ML20090B015
| ML20090B015 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/27/1981 |
| From: | Kane J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8105180402 | |
| Download: ML20090B015 (27) | |
Text
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Met Nos. : 50-329 Ost 4 50-330 Ost 5 (Midland Units 1 and 2) : 5J-329 OL 50-330 QL g -~~~~-=-----E y DEPOSI"' ION OF JCSEPR D. EANE (Continued) a Bethesda, Maryland Friday, 27 March 1981 e The depositien of JOSEPH D. KANE, resumed pursuant to to adjour.mant*at 9 :32 a.m., Rocna 9609 of the.% land Na.ional Bank Building, before BAREARA L. WEITLOCK, a Notary Public r. 11 in and for the District of Colustia, when were present on b' behalf of the respective parties-12 RONALD ZA.MRIN, ESQ., and AL'E S. FARNIII, ESQ., Isham, 13 Lincoln fr Beale, First National Bank Plaza, Chicago, Illinoist on behalf of the Consumers Power cvay. 14 1 WIILIAM PATON, ESQ., Office of the Legal Director, 15 United States Nuclear Regulat.3ry Commission, Wash-ington, D. C.; on behalf of the Nuclear Regulatory 18 S taf f. 17 ALSO PRESENT: I ' /N g[ 1 [0 v., = xR. ArIrI s. na. xEc.Er ~~ c to
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WT."5ESS : CROSS EXAMINATION- (Continued) 1 3 Joseph D. Kane 504 4 I I 1 ll 8 EXE!3!"S: PAGE: I e Constners Exhibit No. 23 507 I Consumm s Exhibit No. 24 507 I 10 Cons.umers Exhibit No. 25 516 l Constners shibit No. 26 5 18 { 11 t I 13 14 i l 15 l l 14 17 13 19 9 21 22 M
$45 01 0: 504 ]i3NH I PR0CEEDINGS ~ 2 Nhereupon. 3 JCSEPH D. KANE 4 resumed the stand and, naving been previously duly sworn. 5 was ersained further and testified as follows* MR. ZAMARINs This is the continuation of the 7 deposition of Joseph Kane, continued from yesterday. 3 CROSS-EXAMINATION 9 BY MR. ZAMARIN: 13 Q You understand that you are still under oath? 11 A I do. 12 Q I have what has been earked Exhibit 23. as of 13 today's date. I would like to ask you if this four-paged 14 document bearing several dates, are the pages in your f5 handwriting? l$ A They are my handwritten notes.' l 17 Q Can you tell se on the first page and second page I 13 where !! says one of two and two of two. dated 3/24/St. can 19 you tell what those two pages represent or what they are? 2' (Handing document to witness.) 21 THE NITNES5s They are a record of a conference 22 call with consumers on the morning of the 24th of March. Mct.7a/staf 48dperfats. Ist. waamamotoa.es. annot som aAssee ~L. ~. .,: ~ ~::: : ~ ~:. -, : ~
l.. '544 01 02 505 r2 ~ s S Fri i These are issues which were discussed with the individuals 2 which have been indicated at the top of the paper. 3 BY MR. ZAMARIN 4 Q What was the sub.)ect of that conference call? i
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A The plans of :onsumers in the exploration program 6 that was to begin. I think, on the 25th of March. 7 Q Exploration program is what we've been ref erring 3 to as the Bering program? 9 A That is correct. 13 Q Mould you also identify the third and fourth pages 11 of Exhibit 237 The third page is dated 3/20/81, marked one I2 of onet and the fourth page is dated 3/23/81, marked one of 13 one. an 1 V 14 A The single paper dated 3/20/81 was a prior i f5 conference call with Consumers, with in' ividuals in the call d is noted above, on the same sub.loct, the e$ploration program. 17 This was a call prior to the call of March 24th. It was the le seans where the call on March 24th was set up. 19 The last sheet is dated the 23rd of March, and is 23 entitled
- Discussion Topics for Telecon on Monday.*
And 21 what it wa.s. my notes so that I could discuss these items 22 with Consumers on the call of ' the 24th. .~ c.4ce 9aderd c.R ertau. Du. 9 ...e. - e wasassestess.* 34. gases MN '8eefteeWWWG SSWESASS -..--_--.,..L.,.,__ ...,... i.1..... -..' :.L.
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i$48 O! Q3 506 .~ ' :,sSMH I Q Does Exhibit 23. then, represent your recordation 2 of what the exploration program by Consumers is intended to 3 M7 4 A Ye s. 5 Q Are there any portions of the progras or any 6 approach taken ey the exploration program with which you do 7 not agree? c A There is one additional document that you nave, 9 which records a conversation between myself Mari Singh, and 10 William Otto. which discusses the probles with not doing SPT j 11 borings of this program. It also states the conclusion with 12 regard to our concern for not doing the SPTs on that sheet. j 13 The conclusion is it is recognized that the program that 14 you are undertaking in areas will be more than what we have 15 requested, and will go further than what we have requested. 4 16 The one area where no SPTs are being taten, it is not quite 17 clear whether the SPTs would have given us a seasure of in 14 situ properties better than under undisturbst and there I am 19 referring to the proDies wie have of taking undisturbed ] 20 saeples in cohesionless estarials and the advantage of the 21 SPT in that regard is it is a measure of the penstration 22 resistance which can give us known information on the i t &ce 9M aRapevreu. Dar. - - um W-i . i same 94 30304 m het m geefWeseWS Gewgamet j
7648 O! 04 50 7 v asSMH I properties of cohesionless materials which we may lose in 2 disturbing that type of sample. 3 0 other than those items which we discussed 4 yesterday, any other problems with the Boring Progras? ,5 A Based on zy understanding, which I have recorced 6 there. I have no other problems. I have asked to have a i better record than that telephone conversation for a copy of 9 your contract. 7 Q dhen you talked about areas of concern, using the 10 undistures rather than the SPTs, were you talking about il particular areas of the plant.or staply areas where there 12 may be cohesionless soil? I' A Strictly with regards to areas where there is b 14 cohesionless soils. 15 Q There was no particular area of the plant site 16 that you had in sind? 17 A That is correct. IS (Consumers Exhibit 23 identified.) 19 WI. ZAMARIN: I have what is marked Exhibit 24 as 23 of today's date. 21 (Co'nsumers ENibit 24 identified.) 22 1 f.~. ~ s.w sw l 1 ,w==== senn.es J
~ l l !76a8 01 05 508 l ! [ es9WH I BY MR. ZAMARIN: i l 2 Q Can you tell as what that is? 3 (Handing documbnt to witness.) 4 THE NITNESS: The document you have indicated as 5 Exhibit 24 is actually two parts. One part is a handwri: ten j 6 summary by Tony Cappucci on a January 20 1981 meeting with 7 Consumers with regard to the settlement of category I c underground piping. I was provided a copy of Tony 9 Cappucci's notes' and I responded by writing the first page 10 of Exhibit 24, which is my handwritten notes in response to 11 Mr. Cappucci's summary of that meeting. I 12 SY G. ZAMARIN: 13 Q Nith regard to the borings that are being or'are .s e la to be taken in the dike, pursuant to the exploration program _e 15 that we have been talking about, in the event that those 16 borings show no problem with dike stabtlity, will that 17 satisfy the concerns of the NRC with regard to the dike? 13 A I can only answer for myself.' I cannot answer for 19 the entire NRC. If the borings show the fill has been placed proper $y and has soil properties equal to or cetter a j 21 than what was used in the design, as far as I as concerned-3 22 it will resolve my concerns of the past with the dike. 1 i P t MM 7M 4:MepcTterd. IT. ~ we_ m 54 M9 m 894W80 Ibe,tSuuuPGE MW _..._.._._i._....--,_.I._._-,._..._.____-_...-_._____.-___..,_._.__.._
i 1 164a OI C6 509 e os3NH I Q As f ar as you know..ould that also resolve any 2 concerns or satisfy any a sncerns that the corps had with the 3 dike? 4 A I would say the same thing would be true. 5 Q Do you knew of anyone else within the NEC who wculd have any different opinion? 7 A The borings presently are entirely around the 3 ultimate heat sink. Whether in consideration oi' 9 environmental needs other issues were raised with the other 10 portion of the dike. I cannot address. 11 3 So f ar as you know, within the context of the 12 issues in this metter. there is no one else who would have 13 any contrary opinion to yours with regard to the dike and 14 what the borings should shows is that right? 15 A As far as I know at this time. I as not hedging. t$ 3 I understand. 17 A Rhat I as attempting to do is there is an issue of 13 das safety which the NRC is involved with. Whether unde r 19 the requirements of federal das guidelines or das safety it 20 Decomes an issue in the future. I derr#t know. 21 0 I have here a draf t, a letter marked 'draf t.' It 22 indicates J. Kane, received. 3/2u81 at 4:40 p.m.. on the e e4:e %nd aRyau, he ~u.~,,~, W44emenWT9eBP S 4 See m 9894580 enefteemuSS ON ~ ~-
1 IS48 01 07 510 {canH 1 letterhead of the Department of the Army, and once again 2 with no indication of whose Army. And on the second page is 3 typed the name P. IL:Callister, Chief of the Engineering 4 Division. i The last paragraph of this letter, it statess 'It is our 6 understanding that the.8/lO Kips has been obtained by 7 deducting stage 5 load on 16 January, 1980 (2.2 Kips) from 3 stage 5 load on 31 December,1981 &3.0 Kips). Table 4-la. i 9 However, from the heading of e-la it is clear that this 10 table pertains to building load only, "theretare loads sheun at various stages sust. be the dead load of the building load 12 only. The applicant should clarify this discrepancy.* l 13 Can you look at that and explain to se just what the .o 14 problem there is that McCallister is attempting to convey? i 15 (Handing document to witness.) lo TIE WITNESS: I would like to.stndicate that the 17 Army is your army and my army, the U.S. Army. 18 BY MR. ZAMARINs 19 Q All right. I Z) A 14r. McCallister has not signed this. This is also 21 a craft, so this is directly from Hari Singh. What he is 22 attempting to convey is that there is still some confusion m c4ar. Jedraal CR nesteu. One. 4 m,eoeswee sevenees l
t i S40 O! 08 511 .43NH I in his mind about the load that was supplied prior to the 2 surcharge. He is still having some confusion with table 3 4-la. 4 Q And this letter that I have referred to, this 5 draf t, was a review of Consumers Power Company's response to 6 interrogatories.1, 2. and 3 of the NRC4 is that right? 7 A That is correct. As far as I know, there are two
- 1. 2 and 3 NRC interrogatcries. I think.
Structural c 9 Engineering Branch, when they sent our theirs, was also 10 lameled I
- 2. and 3.
This was the first set of i 11 inte rrogatories. 12 W. ZAMARIN: I would like a short racess. 13 please. b la (Recest.) 15 3GI. ZAMARIN: Back on the record. 16 SY liR. ZAMARIN ^' 17 Q Mave you done some kind of an analysis of Duilding 18 settlement markers for - within the full surcharge area of 1 ] 19 the diesel generator building? 23 A Yes. 21 Q mat was the purpose of that? 22 A To summarize the voluminous settlement data to 4 i cr@ca.7edres[c % 8me. - sa wei,e.neer er48amese?9eL* S.4. M M 389 6 see.tessurges so.gmass .__,._-,____,__,_.___'U. E
648 01 09 512 siDM 1 where it would have meaning to me. 2 Q Has it been summarized to a point where it has 3 seaning to you? 4 A Yes. 5 Q Nhat is the meaning? Is that too general a 6 question? 7 A I think I can answer what you are asking. I had problems in reviewing the data, with trying to understand c 9 . the differe.it instruments at differerst elevations at IO different locations, and so I attempted to sumoarize those and see if foundation zones settle more than others. Also I 12 was puzzled by the amount of rebound that was indicated in 13 some of the devices. I was trying to understand what would 14 have caused that. 15 I think my sumoary has answered those ques.tions. IS Q In arriving at those answers.dare you satisfied ~ 17 with the surcharge program as having consolidated the soil 18 beneath the diesel generator building to a point of 19 secondary consolidation? 23 A Not entirely. There are rebound measurements in 21 some instruments which are not realistic, in my opinion. I 22 think it is because of the way the settlement was i C K 4 WP&GesetBG99AB, S4 M M 8894300 ene,te 6 Sevemmes i ~ ~~
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conducted during the period when the full surcharge was 2 imposed, that period. And because of that. it raises 3 questions about the accu acy of your survey data. 4 What it doe,s is it reinforces my understanding that doing 5 the additional borings and laboratory testing will help a resolve any questions I do have. i Q With the resolution of some questions at which you arrived as a result of your settlement marker survey, were 9 you able to or did you. In f act, resolve some questions chat 13 indicated that the surcharge program had not achieved il secondary consolidation in the soil beneath the diesel j 12 generator building? 13 A I was not able to conclude that it had not. One 7 e 14 thing looking closely at the data has pointed out that the 15 only settlement markers that we have been given data for 16 continuously was the DG-series, which w0nt up to. I think. !7 FE. 9/.30, whereas all of the other instruments, the i J IS anchors settlement plates, extended only tip to the time of 19 surcharge rebuttal. 20 I think I have indicated in my review of amendment.5 21 that we are asking for that data to be - me are 22 particularly interested to look at the settlement resulting } 1 ./ c4cr. 7eM c8dportata, 8es, =ee,= saamm, e nese ..emimevem. ea samme een ano. esse eneftemunes tegeneau i _____,_2___-_-_. J- ~
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514 -{csSNH from the dewatering operations. No, are particularly l 2 interested in looking at the settlement that occurred since 3 you have loaded the pedettels with the diesel generators. 1 4 There is also one other ites which is not reflected in 6 that. In Dr. Gould's deposition we were handed a document 6 that showed settlements significantly larger than any of the 7 data that has been recorded there. They are indicated to be 8 PD, which I understand are pedestal earters, and the 9 eagnitude of those settlements are e lot larger than i 10 anything I have seen. I as talking about 17 inches. 20 .11 inches. i 12 I asked Dr. Gould what do these measurements reflect and 1 13 what - there is a time scale on the drawing, but it does I h. 14 not give the year. And I was trying to understand what do 15 those records show? i 16 Q Did he tall you what they shem? l 17 A He did not know. He said it was inferimetion sent to him, but he did not reveal that information. I suggest 19 this would me a one ites I will provide free Dr. Gould's - E { or you have already provided it to 'as - the graphs of that 21 settlement which we could discuss at the testing on l 22 Aeondaant.5. s..usam.s NM M I mM seaseosomes gewenase _ _ _.. _.. _ ~ _ _... .-.1
7648 O! 12 515 m ( csSWH I 152. ZAMARIN: Off the record. 2 ' (Discussion off the record.) 3 i 4 i 7 e 9 10 18 12 e 13 e w IS 4-l to 17 3e 19 .C 21 22 N* & en
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'3 % i MR. ZAMARIN: Back on the record. 4f 2 SY MR. ZAMARIN 3 Q I have here what,is marked Consumers Exhibit 25 4 for identification. 5 (Consusers Exhibit No. 25 identified.) 1 6 Can you tell as what this sheet is? 7 (Handing document to witness.) 8 (Pause.) ? A It is a record of a telephone conversation on the IQ 25th of March between niiliam Otto. Mari Singh and myself on i 11 oroposed Soring. Program at Midland. 12 Q ! have a le tter dated Jar.uary 16. 1981 from the 13 Department of the Army, and on the lef t it does say United t 14 States of America. Waterways Experiment Station. directed to i w 15 the District Engineer for the Detroit District. It appears l 16 to be over the signature of Paul F. Hadels. H-e-d-e-1-a. 17 Have you read this letter.
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IS (Handing docume nt to wi tn es s. ) 4 19 A Yes. ! have read that letter. ] 20 Q M you agree with all of the statements sade my 2I Paul Hadala in this t o January 1991 letter? 22 A I have not reviewed thee in detail. ! have 2 e Me 89f. seemumWWWut Se m mM me9tSEuWEEG N i IL
3 02 02 517 3 I confidence in Paul Hadale's review. %e 2 0 Oonfiden=s in Paul Hedala aside, do you have any 3 independent verification for any of the conclusions rear.ned 4 by Mr. Hadala in this letter? 5 A Sy that understand you to mean have I made an 6 indeoendent check af the things that he has discussed there? 7 0 Yes. 3 A I would say no. i 7 0 Is anyone,else gcing to do an independent review 13 of Mr. Hadala's work here7 i II A It is my understanding Mr. Medale is doing this 12 work for the Detroit District. That is a copy that 13 'Ar. Hada t a has s on se at the same time he sent to the 14 Oorps. Ne Ooros nas reviewed that and has incorporated it 4s 15 into draf t that you have been provided a copy of. 36 0 You MT. have any reason to disagree with 17 anything in this le tter. do you? i IS A .%. I do no t. 13 0 And in f set you tend to agree with it mecause of 20 f o ur t oe.f i de w e i n the a mi l i ty o f Dr. Hade l a ? 21 A Nat is =orrect? 22 iG. ZAWA4ks The January l $. 1991 le tter that we W e, A~ MM me w esuammes a ,,--.--,...-,-.----,---..-,-.--.a.-,. .~..-_,,-.-~,----n-- ,., -. ~,,,,, - - -,, - -.. -
00203 515 e hibit 26. 3W t are discussing is marked Consumers x 2 (Oonsumers Exhioit No. 26 identified.) 3 BY 42. ZAWARIN8 a C Anything aeout the cracts in the Isorated water 5 storage tank f oundation ring that I did# t ask you yesterday 6 that you thint I ought to know about? 7 A 3 0 Have you reviewed any of the answers to NRC 7 . -terrogatories that have been filed my Consumers Power 13 Oomg:eny ? !I A neuld you repeat the question, please. 12 C Have you reviemed any of the answers to NRC 13 1..ter ogatories that have meen filed by Consumers Power 14 Osm=any? v 15 A Yes. I$ 0 $1oh ones? 17 A The three that were addressed to the initial set 15 of inte-regatories. I have looked at the resconaes to the rG inte rrogatories my the structural. Engineering Branch. 2 ", O Mave you reached any co9eiusions or arrived at any 21 it=ressis9s as a result of these reviews? 02 A alth re,ard to the first set of interrogatories, r
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85 02 04 519 3% i the reason the Corps of Engineers responded in their letter. 2 wh.ich I think is a teletyse. 324 was because of the concern 3 I had in response to Interrogatory No. 3. and I agree with 4 what is being asked for my the Corps of Engineers. 5 Q That is the thing we talked acout just a f ew 6 minutes ago? 7 A That is correct. sith regard to the second set of 3 1.terrogatories. I think I indicated yesterday there were 7 several interrogatories which I felt were not responsive. 13 Q Do you reca11 which ones they were, what the 11 sucject satter of those interrogatories is? 12 A I would have to be - to be specific, I would have 13 to look at the interrogatories, out if I remember correctly 14 there were responses that we.e saying we did this analysis 4, 15 and we will provide it to you at the time of the audit l$ review, and it seemed to se that if the work had already 17 oesn done then it should have been sueeltted at the time of I5 your ressonae to the interrogatory. 19 3 That is the basis for your dissatisf action with 20 ne. inter ogatory answers? 21 4 I would have to review the ressonses to be sole to 22
- a..swer that.
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43 32 05 520 544sp 1 MR. ZAMARIN: Off the record. t 2 (Discussion off the record.) 3 Back on the record. 4 BY MR. ZAMARINs 5 Q Have you done any review of the underground piping 6 satter with regard to the Midland soil settlement? 7 A Other than review of the Corps of Engineers' 5 efforts, no. 9 Q As a result of whatever review you have done, what 13 conclusion. If any, have you drawn with regard to the 11 underground piping? 12 A The conclusions that I have cirewn are a result of IJ your analysis where it has oeen indicated that some of the y, pipes are overstressed at this stage because of the 14 15 deflections that have been already esasured. 16 Q !s that the extent of your conclusion or 17 impression, f eeling acout the underground piping? IS A I have had discussions with Tony Cappucci scout 17 your position of profiling some lines and not others. and 23 you have my position with regard to that in :osethinq ! nave 22 given you, and that is the single copy before you. Tony 22 Cappucci's notes. CJ edee. 7e4eef o tgeem u See WeemeuSPeak S4 m mh mensommes essemass } ____________-__-______--___-__-J ' ~ ~. I.. ~^
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Q In orcar to save se the trouble of digging for b u. 2 that, can you tell me wnat that says? 3 A It says that you,want to indicate to us that it is ji 4 not necessary to profile other pipe and conduits. Then you 5 snould demonstrate by this sub-surface exploration 6 information you had that they are indeed similar. { 7 Q Do you have an coinion with regard to the croposed ,;j 9 remedial fix f or the auxiliary cuilding? 9 A Oculd you be more specific? 13 Q N. } il A dould you repeat the question? 12 .Q Sure. Do you have an opinion with regard to the 13 proposed remedial fix for the auxiliary mu11 ding, as to la .hether it is adaquate ? 15 A 'Jy opinion is there are still some outstanding I$ issue s with regard to it. They are refle,cted try the Corps e 17 draf t and Dr ey notes on reconse to. I thint it is, Question IS 42. 19 Q Aside from the satters that are conta19ed in the 23 3 raft reocrt, the "orps report and your notes, then there 2' would be 90 concerns that you have with regard to the 22 adequacy of the sur111ary ::rJ11 ding remedial fix insof ar as p 'd e4cr.7e4ee/ A eet,u. S.c 9 WeSummW'WS., Ed. W WM anfteweet ee.caeeg l t i
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, 3* dmo I it comes within your review responsibility is that right? i-J ? 2 A ! underst.and tnat question to mean everything that 4 3 I have reservation on is ipdicated in that draf t. and ! A would have to say no. 5 3 Then you know what I have to say. What are the J others? I 7 A You have susmarized your technical specification 3 f or doing tnat work in response to one of your questions. 7 de have ootained, through deposition. a cooy of the i 10 technical specs for doing that underpinning work. In 11 Dr. Gould's deposition there were questions that we nad 12 asked, which he has referred to being in the tech spec. 13 ! know one ites is monitoring, and I think there were 14 several others. And so not everything that you have on A 15 either the Corps drafts or my notes would encompass that. 16 .1h at ! an attempting to say is I would want to review the 17 tech soec to see if it answers all of the questions that ! 13 have raised with Dr. Gould in the past. Excuse oe. It is la not Dr. Gouldt it is Mr. Could. i 23 3 Oan you tell me what nose questions are to tie 2t extent tnst tney are not contained in your revie e or the 22 tref t oros review of Sovision 107 O sa. u es se n "*""*'** na a-mM messemepuse ecoge.ee
3 C2 05 523 4 3.'G.'*o I A ! have concerns, once this work begins, what 2 monitoring of the adjscent structures and the eff ect of this 3 work will have on both the. excavation of the stif t and the 4 jacking of the caissons, the effect on the foundation of the 5 turoine ou11 ding. Q !s your concern for the excavation of drif t with 7 regard to a lateral support or sungort of adjacent 3 structures? 9 A Yes. 13 Q dould that ce the stee concern with regard to the 11 e ff ect on the foundation of the turoine Du11dingt I2 A Loss of lateral support would affect the 13 f oundation of tne turoine mutlding. 14 G That is wnst your c'oncern is7 15 A That is correct. l$ Q What is your cGncern with regory, to the jacking of 17 ine caissons? IS 4 ahether the jacking process would cause movement 13 in tne structure that you are jacking against and what 23 wonitor19g you clan for where these operations are 21
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^\\ i ~ t 02 09 524 i t.1 I A Not that I can think ef. 2
- IR. ZA'4ARIN:
Off the record. 3 (Discussion off $he record.) 4 SY '4R. ZAMARIN8 5 0 Do you hase.any probles or concern with the 6 concept of the now proposed remedial fix for the service j 7 water structure 1 c 3 A As have not begn given a.1y details on the concept 9 of the service water structure. i 10 0 Do you hase some idea what the concept is? II A To extend the wall and put a footing on the 12 glacial till. y ' 13 0 Do you have any procles with that concept as a 14 oroposed fix for the service water cumphouse structure? 15 A I do not. 16 (Pause.) 17 0 I note in the Oorps draf t repor, Revision 10, 13 which has caen sarked Exhimit 22 as of yesterday's date, 19 Marry Singh states some concern with the effects of ^ 23 corsanent strains in the reinforcing cars of the duct 21 Sanks. Do you consider this to be a significant promise? 22 (Ha-ding document to witness.) ~ Sp-t eg efee.%.e/ c% S= 'a.N -.4 h h ea m essennes s '\\ 7 T [ .-. I E -- 7~1-ISE 2--- 1~2 ---- -- 2--
- S 32 10 525
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A I don't know. I don't consider tnat the area of 2 review of geotechnical engineeering, and 'Jr. Singh has 3 indicated that this is somgthing that should os followed up 4 sy the aopropriate section of NRC. 5 3 'dechanical or structural? 6 A Structural. 7 Q You don't have any iraression as you sit here now? 3 A No. 9 (Pause.) 13 3 I note that on page 12 of this 'draf t Corps report. II Exhibit 22, with regard to Question 46 and 45-I-F, the last 12 complete caragraph of that page. that Mr. Singh states. "We 13 concur.' dero you ref erring to the Corps of Engineers? 14 A Yes. 15 3 ade concur with the remaining portions of the 1$ Applicant response to Question 45-1-F. If the aporopriate '\\ 17 values of shear strength parameters are used, the analyses 13 cerfor :ed my him would a ssure the seismic safety of the 19 f oundations of the two Category I reinforced concrete return 20 c i oe s. " 21 Do,.you agree with that statement if the sheer streng n 22 carameters used are. correct, that the analysis performed Dy. l M. 7 % YrJe ., 9 4 eraesssemoveep m mM i see99eepegg Gewgemet
48 02 11 526 SdHao 1 Consumers Power Ooncany would assure tne seismic safety of 4. 2 the f oundations of the reinforced concrete return oi=es? 3 A Yes. .that I uncerstand from that is to say that 4 One stability analysis that you have provided us, if the 5 shear strength f rom the testing that you are now going to de are equal or exceeded by those results, equal or exceeded 7 the values that you have used in your design analysis, then 3 we would agree that you have demonstrated stasility of those 7 concuits. 10 0 On cage 13 of Exhioit 22 with regard to Question il 47, which cite dewatering. Mr. Singh states, he is ref erring 12 to the full-scale recharge test that will be done maybe i 13 so=eday, that if the test indicates more than 90 days 14 f echar e time to reach elevation SlQ, the dewatering system 15 will ne acceptacle. In your opinion, is there some time 16 period less tnan 70 days that would also be acceptable? 17 A It is my understanding that 90' days are coming 13 accut cecause that is your estimate of the time. I don't 17 think tnere is anything sagic aoout the 90 days. There is a 23 time limit which I thich would oecome critical. I as not 21 o r epar ed ~~ 22 2 Time wit.-dn which to e ff ect the cold shutdown of s ~d e4ce- %al cRyeu. Ae e--- WeGemeGTOsb 54. M MN matteamw e e e e ug aae s
- 45 02 12 527 S. pac I
the reactor? I l' 2 A Yes. 3 3 As long as it was greater than the time in which a 4 cold anutdown of the reactor could be aff ected it nould be 5 su fficient? 6 A or whatever measures were necessary in addition to 7 shutting the ;:lant down. 3 3 Necessary to do what? Shut the piant down. In 9 other words, you are talking aoout if they were going to go 13 out and run some tests or try to cut some cackup wells in il service first you would add that on to the time, if you were 12 going to do that before you go into shutdown? 13 A I am not clear in my own sind. Shutting the 14 piant down is one operation, but maintaining it in shutdown 15 position is another. If there is something that I cannot 16 think of now which is being affected by the dewatering that 17 has to remain operable for a long period' of time other than 13 Just the period to shut it down, then that may be affected. 19 WR. ZAMARIN: Off the record. 20 (Discussion off the record.) 21 SY '42. ZAMARIN: 22 3 on the last page of Exhibit 22, paragraoh numoer 5, it says "If you have any questions regarding our review b cA:e.%ad c)Lportm. Du. .,e W48enseWTees. M m e 39 4980 ana,tesowess eewsmass se ,.m. ---+. -e-n,a. ..-e w----_ .-~,y~ p#.-w g y-a .cy ..m,-,-ipy 9 ,,,e 7,,_,,yy,,wy .p., g- ,ay, -p __m,,. y,.,wy.,-.,.-y- -g-ee ,.9
+ 49 32 13 528 ?4foo I conusents, please contact Mr. Harry Singh." 5 ( - 2 If I have any questions should I do that? 3 A The l'atter is di[ected to the NRC and net to 4 Consumers. 5 Q dith regard to any of the proposed remedial fixes 6 or any of the activities of Consumers Power Company or their 7 contractors or consultants that relate to the soils issues. 3 do you havp any disagr essents or reservations or criticisms 9 that you have not described to us during the course of your 30 deposition ? 11 MR. PAIDNs I will have to put my objection to 12 that question on the record as calling for an immediate 4 13 review of inforiation that Mr. Kane say or may rtot have 14 pickTd up over many, ruany months. If he wants to atteopt to Q 15 answer that, it is all right with me, but the question is 16 coviously objectionable. .? 17 SY 4R. ZAMARIXs 13 3 Oan you. think of anything else? 19 MR. PATON8 Do you understand the question. 23 s Mr. Xane? 21 THE d TNESS: Yes. 22 Can we go oif the r ecord. rJ c4ce-9sdesal.:Rpecs. Onc. , - e e, wasseeeme90et. 3 4,
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.4 4 ~ ! 02 le 529 3 laEfmo I (Discussion off the record.) V 2 7.-15 dI3ESS: Everyt ting that I presently nave 3 knowlewdge of I :nink you have o,en given a :::y of in w 4
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5 WR. ZA1ARIN: I done nave anything further. 6 Signature is reserved. 7 (4herevoon, at 10:55 s.:. the takin; of the 3 deposition was a:!journed.) 9 13 JOSEPit 3. KANE j i! l 1 12, IJ l IA r I l 15 i I6 I7 y&ua sa 20 21 W c4u Jadaal crews:ns. Doc - - - ~ W4Z _ Zbb. 34 Mt m &&M ma7 L _ _; Cow Maes E i _ _ _. ~ _ _ _ -}}