part of the foundation.
<4
~
n.
Do yau know what that depth is, was at that time, excuse me?
A I:beli
<c minus two, elevation of minus two
-feet was the bottom of the rad waste building which 4-d --
~
~
L
+, u :-. -
A' 96 r;
+
0
'is'theLlowest buildingEwith'the exception of the
- reactor building and the reactor. building was han'dled
- se pa r a te ly.
G
-Minus-two was with reference to the level.
j:ofjLake Michigan?
.k.
k A
Yes.
~
i
. What :was dif ferent with respect; to the 4
l'; reactor building?
e
. A' We committed to and-have subsequently
]\\
j-installed sheet piling around the reactor building to i
~
avoid.:affecting groundwater.
a i
t
[-
l 0
I'm still now at the time when you-first n
L I-3 j acquired this knowledge of the dewatering plans of
. n
/
i.
NIPSCO_in~approximately 1970.
o i
5.
Was this sheet piling around the reactor
,
=
' bui3 ding part of the plans at that time?
'I A
I do not believe it was contemplated at the PSAR stage.
m-l G
What else was involved in the dewatering procedure at the time that you first knew about it?
/
A I believe I described everything that I am aware of that -was involved at that time.
i E
a w -...--
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{g 0
-Okay.
EDid 'there come time when there were-t-
a changesL.madeLwithLrespect?to the plans for dewatering in conjunction with construction of the Bailly plant? -
[-
A Notluntil-after we received the construction a, permit.
.L:
+ -
0 What changes were made~then, sir?
' p-
.A The company volunteered to put in a slurry hwal'laroundthe excavation.which, in our opinion, i would eliminate'-the possibility, even though we
-r
- considered-it
~
remote, of any off-site effects of t-A dewatering.
.s.
G Why did the company volunteer to do'that?
x-A Because we were of the opinion that the y-
- j people opposing us had a
_r real concern about dewatering iin: Indiana Dunes Lake Shore area which I personally 1
]:donotthink the case is any longer.
(F What do you not think is the case any longer?
- A That the concerns are about dewatering because I.think1there is ample evidence now and there was ther.
tha' t any-dewatering ef fects of f-site would be minimal i
and temIorary.
4 i
A lC R
}% '-
_(
98-T C
h
^
-BUt f you didn ' t-'-b.elieve that'at the time g
Lthel company 1 volunteered to put:in a slurry wall?
~
A' I dif3n'tibelieve that was the I believed Jtiiat.theLpeople: opposing us were^ concerned about the
+.r
-[ ef f ects Lof dewatering 1 of f-site, yes, I'believe that.
4 g-
," I believe1that 'theyfwere concerned,-yes.
t.
G And because you believed they were concerned
!=
}about-the e'ffects of dewatering of f-site, you
.-.3 volunteered}tofput in the. slurry' wall.
L, u
-A
_Tha t 's correct.
1-;.
g 11 ave you done any, volunteered-to.do'any other; th'in gs - because you thought the people opposing i 'the plant were concerned about them?
5
~.
- L
.A As-I recall,-weJalso put.in a tertiary Ilj treatment system on our sewage treatment plant because n
- 5. of an expressed concern.
.i 3
0 When7did you do that?
~
A. -
I think that was a hearing commitment.
'H
.0 What does that mean, a hearing commitment?
A
.Something that we committed to do during a L
hearing.
G On the construction permit?
(
er
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'Ri gh t.-
,G.
Anythingselse that you volunteered to do in
. response-to. concerns?of. people;who were' opposed to
- h.l
'thatiorare opposed.'to.the Bailly-plant?
1!l A. -
There:are no/other concerns that are
.-y th'at'I'm aware of.-
{ legitimate i
O
.Now,'would you answer the question, please?
,f:
- i.
A.L No.
7 I-There are no other. things that you 0
u i volunteered to do?
I' A.:
I - ca n ' t ~. think. o f any.
1}
-0 lWhen after the construction permit was
.]issueddidyouvolunteer to put in a slurry wall?
. e.
- A.
During the. summer of ' 7 4 '.
I.
- i 0
- Why then?
?
A.E Because we became aware of it then.
-~ 0 How so?-
f-
- A. '
One of the contractors that we were dealing lwith-to do the site excavation work volunteered this
- information to us at that time that we were not aware i
e of itEbefore'then.
GL What contractor was that?
e m
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pr.
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A
'The contractor.-for excavation work was
- Calumet Trucking and the contractor for1the slurry.
wall: work'was Thatcher-Holtzman as a subcontractor to Calumet Trucking.
2 O'
.Which was the-one that volunteered to you the l
k notion ~of putting in.a slurry wall?
l, A
It was the Calumet Trucking people.
I
'G
~ Who?
y A
-I d on ' t - k,n ow that.
There were several of
{us' involved'inameeting in which we identified the
>E
.l perusal of.the files which we have showed to you and
?
- I don't know which of the gentlemei who were present-j volunteered it.
C G
Do you recall how it came abott?
I.
A.
As I recall, they said, well, they were
!z
- now aware'of this new process of installing a slurry i
wall which would preclude any dewatering that could have an off-site effect.
G What prompted them to volunteer that information?
A Because they were familiar with the proceed.ngs and knew that that was one of the major issues.
e
~
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fit %9 ' wt 5m q ag.
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'O How were-they so~ familiar?-
Were'they in a
. attendance.during evidentiary hearings?-
r A. -
Some'of them,, 1 think,_.probably attended sometimes.
4 So in'the' summer'of '74~they'said,.in
." effeet, we've;got an idea for you, why-don't you think
.about; putting inLa slurryJwall.
-- I
~
.A:
- That-perhaps'characterizesJit.
s if O'
Or perhaps it doesn't, also.
Y-a Is that a fair characterization, Mr. Bohn?
I A-I can't make a better one.
.t.
I: know, but is.that a fair characterization
?
1 '
A Yes.
3-e i
4.
Thank you.
i Did.'ou ask them.how long they'd known-g y
-xfaboutthe;notionofa slurry wall?
j A
Apparently after it came up in discussion it was something,that they were just very recently aware of,'something'.that had.never been done in this
-country, and Holtzman is a German contractor and apparently had been doing it over there.
I don't know how the relationship got
. t V4:.
b y
~
t
I' t :
- e-_ :
y 102 M
g established between. Thatcher'and-Holtzman, but-
[
apparently Thatcher had been:made aware of it only
.recently or!near:the time.we wure.
0;
- H cnv. a bo u t Calumet: Trucking?
When did they n
become' aware-of it?
1r 2
A' It would~have-been Thatcher-Holtzman that
~?.-
- would have made-Calumet Trucking aware of.it, I r!-
j>would assume, about the same time.
That's only an 9
V. assumption.
a LIfhave nothing to base that upon.
1-
-: 5 3
G-
.And'after the time when NIPSCO volunteered
$ t'o put-in the slurry wall, what,.if any, other 2-
- i. changes _were there with respect to the company's a
3
! dewatering-plans in~ connection-with construction of fh:Bailly?
~
L A-We thought the slurry wall would completely
.!.j supplant the requirement to put in well points and lthat is the basis on which we went forward with it.
I i
0 In what sense.did you go forward with it, 1
Mr.Bohn?.
A Well, we submitted it to the staff as a construction procedure for their approval or their i
i
m m -. - - - -
1 rkg lJ3
~
y (
W i
connideration.
,0 Did-you.think that youLneeded the staff approval?!
n
. :A-There was some consi'derable ' discussion,'as.
a j I-recall,.between vario1s parties, including legal, 1
h.'about whether or:not--we needed to make more of it
_j -
}isince;anypossibleeffect-ofthe slurry wall would
.i
~i have been-no more-dewatering required than the well V
-3 d.
.y' points-which wero~ approved, and it was my opinion we S
idid not:need to-advise th'e staff.
..t.
.l However, the-sum total of opinion was j'
i
~a '
l 3 otherwise and we did. advise the staff.
l-0 Whose opinion-was otherwise?
L E'
A I don't. recall whose in. par.ticular, but I l'
r.
hknowit:wasdiscussed, that question specifically was s'
- discussed.
o i'
.0 Who made the. decision to go to the staff t
r
.with the. slurry wall idea?
-A I think it would have been Mr. Lyle's decision at that time.
O Do-you think he made the right decision?
A I think.in' hindsigh t, I think it's probably g
+
4
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1,,
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. - ~..,,. -. - - -..
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$:; si$:{1 104
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.always' wise to' advise: the staff.anything'you are going.
~
.to'do,Twhether there'is aLdirect impact or not.
I don't.think they can be in.a' position of
,sayingwe' don't-kn'ow what1the applicant is doing on C
^
- -the site.
k
.{
G Dofyou think Mr. Lyle made the right
'i
' dec'ision?
5-i A
Yes.
d.
G' Even though it's-not the decision
- t. hat you u
! thought,should have been made?
E i
A' That's correct.
I G
What,Lif anything, happened 1next with 1
I respec t to the company's plans for dewatering in
.7 conjunct' ion with the. construction of t2a Bailly plant?
-Ii A
The staff approved it, didn't object to it, R's
- as I recall, but I don't recall the mechanism whereby 1l~'it' got published, but ~
things do, and I don't those i.
know' exactly just how that happened.
But, there was a request -- you're getting into the legal area now in which I'm totally incompetent.
In any event, we had a hearing an it.
I don't. recall the mechanism that brought i t about, 9:.
~
s
.~h
~
.y_.
..-r-
,.y
7>.x
~n.
l k %... p i a
-U
- p
- f.
~
105 l
ibut1we did have-anLexpedited. hearing on the slurry wall'which was. subsequently overruled ing the Appeals Board and weJhad further' hearings on the slurry-wall.
([
Y e s',
sir..
l
.Then what' happened with respect to the i = company's plan'to dewater?
~
. ?:
-5 A.
.Then I believe-an amendment was issued.,
.i _l if I remember correctly, including the slurry wall a- ! in theidesign.
y 0
When was that?
i
. A. -
The hearings 1took place in-late '74 and early;'75, I believe.
However, since we were shut down I do'n'.t.believe the actual issuance of it was
!forisome later, like two or three'y' ears later.
ii I'm not sure, but since there was no
. i,.
actual valid CP during that period of time, I don't s
1
,) believe.they issued it until sometime later, years later, perhaps.
O What, if any, other changes were made with respect to th-company's plans for dewatering at the Bailly1 site?
A-In conjunction with the dewate.-ing, I believe o
s c
e
+.
,_y
jg
=
/
"?
106'
~
-there1were: additional monitoring wells installed.
E -
0 In addition'.to what,1 sir?
~
A.
In addition:to those that were'previously committedicto-during the.CP hearing.
- A' '
~E.
S s
G
.Thus far,'we havecnot been-talking about
'/'.
N Emonitoring.
A All'right, then --
5i g'
We've been talking about the dewatering r
l; { plans..
W h.
A.
Okay.
None, then.
g Is that true up to and including the presen;
=
i e
y time?-
. ::j-A The i stallation of the slurry wall created 1_ a ' problem tha t wa s not previously present on the site l1whichwebecameaware of subsequently, which was a
l' creating a hydrostatic pressure situation in what i.
! is now known as_ Unit 3 or the confined aquifer.
Had well point dewatering been used, the i
~ situation would not have taken place.
We created a problem --f or our selves.
0 What is that problem, sir?
.A Having pressure underneath the clay layer 3
I-g.ph
- . 4 & W*
~,,-
107
.x t
'thateis extant'under ths. site at.minus ten.
10 How'.did you create that problem for yourselves?-
A.-
..-B y t h e installation of the slurry wall' whic 1
.s-9l allowed the-groundwater head to be placed*on that i:
M. lower-aquifer up at'the excavation.
j
'- 0 And'in what respect is that a problem?
)
A.
. It creates the potential of failure of the
- g j' Unit 2 or' clay layer'under.the site if'the pressure u
4
- -underneath the-clay-layer became greater than the O.
', ' ' total weight of the confining layer.
O' And in what. respect-is that a problem?
3-A.
Well, in the event that the clay-layer e, -
- failed,'it would then have to be excavated.
l It's-not a problem as far as the design of 5.
l the plant.goes because the piles carry the load 3
tih ro~ ugh the clay layer, but it's a problem during
~construction only.
O How has the slurry wall created that problem?
A I will repeat what I said before.
It-brings the groundwater level up to the slurry. wall and then that level is imposed on the p
7
-,,,..-~,w
-m.,--<-,,c3
-w-
g^- : '.
1 Tyn:
~
w e 108 s
"J
' confined' aquifer.
-(f And that problem would_not;have existed had you-not put'in the' slurry wall?
A-
'That's certainly my opinion.
e-
- i 4
LHas.this'probler of the-hydrostatic
.q-3 pressure:in Unit 3' led to a change or' alteration with
. respect to NIPSCO's plans for dewatering in
.!_ conjunction with construction of Bailly?
[
y,
.A
_Yes.
u t
4 Would'you tell us in what respects?
}
A-It requires the removal or relief of the r
- pressure inEthe confined aquifer to avoid the heave t
l' potential.
.y.
4 Heave potential of what?
[- -
A Of the confining Unit 2 clay layer.
E-4 O
Within the excavation?
-.i A
Within-the excavation.
- g What plans for relieving that pressure exist, sir?
A Installing well points through Unit 2 into Unit'3.
0-When was this pre len of the hydrostatic e
i
~
re.
-h v.
'I ls 109 r
r, o
la
)
l pressure 1in-Unit <3 learned 1-about?
i AL The slurry wall was. installed in early
'77.
I-believe Lit became apparent during 'some
- of the; tes ting L work : tha t:-.. was conduc ted -i~n-197 8.
hl
'O
'Whose testing work?
i M
A
.-The. work that was(done performing pil.e tests -and borings in the site that we previously a
. g-
- referred to.
' ~
a{
G The* indicator pile program that was carried
{-out~inconnection~withthe short pilings proposal in
'.i
" the summer of '787 I
. {~
A.
That's part of it, yes.
!j G
'What is'the other part of it?
A We had other. programs earlier on than the
' t:$-indicator pile program in '78 in support of the j short-piles.
I ii G
- Involving borings and drillings and A
And piles.
0
. And punching holes in the bottom of the m
excavat' ion?
A That's correct.
.O.
How, during that activity in 78, was the
., moi 44-mou w e.-=* %
i
,,e.
..,-m
,.-,.-.,,.,y I
2.
110 p,~+.
- x. '
problem of: the hpdrostatic pressure in. Unit 3 learned about?.
A
-There were-casings still in the excavation that had-been put around piles, around. test piles
.gLto remove the sand between the testing elevation and
.i i the' final ' driving elevation, and it was noted that the i
- water stood i.igher in these casings than it.was in a
!'; the excavation itself that was pumped out.
O' That was the first knowledge that the j company had of this problem of hydrostatic pressure in Unit'3?
tj' A_
I believe that was the first, yes.
l E-
. j.
0 What did you do about it?
2 A
'e proceeded to install piezometers in the
.I -
E' bottom of the excavation into the confined layer to a
5
- determine the magnitude of the confining pressure or
[ the confined pressure.
O When did you do that?
A I believe that was done in late 278, as best I can remember.
G And then what happened next with respect to the problem of the hydrostatic pressure in Unit 3?
e 6
7 q,-; ~
111
'A' We instslied two, I think we called them relief wells ~, butsideJof the main building ~ block but
-inside the slurry. wall to relieve that pressure.
.O
-How-did-those wells work'?
Were those; d1 pumps?
t' N
3-
. A.
M o ', theyLwere gravity wells.
I 0'
- What happened.to the. water that was relieved?
i 1.Was'there water, did water come up.through those l.y. Wells?!
u i
A Yes,: it relieved from Unit 3 to Unit 1.
.i G
These wells were put in within the confines i
!Lof.the excavation?.
A Yes.
e E
G You said within the slurry wall, I think.
A Yes, but outside the main building block.
O Why outside the main building block?
i A
To assure it would.have no effect on the foundation.
g What effect on the foundation were you concerned about?
A Any effect.
O.
What ef fect might there be?
o s
e
!!-Q 4
- ;,7 v.q:
2" 4
112~
}
[
/
' A.
- Well,- we ~ didn ' t. think' there would be an
.effect, butHjustiin the--event-there'could be we
' w a n t e d. ta) avoid'any. possibility of having an effect.
c G
What ~ effect could there be?
["
A'
'Well, one :possible ef fect would be it would 1
' ;.oreatena. spot where the clay was not it would be I a~ softer area that would have.-to be repaired, probabli.
f I
I G'
'Why would it have to be repaired?
e t*
A Togget..the densit-of the materials the I;.
i same as the~ remainder of-the site head.
- y
.t
~G
.After.you put in these relief wells -- when
..did you do.that?
- i A
The--indicator _ pile program that we have m
t a
).discussedwas conducted in late
'78.
I believe the
[ relief wells were'put in in
'79.
E a
=;
G What-happened next with respect to the
?sj problem of the hydrostatic pressure in Unit 3?
l-IL By reading the piezometers that we had installed, we did not get the relief that we had expected.
G When did you learn that you were not gettine the;. relief you were expecting?
m
,e
-re--m----
irm.
- --1-n-,*-
r w
7' i-g a
' hf
.e..
113 I
W A
Not.too long after the-~ relief wells were installed.
(F
. What did you-then do?
- A We had a contractor come in to run tests on
- i. o.the relief wells to determine what kinds of volumes c
3
'l we.were getting from them, to develop the relief f-l wells to see'whether or not they were plugged and, o
- if so, with what, and whether they were a free-flowing 9
0' drain'or relief well as we installed them to be.
Si l
0 Wha t contractor was that?
~ t
("
A I believe--it was Groundwater Technology.
i j '
O Who had installed the relief wells?
. )
A I don't recall who installed them.
I don't 9* believe it was-Groundwater Tech.
I think it was i
5 someone else.
I don t recall'who it was.
t 5
l 0
'Why didn't you call in the same company tha t i
i Tj installed them.to see if they were working right?
It may have been Midwest Dewatering that we A
had put them in, I'm not sure, but in the event that it.was we wanted to make sure that we got someone that was competent in the groundwater field to run tests and tell us where we were and what to do next.
3 t & se a es.*->
- r I
rw 114 O
Did you think that 'the ' company.that had installed them was not competent in the groundwater
~ field?
A
'I~have a problem with knowing who-installed
.]-them'at this time, fa f
If Groundwater Tech installed them, we 3
L considered them competent, but my memory says-they're
?-
.fnotthe ones that put them in.
Midwest Dewatering is sort of a well point
.k dewatering organization that doesn't have the 4-
). technical competence that Groundwater Tech has.
I
{
G Who made the decision to put them in?
t A
It was at the recommendation of Sargent Lundy l
1 based upon.the information we'had gotten from reading i
i the piezometers.
E
. ~.
G In other words, you didn't go to Groundwater
-i
} Technology before
-3 you put them in to ask them whether they thought you should put them in or whet they thought you should do about the problem.
A 1 don't think so.
O Just came up with what you thought was a solution and when it didn't work went to someone and 6.
v: ~
a.
.c s
- 115-ref l:JJ Y
,f askedL them whether they thought you had.the right' sv
' solution.
A Sargent_Lundy has hydrogeologists and people that we consider to be competent:in the groundwater lffield.
ta G.
Then why did'you-bring in Groundwater
~. -
- t Technology?.
-ri. j-A, Sargent Lundy recommended, I think, that a
f should bring someone in that could verify
.-h, perhaps vn) or supplant their information and perhaps field-
~.
G_ experience.-
O Did you-ask'them why they thought you
!shouldbringlinsomebodyelse?
7'
' C A
No, that's a decision that I think we I
- I.j concurred in after we saw the information that we had
~and determined that we would certainly welcome
(
someone that we all agreed was very competent in the
+
groundwater field.
G-Because you felt that you had not had someone who was very competent in the groundwater field prior
'to that?
~
A We wanted another expert opinion, at least.
H l
g
' ~
g 116 I
e-G-
Did you. feel you had an expert opinion
- prior tofthat?
A We considered.it an. expert opinion, yes.
G-Wh~ose?.
0
~.
A-Sargent'Lundy's.
I don't recall whose
-l in particular.
'They had several people working there,
~
b O
When Groundwater Technology came in to,
-)
i-in effect, study the problem what happened next?
A The development of the wells, the relief lJ wells, and checking the volumes of water-that_they wer e --
i
-l capable of relieving indicated ~that it would take a 1
i large number of relief 1wc11s if it was to be done 2
j by' gravity only and it.would be much more practical to pump water out rather than create large enough i
!'s areas for it to come out by gravity only.
5 O'
That was Groundwater Technology's conclusions i
l-after 'they came out and looked at the problem?
A.
They-also conducted a pumping test, installed a pump down into the third' layer, installed a pump t
in it 'a n d ran an extensive pump test to determine how much water could, in fact, come through the
- Unit 3 materials, and from that information they were b
e
-e
-me y
~
m k,%
117 o
w h
m.. '
_.2
? w; rm;:
-(,,s lable-to ~~ recommend how-many relieving points would be required.
'0
'So;they'did, Groundwater Technology.did a study andEgave.- -
j -
A
~1t-wasn't: a. study.
In other words, it was-
~
.'[ on site field' work generating' field data.
~
K I
4 1And they gave-NIPSCO a report and a e
recommendation, is that correct?
C.
j-A The only problem'I'm'having is whether it
- 6
.was given directly to us or Sargent Lundy first.
+
I G
They issued a report and a recommendation n directly to NIPSCO-or to Sargent & Lundy?
2 5
A Right.
S.
e 0
-What was that report and recommendation?
~
[
JL I believe the recommendation was that you h
I
- .~ co uld install a number of relief wells, gravity
. i j relief ~ wells, and this would adequately relieve the i
. pressure, or you could install a substantially smalle r number of either well points or pumps to relieve the
. pressure.
'O-When was this report and recommendation given to NIPSCO?
a b
- h[..
memim h e-9
~
9 e,
.n.,
~
.m.a
,w.y
- --[
/
- c4
-(([r N
'118 y
i
. A..
That's all..in the. record.
It.must:have
~
beenilate '79,,p'rhaps..That's a guess.
e O.
. What' happened next with respect to HIPSCO's plans concerning dewatering a t the Bailly site?
f-A We' -subsequently submitted all the 1:.
.{.information that had been generated from the on site
't J work to-the staff.
I 1;
O When was'that?
b 1C It must
-g it was probably 1980.
I really
'1 don't' recall.
4~
.Why did you submit all the information that
=
2.
- had-been generated to the staff?
- 5 A
Because it was a change-in the dewatering e
. program that they had previously approved.
i g
g~
Did the change require their approval?
E
-l A
It-required their. concurrence, we felt.
i
- [
g What's the difference between approval
-and concurrencc?
A They don't approve designs.
They are not in the' design business and they are very careful about that, and I think justifiably so.
4-Why do you think that is justifiable, Mr.
a,
._. ~ - -
&p*.
- p..
119 s
I 1
' Bohn ? :
.. e..
' A. '
They are;not a design organization.- They a
don't~ design plants'and'. foundations and so forth.
x They merely' approve them-for....
p g
i 9
Jg"
.Okay.
i p.
- n 4
A. -
. Bless them.
3;.
.O' W.' s that'a' request or an instruction?
5 i
A.L Yes.
g'.
0 What-was the change in the' dewatering plan
~
! with' respect to which NIPSCO was seeking the staff l.
- tconcuricnce?
L l;,
f A.
-It was. dewatering Unit 3.
,r -
l 0-To what level by what_means?
?
i A.
By..well points.
i 7
e E
B To what level?
o-p l'
A.
And still to the same level as we've l.
l.
- !-previously discussed on dewatering, which I believe o
is minus two.
l, 0
What, if anything, happer.ad next with respect to NIPSCO's plans for dewatering?
'A There were several discussions that took place with the staff.
T u
.n-44 Du f." 5 F%H%-'
F%*
'%~
.m
l 120 I don't recall specifically when, but it culminated finally in the issuance of their, I believe that's in the environmental impact appraisal.
O Is that a document?
C i
Yes.
.u 1
-[
G Bearing a date in July of 1981?
i l
A Yes.
a G
Between the time of NIPSCO's submitting the c
data and seeking the concurrence of the staff in this
! change of dowatering pragram and the issuance of this
.t[ document that you've just described in July of 1981, t
{what, if anything, else happened with respect to the
!j dewatering program, anything?
E A
As I me n ti nned, we did submit the information i
ii to staff and had phone conversations with staff.
O What additional information did you submit ij to staff?
A Regarding the tests that were performed, as I've previously stated.
O The Groundwater Technology tests?
A Yes.
,l 0
Has WIPSCO received the staff concurrence it
'121 l
sought 1with respect;to the change in the dewatering program that we've been-discussing, namely, the well point dewatering of Unit 37 p,..u
' A..
"In my opinion, yes.
g.
s a
Where.has that concurrence been reflected?
A In the documents that were issued a couple of weeks ago.
I a
O July of '81?
5 t
j.
A Yes.
a 4
Now, what, if any, other chaages have there l
[ been in NIPSCO's' plans with respect to dewatering i
l in connection with Bailly that you haven't yet t
l t
l test'ified to?
-3 A
11 don't recall any others.
I i
G Did you mention earlier that a change was 5.
!.. made concerning the installation of sheet piling
,i pround the reactor building?
l l
A That was committed to during the construction permit hearing, yes.
I G'
In testimony given by a witness testifying in support of NIPSCO's application?
A.
Yes, I-believe so.
a b
-e y
_w.~
O s
123 O
And that was a change from the original dewatering program, is that correct?
A The original dewatering program being.
well point dewatering down to elevation minus two, E
E elevation minus four, I'm sorry, the bottom of the i
h t foundation is minus two.
Two feet below that makes it i
I hminus four and would not have been deep enough to l
I i dewater the reactor building foundation, and that's i
fwhywedecided to put in the sheet piling and also l
l h to sheet pile any other sumps or whatever that go E
[ below minus four.
ie 0
When did you decide to put sheet piling
.~
) around the reactor building?
E l
A I don't recall, but it was during the l
construction permit hearing.
2 l
0 Why?
E A
To avoid having to dewater below minus four O
Why did you want to avoid having to dewater below minus four?
A I don't recall.
I'm sure there is a very good reason, but I i
don't recall exactly what it was at the moment.
+
l
.W o
123 O
Who do you think made the decision to put sheet piling around the reactor building?
A We made the decision to put it in to live up to the commitment that we had made or we felt we lmade a commitment.
5
-[
0 The question is why did you commit to 5
' minus four?
i A
Yes, I recognize the question.
I'm sorry
~
3gI can't answer it.
I hope it comes to me. It should u
! be something I know very well.
t O
If it does come to you, will you let me i
" know?
A I will.
e E
O Ilow would sheet piling around the reactor i
i building avoid the need for well point dewatering?
A Sheet piling is an impervious barrier j except for very minuc leakage through joints and it's used only for much dewatering because you drive the l sheet in.
It's impervious to water.
0 You said it's used only for much dewatering A
Much dewatering is accomplished by using sheet piling only, yes.
c
-,. ~....
1 W;
l I
124
[
-o
?
- Q:
You mean, on other construction projects?
l l
A'
.Yes.
O.
You don't mean in connection with Bailly.
AL No.
ei G
-Okay.
i 5.
l A
In other words, it's a very well known and
{acceptedmethodofkeepingoutwater.
i.
'O After you installed the sheet piling around i the reactor' building, would you need to draw down the
[waterwithin the confines of the sheet piling?
.I
' A.
"Yes.
i
{
O_
llow would you do that?
A By putting in a sump pump to collect the
water.
O To what elevation would you have to draw down the water wit,hin the confines of the sheet
)
i piling for the reactor building?
A It would be pumped out down to the clay layer which is minus ten.
The: building itself i s, the bottom of the foundation is minus four.
Two feet below that would be minus six which is good for the majority h
p,
r
,v.,
,y
,,,y..,
1 125
' det0%
x;
.- r of the' foundation.
However, the reactor, I'm sorry, the tendon tunnelwhich goes around under the reactor is deeper than that down into the clay lay'er-so you'd
!havetodewaterdown to the top of the clay ~1ayer.
4T 0:
To what level would the bottom of the i
jsheet piling be driven?
A Minus fourteen, approximately.
g-l s
'O Is the clay. layer-extant under the entire 3
{ site within the area where the reactor building is t[designedto907
. 4 l
'A
.Yes.
l l
3 j,
j O
How do you know?
l A
.The sheet piling has been driven and founded
'I t
l-E all the way around.
t-g.
5 j
O What are the dimensions of that building?
i i
A I don't recall.
O
-Approximately.
A ALhundred sixty by two hundred, approximately.
O Feet?
A Yes G
So there is a sheet piling rectangle of about
+ weeme,
ae m
W,'
~ ~ ~
o.
126 i
those dimensions driven intoithe site to an elevation of minus fourteen.
A Yes,Lapproximately.
O And throughout the perimeter of that l'rectanglewhenthe' sheet piling ~ was driven, it was
~
A
{foundtobe located in the clay layer.
A
- Yes, I
a.
O How was that determined?
5:
A L
1 It's very easy to tell when you're driving
{a sheet, when you drive it from the sand into the.
'I Iclaybecause it reacts entirely differently.
I 5
i j
0 Resistance to driving, in effect?
!i A
- Yes, e
t.
O
'How do you know that that clay. layer which i
3
$ was.found around the perimeter of that rectangle exisus I
u
- throughout the entire area within the rectangle?
i l
A
.All of the borings that we have taken on the site, and we have many, have indicated the presence of the clay layer at about minus ten to the top elevation and dipping to the north.
The only place we found it absent so far
' is in the southeast corner of the excavation where the e
m
- ~ -,.., - -
-.y
i fe.
+
127 slurry wall is.
G.
There is no clay layer in the southeast area?
A.
There may be one, but if so it's very, O ~ very: thin.
j N
-[ '
In other words, you punch, we punched right i
' on through the c3ay layer without recognizing it Ii was there, so if it's there it's very, very thin.
L S
0
'You don't know whether the clay layer
{ gets very thin in other locations, too?
E A
All the information-that we have indicates
-t j.that it starts thinning out at the south end and gets V
L
-i -.substantially thicker as it goes north, being some E
eighty feet thick-by the time it gets up to the north I
I.
5 end of the turbine room.
G Uhen did you learn that it was either very
!si thin or didn't exist in the southeast corner?
A When we drove the slurry wall.
We had borings, of course, that indicated that it was thinning out and getting quite thin on the south end.
We didn't know precisely where it may 1
' disappear, but the pile driving contractor, I'm sorry, 4
s
-w.
-se b
P; i
~
, er.
- .~
128
- - W E
e 1,
in the slurry wall had been the contractor that put advised what -to :c' t if. he punched through the clay layer;'iniother words, it was not unexpected.
- G'-
If.the' clay layer is very thin or non-
- se existent within the perimeter of-this sheet' piling k'
-[ driven around the reactor building, what will be the f'
i consequences of well point' dewatering to minus ten in II 2 that area?
lA
'If the confined aquifer-pressure wasn't
'hcontainedor reduced below that, you would get water I-
- coming up through where the clay layer was non-l a
- existent.
t l
)
G Would there be. water from Unit 37
.D A.
Yes.
.i L
E G
How many borings have been done on this site?
a a
l A
I'd say more than fifty.
I really don't E
lhave a good handle on it.
i G
How many of those are within the confines of. the reactor building?
.A' I don't know.
Several.
G When was the sheet piling around the reactor i
driven?
d
..%_w.
.. - +. *..
b 4
-.+s
.,~
.-,r
y.
129 A
I believe in
'78.
Same yLar that the indicator piles were driven, I think.
O Is there any dewatering, is there a well point or sump pump in that building operating now?
l A
Which building?
s O
Reactor building.
5 A
Yes -- no.
There is a pump there within the I
i confines of the sheet piles.
It has not been operati ng
$a for several months, but there is one there that was
{ operating for a while.
i O
Why is it not operating?
i*
A I think there was a mechanical problem and 2
i we didn't see any reason to fix it at this time, e
9 0
Are there other dowatering pumps operating i
i E now?
E.
A Yes.
5 E
}
G At what rate are they pulling water out of the ground?
A Two hundred thirty, forty gallons a minute, I think, is the most recent figures I've seen.
O Are there other places on the site where sheet piling has been used for dewatering?
yp -
x i
4 130 t
c, LA Yes..
G
.Where?
.A
'Around the intake valve house down at the
-lakefront.
When the inset-was built, it was used'in A[ conjunction with well point dewatering.
Well points b
15
' -were used first and then sheet piling, also.
0 Why?
l:
-3 j
A' Because of the depth of the excavation, to a
j minimize the amount.of excavation required, I
t O
.Any other sheet piling driven in conne etion
- with dewatering at the Bailly site?
!j A
They're sheet piling down at the west side
?
i of Unit 8.
The slurry wall ties into that on the i.
L i south'end of Unit 8 and again on the north end of i
i l
Unit-8.
i G.
Why?
A Because the space available to operate the equipment up next to Unit 8 was inadequate to put in a slurry wall.
G So that the slurry wall does not completely encircle'the excavation.
. i
rc y
k'
'*~
131
.c A
~That's correct.
G-Part of the underground enclosure is slurry
-wall and part.is sheet piling?
A:
Yes.
G; What distance'does.that, what lateral 5
-3 distance.does that sheet piling cover?
~.:
c o
A Probably a couple hundred feet.
y.
5[
O Roughly the length of Unit 8?
-e A
It's not as long as Unit 8 because the Y
U north elevation of the. nuclear plant is south some i
- 1-E~eighty feet of the north elevation of the fossil 2
plant, so it doesn't go all the way.
i r
G Any other sheet piling driven?
e l
A Not tha t I recall.
I
[-
0 Are there plans to put sheet piling around i'
E
$ other aspects of-the excavation?
~ij A
There are plans to put sheet piling around I
the tendon tunnel inside of the present sheet piling in the reactor building.
G Will the tendon tunnel have a bottom t
elevation below-that of the reactor building to which you 14 ave testified?
d
l I,
132 s
A Yes.
O How far will that go?
A This is only an estimate, but I guess around minus twelve.
G And the clay layer's at minus ten?
s A
Yes.
5 l
0 What is the thickness of the clay layer at point?
- that i
?
A I don ' t k now, but I would guess it's 5
[ thirty-five feet or so.
l G
Why do you guess that?
ij A
Because that's approximately halfway between i
i i the south end and the north end.
It's eighty feet at the north end and a few i
i feet at the south end, so half of eighty feet is i
- roughly thirty-five feet.
5 progressiob G
Is it a straight line curve, the l
the thickness to thinness?
f, o f l.
A.
No, but it approaches that.
I G
That's based on the borings you've done?
A Yes.
G What are the dimensions of the tendon tunne:.?
I i
I 4
t 133 A~
It 's circular --- I don't recall.
G.
Approximately.
1 A
Eight feet diameter.
G When-was the decision made to put in the Oj sheet piling around the tendon tunnel?-
N A.
I don't recall when that decision was made.
i It was discussed in~the construction
~
- permit hearing and'it was stated there that sheet E
l piling would be used in all places where it was
[necessary to go below minus four, as I recall.
p
. l 0
Do you. recall why the company decided not to
{.j dewater below minus four?
l A
I don't.
I e
G Not to dewater below minus four at places i
! other than those. enclosed by sheet piling.
l A
No, I don't.
i-l
.G' What, if'any, other changes can you tell me about in connection with the company's plans for dewatering in conjunction with construction of the Bailly. plant?
A I don't believe I can tell you anything else.
G Let's take a short recess.
q 4
n
- s v
~ >,
134
.o (Whereupon, a short recess was taken.)
.MR.
VOLLEN:
'All right.
.Shall we resume.
O Have you thought of whyothe company lcommittedtonot dewatering below minus four?
h; A
No, I haven't.
1 O
Is it or was.it, Mr. Bohn, because of 5
!.; conc ern about 1 the off site effects of' dewatering to.
a deeper leve'l than minus four?
f-A LI don't see why there would be anything 3-
- , magic about minus four in thatievent as opposed to l
- [minus six.
I don't think that's a o
J l
}
O You do not think that was a reason, 1
?
' concern, about off site effects?
I l
~
A No, I don't recall that being the reason.
G Do you know where that commitment was i-2; made, that decision not to go below minus four?
i A
I assume it's in the, I assume it was made in the CP hearing.
G Over what period of time does NIPSCO's plans for site dewatering contemplate that dewatering will be carried out?
m e n
=,,--m s,
m r
y Y
115 l-r f
JL -
- You mean, additional dewatering?
We've been dewatering, of course, since 1977.
-G_
.For how-long to NIPSCO's --
.MR.
EICHHORN:
I'm showing him --
l MR.-VOLLEN:
Okay.
[al Why don't you let me ask a question first
?.
I before you give the witness documents which may conta Ln 5-j.some1informationrelative to his answer.
.i MR. EICHHORN:
All right.
II-u By Mr. Vollen:
i 5'
5-O
~For how much longer do NIPSCO's plans
-3. contemplate that dewatering will be carried on?
?
f Answer the question, Mr. Bohn, without s
~
! looking~at any documents that Mr. Eichhorn is giving
[ you.
e s
MR. EICHHORN:
The reason I'm giving him the
(
document is that question was asked in his prior
-deposition and if you are going to repeat the questions, Itthink he has the right to look at the answers that he gave previously.
4 MR. VOLLEN:
No, he doesn't.
You want to object to the question, object e
,n.w.
~
W
(?'
M i
t 136 m
1, i
to'the: question, but please: don't give the witness r
documentsi-vo look.at'when there is a pending question MR. EICllH ORN :
Very well.
I will object to the question, instruct the jwitnessEnot to answer it.
It has previously been i
." answered in the previous session of this deposition.
2
.By Mr. Vollen:
Ij
.0 M r..
Bohn, will you answer the question?
6
- 3 A
On a'dvice of counsel,'no.
V
. a l
G-To what depth has dewatcring been carried E on since 1977?
I*
A Approximately minus'eight I'm'sorry, I' i plus L ei ght.
7 4
At what point will the site be dewatered to i
. j' a lower leveli i
A When it's necessary for us to excavate belod f
1
[ plus eight.
O Is that the bottom of the excavation now?
A-Yes, approximately.
O When will it become necessary to excavate below plus eight?.
To drive-the piles in the reactor building, A
w-q-
s.
e g.
137 1t r
u a'uxiliary building, rad waste building, and off gas filter building.
0-To what depth will you dewater then?
I A.-
To'the minus four, I believe, wa s. previou s1:7
.,-i stated.
'e 0
G For what period of time do NIPSCO's plans i
- contemplate that dewatering will be carriad out to
}.-
the water level at the site, at the excavation
! maintain Lat minus four?-
{
A Same question.
I a~
~
l MR. EICHHORN:
It is, indeed, and I will make the
~
l t
j same objection in that it's been asked and answered, i
I j instruct the witness not to answer unless he has the i
o L
i opportunity to look at his deposition to see what i
~
E answer was given when it was first asked.
t i
By Mr. Vollen:
i f
G Do you know the answer, Mr. Bohn?
A I won't answer on the advice of counsel.
O After whatever period of time it is that NIPSCO intends to engage in dewatering to hold the, to bring and hold the level of the water in the excavation to minus four, what are NIPSCO's plans with i
.' _.- i.
~
w w
,e
_ _i
,,w-.
e, e
-e--
r 138
' in
': v n
. respect to dewatering?
A Well, when it's no longer for construction purposes to hold.it down at.that level, then-the dewatering would be reduced to allow the water level
!LocomeLback.npto the p oint where it would be A
$ re~guired to hold.it down for construction' purposes i
- and, finally, when construction gets up to grade or 5
I thereabouts, dewatering would be discontinued.
a G
What leve' is grade?
{
A-P_us forty.
t
'O And that's approximate ly the level of the i* ground before :he excavation started?
I l
i-A Yes.
e L
O Do you know how long after the period of i.
i E construction when you want to maintain it at minus
- four it will ha before dewatering to allow the, before i-jdewatering will be trrminated so you would be at grade?
A After the water, after it's no longer i
l
.necessary to hold the water down to minus four, the i
foundation itself would all have to be poured.
}
It would be a dort period of time, another j
1 v
r w
a 139 few months, probably.
O An'd at the end of that few months after you concluded it's no longer necessary to hold it at minus four, the company's plans are that there will be g no dewatering at all?
?
A Yes, that's correct.
Ij G
At any time during the remainder of the I
construction period.
l A
No, I think we're talking about the main i
7 building block.
l The pumphouse, for instance, it will be t
j necessary to dewater for the pumphouse installation 3
i down at the lakefront.
It may or may not be going 5e i on at the same time as dewatering for the main
! building block.
E E
j G
How much dewatering is contemplated for the
- ( construction of the pumphouse?
A Whatever time is required to get the foundation cleared up above the lake level.
O What is that period of time?
A I don't really know without looking at a schedule.
A period of several months.
I
140 s
x O~
How is that dewatering going to be done?
A I don't-think we finalized that.
It may be well points', it may be sheeting.
My guess <is it will be a combination of the two.
~
E s
g Is that'pumphouse within the confines'of the excavation?
i
~
{,
A.
No, it's not.
It's down at the lakefront.
l i.
O Right'on the shore?
i' g-l l-i'A Right on the shore.
Well, within fifty or a hundred feet or i
l something like that.
It's not right on the shore.
i l
{
G.
Is that'a Class 1 structure?
i l
- j A
Class'l structure.
MR. LEWIS:
I'm sorry.
I didn't hear that answer.
i l
i-I THE WITNESS:
Yes, it is a Class 1 structure.
MR. EICHHORN:
May I clarify the record, withdrav ix j an objection and permit you to ask a question.
t i
The question you asked in the first deposition was what were the plans in 1974 for the period of time that it would be required to dewater j'
to the elevation of minus two or minus four, the question says.
I believe you asked the question this J
t-o
_.,.1 u 4
-rv-..
- - - ~,
.n r-.
r
7
~ :.
~a 141 e
.,e C-time in the~ context'of present plans.
I, therefore, withdraw my objection.
I apologize.
I wasn't given the opportunit r to look it up.
I have now looked it up and you may R!.ask;that. question.
A N
MR. VOLLEN:
Thank you, t
Miss Reporter, can you find it?
3 (Questions read by reporter as l
follows:
U "For how much longer do NIPSCO 's i
[
plans contemplate that dewatering i
will be carried on?"
5 l
"For what period of time does
?
NIPSCO's plans contemplate that l-dewatering will be carried out 5
l to maintain the water level at
!e i.
the site, at the excavation at minus f our ? ")
MR. VOLLEN: The reporter has just found two questions to which you have objected and instructed the witness-not to answer.
Do I. understand that you are withdrawing m~
fe e
b a
y-
.=
142 your objection -- I don't care about your objection
-- are you withdrawing your instruction as to both questions?
MR. EICIl!!O RN :
Let me hear the first question lagainand the preceding question.
ij (Same questions read by reporter.i i
l MR. VOLLEN:
The reporter has just reviewed the
$j record and read for us two questions that I propounded I
I to which ynu objected and instructed the witness not j
l to answer.
E Are you withdrawing your objection a;.
E finstructionas to both questions?
MR. EICilllORN :
Yes.
?
MR. VOLLEN:
I am going to ask the reporter in Ij the transcript to repeat the questions.
G I am now going to ask Mr. Bohn to answer the
- !lcarlierofthe two questions to which is counsel I
I objected and instructed him not to answer.
A Which is?
O Por how much longer do the company's plans contemplate carrying on dewatering?
A The bounding figures would be eighteen to l
..~
143
. thirty months.
0-What do you mean by'" bouncing. figure"?
.A In o ther words, probably no less than eighteen and no more than thirty.
.R 5
g Months from the time construction resumes?
A n.
t
'A
.Yes.
i 0
What assumption does that make?
What i assumptions are made in using eighteen to thirty fmonthsas the bounding period, Mr. Bohn?
A I think if construction went well we could i
I.
l
[probablyhave the buildings up to grade in eighteen l: months a nd if there were unexpected delays, for
\\
I l whatever reason, it could take as long as thirty i
?
months.
I Obviously, if you were faced with a court l
$ order stopping construction during that period of time, 1
- 3. j which I'm not contemplating daring the eighteen to r
thirty month period, it would be longer than that.
O Or if the problems were encountered in connection with the piling installation method during that period, you could have a longer period than 1
thirty months of dewatering.
~
1 1
4.;
x2-i y
144 e.
A That's.a rather hypothetical question in my opinion, in that we have driven two thousand piles already with the method we plan to use, and I wouldn' t
anticipate any problems in that pile driving from now C' j ' on.
i O
Where is the turbine building vis-a-vis
' the site?
l; A
It's the northernmost structure in the main
$' power block.
O.
That part of the site where the clay layer 1
i
[ is.the thickest, according to the 3
A Yes.
!^j O
information you have, and it's in that 9i part~of the site where the two tnousand piles have 1
E been driven, is that correct?
I A
Yes.
'i O
So you don't really know what's going to happen when you start driving 'ots of piles into that part of the site where the clay layer is thinnest, do you?
A The forty closely spaced heave pile cluster that was-driven was about the middle of the s:. te.
a
,#4 m.-=.-r
c.
i s
145~
4 We have driven other piles on the south end of the site for testing purposec.
We see no reason to expect difficulties.
O But you don't know, do you?
E A
We do not know.
I h
G Now, I am going to re-propound and at this
- point ask the reporter to put into the transcript the l
- second of the two questions I earlier asked which Mr. Eichhorn objected to and which he has now
{ withdrawn his objection as permitting you to answer, I
[namely, for how long do you intend to hold the level i
{ at minus four feet?
Ij A
My estimate would be twelve months.
G What would be the starting point of that i
I estimated twelve months?
Whatwould be the end point?
E A
The starting point wouldte when it was
!! necessary to dewater below plus eight which is where we are now, and the end point would be when the foundations are poured.
I don't mean the walls, I mean the foundation.
All foundations, to the best of my r e c o.11 e c ti o n, are above plus eight, so our present c
'~,, - < ~; - -
'46 dewatering which taker ~it down to plus eight would be adequate at.that time.
'O Your estimate is.that from the time you resume construction till you drive the pile and pour t
i g the foundation for t..e base of the buildings would be k
-l accomplished.in' twelve' months?
~
i A
I said that would be a minimum figure.
~ i than twelve months, certainly.
- I' d say no.lcss
' I a
O liow much more.than twelve months do you l think it would be?
I
[
A ~
Twelve to eighteen.
Eighteen should be a i; max.
l 0
You testified that the clay layer is eighty
?,
' feet thick at the north end of the excavation.
i A
Yes.
I O
What is the elevation of the top of that I
A Minus ten.
O And.to what depth?
Is it your testimony that the top of the clay layer is at minus ten throughout the site?
t.
A Apr oximately, yes.
O To what depth do the pilings in the turbine c
- 3 c c
s y
y
)
e
.c.=-e.---.,y
--y
n l
~
v 147 I,
-n u-room go?'
A In that the clay-layer is wedge-shared, the r "sre~ longer than they are on the south of the turbine
' area.
}~
O Do they penetrate the clay layer?
A'
'Ye s, into the lacustrine deposits.
{
5 O
Is it contemplated that the short piles in i
.ftheClass-1structureewillalsopenetrate the clay l layer?-
I U
l A
It is.
E
~ {
E G
Including in the reactor building?
- [
A Yes.
i G
Where is Unit 3 in relationship to the 7
o; clay layer at that part of the excavation under the t[ Class 1 structures, the Unit 3 aquifer that you
~
. =
testified about earlier?
. i 3
A Unit 3 is the layer under the, bounded on the upper side by be wedge-shaped clay layer and bounded on the lower side by the glacial till.
O Glacial till?
A Yes.
G
-Is that the same as the glacial lacustrine 4
4 1
w e,Memmebee 4 eh m '
y. #y g-yn,
--,-,-..---+.--.r 9
,_,-r+--.--m
gM:
s
,e g? -
~
,y-148 V
~
c M
T rfN f
deposits?;
A.
Those'are:the same'as Unit 3.
They are also bounded on the top by the Unit 2 clay layer and
-on'the bottom by the glacial till.
R 3
G.
And it's into ti. t Unit 3 that the thort I'
-l ' piles ' will be driven, according to the present plan?
i A
Yes.
"I.
1 G
What,.if any, studies have been done on the
!a effect of-penetrating the clay layer with the piles
'Jinto Unit 3 on'the amcunt of dewatering needing to be t
done to relieve the hydrostatic pressure in Unit 3?
t
{
A I'm sorry.
I don't understand the question
}
+
j G
Would you read that question?
E (Questio.. read by reporter.)
i-i.r By Mr.Vollen:
5 j
Q.
Do you now understand the question, Mr. Bohn?
i-
_f A
I believe I do.
The effect of driving the piles through the clay layer will have no effect on the dewatering.
G The question is what, if any, studies have been done on that?
A We certainly know t'ae character of the clay,
~
~
v
g-s l
149 We know its permeability and there is no resson to think with any knowledge I have of the work that's been done that it should affect it at Lil.
e G
What is the design of the foundation for
[ the pumphouse?
A Basically the same as the other Class 1 a
structures, in other words, piles supported by 4
P
!: concrete mat.
r j
G Short piles?
i A
Those may be long pilcs because the clay a layer is so thick at that point there is practically no -- and, in fact, in some cases there is no Unit 3 i because Unit 2 is all the way down to the till.
O Precisely whether or not that's the case at ii the pumphouse, I don't recall.
It may be that by the i~
2 time you get through Unit 2 you are at the glacial s'
ltill.
It's very close to that, anyway.
They are intended to be short piles in that they are intending to go through the clay layer into the glacial lacustrine deposit, but at that point I think it's almost moot.
G You mean you may have to drive long piles 4
l
_ - _ - ~. _ _.... _..
^
p=t; "15C e
iw' ether you-want to cr not?-
h 1
.Yes.
- 0. '
Has the pile design for the'pumphouse-been
' submitted by NIPSCO~.to the staff as-yet?
4
. A.
I believe'it has, yes.
~
E, G ~
- Does the March ~-5, 1981 staff SER on the pile 5
design include a review and an analysis of the pile
- 3. design for the'pumphouse?
A
'As I recall,.there is some ambiguity there
{ in our thinking because I believe it reads semeplace r
[astifithat information had not been submitted to the i.-
i l
fstaff-where, in fact, it has been.
I really can't
!j' answer the specific question.
.E i
a The question is not what has been submitted I
L 5 to1the staff but what is, does-the SER review the 5
piling design for the pumphouse.
i '
-s
[
A' The way I recall the SER reading, and I may I
be inaccurate, is they are expecting further input
.on.the pile design-for the pumphouse.
That's somethi ng r'
that'would have to be clarified.
.0 Are you expecting to give them further
. input?
i u
=
crn;
~
(q u
- g,
il I.
. + '.
c.'
x.
e.
151
~
4 A
We expect ~to' clarify-it.
G..
5.What do1you mean by-that?
x A
Make--sureathat there is no misunderstanding
.in that theyfare expecting-something=that is.not o
,i forthcoming.
1
'l G1
-Is there currently any dewatering carried 6
outibyLNIPSCO in connection with Unit 7'or' Unit 8?
5-3; A.
.Yes.
j G
. What dewatering is that, Mr. Bohn?
.u.
j A
There-is ash; pond' sealing. dewatering going t
',s.
..on.
. E.
tj; The' operating-engineers are on strike and 4-Ij have'been, I~ think, since the first week in June, 9
- sof
- the sealing process is not being accomplished.
.3
[ However,-the dewatering continues.
i
_{
- G' That is the dewatering-being carried out in
"=:
_i. connection with the company's sealing of the ash ponds?
A Yes.
G-Any'other' dewatering in connection with Unit.7-or 8?
. A No dewatering, to the best of my knowledge, where1it's pumped, in other words, where there is any
_ j.,
e-w A
e e
b s
.g e*
w,- e e s-1
--m',,
3 n,'1--
v-r.-e--r>wm'
g_ -.. 3.. _
p%:,1 g
152 a
,. } s
.'. r :e -.
~
L
.pumpingforLanything: going on,in the-natural-flow of
~
Le
~ water.
. G.
'What natural flow of water do:you have in
^
mind, Mr.~Bohn?
I A
When: Unit 17'was' installed there was a
.t.
--,-[ gravity' drain put'around the foundati'on.
G
- Yes?'
u 3
' And.as f ar. as-I- know, it's still there.
.O A-Eg G-
.What-does that gravity drain do?
h
, Allows the groundwater to seek the drain'
~l.
' and. drain;off the. lake as it does anywhere.
'{-
0 Drain.off the lake?
?
1 L
~
.j.
A-Drain off'to the lake.
9 0
That is, i n :- e f f e c t, dewatering, isn't it?
i'
~
-5 A
' Not in my opinion.
A L
O' What is it in your opinion?
-3
[i :
A.
It's a drain.
t\\,
t l
G
- To divert groundwater away f rom the f our.d a t ion of the unit?
A Yes.
G Is there such a gravity drain around Unit 8 7 A
I don't know.
I wasn't involved in that w
g-m, y eems.a w
ai e = a e-
- g..
F :,
n.:
$?
c 153 c r.
v
. unit-and I don'tiknow if there~is or not.
Of Do the~ plans;for construction of Bailly contemplate a ' gravity drain around the foundation ~,
- BaillyiN-l?-
)
~JO
' Tha t 's something/that will probably be
~
k E discussed with the staff at one time to determine whether
(
or not they:are interested in having a drain around
}
r i it so~in the event, for instance, you had an 5
-; accidentLand radioactive water were to leak through 5
'I some fissure in the foundation or whatever and get into
't
.s.~
g j the groundwater, that would be an opportunity to 7
d 4=j interdict that. water.
}.
I understand from discussions with the E
staff that something is being contemplated on other a
.g-
~
$ units. That m.y be something that they'd be interested i
x 3
in having us do as well, put in a gravity drain
..i.
!around the foundation.
O Are. there currently plans for such a gravity drain around the foundation of Bailly?
A No, I don't believe so in that I don't think there have ever been any drawings prepared that shows any-such' draining.
I i
l i
_=-:n i
\\
x
,jy; a.
i
.i i_
ti 154 As far-as current plans,.I.would say no eve :1
..though I would not be surprised if-the staff expressed interest in.having a drain there.
0-
.Are there.any plans for any form of
.):dealingwith.grounowaterafterconstructionofBailly
] at ~any time af ter construction of Bailly reaches 5~
-' ' grade ?'
A No.
c' g
0
_No sump pumps contemplated?
[
A.
The~only-sump pumps would be within the i
r-
~
- structures themselves which take water from leaking
)
'?{ pipes, whatever is insiue, not what would accumulate 4
~ j groundwater.
o.
0 Aren?t there any plans for dealing with-the i
..i E possibility of groundwater seeping through the below sa
- .crade portions of Bailly?
E A
There will be designed into the plant internal sumps that, in the event water did come through the walls, it could be pumped out without laying on the~ floors, yes.
0
-I s it contemplated that any water will leak
.through t he walls or floor?
,4c w.m e sde 4%
=. :
g _-_
=_.
J y.
I
'155 7
A.
It.was ' discus' sed in detail'in the hearing-for_the construction permit.-
Concrete structures are rarely one hundred percent waterproof.
I'would be very surprised if.there hwasn't~someleakage.
N
-. -l :
.G
'Through.the walls or through the' foundation
~
.i J;-floor?
[;
A Yes.
.G Are there.any plans to in any way divert
{ water ~away, groundwater away from the walls below j grade or from the-foundation?
Ij A
.Only in the event that what I previously
?! stated-comes to pass.
a-0 That of the staff requiring or desiring i
E a' gravity drain?
A Yes.
' l 2i Obviously, it's something that we could i
do during the-construction process.
For instance, if the staff expressed an interest.and in the event it never was a requirement or never desirable, it would just drain into a standpipe, for instance, and never be used, but, in
.:.~_-.-.
_ - ~, - -.,
c
p y'**
Fa' 156 E l
.other;words,--if.you put one in it'doesn't mean you're
- going.to use it'andfI'm saying if there1is an interest'in
- puttin'gLoneLin during the construction
- process, we might;do that..
J g
Why was'a gravity' drain put in at Unit 7?
c.
k-A To; keep water from the construction walls.
- r' I.They are not' sealed.
-,[.
l The Unit.8 wallsLwil'1 be sealed'with what-
. h ever the materials were that were testified to, I 1.
u
. think various layers of : tar and plexiglas and all the
.I things you seal foundations with, and I understand ~
t~.E they are very successful.
O I think you'just said Unit 8.
You mean the f n'uclear unit, don't you?
i-l
.A-Yes, that's what is contemplated.
5
[
Now,-Unit 7 has, I don't recall any I
waterproofing done to those walls and I wasn't there.
[
0 What about Unit 8?
A I say~I wasn't there during the foundatica construction on Unit 8 and I don't know.
O And the nuclear unit, it's contemplated to do. waterproofing?
i I
/
s
- ~. m,
N:ff N,
157
+
-+
A' Yes..
9
-Q When i's the-first.. time that, the earliest
-date..ofJwhichiyou had; knowledge.of NIPSCO's plans i
. f or: monitoring the effects of its dewatering program
!--in'c~onjunction witb'the construction of Bailly?
%2 JL The commitment, of course, for.the dowatering monitoring' wells was made during the heari ng 1
j and? installed immediately thereafter.
4 0
Is that the earliest you know of the
.' monitoring plans of the company?
l
]
A-We did some preliminary monitoring before l
I that ourselves..
I don't recall what the extent of 2
i it was.
e We monitored, I think, perhaps a couple.of
~
l
[:
i the interdunal ponds and certainly our own ash ponds.
i 3
- 5, That was not part of the plan submitted to or
- i i approved by the staff during the hearing.
O When.did you do that preliminary monitoring?
A I think'we may have started that in
'72.
There may or may not be any record of it any more, out I believe:we did it.
4 What did you do in '72?
el
-s f
.W T
epQ'e4
3.
r
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158 F
g A'
Just recorded elevations, I-believe, of ashiponds, 'and I'also think it included one or two of thelinterdunalLponds and I don't know if it was
'once'a week.orLonce.a month, or whatever, but I'm O
jEsure weldid do-some monitoring there.
N O'
That monitoring consisted of reporting 3.
elevations, I think you said.
I.
A Yes, I think so.
G Water level elevations?
A Yes.
- w I.
O By what means?
Ij A
'Not groundwater level elevations but pond
~
. j water elevations, in other words, visible water.
G How did you record that level?
e
.I
- E A
I don't recall.
I didn't do any of the 5
=
- actual work myself, but I do believe we had someone i
! out from our staff that took elevations from time to i
time.
O Do you know whether records currently exist as to the A
No, I do not.
G as to the information recorded.
i 4
g35 mye m-er aie em we
- 6
=
35 3 -
~
'e Q
159 a
g
' A. ~
No,- I_ don't..
I G
If they did exist, Mr. Bohn, where would
!they_be?-
.A I would assume if they did exist they would
!'be in our groundwater.! monitoring files.
i"
-f I think you've been provided those, as fa r y
- as'I k'n o w, and if.youLdo not have copies of them,-
Ii'maybe they;do not exist.
$~
s-G~
And _that's the earliest-record that you
~5 hk'now of'that NIPSCO had of recording, of doing any
_," monitoring,.is-thaticorrect?
t'j.
A
.Any monitoring?
l-G Right.
c.
r A
Of my own knowledge, yes.
i
~
E G
You don't know of any monitoring done prior
- i. -
, to this recordation of pond level elevations in 19727
's A
I can't think of any.
G Aside from this, which I think you've
~ described as preliminary monitoring in
'74, the
. monitoring program, you said, was testified to in the construction permit hearings.
A Yes, there were some adjustments to the O
b 4
s
160
?
- ~
programfmade'during~the~ hearing to accommodate the
~ wishes df.the staff.
-4' Can;3 9u describe for us what that monitorin g l program.as adjusted to~ accommodate the staff's wishes
{ consisted ~of?
t A
It was basically groundwater leve,1 monitori:1g 7
7
{ wells-and the adjustment for the staff,-I believe, 5* included additional. wells ceyond those that we had l'
, [first; proposed.
.[
O How many such wells were involved in the
.*e.
C E monitoring program?
l A
It runs in my mind that the first ones z.
that we were committed to by the construction permit 0i hearing was something less than ten, like seven or z
[eight.
4 4
Can you describe for us where those seven i
j or eight l-
=
groundwater level monitoring wells were located or were to be located?
A They were located basically between the excavation and the-Indiana Dunes National Lake Shore.
O On whose property?
A On NIPSCO's property.
g
.-.y
E..
161 J
.g'
~..
- g Were those seven or-eight. wells, in fact,
~
- 1nstalled?
A Yes.
O
'When?
~
A I belie've in-either-late '73 or early ' 7 4 ',
1
-[ 'I - think ' the firs t group were installed.
I don't
.I
- recallvbich.
5 i;
O
.Before the construction permit was issued?
~$
i A
I believe so.
5
{
G.
Did they begin recording groundwater levels
.t l immediately or promptly after they were installed?
..:j A
Yes, they did that.
i f
3j My memory could be incorrect on when they
?
i were installed.
There may not have been any installed 1
E'until after the construction permit issued, but it 5
- seems like they were installed before that.
i O
Were they installed before excavation began ?
A Yes.
I G
How soon before excavation or how long before excavation?
A Excavation did not begin until it began
-~
in '74 I'm sorry, I don't know.
c
- 1
kl *
$.1 e ici 162.
. ' n,
- g:
'You don't know when.they were installed?
A No, not' exactly.
GL LHave those seven or eight wells which were
~
installed atesome point'have been in operation-from
..' Olj-the' time-they were instal' led up to and including the i
j
. -h present ' time ?
j
- A(
There may be one or-two that were abandoned,
_j'
.; but there's.been many more added.
O' Let's stay with those original seven or
-l; eight first. EOne or two of them --
r.'
E
'i been abandoned.
They may all be A
May have j in' operation,'I'm_not'sure.
,5 0
You don't know?
- =
A No.
I
-j G.
Who knows?
c l.
A That's presently under the purview of i-C lAl-Severance.
I think he would know.
O Is he the person on the nuclear staff that knows.the most about the details o'.
the dewatering monitoring. program?
A Presently, yes.
.Q You say that as if at some pr'_or time i t a
e, M
W N
y
-4 ve y~
163 p
+
=;,
' e was someone'else.
A
'I think-it was John ~Dunn's.resevasibility when1he'was.there.
p G
Now,-subsequent to the time of commitment
~
htothe ~ seven : or eight. wells, did there come a time M
- when there was.a change in the monitoring program?
.j.
J A
Yes.
5!
.1 G
When wasithat?
0 A
When we-went to the slurry wall and in
] conjunction.with the jetting.of the piles the staff
- requested that'we install some additional monitoring i*: wells, as.I~ recall.
l 0
-Those are t'wo separate events?
o
.l '..
A They are two separate events, but I don't
'know that they are two separate series of wells.
l They may just be one, in othe r words, the i
-f;slurrywallwas installed in early
'77.
G LAll right.
A The jetting began in September.
I think the welle were installed in conjunction with the jetting of the piles.
-Remember, we were circulating a lot of water L
1, r
L
p.,. =;
164 I
.r' l
'and had we pursuedithat, that's the way we would have
~
~done it.
The staff wanted some additional wells; wenput'in some additional wells.
R 10 That was'in '77?
c.
.a-
- L D A.
. I: believe 'so.
5 A.l 0-
-Before constr.uction was halted or after?
-g.
[
'A About'that time.
There may have been 4'
'c i-some installed before construction, the rest after, V
Ibut it was about that period of time.
~ O' And-additional wells were put in at the
- $' request of the staff?
J' E
A Yes.
.G
-Ilow many?
I
[
A I think we have more than thirty total now 5
land I don't recall whether there was another time that s'
3 we put in wells after that for any other reason.
E.
Therefore, I would assume that we added some twenty wells or so during that period of time.
O Added twenty to the seven or eight that you originally had in?
A Must have been.
O 7-y
g,-
g-*.
- a..
p 165
.:~
t r' G-
-Do7you know whyjthe' staff wanted you to add an. additional twenty wells?
A-Their. concerns were the.large amounts of-water tnat we would be! recirculating and-using for-g jetting the piles.
. g-Of course, wefinjected water down-into the 5-confined aquife'r and-they. wanted to know what possible a
e j effects 1this could have and requested the addition
. e j-of a number of wells, as I recall' I
W.
G Because offtheir concern atout the' jetting?
E A-Yes.
f G
~ Where are the additional twenty wells?
l A
They are in roughly the same area between
' e; the site, the excavation and the Indiana Dunes National
~i[-Lake' Shore.
5 The re were some added on down towards the
- =
1 l
j. east end of our property as well and one over next
~to Mineral Springs Road.
G On whose. property?
A That would be on the Park Services property O
In the National Lake Shore?
A.
The National Lake Shore.
G
'That's the first monitoring well that NIPSCO's
-,, m 6W ee NWg D
i
_ g-W~
~
+
p ie---
4m 166 L
insta11edvin the Indiana Dunes National Lake Shore?
-tu I believe that was the first.
O When you say to the eastern part of your property,.is that the area that is south of the
. hNational.LakeShoreboundary?
.y.
c.
A Yes, the one I mentioned next-to Mineral l Springs Road is not on our property.
There are other:s l=
- onour property that are south of the Indiana Dunes National Lake Shore, yes.
h 0
You said the staff required or requested the 1
i' additional twenty wells be put in in '77 at about the i
! time construction was halted.
E l!
Did NIPSCO, in fact, install the wells?
E-A Yes.
\\
'I 0-
-Did they begin operating?
l A
Yes.
i-G And have they operated from that time until the present?
A Yes.
O subsequent to that, have there been any changes or alterations in NIPSCO's dewatering monitor.- ng program?-
9 4
j
a.
~
j g. : "
e L
-167 d'
a A
In conjun'ction with the hydrostatic heave monitoring concern, I believe there'were a couple, at least'a couple more added during that period of time in, like,.'79.-
i o
k 0
' Excuse me,.you said in that period of time A
-[ and.'79?
i
-l A
In-1979, I think.
During the period'of time that we were
.g.
i pursuing resolution of the hydrostatic pressure in I Unit-3, we installed some additional units, some w
t e'
," of which I testified to earlier when we added tj'piezometers.
Those are still being monitored.
J G
Are piezometers monitoring wells?
9 A
A piezometer is a monitoring well, yes.
i.. E It can be used as.
5 O
Those were the two I think you mentioned
's s
~i that you added in the excavation.
A.
In the excavation.
I think in addition to that there were a couple monitoring wells added outside of the excavation, I: believe.
O In connection with the knowledge of the s
~
tp., -
c..
ITb 168
,m h'ydrostatic pressure problem?
A Yes.
G Which resulted from the slurry wall.
i A
Then we were monitoring, of course,' water
- elevations _in Unit l' and Unit 3.
N In several of'these wells we put in i
'I combination wells, two wells side by side, one of
' !s which monitored pressure in Unit - 1 and the other
. a' monitored pressure in Unit 3.
6 G
Those -wer'e installe in 1979 as a result t-i a-
.l of the knowledge of the' hydrostatic pressure problem 0
$ in' Unit'3, is that correct?
!~
l A
I believe that's correct.
E G
Those are in the excavation and some
.Ij outside the excavation.
5
. l A
Yes.
i l.
The ones in the excavation, of course, monitor only Unit 3.
G The ones outside the excavation are located
.where -- of this group that were added in '797 A
There is one near the southeast corner of the excavation on the outside of the slurry wall.
_.-m4+
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.a4
,4,
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~
169 g_
3-There-ist one-or.two on the east side of the excavation '.
ThereEis'at least one over-in the green belt area s
between_the plant: 'and the Indiana Dunes National Lake s,
Shore..
f
~
G
'Any. thing else?
A
-[ -
A' There may be.
Those are the only ones I.
i I
think of at the moment.
There are sever 11 in h<
$'can
[6
!' total.
V d
L; s
- j G
Whose ~ idea was it.to'put those in?
I",
i A
I believe that was a recommendation of our 1,,
^
[: consultants..
~
~
j 0
Who?.
E I.:j-A Probably Sargent &.Lundy with Groundwater
~
- 9.
D Tech Corps.
r-t L
i o
5 0
Did you discuss that with the staff?
l A
We kept the staff apprised of what we were i
5 j doing all'the way along, yes.
~
g
'Did you ask for their approval in that chnage in the monitoring program?
l A
That was not a change in that it was merely getting add'itional information.
I don't think they were concerned about getting additional information.
1
~
s
ks._,;..
- {
A-
-e 170
+1 O
Did-you ask=for. approval of.that getting of-additional.information out ofEthe_ monitoring system?
,s A
I don't think we did.
I.know we kept them
.O.i apprised.
i
[
-0 What, if anything, did the staff say about 3-it?
I_;
A As far as-I know, they were certainly in
!a concurrence with getting additional information.
J
{--
Q How many. additional wells were added as a
~'-
I 3 result of this hydrostatic pressure problem?
L T*
A I don't know.
L
.i G
Approximately.
o i
A We must have at least six that monitor both I
.5 aquifers, so it must have been at least six.
d e
O Does that give you a total of what, about l
i-
=
i thirty-five or thirty-six wells total now?
(
t-A Yes.
Somewhere in that area.
I
~4 Subse.aent to the installation of these additional wells in
'79, have there been any other changes:in the dewatering monitoring program?
A I believe we added at least one well when a
e
__,,,,-....,,-~,x
~
~~ ^
~ ~ -
~~
3 v.~,
) M.;
-s o-171
's.
-the ash-pond dewatering was about to commence between the excavation and the ash ponds, so we could better monitor what the' dewatering effect was of the
- ash pond.
[
.0 LWhen was that?
I
-l A-That should have been early '80 in that E
',, the' ash pouds were. sea. led last year in 1980.
I believe 5-3 i it,was just before that program commenced.
g-r a
G Whose idea was the installation of that I well?
I e.
A-I believe'it-was the recommendation of i
- Sargent &.Lundy that it would be nice to have that l additional information.
o I
4 Did you inform the staff of that?
I
.5 A
I don't know.
t 3
l There would be no reason to, obviously, i
s e
!.since it's on our property.
It had nothing to do directly with the nuclear even though that was why we wanted to-gain the additional information in case.it was pertinent information to use.
O Any other changes in the monitoring, the dewatering monitoring program?
.....2_..-.
s
7~
172 p
A Not that I recall.
G Any others proposed?
A Not at this time.
O At some other time?
g A
perhaps.
We'll see.
G Do you have knowledge that other changes
.i
' to the monitoring program will be proposed, Mr.
j Bohn?
0 A
No.
l
{
G Do you have knowledge any others will be i
,' required?
i A
No.
!i G
But your prior statement indicated that you
=
. can never foretell tlTe future, is that the point?
I_
8 A
Perhaps.
C.
O
~
Perhaps it indicated chat?
Ej A
Yes.
I G
Yes what?
A Yes, I agree.
You can never tell the future and we may have to add more wells.
G As you understand it, is your current monitoring program approved by the NRC staff?
fMea s
c v
u..
- y 173 e
C
\\u';
A-The current monitoring program is approved
^+
us by f the s.ta f f, yes, I believe that's true.
-G Do you understand the the NRC staff wants
.further information or further changes in the lmonitoringprogrambeyondwhat the program now
" consists of?
a.-
i A
In the. environmental impact appraisal....
. j; G
That's.the July '81 document we talked abou; 3 before?
A Yes.
t -
They mention that they would require the 2:
applicant to put in a confined aquifer recharge system a
u t
i and that that system would be submitted before the 7
0
- hearing is over, I believe are the words, and I do not 1-i know at this time what may be required with regard 6J
. to. tha t system.
i l
0 Recharge system is not monitoring, though, L
5 is it?
A
. Recharge system is not mc~iitoring, but it could be possible that they would require additional monitoring because of the recharge system.
G aut as of right now you don't know anything j
i o
~, +
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=
h e
y 4
- y.
- >-;,[ li;
~ -
'6
.174 r^'-
. about'the staff. requiring any changes-to your monitoring program?
'A That's' correct..
O
- And your. monitoring program then, consists e
l-Lentirely.of.che wells you have been describing in
~
.an
. f.._ ansker to my questions?
e A
Yes.
s f.
0.
Is there1any monitoring of pond levels?
e j-
.T..
Ash pond levels.
I don't believe there is
? any~monitcring of interdunal pond levels.
There is
! groundwater, but~I don't believe pond levels.
L w
A
.The ash pond levels those ponds are on L
2g NIPSCO.'s' property,:aren't they?
e' g
\\
-e c'
A Yes.
.' al G
.And the. plan is that before long those
(-
x 5.
I
< strike'that.
^
!~
j j.
When is the first time that you have knowle dge of NIPSCO's plans to mitigate the effects, if any, of P
si te dewatering at the Bailly plant?
A1 I don't recall when we got into that r
recharge system, mitigation system, excuse me.
.. G.
Are those two words synonymous?
4
..we
--=s
+
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y
- w 175 l.-.
i x,.
di
.9 A
'Yes.
O A' recharge or mitigation system was. discussed in.theoconstruction permit hearing, was it not?
A Recharge. systems were discussed'in the i
- 1 -
And committed to by NIPSCO.
5
. A. -
.No, I don't think so.
!j G
Required by1the staff?
dI A-No, I don't think so.
Iw
. hen was the first time, Mr. Bohn, that a O
W E
[ recharge or mitigation system was a commitment of i*. NIPSCO?
A.
I don't recall.
I G
Is there such a plan now that is a I
i commitment of NIPSCO, whether voluntarily undertaken
- l. '
- or imposed'by the staff?
r 1
A I don't recall that there was ever a commitment, I'm sorry, a requirement.
There has been a commitment and such a system has been installed.
O When was that commitment made?
A I don't recall that.
f
.u..
s
~.
g 9
-m w
w s w >
v, m
r, w
y n
-o.
$5 c
_176 m
eu
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cc G'
Approximately.
A' Let's_say, I'd say 1973 or 1979.
O Can you explain to us what that commitment i
is.and what the system is that's beca installed?
A.
The commitment, as I recall, is to mitigate i
-[ when the groundwater level declines due to dewatering M
I j-at.theeasternpropertylinemore than one foot.
O That commitment was made in '78 or '797 1
1 A
I believe so.
{
0 LWhat form did that commitment take?
i' r
~
A~
I don't recall that.
Ij We 'did advise the staff.
Perhaps it isn't l'
-l even a' commitment as such, but I know the system 9i'was installed and we advised the staff that it was V-
- 11_ instal]ed.
O Tell us what system was installed, Mr.
I i-Bohn.
A The mitigation system.
O Explain what it is.
A It's merely a rair of pipes that are perforated on their bottom side, strung down the east side of our property and connected to the water f.-
.c h
F
-2E
=
177 x
l a
that would be pumped out of the excavation and valved 3
so in the event it was determined that the groundwate:-
I had declined a foot or more because of our dewatering a
system, that water would be admitted to this, frequently 4
0i called a trickle recharge system.
,4 Water would be admitted into that system 2
5
,' into the groundwater to create a groundwater mound I
2 3
- between the pumping going on at the excavation and 3
0 the property line to prevent that drawdown from i
d
{ exceeding one foot.
1 i
s 1
l 0
Two pipes?
i j
{
A.
Two pipes, l!
j j
0 Running how, one on top of the other or
?
i parallel to each other?
=
E i
A.
Parallel.
2 w
O Are these pipes on the surface of the ground 3
5 5' o r 1
are they buried?
ll o
4 A.
They are probably six feet under.
- j 0
In an open trench or closed trench?
l A
Closed trench.
n l
k i
0 Six feet underground and covered on top?
l 1
l A.
Right.
[
i si C
E f
R L
a
r---
t 178 e
O Is there a means of measuring the flow into those pipes?
A Yes, I think it's metered.
O Over what length of the boundary, over what length of the eastern border of your property?
A I don't recall the length of it.
Several
' hundred feet.
I I
4 From what point to what point?
A I believe it encompasses the entire angle.
\\
If you drew a point from the dewatering i
a l system to the Jake shore, both north and south, I i
{ believe it would encompass the entire included angle.
Ij 0
When you say " lake shore," you mean Indiana e
Dunes L,tke Shore or the Lake Michigan shore?
I E
A Indiana Dunes National Lake Shore.
O The boundary between the National Lake Shore i
F,
[ and the NIPSCO property is essentially a north-south line, is that correct?
A.
The eastern boundary is north-south.
There is also one that runs east-west.
3 Right.
Does this trickle recharge system run along
}
179
)
)
the eastern boundary of the Bailly site?
A It runs parallel to the eastern boundary, f
yes.
O Ilow far from that bou6dary?
E s
A Probably four hundred feet, approximately, i
four hundred feet west of the east boundary.
Q.
What is its northernmost point?
{
l l
A I don't know.
5 0
How far to the shore of Lake Michigan?
A It's south of the existing fossil plants.
t
[
G South of the existing fossil plants?
}
A Yes.
1 j
4 Ilow far?
?
A One or two hundred feet, probably.
Somethir.g I
E lir,e that.
It would be a guess.
E.
l 0
What is its southern terminus?
i
}i A
Approximately even with a line, even with the east-west boundary line extended.
G Then there is no recharge system along that east-west bouadary line?
A That's correct.
O What was the occasion for the installation o.f l
l
180 s
that trickle recharge system in 1978 or '797 A
You mean why did we put it in?
G Right.
A Specifically why it was put in at the
! exact time it was is because the excavation was opened i
$ for other pu;? poses.
In other words, there is ash 5
- lines running from the present fossil plant all the I
- way down to the ash disposal area.
s They were replacing one of those ash lines 5
{and it turned ou: to be a convenient time to install
.i s
- ' a tricxle filter as well so we wouldn't have to dig i{a separate trench.
G I see.
That's the slurry line tha*. carries the ash
( in tne slurry f rom t he fossil plant to the ash ponds, s
3 l
A I t's Tn ash, it's a slurry of ash water,
!l sure.
I MS. RAPKIN:
Can I interrupt?
MR. VOLLEN:
You can.
I have.
(Discussion bad off the record.)
By Mr. Vollen:
O Is the location of this trickle recharge i
181 system four hundred feet west of the eastern boundary of your property determined by the fact that that's where the existing line was to put, to carry the ash f r om the fossil plant?
Oi A
No.
t
_l G
How was that location for the trickle 5
- recharge system arrived at, Mr. Bohn?
A
!j A
That was determined on the basis of where e! the most efficient place would be to install it.
Iw O
Efficiency is measured how?
3 A
Efficient in controlling the groundwater l level with a minimum amount of input.
O Input of what?
e e
I A
Water.
S 0
Through the recharge syster?
I a
A Yes.
l 0
The decision to locate the ash lines in that same trench was made how?
A The ash lines were already in that trench.
They were merely replacing one of them.
O So it was mere coincidence that the A
Yes.
182 r
0 that the most efficient place for the recharge system happened to be in exactly the same trench where the ash lines were.
A It may have been modified a few feet to
! accommodate
- 1a t.
N I don't know that that's true or not true, 5
but it was the approximate location determined ahead I
i of time.
8 0
0 Let's go off the record and deal with
! Anne's scheduling problem.
s
?
[
(Discussion had off the record.)
i*
MR. VOLLEN: Back on the record.
Ej It's now approximately quarter to 5:00.
?
i Counsel for the S ta te of Illinois needs to leave.
i.
E We have a lot of questioning yet and will not be
- able to finish this deposition in this time and, i
{there2cre, I suggest that we adjourn the deposition to be continued at a mutually agreed upon time.
Anybody have any problems with that?
(No response.)
(Whereupon, the deposition was continued sine die.)
_