ML20090A846

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Transcript of TR Thiruvengadam 801211 Deposition in Chicago,Il.Pp 1-61
ML20090A846
Person / Time
Site: Midland
Issue date: 12/11/1980
From: Thiruvengadam
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML17198A223 List: ... further results
References
CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101090377
Download: ML20090A846 (62)
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Text

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= 5 In the matter oft Docket Numbers: ) 6 CONSUMERS POWER COMPANY 50-329 OM & OL and K 50-330 OM & OL 2,, 7 Midland Plant, Units 1 and 2 : 1 - - - - - - - - -x: nl 8 d d 9 Chicago, Illinois 10 Thursday, December 11, 1980 = 11 Deposition of THIRU R. THI,RUVENG AD AM, a witness is j{,12 herein, called for examination by Coun'sel for the NRC in I 13 the above-entitled action, pursuant to notice, the witness l 14 being duly sworn by PATSY ANN STROH, a Notary'Public in E g 15 and for the state of Illinois, at the offices of Isham, u a[ 16 Lincoln, and Beale, First National Plaza, 42nd Floor, et l 17 Chicago, Illinois 60603, commencing at 1:15 p.m., 2 h I8 Thursday, December 11, 1980, and the proceedings being E 19 taken down in stenotype by PATSY ANN STROM and trans-20 cribed under her direction. 21 i, 22 23 I 24 s. 25 ! s I l I ALDERSON REPORTING COMPANY. INC.

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' c. ..,..m,.. .s m -. .u. - m *E . J :y~! ?cm.m.,g.. S ... r, -s .C_.O _N., _T'_E. N'.T _S. 2 Examination by Counsel 3 Deposition of For NRC For Applicant 4 Thiru R. Thiruvengadam 3 5 = 5 b 0 EXHIBITS Mo I For Identification 4. ey M j 8 9 1. Resume of Mr. Thiruvengadam. 3 9 z c 2. Sketch of cracks in diesel generator 22 g 10 z 5 generator building drawn by g 11 m Mr. Thiruvengadamu dated c 12 z_ 12/11/80. I g 13 m ] 14 2 15 = a g 16 e i.f. 17 .== 18 E 19 R 20 21 22 23 I 24 \\. 25l ~ ALDERSON REPORTING COMPANY. INC.

~ ' ' " ' 1~ .s p -,3, -g,. p. a ~.3: ~: . z,.. ~. % d~ f s:0.Q~;(: * '1*: '-7 -;-hk.,' . ; *- ~.'Q.-u2 '7"-' 3 .,...a i 1 .P _R.O.C.E.E _D _I _N _G _S 2 Whereupon, 3 THIRU RADHA THIRUVENGADAM 4 a witness herein, called for examination by Counsel for g 5 Nuclear Regulatory Commission, having been first duly R ] 6 sworn by the Nota'ry Public, was examined and testified as R 7 rollows: ] 8 EXAMINATION BY COUNSEL FOR NRC dd 9 BY MR. PATON: i h 10 Q Would you state your rull name for the record, j 11 please? 3 d 12 A Thiru Radha Thiruvensadam. Ea s. 13 Q And would you state by whom are 'you employedt 5 l 14 A Consumers Power Company.- This res-ume is about 2 15 three years oli. U j 16 Q All rir,ht. As a matter of fact let me mark this e 6 17 as Thiru deposition ExP..t. bit 1 and today's dat.e, December U Ci 18. 11, 1980. E 19 (The document referred to, R 20 resume of Mr. Thiru, was l 21 marked as deposition Exhibi t 22 No. 1, for identification) 23 BY MR. PATON: (Re sumin g) 24 Q The resume that you just. handed me is three 25 ) pages.long, and you have just indicated that-it is ALDERSON REPORTING COMPANY,INC.

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.=.am:hw;"-' %-%LQ%.gpr yino.v'-a .g y ;.y g; :-: y5y7 mig:G.;..,,-7.G.. h g (, . ~..... - 4 ,,,r...-._, ~,. ..:.. _3 ,3,.. ... e- -. ). < g.p .hMy t ree ye'ars ou( M* date. Alrignt, I just wan t 2 to so over with you, very brierly, your education. 3 A All.right. q yng} have a degree of civil engineering from 4 the g 5 University of Madras in 1961, is that correct? D+ 6 { A That's right, sir.' "2 Q It says passed in first class with honors? n 8 8 A Yes. a d ci 9 g Q Does that mean you were first in the. class? o 10 z A No, there is a classification of first class, 13 11 y second class, and third class and honors. ,I got a very d 12-i high grade to be classed in first class and got and even 1 13 5 higher grade to be placed in honors. E 14 Q Okay, thank you. That was civil engineering? 2_ 15 l g A That's right. J 16! G Q Did that involve any s truc tural classes? d 17 5 A Yes. ~ $i 18 1 Q How many, do you recall? 19 A No, I don't recall. 20 Q .Ok ay, your next degree you have a M.E. degree in 21 power engineering, is that Masters? 22 A Masters of Engineering, yes. 23 Q In 1963? 24ll A That's right. 25 ! 4 i Q And you received a P.H.D. degree from the ALDERSON REPORTING COMPANY, INC. I

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.a g-,,.;,. 2.r.: ~~ -O- .x .c- . y.. .v- ~~ ' 3 1 University of Illinois in 1969, is that correct? 2 A That's right. I 3 Q And that is in civil engineerind,.but it says, 9 4 (structures), does that mean you. majored -- = 5 A Majored in s truc tures, right. h j 6 Q Are you presently working on the Midland facility? 5 7 A Yes, that's correct. ] 8. Q When did -- when were you first assigned to the d y 9 Midland facility? h 10 MR. FARNELL: During the time he was at Consumers = ~ II j Power? g 12 MR. PATON: Yes. 13 THE WITNESS: I was assigned off and on starting from the beginning of 1979,' to the bes t of my recollec tion. ~ 9 15 i E BY MR. PATON: (Resuming)- = 16 j-Q A11 'r44t, give me some idea in the year 1979, C 17 0 what percentage of your time you spent working on the Mid-h 18 = land facility? 19 l A. In the beginning of 1979, just a pure uess i i o 20 would be approximately 50%, toward the end of 1979, my 21 guess again, prouably 80%. I 22 i. Q All:right',*do'that, fob 1980. 23 I A 1980, 100% or the time. 24 Q Okay, are you familiar with a document that is 25 entitled -- that is dated December 6, 1979, entitled ocder ALDERSON REPORTING COMPANY. INC. i

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2 A I have heard of the document, yes. 3 Q Have you ever, to your knowledee, seen the j 4 document? i = 5 A I might have seen the document, yes. X 9 3 6 Q Do you know if you have ever seen the document? E 7 A I have not read the document. K l 8 Q Okay, and your work on the Midland facility d d 9 involved your expertise in structures? ,z h 10 A That.'s right. z I 11 Q Describe your present responsibilities with .g = l 12 respect to.the Midland facility. g I 5 13 A At the present time I'm the section head for l 14 civil engineering in the Design Production D'partment in' e g 15 the Midland Project Division. g 16 Q You said you're the section head. Did you say w 6 17 of the Design Production Department? a E 18 = A Yes. 19 ] Q Okay, that i..s your title or the name of your job 20 but I'm asking you to describe your present responsibilitieg. 21 i A My responsibilities are to expedite, design, 22 production and in general to be responsible for all civil s. 23 I engineering items concerning the Midland projec t. 24 Q Do you spend most of your time at Jackson, 25 Michigan? 1 1 ALDERSON REPORTING COMPANY, INC.

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. z..:.x r ~....- ,.a g :-.. 7! 1 A That's correct. 2 Q With respect to structura.1 matters, do you 3 communicate with' people at Bechtel? 4 A Yes, I do. 3 5 Q Who do you commicate with most? E j 6 A With all the individual structural engineers, the R 7 structural group supervisor, assistant project engineer and K j~ 8 whoever in that particular sec tion, dd 9 Q With respec t to structural work give me the names ,zo h 10 of the people that you communicate with at Bechtel, for = 11 example, who do you communicate with most? 3 y 12 A Bimal Dhar, Mo Elgaaly, E g-a- a y, and there 5 g 13 could be otherr. There's a whole group of people. 14 Q Okay, bu't as far as your -- you said in response 9j 15 to my question of who do you communicate with most, you = j 16 would say Bimal Dhar? w h II A Yes. = M 18 Q When did you become the section head of the E 19 ] Design Production Department? 20 A May of '80. 21 Q What was.-your job before May '80? 22 A I was a staff engineer assigned to P'oject 23 Eqsineering S ervices Division. i 24 ~ Q Staff engineer? Would_you'say that again? 25 --{ A Staff engineer assigned to the P roject Engineerin:; ALDERSON REPORTING COMPANY, INC. ~ i

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f/ C -"* "~~ Y 2 Q What were your responsibilities in that position? 3 A To provide te c hnic al..assis tan c e to.the proj ec ts 4 ander construction and under modification. g 5 Q Did this -- when you were the staff engineer a 6 assigned to Broject Engineering Services Division, did you R R 7 utilize your structural trainins? A 8 8 A Yes. n d d 9 Q In other words, was your job - isere you involved i a 10 in other diciplines? E! 11 A I was enrolled mainly as a civil engineer with a p 12 special emphasis on structural engineering. Ea 13 5,. Q All 'right sir, and when did you first become -- mg 14 when did you first -- whan were you first assigned to that t: g 15 jeb as staff engineer? a: j 16 A Since the time I joined Consumers Power', November i.i N I7 1978. EC 18 l Q Are ycu aware that the diesel generator building i,s U 3 walls have shown cracking? n 20 l A Yes. 21 Q In your opiriion what is the cause of this 22 cracking? 3 l A I haven't personally investigated all the data j 24 pertaining to that. I have to rely on the conclusions drawn from Bechtel engineers: .taat most of the cracking i i ALDERSON REPORTING COMPANY, INC. ~

~- - ~ ~ _ nJ.' ';~;-!..22;. C y: _-~_ Q ;Q ?g; ._,;-g'9~ '.e 3 y :x. a a 3; - -cz ..,..,c - z.-; ., c, I was due to shrinkage, and some of the cracking is due to l 2 the building being held up by duct banks. 3 Q I want to make sure I understand your answer. I 4 think you indicated that you 're relying in s tating your = 5 answer on Bechtel engineers. Can you tell me who within h j 6 Bechtel gave you that information? R d 7 A This was presented in many meetings and the 8 group superv1:.or in charge of civil structural area is d d 9 Bimal Dhar. z Q 10 Q I understand your statement about the building 5 11 being supported by duct banks but the other reason you a y 12 described. as shrinkage. E g 13 A S hrinkage, right. 5 I4 Q Do you know what caused the shrink ge? { 15 A There is a normal process in any concrete walls. = g 16 The concrete upon curing tends to shrink. e h I7 Q Okay, you're not indicating that the cracking is = 18 something that is normally to be expected or are you? = E I' g A Shrinkage cracks are normally to be expected. 20 Q Okay, what kind of cracks do you have at the l 21 diesel generator building, other than shrinkage cracks? A My recollection is the cracks are due to the 23 buildin; being held up by duct banks. l 24 l Q When is the last time you saw those cracks? 25 ! A I was touring the si,te along with the NRC I .I ALDERSCN REPORTING COMPANY, INC.

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g:p ..g_.___,,._,,_ ( s :.N c. . r.. ,.--~,.w.,~.,...m. .,u~._,,..m._... []h$r1.=~,L Aerso_nnel. I don't recall thDc.,exactytime_.Ka was. That was t 2

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3 Q Okay, was that in August of 1980? I don't mean 4 to pin you down to a date. I mean just approximately, what = 5 month was it? I ] 6 A I don't recall. R 'A 7 Q You don't recall what time it was? Was it in the ) 8 last half of 1980? d m; 9 A It would be a guess. z h 10 Q Okay, how many times have you visited the site ~ z 5 II in the year 1980? 3 f 12 A I don't recall that either. 3 '5 13 Q Do you recall whether it was more than five times? a l 14 A I would say more than twice. $j 15 Q Do you have any idea how many times you visited = 2[ 16 the site in the year 19797 w h I7 A I can't recall the number.- b 18 Q Can you say it was less than five? =k 19 [ A Probably. 20 Q Have you read any of the depositions that have 'l ~ been ' taken in this proceeding? 22 A Yes. 23 I Q Tell,me whose deposition you have read? 24 A Sherif Afifi's. 25 Q Is that all? ALDERSON REPORTING COMPANY. INC. g-

.,-.,g,. a. L 6..- f- ...,. : m .w' = GCQq~,f: 3.- _-.G=-R _,* _,y..g_ _.,. -+n* --:2.. ....x 1 A Yes. 2 Q. I want to ask you a question about your relation-i 3 ship with Bimal Dhar. Do y'u direct his activities? o 4 A' Not personally. I act.on behalf of my boss = 5 whouis Design Production Manager.and.,he directs all the 2e] 6 activities of Bechtel. R 7 Q Okay, what is your boss's name? 3 l 8 A Ronald Bauman', B-a- u - m-a- n. d =; 9 Q And.he direct Bechtel's activities? z h 10 A That's right. = 11 Q Does he monitor Bechtel's structural activities? m l 12 A The question is not clear. S ~ 5 13 Q Okay, does he observe, does he watch Bechtel's a m I4 j construction activities? Does he stay on top of'what .u C 15 h Bechtel is doing in bu11 din 5 structures? m g 16 MR. FARNELL: Stay on top, that's -- w h II MR. PATON: Well he asked'-for clarification. I a 5 18 think the first question was pretty clear.-- does he observe E 19 ,) Bechtel's structural.. activities? 20 MR. FARNELL: Do you mean the building, you mean 21 observe structural activities? 22 MR. PATON: If the witness can not answer that 23 . question I wil3. move on to another question. 24 THE WITNESS: I have difficulty -- 25 BY MR. PATON: (Resuming) s t ALDERSON REPORTING COMPANY. INC.

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,.---,-...-s..f; + - m., n.1 ..~r-w... -. ~. 4# '.' f' ;p ;.Jbhe-~pk s s= 'h. Q You can not" answer drift question'i Y 2 A Yes. .3 Q Did you say his name was Bauman, B-a- u-m- a-n ? 4 A Yes. 5 j Q What are his responsibilities? j 6 A He is responsible for design production. That is R b 7 a title. To make sure that all the designs are done in 2 l 8 time. aridi meet the schedule. d 6 9 Q You said he is responsible for making sure that j c 10 all the designs are done on time and meet the schedule, is E 11 g that correct? ri 12 3 A That's right. 2 d 13 3 Q Is he also.' responsible for.seeing that all the E 14 designs are done correctly? m 2 IS 'y A I don't know whether that is his specific respons-16 g ibility or no t, g ti 17 { g Q I don't want to interrupt you as long as you have !ii 18 = got anything. 19 l A No, go ahead. l i 20 l Q You said he is responsible for making sure all l 21 ~ done on time. Now,.I'm not sure exactly the designs are 1 22 what that means. Can you apply that.to the diesel generator 23 building? 24 A No. The diesel generator building and soil 25 related problems are.being handled by the project manager. l l ALDERSON REPORTING COMPANY. INC.

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Okay. I will continue the deposition but it E 14 y appears that Mr. Thiru is probably not the right witness 9.. 15 g in the structural area. But I will pursue it furtner. ? 16 Does Mr. Keeley get any assistance on structural 6 17 y matters from the Design Production Department? E 18 A Yes. 19 Q And who provides him that assistance? 20 A .I do. 21 Q Okay, so we're back to you again.. 22 (Discussion off the record) 23, l THE WITNESS: Just for your clarification.I 24 would also add Mr. Keeley is also the boss of Mr. Bauman. 25 BY MR. PATON: (Resuming) ALDERSON REPORTING COMPANY. INC. ~

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~Q .= v '2 ' Q Will you describe' he cracks -- just a minute. 2 Is there any cracking in the service water structure? 3 A Yes, there are. 4 Q. Are those cracks shrinkage cracks? 5 j A Some.cf them have been determined by Bechtel to I 6 be shrinkaSe cracks. = 7 a; Q Are there other cracks in the service water n 8 8 s truc ture., other than shrinka5e cracks? a d d 9 g A Some of them have been determined by Bechtel to h 10 be other.than shrinkage cracks. 25 11 j Q You say determined by Bechtel, has Consumers d 12 15 determined there are other than shrinkage cracks? S= 13 E A I did not. g i4 g Q Did anybody in Consumers? 2 15 g A Not to my knowledge. ? 16 Q Are you relying on Bechtel for that conclusion? 6 17 w A Yes. b 18 m Q In the service water structure have you done 19 anything with respect to tnose cracks by way of remedial 20 action, or have you taken any action with respect to 21 those cracks -- other than the shrinkage cracks? 22 A My present recollection is we have not done any 23 I remedial action so far. 24 Q Do you plan any? 25 - I i A There is a remedial program in the works.- ALDERSON REPORTING COMPANY, INC.

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  • l 16 Chat Bimal Dhar supervises?

6 17 w A Probably so. .~. 18 Q E Do you have any idea what conclusion they made 19 l as'a result of that analysis? 20 A All the cracks in the service water building were 21 addressed in a question to the Commission, and was 22 presented verbally by Julius Rotz of Bechtel, in a meeting 23, held on the site approximately February of '80. i 24 Q And the NRC was present at that meeti'ng? I 25l A They were present, yes. N I l

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==!" Q That is west? mj 12 A Yes,.I'm not sure in my present recollection as-3 13 j to which side of 'the wall the.se cracks were. They were on* E 14 l w the walls. b_ 9 15 'When the diesel generator building was designed, ili Q a y 16 do you know the total,and differential settlement that was 6 17 y considered in the design? E 18 = A N.o. i 19 l Q Would you expect, considering Mr. Dhar's respons-0 ibility, that he would know that? 21 A Sure. 22 Q Do you know whether that information was presentect 23, in a PSAR? 24 A My recollection is that PSAR does not have a-25 reference to the dieselcseneratcr':buaid:sg. l ALDERSON REPORTING COMPANY. INC. w 4e.,w <m="r -+t- '"^ -). m-. w

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,b 22 Q And your -- considering everything you know about 23 the diesel generator building and the soil.under the diesel y' 24, 4/l generator building, I'm asking you whether in your pro-e es >1' ressional judgment, an anaylsis should have been made to l ALDERSON REPORTING COMPANY, INC. ~ _h y -.4

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37 m ~. 1 Q Okay. Now with respec t to those activities, does 2 Consumers Power review the work Bechtel does? 3 A Consumers Power reviews in general the work done 4 by Bechtel. g 5 Q Okay now. Now I want to get a little more spe-8' 3 6 cific. You say they review in general. Tell me a little b 7 more about that. F,or example, laying out the structure. M 8 What does Consumers do to review the work that Bechtel does ed 9 and at the Midland Plant, I mean, I want to know what in g h 10 y fact happens. = E 11 g A I can only speak in terms of what happened af ter c:y 6 12 3 joining the Consumers Power. By the time the service 13 E water building has been laid out, designed, and constructed E I4 s Q '. And plan.ned? 2 15 g A And planned. ~ 16 l Q All right, with respect to the -- there is a pro-( 17 i g posed remedy at the service water structure, is that correc t? 5 18 = A That's right. 19 l Q And Bechtel is responsible for '; hat proposed 20 review? 11 A That's right. 22 Q And how long has Bechtel been working on that? 23 A I would guess about more than a year. 24 Q Okay, now you used the work guess, that was a 25 figure of speech wasn't it? ALDERSON REPORTING COMPANY. INC.

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r ~ Q L ; ;,' ~?~ c Q . 30 .: i.tr.: ~ N -.. c. -. a.- n x--- g._ ,,.Je ..g m .gc 7. _,,, *n -A I do not know t he' ix.,,'ac t " tim e. 2 Q Would you estimate about a year? 3 A About a year, yes. 4 Q All Iright,n o w tell cte what has Bechtel done in 5 that year with respec t. to the proposed - 'for the' service 3 0 water structure? R 8 7 Q .Bechte.l has evaluated a proposed fix and is still 8 8 doit g the evaluation. The final design is not complete a d ci 9 yet. 3 H 10 -E Q All rtsht', they're evaluating -- they have been in 11 y evaluating a proposed fix and they're working on a design? d 12 3 A That's right. c. 13 5 Q Tell me during the last year what review E 14' g Censumers Power had made of that worki beinst doneoby e.c l 9 15 j Eachtel? g' 16 g A Consumers reviewed the concept of the fix. 17 g Q Have you completed your answer? !E 18 A Yes. E 19 Q Tell me what you mean by the concept of fix. 20 What is -- what is the concept of the fix at the service 21 water structure? 22 A Bechtel proposed to transfer the load from the 23 cantilever portion of the service water building by means 24 of piles to the glacial till level. 25 ', -Q And Consumers reviewed that concept? ALDERSON REPORTING COMPANY, INC. ~

~.,. .g.g,i ; lig --h- .,._,. x. ; % f if,' Q @f ; p -. %.%( f -{.gq..gd 7 3S mv..;,.,;a 1 A That's right. 2 Q And did Consumers approve that concept? 3 A Consumers, based upon the recommendation of 4 Bechtel and their consultants) agreed with the concept. 5 Q Who in Consumers reviewed that concept? 5l 6 A Myself, and Mr. Keeley. R 7 Q 2 Tell me all of the specifica that you wer.e l 8 aware of with respect to the concept prior to your approval d m 9 of it. I mean what did you know about that concept? 10 MR. FARNELL: I think it might be easier if we = 5 II made it a little more specific. Instead of saying give a g 12 me everything. s j I3 BY.MR. PATON;. (Resuming) e E I4 Q Well, you told me--you told me the' concept k-b consisted of' transferring t.he~ load from.the cantilever a f0 pcrtion by piles to the glacial till. Is that all you .d 17 knew? nk 18 A No. E 19 l Q Tell me what else you knew? 20 A I do not recall the specific details at this 21 moment. What I recall is as follows: Bechtel proposed 22 l \\ sixteen piles and proposed a corbel system to transfer the 23 load from the pile. They didn't propose to us the details 24 's. in terms of pile capacity, diameter of the piles, I do 25 .not recall them now. ALDERSON REPORTING COMPANY, INC. E

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17 l g about this concept. The decision could have been reached 5 18 in a meeting in which Mr. Keeley was there. = 19 l l The fact that I did not raise any objection to 20 the scheme -- or I might have told him that I agreed to 4 l 21 l the scheme. I do not know the exact conversation. These ' 22 were the possible ways in which it could have happened. 23 l Q But you don't really remember? 24 l A I do not remember, yes. 25 Q .Did Mr. Keeley say anything to you about this ALDERSON REPORTING COMPANY. INC. i

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sollt information to review and accept this concept? I4 ~ A For'. soils information, I relied up'on Bechtel l EC 15 h and Bechtel consultants. 3 ~ 16 g Q Okay, and what did they tell you? A They told me that this scheme is feasible. a 18 Q They told you the conclusion that the scheme E 19 j was feasible? 20-A Yes, sir. 21 Q What did they tell you about the soils? i A I'm referring to the soils. 23 Q You mean that the soils were feasible? 24 A You raised a question whether I was aware -- 25 information on soils? 1 ALDERSON REPORTING COMPANY, INC.

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" ~ 1'^~ > 2 A And my response was I relied, for. the information 3 on the adequacy of the soils from -- on Bechtel and consul-4 tants. = 5 Q Okay, did they give you any information ab5ut 5 l 6 the soil or did they just give you information that their 3 6, 7 conclusion -- that there was no problem with the soil? l 8 y mean did'they give you any soil parameters? d'I 9 'I'll ask th'e question in another way if it's giving you g l 10 - any difficulty. I think my question is quite. simple. Q 11 Did you merely rely on thekr conclusions or did ~ a g 12 they, in fact, give y.'ou some specific information about 3 [ 13 the, soil in which you coul.d make your own judgment? l 14 A I relied specifically on Bechtel and consultants bx g 15 w on the soils. m

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And you had -- Consumers had previously relied 6 17 on Bechtel, with respect to the soils in placing the plant w h 18 fill, had they not? E 19 l A This, 1: right. 20 Q And that didn' t work out very well, did it? 21 MR. FARNELL: Objection. BY MR. PATON: (Resuming) i I Q Was.there not subsequent to that a rather sis-24 nificant problem with the plant fill? 25 1 A There was a problem. l 1 ALDERSON REPORTING COMPANY. INC.

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Q Did'it in anyway improve the safetf of the diesel 15 generator' building?

16 l MR. FARNELL: Safety in an operating sense? G 17 \\ = MR. PATON: I think you can leap all the way to b 18 that operating stage but if you want it clairfied, yes. E 19 l ,BY MR. PATON: (Resuming) 20 Q The safety at the operating stage. 21 A The surcharge consolidated the fill. Thereby 22 providing a firm foundation for the building. Thereby 23 increasing the safety of the building. 24 l Q Wouldn't the weight of the completed 25j 4 u i 'l ALDERSON REPORTING COMPANY. INC. 'h

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' ~ ~ 2.,. a ;..g.;,.;y. ' 5::7 -m- . v :.. n. h.: hO'.Zf~Cl::.T&,-flg- ' .f$Qgs 51 sn ,x. r 1 Q Review the work that they did in whatever manner 2 trtat you do it. Whether you review the actual process -- 3 I mean do you do'anything about it? Do you do anything s 4 to verify that what they did.was effective? .g 5 A.. The work done by Bechtel in the field'comes 0 under.the jurisdiction of the field Consumer personnel. n' I Q , I gather you have no responsibility-to review ~ a 8 that work-- the work that we're talking about here? d A, hes, I do not have the responsibility to review n 9 10-2 the actual grouting process. = E 11-g Q 'Okay, fine. Go off the record for just one 12 second. S 5 13 . (Dicussion: off.: the record) BY MR. PATTON: (Resuming) ] Q Do you know the program that is planned to 16 d treat these gaps? d 17 g A The plan was to grout the gaps. k 18 Q E Do you know how many gaps there are? 19 l A I do not recall. 20 Q And it's correct, you do not know whether these' 21 gaps. have been. grouted. yet or*.no t? 22 A. That's correct.' 23, I Q Are you familiar with the seismic analysis that. 24 was performed on the diesel generator building? MR. FARNELL: What time? ALDERSON REPORTING COMPANY. INC.

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N 'lE D E 3 ~~ N Yd6 b'kIk5f n.%. 2 * .,7._ g g, h 7-e- ' e.. '. - N e-32 ~ , v. 1 Q In yo ur-- I' m s orry.- - 2 A I would presume that variacion.in strain levels 3 would be' accounted.for in those'formolas. 4 Q My original question was, how will Bechtel = 5 k address variations of sheer modulus with strain and you j 6 referred' to the Topical Report. R 7 Do you know how the Topical Report addresses K .] 8 this 'subj ec t? d 9 .A' No, I don't. 10

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. Q 'Did you expec t that the surcharge loading would 5 Il require 'a revision of your seismic anaylsis af ter the a y 12 removal of the surcharge? b 5 13 MR. FARNELL: Would you repeat that please? 2 14 (Question read) w } 15 THE WITNESS: Yes. = g 16 BY MR. PATON: (Resumins) e C 11 Q And I believe you answered that as far as you E g 18 know Bechtel has that E under consideration right now? 19 g A That's right. Q And -- does Bechtel plan, to your knowledge, to 21 obtain new soil parameters for that seismic anaylsis? 22 A To my knowledge, they are using new soil para-23 meters.for correctional anaylsis. 2. Q To your knowledge, they have already obtained 25 that information, is that correc t? s ALDERSON REPORTING COMPANY. INC.

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~ ' ' W l 6, ... v .<..4.*=." .I,* Iffy W ~; so m-*>*s., \\' ?l) i c. .s ,..: f.., n .,n,v..~ y {JEa .w , p.. s 1,ng;,a co" rect. 'Y 2 Q Did they obtain it after the surcharge was removsdf 3 A That's right. 4 Q Do you know how Bechtel-obtained -- that -- i 5 those new soil parameters? I 6 A' My understanding is that they performed cross I hole tlests to obtain sheer wave velocities. ] 8 Q. You said they obtained new soil parameters and d d you mentioned sheer wave velocities. Did they obtain any 10 other new soil parameters? =, 5 II A I' tit not aware of anything else besides what they ilt d 12 z have obtained in this case. s 13 g Q Okay. Off the record._ ' -(Discussion off the record) t; 2 15 = BY MR. PATON: (Resuming) 16 l Q Mr. Thiru, I want to ask you some questions that G 17 relate to pipes and conduits under the ground. m b 18 Are you< aware that there are discontinuities E 19 l l'n the foundation of' the diesel generator building con-20 sisting of pipes and conduits? 21 A I'm aware there are pipes and conduits under 't \\ 22 the building. 23 ) Q And you're not certain that you would call them. i 3 discontinuities, is that correct? 25l-A That's right. I I I ALDERSON REPORTING COMPANY. INC. j_.-,

= ~ ~ ^ :,..... r- . w.. .4 57;.3 3. g. ~. ,.3. g.: oer ;.;.e.5. a.. 4:-; .,.... m g.; 57 s, " . vi.'s v. 1 y i 1 Q Do you know how many pipes there are under the i Lg-2 diesel generator buildinb? K 3 A I don't recall the number but it is submitted r i .T 4 along with the responses to the questions to the Commission. g<t c 1. 5 Q Do you know how deep in the soil they are? Any g T-3, C ol' them? g o 2 S N My recollection is that the circulating water X ) O E pipe is.'quite deep. I don't know the elevation. The ~ id '9 condensata line is less deep. 4 m - (' .k,10 q.. The.first cae you named was the service water pipei = [ ',r. 5' II MR. FARNELL: Why don't we get it read back? i 2 ! N I2 (Question not read.) L E I3 j .BY MR. PATON: (Resuming) E 14 i 2 Q I do n ' t -- Do you remember? k F 15 K E g A No, what I said was circulating water pipe, = P-16 'l circulating is what I said. G 17 Q Circulating water pipe. a E =- to 18 = A Now I remember that there could be a service E g-19 water pipe also under the building. Q 'Are any of the three pipes you named, to your 21 knowledge, category one pipes? 22 A The service water piping would be category one. 23 g I Q Have you been involved in the analysis of the 24 I stress on those pipes? I. L 25li E A No. ALDERSON REPORTING COMPANY. INC. ~ 9

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..u-...-.,.w :,-.. - u u.... ~.., ~. ~ ~ -... . ~. . ~. -..n.. g,:" pira : =q.., .af y- = Q Who is responsibile for analyzing ny stress 2 that may be on.the pipes under the diesel generator 3 building? 4 A Bechtel. = 5 g Q Is that within Mr. Dhar's section? + 6 { A .No, the stresses and piping would be analyzed E 7 within the 'Bechtel organization by a group called Pip,ing e. ] 8 Streas Group.

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y Q Okay, are those mechanical engineers? o 10 3-A I believe they are. 5 11 s j Q Do you know the name of the person who heads up d 12 3 that section. 3 13 S A Yes, I do. The name is Don Riat. A 14 y Q Do you know whether there are any deviations in 2 15 s the depth'of the pipes from the original design? g 16 w A I have seen the response to some of.the questions G 17 g by the Commission which had figures relating to the survey $i 18 g profiles taken and these show deviations from the original 19 designs. 20 Q Do you recall any deviations as much as twenty-21 one inches? 22 A I recall a large amount like that. .I do not 23 recall the exact amount. 24 i Q Did you ever hear anyone at Consumers Power 25 state that any of the pipes under the diesel generator ~ ALDERSON REPORTING COMPANY. INC.

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.,e" I building are already over stressed? 4 2 MR. FARNELL: Currently? l 3 BY MR. PATON: (Resuming) 4 Q Did you ever? 5 A I do not recall anyone within Consumers Power T { 6 Company making a statement like that. ) R b 7 Q Did you recall 'anyone within Bechtel. making a l A ] 8 statement. like that? d 9 j A s 'I recall. that within Bechtel there was a concern o 10 that the. pipes could have stresses more than a certain z.- E 11 g amount. I do 'no t. recall the amount but the discussion ti 12 E was which code should be applicable under this condition. 5 13 . Q', 'Do you agree that some of the pipes under'the E 14 y diesel generator building are presently undergoing some 5 15 g stress? 16 N A Since I am not a pip.i_2g stress engineer I can i 17 y not give you a definite answer to the question. E 18 'g Q Do you know whether Bechtel has any plans to 19 monitor settlement of the diesel generator building? 20 A There is a monitoring program to measure settle-21 i ment of all the buildings. l' 22 { Q Do you know any -- has that been submitted to j 23 the NRC? 24 i A I believe in the presubmittals to last time, it 25 .had been, yes. \\ ALDERSON REPORTING COMPANY, INC. s ~ ..}}

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