ML20090A858
| ML20090A858 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/02/1980 |
| From: | Kane J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101140144 | |
| Download: ML20090A858 (180) | |
Text
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, 39 -.:.... . # -g '3g-{g ?l.r '- Uh'Q'A*R .... m,~.- K.,."l$~ $-(( (*[:'. j a*- . ^UM. -..,.::, u 7 CR 5756 1 UNITED STATES OF AMERICA WRSlocm/wb 2 NUCLEAR REGULATORY COMMISSION s-3 Before the Atomic Safety and Licensing Board 4 5 In the matter of: Docket Nos.: 50-329-CM 50-330-CM 8 CONSUMERS POWER COMPANY 50-329-OL 50-330-OL 7 (Midland Units 1 and 2) 8 9 DEPOSITION OF JOSEPH D. KANE o to VOLUME IV 11 Bethesda, Maryland 12 Tuesday, 2 December 1980 13 Deposition of JOSEPH D. KANE resumed by agreement u 14 of counsel, pursuant to adjournment, at.9:00 a.m., in Room 15 P-110, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland, before William R. Bloom, a notary public in and for 16 ^ 17 the District of Columbia, when were present on behalf of the la respective parties: o to On behalf of the Applicant: 20 RONALD ZAMARIN Esq., Isham, Lincoln and Beale, b. One First National Plaza, Chicago, Illinois 21 JAMES E. BRUNNER, Esq., Consumers Power Company, 212 W. Michigan Avenue, Jackson, Michigan 22 i (L E Oe% u A ~ '\\ O. 9 l
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ebl 1 This is the continuation of the 2 MR. ZAMARIN: n deposition of Joseph D. Kane, continued from.the previous s. 3 session of Thursday, October 16th, 1980. 4 5 Whereupon, JOSEPH D. KANE 8 resumed the stand and, having been previously duly. sworn, 7 was examined and testified further as follows: a O FURTHER CROS9 U.MINATION g o BY MR. ZAMARIN: to Mr. Kane, you understand you are still under oath 11 Q ~C and sworn to te,11 the truth, dont you? 12 13 A I do understand, w Do you know what type of Piezemeter as used with 14 Q w regard to the surcharge program of the diesel generator 15 l 16 huilding at MiC -I? 17 A Before we start, oculd I give you some information l 1 that I had indi=ated in my previous testimony that I would i is j 1 19 give to you-j 20 Q Ch, surely. ...( - having to do with record sampling?. 21 A 22 MR. PATON: Why don't you identify it, tell fairly M E!.,.I W eL. L y I y 9 .s
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cr. 2 again. .kl n 25) THE WITNESS: It is in response to my previous m 3 b testimony.and it can be found in volume I, page 54, of the 4 ye1 .M,J previous testimony, and it is sources of information having te f' 5 And do with record sampling and testing during construction. ,an 5e 6 f,ik these are excerpts from a Corps of Engineers' Engineering 7 v e.. 1 1t.4 a Manual. j,.g There are three pages frem EMin02-2300.5nd th*Y .....n iNd 9 W I. w . ~ - " 10 are pages 7-1 through 7-3. v In addition as I recall, Mr. Zamarin also asked me ?) 11 C' for a list of events that I had before me which I had given 12 G Ch.d 13 to him in deposition. And I have made a ecpy again of that Fr.1 u chronology of events for Midland, 14 ij.M one cther comment I would like to make is when h 15 &,;: A) - questionad about the number of employees in the Gectachnical //.. 1e WC Engineering Section'I think I cave the names of seven pecple. 17 g;j The names 9+.;; I should correct that to add two additional names. 18 M. that were missing were Gerry Pearring and John Chen. i $g 1s ?;i.; $5.1;. 20 BY MR. ZAMARIN: C Would you spell the two names, please? 21 Q g se Pearring is P-e-a-r-r-i-n-g, and Chen is C-h-e-n. 22 A pa sh IN$ v yyg g_ .s P g l
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..t. n 3:, n. :. o.,.: -.- '.s ~.. y. $ J .;b.. L..: p. ; M' N , e -.. m v..~..,.-.... ,;-;.. -<vt.1-, n -r e.... .. ~. p. .s g..r%.g.= c e w... - g t cb3 1 Q John Chen? e 2 A Yes. 3 Q What are their titles? A Geotechnical engineers. 4 5 Q Have either of them done any work on the Midland a soil settlement issue; to your knowledge? 7 A No, they have not done work, to my knowledge. s MR. ZAMARIN: I am marking as Exhibit Number 18, 9 Consumers F.whibit Number 18 as of today's date, 12/2/80, o the document that you produced today, the first three pages -- l 10 l the first four pages of whlch are the sources of informatien 11 l 12 that you referred and the la'st three pages of which are 13 the chronology to which you referred. u 4 14 (Whereupon, the documents refer =ed to were marked is to as Consumers Exhibit 18 17 for identification.) 1s BY MR. ZAMARI": 18 Q Is that right? 1 20 A Are there only two pages to the chronology? b., 21 Q Three pages, I believe. 22 A I thought there were only two. Okay. L Ed Je % eL. ) ~ S v -e,, ,r%
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AM...;;, g.3 a- .f-7 ob4 1 Q Well, I don't know. Look at what',s on the last e 2 page. Maybe that's not part of the chronology. What's that on the last page of what I've just marked as Exhibit Number 3 4 187 There are two pages of chronology, and one addi-s A tional page of events that were developing as the soil ~ e settlement issue was being reviewed by NRC that had been 7 a prepared by Lyman Heller. s Q I have a question p= Ming. I will withdraw it now because I want to get onto another line, and I'll ccme back to to 11 it. 1 Since October 16th, the date of the last session of I 12 4 your deposition, have you come into possession of any docu-13 } b 14 ments that would be within the purview of the notice to pro-a i is duce at the taking of the depcsition as modified by Counsel? n m 7 la A Have I come into the possession? 17 Q Yes. 18 A Does that mean things that I have written? is Q Things that you've written or things that have been y 20 transmitted over, given to you which would be items that are 4, u not in the Public Document Room, unmarked copies - strike 7 21 n 7 22 that - marked copies of things that are not in the* Public a N \\' AEN$l L, Sna, ~ 4 .s l. e e e e.-, ,,.,n, ,.w. .n-.
1/25 h mcs M %i w %'I~W;.-@g A.~..w, MW ( I E U.i :CiisasEC-qr;s pw-g-g=m=. c. a r- .. c. -n~.e.m i.... u.n.,. -.~--'- w.c o. m..,w.u m. g;7 ,,,,n._v;r_.m_..,_..,,;...m_,, l y 'f;th, =w ,,,m ._ y Document Room, or items that otherwise were not transmitted ab5 1 ,e 2 to or from Consumers Power Company? s i 3 A I would say Yes to that question. i 4 Q okay. Do you have any of ' hose items with you now? 5 s A I do not. 7 Q Where are they located? 8 A In my office. 9 Q Would it be possib'.e for you to bring them with n to you after the lun=h break? 1t A I could bring as many as I can identify, but there C 12 may be some that I could not readily-I would have to go through all my files again and deter:nine which ones I have not 13 u 14 given you. 15 Q You could make an effort then to at least bring as many as possible after.the lunch break, and then at some 1s 17 later date, do a more careful review of your files and supply 18 us via Mr. Paton with other documents? g 1s A some of those documents refer to the preparation 20 of our testimony with regard to the up-coming hearing. I <(- would want to discuss those with my. counsel. 21 1 22 Q obviously. And I would assume the claim cf i \\ s e a k e ]
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? ..g, s. 2 h?p-_ , n. -m,:...<-:- : :u: -;- Dp _-y.fyy. ..:3., 3y.f . cr.-. .... m ,,.e. 9 r privilege would be asserted, and then we'll see whether we ob6 1 agree or whether we.have to seek higher authority. 2 c. 3 Really all that I'm asking is-4 MR. IAMARIN: And perhaps, Bill, I should be asking this of you rather than the witness, if he can just bring l 5 us what he can find over the noon hour and with regard to the a items that would require a more thorough search, if he could T i And obviously a do that and you could supply copies to us. the claim of privilege is something that need s to be identi-a o to fled and then assert a privilege. 11 MR,. PATON: Yeis, we'll respond to that after the C 12 lunch hour. - ' HE WITNESS: Could I ask that since you're asking I 13 T me to bring it after lunch, I will not have time to make I' copies, that I bring those and you identify, similar to what 15 you're doing for us, which documents you would want? j to i 17 MR. ZAMARIN: Yes. I anticipate that I may have some questions on them after lunch but yes, we will then is Is identify those of which we want copies. BY MR. ZAMARIN: ~ C Do you know what type of piezameter was used wd.h 21 Q t regard and in connection with the diesel generator b"4 W 'g's 22 a ? ) U.. .@ G ' I& S, ~ F e S. i
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.. g, g : _c .y;c.w, h:3.-c-s. . -- ~ - w _. 1 v :- g. y;- _.s. -..e,_:. .,.r v e. 3 ;, 11_ The sensitivity of the different type piezame: ors 1 A cb8 2 are different. c. And does the type of response that each gives 3 Q differ in that some would have a slow while,others would have 4 5 a more instantaneous response? n i s A Yes. f Do you know which type, with regard to sensitivity 7 Q and method of response, was used for the diesel building a 8 surcharge? Being the air pressure type piezometer, you would o l 10 A l expect a more rapid response to the pressure versus such as 11 C an open-tube type piezameter where the larger quantity of 12 water would be re @ ed and there would be a period that it 13 u would take to respond for that water to build up. l' i If you had, for example, the more slow response la Q type, would that influence piezometer readings insofar as is
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17 Would you repeat the question? My understanding ts A i' of the question is if we had the type of piezameter that had 1s P a slow response, would it represent or be affected by the 8 i Is that correct? L 21 excess pore pressure. The question is if a piezameter of the slow I. 22 4 ,Q No. 4 $dk& Sne, ~ l r o 's 4 3 j ~
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n 1.158 1s Q If in fact such slow response piezometers were .;.Nn 20 used rather than the closed system or instantaneous respen i-y piezameters at the diesel generator building, would that, 21 J _.y in2i y,3;.g your mind, possibly account for what you peresive to be a 22 ,, e g:n
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pressures was over several months, and I think the d 's lag M 5 f a that is a problem with the slow response type piezometers .'.f~ y 7 would not be over that period. I think it would be over I.,s 2R e periods. of days rather than months. o e Q The time lag y'ou say would be over a period of days j s $} to rather than months; is that right? 11 A Yes. u C ..j 12 Q And in your mind it is not possible then that a pore pressure dissipation was so rapid that it could have h 13 .:n 14 occurred in significant magnitude during the first several .jd <d days and therefers not have been accurately-recorded? cl.w 15 9 .sd %%} qi is A well, it's my understanding that the piezcmeters .a1 h;lj 17, are a closed system and therefore, they would be more 18 accurate. 4 ^ 4 t. ) 19 Q Could you answer that question assuming that they j_ 3 %9 weret$1eslowresponseopensystem? 3 20
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,=. usc we. 1 v~ ere observed at Midland, in my opinion even with the slow obil I w The pere pressures would have type it would have been higher. 2 n developed higher than what was indicated add what you have 3 i 4 submitted for Midland. And is it also your opinion that not only would i s Q they have developed higher but that they would have been e recorded' higher even assuming the use ed slow response open 7 a system piezometers? 8 A Would you repeat the question? I o (Whereupon, the Reporter read from the record to 11 as requested.) 12 TEE WITNESS: Yes. i 13 BY MR. ZAMARIN: u Are you familiar with the piezemeter styled a l' Q le Casa Grande type piezometer? 1s A Yes. .Is that a slow response or instantaneous response 17 Q i piezometer, in your opinion? ta Is A Slow response. You testified at one of the previous sessions of 8 Q ~ f your deposition that you.had expected, or one could calculate, C U I believe, a 35-foot head as a result of the excess pore 22 j I 988. 3 ^
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. ;;;gy. -- .? ;3 ;.~g &u 3:.: f c- ..,...g mv.. m 15 r ab12 1 pressure. Is that correct? I indicated that would be the maximum level that 2 A n i l 3 you could expect. ?l Are there certain assumptions that one would have 4 Q i q a to make in order to expect to reach or approach that maximum 5 1 a head? i )( 7 A Yes. m Can you tell me what those assumptions are? 8 Q c.4 That the soil is fully saturated, that the lead f .) d s A w y imposed initially is imparted to the water in the pore pres-10 1. -.3 sures and not carried any by the soil structure. 11 q -(, Would one of the assumptions also be an instan-12 Q 4 l 9ti 12 taneous application of surcharge? 1 u d 14 A You'd have to define " instantaneous. " Are we sayinc s .1 J 15 within seconds? .b Why don't you tell me within what period of time 18 Q fy 1 the surcharge would have to be applied in order to be on-17 g 'sistent with an expectation of the maximum 35-foot he d? 52 1s I The time that would have to be applied is before g _] 19 A 1 [2 20 any drainage would occur. ~ 3 y 21 Q With regard to the diesel generator building area, f"rl y'I what is your opinion of the amount of *Ne before drainage ~ 22 l. W OLEJ.Je?; a G, ~ $.y J i?1 N M v
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drainage path, in your opinion? p. s A I don't
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In some loca-J ': tions it is my understanding we have essentially a full depth 7 .i 8 of fill that is clay. In other areas we have mixed. In othe: a e areas we have entire sand. And I don't think I can give an ., ::d n average for those three conditions. ~10 'O k. 11 Q What would you ' expect the time to be in the area C W,d 12 of nainly sand? h4 13 A I would expect it to dissipate rapidly. q.] s u ,2-- 14 Q Eaw rapidly? Within a day?
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^ : 23 15 A over a period of several days. .:. d he-m .... j Q What about-- ?~ 1s -s-.., 17 A It depends on the permeability of the sands. The: ~ ' ' %) 7Ti is would be some sands where it would not build up. There wculd j to be some sands where it would. %. i Q When ycu say "it" what are you refarring to? 20 .l 21 y,} A The pore pressure. 22 .7.3.a Q okay. 3.'.. - e
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~ O.- u4 g C'~ ' . w,,:. M,s,J-[.h.M-{.2.'" f --- g } - M*p .",:r6 A ~ y' a.-- sw .n. gs ....m ~ 17 Now,we're talking now about drainage path; right? cbl4 1 2 A We're talking about drainage path. But the drainage 1 .rs path is the means by which the pore pressures dissipate. 3 4 Q Right. 8 You say there were sema sands where pore pressure 's wouldn't build up. You mean it would not act as a drainage 7 path 7 s A No. What I mean is there were some sands that are so permeable that upon loading, the water would not build e w up - the water would not build up a pressure because of that. to leading and it would drain almost instantaneously. 11 C There are other sands, because,of the gradation 12 13 or the percent fines, where that would not occur. Where wouldthe sands that id is your understanding to Q existwithregardtocerta5nareasofthedieselgenerator 15 building fall within this gradation of fines that you refer te 17 to? 18 A I would say wherever there were sands that had more ) t1utn five percent fines, five percent passing a 200-mesh sieve. ] to 4 [ 20 Q What would happen where you had sands where there ( 21 were more than five percent fines? The rate of dissipation of pore pressures, the 22 A 0L E.L.t M eL ~ 's, a 9
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1 8 we have sands with less than five percent. ..=. ; y, ' 7-:] 9 Q Based upon what your understanding of the gradatic o ,1 .J 10 of the sands in and around the diesel generator building is, n <1 do you have an opinion, based upon your gectachnical enginee- ~ ~1 11 J C ing experience, as to the amount of time that would be re- ~-M 12 quired under the surcharge conditions that exist at the diest 1.i 13 q .g generator building for drainage and dissipation of excess 14
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.7 15 pore water pressure? 4 ".) j te A The question is directed toward the sands? 3, 17 Q Yes. 43 '._y~. j 18 A I think I have-indicated how quickly the sand c e . ~. ' 19 drains depends ~en the gradation. So if I'm being asked to Ji .1 20 make a guess of time, then I think I have to know which type 3 i b s 21 .nj of sands you're talking about. -\\ 22 Q Well, the predicate of my question was based upon ,. :g. ' :.y s.y J , ur es. m \\ kJ
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~ c-<,. % c-3,u 19 l our understuiding of the gradation of the sands which you've cbl6 1 y five percent described as silty sands which are greater *han 2 fines and sands between five and 12 percent fines, based upon 3 i your understanding that that was the type of sand that we 4 had, what would, in your opinion, be the time for drainage e 5 and dissipation of excess pore water pressure under the sur-e 7 charge conditions 7 I'm not sure that the witness indi-MR. PATON: d cated that that was his clear understanding of what the sands 9 were because I think he said when he got finished that he to wasn't sure whether there were any sands less than five per-11 C-12 cent. To answer the question I think I 13 THE WITNESS: have to address the three types of sanb that I have grouped 14 that could possibly be there, and I would say that if it is 15 less than five percent fines, then the diss'ipation of pore Is pressure - the drainage through that material will be very l 17 ts quickly, If it were, say, five to 12 percent fines, I think to there would be some buildup of pore pressures but that would 20 C And by " rapidly" I'm talking about days. 21 rapidly dissipate. s the type of material that has more than 12 22 If ite l '\\ l N O I n n-- -,--e v- --n, d , e r, -,
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percent fines, I think it would take weeks to dissipate. Cp3 ab17 1 d&2 Nd 2 BY MR. ZAMARIN: m 2 Q When you say "with five to 12 percent fines it i4j bb would take days," are you talking about one or two days? 1 4 ? M'i;7 s A Yes. But it should,be recognized that we have 3W.h silts and clays in the fill; which would take much longer. v n.se a 63 7 Q With regard to the clays, and based upon your un kJr*' ,5 C M. + a s*=nding of the pred~ain= t characteristics of the clays ex .wrk ing under the diesel generator building, what is your opini ca.. q s '2.m'{lo 6
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11 water pressure under the surcharge load? "If1 12 A I know there are many facters which affect the t FhNh dm 13 and that is: how fully saturated they are. That could bri .-w.g u ' *5 up the problem of, if only partially saturated and, under ic .#sN 14 m.c ing, now causing some of the gas in the air voids to go ist ..::~ ~ 1s g) {M solution but some gases to rammin in the air voids, and if d.;.J 1s ph were only partially saturated and that occurred, f. hen that ,w t 17
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m +M.4 1s w; o., I knew the degree of saturation of the materials that were I:2-4 20 I )p.pi Q .T { involved, until I knew what is the likelihood of sand lens v 21 n.s 22 extending through those areas. *There are many factors to ~4 g w...A.: g, s 9 s -l% e, 'h,3 ;. ~
.f",'};. l-J ?; p.x eu % ;:~3-M ,. 3 .;a-?,5;L*Q.;573_-._ =. . ma... --.. o - a si cb18 1 considered. c 2 Q You say you would have to know the likelihood of 2 sand lenses extending through those areas. Is that because 4 the time for dissipation and time to consolidation varies as s a function of the drainage distance? 's A' Yes. 7 Q And do you know by what mathematical relationship a time relates to the function of drain =nge distance? 9 A Would you repeat your question? f o to (Whereupon, the Reporter read from the record 11 as requested.) C 12 THE WITNESS: I don't' recall the exact mathematical 13 relationship. u 14' BY MR. N N: 18 Q In coming to your conclusion that the maximum 18 drainage head would be 35 feet, did you asuune a certain 17 drainage distance? I la A I don't think it's proper to label it "m=v4 mum l is d=a m ga h.ad.. 20 Q Label it however you wish then. .t 21 A It is the maximum pore pressure that could have i 22 developed because of Icading. A G.Lte9:: eL. ~ L 0 y e ...m. r.
Q: ',._,_._. l "'" _ W: J_~ ~}\\;.=l..%s,M; #N" 2 3.:;-.- J. t y?3SN~{] . T ~pd,_ ' W~1 - '.,1 M$$ Yip 3 , - Ij5ffM . =7pvn :, m.w a -mn.- n.m, ~~ y 1.,,.,.,,,_ . '{ $ Y w s* w :> M, ,-r. ..m n e ~ ~ * ~ u se ? Un w n o n ~.*=se -m=~* ~ - ~ y .s. g g es-, g .~ I cbl9 1 Q Then in reaching your conclusion of maximum pore pressure head of 35 feet, did you assume a certain drainage 2 fm 3 distance? 4 A No. I think the indication that it's the maximum s head is assuming that there are no readily apparent drainage s paths. l 7 Q How does the drainage distance influence drainage I J 8 time? o e A When a soil is loaded and is fully saturated, the tendency $stosqueezethevoidsclosedwhichputsthepore to 11 water under pressure. That pressure wants to relieve itself .( by draining, by seeping out of those air voids. And so the 12 j t3 longar the distance that it has to drain and develop seepage o 14 resistance affects the time of drainage. 15 Q You're saying that in reaching the conclusion of a maximum pore pressure head of 35 feet you assumed no resdily 18 17 accessible drainage paths. Do you think that that's a likely ta circumstance with regard to the diesel genera *ar building? 1 ts A Could we go back to where I said I have assumed 20 no readily available drainage paths? ,,C Do you mean you want to hear your answer again? 21 Q 22 A I want to hear where I made that statement again. M E.4 tM &L ~ s 1 l I
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.,.,,y,; r 3$ Would you read that answer back, ab20 1 MR. ZAMARIN:, 2 please? e j (Whereupon, the Reporter read from the record J 3 4 as requested.) s TEZ WITNZss: I think the distinction I'm t ying I to make is the computation for maximum pore pressure-8 think I have indicated what are the assumptions when you 7 calculate that, but they are the assumptions to calculate the 8 And I'm saying pore pressure that you could develop. s
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w maximum....The question that you have is when I do that I.'m to j It assuming no drainage path. I recognize that is the==v4 mum .i C .value, and I recognize there a're drainage paths in the fill 12 m at Midland which would give Eta less than that==v4==. 13 SoIguesswhatI'mobjecti$g:_misyoursaying 1' that I concluded that there were no drainage paths. 18 9 te BY MR. ZAMARIN: 9 17 Q I didn't say that. I was simply asking whether ls p I-you believed that there were no drainage paths with regard ts to the diesel generator building area at Midland. to i 20 g I think I said I felt there were. t Based upon what your understanding of what those 21 Q drainage paths are or are likely to be, do you know how much 22 s i \\
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.A- .~ ~ W ,&52 wNum w-g less than a 35-foot head would be in fact expected? 1 ob21 It seems we are now repeating a line of questioning 2 A p \\. I think we are. And you are 3 that you had given me before. asking me to give you the pore pressures which I felt are 4 more reasonable for the Midland site other than the 35 feet 5 and I think I have indicated in previous testimony that it 8 7 would take an analysis to do that. And I think I went through talking about sections, ~ a about reflectinir on those sections, soil parameters,. soil s stratification and estimating what'I thought were the potential j to And drainage paths to be able to make.that kind of analysis. 11 C I,think we're returning to that Isame line of questioning. 12 so are you saying as you sit here now, basad on 13 Q your expertise in geotechnical enginee ing, that you cannot 14 provide.an opinion as to what the likely drainage path is with 15 regard to Miatand and therefore, what effect that would have i 1s l i i on the maximum pore pressure head of 35 feet? 17 As I sit here now, I have not made that computation. ta A f I have indicated to you what I thought would have to be done te to make that computation, and I have indicated in the past I 3 ..L felt if there are reasons to explain why the pore pressures 21 did not develop to higher levels that you would have anticipatec 22 l M \\ I i l I
~y... <:.. c .. G-;. .n.,q.,z-3pf ..W:h&DZ12 'j.-_^ &' . %gc.*-4};W. 'J.W:7 ~& - , n.v..m ^=;- e 1 ,.,. y .rsw. n .,.4.- 25 e > .t then this type of analysis should be made to give reasons why t ,1 eb22 1 ~., 2 it never reached that level. m. j Is it true then as you sit here now vou are not
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7'$ 11 L.J C. I'm not capable of giving you an opinion because 12 A +., 13 I have not done that analysis. g; o Do you believe that such a calculation of.drainac a 14 .Q
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'/M 15 G be calculated based upon the heterogeneous nature of the w. te f.c,3 D Il soils in and around the diesel generator b"11d+ng7 gy; - 17 hili I think an examination of the conditions that I ts A 3;4 have talked about previously could be made and give a good y 41,] ts .7.n.,n.J nndnest=aM ag why the pore pressures never fully developed. 20
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m ?:0,4 L I don't want to indicate that I think this is an exact com-re 21 yd4 e% putation that anyone can do and when completed there would .1 22 L _' 4 - Mv - -s %f
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~n - - - -~ ~.., _.; E 26 j eb23 1 no questions. 2 I think I had indicated that there would be many n o 9 assumptions, assumptions on stratification, assumptions on 3 0 0 soil parameters which would be involved. But I am saying if 4 the pore pressures never developed to a level that we would s 4 s anticipate, there must be reasons. And looking at potential 7 drainage paths may help explain the reasons. t Q Do you know whether time of dissipation varies as a the square of the drainage length? w l. to A I'm not positive but I think it does. 1 11 Q so then if you had a drainage length that was one-f-C fifth of an assumed length, thin time for dissipation would be 12 d one-twenty-fifth of the time that would be calculated for the ,l 13 14 assumed length. Is that,right? 1 15 A That's right. 1 is Q I take it then that the' drainage path length would !t 4: 17 have a substantial impact the on the time of pore pressure dissipation and the extent ti. which certain piezameters i 18 18 would record all of that dissipation. Would you agree with 20 that? i v 21 A I would.- l
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Would you agree that the process of settlement is \\ S. .r- ., ~.. - -.,,,. - -,,,
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....v .m s..: .w 27 e a decelerating process under constant lead? ab24 1 2 A Tes. 3 Q And,by that am I correct in understanding that = there should be marhum settlement at the beginning of [ 4 application.of a load, maximum dissipatica of pore pressure s r at the beginning of application of a load, and then no [ e acceleration in the settlement or dissipation of the pore 7 a pressure under that constant load? 9 ,A Generally, yes. There could be extanuating circum-f n to stances which could change the rate of acceleration. 6 11 Q Tell me what those extenuating circumstances are. {i. To cause a change in site conditions such as 12 A ii a increasing the level of cat =stice in the soils where, ht-13 u E 14 cause of developing satu::ation new zones of soils have become u 15 saturated and the saturation effect overwhelms the normal 1s deceleration of settlement. Da y 17 Q Would there be any other extenuating circumstances 18 to your knowledge that could-19 A Not that'I recall. I to Q Are you familiar with the settlement versus log . 21 time plots for the settlement markers on the diesel generator g building during the application of the surcharge and the 22 1 = .[ .C., res. 1 O N ?
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. v.c =m.. w,. ~.,. ..,; '.aw~ nac, - 29 K $ ?cw k u g ~ ab25 1 removal of the surcharge? i A' 2 A I have some familiarity with them. y.q p w i 3 Q And do you recall that they are essentially of a q V.: somewhat S-type curve showing a second drop? 4 ~ 32 C3 8 A I'm waiting to see'the chrve. . gg g.j I have here Fig'tre 3 of Consumers Exhibit Number nli;l 8 Q . :..n
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g' ; to A Perhaps you would like to indicate on here what '~ h 11 you're referring to a's the second drop. C Well, what,I see'is the portion before I believe 12 Q + 13 it is 100 on the log time scale. There's a certain slope an: o v 14 then that slope decreases. It turns upward -- not upward of j 15 hori=ontal but it changes slope, doesn't it? .ak 18 A It appears, does it not, to change here and also yM + --: ^! 17 here? .H 9e ts Q Unfortunately when you say "here," we can't get w ts it on the record. It's just before the 100 on the log time l. a 20 scale it changes. Is that right? ,$l ty i .s 21 A It appears to change at the time just before 100 ,v ',g;j l
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....,..,.-.....-n.ans.. x 30 ,e _gi = w = ~.. - - _.--.- u .a p g cb27 1 wouldn't expect to find a settlement versus long time plot ^. 2 for a lab test, would you? 3 A Yes. 4 Q Ch, you would7 5 A Sure. ~ 52 8 Q Why don't you describe for me then the type of ~ 7 laboratory test and the type of plot that you would have for primary and secondary consolidation with regard to lab tests. a 8 A Do you have a curve you wish me to indicate it on o 10 or do you want me to draw my own? 11 Q I just want you'to tell me what you would do, what C 12 you would plot on each of the ordinates. and what the cu=ves 13 would look like. u 14 A We are now ta?. king about a laboratory testv-18 Q Yes. Is A - which is plotting either dial deformation read-17 ings which is the equivalent of settisment versus the log of l., time, and.you would anticipate having an 5-type curve there 18 from which you could estimate the end of primary consolidation 18 20 and the begi:using of secondary consolidation. (engs. 21 Q You said you would have what type of defo:mation f i 22 reading? Dial? i i I % E.Jt M 8 ^ \\ s l l t [
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31 cb28 1 A Dial. \\ J 2 Q Dial? Gauge, dial of the laboratory equipment. A 3 Is this a standard type of test and method of 4 Q f. plotting used customarily in good engineering practice? a Which one are we referring to? i A 3 The one you just described. 7 Q 3 A Dial deformation? Dial deformation reading versus log of time. e Q I to A It is customary. 11 Q It is. C' Customary in the.engineerisg field or just cus-12 tomary with regard to NRC engineering practice? 13 customaryintheengineerinkfield. 14 A Do you consider it a reliable method of estimating Is Q to or predicting settisment? The plot we're talking about was versus log time.' 17 A That plot is not used to estimate the amount of settlement ts but the time for settisment to occur. ts Do you consider it to be reliable in estimating to Q l C the time for settisment to occur? 21 l there There are cases where I would consider it; 22 A AGl tW 8, ~ 8 9 9 3 ,, - +, r,- -n
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-,.3 Q c: %.~. - .;i -g ch29 1 are cases where I would not. \\ l 2 Q Would you consider it a reliable method in the I case of the diesel generator building? 3 Because of the heterogeneous nature of the fill, 4 A it would be difficult to use that to predict the time. s e Q What kind of a lab test, if any, would give re-l liable predictions as to the time of settlement in a situation 7 a such as the diesel generator building? 8 A The test that we're talking about, the plot of n 10 deformation versus time, would be the best laboratory ap-
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11 preach, the best available. 12 .Q Is there a laboratory approach to predicting 4 13 settlement? 14 A The amount of settisment? ts Q Yes,- ta A Yes. 17 Q - with regard to a situation"like the diesel 18 generator building. i 1s A It's been my experience that it is more accurata i l when running the consolidation tests to be able to predict 20 the amount of settlement than it is for the time for settle-21 ment to occur and therefore the laboratory consolidation 22 l 1 's 9 I 1 ~. - - 1
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+..$ I[#M' k - y. : > g;.. ..m ~ . nw. .u. .y. f ab30 t test, in my estimation, can reasonably help you to predict. 2 the amount of settlement. n 3 Q Okay. There's an expression I use that is called 4 damnation by faint praise, and I'm not quite sure what you a said or if that's what you did in that answer. a What I understood you'.to say is that predicting 7 the amount of settlement was a little more accurate than a predicting the time of settlement using the dial deformation a n versus log time, and that it would reasonably help you in to 2.050 11 predicting. Is it a reliable prediction of amount cf settle-12 ment? 13 A There are cases where it would be reliable and o 14 other cases where it may not be, ts Q In your opinion would it be a reliable prediction 16 of the amount of settlement in a case such as the diesel generator building where you have heterogeneous soil pro-17 ts parties? i to A Yes. Yes, if the various conditions that exist 20 under the diesel generator building are appropriately taken C 21 into account. 22 Q dkay. M U.L.I3: :-., eL. ^ 4 O 9 8 e A
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. / 4, 4. What are those conditions, and in what way would Ob31 1 they be taken into account so as to be appropriately taken 2 3 into account? Because of the different types of raterials and 4 A their different thicknesses and their different compress-s ibility characteristics, you would have to establish by sub-a surface explorations the thickness of the layers and by 7 laboratory testing establish.their compressibility charac-a s teristics. And it would be recognized that there would be to 11 wide variations. In recognition of those variations you would use the laboratory consolidation test to give you a 12 range of settlement predictions. The range would develop 13 because of the different soil thicknesses and compressi-14 ts bility characteristics. la Q And what would you do with the range? Rave an tmAmestanding of what I think would be 17 A is the maximum and =4a4="= settlement that could be expected It under the diesel generator building. l. 2D Q Do you have any idea what kind of a range you r.L might be talking about with regard to conditions such as the 21 22 diesel generator building? $dMM8 ~ l 1 x O 8 .._1
7 ..K ^~.iC Q-Q~~l;:=y, ~ & Q.....,._.,_.y:;.gg': ,3_ y:2..::k i. A ;q --c- - .- m %v- .:.,.u. .e. - v - 35 I can only put numbers on that af ter I made that cb32 1 A 2 analysis. You don't have any idea now whether it would be 2 Q a range of, for example, a half an inch to 25' feet or scme-4 5 thing less than that? Based on the behavior of the preload I would say 8 A e 7 it would be less than 25 feet. Can you tell me how much less you think it would a Q 8 be? o to A Considerably. 11 Q How much? Quan*4'y that if you can. C 12 A Less than 10 inches.' You believe the range would be somewhat less than 13 Q o 14 a.10-tach range,7 la A Yes. 18 Q Can you as you sit here now indicate how much less than the 10-inch range you believe it might be, or is that 17 is as far as you want to go? 19 A That's as far as I feel I should go. As far as you feel you should go for what reason? 20 Q b-That not having made an analysis I shouldn't be 21 A l 22 giving figures. _1 x 9. e 9 m== e 4 e.* e a.ess
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%:==A.cW { .,c.e- .y-e,.:s-c.. ;;,. ~ 37 eb34 1 Q Would any five of those borings be. sufficient to 2 make that calculation? os.. 4 3 A There's a certain amount of judgment on what 4 borings are enough. The horings that have been located 5 attempted to do the perimeter of the diesel generator build- 'e ing. I think some of the horings for the diesel generator 7 building, the six additional borings, have already been 8 agreed upon by the Corps to be deleted; that is the borings s that ask for the standard penetration test because of new n 'i to information that you submitted to us on September the 14th. 11 Scate of the new borings would give you the infor-C- 12 mation equivalent to what had been asked by the Corps borings, so some of the borings could be el4minated but some of the 13 14 borings required to take undisturbed sampling would still be 18 required in those areas. 18 In other words you would have to evaluate the 17 boring that have been completed plus the additional borings 18 the Ct._ps is asking for, evaluate the standard penetration 18 test results, and use a judgment where you would want to take 20 undisturbed sampling for laboratory consolidation tests. ..L 21 MR. ZAMARIN: Would you read the answer back, 4 i 22 please? i 'N I t
..!_ T a %..,~..-. - =i ~ %ww* ' ~ * :s_s.. ks,J. ,"y&2?25 W 4Y R..."c.b.4;.-~gur* (ni v^^.-,,WW h*4(t & ff? g _.. . ___x..m; w r 4,. ^ -umm--.,.s.,,.,_,.,,,___,_, O % ....:.;..-x ~.x ,,.-n.--...c.-.~.. ,y# IGidd,n.. = 7' ob35 1 (Whereupon, the Reporter read from the record ,p 2 as requested.) THE WITNESS: Could I say something? l 3 If I had said all the borings, all the SPT borings 4 in the diesel generator building could be deleted, then that 5 e is an incorrect statement. Some of them, and I thi.* there are two in the diesel generator building which have been 7 judged not to be required because of the additional info::ma-i a o tien that you have submitted, but it does not relieve the e necessihoftakingundisturbedsamplesinthoseareas. to BY MR. ZAMAR d:~ 11 , So it's t=ue, isn't ih, that the number of bcrings 12 Q 13 in the diesel generator building area rama4n the same as it f 14 did with the orig 1.nal Corps request? 15 A No, that is not correct. l to Perhaps I can explain. 17 Q Please. Six borings requesting sta.ndard penetration tests .ts A were originally requested in the diesel generator building. to You have submitted new boring information in your September 20 L. Some of those horings are in the area 21 14th, 1980 submittal. 22 that the Corps had asked for borings. It has been judged S O
2,.. >.:3 ;... 5 p.c.[-iJ:il % e -o-- ,3. x _.h. Q s.j C 1. g. p._-- Q= ? si-;e.' V ;. g,3.r:Q ,.r ..s.. , a .%M. -. a:. to that they wculd be adequate to replace the SPT. borings cb36 1 2 criginally requested. c s. 3 And so some of the original 18 borings c:.n be '4 deleted. When you finish with the other borings in the diesel i ).. generator building then a judgment has to be made, based on 5 e that information: the soil stratification, the blow counts 7 observed, the type of materials, where undisturbed samples 1 4 should be taken. S But to answer your original question, some of the to borings are being deleted. 11 Q Ecw many borings is it right now that are being C requested in the area of the dieIsel generator building? 12 s 2.185 13 A I think it is four borings. I think two had been 14 replaced, but.I don't went to be held a the two. Consumers 15 will be supplied a new boring location map which will tell te which borings that you have completed will take the place 1 17 of borings requested by the Corps. '18 But I think four SPT borings are still required l 1e in the diesel generator bn11 m g. After those four are com-t plated and the two - the locations of the two original ones 20 l C which had been replaced by your new information are evaluated, I 21
== tho a decision bas to be made whe=e e tae your undist==3ed s i 5 1
2, -.-,.,f .. - -,_ w,,. i ..%p;e.g.:m.'.nmkW . w. .~.c..-..h - 4'22: YQ:..-~.Q,Qg. ,; f;gy" . % v..
- .., a:..
w,: - ~ ' ' l t e 40
- )
ab37 1 sampling. Y)3' .1 g!N 2 Q My understanding of the original Corps request '3l$ with regard to borings around the diesel generator building .4,3
- e 3
hh was that there were six locations and there were going to be 4 J Q'r.yl, two borings at each locations, one to perform an SPT and one N 5 N 8 to extract an undisturbed sample. Is that understanding $d
- )
7 correct? "Q; 3 e A wo. icj Ithat was it that was ag]r,ed for in that original N.c "$ s Q 4.50 o request for borings around the diesel generator building? "JT to r ;. originally six borings that required continuous M*:l 1 11 A .m Anh ( disturbed samplings and SPT type information. Following thz ..i. 12 .. ~w ' '.b Y an evaluation would be made which would say what areas are 13 ~ '~ g g likelymorecompressiblethanothers,batareasare'likely y JW 14 more affected by a bearing capacity analysis, and then to gc te ~ 1 'Siv to and get undisturbed samples in those areas. So if you had information 2rcza the six borings $g 17
- qQ) liL that was different.in all holes then it possibly could resu.
to Y,64 h* 1s in six undisturbed sampling borings. But if you could decii dM' by the completed borings that maybe there were only two or ~.ffh )._ 20 Af G' ,y,d three types of conditions that actually still existed under b 21 the diesel generator building, then it would only be necess ((. 22 iw S T% i.~. n
g%.__ y...; 3.,.,. .-..... g r _ . a.: ;. m ~ r .4 ...t w.... a. ~.n...a -. -.... y t ; h w.m., s.. _. ...,_.,,_..m.,...,.m..,,.,..,_,,.. f.f?;$. am. .]:,. 43 i i j1{ ub38 1 to do undisturbed sampling in those areas. .~. .4 2 I'm somewhat puzzled by the interpretation by M (- s $qh,'j 3 Consumers that you do undisturbed aampling everywhere where .f'd 4 you do SPT's. That is not the normal engineering practice. 4[W yJ 5 And that's not what is indicated in our Reg. Guides en site
- Ni g.g a
Investigations. JAnd I'm puzzled why it's being interpreted y ..;M Li t 7 that you need undisturbed samples for every hole for the full J.Q ~."..t, we (NJ 8 depth of the hole. NJ 9 Q It is your understanding than that that is not wha y*vg n 13,34, 10 was requested by the Corps? mj 0 11 A That is correct. ,h ( 12 Q I have here what is page two of two in an attach-eJ -.c
- heS 13 ment to the June 30th, 1980 letter to Mr. J. W. Cook, vice 4.y u
sig E3 14 president of Consumers Power Company, over the signature of .*j ts A. Schwencer, 5-c-h-w-e-n-e-e-r, Acting Chief of Licensing jg l .Y1 18 Branch Number 3, the subject of whicih i's " Request for Addi-I[J.}
- 3. i 17 tional Information Regarding Plant Fill."
+ c1 .l 18 In Note 3 on that page two,cf two, in Table 37-1 a .m 7 / T 18 it says: '. 7.. .y \\ M. / ilj " Continuous split spoon sampling'using 8 ^.i G L' >r ? . 21 SPT is required. Ecles are to be held open using g e o., ... m ~ 22 ~ either casing or hollow stemmed auger. Additional ggg,
- a.-;
/. h:$ ~ am n%.3 / A. s w. y .4 '~3 ^ f .y'_ 5. . s....
. C. f y L'3 3. 5-. y.-- g. m,e 7 * ;, T..,. Q c. m ; 3.:. w ;b - % :- k - ,.,..~z. .#.. -..e._ %'s -..:a .r..."- 42 borings to obtain representative undisturbed samples cb39 1 c 2 for detailed laboratory testing should be located at 4 3 the completion and elevation of the r;plit spoon .) 4 sampling program. The groundwater level should be 0 5 recorded at the completion of drilling in all 7 i 8 herings once the level has stabilized." 4d 7 MR. PATON: Could he see that? 7 i ~- l 3 MR. ZAMARIN: Surely. 9 BY MR. ZAMARIN: .s 10 Q I think perhaps when you say that you don't under-a ,i .+j 11 stand how it could have been taken that undisturbed samples f '- %.:) were required for each of those, where it says here: ~ 12 ..A 13 " Additional borings to obtain represer.- i 14 tative undisturbed samples for detailed laboratory 15 testing should be located at the ecmpletion and ..a 1s elevation of the split spoon sampling program...." Tj perhaps that's the sentence that has been misunderstood.by 17 18 somebody. 2.270 A I guess there continues to be a misunders*=M hg 18 8 with this sentence. C.. 21 " Additional borings to obtain represen- - s tative undisturbed samples for detailed laboratory 22 ,7 Y .0 b d elsre/ h 8mm ~ l..:4 15\\ s TM. ~- m]
&gfl.;.4& (s.W. ' Q3h - y [. -; ~.= r' % g y. _._. _._ &__ Q w.W Q yg&.Q . kr:::3...+. ~. -. c..-. i . _,w, GpftN6 %W ~w -.... s e,. w m, & -u ,,.r.- . m,.,., _.,,, j$... ( A'on. e..: .. e -,~~% .m..,..-~...,,,e.~,_., Qp.4,r - - ;/ ~. 43 ,. c. w:.,~. ..1 a 1 eb40 1 testing should be located at the completion and .) 2 elevation of the split spoon sampling program." E4 p _m ~ *m I guess the misunderstanM ng comes from the use 3 4..1 ..m 42 4 of the word " representative." It is not normal engineering ?,.A. practice to take undisturbed samples for the full depth of j 5 ,r4. 2 e every hole. We had this same discussion in I think it was .,.n ~ w, 7 at the end of July with Consumers about when James Wanceck ',ff y a made his presentation of a million dollar costs for addi-l 'a s tional borings that this was not what was intended. 'Hj w - 21' 10 We were talking about taking representative un-
- s 1
, -t 11 disturbed samples and we talked about,at that meeting,of r ~ .. w" 12 looking at perhaps taking only the worst condition and the
- w. 4e. 4 1
13 average condition and testing that. And I thought it had be ] j'j; 14 made clear at that time that we were not sxpecting you to . -s ., :;. s ts test every sample. ...: q .'a .SJ to I'm really baff*.ed that anybody would think that . w.s
- 1
.-d we would want you to test every sample. 17 -.q l Q. Doesn't that sentence that you just read seem to 18 N 18 indicate that h t the Corps requested on June 30th, 1980 .x ,f ) was undisturbed samples for each of those borings? .:2 G l 4 :; 21 A What does " representative" mean to the people whc - g.,a)q 'ig are reading this? I guess-that's one question. To me it 22 '2TA ' $1.N f O L. E. L.i M & ~ s .,.e,.. 3 .. w) M itn; I -g(. 9f e-w = e --y er. r- -m
.. v /.;~i.a&.'5: . ~..;-- x
- a- %l2 h g 3-... _-[ G Q..y ] *.f }.)..j. y 3
'1- ^'sl%? * . j..), ,.*U'- -(\\ I 1b.Y means, you know, you have a layer a certain thickness and fra ab41 1 < S. ! . ;,fff r. 2 it's not necessary to test every sample in that layer. Yet 's '$q":F would take representative samples out of that layer and to: 0 3 4, ~ - t i 4 them. And that is the normal procedure. AM 5 Q Representati"e samples being representative of tM .ffn a what? T& h h? 7 A Of a given soil layer,stra*4dication. y. e- ..,Q rdM 8 Q okay. I may now he more confused than we were .g.e,1 9 when we started. Let's go back a bit and-- I'm not a geo-MN 4Gy_ w . N 10 technical engineer by any means. ' 7,j .w.f" You say that what was requested was six borings 11 ~,, ..d4 { six borings with continuous SPT sampling. ' 92? 12 A . ~;4 Sh'3 13 Q And that there was not a request for the extrac \\ , -it1 a D 14 tion of undisturbed samples in that June 30th request? '. ? "A ,n.. ]Q)t No, I haven't said that. What I have said is - 15 A .auv4 M,3'1 v-to I've said it I think twice already this morning -- you wou 4to.c !.'i[$ al 17 do those SPT borings and identify the conditions that exis AW, Is and use your engineering judgment to what of. the info::mati ~ ra p fil [1 to that you new have before you of where there is a cencern f 5,fg (MR 20 settlement and where there is a concern for bearing capaci qd M.p.8.fi 21 and only in those areas go and take your undisturbed sampi
- 9..tw r..
b.. 2.320 22 .If you did those six borings and got va y high g r +-' G) E.4 I 9 ; : A ~ s M e, ,r ? ~ ~- - ~. -
.2 3 :L....- -- L. .q : _... _-. %.m.. ~ ~ ' ".. u.% v b'}, ~%**~ ~~ ' 5~ '
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, e..7.w. ; :, - -a r,,,,.. : -- -. ;... ::: ::. ~.v.. a.. n n.:. g. y 4- .,-,,.m.__.,_..-,...,.....,,1 &.. lJ:.:wh ~..n- .l[:, -~ m. ;. g n u fi-l ..i.M eb42 1 blow counts in all six borings, than it wouldn't seem ressen-l ?,
- i.'i 2
able to me that you would be expected to run settlement p, \\. - i% 3 computations and bearing capacity. WI; T 4 It seems to me we should be using engineering ,*M judgment to - based on that information, where do we go and L.kh, 8 1s 8 take our undisturbed samples.
- F 7
Q Do you believe that there is layering in the fill 'A 8 beneath the diesel generator building? .M~rs. ,aM 9 A
- Yes, u
o z.1 10 Q And upon what do you base that belief? 11 A, From the borings that have already been completed
- . < v 12 MR. ZAMARIN:
Why don't we take a brief recess? ' W'r,m.'.. 3, 13 'Aecess.) 1 u 14 SE. 2AMERIN: On the record. ,M ... ~ TI!) 15 BY MR..ZAMARIN: eu ?.nq 6541 18 Q Could you describe for me what your understanding %x 17 is of precisely what was to be done in accordance with the gj w ' ' 4.')} 18 June 30th, 1980 request by the Corps as it related to boring 18 in the area of the diesel generator building, and really wha -%l MA y I'm asking you. to' do is to tell me what type of equipment 20 -3,,:e Q 21 would be taken out there, what one would do with it, what Q 5;MI[j they would pull out of the soil, if anything, and what, in 22 e W.
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d i mfor .I xm 9.6 .;L)y $kh .yg w.
i ' *x n.. = ,d'-y y g f-h.d =r
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..w;-c. M 5* " ~.* k-{[L*: {"_ &I l. -.. }, j N Y. . c.3,. 46 ab43 1 total, could be physically done. Wouldn't it be easier if I just referred you to r-'.350 2 A w. a Regulatory Guide that addressed site investigations? 3 I don't know whether it would or not because I 4 Q 5 haven't tried to read one'of those. 8 But can you tell me? If you don't have that know-ledge that's fine, but if ycu can I'd appreciate it if you l' 7 would shaply tell me just what it is that they wanted some-8 one to go ont and do, and how they were to go about doing s J. o 10 it. 1 11 A Could I have the document, please? 12 Q Yes,. you-may. y 13 (Document handed to the witness.) u
- The document we have just given to you is the 14 18 June 30th, 1980 letter and its attachments.
t
- i
-t te A That's correct. I
- 3 17 In Enclosure 1 to this document, the NRC requests-that you complete as a =4a+= = the exploration and tes" "g 18 program indicated by Table 37-1.
And on Table 37-1 it has -19 The table is entitled " Request for Additional. 20 five headings. f I. b. 21 Exploration, Sampling and Testing." l; The first column lists the four -site areas where 22 [.j 4 II .J M .*4 S) - m
?.%gm.. - - ~ ~~; - 7.. n-e- 7.w;&N;2$gm ~. egt,.,_ .... M w. ;..... ;. _ - - = _. J.f ;.t =:. e.a. . '?5 w $55EA$Qf. 'f-QQW6W . -.. e - + u -q -
- 'i...,
E=. M ~ " T.-. 4' t,,v2 m... g. ..= :.. = wc.u~. n. -. . -.v ~. u.v..- .,,e-....,... ...m .,,m,,... 31,,.,,,,, _,,, _, y.. Qw;y t.-.== ~.~,n - - f~ -~~~ ~ /4 t >? ab44 1 borings have been requested. ep:]. 2 The second eclumn attempts to give guidance on ti M;)) g. p. v 2 depth that these borings should extend to. ..mW The third column has to do with the sampling and $.9 4
- h. x is referred back to the notes of Table 37-1.
.-: :p 5 w.i?,h The fourth column has to do with the tests that '. :t~.v
- OC 6
-
- 79 you would need to run to develop the studies that are liste
' [l;l 7 r.o. in column five which are anticipated geotechnical engineeri j'$ a .:. :1 w-a ?f] 8 studies to be required, and for each of the structures cart .iM) w -77 10 studies are indicated as being needed. . :p 11 For instance, the diesel generator building says ( "The purpose of the explorations.and
- Zy 12
- I M M
'M 13 testing is to re-evaluate bearing capacity, settle- .J:v;g o 14 ment and piping distortion of the Category I conduits
- q;
2 ,3.d s QV 15 that are beneath the diesel generator building." S Mg w .a to To do this it would be necessary to go to the j$jj d^5! 17 diesel generator building area and conduct bcri:igs. The r:
- ei
- .g 6l 1s varies with the drilling outfit that's involved.
q But the purpose is to take continuous undisturb. 51 ts - <.h sampling. g . n6! L I assume you know what an SPT test is. 21 'hd. 22 Q Why don't you tell me what it is?
- bM
-dd .M Mh 8ne. 922 4;f 1 .w.
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n- - -- e:.ggpq. '..-Jm -~.-c.- . n.. ? ~<, .~~- = u c.q. 9 ;_* h - y = q. _.3 9 Q p '. -. = " ' Nw c. .,m ^! 48 7 s .y A standard sized sampler two inch in diameter is 2.2 eb45 1 A driven into the ground under a select weight hammer, 140-9 2 ,] p That resist-pound hammer,and is dropped a given distance. +. 2) 3 e ance to the penetration of the sampler is measured. The ~...7 4 %) standard penetration test is the number of blows of that M, 5 .h n hammar driving that sampler one foot. e j.] Generally the sampler is driven anywhere frca 18 7 , k,.., 8 inches to 24 inches.. But the first six inches of driving
- ~A are normally discarded because of the effect of cuttings
.A c;d 9 -Ml n 7.! 10 from previous samplings in the same hole. 9.. So th'is process of driving the spoon. sampler wit . s.sl 11 i ~ ) W. 1 -4 y 12 the hammer is continuously performed in this hole. And at .e4, the and of the hole you would have blow counts for the full-X']g 13 You would have recovered soil samples i 14 depth of the hole. _-Iyj y the spoon. samplers for identification and visual classifica 4 b.D ,.....d, w tion which would give you an idea of the soil type, of the EM, to d$1 17 difference in soil layering and stra*4 "ication. l.i.N.h., ..h-u 18 You would do this type of sampling in each hori: Ad and where located, you would record the groundwater locatic 8 +d u.Af .ifl Then on the basis of those completed six boring: 8 ~ 3.M {. you would evaluate the material types, the thicknesses of 21 J -N j the layer and the blow count data that you have recorded. 22 lE 'N ~ *
- MiR
- r. ~:.
...c..-, 22.m. L ....... - x.. 8__ %fik c ~ 'yl2?.!???.PQQ .mr.. - - &*s.gw.m0N9.,.. Ei}. . y. g....f.g3 mv.; , ~..g', _ x..,.,.,. .., ;-:,.m,..r,. - u .e\\;.. "~"*~""^~._*~,_,.<t~*- t. ...,.......e...._.._.,.m._,.,,,, A .*% = .,., w r 1 = m,... e - - ,.., c, . ~. m,3 9 49 The blow counts would be an indication of soil properties. eb46 1 It would be an indicator. It would tell you whether material 2 is either soft or loose or very dense, medium dense, and 3 you would make a judgment, based on that information, where 4 .t J 5 to take undisturbed samples. 1 1 The selection of the undisturbed samples requires .1 s a judgment on the person evaluating the boring information,, [ 7 s of recognizing what studies he has to complete, and making 1 8 a judgment, where should I take undisturbed samples to get 3 9 ]i me the samples that I need to run laboratcry tests on to n to establish the soil parameters that I need for these studies. j 11 ';d { It is not normal practice to take undisturbed 12 j d'. It is normal samples in every boring at every depth in them. 13 ..g practice to make a judgment based on the SPT result where 4 i 14 L D 15 I should be taking my undisturbed samples. N '4 to I think I have answered your question. You indicated that blow counts would be taken for l 1 17 Q 18 the whole depth of the hole-..Do you really mean that? I ,i l ; 19 mean isn't it usually every two or two and a half feet that l i 1 you actually do it, or do you actually do it for every depth ~ 20 j n C 21 throughout the hole? -1 l ..s il I don't think there is a set procedure that you 22 A 33 =} ~ GL.EJ J % eL ~ 4m x M 8 .i
2.;.
- ~....
.,.,-g.. . ;. g.; L ;* 3 3. - _j y; -g g g n.; L'i,; y t.- 1 <.- e - --WW .; >... a.z. ?* SC ab47 1 take it every two and a half or you take it continuously. 2 You must recognize what is at the site and if you have heteorgeneous material where you're trying to identify thin , 'E 3 layers of material because of their impact on drainage, then
- M 4
si 5 it is common practice to take continuous split spoon samples. ?.q'1 M e If you have a nice homogenecus material that you -q.y
- =rs d'd 7
are reasonably assured that its properties aren't changing .m..,. 'y:@ s in short depth intervals, then the nornal practice would be 'I' 4-? s to take sampling at, say, two and a half foot intervals. .Al 10 Q From what you've just said do I take it the Corps ,[ is asking for the continuous split spoon samples as opposed 11- $~3N C 12 to at some intervals, for example every foot or every two k. M 13 and a half fset?
- 1 o
3,{ 14 A That's correct. ! T ~i 15 Q And from that would you then and up, if you have nm .~.-4 aps 18 a 25-foot hole, with 25 feet of samples when you pulled them '.9 .n -i 17 out?
- wn
.3 ] 1s A If you fully recovered ea.h sample, yes. s 2.500 1e Q on the borings that have been datamined as no 4 20 longer required ad. this time - and you think perhaps it was Q3ja C 21 two with regard to the diesel generator building - the [-f[] W3 22 elimination of the need for the standard penetration tests J2$ 'MJ (~y. iv AE.t.,.i% G, ~ J .s' b \\ .3 i a d
,.,. _-...9......._... .%_ g o.:j y. %.. %-2.r-p.;... y;. mu...,. n. n %,s. 2-jp g --y'W& n_. r+s,m m-w. ,;3.w. .,p ~-..- .e.,.r.w., n=:, or q m-a u..r. z, v.* ww.q 'g
- g. y.
- .ac=u.
- g...
..,. e.-r.-m x.,.m,,,.. .-.wm. mm...~ _. .x
- f.,,.,,,
. m ,e...m._.,., ,.( y y.:.-Jc= m. n _ _, .- - m,. _. +
- n. a.
then I take it al.1.o alb hates the need.for the split specn ? eft g,gT-f-ab48 1 w y.,.. 9-. Lt.f# 2 sampling. Is that correct? N.i 2 A That is correct. ' 'a '
- You said that based upon the observation and
'N ...ti 4 Q A, MM-evaluation of the recovered split spoon samples and a deter-33f-- n j s . f* %51 mBQ mination of soil properties, evaluation of blow counts and a ?Sf,Q4 $h.5 thickness cf layers that a judgment would be made of where 3 7 r :a, '17) to take undisturbed samples, and that that would be based .g.4 s W upon what studies were necessary to complete in order to ly g s p -.. establish the soil parameters that one was looking for. to F ;.: A ,:A. ... w Te11 me more precisely on what factors on where ..y.J_ I it C* s .r i 7;.3 12 to take those samples would be based. ~.>< %
- m. %
13 Q You,would have to first recognize what the SPT Q C,.~g . '1*?L .'y u is and.that's a measure of the resistance of the spoon %~ib4 - u es 14 _ ~.> ts penetrating it. That measure of resistance is an indirect fu c ]~R+.-h .2 m, w.,) reflection of soil density,and because of previous data thz .-- a
- MN3 1s
..w.s,.; .we,have,we have some idea, because of SPT resistance,what 17 qyi,3
- - y..a:
...c ta soil properties we could expect. Q. f..:j w.. The extreme would be to take an SPT where it tot ' J..' :
- 19
, r' t. l y. : -. no effort for the' spoon sampler to penetrate the soil and t :w. s 20 p.5iL; W hi. a in that case you would know, depending c: whether it was a [ s =D,, Ng 21 ) @M.m. 3 1, v;f cohesive or cohesionless material, whether the material wa w p.;; 22 !.7.d@j 2idy&? D.I 9.. 'u s; ! ?;3?g. A M m.t =y k%r w. I'gi n '2 s.~... e
e e
-,-+- v - --a w-
___s.: ,,, g. _ ;:.gy.3p,3... _;g3 y. y ; a - xa a .g ~ ,s..,.. y.. g, _,;gy - .%5 . c.:a b 52 eb49 1 either very loose or very soft, and that pen,etration re-sistance would tell you something about the properti.es of 2 ,e 1, s.. li 3 those materials. L I And for a concern for settlement, for a concern 4 for bearing capacity, if you encountered that condition 5 where you got very little resistance, then you would know
- i a
that you should be taking undisturbed samples in those areas 7 a to establish those properties. i. When you say "to establish those properties,"
- k 9
Q to to establish what properties? 1E You would take undisturbed samples to run lahora-A C tory consolidation tests to. study - to evaluate the com-l 12 You pressibility characteristics of the soil under loading. l I 13 e 14 would take the samples, the undisturbe samples to run shear strength tests to establish the shear strength parameters of 15 j 16 the soil. j There could be other conditions that you would be 17 i ta investigating such as permeability. You would take undis-turbed samples to run permeability tests on the material u t depending on what you felt was necessary to evaluate. 20 7 For example, id in one of these 57T's you found l 21 Q i 22 a certain level, say blow counts
- ee at, say, 10 feet or e
@,.E.4l#; n,4L a ij -j e + 9 m.
.s'i .E,gg krm-Q ~%Q..]X.Q_. ~ ^ 3$$y-Q 7.._.- Tji$ny?{g,2j'*' "'y p?$ $ M E M, ..w.,.....%.r;# *?.'. '.-;; - ~ ::. ""7, .. t?W4
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- 4
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=a.u, n-- .,... _--.=-. ~ l. t %g 15 feet below the surface, what would you.do with that? l l1$3 ab50 1 r. It would depend on whether it was a sand or a clay W.~.A 2 A -=Y 0 but both of them would indicate low density and would be an . e. 3 !if W area of concern for any study or any method such as bearing 4 i :@. .' u.a capacity of settlement that you were going to evaluate. ,.y 5
- ,,,.9 s.(5 Let's assume that it was sand and you had blow
..t. e Q t.d 5:& 7 counts of three at a depth of 12-1/2 feet. What would you dc "%q 8 A I would attempt to-If it were sand with three
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9 blows per foot, if I had a concern for liquefaction I wculd ? 'mrN s use those blow counts to permit me to make an analysis that >d 10 .d would detahine the margin of safety I have against a lique- , _ A= 11 r . 4;,; \\* 12 faction type failure. 'N4 13 Q Do you have a concern for liquefaction under the p; -.Q ,u.3 diesel generator bu m84*g in light of the dewatering of this 14 .4, 3 M!1 15 plant? xw We have a concern for liquefaction. The dewateri:
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to A 1 $ra is a remedial treatment to eliminate that concern and that 17
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.g , '&7 1a is being reviewed presently. -l.?q l51 ~ ~i 1s Q But what I'm *= m ng about is with regard to +re .O 20 this three blows per foot at 12-1/2 feet in sand. You said I.Mi if there's a concern for liquefaction you would do certain -nW 21 w'<.:a Would you have a' concern for liquefaction and wcu: s 3i;,; 22 studies. ? s.& j:.W?: w p. M
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.~a*e ,1 i you do those studies, for example if these borings were to eb51 1 2 be done tomorrow and you were presented with the data of 3 three blows per foot at 12-1/2. feet? 4 A If upon reviewing the dewatering we could have ~ assurance that this area would never be saturated becausa 5 4 6 of a malfunctioning of the dewatering system, then you would l } 7 not have a concern for liquefaction. You could have a con-8 corn with settlement'under seismic loading for the same =ene h 1 e with those low blow counts, a 'T \\% to Q Okay. 11 Now you say if you could have assurance that the ] C 't2 sand would never be saturated. Do you mean saturated at a 4 .1 13 time when the plant was not shut down or could not be safely 14 shut'down, or just saturated under any circumstances? l 1 15 A Would you repeat the question, please? ] t te (Whereupon, the Reporter read from the record 17 ' as requested.) i 1 18 THE WITNESS: The concern would vary. You would is have a concern for liquefaction if you could not shut the a 20 plant.down. If there is some structure, some component that's C 21 needed to keep the plant in a shutdown case, you would have i: Q 22 a concern. A s N =r 4 1 l~ .\\ u i;. 4 -w-
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4 ..m.._... .,m.,,.,.m,_.y,.,_, g.. y. ~+ ee ru .i j.gcc. m. m._ _ - _. -- _ _ So it really depends on the entire function of that eb52 1 2 system of when you would have a concern. p 3 BY MR. ZAMARIN: 4 Q We're *= M "g now about the diesel generator i. l 5 building. 6 A I'm sorry. I keep thinking we're talking generic. 7 Q That's my fault. We're talking about the diesel 3 a generator building. So would you have such a concern for the sand never being saturated with regard to liquefaction 9 n potential at the diesel generator building? to
- j Before I wou.i.d answer that I would want t'o know 11 A
(- the function of the diesel. generator building, the time of a 12 shutdown and in keeping the plant shut down, and if it could 13 14 be demonstrated that the plant would n t need it - excuse 15 me, if it could be demonstrated that it was not a problem with liquefaction when shut down, then it would be acceptable 16 in my estimation to conclude and rely on the dewatering 17 ta system, that it is a safe remedial measura. l 19 Perhaps I'm not making myself clear. l 20 If in the operation-If when the plant is shut 21 down the diesel generator building is not needed, then I i, 22 think it would be acceptable to accept the dewatering system h i I _l
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. 2 p.y g 2. 43, 1 ?,_ H ;3,7-2- f ~r:.. l. : .c ~ ~g,},*s '." J 2.~ ' . ;, 7K... 5.,.%"Q,r ((-['^g '-3~ 7 w ..~.. . :1 M. .u a,.,. .e'- i ee with proper controls and monitoring that would show that the i . d ab53 1 water was being kept out of those loose sand areas. .y 'T .2 ^ P Do you know whether in fact the diesel generator h,0 3 Q building has any function in keeping the plant shut down? n 4. 4 4 1 c~0: It is my understanding that 2.t is needed for shut
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A -c2] =. +:- 'M 8 down, but I'm not sure beyond that. r u /s To your knowledge was the basic dewatering scheme -.Isf 7 Q 33
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'c 3.020 %,j presented to the NRC in July of 19797 8 -p I think I would have to understand what you mean 8 A O 10 by " basic." -.u ..q -'n; Do you know if anything with regard to dewatering l 11 Q 4 C was presented to the staff in or around July 19797 12 I do not know about July 1979 because I was not e,- 13 A ,g;gj e .,.w .1Xi! 14 involved with the project at that. time. ,.s.)d What is your understanding of when information w %-e/ 15 Q
- 0
. -4.r# regard to the dewatering plan was presented to the NRC by m "?21 16 , MQ 17 Consumers or Bechtel? ~ l ~ -fd... .d. It is my understanding that information has been ~ ta A i 5) gr) submitted, has been reviewed, and questions have been to , 71 e+} generated on the dewatering system and it is expected that s 20 I2;; {_ additional information will be supplied on the dewatering . W,.; sw V2 21 as l - MM" = t-22 .system. 4 s i r. 2 3.030 $1 $$aderal& Sna, ~ l.
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During a conversation yesterday with the Project 3 A Manager it's my understanding two volumes have come in and 4 j c-it' my understanding it came in last Friday. I have not k 5 b f a ser, those volumes. 7 Q' When you say it came in last Friday, yocr under-standing is it came in to whom last Friday? s P S A To the NRC. I don't know whether that means that o t became docketed or what, but it's my understanding 10 is when i 1 that's when the Project Manager recognized that it was avali-j 11 C 22 amie. 13 Q Eas any of that information been transmitted to u 14 the Corps of Engineers? j . 'I It's my understanding that the arrangement that 15 A we have with Consumers is that you would supply it directly 18 'j l 17 to the Corps. ts Q Eave you had any communication with anyone at the Corps with regard to that information and what they are 18 doing or are going to do or should do with it? 20 C 21 A I've had communication with the Crops, but no one l from the Corps has indicated to me receipt of that informatien. 22 i 4 i M 1 j 's i
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_,.e >e-u...~.-w= ,,.a - -c....,,,., 58 cb55 1 Q Eave you reviewed that information in any way? 2 A I haven't seen it. C 3 Q Do you recall ever having read a summa _'1 of the July 1979 meeting at which Consumers preaanted a comprehensive 4 discussion of all of the proposed fixes to the NRC7 5 s A A summa:.f of the July 29th meeting? I don't re-7 call that. 8 MR. PAT' N: Listen very carefully to the question'. O 9 MR. ZAMARIN: Do you want it read back? o to MR. PATCN: Yes. (Whereupon, the Reporter read from the record 11 C 12 as requested.) 13 THE WITNESS: I den.'t recall a July 19th meeting o BY Mt. ZAMARIN: 14 15 Q July 1979. 16 A I'm sorry. The date is before my involvement. 17 I recall having read summaries of meetings, and I'm not sure is what they'd be. 18 Q A while back we were *= W "g about the 35-foot I 20 m,,4.num estimated pore pressure head with regard to the sur-l l 21 charge of the diesel generator building. Do you have an l opinion as to whether that figure would be approached in a l 22 M.Et Ia; =,a ~ s e
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.~ c c.u....u. w..,.."' M m ~ ~ ~ n - a ~. F; .. w - : 1 ; i .O.w, --.... 2 ; ~, - s e. n . n.. ......y u 25= =:~~ situation other than instantaneocs application of the sur-L id.. ab56 1 charge, for example where the whole surcharge was placed l.! 2 4.a p i1 over a period of six to eight weeks? /.; 3 M..., It would depend on whether the material being l ~ T-4 A g 5 leaded was fully saturated. It would depend on the drainage M W But even path available to the material being loaded. M a D assuming the worst. conditions, the worst conditions being 7 We fully saturated and no accessible drainage path, you would Y. a Zj) -) you would net expect that maximum 35-9 probably not expect, ,y w a. .a 10 foot head to be reached. M ,In calcula n g the 35-foot head, does that assume c s.+ 11 Q ?$$ ( an application of surcharge within a relatively short period 12 c.; i.O of time, even instantaneous or, for example, within a day or 13 -,i u -1 14 a matter of one or two. days? 4 ... e You.'re using the term " surcharge"~ NJ 18 A g O. M 18 Q Cr lead. 17 A It assumes a rapid loading.
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_f.'s.s. And do you have any idea,of how that 35-foot fign ts , gj Q 1;J:1 would be A4 a4Mshed or reduced if, for example, the deter- .JA 19
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.- m 20 [j (_ as opposed to rapid loading, and assuming no readily accessi -~.y; y mup Q 21 q .n m g;g'sn drainage paths and assuming complete saturation of the scili -cy si. --w h bh
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.. g - :;d;.;q. :.Q.py-- -i ;: c 5n;% - ' h= -O'- n.<.-= ..c - ?? ' C.-.py ,,..-! 5.W ' = en In my opinion I would recognize that it would be cb57 1 A lower than the 35-foot but I haven't given any thought to what 2 p n.. 3 levels below that. But for the Midland project the rate - excuse me, 4 the head that developed under loading is being influenced 5 both by the pond raising and the loading, and the level that 6 7 it rises is not very high. And I'm trying to decipher what portion of that is caused by the pond seepage and what part 8 s is caused by the loading., o to Q In your opinion is it possible that some of the rise in pore water pressure was not recorded on the piezometers 11 C because of lag in the piezameter response? 12 I think there would be a lag initially but I think 13 A over a period of one to two weeks that that lag would have 14 15 been overcome or have been made up for. 16 Q And when you say over a period of one or two weel.3 17 that lag would have been made up for, are you then assumAng 18 that the drainage distance, the drainage paths-were such that there would not have been a more rapid dissipation of to 20 excess pore pressure'than two weeks? In some areas, in the==m*4er areas irou would 21 A 22 recognize it. I would have to understand what the drainage e 9 O --n.-- - - - - - - - - - - - - - - - - - - -
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( iu. a. .,.t. _,. :: ...--,m,,..n..,u...~._... E c1 p%y m. .w en m>~.- paths were in.I think it is the southeast portion where you 5 ab58 1 s .J. 5 2 have the more compressible materials for almost the entire C ~ 3 depth. i 1 6 4 Q So as you sit here now you're saying that you
- .j don't know what the drainage paths are likely to be in that
'[ s .1 southeast portion where you have the more compressible 0 6 ..f \\ J 7 materials, and that you den't Jcnow whether you would expect 2 8 dissipation more rapid than two weeks for example? .M 'l e A Yes. .,j w i 3.145 to Q You indicated that you had a conversation with 0 11 Darl Ecod about the two volumes that came in recently frem 12 Consumers. Is.that right? 13 A Yes. 3 u i 14 Q What was the gist of that conversation? d i:t 15 A That the two volumes addressed the review concerns ~1 expressed in the August.4th letter to Mr. Cook which en-Q 18 =.n 17 closed the C ps of Engineers' review comments ard questions. j I la Q %. s there any other discussion that you had with !l 19 Darl Hood? 1 a :, N 20 MR. PATON: As relates to Midland? a , :d r ( f.] 21 MR. ZAMARIN: I'm talking about that conve'rsation. V In l:; 22 THE WITNESS: With regard to those volumes only? q ci ' 2,5 = - H .,5 A b elwol $ne. ~ ' ^~ v 4i et
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,.,,.-v 'as :. ..:.2 .3 l ab59 MR. ZAMARIN: Yes. 1 2 THE WITNESS: He had asked me if I had received 7 -j {* s4 3 my copy and I said I had not. .d,.; ~> BY MR. ZAMARIN: aj Anything else you recall about that conversation \\ 5 Q N. 1 i.i about these volumes? ) 6 I '4 7 A Not that I recall. < n; ,.] ~1 Q Is there anything else you recall in that conver-8- .4 e sation about Mid1=nd? sj o A Several thf:igs. ~ to
- ~1 Will you start with the first. that comes to mind?
11 Q Rl [- 12 He said to recommend to you that you ferget your A '3 sine die. 4u u ..) l' ' '. J 3 Q All right.- -&r 15 What else? ,-w ~, y '7 ^ te He wished me good luck today. ' r -> A . - d;... 17 Q Anything else? 1 v;i ts l. A No. l r.. j 19 Q Did you have any conversations with anyone about 20 e'] the SALP appraisal for Midland?
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SALP7 T;. i ' ',[.* ' g Systematic appraisal of Licensee performance
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.u.n. ~,,.,-. fg g. g '- L...~. e a. =....,, -..,,.,,..,,, w.,.. n.,..,,,.,., _ 63 b5.6, _. . ~ w. s. I } eb60 1 that was recently done and presented to Consumers Power 1 ~ 2 Company? 3 A I don't recognize SALP and not recognizing it, I .1 don't know whether I had conversations on that matter or not. 4 >t 5 Q Okay.
- 1 d4 Did you have conversations with anyone since 6
3 October 16th about Consumers' performance either with regard !N 7
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to on-going activities at the site or with regard to the '5 8 .a r e soils issue? w ,j 10 MR. PATON: Other than his Counsel? ,t N 11 MR. ZAMARIN': If it was with Counsel he can tell 12 me that. I will see whether you object or not. I'm just ' ;4 13 asking for anybody now. 14 TEE WITNESS: Would you rep $at the questiona. ] 15 please? .., a 18 (Whereupon, the Reporter read from the r'ecord p 17 as requested.) ts THE WITNESS: I must have talked to a hundred 1 people about Midland and the settlement problem. j to A 20 With regard to Consumers' performance, I'm sure g 'i C I had conversations with many people about being puzzled by 1 21 .,1 ? 22 Dr. Afifi's deposition where it was felt that consumers - 1 y 'i) Q M BuW G, ~ a
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c::p:y=:4 Q. ~. g, 3 :.:..O Q -... _ n- -.c., .,. n. ;,,. ~ .g-. . :.;.. =.: y.4, .;.~.. m.r_:. .e. -:*. ~ % ' Y.-- 4;a.. 1 64 that it was necessary only to respond to direc.t questions cb61 1 from NRC rather than taking the approach of convincing us 2 that the remedial measures that you were proposing were 3 satisfactory and that safsty was assured. 4 BY MR. ZAMARIN: C3 5 s Q Anything else that you recall? 7 A Not that I recall. Did you take notes at Mr. Afifi's deposition? a Q s A Yes. o to Q Do you have those with you today? No, I do not. 11 A C 12 Q Do you have them back at your office? 13-A Yes, I do. 14 Q Would you bring those back ith you after lunch? Is it physically possible for you to bring them after lunch? 3.200 15 18 A It is physically possible. Then I request that you respond to that. 17 Q Did you tais notes at anybody else's depositions? 18 19 A I don' t think I've been there. I think I Dr. Afifi is the only one where I've been there. 20 , C I don't recall, there have been so many, and so 21 Q 2
- nany people.
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.,4 ) When did it first ecme to your knowledge that ther ab62 1 was apparently some mistmderstanding on the part of Consumers >, r'. 2 b Power Company about what was requested by the way of boring 3
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information? 4. Are we new talking about the June 30th request? [J[4 g A 1 a a Q Yes. You're going on to a dif"erent subject than what 7 A we just talked about with regard to being puzzled by a ,-.~- , :.1 e Dr. Afifi's statements? @Md? ${ s' J to Q That's right.
- . 7,pj With regard to the June 30th request for addition
$2 11 A borings, I first became aware at the meeting that we had wit 12 <a q Consumers and I can recall conversations with James Wancock .kN,N' 13 u f$d 14 on that matter. n vq 15 Q When you say " meeting" are you.*= m "g about the MdM e< y'~ 18 borings appeal meeting? ?.G, 17 A No, that was in August I think. ~.. once you received the request for additional 4
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to borings we had a meeting here, I think it was in this rocm
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,. tu...:]- with Consumers., trying to understand what was being asked ....y[3'l 20
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..n - :. 21 in that request for additional borings. 7gg .. My Following that meeting you appealed and we had t g.fyj 22 $4:n ~ u.4 e i.*$'&
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eh! ' tw. 's ' N' h *. ' *, [ . [..g'>M,h k; {. ....i: + .ns a :.,,.; [ as ~ ab63 1 appeal meeting. 2 Q Was that meeting in July do you think? 3 A I think it was at the and of July. 4 Q And to your recollection did you explain to Mr. Wancock that really what was being requested were the I E SPT's and not the continuous undisturbed samples, for example a 7 for the consolidation tests in that June 30th-- 8 A I thought I had. I also referred him to the Reg.' 9 Guide. I can remember discussions with him, and they were 10 not just between Mr. Wancock and myself. Everyone that was at the meeting was available to hear those discussions. 11 C But I can remember discussions, saying to him I 12 would look at the worst condition and the average condition 13 o 14 and.make my judgment' on what settlement I could expect, 15 based on that information. 18 I also recognized at that time that his estimate 17 of one million dollars or whatever it was to do the work was including all kinds of testing that was not intended,by the ta origbut request, and I remember discussions on that. is 20 I also remember bringing up the point about trepre-C 21 sentative" with Mr. Wancock at that meeting. 22 Q Okay. l s l I
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-.~g., _. tb. 67 .p -. y, Ct t ew_- You sa.y that you questioned the " representative," ab6d 1 and that is the interpretation of the Note 3 in Table 37-1 2 in the June 30th,1980 letter, meani,g that representative ~ 3 j 5 samples were ones that could be identified by the corps ? 4
- *ough you at some date after the SPT's.
Is that right? 5 My recollection of mv discussion with being s A No. " representative" was it was not intended to take continuous i 7 's undisturbed sampling, and it was not intended to require test-e ing of every undisturbed sample. w It was the intention of testing only representative 10 11 undisturbed samples. fC And would the testing of the samples be done of 12. Q 3 those split spoon. samples that were extracted during SPT's? i 13 i o No.' You may do testing and the testing would 14 A r 15 ba classificationf moisture content, some of the more basic f a 3 18 tests. But the engineering studiais to be conducted would e require the disturbed s unpling and tests run on those materials 17 i i ts Q So the sense then in Table 37-1 where it says: to aAdditional borings to obtain represen-20 .tative undisturbed samples for detailed laboratory b testing should be located at the completion and \\ 21 + 22 elevation of the split spoon sampling p.v am...." l A s M -y l I s L
?' p3,=.=f-;.~ ,.;;in--% .,....- m. ~ l:..;i :L-tq: p: - ~~-9-74...- z.;9~Q f' ~ m% c _. a,; ,_..,m... r/. f. in your understanding is not a direction to take those samp --;i,' 1 ab65 ua and locate them at those particular points? ,GJ 2 r.p3 .3 n.:s) At every point?- -rW+, ih 3 A vell, all.I s'ee here is where it says the "borir .mMti 4 Q
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....should be located." 5 ~ '."g .n.1 ; These should be located there. 8 NS ~ p& I think I have indicated this morning that you 7 A ' 3(~ i would look at all the infor: nation you get from your SPT's m N. 8 "EQ'} ^5A and on the basis of that information choose where to tak 8 Cg;, I don't think that's inconsiste P-o your undisturbed samples. 10 j l my .d 11 with that paragraph. l 4 c Q okay. 12
- .1
-. _ ~g So what "should be located" is indicating at se ,m, 13 l3 u later time will "be located" by the NRC or the Corps for ; t '. g 14 ':fy n;Q No, it was intended that you, Consumers, would ~@ 15 A -~i.M M.. evaluate your infor: nation and choose the locations to tak . ; ~., ..-. f ,s s
- -% g Because'of'the continuing controver 59ri.p+I W
17 undisturbed samples.. ~kN on that, perhaps the best solution would be after the bor 18 l y..,3% were taken, to get together and make a judgment and reach M3 ' )' l' agreement where the undisturbed samples would be taken. . m s.
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eypcN ?. ..nA C l m$~ way we could eliminate that problem. 21
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r. .~..~ w:, n.- m t' / cb66 1: so what th*.3,jia saying then is to take the SPT's i 2,, and then Consumers 'should decida-then where representative e \\~ l ~3 undisturbed samples should be.taken and they should do borings p' .) j 4-to takeithese? ' ~ i. L_ / . / 4 j
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A' That're' correct 4
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c,. ( [ ^ .:e .Q1 ^And'us' it aljo^ intended,that the agreement of the - *,..e a ...?, ~ r J iy 'N7 N.IC 2, cr the Cor.ps would'ha,ve tc. be sought with regard to e . ~ / whers those undinurbed samples were to be taken? "~ i s 9, ' ], ~ q, :' ' ' It ms not agiaed or assumed; I think you have 3 L -9 A .j 4'. the option.'of evaluating.the? info;rmation, on choosing the i l ~. 1G ',/ ) . location and, taking.thos$$ samples. If it becomes a problem
- 11
{ y-r t2 later on'then it'd'a probles/' And that's why I'm suggesting i ,i -. ;., 13, /maybe we should botlih looking at the same information before / /s o =
- I 1 '. you do it., ' ', '.
I ,,e ~ J s 15-Q'. Ey that Irtr4ke it that what you're saying is that qq q .a if Consears should go ahedd "a:od decide on - to take these ~ '18 ' ~ r =,. 17 bcciogs and. decide on icoatiensrand at some later date, the f y ,~ ,a <,.a 1 c '.!8, staff.disagrecs with that then Consumers has done it scmewhat u ,l g 1, r. d (.' l .Jo At.chelf risk beccuse you'11' sa.y "You've got to take them v# _ ~ f '*$i _ /,, = .p ^ i ,,e at. o, th$r: pos'itic.a,s! d 4.'- C,. f ;20 '~ ~ i ( N Y, f f. Is that what you're saying? - / ..) I . 'A ' I.thinkfunfortunately,that'sinherentin a ,/ %y. l' a
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n.xn ~.w== u.D-t E,71:: "y=- _y-_,j.. f:; **, Q s m m% < o. 3 <,.w. Tn I cb67 1 everything. It's inherent in every project.. 2 Q So then my statement was correct? Basically C.1.310 3 that's what you've said? 4 A That's correct. MR. PATON: The last question was: Was my state-3 a ment correct? Could I ask that Mr. Zamarin's statement be 7 read? (whereupon, the Reporter read from the record s e as requested.) w to BY MR. ZAMARIN: We were talking about what you would do if in this 11 Q C split spoon sampling and in the S?T's you found an area where 12 there were three blows per foot at a depth of 12-1/2 feet, 13 14 and we discussed somewhat the concern for liquefaction. 18 What other tests or what else would you do when presented with data taat showed three blows per foot at a is depth of 12-1/2 feet in onn of the borings around the diesel 17 18 generator bn W hg? 1s A For sand material? t 20 Q For sand material. -L We have the problem in omdisturbed sampling of 21 A cohesionless material such as sands of recovering a good 22 N -j _.s i_ L
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-. ~.. _ ~ ~ [ ;3:=: &.. n ~ ~ ~ - ob68 1 undisturbed sample. T* tree blows per foot would indicate a 2 loose sand, and so there would be a question of whether we {- 3 could in fact recover an undisturbed sample. If it were a 12-1/2 foot depth it would appear to 4 me to be accessible to a test excavation, a test pit excava-a tion to where, rather than trying to take an undistur ebd s sample.in a loose sand,you may elect to go down with a test 7 pit excavation.and establish the in-place density of the a s sand by running tests in the test pit, and you could estab-w. lish its in-place density, and then recover enough material 10 11 in that zone through yotir excavation to run the necessary C laboratory tests at the density that you have established in 12 13 the field. j l u 14 Q And what are the necessary laboratory tests to i 15 which you refer? t [ to A It varies with the different structures. If we're talking about the diesel generator building, we have talked 17 1s about settlement, bearing capacity and piping distortion. What kind of a test would you do with rega:id to 19 Q 20 piping distortion? C 21 A It's mainly intended from the standpoint of settle-differential settlement and the effects that have been 22
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.z. = ;..., -':~.;; d.%.45 a %My% .v n~; x.. N,-EU Q ( :9.. A.5.%R. * "; D JTJf - - _r. :r w .n.= Ys'Y-- - :,.6.. v ' u 72 caused en the pipe *ncause of those differenti.a1 settlements. cbG9 1 You could also take material for rmmbg shear 2 C-3 strength tests. I think in the analysis of piping stresses a parameter that you would want would be subgrade modulus. 4 5 Q Would test pits with hand-carved samples be ade-quate in your opinion for, say, the top 10 or 15 feet of the e 7 soil around the diesel generator building? 8 A I think-If we're saying for the top 10 feet excavate test pits and take out block samples and the block 9 to samples uld be.more of a cohesive type material and run in-place density tests which I have just described in the 11 C-cohesionless. material, then they would be satisfactory. 12 3.400 .t3 That is assuming that the test pits or the test excavationscoveredthearealextentthattheboringswould 14 15 cover. 1s Q In Table 37-1 that accor= M ed the June 30th 17 request for borings it has an indication under Column 4 that you described before which identifies the type of lab ts I to testing. And in the fifth eclumn'it indicates the antici-20 pated geotechnical engineering studies to be required. ,L 21 For sands, with regard to the diesel generater 22 bM W-g location, it indicates " drained, Nect shear of \\ M E.L I% eL ~ e 8 0. .v. w w e-- .w.m , + - ye w-re-
N j;3 h I h=4.-{q % es y y y D5.6.v.,s. v,,.... 35 bh kb5 ...t.tu m m y,_ ty,, km.. w_,...- :-l-uc==.
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~ . 4 .1..u.r. -, m.., .,.c.~.~ c.- ~._. c e m-.. .-w.._-.,., y3u?i= x ~.n,&- 7., ~ .~ w both loose and dense specinens, and also relative density." ob70 1 And under the eclumn of " Anticipated geotechnical 2 p L engineering studies to be required" I don't see anything 4 listed. Can you tell me exactly what would be done then 5 with the results of those lab tests for the sands? s 7 A' Could I see the table, pisase? 8 Q Surely. (Eanding document to the witness.) 9 n The column that is entitled " Anticipated geo-to A technical engineering studies to be required" corresponds to 11 (.. 12 each of the four structures involved.. What you have just read for sands is covered by the same note for the diesel i 13 O generator building which includes bearing capacity, settle-I 14 i 15 ment, and piping distortion. 16 I'm interpreting your previous ccmment to mean that there doesn't appear to be anything required for the 17 18 sands. I am saying the same information that you would develop for th's cohesive soils and for the sands would be used l 18 20 in these same type studies. D What would you do if you had in the SPT's data 21 Q that indicated three bicws per foot at a depth of 12-1/2 feet 22 !A Ed JMG, ~ j s 9 8
...l. ~ ,.,.....z-.. I^$.y#4h k'; m. /* h **. E*~ ~ K.. -[.,.* I r > n: - ..s..- v-mes c.,,u ,_..~.s e s: 74_ e. i eb71 1 in clay? u It would be an indication of a soft clay and there 2 A ..ss y 22 3 would be a concern for settlement. There would be a concern for its shearing strength which would be used in a bearing j 4 5 s'i. 5 capacity type analysis. (RJ$ 8 Q. What would you do then? p3 - r.6 I would establish the settlement and shearing 7 ~A ' $11 Ofd) 0 strength properties of the clay that indicated the three blow 8 .%j -i 9 and use those in the analysis that we talked about. Ml 10 Q Is it possible to have the clay with an SPT that $j
- ?
showed three blows per foot at 12-1/2 feet that would still g-t 11 yC hav.e adequate shearing strength properties? 12 un. 13 A It's possible. o i$ 14 It should be recognized that adequate bearing ts capacity has several factors. The significant one is the gj W-9 1e amount af loading, gg nu .wm Q And what are the other factors? 17 g
- .m The depth of the footing, the presence of the 18
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4, p^ * $ '~~~ ghff-Qf-ln. "'G5'N[$7? --(( ~ ;.- p. ' ~ e.;.- : - . ~ - u.,-.n . w..., .y .m. ... 4., 7 -.~a: y:;,- ~ 8.."- .* L..c.::; ; e r.- -..m e...,.. u %.w-. %,. .,2,., ~, };.r.n _. 9 :;. ~ %, a4 ,g h ,,;yt.:=.w x - - - ob72 1 now if it is within the influence of the sand *- excuse me, p 2 of the soil layer which is being stressed because of the 3 loading. If we're talking about that zone, than the higher 4 the water table would be in that zone, the less resistance 5 to W ing capacity type failure there would be. e Q Why is that? 7 A Why? Because excluding whatever factor the water a would have on the shearing strength, excluding that considera-a tion, the fact that the water is there would make the soil 10 buoiant and reduce the frictional resistance. 11 MR.. ZAMARIN: Could you read back the answer, ~ C' 12 please? 13 (Whereupon, the Reporter read from the record u 14 as requested.) 15 BY MR. ZAMARIN: 1e Q. What effect does the resistance of the water have 17 actually a shearing strength 7 1s A The property of a soil to resist shearing ecmes 18 from friction and cohesien. The presence of the water table 8 reduces the effective weight, the effective stress which is 21 what permits the frictional resistance to be' developed. 22 In other words if you would go to shear a sample M adeel h !, S ~ x e Os e 9 _a
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. s,..,. m ' ~ 76 eb73 1 that was dry, you would have a certain amount of frictional 2 resistance. If you were to saturate that sample, that satura-2 tion would reduce the effective weight of the sample and i '1 4 therefore reduce the frictional resistance. j 5 Q Is it then simply the buoyancy effect, the re-8 duction in effective weight that affects th; shearing strengthi 3 7 A I'm trying to understand the question. Is that e a now ex=1uding,now,that water, the presence of water in that 8 sample does not affect shear strength? 10 Q What I'm saying is,does the presence of water'in- ] 1 11 a sample affect shearing strength only because of the C 12 mechanism you've just described, and that is because of the 14 M 12 buoyancy effect? u ^ l l' A No, it is not'the only-way. ts Q In what other way does the presence of water affect 4 la shearing strength? 17 A There are several ways actually such as in a 18 ccmpacted fill, the water that is there, the amount of 1s moisture which is there under ecmpaction permits the soil ~O particles to go into a certain arrangement. Thau arrangement C 21 could be differant if the moisture-eontent were didferent. j 1 22 j In other words I would not expect a sa=ple to have l j $dh./M dI ~ 3 j
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p '{?'m :.m, a - t ab74 1 the same shear strength at optimum moisture Versus dry of l 2 optimum moisture. And there's a case where it's the moisture 2 content difference which is reflecting the changing shear 4 strength. 5 Q And the me4 =4 - for that is because of the change e in the orientation of the soil particles caused by the water? 7 A Yes. s Q Are you talking now about a particular type of s soil, say clay as opposed to sand or sand as opposed to clay? w to A The discussion about at the optimum moisture and 11 dry of optimum would be more a concern with a clay or a silt-i C 12 type material, but it is recognized that moisture at the time 13 of compaction of a sand does affect the soil arrangement u 14 that ultimately results and therefore it also likewise 15 affects a sand. It affects it in a way that the ensuing te density is obtained. 17 Q Would you expect the presence of sand in a' soil, ta for example around the diesel generator building, to increase is drainage rates? 20 A You said the presence of sand'in a soil. If the C 21 sand particles are being mixed with a' cohesive material there 22 is a limit to where the increased amount of sand will probably 4 l O
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N-j' N% c.,,.a ,,,,,... w " # - ' 78 ) cb75 1 have not a factor - or would not be a factor.. What I'm 2 saying is if there's enough cohesive material, enough fine 3 material to fully coat and maka a matrix around the sand, 4 then essentially it would continue to behave as a cohesive 5 material. a There is a limit and the limit would be controlled 7 by the amount of fines and the amount of sand. e Q Would you expect the presence of pockets of sand 9 to increase drainage rates? w to A Pockets of sand? 11 Q Yes. C 12 A They cMd, and they could not. If a pocket of 13 sand were already filled with water and had no free exit to a i 14 another sand, and that is what would be. inferred by a i 15 " pocket," then it might not have any effect. 18 Q In your opinion could the presence of sand de-17 crease drainage rates over that which you would have absent-1s the presence of sand? to A The only condition I could think of where it would 20 decrease it is where the lenses or pockets of sand are less ( 21 p= -==ble than the sand that it's in. 3.630 22 MR.
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...,-,- ~ .-s m m m. .o. m. -, F ~, .~. ..-. +., ~ .m.-:e. 7y _ p in:nv:.=~- - uy eb76 1 (Whereupon, the Reporter read from the record 2 as requested.) l 3 THE WITNESS: I believe your question was a broad 4 i J 4 question. And you can have a sand deposit with different s sands of permeability. And in responding to your indication a of sand lenses, I'm saying in some cases it could have an 7 effect. 5 MR. ZAMARIN: Okay. 9 BY MR. ZAMARIN: n to Q What you're talking about then is sand within sand. 11 A Yes. 12 Q And I'm talking about sand within other type,s of 13 soil, for example clays. And would you expect the presence u 14 of sanci in any way, that type of a situation, to decrease i 15 drainage rates? 1s A I would expect it to decrease drainage rates. 17 MR.. ZAMARIN.: Could you read the question back, la and the answer? 19 (Whereupon, the Reporter read from the record i 20 as requested.) C 21 THE WITNESS: I should clarify my answer. The question was'" decrease the drainage ra'te." Actually it would 22 g I.
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.QpyggF; lJA: .-w - . n. ~-m.. :43iss'2hQ~C=p _--Q%;Q. ;.. {:393QJ , ' O.. . m:5.....,.,70., ,.y. z.,,..s > f 80 ab77 1 accelera.te the drainage rate. 2 BY MR. ZAMARIN: .{ ) 3 Q Would you expect areas with air voids to have high 4 permeability? 5 A Would vou repeat the question, please? s Q Yes. d 7 Would you expect areas with air voids to have high a permeability? 8 A Is the question versus soil with no air voids? n i 10 Q Yes. l 11 A Yes, I would. lC 12 Q All other things being equal would a dense clay 13 or a loose clay have higher permeability? i u 14 A A loose clay would have higher pe===hility. 34 Q If a piezameter, for example in the area of the 15 te diesel generator building in the surcharge program were 17 located in an a.rea of clay with large air voids, what, if ta any, factors in your opinion could prevent the piezameter from responding to the full theoretical preload level once 8 the load had been applied? C 21 There are several considerations. Could,I have a A 22 repeat of the question, please? e 8 O 9 \\
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~ ~ "~'W#dM$%h. , 4, T. 7T. dY. h. hy 4 M +.Tq:.. w f --q n w m.. w --t m a m. u. w. yg_. . U UJ z. 2:..~..r ;.?, GQ -= ,.~, n ~ - u.x u-.. w r . - s. ~~ - - -- ~ ~. E a, }p ygic.:o u w - cb78 1 MR. ZAMARIN: Surely. l 2 Would you read it back, please? 3 (Whereupon, the Reporter read from the record 4 as requested.) 8 THE WITNESS: Could I have it read back from the 8 portion of the question that has what factors would prevent 7 the piezometer from responding? 8 (Whereupon, the Reporter read from the record s as requested.) 10 THE WITNESS: A clay with large air voids upon 11 loading would be forcing that air into solution and therefera -C ~ 12 you would be decreasing the voids without significantly rais-13 ing the piezameter level. That would be one factor. u 14 BY MR. ZAMARIN: 18 Q Would you nonetheless be consolidating the soil is under those circums*m cas? 17 A You would. But you would not be expecting the. Is behavior of the S-curve with settlement versus time because 13 that r..urve is developed on a fully saturated sample. 20 Q Would you expect something that would approximate C l 21 the S-curve if that condition existed? 22 A It seems to me we're
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5::pg.c;i*l:b-'% ~Oc' . n.. ci m :. R S 5 : h 5 2 3 y-. f Q T '.},} g ((~ 2 .xmc .=,.,,& ,,.,.,..r~ 82 and if that partially saturated sample that has voids in it, eb79 1 2 were the case I would expect the rate of consolidation to be k. less than what it would be if it were fully saturated. 3 4 Q Going back to the question, keeping in mind what we're really looking at now is the response of a piezameter I if it were located in an area of clay having large air voids, a you.'ve given us the one factor so far that would prevent it 7 from demonst= sting the ftli theoretical preldad level. 8 l s Are there other,s of which you're awara? Ic A I can't think of anything more with regard to the 11 piezometer response. v60 12 I can think of,if this condition exists, how could 13 it affect the settlement markers. u 1 14 Q Tell me about that. 1s A Not being fully saturated, the fact that there are is air voids there may be albhating the fact that the soil 17 would behave. differently if it were saturated and therefore, i i ta if we introduce saturation we may observe a settlement pattern ts which is different from what we're observing when it has the I ~ 8 air voids. C 21 Q Different in what way? 22 A Different in that it may consolidata at a greater t na 6 e ..._-x- .r_,
m. --.m f :......,. %GM fy. .hl:efl5 n. w:w.. m m -, a. . g _s -.. u... 3 ..,s . ~,o... m....,..._... E o' R-ll2h M.. n - ~ " - - w cb80 1 rate when saturated. 2 That's part of our concern under the diessi genera-3 tor building, that there were =enes which, by your explora-4 tions, were shown to be soft, that may not have been fully 5 saturated under the development of the pond, and that's one a of the reasons for our request for borings. 7 Q What evidence do you have that there were =cnes 8 such as you described that were not fully saturated under 9 influence of the pond? o to A We know the bottom of wall footings at elevation 11 628 - I think the average' elevation that the pia:cmeters -C 12 raised to in the diesel generatot building during surcharging 13 was 625, I think. We're trying to understand whether that 14 625 is because of the excess pore pres ures under the loading 15 but in fact the level of saturation is below 625 and we're 16 thinking, based on what we observed in the pia:cmeter be-17 havior, that the level of saturation that.was actually ob-18 tained in the diesel generator building may have only gotten 19 to elevation 621 or 622. 20 Q And upon what do you base the statement that it C 21 may have only gotten to 621 or 6227 22 A The behavior of the pai:cmeters before leading and M E.L.I W 8, ~
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.w.m <..,. ; 7,,.., c - e.. r. ,,.;....s_,., ~ . g.: i.=.=. m. _,.. -,,g e. ab81 1 after loading. Describethebehaviorbeforeanda5terloadingthat 2 Q would lead you to believe that it may have only gotten to 621 3 4 or 622. You're asking me to describe it? 5 A 8 Q Yes. You said that the behavior of the piezemeters 7 before and after loading led you to believe that the water a level may have only gotten to 621 or 622, and I'm asking what s n behavior.was observed that leads you to believe that. 10 There were a series of pelzemeters which, just at 11 A C the time of loading, were indicating a level around 621 or 12 i 622 and then under loading there was an increase and then a 13 o And then under removal of the leading there was the 14 dropoff. behavior where it dropped and raised back to the level that had i-15 existed before removal and then went down to some level, and 18 that level appears to be 'around 622, which we're ^4"k4ng 17 is the level of steady seepage as being developed off the 18 1 1s cooling pond. i You're saying it went down to a level of 622 while 20 Q. i C 21 the pond was still being held at 6277 22 A That's correct. And then it continued *a rise Adadael& S.e. ~ e 93 d ~ ,4-. a w- -.,.~~----n., .e
2.,.>.:_ ~ ; m 7,:.z.L. _.&,y g Z..:t - g...-.,~ 7;C.' -. vg K ^ ;.,C.u. ^ Q~ a c- ^p Mp;m. % i: y y - y, .x +- .N Y~ .,.,7, .w.<- oc eb82 1 following surcharge removal which to us is indicating that 2 steady seepage is still developing off the pond. 3 Q You say it went down to a level of 622. For how 4 long a period did it go to that level? 5 A Weeks. a Q And in your opinion had it stabilized at that 7 level? a A It wasn't stabilizing. It was still being in-fluenced by the development of pond seepage and it continued e to gradually rise after surcharge ridioval. to 11 Q Would you agree then that, based upon all the ob-C- 12 servations, that the soils, at least below 622, were sauurated 13 during preload? u 14 A I could not agree, based on the information I've 15 seen, that all the soils below 622. te Q Do you have any evidence that any of those soils 17 were not saturated? A I do not have evidence that they were not saturated 18 18 I would like to see evicence that they are saturated. Q The piezameter readings and the behavior of the 20 C 21 piezameters were removed doesn't lead you to conclude that 22 the soils below 622 were saturated? Is that rigat? M E.L tM 8 ~ 1 1 O-4 e u--i su u-i
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,,s, ' .. :.;.y...,. ; m.,_..,,,.....,,_ ~_,...u. p- ,._,-.c.,.. ~ ~ = ~ = %'t. ec 4.w.2 u c m,~_ t 4' i~$ eb83 1 A It indicates it. But we have the problem with the y iD leading, the surcharge loading and that loading causing the 8 2 7..q d9 3 pore pressures to develop. And so maybe it's down to 620 seg5 .. e or maybe it's down to 618, I don't really know. Th 4 j But I de know taktug undisturbed samples in that .w. .,.f 8
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+..,A, zone and saturating them in the laboratory would help us to s 42 M-1 answer whether the effect of saturation on settlement could 7 lyg ..n! 8 be answered. %m . t.uj What reading would you expect in a piezcmeter tha n 8 Q ,JM o r.y :., has been placed in a soil that is not saturated? 10 1 E5' 11 A Would you repeat the question, please? 2 C 12 MR ZAMARIN: Would you read it back, please? (Whereupon, the Reporter read from the record 4 876#, b 13 p$q o 15p 14 as requested.) ...gd.a 4 18 THE WITNESS: I would not expect a piezemeter to 'c j.] indicate a level that is above.the l'avel of saturation. .a e, te gg m +.t so.mro*,L.' BY MR. ZAMARIN: J..? g1 For example, if the soil were dry then there ~. .Li ts Q
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,.f wouldn't be any reading on the piezemeter? Taking that to 18 4 20 extreme, is that correct? .3
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w C 21 3 7,,, ?.. g You indicated before that vou weren't certain as wr: 22 " 9'j Q n.s : f5 M. Q.4 bdel ru/ d ' ' :, [ne, h:\\l ~ 'nw V~g.:1 .u 's x a a.A t we f?w. spy e O ';* ' ..p . ~.,.. _,.
,_,-e R;.:y ;.6x.Na ^ 4i 7 -n * . ~.. '. : K k':i2.I.*bi~X^:::.~. Q.-?=Q.' -{.,f;~j.Qf -%% e. a.; 87 But based upon the data what level of saturation there was. eb84 1 that's available to you, the piezemeter data both before, 2 k durinet and after the preload, is there an indication or a 2 conclusion based upon geotechnical expertise that one could 4 make with respect to it having been saturated at least to s e elevation 6227 7 A The problem is coming-- You know, if we had not loaded the deposit then it could be conclusively drawn that a a piezameter that is reflecting it at 622 is essentially 9 w to saturated. The fact that we've now loaded it causes the pore 11 pressures to rise, and.what you would be getting in a piezo-e 12 meter that is at a depth deeper than 622 may be reflecting e 13 o the pore pressures under that loading, and it dossn't mean 14 the level of saturation has reached 622. I'm saying there are 15 excess pore pressures at the level that you're measuring at. le I would ask you to look at all the data', including 17 Q the behavior of the piezameters after surcharge removal, and to ask you whether based upon your expertise as a geotechnical 18 engineer ycu'can conclude from that that the soil, at least 20 t C_ to elevation 622, had been saturated. 21 To answer that, you have said to look at all the 22 A % E.L.I M eL ^ \\ e e i k. e*- - * * * <.* e e. o' * ' " * *
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c: ~ a N. .p'.s _,., g4 3.s.. q.- 5ppo , f.g..,---. u== -. ."'EiG% ,..+gffSD-Qj $_ p L.., .. = &2 M]/325:YMM47 s. t 's _ yy - ~ -..-c+; 7. ten. :,.2 ...:.w -,1, ,,,~ = = :a =~ ~._. ~ s .- -.__.e. m m-_.~m m,...,,,. 88 ~. @Xp= mw - - -,.4 g. I would want to go back and look at all of the data. eb85 1 data. It is my understand.ing that there is enough of the data that 2 3 would tend to indicate it, that it is around elevation 621, 622 at time of surcharge removal. 4 Will you explain.the process with respect to the 5 Q consolidation tests that the staff wants done with regard to a how those tests will be done, and how you go about making 7 settlement predictions based on those results? a I I'm not sure to what detail I have to go into. 9 A hope you're not asking me to give you the ASTM procedure for 10 11 consolidation testing. No, I want you to generally describe the process 12 Q and how then the data obtained from that process would be used 12 u l' to make settlement predictions. You would run your laboratory consolidation tests 15 A using a standard such as the ASTM s*=nd=-d for consolidation 18 testing, and in the course of that test you would develop a 17 P ot of void ratio versus log pressure, and that would give 13 i l you a curve under that loading and that leading would have been 19 carried beyond the limits that we would anticipate at Midland, '20 C and on the hasis o!.that curve try and establish the precon-21 solidation pressure that was imposed under the surcharge 22 e s S. O
" ; w.. t.,.. t
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.~..-..m. ~ ~ e:c ~r:. =.,;a a...; - U 7 r J .h eh86 1 leading. .r??g And. if. we now, with that preconsolidation presst 2 j*M g g C. can verify that it exceeds the final loading that we have 3 !Es3*rgi ' M.is. computed under the structure, then we could safely concludi 4 J G ,, r +,.C that the amount of settlement should be =4"4==1. ..x, .m 5 j P' You left out a little step that I need to under j d' (u.g? a Q p.- stand that and that is when you do these consolidation tes 7 in the lab, you get a certain type of data, and then how d a fly % 4W What is that data and how do you get that into 8 you get-- WR.J BA$ij ~ T-4.210 10 void versus log P plot? .. +49@, During the course of the test you would maka 11 A T@ l A.. :. f (- measurements that would permit you.to compute.the change f 12 y, The consolidation is causing the void ratio - ,..m 13 void ratio. 'wn u '6.di And you would make that computation at the pre: 1' decrease. gg And with that vo you applied in your consc1idation test. ,; w 18
- s.(g dWM ratio and with that pressure you would plot that on E var 16
, JJ log P curve, and that would give you a curve of that beha
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- W S e's ts Q
All right. ..~%!W . Mkd Then how would you go about computing a change ts agd... .a h' 8 void ratios? There are equations that are given in the in- &t%:; 21 A '.q,e;j But it is a measure 22 structions for a consolidation test. O.l f;l lHr ) $ ~- m s/ th s, s i u -t.'n:mo../ +-*-e-- .=r., ,3 s
~~ y ., 1 ... _.m. l..?-".;c::::: #... ,..g.a--- _ M.. M .m M-g;.,-. 4 -c.e g f:.; r u m--- ;y p .-,.. w_. : _ l r s. aan._t.,,:. 2.,?. w3+:..w, -. ...,,.u-- tw.yz,g. g. ~ c -.,y3 3.. wu=:.e. -~,a,n w.m z,....m n.,..,...,tv.t :.=m s.v.m m .-. m., e.,.,,,. _.....,,,,,..,.,., w r f.; s..,S=~ax ~ ~ . 1 :.. ..,. ~.. - g eb87 1 the voluma decrease during the test. And on this measure of volume increase versus log 2 Q
- I g-(
3 of time-Strike that. Is basically what you're doing then before you get 4 a to the E log P plot, taking a changing - did you *ay ~ l! " changing volume" versus log of time, that this i.* ene method e of doing that calculation, plotting the change of volume 7 i versus the log of time and then taking certain points of off N 8 that and put*4g those in the E log P plot? e 10 A Yes. And is that analogous then, at least that step, -tic i tt Q ~ b-plotting settlement versus log of time? 12 y I 13 A It is similar, but there are differences. And o depending on your experience, both types of plots are used, 14 E versus log P or percent consolidation versus log P. 18 And isn't also one of the major differences that ^; 1s Q what you're doing in a consolidation test where.you're taking 17 ts this change of volume versus log-time and then translating
- a l
that or taking those points to create the E log P chart that 19 s; you are in effect doing a se'ttlement versus log time.calcula-8 C 21 ) tion on a one-inch sample? ,,j A Not all samples are one inch. 22 1 A E w h en m. .s N x 3 ,,1 5 4 -.--y.-~ ---y. __.-e,, --.y - + - - - - -
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s.. .. p ~.w..~ - se : - e. x .a - -.s.. +.-~,c ,J y - - c.,.,;, .,, s ~ec ab88 1 Q All right. What's the range of samples which you expect to be 2 p 4 s ) 3 using for these tests? i I i I've seen them as thick as one and a half inches. 1 4 A s Q Okay. So we'll say on a one or a one and a half inch i. e 7 sample. Then basically what you're doing is you're doing a i settlement versus log time calculation on a one or a.one and a s a half inch sample, aren't you? n to A Yes. 11 MB.. ZAMA.RIN: We'11 be in recess until,one o' clock. 12. (Whereupon, at 12:00 noon, the taking of the I deposition was recessed to'recenvene at 1:00 p.m. 13 o 14 the same day.) 15 i to 17 18 19 20 C 2, l A.E.L t M eL ~ '\\ D, 8 9we .+ y y -w ,g w en.-
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- s AFTERNOON SESSION
. g g) ~ abi C4 1 'cpy L4.265 (1:47 p.m.) - Q.0 2
- 1+6-M
.v.- i 3 Whereupon,
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- 2-JOSEPH D. KANE 74,;hl.
4 9 NT resumed the stand and, having been previously duly swer a J~:.hef-D Tf. ' was = = hed and testified further as follows:
- j..[h 4 E-6
- v.m MR. ZAMARIN
Mr. Kane, over the noon hour y
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.r 0%F 7 d cr-have returned to your office and have brought back with afN.7 . %'yj e
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. mi.$ certain documents which I requested this morning, those 4.9:6 9 ?,,"D..; had ccme into your control subsequent to October 16th, r.. 6 to , m, last session of your deposition, and which were within 11
- . ~@
purview of the request to produce and the taking of del 12 W.y And tiens as modified by Counsel. 13
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u A. gain keeping in mind that you indicated th. - q 14 w.... a.'g .,, ; i did not have time to do an exhaustive search, you have w 15 ,.. g.. .iiWE! te duced some documents. M .s
- ,a A'K48g 17 CROSS-EXAMINATION (Continued)
". n .v. _JO.y 18 BY MR. ZAMARIN: ,,;;h G. Now let me ask you though, did you have ti: 1e Q ,y - n..f.. a ecmprehensive search of ycur files in producing thes 20 ' ?r':f+/9 ~ .4.*
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21 documents? . ','iM..g,f ,.a Not a d'etailed one, but I did check all the . r-L.y 22 A sc.y e.., a :.4efi$ lMyh,'g b e a, L..g q . s;.y n.. ~ >w.,..y \\ r $ss$'4Mi .i'3,. fa1 3 ~.v. ,. y e
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,;.3 _ _ ,. n.s.f:' .,. y, c. 93 W ab 1 Q okay. ~ 2 M3L. ZAMARIN: In any event we have been provided car-C tain documents which I will now identify for the record. t 3 One is a document on United States Nuclear Regula-4 tory c = 4=sion letterhead. In the upper right-hand corner R And it's it bears the notation "J. Kane, received 11/3/80." i 6 a letter from Vollmer to Cook with regard to De decision 7 regarding additional soil borings and tests.ng. 8 Attached to the front of that is a portion of a 9 writing b ist page which contains some handwritten notations. to And attached to that is a letter dated October 3, 11 12 1980, from the Corps of Engineers to Mr. Lear. And attached to that is the transmittal of that I 13 letterandthatisthecommentsonsoi$boringinformation I 14 l 15 received from Bechtel. to You'have also provided a telecopy of a draft letter to George Lear from the Corps, consisting of two type-17 written pages and two attachments, one being a. site map and te the other-figure 1 being a site map and Figure 2 being a Is site map showing locations of borings. And this draft letter 20 C doesn't bear a date that I can see, other than a stamp on the 21 i second page indicating that it was transmitted to the NRC 22 e e -n-e w --,1,. ---a. .w, ,e. s,,e m- - - 4 ,.,-- + - --.,, ,,e -~,e--- w* -w w
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.-,.. ~.. n.. v. - -.- -.- .M ' - aa G.& :... :, e. [ @ m$-bs- ~ .;p u.- .7 - % Ob 1 November 25th, 1980. 2 You have also produced a document consisting of 12 pages containing handwritten notes which I believe you 3 identified as originating with Darl Hood. And attached to 4 l* 5 that is a little note pad page showing Thursday, December a 22nd, 1977 as the date. It says: 7 " Joe: Chronology which will be helpful in preparing testimony, Parts 1 and 2. I think 1 s s Darl plans to have these typed up." n 10 signed, Lyman. 11 You have also produced two pages, the first of 12 which is~a routing slip and the second of which is a note 13 to Darl Hood from Attorney William Paton with regard to o requested information from Consumers as relates to the hearing i l' 15 MR. PATON: Cok11d we indicate that that document te indicates it was sent to you? 17 MR. ZAMARIN: Oh, yes. We have previously re-ts ceived a copy of this. 1s I also have a single page dated 11/13/80, one of one, which contains the pages of deposition transcripts on 8 ~ i C 21 which corrections were noted by you. l And a four-page document, the first three pages 22 (- .i e l Wa S-. g, -e9-p. -p.-- ,.r.- m ... -., =
,,.,x 4 -F,.jj Q. p ; - .j y. t ;.:p 9,v:i A /~ - 9 s. mu s. ,,./ 95 eb 1 of which are vritten on both sides, which constitute your af 2 notes of the deposition of Dr. Sherif Af.fi. ,e t. g J 3 In addition you have indicated there are two cate-geries of documents which you have not produced, the fir:2t of 4 E. 8 which contains legal advice given in preparation for your 8 j testimony at hearing, and that includes a memo involving .k. e input of Counsel, a memo from Darl Eood and Mr. Paton listing 7 -;1 a the things you should be addressing in your testimony, and -1 a ~]u t also notes of meetings with Counsel and others with regard 8 .J ,,s to to that subject, the second category of which contains your j ..] 11 preparation of documentt. you feel are important to the hear- .q c ings, and also deposition quantions that you have prepared 12 .n "4 13 for Consumers' witnesses. ' :a, u 14 We have requested those documents and at least fo: 3 33 the time \\being a claim of privilege has been asserted in 15 y this regard to those, which I will ask to be stated by to -j l _ :i 17 Mr. Paten on the record in a moment. 18 The third item er category of items which has not been produced is what'has been described as a draft 19 20 document frcm one NRC employee to another with regard *4 the -s b. 21 '3 employment relationship'between the NRC and the Corps of t q F.ngineers as it relates to Midland and one other project. 22 i 'm 4 l -$3 %7 h M [sw. => '::M .+)y,4 .L
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t ~. .m--. m,.,.,._,..,,,,_.,,,,,,_ M.. k a u..,,,~m ~ ~ s. m +a. x-Z:] ab5 1 We have asked for a copy of that insofar as it t.;
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2 relates to Midland and have been advised that that is not dr ! p being produced.because of the claim that it is not relevant 3 r .c ' wi 4 for discovery purposes. 7 .nt v. 5 BY MR. ZAMARIN: l $,, Is it correct then that with the exception of the
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.. = documents I have just indicated that have not been produced
- m. -
7 42
- w and the documents which you have produced and I have iden-i -.,e 8
50 o '.4 tified, that you have no other documents within the purview .4 o y of the^ request this morning, other than those which you may M f later find upon a more intensive search of your files? 11 Ns 3_- { 12 gh A That is correct. M At this time then on the record we 13 MR. ZAMARIN:
- tjfj u
yy would ask for the documents within what was described as the l' 6
- ,.:'.t j,,'.l first category, that is the memo involving infomation from 15
~.- Mr. Hood and Mr. Payton listing. things you should be address 18 [*yyj mg 17 L9 ing for the hearing, and also the preparation of documents c.; l.. :, you feel are important to the hearings and the deposition te '9-1 questions for consumers' witnesses, as well as the draft 1s document addressing the issue of the empicyment relationshi; ,.q y between the Corps and the NRC. ' yrs .i ni 22 MR. PATON: With respect to the last document, I .% ] w. I $dMM 8e. ~ i.?ti &q x ,p ... e, .,g, 4 t e e. 69 4 .. - -, - - _ - -, -.,. ~. .-,.-m., -.,....y. ,.,-,_w ,c-- -. - -
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pg3 ,: f, O 'F agree with your statement that we don't think it's relevant eb6 1 for discovery purposes and by that I mean we don't think it 2 g( would be - the informauion contained therein would lead to 3 4 discoverable evidence. With respect to the other documents we're claiming E a privilege but we're going to take another look at those 6 documents tonight and see if we can't work something out with 7 i a respect to them by tomorrow. 1 8 BY MR. ZAMARIN: 4.400 o i Mr. Kane, you indicated that wf.th regard to the j to Q additional borings that have been requested in the area of 11 C the diesel generator buliding that the SPT's and the results 12 of the spoon samples that are taken, an engineering judgment - 13 o wou3dbe mada as to the location, if any, for undisturbed. l' samples to be taken for various lab testing. Is that correct? 15 1s A You used the word "would." I'm not sure whether 17 the word should not properly be "should." Would or g. g m sorry, what, word, in what context? te 18 should what? 20 could you repeat ycur question, please? A ,L.. 21 MR. "m : Could I hear the question, please? (Whereupon, the Reporter read from the record 22 $dMM[an. ) ~ e e W
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l(, '3.., 'Z * ?..A" .w* r.. s C ,. sj ' . w q>..#g eb 1 as requested.) 2 THE WITNESS: It sounded as though you were saying 3 this "would be done" and it's my understanding our letter 4 to you has indicated this shou.'d be done. That is the dis- ~ 5 tinction that I was t.ying to make. 6 BY MR. ZAMARIN: 7 Q You say "this." What do you mean? The horings? 8 A The borings, the testing. s Q All right. w to Now there have been a number of borings already '11 done with regard to the diesel generator building. Is that 12 right? 13 A Yes. u 14 Q And based upon those borings, are ycu able to 15 determine frem which layers undisturbed samples should be 16 taken? 17 A I think it n uld be correct first to indicate that l 18 there is a great deal of boring information in the diesel generator building but wo should be referring now to those 19 20 borings after the surcharge program. And those horings which you have taken would pe:mit you to tall where the undisturbed 21 22 samples should be ~4 en. $d.h./ 8 l - L-8as. ~ 9 O + ,p.. ...-=--* owe
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1 ~ . n..~m .., g. . ws....,. ;, l ,,.,s 99 Y I It is my understanding from discussions with the ab8 1 Corps in the borings that are being deleted, the borings you .. y.. 2 g have already completed and submitted to us would permit you 3 "'{ to determine where undisturbed samples would be taken. 4 3) 2 And has that deter:tination with regard to where .f yi 5 Q M@... ;. those undisturbed samples be taken, if any, been done? e .j,1;-? It has not been done as far as I know by the Cor; .'*? l 7 A .a (' ' 1,y We're expecting Consumers to make that detai ninat: 8 nor NRC. . ~... 'gfq
- gg Do you know if anyone within the corps or the NRt 1
s Q ,.4, o .:.q has decided, based upon the,I believe,six borings that have 10 been taken in. the diesel generator building since the sur-9fij { 11 J.; charge, whether any undist rbed samples need be taken at al 12 W :.d] aig To my knowledge, no one has indicated a depth 13 A W;.q. - ~.y interval to where undisturbed samples were taken. Our dis- .7 14 wt.a, .4-,,, cussions were, in looking at the SPT borings, the ones re- ~ 15 14.,fi ....-z4 cently submitted.in September, seeing zones which I would m;w 1s 'Ajg; CMce classify as med:.m dense'and depending upon the results of ~v.; 17 .y y 4-4v3* the other four orings, SPT borings, we'll be determining 18 +^. 2 ..:l to whether I would want the sample in that zone. What would it be about the other four borings t: N 20 Q _..r'.;.,il ( would either make you want to or not want to take undistur. 21 M. e;f p); t z... 22 samples in those areas? Yj M %J .?; let l .) l_ 'N I. N n s.v :a i -~ +
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3 s1*-- I could find in the other borings to be ccmpleted eb9 1 A blow counts and soil conditions that were worse, indicating 2 i a looser or a softer material and I could find in the other 3 borings to be completed a greater depth of medium dense soils 4 than I had found at these two locations, and that could on-5 courage me to take undisturbed samples at other locations. e It would encourage you or compel you to do that? 7 Q In an effort to resolve this difference it would s A I'm not in the encou= age me as an NRC engineer to do that. 9 position, in my present position, to be ccmpelled to do that. 10 It Q With regard to. the diesel generator building sur- ^C charge or the piezameters that were' located in saturated soil 12 at a' depth where there was no question but that they were 13 saturated soils, is there anything oth r than rapid drainaga 14 that would account for observation of less than the 35-foot 15 1e estimated maximum pore pressure head? The question I understand talks about the soils 17 A being saturated, and the only effect then would be the rapid ts 18 drainsge and my answer would be Yes. 20 Q Yes what? C That that would be the only factor. l 21 A We also spoke before lunch abo'ut this laboratory [ 22 Q A E.L t M a ~ e Sy 8 ~ -~ ...,..v.,,. T--
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.-J=W ..m*k . %~!:- =.. s.n . w,. 101 . testing that you would do, and I believe you indicated that eb10 1 2 there would be some correction that would has a to be done for { 3 sample disuurbance. w 4 A I don't recall any discussion before lunch about a 2: a sample disturbance. 4 8 Q All righ' Then we'll start afresh on it. ,2 !. 7 You described consolidation tests that would be
- Y a
run in a laboratory and I believe that you indicated there was e calculation that would be made and then the results of that i-o 10 calculation would be plotted on an E log P curve, E being a 4.570 11 void ratio and log P being log of pressure. Is that correct? C 12 A. That's correct. i 4 13 Q And when you plot on the 3 log P curve is it [ 14 necessary to make any kind of a correc on to account for gj sample disturbance under the circuzustances that are known 15 ..y G 18 to exist with respect to the diesel generator building? 17 A It would be appropriate to use the measures that .3 ts e.re known to adjust.the samples for sample disturbance. i Q And in addition to sample disturbance resulting is 20 from the obtaining of the samples, wouldn't there also be b- .j disturbance by virtue of the fact that you're dealing with 21 22 fill rather than naturally deposited soil? i wd ya E e 61 m 11
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-..n,,, n. -, r. e,. -. i 102 M D :.$:.a-r -.. = ';y 2:- M -Q ~' ab;; 1 A I don't see the fact that there are different types 1 2 of materials as being a reason they are disturbed. No, I do ,3 .) 3 not. . :1 h 4 Q So that in your geotechnical opinion there is no correction that would be appropriate on the basis of dealing ~ d. g 'll with fill as opposed to naturally occurring soil? e 7 A Are we talking about sample disturbance now, or ..t a distinction between compacted fill and normal - normally ..I a ?. .I '1-e consolidated type soils? o 9 11 Q What I'm talking about is when you have a E log h .] 11 P plot there is'a corr. action that is generally made to acccunt .j 11 for sampla disturbance to bring the curve to a shape that f) 13 is appropriate for an undisturbed sample, d s, d 14 What I'm asking you is in your opinion, is'there D any correction also that is appropriats where you're dealing 15 7;m te with fill material as opposed to naturally occurring depc' sits' .s A 17 A There is a distinction in the type of curve you .3 .? 18 would expect for a fill, compacted fill and a normally con- ,a ,s l 18 solidated soil, il 20 .At Mid1 = d we have not only a compacted soil but (. b ( .a 21 we have a compacted soil that has been surcharged.and pre-5: 22 consolidated, and I would make the correction for sample J.- M)i stj LG.L Ie%GN ~ %.:u v.J l p.
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103 -4. disturbance for both types, the type that we have in Midland cb12 1 and the type that we would have on no:mally consolidated soils. 2 I have marked this sheet of yellow MR.. ZAMARIN: 3 paper Consumers' Exhibit Number 19 for iden+4"ication as of 4 s today's date. (Whereupon, the document 6 referred.to was marked 7 as consumers' Exhibit 19 8 for identification.) e to BY MR. ZAMARIN: Could you.just sketch on that for me what you '11 Q would expect a typical E log P curve, without correction,_to 12 look like for the type of soil you believe exists underneath 13 14 the diesel generator bid 1 d 4 ng, just th general shape? I'm 15 not asking for dimensions. 18 (HanA4nef document to the witness.) One is for a nor-17 A I'm going to draw two curves. I'm mally consolidated. soil and one is fer a compacted fill. 18 not sure what condition the fill in the diesel generator 19 20 ha4'A4ng is under. i C Instead of two curves may I suggest'you make two 21 Q . graphs, and on the upper one perhaps show for a naturally 22 l y A E t I M eL. l ~ \\ N i
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okay, you have drawn and given to me on Exhibit '.%d 4 19 two graphs, the first showing what you believe the E ic' .~g . ;w 5 J)g-d - u. 4. q 7 curve would look lika for normally consolidated soil, an j 8 the second showing what it would look like for the ecmpact t.w. 7 ,1$i _,, . u.i,b fill, and you've..labeledt.them 'as: such. Is that correct? u^;d p a , -a.dp x. 9 A That's right. 1-@fj. o I notice that the curve for the normally consol gr.f.p)3 ~,2.' to Q y dated soil has more of an S-shape, that is, that the cente 90"O 11 ..A portion of the curve appears to approach a straight line s %,3 tNj 12 ,.:U ;u. whereas for the compated fill it is more rounded. Was thz 13 ' inr.;Q,M . +. - u 4.., 14 intended?
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I also note that on the normally consolidated .au 1a Q 8%gf] ?f curve there is a more gradual _or a lesser slope at the t 17 ,.g/g 'TR$ beginning of the curve before it enters the straight line - s;.F ta 1
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Was that intended also? . c.. 3.yh '$I@G*,N ' .:r' 20 A That was intended. . w.s And I also note that at.the bottom or at the e /@;g;.f.t ~ ars. 21 Q
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22 of the curve for normally consolidated it appears to appr .R?y:n 9%. A $g ..T,- . sg % RSm I* e Q.hp.f%S 3 8, ~ <- +
i { . A ' ' h.', ~~ 3 ' %:. :::iB a ' N:Qz ...,;.pg.3Q-gg:Q.g-. xs. :..,:-:,. 105 l a straight line, and it appears that if one wsre to extrapo-l l
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late along.the slope as it appears it would continue with the 2 C same slope whereas on the compacted fill it appears to be 3 approaching the horizontal. 4 was that intended? s What you said for the normally consolidated is s A I'm not sure what you're saying about.... 7 true. a Q okay. For example, on the compacted fill it appears that 9 it.is ri ing, the slope is rising at the end. to That.is not intended to rise. 11 A 12 Q okay. Is that intended to look pretty much the same as 13 the not-nally consolidated at the end, $nd that is to have a 14 downward slope and that is maintaining a cons m t slope? 15 18 A Yes. 17 Q Okay. Now the curves that you've given me, which is a 1s plot of void ratio versus the log of pressure, does this 18 indicate what you would a=pect curves to look like prior to 20 i C 21 correction for dist"*k=?ce? 22 A No. e.,
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..,...,-,--n.,,..,,,,.s.,,.,..~-.. ~. y 106 &gl,-)c.w. n -.e - - g ~ cbl5 1 Q This is after correction for disturbance? 2 A I'm sorry, I misunderstood your question. I would ' (,,,, expect them to look like that before correction for dis-3 .4 turbance. 5 Q All right. can you, in another color pencil which I will give s you, sketch on these same plots what each respective pict 7 would look. like approximately after correction for disturbance, 8 and I will ask you to make the corrected graph in red pencil 9 n w I to which I am providing. l 11 (una4,g pencii to the witness.) C Okay. How about for the compacted fill? 12 12 A It is more difficult because of the slope of the o compacted fill to be able to correct it f:r sample disturb-14 15 ance. Is Q okay. 17 How aculd you, go about det==4 a4 ng whether what you.had underneath the diesel generator b"41 ding was more 1s like normally consolidated fill or more like compacted fill - 8 nomally consolidated soil or more like compacted fill? 8 C 21 A I would. run a consolidation test. Q An#. tist would tell you? 22 m GJ tWeL ~ P S O ,w y m m-v---- ---n-- -.-----m..---9m +m
, " - K..a.'h & $.- k- [ L' 2:.'.- -.l. - _,;,~j}QA . n.. ".:;..p:::;f,nf.S. A ' JWY'r s !"i"*7. 4 -:J...,, r.; c..r.#- s 3n 4- ,M ebl6 1 A The behavior would help me. The behavior would 6.: 4 .,.-q also help me determine whether I could establish the pre- ' '6. 2 1,"Ed -nfig 3 consolidation pressure. ....o R:fM You indicated for ner:nally consolidated soil, a 4 Q M,..i.G
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5 correction in red and there is scme A*'farance than between ~@23) --6.* 4 the - that you would expert the laboratory slope would loo) .,4 8 .,;s&7l . m 'ij$.;N-7 like and the corrected slope. - y g,, Can you tell me how you would go about predic'4"5
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~; 2 u for example, settlement based on this type of a curve?
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w v4 You would estimate the effective vertical over-10 A 7 11 burden pressure that you have now. ,d ;.i C That would be some point along the log P scale; 12 O yqg ..q.,.3 13 is that right? y u -6+ . 5.. h 14 A That's correct. Zvig ....,r, 15 Q okay. ' N.. ; i.dek And than under loading, which'is to be added by 16 A ,j.7..j g .s the structure, you would have some leading increment which ..m.nu 17 Mij J.y.O. -J:7p 18 woul.d be added to that and you would determine between thes W'ci .... -....a ? two pressures what is the change in your void ra.tio. to j.]f 4 ,I Q Okay. M gl C 21 And is there a for:nula you would use to dete 4-yf;.g q fs$$ 22 settlement? w-d m .s.;. ' h. g;..! 73 M -y mud yMq ,? m i' ? Qf ---a.
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~ N;.a.# =.= >.~. =_,-... 7., -g r cb17 1 A Yes. And do you recall offhand what that formula is? 2 Q One of them uses There are several formulas. 3 A 4 compression index. Strike that. Right off of this would it be-5 Q Really what I'm wondering, you say you take the 6 We-difference of void ratio,,I don't quite understand that. 7 For. example on the log P scale we can find a point 8 have-e ' which would correspond to the load to be anticipated by the Is that correct? 10 st=uctur. 11 A. That's correct. .And so if we were to arbitrarily pick some point 12 Q on this log P scale, and I will indicate that by a dashed l 13 u pencil 1ine, I would like you to look at Exhibit Number 19 14 5.080 and tell me how you would go about taking information off of 15 that graph which would allow you to. calculate or predict a to 17 settlement. (w=ad4ng dccument to the witness.) ts What l There are many factors to be considered. 19 A you're intending to do is establish the pressure that exists 20 C in the soil before you load your structure loading onto it. 21 That may be affacted by an excavation that allows the soil 22 so 1 ..~~-.-w.. ._.,...n .. n ,,, n
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..v..;y ~.'.?d 8 compute, by various methods, the vertical stress increment .g .. w +Q.) 7 under the loading of the structure that is to be imposed. ..v W' ..A That would give me a delta-P, an increase in pressure. 8 .gp erse - s.;a n7w s I would add that onto P-1 which would take me tt !M M a
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C 12 The corresponding change in void ratio at those ?Q@ mm f.. g pressures would be delta-E, the change in void ratio. Iw 13 --n .-,.,:.$.1 use that information to predict settlement. 14 q, Jc)1 18 Q And when 'rou say " change in void ratio" you're .j A 5.% 1.;fyj refer =ing to the beginning void ratio, to the void ratio t to w<e,0 we indicated according to that point on the plot? mq}c ?:.D 4;;@ 18 A The beginning void ratio being the appropriate 2,G. es.*g 3, a .'M.. void ratio at the correct P-1. cm: I 'E.74 20 cta. Q With respect to a situation similar to that or . G&yN, f" i -> wN 21 3-g such as that of the diesel generator building, can ycu giv rig.un 22 J.pg an estimate of what the magnitude in inches of that correc GWO s .E a". 'Q g '. M.7,9 ftd. 4 kh NM v3.t; p.y i
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1to +. \\ that you have just sketched out there might be as it relates ><r +(1 J ebl9 1 2 to predicted settlement? N'dj $b Do I understand your question correctly that you're .a 7C 3 A lE$ asking me of what I understand to be underneath the diesel 4 generator building, could I estimate the magnitude of settle-
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5 a ment that could be expected? n,d y:w What I'm saying is you have gone through and w 7 Q No. M.x. w you have indicated a correction on that E log P plot that b:- s And W. would have to be made to account for sample disturbance. YSl a
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what I'm asking ycu is do you have scme opinion as to what 4.] to
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C of predicted settlement, be it a range of a half'to one and 12 p.M a# ' 13 a half inches, for example? . =::t u Is ycur quastien directW. to what is the differenc T.1j 1' A . (j i between an uncorrected and a corrected sample? J.fj 15 T Lr. J. 18 Q. That's right.
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3$ approximately what size sample would you be workir 22 lab test, > r; ; ~
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i'~% f:. G,,,,g. ,,,., e,r:s? 111 cb20 t with? Four inch in diameter, one inch thick. 2 A So on this one-inch thick sample that you have, 3 Q how do you then go about extrapolating er applying that to 4 make predic.tions with regard to a 30-foot sample 7 5 You make a direct relationship between wh: M you s A observe in that one-inch sample with the thickness of the 7 a ecmpressible layer. So in effect would you multiply it by 3607 S Q n 10 A I'm not sure where the 360 came from. 360 is what I think is the number of inches in 30 11 Q C n e..t. If.that is.the. height of.the compressible layer,: M A w 14 yes. So that any error that you.would have as a result Is Q of the sampling disturbance and the difference between the te corrected cu=ve and the curve prior to correction would be 17 amplified by a factor of 360 when you applied it to the is 8 actual compressible layer. Is that right? 8 A Would you repeat the question? i C 21 MR. 7.AMARIN: Would youread it back, please? (Whereupon, the Reporter read from the record 22 '\\ 9 e e m - - ~. -+,, - - - - +.. e +
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~(< T14 . ;,9 M.1:.u.x-w w .2m . ~ w ab21 1 as requested.) 2 THE WITNESS: It's possible. ] {- y 2 BY MR. ZAMARIN: 4 Q. Well, isn't it more than possible? Would that i s happen if you had-t ,i e A suppose there are other circumstances that work .:4j' the other way, that there are compensa*4 g errors. 7 j s Q Give me an example of how you would expect to have I a compensating error in the laboratory work calculations that 9 o you conceive to be done in accor,8.ance with the Corps' re-10 1 d 11 quest for the diesel generator building at Midland.
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We're pointing out a problem. We're taking un-1 13 disturbed. samples and in effect we recognize they're not o 4 totally undisturbed and we're trying to correct for that by a 14 .i 15 procedure that allows for sample disturbanca. f 18 Now we're saying that is magnified in the results, 17 and I'm saying there are other considerations n the labora-18 tory test which can compensate for scae of thac error. Q What are they? A I don't know. I would have to look....I can refer C you to a Corps of Engineers manual that lists the type of 21 22 errors you could have in a consolidation test and some of ASU& c$ne. ~ s
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,.Q :x.-.* y - u 3,.2,. 3- . v ' r"' ' ' %T:'- - i.. y :::.. 4,,... n 111 f cb22 1 them would be compensating. If you would like.I would refer 2 you to the manual. 3 Q Okay. 4 A That would list those potential types of errors. 5 Q All right. s With regard to the error introduced by sampling 7 disturbance, whatever that error would be and whatever that a correction that you. made would be, would be in effect multi-e plied by 360 times 1< hen you went and applied that to a 30-o to foot compressible layer. Wouldn't that be true? 11 A Yes. m.200 12 Q Looking then at just the error associated with 13 sampling disturbance which would be for a 30-foot compressible 14 layer multiplied by 360, can you estimate in a situation such 15 as the diesel generator building the number of inches of 16 which we might be talking after multiplying by 3607 17 A No, I cannot estimate. ts Q Do you have any idea of whether it's likely to be is in the order of half an inch or more? 20 MR. PATON: -I instruct the witness not to guess. C 21 THE WITNESS: I accept his advice. 22 BY MR. ZAMARIN: l I LG.L tM 8, ~ Os l
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..c..._,..,.m,,,..,,,,.,,, w==. e. 9 9 A . r, "y 4JJiddJ.- *e i., w-w ob23 1 Q I didn't ask you to guess. I'm asking you based upon your expertise as a geotechnical engineer and every 2 c h ounce of experience and knowledge you have'in that area to 1 3 1 tell me if you think it would be on the order of a half an 4 i 5 'nch or more. Without having the actual data in front of me, s A 7 I don't want to give an opinion. I understand that you don't want to, but I'm asking a Q And what I'm looking at is I'm locking at a correc-9 you to. o tion for an E log P curve you sketched for us. You have scme to general idea, I would assume, of what the magnitude of those ~ 11 'C corrections generally are, and you can either tell me what 12 the magnitude of that correction would be as it translates to 13 inches or you can multiply it by 360 a$'d then tell me what 14 15 that would be. 18 MR. PATON: Just a minute. 17 I'm instructing the witness that if in your pro-fossional judgment the answer would be a guess or would not ta have an application to the Midland case then you should 18 20 answer the question accordingly. C 21 T E WITNESS: A great deal has to do with the 22 extent of sample disturbance. You know, if someone is ;ery 1 MTU $ne. ~ P l i W%.
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. w,v, i tt eb24 1 careful in taking samples and has =4 nim =1 dis'turbance, that 2 would be one value. C 3 If someone has taken no care and loosened the 4 sample to where it has very little meaning, it would have s another value. So I don't wish to give a value between that s range. 7 BT MR. ZAMARIN: a Q Can you tell me precisely how you'd go about taking e samples so as to m4"4*dze sample disturbance? w 10 A That question makes me think that either you don't ' 11 know or Bechtel has not looked at the Reg. Guides that are 12 available to them. 13 Q Well, I'm asking you and I want to find out if you 14 know. ThenIwilldecide.whetherweaheewiththat. is The question is how do you go about taking samples to so as to absolutely =4n4*d.za the sample disturbance? 17 A In taking the actual undisturbed sample I would 18 attempt to push the tube with a smooth push that would 1s =4-4=4ze disturbance rather thar. allowing anything to jar it. 20 4 I would remove it from the boring hole as carefully as possi-i C 21 ble, trying not to disturb it. 22 When I got it to the surface I would handle it as S O
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. ~ +1pc l O %. : a. --....,. - +, v.- - n w w - ~ m - ~ -~~ ~ ~ ~ - " - " - N , '. y. . ~..- _.4% g_ 334 'yf. :, 2 a 2: u.. e -~ cb25 1' carefully..s I could and cut off a portion of the end and 2 seal it with wax to m4 4m4ze disturbance and loss of moisture. C 3 I would transport it to the testing lab as care-4 fully as I could, making sure it wasn't disturbed in trans-5 port. 8 I would handle it in the lab as carefully as I 7 could so that in extruding the sample for testing it would s not be disturbed. s I would put it in the tes+d,g chambers as carefully i n 10 as I couJ.d and test it as carefully as I could. And then I 11 would think I.would be very careful. C 12 Q In that answer you have a lot of you "would 13 attempt to do things" and you "would do things as much as 14 possible" and "you would do it as car fully as you could," 15 and I take it that even in doing things as carefully as you la could, and in doing them with as little jarring as possible 17 Lnd with attempting to push as smoothly as possible that ts you're still going to introduce some sample disturbance. 18 A 'that is correct, sir. 20 Q And is there some point, some level of sampling C 21 disturbance at which it is really not possible to tell whether 22 you have sampling disturbance for which compensation ought to M q
~ ?.:r+.: fj Q- ) E:;;; $ Q A . c:3:g,s.-f y~. ~ "k-m u- ~ . n.. i. M S :. % y h: f L ' h T D i:- g_ __ __ .,cw c o x,. _,. ..z- .. 3 117 ab26 1 be made in that sample? 2 A If you got to the point where you were as careful 3 as you could and you could not tell if there was a sample 4 disturbance, then I would be inclined to accept the results 5 of the test as they are. s Q What would you have to see before you would apply 7 scme kind of correction? I mean just a handful of dirt in a the lab? At what poidt between a handful of dirt and some-9 thing that looks like a nica solid cylinder of soil would you-- w to A The correction for sample disturbance comes with. 11 the behavior that is exhibited with the curve. C 12 Q so what.you're saying is if you get a curve that 13 doesn't have the shape you expect on an E log P plot, then 14 you go ahead and' correct it? 15 A That's correct. to Q And is there any other explanation for a curve 17 other than what you'would expect on the E log P plot other ts than sample disturbance? i ^t 18 A Is there any other explanation for sample dis-20 turbance? C 21 Q No, is there an';.-ther explanation for what you 22 have drawn as the blue line or. this Exhibit Number 19, other O 9 9 .l@
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.,. _:3_~Qf* y . cm.. .,a ,, a cb27 1 than samples? Would you repeat the question please? 2 A Is there any other explanation for what you have 3 Q drawn on this plot as the curve in blue on Exhibit 19 othier 4 5 than sample disturbance? By " sample disturbance" I think you mean not 8 A Is that correct? Are you properly handling the sample. 7 asking me is there any other form of disturbance other than 8 8 that? o I'm.not asking you that but I will in a minute. 10 Q Right now I'm just asking if there is anything else that could 11 account for the dif"arence between what:7ou'.ve drawn as a 12 red curve and the blue curve on Exhibit 19, other than 13 u l' sampling disturbance. 15 g y,,, is Q What? The fact that in its natural place the sample 17 B.300 A has a certain coa *4"4"g pressure and upon removal you will 18 i 1 1s lose the effect of that confining press.tre. 1 l I Q Anything else? C 21 A' None that I can think of. Is it possible that you would have that situation 22 Q LGt IW 8, ~ l x Og O v-
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~. ^, ~ ._ ;:. Q 5 g.y.. g- , 3.g g, p:y,-% @ ' % ;-.-c- _,.,g. . <.->.r::- - .. -. = t.:..'. 1 *W **- - x 3 , n o, eb29 1 Q okay. 4 i 4 With regard to the compacted fill, you haven't lj 2 nk i shown. us anything that would indicate how you would go about ,4 3 You have indicated a 4 correcting for sample disturbance. point which I assume is about the 0.42 void. ratio. ~ 4 5 e i Forty percent of the initial void ratio. 1 a A. .s 5 7 Q Okay. .s ~ t 0.407 1..., N_ 9 A Yes. .e n Can you attempt to show us on Erhibit 19 what the 10 Q ..cm' correction for the compacted.. fill would look like, how you 4j 11
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12 would go about doing that? a I.think I have already indicated that because of .. u.j 13 A o the shape of the curve of P.he ecmpacted fill, it would.be q 14 , h, ta difficult to make that correction.
- wW u.ia How uculd you go about doi =g it in the lab?
x 3, 1s Q g It is generally not done in the lab on compacted 'T 17 .A ie -d. is ff,u, 45 . 'j 19 Q I see. .'.3 But at Midland we have the added problem to face 20 A .b C of a compacted fill that has been preconsolidated,-and you 21 $$4 do make a correction for preconsolidated soil. 22 lT 4' ne! g m g g. m !i. D 2 w ~ :.~. ,.r m
....~....:. ~.:." T J L. ,.WCTsM.. >~.. M. e.n%%. :ia.L. ... s.. i., c. '" 2' M %.,.~~: :WL.1. :=4.5. ~_. -.v.;n. e qy.g.; .gw..;qype : 4 et..,..@. v . n,g n,.. .. g,;,-m-- a - = c= = m.,,.. w.., u,.,,m_ .... ~...,. -..,,..,,... _,,, ,. 1ps, , ;, a,,. e. a.. 3.,, .g 1-w ~ . ~,..,.. i ;..n:ca w..n + And can you show me on a graph what chat would eb30 1 Q look like and what.the correction would look like, and ex-2 plain how you make that correction? 3 4 A For a compacted fill? 5.350 For a compacted fill,such as we have at Midland, 5 Q [ i 8 which is also preconsolidated. I don't know of any tests on compacted fills in 7 A a my own experience. I don't know of any compacted fill where it was necessary to go back and preconsolidate it, or to s n 10 preload it. Genairally it's placed in adequately encugh and j at the required density that you don't have that problem. 11 C Are you saying then that you don't have any idea 12 Q how you go about making-the correction for sample disturbance l 13 14 in that type of a situation? i I have an idea but I den.'.t know what the actual i 15 A te curve is going to look like. I've'given you the range be-i i tween the normally consolidated soil and the compacted soil. 17 I think what we have at MidMd is somewhere between the ts two, and until I see that curve I don't know what I would a. ts 1 1 8 do in the way of correction. 4 b Are you saying that what you would so is you would 21 Q take the curve and correct it back to look something like the L' E 22 k ~ MM& bl.s ~ 1 ~ . ~., -
2<. w. a 4.+.iE2Z-Q~'"7-p --Q~Q, :.. _.;. ;Q.g~ . -M. :3c:-g;~. ; ' rep: ~& .. ;.-rc. .= .v. =.. n:. 1St l' red curve that you have on Exhibit 19? I eb31 1 l 4q No, I don't mean anything like that. 'i 2 A q d Wall, how would you know how to correct it? .t 3 Q .g 'il I'm not sure the ecmpacted fill at Midland has 4 A 4 this shape and the reason for that is this is a compacted
- i. t 1
5 .jt The question at M4d1=m1 is we have already recognized 1 a fill.
- -1 that it is underccmpacted, so we're not even sure that Midlan
- a 7
A 8 has that shape. -t f.Q How are you. going to go about finding out to what m -Jtl 6 Q shape it ought to be corrected if you don't know what the to .sg ~ c,1 corrected curve should look like for a fill that is either D 11 compacted or undercompacted and also preconsolidatad? i 12
- c,y I'm not sure I would correct un*di I saw the
?4.G 13 A .s -rJ actual curve on the material to know what correction I could g J24 14 M:4 so I think the first step is to run the test -; *ut 15 make on it, j'~71 . f.Ri and observe the curve and hope we can pick up from that m 16
- 3 q if;.7~{
curve that it was preloaded and has a higher pressure indi- J 17 . e..a cated by the consolidation test than it presently has under . e tj "'M 18 '4.c: 4 l9d; 18 the existing loadings. , e. :a e i-To what would you look for gnidance in deter < d:?j 20 Q 1i-j ,r. ' rf..s. 4.- f, wouldn't attempt to correct it? gr [W $dM M b G es ~ isl.gE )_ A h
k$.[63:N#5$C'. ,_ {,.N.Y N s.J N7$5 "U. ;[ -5.4.._;,i j$, >. ggygpg ;4 qq
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ua==. ...,..,.~7..- ~~v fg...; r ... w ~:.n n, z .r., --,s e. :, n ~ ~.. v. p_,,,-,...-=...,,,,...,.,,_,,.._.,..,.,..,__. .~. 123 . ~.. p;.... e.- u:.a w. J - -- - IthinkIhr.vesah.dIamnotsure,oftheshapeof ob32 1 A the curve because of the unique conditions that I think we 2 I would look at the curve and make a judg-3 have at Midland. t because of mant whether it.was reasonable to correct or no. 4 5 sample disturbance. l l 8 Q Okay. And upon what would you base that decision as to 7 whether it was reasonable to correct or not, based upon the 8 I e sample disturbance? o The shape of the curve that actually developed. to A And what shape would you expect to see which would 11 Q C lead you to believe that you ought to correct for sample 12 I 13 disturbance? o If in fact the. fill thzt was placed W. W#=d 14 A 1 which has been acknowledged to be undercompacted had the 15 shape more closely aligned to a normally consolidated'. scil, is then I would make the i arrection 's4=4 7 =v to what I would 51 17 make for nomally consw11 dated soil. 18 And if it had a curve that more closely approxi-1s Q mated that for a compacted fill, then you would not make a
- 1 r
-a t v 21 ccrrection. Is that.what you.'re saying? I would have the same problem I'm having now of 1 22 A be8Mb 8as. 'l ~ T l, .. = -... -...
=, - v.. \\ .3.;;c:a u ' %n-- t -n- ..._ g, ;;; :yy~-.1.... _ g3-g, . - _ y g_ -., p 7 :.v.g.. -,;,,;3,g.j =- <
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. %:Y. a. .,, c,,,. i i_ n_ F-l I think I have said'I am not sure of the shape of ab32 1 A the curve because of the unique conditions that I think we { 2 7 I would look at the curve and make a judg-3 have at Midland. 4 ment whether it was reasonable to correct or not because of 4 5 sample disturbance. i 8 Q okay.
- i And upon what would you base that decision'as to t
7 2 1 whether it was r'easonable to correct or not, based upon the
- I 8
a 8 sample dfsturbance? .j The shape of the curve that actually developed.
- 1 10 A
1' 4 And what shape wonid you expect to see which would 11 Q
- i C
lead you to believe that you ought to correct for sample 12 74 .{ 13 dist' % ce? If in fact the fill that was pliced Et RMr nd a i 14 A 'A which has been acknowledged to be undercompacted had the 15 shape more cicsely aligned to a normally consolidated soil, 1 a 18 7 then I would make the correction similar to what I wculd 17 make for normally consolidated soil. 18 And if it had a curve that more closely approxi-i l' .) Q . a. [ mated that for a compacted fill, then you would not make a 8 21 correction. Is that what you're saying?'
- l Id I would have the same problem I'm having new of A
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.. - -9.F. 12 ~. ~... _. g. c -Y:.) trying to correct a curve for co=pacted fill. l ab33 1 ~* do .Nd when you do a laboratory consolidation test, 2 o w a., M. 3 you measure pore pressure. 2.3-zr sk$ -5.415 4 A No. bh And are you familiar with a pict that is referre( a o ' 5.:.*; to as a change in height versus log time plot with respect a +.., dL 4-$,M 7 to consolidation? 4: ;9 . U,, Change in height being what is measured during t' 8 A N .m.=5': 04 8 test? %. ~ 7.1 o 1 -. 'fl 10 g Yes, the. delta-E. 1+ % 11 A I am f = " # = " with plots that have presented m[.f. - c deformation readings which I'm assuming you mean to be the 12 C.]:. :{ ,2 change in height versus log time. . ';j 13 o .~4 That's not what you've drawn here on Whhit 19 ',[DY; 14 Q ..<a J S,, j 18 is it? .g! 16 A These are void ratio versus log pressure curves N#21 17 Q Tcu're sure of that? f ,f; ta I'm sure.what I draw. A ..:. g e 27 7 l' Q okay. n ,. @} g 20 would you accept-strike that. f.fyA would you expect more error as a result of samp 21 kij diatu 3ance er less===or as a result.of 5*=P11:5 di'*" 5* 22 -g .II D.c.I, ,I-Q w Mi w
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'kyi;-L*Q[~;7;: _--Q, g... - n,. y : g y.p r . e 3_. z:-g. . ' s _.v-- h - ... - m. ,...e'#'- .,. ~t.. ..>.2 1 *) 2 or no difference in error as a resulu of sampling disturbance ab34 1 if a plot looked more like that for normally consolidated r-2 ( or more like that for compacted fill? 3 i would expect more disturbance for. a no::mally 4 A 5 consolidated soil. a Q WhY is that? secause with a compacted son 4
- would have a good 7
A chance of being overconsolidated because of the compaction a effort that you impose in plachg the fii' which would be a e lot more than it would be with normally consolidated. to With regard to the soil beneath the diesel genera-11 Q C -,,,,,u,1,,,, st,1and, wou1d you ex,ect ee=e e= de== or less the same magnitude of sampling disuurbance as you 13 would typically find with normally conso u m ed s N 14 Would you repeat that question, please? 15 A 16 MR,. ZAMARIN: Would you read it back, please? (Whereupen, the Reporter read frem the record 17 18 as requested.) I think I have indicated that.I'm 19 THE WITNESS: unsure of the condition that the fill is in under the diesel 2 If it is closer to a.normally consoli-21 generator building. dated soil I would expect it to have more dist d ance. 22 i
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Also it should be indicated that there are various ab35 1 It's somewhat degrees of disturbance with material type. 2 easier to disturb a cohesionless soil than it is a cohesive 2 soil, and in taking undisturbed samples in the portion of q ]5.490 4 the diesel generator building which is predominantly cchesive, '4 5 if properly conducted, a lot of sample s I would not expect, 5 7 disturbance. . a. I 3 MR. ZAMARIN: Okay. 4 o BY MR. ZAMARIN: e n I think you had indicated earlier, though, that, to Q one of the reasons why you would expect less sample disturbanc 11- .{ [ in a compa hed fill is because there's a good chance that it 12 .ed has already been overconsolidated. I think that's what you A 13 14 said. 5 - 1s A For a well-compacted fill,.yes. 4, So what you're saying is the reason you don't know 1 9 1e Q whether you would have more or less or the same sample 17 disturbance with respect to the diesel generator building is Is because you don't know what the soil is like under there. 19 20 - Are you saying that it may be that it's overly C 21 consolidated? No, I think I'm going the other way, and that is-22 A
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..s.. m .i - -*KY.-- .L'.. g.$ ..,,_..g,r:%~ L 12. I Wink it has been recognized that it was not well compacted eb36 1 and so it's closer to being - its behavior is closer to 2 {. being represented by a normally consolidated soil. 3 4p.' Which one of the two plots that you've drawn on Q h m.: Exhibit 19 Icoks more lika the' plot for overly consolidated 3h 5 n, ri soil, the top one or the bottom one? 8 .+ .'B Well, you'd have to assume the pressures are the ~ ...a 7 A ';j But I .0;4 8 same in both. I would expect different pressures. .Y'.!.. -yd thi=k I can answer your quesdion by saying a well-compacted 8 7;e.d Q soil has a potential for being overconsolidated. to ..y q' You didn't answer the question. Which one ed the 11 Q ~i C two plots would look more like the plot for an overly, con-12 .ab 13 solidated soil? W M.I o well, if I.had the right log P scale I would say
- u.~.
1' A e ;."< ,-.;3 18 this one. Eiw am "This one," referring to the compacted soil? j.g:n'; a 1s Q ~. '~iNE$ 17 A That's correct. dyjj What is your unders*=m'i"g of the meaning of the II Q , w:d . bf to t m " record samples"7 3Ii' ,.-4,); When a project is under const=uction it is commo: ~.. 8 A %g -( engineering practice to take samples that will establish a
- ',.n 21 TS'd record to show that what you've constructed has been proper Q;:n 22
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..wa ,.z,...w.,-.w , ;t.4 ( >.-.:b e. r. c.. _ #y.m ,,.e. ~., -., m,,,. w, u., y.. _,,,, _,, y n av ' M - -... w ,29 Q s, c= =.~ w-- eb37 1 constructed and has properties within that st ructure that ! - { you anticipated ir. the design. 2 l Those record samples can include compactic,n con-3 'J x 4 trol tests. Those record samples can include establishing 5 design - or checking the design parameters such as shear '] 4 strength, permeability, or any important parameter you felt 8
- l 7
necessary in the design of that s eacture. 's 8 Q What type of tests does the staff want done ed the ,.] .d 8 samples taken frem the dike area? .3j if 18 A Could I see Table 37-1, please? w ~ 'Ti 11 Q Sure. C. e-i 12 (Handing document to the witness.) '9 13 A Excluding basic classification tests which would 1' l' he soil type, natural moisture content those basic tests, E 15 the tests that are being asked for for the cooling pond 4'j 16 h ents are shea-strength tests. .1 17 Also in undisturbed samples you would be able to '~ q l ta establish the density of the fill ih the embankment and f hopefully make a judgment on the percent ccmpaction that was 19 4 i 8 attained when it was placed. l (. j 21 Q Is it customary practice to your knowledge to take 22 W samples such as those after a dike is built in order to run J. O 'A l .b 4.; i.
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. t. ppg,3.g ~ >: ;- -o- ...~,,. w :.< q: =,_c; q.;:ri.:.._ g =g g g.,3g# .s5 c.,.; . ~ ,,o { eb38 1 shear strength tests? It is not customary practice to th e it aher 2 A C It is custcma.-y practice to take it while 3 construction. 4 being constructed. And to your knowledge have se WaWu h 6 5 Q borings in the dike area changed since June 30th, 19807 -l 5 -7 '-J 7 A Yes, they have.
- t
.i g o Do you know why? Because of a decision made by NRC management. 1 9 A ] And do you know what the basis for that decision s. to Q .j j 11 ns? 1 C I know what was discussed. I do not know the 12 A w i 13 basis for that decision. i You know what my next question is. What was dis- .i 1+ Q .j .-:4 15 cussed? .] !3 I think we went through, the first day of my 16 A deposition, on one of those same issues and the issue is 17 there's a portion of the cocling pond, because of its loca-18 tien, because it surrounds the ultimate heat sink, because 19 }.[' it surrounds the Category I pipe, that there were members 8 ^ I' '1 C of the NRC staff who censidered this structure to have the 21 I:j ~u equivalent of a Category I classification. 22 ig 'El ..w 4 M 't e. b) f t
r.m%.-.. ^=~ s n .a.*..* r f{ ' M5.Tyw c-:- mI1.m,..,._ u..,,," '" ~ - <~ D2iT}.% g5 V5?fYNNN h " ~ ~ G :S.a.. -.,.. w.:-m
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. t -.. i There is the other portien which doesn't have the @9 P;" 1 eb39 1 Category I pipe which is being judged it's not a Category I w.,
- 4.;
2 -{ embanianent bpt it does have safety and environmentai con-M 3 .y.i The decision by the NRC management was to rem-s- 4 siderations. W*S the borings asked by the Corps in the portion which is not 4 5 %i r==dM y apparent to be Category I and to move them to the .C.+? e
- g,
- n hent that is adjacent to the category I conduit.
=r, q""- 7 Do you mean to say that back in June of 1980 tha =. :a 8 Q c0 Mj the Corps and the NRC didn't have any concern for the baff2 9 99 dike area or what you refer to as the portion of the embanl a to A
- 3.r.3 ment near the Category I conduit?
11
- n.:R As far back as I. can. remember the NRC had conce:
"f .. w. 12 A
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.:.721 tts - 12 for the entire cooling pond. p'^ 2 ]' u ',l' d Why weren't borings requested in the location 14 .rj ..Q where they are being requested now? i ~.t3 ha 15 =cy A judgment was made, based on identification of ..Sq 18 A -1yf/3 locations by the Corps of where stability, because of c.,
- L.q 17
,ygdp v1 conditions, conditions being such as height of emb=a6="t 18 ' ['. ].,, >j over a former stream area, where stability was more critic 18 ,9 -y and on that basis chose the locations that were initially A d 20 &c. J 8.- md 21 identified in the June 30th letter. M cF , ' -,. 7.,: It was thought that we, by those boring, in th nu de 22 gg =. :, D*L O
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~ n. - +...~x= ...<7. % w <-. a., .o 111 cooling pond, could descastrate that we had obtained the t ab40 shear strength parameters that were used in design, that we 2 { could satisfy ourselves that the dike materials had the re-3 Then we could satisfy ourselves that the quired compaction. 4 5 dike was safe. And it was on that basis that initially a certain 6 7 number of borings were chosen. And certain locations were chosen? s Q 8 A That's correct. what you're saying then is that the area in which to Q they are now being requested is considered, at least by the 11 I C. corps of Engineers., to be a less critical area than that 12 area in which they were first requested with regard to the 13 u 14 dike? B6 I don't think the proper term is "less critical." 15 A I think the proper term would be the " potential for in-to 17 stability is less." I think anywhere where the dike would fail wou d be critical'. 15 so.the potential for instability is less where 19 g the borings are now'being requested.- Is that right? 20 b Are we talking now about the baffle dike? 21 A 22 Q Yes, we are. \\ + t e = s ,,m-e v w-n --e -e t-aw. e- -*- e w e-e=w- ---a 6
~- .u.., . ;-,3%,. -^ ^,s;ti..-QQu?$- MldM,N EG.W 6- ....s.,7r"g ~ ~_ _ _ mch - - w 2+x y-j :.,: 1. x :.. ~. .4:'~qthyj_ y. q " 7. v v. r ...,.m.x e m.~,.c...,,-m _,,,,._.__. -. ...,s... o .r. G.,,,:.~..:. :.w. -y- - - - -N-k 1 39 } ~ . -m = w ar-eb41 1 A I think to answer that question we would have to f 2 know whether the conditions-I'm hesitating because if we l now go out and do the borings and find out that the perimeter 3 4 dikes are well compacted and the baffle dike is not, then 5 obviously the baffle dike becomes the more critical one. m 8 Q - Really what I'm wondering is that back in June of 1980, apparently in.the. minds at least of the Corps of l' 7 Engineers, there was nothing of sufficient concern about the 8 9 baffle dike to cause then to request some borings over there. 10 And now we suddenly find out that they want them over there. 11 And I'm really wondering what kind of a.thunderstriX ~ C 12 there was that caused this great revelation and this change-13 of sentinent on their part, if that is in fact what happened. 14 A Perhaps it would be best if you talked to the 15 people who were thunderstruck. 1e Q okay. To whom should I talk? 17 A. I would say the person who signed the letter about l 18 the change in the horings, Robert Tedesco. ts Q Anybody else? 20 A I was not at any meeting where the decisions were C 21 made to change the location and so.I don't know who else was i 22 involved. %Et tWdL ~ a .s q 4 9 9 O yy,+.., r - _., ..e
,g; c','y(* .,a, z. -p# w - - ...~.~... j.- :. --7., . n y!;7'U~ ' . w c.,.- X. _.**): . W:bQQ nT - ;. r' =^ Did you have any discussion with anyone w M re-1 ab42 Q gard to this change in the location of borings, either befo' 2 3 or after it was made? that wa The discussions I had were the decision 4 A mada was to change the boring locations to the baffle dike s and in the area of the Category I pipe and the ultimate hea ~ a It was directed that *5 ee horings be removed and 1 7 sink. On that basis we chose new locations c a moved to that area. baffl.a dike and the dike around the c h e heat s h 9 tha When do you recall d s d d sion ha W W 2 to o My guess, it would have been either late Septem! 11 A b 12 or early october. 13 g of 19807 14 A That's currect. were there then some borings that had been re-13 o quested in other portions of the dike for which requests 16 II were withdrawn? I thought I had indicated three of them were ta A withdrawn and moved to different locations. is And to your knowledge was that based upon any 23 Q kind of decision that the Corps was wrong in their concer-21 22 stability in those areas? 01 2.s Ia+,r G-1 j \\ i Mm
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( ).%.u........,.....,.,..m....,_.,.,,,__,, s.I ~ ' fc ,y ,=. %g.;,7h= m. mm 'o -- 1 a; ..j I have indicated I was not at.the meecings so I 1 A Of* eb43 y don't know whether those discussions were made. 2 j { W4 3 Q Didn't you ask anybody?. I'm not sure as of today whether the other per-h -; tions where. they have been withdrawn has been totally re-4 A k - gs: 5 2;.3 . bn' -? solved. 78J f Wi So by that are you suggesting that 7 Q Ch, I see. sp[j 3 perhaps evnn though these were moved that there is still sem .gA 8 .-%) thought that those are =.the.ones that are no longer being og,.j 8 ~.pe n to asked for will be asked for anyway? .[4 "-M It's my unders * 'hg in what has been, asked of l 11 A Ay.1 ( you, consumers, to address the other portions of the, dike 3 12 .jp with regards to environmental hazards and other safety A:J 13 3 @*i u d
- .6 and whethe
.[j3 hazards, that that information will be Icoked at, l' I@j that could lead to other work in the cooling pond, I don't .w 13 M w.9 a to I have not had any d'scussions. S"g'.' know. But it teams to me.<a would want to evaluate the ,1-17 J.7.e' G., m information we h.a a asked f r 1 you and make a decision. _= ...-;i la j There has been some change at least within the y 19 Q -<l N Corps or the NRC with regard to the location of these borin 0 ( Do you know whether that change was initiated +1 % ?:. y g'*; 4 on the dike. .~ . a -:( ' 22 by the NRC or L*J the Corps? B " 7. -ur
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_. 3 _, .,.,. m __-,-.:.gg5 y 6 p;y d*Q:b m-- .s .,,,.,,.,c.. -. W~- e. .,,u .t 1 f l .I I'm relatively.certain it was initiated by the X 4 .s. l eb44 1 A .:t t .. i. And does that indicate then an agreement with sa 2 Q ,,ggi.. position with regard to these borings that was proposed by .... a %-m 3 .f.ye' a Consumers Power Company and its consultants?
- .ar 4
'3- . y.pa Would you repeat the question and explain what y ' Jh,.,I 5 A w yd3? 6 mean by an " agreement"? 4 3,M (Whereupon, the Reporter read from the record -h 7 - a ,:gN. e..I 8 as requested.) . -I.i N.h_N 8 MR. PATON: You say "some position." That's ve: m.' TI@i 10 broad. j'Yj n-;,% e.: 11 MR. ZAMARIN: Let me get more directly to the 5 ,4 WN..a' 12 point for you.
- 4.. 4 BY MR. ZAMARIN:
13 L'ffc " , - D., -4 Consumers and their consultants have disagreed o 14 Q
- [M
the need for the borings as requested in the dike area in +.. 15 Q;f ~nc
- - e 2: ;
18 the June 30th, 1980 letter. Is that right? M;;*iG'i 'NPf' 17 A Tney have disagreed, yes. y.j{j ' 25! ts Q Yes. " ~.,. c . And the NRC has now changed its position with ud to X'd , "G@H D di"- regard to at least three of the borings in the dike area 3 tl %5;b Is that cor: .IG M.. p as described in that June 30th, 1980 letter. 21 3.e:$m.1 22 A That is correct. 5$ t, h? h.!$. k. L2LE! tet u4
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-.~.,- _..,, _., __. [.,c. ,, _.~ c::.1. c v ~ -.;;.y; ;;.= =:.x..n ~ g cb45 i Q Does that indicate then an agreement, to yotr mind, by the NRC with Consumers Power Company's objection to those 2 { 1
- k-ee borings?
i I think I've indicated that I'm not aware of the I 4 A reasons for c: uging those three borings. And I think I 5 would have te, be aware of those reasons to be able to make a a judgment whether there has been any agreement reached. 7 so you don't have any idea why they were chanced? 8 Q I think I have indicated to you, because of the e A i t doubts that some people have as to the safety significance 10 andthephpersafetycategorization,thatthatthoughtwas i 11 C a thought which promp.ted them to change the locations. 12 I think in my first full day of deposition we l 13 u s j spent a great deal of time on that matter. I' ts Q That's right. And also at that time I don't think j 4 we were aware that there was going to be any change with te regard to the requested borings which were so terribly 17 importut at that time to the Corps of Engineers in the loca-ta 18 tions at which they had been requested. 20 At that time you were not aware, nor was I. A b 21 Q I understand. 4 22 6.100 g3,c,,,,) i I 4 Y Y U , $see, li 3 0 '~
p. ..v -y ..... K -c; y.. " N -f u-' 3.~m ..Q ^;;L3 5 : -... - -x w: v.ne.. d:;.'gr.*nj;;k ' <...-.a -:sw.:...,a.- .,,.,e 3 2 -r ab46 1 MR. ZAMARIN: Back on the record.. . { 2 BY MIL ZAMARIN: 3 Q With respect to the requested borings in the dike, 4 for what p se are they requested? Is it to detaa he slope stability er is it to determine settlem<nnt? 8 ~ s A The purpose is to permit undisturbed samples to 7 be taken to establish shear strength which would be used in 2 8 a shear stability analysis. It is not a concern for settle-8 ment. w 10 Q On Consumers' Exhibit Number 11 as of 10/15/80, the third page thereof under Paragraph Number 8, it. talks 11 C 12 .about "present state of the art approach " 13 I'll let you look at that. And my question is f what state of the art methods are you referring to when you I 15 talk about the testing requested by the Corps? ~ 16 (Handing document to the witness.) 17 To which section are you referring? A Q Number 8. Do you see the paragraph numbered 87 ts 19 It's in there. 8 Is the question what is meant by " state of the A C 21 art"? 22 Yes, the questien is what state of the ar: methods Q AEN& Sna, ~ w--- t-e w
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s, .;y .x.m u.:r a. a m - -.,, ~ ~.a a.. - ~ n, ~., v.--.. c.'. h.. ~ T.T ~ W k as Swm-- 't '. H.; 1 i-1 ab47 are you referring to in re:i'arence to the' testing recuested
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A The laboratory consolidation tests. %g 4 Q And does this present state of the art approach h:1
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..y to which you refer also apply to any method of correction 5 4j,t
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which would be used in connection with those lab test calcu- pr ~. i k* k --';.g:.J 7 1ations? 8 A I would consider the corrections such as fcc. san ^ .?.i
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disturbance to be all part of the state of the art. y o 'a 2M 10 Q And are there any other corrections other than ,..J.9 ] t1 for sample disturbance that you would expect to apply as ..rq. - 12 part of the state of the art? m.1 13 A Is the question directed to laboratory consolida- / ;, u 14 tion tests?
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18 Q Yes, if that's the only kind of test that you Cl,0l \\.u,,-Ak refer to regarding the request by the corps. 1s .x 17 Q The confusing part about it is the document you D ' '.M e refer to I think covers all structures, and that particular 18 . 4 f .. :) section I think was referring to consolidation tests, so - ...e 8 I'm t: ying to resolve whether your questien now refers to -03 i]II,j consolidation tests or to everything that was intended by t2 21 .1. M, v. 22 W document that you have. W 'd*2..4 q AEt I% G, ~~ M.Bi -s 1
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, %'W c. .,,u.,, .,,.,..v cf 1?o r 1 Q Okay. eb48 With regard to the borings that are requested, are 2 p there tests other than consolidation tests ths.t are requested 3 4 or contemplated? 5 A Yes. 8 Q What7 7 A Shear strength. 1 s Q What else? If you consider the measurement of g situ 8 A o 10 density a test. 11 Could I see Table 37-1 again, please? C ~ (Document handed to the witness.) 12 The requested testing includes shear strength test-13 6.180 ing,relativedancitytesting,consolikationtesting,and'the 14 ts normal classification test. And would you reference to present state of the 1s Q art apply only to consolidation testing? 17 The statement that you read in Paragraph 8 was 18 A referring to the state of the art with regard to consolidation 18 1 8 tests, yes. i ( Q And the only correction
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21 would propose with respect to that would be corrertien fer 22 e DL E.4 I % 4L ~ O e a L.__--
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. n - m n. _,, ,,,m.m,,,,,,,, k $*D'JD 4-.cxr a --:..s-ve~. *~~ ~ - ~s, .g v wr - '> <- s ~. ne. n - m~ ~ = - - ~ ~ - - h.h fe$h-n T ^1.7 + h_ 14o ~ eb49 1 sampling disturbance. Is that sight? 2 A I'm trying'to recall the procedures in the test { 3 to where there may be other corrections. I cannot think of any. 5 Q Did Dr. Peck, to your knowledge, aver state that a the fill underneath the diesel generator building was in fact 7 placed dry of optimum? 8 A To my Nnowledge he indicated that it was his under-9 standing that it was. w to Q Was it that.he indicated it was his understanding 11 or did he cite placent.tdry of optimum as a possibility? C 12 A I n assuming that when the subject was raised 13 about it being dry of optimum that he had availabic to him 14 before that statament data that would help him to decide 15 whether it was dry or not. Q Imd is it based solely upon that.essumption:cf Is 87 yours that you conclude that Dr. Peck believed that the fill ta was placed dry of optimum? 19 A The basis that I have that it was placed dry of cptimum was the conversation that-I had with Dr. Peck. What b 21 basis Dr. Peck had for thinking it was dry of optimum I have never d*.scussed. with him. { O (L E.L.I M G. ~ O S. O s
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..e 984 l i eb50 1 Q Tell me exactly what it was about that conversation !. { that you had with Dr. Peck that caused you to believe that 2 '? 3 he was of the unders+="A4ng that the fill was placed d:7 of J.t 9 4 optimum? f* 1 8 A I think it was the July 31st, 1980 meeting where, 3 j 8 in.a conversation with Dr. Peck, I had indicated that I would have expected a much higher development of pore pressure 7
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8 under the surcharge loading tiuan was recorded in the piezo- ~ 8 meters and he indicated to me that a possible reason that 10 it did not reach the levels that~you would ant.icipate was g, q; ..1 11 because the material had been placed dry of optimum, had a
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C 12 lot of cracks in the material because -- I think I can 13 remember the expression -- being placed in slabs. o I' And I remember the expression " macro voids,". l 15 meaning his classification of the cracks, and under loading te of the surcharge, the pore pressure did not raise to anti- [~, 17 cipated levels becau*a those cracks provided a drainage ta path which did not require the pore prescures to raise to the 18 l-high lev =1s you were interested in. i [f Q Would you expect a distance of layers of soil to 8 C 21 l' provide drainage paths? 22 A If the layers were of a permeable material, yes. l-ka 4, sus j; s I.*$ .e W. w, '~ ~ ~
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,, - - ~. m.,. c. e.,. m. -g' 1 j ') J' wm d-7- .~%... w cb51 1 Q You just described a conversation you had with Dr. Peck and his statement of the possibility and a possible 2 l' explanation for the magnitude of pore pressure dissipation. 3 Do you agree with his stated possibility? 4 If we had,a la.tge system of cracks with large 5 A voids, then it could parnit the rapid diss.ipation of pore a i But if we had that condition it raises questions 7 pressures. t.ith regards to your observed settlement behavior. a 9 MR. ZAMARIN: Could I have the answer back, please? (Whereupon, the Reporter read from the record to l 11 as requested.) 12 BY MR. ZAMARIN: 12 Q What such questions does it raise, and why? 14 A We have discussed this pre.ously. 18 If the fill were dry with large voids when loaded i you would expect a closing of those large voids because of f 18 that loading and therefors, in closing those voids you would 17 i get a settlement. Then to me there would be a period of 18 time while you experienced that settlement that additional ts loading would th u take you into the normal consolidation 20 C 21 process. 22 Your date of settlement versus log time and ths 9 1 - - - - ~, - -m-
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.,.4.m..QQ 2Q.[-Q. -- .}~. _{ }}. j ^% .,/ c. ,,. e e- ..y -,, t 1 't shape of the curve as you are indicating is representative ob52 1 2 of a homogeneous material which avh4 hits that shape. When ^ 4 s 2 loaded, that shape I don't feel would be representative of 4 a condition where you have large voids that initially have s to be closed. s Q gow long do, you think it wculd take to close the 7 type of large voids which you are talking about? s A It depends on. factors. It depends on whether the 4 8 material was saturated. - n i to Q What I'm talking about are the type of voids and i 11 other co.iditions that Dr. Peck stated to you as a possibility C 12 in your conversation with him. j 12 A I don't think you could give a time. I think the extend of the voids, the fact of wheth b the material was' f 14 15 dry or was saturated are ali factors that you must evaluate. 1e Q Are you aware of any borings or test pit observa-17 tiens which indicated that the fill underneath the diesel i generator building may have bten wet of optimum? l 1s l A I did not see the test pit excavations. It's my 12 l 8 understanding that test pit excavations were conducted. It's b my undersu aM ng that members of the NRC staff did have the 21 opportunity to see those test pits and after having had the 22 AE! tM e7, ~ \\ e e O I ~ ~
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-~~.~ ~. u 1 discussic. with Dr. Peck about material being placed d..y, ab53 in discussing with a member of the NRC staff who had visited 2 {i { .') and saw the test pits, he had-indicated that there were 3 t .w
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4 cracks in the fill that he had observed. d k'. 5 And so the information with regard to test pits 1 would make me inclined to believe that it was placed dry. a Q You're referring c2 course to Lyman Heller? 9 7 -w J. 4 A That's correct. .+ ? 'Q This discussion with Lyman Heller about test pits 8 and cracks in the fill, did that pertain to test pits in the IG -] "i! 11 - diesel ganarator building, outside the diesel generator ( 12 building, or some other area? .] A To my understanding it pertained to test pits '3 w l .a, 94 _ ~4 outside, but I'm not positive of that. 'd 15 If horing's in the diesel generator building Q I ~ I T"j demonstrated that the soil was wet of optimum and a test pit 16 1 I m 17 in in the diesel generator building showed that the soil was m wet of optimum, would that change your opinion as to whether 1s the mechanism which you described associated with the soil 19 i.; a y placed dry of optimum was likely to have occurred? 11 A If the borings and the tests on the samples 22 ~ recovered frem the berings shewed that the matarials were not ree. W( 's ..s g l ,.y- -9 s - g... g.*
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T4C 1 i cb54 1 dry but were wet of cptimum, it would change my opinion en 2 whether cracks and large voids existed, yes. j { 6.350 3 I think.we had this discussion before on the time element of when these tests were run on the samples and E how the moisture content was established were all previously a discussed. 7 MR. ZAMARIN: I'm sorry, could I have that answer a back? 9 (Whereupon, the Reporter read from the record 18 as requested.) 11 BY MR. ZAbDLRIN:. 12 Q With regard to soil that was not wettied by seepage 13 from the pond or recharge from the pond, would you expect o 14 any change between the time it was placed with regard to 18 whether it was placed wet or dry of optimum and the time tests 18 were run, even assuming those tests were run after the sur-17 charge. ts Depending on its location in the fill and its A t 19 closeness to the groundwater excluding any effect of the 20 seepage from the pond, you know, by capillary actien, you 21 could exp,ect a change in moisture content in soils. 22 -Q okay. A E / I h E, j
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' ~ *- w - g;; t,,,~_ (,i.'c= we ~.6 w l l eb55 1 Wocidn't you have expected that same capillary j 2 { action prior to surcharge? 3 A Prior, and continuing. But the discussion that I recall we had before about moisture content was if we were 5 now to look at data of moisture content of the 'ill, would e that show us that the material was placed wet f optimum, 7 and I'm saying it depends on how careful those moisture 8 contents were run. e And i think I went through the example of if a w 10 sample sat around for a long period of time and then were 11 tested for moisture centent you could get a wide range in .b 12 difference in. moisture contents by where you selected the 13 sample that you tested for moisture content. o l' Gravity would pull down the moisture in a sample 8 that's sitting down for a long period of time and the bottem te would tend to be wetter than the top. And if the sample sat i i 17 around for a long period of time before being tested it ta might not give you a reliable moisture content. i Q But what I'm t= m ng about now is soil that was 20 not wetted or saturated by pond recharge or pond seepage, 21 and with respect to that soil you wouldn't expect any change 22 between the time it was placed and the time the tests were g i LG.s tM 8, ~ s 8 e e -= _ 1 w v v g--w-
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u.,:r.. :. .~ 3.;y., ,_g o~ 147 ab56 1 done with regard to moisture content, would you? 2 A At the surface you can expect some drying out. At 2 { 3 the lower levels affected by capillary action you can expect j 4 an increase in moisture. So there are zones within that fill + 3 8 that could be affected. s Q Okay. Now would you expect there to be any significant 7 change with regard to the moisture content of that soil frca L 8 l~ the time 1:nmediately prior to the. surcharge until today, for l 9 !) 10 example? ll 1 11 A I would expect the poisture content to have C 12 ch-ged.- 4 12 Q In what way? u l 14 A In that the surcharge should have squeezed out i 15 moisture and reduced the moisture content. ts Q okay. l* 17 If moisture tests run after the surcharge shou =4 1 ts that soil which was not wetted by the pond rechargo was not t dry of optimum, would it be your opinion that it was also not 18 8 dry of optimum prior to the surcharge? C 21 A I think you're having difficulty of - after the j surcharge of taking the effect out of the. pend because the 22 \\ i. e
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.- R;.;7.c.i3x & '.3:m::' kO~ ' e l..:~.c.>...4-l-5.j Q.g 5...-. K.=? Q.'*" ~_.[_ Q.,3. Q.. E - - y. :s-.a ..n.._ i =, % c ., :e. .x i 148 eb57 1 pond was raised prior to the surcharge. ^ .'A { 2 Q I'm talking about soil that was not wetted by the 3 recharge from tha pond ihen it was raised. I ,4 .J 4 A If you can make that distinction. ?! I i 5 Q That has been the predicate for each of the last .i 8 few questions I've asked. .._.i 7 A. Would you repeat your question now? A 8 Q With regard to the soil that was not wetted by a e recharge frca the pond, would yougect tests-Strike n le4 10 that. With regard to the soil that was not wetted.by-11 .d, { 12 the recharge of the pond, in your opinion would a test afte.: qi 13 the surcharge showing that it was not dry of optimum also ma '7 14 indicate that immediately prior to the surcharge that that n 15 soil was not dry of optimum? l 18 A For my own benefit, can I rephrsse the question' vi 4 17 to say we're assuming this scil was not influenced by the te j pond? '.[ Q That's correct. 18 '1 A And before the surcharge was imposed it had a 1
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b 21 certain moisture content, or after the surcharge? Which of m:N . t 22 ..; q those conditions? d ..n M [ne. Ej s.v. '?- ~ ea--, e- +e ~--e "-em
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e 4 't C6 to A Could you read the question, please? -r , ep.5 (Whereupon, the Reporter read f=ca the record 11 '.,. 2,. c.i.aw:ri 12 as requested.) ,;%g
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13 TEE WITNESS: I don't think you can make that lM u .a..v correlation because I think the surcharge would have chan< w' 1'
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the moisture content of the material before and after. .:lsigQ 15 yyr:1 l.. m ?w 1s It's seems to me you're asking is the moisture I 7..43
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18 -M j'Ci q 18 BT MR ZAMARIN: kom 20 Q Are you saying that the surcharge would have
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+ 150 cb59 1 A It could have, yes. In what way would it have changed it, or could it 2 Q { l 3 have changed it? It could have caused some densification of the 4 A soil because of the surcharge and that densification moisture s
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1 7 weight of the solids. So for a given solid you would have more solids if it were consolidated so in that regard it a 8 could affect the moisture content. r o i 10 Q Right. And wouldn't t. hat then, however, give you results 11 in moisture tests after the sur-M e which would indicate 12 j a d=yer soil than you had prior to surcharge? 13 1' A Yes. But I thought your question was are they both ta dry or are they both the same. 1, to Q No.. 17 A I agree with your statement that they would be f i ta dryer after the surcharge. Q After the surcharge. .i 8 so if it is in soil that wasn't affected by.the b. pond and you run a moisture test after the surcharge, if anything that moisture test after the surcharge will be I 1 m E.4 Ih & 2 l 1, n
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.W D., =,,h w n ?, m. .. ~ -,. : v a v .M Is that than it would have' been prior to surcharge. @m, ab60 1 drief .ar 4 W-g1 r 2 what you're saying? \\, .$..- +4p If you address'ed those other considerations I sa 3 A about rsmnhg moisture content tests. 45 4 .;gj-In other words being careful that ye a ~j t Q ch, I see. 5 .. A : don't let them sit and dry out and that kind of stuff? [IdNJ s c 7 A That's correct. -. s. 2 -ag Eave you reviewed any water content data at all 9. s Q > $~t,3. Ggs with regard to the soil under the diesel generator buildint s 7.g ,,s ..y to A No, I have not. C 'O 4::.m If in fact the soil was not p1 aced dry of optim - :., :n., 11 Q - 1a ?in; underneath the diesel generator building, would that chang 12 ..-..,_J in any way your opinion and conclusion.with regard to what LiG:3 13 'jyj],, gg ,.,. z settlement versus log time curve for the diesel generator .a-. '~'*.m. l' _. s SJ 15 building demonstrates? rdkj j, - J It would not introduce the problem of the crac} f-.f5hh 18 A and so I could expect the behavior to be more representat: .. u ::t 17 53-j 4,d. 4 Are you saying then.that it's more likely that ts i[g..] Q that curve.in fact represents the typical primary /seconda: . n... to . a J- . 'Qj]
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2 Q Eow much better of a chance? I mean is it like13 g'j h* d .s F.. that it does than in your mind represent typical behavior? p':El 3 .m. A Theftypical behavior that we see is based on j . n..; ~i@ ~ l We ' w laboratory tests of essentially a homogeneous material. 4A. 3 f.@ ' 1.w.y
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don't have that at Midland. We have soils of different =.g... $h1EN compressibility characteristics. And so, because of the 7 MD .Tc; conditions we have at Midland, I'm not sure there is a typti xw-W 8 .h.rs c.. 8 behavior 3 r ! W.';) i.c.:.m...o t soil -i.$d Q Would you expect there to be d=4 9 8 =" . w.n characteristics in the soil underneath the diesel generator m 11 . ~w ~.y b ,g, ..:4 v: '~ D=4"=nt in the sense of causing tihe most con- ..4 A u p-yP , '~ 7lQ 14 solidation? .A @. is Q Causing the most consolidation and also exhibiti ~. =.... 3g .%.:a-,- c , N3'O " I angineering properties of the soil which would dcminate the ws.: basavior of the soil, or predr'minate the behavior of the'sc .Q ..w. ' A I would expect the soils, certain soils to have 1s c.. gj .y., 3, d=4"="t behavior when concerned with settisment. But the K,.C:] .n ; fact that they are different with different compressibilit.
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20 y;] y -. y. ! U 21 characteristics, you can't just look at-the dominant one, -/2,.4 hkh you have to look at the differential settlement between th-22 M.e%.d., 6.610 i 4 s
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.m.,, .r.'re] and the amount of rise in ucess pore water pressure that - S 10 '69'2 you would be able to record or observe on the piezemeter, 11 i_.W ( what good does it de to make that prediction? Aren't you 12 c,; 1 - a..i I 13 just guessing? 4 o -u 14 A You have indicated you do not know the drainage i l. a A 18 characteristics. You don't know the material types well
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I would think with the '. i.n. 4 borings you have completed'that you have a lot of informatic jf:] 17 .n 9 , 1;)i; that would permit you to know that. 18 M..Q 't Q Really what I'm saying is, though, that since yot
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8 have those variables, of what use is that prediction when . 8.:&'! a t.b
- g you can observe the actual field behavior under surcharge, 21
>g 22 that is, settlement versus time? irNh,q m ikh b7 , ma SM/-./ M c7= ~ ld.[d. m@i/E i r' mF4 i 'N5 I sq w-a _g---r. a--%-i.-w* +ee. .---,.g.,---eg -i ep--r-, w,--sa.-m ,,g.,_ y- -r-w peya.-er 9W4,,.y --M y-y
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-g %:vL%p g;Q,.'ShR Ahfph, fge-p 5.n.r :....,. fkfh bh .f,..,= -.. WW n- .ge-y3m ~4- .n.. .. - e l,,_.pym-: ~;--~~ u - ,2I m~ ? m r s z.~..n ""^*" eve *% , ~ ' -,i.$;.c...,.,,, z.- ~--.. - r m. m ~.~,,, _,_.,. n,, rQ %'s?= w.w-T. 2 l w..* ll.-.".16 Well, given enough time to where there would be 4 'E n ab64 1 A i MKe question that you were in secondary consolidation, there ma $b 2 Dw c.4 Given a schedule where time is a sig iWCF' 3 not be a need for it. syr!n I think not knowing is a piece of info::mati
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ficant element, fdd %.wj which would help you make the judgment in.short time sched: }} s y wra of when to remove the surcharge. 8 -fM..
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~. 7 w%p that under leading, both the settlement and the piezemeter _ow, - 99 a O S$t, behavior as anticipated has now fully dissipated and now I r
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o l-N know that I'm out of primarf consolidation. '1 to 'Nej Upon what assumptions is the prediction of leve U tt Q ' ); g ms 12 rise in pore water pressure made? ~ +ie.-J G,.#54 I don't understand.your question. MJij 13 A o ?.. q - P Well, there are certain assumptions that you,ma 14 Q ? , a.: when you predict the level to which pore water pressure wi disi.h,.$ 15 m:w - . ~ a.#s te
- rise, for example, drainage path.
Are there any others? . et <;. - Ld:gsy Are there factors that affect the height the Mpv SM5Y 17 A HBisk pore pressure is going to rise? .., g:'y g la g, 18 Q. That's right. Are there assumptions that you : ll.yy w'E.X 1 .,g.. y 78+ 20 make in arriving at that prediction? c. ?gp.4!.j .a.a:.is There are others, whether you are fully satura -g 21 A .Td g$x~e.+;A 22 Q What else? 4 y W % j * '4
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'. py%.% 2 Ens:--fn-- x v:- .=..,.-2 .__,...e.+ , - e ~ cb65 A The rate of loading. 1 2 { Q Anything else? I j 3 A Not that I can recall. n l i ]i Q And you have a possible range of vclues for each 'ei 5 of those assumptions. Is that right? 4 a A That's correct. 1 ,j Q And you have to somewhat arbitrarily pick one of 1 7 >4 those values in order to come up with an expected level of a '1 rise. A You may not have to choose one value; you can look l.] to LJ A tt at tha range. d.i b 12 jj g y,,,, Jl Do you have any idea what the range of values 13
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u 3 14 would be for the surcharge of the diesel generator b"4td4ng? ] Given that it's a==v4=um of 35 do you know how far down it 15 . :1 ja ij would go? 7.020 A It could be very low, depending on the drainage '7 l l paths that are available and whether you were fully saturated. I' 1 1' 19 l Q So you may have a range from one foot to 35 feet? f i.' 20 4 f A That's correct. It's unlikely you would have a .i 27 that range in a 30-foot height of cohesive fill. '.'I Q Is it more likely you would have between one foot i 22 m m ma. a B-
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.,.e.,,.,-.-w,.-.>~.....,-.... .. ~.... .4 ,e ~. k.sw:c..n-~. z,z. j ab66 1 and 30 feet in that kind of a-situation? 2 A No, I would increase the one foot. j { o 3 Q To about what? j. i 4 A I feel the question is what I hava answered before. P I don't want to make that guess until I've looked at the j 5 1 s potential drainage paths. 7 MR. ZAMARIN: Off the record. '4 .I 8 (Discussion off the record.) 9 MR. ZAMARIN: Back on the record.
- aj n
1 to BY MR. ZAMARIN: 18 Is it requi=ed for good engineering practice in 11 Q ll your opinion as a geotechnical engineer to make a prediction 12 H as to the length of time a surcharge such as that placed on 13 o ,the diesel generator building is to be ledt in place? j 14 .o 15 A Can we reach an agreement on using " required.for j.1, ..a n good engineering practice" and just use the term " good is c 17 engineering practice"? I q yo, z.m saying " required." In other words if you is don't do that have you committed engineering malpractice? ..J 3 l4 A No. 1 C Q If you don't do that is it considered to be un-y 21 ?,; acceptable practice within the engineering ccumunity? That's 22 , +.: 4! ,n 4 DLEt tMeL ~
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tw e'.";;; g g i. % [-:U.-- ..,3 g..{.g. y g .n.,.s .,.. 2.- 158 I eb67 1 what I mean by " required." I don't think the engineering ecmmunity is so well 2 A { established to have set thess guidelines. 3 f 4 Q Okay. 5 So your testimony is that, to your knowledge, such guidelines do not exist within the engineering community. a 7 Is that right? I don't think our profession.is so structured a A that it takes away technical judgment to where you would be s to free to use this technical judgment I don't think there.is U a set of requirements within our profession that will say you 11 b 12 must*do this, you must do that. 13 Q well, certainly within some limits there are.. ,i There are some that say if you're calculating bearing capa-14 city, for example, there are certain factors you have to take 21 15 In J and if you don't take those into account that 4 18 into account, 17 that is inconsistent then with good ngineering practice. i ts And what I'm asking you a do-- 19 A That's not totally correct. If you.have experience in a given area and because I 8 b of that experience you do not need to run the shear test 21 parameters and the. other infoz:mation and because of your 22 h; } -e pas. ' f.1 s.. ,\\ H e f' -a i ~ . < r ..~.....,.... o w -e-.,w,- - - -,~ --e-w, -.~~n-, w w-w.,-,_ e w-va. m., - +., r
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n experience you're able to correctly predict-what is necessary I ab68 1 for the design to be acceptable, and you do that and you come 2 then I think that would be accepted in the 3 out correct, engineering profassion. 1 4 3,. lt 5 Q Okay. '9 And what you ha'3 just dona is given certain i C1 s .y criteria which must be met in order for one to say that, good ..qh 7 -4 engineering practice had been used? 1 4 s s A .I haven't given criteria. I have given my thoughts o I couldn't go to some place where this is written down. to t. .i 11 Q well, let me give you an example. I '-1 Q I've been involved in many lawsuits with respect W 12 .r,a. to architect / engineer's errors and omissions, and one of the }l 13 u-q basic questions in those cases is whether malpractice was i 14 15 ccmmitted. And in det--4,4g whether malpractice was . u, committed you have to decide, or the t:yer of fact has to i to
- -t i _
decide whether what was done by the engineer / architect was i. 17 consistent with the standard of care in the architect's role Is 4 t l~t to or engineering community. And the standard of care is defined as that which 20 C is customarily required for good engineering or architectural 4 21 practice, and there are certain things you just have to do, 1 22 4 M t;d I. -* l El lA l
c '.) ;d.a + a %.m. -- ,,.,,.,z. ;;:;. q ~..,. v%. .r .,o ~ - i.' 1 n.) ~;,: and if you don't do them or dnn't have an excuse for not .yd eb69 1 doing them such as having the kind of experience you just
- ea 2
Td C -33 ( described, then you just haven't done the job right. .: i.1 3 Qly .ST. And really my question is: Is making predictier 4 ll?Q ' c;% of the length of time a surcharge has to be left in place 3 the kind of a prediction that must be made or else you have t #s ~ Ihij* 8 departed from what is considered to be good engineering
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$+% 7 J$ practice, if you have an opinion? 8 . gi4, In my review effort with the M4 died project I Jg?G M.,j 7.080 8 A n ~. :s ha n not tried to step back and examine whether good engin i NLS to ..m I've tried to addr , 7 {8 Fin '1 ing practi,ce is being followed or not. 11 ~?.E %[3.T ( - 12 ff the issues and whether in my opinion, in my experience, !- W r7 there is reasonable assurance of safety. .c,gi 13 . 35$r,1 .em. t on the intentier 2 I'm not, going to pass judgm 'rg:M l' TW or whether others have been negligent with the approach t2 .r. y ;:p ts M ig I have used, and I'm not going to answer questions that a: . t.-:5 18 N.w:.j g
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17 asking me to judge negligency in others. ^nid You - Well, for one thing I disagree with you. , 9.'s.. ts Q ,;.'J.y
- - :.5m answer if you're asked and they are appropriate questions
%.icq ts y*~ but beyond that, we don't need to get them because t's ac Av g g 4 u. asking you whether anyone has conducted themselves in any 21 J ..%,.,g l.'- particular manner, including a negligible manner. 22 e I. M dad & $m ~ f s l. &,g \\ ****/ ,e/ . + m u ,e- --n---__-._,,-e.,.e---w ,um-, ,--v-sw,--o-w-,v- --m--g--,, w-m, ww-+- wsr-,w,,w, v,,,-wm --,---~o
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~ f.,, .-.7._.-d 161 ,~y _s:P w e - - - ..;) What I'm simply asking you is if you have an ab70 t opinion, based upon your experience as a geotischnical en-4 2 i { gineer, as to whether good engineering practice requires 2 making a prediction for the length of time the surcharge is l.- 4 to be placed on a structure such as the diese'l generator a 4 ba41d4"g prior to the imposition of that surcharge. 1 a Good engineering practice would encourage you to t l, 7 A a make that prediction. I don't think in my estimation our field of engineering is so st=actured that it would be i s w 4 ). to required. We discussed a little. earlier the Z:. log P curve l 11 Q p. d ( for a compacted soil sample. Do you recall that? 12 2 i t. 13 A I do. o And I believe that was on Exhibit Number 19. to Q You indicated that it was difficult on timt curve i.i. ts to indicate a correction or to dec'ide exactly what type of i to I correction for sampling errors should be made. 17 I Is that because it's difficult to locate the point i ts i i te of r=v4= = cu=vature on that curve? s I'm assuming you're referring to the curve for 20 A b 21 compacted fill. i, .i 22 Q Yes. 1 i I M i I i 8 t i l j ,,-,---.,--ev- --n ,.,,-,---,r~,,,w.--, -,w,,,..--+,,,,---,-w,..... -. _....,...,. +. -....,.,,--,.n .-.,~~---,n .-n w
j O.- m. L;-GR Q..y. 3..4. Z.x'.s..'.E..~' Q : Q 4 gci-gEi- ! Ac:- p- .%,,.s. w.g. .e j "i'v - c 2.; . a.-- 14'1 1 cb71 1 A That is part of it. The fact that we don't go i into a straight-line portion of the curve is another pertion 2 { 3 of it. 4 Q. So in other words there is not a well-defined i i break in the curve as well as not a well-defined point of a ~ i s
- naximum curvature?
i 7 A That is correct. I a Q And that would make it very difficult to correct for disturbance in that type of a soil and allow considerable 9 1 l to rcom for error, wouldn't it? 11 A Faced with the problem of =,Wg that adjust:nent, 12 my answer would be yes. t 13 Q In your opinion, on a consolidation test and in 14 that type of the plot, would you expec a compacted soil to ta behave or to demonstrate a plot similar to that of a dis-to turbed na+.2ral, scil sample? 17 A I think I have indicated that because the materials ts that were placed in the foundation of the diesel generator 1 building were undercompacted, than i am not sure of what the to 8 behavior would be in a consolidation test. I think I have C 21 indicated'that if I ran the test and I was able to judge 22 whether the test results that came from the consclidation l s t e* .-_.___c-y, -- c--- -..,v.- c,-.,m--r-- ,,.-m---.---y,- -,__~,,-,..-..,w,,,,,m- .___-,------,,s
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= i test were closer to a normally consolidated soil, then I 1 ~~I] eh72 1 would make the adjustment for sample disturbance. a 2 { I think I have indiented I would have a problem 4 ..? 3 e.,', such as I have now of adjusting the curve if it came out 4 -- :-) s looking like a compacted fill. , c. v s Q Well, my question is:
- q
$.. l, Based upon your experience, would you expect a cy, 1-Gi 7 e ?> compacted soil sample to behave similar-to a disturbed Q: a s natural s,cil sample? 3l]j h-I think I have indicated by those cuzves there .~T1 10 A . A., 11 that it would not be that way. $. '. J(j( How many times have you performed consolidation 12 Q. _.y teaus and made predictions, based on a compacted soil samplei M 13 o There's a. couple of parts to that question. How . ~., 14 A ~-9 many times have I performed consolidation tests? ts .., q ...s-18 Q No, my comma goes is a different place.
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.s Bow many times havo you done consolidation tests - A.h,.. 17 . L. and made predictions, based on compacted soil samples? ,s 1s ? By making consolidation tests I'm assuming if I
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n: i - s, s i I'v had been the one who had asked for the, test to be run. 1 to l .4 t' not worked to any great extent in the soils lab. -7a \\.,,./ ~ l 21 . g 22 Q You say not "to any great extent." Eave you wo: I. f.....4Q> - := ^ J.Q ]w j..:.D MU& Sna, ~ b l... c.
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~ <.. s...y,, - 3 3, 4-. ug a+;.ka % c.q- , y,,;;; _ 333 Q r v:- r:p - +. a. -u l . m v.. ... m r 144 ab73 1 to any extent in the soils lah? 2 A Yes. { I 2 Q All right. ii t i To what extent, with consolidation tests? 4 In the course of both graduate and undergraduate 5 A ) 7.150 8 work I ran consolidation tests. In my experience with the t Corps I required a great many consolidation tests to be run 7 e and use the results of that to make predictions of settlement. 8 9 With regard to compacted fill I would say there would be at least four projects I have worke[ on. ~ to 1 It Q Could you name those, please? 1 C 12 A Beltsville Dam, Eine Marsh Dam, Tocks Island Dam. I also think they were run and evaluated for another dam, 13 u i 14 Trazier Dam. 4 1 15 Q And these were consolidation tests that were done \\ Is on compacted soil samples? ? 17 A That's correct. 4 1e Q Do you know what the margin of error is in running ts that kind of a test and making predictions based upon that ',i 8 kind of a test? a b. -i 21 A You would have to define " margin of error." .i j 22 " Margin of error" with regard to what? ~ I .J 1 3 lk.. .s l,'= l . - _ _ _ _, _ _ _.. _ _ _. _ ~
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.;-.~..,._.,_...,m,.,,..,,__,, ,g,j , y,. g [:. .y.. {B=m s - a Well, for predic- %g settlement,'for example, on ch74 1 Q the basis of a consolidation test on a compacted fill sample. 2 { I can only recall one of those projects where we 3 A actually had the fis1d behavior where I could compare the 4 predicted settlement with what was observed in the field, s and to my recollection it was relatively close. By '.that, I m' s think 3.t was within an inch of what was predicted.
- 4, 7
1 0 a Q What project was that? s A Beltsville Dam. 3 10 Q And whos was that? '7 1 11 A Back around 1970. 4 1 ( Do you still have any records with regard to that? .d 12 Q t 13 A No. u 14 Q Where would one go to find such? ~ .2 To the Philadelphia District Corps'of Fngineers. ts A What happened in the other places where you did [. 18 Q 17 consolidation tests on compacted soil samples? Trexler Dam and Tocks Island Dam were designed-ts A Actually Tocks Island Das had gotten to the construction plans is and specifications stage and the project was d=opped. 20 C Trexler Dam had a great deal of design completed 21 .s
- 1 22 and was dropped.
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~ = G- '? y- /;.pM.=Gi- % :7-e- . _,.,x.. ; ;Q.OjQ,g;.g. 1. r_. .N w.,..;. .,a ....s.- m 166 l 1 Blue March Dam has been constrticted but I left. the 'h, ab75 1 j { Corps of Engineers before actually doing the construction of 2 ,,l 3 Blue Marsh Dam. 4 With, regard to the Beltsville Dam prediction of Q. [2] a:1 settlement, you indicated that you believed that the predic-4 s ..e tion based upon the consolidation test was within an inch of 'i ,s wl a ai -m
- y Can you tell me what the total predicted settle-7 experience.
.1p Uh-a ment was? M. i Based on ten years dd"ference, if I remember 8 A Q-1 T.L correctly, it was on the order of 12 inches. 72] 10 ~s i And the actual settlement then was 12 inches plus M3 11 Q ?E 12 or minus one? %g., 13 A I think it was 11 inches. 4e l. u was the consolidation test done on ta. sample that w 1' Q M1 (g$ was reconstituted in the lab.. orrone that was extracted in the ts w y field after the fill was placed?
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is 17 A The consolidation test was done on our recompactec (si ry. material. Actually the sample was tested before the con-te . i, struction and was taken.from the material that was to make O
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T.it.M-hyJ}Y_ f-I. - -. :1 r" ~'M N F$$$ kfk [ Nd*TM W- .. ?%~g' g._.._w.t.w v.w . m. =. w..,y., .,,m _ _, m,,,,_. g,. (. : b w ~.~..u r u w-. -w..-~~ ~ -.-n a.w-m-.m s n -~ -~ ~~ N. ~~-~ - gn;n. ~ .~w g 2 mm = - 4 'y; " - N3 - , m ch76 1 A That's correct. I would like to indicate that that was one project 2 { where record samples were taken and samples were available 3 4 for running consolidation tests. ^ Would you expect the experience then where you have 5 Q a sample constituted in the lab to be comparable to one such s as at Mid1=nd where you would extract a sample in the field 7 after the fill had been placed and after the surcharge? s would you repeat the question, please? s A (Whereupon, the Reporter read from the record .a 10 ~ 11 as requested.) . C I would expect it to be ccmparable. 12 TEZ WITNESS: 13 3Y MR. ZAMARIN: Would you expect then that the margin of error l' Q 15 would not-Strike that, would you expect then that the margin of error ts attendant to that type of a test would not significantly 17 differ between the lab-constituted sample and the field-te 18 extracted sample? Are we *=$M *g about sample disturbance or what? 20 .A What I'm talking about is the reliability, the 21 Q margin of error in the prediction of settlement based upon 22 6 s e 0 l.- -..
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G. . a.::a l I 16f I '} d i ab77 1 consolidation tests where, on the one hand, you have a lah-1 u..a 2 constituted sample and on ths other hand you have an ex- [.'d { ,n [.v'.i.9 3 tracted sample taken after the f L11 was placed and after the
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.d Y) 4 surcharge was applied to it. ~ -i 8 A The margin of error is going to be influenced by 8' -i 8 how a ll you reconstituted the sample to duplicate the field M'h
- f1 7
conditions, and so there is no one margin c'f error. It 5l ~~ s depends en how well you have duplicated the field conditions. w s Q so you're really talking about two totally dif-N.] n 3 g] gg forent procedures when it comes to evaluating the margin of to G n 11 error with regard to a test where you've reconstituted a '-:1 ( v Pp3. : semple.with one where you have simply' extracted it, aren't 12 13 you? u .a Ps 14 A '*ou're talking about two different procedures for pg -N.\\ ts $.m.3? doing what? 1 n ;.4 l' .W' rj Q For predicting settlement and assuming a certain GJ1 ].h reliability or margin of error with respect to that predic-II
- .., I 18
~ tion. -4 $g)- 18 A If you are successful in reconstituting the sampi .1 20 .,. u. $ to be representative of what you have in the field, then to 2Q () II $.-1 me the margin of error in predicting settlement would be n l 22 essentially the same because you have produced in the lab wh M,k AE / th 4, e g s
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,.... u . _... s. E ~.::E- _ _.. c,_ _....,, n M_'- t"; c_W# ,.. fE i34.b.J.,,,,, 7.'df M-E;;.W6 - t,w.;9y. ,.pgpep.y.;4 ~ .y->: wa:=.. n,m n c.a:,..,.-. ste.: m ~..~. ,,m ,hy.,.. ..n 1 ,., -,. % w :.... - r. ,.m..,...,,,,.. ,,9 v c h.:.~M m& . +.. --g , n eb78 1 is in the field. 2 Q I see. { so in your opinion then you would not expect a 3 lower margin of error where you reconstituted samples in the 4 lab than you would where you're taking the sample in the s field such as would be done at Midland? e There could be a difference in margin of error but 7 A there are other factors, both in the lab and in the field, 8 9 which could more influence that margin of error. 10 Q such as -7 such as when you took your sample in the field, i 11 A ~C You know, if is it representative of the entire==haahaat. 12 you take a semple in the field that doesn't automatically 12 o mean it is the most representative one, so you have prob 1 mas 14 is in that regard. 18 Q okay. 17 A l that's likely to increase the margin of error with regard.o the field-extracted semple? 1s I'm pussled by the question because I think you Is A could take a reconstituted sample in the lab and better 20 represent an==hanhaat section than you can with a field
- U 21 22 sample if not properly done.
I as saying there s=a many l l L E.L.t M L I ~ i O E
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9g %, ' h-*7 J - cJ. n' .y . - L3 :...,;,.; f margins of error in all processes that you're doing. eb79 1 2 Q Is there any generally accepted engineering ( f opinion with regard to the reliability of reconstituted lab 3 i samples as opposed to extractions in the field for estimation l i 8 of settlement basud upcn consolidation test 2 j, e A I think the feeling would be that the field samples i 7 would statistically give you better results than the labora-i a tory reconstituted samples. t s Q In one of your previous deposition sessions we 18 were *=1k4ag about the 1.5 factor for the preload. Do you f Il recall that? b 12 A I do. j Q And did you refer to that as a margin of safety? 13 j 14 A No, I did not. ) d 18 Q That is not a margin of safety, is it? j te A No. I thought we had discussions where I indi-1 1 ] 17 cated it was not a margin of safety. l Q And would the 1.5 factor-What we're really 1s
- = thing about is the higher the number, the higher the ratio, ts t
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i l increase the rate of censolidation, yes. cb80 t And the only effect of stress that is needed in the f {- 2 Q soil is that which is equal to the design stress? 3 I'm not sure what you mean by that. 4 A + I s Q okay. In a prel'oad, if there was no consideration for s increasing the effective stress of the preload in order to i 7 speed up the consolidation, would you only need for that pre- >l s 4 load program an effective stress in the soil equal to the s design st=ess of the structure that is to be placed on it? to h could I add onto that "to result in the same amount 11 A 9 C 12 of settlement"? w .1 l 13 Q That's right. 1 Isthatwhatycurquestion[s? 14 A 4,; ts Q Yes, the same amount of ultimate settlement. i to A Excluding the time element, yes. And it's not customary to factor into or normal 17 Q engineering practice,to factor into that stress detem hation ta ts environmental loads, is it? It would depend on the environmental load and 'the 1 20 A p v 21 length that it would be imposed. The length that the environmental load would be 21 Q l : Y
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.y_. _w. e ~ y;.5-e - M 7z& .o.-x .c:==w L~i. Eh: -3p=-,g z.;>~ gGrSJ l g 4 ,,g...... ~ + - 2-a:.,.y;, 172 l jbn1 1 imposed? 2 A Yes. { Can you give an example of an environmental load 3 Q that would be factored into such a determination of the stress 4 5 to be a;711ed at preload? A No. 6 Is that because you just can't think of any that 7 Q would be other than of such a short duration that-8 The environmental leads I c=n f i"k of would be 9 A t=ansient and would not fit that description. to So therefore they would be factored in because 11 Q when you say transient they are such a short-ters effect that 12 they wouldn't have any real effect? 13 14 A They would not be sustained long enough to cause is the effect, to Q okay. When you're talking about margin of erro=, if I' 17 can dd act your attention to the typical settlement versus 18 log of time plot, would you consider the difference between ts the predicted settlement based upon the assumption that a..; 20 surcharge would remain in place over the life of a structure 21 and the settlement that would be expected under a lesser 22 MEdI9::-eL ~ \\ 9.
. 'I' ~ 7.,. . g. e m s. . -m y m....,,. G -.w.r =.., e. n n. _..n,,,a.... y .. y.. * ' ~3. m;.,: ty3 3.;cm, ~ a- + lead, that is, with the surcharge off of the structure, to jbn2 1 be a factor of safety with regard to the predicted settle- }{ 2 ~ 3 ment? i I wouldn't consider it to be a factor cf safety. 4 A I would consider it to be an additional margin of safety. s s Q In your opinion is the diesel generator building - the soil beneath the diesel generator building at Midland 7 a presently in primary consolidation? s A. I don't know. m 10 Q Would you expect an observed settlement of no more ' }4 than about.1 of an inch from the time of the surcharge E 11 eC 1979, through September of 1980, to be - 12 removal in August, . a. 5 consistent with the soil beneath that structure still being 13 u 14 in primary consolidation 7 w There are saveral considerations that you must ts A 1s' agree on before you can answer that, such as has the load, .~ t the final structure load been imposed,that entire time, 17 ts whether there could be any conditions that could develop that could cause a change and lead to additional settlement, ts 20 and there I'm referring to saturation zones that were not ) previously saturated and the offact that has on consolidation. 21 ~ l. Excluding changed conditions and assuming that 22 l YN $ne. 3 \\ .....-x.,,__,...m,.._.,....yw 3m -._..-,_,---._.-_,.-,-_,,.n.---.~.--. .-.,_~r, .--3,.., - -., - -,------.y-
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C. ,,. -.a. .. c.n'? ' ~, - i I l 174 L full load has been applied that entire time, than that settle-jbn3 1 ment that you have indicated which is - what? - one-2 { 3 hundredth of an inch? 4 Q One-tenth of an inch. t - one-tenth of an inch over that period would be i .5 A indicative of being in secondary consolidation. a If the load of the structure, the diesel generator 7 Q E i a building, during the period of August, 1979, through Sercember of 1980,was within 250 pounds per square foot of its final 9 stru m al load and that 250 pounds per square foot repre-10 senting the live load and there was no condition such as the lC 11 saturation zone which you described and the structure had 12 experienced no more than one-tenth of an inch settlement 13 u during that time period, would you still be of the opinion 14 that that would indicate that.there was secondary consolida-ts 18 tion? 17 MR. PATONr I'm sorry, *would you still be of the i ta opinion"? 19 MR. ZAMARIN: It was after his other answer, I a 8 added the- \\ 0 v .\\ 21 MR. PATON: Okay. 22 TIE WITNESS: The difference between this question ii .i
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7.,, and the previcus one is the 250 pounds per squ'are foot? jbn4 1 { 2 EY MR. KAMARIN 3 Q What I'm asking you,is that wouldn't change your answer to the previous question, would it? 5 A No, it would not. 4 I would like to clarify that. You did say it 7 included live load? s Q The 250 pounds per square foot is the live load. s A Is the differtnce, but that difference is based 18 on dead load plus live load? 11 Q That's right. 12 x That.'s correct. 13 Q In your opinion, in accomplishing a preload program ( i u 14 such as was done with the diesel generator building, would ts it be better to raise the cooling pond level as the load is to being put on rather than prior to imposition of the load so 17 as to shut down or close voids in the soil before water is put in and thereby effect more rapid consolidation? A It's seems to me that was a question that was 8 asked of me before. () 21 Q Not with all these factors all in one question. l t A could.we go over all the factors again then? 22 t set t 8 t 9
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2 In your opinion, is it better in a surcharg's 2 program like the diesel generator building to raise the cool-i i 4 ing pond level as the load is being put on rather than rais-l 5 ing the pond before the load is put on in order to shut down i 4 or,41ose the voids in the soil before the water is introduced 7 and therefore effect more rapid consolidation than you would s a have if the pond were firsa raised, the water filled the t l e voids and then had to be squeezed out? 18 A I still don's think I have the whole question. 11 Q Do you went to tell as what you have, or do you it want the question read back? 4 12 MR. SAMARIN: Why don't you read the question back? 1' (whereupon, the. Reporter read from the record j 18 as requested.) 1 J 18 TIE WITNESS: I don't know whether it's the time 17 element or not but there are se many considerations in there l to that I think I would have to write them down to understand i 18 the variations that you're giving me and to make a judgment on that. b I 21 gy gg, ggggggy, l Q okay, let me give you the two vart.ations because 22 4
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,.,.). ,.3 what I'm trying to do by giving you : sore factors is to demon-I jbad 2 strate what I perceive to be the r.echanima that would go on, { 2 and that is if you raise the level of tae pond first, you're goiaq to fill the voids with water and then you've got to / 4 squeese is out whereas. if you raise the level as you are s applying the load, the voids will be closed before the water e 7 is introduced and you don't have to squeese them out later. 8 So let me just ask you though, in your opinion, ) is it be,gter from a geotechnical engineering standpoint to 8 to have raised the cooling poid as the load is being put on, or 11 would it have been better to have raised the cooling pond C 12 gig,gy '8 A It would have been better to have raised the cool-o 'd ing pond first. ts Q In your opinion, would that have then caused volds to fill with water which them would have to be squeezed out? 17 A Yes. Q And la your opiales would that then have slowed down the comme 11dation prose,sg7 A Squeesing the water out of the voids slows down the 38 l { process but the reason you would raise the water is because 88 of its impact on the b savier of the soil upon saturation, e 5 8 9 9
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'T' -- -,.M 17o " ~ ~ - f.-a jbn8 1 saturated, then you're not squeezing out water but you're { 2 squeezing out air, and the water attempting to enter and do 3 what it has to do to make it settle more rapidly is com-4 peting with air trying to be squeezed out. C7 s The saturation action is preme*4 g greater settle-l 6 ment than would occur if it were d I and if you are squee:ing e 7.600 7 air cut of the same voids that the water has to get in:to a cause that condition., then I think you have slowed down the 9 ultimate settlement that will occur;;under full saturation. n 10 Q So what you're saying is if you're squeezing air 11 out that that's going to slow down the process because that - C 12-then wi$. be exerting a pressure against water that is 13 attemp+4*g to fill it and that would be a worse case than u l' if you had the voids simply having water being squeezed out? 18 A I think it is a worse case if you have a soil which to is susceptible to significant settlement upon weight, yes. 17 Q And in your opinion is the soil under the diesel ts generator building susceptible to significant settlement upon 18 weight? 20 A In my op4"4on, I don't know. I don't know for sure. g - 21 I think it has the potential if it were placed dry; if the 22 fill were originally placed dry then there is a potential for i AdM& cTna. ~ 9 =--,A.- ,...m,- e e ,..-w=- w --y ,-.,,wy.---- m w. -w+ ,.w.,
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_,,.,:_~ s. l 5on l 1 significant settlement. jbn9 What soil parameters control the significance of { 2 Q 3 the soil for settlement upon weight? It has to do with the particle structure and how 4 A 1 that behaves upon lubrication frem wet *d"g and how the soil 5 a reacts upon that wetting. I *ki k I can give an example of a loess where unsaturated, it could accept a great deal of 7 loading without settling, but upon wetting will actually a That's an extreme. collapse,and significantly settle. e I think it is recognized that some fills, when 10 compacted dry, will tend to irdicate a lesser degree of 11 12 settlement. We don't have anything like loess at Midland, do 13 Q u M we? 15 g ya, Do ordinary clays such as those normally found at 18 Q Midland --h4Mt that kind of loess-type behavior that you 17 18 just' described? De ordinary clays other than at Midland? 18 38 A No, no, like those found at Midland. Q (J Exhibit the behavior such as loess? 21 A Q Yes, that you just described. 22 ~ o s. S ,n..-
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s that the diesel generators would be operated to supply that 5 8 lost power. And what is the function of the building? 7 Q To protect the diesel generator. buildings 8 A and pres.erve them in a condition so that when they are ready a 10 they would properly operate. 11 Q I think. you said to " protect the diesel generator 12 bn W 4 g." Do you'mean to protect the diesel generators? 13 A Yes. o l' Q And,by that you mean to protect them from the 15 elements, the weather? The. elements. 15e foundation of the structure to A 1 would be such that it would be stable to where the diesel 17 generators would be kept at a level to where they would 18 to ep,,,g,.; properly. l 20 And the generators themselves are founded on Q (' l l pedes als. Isn't that right? 21 22 A That's right. \\ M. Gt ! M L. ~ i f i
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~ f,.?W=shm~ , ?;. .~ %>c 3_ g 3 . v v:. ... ~ m 1 jbn12 collapse. 2 Q In your opinion has that occurred? {- 3 A Where? Q In the diesel generator building. Eas it collaps.ed in the diesel generator building? 5 A 8 Q Nc; that overstressing. That is not my part of the analysis, my part of 7 A a the review,to evaluate the overstressing. Q Do yee have an opinion as to whether it has or 9 t o hasn't? 11 A I have no opinion.. --C Q Are you aware of any problem with the diesel 12 13 generat== pedestals? u A The problem with the pedestal. are similar to the 14 foundations of the wall footings in that if the wall foo* gs 15 are settling they could also affect settlement of the pedes-is 17 tais. 1s Q How? i By causing one area under the wall footing to 19 A settle, it.could lead to settlement under the pedestal. / t' / Is there any indication that that has occurred or 21 Q will occur? AEd JM eL ~ i l e W u----* 9%%
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4 ~ .n,. . ~. r, a. ~ , oc 34 22 :w.~w [ wb 1 CERTIFICATE OF NOTARY PUBLIC AND REPOR*ER ,{ I, William R. 31oom, the officer before whom the 2 l 3 foregoing deposition was taken, do hareby certify that the 4 witness whose testi. mony appears in the foregoing deposition 5 had been previously duly sworn; that the testimony of said a witness was taken by me by Stenomask and thereafter reduced 7 to t.r,powriting by me or under my direction; that said a deposition is a t ne record of the testimony given by said 9 witness; that I am neither counsel for, related to, no 10 employed by any of the parties to the action in which this 11 deposition was taken; and, further, that I am not a, relative -( l 12 or employee of a=y attor=ey or counsel employed by the parties l 12 hereto, nor financially or otherwise interested in the outcome u 14 of the action. 15 n 1/\\-A // /f ,,y,4 y 18 ., y W. R. Bloom 17 Notary Public in and for the District of Columbia la 19 My m mi<sion expires 14 August 1985 20 F. i i 22 S i O}}