ML20090K919
| ML20090K919 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/11/1980 |
| From: | Ferris W BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-02, CON-BOX-2, FOIA-84-96 OL, OM, NUDOCS 8405240478 | |
| Download: ML20090K919 (79) | |
Text
\\hnt NU_ CLEAR REGULATORY COMMISSICN Qg'et l d4 #
/
<f/
In tte 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
(
CATE: December 11, 1980 PAGZE:
173 thru 252 AT:
Chicago, Illinois
.M E9X REPORTI.TO L
F.
400 Vi_T. r.ia Avs., 5.W. Washir. pen, D. C. 20024 r,
Talaphens : (202) 554-2245 l
1 0405240470 040517 PDR FOIA RICE 84-96 PDR
173 I
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
_______________x i
e 5
I In the Matter of:
8 6
CONSUMERS POWER COMPANY Docket Numbers i
g S
7 Midland Plant, Units 1 and 2 :
_ _ _x d
c 9 l Isham, Lincoln, and Beale First National Pl.a:a h
10 l 42nd Floor Chicago, Illinois 60603 5
i 4
II l Thursday, December 11, 1980 3
The continuation of the deposition of MR. WALTER 5
13 l FERRIS in the above-entitled matter met, pursuant to 1
E is,
"d3 """"*"*' ** 8 a
APPEARANCES:
0
'0 l l
On behalf of the NRC Staffs a
g j
WILLIAM D.
PATON, Esq.
United States Nuclear Regulatory Commission E
Washington, D.
C.
20555 19 On behalf of the Applicant:
~K 20 i
ALAN S.
FARNELL, Esq.
I Isham, Lincoln & Beale One First National Plaza 22 Chicago, Illinois 60603 i
23 '
24
)
25 i
ALDERSON REPORTING COMPANY. int
- 174 1
Also Presents
.s 2
JOSEPH D.
KANE Geotechnical Engineer 3
United States Nuclear Regulatory Commission Washington, D.
C.
20555 HARI N.
SINGH 5
U.
S. Army Corps of Engineers Detroit, Michigan
{
JAMES W.
SIMPSON 7
U.
S.
Army Corps of Engineers Chicago, Illinois dd 9
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W h
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t 2a 21 22 N
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l ALDERSON REPORTING COMPN --
175 EEEEEEEEE%1 2
Whereupon, 3
WALTER R.
FERRIS 4
,. witness herein, called for examination by Counsel for 5
l the Nuclear Regulatory commission, having been previously
{6 sworn by the Notary Public, was further examined and I
7 f
testified as follows:
0
- EXAMINATION BY COUNSEL FOR NRC d
BY MR. PATON: (Resuming)
N This is the continuation of the deposition II 4
of Mr. Walter Ferris of sechtel, Incorporated.
g
',12 I.want to place on the record a request that 13 the NRC. staff is making of Consumers and sechtel.
Will you provide the raw survey data of the initiai readings lU l 'of the building settlement markers,borros anchors and fIO settlement plates for the Midland site?
II This should include a plan that'shows all II survey monuments with elevations that are used in g
t l
completing the survey -- change that to were used in I
completing the survey.
i MR. FARNELL:
Could you read back the question?
22 (Question read)
MR. FARNELL:
I understand your request to go to all buildings at the Midland site since possibly j
the date of construction, an'd I think that request may be l
l AWRSON REPORTING COMPANY. INC.
i
p-4 176 I
overbroad, 'and: I really don t see where.somehof these i
2 buildings have'anything to do with this litigation.
3 i
am quite frankly surprised.that you Also, I
\\
4 would bring this up after we have been -- settlement li g
5 has bedn disco,vered two years ago, and we havembeen-o9 i
3' 6
1 in this litigation for almost a year.
i R
- 5 7
MR. PATON:
Mr. Farnell, there is a lot of N
j 8
information we have not been able to obtain, and this d
d 9
}.
is one of those nieces.
c h
10 MR. F A R N E'L'L:
This is something-you requested
=
l II earlier?
3
'd 12 2
MR. PATON:
No, we have recently discovered C
f I3 informacion that leads us to, question the survey n
f I4 f reliability.
Your saying that we are recently asking
=
l C
h 15 l for information amazes me.
You know that we simply f
16 'i cannot obtain enough information to evaluate your a
II l proposed remedy in this case, so I. don't think you should c
18 pretend to be shocked that we are asking for information.
8 MR. FARNELL:
I kind of look at this as t
n 20 another one of your requests that we should be able to 21 read your mind and give you things chat you have never i
asked for before, f
l 23 !
i i
MR.,PATON:
No, no, I agree that we have l
i 24 never asked for this information before, and I don't 25 -
expect you to read our mind.
It's -- we have recently.,
ALDERSON REPORTING COMPANY. INC.
~
177 b-5 1
~ discovered information that makes-us question the 2
settlement information and we think that might help.
3 MR. FARNELL:
Do you want all buildings?
4 MR. PATON:
No, let's talk about that for
[-
5 just a second.
We would like to limit our request to F!
0 the' diesel generator building *, service water structure, e7
- E 7
electrical penetration area, feed water isolation valve
}
8 pits, and retaining walls for the service water structure (4.
! and the intake structure.
~
I c
10 c
MR. FARNELL:
How about a time frame?
'I k
II MR. PATON:
Just a second.
a
(
12 (Pause)
E l
13 e MR. PATbN:
We would like the information in
=
I4 a month.
E l
15 '
g MR. FARNELL:
No,
~
E I0 MR. PATON:
You asked me for a time frame --
W 17 MR. FARNELL:
That wasn't the time frame
~~.
II I was referring to.
I was referring to dates of which k
3 this initial settlement, whatever that means n
0 MR. PATON:
I think he means to go back to 21 the initial survey, don't you?
II MR. KANE:
Right.
23 MR. FARNELL:
I have a suggestion.
How about 24 since August of 19787 Is that when you-want to go 25 '!
back to?
Do you want to go back to prehistoric time?
I I
l ALDERSON REPORTING COMPANY, INC.
p-6 178 I
MR. PATON:
Let's go off the record and talk 2
about it.
3 (Discussion of f the record) 4 MR. PATON:
We have had a discussion off the g
5 record,.and we have agreed that Bechtel will attempt to o"
f6 have someone knowledgeable about this subject discuss it 8
I.
with us in Ann Arbor next Wednesday, and we will then
- n 8
8 discuss further our request, n
d" 9
~
MR. FARNELL:
That's agreeable to us.
OF 10 j
BY MR. PATON:
(Resuming)
=
fII Mr. Ferris, in the year 1980 approximately how i
d 12' much of your time have you spent on the Midland soils z
. S' 13 j
-l p.roblem?
What percent of your time?
m I4 A
I am making a very rough estimate, I would u
O 15 g
say probably about two days per month -- that includes
~
16 3
meetings.
6 17 -!
G All right, what about 1979?
Ecw much of I
Em 18 'I your time?
U 8
l A
I would have to say about the same amount.
I n
20l 4
One more year -- 1978?
l 21 A
I did not get involved in Midland until a 22 phone call from Afifi in early August of 1978, and 23 -
following that I probably spent two to three days per I
24 month till the end of the year, most of that in meetings.
25l 0
That's two days per month?
I ALDERSON REPORTING COMPANY. INC.
1
I p-7 179 I
A Roughly, yes.
2 G
So, okay.
That's in the last three years 3 la total of less than sixty days?
I 4
A It would be in that order, yes.
g' Okay, let me show you Kane Exhibit Number 12.
g 5
a' 6 :f Mr. Ferris > would you look at Vu-Graf Number 10 attached R
- S 7 ' to Kane Exhibit 12, and I direct your attention to the K
8-,! chart there that reflects the elevation of the pond?
li 4*
9 A
Yes.
.zcF 10 g
G All right, can you tell me what the elevation
=
5 II of the pond was on October 13, 1978, and I assume that 3
f I2 the date.up here is day one?
3 13 5
A October 13, 1978, is day zero according to m!
I4 this scale, and the elevation looks to me to'be about
=
15 elevation 622.
I don't have a scale to give you more f
16 precisely, m
h I7 I G
Fine, and then about January 26, 1979?
=
{
18 A
At that point in time it looks like it's E
I9 g
about 626, in that order; again, I don't have a scale.
e 20 G
Okay, and then tell me the elevation of the 21 pond -- tell me the last date that you are able to see l
22 on this chart.
i l
23 A
Well, the last date I can see is August 30, 24 1979, and again that looks like it's about 626 or 25 something like that.
l l
ALDERSON REPORTING COMPANYc INC0 l
p-8 180 I
4 And then does it continue for say seventy to 2
eighty days after August 26, 1979 does the level of 3'
the pond stay constant?
4 A
It looks reasonably constant.
There seems 5
j l to be some minor fluctuations.
9 3
0 G
All right, let's call it at least sixty days.
C 7
So, through October, 1979, did it remain fairly constant j
8 according to that chart?
d y
9 A
It looks like that -- that it remained fairly EF 10 J
constant.
=
5 Il 4
Let me refer you to piezometer number forty --
m f, I2 l piezometer elevation chart number forty.
-3 j
13 f A
Yes.
m I4 l
4 My question is there's a line here labeled k
C 15 h
surcharge removal completed --
=
g 16 A
Right.
l h
II l G
And it appears to be right at the end of E
IO August.
After that line there is a decline in piezometer II g
elevation that is reflected by that chart.
20 g
7,,,
2I O
Is that caused by the piezameters returning 22 to ground water level?
23 l A
What is the elevation of this line?
I 24 s.j g
I can show you another chart.
25l A
It shows that it's less than'625?
}E i
ALDERSON REPORTING COME ANY thu"
181 p-9 I
g Okay, it's -- just a minute.
2
~
(Pause) 3 A
I think I know what your question is.
4 g
All right, I suggest to you that it's slightly 5
g above-626.
I will ask you to assume, and I can show a
5 0
you another chart that shows the line I have marked here I
as 625 would indicated that the top level at the end n
8 3
.of the rebound is slightly above 626.
I have another a
d I
d 9I chart that I can.show you.
5.
I 10l' H
A This is fine.
I believe I already addressed
=
f II l this, yesterday.
f I2 g
You did.
- a 13 j
A And,.at that time I said that there is other ml I4 l information I would need before I could interpret this s
15li w
graph.
g g
6j g
All right.
2 i
6 17 l; A
The specific information that I referred to o=
yesterday was-the pond level and the ground water level N
8 in the vicinity of the diesel generator building.
20 g
All right.
21 A
There may be other factors that I should also 22 look at and that would become apparent after I had 23l! looked at those two factors.
24 I j
G Other than the ground water, what other 25 factor would have affected it?
i i
i ALDERSON REPORTING COMPANY. INC.
P-10 182 I
A The one that immediately comes to mind is 2
that somebody could have dug a hoIe besides the piezometer 3
and changed this ground water table locally, but I 4
don't know that.
There could be other factors that 5
j could account for that.
3 0
I would want to look not just at one piezameter, R
7 but all of the piezometers in that area to see if that a
0 was an analogous reading or if this was typical of d-9
~.
the readings.
If it was typical of the readings, then c
h 10 I would have to find out what would cause that, and I II don't have that information here, and I very much doubt t
f I2 today if I'can evaluate it for you.
g 13 g
.And I believe you said that you never did --
14 you never --
_j 15 A
I never did make an evaluation.
t d
I0 4
So, any conclusions that Bechtel has with M
h II respect to those piezameter readings comes from someone
=
II else?
19 3
A That is correct.
I believe I said that n
20 yesterday.
2I 4
All right.
Now, Bechtel has concluded that 22 prior to removal of the surcharge you were in secondary 23 consolidation, is that correct?
l 24 A
That is correct.
25 g
And this piezometer, which is number forty, ALDERSON REPORTING COMPANY, INC.
183 11' I
clearly demonstrates a lower piezameter elevation after s
2 the removal of the surcharge than before, does it not?
3 A
Yes.
4 4
For example, during the month of October?
5
=g A
Yes, the level is lower on that month, a-3 6
G Lower than it is in the month prior to removal 2a 7
of the surcharge?
n 8
o A
That's right.
d 6
9 g
i
_G All right.
To have that circumstance, doesn't o
P 10 l 5
that mean that you must have had a substantial change
_~
=
11 g
in ground water level between the removal of the surcharge d
12 3
and the -- and October?
3 13 3
A One of the comments I said was that I would E
~14 y
like'to know the area ground water level in the vicinity 5
15 g
of this piezameter before I would --
?
16 MR. FARNELL:
He has already --
6 17 l w
BY MR. PATON:
(Resuming) i
=
18
=
I understand he has testified he needs a lot 19 8
more data.
20 1
g My question is this:
regardless of any more 21 data, my question is essentially if, in fact, prior to the removal of the surcharge you had squeezed out 23l all excess pare pressure -- let me ask you that do 24 l t.-
l you agree at this point here where you say you were in 25 '
secondary consolidation that all excess pore pressures t
ALDERSON REPORTING COMPANYo INC.
184 I
had been removed?
2
'A That is what I testified to.
I did not use 3
this graph to make that comment from.
4 G
All right, but all excess pore pressures were 5
g removed..
9 6
A Excess pore pressure due to the surcharge.
R b
7 4'
Doesn't that mean that regardless of any A
8 other information anywhere that if your piezameter d
d 9
' ele.vation is high'er before the removal of the surcharge h
10 and then is lower after the. removal of the surcharge, 5
l i
II doesn't that mean that between this time when surcharge a
f I2 was removed and this time when the piezameter level was
'S 5
13 ! lower that you had a substantial change in ground water I
m 5
I4 ;
level?
b g
15 A
Not necessarily, because there may be something
=.
I0lI wrong with that piezometer, and I don't have the infor-rid I
.h I I mation to determine that, and I'm not willing to say e
I0 that at this time, h
I9 g
MR. FARNELL:
I think you beat that piezometer n
20 to death.
2I MR. PATON:
I'm not getting any information.
22 That's the problem.
23 MR. FARNELL:
.That's because you're not 24 asking questions that are intelligent.
25 MR. PATON:
Now, I resent that, Mr. Farnell.
ALDERSON REPORTING COMPANY, INC,
185 I
I don't appreciate that at all.
I'm getting no answers 2
at all.
3 MR. ?ARNELL:
You're getting answers, but 4
they are not the ones you want because they are not 5
g the right questions.
n 0I E
MR. PATON:
Here is the Chief Soils Engineer.
R 7
j Bechtel'is claiming they are in'sdcondary consolidation n
S 8
M.
based on the piezameter level, and here is the Chief Soils d
9
~
7-Engineer, and he doesn't know.
So, I resent your telling S
10 g
me that I.am not asking the right questions.
I am
=
II asking very carefully drawn questions, and I'm getting no answers.
a I
.[
MR. FARNELL:
You're getting answers, but not E
d 14 l what you want.
15 g
MR. PATON:
That's right.
I'm not getting f
16 any information that's fairly basic to this case.
l f
That's why the NRC can't make its assessment.
=
0 MR. FARNELL:
I doubt that.
h j
MR. PATON:
Okay, you doubt it.
O BY MR. PATON:
(Resuming)
O Mr. Ferris, I show you piezameter number 22 thirty-six and ask you whether that general situation 23 j
that you have just described, and I will describe it 24 -
again if you want me to, is also true of that where the 25 l pirzameter elevation is higher prior to the removal of J
ALDERSON REPORTING COMPANYn INC.
186 I
of surcharge?
2 A
I have to make the same comment of this.
I 3
have not made the evaluation of the piezameter.
I 4
cannot look at the record of a piezometer and evaluate 5
it for you directly.
I think it's the same -- exactly 2,
8 3
,6, the same ground that we went over with regard to piezameter R
- S 7
number forty.
M 8
8 G
You say maybe the piezameter was what d
9 erroneous?
You said maybe the piezameter was broken C
h 10 or something?
=l II A
Maybe something was done there.
I 12 4
What could have been done?
r 3
5 13 A
I have no idea.
u h
I4 0
Maybe something was done and you have no 5
y 15 idea what could have been done?
u d
16 A
I have not evaluated all the data, so I can't A
i
(
17 tell.
c f
18 G
My question is then, isn't the only explanation E
19 g
for that change, a rapid change in ground water level, and n
20 your answer is that's not the only explanation?
21 A
That's not necessarily the only explanation.
22 0
And I am asking you what other possible 23 ;'
explanation could there be?
24
'MR. FARNELL:
He has answered that already.
25 '
He has gone into that before at least four times.
ALDERSON REPORTING COMPANY, INC.
187 I
MR. PATON:
No, he said the piezameter might 2
have broken, and I'm asking what other explanation, and 3
he hasn't answered that.
4 MR. FARNELL:
He has answered that already.
e 5
g He has gone into that before, and this is really trying 3
6 his and my patience, and I think you are wasting a lot 3
h of time.'
N 8
8 3Y MR. PATON:
(Resuming) d d
9 l
4 Do you have any other reason, other than the
.g C
l n
10 i piezometer could have broke?
E a
=
E 11 j,
MR. FARNELL:
Asked and answered.
c 12 3
MR. FERRIS:
I did give other reasons than
=
l d
13 s
that.
Look at'the record.
E 14 y
BY MR. PATON:
(Resuming) 5 15
}
i G
For this change here, between the --
Q 16 A
Not specifically on that.
6 17 g
G Well, that's what I'm asking.
i E
18 A
Oh, you're asking for that specifically?
E 19
]
4 No, what I am asking about specifically is 20 the change of elevation immediately prior to the removal 21 of surcharge and after it returned to this level.
22 A
You are talking about this elevation?
23 g
Okay, this elevation, but let me put it 24 l(,
for the record.
This elevation being the elevation 25 !
at the end of September.
ALDERSON REPORTING COMPANY. INC.
i
188 l
1 I -
A That elevation according to this is about 1
2
~
elevation 622.5.
3 g
Okay, my question is what are the possible 4i l reasons that could have done that?
l A-I cannot list all of the possible reasons, but 4{
6 ;I the other reason that I mentioned, there may have been E";
some work going.on there that I am unaware of, and would n
8 8
have to find out about.
m d
d 9
g G
Let me ask you this.
Is a rapid change in 0
10 I
'j-j ground. water level a possible reason, regardless of
=
l E
11 1 what actually happened?
Is that a possible reason?
g i
d 12 z
A
,'.Only if somebody pumped water rrom a hole 3
13 I
g in that area.
If they excavated a hole and pumped l
E 14 l water from it.
?
15 '
g l
Okay.
Now, we established a few minutes ago
~.
I 16 l ij-that the ground water -- that the pond reached I 17,
d believe 626 feet in January, 1979, and stayed very
=
5 18
=
close to that through October, 1979.
19 8
A Right.
20 g
Do you have any idea when the seepage from 21 the pond, as it affected the area under the diesel 22 generator building, would have stabilized, and if i
23 :: you don't understand my question --
24 l l
A I understand your question, I don't know the 25 i answer to that because I have not made an evaluation to i
1 ALDERSON REPORTING COMPANY. lNC.
i
189 L
l
[
I that specific.
l 2
g Do you know if anybody in Bechtel has?
f 3
A.
I would very much assume that they have, but 4
j I don't recall it, and I don't know the information from 5
having done such a study myself.
0 0
During the period of time when the full g,
b 7
surcharge was on the diesel generator building, is it M
0
~ the settlement markers could not be monitored?
true that d
I M R.- FARNELL:
What settlement markers?
I hl mean, all of them, one of them --
}
II l
=
BY_MR. PATON:
(Resuming)
{
12 g
Do you know how many settlement markers 3
I I
j there were,in the diesel generator building?
I4 A.
I am sure I have been told.
I don't recall.
b the number, and I don't recall that some of them were u a 0
inaccessible during that period.
II g
Okay.
I want to show you Figure 3 attached 18 to Kane Exhibit 8.
There is'a note at the bottom, h'
I g
and I will hand it to you so that you can read it, but E
I will read it for the record.
21
" Temporary markers at elevation 664 feet 22 were used during this period to estimate the settlement 23l of.the markers."
M A.
Could you read that.again, please?
25 g
I will hand it to you so you can read it j
l ALDERSON REPQRTING COMPANY. INC.
190 I
yourself.
I'm just reading it for the record.
I have 2
one more short sentence.
3 "On September-14, 1979, the settlement was j
i 4
again based directly upon the permanent markers."
5 I ask you to direct your attention to those 8
I sentences.
I A. '
I think I understand that.
K 8
0 okay, does that, after reading that, does N
that clarify'for you or refresh your recollection as I
h10 to whether any of the settlement markers were inaccessible
=
II during the surcharge period?
(
12 A.
I believe what that is saying is because the 5
13 I j
surcharge was inside the building, and you could not get fI4 into the top of the surcharge inside the bui5. ding, the 15 temporary markers were made that could read the settlements f
16 of the surcharge inside the building during the period a
h II when the surcharge was at its maximum level.
I8 I believe that's what it is saying.
E II g
g All right.
Can you explain the word " estimate" in here?
It says:
" Temporary markers were used to 21 estimate."
Just a minute, let me go off the record.
22 (Discussion off the record) 23l MR. FARNELL:
I'm going to object to your i
M question.
I don't think it's been established that 25 '
Mr. Ferris had anything to do with that graph.
Therefore,
191 I
I there is no foundation.
2 MR. PATON:
Okay, it's a Bechtel graph, if 3
Mr. Ferris can't answer my question, it's a perfectly 4
acceptable answer.
e S
MR. FERRIS:
I would like to answer your h
5 0 l question.
I would like to give you an answer to your R
1 l
ion.
7 l quest n*
8 M
BY MR. PATON:
(Resuming) d
}".
9 G
Okay, do you understand my question?
C h
10 I I
understand your question.
A I
=
N II l 4,'
Go ahead.
U I2 A
I personnaly did not write the notes on s
i 13 j
this graph, and so I am not responsible for the English m
I4 !
that's there, but we do have people who are not English-E i
15 l speaking people, and their use of words in English may rg Ef 10 not be entirely correct.
t.
k II l I believe the person who wrote that should 18 be asked that question.
19 '
g G
okay.
Do you know who that person is?
20 A
I don't recall who it is.
21 4
Do you know whether the person at Dochtel 22 who interpreted piezomotor data would be the same person 23; that wrote this note here?
24 f A
I do not.
25 g
Okay.
Does Bechtel have any plans for I
i ALDERSON REPORTING COMP ANY. INC.
192 I ' monitoring settlement of category one structurec between 2
now and plant operation and after plant operation 3
starts at Midland at the diesel generator building?
l 1
4 A.
It's my understanding that they do have that.
I 5
y You would.have to get the details from the Midland project.
t' 0 !
4 Do you have any knowledge as to whether this R
\\
o 7
plan has been submitted to the NRC7 O
A.
I do not.
You would, again, ha've to ask the l
d l
q 9 l project.
5 L
h 10 4
I assume you don't know whether they plan to
~
l 5
II' submit it to the NRC?
U f
II A.
I would assume they do, but I don't know that 9
g 13 !
for sure.
3 14 j
4 All right.
How will Bechtel determine whether
=j 15 !
buried conduits and pipes are settling during the I0 f
plant operation?
h II I MR. FARNELL:
I am going to object to that.
=
}
18 I think that it's been established already that he E
I9 8
isn't responsible for pipes; therefore, there is no n
20 foundation, but he can answer.
II THE WITNESS:
Mr. Farnell is correct, I do U
not know.
I 23 BY MR. PATON:
(Rosuming) 24 0
Explain to me in the organi::ation -- those 25f pipes and conduits obviously are buried in the soil, I
ALDERSON REPORTING COMP ANY. INF
193 Il and you are the Chief Soils Engineer.
2!
A.
Right.
I 3!
G What is the organizational structure that ends 4fupthat you have no responsibility in that regard?
Whose 5
responsibility is.it?
6 A.
I believe -- maybe it was not clear from o
7 ' what I said yesterday, but I believe the engineering
^j I
8 M
j work in Bechtel is done by the project.
O i
ll The project is supported by other specialists e
9
~
j
=
h 10 as required for specific purposes, and the soils group
=
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II l.of the geotechnical group provides design criteria 5"
12
,to the project engineering group and other soils related S
I j
13 l information when requested, and I.do not knok that b
I4 we have been requested to provide information on
$j 15 j settlement and pipes, and therefore I cannot address u
d 16 l that subject.
W h
II G
Okay.
I think Dr. Afifi said something
=
b II similar to that.
You respond to questions that are E
I9 g
asked by project engineering, you don't supervise the 20 construction?
21 A.
We are in a different division of Bechtel, 22 and we support their work on request.
23,
4 Okay.
Mr. Ferris, yesterday I asked you about 24 C.
examples of your experiences where surcharging had been 2$. applied after the structure had peen partially or l
ALDERSON REPORTING COMPANY. INF
2 i
194 1
1 completely finished.
2 A
Right.
\\
3
\\
G One was at Carr Fork, I believe, and the other 4
involved a tank, an oil tank, is that correct?
5 A
It was oil tanks, but that's.right.
I 8
l 0
Okay, and at Carr Fork, piezometers were 7
not used.
8 A
That is correct.
.a a
u 1
~.
9 S
I think you indicated with respect to the. oil
]
j tanks, piezameters were used?
10 k
II That is correct.
A 2
u
(
12 G
(What was the piezometer behavior after the
^
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5 13 l surcharge was removed?
a-i 1
I4 A
I don't recall that.
I am sure that informa-f 5
is 5
e1on mu e 3,y, 3,,,e,x,,,
3,,z aon,,
,,,,11, j
u d
16 g
Do you remember whether the piezometer 1
h 17 behavior was consistent with what you expected?
I.8 A
I don't remember that, the job was done l
I' 1
g quite a few years ago.
)
g okay.
Mr. Ferris, we exhausted your recollec-4 21 tion on your experiences with surcharging where the 22 structure was either partially or fully completed.
23 l
You gave us two examples.
24
- n, Is that it, or did you have any other 25; ex,eriences?
j L-.
J---------------
- - -ALDERSO N N - ---
195 I
~
A.
l I did have other experiences.
2 4
of surcharging where the structure was 3
partly or fully complete?
4I A.
It depends on what you call a structure.
5 g
Do these other examples involve tanks?
0 A.
No.
R 7
G okay.
Would you tell us about those other 0l instances?
d l
l A.
I believe yesterday I said there were four 10 i cases that I can think of on surcharging, and actually since then I thought of others, but I will stick with I
the four.
s 13 j
4 No, you can give us all of them, but would l you start with the examples of those where the structure E
I 15 l was partly or fully completed?
g Ef A.
All right.
This is one that you may have a I
little more difficulty in understanding, b
18 i
It relates to a tailings dam in Canada for E
g the Highland Valley Copper Mine at a place called 20
- Lornex, L-o-r-n-e-x.
There the embankment was built 21 in stages to permit improvement of the foundation so 22 that the dam could be built to a height of about a 23!
hundred and fifty feet, 24 v
In other words, the foundation was preloaded 25 by the dam itself; we waited till piezometers dropped A LDERSON REPORTING COMP ANY, INC,
.. _ _ _ _ _ _ _ - _ _ __._ _-. _._ _ - ~ _ _ _
i 196 i
I sufficiently to then put on the next stage of the em-1r
]
2 bankment, and I am considering that an embankment is j
3. a structure.
I 4
l so, during construction of that structure, i
S there wa,s in effect preloading of the foundation.
The 6
foundation'was of clay, and because we wanted to con-f i
7 solidate the foundation as quickly as possible, we l
8 installed drains in the foundation.
d j
d 9
The trade name of the drains is Geodrains, 10 g_.o-d-r-a-i-n-s, consists of plastic and paper, and j
bl installed by machine.
I 11 11 It might save a lot of questions if I tell g.33 you that.that work is publish'ed in the Pan-American --
14 the Proceedings of the Pan-American Conference in f
I l
l 15 soil Mechanics that was held last year, I believe in i
u h
d 16 Chile.
w 17 g
Okay.
Let me make a comment.
Let me limit 18 my question to your experience where the structure was 4
I II g
completed, and then the surcharge was removed.
j 20 A.
Okay.
The only other. experience of.that 21 type that I can recall, and it'.s not a personal ex-22 f,,,
perience, is the comments of Dr. Peck at the meeting 23 :
with NRC in February of last year,when he said the 24 y
precedent for preloading a structure was the auditorium 25l' in Chicago, and I believe that w.as around 1885.
l 4m--.au
.a-r-,
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197
'I G,
You said that Dr. Peck said something like 2
this was the practdent?
3 A
The precedent.
I 4 l 0
Can you tell us why that's considered to be 1
5
=h l a precedent?
3 O
A.
I can't tell you that.
I G
You mean Dr. Peck said it and you have no 8
idea why he said it?
d I
A.
I can tell you why I think he said it, but 10 I can't tell you why he said it.
fII G
Fine.
(
12 A.
I think he said it because it was the earliest b
13 j
recollection that.he had -- earliest structure that
)
14,
was preloaded in the structure.
15 G
You mean it's the precedent because it's the i
U i
16 g
first?
h I7 !
A.
The first in his recollection, but I cannot a
3 II speak for Dr. Peck.
I' g
S okay, do you know any more about this 20 auditorium that was preloaded in 1885 than you have 21 told us so far?
22 A.
No, I do not.
23!
G Do you know whether piezameters were used at 24
,y this structure in 18857 25 !
A.
Do you want me to answer the question?
ALDERSON REPORTIMNfrfrek
198 I
G Yas.
2 A
I don't know.
3 g
_ No, I don't want you to answer the question.
4 Other than your experience, do you have any i
e 5
knowledge of other examples of surcharging after the il
.6,' structure was partially or fully completed when surcharge R.
l 6,
7 ' was subsequently removed?
7l 8
A.
I can't think of any at the moment that d
d 9
qualify for that specific case.
g 10 0
Do you know any references in the literature k
Il,
to that subject?
U y
12 l A.
I do not, s
5 13 G
Have you heard anyone in Bechtel or Consumers
=
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Power make any comment or writo a statement indicating 15 that the surcharging should have been held for a longer rj 16i period of time?
A f
I7 f A.
I have never heard that statement, no.
=
1 18 0
or have you road that statomont?
E g
19l A.
I don't recall having read it in those specific 20 l words.
21 0
Okay.
How was the height of the surchargo
(
22 f selectod?
i 23l A.
I believe it was related to the maximum y
24 pressure that was imposed on the fill layer, as you 25 called it yesterday when I discussed the stratification l
Al TWDCrw mennette m m a m eu
199 I
of the, site soils, and I consider the fill to be one 2
stratum and then whatever is below that to be other.
3 I believe the intention was to stress the full strata.
4 depth of fill to approximately elevation 600 to pressures 5
that equaled or exceeded the pressures that would occur f
0l during operating life of the diesel generator building.
I G
Would that include dead load and live load?
8' A.
I believe it was intended to include dead I
d and live load, h10 g.
I think you indicated the Weigh load would be II f either equal to or exceed that final inspected load, but 1
g 12 did it exceed it by some pergentage?
13 A.
I believe that information has,been given I# { to the NRC'at the public meeting in Midland ht the and 15 of August of this year, fI' S
I am questioning your knowledge.
h II !
A.
I did not do the calculation.
=li 18 4
Do you Lac k wnat the percentage was?
$j A.
To my knowledge,the Vu-Graf that was given to the NRC at that time -- shown to the public and the 21 NRC, and given to the NRC showed that the preload 22 stresses exceeded the design stresses.
23f G
Okay.
You said that before.
M
(
A.
Yes, I did.
25l g
Exc<seded, but exceeded by what percentage?
@DERSON REP O RTI NG COM P A N Ynf NC ---
200 1
A I do not recall the percentage.
Is varied 2
throughout the height of the fill.
3 4
You said this information was presented at 4
a meeting'in August of 19807 5
A I believe'it was August.
It could have been l the beginning o.f September, but
]
'6 it was the public R
S 7
meeting that was held in Midland, and Mr. Kane was Xj 8
present at that meeting.
d C
9 0
Do you recall who made that presentation?
10 4,
I believe it was Dr. Peck that did, but I
=
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U
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12 4
okay, and was it Dr. Pack that developed the
'5 5
13 information?
a j
l 14 l A
It was either Dr. Peck or Dr. Hendrin, and I N
g 15 l could not recall which.
3 d
16 0
Do you know who developed that information?
a
{
17 l A
That was done by Bechtel -- the soils group 18 in Ann Arbor, the geotechnical group.
h 19 G
Under Dr. Afifi?
20 A
Under Dr. Afifi's supervision.
21 g
Do you know who under Dr. Afifi?
22 A
I don't recollect who it was.
23 ;
O All right.
Do you know when that information i
24 was developed?
25l A
For the Vu-Graf?
i I
ALosasON REPORTING COMBAMY thir
201 I
G Yes.
2 A.
No,.I don't.
3 4
Do you know was it developed before or after 4
the surcharge was placed?
l g
5 A.
I believe the information that was shown on El 5
0 l the Vu-Graf was prepared a'fter the surchargo had been S
7 y
placed and removed.
I believe that particular Vu-Graf 8
was prepared for the public mooting.
U 9
4 Regardloss of the Vu-Graf, can you tell un c
h 10 who prepared the information that lod to the amount of
=
i o,5 II l
surcharge?
In other words, y
12 A.
Oh, I believe that was also dono in the 3
T3 j
soils group, of courso at a much earlier timo.
I a
34 ;
D believe thoro woro estimatos; I don't rocall the procino Ej 15 l nature of those ostimatos.
=
i 16 0
All right.
Do you personally have an opinion h
II as to whethor a surcharge should excood final load by b
18 any porcentago?
Is thero any rule of thumb that you E
]
would follow?
20 A.
That depends on what you are trying to do.
21 0
It would depend on the particular situation?
22 l A.
Yes, it would.
O All right.
Do you have any personal opinion 24 as to what would be appropriato at tho Midland sito?
25 A.
At the Midland sito what wo were trying to do I
ALDERSON REPORTINGIOMPANL INF.
202 I
was minimize the mettlement of the diesel generator 2
building, eliminate the settlement of the fill under its 3
own weight and the weight of the structure, and I 4
believe that has been achieved.
I believe the settlement 5
readings show that.
{6 l 0
You say you were trying to eliminate the I
structure -- you were trying to accelerato --
8 i
A.
Well, minimize== accelerate the settlement of dO 9 I the fill under its own weight, and the weight of the 10 structure.
II G
Okay, with that purpose in mind, do you j
12 have any - -
I3 A.
The purposa was to get to a situation where I4 we could predict the settlement of the diesel generator 15 building over it.: forty-year life or whatavar the life is, f
16 ;
O With that objective in mind, do you have any h
II '
parsonal opinion as to the percuntage that the surcharge f18 should have exceeded tha tinal oxpected load?
E II g
A.
I can relaco to the surcharge that was there.
20 I believe it was extrom ly successful in doing that.
21 0
Okay.
I don't think you are answoring my 22
(,,
question.
My question,is do you have any opinion as 23 to percnnt?
24
(,,
A.
I did answer your questit)n.
I said that the 25 :
amount of the fiU that was put there clearly was I
Al.DFMSON REPORTING COMPANYo INC.
203 I
satisf actory since the results were satisf actory.
2 0
By what percent did the surcharge that was 3
put there exceed the final expected load?
4 A.
I don't know that.
5 0
Other than Midland, in your professional f
'l experience with preloading where the surcharge after the I
preloading was removed, do you know of any instance I
involving pipes and conduits being buried in the foundation i
d I
soils?
10 MR-FARNELL:
Could you read that back?
lII (Question read)
(
12 MR. FARNELL:
I don't understand that.
Ej. I0 MR. FERRIS:
I think I understand the question, I4 and I can address it.
I discussed with you yesterday W
i g
15 the Carr Fork project for the Anaconda Copper Company, 8
I 16 g
and that included two thickener tanks, these are big II '
basins, and each of those thickener tanks had an I8 underflow tunnel, I don't recall the size of that, but E
I' j
you could walk into it standing up, so it was clearly 20
-, they were larger than six feet in diameter, and in 21 both those instances of those two tanks, those areas 22 were preloaded after the underflow tunnels had been 23 constructed.
24 S
Do you know any other examples?
25 l A.
There may be others at carr Fork, I just ALDERSON REPORTING 9;PT]/YXLM
s 204
~
I I do not -- oh, I do recall in the ore storage area at
~
2 the Carr Fork project there is a reclaim tunnelApart 3
of which was concrete, part of which was corrugated metal, 4
and that was beneath the most heavily loaded poriion of 5 j that planta The ore' pile' was quite i i1igh pile.
0' 6
0 At Carr Fork were any of-those' buried pipes g
i C
'd I
or conduits effected by the surchar'e?
g e79 8
s A
I do not recall that the underflow' tunnels i
d
~
9
~
at the thickeners were effected; I do recall that z
g' 10 there was deformacion at the reclaim tunnels at the ore
=
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II !
storage pond.
~
3 l
12 y
G At Midland do you know whethdr thi pipes S
13 j
and conduits urider the diesel deEerator building are 14 category one?
x
=
s I3 '
-t A.
I would suspect' ' there must be category one
^
=
5 I6 pipes there, but I don't k5Sw whic,h is category one.
s f
I7 l 4
Was any consideration given'to t}iat in 18
.s planning.the surcharge prdgram?
~
l~
I9 i
A.
Yes, there was.~
g a
20 g
What were those co'nbiderations?
~
2I A.
In evaluating what type o'f-corrective treatment.
22 to carry out at the diesel generator building, one i
I
~
23
' tlid procedures we concern that we had was that some of 24
~
l considered did not take care' of the pipes anc_ onduits, N
25 Ts and we felt with the preloadin'g. fill that if damage s
i, l
ALDE'RSO20 REPORTING COMP A NY INr
205 I
was going to occur, it would occur.under the preload 2'
and could be taken care of prior to operation of the plant.
3 G
Okay.
Let me try to characterize your i
4 answer, and if I don't do it fairly, please correct it.
5 g
I think I heard you say that it was that a
{'
! your thought 6
was that if the pipes and conduits under E"
the diesel generator building were going to be damaged n
8 8 ! in any way because of the settlement, that your preload a
d
}"-
program would jus-t accelerate that matter and you would 9
oS 10 j
get an answer to that and deal with it sooner rather
=hII than later.
c 12 z
A That is not precisely what I intended to say.
=a I
I don't recall what I exactly said.
E 14 g
G Please clarify.
'=
I A
What I intended to say was that damage to T
16 the pipes would occur during the construction period
=
d 17 l and could be taken care of during the construction i
3=
5 18 period, whereas with other types of corrective treatment
=s" 19 8
i that we considered, such as underpinning, the fill would n
20 still have continued to settle under its own weight, 21 and some damage could have occurred after the plant 22 had gone -- might have occurred after the plant had 23 gone into operation.
24 For that reason -- one of the reasons we 25 !
used the preload was that we could take care of these I
l ALDERSON REPORTilNG COMPANY. INC I
206 I
problems during construction.
2 G
Did you consider whether the preload program 3l would aggrevate in any way the damage to the piles from l
4 settlement.
By that I mean -- I think I understood 5
j you to say that it might have accelerated that damage, 2
E 0l but would it have made it any worse?
R 7l
- }
i MR. FARNELL:
Damage -- I don't think it's 8l Eg been established that there has been any damage, d
}".
9 MR. PATON:
Do you understand my question?
o i
F 10 I j
MR. FERRIS:
I understand your question, but
=!
II I don't recall the extent to which we considered that.
E h
I2 BY MR. PATON:
(Resuming) 3 g
13 I
G Do you have any present opinion as to whether ---
l M
4l1 ignoring'the fact that the surcharge program may have 1
~
C 15 h
accelerated any damage to the pipes?
=
16 L
I don't know that the pipes have been 17 [' damaged, so I can't answer the question.
That's my d
=
l 5
18 problem.
t."
19 8
G Have you never heard in Bechtel any discussion n
20 l
whether those pipes and conduits are presently undergoing 21 l stress and in fact may now be overstressed?
22 A
I have heard discussions of stress in pipes.
23 i
I do not'specifically recall that th'ey related to 24j the diesel generator building, and therefore, since it's 25 not an area that I feel I'm expert in -- stress in i
ALDERSON REPORTING COMPANYo INC,
207 I
pipes, I prefer not to discuss it.
2 G
Have you ever heard anyone in Bechtel 3
express an opinion that any of the pipes at the Midland 4
facility are presently overstressed -- the pipes in 5
3 the ground) n 3
6 A
I believe I was present in a meeting when E"
I such a discussion took place, o
I 8
8 4
Somebody in Bechtel said that some of the d
{"-
9 pipes may be overstressed?
E 10 j
A My recollection is that at. bends in pipes
=
5
'l g
the stresses were very high.
I don't specifically c
12 2
recall that they were overstressed, but they were very n:
13 l g
high stresses.
E 14 y
l G
Who said that?
=
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15 f A
I think it was Bimal Dhar, but I could be J
16 ;;
g l
wrong.
(
17 i w
4 Have 1.abcratory consolidation tests been cw 18 conducted on plant fill material in the diesel generator C6 j
building area following the removal of the surcharge fill?
20 A
Not to my knowledge.
21 l' G
Are there any locations where a slope slide 22 of the cooling pond embankment could prevent the l
23ll functioning of a category one pipe?
I 24l A
I have not specifically looked at that, 25 '
so I would not be able to say right now.
ALDERSON REPORTING COMPANY INC
208 I
could you,tell me what you mean by slope 2
when you say that?
3 4
Let me show you Kane Exhibit 3.
I am going 4
to show you Kane Exhibit 3 which purports to be a plan 5
j of the service water' pump structure, a portion of the n
3 6
cooling pond, and dikes immediately -- the baffle dike R
\\
- S 7
and the dike on the side of the cooling pond, and ask Ml 8
you if that would assist you?
l d"
~.
9 Frankly, I do not know the source of that c
h 10 document.
I think it was introd'2ced by the Applicant.
=
ll A
Could you tell me which specific slopes 3
y 12 you mean and which pipes you are talking about?
4 l
13 {
Let's go of.f the record.
m I4 j
(Discussion off the record) h 15 BY MR. PATON:
(Resuming) 16 Mr. Ferris, I want to show you Kane Exhibit h
17 I Number 3 which, as I said before, I am not sure of the z
18 source of this, it was introduced by the Applicant, but E
II g
it appears to show a portion of the pond and it appears 20 to show -- appears to show a portion of the cooling 21 p o nd,- and it appears to show the inner pond that's 22 called here " emergency cooling water reservoir," and I 23 :
ask you whether on the portion of the baffle dike that i
24 '
is shown and the portion of the dike on the other side 25) of the emergency cooling pond, do you know whether D
A LD ERSON_ R EPO3FR@$ @tErd9/RR2JYmL
209 1
there are any category one pipes in those two portions?
2 A
I believe there is a pipe on each side of 3-category one, but I am not absolutely sure of that.
4 G
Okay. Are there any locations where a slope e
5 slide of the cooling pond embankment could prevent R4g 6 l the functioning of those category one pipes?
R E
7 MR. FARNELL:
He said he doesn't know for A
j 8
a fact they are category one pipes.
d 9
BY MR. PATON:
(Resuming) zeg 10 g
Let me ask you to assume just for the sake z=
11 of the question that those are in fact, as you think 3
{
,12 they might be, category one pipes.
5 13 A
-I have a problem with 'the rest of your
=
m5. 14 question.
$-j 15 g
Do you have a problem with the expression
=
g 16,
slope slide?
e I
i g.
17 i A
Yes, I do.
Are you talking about the 5
i 18 l embankment?
E 19 g
G Yes.
n 20 A
Okay, I still have a problem.
21 4
Let me ask you this.
Do you consider that 22 there is any fai).ure of the embankment dike that could j
l 23 l effect what I have asked you to assume to be those 24l category one. pipes?
25L A
I haven't assumed anything about failure of i
I ALDERSON REPORTING COMP ANY int-
210 I
the dike.
All of the analyses that I have seen shot that
~
2 the dike is stable.
3 0
Okay.
Could a slide of the cooling pond 4
embankment prevent the functioning of category one 5
l, pipe -- let me ask you preliminarily, a
8
6 Do you know where the category one pipe is?
,a 8
7 A
It's.my recollection that they go along n
8 8
both sides here, and they are in the till.
I am not a
d" 9
~.
certain that they are category one, but there are z
0 10 g
pipes on both sides.
=
fII Q.'
Okay.
Could a --
f I2 A
I am not sure they they are both category
="
13 5
one.
I am sure one of them.is.
m I4 0
Okay.
Could'a slide of the embankment N
g 15 ffect the functioning of those pipes?
e
=
d I0 i
MR. FARNELL:
I thought he said he had problems d
C 17 I with that which you haven't cleared up yet.
E 3
You don't understand the question?
Ch I'
j MR. FERRIS:
I understand what you are saying, 2o but I have problems with it because the information 21 I have on embankment that I've seen indicates it has an adequate factor of safety.
23 l
BY MR. PATON:
(Resuming) 24 I l
0 You are indicating that it couldn't possibly 25 '!
slide?
Is that what you are saying?
~
i Jw
211 1
1 I didn!t say that.
I am saying what I know 2
about the embankment.
3 I am asking you to assume that it does slide.
l l
4 A
I see.
Okay.
5 g
Would it affect the functioning of the pipe?
3 0
I A
If I made that specific assumption, which I R
- S 7
am not certain is a reasonable assumption, then I j
8 believe it may be possible that a pipe could be damaged.
d y
9 g
Does Bechtel have a policy of taking control zo I
h 10 samples during construction to check the adequacy.of
=
3 Il compaction in various embankment zones?
m
{
12 MR. FARNELL:
What time period are we
=
5 13 talking about?
m E
I4 MR. PATON:
Today.
E 2
15
-MR.
FERRIS:
I don't know that there is j
16 a specific policy.
a f
I7 l BY MR. PATON:
(Resuming)
\\
z b
18 Is there a practice?
cs 1
l9 g
A There is a practice.
20 g
And they do follow that practice?
21 A
As far as I know they did on those jobs that 22 7.m involved with.
23 MR. FARNELL:
He said there was a practice, 24 and I don't think we have got what the practice is.
25 'I MR. FERRIS:
There's a practice of taking l
ALDERSON REPORTIN(;; MMN ANV I Mr*
212 I
quality control samples in fill during construction.
2 Bi MR.-PATON:
(Resuming) 3 Q.
Does Bechtel have a practice of taking record 4
samples during construction to check the adequacy of the 5
j compaction in embankment zones?
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I object and ask for a definition
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I don't know --
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Do you understand the difference a
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13 MR. FERRIS:
.I'd like to know what you mean.
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BY MR. PATON:
(Resuming)
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15 Q.
Okay.
Is it your testimony that you do l
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II MR. FARNELL:
He said he didn't know what i
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record samples --
5 0
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I want to know what you consider 21 record samples.
22 MR. PATON:
I am asking the questions, Mr. Ferris..
F 23 !
MR. FARJELL:
That's not 24 I I
MR. PATON:
My question to you is do you 25 know the difference between record samples and control ALDERSON REPORTING COMPANY. INF i
l 213 I
samples?
2 MR. FARNELL:
He does not know what you l
3, mean by record. samples.
4 MR. PATON:
Fine, let him answer the question.
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He can't answer the question.
3 6
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(Resuming) w 17 Q
Do you know the difference between control i.
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A Well, a control sample can be a record sample.
'O That's the problem I have, and so I want to know what 21 you mean by record samples when you asked me that question.
22 O
You said to me a control sample can be a 23 :
record sample?
24 A
Right.
25 '
G Can a record sample be a control sample?
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ALDERSON REPORTING COMP AhlY I Mr*
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A Not all record samples as I define them are 2 'i control samples.
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Tell me the difference between the two.
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n 20 A
At specific locations they are.
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That is my definition of record j
25 samples.
I do not know if it's your definition.
ALDERSON REPORTING COMP ANY. INC.
l 215 I
G My definition is not relevant or even 2
competent.
I am not competent.
I asked you your 3
definition.
4 A
Okay.
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Let's break before we go into 5
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MR. PATON:
Okay.
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(Short recess taken) k I0 'l BY MR. PATON:
(Resuming) m h
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Mr. Ferris, I asked you a question about E
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that question.
20 Does Bechtel have a practice of taking record 21 samples during construction to confirm the adequacy of 22 soil paramaters?
23 !
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I thought I had answered that.
I said not i
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in.every case, but in some dams that has been done.
25i G
Okay.
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ALDERSON REPORTING COMRANY INC
216 I
1 A
But not in.'ll dams.
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2 G
All right.
Was a program of taking record 3
l samples for the above purposes initially planned by ll Bechtel for the cooling pond embankment at Midland?
4 5
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I cannot answer that for sure.
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f 16 That is basically what I recall.
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You don't recall expressing any intent on 2
I Bechtel's part to take those samples?
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I don't recall that I said that.
I don't 20 recall that I would have had that information available 21 to me.
2l G
And you. don't have any --
3l A
I might have said that had I done the dam 24 1
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I would have required record samples and therefore they 25 >
would have been available, but I don't recall saying i
i ALQERSON REPORT 1N(:(*nMD AMV Iw' i
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that this was an intent on the part of Bechtel.
2 O
Okay.-
2 hat's my next question -.if you had 3
done the dam.
If you had done the dam, would you have 4
recommended the taking of record samples?
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23 A
I think I was much more specific than that.
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G You weren't involved at all?
2 A
No, not at all.
3 G
Do you know enough about the dam now to know 4
whether you would have recommended taking record samples?
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Could I have that read back, i
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20 MR. FERRIS:
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I will ask you to rephrase it.
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1 25 :
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What is the purpose of taking record samples?
1 ALDERSON REPORTING COMPANY. INC.
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A Record samples as you defined them?
2 G
As you defined them.
3 A
As I defined them, the purpose of those is 4
to provide information to the designer that the dam as 5
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Now, let me try the question again.
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In generally accepted engineering practice, Nl 8
what soil parameters should be established for materials 1
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to confirm I
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II A
I still have the problem.
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I2 MR. FARNELL:
Sam objection.
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(Resuming)
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IJ ycur problem with what soil parameters?
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A The problem is with generally accepted d 16 ll practice.
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1 18 G
Generally accepted engineering practice --
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that does not have a meaning for you?
20 A
Earlier I said that I did not believe the 21 taking of record samples as I defined them was essential
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to good engineering practice.
22 23 ;
G Okay.
24 (j
A Therefore, I could conceive that I could 25 exclude those in responding to you, and I could respond i
ALDERSON REPORTING COMPANY. INf"
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to you in that respact.
2 G
I understand your answer.
3 A
Okay.
4 G
Mr. Ferris, one more time just for clarification.
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Does good' engineering practice -- would good s
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Could I have that read back, I
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(Question read) n 20 MR. FARNELL:
Is that the end of it?
2I MR. FERRIS:
The answer to that is yes.
22 BY MR. PATON:
(Resuming) 23 G
Do you do it by some means other than record 24
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samples?
25l A
It could be done by other means.
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ALDERSON REPOnTING COMPANY. INC.
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Q.
What other means?
2 A
Well, the thing that is essential to good 3
engineering practice is that you. control the placement 4
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the other parameters will be attained.
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Okay, I understand, and that applies to the
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Has Bechtel evaluated the consequences A
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MR. FARNELL:
You are assuming that they n
20 postulate a failure, right?
2I BY MR. PATON:
(Resuming) 22 0
I asked him have you evaluated the consequence 23 of any postulated failure of any portion of the cooling 24 l pond embankment?
ss 25l A
I personally do not recall having done that.
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G Do you have any knowledge whether anybody in 2
Bechtel did that?
3 A
I do not recall that I have been told that, 4
but I am saying that I do not know whether they have or they have not done that.
G Who in Bechtel would know that?
n R
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The Bechtel project-engineer on Midland n
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should know.
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Is that Mr. Curtis?
C 10 A
Yes, it's Mr. Lynn Curtis, C-u-r-t-i-s.
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4 Do you know of any fact indicating a need o
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to investigate potential downstream damage caused by 3
failure of the dike at Midland?
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Could you repeat that question again, please?
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Yes.
Do you know of any fact that would
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indicate a need to investigate potential downstream l damage caused by failure of the dika at Midland?
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quired to' evaluate 9 safety of the dam -- of a.ll dams.-- on 20 that basis.
That was one of the items that was of 21 concern.
You are talking about a global requirement?
l' O
No, my question is addressed --
23 A
Well, Midland is a dam.
24 G
I am talking -- do you know of any fact 25 '
concerned with Midland that would indicate a need to i
l ALDERSON REPORTING COMPANY. INr*
223 1
investigate the potential for downstream damage caused 2
by failure of the dike at Midland?
3 j
A Well, I believe it is a requirement that one l look at 4
that, but I personally do not know that.
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I am not talking about general requirements e
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I don.!t know of anything.
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To your knowledge has Bechtel made any
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11 l by a failure any failure of the dike at Midland?
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12 l A
I do not know whether they have or have not.
13 4
Okay.
Mr. Ferris, I hand you Kane Exhibit 3 5
14 l and direct your attention to page two, the fifth line.
m 5
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Let me read that sentence:
y 16 l "Furthermoro, it is estimated that borings W
6 17 l per area which would be required in accordance with the a
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18 staff's request would cost a minimum of $400,000, not P
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costs and possible damage to install components and 21 structures."
22 I ask you to look at that sentence.
In fact, 23l look at any part of the document you want to.
My 24 question is going to be whether that S400,000 cost is 25,
reasonable in yo'r opinion.
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A I don't know what it's made up of, so I 2
can't address that.
I have heard the number before, but 3
I don't know.
I 4
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A Again, I would have to refer you to the j
6 project engineer.
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I am. reading from a sentence in the first Gl 8
complete paragraph on page thirteen of Kane Exhibit 8.
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" Standard penetration tests in the fill at these locations zoF 10 g
show blow counts between ten and sixty with two ex-E II ceptions,near'the surface on three and seven."
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What is this document -- what is it a
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You can read any portion of the document you e
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It's a response to our recuest for borings of our g
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Okay, I have read it.
1 3
18 4
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there that borings with standard penetration tests were n
20 completed when the piezometers were in the dike.
Do 2I you agree with that?
22 g
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Do you know whether that information -- the 24 borings with the standard penetration values have 25l ever been submitted to NRC?
I ALDERSON REPORTING COMPANY. int'
i 225 l
A It.says here they are going to be provided 2
in response to question forty-six.
3 g
okay.
4' A
I don't know if question forty-six has been 5
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To your personal knowledge do you know R
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whether that information has ever been submitted?
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I don't recall precisely when the pond was z
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would think.
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Okay, thanks.
5 19 The blow counts of three and seven which 20 were indicated in that sentence I just asked you to read, 21 is that a cause for concern with respect to dike 22 stability?
23 A
Not necessarily.
I would need to know where 24 they were and what material was there.
The sentence 25 says "at two exceptions near the surface of three and i
226 I
seven," and it's very common to have low blow counts 2
near the surface.
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4 A
Without knowing ruore about it, I could not I
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respond to you.
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Do you have --
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A I need to know the material and look at the log.
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9 f whether Bechtel ever did look at the material or 10 g
investi. gate.that further?
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I don't recall who installed the piezometers.
f 12 Are you saying that Bechtel installed the piezameters?
S.I j
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Regardless of who installed the piezometers, e
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l dc you know whether Bechtel ever conducted any inves-l tigation with respect 15 l
I to those low blow counts?
16 i
L I am not aware whether they have or not, h
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G Do you have any professioral experiences 18 where hydraulic fracturing caused instability of an b
19 l g
embankment?
20 A
What do you mean by instability?
21 0
Let me ask you, in your opinion do you 22 understand the word instability -- your judgement with 23 '
respect to embankment.
i 24 'l A
I un-derstand instability.
I D
g Okay, I am asking you as you understand the l
ALDERSON REpoloTtNn mun a uv iw-
227 I
word instability.
2 A
I personally de not know that of.my own 3
personal knowledge that that has caused instability 4
as I define instability.
5 4
How do you define instability?
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6 A
Instability in my opinion would be fa lure.
R 7
4 Have you ever heard -- you know, you have Al 8
answered from your own personal experience.
d 9
A Right.
t E
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Have you ever heard of any instances where 11 hydraulic. fracturing has caused failure'of an embankment?
ta f
II A
I have not heard that it has.
I have heard S
5 13 cases where it has caused damage.
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15 those instances?
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A Yes.
On a Bechtel. project in Montana, at l
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- colstrip, C-o-1-s-t-r-i-p, there was an earth embank-a 18 ment there about the same height as the, Midland em-E 19 bankment, and in drilling a hole into the core of the 20 dam, the dam was fractured over a length of about a 21 hundred feet is what was quoted to me.
I did not 22 personally see it.
23 :
I would be very concerned.if that happened r
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24 to an embankment.
25l g
Do you know any more about that situation?
i ALDERSON REPORTING COMPANY. INC.
228 fForexample, what caused -- you said it was a hundred I
l feet what?
2 3
L A hundred feet long.
4 G
The damage?
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A The crack was a hundred feet long, that's h
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Do you know how long it took to develop the Kl 8
hundred-foot crack?
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A few seconds.
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It happened immediately?
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Right, very quickly, n
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What was the purpose in drilling the hole 3
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You were doing sainpling -- taking a sample?
c8 l9 l A
In actual fact, what they were doing was g
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grouting in the dam.
21 G
You mean you drilled the hole and then you 22 were going to put some material in the hole?
t 23 i A
Yes, under low pressure.
24 lj 0
Under low pressure?
25
.A Yes, drilling the hole for' grouting is my l
l l
ALDERSON REPORTING COMPANY. INC.
229 1
recollection.
2 g
All right.
To your knowledge was there ever 3
an investigation as to the cause of the cracking?
For 4'
example, was it because when the hole was drilled it g
5 1 wasn't done properly?
8 3
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Well, I.would assume it wasn't.
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10 A
I believe it was hydraulic fracture.
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Do you know whether it was caused by the s{ 13 12 fact that the hole was drilled and improper procedures 5
were followed or done carelessly?
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I don't know that.
It was a ecmpetent c
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g 16 g
Okay.
Could the grouting have caused that?
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No, it was during the drilling of the hole.
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Prior to the grouting?
E 19 e
A Yes.
M 20 g
Okay.
To your knowledge no one ever determined 21 why the hundred foot crack occurred?
22 A
I believe everybody attributed it to hydraulic 23 i
fracturing.
24 4
Had grouting been done in any other holes 25l anywhere near the hole where the cracking occurred?
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ALDERSON REPORTING COMPANY. INC.
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230 A.
That I. don't $acalk.
I 2.
G Have you e:thausted your knowledge of anything --
3 any instance you ever h3ard where hydraulic fracturing i
4 has occurred?
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Well, I'know in the. literature there is
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but I have-exhausted reference to hydrauli6 fracturing, R
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Okay.
!! ave you ever heard any comments by d
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Yes, I believe there have been comments that b
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that is a possibility.
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Is Dr. Grey -- is there a Dr. Grey that is k
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c 5
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Not on the Midland project as'far as I knew.
h II l 0
Have you avar haard anyone -- strike that.
18 You say there is not a.Dr. Grey that is a 5
g consultant for Bechtel on the Midland project?
20 A.
You didn't ask me that.
21 0
All right.
Let me ask you that quest' ion.
22 A.
I know there is a Dr. Gray at the University 23 1 I do not know ifI e has consulted on h
of Michigan, but the Midland project.
)
24 25f Do you know if'he has ever made',a comment G
l I
ALDERSON R$ PORTING COMPAhY. INC.
231 I
about the likelihood of hydraulic fracturing at Midland?
2 A
I have never heard that.
3 4
Have you ever seen anything written to that 4
effect?
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A I do not recall seeing anything written on that.
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What precautions would you take to E
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prevent hydraulic fracturing when drilling?
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A I w uld refuse to drill is the simplest way dn 9
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G Assuming that you were going to do some l
11 m
drilling in an embankment g
12 MR. FARNELL:
Are,you just talking about 3
13 j embankments in general?
l 14 I MR. PATON:
At Midland.
g I
15 g
i MR. FERRIS:
Well, I think one thing I would l
16 do first is discuss it very seriously with our con-j 6
17 i a
sultants to see what factors would need to be considered, h
18 but I believe it is a potential danger to drill in a E
19
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dam that has water against it.
20 BY MR. PATON:
(Resuming) 21 0
okay.
It is your opinion that hydraulic 22 fracturing is a real danger in the Midland case, is I
23 that correct?
24 !
l A
I think it could be a real danger in the 25{ Midland case.
I think it involves a liability that l
l ALDERSON REPORTING COMPANY, INC.
l
,~232 I
I don't believe is justified.
2 l g
Okay.
Could be presents a. possibility which 3
I am suggesti:ig is not too helpful.-
I am asking-you - x
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A.
- Well, I, don't know whether1 it-could or'could' 5
j l not happen, but I don't want it to happen.
?
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In othei words, you don't have any specific
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knowledge, you are just saying it's a possible, risk so
+
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Is that what you are saying?
4
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I am sayin'g that it happened once before:t'a z.
I O
h 10 my knowledge in a dam of that'si::e with a competent a
4 II driller working, and the.persoil who was watching it was' y
12 a geologist of about forty y ars expsrience, and if it s
5 13 happened under those cir'ctimstances, it's more likely to
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happen with people who are less experienced watching it.
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15 l g
Okay.
Isn't it fairly commo$ practice to
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investigate dams by borings after they are completed?
+.
h II A.
I do not believe it is fairly common practice.
i.
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Was it'ever common practice?
e.
19 A.
I do n'ot believe it was ever very combon j.
20 practice.
II g
Do you think th'e f easorY' -- do'you think.
22 '
hydraulic fracturing is one of the reasons th a,t 16's,not 23 ;
common practice?
], '.*
y.
g.
24 A.
I can't answer thatF I I
don't know.
25 i g
okay.
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ALDERSON REPORTING COMPANY, INC.
233 1
A I would like to make one statement to add to 2
that last answer I gave you.
Can I do that?
3 MR. FARNELL:
Yes.
4 MR. FERRIS:
In answering that question, I 5
made the assumption that the dams had water against j
6 them as the dam at Midland has water against it right now.
R b
7 BY MR. PATON:
(Resuming)
M 8
g This is when -- is it usual when a dam is d
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9 complete:-- when a dam has just been finished to have z
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10 l water against it or not?
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Sometimes it does, and sometimes it doesn't.
m "y
12 G
You can't say it's more often one way than c
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E I'4 'I m
A Right, unless you tell me more.
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Where there is not water against a dam when
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h 17 after the completion of the dam?
5 18 l A
Not in my experience.
E l9 g
g So, your answer is that it's not common n
20 practice would apply whether there is water against 21 the dam or not?
22 A
In my experience that is correct.
23 l g
Okay, and how many -- can you approximate, 24 '
generally, how many personal experiences you have where 25 that statement would hold true?
l 1
ALDERSON REPORTING COMPANY, INC.
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234 1
A You mean how many earth dams have I been 2
involved in?
3 G
Yes, and obviously if it's a large number 4
you can approximate.
5 y
A It's quite a large number.
I would say 9
6 more than twenty.
R*S 7
G All right, let me ask you this, in the 3
l 8
year 1980?
d o;
9 A
In the year 1980 the number of dams I have l
h 10 been involved in?
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Yes, sir.
m g
12 A
In 1980 probably not very many -- probably I
O 5
13 two or three..
=
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G In those two or three was any drilling done ej 15 after the completion of the dam?
i j
16 l A
Not to my knowledge.
w h
I7 G
In none of those instances?
f18 A
Not to my knowledge.
e 19 9
G All right.
'Go back either a year or two, a
20 whatever, in your memory.
21 A
I can simplify it.
I do not ever recall 22 drilling in a dam when water was against it.
23 G
All right.
24l A
I do recall drilling to install piezometers 25l in a dam when there was.not water against it, and that ALDERSON REPORTING COMPANY. INC.
J
o 235 l
I was a very special case.
2 g
Do you ever recall drilling in any dam 3
whether there was water against it or not for a purpose 4
other than installing piezameters?
g 5
A No, I don't offhand.
8 3
6 4
Are you familiar with a program of the R
d 7
state of California, Division of Dam Safety?
Al 8
MR. FARNELL:
Will you be more specific?
d E
9 2.
MR. FERRIS:
I think you need to reword O
h 10 the question, too.
=
5 II BY MR. PATON:
(Resuming) 3 f
I2 g
From that statement you don't know what I'm s
5 13 talking about?
m
=
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A I don't know of a program.
California was c
I g
15 ;
the first state in the Unitdd States that had a dam
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16 safety group if that's what you are referring to, w
h I7 l g
You mean to your knowledge, they do not have
=
5 18 a program?
A" 19 g
A They very actively -- I would not call it n
20 a program.
That's the word I'm having problems with.
21 g
Okay.
You say they did not have a program?
22,
A They have a group of people who evaluate 23 dam safety.
I 24 g
Do you'know whether they had a program to 25 i investigate stability of dams?
I ALDERSON REPORTING COMPANY. INC.
236
\\
I MR. FARNELL:
What time?
2 MR. FERRIS:
I think I know what you are 3
asking about.
Because of seismicity in California, the 4
state required that certain dams be investigated.
It 5
j is my recollection that the dams that were investigated 6
were hydraulic fill dams, which are not the type of.
8 7
dam that you have at Midland.
l BY MR. PATON:
(Resuming) d i
"j.9 I
~
G I am sorry, hydraulic what?
c A.
Hydraulic fill dams.
They may have enlarged II beyond that, but that's the part that I'am aware of.
3 k
II G
Explain that, please, sir -- hydraulic fill dam.
3 13
[
A.
It's a type of" dam that has.not been commonly b
I4 used in the United States since the Port Pec'k Dam, 15 which the Corps of Engineers was involved in in the d
I6 late
'30's.
W C
17 g
The soil is made into a surrey, and the 18 surrey is discharged into a pond, and the courser 1:
I' g
particles fall at the sides, and the finer materials 3
stay in the middle.
So, you have a segregation that 21 creates a core with courser materials than the shells 22 of the dam.
1 23 9
In connection with the state of California --
24 the program of the state of California, Division of i
25 Dam Safety, were undisturbed samples taken for lab ALDERSON REPORTING COMPANY, INC.
..r
237 I
testing similar to what's being asked for by the NRC?
2 A
I do not know the answer to that.
3 In projects under the National Dam Safety 4
Program were undisturbed samples taken for lab testing 5
similar to what is being asked by the NRC?
f6 A
My understanding of the National Dam Safety a
R 7
7 Program is that where there is a problem that then E
8 A
additional investigation may be required, but I per-d d
9' j
sonal'ly have not been involved in any single case of that.
C h'
S Your testimony is that under ordinary
=
f circumstances they would not take such?
N A
I believe under ordinary circumstances where I
there is no evidence of a problem, I am unaware that 3
E 14 they require boring.
a 9
15 2
g Do you know where there is indication of a
f16 a problem that they would take borings?
h I7 A
I believe the draft that was prepared by a
N 18 the Corps of Engineers for dam safety in their phase g
two study would make allowance for samples to be taken, 20 but I don't recall if they specifically say boring or 21 l
what.
22 Nor do I recall whether they discuss whether 23 the reservoir is full or empty.
24 '
g off the record.
25li (Discussion off the record) l ALDERSON REPORTING COMPANY, INC.
. ~. -.
238 I
BY MR. PATON:
(Resuming) 2 O
Before you started the surcharge program at I
3 the diesel generator building, what were Bechtel's 4
limits on_ total and differential settlement?
5 g
A For what?
n 5
6 G
seettemene of the dieser generaear butiding.
l 7
+
MR. FARNELL:
For what purpose?
m 0
MR. FERRIS:
You mean recorded in the FSAR d
o; 9I or what?
4 h
10 B*l MR. PATON:
(Resuming)
II G
I am asking you before you started the t
g 12 surcharge program, did you make any determinations as 3
g 13 to what you. felt?
I4 l
A I did not.
k
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15 g
Okay.
I will finish the question so that x
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the transcript reads right.
n M
i I7 Did you make, before you started the surcharge a
f 18 program, did you make any estimate of total and differen-g tial settlement to be expected from the surcharge program?
O A
Not that I am aware of, other than the 21 reference I made to you yesterday.
22 g
About the.six to eighteen inches?
t 23 -
3 k
Of Dr. Peck's statement in a meeting, but i
24 there was no calculation.
25!
O Did you make any estimate or calculation ALDERSON REPORTING COMPANY, INC.
239 1
concerning how much total or differential settlement 2
the building could tolerate?
3 A
I did not.
4 g
Did'anyone?
g 5
A And I would not, I am not a structural 8
6 engineer.
I g
7 g
Did anyone at Bechtel make such 2 study?
3]
8 A
I do not know.
dy 9
g Prior to the surcharge to your knowledge did 10 I anyone est.Luate the amount of cracking that <.he building l
11 l could tolerate?
m I
12 A
I do not know the answer to that a it t.e r.
3 l
13 That's a structural problem.
l 14 g
Do you have any opinion as to whether it is 15 important to establish settlement limits prior to 16 starting the sur. charge program?
g M
d 17 MR. FARNELL:
Are we talking about the 5
18 Midland surcharge program, and if we are, which I E
19 assume we are --
g 20 MR. PATON:
You are right, we are.
21 MR. FARNELL:
Then it has been asked and 22 answered and gone into in depth.
23 MR. PATON:
No, I haven't.
I really haven't 24 asked him his opinion whether or not it's important 25,
to establish that limit.
He said he didn't know whether i
ALDERSON REPORTING COMPANY, INC.
240 1
they were established.
2 MR. FARNELL:
I think that was dealt with 3
yesterday.
4 1
BY MR. PATON:
(Resuming)
=
5 G
Do you have any opinion on that?
6 A
No, except for the opinion I expressed R
R 7
yesterday that it was my opinic.1 that Dr. Peck made M
l 8
his statement of six to eighteen inches in relation'to d
i d
9 z.
the need for the instrumentation taking care of whatever 26 10 settlement would. occur rather than the precise settlement.
[
II G
My question is do you have an opinion?
y 12 A
well, I made that statement because I think 4
g 13.
it is a valid statement.
That is my opinion.
m i
m i
5 14 I G
Okay, Dr. Peck's statement -- okay.
I 15 In other words, you adopt his statement?
j 16 A
I do not know that that's the reason he w
17 I made the statement, but it is my opinion that it is, 18 and I think that it's an important consideration.
E 19 G
You are referring to the statement you made 20 yesterday about the six to eighteen inches?
21 A
Yes.
22 0
My question is do you have a personal opinion 23 as to whether it is important to establish settlement 24 limits?
25 A
It's important for the instrumentation to l
l I
ALDERSON REPORTING COMPANY, INC.
241 I
establish broad limits.
2 Okay, and I understand your statement yesterday 1
3 had to do with the ability of the instrument to measure 4
the settlement.
5 A
Yes, and that's for the same reason that I 6
am making that statement right now.
R 7
G In the Midland case is it an important safety A
j 8
consideration to establish prior to the surcharge program d
9 what the settlement 10 MR. FARNELL:
What do you mean by safety?
II MR. FERRIS:
What are you talking about?
3 y
12 It's not clear to me what you are talking about.
b 13 l 5
MR. PATON:
I am talking about the Midland m
l 14 Nuclear facility, and I am talking about the diesel 15 generator building, and I'm asking you whether it is j
16 an important safety consideration --
m 4
h I7 MR. FERRIS:
I thought you were talking
=
y
.18 ' about the preload.
c I9 MR. FARNELL:
I don't know what you mean by 20 safety consideration.
21 l
MR. PATON:
You say you don't know?
MR. FARNELL:
I don't know what you mean 23,
by safety consideration.
24l r
MR. PATON:
You don't know what I mean?
e 25 Okay, I'm going to let the record stand right there.
1 ALDERSON REPORTING COMPANY, INC.
242 1
You say you don't know what I mean by safety considerations.
2 That's okay.
3 MR. FARNELL:
Safety considerations with regard to the diesel generator building, yes.
5
=
3 MR4 PATON:
I just said that.
I 6
BY MR. PATON:
(Resuming)
_e R
7 G
Do you understand the question?
n E
8 A
I don't understand the question, because I 9
I i
thought you were talking about preload fill, and then o
,a g
10 you started talking about the building.
z
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11 g
Could you please rephrase your question so d
12 '
g that I understand which it is you are talking about?
d 13 i
G
'Okay.
I am talking about do you feel it E
14 '
g is an important consideration prior to imposing the q
9 15 :
j l surcharge to establish what the maximum settlement could 16 l
~
be that the building could take?
d 17 )
g A
The maximum settlement may not be important' 18 The differential settlement could be important with E
19 l
regard to cracking.
20 g
Fine.
Now let me ask you as to differential 21 settlement, do you consider it important to establish I
prior to surcharge program what the maximum limit of I
23 differential settlement would be resulting from the I
24l!
surcharge?
25 '
MR. FARNELL:
Could you read that back, please?
ALDERSON REPORTING COMPANY, INC.
243 1
(Question read) 2 MR. FERRIS:
I don't believe it is that 3
significant.
1 4
BY MR. PATON:
(Resuming) 5 g
g Did you do it?
9]
6 A
I did not do it. -
3 7
0 Did anybody at Bechtel do it?
A]
8 A
I do not know whether they did or did not.
d q
9 O
Do you know who in Bechtel would know whether 10 ithat was ever done?
II A
Well, I believe Dr. Afifi might know.
m f
I2 0
Okay.
Do you think it's important prior to e
5 13 the imposition of the surcharge to establish maximum a
mg 14 allowable cracking limits that you might expect from the
$j surcharge program?
15
=
d I0 A
For the diesel generator building?
w h.
17 0
For the diesel generator building.
y 18 A
Well, the diesel generator building at E
I9 g
Midland is a very husky building, and for that reason, 20 I do not consider it was a very important consideration.
II g
So, was it not done, or was it done?
I 22 assume from your answer it was not done?
l 23 l i
A To my knowledge, no.
24 0
You say it's a very husky building?
25 i A
Yes, it's an unusual building in that it I.
l ALDERSON REPORTING COMPANY, INC.
244 1
is designed to protect the diesel generators from turbine 2
missiles and tornado missiles.
It's unusual in a 3
building in that it has quite thick walls and.is quite 4
rigid.
e 5
g G
You are' indicating that for that reason --
5 6
okay.
You have stated your answer, g
d 7
g To your knowledge is there any cracking in the l
8
,3 diesel generator building at this time?
d 9
l z
A I don't know at this time.
I did see cg 10 cracking prior to placing the preload.
z 5
11 j
G Do you know whether when a building is cracked d
12 whether that means allowable standard code limits have 9=
13 E
been exceeded?,
E 14l y
A You would have to ask a structural engineer that.
2 15 g
G Okay.
A fair answer.
?
16 Do you know whether Bechtel has completed any G
17 'I g
analysis of the cracks at the diesel generator building?
5 18
=
A I don't know what analyses have been done on l
19 l the cracks.,
20 I g
Do you know whether any analysis has been i
21 done?
22 A
I believe some analysis must have been 23 I done because I heard Mr. Rotz discuss this subject at 24 j Midland in February of this year.
I believe it was i
25 l February of this year..
ALDERSON REPORTING COMPANY. INC.
i 1
245 I
l 0
Okay.
That terminates the deposition.
MR. FARNELL:
I would like to take a few 3
minutes.
I may have some questions.
4 (Short recess taken)
MR. FARNELL:
Back on the record.
I have a a
6 few questions.
_n 8
7 EXAMINATION SY COUNSEL FOR APPLICANT n
5 8
a BY MR. FARNELL:
d6 9
g g
Mr. Ferris, do you recall yesterday responding o
i g
10 1
z I to a question by Mr. Paton concerning whether consolida-
=
11 l E
l j
tion tests are a reasonable method to predict settlement?
d 12 z
A Yes,.I do.
S 13
~
5 l
g Do you recall your answer to that question?
E 14 '
g l
A I said they were reasonable.
E 15 g
g Is that answer decendent on any factors?
16 l
l A
Yes, it is.
The question is a general 61:7 question and I responded to give a general answer.
w=
4 18
=
I think in instances where you would have 19
)
better data, then I would not use the consolidation 20 test, for specific cases like the diesel generator 21 building at Midland where we have better data than we 22 would get with consolidation tests on undisturbed samples.
23 The case I was referring to, the general 24ll cases where you go t.o a site and there is no information, i
25 then that'is the only basis for making an evaluation of ALDERSON REPORTING COMPANY. INC.
246 I
settlement.
2 g
Do you recall yesterday testifying concerning 3
soil stratification in regard to underpinnings for 4
service water structure and other structures at Midland?
5 A
Yes, I do.
]
6 g
Was it your testimony that you needed to 7
know the soil stratification prior to making design M
j 8l underpinnings for these buildings?
d 9
9 A
Yes, I was relating to the pilo foundations, i
10 and to do that you need to know where the barium stratum II is, and in my reference to stratification, I was f
12 talking,in gross terms in relation to fill as one stratum.,
4 l
13 and.till or any layers below that as additional strata.
=
E I4 g
Do you need to know the substratum prior to
{
15 designing these underpinnings?
a 16
'I W
A You must know the stratum into which the w
I
.h 17 piles are going to be founded.
18 G
My question was whether you needed to know E
I9 g
any substratum?
20 A
Ch, beneath that?
21 or above that.
22 A
I don't believe so at the Midland site.
We 23l already have a lot of-information.
24 g
Do you recall yesterday some testimony you 25!
gave concerning borings and initial site investigation?
ALDERSON REPORTING COMPANY, INC.
s 247 I
A Yes, I recall discussing that briefly.
2 4
was it your testimony that it was normal 3
practice to do borings to determine soil characteristics 4
on an initial investigation of a site?
g 5
A Yes, it is very normal practice.
S 3
6 G
Is it normal practice to do borings after n
g 7
construction has.been done or is partially completed n]
8 on a site?
d c
9 A
That is unusual insofar as soil exploration.
h 10 4
Do you consider the NRC request for borings
'l II to be unusual?
m I
I2 A
I believe it is unusual at the Midland site.
f g
13 G
It would not be responded to in normal l
14 practice?
g 15 A
I believe that their borings refer to construction z
g' 16 fixes at a number of locations, and we have provided means d
h I7 l for checking those fixes by othar and better procedures.
f18 G
Do you have an opinion concerning the E
19 9
stability of the dam at the Midland site?
M 20 A
No, I don't.
21 4
Do you consider the dam to be stable?
22 A
Yes, I do.
)
23 l 0
That's all the questions I have.
t 24 MR. PATON:
Okay, I have a couple of questions 25,'
now.
I I
ALDERSON REPORTING COMPANY, INC.
248 e
EXAMINATION BY COUNSEL FOR NRC 2
BY MR. PATON:
'3 G
Mr. Ferris, I want to ask you about your 4
response to Mr. Farnell's question about whether the i
5 g
staff's pending request for borings is unusual.
1 6
believe that you responded that it was an unusual J
I 7
j request?
l 8
i A
Yes, I did.
.d d
9 4
G And the reason is that you have a better way i
i 10 l l
l to provide the information you believe the. staff wants,
{
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l is that correct?
(
12 l
A I believe so, yes.
l 13 l
B G
Don't you consider that since the subject l
14 l being addressed is a nuclear power facility that w
j 15 even if the information you have provided is better, j
j l
16 l l
isn't it appropriate that you also submit the other d
17 information to use.as verification of the information 4
=
18 you have submitted?
i O
t 19 l
A You mean the horings?
l G'
The borings.
21 A
A major problem I have with the borings is that it may confuse matters, and I believe I discussed e
i 23 I that yesterday.
l 24 i l
4 okay.
You're afraid it may confuse the NRC, i
25 I
is that correct?
i ALDERSON REPORTING COMPANY. INC.
249 1
A No, I am afraid it may confuse the NRC or 2
anybody looking at it.
3 G
Don't you think that that matter would be 4
hatter decided by the NRC7
=
5 A
I believe we are the engineers on the plant, h
]
6 and it's my opinior that it's not -- I believe it has G
7 a potential for creating a problem.
Ml 8
4 Okay, but NRC does have s,ome function that d
o; 9
calls on them to review the safety and to make an 10 assessment of the safety of this facility.
II MR. FARNELL:
This whole line of questions --
3 g
12 there is no foundation.
I mean you are asking him to 5
5 13 tell us about what the NRC's function is, and it's a
l 14 up to the NRC.
kj 15 !
MR. PATON:
Exactly, and I would like to state a
d 10 on the record why.
He just stated very, very clearly w
6 17 l that he has made a judgement that the NRC does not 18 need this informstion.
E 19 MR. FERRIS:
Because we provided better I
20 information.
21 BY MR. PATON:
(Resuming) 22 G
Okay.
So, it is your opinion that the NRC i
23l does not need this information?
(
24 A
That is my personal opinion.
I 25 0
And it's your opinion that the NRC is in ALDERSON REPORTING COMPANY. INC.
l l
l 250 l
I error in asking for this information?
2 A
I do not think that it is in the best interest 3
of the NRC to ask for that if it is going to create a f
4 problem, and it is for that reason that we have discussed 8
this matter.
g G
Do you think the NRC thinks that that boring E
7 information is going to create a problem for them?
n A
I don't know --
d li d
9 MR. FARNELL:
I object to speculation.
g 5
10 l BY MR. PATON:
(Resuming) g
=
,5 4*
You don't know?
N A
I can't think for the NRC.
5l 4
I submit that that's exactly what you are 3
14 d
doing.
w 2
15 g
Mr. Ferris, with respect to the word unusual,
?
16 4
g would you describe the soil settlement problem that d
17 f exists at the Midland facility as unusual?
mz k
18 A
Yes.
Maybe I should have used E
19 l
the word unnecessary rather than unusual, but I would 20 say it is somewhat unusual -- the soil condition in the fill.
i G
To your knowledge has.Bechtel ever been invdived in a project with any problems similar to what i
exists at Midland?
25 A
We have had compaction problems Lafore.
i l
ALDERSON REPORTING COMPANY. INC.
251 1
G Have you had any compaction problems at any 2
site similar to the extent of those at Midland?
3 A
Not to the extent of those at Midland.
4 G
No further questions.
5 MR. FARNELL:
Fine, I have no further questions.
3 0
(Whereupon, at 11:45 a.m.,
the taking of the E
8 7
instant deposition ceased.)
3l 8
I d
d 9
i=
10 E
l Signature of the witness j
11 m
I I2 SUBSCRIBED AND SWORN to before me this day of
]
13 a
1980.
8 l
14
'i 15 G8 j
16 Notary Public d
i My Commission expires:
g 17 i w
E a
m 18 E
19 R
'l 20 21 22 23,
4 2i 1
~
25 1
f ALDERSON REPORTING COMPANY, INC.
r 252
'I CERTIFICATE OF REPORTER 2
J UNITED STATES OF AMERICA
)
)
ss.:
3 STATE OF ILLINOIS
)
4 I,
PATSY ANN STROH, the officer before whom 5
the foregoing deposition was taken, do hereby certify 3
O that the witness whose testimony appears in the foregoing n
I deposition was duly sworn by me; that the testimony of 8
said witness was taken by me by stenotype and thereafter dhI reduced to typewriting under my direction; that I am 10 neither counsel for, related to, nor employed by any of El II the parties to the action in which this deposition was ll 12 taken, and further that I am not a relative or employee b
13
.j of any attorney or counsel employed by the parties I4 thereto, nor financially or otherwise interested in the 15 outcome of the action.
16 g
j ti 17
,**,i y
,?
,f
=
s w a
g j,
Notary Public in and for the State.pf Illinois b
II g
My Commission expires July 27, 1983.
20 21 22 23,
e 24 25 l REN RgpORTING COMPANY. INC.