ML20090A836

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Transcript of B Dhar 801217 Deposition in Ann Arbor,Mi. Pp 1-160
ML20090A836
Person / Time
Site: Midland
Issue date: 12/17/1980
From: Dhar B
BECHTEL GROUP, INC.
To:
Shared Package
ML17198A223 List: ... further results
References
CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101090356
Download: ML20090A836 (162)
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. n s :. - nw ~. kk .. ~. _ UNITED STAT.'.:. OF AMERI.CA T f f.,p. g,, i._ 1,y, $ - , ' v.* -Y NUCLEAR REGULATORY COMMISSION 2 Before the Atomic Safety and Licensing Board 3 - - - - - - - - - - - - - - - -x 4 In the Matter of: Docket Nos. 50-3290M&OL = 5 h CONSUMERS POWER COMPANY 50-3300M40L 3 6 g - - - - - - - - - - - - - - -.x 7 Conference Room, 7th Floor j 8 777 East Eisenhower Parkway ,3 Ann Arbor, Michigan d 9 i Wednesday, December 17, 1980 10 z= l M 11 l Deposition of <3 i 12 BIMALENDU DHAR g j 13 the deponent, called for examination by the staff of the 14 Nuclear Regulatory Commission, pursuant to notice, at 9:00 a.m., m 1:: 2 15 l when were present on behalf of the respective parties: i:! i i j 16 For the Nuclear Regulatorv Commission

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![ 17 WILLIAM D. PATON, Esq. a E 18 JOSEPH D. KANE, Geotechnical Engineer 1. = r h 19 ! FRANK RINALDI M 20 on behalf of Consumers Power Comeany l 21 ! ALAN S. FARNELL, Esq. I i 22 I JAMES BRUNNER, Esq. I Isham, Lincoln & Beale 23 ' One First Narional Plaza Chicago, Illinois 60603 l 25 e s i, 4 .i .) ALDERSON REPORTING COMPANY. INC.

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..T. ... v -. - ....,a. ' m % . ;,t -.. - ' ~ PROCEEDINGS 2 Whereupon, 3 BIMALENDU DHAR 1 4 was thereupon called as a witness herein, and after having been g 5 first duly sworn, was examined and testified as follows: R 6 EXAMINATION a C" 7 BY MR. PATON: n j 8 Q Will you state your full name and business address da 9 for the record? E 10 A My full name is Bimalendu Dhar. My business address 3 ) II is 777 East Eisenhower Parkway, Ann Arbor, Michigan. 3 SI I2 Q It is not Dr. Dhar; it is Mr. Dhar? 3 .2 5 13 A Yes, sir. = \\ m 1 5 I4 Q Mr. Dhar, I notice on the resume which I will mark h l } 15 i Staff Exhibit No. 1, under a heading called Organization and = d I0 Location, you have the letters SFPD?

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I7 l A That is the San Francisco Power Division. 2 E 18 (The document referred to was b I9 marked Staff Exhibit No. 1, i M 20 December 17, 1980, for identifica-II tion. ) l 22 BY MR. PATON: (Resuming) l 23 l Q You now work for the. San Francisco Power Division? l 24l1 A No, I work for the Ann Arbor Power Division. 25, Q Your resume is dated August of '79. As of that. time l .i d ALDERSON REPORTING COMPANY. INC.

i . n,- W.@k.,., ._Qf . %gg-2:5. ^- :W?.~ t-M ,.-... :x,. - 'E~F&l2h iT.2~h: I ~. ;"% 4 .:% % G. sa:v 1 it was the San Francisco Power Division? 2 A That is correct. 3 Q What is your job at Bechtel? 4 A Would you please clarify that question? e 5 MR. FARNELL: Do y'ou mean his position? Ma j 6 BY.MR. PATON: (Resuming) 57 7 Q What is your title at Bechtel? ~ 2 j 8 A I am an Engineering Supervisor. d:i 9 Q How many people do you supervise? z'o g 10 A In my present capacity, approximately -- under my 3j 11 direct supervision here in Ann Arbor, approximately 85 people a y 12 and 30 at the job site where I have technical resoonsibility. _33 13 0 You mean here at the Ann Arbor office that 85 people = 14 l

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== { 18 A Other intermediate supervisors who in turn report to c 19 me. M 20 Q Are you the head of some section? In other words, is 21, there a section that you are the head of? 22 A I am Group Supervisor, Civil Structural Group, for the -{ 23l Midland Project. 24 Q How much of your time do you spend on the Midland 25l Project? i, .l ALDERSON REPORTING COMPANY, INC.

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r-A I spend all of my time bn the Midland Woject. 2 Q How long has it been since you spent all of your time 3 on Midland? In other words, have you spent all your time on 4 Midland in the year 19807 = 5 A Yes, I have. h j 6 Q How about 1979? R CS 7 A Yes, I have. Ml 8 Q How about 19787 d* 9 A Yes. zo 10 g e777 3 5 II A Yes. 3 f I2 Q How many years have you spent full time on Midland? S 5 13 A From ' 76. w 5 I4 Q I stopped one short. That is unusual. That is why I b [ 15 I asked him by year. = g 16, 3 76 -- almost entire '76. I came back from vacation d .I. I7 ! in the middle of January to the best of my recollection. =w 18 Q Since January of '76 you have spent full time on I9 g Midland; is that correct? 20 A That is correct. 21 Q Now, you indicated that you are the Group Supervisor, 22 Civil Structural Group for Midland. Is there a Group Supervisor, 23 Civil Structural Group, for other nuclear facilities that 24 l Bechtel is working on in the Ann Arbor. office? l 25 ' A Yes. i .j I ALDERSON REPORTING COMPANY. INC.

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9,y g.,;;. h >--f & ' ~ c o-m - g c, v., c.- . c :;, e ~~' 1 Q What nuclear facility is that? i 2 A We are doing some work for Palisades, a'nd to the best 3 of my knowledge, we are also doing some work for Duane Arnold. 4 Q Tell me what your job is? In other words, what do you g 5 do as Group Supervisor of Civil structural Group, Midland? R+ 3 0 A That is currently? R 7 Q Right. ~ T. j 8 A I am responsible for analysis, design of all. structures, d E 9 Z. preparation of engineering drawings, specifications, and licensing h 10 documents for Midland for the Civil Structural Grouo. z II Q I want to make sure that I have that. Yot; are 3 y 12 responsible for analysis and design of structures;.is that 5 13 correct? .= a: E I4 A Analysis and design of structures. _c g 15 Q Engineering drawings-? = j 16 l A Engineering drawings. d ,,N I7 l Q And specifications? = ] 18' A Specifications. ~u 19 Q And licensing documents; is that correct? 20 A Yes, sir. 21 Q Do you know a Bechtel consultant by the name of 22 Dr. Davisson? 23 A Yes, I do. 24 Q With respect to the Midland site, has Bechtel retained 25 ) Dr. Davisson to do some work in Midland? i d I l ALDERSON REPORTING COMPANY,INC. e

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O What work has he been retained to do for Bechtel? 3 A As I know, he has been providing us input for the 4 design of piles for remedial actions for the service water pump e 5 structure. 3 6 Q Is he also providing input for the caissons in the = 'sE 7 electrical oenetration area? 8 8 a A My understanding is that he would review the caisson d d 9 j documents. o g 10 Q You say "that he would review." Do you know whether z E 'I g or not in fact he is doing any study of the caissons in the d 12 electrical penetration area? z -7 = 13 g j A I do-not have any direct knowledge of that. 3 E 14l' Q Who in Bechtel would know that? I 15 r g A Dr. Davisson is consultant to the Geotechnical Groun, y' 16 and I would refer you to Dr. Afifi. lI 17 g Q Now you indicated you don't have any direct knowledge, E 18 I want to ask you about direct, indirect, or any kind of knowledge? = 5" 19 l MR. FARNELL: As opposed to speculation, of course. 20, l BY MR. PATON: ( , Resuming) O As opposed to speculation as your attorney says.

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! to your knowledge, is Dr. Davisson doing with respect to i 23l'caissons in the electrical. penetration -area? 24ll. A May I talk with my ' counsel for a minute? 25 MR. PATON: Sure. I I ALDERSON REPORTING COMPANY. INC. -___-___-________2__-____

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~ >?'."i:::. - b.r.3 n~_. ~ ?:: -N' ~kL ~ ' f; (Deponent conferred with counsel.) 2 A The substance of what I have heard is that Dr. Davisson 3 is reviewing the carrying capacity of the ~ caissons. 4 Q Reviewing the carrying capacity; is that correct? 5 j A Load carrying capacity. Y E 0 Q If I said load bearing capacity, would you agree with ,n 8 7 that? Is that what he is doing? X A That is what I have heard. d 6 9 j Q As far as you know, that is the same thing? 10 g A Yes. = E 11 Q . Now, you say he is reviewing the carrying cacacity. g d 12 ' Is he reviewing work that was done by Bechtel, or is he sup~olying z q ~ 13 3, the initial input to that work? 5 34 A Would you please repeat the question? 2 9 15 g Q You say that he is reviewing the work. Is he reviewing 16 g somebody else's work, or is he supplying the initial work himsel'f? 6 17 I .a A He is reviewing somebody else's work. 18 Q Whose work'is he reviewing? E j 19 l A We had a consultant for caisson design by the name of 20 I ! Cht.ck Gould, and he ic reviewing his work. 21 Q Chuck Gould, G-o-u-1-d? I 22 l j A Yes, sir. 23 Q He is reviewing the work by Chuck Gould; is that i l 24 - I correct? i A That is my understanding; yes. t ALDERSON REPORTING COMPANY, INC. wpy + y w w r w-

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.N. ~~ :- . ~. I Q What work is it that Mr. Gould supplied that -- I guess 2 it. is Dr. Gould? 3 A No, to the best of my understanding it is Mr. Gould. 4 Q What work did Mr. Gould supply that Dr. Davisson is y 5 reviewing? 9 3' 6 A Mr. Gould supplied the input to the design of the R

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caisson supports for the auxiliary building wing area. 3 ] 8 Q Can you give me any particulars of that input? d U 9 A Will you be a little more specific about it? .zo 10 'j Q You said " input" to the design; what did you mean by = 5 II that? 3 y 12 A Ee supplied the basic scheme, and also supplied the = ~ = 13 8 details for the* caissons. = m I4, 'l 0 What do you mean by " basic scheme"? l 15 ~ .g A What kind of caissons to be used, and what would be the = si I0 l. approximate length, and what can be considered to be the load A C 17 i 'g

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= i ~ 18 I i 0 What was the approximate length? 19 g i A I do not remember the exact length, 1 a 20 l ~ l Q Do you remember the approximate length? 2I A No, I do no t. 22 I O Do you remember the load bearing capacity? 23 A What I recall is-13 caissons per 4000 kips. 24 i i Q You said 13 caissons? 'l 25), A Approximately, yes, sir. .4 i'i ALDERSON REPORTING COMPANY, INC. l ~

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-,*a 2 A Yes, sir. 3 Q Did anyone in Bechtel review the input supplied by 4 Mr. Gould other than Dr. Davisson? g 5 A This was coordinated with the Geotechnical Group'. R+g 6 Q Okay, my question was did anybody in Bechtel review ,n* 7 the work supplied by Mr. Gould? N 8 A What does " review" mean? d I d 9 ]. Q The same way that you have been using it. o b 10 g A Geotechnical Group reviewed it to the best of my II knowledge. 3 d 12 3 Q Who within the Geotechnical Group reviewed it? -? 13 ' E A This was done by Dr. Afifi's. group, and I do not. i 22 14 recall the name of the one engineer that came from the nj 15 Gaithersburg office to review. it. = j 16 j Q Do you have a report from Mr. Gould that came with his l C 17 ! 3 recommendations or his input? = l r 3 18 l A To the best of my recollection we have gotten written E I Ul ' summary of the presentations he made on the subject. i 9 t a j 20 - i Q Do you have a copy of that? i 21 ll A It would be available in the Civil files. I. i 22 l Q Are these your files, or are they Dr. Afifi's files? I 23 Are they under your supervision, or are they under his super-i 24 i vision? l 25 ' A Civil files would be under my supervision. ',i ALDERSON REPORTING COMPANY. INC. I

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l 1 Q What is the date of that? Is that a report? You said 2 a summary? 3 A A written summary. 4 Q Wha't is the approximate date of that? 5 A To the best of my recollection Dr. Gould made two 3 6 presentations to NRC, one in July of '79 and one during February n' b 7 '80. 2 I ~ Q Excuse me. You just said "Dr." d d 9 2. A Mr. Gould. 10 Q So tihe written summary would be sometime after 3 5 II February of '80; is that what you are indicating? m f II A Yes, sir. R g 13 MR. PATON: A1, could we get a copy of that? 1 l 14 MR. FARNELL: n I would like to note for the record that C 15 ' b j we have produced the Civil Group's files. j 16 (Discussion off the record.) at ( II f MR. PATON: Off the record there was an agreement that E 18 ' the summary that Mr. Dhar has referred to has been supplied to 1 19 g the NRC. 20l SY MR. PATON: (Resuming) II Q Mr. Dhar, other than the meeting summary that you have 22 just referred to, Mr. Gould did supply to Bechtel other documents 23 ' indicating his recommendations; is that correct? l i 24 A-To the best of my recollection he did-not submit anything 25 else. i ALDERSON REPORTING COMPANY, INC.

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~~ Q Do you mean his recor[mendations to you% ere all oral? 2 MR. FARNELL: I don't believe he said that. 3 BY MR. PATONp (Resuming) 4 0 I am asking you did his recommendations come to you = 5 in -- 5+ 0

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Also, I don't think he said 'r'commenda-e e7 G" 7 tions." A k 0 BY MR. PATON: (Resuming) d" 9 Q All right, Mr. Gould's input, can you tell me the z_ 10 form in which it came to Bechtel? 2 5 II A It was in the form of input to the specification for 3 y 12 the underpinning work in review of that specification. 'l g 13 l Q Okay, was it in writing? = m ii I4 A To the best of my recollection Dr. Go'.21h. worked on _j that specification with my group. 15 g 16 Q Is that your answer? My question was: Was it in as N I7 writing?

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18 MR. FARNELL: It is unclear as to what -- there are = b I9 'two things -- specification and review of specification -- I don't s M 1 20 j think he understands. I 21 BY MR. PATON: (Resuming) 22 Q Eis input was specifications-for underpinning; is that 23 l correct? 24 A Yes, sir. 25) Q Now, it is taking a long time for me to find out from s ALDERSON REPORTING COMPANY, INC.

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Is the input in writing? And we .= 1 5 18 i are now about ten minutes findint out whether the input was in 9" 19 i j writing. \\ 20 ' I MR. FARNELL: Your clock is a lot faster than mine. 21 MR. PATON: I think I would agree with that, too. l 22 l BY MR. PATON: (Resuming) i 23 ' Q Was it in writing? i 24 A I want to talk to my counsel. 25 (Deconent conferred with counsel.) \\ 4 'l ALDERSON REPORTING COMPANY, INC. ~ i i i

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k. ...r.-. -. -,e .->-ea v -. ~ ~ - j..-' ~ ~ : - m,,e. r..,I.y V ~ e. A To the best of my recollection it was not in writing. 2 O The specifications for underpinning were not in writing? 3 MR. FARNELL: That is not what he said. 4 BY MR. PATON: (Resuming)' g 5 Q Is that what you said? E 3 6 A No. R b 7 MR. FARNELL: That is not what you asked. M k 0 BY MR. PATON: (Resuming) d i 9! d E The question I am asking you about is the specifications Q ~ ~ 10 'j for underpinning. = 5 II A Whether the input was in writing, and my answer to that a 12 g i question is to the best of my recolleqtion it was not. ~-a 13 -m Q Did he give you specifications for the underpinning? 3 14 A He provided us i.nput. 9 15 g Q Is there some difference in your mind between inout = E I0 and scecifications? .s i C 17 ' d A Yes, sir. = ti 18 ' Q Tell me what that difference is? E" 19 i A Input is -- I would have to consider the input to be a 20 ' .! the technical details for the scecifications snd is to be written I 21 i in a form where it could be called formally a specification. 22 Q Do that one again slowly? Say that one again? The 1 23 l' Input is wnat? 24 i i A The input is the technical details that goes inro the 25 specification for particular work, and a specification would be .l ALDERSON REPORTING COMPANY, INC.

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%M-x I to incorporate all that input in a form which can formally be 2 issued as a specification to control a piece of work. 3 Q The second one again -- specifications are what? 4 A specifications are documents which can be used for 5 construction of a particular item of work or a particular +g 6 ~ structure. 7. b 7 Q Specifications are documents that can be used for 8 constructions? d" 9 ~. A For construction. l z \\ 2 l I0 'j Q Okay, did Mr. Gould provide you any specifications? = II A He provided input to the specifications. f12 Q He provided the input, and then Bechtel made the l 3[ I3l specifications; is that correct? ' 14 A We put it together -- the specification -- yes, sir. j 15 i O In what form did he-supply you the input? l = g 16 A It could be informal, written on a piece of paper; s h I7 he could come here and discuss with us an give it to us verbally. 5 3 18 Q I would ask you not to tell us what could be; what cs I9 a in fact happened? i' \\ 20 ; A-It was in the form of written on a piece of paper, I 21 ' informally given to us, or to the Civil Gr'oup; it was given 22 verbally in the course of meetings we had with him to develoo 23 the specifications. Q Is it in fact that some of the input came in writing 25 and some came orally; is that correct? .I -l ALDERSON REPORTING COMPANY. INC. M

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e , n. _ -. + ', ~ ,y i: w A Writing informally; yes, sir. 2 Q Now my question is: Some of it came in writing and 3 some came orally; is that correct? 4 A The writing was informal. That is what I want to add. 5 g Q What do you mean by " informal"? a f 6 A Just on a piece of paper and given to us -- not n' 7 consummated through any letter. ~N ~ 8 8 n Q Was any of this information given to you orally and d* 9 ~ z_. not any other way? ~" 10 'j A I do not recall how much. Some part could have been = i 5. 11 1 given orally, I a 1 12 ! d E i Q You don't know? i 2 5 13 i A I don't recall. = m I4 Q Who did he. give this information to? u= y 15 li A The person who was working on the specification at E I0 l the time. l C 17 i H Q Does that person have a name? E 18 A Yes, sir. c I I9 Q Who is that? 2d { A To mv recollection he is John Hook. 2I Q I Does he work for Dr. Afifi? 22 A No, sir, he worked for Civil Group. i 23l 0 Does he work for you? 24 A He worked for me. D Q Does he still work for you? r' i i ALDERSON REPORTING COMPANY. INC.

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Q Yes. 3 [ 0 A-To the best of my recollection, no. d ".~9 Q Did it include drawings? 29l 10 A My recollection is no. = II Q Okay, when was this input from Mr. Gould supplied to 3 f Bechtel? -_j 13 l A To my. recollection it was during sometime in '79. 14 Q Is it your testimony that the input that you have [- 15 stated was given to Bechtel by Mr. Gould has been supplied to ili I0 Dr. Davisson? =s C 3 17 l A My recollection is yes. y E 18 I Q You indicated that Bechtel used the input that was _c b I' supplied by Mr. Gould and made specifications; is that corr 2ct? M 20 l l A That is correct. 21 l Q When did Bechtel do that? 22 l A During '79. I 23 ' l O Can you help me a little bit? Can you be more specific Ml than '79? 25 i A My recollection is during the middle of '79 sometime. I

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  • 6 1

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  • S 7

direct knowledge, your indirect knowledge -- I just want to know l 8 what you know.from any source. dd 9 A Yes, sir. ,zo h 10 Q Did you consider tha't question a difficult question? II MR. FARNELL: What type of question is that? I think a f 12 that is totally uncalled for. I ag 13 { MR. PATON: I will withdraw that cuestion.

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14 ! i3 i BY MR. PATON: (Resuming) E I P 15 g Q To your knowledge Consumers has asked the NRC to j 16 approve the remedial actions they have suggested in the electrical e d 17 i d penetration area. Now what has Consumers asked Bechtel to do i 0 with respect to the caissons in the electrical penetration area? I: j 19 l MR. FARNELL: Will you read that back? 20 I j (Record read.) 21 ll MR. FARNELL: I don't know whether you are talking 22 ly about construction, or design, or implementation. 23 i MR. PATON: That is what I am asking him. What has 24 I I Consumers asked him to do? Ab j MR. FARNELL: Asked him to do with respect to what? 3

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j II A To the best of my understanding Consumers has asked m j 12 Bechtel to complete the design and do the analysis which has been 2l g 13 committed in response to various questions to make sure that c the m 5 I4 remedial action results in a safe structure and then issue the t: g 15 necessary documents for construction. ~ I0 3 BY MR. PATON: (Resuming) wi [$ I7 Q Do you have an opinion as to whether or not the E g 18 information that has been supplied -to the NRC with respect to 19 5 these caissons is sufficient for them to conduct a review of your a 20 i work? 21 MR. FARNELL: For what? By "them" I assume you must II be referring to NRC. For what purpose? 23l MR. PATON: I am not asking him any legal questions; 1 24 l I am asking him an engineering question. If whether in his-1 i 25 ljudgment the information that Bechtel and consumers -- the l

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w. M Y '- Y: A ,3.g g-. 3:- : ~~ 35-36 -:m., ... a, 1 A In the design yes, sir. 2 Q How about bearing capacity? 3 A Load bearing capacity. 4 Q You said loads; that is correct. 5 Bearing in mind your understanding of the use of the ] 6 word " design," do you have an opinion as' to whether or not the R 7 NRC has sufficient information to review the design of the X l 8 caissons? d d 9 z, MR. FARNELL: You are talking about the final designs? 10 i I think he has testified they don't have the final designs. II MR. PATON: I am aware of that. m ( 12, MK. FARNELL: 5 Also, on the same objection as to whether g 13 we are talking CP or OL review. a g 14 BY MR. PATON: (Resuming) G I5 Q Mr. Dhar, do you have an opinion, bearing in mind your = j 16 understanding of the word " design," as to whether the NRC has W h I7 i sufficient information to review the design of the caissons with = 5 18 respect to the-remedial action that has been proposed by Consumers r-I' for the soils problem at the Midland ' site? M 20 l MR. FARNELL: Same objection as to the foundation, and 21 lack of knowledge as to the details, and vagueness as to whether 22 it is OL or CP review. If you can understand his question, you If can answer it. 1 24 A I believe I answered the question before. I repeat the 25[ same answer. The material which has been submitted represents 'l ALDERSON REPORTING COMPANY. INC.

... n..e 5 h Ni f .,..r 5 $$?~Y c. ., u.... v+gs;. g (,; 3,n 4. u ~.., ,.. w :.~.: v e .c,-e ~~- ~ ~ ~ - k.p:.y.j.:: w..1.m <eene,, peg gg 33,}emedial actic'E n.'d also"the c2 A ria which would .~. -1 2 be used to evaluate the adequacy. That part is adequate 3 information to make determination of that part of the design. 4 BY MR. PATON: (Resuming) = 5 Q 3 "That part of the~ design" -- what part is that?'. 3 0 A The adequacy of the concept and the criteria that would 7 be utilized to establish adequacy of the structure. X ] 8~ Q You do not now have a final design -- dd 9 A Yes, sir. 2, 10 0 -- of the caissons; is that correct? Z i 5 11 A tes, sir. mj 12 O Do you have anything that you call a preliminary design s 5 13 .or interim design? Do you consider that you have any kind of = 14 design of the caissons at this point? in 7-1 15 A Yes, what we would consider to be a better than ~ j 16 preliminary but less than final, e C 17 g Q Did you state that you don't know exactly what ~- 18 information has been supplied to the NRC with respect to the ~ h 19 i g ' design of the caissons? 20 A Yes, sir, the details of the answers I am not familiar 21 with. 22 Q Who would have the responsibility within Bechtel to l 23 l' know that information? 4 e l 24l' A I delegated that part of my work to my Deputy Group t 25 Supervisor, Shing Lo. i l l ALDERSON R EPORTING COMPANY. INC.

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8 Q Do you know whether Mr. Lo knows what information has dd 9 been sent to the NRC7 10 A Can I talk to my coun.tel, please? I E 11 MR. PATON: Certainly. <m j 12 (Deponent conferred with his counsel.) h 13 BY MR. PATON: (Resuming) I 1 \\ = 14 Q Can you answer the question? 3 g 15 A I do not know the exact details. _= 16 l Q Have you ever discussed it with Mr. Lo? g w( 17 A Yes, sir.

  • =

} 18 Q Tell me what that conversation was, or those E 19 ' conversations? M 20 A To the best of my recollection I talked to Mr. Lo 21 regarding the progress, whether he has any problem areas that he 22 sees, and whether he has answered the question. He reports the I 23l progress to me occasionally and frequently, and any problem areas 24 l he encounters, he advises me of it. 25 [ -Q Okay, you sa.1.c' he reports to you occasionally and t .i ALDERSON REPORTING COMPANY. INC. ___-____-__.-______-__m.____m

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specifica1Iy addresced what information is being suppiled to NRC?

I E 14 E A Yes, he reported to me the information supplied in 9 15 response to specific NRC requests. ~ l 16 Q Did you discuss with him specifically what information O""17 i is being supplied to the NRC with respect to the caissons? x !5 18 A No, except that I recall that he told me that some of s" 19 8 these particular specifications were to be submitted to NRC. 20 l Q Do you have any idea when? 21 MR. FARNELL: I don't think that implies that it wasn't 22 submitted. 23 3 BY MR. PATON: (Resuming) i 24 i l 0 When did he tell you that it was to be submitted 25 l approximately? i i .l I ALDERSON REPORTING COMPANY, INC.

~ 7 -; *.. :... -:a pgg4,;';d. %nq-- ... n.. m .r@G&l*2W; 5.: _-.&Q , }k.&J m n. ..n r. 40 1 A Approximately. I don't think -- four or five months 2 maybe. 3 Q Do you know whether or not in fact that has been 4 submitted? l 1 1 e 5 MR. FARNELL: I think that has been asked and answered. h I' E O BY MR. PATON: (Resuming) ll 7 Q Did you say that has been submitted? 3[ 8 A I said that has been submitted. d* 9 Q I'm sorry -- do you recall your answer? Do you know ? f10 whether or not in fact that summary has been submitted? = II A I did not know from my personal knowledge, m f II Q Within your responsibilities, do you have any duty or I f 13 l obligation to sign off, to concur in writing with respect to any = l 5 I4 information that is sent,to the NRC? g 4 9 15 5 MR. FARNELL: Sign off -- what do you mean by sign off? 4 = Si I0 BY MR. PATON: (Resuming) d i I C 17 ' 3 Q Do you understand what I mean by signing off? z 5 18 A No, sir. _c8 g Q All right, that will be another question. 20 With respect to the concept of the use of caissons, do 21 you know when that concept was provided the NRC? 22 A To the best of my recollection it was provided in '79 sometime. i 24 l l Q In what form? i-25 i A In response to NRC Questions. ? 'l -l ..ALDERSON REPORTING COMPANY. INC. y

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~ ^ . x,. c ,u-',g.. ' - h., ' I **' -~ y t,, s *. '$ M.*~..'". ~ _,, -[ 42 . % v., ...2., I MR. FARNELL: Lec's do them one at a time -- the piles 2 and caissons. I think if you want to get at it, you might ask 3 whether he is talking about facts, opinions, or conclusions. It 4 is just so broad. 4 BY MR. PATON: (Resuming) 3 3 6 i Q All right, give me facts, opinions, or conclusions with "o"; respect to piles; do ycu have any disagreement with the facts, 8 8l j opinions, or conclusions that have been supplied by Dr. Davisson? a-d 9l ci .j A .We have comments from Dr. Davisson on our specs, and we i t' 10 3 got them resolved after talking with him. 5 11 g Q You got comments about specs, and you got them. resolved. d 12 E I What were those comments? S ia l 5 A I do not know. As I said before, I am not familiar w2.th E 14 Il the details. 4 g 15 y j Q Who within Bochtel has the responsibility to be familiar 16 l with those details? d 17 g l A I would consider Geotechnical Group to be knowledgeable E 18 I in that. E 19 l Q Is that Dr. Afifi's group? 20 A Yes, and my Deputy Group Supervisor, Shing Lo, would 21 know. 22 O You used the word " resolved." I gather at some point 23 l you have knowledge that there was some comment by Dr. Davisson 24 l ! that was.not in complete accord with Bechtel's thinking; is that 25, correct? ALDERSON REPORTING COMPANY, INC. I

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{ 18 was provided since there apparently were two earlier ones. c i h e I9 i MR. PATON: I will ask him if it is his testimony that M 20 the concepts were in the earlier versions. 2I BY MR. PATON: (Resuming) 22 0 Let me ask you a slightly different question. Have you 23 l read the portions of Table 12-1 that I have referred you to? 24 A Yes, sir. 25i Q Is it your testimony that that is the concept and i ALDERSON REPORTING COMPANY. INC.

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^ 46 I j MR. FARNELL: What is in Question 12 will speak for %l itself. 3 MR.PAbN: I am asking for his knowledge of what is 4 in Question 12. Ii' he would prefer to read that over the lunch g 5 1 hour, that would save some time. R .i. I l2 0 MR. FARNELL: My comment is that Qucation 12 speaks for R d 7 itself, and we don't have the first -- the original - as opposed ~ M 8 8 to revisions. (J d I MR. PATON: I am asking his knowledge. I understand 7. h 10 there are certain words printed in that answer. = 5 II A The response to the Question also refers to Interim am N II Reports 6 and 7, MCAR 24 for the detailed description, and without i 5 1 g 13 having that, I cannot make a judgment. 14 g j S MR. PATON: (Resuming) k i j 15 Q Mr. Dhar, we asked that you bring with you today any = a[ 16 documents that you have in your files under your control and I h I7 l supervision with respect to the remedial actions at Midland. Do ~ W 18 ' you have any such documents? 19 9 MR. FARNELL: I note for the record that several weeks M 20 ago Consumers produced a massive amount of documents from the 21 Bechtel files, and included among those documents were documents 22 l j from the Civil Group, and those documents were produced at the 23 I request of the NRC. So the answer would be in part that we have i 24 I l produced these documents. Mr. Dhar did not bring those documents 25 ' with him today because they have been produced to you, and you 8 4 -l ALDERSON REPORTING COMPANY,INC.

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  • P l

8 Q Not at all? dd 9 A I will rely on the Civil Group files. i ,Zog 10 Q Are the Civil Group files in your office? l Z ~) 11 A It is under my - .I am responsible for the files. They 3j 12 are in the Civil working area. m g' 13 g . What I mean is how far is it from your desk? Is it on = 14 the same floor? .s -g 15 A Yes. Right across 'he aisle. t w g 16 Q So every time you work on the Midland case you get up w y 17 l from your desk and go over there and get a file and come back; ax k 18 is that it? E i 19 l A If I need a reference. na i 2d Q So, in fact, you have no files whatsoever of your own? 21 MR. FARNELL: You askad him only about the Midland case. 22 ' It has been asked and answered. 23 BY MR. PATON: (Resuming) 24;l Q On the Midland case you have nothing in your desk that 25 ; are your own files.with respect to the Midland remedial action? i .i ALDERSON REPORTING COMPANY, INC. i

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.a>... 48 1 A I do not keep a file, but I have papers as they come in. 2 Q You have papers on it as they come in? 1 3 A Before they go to the file. 4 Q You mean this is only temporary? They are on your desk e 5 for a week or two, or something, and then they go, but you don't E 3 6 have any other information in your desk as distinguished from the R 7 Civil Group files? Al 8 MR. FARNELL: With regard to Midland. d d 9 SY MR. PATON: (Resuming) ,zog 10 Q With regard to Midland? z j II MR. FARNELL: That has been asked and answered. i R f 12 l BY MR. PATON: (Resuming) = 4 -e { g 13 Q What is your answer? 3 14 l A 5 Occasionally I make copies for working sometir , and 15 then I have to work on some reference I need, I make a copy for j 16 working, and when I am done I throw it away because I have the A l I7 i material already in the file. 3 l k 18 Q Is there a problem with the soil or the fill at the i: I9 ! service water structure? a i 20 A To my knowledge, yes, sir. II Q What is that problem? 22 l l A As determined by the Geotechnical engineers, the fill 23 under the north part of the structure, some part of it, ' s no t i Ml adequately compactnd. 25 0 Is there any observed excess settlement at the service t ALDERSON REPORTING COMPANY. INC.

.m,- -I ? 7 'I m:;? pin., n:,..... : n - w -.. _.,..,. pp. () ...c., ~~ . ~ ~. Ak ~ 1 p..__. ~. I water structure? - i., . ~...... ' c s..a. .c 2 A To my knowledge, no, sir. 3 Q What is the proposed remedy at the service water 4 structure? g 5 A The proposed remedy is to drive piles near the north o 6 end of the structure and construct corbels from the north wall of R 7 the structure and jack the pile against the corbel and lock it off i M ~ l 8 at predetermined load. d d 9 Q That last expression you used -- lock it off -- is that IE h10 what you said -- 1-o-c-k it off? = II A Yes. S d I2 Q And complete that -- lock it off.--

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A \\t predetermined load. l 14 0 How many piles do you anticipate using? I cnow I asked _bj 15 you that question before? = E I6 A The present scheme calls for 16 piles. m y I7 : Q Have they been ordered? =u 18 A Not right now. E I9 g 0 Is that within Bechtel's responsibility to order those 20 l piles, or does Consumers do that? 21 A Bechtel would do that. 22, O What is the diameter of these piles to be? I 23 A As they are presently -- as it stands presently, it is 24 l 14 inch diameter pile. 25 Q You say "as it stands presently"; by that do you mean i .l ALDERSON REPORTING COMPANY. INC.

\\ 7-: M...,.,_.*"M5;%..$JJ,;5.m.t.,: n... .n, : .%Wm - -d :'_ ~_it..m;' JJ. y.L.iC'". 4 _. :.q - .--u- :... .u A. Q...- . f5 d6 M4 #R'h. .32 .~:....... w,....- so m ..,u. ; m.y e s. sa. 0 \\ p"... - +,.. i \\ .'I, that it may change? t. 2 A Since we have not completed all of our calculations and 3 testing of pile, it may. 4 Q Bearing in mind the fact that this diameter may change 5 as you do additional calculations, for what purpose do you now use ] 6 the 14 inches? R d. 7 A We use 14 inches -- it is my understanding that Geotech M g 8 will calculate spring constant of the pile based on 14 ' inches, d

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and we would prepare our preliminary design based on that 14 inch i 10 diameter. _2: 5 II Q What does spring constant mean? is d 12 E A 5 Spring constant means the deflection of the pile for 5 I3 : a civen load. a l 14 I t: I Q By " deflection," do you mean lateral? = 6 g 15 A No, sir, vertical, but it could mean lateral in general = E I0 sering constant. g h I7 l 0 You said vertical deflection? It includes the concept E 3 18 of vertical deflection? 19 g A For this application; yes. i ~ 20 Q And the vertical. flection could be caused by what? 21 I A Vertical load. 22 O Does this relate to the length of the pile? 23 I MR. FARNELL: What is "this"? 24 BY MR. PATON: (Resuming) 25 l 0 Spring constant? .\\ i ALDERSON REPORTING COMPANY. INC.

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S1 = 1 A I would think so. 2 Q Have you made a preliminary estimate of pile length? 3 A It is my understanding that Geotech has made a 4 preliminary estimate of pile length, e 5 Q Geotech does that, not you? h 3 6 A Yes, sir. Rg 7 Q What is that preliminary estimate? 2 8 8 A I do not recall the exact length. d d 9 0 Do they get any input from you in order to determine i h 10 what the length of the pile is going to be? l z_j 11 A They would get the input of the top elevation of the 3 j 12 pile. S g 13 Q From you? a 14 A From the structure, yes, sir. D_ 15 0 Is that all they get from you? y 16 A And the location. s d 17 0 Do they get from you the load to be imposed? u ca 18 A This is an iteration process.- They would give us the E 19 capacity, and we would run the calculations and see whether thev g i n i 20 can work with chat capacity. If not, then go back and learn what 21 ! the actual loads are. I 22 Q They tell you the capacity of the pile before you tell 23 them what the loads are going to be? 24 A We would give them an approximate idea of the loads, and 25 that would determine what is to be the diamet;er of the pile. ALDERSON REPORTING COMPANY. lNC. i

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They determine the size of the pile -- the approximate a 3 14 lJ size of the pile -- and that would give us the ultimate capacity G: 15 h of the pile and the spring const: ant. 16 ai Q How was the spring constant determined? us 17 ' 2 A E I wouldn't know the details. $" 18 li Q They determine the size and capacity of the piles, and 19 9n ! then they send that information back to you? 20 '! A Yes, sir, i 21 i Q What kind of calculations do you make et that point? 22 A We would go through and establish any jacking load, and 1 23 we would go through and determine the seismic analysis and i 24 I i i determine the loads on the oile, and check to determine load i, 25 ' determination and see if we are meeting the required safety factors I a l ) .i ALDERSON REPORTING COMPANY. INC.

7 g. ;;n. In.: -h- ..__.x..5 S Z'Q;Q'J_';;; 5-G.? Q Q}J ~~ P, V...; s I Q Do you know how far the piles will be driven into the 2 ' glacial till? 3 A I do not remember. 4 Q Do you know if that has been determined? 3 5 A I believe that will be determined based on the actual ] 6 I driving records. RhI Q Has any preliminary determination been made in that t { a j 8 regard as to how far they will be driven into the till? d I A It is my understanding that Geotech has made some o h 10 preliminary determination. = 5 II Q But you don't recall now what it is? a N II A I do not recall. I3 Q ' Do you know how.they make that determination? I4 A I am not familiar with the details. l a 15 lI 7 Q Do you have any idea of the information they used to g a 3[ 16 d make that determination? I .t{ 17l' A It is my understanding that they use the boring records. x Ii 18 l Q What kind of information do they get from the boring E 19 j l records to make that determination? 20 ll A As I said before,- I am not familiar with the details. I 21 I 7-2 l Q Do you know when the Geotech Group made the preliminary 22 l j estimdte of how far they will drive into the till? 23 ' A My recollection is that was sometime in '79. 24 li Q Can you.do any better than that? Can you be more 25l specific than that? .I ALDERSON REPORTING COMPANY, INC. i d., m-w

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~( > 2. :. ..m....~ ..,y \\.,, s. . ~ - - M {* ~= L. ~.. I. 9G; ' ' i ' "' ~% .s A I would think sometime in the summer or fall of '79. 2 g Did Dr. Davisson supply any information to Bechtel to 3 your knowledge with respect to the calculation of how far you 4 expected to drive the pile into the till? 5 MR. FARNELL: Are you talking about the preliminary? 8 6 a MR. PATON: Any information -- file, preliminary, e. R 7 anything. 0 MR. FARNELL: Preliminary estimate of how far they are d =i 9 going to drive into the till? 10 z MR. PATON: Yes. = iii 11 g A As the interface between Dr. Davisson i's conducted cf 12 2 through Geotsch, I do not recall. h 13 g SY MR. PATON: (Resuming) M 14 3 O Did you ever hear any discussion of it? What I want is E I g 15 your knowledge. Have you ever heard it, or saw it, or from wx ? 16 g whatever. source? t{ 17 ! w l A My recollection is that it was discussed in a meeting, 18 i I but I do not recall the exact details. E I 19 i j l Q Do you know whether the NRC has been supplied any 20 l information t4ith respect to how far you estimate you will drive 21 ' the piles into the till? 22 j A I do not know the details no. 23 ' O. Do you know whether or not in fact you expect to drive 24 i 3 the piles into the till? 25 ' A My understanding is, yes, we expect to drive it into i '} ALDERSON REPORTING COMPANY. INC.

,..g.gs 4.? O w,M d' 2.Y..' : *~'- .~ 55 .,u. I the till. 2 O What is the maximum vertical static load to be imposed 3 on the piles at the service water structure? 4 A I would have to know a little bit more detail before I g 5 can answer the question. 8 ] 6 g Is there some part of that question that is confusing? R b 7 A It is not specific. 3 ] 8 0 Do you have any difficulty with the word " static," for d 9 example? I understand it to mean dead and live loads, and' I would z 10 amend my question to read that way. Does that clarify the 5 II question for you? m j 12 A Would you please repeat the question? =3 5 13 0 Sure. My question should be understood te include -- = l 14 now, let me ask you. Would you include within the word " static _b f_ 15 load," dead load and live load? E I6 A Generally speaking, yes. + C g 17 'l 0 Let me ask you that question again. With that under-E g 18 standing, what is the maximum vertical static load to be imposed E II E on piles at the service water structure? M 20 A As I recall what I have reviewed so far -- understanding 21 that the calculations are not yet final -- my recollection is 22 j that they would be jacked to about 100 tons initial jacking. 23 } O Would you expect the final load to be something less i I 24 than that -- you said the initial jacking -- is the final load i 25 - something less than that? .lI ALDERSON REPORTING COMPANY, INC.

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yy. %;- - Y-l ii * -?? l }hs ' l:,[?fl ? ~ ' <. .,y , y. .m + 1 A My recollection of what I said before was that when I the combined 5SE load with other loads, the factor of safety was 3 1.5. 4 Q Is that a factor of safety for dynamic loads? 5 A I still cannot understand that word. It is not a 3 6 factor of safety for the dynamic load; a no. I thought I was n 3 7 clear what I said, n 2 8 a Q What is your understanding of the expression " factor d ]". of safety" with respect to pile d4 sign? 9 h 10 j A I would consider factor of safety to be the ultimata = capacity of the pile divided by the load on the pile under a d 12 z particular condition. Q Okay. Is that factor of safety in your opinion within E 14 5 the concept of acceptance criteria for the piles at the service k i 15 g water structure? g? 16 MR. FARNELL: As I recall his acceptance criteria deals 6 17 l with buildings, not piles. w 2 I = 18 'i, = MR. PATON: Maybe I have made a mistake. I will ask- "wj 19{i him that question. l* 20 BY MR. PATON: (Resuming) 21 Q Is ycur concept of acceptance criteria such that it 22 cannot be applied to piles at the service water structure? 1 23 ' l i A The concept of stress, allowable stress versus actual l l 24 stress may not be applicable to the piles. That is applicable 25 ' to the structure. 4 i'i . ALDERSON REPORTING COMPANY, INC. ~ l

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.;.y,;,.9. JW ; 7--O~ w.... % - ~ ~ r.. :.. ~ 1 MR. FARNELL: What subject? 2 MR. PATON: Come on -- what subject. 3 i MR. FARNELL: There has been 80 different concepts 4 bandied about here. 5 l MR. PATON: I am talking about lateral loads on the 8 6 . piles which I have been talking about for five straight it.inutes, R 7 j and then you ask me what subject -- I don't understand that. ] 8 During any lateral load at any time caused by any force. d d 9 i MR. FARNELL: Sure. Beautiful. h 10 z BY MR. PATON: (Resuming) E 11 Q Did you ever consider that? ti 12 A Would ycu please repeat your. question? 3 13 5 i 0 Yes, sir. Did Sechtel ever consider whether lateral I 14 y loads would be imposed on the piles? 2 15 g A Bechtel did not consider lateral loads to be imposed 16 on the pile. 6 17 i y Q Can you tell me why Bechtel did not consider lateral. 5 18 loads to be imposed on the pile? E 19 e i n A Because it is considered that the piles are laterally 20 very flexible compared to the structure which is founded on 1 21 i original soil., and therefore does not carry any part of the 22 lateral load. 23 1 Q Your conclusion is that there will be no lateral load l 24 l imposed on the pile; is that correct? 3 25l l MR. FARNELL: l That has been asked and answered. 'h ALDERSON REPORTING COMPANY, INC. .r. y g y

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3" 18 Q How far above the pile is the corbel? c 3 A I do not remember that kind of intricate details. 1 a 20 1 l Q Is the pile directly below the corbel? i 21 i A What do you mean by "directly"? 22 i Q Is the purpose of the pile to support the corbs1? 23 A I woi.11d consider. it the other way around. Q. You mean the corbel is to support the pile? 25f A The corbel is to transfer the load from the pile. l ALDERSON REPORTING COMPANY. INC. ~

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~ 5 E W 2~ ' m ~~ &;-Q. _. _. _ _v, ,.; j:)lp ' ..:.L. :s % -T r - .. _. ~. m 2 j n-e 1 corbel? 2 MR. FARNELL: Any connection? 3 MR. PATON: Yes. 4 MR. FARNELL: What do you mean by " connection"? 5 g BY MR. PATON: (Resuming) a 6 Q Do you understand what I mean by that? R d 7 A Do you mean contact? 8 0 Yes, during a safe shutdown ea'thquake? r d d 9 A That will depend on our final analysis and the loads .zo 10 which are on it whether there is any separation or not. Z 11 Q Do you expect a safe shutdown earthquake would impose a y 12 any lateral loads on the structure itself? I fII A Yes, sir. n 5 I4 l 0 Would these lateral loads be imposed on the corbel? Tj 15 MR. FARNELL: Lateral loads developed during the E I6 earthquake? I k II l MR. PATON: Yes. E I g" 18 A There would be a small initial effect on the corbel r-E 19 g ! itself, but since the piles are not carrying any lateral load and ll 20 are not resisting any lateral load, I do not expect a great. deal 2I ' of load to be transferred to the corbel. I 22 i i BY MR. PATON: (Resuming) i 23 Q You say that the pile will not resist any lateral load 24 ii because there is no connection between the pile and the corbel? 25 'i A No, sir, because of the stiffness. 3 'I ALDERSON REPORTING COMPANY. INC.

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Do you know how Geotech established those values? E 19 : X 1 5 l A No, sir, I do not. I do not know the details. 20 l Q You attended a meeting in Bethesda either last Friday 21 f 22 ! or the Friday before that; is that correct? l A Yes, the 5th of December. 23 Q Did that concern seismic information? t 24 4 1 A Yes. l 25 i O What was the purpose of your attending the December 5 i ALDERSON REPORTING COMPANY,INC.

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5 II Q Is someone suggasting that you use site specific y 12 ' response spectra at Midland? i 5 I3 i A That is my understanding.. = \\ m I4 j Q Who is suggesting that? Bechtel or the staff? g' 15 A It is my understanding that the staff' wrote a letter z d I' to Consumers suggesting site specific response spectra. w h I7 O And you are now considering whether you think that is E 18 f the appropriate way to go? 19 E A That consideration is being made by Consumers Power. A 20 Q And to your knowledge have they decided whether that 21 I j is appropriate or not? i 22 A We have not received any specific directions from Consumers Power. 24ll Q Has the staff-within the last two years indicated to 25 Bechtel that there is any change in their thinking with respect I I ALDERSON REPORTING COMPANY, INC.

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2,,, -Q TsO h C 4: '.: & & s s '.., --.. ':jfi? %;-+ ...,- n. .a p -'~ m ,.a. I Q In the seismic structural analysis that you performed 2 afte r you discovered this soil settlement problem at Midland, 3 was the floor response spectra for the diesel generator building 4 generated on the assumption that the shear wave velocity would g 5 not be lower than 500 feet per second? 9 ] 6 MR. FARNELL: Would you repeat that one, please? 5 E 7 (Record read.) Xl 8 A The answer to that question'is yes. cd 9 BY MR. PATON: (Resuming) ,zc 10 Q Have you assured yourself that the soil shear wave _z j 11 velocity will not be less than 500 feet per second for the life a Sj 12 of the plant? 5. 13 MR. FARNELL: For the diesel generator tha,t we are = n i I4 talking about? Y. j 15 MR. PATON: I will accept that amendment. E I6 A I do not know. d I !i 17 ! BY MR. PATON: (Resuming) w= k 18 Q You have described generally the proposed remedy at C 19 the service water pump structure. My question is, did Bechtel M I 20 consider any alternative corrective actions? i 21 A Based on my best recollection, we did consider other 22 alternatives. One of them was to remove and replace the fill 23 l under that part of the building, and the other one was to 24 l strengthen the structure. 25 l Q You said strengthen the structure? 1 1 AL.DERSON REPORTING COMPANY, INC. l

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I the practicality of construction. 2 Q Okay, feasibility 'of the scheme and practicality of 3 construction. Practicality would indicate to me dollars. Did 4 you consider dollars? g5 g-My recollection is a little bit not clear at this time g 6 what are'the factors we considered, but these are the ones that R b I I remember now. X 8 Q Who made the decision to proceed'with the remedy that d" 9 you have stated was proposed for the service water structure? g 10 A The decision was made by the task force. = 5 II Q There was a task force created for this purpose? m d 12 z A For resolving this problem -- a plan for the problem. E 13 I = 1 Q Does that task force still exist? 2 14 d A To my understanding it does not exist any more. M 9 15 g Q Was that just Bechtel, or was that a joint task force 16 g with Consumers? ( 17 a A It is my recollecrion that there was a Consumer member 2 M 18 on the task force. =" 19 i j j As I remember it it was Mr. Widener, myscif, Dr. Afifi, 20 l l Jim Wanzeck', from Construction, Al Boos, and from Consumers it 21 ! is my recollection that it was Mr. Tom Cooke who attended the 22 meetings of this task force. 23 ! Q How about Gil Keely? Was he on this task force? 24 l A I do not recall whether he was a formal member of the 25 g task force. He might have attended some of the meetings. .I ALDERSON REPORTING COMPANY,INC. i

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C 9 5, A My knowledge of the dewatering problems is very limited: 10 therefore, I cannot comment on the feasibility of that scheme 3 h 11 from that particular aspect. t Y 12 BY MR. PATON: (Resuming) = y 13 i Let me ask you to assume that the dewatering system works? Q = l 14 l MR. FARNELL: 't It still doesn't take care of his = 15 j problems, and there is an objection to the foundation regarding = y 16 his knowledge of dewatering. 35 N II BY MR. PATON: (Resuming) Ec

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Bechtel made that judgment in the first place. If you I9 I 'are unable to tell me assuming with the permanent dewatering a 20 system that would affect your judgment, I will not press it. I IIl MR. FARNELL: Bechtel made the decision; he didn't say 22 he made the decision. i The::e is no fot,ndation for that question. 23 ' BY MR. PATON: (Resuming) 24 Q 1 Do you have any opinion as to whether with the knowledge 25 j of the permanent dewatering system that Bechtel proposes -- and I l c k 3 ALDERSON REPORTING COMPANY, INC. j, 3 : q, ; _. y _ _; q ~ _;... ; 3_ g ; ; 7..; _;.;.

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, *ir c _ gy -~ - c ,-.e------ 2 Mr. Dhar checked his desk over the lunch hour an provided us any 2 information in his possession or in his des)c that relates tb 3 %" m: % Midland. We have just been provided a stack of materi/i which I 4 will estimate is approximately six inches high, and we c ce just 5 = g beginning to look through that material. MR. FARNELL: From what I understand, these were E 7 documents that,here on his desk and not in his desk, and were e. S 8 M the type of documents that he testified previously that he would d 6 9 g use until he finished with them, and then they would go into the 10 z files. They have already been produced as far as we know. h MR. PATON: We had better read that last question d 12 y because I want to ask him something about the documents. Read 3 13 that last question back, if you will. 3 14 (Read record.) x 2 15 g-BY MR. PATON; (Resuming) ~ 16 l Q Do you understand the question? I will be glad to 17 I repeat it. Before we took the break we were discussing an wl 18 5 1 alternative that I believe you indicated was suggested by NRC. 19 l A No, Civil staff. 20 Q I'm sorry -- Mr. Tuveson. 21 A Of.Bachtel Civil staff. 22 Q - Would you state briefly what that was? E 23{I A The alternative was to investigate what the origin of 24 I ' the ground surface is in relation to the so-called cantilevered t l 25, part of the building and what it would take to extend the-l I i ALDERSON REPORTING COMPANY. INC. i s-w l t

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== g 16 O Do you have any plans for in-service inspection of the ad d 17 i bolt during the life of the plant? / Ig l A At this time, no. C' e 19 l Q You know whether you plan to have such inspection at M l N 20 - any time in the future? 21 A We will have'to look at the situation and evaluate and 1 22 \\ determine whether such a plan will be necessary, i i 23) Q As far as you know right now you can't conclude that 24 it will be necessary-or not. At least you have not made that l 25 decision at this point? j . ALDERSON REPORTING COMPANY, INC. ~ t b ..m-r

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~ w: R- ~ ~ scv~ a., I study, and then the loads are changed, and then we go back and 2 redo the calculations. And since that time we have not completed 3 all the evaluations. Q Now, I will ask you all of those same questions about y 5 the safe shutdown earthquake unless you tell me that the answers "I g 6 would be the same. I just asked you about the operating ba:.is 5 d 7 earthquake. Wotild the answers be generally the same? f. X] 8 The answers would'be generally the same, but if you A d 2 9 want to ask me one more time -- ,zo h 10 Q No, I don't mind asking you. As far as you know your ~ = 11 answers would be the same? 3 Y I2 A Yes. --3 13 Q With respect to the long longitudinal bolts that will l 14 be used at the c 3rvice water structure, will they be pre-tensioned ? bl 15 A The present scheme calla for pre-tensioning. = ![ 16 0 Okay, what does that mean? as 17 ! A That means that the scheme that we have got right now = !3 18 does require pre-tensioning. w* 19 I 8 i O .That is my question: What is pre-tensioning?. n 20 A Pre-tensioning means you stretch the bolt before you 21 put it in service so that when there is a tension load in the 22 i bolt, the bolt still has got some compression left -- the l 23 ' interface has some compression left in it. Pre-tensioning means. 24 ! j stretching the bolt to some predetermined value before putting it 25 in service by some predetermined force. I l 'l ALDERSON REPORTING COMPANY. INC.

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( ; 7,sc, ..., ~, -,- r -<-~s. ..u*'t,~~~ '~~ vf.; ~ " y. E.,,1:. Does tee w'ord "frictI,oi$3: fit" h11a'ifyManing for you? -- - O n -- 2 A It is not very clear to me. 3 Q Does that concept of friction fit, does that have any 4 meaning with respect to the proposed service water structure? 5 g A I do not understand your word. c? j 6 Q Do you have any understanding of the word? C CE 7 A I can only guess what it means, but I would not like ~ g 8 to do that. d" 9 O Have you assured yourself that the concrete at the 2 10 interface between the corbels and the service water pump 35} 11 structure can adequately resist bearing pressures developed as a a j 12 ! result of pre-tensioning of the bolts? 1 ,= g 13l' A In the analysis that we have done so far, yes. 14 Q Do you know whether the permanent dewatering system 15 j. l will be designed to withstand.a safe shutdown earthquake? i j 16 l A My understanding is, yes, that it will be designed to d ( h 17 f withstand the safe shutdown earthquake. I will have to change I b I8 the answer. Do you mean the system itself? E I9 e i 0 The permanent dewatering? n I 20 j A The system itself? 21 I i Q Yes. a 22 l A My understanding is that it will not. I misunderstood i 23 ' the question. 24 i j Q The first time I asked you that question you answered 25 * "yes " What'were you responding to? i i I I j ALDERSON REPORTING COMPANY. INC.

^ ~' n., .nc ~.. ~.',:. W *:E 2: Y _: :: 2$~h.b.bi; ' ~.L'Oisd?'" ., ;. g. w,. %. - - O- ,. v.... 1 A I was responding to the aspect of the design where the 2 sand when subjected to the safe shutdown earthqaake would liquify, 3 and that earthquake aspect was considered SSE. 4 Q I want to ask you about that statement. I will sa_v g 5 what I think you said, and please tell me whether I am right or 9 g 6 wrong? I think you said that in considerin~g the permanent C 7 dewatering system, you were considering its impact on sand, and a' j 8 the question was will the sand undergo liquefaction, and the d d 9 force that you put into that computation to say whether the sand z'c g 10 would undergo liquefaction was the force to be expected from a = j 11 safe shutdown earthquake; is that correct? I 'f 12 l A Yes, that is correct. E I 5 13 { Q You say that slightly grudgir~ gly. Is there any part l 14 of that that is wrong? "=j 15 A I would say that I.do not agree with the way that you g 16 l; have worded it. The wording may not be technical in all resoects, as \\ d 17 I but I said, yes, because the general idea is correct. E c 3 18 Q Are there any seismic category i valve pits located in ? I9 the fill adjacent to the east and west sides of the generator 5 i 20 'i building? i 21l A Yes, sir. 22 Q Did any changes occur to these pits during the diesel 23 ' generator surcharge program? 24 MR. FARNELL: What do you mean by " change"? 25 MR. PATON: If the witness doesn'ti understand the i

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= f 16 to the NRC. 2 i C 17 ' Q I am asking you your recollection. Do you remember the C i 3 18 cause? Do you remember from any source whatsoever the cause of C* 19 2 4 the cracks? M 20 1 A As I said before, the causes of the cracks -- it could i 21 i be either shrinkage or due to settlement. 22 3 O Were there any cracks that you have determined that were 23 l caused by settlement? 1 24 i i A My recollection is that, yes, there were some cracks 25 13 that aave been determined to be caused by settlement. h 4 ALDERSON REPORTING COMPANY, INC.

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_,_..4gy_ y y W:; rff;.C.. J Wr 1^ ' ' 96~ ~':&.__.......N, ) . s. .:.p; - m :...:~ -. :.-- -, e p.L;. ~ v,..,,.-. ...,. m. {, _ f.; g. Nh -...m..-- a- ,. - - n ~. a :- **"- ~ -*"' .W p.._. ,7, - r;., i . ~.n ;x el-.q w--- -/ ~- w 7.. A Yes. j 1 2 Q Twice? 3 A Yes. 4 Q Three times? g 5 A I would say so. I j 6 <, Q You are certain of three? R 7 A yes. 3 3 8 9 How about four? d ei 9 A I would say yes. ~ iE 10 0 Seven? z ~ 3 II A I would not be able to say with any confidence. I y 12 I O Is it within the scope of your resconsibility to go 9 i g 13 ' to the site and observe these cracks? a 1 m I i I4 l THE WITNESS: Can I talk with my counsel? M g 15 ll MR. PATON: Certainly. 3[ I6lt (Deponent conferred with his counsel.) I N I7 ' A I have delegated that responsibility for the soil 6 1 1 3 IO j settlement problem to Shing Lo, and I am not aware of what he i I9 'has done about a crack monitor. 5 20l BY MR. PATOM: (Resumi: J) l II{ Q Let me understand that. You say that you have delegated s 22 { your responsibility for the soil settleraent problem to Mr. Lo? 23 A Yes, sir. I 24j Q All the responsibility? You said that you have i 25 1 delegated the responsibility to Mr. Lo. Is'it just that. i t I i i-ALDERSON REPORTING COMPANY, INC.

~ z . x. ... m..;..... --; ;,. g :. - -- = 4. <y vg,y x y.. - r-l.~~ c. _.3 .w . l .1 -~ '- . --cw m.,.,. 1! straightforward? You have delegated all your responsibility? l 2 MR. FARNELL: That is in response to your question. 3 MR. PATON: I am asking him to explain it. 4 A Yes, I have delegat ad the responsibility. 1 g 5l BY MR. PATON: (Resuming) j 6 Q All your responsibility with respect t'o the settlement R R 7 problem?' 3 j 8, MR..ARNELL: The term " delegation" -- d I d 9 MR. PATON: That is his word. ii 10 l THE WITNESS: What do you mean by "all"? z i E Il j MR. PATON: If you don't know the meaning of "all," I L' Y 12 l will abandon the question and go on. I am not going to 2i I g 13 ! participate in that kind of discussion. If he doesn't understand I m n 5 14 l the meaning of the word "all," I will abandon the question. c = g 13 f MR. FARNELL: I am.not sure what you are gettina at. si 16ll MR. PATON: If he doesn't understand the word "all," = 17 I will proceed with my interrogation. 3 18 MR. F^"4 ELL: That was in regard to this question. c II MR. PATON: Fine. He just said he didn't understand n a 20 ' the word "all." If that is his testimony that is fine; I will 21 abandon the gaestion. i 22l MR. FARNELL: He said what he said. 23 MR. PATON: Fine. 24 BY MR. PATON: (Resuming) 25 s Q Are any of the cracks that you have observed at the

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( i Questions? ^ E 10 j E i A We had done some. We didn't do any detailed analysis, 5 = 11 I l but we did consider the effects. d 12 ! Q Have you come to any conclusions as to the effects on 13 5 the rebar? 14 g A Effect of what, sir? 2 15, l y l 0 You said you did some reanalysis. I may not be l I 16, co.rectly remembering your testimony, but I believe you said you i 17 ' y were going to do some reanalysis to determine whether there was 5 18. E j any effect on the rebar; am I wrcng? I 19 i E A Whether the width of the crack will cause any effect a 20 on the rebar; yes. 21' ) 22) My question is,.had you come to any conclusions in that Q ) i regard? l 23 ' A I believe so that we have got a width of crack beyond. 24 q I ' which we consider the cracks to be repaired. 25 2 3 MR. PATod: Would you read his answer back, please? '.i ALDERSON REPORTING COMPANY. INC. -h

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n _m.. +*w .}% $ - = ~ ' ' '~ ' t '#,. - ~* t a. O*" 100 s<- I j Q We are pretty close to the area of responsibility of 2 you and Mr. Johnson. Is there anybody else in Bechtel that would 3 initiate such an investigation? 4 A Other than? 3 5 O Other than you and Mr. Johnson? ? "3 6 A I wouldn't'think so. C b 7 Q Then you are fairly certain that as a matter of fact M g 8 .there is ro plan to conduct any further investigation of the d j I { stress in the rebar adjacent to the cracks? Eg 10 A 3 I did not know of it as I said before. _5' Q a Mr. Dhar, do you know if the response to the Staff's f Questions with respect to cracks has been supplied to the NRC? 4= 13 g A My understanding is yes. E 14 g Q Did that response address the condition of the rebar? e i c 15 I h A My recollection is not very clear about the contents = ? 16 m of that response. C 17 ' d Q Do you have any recollection of what that reponse said E 18 'I m I about the condition of the rebar? C 19 { i j A My recollection whatever 1 can recall is that response 20 said that the stresses on the rebar is low because the cracks were 21 l j caused in the concrete when it didn't gain enough strength, and i 22 ) it also made the point regarding the self-limiting nature of the i 23 load. That is all I remember. 24 ! Q You say that the stresses in the rebar were low? 25 A Yes, sir. ALDERSON REPORTING COMPANY. INC. I

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3. _.. ; >;.. - n- .-x x-% h Q~*_:;::,~' h ?- k;. {}-?$f.5 g 102 l l i i 1! will mark it Staff Exhibit No. 2, D,ecember 17, 1980 -- I will I 2 also put your name on it -- and I~ will ask you the source of that 3 document? Where did you get that from? 4 A I do not recall where it is from. 3 5 Q Do you agree it appears to represent some kind of S i j 6l scheme of the remedy at the service water structure? R 7 A Yes, sir, it does. l 8 Q And on that scheme, is there any space between the top d z; of the pile and the bottom of the corbel? c 9 o g 10 A No. 3) 11 Q If there is any, it is occupied by the shim; is that a I 12 I correct? 4 13 ; A Yes. j =j 14 Q Do you have any idea how wide that shim is, or how deep C { 15 it is? = E 10 i A I do not. I am not sure whether it is drawn to scale W l N I7 = in detail or not. 18 l c d Q Did you indicate to me in your prior testimony in this l c i-19 l 5 . deposition that the top of the pile did not come in contact with m 20 ! the bottom of the corbel? I l I 21 ; A That is my recollection. ( l 223 0 Do you have any expl.anation for this schematic which 23 }i would appear to have the top of the pile -- 3 24j A This may be an analogous detail. Of course, there is 1 25.l a shim shown there without any damage. I ,j ~ I d ALDERSON REPORTING COMPANY. INC. l

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20 't A Not that I can think of; no. 21 : Q What effect did the surcharge program have on the 1 22 j-cracks? 23 A My recollection is that the cracks didn't go through j 24 !. any significant change during the surcharge process. I 25 Q You said they didn't undergo any significant change: { ALDERSON REPORTING COMPANY, INC. u

~ . > g p g._ a. ;; --a-- m._ 6 - 1.._ J.*^l 7 y --,-j- -f ,.. ;{,j# 2 q 108 -<,,v.. .-.,,,2 ;,. ~ 'l l< did they undergo any change? 2 A My recollection is that there was some change. 3 Q Did the cracks become worse or better? 4lj A By that do you mean did they become larger or smaller? 2 5 Q I will accept that; yes. n' 3 6 A My recollection is that some cracks were smaller. I do C 7 not know if any were larger or not. I do not recall if some ] 8 were larger or not, d d 9 z. Q You have a distinct recollection that'some were o h 10 smaller? E 4 II A Yes. m gg E Q But you don't know whether others were larger? { g 13 j g 7,,, i = I4 O Do you know where the cracks were that became smaller? ?* 15 h A My recollection is ' hat it is on the east wall. t f 16 Q Did the surcharge program aggravate differential d i 17 d settlement? i 18 ' A I do not recall. i- "g O Did you ever know? 19 < i 20 ' A At one time I locked at that data, yes, but right now t 21 ' I do not. recall. I 22 l Q Did the surcharge increase or decrease the amount of I i i 23 } stress on the pipes and conduits under the diesel generator 24 l i building? 25 i A Pipes and conduits are not my area of responsibility. t i .l i ALDERSON REPORTING COMPANY. INC. j

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......~ ~. (s.. 5_--- m. s -.. _.. -. = _.. -. 9 :: ~~Q I Q All right, sir, pleas ^e answer the question based on 1 2 any information you may have heard, or seen, or you got from any 3 source? 4 A I do not recall hearing anything about the increase of 5 3 stress due to the surcharge. a j 6 Q Do you have any opinion as to whether the surcharge a R 7 program would increase or decrease the amount of stress on the e a 8 pipes and conduits under the diesel generator build 3.ng? a d =i 9 .j MR. FARNELL: Objection to the foundation. He said I-10 j that is not his responsibility. E 11 g BY MR. PATON: (Resuming) 12 I Q Didn't you at one time express an opinion that the -T-13 g bends and elbows in the pipes under the ground had already been E 14 d overstressed? e 9 15 g MR. FARNELL: That is not necessarily connected with 16 g your previous question. 17 'y MR. PATON: I am very sorry about that. He said that E 18 he didn't have any expertise, and he has got it on the record =a" 19 1 j that they are already overstressed. l 20 BY MR. PATON: (Resuming) 21ll Q Did you make such a statement? i 22 l l A I recall in a meeting that I said that; yes. 23l g Q Okay, now do you have any opinion as to whether or not 24 1 the surcharge would tend to increase or decrease the anount of 25 ' stress on the pipes and conduits under the diesel generator .i i ALDERSON REPORTING COMPANY. INC.

' 'h~ -- ~ m. 7 pg 4.. k-; ~ T= .. c. % - 5d-ShJi.~:L: 3Y$'5:i. . 'C&li# 110 .. ~.....,.: .~ I building? 2 MR. FARNELL: Same objection. My objection is to 3 foundation. 4 A Do you want me to answer the question? 5 BY MR. PATON: (Resuming) a f0 Q Please? n R 7 t A If the pipe is restrained and the surcharge will deflect I the pipe more, then it could increase the stress on the pipe. dd 9 j Q Do you agree that the cracking in the diesel generator E 10 g building indicated overstressing? = 5 11 g A What stressing? Stressing of what, may I ask? d 12 z Q The structure? E 13 g j A Not necessarily. I do not recall. E 14 i, g Q Do you know whether any portions of the structures 9 15 2 that have exhibited cracks have exceeded elastic limits? = 16 3 A I do not know. e 3" 17 < Q Have you conducted any investigations to determine 2 a 18 = that? w 19 j A To determine whether -- 20 Q To determine whether any portion of the structures i 21 i l have exceeded elastic limits? Il 22 l-r A As I said before, we have done an evaluation of the 23 cracks which was presented to NRC. Other than that, we have not 24 done any analysis. 25j )_ Q Now, you supplied some information which I think you .h-ALDERSON REPORTING COMPANY. INC.

i ...w... j .- f-ij h-- hYfl Y N. T .,..g.,, - ~ ; m ig; -.1 - ce, o '. :...a. g p .. ~.,. _ g?#l2;_-S.: s_ 'y.m M.- ""l T - % 1-have referred to as the crack' study to NRC; 1s tnat correct? 2 A Yes, sir. 3' Q Did that include crack mapping? 4 A Yes, it does. 5 j Q Now, in that study, is it correct that you nowhere e O address any elastic -- no elastic analysis was made? N b 7 A To my recollection that is correct. 3 l 8 Q And in fact you have made no elastic analysis? d c 9 A We have made no elastic analysis; no. E h10 2 Q Do you have any plans to make such an analysis? = 5 II A At this time I do not know of any plan. 3 d 12 z Q Do you know the present estimate of the range of -3 13 j differential settlement which the diesel generator building can E 14 g safely withstand? u 7 15 g A I do not. T 16 3 Q Do you know whether anyone at Bechtel has that w 17 3 information? = E II < A To the best of my recollection we have done an analysis N 4 E l which will simulate future differential settlement of the -l A i 20 l building and calculated stresses. 21 lI Q You say you had done that analysis? i 22 ' l j A To the best of my knowledge. I am not familiar with l 23 j the details, but that 12 my understanding. 24 k Q Who would. have performed that analysis? i 1 A 'It would have been done by Shing Lo -- by one.of his t. .t .I ALDERSON REPORTING COMPANY, INC.

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112 -.; ~s.. 2.; + 1 I engineers. 2I Q Do you know if you have provided any of the results of 3 that analysis to the NRC? 4 A My understanding is no, we have not. 5 = g Q oo you know why you have not? 3 6 A Because the analysis is not complete yet. 1 n 3 7 Q Do you know when that analysis will be complete? m9 8 3 A My estimate would be in the course of the next couple dn 9 g of months. Og 10 Q Do you know whether part of the input for that analysis E 11 ' j was the fact that the building was cracked? = 12 j A As for my understanding, the cracking was not an input E 13 5 j into that analysis. E 14 'y Q Do you have an index of computer runs performed to E 15 g analyze the diesel generator building stresses? 16 ) A Does it include all computer runs? d 17 ' y Q I limited this to the diesel generator building. E 18 g A Does that mean all computer runs that we have done I 19 i 2 l from the beginning? 20l i Q And are you bearing in mind that the question said to 1 21 ; } analyze stresses? 22 l l A The answer to your question is no. 23 ' Q Are they listed, or are they in any way -- is there 24. ! any kind of record of cc:mputer runs made to analy e stresses in 8 25 ) the diesel generator building? i ,i ALDERSON REPORTING COMPANY. INC.

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I Q In the Civil calculation index -- that includes the 16 m l ai 4 17 computer runs? E 1 E 18 A Yes, the computer runs are part of the calculations. .= i b 19 { Q Mr. Dhar, I am going to ask you a cuestion which may 2M 20 i be unfair. If it is unfair'and you do not want to answer it, 21 that is perfectly fine, but we were provided an index to 22 h calculations from the Civil Group's ' files. Dr. Afifi provided l P-23 l that. Would the computer runs that I have been asking you about 24, as far as you know be included in that index? l-23 { A As I said before, these computer runs, once they are 1 .q 3 ALDERSON REPORTING COMPANY, INC. i

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4:-:-~ ~. 1 114 i 1 l' done, checked and approved, only then will they be included in 2 the index. As I said before, also, these calculations are in the 3 process of being checked and fina'lized. 4 Q You are indicating to me that the computer runs that I we are talking about, a lot of them are not indexed in this file? ,9 i { 6h' A That is right. Only the final ones would be indexed. 7 n; We might have done a lot of runs in this process. N 8 8 Q How far back in time would we have to go before we got a dd 9 g to those that were done, checked and completed, and indexed? Do I-10 i we have to go back two years for that, or three years for that? E 11 g A During the process of work, as we finalize calculations;, = 12 j we will get them checked. We will get them approved. Once they E 13 l 5 are approved, we will have an index, microfilmed, and go through E 14 ', the usual process. So it is a continuous process as we go along = 9 15 j once they are finalized. 16 l ~ j l Q Can you give me a rough estimate of how far behind you d 17 j are? In other words, when you talk about those that have been ca 18 l = l finalized and indexed, are we talking about six months ago, a l I" 19 i g l year ago, two years ago? 20 I j MR. FARNELL: I don't think the teco "behind" should be 21 i i

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MR. PATON: Strike the word "behind." 23 BY MR. PATON: (Resuming) 24 4' 4 0 In the normal course of business, what amount of time 1 25 j is there between the present time -- l .d 3 ALDERSON REPORTING COMPANY. INC.

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e I J22;-i?_^ 2: hhfdg n-,,'i.{i.fi"# b . x, c p.yg_;,. e;. g 7 a-s. . -: +,.. .x 1 A Yes, sir. 2 Q Now, with respect to the computer runs that have not 3 been approved, indexed, and filed, etc., is there any record that 4 ^ would enable you to have access to those computer runs, or are 5 l they just laying around the building somewhere? I A If they are not finalized, they would probably be with H A 7 { the originator, j 8 Q-There would be no piece of paper anywhere that would dd 9 g lead you to all of those unapproved computer runs; is that lP 10 correct? g 11 g A That is' correct. 12 MR. PATON: How about a five minute break? 13 E (Sreak. )' l 14 g BY MR. PATON: (Resuming) g 15 g Q Mr. Dhar, what soil parameters do you need to perform 16 a seismic analysis as per example at the diesel generator 6 17 < g building? E 18 g A We need to know the effective shear wave velocity of 19 I l the foundation material to do a seismic analysis. Other 20 l parameters are available with us in the Civil Group. 21 l Q What other parameters would you have to know besides 22 ! ! shear wave velocity? I 23 A We need to know the building configuration. 24 i j Q These are soil parameters? 15l / A Soil parameters, yes. We would have to know the shear ALDERSON REPORTING COMPANY. INC.

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I Q How do you calculate the damping ratio? h 10 A I do not remember the formula for that. j 11 3 Q Whose responsibility is that? d 12 z g A This is done by the Seismic Group Leader in.my Group. 5 13 Q Who is that? E 14 I a a l A Chuck McConnell. 2 15 l w= Q He works for you? 16 3* l A Yes. ( 17 : Q Do you need to know the shear wave velocity profile for 5 18 i c different soils at different depths? I 19 1 = i M A Either we have to know that or the effective shear 20 i wave velocity. 21 ' h Q By effective shear wave velocity, do you mean you would 22 take an average as opposed to knowing what the shear wave velocit4 was' at the various depths of the soil? A If that is supplied, yes, that would be one way of doind it. ALDERSON REPORTING COMPANY. INC.

2 .G,fnj_2b.r'; = ~,--$. h;,. * ~.' ~5.~ :: 118-.7J . = y g.gm. ' W - m- ..,., m . -s,. w .e -e . a... Q Do you need the soil stratification profile? j i A That would be calculated from the effective shear wave 2 3 vel city. Q Do you need that information in order to do a seismic 4 = 5 analysis of the diesel generator building? l 5 1 A The way we have performed this analysis, I would need 6 I -l 7 to know the effective shear wave velocity of the foundation g medium or the shear wave velocity for different layers. 9 Q Which way did you do it? 10 A My recollection is for the diesel generator building i j gg we have the shear wave velocity for different layers, and the-l { 12 Civil Group calculated the effective shear wave velocity. 1 x 2 13 Q Do you need to know the strain dependent modulus and E l 14 damping? 1 I $j 15 A The shear modulus which is given to us, we consider 3 3.- 16 that effect. m g 37, Q Do you get that from Dr. Afifi? l g jg A Dr. Afifi, yes, sir. b 19 l Q The value of shear modulus varies with strain, does it X 20. not? ) 1 21l A Yes, sir. l 22 i Q How do you take that into account in the design -- the 23 fact that the value of shear modulus varies with strain? l 24 ; A This input is provided to us by Geotech. i 25J Q Do they give you a plot of shear modulus versus strain? i i ALDERSON REPORTING COMPANY. INC.

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I8 A I would consider that either Chuck McConnell-would know, 3: s II l 'or he would know the person who would know. K 20l 0 And he works for you? i IIl A He works for me. 22[ Q Can you tell me how the soils in the diesel generato. 1 1 l. 23 l building -- how were the soil parameters to be used in that seismic 1 24lanalysisobtained? 't MR. FARNELL: Which seismic analysis? J 'l ALDERSON REPORTING COMPANY, INC. ~

~ ~' ' ~ ' w, _2.,-Y;'?j'#_.. .g,;-.3 . a ~ n, *q -%- w.- x. 4~. = l I 1 Y _ :'.;:. T & ~? g 7;4 120- .; w. i I BY MR. PATON: (Resuming) 2 Q We have been talking about a reanalysis of the diesel 3 generator building subsequent to the removal of the surcharge. 4 How did you determine the soil parameters to be used in that s 5 analysis, and please address the fill and the till? E 3 6 t A I do not know the complete details. = I O Tell me any details you do know? n 3 8 a A My understanding is that some insitu shear wave dn 9 j velocity measurement was done by Professor Woods. It is my c h 10 g understanding that was the basis for the shear wave velocity E 11 g being utilized in our analysis, i d 12 i j Q Did the seismic survey which was completed to 5 13 i establish shear wave velocity in the soil under the diesel E 14 p ! generator building show shear wave velocity as low as 350 feet E r 15 ' per second? 16 g MR. FARNELL: Would you read that back? C 17 i d (Record read. ) b 18 = A I recall hearing something like that. a" 19 j BY MR. PATON: (Resuming) 20 l Q What is it that you recall hearing? 21I A In one case shear wave velocity was lower than 500. 3 22l Q In one case only? To your recollection was there only 23 one case where shear wave velocity was lower than 5007 24 t A That is my recollection; yes. I 25 lj Q In your opinion does shear wave velocities in soils l .i l ALDERSON REPORTING COMPANY. INC. l

_.th 57.~..'((. f;5J C ' ~T-- $- [.b 4 E-MW ~.8 $4 m q y[ @ y e.y ch NN., i3LDiM 7 ,u n - ~ w :.- p y .m 121 a _. ,.z W; _ --c--- \\ ..n. - 9,.,dll~- r m ; s..-. -- : - t..r ;. .--n- ~,..: -, - u: t-~.--- h_ a ..~. . -s.v,. x h n. " 1" deperid on how stiff or dense $.ke" soil isi' 2 A I cannot answer that question. 3 O Do you know if Bechtel had adopted shear wave velocities 4 of 1350 feet per second before surcharge? 5 ~ j Please clarify your question. A e i 3 6l Q Okay, I will clarify it by repeating it. P R 7 A What do you mean by before surcharge? Kl 8 Q Before the surcharge program at the diesel generator e d 9 2. building? ol 10 A Do you mean by that the initial analysis? ..5U Q

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1 I1 [ A That is my understanding. It might not be exactly 350; R g 13 it may be somewhere around that. m E 14 g Q Do you know that after the surcharge was removed, you ~ 9g 15 ) obtained measured ranges of shear wave velocities substantially 16 l 3 ! lower than 1350 feet per second? 8 i 17 \\ A That is my understanding; yes. ~- = 18 = Q From that information -- from *.he comparison that we w l j 19 llhave just discussed, can you make any conclusion about the 1 1 l 20l: effectiveness of the surcharge in making the soil more resistant 21 '1 to additional settlement? 22 i l 1 A No, I cannot. I 23 Q Is that because that is not within your area of 24 ! exoertise? 25j* A That is one part of it; yes. i'1 ALDERSON REPORTING COMPANY. INC. -y 3

,Ng t** ... 7 y_ -- ..,]e'** ' * * =4 y,5[ w.. l n ~ . u. :.. 1; Q What is the other part? 2 A The other part is that before we measured the shear 3 wave velocity, Bechtel assumed a lower limit shear wave velocity 4, of 500 feet per second as written in response to a NRC Question. 5 h You say Bechtel assumed a shear wave velocity? Q ] 6! A A lower limit of shear wave velocity of 500 feet per R 7 second. i A a, Q When did you do that? d d 9 . g. That response was submitted, I think sometime in '79. A l 10 Q You said that you assumed a lower limit of -- =] II A Five hundred. 4 y 12, Q What was your upper limit? 4 l 5 I3 i A In that response we said that we would consider the = 14 upper limit the same as it was used in the original analysis. ir I I5 j Q Which is what? 2 f 16 A Around 1350 or 1360. d l l II Q Can you perform a seismic analysis of the diesel l 2'* II generator building according to the state of the art requirement c b I' ! without knowing the relationship of strain with shear modulus? M l 20 MR. FARNELL: Will you repeat that, please? 21 (Record read.) 1 22 MR. FARNELL: I make an objection to the state of the i 23 are recuirement. That is very vague, and therefore, I object as 24 : to the form. s i .i i ALDERSON REPORTING COMPANY, INC. I

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.w ~~ @ =,- Q,'.....,;,-{:Qjy ~.. ,,.. :.m. MW -x .~~ -i :l.T.hQ~.: a . n.. 2: n-1 A A duct can be there for many reasons. 2' Q Are there any ducts -- whatever you mean by ducts -- 3 do you know whether there are any ducts in the foundation 4 of the diesel generator building? = s A There are ducts for electrical conduit if that is what !] 6 you are referring to. i 7 Q Are there any other conduits in the foundation of the 4l 8 diesel generator building other than the pipes and ducts that you dd 9 have just referenced? 10 A None that I recall. y = 3 II Q Do you know where these pipes and ducts are located in a f 12 the founcation, and by that I mean at what depth? r2 I3 i A I do not recall the exact depth. 14 Q Have you been involved in any analysis of stress on W is 5 3u,1,4 pip,,, l s E I8 A My reellection is that some analysis was done for the w l h 17 ' circulating paper pipes. ~ E 3 18 Q My question was what involvement did you have? Were you C II l M \\ 1 involved in that analysis? 3! A I don't recall. I might have reviewed some parts of i 21 l the analysis, j 22 i Q Is Mr. Lo in charge of that subject? 23l1 A My recollection is that this analysis was done sometime 24 ago, and it would have been -- Mr. McConnell might have knowledge l I ' 25 i! of that analysis. j i .1 i 1 ALDERSON REPORTING COMPAN,Y INC. l

.w.... {f ~~ - ~ - ~20 pap;-- -an,.....-. .,.m _.m..,..... t,g ,1.,. c. -m .,. ~ ~ A4 . g-~ 94' \\ }., % ~. ... +.. m ;l l Q Okay, you say he might have;- do you know whether or not 2l he does have? 3 A I cannot be 100 percent sure. 4 Q Is there still to your knowledge some dispute between 3 5 N the NRC and Bechtel with respect to the stress on the pipes under k 6' the diesel generator building? e 2 7 A I recall there may be a question on the duct banks in a the latest round of questions we have gotten from NRC. d 9 g Q Referring to your previous statement at some meeting E 10 g that you attended where you expressed the view that the bends = 5 11 g and elbows of some pipes may.be already overstressed, do you 4 12 g still have that opinion? 2= 13 i A I was merely reporting what I was told regarding the E 14 state of stress of these pipes. -2 r 15 2 Q You were told by whom? .3 16 ! 'l l A Sy the Plan Design Group, d 17, a Q Who is that? E i

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E I do not recall who exactly told me, but it could be 19 - j l Mr. Tulloch. 20 ! O Do you have any reason to believe that statement is no 21 i j longer true? 22 { 1 A No. 23 l 0 Would you call the analysis of stress on the pipes, is 24 ' that the responsibility of a mechanical engineer? 25 A Yes, except the seismic stress in the buried picing is 4.j 1 ALDERSON REPORTING COMPANY,INC.

~ .T . x,. ', inG25D ;.-: c@y;d.g ' .;,c-:;-;jyr 1; p _% ei Ai -? ? .... x - s 126 /- a.; a. .,.m I the responsibility of the Civil Group. 2 O Is the seismic input your responsibility? 3 A The seismic stress in the buried piping is the 4 responsibility of the Civil Group; yes. 5 g Q Are any of the pipes, ducts, or conduits under the a j 6; diesel generator building Category 1 pipes, ducts, or conduits? C R 7 A Under the building? K 8 Q In the foundation of the diesel generator building? - d d 9 z. A I recall that some duct banks are classified Category 1. Cy 10 Regarding piping, I do not recall where the break is between 3 II Class 1 and Class 2, but there may be some Class 1 in the a j 12 vicinity. 13 Q Do you know at what depth any Class 1 piping or ducts a i I4 or conduit are in the foundation under the diesel generator Ej building? 15 z y 16 A I do not remember exactly; no. W d

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17 l Q In the excavations for placing any of the pipes, ducts, E i 3 18 ' and conduits in the foundation of the diesel generator building, e-E I' ' s do you know any of the bedding and backfill details of those 4 M j 20 l excavations? 21{ A I do no t. I 22f Q Within the secpe of the responsibility of the section - - 23 ' are you the head of a section or group? i M A I am the head of a group. 1 25 Q Civil Group? ALDERSON REPORTING COMPANY. INC. l

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9 A At one time I have. f y 10 Q Do you remember any of those details? = 3 II A What I remember is that there is sand backfill in and a { 12 around the piping, but I do not remember any other details. 5 5 13 Q Is your present responsibility with respect to any E i 14 pipes, conduits, and ducts in the foundation of the diesel W 15 5 generator building limited to seismic stress? m si I' A Seismic strass for the buried piping, w h II l Q And that is the extent of your responsibility -- this II input with respect to seismic stress? E II g A Seismic stress with respect to buried piping is cart 20 of civil responsibility yes. 21lI Q My question is: Is that the extent of your i 22 responsibility, or do you have any other responsibilities.iith 23 l respect to pipes that are under stress? 4 M} A Tor which category of pipe? 25 3 All categories? i 4 i ALDERSON REPORTING COMPANY, INC.

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. a " b J h y ; ;.-: y, ; j g ..... -'.,,- % u' 12E s v. .., t;. I' A For the piping like sewer piping, storm drains -- 2 Q I am talking about buried pipes? 3 A Storm drains would be buried. For concrete piping, 4 that would be Civil Group's responsibility. If it is steel 5 piping and they belong to an ASME class, then it would be' Plan 3 0 Design Group's responsibility. g b 7 Q Without telling me the responsibility of other groups, 1 A 8 tell me the responsibility of your group with respect to buried d 9 pipes, ducts, and conduits other than seismic stress? What is I h10 the responsibility of your group? II ' = E A The responsibility of our group would b,e -- I believe a "E 12 that some of these pipes should have been our drawing -- I mean 4 l 13 'l Civil drawing. I do not recall which one of them. Even some of h I4 the Category 1 may show up on the Civil drawing, and we would E i g 15 I provide the burying details. For pipes which are not the z j 16 responsibility of Plan Design, we will route them and we will e i .h I7 procure them. e 3 18 l 0 Procure them? E 19 l j A Write specifications for them. 20 I Q okay. l 21 < A And for those pipes we will be responsible for the l l l 22 1) installation also and providing construction support and 23 4' installation. 24 i Q When you provide construction support for installation, t 25 do ycu tell them at what elevation to insta11'the pipes?. J' .l ALDERSON REPORTING COMPANY. INC.

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~* W MR$6Nif h M' ~ ~a ~ ,q.m g .,th g ,j _;.:. . v 2., 4 .na .=~w.- .~- f_^_ x s .A L j A I do not know whether this information is in the Civil 1 drawing or the Plan Design drawing. Are you asking about the 3 Category 1 piping? 4 Q I am asking you about pipes in which you provide e 5 construction information. You indicated that there are pipes n 3 6 which you provide constructional information on the installation a 7 n; of the pipes, and I asked you did that include intended elevation? n 3 8 A If it is our responsibility to provide the elevation, d:i 9 g the elevation will be given on the drawings. o (; 10 z Q Do you know whether the pipes that were in the 2 11 j foundation under the diesel generator building were installed d 12 j initially at the intended elevation? -t E 13 E A I do not know. 3 14 l Q Do you know in fact that some of the pipes were E 15 j installed at elevations other than the intended elevations? 1 ~ ? 16 A No, I do not know that. G 17, y Q Mr. Dhar, I show you a three-paged document that has l 5 18 g the words " Teletype Message" at the top, and I will mark this t 19 i l Staff Exhibit 3, Dhar, December 17, 1980, and I will direct your l 20 ' attention -- you can read all of the document you want -- but I 21 will direct your attention to the paragraph numbered 1 below the 22 ! l l middle of Page 1. I will read that paragraph. It says: "THE RESULTS OF THE YARD PIPE ANALYSIS HAVE NOT l 24 i' SEIN FINALIZED, BUT BECAUSE THE EXCAVATION WILL BE 25 4 4 MADE, THE LARGE (21-Inch) DEVIATION FROM DESIGN .,1, 3 ALDERSON REPORTING COMPANY. INC.

-= . L... sqc. i. : h -~kn- , 4.;s. m...a-l T.s Q.IT ; n1.: _-- y.3 . " '{.,].}- - l# 2 4 m:~.. I ELEVATION SHOULD BE CORRECTED. THE FOLLOWING PIPES 2 SHALL BE REBEDDED." 3 Then it lists the pipes. I ask you te look at that 4 document. My question when you have had a chance to review the 1 g5 document is does that refresh your recollection as to any j 6 deviation in the installation of the pipes? K E 7 A To some extent it does. I cannot recall the whole of 1 3 8 the incident, but sorae part I can. d 1 9 Q What part can you recall? Y .'f10 A That this was for the condenser line, and then there t l 5 II was an apparent discrepancy between the elevations, and this was a ( 12 4 the instructions to correct that. 1 g i l I3 g Do you recall whether there was any other deviation in !M the elevation of installing the pipes other than the one mentioned W is 5 e3,,,, a i d I' A I do not recall. e h II ' Q In your opinion is"there any significance to the fact E U II that the pipe was installed 21 inches from the elevation from c* 19 l j which it was intended to be installed? 20) MR. FARNELL: Significance for what would be my i 21 i question.- 22 l MR. PATON: It is not my question. 23 ' A I consider an error'has. been made. { 24I l J BY MR. PATON: (Resuming) "l Q I didn't' hear that. r i i o' 1 ALDERSON REPORTING COMPANY. INC.

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' :T ' - C 1 T - m i?i W A I.would cons.ider that an error had bedfrmade. 1 2 Q Does that complete your answer? 3 A Any other thing would be guessing on my part. 4 Q The significance to you of the fact that a pipe was 5 installed 21 inches from the elevation that it was intended to 0! be installed is that an error was made? R R 7 A Yes. E Q Does the fact that a pipe was installed 21 inches d# from where it was intended to be installed introduce any 10 j uncertainty in your present determination of pipe stress? I 11 MR. FARNELL I don't believe he said he makes a 12 3 determination of pipe stress. 4l 13 A I am not responsible for pipe stress other than the e! I4 seismic stress. k 15 (( Q Would the fact that a pipe was installed 21 inches a from its intended elevation affect in any way your seismic t{ 17 stress analysis of the pipe in the foundation? a E= 18 A Depending on where the pipe is located, it may or may E 19 ' j j not affect it. 20ll Q Tell me how it could affect it? 21 h i A If we are using the soil modulus and the pipe is i 22 i i located in a particular layer, and we use the corresponding 1 23 ' soil modulus, and there is a 21-inch error or a similar error 24 I made and the pipe gets located into a different layer with a 25 different modulus, then. of course the modulus would not be l -j ALDERSON REPORTING COMPANY, INC. i

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u ; s,. r. A . ~.. .s " bl A"'id.~,,. I. 'De ~'P /; - overstressing the line, did you predict an expected settlement i i l 2 of that condensate line? 3 A We based the calculation on the estimate of settlement. 4 Q How did you do that? How did you estimate the 5 settlement? f0 A We took the estimated settlement which I told you I 7 before as the base. 8 0 If you told me before', I'have forgotten. How did you d* 9 estimate that settlement? 10 j A We didn't estimate the settlements this settlement I 11 as we understood was estimated by Professor Peck to be between 1 12 6 and 18 inches. 13 y Q Do you have any idea how Dr. Peck arrived at the l15 I# figure of 6 to it inches? A

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16 g Q Mr. Dhar, I show you a page which is designated h* 17 ' d rig.19-1 from Vol.1 of the 50.54(f) Responses dated April 24, l 18 1979 and ask you if you can tell me what that is? 19 I ) MR. FAR!!!!,I,a I.et's go off the record. no (Discussion off the record.) 21 ' A My recollection is that this is a survey pipeline 22 profile by CID. 23 ' Q Tell us very slowly again what it is? 24 1 ( A CID, Goldberg, :oino & Dunnicliff. 28j O That is a survey. Okay. Can you read the numbers on

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~ ?' n,. >3. g z;p.2 ..X-l-7 h- " ..._,..x .~~ ~ -u. 2 -[';} g _-~&j; _. ; _.?:.~'Z;; 136 . J, = = ~ .. ~ ~. :-., ;;. l I i 1l l that? I have scme difficulty reading that. Can you read those 2 numbers? 3 l A Any particular number? 4 i MR. PATON: Off the record. = 5 j (Discussion was held off the record.) j d 61 SY MR. PATON: (Resuming) -n R 7 ~ Q That you indicate is a survey of pipes. Are those g 8 8 pipes under the diesel generator building? d6 9 A As seen in the key diagram here, there is one line y M 10 E under the building. The others are around the building. E 11 Q How many different pipes are shown on that figure? i d 12 i A A total of nine figures are shown. 3= 13 E Q Can you tell from looking at that figure whether any E 14 of those pipes are overstressed? 2_ 15 i A No, sir, I cannot. 16 Q Do you know from any source of information whether any ~ ' 17 I g y j of the pipes represented on 19-1 were in fact overstressed? E 18 ~ E '.NUL. FARNELL: During the time of the surcharge, or now? 19 : e i a l SY MR. PATON: (Resuming) 20 O Let me ask you this: The date on that is April '79? 21 j A Yes, sir. l 22 l j Q So that is before surcharge; is that correct? Before 23 ij y the full surcharge was applied? 24 j 1 A I don't think so. My recollection is that-that would 25 i not be correct. l ..( I i ALDERSON REPORTING COMPANY, INC. l

...n... ... #wW-3..ag*?&....::-:. ,...,..... ~.-: -v5.-+.nn 3:.nJ. -=w x. - m ' ' "" ejt.tv.;-ty g g @ %. M i,w _. p gg..,.,,y;- W?. t.Q**"" K'"'D.74. c? ..,,n. ._.p , -.. ;.- r" ' T : 3 }'7 ......I_<= m:';. ;:.,- n - v. s.- - ~ w-n r; _._..n__..a. g:- ..'.o. ~.,-->,..n ? :- --. - - - N.s J ; >.. ? ..,,,,I' ; When was the full suscharge applied? ." ~ ' Q l T' A f' ~ " ~ ^ t 2 A I do not recall, but I would think the end of '78 or { 3 early '79. 4' Q Does that figure -- what'is the date on that figure? 3 5j April what? E l j 6! A April 24. n*" 7 O Would you understand that figure to indicate that was Kl 8 the condition of those pipes on April 24, or can you tell from r3" 9 that figure? 2og 10 l A No, I cannot tell from this figure. I would assuae z 1 l = 'd I I ' that it 3 is no later than April 24. "E 12 Q I think we can all agree on that. Okay, does that g 13 figure give you any indication as to the time element it is n I4 j i supposed to represent? In other words, that is the condition r: I 15 i of those pipes on what date? Can you tell from looking at that g = f 16 ! figure? 2 i d 17 'g A No, I cannot without looking at the text. ~ i I XR. PATON: Let's no off the record. ,i P i n g9.. (Discussion held off the record.)

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20 $ ) BY MR. PATON: (Resuming) I I 21 t Q Describe the procedure and the instruments used to 3 22 aj establish the profiles shown on Fig.19-l? i 23 5' i A I do not know the complete details. i j 24[i l Q I am not asking you for the complete details: 'I am 25 ~ asking you in your, expert knowledge can you tell me how you go j '] ALDERSON REPORTING COMPANY. INC. 1

. _.m ...g.g,. N ~ O - . ~. K - S: = ?: C _h: *7h?Ei,. ' 3:.. ".*f3&L-!'" v. a .n 1 about establishing such profiles? i l 2 MR. FARNELL: You asked for his expert knowledge, and 3i he told you that he is not an expert, but if you want his opinion, 4 fine. i 5 MR. PATON: He is also responsible for seismic stress. 9 ] 6i A The first thing I would like to say is that I am not I R 7 an expert in this sort of measurement. That is why we hire GZD Al 8 to do the work. d U 9 z. BY MR. PATON: (Resuming) 10 Q Okay, you say "this sort of measurement"; what do you i5 II mean by that? 3 I I2 A Underground pipe profiles. 3 13 O Do you have any idea how that is done -- how they get l = 5 I4, those profiles? ? g 15 A I have some idea how it is done. g 16 Q Tell me what your idea is? 2 i h I7 A I understood that GZD have a bug -- E 3 I8l1 Q A bug? E I 19 ' 2 A ~ 20 !. A bug which travels along the invert off the pipe, and n they have instrumentation which records the difference of 21 I i elevations between the bug and the reference elevation. t l 22 -} Q You say it travels along the invert off the pipe? Is 4 23 ) that what you said? j What does that mean? { 24 i J A That means the bottom of the pipe. [ l 2$ 'I 1 I O Does the bug travel on the inside of the pipe or outside? .i, I l

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. 3 ;;c.p. - 3: . ;:=- .'.x .a n r- .+ ; :;.:; q _;_ y ~~ y. =;- g. gu' a. I Q This method that you have that Mr. McDonnell has 2 submitted to you, you now have it before you for consideration? i 3 A Yes. 4 Q Is it in the documents that were on your desk? 5 y A It was one of the recent ones so I would expect it e 6 to be on my desk. R 7 0 would you look at those documents that you have M] 8 presented to us and identify which one that is? d" 9 ~. MR. PATON: Let the record show that Mr. Dhar has just i" 10 'j handed to me six pieces of paper. The first one has printed at = II the top " Calculation Coversheet." The second page is entitled a 12 E Calculation Sheet No. 1, and continues through Calculation Sheet 5 13 No. 5. I will mark these sheets -- you have no objection to I that, Mr. Dhar? E i 0 15 s THE WITNESS: No. = 7 16 ' R MR. PATON: I will mark these Staff Exhibit 4, Dhar, d 17 d December 17, 1980. = 5 18 .ll-1 BY MR. PATON: (Resuming) 19 j j Q Do you know prior to the application of the surcharge 20{! whether there was an evaluation of the consequences on buried ? 21 I pipe? Did anyone evaluate what the effect of the surcharge l 22 } l would be on the buried pipe? i' 23 ' l i A Except for the one that I mentioned for the condenser 1 24 2 l line. Except for the one I mentione'd for the condenser line, I 15 r j do not recall that any other analysis was done. 4 l .l . l ALDERSON REPORTING COMPANY, INC. l -,,. - + y

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1 2 impact on other pipes other than the condensate line? 3 MR. FARNELL: Read that back, please. 4 (Record read.) 3 5 MR. PATON: Is your point that he said he didn't know R+ 3 0 it.was done? i R 1 7 MR. FARNELL: Right. N l 8 MR. PATON: I will withdraw the question. dd 9 BY MR. PATON: (Resuming) ,zoy 10 0 Do you believe an analysis of the possible impact of Z 5 II the surcharge program should have been performed on the pipes a I f I2 I other than the condensate pipe? 4 5_ 13 A In my opinion, unless there is a contraint in the 14 pipe as in the condensate line existing -- pipe being made of I 1: 15 ' stainless steel and being very ductile in natura -- there is no f 16 l great danger of any significant damage to the pipe due to a 17 3 settlement, i: E 18 Q Did your answer contemplate that before the surcharge w" 19 8 j was imposed, the pipes were already under some degree of stress? n 20lI A If that profile was done before the surcharge as it i 21 i looks like it was, there was some degree of stress in it. 22 :: Q Regardless of Fig. 19-1, do you know whether the pipes I 23 were under some degree of stress prior to the surcharge? 24 r ( A If I didn't have that information with re in 19-l? 25I Q No, I am asking you to ignore whatever you have learned I ALDERSON REPORTING COMPANY, INC. t l

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from looking at your Fig.19-1, and ask you independent of what-2 ever information you get from 19-1, didn't you know prior to the 3 surcharge that the pipes under the diesel generator building 4 were undergoing some degree of stress? e 5 j l A My recollection now is that this profile was done 3 6 i before surcharge to compare before surcharge and after, and R 7 j looking at the' profile, it is apparently there was some stress 8 8 in the pipe.

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y Q Has there been differential settlement of some of 6 10 i these pipes that are reflected by Fig. 19-l? 5 11 A Is there some --

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12 Q Does Fig.19-1 illustrate differential settlement with E 13 1 E some of these pipes? l 14 l t l A Yes, it does. 2 15 ; s j Q Does differential settlement cause overstressing of g 16 l w the pipes? y 17 : d A If the differential settlement causes curvature in the c I w 18 E pipe, then the stresses are introduced in it. I 19 ' 5 l Q Are there examples on Fig. 19-1 where differential 20 : settlement has caused curvature of the pipes? 21 ;h A Yes, there are. 223 j Q Have you conducted any investigation to determine the i 23 1, 24 ; aucunt of stress in those curvatures? .i A

io, I have not.

It is not my area of responsibility. 25 i O Do you know whether anyone at Bechtel has conducted .A \\ i ALDERSON REPORTING COMPANY. INC.

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~ m :@:s (np h..; c...; = w.1..,j N. ..y ~. _ - - - f: ^"~ such an investigation?~ l 2 A It is my understanding that Plan Design Group with their staff are performing an analysis., 4 Q They are doing it now? = 5 g A It is my understanding that they have been doing it 8 6 '79 also. n i 7 Q Do you know whether Bechtel or Consumers submitted to al 8 the NRC any evaluations of Category 1 pipes in the vicinity of d:i 9 g the diesel generator buildi'ng before the surcharge? 6 10 I A I do not know for sure. = E 11 j Q Do you know if any more recent profiles have been taken d 12 i of the pipes in the vicinity of the diesel generacor building, E 13 E and by that I mean more recent than Fig.19-l? E 14 [e A My recollection would be that some profiles were taken 2 15 g after this. + 16 l Q Tell us what you know about that? When, how many, etc.h N I7 l 5 A After removal of surcharge, some of these pipes are 18 ll C= profiled to compare the effects of surcharge on them. g C 19 i ~ O Who did that work? 20 A That was done by GZD. l 21 j j Q Did you review the profiles that they made subsequent j 22 lj to the removal of the surcharge? 23 ' I have looked at' some of them. I recall looking at 'l ~ a 3 some of them. 25 i i Q Did you reach any conclusions? ALDERSON REPORTING COMPANY,INC. ~ -s p .4 ,w,

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1 A My recollection is that there was no great significant 2 difference between the two. 3 Q No great significant difference? 4 A

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~ g 5 0 Was there any difference? 2+ 3 6 A I do not know. There may be. R CE 7 Q Tell me what you know. Was there any difference? 3] 8 And please don't -- it doesn't help to say there may have been. dd 9 z. Do you remember whether there was in fact any difference? og 10 A I don't recall the exact details. I h 11 Q No. I didn't ask you about the exact details. 3 y 12 I MR. FARNELL: I think he is saying he doesn't. 13 MR. PATON: Fine. If he doesn't know, he doesn't know. m i E I4 ' I want to know whether he knows or not. $j 15 l BY MR. PATON: (Resuming) .r a[ I6 Q Do you in fact know whether there was any difference 1 II ! in the profiles before and after the surcharge? E I 18 l A I do not recall the degree of difference between the i-19 9 two. i M i 0 Q You recall the degree of difference. That tells me 2I. I there was some difference. Was there some difference? i 22 4 e A I cannot be absolutely sure of that. l 23 Q Do you know if the profiles that we made after the i surcharge was removed has been submitted to the NRC7 1 25l A I do not know or sure. t. 4 I i ALDERSON REPORTING COMPANY. INC. I

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.%. r. 3.. fcIN,A[^Y.? -' ~-. -r ' -., M. khh.hD'hr k N fbNI b "O ?~<Q.f5iX-.T57.:. -r g. .- m-.. .._,,.,_..,,,..,..,.,,.,,n (,. _.., c 1,.. ....... u., s..,,. ..~ A4 ..n. 4 g,',_ cq c.==2 ~. un Fig.19-1 I direed ' our atten' tion tS. Pipe Profile 2,l~-P~= ~ f i 1 2 26-OHBC-54 which is the one at the bottom of the page, and ask 3 you whether you would agree that that profile indicates 1 4 approximately 9 inches of settlement before the full surcharge e 5 was placed? L.. ] 6l MR. FARNELL: Read it back, and I think this poor R 7 little chart will speak for itself if left alone. This chart l 8 which is difficult to read which came from your client would, if d si 9 it could speak for itself, but I am asking Mr. Dhar his knowledge z oy 10 of the chart. z II l A It is so difficult to read I can't be sure. I can't 3 N I2 tell you. i = i g 13 ! MR. PATON: I want to make sure that is on the record. = mii I4j. Will you read back his answer, please? -C i I 15 g (Record read.) = E I0 ! MR. FARNELL: Just for the record, was this the w i !5 I7 ! original document that we submitted to the NRC?

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l y 18 ' MR. PATON: Yes. My response is to my knowledge w U! 'of the many copies supplied to the NRC, to my knowledge this is M i 20 j one of them. I have no reason to know that this has been I 21 : reproduced or reduced. I 223 All right, sir, may I see that again? d 23 *j BY MR. PATON: (Resuming) 94 I Q Your answer is that you are not able to determine that i i 25 ' from the chart? i t j I

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_ = . :~, ;,. A. *3 = - .. ~.M - SE*E ' "T: ::: T. h. .e. I A I didn't complete my answer. 2 Q Fine. Please do. Do you want to see it again? 3 A I cannot read this so I cannot tell from that. 4 Therefore, since I cannot read it I cannot determine between 5 what point that 9 inches in the Question is applicable. 3 6 Q Mr. Dhar, do you have any knowledge as to the extent ,n R 7 of the pipes in the vicinity of the diesel generator b,uilding n had settled prior to the imposition of the surcharge on the dd 9 j diesel generator building? h 10 z MR. FARNELL: I think that has been asked and answered. =2 11 g BY MR. PATON: (Resuming) d 12 iE Q Would you answer my cuestion? d 13 i i j j j A If this chart represents a profile done before the E 14 d surcharge, this chart wouldn't give the information. 2 9 15 j Q What.js your conclusion with respect to the chart? ~ 16 i j Can you tell whether that is a profile of the pipes before !'ll 17 surcharge or after the surcharge? 18 MR. FARNELL: = E 19 You are asking for his understanding? g MR. PATON: Certainly. I have been sticking to his 20 l understanding -- nobody else's understanding. 4 21 i [ A My understanding would be -- I would have to guess, 22 i and my guess is that it would be before the surcharge. 23 SY MR. PATON: (Resuming) 24 ? j Q Independent of Fig.19-1, do you have any knowledge of 25 j the extent of the settlement of the pipes prior to surcharge? I ALDERSON REPORTING COMPANY, INC.

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showed some settlement. 2 I 3 Q other than the condensate line? A other than -- to the best of my recollection, if this 4 e 5 figure represents the data before the surcharge -- 5 Q Do you know why GZD was asked to make these profiles? j 6, g 7 A So that Bechtel can evaluate the condition of the 3 underground piping. d:i 9 Q I may have asked you this, but I will ask it again. I 10 With the exception of the condensate line that you have discussed, E I 11 did Bechtel conduct any analysis of the pipes in the vicinity of <3 y 12 the diesel generator building to determine what effect the 2 5 13 surcharge load would have on those pipes? E i l 14 A To the best of my recollection, no analysis was done. t: I j 15 Q Do you expect additional settlement of the pipes in 2 16 i the vicinity of the diesel generator building? - .3 1 l i 17 i MR. FARNELL: During what period? 5 i 5 18 MR. PATON: In the future. E" 19 A I do not know. I 20 l BY MR. PATON: (Resuming) 21 ! Q You don't have any opinion as to whether the pipes in i 22 j the foundation of the diesel generator building over the next 23 ' four years will undergo any additional settling? 1 24 g A If you want to know my opinion -- 1 25 1 Q Yes. s f s ALDERSON REPORTING COMPANY. INC. l

~t '+... .a- % d Q q~57;.:--y -?gg ' +.3..,s aik. x-.. ~ %+ ,,. m e-n ~.. n ,u l I A -- I would think there would be some settlement. 2 Q Do you have any opinion what effect that settlement 3 will have on the stresses that are now in the pipes? 4 A Without analyzing the coridition of the pipes as they e 5 g exist now, I cannot answer that question. 5 6 Q Can you say positively that additional settlement will 5 7 aggravate to some extent the stresses that are now in the pipes? n 8 8 a MR. FARNELL: I think he said he would need an analysis, d

s 9

g MR. PATON: My question was can he come to any conclu-E 10 g i sion. Would you read the question back. = 1 E 11 j (Record read.) i 12 i MR. FARNELL: I object to that question. Mr. Dhar E 13 i said that he needed to make an analysis which he hasn't done, E 14 i 2 and therefore, there is no foundation for the question.

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7 15 j my continuing objection is to his lack of expertise in the pipe T 16 l Also, there is the word " positively" in the questi,on. area. ti 17 g { A I cannot positively say that. 5 18 ' = BY MR. PATON: (Resuming) 19 i Q Can you state that it is possible that additional 2a,l j settlement would decrease the stress that is now in the pipes, 21 ! j my question being is that possible? 22 l l MR. FARNELL: Objection. Speculation. 23 ' j SY MR. PATON: (Resuming) 24 Q If you would have to guess, just say so, but my { 25 i question is can't you conclude that there is no possibility that i ,'i ALDERSON REPORTING COMPANY. INC. l ~

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. do not recall.

8 8 Q Would the responsibility for that be within your d" 9 ~. group? Ztg 10 A I want to add something to my previous answer. z 5 II Q Sure. 3 12 E A Except for the borated waterline. Please repeat your =- g 13 question. i 3 14 i 9 Q Mr. Dhar, I asked you a question about whether you c g 15 had any plans to monitor the ' profiles of pipes. Do you recall ij 16 that question?

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\\ C 17 ; d A Yes, I do. = 3 18 Q Now you indicated to me that you wanted to amend your c" 19 ! 2 answer. Will you give me a complete answer to that question A 20l l now? 21 li A I do not recall any plans to monitor the pipes in the l l 22I future except for the borated waterlines. t 23 ' 1 Q Why do you plan to monitor -- are these horated } i 24 3 l' 2 waterlines in the ground? They are underground? t 25 : A They are underground; yes. i . s,. i I s ALDERSON REPORTING COMPANY. INC. k

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..;. e:.y,.. x -- > n- \\ 154 gw a, 1 Q Why do you plan to manitor these lines and noe other 2 lines? 3 MR. FARNELL: He said he didn't recall whether any 4 other ones would be monitored, but he did recall this one would 5 be. 8 6 BY MR. PATON: (Resuming) R C t, 7 Q Let me ask a different question. Do you know any reason E 8 why borated waterlines would be monitoredE For exampla, do they n d d 9 have specia2. safety significance? .zcg 10 A To my best recollection NRC has expressed concern about 2_ 5 II borated waterlines, and they have indicated that additional 3: ( 12 monitoring -- they would recommend additional monitoring. = g 13 Q They would recommend it? -~ h I4 A That they recommend it. That is my recollection. j c 4 g 15 Q Your recollection is that the NRC recommended the = a[ 16 monitoring of borated waterlines, but you don't recall that they i h I7 recommended monitoring other lines; is that your recollection? E IOlI OiR. FARNELL: That is not what he said. E I I9 l 8 MR. PATON: I am not trying to mischaracterize what he n 20 l s a.td. 21 I A What I said in my answer to the question about whether t 22 3 t the borated waterline has any special significance, I was j answering that question, and my answer was that NRC has indicated 24 1 i that borated waterlines are to be of great significance as to i .i h Q ' plant safety. l* l .i i .i ALDERSON REPORTING COMPANY. INC. j i

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A. O {;j?.. 3 w.. 3 jc.m ~' BY MR. PATON': l 2 Q Mr. Dhar, this may possibly be repetitive, but do you 3 have any plans to monitor any other lines or pipes other than 4 the borated waterlines just discussed? e 5 A I don't know. 3e 8 6 Q Mr. Dhar, I will show you a document that is from = 7 Vol. 4, Tab 93. There is a cover note signed by S.S.-Afifi 8 dated November 26, 1979, and it has attached to it two pages of d =i 9 meeting notes. The date at the top is October 25, 1979, and I i h 10 direct your attention to a sentence in Paragraph No. 3 on Page 2 3 5 11 of the meeting notes, and the sentence reads: "K. Weidner <m d 12 said that he had already suggested that the Project recuest the z= S 13 Field to cut the pipe at certain points to check stresses." E E 14 l That sentence is underlined in pencil there, and after E E 15 you have had a chance to review that document, I want to ask you u= 16 if you agree with Mr. Weidner's recommendation in that sentence? j

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17 ' MR. FARNELL: I just want noted for the record that E E 18 this document has numbers stamped on it SB either 5 or S02095. I -c i i I 19,i BY MR. PATON: (Resuming) =5 20 l Q Do you agree with the recommendation in that sentence? i 21) MR. FARNELL: I am going to object to this again as i t 22 ) being outside his area of expertise. l 23 ' 3Y MR. PATON: (Resuming) l 24 ) Q Would you answer the cuestion? i l 25 ! A Aecogni::ing that I am not expert in piping stresses -- ! ~ l p ALDERSON REPORTING COMPANY. INC.

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1SG l::.. -c,:u. = 1! Q Except for seismic. I 2 A -- my answer to the question would be if the 3 calculations show that the pipes are overstressed, this would be 4 one method of checking their stress. g 5 Q Do you know whether the pipes were ever cut to check R 4g 6 :i stresses? g 1 R 7 A other than the condenser line. l 8 Q other than the condenser line? d d 9 A No, I do not recall them being cut. ,2o g 10 Q Did you attend a meeting in Bethesda on January 16, E l II 1980 at the NRC? i a g 12 A I don't think so. g 13 1 Q No? i l 14 l ii In 1980 you said? A j 15 Q Right. = l d I0 A I don't think so. 5 i 'g" 17 ; Q Do you have any knowledge of cracking of the ring beam z l i g 18 i i . foundation for the borated water storage tank? l 2 19 I A There are some cracks in that beam; yes. M l 1 20 0 Are the cracks confined to the ring beam, or have they 21 ;I, extended into the-shell of the tank? a 22 j A Do you mean by the shell the metal of the tank itself? 1 .I 4 23 i Q Yes. l i 24i b A I do not recall any cracking of the tank itself.- l l-Q To your knowledge has there been any analysis to i I .t ALDERSON REPORTING COMPANY. INC. i

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.li :. .~.>;.. "mg 6-- I-evaluate the effects of the cracks in the ring beam during a 2 seismic event? 3 A I would like 'to have some clarification on, that 4 question. Analysis for what? j5 Q The structural integrity of the borated water storage e j 6 i. tank. g. b 7 A Are you referring to an analysis specifically for this j 8 crack? dd 9 Q Yes. 2o h 10 A No analysis has been done specifically for this crack. II Q Has there been some other kind of analysis dcne other 3 12 E than specifically for this crack? 13 g A Yes, sir. 3 14 Q For what purpose was the other analysis done? =0 15 l g A The analysis is being done to evaluate the effect of 16 3 settlement on the ring foundation. d l C 17 ' .j Q Has that analysis been completed? = l E 18 ll A That analysis is still under progress. i =s 19 52 O When did that analysis start? 3 20 i A That analysis was started sometime in '79. i 21 I i O And that is continuing? 22 - A Yes, sir'. I' 4 i. 23 i j MR. PATON: Give us five minutes, and I think we are 24 ) done. h j 25 ' i (Recess.) l 1 .j l-ALDERSON REPORTING COMPANY. INC. l-

u. ,, ~- l .. ~ w- ,t. w ':};'g:y y> .% g c~:-E:u- % :77M^ ...- M ~ < v = 4 -- Y. C i:- C - Q,~ ?;:: s y"- 4 ' a-' i ~:,; ~......,;-a 1 BY MR. PATON: (Resuming) 2 Q Are you aware of gaps in the foundations of any 3 Category 1 structures at Midland? 4 MR. FARNELL: Currently? 5 BY MR. PATON: (Resuming) i = h j 6 Q Currently? E 7 A currently I am not aware of gaps. M j 8 Q Have there been gaps that you have been aware of that d 2 9 have been grouted? z i oy 10 A Yes, sir. z i = j 11 Q Have there been voids that you are aware of in m 3 12 Category i buildings that have been grouted? =} 13, A In the building irself? = j ft j. 14 l Q In the foundation. i E I j 15 A And it has been grouted already? i 16 gi Q Yes. o E 17 i A I am not aware of that, a = I 3 18 Q Are you aware of any that have not already been grouted? e r. a 19 l A Yes, sir. -M 20l Q You are aware of voids, and you said they have been 21l grouted? I 22 A voids under the foundation which have not been grouted.i 23 I Q voids not grouted and gaps have been grouted? i I [ 24 ! A Yes, to the best of my knowledge the gaps have been I i j 25 l grouted. i-I I I ALDERSON r{ PORTING COMPANY, INC. _}}

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