ML20090K899
| ML20090K899 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/11/1980 |
| From: | Thiruvengadam CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-02, CON-BOX-2, FOIA-84-96 OL, OM, NUDOCS 8405240467 | |
| Download: ML20090K899 (63) | |
Text
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Q:E d L U \\l h \\
lf NUCLEAR REGULATORY CCMMISSION In 16e Mattar of:
CONSUMERS POWER COMPANY
) DOCKET NOS 50-329 OM
)
50-330 OM (Midland Plant, Units l'& 2
)
50-329 OL i
50-330 OL
.\\
DEPOSITION OF THIRU R. THIRUVENGADAM
(
dATE: December 11, 1980 PAGES: 1 thru 61 AT:
Chicago, Illinois i
4 3-
- i
{-
ALDE%T REP 0 FIT 1.TG s
f.
400 V1..gisia Ave., s.W. Wasning :=n, D. C. 20024
(~
Talaphena: (202) 554-2345 8405240467 840517 PDR FOIA RICE 84-96 PDR
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
_ _ _ _ _ _ _ _ _ _x
=
5 In the matter of:
Docket Numbers:
E l
6 CONSUMERS POWER COMPANY 50-329 OM & OL and R
Midland Plant, Units 1 and 2 :
A l
8
_ _ _ _ _ _ _ _ _x d
c; 9
Chicago, Illinois 10 Thursday, December 11, 1980 II Deposition of THIRU R. THI,RUVENGADAM, a witness l
D Y
12 herein, called for examination by Counsel for the NRC in y
5 13 the above-entitled action, pursuant to notice, the witness a
e 14 being duly sworn by PATSY ANN STROH, a Notary'Public in E
15 and for the state cf Illinois, at the offices of Isham, d
16 Lincoln, and Beale, First National Plaza, 42nd Floor, w
y 17 Chicago, Illinois 60603, commencing at 1:15 p.m.,
k 18 Thursday, December 11, 1980, and the proceedings being
,cs 19 taken down in stenotype by PATSY ANN STROH and trans-20 cribed under her direction.
21 n
23,
i 24
~
25l i
ALDERSON REPORTING COMPANY. INC.
e O
2 I
APPEARANCES:
2 On behalf of the NRC Staff:
3 WILLIAM D.
PATON, Esq.
United States Nuclear Regulatory Commission 4
Washington, D.
C.
20555 5
j On behalf of the Applicant:
4 3
0 ALAN S.
FARNELL, Esq.
E Isham, Lincoln & Beale I
One First National Pla:a E
Chicago, Illinois 60603 A
8 j
Also Present:
9 k
JOSEPH D.
KANE l
10 Geotechnical Engineer E
United States Nuclear Regulatory Commission II,
j Washington, D.
C.
20555 NI HARI N.
SINGH 3
U.
S.
Army Corps of Engineers g
g Detroit, Michigan I4 JAMES W..SIMPSON U.
S.
Army Corps of Engineers 15 s
Chicago, Illinois E
I6 ;l w
d 17 I 5
18 E
19 M
20 21 22 23f I
l 24 '
l i
l 25l i
i l
l ALDERSON REPORTING COMPANY. INC.
A EEEEEEIE 2
Examination by Counsel Deposition of For NRC For Applicant Thiru R.
Thiruvengadam 3
g 5
i
?
6 EXHIBITS R
b I
For Identification Xl 8
j 1.
Resume of Mr. Thiruvengadam.
3 9
g 2.
ehetoh of or. ohs in e1.se1 gen.r. eor 22 z:
generator building drawn by g
yj Mr. Thiruvengadam e dated 12 5
12nus o.
E g
3, 2
15 '
g 16 d
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19 l R
2o 21 l 22 i
23 24 l 25l I
ALDERSON REPORTING COMPANY. INC.
i
3 1
_P _R _0 _C _E _E _D.I N G S 2
Whereupon, 3
THIRU RADHA THIRUVENGADAM 4
a witness herein, called for examination by Counsel for
=
5 Nuclear Regulatory Commission, having been first duly 5
l sworn by the Notary Public, was examined and testified as j
6 G
H 7
rollows:
a EXAMINATION BY COUNSEL FOR NRC de 9
BY MR. PATON:
i h
10 Q
Would you state your rull name for the record, 5
j 11 please?
m l
g 12 A
Thiru Radha Thiruvengadam.
13 Q
And would you state by whom are "you employedt 14 A
Consumers Power Company.-
This resume is about Z
2 15 three years old.
U j
16 Q
All riuht.
As a matter of fact let me mark tnis d
g 17 ;
as T,hiru deposition Exhibit 1 and today's date, December a
1 h
18 11, 1980.
E 19 (The document referred to, 20 resume of Mr. Thiru, was 21 marked as deposition Exhibit 22 No.
1, ror identification) 23l BY MR. PATON:
(Resuming) 24 ;
Q The resume that you just handed me is three l
25,
i pages long, and you have just indicated that it is I
1 ALDERSON REPORTING COMPANY. INC.
14 I
approximately three years out or date.
Alright, I just wan t 2
to go over with you, very brierly, your education.
3 A
All.right.
4 Q
You have a degree of civil engineering from the 5
University of Madras in 1961, is that correct?
5 6
A Thae,s righe, sir.
E 7
Q It says passed in first class with honors?
A Yes.
d d
9 Q
Does that mean you were first in the class?
g 10 z
A No, there is a classification of first class, t
second class, and third class and honors.,I got a very g
12 high grade to be classed in first class and got and even b
13 5
higher grade to.be placed in honors.
l 14 g
Q Okay, thank you.
That was civil engineering?
2 15 i
g A
That's right.
1s Q
Did that involve any structural classes?
g 17
=
A Yes.
k 18 l g
Q How many, do you recali?
19 I
A No, I don't recall.
l 20 Q
.Okay, your next degree you have a M.E.
degree in 21 power engineering, is that Masters?
22 A
Masters of Engineering, yes.
t 23 Q
In 1963?
f l
A That's right.
i l
25 l l
l Q
And you received a P.H.D.
degree from the l
0 ALDERSON REPORTING COMPANY, INC.
5 1
University of Illinois in 1969, is that correct?
2 A
That's right.
3 Q
And that is in civil engineerin[, but it says, 4
(structures), does that mean you majored --
5 A
Majored in structures, right.
]
6 Q
Are you presently workind on the Midland facility?
R 7
A Yes, that's correct.
2
]
8 Q
When did -- when were you first assigned to the d(
9 ! Midland facility?
10 MR. FARNELL:
During the time he was at Consumers
=lU Power?
12 MR. PATON:
Yes.
13 THE WITNESS:
I was assigned off and on starting E
14 g
from the beginning of 1979,' to the bes t of my recollec tion.
l BY MR. PATON:
(Resuming)'
~
16l Q
All ~r4ht, give me some
- 4. dea in the year 1979, G
17 what percentage of your time you spent working on the Mid-y 2
18 g
land facility?
19 l
A.
In the beginning of 1979, just a pure uess o
20 would be approximately 50%, toward the end of 1979, my 21 suess again, probably 80%.
22 Q
All: right,cdo' tha t-f or 1980.
23 A
1*980, 100% of the time.
24 i l
Q Okay, are you familiar with a document that is 25l' entitled -- that is dated December 6, 1979, encicled Order c
l ALDERSON REPORTING COMPANY. INC.
I
6 dhj..
I modif ping'.c o ns truc tio n. permit ?
9, 2
A I have heard of the document, yes.
3 Q
Have you ever, to your knowledse, seen the 4
document?
=
5 A
I might have seen the document, yes.
h j
6 Q
Do you know if you have ever seen the dccument?
R 7
A I have not read the document.
2l 8
Q Okay, and your work on the Midland facility d
y 9
involved your expertise in structures?
E E
10 A
That's right.
E Il Q
Describe your present responsibilities witn
.m
{
12 respect to.the Midland facility.
3 13 j
A At the present time I'm the section head for l
14 civil engineering in the Design Production De'partment in Uj the Midland Project Division.
15 8
i g
16 '
Q You said you're the section head.
Did you say w
I of the Design Produc tion'Departmen t?
z 18 A
Yes.
19 l
Q Okay, that l's your title or the name of your job 20 but I'm asking you to describe your present responsibilitie: 1.
21 A
My responsibilities are to expedite, design, t
22 l
production and in general to be responsible for all civil 23 i
engineering items concerning the Midland project.
24 l l
l Q
Do you spend most of your time at Jackson, 25l l
1 I
ALDERSON REPORTING COMPANY. INC.
7 1
A That's correct.
2 l Q
With respect to structural matters, do you 3
communicate with* people et Bechtel?
4 1
A Yes, I do.
=
5 Q
Who do you commicate with most?
k j
6 A
With all the individual structural engineers, the E
I 7
structural group supervisor, assistant project engineer and K
]
8 whoever in that particular section.
d q
9 Q
With respect to structural work give me the names 3
g 10 of the people that you communicate with at Bechtel, for
=
4 5
11 example, who do you communicate with most?
m g
12 A
Bimal Dhar, Mo Elgaaly, E-1-s-a-a-1-y, and there s
I3 j
could be others.
There's a whole group of people.
14 Q
Okay, bu't as far as your -- you said in respcase k
15 to my question of who do you communicate with most, you fI' would say Bimal Dhar?
I A
Yes.
18 Q
When did you become the section head of the E
[
Design Production Department?
20 A
May of '80.
21 Q
What was.your job before May '801 22 A
I was a staff engineer assigned te P'ojec't 23 Eqsineering Services Division.
y, Q
Staff engineer?
Would you say that again?
e 25 A
Staff engineer assigned to the P rojec t Engineering; i
ALDERSON REPORTING COMPANY, INC.
~
8
~
1 Services Division.
2 Q
What were your responsibilities in that position 1 3
A To provide te c hnic al..assis tanc e to.the projec ts 4
under construction and under modification.
5 Q
Did this -- when you were the staff engineer j
6 l assigned to Projec t. Engineering Services Division, did you 7
utilize your struc tural training?
8 A
Yes.
d 9
Q In other words, was your job ciere you involved 10 in other diciplines?
l 11 A
I was enrolled mainly as a civil engineer with a
y 12 special emphasis on structural engineering.
E g
13 Q
All 'righ.t sir, and when did you firs t become --
l 14 when did you first -- when were you first assigned to that 15 g
job as staff engineery a
ai 16 A
Since the time I joined Consumers Power, November w
k 17 ' 1978.
I8 Q
Are you aware that the diesel generator building E
II g
walls have shown cracking?
A Yes.
21 Q
In your opinion what is the cause of this cracking?
23,
A I haven't personally investigated all the data Ml pertaining to that.
I have to, rely on the conclusions drawn from Bechtel engineers - taat most of cne cracking i
)
ALDERSON REPORTING COMPANY. INC.
o 9
I was due to shrinkage, and some of the cracking is due to 2
the building being held up by duct banks.
3 Q
I want to make sure I unders tand your answer.
I 4
think you indicated that you're relying in s tating your
=
5 answer on Bechtel engineers.
Can you tell me wno witnin j
6 j Bechtel gave you that information?
R R
7 A
This was presented in many meetings and the k8 l group supervisor in charge of civil structural area is d
d 9
Bimal Dhar.
10 l Q
I understand your statement about the building 11 being supported by duct banks but the other reason you a
y 12 described. as shrinkage.
E g
13 i A
Shrinkage, right.
i a
l 14 Q
Do you know what caused the shrinkage?
n g
15,
A There is a normal process in any concrete walls.
I g
16 ;
The concrete upon curing tends to shrink.
d j
h I7 l Q
Okay, you're not indicating that the cracking is 18 something that is normally to be expected or are you?
-s' I
j A
Shrinkage cracks are normally to be expected.
20 Q
Okay, what kind of cracks do you have at the 21 diesel generator building, other than shrinkage cracks?
22 A
My recollection is the cracks are due to the 23 'l building being held up by duct banks.
24 Q
When is the last time you saw those cracks?
25l' A
I was touring the site along with tne NRC l
i ALDERSON REPORTING COMPANY. INC.
10 1
personnel.
I don't recall the exact time that was. That was 2
- a. day before the appeals board meeting.
3 Q
Okay, was that in August of 1980?
I don't mean 4
to pin you down to a date.
I mean just approximately, what
=
5 month was it?
h]
6 A
I don't recall.
R
~d 7
Q You don't recall wha.t time it was?
Was it in the R
l 8
last half of 1980?
d d
9 A
It would be e guess.
I g
10 Q
Okay, how many times have you visited the site 3
i e
3 11 in the year 19807 I
g 12 A
I don't recall that either.
5 g
13 Q
Do you recall whether it was more than five times?
l 14 A
I would say more than twice.
15 '
Q Do you have any idea how many times you visited I0 the site in the year 19797 I
A I can't recall the number.
i 18 Q
Can you say it was less than five?
O j
A Probably.
0 Q
Have you read any of the depositions that have 21 been taken in this proceeding?
22 A
Yes.
23f Q
Tell me whose deposition you have read?
24 A
Sherif Afif1's.
25 I Q
Is that all?
ALDERSON REPORTING COMPANY. INC.
l
11 1
A Yes.
2 Q
I want to ask you a question about your relation-3 ship with Bimal Dhar. Do you direct his activities?
4-A Not personally.
I act on behalf of my boss e
5 who.is Design Production Manager.and.he directs all the 5
6 activities of Bechtel.
R 7
Q Okay, what is your boss's name?
8 A
Ronald Bauman, B-a-u-m-a-n.
dd 9
Q And he direct Bechtel's activities?
10 A
That's right.
i 11 Q
Does he monitor Bechtel's s tructural activities?
m
(
12 A
The question is not clear.
E g
13 j
Q Okay, does he observe, does he watch Bechtel's l
14 construction activities?
Does he stay on top of what i
15 Bechtel is doins in building structures?
g 16 MR. FARNELL:
Stay on top, that's --
W i
h I7 MR. PATON:
Well he asked for clarification.
I b
18 think the first question was pretty clear.-- dJes he observe E
,)
Bechtel's structural.. activities?
20 MR. FARNELL:
Do,you mean the building, you mean 21 observe structural activities?
22 MR. PATON:
If the witness can not answer that l
23l question I will ove on to another question.
l yl l
l THE WITNESS:
I have difficulty --
25 '
j BY MR. PATON:
(Resuming)
ALDERSON REPORTING COMPANY. INC.
I
12 1
4 You can not answer that question?
2 A
Yes.
.3 Q
Did you say his name was Bauman, B-a- u-m- a-n ?
4 A
Yes.
5 j
Q What are his responsibilities?
e]
6 A
He is responsible for design production.
That is b Il R
a title.
To make sure that all the designs are done in a
0 time.and meet the schedule, d
d 9l Q
You said he is responsible for making sure that g
all the designs are done on time and meet the schedule, is
=
f that correct?
A That's right.
5 13 Q
Is he also.' responsible for seeing that all the l
14 designs are dune correctly?
g 9
15 g
A I don't know whether that is his specific respons-
?
16 ibility or not.
1 d
17 !
g l
Q I don't want to interrupt you as long as you have 18 i'got anything.
E 19 l
A No, go ahead.
20 Q
You said he is responsible for making sure all 21 the designs are done on time.
Now, I'm not sure exactly 22 what that means.
Can you apply that to the diesel generator 23 building?
24 l l
A No.
The diesel generator building and soil 25 :
! related problems are being handled by the project manager.
ALDERSOP3 REPORTING COMPANY. INC.
13 1
Q By Consumer's project manager?
.\\
2 I
A Consumer's project manager.
3 q
'What's h.is name?
4 A
Gilbert Keeley.
K-e-e-1-e-y.
g 5
Q You mean -- does Mr. Keeley -- are you indicating 836
, that Mr. Keeley is responsible in Consumers for all of the 7
work to do with the remedial action that has to do with the
+
n 0 i soil?
d A
That's right.
10 Q
And does.Mr. Bauman have any responsibility with l
z=
f "l
respect to the remedial action with, respect;to thet. soil?
fI A
To my knowledge, no.
- g i
Q Okay.
I will continue the deposition but it l
14 appears that Mr. Thiru is probably no t the right witness g
9 15 j
l in the structural area.
But I will pursue it further.
16li T
Does Mr. Keeley get any assistance on structural d
17 j g
matters from the Design Production Department?
W 18
=
A Yes.
19 Q
And who provides him that assistance?
20 A
I do.
21 l
Q Okay, so we're back to you again.
22 (Discussion off the record) 23 THE WITNESS:
Just f,or your clarification I 24j i
would also add Mr. Keeley is also tne boss of Mr. Bauman.
25 !
BY MR. PATON:
(Resuming)
I ALDERSON REPORTING COMPANY. INC.
[
14 I
Q Will you describe the cracks -- just a minute.
2 Is there any cracking in the service water structure?
3 A
Yes, there are.
4 Q
Are those cracks shrinkage cracks?
l 5
A Some of them have been determined by Bechtel to 5
be shrinkage cracks.
E 7
Q Are there other cracks in the service water
~
X structure, other than shrinkage cracks?
dd 9 l g
A Some of them have been determined by Bechtel to C
10 be o ther.than shrinkage cracks.
z g
11 Q
You say determined by Becht.el, has Consumers
(
12 determined there are other than shrinkage cracks?
13 3
A I did not.
E 14 g
Q Did anybody in C.onsumers?
2 15 g
A Not to my knowledge.
l 16 Q
Are you relying on Bechtel for that conclusion?
6 l7 l w
A
- Yes, h
18 g
Q In the service water structure have you done 19 anything with, respect to those cracks by way of remedial 20 action, or have you taken any action with respect to 21 those cracks -- other than the shrinkage cracks?
22 A
My present recollection is we have not done any 23 '
remedial action so far.
24 Q
Do you plan any?
25 ;
A There is a remedial prosram in ene works.
I ALDEnsON REPORTING COMPANY. INC.
15 I
being contemplated.
2 Q
Who is workins on that?
3 A
Bechtel.
4 Q
Who within Bechtel?
Bimal Dhan!
5 A
Civil group.
[
6 l
Q Have you drawn any conclusions -- now I want to I
ask you about the cr,acks in the service water structure l
8 and I don't want to ask you about the other cracks that you d
consider to be shrinkage cracks.
I want to ask you about 10 i
the other cracks.
l' Have you or Bechtel drawn any conclusions as to
(
12 whether those cracks are serious --strike tha t --
That 5
13 i
they impose any. safety problem?
3 I4 f MR. FARNELL:
I assume that's the operation of g
2 15 l g
! the building?
16 THE WITNESS:
With the buildins as it is now, j
d 17 i w
without any modification?
b 18 BY MR. PATON:
(Resuming) 5 19 i l
Q If the cracks were no: remedied or fi;;ed, that 20 they would pose a safety problem at the operating stase?
21 A
To my recollection, no.
22 Q
You did indicate that someone is workin on a a
23 '
remedy?
24 l A
That's right.
25 i Q
Do you know wny you would work on a remedy berare 1
ALDERSON REPORTING COMPANY. INC.
~
16 1
you determined -- before you determined that it had safe ty 2
significance?
3 A
A rew borings taken in that area indicated low 4
blow count matorial, even though the structure has not 5
significantly suffered.
So the decision was taken at that f6 point in time to provide underpinning support for that 7
portion of the building.
I Q
Is that the remedial action that you propose to d
fix the cracking,is the underpinnin6 oupport?
i A
No.
The underpinning support, that's not to fix the cracks.
The cracks may close gr may still remain same.
The cracks -- repairing of cracks is a totally different l
area.
14 '
Underpinning is to take the support away from the l
15 soils that have been found poor and to transfer the load
- l 16 down to the till.
h*
17 1
d Q
Right.
I want to ask you about the cracks and l
18 g
the remedy for the cracks.
Do you have any idea what 19
]
that remedy is going to be?
I think you indicated.that 2a somebody is working on it or something like that.
21 A
No, not on the remedy for the cracks.
22 Q
All righ t, 1.ecs stay with the remedy for the cracks.
23,
Do you know whether anybody is, working on a remedy for cne 24 crackst 25 l A
Not to my knowledge.
i i
ALDERSON MEPORTING COMPANY. INC.
l
17 1
Q Do you know whether anyone conducted any kind 2
of analysis on the cracks in the service water structure 3
to determine the degree to which they could effect saf e ty?
4 MR. FARNELL:
At the operating stage?
5 Mr. PATON:
At the operating stage.
THE WITNESS:
Yes.
7 BY MR., PATON:
(Resuming) 8 Q
Who did that?
d lII A
Bechtel.
10 Q
Bimal. Dhar?
A Civil group.
i 12 Q
You don't know who within Bechtel?
II A
Bimal Dhar is the' supervisor of the civil group.
l"'
I don't know whether he personally did that.'
Q To your knowledge, it was done within the section f
that Bimal Dhar supervises?
A Probably so.
E 18 Q
Do you have any idea what conclusion they made 19 l
as a result of that analysis?
20 A
All the cracks in the service water building were 21 addressed in a question to the Commission, and was
.22 presented verbally by Julius Rotz of Bechtel, in a meeting 23
. held on the site approximately February of '80.
24 !
Q And the NRC was present at that mee ti'ng?
25,
i A
They were present, yes.
f I
ALDERSON REPORTING COMPANY. INC.
18
-N
.l 1
Q What -- Do you know the cause of the cracks,and I
2 l
again I'm not talking about~the shrinkage cracks, at the 3
l service water structure?
4 A
I personally have not investigated those cracks,
=
5 g
but from the meetings and,the response to NRC questions, 8
6 y
' some of the cracks were attributed to settlement.
R 7
j Q
When did you first become aware of cracks in the 8
8
]
, diesel generator building?
I have returned to the diesel d
9 g
generator building.
When did you first become aware of E
10 j
cracks in that building?
E 11 A
I do not recall exactly the time period but it d
12 f
j was soon after the discovery of the diesel generator 5
13 i a
problem.
l 1<4 g
Q What was that approximate date?
2 15 U
A I would say November of 1978.
j 16 W
j Q
Okay, do you have any knowledge as to the effect y
17 i U
of the surcharge program at the diesel generator building 18 l
19 on the cracks in tne diesel generator building?
M A
No.
20 Q
Did you observe the cracks?, You have just stated you observed the cracks bef' ore January.
A I w'r.s aw ar e o f the cracks.
~
23,
.__,1 I
Q When'.did you firsi s.ee the cracks?
24 A
I don't recall.
[
~
25 i
~
Q Do you'have any knowledge cd whethe the; cracks ALDERSON REPORTING COMPANY, INC.
~
19 1, are any different now than they were in November 1978, 2
when you first learned about them?
3 A
I am aware of the present situation of the cracks, 4
to the responses to NRC -ques tions,.acd to my ~ sits; ttsits on e
5 observation,but I'm not fully aware of how different they h
j 6
are from 1978.
R 6
7 Q
Sir, you said, "I'm not fully aware."
A j
8 A
I' m no t --
d I
q 9
Q You're not aware.
Are you aware at all?
E 10 A
I' m no t aware, yes.
l 11 Q
Do you know how often Bimal Dhar visits the site?
3
(
12 A
No.
3a g
13 Q
Do you know how often anyone in Simal's -- 31 mal'E I4 section visits the site?
E I
g 15 A
No, not a specific number, no.
=
g 16-Q Is --does Mr. Keeley have any responsibility to w
h assure that Bechtel performs its function properly in 1
=
}
18 making the remedial action proposed, for example, at the E
g diesel generator building?
O MR. FARNELL:
Could I have that read back please?
21 (Ques tion read) 22 MR. FARNELL:
You're talking about the diesel 23 generator building?
24 l l
MR. PATON:
Yes.
MR. FARNELL:
What do you mean by making remedial i
ALDERSON REPORTING COMPANY, INC.
20 1
actions?
To me that's not clear.
2 MR. PATON:
You mean you have proposed remedial 3
actions -- this whole case is about the remedial actions 4
as a result..of soil settlement problem and you don't know g
5 what I mean by the remedial actions?
?
6 MR. FARNELL:
By making -- the way you have used R
R 7
the term making remedial actions, I don't understand shat it M
8 means.
Designing them, implementing them, c ons truc ting dd 9 I them, I don't know.
There are at least two or three things l!
10 it could be.
1
=
II MH. PATON:
I will clarify it for you.
I don't k
k II know if the witness needs clarification.
In carrying out 4
. l 13 your proposed remedial action--I'll ask the witness even another question.
_"j 15 l BY MR. PATON:
(Resuming) l
?
16 '
g I
Q Do you know what your proposed remedial actions 6
17 a
are at the diesel generating building?
x M
18
=
A Proposed?
19 l
Q Yes.
20 A
I know the remedial actions that have been 21 carried out.
22 Q
Yes, you know those, okay.
Do you remember my 23
- last question or do you want to have it read back again?
24 l l'
A No, I do.
As regards Mr.
Keelq's r sponsibilities e
25 t I am not fully aware or it.
Whatever I say would be ALDERSON REPORTING COMPANY, INC.
21 I
speculation.
2 Q
But I gather from what you told me before, with 3
respect to your structural responsibilities.you report to 4, Mr. Keeley,.with' respect to the remedial action at the 1
=
5 Midland sitet h
j 6
A That's right.
R 7
Q And you don't know what his responsibilities-are 3l 8
with respect to remedial actions?
dd 9'
z.
MR. FARNELL:
I think he said he wasn't fully 10 aware.
That was the terminology he used.
II BY MR. PATON:
(Resuming) m g
12 Q
If you're not fully aware then tell us what you 9
g 13 do know about,them?
m E
I4 A
The responsibility of the remedial' action rests b
g -15 l x
with Bechtel primarily.
That is what I'm speculating.
a 16 And as to how much Mr. Keeley he's responsibile.for that.
hI I don't know.
I don' t know the responsibility structure,
=
i M
18 '
hierarchy, in thuse terms o f "res ponsibility. "
E 19
]
Q When you say Bechtel has responsibility for the 20 remedial action--
Do you know whether any agreement has 21 been reached between Bechtel and Consumers Power as to who 22 is boing to pay for the remedial actions?
23,
j MR. FARNELL:
I'm going to object.
I just don't 24 l l
think this is part of this hearing but you can answer if you like.
l I
i ALDERSON REPORTING COMPANY. INC.
I l
22 1
THE WITNESS:
I don't know.
2 BY MR.. PATON:
(Resuming)
.3 Q
You don ' t know.
If Bimal Dhar visited the site 4
would you know about it?
e 5
A Not necessarily.
h]
6 Q
.Okay, if he visited the site would Mr. Keeley R
I R
7 know about it?
%l 8
A My impress 16n is, not necessarily.
d 9!
Q Is it within Mr. Keeley's scope of responsibility, z
2 10
'j
.with respect to the remedial actions, to make sure that Mr.
=
l 5
II l Bimal Dhar visits the site often enough so M Bimal Dhar a
p 12 performs his f nction with respect to the remedial actions.
3 13 l
MR. FARNELL:
Would you read that back, please.
=
I4 l (Question read) l' 2l 15 i THE. WITNESS:
I don't know.
=
16 BY MR. PATON:
(Resumin3) hI Q
Did you have any involvement in the design or
=
18
=
the diesel cenerator bu11 din structure?
e 19 g
A No.
20 Q
Mr. Thiru, I hand you a piece of paper which I 21 will mark, Thiru deposition Exhibit 2,. dated 12-10-80, 22 and ask you -- can you draw for me -- can you. sketch the 23,
cracks that now exis t in the diesel generator building.
24 i j
(The document referred to, a 25 ske tch drawn by Mr'.Thiru,
.I l
ALDERSON REPORTING COMPANY, INC.
23 j
was marked as Exhibit No. 2 2
for identification.)
3 MR. FARNELL:
Any particular side!
4 BY MR. PATON:
(Resuming)
=
5 Q
For example, do you remember on which wall these hj.
6 cracks were?
R R
7 A
My recollection of these cracks is very vague, 3
j 8
but I remember two cracks as regards.to the. location.
d 9
Q And what wall were they --
10 A
That is the third wall from the west.
E 11 Q
Is it a center wall?
mj 12 A
There are -- There is one on the center wall.
3 5
13 They are four cubicals..
3
=
I4 I Q
Before you draw the sketch cracks, let me ask 3
E 15 you this.
Are there any cracks in the north wall?
g 16 A
I do not recall.
w h
37 Q
Are there any in the south wall?
5 18 A
Probably there are, I do not recall.
19 g
Q Are there any in the west wall?
0l A
I do not recall.
I Q
Are there any in the east wall?
2 A
I do not :ecall.
23 i
Q KR. dgh t,. now I want to ask you this question, 24 Mr. Thiru, who is it in Consumers Power Company, that has 25 i j
the responsibility to see that any problems which arise l
l ALDERSON REPORTING COMPANY. INC.
24 1
1 rom these cracks is remedied.
2 A
The ultimate responsibility rests on the project 3
engineering manager.
4 Q
Who has the day to day responsibility?
=
5 A
We don't.have a day to day responsibility with 5
6 Consumers.
Day to day responsibility 1s on Bechtel.
R 7
Q What is your responsibility with respec t to 3
l 8
these -- remedying these cracks?
dd 9
A I work under the direction of Mr. Keeley, and if E
h 10 there is a problem or if there is a response to a question, s
E II Mr. Keeley requests me to review them -- and I do the 3
g 12 review and take necessary action.
3 13 j
Q I
ather from your answer it's a response -- kind w
I4 of a responsibility.- In other words you do somethin3 only 5
g 15 l when -- when someone comes to you with a problem?
=
g 16 MR. FARNELL:
We're talking just about cracks e
6 17 !
a now?
5 MR. PATON:
Cracks in the diesel generator 19 j
building.
20 THE WITNESS:
That is true.
21 BY MR. PATON:
(Resuming) 22 Q
Is there any responsibility within Consumers 23,
Power to do something more than merely respond to a 24llproblem but to go out and try to supervise the problem?
25l MR. FARNELL:
What do you mean by supervise a ALDERSON REPORTING COMPANY, INC.
25 1
problem?
2 BY MR. PATON:
(Resuming) 3
.Q Alright I will eliminate that from my question 4
and ask.you this.
g 5
Does anybody in Consumers Power have any respon -
8
.j 6 lsibility with respect to remedying those cracks other than R
7 to respond to a problem that somebody brings.to them?
X-j 8
A The cracks may be observed by the Consumers field d
m; 9
engineers.
They get together with Bechtel and us and the 10 Jackson office and we resolve the ~oroblem.
E i
Il Q
Alright, Mr. Thiru, would you sketch on this 3
y 12.
piec.e of paper which I have marked deposition Exhibit No.
l 3
5 13 l 2,,yourmemory of the cracks and let me ask you again, your
=
14 l recollection is you think this is on one of the center
=j 15 walls?
z j
16 A
Yes, and again I want to emphasize this is my d
l C
3 17l' recollection to date.
z 18 '
Q And to your knowledge, is this your recollection
=
19
)
of the cracks as they exist now or as you knew them a year 20 ago or when?
A As I knew them a few months ago.
22 Q
Alright, sir.
23 '
(Pause) 24 I I
Mr. Thiru, you drew two x's on this piece or 25 j paper.
What I'm asking you to do is show me where the i
ALDERSON REPORTING COMPANY. INC.
26
~
1 crack began and where the crack ends.
In other words, I 2
want you, to draw the cracks for me.
3 A
Okay.
4 (Pause) g 5
'Q Are the two cracks that you ' ve drawn here, not 8
6 shrinkage cracks in your opinion?
R d
7 A
It was reported to be -- it was reported not to 2
g 8
be shrinkage cracks.
d N
9 l Q
Do you have an opinion as to whether they are z
10 shrinkage cracks?
=
II A
I haven't investigated.
to determine whether they 3
y 12 are shrinkage or not.
And also thoses figures are obvi-3 13 j
ously no't to scale.
3 14 '
G Q
Okay, now I'm --I'm -- Let me ask you this.
$j 15 You've drawn thrae blocks on this piece of paper.
The top
=
block has four sections to it.
Are we looking at the side C
17 '
d of the building, top of the building or what?
=
i 5
18 A
The top sketch is a representation of a plan and g
19 l
the --
2a Q
Mr. Thiru, I'm sorry -- that just doesn3t l
and.it's my problem -- but that doesn't mean anythits to 22 l
l
- me -~~.A plan. 'Aretwe locking at the top?
I 23!
A From the top.
i 24 i Q
From the top.
Okay now, down here, this is wall 25 f
A,which is one of the center walls, is that correct?
1 ALDERSON REPORTING COMPANY. INC.
\\
27 1
A That's right.
1 2
Q Can you tell me on the top plat, which you have 3
marked plan-- and I wrote something on there which I will 4
eliminate,.which is north and south?
e' 5
A
.This is north and south,
.h j
6
.Q Okay now --
When you drew this -- which is the --
C b
7 showing the crack for wall A on-the lower right three blocka A]
8 on this exhibit, were you f acing eas t or wes t?
May I d
d draw an E right'there, would you agree that's east?
h 10 A
Yes.
=
l' Q
That is wes t?
12 A
Yes, I'm no t sure in my presen t recollection as-3 13 j
to which side of the wall the.se cracks were.
They were on E
14 d
the walls.
E r
15 g
Q When the diesel generator building was designed, g.
16 do you know the total.and differential settlement that was C
17 1 3
l considered in the design?
b 18 g
A No.
19 l
Q Would you expect, considering Mr. Dhar's respons-i0 ibility, that he would know tha t?
21 A
Sure.
22 Q
Do you know whether that information was presentect 23 in a PSAR?
24 A
My recollection is that PSAR does no t have a 25l l reference to the dieselcgenerator':buaidIdg.
I I
l ALDERSON REPORTING COMPANY. INC.
e
28 1
Q Would that information be in the FSAR?
2 A
Yes.
3-Q Okay, I said would it be in?
Do you know in 4
fact if it is in there?
=
5 A
There -- yes.
h
,]
6 Q
In your judg. ment just a minute -- do you
.E 7
know with respect to the surcharge program in the diesel
]
8 generator building, was an analysis performed to evaluate dd 9
E.
the impact of the expected settlement on the structure?
y 10 MR. FARNELL:
Would you read that back?
E II (Question read) m g
12 Expected settlement under the surcharge?
3 g
13 MR. PATON:
Right, right, settlement expected
=
14 from the surcharge.
What impact would it have on the
=
j 15 ! structure?
=
j 16 THE WITNESS:
I don't know.
e h
BY MR. PATON:
(Resuming)
=
18
=
Q In your professional judgment, should that have 19 l
been done?
20 A
If it is considered important and if it is 21 considered that it might have measureably Sreater effect 22 on tae structure, yes.
23 I Q
Mr. Thiru, you're the expert so I don't know 24l whether it's important or not.
I'm asking you in your 25 '
professional judgment, should it have been done in the ALDERSON REPORTING COMPANY. INC.
29 1
Midland case, at Midland?
l 2
MR. FARNELL:
I think he answered that.
3 MR. PATON:
He said if it was important he 4
should do it.
I could probably reach that conclusion my-5 3
3,1f, a
f6 1
I'm asking in his professional judgment, is it n
8 7
impor tan t?
a 8
8 a
MR. FARNELL:
He doesn't have to give you a yes i
d-d 9
y
. or no answer.
=
g 10 z
F. R. PATON:
He doesn't have to -- no that's fine E
11 g
with me.
He can,give me all the answers he wants.
d 12 2
j MR. FARNELL:
He did.
3 13 i 3
l THE WITNESS:
I do not know the initial stresses E
14 y
in the building, so it is difficult to reach a professional 15 g
judgment without knowing the stresses in the building.
T 16 1 BY. MR... ? ATO N :
(Resuming)
N 17 3
Q Do you know prior to the imposition of the sur-5 18 g
charge program, that the diesel generator building had 19 some differential settlement?
20 A
I have.been aware of that through the settlement 21 plots.
22 Q
And your -- considering everything you know about 23 24 l the diesel generator building and the soil under the diesel generator building, I'm asking you whether in your pro-25.
i l
ressional judgment, an anaylsis should have been made to ALDERSON REPORTING COMPANY, INC.
30 1
evaluate the impact of settlement to be expected under the 2
surcharge load?.
3 MR. FARNELL:
That's*the exact same question you 4
asked before, and he answered it once and he answered it g.
5
- twice, e
6 MR. PATON:
No, no, after that we established W
l b
7 his knowledge.
For example, he was aware that there was Al 8, differential settlement in the diesel generator building.
I d
m 9
Now I'm askids him to assume everything he knows c
h 10 about the diesel generator building and in his professional
=
judgment is that g
12 MR. FARNELL:
The quection as it was asked the 3l first time *had to assume his knowledge.
I don't think'you E
14 l E
added anything to it.
e r
15 I g
MR. PATON:
Are you directing him not to answer 7
16 l j
that?
You know he's a structural engineer.
He's Consumers 6
17 w
i Power's expert.
=
l M
18 If you instruct him not to answer that question 19 l
that's fine; Indon't think I.'ll certify that.
If he 2o doesn't want to answer that question.that's fine with me.
21 Will you answer the question, please?
22 MR. FARNELL:
My objection was you already asked 23 and he answered.
Do you have anything to add to your 1
24 previous --
25 I
MR. PATON:
No. I want you to answer my question.
ALDERSON REPORTING COMPANY. INC.
31 1
If'he refuses to answer my question that's -- that's fine.
2 THE WITNESS:
The settlement blocks do not clearl;'
3 show whether the set :lement was differential in terms of I
4 global, or differential in terms of structural displacement 5
BY MR. PATON:
(Resuming) h
[
6 l q
.Are you indicating there was some uncertainty as 7
to whether there was differential settlement at the diesel 3
8 senerator building?
d
}".
9 A
No, there is difrerential settlement but if C
10 there is a total body movement it would not have caused z=
lII stresses in the building.
g 12 Q
Is there some uncertainty in your mind now as to 3
I l
whether, prior to the surcharge, the diesel generator i
l 14 b
building was under some kind of stress?
2 15 g
A No.
16 g
Q You know it was under some kind of stress?
6 17 '
a A
I know it is under some kind of a stress.
x 18 Q
What kind of stress was it under?
E 19 l
A I do not know the exact amount.
20 Q
What other kind of information would you have to 21 know, that you do not now have,to allow you to make a judg-22 ment as to whether an anaylsis should have been performed 23 to evaluate the impact of the effect of settlement under 24 the surcharge program at the diesel generator building?
25l l
A I would have to knuw the initial stresses on the ALDERSON REPORTING COMPANY. INC.
32 I
building, I would have to know whether the structure itself 2
suffered differential aettlement and not a rigid body 3
motion.
t 4
I would have to know that the surcharSe is going I
y 5
i to cause additional structural differential settlement n
6 rather than rigid body movement.
i R
b I
With this information I could conclude whether a X[
8 l total anaylsis is needed or whether this could be missed d
I 91 d
}.
i by inspection.
=
h 10 ll Q
Okay, am I correct,.your testimony is that you
=
i
,5 II do not how know those things?
d 12 l z
l
'A I do not know those things, yes.
Sl Q
Is it possible that se ttlement of the diesel l
14 l generator building was rigid body motion and in fact there
,h i
C 15 l j
i was no differential settlecent?
?
16 A
It is possible, d
17 I
y Q
Do you -- are you certain that there was -- that 5
18 g
the diesel generator building experienced differential 19 l
settlement prior to the surcharge program?
20 A
When you measure the settlement at two corners 21 of the building and you call that as differential settle-22 ment, the blocks show that there bas been differential 23 !
settlement.
24 i I
Q I'm sorry I don't understand.
Did ycu -- your 25,
! answer I don't think was a direc t answer and I Just don' t ALDERSON REPORTING COMPANY, INC.
33 I
understand it.
My question was are you certain whether 2
there was differential settlement at the diesel generator 3
building?
I would appreciate a yes or no and then you can 4
explain it all you want. I just didn't understand your
=
5 answer.
h 3
6
.A Yes.
R OS 7-Q You are certain that there was?
Xl 8
A Yes, the blocks show it.
There was differential d
c 9
settlement between two corners of the building.
E h10 Q
Do you know how much that settlement was?
That
=
5 II differential settlement was?
m k
I2 A
I don't recall the precise value.
g 13 Q
So there was more involved than rigid body motion 1 s
14li E
MR. FARNELL:
Prior to the surchargei w
i 9
15 I s
. MR. PATON:
Prior to surcharge.
4 f16 l
THE WITNESS: I don't understand the question.
d" 17 l' BY MR. PATON:
(Resuming) x I'
18
=
Q Okay, you answered it.
19 l
Did the settlement records show rigid body 20 motion?
21 A
Again, I did no t inves tigate the settlement 22 records.
I observed the plots and the presentation made j
23l! in meetings which showed a com bination of rigid body move-ment and differential settlement.
25 Q
Mr. Thiru, I forgot your answer.
When I asked 1
l l
ALDERSON REPORTING COMPANY, INC.
i
3h 1
you -- we had some discussion about whether an analysis
-2 should have been made in your judgment bu t I t hink bef or e 3
that I asked you a question about whether or not, in fact, 4
such an analysis had been made.
g 5
The analysis I'm referring to is one that e v.alu a t e d s
3 6
the impact of the settlement under the surcharge load.
Rh7 What was your answer?
Has such an analysis been made?
8 A
I told you I do not know.-
i d
f9 Q
You do not know.
Does Consumers have any problem 0
10 g
measuring actual settlement at the site?
What I'm getting
=
5 II at, is' there any difficulty with your survey data or any-a g
12 thing you used to measure actual settlement at the site?
Sj,13 MR..FARNELL:
Are you referring to any specific E
14 g
bu11 din 57 9
15 '
g MR. PATON:
No, generally.
16l T
g MR. FARNELL:
Could you read the question back?
F 17 d
(Ques tion read)
=
5 18 E
MR. FARNELL:
I don't understand the question.
19 l
BY MR. PATON:
(Resuming) 20 Q
How do you measure actual settlement?
21 A
I want to clarify that by a statement that 22 Bechtel is responsibile for evaluating the settlements.
23,
Q Okay.
24 i
A Are you implying to Bechtel or Consumers?
i 25 !
Q Yes. In other words I appreciate the fact that i
i e
i ALDERSON REPORTING COMPANY, INC.
35 1
Bechtel's responsible.
Does Bechtel or Consumers -- is 2
there any difficulty, to your knowledge, in measuring 3
actual settlement at the site?
4 A,
Not to my knowledge.
5 Q
For the design of the diesel generator building, 3
6 what values of modulus of subgrade reaction were used?
n R
7 A
I do not recall.
n l
8 Q
Is that -- is that something that would be deter-d i
d 9
l g
minded by Bechtel?
h 10 z
A Yes.
=
E 11 g
Q-
- 0kay, do you personally have any responsibility 4
12 Z
with respect to the structural work done by Bechtel other 3
13 l 5
than to respond to requests for information or respond to
'y 14lI E
~
the problems brough to you?
E is '
y MR. FARNELL:
Repeat that, please.
Read that
~
16 back.
6 17 l g
l (Question read) 18
=
MR. FARNELL:
The. question assumes several 19 l
factors that I don't think he testified to.
I'm going to 20 object to it.
21 BY-MR. PATON:
(Resuming) 22 Q
Can you answer the question?
A The question is not,very clear.
My responsi-24 l bilities were stated earlier.
I do not have a direct 25 '
j responsibility to what Bechtel is doing in-house.
I ALDERSON REPORTING COMPANY, INC.
'36 1
Q Okay, you have repeated several times that when 2
I asked you a question you answered that's Bechtel's 3
responsibility.
4 A
That's right.
=
5 Q
I'm trying to find out what your responsibilities h
i j
6l are with respect to Bechtel and I f ather so f ar that you 7
have none other than to respond to reques ts for infor-a j
8 mation.
d m;
9 A
To review.
I h
10 Q
Okay.
Now, do you converse with Mr. Keeley?
=
l 5
II (Short recess taken) g 12 BY MR. PATON:
(Resuming) 5j, 13 !
-Q Mr. Thiru, tell me in very s'eneral terms what E
14 g
Bechtel is responsible for with respect to structural
~
9 15 g
work, for. example, at the service water structure..
From g?
the begining, from the design of the plant on.
16 d
1:7 !
g j
I do mean in general terms as opposed to what E
18
=
Consumers does.
19 j
A Generally, my understanding is Bechtel would be 20 responsible for laying out of the structure, planning the 21 structure.
22 Q
Planning?
23 A
Designing the structure and construction of the 24 l l
structure and whatever associated monitoring prograqs 25.
l there may be.
I t
ALDERSON REPORTING COMPANY, INC.
J
c 37 1
Q Okay.
Now with respect to those activities, does 2
Consumers Power review the work Bechtel doest 3
A Consumers Power reviews in general the work done 4
by Bechtel.
5 l,
Q Okay now.
Now I want to ge t a little more s pe-n 2'
6 cific.
You say they review in general.
Tell me a little
?
h7 more about that.
For example, laying out the structure.
n 3
8 What does Consumers do to review the work that 3echtel does a
d6 9
j and at the Midland Plant, I mean, I want to know what in C
P 10 I i
j fact happens.
11 l j
A I can only speak in terms of what happened afteray d
12 g
joining the Consumers Power.
By the time the service E
13 3
water building has been laid out, designed, and constructed.
E I.4 i d
l Q
And planned?
k i
9 15 j
i, A
And planned.
16I l
Q All right, with respect to the -- thert is a pre-6 17 i posed remedy at the service water structure, is that correc t?
g i
18 A
That's right.
E 19 Q
And Bechtel is responsible for that proposed 20 review?
21 l A
That's right.
22 Q
And how long has Bechtel been working on that?
23,
l A
I would guess about more than a year.
24 i l
Q Okay, now you used the work guess, that was a 25 t
i figure of speech wasn't it?
I ALDERSON REPORTING COMPANY, INC.
38 l
A I do not know the exact time.
2 Q
Would you estimate about a year?
3 A
About a year, yes.
4 Q
All :righ% now tell me what has Bechtel done in 5
j that year with respect to the proposed -- for the service n
@.6 water structure?
5 7
j Q
Bechtel has evaluated a proposed fix and is still n
8 8
doing the evaluation.
The final design is no t comple te a
d 1
d 9i i
l yet.
'h 10 ll z
Q AE right, they're evaluating -- they have been
=
E 11 g
evaluating a proposed fix and they're working on a design?
d 12 E
A That's right.
S' 13 i
Q Tell me dur.ing the last year what review E
14' y
Consumers Power had made of that work _ beins done~by.;
5 15 y
Bechtel?
?
16 A
Consumers reviewed the concept of the fix.
6 17 i i
Q Have you completed your answer?
g M
18 A
Yes.
0 19 Q
Tell me what you mean by the concept of fix.
20 What is -- what is the concept of the fix at the service 21 water 'tructure?
s 22 A
Bechtel proposed to transfer the load from the 23,
- cantilever portion of tne service water building by means 24 of piles to the glacial till level.
25,
'Q And Consumers reviewed that concept?
l ALDERSON REPORTING COMPANY, INC.
6 39 1
A That's right.
2 Q
And did Consumers approve that concept?
3 A
Consumers, based upon the recommendation of 4
Bechtel and their consultants agreed with tne concept.
y e
5 Q
Who in Consumers reviewed that concept?
h j
6 A
Myself and Mr. Keeley.
R d
7 Q
Tell me all of the specifics that you were 2
j 8
aware of with respect to the concept prior to your approval 4
i c
9I of it.
I mean what did you know about that concept 1
,z 10 MR. FARNELL:
I think it m16ht be easier it we II made it a little more specific.
Instead of saying sive m
l II l me everything.
3 13 j
BY. MR... P ATO N ;
(Resuming) 14 Q
Well, you told me-- you told me the' concept j
15 consistdd of transferring the load from.the cantilever a
f 16 l portion by piles to the glacial till.
Is that all you d
17 knew?
i x
5m 18 A
No.
19 l
Q Tell me what else you knew?
20 A
I do not recall the specific details at this 21 moment.
What I recall is as follows:
Bechtel proposed 22 sixteen piles and proposed a corbel system to transfer the 23 load from the pile.
They didn't propose to us the details 24 l in terms of pile capacity, diameter of the piles, I do 25 not recall them'now.
l I
ALDERSON REPORTING COMPANY. INC.
40 1
Q I'm sorry, you say they did but you just don't 1
2 l remember the numbers.
Okay, you said they told you the 3
pile capacity and you said something else?
4 A
File diameter.
3 5
Q What else did they tell you'besides the fact that 8
j 6
they were going to use sixteen piles, they were going to R.
7 use a corbel system and they told you the pile capacity s
]
8 and pile diameter.
What else did'they.tell you?
dd 9
E.
A That's rather a general question.
h 10 Q
No, I think its an extremely specific question.
l 3
II Did they tell you anything else, the answer is either yes 3j 12 or no.and you can explain your answer.
s 13 j
A Y,es,but I don't recall specific. items.
I4 Q
Okay, without getting into specif1'es, do you kj 15 remember the general subject matter of what it is they a
16 told you about?
6 17 '
A They discussed a transfer of the load from the a=
M 18 I
=
corbel to the wall and the method of transferring the load 19 l
from the pile to the corbel.
And the method cf driving 20 the piles.
That's in general.
21 !
4 Q
Okay, do you remember what they told you about 22 the method of driving the piles?
23 They were designed to be pre-drilled piles and A
I j
24 l a hole would be drilled with a diameter smaller than the 25l pile diameter and the pile would be driven from the top l
ALDERSON REPORTING COMPANY, INC.
41 1
of the building.
2 Q
Did you evaluate this concept?
I think you did 3
say you evaluated this concept and approved it.
4(
A Reviewed the concept.
5 Q
You reviewed it and approved it?
E 0l A.
Agreed with it.
R I
Q Agreed with it.
Did anyone else share -- assist j
8l you in.your review of this concept?
df' A
Within Consumer Power Company?
E 10 s
Q Yes.
l
~
h l
A I do not know for sure.
d 12 I E
Q And did you, with respect to your review of this S
13 i
concept, did you report to Mr. Keeley?
3 14 g
A Yes, sir.
E 15 i j
Q Tell us what you said to him about this concept.
16 A
I don't know what.I actually'.haid to Mr..Keeley 6
17 j y
about this concept.
The decision could have been reached 5
18 g
in a meeting in which Mr. Keeley was there.
19 The fact that I did not raise any objection to l
20 l
the scheme -- or I might have told him that I agreed to 21 the scheme.
I do not know the exact conversation. These 22 were the possible ways in which it could have happened.
I 23,
Q But you don' t really remember?
24 ;
A I do not remember, yes.
25 ;
Q Did Mr. Keeley say anything to you about this I
ALDERSON REPORTING COMPANY. INC.
l
42 I
concept?
l 2
A I do no t remember.
3 Q
Is Mr. Keeley a structural engineer?
4 A
No.
=
5 Q
You report to him in this regard because he is 5
6 l your supervisor, he's been designated as your supervisor 7
in this regard?
3l 8
A That's right.
d-l 9l Q
Mr. Keeley's -- I'm not trying to embarrass you.
10 Mr. Keeley'is not as competent in structural engineering E
I l
II as you ares
%s he?
{
12 MR: FARNELL:
You can take the 5th amendment 13 if,you want.
Do you understand?
b I4 THE WITNESS:
I do no t know that for sure.
l l
15 BY MR. PATON: (Resuming) x 16 Q
I think I will have to let that go.
g 17 Has Mr. Keeley, to your knowledge, spent any aa 18 substantial periods of time acting in the capacity as a E
19 l
struc.tural engineer?
20 A
I do not know whether he acted in a capacity as a structural engineer.
22 Q
Okay, did you report to anyone else or did Mr.
23!
Keeley report to anyone else with respect to this concept.
24 I
A I do not know about Mr. Keeley.
I had reported j
to Mr. Keeley, that's for sure.
l ALDERSON REPORTING COMPANY. INC.
53 1
Prior to joining the Midland -- full time in 2
Midland in May of '80 I reported to Mr. Jack. Hunt.
I 3
might have reported this to him.
I'm not sure.
4 Q
Do you know whether Bechtel or Consumers consi -
=
5 d ered any alternative to this concept?
I
[.
6 A
I recall one of the alternatives were to provide 7
jacked piles or caissons.
Nl 8
Q Was it -- was it ever considered to take it out d
c; 9l and start all over again?
10 A
Not that I'm aware of.
II Q
In your professional judgment, at the time you k
{
12 reviewed and approved this concept, did you have ad4quate 13 soils information to review and accept this concept?
m A
For' soils information, I relied upon Bechtel i
and Bechtel consultants.
I Q
Okay, and what did they tell you?
d 17 !
A They told me that this scheme is feasible, a
N 18 Q
They told you the conclusion that the scheme E
19
{
was feasible?
4 20 l
A Yes, sir.
21 Q
What did they tell you about the soils?
22 A
I'm referring to the soils.
23 l Q
You mean that the soils were feasible?
24 A
You raised a question whether I was aware --
25l information on soils?
l 1
ALDERSON REPORTING COMPANY. INC.
e 44 1
Q Yes.
2 A
And my response was I relied, for. the information 3
on the adequacy of the soils from -- on Bechtel and consul-4 tants.
=
5 Q
Okay, did they give you any information about h{
6 the soil or did they just give you information that their 7
conclusion -- that there was no problem with the soil?
K j
8 I'mean did'they give you any soil parameters?
9 9
I'll ask the ques tion in another way if it's giving you 10 any difficulty.
I think my question is quite. simple.
lII Did you merely rely on their conclusions or did YI they, in fact, give y'au some specific information about b
[
13 the soil in which you could make your own judgment?
A I relied specifically on Bechtel and consultants on the soils.
Q And you had -- Consumers had previously relied d
17
! on Bechtel, with respect to the soils in placing the plant a
h 18 fill, had they not?
E 19 l
A This is right.
2e Q
And that didn't work out very well, did it?
21 MR. FARNELL:
Objection.
22 BY MR. PATON:
(Resuming) 23 l
Q Vas.there not subsequent to that a rather sis-24 I l
nificant problem with the plant fill?
25 i A
There was a problem.
l l
ALDERSCN REPORTING COMPANY, INC.
y.
45 I
Q I would suggest that the problem was significant, 2
do you agree with that?
3 A
It's a matter of opinion.
Q What is your opinion?
5 j
A Reasonably significant.
8 6
l 1
Q Easily a multimillion dollar problem, is it not?
E 7
A From an economic point of view, yes.
n]
8 Q
Now* bearing.in mind che fact that you had relied e
i i
9l on Bechtel on one instance, with respect to placement of g
i 10 fill.
I 11 l g
Did you consider it appropriate in considering d
12 3
the concept in this case to again rely on Bechtel with S
13 3
respect to information about the fill?
E 14 l j
'MR. FARNELL:
You're mixing up two things. The 15 g
placement of fill and information about the fill.
j 16,
w j
MR. PATON:
If the witness tella me there is i
17 !
W absolu tely no connec tion be tween those two, that's fine, b
18 g
I will move on to the next question.
19 MR. FARNELL:
You're making connections which 20 I don't think you asked.
21 MR. PATON:
If the witness can't make that 22 connection, that's fine.
23 l
BY MR. PATON:
(Resuming)
Q Is your attorney right?
You saw no connection 25l between those two?
I ALDERSON REPORTING COMPANY. INC.
~
46 1
A Would-you repeat that question, please?
2 (Question read) 3 THE WITNESS:
You have addressed the issue at the 4
. fill twice.
i a
5 BY MR.. PATON:
(Resumins) 5 3
6 Q
In fact right at the end of that last question a
I 7
I thought I said soil, perhaps'I said fill.
M l
8 Do you want me to say it again?
d" 9
~.
A Yes, please.
O h
10 Q
You relied upon Bechtel, with respect to plant
=
,k II fill, and thereafter you developed a problem which may be
^
fI a sign'ificant problem.
Sj!
In light of -
you later Ladicated that consid-m h
er.ing the concept of the fix of the service water structure
=
9 15 g
you did not receive any specific information about the
~
16 g
soils.
You relied again on Bechtel, with respect to the Y
17 d
information that they gave you about the soils.
x 18 MR. FARNELL:
I don't think he said he didn't E
19 get any specific information.
20 BY MR. PATON:
(Resuming) 21 Q
Allr
-ht, tell me'what.you got then.
22 I'm not aware --
A I could have received -- but 23,
j I'm not aware or the specific information.
24 l
.i Q
You don't knowLif you received.any specific 25 !
information?
ALDERSON REPORTING COMPANY, INC.
l
0 47 1
A That's right.
i 2
Q I thought you had answered tne question telling 3
me that you had not, that you.ad relied on Bechtel's 4l conclusions with respect to the soils?
e 5
MR. FARNELL:
There 's, no thing inconsis tent on h
6 relying on a conclusion and getting specific information.
Rf7 BY MR. PATON:
(Resuming)
[
8 Q
I will ask you again.
Your statement is you don'b d
I d
9l remember whether -- in connection with your consideration
$l 10 l1 of the concept of the fix at the service water structure, Il you received any specific information about the soils?
m j
12 A
I could have but I do not recall.
N 13 l
,5 l
Q You do not recall.
Do you know whether you were 14 I ever told what the depth of the penetration'into the glacial h
j 15 till was to be?
Ibl' A
There was a discussion.
17 3
Q Do you remember it?
=
5 18 '
A No, I don't.
19
)
Q How long ago did that take place?
I A
I do not remember that either.
l i
21 Q
Do you know now how far the piles are extended 22 into the glacial till?
23 l l
A No.
24 Q
Do you know if Bechtel know.s?
25.l
~
A I know Bechtel knows.
l ALDERSON REPORTING COMPANY, INC.
~
48 i
1 Q
Mr. Dhar knows or his section, someone in his sectio. l 2
A Since this is an area of geotechnical engineering 3
I think probably the geotechnical engineer of Bechtel l
4 would know this information for sure.
e 5
Q Okay.
Let's'take five minutes.
8 j
6 (Short recess taken)
R b
7 BY MR. PATON:
(Resuming)
Nl 8
Q What was the purpose of the surcharge at the d
l diesel' generator-building?
Q h
10 ll A
My understanding is to consolidate the fill.
=
Did it accelerate the rate of settlement?
Q A
It' accelerated the rate of settlement compared S!
to the settlemept measured previous to surcharge.
Q Did'it in anyway improve the safety of the diesel 15
~
g generator building?
16 l
MR. FARNELL:
Safety in an operating sense?
17 i g
i MR. PATON:
I think you can leap all the way to 5
18 that operating stage but if you'.want it clairfied, yes.
E 19 BY MR. PATON:
(Resuming) 20 Q
The safety at the operating stage.
21 A
The surcharge consolidated the fill.
Thereby 22 providing a firm foundation for the building.
Thereby 23 l increasing the safety of the building.
24 l l
Q Wouldn't the weight of the completed 25 ALDERSON REPORTING COMPANY, INC.
9
49 I
itself have eventually consolidated the fill under the 2
diesel generator building?
3 A
It would have taken a very long time.
4 Q
Right, that's my point.
In other words, what it j,
did was to accelerate the rate of settlemen t.
'8 6
1 l
A I agreed to that.
n R
7 Q
.Okay.
Did it -- the surcharge aggravate the E
8 cracks that were in the diesel generator building?
I d
9 i-g l guess my recollec tion isnit -- I don't kn,ow the answer to o
1 g
10 z
that bu t -
anyway I'm sorry.
5 11 '
s A
I do not recall.
d 12 Q
'Sorry about that.
Did it aggravate differential m2 13 '
5 settlemen,t?
E '14
[b A
After the surcharge there was ---I'm sorry, there 2
15 l s
were differential settlements.
I do not know.at this j
16 l s
point whether it aggravated it as compared to before.
y 17 i g
i Q
Did the surcharge program in. any way reduce the 5
18 5
amount of settlement?
19 M
MR. FARNELL:
Compared to what?
Would you 20 read the question back, please?
21 (Question read) 22 BY MR. PATON:
(Resuming) 23,
I Q
Compared to what you, would have expec ted --
24 '
would have resulted from just the bu11d1'ng being there 25j l
1.tself ?,
1
~.
ALDERSON REPORTING COMPANY, INC.
i
\\
50 1
A I do not fully understand the question.
However 2
I would like to make a statement that I have only very 3
limited background in geotechnical engineering to evaluate 4
settlements.
=
5 Q
Well, but doesn't a structural engineer -- is h
j
'6 very interested in knowing about settlement and differentia:.
R R
7 s e ttlemen t?
Al 8
A Yes,~yes.
d d
9 Q
Do you know whether there are any gaps under-
.z 10 neath the wall footing of the diesel generator building?
5 II A
,I have been informed that there are gaps.
m h
12 Q
Did you ever see the gaps?
3 g
13 A
No, I have not seen the gaps.
g 14 !
m Q
When did you find out there were s'aps under
_b.j 15 the wall footings?
=
16 A
I do no t know the timing.
h7 Q
Okay.
What is the present status of those gaps?
z 18 Are they being fixed?
E 19 l
A There was a program to grout under the gaps.
20 I'm not aware whether that has been carried out or not.
21 Q
That would be done by Bechtel?
22 A
Yes.
23
-Q When Bechtel performs that work, do you in any-24 way review what they did?
25l' l
A Review the actual grouting process?
I ALDERSON REPORTING COMPANY, INC.
51 1
Q Review the work that they did in whatever manner 2
that you do it.
Whether you review the actual process --
3 I mean do you do anything about it?
Do you do anything l to verify that what they did.was effective?
4 i
,g 5
A.
The work done by Bechtel in the field'comes R
2 0 ; under the jurisdiction of the field Consumer personnel.
R c
7 Q
, I gather you have no *!sponsibility to review j
8 i
that work-- the work that we're talking about here?
d i
6 9l A
'Yes, I do not have the responsibility to review j
C P
10-i the actual 5 routing process.
=
i E
11 l g
Q
~0kay, fine.
Go off the record for just one d
12 3
second.
(Dicussion off.the record)
E 14 *i y
BY MR. PATTON:
(Resuming) 3 15 Q
Do you know the program that is planned to
\\
16 l l-
{
treat these gaps?
d l'7' y
A The plan was to grout the gaps.
5 18
=
Q Do you know how many aaps there are?
19 I k
A I do not recall.
20 Q
And it's correct, you do not know whether these 21 gaps.-have been grouted.yet or. cot?
22 A
That's correctv 23 !
Q Are you familiar with the seismic analysis that 24 l I
was performed on the diesel generator building?
25 l i
MR. FARNELL:
What time?
ALDERSON REPORTING COMPANY, INC.
i
52 1
BY MR. PATON:
(Resuming) 2 Q
The original analysis for the application for 3
the construction program?
4 A
I am aware a seismic analysis has been performed g
5 for the diesel building.
I'm not familiar with the details 8.
]
6' Q
That analysis was performed by Bechtel?
I b
7 A
'Yes.
K]
8 l
Q You have a -- just a. minute.
Do you have any d
I
}".
9 I
training in seismic design of structures?
i 10 A
Yes.
=
,k Q
C'ould you describe that please?
Describe what that training' consis ts of.
3 13 j
l A
I have taken courses in my graduate program on E
g 14 lIanalysis, structural analysis, and I have reviewed some 9
15 !
j i
seismic analysis of structures.
16 l T
j l
I did not participate in -- I did not participate d
17 g
in a training program for seismic analysis of structures.
5 18
=
Q So you have some training and you have some 19 l
experience.
You have some education and some experience 20 in this field?
21 A
Review experience, yes.
22 Q
What soil parameters would you need in order to 23!
perform a seismic analysis, for example, at the diesel j
generator building?
25 '
A You would need the modulus of elasticity, ALDERSON REPORTING COMPANY, INC.
53 1
the sheer wave velocity, and dampine.
2 Q
Is that all?
3 A
At this moment, that's all I can' recall.
4 Q
Would you have to know for different soils, and i
5 different depths, strain dependent sheer modulu.s?
6~
MR. FARNELL:
Repeat that, please?
j b
7
~
BY MR. PATTON:
(Resuming) 3 j
8 Q
I'll repeat it.
Would you have to know for 0
f.
9 differen't soils, at different depths strain dependent h
10 y
she er modulus?
=
E 11 I g
A It is a function of what anaylsis you do.
For c
12 3
the anaylsis done by. Bechtel you could derive the founc 3
13 l j
dation spring constants from the value -- from the parameter.s E
14 g
I have given there.
9 15!
j Q
Would you make a soil stratification profile?
?
16 l
A I. don't understand y6ur question.
i 6
17 l y
j Q
Do you recall that this follows the question of 5
18 !
g what soil parameters you would need to perform a seismic 19 l
analysis?
To perform a seismic anaylsis would you need i
20l to make a soil stratification profile?
21 A
For the type of analysis I mentioned previously 22 it takes an average of the soils present under the building 23,
l so you need not make a soil stratification.
24 Q
Have you performed a seismic anaylsis of the 25,!
diesel generator building after the surcharge was removed?
l 1
ALDERSON REPORTING COMPANY, INC.
a.
54 1
A I did not.
2 Q
Did Bechtel?
3 A
They were in the process of doing it.
4 Q
And do you know whether in that in performing 5
that seismic analysis they plan to take an average of the j
6 j soil as opposed to making a soil stratification profile?
1 7
A That is what I recall from the responses to the M
8 questions, summary to the Commission.
d 9
Q-Mr. Thiru,.am I correct, that you stated with 10 re s pe.c t to the soil parameters you would need to perform 5l II a seismic anaylsis? You did not necessarily g
12 need to determine strain dependent sheer modulus, is that ad 13 g
correct?
E 14 A
From what I recall in your earlier ques tion you g
stated for soil strata.
Am I right?
You have the --
?
16 ;
Q I see, I did preface that with. ror different d
17 a
soils and different depths, is that what you mean?
x 5
18 A
E That's right.
19 l
Q How will Bechtel address variation of sheer 20 modulus with strain?
21 A
Bechtel uses the soil spring cons tants and soil 22 damping in there analytic model.
The equation for those 23 l
soil spring constants and damping are given in Bechtel's I
^
24 l Topical Report hA, Revision 3, which has been approved oy 25l l
NRC.
ALDERSON REPORTING COMPANY. INC.
55 1
Q In y o u r-- I ' m s o rry.- -
2 A
I would presume that variation, in s train levels 3
would be accounted _for in those formulas.
4 Q
My original question was, how will Bechtel 5
address variations c:
h sneer modulus with strain and you j
6 referred ~to the Topical Re9ert.
R 7
Do you know how the Topical Report addresses 3) 8 this ~ subj ec t?
d O
9
.A No, I don'O.
g 10 Q
Did you expec t that the surcharge loading would
}
j II I require'a revision of your seismic anaylsis after the a
f II,
removal of the surcharse?.
s j
13 l MR. FARNELL:
Would you repeat that please?
14 (Question read) k 9
15 THE WITNESS:
Yes.
m E
I0 I BY MR. PATON:
(Resuming) w h
I7 Q
And I believe you answered that as far as you h
18 know Bechtel has that E
under consideration right now?
17 g
A That's right.
20 Q
And -- does Bechtel plan, to your knowledge, to obtain new soil parameters for that seismic anaylsis?
22 A
To my knowledge, they are using new soil para-23 meters.for correctional anaylsis.
24 l Q
To your knowledge, they have already obtained 25 that information, is that correc t?
I i
ALDERSON REPORTING COMPANY, INC.
i 56 1
A That's correct.
l 2
Q Did they obtain it after the surcharge was removed 3 l
3 A
That's right.
j 4
Q Do you know how Bechtel obtained -- that 5
those new soil parameters?
3 0
A.
My understanding is that they performed cross R
b 7
hole t'e s ts t' obtain sheer wave velocities.
Al 8 l.
Q You said they obtained new soil parameters and d
f.
9 you mentioned. sheer wave velocities.
Did they obtain any 10 other new soil. parameters?
=
I f
II I A
I'm not aware of anything else besides what they h
12 have obtained in this case.
s' j
Q Okay.
Off the record.
~
(Discussion off the record) k BY MR. PATON:
(Resuming)
T 16
)
Q Mr. Thiru, I want to ask you come ques tions that d
17 l'relate to pipes and conduits under the ground.
g 18 Are you aware that there are discontinuities E
19 l
in the foundation of' the diesel senerator building con-20 sisting of pipes and conduits?
21 A
I'm aware there e.re pipes and conduits under 22 the building.
23 l
Q And you're not certain that you would call them 24 '
d is c o n tir.ai tie s, is that correct?
25 '
A That's right.
ALDERSON REPORTING COMPANY, INC.
57 1
Q Do you know'how many pipes tnere are under the i
2 diesel generator building?
3 A
I don't recall the number but it is submitted 4 :along with the responses to the questions to the Commission.
=
5 Q
Do you know how deep in the soil they are?
Any b
0 'of them?
7 N
My recollection is that the circulating water A
j 8I pipe is.'quite deep.
I don't know the elevation.
The d
I f.
9 I condensate line is less deep.
10 g..
The.first one you named was the service water pipei fII MR. FARNELL:
Why don't we set it read back?
g 12 (Question not read.)
S 13 j
.BY MR. PATON:
(Resumins)
E 14 g
Q I don't -- Do you remember?
w
$I A
No, what I said was circulating water pipe,
'0 circulating'is what I said.
d 17 !
w Q
Circulating water pipe, a
N 18 A
Now I remember that there could be a service E
19 l
water pipe also under the building.
20l Q
Are any of the three pipes you named, to your 21 knowledge, category one pipes?
22 A
The service water piping would be category one.
23 !
Q Have you been involved in the analysis of tne i
24l l stress on those pipes?
A No.
I ALDERSON REPORTING COMPANY, INC.
1 58 I
Q Who is responsibile for analyzing any stress lthatmaybeon.thepipesunderthedieselgenerator 2
building?
4 A
Bechtel.
l Q
Is that within Mr. Dhar's section?
6 ll A
!hs, the stresses and piping would be analyzed
_a i
R 7
within the 'Bechtel organization by a group called Piping n
l 8
i Stress Gr up-d 9l a
Q Okay, are those mechanical engineers?
g e4 10 '
E*
A I believe they are.
I 11 i
Q Do you know the name of the person who heads up d
12 that section.
13 5
A Yes, I do.
The name is Don Riat.
l 14 e
Q Do you know whether there are any deviations in k
15 W
the depth of the pipes from the original design?
j 16,
e i
A I have seen the response to some of the questions G
17 g
by the Commission which had figures relating to the survey 5
18 g
profiles taken and these show deviations from the original 19 k
designs.
l 20l l
Q Do you recall any deviations as much as twenty-21
(
one inches?
l 22 A
I recall a large amount like that.
I do not i
23,
l recall the exact amount.
24 Q
Did you' ever hear anyone at Consumers Power 25l l'
state that any of the pipes under the diesel generator ALDERSON REPORTING COMPANY. INC.
4
59 1
building are already over stressed?
2 MR. FARNELL:
Currently?
l 3
BY MR. PATON:
(Resuming) 4 Q
Did you ever?
5 A
I do not recall anyone within Consumers Power j
6 Company making a statement like that.
R b
7 Q
Did you recall anyone within Bechtel. making a Rl 8
statement. like that?
d 6
9 A
I recall that within Bechtel there was a concern 10 j
that the. pipes c'ould have stresses more than a certain E
l amount.,
I do not. recall the amount but the discussion h
which code should be applicable under this condition.
was 13 i
Q
'Do you agree that some of the pipes under'the j
I 14 l g
j diesel generator building are presently undergoing some j
15 '
stress?
~
16 A
Since I am not a piping stress engineer I can g
17 i g
not give you a definite answer to the question.
!ii 18 Q
Do you know whether Bechtel has any plans to g
19 l
monitor settlement of the diesel generator building?
20 A
There is a monitoring program to measure settle-21 ment of all the buildings.
22 Q
Do you know any -- has that been submitted to 23 the NRC7 l
A I believe in the presubm:.ttals to last time, it 25 :
I had been, yes.
ALDERSON REPORTING COMPANY. INC.
Go 1
1 1
Q Could you tell me generally,'without a lot of 2
detail, how you monitor the settlement of a pipe, of the 3
elevation of a pipe in the ground?
4 MR. FARNELL:
Is this a general ques tion?
g 5
MR.,PATON:
Now I'm changing the diesel generator 8
i i
j 6 l building to the pipes under the diesel generator building.
7 Let me ask a preliminary question.
M j
8 BY MR. PATON:
(Resuming) d d
9 Q
Do you plan to monitor the settlement of the h
10 pipes in the ground under the diesel generator building?
5 4
II A
I'm not aware of a program.
l 12 Q
I have no further questions.
e 5
13 MR. FARNELL:
We have no questions.
l 14 (Whereupon, at 4:25 p.m.,
the taking of the
$j i
instant deposition ceased.)
15 l
g 16 !
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6 17 a
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U"'88
.=
18 E
SUBSCRIBED AND SWORN to before me this day of 19 R
980.
20 21
. 22 Notary Public 23 '
My Commission expires:
24 25l l
ALDERSON REPORTING COMPANY. INC.
61 I
CERTIFICATE OF REPORTER 2
UNITED STATES OF AMERICA
)
)
ss.:
3 STATE OF ILLINOIS
)
4 I,
PATSY ANN STROH, the officer before whom 5
the foregoing deposition was taken, do hereby certify 3
6 that the witness whose testimony appears in the foregoing R
b 7
deposition was duly sworn by me; that the testimony of A]
8 i said witness was taken by me by stenotype and thereafter d
d 9
reduced to typewriting under my direction; that I am
$l 10 neither counsel for, related to, nor employed by any of 5
II the parties to the action in which this deposition was m
f12 taken, and further that I am not a relative or employee 3
5 13 of any attorney or counsel employed by the parties a
A 5
I4 thereto, nor financially or otherwise interested in the E
I j
15 !
outcome of the action.
=
- ?
16 tj 17 j C',i,
...uf..
.L.,'
s 5
I8 Notary'Public in and for the State ;of Illinois E
19 My Commission expires July 27, 1983.
20 21
'_/
22 i
23 l l
24 i 1
25 i
I i
ALDERSON REPORTING COMPANY, INC.
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