ML20090A901

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Deposition of Jp Matra on 810107 in Bethesda,Md.Pp 1-113
ML20090A901
Person / Time
Site: Midland
Issue date: 01/07/1981
From: Matra J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML17198A223 List: ... further results
References
CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8102270042
Download: ML20090A901 (117)
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.. z s,.. p. -( ;.2 ; m.- ~.... vi-- Transcript of Proceedings UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOT _ _ _ _ _ _ _ _+ In the Matter of: CONSUMERS POWER COMPANY Docket Nos.: 50-329 OM 50-330 OM (Midland Units 1 and 2) 50-329 OL - - - - - - - - - - - - -+ 50-330 OL e DEPCSITION OF JOHN P. MATRA,'JR. ' Bet:hesda, ' Maryland Wednesday, 7 January '198f ~ ~ ' ACE.FEDEIIAL REPORTERS,INC. l pa,p.,,,,, l AM North Capitol Street ~ ~~-- ~ ",'~ ~ " Washington: C.c0001~- - NATIONWIDE C.OV_H_.A.G..E DAl(Y._...... gm3 37.pon Nh* a.._.. ..s..,g .v

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4 In the matter of: 5 CONSUMERS POWER COMPANY Dockets Nos.: 50-329 OM 50-330 OM 50-329 OL 6 (Midland Units 1 and 2) 50-330 OL 7

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3 DEPOSITION OF JOHN P. MATRA, JR. Bethesda, Maryland 9 Wednesday, 7 January 1981 to Deposition of JOHN P. MATRA, JR., called for 11 examinatien by agreement of counsel, at Room P114, Phillips 12 13 Building, 7920 Norfolk Avenue, Bethesda, Maryland, at 9:00 a.m., 14 before William R. Bloom, a' notary public in and for the 15 District of Columbia, when were present on behalf of the respec 16 tive parties: 17 On behalf of the Applicant, Consumers Power Company: 18 MICHAEL I. MILLER, Esq., ~Isham, Lincoln and Beale, ' (@f.'3(, 19 One First National Plaza, ' * " ~ ' " ' '*DhIcipo, Illinois 20

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.s s 2 f wb 1 On behalf of the Regulatory Staff: 2 BRADLEY W. JONES, Esq., Office of Executive Legal Director,. 3 United States Nuclear Regulatory Commission, Washington, D. C. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 l .. h :. 19 l .. r 20 . r. _.:.... s-.. v... \\ I 21 nu-O- 22 at 0 m gn

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II.jb],..pf73. - _%.?gL - "],l'-;l[7M e.:.7g2.w ; };.. <- - s-m { m w. ~.. I 5 eb2 1 (whereupen, the document 2 referred to was marked as 3 Matra Deposition Exhibit 1 4 for identification.) 5 BY MR. MILLER: 4 Q Mr. Matra, looking at the second page of your 7 resume and experience it says from 1953 to 1967 you were 8 employed by the Glen L. Martin Company as a structural en-8 gineer. Is that correct? 10 A That is correct. 11 Q And what were your duties generally as an employee 12 of the Martin Company? 13 A I did a number of things. I worked in the design-14 and analysis of the P5M canberras basically aircraf t and 70 j 15 missile work. te Also I worked in their Research Department, 17 mainly dealing with structural problems. 18 O What sort of structural problems? 18 A Being an aircraft company, it was an aircraft. .' type or aircraf t-related problems, both thermal, non- '21 elastic, noh-linear type. 22 Q Sir, would you describe for the record what the %Gt IWL

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3 weapons, from the ship, in other words, to the air. 0 I take it it's a branch of the Department of the 4 5 Navy. Is that correct? e A That's correct. 7 Q And about how many employees does the Naval Surface 8 Weapons Center have? 8 A I would say about four thousand. 10 0 Are they all located in Silver Spring? 11 A No. Some of them are at Dahlgren, Virginia. 12 Q Is Silver Spring the headquarters of the Center? 83 A Dahlgren is, Virginia. l' Q And you've been employed as a structural engineer II at the Naval Surface Weapons Center from 1967 to the present? I' A That's correct. 'I Q And'what have your duties been at the Naval Surface I' Weapons Cenher? +- It A Agai'n as'a strhetural analysis staff and more or less workiEh on.'the' more alfIiedit

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b.: s s a L.y W -r 7,2x '.C % c -n- . ~.... x - :S-G.ji' 3.g3 y.-. .-..~:- mu-a.,;u 7 cb4 1 a building or anything else that comes up. 2 Q "Now since 1967, how many structures, buildings, have you been involved with in your duties as a structural 3 engineer with the Naval Surface Weapons Center? 4 5 A Buildings would only be for example the housing a for some of the electronic movable type of transportable type that we worked on that would be housing electronic 7 equipment for moving from one location to another in an emer-a 9 gency. 10 0 What is the approximate size of these buildings? 11 A I would say about the size of a large trainier. 12 0 And would you say that the bulk of your work for 13 the Naval Surface Seapons Center has involved structural 14 engineering problems related to weapons systems? 15 A Weapon system, yes, that's right. Basically that's 18 what our function is, but we handle all types, or we're 17 capable of handing all tyrgs of structural problems. Is 0 Now I see that.you majored in structures at 18 Rensselaer Polytechnic Ntstitute whenjyou received your 20 Bachelor's degree of aeronautic.enginehing, = - 21 'Would you, describe,:for,us cliei,c.ourses, if any, 22 that you had involving strength of materials? . W.O 9 a E/ I4& I L

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9 20 L' r e.ve;.taken courses using.-- well,,in-no n.-line ar mechanics," for example, some, courses;in-hg ;Ohy.I:. forget..I'm l 21 t 22 trying to thin)c.of the proper word, using Kronecker deltas. l %ER% 47-l i ~ .L

bl ' ' e s g w,.g. % - .b."'$$,*;-,, '_,' ]; -]._ '-' ; =4h-.[9=. e' ,Ma*. I]* *'" *'* * ~ f m. .j e m .r.. ' #0d .M. o cb6 1 It's a shorthand form of structures. 1 2 Q Would you spell that, word for the Reporter, please? 1 3 A I believe is is-- I don't know the exact spelling. 4 I'm just guessing here. It's K-r-o-n-i-c-k, I think it is, i - 5 but I'm not sure. 4 What the devil do you call that? Variational 7 calculus techniques using Christoffel's symbols. 8 Q Mr. Matra, do you consider yourself to be an expert 9 on the strnegth of materials? 10 A I consider myself to be an excert in structures, 11 structural analysis and design. 12 O And does part of that involve analysis of strength 13 of materials? 14 A They go hand-in-hand. You must know strength of 15 materials to do structures. 18 Q So you do consider yourself to be an expert then 17 in strength of materials? 1s A Yes. e., I l, Now in an idealized. situation will you agree.that.:n.7 19 Q 20 additional strain on a material.c.auses additional stre.ss..,... ; :-.g,- - < v.. 21 until the yield point of.the material.is reached?,,,, 22 A .Ye s., g., M:- ' ^ - - x g 4 e

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You get greater elongation when it does resist 1 . b *.f... f *..- 19 lead. t.te e n And it's approx'iinately equal-n.,. ?? eIts : ability to 20 0 .. f. v. .t ~^ r,esist load rem'a'id apifo2idately 'e@il' to its 'abflity to. 21 q, 22 resist load at its.y'ield 'p'oist'.- Ii'that correct? i f Abadaol& Sne. l

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X.>-~.,.- . w;. x ..<.~,; n. 5 [ '3' 3...- y..;..,. ' .z.,, ; a.* ..., n e Si 1 A What's your question again? eb8 2 Q All right, that the material retains its ability ' ~ 3 to resist load once it has passed its yield point at approximately the same level, if you will, as it was at its 4 5 yield point; that is, it's a straight line? 8 A Yes, a straight line. Okay. 7 Q All right. 8 Now for reinforci.g bars used in reinforced con-9 crate structures, would you agree that the point of failure 10 of those reinforcing bars is about one hundred times the 11 yield point of the material. - the yield strain of the 12 material. I'm sorry. 13 A You're asking-- I still don't understand your 14 question. I'm.sorry. 15 0 okay. 16 Well, as a certain strain is applied to a rein-17 forcing bar it will reach its yield poin't. Is that correct? Is A That's correct. ~ gg ....i/ Q All righ.. And then will you agree' T. hat 'it would 4 akbappi xi Uf . 20 t .... v.. 21 mately a hundred times that forc's b'eyiind its y'ield point ir 22 e' yield strain -- I'm sorry -- before fa'ilu're occurs?' AEN& SN l 1 m.

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c $ {/, ~/ " # ~ * -. :. 2 :s;. -...a.:.. v -...-.. w g .2,..u.- s.,.h c.u. .g .,.._.....,,,,,...s. gj. 3 i :.... _ 33,,; mm 12 cb9 1 A You're talking about the strain is a hundred times? 2 O Yes. 3 A What type of steel are you using? I mean you. 4 haven't defined the-- You're just saying they are bars and 5 there is steel in there. I would want to know more about the e conditions that you're talking about, and then analyze it in 7 that respect. a Q Let me see if I can be a little bit more specific. 8 I hope this will be helpful. to It would be the' normal rebar that is used in high-11 strength reinforced concrete structures. 12 A You're saying approximately a hundred times. I 13 don't know the exact number but I know it's greater. Okay? 14 Let's put it that way. 15 Q Would you say it is substantially greater? Is A You get quite a large elongation. This is what 17 you get wher, you get a large strain, basically.is.what you're Is saying, I think. Q - Now once this material, this reinforcing steel ' 'ts z' p ' 20.is past in.yis1d point, nonetheless as stress is reduced 3 21 the strain ~is reduced. Isn' t that co rrect?..,'..., 22 A once-- ......f. . W bb$ sd g (

..;,r. 7,.ya,;y ; :ns ~f-C -6 d b Q.5; n.;.,-._ G y J. " ~' }.:, Q ].5 ,,.m. -, ~.. t1 cb10 1 Q once it's past its yield point but it hasn't 2 failed, as stress is reduced strain is reduced correspondingly, 3 Isn't that correct? 4 A As you reduce the stress? In other words you're 8 taking the load off of this? e Q Yes, you're unloading it. 7 A And then you're saying it is going to go down, but 4 it doesn't have to go down the same path. It's going to go 8 down to a certain way and then go parallel to it, so you're to going to have some permanent set. So it depends on where you're going, what you're talking about. 12 How much'is another question here, is when you 13 reduce it it depends on-- You're talking about your stress / J strain curves here', I'm assuming. 14 Is Q That's correct. Is And would you agree that the stress / strain curve will be appr'eximately parallel to the stress / strain curve U beforethe/ieldpointisreached? te A des', 'it's goiN to come down and then parallel. I' lP 88 ~ af They're not *goi'n't to'he to the same line. 21 g gut khey' kill' b'e essentially parallel. Is that. 22 3' .j. ,,,,,,gy M ale.l & L \\ S 4 m.... m... .m a

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...,,u an' 19 ebl6 1 Comanche Peak Nuclear Plant Projects, had you personally ever 2 been involved in the design or analysis of a nuclear power 3 plant? 4 A Not a nuclear power plant. 5 Q All right, sir. 8 Would you just describe for me -- I'm a lawyer and 7 I don't understand this -- what projects in your background a you believe are most analogous to the design effort involved 8 with a nuclear power plant? 10 A In my background? 11 Q Yes, as far as the structural. 12 A The structural aspect, whether it's a building, 13 a'n aircraft, or a submarine, I don't think it makes that much 14 difference. A structure is a structure, and stress is stress 15 and strain is strain. 16 Probably the only differences that I could see - 17 in my particular analysis, you must consider:your soil, your 1s seismic type of analysis if you're to run the ' spring con-l ~ '8 'stants that you use. But other than that, I think ths . analysis ii practically the same. .F.u r.# 5e t 21 ..:I don't see-- If you can do structures. work *. s.. ;. 5- ~ 22 you're just' putting in different material propertissP.~ t:?.4.9 3: M.,2.J t M eL. -. ~. >w --~--.~e- ,.--n,,n_e,e-, ,,. ~., x - x-- w-

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= ' - 21 sbl8 1 Q Now Mr. Matra, we touched generally on your quali-2 'fications. Are you a member of any professional societies, 3 sir? 4 A Yes. I'm a member of Gamma Alpha Rho which is an 5 aeronautical engineering honorary society, and I belong like 6 to the Arnold Air Society and the American Rocket Society 7 or something like that, and the Institute of Aeronautical 8 Science. I didn't put it down there, nor all my publications, 8 other than my thesis. 10 Q Okay. 11 Are you a member of any committees of the ASME7 12 A No, I'm noc. 13 Q Are you continuing your course work at the Uni-14 versity of Maryland for your doctorate? 15 A Not at the present moment. I probably will, but 16 I stopped for a while. I'm trying to get a doctor's in math,. L 17 in applied math, is what'I'm trying to do. 18 Q There are two papers that are identified as pub-18 lisned theses. .~. 1! ad r : %-- Y= re. 2/.i ".m. s A' Yes. ~ c ru r. 11 7 10 Where were thdsaf published?'.Were they just. pub-22 lJ, j lished by the institution that you attended? l I hee $ N $ne. .t. +

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. % - ; Q L Q 3 - - 3..-- g 3 Y~ ,9 fw.l 3: 7 . w. ;,q.. - '^ 'r.. ..g 23 eb20 1 Q Well, if you can give us the titles maybe we ought 2 to do that if you can. 3 A Okay. One dealt with a reentry type vehicle. 4 This was done at the :urtin Company when I was there, dealing 5 with heat shields and the structural analysis of a heat 6 shield and its attachment during reentry. I think it is a 7 Martin RM report. It's an HTC report, high technology -- and 8 heat. 9 There's another one just recently -- well, not recently but within the five years which would be on laser 10 11 damage type on a structure, let's say. I'll put it that way. 12 And that's about four different volumes, and that one is 13 classified. 14 Q But none that are available to the general public? 15 A go, 16 Q Can you describe for us how the Naval Surface Weapons Center was selected to perform this work for the 17 18 Nuclear Regulatory Commission? 18 .A ,Yes. I think 't' hat we've done other work for 'them'/ ' ' 0 ~~ ' U " ' '- N- ~#

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20 '~' with respect to-- C 21 (--.Q You ~saf "~we,"' but no.t you personally?: ~ c.-. . A, kell,- the, staff'W I'm referring to th'e*Stiructural 22 s --.a-m NNs-e=s y

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. m.~,. . = - -.. ._y , u.. 25 ab22 1 whether we could help on this particular task. 2 Q Did he contact you or Dr. Huang? 3 A He contacted myself in this case and then I in turn contacted Dr. Huang and our particular chain of command in 4 5 the Naval Ordnance Laboratory. I this case it was Jack Wack. 6 Q Will you describe for me generally what the chain 7 of command is in the Naval Surface Weapons Center? 8 A Okay. Well, we have a department and then under the department comes the division, and our Structural Analysis 9 10 staf f reports to the division head. In this case it's Jack 11 Wack. And we ourselves do all the structural work basically 12 across the Lab. 13 That would be any other department, any other division, any other branch which is under us, and proceed 14 15 from there. We are on the division staff, I guess is the way 16 it would be. 17 Q And where does Dr. Huang -fit in? Is he Mr. Wack's te superior? 18 A lio. Dr. Huang is mo.re or,less the' head of,.the 20 staff, the head of the Structural 3 staff.

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==.% w 28 eb25 1 that the Regulatory Guides.have been met, and read both the 2 Regulatory Guide and this, as well as with direction from 3 the Nuclear Regulatory, in this case Frank, to say "Look at these things, look at these," and decide our own particular 4 5 judgment in the particular investigation, s Q And will you describe for me in general terms what 7 your work, if you will, has consisted of on the Midland Plant, 8 what you've done? 9 A Well, the first thing I did was try and get the 10 Final Safety Analysis Report, read anything pertaining to 11 the structures part of it, compara those with the guidelines 12 set out by NRC, did they meet them or didn't they meet them, 13 or anything that we didn' t quite understand, we more or less 14 sat down and wrote ourselves questions. 15 Once we completed this we.then wrote an FSAR and 16 then put some questions on this. 17 Q FSAR or Safety Evaluation Report? 18 A Safety Fivalu'ation Report, this one. 2 Q Okay. '- - 19

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l ~4. v.. e.o.H'- 29 cb26 1 asked, like when they were talking about particular problems 2 they were h'aving. 3 I'd like to say that we basically, when I say the Naval Surface Weapons Center or the Structural Analysis 4 5 staff, got involved in this more or less last February. 6 Q Yes, that's understood. 7 A -- so a lot of this work has been done. And then 8 we were just catching up and trying to pick up the pieces, 9 in other words trying to understand what's going on and what 10 are the problems, if any, so that we can help. 11 Q It has been 11 months. Do you think you understand 12 what the problems are? 13 A I believe we understand what most of the problems 14 are, yes. 15 Q Now have you ever had a talk or any c cnversation at 16 all with a man named Mr. Lipinski, an employee cf the Nuclear 17 Regulatory Commission? 18 A I know of a Mr. Lipinski: hI have talked with him, but basically; not in regard to tlie Midl'and.. Most of my 19 conversatic'n.was with Frank Rinaldi. -;A-f Mc r.rf f.* C '. : 20 . Q.. - Q Now I see that. youi.liave Ethree b'1'ue ' bin'ders sitting 21 22.. I' '~ r ,.there.. , u.sr.r:. L6.4,.I%,8, l . ~.

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2;;.,. e I 35 cb32 1 were changing and walking around. It was just the person who 2 was closest to me. 3 Q Do you remember the names of any of the individuals 4 from Bechtel or Consumers Power Company? 8 A No, I don't. 8 Q Was Mr. Rinalgli with you at all times during the 7 tour? 8 A Well, he was there, but not personally with me. He 9 was also going around. 10 0 ifas Dr. Huang there? 11 A Dr. Huang was there as well. 12 Q All right. 13 Now do you recall Mr. Rinaldi, during the course 14 of the tour, remarking that the cracks in the diesel generator 15 building were not as large as he had expected them to be? 16 A Mo, I don't recall that. 17 Q Ifas this the first time that you had ever been at 18 a nuclear power pl' ant? ..... x, 18 A Yes,-it was;. :i..m Did' you'obse25reacracks :in7c'ertain of the structures? 20 .,:.;.. C2 0 i 21 y,,., Isdid observe cracks in structures. Some of g l 22 ,2.03,0 these cracks-- I mean if you're ' going to build any building m Et.,.t M L , g. y

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.;a v .c. 39 eb36 1 But I'm leaving this, you know, to the soil people here. If 2 the dewatering system is okay I'm not going to argue with tium 3 0 I show you a document marked yesterday as Rinaldi 4 Deposition Exhibit 7. 5 (Handing document to the witness.) 6 I call your attention particularly to the matters 7 that follow the first page. 8 A Yes. 8 Q Did you prepare that? 10 A I prepared most of this document. 11 Q And could you describe for us what those requests 12 represent? 13 A At the time when I first wrote these particular 14 questions, these were questions that arose when -- upon read-15 ing the F3AR and attending that particular meeting at Midland. 16 And the questions I was more or l'ess asking myself to get 17 answers to so we could eva16 ate'incre or less the buildings i 18 and the work a lot more effectively. 18 ? Q All right. ~ l c.-0.4 20 fir. Matra, tha't do'cument is ' difed' cit beife've"in' R i i 21 ' C '" ~~ 2. E - - - ? ' 2 ' -' '- - - ~.. - - -. October of 1980. s l ~'~ l 22 That's corre't@.'--- -'- ~~ '."-~ ;.I 2 ~' A c' ASU Sne. A wr

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^. s ~~*~. % .!; Q: s 40 1 Q Between February 1980 and October 1980, what were cb37 2 you doing with respect to the Midland Project? 3 A As I said, I was reading the FSAR and preparing * -- 4 getting this thing (indicating) up to date. i 5 Q This thing is --? 8 A The Safety Evaluation Report. 7 Q I see. 8 Approximately how many hours did you spend between l i I 9 February and October 1980 on the Midland Project? 10 A I'll say about titree-quarters of my time was spent 1 11 on the Midland work. In other words, I had other functions i 12 to do. 13 Q Okay. l 14 But your primary task during that period was the 15 Midland Project. Is that right? ] to A That's correct. 17 Q And did you meet with Mr. Rinaldi'during that time 18 i period? r -- t. ' - 8 A Yes, we did. ? ,-Q About how frequently did yoti meet..with him?.. 1 21 A I think maybe once every oth'er week, more or less - 22 to see where I am and what I'm doing.'d y' ' 'T I l O A.0 e. e4. ehw+=r ...wa

cyc %::~ - NY- , n.% ..u NSlO2;QD: 13.&Q* Y~ {. <s},[5 m. a.. 41 i cb38 1 Q Now Question Number 5 of numbered Paragraph 5 on 2 page 2 of the attachment actually to Rinaldi Deposition Exhibin 3 7 refers to tension field data. 4 Could you define those words for me, please? 5 A I believe so. In a structure let's say you get e a bending, let's say something is bent or bending, you get 7 a tension side and a compression side. We're talking here e the tension field in the tension side. What are these values? I 8 In other words in the case of-- Let's say you 10 have concrete and you have steel bars in there, and the steal 11 in this case is going to be taking the particular load, so 1 12 what tension load is being picked up locally by the steel bars, 13 in tension, that is? 14 Q What you're asking for is the amount of the load 15 that the steel would see as a result of differential settle-14 ment? 17 A Right. This pertains to a crack analysis. W :S l' ' crack is okay as long as it does not continue to propagate.- 3 to And what I'm saying here is: Show us that it will not propa-gate, will not'c6nt'inue to crack. " r '2 21 Q I take it that crack propagation indicat s' tlia't?~ N 22 additional strain is continuing to be exerted-- &dM&& .n,. ii

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.e.93.y;,. " 3.:94&~...s:, - c- - ~~- .e5..., r" ls [ g<.~ s, 43 As a struct6ral engineer, Mr. Matra, are there 1 Q cb40 s recognized'tdchniquesbywhichthistensionfieldcanbe 2 3 measured, to your knowledge? I believe' there are recognized techniques in 4 A '3 E' which they could be obtained. A lot of this is going to depend on the sophistication possibly in the model that you 6 have to get thi[iut. -I don't know the type of model. 7 8 If you have, for example, a good maybe finite- ). element type nodel or'ythree-dimensional model, the more 8 dimensions the greater the cost to run the particular analy-10 ~ Buh I believe that we -- when I say "we," the Struc-11 sis. 1 tura[1 As.tlysis staff in this case -- coukd raccmmend a solu-12 tion to you, but I can' t tell....In other words, I cannot 13 w tell how to run their analysis or anything to that effect. 14 3 s 15 'O' Yes, sir. 16 But I want to know whether- } If they come and ask.~us,#" Gee, how will you do it?" 17 t." -. - -. 3 %s T' .t8 I could recommend a technique;fri!-which, yes, it can be done.

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%W = i;u ,..r<. 4 47 eb44 1 described in the response to Subpart 4 of Question 40? You're saying is that a form of tension field. 2 A Let's say there's a crack located in 3 What I was after here-- a certain part of the building and what I would want to know 4 then, what is the tension field loading in that area of the 5 e crack? You don't tell me that here exactly. You're talking generalities here more than specifics. 7 (Whereupon, the taking of the deposition was 5 recessed to reconvene in the Library of the Maryland 9 10 National Bank Building.) 11 BY MR. MILLER: that as 12 Q Mr. Matra, you do understand, do you not, far as providing tensile strength in the structures at the. 13 Midland Plant, credit is only taken for the reinforcing 14 15 steel in the structure? 16 A That's correct. And therefore, in determining'.the loads that have 17 Q been applied to the structure it is loads;that are applied -- 18 tensile loads that are applied to structural steel tdiatafe' 4 - ' 18 2. 2,. _:. . ;gp. :,. . 20 .the' focus of the analysis. Is that' dor'recE? -i '- In the analysis you haire performed I:b&l5.evu - that 2). A i 'E~ ~Y 1 *t'"I h:.- W?':4 ? :* ' (- is correct. i g),,g.j,,,s %g,,;.... x + -, +,, +wy_

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".... ' = J:n.~., " ' ~. = - nM2::~~~.7:1ri W ' W h$iu-5 QQ[s:.l'.:. _s.= - *''.c u x.s-.. n.. w..,..,, ....---~._:._..,. _,4 %. c.e.. ,c,.,. y ~~ '~ f~ fC** w.ma - - so And that is the basis on which an evaluation would cb45 1 Q be made by you as to whether or not the structure is ade-2 quate from a structural engineering standpoint -- isn't that 3 right? -- as far as tensile loads are concerned? 4 5 A You mean on the particular building you're analy:- ing,in this case one of the Midland buildings? 6 7 Q Yes, sir. 8 A There's more to it than that. Let me say that you have a particular building in which you have part on 8 10 solid ground, part on fill. Your original analysis possibly 11 was done on an all-solid foundation and then you found out 12 that there was a fill. So you perform another analysis, and in effect I 13 think you've done this with the service water building, and 1' ycu show that it was cracks and you can get, tiell, like it 15 16 exceeded-- Your building has a problem, could have a problem. 17 In fact this is what I read in one of your particular., - :.I l l forget which one it. was off-hand. .a.- 18 19 ind in this case you're changing your basic. 20, boundary.c5nditions and therefore you're changing your3 problem.- 21 :Therefore,[you could have tension loads where you. don!.t..ex :, ,pect them. I :nean-- And it's for these reasons I.think you 22 S) 44 Ih d s.:,..~ l e

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3: p,._; x :: u r ;- ?.-, g ;g s.. . x. 49 should rerun an analysis of that particular building. I'm eb46 1 2 just giving an example. So there are other things that could come into the 3 reason for asking for the tension fields in certain areas. 4 You've got to look at each building and each particular 5 a problem independently. 7 Q Well, let's assume that the tension field analysis in the form that you generally described it was run for each 8 9 of the structures at the Midland site. Would that give you information concerning the concrete or the reinforcing steel? to 11 A For the tension field I'm after the -- and the 12 reinforcement, if it is reinforced concrete, then that would 13 be what the tension -- what the steel bars would take basically because that's how it's basically designed, if I'm 14 15 not mistaken, in this case. to O That's correct. 17 For a tension field analysis, though, you would s have to analyz.enany cracks that might exist in the structural 18 18 steel itseIf..- Isn' t thad.-right? 3- .*/I.'meafter--In th separt cu ar case in your crack y,e 5 i i l 20 A 21 area you de'n;' t :hav.e..to have-. In fact you can't tell me 22 whether the;. steel is cracked or not. I mean it's embedded . g..,... ne.

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51 i 1 would get so great that the reinforcing steel might fail. Is cb48 2 that right? 3 A This is correct. 4 Q Are there criteria which are generally accepted 5 by structural engineers to establish when a crack is propa-8 gating or not propagating? 7 A Are there criteria? 8 (Pause.) 8 Other than you mean visual, or analytical, or-- to Q Either one of those. 11 A Uell, there's the visual. You could measure it 12 and see whether it is enlarging. That's one particular 13 technique. 14 Analytically, kn' wing the particular properties of o 15 your particular material and when they exceed -- well, you go 16 into the plastic range and everything else, then you can I determine there's a possibility that it can, continue to crack " or not. It, depends on-- That's why I wan.t.,these,tey ion " field values'.'. .fn i s,: -..L..e..,:cd. - .s 20 You' get so m' ch alongation..becande,.ci?.the extr.ac.:.. m u 21 strain so what happens to it? It's go.t.toreither,.open up the .r 22 crack, or what? . ;. - i..., I h Mhm [ne. ~ 4 m-+

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\\ ...s. .... ~ - - :- s.. 53 l l 1 crack propagation? eb50 This could be different for every.. structure now. 2 A 3 Let me - In terms of the value. 4 Q You're talking in terms of 5 A Yes. In terms of-- You're saying a certain width crack, but then a magnitude here. I would want these more or less substantiated by some sort 7 to back up your particular.... 8 of test or, you know, Wouldn't you agree that the response to Question 9 Q 40, Part 4, provides an analytical approach to determining 10 not when a specific crack size approaches the yield point, failure but yield point of reinforcing steel? 12 Here you say the majority of the cracks were 13 A 14 caused by shrinkage. That's your statement, so I have to 15 take it for its value. It's typical of concrete structures. la Okay? And then you " talk about the duct banks where you II removedthelocal--thhparticular,problembyseparating I' the duct banks from your wall there.'. In this case it re-to c ,.1 lieved that local partic61ar problem;:r :i te i 20 l. :e.

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~ 44 eb51 1 A Yes. Because the crack closed doesn't solve your 2 crack problem. The crack is still there. 3 Q Well, there was some strain experienced by the 4 reinforcing steel. 5 A That's correct. 8 Q And then it was relieved once the duct bank was 7 cut loose. Isn't that what would be indicated? a A Locally, the problem, yes, and then the stress if 9 locally relieved. 10 Q Okay. 11 A And then you talk about here a maximum width of 12 these cracks, wheravar they are, is 20 mils. And using that 13 width you are correlating what is the stress on the steel. 14 Q Yes, sir. 15 Isn't that the strength value of interest, that 18 is, the stress on the steel? Isn't that.what we're really ' 17 interested in determining in order,.tg evaluate the struc-18 tural integrity of those buildings? y.y ,,,.g.,. 18 A I would say yes, it's part of the particular. prob- ,;,.Lem. }..: - : ' < .......: ~ ;.s. : ~ ~,. u.- :. Q Okay.

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==. i eb52 1 Q I know what you mean. What are the design loads and what are the stresses i 2 A ? under the design loads by which you're also saying these 3 have to be added to your other -- if it is a seismic load, l 4 if it is a snow load, or whatever the case may be, or a wind s I e load or.... And in fact the answer to Question 40, Part 4, 7 Q i t s states as follows: 1 Combining these-cracking stresses with 4 I 8 the stresses due to required load combinations ) 10 4 11 results in...." 12 certain maximum calculated stresses. I 13 And can you then determine whether or not you are ~ at the yield ooint of the structural steel -- I'm sorry, the 14 q 18 steel reinforcing material in the concrete? I. i 18 A I think you can, yes. 5 in "T ? 17. Q All right. 18 Now I've been asking you to 'look at this' and'I ~ realize that it's certainly a mouthful for me.

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,...c.... _....,n.~.-...,..__ $lWYh.=-.y& .f;g _ '.27 a ~~ '~ 56 cb53 1 them and bring all my books up to date, and then re-read them 2 and see how they affect the-- I'm still in the process of 3 working through them. 4 Q Now the correlation that's in the answer to Ques-5 tion 40, Part 4, between crack size and stress on the concrete 6 is based on certain references which are found on page 40-13, 7 References 7, 8 and 9. And my question to you first is: s Are you familiar specifically with any of those 9 references? 10 A No, I'm not. 11 Q Are you familiar with the work of any of the indi-12 viduals who are listed as authors of those references? 13 A I heard of these particular names but I'm not 14 familiar with what particular work is associated with each 15 or any of those. 16 0 Mr. Matra, we've been talking about crack width. 17 A

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n... ...rm::7.- . nf -m..W=&l2hqq:'i: --Q, Q;Q ~ ,;-:-;QgA, O e gr_i-g:u - .,. g - 3*-- 3. t., 57 ob54 1 length? When you talk about crack propagation, then you 2 A I would think myself-- 3 talk about criteria, I mean we don't-- I would not I'm just talking now as a structural engineer. 4 want any crack propagation af ter a certain period of tims 5 If it continues to propagate then I think you 8 in a building. have a problem and I think this must be established. 7 And when you use the word " propagate" you mean 8 Q 9 any increase in length? If Any increase in crack width, crack length. ) A this is a continuous process then there's a reason for it. 11 something's happening, and I thinli ~the problem needs investi-12 13 gation. i 14 Q All right. Let's assume that a certain amount of differential 15 settlement has occurred as of a certain date and that over 16 17 the remaining lifetime of"the structure, in this case 40 years, additional differential settlement is predicted to 1s ( 4; pecur but it is othersise Ecc.eptablerin terms of soil proper-18 ,;, g iG ~ ,t 2E ties and so on. f Would you exp'ect tiha't".as2 h'a.t differential settlemert ti 21 .3.a-occurs over the 40-yedi 1ifetime of tho' structure that there ,22 W9e #4dV AB 't M s a t

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~ m ~~ , m .s., . -.v. s.. ..a, :x.um. .. r. .,.,n,a.:.. g ~...,. s .Ne ~g.w.,_. .,.,.y..,,,..,._., _ g.y 19._Q gf5= L a ~ ~ 58 may be some additional cracking that will take place? cb55 1 2 A There may be. I'm not saying there won't be. 3 Q And if it was within known limits, would that,be 4 acceptable? 5 A Within known limits in your design as it had been 6 preset, yes. 7 Q And is there any way that you know of of correlat-ing say an additio'nal half inch of settlement to the length 8 9 of a crack in concrete? 10 A Other than tests and running some more analytical 11 results, there probably is no way that I know of. Let's put 12 it that way. 2.600 13 Q So it would just be really a case of observation 14 over the lifetime of the plant, of how much-- 15 A As well as a little more thorough analysis. 16 You could run an analysis, let's say a real crude 17 analysis first, and then, in the local ' area, run a more detailed, a more refined analysis to deitermine -- or problem 18 area -- and:'from your coarse analysii' giatFyowloads to ~ 20 apply on' yotfr -Mi'n your local and get ;- and; analyze.the 1 local prob 1Em with a lot more.... / u-VM i.-i f v'.ID. 21 22 If you cut down the size-%f fth'a problem yo'u cut W 89 0s

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~.-- ... ~ - -2 .....--n.. m . ;- g- -y (;_ y 3' g ; #. - = a e>-' sv i so 1 eb56 1 down the cost in running the problem. These gentlemen I 2 believe are structural individuals and they should know, i 3 O Mr. Dahr is. Mr. Brenner is half structural and i 4 half a lawyer. B3 5 Let me just go back for a second to the tension a field analysis. 7 A Al,1 right. { 8 Q First of all, would you agree that cor. crete is u s regarded as a heterogeneous materic17 1 10 A Yes. j 11 Q And would you agree that steel is a homogeneous 12 material? 13 A Yes. 14 j Q Can we agree that tension field analysis is used 15 for analyzing homogeneous materials? 16 A The use that I have seen in aircraft structures, 17 it is on homogencous, particular type materials. That does not.mean thht a similar type analysis cannot be performed on structures, buildings', "or. anything along thest particular ".'. '.': 1 20 lines. I' feel tha.t we yan get-;.the tension field yalues -is. >.4 - 21 1 .these cases. s..::1 e :.O '. 2. "t-22 -.It depends on.how:you model your material-and how. i M Et IW& ~ '\\ e o ~ y .,w y www t-- w "3weew' vsp-- W9T-" T--

. ___ f & W W 5 ' : 1':a %.. . :..- 4. L --- G,gQ. ~. 'ygjfyq -~ rg- '.y, _,, ,.,fQ..:qs-+ s?: e*$S pM.};'75% --37 -~.;. *- M%yx.;.e, m ; u...n ~.-.. n..w.,, 4; ... :.t. c. 2 ,......,..s, ,.,. =. ~, s .. e,.'.,; ' l. ':,. g;, N.e .gwaaw-- 60 eb57 i you look at it. You have to maybe work with 3D elements or 2 you have to work with other type of... You.have to be more 3 disciplined, shall I say, in your modeling techniques to, do 4 it. s Q And once again, the result of tension field analy-1 e sis is to determine the local stresses on the reinforcing 7 steel. Is that correct? s A Also, whether the crack-- If you have a tension 9 in the concrete....I mean, are you making an assumption here to that you have reinforced. steel in all parts of the building, 11 or are there certain parts of the building that don't have 12' reinforced steel? 13 .gr Q I represent to you that it is a completely rain- {,* 14 forced steel structure. 15 ,pS Then when this was designed you determined for 7 to certain tension loads on a particular building, I'm pretty 17 sure. Now, because of.:some sort of problem, either a fill is problem or some settlement problom you now don't basically .e 19 have the boundary, the same boundary.tconditi.ons that you i 20 originally had..m. ,a.,ir: u C_, 21 Under:these. conditions thed'you.have changed your-22 problem. Where you had'h;certaid.samoun.t.of tension load $dMM c7as. ~ p

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..- ~ "m 4 . a.. y 61 cb58 1 before you may have more or may not, as the case may be. 2 And because of this you have caused cracks, or could..have.... 2 caused cracks. So what I'm asking here, if you see cracks and 4 there are problems in here, some sort of analysis or analy-5 sis technique -- it's up to you, up to Bechtel to do this, 8 7 or Consumers Power Company to check it. 8 Basically, that's what the whole purpose of the s question is. We're not telling you how to do it or-- 10 Q I understand. I'm not being contentious. I'm i 11 really trying to understand. 12 But it is a fact, is it not, that concrete -- the 13 existance of any crack in concrete indicates that in that 14 local area that material has failed? 18 A That's correct, surface cracking. Is Q At the surface at least.there has been failure of 17 the concrete material.

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20 above those which it was designed for. .ce;', .~t 21 And I 'think then you take a *1'cok :atbits and say' .h... P. 22 Gee, is it still good, or should we have to do acmething?!.....n!. ' '. i, A E.L.I % L S

~ - f,; _,..' h: 3y . g..yw,.;y. 4 : -~~ % . c :.-m .~. y.~ % - g ~ z.,,,-T y ;.2s- ,. s: . -r. e3 eb60 1 That's basically what we're getting at here. 2 Q Fair enough. ~ 3 I'd like you to look at Item Number 9 and the C3 3.070 attachment to Rinaldi Deposition Exhibit 7. 4 5 (llanding document to the witness.) e A Okay. 7 Q That refers to applicable American Concrete a Institute codes, does it not? s a y,,, 10 Well, on these particular codes what I normally do here, I get directions from NRC. In this case I've spoken 12 with Frank Rinaldi on what is acceptable at this time when 13 I'm looking at this particular work. And I use these codes I' as a check. 18 Q I see. 18 And what, if anything, did Mr. Rinaldi tell you about the applicability of the ACI 318 code versus the ACI # II '8 349 code?.' s. !. c

t. A "318 Snd*3497 I think that what they're saying"'

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A. I would say after a lot of the work had been done 3 on the Midland plant, yes. 4 O So it may very well be that the Midland plant will 5 not satisfy all of the criteria of ACI 3497 s A This is correct, but that doesn't mean that we 7 shouldn't check it. I mean I think, myself, I look at does e that load exist there and do they want to check it to these e criteria, and if they want to check it to these criteria I'm 10 going to check it to these criteria. 11 The mere fact that, shall I say, some other plant 12 has bee-designed to a different criteria does not, to me, 13 mean that that plant is safe. Maybe the ultimate design 14 load that uns applied to that never occurred. If you follow 15 my logic here. Is We're talking here you have a building, you have 17 a building and this is.. designed to some other criteria, so 18 now we're saying we'g,trying to restrict it to a new 18 particular criteria,which apparently Midland was not designed e, 20 .to because it wqsn't;.given 39*trhem.,7 So dt is all logical. But that;,dgesN,' t._mean,we f,shouldn' t check it. ' ; 2,1

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42 maybe, or the other loads that the differences in the parti-cb62 1 l 2 cular criteria- - 3 Q of course there is no way of knowing whether-- 4 A Not at the present moment. 8 0 -- they'd really experience those loads either? 8 A Right. But we could at least check them out, 7 Q Now do you know what was done with all these t 3.130 8 dif farent items that are found in the attachment to Rinaldi I s Deposition Exhibit Number 77 10 A You mean by whom? 11 Q By !!r. Rinaldi. 12 A What was done? 13 Q Yes. What did he do with them? Do you know how-j 14 he, transmitted them to the applicant? 1 18 A I do not know how he transmitted them to the 18 applicant. 17 O All right. 18 Did you ever see the "C~staf f

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. * ~ ~ . %.W M J.j%, ,3Jt. = ~ =. ..i. *y...--..>"- % 66 eb63 1 Q And what you're indicating-- Because the record 2 can't reflect when you say.,"come from here to here," what 3 you're saying is that many of the data requests, the open 4 items that are found in the attachment to ninaldi Deposition 5 Exhibit 7 were later made into interrogatories and served on a the applicant. 7 A Only on the settlement problem, if I'm not mis-8 taken. 9 Q All right, sir. 10 A Not all the questions in here were. 11 Q And specifically Item Number 9, dealing with the 12 ACI 349 code versus the ACI 310 code, is not found in the 13 interrogatories that are directed to the applicant. Is that 14 not correct? 15 Do you want to take a look? 16 A It may be. Does that deal with settlement? 17 I'm just saying when we were given groundrules to 18 do these-- .c *;..;, 19 0 Do the.Anterro'g.ato, ries? 4 i i is 'h -7:N;."l? 20 A Right.. n.: ' .. e.. dS: N. ' ' '" 21 (Continuing) --.they said only per: tai.ning,.co,. -the,:,.,: 7 e, 22 settlement., problem,.,if_I'm not mistaken, and that'.s what is in i l _l 99 0. 9 e

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. v.,,g .-K....=e* - ~ =;w*Q Q. *j *L _~'. .a.~ _?. ,; v ! m x.. a. .,;u v-67 \\ cb64 1 here. 2 But you're referring to Nusber '9. ~It 'may not be 3 in there. You may be right. i 4 Q Okay. 5 A I don't think it's in there. 6 Q That is you don't think the ACI 349 code question 7 is in the interrogatories. Is that correct? 8 A I don't think so. 9 q All right. 10 A At least I don't see those particular numbers, 11 skimming right through it, tio, I don't see it in here. 12 Q Thank you. 13 tiow I show you a document that was marked yesterday I 14 as Rinaldi Deposition Exhibit Number 8 for identification. 15 (Handing document to the witness.) l 16 I ask yo'u first if that is in your handwriting. 1 i 17 A Yes, it is. Q Can yoii't'all us the approximate date when that 1e ~0 19 document was prepared?' a. A Ch. I was doing th'is to help'myself basically 20 understand w at' ~has been done' 'a'nd' what' questiori....s were asked",'" '* d ' 21 l

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. x, ??* -.pg,,;.g.;;G %. :fm - .s.,,; M.c.a.,fi&jl.*Q.QT*;.vL.:..- Q fpfg.. ' {;. 3 ; G3. 3 .,. - v j T w. i 73 eb70 1 less they had forms which-- You say okay, these are the 2 things, the sections on-structures that-- You may have them And that I basically used as the general format and 3 there. 4 all to follow. 8 MR. MILLER: I would like the Reporter to mark as'Matra Deoosition Exhibit 2 a multi-page document entitled e 7 " Facility Review - Administrative Data." It bears no date-- the bottom it says SES Form 18 dated 1 October 1979. 8 Well, at 8 (Whereupon, the document 10 referred to was marked as Matra Deposition Exhibit 2 12 for identification.) 13 BY MR. MILLER: 14 Q Mr. Matra, I s'how you a document marked Matra Deposition Exhibit 2 for identification and ask you if you M to have ever seen it before. 17 (Handing document to the witness.1 i to i Yes._.It looks like it is in my handwriting.' Q And;could you.tell me whether that.4s ths. document 8 a ..which you've beansreforhing. to before that:provided..tte t. i 21. format foF the. drafting' of, the safety EvaluationnReport;3,h. yl., , 3.._. GThis-is what' I. used to 'put a ' lot of. the .; 22.., t i ns. w,., e n .n, r, e+ - +. -,~,.-,.-.,, - - we._ ~+ ~ a-e ge a% s my9.-

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9 A In other words I wrote in here, and they had cer-to tain questions that they asked on seismic. A detailed plan 11 including a dascription, et cetera, is provided, and if that 12 was in there, yeah, okay. 13 0 Did you circle it? Is that your indication that 14 it was satisfactory? 15 A Yes. And I give the page and everything in thera. 16 Q All right. 17 So this was really kind of a first step in-- 18 A Right.. It's working papers is what they are, c u., to before I wrote the Safety Evaluation, Report. w 20 Q . Turning,to numbered,.pa,qe d3,..that is the page.that g 21 talks abouti* the3 concrete: contai,nmeqt. - And the handwritingyc - j there is all yours. 3 Is that, correc.t?: - x.ns -. 22 =

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...,..s.,_..,_,,..,.,..,, hfh@'E3 '~ ~ ~~ }.'. '.-~;M M-76 ~ 1 A Right. In other words at this time we were talk-eb73 2 ing here about different Regulatory Guides and different -- 3 whether they're the same or what they are. I wanted to,know 4 and I wanted to check them myself before-- Rather than stop 5 and do it, I just wrote to myself to get back and do it. In 8 other words I wanted to satisfy myself about that. 7 Q Can you find for me in this document -- and I 8 realize it's a fairly thick one -- your initial analysis of 8 the structural problems, if any, that were caused by the soil "O settlement at the Midland site? 11 A My analysis? 12 Q Yes. Is it found in this document? 13 A No, you won't find my analysis of any of the buildings in this document. We're going'to perform a struc-10 tural analysis. We have asked for information and un to 16 date have not received any on it. 7 17 And by "information" I'm referring to-- Le t' s 18 In one of the questions--

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see. Q Are you referring to answersito these interroga - ~ II' ' 'J... "la 1 tories? Is that what you mean? 0 6 4 Q i.: .. t-l.i e -fe'. ~ - ~ ?. . 2h A That's correct. That's soineMS its Like~ set wan't w-2 ~ 22 to run a seismic analysis on the conta5.nmenf.'bulididgT.and l -.*w.. M +-+m.mn w M 7y

' ' $,' ~- *. : r ~ .,- 3 . y' ..~.n.-7.. -e .m a i 3;cy.. 2 .s .. x ..e _- -..:.u. . 5. y 3... ;- .. = v.< s - -:, v... 77 cb74 1 we're picking another building to run it. To run these we 2 would need some of the material properties, some of the 3 constants that were used. Not that we're going to run the 4 same analysis; it's just going to be silly to run it again. 5 our analysis is going to be different than what Bechtel or 6 Consumers Power people have done. Our model is going to be 7 different. And we're just independently going to either 8 agree or disagree. 9 Q But with respect to the soils settlement issue, to these interrogatories represent, do they not, all the out-11 standing-- 12 A -- questions that we had. 13 0 -- questions that you had? 14 A Yes. 15 Q New I used the word " analysis" when I asked you 16 about where in Matra Deposition Exhibit 2 I would find the 17 foundation' questions. I used the word " analysis."

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ts Where are they discussed in this document, quite-l' . apart from'any. analysis, in other words the foundatie'n problem 20 ~ , f. . arising from{ the: soils settlement at the Midland site?'.,. s.... 21 g .,You mean in here? Ret :.:F.6 l 22 O Yes, sir. -Mr.; 'r.9. :-.' i l OF9p N6e 2 *, e: s I \\ ~e

z., n...., e-r ...n,n..... - ~. f..[O E i ; C ~, _^ "s - v.~ sy m.g., fg.,,. 5.9:.- p s w.~.;, Y -T. N( j.........,. ,...y .. _ < v._ w. 3, '.2D.h.I.. '"J *.T.. " 5.". "*jj,.&-. ,i__ .4_..s._m.,. <==. ... -. _ -? ..c ...~.m .w ', ~,',' ". ',.',. ",,',^,~,",,,~~ _n ~ e. G...: s. ,..c. ._m.......,, ,-.>x---, ] $. @ m-J.= w a - - , -'s,. .c 78 1 A I don't understand your question. I'm sorry. cb75 2 O Is there any part of this document that purports to discuss the foundation as a result of the -- and the effect 3 of the soils settlement on the foundations? 4 What you mean is to get information out of the 5 A FSAR on foundations, and I think one of the titles here..... 6 Like here, " Response spectra aoplicability for various 7 8 foundation locations." 8 So throughout here they.... 10 So if it is in here, other than that, I just pulled 11 it out of the FSAR, any information on the questions, the queittions and answers that they were asking. 12 13 0 Okay. I' At about the hiiddle of this document there's a handaritten sheet headed 3.8, Design of Category I Structures. 15 16 A Yes. And about halfway down the page there's a refer- 'I Q ence to page 3.8-5, and I assume that's 3.8-5 of the FSAR. 18 Is that correc.yt.:; -...- % a. t 2,0 A ..Yess: I. be.lieve. so.y . 21 .It says.?Equasion -A.1 lef t out live load." g . ~. 3..;... ; A ilere I was comparing what was used and what was in '2 h ( , i.. c. O O$. s

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-. n - m..,.. n ~.,,.,,.._.. y- [5.;$::[6% e -.$ c.,..- T d. % +i$ ' '~ 80 ob77 1 I was looking at at the time. 2 Q And then'your analysis of these various equations 3 continues on the next page. Is that correct? 4 A Right. 5 0 And did you resolve to your own satisfaction that these equations did in fact meet the applicable specifications? 6 7 A At this particular time I mean I was only com-8 paring numbers, not magnitudes, and one would have to know 9 what each component and what its effect is to tell the over- "O all picture. And I believe, if I'm not mistaken, that in 11 some of the response and answers some of this was being done 12 by Bechtel or Consumers Power at that tine to make a coepari-13 and later on I found some ci these in my questions and

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answers. 15 Q okay. 16 MR. MILLER: I'm about to change subjects so this 17 .is as good a time as any to break for lunch. I j 18 (Whereupon, at 11:54 a.m., the taking~of'the 1 9 . deposition.'was. recessed to reconvene' atrl2: 45?p.m.- l l the same day.). I-e.: is '..:J.!.d'

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~ .~ ~',:. - --e- . *. rt. .... w: a. :' - s ~~., a. 81 AFTERNOON SESSION Gb78 1 .(1:25 p.m.) 2 9 / 3 Whereupon, JOHN P. MATRA, JR. 4 resumed the stand and, having been previously duly sworn, 5 6 was examined and testified further as follows: 7 CIRECT EXAMINATION (Continued) a BY MR. MILLER: g Q Mr. Matra, I show you a document that has pre-viously been marked as Rinaldi Deposition Exhibit 10 for. to 11 identification and I ask you whe*.her you ever saw that docu-12 rent before.. 13 (Handing dccument to the witness.) 14 A I think I have seen this document before. 13 Q Did you have any hand in the preparation of that - 16 document? 17 A On:.this document? No. t 16 0 Is that something that had been prepared by e..,,,- 19 Mr. Lipinski, do you know',- ofetherNRC7.

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Nell, 19 first of all have you seen.these documents.:before?

20 A Yes, I have. . r.W,, -.i.,, 21 Q And you a're.the -John Matra', Jr. that is. referred l 22 to as author? Is that jri:ght2. 3 - ~ M ERM. dL. 9 v-

.,s.- rs-p yx _- 5.+ f.x a %.*-- M - - . w,...,, ~;c. - ;R-L.j-LQ.g5 3.. ;- =y.. ? '~ *.,} : Z3 c- .,,3... .~o 91_ eb80 1 A That's correct. 2 Q All right. 3 A In fact, you can see some of the original writing 4 in here that was in this book in here, the yellow pages. 5 Q If you look at the back of Exhibit 12 you'll see 6 that there are certain-- 7 A This was done -- I'm definitely sure was done 8 later than this one. (Indicating.) 9 0 Exhibit 12 was done after Exhibit 11; is that 10 correct? t 11 A This is correct. 12 Q so Exhibit 12 represents-- 13 A -- a later version of this. 14 Q And that's youE most recent draft, if you will, 15 of the Safety Evaluation Report for the structural engineer-to ing with respect to Midland? 17 A Yes. n..' 18 Q Is that right? 'a - 18 A That's right. w .. h c hn:. 20 Q Thank you. 21 Now at the top of page'::llt.of / Exhibit 12, Mr., Matra;- c c. 22 there's a reference to the electrical; duct banks. l ....a c.e.. - M EJ-.I %.an. O ~~

ai TN.==r::*..~.- - R _ _ Qg' _n_N N^ S4'wwn--$p' ): .c. .3$ [ -{[ }{ ~ p. r' "-, pj{4gg [My .5$'Myz$ ~ g,-. ...-: 4.., n..<,, -.., -, m_,,,, : u,,,.. a....,... a, n m- '& S 2*.'.3 2 _ ;e =-; >. v. wm +.e -,. y y,,,_em,,_, a ~ Qi:... Exu & f~~ g _ 84 1 A Yes. ob81 g .And the final sentence in that paragraph concludes 2 3 with the words: 4 "We agree with the applicant that as long 5 as the pressure and water type condition around the 6 cables are not included in the design requirements, 7 minor cracking of duct banks are not objectionable." 8 And do you agree with that statement? 8 A Yes, I do. M Q All right. 11 And do you have any reason to believe, as you sit 12 here today,' that there is anything other than minor cracking ta of the duct banks which has occurred at the Midland site? 14 A Well, wnen yo'1 take the whole thing in its con-15 we agree with the applicant that as long as pressure and

text,

'6 water type conditions around the cable are not included in 17 the design requirements....Is it a design requirement? ZI'- 18 don't know. 19 Therefore I said then minor cracks are not objec-tionable.- 'As long as you don't have an obstructica or-- i - ~21 Q 'As you may recall, this was the'strdeturd,' thst is, '* 22 the duct banks,' that were tested by means of rabbitM-A

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'~ - ' _m._ ~ -, - . '* y,ty%.J,'.%, '....JG.,*-y"7"' . sg.4 % M -- n 4.fi j,' ' *, 'i,'"*., 'e. ej 4-a.-r-m pr.....,,,.a l 87 eb84 1 your second paragraph indicates here? A Yes. On the service water building, this.is the 3 one with the piles and the core bell on the outside which 4 they used to jack up part of the building. And yes, we had 5 a lot of questions on that particular design. 6 Q All right, sir. 7 Assume with me that instead of piles caissons were 8 actually inserted under the service water pump structure. 9 Would that be the equivalent of the abutments that are re-10 ferred to in the second sentence? 11 A No. I'm referring to going right dcun to colid 12 ground, just like ycu do in a das or-- 13 Q In other words a solid concrete structure? 14 A Yes. 15 What the basic prcblem here is I don't Joe where 16 we can take out the lateral loads in a pile, a driven pile 17 as recommended here, say for an earthquake.. I think the thing 18 is going to slip. There is no mechanism shown unless there i 1 18 is some andl .they.have some lateral attachment".:.r.... r.. 4.; 20 '.'In. ether.:words., I don' t have..alL.:the..deta'ils :.in ; - 21. ,their anal ' sis.jor. what. they have proposed here to really l 22- -accept it in our mind. If they can shownthis.then-- ' ~ l

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21 ..a 'A "It doesn t'h' ave to - be all th<e ' way around' bist' over 1 22 mos t o r som'e' o f. 'i t, ye s, *down at"" the base. '9 9 +s .=

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.,v.-,.,,..n,.,,,....... A $~f;.r.w.,,,., y cm,~, -- .;g s _.g-w g 90 eb87 1 response. E O All right. i some of these are the open items mentioned. 3 A I would like the Reporter to mark 4 MR. MILLER: as Matra Deposition Exhibit 3 for identification a type-5 undated, which just has a front page with a written document, the words " Questions and open Items." 7 (Whereupon, the document 8 referred to was marked as 8 Matra Deposition Exhibit 3 to for identification.) 11 12 BY MR. MILLER: 13 Q Mr. Matra, is Matra Deposition Exhibit 3 the type-written version of these' handwritten sheets that are found 1# 15 in Rinaldi Deposition Exhibit 127 (Handing document to the wi,tness.) 16 17 A I believe they are.

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J: i Now Question 3, the second'. sentence of tha,t says: ts Q "We require as necessary.the revisions ;;(r p..,. 18

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.... v..-. 1 91 cb88 1 A The fact is there I think Consumers Power in their 2 reports indicate that they were going to do that anyway 3 and which I read after this had been written. 4 Q In any event there's a commitment to do it. You 8 haven't seen-- e A It hasn't been done, to my knowledge. I haven't 7 seen it. But maybe it has now. I don't know. 8 Q In terms of the applicability of the various 9 codes and Regulatory Guides, you rely on Mr. Rinaldi for 18 that, do you not? This 's correct. 11 A i 12 g 'Okay. 13 !!r. Matra, I show you a document that has been 14 previously u.trked as Rinaldi Deposition Exhibit 13 which he 18 identified as the contract between the Naval Surface Weapons 18 Center and the Nuclear Regulatory Commission. 17 (Handing document to the witness.) ,. 18 Have you ever seen that document beforei 9

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input, analysis results.and other related technical docu-9 to ments."

Are whatever written reports were submitted to 11 Mr. Rinaldi included in those three binders which ye. looked atf1 12 13 earlier today? Of course Everything to'date that we have done. 14 A we're still working on the task, but it is included in those 15 is three binders.

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is it fair to say the subtasks'for the Midland Project, to Is that only t'he;first.two subtasks have been performed? to 0*

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+ 93 we're beginning to get involved in the design audit and eb90 1 The date is 2 things.like that, which is going to be set up. 3 going to be set up. The last subtask on numbered page 4 of Exhibit 13 4 Q refers to a confirmatory independent structural analysis. 5 6 A That's correct. Is that what you were referring to before which 7 0 8 is yet to be performed? 9 A That's one of the items, as well as the audit, to that has still to be performed here. And on the previous 11 page, " Conduct a design audit." 12 O All right. 13 Has the Category I structure, in addition to the facility containment stru'eture, that has to be analyzed by 14 15 you been selected? 16 A Definitely not. We have a number that have been 17 considered. The service ivater building is one of them. Of 18 course the containment. building is another. 18 Q Well, the containment.is... required,-- 20- _., _, _ ; A. . Right. , qh-d. .cre : \\l 21 ,Q -- in any event. + e -22 A As I said; of-course the containment is another. .--,n. ~ M E.L.IW a '\\ e e ^ ~

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... 1.#. r._ _. m,_,., h'$w.m&- - , c '/, ' ~ ' ' ' y, l s'c g '.,. s.- m & 94 It And if time permits we may also get involved in another. eb91 1 2 depends on how f,as,t.we. work. 3 Q But as it stand right now-- We just mentioned some rather than selected a 4 A And a lot of this is going to depend also on the 5 couple. a audit of the data. We may get some of the information we want from the audit and therefore it would be to our satis-7 3 faction. 9 MR. MILLER: I would like the Reporter to mark as Matra Deposition Exhibit 4 a handwritten document which to appears to be a request -- a requisition from Mr. Matra to 11 Butler Analyses, Towson, Maryland, and it has a date of June 12 13 6th, 1980. (Whereupon, the document 14 referred.to was marked as 15 Matra Deposition Exhibit 4 16 for identification.) 17 18 BY MR. MILLER: 19 Q .'Mr. Matra, I show you a d.o..c.u.m..e,.n.t t. h, a.t., has. lpeen marked _as Matra., Deposition Exhibit. Number 4. 20 T.. (. Handing. document to the., wi. t. ne s. s.1, 21 .Have you seen that documen.,t?.,... 22 M E.4,.I & : :A. ~ e e .s.

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~ [Q%.l= na- - ' '~ ...'[:.n. 2_29... a ab93 1 We think it's a more accurate method of icing it. C4 2 Q Do you know whether the applicant.has. conducted 3 that type of an analysis, the type that you just described 4 in your previous answer? 5 A You mean the applicant, myself? 8 Q No, no.. I'm sorry. Consumers Power Company and 7 Bechtel. 1 a A Has done a stick analysis. They show this in 9 their particular -- in the FSAR. They show-- In the seismic 4.244 to they get the floor loads and the thing as a stick analysis 11 and then run it through, and then they apply this on a finite 12 element, if I'm not mistaken. 13 But that's not the real true loads that's going 14 to be on the structure. Ih other words if you look at the 15 building itself you'rs going to get -- locally you're going 16 to get-- The way they do it they get tension and compression, 17 take out your moment or compression' loads and tension loads I 18 on maybe one side of the building where you get a local iri 18 bending in these particular: cases. r:. ;:.ci-: "*. 20 And this:is.what we'recafter'. hare,itolfind out . 2 :- 21 what effect this.'has.3 I. 9h 2. m -.. r1' ?: ~ j I 22 0 Is this.analys'5.stre' lated:ateill. toithe' soils ^s. .M

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~-- . m,.% .~ ;- =-a.z..y.';:.; : z y=pg ' _,;g-;Q.g , v... 97 settlement issues, or is this comething that is independent cb94 1 2 really of that matter? 3 A I think it's independent. The. soil settlement problem is another problem, but I bought everything I had 4 5 over and this happened to be in thero. 6 Q Fine. 7 And have you actually let the contract to Butler 8 Analysis? 9 A The contract has been let and completed and we're 10 now in the process of -- well, running and checking it, the 11 subroutine, and checking it out with an actual structure. 12 Q Does the NRC have any computer models that would 13 simulate the situation that you've described; that is, did 14 they use the analytical technique and type of model that you 15 described for the containment building or did they just use 16 a stick model also? 17 A Does the NRC use....I. don!teknow what the NRC 1s really uses in this case. I just: can; tell you what we've done, 9f. -... 0 okay. y:.- 39 ., g, Did you check with Mr;.c.E.inaldi, for,examplei+'.be.-Y:s 20 F. 21 fore going ahead with this contr.ect.? .4 3:.J y 3. 22 A Yes, we did. v.r. n c ; /-;.s.. n ;.s. : g. - .e - J,- p ... ~. $$edeel&m,$na. ~

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.y ,.7,.y :... . a..-g 1 Q' And did he say anything to you about whether or cb95 not the NRC had taken such an approach to seismic analysis 2 3 of the containment structure? 4 I don't know in general what his comment I 4 A I feel-- I don' t think He didn't stop us, or whether he felt-- i 8 was. that this type of analysis has been run, let's put it that 8 way, not to my knowledge, unless it is someplace else in the 7 l* a literature. J/ q Mr. Matra, a little earlier today when you spoke 4 8 about the Corps of Engineers and documents that it had sub-to l if we look at page 7 of the attach-11 mitted to the applicant, ment to the cover letter of Rinaldi Deposition Exhibit 16, '2 t we see Item -- well, it's Subparagraph B aoout the middle of I3 l page 7 and it reads as follows: "The bottom of the borated tanks, being 15 flexible, could warp under differential settlement. Evaluate what additional stresses could be indsded 17 I in the ring beams, tank walls and tank bottoms be-ts >cause of the settlement and compare with hilowable E ? 20 stre2ses.. Furnish the computations on stiesirins,- T* incid' ding method, assumptions and ad,o..id'... pt soil. ' 21 ' ' 3 - / ".- ^ Ed ' ' ' 1.22 properties in the analysis." l m a n e. a..a. + 6 e m 4-g

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.,.,...n...,n:,,..... ,e .. ~. n;pa '.:=== =n .a=. . ~ =. .m. . 4 ~ f ;2 k~ . yy ' ;. : > -Rg inn l eb97 1 Q Is the information that is called for in this Sub-i 2,. paragraph B information which you must have in order to 3 satisfy yourself with respect to the structural adequacy,of 4 the borated water storage tank? 5 A Well, if the tank itself and the foundation -- 6 let's put it this way -- would settle or warp in any way, 7 then I could run an analysis on that tank and determine what s effect this would have on the structure. 8 I didn't write this particular statement here. 10 Q So in fact as far as you are concerned all that 11 was necessary for the borated water storage tank is that they ~ 12 should be-loaded to monitor any effects on their supporting 13 foundations and soils media? And I'm referring to page 12 14 of Rinaldi Deposition Exhibit 12. 15 A That's what my statements were. 16 MR. MILIER: I would like the Reporter to mark ~ 17 as Matra Deposition Exhibit Number 5 two handwritten sheets .5 18 uhich are undated. The too line on the first page has the .y 18 number i encircled, andithe! word:"Onct's." b. 1.28-;.;*~ . - ; ;. i }. \\ r..;.:.m u ;. z4::. : :.. r 21 =.em.e 22 G. ....s.- %'4* 4f f p 19 0. \\ l I t J

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. <~ : .r ^ _ Q:p Af*R%, { 'N.S:v ; - >.-w. ~-. .v n .......u,;.n-m a.:. _ ~. 5..,q., vi ,u. %. :..,.. .z ..,. -,,. ~.,... y ~. i;:.. _ '2 23.., g } - u. u k J -- " *~ in? i eb99 1 Q And is that kind of your preliminary notes with 2 respect to-- 3 A -- with respect to some of the positions we've 4 taken. That's all it is. 5 Q All right. 6 A In other words as you're reading this we're not 7 going to remember everything so I just put them down. 8 Q If you would help me out on what follows the number 9 2 in a circle, would you just read that into the record for 10 me? 11 A It says: 12 "2. Cover letter and a paragraph 13 stating that the...." 14 Let's see. 15 ".... improved base in the seismic reanalysis. We 16 agree with the applicant will perform seismic re-17 analy' sis for Category I structures." 18 Q. And that again refers to something we discussed 2. 18 earlier; right? ,..g.,.,, . g 3 g.;:.g,p ;g..g e 20 A. Yes. ..y. g'g. g.- ; ;., g .....;gg 21 g Okay.;,g 22 .A .-In. other. words. I.',m writing. myself notes,..iThat 's 1 9 ~' ,,,s. e e

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.,,3., 103 all they are, because you don't always continuously work on ab100 1 2 it. You may work on it and put it aside. 3 Q Sure. There doesn't appear to be a numbered paragraph 3. 4 6 You then jump to numbered paragraph 4. Is that correct? 6 A Well, that's what it looks like, yes. 7 Q And this is: 8 " Procedure for crack repair assuming 9 that the analysis proves satisfactory." to Is that correct? 11 A Yes. 12 Q And there you want to know how they are going to l 13 go about repairing-- 14 A Are they going' to leave these cracks there or are they going to fill them up to prevent corrosion of the rebars 15 is or what? 17 Q That would be desirable to repair them. Is that 1 18 _. g right? I'.just want to know ( 18 A Yes, or to do something.., 20 if anything-- 21 Q Numbered paragraph.5 f.n this exhibit says: 22 . "How is-the-: applicant.. satisfied that the --22, ~ $c.8./.co/ hers,8ae. ~

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.i ,.Q i n e; P on in one of these questions and answers from NRC in which abl03 - 1 they did answer that so I said eliminate it to myself. 2 3 0 okay. But at the time there was a question raised and it 4 A a wasn't answered. That's what it amounted to, the part t_ hat I was reading, and then I finally got to it and it was e 4 7 answered. 8 i O All right. 8 Now there's another reference to the duct banks 10 on the first page, and we've already discussed that subject sufficiently. 12 on the next page, the first two numbered items 13 have references to pages and I take it that that is where is found-- g Where the information is found. " Service re-15 analysis will be conducted." This is part of ' those analyses i 16 l that I talked about, and that's the pages they occur at. 17 l l - ..Q -

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.- i ! 19 ,And that. continues on down the page? n A hat's; correct".', In other words first I asked the F ~ "cr e e f t I...;.. question and'then somehow-you people either interpretedCit'.+' 21 16 or the question was asked prior to this, and I'm just pointingt. 22 ) ...-..--o. i I

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. 3 Q ^* g.[ S ~{ 3, x. = y ".gc.i.nu i:N :*:3&- . 4,;.m : - e,.:v.s. +.-:- m u. a y;., ,n abl04 1 out where they're answered. .2 Q Okay. 3 On another page there are just three lines. "Through cracks, effects on corrosion, 4 5 yield of...." e Is that "reinforcertent"? 7 A Yes. a Q What do those words mean, do you recall? I 8 A At this time we were looking at cracks and what 10 don't we want. We don't want through cracks. Are there any ~ 11 effects on corrosion? I'm just asking myself basic questions 12 that I could-- More or less it's a thinking process with me. 13 O And you were concerned about the yield point of 14 the reinforcement steel. Is that correct? 15 A That's correct, on the rebars. ~ Q And we talked about that earlier today. is 17 A Yes. 18 Q Okay. .9 The nest pagelhastar. horrendous sar.iss of equations. 1 A These are either;onolof etwo'. places. As you can .. 20 '. :.r. c,, 21..,,,,. 7,ye taken some.and. changed:th'am. These were either. 22 i .. i.,-g .+. g. . in the spees or in.the.fSAR. Right now I don't know which j.e... 89 8. I 1 i I ...m

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' ' l *s. ' ' '. : - ..T ~.:x- - l4-f~&Q-[;7;,., _--Q.~=; {;f. ~J.}i* ' yy a :.~ ;. n :- A z = ' -' % *>. =. a.::. 109 cbl06 1 cracked the structure is weakened? 2 A Well, if a wall cracks it's not going to be better; 3 that's for sure. 4 Q Well, if the wall is not used-- If the concrete portion of the wall is not used to provide tensile strength, 5 then the structure is not weakened as far as the tensile 6 7 load bearing capacity. Is that right? s A Could you tell me any time a wall is going to crack it's only going to crack where it's not going to be 9 10 used in tension? I mean I'm making statements that if a 11 structure cracks there's a reason for it cracking. Why is 12 it cracking? 13 So when I'm writing these things I'm writing notes basically to myself and if you want to publish them, publish 14 15 them but-- 16 Q No, I just want *o understand. i 17 g. It's my thinking process. I'm reading.somethings i 18 I write something down. I say-- a Q~ This.doesn'.t necessarily represent.the las.t.- to 20. definitive word?

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.e'- % w.'....n v ,,1 eb108 1 A Other than that fact that we're going to be at i 2 the hearing? 4 3 Q Yes. i I 4 A And the problems we have. What you have here is \\ 5 what we discussed. J 6 Q Has there been any discussion as to who is going 7 to testify on which subject matters? 8 A I think as far as if it comes to testifying it i 9 will be either myself and/or Dr. Muang or both of us, as far. i 10 as I know. i 11 Q That about covers the possibilities. 12 A Right. It depends on-- Dr. Huang is an expert, l 13 I mean an expert in his particular field and has a lot more-- 14 0' What is his specific field, do you know? 4 ts A Well, it is structures. He has a degree in civil to engineering. He has worked in the Martin Company. He has 17 also worked in the building.part;at Michigan. He went to to the University of Michigan. i.I,think one of his teachers, if i. 1 i 18 I'm not mistaken, was even Timoshenko, so he4 nows; structures k I 20 l-

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(.,., .g tc- ,:-..u.. ...,..s o.......%,, l3N1Sw-J c_T[:,., ,~2~%_ ~ 112 1 well? tb109 2 1. Yes, I did. I worked.with Dr. Huang for at least 3 20 years. 4 Q I see. 5 Did the two of you move from the Martin Company 8 to the Naval Surface Weapons Center at the same time? 7 A That's right, a e Q Have you received any -- oh, directions from the NRC that any review you undertake with respect to Midland 8 10 has to be done with particular care because there's a public 11 hearing involved? 12 A I don't know-- You're talking about-- I don't 13 know what you mean by " direction." 1' Q Has anyone ever commented to you that this is -- 18 that this review has got to be done more rigorously or more carefully or has to be better documented because ::there's a ta 17 public hearing involved? ..e - A Not that-- I mean they just tell me.to perform,a te l 18 task and I tried to do it the best I could;.,I felt that at..:r -r . 20 times mayble there's a possibility of a hearing /It think.in. *. .f N. anything that you do along these particular,ylines,,,so, yon'.v. 22 prepare youself accordingly. h..t?./ 2. .1.'.e " r ra l ~-~~ M E.L.I% eL,..:...:.., 9 9

' ' 'NN. s te 3:: %.;;3..:; _, -- 7 '~; 3 p3 ,.:; da.pk - 1r..:~ n- ._.,._g v.. ; 1 cb110 Q Okay. 2 Have you had any conversations with Mr. Jones or 3 Mr. Paton or Mr. Olmstead of the NRC legal staff prior to preparation for today's deposition? 5 A well, I didn't even know I was going to be-- O They just told you to report here with your docu-e I ments. Is that right? 8 tie were told there's a possibility and the fact A that -- and we were given certain depositions that were 8 given by I believe you people or whoever had given them, and 10 11 I looked them over. O Whose depositions did you look at? Mr. Dhar's'. 12 13 A Darl !!ood's. 14 Q I see. B5 A That's the one I was looking at. There were others 16 involved. I didn't read every word. MR. MILI,ER: Okay. No further questions. Thank' ts you very much. to ....s. (tTh'ereupon, at 2:25 p.m., the taking of the v. ., a :::..: : 20 deposition,...,was concluded.) ': 1 ; ;.... '. 21 1: ;=.:. :. 22 i, 3ubeenbod and swom to before me te M of

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? ?$.':,;*.l ?.~ n - ~ .g >. g. --- ?q. g+ c.4-- y,..;,2 ~,.. e4 w.np%:%p m..- - a . _.y ? n. ~ ...~.,,..:~- 2., _.-..... w. .. e.,,. ,,.c '.s. -"...-t 't m..u...;. v...sp, 3g t;. c. g;. ~'.& da _,,y ~ , ~ 7. ..-,, g.e 114 wb 1 CERTIFICATE OF NOTARY PUBLIC AND REPORTER 2 3 I, William R. Bloom, the officer before whom 4 the foregoing deposition was taken, do hereby certify that 5 the witness whose testimony appears in the foregoing depositior 6 was duly sworn by me; that the testimony of said witness was 7 b taken by me by Stenomask and thereafter reduced to typewriting a by me or under my direction; that said deposition is a true g record of the testimony given by caid witness; that I am to neither counsel for, related to, nor employed by any of the 11 parties to the action in which this deposition was taken; and, 12 further, that I am not a relative or employee of any attorney 13 or counsel employed by the parties hereto nor financially or 14 15 otherwise interested in the outeeme of the action. 16 17

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/ A,"M 18 ~ Notary Public in and for tiid 19 . District of Columbia , :0 - :.t. 2 r - My commission expires 14 dugust 1985 a. 21 I. . 12 +"**"E-w" ..s we.s. 43 .4$.% e. = ~s? ,t> - Ts% .m - .}}

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