ML20090A842
| ML20090A842 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/10/1980 |
| From: | Ferris W, Ferris W BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101090365 | |
| Download: ML20090A842 (173) | |
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t~ 5 0-329 OL9' ' R' 50-330-oL %r. -e. . c. DEPOSITION OF WALTER R. FERRIS i ct. a,._. ( DATE: December 10, 1980 PAGE3*: 1'thru 172 e AT: Chicago, Illinois ~ t n 1 ,.c y ..., c ....v.;.v.. .J .. ! e;.6ll . ;;.h,..p 'y...e . ?.;; 1.y
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.. m rm, ~- so. . f* * ~:.%....... w.--. f;. m..,-.,--. Ay; .....m.,, ?%.. a.. c... c - v. -~m - ~ ~ ~ - - ~ ~ - 7.. -q -- -C.R. &p.. _ ._u-s s w,.... r -- -- + h 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 EEFORE THE ATOMIC SAFETY LICENSING E0ARD 3 (' In the Matter of: ) 4 ) Docket Nos 50 329 OM CONSUMERS POWER COMPANY ) 50 330 OM 5 ) 50 329 OL h (Midland Plant Units 1 & 2) ) 50 330 OL 5 6 a 7 Offices of Isham, Lincoln and Beale One First National Plaza j 8 Chicago, Illinois d d 9 December 10, 1980 g ' 10 Deposition of: .E. 11 WALTER R. FERRIS 3 Y I2 the deponent called for examination by the staff of the 5 ( y 13 Nuclear Regulatory Commission pursuant to notice, at 9:30 m ] 14 a.m. 2 15 PRESENT ON BEHALF OF THE RESPECTIVE PARTIES: =a 16 3; For the Nuclear Regulatory Commission ai g 17 5 Mr. William Paton lii 18 Counsel for NRC E 19 . g Mr. Joseph Kane 20 Hari Singh 21 Jim Morrison s 22 For the Consumers Power Company o 23 Mr. Alan'S. Farnell and Mr. Ronald G. Zamarin 24 Isham, Lincoln & Eeale, Counselcrs at Law One First National Plaza 25 Chicago, Illinois 60603 I c ALDERSON REPORTING COMPANY. INC. u
.g 's.: ;'. c,,y.y. < E1 :M K E5 A h E_. h: ~.'" - hg ' ,*_.,j ",-).*:3 e w (Witne ss sworn. ) WALTER R. FERRIS called as a witness herein, having been first duly sworn (~. was examined and testified as follows: 4 EXAMINATION BY 6 E MR. PATON 7 3 This is the deposition of Walter Ferris of l 8 d the Bechtel, San Fransisco office being conducted pursuant to c 9 notice sent by the staff November 25th, 1980. 10 Mr. Ferris, please state your full name and q 11 8 your employer for the record. .c 12 5 ( 3 A My name is Walter Ronald Ferris, and I work with g 13 Bechtel, Incorporated in the Hydro & Community Facilities E 14 M 5 Division. 2 15 a Q All right, the name of the corporation you work 16 g d for is Bechteh it's-Incorporated; is that correct? G 17 m= A Bechtel, Incorporated. li 18 E Q And is the organization that is located in Ann 19 R Arbor, Michigan also Bechtel, Incorporated? 20 A In Ann Arbor, there are Bechtel, Incorporated 21 personnel in the geotechnical group. g Q y Now, you say the geotechnical group, are you acquainting that to the hydro and community facilities division? 25 ) 'I ALDERSON REPORTING COMPANY. INC.
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_;n. .. - ~. _. . _. a. _, _;. " e - .' ".c'" " q~ '.%. . g '.7:.#. -P&,O .:..% 3.A. ;..P. n W.M ~,., TTc. ~ .%~:.%.. '.,:: :.. ~n:%:.__. s. .,'w ,.p._.._..,...,,.. ...-,--...-...~r.~. .~ ~~~.. 4. 3 y. .f.p._. -Q y :: c- --v--- A Yes, they are members of'the hydro and community 2 facilities division. 3 Q Do you acquaint these -- is the geotechnical \\ 4 the same as the hydro and community facilities? 5 A No, it is not. h 3 0 Q What is the difference? R 7 A The geotechnical group is a sub-group within N l 8 the. hydro and community facilities division. dd 9 Q What is your position within the hydro and community 1 6 10 division in San Fransisco? z 5 II A I'm the chief soil engineer. l 12 Q Are you Dr. Afifi's boss? l-5 13 3 . Technically I am his superior or supervi'sor. l 14 q 7,m looking at a document that you gave me that b_ g 15 apparentJ.y is your resume, and I'm going to mark it Staff a j 16 Exhibit 1, December 10, 1980. And I'll mark it Ferris as
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U 18 (At which time the document was marked.) E I' g And I notice you have a degree from Harvard; i E ~ is that June of 1955? 21 A That 's correct. l (,. 22 Q Soil mechanics? 23 l A . That 's correct. M Q Is that a Bachelor Degree? 25 A No, that is a Master's Degree. At that time Harvard ALDERSON REPORTING COMi8ANY. INC.
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+ 4 I called it a "SM" but it is in fact a Masterb Degree. 2 Q Okay. On your resume, it says December, 1941 3 to January,. 1942, Royal Engi.neers, UK,(United Kingdom) 4 am I correct, that that is two months? g 5 A, No, you are not correct, I was in the Royal Engineers e 6 from December,1941 dnt11 January of 1948 -- a little over R 7 six years. Al 8 Q Okay, I'm sorry, but do you see your resume, dd 9 it says from and to, does that not say January '42? ,z h 10 A It appears to be a typographical error. ? 11 Q So, you would make that a '48; is that correct? 3 I I2 A That's correch.- ( 0 5 13 Q Would you tell me in your judgment what Dr.'Afiri's a 3 14 responsibilities are ? 15 A Dr. Afifi is the assistant chief soil engineer g 16 in the geotechnical group in the Ann Arbor office. s 6 17-Q Assistant chief engineer in the what? w f18 A In the Ann Arbor Office of Bechtel. E 19 Q But you indicated the group, geotechnical group. g 20 A He is with the geotechnical group. 21 Q Did you read his deposition? k 22 A Yes, I have. 23 Q Can you tell me what his responsibilities were 24 with respect to the soils problem at the Midland site? 25 MR. FARNELL: Currently, right? ALDERSON REPORTING COMPANY. INC.
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S ~ g 13 Q .I didn't he-ar the first word. l 14 A Soil perimeters. _b g 15 Q Okay; is that.all? m d I0 A Yes, at the moment, yes. as h II Q You say he is providing soil perimeters to project = g 18 engineering; is that the extent of his responsibility at E 19 g the present time? 20 A No, you asked me on the Midland job. He is providing 21 it on the Midland Project. l 22 Q Yes, I do mean to limit it.to the Midland Project. 23 A That is what his job is, t 24 Q Does he have any responsibility to see that the 25 information he provides to project engineering is properly ALDERSON REPORTING COMPANY. INC.
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y_'e I have responded to it. ~ 2 Q Okay, you agree he did give them advice on the proper 3 compaction standard to be used at one point? 4 A Yes, I have seen a memo. = 5 h And after he gave that, advice, there was still Q 3 6-confusion on the proper compaction standard? R E 7 A I'm not familiar _with that area. M g 8 Q Okay, you read his deposition, but yott don't dd 9 recall having read the deposition as to whether the confusion 10 came after he gave them advice; is that correct? .E. II A I believe clie confusion existed beyond that, a g 12 I don't know anything about the detailings of it. ( 5 5 13 r Q And ou don't see Dr. Afif1's responsibilities = l 14 as including the duty to go out and try to find out whether g 15 the advice that he gave us w'as being followed? = ai I0 A No, I don't believe so unless he is specifically as s: ny g askea by the project to. m l { 18 Q Okay, now you answered a question a short time E 19 g ago as to what Dr. Afifi's present responsibilities are n 20 with respect to Midland. 21 A Ye s. (. 22 Q What have his responsibilities been f'or the past 23 three or four years? Do they differ in any way from what 24 you just said his present responsibilitics are? 25 A No, as.far as I recollect, Dr. Afifi being in. ALDERSON REPORTING COMPANY INC.
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Q How often over the last three or four years, df9 approximately, how often do you talk to Dr. Afiri? 10 A I talk to him quite frequently. Probably two = 5 II times a week, by telephone. is y 12 Q Mr. Ferris, I want to show you a document that s j 13 is dated June 30, 1980, that has'already been designated 14 in these proceedings as deposition exhibit number 4 in g 15 the deposition of Mr. Lyman ' Heller. And I'll hand it to x ii[ 16 you and you can look at any part of it you want. But I'm as h I7 directing your attention to Enclosure 1, the last paragraph II of number 36 which is four lines long. You can look at h I9 g any part of that document that you want. My question will 20 be addressed to that paragraph. II Q Could you point out again the particular paragraph 22 that you want me to address? 23 Q Yes. And in fact, I'll tell you the question, 24 it may help you with your review of the document. But 25 the paragraph I'm referring to is the four-line paragraph l ALDERSON REPORTING COMPANY, INC.
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--.,.p~- ~ .a ;,...... =. pg ....,,,. ~ - - -,.., -- A,s. ~ ~ ~ - []i. 1,... N ~ e-I 1 that appears at the end of number 36 on the page that is 2 parked " Enclosure 1." Mr. Ferris,[want'totellyouthequestionthen 3 Q (- 4 you can read the document a little better. 3 5 This sentence I'm directing your attention S 3 6 to is really the second sentence of the four-line paragraph g R, 7 of the end of 36. And it reads, " Also provide the locations, Xl 8 boring logs and availability testing data of any exploration d $[ completed in 1979 and 1980 which has not yet been submitted." 9 10 E And the question I'm going to ask you is 5 II did you at some time after.that letter submit the information in I II referenced in that second sentence that I just read? 5 5 13 A I personally did not. ~ m l 14 Q Do you know if it was submit':ed? Y h' 15 A I do not know if t' hat has been completely compiled a j 16 with as yet. as N I7 MF. FARNELL: Also he doesn't know if there is any wx k 18 such information.. E 19 BY MR. PATON: 20 g y ell ask the witness. Do you know if there is II any such information? l ( 22 A I'nt aware at this time that there were boring 23 logs that the NRC had not seen, but I do not know if those 24 have been as yet sent t6 Anderson. 25 Q Who 'within Bechtel should know that ? 1 ALDERSON REPORTING COMPANY. INC.
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.w;..x .e ~,; e. 12 Y 1 A The project engineer. 2 Q And who is that ? 3 A Currently, it is Curtis. i 4 Q In July,1980, who was the project engineer? g 5 A I don't recall. R 6 Q All right, now would Dr. Afifi know whether that R 7 information had been provided, is that within his responsibility a j 8 A He would know what he had provided to the project d q 9 so indirectly he might know what was available to go to z h 10 the NRC.
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Il Q Do you know anything about the information contained E ( 12 in boring logs and available test data of any exploration ( b 5 13 completed in 1979 and '80 that had not been submitted to m l 14 the NRC in June of 1980? Do you know what that information D. g 15 was? = 16 g A I don't recall precisely, no. e ( 17 Q Who within Bechtel would know that information? f 18 A The project engineer would know it. E 19 Q If the NRC asked for that information,- whose 20 responsibility is it to determine whether it will be provided 21 to the NRC? l ( 22 A I believe the applicant is responsible for that. i 23 Q When you say " project engineer" do you mean Eschtel-24 s. or Consumers? 25 ' A The. Midland Bechtel project engineer would know ALDERSON REPORTING COMPANY, INC.
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4. s.. . -... ~.,. ~ [; 7;.-l 1...., 1" ~ 7 j ~- 'C -mn. ~~ what Bechtel had available. 2 Q I'm trying to think of how.to word this question 3 and I'll do the best I can. The question is this way: 4 it seems unusual to me -- and please respond or comment = 5 h on my statement -- I'm not trying to argue with you, but ] 6 it seems to me that the chief soil engineer for Bechtel R 6, 7 does not know whether when the NRC makes a request for Rl 8 boring logs and availability test data of any exploration d q 9 ccmpleted in 1980 that that information was not ever provided. 2 og 10 MR. FARNELL: That 's not even a question.- 3 h II BY MR. PATON: is I 12 Q Does that seem unusual to you? ( 13 MR. FARNELL: That is unreasonable. c a 5 14 SY MR..PATON: El 15 q' Is that within the. scope of your responsibilities -- a E 10 A I..have no direct. contact.with the NRC. as l I7 Q Do.you have any responsibility with respect to a 18 a question from the NRC -- strike that. E 19 g With respect to the particular sentence 20 that I asked you.to direct your attention to, did you have 21 any responsibility"? 22 (,. A Only in reviewing the data that would be sent. i 23 Q Did you review the data that would be sent? i 24 A I do not recall all of the data that I have reviewed 25 specifically. ~ ALDERSON REPORTING COMPANY, INC. t -l.
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14 . -: v., ? 1 Q Do you recall whether you specifically reviewed 2 this data?. 3 A I recall having reviewed some borings that were 4 not available to NRC on June 30th. y 5 Q Did the data that you reviewed indicate poor 9 ] 6. foundation conditions in the areas of the electrical penetration R { 7 rooms? X ~ g 8 A Which data are you referring to? d d 9 Q The data you just indicated that you reviewed. 10 Q I do not recall that.
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j 11 -Q. Have you reviewed Volume 8 of the responses to a ( 12 the NRC 50 54(f) questions? Sg 13 A. I have reviewed the responses. that Afifi has GR l 14 prepared. for the project and therefore, those portions 2 15 that are ' contained in Volume. 8, I would have reviewed, j 16
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e 6 17 Q Do you know if the information requested in this E E 18 sentence that'I have referred you to in Heller Deposition E 19 R Number 4 is contained in Volume 8 of the 50 54(f) responses? 20 A I do not. 21 Q Do you have in your office Volumes 1 through / 22 8 of the 50 54 (f)? 23 A Yes, I do. to th.e information that 's indicated 24 0 Now, with resoect 25 in the sentence in the Heller Decosition to which I have s ALDERSON REPORTING COMPANY, INC. i
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~ ~ %_.,.. m _... g.. r.... .;y v.. .s um.,..~~.... ..~. . =. ' "'* 5 'a..*. mu s i*-==e. ./.. ~ ~ I referred you, do you have any'racollection as to whether there 2 was any ' indication or information indicating coor condition 3 foundations anywhere on the site. 4 A I do not know soecifically what is in the borinzs 5 referred to there, so I cannot answer your question, j 6 Q All right. R 7 A I don.'t recall what is in them. if j 8 Q Let me ask you this, do you remember whether dd 9 or not you ever reviewed this information at any time?' x. 10 A I think I.just answered that. 3 k II MR. FARNELL: It has been asked and answered. m d 12 z BY MR. PATON: S g 13 Q I know you said you don't remember., but did you l 14 ever look at it? m h 15 A I think I told you I recall seeing some of that x E I0 information, but what I don't know is whether I see all e h I7 that 's referred to in that general sentence. =li 18 Q You said you saw some of -- E I9 g A I believe I have. 20 Q So, you are fairly clear that you saw some of 21 it, but not all of it ? ( 22 A Right. 23 Q As to the "some of it" do you recall anything M about it? 25 -A I do not recall stuff relating to electrical i ALDERSON REPORTING COMPANY,INC.
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=....K 5-E= *3-T.~L'b: 3. ?YL b. $ Y1 c q v.. ...,,u. ~- 20 r I Q Do you know what kind of information -- strike 2 that. 3 Describe the discipline of the person who 4 would make that design -- design the remedy. g 5 A There is not one person. a 6 Q All right, tell me what disciplines would be C E 7 involved. A g 8 A Well, the pile part of it, the recommendation d d 9 for that will be made by soil engineer and then the overall mi h 10 analysis of the building would have to be carried out by E 11 struc'tural engineer. a is g 12 Q Okay, is there a discipline called " foundation S 5 13 e ngineering" ? m l 14 A Yes. A soil engineer carries out foundation g 15 engineering. m d 16 Q And you are a soil engineer? si g 17 ' A I'm a soil engineer, yes. l d F: E IB Q Now, can you tell me what information you would 0 19 need about that fill to provide your input into the design 20 of the underpinning? 21 A You would need to know the soil conditions at 22 the structure. 23 Q Okay, tell me what you mean by that. 24 A You would need to know what type of soil is there. 25 What its consistency is, s D ALDERSON REPORTING COMPANY. INC.
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What do you mean by consistency? E 11 A Soft ~or stiff. 3 p 12 Q How is that measured, what perimeter? 3 5 13 A In its very crudest method by stindard penetration = l 14 test'. e .] 15 -Q Now, stratum,'I'm not sure I und'erstand stratum. C g 16 That part of this clarifying -- each stratum -- is that as 17 what you-meant when you used that term? m! 18 A. It is the soil layering, each layer is a stratum, h I9 g so the subject surface consists of strata of different 20 materials. 21 Q How would you go about determining those things, l 22 where would you get your information? 23 A From borings. 24 Q What kind of borings? 25 A Normally, soil borings. ~
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== II A A load test on tha pile. 3 I I2 Q And do you know whether the plan is to rely on 4 g 13 load tests for piles in this case? m l 14 A-I do.not recall that it is specifically to rely l 15' on 'that. - a j 16 q Do you know if it was ever planned to do that? as d 17 Was it ever. planned to do that ? - *m! 18 I A What do you mean when you say -- what is your k 19 actual question? 20 Q Was there ever a plan to rely on load tests for 21 piles in place of tak$ng undisturbed samples? 22 MR. FARNELL: I don't think those things are mutually -- 23 he testified that those things are mutually exclusively. i M -g -Q . ell, if they are not that 's fine, he.can tell W 1 25 me that, f- .i -., I ALDERSON REPORTING COMPANY, INC.
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I ..=mcMr w -%&is: . ? .m..n.:.a.. m . ~.. - x ..::':cM .....,,...., a.. o g ~ I need to know to design the underpinning and my question to 2 you is -- 3 MR. FARNELL: We are just talking about the surface 4 water building now? 5 MR. PATON: I'm still talking about the surface water { 6 structure and my specific question is I'm addressing what C 7 you need to know to design your underpinning and my question n j 8 is would you need to know the n.aximum static and dynamic d d 9 loads to be imposed? z 10 . WITNESS: The soil engeineer would not necessarily [ Il need to know that, it Y I2 BY MR. PATON: S 5 13 q.' .Would the structural engineer need to know the -- m a m E I4 A' The structural engineer must.know that. b g 15 Q Would the structural engineer or the foundation .a -l I6 engineer have to know the load bearing capacity of the w IF I7 pile s ?- E II I8 A Could you repeat that question, please ? k 19 Q For whoever is designing the underpinning, is 20 it necessary to know the load-bearing capacity of the piles? 21 A Yes, it is. 22 Q Is it necessary to make a settlement prediction 23 i for.the pile s? 24 A Yes. You would need to know. 25 Q Now, with, respect to the information that you,have ~
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n w. ..e~:-..,,--.~.-.. ~... p' f, ;.;fp me 7 y.y-. y. . n. -g. five years, ten years ago?. _-. ~ g 7 2 A ' Probably ten years ago or more. 3 / ' Q Could you tell me anything about why engineers within 4 the last ten years have undergone a change of anything 5 in this regard? I 0 A Much more reliable procedures for installation R E 7 and checking the loads and piles have been developed. g.] 8 Q So,.that within the last 10 years. load testing < dd 9 t.o your knowledge has become much more reliable. .2 10 A Load testing has always been reliable, but there Z h II are additions tb Wee w!rk that are done that make it even 3 ( 12 more reliable.- =3 lii I.3 Q Can you just tell me briefly what you are referring = l 14 to' when 'you said " additions to that work" ? g 15 A Well,. things that.you do in addition to the actual m 16 ai loading of the pile. as h I7 Q Can you give me an example? 18 A Yes, use of cae waive equation which was developed E 19 g about 10 years ago. 20 Q Could you give me one more example? 21 A That is the basic. 22 Q And in your opinion of. the waive equation and I 23 other I think you. described as additions, make the load 24 tests so reliable now that in your engineering judgment 25 whatever you would learn from obtaining sheer strength is t ALDERSON REPORTING COMPANY. INC. ~ l
i'. p *, 4.. .53.;gcy_k'a-'5r*kh%' w..& % '- $ ShECb~~Yi$ dl' %'S-S?? m w r..uu 36 r I just not worthwhile going after. 2 A That.is correct. The combination of the load test and 3 waive equation analysis when properly done by somebody 4 who understand it is far superior. 5 A Okay, now, you do the load test obviously before I 0 you install the piles? R 7 A That'.s what I said. X ] 8 Q Before ? dd 9 A Before you install the piles for the structure. l 10 Q Can-.yott design the piles.before you do the load = 5 II tests or do you have to wait until after the load tests? m l I2 MR. FARNELL:. Are you talking about the piles -- I S 5 I3 thi.% there is-problem. a = E I4 MR. PATON: Can you design the piles that are going g 15 to,be installed prior to doing the load tests? m E 10 WITNESS: What aspect of the design do you refer to? as . h I7 BY MR. PATON: 18 Q Load-bearing capacity, e II g A I believe it is possible to state that a pile 20 of capacity can_be driven up the side. 21 Q Let me get away from what is possible. ~ Do-you 22 s. know what your plan is in this case? 23 A Yes, I do. My understanding-is that it is to 24 drive 110 capacity piles that utilize but use only 75 tons 25 of them. l .\\ \\ ALDERSON REPORTING COMPANY, INC..
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I'm not pressing you on those numbers. That C J; 10 z is the load to be imposed now what I want to ask you about E 11 j is the ability of the soil to support a pile that is carrying d 12 5 75 to 110 tons.- <And my question is don't you need to know 3 13 the sheer ' strength of the soil to know whether the soil E 14 y can support-16 piles, each of which is carrying between 2 15 g 75 and 110 tons? ? 16 3 MR. FAP.NELL: I think' it was 75 without 110. d 17 g MR. PATON: All right, 75 Di 18, = WITNESS: I believe I have already answered that. 19 You do not need to know the sheer strength of the soil. 20 BY MR. PATON: 21 Q Do you need to know the sheer strength of the 22 soil to know how many piles are required? 23 A Not in my opinion. 24 Q Mr. Ferris, in your experience within the last 25 s five years, have you first estimated bearing capacity by ALDERSON REPORTING COMPANY, INC.
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(,k3 * -c :: v% w D.d i I analytic methods? In other words, have you f&howed the 2 procedure -that's suggested by the staff as opposed to using 3 load tests? 4 A I personally have not. = 5 Q Do you know of any instance where it has been h! O done ? ' R 6 7 A It may have been done, I can't recall. 7. $.#8 q To your knowledge. do you recall now? d d 9 A I do not recall right now. z h 10 Q In the last five years, approximately how many E 11 instances do you recall in which load tests were used instead 3 f 12 of first. analysing bearing capacity by analytical methods? 5 i 5 13 A. I can recall three r.ight now. 2 (n E 14 Q Okay. Could you describe those three briefly? E g 15 'A Yes.- I can tell. you the project, Bellrich project, a si I6 which is being done out of the Ann Arbor office and two as N 17 specific contracts on the Hope Creek, Nucle c Plant Fernon W 18 Categoric I structures. E 19-Q Does waive equations involve an analytical approach? 20 A Yes, it does. 21 Q Is it used in connection only with load tests? l 22 A No, it doesn't have to be used, you need to know 23 the load tests to use it, but there are aspects beyond l l 24 that where eve.7 time you use a waive equation you ' don't l l 25 ,have to have a load test. l l ~ ALDERSON REPCRTING COMPANY. INC.
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2- ..'yp-:- j;F L E ~7q** v~.;. :W-- *'.0055?5]* **I$5k% t.?D'55Y .='#* . --:c.<.. 1 Q Does waive equation use sheer strength? 2 A No, it does not. 3 Q Is:the waive equation approach reliable in hetero-4 generous soil deposits? = 5 A Yes, I believe it is. 5 ] 6 'Q Does the pile load test permit you to determine C 7 long-term settlement ? 3 $8 A 'No, the pile load does not permit you to do that, dd 9 Q Do you make any determining of settlement of 5g 10 the piles? _3 5 II A I believe the piles were being installed conservatively in Y I2 so that not 'a problem. 5 5 13 'Q Does that mean that they are driven ddwn to the ~ a l 14 till? ~ U g 15 A The piles must be. driven into the till. a j 16 Q And once they are driven into the till, does e h I7 that mean you can forget about settlement? a 18 A No, I did_not say that. i: g" 19 Q Okay, tell me what concerns you have, if any 20 when the piles are driven into the till with respect to 21 settlement. 22 A If they are driven sufficiently deep into the 23 till, I don't have a concern for settlement at the loads 24 we are discussing. 25 Q Approximately how deep do you mean? ALDERSON REPORTING COMPANY, INC.
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A The load test will not, the load test that I 0 have been discussing with you will not. e. b 7 Q How will you determine that ? l 8 A I do not know precisely how that's being done, d ]". 9 Q Do you know whether it has been done? O 10 g A I do-not know that either. = 5 II Q Do you know -- you stated there was a determination is g 12 . that each pile would support approximately 75 tons, do s 13 l yo,u know when that determining was made? The precise date. I4 A Who is going to design the piles? = b A We ar'e authorizing a consultant to assist us a j 16 with design. at k. I Q What is the name of that consultant? lii 18 A That's Dr. M. T. Davisson. = 19 g Q Do you know when he was retained? 20 A Sometime in 1979, prior to the end of June,1979, 21 I can't recall the precise date. 22 l Q And is it Dr. Davisson that determined that you 23 were going to need 16 piles tha,t would supcort 75 tons each? j A No, I believe we went through all that. The. ALDERSON REPORTING COMPANY,INC.
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f~ ~ .[. A {~- -..; - V' _~ ~ ,.f(~~ Ih ~ - * .g m.. m, :-".- : t'-~~ - r G 43 -n ~ a sz........... .,w,,._ g; (,k b s. ; .t c... - -. -,n-- + + s w .v-*. 't-r.. ~, n o c. . =4 ~-., $0.Th-l-% .?c ~1^T~ -$ ~ 1 structural engineer provided the loads that the piles have to 2 carry. 3 Q .Do you know who the structural engineer was? ) 4 A I do not know who that was at that time. l 5 j Q So, the structural engineer provides that information a 6 to Dr. Davisson, right ? R b 7 A He pro.vides it to Sherif Afifi. l 8 Q And does Dr. Afifi add any information to that dd 9 z. when he passes it on to Dr. Davisson? h 10 A .I don't know any reason why he shnuld. .!F k II Q-Dr. Afifi doesn.'t he add any information to it? n I II A. With regard to the load-bearing capacity? .E a 5 13 q. No. That 's not what I mean. I mean within Dr. m l 14 Afif1's' area of expertise and responsibility, what does a g 15 he add to't'he'information he'got from the structural engineer ay 16 before he passes it on? ad f I7 A He would provide the soil data at the. structure, E g 18 the boring logs, whatever information he had, water table E I9 g level. 20 Q Would he provide all the information we talked II about before under the heading of soil conditions, for 22 (. example, clarifying the soil into gravel, sand, clay and 23 silt. \\_ 24 Q A Well, he would provide the boring logs and 25 any evaluation of,those logs that he made. ALDERSON REPORTING COMPANY. INC.
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' bs .. *> - g.*gsgg,,}w. - : Er-?C * "Y'~ s-X:% E-5. $- h ~~ ~.-.. .n, N. g bo?.*b' egw c 3u 46 ? I is, the Midland Prnject Structural Fngineer. 2 Q The Bechtel -- 3 A Bechtel. 4 Q Not Consumers? 5 g A No, Bechtel. a 3 6 Q Mr. Ferris, did you bring any files with you today? ~n a 7 A' No, I didn 't. 3 g 8 Q Can you tell me why you didn't? d d 9 A Because I don't have any personal files on the 2, h 10 Midland Project. _3 II Q No notes? 3 I I2 A No, any notes that I had, I sent to.the project. Ei* g 13 To Sherif Afifi. l 14 Q. When did you do that? _b 15 A After meetings. = I 10 m 0 You mean right after any meeting you would send as $i 17 him the notes? ${ 18 A I would send him the. notes to be incorporated E 19 into the notes of the meeting. 20 Q So you have no personal notes? 21 A No, I have no personal notes. I do a lot of 22 projects. I don't keep personal individual file s. 23 ; Q Can you describe what kind of records are kept 24 at Bechtel in San Fransisco with respect to the Midland 25 soils problem? ~ ALDERSON REPORTING COMPANY, INC.
f~J'I N ?~: ..;yn.o w.-,,.; =., s~- w. 3.,y+, .yp_ ... w,.,.,,,.. ...,c...... { ;::: w.:.. ..~.;-.e.-~~ we v -.- ~ -u w r -~u ~c= ~~~ ' ~- w&. ^^ f,., g7 ~Q, ' 4. :.w ~. .m m. .) %: - ' ~ ~% 1 A I can on.'.y -- Just those that are in our geo-2 technical group there. 3 -Q Yes. 4 A And I receive ccpies of correspondents, the reports 5 that you mentioned earlier, things like that, and those h 3 6 are filed in the geotechnical files in San Fransisco. R 7 Q How many people work in the geotechnical? 8 ~A We have about a dozen soil engineers, dd 9 'Q And are you -- ~ i h 10 A I'm in San Fransisco. = ~ g,11 Q Right, and do you supervise that group ? m e5 12 A Yes,.I do. That 's one of my responsibilites. z 5 5 13 Q These. files are kept in a file for a group tilat E E 14 you supervise?
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2 15 A-No, I supervise their individual work, I work am for a manager of soil engineerin5 who is overall in charSe 16 j as g 17 of the soil treatment. M h 18 Q Who do you work for? E 19 A Harris Burk. R 20 Q You don't consider those files to be under your 21 control? 22 A No, I don't, I consider them to be under Mr. i 23 Burk's control. I have access to them. 24 Q What kind of information is in those files other 25 than correspondents that you received? ALDERSON REPORTING COMPANY. INC.
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==&# y;~.1~-- -M. L ( ' %p%%;&th:; ;i= W*f*...x 7y;,,vg.~:: my i~ m -,3. 7.. .a.... ........c.. 59 ..~ a. ,,.... -. ~ - f;'[].;Y...r ~ ~ ~ "h a..,, ~-- ? I best of my recollection. ~ 2 Q In the ordinary course of your experience, you have i 3 been with Bechtel for 21 years in the San Francisco Office, 4 and you are now in the Midland site and the soil problems S 5 there. What would be your. estimate of when Bechtel ordinarily 2 j 6 would have contracted for the purchase of' those plies? 7 MR. FARNELL: Are you talking about as the design a 8 8 or the pile or are you talking about some point in time d C 9 or some -- ze g 10 MR. PATON: No, I'm talking about his knowled M of E Z II this case and to estimate approximately when --- a I2 ' WITNESS: I. don't know anything about the contract s 5 13 for the pile s. m l 14 BY MR.. PATON: ? g 15 Q I understand that, and I'm clear on that. I'm c: j 16 asking you in your 21 years of experience with Bechtel, cd N 17 A On a general basis? Cd= $i 18 Q On a general basis, when would they ordinarily k 19 g contract for piles, bearing in mind your knowledge of this n 20 case, approximately when? 21 A Ordinarily on a job you would contract shortly 22 before you drive the piles. 23 Q Do you mean maybe six months before ? 24 A Could be on that order. 25 Q Then you would not be surprised to learn that Eechtel 1 ALDERSON REPORT
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5 II A Aga'in, bo"ings in that area indicate low blow a y 12 count. r S = 13 q,. Do you remember precisely whqtt the blow counts l 14 ~ y,p,7 /:* g 15 A No, I don 't. m j 16 Q Is there any other indication of pore fill in as k I7 that area? m k. 18 A There is principally low blow counts. E 19 Q What conclusions have you reached as a result 3 of obtaining los blow counts in that area? II A As proposed to underpin the penetration areas? E Q What I mean by my question is what conclusions 23 have you reached as to the conditions of the scil? M A Well, there is loose material there. 4 25 Q Have you reached any other conclusion other than ALDERSON REPORTING COMPANY, INC. ( L
-- -6mi.- -g^ *'.=,n A.,.% > v=~.. n..n ~.;.;3;; w.m. ~ * ~..:-49 : 'mm ~.c v.- --g9u.w 7,... ? ^. - ^- Wf.riTW.';t ~' vt +.~:% kN'M ~~ 19 yy.;_ '"r..-@ . --. g~ 7. ~-P m p p_, -. e~-e .w., t.... _ _.. - ~. v..a - .g. .,M n. . -, -,.., -. ~. - f:?~l7..- a ~ . ~., ~. =.,.. + n.' ~ C ' ' ',' I there is loose material there*? 2 A I don't know what you mean. 3 MR. FARNELL: By a " problem" what do you mean? 4 MR. PATON: I mean do you agree that there is pore 5 fill in that area? = h j 6 . WITNESS: There appears to be based on the blow count. R 8, 7 BY MR. PATON: A j 8 Q And I'm asking you what you know about the fill dd 9 and you have indicated to me that there are low blow counts i h.10 and that indicate: -- did you say -- loose fill -- z_ ) 11 .A Loose or less dense than we had anticipated. is ( 12 Q And I'm asking you, are, there any other indications sg 13 of. the inadequacies. of' that filled material? m l 14 A - I'm not aware of any. 12 g 15 Q Please describe the remedy that 's proposed and a 16 g I'm now talking about the electrical penetration area. e ti 17 A It is proposed to underpin the ends of the electrical -- a a: 18 I Suess they are called the win 5s of the auxilar3. building. E 19 k Is that the same place that you are talking about ? l j 20 Q Can you describe in a little more detail what 21 the proposed remedy is to this soils problem in the electrical l (,, 22 penetration area? l l 23 A Well, they are goin' g to carry the load at the l I l 24 end of each wing of the aux 11arY cuilding down into the i 25 glacial till by means of caissons, so they are going to 1 1 i ALDERSON REPORTING COMPANY. INC.
A~ 5= 5 h: NN 5. ..a ;: z_b + a = W vn . n v.. I transfer the load at that end to the till so that the fill 2 is not supporting it. In the process of doing that, they 3 also have to supoport one of the column walls of the Tushen 4 building which is an adjacent building, or locally they 5 have to column lines, h Q What is going to support the other end of the ^n 7 wing that is going to be supported? A ] 8 A The control building. dd 9 Q Is this proposed remedy going to impose additional I ,.h 10 loads on the control building? E g 11 A I believe it.will. 3 y 12 Q Was that taken into account in the design of El 13 the control building? i = l 14 A I do not know that. U 2 15 Q Is that not within your area of expertise? / y 16 A No, it is nat. as l g 17 Q What was'in the original design? What was to / h 18 support this wing that is now going to be supported by E 19 the caissons? 20 A Fill. 21 Q Okay. Do you consider the change from the support 1 22 from the fill as in the original design to caissons resting 23 on till; is that in your opinion a s'ignificant design chan5e? 24 A It would change the design to the extent that 25 a structural engineer should look at the design. ALDERSON REPORTING COMPANY. INC.
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-r k.-i.i C~h.' 3: _-- Q ~ Q ; -5 Q +h. . Qgp y,+.; ):-:~ n-x ,.- x. =' m; ~r., -v - 55 I BY MR. PATON: 2 Q Do you have any idea of the dollar cost of the 3 proposed remedial action for the electrical penetration 4 area? 5 j A No, I don't. n a 6 Q Do you have any idea of the proposed cost of K'f7 the remedies th.at are proposed to resolve the soils problem j 8 at the Midland site? dd 9 A No, I don 't. 4 2 $o 10 ~ Q Is there anyone in Bechtel that would address @' II that subject? 3 y 12 A , 'm.sure there must be, but I don't know who I. 3 5 13 that woul.d be. ca = I4 l Q Do' you have any idea who that would be, for example, e g 15 the comptrol'ler or there mu'st be someone who addresses d I0 problems like that. as h II A Well, the project engineer probably knows, but as 18 I don't know for sure. E II g Q Do you mean the project engineer -- 20 A Of the Midland Project. 2I Q The Bechtel Project Engineer? 22 A The Bechtel Project Engineer. 23 Q And is this the gentleman that's on the site? M l A No, he is the man in the office in Ann Arbor. 25 Q And is this Mr. Curtis? Did you ever hear anyone ~ ALDERSON REPORTING COMPANY, INC.
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== e - ,v w I in Bechtel discuss the cost of any of the remedial, actions 2 that are proposed at the Midland site? 3 A I do recall hearing a cost discussion once. 4 Q What did that consist o'f? 5 A = I It was a discussion of some analysis of different l 6 procedures for correcting the diesel generator building.. R b. 7 Q ~ Do yo,u remember any dollar figures that were M 8 mentioned? dd 9 A No, I do not remember precisely any figures. 2, h 10 Q Who'was at that meeting? i.F II A The person that I recall discussing it was Carl 3 y 12 Wiedner. It was a personal communication. 5 g 13 Q, You have.been with Bechtel for 21 years. Can .g 14 you tell'me generally how Bechtel resolves matters similar El 15 to this where an obvious error has been made and there c: 3[ 16 is some substantial cost to remedy that error, how is that as l 17 generally resolved as betwe.en Bechtel and the Applicant? E g 18 MR. FARNELL: Would the court reporter read back the E 19 last question. 20 (At which time the aforementioned 21 question was read back.) 22 WITNESS: I don't know, l 23 ( BY MR. PATON: 24 Q In 21 years, have you seen any other situations 25 like this where an obvious error has been made and remedies I ALDERSON REPORTING COMPANY. INC. u
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Q 3 57 . -: y.... x P I of substantial portions and remedies have to be proposed 2 and made? 3 A Yes, I have recalled other occasions. 4 Q Can you tell me briefly what was the most recent 5 = one like this that you can recall? E 3 0 MR. FARNELL: I'm going to put an objection on the 7 record, I think this is just totally, completely outside 2l 8 the scope of any permissible discovery'in this case. I'm d* 9 going to let him answer it, but I think it is a waste of 2 10 his time and our time. - And also, I'm going to ask him = 5 II to not disclose any discussions he has had with attorneys ~ a j 12 within Bechtel with regards to these matters. 5 5 13 MR. P,ATON: Since you have stated on the record that = l 14 you think this is.a waste of time, I think it is appropriate g 15 that I make.some response. 'I have been -- z E 10 MR. FARNELL: That may be more of a waste of time, as h I7 but go ahead if you want. E 3 18 MR. PATON: I don't know why we are Setting into the h 19 g same acrimonious -- 20 MR. FARNELL: I'm siniling. II MR. PATON: Okay, good, you are smiling. I have been E attempting to find out from some Bechtel personnel, it 23 seems extremely obvious that an error of major proportion:: M has been made here, and I would have to assume that 1:here d is some arrangement between Bechtel and Consumers as to. who is '~ ALDERSON REPORTING COMPANY. INC. W
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. s v. I i , I believe the sequence of construction was not 2 the sequence that we -- that my group 's personnel had recoc= ended, 3 and that resulted in additional settlement. 4 Q And was that constr'ution done by Bechtel? 5 A It was managed by Bechtel. e* 6 { Q Do. you have any idea in that instance the cost %S of the remedial. actions ? A 8 '8 a A No, I don 't. dd 9 g Q And you have no idea as between Bechtel and the og 10 people they were contracting with to do that work, who z Ey" paid for that remedial action? d 12 z A ,No, I do not. 3 13 j Q And your statement is that in 21 years -- strike B { 14 that..In 21' years, can you estimate approximately how 2 15 many instances you have seen similar to that where work a= g" 16 was done on a contract with Bechtel and a major error was 6 17 made requiring remedial action? a b 18 = A Okay, I can only recall two other occasions, t 19 l Q And in your 21 years with Bechtel, you don't i "O ^ can't give us any information on how these matters are 21 resolved as with regard to whc pays for those remedial 22 l actions? 23 MR. FARNELL: You have asked him that at least twice, 24 l he has answered it at least twice, which is in my opinion 25 totally outside. I think you are reelly pushing limits here. i l ALDERSON REPORTING COMPANY, INC.
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3 18 Q Why are you using caissons here and piles in E I9 the case of the surface water structure? g 20 A In the case of the electrical penetration it 21 is because of the access to the work, you could not drive 22 piles there, and also, in that particular instance, we 23 do wish to investigate the stratum to which we go and make 24 sure that the caisson is seated in the glacial till. 25 Q In the case of the surface water structure, you are AI.DERSON REPORTING COMPANY, INC.
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..=.yg.a..W: 9- .4 = ; Q. ^L..r' 3 w _-- g :. Q ~-. ' - 3.~.~;,.Jr 4 w,. x .o e 61 . cc,. w.. I not goin5 to investigate the stratum to be sure that it is 2 installed? 3 A I did not say that. 4 Q Okay, we are doing it by another procedure, which 5 j I discussed earlier, now, when I asked..you a.:similar question a 3 6 to what I asked you with respect to the surface water structure, n' 7 and that is: what do you need to know about the soil bercre 2 j 8 you design the caissons that will underpin the electrical dd 9 penetration areas. .zoy 10 A. Okay, the stratum that we are going to -- we 2 11 already have a lot of information on. The glacials till a y 12 .in which the, ma(or. structure is under, the main concern ~ 5 y 13 is that the caissons.:being sent into that 'till, so we need a = 14 to inspecti the bottom of the caissons to make sure we are g 15 in that till. = j 16 Q My question was what do you need to know about as h I7 the soil before you design the caissons? = 5 18 A You need simila:- information to that, that I E I9 g mentioned at the surface water, we need to know the soil 20 stratification, what is fill and where is the till. 21 Q Do you need to know for example, the soil, conditions, 22 is your answer the same as before that you need to know 23 soil conditions and that would include. soil classification M which is gravel, sand, clay and silt; is that correct? 25 A That's correct. ALDERSON REPORTING COMPANY. INC.
. 5. k ~. -y.r &_ " ? s..s, -:a::.:*;~ '~ n. x :,,:.,. w .w .. - a. g.,. :: u.r..a. --v.-~. .u~.e.,~w-. - - - ~ - . p e.. ~.. 2 -, m j r _ -- . T, - ~~. s.- ~;- T..* %. .pg -- Q What is the. source of the informatio h hat you 2 have with respect to the till? 3 A The' Dames and Moore Reports? 4 Q What is the approximate'date of that Dames and 5 - Moore Report? j a O A My recollection is that there are two and I believe R
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they were in the late '60s, 1969 or 1970. X 8 Q _You indicate'there are two Dames and Moore Reports. d d 9 z. A I believe there are two, I was not working on Cg 10 . the project at..that time. Z 5 II Q .Do you know if those reports have been'provided 3 d 12 z to the NRC7 e g 13 A I would assume so, but I don't know for my own- = e 5 14 personal knowled e. I believe there were appendices to 5 _C [- 15 the PSCR in which case the NRC would have them. = si I6 Q Do you know whether there are any cracks on the w 17 I k penetration area structure? wz 18 A No, I don 't know that. I don't recall it any-E 19 g way. 20 Q How often do you visit the site? 21 A Very seldom. 22 Q In the last two years, how many times have you 23 been to the site? .[ 24 A Well, that 's ' 79 and '80 ? 25 Q Ye s. ALDERSON REPORTING COMPANY. INC. ~
~- .n.c A~-5lC h C.':: ' Q &5 g-g=y'5f? . >,. z :.,g.a. 3:. - -n- ~_.,. 'sc. m,. v. ~ I A Probably thre e or maybe four times. 2 Q And in those three or four times, when you go 3 to the site, approximately how long did you stay there? 4 A 'Usually for a day or two days. 3 5 Q And when you go there, do you go just to meetings ? j 6 or. do you go around and inspect and make a physical inspection C 7 of the site? M g 8 A The purpose of my visit has been to attend meetings, d( 9 I take the opportunity of looking at those areas that I zog 10 can see' just for persons.1 interest point of view. E II Q .In the last 3 two years, how much time have you I 12 spent other'than at meetings out looking at the site itself? 5 g 13 A Cou?d you repeat that question please? mj 14 q .Yes. You indicated that in the last two years, D 15 you have been to the site either three or four times. = g 16 A Yes. as N 17 Q And I want you to tell me how much time you have 5 !E 18 spent outside meetings, in other words, I'm not askin:; e 19 g you about meetings, I'm asking you about how much time n 20 have you spent on the site looking at or inspecting areas 2I of a site and the structures on the site. A I don't know precisely, but I would'say maybe 23 half a day each time I have been there. [ 24 i .[ Q When is the last time you looked at the electrical 25 penetration area? ALDERSON REPORTING COMPANY, INC. ~
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,..,..-~~-...x...->e.~.u.-~~--. As. ~. .~. t,'m.,',.34;c we mp-s= .. ~.... I b G en I have $ Mis"SN NN&Wn A ~ 2 penetration area and that would have been some time in 3 1979, I believe. 4 Q Around - '79? e 5 A '79 or lata '78. h O Q. And do you not recall any cracks at that time ? -n b.7 A I do not recall having seen any cracks. l 8 .Q Okay, now my question is do you have a distinct d d 9 z. recollection that there was n'ot any cracks? 10 A I would not say that. = II ~ Q-Do you have any knowledge of any contract with it d 12 Eechtel concerning the underpinning of the electrical penetration z-3 5 13 area? m co E I4-I'm not aware of any current c.ontract' for underpinning A b $.15 there. u i[ I6 Q Are you aware of any negotiations or conversations e C 17 3 concerning a proposed contract? ~c 3 18 A It 's my understanding that there were negotiations E I9 g with the potential low bidder -- or I'm not sure if it i 20 was a low bidder, but a selected sub-contractor, sometime 21 about the tilaa that the stop-work order came through. 1 22 Q By the "stop-work order " -- 23 A I mean the December 6th letter or whatever it 24 , s. 25 l Q All right, December 6, 19797 l -l ALDERSON REPORTING COMPANY, INC..
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'A '79 2 Q What was the status of that contract at that 3 time, I mean was it just being discussed or negotiated - 4 or did it exist or what? = 5 A I really don't know that. It's not something h j 6 that I wouldntt normally be.. aware of. R b 7 Q Okay, who did you hear talking about it? M ] 8 A I believe the first person who told me was Dr. d. d 9 Davisson whom I mentioned earlier. .2o h Q Do you reca11'anything more about what he told 5 II you other than what you' have just said? m y 12 A Not.really. 5 13 5 Q . Do you recall who the other party to the contract m E I4 was? h h 15 A Yes, I'believe it.was with a firm and I'm not a j 16 sure of the complete title of the firm, but it had Mergantile e N I7 in it. "zw II Q Do you know whether that contract included the I: I' g design of the caissons? E A~ I really don't recall that. 21 Q Who in Bechtel would know about this contract? A The project would know -- the project engineer. 23 Mr. Curtis. M ,[, Q Mr. Curtis spent his time in the office in Ann 25 Arbor? ALDERSON REPORTING COMPANY. INC. ~
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divisions, and.I'll have to read them off to you,. San Francisco N j 8 Power Division, Ann Arbor Power Division, Gaithersburg d q 9 Power Division, and Los Angeles Power Division. 2 Cg 10 Bechtel Incorporated consists of a number Z 5 II of divisio'n's also-of which Hydro and Community Facilities a f 12 Division lis one, Mining and Metals Division is another -- 13 and I doil't recall the others right now. m l 14 g. All right. And is Bechtel Incorporated headquartered .9. g 15 in San Fransisco? = g 16 A Hydro and Community Facilities is in San Fransisco. e C 17 d' There may be facilities of Eechtel Engeineering that are c 3 18 not. I don't now that precisely, i:: 19 8 Q All right. Thank you. Do you know whether Dr. n 20 Afifi has any knowledge or input into that contract that 21 we have just been discussing? 22 A Do you mean the contractual discussions? 23 Q Yes. M A I do not know. 25 Q Now, referencing the contract that you indicaced was ~ ALDERSON REPORTING COMPANY, INC. -I
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=" 67 , m c Y-. . a, I with an or5ani:::ation that had the name Mergantine in the 2 the title and - 3 MR. FARNELL: I don't think there has been established 4 that there was a formal contract. e 5 5 MR. PATON: I think you are correct. + 3 6 3Y MR. PATON: R E 7 Q It was at least some ' discussions of a contract ; 3 j 8 is that. correct? dd 9 A. I think what I said was that I had heard that .zeg 10 there had'.been negotiations but I don't know what the status Z 11 was. m ( 12 Q And to your knowledge, that contract concerned 5 ~ 5 13 the electrical penetration area? a = E I4 A That is correct, the underpinning of the electrical G g 15 penetration. = E I6 Q Do you know whether Dr. Afifi provided any input is f I7 such as plans and specifications or any other input with ea 18 respect to that proposed contract? i: g" 19 A I do not know the. extent to which he might have 20 submitted information. 21 Q Now, I'm returning to the question of what you 22 need to know to design the caissons in the area of the 23 electrical penetration area, and your first response was 24 you would have to know the conditions of the soils, the 25 soil conditions. ALDERSON REPORTING COMPANY, INC.
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.m a ,- g n f.+ d ' h :: Y'? v...;- M d ' Y R - 1 5 E '?:: '~~' $ $ $L * *: ":NY.2#~ ~ ts ... n .e' I A It is a rather heterogeneous stratum in some 2 are as. 3 Q It is one stratum made up of a lot of different -- 4 A Lenses. y 5 Q .-- a lot of different types of soil? 8 I E A Several different types of soil. R I Q And you consider that one stratum? X g 8 A I was considering it in the way I was using it d ci 9 in the way I was when I responded to your question. I h 10 Q Do you have to know what the make-up of that l 3 II stratum'is? In other words, do you have to know what percentage a g 12 of gravel, what percentage of sand, what percentage of 5 5 13 . clay, e,tc?' s a t E I4 A Not necessarily in this case. m g 15 Q All right, then I think you are telling me that a d l' all you need to know really is the depth of that what you w h 17 consider. one stratum? m 18 A The cost important thing is the depth to the E II ' g till stratum and in this area you need to know the depth E to the water table because that is also something that 21 must be taken care of in construction. 22 Q Did Bechtel know those things on December 6, 23 19799 M A Yes, I believe they did. 25 Q Do you know whether they had conveyed that information ALDERSON REPORTING COMPANY, INC.
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.M ] 8 the road-bearing capacity of these caissons, don't you? O d 9 A Would you please reword that question? ,z 10 Q Ye.s, I think I better. In order to design the 4 II caissons, do 'you have to know the sheer strength of the 3 g' 12 soil on which the caissons will rest? 5 5 13 A. In order to determine the factor safety against = b I4 the sheer' failure, yes. ? 2 15 Q And how do you -- 5 !l 16 MR. FARNELL: Would the court reporter read back the se 17 last question and answer. ai' 3 18 (At which time the aforementioned E D g question and answer was read back.) 20 BY MR. PATON: II Q On December 6, 1979, did Bechtel know the sheer 22 strength of. the soil on which the caisson was to rest? 23 A Yes, I believe I answered previously that we 24 had all of the data that Dames and Moore produced. 25 Q This is the data that Dames and Moore produced 1 ALDERSON REPORTING COMPANY, INC. l
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2 73 1 A I think what I said was that that information 2 was in the Da=es and Moore report. ^ 3 Q Okay. Prior to December 6, 1979, did Bechtel 4 ever put that information about the sheer strength of the = 5 soil in. the till into an analysis to estimate the load h ] 6 bearing capacity of the caissens in the electrical penetration R 7 area? Xl 8 A I don't recall for that specific date. 'I would' d 9 assume if it was done, if there was negotiations for contract, g 10 but I don't now that for sure. Z1 11 -Q Would that have-to be done prior to the contract n ( 12 being let?- z3 5 13 A. .I'm sure somebody would have looked at that. a l 14 q,' The point is you would have to apply that information E g 15 to determine what kind of caissons.you were going to buy; I a si l' is that correct? e ti 17 A Not kind, what size.
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What design? Do you participate in any discussion E 19 as to any alternative remedy for the problem at the eldctrical 20 penetration area? 21 A I don't recall having discussed an alternative
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23 ( Q To your knowledge, did anybody in Bechtel ever M consider any alternative to the use of caissons to 25 l underpin the electrical penetration area. 1 i I ALDERSON REPORTING COMPANY. INC. ~ l
.k ?i~:~%;--,. fr ~ 'Y ~ ~ z.ib x :... - m - L. % ;*.. - ~~ 4. w. n.-..~~~ fr".??LE ?.- r..v.I-T' D "'~ Y ~ ^ I don't recall that'.- A 2 l Q Wouldn't it be normal engineering practice co i 3 consider some ' alternative to a proposed fix? 4 .A 'My answer was that I dori't recall. I did not 5 say that it had not been done. I Q In the normal course of your responsibilities, R 7 do you think you would have participated in such discussions 3I 8 if they took place? d I A Not necessarily. 10 Q Who would make a determination like that? II MR. FARNELL: Determination of what ? m I II MR. PATON: As to possible alternative remedies to S I3 j the -- l 14 MR.FARNEh,L: Determining -- 15 MR. PATON: Possible alternative fixes or proposed = ai l' remedies to solve the problem at the electrical penetration m h I7 area. 18 WITNESS: The project structural engineer. E I' g BY MR. PATON: 20 Q Okay, I believe you indicated you don't know that 21 person's name? 22 g 7,m not certain of his name and that's why I'm 23 ; unwilling to mention it. M Q It's not Mr. Dahr, is it? 25 A It could be Mr. Dahr. 'l ALDERSON REPORTING COMPANY. INC.
. u. 7.y d u ~- % : k*~~ ~ v.. eM 5[= ~'WYb ':9fW, ..s 1 Q Whoever this persen is as far as you know, his 2 office is in Ann Arbor? 3 A That's correct. 4 Q Do you recall any discussions by anyone within 5 Bechtel as to alternative remedies in the surface water l 4 structure, for the surface water structure? I 7 A Yes, I do recall discussions, I do not recall 3 8 who'they were with, but I do recall discussions. da 9 Q Do you recall any possible alternative to the 10 underpicning that was discussed? l 11 A Yes, I do recall that there was discussion on a i d 12 alternativas. t 13 Q But, you don't recall -- l15 14 A-I' don't recall who it was with. Q Was the question of cost included in those j 14 considerations? e ll 17 A I do not believe cost entered into the discussions a b 18 that I recall. E 19 Q Yon don't have any clear recollection that cost X 20 was not considered. 21 Q I don't recall that either. 22 Q The usual practice would be t6 give some consideration 23 to cost, would it not ? 24 A Yes, of course, good engineering practice would 25 require a consideration of cost. + ALDERSON REPORTING COMPANY. INC.
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I4 BY MR. P,ATON! C 15 Q Do you have an opinion? E 30 A Well, I believe good business practice would also. m N 17 Q Would also consider that you would consider cost w h 18 op. good engineering? E I' g A Good engineering practice means you are designed M to meet the designs criteria at the lowest cost. So, from 2I an engineering point of view, consideration is of great 22 importance. 23 Q And you have answered as of engineers and I'm 24 asking is that also as of good business practice? 25 A I just answered that, I believe it is also good ALDERSON REPORTING COMPANY. INC.
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I . -c. v. c- .a I business practice. 2 MR. PARNZLL: He already answered that. 3 Would this be a good time to break for lunch? 4 MR. PATON: Yes. 5 (At which time a one-hour lunch break j 6 was taken. And the deposition was resumed R I 7 after lunch.) 3I 8 BY MR. PATON: rJd 9 Q Mr. Ferris, sometime ago, I believe you indicated 10 to me in response to the surface water structure that it j 11 was your opinion that it was not good current engineering s [ I2 practice to estimate load bearing capacity of the soil 4 g 13 prior to loaditest; is that what you said? l 14 A
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. _ _ hi; ~; ':?.'.N4?~ . i-3 d : -UI2h i~T.L: y,g.,:,. W n C-Q. a .v .; u. ....a e<.-- I Q Okay. 2 A And since that time these procedures have started 3 to be used. 4 Q What is your source of information that indicates 5 to you that change in thinking in the last ten or fifteen I years? How do you know that ? R 7 A. Major. source? 3 I 8 Q Yes. I would like to know all of your sources. d A Basically, discussions with Dr. Davisson. g 10 Q Discussions on work with Dr. Davisson, would k II you say primarily your discussions? I II A, . Right. - 5 g II Q Mr. Ferris, have you read the December 6, 19'79 l>< ord.=, 2 15 A You just showed me that, I believe; is that the a d I' one you just showed me this morning? w h II Q No. I8 Q Then I probably have, but I don't remember. s II g Q Do you rememebr the term " acceptance criteria" in that order? 21 A I don't remember in what context it was used. 22 Q Does the term " acceptance criteria" mean anything 23 to you? M ,A It does to me. I thi you need to tell me in 25 what respect you were using it. ALDERSON REPORTING COMPANY. INC. i
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.{; p554 1[;' - ++,? 755?,$ :.I - -, w ,_.,.m..., ..... a n. (?C) 80 o,.%. a h5 n.- -. r .r. .>~~~~# '~ ,s . *c, 31% ,.*,.u. a m'I. - > v. Q With respect to the proposed remedies, the re=edies 2 th t are proposed by the applicant, say for example, on 3 the surface water structure, does the word acceptance criteria 4 have'any meaning to you with respect to that proposed remedy? 5 A Yes, I believe there are proposals -- in fact, I 6 I know there are proposals to do things there to satisfy 7 us, that we have appropriateicapacity in piles. l l 5 R 8 Q You said there are proposals to do things there dd 9 to satisfy us that we have - 0 10 A It's my recollection that in a meeting with the II NRC at Midland in about Feburary last year, that there a I II was a discussion of what was to be done at the surface y g I3 water structure. l I15 I4 Q .For the purpose of satisfying the NRC's review? A Cur primary purpose is to satisfy ourselves and a E I' the intention is, of course, to reach agreement with NRC. w h I7 Q Do you know what particular -- can you give me 18 an example of an acceptance criteria as you understand l E I' g 10 7 20 A Yes. It is my' recollection that each of the II piles at the surface water structure was going to be tested 22 to one and a half times it's capacity, it's working capacity. 23 i: Q And when was that to be done? i 24 ' A After the pile was installed, and before the' 25 pile load was -- before the load of the building was transferred ALDERSON REPORTING COMPANY, INC. 9
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14 that they'evaulate and accept it? 15 8 A My feeling is that they should not accept it 16 aid on one item out of that structure. ti 17 m g Q I think we can go through the same exercise with I. all the proposals I want to see how this particular one 19 W works. Would you expect NRC to accept it on whether or 20 not it met the criteria? MR. FARNELL: What do you mean? I'm confused. MR. PATON: He has just told me precisely what he means by acceptance. WITNESS: If you don't mind, I would like to answer it as I understand it. I be'11 eve we have told you the ~ ALDERSON REPORTING COMPANY, INC.
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a.r 4: ; 7.c ::,n ;~ a h v"' ~W ,w.-%. .a ;.: Q.5 y 2:,- &,?Q '~;.,[..}.:, ;;[,.. ~ ~ a7 ~. :. 1 , they have to know what the dynamic loads are to be imposed 2 on that pile? 3 A Somebody would have to satisfy themselves that 4 we have enough piles in the structure to take care of the 3 5 2 loads that are coming on the structure. I O Q k7 ' Well, then are dynamic loads to bo imposed an acceptance ~ 3 criteria? l S A Not for the installation of the piles as such. e d 9 i As I understand your question. 10 Q Do you agree that you have to make that determination .g 11 a at some t1=e7 ( 12 = MR. FAR! ELL: Which determination?, 3 13 aa MR. PATON: The dynamic load' to be imposed on the 14 pilings'. j 15 E.16 That must be included on the design. WIT!ESS: g d BY MR. PATON: 17 Q Before installation? 18 l 19 A Certainly, before you come up with a design for I the foundat,1on you must know what it is you are designing 20 for and the loads is one of the most important things. 21 Those are one of the most importhant things. 22 Q Did Bechtel know on December 6, 1979 what the dynamic loads were 24 to be proposed on the piles for the proposed surface water structure? 25 i 1 'I ALDERSON REPORTING COMPANY. INC. l f.
n..... $ 5.;:.Yul kY 1 i'!*' ~~ 'h C _w. 88 e:.~,:.....u,n, ...e 4 ( b' ~ ., ~,. an y ~ .+ .n. .,y, 4 4 s I A I do not know. That is not in my area of expercise. 2 Q Does the 75 con pile load capacity corporate 3 seismic loading? 4 A I don't know the answer to that, what I 61Ve - 3 3 you is my recollection of what I heard in the meeting in 2 3 6 February of this year. 7 Q Have you heard any discussions among any people 8 at Bechtel as to the meaning of acceptance criteria? d 9 A The word is used very aften. I don't recall 10 being party to a specific discussion in it. a h II Q In your professional experience, excluding for a. l 12 a minute NRC's use of that perm, is that a term that you S g 33 understand other than its use 1,n connection with the i 14 .NRC7 II A Well, I would understand that use of terminology, a d I6 but it would have to be in some context. a h II Q Okay. Do you consider demonstration of an adequate 18 margin of safety against bearing capacity failure to be E I9 g necessary to accept your proposed remedial measures? 20 MR. FAR!! ELL Could the court reporter read back the 21 last question. 22 (At which time the aforementioned 23 question was read back.) 24 MR. FARNELL Are you talking all remedial measures? 25 MR. PATON: Ourface water structure. ALDERSON REPORTING COMPANY, INC.
i ..'3tuA-+'?2 % & % ~. ::1.~: % W E E ?:'T.': %:"'. $ 5 k s ~~- C *C M Y g ..e" * . ma.. ...z 89 1 MR..FARNELL: I guess Ihave a vagueness. objection. 2 I don't know what adequate margin of safety is. 3 MR. PATON: That's in his opinion, I mean if he doesn't }, 4 have an opinion, that's up to him. 5 WITNESS: There may be other criteria that I'm not = h '3 6 aware of, but that is certainly one of the important criteria. 3 ....y 7 BY MR. FATON-M] 8 Q' Okay, so that in your opinion, demonstration d M 9 of that margin you consider that necessary? ,2 h 10 A Yes, I believe I have already stated that several Z_) 11 times today; 3 g 12 Q .Would you say the. same thing for demonstration
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G M u. .~ ...er .m - - w nn.=~-~~~~- W. -.'.~. m... _., 5. ~. p_?= '"-1"~cEtui ants, I'm not ' sure tha[; 'I can" tell you WTth respect .S. 2 to all of them. On the first trip that I made to Midland, 3 following the problem that we have been discussing here today, 4 the settlement. problem of the diesel generator building, g 5 I was asked by Phil Martinez to nominate consultants in E 3. 6 the area of soils. R C I .And I had a discussion with him at which a j 8 we discussed the possibility of Dr. Peck being the consultant. dd 9 I pointed out to Mr. Martine: that Dr. Peck is very busy, ,z 10 much sought after consultant, and I thought there was a Z 5 II very good chance that he cotild not spend as much time on 3 Y Ik his job.as was.possibly required. 5 5 I3 And so I made a suggestion to him, to Martine::, =>5 'I4 that-we'ask both Dr. Peck and Dr. Hendron to be consultants .j 15 in the area of soils for the evaluation of the diesel generator = d 16 building on the understanding that Dr. Hendron would be as C-17 g the more available of the two and he and Dr. Peck when E 3 18 they could would review their work amongst.themselves and E I9 g then provide us with their evaulation of those areas that 20 we reque sted. ( 21 I believe Sherif Afifi.was present with 22 me when I had the discussion with 'Martines: and I believe 23 it was in the Ramada Inn in Midland is where we had the 24 discussion. 25 BY MR. PATON: ALDERSON REPORTING COMPANY, INC. ~ ~ m
~ 'E % ~ ~ x., Y:5dI*]h*ET1** ~.". Q5&l_ 4: 'U$l1 ..? 3..g,g- & ~ ' E ::-Y :' ..e:N.- g .c ..,c-;. 91 I Q You have indicated, however, that it was your 2 idea. l 3 A It was Mr. Martinez's idea that they required 4 a consultant and he asked me to recommend one to him. I g 5 did and he accepted the recommendation that I made. ? 3 6 Q Did the name Dr. Peck come to mind because of ~n'8 7 your knowledge of his reputation in the area? N ~ l 8 A Of course, Dr. Peck is one of the best known d x. 9 }. soil engineering consultants in the world. o h IS Q Do you know how many hours your consultants such =! II as Dr. Pect and Dr. Hendron had spent on the Midland soils s f, 12 Problem? I mean do you keep records like that ? a 13 j - A I don't keep records lik.e that. E 14 = MR. FARNELL: All consultants? $9 15 13 MR. PATON: Let me stick with Dr. Peck. f 16 WITNESS: I personally do not keep those records. as hI BY MR. P ATON: m b 18 = Q Does anybody keep records like that ? k 19 g A I believe that there may be records like that. 2a Q I gather from the answer you don't really know 21 for sure. 22 A Well, Dr. Peck bills us for his work and I believe 23 you could from looking at. his bills over the past two years - i 24 determine the number of. days of work that he has done on 25 the Midland Project. But I don't keep those bills myself. I ALDERSON REPORTING COMPANY,INC. i .. ~ -. _ {
-.:"l85.;=.% W - - - < ^ TWR. . -a w .y - ??b 7$$52!$ v.y:1.s 1 -~ w :+. - ~ -,.:..r - -. + a.:;~; ^ ~ .. x x. %cyr.:r:n.y. e% e,2 .-j; & ; ,~ : r, o a ~ :?-: -'* W~ '. 1. ._,, ; 43, ;, vu, s.. -. m : ~ s"* ~ &N. ( j c. 4. _... ..q. - m m - - ~ " " - '{'-' ' 'y " ~ ~ ~ (/ ~" ~Z*~ z 5.2 n..a - - - - ~ 9 ' ~~ Y ~ ~ Q Do you know who does? 2 A ' Yes, our accounting office would, but I don't 3 know how long they keep them. 4 Q I assume you don't have any way to estimate how 5 j =any days Dr. Peck for example -- a. 3' 6 A Not right now, I don 't. n' 7 Q And would your answer hold generally true for 3l8 other consultants like Dr. Hendron and Dr. Davisson, you d d 9 don't know? You can't estimate for example., the number z C> 10 of days they have spent on the project? o -!U A That is right. I could not tell you today how 3 6 12 many days he spent on that specific project. 3 13 j Q You stated before you have read Dr. Afifi's' deposition. E 14 g A Yes, I did. e: C 15 g Q Ed.ve you read any other depositions in this case? f 16 A The only other deposition I read was Mr. Kane's as I7 deposition -- or a portion of it. I8 Q i" We finished one portion of Mr. Kane 's deposition fI9 that took p' lace on three separate days -- 20 t l A That 's probably the time. 1 21 Q As far as you know it was three different transcripts? 22 A I can 't recall that, but it was more than one l: 3, . volume, and probably it was over two or three days. 24 j Q Now with respect to Dr. Afif1's deposition -- 25l A Yes. i ALDERSON REPORTING COMPANY,INC. ~ m.
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.u".*~e ~ .y,,- e 1 evaluation of some of our proposed analysis is not in agreement l 2. with my evaluation. 3 Q All right. I would like very much to get whatever 4 -detail I can, for example, tell us what evaluations. g 5 A Okay, I guess we should go through them one-N 6 by-one then. $g 7 Q Yes, sir. A 8 A Why don't you call it out and I'll tell you what dd 9 I recall. ieg 10 Q I don't know what it is that you disagreed with. E ~s 11 A I believe to start with the service order, intake <m ci 12 .g. structure, he. wanted to evaluate pile capacity using soil S 13 perimeters as we discussed earlier. I believe our evaluations E 14 for. pile capacity is a better*way to do it. N 15-On the diesel generator building, his evaluation
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16 cf the effect of the preload is not consistent with my as .g 17 evaluation, it affected the preload on the compacted fill. M 18 Q I would hope you would go on and tell us in what ways. { 19 A I believe he has some concern about whether or i n 20 not the preload was kept on long enough and I believe the 21 data showed that it was. And I don't recall anything on 22 the other facilities that were to be corrected. I did 23, not agree that there was a signed technical basis for requiring 24 the additional bcrings that are requested by the court i 25 l engineers and of course, Mr. Kane has defended in his deposition. I I i I I o ALDERSON REPORTING COMPANY. INC.
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building. h j 6 A Sure.. R R 7 7 Q You indicated that you believe the surcharge ] 8 was. left' on long enough. d 9 .A Yes, I do. .z 10 'Q What is your basis for that? E h II A My basis would be the results of the piezameter 3j 12 and settlement analysis, settlement ratings, I mean, ci g 13 Q What was 1-t about the piezometer readings? l 14 A The excess pore pressure had discipated which E g 15 ordinarily 'is the manner in which you determine the prim"y a 5 I0 consolidation has been completed. 4 W h II Q And you also said the settlement data? z { 18 A Ye-s. When the settlement data are plotted on E II g a semi-log plot of settlement versus time, they do reach E straight line portion and that straight line portion extended II for a sufficient length of time to indicate to me that 22 secondary censolidation was taking place. 23 Q Was that about a year? A No, it was not a year, -it was less than that. 25 The complete load was on in early April' of 1979 and the ' load ALDERSON REPORTING COMPANY, INC. wy r, ,,---t- ---y e w w -wv.- -_y +w" w +-
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was taken off about the middl'e of August of 1979, so it was .2 about four months. 3 Q Do you understand from the deposition what Mr. 4 . Kane's giosition is with respect to the need for additional 5 = borings? h 5 6 A Yes, I do. R 7 Q What.is his position? Al 8 A As I understand it, hiewantstotakeundisturbed d 'I 9 samples and evalu' ate the preconsolidation pressure of the zCg 10 .caterial in the fill beneath the diesel generator building. ~ 2 i II And he al'so wants I believe to predict what settlement 3 ( 12 might occur. But as I understood his deposition, he, was 4 i g 13 primarily interested in the preconsolidation pressure to, m j 14 compare that with the preload fill. b g 15 Q Is it your understanding from reading Mr. Kane 's x E I0 deposition that he thought the information from the borings ad j 57 was more significant than the information to be obtained E 18 from the surcharge program? E II j g A It is my impression that he needed that information i 20 before he would have believed the other. 2I Q And is it your thought that the information obtained 22 from the surcharge program -- strike that. In your opinion, 23 j is it possible that some valuable information would be 24 obtained from the additional borings? 25 MR. FARNELL:_ What is your definition? l ALDERSON REPORTING COMPANY, INC. j
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f.' 1 in that regard. ~- 2 A I don't believe that's possible. 1 3~ Q And can you tell me why? Is it due to the hetero 5eneous 4 nature of the fill? = 5 A I can try to explain why. First of all, the 5l 6 preload fill is a full scale loading of the soil, so it R 7 is independent of whether or not the fill is heterogeneous. A j 8 Q I apologize for interrupting you, could you start d 'i 9 again? z h 10 Would the court reporter read back the MR. FARNELL: z E .last question. 11 m g 12 (At which time the last question 5 5 13 was read back after a brief a l 14 e interruption.) != 2 15 W m .E 10 BY MR. PATON: e d 17 Q Does that complete your answer? a "i g 18 A No, it doesn't. That was the first item. The E 19 g second item, we have checked that the preload fill has a 20 done what-we intended it to do, that is take 'ouz the primary 21 consolidation that 's been done in two ways, one by the' 22 piezameters and that is -- the piezometers show that the 23 excess pull pressures have dissipated and secondly, the 24 settlement carved on the semi-log plot has reached secondary 25 I l consolidation. l ALDERSON REPORTING COMPANY, INC. g ,g,.-. r 3w,, + y. h
-~... \\ .s c . f.;.7a-+ - M:f w - w..- c :x - ":*1 G h 1? L"h D $ r N ;i.. ' LS%d" q: r.~ g9 1 The next item is that in my experience in 2 dealing with preconsolidation as determined in the laboratory 3 on soil samples that that is very much affected by sample 4 disturbance, and it may also be affected by the soil itself. 5 E Whatever manner it has, whatever factors it'..has undergone { 6 to reach the state at which you sampled it. K 7 .And I would te very concerned thitt Mr. Kane. X l 8 would take samples and find out from those samples that d si 9 he had a preconsolidation pressure that is being equal ZC 10 .to the overburden pressure at the sample depth, prior to E j 11 any preload'being there at all. m
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~ n., .n,. .. g x +.. ' 4;- ; ~ -D-w... - % 5:E= l'2:-[_ * #: -3.$8hil - h. : :(2:?" ~ \\ s.. .., cs 101 1 Q In reading Mr. Kane's deposition, did you gee '2 the impression that he would take the information that 3 he would obtain from borings, the borings that he has requested 4 that have not been supplied, with respect to the diesel e 5 generator building, and make some kind of a worse case O analysis? R R 7 7 In other words, that if he received a range ] 8 of information that he would use the worse'information d d 9 to make his evaluation? Did you get that impression? $g 10 A I do not recall that I got that i=pression. z J*: 3 11 ~ I would like to recall that I don't recall one,way or the m I 12 other. 3 5 13 . Q It could be then. Are there any weaknes'ses or a = 14 , defic.iencies at all that you are aware of with the preloading aj 15 method of the surcharging method? a f 16 A What do you mean by weakness? e h II A That's what I'm asking you, and is it a perfect a lii 18 method to accomplish what you are trying to accomplish. E I' g MR. FARNELL: Are we talking in general? Are we talking 20 about Midland diesel generator? 21 MR. PATON: I'm talking about Midland. soils.. surcharge 22 Program, diesel generator building. s -. 23 MR. FARNELL: That wasn't the way the question was M formed. 25 MR. PATON: Strike it all. I'll ask it again, w ALDERSON REPORTING COMPANY. INC.
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m j 12 A Yes. 5 13 Q Can you describe the extent to which there are 5a l 14 sand portions below the diesel 5 nerator building? E g 15 A It is my recollection that on the north side z j 16 of the building there is a fair amount of sand and particularly ai i 17 .in the northwest corner. a 3 18 Q Okay. E 19 A There is also evidence of sand backfill along 20 some pipelines that are under there. 21 Q Did you take any st*ps to accommodate that problem 22 that the preloading program may not have compacted the 23 sands? 24 A
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~.. ~ ~ N - : = AS:E~ = '~;WNbb ' % ':?$T . m,y... 103 I A The corrective action proposed, our main concern 2 is that the preload may not have compacted that sand sufficiently 3 to preclude liquifacture in the case of loose sand, and 4 our i'ecommended corrective action for that is to lower 5 g the water table in the plant area so as to preclude the a j 6 possibility of liquifacture and any sand left. n' b I Q That 's to your knowledge, that will be taken n I care of by permanent de-water 5.ng? d d 9 A That is what is proposed. h 10 Q To your knowledge, is that permanent de-watering II proposed solely in connection with sand at the diesel generator a N II building or' is it. also proposed with sand in other areas? 5' 13 g A. It was made as a general de-watering program eg 14 to take' care of any sand that might be located in the plant g 15 that were loose.
== d I6 Q Has Bechtel had any meetings with Dr. Peck in w h.I7 the last three months? E g 18 A Do you mean meetings that I attended? E I' g Q That you are aware of. 20 A The last time that I met with Dr. Peck on the 21 Midland project was at the end of August in Midland. I 22 don 't kr.ow if that 's three months. 23 Q Okay. That 's probably more than three months, pretty close. Have you had any meetings with Dr. Hendron 25 in the last three months since August -- After August? I .1 i ALDERSON REPORTING COMPANY, INC.
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~ a m 5 14 Q Let'me isk you, are there any under the diesel 5 g 15 generator building that are c'onnected to the diesel generator a f 16 building? as 6 17 A I don't really recall where the pipes and conduits a= 5 18 go to, E 19 g Q So, you don't know whether there are any that n 20 are connected or any that are not connected? 21 A I just do not remember that. 22 Q How is the effectiveness of the surcharge program 23 affected by the fact that they are below the generator 24 building that there are,less compressible soils and more 25 co=pressible soils? ALDERSON REPORTING COMPANY, INC.
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z E I6 for you to have made an estimate of the elevation in the as [I7 pie::ometer -- in piezometer elevation prior to imposing F: E 18 the surcharge? 19 g A With such a heterogeneous fill, I don't believe 20 chat such an estimate would have been very reliable. What 21 we were looking for was to see when the excess pore-pressure 22 dissipated completely and that is one way of telling that 23 you have completed primary consolidaton. 24 The other way I mentioned earlier, is to 25 l 1 look at the settel=ent card. ALDERSON REPORTING COMPANY, INC. ~
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111 .m. m. m ~ I Q If the soil there'had not been heterogeneous 2 as it is, would you have made an estimate of the anticipated 3 piezometer elevation prior to i= posing the surcharge? 4 A Probably not. If it was me. 5 j Q What if the soil was homogeneous, would you have 0 done it in that case? R b 7 A Probably not. j 8 Q If it had been homogeneous and if you had made d d 9 . an eatimate, wouldn't you be intereated in determining . 10 how close 'you came to your estimate to verify the performance = 5 II .of.the' surcharge program? 3 g 12 MR. FARNELL: That 's got tivo assumptions in there. s5 'l3 None of which is relevent to this case and I just don't m l 14 see it. I don 't even. understand the question. ' j 15 WITNESS: I think I can answer your question. I think u ij 16 the thing that you have to realize is what we were looking e h. I7 for was when the excess pore pressure dissipates, we were t la not interested in the maximum level to which the pore pressure C g reached.- BY MR. PATON: 21 Q Okay; try it just one more time. Your interest 22 in knowing when the excess pore pressures had dissipated, 23 related to your interest in' knowing when you had reached M secondary consolidation; 1s that a true statement? 25 A Well, when you finish primary consolidation,, u ALDERSON REPORTING COMPANY, INC. ~
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~. k W>=._ s y .. -. x nI- - then you get into secondary consolidation and 1 would be i D. 2 willing to acceot that those two coints would be about 3 the same. 4 Q All rizht, you.iust don't see any way,that your g 5 orior estimate what would hacoen to piecometer level you 8 a 6 don't see that that would have helced your determinations R o C. I at all? 3 8 8 A It would not have heloed our determination of d Q 9 when the or1=ary settlement would be comolete. z C 5 M C Does the level to which' core cressures -- core-3 h II water cressures.would rise have an imcact on stability 5 ( 12 of the deposit being loaded? 0 5 13 A Yes. m ao E I4 Q Eut 'even in place of that, but that doesn't indicate IS ~ to you that,you should esti= ate prior to the surcharge. f 16 what your pie:cmeter elevations are going to be ? e 17 d ,A The preload was put on in steps and those increments c II of loads were small enough that we were not concerned about E l9 g failure of the fill. n 20 g 37, y,7713, 7,m going to hand you a document II on the letterhead of Soil and Rock Instrumentation, dated 22 October 19, 1979, a letter addressed to Dr. Sherif Afifi, 23 signed by John Dunacliff and it has attached to it three M paSes and ask you -- and I have marked it as Staff Exhibit 25 ' 2 and it does indicate that a carbon copy was sent to Walter I
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l 14 A. It was early in August of 1978, I believe I may n l 15 have mentioned it to you earlier today, that I was informed a j 16 by Sherif Afifi-that the settlement of the diesel Senerator e 17 g building was approaching the predicted settlement differing a ti 18 at PSAR. E I' g Q Since August, 1978, are you familiar with what 20 type of instrumentation was used at the site at Midland 1 21 for example, the diesel generator building to measure the 22 settlement? 23 l A Initially, Borris Anchors were put in the ground. ( 24 I believe settlement plates were put on the ground'as well, 25 and then as I mentioned, sometime around about May or so of ALDERSON REPORTING COMPANY, INC. G
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-. g. !=g -.y h 233g,'. %..' E-pq.- ,.,3~. ~.W-5.-l '.[, "~ yg a y,;, r-127 I Q Did you do those in some cases? I 2 A Do you mean some cases, probably most generally 3 we did it. q .'In ' light of your answer that you most generally 4 5 did it.that way, why are you not complying with the borings l.6 requested by the, staff in this case? E 2, 7 A For the same reasons that I didn't do it at some N j 8 of' the. sit'ar where' we did it on. d y 9 ~ q Tell me generally what those reasons are. h 10 a A It's probably simplest to discuss one site, this II is a miping' plant in Nevada, in alluvial fan which is very a y 12 heterogeneous deposit and you cannot get samples there ( N 5 I3 that'you can relate in the way that Terzagk1 and Peck have a h 14 done in,their book, you can't get standard penetration w g ' 15 tests.that are meaningful and you can's take undisturbed a j j 16 soil samples that are meaningful and so there we did a ). al, ('17 preload fills to evaluate the soil properties that we needed 18 to determine settlement of structure foundation. b 19 g Q You said preload fills, do you mean surcharge? E j A Surcharge fills. II MR. FARNELL: Would the court reporter read back the I.. 22 last few question and answers. 23 (At which time the previous two questions (. M and answers were read back.) i l 25 WITNESS: I'm referring to the questions where I was ALDERSON REPORTING COMPANY. INC. ,gr-9 m ..p ,m.,-3 ..m- .,y . -i. a w. .,.g..<.
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13 Q 'You discussed a moment ago a project in Utah; a g 14 is that correct? g? ~ 15 A A' moment ago I discussed a project in Nevada. a j 16 Q Was there a settlement problem at that project? e Y 17 A No, there was not.' a E g 18 Q Is your reliance information from piezometers ~ P g" 19 affected by the fact that the fill is heterogeneous? 20 MR. FARNELL: Would the court reporter read back the 21 last que stion. ( 22 (At which time the aforementioned 23 question was read back.) 24 MR. PATON: Strike that question and I'll try it again. 25 ' BY MR. PATON: ALDERSON REPORTING COMPANY. INC.
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.. m. .m v.. c.,.x .1 Q Is the accuracy of information provided by pie:ometer 2 readings affected by the fa'ct that the fill is heterogeneous? 3 A The accuracy of the piezometer is not affected 4 by.that. 5 Q Is the settlement information affected in any h j 6 way by the fact tihat the fill is heterogeneous? d 7 A' What do you mean by the settlement information? 2 ] 8 Do you mean the settlement at a specific point or the overall d ci 9 picture? 10 Q No, the information you get from a settlement N j 11 marker is the accuracy of that information affected by a y 12 the fact that the fill is heterogeneous. 5 ( j-13 A- .I don't believe the accuracy of the settlement = l 14 marker is affected by the heterogenity of the fill. $l 15 Q: In the project where you took undisturbed samples a 16 ~ g can you tell me how you determined where to take undisturbed ai g 17 samples? E ma 18 A, Which project are you talking about now? E 19 Q Well, I think you indicated there were projects 20 in which you just spoke awhile ago where you did take undisturbed 21 samples. 22 A We took them in the strata that we wanted to 23 know the soil properties as'best we could. 24 (} (At which time a brief break 25 i was taken.) ALDERSON REPORTING COMPANY, INC. i ,w
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= , c m....., x, 130 1 Q Based on your experience do you believe running 2 laboratory consolidation to be a reasonable consolidatten 3 for running consolidation? 4 .A, I would have to say that it is not a very reasonable 5 one, not necessarily a very reliable one. j 6 Before we get off that, I would like to R 8 7 point out that.my response to that was a general response Nl 8 and could be influenced by a lot of other factors. d d 9 Q Was there ever any consideration given to making 10 . settlement prediction
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( 12 A I'm not aware of any. 5g.I3 .'Q . Do you recall any discussion of that in your 14 reading of Dr. Afifi's deposition? 15 5 A ,I do not specifically recall it in Sherif Afif1's' a y 16 deposition.- I do recall that there were discussions at w g 17 tlie time prior to the time of preloading. There were some rough 18 estimates of what the settlement might be. e 19 g Q Who made those? 20 A But there were no calculations. 21' Q Okay. Who made those rough estimates? ( 22 A Dr. Peck in a discussion that we had, I believe, 23 in Champaign, Urbana, he made reference to a pessimistic M upper limit of 6 to 18 inches as the settlement resulting 25 from the preloading film. ALDERSON REPORTING COMPANY, INC.
'Y ...,.. s e. e u s. m r.-- e.<,..,,, g { ;.,'t r a... r. e -- r - w.e. - ~ -- * *, n..~.* v e u-, e e n. =>* ~ ~ ~, -m~~ ~. f;_.yg.:.a :..n i - ~ ~mfL I Q Do you have any ides on what he based that rough 2 estimate? 3 A No, I believe it was just that, a very rough 4 pessimistic rough estimate. I do not believe he did any 5 calculations. I do not believe he had any data to do any ] 6 calculations at that time. RE7 Q He must have known something about the site. 3 I. 8 A No, I believe he was looking at a rough pessimistic d 'I 9 . upper limit of what the settlement might be. One of the 10 factors that he was concerned about is that our instrumentation 5 11 should be able to take care of whatever movements occurred. ,n l 12 Q I'm sorry, sir, I don't understand that -- our ( 3 g 13 instrumentation shohld be able to take care of whatever 14 occurred. 15 A ' dell, he wanted to' make sure that when Bechtel m si 18 arrange'd for instrumentation that they would be able to w ( 17 take care, operate, under the most pessimistic estimates a! 18 of settlement that might occur. E II g Q In your recent statement about installation of E instruments, did you mean that you wanted to make sure 21 you had instruments that would measure any possible range (.. 22 of settlement so that the settlement wouldn't exceed what ) 23 your measurements would measure? ( 24 A Yes, we didn't want to have an instrument that 25 certainly the point would -- it would go off the scale or ALDERSON REPORTING COMPANY. INC.
.}<. ;[J . = ;. g.:, +. 4.: 3 -> ..,. x ..b' f -J '. Q q~;; 'L.: _-- & Q -e, ys.. c.- - " ~ ' 132 I something like that. 2 Q Sure. And are you connecting Dr. Peck's 6 to 18 3 inches pessimistic estimate with his -- in other words, 4 that was in connection with him saying he wants to make 5 sure we have instruments that would cover at least this 3 6 much settlement. Is there a connection between those two? 7 A-I believe it was made in the context of giving Xl 8 Bechte1 some idea of what the upper limit of settlement dd 9 might be, but it was not based on calculations because 10 I do not believe that he had the' data to do calculations, II 'nor do I believe he did any calculations. I l.2 Q Okay. '5 g II 'A 'It was a spontaneous comment in a meeting. 3 I4 Q Do you know whether Dr. Afifi gave any consideration 15 to a prediction of settle =ent prior to the surcharge program si. I0 being imposed? e h II A I'm not aware of any. k 18 Q E Let me read you from page 57 of Dr. Afif1's deposition, II g and he'has not read this and corrected it, so let me just 20 read this to you and see if it refreshes your recollection II about anything. ( 22 I was asking him about whether he considered 23 making a settlement prediction part of the surcharge program (,. M and I'll read this, but you can certainly look at it if 25 you want to. ALDERSON REPORTING COMPANY, INC.
.. -.m. J.Li-- = - - - MW.mu,_ M,.ahL ^ = >- # w ~,- ^ W N c G T Q ?Q {,_ x.$$f 'q.9W$!D;.. .g.$[f.f2*QdJf . a f.&f 7 _ v% .... n u. m .,m: .gwee.. _?. g ,..,,.._,..,m._._,,,,.,,... G.% a..: ?. 133 . :.. a :.---. - n.n n - m w, - --. p.- n. . ~.. ~. ? g3.:gc1.= ') ' c; - Q I "My original thought may be, perhaps, if 2 there be no confusion, that 2it would be one way to go. 3 To predict the settlement on the basis of lab tests. The 4 very initial thought because the material appeared to be = 5 h heterogeneous enough and the surcharge program became an j 6 opportunity to provide answers, be provided in lab tests. R R 7 That was not the favored way to go." (reading) X l 8 A I have trouble understanding that. d 9 Q Obviously, there is typing or some type of errors 10 in there, but my question to you is does that refresh your E ~ j 11 recollection at all about any consideration given to laboratory P g 12 testing or anything7 5 5 13 A It doesn't change anything I have said. ~ m l 14 Q You have no recollection? $l 15 h I. don't recall di5 cussing this with Dr. Afifi. m j 16 g .How many projects have you been involved in where w( 17 thei'e has been surcharging? Y ~ 18 A I have been on several. Do you want me to tell E 19 you? 20 A Well, first of all, tell me approximately how 1 21 many projects have you been involved. 22 A Right this moment I can think of five, but I'm 23 not saying that I haven't been on more than that. i. 24 Q Okay. That 's fine, sir. 25 Did any of those involve surcharging after the ALDERSON REPORTING COMPANY. INC.
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?: T. C h '~.7:Ykhnl... _' d'.%.5? .nc5 -..,s. ,c,- 134 I structure had been partially or completely built? 2 A Yes, two of them. i 3 Q Okay. Would you tell us about those two? 4 A Okay. One is a very conventional problem, quite. ~ 5 commonly used in engineering.in that it was oil tanks for h -{ 6 a fossil fuel power plant in Louisiana, the tanks were y 7 built and then. water load was applied in station to take 3 l 8 out the settlement in the foundation. So in that way, dd 9 the settlement of the tank was taken out prior to it carrying 10 its oil load and also the bearing capacity was enhanced z_ h. II. by'.the consolidation that took place. n 'I' II. Q Could I ask you a little bit about that one? x3 13 .A Yes,. sir. 14 Q Would that be the normal practice for foundation 15 g. for, oil tanks? II gi A I can't say that it is normal, it is one of the ai li 17 things that is done with oil tanks because frequently oil u 18 tanks run poor -- are frequently put on poor foundation. E 19 g Q You did it because it was some problem with the 20 3o119 II A The soil was soft. I i. 22 Q Would it be good engineering practice to just t 23 go ahead and fill those tanks'with oil? M A No, we could not have done that, we would have s 25 had a problem with the foundation. AbERSON REPORTING COMPANY. INC. i ~~
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f,.,a,. . q:... ~ a.. A -.;=. c a.,. " ~ ' " 1 Q Okay. What would be the most significant problem 2 you would have? 3 A -Bearing capacity failure in that particular instance, 4 there was a potential for bearing capacity failure. 55 Q Now, in that instance, did you make a settlement ] 6 prediction before applying the water load? 7 A. I believe in that particular instance there was a- ] 8 settlement as to it, but the primary control in that particular d d 9 instance was in the pie::ometers, because we did not want z, h 10 to overload the foundation. We put in a partial water z) 11 load and then watched the pie::ometer dissipate and at a it ( 12 specific point then added some more water until we reached b 5 13 the max 1=um-load in the tank. m l 14 Q Was the amount of settlement in that case critical? 2 15 A I No, it was not critical. j 16 Q e Now, I may have just asked you this, and you ti 17 may have just addreassed it, but why did you make a settlement E hi 18 prediction before imposing the water -- E I9 g A Well, I didn't make it but somebody made it. 20 Q Why was it done? 21 A It was not necessary to be done, it was just 22 something somebody did. 23 Q It was done but in yourjjudgment it was not necessary 24 to be done. So, then that case does not distinguish itself I 25 as far as you are concerned for the Midland case, in your 'l ALDERSON REPORTING COMPANY. INC.
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8-x 136 m,. 'i. s .... 4 :. 1 opinion in neither case was it.necessary? 2 A Well, you asked me where I used surcharging and I'm 3 responding to that request. 4 Q That is correct, but what I'm saying is you don't = 5 5 think it was necessary to make a settlement prediction ] 6 in that case just like you don't consider it necessary R 7 to make a settlement prediction in the Midland case. 3I 8 A I did not say that. In Midland, we did measure i dn 9 settl.e. ment and we did use -- g h 10 Q I'm talking about settlement predictions. _a 11 'A I didn't try to draw a parallel between the two. m I,12 ,Q But it is true that in neither case did you see 5 ( II-5 the need for making' a settlement prediction? ' m I' 14 A That is correct. t: l 15 Q And in the case of oil tanks you didn't need ai 16 to make a settlement predict' ion because you imposed the wl 17 load -in stages-and you watched your piezometers and you a b I8 were able to control the situation tha.t way. E i 19 A That's correct. 20 Q Would you tell us about the other instance in 2I which -- 4 (, 22 A Instance or instances? 23 Q Well, I think you said there were two instances 24 in which there was surcharging after the structure was 25 partially or fully completed; is that correcc, and one of ALDERSON REPORTING COMPANY, INC.
5~~ ?kTZ"f.[E:^,"~~ rn. l C-. ~ h.W~'- M- .5 . -~ g . ~.a-te'.:.ivg' t ' ;;Na-b. b. Ykh[#-b L_%, 3. : c ~ r- -Q"-f,i".g.2 7.3 - =.- p,[i 13 7 ., ::.., a...: ff_ n.. n-r---- -~. p... 7, ~ ~;3 4 ,,. :. r s,...~ '/. e I time.was the -- 2 A I do not recall saying that, but I do know another 3 in which I can discuss with you. That is in Utah. I mentioned 4 it briefly this morning. It is a mining project in-an = 5 Anarconda. Copper.. Company at a place called carrfork. 5 8 6 In tihat particular instance, the plant site 7 was in very narrow valley that was filled with material l 8 that had been washed down into the valley during flood dd 9 stages from the hargrain. zi, o 10 We intended to do a conventional expiration i.F 5 II 3 at that. site and found because of the type of material f 12 there ~that wo: could not get meaningful data to evaluate 9 5 13 settlement for structure foundations. m l 14 We had in any case at that site intended $l 15 to obtain sneer
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3[ I0 wers some crushers in the site, vibratory loads in the as h I7 plant. We took the sheer way velocity measurements = @ ~ 18 and then reduced the sheer moduluous valuec by a factor E I9 g to come up WMh a moduluous on which we could evaluate 20 settlement of foundation. 21 What we did not know at the time we did 22 that, the location we selected for sheer way velocity happened 23 to be the best part of the site and one structure we were 24 aware that there would be quite significant settlement 25 l in the structures. And we had recommended at one of the major ALDERSON REPORTING COMPANY. INC. ) l
'w : . v, . ~.3 Q - .A' ?[:.; 7'y- -; Q% - 5b.** : *-T K' l3 _~~ 1 -. f i v- .a 138 l I structures on the site that they place the fill, the required 2 fill area fill. And then put in the foundation of,the 3 structure. 4 po'r some reason thiitt recommendation was 5 not b followed and the structure foundations replaced and l 6 then the fill was added and, of course, the structure started R 6, 7 to settle quite,a lot more than what we had predicted. Xl 8 We had not in any case predicted the correct dd 9 value of settlement on the basis of the data because the 10 soils, the location of that structure were not as good ={ 11 as the location where we had measured the sheer way velocity. g 12 I was. called to the site and recommended that we fill the 5 5 13 buildingwit$1 sand and to some extent beyond this. a l I4 And I also contacted Dr. Hendron and asked b 15 him if he would come to look at the site. He came to look g 16 at the s'ite and he increased the amount of preload that as g 17 I put on'the structure. 18 He, in addition -- we looked at each of E I9 g the structures on the site and because we did not really 20 know the quality of the material below them, we preloaded 21 all of the significant structures like the tailing thickeners 22 and other buildings on the site. And he in conjunction 23 with us recommended a staged loading in the storage area. 24 In that particular case, we used only settlement 25 measurements to evaluate when the preloading had been on long ALDERSON REPORTING COMPANY. INC. L
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. tf,. * ! k;- l V$> b.- 139 ~~;r m..;.. "Z."....... aw --.nn-3 L,: ~.. - Ap. .. s m. m ~ (;".-l. ?- ~~, f':: -Q ~r 1 enough because -- 2 Q You mean as opposed to piezometers? 3 A We could not put piezometers on there, they would not 4 have been meaningful, the water table was quite considerably 5 -below the foundation level, and drilling holes in that 5l 6 ground was just extremely difficult. The piezometers would R 2, 7 not have been meaningful 'in the material either. It was M l 8 quite relatively pervied. d' 9 So the entire valuation of the length of 2 h 10 time that preload was kept on was based on the settlement s_ j 11 measurement. .It 's my recollection that after about -- 3 ( 12 the tedt books tell you that sand settles immediately, -S. g 13 of course,'it doesn't -- granular material settles easily, a l 14 they don't. 'They take some time to settle. And we find a g 15 that usually the major part 'of the settlement had occurred a y 16 within one month and we kept the load down for sometime ai 6 17 after that'until we were satisfied that we were in a secondary 5 5 18 consolidation condition. E 19 The preload was removed and strangely enough 20 the building looks better than it did at the start. The 21 cracks had closed, and as far as I know the plant is operating 22 quite safisfactory. 23 The maximum settlement at the concentrated 24 building was 16 inches. 25 I Q At what, building? ALDERSON REPORTING COMPANY, INC. 1
"~~ m.. "WD5 . __:. ~ W.O"' py.x.iu 3:-?~x'3" .v. m d ~ W 140 -cw e s ' 1 A At the concentrator building. The main building 2 that I am talking about, the concentrator. 3 Q Does that complete. your answer? 4 '. A. 'That'is in summary. 5 Q 5 The 16 inches of settlement at the concentrator = l 6 building, does that include the settlement that took place R 2 '7 prior to the sur. charge? M l 8 A It includes all of the settlement that took place d 9 including the settlement under the preload fill. 10 Q Roughly how long ago were you involved at this z 11 project? m I. U A I would say it is about three years ago, it is t g 5 13 quit ~e recent. m l 14 Q All right. g g 15 A Yes., about three years. GE a[ 16 Q And can you tell us, do you remember of the 16 asl 17 inches how much took place before.the preload and how much .b 18 after? e 19 A Oh, maybe a third of it took place before, I 20 don't remember. That is the maximum settlement, not all 21 points in the building settled that much. 22 Q Okay. Was there a differential.; settlement. in this 23 instance or was it all settling - I guess you just mentioned i M there was a differential settling. 25 A There was differential settling. It was a different .I I ALDERSON REPORTING COMPANY. INC. j i
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n- . ~,:. 142 I what you mean -- ^ 2 A What I told you was that they had put in the building 3 and then they put in the area fill which was required. 4 When I*went to the site I asked them to add preload fill 5 in the building and adjacent t.o it and Dr. Hendron increased E 6 the amcunt of that preload for me, as to my' recollection. 7 Are you worried about the word preload? NI 8 Q No. Here is my concern, was the preload placed dd 9 uniformly over the building? 10 A We try to put it uniformly to minimize differential k II settlement.' g 12 Q., Okay, now that 's the key, what did you do to 5 g 13 minimi:e differential settlemen,7 l14 A, We tried to put in the fill in relatively uniform 15 layers, you don't put all of it in at one end and nothing ' y 16 at the other. e I7 Q Well, let me ask you I:his', do you have one end 18 of the building settling more ' han the other if your t E II g preloading program puts more weight on the part of the building that is settling less, wouldn't that tend to reduce 21 differential settlement ? 22 A Would you say that again, please ? 23 Q Yes, if you put more preload weight on the' portion l 24 of the building that so far has settled less, wouldn't 25 that tend to reduce your differential settlement? s 4 ALDERSON REPORTING COMPANY. INC. j
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_,p, ,. ~ {,, %. ,,i ma..gr -.A 'but I' din't recTll that a 2 we were that sophisticated in that particular instance. i 3 Q That 's my question then, if you didn't make any 4 efforts, did you make any effort in your preload to reduce 5 differential settlement? j 6 A We do to the extent of putting in the fill in k7 a uniform manner. 8 Q You indicated that the actual total settlemsnt ed 9 was approximately 16 inches -- 10 .A To. my recollection - it is my recollection that 5 II the maxiirm' settlement in that specific building was about n ( 12 16 inches.. g g.I3 4 ,'And do you recall what,your prediction settlement 14 was? II A' 'I would say it was probably around three inches, ai l' something like that. e h II Q Is there a report th1Lt you are aware of that I8 describes the surcharging prcgram that was conducted at I' I g Cartfork? A Do you mean a summary report that we prepared 21 later? 22 'r q y,,, 23 A ,I don't recall that we did that. There are memoranda 24 concerning the thing. I believe those would all be the 25 property of Anaconda Ccpper Ccmpany. S' ALDERSON REPORTING COMPANY, INC. t
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Q Would they 'be in the San Fransisco Office? w. 10 .A They'would be in the San Fransisco Office in .= "e I I. the ' Mining' and Metal Division. 3 f II Q ','Do you know whether that summey report would 5 ?' 5 13 show loadin's and, settlement history? a = A . I. do not believe I said there was a su'mmary report. E I4 b 15 Q Are you aware of any report ? g 16 A I do not recall that we did a final report on as 17 g that, on the preloading. What I. did say was there might a lii 18 be memos concerning it. E II g Q And.would those memos be in your division files 20 in San Fransisco? II A I believe they would be in mining and metals. 22 division files. s, 23 MR. PATON: Al, we are requesting that if such reports -- M let's go off the record. 25 (At which time a discussion was I eld off the record. ) h ALDERSON REPORTING COMPANY, INC. m
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p r '" 1 MRi>PATON: Mr. Farnell,iI'm requesting that you make '2 an effort or you ask Bechtel to provide information concerning i 3 the experience just described by Mr. Ferris at Carrfork, '4 i including if possible loading and settlement history, cracking 5 g history,.of the surcharge program that he has just described. a { 6 MR. FARNELL: Cracking history? y 7 MR. PATON:. Didn't he mention cracks? 3 l 8 WITNESS: ,I did mention cracks. I don't know what d z;. m 9 information is available. h 10 Mil. PATON: Those.areuthe.subfects,:if 'any of that s k lI is available. 3 ( 12 MR. FARNELL; We. will make an attenpt to locate such = 3 5 13 document's. No'te for ti:e record it is Christmas time and a l 14 your ' stockings seem to be getting stuffed with many documen' t ,c_ j 15' requests but we will play Santa Clause and do our best si 10 for you. ai ( 17 MR. PATON: I appreciate.that, Christmas or any time. 18 BY MR. PATON: n I9 g Q Can you tell me the thickness of the compressible 20 layer at Carrfork? 21 A I can't answer that question. I can tell you 22 that there was about 100 to 120 feet of soil above rock, .j 23 but I don't know the relative compressibility. l.. 24 Q Do you recall the height of.the surcharge load? 25 A I don't precisely recall that. I really don'.t f ALDERSON REPORTING COMPANY, INC.
~ ~- ~ I-In22 i E'm C h }Nd- ~ ^ ? ' ~- s., 7 g, g...e.. A ~ 2 146 n .r. ? 1 recall the height. 2 Q Did you follow any general rule, such as the surcharge 3 being 50 percent more than the final load? 4 A 'ie -- my recollection is that we had it 50 percent g 5 over the dead plus. normal alive load. That is what my ?{ 6 recollection is and that is merely a recollection. R 7 Q Do you have any recollection in that regard with N 8 8 respect to Midland as to what degree the surcharge exceeded d d 9 the final expected load? 2, C 3 10 A Well, I believe at the last public meeting there 5_ j 11 was some information handed out showing what the preload a j(. 12 strss's was related to the building stress and I don't remember 5 5 13 the exact n'umbersg but that piece of information was given a l 14 .to NRC., E e 15 Q Okay, fine. = j 16 Q Mr. Ferris, let me review, at Carrfork I think ai ' fI7 you, indicated you did not take piecometer readings. i: E 18 A No, there would have been no point in taking h ~ 19 g them. r3 20 Q That is correct, you did not ? 21 A Yes. 22 i_ Q Did you address piezometer readings with respect 23 to the first example you gave? I 24 A Yes, I did. That was the primary basis that 25 we used for controlling the load. ALDERSON REPORTING COMPANY, INC.
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{ 18 will you tell me whether that chart shows that the piezometer c s. 19 g elevation shows.a drop or an increase? l 3 20 MR. FARNELL: I think the document will speak for l 21 itself. 22 WITNESS: It appears that -- I presume I don't see 23 the scale on this drawing here, but I presume that upwards 24 means increasing pore pressure, i 25 Q We have a better picture of this which shows ALDERSON REPORTING CONtPANY. INC. ee' e edee b
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.n I hf. ,3; MEN- ~.:- Oh r$'...G;;$?.D - :- --- (QT '149- ,..u..~.~.. n. ~^ .,. -,... ~. < .~ - ~ ' ~ ~ '~ "Q ^7 - ~ - ;-. m;q "- " l'I E full load was imposed? t 2 A Yes. 3 Q And what other information would you need to tell me 4 whether that' slight increase in piezometer elevat. ion in 5 g that three month' period is what you expected to have. j 6 A The two things that come first to mind are I R E 7 would like to s.ee a plot of lake level during this per.iod n ] 8 o f t ime. And I would like to see information on the variation d m; 9 'of the' area ground water table in the vicinity of this, z og 10 outside of the limits.. 2 II Q All righti,,are you indicating that that ground a g 12 water level could have influenced the piezometer reading? g.. 5. 13 A. Of course, it will increase the pie::ometer reading. n I4 I. don't k ow if that is the cause of the rise because it i fj 15 couldsbe that the lake was rising in that period. It could g 16 be that the area ground water is rising. as 6 17 q .But didn't you indicate to me before that your 5 { 18 knowledge'of the piezometer elevation was part of what E 19 S led you to conclude that you are now in secondary consolidation? n 20 A Yes, that is correct. 21 Q Well, then if you are sure you are".in se~condary 22 consolidation, then you must know what is going on with 23 the ground water. 24 A What I'm saying is you need to change this to P 25 take out these other affects, effect of the lake and the ground ~ ALDERSON REPORTING COMPANY,INC.
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-- :. ~. a. .,a.. I water and then look at that to see if there has been any. 2 Q Did you do that? '3 A I personally did not. 4 Q Did Bechtel do it? = 5 A I believe something like that has been done. I+ 3 6 Q All right. Who did that? R 7 A It would have been done under Sherif Afifi's ] 8 supervision. dy 9 Q Do you have knowledge, does he know that ground 5 [3 10 water t' ble level during that period of time ? a ? k II A
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Q 'All right, let me ask you this, if the piezameter .g 10 2 5 11 number 40,was not influenced in any way by the ground water a Y 12 table, what.~would.you have expected that curve to do in 5 j 13 May[JuneandJuly? =. m 5 14 'MR. FARNELL: I think he also said it might be influenced D I.5 by the lake. = l .j 16 . MR. PATON: Well, I assume the lake is affecting the a [ I7 ' ground water, right, assuming it isn'ti affected by the I~ =g. l'8 lake or the ground water table, what would you expect that E 19 g curve to do in May, June and July? 20 WITNESS: If it is not affected by the lake or the 21 ground water, I would have expected it to be fairly level. 22 BY MR. PATON: 23 Q Well, as the surcharge squeezed out the excess 24 pore pressures, wouldn't that line have declined? 25 A Yes, if it was still dur'ig that -- I did not ALDERSON REPORTING COMPANY, INC. ~
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, a... 7,s g % :~. n ~ K.- -'-: .m. v e' .., a., s I understand that question. .2 Q You are saying that it may have already squeezed out 3 all.of the excess pore pressures, that is a possibility. 4 We are talking about a supposition, not about a real thing. = 5 You are saying that you can't 'really make accurate -- h j 6 A I cannot look at that one ' curve without other -n R., 7 da'ta and tell you exactly what has happened. X ] 8 Q And you did not do this? d d 9 A I did not make that evaluation. i h ' 10 .Q .But to your knowledge, you think Dr. Afifi did? z II A J,I believe.it would have been done in the soils B I 12 Eroup in Ann Arbor. ' g 13 Q= Did you.ever hear Dr. Afifi say whether the piezometer Jt 5 I4 behavioi was - what he had eitpected? _b 15 g A.' 'The only com:nents on pierometers that I can recall m - ~ 10 is.t'at people felt that the pore pressure dissipated quite h f I7 quickly and', of course, we had no idea whether that was e { 18 going to be the case beforehand or not. Do you know whether E 19 Dr. Afifi is also satisfied that you are now in secondary 20 consolidation? 21 A I believe he is. i l 22 Q Is there anyone in Bechtel who has expressed 1 l 23 to your knowledge any doubt about whether you are in secondary ~ 24 1 consolidation? 25 A I don't recall hearing anybody express that doubt. ALDERSON REPORTING COMPANY, INC. ~ a h.
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13 A Tes, I have. m l 14 Q What did you ever hear him say about it? { 15 A I believe he is of-the opinion taat we have reached = f 16 secondary consolidation. as 6 17 Q Based on what I mean? M= { 18 A Based on the data that he has been given. E 19 ~ Q Those are his conclusions? 20 A ges. 21 Q Ha.ve you ever heard anything about his reasons 22 or basis for his reasons? 23 A I'm sure I must have, but I can't recall specific 24 statement s. 25 Q Did you ever hear him saty that the cie::ometer ALDERSON REPORTING COMPANY, INC.
.g.yg,c 9.. !iN ^- s..~- N kESCL T h: OY.,-yd ; 'e-,.;. ': E 2 f ' i w ,= ..%w ; * - ~ 155 c-s, w....,.. 1 behaved exactly as expected? 2 A I think he was a little surprised that the piezometer 3 pressure didn't go a little higher than it did, but I don 't 4 know of anything. else that was surpising and I guess he = 5 h did not know how quickly the water pressure would dissipate [ 6 either before we actually put the load on. R d,7 Q Let me ask'you about there is a line on piezometer Zl 8 number 40 plot th'at says "begin surcharge removal." dd 9 A Yes. 8 10 , Q. And immediately after that line there is a fairly II~ sharp drop in. piezometer elevation. 3 { ' 12 A; Ye s. - 3 5 13 1 Q-What causes that to drop.at that point ? a 14 ' Well, one possibility would be just. 6emoval'of A h: j 15 the surchhrge. a 5 16 as q. That relieves the-pore water pressure; is that Ii I7 correct? u is5 18 A Yes, in this particular instance it appears to E I9 g have gone down and come back up again. E Q - Okay, now coming back up again, is that called 21 rebound? l 22 A Well, it could be rebound. 23 Q What.do you call it? M A I don't know that that 's what it is called. 2-25 Q . I don't understand what causes that. I.can understand l L i ALDERSON REPORTING COMPANY, INC. ~ e r.--- y mgr" P
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.o. R. . A. ~. (;p.~.. ~n =-, l why you take the surcharge off, there is a relief pore water ..~n.~. ~w 2 pressure is relieved. 3 A And' drops. 4 'q And drops the elevation drops. But do you understand 5 g why it goes back up again or rebounds? 9 3 6 A Well, I think 'it is going back to the controlling R E 7 water level there. It may have gone below that when the K 8 8 load was taken out. dd 9 Q W1iat force would cause it to drop way below that .z C [3 10 natural stage and bounce back up again? 3 h 11 k .Well, if you had a negative pore pressure tha: 3 ( 12 would cause it. ~ ~ 5 g 13 Q ',: Tell me wriat you mean by " negative pore pressures." = l 14 .[',ye11, pore. pres.suresthatarelessthanthebase 5j 15 that,you are. measuring the pore pressures from. m -E I6 .Q To me the answer is you have a negative pore w h 17 pre ssure - E 3 18 A Let me give you an example, and if you take a G g" 19 dense sand and squeeze it, you will see that what was -- 20 maybe if it is saturated, what was wet on the outside becomes 21 dry because when you sheer the sand it increases in volume 22 and the pore water is sucked back into the pores. You 23 get negative pore pressure. 24 Q All righ. Now, the curve shown on this piezometer 25 l number 140 plot after the removal of the surcharge shows lower i l l 1 ALDERSON REPORTING COMPANY,INC.
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pie:ameter elevations, do you agree with that ? Lower than 1 2 'it showed in May,. June and -- 3 MR. FARNELL: What point -- 4 WITNESS: The thing I would like to know is where 5 h was the lake ' level during this period was there any pumping } 6 going on in this period. What other factors could have R g, 7 affected the ground beyond. I cannot just:by looking at sl 8 one curve tell you the answer to your que stion. d d 9 BY MR. PATON: $g 10 Q.' Absence to the knowledge of 't'he ground or the E iii 11 water table level, you cannot draw any conclusions from ci { 12 the fact that.the curve after surcharge removal is distinctly = 13 at a lower elevation than prior to the removal of the circulation E j 14 You Ean't. ' draw any conclusions? E 15 i A Well, I would assume that part cf that is becat'se 5 y 16 of the reduction of the water base water. level for some.: w g 17 reason, but; I don't know what. lii 18 Q By base water, do you mean the ground water table? E 19 A R Yes, say the ground water level lowered beyond 20 what happened. That 's what I said with that one piece 21 of information I could not -- i 22 Q In other projects, on which you have experienced 23 with preloading, did the piezometer elevation decline after } 24 reaching full surcharge height? 25 MR. FARNELL: I don't understand. Would the court reporter i ~ l ALDERSON REPORTING COMPANY, INC. . ~. -. -
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m E I4 level,' level'1n,the. piezometer, declined and at some point b_ g 15 we added another increment and the piezometer went up again. c: si 10' e ' Q And that is'merely normal expected behavior; N I7 is that right? azy.18 A Yes. c 19 Q And it declined because you were squeezing out 20 the excess pore pressure? 21 A Right. 22 Q I assume that by looking at this chart, this 23, plot of piezometer 40 you cannot tell absent some other i 24 information where you reached secondary consolidation? l 25 A No, I would like to see other information before -l ALDERSON REPORTING COMPANY. INC. l
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l 159 . s. w.. ., 3.; 1 I would make that decision. What I'm really trying to say, 2 just giving me that chart doesn't tell me all the information 3 I need to have. And I have not made an evaluation of it. 4 Q Eave you seen the other information, do you recall g 5 having seen the other information that you said you might Rj 6 , need? Such as the pond level. R d 7 A I probably.have seen it. I do not recall it X] 8' in relation to that curve. In fact, I don't recall that d 9 specific curve, although, I must have seen it because I 10 presume it was at the public hearing. E 11 -Q n Approximately how long -- and is it your testimony that y[u, yourself, did not make a computation to remove ( 12 13 frds this tppe'of information any impact of the pond or a the grou5d wat'er leve'1? l 14 y 2 15 .A .I did not. w a f 16 .q You didn't do that yourself? ~ e 17 'A I didn't. a 18 Q Did you ever review that work that was done by E 19 anybody else? 20 A I'm sure I must have reviewed some of that in 21 the responses that have been made to NRC. 22 Q Roughly how long ago would that have been? + l 23 A Quite some time ago. 24 .s_. Q Do you know what kind of piezometers were used i 25 at the midland site at the diesel generater building? l ALDERSON REPORTING COMPANY. INC. ~
....- --,,: 4',~-, _ dM$iik~ " [:kk'Nf"YWW#.. - G-s 3 -:.--~-_ ,-5hk[.kE[N.NE ~ 3 -r $ 7, ~ - ' - - ' [ 2 M*'. -$.'@R Y~.:,..m -m 160 .p,y; ,, m mm m.~,.. O D. .u.:. .c-.-- n n.~ - - ~ ~.. e n, > - M . ~. ., ~. . y p,',)i.gy= -.mm.1--- A-The piezometers th5t'y1 saw atthe~M15 hand Plant 2 site we're essagrande type piezometers. '3 Q Is that an open-tube type of piezometer? 4 A As it was.used at Midland it is. 5 Q Were all of the piezometers used in connectiorf h j 6 with the diesel generator building to your knowledge of 2 7 that type ? A g 8 A I believe they were. dd 9 Q Were there piezometers in use in other places ,z h 10. ~ on the site that were other than open-tube type? =_ I Il A I don't recall. is I 12 Q, Do the piezameters at the diesel generator building, = l 13 which I think icu said were open-tube type, have a problem". m l 14 with time lc.g?' g 15 A m. - INll, there is a time lag affect for any type g" 16 Casagrande type of piezameter was developed .of piezometer. ai ti 17 to reduce the time lag from what I would call a stand pipe a M 5 18 piezameter, a stand pipe observeration. - And so there would 19 be a small time lag. 20 t Q You mean the open-type has less of a time lag 2I than another? 22 A The time lag relates to the time that it is required i 23 for the water to flow into the piezameter to reach equalibrium l M level. If you can do that with a very small volume of g 25 water, then the time lag will be small and there are piezometers \\ l ALDERSON REPORTING COMPANY, INC. --4+ t - 4 g T-
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m j 12 Q I' thought it did. j 13 A You. showed me one for Pc-30, that had pond elevation. a 5 14 g Q This graph for P,C -- my point is the ~ pon@ is 4 l 15 the pond. Would you expect.-- a d I0 A 'I wou-ldn't disagree with that as 6 17 Q And would you disagree that during May, June 5w 3 18 and July, the level of the pond -- E 19 A The problem I have with this graph was knowing 20 where May, June and July is on it. I can see April and 2I I can See August. The pond elevation during that period 22 rose slightly and then fell according to this. The scale 23 on this drawing is quite different than the scale on the 24 one you just showed me there. 25 Q Is the change in elevation of the po.nd \\ ALDERSON REPORTING COMPANY, INC. - ~ .n a
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J 'n L:2 *..*are emw-- ~ I sufficient to have affected tihe piezometer elevation? 2 A It could have, I don't know without looking at data 3 to be able to tell you, but the change in the pond elevation" 4 would' have caused some change in the ground water level 5 5 and the plant fill and the affect of that on the' piecometer = +g 6 is what I would be interested in finding. .g C 7 Q Even if the pond water level remained absolutely ] 8 constant, it could be that it was causing the ground water d d 9 table to -- the ' ground water table was changing as a result 2 h 10 of'the'.l influence of the pond; is that possible? Z II 'A Weli, that would.be one factor that I would want l 3 l I2 to looli lit.- I do not know because I don 7C have the data s 5 13 here, I do' not knos whether in fact that was, happening, ~ I4 but that would be'one.' thing I would like to look at. -b 15 Q M". Ferris, directing your attention to pie:c=eter ![ 16 number 40 plot, and specifically the piezometer elevation
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169 4 1 BY MR. PATON: 2 Q Directing your attention on F1 ure 1 of Kane Deposition 5 3 Exhibit No. 8, the pond elevation, would you a5ree that 4 it remained almost constant through the end of the year 5 1979? .=gj 6 MR. FARNELL: He said already he had problems with R 7 it __ N] 8 MR. PATON: From the middle of '79 to the end of the d 6 9
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He said already he had problems with the iE. Il scale on that thing. m y 12 BY MR. 'P' T'O'N: A 4 g 13 Q ,He may have problems. If h"e can't answer the 2 l i4 question beca'use' 'of problems, that 's fine. 5 g 15 MR.' : FARNELL: What do you mean by "almost" counsel? a
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n [ 52-h* '=== 1 - 7.umte m plo[ to be lower t'h[ah'the 1eSoNeYe N ievation 2 prior to the beginning of the surcharge. 3 A I think I would have to go back to what I said 4 before. The' pond level is one of the pieces of information h .5 but the ground water level in the vicinity of the diesel' { 6 generator building is another and there could be things a 7 that were going on that I am not aware of that need to 3 l 8 be factored into that before you can analyze it. dd 9 Q 2 Can you tell me anything that would cause a sharp 10 change ~1n the ground water table? Z 5 II A Yes, a sharp rise in the pond might locally cause is y 12 I c a -- ~ = 13 q' Or. a sharp decline? a. l 14 A, Or'a. sharp decline. $l 15 g- "Do you know of any others. m j 16 .A Well, I'm sure I could think of some, I just g .$i 17 don '.t know offhand. 4 f18 Q What we are suggesting is there was no change E 19 g in the pond and what other possible causes could there 20 be? 21 A Well, if.I was going to analyze that, one of 22 the things I would look at first, is the whole pattern 23 of the ground water in the plant fill, and that is controlled ' I 24 by the pond, but the pond level the level at some point 25 within the fill doesn't have to be the same. j .l ALDERSON REPORTING COMPANY, INC. +
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9. AUTHENTl* CATION 2 This is to certify that the attached proceedings before 3 the Nuclear Regulatory Commission in the matter of: 4 DOCKET' NUMBER: 50-329-oM, 50-330-oM, 50-329-OL, 50-330-on =, 5 a PLACE OF PROCEEDING: Offices of Isham, Lincoln and Beale d 6 One First National Plaza, Floor 42 .g Chicago, Illinois E I g DATE OF PROCEEDING: December 10, 1980 8 8 a e were held as herein appears, and that this is the original ci 9 2 transcript thereof for the file of the Nuclear Regulatory h 10 i Coitmis sion. 33 11 <n d 12 z g mt uk) ( 5 13 TERRI HEyY a G E 14 w 2 15. w= j 16 as 17 w E ca 18 19 R 20 21 l 22 i 23 I I 24 \\ 25 ALDERSON REPORTING COMPANY, INC. ~ I
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Chicago, Illinois g 2 7 { ~ g DATE OF PROCEEDING: December 10, 1980 8 8 N e were held as herein appears, and that this is the original d 9 ,} y transcript thereof for the file of the Nuclear Regulatory g 10 E Commission. j g 11 N M %A g 13 TERRI EERATY t a J f 14 g o 2 2 15 j E j 16 d ti 17 w L w {N z N 18 I:" 19 N:- l 20 21 22 23 24 25 ALDERSON REPORTING COMPANY. INC. .}}