ML20090K910
| ML20090K910 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/10/1980 |
| From: | Ferris W BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-02, CON-BOX-2, FOIA-84-96 OM, NUDOCS 8405240473 | |
| Download: ML20090K910 (173) | |
Text
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P'U. REG *JLATORY CCMMISSICN h,
8 9.
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f In the Mattar of:
CONSUMERS POWER COMPANY
) DOCKET NOS 50-329 OM
)
50-330 OM (Midland Plant Units 1 & 2
)
50-329 OL 50-330-OL DEPOSITION OF WALTER R. FERRIS
(
DATE: December 10, 1980 PAGZS: 1 thru 172 AT:
Chicago, Illinois ME%T #- (N.T4ir L
400 V1..gisia Ave., S.W. Washi.g.ca, D. C.
20024
('
.alaphone: (202) 554-2345 i
8405240473 040517 PDR Fath RICE 04-96 PDR
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I U"ITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO!!
2 BEFORE THE ATOMIC SAFETY LICENSING E0ARD 3
I In the Matter of:
)
4
) Docket Nos 50 329 OM CONSUMERS POWER COMPANY
)
50 330 OM g
5
)
50 329 OL H
1(Midland Plant Unit s 1 & 2 )
)
50 330 OL I
g 6
7 offices of Isham, Lincoln and Beale 3
One First National Plaza g
8 Chicago, Illinois d
9 December 10, 1980 I
h 10 Deposition of:
3 l
11 WALTER R. FERRIS 3
I 12 the deponent called for examination by the staff of the g
(
g 13 Nuclear Regulatory Commission pursuant to notice, at 9:30 8
14
~
a.m.
15 PRESENT ON BEHALF OF THE RESPECTIVE PARTIES:
g' 16 For the Nuclear Regulatory Commission w
g 17 "g
Mr. William Paton a
18 Counsel for NRC E
19 Mr. Joseph Kane 20 Hari Singh 21 Jim Morrison 22,
For the Consumers Power comoany o I
23l Mr. Alan S. Farnell Ml!
and Mr. Ronald G. Zamarin Isham, Lincoln & Beale, Counselors at Law 25,
One First National Plaza Chicago, Illinois 60603 l
ALDERSON REPORTING COMPANY, INC.
2 (Witness sworn.)
1 WALTER R. FERRIS called as a witness herein, having been first duly sworn was examined and testified as follows:
4 EXAMINATION 5
l 6
MR. PATON This is the deposition of Walter Ferris of d
the Sechtel, San Fransisco office being conducted pursuant to
=
9 notice sent by the staff November 25th, 1980.
Mr. Ferris, please state your full name and j
11 your employer for the record.
i 12
(
A-My name is Walter Ronald Ferris, and I work with i
l 14 Bechtel, Incorporated in the Hydro & Community Facilities
' Division.
~
w Q
All right, the name of the corporation you work g
16 1 d
for is Bechtel; it's Incorporated; is that correct?
6 17 f
A Bechtel, Incorporated.
h Q
And is the organization that is located in Ann R
Arbor, Michigan also Bechtel, Incorporated?
20 A
g In Ann Arbor, there are Bechtel, Incorporated personnel in the geotechnical group.
Q Now, you say the geotechnical groue, are you i
lacquainting that to the hydro and community facilities I
- division?
ALDERSON REPORTING COMPANY, INC.
3 I
A Yes, they aro members of the hydro and community 2
facilities division.
3 Q
Do you acquaint these -- is the geotechnical 4
the same as the hydro and community faci? ities?
5 A
No, it is not.
0 Q
What is the difference?
7 A
The geotechnical group is a sub-group within a
0 the. hydro and community facilities division.
d Q
What is your position within the hydro and community 10 division in San Fransisco?
=
II A
I'm the chief soil engineer, m
Q Are you Dr. Afiti's boss?
s g
13 A
Technically I am his superior or supervisor.
l 14 Q
I'm looking at a document that you gave me that 15 g
apparently is your resume,and I'm going to mark it Staff a
E IO Exhibit 1, December 10, 1980.
And I'll mark it Ferris w
N I7 Deposition.
18
( At which time the document was marked. )
E II g
And I notice you have a degree from Harvard; E
is that June of 19557 II A
That 's correct.
22 i.
Q Soil mechanics?
23!
A That's correct.
M Q
Is that a Bachelor Degree?
25 '
A No, that is a Master's Degree.
At that time Harvard I
ALDERSON REPORTING COMPANY. INC.
)
4 1
called it a "SM" but it is in fact a Masterb Degree.
2 Q
Okay.
On your resume, it says December, 1941 3
to January,. 1942, Royal Engineers, UK,(United Kingdom) 4 4
am I correct, that that is two months?
=
5 A
E No, you are not correct, I was in the Royal Engineers
]
6; from December,1941 until January of 1948 -- a little over 7l E
3 six years.
.M j
8 Q
Okay, I'm sorry, but do you see your resume,
d d
9 it says from and to, does that not say January '42?
10,
A It appears to be a typographical error.
11 Q
So, you would make that a '48; is that correct?
3 l
12 l A
That's correct.-
b g
13 Q
Would you tell me in your jud ment what Dr. Afifi's 6
l 14 responsibilities.are ?
15 A
Dr. Afifi is the assistant chief soil engineer j
16 in the geotechnical group in the Ann Arbor office, w
N I7 Q
Assistant chief engineer in the what ?
U g
18 A
In the Ann Arbor Office of Bechtel.
E 19 g
Q But you indicated the group, geotechnical group.
20 A
He is with the Seotechnical group.
21 Q
Did you read his deposition?
l.
22 A
Ye s, I have.
23!
Q Can you tell me what his responsibilities were 24 l with respect to the soils problem at the Midland site?
25i MR. FARNELL:
Currently, right?
ALDERSON REPORTING COMPANY. INC.
5 I
BY MR. PATON:
i 2
Q What they have been and what they are now.
3 Tell me what they are now.
4 A
He is now providing to the Midland Project Engineering 3
5 Group information in relation to the questions from the 2l 6
NRC, which relate to the technicians for the problems that 7
occurred.
A j
8 Q
What kind of information is he providing?
dn 9
A Just the soil information.
10 Q
Tell me what ycu mean by that.
=
II A
Oh, soil perimeters that would be used by them Y
II for design.
b 13 j
Q
.I didn't hear the first word.
14 A
Soil perimeters.
15 5
Q Okay; is that all?
m E
I' A
Yes, at the moment, yes, w
h I7 Q
You say he is providing soil perimeters to project 18 engineering; is that the extent of his responsibility at E
I9 g
the present time ?
20 A
No, you asked me on the Midland job.
He is providing 21 it on the Midland Project.
/
22 Q
Yes, I do mean to limit it to the Midland Project.
23 !
A That is what his job is.
M Q
Does he have any responsibility to see that the 25 information he provides to project engineering is properly ALDERSON REPORTING COMPANY. INC.
L
6 I
authoris:ed.
2 MR. FARNELL:
Would the court reporter ret.d back that 3
question.
4
( At which time the aforementioned 5
question was read back.)
0 MR. FARNELL:
I think we need some clarification of 7
" properly authorized."
I just don't understand.
I think Xl 8
it is vague, d
d 9
BY MR. PATON:
10 Q
Let me ask the witness.
Do you understand what N
3 II I mean by that question?
g 12
,A I'm not quite clear what you mean by it.
s
- 5. 13 Q
Okay.
He provides soil perimeters to project a
l 14 !
engineering, right?
E g
15 A
Right.
=
16 Q
What do they do with it?
l 17 A
They use it for specific design purposes.
k 18 Q
Does Dr. Afifi have any responsibility to see h
I9 g
that the information he has provided to project engineering 20 is appropriately used for specific design purposes?
21 A
Only in the event that the project would ask him 22 to review something that they had done in his area of expertise.
23 ;
Q So, his responsibility is limited to providing M
information and it ends there -- providing information l
25 '
requested by the project to the best of his ability in his I
I
,l ALDERSON REPORTING COMPANY. INC.
r
)
7 I
area of expertise.
Does he ever volunteer information prior to its being asked?
Q I really don't know how to answer that.
Q Well, you said he responds to questions.
l A
That 's correct.
l 61' Q
Does he ever give them information that they 5
7 haven't asked him for?
3 A
I don't know how he would know about it without da 9
being asked.
i g
Q So, your answer is no?
Ig 11 MR. FARNELL:
I think that!s not what he said.
g 12 BY MR. PATON:
3 13 i
R Q
Do you know whether he ever volunteers information?
A I do not know.
g Q
In reading his depcsition, do you recall the 16
.l exchange between myself and Dr. Afiti concerning the proper compaction standards?
18 A
I recall there was some discussion on that.
19 l
Q And do you believe that there was any confusion 20 within Bechtel over a period of several years with respect 21 to the proper compaction standard to be used at the site?
22 MR. PARNELL:
Is this being tied to the transcript 23.
I or is this kind of --
M MR. PATON:
He can base his answer on anything he 25 !
I wants.
His reading of the transcript or his general knowledge.
ALDERSON REPORTING COMPANY, INC.
8 MR. FARNELL:
Would the court reporter read back the 2
question.
3 (At which time the aforementioned 4
question was read back.)
=
5 l
MR. FARNELL:
What year?
Are we talking about any 3
0 year?
E 7
{
BY MR. PATON:
l 8
Q I asked him for several years.
g d
9 i
MR. FARNELL:
I want to make sure we are talking about the same thing.
That's why --
g 11 WITNESS:
Based on my reading of the transcript, there d
12 2
was confusion.
I had been aware that there was some confusion 5l prior to that time.
l 14 '
Q Do you understand.Dr. Afif1's responsibilities w
k 15 g
to include clarifying that confusion?
16 l
A Yes, I do believe that if he is aware of the g
17 a
confusion.
18 Q
But only if he is aware of the confusion; is 19 j
that correct?
20 A
How could he know otherwise?
21 Q
In other words, you don't see any responsibility on his part to verify that the information he provided I
i was being properly used?
24 A
If he was not provided with information that I
25 '
permitted him to know that, I don't see how he could possibly 1
ALDERSON REPORTING COMPANY. INC.
i 9
I have responded to it.
2 Q
Okay, you agree he did give them advice on the proper 3
compacticn standard to be used at one point?
4 A
Yes, I have seen a memo.
5 Q
And after he gave that advice, there was still j
6 confusion on the proper compaction standard?
t 7
A I'm not familiar,with that area.
AI 8
Q Okay, you read his deposition, but you don't d
8 9
recall having read the deposition as to whether the confusion 10 came after he gave them advice; is that correct?
h II A
I believe the confusion existed beyond that, m
(
12 I don't know anything about the detailings of it.
B g
13 Q
And you don't see Dr. Afif1's responsibilities
]
14 as including the duty to go out and try to find out whether 15 the advice that he gave us was being followed?
m a[
16 A
No, I do n ' t believe so unless he is specifically w
l I7 l asked by the project to.
II Q
Okay, now you answered a question a short time 19 g
ago as to what Dr. Afifi's present responsibilities are with respect to Midland.
21 A
Yes.
22 Q
What have his responsibilities been for the past i
23 three or four years?
Do they differ in any way from what Ml you just said his present responsibilities are?
25l A
No, as far as I recollect, Dr. Afiri being in ALDERSON REPORTING COMPANY. INC.
\\
10 I
Ann Arbor he~has be'en essentially working as my assistant 2
l chief in thef geotechnical ~ Croup. of hydro and community 3
facilities' divialon'which is located in the Ann Arbor office.
4 Q
Your Answer is that his duties for the past three 5
or four yess' have b.*en +:he sar.e as you have just indicated 3
0 they are present].y?
l 7
A Right.
Nl 8
Q How often over the last three c:' four years, l
d 9
approximately', how 0.fte 1 do ;'ou esik to Dr. Afiti?
10 l A
I talk to,him quite frequently.
Probably two 5
II timea a week, by cal 4 phone.
g 12 Q.
Mr. Ferris, I want to show you a document that 5
l j
is dated June 30, 1980, that has already been designated I3 l
14 in these proctedings as deposition exhibit number 4 in 15 the deposition of ftr Lyman Heller.
And I'll hand it to m
ai I6 you and you can look at any part of it you want.
But I'm w
h I7 directing your attention'to Enclosure 1, the last paragraph I8 of number 36 which is fur lines long.
You can look at h
'I I
g any part of that document that you want.
My question will E
be ' addressed to *; hat parttgraph.
21
. Q Could you scint, cat again the particular paragraph E
that you want me to addresu?.
23 :
q Yv. s.
And _in fact'., I'll tell you-5he -Nestion, 1
M it may help yout u'th yout' review of the-document., Eut 25 '
the paragraph I'm refscring to is the' four-line paragraph
,x 2 -....
i s
- ALDERSON REPORTING COMPANY. INC.
s.,
11 I
that appears at the end of number 36 on the page that is 2
parked " Enclosure 1."
3 Q
Mr. Ferris, I want to tell you the question then 4
you can read the document a little better.
g5 shis sentence I'm directing your attention 0
to is really the second sentence of the four-line paragraoh R
I d
7 of the end of 36.
And it reads, " Also provide the locations, 8
boring logs and availability testin6 data of any exploration d
d 9
completed in 1979 and 1980 which has not yet been submitted."
10 g
And the question I'm going to ask you is l
II did you at some time after that letter submit the information n
(
12 refe'renced in that second sentence that I just read?
b g
13 A
I personally did not.
g14 Q
Do you know if it was submitted?
15 '
A I do not know if that has been completely compiled 16 g
with as yet.
i
.h 17 MF. FARNELL:
Also he doesn't know if there is any a
5 II su c h.. info rmation..
E 19 g
BY MR. PATON:
E Q
I'll ask the witness.
Do you know if there is 21 any such information?
22 A
I'm aware at this time that there were' boring 23 logs that the NRC had not seen, but I do not know if those have been as yet sent to Anderson.
25 Q
Who within Bechtal should know that?
I l
i l
ALDERSON REPORTING COMPANY. INC.
12 1
A The project engineer.
2 Q
And who is that?
3 A
Currently,~1t is Cursis.
4 Q
In July, 1980, who was the project en5 neer?
1 g
5 A
I don't recall.
8 j
6 Q
All right,-now would Dr. Afifi know whether that R
d 7
information had been provided, is that within his responsibility',
3l 8
A He would know what he hadzprovided to the project d
c; 9
so indirectly he might know what was available to go to 2
h 10 the NRC.
11 Q
Do you know anything about-the information contained
.3 g
12 in boring logs and available test data of any exploration 5
i g
13 completed in 1979 and '80 that had not been submitted to a
14 the NRC in June of 1980?
D'o you know what that' information t:
)
15 was?
5 j
16 A
I don't recall precisely, no.
s e
l 17 Q
Who within Bechtel weuld know that informat ion?
z k
18 A
The project engineer would know it.
E 19 Q
If the NEC asked fcr that information, whose E-responsibility is it to determine whether it will be provided 21 to the NRC?
(
22 A
I believe the' applic' ant is responsible for that.
I Q
When [/ou. say " project engineer" 'do ' you me an Bechtel 23 24 l or Consumers?
25l A
The Midland Bechteliproject engineer would know' 1
ALDERSON REPORTING COMPANY, INC.
13 I
what Sechtel had available.
2 Q
I'm trying to think of how to word this question 3
and I'll do the best I can.
The question is this way:
4 it seems unusual to me -- and please respond or comment g
5 on my statement -
I'm not trying to argue with you, but S]
6 it seems to me that the chief soil engineer for Eechtel R
8, 7
does aot know whether when the NRC makes a request for
?
l 8
boring logs and availability test data of any exploration dd 9
completed in 1980 that that information was not ever provided.
10 MR. FARNELL:
That 's not even a question.-
E 11 BY MR. PATON:
is Py 12 Q
.Does that seem unusual to you?
5 g
13,
MR. FARNELL:
That is unreasonable.
=
l 14 BY MR. PATON:
15 Q
Is that within the scope of your responsibilities --
f 16 A
I..have no direct. contact.with the NRC.
e f
I7 Q
Do you have any responsibility with respect to a
18 a question from the NRC -- strike that.
E 19 With respect to the particular sentence 20 tha.t I asked you to direct your attention to, did you have 21 any responsibility?
22 s
A Only in reviewing the data that would be sent.
23 ;
Q Did you review the data that would be sent?
24 A
I do not recall all of the data that I have reviewed 25l specifically.
i l
ALDERSON REPORTING COMPANY, INC.
14 1
Q Do you recall whether you specifically reviewed 2
this data?.
3 A
I recall _having reviewed some borings that were 4
not available to NRC on June 30th.
5 Q
b Did the data that you reviewed indicate poor
]
6.
foundation conditions in the areas of the electrical penetracion R
7 rooms?
]
8 A
Which data are you referring to?
d d
9 Q
The data you juqt indicated that you reviewed.
z h
10 Q
I do not recall that.
- =
j 11
-Q.
Have you reviewed Volume 8 of the responses to
(
12 the NRC 50.54(f) questions?
5g 13 A
I have reviewed the responses.that Afifi has i
a l
14 prepared for the project and therefore, those portions 5
2 15 that are contained in Volume 8, I would have reviewed, g
16 just tne soil portions.
i 17 Q
Do you know if the information requested in this 18 sentence that 'I have referred you to in Heller Deposition E
$ ' 19 Number 4 is contained in Volume 8 of the 50 54(f) responses?
20 A
I do not.
21 Q
Do you have in your office Volumes 1 through 22 8 of the 50 54 (f)?
23,
A Yes, I do.
I 24 Q
Now, with resoect to the information that 's indicated 25 '
in the sentence in the Heller Decosition to which I have ALDERSON REPORTING COMPANY. INC.
15 I
referred you, do you have any recollection as to whether there 2
was any ' indication or information indicatinc coor condition 3
foundations anywhere on the site.
4 A
I do not know soecifically what is in the bo. rings 5
referred to there, so I cannot answer your question.
]
6 Q
All right.
R 8
7 A
I do n.' t recall what is in them.
- f8 Q
Let me ask you this, do you remember whether d
y 9
or not you ever reviewed this information at any time ?
10 A
I think I just answered that.
E II
' MR. FARNELL:
It has been asked and answered.
3 I
II BY MR. PATON:
5 f
13 Q
I know you said you don't remember., but did you l
14 ever look at it?
_b II A
I think I told you I recall seeing some of that d
I0 l information, but what I don't know is whether I see all w
h I7 that 's referred to in that general sentence.
=
{
18 Q
You said you saw some of --
C l-I' g
A I believe I have.
20 Q
So, you are fairly clear that you saw some of 21 it, but not all of ita 22 A
Right.
4 23 ;
Q As to the "some of it" do you recall anything l
l M!
about it ?
I d
25 A
I do not recall stuff relating to electrical i
ALDERSON REPORTING COMPANY, INC.
16 1
penetration area, it may have been there, but I don't recall.
2 Q
Do you remember anything about -- did it indicate 3
anything about foundation conditions at the feed-water 4
isolation valve pits?
g 5
MR. FARNELL:
That has been asked and answered.
R 6
BY MR. PATON:
3 7
Q No, I. asked about the electrical penetration.
3
. 8
]
A Well, I don't recall that either.
dd 9
Q Mr. Ferris, with respect to the information that
,29 5
10 is referred in this sentence in the Eeller Deposition that 11 you indicated you had at one point seen some of, do you m
I 12 know any reason why that information was not submitted I
e g
13 to the NRC prior to the NRC 'asking for it ?
~
l 14 A
No, I.do not.
15 Q
Okay.
Are you aware of any information -- and j
16 my question relates to the Midland care and the soil problem --
w 17 are.you aware of any information Bechtel has provided to z
18 Consumers for the purpose of forwarding to the NRC that E
19 has not been sent by Consumers to the NRC?
20 A
No, I do not.
2I Q
Do you have any reason to believe that there 22 is any bias or lack of objectivity in the staff's review 23 of the safety issues in the Midland project -- I'm limiting 24 this to the soils issue.
25l MR. FARNELL:
Would the court reporter read back I
ALDERSON REPORTING COMPANY, INC.
~
17 I
last question.
2
( At which time the aforementioned 3
question was read back. )
/
4 MR. FARNELL:
I think that 's -- are you talking about
=
5 h
any one individual or are you talking about everybody that 's j
6 reviewed it?
Are you talking about attorneys?
It is too R
R 7
broad of a question.
2]
8 MR. PATON:
I'm asking if he has any reason to believe --
dd 9
I think th? question is clear.
10 l MR. FARNELL:
I object to the form.
E l
II '
.MR. PATON:
Either he does or he doesn't.
Maybe he a
I I2 does, maybe he doesn't know.
E 13 '
MR. FARNELL:
You are talking on balance, are you 2
l 14 '
talking one individual?
I mean the staff is composed of g
15 l a lot of different people that's what my objection is.
x 7
16 3
BY MR. PATON:
e 6
17 Q
E Do you believe that within the staff there is 18 any individual that is involved in the review of the Midland k
19 Facility and that person is biased or has a lack of 20 objectivity?
2I A
I have no reason to believe that.
22 MR. FARNELL:
Would the court reporte read back the 23l last question.
24 (At which time the aforementioned 25 question was read back.)
ALDERSON REPORTING COMPANY, INC.
18 I
BY MR. PATON:
2 Q
In view of your knowledge of the settlement projects 3
at Midland, do you think the staff should require a closer 4
than normal sociny of the geotechnical engineering aspects
=
5 of the Midland design?
h j
6j A
I don't know why.
M d
7 Q
Is there a soils problem at the service water M]
8 structure?
d q
9 A
Yes, there is.
E 10 Q
What is the problem?
5.
II A
There is some bore filling beneath the inboard 3
I 12 end of the service water structure and there is a plan 5
5 13 to underpin that end of the building.
m 14 Q
I. don't remember a word you used -- you said 15
. bore fill under the something.
j 16 A
Under the inboard end of the service water structure.
2
(
I7 Q
Tell me what you mean by " bore filling."
x 5
18 A
The expirations indicate low blow counts in the R
g" 19 standard penetration test.
20 Q
Is that the extent of the investigation that 21 was conducted?
You made standard penetration tests and 22 determined that there were low blow counts; is there anything 23 else?
Strike '.iat question.
24 Did you conduct any other investigation 25 besides standard penetrations?
ALDERSON REPORTING COMPANY. INC.
19 1
MR. FARNELL:
Of the fill beneath the service water 2
structure?
3 MR. PATON:
Ye s.
4 WITNESS:
My recollection is standard penetration I
e 5
l tests.
g I
6 9
'\\.
BY MR. PATON:
{
7 Q
And you indicate the problem is low 'clow counts,,
3 g
8 j do you recall any of the specifics?
d I
C 9!
A I don't recall the numbers.
Yg 10 Q
And describe the proposed remedy.
_~g 11 j A
'It's planned to underpin the end of the building 3
l Y
12 with piles.
Sg 13 Q
Now, you said underpin.
The piles wou'ld be attached 2
[
14 to the side of the building; is that correct?
g 15 A
That is correct.
=
16 g
Q Okay.
Tell me what needs to 'oe known before e
g 17 that underpinning is designed?
5 5
13 MR. FARNELL:
I'm not h
sure that we have got any foundation 19 that this is something that he has knowledge.
20 It also needs to be known by who.
It is just too open-21 ended of a question.
22 BY MR. PATYON:
23 ;
Q You indicated that generally speaking che remedy 1
24 l 1s to underpin the end of the building.
i 25,I A
That's correct.
ALDERSON REPORTING COMP NY,INC.
20 1
Q Do you know what kind of information -- strike 2
that.
3 Describe the discipline of the person who 4
would make that design -- design the remedy.
e 5
A There is not one percon.
h j
6 Q
All right, tell me what disciplines would be 8,
7 involved.
Ml 8
A Well, the pile part of it, the recommendation d
9 for that will be made by soil engineer and then the overall 10 analysis of the building would have to be carried out by i!!
h Il a
structural engineer.
3 l
12 Q
Okay, is there a discipline called " foundation S
5 13 engineering" ?
m i
l 14 A
Yes.
A soil engineer carries out foundation 5
15 engineering..
a g:
16 Q
And you arc c. soil engineer?
as(
17 A
I'm a soil engineer, yes.
- s 18 Q
Now, can you tell me what information you would E
19 need about that fill to provide your input into the design g
20 of the underpinning?
21 A
You would need to know the soil conditions at 22 the structure.
23 Q
Okay, tell me what you mean by that.
I
^
Mj
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A You would need to know what type of soil is there.
25 What its consistency is.
i l
i ALDERSON REPORTING COMPANY, INC.
21 1
Q Anything else?
2 A
You, would need to have some assurance that there 3
is a stratum to which you can carry the building load safely.
4 Q
That would freque'ntly be the till?
e 5
A In this particular instance, it is the till.
0 g
Q Anything else ?
7 A
No, I think those are basically it.
]
8 e
Q Okay, by type, do you mean sand or clay?
d 9
f A
Yes, the soil stratification.
g 10
)
Q What kind of a determining would you make other j
11 than the fact that it is either ' sand or clay?
y 12 5
MR. FARNELL:
Are you talking about type of information?
MR. PATON:
You said type of soil --
E 14
~
u D
WITNESS:
I meant soil clarification.
1 2
15 I 5
SY MR. PATON:
g 16 d
Q All right, can I change that.
g 17 A.,
You.can.chan5e.that to soil clarification.
5 18 g
Q Now, within soil clarification what are.the possible 19 clarificatior s ?
20 A
Gravel, sand silt and clay.
21 Q
You would determine that in your soil clarification.
22 You would determine that the soil was made up of gravel, 23 l
sand or silt or clay or what it was.
Now, would you determine 24 '
how much of each of those if there was more than one of 25 ;
those involved, would you determine how much' of each one of f
I ALDERSON REPORTING COMPANY, INC.
~
22 I
those was there?
2 A
My intention would be to get the soil stratification, 3
which is what I mentioned initially to you.
4 Q
Is soil stratification part of the soil clarification?
5 g
A I would clarify each stratum.
n 3
.6 Q
Clarify each, okay.
And would you do 'that down I
R R
7
.to the point where you got to the till or whatever you
]
8 felt was the foundation?
d I
2 9
A It would go into good foundation, the soil.
,z9g 10 Q
What do you mean by consistency?
E II '
A Soft or stiff.
l 3
Y I2 Q
How is that measured, what perimeter?
5 5
13 l A
In its very crudest method by standard penetration l
8 i
l 14 l test'.
m 15,
Q Now, stratum, I'm not sure I understand stratum.
16 gi That part of this clarifyin6 -- each stratum -- is that w
1 17 what you meanc wnen you used that term?
18 A
It is the soil layering, each layer is a stratum, h
19 g
so the subject surface consists of strata of different 20 materials.
2I Q
How would you go about determining those things, 22 where would you get your information?
23 :
A From borings.
24l Q
What kind of borings?
i 25 l A
Normally, soil borings.
I ALDERSON REPORTING COMPANY, INC.
23 Nell, what I mean is standard penetration tests would 1
Q 2
'ne one.
3 A
That's one method of doing it.
4 Q
Now, that would give you disturbed samples, right?
g 5 i A
Yes.
They would be disturbed.
Nj 6
Q And then you would aiso take undisturbed samples?
R R
7 A
You could if you so desired.
A j
8 Q
Do you have any idea whe:her that would be done e
d 9
under the service water structure ?
$g 10 A
I do not recall if it was done.
E
~
j 11 Q
Do you have any opinion as to whether or not 3
y 12 it'should have been done ?
5g 13 MR. FARNELL:
For what purposes?
a l
l 14 l MR.'PATON:
For the purpose we are talking about.
2 15 WITNESS:
5 Well, I believe it need not have been done.
i j
16 l BY MR. PATON:
\\
y 17 !
Q I want to make sure, Mr. Ferris, when you say 18 it need not have been done, were you referring to dndisturbed
=
19 samples?
20 A
Yes, right.
21 Q
Why do you say that ?
That maybe it need not 22 be done.
23 j A
It depends on what your underpinning procedure 24 is.
25 Q
Doesn't the information that you are going to get ALDERSON REPORTING COMPANY, INC.
r -... -
24 I
about the soil condition determine what your underpinning 2
procedure is going to be?
3 A-Yes, you would make a decision at that point.
4 Q
Okay, but then you just said your underpinning i
e 5 l procedure would determine whether or not you are going
]
6 to take undisturbed samples.
It seems like a vicious circle C
7 to me.
N 8
A You can get information on the underpinning procedure d
d 9 I by other procedures.
2, 9
5 10 Q
For xample ?
- =
II A
A load test on the pile.
3 I
I2 Q
And do you know whether the plan is to rely on
=
3 5
13 load tests for piles in this case?
l 14 I A
I do not recall that it is specifically to rely J:
g 15' i on that.
a j
16 Q
Do you know if it was ever planned to do that?
w f
I7 {
Was it ever. planned to do that ?
z 18 A
What do you mean when you say -- what is your
_ch 19 actual question?
20 Q
Was there ever a plan to rely on load tests for 2I piles in place of taking undisturbed samples?
22 MR. FARNELL:
I don't think those things are mutually --
23l he testified that those things are mutually exclusively.
I 24 Q
Well, if they are not that's fine, he can tell 25 me that.
I i
ALDERSON REPORTING COMPANY, INC.
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A I do noo recall.
2 l
MR. FARNELL:
That was inherent to your question.
3 I don't -think there is a foundation for it.
4 MR. PATON:
Okay.
5 BY MR. PATON:
f 6]
Q Now, I was asking how you get the information nhI to help you determine things such as soil clarification, 8
clarifying soils and the gravel, sand and clay and silt l
d
}"
and you were telling me that you would take borings.
Would 9
10 you take standard penetration tests which would give you
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12 I
what other 'means would you use to determine soil conditions ?
9 13 j
A In this pdrticular instance,'ou would make a y
E 14 l load test -on a pile, that would give you information.
w i
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Q Would you determine the area and depth of the z
E I0 problem of the bad soil conditions?
1 d
l h
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'A You would determine the depth of the pore soil
=
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conditions.
C*
19 g
Q Would you not also determine the area?
20 A
Not necessarily.
21 Q
Is that because you would assume that bad soil j
conditions extended under all areas of the structure was 23 I affected?
l 24 '
A You could make that assumption, I don't know.
25 Q
All r4.ght.
Now, I'm talking about what you would I
ALDERSON REPORTING COMPANY, INC.
26 l
1 need to know to design the underpinning and my que stion to 2
you is --
3 MR. FARNELL:
We are just talking about the surface 4
water building now?
5 MR. PATON:
I'm still talking about the surface water f
6 structure and my specific question is I'u addressing what R
7 you need to know to design your underpinning and my question Ml 8
is would you need to know the maximum static and dynamic d
i d
9 loads to be imposed?
h 10
. WITNESS :
The'so11 engeineer would not necessarily l
II need to know that.
m j
12 BY MR. PATON:
-3 5
13 l Q
-Would the structural engineer need to know the --
2 l
14 A
The structural engineer must know that.
y 15 Q
Would the structural engineer or the foundation a
i 16 engineer have to know the load 'cearing capacity of the md i
h I7 piles?
x!
II A
Could you repeat that question, please ?
c I9 Q
For whoever is designing the underpinning, is 20 it necessary to know the load-bearing capacity of the piles?
21 A
Yes, it is.
22 Q
Is it necessary to make a settlement prediction 23l for the piles?
24ll A
Ye s.
You would need to know.
25l Q
Now, with. respect to the informacion that you have ALDERSON REPORTING COMPANY, INC.
27 I
said you would need to know, how much of that information 2
did Bechtel know on December 6th,1979 -- and I'll volunteer 3
to you tha-t that is the date of the order modifying construction 4
permits that was issued by the NRC.
=
5 MR. FARNELL:
Just for convenience, why don't we do k
I 3.
6 l
them one at a time because there ar'e a lot of factors here.
R*S 7
WITNESS:
.I would like to have your question again, Xl 8
please, because it sounded long to me.
d y
9 BY MR. PATON:
E g"'10 Q
Okay, that's fair.
Let me first just state a 11 little background, I'm going to ask you with respect to R
I_
12 a lot of. information and I'll take the information one Sg 13 I at a time.
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14
.A For the surface water structure?
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15 i
,Q For the surface water structure for Midland for x
y 16 the soils problem.* How much of this information was in
. e f
I7 l the possession of Bechtel on December 6th, 1979, and the
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18 reason I'm asking you that question, is that 's the date E
I9 g
of the order modifying construction permits.
What I want 20 l
to try to find out from you is when that order was issued.
2I What did Bechtel know about the design of these remedies?
22 That is the purpose of my question.
s 23l A
And are you going to ask me specifically the 24l items that you want to know about ?
25 Q
I think your attorney wants me to do that, and I'll i
i i
ALDERSON REPORTING COMPANY, INC.
28 I
do that.
2 A
Okay, fine.
3 Q
Starting with maximum static and dymanic loads to 4
be imposed, I believe you indicated to me that you must i
g 5
know that in the design of the underpinning and my question E
]
6 to you is what was the status of the review -- strike that.
er R
7 What did Bechtel know about the maximum a
j 8
static and dymanic loads to be imposed for the underpinning d
d 9
at the surface water structure on December 6, 1979 Yg 10 A
I don't know.
That's a structural matter.
I
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3 d
12 Q
All right.
For the structural people to know E
S g
13 that, wouldn't they have, to have some information from
=
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I 2
15.
A Yes, they would.
U j
16 !
Q What kind of information would they have to have I
g 17 j from you?
I k
18 A
The inform 1 tion you. asked earlier. about.the soil E
19 conditions.
I 20 Q
All right, now on December 6, 1979, had you provided 21 the structural engineers with information that you described 22 under the heavy soil conditions?
23!
A To the be st of my recollection we had boring 24l data at that l
structure at that time.
25l Q
Okay, you had boring data.
But for example, had ALDERSON REPORTING COMPANY, INC.
29 I
you clarified the soils in the surface water structure into 2
gravel, sand, clay or silt?
i 3
A I believe so.
4 Q
Had you on December 6, 1979, determined the consistency 5
of the soil in that area?
j 6
A I believe we were aware that there were low blow g
7 counts there.
it j
8 i
Q Had you come to any conclusions with respect d
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9 to stratification?
10 A
I can't recall that precisely, but I believe
=
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f 12
.so at least to that. extent, we knew the stratification.
S 13 j
q.
When you talked'about stratification, didn't E
14 you mean th'.t you would determine the layering in the till?
w 15l-92 A
If there was any.
=
16 Q
Do you know whether there was any?
h II A
I do not recall that.
z 18 MR. FARNELL:
Let's go off the record.
19 g
(At which time a brief discussion was held off the record.)
21 BY MR. PATON:
22 Q
Mr. Ferris, I'm returning to the question that 23 :
we left off on, concerning what,you would have to know 24 to design the underpinning at the surface water structure 25l and am I correct that one of those you would have to know, I
ALDERSON REPORTING COhlPANY, INC.
30 1
the engineer that was designing it, would have to know would 2
be load-bearing capacity?
3 A
Right.
4 q
.To know load-bearing capacity, an I correct that 5
j you would have to know the sheer strength of the soil?
9 3
6 A
Not necessarily.
E i
7 Q
You would not ?
Kl 8i A
For the par.
d d
9 Q
And is that because you would do load tests later?
h 10 A
That's correct.
II Q
Is it good engineering practice to make load 3
g 12 tests for piles after they are installed as opposed to 5
5 13 determining their load bearing capacity prior to installing 2
l 14 them?
f j
15 A
I did not say that the load test would be done a-g 16 after they were installed.
w h
I7 l Q
When do you do the load test?
l 5
18 A
You have to install a pile to load test it.
c g" 19 Q
When do you load test it then?
20 A
After you have installed it, but it does not 2I have to be one of the piles that was in the structure.
22 Q
You say in some instances, you could determine 23 load-bearing capacity by knowing the sheer strength prior i
24 to the installation of the p1.le; is that correct?
25j MR. FARNELL:
I don't think that rs what he testified.
l l
t ALDERSON REPORTING COMPANY, INC.
~
31 I
WITNESS:
I didn't.
2 BY MR. PATON:
3 Q
You didn't say that?
4 A
I guess maybe you can read back what I answered to g
5 that question.
R 6
MR. FARNELL:
My notes say that he didn't necessarily 7
need to know it.
Nl 8
BY MR. PATON:
dd 9
z.
Q Do you understand the NRC's position with respect h
10 to the installation of piles at the surface water structure E
Il to be that it is appropriate to first analyze by methods Y
12 that will estimat'e bearing capacity prior to installing 5
5 13 the piles?
m I4 MR. FARNELL:
Would the court reporter read back the
$j 15 last question.
a E
I0 (At which time the aforementioned A
f 17 question was read back.)
a!
18 WITNESS:
I don't understand that comment completely, h
19 g
could you either show me or elaborate on that ?
20 BY MR. PATON:
II Q
Let me a.sk you a question, do you have any knowledge 22 of what the NRC's position is with respect to the files j
23 j and what kind of information you should have be' fore insta'lling 1
24 i the piles?
i A
Ye s, I b elie ve I do,
t-ALDERSON REPORTING COMPANY, INC.
32 I
Q Please state what that is.
2 A
I believe they had requested to evaluate the 3
capacity of the pile using sheer strength perimeters.
4 Q
And do ycu believe that is appropriate in this e
5 I
case?
h j
6 A
No, I do not.
3 R
7 Q
Why not?
3
]
8 A
I do not believe it is the best way to determine dd 9
3.
the capacity of the pile. It's not the most reliable.
10 Q
You are indicating that a load test for the pile II is more reliable, it l
I2 A
Y.es, I an.
13 Q
ITow, you said something awhile ago that I didn't a
'14 i
understand.
When do you make the load test for the pile, k
15
- when do you plan to make the load test for the pile in I0 gi this case?
- d h
I7.
A I do not recall pc ecisely when it was to be made.
\\
h= I8 Q
Do you know how many piles you are going to install E
19 g
in the underpinning of the surface water structure?
20 A
I believe it is 16.
21 Q
And how many of those are you going to load test?
22 A
I did not say we were going to load test those 23
- p11g3, 24l:
,j Q
That's the confusion.
You are going to conduct i
25 a load test, but you are not going to load test these piles?
l I
I ALDERSON REPORTING COMPANY, INC.
I 33 a
i I
A We will load those piles, but not in the same manner.
2 that the load test is carried out.
3 Q
You are going to conduct your load test in some 4
area other than the precise place in which the piles are 3
5 going to be installed; is that correct?
R 6
l A
It will be in the area of the surface water intake C
7 structure but will not be one of these piles.
)
8, Q
And your statement is that those load tests about dd 9
their being more reliable results than following the procedures h
10 suggested by the staff?
=
II A
Yes.
in I
II Q
Considering the fact that we are -- strike that.
E" 5
13 Is the surface water structure a categoric I structure?
8 i
e E
I4l:
A Yes, I believe it is.
Y[
15 lI Q
What does that mean?
=
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That means it is essential for the safe shut w
h I7 !
down of the plant.
18 Q
Considering that the surface water structure E
19 I is a categoric I structure, do you agre,e that it would 20 be prudent even assuming that the load tests give more II reliable resulta to learn sheer strength prior to the installatio:a II of piles to determine its load bearing capacity.
23 MR.FARhELL:
Would the court reporter read back the 24 l last question.
I 25!
i (At which time the question was read back.)
ALDERSON REPORTING COMPANY. INC.
I I
34 I
BY MR. PATON:
2 Q
Can you tell me why?
3 A
I have already answered that.
4 Q
Okay.
I understand that your testimony is that load
=
5 tests would give a more reliable result.
Is it your opinion h
6 that you wouldn't learn anything by attempting to learn 7
the sheer strength of the pile prior to the installation
- ]
8 of the piles?
dd 9
i.
A You would learn something, obviously because h
10 you have obtained some information.
=
II Q
But your judgment is that it is not worthwhile it f
I2 getting that informat ion?
s 5
13 A-That 's ' correct.
=
a E
I4 Q
Is it based on some kind of cost benefit, I mean 15 for example, if obtaining that information cost a dollar; E
16 I si l
would you go ahead and get that information?
l.
I 7 '
A No, it's based on good engineering practice, x
I8 current good engineering practice.
E 19 Q
You say, " current."
Has it changed?
E A
Yes, it has changed.
II Q
Was there a time when it would have be'en good 22 engineering practice to get sheer strength first ?
D-A There is a time whe.7 some engineers would have 24 believed that was the way to do it.
25 Q
Give me some idea about time.
Are we talking about ALDERSON REPORTING COMPANY, INC.
35 I
five years, ten years ago ?
2 A
Probably ten years ago or more.
3 Q
Could you tell me anything about why engineers within 4
the last ten years have undergone a change of anything
=
5 in this regard?
5 0
A Much more reliable procedures for installation 9
a.,
7 and checking the loads and piles have been developed.
g.
]
8 Q
So, that within the last 10 years load testing dd 9
2.
to your knowledge has become much more reliable.
10 A
Load testing has always been reliable, but there II are additions to that work that are done that make it even m
I I2 more reliable.
5 5
13 Q
Can you just tell me briefly what you are referring a
14 to'when'you said " additions to that wo rk" ?
h:
g 15 A
Well,. things that you do in addition to the a'ctual
=
g 16 loading of the pile.
as h
I7 Q
Can you give me an example ?
in E
I8 A
Yes, use of the waive equation which was developed E
19 about 10 years ago.
20 Q
Could you give me one more example?
21 A
That is the basic.
22 Q
And in your opinion of the waive equation and 23 :
other I think you described as additions, make the load 24 tests so reliable now that in your engineering judgment 25l whatever you would learn from obtaining sheer strength is ALDERSON REPORTING COMPANY, INC.
36 1
just not worthwhile going after.
2 A
That is correct.
The combination of the load test and 3
waive equation analysis when properly done by somebody 4
who understand it is far superior.
3 5
A Okay, now, you do the load test obviously before 9]
6 you install the piles?
E 7
A That's what I said.
]
8 q
gefar,7 d
f.
9 A
Before you install the piles for the structure.
10 Q
Can you design the piles before you do the load II l tests or do you have to wait until after the load tests?
it i
f I2 MR. FARNELL:
Are you talking about the piles -- I s
5 I3 think there is problem.
2 I4 MR. PATON:
Can you design the piles that are going g
15 l to, be installed prior to doing the load tests?
z id I6 l
'dITNESS:
What aspect of the design do you refer to?
w h
II BY MR. PATON:
h 18 Q
Load-bearing capacity.
6 II g
A I believe it is possible to state that a pile 20 of capacity can be driven up the side.
21 Q
Let me get away from what is possible.
Do you 22 know what your plan is in this case?
23,
A Yes, I do.
My understanding is that it is to Ml drive 110 capacity piles that utili::e but use only 75 tons 25 of them.
s ALDERSON REPORTING COMPANY, INC.
37 1
Q I heard y9u say " drive 110 ton capacity piles" 2
and I didn't hear the rest.
3 A
Well, the actual required capacity should be 4
75 tons, that is my understanding, but for conservatism,
=
5 the piles will be driven as 110 piles.
6 Q
I don't know what you mean by they are driven
~nfI as 110 piles, f8 A
They are driven to a sufficient depth to allow d
c; 9
a 110 allowable capacity.
$l 10 Q
But you have determined that the load bearing 11 capacity is 75 tons.
m
(
12 A
Presumably a structural engineer has provided 5-13 5
that information.
That's what I understand.
a h
I4 Q
How did he do that prior to conducting the load
$]
15 test 7 x
y 16 A
Ee did that from his structural analysis, w
h.17 Q
What kind of information did he use?
s 18 A
Presumably; the weight of the structure and whatever 6
19 design perimeters go into the structure.
20 Q
Doesn't he know sheer strength of the soil to 21 know that?
22 A
No, he does not.
23 Q
Mr. Ferris, the 75 tons, is what the structure 24 will impose; is that correct?
25 A
That is my understanding.
I have not made that l
l ALDERSON REPORTING COMPANY, INC.
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38
,s s
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calculation bud'that's what I have been told.
2 l
Q Did you say you plan 16 piles?
3 That is my ~ understanding.
~
A s
Q
-30, the total load muld be somewhere in the e
5
-~~
l vicinity of'16 tons ?
s
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A
-Yes,.I don't have a. c3lculator.
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7
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Q Well, ' whate ver that is ? "
l 8
A A
That 's my.,qscollection, yds.
d d
9 i
Q I'm not pressing you on those. numbers.
That ok 10 s
i is the load to be-imposed now what I want to ask you about g
g 11 is the ability of the soil to support a pile that is carrying 3
(
12 x
75 to 110 tons.- snd my question is don't you need to know 3
13 R
the sheer strength' of str.e soil to know whether the soil
~
l 14 g
can support.16. pile {, each of which f.s darrying between 2
15 g
75 and 110 ton: ?.
- s;
?
16 MR. FAPJiELL:
1,s think it was \\75-without 110.
17 ll g
MR. PATON:
All right, 75 lii 18
~
g WITNESS:
I believe I have already answered that.
s 19 l
You do not'~ need to know the sheer strength of.the soil.
s y
c BY MR. PATON:
21 s
s s
Q Do you need to know.the sheer strength of the 22 soil td;know he,g.mnny piles are requirsd?
23,
V A.
Notiin my opinion.
s Nr. Q 24
'^
Q-Ferris., in your experience within the last s
25l
't-five years, have,;'otI'.,,,first estimated ^bcaring capacity by
~
s
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A _
g, ALDERSON REPORTIN.G CCMPANY, INC.
a
39 1
analytic methods?
In other words, have you followed the 2
procedure that's suggested by the staff as opposed to using 3
load tests?
4 A
I personally have not.
5' Q
Do you know of any instance where it has been j
6 done?
R 7
A It may have been done, I can't recall.
N$,8 q
To your knowledge, do you recall now?
d i
d 9
A I do not recall right now.
g 10 Q
In the last five years, approximately how many
=
11 instances do you recall in which load. tests were used instead in I
12 of.first. analyzing bearing capacity by analytical methods?
5 5
13 A
I can recall three right now.
a l
14 Q
Okay.
Could you describe those three briefly?
E i
g 15 A
Yes.
I can tell you the project, Bellrich project,
a ij 16 which is being done out of the Ann Arbor office and two e
h 17 l specific contracts on the Hope Creek, Nuclear Plant Fernon l
h IO '
Categoric I structures.
h 19 Q
Does waive equations involve an analytical approach?
20 A
Yes, it does.
21 Q
Is it used in connection only with load tests?
22 A
No, it do e sn ' t have to be used, you need to know 23 the load tests to use it, but there are aspects beyond 24 that where every time you use a waive equation you don't 25l
, have to have a load test.
I ALDERSON REPORTING COMPANY, INC.
40 I
Q' Does waive -equation use sheer. strength?
2 A
No, it does not.
3 Q
Is the waive equaticn approach reliable in hetero-4 generous, coil deposits?
=
5
~
A Yes, I believe it is '.
h 3
0 Does the pile Ioad test permit ycu to determine
/
Q g
7 long-term settlement $,.
N j
8 f,
.No, the 9116-( load doe' not. permit you to do that, d
c; 9
Q
.Do
- you make any determining af settlement of z
10 the piles?
2 4
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A I believe the piles;were beingfinstalled' conservatively Y
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Does ' hat mean' thatythey dra driven dcyd toithe s
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,cThe piles must be driven into the till.
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And.on:e they age driven into the till,c does m
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that mean you' can for:;et about settisment?
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i, Okay, tell me what 'i:oncerns you have,bi,Fany
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A We will have to determine that.
2 Q
Eow do you determine that ?
3 A
You do it as a result for your valuation of the 4
load test and the waive equation.
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Q Then I thought I started out asking you does 5
6l a pile load test permit you to determine long-term settlement?
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A I'm talking about capacity, the pile load test Ml 8
determines capacity.
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Q Does a pile load test tell you how much of the 5
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11 A
It does under the immediate load, it does not a
N 12 tell you the long-term settlemant.
~n3 13
.Q That's what I'm concerned about.
The long-term 5=
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14 l set tleme nt.
Do you have any concerns about long-cerm settlement ?
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15 A
No, I do not in this particular instance,.
g 16 Q
. Why not ?
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17 A
Because I believe I told you that the piles are E
5 18 going to be installed for a higher capacity than is required E
I9 and that provides your margin of safety.
g 20 Q
You mean you have determined that 75 tons each 21 pile supports approximately 75 tons?
22 A
Right.
t 23 l Q
But they will be conservatively placed so that i
24 they will support 110 tons and there fore you are not concerned-i 25 [
about settlement ?
I ALDERSON REPORTING COMPANY, INC.
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42 1
A That's correct.
2 Q
Will the load tests allow you to determine a 3
down drag or negative skin friction and I'm equating those 4
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3 A
The load test will not, the load test that I et 3
0 have been discussing with you will not.
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Q How will you determine that ?
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0 A
I do not know precisely how that 's being done.
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Q Do you know whether it has been done ?
o 10 A
I do not know that either.
fII Q
Do you know -- you stated there was a determination g
12 that each pile would support approximately 75 tons, do s
j 13 yo,u know when that determining was made?
The precise date.
3 14 g
A Who is going to design the pile s?
-j 15l A
We are authorizing a consultant to assist us
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Q What is the name of that consultant?
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18 A
That 's Dr. M. T. Davisson.
19 g
Q Do you know when he was retained?
20 A
Sometime in 1979, prior to the end of June, 1979, I
I can't recall the precise date.
Q And is it Dr. Davisson that determined that you 23 were going to need 16 piles that would support 75 tons 24 each?
A No, I belie ve we we nt through all that.
The i
ALDERSON REPORTING COMPANY, INC.
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43 I
structural engineer provided the loads that the piles have to 2
carry.
3 Q
Do you know who the structural engineer was?
4 A
I do not know who that was at that time.
5 Q
S.), the structural engineer provides that information 3
0 to Dr. Davisson, right?
R b
7 A
He provides it to Sherif Afifi.
Nl 8
l Q
And does Dr. Afifi add any information to that d
9 when he passes it on to Dr. Davisson?
10 A
. I don't know any reason why he should.
II Q-Dr. Afifi doesn.'t he add any information to it?
m y
12 A.
With regard to the load-bearing capacity?
s f13 q.
No.
That.'s not what I mean.
I mean within Dr.
l 14 Afifi's area of expertise and responsibility, what does 15 he add to ' the 'information he got from the structural engineer I6 a
before he passes it on?
w f
I7 A
He would provide the soil data at the. structure, 18 the boring logs, whatever information he had, water table E
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level.
20 Q
Would he provide all the information we talked II about before under the heading of soil conditions, for 22 example, clarifying the soil into gravel, sand, clay and 23
- stig, M
Q A
Well, he would provide the borin5 logs and 25 any evaluation of those logs that he made.
l l
ALDERSON REPORTING COMPANY, INC.
44 1
Q From which someone else could determine the soil 2
clarification into gravel, sand, clay and silt.
3 A
I believe, Dr. Afiri will have a clarification 4
for the soils on the boring logs.
g 5
Q You say he will have --
E 3
6 A
Or he has.
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7 Q
Do you know whether he has or whether --
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8 A
He has on all the boring logs that he has seen.
dn 9
I. do n 't know why.it, should be different here.
10 '
Q Do you know when he obtained that information 3
11 here ?
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12 1
A At the time of the drilling.
b 13 l 5
I Q
Nhich was when?
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A I don't recall the precise date when those borings l
2 15 were made.
U
,7 16 Q
Do you know whether it was before December 6, e
6 17 1979?
5 18 A
I believe so.
E 19 Q
Do you know whether Dr. Davisson is now designing 20 the pile foundation?
21 A
I do.t't know.
22 Q
W1'Al Dr. Davisson address long-term settlement 23 l or the pile s; is that his responsibility?
24 A
I believe he will comment on that.
t 25 Q
Do you have any idea whether he has made any ALDERSON REPORTING COMPANY, INC.
45 1
conclusions in that respect yet?
2 A
I don't recall that either.
3 Q
Did you ever talk to Dr. Davisson?
4 A
Yes, I do.
i y
5 Q
How frequently?
I R
6 A
Well, I talked to him last Thursday.
I R
7 Q
Well,.that doesn't help me too much.
M Approximately
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8 how many times a week do you talk to him?
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5, A
Probably once a week, but not necessaril:
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'Okay, with respect to Bechtel and Dr. Davisson, Q
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12 l who is the principal contact for Dr. Davisson?
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,A' Afif1 in Ann Arbor.
m i
l 14 Q.
With respect to this problem, with re'spect to
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15 the Midland Project?
a 7
16 3
A With respect to the Midland project.
e 17 i Q
Mr. Ferris, I may have asked you this question x
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18 be fo re, and I j us t don 't recall your answer.
I want to 5
19 g
ask you on December 6,1979, what did Bechtel know about 20 the maximum static and dinet flows to be imposed on the II piles to underpin the surface water structure?
22 A
You would have to ask a structural engineer that.
I 23 Q
And you are not -- do you know who the structural 24 engineer is?
25 A
The project structural engineer, whoever that i
l ALDERSON REPORTING COMPANY, INC.
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1 is, che Midland Project Structural Engineer.
2 Q
The Bechtel --
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A Bechtel.
4 Q
Not Consumers?
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5 A
No, Bechtel.
5
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6 Q
Mr. Ferris, did you bring any files with you today?
R R
7 A
No, I didn ' t.
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8 Q
Can you tell me why you didn't?
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9 A
Because I don't have any personal files on the i
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No notes?
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12 A
No, any notes that I had, I sent to the project.
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To Sherif Afifi.
l 14 q.
When did you do that ?
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A After meetings.
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You mean right after any meeting you would send as 17 him the notes?
18 A
I would send him the. notes to be incorporated E
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into the notes of the meeting.
20 Q
So you have no personal notes?
21 A
No, I have no personal notes.
I do a lot of 22 projects.
I don't keep-personal individual file s.
23 Q
Can you describe what kind of records are kept 24 at Bechtel in San Francisco with respect to the Midland 25 soils problem?
ALdERSON REPORTING COMPANY, INC.
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A I can only -- just those that are in our geo-2 technical group there.
3
-Q Ye s.
4 A
And I receive copies of correspondents, the reports 5
that you mentioned earlier, things like that, and those e
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6 are filed in the geotechnical files in San Fransisco.
7 Q
How many people work in the geotechnical?
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8 A
We have about a dozen soil engineers.
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'Q And are you --
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10 A
I'm in San Fransisco.
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Right, and do you supervise that group ?
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12 A
Yes, I do.
That 's one of my responsibilites.
13 Q
These files are kept in a file for a group that l
14 you supervise?
I 2
15 l A-No, I supervise their individual work, I work g
16 for a manager of soil engineering who is overall in charge s
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18 Q
Who do you work for?
E 19 A
Harris Burk.
I 20 Q
You don't consider those files to be under your 21 control?
22 A
No, I don 't, I consider them to be under Mr.
23 Burk 's control.
I have access to them.
i 24 Q
What kind of information is in those files other 25 than correspondents that you received?
f ALDERSON REPORTING COMPANY, INC.
48 I
A There would be correspondents that we have received l
2 or sent, that 's essentially all.
3 Q
Okay, are the files that concern themselves, 4
are the papers that concern themselves with the soils problem e
5 in Midland kept in a discrete file or are they mixed in h
j 6
with other papers?
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A They are -- the file we have is for the Midland
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8 Project and the reports, volumes of reports that you referred d(
9' to are kept in a separate place from that particular filing I
h 10 cabinet.
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Okay, by that you mean the 50 54(f) responses?
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.A Yes, the hard-bound three-ring binders.
s 13 j
Q Right.
Ignoring for a minute, the volumes that 14
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contain the 50.54(f) responses, what is the quantity of si 6
15 material that you have in the Bechtel office that concerns
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h I7 be placed in one drawer of a file cabinet?
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5 18 A
It's about a drawer and a half to the best of E
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my recollection. I'm not absolutely sure, I don't do the 20 filing.
21 Q
And can you give me any kind of idea how far 22 back that file goes in time to some year, '75, '747 23f If you know.
M A
I don't know how far back, most of it I'm sure 25 goes back to 1978.
I ALDERSON REPORTING COMPANY, INC.
49 I
A Do.you mean at least to 1978?
2 A
I said the bulk of the correspondence in that 3
is from August of '78 up to the present.
4 q
.How long have you been assigned to the San Fransisco i
g 5
office?
@f0 l A
21 years, a little over 21 years.
7 Q
I want to ask you about contracts between Bechtel A]
8 and other organi::ations with respect to the piles in the d
I surface water structure and I want you to ignore the contract 10 that you made or have with Dr. Davisson, do you have knowled e S
II of any other contracts between Bechtel and anyone with a
f II respect to those piles?
s 13 j
A
, I don't believe I have any contract documents.
14 Q
Okay.
I didn't ask you if you have any documents, h:
15 7,m asking you do you have any knowledge as to any contracts g
16 between Bechtel and anyone with respect to it?
w h
II A
I don't recall that at all, I don't recall seeing
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Q In the normal course of your business, would 20 you expect that there was a contract for the purchase of 21 these bills by this time?
22 A
I would expect there was if they had been contracted 23,
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Q I'm afraid your answer to me scrt of --
. 25 A
I don 't know.
I haven't seen the contract to the ALDERSON REPORTING COMPANY. INC.
50 I
best of my recollection.
2 Q
In the ordinary course of your experience, you have 3
been with Bechtel for 21 years in the San Francisco Office, 4
and you are now in the Midland site and the soil problems e
5 t here.
h What would be your. estimate.of when Bechtel ordinarily j
6 would have contracted ~ for the purchase of' those piles?
R R
7 MR. FARNELL:
Are you talking about as the design X]
8 or the pile or are you talking about some point in time d
d 9I or some --
Mh.PATON:
No, I'm talking about his knowledge of 10 E
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II l this case and to estimate approximately when --
3
(
12
' WITNESS:
I don't know anything about the contract
=
1 3
5 13 for the pile s.
a l
14 l BY MR.. PATON:
5 15 5
Q I underst.and that, and I'm clear on that.
I'm a
j 16 asking you in your 21 years of experience with Bechtel.
d l
N 17 i A
On a general basis?
U l
18 Q
On.a general basis, when would they ordinarily E
19 contract for pileg bearing in mind your knowledge of this g
20 case, approximately when?
21 A
Ordinarily on a job you would contract shortly 22 before you drive the piles.
23 :
Q Do you mean maybe six months before?
I 24 A
Could be on that order.
t 25 Q
Then you would not be surprised to learn that Sechtel l
ALDERSON REPORTING COMPANY. INC.
51.
I has not yet contracted for these piles?
2 A
They are not doing work so it wouldn't surpr.ise 3
me.
4 Q
If you had to guess, would you say they probably 5
have not --
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6 A
I don't know.
e".
8 7
Q Mr. F.erris, is there a problem with the fill
)
8 material in the electrical penetration area?
d 9
A Yes.
,10
.Q Would you please describe that problem?
II A
Aga'in, borings in that area indicate low blow in I
II count.
g 5
13 Q
Do you remember precisely what the blow counts
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l 14 were?
g 15 A
No, I don't.
8 I
E IO !
Q Is there any other indication of pore fill in at h
I7 that area?
18 A
There is principally low blow counts.
E II g
Q What conclusions have you reached as a result E
of obtaining low blow counts in that area?
II A
As proposed to underpin the penetration areas?
22 Q
What I mean by my question is what conclusions 23 l have you reached as to the conditions of the soil?
Ml A
Well, there is loose material there.
I E!
Q Eave you reached any other conclusion other than ALDERSON REPORTING COMPANY. INC.
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52 1
there is loose material there ?
2 A
I don't know what you mean.
3 MR. FARNELL:
By a " problem" what do you mean?
4 MR. PATON:
I mean do you agree that there is pore 5
fill in that area?
5 g
6 W
. ITNESS:
There appears to be based on the blow count.
R R
7 BY MR. PATON:
K j
8; Q
And I'm asking you what you know about the fill 9lI de and you have indicated to me that there are low blow counts i
\\
10 and that indicates -- did you say -- loose fill --
~
j 11 A
Loose or less dense than we had anticipated.
m j
12 Q
And I'm asking you, are, there any other indications 5
13 of. the inadequacies of' that filled material?
]
14 A
I'm not aware of any.
E 2
15 1 Q
Please describe the remedy that 's proposed and 16 I'm now talking about the electrical penetration area.
g e
(
17 )
A It is proposed to underpin the ends of the electrical --
18 I guess they are called the wings of the auxilary. building.
E 19 R
Is that the same place that you are talking about ?
20 Q
Can you describe in a little more detail what 21 the proposed remedy is to this soils problem in the electrical 22 penetration area?
23 A
Well, they are going to carry the load e.t the 24 end of each wing of the auxilary ou11 ding down into the 25l glacial till by means of caissons, so they are going to i
ALDERSON REPORTING COMPANY. INC.
53 I
transfer the load at that end to the till so that the fill 2
is not supporting it.
In the process of doing that, they 3
also have to supoport one of the column walls of the Tushen 4
building which is an adjacent building, or locally they
=
5 have to column lines.
U 5
6 Q
What is going to support the other end of the 7
wing that is going to be supported?
3l 8
A The control building.
dn 9
Q Is this proposed remedy going to impose additional i
yh 10 loads on the control building?
]
11 '
A I believe it will, a
p 12 Q'
Was that taken into account in the design of 13 l the control building?
=
l 14 A
I do not know that.
E 15 Q
Is that not within your area of expertise?
j 16 A
No, it is not.
e g
17 Q
What was in the original design?
What was to 5
5 18 support this wing that is now going te be supported by E
19 the caissons?
20 A
Fill.
21 Q
Okay.
Do you consider the change from the support 22 from the fill as in the original design to caissons resting 23 ;
on till; is that in your opinion a significant design change?
24 A
It would change the design to the extent that i
25,'
a structural engineer should look at the design.
ALDERSON REPORTING COMPANY, INC.
54 1
Well, he should look at the design, he should evaluate 2
the de sign.
3 Q
Doesn't it require a fairly substantial amount 4
of redesign?
l 5'
A I'm not a structural engineer.
5 g
6 Q
Within your area of expertise, do you consider 7
this a signific. ant change in the design?
]
8 MR. PARNELL:
I think he answered.
dn 9
WITNESS:
I believe it is a change.
i h
10 BY.MR. PATON:
z j
11 Q
Well, my question was whether it is a significant 3
g 12 change.
x 13 A
I don't know what significant means.
l 14 '
Q' Then describe to me the design change, it has 2
15 more significance than painting a buildin5 a different f
16 l color, I assume ; is that correct?
d
{
d 17 j A
Yes, there is no connection with that at all.
x k
18 Q
I'm trying to get your expert opinion on whether E
19 R
this is a minor change of design or a major change of design.
20 A
It has changed the support condition for the 9
21 wing walls.
22 MR. FARNELL:
Could the court reporter read back the 23 last question and answer.
24
( At which time the aforementioned 25 question and answer were read back.)
I ALDERSON REPORTING COMPANY. INC.
55 I
BY MR. PATON:
2 Q
Do you have any idea of the dollrr cost of the 3
proposed remedial action for the electrical penetration 4
area?
5 l
A No, I don't.
5 6
Q Do you have any seea of the proposed cost of K
b 7
the remedies th_at are proposed to resolve the soils problem 3]
8 at the Midland site?
d l
f9 i
A No, I don 't.
10 Q
Is there anyone in Bechtel that would address i II that subject?
m Y
I2 A
I'm sure there must be, but I don't know who 4l 13 that would be.
l 14 Q
Do you have any idea who that would be, for example,
15 the comptroller or there must be someone who addresses y
16 problems like that.
e h
I7 A
Well, the project engineer probably knows, but b
18 I don't know for sure.
h I9 g
Q Do you mean the project engineer --
20 A
Of the Midland Project.
21 Q
The Bechtel Project Engineor?
22 A
The Bechtel Project Engineer.
23 Q
And is this the gentleman that's on the site?
24 l l
A No, he is the man in the office in Ann Arbor.
25 Q
And is this Mr. Curtis?
Did you ever hear anyone i
ALDERSON REPORTING COMPANY. INC.
56 I{
in Bechtel di,scuss the cost' of any of the remedial actions 2
that are p"oposed at the Midland site ?
3 A
I do recall hearing a cost discussion once.
4 Q
What did that consist of?
5 A
It
=
h was a discussion of some analysis of different j
6 procedures for correcting the diesel generator building.
7 Q
Do you remember any dollar figures that were Ml 8
mentioned?
d n;
9l A
No, I do not remember precisaly any figures.
10 Q
Who' war at that meeting?
N Il '
A The person that I recall diqcussing it was Carl in y
12 Wiedner.
It was a personal communication.
5 g
13 Q,
You have been with Bechtel for 21 years.
';an l
14 you tell'me generally how Bechtel resolves matters similar 15 to this where an obvious error has been made and there
!l 16 is some substantial cost to remedy that error, how is that w
l 17 generally resolved as between Bechtel and the Applicant?
=
E 18 MR. FARNELL:
Would the court reporter read back the E
19 last que stion.
20 (At which time the aforementioned 21 question was read back.)
22 WITNESS:
I don't know.
23 ;
.BY MR. PATON:
24 Q
In 21 years, have you seen any other situations 25 like this where an obvious error has been made and remedies l
ALDERSON REPORTING COMPANY, INC.
57 I
of substantial portions and remedies have to be proposed 2
and made?
3 A
Yes, I have recalled other occasions.
4 l Q
Can you tell me briefly what was the most r? cent 5
one like this that you can recall?
j 6 l MR. FARNELL:
I'm going to put an objection on the 7
record, I think.this is just totally, completely outside 2l 8
the scope of any permissible discovery in this case.
I'm d
c 9
going to let him answer it, but I think it is a waste of
,2 10 his time and our time.
And also, I'm going to ask him
=
g 11 to not disclose any discussions he has had with attorneys is l
12 within Bechtel with regards to these matters.
s 5
13 MR. P,ATON:
Since you have stated on the record that a
I l
14 l you think this is a waste of time, I think it is appropriate i
g 15 that I make.some response.
I have been --
a il 16 f MR. FARNELL:
That may be more of a waste of time, w
l I7 but go ahead if you want.
E 3
18 MR. PATON:
I don't know why we are getting into the 0
19 g
same acrimonious --
20 MR. FARNELL:
I'm smiling.
II MR. PATON:
Okay, good, you are smiling.
I have been 22 attempting to find out from some Bechtel personnel, it 23 l seems extremely obvious that an error of major proportions 24 i
has been made here, and I would have to assume that'there 25l 13 some arrangement between Bechtel and Consumers as to who is I
l i
ALDERSON REPORTING COMPANY, INC.
58 1
going to pay for this.
And I'm merely trying to discover 2
anything I can about that, because I think it would clearly 3
lead to discoverable evidence.
With respect to how this 4
problem came about, and the proposed remedies and etc.
=
5 that 's the= purpose of my inquiry.
b
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j 6
BY MR. PATON:
R R
7 Q
I believe you can answer my question as to the A
j 8
most recent instance that you recall similar to this where dd9 a major error has been made, remedial action is required.
if 10 A
Could you say what you mean by "similar"?
Do Il you mean that something happened that should not have happened?
in g
12 q
- yes, 5
g 13 A
The most recent that I can recall right away was a
l 14 at a mining project in Utah.
N I
5 15 Q
And was this work done by Bechtel?
=
16 g
A Yes, it was, w
g 17 '
Q And something happened that shouldn't have happened?
18 Briefly describe that,
e 19 A
Okay, it was a settlement, more settlement than 20 was anticipated by the people at the building structure.
21 Q
And was the problem remedied?
22 A
Yes, it was.
23 Q
Is it clear to you the cause of the problem?
24 A
Yes, I believe it is.
25 {
Q What caused the problem?
l ALDERSON REPORTING COMPANY, INC.
59 I
A
, I believe the sequence of construction was not 2
the sequence that we -- that my group 's personnel had recommended,
3 and that resulted in additional settlement.
Q And was that construction done by Bechtel?
l A
It was managed by Bechtel.
j 6
Q Do you have any idea in that instance the cost E'-
7 of the remedial actions?
A A
No, I do n ' t.
dn 9
Q And you have no idea as between Bechtel and the h
people they were contracting with to do that work, who f
paid for that remedial action?
h A
,No, I do not.
3 Q
And your statement is that in 21 years -- strike E
14 d
that.
In 21 years, can you estimate approximately how many instances you have seen similar to that where work 0
was done on a centract with Bechtel and a major error was made requiring remedial action?
h 18 A
Okay, I can only recall two other occasions.
E 19
]
Q And in your 21 years with Bechtel, you don't 20 can't give us any information on how these matters are 21 resolved as with regard to who pays for those remedial 22 actions?
23 MR. FARNELL:
You have asked him that at le as t twice, t
he has answered it at least twice, which is in my opinion 1
25 ij totally outside.
I think you are really pushing limits here.
l ALDERSON REPORTING COMPANY. INC.
60 I
BY MR. PATON:
2 Q
Okay, well, I gather your answer is no, you don't have 3
any idea.
4 A
I don't now.
5 Q
Now, with respect to the electrical penetration
=
5
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area, you ha e described the proposed remedies underpinning R
7 the wing, which are the electrical penetration areas with M]
8 caissons; is that accurate?
d 5
9 A
It is underpinning the outer ends of the wings.
l3 10 Q
What is the difference between a caisson and 11 a pile ?
is
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12 I A
Size, I gue ss is t he mos t, and the method of 5
.g 13 installation.
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14 Q
Just tell me, which is bigger, etc.
m 15 A
Well, generally speaking, a caisson is bigger, a[
16 and depending on how it is installed, it could be installed d
l l
17 by hand, or it could be installed by drilling process.
E 18 Q
Why are you using caissons here and piles in E
19 the case of the surface water structure?
20 A
In the case of the electrical penetration it 21 is because of the access to the work, you could not drive i
22 piles there, and also, in that particular instance, we t
I 23 t
do wish to investigate the stratum to which we go and make M
sure that the caisson is seated in the glacial till.
25 Q
In the case of the surface water structure, you are r
l ALDERSON REPORTING COMPANY. INC.
61 1
not going to investigate the stratum to be sure that it is i
l 2
installed?
3 A
I did not say that.
4 Q
Okay, we are doing it by another procedure, which I
g 5
I discussed earlier, now, when I asked you a similar question 8
g 6
to what I asked you with respect to the surface water structure, R
7 and that is:
what do you need to know about the soil before X
8 you design the caissons that ' ill underpin the electrical d
d 9
penetration areas.
3 10 A
Okay, the stratum that we are going to -- we
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The glacials till in I
12 in which the major. structure is under, the main concern x3 5
13 j is that the caissons being sent into that till, so we need a
b I4 to insp.ecti the bottom of the caissons to make sure we are
$j 15 'i in that till.
m j
16 Q
My question was what do you need to know about w
h I7 the soil before you design the caissons ?
18 A
You need similar information to that, that I E
19 mentioned at the surface water, we need to know the soil 3
stratification, what is fill and where is the till.
21 Q
Do you need to know for example, the soil conditions, 22 is your answer the same as before that you need to know 23 soil conditions and that would include soil classification 24 l Which is gravel, sand, clay and silt; is that correct?
25l A
That's correct.
ALDERSON REPORTING COMPANY, INC.
62 i
I Q
What is the source of the informa 1on that you 2
have with respect to the till?
3 A
The Dames and Moore Reports?
4 Q
What is the approximate date of that Dames and 5
Moore Report ?
3 8
A My recollection is that there are two and I believe 7
they were in the late '60s, 1969 or 1970.
M 8
Q You indicate'there are two Dames and Moore Reports.
i d
I d.
9 I A
I believe there are two, I was not working on 10
.the project at. that time.
II Q
'Do you know if those reports have been provided
(
12 to the NRC7 8
g 13 A
I would assume so, but I don'* know for my own-14 personal knowledge.
I believe there were appendices to 15 the PSCR in which case the NRC would have them.
j 16 Q
Do you know whether there are any cracks on the wl 17,
penetration area structure ?
I8 A
No, I do n ' t know that.
I don't recall it any-E I'
g way.
20 Q
How often do you visit the site?
21 A
Very seldom.
22 Q
In the last two years, how many times have you 23 l been to the site ?
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Well, that's '79 and '807 25 g
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I ALDERSON REPORTING COMPANY. INC.
63 1
A Probably three or maybe four times.
2 I Q
And in those three or four times, when you go 3
to the site, approximately how long did you stay there?
4i A
Usually for a day or two days.
5 Q
E And when you go there, do you go just to meetings
]
6l or do you go around and inspect and make a physical inspection R
7 of the site?
2l 8
A The purpose of my visit has been to attend meetings, dn 9
I take the opportunity of looking at those areas that I b
I g
10 can see just for personal interest point of view.
i i
Il !
Q In the last two years, how much time have you 3
I 12 spent other than at meetings out looking at the site itself ?
N 13 j 5
A
. Could you repeat that question please ?
al 14 l q
Yes.
You indicated that in the last two years,
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15 l you have been to the site either three or four times.
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A Yes.
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17 Q
And I want you to tell me how much time you have 18 spent outside meetings, in other words, I'm not asking e
19 g
you about meetings, I'm asking you about how much time 20 have you spent on the site looking at or inspecting areas 21 of a site and the structures on the site.
22 A
I don't know precisely, but I would say maybe 23l half a day each time I have been thero.
24 l Q
When is the last time you looked at the electrical 25 penetration area?
ALDERSON REPORTING COMPANY. INC.
64 I
A I believe I have only been once in the electrical 2
penetration area and that would have been some time in 3
1979, I believe, 4
Q Around -
'797 5
A
'79 or late '78.
3,6 Q
And do you not recall any cracks at that time?
7 A
I do not recall having seen any cracks.
Xl 8
Q Okay, now my question is do you have a distinct d
d I
recollection that there was no't any cracks?
10 A
I would not say that.
=
II Q
Do you have any knowledge of any contract with
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12 Bechtel concerning the underpinning of the electrical penetration b
g 13 area?
l 14' A
I'm not aware of any current contract' for underpinning 15 6
there.
N I'
si Q
Are you aware of any negotiations or conversations e
h I7 i
concerning a proposed contract?
u 18 A
It 's my understanding that there were negotiations h'
I g
with the potential low bidder -- or I'm not sure if it was a low bidder, but a selected sub-contractor, sometime 21 about the time that the stop-work order came through.
22 Q
By the "stop-work order " --
23 l A
I mean the December 6th letter or whateve'r it i
24 13, 25 Q
All right, December 6, 1979?
ALDERSON REPORTING COMPANY, INC.
65 I
'A
'79 l
2 Q
What was the status of that contract at that 3
time, I mean was it just being discussed or negotiated 4
or did ic exist or what?
5 A
I really don't know that.
It's not something
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6 that I wouldn!.t normally be. aware of.
7 Q
Okay, who did you hear talking about it?
Al 8l A
I believe the first person who told me was Dr.
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Davisson whom I mentioned earlier.
10 Q
Do you recall anything more about what he told fII you other than what you have just said?
Y II A
Not.really.
b i
g 13 Q
Co you recall who the other party to the contract l
14 was?
E 15 I 5
A Yes, I'believe it was with a firm and I'm not a
16 ai sure of the complete title of the firm, but it had Mergantile w
h II in it.
18 Q
Do you know whether that contract included the II g
design of the caissons?
A I really don't recall that.
21 Q
Who in Bechtel would know about this contract?
22 A
The project would know -- the project engineer.
23 l Mr. Curtis.
M Q
Mr. Curtis spent his time in the office in Ann 25 l Arbor?
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'Q ' _,Sciefig tell me the difference telween Sechtel 4
Power C'orgogtion 'and Dechtel Incorporated.
Just generally, N
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what dod's.eac.h bae YtD.
Why'are t'heyYdifferabt?
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'Bechtal Poweh(Gqrporabion consists of mveral A
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lnd la Wichtel'Incorpord.$ed neadquartered
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I don't now that precisely.,
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All right'.
Thank' yht'.
Do yoh know whether Dr.
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Do.j'ou mean ti!y conttMtual discussions? -
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I do'_not.;know 25 Q
Noy,et a ?.pging' thy contract that' hou indicated was f
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with an organization that had the name Mergantine in the 2
the title and --
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MR. FARNELL:
I don't think there has been established 4
that there was a formal contract.
5 MR. PATON:
I think you are correct.
3 6l BY MR. PATON:
7 Q
It was at least some discussions of a contract; 3l 8 l 1s that. correct?
d I
d 9
A I think what I said was that I had heard that 10 there had been negotiations but I don't know what the status
] IIl Was.
a l
12 Q
And to your knowledge, that contract concerned g
5 13,
the electrical penetration area?
a i
1 I4 A
That is correct, the underpinning of the electrical 15 g
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16 Q
Do you know whether Dr. Afifi provided any input w
l 17 isuch as plans and specifications or any other input with 18 respect to that proposed contract?
E' I
g A
I do not know the. extent to which he might have 20 submitted information.
21 Q
Now, I'm returning to the question of what you 22 l need to know to design the cai:: sons in the area of the I
23 ;
electrical penetration area, and your first response was 24 you would have to know the conditions of the soils, the 25 j soil conditions.
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Q Okay.
You would have. to kdow scii.: classification?
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' Stratifi(ation, yes, which would include the
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4 classification of each~stranum,,,-
S 5
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Okny',- s,tratification and w'ithin each stratum
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6 the classification-of the sot 1?
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A Rignt.
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8 Q
And you would also want to know the consistency dd 9
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of the soil?'
h 10 A'
. Rir.;ht.
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-Q Generally whether it is sort or stiff?
is l
12 A
,Right. 'But primarily you would want to know e
5 13 where t'he surface of tihe till is because that is the stratum
=
l 14 to which you are' carrying a load.
!ij 15 Q
But you do need to know the soil conditions in m
E I'
the fill?
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17 g
A You need to know the fill.
=
18 Q
h But don't you need to know -- you said the depth I'
g of fill, didn't you just tell me that you need to know 20 the soil stratification?
II A
Stratification and classification.
In my reference 22 to the fill, I was considering that to be one stratum.
23 '
Q Do you mean that the fill is one stratum?
l u
i A
I was considering it to be one stratum.
25 Q
That is in fact not the case, is it?
l i
ALDERSON REPORTING COMPANY, INC.
69
+
1 1
A It is a rather heterogeneous stratum in some 2
are as.
3 Q
It is one stratum made up of a lot of different 4
A Lenses.
5 Q
.-- a lot of different types of soil?
0 A
Several different types of soil.
R b
7
.Q And you consider that one stratum?
E j
8' A
I was considering it in the way I was using it dn 9
in the way I was when I responded to your question,
,z l
10 '
Q Do you have to know what the make-up of that 5
Il stratum'is?
In other words, do you have to know what percentage 3
I II of grave 1, what percentage of sand, what percent &ge.of
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3 5
13 clay, e.tc?
m l
14 ;
A blot necessarily in this case, n
15 Q
All right, then I think you are telling me that d
I0 all you need to know really is the depth of that what you at h
II 1
consider one stratum?
18 A
The most important thing is the depth to the C.
I9 g
till stratum and in this area you need to know the depth 20 to the water table because that is also somethin5 chat II must be taken care of in construction.
22 Q
Did Bechtel know those things on December 6, 23 19797 A
Yes, I believe they did.
25 Q
Do you know whether they had conveyed that infor=ation
)
_l ALDERSON REPORTING COMPANY, INC.
L 70 l
I
,to the NRC?
2 A
I do not know that.
3 Q
Would you have to know the maximum static and dynamic 4
loads to be imposed on the caissons?
5 A
I wouldn't have to, but somebody who is designing
+
3 0
the caissons would have to.
R b
7 Q
Whoever designs the caissons would have to know a
j 8
that?
l d
k 9'
A Yes.
El 10 Q
Did Bechtel have that information on December
=
5 II 6, 19797 n
I II A
I believe so.
=3 3
Q bo you know whether the NRC has provided the 5=
l 14 applicant and Bechtel with any recent seismic requirements
_b 15 that may be different from those of the construction when d
I0 the construction permit was issued?
e h
I7 A
I have been told that there is classification a
b II in given to changing the SSC.
E I9 g
Q If that in fact happens, would that affect the 20 analysis of the maximum static and dynamic load to 'ce imposed?
II A
It would not change the static loads, but it 22 would change the dynamic loads.
23 ;
Q Right, do you knew to what extent Bechtel has Ml addressed any change in dynamic -load caused by diff erent 25 l seismic requirements?
I I
i ALDERSON REPORTING COMPANY.'INC.
71 I
MR. FARNELL:
Are we talking about one building or 2
all buildings?
3 MR. PATON:
I'm still talking about the electrical 4
5 WITNESS:
No, I'm not aware of what has been done.
]
6 BY MR. PATON:
R
'h I
Q To design the caissons, you have to determine
]
8 the load-bearing capacity of these caissons, don't you?
d m;
9 A
Would you please reword that question?
z 10 Q
Yes, I think I better.
In order to design the II {
caissons, do?you have to know the sheer strength of the a
f II soil on which the caissons will rest?
3 5
13 A
In order to determine the factor safety against a
14 the sheer' failure, yes.
I 15 Q
And how do you --
t d
I0 MR. FARNELL:
Would the court reporter read back the w
h I7 last question and answer, z
( At which time the aforementioned E
g question and answer was read back.)
20 BY MR. PATON:
21 Q
On December 6, 1979, did Bechtel know the sheer 22 strength of the soil on which the caisson w&s to rest?
23 ;
A Yes, I believe I answered previously that we 24 '
1 had all of the data that Dames and Moore produced.
25 '
Q This is the data that Dames and Moore produced ALDERSON REPORTING COMPANY, INC.
72 1
in 1969 and 1970 ?
2 A
For the till.
3 Q
And that related to the till?
4 A
Yes,.which is the bearing strata for the caissons.
5 y
Q Is it correct that the sheer strength of the 3
3 6
soi!. in the fill -- is it correct that the sheer strength C
d 7
of' the soil in the fill is not in consideration here ?
]
8 A
Well, there could be -- again there could be dd 9
a small down drag load on the caissons.
o 10 i
Q Other. than the down drag load; is that the only Il significance?
m f
I2 A
That would be the only significance.
S g
13 Q
Okay.
For the, record, let me finish.
That would
=
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be the only significance of the sheer strength of the soil b
15 in the fill is the down drag, right ?
d I0 Does the fill material provide any lateral w
h I7 support for the caissons?
18 A
I could not believe that that is taken into account E
19 in the design,_but I'm not absolutely sure.
20 Q
Mr. Ferrib. I believe.you.. indicated that.
21 prior to December,1979, you knew the sheer strength of 22 the soil in the till.
23 A
Right.
I M!
Q And you obtained that information from Dames l
25 l and Moore Reports dated approximately 1969 and 1970?
i ALDERSON REPORTING COMPANY,INC.
l 73 1
A I think what I said was that that in formation 2
was in the Dames and Moore report.
3 Q
Okay.
Prior to December 6,1979, did sechtel 4
ever put that information about the sheer strength of the 3
5 soil in the till into an analysis to estimate the load 8
]
6 bearing capacity of the caissons in the electrical penetration n
7 area ?
Nl 8
A I don't recall for that specific date.
I would '
dd 9
assume if it was done if there was negotiations for contract,
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but I don't now that for sure.
.?
II
-Q Would that have - to be done prior to the contract n
I I2,
being let?
=3 5
13
'A I'm sure somebody would have looked at that.
a l
14,
Q The point is you would have to apply that information 15 to determine what kind of caissons.you were going to buy; y
16,
is that correct?
d
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d 17 A
Not kind, what size.
Uk 18 Q
What design? Do you participate in any discussion C
19 as to any alternative remedy for the problem at the electrical 20 penetration area?
2I A
I don't recall having discussed an alternative 22 there.
I 23 Q
To your knowledge, did anybody in Bechtel ever i
24 l consider any alternative to the use of caissons to 25 underpin the electrical penetration area.
ALDERSON REPORTING COMPANY, INC.
74 I
A' I don't recall that.
2 Q
Wouldn't it be normal engineering practice to 3
consider some alternative to a proposed fix?
4 A
'My answer was that I don't recall.
I did not 5
say that it had not been done.
~
0 Q
In the normal course of your responsibilities, R
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do you think you would have participated in such discussions Kl 8
if they took place?
d f.
9 A
Not necessarily.
10 Q
Who would make a determination like that?
U MR. FARNELL:
Determination of what ?
g 12 MR. PATON:
As' to possible alternative remedies to 9
g 1.3 l the --
=
i 3
14 '
?
MR. FARNELL:
Determining --
E C
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MR. PATON:
Possible alternative fixes or proposed z
j 16 remedies to solve the problem at the electrical penetration d
I 17
- g7gg,
{
18 WITNESS:
The project structural engineer.
E II g
BY MR. PATON:
1 Q
Okay, I believe you indicated you don't know that i
21 person's name?
22 g
7,m not certain of his name and that's why I'm 23 !
unwilling to mention it.
M Q
It's not Mr. Dahr, is it?
25 A
It could be Mr. Dahr.
ALDERSON REPORTING COMPANY, INC.
75 1
Q Whoever this person is as far as you know, his 2
office is in Ann Arbor?
3 A
That 's correct.
4 Q
Do you recall any discussions by anyone within
=
5 Bechtel as to alternative remedies in the surface water hj6 structure. for the surface water structure ?
R d
7 A
Yes, I do recall discussions, I do not recall A
l 8
who'they were with, but I do recall discussions.
d 9
Q Do you recall any possible alternative to the
$g 10 underpinning that was discussed?
11 A
Yes, I do recall that there was discussion on a
y 12 alternatives.
3 5
13 Q
But, you don't recall --
m l
14 A.
1 I don't recall who it was with, u
2 15 Q
Was the question of cost included in those s
,7 16 considerations?
w d
17 J A
I do not believe cost entered into the discussions a
b 18 that I recall.
6 19 Q
You don't have any clear recollection that cost R
20 was not considered.
1 21 Q
I don't recall that either.
22 Q
The usual practice would be t6 give some consideration 23 to cost, would it not ?
i 24l A
Yes, of course, good engineering practice would i
15 '
require a consideration of cost.
ALDERSON REPORTING COMPANY. INC.
i 76 1
Q And good business practice?
2 A
Good engineering practice requires it.
3 Q
Good business practice would also require it 4
wouldn 't it ?
=
5 MR. FARNELL:
It has been asked and answered.
3
]
6 MR. PATON:
He didn't answer it -- that is specifically R
7 what he didn't answer.
X
]
8 MR. FARNELL:
I object.
There is no foundation that d
l 2
9 he,is a business man.
,z h
10 l MR. PATON:
He is a chief soils engineer for Bechtel z
I
=.11 '
i j
and has been with Bechtel for 21 years.
If he doe sn ' t I
12 hav6 an opinion, that 's fine with me.
4 g
13 MR. FARNELL:
I'm still obejeting, no foundation, a
l 14 BY MR. PATO N~:
I l
15 Q
Do you have an opinion?
m E
I0 A
Well, I believe good business practice woulii also.
2 N
I7 Q
E Would also consider that you would consider cost I8 of good engineering?
C II A
Good engineering practice means you are designed 20 to meet the designs criteria at the lowest cost.
So, from 2I an engineering point of view, consideration is of great 22 importance.
23 Q
And you have answered as of engineers a'nd I'm I
24 asking is that also - as of good business practice ?'
25l A
.I just answered that, I believe it is also good i
I ALDERSON REPORTING COMPANY. INC.
w
~
77 I
business practice.
2 MR. FARNELL:
He already answered that.
3 Would this be a gsud time to break for lunch?
4 MR. PATON:
Yes.
5 j
(At which time a one-hour lunch break e
6 was taken.
And the deposition was resumed K
7 after lunch.)
Ml 8
dY MR. PATON:
d d
9 Q
Mr. Ferris, sometime ago, I believe you indicated
,z?
5 10 to me in response to the surface water structure that it 5
II was your opinion that. it was not good current engineering 3
I 12 practice to estimate load bearing capacity of the soil 5
5 13 prior to loaditest; is that what you said?
A l
14 A
I don 't believe I said it in those words.
{ 15 Q
Would you say it in your own words?
m E
10 A
Yes.
I think what I said was there are better d
h 17 I ways of evaluating that.
18 Q
Better ways of evaluating what ?
E 19 g
A Load bearing capacity.
20 Q
And is that better way by load testing?
II A
Load testing combined with the waive equation 22 an& lysis.
23 l Q
And this is a5ain, a better way to estimate lead 24 bearing capacity of pila 3; is that what you said?
25 A
Yes, better way to estimate the load capacity of piles.
ALDERSON REPORTING COMPANY, INC.
o 78 l
I !
Q Did you indicate that at one time it-was the practice 1
2 to estimate the load bearing capacity of the soil first 3
before you. install?
4 A
I would like to correct what I just said there, g
5 I'm talking about the load capacity of the soil, the load 8
i j
6l being transferred through the pile.
7 Q
All r.ight.
Fine, would you say load bearing X
l 8
capacity?
d 9
A If you would like to call it that, that's fine.
10 l It doesn't bother me.
5 J
II I Q
Again, you indicated that it has' been determined 3
g 12 now, cur rently, that it is not considered the best way s '., I a
5 8-to determine to estimate load bearing capacity of the soils.
m l
14 It is current practice to do that prior to load testing, u
g 15 There are better ways to estimate load bearing capacity.
=
E 10 A
I don't remember my precise words, but I believe w
i f
I7
_ what I was indicating was my -- It 's my belief that the I8 procedure that I described using the waive equation and E
19 g
the load testing was a much more reliable way to evaluate 20 the load bearing capacity of a pile in soil.
2I Q
And did you inicate that there had been some 22 change in engineering thinking in this area in the last 23 ten years?
24 A
I think I said it was more than 10 years, I beleive 25 the waive equation was developed in the '50s.
I I
~
ALDERSON REPORTING COMPANY, INC.
~
79 e
I Q
Okt.y.
2 A
And since that time these procedures have started 3
to be used.
4 Q
What is your source of information that indicates 5
g to you that chan5e in thinking in the last ten or fifteen a
5 0
years?
How do you know that ?
,n b
I A
Major. source ?
3 l
8 Q
Yes.
I would like to know all of your sources.
d
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9 ll A
Basically, d_scussions with Dr. Davisson.
C h
10 Q
Discussions on work with Dr. Davisson, would 3
II you say primarily your discussions?
I I2 A
Right.
3i 13 Q
Mr. Ferris, have you read the December 6, 1979 m
E I4 order?
15 A
You just showed me that, I believe; is that the if 16 one you just showed me this morning?
w h
I7 Q
No.
IO Q
Then I probably have, but I don't remember.
U II g
Q Do you rememebr the term " acceptance criteria" 20 in that order?
2I A
I don't remember in what context it was used.
22 Q
Does the term " acceptance criteria" mean anything 23 l to you?
i 24 A
It does to me.
I think you need to tell me in 25 I
what respect you were using it.
ALDERSON REPORTING COMPANY. INC.
i 80 I
Q With respect to the proposed remedies, the remedies 2
that are proposed by the applicant, say for example, on 3
the surface water structure, does the word a' ceptance criteria c
4 have ^ any meaning to you with respect to that proposed remedy?
5 g
A Yes, I believe there are proposals -- in fact, e
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7 us, that we have appropriatei' capacity in piles.
3l 8
Q You said there are proposals to do things there dd 9
E, to satisfy us that we have --
g 10 A
It 's my recollection that in a meeting with the 3_
11
. NRC at Midland in about Feburary last yegr, that there I_
12 was a discussion of what was to be done at the surface S
5 13 water struct.ure.
a 14 Q
.For the purpose of satisfying the NRC's review?
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A Our primary purpose is to satisfy curselves and
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the intention is, course, to reach agreement with NRC.
f I7 Q
Do you know what particular -- can you give me Eg 18 an example of an acceptance criteria as you understand E
19 it ?
20 A
- Yes, It is my recollection that each of the 21 piles at the surface water structure was going to be tested 22 to one and a half times it 's capacity, it 's working capacity.
23 ;
Q And when was that to be done ?
l 24 A
After the pile was installed, and before the' l
25j pile load was -- before the load of the. building was transferred ALDERSON REPORTING COMPANY, INC.
81 I
to the piles.
2 Q'
Now, bearing in mind the word " acceptance criteria" 3
if the test -- did you say the piles were to be tested 4
to one-and-a-half times the working load?
3 5
A That 's my recollection.
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6 Q
And that would.-be to determine the acceptance i
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' o f t he pile ?
2 j
8 A
That's correct.
dd 9
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Q The acceptance of the pile at the working load?
10 A
Ioa. are. overloading the load to..make 'sure that.you 5.II have it satisfactory.
3 Y 'I2 Q
And what -
has that.been. done ?
b 13 l A
As far' as I know the piles have not been installed.
5a ag 14 Q-The proposed remedy, when was this proposed remedy
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16 A
I do net,know that date, What I just said was e
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that I recall it being discussed with the NRC and I believe U
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it was about 7ebruary; of last year.
20 Q
February of this year?
21 A
I beg your pardon, not last year.
I think I 22 might have said last year, but I mean 1980.
23 l Q
Okay, February?
i j
24 A
of 1980.
1 25l Q
That's when the proposed remedy for the surface l
l ALDERSON REPORTING COMPANY, INC.
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water was discussed in early 1980?
2 A
In February of 1980 it was my recollection.
3 MR. FARNELL:
Are you saying that was the first time 4
it was proposed?
5 MR. PATON:
I just asked him what was said --
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6 WITNESS:
To clarify the record, what I said was I d
7 did not recall when it was first discussed with the NEC, M]
8 but I do recall it being discussed with the NRC at a meeting d
9 at which Mr. Kane was present in Midland in February of 5g 10 1980.
5 II '
BY MR. PATON:
n f
II Q
Now, this proposed remedy is before the NRC, 3
5 13 now you have.sent it to the NRC?
m I
14 A
It was. discussed with them.
I do not" have anything
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Q But it has been proposed to the NRC to your knowledge?
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h I7 A
Yes, it may have been sent, but I don't know.
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And this acceptance criteria that the piles would E
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have the ability to bear one-and-a-half times the load 20 that was expected, that test is going to be conducted sometime 21 in the future; is that correct?
22 A
Yes, when the piles are driven, after the. piles 23 are driven.
M Q
And the NRC will not know whether they meet that 25l requirement until af ter the pile s are driven -- you won 't know -
ALDERSON REPORTING COMPANY, INC.
83 I
7 that either ?
-2 A
That is correct.
This is an acceptance criteria.
It 3
is an acceptance of each individual pile in the building.
4 Q
dell,. under that set of circumstances, since 5
the NRC will not know until you perform this test, which 6
is sometime in the future, that the piles meet that. test, R
I then is there any way that NEC could accept these piles e,
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j MR. FARNELL:
I'm going to object to that, I don 't 10 know what the NRC can do.
They can prove they can do a
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h. 12 MR. P ATOR:... If this is within. your. understanding of. acceptar c 5
13 j
criteria, it would be acceptanc9 for what purpose?
14 WITNESS:
.Construccion.
g 15 BY MR. PATON:
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And are you using that in the context of saying h
I7 that the NRC would after receiving this information approve a
IO your proposal for construction?
E g
A No, I have said other things to you about this, that isn't the only thing I said to you about it.
I Q
All right, but let's talk about this one.
A As far as the installed piles in the building, l
individua'lly being accepted, that is my understanding of the acceptance criteria.
Q Okay, do you propose that the NRC accept this i
ALDERSON REPORTING COMPANY, INC.
l 84 I
proposal prior to determining whether or not it meets this 2
acceptance criteria of one and a half times the expected 3
weight.
4 MR. FARNELL:
Would the court reporter read back the
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6 (At whic'h time the last question R
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BY M.R PATON:
d d
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The proposed remedy for the surface water structure --
10 i MR. FARNELL:
I don't think that question makes sense.
E j
11 WITNESS:
It doesn't to me on the basis of what I R
y 12 have discussed with you.
3g 13 BY MR. PATON:
a l
14 Q
All right.
We have been talking abcut the word l
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l 15 acceptance criteria.
s j
16 A
That's correct.
d 6
17 Q
Focus on:the word acceptance.
$s' 12 A
'Yes.
E 19 Q
What does tht mean in the context --
R 20 A
In the context that I have been discussing it 21 with you ?
I have been discussing the acceptance of the 22 individual piles which are going to be used for proposed __
23 to be used for underpinning the surface water structure.
24 Q
Have you been using it in the context of acceptance 25l by NRC7 i
I ALDERSON REPORTING COMPANY. INC.
85 1
A Acceptance by'anybody, Bechtel, our client and
.NRC.
3 Q
Well, then you would not expect the NRC to accept it until after this test has been accomplished.
A Accept what?
3 6
Q Well, does the NRC when you send them information, 7
3 do you' send them a proposal for-the s.urface water structure; j
8 d
is that correct ?
d 9!
N A
Right.
10 l
I Q
What do you expect them to do with that proposal?
g 11 8
A Expect them to evaluate.
This is one item in g
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g 13
',Q Isn',t the objective of your suomitting that proposal 3
14 33 l that they'evaulate and accept it?
A My feeling is that they should not accept it 16 g
d on one item out of that structure.
f 17 j
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Q I think we can go through the same exercise with a
18 E.
all the proposals I want to see how this particular one 19 k
works.
Would you expect NRC to accept it on whether or 20 not it met the criteria?
21 MR. FARNELL:
What do you mean? I'm confused.
MR. PATON:
He has just told me precisely what he means by acceptance.
i WITNESS:
If you don't mind, I would like to answer it as I understand it.
I believe we have told you the ALDERSON REPORTING COMPANY, INC.
86
~
I acceptance criteria that are proposed to be used and I believe 2
that 's one of the items that the NRC shoulc review in their 3
review of that structure.
Now, the acceptance of individual 4
pile r will be based on that acceptance criteria that the 5
NRC has reviewed and hopefully accept it.
.6 BY MR. PATON:
9 b
7 Q
Okay, that is an acceptance criteria, can you M]
8 think of another example of an acceptance criteria with d
I d
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respect to the remedy for the surface water structure ?
h 10 A
Well, that is the principle acceptance criteria.
E I
4 II
. I'm having problems with what you are asking.
3 I
I2 Q.
I think a lot of people have trouble with that 5
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l 14 MR. FARNELL:
The questions you are asking?
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MR. PATON:
Yes.
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us h
II Q
Our max 5. mum dynamic loads to be imposed are they 18 acceptun:e criteria?
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g A
Not in the pile driving portions, the insulation 20l of the piles, the maximum dynamic loads have to be taken II care of in the design o f the structure, which may lead 22 to the capacity of tl'e pilings being a specific number i
23 !
of tonnage or whatever.
M Q
Well, fJr anybody to evaluate the piles that 25 l are proposed to be used at the surface water structure, don't l
I l
ALDERSON REPORTING COMPANY, INC.
87 1
they have to know what the dynamic loads are to be imposed 2'
on that pile ?
3 A
Somebody would have to satisfy themselves that 4
we have enough piles in the structure to take care of the a
5 E
loads that are coming on the structure.
3 6'
g Q
' Well, then are dynamic loads to be imposed an acceptance d
7 criteria?
l 8
e A
Not for the installation of the piles as such.
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As I understand your question.
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Q Do you agree that you have to make that determination E
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at some time ?
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MR. FARNELL:
Which determination?
g 13 8
MR.'PATON:
The dynamic load'to be imposed on the l
14 {
g p iling' s.
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WITNESS:
That must j
16 be included on the design.
d BY MR. PATON:
G 17 s
Q Eefore installation?
b 18
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Certainly, before you come up with a design for 19 the founda' tion you must know what it is you are designing l
20 for and the loads is one of the most important things.
21 Those are one of the most importhant things.
Q Did Bechtel know on December 6, 1979 what the 23 dynamic loads were 24 to be proposed on the piles for the 25,
proposed surface water structure?
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I ALDERSON REPORTING COMPANY, INC.
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A I do not know.
That is not in my E.rea of expertise.
2 Q
Does the 75 ton pile load capacity corporate 3
seismic loading?
4 A
I don't know the answer to that, what I gave.
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Q Have.you heard any discussions among any people
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The word is used very often.
I don't recall E
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II e
Q a,
In your professional experience, excluding for f
I2 a minute NRC's use of that 1:erm, is that a term that you ci -l 13 understand other,than its use in connection with the l
14 g
-NRC?
15 I
Well, I would understand that use of terminology, i[
I6 but it would have to be in some context.
ad h
I7 Q
Okay.
Do you consider demonstration of an adequate 18 raargin of safety against bearing capacity failure to be I9 g
necessary to accept your proposed remedial measures?
E MR. FARNELL:
Could the court reporter read back the 21 last question.
22 (At which time the aforementioned 23 question was read back.)
M MR. FARNELL:
Are you talking all remedial measures?
25 l MR. PATON:
Surface water structure.
I I
i ALDERSON REPORTING COMPANY,INC.
89 1
MR..FARMELL:
I guess Ihave a vagueness objection.
2 I don't know what adequate margin of safety is.
3 MR. PATON:
That 's in his opinion, I mean if he doesn't 4
have an opinion, that's up to him.
5 WITNESS:
There may be other criteria that I'm not h']
6 aware of, but that is certainly one of the important criteria.
3 7
BY MR. PATON:
3*l 8l Q
Okay, so that in your opinion, demonstration d
d 9
z, of that margin you consider that necessary?
10 A
Yes, I believe I have already stated that several 11 times today.
I 12 Q
Would you say the same thing for demonstration 4
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.of an adequate margin of safety against liquifacture failure?
3 14 A
Yes.
It 's our normal practice to have a factor b
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Would you say the same thing with respect to e
d 17 unacceptable elements of settlement?
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18 A
I would not be able to' discuss that with you E
19 g
as such, because it combines structural analysis as well.
20 It depends on the function of the structure.
21 Q
Can you tell me what process Bechtel followed 22 in selecting its consultants?
23 :
MR. FARNELL:
For the Midland project?
i 24 l MR. PATON:
For this M.idland soils project.
25l WITNESS :
I can tell you with respect to some of_ the i
4 ALDERSON REPORTING COMPANY, INC.
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90 I
consultants, I'm not sure that I can tell you with respect 2
to all of them.
On the first trip that I made to Midland, 3
following the problem that we have been discussing here today, 4
the settlement problem of the diesel generator building, 3
5 I was asked by Phil Martinez to nominate consultants in 8
3.
6 the area of soils.
R-R 7
.And I had a discussion with him at which n]
8 we discussed the possibility of Dr. Peck being the consultant.
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I pointed out to Mr. Martine s.that Dr. Peck is very busy, h
10 much sought after consultant, and I thought there was a
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I I2 his job as was possibly required.
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13 And so I made a suggestion to him, to Martine=,
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14 that we ask both Dr. Peck and Dr. Hendron to be consultants 15 in the area of soils for the evaluation of the diesel generator E
I6 building on the understanding that Dr. Hendron would be w
f I7 the more available of the two and he and Dr. Peck when f18 they could would review their work amongst themselves and E
19 g
then provide us with their evaulation of those areas that 20 we reque sted.
II I believe Sherif Afifi.was present with 22 !
me when I had the discussion with ' Martinez and I believe 1
23f it was in the Ramada Inn in Midland is where we had the i
24 discussion.
5 25 BY MR. PATON:
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i ALDERSON REPORTING COMPANY, INC.
91 I
Q You have indicated, however, that it was your 2
idea.
3 A
It was Mr. Martinez's idea that they required 4
a consultant and he asked me to recommend one to him.
I g
5 did and he accepted the recommendation that I made.
9 5
0 Q
Did the name Dr. Peck come to mind because of C
2 7
your knowledge of his reputation in the area?
8 A
of course, Dr. Peck is one of the best known d
4 9
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soil engineering consultants in the world.
10 Q
Do you know how many hours your consultants such
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I mean do you keep records like that?
S 13,
j A
I don 't keep records like that.
Ei I4 MR. FARNELL:
All consultants?
1 6
MR. PATON:
Let me stick with Dr. Peck.
s I0 WITNESS:
I personally do not keep those records.
h BY MR. PATON:
z Q
Does anybody keep records like that ?
E g
A I believe that there may be records like that.
Q I gather from the answer you don't really know 21 for sure.
22 A
Well, Dr. Peck bills us for his work and I believe 23 you could from looking at his bills over the past two years determine the number of days of work that he has done on 5l the Midland Project.
But I don't keep those bills myself.
ALDERSON REPORTING COMPANY, INC.
92 I
Q Do you know who does?
2 A
Yes, our accounting office would, but I don't 3
know how long they keep them.
4 Q
I assume you don't have any way to estimate how 5
,3
=any days Dr. Peck for example --
e j
6 A
Not right now, I don 't.
'l 7
Q And would your answer hold generally true for
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9 don't know?
You can't estimate for example, the number h
10 l of days they have spent on the project?
e 4
II A
That is right.
I could not tell you today how 3
k II many days he spent on that specific project.
3 5
13 Q
?ou stated before you have read Dr. Afifi's' deposition.
m b
I4 A
Ye s, I did.
g 15 i Q
Eave you read any other depositions in this case?
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The only other deposition I read was Mr. Kane 's
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'de finished one portion of Mr. Kane 's deposition E
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that took p' lace on three separate days --
20 A
That 's probably the time.
2I I Q
As far as you know it was three different transcripts?
22 A
I can 't recall that, but it was more than one 3
. volume, and probably it was over two or three days.
i 24 Q
Now with respect to Dr. Afifi's deposition --
i 15 I I
A Yes.
ALDERSON REPORTING COMPANY, INC.
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93 1
Q Does anything come to mind right now that you 2
disagreed with in his deposition?
3 MR. FARNELL:
I'm going to object to that.
4 MR. FATON:
That exact question was asked by other g
5 counsel on your side of the case.
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6l MR. FARNELL:
I'm still going to put my objection R
7 in.
Mj 8
MR. P 'sTON:
Fine.
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9 MR. FARNELL:
I object to the form, compound.
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10 You can answer it if you recall.
z 11 WITNESS:
I don't reccll anything that I objected 3
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13 BY MR. PATON:
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Q How long ago did you read Dr. Afifi's deposition?
g 15 l A
Probably a couple weeks ago.
i 88 j
16 l Q
With respect to Mr. Kane's deposition, the same d
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17 l question.
5 bi 18 MR. FARNELL:
The same objection.
E 19 MR. PAON:
Do you recall anything in Mr. Kane's deposition 20 that you disagreed with?
II WITNESS:
I would have to say yes, there were some things.
22 BY MR. PATON:
23l Q
Please do your best to tell us what you can recall 24 right now that you disagreed with.
25 '
A I can't remember in detail but I believe that his l
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evaluation of [o{4 pf our proposed analysis is not in agreement 1
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All right.
I would like very much'to get whatever
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Ye s, sir.
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Why don't you call it out and I'll tell.you what i
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10 Q
I don't know '>$at it is that you disagreed with.
g 11 A
I believe to start with the service order, intake 3
g 12 structure, he wanted to evaluate pile capacity using soil E
13 ;l pe,rimeters as we discussed earlier.
I believe our evaluations E
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E 15 On the diesel generator building, his evaluation
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j of the effect of the preload is not consistent with my w
17 evaluation, it affected the preload on the compacted fill, b
18 Q
I would hope you would go on and tell us in what ways.
E 19 A
I believe he has some concern about whether or 20 not the prelcad was kept on long enough and I believe the l
21 data showed that it was.
And I don't recall anything on 22 the other facilities that were to be corrected.
I did 23 not agree that there 'nas a si ned technical basis for requiring d
24 the additional borings that are requested by the court 25l engineers and of course, Mr. Kane has defended in his deposition.
A ALDERSON REPORTING COMPANY, INC.
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I think those are probably the most significant 2
ones that I can recall at the moment.
3 Q
I want to ask you a few questions about the items 4
that you have just discussed starting with the diesel generator i
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5 0
A Sure.
3 7
Q You indicated that you believe the surcharge X
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was left' on long enough, d
9 A
Yes, I,do.
h IO j Q
What is your basis for that?
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My basis would be the results of the piezometer 3
y 12 and settlement analysis, settlement ratings, I mean.
5 5
13 Q
What was it about the pie =ometer readings?
a 14 A
The excess pore pressure had discipated which E
g 15 ordinarily is the manner in which you determine the primary aj 16 consolidation has been completed.
w h
I7 Q
And you also said the settlement data?
18 A
Ye-s.
When the settlement data are plotted on E
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a semi-log plot of settlement versus time, they do reach E
straight line portion and that straight line portion extended II for a sufficient length of time to indicate to me that 22 secondary consolidation was taking place.
23 Q
Was that about a year?
24 A
No, it was not a year, it was less than that.
25 !
The complete load was on in early April of 1979 and the load ALDERSON REPORTING COMPANY, INC.
96 l
I was taken off about I
the middle of August of 1979, so it was 2
about four months.
3 Q
Do you understand from the deposition what Mr.
4 Kane's position is with respect to the need for addi,tional 5
g borings?
a 6
l A
Ye s, I do.
C 7
Q What is his position?
A 8
A As I understand it, he wants to take undisturbed d
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samples and evaluate the preconsolidation pressure of the E
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_s material in the fill beneath the diesel generator building.
II And he al'so wants I believe to predict what settlement t
Y 'I2 might occur.
But as I understood his deposition, he, was
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13 primarily interested in the preconsolidation pressure to l
14 co-mpare that with the preload fill.
_e 9
15 Q
Is it your-understanding from reading Mr. Kane 's d
I6 deposition that he thought the information from the borings w
I7 was more significant than the information to be obtained a
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18 from the surcharge program?
h 19 A
It is my impression that he needed that information 20 before he would have believed the other.
II Q
And is it your tho'tght that the information obtained 22 from the surcharge program -- strike that.
In your opinion, 23 '
is it possible that come valuable information would be 24 l obta..ned from the additional borings?
25l MR. FARNELL:
What is your definition?
I ALDERSON REPORTING COMPANY, INC.
97 1
MR. PATON:
I'm going to ask "possible" and then I'll 2
ask the next step.
I assume it is possible.
3 MR. FARNELL:
Anything is possible, I'm talking about 4 -
value.
5 g
MR. PATON:
He is the expert.
v{6 MR. FARNELL:
That 's too vague.
I'm going to object 7
to it.
Could the court reporter --
Ml 8
MR. PATON:
I'll strike the question.
d N
9li In your opinion, is it possible that there z9 5
10 could be some information obtained from the borings that
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12 I the behavior of the surcharge program?
5 5
13
.MR. F'ARNELL:
Would the court reporter rea'd back the l
14 l last question.
I 15 (At which time the aforementioned
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as h
I7 WITNESS:
My answer to that would have to be no.
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18 BY MR. PATON:
E 19 Q
Okay, that 's very interesting.
You are saying 20 that that 's not even possible ; is that correct?
II A
As I understand your question, you asked me, 22 would the boring give some data that would aid in evaluating 23 ;
the preload.
i I
24 '
Q Well, actually what I asked you was is it possible 25 that you could obtain some information that would be useful ALDERSON REPORTING COMPANY, INC.
98 1
in that regard.
2 A
I don't believe that's possible.
3 Q
And can you tell me why?
Is it due to the heterogeneous 4
nature of the fill?
5 A
I can try to explain why.
First of all, the
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6 preload fill is a full scale loading of the soil, so it R
R 7
is independent of whether or not the fill is heterogeneous.
M[
8 Q
I apologize for interrupting you, could you start d
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5 10 MR. FARNELL:
Would the court reporter read back the E
11
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3 I
12 (At which time the last question
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2 15 M
j 16 j BY MR. PATON:
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17 I Q
Does that complete your answer?
18 A
No, it doesn't.
That was the first item.
The E
19 g
second item, we have checked that the preload fill has 20 done what-we intended it to do, that is take 'out the primary 21 consolidation that 's been done in two ways, one by the 22 piecometers and that is -- the piezometers show that the 23l excess pull pressures have dissipated and secondly, the 24 settlement carved on the semi-log plot has reached secondary 25 consolidation.
l l
AL.DERSON REPORTING COMPANY. INC.
~
99 1
The next item is that in my experience in 2
dealing with preconsolidation as determined in the laboratory 3
on soil samples that that is very much affected by samp].
4 disturbance, and it may also be affected by the soil itself.
I 5
g Whatever manner it has, whatever factors it.has undergone n
]
6 to reach the state at which you sampled it.
-nf7 And I would be very concerned that Mr. Kane
)
8 would take samples and find out from those samples that d
d 9 l he had a preconsolidation pressure that is being equal 5
i g
10 to the overburden pressure at the sa=cle depth, prior to E
11 any preload being there at all.
[
12 Q
You indicated some problems or proficiencies S
5 13 with the laboratory testing that would be done.
m
=
14 5
A Sample disturbances and laboratory testing and
.h 15 the valuation of the laboratory test.
3[
16 l Q
Is there something about the particular instance l
6 17 i that the diesel generator building that makes you more
- s Em 18 apprehensive about using laboratory tests than other situations, E
19 I mean laboratory tests are very commonly used and have 20 been used on this site for other determinations, right?
Il MR. FARNELL:
Could the court reporter read back the 22 last que stion.
23,
(At which time the aforementioned 24 question was read back.)
25 MR. FARNELL:
I'm goin5 to object to the fo:n of that.
ALDERSON REPORTING COMPANY, INC.
100'
~
I You can answer it.
2 WITNESS:
The objections I have to the sampling disturbances I
3 and the laboratory testing would apply to any of the sampling 4
.and testing that 's been done at the site.
Howe ver, t he-
=
5 5
previous sampling and testing that was done prior to construction 6'I of the plant was the only information that we had available eT d
7 to us.
M]
8 We didn't have any preload fill, any full dd 9I scale load tests, we didn't have the benefit of those other Eg 10 factors.
What I'm telling you is that in my opinion, the 5
11 preload fill is a better way to evaluate the settlement.
is f
I2 BY MR. PATON:
3 13 5
i Q
It is a better way, but apparently, you feel aj 14 that. it is so much better that I believe you. testified that 5
l j
15 it wouldn't even be possible that by taking samples and
=
d I6 performing laboratory tests, you could gain any information as h
17 that would help you interpret what has happened to the z
18 surcharge program.
E I9 g
MR. FARNELL:
The record will speak for itself.
n 20 WITNESS:
The concern that I have is that when the II samplin5s are taken and tested that you will end up with 22 a range of values of preload and not know really where 23 you are.
Mr. Kane would be just as much in the dark after 24l that as he apparently is today.
I 25l BY MR. PATON:
1 ALDERSON REPORTING COMPANY, INC.
~
101 I
Q In reading Mr. Kane's deposition, did you get 2
the impression that he would take the information that 3
he would obtain from borings, the borings that he has requested 4
that have not been supplied, with respect to the diesel g
5 generator building, and make some kind of a worse case 9
]
6 analysis?
g R
7 In other words, that if he received a range
)
8 of information that he would use the worse'information d
8 9
to make his evaluation?
Did you get that impression?
10 A
I do not recall that I got that impression.
N II I would like to recall that I don't recall one, way or the 38 I
y 12 other.
~
C" 5
13 Q
It could be then.
Are there any weakneises or
=
I4 l l
l
, deficiencies at all that you are aware of with the preloading E
I 5
15 l method of the surcharging method?
m i
j 16 I A
What do you mean by weakness?
- d h
I7 A
That 's what I'm asking you, and is it a perfect 18 method to accomplish what you are trying to accomplish.
E 19 MR. FARNELL:
Are we talking in general?
Are we talking 20 about Midlar.d diesel generator?
2I MR. PATON:
I'm talking about Midland; soils. surcharge i'
22 pro 5 ram, diesel generator building.
23 l MR. FARNELL:
That wasn't the way the que stion was l
l M
forme d.
i l
25l MR. PATON:
Strike it all.
I'll ask it again.
i ALDERSON REPORTING COMPANY, INC.
102 i
1 BY MR. PATON:
2 Q
With respect to the surcharge program, applied 3
to the diesel generator building at Midland, are you aware 4,
of any weaknesses or deficiencies in, that program?
5 A
Deficiencies in what respect?
h j
6l Q
In accomplishing what it is you are trying to a
E 7
acc omplish.
~
]
8 A
Yes, the preload will not compact the sand portion d
q 9
to the same extent that it will compact a clay portion.
$g 10 Q
Are there sand portions below the diesel generator 11
' building?
3 y
12 A
Yes.
3g 13 Q
Can you describe the -extent to which there are m
14 sand portions below the diesel generator building?
E 15 A
It is my recollection that on the north side g
16 of the building there is a fair amount of sand and particularly w
g 17 in the northwest corner.
=
Q 18 Q
Okay.
E 19 A
There is also evidence of sand backfill along 20 some pipelines that are under there.
21 Q
Did you take any steps to accommodate that problem 22 that the preloading program may not have compacted the 1
23 sands?
\\
24 I
A Yes.
l 25 Q
What steps did you take ?
ALDERSON REPORTING COMPANY, INC.
l-
103 I
A The corrective action proposed, our main concern 2
is that the preload may not have compacted that sand sufficienti-j 3
to preclude liquifacture in the case of loose sand, and 4
our recommended corrective action for that is to lower 5
j the water table in the plant area, so as to preclude che a
5 0
possibility of liquifacture and any sand left.
~a d
7 q
That's to your knowledge, that will be taken N
0 care of by permanent de-watering?
d f.
9 A
That is what is proposed.
h 10 Q
To your knowledge, is that permanent de-watering 2=
5 II proposed solely in connection with sand at the diesel generator a
j 12 buildin5 or is it also -proposed with sand in other areas?
3' g
13 A
It was made as a general de-watering program l
14 l
- to take' care of any sand that might be located in the plant y
15 that were loose, a:
j 16 Q
Has Eechtel had any meetings with Dr. Peck in w
h II the last three months?
E 3
18 A
Do you mean meetings that I attended?
E U
g Q
That you are aware of.
20 A
The last time that I met with Dr. Peck on the 21 Midland pro, Ject was at the end of August in Midland.
I 22 don't know if that 's three months.
23 Q
Okay.
That 's probably more than three months, M
pretty close.
Have you had any meetings with Dr. Hendron U
i in the last three months since August -- After August?
I ALQERSON REPORTING COMPANY, INC.
104 1
A I have not met with Dr. Hendron.
2l Q
Have you met with Dr. Davisson after August ?
3 A
I think I told you earlier today I met with him last 4
Thursday and talked to him.
3 5
Q You said you talked to him.
R 6l A
But not on the Midland project.
You are right, R
7 I did say that I talked to him.
I actually met him and
[
8l talked to nim.
d I
d 9l Q.
Are there pipes and conduits beneath the diesel 10 generator building now that are not connected to the diesel z::
I j, 11 generator. building?
is Y
12 l A
I don't recall that, that are not connected to g
13j the diesel" generator building?
g m
l 14 Q
Let'me ask you, are there any under the diesel 15 generator building that are connected to the diesel generator j
16 building?
ai(
17 A
I don't really recall where the pipes and conduits
- s f
18 go to, E
19 Q
So, you don't know whether there are any that 20 are connected or any that are not connected?
21 A
I just do not remember that.
22 Q
How is the effectiveness of the surcharge program 23 i affected by the fact that they are below the generator 24 building that there are less compressible soils and more 25 ;
compressible soils?
ALDERSON REPORTING COMPANY, INC.
o
105 I
MR. FARNELL:
Would the court reporter read back the 2
last que stion.
3
( At which time the aforementioned 4
question'was read back.)~
=
5 WITNESS:
Are you talking about the clay soils below 6
I the generator diesel building?
2 d
7 BY MR. PATON:
2]
8 Q
Clay and sand.
dd 9
A Then I'll address both.
In the clay, if there
.z II was prior to preloading a difference in compressibility 11 in the clay, then the preload would tend to make the condition I
12 more uniform, it would stiffen the less compressible soil 5
5 13 so that overall, you would have more uniform, you would a
I4 tend towards more uniform, compressibility of the clay
$j 15 l
- 30113, a
d I6 In the case of the sand soils, the preload d
l I7 would stiffen the sand soils to the extent that they would 18 be able to support the static loads, but it dbes not densify E
I9 g
the loose soils sufficiently to preclude the possibility M
of liquifacture in some of the loose sand that we know 21 are located there.
22 Q
Do you plan to verify the effectiveness of your 23 surcharge program at the diesel generator building?
24 A
We are doing that right now t,y instrumentation.
25 {
Q And are you doing it partially by watching settlement ALDERSON REPORTING COMPANY. INC.
106 1
curves?
2 A
That is part of the instrumenation.
The records from 3
the settlement-points are plotted on curves.
I'm not plotting 4
them personally if that is what your question is.
g 5
Q No, no. And you are also doing that by watching a
j 6l the be' havior of the piezometers?
R 7
A Yes.
That is correct.
%l 8
Q Do you recall a settlement curve testing designated dd 9
DG-3?
E 10 A
Not right now I don't.
E 11
.Q Okay.
Are you aware, Mr. Ferris, that there t
I 12 is of the request for addition of borings, that the staff S
5 13 1 has made that has not been responded to or that the applicant a
l 14 has not responded to date the question of our June 30th 15 let ter ?
j a
j 16 MR. HARNELL:
I think the applicant has responded w(
17 to it, a
18 MR. PATON:
Okay, fine, the applicant has responded E
19 g
to it with no bo-ing information.
20 WITNESS:
You showed me the letter today, earlier.
21 BY MR. PATON:
22 Q
And what is your position with regard to that 23 information, I mean is it that the staff doesn't need l
t 24 l it or was it your position?
25 MR. FARNELL:
Your position.with regard to the request ?
l ALDERSON REPORTING COMPANY, INC.
107 1
Is that what you mean?
2 MR. PATON:
Ye s.
3 WITNESS:
I think there is no technical basis that indicates 4
that those borings are requirec.
e 5
BY MR. PATON:
I
]
6 Q
Then that 's for the staff's evaluation.-
R R
7 A
That 's who is asking for them.
Ml 8
Q Okay, now, what I'm getting at is you made a dd 9
judgment as to the staff's need for that infor=ation.
10 A
Okay, I'm telling you from my point of view, JE 11 I see no t' chnical basis that would require those borings e
a y
12' to evaluate wh't we have done.
a 5
5 13 j Q
No need-on a technical. basis is obviously, you 8
l l
14 don't. th' ink the staff needs that information; is that correct ?
15 A
I think we have provided the staff with a signed j
16 basis for revaluating the preload fill and what it has e
g 17 done.
u f18 Q
Did piezameter elevations reach anticipated values E
19 under the surcharge program?
20 l
MR. FARNELL:
Anticipated by whom?
21 MR. PATON:
All right, I'll back up and ask you a 22 previous question.
l 23l BY MR. PATON:
24 Q
Did you prior to imposing the surcharge program, 15 i did you make any estimate as to what piecometer elevations would ALDERSON REPORTING COMPANY, INC.
108 l
be after you put the surcharge program on ?
2, 1
MR. FARNELL:
By "you" are you referring to Mr. Ferris?
3 BY MR. PATON:
i 4
Q Did Bechtel do that ?
5 m
A I did not do that.
Im not aware that such an j
6!'
estimate was made and I would like to recall that there
,n 8
7 j
was one other portion of Mr. Kane's testimony that I disagree
[
8 wit h.
d And that was the 30-feet rise -- 30-plus feet rise d
9 i
in the piezometers.
I don't agree with that.
10
'I
-Q Okay.
Do you have any idea how he made that E
11 estimation?
Did he explain that?
d 12 3
A I think I know how he made it and I don't think,
S 13 5
those conditions exist underneath the building.
14 Q
It had to do with the height of the surcharge k
15 y
and the weight of the cubic feet of water.
16 A
It js my impression that he assumed that the y
17 y
soil below the diesel generator building was completely M
16 confined like in a consolidation test and then the preload
=
19 fill was placed on it.
Under those circumstances, the I
20 pore-water pressure would initially reach a height equivalent 21 to the weight of load added.
22 Q
And would that be under those circumstances approximate 1 23 I
35 feet?
24 A
I haven't calculated, but it is very roughly 25 that.
ALDERSON REPORTING COMPANY. INC.
i
109 I
Q You would start with the height of the surcharge, 2
which was --
3 A
Well, it is 20 feet times the weight of soil 4
divided by the unit weight of water, which is 62.4, so 5
I don't have a calculator here, but I think that will come 5
0 l
right around 35 7
Q 62 pounds per cubic foot?
AI 8
A 62.4.
d 9'
Q And you indicated that the conditions that Mr.
I h10 Kane might have assumed when he mentioned that rise in II
- piecometer elevation of 35 feet did not exist; is that a
N I2 correct?
S
~
13
,5 A
That is correct.
14
.Q And tell me, how actual conditions differed from is I
y 15 what you think he might have assumed?
z 16 ai A
Well, first of all there is nothing to confine e
h II the water and the soil beneath the building in the sense 18 that. I just mentioned like having a consolidation ring E
I9 g
in the laboratory.
20 Secondly, there are sand lenses and layers 2I there that act as drainage paths which would permit the II water pressures to dissipate quite rapidly.
There are 23 l some other factors as well.
You have learned enough salt i
M mechanics today.
25 Q
I appreciate your answer, but what are some of those l
I ALDERSON REPORTING COMPANY. INC.
110 I
other factors?
2 A
Well, the development of the pore-water pressure in 3
the soil due to a load is rather complicated and it's 4
merely just the load that 's supplied as though the water 5
can dissipate.
There is deformation in the soil and that j
6 can affect pore-water pressures.
It's quite a complicated R
b 7
deal.
- t S
8 A
l.
Q I may not ask you all of the factors, but are d
I 9
there other factors that you haven 't mentioned?
. 10 A
Yes, I believe there are.
There could have been i
II openings in the fill, that may have been, I'm just hypothisizing.
3 f
II It could be that there were. drainage paths even within 3
,g 13 the ' clay fill.
l 14 Q
Okay, is it not good engineering practice or I
j.
15 l would it have been good engineering practice in that case i
a[
16 i for you to have made an estimate of the elevation in the w
I h
I7 pie::ometer -- in piezometer elevation prior to imposing
=
1 b
II the surcharge?
E g
A With such a hecerogeneous fill, I don't believe 3
that such an estimate sould have been very reliable.
What II we were looking for was to see when the excess pore-pressure 22 dissipated completely and that is one way of telling that l
23 you have completec primary consolidaton.
M The other way I mentioned earlier, is to 25 i look at the settelment card.
ALDERSON REPORTING COMPANY, INC.
lil I
Q If the soil there'had not been heterogeneous 2
as it is, would you have made an estimate of the anticipated 3
pie:ometer elevation prior to imposing the surcharge?
4 A
Probably not.
If it was me.
5 Q
What if the soil was homogeneous, would you have
]
6 done it in that case?
n b
7 A
Probably not.
X 8'
I Q
If it had been homogeneous and if you had made dd
. an estimate, wouldn't you be interested in determining I
f10 how close you came to your estimate to verify the performance II of the surcharge program?
is f
II MR. FARNELL:
That's got tw-o assumptions in there.
5 5
13 Mone of which is relevent to this case and I just don't 14 l see it.
I don 't even understanu the que stion.
=
15 '
WITNESS:
I think I can answer your question.
I think a
id I0 the thing that you have to realize is what we were looking w
h I7 for was when the excess pore pressure dissipates, we were n
Ii 18 h
interested in the maximum level to which the pore pressure not I'
g reached.
E BY MR. PATON:
21 Q
Okay, try it just one more time.
Your interest II in knowing when the excess pore pressures had dissipated, 23 related to your interest in knowing when you had reached M
secondary consolidation; is that a true statement?
U A
Well, when you finish primary consolidation, o
l ALDERSON REPORTING COMPANY. INC.
n..
..,i...
112 I
then you get into secondary consolidation and I would be 2
willinz to accent that those two coints would be about 3
the same.
4 Q
All rizht, you.tust don't see any way that your 5
j Drior estimate, what would hacoen to ciecometer level you a
j 6'
don't see that that would have heloed your determinations R
d 7
at all?
A
~
j 8
A It would not have heloed our determination of J
d 9
when the crimary settlement would be comolete.
10 !
O Does the level to which core o~essures -- oore-
=
1 II water cressures: would rise have an imoact on stability a
g 12 l of the deoosit beinz loaded?
y l
5 13 f A
Yes.
a l
14 Q
But even in place of that, but that doesn't indicate 15 to you that you should estimate prior to the surcharge.
~
E I' I what your piecometer elevations are going to be?
as h
I7 A
The preload was put on in steps and those increments f18 of 1 cads were small enough thac we were not concerned about a
I9 g
failure of the fill.
20 g
37, pepp13, y,m going to hand you a document II on the letterhead of Soil and Rock Instrumentation, dated 22 October 19, 1979, a letter addressed to Dr. Sherif Afifi, 23 signed by John Dunacliff and it has attached to it three 24 pagea and ask you -- and I have marked it as Staff Exhibit 25 2 and it does indicate that a carbon copy was sent to 'dalter ALDERSON REPORTING COMPANY, INC.
i
113 1
R. Ferris and ask you have you ever seen that before?
1 i
2 A
I don't recall a clear recollection of having 3
seen it before.
It says a copy was sent to me, so I probably 4
did see it, but I don 't recall.
g 5
Q S
In your opinion does that letter reflect a problem
]
6 with survey accuracy with the Borris Anchors?
7 A
I can't tell that from the information that 's X
g 8
here. I don 't know what the p'.rpose of the letter was originally d
d 9
I kn'ow he is making a review.
I can't recollect the subject 5g 10 I
and I don't recall having discussed it with anybody.
II Q
Wells this chart on the back here, review of a
g 12 sett lement. below, b
g 13 A
Yes,. he makes some statements there, but without l
14 looking.atgadditional data,.I don't believe I would want 15 to draw any' conclusions from that.
E 16 Q
In other words, your statement is there is not w
l 17 enough information in that. letter for you to conclude whether 18 or not it concludes a problem with survey accuracy in the E
19 Barris Anchors?
20 A
Yes, I think you should talk to somebody else 21 about that.
I did not make any study as a result of that.
22 I don't recall the3etter.
23 Q
Is your statement that you have read the letter M
sufficiently so that you can't tell whether it reflects 25 '
a problem with survey accuracy or you haven't had enough time ALDERSON REPORTING COMPANY. INC.
114 I
time to read the letter?
2 MR. FARNELL:
It's been asked and answered.
3 WITNESS:
.I have read through the thing and there appears 4
to have been some questions with this survey, but it is 5
not clear to me what those questions were and whether or 3
0 not these are significant comments.
I BY MR. PATON:
3]
8 Q
In line one of the letter, it says, "I have reviewed dj your plots of initial elevation versus settlement on the 9
10 14 Borris Anchor and settlement platt for the customers
=
II sent'to.me on September 20th" (Reading) m I
Do you know whether those plots have been S
13 j
supplied to the NRC7 MR.. 'FARNELL:
I'm going to object to --
Ej 15 WITNESS:
No, I don't.
=
g 16 MR. FARNELL:
the questions on the base of the
- d h
II document, he said he hasn't read it, he doesn't recall 18 reading it, this is going to be purely speculation.
E I'
g BY MR. PATON 20 Q
Well, I did show him the document and give him 21 time to read it, the letter is addressed to Bechtel and 22 it indicated a carbon copy was sent to him.
And if he U
needed some more time to read the letter. he can certainly 24 take more time to read the letter.
"l MR. FARNELL:
No l
ALDERSON REPORTING COMPANY, INC.
115 1
WITNESS:
I think I answered -- I told you the comment 2
I have on it.
I'm not familiar with the subject and I 3
believe I would not want to discuss the items here without 4
knowing more about this matter.
5 MR. FARNELL:
h That was the rubstance of my objection.
j 6,
BT MR. PATON:
3 7
Q Do you have any other knowledge outside of this l
8 letter with respect to the accuracy of the survey, accuracy d
d 9
of the. Borris Anchors at the Midland stae?
.2 10~
Do you have any other knowledge that there II is any other inaccuracies?
E y
12
,MR. PARNELL:
I don't believe he said there were s
5 13 inaccuracies.
14 WI'k'NhSS: I don't recall that.
I do recall that prior 15 to or towards the end of the preload fill, there were additional a
j 16 instruments put in that were more accurate than the initial w
17 Borris point.
Whether that related to some problem at 18 the Borris point or not, I do not recall.
E 19 g
BY MR. PATON:
20 Q
Do you know who would know that?
21 A
Sherif Afifi.
22 Q
Do you know whether there has been a problem 23 with respect to building settlement markers, the accuracy M
of building settlement markers?
25 A
Which building, settlement markers ?
ALDERSON REPORTING COMPANY. INC.
115 I
~
Q On. the.. die se11. generator.ebuilding.1 2
A Ones that have been installed since August of 3
1979 or something prior to that time?
4 Q
I'm not sure where you got that date, but that 5
is fine.
3 0
A I really don't know.
Something may have been 7
discussed with me, but I don't recall.
I do recall that M]
8 we discussed getting more accurate instrumentation to evaluate d
i I
the second settlement portion of the--
10 Q
All right, who was that conversation with?
=
5 II A
I believe that was in the meeting that we had n
(
12 with at least one of the consultants in Midland, b
5 13 Q
Do you r@all who ?
m l
14
.A I would think it was Dr. Hendron, but I'm not 15 absolutely sure of that.
a E
IO Q
Do you know whether Dr. Afifi would know about w
h II l was he present at that conversation?
b 18 A
I do not know that he was there, but he ought E
I' g
to have been, that 's his office -- Ann Arbor.
E Q
To clarify the record, the meeting was at Ann 21 Arbor?
22 A
Ann Arbor but the meeting was a Midland meeting.
I 23 l Q
And you are not positive if Dr. Afiri was there,
(
but you think hemight have been?
25 A
I'm sure he was there for part of the meeting, i
ALDERSON REPORTING COMPANY. INC.
117 1
but I'm not sure when that specific topic was discussed 2
that he was present.
I would also think that John Dunacliff 3
was present, but I don't know that for sure either.
4
.Q, And you reference some inaccuracies and instrument 5
by that, would you refer to two things and that. is one 5
g 6
being the Borris Anchors and the other being building settlement C
N.,
7 markers --
X j
8 MR. FARNELL:
I don't think he testified that.
d 4
9 WITNESS:
I think what I said was we discussed a more 10 accurate way of measuring the settlement.
}
11 MR. PATON:
What other type.of instrumentation would you a
I II use to measure your settlement, other than Borris Anchors b
5 13 or building settlement markers?
a l
14 MR. FARNELL:
Is this just a general question?
!il g
15 BY MR. PATON:
a f
16 Q
At the diesel generator building.
w g
17 A
What we are using?
w 18 Q
On the Midland site diesel generator building?
h 19 g
MR. FARNELL:
Could have used -- did you use ?
20 MR. PATON:
Did you use.
21 WITNESS:
That I'm sure has been discussed with the NRC, I 22 don't recall the precise name of the equipment, but the 23 points were put in and I'm sure that that has been discussed 24 with the NRC in the meetings with NRC.
25 i BY MR. PATON:
l ALDERSON REPORTING COMPANY, INC.
118 I
Q Do you know of any other instrumentation other 2
than building settlement markers 'or Borris Anchors?
3 A
.I know that initially they were using scribe 4
marks that had been put on when the form work for the diesel 5
generator building was constricted and that's the basis 0
for evaluating that this budiding had settled more than 7
it should have..
X j
8 Q
What is a " scribe mark"?
d 9
A.
Just a pencil mark, just your every day mark.
10 Q
Since August, 1978, -- let me interrupt and ask, h
II you, I believe, got tnat date, August
'78, does that mean is g
12 something to you because that's when the problem was first b
13 discovered..
l 14 A.
It was early in August of 1978, I believe I may 15 have mentioned it to you earlier today, that I was informed E
I6 by Sherif Afiti that the settlement of the diesel generator w
h I7 building was approaching the predicted settlement difraring I6 at PSAR.
h II g
Q Since August, 1978, are you familiar with what type of instrumentation was used at the site at Midland 21 for example, the diesel generator building to measure the 22 settlement?
23 A
Initially, Barris Anchors were put in the ground.
I l.
24 I believe settlement plates were put on the ground as well, 25!
and then as I mentioned, sometime around about May or so of ALDERSON REPORTING COMPANY, INC.
119 1
'79, I'm not sure of the precise date, tf1 e was additional, 2
more accurate settlement instrumentation installed in the 3
building.
4 Q
In the building?
=
5 A
For measuring the settlement of the building, h
j 6
yes.
7.
R 7
Q Is.that building settlement markers or is that X
j 8
some other type ?
dd 9
A It was another type of instrumentation, I cannot 10 recall,thecprecise details but I'm sure that is in the e
!!il 11 response to questions to the NRC.
R I
I2 Q
Is the accurate measurement of settlement anything 5
5 13 you have discussed with Dr. Afiti in the last six months?
8
=
5 14 A
I don't recall to be specifically -- if we specifica113 15 have or have not discussed that.
si I6 Q
Is this a matter thct you leave more to his responsibi: 1 ul l
I7 I or was this a matter that you would expect to discuss with k
18 him considering your relationship with Dr. Afifi?
h 19 g
A The day-to-day work of the geotechnical, the 3
soils group and the geotechnical department in Ann Arbor 21 is Dr. Afif1's responsibility.
I expect him to keep me 22 informed of the work that in going on, but I do not expect 23 ;
that I'm involved in every little detail or every calculation 24 that they do.
25 '
Q
'dould you consider an inaccuracy in settlement ALDERSON REPORTING COMPANY. INC.
120 1
measurement to be. something that he woul'd discuss with you 2
or is that a detail?
3 A
I would think he might discuss that with me.
4 Q
.Do you know of any organization other than Soil 5
, and Rock Instrumentation that has =ade an evaluation of l'6 the quality of your settlement data?
7 A
I'm not aware of another organization.
2I 8
Could the court rerorter read me back the d
9 last question?
10 Q
' Ye s.
h II
( At which time the aforementioned B
Y I2 question was read back.)
b g
13 MR. PATON:
Al, we request that you provide us the l
14 plots that are referred to in the first paragraph of this 15
- letter, g
16 MR. FARNELL:
I'll talk to Bechtel and we 'll endeavor w
17 to get those settlement plots to you if they are still 8
18 in existence.
k 19 g
MR. PATON:
I would appreciate it.
BY MR. PATON:
21 Q
Are you aware that excavations have been made 22 directly adjacent to the diesel generator building wall 23 )
footings ?
I 24 A
Of my own personal observation?
25 Q
No, I mean are you aware from any source of knowledge.
ALDERSON REPORTING COMPANY, INC.
121 1
A Somebody told me that Joe Kane reported there 2
was an excavation next to the building and I believe we 3
had a discussion on that at the last meeting we had.
4 Q
,Do you know what the purpose of digging those
=
5 excavations was?
5 l
6i A
I don't know what the purpose was.
7 Q
This is the diesel generator building we are K]
8 talking about.
d 9
A.
, Ye s.
10 q '.
Do you know the length and depth of those excavations?
II A'
No, I don't.
I believe they were quite narrow g
12 excavations.
I' don 't know how deep they were.
bg 13 Q.
Were they inside the building?
14 A
I don't know, I don't recall.
All I recall was l
15 that they were close to the wall, whether they were inside g
16 or out side, I don't know.
W y
17 Q
Do you know how many there were or where they 18 were?
h 19 g
A No, I don't.
20 Q
Do you know when they were made?
21 A
No, I don't.
22 Q
Do you know if they had been backfilled?
23 :
A No, I don't.
24 Q
Do you think that because of this excavation 25 or these excavations, that that less than the final load is now ALDERSON REPORTING COMPANY, INC.
122 I
being applied to the diesel generator building wall footings ?
2 MR. FARNELL:
I don't think he can answer.
I think 3
he said he is not familiar with these excavations, therefore, 4
f don't think he can answer this question because of lack 5
g of foundation.
-a j
6 Would the court reporter read the question
^n R
7
- bacy, A
8 8
( At which time the aforementioned dd 9
question was read back.)
g 10 MR'. FARNELL:
Also, I do'n't think there is any testimony z
11
.that the excavations are currently there.
This is in addition I
I2 to my.other objection.
=
3 5
13 Q
po you know if those excavations are there?
m
=
5 14 A
' No, I do n '~t.
I have been told that Mr. Kane made h=
1 g
15 j some reference to the. excavation.
8 i
g 16 l Q
If there were excavations directly adjacent to
. W
(
f 17 l the diesel generator wall footings, could you conclude 5
l
^
{
18 whet'her that would remain at the final load being applied E
19 g
to the diesel generator building wall footings was less a
20 than the final load?
Il MR. FARNELL:
Since we don 't know the details of these 22 or he doesn't know the details of these excavations, I 23 ;
don't think he can answer that question, 24 B'r MR. PATON:
25 Q
Would you have,to know the details of the excavation l
l ALDERSON REPORTING COMPANY, INC.
123 a
1 to make that conclusion?
2 A
I could make a very general answer.
3 Q
We will accept it as a very Seneral answer if 4
you want to give us that.
e 5
MR. FARNELL:
As long as it is not speculation.
5 6 -
MR. PATON:
General answer.
7 WITNESS:
If you remove some soil from above the footing, 3
8 I'll have change in pressure on the footing to some de5 Fee,
n dd 9
but it will not be a very significant change.
Y 10 What was your question again?
3 5
11 BY MR. PATON:
d 12 Q
My question was directly adjacent to the diesel z
5 d
13 generator: building wall footings.
3 E
14,
A
' Adjacent to the wall?
du E
15 Q
oirectly adjacent to the diesel generator wall 5
foo tings.
Does that change your answer?
16 l 3e p
17 A
It would depend on what you mean by adjacent.
5 M
18 I think "emoving a little soil may change the pressure E"
19 a little bit, but I don't believe it is a significant change.
20 I would need to know a lot more about it before I could 1
21 give you' a specific answer.
i 22 Q
That's fine.
I won't pursue that.
23 MR. PATON:
A1, would you provide a plan or information i
i l
24 that shows the limits or the extent of those excavations?
25 MR. FARNELL:
Could you give me a little bit more l
ALDERSON REPORTING COMPANY, INC.
124 e
I definition as to what type -- what you want?
2 MR. PATON:
Let me do this, 1et me ask Mr. Kane -- he 3
is not being deposed, but let me ask him to just address 4
that matted.
5 MR. 'FARNELL:
Let 's go off the record.
b (At which time a brief discussion R
d 7
was held off the record.)
A]
8 MR. FARNELL:
I'll endeavor to look into the excavations d
n; 9
that Mr.. Paton has referenced and to see if I can locate
$. 10 within Bechtel any information concerning when these excavations E
11 occurred,. the extent of the excavation and whether they 2
I 12 have been backfilled.
E a
5 13 MR. PATON:
Thank you, sir.
mj 14 BY MR. PATON:
$[
15 Q
Mr. Ferris, do you agree that the diesel generator
=
g 16 building is constructed heterogeneous soils with highly w
,N I7 variable conditions of layering?
\\
5 18 MR. FARNELL:
That's a compound question.
I'll object h
19 to it.
20 BY MR. PATON:
21 Q
That seems so obvious, it is unbelievable, but 22 we will break the question in half if you want me to.
23 Do you agree that the diesel generator building 24 '
is conducted on heterogeneous soils?
25 A
Beneath the diesel generator building is a I
ALDERSON REPORTING COMPANY, INC.
12 5 1
heterogeneous fill in my opinion.
2 Q
And the reason you changed that answer is that the 3
till below the fill may not also be heterogeneous, is that 4
why you made that distinction?
5 A
Until the load, the fill is a highly preconsolidated 9]
6 soil and it may vary from point to point.
It is a very R
R 7
competent found.ation. stratum asayou very well. know.-
K l
8' Q
Do you agree that the fill below the diesel generator a
d 9
building has highly variable conditions layering?
z.
i g
10 A
I'm not sure that I would necessarily agree with 5
11 layering, but 'lensing or layering, there is -- it is quite 3
f 12 heterogeneous based on the boring data.
S 5
13 Q
Other than Midland, do you have experience with a
i 14 other structures built on heterogeneous soils?
el 15 A
Yes.
=
g 16 Q
In these other projects, did you explore the w
h 17 condition of the soil with borings?
u
{
18 A
In some of them.
E 19 Q
Did you take soil samples?
20 A
What sort of soil samples?
II Q
SPT's or undisturbed soil samples?
22 l A
This is borings to evaluate the foundation design I
l 23 '
criteria?
l 24 l Q
Yes, sir.
25 MR. FARNELL:
Is this before the buildings were built also?
l h
ALDERSON REPORTING COMPANY, INC.
126 1
MR. PATON:
Yes, sir.
2 WITNESS:
I would say generally speaking, drilling and 3
standard penetration testing or soil sampling is carried 4
'out as an initial process as you move on to a new side e
5 to determine soil conditions.
'd 6
R 7
Q Prior to initiating the Surchc.rge Program for
%l 8
the diesel generator building at Midland, why didn't you d
y 9
take.'similar borings and soil samples chat you have just E$,10 described that you took in other instances before you began E
j 11 co.nstruction ?
3 j:
12~
MR. FARNELL:
First of all, he didn't scy he did it 3g 13 in 'all instances.
mj 14 MR. PATON:
All right, in the instances in which you 2
15 did it.
E g
16 WITNESS:
Could you read that question again because w
17 I'm not sure that I understood it.
b 18 (At which time the question was read
=
19 back for the witness.)
i l
20 BY MR. PATON:
21 Q'
I'm going to strike the question.
l 22 In the other projects that you mentioned, 23 other than-Midland, di:. you develop soil profiles and assign 1
24 representative soil properties to these layers?
15 I A
Not in every case.
ALDERSON REPORTING COMPANY, INC.
127 1
Q Did you do those in some cases?
2 A
Do you mean some cases, probably most generally 3
we did it.
q
.'In light of your answer that you most generally 4
5 did it that way, why are you not complying with the borings 6
requested by the staff in this case?
E 7
A For the same reasons that I didn't do it at some X
l 8
of'the sit'es where we did it, on.
d 9
Q Tell me generally what those reasons are.
10 g
A It 's probably simplest to discuss one site, this
=
II is a miping' plant in Nevada, in alluvial fan which is very at E
12 heterogeneous deposit and you cannot get samples there
+
5 13 that 'you can relate in the way that Terzagk1 and Peck have a
b 14 done in.their book, you can't get standard penetration b
h 15 test 3.that are meaningful and you can't take undisturbed 16 l a[
soil samples that are meaningful and so i:here we did a w.
(
I7 preload fills to evaluate the soil properties that we needed a
h 18 to determine settlement of structure foundation.
h 19 Q
You said preload fills, do you mean surcharge?
E A
Surcharge fills.
I 21 MR. FARNELL:
Would the court reporter read back the 22 last few question and answers.
23 (At which time the previous two questions M
and answers were read back.)
25 l WITNESS:
I'm referring to the questions where I was l
ALDERSON REPORTING COMPANY, INC.
128 1
. asked why we are not doing borings at the diesel generator -
2 building as requested by the staff, and the response that 3
I have previously -- in light of the fact that we had done 4
drilling.and sampling elsewhere.
5 And the response that I gave was not relative h
j 6
to that particular question.
I misunderstood the question.
R 7
.The reason that we are not doing drill and M
i j
8 sampling at the diesel generator building is because we d
~
=;
9 believe we have provided the staff with ample information E
g 10 satisfactory information from the settlement and pie::ometer 11 data to evaluate the adequacies of the preload fill, in I
12 BY MR. PATON:
5 13 Q
'You discussed a moment ago a project in Utah; 5
14 is that correct?
15 A
A moment ago I discussed a project in Nevada.
d 16 Q
Was there a settlement problem at that project?
ad 17 A
No, there was not.
13 Q
Is your reliance information from piezameters E
19 g
affected by the fact that the fill is heterogeneous?
20 MR. FARNELL:
Would the court reporter read back the 21 last que stion.
22
( At which time the aforementioned 23l question was read back.)
24 MR. PATCN:
Strike that question and I'll try it again.
25 BY MR. PATON:
ALDERSON REPORTING COMPANY, INC.
128
.1 Q
Is the accuracy of information provided by piezometer 2
readings affected by the fact that the fill is hetero 5 neous?
3 A
The accuracy of the piezometer is not affected 4
by.that.
5 Q
Is the sattlement information affected in any h
j 6
way by the fact that the fill is heterogeneous?
7 A
What do you mean by the settlement information?
M]
8 Do you mean the settlement at a specific point or the ovkrall d
2 9
picture?
10 Q
No, the information you get from a settlement
- =
j 11 marker is the accuracy of that information affected by is y
12 the fact that the fill is heterogeneous.
5
/
5 13 A*
I don't -believe the accuracy of the settlement
=
l 14 marker is affected by the heterogenity of the fill.
D 15 Q-In the project where you took undisturbed samples y
16 can you tell =e how you determined where to take undisturbed
~
e.
g 17 samples?
18 A
Which project are you talking about now?
E 19 Q.
Well, I think you indicated there were projects g
20 in which you just spoke awhile ago where you did take undisturbed 21 samples.
22 A
We took them in the strata that we wanted to 23 know the soil properties as best we could.
24
( At which time a brief break i
25l was taken.)
ALDERSON REPGRTING COMPANY. INC.
129 l
1 WITNESS:
I think that.there has been a confusion 2
in the last few questions.
I believe my understanding 3
was what I normally do in the way of exploring sites and 4
this is where there is nothing on the site before we go 5-on, there and we are getting foundation and material investigations j
j 6
7 believe what you are asking me about is l
7 borings made at,the Midland site after a structure has Nl 8
been constructed.
And that is not something that we normally d
ci 9
do'.
10 BY MR. PATON:
5 11 Q
Based on your experience, do you believe running 3,
g 12 laboratory consolidation testing to be a reasonable approach b
g 13 for estimating the amount of settlement and the rate of l
14 consolidation?
l j
g 15 l MR. FARNELL:
Would the court reporter read back the a
i g[
16 last question.
i
(
W h
17' (At which time the aforementioned 18 question was read back.)
E 19 MR. FARNELL:
That 's a compound question.
20 BY MR. PATON:
j 21 Q
I'll break it down if you insist.
Based on your 22 experience, do you believe running laboratory consolidation s.
23 J
to be a reasonable approach for estimating the amount of 24 se ttleme nt ?
25 A
Yes.
ALDERSON REPORTING COMPANY, INC.
.~..-.
130 I
Q, Based on your experience do you believe running 2
laboratory consolidation to be a reasonable consolidation 3
for running consolidation?
4
.A.
I would have to say that it is not a very reasonable
=
5 one, not necessarily a very reliable one.
5 6
sefore we get off thae, I would like to 7
point out that.my response to that was a general response Nl 8
and could be influenced by a lot of other factors, dd 9
Q Was there ever any consideration given to making
,z h
10
. settlement prediction test diesel generator building prior 11 to imposing the surcharge program?
m j
12 A
Its not aware of any.
f
~
5 13
'Q Do you recall any discussion of that in your
=
l 14 reading of Dr.
Afifi's deposition?
15 A
I do not specifically recall it in Sherif Afifi's y
16 deposition.-
I do recall that there were discussions at w
g 17 E
the time prior to the time of preloading.
There were some rough
}
18 estimates of what the settlement might be.
E 19 Q
Who made those?
20 i
A Sut there were no calculations.
l 21 l
Q Okay.
Who made those rough estimates?
22 A
Dr. Peck in a discussion that we had, I believe, 23 ;
in Champaign, Urbana, he made reference to a pessimistic i,
24 upper limit of 6 to 18 inches as the settlement resulting 25 from the preloading film.
ALDERSON REPORTING COMPANY. INC.
r~
13 1 I
Q Do you have any idea on what he based that rough 2
estimate?
3 A
No, I believe it was just that, a very rough 4
. pessimistic rough estimate.
I do not believe he did any 5
calculations.
I do not believe he had any data to do any
]
6 calculations at that time.
3d7 Q
He must have known something about the site.
3 8
A No, I believe he was 1 coking at a rough pessimistic dd 9
I upper limit of what the settlement might be.
One of the
.z 10 factors t' hat he was concerned about is that our instrumentation II should be able to take care of whatever movements occurred.
. l 12 Q
I'm sorry, sir, I don't understand that -- our s
5 13,
instrumentation shonid be able to take care of whatever a
14 occurred.
zj 15 A
Well, he wanted to make sure that when Bechtel a
d I6 arranged for instrumentation that they would be able to us f
I7 take care, operate, under the most pessimistic estimates 18 of settlement that might occur.
b I9 g
Q In your recent statement about installation of 20 instruments, did you mean that you wanted to make sure 21 you had instruments that would measure any possible range
'l 22 of settlement so that the settlement wouldn't exceed what 23 l your measurements would measure?
)
24 A
Yes, we didn't want to have an instrument that 25!
certainly the point would -- it would go off the scale or ALDERSON REPORTING COMPANY, INC.
i 132 I
something like that.
Q Sure.
And are you connecting Dr. Peck's 6 to 18 3
inches pessimistic estimate with his -- in other words, 4
1 that was in connection with him saying he wants to make 5
sure we have instruments that wotild cover at least this 3
0 l
much settlement.
Is there a connection between those two?
7 A
I believe it was made in the context of giving 8
Bechte-1 some idea of what the upper limit of settlement i
d d
9 might be, but it was not based on calculations because 10 I do not believe that he had the' data to do calculations, 5
II nor do I believe he did any calculations, m
( ' 12 Q
Okay.
Bj 13
.A It was a spontaneous comment in a meeting.
l 14 Q
U Do you know whether Dr. Afiti gave any consideration 15 to a prediction of settlement prior to the surcharge program E
I6 being imposed?
w h
I7 '
A I'm not aware of any.
l' i
Q Let me read you from page 57 of Dr. Arif1's deposition, E'
I g
and he has not read this and corrected it, so let me just E
read this to you and see if it refreshes your recollection 21 about anything.
i 22 I was asking him about whether he considered 23 '
making a settlement prediction part of the surcharge program
(
M and I'll read this, but you can certainly look at it if 25 you want to.
ALDERSON REPORTING COMPANY. INC.
)
133 1
"My original thought may be, perhaps, if 2
there be no confusion, that it would be one way to go.
3 To predict the settlement on the basis cf lab tests.
The 4
very initial thought because the material appeared to be 5
' heterogeneous enough and the surcharge program became an
]
6 opportunity to provide answers, be provided in lab tests.
R R,
7 That was not the favored way to go."
(reading)
Al 8
A I have trouble understanding that.
Od 9
Q Obviously, there is typing or some type of errors 10 in there, but my question to you is does that refresh your
~
11 recollection at all about a
any consideration given to laboratory I
12 testing or anything7 5
g 13 A
It doesn't change anything I have said.
l 14 Q
You have no recollection?
I g
15 A
I don't recall discussing this with Dr. Afifi.
a
/
16 Q
How many projects have you been involved in where w
17 there has been surcharging?
18 A
I have been on several.
Do you want me to tell h
19 g
you?
20 A
Well, first of all, tell me approximately how 21 many projects have you been involved.
22 A
Right this moment I can think of five, but I'm l
23 not saying that I haven't been en more than that.
i M
Q Okay.
That's fine, sir.
25,
Did any of those involve surcharging after the ALDERSON REPORTING COMPANY. INC.
O
134 1
I structure had been partially or completely built?
2 l
A Yes, two of them.
3 Q
Okay.
Would you tell us about those two?
4 A
Okay.
One is a very conventional problem, quite 5
commonly used in engineering,in that-it uas oil tanks for 1
{
6 I
a fossil fuel power plant in Louisiana, the tanks were I
,k7 built and then. water load was applied in station to take Xl 8
out the settlement in the foundation.
So in that way, d
9 9
the settlement of the tank was taken out prior to it carrying 10 its oil load and also the bearing capacity was enhanced h
II l by the consolidation that took place.
m l
'g 12 Q
Could I ask you a little bit about that one?
5 ' I3 g
A Yes, sir.
14 Q
Would that be the normal practice for foundation E
i j
15 i for. oil tanks?
a f
16 l
a A
I can't say that it is normal, it is one of the w
l 17 things that is done with oil tanks because frequently oil 5
18 tanks run poor -- are frequently put on poor foundation.
e 19 g
Q You did it because it was some problem with the 20 soil?
2I A
The soil was soft.
22 l Q
Would it be good engineering practice to just 23 !
So ahead and fill those tanks'with oil?
M A
No, we could not have done that, we would have i
25 I had a problem with the foundation.
(
l l
ALDERSON REPORTING COMPANY. INC.
o
135 1
Q Okay.
What would be the most significant problem 2
you would have ?
3 A
Edaring capacity failure in that particular inscance, 4
there was a potential for bearing capacity failure.
h.,5 Q
Now, in t hat instance, did you make a settlement i
j 6
prediction before applying the water load?
i
-(
7 A
I believe in that particular instance there was 3]
8 settlement as to it, but the primary control in that particular d
d 9
instance was in the pie::cmeters, because we did not i
want 10 to overload the foundation.
We put in a partial water l
11 load and then watched the piecometer dissipate and at a a
4 l
12 specific potnt then added some more water until we reached 5
g 13 the maximum load in the tank.
l 14 Q
Was the amount of settlement in that case critical?
15 A
No, it was not critical.
j 16,
Q Now, I may have just asked you this, and you e
g 17 may have just addressed it, but why did you make a settlement 18 1
prediction before imposing the water --
19 A
Well, I didn't make it but somebody made it.
20 Q
Why was it done ?
21 A
It was not necessary to be done, it was just 22 something somebody did.
23 i Q
It was done but in your. judgment it was not necessary l
\\
24l to be done.
So, then that case does not distinguish itself 25 as far as you are concerned for the Midland case, in your ALDERSON REPORTING COMPANY. INC.
136 1
opinion in neither case was it.necessary?
2 A
Well, you asked me where I used surcharging and I'm 3
respending to that requesc.
4 Q
That is correct, out what I'm saying is you don't 5
think it was necessary to make a settlement prediction
]
6 in that case just like you don't consider it necessary R
R, 7
to make a settlement predicticn in the Midland case.
8' A
I did not say that.
In Midland, we did measure dn 9
settlement and we did use --
10 Q
I'm talking about settlement predictions.
l 11
'A I didn't try to draw a parallel between the two.
i m
I,12
.Q But it is true that in neither case did you see E
g 13 the need for making a settlement prediction?*
[ 14 A
That is correct.
15 '
Q And in the case of oil tanks you didn't need i
16 to make a settlement prediction because you imposed the wl 17 load in stagen and you watched your piezometers and you 18 E
were able to control the situation that way.
19 A
That's correct.
Q Would you tell us about the other instance in 21 which --
22 A
Instance or instances?
23 ;
Q Well, I think you said there wore two instances 24 in which there was surcharging after the structure was 25l partially or fully completed; is that correct, and one of ALDERSON REPORTING COMPANY. INC.
83 7
)
I time was the --
2 A
I do not recall saying that, but I do know another 3
in which I can discuss with you.
That is in Utah.
I centioned 4
it briefly this morning.
It is a mining project, in-an 5
Anarconda. Coppar.. Company at a place called Carrfork.
0 In that particular instance, the plant site 7
was in very narrow valley that was filled with material Xl 8
that had been washed down into the valley during flood d
d 9
stages from the hargrain.
10 l We intended to do a conventional expiration l
II at that. site and found because of the type of material a
I I2 there that we could not get meaningful data to evaluate 5
g 13 settlement for structure foundations.
l 14 We had in any case at that site intended 15 to obtain sheer
- way', velocity measurement because thers a
E 10 were some crushers in the site, vibratory loads in the w
h 17 plant.
We took the sheer way velocity measurements II and then reduced the sheer moduluous values by a factor e'
I g
to come up with a moduluous on which we could evaluate 20 settlement of foundation.
21 What we did not know at the time we did 22 that, the location we selected for sheer way velocity happened 23 to be the best part of the site and one structure we were 24 aware that there would be quite significant settlement 25l in the structures.
And we had recommended at one of the major I,
,l ALDERSON REPORTING COMPANY, INC.
138 1
structures on the site that they place the fill, the required 2
fill area fill.
And then put in the foundation of, the 3
structure.
4 1
For some reason that recommendation was 5
not followed and the structyre foundations replaced and j
6 then the fill was added and, of course, the structure started 7
to settle quite,a lot more than what we had predicted.
8 We had not in any case predicted the correct dd 9
value of settlement on the basis of the data because the 10 soils, the location of that structure were not as good h
11 as the location where we had measured the sheer way velocity.
B
[ 12 I was called to the site and recommended that we fill the E
g 13 building with sand and to some extent beyond this.
l.14 And I also contacted Dr. Hendron e.nd asked 15 him it' he would come to look at the site.
He came to look j
16 at the site and he increased the amount of preload that i
w l
17 I put on the structures.
18 He, in addition -- we looked at each of k
19 g
the structures on the site and because we did not really 20 know the quality of the material below them, we preloaded 21 all of the significant structures like the tailing thickeners 22 and other buildings on the site.
And he in conjunction 23 r with us recommended a staged loading in the storage area.
24 In that particular case, we used only settlement 25 measurements to evaluate when the preloading had been on long ALDERSON REPORTING COMPANY. INC.
139 1
1 enough because --
2 Q
You mean as opposed to piecometers?
3 A
We could not put piecometers on there, they would not 4
have been meaningful, the water table was quite considerably 5
below the foundation level, and drilling holes in that j
6 ground was just extremely difficult.
The pie:ometers would 7
not have been meaningful in the material either.
It was 8
quite relatively pervied, d
i 9
So the entire valuation of the length of 10 time that preload was kept on was based on the settlement 11 '
measurement.
It 's my recollection that af ter about --
g a
I 12 the text books tell you that cand settles immediately, 13 of course, it doesn't -- granular material settles easily, i
l15 14 they don't.
They take some time to settle.
And we find that usually the major part of the settlement had occurred i
g 16 i
within one month and we kept the load down for sometime i
w g
17 after that until we were satisfied that we were in a secondary 18 consolidation condition.
E 19 !
g The preload was removed and strangoly enough 20 the building looks better than it did at the start.
The 21 cracks had closed, and as far as I know the plant is operating i
22 quite satisfactory.
23 The maximum settlement at the concentrated i
24 '
building was'16 inches.
25 '
Q At what building?
l ALDERSON REPORTING COMPANY. INC.
140 1
A At the concentrator building.
The main building 2
that I am talking about, the concentrator.
3 Q
Does that co'mplete your answer?
4
.A
'That is in summary.
5 Q
The 16 inches of settlement at the concentrator
]
6 building, does that include the settlement that took place k
'7 prior to the surcharge ?
8 A
It includes all of the settlemen': that took place d
I. 10 9
including the settlement under the preload fill.
Q Roughly how long ago were you involved at this Il project?
I2 A
I would say it is about three years ago, it is i
18 quite recent.
14 4
All right.
15 A
Yes, about three years, ai 18 Q
And can you tell us, do you remember of the 16 l
17 inches how much took place before the preload and how much 18 after?
I 19 g
A Ch, maybe a tnird of it took place before, I 20 don't remember.
That is the maximum settlement, not all 21 points in the building settled that much.
22 Q
Okay.
Was there a differential. settlement in this 23 instance or was it all settling -- I guess you just mentioned M
there was a differential settling.
I 25 A
There was differential settling.
It was a different I
ALDERSON REPCRTING COMPANY. INC.
A41 t
I foundation than the diesel generator building.
2 Q
You indicated that the building looked better.
3 A
You could not see cracks that you could see prior 4
to that time.
5 Q
Would you expect that from a surcharge program?
l 4
A I don't know whether you would or would not, 7
it just happened to happen.
8 Q
But if there are certain stresses on a structure d
i 9
causing cracks --
10 A
T.,et me answer that question again.
I would say II if the surcharge program resulted in reduced differential 12 settlements then you would expect that the cracks would 13 clo,se up.
14 Q
Right, but if you have differential settlement 15 before you start surcharge, and let's say the north end ai l'
of the building is settling =sre rapidly than the south w
i I7 end of the building, if you put a surcharge over
- hat whole I8 building at a uniform rate, isn't -- why would that tend I
g to reduce the differential settlement, isn't that going 20 to either keep the differential settlement the same or r
l 21 aggrevate it?
22 A
Well, the overall combination of the prdload fill 23 and the area fill may result in a more uniform settlement M
pattern in the building.
25 Q
Okay.
I'm sorry now, by preload fill, I think I know ALDERSOM REPORTING COMPANY. INC.
182 i
I what you mean -~
i 2
A What I told you was that they had put in the building 3
and then they put in the area fill which was required.
i 4
When I went to the site I asked them to add preload fill 5
in the building and adjacent to it and Dr. Hendron increased E
8 the amount of that preload for me, as to my' recollection.
I Are you worried about the word preload?
8 Q
No.
Here is my concern, was the preload placed 0
i 8
I uniformly over the building?
10 '
A We try to put it uniformly to minimi:e differential i
Il settlement.
i 12 I
Q, Okay, now that's the key, what did you do to 12 minimi:e ditforential settlement 9 14 A
We tried to put in the fill in relatively uniform 15 layers, you don't put all of it in at one end and hothing ai I8 I
at the other.
m 17 Q
Well, let me ask you this, do you have one end I8 of the building settling more than the other if your I
g preloading program puts more weight on the part of the i
20 building that is settling less, wouldn't that tend to reduce 21 differential settlement ?
22 A
Would you say that again, please ?
23; Q
Yes, if you put more preload weight on the portitn M
of the building that so far has settled less, wouldn't 28 that tend to reduce your differential snetlement?
ALDERSON REPORTING COMPANY. INC.
p 143 1
A I believe that would, but I don't recall that 2
we were that sophisticated in that particular instance.
3 Q
That's my question then, if you didn't make any 4
efforts, did you make any effort in your preload to reduce i
5 differential settlement?
l 6
A We do to the extent of putting in the fill in 1
7 a uniform manner.
3 I
J 8
Q You indicated that the actual total settlement cJ l11 9
was approximately 16 inches --
i 10
.A To my recollection -- it is my recollection that the maximum' settlement in that specific building was about
}
12 16 inches.,.
,13 Q
And do you recall what your prediction settlement l15 I4 was?
A
'I would say it was probably around three inches, 18 al something like that.
w 1
17 Q
Is there a report that you are aware of that 18 describes the surcharging program that was conducted at i
l I'
g Carrfork?
20 A
Do you mean a summary report that we prepared 21 later?
22 q
y,,,
23 A
I don't recall that we did that.
There are memoranda t
M concerning the thing.
I believe those would all be the i
28 property of Anaconda Copper company.
ALDERSON REPORTING COMPANY. INC.
lu o
i I
Q You don't think that Bechtel would have any of 2
those reports?
3 A
I do not know that.
At one time we would nave, 4
but I don't know what happened to the files at the end g8 of the job.
I 8
Q Do you know if anybody in Bechtel would have 7
them, who that person would be?
8 A
I can't think of it right now.
d l
Q Would they be in the San Fransisco Office?
10 A
They would be in the San Fransicco Office in I I' the Mining and Metal Division.
12 g
/,.Do you know knether that summary report would
{
la show loading and, settlement history?
I4
. I. do not believe I said there was a su'mmary report.
1 A
15 Q
Are you awa.'s of any report?
E 10 A
I do not recall that we did a final report on i
w i
II that, on the proloading.
What I did say was there might II be me:nos concerning it.
l I'
g Q
And would those memos be in your division files i
20 in San Fransisco?
21 A
I believe they would be in mining and metals 22 division files.
23 MR. PATON:
A1, we are requesting that it such reports --
1 M
let 's go off the record.
l 28
( At which time a discussion was held off the record.)
ALDERSON REPORTING COMPANY. INC.
i 95 1
ML PATON:
Mr. Farnell, I'm requesting that you make
'2 an effort or you ask Bechtel to provide information concerning 8
j the experience just described by Mr. Ferris at Carefork,
'4 including if possible loading and= settlement history, cracking S
history, of the surcharge program that he has just described.
l l
6 MR. FARNELL:
Cracking history?
7 MR. PATON. Didn't he mention cracks?
8 WITNE33:
I did mention cracks.
I don't kr.ow what d
9 information is available.
i 10 MR. PATON:
Those araiths. subjects, 1P'any or that 11 is available.
I12 MR. FARNELL:
We will make an attempt to locate such 13 documents.
Note for the record it is Christmas time and 14 y'our stockings seem to be getting stuffed with many document 15 requests but we will play Santa Clause and do our best E
l' for you.
1 17 MR. PATON:
I appreciate that, Christmas or any time.
18 BY MR. PATON:
l I'
I g
Q Can you tell me the thickness of the compressible 20 layer at Carrfork?
21 l
A I can't answer that question.
I can tell you 22 that there was about 100 to 120 feet of soil above rock, 23 ;
but I don't know the relative compressibility.
1 84 Q
Do you recall th* baight of.the surcharge load?
18 A
I don't precisely recall that.
I really don't l
806 I
1 recall the height.
2 Q
Did you follow any general rule, such as the surcharge 3
being 50 percent more than the final load?
b 4
A We -- my recollection is that we had it 50 percent 1
j y
5 over the dead plus normal alive load.
That is what my l
R 1
]
6 recollection is and that is merely a recollection.
l I
1 Q
Do you have any recollection in that regard with 8
respect to Midland as to what degree the surcharge exceeded d
I the final expected load?
i i
10 A
Well, I believe at the inst public meeting there i
51 I
was some information handed out showing what the preload 11 stress das related to the building stress and I don't remember I
13 the exact numbers, but that piece of information was given 14 to NRC.,
r i
I II Q
Okay, fine.
i i
ai l'
Q Mr. Ferris, let me review, at carrfork I think 17 you indicated you did not take piesometer readings, i
I8 A
No, there would have been no point in taking I
l If g
them.
[
30 Q
That is correct, you did not?
I 21 A
Ye s.
i 22 Q
Did you address piesometer readings with respect
[
23 to the first example you gave?,
24 A
Yes, I did.
That was the primary basis that a
r 28I we used for controlling the load.
i ALDERSON REPORTING COMPANY. INC.
9?
1 Q
Mr. Ferris, I want to ask you some questions 2
about a piezometer elevation plot designated as pie:ometer 3
numeer 40 which I'll show you.
It is attached to a doourent 4
entitled consumers exhibit number 12 of Mr. Kane's deposition.
g5 A
I didn't see these.
]
4 Q
There are some pencil marks on that sheet, Whion l
7 are my own writing, and I ask you to ignore thosej please.
8 A
Okay.
I can't read everything on this or at O
9 III least I'm not 'sure that I u'nderstand it.
10 Q
1 think if you have any difficulty, I think we l
have a better copy of that.
That one for example doesn't I
i 12 show, t;he elevation.
t 13 A
This is fine, I think I can understand it.
k Let me ask you some questions and then if you j
I4 13 want to review it some more.
y 16 A-If I have a problem I'll ist you know.
n-17 Q
During the months of May, June and July,1977, 18 will you tell me whether that chart shows that the piesometer 19 g
elevation snows a drop or an increase?
20 MR. FARilELL I think the document will speak for l
i 21 itself.
l 22 WIT!!E33:
It appears that
- I presume I don't see la the scale on this drawing here, but I presume that upwards M
l means increasing pore pressure.
28 Q
We have a better ploture of this which shows AL.OERSON REPORTING COMPANY. INC.
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ 1 148 I
this line to be 60 and that to be 65 I can show it to l
2 you if you want it.
3 A
No, this is just fine.
4 Q
Okay.
5 A
It looks to me like there is a slight increase I
e on the piesometer pres.ture.
I Q
Did you expoot that7 8
A Well, I cannot tell that based solely on this 4
j document.,
10 MR. FADNELL:
What time are you talking about?
II l
MR. PATON:
He is looking a,e May, June and July and l
12 he said it increased and I asked, "Did you expect it to I3 increase over that three month period."
i 14 WITNESS: 'But I think I would need to know something II other than wnat you have just given me to be aDie to respond.
I4 BY MR. PATON:
al i
17 Q
Well, let me ask you this, you know that the 18 surcharge reached its full height on April 6th,19791 is
(
l I'
g that correct?
20 A
Yes, right.
It was early and I didn't remember 21 it was April 6th.
22 Q
And it was starting to be taken off on August 23 15, 1979 It was fully off on August 30, 19797 24 A
Ye s.
i 28 4
So that during the months of May, June and July,1979, ALJDERSON REPORTING COMPANY, INC.
149 I
the full load was imposed?
2 A
Yes.
3 Q
And what other information would you need to tell me 4
whether that slight increase in piezometer elevation in 5
g that three I:enth' period is what you expected to have, e]
6 A
The two things that come first to mind are I R
E 7
would like to see a plot of lake level during this period 3
l 8
o f t ime.
And I would like to see information on the variation d
9 of the' area ground water table in the vicinity of this,
,z h
10 outside of the limits.
[
II Q
All'right,,are you indicating that that ground 3
I 12 water level could have influenced the piezameter reading?
g..
=1 13 A.
Of course, it will increase the piezometer reading..
a l
14 I. don't k'ow if that is the cause of. the rise because it n
h
~
0 15 could be that the lake was' rising in that period.
It could j
16 be that the area ground wat'er is rising.
4 mi c
h 17 s
Q But didn't Yodtindicate to me before test your z
h II knowledge 'of the piezo$ tete elevation was part of what
~
h 19 led you to conclude that you are now in secondary Gnsolidation?
\\'
N N
20 A
Yes, that is correct.
- U
\\
2I g
Q Well, 4 hen if you are sure you aredi1 ' secondary
~
22
..g consolidation, then you must know what is going ori with
^
23 the groarici, water s'
- I M
A What I'm saying is you need t6 change this Eo 25 !
take out.those 4ther affects, effeci of the lake and the ground ['.
S i
.~
/
ALDERSON REPORTING COMPANY, INC.
_; ~
7
~
150 I
water and then look at that to see if there has been any.
2 Q
Did you do that?
.3 A
-I personally did not.
4 Q
Did Bechtel do it?
5 g
A I believe someth,ing like that has been done.
e j
6 Q
All right.
Who did that ?
9 8
7 A
It would have been done under Sherif Afifi's 3
l 8
supervision.
d q
9 Q
Do you have knowledge, does he know that ground E
10 water table level during thaft period of time?
?
II A
.I would assume he does.
We had a lot o'f piecometers a
I i2 in thecarea..
3 5
13 a
,Q
)W. Ferris, I want to show you Figure 1 attached a
s 14 to Consumers Exhibit No. 8 of the Kane deposition.
And El 15 I s'uggest to you that there is a plot here showing pond a
j 16 elevation versus time.
This second plot right here, and e(
17 I think there is something that would show you the elevation 18 of the pond during May, June and July.
0 19 I presume this must be August, this is about 20 August here.
There are some other platts that show it, i
2I let me point that out to you.
I'm suggesting to you that 22 this last chart ~ shows April and here is August right there 23 (pointing) and the days I think are the same.
Right there i
24 on that bottom chart.
25 1
A And this piezometer is where the two pieces I wanted ALDERSON REPORTING COMPANY. INC.
151 1
to know were piesometers not affected~by the surcharge, 2
but in the vicinity of this structure so that I have some 3
idea where the ground water table is and I also wanted 4
to have a. plot of the lake water because that lake elevation.
5 g
because that could have something to do with it.
a 3
0 Q
What you are telling me in short is that you
^n 7
cannot simply --
A]
8 A
I cannot look at the plot and tell you right dd 9
- orr, Y
10 Q
'All right, let me ask you this, if the piezomster E
11 number 40 was not influenced in any way-by the ground water 3
I 12 table, what !would.you have expected that curve to do in 5
y 13 May, June and July?
m.
l 14
' MR. FARNELL:
I think he also said it migh't be influenced b
l 1.5 by the lake.
a f
16 MR. PATON:
Well, I assume the lake is affecting the w
h I7 ground water, right, assuming it isn 't affected by the z$. 18 lake or the ground water table, what would you expect that E
19 curve to do in May, June and July?
20 WITNESS:
If it is not affected by the lake or the 21 ground water, I would have expected it to be fairly level.
22 BY MR. PATON:
23 q
.Well, as the surcharge squeezed out the excess 24 pore pressures, wouldn't that line have declined?
25 A'
Yes, if it was still during that -- I did not i
ALDERSON REPORTING COMPANY, INC.
152 o
I understand that question.
2 Q
You are saying that it may have already squeezed out 3
all of the excess pore pressures, that is a possibility.
4 We are talking about a supposition, not about a real thing.
=
5 h
You are saying that you can't really make accurate --
j 6
A I cannot look at that one curve without other R
d 7
~
data and tell you exactly what has happened.
X j
8 Q
And you did not do this?
dd 9
A I did not make that evaluation.
i h
- 10 Q
But to your knowledge, you think Dr. Afifi did?
~
3 II A
- I believe.it would have been done in the soils I
12 group in Ann Arbor.
5 5
13 Did you. ever hear Dr. Afifi say whether the piezometer g.
=
l 14 behavior was -- what' he had expected?
$i 15 A.
'The only comments on piezometers that I can recall j
16 is that people felt that the pore pressure dissipated quite w
{
17 quickly and, of course, we had no idea whether that was
$i 18 Soing to be the case beforehand or not.
Do you know whether E
19 Dr. Afifi is also satisfied that you are now in secondary 20 consolidation?
21 A
I believe he is.
22 Q
Is there anyone in Bechtel who has expressed 23 ;
to your knowledge any doubt about whether you are in secondary 24 consolidation?
25 A
I don't recall hearing anybody express that doubt.
ALDERSON REPORTING COMPANY. INC.
o 153-154 I
Q Eave any of your consultants expressed any question 2
about whether you are'tri.secoadary consolidation?
3 A
I have not heard them say that.
4 Q
Okay.
Who under.Dr. Afiri do you know would 5
l g
do the actual work involved in taking out of that curve a
j 6
there the i= pact of the lake and the ground water table
^a d
7 so '. t hat you would --
M]
8 A
I do not know that, on a day-to-day basis, that dd 9
?.
is entirely within Dr. Afif1's area of work and he could e
10 g
assign any of his people to do something like this.
=
{
ll Q
Have you ever heard Dr. Peck discuss the piezometer R
y 12 behavior at the Midland site ?
5 5
13 A
Yes, I have.
m l
14 Q
What did you ever hear him say about it?
D 15 A
I believe he is of the opinion that we have reached j
16 secondary consolidation.
e g
17 Q
Based on what I mean?
f18 A
Based on the data that he has been given.
U 19 Q
Those are his conclusions?
~
20 A
- Yes.
2I Q
Eave you ever heard anything about his reasons 22 or basis for his reasons?
23 A
I'm sure I must have, but I can't recall specific 24 st atement s.
23 Q
Did you ever hear him say that the ciezameter I
~l l
ALDERSON REPORTING COMPANY, INC.
i 155 I
behaved exactly as expected?
2 A
I think he was a little surprised that the piezometer 3
pressure didn't go a little higher than it did, but I don 't
~
4 know of anything else that was surpising and I guess he
'did not know how quickly the water pressure would dissipate S
5 E
6 either before we actually put the load on.
~
<T E
7 Q
Let me ask'you about there is a line on piezometer s]
8 number 40 plot th' t says "begin surcharge removal."
a od 9
A Ye s.
$H 10 g
Q.
And immediately after that line there is a fairly Il sharp drop in piezameter elevation.
3 Y ' 12
.A-Ye s.
~a 5
13 Q
What causes that to drop at that point ?
m i
I4jl m
E A
'Well,- cne possibility would be just. removal of b
_l 15 the surcharEe-7 16 3
q, That relieves the pore water pressure; is that w
N 17 correct?
k 18 A
Yes, in this particular instance it appears to E
19 have gone down and come back up again.
20 Q
Okay, now coming back up again, is that called 21 rebound?
22 A
Well, it could be rebound.
23l Q
What do you call it?
I 1
i 24 A
I don't know that that's what it is callec.
25 Q
I don't understand what causes that.
I can understand ALDERSON REPORTING COMPANY, INC.
156 I
why you take the surcharge off, there is a relief pore water 2
pressure is relieved.
3 A
And drops.
4 q
And drops the elevation drops.
But do you understand 5
g why it goes back up again or rebounds?
n 6
i A
Well, I think 'it is going back to the controlling n'
'7 water level there.
It may have gone below that when the k8 load was taken out.
d d
9 E.
Q What force would cause it to drop way below that h
10 natural staAe and bounce back up again?
5 II A
.Well, if you had a negative pore pressure that 3
y 12 would'eaus'e it.
h 13 Q ':
Tell' me what you mean by " negative pore pressuEes."
l 14
, ell-,' pore pressures that are less than the base g
y M
9 15 l that,you are measuring the pore pressures from.
m d
16
-Q To me the answer is you have a negative pore e
h 17 pressure --
5 g
18 A
Let me give you an example, and if you take a A
g" 19 dense sand and squeeze it, you will see that what was --
20 maybe if it is saturated, what was wet on the outside becomes 21 dry because when you sheer the sand it increases in volume 22 and the pore water is sucked back into the pores.
You 23 i
get negative pore pressure.
i 24 Q
All righ.
Now, the curve shown on this piezometer 25 number 40 plot after the removal of the surcharge shows lower l
ALDERSON REPORTING COMPANY, INC.
157 1
pierometer elevations, do you agree with that ?
Lower than 2
it showed in May, June and --
3 MR. FARNELL:
What point 4
WITNESS:
The thing I would like to know is where g
5 was the lake level during this period was there any pumping
?
6 going on in this period.
What other factors could have R
7 affected the ground beyond.
I cannot just iby looking at a
j 8
one curve tell you the answer to your question.
i dd 9
SY MR. PATON:
i h
10 Q.~
Absence to the knowledge of t'he ground or the
[
g 11 water table level, you cannot draw any conclusions from 3
y 12 the fa.ct. that the curve after surcharge removal is distinctly E.
d' 13 at S
a lower elevation than prior to the removal of the circulation l
14 You can 't. ' draw any conclusions ?
~
2 15 A
Well, I would assume that part of that is because g
16 of the reduction of the water base water. level for some-w g
17 reason, but I' don 't know what.
18 Q
By base water, do you mean the ground water table?
0 19 A
R Yes, say the ground water level lowered beyond 20 what happened.
That 's what I said with that one piece 21 of information I could not 22 Q
In other projects, on which you have experienced 2$j with preloading, did the piezometer elevation decline after 24 reaching full surcharge height ?
25l MR. FARNELL:
I don't understand.
Would the court reporter l
ALDERSON REPORTING COMPANY, INC.
158 I
read back that question.
2 (At which time the aforementioned 3
question was read back.)
4
.MR. FARNELL:
My objection is that are you assuming that
=
5 h
the surcharge remained on or did you take off the surcharge,
]
6 that's it.
The question is indefinite.
g i
d 7
BY MR. PATON:
A j
8 Q
After reaching the full surcharge height and d:!
9 the resuming is that it stayed on?
!g 10 g
I think I can' answer your question.
In the case II of the, oil tanks that I mentioned, when we applied an increment I
12 of wate in the tank, the piezometers rose and then we 5
5 13 maintainedithat water level in the tank and the piezametric
=
l 14 level, level in the - piezometer, declined and at some point E
i
[
15 j we Added another increment and the piezameter went up again.
x E
I6~
Q And that is merely normal expected behavior; as h
I7 is that right?
z 5
18 A
Yes.
E 19 Q
And it declined because you were squeezing out 20 the excess pore pressure?
21 A
Right.
22 Q
I assume that by looking at this chart, this 23 j plot of piezameter 40 you cannot tell absent some other I
24 information where you reached secondary consolidation?
25 l A
No, I would like to see other information before 1
ALDERSON REPORTING COMPANY, INC.
159 1
I would make that decision.
What I'm really trying to say, 2
just giving me that chart doesn't tell me all the information 3
I need to have.
And I have not made an evaluation of it.
4 Q
Eave you seen the other information, do you recall g
5 having seen the other information that you said you might a
6 need?
Such as the pond level.
R 7
A I probably.have seen it.
I do not recall it A]
8' in relation to that curve.
In fact, I don't recall that d
q 9
specific curve, although, I must have seen it because I
?
h 10 pre sume it was at the public hearing.
=
II
-Q Approximately how long -- and is it your testimony 3
I 12 that yo'u, yourself, did not make a computation to remove
~
=
13 fro'm' this tppe of. information any impact of the pond or
=
5 14 '
the groubd water level?
kj 15 A
I did not.
x d
10
.Q You didn't do that yourself?
w N
I7 A
I didn't.
5 k
18 Q
Did you ever review that work that was done by E
19 g
anybody else?
20 A
.I'm sure I must have reviewed some of that in 21 the response: that have been made to NRC.
22 Q
Roughly how long ago would that have been?
23 j
A Quite some time ago.
24j Q
Do you know what kind of pierometers were used i
25l at the midland site at the diesel generator building?
i ALDERSON REPORTING COMPANY, INC.
160 1
A The piezometers that I saw at the Midland Plant 2
site were casagrande type piezameters.
3 Q
Is that an open-tube type of piezometer?
4 A
As it was used at Midland it is.
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5 Q
Were all of the piezameters used in connection
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6 with the diesel generator building to your knowledge of R
l 6,
7 that type ?
3l 8
A I believe they were.
d ci 9
Q Were there piezameters in use in other places 2
h 10 on the site that were other than open-tube type?
E 5
II A
I don't recall.
m a
y 12 Q
Do the piezameters at the diesel generator building, b
5 13 which I think you said were open-tube type, have a problem".
a l
14 with time lag?'
15 A
Well, there is a time lag affect for any type j
16 of piezometer.
Casagrande type of piezcmeter was developed w
y 17 to reduce the time lag from what I would call a stand pipe b
18 piezometer, a stand pipe observeration.
And so there would E
19 be a small time lag.
E Q
You mean the open-type has less of a time lag l
21 than another?
22 A
The time lag relates to the time that it is required l
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23 for the water to flow into the piezometer to reach equalibrium M
level.
If you can do that with a very small volume of 25 water, then the time lag will be small and there are piezameters ALDERSON REPORTING COMPANY. INC.
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like that.
And then with a casagrande type, there is a small, 2
I think it is a 38th incri diameter intube so that the volume 3
of water if piezometer changes by a foot of volume of water 4
that flows in has to be whatever the voldme of water is e
5 in a 38th inch tube of a foot.
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6-Q Do you know who placed the plant fill at Midland R
7 as between Bechtel and Canonie?
A l
8 MR. FARNELL:
What part?
d 8
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WITNESS:
I was never at the Midland site at that h
10 time so I.cannot tell you from my own knowledge.
But it
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l 12' placed by Canonie up to somewhere about elevacion.. of 615 J
3 5
13 and above 'that the fill was placed by Bechtel, but I don't a
14 know how reliable tha't information is.
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15 BY MR. PATON:
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16 Q
How about at the dike?
w
-l 17 A
Canonie was a contractor in the dike.
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5 18 Q
To your knowledge Canonie did the entire dike?
5 19 A
It is my understanding he did the entire dike.
20 Q
To your knowledge, did Dr. Afifi suggest some 21 compromise with respect to the borings that are being requested 22 by the staff?
23 '
l A
Suggest to me ?
l Q
Suggest to Bechtel or to --
M 25l A
I don't know if he did to Bechtel, but he and I 1-ALDERSON REPORTING COMPANY, INC.
162 O
I discussed possible.
2 Q
Tell us those conversations, tell us what he said and 3
what you said.
4 A'-
Well, I would havecto-start off the thing by 5
g saying that I do n ' t believe that the borings that were
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requested with the core are technically required.
I believe R
7 that for each of the fixes that we have provided you information X
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there is a check which is a sound check and well recognized d
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h 10
.Q I'm sorry, sir --
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Therefore, our discussions were 3
Y 12 not r,e' lated to.the technical necessity of doing borings.
g g
13 Q
- Okay, n
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A But rather discussing what might be done to get j
k j
j 15 i out of a stalemate situation.
That 's really the only basis
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W g
17 '
Q Did'you read Dr. Afifi's deposition that addressed w
h 18 that subject?
b 19 A
I'm sure I must have.
I don't recall exactly.
20 Q
Let me suggest to you that I asked him whether 21 his suggestion was based on -- I'm going to suggest something 22 -
to you and ask you if it refreshes your recollection.
I'm 23l going to suggest to you that I asked him whether his recommendati n 24 were based on the merits of the case, the real need for 25 borings', or was it just an attempt on his part to settle, I
ALDERSON REPORTING COMPANY. INC.
l 163 1
1 get rid of a problem with the staff.
2 A
Well, I don't know about his recommendation that l
3 you are talking about, I'm talking about discussions I 4
had with Dr. Afifi.
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Q b
And I'm asking you about your recollection of
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R b
7 A
I don't remember.
Kl 8
Q I suggest to you that he gave the matter some dd 9
i, consideration and said it was very difficult to know which 10 of.those two provided the basis for his suggestion.
l 11 MR'.. FARNELL:
I totally disagree with that.
And also B
, y 12 Mr. Afifi-has not completed his deposition yet, so I can't Ij 13 agree'.with that at.all.
m j
14 l BY MR..PATON:
Y l
g 15 '
Ca'n I ask you to read pages 245 through page Q
z
.j 16 250.
s e
17 I think starting on line 20 he tells what 18 he proposed.
h 19 My question is, did you ever have any conversation 20 with Dr. Afifi that led you to believe that there was any 21 question in his mind as to the basis for his settlement 22 in this dispute?
23 A
I don 't understand the que stion.
24 Q
All right, let me strike that.
I I
15 What was your understanding of what his ALDERSON REPORTING COMPANY, INC.
164 I
suggestion was or his offer was to p'rovide the staff with 2
some information?
3 MR. FARMELL:
There is a couple -- can you refer to 4
s~ specific page in here or --
e 5
MR. PATON:
5 You can base your answer on the deposition l
6 or conversations that you had with him.
Do you understand k.
7 that he made some kind of an offer or a sug5estion?
K-l 8
WITNESSr I read that here.-
h* hat I told you' was that ;I d
9 had conversations with Afifi, but I don't know anything 10 about conversations that he'had.
_z 11 BY MR. PATON:
I 12 Q
. hat is your recollection of your conversations with W
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13 Dr. Afif.1 as to any suggestion he had to bide the staff a
l 14 with some of the information they were requesting?
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A The ' recollection that we had, we met with the z
j 16 NRC, I believe at the end of July at that meeting it was e
g 17 my recollection that it seemed it was a problem in the a
N 18 staff's understanding bearing capacity.
And I believe.
c 19 our discussion was based around trying to satisfy that 20 requirement to see if there was some way we could satisfy 21 that because we felt perfectly satisfied, in fact, with 22 bearin5 capacity and with settlement from a technical point 23 l of view kith the information we presented.
24 But in an effort to get out of the 25 !
stalemate, we discussed what might be done, but those were ALDERSON REPORTING COMPANY, INC.
o 165 i
i discussions between Dr. Afif1 and me and were not.
And I 2
don't know how those discussions were transmitted further 3
on in the organization, I don't know if they were transmitted 4
further in'the organization.
5l g
Q Am I correct that the thrust of your statement a
6 is that at least in your opinion any suggestion to provide R
7 the staff with that information was based on your desire a
j 8l to settle the dispute and not based on your real thought a
d 9
that this information was really needed by the staff?
g 10 A'
That's correct.
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'Q Now, my question is this, did Dr. Afifi ever a
I 12 say anything to you that indicated he agreed with you in x3g 13 that regard, that he was doing it solely to satisfy the z
14 staff as opposed to thinking that there was any real need
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16 A
I believe that's the spirit in which we had the as N
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18 Q
To your knowledge, he agreed with your thinking E
19 g
on that matter?
20 A
That would be my recollection of the conversation.
21 Q
And you have just read his deposition from pages 22 24 5 to 250.
23 A
Right.
I 24 Q
Does your understanding of pages 245 to 250 indicate 25 l to you any conflict l
ALDERSON REPORTING COMPANY, INC.
166 I
A I don't really see anything.
2 MR. FARNELL:
You are talking about two different 3
things.
His conversation with Mr. Afifi and these are 4
conversations with other people.
5 WITNESS:
In reading that I don't see any conflict h
j 6
with the discussions.
7.
R 7
What was your question that led up to all Xl 8
this response, do you recall what your question to me was?
d I
9 BY MR. PATON:
g 10 q.
Now, I'm going back to our discussion of a minute i
II ago about piezometer number 40.
in y
12
.A' Yes.
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,.And I.think you indicated that you couldn 't *just a.
I4 look at..that plot and make conclusions.
15 A.
Yes, I don't believe so.
d I6 Q
as You might not have said this, but I construed f
I7 it to mean you would have to take out of that plot the 18 affects of the ground water.
E 19 A
I would have to look at all those factors that might affect the piezometric level.
II Q
Can you tell me how you would go about that, 22 how would you take information concerning the ground water i
23l table,howw$uldyou--
24 A
Physically?
25 Q
How would you take that information and interpret the ALDERSON REPORTING COMPANY, INC.
167 I
piecometer number 40 plot?
2 A
I believe I would have to go through all the pie::ometr:
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3 l data they have to get that information that's necessary 4
to modify that curve.
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5 Q
Did the graph that I showed you -- do you recall, h
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I'll be glad to show it to you again.
R E
7 A
I recall the one you showed me.
X j
8 Q
Did it show that the level of the pond did_not d
y 9
change during that period?
g 10 A.
The'particular graph that you showed me for PC-II I40 did. not have the pond elevation on it.
3 l
12
'Q I thought it did.
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s 5
13 A
You showed me one for PC-30, that had pond elevation.
a l
14 Q
This graph for PC -- my point is the ponds is g
15 the pond.
Would you expect --
j 16 A
'I wouldn't disagree with that,
w h
17 Q
l And would you disagree that during May, June
=
h 18 l and July, the level of the pond --
E 19 A
The problem I have with this graph was kr.owir.g 20 where May, June and July is on it.
I can see April and 2I I can See August.
The pond elevation during that period 22 rose slightly and then fell according to this.
The scale 23 j on this drawing is quite different than the scale on the 24 one you just showed me there.
25 i Q
Is the char.ge in elevation of the pond l
ALDERSON REPORTING COMPANY, INC.
168 4
I sufficient to have affected the piecometer elevation?
)
2 A
It could have, I don't know without looking at data 3
to be able to tell you, but the change in the pond elevation 4
would'have caused some change in the ground water level e
5 and the plant fill and the affect of that on the pie ometer 5+g 6
is what I would be interested in finding.
E 7
Q Even if the pond water level remained absolutely 3
j 8
constant, it could be that it was causing the ground water d
ci 9
table to -- the ' ground water table was changing as a result z
10 of the ' influence of-the. pond; is that possible?
=
II
'A Well, that would. be one factor that I would want is y 1 2 lIto look' at. - I do not know because I don 7t have the data El 13 here, I do not know whether in fact that was, happening, a
14 out that would be one thing I would like to look at.
15' Q
Mr. Ferris, directing your attention to pie:cmeter j
16 number 40 plot, and specifically the pie:ometer elevation w
l 17 after the surcharge has been removed, and bearing in mind h
18 the fact that the elevation of the pond on figure 1 shows E
19 the elevation of the pond remained constant MR. FARNELL::
I'm going to object, he didn 't agree 25 with that statement.
22 MR. PATON:
All right, I'll start with that.
23 '
MR. FARNELL:
You are talking about two different 24 scales and they are he.rd to read so I think this whole line of 25 questioning is going nowhere, slowly.
ALDERSON REPORTING COMPANY, INC.
169 I
BY MR. PATON:
2 Q
Directing your attention on Figure 1 of Kane Deposition 3
Exhibit No. 8, the pond elevation, would you agree that 4
it remained almost constant through the end of the year
=
5 979?
1
]
6
'MR. FARNELL:
He said already he had problems with R
7 it _.
A j
8 MR. PATON:
From the middle of '79 to the end of the 4
c 9
- year, 10 MR. FARNELL:
He said already he had problems with the
=
II scale on that thing..
m 9
b 5
13 Q
.He may have problems.
If he can't answer the 2
l 14 question beca'use of problems, that 's fine.
15
.MR..FARNELL: What do you mean by "almost" counsel?
a d
I6 MR. PATON:
If he can 't answer the question, he should W
II say so.
l 18 MR. FARNELL:
It's vague, I'm objecting.
I'm telling II J
you, you don't have to speculate, either.
20 WITNESS:
I can see that this line is relatively level.
21 There are little humps in there.
22 i
BY MR. PATON:
23 Q
All right, bearing in mind that, what would be M
the possible explanations for the fact that the pie::cceter 25 elevation after the surcharge removal appears on pie::ometer I
ALDERSON REPORTING COMPANY, INC.
170 I
number 40 plot to be lower than the piezometer elevation 2
prior to the beginning of the surcharge.
3' A
I think I would have to go back to what I said 4
before.
The' pond level is one of the pieces of information
,5 but the ground watsr level in the vicinity of the diesel l
6 generator building is another and there could be things 7
that were going on that I am not aware of that need to X
l 8
be factored into that before you can analy::e it.
dd 9
Q
' Can you tell me anything that would cause a sharp 10 change in the ground sater table?
.~]
II A
Yes, a sharp rise in the pond m'ight locally cause n
(
12 a --
5
~
13 Q
Or. a sharp decline ?
I15 14 A
Or a sharp decline.
g
'Do you know of any others.
m j
16
.A Well, I'm sure I could think of some, I just w
g 17 don 't know offhand.
' 18 Q
What we are suggesting is there was no change h
II g
in the pond and what other possible causes could there 20 be?
II A
Well, if I was going to analyze that, one of 22 the things I would look at first, is the whole pattern i
l 23 ;
of the ground water in the plant fill, and that is controlled' I
s 28 by the pond, but the pond level the level at some point 25 within the fill doesn't have to be the same, t
9 ALDERSON REPORTING COMPANY. INC.
171 I
(At which point the deposition ended 2
on December 10, 1980, at 6: 00 p.m.
3 to be resumed on December 11, 1980, 4
at 8: 00 o' clock a.m.)
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ALDERSON REPORTING COMPANY. INC.
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172 1
AUTHENTICATION 2
This is to certify that the attached proceedings before 3
the Nuclear Regulatory Commission in the matter of:
DOCKET' NUMBER:
50-329-0M, 50-330-ox, 50-329-OL, 50-330-oL y
5 2
PLACE OF PROCEEDING: Offices of Isham, Lincoln and Beale
]
6 One First National Pla::a, Floor 42 Chicago, Illinois
-h7 g
DATE OF PROCEEDING:
December 10, 1980
]
8 d
were held as herein appears, and that this is the original d
9 f
transcript thereof for the file of the Nuclear Regulatory g
10 Ccinmission, g
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1A E l
%A g
13 I TERRI HE Y
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2
- 15. l U
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ll 17 1 a
18 E
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2o 21 22 3l 25 i
i ALDERSON REPORTING COMPANY. INC,
=
172 i
1 AUTHENTICATION 2
This is to certify that the attached proceedings before 3
the Nuclear Regulatory Commission in the matter of:
4 DOCKET NUMB 2R:
50-329-0M, 50-330-0M, 50-329-OL, 50-330-OL
=
5 PLACE OF PROCEEDING: Offices of Isham, Lincoln and Beale l
6 One First National Plaza, Floor 42 Chicago, Illinois E
7 k
DATE OF PROCEEDING:
December 10, 1980 l
8 I
e were held as herein appears, and that this is the original d
9 4
2i transcript thereof for the file of the Nuclear Regulatory h
10 Commission, g
11 m
LA i LLA Q 1 13 TERRI HERTTY
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25 ALDERSON REPORTING COMPANY, INC.