ML20090A790

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Transcript of Lw Heller 801009 Deposition in Bethesda,Md. Pp 1-139
ML20090A790
Person / Time
Site: Midland
Issue date: 10/09/1980
From: Heller L
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17198A223 List: ... further results
References
CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8012100648
Download: ML20090A790 (139)
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Text

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CCNSCMERS PCWER COMPANY CCCKIT NCS. (Midland Plant Units 1 & 2) : 50-329-CL i ? 50-330-CL i ~ I 30- 32 9-CM 50-330-CM Cecesition of LI4AN WAGNER EELLER i i i I OA.~r: Cet=' er 9, 1930 ?AGzg: 1-139 c 3ethesda, Maryland I k I U h~ - 5... w. s .LLDtDti ML ' REPORn.TG l* %ti r1 t 4cc ri_v -u An., s.w. **' :r--, ':.. c. :cc:4 b.:

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I In the Matter of:

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CONSUMERS POWER CCMPANY Docket Nos. 50-329 OL l 50-330-OL (Midland Plant Units 1 and 2) 50-329-OM i N 50-330-CM j ________________x i 3 Nuclear Regulatory Ccmmission 10th floor j Maryland National Bank Building g 7735 Old Georgetcwn Road Sethesda, Maryland 5 OEPOSITION OF LYMAN WAGNER EELLER .-= The abcve-entitled matter came on for depcsitien, pursuant = 5 s to notice, at 10:30 a.m., October 9, 1980. 2 APPEARANCES: i On behalf of the Nuclear Regulatory Commission: g

sa BRADLEY JCNES, Esq.

3 WILLIAM D. PATON, Esq. 1 Office of the Executive Legal Director U. S. Nuclear Regulatory Ccamission 2 g Washington, D. C. 20555 On behalf of Consumers Power C=mpany: i

7. E. BRCNNER, Esq.

212 W. Michigan Avenue Jackson, Michigan 49201 i 3 t. t i ~ i ALDERSCN REPCRENG COMPANY. INC. 4

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== .= 3 Exhibits Identified 2 i-Censumers Power Ccmpany 1 5

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=. Censumers Power Ccmpany 2 77 ,3m Censumers Pcwer Ccmpany 3 80 .ua E, Censumers Pcwer Ceme.any 4 96 = Consumers Pcwer Company 5 108 23 t Censumers Pcwer Company 6 124 Afterncen Session 47 g .l 1 t t i 1 i ALCERSON REPORTING CCMPANY. INC.

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==* A .?..r name is Lyman Wagner Heller. g 2 0 What is your address? e aa-A I presently live at.lS605 Rolling Acres Way in Olney, ai =, Maryland. u Q Chat is olney? a s A C-1-n-e-y, Maryland. f E Q And vou are _eresentiv eme. lov.ed hv_ the Nuclear i Regulatory Commission? A That is correct. Q what is your title? j ) .s t s i 1 .i ALCERSON REFCRTING COMPANY. INC. -l

.;;..,.y.,r_.,., .e -f; q. - - - ~ ~,'_ Q s x. ~ .-.& *:Y *C ... a ~7K:: .*.~?~. i : ~L _.f. L-: -- -[ , Qppz* n...y; d _ _ - Q., z ;? [c - N 5- ..a .. a,r,... 4 l' A I am the section leader of the Geotechnical Engineering Section, Hyd:clogic and Geocechnical Engineering 3 ranch, Division of Engineering. Q Let me see if I got that right. You are the section ~ ,q leader, Geotechnical Engineering Section of the Hydrological a 2 and Geotechnical Branch of the - M A Division of Engineering. a 'i If you will strike the "al" in hydrological and just i make it hydrologic, that is the official designation. i,: Q Okay. Did you bring a resume with you to this a<3 deposition? i A Yes, I did. .=.l Q Could I see it, please? za 's A Yes. Ca i MR. 3 RUNNER: Off the record a second. i (Discussion off the record) a

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MR. 3 RUNNER: Back on the record. E f h I am looking at a document which I mark as Consumers 5 3 Pcwer Company Exhibit No. 1 - Heller Deposition. The document is entitled, " Professional Qualifications Synopsis, U.-S. Nuclear j Regulatory Comctission, Lyman W. Heller, leader, Geotechnical Engineering Section." 'N 'I ~ ALCERSON RE?CRTING CCMPANY. INC.

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-,. 's. Y.. a.* (.The above-mentioned document 1 l was narked Consumers Power Company's Exhibit No. 1 - Heller Decesition for identification.) ~ g (Pause) 3Y MR. BRUNNER: j Q I note that your resume states that you received a ~j bachelor of science degrees in both agricultural engineering i E and in civil engineering. t2 5 A That is correct. a<$. Q Were you studying bcth of these subjects at the same -z! time while you were in school? = =, ~ A No, sir. 5 ? Q Which subject did you take up first? I 8' A Agricultural engineering. Ei Q And you received your degree in that in 1950? 8 Ea is A Yes, sir. .m M j Q While in an agricultural engineering curriculum, did 3 3 you take ty civil engineering courses? r A No, sir. Q At what time did you start studying civil engineering? A In the fall of 1955. t i; 1 i-ALCERSON REPORTING COMPANY. INC. - 3- -=

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.*'d"u"**- ~ > . s:.w = ;.. . - Sace. r"p* gg :.a. 2 : 3: ;.:- n- .. -v.,.. ':.g. u:_ a y~;.. _- -y'* ""'* gy.._";_:l;g- = . '. py o- -"" -a c..,as. . w... 6 .y. r Q What did you do between 1959 and 1955? (Pause) A I was empicyed by the John Deers ottumwa Werks in ottumwa, Icwa in June of 1350 to Januarf of 1951. I was a product 3, r .~ engineer with that organization and was engaged in the design 4 and detailing of farm machinery, hay rakes, bailer motors, adaptions, forage c cp pickups, and the like. aj Q Could you step a second. You are reading frem a page z 3 of your resume new. What page are you en? Sz 5 A I am en the fouruh page of the package that I gave to a <a vou, and I am reading frem the fourth ent y on that page. = = e 3 0 okay. While employed with the Jchn Deere ottumwa -- = .= 3 I am sorry. Could you read the wc *z folicwing " Deers." I cannou 2 g nake them out in my copy. k 8' A "o-t-t-u-m-w-a." 3i Q The next word? w.Ma 5 A " Works." W-o-r-k-s. u ,r 4 Q The next word is aisc "Ottumwa"? r-E 3 A Yes. Q What is the werd afmer that? A " Iowa." I-o-w-a. Q All right. While working for the ottumwa Werks in 4 9 t t. i i ALCERSCN RE.*CRTING COMPANY. INC.

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ee- ..mww-K yp,-.. ~ - . ~..... ~ ~ g u.=:x,-~. .;i z.- y Ottumwa, Iowa, did vou do any o. rojects of a civil engineering I nature? (Pause) A In c. art. q ~ Q Explain by what parts -- explain what you mean by d "g "in part." A In the design of an adaptation for an engine on a n "j hay Miler, it was necessary to perfor:t certain structural 'l 2 type analyses on the vibration characteristics and the load e 4 z car:f ng characteristics of the frame of that particular machine. i 5a< s Q So you were inv*olved in the design of engines for i hay bailers as one of your jobs? i -a A No, sir. a2N M Q Would you explain what connection your jcb had with 1: M i the design of these engines for hay ballers? ai 8 A The work I was asked to do was to adapt a different u.

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engine, a different pcwer unit to supply pcwer for the bailer-a r E itself. This is not what I would characterize as motor design, but. an adaptation or use of a motor in a particular applicatien. Q Would that involve any modification to the motor? 1 l ~~ A No, sir. ) Q So your jcb wais to determine whether or not this motor 8i l h h 1 i ALDERSON RE?CRTING COMPANY. INC.

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~ f.pp*-ijf 2 : Jn?~'& . v.a :m:.. .#..:=-wL -t;firi:~. ~~-y,-?;--g. ..gff-Q- - - +%% c.. a m, . _ p, g 2: ( could work in different a9e.lications? 6 A No, sir. Q I am having difficulty with what you mean by ~ " adaptation.* 3 Why don't you just start from -- why don't you just 4 tell me basically what you were doing on a day to day basis while engaged in that project? A "j A The problem was that the supplier of the motor for 4 this particular bailer, for the production of this farm machine !=z g sale, was no longer available, and a different motor f cm a <3 different manufacturer had to be adapted to or incorporated into a i_ 3 the total design of that machine.

== j And so my work was only to take a given motor f cm a G i-3 new supplier and to design the mouring and evaluate the r5 i adaptability of that particular motor to this particular machine. sid Q What other projects did you work on while at the u. E ottumwa works? m t. A I worked on the design of a new product, a new hay R rake, and I worked on the pickup for a bailer, a new pickup for = a bailar. O Are these mechanical devices, the hay rake and the pickup for the baller? t \\ .i 4 t ALCERSCN REFCRTING COMPANY,INC.

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[ a grass roots level design starting from scratch or was it an 5 adaption of known technology? m g' A It was an adaptation of known technology. s 3 I Q Why don't you briefly describe what other projects n -= ~ ~ you worked on while working for the Ottu=wa works? 2 E 5 n d A I will describe what I characteri:e as design of a a E hay rake. This machine, de basic funculon is to move a swath F s c of ferage c cp f:cm a uniform distribution on the field, a< 5 agriculturai field, into a more concentrated line of product in =

== l order that that crop =ay properly cure for its use - for its l gathering and use as food for an ani=al. E = a E This hay rake has a n"d er of functions. The thing 3: a that was particularly new about this one is that it was designed 8' S is for use on the three point h.tch of the John Deere tractor, and L 8 t a it was power takeoff driven rather than g ound driven. = 5.~ And as such, it had to be designed from essentially t = a the ground up; meaning that the frame had to be constituted; g the raking teet.S had to conier.n to a new pattern of motion; and h the ground speed for this particula rake, the criteria for that E i was that it had to move much faster than the previous models dat i. 7 i t. = l _= t t Ee I j i ALCERSCN RE.2CRTING COMPANY. INC. = b

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j A Yes. 23 Q What were those projects? A I was assigned to Third Army Headeuarters in Atlanta, Georgia, and I worked in the Military Mapping and Planning Office j in that organization. And I would characteri:e =apping as a civil l \\ 4 { i ALCERSON RE.2CRTING COMPANY. INC.

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verk involving the design of building foundations or structures. a<a A No, sir, it did.E.ot. 3 I Q How long did you work in that mapping project? j i A Apprcxi=ately four months. 2 g Q Okay. Did you work on any other projects of a civil si engineering nature while you were in the Army? i i A No, sir.

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I note you were discharged from the Army in 1953. Is a 5 that correct? l* A That is correct. Q And after that you were employed by Herman Nelson Corporation in Moline, Illinois? A Yes, sir. i s 1 i 1 t ALCERSON RE'?CRTING COMPANY. INC.

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-i n y ~g- . - ~ - - wit.vs m.....+....%. a. .u,. _~x -r- . ;.2. y _mc - e-- _13 vn:. T;;.~ ~: w,. c :.,, a:. -m -m -. u n.,., _. i: b L =... a, c, - -. s-n ~r.~ ~ - - w w.r ~w..ua.~~.-~~-..- [^^ ?= ~. .s .(. w.,.j.c:;.-u r ~ ~ & -- ,t': .n ' "y 'I was also involved in i= proved -- rather, inprovements to unit ventilators and cooling fans. Q I take it frem what you just said that while working for Herman Nelson Corperation you did not do any work which ceuld n E be classified as of a civil engineering nature? 3 { A That is correct. j Q I notice in 1954 you entered the University of Illinois I ^ 3 I,aw Schcol. Is that correct? -i E A That is correct. t t z j 5 Q And you withdrew frem the law school in october of 19541 a 3 A That is also correct. a i 3 0 Could you tell me why you withdrew frem law school? _l A I could. = a. Q Would you? sr 5 8' (Pause) i A I determined that my previous life and my previcus u 'd3g experiences and my previous perceptions of a career in law were a c nce what I was experiencing in this educational environment. And I felt a career in this line would be incompatible with my life goals. Q All right. After that you were employed by 3endix lAviationCorporation. i l I s s i A1.CF.'RSCN RE.*CR'nNG COMPANY. INC.

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4, r A Yes. Q And you worked on the design and detailing of erfgen breathing apparatus, experimental model checkouts? \\ A Yes. t n Q Could you describe in more detail what your work in 3 the design and detailing of oxygen breathing apparatus involved? l A These apparatus were designed for supplying erfgen to n military aircraft that have to fly at high altitudes, and the f primarf function of the breathing apparatus is to take oxygen 52 f cm a very high pressure and insulated tank; pass it through a n< stage of pressure reduction in a safe manner; control the race i of oxygen supply to the breathing demands of the individual = f using the breathing apparatus; and to ensure reliability and aa failsafe manual overrides in cases of malfunct.sning of that' c a

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,rs j debugging it in its physical state. Q After working for Sendix Aviaticn Corporation, you entered the University.of Illinois College of Engineering in civil engineering. Is that correct? A Yes. i s t .i i l i 1 i ALCERSCN RE?CRTING COMPANY. INC. 1 +e g M

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-mg _ Q Dilycu have anv. e. articular reason for switching over to civil engineering at that time? A Yes. t Q What was that? 2 !"T

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I felt that civil encineering offered a greater a 4 { career flexibility than advanced graduate education in mechanical engineering, which would have been my second choice. n 'd Q I believe you testified you graduated frem the Universit 1 i E. of Illinois in civil engineering in 1957? i 5 5 A No, I did not testify to that, .a ea Q I'm sorry. When did you graduate from the University a 3 2" of Illinois in civil engineering? i _-= ~ A In June of 1957. 2 i = Q New, I note that you worked part time for a consulting h ~ 8' engineering firm, Clark, Daily, and Diet: while in schcol. That ni was while you were an undergraduate in' civil engineering?

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A May I c=rrect the record? a E Q Certainly. a3 A I may have testified while you were iceking ever the l resume on page 1 that I did graduate in June of 1957. But my recollection was only t.'lat I did say 1957. 7 Q Fine. i t .t I. t t 1 4 AL":ERSCN RE.*CRTING CCMPANY. INC. l n ~~

.,,.n..> l.,,, $$$p w,-. =b.~.=.- ~ .,f7f~, _;~#.,., 3 %q&MK% ids $4)f@.-py-[$yM,h.*%. .h*,y.,;. _,,M_.4 .e--- =b f_ 5 ry.YA 22:C' AJM.,N~TT~. '_yj,77 7 m g., ~~:. u.n.r.,.s....---,- g._ t.5 A;. ..-.m.,..~. .r. a' ~. f. u6,. ..r ~ g n.. ~.~_ A The facts are I did graduate in June,of 1957 with a bachalcr cf science in civil engineering. Q Fine. A Thank ycu. 1 b Q I don't think you have to worry about ic toc much. 44 okay. We are back on your consulting experience with 3 Clark, Daily, and Diet =. Were you working part ti=e while you I N ~j were an undergraduace in the civil engineering program fer the .z Clark firm? i= A Yes, sir. E< Q And ycu have dow'n that you werked en bridges, pile 8 z j caps, and retaining walls for interstate highway interchanges. Could you describe specifically what werk you wars doing with l 5 y regard to bridges, pile caps, and retaining walls? ~ b A For the bridges I constructed influence diagrams, 3 deflected shapes of the scructure itself en a two span continucus 5 ,u

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~ m 5,- Q 3efore you go on, could you explain what that is? 9 M A Yes. An influence line is a graphical pict of the influence of a lead that moves across the span en a particular i point on that span. The influence value could be shear in-a member, mement I l l t ! 2 ALCERSON RE?CRTING CCMPANY. INC. ~

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= r 3t a connection, er any other structural cuantity of interest. _t is necessary to construct this diagram in order to determine l l the stresses imposed upon the bridge by the ASEO leading i parameters established for that particular bridge. ~ E Q What is ASEO? 2 A It is an acrenym meaning Association of State Highway ( j officials. n 1 'd Q Ckay. What else did you do with regard to the design f of bridges by working on bridges? 'z: A Helped establish the gecmetric configuration of those 3< bridges that must become a part of a curve, either vertical 5 3 or herizontal, in the alignment of that bridge with the highways I involved. This is just a matter of establishing elevations, I control elevations for that structure, such that the bridge will 2 have adcquate clearance and will properly align with the m-W roadways and pila caps, t.nd so forth. 8 u,

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Q All right. You also -- 5 .E A A three dimensional geometric prebiam. Q You also mentiened pile caps and retaining walls. What-work did you do~with regare* to pile caps? A The one job I recall was that the piles were driven in the wrong locatien, and it was necessary to check and redesign 1 6 ~ 1 ALCERSCN RE?CRTING COMP ANY. INC.

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.4~ ..-s sG:~.... m'e --y.,.....%. .,..,.....~.....,;,;-.. y., w..,, .-.t*..,. y,- g m_.. ..m. .m... ~.,_ .;a ; - fat. g{ .~. ,, m. .~n. ., a; y. .;--r..-- the cile cap that was to ao on that particular bent in order to 1 acecmnodate a longer and heavier span of the main structure. Q Did that project involve the design of piles from l a bearing capacity standpoint? r A No. The piles had already been er.alaced, so there was e no design involved. It was simply a matter of checking the 2 cap to see that the leads imposed upon the cap were within code R s allowable values. i E. Q Was that the only project you worked on in the area E 5 of pile caps? a<3 A Yes, the only one to my recollection. 5 Q Did'you work on any other projects involving piles?

== ~ A Not for this firm. b W Q You also have that you were working on a project for a 8' a retaining wall for interstate highway interchanges. Ei 8 A Yes. 4wa g Q Could you explain what the retaining wall was and 3 what it did? 8 m3 A The purpose of the retaining wall was to retain the l earth in a vertical attitude in order to allow the. roadway to pass very closely to tha ~ wall. A retaining wall is used whenever it is necessary to i t I I 8 i i 3 l I ALCERSCN REPCRENG CCMPANY. INC.

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  • 19

. ~ i. Yi -.-; ,,g, c support a soil c: a rock that would otherwise slide into a new position that is needed for the traffic itself. This was a reinforced, concrete retaining wall, the conventional L-shape. ~ _q j Q Did that design -- I am sorry. Were you involved in a the design of the retaining wall? -j A Yes, sir. n Q Did your design take into account -- strike that. f Was the retaining wall designed either to sit on or to 4 i:2 5 support fill material? a<a A Yss, sir. a 5 5 Q Was it sitting on the fill material? ~s A Yes, it was. a* a Q Did your design take into account the amount of 5 predicted settlement for that fill material? 8' ai 6 A No, sir. 8 u. 'a .a 5 Q Why not? m ~ Jetaining wall are ,E A The loads that are imposed upon the : also prescribed by the ASHO specifications, and to the best of my kncwledge, these specifications do not provide for increased lateral loadings on the wall due to settlement of the fill. Q Did your design take into -- I'm sorry. Did you l .s + 4 .I ALCERSON RE.*CRTING COMPANY. INC. i

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_._m.,. ._ ;g +. - m*.a. +u.n 2: . - -. - w.<,w -. finish? A Yes. Q .Did your design include a slope stability analysis for the retaining wall? R A Yes. a f Q That is required by the ASEo specifications? 3 A Yes, it is. Mj Q Did your design include any consideration of the i j retaining wall frem a hearing capacity standpoint? E 5 A Yes, sir. n<3 Q That is also reqtiired by ASHo specifica:icns? a 4 5 A Yes, it is. .= = 0 New, while working for the Clark, Daily fi=n, did aw

you do any other projects of a civil engineering nature, other

-= ca 8' than the three that we have talked about? i (Pause) 5a 5 A Yes. n ,5 Q ~4 hat were these projects? A one waat a steel culvert, corrugated steel culvert that ) was necessary to pass storm water from one side of the roadway i to the other. There was drafting work that located sidewalks and lighting fixtures and drainage for the everpass s,._acture. l I.I s ALCERSCN REPORTING COMPANY,INC. =

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- ;; a., ;,.. :.z;- ;-~. - _..,; - yp- . i. Y:- .:a g = 5 .r There was =aterial quantity takeoffs from the erecared 1 drawings for bid purposes and a nu=her of other miscellaneous consulting engineering tasks, some professional and some sub-professional. U Q I note from your resume that in the su=mer of 1956 ed ?! vou worked for the county engineer's office in Tuscaloosa, C. Illinois. 'fas this while you were still working for the Clark, n y Caily firm? 3 A No, sir. c 5 5 Q What years were you working for Clark, Daily? What a<a daces? a 5 A 3eginning roughly in the fall of '56 and terminating =f essentially in the fall of 1970 - 1957. 3 0 okay. Well, that includes the su=mer of 1956, doesn't 3 i it? No, I am sorry. That is incorrect. I withdraw the ques-J.on. a! 8 Okay. While you were working for the county engineer's b. 'd'ag office in Tuscaloosa, Illinois, you helped survey oil well loca-a h tions and elevations ane. sidewalks and sureet and gutter work. n 3 Was this surveying sidewalks or designing sidewalks? A Surreying sidewalks. Q Did you do any civil engineering design work for the county engineer's office? 1 I i i I s j I ALCERSCN RE.2CR LNG COMPANY. INC.

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=== M W ~ - =.... ~. x.--:- ;.wn ~ r8 ' ~ -1 - ~.y c - y vs z.. u. .,. v'..., y_...,,. +. - - 22 2 ..u.- .m-. . m - _, ) - ~.c - n,,....,.,...... J.y e ~. i ~ 4, -m.* z .. ~.. ~ ..-.yw..- y ; A No, sir. q It was all surveying, then? A That particular aspect was all surveying work. Q What other aspects were there? a b. A Well, the city of Tuscaloosa widened and replaced 4 5 ene of their =ain streets; the curbs and gutters were

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and the sidewalks were reolaced, and the wearing surface of the = a '] street was replaced. Y. .w job was to assist the survey party to plot the = E profiles that were obtained from that sur'ey work and to check a c the drawings that were made by another civil engineering fir:1, 3 5 a registered civil engineer who was also employed by that office; .= ) and then when the work was done to condi::t the pay quantities 5 for the work that was done. Q All right. You graduated with a BS in civil engineer-i ing in June of 1957. u, 'JW= A Yes, sir. a E Q And then you went back to work for the Clark, Daily, sa and Diet: fi.- :t ; is that correct? A Yes, sir. Q Was your work for Clark, cally, and Diet: similar to the work you had done previously for Clark, Daily, and Diet:? l 1 I t I { e 4 4 AL.CE-tSCN RE?CRTING COMPANY. INC.

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,~ 5 A No, sir. 3< Q Other than the experience.with pile caps to which i you have previously testified, were you engaged in any projects 2 involving the design of underpinnings, such as piles for 2aw M caissons? ia A Mot in the design, no, sir. i 8 Q Other than your experience with pile caps which you u.a had previously testified to, what projects did you have while a= a [ working for Clark, Daily, and Dietz which involved underpinnings .j such as piles or caissons? A I am not sure I gathered all of that question. Would you nind repeating it, please? I l MR. 3 RUNNER: Could you read the question back? l I s l, 3 t t i ALCERSON REFCRTING COMPANY. INC.

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re-s.,. THE RE?ORTER: "Other than your experience with 2 pile caps which you had previously testified to, what projects did you have while working for Clark, Daily, and Diete which involved underpinnings such as piles or caissens?" THE WIOTESS: None that I can recall. a4 .= j BY 'R. BRUNNER: .j Q

n September of 1957, you entered the University of aj Florida Graduate Schcol; is that correct?

.zo A Yes, sir. n.z 5 Q What was your degree program at that time? a.c A I was working towards a master's degree in civil i 2 3 engineering. =. Q I notice while. you were doing that you were also =,. a 2 L: acting as a teaching assistant for the Department of Civil F 2 i Engineering; is that correct? i i A That is correct. u.aa 3 Q You taught drafting and strength of materials

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laboratorf. Could von describe what strength of materials s E I A laboratorf class involved? A The strength of materials laboratorf involves a i supplement to the fe.~al classroem work in the strength of materials. The laboratorf work used testing machines, strength j i .g t 2 1 e e 9 s e ALCERSCN REPCRTING CCMPANY. INC.

' ' '. ?+.. r. . b i. p _-;.y4;i% 3: *- S W . ~; - n,- .QE&LQ4 :3 3 Q-e9f.. ,' * [.~,, ~.. gy +. - 25 J' i e cm..._. ,e l testing machines, i= pact testing machines. of It involves the instrumentation and measurement material properties and teaches the student proper dccumentation of the c.ure.cse of the work, results obtained, conclusiens drawn, -n 0 and accuracy of che werk. E Materials tested are primarily =etals and concrete, n ~. 3 0 Did you test any soils in this class? A Y A No, sir. = What was your area of concentration in the civil k q 5. 4 3 engineering field fe your master's thesis? E< A Scil mechanics, foundation engineering. 3 4 z 4 0 What par.icular subject did you w ica your master's thesis en? 5 My master's thesis was written en the topic of the i A r 4 eu11 cut resistance of piles. s{ 8 O I note while you were in graduace schcol you worked a G. it I "g the summer of 1958 in the Army Engineering School, Tert -- a E. looks li'<a Selvue, Virginia. Is that correct? 3 I A A No, sir. O Could you tell me what the wc ds are? A Ft. Selveir. 3-e-1-v-o-i-r. i Q Your resume states that you wrote a series ten I t It \\ ALCERSON REPCRhlNG COMP ANY. INC.

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.' y .9 - pe :__ ~ _... . ~., 7 ..,.,.. __ y e I c,. _. - W correspondence course en reinforced concrete. Could you describe what that involved? A The Ar=v Ingineer School writes a sc=ber of courses ~ cn different cecies for their field officers that can.be studied e. n at remote areas, such as in the field. Thesa are correspendence M .e d ~, courses. g [ The purpose of series een of this instructional n 3 series was to prepare the field grade o.fficers for successfully E passing the professienal engineers examinatica in any state. z 5 q I take it you wrote ene section of the whole course, a<3 then? Is that -- a t A Yes. There were a n"d er of sections of the course: foundations, and so forth. The topic that I was assigned was s9 i reinforced concrete. ca I 8~ q What did you de after graduating with an MS in ai 8 January of 1959? 'Jag A I was employed as an inst ncter in the Depar.~ent of

  • n h

Ingineering Mechanics at the University of Ticrida. E3 0 New, the course you taught at this ti=e was entitled " Strength of Materials." Is that correct? A Yes. Q Were the type of materials considered in your course i. i f e I e 0 t ALCERSCN REPORTING COMPANY. INC. l

...... n... .:.. m. - w.:..,.- -.;u. c _y ..,... s. - ;: x. :.,-- =. w :- 4 -, y.. w 4.. _.,%, y,g., 7 F M- ,u ~'- r-i l things like steel or metals as cpposed to soils? ,i A The strength of materials course covers strength considerations without reference to a particular kind of 1 i material. M It is an engineering mechanics course that essentially .4 1 i assumes elastic behavior of the materials and ta' aches how to 6 calculate the stresses impcsed by the leads that would be carried A j by a variety of structural shapes, such as H-beams, columns, j pressure vessels; no particular emphasis en any particular 4 =aterial, concrete, steel,or soil. =< O Did the classes include study'of soil properties 8 z j such as bearing capacity or resistance to settlement? A No, sir. 3+ i Q Now, starting 6/59, I note from your resume that y' u o 3y werked for the U. S. Naval Civil Engineering Iaboratory at i i Per. Euene=e, California. Is that correct? i a .a3: A That is correct. [ Q Why don't you explain what work you did in connection i r i i k with laterally leaded pilings at the U. S. - Naval Civil Engineering ^ Laboratorf? A When I came to the laboraterf a research pr: ject had been underway for a few years to determine the behavior of pilings 1 / i 6 l-a 't I 1 - ALCERSON REPCRTING COMPANY. INC.

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z = ., f-[-ifd.W f .$i:Gkg&Z&... (r,,.,, a g;_;. yg -,, m _ _, m -.... u. w --. ... n.c..,- 3.._,. t, N L..- .--.n. u.a :.;n.. m. :., - s s r ~ w. o. .~s..~.. -7 ~. g 4.p. .--w., v. -. 2 =,,.a- ,i-.- v s.. v. p g I subjected to lateral loads. The purpose of the research project was to :nderstand how imposed loads on the pile are carried by the soil into which the pile had been driven. The laboratory work was a study of a 4-R single pile surrounded by sand and surrounded by clay. j j-ne.ead of the pile was subjected to noment and a E lateral lead such as to maintain either free head conditions Ea ~$ or fixed head conditions. The variables measured were the soil pressures on the g u z l face and back of the pile and the deflected shape of the pile. = c j O Did you consider the soil pressures below the pile? E 5 A No, sir. Q Did you work on any other projects while at the -a L C. S. Naval Civil Engineering Laboratory? a i. A Yes, sir, i a Q What other projects? 8 'al l Strike dat question. Maybe it would be faster if I 2 just went through them. e i y 3 A I can read the above one if you wish me to. 1 ~ Q I note that starting in the tenth month of 1960 you 4 worked on another project, apparently in connection with laterally i; leaded piles. How did this second project differ from your firs I i i I I f s a i ALCERSCN RE.=CRTING CCMPAN'f. INC. a

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c. c4ect in the area of laterally loaded o.iles?.

s A This was a continuing phase of the laboratory work that J had been done previously and invcived the contractual arrangements with consultants. It involved a sur.ca:f and l O evaluation of all tests run and involved the integtatic n of the j laborato:f work into design cr teria to be used by the Navy fer designing laterally leaded piles for their applications. e A i ~$ .Q Did your analysis of laterally loaded piles include I a seismic analysis of those piles? -z: A No, it did not. 3< l Q Now, in your consideration of design criteria for 5 laterally leaded piles, what particular design parameters were taken into acccunt? E_ A The design parameters were the stiffness of the e' a piles, the load deflection characteristics of the soil into 8' i which they were artedded, the degree of fixity of the head of the I u. r

  • 4 sile, and the deflections of thmo.ile.

r a s _2 j Q I note f:cm your resume -- I note from ycur resume the next project you became involved in in the C. 5. Naval ~ Civil Engineering I,aboratorf was what you described as complex research activities on projects involving scil techanics, 1 foundations, and related disciplines as applied to ' problems of i I' i i. t ! ( I ~ ALCERSCN RE?CRTING COMPANY. INC. ~.. _.

.mu : >.. ; . A.. : A N w h-- q &..m :E.i..,C.C f 2 2 ;; &'. 2x-;-; ... J;45. :::--=- .z - p =p' _ _ - - .-m.__ % s.: -? ^W n.r:ht:. r-u :i%- '"'^ % i ? p ~ Q" b y -rs w e #- 3.-,;.IJ. ~.. O.c..:r. C-m.- ... w - m...-._...,_-... . :;: m.. u.n-... ., a. .y;; - 03n g. ..s-_.-. .. _ ;.9 p,..%.. e -ms .. r w. m. -- ..._,1.-. buried, trotected structures subjected to dynamic leading by the effects of nuclear weapons. When you referred to " buried, protected structures," are you referring to things like fallout shelters? n., A No, sir. Q What are you referring to? 5 A I am referring here to an underground structure whose R j purpose is to store Naval ordnance and Naval supplies such tha the actual loadings i= posed by a nuclear weapon would not t. .j adversely affect their functional survival, rather than protecting <s only from the radiation or' fallout effects. 5 Q While you were working for the C. S. Naval Civil = ~s Engineering Laboratory, did you do any work in connection with 3 i prediction of the settlement of fill material? r 2 i (Pause) i* A Yes. aa g Q What was that? a l A Tor the performance of some of our tests related to lateral load capacities and behavior of piles, it was convenient to compact the sands around a test pile by means of flooding the sand with water to allow seepage pressures to improve the l density of that material. + ? s I. 8 8 f t ALCERSCN ME.*CRTING COMPANY. INC.

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A. .,,y.' i Since the pile was placed prior e surrounding it with sand, the dcwndrag effects of the upper portion of the fill 4 sand had to be considered with respect to the at-rest pressures on the sensing device in the pile. i E so in this sense, the settlement aspects of soils were considered. 1 Were there any other projects where ycu had to onsifer 3 Q t A the settlement aspects of soils? ~~ A The projects that censidered the blast loading of the f e soil, which of course is necessary to design or consider an z: 5 undergrcund protective structure did inve17e the settlement of i 8 g . edal studies of the behavior of buried structures to l j soils. M l =. overpressure blasts also involved the inst.rnentation and 5 y evaluatien of settlements in a container of soil. Were these settlements that would occur as a result of a 8' Q 3 a nuclear blast? l r.:a 5 A Yes. =. Are there any other projects in which you considered j Q settler 9nt of soils? 1-l (P ause) A Not for which I was. responsible. Q All right. I note from your resume that starting 6/65 e f s 4 ACERSCN REPCRTING COMPANY. INC. f w mm- -. -. -,, ~. - n a

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$%k'd$8g@h.[ [. [Ej[ fly?d6 !*'"?.SM??7~ZY-N _ f, - -r, ~ 2 [_ 'M m 2:.ic. -w-:. v -..,.,. ._.3,,, .m.- g. 32-s y ..... e --~- %.,. c.%...-. ~. g,., -Q _ ,._= m n. - - - - - - .-y. Qn. .y end up to February of '74 you worked en the U. S. Arr! Ingineer Waterways Experiment at Vicksburg, Mississippi. Is that correct? A No, sir. It shculd read, "U. S. Army Engineer Waterways Experiment Station," rather than an " experiment," as n i O you had quoted. 3 Q I am sorry; that is the way it does read. I just 4 j did net read the entire title. N '.f A 'Thank you. Q I note that while engaged in this project you performed c E analysis cf ground motion -foundatien structure interaction and a< 8 the earthquake resistance of earth and rock filled dams. Is that .c z I a correct s.atement?

== ) A Yes, sir. 3

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Q Did this involve the design of dams or only the 1 r 3 analvsis of dams which had already been designed and built? x 3 8 A Both. a 's A. Q Did your work in this area include any analysis of a t settlement of fill material? s 5 (Pause) A Would you clarify - strike that. Could you -- 4 i Q Weuld ycu like =e to clarify my question? m i 4 i I t e l ALCEMSCN RE?CRTING COMPANY. INC. 1

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.r. z -.. .,,.-..m.,...w.,...._... J .v. ' p.W : 1., w. - - - ..~.%._ g,,..... - W that correct? = \\ A Tes, sir. j Q what was your title when you first started working for the Atemic Inergy commission? e, A I believe the record will show I was classified as 2 ( a nuclear engineer. .~ Q Were you a member of any particular branch or section "A 9 of the NRC -- I am sorrf -- of the Accmic Energy commission? II A Yes, sir. -c 5 i Q what was that? a= A I was a member of the Site Analysis 3 ranch. f Q New, it indicates on your resume that you made recommendations for accepting, rejecting, or modifying preposed I.y designs for fcundations and the geotechnical features of nuclear r2 i facilities. i 8 A That is correct. w.a g Q I take it frem that description that you were involved a a l in more than just evaluating the suitability of sites fer nuclear power plants at that time? A Yes. Q Maybe -- what six plants did you work at? A I worked on Comanche Peak; I worked on South Texast-1* e ALCEMSCN REPCRTING COMPANY. INC. l

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.e.. _., - - 35 4 r I worked on Farley 1 and 2: I worked on Three.w.ile Island 2: l I worked on Cherokee and Perkins. i Q Cherokee and Perkins? A Cherokee and Perkins and a number of others that have j not materialized. 3 F Q Did you do any work with regard to the.w.idland Plant M. A site? g. 4 e. A No, sir. l Y Q Did any of these particular nuclear stations or i 2! proposed nuclear stations involve or incorporate a design wher~ein 3 B ' structures were to be placed on comoacted fill material? a E j g A Yes, sir. I Q Which ones? 3 b I y A South Texas. 9 Q Any others? Eia A Farley, Allens Creek, which is still in CP, however. 3 g Q could.you stop for a second. Allens Creek was not one t i 5 of the plants you mentioned before, I believe, when you answered e. l my question as to which plants you had worked at. Were there any other plants besides the six that you gave me in your previous I i 1 s.nswer that you worked on in your initial position at the U. S. Atomic Enerpy Commission? 1 i I 4 i l I ALDEMSCN REPCRTING CCMPANY. INC. .-. ~ -.

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, g,',3; z.i w j .e...,.-- I L I would need to go over ths list to give you a complete A listing of those plants I worked on and the time period I worked on them. I had meant to indicate when I indicated a number of other clants that had not materialized that Allens creek would ~ 3 - have fallen into that category. { g I am sorry if I misled you. ~ n j ( Q Continue on with your list of plants which made use i a You have 9 i of compacted fill material for foundation structures. k h given me so far South Texas, Tarley, and Allens Creek. ~z = 3 Were there any others? a e f A River Bend, Beaver Valley, Shoreham, Jampesport. E I t Q Let me stop you a second. = = 4 Are you giving me a list of plants which you have =., y j worked on or proposed sites which you have worked on and which i - made use of compacted fill, or are you giving me all of the plantC i = iit - that have compacted fill as a foundation for structures? 8 w, w i_ A Both: ones I have worked on and ones that have a e - comoacted fill as well. n 5 0 All right. ~ A I did not complete my list when you gave me the 6 first question. I would need to refer to my file.in order to give you a complete list of the plants I have worked on. I am p

  • OE*.SCN REPORTING COMP ANY. INC.

..., ;.:.c:.t. r ?: _ g -a9af.d. Q:- ;yo.- .. x ~. ;G-E.j:Z. 73-y - 1y. ["{,}~g. "f e i - o - 37 . s %; e.- o r .sorr.r if they are not consistent with these other plants I have ,I worked on that do have compacted fill. i Q All right. So your answer is with regard to South i "'exas, Farley, Allens Creek, River Send, Seaver Valley, Shorehar., O and Jamesport, that these are all plants that you have worked on? 3 l A Yes, sir. Q And they all have compacted fill as a fot.indation for 'd, at least one s.ructure? Y A Yes, sir. c u i g I was having -- may I make a' comment? <a Q Certainly. a 1 3 3 A I had interpreted your question as those plants I had l worked on while I was with the AEC. I have now included that i a I 4 y period of time when AEC was changed into ERCA and NRC. g 3 8' O You have not included it? j ni i 8 A Yes, I have inch'ded it. i W. g Q You have given t the complete list of all the plants a i 5 i l you have werked on, either Ln Az'C or NRC7 A Yes. I ~ Q Dfd any of ..ese plants upon which you have worked i make use of underpinnings, as the term is itsed in civil engineerin prsetice, to support Class 1 structures? t s ALDERSON REPCRTING COMPANY. INC.

m. -f., %w~y..ar.m, ..c. i r. .Of f~ f..i ~ : 5'_. &&$4:.-[_;>*-'..,hk-$5'E?b h 'm c.w.3 t : n. .. m.,.,. 4, 33 -,: a c.v. ~.,. .n. m,._._-...-.m. .. _,,,, gj , e _,n.: ~. n. .c 2.J%-.r......%... s- ,,_,4,4, y,, p:, 9,,. W i A Would you mind repeating that please? .May. I sim:17 ask a question? 4 Q okay. A .Are you new indicating just the plants that I have 3 R mentioned er any c.lant that uses -- g j Q Why don't you just -- why don't you first give me the answer with regard to those plants upon which you have worked in ..j 3 your capacity as a reviewer for either the Atomic Energy I Ccmmission er the NRC and which make use of underpinnings for c:: ,~: Class 1 s m etures. 5< A Syron uses piles under its pumpheuse at the river; E a E l Ft. Calhoun, Unit 2, I believe, preposed to use piles to support ca that addition to that earticular plant. E a. !E Q When you say, "that addition," are ycu referring to the i 5 8~ entire Unit 27 3 A Unit 1 is supported on piles. I was not the reviewer a cf that particular plant. They intended to expand at one point a = in time, and they proposed to also support that plant... pilings. Q This is the entire plant including the reactor? A Yes. However,that plant was droppedt so it was one of the casualties of high interest rates and icw power demands. Q Any others? 1 e ! It i l -l ALCEMSCN REPCRTING COMPANY. INC. i

i ' ' '.4' 3'? A _.., _ %..<,-,;p sc,f, i 1 ' L...- ; Pg ,< g y.p.p.. .45y.7 ^-' ..,,.,7 g n '% Y:. .'., ':3 c a. 39 1 A The Bailly Nuclear Plant. Q What structures at sailly are supported by under-a pinnings? ~ A .All of the structures, safety and nonsafety, are proposed to be suppersed by pils foundatiens at the Bailly Plant. 3 i j { May I comment? Q certainly. i 1 A {

  • y A

The term underpinnings usually is reserred for a f remedial construction action, as cppesed to caissens and piles i = E heing designated as criginal foundation designs. 3 1 Q I understand. 5 A It is only terminology. = I Q What I intended to do was refer to the use of piles y a y and caissons as original foundation designs or for remedial 58 construction work. 3 W You state that sailly has proposed the use of piles. 4 l Ias 3ailly been granted a ccasttuction permit yet by the NRC7 a i 1 2 A Yes, sir. Q And that constuction permit was granted on the basis of a design involving piles for all of the class -- all the majer Class 1 structures for the station? A Yes, sir. = 6 t ALOEMSCN REPCRTNG COMPANY. INC.

n.+. u. ? 'y l f ?":Y31'j}-{y]K.:n...7g 3 P,7 - ~ ~ @ M p M y. g ] fJ g y,! %j *;,, g,ypy,W*Wdp.,#l Af o r u.a.o. = .-*c=.- e m f.. e ~< - x.w.. 40 W ' .. ~,..-~,,,.,,. .s .g;o ~J ,, G; ~ ~ '". ,, g ~ Q Are there any others that you can recall? l A I am sure there are many minor structures supported on piles at a number of stations. My memory is not goed enough to give you all of those. I can just relate these that come to mind ~ R new. t 3 { Q All right. Could ycu do that? 3 A Waterford at one time ha'd a pile !cunded portion which } j has since been changed to structural backfill rather than piles. I Q Is there any particular reason for that change? ,e. E: A The reasca that is given to me by applicant's AI was 5 ene of ecenemics. The:mappears to be an inappropriate charge 5 being madu for the pilings by a subcontracter. They elected to = I evise their design. t I believe those are all I can recall. 5 i Q All right. Now, I note f cm your resume that starting i i in 12/74 you verked as a reviewer for the U. 5. Nuclear Regulator,' D. i ag commission. Was there any change in your jcb frca 12/74 as far aj as what your duties were and what your responsibilities were? A Yes. Q What was that change? A The Site Analysis Branch was recrganised to include a Geotechnical Engineering Section, a Geology-Seismology Section, ~ l i I I l-I i j 1 1 ALCEMSCN ME.*CRTING CCMPANY. INC.

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._..s.- - m,g r A Yes, sir. Q For purposes of construction activities 7 i A Yes, sir. Q 'Did any,of those plants make use of the preloading i 2 process design in structural backfill? 3 j j A No, sir. .[ Q When you use the term " structural backfill," what does i 'j that mean7 ig A structural backfill is materials used to support a i structure and usually it is -- its characteristics and properties are known,and it is engineered and controlled during 4 cens.ruction such that its properties, expected properties are i = 1 l attained. I In other words, it is materials used to support the 1 5s i structure. i a ) Q Has any nuclear plant, including those which you may not have worked on, made use of a preload design at any stage in l the pecess of design or construction? A No, sir, not to my knowledge. O Now, you refer in your resume to having a responsibility for earth dans and stability of mine tailing damer are those earth dass dams that are built in connection with nuclear power i I. t Al P'ewet*N sewesT1NG COMP ANY. INC.

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.. n.,. x ..., : a ;, -Q ?:2: -y-,.74y 5 ; z. f Q f . y. . sw a.. r.. ,3, 43 t facilities? A Yes. O And what, in your experience -- to what use have these earth dams.heen put in conntetion with nuclear pcwor plants? 0 A The earth dams are used to impound a body of water 3 { to be use'd as either the source of cooling for the Operatica of f a plann er for the purposes of the safe shutdown of that plant j in case of an emergency of some kind. T Q Mave your respcasibilities changed since 12/747 .-c { A Yes. O What are your present job responsibilities? s g A The present respcasibilities include a greater degree i I of administrative work than was the situation in 1974, December of 1974, primarily with respect to budget preparations, personnel actions, training, and duties of this kind in the support of a 8 our management. 3 t1 Are you still connected with the seismology, the n j [C hydrology and seismology and geology -- hydrology branches? A No, sir. Q Okay. Which branch are you connected with at the i present time? A At the present time, Hydrologic and Geotechnical t ALCERSON MEPCMTING COMPANY. INC.

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  • r. Lear?

I 's A Yes. g Q Who is that person or persons? g 4 A The persons in Mr. Lear's branch include ::ryself, 34 Dr. Thompson, Dr.Pichumani,'Dr. Gupta. 1 Q I think you are going to have to slow down. The cours 1 repcrter is having trouble picking up the names. 1 i i i Dr. Fichumani, did vou say? 1 5 s A Yes. I 8 Q Row do you speil that? A P-i-e-h-u-a-a-n-i. I l Mr. Greeves, Mr. Kane, and Mr. 31 vins, Dr. Ccdel, I Dr. F11egle, Mr. Johnsen, Mr. Rico, Mrs. crane, Ms. Smith. I Q Are you limiting your answer to engineers and/or j technical support pecple? A Mo, sir. I was listing all the members of Mr. Lear's 1 ( i g i ALOEMSCN MEPCRTING COMP ANY. INC.

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g (*.,:c .?, 's - branch. Q Ckay. Why don't you stop. Limiting yourself to engineers and technical people, would you just quickly -- I will ask you a question as to whether these par.icular people are g engineers or technical people. g f Dr. Thompson, is he an engineer or technical person? E n A Yes, sir, he is. A

  • j O

And Pichumani, is he7 g A Yes, sir. ): I, Q Gupta? <a A Yes, sir. a I' Q Mr. Greeven? I z I A Yes, sir. I. I W Q Mr. Bivins? g 4 i A Yes, sir, l a 8 Q Dr. Ccdel? t. d 3 A Yes, sir. a l Q Dr. Fliegle? A Yes, sir. Q Mr. Jchnson? A Yes, sir, i Q Mr. Rico? e t ALCERSCN REPCRTING CCMP ANY, INC.

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.}. M; ^.- ~ ,~...-,x...;>G2.1.i~;';;:,--h'-3gh.5~.',,~[,',Q(-% 2 .m = .a i t l A Yes, sir. Q Mrs. Crane? A No, sir. Q ,Are there any others who are either engineers or 3 tscht.ical support people who are members of your branch? { A Yes. Dr. Chen and Dr. Pearring. And I may have missed i g one or two members in the hydrolorf group. I would have to get

  • j a complete branch listing, since we have been reorganized about I

two months now. I 1: q Other than yourself and Mr. Xane, have any of those 8 people worked on the Midland project review? g J 4 A No, sir. 1 .D. BRUNNER: I guess we are going to break for lunch if that is agreeable. (Thereupon, at 12:18 p.m., the deposition in the 1 a above-entitled matter was recessed to reconvene at 1:15 p.m. that n same day.) t j 3 i: I t a 1 i k t l s j I ALCEMSCN REPCRTING CCMPANY. INC.

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47 t ; %..., 'N. ,....,~----s . ~. ~ >. ~ - - - ~ - - ., ~ :v. .g,,,,. 3. - - v -. ..r u..-~.=- 3 i i Ar*ERNCCN SESSION i (1:20 p.m.) I MR. BRUNNER: Back on the :ecord. I . This is the continuation of the deposition of Mr. Lyman Meller. E l Mr. Beller, I remind you that you are still under oath for the purposes of this afternoon's proceedings. l 'J ST MR. BRCNNER: a l l l Q Before adjourning for lunch we were talking about your resume. I notice in addition to receiving a master of sciones degree, you receive'd your doctor of philosophy degree tres l the University of riorida in 1971 is that correet? i f A That is correct. l l l j Q while you were working for your PhD degree, were you l a fulltime student at the University of riorida? l d n A ror a year and a half I was, yes, sir. g, ,I 8 0 After that you heemme a part time student, I presume? E j l A Yes. I 0 What did you write your destoral' thesis on? ) i I A The title of my dissertation was: 'The Particle Motion' i rield Generated by the Torsional Cecilation of a Rigid circular l roundation on sand.' t 1 t \\ 4 I ALCERSON REPCRTING COMPANY. INC.

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tructural analysis of hetiding foundations?

A No. Q Would your section review a proposed dewatering system if one were proposed for a nucisar power plant? 2 We would participe.te in the review of the geotechnical A { features of that dewatering system. Q What are the geotechnical features of a dewatering system? g Tor exampte, it would include the filter criteria for A surrounding the well points, if that was the particular design submitted. If it were a pa'ssive system, we would review the a sI,' f ut.rs, ee,radauon., sona uon, eose a,e exa.,1es of ee I features. 1 1 I Q '#culd you censider the permeability of soils or any 1' analysis regarding the permeability of soils supplied by the a" applicant? s A Yes. 5 g Q Does your review authority include the area of seismic analysis? A Tes. O In what respects? A With respect to earthwork dams, properties of t t ALDERSCN MEPCRTING COMPANY. INC.

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,......-,c..m. ... -. ~ ..- ~. _ ;, y ' 1 -k &;,P :',';i:. '.a w...,E - ',} }- = (Pause) l A In general, no. There are some exceptions to that. Q could you describe the exceptions? A cne exception would be the conduits or tunnels through ' l and under earth dans wherein the movements, long ters movements { of the soil would have an influence on the loads assumed and the structural behavior. j Q with regard to underground buried pipes, huried electrical conduit or electrical ducts, would your review i authority ever include an analysis of the effect of soil imposed i a loads on those structures? - t A No. I whatwasyourtitletaseptemberof1978ifyourecall?l Q 1 A I was the leader of the goetechnical engineering i 8, section of the Geosciences leanch, Division of systems safety, a office of Nuclear Reactor Regulation. Q who, if anyone, reported to you in 1978, September. 5 o l t.imit your answer to engineers and/or techniaal support persons. I (Pause) A Mr. Gillen, Mr. Greeves, Mr. Kane, and Mr. Theepser.. l Q ffhen did you first learn there was a probism with the foundation soils at the Midland site? ls' l t l s I AL,CERSON REPCRTING COMP ANh. INC.

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w_. 5 .? r . c - 52 .;Y .,, u, f A In the fall of 1978. i Q Do you know how that problem I have referred to was made known to the NRC7 l A I understand that there was a report made by consumers l n Power to Region III, but I was not involved in that communication. l g Q What was the nature of the problem? { A I think that the correspondence indicated that the j settlement of the diesel gererator building either had or was f approaching the expected lifetime settiament for that structure. Q Why is that a problem? A It w'es determined by Consumers Pcwor, it is my understanding, that it was not -- that it was a reportable item l I l under the regulations governing their construction permit and a l 1 j reportable deficiency under those reggiations. ~ 8,' Q rros a technica1 standpoint, why is it a problem if a l building settles more than what had beenexpected at the time it was designed? l A It is a problem because the designers of that nuilding would not have antisipated its behavior and would not have l incorporated the appropriate features to secommodate that unexpoe-l ted settlement in a way which would assure the function of that l building would be maintained. l l i t s ALDERSCN MEPCRTING CCMP ANY. INC.

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i rather -- would exceed that anticipated in the design. j Q After this problem was reported to the NRC in the ~n 'j fall of 1978,'did you keep abreast of the materials that were s"W tend to Consumers Power Company in reporting the various z;: i_:z aspects of the problem? a< A No, not abreast. We generally obtained our information-z I frem our I & E offices because most of the communciation, I =. _= understand, was through the Region III I & E office. ~ =+ i Q Did you visit the Midland site at any time in 1978? E T A Yes. i* Q Was that in December of 1978? c a= A Yes. _w h Q What was the purpose of your visit? I3 A The purpose of our visit was to learn more about the f. reported deficionef and to acccmpany and support our I & E ~ t representatives on that site visit. Q When this problem was first reported to the NRC, did I I l -g 8 g i ALDERSON MEPCRTING COMPANY INC..

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..m c :rg-r: . w - ~. ~:--.:; u. 2. g.y ^^ ^ 51 - K '!: - G ..v'- r-vour section have any responsibilities with regard to reviewing the data that had been submitted by Consumers Power Company in connection with it? A No. ~, Q Did you later obtain any such responsibility? j A Yes. Q When did you first have the responsibility with regard 5 .4 to reviewing the preblem? f A 'I'he responsibility became -- the responsibility came tz to us through a =echanism known as a transfer of lead 5 a 43 responsibility, which is an NRC mechanism to transfer or share a f the review aspects of problems that are not resolvable by I & E on = ~ a QA or inspection basis. =a Q You mentioned " transfer or share." After this ea i transfer took place, did your section have the lead responsibility ai [. with regard to those particular technical aspects of the problem

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in which you normally deal? a A My answer would have to be yes because although other 1 sections, branches would support our review within NRR, we would he looked to as the lead review group for this particular problem. Q When did that aansfer take place, if you can recall. If you like, you can refer to your documents to aid your j-l j t s l ALCERSON RE?CRTING COMPANY. INC. ~

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v.~e. e.w =- r - 0-. m.-~ recollection. I do not believe my documents show them, but I believe A someone's documents, probably Darrell's documents, would indicate recollection I it was in January of 1979.,That is the closest ~ n O can make at this point. a 1 C You visited the site in December of '78. Did Consumers 3 Power Company c.ropose any remedial action with regard to the = M 3 unusual sett1,ement of the diesel generator building? A They did describe an experiment that they had planned kc i for consolidating the fill beneath the diesel generator building i) = 3< a presentation, I believe,'on the 4th of Decee*er. 8 i ii Q You used the word " experiment." What experiment are yes 2 referring to? ,=a They described to us a scheme for applying sand around j A r2 8; an interior tube of the diesel generator building in order to i ai load that fill and compress it. 8 r.: y'A Q Was the purpose of this " experiment" really to gain a 5 data with regard to the fill under the diesel generator building, I3 or was there some other purgese that they had in mind? t A 'I really cannot speak to their total purpose; it was my impression that they wished to conduct this activity and were simply informing us of their intentions and schedule to i 'i i. I I ALDERSCN REPCRTING COMP ANY. INC.

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- '~ 56 .^t s. ,.u r carry out this activity. Q You used the word "experi=ent." was that particular word used by consumers Power Company to refer to the preload ~ project, the project you just described? n O A I am not sure whether they used the word " experiment." 5 From the description of the instru=entation and the planned j loading of the fill, many would classify that activity as an a exper_, ment. E Q Why would that particular term be used? E A There was - I would use that term because of the 5< instruments that were proposed to make the measurements from the E j schedule of leading that was proposed and from the expectation = f that a large variation in the resulting settlement was anticipated. a j Q What in particular with regard to the instruments that

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=,- were proposed led you to describe this as an " experiment"? Ei= A The instruments were to be installed at a nurher of ld y depths and quite extensively throughout the areal extent of leaded = 5 area. "'he loads, as I recall, were to be increased in five foot n M increments with delays between each increment and the resulting settlements were not offered until we asked for those resriting 1 settlements. And there was a factor of three, I believe, between the i 1 s I ! 0 l j 1 i i ALCERSCN REPCRTING COMPANY. INC. '

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.) g," i. -'"~*% minimum expected settlement and the maxi =um expe.cted settlement of the fill. 7 q In your opinion, was the instrumentation that was preposed adequate to measure the results of the preload program? A At the time I was certainly not able to =ake that kind .a 5 of judg=ent based on the verbal presentation and the visual aids a i w that were presented to us. s "d So I would have to answer that I do not '.ow. c g Q Have you since drawn any conclusion as to whether or i not the ins m: mentation that was used to.=easure the effects of = a<3 the o. reload was adequate to do so? = 2 3 A No, I have not. = Q Prior to W s occasion when Consumers Power Company za informed you of the proposed remedial action with regard to the 5 4 diesel generator building, had you ever heard of a case where = si anyone attempted to preload fill material? 8 Gag A Yes.

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  • dhat was the occasion?

r. 53 A Ohe occasions are presented in the literature, and they are generally used for reclaiming organic soils to support-light structures. l q Had you ever had any personal experience.with the use o- \\ 0 f \\ J ~ ALCERSON REPCRTING COMPANY. INC. 4 I

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.-e--- 5g -% W.: a: e .c preloadine prior to that meeting at consumers Power Ccmpany's 1 Midland site? A Not personally, no. Does the literature to which you referred regard a Q

c. reload e.regram as a suitable nethod for obtaining adecuate n"

.e characteristics of fill material where it is used? n- "'he literature is divided on this issue. In some 3 A -n 3 cases it has been successful; in some cases it has not been successful, the applications for which it was originally designed. i c i Does the literature include any examples of the use 5 0 3< cf preload p cgrams in situations other than for the purposes of, E 3 recla -4ng organic soils? d = A Well, it is used for consolidating landfills or 2 =+ j:. industrial fillsaleng waterfronts, for example, and in some cases ~ 2 natural materials that have not had time to consolidate: clays. 8' is So there are situations other than peaty soils or organic soils a 'J that have been treated by preloading. ld =.

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Q Is the preloading technique generally accepted as a method for consolidating soils in the civil engineering field? A It is accepted in some applications, yes. O Would you say that it would be generally accepted in the application of compacting fill material that had been placed a J 4 I 1 4 j s ~ g ~ O ALCERSON REPORTING COMPANY. INC.

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l that which would be predicted following the preload later 2

j cccurred? t A There are none reported that I know of, of preload of i a =anmade fill that was intended to be the support for a =. str'leture. 5 ? 1: Q Ycu gave me two reasons why preloads are not, in your e u s opinicn, generally accepted for the purposes of compacting man =ade ici ,a ,?! u_., 3 v, h W Are there any other reasons that you know of? Ye A Well, a reason, even I guess as good as the high cost, y y ~ ALCERSCN RE?CRTING COMPANY,INC.~

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- ' ; _gi-;;p. 2%.:;~ lt-- ..,,..x _.;;-5 5g3 5 -- x-;j. y_ g-~~._..g3 -e-v e.< ..~. a. e s 60 ncw ..,.a .,<_c' r is that de resulting material is likely to have the potential for differential settlements. Part of the reason for that on natural materials is the variable occurrence of peaty er organic material as it occurs in nat.:re. ~ a . If you limit your answer only to the use of the preload ' Q T for purposes of consolidating manmade -- man-placed fill material, n does that same differential settlement reason apply? 5a

  • f A

In general, it should not; for the case under consideration, it may well be the case because of the variable i =atarials analogous to the natural soils. E=< Q What various materials are you re#= dav to? = I A Materials that are reported to be present in the fill =._ beneath the diesel generator building. _-.a O What are those materials? C A Materials like sands, clays, concrete, c=bbles, a { i* Q What was the last one? d '.a = A Cobbles. C-o-b-b-1-e-s. Cobbles. And that kind of W $i 5 material ac:mally found in glacial deposit. -= A Q Which is what? A Sands, clays, cobbles, but not concrete. Q Are you saying that the existence of the materials you l just referred to - namely, sand, clays, concrete, and cobble -- l 1: i 1 0* l I \\ \\ s t i. ALDERSON RE?CRTNG bMPANY. INC. i

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,N,-y ,m IOj$d[ {$[ -/- " r < t-~_E., TM'$.%yf.{[ ?g .~:- 7 ..4_: - n,u..., m..,. u - .4- +. -.m -F,((,,. .61 ( j ' :'. L.t:-., .r. w, -.., y,. f y.,, --.y. t.m.,.. _ y -. ' ~; f .,u.e ~. g, 3;. =. v.~ ~ 7 -mg in a fill material folicwing a prelead program,would create a potential for differential settlements? A If I may amplify -- Q Please do. O A -- the macerials were present before the preload 2 pregram. I believe you said present after the prelcad pregram. l T hese materials de have variable ecmpaction characteristics. And a 3_ since there is the potential for differential settlement in -i E naturally eccurring materials that are different, one would ez 5 by analegy expect different and differential settlement

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characteristics in this particular geologic configuration.

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~ j Q You used the term " consolidation" in one of your previous answers. Could ycu define the meaning of that term? ~ 3 A Well, consolidation in a very, very general 5 i terminology would mean the reduction in volume of a given s i volume of soil without a change in the weight of the solid 8 a,

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=. constituents of that defined volume. = ,E Q Are veu familiar with what is ccamenly referred to as 23 a consolidation test? A Yes. J j Q Are you also familiar with the terminology, " primary 1 jconsolidation"and"secondaryconsolidatien"? i. l 4 i i ,i t ,s .s i ALCERSCN MEPCRTING CCMPANY. INC.

...2 .s -. #. ; gi,yfla ; S:-g-k.- m,,f.. x..: G lJ i'J.. p 3.. _-- -fg..,].-{. }.; y 62 as. .. n e A I believe so, yes, sir. Q Could you define primary consolidation? A Primary consolidation is that portion of the consolidation of a soil under a given leading during which the d U.a water that occupies the voids in that specimen of soil is at a { greacer pressure than would exist at the boundaries of that j specimen during the lahcratory test. A j Q Could you also define secondary consolidation? i Secondary consiidation would be that por ion of the .c A c i consolida. ion of that sample that would occur under the same 5 a< given leading wherein the pressure in the voids in that soil i the same as the pressure at the boundaries of that sample. I was E or a simpler way of saying it, using perhaps other terms - I a i perceive you wish me to step. ta Q No, go ahead. f Ei A Using other terms, one would say that the secondary --2 portion of the consolidation is that portion of the consolidation ag a I under a constant effective stress. f3 Q If one runs a consolidation test and plots the amount of displacement in the sample as a function of the logarithm of the time after a lead is applied, is there any generally accepted curve or configuration which would result? 9 O E 1 0 \\ 1 ( Ai ccascN RE?CRTING COMPANY. INC. ~ 3 -.w, .g yv.-

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.w.,._..,_.,,,,_,___, g.. <., -..n a.. .-..,,,--:... - n -.,, n,. y.. n. .K ~ &g. p. . :._ : ax..,.. n-(, c. ... - - ms. A one can interpret the measured displacement of the Icaded portion of the consolidemeter and the time in a way that i allcws one to determine the primary and secondary per. ions of the consolidation curve. f 0 Q If you would, could you use this sheet of paper -- e. before doing that, could you explain how one does that. E A The movement of the leaded portion of the consolidemetas 2aj under a constant load is interpreted as the change in the void .z;: ratio of the sample that is in the consolidemeter. n .z: And this void ratio that is calculated is then plotted =. 43 against the logarithm of time under this constant, and the 5 characteristic shape of the e-log p curve is interpreted so as to i i = distinguish between the primary consolidation portien and the z;a secondary consolidation portion. 5 I. =,' Q I think you maybe misundersteed my question. The .3 f, question I asked was whether or not a particular characteristic G

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I ~ A Mav.be v.our answer did address that question. Did it or did it not? 1 A It did. May I explain? Q Please do. t i-I l s i l i ALCERSCN RE?CRTNG COMPANY. INC.

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n 5

Q No. Perhaps we can arrive at it by a different route; t-1 M instead of looking at a laboratory sample, if you looked at a field test and measured settlement versun icg H me in a situation where a preload had been applied to particular materials for purposes of censolidating it, would you expect any particular -- I t 3 p i AL.CERSCN REPORTING COMPANY. INC. L

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s 2

A Probably not. 5 Q Is your testimeny, then, if I apply a preload such as z a< what was applied in the case of the diesel generator building and 3 a 5 I measure total settlement as a function of the logarithm of time and plot the results, that there is no predicted shape of ~ 3 w 'E the curve? a ?. J i There is no particular configuration which I could a ni ~ predict as the final result of my plot? Is that your testimony? G 5 A The only way you could expect a characteristic plot a

=

k was if you assumed that all portions of that fill were undergeing a ~ the same stress and that all ;<-tions of that fill would respend to the same stress in the same way, which wculd =ean that the materials would have to be uniform sand or uniform clay or .niform something in order to have a " characteristic lead times-e I a 3 9 ALCERSON REPORTING COMPANY,INC.-

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reach the stage of secondary censolidation in this field test, i would a plot of settlement versus the leg of time result in a .c straight line? 2,- d A Not unless allether =aterial was cf the same type, c 5 and the reason for that is that in the secondary consolidation 1: .~, j of sand, it is generally semewhat different than the seccadary a< censolidation of clays in terms of the characteristic curves. 8 z 4 Q Let ms see if I understand your answer and make sure ycu understand the question. I am talking about a field test such as what is =,' actually done in the field in the use of preload for the purpose a ai of consiidating soils. I am limiting.the cuestion te fill l =aterial that has been placed in an area.

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,5 I presume that bv. c. lacine. the lead on the =aterial ~ s M you could expect seme of the - at least seme of the material to consolidate. Is that a correct statement? i A Ch, yes, yes. Q New, you have defined primarf and secondary consolidat: t f ALCERSCN REFORTING CCMPANY. INC.

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i 3

settlement marked at the top of the fill material as a function 3, of the icgarithm of time, do you and up with a straight line? %j (?ause) N A In my opinion you could or you could not, depending i E upon the distribution and the initial characteristics of the fill. I 3 itself. Now, if this was a normally consolidated clay all on the <a( same side of the A line and every other situation idealized, E I would answer ves.

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g For randem fill - call it random fill -- I guess a. 6 l l that's what you would have; I don' t see how one could make ' 2 + m that statement on a scientific basis. a m And therefore I hesitate to -- I cannot answer yes to c.a a j - .] your questien. ~ = E Q Is it your understanding of the statement I just made n A that has been made by Consumers Power Company's consultants with regard to the soil fills? A I am aware that a statement s4* 1ar to that has been made.~. Censumers Power's consultants. = l I e s j ~ t ALDERSON REPCRTING COMPANY. INC.

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..%. s.. s C. n% w- -- - ,. y ',.. +.. - = 1 Q Could you make the exact statement which you feel has been made by Consumers Power Company consultants which is similar to that? 3 A It is my recollection the statement is that the g j curve portion of the load -- rather, the displacement log time -n ], plot approaches or looks like a straight line. j Q And is that true with time when the secondarv n d censolidation is reached in the field test? g 5 A I do not k=cw, and I do not knew for the reasens I havs i i previously stated, the non-uniformity of the fill, the differm  % 3 m ~v .~ . n. m.. 1 1 ,,,. e < - 70 ~ .e

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e' I that the straight line characteristic was observed over a longer I period of time, which you refer to as a curve approximating a straight line, was observed over a, longer period of time, could a you then conclude in your opinion that secondary consolidation g

i 3

had been introduced? a well, I feel that my definition of secondary f A l I E consolidation, those conditions would have been met without M dcubt; given enough time, eventually the core pressure will .4 E' completely dissipate,and therefore you are by definition in i 1 5 i secondary consolidation. 4 <I Ecw much time is something else. 1 a 4 E then, that it is your opinion, the fact Q I take it, 3: i I that there is no particular point on this plot of settlement s = 5 E versus log time just by looking at the shape of the curve one l 2 could conclude that you had entered into secondary consolidation. 1 i Is that a correct statement of your opinion? 3 ~w

  • a A

Based on the data I have seen, that would be my a h opinien at this point, yes. i-4 In your opinion, can the straight line section of the Q curve, the section of the curve which is approximately a straight t line -- and again I am referring to the settlement versus log !,timecurve--canthatstraightlineportionbeusedtopredict f I i i 1 e i ~! } 4 ALDERSCN REPCRTING COMPANY. INC.

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' - ~ ~ I i future settlements? I ( 1 A In my opinion for this case, yes it can. Q Can that straight line portion be used to predict settlemenes with a reasonable degree of assurance in this case? e n A May I consult with my attorney? 2 MR. JONES: Do you have any objection? w M J i MR. BRCNNER: No. 1 N 2 (Discussion off the record) ~ Y THE WI"' NESS : Can I have the ques icn reread, please? = i MR. 3 RUNNER: Yes. Can you reread the question? <s THE REPORTER: "Can that straight line portion be used i E = 3 to predict settlements with a reasonable degree of assurance in 1

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= this case?" 3 j THE WITNESS: Cn advice of a=unsel, I wculd like to E put a framework around my answer since I cannot reply yes er no z 3 a to this question.

aa The reason I cannot reply yas er no is because the E2

= phrase " reasonable degree of assurance" in this case enecmeasses I i n many other disciplines than just mine. One must ask himself: i " assurance of what?" That has not yet been defined. What is 1 reasonable has also not been defined, to my understanding by our J j cwn Commission. .1 I s 0 i i ALCERSCN MEPCRTING COMPANY,INC.

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. f: m p.;f,a i ; A g -- J e - - ., gg..w J,q g.j;gg- <,cs. c.,,;. .....w-y = s .s. r I will give you my opinion for what it is worth, that the portion of the curve that has been determined at this point appears to be a straight line, but it is a very, very short straight line on the log time plot. i 9 I guess I would have to respond that at this point i 4 R R I cannot agree that there is a reasonable degree of assurance .~ r l 3 provided bv that short straight line to cover all of the variables 3 a ] I. involved in his case. I I c SY MR. BRUNNER: l i What - how much longer would the plot have to be.for j Q i 3 you to conclude that there was a reasonable degree of assurance? g J j 3 A The uncontestable length of time necessary to have 4 5 reached secondary consolidation in all of the types of materials g 0 under the diesel generator building would' have to be based on ~4 conservative assumptions. Such assumptions might be samples ni of the fattest clay obtainable under that building; permeability-- a 2a permeability characteristics drainage paths; times for = i: reaching secondary consolidation. s 4 3ased on the characteristics of that clay, if it was ~ 1 descastrated that the load was on long enough to drain even.that per ion of the fill, to me that would be an airtight case for l l l secondary consolidation. Those assumptions are very, very-t l i l l l t i N }. ALDERSCN RE. CRTING COMPANY. INC.

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....-- Q restrictive, but I could answer your question y.es if that was t in fact the case. Q could any of the -- strike that. Eow could any of the conditions you just nentioned t e, 3 be dete==ined for the fill under the diesel generator building at ~ 4 ~ R the Midland site as it presently exists? n well, you already have a number of samples f cm the j A E. diesel generator area; physical characteristics; pe==teability; i z' time for 50 to 90 percent consolidation can be determined for i these materials, ,i And the time necessary to consolidate the fill, i = l 90 percent or whatever, is a straightforward calculation. ~ = 3 Q Are you taking into account in that answer the known 2h 5 heterogeneity of the soils under the dieselgene ator building at G 1 z the Midland site? i l 1ee A No, sir.

  • a gl Q

'Does the known heterogeneirl of the soil under the l r i diesel generator building at the Midland site change your ) previous answer with regard to hcw it could be determined for l sure whether or not the soils are in secondary consolidatien? A The known heterogeneity of the fill soils certainly i nakes the assumption of a uniform fill composed of the fattest 9 8 .t l i l 1 I ALDERSON REPORTING COMP ANY. INC. i

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4-r t 'r .g, , ( g-, w r ebtainable clays, a very conservative assumption. j i Sut heteregeneity in itself,which cne might say means we really are not sure what we have, except this is a lot of stuff f there, ma]Ses it difficult to quantify the contribution of the g M 3 heteregeneity to the censolidation process in any kind of ratienal 4 n wav. a K i Q My questics was directed to whether or net given. n N materials which have been used fer fill under the diesel generator Y E building and given your previous answer with regard to what z' i samples have to be 1ccked at in order to determine if you are 1es you R 4 would take -- strike the question. R R., Let's go back to the beginning. You probably have I n] forgotten. J = A I was following it very carefully. I understeed it the 5 second time, I believe. E_ i Q Wouldn't you agree that the heterogeneity of the <m i fill under the diesel generater building affects ycur ability to z= ,= extract or chtain representative samples? E E A Yes. A i 5 Q If you had a mixture of clay and sandy soils, which I a= believe are at least two or the ecmponents of the Midland fill, aa e clays, and I believe the other one you' mentioned was concrete er aa= l cobbles - s A I believe materials of that nature have been f=und. i M Q Isn't it a fact that given those materials in a field test prelcad, the clay will dominante the final result frem a settlement standpoint? I I A -Yes. t i t I l l l 0 \\ l l f t l i ALCERSCN REPCRTING COMPANY. INC. t

'. >l *,.1 - c. ~ r,~_ ~g -.+.%.y:.L.... ,. #,., f. .?;g. c.;;;.w. n,: -n .._.....g ..;k;l:2,- -fs ...e ci%. ...u e- .g... 76 r Q Is that why you celieve it is necessary to obtain a sample of the fattest clay in order to predict whether or not ! you are at secondarf consolidation, what you refer to as the l 3 fattest clay? R j A The fattest clay or that with lowest permeability ?'. A would be the material that would control the length cf time j necessarf to obtain secondarf consolidation. I do not knew that I any sampling would be necessarf. You have already dug a lot of test bits in that area. i 3 You already know very well the range of materials that are <3 a present. E j Q What is the expected shape of the settlement versus 1 i log ime for clay? a ] '*j A Well, the secondary consolidation of clay materials i 0 1 x eventually approaches a straight line for a portion of its void 3a e ra ic log time curie. a M The eventual tail end, it departs from that straight line. It has been observed to depart from a straight line, hope-fully on the conservative side. 4 Q I believe my question went to settlement versus log i, time. I think you have answered it by qualifying it and changing e i it to veid ratio versus log time. Could you answer the questien + l l I i i 1 ALDERSON RE?CRTING COMPANY. INC. 1 i

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f::,Q, ;~. A -...-- - .f..,_. '~-*-;;;.. m +k - with regard t:., settlement versus log ti=e? A Settlement leg time behavior of the clay would eventually approach the same characteristic shape for the clay. By " characteristic shape" I mean scw an essentially straight line a M 3 ortien at the and of consolidation time. M R_ Q What is the overall shape of that curve? Ycu can use Mj this sheet of paper and draw it if you like. E MR. JCNES: Can you mark this semehcw and put it on ~ ) E the record? 5 1 I MR. 3 RUNNER: Yes. <t d, (Pause) 3 "'HZ WITNESS : You have a shape something like that. = i i (Indicating) a. 5 MR. JONES: Go ahead and note on the bott:m just wha 5 2m he is drawing so we can show what it is. ta MR. BRCNNER: You just handed me a piece of paper aal vhich I am going to mark as Consumers Power Company Exhibit l Number 2 - Heller Deposition. It is dated 10/9/80. 5 n 1 (The above-mentioned document I I was marked Consumers Power Company's Exhibit No. 2 - Heller l ceposition for identification.) i t E h i ALCERSCN REPCR 1NG COMPANY.'INC.

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~. _gg.-- 79 '_ ,2 4.: n -m ;; u. .. ;..=u..m ,s > > a. 2... ~ --....,m.._ , u......,,., g *.y p;.1%- g . s.e *. r% y Q Oc you recall C. ::anda's nethod for dstormining the point at which you have en: S =pon secondary consolidation? A From that part'~ plot? g Q From a plot s' - to this, yes. g j A No, I do not :se:J.; his construction for displacement A. or settlement log time. i j g Q Earlier you sali sat with regard to the diesel M .a generator building area, cc ":mers Power company already has a ~ I E large number of samples whf. have already been taken. Is that ij a correct statement? 3 A I think they had sema test hits under there and took i some materials out for cize:. :.iication and whatsot. = g Q In your opinic=. :.s the datr. which Consumers Power wl Company already has suffic:.: to, if analyzed, to determine 2 whether or act secondary c. .sclidation has been reached? 3 e A I am not sure vi sher that is the case. I believe they m a3 .} had two test bits, and the. ran into a wide variety of clay l i: consistencies in that bit. surprised if the rest of the fill I guess I wou'.i 1 ran outside of the ranger .:.t they had uncovered'. It could be. 1 Q Referring again.o your plot of settlement versus log l l time, which is contained ;. Txhibit No. 2, in your opinion, would 6 i 8 s i 1 t i ALCEMSC ' *EPCRTING COMP ANY. INC.

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. ;-; y _ z. ?.a W :-.-c.- ,,,.3 .. ;.: Q :3 5 g,.-. .j k. [ ~ '._n.e_y qy ~ ~ ~ ~.. - . - + < _ .e -. sw.;... u .s-j SO s r a plot of sectiement versus log time for the diesel generator building foundation differ i.n any substantial way frem the plot which you have shown here in Exhibit 27 I do not have a sufficient background to answer that A 3 question because I have not icoked at the kinds of materials [ discovered at depth under that building. M 3 o If you assume that the fill material under the diesel n i sands E generator building consists of clay with icw plasticity I E and some cobbles and concrete, then in your opinion, would the 'j i observed behavior of the diesel generator building foundation <sg, under preload differ substantially from the plot which you have 2 3 exhibited here in Consumers Power Ccmpany's Exhibit No. 27 1 j (Pause) E A Probably not in a substantial manner in terms of the 2 2 shape of the curve. m 1 g Q I would like to have you take a look at a document a 3j which I am marking as Consumers Power Company's Exhibit No. 3 - = s Heller Deposition, dated 10/9/80. (The above-mentioned document was marked Consumers Power Company's Exhibit No. 3 - Neller l Deposition for identification.) i I i I 1 I ALCERSON REPCRTING COMPANY. INC.

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If you look at figure three of that document, could n N you tell me basically what that figure purports to be? 3 (Counsel handing dccument to witness) ,i_ i (Wit =ess reviewing document) <s i A The figure purports to be a plot of measured and 2 i = ~ predicted settlement versus a log of time. There are some j = j notations on the figure that indicate that the permanent marker a Y.y could not be monitored from March of 1979 to Sectember of 1979 2 a due to emplacement of surcharge,and temporary markers were used ~ Ba at another elevation during this period. esa 'Q Does the plot indicate which settlement marker is bei a = 5: implied? E .4 A It indicates that the data is based on a temporary marker from the settlement of che zero until roughly ISO or so days later. 4

  • hen there is data based on the permanent marker up l I

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j A

According to this plot, the permanent marker did not 3 move frem the period september 14 to June 12, 1980, to the I 5 resolution of this pict; one would say it did not move. E_ i Q Lecking again at the plot, again assuming that the <3 f data has been plotted correctly and accurately, can you observe 3 j anything with regard to the rate of settlement or change in the E i rate of settlement which occurred at approximately the 90th a j day into the plot en the time scale? 2x A According to this plot, roughly the 90th day it appears 3 3 that the rate of settlement changed quite dramatically. I cannet ua j see the data points so it is difficult to say whether that wculd s have been a curve er whether they.are tso straight lines. a Q Again Iceking at this plot,which is centained in figure three of T.xhibit No. 3, if you lock at the pcrtion of the curve 1 I which has been plotted between that day that you just indicated I i i when there was a dramatic change in the settlement rate noted en l H i s-i. i ALDERSCN REPORTING COMPANY. INC. l

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.y;~.- - ~~ y x.y .u=-- + .~ the plot and 8/13/79, which is noted on the plot as the date t of surcharge removal, could you characterize the shape of the curve between those two points? from the 90th A well, it looks like a stair step to me; ~ line day on out to August 15, there are a number of straight ll1 portions through which either a line could be interpolated or an I average line could be - probably be drawn. 3 N_ One could also, I suppose, plot a curve through those h points if he se desired. 'There is seme slight curvature to that "z'! line. It appears to be approaching a. straight line, however 3 . Indicating) ( .2 5 j Q Are you familiar with optical surveying techniques? = 3, A Yes, sir. a. Q Is it consistent with your understanding of those techniques that when used to monitor settlement you obtain the k [- stair step pattern to which you referred when characterizing the ~ ua plot between the 90th day and 8/15/797 = I am not familkr with the physics of optical surveying; h A that would indicate an expectation for a stair step plot; i no, '4 - [1 ~ sir. Is it true that the ssolution of. optical surveying Q devices can cause or could cause a stair step shaped plot? I a 1 I i i i t i l l ALDERSON REPCRTING COMPANY. INC. 1 l-

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==_ .g_.. 3 pp - _.'%.**'.-ap*_ l i - n: s... ,a g4 -+ i r-A Sure, it could happen. (Pause) 1 MR. ZAMARIN: Shall we take about five minutes? O' -J (Recess) i S 3 3Y MR. BRUNNER: f 4 R 2 Q Taking a last look, hopefully a last look at figure a: K j three to Consumers Power Company Exhibit No. 3, which, as, g. .4 previously described, is a plot of settlement in inches.versus .d = 1 z l time counted in days plotted on a logarithmic scale of what 'M i I purports to be a settlement marker or settlement markers at a f*N <a particular location in the diesel generator building area, Midh .4 ji

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= 4 I' 5 .-} } date that appears on it is reported accurately on the plot, ~ 'r j j can -- do you have any opinion as to whether or not that' plot N

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.a, a is clotted thereon? .d .a ji. 4 2 A Well, you use the best information you have, and thi ,j, ?~, 2. 8 is the best information you have. So one would therefore use i n s .4 that to make an estimate of the settlement that is likely to l;) occur in che future. y M .Q What is your estimate of that settlement which is 4-t s4d i likelv to occur in the future? Y3d 21 l

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l .Jt,s. t.*q.; .) e.* -:---w .g -== *e maw.-s e s,. - + -~~.-.- -- ~ -- "Qp, -.,.y.. Mfy &; g=. w..,ws..., g. %. mr.eJ.-....m,p.M u - ~..,... M - - h%. s. ._..,,, e t.-ec2.c.._e-.. , v.4/ 4mqvq7. ]. -e .w 4mv..,' g...-- 3'y Q.iv... -a-g u p.:.: ---_..-me..~a,.,-, w, z. 'g5 . :r :. n >n. = - n.,,,,.. p.c m; 4 g, ;. ,t. e w. - _ - u I personally do not have enough information to make A future settlement would be: a guess or have an opinion on what that Q What other information would you need? (Pause) 3 well, we talked at one time about how long the line A ~ would have to be with respect to log time in order to arrive at M J i. j an extrapolation of that line for an upper bound settlement n ._a = estimate. Certainly, that would be helpful, to have a data base ':z I for the extrapolation of that line to a later point in ti=e.

i am not prepared at this tifne to say what complete information 3

z = } would be necessary to make that prediction. E I would think, as a minimum, at least one other 3 E 5, confi:=atory approach would be prudent to gain confidence in the ~ i r extrapolation procedures based on these data. i l 3 a j Q What is a piezemeter? lda .} A E A piezometer is a device that is inserted into the

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- sw.. , ct;,. 86 r 1 If piezemeters were installed in an. area where the prelcad program was instituted, would you expect any particular behavior of the piezemeter indicative of the fact that you had entered into secondary censolidation? = 3 3 A If the piezemeter was sufficiently sensitive to e W R detect pressure changes, one would expect the piezemeter at the ~ e of secondary consolidation to record a constant pressure -d n 5 versus time. 5 Q What sort of behavior would you expect f cm a i i piezemeter during the phase of primary consolidation?

  • e3 i

A cne would expect the pressure recorded by a sufficienta z= 3 sensitive piezemeter that in fact measured the core water E i pressure to record a pressure higher than that that one would W E; expect due to the static groundwater table elevation. G Q Co you know whether or not Consumers pcwer Ccmpany 3a . installed piezemeters in the area of its diesel generat== l E I building?

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A I believe that they did. m 4 .9 l I Q And haw they provided data from those pie ometers to 4 the NRC in connection with their application? I A I believe so, yes, sir. Q Have vou reviewed that piezemeter daca? 2 t o4 ..e f i ' ALDERSON REPORTING COMPANY. INC.

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-.a 7 - - + f A No, sir, I have not. Do you know if anyone in your secticn has reviewed that Q piezemeter data? I understand that Mr. Kane has reviewed that data. A Do you know or have you heard of one Dr. R. 3. Peck? n 3 Q M .4 A Yes, sir, I have. Is Dr. Peck a recogni=ed authority in soils engineeringi ,j Q J = A Yes, sir, he is. is he not an internationally known, Q In fact, z_ i recognized authority in soils engineering? He is one of the internationally recognized authorities. m a A 5 Q Do you know one Dr. A. J. Hendron, Jr? ~ A Yes, sir, I do. U Is he, too, recognized as an authority in the area of Q 2 3 soils engineering 7 m m A Yes.

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Q Do you know or have you heard of Dr. M. 7. Davisson?

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~ s A Yes, sir, I have. ~s And is he a recognized authority in the field of M Q soils engineering? A Yes. .i 4 Is he also a recogni:ed authority in the area of pile 0 Q t i i s. 4 ~ ALCEMSON REPORTING COMP ANY. INC.

~ ' ' ' c ::.;- j L '=Y ~,*3.g-fl 4. 2 L $3h.73 s %~ ., m q _, ,~Nr ?.'yj-[} .,*,3 * :: __- k. Kw.] _ ' ' '. - j'* **5*. g,. g.. ,,,e ,,~ w..,.,:. 88 b t I t and caissons? 1 A Yes. Q Are you familiar with the document which has been marked as. Consumers Power company Exhibit No. 3 and is entitled, R j " Discussion of the Applicant's Position of the Need for Additional i R Borings"? A I have leafed through it. I have not read it in i detail. Y E Q on page 6 of the document there is a section that is i

entitled, "3 earing capacity."

Have you read that section in 3 I a detail? .i i. 3 A No, sir, I have not read it in detail. i 3 i j Q Have you read it with enough detail to express an a i-J opinien as to the correctness of the analysis that is provided in i 3 that section? ss A The analysis appears to be the same as that presented .aa on September - August 29 at Midland, Michigan. And I did not i h read it because of the similarity between this information and i an that which was presented at that meeting. It appeared to.be correct Q The analysis in this section is entitled, " Searing e1 Capacity." In view of your conclusion as to the apparent l t i 1; 1 ALDERSCN RE.*CRTING COMPANY. INC. .~

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7-correctness of the analysis, do you have an' opinion as to whechi 3

or not Consumers Power Company has demonstrated adequate -t ~' 4 acceptability of its Class 1 structures at the Midland site 4 w 1 from the standpoint of bearing capacitv? e I H A Again, I will have to qualify my answer; I do agree .i 3 that the method of analysis appears to be correct as presented y i E in this exhibit. Q n I do not agree that it has been de=enstrated that th' ,j t j appropriate parameters for insertion into that mathed of analys i i Ij j has been determined and demonstrated. .1 3 Q If you need to, you may refer to that section for my s = 3 next question. My next question concerns which parameters '.] i

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you feel have not been applied correctly or used correctly in cu ] y bearing capacity analysis so as to limit your ability to find s d tj ~. adequate assurance f cm a bearing capacity standpoint. .a 3 n a A The variable C, the variable NC, and possibly the .I n. variable N. Q a

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Would you explain why you have a problem with variab in C7 i 4 A variable C is an indication of the strength assumed j for the soils beneath the footing of the diesel generator ) 4 building. To ny kncwledge, no strength cost of an appropriate c. .;bl ~ i +1 ?, 9 9 ..c

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c Q Excuse me. Before you go on, what is your understanding of the way Consumers Power Company obtained its value for C for S j use in that analysis? R A, A okay. I have been told by members of my staff and sj by our consultants that the materials tested to obtain these N parameters were obtained not from beneath the diesel generator building, but from a portion of the random fill in the area of I. i the horated water tanks. B a Q Is it true that - i E = 3 A And that the driving resistance characteristics for .a that fill were also interpolated from the area of the horated j 2 l water tanks to the material beneath the footings of the diesel 2a generator building. m I have not confi :ned this on a personal basis, but a 4 euaj that is my reason for stating that the analysis method appears = 5 correct, but the input parameters appear to be questionable. X ~ Q Do you have the same problem with NC and :r ? g l A Yes. Q co you have any other problems with regard to these parameters? ) s l, l ALCERSCN REPCRTING COMPANY. INC. 1

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}.g, A None that have been brought to my attention. (Pause) Q on page 7 of this Exhibit No. 3, about half way g through the page it states, and I am quoting: "The drain ren ] angle of bearing resistance is known to be primarily a function R A of the plasticity. characteristics of the soil. And as the K] plasticity of the sample tested is within he range found beneath " a diesel generator building, these tests are representative, 5 and testing of samples below the diesel generator building would !j not result in significantly different design values." =g, Do you agree or disagree with that opinion? 2 j A I would have to disagree. I g Q on what basis? -l A on the basis of some of the reported strengths that 23 were obtained in the test bit in the diesel generator building B a area. g al Q Is there any other basis for your disagreement with the conclusion or opinion expressed? / 1 A The fill is known to be highly non-homogenetic. I am unable to conclude that there are not soils of similar strengths beneath the diesel generator building that were discovered in the test bit. Certainly, these soils are variable. And whether one ii 8 l 1 t g e j i ALCERSON REPCRTING COMPANY. INC.

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Kr. a %& 3:~~*:Sc- ~..- n.'.kSG2?:.}~; 5.: _-- Q.y _3;g}l.f ~ %.w - . m <* ' y .t is justified in averaging those conditions is to me questionab.'e. Kane ever expressed to you his opinion Q Has Jo e concern'ng whether or not there is a bearing capacity pre

  • clam at the Midland diesel generater building?

4 n 3 A He has. A Q And what was his cpinien, as expressed to you? 2 A I believe he said that he did not have a prcblem with n n E the bearing capacity. 's: Q

s it a normal practice in design and construction to

~ 3 i take shear streng-d and - shear strength tests and blow counts <3 i under each and every footing of all structures in a nuclear 2= 2, project? 2 ] A No, it is not required by any regulatery guide that if we have available to us at this td.me. 2' =. Q Is it the normal practice of the NRC to require aa shear strength and blew count tests under each and every fccting .:aa [ of buildings which are founded en glacial till material when- ~. ri: considering an applicatien for an operating license er a 1 M c construction permit? l A Not for footings, no. 4 Q Is it not.also true that glacial till typically exhibis 1 } a fairly bread variability in scil properties? i. l I j-i e i i i i i ALCERSON REPCRTING COMPANY. INC. i l

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.-.x w .,:c - f_'n__ -*T- --,a i. .-..<=.n,,.-.,= 5 A It definitely can. Q. Have you revieweda consumers Pcwer Company prediction l I for settlement which is likely to occur as a direct result of g the proposed dewatering system that they have at the site? 3 j A No, sir, I have not. l R R Q Do you have an opinion as to the necessity of taking ~ M g additional herings'in the area of the diesel generator building ua in order to demonstrate adequate soil properties? Such ~ I E additional borings have been requested by the NRC. i A Tes, I have an opinion. <3 g Q What is your opinion? 5 j A I believe it would be highly prudent to do so. = 'i g Q Would it be necessary, in your judgment, to take y these additional borings in order to demonstrate adequate G 2 acceptability of the soils below the diesel generator building? me e A It seems to me this would be the most econcmical uaj way of doing it. There are probably other approaches to 1:s obtaining the necessary information that could be utilized, all of which would probably be more expensive than the sampling and testing program requested by the staff. i Q Concerning your conclusion on bearing capacity which was addressed on page 7 of Exhibit No. 3, are you aware that in I 5 l 3 l 3 i i ALDER 5CN REPORTING COMPANY. INC. -e,r r-r - - ev .,, ~, - - - -, - ~ ---t

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o -},. r . - c s. c. s e-94 r" i I this analysis the factor C with a bar over l't was taken as zero and the factor C was based on samples of lowest density? a ,2 A I believe that Professor Hendron so stated in his 3 g presentation at the meeting on August 29. ? R j Q Does that change your conclusion at all with regard 9 ~ 7 E bearing capacity? o.; ~ No, because the investigation was done on materials e i A a that appear to be the best materials in the entire fill, those ( t E the area of the horated water tank. And I am not at all convinC- ~ S. E -,.j i that they are representative of the material here. B '1 g, Q You stated that the samples upon which this analysis j E g was based were taken at the horated water storage tank? -w g i A I believe that is correct. 11 J Q If you assumed the samples were taken at the horated 2= water storage tank, the condensate tank, and the Uni 1 E a { e transformer, would that change your opinion at all? 'd ne J we..' l A I am not familiar with the conditions at those areas, = so I do not have an opinion. j Q Do you agree that the drain angle of friction for a soil is a function of plasticity and not of density? (Pause) 1 } A I would agree for a static test those do seem to be

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4 ..ar. m:. s; .hMe_. .g.h.h :[_. ;.3d;j.,,,b., .5 ryj:31-?hT.7f; M @ 9 - ~... s, -t "M*^ ^s.- = - C'*".%U 2.-..--. M "Y 2._. :. se=== ,;pfiQPfp.s., M. M ' @0ff2. ...c 1 y ~." ;. m.c. ,,.,..g m s, s. m.m,,,..s.,..,,. .;.y 95r < ;. u.... ,'}.2Ln -.:=~.., 3 - L:: ~ ~ '. : ? - Q correct correlations. 1 Q Have you reviewed the Censumers Power Ccmpany preposed fix in the tank farm are i A No, I have not. I i 3 g Q Have you reviewed Consumers proposed fix in the area of f the service water pump structure, the part of it that is founded ,j en fill? A I have not reviewed the latest submittals. I am g aware of the general scheme for both the service pump house and 5 j the horated water storage tank, but I have not gene into a detailoz 3 review at all. t = i (Discussica off the record) i I MR. 5 RUNNER: Back on the record. l j g i w I BY MR. BRCNNER: 5* Q What is your understanding of the applicant's - ai a-Consumers Power Company's proposed fix with regard to the service a

d 5

water pump structure? a A I understand they are going to drive some piling on the cantilever side of the pump structure and to attach these piles to the pump structure with some bolts. 1 J Q In the NRC's latest request for borings, did they request a boring in the area of the service water pump structure, { c J l i, N j i ALCERSCN REPCRTING COMPANY. INC.

' M Q'. 2. 3::Qc':(e 64 .- N...Y $ d'23 ;f,; y -. g.)) ~.{.].gg --- i w a... >.: 96 i r to your kncwledge? A Yes, sir. I am pretty sure they didt they should \\ ^ z have. s Q I am going to hand you a document which I am marking g j as Consumers Power Company's Exhibit No. 4 - Heller Deposition. 1 E_ It is dated 10/9/80. It is' a document which purports to be a

j istter to Mr. J. W. Cook, Consumers Power Ccapany, from A.

l s Schwencer, acting chief, licensing branch number three, Division Y 5 cf Licensing, dated June 30, 1980, along with an attached service iE 2 or ec. list, and an enclosure one consisting of three pages, c 2 <3 f, figure 37-1 and figure 37-2, each consisting of one page. 22 (The above-mentioned document i 3 ~ was marked Concumers Power 5 l company's Exhibit No. 4 - Heller f Deposition for identification.) a 4 Ba SY MR. BRUNNER: j g al Q Looking at this Exhibit No. 4 at the page that is li: marked table 37-1, could you tali me for certain the NRC has I requested boring in the area of the service water pump structure? (Counsel handing document to witness) 1 A The lefthand column of table 37-1 on the third entry under location indicates service water pump structure and = i i I i- ! l ALDERSCN MEPCRTING COMPANY. INC.

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. i. -Q l retaining walls. Q Can you tell from that how many borings have been requested? s A I believe one hering has been requested. R 3 Q And would that be in the area of the service water R A pump structure or in the area of the retaining wall adjacent to g the service water pump structure? d = A I would have to look at the plot plan to make sure t 5 they are not terribly far apart. i Q Is there a pict plan attached to that exhibit? <a e A I believe so. i 3 ~ Q Go ahead and look at it. 3 (Witness reviewing document) 5 ) Do you have an answer? 2 3 A I would like to correct that. The table 37-1 aia g indicates one boring at the service water pump structure and aj two borings at the retaining walls. The plot plan shows CCE E boring 16 relating to the service water pump structure,and for the two borings related to retaining walls, CCE 15 and CCE 14 would locate those two exploration points. Q Are you aware of the reason why the staff has requested 1 a hering at location COE 167 s l, t i ALCERSCN REPCRTING COMPANY. INC. ~*

.. c. .. ~. w m. h.nh,; 12.-Q ' :: h-.-q.-};Q,g..J. -.3.,;$*;,~g;f.. _. . '.:;qc.-Q:?u %*? , v... : 1 c'c Y:; :.. +.a .a-,- ?c - ~,. t A Yes. Q What is that reason? s A The reason is stated in column five of table 37-1 and would be used for confirmation of pile foundation design ~ r, j feasibility for vertical and lateral loading. W Q Are any samples requested to be taken in connection 2 t r,j with that boring? 4 1 3 A Yes. ] 5 Q Wculd those samples be in the fill material, in the I 4 \\ i glacial till, or both? <a e A I believe the intention is for both materials to.be i g = j evaluated. I g Q Why is it necessary to take a sample in the glacial I till material? $i3 A To determine the properties of the glacial till that 3 i z i e will assure expected support for the underpinnings of the pump aa 4 l house. l Q Are you familiar with any of the horings that were l taken by Dames s Moore in the glacial till at the Midland site? 4 A No, I am not. Q I take it, then, you are also not familiar with the t I location of the borings that were taken by Dames s Moore in the I I t' i l i l

  • i i

ALCERSON REPCRTING COMP ANY, INC. l

=.. + 1 .. sm: ~C: .= _ 3f+. _ Q.b'2mm -u-. eg'W::.=&-{h.f M @ .g..:..,_ _,,,

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. ;,. s.. m,.,._..m,,,, .. -.w.. c c. ,., - -,.~, -,, m.. r. .-.m.,,. - -.. ~.. ..y*- . ~. 7.m. -Q ,xt: m.~ n i -:: glacial till? i A I have not checked those locations, no, sir. Q Did you. review this request for additional herings before it was submitted to Consumers Power Ccmpany? i g 2 4 j A Yes, sir. A Q And did you concur with all of the boring locations ) 4 j which have been requested? J = A Yes, I did. 4 .il l 5 Q Did you originate the idea that Consumers should have lj to take extra borings at the Midland site, or was that originated i 3 by someone else? a t E j A It was originated by someone else. i 1 E Q Who was that person? j j A I am not sure who that person or group of persons was l a 1 who made that determination. I am fairly certainly it came from i s am .e our consultants. ,a j j Q Now, again, looking at table 37-1 of Exhibit No. 4, = s has the staff requested any borings in the area of the auxiliary k building? A Yes, they have. Q Are those horings in the area of the electrical I penetration part of the auxiliary building? i f ) + e l N e e 1 I i ALDERSCN REPCRTING CCMPANY. INC. l

2 k- : e-a.- - .-~.. =: -+ ' :p. y-g.,,. 3;qJ'" - : n w.-g ~ W '" . -m z:v: x. .-.'n-7gn r i 4 A They are very close to.the electrical penetration areas of the auxiliary building. Q Do you know what Consumers proposed fix is with regard to the electrical penetration area? g 2 j A As I recall, the proposed fix was a fill concrete 1 R under that particular part of the structure. K g Q Have you reviewed consumers Power Company's submitted I e infor: nation with regard. to the electrical penetration area of a 4 i E the auxiliary building? i'l A I have not reviewed it. I have been briefed on the B concept that is to be used. As I recall, the fill concrete was a t 2 j to be used beneath the small portion of the auxiliary building. I l g The caissens were to be used to support the ma!.nportion of I the building that required remedial support. 3 a Q Do you have any objections to the basic concept which g a the applicant has proposed in those two areas that you have ea

dj l just mentioned?

I A Yes, in one area. ~ Q Which one is that? l A The portion of the auxiliary building that is to be i supported on caissons. Q What is your chjection? l i' t x e ALDERSON REPCRTING COMPANY. INC. 1

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. c... sm ;w:. .. m, =. m,. a. __ w... e. ~. ...m... . 101 ......m i.." o m u-p ..,-,,. ~.,...,. _~.. l _ y? i .s p % p: - .y...,. v,. ..u w.-_ - g,2 W i A The cbjection is basic in that the structure will not i be supported in the manner for which it was designed, and the .i !, consecuences of that are likely to be indeter:ninant with or 11 without analysis. ~ r I H What is the difference between what Consumers has i Q { presently proposed and the way the s m eture was designed which creates a problem in your mind? A The assumptions for the support conditions :nade for I i a spread footing or for the mat foundation are different than the s. Ej sueport conditions and loads that would be imposed en this 1 presently existing foundation by the placement of caissons beneath : a j ..r i = only a portion of the foundation. n Q Is your problem with the loads which will be introduced' 1 5 r I to the structure by the caisson itself? 2 1 3 j A Yes. Ei Q co you have any other problems, or is that an accurate a u W statement of your entire problem? l o 5 A well, they are all factors that come into play when R you support a structure in a manner differently than that for ll l which it was designed, including its response to dynamic loads, I j wind loads, or any other combination of loading that the s m eturO i l was expected to resist and perform satisfact=rily. ~ l I 9 I f ? N ALCERSON REPCRTING COMPANY. INC. l

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~ , N% c... :. .,..,;..-a 102 s l l { In all cases, the changed conditions,at the foundation ~ } l1evelwouldhavesomeinfluence, and I cannot address how much or 1 the consequences of that, but certainly the conditions are-different and would impose different stresses and strains on thac l 3 M 3 structure, a R 4 3 Q Are you familiar with Consumers Power Company's s g proposed fix with regard to the underground diesel tanks? A As I recall, in response to questioning on the diesel j i E generator tanks, fuel tanks, was that there was no planned i i remediai action in this area. <R a Q It is my understanding the diesel fuel tanks were f= j loaded by filling them up with water. Settlement was then observed i .i g following that; is that consistent with your understanding? t 3 A I believe that is correct. I 4 x Q Did you observe the cattlement data that was obtained i 3 m u-during that process, during that stage when the tanks were filled wa l up with water' 1 G A No, I did not. I j Q Referring again to Exhibit No. 4, figurra 37-2, I believe you earlier stated that there are two retaining walls l shown in this figure. Are both of those retaining walls Class 1 s m etures? ~ 1 i I i s l ALCEMSCN MEPORTING COMPANY. INC.

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  • do 1 its ability to provide for the safe shutdown of that plant, not kncv whether they have been classified by Consumers Power t

I i l as " Class 1 structures." .I l s ,Looking in particula'r at the retaining wall which is l l Q ll 4 in the area of boring designated COE 14, can you explain why, I i j ~, in v.our co. inion, that retaining wall is related to the safsty i .4 I 'J of the plant? E cur reviewers have brought it to ny attention and the I. A ,.I attention of others,that that particular wall retains fill soil 3 into which the diesel generator fuel storage tanks have been I E E buried along with the associated lines for moving that fuel to the =_ I diesel motors themselves. A E our reviewers have pointed out that should that wall 9 I move and the fill with it and the tanks with the fill, that the n l 4 fuel lines could be disrupted such that fuel could no longer r'eae.% 3 da

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the diesel generator building. It becomes reasonable, then, to provide some measure r. t of assurance that the retaining wall. adjacent to boring 14 has a l l sufficient degree of reliability to prevent such an occurrence. Q When you refer to "our reviewers," what particular individuals are you referring to? ~ l i 'i 1 ALCERSCN REPCRTING COMP ANY. INC. s

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d team of reviewers who are cooperating in this review, both in -j a parallel and in a line of command nature. d j Q I, coking at the retaining wall adjacent to the boring 3 5 location designated COE 15, have you reviewed Consumers Power 1 i = g Company's submitted data with regard to that location? a y A No, sir, I have not. =, 1 5 Q Do you know whether or not your consultants have done i g so? g A I cannot make a positive statement. I am assuming i a i = that they have reviewed the latest submittals on that particular a z y retaining wall. a2y Q Do you know what the staff's position is with regard o i to the adequacy of the materials in that retaining wall? i l A I do not believe a conclusion has been reached in the i i review process with respect to that retaining wall nearest to COE t \\ f 15. I believe it is still in a review mode, t t 1 Q Why did the stliff retain the services of the Corps of-t 4 i f j I ALCERSCN REPCRTING COMPANY. INC.

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[{ 'n j, r. gw-:.v,.p.m..w.,.v-m.,., y . : - v.:. :. ..,.n...n.,..,m.,,...._, s- ~. p*u,,. : 2,.- g . a.:t <n w - -- 3.~;; Engineers as a consultant on this review? ~ I A We retained them because we realized that the scope 4 3 of the review and the time and the resources necessary to j j s . successfully conclude this review would be far beyond that that .4 l j

  • is usual for an OL review in the geotechnical area.

And the 7 i i staff would not be able to handle it in a timely or sufficiently ?9 i j detailed manner. N Q When did the. staff retain the services of the Corps y E of Engineers as a consultant? I A For the Bailly project we requested their assistance in the fall of 1979. a 4 iE l j Q What abe'ut for the Midland project? 4 3 A For the Midland preject we requested their services } j 1 .h l in the fall of 1979. 2 4 a j i Q You stated earlier that you personally were aware of m a ~ 1 a the existence of the problem with soils at the Midland site in 1 a

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l j g the fall of 1978. Isn't that true? = ~ A That is correct. Q Why did you wait for 'Aat locks 1. Dea period of a year l before retaining consultants to help with the review on this J. problem? A curing this time period I approached individuals in i f u 3 s i i ALCERSCN REPORTING CCMPANY. INC.

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+.s-_- I ..c LW. ..r:. l t f whcm I had confidence with this probics, outlining the secpe of ~ 1 the problem, and was unsuccessful in obtaining their services. 4 Because I was unsuccessful a number of months of ~ delay occurred before I could -- we could engage persons to s g j l undertake this review. 5 3, Q What persons did you attempt to - rather, what g i j persens did you contact with regard to obtaining their services 3 in this review? Y E A I contacted Mr. Leroy Mac Inear at the Waterways 3 Experiment Station in Vicksburg, Mississippi and requested that t a he also supplement his resources with an overseeing consultant y 'T 2, by the name of stanley Johnson. ~3 3 Q When did you contact Mr. MacInear? t A I contacted him 'in the spring of 1979. !2= (Pause) I believe I have answered your question. a g i / Q What about Mr. Johnson? Wan did you contact him, if A you contacted him personally. l At about the same time or a couple of weeks earlier. A Q Are these persons members of the NRC staff? A No, they are not. Was there anyone in your section, other than yourself, Q i t. l i j l I ALCERSCN REPORTING COMP ANY. INC.

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4.. N.. x. ....,...s.-.,...,.w...,,...._._,_ ,.s.4 f,,m% t.= a-- ,i,: -m.g+' who was reviewing this problem namely, the Midland soils problem 8 A Yes, there was. i Q And that person, I take it, is Mr. Kane? t i s l A , No, sir. That p,erson was Mr. Dan Gillen. 3 l j j Q When did Mr. Gillen start his review efforts? I Very shortly after informatic's became available f ca A --j our I & E office and from Consumers Pcwer. N Q Was anyone else in your section assigned to review i f: the Midland soils problem at that time? I a A No, sir. <n s Q When did Mr. Kane start working on that problem? A Mr. Kane started working on the problem in the fall I of 1979 - I am sorry. Strike that. g 8 Mr. Kane started working on that about the first of the 5m year, 1980. aw Q Was Mr. Gillen working on it up until the time l Mr. Kane started working on it? j k A ^No, sir. A Q When did Mr. Gillen terminata his efforts working on the problem? A Mr. Gillen transferred from our office to another ' office within NRC -- I cannot recall the exact date -- late 1979.' I a 6 4 I Al.CEMSCN REPCRTING COMPANY. INC. o-o

' C; .. a. . ;;,. 7.Zp-..- -..... Wg,g. R. w:; ~~...,y ,-: 7. a.; .~. ' h;fc- ,,,,..g, -- e. >.g.. . n_,. l -4 .c ~ 108 .m r.. , 4;. e + Q Has anyone elsw other than Gillen and Kane frem your ~ section worked on the review of the Midland soils problem since its inception? s A The date I gave you on the last question, if I may 3j correct it, it would have had to have been in early 1979. No other person was available to work on this task during the interim period. aa Q Your statement is that Mr. Gillen transferred in the t E early part of 19797 A Yes, sir. d Q And that Mr. Kane came on board in the early part of I 19807 I A That is correct. I Q 5etween those two times, there was no other person 5s assigned to the project other than yourself? sn g A No other person than myself was available for any assignment. j 2* O I would like you to take a look at a document which k I will mark as consumers Power company's Exhibit No. 5 - Neller Deposition, dated 10/9/90. (The above-mentioned document was marked Consumers Power l i t \\ ALCEMSCN REPCRTING COMP ANY. INC.

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..~g , _,;c...a v ~. - .n.... Company's Exhibit No. 5 - Heller Deposition for identification.) 3Y MR. BRUNNER: I l Q I am looking at a document which is a letter to.t. i .-i I j J. W. Cook, vice president, from A. Schwencer, dated August 4, 3, 1980. The subject is Corps of Engineers report and request for E additional information on the plant fill. The letter is two l eages long with an attached ec. list consisting of four pages and .a another attach =ent styled enclosure one, entitled " Department of 1:z j the Army, Detroit District, Corps of Engineers, Box 1027, is Detroit,.$tichigan," which consists of 16 pages, i! Enclosure one contains some crossouts and some renum- ~= 3 bering of paragraphs. It appears to be handwritten text. On 3 i-E page 2 there is a "39" of handwritten text; page 3 there is a

4 "40" of handwritten text.

Before that there is a paragraph i l n 1 crossed out, and on page 5 there is a."41" handwritten text and

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some interlineations written in handwriting. a h on page 6 there is a "42" in handwriting and a circled s2 section, some cross-cuts, and an arrow pointing from one paragraph to another, and various other interlineations and crosso 1 I! outs in the rest of the enclosure. Would you take a look at this enclosure and tell me 6 t 1 I \\ ALDERSCN REPCRTING COMPANY,INC. ~

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... n.. m c. m. l r etw :c < :. a ..,.m. r whether or not you are familiar with it. =mme (Counsel handing doc =nent to witness) (Witness reviewing document) A Yes, I have read this letter. i Who :nada the cross-cuts and put in the numbers in the n 3 Q left margin, if you know? A, 3 A I believe Mr. Darrell Hood performed that task. n .4 5 Q Do you know whether _ or not that particular letter and I E enclosure was sent to Consumers Power Company? _z i A I do not have personal knowledge that it was sent to <3

i Consumers Power Company.

Darrell could confi:m that, if you would 2-3 ask him. E Q You have no reason to doubt that it was at this + d'e? NC 5 A I have no reason to doubt it, but I don't have any 2 3 personal knowledge. 3 Q Now, what was the purpose of sending that enclosure -- a

4 j

letter to consumers Power company, according to your understanding l 4 j G A The purpose of this letter was to first clarify the j I 1 .4 deWis of the borings that were being requested as a supplement to a letter to Mr. Cook dated June 30i 1980. The purpose of the entire text of the Corps of

Engineer letter is to inform Consumers Power of the questions and i

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5 _ M W-;x +-p r,ss...a:=-.sze... g .111 ,,eu, v u c.,.m.,...~ _. p- ...-..p--...,-m,,...,,,.,.m..,..s.,,__,.. N. W c.Y =:.. N - - _;:( --- ~;. 3.. { e, i t issues that would need to be resolved and answered to continue 8 I,l the operating license review for this particular plant. I 1 Q The questions renumbered by Darrell Hood contained in I ' enclosure one were those questions, as far as you know, authored s 3 j by the Corps of Engineers? ~, A, A Yes. The entire letter was authored by the Corps of s j Engineers. The deletions, the numbering were provided by J Mr. Kane and concurred in via telephone with the Corps I j E { reerssentatives responsible for the letter. ? i Q Is the Corps of Engineers providing assistance, <a -i consulting ass.isr.ance to an? particular section of the NRC, other z _= s than your section, in connection with this Midland soils problem? E E l A In connection only with the Midland soils problem? a t: 5 Q That is right. 2 A I believe they have been requested to provide some 3 m p updated ficoding data for the use of our staff. I believe it was a E i

  • Midland, but I could be mistaken on that.

To my knowledge, there i E is no Corps personnel presently working on other aspects of the az I review for the soils issue itself. i { Q You' testified earlier, I believe, that your review s .I; authority or the review authority within your section does not I;. include an analysis of the effects of particular loadings due to 4 I. ' N ALCEMSCN REPCRTING COMPANY. INC.

f@ ' ,.2.- i g*y.{- J[*. 41 MiE-rq .,_,,.,,. x c...M., .j {'-{.{.{ 3.-. [.,,.yQ-C- .e.>& . n..~x_:. t ..r '- 112 .% % e..,u. 3,,_.,.- f l soils or other sources on structures. If that is the case, do you believe that it wculd be i i , proper for your section to submit questions to an applicant,such as consumers Power Company,which requests analyses of the ,5 ..n 3 effects of such leads on structures? K The enclosure to the letter to Mr. Cook is coordinated A _nj by the project manager with other review personnel who have respcasibilities for other factions of the review. And it is I j my understanding that those persons responsible for areas of Ej review, interfaces, or affected areas of review fully concurred n y in the questions being previded to Consumers Power. So the letter itself is not a total reflection of the ~ A review responsibilities of our particular section. It has been coordinated with those other parts of the review with persons ~ 1-involved in the review of this plant. Ema y Q It is your testimony that this particular letter has a been reviewed by those persons who are responsible for analy=ing 3g j i 5 structures? E ?. A They,are aware and it is my understanding _they do concur in the need to ask the question or raise the issue, as the case may be, in that letter. J i Q co you know who these persons who have concurred are? l i ? 6 '\\ l i ALCERSON REPORTING COMPANY. INC. ~~ l 3

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yw&-+.rs=q'QQ:hk. as.J..,,?5 2Q.: ??fWQ[Q_a -,..3; ~.: - ~r '_Y zh & Q' l Wg%f& Q ~ J m : ? :y w e m k..r,- m-,w- . w._ g .n.,___,,_._,._,. t J 39 c... :. ; ..,,..--..s..,..- - n,w.a ,~. .u.,,--. ~. -.. lA f y;,,:.,r e.n w* ~~ .;c . =. ..,.~y i ;; I A If I may, I would prefer to defer that cuestion to ~ Mr. Kane who was personally involved with that and could give i ! you firschand testimony. Q Your answer is no, you don't know who those N 4, 7 persons were? 7 h A A-I could give you a guess, but you would be -- have 4 i better information from Mr. Kane. n es c Q Is Mr. Kane the person who told you that these other ~ i k people had concurred with the questions that were submitted? E_ i 5 A Mr. Kane and Mr. Hood. m d Q Are you familiar with the December 6, 1979 order = 1 3 issued by the NRC concerning the' Midland site? ^= A Yes, sir. ^ You testified earlier that with regard to this Q 2 J z enclosure that has been submitted by the NRC containing what you N stated were issues that would have to be resolved by the staff e

s al in conducting an operating license review of the Midland soils

, j ~ s 1 problem, is it your understanding that all the questions in this ~ 2 a enclosure would have to be answered to provide the acceptance criteria which is referred to in the Dacomber 6, 1979 order s )modifyingConsumersPowerCompany'sconstructionpermit? I A Yes. It has been my experience, not necessarily en 3 i 4 ) \\ 1 is e ALCERSON REPORTING COMPANY. INC.. j i 1 ~

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  • l A

So it is - 4 ~ t I think my question was directed to the fact that the nj Q N December 6 order mcdifies Consumers Power Company's construction I 5, permit, and the way you have categorized the need for answers z_ i to the question in the enclosure was that they were needed to <3 conducu as cperating license level review. -f s 2, So my question is: in your opinion, as a reviewer, = ~s is it necessary for consumers to answer all questions in this ia* 1 ) ) enclosure in order to meet the acceptance criteria in the order 2 which relates to construction permit level review? 3 is e A Thank you for explaining that. My opinion woud be no, a a w] j it would not be necessary to answer all of those questions to l ~ s i establish basic criteria for the remedial actions necessary at f ia Midland. 1 Is there any way that Consumers ?cwer Company can Q l tell which questions would have to be answered and which ones would not have to.be answered in order to provide the basic i ) i a ~ ALDERSCN REPCRTING COMP ANY. INC. 1

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g a:. ~ &- . ~., :. -~N;n.. q .y..e,;.. g,; criteria? A I would not be able to distinguish at this point, and } I do not believe that the reviewers had that distinguishing requirement in the order of or the requirements for answers-- I e E j !. don't believe that distinction was made. I n 3 Q With regard to the preload program at the diesel nj generator building, do you believe that direct field tests, such L t as what the preload may be termed, provide a more accurate E indication of future settlement than would laboratory samples and i -l analyses done on laboratory samples? 3 i A Yes, thev will c'rovide a more accurate measurement of z= past settlement. Ej Q Would it provide a more accurate prediction for future settlement? 2 A Yes, it could provide a more accurate estimate of 3 m future settlement. a 1 a 2g Q I believe my question was: would it in *5's case 1 e.rovide a more accurate crediction of future settlement than would =. analyses done on laboratory samples?. A Yes, 'it would provide a more accurate assessment of future settlement. i Q on cage 4 of Exhibit No. 3, which is the discussion of

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~ l.-m. Q& ;C.~h-6~1.'3_: -3Q~~=;- Q. '-z:;. *jQ.. -%"s .'s .. t:, ..-~,.=<k' 116 r 3 applicant's position on need for addi:lonal horings, what is the t i second full paragraph from the top, there is a description by the i I author of the errors incident to measuring settlement using ~ g laboratory samples and using direct field data. H j j Could you read that paragraph and tell me if you R R disagree with anything in it? n i (Counsel handing document to witness) n J = Starting with the words, "The technique of extrapolat-i E ing." i. I A "The technique of extrapolating from full scale test B f results is the most reliable method for predicting settlement. 2= j Nermally at the star of a job sarpling and testing are utill:ed = E to predict settlements. In this particular situation the a tj surcharge program provided the opportunity for direct measurements a= and thereby eliminates the need for sampling and testing." ma I Should I c.o on? ,,W=g Q You can either read it to yourself or read it out loud. / = { (Witness reviewing dccument)

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A Okay. j .lj' Q Do you disagree with any portion of that paragraph? I I A Yes, I do. Q What portion do you disagree with and in what respect 6; s ALCERSON REPCRTING CdMPANY. INC.

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- n - i.y .,w,~- 9 + - t l do you disagree with it? 1 i. A The c. art I disagree with is in the second sentence: i "Normally at the start of a job sampling and testing are s utill:ed to predict settlements." n I In this case we have no sampling, and we have no a E i 2, testing, and we have no parallel understanding of the materials K i tihat are involved in the consolidation process and in the n J l resulting settlement. 3l 5 So when you simply lump together the statement that, i_ i "Normally at the start of a job sampling and testing are <a i utilized to predict settlements," we are dealing here with a z= j reasonable understanding of the constituents and the conditions E E that are present in a soil material. a In this case we do not have that parallel bcdy of a = information and data from which to judge the sensibility of the 3ay results that are being obtained from the measurements. Now, I Ja do agree with all of the sensitivity and accuracf statements E that are made with respect to comparing laboratory measurements 3 l 4 4 e i i directly with field measurements of settlement. 1 l The missing link here and the important missing link l I is the understanding of the soils themselves. And that is why I 4 1 1 1; have to say that the phrase, "Normally at the start of a job," I t 4 4 i ALCERSON MEPCRTING COMPANY. INC. L

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j[Qf.L. a -- 7 .1xg,., 11g , :. w:.... m m.,.-,.. ::sww.a. -:. u..... _..a,.. ..a s 'g'.g> s ..e.- ...m._..-%_. ,. m. ..q. ~.. ;.. ph. t _._. - gm.. - -.. _ is not realized in this particular case. ~ In your opinion as a reviewer, is it necessary for Q consumers Power Company to meet the original -- its original PSAR ccamitments with regard to soil compaction for the staff to R make a finding that the proposed remedial action provides l f adequate assurance to the health and safety of the public? i 1 A No. M At a meeting that was recently held at the Midland Q site, I believe you made the' statement that the staff was burned t- 'E i twice -- quote, " burned twice," unquote - at the North Anna proceeding by using field data rather than laboratory samples. 3 a E E I may have misquoted you slightly. If I have, you can correct my quotation and then explain what you meant by it. m i May I have a minute to leaf through the same things { A a I have given you to try to clarify my last answer before we = Rz centinue with this one? eaa f Q Yes. 2 I think it is an important sort of clerical oversight. = s A (Pause) I had provided to you a number of papers similar to i this one, and -- 1 Q 3efore you continue, would you identify for the record iI I i s t \\ 1 ALCERSON REPORTING COMPANY. INC.

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a your last cuestion as to whether it was necessary to obtain the a j original PSAR compaction of the fill beneath the diesel generator a building as a requirement for support of that building. = 3 t The document I gave you a mcment ago is dated December a i: a M 1978. And our notes that I made at the presentatica and at.the f ~ = first knowledge that I gained firsthand of the settlement 1 1 M I' situation at Midland, on page 4 I have in my notes something different than is recorded in the NRC meeting notes. The statement I wish to make at the conclusion of that- ?, meeting is that NRC has no choice but to.use PSAR criteria in = I i i N F I l i ALCERSON REPCRTING CCMPANY. INC. ~_

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.y :.;. . T- - i evaluating the FSAR in terms of commitments. realized. ~ 4 1 And I would like to state that the meaning of this 2 1 was not that the fill had to be exactly as was determined in th N -e 0.L PSAR, but that the support for that b.uilding would need to meet '.[ g

i d.4 the same rigid standards as were anticipated at the PSAR stage.

41, ~;j 3 Q Could you make that same statement with regard to et ..4 n T. ' I class 1 structures at the Midland site? n 4, .4 A I could make that statement. I am not the reviewer, ~ .$i i a h g I could make that statement, yes. 4 3 w a a Q' Well, with regard to the soils problems, if any, whi 3 have been unidentified.in areas other than the diesel generator-J w building at the Midland site, would it be necessary for Consume <wJ = =. ...-,d E Power company to meet all of the original PSAR requirements wit i a e a s; regard to those soils in order to satisfy the staff that an a . 3, 5 z adequate degree of insurance to the public health and safety ha . tj . i: Ei + >4 a .a.. g been realized? d 9:n i A It is my opinion that it is not necessary to demonst 1A that the same criteria were adhered to. It is, I think, essent -i t. s f -c to demonstrate the same degree of reliability, the same risk c: . 4 .n adverse circumstances are obtained with whatever fix is propose m and completely implemented and checked out. -4 }. ,t l, Q Do you recall the question I asked about North Anna' 'J . n s .. } .i -v k i N.,J h 1 96.1 i ALDERSON REPORTING COMPANY. INC. *. 9 e 3 g e 1 m w ge,y-w ."--tw wT w -wT

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,:....~-- 6. ;Q,, ~ '. 3., ~,.;%.;..% J c . w.. ; I e- ' sw.:c,.,.; ; g; 4 e 1 i' A Yes, I do. ~ 1 l Q Can you answer that question? A I was afraid you would ask. Yes, I will. North Anna ~ was a situation almost the reciprocal of Midland. The tests that i 5 !theyhaddonefortheservicewaterpumphousewereconsolidation o a m

  • tests from a sampling operation in this case in a sapprolite E

,I I h that prebably is no more variable in compression characteristics j than the constituents of the fill at Midland. t And their PSAR predicted a reasonable degree of j:. j settlement, scmething less than one inch. They built the <a se:cture, and it began to settle. And it settled up to the i predicted lim 4 t, and the appropriate amendments were submitted E and reviewed and little concern was given to that. 2 .E Measurement menuments were placed all around the' 3: 5 structure to continue to monitor settlement, and although the ia settlement had stoppad, according to the monuments, there was a M. 5 =eriod of time over which the settlements began to increase for a k no apparent reason, with no apparent increase in load, and no s l l directly observable cause. = -That happened once and a prediction of settlement was made based on the settlement records over a period of ~*me and

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n. A.w-... ~~m.. 3_ c - = ~. _ ~ gw W .4 A couple of years later the structure began to settA I I. l' more rapidly, and at this point seme mechanical modifications ci' l . M.h. M. ! were made to accommodate this settlement. The magnitude of th .+2; acccmmedation was in the neighborhcod of three inches of addit $ 3 3 g g i m-s ! settlement. 4 >q n g A technical specification was written with a reasona .dj A cff I warning pericd, as this structure could possibly approach the .4 ".a .s The fj E new limits for the new accommodation of that settlement. j 5 structure again began to settle and approached the limiti: ~. uj i i value established in the technical specifications by the appli: 4 a And it was necessarf to re-evaluate the entire system. i dz -SA I f -:i so my comment, elaboration on my comment is not so 3 ] i that laboratory tests are more reliable than the field direct 4 a ~; j j measurements, but that a complete understanding of the materia c a characteristics and the factors affecting the settlement need rl 3 be obtained and understood before either approach to settlemen s _ c.j

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. c.j g 4 credictions is trea.ed with a sericus vein -- treated in a t . 'c: r- +. i mZ s a serious vein. I l Y = d Q You, mentioned the word "sapprolites" in referring i 3 .2 .-::t the fill at North Anna. Are there any differences between

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perhaps completely explained point. a. n y Q Oc you have an epinion as to whether or not more is known about the properties of the fill material used at Midland i i* than is known about sapprolites? .a a 5 A No, I do not have an opinion on that. a I Q Do you have an opinion as to whether or not the E cooling pond dike at the Midland plant or a portion thereof -is a safety related structure as defined by NRC reg guides or other-t applicable guidances on the subject of safety related s m etures? A Some portions of the dike are important to safety, and ~ i h l t ALDERSON REPORi1NG CbMPANY'. INC. ~,,,.

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J.* i leM b ' 6,.. t af e-., m my,.,,, ,'G:+. ,,t:.: ~ r. . _, y, p.r,m . ~,... g, . =.a..n. n - some portions of the dike are less important to the safety of f that plant. MR. BRUNNER: I am going to hand you a document which 6 - Beller I am marking as Consumers Power Company's Exhibit No. 2 g j Deposition, 10.9/80. R (The above-mentioned document j. was marked Consume:s Power n 2^ r Company's Exhibit No. 6 - Heller U Deposition for identification.) 4 z_ 3 BY MR. BRUNNER: <a p Q This is a document which appears to be a map or a t E I s top view of portions of the Midland cooling pond dike. Have you j seen any drawings of the Midland cooling pond dike in the past? 2 A Yes, I have seen cross-sections. Does that drawing co= port with your memory of the = Q 3 way the cooling pond dike is set up,.at least in the sections a .:aa= e that are shown there? A Ch, it looks similar to the other drawings I have seer = Q Now, you just testified that in your opinion a portior n i I of the dike is important to safety or more i=portant to safety i I, than other portions of the di'<e. i Is it your testi=eny, then, that the entire di'<a is a t 1 1 .N s 1 ALCERSON REPCFiTING COMPANY,INC. i

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~. f~= g 4,h = - ^==c. I'? ' ,, _,., :R.. _ h-l, '. * * '.. -[ e 125 iw c ,;c ,,,y.. ~'- 4 r safety related structure as d.efined by NRC in guidances on the subject of what structures are safety related? A Well, the portion of the dike that is adjacent to the service water pond is without doubt a seismic category one, q safety related structure. Those portions of the dike at a great a f distance frem the excavated pond could reasenbly be assumed as 1 unable to affect the ability of that pond to hold and supply 5 I water for the safe shutdown of the two nuclear units. .a f Q Why do you believe sections of this dike that are tz 5 imediately adjacent to the pond are, in your words, undoubtedly n*.3 safety related? a ~z i l 3 A Secause their failure would lead to the inability of l 3 supplying water for the 1:mnediate needs, after the berated water G is used, of course, immediate needs for water to cool that plant.l 4 1 1 a The design of the submerged pond, as it is called, recM es a f 8 m l ?. circulation of water wi~hin this particular pool. 5a (I.,dicating) 2 o a 4 =g j And disruption of this line or the redundant line on a 1 2 the other side would not allow sufficient cooling of this trapped water to fulfill the cooling. function. j Q For the record, when you refer to **Ms line," I beliaq l. l you pointed to what looks like a black line. i ?. 4, i . ALDERSCN RE?CRTING COMPANY. INC. ~

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,i A Yes. I The back section is a section which is a section R. Q furthest down on this drawing, down and to the right on this n e ia ~ t drawing. 5 A Farthest frem the pump house, yes. ~z 5 1 a l <s a Q Fine. It is your testimony, then, that a failure E of the dike in areas adjacent to these pipes -- 3 A Areas adjacent to those pipes could disrupt and 2 i= j break these pipes, disrupt the flow in these pipes. And it would G2 cause a safety problem for the plant. Ei e Q Is there any other reason why a failure of the dikes w u I

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.C safety problem? a a s A Well, their failure would reduce the volume of water available in the cooling pond itself and therefore wculd 'a result in an insufficient supply as calculated to be necessary i I I for cooling the plant. ~ l h 8 8 i. l ~ l ALDERSON REPCRTING COMPANY. INC. e t

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..- Q*~74 Q. ~ K - '..w.,~. gl,.7-i Q _ ,..m .-. :.v.r; .a. m. e 127 1. . % Y-. r-l Q If you assume that the amer ;ency ecoling pond provideQ ~ enough water for an ultimate heat sink, as that term is used in 6 i i: NRC practice, an ultimate heat sink being the amount of water 2 necessary to maintain a safe shutdown condition of the plant, s t, -H does that change your answer to the previous cuestion? i i E A No, i~. does not change my answer because I couched 4 ,I. the answer in terms ot' the degree of safety and not in terms of ~n I the essentiality of the dikes that appears necessary in those E. E areas adjacent to the submerged pond. E_ i Q Would you rastrict your answer to just a determinatios iq s as to whether or not a failure of the dike in a particular mode .i g Q 3 would make it into a safety related structure as used, as that ~ ~, 4 i ter= is used in NRC guidance on the subject? .i H.- ~ j j If you restricted your answer to that consideration, a 2 3 than is there any reason, other than possible rupture of the 3 3 tee pipes you have referred to, why the dike and the area

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A[, j adjacent to the pump house could be considered safety related? ') s A Do you mean are there other reasons? n Q Are there other reasons why you would consider this I dike to be safety related, other than the possibility that.it ma) e 3 adversely impact en one of the two pipes that you mentioned? 1 4 i O,i i A Those are the major reasons. There are of course 1 4 .i} i i-m. v. 'N ALDERSCN RE?CRTING COMPANY. INC.

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g W supplementary concerns,such as the failure of the dike in this ~ I area could possibly block the intake; the failure, in a certain manner - I am not sure what the materials are, but they could be commesed of fine sands and silts -- would definitely provide 4 s n [ j 1, a large degree of turbidity for the water. t I And this turbid water or mud, as it would be called, n E,. n would then be pumped into and circulated into the emergency in 5 cooling system. So there is that aspect. One could go on, but il it seems those reasons are enough to classify the dikes in this 15 i area as being necessary for the safe shutdown of the plant, safe <a d and reliable shu:down of the plant. Z. 3 Q Is it your understanding that this dike area has not = 5 been Q-listed? O J A I have not examined the Q-list. I believe that those .I discharge lines were not shown on the FSAR. I believe that those = 3 4 lines are now shown only as a result of our ques-J.oning and I a i .:a't j assume that the Q-lisH "g of this portion of the plant is simply s an oversight at the 75AR stage, since they were not so identified a = earlier. Perhaps another reason they were not Q-listed is that i these dikes were authorized to be constructed under an TWA. And perhaps they just never got on the list of items to be controlled-i l

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z . < p..u -;njlu - sen-R-v_. 2._,, -..,..,.r t Nw c. 3 u.. ..,....-r*"- 129 t 1 i l Q When you use the ta==t " oversight," are you referring I to an oversight by Consumers or an oversight by the NRC? A Possibly both; we are talking about a period of time, g . 10 or 12 years ago. 4 H j i, Q De v.ou know when the NRC receivec information that 3 E., the two.pic.es vou referred to were going to be built at their I present locations? n

  • s e

A No, I do not know that date. i E Q In your answer to the previous question or the question i_ i right before that, you left me with the feeling that you still <m

i had not stated all the reasons why you think that the dike might 3=

he safety related. Are there any other reasons? I would like to .= s i know all of them right now.

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A Those are all that come to mind at the present time. 3= These are the only postulations that I can see. Others that 3 4

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j resolved. 0 i O When you state "other concerns," you mean concerns a i M a 3 other than soils concerns? A Yes,' sir. i 1 Q In your opinion as a soils engineer, if the fill !i material which had been used by consumers Power -- stri*<e that. 4 e l I '\\ e ALCERSON REPCRT1'NG CC'MPANY.'INC.

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.c-.,-,r.,.--..uw,.. 3. . n, v. u., p% = .~c-.- ~ w... g_. w. , x g_ g In your opinion as a soils engineer, if the fill Il material which actually was used by Consumers Power Ccmpany under-the diesel generater building had been adecuately ecmpacted at the time it was installed er cut into place, would the unusual 4_ settlement problems which have developed and which have been a i 5 dccumented by Consumers have occurred? 3 A I do not think it would have, no, considering all of Xnj the controls that would have been necessary to meet the original i E specifications. tz 5 I would say, no, the likelihood is very small. = Q When you state'"criginal specifications," you are i ,3 ' referring to the specifications in the PSAR? _,= A Yes, sir. aW -= Q Which group within the NRC or rather which section has 2:W8 the lead responsibility with regard to the proposed dewatering si 'd } system at the Midland site? r

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I think our hydrologic section probably is spending mo( a i:: of their time on that aspect of it. e 3 A Q Youstatedearlierthatyourgrouphassemeresponsibij fer considering the dewatering system. A Yes, sir. l Q And I believe one of the particular areas of conce.~ t(- 1 I E \\ l 3 4 ~ j ALCERSON REPCRTING CCMPANY,INC.

.r... ~,.. f ;.7,y_-i.;b ;. x-;3-O- ~.c ...%~,-h.;f' Q q y 3_. Q.. ?. ~;_.' :}-. R_M5 e.. rs .. ar,. e, 133 r t Ii your group was soil per=eability. Is that a correct statement? A I think for this particular review our concern would be for the filters for the packing for the dewatering wells and 'l I installation of the pe:manent piezemeters, for example. We 3 y p probably would not be concerned about the ti:ne for drawdown, the 4 M ?, rate of recharge under accident conditions. The hydrologic E reviewers appear to be sufficiently informed to take care of that M .a I i matter. i on a generic basis we would review the soil permeabiliti. I i say, at another plant just to be sure that the values assumed <m are consistent with the nature of the soils, identification of the a E= 3 soils. g Q co you have an opinion as to whether the proposed a + 3 dewatering system can if properly designed provide an adequa' e 2* solution to the potential problem of liquefaction at the Midland ia e site? 'aa E A It should handle the liquefaction problem. a i: Q Have you held this opinion all along, er have you 9 .i .4 t changed your opinion on this subject recently? (Pause) I j A I think I h' ave held the opinion that the dewatering i l system would handle the liquefaction problem if it is properly i 1 i ALCERSON REPCRTING COMPANY. INC.

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g~ . :13 2. %..:i. :;. . v.. - n. ~,,...,m ..-v.....a..~,,. .~.-~. ,y l ~. y ~ Qp;, . ~..n...- y _ .. c:.. w. a... designed, and so forth. I Q Are there any particular prcblems that you are aware l. t of associated with designing a dewatering system for the tiidland i 1 g j plant? n t j l A There are always a number of precautions that have .~.~ J to be taken for a dewatering system, either permanent er I 4m sure .,j temporary, but par.icularly for a permanent system. that the designers are capable of taking those precautions. ~n I E Q Have you reviewed Consumers Power Company's submission ~ z_ il concerning shear wave velocity measurements at the Midland site? <3 d A No, sir, I have not. z 3 Q I take it, then, you have not reviewed data from cross-hole tests either? j -} A I have not reviewed that data. 2= Q Is that something your section would have respcnsibilit 4 a 2 e to review? w

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3 A Yes. A Q To your knowledge, that review is being undertaken by r E M your section? 1 A Yes. J Q Is that a subject which has been referred to yCur i l consultants? O I t I S 1; ALCEMSCN REPCRTING COMPANY,INC. 3

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_,z .%;.y=.n7.m A.m?"50- , v l ;m. L h.~ h:.;C. :h-T; p - _- Q,.Q...g....- 3.g.j~Q.y i J- -% ~ Y:- N '-~ ,/s, .,,.,-.t' r-A I assume that it has. I do not have' personal kncwledge ~ that it has, but I am confident that it is supposed to be. I i Q Who has responsibility for seeing that that review j 1 is done? .i A Mr. Kane. Mr. Kane is overseeing the Corps' review A for this plant. Q Do you hava any idea when your section will be done E with its review to the extent that -- strike that question. co you have any idea when your section will have done 4 sufficient review to submit -- to support a staff SIR on the <3 g Midland soils fix? z i = 3 A I will have to again give a schedule kind of answer j 1 rather than a direct date answer. In general, we can review a h wtiatever is submitted and come to a collegial conclusion in about h= three months, in terms of an SIR from the technical people to si= e the licensing group. aa The date of ecmpletion of course is dependent upon the ,.s informatien that is submitted, the sufficionef of the information, f M the reliability of the proposed fixes, let's say,.and a number of other factors. 1 An SIR of course can be written positively or I f1 nega-J.vely, depending upon the demands that our licensing people i 1 i e i t 9 ALCERSCN REPORTING COMPANY. INC.

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.,. s,_e .. g -w r........ n. f ~ p.er-:-.c= :a v..~-- - is- .. ~. '- 9 g,,;w J make upon us. We can write an SER at any point'in time. ~ Q I would like you to refer to Exhibit No. 3. There is a figure there which is titled figure number two. In parentheses i e it says asee reference one.* My understanding of this figure is E i j that it purports to shew the loading placed on he plant fill n A

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j the history of that particular plant fill. .i Are you familiar with that diagram? n 3 A I have -- it is the same diagram that Professor Peck E i used, I believe, at the presentation. I am familiar with it, n -i ves. = j Q Iceking at the varicus loading facters shown in that E g diagram, do you have an opinica as to whether consumers ?cwer company used adequate weight in its prelcad program, assuming tha: 3 the data there is actually correct? 3a A The question you have asked is a very complex questien, a:sl and it needs to be answered at least in two steps. The first step 5 is: has enough load been applied to sufficiently reduce the g potential for future settlement? I think in that case one would have to say that the usual procedure is to surcharge to a somewhat; higher level than has been obtained here, particularly for those soils at descer depths. i I e i L [ ALCERSCN RE.*CRTING COMPANY. INC.

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.)f g w . d;-::.;w5,. . >' g;y,:>j.H. Jm*~&~' I ""F ~ - N % -c . 2, a ..,--.. e 135 r~ 4 As to whether the surcharge has improved the shear i 1 lstrengthcharacteristicsofthesoilbeneaththefooting,oneneeds I to examine what effect that areal load had on consolidating and i improving the shear strength and whether or not the soils that t l 3 lwouldreceivetheshearingstressesbythefoot.3.ngshasbeen i 2 6 E sufficiently consolidated such that the shear strength along those a a 5 shear potentials is realized. e I am not really prepared to answer that question. I 4 l n Y suspect there has been some improvement, but I suspect that it i i-! has not been 1.arge. E<B Q You are referring -- you are referring to improvement -o 5 3 A of bearing capacity. 1 E ~ j Q Just with regard to settlement,- do you believe the lead 5 g' that vs.s applied in the preload program is adequate to meet the 4 \\ j design purposes of Consumers Power Company csing preload?

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N w A I honestly do not know. It is en the sher side of a 1 G j usual practice. 4 G E Q What are you hasing your opinion as to usual practice s on? I I 4 A Well, it is common to surcharge to roughly twice the i carry load and in certain cases down to one and a half times the 3 imposed loadings. Here we are approaching perhaps on the low sidO 4 e i N I ALCERSCN RE;8CRTING COMPANY. INC.

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r v.w. ~- tr~ -... y ._-.w-r. -.46aE=._.,. ,.y s'- .. :,.. s .., p r,.. y... m. W -. u...,,,. 4.,. r-ir ; '- 136-( ) - w _e.. -. ,.s.. ,,_....mm., .s,,.,. ,,. ~...... ~..... _ (2k. 2 Ex.t.... = .} *.,,. "~-- *a. of that ratio. Q You say it is ecmmonly done. Is that based on your experience? A No, it is not. It is based on the literature and 9 3 reports of other people's experiences with surcharging operations. A. Q You testified earlier that surcharges are often used E to ecmpact organic soils or soils with organic material in them, re d Is the statement you made with regard to the multiple of the t 5 seeh-Idad that is.used in the surcharge, the multiple of the 3 i.e lead which is actually seen by the soil in normal operation, is a thatapplicabletocasesw5terepreloadsareusedfernonorganic a E= 3 fill material? 3 g A I would think it would be. I think it has been applied -l for nonorganics as well as organics. Ia Q If you neglected the effect of dewatering, would the aa g lead be adequate according to the criteria you used to answer the .d.j previous questions? E In other words, if you neglected the original load M caused by dewatering, which I believe is one of the loads that is noted in the diagram, in that situation would the load that {wasappliedbeadequateaccordingtothecriteriayouused I i 1 earlier? l 1 \\ ALCEMSCN REPORTING COMPANY. INC.

y n ; p = s & - S C - % ~' ~ w. N W : i ~Y S = i O h E.'i:^2:1 -:- & Q.;.: =; ;.~~,;*-N W i ,,[ e:cs =.,n.. . u,.,.;; - e k ~ ~ ' 137 r ~ A Well, the fill was not.dewatered at.the cime the i preload was applied to this area. So we are interested in the i i maximum load applied, rather than, you know, what one could I hypothesize. Perhaps I am missing the point of your question. 4. 2 Would you oika to repeat it or rephrase it? i R 'I Q Are you familiar with any ACRS review of soils concerns-R 1 s A Yes, I am. M Q Could you tell me why the ACRS has gotten interested in Y 5 reviewing soils? El A No, I could only speculate, and I prefer not to. <3 a Q Have you briefed any members of the ACRS staff with i= 3 regard to the Midland soils problem?

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n A Yes, I have. 2:-* Q What persons did you brief. E* A I briefed a consultant to the ACRS. His name is as a .a Professor Osterberg.

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a MR. BRUNNER: I have a couple more areas of questions 4 i:: I wanted to go into, but we have to take off. Do you have any n objections to - I do not think we will' probably.want to further L depose Mr. Heller. But we may want to. Do you have any objections to adjourning this sine die? MR. JCNES: No objection 0 4 4 e t ALCEMSCN RE.*CRTING COMPANY. INC.

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. > ~ :vz- =.. :-. .--.-~-,-r.w. - ~e ..u,n,...... m.M krz. ~:: ~ ~. =~..a . e, w. v... : n e g ~ MR. BRUNNER: Okay. I. thi-Oc that way we can all leave in a timely fashion. We've finally had enough. So, I thank you for your cooperation. THE WITNISS: Thank you. H 3 MR. JCNES: Do you want to give =e the exhibits and 4 -T A,. I will get them copied. n i MR. BRUNNER: All right. The understanding is that n t I am going to leave the exhibits to this deposition here, and Y E. fir. Jcnes has agreed to copy those and send the copies to ne. _z i MR. JCNES: I'll send the originals back to you. m .i MR. BRUNNER: Ye's. You are going to send the originals z= 3 back to me. Fine. i .= g so the deposition is then adjourned sine die. Nc 5 (Thereupon, at 5:55 p.m., the deposition in the 2 =. above-entitled matter was adjourned, sine dia.) .a m ld

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~" s ., s:~ . v a. .w.- - s -.. g r CERTI?!CATE OF REPORTER CNITED STATES OF AMERICA ) ) Docket Nos. 50-329-CL NCC'IAR REGULATORY CCPMISSION ) 50-330-CL 50-329 OM S 50-330-CM -r:* 3 I, DAVID S. PARKER, the officer before whom the R foregoing deposition was taken, do hereby certify that U A the witness whose testimony appears.in the foregoing d i deposition was duly sworn by =e; that the testimony of l 2 i ?- \\ C said witness was taken by =e by stenomask and thereafter z= j reduced to typewriting under my direction; that I am 3y. neither counsel for, related to, nor employed by any of = g the parties to the action in which this deposition was a E taken, and further that I am not a relative or employee 4 of any attorney or counsel employed by the parties E a,. thereto, nor financially or otherwise interested in the 3a i outcome of the action. d ? .m \\ = c v' ~ --4' #7 s s .== t'* g 1. .e I e* M g ;m pg._: :~ c*: t.'

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