ML20094H916
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lovember 19, 1930 L
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!!ote to William J. Olmstead, Assistant Chief Hearing Counsel e
St'BJECT: 11IDLAND DEp0SITI0il MITT!ESS Ue plan to take the depositions of several Bechtel employees in Ann Arbor beginning on Tuesday, December 9,1930. One of the witnesses the Staff would like to depose is Mr. P. A. ?!artinez, forcer Midland Froject itanager for Bechtel.
I have been told that Mr. "artinez is now enplay.d by Bechtel in !!exico and t!ut they have no intention of bringing hiu back for a deposition.
o He were initially notivated to take Mr. ::artinez's deposition because of his position as project canager. He thought he t'ould be as knowledgeable as anyone with respect to the errors nade in soil placement.
Oar interest in Mr. !!artinez increased after we took the deposition of Dr.
Sherif Afiff, Chief Geotechnical (soils) Engineer for Bechtel. With respect to a number of subjects on which we thought Dr. Afiff should have answers, he told us that project management would know that. Examples of this are:
1.
Uith respect to tne appropriate compaction criteria to be applied in placing fill, the Region III Inspection Report shows a 3-year period of mass confusion in Bechtel as to the appropriate criteria. At the Leginning of this ?-year l
period, Dr. Afift advised projecti Sanaccrent what he thought the appropriate criteria should be, but when questioned as to why it was not followed, we were refcered to project canagement.
l 2.
Dr. Afifi testified that he cade an esticata of shcar wave
-l velocity of 700 feet per second. !ie know that the shear
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l wave velocity used in the seismic design of Category I structures was 1350 feet per second. This higher value is in some respects non-conservative. Later infornation re-vealed that Dr. Afiff's original 700 feet per second esti-mate was more accurate than the 1350 feet per second used in design. When asked why the wrong value was used, Dr.
Afift referred us to project nanagerent.
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3.
In the PSAR, Consurers comnitted to removing loose natural
- i sands with relative density less than 75%. Licensee never
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j; carried through on this cornitnent. When we inquired of Dr. Afifi about this, he referred.us to project v.anagement.
8408140158 840718 PDR FOIA RICES 4-96 PDR
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Darl 1:ood. (Project fianager) and John Gilray (quality Assurance Branch flidland (Soils) revicwer) participated in a r.aating with Occhtel in early 1979 in which they were told that Dechtel was considering rt.uoving !!r.
I'*tinez from the Midland Project because ther7 were problems with his nlatic.nship with Consuaers. At 4 bout the tir.a of this meeting, John
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cilray was told that Martinez was not a strcng ranagar and th..t Cechtel
. cxpected improvement because !!artinez's prospectice raplace, ment (John Putgers) had the qualities of technical cogd.caca and etraag managenent abilitics with respect to day-to-day probl :s.
I cannot make a strong recc:r.endation on C ".hc:i-a Ptil u;.' o taking ifr. !'artinez's deposition. He was in a positica to ?. ni *.t all t'io prob-Ic.ms were, but our experience to date in the d.psit.;er.s is
- it witne :es who should know answers frequently do not know.
g William D. Paten, Attorney Office of the Executive Legal Director
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WDPat'on: cat 11/19/80 t
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