ML20141P144
| ML20141P144 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/14/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#186-486 OL, NUDOCS 8603190057 | |
| Download: ML20141P144 (118) | |
Text
OPIGITAT l'
O UMIED STATES NUCLEAR REGULATORY COlVEvIISSION IN THE MATTER OF:
DOCKET NO:
50-424 OL 50-425 OL GEORGIA POWER COMPANY, et al.
(Vogtle Generating Plant, Units 1 and 2)
O LOCATION:
WAYNESBORO, GEORGIA PAGES:
709 - S26 DATE:
PRIDAY, MARCII 14, 1986 0 I r
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.O Ac-FEDERAL REPORTERS, INC.
Cffic:al P.:eners moa t'<o057 060314 m.N d cam kee f'Dl' ADocg 09000a24 Washington, b.C. 20001 I
PDR (202)347-3700 NADONWICE COVERACE
709
]
UNITED STATES OF AMERICA I\\']
2 NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD 3
- - - - - - - - - - - - - - - - -x 4
In the Matter of:
5 Docket No. 50-424 OL GEORGIA POWER COMPANY, et al.
50-425 OL I
6 (Vogtle Generating Plant, Units 1 and 2) 7
- - - - - - - - - - - - - - - - -x 8
Burke County Office Park 9
Auditorium West 6th Street p)
Waynesboro, Georgia 30830 Friday, March 14, 1986 jj I? j The hearing in the above-entitled matter convened at
[/D s-13 9:30 a.m.
14,
BEFORE:
n e
15 ll U
JUDGE MORTON B. MARGULIES, Chairman 16 U)
Atomic Safety and Licensing Board Panel j
U.
S. Nuclear Regulatory Commission 17 [
Washington, D. C.
20555 l
JUDGE GUSTAVE A.
LINENBERGER, JR., Member l
18 l' Atomic Safety and Licensing Board Panel I
U.
S.
Nuclear Regulatory Commission I
,9 Washington, D.
C.
20555 a
l 20 p JUDGE OSCAR !!. PARIS, Member Atomic Safety and Licensing Board Panel 21 U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 22 l
21
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ske Fedeent Heporters, Inc 25
-- continued --
u4-710 1
APPEARANCES:
j 2
On behalf of the Applicant:
BRUCE W. CHURCHILL, ESQ.
3 DAVID R.A. LEWIS, ESQ.
Shaw, Pittman, Potts & Trowbridge t
4 1800 M Street, N.W.
r Washington, D.C. 20056 5
CHARLES W. WHITNEY, ESQ.
HUGH M. DAVENPORT, ESQ.
6 Troutman, Sanders, Lockerman & Ashmore 1400 Candler Building 7
Atlanta, Georgia 30043 8
On behalf of the Nuclear Regulatory Commission Staff:
9 BERNARD M. BORDENICK, ESQ.
LEE DEWEY, ESQ.
10 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission c
Washington. D.C. 20555 i
yy l
f 12 On behalf of Intervenors:
O RAvMOND TiNotE i
13 WILLIAM F. LAWLESS l
Georgians Against Nuclear Energy i
14 1253 Lenox Circle Atlanta, Georgia 30306 15 16 17 18 19 20 21 22 23 O
24 WFesterd Reportees, Inc.
25
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'C O N T E N T S 711 p
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WITNESS DIRECT CROSS REDIRECT RECROSS EXAM i
y 3
William F. Lawless i
by Mr. Tingle 719 4
by Mr. Davenport 721 l
by Judge Paris 741 5
by Mr. Davenport 742 by Judge Paris 752 l
by Judge Linenberger 754 by Mr. Tingle 757 i
by Mr. Davenport 758 7
Lyman Heller 8
Raymond Gonzales
't by Mr. Dewey 760 by Mr. Lawless 766 9
by Judge Paris 783
- " 9'
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- 9'"
10
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Thomas W. Crosby 11 Lewis R. West i
Clifford R. Farrell
'f l
12 Stavros S. Papadopulos by Mr. Davenport 789 l
by Judge Paris 802 13 by Mr. Lawless 803 by Judge Paris 814 14 l
by Judge Linenberger 816 i
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16 17 18 I
19 20 I
l 21 l
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l 23 24 w r e w s n.p <wei,Inc.
25
i 26116.0 BRT 712 (n;
1 PRQCEED I, f) G S_
2 JUDGE MARGULIES:
Please come to order.
3 Mr. Tingle, are you representing GANE here today?
4 MR. TINGLE:
Yes.
S JUDGE MARGULIES:
I don't know if you have filed a 6
written appearance in this proceeding.
You made an oral 7
appearance on the record.
llave you tiled a written 8
appearance?
9 MR. TINGLE:
No, sir, I have not.
10 JUDGE MARGULIES:
Would you do so before the day 11 is over.
The reporter will give you an appearance form and 12 we will include that in the record.
13 We heard argument last night on Applicant's motion 14 to strike the testimony of William Lawless on Contention 7.
15 The Board reviewed the matter last night and our ruling is as 16 follows:
17 On the matter of timeliness, the filing was not in 18 strict conformity with the time requirements.
The filingo 19 did come in a short time late.
We did find that no prejudice 20 resulted by the late tiling and we will not consider that as 21 a basis for denying the submission of the statements.
22 In reviewing the two statements, one being the 23 supplement of December 15, 1985 and the other the statement 24 of February 23, 1986, we tound come material that was 25 relevant, some that was irrelevant, and there is come that n
v ACE FEDERAL REPORTERS, INC.
i 202 347 3700 Natlon*ide Coverage an.33M646
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falls into a gray area.
2 In the motions there are allegations that some of 3
these items in the gray area are vague.
Perhaps they are.
4 We believe the solution is to get an explanation as to what 5
is meant and, if it ecntinues to be irrelevant, the parties 6
will have an opportunity to once again move to strike those 7
areas.
8 We will now go through the documents and state 9
which of the areas should be stricken.
We will start with 10 the statement of December 15, 1985.
We find that pages 1 11 through 6 should be stricken as irrelevant.
That portion of 12 page 7 should be stricken except for the last sentence which p
13 reads, " Assuming that grouted wells under the VEG power block J
14 are one complete solid," and going onto page 8, to the end of 15 that paragraph.
That will not be stricken.
It is unclear 16 whether this is new matter or just what the Intervenor is 17 proposing.
We will permit that to remain in the record as 18 part of his testimony.
19
'1 h e following paragraph on page 8 will be 20 stricken.
21 The matter of leakage of radioactive water from 22 the auxiliary building on page 8 will be stricken, through 23 its continuity on page 9, 24 Hazardots chemical wastes will be stricken.
25 contamination of Cretaceous aquifer at SHP will be b
ace FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 80t>33& % t6
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I stricken on page 9, through that portion of page 10.
2 The matter of groundwater travel time will be 3
heard.
4 That completes the ruling on the supplemental 5
document.
We will now proceed to the document of February 6
23, 1986, and ra ther than starting with the summary, or what 7
has been labeled summary, we will move to page 4, the 8
introduction.
I use the numbers of pages.
The documents as 9
submitted were not numbered and we took the liberty of 10 numbering the pages.
It might be helpful if the parties 11 number their pages so that we will have a point of reference, 12 starting with the number 1 for the first page of each O
13 document.
U 14 On page 4, the introduction, it is just that and 15 we find no basis to strike it.
16 Page 5, the " Adequacy of Geological /llydrological 17 Exploration," that page will be stricken, including on page 6 18 in the first line, the words, " power block (Papadopulos 19 1986)" will be stricken.
The remainder of that paragraph 20 will remain in, as well as the following paragraph.
We are 21 uncertain as to what Mr. Lawless means, and want to consider 22 it.
23 Going down to the bottom of page 6,
" Uncertainty 24 in data on Marl Thicknoss and Permeability," we will strike 25 that which appears on page 6 and the first sentence on page 1
ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800-34%M
26116.0 BRT 715 7LJ 3
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2 As Staff proposed, we will follow Staff's argument 3
that the centence starting, "On the one hand, the marl must 4
be satisfactorily mapped" and goes on "but on the other, 5
breeching the integrity of the marl in order to monitor the 6
marl may be self-defeating by adding the potential for 7
additional contaminant flow pathways," that will remain in.
8 The sentence following will be stricken.
9 As to the direction of groundwater flow, 10 Intervenors say they have nothing to add.
There is no reason 11 to strike that.
12 on aroundwater travel time, that portion appearing f]
13 on page 7 will remain in.
v 14 On page 8, that portion that will remain
'n starts 15 with the first sentence, " potential for rapid water transport 16 through fissures in the backfill material exist."
That will 17 remain in.
The remainder of that paragraph will he out.
la The last paragraph, which constitutes a single 19 santence, will remain in.
20 Moving on to the summary, which is not necessarily 21 a summary in that it includes some material that is not in 22 the body of the document, we will permit number 1 to remain 23 in, appearing on page 1,
which covers incutficient 24 exploration, which is a matter that in our memorandum and 25 order we accepted as a 1itigable portion of the contention.
%J ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage im3)MM6
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1 2 is out, e
2 We believe paragraph 3 may relate to that 3
appearing on page 7 and runninc on to page 8 of the 4
supplement and for that reason we will leave it in.
We 5
believe that it is related.
6 4 is out as being irrelevant.
7 5,
we believe Mr. Lawless is speaking about 8
standard deviations in the inatter of. laboratory analysis and 9
for that reason we will leave 5 in.
l l
10 6 is out.
11 7 is out.
12 8 is out.
l 13 9 is out.
l 14 Au to 10, we are unsure what Mr. Lawless is 15 speaking about and for that reason we will leave it in.
16 1 is considered relevant.
12 is considered 17 relevant.
18 That concludes our ruling based on the arquments 1
19 last nicht.
The parties will have an opportunity at the 20 appropriate time to move to strike the testimony of 21 Mr. Lawless.
22 MR. LAWLEDG:
Mr. Chairman -- I think otar nike is 23 off altogether.
24 JUDGE MARGULIES:
We can hear you, Just speak up.
25 MR. LAWLESS:
I had difficulty with your comments AO I
ACE. FEDERAL REPORTERS, INC.
202147 37m Nation *lde Coverage m))we
26116.0 BRT 717 t
'l
1 on page 6 and 7.
Could I ask you to quickly repeat it?
2 JUDGE MARGULIES:
6 and 7 of which document?
3 MR. LAWLESS:
The last document which you were 4
referring to.
I think I have them all but I'm a 11ttic bit 5
confused.
Dacking up to page 5, just to double-check, you 6
atruck page 5?
7 JUDGE MARGULIES:
I struck page 5.
8 MR. LAWLESS:
And then over to 6?
9 JUDGE MARGULIES:
I did not strike the portion of 10 the paragraphs starting, "The average hydraulic conductivity 11 K calculated" --
12 MR. LAWLESS:
Is that on page Q
13 JUDGE MARGULIES:
Tha top of page 6.
The C
14 remainder of that parauraph and the tollowing paragraph are 15 in.
The remainder la atricken, starting with " Uncertainty in 16 data on Marl Thickness and Permeability."
17 MR. LAWLESS:
The middle paragraph, "Further, the 18 full power block" -- wan that stricken?
19 JUDGE MARGULIES:
That la in.
20 MR. LAWLESS:
And then page 7?
21 JUDGE MARGULIES:
Page 7, in the top paragraph, 22 that portion that Ic in la that portion that Staff arqued 23 abould be in, "On the one hand, the ma rl nuat" --
24 MR. LAWLESS:
All riqht.
25 JUDGE MARGULIES:
Do you have that?
O,_
ACE. FEDERAL REPORTERS, INC.
202 347 37(x)
Nationwide Coverage NWA33MM4
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i MR. LAWLESS:
Yes, sir.
And then statistical
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2 treatments, is that the last sentence -- strike --
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3
' JUDGE MARGULIES:
Statistical treatments is I
4 stricken, that's right.
Direction of groundwater flow is in.
I I
S MR. LAWLECS:
Through page 0?
6 JUDGE MARGULIES:
Page 8 is stricken, except for 3
i 4
j 7
the last sentence which is a separate paragraph -- I'm sorry.
l 0
MR. LAWLEGS:
The first sentence carrying over?
f j
1 1
I 9
JUDGE MARGULIEC:
The first sentence reading,
)I i
10
" Potential for rapid water transport through fissures in the I
i 11 backfilled material exists" iu in.
The remainder of that l
l 12 paragraph ir out.
13 MR. LAWLESC:
Thank you.
14 We will leave 9 in.
I don't know, at this point 1
j 15
-- we hadn't looked at it last night -- how it relates to the i
r 16 remainder of the documents.
All it is is a citation of.
l l
l 17 references.
i l
10 MR. LAWLESS:
Yes.
Page 9.
I understand; yes, f
1 19 sir.
I 20 MR. TINGLE:
Mr. Chairman, could I ask just a f
j 21 procedural <1uestion?
At what point is the decision of the
)
22 una 1 on this matter appealable?
)
23 JUDGE MARGULIEG:
I wish you would speak to Staff I
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24 about matters of procedure and hew to handle things of that l
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1 MR. TINGLE:
Thank you.
2 JUDGE MARGULIES:
Staff has agreed to provide you 3
with guidance on how to proceed.
4 Are you --
S MR. TINGLE:
Yes, sir.
We are ready to continue.
6 JUDGE MARGULIES:
Will you please step up and be 7
sworn, Mr. Lawless?
8 Whereupon, 9
WILLIAM F.
LAWLESS 10 was called as a witness and, having first been duly sworn, 11 was examined and testitied as follows:
12 DIRECT EXAMINATION 13 DY MR. TINGLE:
11 Q
Mr. Lawless, would you please give your name and 15 address for the record.
16 A
My name is William F.
- Lawless, L-a-w-1-e-s-s.
17 Home address or business?
Or does it matter?
I'm at -- an 18 assistant professor of. mathematics at l'aine College in 19 Augusta, Georgia, at 1235 15th Street, 30910, 20 0
Mr. Lawless, did you present this document dated 21 February 23, 1986 entitled, "Intervenors' Testimony before 22 the Atomic Safety and Licensing Board, Contention 7, 23 Groundwater Contamination," to this Daard?
24 A
As testimony, yes, I did.
With an attachment to 25 it.
U ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nation *ide Coverage 800 34fM6
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1 Q
Do you have any corrections to this document?
2 A
No, I do not.
3 MR. TINGLE:
I guess he is ready for cross -- oh, 4
I'm sorry.
Could this document be incorporated in the record 5
as if zead?
s 6
JUDGE MARGULIES:
When you say "this document,"
7 you mean the document of February 23, and the document of 8
December 15, 1985 with those portions stricken that were 9
previously ruled on?
10 MR. TINGLE:
Yes, sir.
Thank you Lor the 11 correction.
12 JUDGE MARGULIES:
Is there any objection?
(V) 13 MR. CHURCHILL:
No objectian.
14 JUDGE MARGULIES:
The der.uments will be bound to 15 the record as if read.
16 (The documents follows) 17 10 i
19 20 21 22 23 21 O
V i
ACE FEDERAL REPORTERS, INC.
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J.E.J.
February 23, 1986 United States of America Nuclear Regulatory Commission l
l In the Matter of Georgia Power Company, et al. (Vogtle Electric Generating Plant, Units 1 and 2)
Docket Nos. 50-424 (OL), 50-425 ux.,
Intervenors' Testimonv Before the Atomic Safety and Licensino Board March 11. 1906: Contention 7.
Groundwater Contamination Summary The summary includes groundwater contamination comments friam this
- document, and from intervenor documents previously preset 1ted to the ASLB board.
/
1.
The hydrogeologic data collected by VEGP appears to be in-
}
adequate for a number of reasons, e.g.,. insuf ficient enr91orationn
1 l
no inferential treatment of the data, and insufficient data.
i a
een no statistici tr steent on therNeint sc:ol-groundwater.m/
h lected a
thickness and permea' 11 onitor1ng sta.
.a-i 3.
The settlement of the earl may lead to, a reduction in the in-tegrity of the earl and, as a result o'f tho' deformation, may provide pathways for contamination of the pguifers under VEGP.
~
O
,4 The numerous wells and other structures through the suidee X
/
ubsurface soils may-become pathways for contaminants to and s
breech th M
gh the data indicates not exclusively so, Dupont stulated that we (sings were the pathway for the, contamination that has occurred at the SRP.
5.
The standard deviations of the hydraulic conducti vi ties recently collected for subsurface soils under the VEGP power block exceed customary and acceptable l evel s, s#
~%
7 6 I The well-grouting method "ed-W to cl o'se cov p gav 11 voids (Intervenors'-
- wells, may Analysis.
- t
/
_7-7.
NRC' Staff slidd1'd providstgroundwater%taminatien resulth l
from all other NRC 11 e acilities in.
or the public
~
~
" i,.
l i'4
,4
'?O r
t:
f licensing process / procedures on the potential for groundwater contamination.
f 1
B.
The VEGP groundwater itoring program's first monitoring reportwasrecentlyreceive[b intervenors, but without chemica
/
arjalysis of any of the monitor wells.
Monitoring result s chemical a a/
without lysis of chemical hazardous constituents is deficient and/ nadequate.
The adequacy the VEGP baself can not be ponfirmed without this data., VE should not be al -
lowed to ope /
1 rate without first publishing a
c rent chemical i
analysis of the groundwater.
)
i.
9.
The VEGP area already receives significant levels of tritiOm f
and strontium-90 released from the SRP (Lawless, 1985).
l
~
l
- 10. The improved surf ace runof f and apparently significantly dif-ferent K's between the power block and surrounding area subsur-face soils may be a cause of some concern.
1 11.
The groundwater travel time calculated by VEGP could lead to a
significant undercalculation of the actual travel times as was I
done by SRP.
Whereas VEGP is attempting to improve its hydrogeologic
- data, intervenors are not O
satisfied with the data
{
i at this point.
/
{
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12.
Intervenors agree with the ASLB Ruling on the direction of groundwater flow and have nothing more to add at this time.
O Introduction In the NRC Atomic Safety and Licensing Board's (ASLB) Memorandum and Drder of November 12, 1985, Ruling on Motion for Summary Dis-Groubdwater Contamination, position of Contention 7
re i
hereinafter referred as the ASLB Ruling, jheASLBdeniedthemo-tion to strike except for 5' genuinejesuesofmaterialfact raised by intervenors.
In accord with the request by the ap-()
plicants for Plant Vogtle (VEGP),
the ASLB did agree to strike all other'intervenor issues with respect to the groundwater centention.
Subsequently, the ASLB has requested testimony from each of the parties on this contention.
The testimony for inter-
)
I venors on the groundwater contention, as requested by the ASLB, j
is contained herein or has been previously submitted to the ASLB in prior documents.
The discussion by intervenors of the November 12th ruling by the ASLB was submitted to the ASLB December 15,1985: Analysis of the Atomic Safety and Licensino Board's November 12.
1985 Memorandum and Order (Rulino on Motion for Summary Disposition of Contention
' ()
7 re: Groundwater Contention).
This discussion will be referred
/
to in the intervenors' testimony as the intervenors' Analysis..
Other information that will be referred to is the Intervenors' Response to Aoolicants' Motion f or Summary Di sposi ti on' of Conten-M_qn_Z, described as,the interveners' fhrMsgY%
g O
dequacy of Geological / Hydrological Explorationj
/
/
Intervenors had previousl y alleged that applicants had not N
statistically treat;ed the VEGP hydrological,/datas applicants I /
agreed (Rulina,
- p. O),
but the ASLB stat'ed the burden of proof
\\
f was on the interven t
show that such treatments were No
/
customary, or that the VE data was,, flawed.
This suggests that the intervenors, with negl gible' resources, by default are
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a a i=>-
- =
ar ta-r'aia
=+
aati= a*
a.ia riaa practices or hydrological data, e pecially it such analysis even-N tually finds deficiencies [
and that only customary industrial nuclear practices are tho' acceptable p actices. Both of these, if truly suggested, coulc lead to the 1 censing and the improper operation of another nuclear facility in the Central Savannah River Area (CSRA) w'ith the: potential to dama the local environ-ment as has the/ avannah ' River Plant (SRP)
(Lawless, 1985).
- Instead, i t wo/uld be better to have stronger.eng'neering leader-
/
ship and over' sight from the NRC Staff. The leck of trong leader-ship and ineffectual oversight by the DOE at the SRP contributed
/
to significant environmental problems at SRP and ignificant rel eases /
into the VEGP operational area (Lawless, 1985).
The lack of a, statistical treatment may be related to the in-adequate exploration of VEGP hydrogeology.
For
- example, ap-QBODGO. fPmmW rer.nnV$rWL 1hw&ztu.,ry.navaAra
,/
2 power-blocl6Mapadopulos,9986).
The average hydraulic conduc-tivity K calculated from only 4 power block wella et this testing has a standard deviation greater than is customary practice, in-plying that the engineering procedures used to determine K by VEGP may be questionable at worst, or the new data collected is confounded or uncertain at best (Bouwer,
- 1978, p.132).
l Therefore, since a statistical treatment is an important con-sideration whenever hydrologeological data is being gathered, the VEGP hydrological data should be statistically treated.
- Further, the 4 power block wells are located in backfilled and O
compacted material that has been in a subsurface area of plastic deformation (Analysis
- Bechtel, 1986).
The deformation may have had the effect of changing at random the fill's hydrologic coefficients; and may have opened or may contribute to additional flow pathways 'such as the observation wells at the power block, or with head rever,sals, via well TW-1 or well MU-1 down through I
i the blue marl (Bechtel, 1986, figures 4,6,7,and 103 Analvsis).
j Uncertainty in data on Marl Thickness and Per ability l
Statistical treatment of t ar thickness and permeability data should be provided (Bo r,
1978).
icant or staff should as-certain whether the collected data fits withirha, chance distrib -
tion or no (cf. Analysis).
~ ~ = -..~. -,. -. - _ _ _ _ _. -,, - -
e O
Data on Marl Continuity 7
Part f the concern on earl continuity is that the-mafl charac-terization data ears to-be deficient, and also because of VEGP settlement coti ting to the otential for numerous path-
/
N
)
ways into and through the earl via wells (Analysis).
On the one
/
/
- hand, the earl must be satisfactorily mapped, but on the other, breeching the integrity of the earl in order to monitor the marl may be self-defeating by adding the potential for additional con-taminant flow pathways.
Statistical at G 'y creas h n+
nee in the data already collected and prevent the need to punch random' holes into tTiFTarl-(Analvs_i s).
f
/
Direction of Groundwater Flow Intervenors have nothing to add to the Ruling at this time.
Groundwater Travel Time O
Of concern to intervenors is not only water travel time through the power block subsurface outward by predicted Darcian flow, but since the power block subsurface soil has a significantly dif-ferent hydraulic conductivity than subsurface soil
- nearby, the
I
/
l potential for rapid water, transport through fissures in the back-(
the methods for ascertaining 4 he )
filled material exists.
e of
/
.l sufficiency of the hydrogeologic is to use statisAffal inference
{
on t}ilinta s.
The lack of the use of-1'n ce in the past
/
I may have unnecessarily ded the data that has been col-f lected to date.
Such may he case Ab the use of the slug test to collec,t ogeologic data in a fined mouffer at
\\ (Bouwer,
/
VEGP f rom only.4 power block wells or source points
/
19783 Papadopulos, 19863 Anal ysi s).
p C
O latervenors hetieve that their discussion from anal. a on groundwater travel time is relevant and include it here.
6 e
O
s
{}
pte 23 WB6 j.E.3-February 23, 1986 United States of America Nuclear Regulatory Commission Intervenors' Testimony Before The Atomic Safety and Licensino Board March 11. 1986: Contention 7.
Groundwater Contamination 1
(Note: The interven=r='
testimeny was mailsd undar ssparate cover. The ref erences f or that testimony are included here. )
References f
i Bechtel Inc.1986.
Vootle enerov oeneratino olant around-water monitorino orooram Julv-December 1985.
i Bouwer, H.1978. Groundwater Hydroloov. New York: McGraw-Hill.
Lawless,W.F. The Savannah River Plants Hazardous and Radioactive.
l Public Comment and Meetino Report.
A Centers for Disease Control l
Review Panel's Recommendations on Health effects and epidemioloolcal Studies of Operations at the Savannah River Plant l
Aiken. South Carolina. DOE /ER-0225 (1985).
Papadopulos, S.S.
and Assoc.(1986).Results of Hydrocoolooic Test-ino Power Bl ock Area Vootle Electric Generatino Plant Units 1 and l
2.
Prepared for Bechtel, San Francisco.
[
i l
i t
~ - - -. - -.
~
- 'f..
f December 15, 1985 g
\\.)
United States of America Nuclear _ Regulator.y_ Commission In the Matter of Georgia Power Company, et al. (Vogtle Electric f
Generating Plant, Units 1 and 2) ; Docket Nos. 50-424 (OL),
0-425 (OL)
Analysis of the Atomic fety and Licensino Board's November 12. 1985 I
Hemorandum And Order (Rulinb On Motion For Summ/
\\
\\
ary Disposition Of
\\
Groundwater Contaminat ion)/
Contention 7 re:
J The intervenors did not file a moti to strike because the Applicants' were arguing their c se the ugh the malls. Because of the complexity of this issue, an because bot Applicants and the ASLB board have had difficult o'nderstanding scoe f the issues raised by Intervenors, Intervenors want to argue their ca e in front of both the Applicants and the SLB board where confusion can e more easily resolved rather aan trying to do so through the mai Intervenors feel that suff cient information had been supplied to t e Atcaic Safety And -icensing Board (ASLB) to make a determination n whether or not tr. groundwater contention entoto merited gen.ine iss es of materi 1 fact to be heard in an open forum before the ALLB.
/
I Non ' heless, the ASLB granted part of the Applican*s' rec,;est al hough
\\
(fmj th ASLB board agreed genuine issues do exist with the goo dwater i
contention. This analysis will review seriatim the dispositions by the
' N_
ASLB boaid of..the Intervenors' allegations on the groundwater
e O<
a l ontention.
m Sr-90 contamin ton of-roundwater at VEGP
.~
The A LB board and~the Appilcants teu legation. This s part of the allegation stated
\\
The 1971 proundwater chemical analysis should be update. It has been found at Sr-90 contamination in the VEGP...
ea, likely due to SRP rel es, is significant (cf FES). T ere is the
\\
possibility that ot er released chemicals may have changed the 1971 datum.
Both the ASLB board and Applicant we e unable to find reference to Sr-90 contamination in the VEGP gr un vater in the FES and therefore dismissed the contention out o ' hand. B
, Intervenors did not state
.there was Sr-90 ontaminati, of the groun ater in the VEGP area.
Intervenors stated that
-90 contamination in the VEGP area was significant, and that his was discussed in the S (cf. FES, Appendix A, pp.91-92; the N response in the FES,pp. 9-27,
, did not address the WFL-19 comme t concerning significant Sr-90 in mil in the VEGP area either).
Simply ut, using Dupont SRP and EPA data, there exists a signi ' ant diff rence in concentrations of Sr-90 found in milk in the VEGP ar S
c ipared to what both the EPA and the SRP claim should be in the VEGP area due to nucleer weapons fallout and thus do to chance. Numerous N EPA and SRP sources attest to the confounding of SRP released-SI-90 by f./
l
'C x[
~~ N ellout; these are referenced in the first FES citation above. But N none of these sources, both EPA and SRP, analyzed the Sr-90 data tis ng
/
statistica inference. Thus for the most part, the EPA and SRP
/
statistical these sources were speculative. Using /
conclusions
/
inference, a s nificant difference was found to ex st ( t(12)=2.48,p
/
/
less than.05).
I i
With it being firmly stablished that Sr- ' contamination in the SRP
/
area is significant, es etially in thef EGP area where the highest i
/
l readings were found, and ince the RP emits Sr-90, the source of the Sr-90 becomes irnportant. The SR predictions of Sr-90 maximum concentrations, due to airbo releases, at its plant boundary are orders of magnitude below t e co centrations found in milk in the VEGP area (e.g., DPST-82-105
- p. 2-5 (
82); DOE /EIS-0108, p.5-52 (1984);
EPA 520/5-84-012 (198
. Considerin that the SRP is a source of Sr-90 (e.o., ERDA-1 7, p. A-26), that he SRP has had a consistent l
l history of underes imating environmental rameters and impacts (e.g.,
f ERDA-1537, p.II 20; vs. DOE /ER-0225, pp. D-8,41), it is possible to conclude that the Sr-90 mil'< contamination in e VEGP area is likely i
l due to many years of SRP releases.
Wh/ is this of concern? The SRP releases not only Sr-O but many other j
radi nuclides and nonradioactive effluents as well (e.g,
/
DP3T-82-1054). The Sr-90 may be considered a signature. A the SRP,
- groundwater contamination due to background tritium under e
radioactive waste burial grounds, about 1 mile upwind from the airborne release stacks in the H-Area, has been attributed to H-Area easing tritlum. Airborne released tritlum effluents
i l
are deposited on the surface of the burial grounds, washed into the N
,em
\\
()
soil when it rains, then percolated downwards to the groundwater below, and then intercepted by background monitoring wells (cf. the
(
SRP Annual, ell Nonitoring Reports by Fenimore, Radionuclides'In 643G Groundwater-1 3-76, November 23, 1977, p.2). A clear p of airborne releases, deposition, and subsequent goundwate accumulation has been established t the SRP. The same pattern and causal relationship should be und in the VEGP area as a t esul t of SRP releases. Since the only c emical datum for the roundwater under VEGP was established in 1971, and ince the SRP ma es significant airborne
\\
releases each year, and since Sv-90 has be (i found to be significantly higher in concentrations within m k in e VEGP area, it would appear to be important to re establish a ne atum for the groundwater.
Otherwise, subsequent monitoring d a
ay be confounded.
There is another cencern. Gr dwater under VEGP has been accepted as a formal contention. Groun ater contaminatio is a complex subject, one not easy to understa d or predict. Hcuever, t doesn't appear to be part of the scient' ic method to dismiss argume ts because the ccm ents are vagu or not understandable, especia11, when it is an easy matter to c ntact those making the arguments. The "SLB and Applicants te d to suggest that some of these scientific rguments can be legally cceptable or not. While that may be so, it mus be clearly underst d that the spread of contamination in the aquifers elcu VEGP s
i cann be prevented by decree, by legal resolution, or by form I envaronmental statements. The most prosperous course, it would eem,
's to resolve issues that may appear to be vague, especially when possible and when to the advantage of all parties.
]
?
{
c.
~
,~
l Statistical Analy' sis of Hydroloolcal Data (v
Interveno s' stated that the groundwater data had not bee studied with scient ic inference methods. Applicants and the SLB board agreed that th data had not been statistically trea.ed, but both stated that inter gnors have not found flaws in the conclusions based j
on that data. Inter ors were not planning to lo R for statistical
/
errors, but for errors process. This the In rvenors have found.
Statistical treatment on t e groundwater data should include a sensitivity analysis and an.-timate of thetrange of error that exists f
in the collected data. VEGP gro ndwater d ta should be compared to normalized groundwater data from atio groundwater monitoring data from nuclear reactors. No data base i error free, but the amount of error should be quantified, a datum s ablished and updated when found incorrect. For example, an uncerta nty a alysis on the groundwater resolvedso/
travel time may have me of the issues in this area. The
/
ASLB board has agreed that uncfrtainty exist in same of the VEGP treatmen /would quantify t data. A statistical s uncertainty.
Intervenors were not looki g for flaws in the gro ndaater data using statistical treatments, p r se, but in the planning recess. It appears both were found Groundwater contamirtation plumes are known not to travel a a discrete whole, but as a d ribution modeled by distribution moments There are other reason to use statistical and probabilistic treatments of C/
\\
l l
hydrologic data From Viessman, Knapp, Lewis, and Harbaugh (
s Introduction o Hydrolooy (2nd ed.),1977, pp.157,201) :
/
's Ma hydrologic processes are so complex that they can be
(]
Inter reted and explained only in a probabilistic sense.
Hydrolo ic events appear as uncertainties of nature and are the re' ult, i must be assumed, of an underlying process with random s
or stochasti components. The information to inve igate these processes is c tained in records of hydrologi ' observations.
Nethods of statis ical analysis provide wayv to reduce and summarize observed ta, to present infor ation in precise and meaningful form, to de ermine the unde ying characteristics of the observed phenomena, d to make redictions concerning future i
behautor...
/
I
/
1 probability and statistic -
. applications (to)... complex hydrologic processes often equire knowledge of the joint distribution of several andc<n varia les and consideration of the correlation between th
. Dependence o sequential events in a time series is also important concept in hydrology. Methods of analysis can be ex Inded... over both spac and time...With the development of el ctronic ccenputers, these m thods and techniques have become a v luable element in planning an design.
From Meyer ( inte doctory Probability and Statistical polications
,1970, p.3),
For.. probabilistic...or... stochastic model(s, these henomena do).(..not lend itself to a deterministic approach. A prob biiistic modei eescribes the situation more accuratei
._....__,-,___.,m
. ~ _ _ _ - - -
F'.
s 7
/
In a letter report from Dupont in 1981 (Letter R. Maher, Dupont, to 3
T.B.Hi an, DOE-SR, Issues Pertinent to the Lono-Term Opera n of the Buria Ground, June 30, 1981, p. 25, 26), a d! script 1on of contaminant Icw in the groun64ater at SRP is of a di tribution:
continue to move out of the bu/
rial ground at an Tritium wil average flow locity of 30-50 feet / yea. The leading edge of the activity is movi g 3-10 times faster..
I In sumary, scientific in rence wou d quantify the amount of error that exists in the VEGP hyd logi data. If anything, in conclusions by VEGP on groundwater travel t e,
in its conclusions on the marl, in its conclusions on the direc so of groundwater fica, VEGP has 3
demonstrated that an uncer ainty n the data exists.
EHect of Settlement on the Marl Applicants and t. ASLB board have misu derstood this part of the contention by stervenors. Both stated t y did not understand
" differential flow rates of the grouted we is underlying the (VEGP) facility."
n explanation follows. The wells underneath VEGP have supposed 1 been grouted with an acceptable me hod (Intervenors have questioned this method before; e.g.,
cf. the B chtel report G+ote hnical Verification Work Report of Result August 1985, i
Geologic Drill Log, Hole No. 904: The amount of ement injected into the hole to grout the well was 28 cu yd compared to a drilled $rG
(-
\\
w I
volume of 46.8 cu yds, leaving a difference of 18.8 cu yds.)
Assuming i
e grou'ted wells under the VEGP power block are one complete solid,
then as the power block settles, those grouted wells directly under
(
the block will be punched downward at a one-to-one rate, a rate that may be different (" differential") for the marl. Applicants have conclud'ed that the marl is impermeable, but have not shown whether the marl,is incompressible, or whether the marl will deform downward at the same rate as the grouted wells. The grouted wells are likely less compressible in a vertical direction than the more elastic marl. As these grouted wells settle, driven by the weight of the power block atop them, they act like spikes. With plastic defor'mation of the mari, it is possible that the bottom of the grouted wells may separate and core out at the bottom of the mar 1. If so, the integrity of the marl would be dimenished, M
7 There are other concerns with this issue. Will the power block settlement esume with water withdrawl over the years? The Swannah i
River Plant c - dits the contamination of the Tuscaloos aquifer under i
the SRP to deteri ion of production well casin
. What is the possibili ty of grout ero.de terioration under EGP? Applicants have h
not given sufficient assu ance that thi will not become a pathway for contamination. Settlement un th-EGP pcwerblock has been described as plastic deformation, but Ap i
nt did not describe the marl 1
deformation boundar y at tt points of rtherest deformation on the surface of the marl an downwards through e marl.
Leakaoe of Rad' active water from Auxiliary Buildino IntervenesdonotdisagreewithApplicantsandtheASLBboar'N that ould seep into the building from outside through a frscture ( /
water
\\
C)
I m
~
~
The highest levels of contamination recorded under the SRP and in the N
f]
Tuscaloosa aquifer occurred under a spent solvent holdup tank (e.g.,
Steele, T nical Summary of the A/H Area Groundwater Remedial Acti n Prooram', ca.
84, SRP report, pp. 7,101 DPST-83-829, pp. 4-1, 13, 79). The tank was et shown by SRP to have failed, only leaked for
\\
many years. In addit'on, even if water only inflows fr a fracture in
/
the building, a concen ation gradient will occur, d it is possible that contamination will e ape. Intervenors bell 've this to be a viable issue.
Hazardous Chemical Wastes Intervenors argue that the potenti fo groundwater contamination of A
the aquifers at VEGP to be as vi ble an i sue as the possibility of radioactive contamination. Th groundwater ontamination at the SRP has been by both radioactiv and hazardous ch icals. The VEGP groundwater monitoring pr gram should include m itoring for all chemical effluents.
Contamination of Cr taceous Aouifer at SRP ASLB a11 edges t at Intervenors stated that groundwater c tamination at SRP result d frca leaks out of a holding tank. That is o, but not the only so' rce of contamination. The areal extent of the g
.u n 6v a t e r contamina ion in 1983 was in the hundreds of acres. Contamina ion under t e tank is the highest recorded at SRP (e.g., DPST-83-82 1
p.6-1,13,79), but it occurred under the N-Area basin, and since t e basin overflowed, and since the sewar lines leaked, percolation
i j o
{
, ~.. -.
down h occurred over a large areal extent also.
7 O-A source on the storage ta or spe oluents is noted above.
On l
other matters, there is some,4 nfus the HLW tank releases with releases from other a s on the SRP. The HLW ta N are located in the 200 area at SRP,, and the known Tuscaloosa aquifer con intion has
{
occurred) M-Area, a significant distance away, but still on the SRP.
site j
Groun & abr Travel Time I
The outcrop at the SRP did not occur early solely because of the shortened flowpath due to erosion. It occurred primarily because of erroneous conclusions based on average groundwater ficMrates. The-original flowpath was about 1700 to 2600 f t and the erosion was about 900 f t (ERDA-1537,p.11-116; DP-1638, p.10). Assuming that erosion was the only factor, eroding 900 of 1700 should reduce the old estimated travel time for the groundwater first outcrop of tritium to 35 years from 70 years (ERDA-1537,p.11-116). However tritium effluent at the outcrop was first discovered in 1978, one year after ERDA-1537 was published wherein it was stated that no significant outcrcp would occur until the 70th year; it could have occurred sooner than 1978, but that was the year i t wac discovered ( Lawless, Savannah River Plant (SRP) Burial Ground Buildino 643-G Manaoement Aooraisal Report (BGAR) Aooraised June 2-13. 1980, November 1, 1982, pp.12-13).
Further, and conclusively, even with the 900 ft erosion repaired, SRP predicted the re-emergence of the tritium in a subsequent outcrop within one year ( Lawless, BGAR, 1982, p. 11). This does not support i
F
- .; J ' e p >
z
~
l Appilcants contentions on groundwater travel tice.
O The groundwater estimate used by SRP was in error. Appilcants have used a similar method at the VEGP, a method subject to error. That is the main point of DP-1638. By using a three-dimensional model for groundwater flow, a calculation of 17 years for an outcrop was found, in close agreement to what has been observed. Flow rates varied in relation to changing gradients. This may account in part for the calculated differences from observed rates.
10 O
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1 (Discussion off the record.)
2 MR. CHURCHILL:
Your Honor, I know we just 3
started, but in view of the rulinos, could we have a few 4
minutes, possibly a 10- or 15-minute break to look over this 5
and try to determine the extent of our cross-examination?
6 JUDGE MARGULIES:
Certainly.
We will recess for 7
15 minutes.
8 (Recess. )
9 JUDGE MARGULIES:
Back on the record.
You may 10 proceed, Mr. Davenport.
11 MR. DAVENPORT:
Thank you, your Honor.
12 CROSS-EXAMINATION
(
13 BY MR. DAVENPORT:
14 Q
Mr. Lawless, since 1983 you have been employed by 15 Paine College as an assistant professor of mathematics; is 16 that correct?
17 A
That's correct.
18 Q
You are not a geologist, are you?
19 A
That is currect.
20 Q
You have never studied geology in school, have 21 you?
22 A
That is correct.
23 Q
You are not a hydrologist; isn't that 24 correct?
25 A
That's correct.
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Q And am I correct that you have never studied 2
hydrology, except as part of another course whi]e were you at 3
Louisiana State University?
4 A
I have not studied it formally, no.
5 Q
And, Mr. Lawless, isn't it true that you have 6
never had any involvement in investigating the geologic and 7
hydrologic formations underlying the particular formation?
8 A
At Plant Vogtle?
9 Q
At any location.
10 A
Could you repeat that one more time?
11 Q
Yes.
Mr. Lawless, isn't it true that you have 12 never had any involvement in investigating the geologic and
{}
13 hydrologic formations underlyingaa partitular' formation?
14 A
That's not so.
In my capacity as a senior project 15 engineer at the Savannah River plant, I was involved in many 16 groundwater determinations, directing research, directing 17 audits on operations, traveling throughout the United States 10 from DOE site to DOE site, 19 I was not physically one of the workers, but I was 20 involved in strategy sessions and I was responsible to review 21 work that was done in those areas.
And, so, to that extent 1 22 do have experience.
23 Q
Now, Mr. Lawless, have you ever been involved in 24 determining the sequence of hydrologic units for geologic 25 formations underlying a particular formation?
You yourself?
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1 A
Only to the same extent, that I had a review 2
capacity in my position as the senior project engineer at the 3
Savannah River plant and while I was working with the 4
Department of Energy in my travels throughout the United L
States, I was involved in that capacity in both research and 6
in operations, in reviewing proposals and reviewing research 7
and reviewing presentations.
So, to that extent I have 8
numerous experience -- numerous amounts of experience.
9 Q
Mr. Lawless, do you recall my taking your 10 deposition on March 26, 1985?
11 A
Yes, I do.
12 Q
And you testified under oath in front of a court 13 reporter at that time?
14 A
Yes, I did.
15 Q
Do you recall ne askina you the question, "How 16 would you go about determining the seque1ce of the hydrologic 17 unit and geologic formations underlying a particular 18 location?"
19 A
No.
I don't recall, but I would not doubt that 20 you asked it.
21 Q
And do you recall your answer?
22 A
No, I don't.
23 Q
Let me show you your deposition.
24 A
This question says: "How did you go about 25 determining the sequence of the hydrologic unit in geologic iJ ACE FEDERAL REPORTERS, INC.
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formations underlying a particular location?"
2 I said I would not, at that time.
3 Q
Mr. Lawless, the next question after that was you 4
would not do that?
5 A
That's correct.
6 Q
And your response was no?
7 A
That's correct.
8 Q
And the next question was have you ever done that?
9 A
I have never gone in and determined the sequence 10 of the hydrologic units, that's correct.
11 Q
And you have made no effort to determine the 12 sequence of hydrologic units underneath Plant Vogtle; isn't
/~N 13 that correct?
U 14 A
That's correct, but I don't think that refers 15 directly back to the question you first asked.
Are they 16 related?
17 0
Okay.
Mr. Lawless, isn't it true that you have 18 never performed any modeling of any type related to 19 groundwater movement?
20 A
Again, I have --
21 Q
I am asking you for work that you did yourself, 22 Mr. Lawless.
23 A
At the time that you asked -- let me answer the 24 question directly.
I'm sorry.
25 Yes.
I have made calculations on groundwater 7_
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travel time.
2 Q
I asked you whether you had performed any modeling 3
of any type related to groundwater movement.
4 A
I have been involved in modeling studies.
I was 5
quite involved with the modeling program at the Savannah 6
River plant known as dose demand, one of the first major 7
modeling programs in the United States, which is a 8
compartmental model.
9 Q
Mr. Lawless, that model had nothing to do with 10 groundwater movement, did it?
11 A
Yes, it does.
If you just give me one second.
12 It's a compartmental model.
It has many compartments and it
(~)
13 looks at the transport of radionuclides from source to uptake V
14 at particular points in the environment by humans.
The 15 source -- the source at that time was the radioactive waste 16 burial ground at the Savannah River plant and you had to 17 break the transport down into nany compartments.
You had to 18 look at percolation rates through the bottom of the trenches 19 down through the Vadose zone, into the groundwater; and then 20 transport by the groundwater out to the outcrops and uptake 21 through fish and other biotic factors to humans.
s.
22 You also had to look at movement in the opposite 23 direction, with dose -- you had to look at it going straight 24 up with vegetative uptake and other biologic factors, and 25 then the eventual uptake by humans.
So it's a
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I 1
multi-compartment model and it used these -- for the 2
groundwater transport portion of it, it used Darcy's 3
equation.
4 So I had extensive experience, not only working 5
with that particular model -- and this was back in the late 6
'70s and early '80s -- but, as a result of the work there, 7
the critical work there, there were modeling conferences that 8
came out sponsored by EPA and proceedings published of models 9
throughout the country used by the Department of Energy and 10 other organizations.
And I reviewed that as well.
11 Q
Now, Mr. Lawless, you did not hold a 12 management-level position at the Savannah River plant; isn't
{J~')
13 that correct?
14 A
I did for a very short period of time once, 15 temporarily.
I preferred not to work in management.
16 Q
Let me refer you to page 34 of your deposition, 17 Mr. Lawless.
18 Let me ask you first, at what point in time did 19 you hold a management level position?
20 A
I'm not sure that I could pinpoint the time 21 exactly.
Let's see, I left in '83 and I believe the -- I can 22 go b1ck into it.
23 During my short tenure as a manager, we were 24 confronted with the corrosion pitting problem at the Savannah 25 River plant of the high-level waste tanks and one of the
(
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26116.0, BRT 727 g)
I reasons I did not stay in management --
2 Q
Mr. Lawless, I think my question was when were you 3
in management?
4 A
Yes.
I was trying to pin that down.
There was a 5
decision made on going public with that information sometime 6
in 1981, and that's when I was removed from the position.
7 So it was sometime in 1981 that I was a manager.
8 Q
Was your position at that time senior project 9
engineer?
10 A
I don't recall.
It may have been.
We carried 11 quite a few titles.
12 Q
Senior project engineer is not a management level
/~'
13 position, is it?
O) 14 A
No.
No.
And the management position was an 15 acting position and it was for a period of six months or less 16
-- or thereabouts.
The last -- from that point on, the last 17 couple of years were as a senior project engineer.
18 Q
As senior project engineer, you reported to a 19 branch chief; is that correct?
20 A
That's correct.
21 Q
While you were at the Savannah River plant, you 22 yourself were never engaged in research on groundwater 23 issues; isn't that correct?
24 A
I was not involved in the research.
25 Q
You simply reviewed --
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V ACE. FEDERAL REPORTERS, INC.
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26116.0 BRT 728 1
A Excuse me.
I was not involved in the research as 2
a researcher.
I was involved in the 1esearch as a director.
3 I directed the research.
That was my responsibility.
I had s
4 overview responsibility, and it was my job not only to direct 5
it, to criticize the' research that was going on, but to offer 6
alternatives.
It also involved funding of the resaarch.
So, 7
as a Department of Energy engineer, I was quite intimately 8
involved in the research.
1 9
Q Didn't you simply review work performed by Dupont, 10 Mr. Lawless?
11 A
It's more than just simply review.
I also 12 performed an audit, which resulted in the burial ground f']
13 appraisal report, which was a performance audit.
And maybe v
14 if I tell you what a performance audit was you might 15 appreciate it a little bit more.
A typical audit --
16 Q
Mr. Lawless, that's not my question.
Thank you.
17 You indicated that you directed research.
Isn't it true that 18 you simply made recommendations to management at DOE about 19 work performed by Dupont?
20 A
No.
That's not so.
The management appraisal 21 might give you a little ' i t t mare appreciation of the extent p
4 w
22 of the research I was involved in.
23 Q
Mr. Lawless, in the last paragraph -- the last 24 section of ycur December 1985 analysis, you state, "The 25 groundwater estimate used by SRP was in error.
Applicants
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1 have used" --
2 A
I'm sorry.
I have the wrong page.
Give me that 3
page again.
4 Q
Certainly.
I'm referring to the section on 5
groundwater travel time that takes up the last two pages of 6
your December 1985 --
7 A
Ch, my testimony.
I'm sorry.
8 Q
I'm talking about your testimony, Mr. Lawless.
9 The last two pages of the December 1985 document that's the 10 attachment to your testimony.
11 A
Yes.
Go ahead.
12 Q
Am I correct that you state here that "The I'S 13 groundvaler estimate used by SRP was in error.
Applicants L.)
14 have used a similar method at the VEGP, a method subject to 15 error.
That's the main point of DP1638, by using a 16 three-dimensional model for groundwater flow at calculation 17 of 17 years for an outcrop found in close agreement to what 18 has been observed"?
19 A
Yes.
20 Q
Now, the groundwater travel time estimate by the 21 Savannah River plant that you characterize as being erroneous 22 is the 70-year estimate that you refer to in the first 23 paragraph, " underground water travel time" in your analysis; 24 is that correct?
25 A
Yes.
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1 Q
And that 70-year estimate appeared in the Savannah 2
River plant's final environmental impact statement for waste 3
management operations; is that correct?
4 A
It appeared in many documents, including that.
5 Q
And your contention is that the alleged error in 6
travel time estimate was caused by the methods used by the 7
Savannah River plant to calculate that 70-year travel time; 8
is that correct?
9 A
Yes.
10 Q
And your testimony is that the Applicant's travel 11 time estimates used the same methodology in calculating 12 groundwater travel times in the vicinity of Plant Vogtle; is
(]
13 that correct?
U 14 A
Right.
15 Q
What nethod was used by the Savannah River plant 16 to calculate the 70-year travel time?
17 A
They used a linear model that was actually a 18 precursor to dose de1and, which became compartmentalized in 19 dose demand.
20 Q
How did they determine groundwater velccities used 21 in calculating that travel time estimate?
22 A
They used quite a few methoda:
laboratory 23 methods, in situ testing.
In the on-site testing they used 24 tracer tests.
There were quite a few tests used.
25 Q
I'm asking you specifically for the method used to
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I calculate the groundwater velocity used in determining the 2
70-year travel time.
I'm referring specifically to the 3
70-year travel time that you cite in your testimony from ERDA 4
1537, at page Roman numeral II-116?
5 A
Well, the ERDA 1537 document was just a photograph 6
-- just a snapshot of one of the calculations.
There were 7
quite a few documents in addition to that, I guess, that I 8
was thinking of at the same time.
9 I don't recall how ERDA 1537 did it.
10 Q
Do you have that document with you?
11 A
I do.
It's probably on the table.
12 Q
Would you get it, please, so you can refer to it?
(^T 13 A
Yes.
Go ahead.
LJ 14 Q
Let me refer you to the citation you provide in 15 your testimony which was ERDA, that's E-R-D-A, 1537 page 16 II-116.
17 Would you take a look at that page, please?
18 A
Okay.
19 Q
They indicate or they project a travel time of 70 20 years for a flow path from the burial ground to Four Mile 21 Creek, I believe, which they project is a distance of 22 one-half mile; is that correct?
23 A
That is what is written down here; yes.
24 Q
And the average groundwater velocity that they use 25 in calculating that travel time is 40 feet per year; is that (O
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I correct?
2 A
That is what is here; yes.
3 Q
Now, that 40 feet per year groundwater velocity, 4
do you know how that was determined?
no.
I would assume that it was 5
A N,ot offhand, 6
determined through the methoda that I told yc.u about.
- 3. -
7 Q
Do you know whether they used Darcy's law?
Tracer 8
tests?
Point dilution tests?
9 A
They used all of those.
10 Q
For the 40-foot per year figure?
11 A
Excuse me?
12 Q
For the 40-foot per year figure?
(~}
13 A
I don't know how that particular number was vs 14 obtained.
15 Q
Is there a reference in ERDA 1537 for that number?
16 A
Reference 14.
That's Fenimore's report, tracing 17 soil moisture and groundwater flow to the Savannah River 18 plant, report 4.
19 Q
You are familiar with that report?
20 A
Not his 1968 report.
I'm much more familiar with 21 his 1977 report.
22 Q
Would you please read the title of the rciort that 23 is referenced in ERDA 1537 as the source of the 40 feet per 24 year average velocity?
25 A
" Tracing soil moisture and groundwater flow at the
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Savannah River plant."
It has also got " Report 4, Water 1
2 Resources Institute, Clemsor. University."
It was written in 3
1968.
4 0
Is that the same report that I have just handed 5
you?
(Handing.)
6 A
It appears to be.
7 Q
Would you --
8 A
The -- excuse me just one minute.
The citation 14 9
coes not have a DP number.
Since it doesn't have a DP 10 number, they are probably different reports.
11 Q
Would you please reread the title?
12 A
" Tracing soil moisture and groundwater flow at the 13 Savannah River plant."
14 Q
That is by J.W.
Fenimore?
15 A
Yes.
16 Q
The document indicates that it is to be presented 17 at the Clemson University council on hydrology conference?
18 A
Yes.
19 Q
March 28 to 29, 1968?
20 A
Yes.
21 Q
But you feel this is a different document from the 22 one referenced in the ERDA 1537, which has the identical 23 title, author and date?
21 A
No.
No.
I said I do not know.
It may be a 25 different document because this is a DP document.
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1 If you will notice, ERDA 1537 is a document that 2
was puolished at the Savannah River plant.
You noticed, 3
right underneath that document, for example -- just for 4
example, item 15 there is a reference to a Dupont -- an ERDA 5
report and it refers to the Dupont number, which is DP1401, 6
Item 14 does n't have a DP number, so there are Y.
7 some possible explanations to that.
8 Q
Let me pursue this a different way, Mr. Lawless.
9 Would you please look at page 8 of the Fenimore report that I 10 have handed you.
11 A
Sure.
12 Q
At the top of page 8 of that report, Fenimore
(~')
13 reports a velocity of between.08 and.13 feet per day was
%./
14 determined using tracer tests in the flow pat'n from the 15 burial ground; is that correct?
16 A
That's what he has written down here; yes.
17 Q
Now, can you tell me what the -- if you average 18 those two numbers, what velocity you would obtain?
19 A
You are going to get somewhere in the ball park of 20 about 40 feet per year.
21 Q
I'm asking you feet per day.
22 A
I'm sorry.
23 Q
Would it be.105 feet per day?
24 A
About.105, yes.
25 Q
If you multiplied that times 365 days?
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1 A
It would be somewhere in the neighborhood of 40 2
feet per year.
3 0
This 40 feet per day groundwater velocity time was 4
determined using tracer tests; is that correct?
5 A
Yes.
6 Q
So the 70-year estimate that appears in ERDA 1537 7
is based on velocities determined by tracer tests and not by 8
Darcy's law; is that correct?
9 A
With the assumption that the document is the 10 same.
But I want to caution you that they used not only the 11 tracer tests, wnich I attested to, but Darcy's law.
There 12 were numerous calculations made.
The general method would
("}
13 have worked something like this:
Darcy's law would have been LJ 14 a part of the dose demand.
Darcy's law is broken up into 15 factors, as we have discussed over the past few days, and 16 those factors are calculated through various means and then 17 tested with in situ testing to the extent possible.
But if 18 you recall --
19 Q
Mr. Lawless, I'm asking you specifically --
20 JUDGE MARGULIES:
Let the witness finish his 21 answer.
22 THE WITNESS:
Yes.
I'm going to try to summarise 23 it for.you.
24 Part of the problem is, on page 8, as the page 25 clearly notes, that the tracer tests only ran for 97 days.
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1 Let's see, " Maximum velocity was southward.
A narrow tongue 2
just extending past a line of detection wells just north of 3
the detection wells."
4 So they used a tracer test using tritium that 5
moved 8 feet.
The irony is that that 0-toot movement could 6
have been embellished significantly by looking at the overall 7
transport of radionuclides in the burial ground.
8 If you'll give me just one second, just one 9
second, please?
I want to continue the comment.
10 MR. DAVENPORT:
Your Honor, I have to object that 11 the response no longer bears any relation to the question 12 that was asked.
T'N 13 THE WITNESS:
The relevance is, how good was this b
14 40-foot number used by Dupont in their own calculations.
15 MR. DAVENPORT:
I don't believe I asked th.it 16 question.
17 JUDGE MARGULIES:
That was not the question.
18 BY MR. DAVENPORT:
19 Q
Mr. Lawless, are you contending that the 20 Applicants have used tracer tests to determine groundwater 21 velocities used in their groundwater velocity calculations 22 for Plant Vogtle?
23 A
Am I contending that they have or have not?
24 Q
That they have.
25 A
I don't think I have contended on that.
I'm not
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1 certain if I said anything on that.
2 Q
Are you contending that here today?
3 A
No.
4 Q
Mr. Lawless, let me refer you to your prefiled 5
testimony, the document dated February 23, 1986, specifically f
6 to page 3 of it, item 10.
- :-4 7
A Yes?
8 Q
How would impros'ed surf ace runoff raise any 9
concern related to the issues that the Board has identified 10 to be addressed in this hearing?
11 A
This may be a method to disperse fluids over a 12 wide surface area versus a point.
It may distort -- it just
(^'1.,
13 may distort the source point.
\\._)
14 Q
It would affect the recharge?
15 A
No.
It may, but indirectly.
16 Q
How would surface runoff affect the source point?
17 What are you referring to, sir, as the source point?
18 A
The source point would be the point that the 19 radionuclides would entel into the environment.
If 20 everything were clean-cut, according to testimony, it looks 21 like the entry point would be straight down at the point of 22 the postulated accident scenario.
23 0
The source point is well below the ground surface, 24 is it not?
25 A
No.
The source point is at -- I'm sorry.
You are
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I right.
The source point is where the -- wherever the 2
chemicals enter into the environment.
You are right.
3 Q
And surface runoff is not going to improve --
4 improved surface runoff is not going to affect subsurface 5
conditions except to the extent that it affects recharge; is 6
that correct?
7 A
Improved surface runoff may have -- may cause 8
quite a few distortions in that source point.
9 JUDGE PARIS:
May cause distortions in the source 10 point?
Is that what you said?
11 THE WITNESS:
Yes.
If the source point is 12 strictly at the bottom of the containment, then surface
('}
13 runoff may have a different effect.
If the contamination s_-
14 leaves at a point higher to the surface, then surface runoff 15 would be a significant factor.
16 Numerous accidents happen on the surface in 17 loading and unloading, filling containers and unfilling 18 containers, removing radionuclides from a site.
And the 19 improved surface runoff in that case would be a factor.
20 BY MR. DAVENPORT:
21 Q
Mr. Lawless, for the spills analyzed in the 22 Applicant's testimony, improved surface runoff would have 23 absolutely no effect; isn't that correct?
24 A
If it went straight down, yes; that's correct.
25 Only through the first part of that.
But the different Ks n
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1 between the power block and the currounding subsurface area 2
would still be a fautor.
3 Q
That's my next question.
You are referring to 4
hydraulic conductivities?
5 A
Yes.
6 Q
When you refer to the power block are you 7
referring to the concrete structure and its hydraulic 8
conductivity?
9 A
Underneath it.
10 Q
You are referring to the hydraulic conductivity of 11 the marl?
12 A
Of the marl and also the backfill itself.
(~)
13 Q
And the fact that the hydraulic conductivities are C/
14 different between the marl and the backfill causes you 15 concern?
16 A
Detween the -- not the marl, no.
Between the 17 backfill and the surrounding area.
If there are any -- if 18 there is any separation in the backfill from the power block 19 facilities, then it is conceivable that, due to the 20 compaction at the lower Ks of the backfill soil, it's 21 conceivable that there could be some backup of the 22 contamination, that the contanination, through capillary l
23 effects, could rise to the surface if
..re is separation, 24 and then that would add to the -- to a potential runoff 25 problem.
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1 Q
So your concern is the contaminants would rise to 2
the surface at the plant site?
3 A
It is possible if there is rain, if there is a 4
significant source of water at that time, and there will be 5
groundwater.
It depends on the amounts of -- it depends on 6
the amounts of contamination.
It depends on the amount of 7
water that is there.
This effect is known as the bathtub 8
effect and it has occurred at the Oak Ridge facility in their 9
radioactive waste burial grounds at Oak Ridge.
10 Q
So your contention is, Mr. Lawless, that the 11 contaminants might rise through the water table aquifer 12 against the direction of flow --
k]/
/
13 A
No.
v 14 0
-- through the unsaturated zone to the surface?
15 A
No.
It's a bathtub problem.
If there is any 16 separation in the soil from the facility itself, cracks or 17 what have you, if the fluid --
18 JUDGE PARIS:
Excuse me, where is this separation 19 you are talking about?
I'm not clear.
20 THE WITNESS:
On the facility itself.
21 JUDGE PARIS:
You mean between the soil and the 22 concrete foundation of the power block?
23 THE WITNESS:
Right.
24 JUDGE PARIS:
Okay.
25 THE WITNESS:
If there's any separation there that bT ACE-FEDERAL REPORTERS, INC.
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1 would allow rainwater to collect before an accident scenario, w/
2 then that condition, it is conceivable that there could be 3
some upward movement due to a bathtub effect.
This has 4
occurred at the Cak Ridge facility.
5 The different Ks are a concern because the power 6
block area, the soil in the power block area has a higher 7
compaction than the surrounding area, and the Ks there, as a 8
consequence, are lower than the surrounding area, and so you 9
may have, then, a reverse bathtub effect as you trend -- if 10 you are on the surface as you flow over the surface, 11 percolation downward may be impeded and speeded up once you 12 cross the power block area.
13 MR. DAVENPORT:
Could I have the last response
()
14 read, please?
15 (The reporter read the record as requested.)
16 JUDGE PARIS:
May I interrupt and see if I can get 17 this scenario in mind more clearly.
18 First, when you refer to soil in the power block 19 area you are talking about the backfill; is that right?
20 Tile WITNESS :
Yes, that's correct.
21 EXAMINATION 22 BY JUDGE PARIS:
23 Q
And you are discussing between -- the interface 24 between the backfill and the well, between the well and the 25 backfill material; is that right?
(~)
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1 A
That's right, w/
2 Q
Would you explain more clearly this surface runoff 3
and reverse bathtub business?
4 A
I'm sorry.
The backfill area would have a lower K 5
than the area outside.
So the area outside, transport in the 6
area outside would then be faster than transport in the 7
backfill; and there are two concerns, then.
8 One is surface runoff.
If any radionuclides hit 9
the surface, runoff will be enhanced.
It already has been 10 enhanced.
The area has been cleared.
And, second, if any 11 fissures occur through the backfill over time, with aging, 1
l 12 then the fissures will act like excellent conduits, much more l
l 13 so in the backfill area than outcide the backfill area l
O V
14 because of the low Ks, again.
l 15 Q
So you are suggesting that, by virtue -- through l
16 the bathtub effect, radionuclides from the spill might come l
17 up fissures and get on the surface and run off; is that the 10 idea?
19 A
It's possible.
Yes.
I'm not saying that it would 20 happen.
I'm just saying it was a consideration.
j 21 JUDGE PARIS:
Thank you.
I just wanted to 22 understand what you are getting at.
f 23 CROS S-E X AM Ifl ATIOtl (Continued) l 24 DY MR. DAVENPORT:
25 Q
Do you know what the composition of the backfill 1
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is at Plant Vogtle?
2 A
I have read it in here.
3 Q
Can you tell me today?
4 A
No.
5 Q
And do you know how the backfill material was 6
placed?
7 A
I have read that too, but I don't recall.
8 Q
So you cannot, today, describe for us the process 9
by which backfill has been placed at Plant Vogtle?
10 A
No, I cannot.
11 Q
And are you aware of any fissures in the backfill 12 material?
13 A
No, I am noc.
14 Q
Are you aware of any core hole drilled in the 15 in-place backfill material that has found fissures?
16 A
No, I am not.
This is a hypothetical, quite 17 similar to the hypothetical used in the accident scenario.
18 Q
And are you aware of any separation from the 19 backfill material -- or separation of the backfill raa teria l 20 from the power block structures?
21 A
No.
This is a strictly hypothetical situation.
22 Q
And you know of no information at this time that 23 suggests that that hypothetical has any basis in reality, do l
24 you?
25 A
Yes.
It has occurred at other facilities.
That (3
V ACE FEDERAL REPORTERS, INC.
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(~S 1
was the basis of the comment.
t t
L,'
2 Q
You know of no information relating to Plant 3
Vogtle that suggests that?
4 A
No, I do not -- except for the different Ks.
5 Q
The different conductivities do not suggest 6
fissures, do they?
7 A
No.
They just suggest that, if fissures did 8
occur, what they would mean.
Just as the accident scenario 9
auggestas what could happen if that happened.
1 10 Q
Mr. Lawless, let me refer you to pace 6 of your 1
11 prefiled testimony, the document dated February 26 --
I 12 February 23, 1906.
Let me ask you again:
Based on the 13 information that you have about Plant Vogtle, are you aware l
/"N
()
14 of any change in the fill's hydrologic coefficients, o" the 15 type that you referred to in your testimony?
i 16 A
I think I'm a little bit lost on the question.
17 Could you try from a different approach?
18 Q
I'll be happy to repeat it.
I'm referring you to 19 the inf ormation that appears in the middle paragraph on page 20 6 of your testimony, which talks about deformation --
21 A
Yes.
22 Q
-- underneath the backfill material, and talks 1
23 about changing at random the fill's hydrologic coefficients.
1 24 A
Yes.
25 Q
Are you aware of any information relating to Plant l
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1 Vogtle that suggests that the fill's hydrologic coefficients 2
have changed?
3 A
No, I am not.
I am thinking of plastic 4
deformation and the ef f ects that it would have on those 5
properties.
6 The deformation is going to change the Ks, 7
wherever there is -- wherever there is movement, and that's 8
what I was concerned aboat, in part; but also there could be 9
movement in the backfill since the backfill is at a different 10 level, so that there could be opportunities for the variation 11 in the Ks with settlement.
12 Q
Dackfill is at a different level from what?
O V
13 A
From the marl i tself.
It's lower.
The marl is 14 underneath the plant.
The plant is sitting on top of the 15 marl.
The backfill is alongside of the facility.
As the 16 facility moved it could be moving at a different rate than 17 the till itself.
If the facility moved down, the backtill 18 then would probably be going through some dictortions itself.
19 r
Q Are you aware of any information related to Plant 20 Vogtle --
21 A
No.
22 Q
that suggesta that there is any dictortion in 23 the backfill?
24 A
No.
Atg 25 Q
Any ficoures?
ACE FEDERAL REPORTERS, INC.
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A No, I am not.
2 Q
Do you know how much the marl has settled at Plant 3
Vogtle?
4 A
No.
I have not.
I have heard numbers, but I do S
not know that and I've not ceen a citation.
6 Q
Do you know that the current rate of settlement 7
is?
8 A
No.
I have heard, again, information but I have l
l 9
not seen a citation on it.
10 Q
Do you know there the rate of settlement in l
11 declining?
i 12 A
I have heard that information but I have not seen l
1 13 a citation on it.
l l
14 Q
Are you familiar or have you ever reviewed the t
l 15 affidavit of Walter Farris that was submitted by the 1
16 Applicants in response or in reply to your response for the l
1 17 Applicant's motion for summary disposition on Contention 7 i
18 that discussed settlement?
l l
19 A
Gee, I have not seen that, j
20 Q
Mr. Lawlesc, let me refer you now to your --
l 21 A
Could I ask you at to repeat that title again?
i 22 Q
Certainly.
It was the attidavit of Walter Farris 23 submitted with the Applicant'a reply to the Intervenor's 1
(
24 response to the motion for summary disposition on Contention p
i I
26 7'
v l
I i
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1 A
And it deals with the settlement issue?
2 Q
Yes, it does, Mr. Lawless.
Let me --
3 A
I'm sorry.
One more question.
Do you have a date 4
on that, please?
5 Q
Not handy, I don't.
6 A
Okay.
What packet was it about?
7 Q
It was sometime early last fall, Mr. Lawless.
8 A
Okay.
Thank you.
9 Q
Let me refer you now to your December 15, 1985 10 analysis.
That's the attachment to your testimony, and 11 specifically to page, the bottom of page 7 and continuing on 12 top of page 8 where you discuss the grouted wells beneath tae
\\
13 power block.
14 A
Just one second.
15 Q
It is in the section entitled "Effect of 16 settlement on the marl."
17 A
Okay.
18 Q
Now, do you know what the compressive strengths of 19 the grout in these wells is?
20 A
No, I do not.
21 Q
Do you know what the compressive strengths of the 22 marl is?
23 A
I do not.
24 Q
What are you sayiriq that the grouted wells will b
25 punch into?
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1 A
The grouted wells will be like rigid structures, 2
compared to the more plastic marl, as has been presented in 3
testi. mony.
Being that the marl itself is compressible, that 4
means that different levels of marl will move differently.
5 That is to say, the top portion of the marl may move at a 6
faster rate than the lower portion of the marl.
The lower 7
portion of the marl may move much slower.
And in the nature 8
of plastic deformation, the rigid spikes created by grouting 9
the wells would not be as plastica 11y deformed; and the 10 concern there is that the rigid spikes will be inside of a 11 plastic medium or region and that slip may occur.
12 Q
Mr.
I, awl es s, without knowing the compressive O
13 strenath of either material, it's rather difficult to compare 14 their elastic properties, isn't it?
15 A
That's true.
16 Q
And in fact you don't really know whether the 17 grout columns may be more elastic than the marl, do you?
10 A
That's true.
Dut it would seem that they are much 19 more rigid, being cement and belno a vertical structure, and 20 being a unified structure.
Plant Vogtle has gone to leocths 21 to explain how strong this s tructure is and how good its 22 integrity is, and therefore I would assume that that makes it 23 a rigid structure.
24 They have also gone to lengths to explain that the 25 marl itself. is comewhat more compressible and more elastic; ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coversee m33MM6
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1 and even though I do not know the exact values qualitatively, 2
then there is a significant difference.
1 3
Q Mr. Lawless, do you know what the composition of 4
the grout material used at Plant Vogtle is?
5 A
No, I do not.
6 Q
So you don't know whether it's cement, do you?
7 A
No, I do not.
But, again, I have read the 8
material and the material suggests that it is a strong, 9
unified, homogeneous structure with integrity, and it is the 1
10 integrity that I was focusing on, and it has no voids and i
11 they have taken pains to make certain that it is homogeneous l
l 12 from bottom to top.
Therefore, if there are no voids and the 13 integrity can be assured, from bottom to top, then that would 14 make it a rigid structure.
15 Q
The Applicant's references to the marl as an 16 elastic medium is in reference to other geologic structures, 17 is it not?
l 18 A
That is correct.
l 19 Q
Mr. Lawless, your contention is that these grouted l
20
- the columns of grout could act as pathway 3 for 21 contaminants through the marl; is that cortect?
l 22 A
If slip occurs, yes.
l l
23 Q
Doesn't t'
'onsistent head difference between the 24 water table aquifer and ne Tertiary aquifer immediately 25 beneath the marl demonstrate that there-is no rapid l
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transmission of water through the marl?
2 A
We are talking about regional information as 3
opposed to point information.
4 The regional information does provide the 5
information that you suggest.
But your question refers to a 6
point.
That is to say, if you know the room temperature of 7
this entire structure and the average temperature is such and 8
such, does that mean 200 feet away inside this structure that 9
the temperature can be exactly obtained?
And the answer is.
10 Not until you go down there and you specifically look at it.
11 So, the very source that could give us that 12 information is the well itself that has been grouted, and O
13 that well is now cle.ied to us as an information cource.
So, 14 in actuality you cannot use the regional information to know 15 what is golig on at a specific point because the regional 16 information is an averaged information.
17 Q
Mr. Lawless, what will these columns of grout 18 punch into?
19 A
It's not the punching, it's the slipping that's of 20 concern.
21 Q
Slipping in relation to what?
22 A
That there will be slippage between the grout 23 surface and the marl surface.
24 Q
Do you have any information that you can present 25 to us today that suqqests that at Plant Vogtle there has been ACE FEDERAL REPORTERS, INC.
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1 any sliopage between the marl and the grout columns in the 2
grouted wells?
3 A
That is an excellent question.
The only way that 4
you can find that out is to discover the contaninants beneath S
the surface.
There is no other way.
6 One day, if there is contamination discovered in 7
the pumpage water from the confined aquifer, as was done at 8
the Savannah River plant -- that is the only way to find 9
out.
There is no other way.
There is no test, there is no 10 way to physically get down and look at the slippage points.
11 There is no way known.
The only way you will find it is when 12 you find it in the water.
O 13 Q
Mr. Lawless, I take it your answer to my question 14 is no, that you have no information today that auquesta that 15 such slippage has occurred?
16 A
No.
And I do not know of any method that will 17 allow us to obtain that information -- excuse me -- except 18 for the method that I outlined.
19 MR. DAVEf1 PORT No further questions.
20 JUDGE MARGULIES:
Does Staff have any questions?
21 MR. DEWEY:
May I take a brief recess, of five 22 minutes, to talk with members --
23 MR. TI f1GLE :
Excuse me, your lionor.
We would like 24 a recess, too.
Preferably about 10 minutes.
25 JUDGE MARGULIEGr We will take a 10-minuto ACE FEDERAL REPORTERS, INC.
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2 (Recess.)
3 JUDGE MARGULIES:
Back on the record.
You may 4
examine.
5 MR. DEWEY:
Gtaff has no questions for 6
Mr. Lawless.
l 7
JUDGE MARGULIEG:
Do you have any q'Jestions, i
l 8
Dr. Paris?
l l
9 JUDGE PARIS:
Yes, a few.
l 10 EXAMINATION 11 BY JUDGE PARIS:
I I
12 Q
Mr. Lawless, do you know that there are grouted l O" I
13 wells under the power block?
l l
14 A
The grouted wells under the power block area, that 15 was in the testimony over the past few days.
I think the 16 number was 35.
l 17 Q
Are we talking about directly under the power l
10 block as opposed to in the backfill, near it?
19 A
These were supposed to be under -- I think the 20 question was under the power block area.
I assume that that 21 meant under the power block.
22 Q
In your testimo..y dated February 23, 1906, on page 23 6,
in the middle paragraph, in the last sentence you refer to i
l
[
24 certain wells, TW-1, MU-1 -- are those under the power block, 25 do you know?
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A I would assume that they were not.
Those are 2
production wells.
I don't really know - I don't recall 3
their level of exit.
I assume that they were surface wells.
4 They are production wella, operational wella, and not S
grouted.
6 Q
Okay.
Let's forget about them, then.
7 Whose testimony were you referring to with regard 8
to wells under the power block; do you remember?
9 A
No, sir, I don't.
The number was 35.
I don't 10 recall who said it.
11 Q
What was 357 12 A
The number of wells under the power block.
13 Q
35 wells under the power block?
14 A
35 grouted wella, as I recall.
15 0
Under the power block.
16 Do you know how deep they are?
17 A
That was the only question I asked on that.
That la was the only information I got at that time.
19 Q
You got information about the number of wells 20 only, not how deep they are?
21 A
Right.
22 Q
Okay.
23 A
These were confined aquifer wells.
They were i
24 grouted, confined, sacrificed --
)
O 2s a
se taev eet t"r "o" t"e 4rt-t'e"-
t"te -
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A Yes.
2 Q
-- at len.st into the Tertiary aquifer?
3 A
Yes.
That's correct.
4 JUDG5: PARIS:
All right.
Thank you.
5 JUDGE MARGULIES:
Judge Linenberger?
6 EXAMINATION 7
BY JUDGE LINENBERGER:
8 Q
With respect to the grouted wells you were just 9
discussing with Dr. Paris, is it those wells that are the 10 subject of your concern about the possibility of slippage of 11 the grout with respect to the marl?
12 A
Yes, sir.
That's co! rect.
13 0
And these are wella, if I understood correctly 11 what you said to Dr. Paris, these are wells that you believe 15 penetrate the marl?
In other words, the bottom extremity of 16 the well is beneath the marl?
17 A
Yes, sir.
That's correct.
The 35 number came up 10 during a discussion of confined wella, confined aquifer 19 wells.
20 Q
Should the kind of slippage that you have 21 postulated occur, would you expect, as a result of such 22 slippage, that there will have been created a flow path c.long 23 the axis of the grout between the grout and the e.orl?
24 A
Is that the end of the questlon?
Yes.
That's 25 correct.
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Q Would you expect that flow path to remain in 2
existence, despite the fact that we've heard testimony that 3
the composition of the marl is somewhat plastic and 4
deformable?
5 A
That's a very complicated question.
There are 6
effects from detritus that have to be considered; there are 7
aging effects that have to be considered; water withdrawal 0
rates that have to be considered; and then the plastic 9
deformation that you mentioned would have to be considered.
10 The plas tic def orn.ation in general could be looked 11 at this way, that is --
12 Q
Excuse me.
U 13 A
I'm sorry?
14 Q
I'm less interested in how you would go about 15 researching the matter than I am in the answer to my 16 question.
Would you expect those flow paths to remain in 17 existence for any significant period of time, given the 18 considera tion that the marl is plastic and deformable?
19 A
There is a very likely possibility, yes.
20 Q
And what 's the basis of your belief that such a 21 possibility is likely?
22 A
If slippage did occur, if a pathway were opened, 23 the plastic deformation of the marl would have already opened 24 the pathway so the pathway is opened.
If, as the Vogtle A
t
)
25 attorneys suggest, if settlement ceases, then there would not U
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be any additional movement and the pathway would remain 2
there.
3 Whether the pathway would close at a later time 4
would be due to numerous other factr.,rs un that case.
5 Deformation, then, would no longer be a factor.
6 Q
I would infer from what rou have just said that 7
there is no experimental evidence that forms the bacio for 8
your belief t h a t' this is a specula tive expecta tion' on your 9
part; is that cprrect?
10 A
It's based on my knowledge of what has ogeurred at 11 the Savannah River plant and my own knowledge in metallurgy.
12 0
I have problem relating metallurgy to marl
(
)
13 properties, but let's leave that alone.
14 I think that I have heard you say you don't have 15 any field information to support your position with respect 16 to the possibility that these leakage paths can be created 17 and expected to endure for some period of tim ?
18 A
My apologies.
That was in two parts.
19 It the pathway has been' created, if that can be' 20 taken as a given -- and let's separate that from h'cw it was 21 created -- if the pathway has h wn created, then 'I do have 22 knowledge and thal was gained from the Savannah River plant 23 wella that penetrate the confined aquifer and l$ow' he 24 contamination occurred there.
25 Q
Well, excuse me, now.
I have a problem unless you
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can establish a nexus between the Savannah River conditions 2
and the Vogtle conditions.
Was there a marl formation 3
involved in the Savannah River situation?
4 A
Yes, sir, there was.
S Q
And were conditions at Savannah River and Vogtle 6
sufficiently similar to allow you to conclude with some 7
degree of certainty that the same kind of thing that happened 8
at Savannah River can happen at Vogtle?
9 A
Focusing primarily on the interaction between the 10 marl and the wells, yes.
Yes, sir.
11 JUDGE LINENBERGER:
Thank you, sir.
No further 12 questions.
O 13 JUDGE MARGULIES:
Mr. Tingle?
14 MR. TINGLE:
Yes, I have a couple of questions 15 just for clarification.
16 REDIRECT EXAMINATION 17 BY MR. TINGLE:
18 Q
In line with the question that the Vogtle 19 attorneys asked, how was the contanination in the confined 20 aquifer discovered at the Savannah River plaat?
21 A
The contamination was discovered in the drinking 22 water.
Water tests on the drinking water discovered the 23 contamination first.
There were no field tests that first 14 discovered the contamination in the aquifer.
I r~3
)
(/l 25 Q
And what, today, does the Department of Energy i
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1 consider to be the pathway for the contamination at the 2
Savannah River plant?
3 A
The contamination pathway considered by the 4
Department of Energy to be the prime pathway was along the 5
well annuli.
6
-Q Could you clarify that a little more?
7 A
Yes.
The contamination went from the surface and 8
subsurface sources, and when those sources from both the 9
surface and the subsurface contacted the well annuli the 10 greater head pressure in the aquifer above the confined 11 aquifer, and the greater weight of the contaminants, allowed 12 the contaminants to pass through the marl into the
/
h 13 Tuscaloosa, and as the contamination -- according to the 14 Department of Energy, as the contamination continued down 15 through the layers, it finally reached a level that it 16 entered the well stream and was then sucked up and pumped up 17 to the surface in production of drinking water.
18 MR. TINGLE:
That's all.
19 JUDGE MARGULIES:
Is there anything further of the 20 witness?
21 MR. DAVENPORT:
Yes, your Honor, we would like to 22 ask a few more questions in light of those questions.
23 RECROSS EXAMINATION 24 BY MR. DAVENPORT:
,-( )
25 Q
Mr. Lawless, the contamination you referred to ACE-FEDERAL REPORTERS, INC.
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occurred in the A and M area; isn't that correct?
2 A
That's correct.
3 Q
And the clay area that you are referring to as the 4
marl is approximately 8 feet thick in that area, is it not?
5 A
I don't recall.
6 Q
Do you recall whether it is intermittent in that 7
area?
8 A
Yes, it is known to be discontinuous in that area.
9 Q
Have you compared any core logs or results -- have 10 you compared any core logs from the Savannah River plant that 11 show the clay layer at the Savannah River plant to core logs 12 showing the marl in the vicinity of Plant Vogtle?
[ )
\\/
13 A
No, I have not done that.
14 MR. DAVENPORT:
That's all the questions we have.
15 JUDGE MARGULIES:
Is there anything further of the 16 witness?
17 MR. TINGLE:
No.
18 (Discussion off the record.)
19 JUDGE MARGULIES:
The Board would be interested in 20 hearing a response by the Applicant to Mr. Lawless' testimony 21 on these wells below the power block.
Is the Applicant 22 prepared to put on rebuttal testimony in this area?
23 MR. CHURCHILL:
Yes, we are.
Could we have a 24 short recess to prepare it?
We would have to develop one or
/~"'N j
25 two questions to ask.
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MR. DEWEY:
Do you want Staff's witnesses first?
2 JUDGE MARGULIES:
Yes.
We would like to finish up 3
in the normal order and then you can put on your rebuttal 4
witness.
5 MR. CHURCHILL:
Thank you.
6 JUDGE MARGULIES:
You are excused, Mr. Lawless.
7 Thank you.
8 (Witness excused.)
9 JUDGE MARGULIES:
We'll next proceed with 10 testimony of Staff's witness.
11 Whereupon, 12 LYMAN HELLER 13 and 14 RAYMOND GONZALES 15 were called as witnesses and, having first been duly sworn, 16 were examined and testified as follows:
17 JUDGE MARGULIES:
I should have said Staff's 18 witnesses.
19 DIRECT EXAMINATION 20 BY MR. DEWEY:
21 Q
Gentlemen, would you please identify yourselves 22 and state by whom you are employed?
23 A
(Heller) My name is Lyman Heller; I'm a senior 24 project manager in the Office of Nuclear Reactor Regulation,
,7 (ss) 25 NRC, Washington, D.C.
20555.
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A (Gonzales) My name is Raymond Gonzales, I'm a 2
hydraulic engineer within the branch of pressurized water 3
- reactors, A,
USNRC, Washington, D.C.
205S5.
4 Q
Dr. Heller, do you have a document with you 5
entitled "NRC Staf f testimony of Lyman W.
Heller and Raymond 6
Gonzales, on Contention 7, Groundwater Contamination"?
7 I
A (Heller) Yes, I do.
8 Q
Is this a copy of your testimony in this 9
proceeding?
10 A
Yes, it is.
11 Q
Do you have any corrections or additions to this 12 testimony at thic time?
13 A
Yes, I do.
I have corrections on page 10 and page
~
14 14; and Mr. Gonzales has corrections on pages 20 and 22.
15 Q
Would you tell us what your corrections are?
16 A
Yes.
On page 10, the second line on the page, the 17 third word " supersede" is spelled incorrectly.
It should be 18 spelled s-u-p-e-r-s-e-d-e.
19 On page 14, the second line, after the sixth word, 20 which is "above," insert two words, "and below," continuing:
21
- "the marl shows."
That's the end of my corrections.
22 JUDGE PARIS:
Would you read the entire line 23 please with the correction made?
24 THE WITNESS:
(Heller) Yas.
The entire line
,,~(j 25 reads, " difference between the aquifers directly above and ACE-FEDERAL REPORTERS, INC.
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below the marl shows" --
2 JUDGE PARIS:
Thank you.
3 BY MR. DEWEY:
4 Q
Dr. Heller, with these corrections, is this 5
testimony true and correct to the best of your knowledge?
6 A
(Heller) Yes, it is.
7 Q
Mr. Gonzales, do you have a copy of this same 8
testimony?
9 A
(Gonzales) Yes, sir, I do.
10 Q
Do you have any corrections or additions to it at 11 this time?
12 A
Yes.
I have two corrections, on page 20 and 22.
4
'~'
13 On page 20, the third paragraph, the third line which starts 14 out "72 feet per year, while the Darcy velocity" and 15 continues.
16 I'm going to strike out the words, " Darcy velocity 17 at SRP was calculated to be."
Scratch those words out and 18 insert " calculated velocity using Darcy's law at SRP was."
19 So the line reads:
72 feet per year, while the 20 calculated velocity using Darcy's law at SRP was" --
21 The second change is on page 22, the first 22 paragraph, the second line.
I'm scratching out "the computed 23 Darcy velocities," and I'm inserting, "those computed using 24 Darcy's law."
(m) 25 MR. TINGLE:
Could we have that page one more r
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1 time?
U) 2 THE WITNESS:
(Gonzales) Yes.
Page 22, first 3
paragraph, second line.
1 FUDGE MARGULIES:
Read the sentence as you want it 5
to be.
6 THE WITNESS:
(Gonzales) The sentence, starting at 7
the first word is, "Although it appears that measured 8
velocities are more than twice those computed using Darcy's 9
law, I do not believe there is an inconsistency," and 10 continues.
11 BY MR. DEWEY:
12 Q
Are there any other corrections?
13 A
(Gonzales) No, sir, that's the only corrections I
,,( )
14 have.
15 Q
With these corrections, are the statements in this 16 testimony true and correct to the best of your knowledge and 17 belief?
18 A
Yes, they are.
19 MR. DEWEY:
Your Honor, I move the testimony of 20 Dr. Heller and Mr. Gonzales be admitted into this proceeding 21 as if read.
22 JUDGE MARGULIES:
Is there any objection?
23 MR. TINGLE:
No.
24 JUDGE MARGULIES:
There being no objection, the 25 request is granted, im i
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704
' eU UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-424 et al.
)
50-425
~~
)
(OL)
(Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
3 NRC STAFF TESTIMOITY OF LYMAN W. HELLER AND RAYMOND GONZALES ON CONTENTION 7 (GROUNDWATER CONTAMINATION) 0.1 Please state your names, affiliations and positions.
A.1 My name is Lyman W. Heller.
I am currently Senior Task Manager in the Engineering Issues Branch, Division of Safety Review and Oversight, Office of Nuclear Reactor Regulation, NRC.
Prior to the
- October, 1985 ONRR reorganization, I
was the gectechnical engineering section leader in the Structural and Geotechnical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, and was responsible for supervising the geotechnical review of the Vogtle plant.
In carrying out these i
latter duties, I gained familiarity with a number of geotechnical features of this plant.
My name is Raymond Gonzales.
I am a hydraulic engineer within the Engineering Branch of the Division of Pressurized Water Reactor
-p-O Licensing - A, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
Q.?
Have each of you prepared a statement of your professional qualifications?
A.2
(!!oller, Gonzales).
Yes.
Statements of our professional qualifi-cations are attached to this testimony.
Q.3 What is the purpose of your testimony?
A.3 (Heller).
To address Joint Intervenors' Contention 7 which states O
that applicants have failed to assure that the groundwater below the Vogtle Electric Generating Plant will not be contaminated by a spill
't of radioactive water.
In response to a mction for summary disposition, on November 12, 1985 the Licensing Board ruled that there were several issues of material fact remaining with respect to this contention.
Its concerns related to:
(1) the adequacy of geological / hydrological exploration, (2) uncertainty in data on marl thickness and permeability, (3) data on marl continuity, (4) direction of groundwater fIcw, and (5) groundwater travel time.
My testimony will address these areas of concern which relate to geology and geotechnical engineering.
Mr. Gonzales will address the hycrologic concerns.
We shall address material fact (1) fointly.
I l
i
. ~O shall address material facts (2) and (3) and Mr. Gonzales will address material facts (4) and (5).
Q.4 f.Ir. Gonzales, do you agree with Mr. Heller's characterization of the Board's expressed concerns?
A.4 (Gonzales).
I do.
Q.5 Uhat are the Board's expressed concerns pertaining to the adequacy of geological and hydrological exploration (material fact 1)?
A.5 (Heller).
The Board identified (at pp.12-13) what they perceived O
to he several unreseived areas in the record concerning geoiericei and hydrological exploration (material fact 1), which included:
l l
a) the staff's SER (at p. 2-32) indicates that well monitoring in the unconfined aquifer and in the backfill is necessary to establish the design-basis groundwater level; I
b) the staff's SER (at p. 2-32) indicates that additional wells in the marl aquielude are required because previous well monitoring provided only limited information; c) the staff's SER (at p. 2-33) states that the confined Tuscaloosa aquifer should be monitored during plant operation to determine the long-term effect of withdrawing water from this aquifer;
i d) the applicants are still conducting laboratory permeability tests on cores taken during drilling of the marl in June of 1985; e) the applicants' statement that groundwater data from well series 42 are sti!: being supplemented and confirmed by data from additional wells.
Concerning material fact 1,
I shall address items b), d) and e).
Mr Gonzales will address items a) and c).
Q.6 hlr.
Heller, what is your opinion regarding the adequacy of Feological exploration at the Vogtle site?
- O-A.6 (Heller).
In my opinion, recent information made available to the staff b:r the applicant is sufficient to judge that the geologic exploration of the VEGP is now adequate with respect to ground-water contamination concerns.
This opinion is based on my review i
of a report entitled "Geotechnical Verification Work Report of Results" that was enclosed with a letter from J. A. Belley, Georgia Power Company, to Afs. E. G. Adensam, U.S. Nuclear Regulatory Commission, dated August 23, 1985.
This report describes the 3
exploratory work carried out by performing six core borings into the marl formation and the results of pressure tests conducted in the cored holes.
These holcs will be used as wells to measure groundwater elevations in the marl formation.
i O
,y m
,.--wv---
,m,-e,,,
---,,,nn--,,-w-me,r-----
>,----,,p e
--.-,emw--w w mp.,,
,w, - -, -
My review of the sufficiency of the new geolcgical exploration information was focused on evidence that the Blue Bluff marl formation would impede the seepage of potentially contaminated groundwater from the upper (unconfined) aquifer in the backfill material above the marl to the confined (Tuscaloosa) aquifer beneath the marl.
My leview of the boring logs which appear in Appendix D and of the drilling procedures described in sections 4.2 and 4.3 of the above referenced report lead me to the conclusion that the exploration work meets all applicable NRC Regulatory Guides and Standard Review Plan recommendations.
In particular, corings were continuous and the rate of bit penetration was recorded; a detailed field log of the material encountered is also presented lor each O
haie the hote-ere corea u iae cie a ter to remove the cuttings.
These procedures and practices are adequate to reveal the pertinent features and composition of the marl and to assure that pressure test results and later water level monitoring in the six new wells are reliable.
As described in Appendix C of the August 23, 1985 report. ten core samples from the marl were tested in the laboratory to determine their permeability.
The results of these tests indicate that the marl permeability is about 10-centimeters per second l
(cm/sec);
this value is consistent with the description and classification of the marl formation.
O l
)
-e
- _m_,
m m
.s.
_c_
~O In reaching my conclusion I have also reviewed a recent February, 1986, applicant report entitled "Vogtle Energy Generating Plant --
Ground-Water f!onitoring Program -- July - December 1985" attached to a letter from J. A. Bailey, Georgin Power Company, to B. J.
Youngblood, NRC dated February 6, 1986.
As set out in this i
report, the applicants have installed and monitored additional wells to supplement earlier data.
1 1
0.7 Mr. Gonzales, what is your opinion regarding the adequacy of the hydrological exploration at the Vogtle site?
A.7 Since the SER was published the applicants' have drilled new wells, O
h ve ia t ti a arou a ter 2 vei eaitoriar ia tru eat.
aa n ve performed additional field and laboratory permeability tests throughout the entire thickness of the marl.
Thir data has been compiled by applicant in the August 23, 1985 report mentioned by 1
Mr. IIeller, and a February 1986 Report entitled "Vosrtle Energy l
Generating Plant Groundwater Monitoring Program July-I December 1985."
i The staff has been actively involved in reviewing l
the epplicants' proposals to assure the acceptability of the proposals t
l prior to their being implemented.
I now conclude that the applicants' hydrological exploration program is adequate and acceptable.
Q I
_7 Q.R lilr. Gonzales, what is your opinion regarding the Board's first specific concern regarding the monitoring of the backfill and unconfined aquifer (material fact 1)?
A.8 (Gonzales).
The Board's first concern (item a) was that the Staff's SER stated that additional monitoring would be necessary to establish the design-basis groundwater level for Vogtle. This SER concern was related to the applicants' design-basis groundwater elevation of 165 ft msl.
Because groundwater levels in the backfill and unconfined aquifer had only been monitored for a relatively short time, it could not be deterrifned conclusively that this elevation could not be exceeded over the life of the plant.
The design-basis groundwater level defines the maxinum groundwater level used to compute groundwater inducs.1 loads on sub-surface portions of safety-related structures.
Thus it is a structural concern as opposed to a groundwater contamination concern.
To address the staff's SER concern, the applicant has installed four new monitoring wells (LT-1B, LT-7A, lT-12 and LT-13) in the plant backfill and two new wells (808 and 809) in the Barnwell sediments.
In response to a staff request, two of these wells *(808 and LT-13) are now being monitored on a continuous basis and the remaining wells are being monitored on a weekly basis to confirm the acceptability of the applicants' design-basis groundwater IcVel.
O
.. ~O This monitoring will be a license condition for the Vogtle plant.
The frequency of monitoring is subject to change.
Q.9 Mr. Heller, has the SER issue (item b of material fact 1), pertaining to the need for additional wells in the marl aquiclude, been resolved?
A.9 (Heller).
Yes.
As I have stated, since this issue wac raised in the SER the applicants have performed sir: continuous and carefully controlled core borings into the marl formation.
Test results from these borings are set forth in applicants' report entitled "Geotechnical Verification Work - Report of Results."
O Q.10 Mr. Conzales, has the SER concern (item e of material fact 1) that t
the Tuscaloosa aquifer should be monitored been resolved?
A.10 (Conzales).
Yes.
However, this SER provision does not relato to a groundwater contamination concern.
Monitoring in this SER provision is required to ensure that the withdrawal of water from the Tuscaloosa aquifer will not adversely impact on other groundwater users., Thus it is more of an environmental concern than a safety one.
To meet this reoufrement, Staff will require monitoring throughout the life of the plant.
The applicants are currently monitoring two wells on a monthly frequency.
O i
1
-g-hU Q.11 Mr. Heller, regarding item d of material fact 1, have the applicants i
completed laboratory permeability tests on cores taken during drilling on the marl in June of 1985?
A.11 (Heller).
Yes.
The applicants in their August 23, 1985 report presented the results of tests conducted on ten samples obtained during core drilling of the marl.
A falling head permeability test was conducted on each marl sample in accordance with proce-dures described in Department of the Army Manual EM 1110-2-1906.
The results of these tests showed the permeability of the marl to
-8
-6 range from about 10 cm/sec. to about 10 cm/sec.
These lab tests together with the in situ field tests confirm that the marl is nearly impermeable.
Q.12 Mr. Heller, regarding item e of material fact 1, has data from well series 42 been supplemented by data from additional wells?
3 A.12 (Heller).
I have retdewed the February 198G, report entitled "Vogtle Energy Generating Plant Ground-Water Pfonitoring Program -- July - December 1985."
Figures 11 and 12 of this report show plots of the recorded groundwater elevations versus time for the six 900 series wells installed in the marl over the 3
interval July to December, 1985.
Figure 11, in my opinion.
I illustrates expected results because the measured levels (marl pore pressures) decreased with time and have essentially stabitzed over l
l
.. a the last two months of the measuring interval.
In my opinion.
S' these data superfede information collected from the series 42 wells.
Q.13 Mr. IIeller, can you address the Board's expressed uncertainty in data on marl thickness and permeability (material fact 2)?
A.13 (Heller).
Pages 14 and 15 of the Order contain the Board's bases for concluding that an issue of fact exists with respect to uncertainty about the thickness and permeability of the marl.
These bases include:
a) intervenors allegation that thickness and permeability O
<=rer tio= c e trc= 22 exploratory holes, of which 3 drew water and 3 were discounted; b) applicants reply that (1) their conclusions are based on 200 exploratory holes,
not just the 80 in situ permeability measurements at different levels in 22 of these holes, and (2) two out of the three wells in which water was drawn were in near-surface, weathered marl, and in the three discounted wells, water leaked around the packers; 2
c) the staff has found that additional geological and hydrological exploration is required, and that work is still in progress.
I
.. Q.14 Mr. Heller, in your opinion has the work that has been done at Vcgtle been sufficient to resolve any uncertainties regarding marl thickness and permeability?
A.14 (Heller).
With respect to groundwater contamination concerns, I helieve the investigations of the marl are sufficient to conclude that the thickness of the marl beneath the power block structures is well known.
I believe the thicknese is well known because of the unusually large number of holes drilled through the marl in this aron by the applicant as compared to industry practice and NRC regulatory guides.
Table 2B-2 of the FSAR lists 33 holes drilled into the marl, whereas usual practice would call for only a fraction Q
of this number.
The marl formation is about 65 feet thick, and extends from about elevation 135 feet mean sea level (ms!) to 70 feet msl. To accommodate the foundation for the auxiliary build-ing, the marl was excavated to elevation 108.5 feet msl in a 120 ft by 440 ft area, so the resulting marl thickness is about 38 ft in this area.
NUREG 1137 dated June 1985, Sections 2.5.4.1.2 ar.d 2.5.4.1.3 contains the basis for my opinion regarding marl thickness beneath the Vogtle plant.
It may also be noted that hole 900 (Appendi:: B of the applicants' August 23, 1985, report "Geotechnical Verification Work - Report of Results") was drilled to an elevation of 73.7 ft mal without penetrating through the marl, so, at the location of hole 900, the marl extends to depths O
previously anticipated.
4
__,,_,_.e.._,
.. (3 With respect to the permeability of the marl, I have reviewed the applicants' report on recent investigations specifically tailored to measure this parameter.
The results of the applicants' work are reported in Appendix D and Appendix C of "Geotechnical Verifica-tion Work - Report of Results", dated August 1985.
The in situ water pressure tests resulted in no measurable water losses and, as previously discussed, the laboratory permeability tests resulted in a value of about 10
- cm/sec.
I believe additional confirming data of the marl permeability can also i
be found in the applicants' groundwater monitoring report dated February 1986, entitled "Vogtle Energy Generating Plant - Ground-
]
Water Monitoring Program -- July - December, 1985.
Figure 11 of this report shows a consistent decrease in the piezometer levels over a two-month period of time for piezometers in holes 900, 901 and 903.
,In my opinion, this data indicates that the marl has a very low in situ permeability.
1 Dased on these reports, I conclude that, with respect to ground-water contamination, the thickness of the marl is well known, and the permeability has now been appropriately established.
Q.15 Do you believe that the Board's expressed concerns have been resolved regarding material fact 27 O
_ _ _.... A
H 13 -
tQ V
A.15 (Heller).
I believe the Board's basis (a) (material fact 2) has been. adequatdly addressed by existing and new borings into the marl and by suitable in situ and laboratory tests conducted by the applicants.
I believe the Board's basis (b) has been super-ceded by new information on the marl reported by the applicant in their letters dated August 23, 1985 and February 0, 1986.
Concerning the Board's basis (c), it is my opinion that the Staff's requirement for additional geologic and hydrologic explora-tion of the marl formation beneath the plant has been satisfied 4
by the new 'information provided by tae applicant in their letters dated August 23, 1985 and February 6,1986.
Q.16 Mr. Heller, what concerns does the Board express with the data on marl continuity (material fact 3)?
4 A.16 (18eller).
Pages 15 and 16 of the Board's Order contain the bases for concluding that an issue of fact exists with respect to marl j
continuity. These bases include:
a) the intervenors allege that applicants' data from the series 42 wells are not adequate to prove that the marl is continuous; b) the applicants state that its date to support an absence of voids, cavities or fractures in the marl include (1) 10,000 feet of marl penetration, -(2) 900,000 sq. ft, of inspection on the upper surface of the marl, (3) inspection of 20,000 sq. ft of the
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vertical face of the marl excavations and (4) a hydraulic head a J 1elo w difference between the aquifers directly above)(the marl shows that the marl is an effective aquiclude; j
c) the applicants state that additional data is still being developed to supplement the series 42 well information; d) the additional information from the series 42 wells and new data on the narl has not yet been evaluated by the staff and said evaluations made available to the intervenors.
Q.17 Mr. IIeller, what are your conclusions with respect to marl continuity?
A.17 ( Heller).
In my opinion, the data set now available for the marl formation beneath the Vogtle plant indicates that the marl is continuous
- and, from a groundwater contamination viewpoint,
provides an effective impediment to groundwater movement from the backfill above the marl to the aquifer directly below the marl formation.
I base this opinion on my review of two recent reports:
(1) a report entitled "Geotechnical Verification Work - Report of Resul{ August 1985, attached to a letter from J. Bailey, Georgia i
Power Company, to Ms. E. Adensam, Nuclear Regulatory Commission dated August 23, 1985; and (2) a February 1986 report entitled i
"Vogtle Energy Generating Plant - Ground-Water Monitoring Program
)
eiber I
.. O
' December, 1985" attached to a letter from J. Bailey to July B'.
J.. Youngblood, NPr' dated February 6,1986.
Appendix B of the first report (August 1985) presents the geologic drill logs for hole numbers 900, 901, 902, 903, 904, 904B, and 905 which were recently drilled into the marl formation.
These logs show the rate of penetration of the core drill in minutes per foot of advance.
The logs tabulate notes on drill water levels, water return, and character of drilling as the drill was advanced into the marl.
These logs do not indicate the presence of voids, as no rod drops were recorded.
The logs show no loss of circulating water in the holes, as would be expected if pervious materials or marl Q
fractures were encountered which could allow drill water to leak out of the hole.
The drill logs also show the result of water pressure l
tests conducted in the marl to measure the rate of water loss from the hole when sections of the hole were subjected to differing water pressures.
The logs show that none of the holes had any measure-able water loss under the test pressures imposed.
Thus, in my opinion, Appendix B of the August report provides evidence that i
2 the marl is continuous and there are no detectable paths for water to leak into the lower aquifer beneath the marl.
Figure 11 of the second report (Feburary 1986) provides evidence that the marl formation is an effective and. continuous aquiclude.
This figure shows the measured elevation of the water levels in piezometers 900, 901 and 902 versus time.
In my opinion, if the l
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However, the pressure changes took about two months.
I also note that the rate of change of the pore pressures in each of these three piezometers is not grossly different, indicating that the average permeability throughout the depth of the marl is consistent and low.
For these reasons, I believe the evidence is now sufficient to conclude that the marl is continuous with respect to its ability to impede the movement of groundwater from the upper aquifer to the lower aquifer.
0,1 ' Mr. GonzalaJ, will you explain what you believe the Board's concern is regarding the direction of groundwater flow (material fagt 4)?
A.18 (Gonzales).
The intervenors had alleged that applicants' data did not agree with applicants' assertion that contaminated water would flow in a northwest direction toward Mathes Pond. The Board finds there may be merit to this allegation since it has identified three groundwater contour maps that appear to contradict each other.
l Q.19 In your opinion are these maps contradictory?
If so, is there a possibflity that there could be groundwater flow from Vogtle in other directions than towards Mathes Pond?
A.19 (Gonzales).
The Board refers to three groundwater maps for the Vogtle area dated:
November 1971, f.iarch 1980, and December
~
. ef.s 1984.
Copies of these maps are attached to this testimony and are marked as attachments one through three, respectively.
The November 1971 map shows groundwater conditions prior to construction of the plant.
The highest groundwater level data point shown on this map is 162 feet.
This highest level is located south of the plant.
Northeast of the plant there is another high groundwater level at elevation 161 feet.
Both of these elevations are higher than the groundwater level directly underneath the plant which is at an elevation of 160 feet.
These two groundwater levels, being the highest on the November 1971 map, indicate that there is a ridge in the groundwater surface that extends from northeast of O
the riant to south or the viant.
A iine drawn detween these two high points marks the approximate location of this ridge.
If the plant had been located such that it straddled the ridge, then a liquid spill from the plant to the groundwater table could have been considered to flow in more than one direction.
However, this is not the case since the plant is located northwest of this ridge.
Since groundwater can only flow downgradient, it is not possible for groundwater to move from an elevation of 160 feet beneath the plant to a higher elevation along the ridge which is located south of the plant.
The November 1971 map also shows that groundwater levels west of the plant are even higher at elevation 165 feet so there cannot be any flow in a westerly direction.
Flow in a northerly direction is
-~-
!.1.
a also not possible because groundwater would have to move from an i
i elevation of 160 feet beneath the plant to elevation 155 feet and then back up to an elevation of 160 feet.
Clearly this is not i
possible.
The only other direction in which groundwater can flow is in a northwesterly direction as was assumed by both the staff and the applicant.
l The next groundwater contour map is for March 1980.
The staff agrees with the Doard that this map suggests that the flow fields
+
around the plant are directed back toward the plant.
- However, this map represents the effects of a temporary construction-related 1
activity.
Prior to construction of the plant, the groundwater level, t
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of about 160 feet as shown on the November 1971 map.
Construc-tion of the power block structures required an excavation that extended well below the groundwater table.
The major portion of t
this excavation bottomed out at elevation 130 feet which was about 30 feet below the groundwater level.
In order to prevent sloughing 4
of the excavation side, slopes and to ensure dry firm working i
j conditions, the construction area had to be dewatered.
The March 1980 contour map reflects the effects of this dewatering program.
Once construction was completed, the dewatering system was terminated.
Therefore, the March 1980 map reflects what the staff erpected would occur to the water table aquifer because of the i
1 dewatering program.
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Since dewatering was a temporary condition, it was expected that groundwater levels would rise to approximately pre-construction November 1971 levels once the dewatering system was terminated.
]
This is exactly what has happened as shown on the December 1984 l-contour map.
The Board on page 23 of its November 12, 1985 Memorandum and Order recognized the similarity in the pre-construction and post-construction groundwater levels by stating, "The November 1971 map contours... are sufficiently similar to contours in comparable locations on the December 1984 map... to i
suggest to us the possibility that the 1984 map would, if all I
contours had been drawn in, look very much like the 1971 map."
lh The post-construction December 1984 groundwater contour map is
{
similar to the pre-construction November 1971 map in that it i
indicates a groundwater ridge extending from south of the plant to northeast of the plant.
Because of this ridge, there can be no groundwater flow in a southerly direction from the plant as discussed above.
I l
l Groundwater levels north and west of the plant are also lower than l
1
(
at the plant, but the gradient in these directions is flatter than it is toward the northwest.
Since groundwater flow follows the path of least resistance, flow will be toward the northwest, as was j
]
assumed by both the applicants and the staff, because of the steeper gradient.
r i
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. /
9 Q.20 Mr. Gonzales, will you explain what you believe the Board's concern is regarding groundwater travel time (material fact 5)?
A.20 (Gonzales).
Intervenors had alleged that applicants' calculation of 350 years and Staff's calculation of 15 yer.rs for' groundwater travel 4
time may be in error.
In its Order on page 28 the Board expresses concern that the model used by both the applicants and staff i
(Darcy's Law) to estimate groundwater velocity, may be inadequate for estimating groundwater velocity over long distances where, as is the case at VEGP, the water table undergoes marked changes.
The Board points out that et VEGP the water table becomes very steep as ?.tathes Pond and the Savannah River are approached.
O The Board also expresses concern that because the observed values of velocity at the Sazannah River Plant (SRP) had maxima of 69 and 72 feet / year, whi t=S P es e 1
32 feet / year, the one dimensional Darcy model may underestimate groundwater velocity, i
Finally, the Board notes that a three dimensional model may be superior since it would be capable of calculating estimates which take into account flow velocity changes as the water table gradient changes.
O
. : O Q.21 Mr. Gonzales, in your opinion, was Darcy's Law adequate for calculating groundwater velocity in view of the marked changes in i
j the water table in the vicinity of VEGP?
I I
j.
A.21 (Gonzales).
The staff agrees with the Board that the groundwater table steepens as it approaches Mathes Pond.
Ilowever, as i
discussed in Section 2.4.13 of the SER, the staff in determining groundwater velocity and travel time conservatively considered only the flow through a relatively short distance in the plant backfill.
i j
It was unnecessary to consider flow through a longer distance j
toward Mathes Pond since radionuclide concentration from an accidental tank spill world be reduced to less than 10 C.F.R. 20 O
limits within the plant backfill.
The backfill consists of selected sandy material, graded and compacted to meet certain specifications.
This makes the backfill essentially isotropic and homogeneous such that the groundwater gradient within this material is essentially uniform having no abrupt changes.
Groundwater flow in isotropic-homogeneous materials is predominately laminar so its velocity can
- be adequately determined using Darcy's Law.
Thus, the Darcy i
equation utilized at Vogtle was adequate.
Q.22 Mr. Gonzales, is Darcy's law as utilized by applicant and staff inadequate in view of the observed values of velocity at SRP of 69 i
and 72 feet / year as opposed to the Darcy velocity at SRP calculated to be 32 feet / year?
A.22 (Gonzales).
Although it appears that measured velocities are more than-twice the computed Darcy velocities, I do not believe there is an inconsistency because I think the velocities are unrelated estLmates that cannot be compared.
The 32 feet / year le an average velocity computed over an unknown distance having an average gradient of 0.018, a hydraulic conductivity of 7.4 gallons / day /
square foot (1.0 foot /de.y) which was determined by a pumping test in a sand lens within the Barnwell Formation, and an effective porosity of 0.20.
In contrast to the 32 feet / year being an average velocity, I believe the 69 and 72 feet / year are point velocities for the following reasons:
The maximum velocity obtained at SRP using the point dilution method is 69 feet / year as pointed out by the Board.
Ilowever, this method also resulted in a minimum velocity of 2.3 feet / year.
The average of the two Is about 36 feet / year which is approximately equal to the Darcy velocity.
The velocities determined using the tracer tests ranged from 36 feet /ycar to 72 feet / year.
The average of these velocities, 54 feet / year, Is greater than the Darcy velocity
,, m,
but atill within an acceptable range given the difference in the i
i measuring techniques.
As discussed by the staff (Staley affidavit of July 1, 1985, page 2), the SRP velocity of 32 feet / year is an average value computed O
using Darcy's Law.
From a cursory review of SRP reports DP-1638 and DPST-83-820, the staff could not determine whether the point dilution method measurement of 72 feet / year or the tracer test
l V measurement of 69 feet / year were averages measured over defined distances or whether they were point measurements.
- However, because of the nature of these tests, the staff believes that they j
were point measurements.
Tracer tests are made by introducing a tracer such as a dye or salt 1
into one point in the groundwater flow field and measuring the time interval for the tracer to arrive at a downgradient Jocation in the flow field.
Since groundwater moves at a very slow velocity, observation locations for tracer tests usually have to be close together or the travel time, which is usually measured in terms of tens of years, will be excessively long.
Because of this limitation, i
tracer tests usually provide estimates of groundwater velocity over a.very short distance and can thus be considered point values instead of average values.
The point dilution method also gives an estimate of point velocity because measurements are made at a single well and the estimated velocity is representative of only the aquifer material near the well screen.
The point to be made here is that average groundwater velocities cannot be compared with point values.
An illustration of this can be made by referring to Figure 2.9 of the SER.
As shown on this figure, the groundwater contours near Mathes Pond are much steeper when they are closer to the plant.
The gradient between g
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.. two of the closely spaced contour lines near Mathes Pond is about 0.10 while the gradient over the entire distance from the edge of the plant backfill to Mathes Pond is about 0.006.
This means that the velocity close to Mathes Pond, which can be i
considered a point velocity because of the short distance over which the gradient was calculated, is about 17 times (0.1/0.006) greater than the average velocity calculated over the entire distance from i
the plant backfill to Mathes Pond.
Thus the two velocities are not comparable.
Q.23 Mr. Gonzales, in your opinion is the use of Darcy's law adequate in view of the Board's concern that a more sophisticated model might be more appropriate to take into account flow velocity changes as l
the water table gradient changes?
A.23 (Gonzales).
Flow velocity changes would not be a factor since, as I have pointed out in my discussion of flow direction, only the groundwater gradient within the plant backfill needs to be considered since radionuclide concentration from an accidental tank spill would be reduced to less than 10 C.F.R. 20 liniits within the t
backfill.
Because the water table gradient does not change within the backfill, tMs Board concern is not a factor.
i l
Q.24 Mr. Gonzales, in summarizing your testimony, do you have an opinion on whether an accidental spill of radioactive water on the 1
site could result in unacceptable levels of radioactive contamination j
of t.he water table, and possibly the deeper aquifers under VEGP?
A.24 (bonzales).
Based upon a review of all the information that has been made available to staff, I conclude that there is no need for concern of contamination of the water table and underlying aquifer from normal plant operation or a design basis accident.
i j
Q.25 Mr. Heller, do you also have an opinion on this question?
A.25 (Heller). I agree with Mr. Gonzales.
O f
.i I
l 0
PROFESSIONAL OUALIFICATIONS STATEMENT Lyman -W. Heller, Senior Task Manager, Engineering Issues Branch, DSRO, NRR Telephone:
492-7646, Mail Stop 144 (Phillips)
I received Bachelor of Science degrees in Agricultural Engineering and Civil Engineering from the University of Illinois in 1950 and 1957, respectively.
I received Master of Science and Doctor of Philosophy degrees in Civil Engineering, with majors in soil and foundation engineering, from the University of Florida in 1959 and
- 1971, respectively.
My academic honors include an Ira O. Baker (class rank) award from the University of Illinois as well as membership in Tau Beta Pi, Chi Epsilon, and Phi Kappa Phi.
Since joining the AEC (nov' NRC) in 3
February of 1974, I have reviewed or participated in the review of the i
i geotechnical features of about 35 power plants and other nuclear facilities.
Prior to my present position, which I assumed in December, l
1984 I was Leader of the Geotechnical Engineering Section, NRR, for the l
past 11 years.
I was employed for 9 years as Chief of the Analytical J
Eection, Scil Dynamics Branch, Soils Division at the Waterways Experiment O
Station,
U.S.
Army Corps of Engineers.
In this position. I was i
responsible. for special analytical and experimental Corps studies in soil i
and foundation dynamics as well as earthquake engineering aspects of earth and rock-fill dams.
The results of these studies have been I
published as Corps reports and as papers in national and international symposia and proceedings.
Prior to my employment with the Corps of Engineers, I was employed for 4 years as a Research Civil Engineer in the Soils and Pavements Division, Civil Engineering Department, Naval Civil i
Enginnering Laboratory, Bureau of Yards and Docks, Department of the t
Navy.
In this position, I was responsible for soil and foundation studies related to buried protective structures to resist the effects of nuclear weapons as well as design criteria for piles and other waterfront foundations.
My other professional experience includes University i
teaching appointments, from Instructor to Adjunct Professor, employment i
with a consulting engineering firm, and employment as a project and product engineer in industry.
My research contributions have been i
recognized by membership in Sigma XI-Scientif!c Research Society of i
America.
I am o member of the American Society of Civil Engineers and have been a registered professional engineer (by examination) in the State of Florida (PE 7816) since 1959.
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Raymond O. Gonzales O
Structural and Civil Engineering Section Engineering Branch Division of Pressurized Water Reactor Licensing-A Office of. Nuclear Reactor Regulation Professiona.1 Oualifications I am a Hydraulic Engineer in the Engineering Branch of the Division of Pressurized Water Reactor Licensing-A, Office of Nuclear Reactor Regulation.
I received my fomal educational training at New Mexico State University where I received a B.S.C.E in 1965.
I also attended an eleven month training program sponsored by the Board of Engineers for Rivet s and Harbors of the Corps of Engineers in Washington, D.C.
My experienct prior to joining NRC consists of j
Resources Planner,ydraulic Engineer (hydrology), three years as a, Water
- even years as a H and one year as a construction Engineer, all with the Corps of. Engineers in Albuquerque, New Mexico; San Francisco, California and Washington, D.C.
I joined the NRC in February 1978 as a Hydraulic Engineer.
In this capacity, I. review and interpret the hydrologic and hydraulic aspects of applications for nuclear facility construction permits and operating licenses. These facilities include nuclear reactors, uranium mills, fuel fabrication plants and low level waste repositories.
More specifically, I review the adequacy of flood protection designs of plants; determine the adequacy of safety related water suppliers, and evaluate the dispersion and dilution Q,
characteristics of nuclear facilities related to hydrologic engineering.
While at NRC I have reviewed the hydrologic engineering aspects of operating license applications for 10 nuclear generating plants and have written applicable portions of Safety Evaluation Reports and Environmental Statements for these 10 plants.
I also presented testimony at the Midland and Palo Verde ASLB hearings, From 1975 to 1978, I was a Water Resources Planner with the Corps of Engineers (COE) in Albuquerque, New Mexico.
I was responsible for managing planning studies for flood control, irrigation, hydropower, water supply, fish and wildlife and recreation.
In addition, I was responsible for coordinating study input from various planning disciplines including economists, hydrologists, designers and environmentalists, and for preparing cost estimates for planning programs.
From 1974 to 1975, I attended an eleven month training program with the Board of Engineers for Rivers and Harbors (BERH) in Washington, D.C.
The purpose of this training was to obtain intensive experience in national water policy and multi-disciplinary water resources planning through direct involvement in BERH review of COE survey reports, basin and project planning, instruction and experience in policy fomulation and instructional methods.
The objective of the program was to increase my p,rofessional competence to the level required to perform and successfully direct water and tFelated resource planning.
Raymond O. Gonzales
.g_
O From 1966' to 1973, I was a Hydraulic Engineer with the Corps of Engineers in Albuquerque, New Mexico and San Francisco, California.
During the early part of this period. (1966 to 1970) I assisted in hydrologic engineering studies of Corps of Engineers projects in New Mexico, Colorado, Kansas, Texas and Northern. California.
This included collecting and analyzing hydrologic and meteorologic data for use in planning and design, estimating long-term water availability, determining hypothetical flood events for use in sizing structures such as dams, channels, and levee systems, and preparing (portio of Hydrologic Engineering reports.
In the last part of the period 1971 to 1973) I was Head of a Hydrology Section.
In this capacity, I was responsible for planning, scheduling and. assigning studies of water resources projects to engineers and technicians in the Section.
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MR. DEWEY:
The panel is now ready for G
2 cross-examination.
3 JUDGE MARGULIES:
Intervenors may cross-examine.
4 MR. TINGLE:
The mike is not working.
5 JUDGE MARGULIES:
Have you tried the switch?
I 6
don't think any of them are working.
7 (Discussion off the record.)
8 MR. TINGLE:
Your lionor, would it be possible to 9
just have a short recess and analyze this and the corrections 10 here, or let the Applicants go?
11 JUDGE MARGULIES:
Are the Applicants prepared to 12 examine?
13 MR. CHURCHILL:
Your Honor, we have no A'_)
14 cross-examination for the Staff.
(
15 JUDGE MARGULIES:
We'll take a five-minute 16 recess.
17 (Recess. )
18 MR. LAWLESS:
Mr. Chairman, will we take a break 19 for lunch?
Have provisions been made to continue this 20 afternoon or are we planning to go strolght through?
21 JUDGE MARGULIES:
We would like to conclude the 22 hearing today if possible.
Certainly about 4:00, 23 MR. LAWLESS:
I think that's possible, but there 24 is a planned lunch brVak?
25 JUDGE MARGULIES:
We will take a lunch break.
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1 MR. LAWLESS:
I'm prepared on half of it.
Maybe I
'wd 2
can get through the rest of it while we are discussing these 3
things.
I think we are ready to proceed.
4 JUDGE MARGULIES:
You may start with your 5
cross-examination.
6 CROSS-EXAMINATION 7
BY MR. LAWLESS:
8 Q
Dr. Heller, on page 3 of your testimony, A.5b 9
indicates that additional wells in the marl aquielude are 10 required; do you think a well pattern in those additional 11 wells is important?
12 A
(lieller) Yes, I do.
13 Q
So it is an important consideration?
O(y 14 A
Yes.
15 Q
On (c ), discussing the confined Tuscaloosa aquifer 16 should be monitored for determining the long-term effects ot 17 withdrawing water.
In light of the testimony at the hearing, 18 do you believe that monitoring should -- excuse me -- do you 19 believe that monitoring of the Tuset.loosa should include 20 radiochemical analysis?
21 MR. DEWEY:
I object to that question, your 22 Honor.
Tryin issue was specifically ruled on by the floard as 23 not being a relevant contention in this proceeding.
24 MR. LAWLESS: ' Th.i s is in light of a follow-up on 25 whether there are slips in the pathways alongside the well o
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1 annuli. would monitoring of the Tuscaloosa be efficacious.
Ql 2
JUDGE MARGULIES:
We will permit the question.
3 You may answer.
4 THE WITNESS:
(Heller) Mr. Gonzales is our expert 5
on that particular item.
I'll turn the answer over to him.
6 BY MR. LAWLESS:
7 0
Thank you.
8 A
(Gonzales) The reason we had monitoring of the 9
Tuscaloosa is to determine whether there is going to be any 10 reversal in the gradient, and if that reversal occurs, would 11 it affect other users.
I am not involved in determining the 12 need for radiological monitoring of the groundwater.
That is 13 the responsibility of another branch within NRR.
I don't O()
14 know if, in fact, they are going to have a radiological 15 monitoring program of the groundwater.
16 Q
So at this time it's unknown?
17 A
It's unknown to me.
It may be known to somebody 18 else within NRC.
19 Q
Thank you.
On page 5 o{ Dr. Heller's testimony, 20 the last sentence, "The results of these tests indicate that 21 the marl permeability is about 10 to the minus 7 centimeters 22 per second; this value is consistent with the description and 23 classification of the marl formation."
24 In light of the testimony at the hearing, do you 25 still feel that this value is consistent?
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1 A
(Heller) I think that's about right; yes, sir.
xs 2
Q On page 6 of Mr. Gonzales' testimony, on the 3
adequacy of the hydrological exploration at the Vogtle site 4
he mentions this data in regard to laboratory permeability 5
tests.
My question is this:
In light of the information 6
developed during this hearing, do you still conclude that the 7
Applicant's hydrological exploration program is adequate and 8
acceptable?
9 A
(Gonzales) The reason we required additional 10 groundwater level monitoring was not related to any potential 11 radiological contamination of either the surface water 12 aquifer or the Tuscaloosa aquifer.
The reasons for our 13 monitoring, required monitoring program was, ore, to O()
14 determine conclusively what the design basis groundwater 15 level would be for subsurface hydrostatic loading on the 16 safety-related structures; the second requirement was to 17 monitor tne Tuscaloosa aquifer; and the third one is to 18 monitor the water table aquifer.
I'm sorry, there's three 19 portions for the monitoring program.
20 JUDGE MARGULIF',:
Did you get an answer to your 21 question?
22 MR. LAWLESS:
Actually, I think not.
I was 23 referring to the laboratory permeability tests that you have 24 listed on your third line.
25 BY MR. LAWLEGS:
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This data I took to mean to include the laboratory w.J 2
permeability test.
Maybe you meant for it not to be 3
included?
4 A
(Gonzales) No -- yes.
The more reliable of the 5
two tests are the packer tests, and the reason they are more 6
reliable is because you test a larger section of the 7
aquifer.
They tested 10-foot increments so you get some idea 8
of the permeability in that range.
9 The lab tests are not as reliable because you 1
10 necessarily have to take a disturbed sample.
It's a very 11 small sample and you just don't get the same reliabili ty in 12 the results so, as far as I'n concerned, the packer tests 13 provided much more reliable information on the permeability
(
14 of the marl than what the lab test did.
15 Q
And in light of all of the information developed 16 on the ii situ and the lab tests, you still, then, would 17 conclude that the exploration program is adequate and 18 acceptable?
19 A
Yes, I would.
20 Q
on page 7 of Mr. Gonzales' testimony, as 21 Dr. Heller testified earlier, that pattern was important; in 22 a similar vein, do you feel that the addition of wells in the 23 power block area is somewhat of a concern in the pattern of 24 where those wells are located?
Maj'e I should rephrase it 25 because I oet lost myself on the questions.
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Is the location of the wells an important G
2 consideration?
Should the wells just be placed any place, or 3
should the location be a consideration?
4 A
Since a backfill is a selected, uniformly 5
compacted material, I don't think it really matters where you 6
put the wells that are going to monitor for water levels for 7
use in determining the design basis groundwater level.
8 Q
Could it matter if those wells were potential 9
pathways of migration?
10 MR. DEWEY:
Is this a hypothetical question?
11 MR. LAWLEGS:
Yes, it's a hypothetical question.
12 THE WITNESS:
(Gonzales) Migration in a vertical 13 direction or horizontal direction or --
/~}
(,,
14 BY MR. LAWLESS:
15 Q
As we have discussed, if it is possible, 16 hypothetically, for slippage to occur alongside ot a well 17 annuli, or if it is possible for the well annull to become a 18 source, would it not be an important consideration to locate 19 those wells to prevent them becoming successful pathways?
20 MR. CHURCHILL:
Your Honor, I realize this is 21 cross-examination of the Staff's witnesses, but we all have 22 to protect the record.
The contention of wells as a 23 potential pathway f or cc$ntamination has clearly been ruled 24 out by the Board.
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-- into the question of the grouted wells beneath the power 2
block structures, but this has nothing to do with that.
3 The Board has clearly ruled this out, on pages 21 4
to 23 of its order.
5 JUDGE MARGULIES:
You may answer the question in 6
terms of the wells under the power block, but not in terms of 7
wells in general.
8 THE WITNESS:
(Gonzales) Would it be acceptable if 9
I refer this question to Dr. Heller?
He's a geotechnical 10 expert.
He's more qualified to respond.
11 BY MR. LAWLESS:
12 O
Fine.
13 A
(Heller) Your question is with respect to wells n()
14 located in the backfill and unconfined aquifer.
None of 15 those wells penetrate the marl, therefore there really is no 16 possibility for transport with these specific wells from the 17 upper aquifer to the lower.
18 Q
So you do not feel that the pattern is important 19 in that area?
20 A
No, I don't either.
21 0
Dr. Heller, on page 8 of your testimony, the test 22 results, your last sentence, "The test results from these 23 borings are set forth in Applicant's report."
In light of 24 testimony, do you feel the data is adequate?
25 A
Yes, I do.
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1 MR. LAWLESS:
One second, please.
C/
2 BY MR. LAWLESS:
3 Q
Dr. Healer, on page 9 of your testimony, the 4
second to last centence, "The results of these tests showed 5
the permeability of the marl to range from about 10 to the 6
minus 8 centimeters per second to about 10 to the minus 6 7
centimeters per second."
Do you think that the proper means 8
have been used to calculate this permeability?
9 A
(!!el ler ) The calculations of the permeability from 10 the laboratory tests are quite straightforward.
And they 11 have nothing to do with the harmonic mean or anything of that 12 kind.
I presume you understand t.h a t.
This is just a matter 13 of calculating laboratory results; and I feel those are rh (j
14 correct, yes.
15 Q
On page 10 of Dr. Heller's testimony the word that 16 was changed was supersede - forms part of the sentence, "In 17 my opinion these data supersede information collected from 10 the series 42 wells."
19 Do you feel the information supersedes and is 20 adequate?
21 A
Yes, sir, I do.
22 Q
On the same page, at A.13e of your testimony, Dr.
23 Heller, the earlier comment you made about the importance of 24 patterns, would that apply to number (c) as well, where the 25 additional geological and hydrological exploration is (3
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required, that that follow a particular pattern as well?
LJ 2
A I believe we have touched on that in previous 3
answers to questions to you.
The work has been done.
I 4
agree that the patterns are appropriate within the marl and 5
Mr. Gonzales has responded that the patterns are satisfactory 6
in the unconfined aquifers.
7 Q
On page 12 of Dr. Heller's testimony, your 8
conclusion at the bottom of question 14, in light ot 9
testimony at these hearings, do you still conclude that, with 10 respect to groundwater contamination, the thickness of the 11 marl is well known and the permeability has now been 12 appropriately established?
13 A
Yes, I agree with that conclusion, t
14 Q
On page 16 of Dr. Heller's testimony, in light of 15 the testimony on the interaction of the power block and 16 grouted wells beneath the power block -- may I rephrase that 17 to say on the possible interaction -- do you still believe 10 that the evidence is now sufficient to conclude that the narl 19 is continuous with respect to its aallity to impecip the 20 movement of groundwater from the upper aquifer to the lower 21 aquifer?
22 A
Yes. I do.
23 Q
On page 19 of Mr. Gonzalec' testimony, I think -
24 A
(Gonzales) Yes.
25 Q
Is that correct?
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1 A
That's correct.
's_/
2 0
In light of testimony as regards groundwater 3
divides, do you still conclude -- at the bottom of the page, 4
on page 19 -- do you still conclude that the flow would be 5
towards the northeast -- excuse me.
I said northeast, I 6
meant northwest.
7 A
Yes.
I agree that flow will be towards the O
northwest.
9 Q
In your professional opinion, Mr. Gonzales, do you 10 foresee ar.y possibility that contaminants could cross the 11 groundwater divide and move in a ditferent direction from 12 what is concluded here?
13 A
Based on 13 years of records, extending from 1971
()
14 to 1984, the configuration of the groundwater table has not 15 chanc.d significantly.
In those 13 years there has been a 16 groundwater divide located south of the plant, and in that 17 time the flow -- any potential flow is towards the 18 northwest.
There is no indication to me that that 19 groundwater divide will not be there throughout the life of 20 the plant.
21 Q
Were the groundwater divides discussed in the FES?
22 A
I don't believe that they were, no.
I was not --
23 I did not prepare the input to the FES.
But I don't think 24 that they were discussed.
25 MR. LAWLESS:
Is it an appropriate question to (O
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address the FES?
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2 JUDGE MARGULIES:
Do you want to confirm that in 3
the FES?
Do you want to look at the FES?
Is that what you l
4 want to do?
5 MR. LAWLESS:
The question would be this, if it l
6 were not in the FES, does that mean that the FES should 7
require -- does that mean that a supplemental to the FES 8
should be required?
9 MR. DEWEY:
I object to that question, your
[
l 10 Honor.
I think that's a Icgal question that this witness is l
l 11 not capable of answering.
l 12 JUDGE MARGULIES:
I'll let the witness answer if I
i 13 he can.
If he can't, let him say he can't.
O Q
14 THE WITNESS:
(Gonzalcs) I don't believe that the 15 mention of a groundwater divide in the FES would serve any 16 purpose.
I believe that when the reviewer looked at a 17 postulated core melt accident, that he assumed that the flow 18 would be the same as it would be for a tank spill and that's 19 towards the northwest.
20 BY MR. LAWLESS:
21 Q
Thank you.
Could I extend that same question to 22 the sink rate of the facility itself, to the panel, to b,th 23 individuals?
Did the FES discuss the sink rate of the Voctie 24 facility?
25 MR. CHURCHILL:
Excuse me, I don't believe the b}
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sink rate has ever been mentioned in testimony.
It's not 2
part of any issues here.
3 JUDGE PARIS:
Do you mean settlement rate?
4 MR. LAWLESS:
Yes.
I'm sorry.
Settlement.
I 5
believe we have our mikes back on.
6 MR. DEWEY:
I thought the settlement was no longer 7
in contention in this proceeding, so I object.
8 JUDGE MARGULIES:
It may relate to the grouted 9
wells under the power block.
We will permit the question.
10 THE WITNESS:
(lieller) I don't know the answer to 11-that question.
I didn't participate in any of the 12 environmental reviews, only the safety reviews.
13 JUDGE PARIS:
Well, is the settling of the qC' 14 structures of possible safety siqnificance?
15 Tile WITNESS: (lleller) That aspect has been taken 16 care of in the SER; yes, sir.
17 JUDGE PARIS:
Well, what can you tell us about the 18 settlement rate, then, from the SER or from your knowledge 19 with respect to the settling rate connected with the SER?
20 TIIE WITNESS: (Helle f Well, settling rates are 21 essentially related to the loads applied to the marl.
When 22 the backfill was removed -- not backfill -~ when the 23 overburden was removed, measurements of rebound were taken at 24 that time, during construction.
As I recall, they were in 25 the neighborhood of 4 inches, something like that.
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structures and backfill was plac ed I believe most of that 2
rebound has suffered a recompression, let's say, and I tiiink 3
there is a little bit of residual settlement still 4
occurring.
There's still a report to be issued on that 5
particular matter by the Applicant -- and I think the dates 6
and so forth have been agreed upon -- which relates to the 7
safety of the buildings, pipes and that sort of thing, which 8
is strictly a safety matter and not one of penetration of the 9
marl as we are discussing here.
10 Does that answer your question, sir?
11 JUDGE PARIS:
That's okay.
12 MR. LAWLESS:
Could I back up, actually, p
13 BY MR. LAWLESS:
14 C
Were there different rates for different parts of 15 structures on the power block?
Or were those numbers that 16 you just gave applicable through a cross -- was the 17 recompression as you mentioned, Dr. Heller, was that 18 concistent throuchout the power block area?
19 A
(Heller) There really aren't enough measurement 20 points throughout the power block area to answer that 21 question.
There are measurement points or.i number of the 22 structures located within the excavation.
I gue.ss one would 23 say, yes, they are consistent with the loa.in applied to the 24 t,uildings and consistent with the supporting media beneath 25 the buildings; yes, sir.
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1 Q
Not consistent but I meant at an equal rate.
The 2
resettlement -- I think recompression is the word you used --
3 was that at a uniform rate, the same uniform rate downward 4
throughout the power block area?
5 MR. CIIURCHILL:
Objection.
The only relevance of 6
settlement right now is on the issue of the qrouted wells.
7 When our witnesses come back to testify, they will be able to 8
testify that there are only three grouted wells beneath the 9
building of the power block, which is the auxiliary 10 building.
I don't mean to be testifying --
11 MR. LAWLESS:
I think he is.
12 MR. TINGLE:
I think he is and it seems to be a 13 touchy subject.
14 MR. CilURCHILL:
The differential settlement of any 15 of the buildings has not been shown to be of any relevanc'e.
16 MR. LAWLESS:
Whether they are or act is not the 17 question.
This was just a clarification on the testimony 18 that the witness himself cave.
19 JUDGE MARGULIES:
We don't see how it relates to 20 the wells and we will deny the adequacy of the question and 21 sustain the objection.
22 MR. CilURCIIILL :
Thank you.
23 MR. TINGLE:
Mr. Chairman, may I make a utatement 24 from what I know abr>ut it, which is very little?
Dut I do 25 know if you've got a power block that sits here and you've
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1 got an auxiliary building that sits here (indicating) and you 2
have rigid welded pipes between those buildings, if this 3
building cinks at a different rate than this building, then 4
those pipes are going to break.
It's a question of -- if you 5
don't want it in the record -- I mean, it would seem 6
important to me and I appreciate it.
7 JUDGE MARGULIES:
The matter that we have to 8
contend with here, Mr. Tingle, is the relevancy of the 9
inquiry to the matters being considered.
Although it may be 10 important in another context, within the context of this 11 hearing it is not relevant.
12 JUDGE PARIS:
We would trust that the Staff would 13 keep its eye on a problem like that and take appropriate 7-L 14 action if it became critical.
15 BY MR. LAWLESS:
16 Q
Mr. Gonzales, do you know what -- I'm sorry, let 17 me back up.
18 On page 22 of your testimony, in the middle 19 paragraph, are you familiar with point dilution methods?
20 A
(Gonzales) Yes, I am.
21 0
If a point dilution method is obtained at one 22 spot, is that not a point and the velocity at that point?
23 A
Yes.
I consider a point dilution measurement to 24 be a point determination of velocity.
25 Q
Do you know where, or at what point the 69 feet Ch L.)
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1 per year was determined?
2 A
The 69 you say?
3 0
Using the point dilution method, do you know the 4
geographical location of where that 69 feet per year was 5
obtained?
6 A
I looked at page 3-24 of the DPSD-83-829, volume 1 7
report.
8 Q
Could you do that a little slower?
9 A
It's page 3-24 of the DpSD-83-829, volume 1 10 report.
11 That page describes the dilution -- point dilution A
12 measurement that was made and there is no information there f3 13 on how or where these tests were performed.
I don't. really f
~
14 know where they were performed.
15 Q
Thank you.
Based on your professional experience, 16 would you expect that the locatlon, the ceographical location 17 that was used to determine the 69 feet per year, would you 10 expect that that qeographical location would be the same as 19 the locatic;n that determined the 2.3 teet per year?
?. 0 A
No.
21 0
Would you expect them to be in close physical 22 proximity?
23 A
I don't know.
They could be.
24 0
In your knowledge ot groundwater divides, when you 25 are sitting on top of a groundwater divid",
but in uenoral,
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what do typical velocities appear to be?
2 A
I wculd expect a typical configuration of 3
groundwater to result in lower velecities at the divide and 4
higher velocities where the contourc become closer.
S Q
Would it be appropriate to use an average of a 6
number that was obtained in point dilution tects?
Would it 7
be appropriate to use these numbers from a point acar a 8
divide and a point further downstream from a divide to come 9
up with the calculated groundwater velocity?
10 MR. CilDRCiiILL:
Your lionor, could I ask the 11 relevance of this?
The testimony in this proceeding is that 12 the groundwater velocities used at Plant Vogtle were not i
13 determined by point dilution studies.
14 MR. LAWLESS:
I'm just dealing with hic testimony, 15 your lionor.
The next centence says, "The average of the two 16 la about 36 feet per year."
That's what I'm dealing with.
17 MR. TIf1GLE:
Your lionor, with my limited legal 10 knowledge it seenn like this is turning into --
19 JUDGE MARGULIEC:
Juct one minute.
We will permit 20 the question.
Ycu may proceed.
21 Tile WITf1EUS : (Go n z a l e s ) May I have the question 22 again, please?
23 MR. LAWLEus:
- Gure, i
24 DY MR. LAWLESS:
25 0
In determining average velocities, in it a good
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idea to use a groundwater velocity calculated from a point 2
dilution spot near the groundwater divide and one further 3
downstream from the groundwater divide to obtain a true 4
estimate of the groundwater velocity?
5 A
(Gonzales) I guess that would depend on what you 6
were trying to accomplish in your determinatiori of 7
groundwater velocity.
8 Related to Vogtle, we used -- we were concervative 9
in our assumption and we used a velocity
- I'm corry -- we 10 maximized the velocity by using a maximum value for 11 permeability and a minimum value for effective porosity.
We 12 did not use an averace velocity for determining groundv'ater p
13 velocity -- I'm sorry -- we did not use an average of those O
14 factors for determining a groundwater velocity.
15 Q
Right.
I understand that.
I was just dealing 16 with the comment that the average of the two is about 36 feet 17 per year, which is approximately equal to the Darcy 10 velocity.
And I kind of liked your answer.
I would just 19 like to generalize it and see if you agree with that.
20 In general, it depends on where you are wanting to 21 calculate the groundwater velocity, so you should be careful 22 in just lumping two things together?
23 A
(Gonzales) Yes, that'c true.
24 JUDGE PARIO:
Let me pick up on this tor a moment 25 if you would, Mr. Lawleuc, because I had a question about it ACE. FEDERAL REPonTEns, INC.
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2 EXAMINATION 3
BY JUDGE PARIG:
4 Q
Mr. Gonzales, you took -- well, looking back at 5
DPSD-83-829 volume 1, page 3-24, it says that a eeries of 6
tracer dilution tests and tracer injection detection tests 7
yield velocities from 2.3 to 6.9 feet per year.
From that 8
sentence would you conclude that they took a number of tracer 9
dilution tests with values that ranged from a low of 2.3 to a 10 hi;1h of 6.9?
11 A
That is the impression I got when I read that 12 page.
n 13 Q
How much validity -- now, an average is a k'
14 statistic, is it not?
15 A
I -- I -- yes.
16 Q
Take it trom me it is.
17 A
Yes.
18 Q
Ilow much validity do you think there is in an 19 average based on the lowest value and the highest value in a 20 series of values?
21 A
Of courne that would be dependent on the 22 distribution of the different readings.
23 Q
That is correct.
Go can you answer the question?
24 A
May I have the question again?
25 Q
Ilow much -- just in general terms, how much ACE FEDERAL REPORTERS, INC.
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1 validity or how much confidence would you be willing to put
)
2 into an average based on the lowest value and the highest l
3 value in a series of observations about which you know 4
nothing in between these two?
5 A
I wouldn't put very nuch validity in that.
i 6
JUDGE PARIS:
All right.
Thank you.
I'm done, t
i i
7 Mr. Lawless.
}
l 0
MR. LAWLESS:
I might point out he has a fine ij 9
discucslon of that on page 23.
I J
10 Those are all the questions that I have.
I l
11 JUDGE MARGULIES:
Do you have any ques tions, I
12 Dr. Paris?
I I
13 JUDGE PARIS:
I have one more, I think.
I quess j
14 thiu goes to Mr. Conzales, again.
i 1
15 At paqe 23, at the bottom of the page you say, I
j 16 "The point to be made here" -- the paragraph beginning at the
)
17 bottom of the page -
"The point to be made here is that l
18 average groundwater velocities cannot be compared with point i
j 19 values."
20 My qtinc tion is which do yoti consider to be nore 21 rollable, calculated values based on accumed parameter solueu I
22 or an average value based on obcerved field tents?
23 Tile WITNESS: (Gon za l e s ) An actual fleid test i
i 24 meacurement is much more reliable than one that la computed, I
l 25 calculated.
i O-
)
i i
ace. FEDERAL REPORTERS, INC.
l 202.m.37<u s.iion.iae co,er..
mx33uu4
26116.0 BRT 785 (3
(j 1
JUDGE PARIS:
Okay.
Thank you.
2 JUDGE MARGULIES:
Judge Linenberger?
3 JUDGE LINENDEHGER:
Perhaps one question.
4 EXAMINATION 5
BY JUDGE LINENDERGER:
6 Q
Gentlemen, in reviewing your testimony previously, 7
and in the discussions heard this mornino, I have detected 8
nothing that would indicate any substantive disagreement 9
between you -- between Staff and Applicants.
On the other 10 hand, I'm wonderino whether you gentlemen -- let me ask.
11 llave you gentlemen reviewed Applicant 's prefiled testimony on 12 this groundwater subject
- t. hat has been before the Board?
13 A
(Gonzales) Yes, cir.
v 14 A
(llell e r ) Yea, we have.
15 Q
Have you listened to the discussion and questions 16 about that testimony in these hearings the last two or three 11 days?
IU A
Yes, sir.
We have been here every day.
19 0
Then let me just ask, do you have any areas af 20 substantive dLaap eenent with the material that has been 21 presented or the answera that have been olven by Applicant's 22 witnes3es on the o.oundwater contention subject?
23 A
I'll respond first.
I have no substantial 24 objections because I auree with their f1na1 conc 1unlons on 25 all aspects that relate to the contention.
Au far as (VD ACE. FEDERAL REvonTEns, INC.
202 347.1700 Nationalde Coverage NIk3)MM4
26116.0 BRT 786
(~')
V 1
methodology and approaches and so forth, I reserve the 2
differences between an engineer and a geologist's perception 3
of the problem.
4 0
Same ques tion to you, Mr. Gon:: ales.
5 A
(Gonzales) I basically agree with what Dr. 11el l e r 6
has said.
I don't have any substantive disagreements with 7
the general conclusions that were reached by the Appiicants.
8 JUDGE LINENBERGEH:
All right, gentlemen.
Thank 9
you.
That's all I have.
10 JUDGE MAHOULIES:
Mr. Dewey?
11 MR. DEWEY:
I have no redirect.
12 JUDGE PARIS:
Mr. IIeller, in your answer to Judge 13 Linenberqer's questions you implied that you saw things C<
14 differently from the Applicant's hydroqeologists.
I wondered 15 if you could tell us what you perceiv; differently, what 16 problema you perceive in a different way they do, and how?
17 Or did I micunderstand what you seemed to be implying?
10 Till' WITNESS :
(lle l l e r ) Questions of thic kind are 19 very ditricult because of the variance in backgrounds ot the 20 dlf.terent witnenoes that have been here today.
21 My reply to Judge Linenberger was that I had no 22 problena with the bottom 11ne ot tholr conclualons, which in 23 that the marl la plenty thick, it 1.1 plen ty perinea b1" -- th" 24 ability to impede the itow of water without any problena.
25 Th"y look at the data in terma of namen for ditterent O
U l
Act! Fiint!RAL Rt! PORTERS, INC.
202 347 37(N)
Nationalde Coverage fl4Xk)36 M46
26116.0 BRT 707 O
'V 1
tormations and so forth, whereas an engineer looks more at 1
2 the quantitative aspecta of the information to come to his 3
conclusions.
In that respect I consider that there in no 4
substantial dicaqreement, only in the means of arriving at 5
the final conclusiona.
6 JUDGE PARIS:
Are you saying you would 3ike more 7
numbera?
l 8
Tile WITNESS :
(lle l le r ) I'm caying I baaed my 9
conclusions on nurnbers.
They bane their conclusions on l
l 10 history of the formationa.
l 11 JUDGE PARID:
Well, I quesa maybe you and I l
l 12 perceive their teatimony a bit differontly.
Okay.
That'n I
13 fine.
Thank you.
14 JUDGE M ARGill,11:S :
In thete anythinq further of the 15 witneca?
16 MR. LAWLEGG flo, sir.
17 JUDGE MARGULII:U The witnenaco -- you are IU oxcuuod, panel.
Thank you very much.
I 'd (l'a nel excused. )
Your lionor, earlier when you 21 mentloned you wanted to recall nome Utaf[ witneouen and 1 22 asked f or a few minuten --
23 MR. DUWCY I t hink you cald Applicant 'n i
24 W1ther:neu, not GtafI witnvacea.
25 MR. ClluRCilILL I don't think wo need that bleak.
O ACl!.Fl!Dl!RAL RI!!'ORTl!RS, INC.
202 W a h o Nanono kle coverese suoMeMA
.. _ _.. _. _ _ _. _. - -.. _. _ _ ~. _ _ _ _.
t i
26116.0 DRT 700 i
(7 i
,b 1
In the interests of time, our witnesses are prepared to come l
l 2
up now.
l i
l l
3 MR. TINGLE:
Your Honor, we have been on the road 4
since 4:00 this morning and we got up at 3:00.
A few more i
5 minutes -- if not a tull break, at least some kind of break i
?
l 6
before we start in?
l 1
7 JUDCE MARGULIES:
Are you askin! for a luncheon j
8 break?
Is that what you want at this point?
1 I
9 MR. TINULE:
Gomething a little longer than 10 l
l 10 minutes, if you don't mind, i
{
11 JUDOU MARGULIEG:
It's close to 12:00 now.
Let's l
12 take a luncheon break until 1:00, 1
13 MR. TINGLE:
Thank you.
l 14 (Whereupon, at 11:55 a.m.
the hearing was i
j 15 r e c e a d ml, to be reconvened at 1:00 p.m.)
f 16 5
j 17 4
j 10 19 20 21 22
]
23 i
i i
24 I
i a,
i n j
v l
i 1
1 l
Act!.FlintinAI. RI:i'onitins, INC.
20214WW NaHoneide Comage m)M(m
26116.O DHT 789 1
AFTERNOON GEGSION (1:00 p.m. )
2 JUDGE MARGULIES:
Dack on the record, 3
Mr. Churchill, are you ready to proceed?
4 MR. DAVENp0HT:
Yes, we are, your lionor.
5 JUDGE MARGULIES:
Are you going to handle thlo, 6
Mr. Davenport?
7 MH. DAVENPORT:
Yec, your lionor.
Can we have the O
panel back en aroundwator.
9 Whereupon, 10 Til0M AG W.
C H OGilY,
11 LEWIS H.
- WEST, 12 CLIFFORD it.
P A li H E LI,,
13 and O
14 UTAVHOG C.
l' A P A Dol'U Lou 15 reaumed the otand and, having been provloualy duly nworn, 16 were examinod and toctitled iurther ao follown 1/
JIIDal: M A Hullt. I ES :
You may proceed.
1 11 D I H Er'T 1:XAMillATION 19 IlY MR. DAVENP0HT:
20 0
Mr. Wont., I worn like to addroen rirdt th"
?!
quent100 of how many orout.ed holen thote ate bonoath tho 22 power block atructuno.
t,.. t me roier you ta rinure 4 or your 21 tnatImony.
24 A
(Wonf) I havn it.
/ '.
O Would you identify, please, thone grouted core O
Act! Fl!Dl!RAI. Rl!PORil!RS, INC, 202 H747m Nethma kle Ometese mniMfMA
26116.O DRT 790 O
V 1
holes that are beneath the auxiliary building that are shown 2
on this tiqure?
3 A
Yes.
It's holen 514, 102 and 319.
4 MR. LAWLEGUI One more time, pleace?
JUDGE PARIG Which figure are you looking at?
6 MR. DAVENPORT:
l'igure 4 of the tcatimony, your 7
lio no r.
They have a blow-up diaoram in the upper right-hand 0
corner tl. L may be mote 5elpful.
l 9
MR. LAWLEGUI Could you atalt again with those t
i j
10 numbern, pleace?
l 11 Ti!E WITNEGG (We n t. ) S14, 102, J19.
l 12 DY Mit. DAVENPORT:
l l
13 0
And how many orouted core holes ate there beneath 14 the unit I containment buildinqu?
IS A
There are 11.
16 0
llow nany qtouted holen arn there bencath tho tin i t 17
/ cont ainment building?
l l
lil A
Three.
19 MR. LAWLl;UG r 'm not t y.
.funt a 11ttle Illowel.
10 Thino b"nnath the auxL11aty?
21 Tile WITNEGO:
(West) Yoo.
2/
MR. LAWLE00:
And then thric wot'e hou many beneath l
1 l
l 21 tha l
24 Hlt. l'AVENPOkT Woulel you run thl ouqh tho aiuml>nt rt l
2 ',
aquin for Mi, l.a w l e n n, please?
i l
3
~J 1
l l
ACibFl!Dl!RAl. Rl!!'ORitRS, INC.
202d4mm Nanon*kle Courne mn.1m IMa
l t
26116.0 DRT 791 l
IO jb 1
Tif E WITtJEUU :
(West) Three holen located under the i
l 1
2 auxiliary building; 11 holes located under the unit 1 l
I 3
containment buildinq; three holes located under the unit 2 j
i 4
containment buildinq, S
BY MR. D AVEllPORT :
l 6
Q llow many grouted core holea ate located under the i
I 7
turb!no buildinq?
H A
(West) Geven.
9 0
llow many grouted coto holen are thote in the I
10 backfill area generally?
A 42.
12 0
Aro the remaintno holen, that are not under the 13 foor buildings that we mentioned, underneath ntructuren in O
14 the backfill alea?
i l ')
A IJ o,
16 0
Dood the turbino building tent on top of the nail?
the turtelne buildinq?
(
17 A
Yea, it doen 1
10 0
Yen.
l i
l'I A
Oh, no.
70 0
Dorn the aux 111ary bullillnq rent on top of tbo
?!
marly 22 4
Yed.
The auxillary buildinq dood.
23 y
12 0 the con t.a l lurie n t laulldinua test on top of t he.
21 marly 2$
A The ~' y e 'll, t h t' C e n t e t" pol'llon of t he'N.
(
O t
I Acl!.I!Dl!RAI, Rl!!'OR'il!RS. INC.
- onno 8.n.. u em.....
mowum
I I
I k
26116.0 l
DRT 192 i
lb t
V 1
Q In there a figure in your teatimony that would i
l 2
show the containment building?
j l
3 A
Yes, there in.
Figure 6.
}
4 Q
An I correct that only the center portion of the 4
i 5
containment building ba3e mat recta upon t he marl nurface?
l 1
6 A
Yea.
j-i l
7 0
Thea" grouted core holen in the power block atea
[
+
I O
-- let me ack you first, Mr. Went, are there any otouted l
)
9 wolla in the power block area?
10 A
Only the 42 nerien holes that we d i tic u a n mi l
t 11 yesterday and holo 101-A.
j i
j 12 Q
The 42 serien welle, are those boncath any 1
Os
~
13 titIuetute7 j
14 A
flo.
l f
I iS Q
llo l e 101-A, in that beneath a atsueture?
j
\\
l 16 A
You.
The unit 2 containment.
17 Q
Thank you.
10 Mt. Cronby, in the mart more or loan riold than 19 the arout columna in thoue istouted holna?
20 A
(C ocby) The nar1 La moto rigid than the utout
?!
colunnn.
2?
Q Would you export nett1"mont of the marl to ploduen j
2J a l i pp.oJn between the yrvot colunos and the mari/
l 21 A
fio, I would not.
I l
2S Q
Why not?
1 t
Aci!.1'l!Dl!RAl. Rlil'URil!RS, INC.
20244MNn Neo in.kle cineeave mioin sua
I l
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2 ts 116. 0 DRT 79a l
l C4 1
A There are several very good reasons why there I
l 2
would not be differential movement between the two.
The
}
I j
3 first is that there la a very large aurface area around the l
4 outside of the core hole, and a very amall curface area at
(
l I
L the base of the hole where this proposed punching would t
l 6
occur.
That's more than a aufficient amount of frictional I
area to prevnnt movettent as postulated, t
I O
The claJllC propeltien of the marl are much hlqher l
9 than the weight imponed by the structurea, and as a t e r.u l t j
10 the elaatic natute of the marl would tend to close any l
11 surfacea that would vpen up.
And the laut thing 10, the
}
(
12 undetlying unnamed reanda are an denan or donnor than the l
r 13 marl, and as a roault you do not qet motion or pur.chinq into O
14 the lower datul.
lb o
Mr. Crosby, let me ank you to acaume for a minute l
i i
10 that auch clippaqo an decet Ibed by Mr. Lawicoo did occur; i
17 what can you nay about tho bond between the marl an1 the i
10 41out?
i A
The bond la a vnty liqht one.
Lemont vetour a l
20 rock matorial liko
- t. h e mai l pr eventa a very t iqht bond; and i
l l
?!
thia la a atandar d pt act ice uand in the oil induatry for l
l 22 yeata for seallnq Wolls in many atcau of th" wotld and han t
r 23 boon uned over and ovnt again.
24 The 1tredul.ir nuliaco of ihe cor e hole 1 1.i e.1 f, It 25 is not a nmooth cylindot on you taay envin ton.
It's vety Acibi'I!I)I!RAI RI!i'oRI1:Rs INC.
- ormmin i%n.u r.ne..,
=oim u.a w
=.
=
6 4
t 26116.0 j
t 11RT 794 l
O
}b 1
irrequiar and again that adds to the frictioral realutance to 2
any kiint nt ditterential movement.
And, finally, the i
l 1
overburden preatture of the weight of the backfill, which ic 4
about 800 f.eet thick, as well as the weight of the i
S atructures, imposco on elaa t.lc precoure that would clooe ott, l
l 6
again, any opace that may develop, i
i 4
7 Q
Io cettlement complete at Plant Vogt.le, I
i.
i I
i 0
Mr. Crosby'?
I i
9 A
To the beat of my knowledge it in noarly i
10 complete.
Thia 11 not my area ot expertice, but in 4
}
11 preacntationa I h..vo troon before, the amount of nettienent ic i
e a
12 directly tied to the amount of backfillino which han 11 occurred.
Uineo tho backfil1inq l it now about 99 poi cent O
14 complete, the amount of 1:e t. t l e m o n t to also n" Ally complete.
{
I 15 I nave neon orapho whleh doplet that the 16 nettlomont i ts ver y low throuqh the laat few months, which i st l
l 17 connlatent with the amount of backtill which han been placed.
{
f l
10 0
bhen you uay "vrt y low," can you quantity that in j
l l
19 any w.sy?
At o we talkinu about ledd than an inch?
Ilatf an
\\
4' l
10 inch?
}
r 71 A
Yet c.
The total net stottlement thtough thn whole
/2 l>ack fi ll i w; a nd excava t i on pl occo rt id loss than 1 loch.
Do 1
/3 the afnoulit o f ti e t t l o nt s? n t whleh in Joini; to occut in the 14 tututo la fat inca than that.
2 ',
O tioen tho hoad diffetonttal titL11 oxint tetween the O
f AcibFimi!nM. Riti'onflins INC.
e n m.no 8.n.,n.as,ro,,,,,,
m u s a <4*
v.-..
....c.
i 26116.0 13RT 795 i
AU 1
water table aquifer and the Tert.iary aquifer in the vicinity 2
of the power block?
)
A Yen, it doca.
The consistent maintained head 4
difference of. S *a teet between the water tabir aquifer and l
5 contained a<ltilfer demonstrate that there tu no exchanqe of 1
l 6
oroundwater between the two aquifera.
That's all the quentloon we have, l
0 your lionor, t
9 JUDGl! MARut!!,IEG :
Crona-exanination?
10 Mit.
1, AW LEU S :
Yeu, air.
11 Cif 0Ju -l:X AM I fl ATinti 12 11Y MR.
1, AWI, td i L3 0
1,et me tako it in levetce firet.
Mt. Cro:1by, you 14 mentioned if the allpa illd
- excuee me, the queotion 1,y tho l *,
attotney to you waci If a llpn did ocetit, what would happen?
10 And you dald the typn of brind that you una would provent the i
11 allpn.
In that nomewh,it accurate?
lll A
(C onby) tJ o.
That'n not at al1 accura.n.
j 19 0
(*ould you tentate i t., then?
11" nald if n i l pts l
l 20 occut what wotild happon/
And yout' ro n pun tie wad
- ' 1 A
Maybo it would be bntter ii yots h of the tentlmony l
??
- topvated,
/1 MH. Cllliff UllI I,1,1 The quarst ton waa if, 14 bylio t ho t lea l l y, nilpn did occut, what could you cay about the 1
l tion ly
/ri O
1 l
ACl!.lll!!)l!N Al. Rl!IHRil!NS, INC.
nwmm Nanimo ue t'.nv ne mnsso,u.u
_ _ _ _. ~. _ - - - - -
)
4
?
l I
26116.0 3
DRT 196
[
I i
G 1
MH. LAWLEGG Yes.
l I
2 Tile WITNEGG:
(Crosby) Could you repeat the I
3 question?
f I
4 ilY MR. LAWI.CGG l
{
5 0
And your reaponse to that was that bonding would
{
s 6
prevent n11po.
That seema backwards somehow.
If ulipn would
(
i 7
happen, what would happen?
Gilpo would not occur?
It avemn i
(
U if we take all ther other worda involved out, if slipa occur,
)
l 9
nilps would not occur.
Ilow can it ulip and not n!Lp; l
I 10 A
(Croaby) I'm carr y if I contueed you.
I am rayind i
4
)
11 the coment bond would ptevent alipping; and to reply more l
12 costretly, if thorn wad a break in the bond, the over bur den I
j l
11 prennuto would cluso that bond becauce o; the oladtle nature j
j 14 of the marl.
lb Q
Ye1.
That'n a dltrotent k ri n u n.
Ilu t thnn 11 allpa 16 occur han notf.1ng Irally to do wlth thn bond.
Once thn n11p 17 occuan, tho bonil l et broken at that timos in that correct?
10 A
(Ctonby) Thone ate your wordJ, not mlne.
19 0
l'm nekito) you, to that cottoct?
!! rillp doen 10 occur, In tho borul 1 okon?
i 21 A
If that's a hypothntical that would bo tsun.
21 O
Aqaine that adds to the commont that you mado j
l 2.I a bt illl II I'qu!oIkf.ked.
I Hilll'.'
{ bat t hf'il e Wollld n()\\ D f' a
si nmootn autraces in.no would oc nnm.iroun ti rvoulai t uca and 25 tho 11 I eqillaI L t init Wnold add to t h:4 [tletlunal f o f e t' 1o f
Atl!.iti!!)l!NAl Rlil'ONil!NS, INC.
l 2nl w n n 8.mn.a.c....,,,,
me,w,
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1 26116.0 bitT 797 O
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provent movement.
Ilowever, once friction in overcome, what l
l 2
doen happen?
i i
3 A
l'irnt at all, the uhearinc wotild not occur becauco 4
the elastic nature of the materlain in not excee<ted.
S Q
I don't think that relates to your comment about i
6 triction.
Juat a very diroct question, what happen.1 once j
}
7 triction in overevme?
)
t
()
A (l'a padopul os ) What would overcomo the triction, 9
Mr. Lawlenu?
l 10 0
I think that'n a diftetent quention.
l 11 A
The triction will always exint.
If you have o j
i
'2 strona, the friction would result in como att alnn wi thin the I
13
<st out and nom" n t rains on tbc marl.
liu t there will alwayn be t
O 14 fi letion bet ween t wo matorla ta which are in contact.
lb v
- Yen, i
16 A
un your n t. a t e me n t, once the filetion l it ovetcome, il in not vety cleat to ho, i
1 11 0
thank you, DI. l'a pa d o p u l o:1.
Uut back to s
19 N:. cionby, you made a comment on faletlon.
What happenn 20 onco fIletnon in overcohr, 1f 1t enuid ba ovoreohn,
?!
hypothntleally?
n A
(vio1by) I'm deallins with thn real worlel been.
21 Whnte wo aro t.ilkitut about 4 001 holer thtonish tho mall, il 1
)
24 yiHI oln t a l k ilvi about n o fn ** t h l f RJ hypot hot t rla l, l'h not nule it l
ss i n.i, m a... to in., qu,,ntion.
O t
Ati!.Fl!!)l!NAl. Rlil'ORil!NN. INC.
}
202w.nm Netk n.hte rmone, mitwaA L
l l
j 26116.0
)
IJHT 190
?
1 Q
I think it la ystmane.
You brouuht up the tople, 2
You mentioned friction.
You rald theto were irredularitten 3
on the surtaen that increase the t a le t ion componetit which 4
I 4
prevented movement, a nd I ' m a tt k i nq you just vosy directly,
'i w h,' t would happen if that friction waa overcono?
f 6
M!t. CilU HCllli,1, i Your lionor, I think I
[
7 Dr. palmdopu loa expla i ned t he ba f f~lement of the fina rd.
Ilo O
donnn't underntanil tho phynleal conenpt involved in botng i
9 asked if friction wero overcome, becanon friction la alwayd l
I
[
l 10 there.
If we cotild have an explanation f ron Mt. I,awlena what 11 ho meano by frietton bring overcomr?
3 f
1/
Mk. !J Wl,1c'iti t That'n a very cloir technteal term.
l 13 l'rletion botorn movem" tit in known an ntatic filetion.
14 l'r l e t i o n onco that at,itle novement -- static I letion in e
15 overcome, tha otatle ftletton heconen dynanic !rietlon.
1 in did not ntato th" tiletion will dinappear.
The irletion will 11 alwayd hn thete.
Tho qunrttinn is very dilect.
W h a t.
happonn 10 when tho atatle fttel100 in ovetcomo/
19 MH. CllllN ell ! !.1,1 That'n a9puminq a fact not in
/0 ovidonen.
9 hypothetIca1.
W"
?!
.tll!Hil; M AhGill,II:M i It'a a
//
tinde t o f a tul it'd a 1,i y po t h e t l e a l.
i
/l if thn w i t n n ri tt ca n ' t annwo it, plearto lot him l
i
/4 re it n that h,. can't an woi that.
1 i
l
/%
Till: W I T NI:U S :
(M orthy) Y ".t.
t ca n' t a n r> w o t that.
t
(
Aci!.It :l*NAI. Rl!!'ORIl!MN, INC.
i nmmon s..w.n.si,o,,.t...
mn m um p
I 26116.0 l
DitT 799 I
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1 IlY M!t. LAWLl> Gut l
l 2
0 You alvo were acked quantiona about setttonent and i
l 3
you mentioned the word "think," you think it would be auch 4
a int such.
Are yo's an expert on the settlement innuo?
l l
5 A
(Closby) No, I am not, l
I 6
Q Thank you.
When you mentioned that the nottlement 7
would be leua than 1 inch, wau that the total aattiement 0
including tobound uttect?
i l
9 A
No, I said that was a not nettlement.
l l
l 10 0
The not dottlement.
(
11 Mr. Cr o:t by, you nald that the marl waa tuore riqld l
12 than the coluno; in that correct?
1.)
A Yea.
Than the at out colutan.
O 14 Q
l don't know if I can find it in tectimony.
Maybe l
I l$
the panel can help mo.
There 18 some location in the l
16 testimony where th"re was a discuttalon about tho l
l 11 comprensibility of the ma i 1.
Could the panni alert me to l
10 whern that wan locatel?
19 A
In out pt of lied tactihony?
1 20 0
Ye a.
21 A
I don t think it'n in t her e.
N M i<. C H ul<cill L t.1 That wad not an innue, your lionor, 23 and 1 don't bntlevo theto'n any dit?ct tontimony on it.
/4 Mf t, l.AWI,1:UGI W"
ato dnalind with the L ;t o no h"In.
26 Th"I'O Wan puma comment mado a bo it thn c o n p t.* g rt i b [ 1 1 t y o g ihn l
i Aci!.1'Itoi!RAI. Riil'on t I!Ns, INC.
i nmum s.am.u, to,c.,.
m o n w.u.
I
l 26116.0 L1RT 000 O(/
1 clastle propertica of the marl nomewhere in the testimony and 2
it la relevant to this question.
l 3
Till: WITilCGG (papadopulon) If you Lind it and l
l 4
point it out to un we'll bo happy to I
i 5
MH. h AWLI:33 :
Maybe we cotild have a bseak until I 1
6 could find it?
Or with the Dettd'n indulgence, I could just 7
take a few minutec and ace 1[ I can Clip my way through it?
1 0
(D1neuodlon ofI the Iecord.)
l i
')
Till: WITilEUDs (C1ocby) Mr. Lawlean, we ate quite 10 contident that it la not dlncuaard in the testimony, 11 MH.
- l. A WI,I:C U I don't know that I can Lind ic at 12 thn moment.
1I JtibdB MAHOUI.II:D Why don't you otate it an a 14 h y po t ho t. l ea l,
i l 's HY MH. hAWhMGUI 16 0
Ai1 1 14h t..
Mt, cionby, thetn in movemont of tho 17 marl; in that cortnet?
10 A
(cronby) Yon.
We dincumnad thn cettlemnnt, thr 19 umall amount of movennnt.
20 0
Go thero has inaen movemon t up and movemont l'ack
/1 down?
I
//
A Yog.
A vesy amall amount.
The anount is woll
/1 within thn oladtle ps oport lod of tho mail.
l 24 9
do that thn nat! done have olautle psopostlw ?
l l
2b A
Ynd.
L l
l l
Atl!.Illl)l!NAl. Rl!l'OR Tl:RS 'NC.
l Inno.nm s o n.u,r.,,o,,
anm t
t I
26116.0 g
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I C
1 O
What are those clautic propet tica?
A They are diccuaned in ocetion 2.5.4 of the PGAR f
3 and l'SAR.
j 4
0 Can you tell m9 what they ate at thin time?
5 A
flu, I can't repeat them.
i l
6 Q
Olve me that eltation again?
i j
7 A
2.S.4.
l 0
Q PG Alt ?
l
!)
A Yen.
g i
10 Q
And 6. hot are tho olantle ptopertier of the grouted
- l I
11 wolla?
12 A
They atn Iran than the ma t-1.
13 0
I ilo n ' t understand.
In othet wotJd, tho man 1 in i
14 mote riantle than t h" ot out ed wello ?
la that what you at.:
I 15 n a y lirl?
16 A
flo.
The quentlun, I bollevo, wan could you 17 trad th" qu"otlon aqaln, pleano?
10 0
What ato th" clar41le propentica of the giouted i
l '1 welin?
j 20 A
tio.
That waa not the quodtlon that I annweted
/1 ratlies to Mt. Davonputt.
?2 MR. h AWI.imu s Thia in an entitely dittnient 23 quodtlon.
t'oill d wn havo the quon t i on r oad liack ?
/4 J ill 01: M A Rolli,I I:3 W aald the opattei to,id back th" lb last two gunstionn?
a Acit Fitt>l:RAI, Rl!!'oMil:Ns, INC.
202147.)*tH Pianonektf fmetage N O )M fA4A
26116.0 DHT 002 Od 1
(The reporter read the 1ccold ao requested.)
2 Till WITfil:US :
(Crosby) I understand what you are l
.I as a y i ng.
4 by MR. LAWLEGG 5
o to your anewer to the questiona, what are the 6
clat Lie pr oper t icu of the 9: outed wollo, your answer la leon 1
thin the marl?
il A
(CroJby) 1,et me put it this way, in my own wurd:1 i
l 9
The marl 18 more -- I'm norry.
I'm loninq it here.
l 10 0
Take your time, please, l
l f
11 A
The marl la mute t' lg id than the grouted holen.
l 1/
JllDGl: l' Alt I D :
tJow you are conturlini me.
Io their l
13 a liffe ence between clant icity arnt 1141dity?
f O
l t
14 Till: W ITtJiniu s (C r o riby )
Y"a, thern wan.
l 15 I;X AMIll AT10ll l
16 hY Jlllnll; l' AR 10 :
l l
l 11 0
A few minuten auo you :ald the manI wao mot" i
la riantic than th" grout: Inght?
I l '1 A
(Crooby) kloht.
20 0
Inst i t ' it mute flyld than tho atuut/
11 A
Y.- a.
22 g
What'4 the relationshig, between iloidity and
,)
etanticity?
I 'n cont uand.
21 A
l' I t a t o f all, claatlelty 1 contuded that wit.h l
1luli'ity, anni that waa my mlatake.
All I can c.ay in my own e
i l
i ACl! ll!!)l!RAl, Nlil'ORIliHS INC.
I lo2 Ht Jim N onekleunmar mn1%fM4 l
26116.0 f
DRT 003 1
l IO V
1 wordu
-- the statement I can make la the marl is more riold I
1 f
j 2
han the grout 13.
O k a y'?
As far as clastleity, I do not l'
I 3
know for a fact the relative difference between the two.
4 Q
Co you are refuting your earlier statement that j
5 the marl to more clantic than the grout?
l l
6 A
Yeu.
I was conCuned.
i l
7 0
tiow you are saying only that it's more rlyid than l
l 0
the grout?
l
[
9 A
Hlqht.
It i g h t.
10 Q
Under examination you made the comment that the L
li cladtle nature of the mail would clone up any clipa that did l
12 o c ell!' ?
11 A
Yec.
Any rtaeturna that would develop wo11d close 14 of( becaune of the clantle siatute, due ta the ov"rtjutden f
15
- pronnure, j
}
l l
I f.
Cl(OU S - 1:X AM I f1 ATI OlJ (Continued) 17 IlY Mit. L AWI.1:U U l
10 0
1 quene I ' m p t. t i n<J conf u acel now.
{
l 19 30, we have a mani that's evidently 11elld, but -
f
- !O at contain timen, and it in clastic at oth"r timea, t'ould l
i 21 you explain?
i
}
/2 A
W r-ni e talkines about rnla t ivo ditteroncen.
Okay?
13 The narl to an riantic material.
And locaune of that, it I
/4 will clone any polo npaeon bocanno or the ovorburden 25 0: vanute, such an a ( actuse which woild lio attittelally O
1 r
l i
1 Atti lfl!!)l!RAI Rl!!'ORil!RS, INC.
202.m.) ton Nei in.kle rmoen mulwu.44
26116.0 13HT 004 1"'\\
V 1
developed as you are mentioning.
That's what my statement 2
is.
3 Q
So what you are caying is that the marl is 4
differentia 11y -- has differential rigidity and elasticity in 5
three dimonciona?
6 A
No.
7 A
(Papadopulos) Excuse me, maybe I can help on this O
statement.
What he'u trying to say is it you have vertical i
9 compreunion due to settlement --
l l
10 0
Maybe I can ask you to hold for one accond.
I l
11 apoloalse.
I have to not down that laut note and I'll be 12 right with you.
Just one second, please.
11 Okay, Dr. Papadopuloa.
Thank you.
14 A
The rigidity statement refers to dif f erential 15 settlement.
from that point of view he feela that the marl l
(
16 to mor e rigid than the grout and that, thererot e, l
l 17 difforential settlement would not occur because the grout 10 would be able'to take the same atrain an the marl.
Dut doea l
19 that, at the name time, dc to not mean that the marl la not 20 a deformable claatic material.
If the hypothetical that i
21 dif f eront ial alippage would occur in accepted, then because 27 of the olac t ic pr opertlea oJ the marl the c will be l
23 defotmation in thr lateral direction within the marl due to
(
14 the loading on tho t op, which will aqueezo atound grout l
l i
/ 's apike, an you want to call 11, and cloce any openinga that r
l l
l Act!.1711Dl!RAI. Riil'oRTi!Rs, INc.
2024U.Hm Nanimekle Cmoge mn1%ue
26116.0 DRT 615 mb 1
might be formed from the slippage of that spike.
2 0
Dr. Papadopulos, are you an expert on elastic 3
properties of the marl and clastic properties of grouted well 4
columns?
5 A
I wasn't referring to the elaatic properties of ti these things.
I am a civil engineer and I had considerable 7
couraca in deformation and strength of materials.
I am not 8
trying to portray myself as an expert in elastic properties, 9
but what I wan trying to explain, once you accept that 10 something is elastic, one material being more elastic than 11 the other one or more rigid than the other one does not 12 preclude the more rigid material from deforming under higher 13 streco that it is subjected to.
O" 14 Q
I'm not sure I understand your answer, then.
Your 15 answer la that you are not an expert?
16 A
! Jot on this subject.
I tried to clarify the 17 statement.
10 Q
Thank you.
19 A
I was basing my atatement -- you were referrino to 20 the marl's plastic deformation, no I assume anything that in 21 subject to plastic deformation should cloce around an i
22 opening.
]
23 0
Thank you, Dr. Papadopulos.
24 1 think it was Mr. Wect that led off with the 25 responneo.
O Ace FEDERAL REPORTERS, INC.
202 347 3700 Nationeide Coverage non-3]MM6
26116.0 Bi?T 806 O
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Mr. West, you have three grouted wells underneath 2
the auxiliary building, and please interrupt as we go along.
3 I'll try to summarize and just jump in if I'm mistaken --
4 I'll go through it, then --
5 MR. CilURCilILL:
Your lionor, he didn't say t.here 6
were three grouted welic under the auxiliary buildino.
1 7
MR. LAWLESS:
I missed that then.
There are three 1
0 wells --
l 9
DY MR. LAWLESS:
l l
l 10 Q
Could you characterize the three wella that are 1
l 11 underneath the auxiliary building that was deceribed 12 carlier?
13 JUDGC PARIS:
In answering the questiona, will the o
14 witnesses please dictinquish between wello and bore holes?
l 15 MR. LAWLEGO:
And which ones are grouted and which 16 ones are not.
l 17 Tile WITNEGG:
(Weat) I did originally cay that I
18 they were bore holeo and I identitled the wella.
Ther e a re l ')
only three bore holea under the auxiliary building.
I gave 20 you the numbera on thoce.
21 DY MR. LAWLEGG:
l 22 Q
Right.
And thooe were grouted?
23 A
(West) All ot the hoica were grouted, yeu.
24 Q
Co, again you atated that there were three bore 25 holen under the auxiliary building and they were grouted.
O 1
1 ace FEDERAL Ri!PonTiins, INC.
202 347 37(o Nauons kle rmerase mnJMfM6
26116.0 BRT 007 V
1 All right.
2 Under -- beneath unit 1 there were 11 bore holes, 3
or wells -- maybe you can clarify that -- and all of them 4
were grouted.
5 A
The bore holes, and they were grouted.
6 Q
Beneath unit 2, three holes, and I assume bore 7
holes, grouted?
8 A
Two bore holes, one observation well.
And they 9
were grouted.
10 Q
Two bore holes, grouted; one observation well, 11 grouted.
Is that correct?
12 A
Yes.
13 JUDGE PARIS:
Mr. Lawless, could I interrupt you 7s
(
)
14 to get something into the record for clarification?
15 MR. LAWLESS:
Sure.
16 JUDGE PARIS:
Could I ask the witnesses to 17 distinguish between wells and bore holes for us?
Can you do 18 that, gentlemen?
19 THE WITtJESS:
(West) Oh, I'm sorry.
I understand 20 your question now.
Yes.
21 A bore hole, exploratory hole, et <:e tera, are 22 terms that we use for small diameter, usually core holes, of 23 which these were.
They are less than 4 inches in diameter.
24 There is no casing in these holes unless we have to put a 25 temporary casing in during drilling to prevent loss of p)
V.
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800 336-6646
26116.0 BRT 808
(__)
1 circulation of our drilling fluid.
2 If we put any casing at all in, it is temporary.
3 When we get through with the hole, through drilling it and 4
all the testing, we pull any temporary casing that is in the 5
hole and we cement the hole from the bottom up.
And then 6
there's no evidence of the hole ever being there.
7 Now, for an, observation well, we usually use the 8
same -- and in this case -- small diameter hole.
After we 9
get through drilling it, then we installed, this these holes, 10 a 1-inch PVC pipe for our observation well and the bottom 10 11 or so feet of it was slotted.
12 We installed a gravel pack around the screened 13 portion of this, up to 10 or 15 feet above the slots, and 73 14 then we put neat cement grout from the top of the sand column 15 to ground surface.
16 JUDGE PARIS:
In the site visit you saw 17 observation well at the top.
The PVC pipe on top was a good 18 deal larger than one inch.
What's the situation there?
19 THE WITNESS:
(West) These that you have seen 20 on-site, all but three of them have been put in very 21 recently; all of them were put in with 2-inch PVC pipe and 22 screen, except for two.
One of them is LT-13, inside the 23 backfill; and 800 outside the backfill.
They were installed 24 with 4-inch PVC casing and screen, and these were made larger 25 so that we could install an automatic water level recording o
j
,s ACE. FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336-6646 1
26116.0 BRT 809 w.)
1 device.
2 JUDGE PARIS:
All right.
Thank you.
3 BY MR. LAWLESS:
4 Q
Which one was the 4-inch?
Inside was number S
umptyump and outside the backfill was umptyump?
Those two 6
numbers?
7 A
(West) LT-13 is inside the backfill; 808 is in the 8
undisturbed Barnwell formation.
9 Q
And that was for automatic measurement?
10 A
Water level recording.
11 Q
Then on the turbine, there are seven --
12 A
Drill holes.
13 Q
And all grouted?
g, 14 A
Yes.
15 Q
And on the backfill, 42?
16 A
The total number was 42, yes.
17 Q
So this was -- in the backfill this 42 was in 18 addition to these -- the backfill you meant as away from the 19 power block?
20 A
You'll have to ask that again.
I don't understand 21 you.
22 Q
What is the difference between this 42 and the 23 other numbers that we have been given?
24 A
Which other numbers?
25 Q
The 3 and the 11 and the 3 and the 7 --
O
\\_)
ACE FEDERAL REPORTERS, INC.
l 202-347-3700 Nationwide Coverage 800 336-6646
26116.0 BRT 810 f,,_
()
1 A
The 3, the 11, the 7, all that, is part of the 42.
2 0
That is part of the 42?
3 A
That is correct.
4 Q
So we would take those and add those and then 5
subtract them from 42, and 42 is outside -- the difference is 6
outside the block?
Let's do it so there's no confusion.
7 A
Let me explain something.
8 Q
Chay.
9 A
When I was originally asked this question -- this 10 is just to set the record straight, your Honor -- I started 11 counting these holes and I was told to just give ycu an 12 estimate.
Okay?
13 So, very quickly I looked at it.
I should have G
14 known better but I gave you an estimate.
That's the 35.
15 flow that you have brought these numbers back up 16 and in using them as positive numbers, I gave you the correct 17 number, which is 42, 18 Q
I see.
19 A
I used the term " power block" as I have used it in 20 construction.
And that is including the entire excavated 21 area.
22 You use the term power block referring to the 23 buildings.
24 JUDGE PARIS:
As you used power block you are 25 including all the back filled area; is that right?
[)
\\s ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336-6M6
26116.0 BRT 811
,/,
'x_)
1 THE WITNESS:
(West) Yes, sir.
2 JUDGE PARIS:
All right.
Thank you.
3 BY MR. LAWLESS:
4 Q
And that is looking at figure 42.
I didn't 5
realize we were correcting the 35.
6 Now if we can look a*
figure 4 --
7 A
(West) Okay.
8 Q
-- is the 42 number -- does it pertain to the 9
wells at the upper right corner only?
10 A
Yes.
11 Q
And it does not include the number on the left?
12 A
No, it does not.
13 Q
Okay.
I got you.
s N-14 Can you describe, going upward from these grouted 15 wells -- I can make this a general panel question -- can you 16 describe, going upward from these grouted wells, the numbers 17 that we have been given, the 3, the 11, the 3 and the 7, how 18 those wells interface with structures?
19 MR. CHURCHILL:
Your Honor, we'll need 20 clarification how this relates to the redirect.
The redirect 21 was really designed to accommodate the question raised by the 22 Board about the possibility of grouted holes underneath the 23 power block structures.
That is what the redirect was 24 addressed to.
25 JUDGE MARGULIES:
I don't know what you mean by (v~1 ACE FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 804336-6M6
26116.0 BRT 012
(^)i l
1 1
" interface."
2 MR. LAWLESS:
I guess I was just wanting to find 3
out, going upward from the top of the grouted wells, how the 4
grouted well tops would fit into these structures.
5 For instance, we know that beneath one of the 6
units there is one well that is right under the center and 7
another well that is not.
So, I gues what I was looking for 8
was a general discussion about how these wells -- the grouted 9
well tops run into the structures above?
Is there just one 10 flat structure across the whole way?
Are there intermittent 11 structures?
What is involved?
12 JUDGE MARGULIES:
How they come into contact?
13 MR. LAWLESS:
Yes, sir.
g-V 14 JUDGE MARGULIES:
It may not be precisely within 15 the recross, but we will permit the question.
16 MR. LAWLESS:
Thank you, sir.
17 THE WITNESS:
(Crosby) Okay.
Would you repeat the 18 question, please?
19 BY MR. LAWLESS:
20 Q
Yes.
Can you describe what the environnent looks 21 like on these grouted wells directly under the structures 22 that you have named?
Can you describe the environment going 23 from the top of the grouted well upward?
24 JUDGE PARIS:
Are you asking is there anything 25 between the top of the grout and the building above?
(,'l v
ACE FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coserage 800-336 6M6
26116.0 BRT 813
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1 MR. LAWLESS:
Yes, sir.
There may be and there 2
may not be.
That's correct.
3 THE WITNESS:
(Crosby) For those structures such 4
as the auxiliary building where concrete was placed directly 5
on top of the clean marl surface, there is concrete on top of 6
the grout.
Okay?
7 For those that are not on the -- where concrete is I
8 in direct contact with the clean marl surface, there is 1
9 backfill on top of the grouted holes.
l 10 BY MR. LAWLESS:
11 Q
For instance, in unit 1,
with the 11 holes, some 12 are underneath the center post and some are underneath 13 backfill.
Could you discriminate?
g-14 A
(Crocby) No.
We don't have that information.
15 Q
For uni t 2 could you discriminate?
16 A
Again, we don't have the information.
17 Q
For the turbine building, can you discriminate on 18 their locations?
19 A
(West) They are all covered by backfill.
20 0
So, under the turbine building we have backfill?
21 A
(Crosby) Yes.
Backfill between the base of the 22 building and the top of the marl surface.
t 23 4
How thick?
24 A
(Crosby) I believe you'd have to look at that 25 section 2.5.4 of the FSAR to find out.
(O L.)
ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336-6M6
8 26116.0
)
BRT 814 i
,~n i
i i
(_/
1 Q
FSAR 2.5.4?
l i
2 A
Yes.
l 3
Q This is a general question for the panel:
Is the f
4 settlement uniform across the structures?
5 A
(Crosby) As I said before, I am not an expert in 6
that and I cannot --
l l
7 Q
Okay.
Thank you, i
0 Would you be able to answer this question:
How 9
large would the displacement area be with a settlement?
10 THE WITNESS:
(Crosby) Could we define l
)
11 displacement area?
{
I 12 BY MR. LAWLESS:
l l
l
[
13 Q
Settlements; how large would the settlement area 7x k) 14 be with the settlement?
[
m 15 A
(Crosby) Again, I'm not the expert in that area i
16 and I do not know.
{
'l 17 MR. LAWLESS:
Those are the only questions I had, i
i 10 your Honor.
j 19 JUDGE MARGULIES:
Does Stc.ff have anything?
I i
l 20 MR. DEWEY:
No, we don't.
I 21 JUDGE MARGULIES:
Dr. Paris?
l l
22 EXAMINATION j
23 DY JUDGE PARIS-1 t
i 24 Q
Was the marl in the entire excavation area
[
t 25 excavated out so that it was only 38 feet thick; is that t
i l
I (rNJ l
l I
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ACE-FEDERAL REPORTERS, INC.
I 202 347 3700 Nationwide Coverage mk336-6M6 w---.
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26116.0 BRT 015 1
right?
Or just under certain buildings?
2 A
(Crosby) No, sir.
There was approximately 1 3
million square foot of marl exposed during the mass 4
excavation.
The auxiliary building is the only area where 5
there was additional excavation below that mass grade 6
excavation, and that mass grade excavation was at elevation 7
130, and the auxiliary building was 22 feet below that.
And 8
that's where you have the 38-foot thickness of marl.
9 Q
on all the other buildings the marl is roughly its 10 original thickness?
11 A
Yes -- well, 5 toot less than the original 12 thickness.
13 0
Okay.
You cleaned up the rubble?
-)
V 14 A
Right.
15 0
How deep do the core holes under the power block 16 buildings go?
17 A
They went to various depths, but all of then 18 penetrated through the bottom of the marl.
19 Q
Into the sands beneath?
20 A
Yes, sir.
21 Q
Someone mentioned the word " net settlement."
It 22 wasn't clear to me what was meant by net settlement.
Will 23 you explain that?
24 A
Yes.
The net settlement is the difference between 25 the heave which began tor the placement of backfill and the (O>
v ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage MX) 3346646
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1 26116.0 BRT 816
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settlement which occurred after placement of the backfill.
I i
j 2
Q So the heave wa.s about 4 inches; is that right?
i l
3 A
Right.
i l
4 Q
And that sank down when you put the weight on it f
5 and has gone dow1 another inch; is that right?
f I
6 A
That's -- that's --
I I
7 Q
Okay.
Fine.
I l
i j
8 A
I believe the numbers are more like 33 and 4 for l
i j
9 the maximum.
j j
10 Q
I beg your pardon?
l l
1 11 A
I think the numbers are 3 inches for heave for i
)
12 settlements and 4 inches cettlements, naximum, i
1
\\
l 13 MR. LAWLESS:
I believe we have the testimony from
!O l
14 the flRC, 4 inches for settlement.
I think that was richt.
l 15 EXAMINATIOt1 l
l 16 BY JUDGE LI! jet 4BERGER :
l l
i
)
17 Q
I, too, had a misconception about how extensive an l
l l
18 area the term " power block" referred to or refers to.
1 19 If I -- may I refer you gentlemen to figure 6 of 20 the pa nel's pref iled testimony, in the uppermost layer l
l 21 labeled " backfill," a t the extreme right and extreme left of j
]
22 the backfill recion there is a dashed line going upward at 6
j 23 about an angle of 30 degreen to the horizontal -- yes, to the j
f 24 horizontal.
l 25 Off to the riqht, under " terminology" there is a I
i I
i l
i ACE FEDERAL REPORTERS, INC.
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202 347 3700 Nationwide Coverage 1410-336 (M6 L -------.------
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l 26116.0 BRT 017 p!b 1
label, "Barnwell group."
Now, then, I presume that that l
l 2
dotted line indicates, schematically at least, where the l
3 backfill meetr. what is labeled "Barnwell group"; is that 4
correct?
l 5
A (Crosby) Yes, that's correct.
l l
6 Q
Is it true, then, that as you gentlemen talk about 7
power block in your testimony, that that refers to everything l
8 between those two 30-degree angle dotted lines' l
9 A
Yes.
That's the generalisation we've made.
10 0
So it's not just something resting on a concrete 11 slab or under a building or whatever?
12 A
No.
l 13 A
(Papadopulos) We generally try to refer to it as l
14 the power block area rather than power block, but I'm not 15 sure if we have slipped somewhere and said power block by 16 itself.
17 Q
Well, that helps.
Thank you.
18 I belleve you just indicated that the wells and I
(
19 holes we have been talking about penetrate the blue marl.
l 20 I'm curious, stickinq with figure 6, do they 00 any l
21 appreciable traction through the next layer below the blue l
j 22 mari, which is labeled " unnamed sands"?
l 23 A
(West) only the ones that were completed as 24 observation wells go any appreciable distance into the cand i
25 much more than 10 or so feet.
All the other observation -- I (v,,b l
l l
l
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1 mean, the exploratory holes penetrated only about 10 feet or 2
so.
The deepest one of these wells went down probably 50 or 3
60 feet into it.
4 Q
None of them penetrated the sand, went all the way 5
through?
6 A
Not the complete thickness of the sand; no, sir.
7 Q
Nhat about the ooservation wells?
8 A
No, sir.
That's what I said.
The observation 9
wells were the deepest ones, and none of the holes or wells 10 penetrated the entire thickness of the sands at the power 11 block.
12 Q
My own interpretation or what Mr. Crosby said is 13 that plastic deformation ot tha marl could be expected to 14 close or seal off any openings that might develop between the 15 marl and the grouted -- the grout in a bore hole or a wel1.
16 Is that correct?
17 A
(Crosby) That is correct.
18 Q
Now, I ouess the polite way to put this is, do any 19 of you gentlemen view this matter differently than 20 Mr. Crosby?
21 A
(West) I don't.
I I
22 A
(Farrell) No.
23 A
(Papadopulos) No.
24 JUDGE LINENDERGER:
Thank you, gentlemen.
25 JUDGE MARGULIEG:
Mr. Davenport, do you have O
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anything further?
2 MR. DAVENPORT:
No further questions, your lionor.
3 JUDGE MARGULIES:
Is there anything further from 4
the witness?
S MR. LAWLESS:
No, sir.
6 JUDGE MARGULIES:
The panel is excused.
Thank 7
you.
8 (Panel excused.)
9 JUDGE MARGULIES:
Is there anythinq further to be 10 oftered in this evidentiary hearing?
11 MR. TINGLE:
Yes, your Honor, I would like to 12 offer a brief statenent.
13 During the public witness portion of the hearing, nb 14 three former employees from the power company made 15 alleqations as to, b a.q i c a l l y, unsafe construction in the 16 plant; violations ot NRC regulations; falsification of 17 documents; the NRC breech of trust after they reported it; 18 and harassment and firing.
19 The Board took extraordinary action and forwarded 20 l their unsworn testimony on to the proper investigative arm.
21 JUDGE MARGULIES:
We haven't done that as yet in 22 that we haven't been to our offices.
That is our intention.
I 23 MR. TINGLE:
That is your intention.
In doing 24 this, we felt you established or felt like at least there was 25 a prima facie case.
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26116.0 BRT 020 (O) 1 JUDGE MARGULIES:
No, that isn't so.
2 MR. TINGLE:
Well, I think your comment was "very 3
serious allega tions that warranted action, some cort of 4
action."
5 JUDGE MARGULIES:
No, My comment was tha t we are 6
torwarding it to the proper investigative arm tor whatever 7
action they deem appropriate.
We are not characterizing the 8
testimony one way or the other.
We are acting as a conduit i
9 to bring it to the attention of the investigative arm.
10 MR. TINGLE:
I understand.
Dut, in this vein 1 11 would like to offer a motion to extend and not close the 12 record on the safety portion of the hearing until those 13 investigations are completed, because most of the stuff 14 concerned is directly or indirectly associated with the 15 lucueu brought up here.
And since start-up is not until 16 December, I don't think it would really put anybody off au 17 far as getting the plant on line on time.
10 JUDGE MARGULIES:
Do you wish to be heard, 19 Mr. Churchl1l?
20 MR. CilVRCilILL :
Yes.
We object to the motion.
He 21 hasn't brought torth anything that would -- having any 22 bearinq on the evidence presented and the issues heard at 23 this hearing that would warrant extending the record, 24 MR. DEWEY:
Staft would also like to comment that l
25 the investigations and allegationa are fairly routine f%J ACE FEDERAL dEPORTERS, INC.
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26116.0 DHT 821 1
throughout the country inspecting nuclear plants and this 2
certainly isn't a basis for keepinq open a safety record.
3 We are set up to investicate these and there's no 4
nececsity to keep the record open and have the Board oversee S
th"se invectigations.
6 MR. T I tJGL E :
But if thic did have a bearing, then 7
the determination miqht be flawed uselessly, when it ceems to 8
me the record could be kept open without inconveniencinq l
9 anyone.
10 JUDGE MARGULIES:
The matter is wholly 11 cpeculative.
They were unaworn statements.
I really don't 12 know how they relate directly to those contentions.
13 My concern, really, was the allegation ot l
O 14 impropriety on the part of tJRC employee...
15 MR. TItJGLE:
It la my understanding that one at l
I lo the allegations -- and thin is hearsay and you can go ott 17 recoid or take it for what it's worth -- one of the la alleqations waa that the records on settlenent of -- the l
l l
19 different buildings contained in the power plant w+re l
I l
20 settling at different ratec, and that the power company did i
i
{
21 falsify taece rec ord:..
That ic ray underu ta ndi nq of what som"
[
i.
22
-- juct a portion of what the allegations are from the I
23 witnesses.
{
i l
24 Aqain, thia 13 hearcay.
I don't say it ic, but I
l j
25 I'm aaying evidently the board thouqat that th re was 1
l l
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something serious enough to take some sort of extraordinary 2
action and that's the reason for our asking for this 3
extraordinary action.
4 JUDGE MARGULIES:
I don't believe the action is 5
extraordinary.
There have been allegations made that NHC 6
employees have acted improperly.
I think the agency should 7
know of those allegations and we are taking it upon ourselves 8
to submit the transcript to that operating arm.
We haven't t
9 seen anything that would warrant holding thic proceeding open l
l 10 on the basis of what was tectified to here.
[
l 11 MR. TINGLE:
Yes, air I can appreciate your l
l 12 concern with the NRC but that -- to me, the main concern is l
l p 13 what might turn up as far an -- the concern as far as the d
14 aatety of the plant is what is important.
l l
15 JUDGE MARGULIEG:
It what ultimately develops i
16 warrants the filing of new contentiona or the reopening of 1
c i
17 this proceeding, it can take place in the normal procedure.
18 We ree no reason not to conclude the evidentiary record 19 here.
20 MR. TINGLE:
Thank you.
There is one other l
21 matter, it I might?
22 Could we have the courtesy -- let me let 23 Mr. Lawicas speak to you directly.
24 MR. LAWLESG:
Mr. Chairman, would it be possible, 25 just as a - au -- in a courteay fashion to be placed on the r^N U
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1 service list to get the documents that are normally cent 2
out?
Not as an Intervenor, but just as a recipient?
3 JUDGC MARGULIES:
I have no personal problem with 4
it.
I don't know what the Secretary's procedures are.
I 5
will put that request in for you, Mr. Lawleas.
6 MP. LAWLEGG:
Thank you, air.
l 7
JUDGE MAHGULIEG:
In that it would be convenient l
0 for the record, would you please state your address once l
I 9
again?
l l
10 MR. LAWLESS:
That's W.F.
Lawlesa, a c c i a t alit l
11 professor of mathematica, Paine College, P-a-i-n-e College, t
12 1235 15th Street in Auguata, Georgia 30910.
Phone number 1
13 too?
I O l
14 JUDGE MARGULIES:
No.
That won't be necoccary.
I 15 MR. LAWLEGS:
All right, air.
16 MR. TINGLI: s Your lionor. one more thing --
17 JUDGC MARGULIEC:
Just betore we no on to one more 6
l 18 thing, I abould have aaked the parties if they had any 19 objection?
Do they have any obiection?
l 20 MR. ClluRellILI, lic'a not a member, he's not a l
21 party.
Yea, we do object.
l l
22 JUDGC MARGULIES:
llow about the Staft?
t l
23 MR. DEWI:Y :
In the past, Statt haa put the namen l
l 24 of expert witnesses on nervice lista to accommodate, on l
l 25 occasion, so I don't think we would have any problem -- on I
r^N
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l l
l ace FEDERAL REPonTuns, INC.
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26116.0 BRT 024 h) sj 1
our ELD service list.
2 MR. TINGLE:
Your lionor, I would just like to say 3
that we appreciate the Board's patience and tolerance in 4
helping un present this cane.
Thank you.
5 JUDGE MARGULIES:
The Board in required by its 6
mandate to make a tull and complete record, and we have done 7
no more than that.
8 MR. TINGLE:
We atill feel like we'd like to thank 9
you.
10 JUDGE MARGULIES:
We have the matter of briefs.
11 The Board will require briefe from the parties.
The briefs 12 shall be in the form of proposed findings of tact and 13 conclusiona of law.
It was my understanding that the partica 14 were coing to work out the filing dates and if you have done 15 ao, we should put it on the record at thin time.
16 MR. Cll0RCilILL:
I've simply counted the days l'
specified in the regulationa at 2.754, and by my reckoning, 18 Applicant's findingo would be due on April 14th.
That's 19 because 30 days, ac prencribed, falla on Sunday tho 13th, ro 20 thelra would be duo the 14th.
21 Intervenor's tindings would be due 50 daye after 22 the close of the record today, co theit tindinqu would be due 23 Apri1 23rd.
And the Statt'a f1ndinoa, propoced findinya and 24 conclucions, would be due in 50 days, which landa on a 25 Saturday, no theirn would be due May 5, Monday, May S.
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Following that I understand that we havo five days 2
in which to file reply findinos, "we" being the Applicantu.
3 JUDGE MARGULIES:
Are these dates the dates that 4
the documents are to be received?
5 MR. ClitlRcilILL:
I think they are the dates they 6
are to be tiled.
I could check.
7 MR. DEWEY:
I thought they were filed on those 8
datea, myself.
9 MR. ClitlRCilILL :
Thoue ate the filing daten.
10 JUDGE MARGULIES:
As long an it la clear on the 11 record.
They will be the filing dates.
12 Are thone dates agreeable to all of the parties?
f 13 MH. LAWLESG:
Just one small question.
lie said 14 the Intervenor'c daten would be 350 days atter today and 50 15 daya fIom the NRC?
Or did he mean 40 days?
16 HR. ClluReilILL:
The Intervenor's date would be 40 17 daya, and t ha t would im April 23rd.
i 10 MR. LAWLESS:
Do the Intervenors have a chance to t
I 19 reply to the Applic. int'n reply?
Is that allowed?
20 JilDGE MARntILIOG:
The rules do not provide for I
21 that.
22 MH. ClluRCilILL No, they do not.
23 MR. LAWLi'03:
Go the Intervenore, then, will turn 24 in their Citidinyrs of fact by April 23rd.
Are there any l
25 discuscions requented or allowed 1.y Intervenore past that?
O(*
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JUDGE MARGULIES:
I don't underatand your 2
question, Mr. Lawlena.
3 MR. LAWLESS:
Would that be the opportunity for 4
Intervenors to expresa their comments?
Would be the April 5
23rd date?
6 JUDGE MARGULIES:
That la the methodology.
The 7
App 11canta go first, Intervenora go accond, r sff goes third, 8
and then the Applicants have an opportunity to reply.
9 The next atep after that, if any of the parties l
10 aee fit, they may take exception and file an appeal from the 11 Doard's decision.
12 MR. LAWLEGG:
This in after the Doard's decision, 13 then there la a period for appeala?
14 JUDGE MARGULIES:
That la correct.
15 MR. LAWLESG:
Thank you.
16 JUDGE MARGULIES:
You may want to consult with 17 Statf in terna of how the document should be prepared.
18 MR. LAWhEGO:
Thank you.
[
19 JUDGE MARGtlLIES:
In there anything further?
1 20 MR. ClluRCilILL:
We have nothino, your lionor.
21 JUDGE MARGl!LIEGt the record on this portion ot 22 the evidentlary hearing la closed.
The only matter we still r
23 have open la the matter on emergency planning.
Thank you.
24 (Whereupon, at 2:05 p.m.,
the hearinq was 25 conaluded.)
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j 1
CERTIFICATE OF OFFICIAL REPORTER A
l l
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the
'j matter of 0
NAME OF PROCE9 DING:
GEORGIA POWER COMPANY, et al.
1
'l
,l (Vogtle Generating Plant, Units 1 and 2) ll I
l.
i 1
i DOCKET NO.
PLACE:
WAYNESBORO, GEORGIA O
FRIDAY, 'MARCII 14, 1986 DATE:
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
1 (sigt) 67 A4 M
(TYPE JOEL BREITNER Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation
,