ML20154N619
| ML20154N619 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/11/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#186-443 OL, NUDOCS 8603170371 | |
| Download: ML20154N619 (400) | |
Text
ORIGINAL O UNITED STATES ,
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-424 OL 50-425 OL GEORGIA POWER COMPANY, et al.
(Vogtle Generating Plant, Units 1 and 2) .
LOCATION: WAYNESBORO, GEORGIA PAGES: 221 - 414 DATE: TUESDAY, MARCH 11, 1986 g'
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ll In the Matter of: :
5 : Docket No. 50-424 OL l GEORGIA POWER COMPANY,
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et al. : 50-425 OL 6 :
l (Vogtle Generating Plant, a 7
i Units 1 and 2) :
, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 8
l Burke County Office Park 9 Auditorium West 6th Street 10 ; Waynesboro, Georgia 30830 ij Tuesday, March 11, 1986 j I.
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, The hearing in the above-entitled matter convened at !
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BEFORE: )
l 15 JUDGE MORTON B. MARGULIES, Chairman 16 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission [
17 Washington, D. C. 20555 '
i la JUDGE GUSTAVE A. LINENBERGER, JR., Member Atomic Safety and Licensing Board Panel in U. S. Nuclear Regulatory Commission Washington, D. C. 20555 20 JUDGE OSCAR !!. PARIS, Member l Atomic Safety and Licensing Board Panel 1 21 ]y U. S. Nuclear Regulatory Commission
! Washington, D. C. 20555 I 22 l 4 I cm 23 g> l h t 24 ' ;
u FeerJ Ceporters. inc.
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,q l . APPEARANCES:
V i on behalf of the Applicant:
3 BRUCE W. CHURCHILL, ESQ.
DAVID R. A. LEWIS ESQ.
4 SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, NW 5 Washington, D.C. 20056 6 CHARLES W. WHITNEY, ESQ.
HUGH M. DAVENPORT, ESQ. <
TROUTMAN, SANDERS, LOCKERMAN & ASHMORE 7
1400 Candler Building Atlanta, Georgia 30043 9, On behalf of NRC Staff:
1 10 l BERNARD M. BORDENICK, ESQ.
I LEE DEWEY, ESQ.
Office of Executive Legal Director i;
U.S. Nuclear Regulatory Comission g; Washington, D.C. 20555 f
13 {. On behalf of Intervenors:
TIM JOHNSON ,
14 I Citizens for a Prosperous Georgia DOUG TEPERS 15 '
i WILLIAM F. LAWLESS l q Georgians Against Nuclear Power l 16 1253 Lenox Circle
!! Atlanta, Georgia 30306 ,
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20 b 21 22 l O 24 her Feder3 Reporters, Inc. ,
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I! CONTENTS
.b WITNESS DIRECT CROSS REDIRECT RECROSS EXAM
'[
l Thomas W. Crosby 1 2l Clifford R. Farrell '
i Stavros S. Papadopulos 4! Lewis R. West 5 by Mr. Churchill 248 l by Mr. Teper 256 by Mr. Lawless 261 3
(Resumesafteropenappearances) 7 Howard M. Deutsch 8: by Mr. Churchill 357 h
by Judge Linenberg 366 9 by Mr. Bordenick 372 ;
! Thomas W. Crosby 10 i Clifford R. Farrell Stavros S. Papadopulos 11 Lewis R. West l l
, 12 by Mr. Lawless 376 i
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Howard M. Deutsch 33 :
l g by Judge Paris 379 l by Mr. Lawless 390 (Cont) I, by .ludge Paris 391 1 15 1 16 l Prefiled direct testimony of Thomas W. Crosby, Clifford R. t
- 7 Farrell, Lewis R. West and Stavros S. Papadopulos - 253 '
jg Prefiled direct testimony of Hcward M. Deutsch - 371
", RECESS - 12:40 p.m. - 311 !
followed by open appearances ;
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1 PR0 CEED I NG S 2 JUDGE MARGULIES: Please come to order. Good 3 morning, ladies and gentlemen. Thic proceeding involves an 4 application filed on behalf of Georgia Power Company, 5 Municipal Electric Authority of Georgia, Oglethorpe Power 6 Corporation, and the City of Dalton, Georgia. The 7 application was. riled with the Nuclear Regulatory Comnission 8 for licensec to operate the Vogtle electric generating 9 plants, Unita 1 and 2. The facility is located in the 10 eastern part of Burke County, Georgia, on the Savannah 11 River. The applications have been docketed as number 50-424
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13 We are the Atomic Safety and Licensing Board that 14 was appointed to determine whether hearings should be held 15 and whether -- and to conduct the hearing, shou'Id the 16 decision be made to hold the hearing. We have decided to 17 hold the hearing in this matter.
18 I would like to introduce the members of the 19 licensing board at this time.
20 on my left 13 Judge Gustave A. Linenberger, Jr.
21 Judge Linenberger is a nuclear physicist.
22 On my right is Dr. Oscar H. Paris. Judge Paris ic 23 an environmental scientist.
24 I am Morton D. Margulies, the chairman of the (x- ') 25 licensing board. I am an administrative law judge.
ACE. FEDERAL REPORTERS, INC.
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1 .Toint Intervenors, Compalan for a Frosperouc 2 Georgia and Georgians Acainst Nuclear Enercy have presented 3 allegations regarding the plant's operation and its adverse 4 effect on public health and safety.
5 During the course of the prehearing process, it 6 has been determined that we will hold an evidentiary hearing 7 on three of the contentions which are in a technical area.
8 There are other contentions involving emergency planninc 9 which are still under review and no determination has been 10 made at this time as to when to hold an evidentiary hearing 11 on those issues.
s 12 The first contention we are to hear has been (v) 13 designated ae Contention 7. Very generally, it alleges that 14 the App 1Leants have failed to assure that the aroundwater 15 below the plant will not be contaminated by a spill of 16 radioactive water.
17 The second contention, designated as contention 18 10.1, challenges the appropriateness of the methodology used 19 I to environmentally qualify certain polymer materials to be 20 employed in conponents of the facility that perform 21 safety-related functions.
22 The third contention, number 10.5, challenges the 23 I adequacy of the en.ironmental qualification testing pert:rmed 24 upon those models of solenoid valves manufactured by the y
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1 safety-related functiona at the units.
2 In this evidentiary hearino, the parties that will 3 be participating will be Georgia Power Company, acting for 4 itself and the other owners. It has the burden of proof in 5 the proceeding.
6 Also participating are joint Intervenors, Campaign 7 for a Prosperous Georgia and Georgians Against Nuclear 8 Energy.
9 Another party is the NRC Staff. It pa rt ici pa te s 13 as any other party in this proceeding. Its positions are not 11 binding on this independent licensing board.
g3 12 The decision that this board will return is
- 13. subject to appeal within the Nuclear Regulatory Comnission.
14 The decision of the NRC is Appealable to the United States 15 Federal Courts.
16 Persons not a party to this proceeding will be 17 able to make a limited appearance by oral or written 18 statement as provided for in 10 Code of Federal Regulations 19 2.7158. Oral statements are to be limited to 10 minutes.
20 Written statements that may be submitted are unlimited as to 21 length.
22 Both kinds of statenents, which are not made under 23 oath, will be included in the record of this proceeding but 24 do not constitute evidence.
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(-) 25 The designated time for making limited appearance ACE FEDERAL REPORTERS, INC.
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1 -- appearances is between the hours of 9:30 a.m. and 11:30 2 a.m. tomorrow. To accommodate those parties who may have l
3 come today to make limited appearances, we will hold a 4 session for one hour following the luncheon recess.
5 Should other additional time be required, we will 6 designate it as it becomes evident.
7 We have a piece of paper down at the reporter's 8 desk there and those parties who want to make limited 9 appearances can sign up there.
10 I have been requested to make the announcement 11 that there is no smoking in this auditorium.
12 We will now take oral appearances. Who appears 13 for the Applicants?
14 MR. CHURCHILL: Your Honor, my name is Bruce W.
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15 Churchill. I'm with the law firm of Shaw, Pittman, Potts 5 16 frowbridge in Washington, D.C. On my richt with the same law 17 firm is David R. Lewis, And on my far richt is Charles W.
18 Whitney of the law firm of Troutman, Ganders, Lockerman &
19 Ashnore in Atlanta. And on my immediate left is Hugh M.
20 Davenport of the same law firm.
21 JUDGE MARGULIEO Who appears for the NRC Staff?
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MR. DCRDENICK: My name is Bernard M. Doardman, 23 office of the Executive Legal Director, USNRO, and on my 24 right also with that same office is Lee 3. Dewey.
k_) 25 JUDGE MARGULIEG Who appears for the ACE FEDERAL REPORTERS, INC.
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v 1 Intervenors?
2 MR. JOHNSON: My name is Tim Johnson, Campaion for 3 a Prosperous Georgia, 1083 Austin Avenue, in Atlanta. And 4 with ne, Doug Teper, who is with Georgians Against Nuclear 5 Energy, 6 JUDGE MARGULIES: Are there any preliminary i
7 matters?
O MR. JOHNC0ti tir. Chairman, in thic the 9 appropriate tine to make an opening statemen*?
10 JUDGE MARGULIE3: I will gat to that.
11 Mr. Johnson.
o 12 MR. CHURCHILL: Your !!onor, we have flied, last U 13 week, a notion to strike the tectimony of Mr. Lawless, who 14 l has proffered testinony on Contention 7 which is the first 15 contention to be heard this nornino. That motion was not 16 filed in time for the parties to responds and we had 17 mentioned at the prehearing conference that if we had filed 18 such a motion, it would be cood to have argument on that 19 notion at the hearing today. I would suqqest that, after 20 Applicants have presented their direct case on contention 7, 21 and it is Intervenors' turn, that at that time would be a 22 convenient place to argue that motion.
23 JUDCE MARCULIES: Do ycu have any objection, 24 <
Mr. Johnson?
p 25 MR. JOHN 30ti tio , sir. That's fine with ua.
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l 26113.0 RT ir 1 JUDGE MARGULIE3: Do you 1.:h to be heard, 2 Mr. Bordenick?
3 MR. DORDENICK: No, I was just checking with 4 Mr. Dewey who is handling Contention 7. We don't have any 5 problem.
6 JUDGE MARGULIES: It would be an appropriate time, 7 then, to handle that notion.
8 Do you wish to make an openino statenent, 9 Mr. Churchill?
10 MR. CHURCHILL: We have no opening statement as 11 such, your Honor, except to note that we do plan to preJent a z, 12 panel of four expert witnesses on Co n t ent. ion 7, the 13 groundwater leave. On contentien 10.5, which la the i s. u e of 14 l
environmental qualification of the valves, we will have a 15 l pinel of five expert witnesses. And on Contention 10.1, 16 which is the radiation effects on certain types of polymers 17 and cables, we will have a panel of four witnesses.
18 ,
JUDGE MARGULIES: Think you.
19 Do you wich to make an opening statement, 20 Mr. Johnson?
21 MR. JOHtl30N: Yes, Mr. Chairman.
22 JUDGE MARGULIES: You rnay proceed.
23 ! MR. JOH!! SON : Thank you.
I 24 Late in 1903, between Chrictmas and tiew Year's, 25 the flR C pub 11Jhed notice in the Federal Regiator of an ACE. FEDERAL REPORTERS INC.
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1 application by the Georgia Power Company and its partnerJ for 2 an operating license for Plant Voutie. When the Campaiun for 3 a Prosperous Georgia intervened in that proceedino -- this 4 proceeding, we recogni:ed there were certain limitations to 5 the process. We knew that the NRC, tor example, had never 6 denied an operating license for a nuclear power plant.
7 We knew the NRC and its predecessors had granted 8 con truction permits to Plant Vogtle despite demonstrationa 9 that the power from the utility would not be needed and that 10 alternatives would be cheaper. Your agency lanored, for 11 example, a study by internationally renowned economict 12 Charles Komanoff in 1976 which reached these very findings.
O 13 You granted the construction permit based on Georgia Power's 14 claim that there would be blackouta and brownouts by 1979 it 15 Plant Voctie were not in operation by that time. ;
16 We were disappointed when you chose to ignore the 17 fact that their claims were not accurate. The domand for 1
18 electricity last year was less than half. Georgia Power in 19 selling more power to other states and at rates far lower 20 than they want to charco for Plant Vogtle. You said you 21 would not address theJe concerns becau3e it'0 outside your 22 jurisdiction.
23 We w?re also disappointed that NHC regulations 24 prohibited considerations in this proceeding of a number of n
(_) 25 i serious environmental and gafety concerns, cuch as whst to do ACE. FEDERAL REPORTERS, INC.
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's I with high-level nucle r waste from a plant. Thest particular 2 is su.e has h i t hone with Georgians as a site in sentral 3 Georcia is under consideration for a high-level nuclear waste 4 dump. The hundred of citizena who turned out for public 5 meetirigs opposing the dump can testify to the foolhardinese 6 of creating these poisons with no better plan than to put 7 them in a hole in the ground.
O N ev e r t h ae le s s , we intervened in the proceedings.
9 We felt too nuch was at stake to sit idly by and allow the 10 licensing to proceed without serious considerations of a 11 number of the cafety concerns. We face a situation where, if p) t' 12 Plant Vogtle is allowed to operate, it will at the very best 13 produce the most expensiv.: electricity Jn G+orqi1 hiatory, 14 create incredibly toxic radioactive poisons with which we 15 know not what to do, and wonder throughout its brief 16 operating life that it might suffer a catastrophic 17 breakdown. That's at best. At worst, the plant would cuffer 18 such a catastrophe which, in the words of a novernment study,
- 1) could devas tate aa area the Ji e of Penacylvania.
20 Therefore we intervene with the e:<pectation that 21 this licensing board, while it would undoubtedly license the 22 plant given the opportunity, would genulnely listen to our 23 '
safesty concerns and do its best within certain constraintJ to 24 assure that safety concerno are fu111y investigated and A
U 25 problems corrected.
ACE FEDERAL REPORTERS, INC.
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1 We have therefore be-n shocked at the actions of 2 this board. One atter another example can be cited of the 3 board's persistent pattern of irresponsibility and blat utt 4 disregard for the safety and well-being of the people who 5 live here.
6 For example, you refused to order Georgia Power to 7 build a plant to withstand an earthquake the nagnitude of one 9 which occurred in Charleston, South Carolina late in the last 9 century, evean though the- U.S. Geolooic Curvey ackrowle!q>d it 10 does not know where the fault which caused that earthquake 11 lies. Such an earthquake, as you well know, could break c 12 cooling water pipes, leadino to a loss of coolant accident 13 ar.d consequent meltdown. You refu.te to con.'ider the f act 14 that thermal shock -- wnich could occur durino routine 15 transients -- could breach the pressure vessel in a reactor 16 of the Plant Vootle design.
17 Another shocking action taken by this board is its 18 refusal to consider the fact that Westinghouse Prescurized
- 1) Water Reactor stean generator tubes have suffered from 20 crackino, wastage and other problems. These tubes are in 21 Plant Vogtle. You dismissed the consideration of the fact 22 that the TDI plant generators to power emergency systens in a 23 accident consistently failed t.o*.h in tects and 'n tiold .
24 operations. Without these generators, even a routjno O
V 25 blackout could potentially lead to a catastrophir. accident.
ACE FEDERAL REPORTERS, INC.
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1 The NRC Staff haJ been little more than ,$ carbon 2 copy for what the Applicants have requested. At the initial 3 meeting between Intervenors and Staff, and the utility, 4 Dernie Dordenick, the counsel for the NRC Staff, stated that 5 members of the public often had difficulty distinguiching 6 between the utilities and the NRC Staff. Since that point he 7 has demonatrated what he meant.
8 We have b"en gruatly disappointed in all of these 9 actione, but the action by tha Doard which moct clearly 10 demonstrates its lack of concern for the public safety 11 relates to the quality assurance program, QAP, at Plant 12 Vogtle. When we initially interv4ned, two individuals, an 3
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13 Atlanta artiat and mytolf, traveled to U+ynesboro to review 14 the information publicly available if required by law in the 15 county library. These documentJ, all of which were prepared 16 by the HRC and Georgia Power and its contractora, included 17 descriptionc of various safety breakdowns which had occurred 18 during construction of Plant Vogtle.
19 Many of those concerns were quite serious in 20 themselvou, but of even dreater concern to us was the sheer 21 volume of problems.
22 Literally hundrede of breakdowns of materiala and 23 workmanship had buen discovered which had nonet.ow gotten past 24 the company's quality accurance program which la supposed to O(s 25 prevent such breakdowns. We were startled, particularly ace. FEDERAL REPORTERS, INC.
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, !.5 4 w i 1 becau8.= the questivo rem.ilned : How nany such breakdowns in 2 the QAe were not uncovered in other ways?
3 We disclosed our concern in proposed contentions 4 to the licensing board which would call into question Georgia 5 Power's entire CAP. We provided the Board with descriptions 6 of some of these approximate. Georgia Power objected that it 7 had either corrected or would correct each of the instances 8 we cited, but the Doard agreed with us that the point was not 9 so nuch the specific instances as the general pattern of 10 failure. In 1984, the Board accepted this as a litigable 11 contention, which meant it would be included in the hearinas 12 in 1986, the hearings beina held this week. In the interim, I^)
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13 a series of events made this locue far more crucial.
14 Several Plant Vogtle workers approached us with 15 specific allegations about problems at the plant which went 16 far beyond anythino disclosed in the public documents.
17 According to these whistleblowers, who included quality 18 control engineers charged with maintaining QAP, Georcia Power 19 and its contractors had persistently ordered them to ignore 20 faulty workmanship, sone of it crucial to plant safety. They ,
21 were further ordered to cover up the mistakes throuch 22 falsification of documentation of the work. Those that 23 .
ref used to go nlorig were haraccod fis a variety of we.ys, 24 including firinos. One of the harassment techniques for your O 25 (s' analysis will be diccussed by two of the whiatleblowers on ACE. FEDERAL REPORTERS, INC.
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v 1 the Phil Donohue show later thia week.
l 2 Some of those whistleblowers came to us in 3 groups. Others contacted us in independently. Every one of l 4 then expressed the same sentinents: They were shocked by the t
5 activities at Plant Vogtle and did not believe the plant waJ l
1 6 safe as built. They were very hesitant to approach us
! 7 because Georgia Power had portrayed us as devils not to be 1 8 trusted. They tirst approached the reqional Nhc of fice 9 before coming to us being told they were rejected. For 10 example, an NRC staffer, Bruno Uric, told the whistleblowers 11 that the NRC lacks adequate funds to investigate worker 12 complaints and that's exactly what Uric is supposed to do.
g-)S 13 Reccgnising that most workers at the plant, regardless of 14 their concerns, would hesitate to approach Intervenors 15 against the plant, we took two actions.
16 First, we contacted the Government Accountability 17 Project, CAP, a nonprofit law firm established to represented 18 whistleblowers in government and other jobs. CAP agreed to 19 speak to the workeru and after doing so, concluded that the 20 situation at Plant Vogtle ic, indeed, serious, both in terms 21 of the safety problems and the harassment of whistleblowers.
22 GAP initiated in investigation, which we underst1nd is 23 engoino, and agreed that t.by interr.ation uncovered would be 24 compiled and presented to this Daard in the appropriate O( / 25 hearings.
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'nt iba 1 secondly, we notified the Board of these dramatic 2 developments. We had previously been contacted by 3 individuals stating they worked at Plant Vogtle and had 4 safety concerns, but those whistleblowers feared for their 5 careers and would not identify themselves, so the Board 6 refused to consider the information.
7 In this case, however, some of the whistleblowers 8 said they would testify in these proceedings if it night lead 9 to correction ot the problems.
10 We described what the whistleblowers had told us 11 in hearings before the f1HC's Advisory Committee on Reactor 12 Safeguards, with copieJ provide to thi3 Board. We also
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13 threatened to notify the Board of these developments.
14 As you know, these problems included uneven 15 settlement of the auxiliary building and the containment 16 buildings between which pipes containing cooling water run.
17 Such uneven settlement could rupture the pipes causing a loss 18 of coolant accident and subsequent meltdown. The quality 19 control engineer who described this to us explained that 20 documentation was falsified to cover up the uneven 21 settlement. Other problems included air pocketing in the 22 containment walJs and a general attitude of " productivity 23 nefore safety," J;eeding up Cons *.ruction of the plaret at the 24 expense of safety concerns.
25 We filed a Freedom of Information Act request with ACE. FEDERAL REPORTERS, INC.
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I the Departmarnt of Labor to g-t coni-s c o ra pl a i n t ti filed 2 with that acency by whistleblo.ers at Flant Voctie. They 3 dragged their feet consistently on this and althouqh they are 4 required to respond within 10 days. now more than a month 5 after our request they have still not provided the 6 documents. However, we do know that there is a significant 7 volume of such complaints, for the Department of Labor has 8 told us that the copying enarnes will exceed 4200.
9 Thus, the QAP problems were even more serious than 10 we had initially realized. The extent ot the problems will 11 be discovered in investigations and hearings. We anticipate g- 12 that this board would instruct the NRC Staff to fully V
13 investigate and take appropriate actione.
14 It will be difficult to describe the shock we felt 15 with the Board's response to these dramatic developments.
16 The Board decided that the QAP program was okay after all.
17 that Georgia Power and its contractorc either had corrected 19 or would correct each instance of breakdowns we had earlier 19 cited, an argunent the Board earlier rejected when put 20 forward by the Applicants. The Board said it had no sworn 21 testimony from the whistleblowers and therefore would not 22 consider our charges related to those concerns.
- 2) We responded to the Board that we'd be willing to 24 provide affidavits from the whistleblowers and that they O
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1 the process. Therefore, there will be no hearings on this 2 issue.
3 In summary, when the concern about the QAP became 4 much stronger, when the evidence against Georgia Power was 5 strengthened, you immediately closed off the only proceeding 6 in which we could directly face these concerns. Our 7 immediate reaction was that we should appear appeal in court, 8 but our lawyers informed us we are not allowad to appeal in 9 court unless and until an operating license is approved.
10 I cannot understand how this board can take these 11 actions. I cannot understand how you can refuce to allow g3 12 these whistleblowers to speal: as part of the official record
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13 of this proceeding. I cannot understand how the NRC could 14 refuse to investigate their concerna. I cannot understand 15 why you have not fully investigated complaints with the U.S.
16 Labor Department concerning the harassment. Some of these 17 whistleblowers will speak here during the public witness 18 i portion of the hearings of their concern, but others will not 19 since their testimony is not concidered part of the official 20 record. The limited appearances, as was stated earlier, are 21 not part of the official record and will not be considered in 22 the licensing proceeding.
23 It is you who must live with your consciences and 21 , face yourselves in the mirror, but it 1: the people who live 25 I here who must face the consequences of your actions. You are ACE FEDERAL REPORTERS, INC.
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,- 7RT zas 1 endangering the people of Georgia and South Carolina throuch 2 your reckless disregard of the safety of Plant Vogtle. It a 3 major accident occurs at Plant Vogtle -- and as things now 4 stand, when a major accident occurs at Plant Vogtle --
5 perhaps you will regret your actions. Perhaps yeu already 6 do. Perhaps you are un' der pressures we have no way of 7 knowing about which have led to this persistent pattern of 8 irresponsibility. But in any case, you have clearly 9 demonstrated that you have little concern for the people and 10 their safety.
11 It is clear that the purpose of these hearings is 12 to put on a show for the public, to try to convince them that
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I 13 you are paying attention to safety problems at Plant Vogtle.
14 By agreeing to make minor chances in the plant's construction 15 as a result of our contentions, you hope to says See, we 16 really do care. This plant is now safe.
17 If it's so safe, why is Georgia Power company now 18 lobbying Congress to continue to limit its liability, if 19 there is such a major accident? If Georcia Power believes 20 the plant is safe, why won't it accept financial liability?
21 Is its money really important -- is its money really more 22 important than the safety of people of Georgia and North 23 Carolir.a? If you did not have the cloak of sovereign 24 immunity which protects you from liability for your actions, (O
t_/ 25 would you be following this path?
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~RT c,u 1 When Jim O'Reillv, the req;onal direc tor of toe 2 NRC, retired at aqe 56 and went to work fot Georgia Power, it 3 should have been obvious to you all th:st the NRC does not 4 represent the public interest.
5 We are notifyino the Concressional delecation from 6 Georcia and South Carolina as well as appropriate other NRC 7 oversicht committees of Congress of our experience:. We hope 8 that tbay will take corrective measures.
9 In the meantime, it is clear to us that, ac one of 10 the whistleblowers stated: NRC standa for"Nobody Really 11 Cares." But we do care. And we fear that by participating 12 ,
in this proceedino we are givinc it credibility it does not 13 deserve, We cannot* in good conscience participate in such a 14 ,
sham. Therefore, on behalf of the members of Campalan f or a l
15 Prosperous Georgia and the citizens of Georgia and South 16 Carolina, we refuse to contribute further to thiJ cruel hoax 17 and will not participate in thia doc and pony show you call 18 the licensing hearinos.
l 19 I Good day.
20 (Leaves.)
21 JUDGE MARGULIES: Does he also speak for Georgians 22 ) Against Nuclear Energy or Campaign for a ProJperous Georgia?
23 MR. TEFER6 I acree with everytblog he hhn just 24 said, having lived out this reality. I waa not prepared for 25 thic representative of Campaign tur a Prosperous Georgia to ACE. FEDERAL REPORTERS, INC.
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1 leave these proceedings. If I could ask for a recess for 10 2 minutes, I could then go ahead with the procedure at this 3 time. GANE does then plan to proceed in these proceedings.
4 I would like to make a motion for a 10-minute S recess.
6 JUDGE MARGULIES: We will take a 10-minute 7 recess.
8 fir . TEPER: Thank you, Mr. Chairman.
9 (Recess.)
10 JUDGE MARGULIES: Back on the record. At this 11 time I wish to clarify the record by stating that an cpening gs 12 statement is to provide the, parties with an opportunity of
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13 static.g what they intend to prove in the proceeding. The 14 opening statenent is not evidence.
15 I further wich to state that all the actions of 16 this licensing board are a matter of public record on file in 17 the official docket of the NRC at Washington D.C.
18 With that we will go to you, Mr. Teper, and listen 19 to your statement.
20 MR. TEPER: Thank you, Mr. Chairman. My name la 21 Doug Teper. I represent Georgians Against fluelear Energy.
l 22 i While the people of Georgia and South Carolina 23 have suffered under the illegal acts of the !JRC .ind the 24 Atomic Safety and Licensing Doard, it has become incumbent
'J 25 upon certain individuals to proceed with trying to further ACE. FEDERAL REPORTERS, INC, c~uva rm % ______m________ _ _ _ _
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1 the goals and purposes of the United States Concreas when 2 they mandated the NRC to look out tor the health and sarety 3 of people around nuclear facilities.
4 GANE intends to continue in the proceedings, even 5 though they agree in full force and manner with the 6 statements made by Mr. Johnson. There is a legal term, res 7 ipso loquitur, which basically says that the thing speaks for 8 itself.
9 While you state that everything is in the public 10 record, I think a review of the public record will show that 11 Mr. Johnson is absolutely correct in statino the failings of g- 12 this Board and the Commission.
13 It is the intent of GANE in these proceedings to i
1 14 j show that this is a horse and pony show: that this board has 15 all intentione, from the very beginning, to grant this 16 license. There has never been a facility, no matter what 17 shape or form, no matter how many whistleblowers have come 18 out -- or I should say workers and engineers who have worked 19 at plants around this country and here at Vogtle, who have 20 come forward with statements showing faulty workmanship.
21 Even with all this evidence there has never been a license 22 denied in this country.
23 CANE will participate, and by their participation 24 we hope that we can enter into the record evidence of the k- 25 potential catastrophe that is heading full force, like a ACE. FEDERAL REPORTERS, INC.
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1 locomotive train, towards the people of Georgia and South 2 Carolina.
3 Today we start proceedings on groundwater, 4 solenoid valves, and doce rate effects. The real issue is 5 overall construction quality assurance.
6 You have seen fit to do away with this 7 contention. At this point I would just like to say that GAME 8 is staying in the proceedings because we have information 9 that workerc, ac is traditionally the case around the country 10 as they are no loncer employed at the plant, come forward 11 with information about work which was not done correctly, fs 12 which violated NRC regulations, which was overlooked by
(
v
)
13 quality acaurance in: rectors, and if GANE were to sit out of 14 the proceedings at this point, there would be no way for the 15 people of Waynesboro, for the people of Burke County, Georgia 16 or South Carolina, to come forward in a manner in which they 17 would be used to, in order to bring these -- bring this 18 evidence forth.
19 So, on that matter, GAME ic staying in the 20 proceedings. We will attempt to prove our contentions on the 21 three issues before us, but the main issue is the fact that 22 we are going to follow Georgia Power to hell and back, if 23 that's what it takea, to thow thl Board, if possible, and to 24 show the United States Congress who is investigating the NRC tx
- 25 Reglon 2 office -- and we have beea in contact with their ACE. FEDERAL REPORTERS, INC.
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26113.0 RT vee f 1 office, and they are investigating the possible illegal acta 2 of the NRC.
3 And GAME is going to stay in it, and we can !
1
! 4 anticipate that in the near future we will have workers' l 5 evidence; we will bring it forward, and we will embarrass 6 Georgia Power and all their sub -- not all their 7 subcontractors but a number of their subcontractors in 8 showing the shoddy w,rkmanship and the overlooked --
9 overlooking of inspections that some of the workers who 10 worked so hard at the plant have broucht forward, but because 11 of production and money, the company has seen fit to just go 12 over. .
( .
13 So, on that note, GAME will stay in the 14 intervention and we can proceed at this time.
15 l JUDGE MARGULIES: Does Staff have an opening I
16 '
statement?
17 ,
MR. BORDENICK: We do, Judge Margulies.
l 18 The Board has described the three contentions that 19 remain in issue, and the Staff will, on Contention 7 present 20 a panel of two witnesses and on the two environmental 21 qualification contentions will present the same witness --
22 one person.
22 It is the Staff's position that subsey Jent to the 24 presentation of evidence on these three contentions, the 1
25 Doard will be able to find that these contentions are witho .
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2 Accordinoly, the Statt will ask the Board, 3 subsequent to completion of the second phase of these 4 proceedings which Judge Margulies alluded to in his opening 5 remarks, which constitute the emergency planning aspects, 6 assuming that that phase is satisfactorily resolved in 7 Applicant's favor and upon a favorable completion or 8 conclusion of the Staff's review of the application, we will 9 ask that the licensing board ailthorize the NRC Staff to find 10 that the contentions raised are without merit and authorize 11 the Staff to issue an operating license for the two units in 12 question.
'~
13 Thank you.
14 MR. WHITNEY: Your Honor, in the interest of 15 fairness, could we respond to Mr. Johnson and Mr. Teper's 16 opening statement?
17 MR. TEPER: Mr. Chairman, I object to this. I 18 believe opening statements are not a time for argument. The 19 company waived their rights to opening statement. I don't 20 see why they want to start arguing now. They will have had 21 three years of this to prove their case then.
22 JUDGE MARGULIES: The Board will deny the 23 request.
24 Are Applicants ready to proceed?
(
x- 25 MR. CHURCHILL: We are, your Honor.
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26113.0
RT 24o 1 JUDGE MARGULIES: You may call your witnesses and 2 I will swear them.
3 MR. CHURCHILL: Your Honor, I would like to call 4 to the stand Mr. Crosby, Mr. Farrell, Mr. West, and 5 Mr. Papadopulos -- Dr. Papadopulos.
6 MR. TEPER: Mr. Chairman, GANE would like to know 7 what the proper procedure is. Should the Intervenors wait 0 for the end of direct testimony before they ask questions?
9 Or is it proper to interrupt with a question?
10 JUDGE MARGULIES: In any orderly procedure, 11 cross-examination must await the conclusion of direct 12 examination to answer questions.
14 .
MR. CHURCHILL: Your Honor, while the witnesses I
15 are getting ready for y>;u to swear them, I would like to seek 16 some clarification in the status of the intervening parties 17 in this proceeding.
18 { It is ny understanding that Georgians for a 19 Prosperous -- Campaign for a Prosperous Georgia, CEG, has 20 withdrawn from the proceeding. May we seek clarification 21 from Intervenors on that?
22 MR. TEPER: That is correct.
23 MR. CHURCHILL: Do unders tand the Board accepts 24 that withdrawal uo we will no longer have them on our service
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1 be allowed to participate no further in the filing of 2 proposed findings in this proceedinc?
3 JUDGE MARGULIES: The Board was furnished a copy 4 of the statement of Tim Johnson. In looking at the last 5 paragraph of hic statement, which he stated on the record 6 here, he indicates that he will not participate in the 7 licensing hearings. We take that as a formal withdrawal on 8 the part of Campaign for a Prosperous Georgia, and as such 9 that organization will no longer be considered as a party to i
10 this proceeding.
11 MR. TEPER: Mr. Chairman?
rx 12 . JUDGE MARGULIES: Yes.
]
13 MR. TEPER: May I request that, since Campaign for 11 a Prosperous Georgia will no longer be on any of the service 15 lists, may I request that Georgia Power Company and the rest
- 16 of the Applicants include the enclosures tha* sometimes come 17 in their service process, which have been not coming to 18 ( Georgians Against Nuclear Energy?
19 MR. CHURCHILL: Your Honor, we will provide 20 service as appropriate in accordance with the regulatione, 21 taking into consideration that there's now just one 22 intervening party.
23 JUDGE MARGULIES: The.nk you.
24 I will now swear the members of the panel. Would O)
\- 25 you please stand and raise your right hands?
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26113.0 In' ^45 1 Whereupon, 2 THOMAS W. CROSBY, 3 CLIFFORD R. FARRELL, 4 STAVROS S. PAPADOPULOS 5 and 6 LEWIS R. WEST 7 were called as witnesses and, having first been duly sworn, 8 were examined and testified as follows:
9 JUDGE MARGULIES: Please be seated. You may 10 proceed.
11 DIRECT EXAMINATION 12 BY MR. CHURCHILL:
13 Q Mr. Wells, will you please state your full name 14 and place of employment for the record.
15 A (West) Lewis Reed West. I'm employed by Bechtel 16 Civil and Minerals, Inc., San Francisco, California.
17 Q And what is your position there with Bechtel?
18 A I'm a hydrogeologist.
19 Q Will you describe, very briefly, your involvement 20 in the Vogtle project?
21 A I have been involved with the geotechnical and 22 groundwater aspects of the project and -- as it relates to 23 ! availability of water and foundation design.
24 JUDGE MARGULIES: May I interrupt. Would you x- 25 please put the microphone in front of you, Mr. West, so we ACE. FEDERAL REPORTERS, INC.
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2 BY MR. CHURCHILL:
3 Q What is the purpose of your testimony today, 4 Mr. West?
5 A (West) To address the issues in Contention 7.
6 JUDGE MARGULIES: Would you please put the 7 microphone closer to yourself so that the spectators can hear 8 as well.
9 BY MR. CHURCHILL:
10 Q Mr. West, do you have any corrections or 11 additions? Let me first ask you, you have before you a copy 12 of a document entitled, " Applicant's testimony of Thomas W.
~
13 Crosby, Clifford R. Farrell and Lewis R. West on Contention 14 7, Groundwater," dated February 24, 1986..
15 A (West) Yes, I do.
16 Q Do you have any corrections or additions to make 17 to that testimony?
18 A Yes, I do. On page 36, the first paragraph, three 19 lines -- four lines down from the top.
20 Q Could you just pause for a moment until we have 21 all found page 36. What is the correction?
22 A The statement is, " Estimated water and storage in 23 the Tuscaloosa . Aquifer is approximately 21 billion acre-feet 24 and sustainable yield is estimated to be 5 million gallons
_ 25 per day."
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1 It should be corrected to read: " Estimated water 2 in' storage in the Tertiary and Cretaceous aquifers is 3 approximately 21 billion acre-feet and sustainable yield from 4 each is estimated to be 5 billion gallons per day."
5 Q Do you have any other changes?
6 A No, sir.
'7 JUDGE MARGULIES: Do all the parties have that 8 correction?
9 BY MR. CHURCHILL:
10 Q Mr. West, is this document, as changed, your 11 testimony in the proceeding today?
r~ 12 A (West) Yes, it is.
13 Q Mr. Crosby, would you plea.se state your nime and 14 place of enployment.
15 "A (Crosby) My name is Thomas Warren Crosby. I'm a 16 geologist with Bechtel Civil and Minerals in San Francisco.
17 Q Is that a statement of your position there? What 18 is your position there?
19 A My position is as an engineering geologist.
20 Q Can you briefly state your involvement in the 21' Vogtle project?
22 A I have been involved in the Vogtle project with 13 regards to licensing ac:1vities for the geology and 24 groundwater aspects at Plant Vogtle.
25 Q Do you have any corrections or additions to make l
f l
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2 A Just that stated by Mr. West.
3 Q Okay. The document we identified to Mr. West, as 4 corrected, is that your testimony in this proceeding?
5 A Yes, it is.
6 Q Mr. Farrell, I might ark you the same types of 7 questions. Will you please state your full name and place of 9 employment.
9 A (Farrell) Clifford Raddon Farrell. I'm employed 10 by Bechtel Civil and Minerals, Inc., San Francisco.
11 Q What is your position with Bechtel?
12 A I'm a hydrogeologist.
13 Q And your involvement in the Vogtle project?
14 A I have had technical supervision and review of the l
15 -- of those aspects related to hydrogeology of the site.
16 Q The document that we just identified, dated 17 February 24, 1986; as Mr. Crosby has changed that document, 18 is that your testimony in this proceeding today?
19 A Yes, it is.
20 , Q Dr. Papadopulos, would you please state your full 21 name and place of employment.
22 A (Papadopulos) My name is Stavros Papadopulos. I 23 am employed by S.S. Fapadopalos and Associates.
24 Q And what is your position there?
25 A I'm the president of the company.
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~ RT iac 1 Q And your involvement, sir, in the Vogtle project?
2 A I first becan gettino involved in the Voatle 3 project in 1982, when I participated in a review panel with 4 responsibility of reviewing hydrogeolocic investigations 5 conducted by Bechtel to acsess -- to investigate the 6 postulated Millett Fault.
7 In more recent months I have participated in 8 reviewing the hydrogeologic investigations conducted by 9 Bechtel at the site, with the purpose of evaluating iscues 10 raised by Contention 7.
11 Q How would you characterize your professional 12 training and experience? Would you say, for example, you
~
13 were 1 hydrogeologist or do you have a better name?
. 14 A Hydrogeologist or a groundwater hydrogeologist 15 would be proper.
16 Q I have before me and ask if you have a document 17 entitled " Applicants' Testimony of Dr. Stavros S. Papadopulos 18 on Contention 7, Groundwater," dated February 24, 1986.
19 A Yes. I would like to make a correction on page 9 1
20 '
of the testimony. On the fourth line, above the botton of 21 the page, after " tracer tests," I would like to insert the 22 word "and." Remove the parentheses around "poin t dilution 23 method" and chance me t hod" to " test.9," 30 that the sentence 24 now reads " tracer tests and point dilution tests."
/ 25 Q Do you have any other changes?
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~nT 255 1 A No, sir.
2 Q Do you adopt this testimony, this document as you 3 have just changed it as your testimony in this proceeding?
4 A That's correct.
5 MR. CHURCHILL: Your Honor, that concludes our 6 direct testimony and I would ask that both documents, the 7 testimony of Messrs. Crosby, Farrell and West, and the 8 testimony of Dr. Papadopulos, be incorporated into the record 9 as if read.
10 JUDGE !4ARGULIES: We will bind in the statement of 11 Crosby, Farrell and West, with the corrections as made, as
- x 12 the first document, to be followed by the statement of 13 5' Mr. Papadopulos wi.th the correction as made. That's to 14 follow the first statement.
15 (The documents follow:)
16 17 I 18 19 20 21 22 23 24
> 25 i
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~x ' February 24, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424 (OL)
) 50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
APPLICANTS' TESTIMONY OF DR. STAVROS S. PAPADOPULOS ON CONTENTION 7 (GROUND-WATER)
My name is Stavros S. Papadopulos. I am the President of S.S. Papadopulos & Associates, Inc. (hereafter SSP &A), a con-sulting firm specializing in ground-water hydrology. My busi-ness address is SSP &A, 12250 Rockville Pike, Suite 290, Rockville, Maryland 20d52. My professional qualifications and experience are presented in my resume attached hereto as Exhibit A, which is incorporated herein by reference.
I am familiar with the hydrogeology of the VEGP site and its vicinity, having previously participated in the l
l I
hydrogeologic investigations related to the study of the then-(~}
postulated Millett Fault. Recently, I was requested by the Applicants to make a comparative evaluation of ground-water velocities computed by the application of Darcy's Law under the assumption of one-dimensional flow field versus those computed by three-dimensional analyses, and to review and comment upon analyses made by Bechtel of the consequences of a potential ac-cidental spill at VEGP. The purpose of this testimony is to present the results of the evaluations I carried out to address these topics.
Comparison Between Ground-Water Velocities Computed by One-Dimensional and Three'-Dimensional Models C
In their evaluation of travel times for radioisotopes ori-qinating from a potential accidental, spill at the VEGP site, the Applicants assumed the travel pathway to be the linear dis-tance between the postulated point of spill and the point of discharge. Average gradients along this pathway were calculat-ed frem observed water levels, and Darcy's Law was used in con-junction with the porosity and hydraulic conductivity of the subsurface materials to determine ground-water velocities.
Travel times were then calculated by dividing the linear dis-tance between the point of spill and the point of discharge by this velocity.
2-
i l
The Intervenors (in Intervenors' Response to Applicants' Motion for Summary Disposition of Contention 7) referred to studies at SRP where ground-water velocities calculated in a manner similar to that of the Applicants differ from those cal-culated by a three-dimensional model and by tracer tests, and Intervenors alleged that the method used by the Applicants to calculate ground-water velocity at VEGP may lead to large er-rors. The primary issue underlying the Intervenors' allegation is whether the one-dimensional approach used by the Applicants overestimates travel times between the point of spill and the point of discharge. Two aspects of the one-dimensional ap-preach were examined to address this issue: 1) the use of lin-ear pathways between the point of spill and the point of dis-() charge; and 2) the use of an average gradient to calculate the ,
average velocity over large distances. Finally, the rep'orted difference in ground-water velocities calculated by different methods at the SRP site was examined.
Effect of Using Linear Pathways Figure 1 shows a plan view (Figure la) and a cross-section (Figure Ib) of a water-table aquifer between two parallel streams, receiving recharge at a uniform rate. Note that a water particle at point A near the ground-water divide will mi-grate to a point S on the stream along a three-dimensional pathway. The trace of this pathway on plan view (Figure la) is
indicated by the flow path denoted as ABS and in cross-section
(~)
\~j '
(Figure Ib) by that denoted as AB'S. If we denote the length of this three-dimensional pathway by "d", the average velocity V,y along this pathway is:
K (hg -h) 3 v,y = -- ------- ,-
n, d a where-K = hydraulic conductivity (dimension LT-1) n,= effective porosity; hg = water-table elevation at A (L);
h3 = elevation of stream at S (L);
and the travel time t based on this average velocity ist d n, d2 t = --- = -- ---------
v,y K (hg-h) 3 In a one-dimensional approach, the pathway to be consid-ered is the linear distance 1 (see Figure la) between points A and S, and the calculated travel time is:
2 n, 1 t = -- ---------
K (hg -h)s 1
Since the linear distance 1 is shorter than the three-dimensional pathway d, the travel time calculated by the
() one-dimensicnal appr:ach is smaller.
_4
Effect of Using Average velocities In both the three-dimensional and the one-dimensional ap-proach discussed above, an average velocity based on the aver-age gradient was used to calculate the travel time. As the distances between successive equipotential lines (see Figure 1) along both the three-dimensional and the linear pathways indi-cate, the gradients along the pathways, and consequently the velocities, change. The effect of using average velocities to calculate travel times along pathways where the gradient and velocity change with distance is examined next.
Figure 2 shows an aquifer system similar to that of Figure 1, but under assumptions that would create, as nearly as
(]) possible, one-dimensional flow conditions.
The streams fully penetrate the aquifer, and the slope of the stream surfaces is
- assumed to be small so that the equipotential lines (lines of equal water table elevation) are essentially parallel to the streams. It is further assumed that the hydraulic head does not change significantly with depth and that it remains essen-tially equal to the height of the water table. Under these as-sumptions, the flow field is one-dimensional and the height of the water table h, at any distance x from the ground-water divide is given by:
3 W 3 h3 g - -- (l"-x 2))1/2
= (h' O
-S-
. - . - . , - . - - . - ,,. -_.,-,--,----,-,..-.------.-n. e. y - --v--,-,-.. , - . --- -.
. . - - - ,..-.-----.-.---,,-.,.-,n .n
where, as before, h is the elevation of the stream, K is
} 3 the hydraulic conductivity, and:
W = uniform recharge rate (LT'1); and ,
1 = linear distance between ground-water divide and stream (L).
The ground-water velocity at any distance x from the di-vide is given by K dh v = - -- --
n, dx Wx
= -- [ h 3 2.g ,
g1 2
,2)j-1/2 ne K where, as before, n, is effective porosity. Thus, the ve-locity changes from zero at the ground-water divide (x = 0) to a maximum value of Wl v = ....
"eh, at the face of the stream (x = 1).
Under these conditions, the travel time between a point at a distance x from the divide and the stream can be calculated by noting that velocity is also defined as O
h dg x y = .. .
dt i .
and that therefore dx dt = --
v l
By substituting the expression for velocity given earlier and integrating both sides of the equation, the following travel time equation is obtained:
n, x(h,- h 3) t =
-- (h , log, ---------- - (h,-h 5)I w 1(h ,- hx) r' where h,
=
[h 3 2 . f,}2,3 1/2 ,
K h,is the maximum height of the water table which occurs at the ground-water divide (x=0), dimension'L, and all other terms are as previously defined. Note that an infinite time results if this expression is used to calculate travel time between the ground-water divide (x = 0) and the stream. This result is to be expected since the velocity on the ground-water divide is zero and a water particle on the divide theoretically would never move under the assumed one-dimensional flow conditions.
On the other hand, if the travel time between point x and the stream is calculated using the average velocity between these two points, the travel time is given by 3
(V n, (1-x)2
, t = -- -------
K (h,-hS I since these two expressions cannot be easily compared directly, a numerical example will be used to compare them. For a hy-draulic conductivity of 2,000 ft/yr, a recharge rate of I ft/yr, an effective porosity of 0.25, a divide-to-stream dis-tance of 4,000 ft, and a stream elevation of 100 ft, the actual travel time between a point 1,000 ft from the divide (x = 1,000 ft) and the stream is calculated to be 43 years. For the same parameters, the travel time calculated using the average veloc-ity is 35 years.
As illustrated by this numerical example, even under one-V(~N dimensional flow conditions, travel times based on average velocities are underestimated, that is, they are smaller than those calculated taking into consideration changes in gradient and velocities along the pathway. The difference between the actual travel time and that calculated by using average velocities becomes smaller as points closer to the stream (the discharge point) are considered, but thos,e based on average velocities are always smaller.
Difference in Ground-Water Velocities at SRP The difference in the ground-water velocities at the SRP site calculated by different methods and presented in the
(} reports referred to by the Intervenors (DPST-83-829, vol. 1, and DP-1638) is primarily due to the differences in the hydrau-lic conductivity and porosity values used in the calculations rather than the method of calculation.
The ground-water velocities for the Barnwell Formation re-ported in DPST-83-829 (p. 3-24) are calculated by a simple one-dimensional model similar to that used by the Applicants for the VEGP site. An effective porosity of 0.20 and hydraulic conductivities of 1 gpd/ft2 (0.13 ft/d) and of 7.4 gpd/ft2 (0.99 ft/d) are used, respectively, to illustrate 1
l the properties of clayey sands and sand lenses in the Barnwell.
l The calculated velocities are 4.3 ft/yr and 32 ft/yr, respec-(~
tively, for a clayey sand unit and for a sand lens.
l The ground-water velocities reported in DP-1638 were cal-culated by a three-dimensional (multi-layer) model. A hydrau-
, lic conductivity of 5.9 ft/d, determined through model l
calibration, and an effective porosity of 0.25 forms the basis of these calculations that yield velocities ranging from l 30 ft/yr along the ground-water divide to about 205 ft/yr near 1
The Four Mile Creek. eport also refers to velocities deter-4e.ds mined by tracer tests / point dilution ::thod) in the western l t portion of the model area and ranging from 36 ft/yr to 72 l
ft/yr. However, an effective porosity of 0.33 was used in cal-l culating these tracer-:est based velocities. To compare the 1
r 9
l l
t
, _. .. _ _ _ .._.~ - .._ _ .- 2 _ - -----=m----------------- - - - =
1
~'
velocities determined by three-dimensional analysis with those k'_).
l from the tracer tests, the velocities determined by three-dimensional analysis were recalculated in DP-1638 using a l porosity of 0.33; this recalculation resulted in velocities l
that ranged from 24 ft/yr to 154 ft/yr.
l To compare the velocities determined by the three-l dimensional analysis with those from the simple, one-
- i l dimensional analysis, the aquifer properties used in these two methods must be the same. If the hydraulic conductivity of 5.9 ft/yr determined by model calibration represents the average hydraulic conductivity of the Barnwell, without distinction be-tween the clayey sand unit and sand lenses, and the value of effective , porosity appropriate for velocity calculations is 1 0.33, then the simple, one-dimensional approach results in an I
average velocity of 117 ft/yr.
This velocity is larger than the largest value determined by tracer tests; thus, if used to calculate travel times, this l velocity will result in travel times that are underestimated l
with respect to those calculated from tracer-test velocities.
In other words, the travel times computed by ene-dimensional analysis will be smaller than the travel times calculated from velocities determined by tracer tests.
l l In DR-1638, travel times are presented on the basis of calculations that consider the change in gradients and, O
l L.
(} therefore, in velecities along the travel path, for three path-ways between the old burial area and a discharge point along the F-Area Effluent Stream (DP-1638, p. 27-28). The reported length of these three pathways and the reported travel times are presented below along with travel times calculated using the average velocity of 117 ft/yr obtained from the simple ene-dimensional model:
Travel Time, yrs Reported in one-Dimensional Pathway Length, ft DP-1638 Model 1 k,200 90 36 2 3,180 60 27 3 1,780 O 17 15 These results indicate that the one-dimensional model underestimated travel times for all three pathways. In fact, the degree of underestimation would have been even larger if linear pathways between the point of origin and the discharge point were to be considered in a manner similar to that used by the Applicants at the VECP site.
As stated earlier, the differences in the ground-water velocities at SRP calculated by different analyses are primari-ly due to the differences ir the aquifer proporties used in the different.calculaticns rather than the method of calculation.
When brought to a common basis by using similar aquifer
.__ _ . . - - . . . - . = _ -.=
() properties, the smallest travel times are'those calculated by a simple, one-dimensional model.
Review of Spill Analyses Analyses of the potential impacts of an accidental spill at the VEGP site have been made in the past by both the Appli-cants and NRC staff. The analysis by the Applicants addressed the potential impacts of the rupture of the Recycle Holdup Tank (RET), which was considered to be the most critical with respect to the. potential impacts of its failure. The spill analysis scenario postulates the simultaneous failure of both the RET tank and of the auxiliary building in which the tank is located, and the instantaneous release of liquid waste O(_/ containing three critical radioisotopes, tritium (H-3), stron-tium (Sr o0) and cesium-137 (Cs-137) into the water table aquifer underlying the site.
The spill analyses which are subject of this testimony are those presented in " Applicants Testimony of Thomas W. Crosby, Clifford R. Farrell, and Lewis R. West on Contention 7 (Ground-Water)." These analyses consider vertical migration across the marl underlying the water table aquifer and lateral migration along a northwesterly pathway into Mathes Pond. As an alter-nate lateral pathway, northeasterly migration into the Savannah River is considered.
O
~s The spill analyses were based on travel times calculated (J
'. by a one-dimensional model which, as discussed in the previous section of this testimony, underestimates travel times. The transmitted fraction of the radioisotopes is calculated by con-sidering radioactive decay over the period of the computed travel time, ad, justed for retardation in the case of Sr-90 and Cs-137. Additional conservatism is introduced in the calcula-tion of the transmitted fraction by neglecting the effects of i radioactive decay on the initial concentration of radioisotopes as they leave the source area (the starting point of the path-way) and the effects of hydrodynamic dispersion. Furthermore, in considering lateral migration, the calculation of the trans-mitted fraction is based on travel time across only the
() backfill area in .the power block; migration cutside the block l is assumed to be through the Utley Limestone and travel time is assumed to be negligible. ,
An evaluation that considered radioactive decay at the source area and hydrodynamic dispersion along the travel path was made to assess the effect of these mechanisms on the calcu-lations of the transmitted fraction of radioisotopes. This evaluation was made for tritium, the only isotope calculated by the Applicants to exceed maximum permissible concentrations for normal releases (10 C.F.R. Part 20, Appendi:. B, Table II, Column 2) in ground water leaving tne backfill area.
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) A computer program developed by Javandel, Doughty and Tsang (Groundwater Transport: Handbook of Mathematical Models, American Geophysical Union, Washington, D.C., 1984) was used for this evaluation. The program solves the equation derived by Van Genuchten (One-Dimensional Analytical Transport Modeling in Proceedings: Symposium on Unsaturated Flow and Transport Modeling, Rep. PNL-SA-lO325, Pacific Northwest Laboratory, Richland, Washington, 1982; also available as U.S. Nuclear Reg-ulatory Commission Rep. NUREG/CP-0030, 1982) for one-dimensional transport of solutes in ground water.
The volume of the accidental spill considered by the Applicants is about 12,000 ft.3 . The saturated thickness of the backfill in the vicinity of the spill is about 22 ft.
and the backfill has an average porosity of 0.34. Based on these values, the slug formed by the spill was assumed to be 22 ft. high and occupy a square area 40 ft. by 40 ft. Using a specific discharge rate based on the hydraulic conductivity and gradients used by the spill analysis of the Applicants, the period required for the entire slug to migrate across the plane defined by the initial position of its downstream face was cal-culated to be about 3 years. Based on this calculation, a three-year period of source decay was assumed. Dispersivities (characteristic mixing lengths) of 2 ft, 5 ft, and *.O ft, cor-responding to longitudinal dispersion coefficients of 28 2 2 ft /yr, 70 ft /yr and 140 ft fyr, respectively,
~'
were considered in the analysis. The results of the analyses (G
i are shown on Figure 3 and are summarized below:
Peak Concentrations of Tritium Dispersion Coefficient Arrival Time Magnitude 2 3 ft /yr yrs uCi/cm 28 40 3.5 x 10-2 70 39 2.4 x 10-2 140 37 1.8 x 10~2 The spill analysis which neglects the effects of decay at source and of hydrodynamic dispersion had resulted in a tritium concentration of 1.15 x 10 -1 uCi/cm 3 in water leaving
~
() the backfill area (Applicants' Testimony of Thomas W. Crosby, ,
Clifford R. Farrell, and Lewis R. West on Contention 7 -
Ground-Water). As the above resdits indicate, decay at source and especially hydrodynamic dispersion would reduce the concen-tration of tritium in water leaving the backfill. A dispersivity of 10 ft, corresponding to a longitudinal disper-sion coefficient of 140 ft2 /yr reduces the calculated con-centration of tritium by almost one order of magnitude, that is a factor of 10. Dispersivities as large as 100 meters (300 feet) have been used in mathematical simulation studies of large contaminant plumes in sandy aquifers (Freeze and Cherry, Groundwater, Prentice-Hall, Inc., Englewood Cliffs, New Jersey, 1979, p. 400). Therefore, a dispersivity of 10 ft is not )
\~- l
S inconceivable for the sandy backfill materials at the VEGP m) site. I Conclusions The evaluations of the effects of using linear travel dis- i tances and average velocities in calculating travel time and of the reported differences in ground-water velocities at SRP in-dicate that the approach used by the Applicants to estimate '
travel times for radioisotopes, postulated to enter the water i
table aquifer at the VEGP site after a potential accidental spill, are conservative. The simple, one-dimensional approach used by the Applicants underestimates travel times, first, be-cause it is based on the linear distance between the postulated
() point of spill and the point of discharge, and second, because 1
it uses average velocities to calculate travel times.
The spill analyses conducted by the Applicants based on these travel times also neglect the effects of decay at source and of hydrodynamic dispersion. These mechanisms will reduce the calculated concentrations of the radioisotopes considered in the analyses.
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, @ c. c. PArAccrui.co o AcccCIATEO. INC.
O STAVROS S. PAPADOPULOS Ground-Water Hydrologist Date and Place September 21, 1936 of Birth: Istanbul, Turkey Citizenship: U.S.A. (naturalized November 1969; first name corrected to "Stavros" from "Istavros")
Education: Doctor of Philosophy in Civil Engineering, 1964 Princeton University, Princeton, New Jersey.
Master of Arts in Civil Engineering, 1963, Princeton University, Princeton, New Jersey.
Master of Science in Ground-Water Hydrology, 1962 New Mexico Institute of Mining and Technology, Socorro , New Mexico.
Bachelor of Science in Civil Engineering, 1959 Robert College, Istanbul, Turkey.
O tan.ua9 : Ensiisa. Prenca. Greei . Turxisa.
- owiedoe of SPanisa.
Professional -
Registration: District of Columbia.
Professional Societies: American Society of Civil Engineers (Hydraulic Division, Comittee on Ground-Water Hydrology, Memb.er 1975-79; Corresponding Member 1980-81)
American Geophysical Union National Water Well Association International Association of Hydrogeologists (Member, U .S .
National Comittee, 1981-84)
Sigma Xi heards & Honors: U.S. Department of Interior Meritrocious Service Award, May 1977.
U.S. Geological Survey Special Achievement Award, September 1977.
Medal of the City of Montpellier, presented at the International Symposium on the Implications of Hydrogeology on Earth Sciences, Montpellier, Prance, September 11-16, 1978.
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Publications: List of publications attacned.
4,
,, @ c. c. PAPA:crui.co o Accoc Avs2. ma.
e d STAVROS S. PAPADOPtA.0S Ground-Water Hydrologist /
Pmfessional -
Experience: '
October 1979 to pertsent S. S. Papadopulos & Associates, Inc., Consulting Ground-Water Hydrologists, Rockville, Maryland. President. As the senior executive officer of the company, manages the business affairs of the company and provides quality control for technical services. Directs and conducts studies on all aspects of quantitative ground-water
. hydrology. Areas of expertise include formulation of
- ground-water projects, evaluation of ground-water resources through use of'matnematical and digital models, design and analysis of aquifer testi, Saltwater intrusion in coastal aquifers, movement of contaminants and storage of heat in aquifers,.and other problems involving ground-water flow
' and transport of solutes and of thermal energy in hydrogeologic systems. Some recently completed or current r activities for which he carries primary responsibility are listed below:
a) Serves with Prof. Pir. der of Princeton University, Prof.
Cherry ,.of the University of Waterloo and Prof. Freeze of the University of British Columbia on a comittee reviewing and di,recting remedial investigations conductad by other consultants at Ciba-Geigy's Toms River Plant in New Jersey.
b) Designs' hydrogNiogic testing plans for Battelle Memorial Institute of Columbus, Ohio, which will be used to guide the conduct of hydrogeologic tests in monitoring and test wells associated with the Exploratory Shaft Facilities at potential high-level radioactive waste repository site in Deaf Smith County,
~
c) Directed ' supplemental hydrogeolo'gic investigations conducted on, behalf of PRPs at the Chem Dyne Site, Hamilton, Ohio, and participated in negotiations leading to a Consent Decree. Currently, he is
. directing ' additional data collection to finalize the design of an extraction / injection system for ground-water remediation as agroed upon in the Consent Dn ree, d) Assisted potentially responsible parties (PRPs) in the review of investigations conducted by U.S. Environ-mental, Protection- Agency contractors and in the 2
n- . - . . . ._ . . - . .. .
@ C. C. PAPAT,CPULCD Q ACCOCIATCO. IN3.
O STAVROS S. PAPA 00PtR.0S Ground-Water Hydrologist preparation of an alternative remedial plan for the Lone Pine Landfill in Freehold, New Jersey. Currently, he serves as the Technical Coordinator for supplemental remedial investigations conducted on behalf of the PRPs.
e) Evaluated the ground-water monitoring program at the Oaks Sanitary Landfill in Montgomery County, Maryland, and designed a monitoring network that combined monitoring wells with a geophysical monitoring system.
September 1970 to October 1979 U.S. Geological Survey, Water Resources Otvision, Northeastern Region, Reston, Virginia. Research Hydrologist GS-14 (9/70-11/74), Hydrologist GS-15 (11/74-9/79). Originated, planned and conducted, or directed, particularly complex research projects in the analysis of ground-water systems. Developed new, and improved existing methods for aquifer test analyses and for the evaluation of 0- ground-water resources. Served as Research Advi sor Ground-Water Physics to the Assistant Division Chief for Research and Technical Coordination and to his Deputy' for Research, and assisted in periodically evaluating the Division's *research program. Frequently acted for the Deputy Assistant Chief Hydrologist for Research, and for the Regional Research Hydrologist. Made field trips to district offices to provide technical assistance to project chiefs engaged in ground-water investigations, and informed the Regional Hydrologist on progress and problems in the project. Participated and represented the U.S. Geological Survey in national and international conferences. Lectured in training schools and in advanced seminars held for Survey and developing country agency personnel. Conducted a variety of ground-water studies of national and regional interest, including the assessment of the energy potential of the Gulf Coast geopressured zones, the feasibility of aquifer thermal energy storage and the evaluation of shallow land burial sites for low-level radioactive wastes, an( undertook assignments in Saudi Arabia and Portugal on detail to other U.S. agencies and to UNESCO.
September 1969 to September 1970 University of Illinois at Chicago Circle, Department of Geological Sciences, O Pro f esso r.
Chicago , Illinois.
Taught courses in grounc-water hydrology, Associate engineering and structural geology, and advised graduate students majoring in ground-water hydrology. Conducted I
3
. @ c. c. PAPASOPuLCQ O AOOCCIATCc. INC.
p -. - ,
d
- STAVROS S. PAPADOPtA.0S Ground-Water Hydrologist s , -
}
' N research on the application of digital computer techniques to well hydraulics and aquifer evaluation studies. Served on the ' Executive Committee of the department and on various other departmental'and university comittees.
Harza Engineering Company, Chicago, Illinois. Chief Ground-Water Hydrologi st. Served on the staff of the s
, company as consultant on ground-water studies for water and land resources development projects. In this capacity, participated in ground-water studies for the Lake Minnetonka; Project, initiated reconnaissance studies of the potential .of ground water in Northern Guatemala, and served as leader of a'Harza team of experts in Indonesia for the
-s formulation of a ground-water exploration program designed to assess the technical feasibility of developing ground-water for irrigation in several areas in Java and to identify within these areas pilot irrigation projects which will provide data for subsequent large scale development of
) '
- irrigation projects making conjunctive use of surface and ground-water supplies. .
t .
June 1967 to ,'
September 1969 Harza Engineering Company, Chicago, Illinois. Ground-Water Specialist, Planning Division 3(6/67-10/67), Head of Hydroingy , Department, Water Resources Division (10/76-9/69). Supervised engineers engaged in hydrologic and ground-water investigations and in preparation of planning repo rts. Conducted continuous broad view and direction of all aspects of planning favolving ground-water resources, including preliminary and detailed- exploration programs, pumping tes *.s , resource evaluation, aquifer projection studies and definite project formulation. Respnnsible for development of standards and procedures for all ground-water related activities. Major assignments included
, ground-water studies for the Chicago Deep Tunnel Project, the Irrigation Rehabilitation Project in Indonesia, and the Ullum Project in Argentina..
University of Il!inois"at Chicago Circle, Department of Geology, Visiting Associate Professor. Taught evening courses in ground-water hydrology.
September 1966 O to aune 1987 universite or "innesote. oePert ent of ceoiosi ena Geophysics , Minneapolis, Minnesota. Associate Professor.
Conducted research in well hydraulics and aquifer evaluation methods and taught courses in ground-water '
4 l
, @ s. s. PAPAOCPUL.CO O AOCOCIAT30. IN3.
n v
STAVROS S. PAPAD0PULOS Ground-Water Hydrologist hydrology. Served on the Graduate Admissions Committee of the department.
September 1963 to September 1966 U.S. Geological Survey, Water Resources Division, Arlington, Virginia. Hydraulic Engineer GS-9 (9/63-2/64),
Research Engineer GS-11 (2/64-3/65), and Research Hydrologist G-12 (3/65-9/66). Conducted basic and applied research in the mechanics of ground-water flow.
Served as consultant to District offices on special problems such as seepage estimates for Cedar Lake in Washington, analyses of limited pumping-test data in Puerto Rico, the Virgin Islands, North Carolina and Florida, and tracer studies in Colorado. Lectured on aquifer test methods in training conferences for Survey personnel.
Prepared and reviewed technical papers.
The George Washington University, School of Engineering and O# Applied Science, Washington, D.C. Part-time Associate Professorial Lecturer (9/65-5/66). Taught evening courses in hydrology, hydraulic engineering and soil mechanics.
September 1961 to September 1963 Princeton University, Department of Geological Engineering, Princeton, New Jersey. Graduate Assistant (9/61-6/62) and 9/62-6/63). Conducted research in flow through porous media and taught a course in the theory of ground-water motion.
U.S. Geologic Survey, Water Resources Division, Ground-Water Branch, Denver, Colorado. Hydraulic Engineer GS-9 (6/62-9/62). Prepared type-curves for the evaluation of wedge-shaped aquifers in the Little Plover Basin, Wisconsin.
New Mexico Institute of Mining and Technology, Socorro, New Mexico. Research Assistant (6/63-9/63), and U.S.
Geological Survey, Whter Resources Division, Ground-Water Branch, Trenton, New Jersey. Hydraulic Engineer GS-9 (3/63-9/63). Conducted research on the non-steady flow to multiaquifer wells (project was supported by the Survey and used as a Ph.D. thesis).
5
g C. C. PAPADCPUL.03 O ADOCCIATEO. INC.
STAVROS S. PAPAD0PULOS -
Ground-Water Hydrologist September 1959 to September 1961 New Mexico Institute of Mining and Technology, Socorro, New Mexico. Graduate Research Assistant. Conducted research in problems related to ground-water flow.
June 1958 to September 1959 The U.S. Army Corps of Engineers (TUSEC). Trabzon (6/58-9/58) and Sinop (6/59-9/59), Turkey. Assistant Engineer LGS-7. Inspected general construction work and assisted in preparing revisions to design and specifications to fit local field conditions.
O .
O December 1985 .
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(D x> February 24, 1986 UNITED STATES-OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, et al. ) Docket Nos. 50-424 (OL)
) 50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
APPLICANTS' TESTIMONY OF THOMAS W. CROSBY, CLIFFORD R. FARRELL, AND LEWIS R. WEST ON CONTENTION 7 (GROUND-WATER)
() We, Thomas W. Crosby, Clifford R. Farrell, and Lewis R.
West, are geologists employed by Bechtel Civil and Minerals, Inc. Our business address is Bechtel Civil and Minerals, Inc.,
P. O. Box 3965, San Francisco, California 94119. Summaries of our professional qualifications and experience are attached hereto as Exhibits A, B, and C, which are incorporated herein by reference. We have been intimately involved with the hydro-geological exploration of the Vogtle Electric Generating Plant (VEGP) site since the beginning of the project.
The purpose of thia testimony is to address the topics pertaining to Joint Intervenors' Contention 7 which the O
Licensing Board designated for hearing in its November 12, 1985 Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 7 re Groundwater Contamination). These topics are: 1) the adequacy of geological / hydrological exploration; 2) the data on marl thickness and permeability; 3) the data on marl continuity; 4) the direction of ground-water flow; and 5) ground-water travel time.
I. VEGP Geology and Hydrology Plant Vogtle is located approximately 26 miles south-southeast of Augusta, Georgia, on the Coastal Plain of Georgia.
See Figure 1. The plain is underlain by a sequence of sedimen-tary formations which have been deposited periodically be-() ginning in the late Cretaceous period (approximately 90 million years ago) and continuing to the present. The deposition is the result of repeated advance and recession of the Atlantic Ocean. This process has created a thick wedge of alternating and interfingering beds of sand, clay, marl, and limestone sed-iments atop a basement complex of older sedimentary, crystal-line, and metamorphic rocks. The sedimentary formations dip southeast, toward the Atlantic Ocean, at an angle slightly greater than the regional slope, as shown in Figure 2.
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AUGUSTA MC BEAN PLANT GEOLOGIC CREEK VOGTLE UNITS
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SCALE IN MILES { BASEMENT BASED ON LE GRAND & BECHTEL COMPLEX l
s REGIONAL GEOLOGIC SECTION PLANT VOGTLE Figure 2
A. Geologic Units r"
1 G)
The Tuscaloosa Formation overlies the basement complex.
This formation consists primarily of sands and gravels with l
l scattered beds of silt and clay. The Tuscaloosa sediments were deposited in late Cretaceous time, or about 90 million years ago. as shown diagramatically in Figure 2, the Tuscaloosa sed-iments are exposed at the surface near Augusta.
The Huber and Ellenton Formations were deposited on the Tuscaloosa sediments during the Paleocene Epoch (Tertiary Period). These sediments consist of dark gray sandy clays and silts and multicolored clays, l The Lisbon Formation was deposited atop the Huber and Ellenton during the Eocene Epoch (Tertiary Period). Beneath
() Plant Vogtle, the Lisbon Formation is comprised of two members
-- a lower calcareous sand unit and an upper calcareous clay l (marl). The lower sands do not have a formal name and are therefore called the unnamed sands. The calcareous clay has been named the Blue Bluff marl.
l The Barnwell Group of sediments was deposited over the Lisbon Formation in the Late Eocene Epoch. The Barnwell Group is comprised of sand with minor amounts of clay and limestones.
The Utlev Limestone, which is the lowest strata in the group and which is not present everywhere, was locally deposited on 1
( the Blue Bluff marl. The overlying sediments of the Barnwell Group are composed primarily of sands and silts, and are ,
exposed at the surface in the Plant Vogtle area.
, l l
l l
(} The Hawthorn Formation sediments were deposited over the Barnwell Group sediments in the early Miocene Epoch. The Haw-thorn is the youngest Tertiary formation in the vicinity of the plant site. These sediments consist of multicolored clayey sands and gravels.
B. Hydrogeologic Units There are two major aquifers recognized in the coastal plain region, both of which are present beneath VEGP. The lower aquifer is called the Cretaceous aquifer and consists primarily of the sands and gravels of the Tuscaloosa Formation.
It is often referred to as the Tuscaloosa aquifer. The upper aquifer in the coastal plain region is called the Tertiary aquifer and consista primarily of permeable sands and lime-O stones of several Tertiary-age geologic formations. The Terti-ary aquifer is also referred to as the principal artesian aquifer, or as the limestone aquifer in different parts of the Coastal Plain. At Plant Vogtle, the Tertiary aquifer is repre-
, sented by the " unnamed sands" member of the Lisbon Formation.
Beneath the Plant Vogtle area, both the Tertiary and Cretaceous aquifers are confined. The uppermost confining layer is the Blue Bluff marl of the Lisbon Formation.
In addition to that contained in the Cretaceous and Terti-ary aquifers, ground-water in the vicinity of VEGP also exists under water-table (unconfined) conditions as shallow (less than '
o j
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100 feet) and discontinuous bodies in the Barnwell Group and l other near-surface deposits. These discontinuous ground-water units are referred to as the water-table aquifer.
C. Methods of Investigation Applicants have conducted extensive investigations of the geology and hydrology at and in the vicinity of the plant.
- These studies are up to date and demonstrate the suitability of l
l the site for a nuclear power plant.
l The investigations commenced with site exploration in l
i 1971. A thorough search of the literature, stereoscopic exami-l nation of color air photographs, detailed evaluation of geolog-ic conditions at and within five miles of the site, and geolog-l ic reconnaissance along 12 miles of the Savannah River bluff O upstream and downstream were conducted. Geologic field inves-l l tigations included geologic mapping, drilling, and geophysical l surveys. During this phase, 474 exploratory holes were drilled l
l for a total of 60,000 feet of hole. The drilling program in-l cluded electric logging, natural gamma, density, neutron, cali-l per, and three dimensional velocity logs in selected drill holes. Menard pressure meter tests were performed to determine i
in-situ engineering properties of the marl, which is the load l bearing unit for plant structures. The geophysical surveys l
l consisted of a total of 28,400 feet of shallow refraction seismic lines, 5,000 feet of deep refraction lines, and L
l l
l l
L n
(~') cross-hole velocity measurements in the upper 290 feet of mate-tj rials. (The results of these investigations are presented in Section 2.5 of the PSAR.)
Also, ground-water studies were conducted during initial site exploration. These studies included in-situ permeability testing, installation and monitoring of observation wells, and well canvasses. A total of 280 wells were located and in-spected on the west side of the Savannah River. These included all wells in use within 7 miles of the site, and an estimated sixty percent of the walls beyond to a distance of 10 miles of the site. (The data from these canvasses is found in PSAR Table 2.4-4.)
Investigations of the geology and hydrology at VEGP con-
/^
- (_)g tinued during site excavation and construction. These included detailed geologic mapping of the soil and rock strata exposed during the pcwer block excavation, and coring and testing of the Blue Bluff marl. Over 100 additional exploratory holes were drilled in the vicinity of Plant Vogtle. In addition, since initial site exploration in 1971, 37 observation wells have been used to monitor water levels in the water-table aquifer; and the Tertiary aquifer has been monitored by 23 wells. Data have also been obtained from four wells open to Cretaceous aquifer. (Not all of these wells have been opera-tional throughout the entire period of site exploration and construction; some wells have had to be abandoned and grouted -
due to their location near plant facilities.)
I
(~) In May and June of 1982, another major well canvass was
's_/
- conducted to accumulate a comprehensive hydrogeologic data base to evaluate the postulated Millett fault. A total of 886 wells
[ encompassing an area of approximately 4,400 square miles sur-rounding the plant were investigated. Geophysical well log i data from both the State of Georgia Geological Survey and the U.S. Geological Survey were obtained and analyzed. As part of the Millett study, 12 observation wells were installed along l
l two lines southeast of the plant. The wells were drilled ,
through the marl and monitored water levels in the Tertiary and i Cretaceous aquifers below the marl. The data from these and other core holes provide accurate definition of the depth of geologic units, 11thology, and aquifers from the plant to nine-() teen miles southeast of the plant, and evidence the lateral ex-tent of the marl in that direction. See, e.g., Figure 3. (The results of this study are found in " Studies of Postulated Mil-lett Fault" October, 1982.) Even more recently (1984), a well canvass was conducted to identify all offsite wells within a two-mile radius of the plant. (Results of this well canvass are presented in the FSAR at page Q240.5-1 ) ,
During the summer of 1985, a further program of geotechnical verification work was conducted at Plant Vogtle to resolve NRC Staff questions and to acquire supplementary data ,
on site characteristics. The work consisted of conducting standard penetration tests of the backfill, core drilling and ;
, I
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{} in-situ permeability testing of the mari, laboratory measure-ment of marl permeability, observation well installation, and laboratory measurement of the cation exchange capacity and equilibrium distribution coefficient of the backfill.
These programa of geologic mapping, drilling, geophysical logging, well monitoring, and permeability testing have reliably determined the location and characteristics of the i geologic and hydrogeologic units in the vicinity of Plant Vogtle. In particular, exploratory drilling, which is the pri-l mary method for determining the geologic units and aquifers at '
a site, has provided extensive information on the depth, char-acter, and areal extent of the subsurface units and aquifers.
At Plant Vogtle, over 600 holes have been drilled. Over 200 of
() these explored the marl and provide a reliable data base on its characteristics. The locations of these holes are shown in Figures 4 and 5. Detailed geologic sections have been con- l
( structed from these data and are presented in FSAR Figures 1
2.5.1-14 through 2.5.1-21.
l Permeability measurements have been made of the water-l l table aquifer, the mari, the Tertiary aquifer, and the Cretaceous aquifer. The permeability of the Barnwell sands was measured in situ in two exploratory holes and in laboratory l tests of three undisturbed samples from another hole. The [
l l lowest strata in the water-table aquifer (the Utley limestone) l
! was studied with pumping tests, falling head tests, and -
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teristics of the Cretaceous and Tertiary aquifers were also measured in pumping tests.
During site exploration (1971-1973), the marl permeability was tested in situ; 80 packer tests and permeameter tests were conducted in 22 drill holes, the locations of which are shown in Figure 5. During the geotechnical verification work per-formed in the summer of 1985, an additional 15 packer tests were performed in six new holes shown as holes 900 through 905 on Figure 5; and laboratory permeability measurements were taken on ten samples from these holes.
To provide early estimates of the permeability of the backfill material, laboratory tests of a disturbed sample of
() Barnwell sands and of two grab samples of backfill material compacted to varying densities (enveloping the design density and percent compaction) were performed. Much more recently, the permeability of the backfill material was measured in situ by slug tests performed in four observation wells in the power block area.
D. The Interrelationship of Geologic and Hydrogeologic Units at Plant Vogtle The extensive investigations at Plant Vogtle have deter-l mined the interrelationship of both geologic and hydrologic units as shown on Figure 6. The VEGP site is situated over an area wherein the Huber Formation and the Ellenton, if it is O_- .,_
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SEQUENCE OF GEOLOGIC AND HYDROLOGIC UNITS BENEATH PLANT VOGTLE Figure 6
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U present (Ellenton beds have not been positively identified be-neath the site), are thin and relatively permeable. As a re-sult, the Cretaceous and Tertiary aquifers are believed to be hydraulically connected in this area. Overlying this sequence of beds of moderate to high permeability is the Blue Bluff marl, the upper member of the Lisbon Formation. The marl, ap-proximately 70-feet thick, is a layer of very low permeability that confines the Tertiary and Cretaceous aquifers.
The Barnwell sands and limestone, which overlie the marl and in which the unconfined water-table aquifer exists at VEGP, are on an interfluvial ridge -- a topographically high area in which the ground-water in the water-table aquifer discharges along streams that nearly surround the area. The interfluvial
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ridge at VEGP is illustrated in Figure 7. The water-table is, in general, a subdued reflection of the ground surface, and movement is from the central portions of the interfluye toward the bordering interceptor streams. The streams have eroded down to the marl.
Along the east flank of the site, the interfluvial ridge ends abruptly at the bluff of the Savannah River. The sands, silts, and clayey sands that make up the water-table aquifer beneath the site are exposed in the face of ' hat bluff. More prominently exposed is the underlying unit which gives the bluff its characteristic feature -- the Blue Bluff marl. The exposure is illustrated in Figure 7. <
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Bordering the site on the south, west, and north are stream channels tributary to the Savannah River that have cut through the aquifer sands down to the marl. On the north is the drainage of Mathes Pond, which discharges to the Savannah River at Hancock Landing. The marl is exposed at Mathes Pond, and in the channels downstream to the river (See Figures 7 and 8). South and west of the site is Beaverdam Creek and its major tributary, Daniels Branch. The marl is present in these channels just below alluvial channel deposits. Extending northward from these named streams are tributaries bordering the site; the marl is also present immediately below a veneer of channel deposits in these tributaries. The presence of the marl immediately below these channels was determined by explor-() atory holes and is illustrated in the geologic sections of Fig-ures 8 and 9. There is only a narrow remnant of continuity be-tween the water-table aquifer materials beneath the site and those offsite. That remnant is northwest of the plant between the head of the Mathes Pond drainage and the unnamed tributary to Daniels Branch west of the plant. Ground-water beneath the narrow remnant drains either into Mathes Iond or into the unnamed tributary of Daniels Branch. Thus, the water-table aquifer at VEGP is effectively isolated, both laterally and vertically, frora other aquifers.
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- 1. See Figwe 7 for locatice of section
- 2. (Wadities from Vogtte FSAR FH3se 211-45 Geois;*c Sectice S-B1 o seco rooo m2 SCALE ins FEE 7 PLANT VOGTLE SECTION A-A' MATHES POND TO BEAVERDAM CREEK Figure 9 L
(} II. The consequence of an Accidental spill In the very unlikely event that an accidental spill of ra-dioactive fluid occurred at Plant Vogtle and reached the water-table aquifer without interception, the spill would migrate within the water-table aquifer in accordance with the prevail-ing hydraulic gradient. Because of the mari, spill migration of any significance would be lateral, and the spill would move in the direction of decreasing hydraulic head. Accordingly, a spill would flow north and northwestward toward, and after con-siderable travel time discharge into, Mathes Pond and stream, as further discussed below.
A. The Effectiveness of the Marl as a Barrier to Migration of Contaminants The Blue Bluff marl is a densely-consolidated, fine-grained calcareous clay with subordinate lenses of dense, well-indurated, well-cemented limestone. The reported values of the l
l permeability of unweathered marine clays, of which the mari is a type, range from 10~7 to 10-10 cm/sec (0.1 to 0.001 >
ft/ year). In engineering practice, materials with such low permeability are qualitatively considered to be impermeabic.
l The Blue Bluff marl is approximately 70 feet thick.1/ It 1/ Under the power block, the thickness of the marl is less Bue to excavation. Due to this excavation, the marl is gener-ally 60 feet thick under the power block area, and its minimum thickness is 38 feet under the auxiliary building. -
l l
extends over an area well beyond the limits of the plant site
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and the interfluvial ridge on which the plant site is located.
The comprehensive exploration and testing that has been con #
ducted demonstrates that the marl is an extensive and persist-entunitthatsignificantihinhibitsthepercolationofground-water downward to the underlying Tertiary / Cretaceous aquifers.
In particular, the marl's integrity as a barrier to ground-
~
water movement has been demonstrated by (1) fieldandlaborato-[
ry permeability testing, (2) visual inspection of cored sam-ples, the marl surface exposed 'during site excavation, and marl outcrops along the Savannah River, and (3) comparison of water levels in observation wells open to the water-table aquifer with those observed in wells open to the confined aquifer,imme-f) x/
diately below the marl. ,
During site exploration, the permeability of the marl was measured in the field at 80 intervals of varying depth in 22 exploratory holes. Constant-head inflow methods were used. In 20 of the exploratory holes, inflatable packers were used to isolate a specified test interval. These tests followed the procedure set out in Designation E-18 of the U.S. Bureau of Reclamation Earth Manual. In two exploratory holes at the in-take structure, permeameter tests were conducted in accordance ,
with Designation E-19 of the U.S. Bureau of Reclamation Earth "
Manual. In nearly'all of the intervals tested, no measurable-water inflow occurred. In only three holes was any measurable
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F r'} water intake confirmed, two of which were in near-surface, weathered marl at the intake structure. (Water inflow was mea-sured in three other holes, but was due to leakage around the packers.)
During the summer of 1985, the permeability of the marl was again measured. In-situ permeability testing was conducted at 15 intervals in six new holes. These tests followed the procedure set out in Designation E-18 of the U.S. Bureau of Reclamation Earth Manual and were in general compliance with the U.S. Army Corps of Engineers, Rock Testing Handbook, Stan-dard 381 (1980). The entire thickness of the marl penetrated in the holes was tested in ten-foot intervals to ensure that all of the marl and interbedded limestone lenses were tested.
() In all of these in-situ tests, the water takes were zero. The test results confirmed the previous in-situ measurements.
In addition, during coring of the six new holes, ten typi-cal marl and limestone core samples were collected for labora-tory testing to provide an estimate of the range of permeabili-ty of various material types (marl and interbedded limestone lenses) within the marl. The laboratory permeability measure-ments ranged from 8.5 x 10-6 (low) to 5.0 x 10~9 cm/sec (effectively impermeable).
The continuity of this material (i.e., the lack of voids, open joints or fractures) has also been demonstrated. Since 1971, there have been over 10 thousand feet of marl penetrated ,
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(3 at VEGP by drilling, coring, standard penetration testing, and V
undisturbed sampling. At no time throughout this extensive testing Vvas tKere any uhaccountable fluid loss or abnormal tool i
advance in the marl. When coring, the most revealing evidence for the occurrence of voids or fractures in a loss of all or part of the drilling fluid and/or a sudden or rapid advance of the core barre 1.n Neither of these conditions occurred during the site exploration. None of the borings encountered signifi-p cantly fractured zones; nor was there' evidence of leaching (re-moval of calcareous material.)
Visual inspections and detailed logging and photographing of the many extracted samples of marl have likewise produced no t
indications of voids or extensive fracture zones. Over 500
() feet of the marl penetrated has been collected either by coring or sampling and closely inspected ands described. Very few joints or fractures were observed and those identified were consistently found to be tight;'and without void space. Marl beneath the plant sita, exposed during excavation for the foun-dation, was directly examined and carefully logged by qualified geologists. This included inspection >and logging of more than 900,000 square feet of the upper surface of the marl at the base of the power block excavation, more than 20,000 square feet of detailed mapping and photographing of vertical face in the auxiliary building excavation, and more than 20,000 square b
feet of inspection and logging of the vertical face in the .
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4
(} radwaste solidification building caisson excavations. Addi-tionally, marl outcrops along the Savannah River in the vicini-ty of VEGP have also been examined, mapped and photographed.
These extensive and detailed mapping investigations of the marl formation at VEGP have produced an abundance of data indicating the absence of voids, solution cavities, or systematic or ex-tensive fractures or joint sets in the marl.
Finally, the large and consistent hydraulic head dif-farential between the water-table aquifer and the confined aquifers immediately below the marl confirms that the marl is a barrier to significant ground-water movement. The hydraulic head (energy potential) of ground-water in an aquifer is com-monly expressed as feet (elevation) above sea level, and is de-()
tm termined from measuring the elevation of water in an observa-tion well. In the vicinity of the plant, the hydraulic head in the water-table aquifer is 45 to 55 feet greater than the hy-draulic head in the aquifer immediately below the marl. This difference in hydraulic head can be seen by comparing the ground-water (equipotential) contours shown on Figures 10 and
- 11. The contours are based on water levels measured in obser-vation wells in December, 1984. Similar conditions were ob-served prior to plant construction, as indicated by the con-tours of water levels measured in wells in October and November 1971 and shown in Figures 2.4.12-6 and 2.4.12-7 in the FSAR.
To bring about such a marked difference in hydraulic head, the O
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(} barrier must.be extensive and without significant through-going openings (such as fractures or solution cavities).
A nest of observation wells constructed at the site of ex-pioratory hole 42 provided a direct measure of this hydraulic head differential between the overlying water-table aquifer and the confined aquifer sands beneath the marl. The observation wells were constructed in 1971 and included two, 42B and 42C, I
open to the marl itself, and one each, 42A and 42D, that were open to the confined and water-table aquifers, respectively.
At their location, the marl is 65 feet thick. The wells were monitored for four years until construction of the plant re-quired their closure, at which time they were sealed.
Hydrographs of the measured levels are shown in Figure 12.
() The differences in water levels (head) between the obser-vation wells is generally proportionate to the thickness of marl between the wells. The zones monitored by each observa-tion well are illustrated on Figure 13. For example, the dif-forence in water levels of the two wells open to the two aquifers (42D and 42A) is about 55 feet, (the head in the water-table aquifer is higher) and the thickness of marl be-tween them is 65 feet. In comparison, well 42B is open to an interval of the marl that is near the bottom of the marl. The water levels measured in well 42B are from 15 to 20 feet dif-forent (higher) than those measured in well 42A, which is open to the underlying confined aquifer, and the thickness of marl -
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Figure 13
q between them is about 10 feet. Water levels measured in well
}
42C follows this general relationship. It is open to an inter-val of the marl that is within 3 feet of the top of the marl.
The water levels measured in 42C are from 50 to 52 feet higher than those measured in 42A, and the thickness of marl between them is about 60 feet.
Two clusters of piezometers (A and B) were installed in the marl in June and July 1985. The clusters are located at opposite corners of the power block, as shown on Figure 17.
The piezometers provide a direct measurement of hydraulic head over the full depth of the marl. The differences in hydraulic head between the piezometers within a cluster show a progres-sive decline in head with depth as was observed in the 42 se-() ries. See Figure 14.
Owing to the extent and very low permeability of the marl, the impact of an accidental spill on the Tertiary and Cretaceous aquifers will be negligible. A calculation of the possible rate of flow across the marl demonstrates this conclu-sion.
The rate of flow is determined by the hydraulic gradient across the marl, and by the perneability and porosity of the materials. The relationship between these parameters in de-termining ground-water seepage velocity is expressed as Darcy's Law:
O -
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- l l l l l l l l l CLUSTER "A" CLUSTER B' 42 SERIES
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o i Confined equif er g g l l l 42A l l 5 60 l j l
, , 60 100 12 0 14 0 16 0 10 0 12 0 14 0 16 0 10 0 12 0 14 0 16 0 HYDRAULIC HEAD - E L EVATION, FE ET ( M S L)
NOTES:
, I. Measurements in 900 thru 905-Nov.1985
- 2. Measurements in 42 Series - April 1972
- 3. Levels for noter table end confined aquif ers of clusters A ond B based on measurements Nov.1985 (i e ; Figure 16) PIEZOMETER PROFILES BLUE BLUFF MARL Figure 14
v =
where, v = seepage velocity (L/T),
K = coefficient of hydraulic conductivity (permeability) (L/T),
i = hydraulic gradient (ratio) n, = effective porosity (ratio)
The gradient is determined by the hydraulic head dissipat-ed (the difference in piezometric levels of the water table and the Tertiary aquifers) over the travel path (the thickness of the marl). The difference in head beneath the power block can be determined .from a comparison of piezometric surfaces of the two aquifers measured in December 1984. These indicate a dif-ference of about 50 to 55 feet. This is similar to the dif-() forence observed in a comparison of levels measured prior to construction November 1971. The minimum thickness of the marl beneath the power block is 38 feet. See note 1 supra. The maximum hydraulic gradient, then, is 55 feet of head over a distance of 38 feet, or 1.447.
The vertical permeability of the marl is anisotropic, as is evidenced by the differences in head decline observed be-tween the piezometers of well clusters A and B and well series
- 42. The downward migration of ground water across the marl, however minute in quantity, will dissipate more head traversing the layers of lowest permeability than in traversing those lay-era of relatively higher permeability. .
4
- 1
- l
(} The marl is composed of a series of beds, and a material comprised of such layers, each of different permeabilities, is described as having layered heterogeneity. R. A. Freeze and J. A. Cherry, Groundsater, p. 30 (Prentice-Hall, 1979). The average or effective permeability across such a material (ver-tical flow) hac been found to be equal to the-harmonic mean of the layer permeabilities. H. Bouwer, Groundwater Hydrology, pp. 56-60 (McGraw-Hill, 1978). Assuming the ten laboratory tests are a representative sample of the layers present in the marl (each sample represents an equal proportion of the total marl thickness), the harmonic mean permeability would be 0.045
-8 ft/yr (4.3 x 10 cm/sec). Adopting an average vertical permeability of 0.1 ft/yr is therefore reasonably conservative.
(")
( j Total porosity of the marl has been calculated for 18 sam-ples, and the average value of those samples is 47.5 percent.
Recent studies at the University of Waterloo show that for clays the effective porosity (the porosity affecting the rate of ground-water movement) is essentially equal to total porosity.
Applying the values above for the three controlling parameters -- hydraulic gradient (1.447), average permeability (0.1 ft/yr), and effective porosity (47.5%) -- the average ver-tical ground-water velocity in the marl is calculated to be 0.31 ft/yr, and the time required to traverse 38 feet of marl would be 123 years. Taking into account retardation (discussed
below), this travel time is sufficient to reduce all ra-
{}
dionuclides in a worst case spill below the maximum permissible concentrations set forth in 10 C.F.R. Part 20, Appendix B, Table II, Column 2 (which applies to routine, continuous re-leases).
B. Lateral Migration and the Hydraulic Isolation of the VEGP Site Because the marl prevents significant vertical movement of contaminants across it, migration of contaminants from an acci-dental spill at VEGP would be predominantly lateral in the cirection of decreasing head in the water-table aquifer. The water-table has been monitored by measurements of levels in wells at the VEGP site since 1971. With these measurements,
() the direction of ground-water flow can be determined.
The water levels that were measured during site investiga-tion indicated that the direction of ground-water flow beneath the power block area is northward to Mathes Pond. Subsequent excavation and dewatering profoundly but temporarily affected the water table level.2/ The dewatering continued until 1983.
Although water levels were measured periodically during this period, the dewatering operations preclude their use to predict present or future flow direction and flow rate.
2/ See FSAR, Figure 2.4.12-7, which shows that during dowatering ground-water flow in the vicinity of the excavated area was radially inward towards the excavation. -
O .
A 8
(~') Water le'vels monitored in observation wells since cessa-v tion of dewatering indicate that the water table has recovered from the dewatering. Continued construction activity, however, still precludes complete stabilization of the water table, par-ticularly in the power-block area. Backfilling is still in progress around the structures and requires considerable appli-cation of water to the materials. This water percolates to the water table, where its flow is locally retarded by plant struc-tures. Hence, the power block is an area in which recharge and hence water levels are t'emporarily higher than will be the case af ter ccnstruction is complete. Grading and leveling of the site have also changed the drainage pattern and reduced topographic relief, and these changes affect the configuration n
(_) of the water table. Nevertheless, post-dewatering water levels indicate that the configuration of the water table remains a subdued replica of the 1971 levels and that similar flow pat-terns will exist. Compare Figure 10 with Figure 15.
The most recently determined water table contours are shown in Figure 16, and are representative of the temporary ground-water conditions described above. The southern ground-water divide may have temporarily shifted toward the power block area because of the localized recharge from placement of backfill, but it remains nenerally south of the power block.
The flow from points of potential spill are still north and northwestward to Mathes Pond. Analysis of past and present <
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water levels demonstrates that an accidental spill will not mi-grate to the south.
Ground-water moving northward from beneath the power block ~
area will eventually reach Mathes Pond. Concentrations o'f any j remnant radionuclides from a spill at the plant would be fur-
.ther reduced by dilution as the contaminated ground-water slowly discharged into Mathes Pond (which is completely on-site) and, subsequently, to the stream. Ground-water north of Mathes Pond and stream would not be affected. The Mathes drainage has cut down to the marl, as have other streams bor-dering the interfluvial ridge on which VEGP is located, inter-rupting continuity between water-table aquifers. Ground-water in the water-table aquifers on both sides of the bordering pond
() and streams discharges into the pond and streams (i.e., ground-water flows into and not across the pond and streams).3/
3/ Because the water-table aquifer beneath the VEGP site is hydraulically isolated (see discussion on pages 9-11), an acci-dental spill flowing in any direction could not impair domestic or other wells boycnd the streams around the interfluvial ridge. For the same reason, a spill could not migrate to an area where the marl is not present or less permeable (potential avenues to reach the lower, confined aquifers). The only wells that could be affected by an accidental spill are those on the interfluvial ridge and drawing from the water-table aquifer.
There is only one such well. This well is located approxi-mately 1.7 miles south of the plant, and an accidental spill would not move in that direction. 4 O .
h
/~ C. Spill Analyses and Travel Time Estimates b'
Several analyses have been previously made to assess the impact of a postulated spill. Applicants have analyzed the im-pact of the rupture of the Recycle Holdup Tank (RHT) -- the tank that potentially has the highest specific isotopic activi-ty (highest concentration of radioisotopes). FSAR 55 2.4.13 and 15.7.3. The NRC Staff references this analysis in the FES as representing a worst case release for potential offsite im-pact of design basis events. FES-OL, 5 5.3.2.4. The NRC Staff also ~ performed a similar analysis for the rupture of the Waste Evaporator Concentrates Holdup Tank (WECHT), which is a smaller tank than the RHT but which has a specific isotopic activity comparable to that of the RHT. SER, 5 2.4.13. In addition, l ( both Applicants and the NRC Staff have analyzed a core-melt liquid-pathway accident scenario. ER-OL, 5 7A; FES-OL, 5 5.9.4.5(4). Each of the analyses is based on a one-dimen-sional flow model. The analyses differ in the hydraulic gradi-ent, permeability, and effective porosity assumed along the ground-water flow path. The different analyses consider either best-estimate values of flow path parameters or worst-case val-ues of flow path parameters.
All of the analyses impose extreme assumptions involving the manner in which a radioactive release could occur. With respect to an accidental spill, the RHT is the most critical tank and a spill analysis involving the RHT is presented below O _ =
{} as the worst case. The spill analysis postulates not only tank failure, but also the failure of the auxiliary building in which the tank is located. The spill analysis described below assumes that these failures are total and that the release to the ground-water occurs instantly, with no initial dilution of the spilled waste; the spill is transferred to the ground-water as a slug in negligible time (no decay). While this scenario is probably physically impossible, it is presented to bound any lesser scenario.
D. Flow Path to Mathes Pond Following the postulated events above, the spilled waste would migrate along a flow path in the ground-water northward to Mathes Pond. The flow path considered, between the auxilia-ry building and the spring on the southeast side of Mathes Pond, is a distance of over 3400 feet. The first 550 feet of this flow path is through the backfill material.
The time required for ground-water to migrate through the backfill is determined by the permeability and porosity of the materials, and the hydraulic gradient. The backfill is sand and silty sand compacted to an average of 97% of its maximum density. FSAR, l 2.5.4.5.2. The permeability assigned to the backfill is the maximum value measured in situ, 1220 ft/yr.
Total porosity measurements of backfill samples that meet the compaction criterion range from 31.6 to 37.6%, and average
I' i
O_ total porosity is 34%. For sand and silty sand, the total and
! U effective porosity are essentially the same. The hydraulic gradient in the backfill along the Mathes Pond flow pat *t is 3.5 l X 10-3 , but again for conservatism is rounded off to 4.0 X
-3 f 10 ,
I i Applying Darcy's Law to the parameter values above, the i
j calculated ground-water velocity in the backfill is 14.4 ft/yr.
l With a flow path length of 550 feet, the ground-water travel I
time in the backfill is 38.2 years.
The concentrations of spilled radionuclides that are ulti-mately transmitted through a ground-water system to a discharge point (i.e. transmitted through the water-table aquifer to Mathes Pond and stream, and, subsequently, discharged off-site O to the Savannah aiver> is determined bv the fo11owine factors-i The source (tank) radionuclide inven-l tory released to the ground-water l The attenuation which takes place dur-l ing transport through the system, I caused principally by dispersion, di-l lution, adsorption, and radioactive decay.
l Of the several radionuclides present in the liquid waste holding tanks, three are critical because of relatively long half-lives. These include tritium (H-3), strontium-90 (Sr-90),
and cesium-137 (Cs-137). Because they are chemically active and susceptible to adsorption, migration of Sr-90 and Cs-137 in
! the ground-water will be retarded; they will move at a markedly l .
f 1 i
l l
l
() slower rate than the water.
cantly, and tends to travel at the same rate as the ground-Tritium is nut adsorbed signifi-water i
The degree of retardation is governed by the various phys-
- ical properties such as bulk density, aquifer porosity, and ra-dionuclide equilibrium distribution coefficients. The rela-tionship between ground-water velocity (or ground-water '
transport time), radionuclide adsorption, and the radionuclide fraction resulting from decay that is ultimately transmitted to Mathes Pond is given by the following expression:
In (T.F.) = -0.693(t)a 1/2 where, T.F. = transmitted fraction (ratio) t = estimate of ground-water O- travel time (T),
a = adsorption retention factor, ,
T radionuclide half-life (T).
l/2=
The adsorption retention factor (also called retardation factor) is equal to (1 + p/n K d) 3 where, p = dry (bulk) density of the aquifer (M/L ),
n = porosity of the aquifer (ratio),
and K d
= equilibrium distribution coefficient which is defined as the mass of radio-nuclide adsorbed per gram of soil divided by the mass of radionuclide dissolved per milliliter of ground-water.
I l
0 '
eL_________.
(
The density of backfill at the required compaction was de-termined for twelve samples. The values ranged from 1.62 to 1.79 g/cm3 (101.1 to 111.8 lb/ft3 ). A value of 1.6 g/
3 cm is therefore conservative. The ratio of this value to 3
the average total porosity (0.34), i.e. p/n, is 4.71 g/cm ,
The equilibrium distribution coefficients (Kd ) f#
Sr-90 and Cs-137 of four samples of backfill were measured by the batch method. The values for Sr-90 ranged from 40.8 to 94.7 cm3 /g, and the values for Cs-137 ranged from 385 to 3
2134 cm /g. These values are all more than five times greater than the conservative estimates of average values given by Isherwood (NUREG/CR-0912, January 1981). Again to be con-servative, the lower estimated average values of Isherwood, 10 ;
O and 100 cm'< for Sr-e0 and Cs-137 respective 11. were cho-sen. ,
Using the values of the parameters above, the calculated reduction in concentration in the backfill along a northward f flow path are summarized as follows:
Nuclides Kd(cm3/qm) a T 1/2 (vr) TF __ ;
H-3 0 1 12.2 1.15 x 10~1 {
-20 Sr-90 10 48,1 28 1.8 x 10
~194 Cs-137 100 472 30 1.5 x 10 The concentration of radioisotopes in contaminated ground-water after travel through the backfill is equal to the trans-mitted fraction times the initial concentration. The following O t r
_--_________O
I T')
\~J summarizes the initial concentrations assumed to be present in the postulated worst-case spill, the reduced concentration after travel through the backfill due to radioactive decay and adsorption, snd the maximum permissible concentration (MPC) for normal releases from 10 C.F.R. Part 20, Appendix B (Table II, Column 2).
Postulated RHT Rupture Concen. after Initial Travel through Concentration Backfill MPC Nuclides (vCi/cm3) (vCi /cm3 ) (pCi/cm3)
~1 H-3 1.0 1.15 x 10 3.0 x 10-3
-5 -25 Sr-90 1.0 x 10 1.8 x 10 3.0 x 10~7
-5 Cs-137 1.9 x 10-2 2.9 x 10-196 2.0 x 10 It can be seen that under this very simplified and conser-(O~) vative scenario, the concentrations of both Sr-90 and Cs-137 in l ground-water would meet 10 C.F.R. Part 20 limits after travel 1
l through the backfill. Parameters that would reduce the concen-tration further, such as dispersion and dilution, need not be considered. Because tritium is not retarded and migrates with the ground-water, the tritium concentration in ground-water travelling through the backfill would exceed the MPC limits (still ignoring any dilution or dispersion of the spill).
Ground-water exiting the backfill would continue its mi-gration through the Barnwell Group to Mathes Pond. Several high permeability measurements in the Utley Limestone raised i
r~s. the possibility that the Utley might act as a conduit permit-tg ting the ground-water exiting the backfill to flow very rapidly to Mathes pond. However, even if this hypothesis were correct, contaminated ground-water subsequently reaching Mathes Pond would be further diluted in the pond and in the stream running from the pond to the Savannah River, reducing the concentration below 10 C.F.R. Part 20 limits before it flows off-site.
Flow into Mathes Pond is continuous, and the pond level is held constant by a spillway. The ratio of Mathes Pond stream flow to the rate at which the postulated spill would discharge l from the backfill (and into Mathes Pond) is the potential for l dilution of the spill within the stream. The rate of flow in the stream draining Mathes Pond has been measured at 250 gpm.
() The discharge rate of the spill in the backfill is determined by the velocity of ground-water flow (14.4 ft/yr) and the as-sumed volume and dimensions of the spill slug. The critical source of radionuclides in an accidental spill, the RHT, has a l
total capacity of 112,000 gallons. Assuming the tank is filled to 80 percent of its total capacity, its entire content is re-leased, and the spill is instantly transferred to the backfill, the rate of discharge from the backfill would be from 0.04 to l
0.07 gpm, depending on the dimensions of the spill.
The volume of flow in Mathes Pond stream would reduce the concentration of the largest calculated discharge rate (0.07 gpm) by a factor of more than 3500. The concentration of l
s- ) I l
l
7 . .
()
/~'
tritium discharging from the backfill (0.115 pCi/cm )
-5 3 3
would be reduced to 3.2 x 10 Ci/cm in the Mathes Pond stream with complete mixing. Because contaminated ground-water would first discharge to the Pond, and would then flow into and down the stream below the Pond before discharging offsite, there would be adequate mixing. However, assuming only a 50 percent effective mixing, the concentration of tritium in Mathes Pond and stream would be 6.4 x 10" 3
uCi/cm , which is below permi'ssible concentration levels for continuous routine releases.
E. Alternative Pathway to the Northeast ,
Because changes in the water-table due to construction ,
f}
N currently preclude a precise definition of its future configu-ration, a flow path to the northeast cannot at this time be un-equivoca11y eliminated as a possibility. A northeast flow path was therefore postulated and analyzed for this hearing. For this pathway, the shortest distance north to the edge of the backfill is assumed, and a straight line path is struck north-east to the Savannah River.
Within the power block area, the flow path is essentially the same as that to Mathes Pond. The hydraulic gradient is
-3 4 x 10 and the flow path through the backfill is 550, feet. Thus, the transmitted fractions along this flow path and a concentrations after travel through the backfill are the same ,
- - - . 1
as those shown on page 29 above. Only the concentration of
}
Travel time in backfill along the northeast pathway re-duces the original concentration of tritium in the postulated 3
spill to 0.115 pCi/cm . Assuming rapid travel through the Utley limestone with no dispersion, this would be the con-centration at the discharge point of this ground-water flow path.
The discharge point is on the bluff of the Savannah River, at the head of a small tributary to the river. After discharg-ing to that drainage, concentration of the spill would be di-luted by the stream flow, in a similar manner to that consid-ered in the Mathes Pond drainage. Flow in the drainage is n
(_) sustained by ground water discharging from the water table aquifer exposed along the bluff. The underlying marl is also exposed in the bluff, and the Utley limestone extends over the full length of the small drainage. Thus, a measure of the potential dilution is indicated by the total length of aquifer exposed in the drainage, in relation to the width of the spill slug. That is, the spill slug is a fraction of the total length of aquifer discharging to the drainage. The length of aquifer discharging to the drainage is at least 2800 feet. The maximum calcul4ted width of the spill slug in the ground-water is 40 feet. Assuming tha initially spilled slug moves to the discharge point essentially intact (no dispersion or dilution r~S
/
' I
) along the flow path),~the ratio of s' lug width to aquifer length
(~J is 0.014. Applying this>retio as a dilution factor, the reduced peak concentration of tritium in the drainage discharg-ing to the Savannah River'would be 1.6 x 10 -3 pCi/.
cm 3, ,
,y ... .
Thus, the concentration of tritium would be reduced to about half the MFC value along this arbitrary flow line, under the very conservative assumptions applied in the analysis. Di-lution to a negligible concentration would occur almost immedi-ately upon discharge to the Savannah River.
III. Ground-water Monitoring In July 1985, a program of frequent measurement of water-() table wells was implemented in response to the NRC Staff's re-quest. The' principal purpose of this program is to provide more detailed information to supporisthe VEGP design basis t
water level (see sbr 5 2.4.1.2.4). The wells and piezometers monitored by this program are fisted on Tables 1 and 2, and their locations are shosn on Figure 17.
The design basis watey level is the maximum expected ground-water level in the vicinity of the power block struc-tures. The elevation Sf the water table tends to fluctuate g
from year to year and frem season to season in response to variations in the rate of recharge. A conservative maximum level is determined for use in various, design calculation such .
e
TABLE 1 -
OBSERVATION WELLS Ground Depth Depth of Surface Top of Monitored Well Installed coordinates Elev.(1) Marl (2) Interval (2)
Egi_ (Yr.) N E (ft.) (ft.) (ft.)
Water-table seuifer 129 1971 8856 9576 215.9 77 35 - 100 142 1971 8283 8262 231.2 92 52 - 101 179 1971 9059 7779 274.8 130 90 - 131 800 1979 8850 11011 213.7 83 59 - 94 801 1979 7656 10733 212.8 82 49 - 87.5 802A' 1985 7196 10194 216.9 87.5 72 - 90 803A 1979 7085 8898 218.3 82 42 - 87 804 1979 6597 8227 224.1 87 49 - 102 805A 1979 6672 10403 232.7 124 69.5-127 8068 1980 8821 9726 214.8 77 23 - 70 807A 1980 9047 9835 213.6 77 36 - 80 808 1985 9625 9300 207.0 66.3 45.5- 68 809 1985 8320 7860 222.8 89 69.4- 90 LT-1B 1985 8388 9304 213.2 83.3 65.2- 84.7 O LT-7A LT-12 1985 1985 8151 7775 9317 9600 215.9 209.0 87 79 65 - 87 58.2- 78.6 LT-13 1985 8135 10110 219.0 89 68.1- 89.1 Tertiary equifer 27 1971 8622 13931 210.0 148 146 - 190 29 1971 9975 12392 193.0 126 124 - 210 34 1971 12180 10846 86.0 N.A. 47 - 115 850A 1984 11723 10494 225.9 135 147 - 200 851A 1984 8868 7066 262.7 195 235.7-300 852 1984 5993 13380 200.7 153.5 159.1-220 853 1984 11020 9204 227.6 145 176.3-217 854 1984 9899 7917 236.8 153 174 - 220 855 1984 7159 13951 218.0 173 192 - 240 856 1984 4927 12558 186.7 155 156 - 197 cretaceous aquifer TW-1 1972 7738 9984 218.5 140 506 - 850 NU-2 1977 9500 9135 214.5 150 450 - 820 WOTES:
(1) Determined at time of drL11 Lng.
(2) Below ground surface at time of drL111n8
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^
TABLE 2 -
PIEZONETERS IN BLUE BLUFF MARL Ground Depth of Surface Depth of Monitored Well Installed Coordinates Elev.(1) Marl (2) Int'erval(2)
E2 _ (Yr.) W E (ft.) (ft.) (ft.)
I 900 1985 7538 10119.5 216.3 92.6-148 133.8-140.7 j 901 1985 7538 10104.5 215.58 91.6-148 122.0-128.0 l 902 1985 7543.5 10110.5 215.97 91.0-148 101.5-108.0 l 903 1985 8480 8900 215.75 78.0-148 127.0-133.0 9048 1985 8464 8885 215.75 78.8-148 90.0- 96.7 905 1985 8450 8900 215.75 77.3-148 109.8-116.0 NOTES:
(1) Determined at time of drilling.
(2) Below ground surface at time of drilling. Bottom depth of marl is interpolated from figure 2.5.1-31, FSAR.
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(} as subsurface hydrostatic loading (the stresses that ground-water exerts on subsurface structures). The design basis water level for the power block area is 165' feet mal, whereas expect-ed levels in that area range from 157 to 161 ft. mal.
The NR'C Staff's concern was that water levels had not been monitored for a sufficient length of time to verify the fluctu-ations in level that might be expected,4/ and designated this concern a confirmatory item. See SER, Table 1.5 and 55 2.4.12.6
- 2.4.12.7. This item has little bearing on the speed or direction of ground-water flow over the power block area, since fluctuations are quite uniform over this area and do not appreciably alter the hydraulic gradients.
The first six months of monitoring was completed in
() December, 1985, and the results presented. The highest recorded water-level in the power block area during this period was 162 feet mal at well LT-12. Well LT-12 is located in a small enclosed area between the auxiliary building and adjacent structures that, until recently, had been a depression (only partially backfilled). Drainage from the auxiliary building and other structures was directed to this depression. Until late october, when backfilling was continued, there was no 4/ The Licensing Board referred to this concern at pages 12-13 of its November 12, 1985 Memorandum and Order (Ruling on Motion for Summary Disposition of Contention 7 re: Groundwater Contamination). ,
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() attempt to drain the depression. The resulting ponded water was a source of concentrated recharge and has created a tempo-rary mounding of the water table aquifer. Yet despite this ab-normal recharge, the water level remained well below the 165 foot design basis water level.
The NRC Staff also requested that as part of this renewed monitoring program two well clusters of piezometers be in-stalled at opposite corners of the power block to provide addi-tional detail on the pore pressure distribution within the marl. See SER $$ 2.4.12.2.2 and 2.4.12.2.7.5/ As a result, well clusters A and B were installed. The data from these wells, discussed above at page 18, were consistent with that previously obtained from well series 42.
(
(-)> Finally, the NRC Staff asked that the Cretaceous
[Tuscaloosa] aquifer be monitored to determine the long-term effect of withdrawing water from this aquifer. SER
$ 2.4.12.7.p/ During operation, VEGP will draw ground-water from the Cretaceous aquifer at a maximum rate of approximately 8705 L/ min (2300 gpm) and at an average rate of approximately 3180 L/ min (840 gpm). Beneath VEGP, the Cretaceous aquifer is approximately 700 feet thick. Pumping tests previously 5/ The Licensing Board referred to this confirmatory item at page 13 of its November 12, 1985 Memorandum and Order.
s/ The Board referred to this item at page 13 of its November 12, 1985 Memorandum and Order.
' 's conducted at VEGP indicate transmissivities in the range of 110,000 to 230,000 gpd/ft and storage coefficients ranging from
-5 -4 2.1 x 10 to 6.6 x 10 for the aquifer. FSAR at Ter4.ar y om d G d cep s 2.4.12-10. Estimated water in storage in the Tuscalecea 1
aquifer,is approximately 21 billion acre-ft, and sustainable koM QAh%
yield is estimated to be 5 billion gpd (19 billion L/ day). Id.
A.
at 2.4.12-3. Because of the large available capacity, the small use rate during operation of VEGP should have no signifi-cant effect on the aquifer. There should be no appreciable lowering of piezometric levels beyond 1000 feet from the pumping site, and no effect on any off-site water user. The monitoring of the Cretaceous aquifer during plant operation will provide confirmation of these determinations.
('h
- j IV. Conclusion In our opinion, the geology and hydrology at VEGP have been adequately explored. There is sufficient data on marl thickness, permeability, and continuity for a confident deter-mination that the marl is an effective barrier against contami-nation of the confined aquifers. Based on this exploration and the conservative analyses of ground-water flow, it is our opin-ion that even if a worst-case spill of radioactive liquid were to occur at Plant Vogtle and reach the water table, such spill would not pose undue risk to the public health and safety.
I \
V' -
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- EXHIBIT A
() !
PROFESSIONAL QUALIFICATIONS Thomas W. Crosby My name is Thomas W. Crosby. I graduated from Oregon State University with a Bachelor of Science degree in Geology in June 1973. For the past twelve years I have been employed by Bechtel as an engineering geologist. My responsibilities have been the field and office studies for the siting, design, and construction of major engineering projects, including nuclear power plants, hazardous waste facilities, dams, and tunnels.
I have been responsible for field exploration, data interpretation, report preparation, and regulatory review on nuclear power sites in Georgia, Pennsylvania, Washington, California, and Taiwan. My ground water experience includes supervision of monitoring well construction and testing at hazardous waste sites in New York, fennessee, and Arizona. I ,
have also supervised the installation and testing of large capacity production wells in Senegal, West Africa and Washington State.
I am a Registered Geologist and a Certified Engineering Geologist in the State of California, and a Licensed Geologist in the State of Oregon.
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EXHIBIT B 4
PROFESSIONAL QUALIFICATIONS Clif ford R. Farrell My name is Clifford R. Farrell. I have received a Bachelor of Science degree in geology from the University of Southern California in 1954, and have completed some graduate studies.
I have 31 years of experience in field and of fice studies in hydrogeology and engineering geology including investigations for the development of regional and local water supplies; design and construction of water wells; hydrogeologic studies concerned with the safety analysis of nuclear power plants and geologic studies for the planning and design of dams, tunnels, and power plants.
I worked for the California Department of Water Resources for 11 years.
Initially I worked on alternative route studies for the California Aqueduct, becoming head of a unit responsible for geologic studies of tunnels, dams, and power plants. In 1961, I became head of a ground water and hydrology special studies unit that conducted basin-wide water supply studies.
From 1967 to 1969, before joining Bechtel, I completed an assignment with the U.N. Food and Agricultural Organization for the Huaura River Project in Peru. I was responsible for the proposed ground water development O plans and for geologic investigations of dam sites.
For the past 16 years I have been responsible for the technical direction of ground water investigations conducted by the 8echtel Engineering Geology Group. I have directed geologic and ground water studies concerned with the safety analysis of eleven nuclear power plant sites and with the design and characterization of hazardous, non-hazardous, and low-level weste repositories. Characterization studies have included contaminant plume identification and radionuclide migration studies.
Other studies have included: design and construction of ground water supplies for mining, industrial, and agricultural developments in many countries, including Canada, Saudi Arabia Australia, Indonesia, Algeria,.
and Senegal; seepage and pollution analysis of storage ponds at several U.S. power plant sites; and environmental impact studies. I have designed dewatering and ground water control systems for power plant foundations, open-pit mining, and other projects.
i 1 an a registered geologist and a certified engineering geologist in the j State of California.
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EXHIBIT C C
PROFESSIONAL QUALIFICATIONS Lewis R. West My name is Lewis R. West. I have a B.S. degree in Geology from the University of Southern Mississippi and some graduate studies in geology at University of Nevada, Las Vegas.
I was employed by the Ground Water Branch of the U.S. Geological Survey for seven years. During this period I worked in Alabama for four years and at the U.S.A.E.C. Nevada Test Site for three years.
From 1964 to 1973, I was employed by Environmental Research Corporation in Las Vegas, Nevada as field geologist and field office manager. I was responsible for the liaison between the home office in Virginia and the AEC's Nevada Operations Office. My duties involved investigations of tunnels and drill holes for input to determine containment and ground motion offacts in relation to atomic bomb testing.
For the past 12-1/2 years, I have been employed by Bechtel as a Hydrogeologist. My responsibilities include all aspects of ground water occurrence and interaction in respect to foundation, dam sites, retention ponds and engineering geology design criteria as well as development of industrial ground water supply systems.
O 1 am a Registered Geologist in the State of California, k
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26113.0
~'RT 2b4 n
1 MR. CHURCHILL: The witnesses are now available 2 for cross-examination. In accordance with our discussion at 3 the prehearing conference, I believe the Intervenors are to 4 proceed first, followed by the Staff.
5 MR. TEPER: Mr. Chairman, at this time I have a 6 couple of questions and then GANE's expert witness will 7 possibly have some questions. I would like to know if ncw 0 would be the propar time, after my initial cross 9 investigation or if there is an appropriate time after my 10 initial cross?
11 JUDGE MARGULIES: Well, as a party you have the
(')
'J 12 right to cross-exanine the witnesses.
13 MR. TEPER: My queJtion -- Dy understanding is, is 11 there going to be a panel -- this finishes their direct 15 testimony?
16 JUDGE MARGULIES: That is correct. Their 17 testimony is the same as if it were tectified to orally.
18 MR. TEPER: Okay. GANE will now proceed.
19 I would like to start off and then William Lawless 20 will continue.
21 MR. CHURCHILL: Excuse me, your Honor, I have an 22 objection to this proceeding. We don't object to Mr. Lawless 23 cross-examining our witnes.scs. We do object to being 24 cross-examined by two different people. Part of the reasons 25 for consolidating is to avoid just this, and now that we have ACE. FEDERAL REPORTERS, INC.
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26113.0
~'RT 2au I concolidated it seems we are going to be cross-examined on --
? from two different directions by two ditterent people. I 3 think it's normal, customary procedure to limit 4 cross-examination to one representative from a party.
5 MR. TEPER: Mr. Chairman, in recponse to that I 6 would like to say that the scope of my questioning will be 7 less than five minutes and that we have brought in an expert 8 witness to do this cross-exanination. I don't believe that 9 having two questioners will extend or exceed the scope of 10 this investigation, and that in order to get all the 11 information into the record, as possible -- and I know you
('s 12 are interested in getting as much information as possible L]
13 into the record -- that I don't believe it violates any HRC 14 regulation or, for that matter, federal reculation when it 15 comes to the Federal Rules of Civil Procedure.
16 MR. CHURCHILL: Your Honor, I don't want to 17 belabor this. I do know at our prehearing conference nothing 18 was said about having nomebody else cross-examine. In any 19 event -- because we are not objecting to Mr. Lawless asking 20 questions, per se; we are not conceding that he is an expert; 21 but also at the prehearing conference the parties were polled 22 as to the amount of time they thought cross would take. I l
23 believe the parties said that cross-exanination might have 24 been an hour or two at most, and I'm wondering if the 7_
( 'l 25 injection of Mr. Lawicas, without warning at this time, is ACE. FEDERAL REPORTERS, INC.
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1 going to dramatically change that estimate.
2 If it's not, and if Mr. Teper indeed only has 3 about five minutes' worth of questioning, we may not object 4 to this procedure.
5 JUDGE MARGULIES: Do you wish to respond, 6 Mr. Teper?
7 MR. TEPER: Mr. Chairman, GANE does not plan to 8 dramatically alter that which was agreed to at the prehearino 9 conference.
10 As I mentioned, my queJtioning involves possibly 11 less than five minutes, probably just an opening statement.
12 Itaving been involved in investigating the plant for over six
!7 w) v 13 years, and knowing the history cf the plant, I would like to 14 just question the Applicant's witnesJes on their historical 15 involvement with the plant, and that should take less than 16 five minutes and then I will go ahead and turn over the 17 planned cross investigation of the witnesses to Mr. Lawlens.
18 JUDGE MARGULIES: We will permit Intervonor's 19 proposal ac long as it doesn't become repetitious.
l 20 MR. TEPER: Thank you, Mr. Chairman.
21 CROSS-EXAMINATION 22 DY MR. TEPER:
23 Q I would like to ask the experts at what point was 24 their personal earliest involvement with the Plant Vogtic p
k/ 25 project. It doesn't matter in what order you go. I would ace. FEDERAL REPORTERS, INC.
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26113.0 RT tus g
1 just like to know what the earliest involv-n-nt was, with any 2 of the individuals?
3 A (Farrell) I began ny participi. tion of the Vogtle 4 site in late 1971.
5 A (West) I have been involved since spring of 1974.
6 A (Crosby) I have been involved since April of 7 1982.
8 A (Papadopuloc) As I mentioned earlier, I was 9 involved during the Millet Fault study investications in 10 1982. I dcn't recall exactly what season of the yeare.
11 JUDGE PARIS: Can I interrupt. Dr. Papadopulos,
. 12 could you repeat the name of that investigation? I have not N
13 -
caught it either time you said it?
14 MR. PAPADOPULOS: The postulated M-t-1-1-e-t, 15 l ML11et Fault study.
16 MR. TEPER: That's the unknown earthquake fault 17 contention, s'amewhere under the plant.
18 DY MR. TEPER:
19 Q I would like to addresa this to the two gentlemen 20 that began their involvenent with Vogtle around 1971 and 21 '74. It's my underste9 ding, from a review of the documents 22 in the public document room, that Georgia Power init1011y 23 stareed excavation on the rite in the early '70s and at a r- 24 certain point, I believe it was in '74 or '75, the company
)
i 25 stopped construction.
ACE FEDERAL REPORTERS, INC.
26113.0 HT iJii s'
1 At this point there had b<ren some initial 2 excavation done, and these initial excavations filled with 3 water.
4 I would like to ask one or both of the gentlemen 5 if there was any noticeable damage from the fact that this 6 open pit was left to collect water, and if that has had any 7 structural or groundwater implications to the site?
8 MR. CHURCHILL: Your Honor, I would object to the 9 question of whether it has any structural implications. That 10 is clearly not a hearing within this proceeding and it's not 11 a subject of the direct testimony. We have no objection to em 12 the groundwater part of the gaestion.
V 13 MR. TEPER: Mr. Chairman, it ceems to me that 14 there are structural implications in the groundwater. It's 15 obvious on its f ace that any kind of structural damage that 16 might have occurred during the time that water sat in this 17 open hole, that it could possibly lead to a leaking of water, 18 either from the spent fuel from any of the cooling systems, 19 and that this could create a situation in which radioactive 20 waste or other chemical waste could seep into the 21 groundwater.
22 JUDGE MARGULIES: The matter of the potential 23 structural problem is beyond the scope of the contention.
24 The witnesses may answer the question in regard to the
! \
k> 25 groundwater ramifications.
ACE. FEDERAL REPORTERS, INC.
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6 26113.0
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1 14R. CHURCHILL: Do the witnesses need to hear the !
l l
l 2 question again? :
i 3 THE WITNESS: (Farrell) Yes. I would like to have l i f 4 the question repeated. ;
i 5 BY MR. TEPER: ;
6 Q The question is, did the initial excavation done !
j 7 14( Georgia Power in the early '70s, which was at one point !
8 delayed and subaequently filled with water, have any !
! i l 9 implications on the possible contamination of the i I 10 groundwater? l l
11 MR. CHURCHILL: Your Honor, that is an entirely l l 12 different question and clearly outside the scope of this I
13 'haaring. -
14 If you are talking.about contamination of
- 15 groundwater that might have occurred back then, there was no !
l 16 radioactivity back then. We are not ta1xing about that. We l -
17 are talking about, in general, what happens if there were to 18 be a spill in the groundwater after operation. I did not 19 hear that to be the question originally. [
1 20 MR. TEPER: Mr. Chairman, counsel for the i 21 Applicants are trying to obfuscate -- trying to confuse !
i
! 22 everybody. l l
- 23 Tne question is whether the ex
- avation that was ;
l ,
24 done at that time might have a possible effect on future i
, 1 25 contamination of the groundwater. It in obvious that's i i
1 l
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"' R T 266 I within the scope of this hearing. The fact that they dug --
2 MR. CHURCHILL: Note my objection to that 3 question.
4 MR. TEPER: The fact that they dug into the dirt 5 at quite some length and then left it open, I think --
6 JUDGE MARGULIES: You have no objection to that 7 question?
8 MR. CHUNCHILL: Not as I have heard it now for the 9 third tir.o.
10 JUDGE MARGULIES: The panel may respond.
11 THE WITNESS: (Farrell) I don't know of any 12 contamination that would have occurred because of the
(~]
1.1 excavation.
14 BY MR. TEPER:
'15 Q Would the other witness who started in '74 agree 16 to the fact that this initial excavation could not possibly 17 lead to any contamination of groundwater?
18 A (West) As you asked the question, the future, no.
19 Q So, in the future it would not lead to any 20 groundwa ter coritamination?
21 A The excavation in 1974 would not lead to any 22 contamination in the future.
23 MA. TEPER: Thsnk you. I will nos turn over the 24 questioning to Willian Lawless, t,,_ >
'wi 25 JUDGE MARGULIES: In that you haven't nade an ACE. FEDERAL REPO (TERS, INC.
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1 appearance in this case, Mr. Lawless, would you please 2 identify yourself for the record?
3 MR. LAWLESS: Yes. I'd be glad to. My name is 4 Bill Lawless; I'm an assistant professor of mathematics at 5 Paine College in Augusta, Georgia.
6 JUDGE MARGULIES: You may proceed.
7 CROSS-EXAMINATIO!I 8 BY MR. LAWLESS:
9 Q The first question I have Qs on the Crosby, 10 Farrell and West February 24th document, page 22. These 11 questions are just taken sequentially, they are not in any 12 arranged crder. But they will follow the document.
13 Figure 2 shows the Tus;aloosa to be very deep at 14 the Plant Vogtle site. There's been testimuny by PGP, and in 15 this documcat also, such as at figure 7 -- it seems to offer 16 a different perspective.
17 This figure 2 is a nice color drawing running from 10 Augusta to underneath Plant Vogtle.
19 Figure 2 seems to suggest that the Tuscaloosa 20 formation and the marl underlying Plant Vogtle is 21 significantly deep underneath Plant Vogtle. Is that correct?
22 A (Crosby) I don't know what you mean by 2S " s ion 17.icar.tly deep. "
24 Q Well, just the visual suagests that the marl is
,_ \
/ 25 pretty deep underneath Plant Vogtle. You can see where the Ace FEDERAL REPORTERS. INC.
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1 marl would be -- in the Liscon formation, tor instance, rises 2 to the surf ace at >'cBean Creek or stops oefore that, going 3 from underneath Plant Vogtle to the left. And, similarly 4 does the Tuscaloosa formation'itself. It rises dramatically i
? l G from a deep spot or depth underneath Plant Vogtle to the j 6 surface in the Augusta area and outcropping from Augusta down
- e j 7 to just west of McBean. Does that seem correct?
8 i A (Crosby) This is a regional geologic section which 9 does go from Augusta through Plant Vogt.le and does depict the l
l 10 regional geologic relationships of the units.
11 Q Okay. One of the things that -- it's not a big I r
12 concern but it is a concern, is that this seems to suggest 13 that the formation, the blue marl, i t, very deep by the t.ime 14 you get to Plant Vogtle, and in ciqtare 7 you show evidence 15 that the marl rises to the surface on the other side of Plant i 16 Vogtle, so were we to have a little definition or depth, f 17 three-dimensional definition to this section, of course it is l l 18 a section -- but if we had any definition to it the marl 19 would come to the surface behind the plant. Is that correct?
{
20 A Maybe I should clarify this for you. The section 21 which is shown on figure 2 is a regional geologic section, as [
i 22 I said, as the title of the figure shows. l 23 It goes tnrough the plant itJelf, as is indicated l 24 on the section that shows Plant Vogtle. !
O 25 Q Yes, I
l l
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1 A That's figure 6, shows another geologic sec tion 2 which again is through the unite, and it shows the depth and 3 the relationships of the blue marl to the plant itself.
4 Figure 7 is a three dime 1sional diagram whLch 5 gives you a feeling -- a better picture for the relationship 6 of how the Blue Bluff marl was exposed along the blutts of 7 the Savannah River.
8 Q The point is in section -- or in figure 2, the 9 section seems to suggest that the marl runs straicht to the 10 northeast at level, and then I wanted to point out what I 11 think is a small correction, that of course the marl is not r~N 12 level. It rises to the surface right northeast to the
'~
13 plant. Any comment on that?
14 MR. CilDRCilILL: Your Honor, excuse me. I have an 15 objection to that. I realize Dr. Lawless la not an attorney 16 and I don't nean to be obstreperous, but they should be 17 questions and not in the form of statements by the 18 questioner.
19 MR. LAWLE30: Yes. That's why I ended it by 20 asking him if he had any feedback on that. I am not an 21 attorney. I don't want to pass myself off as one. It has 22 been difficult eneugh working in this field of hydrogeology.
23 So I would just like ther response to the Jection.
24 Tile WITilE30 : (Crosby) I'm sorry. I missed your k'-
25 question.
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1 BY MR. LAWLESS:
2 Q You do aqree the mari does rise to tha surface on 3 the northeast of the plant; is that correct?
4 A (Crosby) That's a mischaracterization. The marl 5 is exposed in the bluff along the river where the river has 6 eroded it.
7 Q So the surface -- nonetheless, th narl does reach 0 the surface northeast of the plant? And there is not the 9 irance overburden from Plant Vogtle down to the mari on 10 section 2, northward, for an unextended distance?
11 A That's a lot of questions. Could you ask them one 12 at a time?
(~}
(_j '
13 2 Yes. The orange color, the material that you have 14 showing the overburden from the Plant Vogtle surface down to 15 the marl in figure 2, that surface disappears, then. I would l
16 agree with you that maybe the marl does not rise but the 17 surface itself does drop down to the marl's surfaces going 18 northeast --
19 A (Crosby) As I stated earlier, the section is a 20 regional geoloqic section which goes through the plant t
21 itself. At that locality the Darnwell group and backfill 22 materials are overlying the Dlue D1uff marl.
I.3 Q At that pe;in t a nd or.l y a t that point. I'll agree 24 with that.
O
\' 25 On race o you have the comment that wells were Acu.FEDEPAL REPORTERS, INC.
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1 grouted due to near plant location. My questton la how many 2 wells were under the power block and so sacrificed and so 3 grouted?
4 A (Crocby) Could you show us the location of the 5 statement, pleace?
6 Q Gee, I don't have those tled down. I didn't <!et 7 the page nunbers. Give me a minute.
8 Yee, the last s.t n t e nc e , "some welic have had to b-9 abandoned and grouted due to their location near plant 10 facilities." The last sentence.
11 A (Crosby) Figure 4 of our testimony ahowa the p 12 locationJ of the wella and drL11 holes with relationship to v
13 the power block area.
14 Q Okay. And in that figure 4, then, I would aseume 15 that all the wella that are located underneath the power i
16 bloc 4, except those that are currently operational, have been 17 grouted and sacrificed; la that richt?
18 A Thr drill holen which are core holea which -- have 19 been abandoned have been all grouted. That IJ true.
20 Q Underneath the power block?
21 A Yes.
22 Q Dut you don't know how nany wella, offhand? Just 23 an estimate?
24 A If you'd like no to I could count them for you.
O b 25 Q Dall park. You could juJt estimate it. I'll l
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) l 1 accept that. Is it like 30 to 40?
2 A Approximately 36.
3 Q Okay. About 35.
4 on page 7 -- excuce ne, on figure 3, the long 5 figure, starting with TW-1 on the left and moving to the 6 third noted apot, B-132, three fron the left --
)kay? You 7 have -- you show the marl depicted as coming very close to --
0 or the surfse.e, I should cay, dropping to the surface of the 9 marl in three spots.
10 Detween TW-1 and Beaverdam Creek, that is up to o 11 DM-152, there are only two wells in tha t area,
(~S 12 characterization or exploration wells.
13 Goinc from TW-1 to DL-152 is a distance of how 14 far? A couple of miles?
15 A It's a distance of three miles.
16 Q Three miles. And in this area, for this section i
17 over a period of three miles, then, you had only two 18 exploration wells that went through the narl; is that 19 correct?
20 A Perhaps it would be best if I explained the origin 21 of this drawing. This drawing is a cross-section which was 22 developed as part of the postulatad Millett F.iu t t study which 23 was done in 1902.
, 24 Q Yes, I remember that.
(
25 A The purpose of the section was to show the drill ACE. FEDERAL REPORTERS, INC.
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1 hole data use1 to provide -videnca that thor went no 2 postulated faitlt.
3 There are additional drill holez between TW-1 and 4 tho area that Mr. Lawlecs la referring to and they are chown 5 on other figurea.
6 Q Could you tell me how nany that would be, in an 7 are And what floure?
H A Again I'd refer to fi:ure fodr of our tastinony.
9 That ficure chows approximately 25 welle couth of the power 10 block area in towards the area you are concerned about.
11 Q Okay. S ta r t in.; wi th TW-1, which is right at the
,m 12 power block'a south -- or eaJtern edge and meving towarda 13 Deavardam Creek in the line to'erda Deaverdim Cr mk, there 14 appear to be only maybe four welln that I can see there. In 15 that correct?
16 A I --
17 Q I have other questions goinc south of the plant.
10 EJu t this is more Joutheast in line with this tiqure T.
19 A What wac ysur firJt queJtion?
20 Q You said that there were .5 wella and I said: I:u t 21 if you look at TW-1 going southeact to flesh out the figure 22 3, thero appear to be only three or four wella instead of 25.
23 A I'n sorry, in this my reicrophone that's makir.q m 24 thia noise?
! )
25 MR. LAWLEC3: It mignt be nine.
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, i 1 MR. PARIS: Maybe if you moved it a littic further f
2 from your mouth -- ;
i 3 MR. LAWLESS: Sorry about that. !
4 MR. PARIS: It's not your fault.
l 5 THE WITNESS: (Crcsby) This is a line of section, l 6 again, which was used for another purpose. There are 7 approximately five holes, drill holes, which are in line with 8 this section which are not shown on the earlier figure which i i
9 was referred to. j i
10 BY MR. LAWLESS: ,
11 Q Okay. But still over a period of three miles, I ,
t 12 just wanted your feeling. Do you feel that the period of i 0 13 three niles is sufficient to characterize the marl as wall as 14 you have?
15 A (Crosby) Yes. The drill hole data is very 16 adequate to characterize the oxtent of the marl in that i 17 direction. I
- 18 Q A follow-up on that same figure, does the marl go l l
- 19 near the surface as it does in the depression north and j 20 alongside of the -- of Vogtle? Does it near the surface at 21 quite a few other spots around the plant?
l 22 I think later in your testimony you refer to the l
1 l 23 marl reaching the surface at the various creeks. But what I l 24 am referring to is, if you look at figure 3 you can see the !
! p V 25 narl near the aurface at a couple of spota before you even l
l l
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( RT 269 1 get to Beaverdan Creek.
2 ' So , in general, does the marl have a much smaller 3 overburden as you move aro"und the plant in various spots?
4 A The narl is exposed as shown on the figures we 5 show. And it is, indeed, exposed -- or found at a very 6 shallow depth below Dea <erdam Creek, as is shown. The 7 geologic map which is in the FSAR also shows the extent of 8 the marl in the area surrounding the plant.
9 Q Yes. But in addition to that, not only underneath 10 the creek beds -- you refer to that later in your testineny 11 -- but it seems to the northwest of Deaverdam Creek you've r' 12 got two other areas that come very cloJo to the surface, the N )S 13 marl d,oaa. .
14 A Again, I don't know what area you a're referring 15 to, exactly.
16 Q I'm just looking at figure 3. I see TW-1 and 17 B-152. TW-1 and 0-152. And I see Beaverdam Creek and then 18 one of thelowsur[ ace spots is at B-346, which does not --
19 it penetrates the surface of the marl but it does not go --
20 i it does not cross the marl entirely.
l 21 ! And then immediately to the left of that you have 22 another surface depression that nears f.he surtace of the 23 marl.
24 Is this kind of -- is,,this sort of' typical around 7_s
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25 the plant, that the marl rises to the surface or the surface ace.FEDER.AL REPOR1ERS, INC.
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- 1. drops to the marl?
2 A Auain I cannot differentiate statements from your [
l 3 question. Again I would like to say that the topocraphy at 4 the site whez e these creeks have eroded down to near the top 5 of the marl surface is shown on the geologic map, and the i 6 cross sections in the maps reflect the presence of a marl and l 7 its depth below the ground surface.
l 8 Q .Underneath Beaderdam Creek. But are'there also L
9 other spots around the plant where the marl reaches the
, 10 surface?
! 11 A Yes. And again I refer to the geologic map.
i i 12 Q And that is in addition to the creek beds, as you 13 have shown on figure 37 l 14 A (Farrell) I believe what you are asking is that l 15 between TW-1, on figure 3, between TW-1 and B-152, or between ,
t 4 16 -- and Beaverdam Creek, there are two low spots on the i 17 profile there. :
l 18 Q Yes. That's correct.
t
[ 19 A Those low spots are places where the section l '
20 crosses -- tributaries to Beaverdam Creek.
l l 21 Q So those would be creek beds and not just surface r l
- 22 movement independent of creek beds? Is that what you are ,
i ,
! 20 saying? !
24 A Yes. The surface profile there is a following of l 25 the topographic configuration along that section. J l l l t
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, s 1 Q So we'should have a creek along thoue two spots as
- / 2 well; is that right? '
, 3 A What?
4 Q We should have the Beaverdam Creek at the three i ,
f j '
5 depressions?
6 A No. Those two depressions between Beaverdam Creek i
f 7 and TW-1 are in tributaries that the section crosses. They l l -
8 are tributaries to Beaverdam Creek, unnamed t'ributaries.
9 Q Tributaries on Beaverdam Creek. Okay.
10 Figure' 4. On figure 4, looking at both the inset
\ '
L 11 and the exploratory holes, the pattern of the holes r'T 12 throughout the Plant Vogtle, why are there more exploratory I. (_)
l 13 holes to the west and northeast and under the power block of 14 Vogtle than north,. south, and southeast?
15 A. (West) These holes were drilled for exploratory 16 purposes. They have served a multitude of purposes, part of 17 which is foundation design; and some of them were drilled 18 near the river facilities where there are structures.
19 If you will look at it, we have a wide spread of 20 holes throughout the site.
~
21 Q ies. Then what you are suggesting is that the 22 pattern is due to construction?
-t 23 A The pattern is due to exploration for design for 24 " construction.
b) 25
's Q Since most of these wells were dug in the early l
ACE-FEDERAL REPORTERS, INC.
26113.0 2/2 gRT 1 '70s, how do you feel about the adequacy of this particular 2 pattern for mapping the groundwater and the -- the 3 groundwater aquifer and the marl itself?
4 A (Crosby) These holes are not wells.
5 Q Well, some of them are exploration holes.
6 A The drill hole locations are, in order to 7 characterize the site and provide foundation design 8 information, they are widespread throughout the site and were 9 done through various stages of plant feasibility and 10 construction. Therefore there is a wide distribution 11 throughout the whole site area.
12 Q But it seems that if you were building a facility, 13 the well locaticos night be adequate. But if you were 14 looking at a groundwater map and preparing to make certain 15 that groundwater contamination -- understanding that the 16 potential for future groundwater contamination would or would 17 not be a problem, that you might follow a different pattern.
18 How do you feel about that?
19 A (Farrell) I think that there's some confusion 20 here. What the drill holes you see on figure 4 -- includes 21 j exploratory holes for several purposes, I think has been 22 said, one of which includes exploration for determining the
?3 I groundwater condition. They are included in this series of 24 holes here. We believe that the holes and exploration done 25 l is adequate for characterization of the groundwater.
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/v ]RT 273 1 Q I appreciate that viewpoint. I guess my problem 2 is not that you are doing double duty with the wells, I think 3 that's admirable. But it just seems that the concentrations 4 of the well pattern is skewed to a construction pattern and 5 not sufficiently balanced enough to map the area, 6 particularly going southeast -- going southeast of the 7 plant --
8 A (Papadopulos) Mr. Lawless?
9 Q And also going Northwest of the plant.
10 A (Papadopulos) Mr. Lawless, I have reviewed this 11 pattern from the point of view of groundwater as well, and I 12 feel that the number of holes are more than adequate to O(N
- 13 define the existence of the narl in the directions of 14 groundwater flow. As you probably have also established in 15 your review, the primary direction of groundwater flow in the 16 vicinity of the plant is to the north and Northwest and there 17 is a large number of wells in that area, establishing that 18 the marl is present throughout the area of concern, in terms 19 of the groundwater.
20 Q Is this a gut feeling?
21 A Not really, based completely on data. If you look 22 at the number of wella which are present to the Northwest of 23 the plant, there is a large number of wella which have 24 encounte ed the marl.
b,s 25 Q Yes. I agree with you.
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'RT L/4 1 Is there come scientitic point that you can make 2 about the number of wells and the pattern itself? I mean it 3 seems to me that it's a rather haphasard pattern.
4 How can we feel certain that it's not a haphasard 5 pattern? How can you feel certain the data itself --
6 A There is not a rule of thumb in terms of the 7 number of wells that you install in a site. But, geologic 8 processes are processas which deposit sediments in a certain 9 uniform manner.
10 Given that, and civen my experience on other 11 sites, I feel that there is a large number of wells in the 12 site, more than adequate to establish that the marl is 13 centinuous, in terms of its control on the groundwater 14 system.
15 Q In other words, that's a gut feeling based on 16 experience?
17 A Not gut feeling. Experience, professional 18 experience.
19 Q Based on experience. Okay --
20 MR. CHURCHILL: Your Honor, I object to thia 21 argumentative line of questioning and this attempt at 22 testimony by the interrogator. If we could just have 23 succinct, single questions, the witnesses will be able to 24 answer them.
_N
'- 25 MR. LAWLESS: Well, I think they have been ACE-FEDERAL REPORTERS, INC.
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- T 2/a 1 succinct and I have more on that. I'm sorry that the 2 attorney is interrupting at a point when we can begin to tie 3 some of this together.
4 JUDGE MARGULIES: Mr. Lawless --
5 MR. LAWLESS: I am not an attorney and I'm looking 6 at this strictly from a scientific point of view. I do not 7 mean to imply that I'm an attorney. But these questions have 8 to be probed.
9 JUDGE MARGULIES: They also have to be in the 10 nature that they can be answered because there's no pcint in 11 putting five questions into a single statement.
)
12 Why don't you break down your questions more.
13 MR. LAWLESS: I'm sorry.. I apologine.
14 JUDGE MARGULIES: This is also in the nature of 15 cross-examination, Mr. Churchill. So, counsel for intervenor 16 can lead the witness.
17 BY MR. LAWLESS:
18 Q Then based on experience, the pattern, the well 19 pattern is sufficient. But not based on scientific 20 inference; is that correct?
21 A (Papadopulos) I'm not clear by what you mean by 22 scientific inference.
23 Q scientific inference is a scientific tern for 24 statistical treatment. The data, to see how good the data is
)
25 -- I have a couple of authorities here I could cite, ACE-FEDERAL REPORTERS, INC.
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RT 4/o 1 including texts used at Georgia Tech on the importance of 2 statistical influence to characterize the data so that you 3 have more than an experience or experiential feeling about 4 the data.
5 MR. CHURCHILL: Objection. The intervenor's 6 attonpt to raise this aspect of the contention -- it was the 7 subject of lengthy summary disposition proceedings. And the 8 Board explicitly ruled in its order of November 12, 1985 that 9 their attempt to raise a contention on the statistical 10 analysis of hydrological data was unsupported and that has 11 already been ruled on by this board on the basis of 12 affidavits in favor of the Applicant. It is no longer an 13 issue in this proceeding,. and it was not part of the direct 14 examination that these witnesses had presented.
15 MR. LAWLESS: Whereas I might agree, the 16 Applicants have provided this document as their scientific --
17 best scientific evidence. And I think that that is a fair 18 scientific question of their report.
19 (Discussion off the record.)
20 MR. PARIS: Mr. Lawless, Mr. Churchill is correct 21 that we did not admit the general statistical inference 22 matters to be litigated. So you avo3d questions about 23 statistical inference in genera).
24 But, if you have a specific question about values
~
25 that are presented in the testimony and want to know, say, ACE-FEDERAL REPORTERS, INC.
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1 where a range is given, what the distribution of the values 2 between the ranges were, or want to ask where the mean was 3 between the extremes, something like that, something specific 4 with reference to values in the testimony, it's fair game.
5 MR. LAWLESS: It would seem to me to be an undue 6 restriction on the report that they are using that there are 7 questions that can't be broached on their material that they 8 are using for evidence. I think that's almost an impractical 9 suggestion. I will do the best that I can. Scientific 10 inference is a very inportant process. I understand that you 11 have litigated i t out or ruled it out. I am not an attorney 12 and I have a difficult time with regulations, and I find .that 13 regulations and science don' t nix very well, if at all. -
14 MR.' PARIS: Mr. Lawless, why don't you try to 15 direct your question derived from scientific inference toward 16 the testimony the witness has before us -- the testimony we 17 have before us here that the witness has presented.
18 MR. LAWLESS: That's fair.
19 BY MR. LAWLESS:
20 Q on page 9 -- actually, I'm sorry, on page 8, in 21 the middle, kind of in the middle, starting with "over 200 of 22 these holes have explored the marl" and then dropping on down 23 into the last paragraph, you've got, "the permeability of the 24 Barnweil sands was measured in situ in two exploratory
( ;
i 25 l holes."
l l
l ACE-FEDERAL REPORTERS, INC.
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'RT zib 1 Where were those two holes located? Or what two 2 well areas were used to study the edge of the limestone?
3 A (Farrell) They are located in the power block 4 area.
5 Q Also, was that part of Dr. Papadopulos' report or 6 not? This was independent, from his tests?
7 A Those tests you are referring to -- the two testa 8 you are referring to were done in 1972.
9 Q Okay. These were done in 1972. Thank you.
10 Now, page 9, you refer to the 22 drill holes that 11 were used to nap the marl, narl permeability. What was the 12 basis of the drill hole design?
13 MR. CHURCHILL: Your Honor, again, this is a 14 l fairly technical objection but it's important. Mr. Lawless 15 tends to characterize and almost -- state facts almost in the 16 form of testimony. It is to the point of assuming facts not 17 in evidence. I believe he characterized the purpose of those 18 22 holes. I don't see that particular fact that he said in 19, evidence.
20 If he would like to ask if that was the purpose of 21 the holes and again go ahead and ask the question I wouldn't 22 object.
23 MR. LAWLESS: ies. I'm sorry.
24 BY MR. LAWLESS:
25 Q In the first three sentences you are talking about ACE-FEDERAL REPORTERS, INC.
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i narl permeability and the test to establish that, 80 packer 2 tests conducted in 22 holes. It's shown in figure 5. Can 3 you describe the 22 drill hole pattern?
4 A (Farrell) Could you explain what you mean by 5_ pattern?
6 Q Yes, the pattern of it. As you look at figure 5, 7 why did you choose the pattern that is there? Was it 8 haphazard or was it planned; and if it was planned, what was 9 the plan?
10 MR. CHURCHILL: Could we have one question at a 11 time on that, please? It's confusing to me exactly what he's 12 asking the witness.
r)
\_/ i .
13 l MR. LAWLESS: I'm sorry. So.7etimes you have to go .
14 through the question entirely. I will be glad to back it up 15 if the panel has problems with that.
16 THE WITNESS: (Farrell) Would you repeat the 17 question?
18 BY MR. TEPER:
19 Q What I'm looking for is the 22 -- you can see the 20 well pattern in figure 5; what was the purpose of that 21 pattern? Was it a haphazardous pattern or haphazardous 22 layout, or was it a planned layout? And, if so, what was the 23 plan? That's just one question.
24 MR. PARIS: In other words, why did you put the 25 wells where you did; right?
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26113.0 lE sda 1 MR. LAWLESS: Yes. Yes.
2 THE WITNESS: (Farrell) Well, tne purpose of the 3 location of the holes, these holes were multi-purpose holes.
4 They were, as part of the total exploration program, the
$ permeability testing -- those h les were selected for 6 permeability testing to provide a distribution of locations 7 on the site to test the permeability of the marl.
9 BY MR. LAWLESS:
9 Q But why was the pattern such that there were 10 explorations only under the power block and around the 11 l landing to the northeast and then to the northwest? Why were 12 there no holes to the south and southeast? It's a rather a
13 broad area.that seems to have been left out.
14 A (Farrell) You say a broad area. In relationship 15 to what?
16 Q To the marl permeability.
17 A Well, I believe that the area covered by these It covers an area of, on the 18 f holes is quite a large area.
1 19 j order of, I believe, on the order of two square miles.
20 Q Yes. I agree with you there. It is over a large 21 area. But I don't think that addresses the question.
22 MR. CHURCHILL: Could we have the question again, 23 pleasel 24 MR. LAWLESS: Yes.
25 BY MR. LAWLESS:
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26113.0 BRT 201 1 Q Why didn't you explore south, southeast? That 2 seems to be a very large area, too.
3 A (Crosby) The Blue Bluff marl was explored to the 4 south and southeast of the plant site by the core holes which 5 are shown on figure 4. The -- examini ng the core throughout 6 the plant site cives us cor.fidence in the consistency of the 7 Blue Bluff marl throughout the site area. And there are 8 holes through the south and southeast of the power block area 9 which did have packer permeability tests conducted in them, 10 and they are shown on figure 5; they are the 900 through 902 11 series as shown on the inset up in the corner.
s 12 Q 902 series, right. Yes. But according to page 9
. 13 you state that other than the 901. 902 -- the 900 series, 14 rather, other than that, that the permeability was 15 characterized with the well pattern shown on figure 5. The 16 permeability, that is to say, of the marl.
17 A (Crosby) It does discuss the 900 series. The next 18 j sentence down, "During the geotechnical verification work 19 performed in the summer of 1985, an additional 15 packer 20 <
tests were performed in six new holes shown as the 900 1
21 through 905, on figure 5."
22 Q Yes. I can see that. As you can see, on figure 23 5, figure 5 shcws all of that. It still doesn't answer the 24 question. No permeability testing was done south of the
'J 25 plant?
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l- 1 A (Farrell) Permeability testing is a sampling. In l 2 terms of what the results of the permeability testing was, it l
3 was consistently the same results. The correlation of that 4 testing with the characterization of the marl itself, 5 logically, we believe that it is demonstrable that the 6 permeability characteristics of the marl is consistent l 7 throughout the site, and to the south.
l 8 Q But you did not eay that.
9 MR. CHURCHILL: Your Honor, he's answered the 10 question. That sounds like an objection to me.
l 11 I think he's got the answer he's lookinc for.
12 He's not here to answer. .
e 13 MR. LAWLESS: I beg to differ. I.think that's the j 14 only -- as opposed to law, that's the only way to get to the l
l 15 bottom of scientific questions, is to argue, and put forth
- 16 the case again and again.
l 17 JUDGE MARGULIES: The purpose of the interrogation l 18 is to develop facts and not to engage in a polemic f ror. the l
19 witness, and it's from those facts established in the record l
l 20 that you can draw conclusions. So, it is objectionable to be 21 arguing with the witness.
l l 22 MR. PARIS: Mr. Lawless, is what you are trying to 23 get at why there are -- why no permeability tests were 1
24 conducted in wells at some distance to the south of the power l l'
\ 25
( block, as was done to the north of the power block?
l l
l ACE-FEDERAL REPORTERS, INC.
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26113.0 f" 133 b;RT 1 MR. LAWLESS: Yes. That's correct.
2 MR. PARIS: Could you answer that?
3 THE WITNESS: (Farrell) We didn't see any need to 4 continue further testing, that the exploration that was done 5 to the south indicates the marl is of similar characteristics 6 as that encountered where the testing was done.
7 BY MR. LAWLESJ 8 Q But the permeability that follows later, from 10 9 to the minus 6 to 10 to the minus 9, was based or. data from 10 exploration north of the plant and through the powtr block 11 itself, basically?
3 12 A (Farrell) I believe you are referring to the
%)
13 laboratory permeability tests?
14 Q Yes.
15 A Those samples that were tested were taken from 900 16 series holes that are within the power block area.
17 Q Yes. Right. I think, then, kind of in a summary, 18 then, that the range that is used for permeability is pretty 19 well based on these exploration holes.
20 MR. CHURCHILL: Is that a question?
21 MR. LAWLESS: Yes, that's a question.
22 THE WITNESS: (Farrell) Yes.
23 BY MR. LAWLESS:
24 Q Thank you. On figure 6 you assume that the Huber 25 formation is mildly to moderately permeable.
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- n f 201 1 A (Crosby) Figure 6 makea no 'referencc to what you 2 just stated.
3 Q Well, it says, " semipermeable," and there is text 4 that goes with that.
5 A But you said it was mildly permeable. That's not 6 stated.
7 Q I'm sorry, liigh l y . That's my fault. Ilighly 8 impermeable. Moderately to highly -- so it's moderately 9 permeable to hichly impermeable. I apologise.
10 A I would just stand on what we state in the text.
11 I think your characterisation is incorrect.
12 Q Actually I guess I got it from you on page 10.
13 Maybe that'2 where I made the er'ror. About,the 5th sentence 14 i down, page 10, you've got " overlying this sequence of beds of 15 moderate to high permeability is the Blue Bluff."
16 The question is that underneath the Blue Bluff 17 there is semiperneable material and also systems that are of 18 moderate to high permeability; is that correct?
19 I A (Farrell) Page 10, I think what you are referring i
20 to is a description, a qualitative description of the 21 permeability of the marl, the Blue Bluff marl.
22 Q I don't think so. It says, " overlying this 23 sequence -- this is the fourth sentence down, " overlying this 24 sequence of beds of moderate to high permeability." In other
, 4 25 words, the alue Bluff marl is over systena that have -- that ACE-FEDERAL REPORTERS, INC.
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26113.0 "RT ;Ts 1 are somewhat permeable.
2 A Yes. I'm sorry. Moderate to high permeanility is 3 referring to the Cretaceous and Tertiary --
4 Q I'll follow up on that, then. It the blue marl 5 fails the Tuscaloosa will be unprotected; is that correct?
6 MR. CHURCHILL: Your Honor, I have to object to 7 this, too, as a line of questioning that was explicitly ruled 8 upon by the Board, considered in summary disposition and 9 ruled out on page 14 of the order.
10 The Elnton formation, the question of whether it 11 exists and the question of the formations between the
. 12 Cretaceous and Tertiary aquifer are really irrelevant,
. 13 because we are assuming they are hydraulically connected and 14 on that basis this board said that geology and hydrology 15 beneath the blue marl is not any longer a'n issue in this 16 hearing.
17 MR. LAWLESS: I would object to that. The 18 ques tion really ref ers -- excuse me -- more to the marl --
19 JUDGE MARGULIES: Go ahead.
20 MR. LAWLESS: The question refers really to the 21 marl. If the marl fails then there's nothing to protect, 22 essentially there's very little protection to the 23 Tuscaloosa.
24 If we concentrate on the marl, the marl integrity x- 25 becomes even more important.
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1 JUDGE MARGULIES: In our order, one of the areas
. 2 to be covered is the uncertainty in data on marl thickness 3 and permeability, and we will permit the question.
4 THE WITNESS: (Farrell) Would you repeat that 5 question?
6 BY MR. LAWLESS:
7 Q Then, if the blue marl fails, the Tuscaloosa will
-8 be unprotected underneath the plant?
9 A (Farrell) I'm not clear what you mean by " fails."
10 Q If the blue marl is breached; if contaminants can 11 find their way through the marl through any process, known or
(~) 12 unknown; if they can get through the blue marl then the U
13 Tuscaloosa is unprotected?
14 A Well, that postulation -- if they get through the 15 marl they will be through the marl. But I don't see where 16 that is related to the Tuscaloosa being unprotected.
17 Q I'm not saying that it's unprotected. I'm saying 18 that the blue marl is what is protecting the Tuscaloosa and 19 we are quite dependent upon that, if that is correct. You 20 would agree with that, then? If the blue marl fails, the 21 Tuscaloosa is unprotected?
22 A (Papadopulos) The potential consequences of flow 23 through the blue marl have been discussed in other parts of 24 the testimony, Mr. Lawless, and they indicate that there is 25 no -- any danger in contaminant through the marl of the ACE FEDERAL REPORTERS, INC.
26113.0 "RT 26/
1 underlying aquifers.
2 Q So I take it then that you acree that the blue 3 marl is important, and as long as the blue marl doesn't fail 4 then the Tuscaloosa is protected?
5 A gPapadopulos) "Doesn't fail" is not clear to me, 6 still. Doesn't fail --
7 Q As long as nothing breaches the mar], through 8 whatever means?
9 A What do you mean by " breach" again? Do you mean 10 by flow of groundwater?
11 O As long as contaminants don't go from above the 12 marl to below the marl, as long as that dor n't happen, the 13 Tuscaloosa is protected?
14 MR. CHURCHILL: Your Honor, the witness has just 15 testified that they have in their testimony talked about the 16 transfer of materials through the blue marl. and I think it 17 would be appropriate if Mr. Lawless would asl: specific 18 questions about that, rather than trying to get him to 19 character 1:e something subjectively in the way that obviously 20 these people can't do.
21 MR. TEPER: Mr. Chairman, Mr. Lawless has stated a 22 foundation of facts to -- building up to his final question, 23 which was, if the marl is breached would there be 24 contamination? The Applicant's witnesses refuse to answer 25 that question. I think they say themselves in their own ACE-FEDERAL REPORTERS, INC.
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[ 1 testimony that they have addressed that. Then why will they 2 not just co ahead and answer the logical conclusion to the 3 set of questions?
4 JUDGE MARGULIES: I think that's a fair comment.
5 These are expert witnesses. If there are otner portions in 6 their testimony that relate directly to it, let him rely upon i
7 it and point it out.
8 They shouldn't be hesitant and reticent la 9 responding to Mr. Lawless. If he has predicates in his 10 questions that are not correct, let them cay co.
11 MR. CHURCHILL: I understand that, your Honor. I s 12 was just pointing out that that is exactly what Dr.
13 Papadopulos did do.
14 THE WITNESS: (Pa pado.pulo s ) Your Honor, I wasn't 15 trying to be cute about this thing. I an not really clear 16 what Dr. Lawless means when he says " fails" or " breaches."
17 Are you talking about a structural failure, a structural l
18 breach? I'm not really clear. I'm not trying to dodge the 19 question. What do you nean exactly when you say "a failure 20 of the narl" or "a breach of the marl"?
21 MR. LAWLESS: Let me rephrase it somewhat.
22 BY MR. LAWLESS:
23 Q If contaminants pass through the marl through 24 whatever method --
x I
x- 25 A (Papadopulos) I answered that question, then, ACE-FEDERAL REPORTERS, INC.
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c 26113.0 2a3 gRT i 1 Mr. Lawless. I told you we have evaluated the consequences 2 of contaminants passing through the mari. t 3 Q Yes. I've got a question based on that later, 4 when we get to your report. And I don't want to belabor the i
l ,
5 point. It seems to me rather clear. If the marl is the 6 primary protection of the Tuscaloosa -- and at least it seems 7 to me from your report -- and I just want -- wanted that 8 affirmed if it can be arfirmed.
9 JUDGE MARGULIES: I think this would be an 10 opportune time to take a recess. We don't want to belabor 11 the reporter. We'll take a 15-minute recess.
p 12 (Recess.) ,
l (
- 13 JUDGE MARGULIES
- Back on the record.
l 14 MR. TEPER: Mr. Chairman, if I could possibly make l
15 a request at this time, I guess I would want to call it an l 16 emergency request. My understanding of the procedure that we 17 have set out for these hearings is that groundwater would be I
18 addressed first and then the solenoid valves; is that 19 correct? Or was the dose rate effects the next subject?
20 MR. CHURCHILL: The solenoid valves.
21 MR. TEPER: The solenoid valves?
22 MR. CHURCHILL: Yes, sir.
23 MR. T2PER: My request is this, sir.
24 The Intervenor's expert witness, without the l O', 25 benefit of pay, has con.a to Waynesboro today from Atlanta and
\
i ACE-FEDERAL REPORTERS, INC.
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26113.0 "RT 2su I will be unavailable after today.
2 If it is at all possible, possibly atter -- if we 3 can dispose of the groundwater contention today, if I can 4 request the Board that he somehow or other be able to give 5 his testimony today, it would really be appreciated.
6 I understand that there might be some other 7 proceedings that we might have scheduled before that, but 8 seeing as none of the Intervenors' witnesses or 9 representatives are being paid, it we can somehow or other 10 proceed with Professor Deutsch's testinony sometime today it 11 would be appreciated.
12 JUDGE MARGULIES: Do you wish to be heard, 13 Mr. Churchill? .
14 MR. CHURCHILL: Yes, sir. I believe the Staff has 15 1 witness availability problem with that. Maybe we should 16 hear from Mr. Bordenick first?
17 MR. BORDENICK: That's essentially correct, 18 Mr. Chairman. Based on Mr. Johnson's representations durinc 19 the course of the telephonic conference call last Tuesday, 20 staff proceeded to arrange its schedules, that is ny schedule 21 and the schedule of the technical expert witness, 22 Mr. Nasciantonio. Mr. Masciantonio will not be arriving in 25 this area until probably later this evening.
24 The long and short of it is I haven't completed 25 preparation of my crocs-examination of Dr. Deutsch. On the ACE-FEDERAL REPORTERS, INC.
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26113.0 RT 291 1 basis of the representatienc made, I made a start last week 2 and it was my intention to continue those preparations this 3 evening and tomorrow evening in anticipation of Thursday 4 being the cross-examination date.
5 I don't have a copy of the transcript of the 6 prehearing conference but it is my clear recollection, and 7 the clear recollection of everyone else I have talked to, 8 that Thursday was the date agreed upon for Dr. Deutcch.
9 We indicated, we being the Staff, that we had no 10 problem taking him out of crder, but I think in the context 11 of the remarks during conference of counsei that meant 12 Thursday, not Tuesday. We are not prepared to proceed with 13 cross-exanination of him today and I would object to 14 proceeding on that basis.
15 MR. TEPER: Mr. Chairman, first thing I would like 16 to say, I think it was quite appropriate that the Applicants 17 defer to the Staff. I believe -- my understanding, I did not 18 witnesa nor do I have a transcript of the prehearing 19 telephone conference, but my understanding of these hearings 20 is that if possible they are to be commenced with as rapidly 21 as possible.
22 The NRC and their Staff seem to have adequate 23 resources to bring in their experta when they can, as opposed 24 to when public intervenors and public interest -- and what 25 kind of resources are available to them.
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1 If the Staff has any questions -- I don't believe 2 Mr. Deutsch is goina to change his direct testimony. I 3 believe for the most part it is going to be entered as 4 prefiled. If the Staff har any questions to, or 5 cross-examination, we would not object to the Staff filing 6 any questions and we would be more than happy to answer them.
7 JUDGE MARGULIES: Why do you raise the matter 8 tooay, Mr. Teper? We had qone through this at the prehearing 9 conference last Tuesday.
10 Your witness was accommodated in that we were to 11 proceed with Contention 7 and then 10.1 and 10.5. At the 12 i request of Mr. Johnson, the other parties were willing to 13 change the order to accommodate your witness to follow 14 Contention 7. The record is as stated by Mr. Bordenick.
15 If you did have a request, why wasn't it made 16 before today?
17 MR. TEPER: Mr. Chairman, I did not have this 18 information until this morning when my expert witness 19 arrived. I also did not have the information that 20 . Mr. Johnson, who at that time was an intervenor -- since I do 21 , not have a transcript -- if he made any representations that 22 the expert testimony would be on Thursday, at this time 23 changed circumstances -- and I believe we ca.n make 24 accommodations for changed circumstances -- would be
_s 25 appropriate in order to have a record that is full and l
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23113.0 RT 49a 1 complete.
2 If the Intervenors do have testimony that does 3 need to be introduced in evidence, it is appropriate that 4 that be done when it is able.
5 If our witness is not available after today, then 6 the record would be incomplete and it would then be on your 7 shoulders to make a judgment on an incomplete record. I 8 think that is an unfair burden to yourself.
9 JUDGE MARGULIES: I don't have any problem making 10 the judgment. We will proceed as we expected to, in line 11 with the prehearing conference. You have the remainder of 12 the week to make your witness available.
la We will continue with Contention 7 at this time.
14 MR. LAWLESS: I would like to just back up to the 15 break point. I think at the break point I had asked the 16 question if the blue marl was penetrated or if contamination 17 passed through blue marl, the Tuscaloosa would be 18 unprotected.
19 ,BY MR. LAWLESS:
20 Q Did I get a "yes" on that?
21 A (Farrell) We had not directly answered that. I 22 think we have concern over the characterization of "left 23 unprotected"; of your hypothesizing that the characteriza tion 24 of the marl as we believe it is would not be custained, that s' 25 would not necessarily leave, as you characterize the i
l ACE-FEDERAL REPORTERS, INC.
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26113.0
-" RT . 134 1 Tuscaloosa, unprotected from contamination.
2 The migration of contaminants would still have 3 approximately 150 feet of material to migrate before it would 4 reach -- vertically -- before it would reach the Tuscaloosa.
5 And in fact the direction of flow in the Tertiary aquifer, 6 beneath the marl, is towards the Savannah River.
7 BY MR. LAWLESS:
8 Q Yes. I agree with that, but for contaminants 9 heavier than the water, they may head down if their drop is 10 faster than the flow of the water, but I agree with your 11 answer. That seems acceptable.
12 On page 9, and I would like to refer -- I'm sorry, C:) .
13 on page 10, on the February document, I would like to refer
. 14 you back to the July 8, 1985 document, page 9 -- on page 9 of 15 the July '85 document. Do you have a copy of that?
16 A (Crosby) Yes.
17 Q It looks like it's the last sentence. If I could 18 read that --
19 MR. CHURCHILL: Excuse me, Mr. Lawless,-which 20 document were you referring to? There were several.
21 MR. LAWLESS: In the July '85 document, the 22 companion document to the testimony today, identical 23 document.
24 HR. CHURCHILL: What is the title, please?
25 MR. LAWLESS: "The affidavit of Thomas W. Crosby ACE FEDERAL REPORTERS, INC.
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26113.0 RT 49b 1 and Farrell and Wert."
2 I ray July 8th, that's the date that they signed 3 it.
4 JUDGE PARIS: Is that the affidavit that 5 accompanied the motion for summary disposition of this 6 contention?
7 MR. LAWLESS: I am not certain. I think so. It 8 is the document that's ainost identical to the document that 9 we are presently reviewing.
10 MR. CHURCHILL: That would be the affidavit of 11 these witnesses.
12 , MR. LAWLESS: Okay. It was sioned on July 8,
,Y '
13 1985. If I could just refer to it as that date.
14 BY MR. LAWLESS:
15 Q On page 9, at the bottom of the page, there is a 16 statement, and I would like to read it. It says:
17 "The marl layer" -- again, this is the 1985 10 document -- "the marl layer, approximately 70 feet thick, is 19 in effectively impermeable layer that confines the Tertiary 20 and Cretaceous aquifers and hydraulically isclates the 21 confined aquifers from the underlying aquifer."
22 That statement was changed in the February 24th 23 document. That's on page 10. On page 10, "the marl,
,s 24 approximately 70 feet thick, is a layer of very low
' ' 25 permeability that confines the Tertiary and Cretaceous ACE FEDERAL REPORTERS, INC.
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2 This seems to me in part changed. If I may draw 3 your attention, it looks like the July '85 statement said
! 4 that.the marl was impermeable, effectively impermeable, and 5 that it hydraulically isolated the confined aquifers. In 6 February '86 it refers to the marl "of low permeability" and 7 it's no longer hydraulically isolating. It just says
- 8 " confines."
l 9 Could you explain why that change was made?
10 A (Farrell) Effectively impermeable was a 11 description, a qualitative description that there was some --
12 there were questions, at the time, in the interrogatories in I
l
( 13 relationship -- and we just' thought that it would --
)
i 14 JUDGE PARIS: Mr. Farrell, I did not hear that l
l 15 last sentence, sir. Could you speak into the Mike?
L 16 THE WITNESS: (Farrell) I say effectively
! 17 impermeable is a qualitative term. There were certain 18 questions about what that meant. So we thought that in the 19 testimony that we wou1d reword it to, hopefully, clarify what 20 the description -- the characterization of a marl in l 21 relationship to its permeability.
I
- 22 There is nothing that is impermeable. Very low l 23 permeability is another qualit&tive term that is essentially I
i 24 the same as saying " effectively impermeable." But we thought i
( 25 that it was a clearer statement of it, would be more I
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2 BY MR. LAWLESS:
3 Q I don't know that I could agree that impermeable 4 is the same as low permeable. My follos-up question is do 5 you no longer consider the narl impermehble? From your 6 answer, it sounds like you do not.
7 A We still would describe the narl as effectively
~
8 impermeable.
9 Q Do you no longer consider the marl to isolate the 10 groundwater aquifer from the Tuscaloosa aquifer?
11 A No. We still consider that.
12 Q Why was it chanced?
I 13 MR. CHURCHILL: Your Her.cr, he just answered tha t 14 question.
15 JUDGE MARGULIES: The question is repetitious.
16 MR. LAWLESS: Figure 7 is a ver/ attractive 17 figure.
18 THE WITNESS: (West) What document?
19 MR. LAWLESS: On the back of the '86 document.
20 SY MR. LAWLESS.
21 Q In general, can you characterize the engineering 22 work on groundwater over the past few years? H a .s the amount 23 of money spent by Vogtle, Plant Vogtle increased in studying 24 the groundwater contamination problem?
m- 25 A (Farrell) I don't understand the question.
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~Rf 2;G 1 Q Could you charac terize It? I was just interes ted 2 in the ceneral amount of spendina that has gone into study of 3 groundwater contamination, or has it, in general, increased 4 over the past four or five years?
5 THE WITNESS: (Farrell) The -- are you -- do you 6 understand the question?
7 THE WITNESS: (Crosby) Yes. We are not able to 8 answer that question.
9 BY MR. LAWLESS:
10 Q The amount of engineering work that has been done 11 on groundwater contamination, potential for it and studying 12 the marl itself, has that si,gnificantly increased over the 4
e i
13 past few years? And, if so, could you describe it?
14 MR. CHURCHILL: Could we have a little bit more 15 clarification, significantly increased over what?
16 BY MR. LAWLESS:
17 Q Has it increased over the last few years? Has it 18 been level?
19 A (Crosby) I can only state that we have done 1
20 research and exploration which answered NRC concerns and J
21 addresses Contention 7.
22 Q On page 11 at about the fifth or sixth line, you 23 i mention the marl was exposed at Mathes -- at Mathes Pond.
24 Does the bottom of Mathen Pond penetrate the marl?
25 A (Farrell) No.
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~RT 239 1 JUDGE PART5: What was the answer?
2' THE WITNESS: (Farrell) No.
3 MR. LAWLESS: No. It does not.
4- BY MR. LAWLESS:
5 0 Is there erosion of the marl at Beaverdam Creek or 6 at any creek or channel surrounding Vogtle?
7 A (Farrell)'Are you asking erosion of the marl?
8 Q Yes. Has the marl been eroded in any place?
9 A Yes, it has been by the Savannah River.
10 Q Only at the Savannah River but not at the surface, 11 on the surface itself?
12 l A It has been eroded in the Mathes drainage also.
13 Q So there has been some cut into the marl. Okay.
14 Let's see, on page 11, in the sentence that starts 15 with " south and west of the site," Beaverdam Creek, in the 16 July '35 document there were some sentences that were 17 deleted. That's on pace 10. What was deleted was the first 18 sentence of item 24, " bordering the site on the south, west 19 and north are stream channels tributary to the Savannah River 20 that have cut through the ind down to the marl." There 21 seems to be just one ;
ei' e; let me focus on that.
22 " Bordering the site on souto, west and north are stream 23 channels tributary to the Savannah River that have cut 24 l through the aquifer sands down to the marl."
25 Was the change a result of tryina to ACE-FEDERAL REPORTERS, INC.
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^RT aud 1 recharacterize the streamc as no loncer bordering the site?
2 MR. CHURCHILL: Excuse me, I don't understand. I 3 read the same centence in two different documents and I'm not 4 sure what he ic comparing.
5 MR. LAWLESS: On page 11, in the '86 document.
6 JUDGE MARGULIES: Why don't you tell us what the 7 sentence is that is purportedly missing from the February 24, 8 '96 document.
9 MR. LAULESS: "Sordering the site on the south, 10 west and north are stream channels tributary to the Savannah 11 River that have cut through the aquifer sands down to the 12 mari.
13 , , MR . CHURCHILL: That is located on the top of page 14 11 of the witnesses' testimony.
15 MR. LAWLESS: Yes. I see that. But the location 16 of it seems to have changed. I think the problem with mine 17 is that it doesn't have an indentation -- on page 7 -- give 18 me iuct one second with it.
1 i
19 Okay. I do see the citation.
20 BY MR. LAGLESS:
21 Q The question I have, then is this: Does the 22 Beaverdam Creek border on the south, or does it penetra.e 23 into the Vogtle site .ind the tributaries to Beaverdam Creek?
\
24 A (Farrell) Does Beaverdam Creek border the sotith of 25 the site?
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, 1 Q Yes. Is that the -- Beaverdam Creek is shown in f
2 the figure 1 -- excuse me -- ficure 7 perspective. And you 3 can see a tributary from Beaverdam Creek.
4 What I'm trying to find out is what is -- what 5 consiste of bordering the site? Would it be Daniels Branch l 6 and Beaverdam Creek and Mathes Pond to the north?
7 A Well, possibly -- look at figure 7. I believe 8 there you can see the Savannah' River is bounding it on one l 9 side, the Mathes Pond drainage is bounding it on another, and 10 to the south and southwest, Beaverdam Creek and its l 11 tributaries, Daniels Branch and unnamed tributaries border it 12 on that side.
t (
l 13 0 The unnamed tributary from Beaverdam Creek, that 14 more or less penetrates tne site, then?
15 A It doesn't penetrate'the site.
, 16 Q Yes.
l l 17 A I'm not sure what you mean by " penetrate the r
18 site."
l 19 Q I mean it goes into the site.
! 20 A Well, possibly we should define what you mean by l
i 21 "the site."
22 Q I guess the general area of this diagram, figure
- .3 7.
i 24 A Well --
]\~- 25 Q on pace 11 you are referring to figure 7 and 8 --
l l
l l
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2 JUDGE MARGULIES: Do the witnesses have anything 3 further to add or have they completed their answer?
4 THE WIT!!ESS: (Farrell) I'm sorry, we are lookino 5 at figure 7. I thought he was trying to say something.
6 BY MR. LAWLESS:
7 Q The tributary, the unnamed one from Beaverdam 8 Creek, seems to go towards the plant. Was that part of the 9 characterization " bordering the sit 3" or not?
10 A (Farrell) Yes. I think in our testimony we say 11 " South and west of the site is Deaverdam Creek and its major 12 tributary, Daniels Branch. The marl is present in these 13 channels just below alluvial channel deposits. Extending 14 northward from these main streams are tributaries bordering 15 the site."
16 Q I guess I have -- I just have difficulty with 17 characterizing that unnamed branch as bordering the site. It 18 seems more to almost penetrate the site. It dcesn't quite 19 get there but it doesn't seem to be a part of a border.
20 JUDGE PARIC: I think the witnesses and the 21 interrogator are talking about two different unnamed 22 branches. I think the witnesses are talking about the 23 tributary to Daniels Branch, west of the plant. And I think 24 you are talking about the tributary at the Beaverdam Creek to 25 the south of the plant.
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1 MR. LAWLESS: That's correct. The one that runs 2 along the section AA.
3 THE WITNESS: (Farrell) I guess you are defining 4 the site, I quess, as the property of the Georgia Power 5 Company; that tributary is on the property.
6 BY MR. LAWLESS:
7 Q Okay. It seems to be misleading. That's why I 8 was trying to probe it a little bit, just that instead of a 9 border, there is a stream that cuts very close to the plant 10 towards the southeast. And --
11 A (Farrell) Well, the headwaters of that tributary 12 are south of the --
13 Q Immediately adjacent. Right. And on the plant 14- property? ,
15 A Yes.
16 Q on page 12, about midway through the first 17 ' paragraph you mention the marl: "Because of the marl, spill 18 migration of any significance would be lateral and the spill 19 would move in the direction of decreasing hydraulic head."
20 And I presume that's just a general statement, that that 21 would not take into consideration any penetrations in the 22 marl itself, if the marl were penetrated by wells?
23 MR. CilURCHILL: Your Honor, we are talking about 24 contaminant flow through the marl by well penetration.
( 25 Again, that was a separate issue that has been litigated in ACE-FEDERAL REPORTERS, INC.
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, - ~ RT au4 1 summary disposition and explicitly ruled upon already by the 2 Board and not part of this hearino today. That would have 3 been on pages 21, 22 of your November 12th order.
4 MR. LAWLESS: Whereas that may be so, on page 12 5 they are very specific in mentioning that,the migration tJould 6 move laterally. I guess I am just asking how certain that 7 is, that there would be no other direction that the 8 contamina tion could move in.
9 THE WITNESS: (Farrell) I think the sentence 10 states --
11 MR. CHURCHILL: Excuse me, Mr. Farrell. There's 12 an objection pending.
13 JUDGE MARGULIES: The objection will be 14 sustained. The matter of the well is not part of this 15 proceeding.
16 MR. LAWLESS: I'm not really asking about the 17 well. I'm asking about this statement on page 12. They say 18 i that spill migration of any significance would be lateral.
I 19 How certain are they of that?
I 20 '
I can't talk about wells, I can't talk about plant 21 settlement. But I can talk about that statement.
22 THE WITNESS: (Farrell) Do you want --
7 23 MR. CHURCHILL: Is there a question pending?
24 BY MR. LAWLESS:
(
25 Q Yes. How certain are you that the only migra tion
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I would be lateral?
2 A (Farrell) Yes. That is our belief.
3 JUDGE MARGULIES: I will let the witness answer it 4 as to the extent of the uncertainty he has as to this 5 statement.
6 If he wants to expound on the answer further he 7 may, or if he just wants to leave the yes that's 8 permissible. Is'that your answer, yes?
( 9 THE WITNESS: (Farrell) Yes.
l
! 10 BY MR. LAWLESS:
11 Q What is that based on?
12 A (Farrell) Our analysis,of the migration. the 13 permeability of the naterials involved.
14 Q And you have not looked at any alternative 15 pathways?
16 A Alternative pathways?
17 Q What are the pathways? Just lateral?
18 A Lateral and through the mari, vertically.
i 19 Q How would it get through the marl?
20 A By convection.
l 21 Q Is that the only way it could get through the l
22 marl?
23 A Water?
i 24 Q Contamination.
l 25 A A contaminant? Are you asking --
l l
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26113.0 RT J06 1 Q Yes.
2 A Contamination migration through the marl?
3 Q As a scientist, what are the ways that the 4 contamination can get through the marl?
5 A Well, it depends on what kind of contamination you 6 are talking about. What we have been addressing as 7 radioactivity, and the particular isotopes, the contamination 3 of isotopes, the only possible isotope that we believe could 9 be considered as migrating through the marl possibly is 10 tritium, because it would move with water. And our analysis 11 shows that as far as the contamination goes it would be 12 decayed to low concentrations, acceptably low concentrations 13 before it got through the marl. .
14 A (Pa padopulos ) If I may add to the question about 15 the scientific processes which control the migration of 16 contaminants.
17 BY MR. LAWLESS:
18 Q Yes.
19 A (Papadopulos) The primary processes are ,
20 convection, dispersion and absorption by the subsurface 21 materials.
22 Q So what ycu are saying, then, with everything that 23 you know about Plant Vogtle, tnat that's the on'.y way that 24 contamination can pass through the marl, at Vogtle, directly 25 under Vogtle?
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^RT sv7 1 A That is the only way contaninants would be 2 transported by groundwater.
3 Q There is no other way that contanination can get 4 through the marl?
5 MR. CHURCHILL: Asked and answered, your Honor.
6 MR. LAWLESS: He said "with groundwater, with the 7 transport of groundwater." I'm saying -- or I'm asking this.
8 DY MR. LAWLESS:
9 Q You are saying, with everything you know about 10 Plant Vogtle, that there is no other way for the 11 contamination to pass through the marl?
c- 12 A (Papadopulos) The top of the marl is about 25 to 13 30 feet below the water table at Plant Vogtle so any 14 contaminants have first to enter the groundwater system.
15 Then they will move within the groundwater system by the 16 processes which control contaminant transport within a porous 17 medium.
18 i Q And there is no other way contamination can get 19 through there, through --
20 MR. CHURCHILL: Your Honor, I've got to object. I 21 don't know how many times the same question has been asked 22 and it has been answered.
23 MR. LAWLESS. Well, we have four reputable 24 scientists who are stating that there is no other possibility e ')
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1 raise the issue of whether the marl has been damaged by well 2 penetrations; and we have scientists here that are saying 3 that they can't conceive of any way'to penetrate that marl 4 other than through the normal groundwater transport.
5 MR. CHURCHILL: I have never -- and I understand 6 he's not an attorney and he is unfamiliar with these 7 proceedings -- but I have never in my experienco seen anybody 8 so disrespectful of the ground rules of the Board's orders 9 and rulings in this cace. We know what he's trying to do.
10 He's trying to discuss wells. He hasn't established his case 11' on wells. It has been litigated and disposed of. So he's 12 just trying to repetitively ask the same question over and .
Os over again, to try to get the w[tnesses to enter into a 13 14 discussion of a subject that is outside the scope of this 15 hearing.
16 MR. TEPER: Mr. Chairman, I also am not an 17 attorney and we don't wish to be disrespectful, but the point 18 is, since we are to refrain from discussing the well, if 19 there were other types of excavation which could penetrate 20 the marl, this would be a method of breaching the mari. We 21 have heard these -- the Applicants' witnesses say that there 22 was no other way. There obviously are other ways. If they 23 were to bring backhoes in and dig through it, that is one 24 way.
25 MR. CHURCHILL: We will concede, if we brought a ACE. FEDERAL REPORTERS, INC.
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RT Jus 1 backhoe in and dug 70 feet through the nari and poured some 2 stuff in there it would probably gc throuch.
3 MR. TEPER: And some people would say a well is a 4 method of doing that.
5 JUDGE MARGULIES: We will sustain the objection.
6 MR. LAWLESS: As part of that objection, a comment 7 that I have is statements were made by the Savannah River 8 plant in their environmental impact statements that the marl 9 and the clay at the Savannah River plant could not be 10 penetrated; it was impervious to penetration. And I 11 understand how important rules are in our society, but I must
~
12 inform you that rules will not prevent the contamination
. 13 passing through the marl.
14 JUDGE MARGULIES: There's no limitation -- there 15 has been no limitation on Intervenors' side producing expert 16 witnesses and presenting testimony within the limits of this 17 proceeding.
18 MR. LAWLESS: Right. Thank you.
19 ,
JUDGE MARGULIES: Your offering commonts like that 20 l offer nothing to this record.
21 MR. LAWLESS: No. I think you have helped me a 22 great deal on that.
23 I would like to suggest in the ERDA 1537 document, 24 page 2152 --
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1 Mr. Lawless.
2 MR. LAWLESS: I'm sorry. I thoucht you said I 3 could offer it.
4 JUDGE MARGULIES: I said the Intervenors had that 5 opportunity. They should have submitted testimony by experts .
6 who would testify on this. That should have been submitted 7 like all the other testimony on February 24th.
8 MR. LAWLESS: We'll stand on this. These experta, 9 then, claim that there is -- the only penetration of the marl 10 will be through groundwater transport.
11 JUDGE MARGULIES: This may be an opportunity to 12 take a luncheon recess. Do you know approximately how much 13 more crosa-examination you have?
14 MR. LAWLESS: I've got -- I'm about halfway 15 through I would imagine. We'll be moving from qualitative 16 questions to specific questions on the formulae used.
17 JUDGE MARGULIES: How much time would the parties 18 want for a luncheon recess?
19 MR. CHURCHILL: I don't think that we'd need more 20 than an hour.
21 JUDGE MARGULIES: Pardon me?
22 MR. CHURCHILL: I don't think we'd need more than 23 an hcur and could possibly do it in less.
24 MR. DEWEY: An hour is fine with the Staff.
25 MR. TEPER: We could take 45 minutes if we wanted ace. FEDERAL REPORTERS, INC.
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311 1 .to hurry this along. We are not on an e:< pense account over 2 here. We eat cheap.
3 JUDGE MARGULIES: We will take an hour recess and 4 make it 1:40.
5 (Whereupon, at 12:40 p.m. the hearing was 6 recessed, to be reconvened at 1:40 p.m.)
7 8
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26113.0 RT alz 1 AFTEhN00N SESSION (1:40 p.m.)
2 JUDGE MARGULIES: Please come to order. We will 3 now start with the limited appearances. I Mr. George 4 Deloach, the mayor of Waynesboro here? You may lead off.
5 Would you please take a seat at the table at which 6 the witnesses spoke.
7 MAYOR DELOACH: Okay.
8 JUDGE MARGULIES: We do have a 10-minute 9 limitations on oral appearances.
10 MAYOR DELOACH: I won't take that lona -- I won't 11 take near that long, sir.
12 I just wanted to meet with this croup and welcone 13 you to our city. Since Plant Vogtle hac been in aperation, 14 under construction in our community for the last 13 or 14 15 years, we have seen a lot of changes in our community. It 16 has meant a lot of economic growth to our area. We have a 17 new high school, new hospital, new post office under 10 construction at this time. I would just like to make the 13 point that Georgia Power has been a good neighbor and very 20 suppcrtive in all of our coinmunity projects getting ready for 21 our growth.
22 Recently, several years ago when they had a small 23 prob 1.em out there, e drug problem -- when they had a problem 24 with the drug problem, I was aware that t r. ' , jumped right on 25 this problen and were eager t o correct anything that seemed ACE. FEDERAL REPORTERS, INC.
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! O("RI 1 to be a problem in any constrinction project of this size. I 2 know there will be all sorts of problems to arise, but I have 3 faith and confidence that they have tried to improve and 4 correct anything that has arisen out there. That's about all 5 I have to say for you today. ;
l 6 I just want to welcome you to our town. I l
7 JUDGE MARGULIES: Thank you, sir.
8 Lesley Price?
9 MS. PRICE: My name is Lesley Price. I'm a former i 10 quality control inspector from Plant Vogtle.
11 JUDGE MARGULIES: Would you speak up, please?
12 MS. PRICE: Okay. I'm a former quality control O ,
13 I ns"pector f rom . Plant Vogtl e, and last year in the earl'y part 14 of the year I became concerned'over a coverup that was going 15 on out there, about the buildings that were sinking. I 16 checked the documentation and I became convinced that there 17 was a problem there.
18 I contacted Bruno Uric of the NRC, and gave him I 19 documentation and background notes that he ct'Id check.
20 Mr. Uric granted me confidentiality but then, lecs than a i 21 week later, everyone on the job knew that I had gone to the i
22 NRC.
23 I was then targeted to take the urinanalysis test, 24 as a result of a call on a 1-900 number. They told me
( 25 because of my associations with people at Plant Vcgtle, I was l
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1 going to have to take the test.
2 I waan't afraid of taking the test, and when I 3 took it, nine days later they told me I had failed the test.
( 4 I believe it's a direct recult of my contact With the NRC. i 5 And I was not fired for failing the drug test, I was fired !
6 for misconduct.
7 I don't see how the two go together. Georgia 8 Power can' answer that.
i 9 I believe that the NRC and Georgia Power are l
10 working together in eliminating anyone that is willing to 11 tell the truth about managenent and construction practices at 12 Plant Vogtle. Otherwise, why did it take seven months for
. O 13 Bruno Uric to start his investigation into what I ,had brottght ,
14 to his attention in January? His excuse was that President 15 Reagan had cut their budget; they could not afford to look ,
t 16 into the unsafe practices at Plant Vogtle.
17 And, as a result, we still don't know the results 18 of the investigation because the NRC refuses to release them 19 and it illegally refuses to release them because they have 20 to. We are now in the process of starting a suit against [
21 them.
22 I gave all my information to Mr. Urie because I l l 22 believed I was doing the right thing and that people were in 24 danger. And as a result of that I lost my livelihood. I l
, 25 have been called an addict in the newspapers. I have been l
! I i
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'~ T Jid 1 unable to find a new occupation in this area -- moctly 2 because I wac concerned. I really believed I was doing the 3 right thing.
4 I believe that this committee will grant that 5 license. I think you have already made up your mind that 6 Plant Vogtle will get their construction license and 7 operating license with no problem. And I hope that Vogtle 8 doesn't turn out to be another space shuttle, that after it's 9 already too late you are going to find out you had problems 10 that were known about beforehand and were not taken care of.
11 You may not take what I say as very serious, but r, 12 I'm one of the people who is going to appear on the Phil (j l 13 I Corahee show this Friday r.nd I guarantee the public will 14 listen if the NRC won't.
15 j And I hope some day the NRC has to answer for 16 their actions, as far as Plant Vogtle goes, and the fact that 17 they are taking none to make sure that it's safe.
18 JUDGE MARGULIES: Thank you.
19 Susan Register?
20 MS. RECISTER: My name is Susan Register. In 21 January of '85 I made several complaints to the NRC, Bruno 22 Uric. I was al.1o given confidentiality.
23 One week later I was controinted by a fellow worker 24 and told, word for word, what I had reported to the NRC.
I I 25 And on a news report, the MacNeil Lehrer hour, the ACE FEDERAL REPORTERS, INC.
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26113.0 RT alo 1 NRC lied and caid that we had never asked for 2 confidentiality. In my hand, I have that letter where they 3 granted us confidentiality.
4 We still have no idea if the NRC carea. Who is 5 watching the NRC7 Well, let me tell you I am, and anybody 6 that watches Phil Donahue will know about you guys.
7 Thank you.
8 JUDGE MARGULIES: Do you want to read that letter 9 into the record?
10 MS. REGISTER: No. It will be in the paper and it 11 will be shown on the Phil Donahue show.
12 JUDGE MARGULIEG: Charles Henry?
13 !G . HENRY: Good evening. Am I talking loud
. 14 enough?
15 My name is Charles Henry. I'm a pipetitter out of 16 Birmingham, Alabama out of local 91. I was employed at Plant 17 Vogtle in early August '05 through late November of '05. I 18 was terminated at that time. The reason given was 19 insubordination. I flied a lengthy complaint with Georgia 20 Power quality concern on the Jame day of my termination, my 21 complaint being that I was fired directly an a result of my 22 refusal to worl: in areas and in activities that were in 23 direct conflict with Georgia fower'J quality concern 24 directives and Pullman Power quality concern directives.
25 i Georgia Power quality concern people at that time ACE FEDERAL REPORTERS, INC.
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1 initiated an investigation. Approximately three weeks later 2 I received notice that they had ended their investigation. ,
3 They could not find where I had been fired for any reason 4 other than insubordination. The reasons given were that my 5 tereman did not fire me, my superintendent took the !
6 responsibility. They were looking at my accusations as far l f
- 7. as work in direct violation of standards as a separate -
8 matter. They refused to tie the two together. I objected l 9 strongly in mail. Most of my correspondence has been in !
t 10 certified mail or through Federal Express, which I have 11 ccpies for anyone that wants to care to look at them. #
12 I repeatedly offered to Georgia Power -- I have f l 13 had ' rec. tnt a nei numerous contacts with NRC. I offered to both l 14 ' companies -- both organizations, rather, to volunteer to take l 15 a polygraph test at any time. I voluntarily went on the I i
! 16 plant site, pointed out the areas in question to Georgia l
17 Power quality concern after my termination, i
l 10 I honestly feel like I made every effort to bring i
19 this to their attention in an equitable manner. I recognize :
]
- 20 that from some points of view I would be labeled as a 21 dissatisfied malcontent and former employee, but I honestly '
22 don't think that's the case.
23 When I was intorned by Georgia Power quality l
l 24 concern that they would treat my termination simply as l
( 25 insubordination, approximately three weeks after my l
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l 1 termination, at that point in time they had not questioned !
l 2 any of my coworkers concernina my accucations of inaccurate 3 work and work done in violation of control standards.
4 I, at that point, informed quality concern,
(
5 Georgia Power quality concern, that I would go directly to f
6 the NRC, which I did at that time. And I consequently, four l
7 days later than that, flied a complaint with the Department l 8 of Labor, which I have appealed and will appear before an l 9 administrative law judge early next month.
10 The NRC assured me, when I contacted them by phone i
11 initially, that they would promptly look into the matter.
12 over the peri,od of the next five or six weeks I stayed in e
13 regular contact by phone. At no time was anyone that I 14 worked with directly, other than management responsible for ;
15 my termination, questioned by the NRC.
p 16 At that point I, again, notified everybody 17 concerned that I felt like there was -- no action was being l 18 taken on my part. Frankly, I just didn't know what to do i t
19 about it.
l 20 Instead of using the phone, I called the regional ;
' 21 office in Atlanta and requested the name of the director and 1
22 address and at that point, roughly five weeks after my f
23 termination, I sent -- requested the coordinator's nano, her [
l 24 director's name, her director's address in Washington. They l
25 gave me the addresses. '
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1 Three days later on a Saturday my wife received a 2 threatening phone call while I was at work. The effect of 3 the call was that I'm sergeant somebody with the police 4 department. Your husband has been critically injured at 5 work. Do you have anyone there at home with you?
6 She responded, yes, my two children are here.
7 He said. what are their aces? She told him and 8 the connection was broken.
9 I recognl:e that this could easily be seen as 10 having no connection with my involvement at Plant.Vogtle. I 11 ,
have never received any kind of call like that. Whoever 12 called knew I was at work. Whoever called knew I was in i
13 l construction. Ar.d 1:cr it to come three days after requesting l
14 ltheaddresses for the regional director and the Washington 15 director to send them certified mail, it's just --
the 16 coincidences defy comprehension from my viewpoint.
17 To my knowledge, the IJRC has still not questioned 18 any of my coworkers. I informed them by certified mail that I
19 evidence was being tampered with. ,I had direct knowledge 20 from coworkers still on the job site. I requested their 21 assistance. They assured me they were working diligently on 22 ,
it.
I 23 <
When I fina*1y sent the certified mail, about 24 three weeks later I received a response from the regional 25 office in Atlanta stating that their general procedure was ACE FEDERAL REPORTERS, INC.
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( 1 not to question on this kind of stuff until Labor Department 2 complaints were completely taken care of through the appeals 3 system. That will be sometime next month.
L 4 Now, I would point out that initially I was told '
l 5 on every occasion that the NRC was vigorously inspecting this i 6 and the plant. resident was aware of it. Then I finally found 7 out that they weren't inspecting it at all, apparently. And l
8 that's their word against mine. ,
9 Frankly, I'm not anti-nuclear, pro-nuclear. I'm a
! 10 union employee. I'm pro-union. I worked on the job to the 11 best of my ability. I don't live in Georgia. I can honestly 12 aay if most of the complaints in the vein that mine were, and
-)
l v 13 they were successive and serio'is in nature, are handled in '
t 14 the manner that mine had been handled, I don't think anyone i
15 knows what's going on at Plant Vogtle. And I don't mean that i
, 16 critically or any other way. It's just a personal 1
17 observation. .
18 I have been unable to get a coordinated response. 1 19 From the letters received from Georgia Power, and 20 Pullman Power's representative from me, I have come to no 21 other conclusion than they are actively working together to 22 distort, in sone cases destroy evidence, harass and coerce 23 witnesses. They have done that. I have got people that will 24 back up that testimony.
l 25 Frankly, I don't know what else to do and I've got ACE FEDERAL REPORTERS, INC.
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26113.0 RT '11 1 nothing but sympathy for the people that live on thic aide of 2 Georgia, if there's ever a problem at Plant Vogtle. I 3 personally think we need nuclear oower. I don't know what 4 the ancwer is. Frankly, I'm not qualified to give any 5 ;
answers. All I can speak from is personal experience and it 6 has not been very good.
7 Thank you.
8 JUDGE MARGULIES: Thank you, Mr. Henry.
9 David W. Frambes.
10 MR. FRAMBES: My name ic David Frambes. I'm the 11 carpenters' and millwrights' business acent for local union 12 283 in Augucta, Georgia. I have been in that capacity for 13 about a year and a half now. Prior to t%1t I wir,a 14 carpenter. I am a carpenter by profession, and will probably 15 return to that trade when I leave office.
16 I first worked at Plant Vogtle in 1978. I worked
, 17 there one day then -- that was in August of '78 -- the reason 18 being, it was a lot of other carpenter work available to me 19 at that time, a lot of work closer in town to Augusta, easier 20 work where I was more catisfied working.
21 At Plant Voctie, we are pushed. They got a big 22 job to do and you can ask any carpenter out there, we cot to 23 reu11y work.
24 Returned to the plant in 1981 and went to work i
25 there. I was r. caring the end of my apprenticeship at that ACE. FEDERAL REPORTERS, INC.
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1 time. I was extremely proud to be on the plant, and to be 2 working on something of that scope. That was about the time 3 that the plant really started to take off and build up.
4 Throughout, from that period of time to this day, 5 there has been approximately 11- to 13,000 people working on 6 that plant. It's probably the biggest job going in the 7 United States.
8 Talk about the cost of the piant, 08.4 billior..
9 That's been quite a boon to this area and to the state of 10 Georgia. That's a debt that will have to be repaid. It's 11 going to have to be repaid by the consumers and users of 12 electricity, and rightly so.
13 I enjoy the luxury of using electricity. I don't 14 think somebody else should have to pay for it, for me to use 15 it. I think the nuclear power plant is the way to go. I 16 think it is a very progressive step taken by very farsighted 17 people that can see the need for the power and made a 18 l positive step to fulfill that need.
19 I'm extremely thankful that they chose this area 20 to put it in, as this area needed it. This area had been a 21 prime area to be industrially developed due to the 22 overabundance of available workforce. It had a history of 23 high unemployment rates, at basically farm-wage rates. That 24 led to a working class of basically impoverished people.
23 All that has changed since the introduction of ACE FEDERAL REPORTERS, INC.
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I construction at Plant Vogtle here, pumping the money into l l
- 2. this area's economy. ;
3 I've got 1100 members of the carpenter's local in 4 Augusta. 900 of them are employed at Plant Vogtle. The ;
5 other 200 have employment, all they need, all they want, all f
, 6 they can find, building houses, shopping centers, malls; all j 1
7 the service establishments that are built in connection with 8 economic prosperity.and growth. }
9 We've heard from a committee today, Campaign for a 10 Prosperous Georgia. I don't know what the penalty for l
l 11 perjury would be. If I got up here and lied to you today, I ;
l' l 12 don't know what I would be faced with. But I feel that '
! ( -
13 committee his perjured itself by ascuming that name.
14 If they were truly for a prosperous Georgia, I [
l l ,
j 15 would think they would be in favor of a nuclear power plant. ;
16 The nuclear power plant is going to be necessary in a 17 prosperous Georgia. It attracts new industry, the !
la availability of power. The success of the power company is i
19 obvious to me to be in the best interests of the state of l 20 Georgia.
21 What do they want? Do they want to disallow the ;
i !
22 18.4 billion cost? That's a debt that has been incurred and l 23 will have to be paid. ;
24 Would they have this construction halt, deny that t 25 plant to go into operation and deny the power company to pay .
l -
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1 off that debt? What would happen? What would you have, a 2 bankrupt power company? Would that be in the best interests 3 of a prosperous Georgia? I don't think so.
4 These people who voice their concerns and 5 complaints today, these three that preceded me, I am sure 6 they have genuine concerns and complaints. We have had 7 hundreds of genuine concerns and complaints. In my job as 8 business rep, I have handled these throuch the grievance 9 procedure. Their quality assurance complaints are actually 10 solicited on the job site. Where else in the world have you 11 got a job with an employer who says: Tell us all your
~~. 12 complaints. Tell us what is wrong so we can fix it. They L3 can't fix it unless they are told.
14 I would think that these people, addressing the 15 NHC and the public here today, would, in the best interests 16 of everybody, address the problems so that any problems that 17 are found can be corrected and we can get on with the 18 l business of having a prosperous Georgia. Get that plant on 19 line, have it producing power, nake sure it's safe.
20 The power company is ridiculed for having a 08.4 21 billion price tag on that plant. I think part of the reason 22 for the 88.4 billion is because that power plant has got to 23 be built absolutely 100 percent perfect and they've got to be 24 able to ensure that these theoretical catastrophes will not 25 happen.
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~7r 325 1 It is qilite a job, you know. You got 13,000 2 people out there. There's 13,000 people making probably 3 around S30,000 a year for a full year's work, working hard to 4 get that place built. You are bound to have hundreds of 5 problems. People with problens, grievances, things go wrong, s people make mistakes. All this has to be found out so it can 7 be fixed. -
3 What I have always thought of the NRC was that th:
9 Nhc was like a watchdog, or an overseer. to make sure that 10 this happens; that all the problems are corrected, that 11 nothing goes wrong, that the conpany is responsible; that 12 they do in all cood faith try to ensure there will be none of 13 these problema in operation.
14 What we've had here over the years, since Georcia l
15 Power has been under construction, is constant abuse against 16 l the power company and NRC and the media, whipping up -- a 17 prire example, the Phil Donahue show.
10 You are going on Phil Donahue, fine and dandy, 19 go. But for yeara we have been watching the papers in 20 Atlanta, and even here in Augusta, where I would think so 21 close to home in Augusta, this newspaper ar.d our television 22 people would be close enough to see what is going on at Plant 23 l Vogtle.
24 What do they do? They print and publish 25 extraordinary newJ: A d etag problem at Plant Vogtic. That's ace. FEDERAL REPORTERS, INC.
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26113.0 "HT 526 1 no surprise that there would have been a drug problem at 2 Plant Vootle because there's one throughout all of society.
3 They have not printed that Plant Vogtle and 4 Georgia Power has taken the necescary steps to completely 5 dissolve that problem. There is no problem at Plant Vogtle 6 with drugs now.
7 I'd like to challenge the media -- well, of course 8 it's not -- I don't have the authority to open Plant Vogtle':
9 doors to the media. I'd recommend the power company open the 10 doors to the media, invite in the television crews, let them 11 go out and fii.d all these alleged drug users, drunks, 12 alcoholics, what have you. There are none at Plant Vogtle.
O 13 There are les: people with a drug problem at Plant 14 Vrgtle than you'll find, qertainly, in your school system, 15 probably in church, because the people with problems have 16 i been identified and removed. That's been a constant problem 17 l for me, because some of my people chose to uce drugs -- a 10 j few.
I 19 1 JUDGE MARGULIES: Mr. Frambes, that just about i
I 20 completes your time. We have a lot of other people who wich 21 to speak here today.
22 Thank you.
I 23 MR. FRAM3ES: Please scratch that last statement 24 about my people using drugs. You are talking probably less
)
-> 25 than half a percent, you know? I got good pecple.
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1 JUDGE MARGULIES: Thank you.
'2 ,
J.W. Bell? ,, ,
j 3 MR. BELL: I am J.W. BeYl, president of the local 4 chapter of the NAACP here in Burke County. And, 5 incidentally, I have an article here -- an article in our 6, local newspaper, "The True Citizen," the early bird, talking' 4 e ,
7 about this particular event here this afternoon. And, of 8 course, in my going to the. post office a few minutes ago, I m f 9 asked one or two persons: What do they think about Plant 10 Vogtle? Of co trse, one woman told me: What do you mean, my 11 husband works out there. So we are very pleased that Plant 12 Vogtle has selected Burke County as its site.
( _s ,
13 I'm a resident of Burke CoQnty. I was born and 14 reared here, had to go away to.get an education, but I came 15 back and of course I have enjoyed working here.
16 Prior to Plant Vogtle, back in the late '60s and 17 the early '70s, there was poverty in Bu'rke County ,
18 everywhere: Poverty, poverty, poverty. And of' course when 19 you have a lot of poverty', you have a lot of crime. And 20 crime was at a very high rate at this particular time.
21 Since then, the amount of crime has decreased and, 22 of course, the number of unemployment has decreased.
,a 23 I heard a group'ca11\themselves, " Campaign for a 24 Prosperous Georgia." I want to change this. I want to say
("3
(_) 25 it is a Campaign for a Poorer Georgia, because, prior to the t
i 4 )
- l ACE-FEDERAL REPORTERS, INC.
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26113.0 RT 32e i early '70s, we had nothing but poverty and of course I want 2 to say this, that 60 percent of people between the ages --
3 blacks between the ages of 18 and 35 were unemployed here in 4 Burke County.
5 This plant has brought better homes to the 6 community, better living conditions, better school 7 situations, better church attendance. I happen to be a 8 Baptist minister. Those of you who are, you can be in 9 agreement with me. And, of course, we have living conditions 10 that have been improved here in Burke County, and I am a 11 living witness to this fact. And to address the NRC, we hope 12 that you vote favorable for the licensing of the Plant
~
13 Vogtle, Georgia Po' der, here in Burke County.
14 Thank you very kindly.
15 JUDGE MARGULIES: Thank you, Mr. Bell.
16 Susan Macken?
17 MS. MACKEN: Good afternoon. I want to thank you, 18 sir, for allowing public participation this afternoon rather 19 than tomorrow, as I had arranged a day off from work today 20 and would be unable to be here tomorrow, so thank you for 21 arranging that.
22 i My name is Susan Macken, and while I'm probably l
23 lnot a very polished public speaker and I'm certainly not an 24 expert witness, I am a native of Burke County and spent the 25 lfirst18yearsofmylifehere.
I I
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1 I have been, and continue to be, very concerned 2 about the problems with Plant Vogtle. After hearing the 3 testimony that has been presented thus far, I remain 4 unconvinced that Georgia Power can assure the residents of 5 Waynesboro, Burke County, and the surrounding area of the 6 safety of that plant.
7 The efforts that Georgia Power has made, in my 8 opinion, to mislead and misinform the public, coupled vith 9 the technicalities and bureaucratic entanglement of these 10 hearings, has not provided for a public forum, for issues to 11 be debated concerning Plant Vogtle, fs 12 Two years ago I just happened to be in town, once
(._) 13 again visiting my family, and heard on the Augusta ne.ws 14 station of a public meeting that was to be held here to 15 discuss Plant Vogtle.
16 No one in Waynesboro knew about that -- well, I 17 won't say no one -- very few people knew about that. And, 18 again, public involvement here is very, very linited.
19 I do not feel that I speak alone when I say that 20 Plant Vogtle is certainly an unnecessary and also an unsafe 21 addition to Burke County.
22 Problems, there are certainly problems, too 23 numerous for me to go into here. ' lou have heard some cf them 24 already and you'll hear additional problems as this tO
(/ 25 continues. I just an not completely satisfied that Georgia l
l ACE-FEDERAL REPORTERS, INC.
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26113.0 RT Jau 1 Power can assure us of the saf-ty of that plant. I urge you 2 to examine the information that is presented here and I urge 3 you to deny them an operating licence for Plant Vogtle.
4 Thank you very much.
5 JUDGE MARGULIES: Thank you, Ms. Macken.
6 I.M. Lively?
7 MR. LIVELY: Mr. Chairman, my name is Q.U.
8 Lively. My writing is a little off, I suppose. That's a 9 strange combination of initials, but that's it, just the 10 same.
11 I'm Q.U. Lively. I was born and raised in East 12 Burke County near the present site of Plant Vogtle.
13 I'm one of these gone broke farmers. I was 14 foreclosed on and had to move and translocate.
15 I could have went -- I had an opportunity to go to 16 Florida; Denver, Colorado; Atlanta, Georgia; or West Burke 17 County. But I chose to remain in East Burke County. I moved 18 a little closer to the plant than I originally was.
i l
19 There are other farmers there that have done the l
20 same thing. And I say this to let you know that the local 21 population has no fear of this plant. They think it's being 22 built safe and they are not panicking.
23 Now, when I was born and raised out there we had 24 no electricity. You drew water out of a well with a bucket.
25 You pumped it with a hand pump and you carried kerosene for ACE-FEDERAL REPORTERS, INC.
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1 your lamps.
2 Then we got a chance to get electricity. And we 3 had this doomsday crowd, I call them -- this stuff will kill 4 you, it only takes one-tenth of an amp, and I didn't know 5 what an amp was or anything. But I knew I wanted that 6 electricity. And we have had to sign petitions and there was 7 a controversy, but we got the electricity and I was a grown 8 man before I knew.why those people didn't want us to have 9 electricity. Those were the people who were selling 10 kerosene. So, beware.
11 And there's another crowd. When I was in the 12 second or third grade, 7, xs-)
we studied abou.t Little Red Riding 13 l Hood and the three bears, but there was also a story in there 14 about the barnyard critters. And there was this little hen, 15 and she was the aristocrat of the barnyard. She had degrees 16 from everywhere and she started running and hollered: The
> 17 world is falling in. You remember the story. And one by 18 one, she picked up enough support -- and I called these the 19 fellow travelers -- and they convinced the whole barnyard to 20 just start running.
21 Those folks are here today.
22 A little later on in life we had a chance to get 23 something called DDT. It was a good chemical. They sprayed 24 it in our houses. And it got rid of such things as f')
xs 25 mosquitoes and flies and bedbugs and a lot of folks don't ACE-FEDERAL REPORTERS, INC.
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26113.0 dT 332 1 know what malarial fever is today, but if you were born and 2 raised in Burke County and you are 60 years old or older, you 3 had malarial fever and you know what a bedbug is. But if you 4 are 40 years old or younger, you have never seen any of these 5 things. And DDT is what got rid of it.
6 Now, sometimes, well, due to the doorsday crowd, 7 Rachel Carlson and her book called " Silent Spring," DDT was 8 taken away. This is the same crowd. The doomsday -- it will 9 '
kill you, get rid of it. It will kill everybody.
10 Well, they are still using it in the world and 11 everybody is not dead.
12 Now, at this time they are spreading these same 13 ! , tales, going to poison the groundwater, pollute the 14 atmosphere. I suggest to you that there are more people 15 dying of skin cancer from natural radiation by laying in the 16 i sun than die from exposure to atomic radiation that escapes 17 from a plant. But you hear nobody complaining about the --
18 the good has to outweigh the bad. We know there's a 19 possibility that something might happen one day. The 20 possibility could have happened from other things. But we 21 have got to have electricity and this is the way of the 22 future.
23 Now, as far as the -- anything to indicate that I 24 want an unsafe plant, nobody wants that. But I'm convinced j 25 that it will be safe.
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'RT a33 1 We've got a enurch in East Burke County and a lot 2 of the construction workers come to this church. We've cot 3 pipefitters, carpenters, welders, cement -- all those --
4 although those folks about gone -- we have truck drivers.
5 You name them, we've got them. And they will tell you that 6 this is the safest job that they have ever worked on. That 7 the type of work is better, it's stricter. They have no 8 qualms about it. They don't mind calling the dogs and blood 9 -- you know; the uri.nanalysis test, they will tell you they 10 have no objections to that. But there's some that think you 11 are infringing on cheir civil rights when you require these 12 sort of things. But most churchgoing -- all of them -- none I
13 of the ones that I know object to that.
14 So there's three things, summing it up the three 15 things: Some folks testified here about a year ago that it 16 ,
was environmentally incompatible and ugly and all that sort 17 of thing. But I live in the shadow of the cooling tower.
18 When the sun comes up, it cones up behind that cooling 19 tower. And i t's big at the bottom and little in the middle 20 and it flares out at the top. It's shaped just like Dolly 21 Parton and she ain't ugly.
22 (Laughter.)
23 So. rememoer that ugly as well as beauty is in the 24 eye of the beholder. Beware of the folks that's selling
.'^ !
1s 25 kerosene. And look out for the fellow travelers.
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1 Thank you.
2 JUDGE MARGULIES: Thank you, Mr. Lively.
3 Charles E. Bell?
4 MR. BELL: My name is Charles E. Bell. I'm the 5 business manager of the Sheetmetal Workers Local 86.
6 I have been a union business agent since 1978, and 7 I have been involved in Plant Vogtle since that time.
8 We appreciate the fact that Georgia Power had the 9 initiative to put the drug program, the alcohol program, and 10 quality concern into effect. Personally, I don't want any of 11 my members working by somebody under the influence of drugs 12 or alcohol when it comes to a safety hazard, i: ,
13 We have no objections ~ to those programs.
14 My personal experience in Plant Vogtle, I have 15 been a construction worker for 25 years. I have been a union 16 business agent for eight years. And I have been involved in 17 Plant Vogtle for that same length of time.
18 I see some efforts by the power company to have a 19 Cadillac-type powerhouse, if you want to refer to it as a 20 Cadillac.
1 21 I have worked in other areas on construction jobs l
22 personally. I have seen some efforts by the power company on 23 quality -- you know, this is not the only power company that 24 Georgia Power has ever built. They also built Plant Hatch.
25 It has been on the line for 12 years, no problems.
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'26113.0-g- 335 Q]RT 1 Personally, I've got some people down there right now that 2 are working in Plant Hatch.
3 I have seen some efforts by the power company at 4 Plant Vogtle to do things that other construction job sites 5 have not done in the past 25 years I have been a construction 6 worker. The safety program is second to none in this 7 country. They care about the well-being of their people that 8 they employ.
9 When you talk about a job that hires 12,000 10 people, you are going to have some minor problems. The drug 11 situation on that project at one time was getting to a
~s 12 , critical situation. They took steps to prevent and get rid
. 13 i of the dring situation. I appreciate that. I don't want any 14 of my people killed because of irresponsible people. So we 15 do apprecte it.
16 I appreciate the amount of work that has been made 17 available to my construction workers that have been working 18 on that project for approximately six years.
19 I am a responsible business agent. I care about 20 my members and I care about the environment and I care about 21 Burke County. I'd have no qualms about living right outside 22 of Plant Vogtle. I'm sure that they didn't spend $8.4 23 billion without going and doing the proper things to assure 24 this community that it would be a safe-type powerhouse.
(O s_/ 25 Georgia Power people are very smart. They are ACE-FEDERAL REPORTERS, INC.
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'RT 336 1 very educated. And I know some of the people in higher 2 positions personally because I have been involved in that 3 project for eight years. We appreciate the efforts by the 4 power company to give a quality-type job.
5 The welding situation on that project, you have to 6 be one of the best to be employed at Plant Vogtle. I don't 7 mean just be a welder, you have to be the bect. I refer a 8 number of welders to that job; mediocre welders don't make 9 it. The very best make it. That assures us that we are 10 going to get a quality-type weld in the end.
11 The unions -- my local, local 86, we have a 12 four-year apprenticeship pregram that we train our 13 apprentices to k'now their trade, and the power company has 14 initiated a program -- programs to be sure that the people ,
15 that they use on that project are qualified type people. I l
16 '
got confidence in the power company. I have got confidence 17 in Plant Vogtle. And my experience with the drug situation 18 -- and I have gone through grievance procedures and all the 19 nine yards of all of it -- I have never seen a person that 20 was termina ted for cause of drugs guilty in his own opinion, 21 no matter what determination comes out of it. They want to 22 blame everybody for their own weakness.
23 I don't drink and I don't do drugs, so I have no 24 sympathy for those type people, but I appreciate the fact
- 25 that the power company did initiate these programs to assure ACE-FEDERAL REPORTERS, INC.
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1 quality on the job and the safety of my people that have to 2 work-down there.
3 I have no qualms. I would live right outside the 4 shadow of that thing. I got that much faith in it.
.5 That's about all I got. Thank you very much.
6 JUDGE MARGULIES: Thank you, Mr. Bell.
7 Dennis Hoforth?
8 MR. HOFORTH: I'll wait until tomorrow morning, if 9 that's all right.
10 JUDGE MARGULIES: W.H. Harper, Jr.?
11 Clifford E. Lewis.
12 (Discussion off the record.)
~O 13 MR. LEWIS: My name is Clifford Lewis. I was 14 raised in Burke County, went to school here, went to the 15 University of Georgia and lived in Thompson, Georgia, 42 16 miles away, for about six years. I am presently back in 17 Waynesboro working at the bank here, a local bank.
18 Earlier you had a girl that I went to school with 19 talk to you. She said she wasn't satisfied of Plant Vogtle 20 and whether it was safe.
21 I had a lot of these concerns. A lot of my 22 friends that have families here in Burke County or are ;
23 employed at riant Vogtle. they have assured me that the plant 24 being built is state of the art. This plant -- I had still 25 reservations after talking with them. You want to find out ACE-FEDERAL REPORTERS, INC.
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.v 1 for yourself. If you are interested enouch about it, you 2 do. I was fortunate enough to be able to ao on a tour of the 3 plant and ask my questions, and the Georgia Power people were 4 very professional and had the answers and went beyond just an 5 answer to reassure me of the safety of this plant.
6 This is good for Georgia. This is what we need 7 and I'm happy to say it's in Burke County. It's important to 8 -Burke County for this plant to go on line, and I think all 9 Burke Countians that live here that are interested in Burke 10- County are ready for it to go on line.
11 Thank you.
7s 12 JUDGE MARGULIES: Thank you, Mr. Lewis.
b 13 Roy Chalker, Jr.?
14 MR. CHALKER: My name is Roy Chalker, Jr. I'm a 15 lifetime resident of Burke County, president of Chalker 16 Publishing Company and publisher of "The True Citizen" which 17 is the county's only newspaper. I served as mayor of 18 Waynesboro from 1976 to 1980, and have served three terms as 19 president of the Burke County Chamber of Commerce. I tell 20 you that because in those capacities, and in others, I have 21 had the opportunity to work with officials and employees of 22 the Georgia Power Company at almost every level.
23 l The most cutstanding prevailing characteristic I 24 have encountered through those experiences has been the sense 25 of community responsibility displayed by the men and women of ACE-FEDERAL REPORTERS, INC.
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26113.0 HT .2 a 3 1 Georgia Power. Whether it be the construction of 2 multimillion dollar power transmission lines or simply the 3 trimming of trees on their right-of-way, the company has 4 always been considerate of the needs and feelings of those 5 residents and property owners who were affected.
6 This is not a company which would suddenly abandon 7 its principles of many decades of service to the people of 8 this state and construct a nuclear power plant which is 9 unsafe.
10 I can tell you from experience that, since Plant 11 Vogtle was first announced some 15 years ago, the safety of 12 our community has not been a common topic of conversation 13 here. Becauce of what we know about the conpany and its 14 people, it has been generally assumed as fact that the plant 15 will be constructed and operated with safety as the most i
16 important factor.
17 In closing, I would add that I belong to a local 18 health club, to which a number of the construction workers 19 come to work out on a regular basis. In their conversations 20 among themselves, I have noticed the pride they take in the 21 quality and productivity of their work. Not once have I ever 22 heard one express concern about safety problems due to poor 23 workmanship.
24 Thank you very much.
25 JUDGE MARGULIES: Thank you, Mr. Chalker. Paul I
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1 Shivers, Jr.?
2 MR. SHIVERS: I am Paul Shivers, Jr. I'm a
~
3 partner in x real estate business here in Waynesboro. I was 4 born in Burke County and I lived my 46-year life here except 5 for about four years in the Augusta area. I appreciate the 6 opportunity to appear here, but my observation is that a lot 7 of us are overstepping our qualifications here today.
8 If I decide I want to fly across the United States 9 I go to Auuusta and I get on an airplane. If I had to 10 explain to you why that thing was going to work, I don't 11 think I would be very successful. But I have faith that the g3 12 people who built it are reputable, dependable people and that
~
13 '4 hen I get on it,' it's going to work.
14 If you told me you were going to put motors on a 15 big pile of tin and get 150 people on it and fly them across 16 the ocean, I'd have very serious reservations about the fact 17 that that's going to work. And I put myself in the same 18 category about Plant vogtle. I'm not qualified to tell you 19 whether or not tnat plant is safe.
20 But I do want to tell you that I've got a lot of 21 friends and family working out there in the real estate 22 business. For years I dealt with people who are employed at 23 Plant Vogtle at all levels. I deal with people in this 24 county every day of my life. I have never heard a sincere 25 reservation about Plant Vogtle in the streets of Waynesboro l
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] or in Burke County from the local people.
2 All the crafts people, the engineers, the 3 supervisors, the quality control inspectors, the people I 4 have had an opportunity to deal with who have come from all 5 over the United States into our area that I've dealt with in 6 a real estate capacity, I have been impressed with these 7 people. I'm impressed with their feelings about this 8 project. And I'm the same way about Plant Vogtle that I am 9 about the airplane. I'm fully convinced that it is in the 10 hands of people who know a lot more about it than I do, and 11 these people seem satisfied and therefore I am.
I 12 i I have no reservation with living in Burke County
~
13 I with Plant Vogtle, and the people who are actually out there 14 doing the work don't seem to nave any reservation. So I I
15 voice my unqualified support for the plant and I welcome it 16 as a neighbor here in Burke County.
17 Thank you.
18 JUDGE MARGULIES: Thank you, Mr. Shivers.
19 We have heard all of the people who have signed up 20 and wanted to speak here today.
21 MR. TEPER: Mr. Chairman?
22 JUDGE MARGULIES: I can't identify -- is that you, 23 Mr. Taper? Ol:ay .
24 MR. TEPER: Yes, it is. I believe not everyone t- 25 has had the opportunity -- or everybody signed up. I would ACE-FEDERAL REPORTERS, INC.
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- T 392 1 like to ask if it's appropriate, if anybody else would like 2 to speak at this time?
3 JUDGE MARGULIES: We set aside one hour. We still 4 have five minutes. Is there anyone else who wants to speak 5 at this time? You may step forward.
6 MR. DEUTSCH: My name is Howard Deutsch. I 7 originally came to this hearing to be -- to testify for the 8 Intervenors on the AGC0 solenoid valve contention. Because 3 of the constraints of my professional work, I'm not going to 10 be able to stay any longer than today and I would like to 11 enter a statement now, just as a public citizen, realizing 12 this won't be entered into the formal record.
13 We contended originally that some of the equipnent 14 as being environmentally qualified at Plant Vogtle may, in 15 fact -- may not be qualified.
16 For example, in 1983 there was a board 17 I notification issued, summarizing Staff investigation into 18 Franklin Research Center tests on solenoid valves.
19 JUDGE MARGULIES: Excuse me, Mr. Deutsch, before 20 you go on.
21 Mr. Teper, are you saying you are not going to 22 produce Mr. Deutsch in this proceeding?
23 MR. TEPER: My understanding from your ruling
-s 24 earlier today was that you did not think that it would be 25 appropriate for Mr. Deutsch to present his testimony without ACE-FEDERAL REPORTERS, INC.
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26113.0 RT 34J 1 the NRC Staff having their witness here.
2 JUDGE MARGULIES: I didn't say today. I said in 3 this proceeding.
4 MR. TEPER: If it were possible to dismiss the 5 groundwatar contention today, we would like to have 6 Mr. Deutsch testify.
7 JUDGE MARGULIES: Why can't he appear as was 8 originally proposed on Thursday?
9 MR. TEPER: That was never originally proposed. I 10 have not been able to find that in the transcript.
11 JUDGE MARGULIES: Did you look at the transcript?
12 MR. TEPER: No, I have not.
~
13 JUDGE MARGULIES: How could you find it if you 14 ,
didn't look at it?
15 MR. TEPER: Because it was clarified by 16 Mr. Johnson, who took part in the conversation, that tha t was 17 not in the transcript. When you made your ruling, you agreed 18 with both Mr. Bordenick and with, I believe, myself, that the 19 statement was made that as soon as -- after the groundwater 20 contention, we would go to the solenoid.
21 I am not at all sure that the statement was made 22 that solenoid would be taken up on Thursday.
23 JUDGE MARGULIES: According to your statenant, 24 then, the possibility was that it could be taken up -- excuse s
x> 25 me. Do you have the transcript here?
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1 MR. CHURCHILL: Your Honor, we do not have a copy 2' of the transcrip't. We were present.
3 JUDGE LINENBERGER: I loaned ny copy to the court 4 reporter so there-is a copy close at hand.
5 JUDGE MARGULIES: We'll take a short recess.
6 (Recess.)
7 JUDGE MARGULIES: Back on the record. I have 8 before me the transcript of the prehearing conference that 9 was held on Tuesday, March 4, 1986.
10 Mr. Johnson is quoted as saying, "Mr. Teper could 11 not be with us and he asked me to represent -- and it says 12 " time" but evidently it means "him."
. 13 At page 215, on page 215, Mr. Johnson is quoted as 14 saying, "Okay, I understand. Thank you."
15 Relating to all of this, it sounds as if the 16 proceedings would be wrapped up next week, and I wonder if 17 for the convenience of Dr. Deutsch it would be possible to 18 set a time, for example on Thursday, for the beginning of --
19 thic ,ge'ts back to the schedule -- I guess I'm suggesting an 20 amendment to the schedule but to aet a time certain for that 21 subcontention to be considured 10.5, to be considered either 22 on Thursday or Friday.
23 Judge Margulies: "Do the parties have any problem 24 with that?"
25 Mr. Joiner: -- Mr. Joiner represents Applicant --
t i
l l
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1 "I would concur with Mr. Johnson that there is a fair
- 2. likelihood that we will be able to conclude that evidentiary 3 hearing next week. Rather than, however, set up a specific 4 -
time for Mr. Deutsch to appear, and thus interrupt ongoing 5 testimony of a panel or of a witness, I would propose, 6 instead, that we simply take Professor Deutsch out of turn."
7 Judge Margulies: "Do you have any problem with 8 that, Mr.~ Johnson?"
9 Mr. Johnson: "No, I don't. So that, for example, 10 if we said he would appear Thursday morning, that he might be
-11 the lead off witness, either in the morning or after lunch?
12 Is that consistent with what you are saying, Jim?"
13 Mr. Joiner: "What I was trying to say is, after we 14 finish the testimony on Contention 7 we can then go to 15 Contention 10.5, which I think, based on what we have talked 16 about, is likely to accommodate your schedule."
17 Mr. Johnson: "Okay, that would be acceptable to 18 me."
19 Judge Margulies: "Do you have any problem with ,
20 that, Mr. Bordenick?"
21 Mr. Bordenick: "No, I don't. That has certainly 22 been done before and we could certainly, I'm sure, 23 acccmmodate Mr. Deutsch."
24 Judge Margulies: "The Board has no problem with 25 that. Is there anything further?" And then the transcript l
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2 This hearing has been scheduled for a two-week 3 period. It has been scheduled for this week and if need be 4 scheduled for next seek. If need be, we can hear Mr. Deutsch 5 next week if he can't be accomodated this week. I just 6 wanted to make it clear for all of the parties that we want 7 to hear all of the witnesses, but it has to be within t'ie 8 time scheduled, within the hearing period.
9 If Mr. Bordenick is unable to proceed at this 10 time, the'n we can schedule Mr. Deutsch for a time certain 11 within the hearing schedule.
, 12 Is there any problem with that?
13 MR. TEPER: I would like to ask Mr. Deutsch at 14 this time if it's possible for him to appear sonetime next 15 week, if -- excuse me, Mr. Chairman -- would that be if the 16 hearings were still continuing? If we finish with 17 groundwater and dose rate effectJ, would that mean the 18 hearings are over? Or if we are unable to produce Professor 19 Deutsch?
20 I don't want to run into -he same problem as the 21 telephone conversation. I -- will we be able to put 22 Mr. Deutsch en the ctand at any time within the next two-week 23 period?
24 JUDGE MARGULIES: Let's hear f r om Mr. Deutsch in
\
25 terms of his availability.
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_N 1 MR. DEUT 3CP: I will make every effort to try to 2 schedule a time a: soon as I can. I really am very pressed 3 for time and I took off today with the anticipation --
4 apparently this was not, you know, completely communicated to 5 me exactly what the time schedule was. It's not -- I didn't 6 know of any published schedule. I anticipated that I could 7 talk today.
8 I'll try to work with Mr. Teper.and work out a 9 day, as soon as possible. If it's any way that I can 10 possibly get the time off, I will.
11 JUDGE MAPGULIES: When you say "the time off," do 12 you mean this week?
7s d 13 MR. DEUTSCH: Yes, this week.
14 JUDGE MARGULIES: Is there any reason why you 15 can't be accommodated at a time certain this week, 16 Mr. Bordenick?
17 MR. BORDENICK: No problem. Any day after today 18 he can be accommodated this week.
19 JUDGE ftARGULIES: Mr. Churchill?
20 MR. CHURCHILL: That would be okay with 21 Applicants.
22 MR. TEPER: That sounds fine, Mr. Chairman. I 23 uculd just point out that according to your reading of the 24 transcript -- I want to make sure it's not me being a bit 25 thickheaded here. Is it not true that it's not as clear as ACE-FEDERAL REPORTERS, INC.
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2 JUDGE MARGULIES: If you mean by that wac Thursday 3 a date certain, the answer is no.
4 MR. TEPER: Okay. Thank you, sir.
5 JUDGE MARGULIES: Let's get set up with 6 Dr. Deutsch first.
7 When could you find out, Dr. Deutsch? Could you 8 find out before the day is over and let us know?
9 MR. DEUTSCli: I can know tomorrow. I don't think 10 I'll be able to know today but I'll make every effort to find 11 out today. If not, it would be tomorrow that I would know.
12 I know I can't be here tomorrow. But I can -- if
,13 I can dh it this week, it would be Wednesday or Thursday.
11 JUDGE MARGULIES: Thursaay or Friday? .
15 l MR. DEUTSCH: Thursday or Friday. Excuse me.
16 JUDGE MARGULIES: Is it your understanding that if 17 the witness can't make it this week, then it will either go 18 over next week or be concluded? That is, he will make it 19 either this week or next week or his testimony will be 20 foregone?
l 21 MR. TEPER: That is my understanding of the rules 22 i of this procedure, that if he cannot tectify at this hearing, 23 that his prefiled testimony is invalid because of his 24 inability to be cross-examined.
25 l MR. BORDENICK: Judge Margulies, could I make a ACE-FEDERAL REPORTERS, INC.
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~RT a49 1 request? I think it might be helpful if the parties would 2 get together a few moments and see what we can work out among 3 ourselves. I have a few ideas in mind. I'd rather not 4 express them on the record until I talk to the other parties, 5 until we can come to some mutually acceptable -- I think 6 there's several ways of going and I would like to explore 7 those options with the other parties and see if we can come 8 up with a consensus.
9 JUDGE MARGULIES: You may discuss it. We will 10 wait right here for your determination.
11 (Discussion off the record.)
12 JUDGE MARGULIES: Back on the record.
13 Mr. Bordenick?
14 MR. BORDENICK: Yes. If it please the Board, the 15 parties have co6ferred and Staff made a suggestion which the 16 other parties are amenable to -- to following, and I'll now 17 propose it to the Board. If I misstate any part of the 18 agreement I'm sure the other parties will make that known to 19 the Board.
2G It was the Staff's hope that we would start 21 Contention 7 and run through it until we finished. However, 22 I have conferred with the Staff people on that contention.
23 They are willing to interrupt on that contention, as are the 24 other parties. We would put Dr. Deutsch on this afternoon on 25 l contention 10.5.
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'RT 550 1 If the Board will recall, last week during the 2 course of the prehearing conference, Applicant indicated that 3 they were going to conduct voir dire of Dr. Deutsch, and at 4 the conclusion of the voir dire they were going to make a 5 motion to strike his testimony. That would necessitate a 6 ruling by the Board on that motion.
7 If that motion is successful, that is the end of 8 Dr. Deutsch's appearance. If it's unsuccessful, then the 9 Staff is willing to proceed with cross-examination. However, 10 both Mr. Churchill and I would need approximately a 10-minute 11 recess to prepare for all this. He to prepare his voir dire 12 and for me to go over my previous notes from last week in 13 order to attempt to conduct cross-examination this 14 afternoon.
15 This is an attempt to accommodate Dr. Deutsch and, 16 as I say, the parties are all agreeable to it. If they have 17 anything to add I'm sure they will, and I would submit that 18 '
as a proposal to the Board.
19 JUDGE MARGULIES: What time do you envision 20 concluding today, if the motion to strike is not granted?
21 'MR. BORDENICK: It's now 5 after 3:00. If the 22 Board grants the parties' suggestion, as I indicated 23 Mr. Churchill and I would need approximately 10 ninutes, that 24 would mean we would start at 3:20. I think, all things taken 25 into account, we could fir.ish at 5:00 or shortly thereafter.
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" "; T :1 1 MR. CHURCHILL: I would agree that we could 2 probably finish up by 5:00.
3 JUDGE MARGULIES: What does that do to 4 Mr. Lawless' schedule?
5 MR. TEPER: One minute, Mr. Chairman.
6 Mr. Chairman, Professor Lawless would be available 7 tomorrow if the hearings ran into tomorrow for groundwater, 8 but he is available for the rest of today after Mr. Deutsch.
9 JUDGE MARGULIES: Tomorrow, you understand, we are 10 supposed to take limited appearances from 9:30 to 11:30 and 11 in the afternoon have a site visit, and that we expect to 12 deal with the contention, if there aren't that many limited
~'
13 appearances made in the morning. But the morning is 14 , scheduled for limited appearances and for site visit in the 15 afternoon.
16 MR. TEPER: We have a slight problem with tomorrow 17 morning for Professor Lawless, but he is available at any 18 j other time, other than the morning session.
19 Tomorrow afternoon is definitely scheduled for the 20 site visit. He is available all day on Thursday.
21 MR. CHURCHILL: Your Honor?
22 JUDGE MARGULIES: Yes, Mr. Churchill?
23 MR. CHURCHILL: The Applicant is very flexible on 24 a number of things. Perhaps I could be of help. I don't
_ 25 think my voir dire of Dr. Deutsch would take more than 15 ACE-FEDERAL REPORTERS, INC.
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1 minutes. I would have very little, if any, cross for him if, 2 as a result of the voir dire, I either did not make a motion 3 to have that testimony excluded or I did-and you denied it.
4 One way to proceed -- I haven't talked with 5 Mr. Bordenick -- I could probably go ahead with the voir dire 6' right now and then take a 10-minute break, which would allow 7 you to deliberate on my motion, if I made one, and 8 Mr. Bordenick to do his preparation.
9 As far as tomorrow and the next day, we can fill 10 in time by presenting direct testimony of either panel. They 11 would not have to be cross-examined right at that time but we 12 could establish -- get the direct out of the way and get it 13 ,
on the r'ecord.
14 I think we are fairly flexible on just about any 15 other aspect of the proceeding for this week.
16 If we had time -- if, for example, we were able to 17 finish with Dr. Deutsch today, have time tomorrow for 18 something and Mr. Lawless wasn't available, then tomorrow we 19 could present our direct testimony on either or both of the 20 other two contentions and proceed in a reasonable way for 21 cross-examination of those two panels on Thursday or Friday, 22 or even part of tomorrow.
23 JUDGE MARGULIES: We will proceed with Dr. Deutsch 24 at this point.
( 25 MR. TEPER: Intervenors would like to thank the ACE FEDERAL REPORTERS, INC.
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'R I 22 1 cooparation of all the parties. Ne understand how diff. cult 2 it is to maneuver around the schedules of expert witnecaes 3 and it is appreciated.
4 JUDGE MARGULIES: Now if we could only find ,
5 Dr. Deutsch?
6 MR. DEUTSCH: Still here.
7 JUDGE MARGULIES: We are concluded with limited 8 appearances here today. Now we will continue with 9 Dr. Deutsch as part of the evidentiary record.
10 -
MR. CHURCHILL: Your Honor, the way I envisioned 11 the procedure here, the Intervenor will offer Dr. Deutsch to 12 be sworn in, he will offer Dr. Deutsch's testimony, request
) -> .
13 that it be -- the written testimony be accepted by the Board, 14 an(i before the Board rules on that request our position would 15 be. that J. would like to ask him a few questions on voir dire 16 in order to respond to the Board when they ask if we have any 17 problems with the receipt of that testimony.
18 JUDGE MARGULIES: Do you have any problems with 19 that?
20 MR. TEPER: In introducing Dr. DeutJch's evidence.
21 I would like him to briefly summarize it. That is, not read 22 it in as a statement, but it will be bound into the record as 23 if read. But if he could briefly summarian it, then that is 24 acceptable?
x_ 25 JUDGE MARGULIES: I don't think it would serve any i N ACE-FEDERAL REPORTERS, INC.
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26113.0 "RT 554 1 purpose for him to summarize it. It speaks for itself and it 2 is there in its entirety. It would serve no useful purpose 3 for him to summarize it.
4 MR. TEPER: If the Board so rules --
5 JUDGE MARGULIES: Pardon me?
6 '
MR. TEPER: If the Board so moves, we'll refrain.
7 JUDGE MARGULIES: I'm going to swear you in, 8 Dr. Deutsch.
9 Whereupon, 10 HOWARD M. DEUTSCH 11 was called as a witness and, having first been duly sworn, 12 was examined and testified as follows:
13 l JUDGE MARGULIES: Wil1 you proceed with i
14 l identifying the witness?
15 MR. TEPER: Yes. The witness is Dr. Howard 16 l Deutsch.
17 JUDGE MARGULIES: You have to develop that from le j the witness, 19 JUDGE PARIS: He's under oath. You aren't.
20 , MR. TEPER: Okay. l 21 DIRECT EXAMINATION 22 BY MR. TEPER:
23 Q Will the witness please identify himself?
24 A My name is Howard M. Deutsch, I'm a research 25 scientist at Georgia Institute of Technology in the chemistry ACE-FEDERAL REPORTERS, INC.
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1 department. /
l-S 2 Q And on what matter --
3 JUDGE MARGULIES: Could we have an address for d Dr. Deutsch?
I 5- THE WITNESS: Georgia Institute of Technology,
-6 school of chemistry, Atlanta, Georgia, 30332.
- l. . 7 'BY MR. TEPER:
-8 Q son what matter do you come before the Board today?
9 A It's subcontention of the environmental 10 qualification concerning the ASCO solenoid valves.
r 11 MR. TEPER: At this point, I would like to. submit 12 Dr. Deutsch's prefiled testimony into the record as i
q; 13 evidence. If I can find a copy.
A 14 MR. CHURCHILL: Just so we understand it, our 15 understanding of Dr. Deutsch's prefiled testimony is that 8-16 which is attached to a letter from Tim, Johnson dated 24 i l
17 February 1986. The attachment does not have a heading but it 18 starts out, "my name is Howard M. Deutsch." It consists of 19 five unnumbered pages and an attachment -- the attachment
?, 20 doesn't seem ,to have a cover page either, and it purports to 21 have 10 pages b'ut there seem to be only nine. Perhaps 22 there's a cover page missing.
23 JUDGE LINENDERGER: There is a 10th page. At 24 least my copy has a 10th page of 10.
25 MR. CHURCHILL: I have a 10th page of 10, I don't
+
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I have a Ith (sic) page of 10.
2 May I ask Mr. Teper if that correctly identifies 3 the testimony?
4 JUDGE LINENBERGER: I do have a ith (sic) page of 5 10.
6 JUDGE MARGULIES: Better yet, let me ask I
! 7 Mr. Deutsch, does that identify your prefiled testimony that l 8 you prepared in this proceeding?
9 THE WITNESS: Yes, it does.
10 JUDGE LINENBERGER: Are there any corrections that l
}
11 you wish to make in the statement as it' presently appears?
i-
- r3 12 THE WITNESS
- There's no corrections.
L
() 'UDGE LINENBERGER: If there are no objechions to j 14 the' testimony, we make a motion that it be entered into the 15 record as evidence. l 16 MR. CHURCHILL: As I stated, I would like to voir 17 dire first, if the Board pleases?
18 JUDGE MARGULIES: Is there any objection to his 19 proceeding with voir dire at this time?
20 JUDGE LINENBERGER: Seeing as there will be no 21 direct testimony on the evidence we will move right into the 22 voir dire .
23 JUDGE MARGULIES: The voir dire is for the purpose 24 of determining whether he has the qualifications to submit 25 this testimony and to have it admitted into evidence.
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1 You understand that?
2 MR. TEPER: Yes. I do.
3 JUDGE MARGULIES: You may proceed with voir dire.
4 VOIR DIRE EXAMINATION 5 BY MR. CHURCHILL:
6 Q Dr. Deutsch, by whon are you employed?
I I 7 A Georgia Institute of Technology.
I 8 0 Did you-say the chemistry department?
9 A Yes.
10 ,
Q What is your position there?
11 JUDGE MARGULIES: Could you both please keep your I 12 voices up?
j 13 JUDGE LINENBERGER: See.if your microphones are l'
14 on.
15 BY MR. CHURCHILL:
16 Q What is your position there, Dr. Deutsch?
17 A I'm a research scientist.
18 Q Could you give me your educational background 19 since leaving high school, the degrees you have earned?
l 20 A As stated in my testimony, I have a BS in 21 chemistry from Georgia Tech in 1962 and a PhD in organic 22 chemistry in 1967.
23 Q And before coming to Georgia Tech -- that's where 24 you are now?
l 25 A Yes.
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26113.0 Jr 35a 1 Q Where were you employed?
2 A At the Union camp corporation, in Princeton, New 3 Jersey.
4 Q What did you do for Union Camp?
5 A Research related to the pulp and paper industry.
6 Q In your educational background, Dr. Deutsch, did 7 you specialize in or focus your studies on any particular 8 area?
9 A Chemistry, specifically organic chemistry.
10 Q And, within the area of organic chemistry did you 11 further specialize in any subareas in that general area?
12 A Not in my formal education. In the research 13 , interest that I have taken I have somewha't specialized.
14 0 And what would that area be?
15 A Generally in the area of medicinal chemistry.
16 Q Medicinal chemistry?
17 A Yes.
18 Q Looking -- you recall, when you were deposed by 19 Mr. Davenport earlier on, and I'm looking at a transcript of 20 that deposition, and it said your interests have been in the 21 area of r.atural products. That was your anuwer to the 22 question I had asked previously.
23 Is that medicinal chemistry?
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'RT ady 1 more at the medicinal aspects related to natural products.
2 Those are not totally unrelated but not necessarily.
3 Q What do you mean by " natural products"?
4 A Those that occur in nature, not totally synthetic 5 products such as plastics or other -- herbicides or 6 insecticides that are totally laboratory-produced products.
7 Q And what is your current position at Georgia Tech?
8 A I have answered that already, I'm a research 9 scientist.
10 Q And how long have you held that position?
11 A For approximately seven years. I don't have the
. 12 date in front of me.
13 -
Q Do you teach as part of that position?
14 A I don't necessarily teach, but I do some teaching 15 at my own and the discretion of the department.
16 Q Is that at a graduate or an undergraduate level?
17 A It's generally been at the undergraduate level.
18 Q What sort of research do you do, Dr. Deutsch?
19 A Currently I'm particularly interested in medicinal 20 chemistry research, particularly isn't areas of cancer, 21 chemotherapy and anti-glaucoma medication.
22 JUDGE LINENBERGER: Excuse me, sir, did you say 23 anti-glaucoma medicatiori?
24 THE WITNESS: Yes.
25 JUDGE LINENBERGER: Thank you.
l l
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2 Q Now, Dr. Deutsch, at page 1 of your testimony you 3 state, at the top, that you "do not work on any projects 4 related to the nuclear power industry and have never done so 5 in your past professional history." Is that correct?
6 A That's correct. That's in my testimony.
7 Q And I assume, then, that you have never designed 8 or participated in a program to determine or evaluate the 9 performance of soJ enoid valves in the type of environment to 10 be expected in an operating nuclear plant?
11 A That's correct.
m 12 , Q Had you ever studied about or done any research on l
13 the environmental qualification of equipment?
14 A I have merely read the testing results.
15 Q Related to this --
16 A Related to these particular valves.
17 Q And to these particular proceedings?
18 A Yes.
19 i Q The papers that have been filed in this 20 proceeding?
21 A Correct.
22 0 And I assume, then, also you have not been 23 involved in any kind of maintenance or surveillance program 24 for nuclear plant components at any time?
25 A No, I have not.
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26113.0 RT J61 1 Q Have you ever participated or designed -- or 2 participated in the design of a solenoid valve?
3 A No, I have not.
4 Q Have you ever inspected and actually evaluated the 5 performance of a solenoid valve on the basis of your 6 inspection?
7 A No, I have not.
8 Q In your deposition, taken for this proceeding, you 9 state at page 20 that you had "never provided the intervenors 10 with any information from your own personal knowledge as 11 oppused to that which is generally available in the 12 literature."
\
13 Do you agree with that statement, that that was a 14 true statement' at that time? .
15 A Yes, it was.
16 Q Can the same be said for the information provided 17 in your testimony? That is, that it is not provided from 18 your own personal knowledge but it is provided on the basis 19 of information generally available?
20 A That's true.
21 Q And you have performed no studies related to the 22 issues in this contention, 10.5?
23 A I don't know quita how to interpret that. I x
24 certainly have studied these issues but I don't have any 25 l research program. I have studied the documents that are ACE-FEDERAL REPORTERS, INC.
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available to me and reached the conclusions that I stated in 2 my testimony.
3 Q Dr. Deutsch, during your deposition do you recall 4 telling the Applicants that you did not intend to testify in 5 this proceeding as an expert witness on Contention 10,5?
6 A I really don't recall that. It is possible. I 7 won't -- I mean I don't recall that with certainty, no.
8 Q Are you now offering your testinony as an expert 9 -- on the subject matter involved as an expert?
10 A Yes, I am.
11 Q As an expert?
12 A Yes. I an offering my testimony.
'3
. MR. CHURCHILL: Your Honor, thit's all the 14 questions that Applicant has on voir dire for Dr. Deutsch.
1$ I would object to the admissibility of 16 Dr. Deutsch's proffered direct testimony in this proceeding 17 on the basis that he does not qualify as an expert on the 18 subject matter involved in this proceeding.
19 There is no doubt that Dr. Deutsch is a very well 20 qualified and educated person. He has a PhD in organic 21 chemistry. He holds a responsible position in a very 22 prestigiods university here in Georgia. He does not, 23 however, have any background in the particujar area invclved 24 in the environmental qualification of solenoid valves.
25 Indeed, he has no background as a mechanical engineer or any ACE-FEDERAL REPORTERS, INC.
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1 kind of engineering and, in fact, his chemistry background 2 really is -- has an emphasis on the orcanic aspects.
3 Now, the controlling law on this, in these NRC 4 proceedings, is that stated in the Duke Power Company /McGuire 5 case, ALAB 669, found at 15 NRC 453, 1982.
6 In that case there was also a well educated 7 chemist, I believe he was. He had a master's degree in 8 chemistry. He was asked to testify on areas that had no 9 relationship to cheetstry.
10 The argument advanced by the parties advancing his 11 testimony was that he is a very well-educated man. He is a gs 12 '
scientist. He can understand these technical subjects. He b 13 can read the papers that have been flied in this proceeding 14 and, therefore, he should be allowed to qualify as an 15 expert.
16 The appeal Board disagreed. The appeal Board said 17 that the NRC regulations say very little about how to define 18 an expert for purposes of an expert witnessing; and in the 19 absence of that kind of guidance in the regulations, we go to 20 Rule 702 of the Federal Rules of Evidence which is applicable 21 here.
! 22 Rule 7d2 provides that if scientific, technical or 23 other specialized knowledge will assist the tryer of fact to 24 understand the evidence or to determine a fact in issue, a 25 witness qualified as an expert by knowledge, skill, ACE FEDERAL REPORTERS, INC.
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26113.0 RI XI 1 experience, training or education mav testify thereto in the 2 form of an opinion or otherwise."
3 The appeal Board found, your Honor, that this 4 well-educated scientist, even though he was a scientist and 5 could understand the documents on the technical subjects 6 involved, could not qualify as an expert witness because his 7 background, knowledge, skill, experience, training or 8 education was not in that field and therefore he did not 9 qualify as a witness -- ac an expert in that subject matter.
10 Dr. Deutsch has been very candid about what he nas 11 i studied and what he hasn't studied and there is not an ioti x
12 or a shred of any kir ?. of linking or nexus or relationship to I
13 his background, his exserience and his education and the ,
14 issue of the environmental qualification of the solenoid 15 valves.
16 And on that basis, in accordance with the rules 17 set out by the appeal Board in ALAB 669, Applicants l
18 respectfully object to the receipt of Dr. Deutsch's testimony 19 in this proceeding.
20 JUDGE MARGULIES: Mr. Teper?
21 MR. TEPER: Mr. Chairman, with all due respect to 22 the legal arguments made by my distinguished opponent in this 23 precaeding, the Duke Power proceeding is not necessarily 24 controlling. While it is true .that an expert witness o
25 presented by Intervenors should have the skills requisite in ACE-FEDERAL REPORTERS, INC.
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'RT 363 1 order to present information which will be helpful to the 2 Board's direction, it is not necessary that they be an expert 3 -- experts in the specific component, nor have specific 4 experience in the nuclear industry.
5 I will not attempt to joust on the legal merits.
6 I can only offer Dr. Deutsch's testinony as a PhD in 7 chemistry; albeit organic chemistry, it is still necessary 8 for Dr. Deutsch to have extensive knowledge of chemistry in 9 general, which would deal with polymers and environmental 10 qualifications at a certain level.
11 In order to provide the Board with opposing
-s 12 information as to the merits of Georgia Power's -- of 13 Applicant's testimony that their solenoid valves do meet the 14 environmental qualifications, we have attempted to give a 15 scientific study by a scientist on that information.
16 At this point I urge the Board to deny the motion 17 l of the Applicant, to accept our expert testimony and then at 18 l that point you may weigh the evidence as opposed to that 19 evidence presented by the company. If indeed you see fit 20 that, since our expert does not have the background or 21 experience equivalent or in preponderance to that of the 22 Applicants, you will rule accordingly.
l 23 At this peint, since e do not have the millions 24 of dollars and we cannot buy an expert witness, we took that 25 information which was volunteered to us by a scientist with ACE. FEDERAL REPORTERS, INC.
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1 extensive credentials. At this time we urge the Board to 2 accept that as evidence.
3 JUDGE MARGULIES: Do you have anything to offer, 4 Mr. Bordenick?
5 MR. BORDENICK: I do, Judge Margulies.
6 I support the Applicant's motion. Mr. Teper just 7 alluded to Dr., Deutsch's expertise, vis-a-vis polymers, lie's 8 in the wrong contention. That's Contention 10.1. This 9 testimony is being offered in connection with 10.5.
10 Normally the motions of the sort that the l 11 Applicant has made here this afternoon would go to the weight 12 to be given to a witness' testimony. However, in this case 13 on contention 10.5, it's clear to the Staf f that no weight, 14 in fact, could be assigned.to this testimony based on the 15 questions and answers elicited here this af ternoon and based 16 on the nature of the contention.
17 This this motion had been directed to 10.1, for 18 example, I think Staff would be taking a different position.
19 However, on 10.5 we fully support the motion. It is, in 20 effect, a useless act to admit testimony to which no weight l 21 can be given, and we believe that the testimony should be I 22 excluded.
l l 23 EXAMINATION 24 BY JUDGE LINENBERGER:
s 25 Q Dr. Deutsch, before the Board gets to the point of 1
! ACE FEDERAL REPORTERS, INC. i
! 202 w.nco N= ' - ~ ca ano.m ~" l
f 26113.0 "RT 3e7 (V
1 ruling on Applicant'u concerns with respect to this 2 testimony. I personally can understand how you might feel 3 that you have something to otfer here. And, indeed you have 4 offered something in the form of these -- this prefiled 5 testimony. But it's not completely clear to me whether the 6 situation is as black or white as I interpret the 7 representation of it that I have heard recently.
8 What I'm leading up to is: What can you say about 9 the kinds of things that have gone on in your background and 10 your prior professional history that would make it seen 11 reasonable to you to come forward with this kind of
~
12 testimony, knowing full well that your credentials don't
-12 stand up in terms of, let's say, designing valves or 14 designing pumps or whatever. You must feel that there's 15 something that qualifies you to comment on these things, and 16 do you have a comment in that vein?
17 A Okay. I don't know full well exactly what 18 credentials are required to testify on this subject. All I 19 can do is offer th,e fact that as a citizen, I was very 20 concerned about this issue. I looked into the environnental l 21 qualifications issue at Vogtle as best I could with the time l
l 22 restraints that I have, of having a full time job and many l
l 23 other responsibilities in my life. And a number of things l 24 stood out that were very obvious to me, and I wanted to point l
25 these out to the Board as I have done in other i
i ACE. FEDERAL REPORTERS, INC.
I i
26113.0 RT 366 1 communications, and I felt it was my responsibility to try to 2 get this information into the public record here, in 3 testimony, as best I could possibly do it. I don't --
4 Q Okay, fine -- excuse me. Go ahead.
5 A As I stated, under examination here, I don't have 6 any direc t credentials that I could say that I have ever 7 participated in the design of a solenoid valve, or et 8 cetera. I have been an active scientist for some 20 years 9 and have looked into many areas of science in my general 10 reading. I chink I can look at these testing results and 11 interpret them reasonably well. That's basically what I did 11 as a concerned citisen, and I just wanted to see that the 13 Board had this testimony and record.
14 Q Let me ask the question in a little different 15 manner. Do you consider that your background gives you a 16 better perspective for commenting upon the things you have 17 commented upon than would be the case for a master level or 18 PhD level graduate in social sciences, for example?
19 A In a general way, yes. Although there are nany 20 social scientists who would know nore about thic area than 21 me, if they had been interested. As a student of chemistry 22 , most of my life I have had to pursue the scientific method 23 and continaously look at reports and papers and evaluate them 24 critically from my own research, and that's exactly the i
25 process that I used here.
ACE FEDERAL REPORTERS, INC.
M147-1700 Natienside Coverage 10014 fM6
26113.0 RT 369 1 I was trained in that method and it applies to any 2 field. Certainly, it applies to this. Adnitting that I do 3 not have the specific knowledge about this area that someone 4 would who studied it, that's about all I can offer to the 5 Board.
6 Q Believe me. I'm not substituting my comments here 7 -- and I say this to Messrs. Churchill and the Board -- in 8 any sonJe by way of preempting croSc-examination, should the 9 decision go to let this testimony in. But I just -- the 10 chairman may not agree with what I'm going to ask next but 11 I'm going to ask it. He can gig me later.
~N 12 Based on some of the things you've just said, I go l'
13 tc something I see on the fourth unnumbered pace cf your 14 testimony, at the top where there is a paragraph, the j
15 penultimate sentence of which said, "In other words, it 16 failed before it was even tested."
17 Do you see that sentence?
18 A Yes, sir, I do.
19 Q Now, that sentence appears to me to represent a 20 judgment on your part about valve failure based, apparently 21 on some statement about seat leakage.
22 I wonder how you can bring, with a chemistry 23 background, that kind of judgment to bear when I have no
__ 21 evidence from what you submitted that you even know what is
)
25 acceptable seat leakage.
l ACE-FEDERAL REPORTERS, INC.
_ _ _ . . . . *n? 11?.1*nn W eLin u ta t" u a.a..a cnn 1 u u at
26113.0 RT aiu 1 So, somebody else might have made a judgment to 2 throw out the valve but you yourself are sayinc, in your 3 testimony, it failed before it was even tested, but you say 4 nothing about the question of how much leakage was 5 acceptable.
6 I don't know whether 60 liters a minute was 7 acceptable, but if you do it doesn't come through here. And, 8 if you do -- if you do I don't think it comes out of a l
9 '
chemistry background.
10 So you can see the kind of ball of wax that the 11 Board is going to try to deal with here, in making a decision
~3 12 about Mr. Churchill's objection to the testimony.
13 A I understand what you are saying. That was based 14 simply on the fact that the Franklin Research Center, as best 15 I could understand this, removed the valve from the testing 16 program when they discovered that artificial aging alone had 17 apparently caused this leaking.
18 j Q True. But you passed judgment on the valve. You 19 didn't says Gee, I wonder if Franklin knew what they were 20 doing. You didn't says Gee, I better go -- I, Dr. Deutsch 21 -- better go and find out how fast 60 liters a minute is, 22 compared with manufacturer's specs, for example. Here's a 23 , judgment you based on this valve bcsed on that chemistry 24 background.
25 It's that kind of thing that we are wrestling ACE-FEDERAL REPORTERS, INC.
smsm wn m
e ..m_ . _
26113.0
,T 3/1 1 with, but I'm taking enough of your time here and I think 2 maybe we should make a decision.
3 JUDGE MARGULIES: We'll take a 10-minute recess.
4 (Recess.)
5 JUDGE MARGULIES: We have carefully reviewed the 6 matter in licht of the commission decisions cited and Rule 7 702 of the Federal Rules of Evidence and conclude that 8 Mr. Deutsch's ccientific background is such that it will help 9 us to understand the evidence because of his training and 10 education.
11 We will certainly take into account the nature ot
.~ .
12 his training in terms of the weight of the testimony that he 13 will gi,ve.
14 The statement of Mr. Deutsch is previously .
15 identified, and will be bound into the record.
16 (The document followss) l 17 ;
i 18 !
19 20 21 22 23 24 ;
25 ACE FEDERAL REPORTERS, INC.
3n, u- t nn w, _ .. i. nm, ,_ enn s u -
_.,...--..-..--_:.......-.=.;=:..=-. - - - - .
e b e- My name is Howard M. Deutsch and I am employed by the Georgia i
' (_)3 Institute of Technology (GIT) as a Senior Research Scientist. In this capacity I do not work on any projects related to the nuclear
, power industry and have never done so in my past professional history. My educational background includes a B.S. (Chemistry) in 1962 from Georgia Institute of Technology and PhD (Organic Chemistry) in 1967 also from GIT . From 1966 to 1974, I was employed by Union Camp Corporation in Princeton, !!ew Jersey and did industrial research related to the pulp and paper industry.
As a spokeman for joint intervenors, I am very familiar with l contention 10.5 and was largely responsible for its formulation, and the research to show that this issue should be brought to the attention of the ASLB. We orignally contended that:
. "Some of the equipment specified in VEGP FSAR table 3.ll.N.1-1 as being environmentally qualified may in fact be unqualified. For example, on August,31, 1983 NRR issued a Board notification transmitting a summary of a Staff investigation into Franklin Research Center tests on solenoid valves. Over half the
' valves failed in tests simulating normal and accident conditions.
BN 83-128.
Several valves manufactured by ASCO failed early after exposure to 340 degrees F., i.e., they had little or no tir.e to perform their safety function before failing. Over one year earlier ASCO's own* testing had shown poor performance of these valves, and had reported this to the EQB. The EQE memo from R.
() Vollmer to D. Eisenhut (included in BN83-128A) stated the staff
" continues to approve" the qualification of valves on the basis l
,_ of 197S tests. The applicable standard in 1978 was IEEE l )
382-1972, which has since been replaced with IEEE 382-1980. The EQB concluded that the early failure of the ASCO solencrid valves makes them unacceptable for use in safety systems and suggested that licensees and applicants be prohibited from using the valves in any application where conditions could be more severe than those reported in the qualification test report. In relationship to VEGA, FSAR table 3.11.N.1-1 (environmentally qualified equipment) shows the sum of twenty three separate ASCO solenoid valves. The function of some of the valves is not listed and in no case is the qualification reference listed."
The ASLB accepted this contention, as a separate subcontention among a number of contentions in the area of A
(_) environmental qualifications, which was part of a package of contentions dealing with safety-related items at VEGP. After several rounds of discovery, in which the applicant refused to answer most of the intervenors' questions, and were later compelled to answer by the ASLB, the applicants filed for summary disposition on July 31,1985. In their memorandum of January 7, 1986, the ASLB denied the motion and made it very clear that there were many areas of material facts for which genuine issues remain to be heard.
I would like to briefly summarize, to the best of my knowledge the test'ing history that has been done on ASCO solenoid valve, so that it will be obvious to anyone looking at these facts n
() that the valve should not be considered qualified.
Valve !!P0316 was tested in 1979 by Isomedix for ASCO and
y_ _,. _ __. ,_ m - _
.m adequate performance.' They state that only a few hours of
'b performance would be required at VEGP (basis not stated) . FRC also tested one NP8321, but after artificial aging was removed from the test program because of seat leakage in excesss of 60 liters per minute. In other words it failed before it was even tested! Nevertheless, applicants judged the valve to be qualified.
Valve 206-381-6F (one each only) was tested by Westinghouse /ASCO and FRC and deemed to have performed satisfactorily.
It is obvious from the foregoing that serious problems have been found with ASCO solenoid valves, and there is no reasonable basis to think that all of these valves that will be
() installed at VEGP will perform adequately during the lifetime of the plant.
Relevant to this last point is the applicants program for maintenance and surveillance of ASCO solenoid valves. During the discovery process, applicants refused to answer intervenors' questions in this area, but were forced to do so by the board (order of June 4, 1985). Applicants furnished intervenors with a ten page report titled "ASCO Solenoid Valve Maintenance", copy attached, and stated that the frequency of maintenance has not yet been determined. This document gives a detailed procedure for how valves are to be serviced, but nothing about a surveillance program. Page 8 of the document states the acceptance criteria for proper maintenance. According to these criteria, a valve can
(])
be accepted BUT NOT WORK! Nowhere is the simple statement made
=. . . - . . . ~ ~ .-
" Verify that the valve' functions properly"! Clearly, applicants
( i is' do not have an adequate maintenance or surveillance program for ASCO solenoid valves. One wonders about the myriad of other equipment that was not questioned by joint intervenors.
Another interrogatory that applicants refused to answer, but were forced to by the board, asked how physical orientation of ASCO valves was considered during environmental qualification testing. Applicants stated that they were designed to perfor~ in any orientation (except 206-381-6F), the only requirements being that the " solenoid enclosure be sealed". In view of the fact that ASCO our testing of HP8316 had shown a loss of housing seal integrity one wonders about the usefullnes of the statement. In fact, the attached "ASCO Solenoid Valve Maintenance" report states
(]) on page 5 that the valves must be " mounted in the position indicated on the nameplate". Thus it is clear that physical orientation is an important factor and must be considered in qualifications of ASCO valves.
ht. h*J Howard M. Deutsch February 23, 1986 O
~ . - - . - - - . . . - .
muov.. o fw r
GeorgiaPower 26060-C yp .
- ... ~ - .~1 . , _ , .
d, g VOGTLE ELECTRIC GENERATIN3 PLANT 0 fl a Ihb UNIT COMMON 1o 10 ASCO SOLENOID VALVE MAINTENANCE d ,
No._ t 2 1.0 PURPOSE This procedure provides instructions for the disassembly, inspection, and reassembly of ASCO solenoid valves.
If only portions of this procedure are needed to complete the required maintenance, contact the Maintenance Foreman and use only the steps which are applicable. Document which steps were used in the
" Comments" section of the " Completion" or " Data" Sheet.
N/A the steps on the " Completion" or " Data" Sheet which were not used. l 2.0 PRECAUTIONS AND LIMITATIONS 2.1 The valve may be in a radiation area or may be radioactively contaminated. If.so, follow the instructions on the Radiation Work Permit.
2.2 Minimize the entry of foreign materials or dirt into the working parts of the valve.
3.0 PREREQUISITES AND INITIAL CONDITIONS 3.1 re Verify that a Quality Control (QC) signed Sheetstheindicating
" Completion" QC review of the procedure for hold points. If hold points are indicated, notify QC prior to starting work.
3.2 Determine the safety classification of the valve and check the appropriate classification on the " Power and Signal Removal / Replacement Data" Sheet.
3.3 V.alve isolated, depressurized, and tagged. (Operations' responsibility, Maintenance verify.)
O 200008 CONTINUED
- ~ ~ - . -
3.4 MINIMUM PARTS REQUIRED 3.4.1 Dow Corning's Valve Seal or equivalent high grade .
silicon grease.
h 3.4.2 Approved safety solvent.
3.4.3 Gaskets
- b. Lower Body Gasket 3.5 SPECIAL TOOLS REQUIRED 3.5.1 Solenoid base sub-assembly wrench (for explosion proof, watertight solenoid).
3.5.2 Torque Wrench (0-300 in-lbs), for valves with core diaphragm sub-assemblies.
4.0 DISASSEMBLY, INSPECTION, AND REASSEMBLY 4.1 DISASSEMBLY U) v NOTES
- a. To install jumpers and/or lift wares other'than those directly associated with the equipment tag number (s)/ scheme number (s) listed on the Work Order, notify the Shift Supervisor and comply with his instructions.
- b. Ensure that each lead (wire) is marked so that it can be -
uniquely identified with its termination point.
4.1.1 Notify Shift Supervisor of work to be performed.
- /*
4.1.2 Ensure that the valve and/or operator is fully isolated
- /* and tagged in accordance with Procedure 00304-C,
" Equipment Clearance and Tagging".
() ,
200003 CONTINUED rum
~
f 0 3 of 10 26060-C O 4.1.3 Disconnect and life instrument control, and power from the valve and solenoid coil as required. Record leads
- L* their removal by wire number and termination point on the " Power and Signal Removal / Replacement, Data" Sheet.
4.1.4 Remove retaining cap, retaining clip (if provided),
and nameplate.
WARNING THE METAL tETAINING CLIP, PROVIDED ON SOME SOLENOIDS, WILL SPRING UPWARDS WHEN DISENGAGED.
4.1.5 Disassemble solenoid as follows:
- a. For general purpose enclosure -
(1) Slip entire solenoid enclosure off solenoid base sub-assembly.
. washer, and (2) Removehousingcover, insulating washer (if provi springed).
) NOTE In some assemblies, the coil and sleeves and washers are doubly enclosed in a yoke which must be pulled from the housing first to facilitate disassembly.
t (3) Remove coil from housing (or from yoke).
- b. For explosion proof / watertight enclosure -
flux plate, Remove housing cover, take-up spring,ded).
coil and insulating washers (if provi Unscrew solenoid base sub-assembly and/or remove 4.1.6 bonnet.
' NOTE Explosion proof / water-tight construction requires en U special wrench for flats on solenoid base sub-assembly.
200010 CONTINUED eum
j., s.----
PAGa No.
enocaount No. nav n.N 26060-C 0 4 of 10
() 4.1.7 Remove core spring and core assembly (or core / diaphragm
(
assembly).
CAUTION ..
For valves with core diaphragm assemblies, .
ensure that the hanger spring between core and i diaphragm is not damaged or distorted.
4.1.8 If valve body has an and cap, complete disassembly as follows:
- a. Remove end cap and body gasket.
- b. Remove disc spring and disc / holder assembly or remove piston spring and piston assembly.
NOTE l To remove piston assembly, hook a bent piece of wire O or similar tool into the small hole provided in the back of the piston. Then pull the piston aasambly from the valve body.
4 4.2 INSPECTION
. 4.2.1 Coil
- /*
- s. Visually inspect coil and coil housing for external damage, discoloration from overheating, ;
broken lead wires, or other abnormalities.
- b. Check for open-circuited coil (burned out or l cracked insulation).
1
. c. Replace coil as necessary, f 4.2.2 Inspect terminations and flexible conduit to solenoid '
- /* for damage, discoloration, or other abnormalities.
() !
1
,200011 CONTINUED e
_~-
_ ~~
paos no.- ,
- =L navision
~
paocaousiTeo. 5 of 10 0
26060-C O 4.2.3 Valve Internals
- l.-- a. Clean parts with an approved safety solvent. ;
- b. Inspect valve internals for excessive'vear, erosion, corrosion, or other abnormalities.
- c. Replace excessively worn parts as necessary. .
4.3 REASSEMBLY CAUTIONS
- a. If lubrication of disc stem is required, DO NOT use a dry film lubricant.
Use only a normal petroleum lubricant.
[ b. Ensure solenoid is mounted in the position indicated on the nameplate.
4.3.1 If valve Body has an end cap, begin reassembly as O follows:
- b. Install disc spring and disc / holder assembly or install piston spring and piston assembly,
- c. Screw on and cap and gasket.
. l
'O 200012 CONTINUED c~n
.~-_-..f.--- _1.m .. __ _ _.
anocaount No. maV@CN ,
PAla No.
26060-C 0 6 of 10
/
\ !
4.3.2 Installcoreassemblyandsolenoidbasesub-assembly as follows:
Valves with core /diaphrass sub-assembly -
- a. -
s 'e <
(1) Install body gasJtet and core / diaphragm sub-assembly.- ( J, :
s
- NOTE Locate the bleed hole'in core / diaphragm sub-assembly spproximately 45' from the valve outlet.
(2) Instal'1 core spring with wide end in core first: ' closed and protrudes from top of core. .
(3) Install valve bonnet and screws. Torque
- /* screws to value shown in Table 1.
(4) Install bonnet gasket and solenoid base
- /* sub-assembly. Torque solenoid base sub-O assembly to value in Table 1. .
TABLE 1 Solenoid Valve TORQUE VALUE (in-lbs)
Model Bonnet Solenoid Base Solenoid No. Screws Sub-assembly Cover 8210 110*10 175125 NA 8211 s
80033 . .
80034 NA NA 135*10
- b. Velves without core / diaphragm .sub-as'sembly -
(1) Install core spring, cora arosambly, and body gasket.
(2') Screw in solenoid base sub'-assembly.
O 200013 CONTINUED
g m.v,. em w.
1- w.w . w. ,
26060-C 0 7 of 10
( 4.3.3 Reassemble solenoid as follows:
CAUTION .
~-
Solenoid must be fully reassembled as the housing and internal parts are part of and complete the magnetic circuit. Place insulating washer at each and of coil if required.
- a. If the solenoid has an explosion-proof / watertight enclosure:
Wipe surfaces clean.
(1)
(2) Grease joints with Dow Cornings' Valve Seal or equivalent.
i (3) Place coil, insulating washers (if
! provided), fluxplate, and take-up spring ento solenoid sub-assembly.
,O
~
(4) Grease joints with Dow Cornings' Valve Seal i
or equivalent.
f (5) Screw on housing cover and torque to value
- /* given in Table 1.
- b. If the solenoid has a general enclosure -
(1) Reassemble coil, insulating washers (if provided), and spring into housing.
.(2) Slip entire solenoid as a unit onto the solenoid base sub-assembly, j 4.3.4 Reconnect the instrument, control, and power leads
- /* to the valve and solenoid coil. Verify correct i
replacement and initial the " Power and Sipal Removal Replacement Data" Sheet. If required, indegendently verify correct replacement and initial the Power and Signal Removal / Replacement Data" Sheet.
I 9 204h@l4 I
CONTINUED mun
2 % .o.-
~
MH5EDuiltNO. l EEvCloN ~~~ ,,
3 of 10 0
26060-C
() 4.3.5 Place nameplace, metsi retaining clip (if provided),
and retaining cap onto solenoid cover.
4.3.6 Ensure that solenoid valve mounting bracket is fixed securely to both solenoid valve and mounting surface. .
4.3.7 Notify ShifteForeman that required maintenance is
- /** complete.
5.0 ACCEPTANCE CRITERIA Maintenance ?erformed using this procedure is acceptable when the " Completion" Sheet is properly filled out and approved. Deviations from procedure data and recommended settings will be evaluated on a case-by-case basis, identified in the " Comments" section of the " Completion" Sheet and approved by the Maintenance Foreman. ,
6.0 REFERENCES
Excerpt from " Reciprocating Air 6.1 AX4AY01-3-1 Compressor-Instruction XLE Packaged "L" Design" O 6.2 2X4AYO3-25-0 Excerpt from " Rotary Screw Compressor Instruction Manual" 1X4AN02-291 Excerpt from " Condensate Filters-6.3 Operating Instructions-Powdex Condensate Polishing" Vol.3.
END OF PROCEDURE TEXT ,
I i
l O
l 200015
=-s ,
LEVisl2N PAGE No.
0 M, CEDURE NO.
0 9 of 10
. 26060-C Sheet 1 of 1 POWEIL AND SIGNAL REMOVAL / REPLACEMENT DATA SHEET
[] Safety Related [] Non-Safety Related NOTES
- a. To install jumpers and/or lift wires, other than those directly associated with the equipment tag number (s)/
scheme number (s) listed on the Work Order, notify the Shift Supervisor and comply with his instructions.
- b. Ensure that each lead (wire) is marked so it can be uniquely identified with -
its termination point.
- c. Independent verification is only reouired on safety related equip =ent.
Pldce N/A in independent verification block for non-safety related equipment.
VERIFY RECONNECTION
) IDENTIFY leads lifted LOCATION
. juopers installed, Panel or junction box links opened etc. terminal block, etc. VERIFICATION INDEPENDENT
. VERIFICATION l
1 r
l 20001S M _ . _ _ . . _ _ _ . _ _ _ _ _ . .
. 1
. i
. 10 of 10 Sheet 1 of 1
'( } COMPLETION SHEET Procedure No. Revision
, sheet 26060.C 0 Tag No.
Description 1 of 1 serial No. ASCO Solenoid Valve Manufacturer Model Automatic Switch Co.
Test Equipment Used PROCEDURE
_ STEP DESCRIPTION MAINT. HOLD INITIAL QC POINT _ INITIAL 4.1.1 Ensure Clearance and Tagging (Yes/No) 4.2.1 Coil Inspection _
4.2.2 Wiring Inspection
(]) 4.2.3 Valve Internal Inspection *
- 4. 3. 2a ( 3) Valve Bonnet Screws torqued properly 4.3.2a(4) Solenoid Base Sub-assembly torqued properly 4.3.3a(5) Housing Cover Torqued Property (Explosion Proof /
Watertight only) _
4.3.7 Notify Shift Foreman l
Comments / Additional Hold Points __
- QC has reviewed this procedure for hold points signature AFFROVED ( ) DISAFPROVED ( )
FOREMAN COMPLETED BY DATE DATE o ._,2000J7
26113.0 f-"RT 372
(_)
1 JUDGE MARGULIES: It will be considered a.e if he 2 had given the testimony orally.
3 Does that conclude your direct examination?
4 MR. TEPER: At this time I would like to ask the 5 witness very few short questions. If that is appropriate at 6 this time? Or -- if the understanding earlier was that we 7 would only have the voir dire at this time --
8 JUDGE MARGULIES: We had asked if there-were any 9 corrections to be made.
10 MR. TEPER: That is enough. At this time I have 11 no further questions.
gy 12 JUDGE MARGULIES: You may cross-examine.
V 13 MR. CHURCHILL: Your Honor, we have no .
14 cross-examination for this witness.
15 JUDGE MARGULIES: Mr. Bordenick?
16 CROSS-EXAMINATION 17 BY MR. BORDENICK:
18 Q Dr. Deutsch, are you familiar with the document 19 entitled "NRC Staff testimony, Armando Masciantonio, joint 20 Intervenors Contention 10.5, ASCO solenoid valves" which is 21 17 pages in length and has two attachments?
22 A I know what you are referring to. I don't have a 23 copy of that with me right now, although I do have one here 24 hear in the court, room.
'w-25 Q Is it your testimony that you read the document I l l
ACE-FEDERAL REPORTERS, INC. I 201347 37G) Nadonude Coverase 8(D 33H646 I
26113.0
^hT 373 ,
i 1 have just identified?
2 A I have looked at it. I have not read it in 3 complete detail. I can't recall all of the points in it, 4 no.
5 MR. PARIS: Dr. Deutsch, we can't hear you up 6 here.
7 THE WITNESS: I have looked at this document. I 8 have not studied it in complete detail.
9 BY MR. BORDENICK:
10 Q Would it help if I gave you a copy of that 11 testimony?
12 A Yes.
lj' 13 I have the document in front of me now.
14 l Q Dr. Deutsch -- thank you. That was the question I 15 was going to ask you.
16 Would you turn to attachment 2 of that testimony.
17 Have you found it?
18 A I see what is labeled attachment 1. It is 19 apparently three pages. Then there's another part that says 20 " attachment," with no number after it.
21 Q It should be the last page in the document --
22 A Okay. The last page. I have that. Yes.
23 Q Have you found attachmer.t 2?
24 A Yes, I have. I am looking at the last page now,
-J 25 attachment 2.
ACE-FEDERAL REPORTERS, INC.
Swmarm m _snussa
26113.0
'TME 374 1 Q Have you read that attachment prior to this 2 afternoon?
3 A I looked at it but I have not studied it in 4 detail; no.
5 Q Are you prepared to answer questions on it?
6 A I will do my best to answer any question you 7 propose to me.
8 Q Do you disagree with the attachment?
9 A No.
10 Q Anything written on the attachment?
11 A I don't disagree with it.
12 Q Do you agree with it?
13 A I have not studied this attachment'in detail b.ut I 14 will not -- I do not disagree with it.
15 Q How about the rest of the testimony? Do you have 16 i any disagreement with the rest of the Staff's testimony?
17 A No, I don't.
18 MR. BORDENICK: I have no further questions.
19 JUDGE MARGULIES: Is there any redirect?
20 MR. TEPER: No, there is not.
21 JUDGE MARGULIES: Is there anything further of the 22 witness? You are excused, Mr. Deutsch. Thank you. I 23 appreciate your interest.
24 JUDGE MARGULIES: It's our interest and the
(
25 interest of the public to have a full and complete record.
ACE FEDERAL REPORTERS, INC.
M 1471700 Nananmde Coveraae M31MM(i
26113.0 1T 373 1 As you heard we were willing to come back next week, even, if 2 necessary, to get your testimony.
3 Thank you.
4 It is 4:05; do the parties wish to resume with the 5 prior panel?
6 MR. CHURCHILL: The panel is here, your Honor. If 7 it's all right with the Board and the other parties, I think 8 it probably would be beneficial to proceed.
9 I'm not sure of Mr. Lawless' availability 10 tonorrow.
11 MR. LAOLEOS: I would be available tomorrow
- 12 ,
afternoon. Tomorrow morning's availability is uncertain at 13 this point and I couldn't commit to it. I might be able to 14 show up in the morning if I can clear my schedule. I had 15 only planned for testimony today. So, at this point,'and 16 being away from Augusta, I couldn't be assured of being here 17 in the morning.
18 JUDGE MARGULIES: We can get another hour of 19 testimony in. I think we ought to proceed in that manner and 20 then we'll see where we go from there.
21 MR. LAWLESS: I also would be available Thursday 22 afternoon and all day on Friday.
23 Whereupon, 24 THOMAS W. CROSBY, 25 CLIFFORD R. FARRELL, ACE-FEDERAL REPORTERS, INC.
7D7.u7.1700 Narinnwide Cnversee RAO-11&MM
I 26113.0
^nT 376 1 STAVROS S. PAPADOPULCS, 2 and 3 LEWIS R. WEST 4 resumed the stand and, having been previously duly sworn, 5 were examined and testified further as follows:
6 JUDGE MARGULIES: You may continue with your 7 examination, Mr. Lawless.
8 CROSS-EXAMINATION (Continued) 9 BY MR. LAWLESS:
1 10 Q I think where we had left it at the break, the 11 Vogtle engineers and consultants had felt tnat the only 12 contamination that could pass through the marl would be
~
13 through percolation or water transfer.
14 I think we had left it at that point and I will 15 take up from there unless there -- there appear to be no 16 objections to that.
17 Let's look at page 12 in the '86 document. On 18 page 12 there's a new footnote added. It notes that the marl 19 was penetrated there in excavation, cut from the general 20 thickness of 60 feet under the power block area down to 38 21 feet under the auxiliary building.
22 The way I interpret the note and the presentation 23 is that the marl was cut down to 60 feet under the power I
24 block and also cut down to 38 feet under the auxiliary 25 building; is that correct?
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":T 377 1 A (Crosby) Yes. The marl wae excavated down to an 2 elevation of 130 for the mass excavation and then the 3 auxiliary building was excavated to an elevation of 108.
4 Q And 134 from what general level of elevatior,?
5 A Sea level.
6 Q Yes. I'm sorry. I understand that. But I meant 7 the marl itself, how much of the marl itself was cut? Was 8 there any of the narl that was cut to get it down to the 60 9 foot? How much was removed?
10 A For the mass excavation, the marl surface, 11 approximately 5 feet of weathered marl was removed so that 12 the buildings would be founded on fresh marl.
13 l Q What do you mean by " weathered marl"? How did it 14 get to be weathered? Could you explain that a little bit
, 15 more?
l 16 A When the marl was deposited approximately 30 l
17 million years ago, there was a break in the deposition and it 18 was exposed'to the atmosphere for a period of time before the 19 Barnwell sands were deposited on top of it. That 's when the 20 weathering occurred.
21 Q So there's a general weathering effect across the 22 top layer of the marl throughout the plant?
23 A Yes. Ther3's about a 3- to 5-foot seathering 24 surface.
25 Q Could you describe the weathering jtst in f ACE FEDERAL REPORTERS, INC.
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'lT ;75 1 general? What is it?
2 A It's just --
3 Q Contextually?
4 A It's an alteration that causes a change in the 5 color to a light brown-green color and raises the 6 permeability slightly.
7 Q What does it raise it to?
8 A As discussed in our tes timony, in our affidavit, 9 the -- a couple of packer tests were performed in it at the 10 river facilities area.
11 Q And that was 10 to the minus 6, I think, or
, 12 thereabouts?
13 A Yes. I believe so.
14 Q Centimeters per second. That would also, then, 15 ' hold throughout the plant?
16 A No.
17 Q The extent of the plant alone, the top layer?
18 A No; as I said, it was removed from the power block 19 area.
I 20 Q Excluding the area where it was removed, but in 21 the areas whelT it hasn't been removed from, where there has 22 been no excavation, no disturbance, then that top layer is 23 still probably a perneability of about -- what you found on 24 the river?
25 A I would say so; yes.
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26113.0 RT 379 1 Q Thanks. Uac the 38-foot cut into the mari noted 2 in the FES?
3 A I think you misunderstand the statement. There 4 was no 38-foot cut in the marl.
5 Q I'm sorry. Was the cut down to 38 feet noted in 6 the FES?
7 A Again, you misunde ,tand. There was no cut down 8 to 38 feet. The earl is 38 feet thick below the auxiliary 9 building.
10 Q Yes. It was cut down to that point?
11 A Right.
r . 12 Q There was a thickness left of about 38 feet?
~
) I 13 I A. That's correct.
14 Q Was that noted in the FES?
I 15 A I do not know. I was not involved in the 16 preparation of the FES, 17 A (Farrell) I don't -- I believe that they talk 18 about 38 feet of marl thickness in the FES.
19 Q Where is that dimension of 38 feet? I wasn't able 20 to find it, offhand.
21 JUDGE PARIS: What did you say, Mr. Farrell? I 22 didn't hear you.
23 THE WITNESS: (Farrell) As I recollect, there is a 24 reference. It may not be in the FES, but in the NRC
'- 25 testimony, possibly, of 38 feet. That's what he's referring ACE-FEDERAL REPORTERS, INC.
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2 MR. LAWLESS: Yes. You don't know, then, if it is 3 in the FES? The environmental statement?
4 MR. CHURCHILL: .Your Honor, the FES, the final 5 environmental statement, is a staff document and I think 6 Mr. Farrell has answered and is clear to the extent which he 7 knows or does not know whether that particular number appears 8 in there.
9 MR. LAWLESS: He may have. I just haven't quite 10 heard yet. If you could just rephrase it for me.
11 THE WITNESS: (Farrell) I don't know whether they 7 , 12 mentioned in the FES, specifically, discussing the 38 feet of 0- 13 thickness between the auxiliary building. .
14 I do recall that in one of the reports or 15 testimony by the NRC Staff, they discuss a thickness of 38 16 feet.
17 BY MR. LAWLESS:
18 Q Do you know where that citation is?
19 A (Farrell) We can look. I can look for it.
20 Q I would like to have that.
21 Why was this reference added at this time? I 22 notice tnat it's different from the other. What brought it 23 to your attenticn? Could you explain tha t?
24 A (Crosby) The footnote was added as a point of 25 clarification. The FSAR, in the geology section and in the ACE-FEDERAL REPORTERS, INC.
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'9T 331 1 foundation section, clearly s tates that information I just 2 gave you about the elevation of the depth of the aux 3 building. We put that footnote in there as a matter of 4 clarification.
5 Q So this is in the PSAR?
6 A Oh, definitely.
7 Q Do you have the location of that?
6 A Sure.
9 Q I'd appreciate it.
10 Should this not -- well, I guess I can't ask this 11 of you since the FES is a NRC document. Do you think this 12 should be a part of the FES? I don't recall --
^' '
13 MR. CHURCHILL: Objection.
14 JUDGE MARGULIES: I didn't hear you, counsel.
15 MR. CHURCHILL: I just said " objection." I don't 16 think these witnesses are qualified on what should or should 17 not be in a NRC document.
18 MR. TEPER: Mr. Chairman, our previous witness was 19 cross-examined by the NRC Staff as to their submitted 20 testimony and I just need a clarification from the Board 21 whether it is appropriate to cross-examine witnesses about 22 NFC published information.
23 MR. DEWEY: I second Mr. Churchill's remarks.
24 It's not up to these witnesses to determine what the FES or 25 FSAR should say.
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26113.0 T';T 302 1 JUDGE MARGULIES: What is the relevance of the 2 question?
3 MR. LAWLESS: I hadn't seen it before and I didn't 4 knew if it had just been overlooked in the FES or not. I was 5 wondering how relevant it was.
6 It was not in their earlier testimony, in their 7 July '85 testimony. This footnote was left off and in this 8 '86 testinony it's there. I wondered why.
9 JUDGE MARGULIES: What has that got to do with 10 whether or not it's in the FES?
11 MR. LAWLESS: I was unprepared to find out that the 12 marl had been cut down to that depth, and I was wondering if
~
~
13 this was based on new information or on old information. If 14 it's in the FSAR, it's based on old information. Is that 15 l correct?
I 16 THE WITNESS: (Crosby) Yes, section 2-54 of the 17 FSAR discusses it in several locations. Probably the 18 quickest location to look at -- a diagram which shows what I 19 was talking about is figure 254-1, which is entitled " Power 20 block cross-section."
21 MR. LAWLESS: Thank you.
22 JUDGE MARGULIES: What is the date of the FSAR?
23 IHE WITNESG: (Crcsby) I don't know what date this 24 amendment is but it's the current FSAR, I believe.
-' 25 MR. LAWLESS: Is that new information, though?
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m 26113.0 RT 363 1 THE WITNESS: (Crosby) No, this has been in for 2 three years as far as I know.
~
3 MR. DEWEY: Your Honor, 2-53 of Staff's SER, 4 contains this information, I quote - this is the second 5 paragraph of the SER: " Excavation to elevation 108.5 feet, 6 median sea level, was made over a rectangular area measuring 7 120 feet by 440 feet to accommodate the base mat for the 8 deeper portion of the auxiliary building."
9 So, this information does show the type of 10 information about whicn Mr. Lawless wa,s concerned.
11 MR. LAWLESS: Thanks. That was the next question 12 I had, what was the area extent of it.
13 . BY MR. LAWLESS:
14 Q I presume the area extent pretty well balances 15- itself around the auxiliary building. What effect does this 16 cut have on the marl's ability to protect the Tuscaloosa 17 aquifer?
18 A (Crosby) There is a calculation in our testimony 19 which discusses an accident which would cause movement of 20 potential contaminants through the marl.
21 Q Right. That's a quantitative calculation -- we'll 22 get to that in a minute -- but a qualitative response, if you 23 would?
24 A Could you ask the question again?
O N/ 25 Q Yes. What effect does this cut have on the marl's ACE-FEDERAL REPORTERS, INC.
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~U 1 ability to protect the Tuscaloosa aquifer?
2 MR. CHURCHILL: Your Honor, he just answered the
.3 question.
4 JUDGE MARGULIES: I don't know that he finished 5 his answer. He started to answer there's a calculation but 6 he never completed the answer.
7 MR. LAWLESS: I'm sorry, I probably interrupted 8 him on that. I wanted to alert him that we'll discuss'the 9 calculation at a later point. What I was interested in nore 10 was, in general, what effect does this cut have on the marl's 11 ability to protect the Tuscalvosa aquifer? Doce it reduce 12 it, enhance it, or have no effect?
13 THE WITNESS: (Farrell) The assumption is that the 14 portion of the marl that has been removed is reduced, the 15 effective thickness of that marl as a confining member.
16 BY MR. LAWLESS:
17 Q Thank you. On page 13 --
18 A (Farrell) Could I supplement that answer a little 19 bit?
20 Q Sure.
21 A What I was alluding to earlier was on page 20 of 22 our testimony it says, the last paragraph, " applying the 23 valuce aoove for the three controllir.g parameters" -- et 24 cetera, et cetera - " groundwater velocity in the marl is 25 calculated to be .31 feet per year and the time required to ACE-FEDERAL REPORTERS, INC.
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I traverse the 38 feet of marl would be 123 years."
2 Q Excuse me -- if I didn't cut you off --?
3 A If I could go ahead --
4 Q All right. Go ahead.
5_ A "Taking into account the retardation this travel 6 time is sufficient to reduce all radionuclides in the worst 7 case spill below the maximum permissible concentration set 8 forth in 10 CFR 20."
9 So the answer is it would have no effect.
10 Q Well, I beg to differ with you. Your colleague 11 I mentioned that it would reduce it, 12 It seems to me that there should be no objection r-]
%,/
13 to that comnent because, if the marl was 65 feet and has been 14 reduced from 65 feet down to 38 feet in thickness, then when 15 we get to the question of the calculation, the quantitative 16 calculation, why we can discuss that at that time. That's 17 why I meant to head you off. I apologize for heading you off 18 before you had finished your comment. But your colleague is 19 correct. It has reduced the effectiveness of the marl in 20 protecting the Tuscaloosa. It may not have prevented --
21 MR. CHURCHILL: Objection.
22 JUDGE MARGULIES: Mr. Lawless, it doesn't help the 23 record any by your lecturing these people as to what is 24 correct or incorrect. The record will only be developed by 25 asking them questions and developing facts. And from those ACE-FEDERAL REPORTERS, INC.
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1 facts certain conclusions can be drawn. But to engage in 2 this dialogue with the panel members, it does not add 1 anything to the record.
4 MR. LAWLESS: I agree. I agree. Thank you.
5 BY MR. LAWLESS:
6 Q On page 13, of the 22 exploratory holes three 7 measured water inflow. Supposedly this was in the weathered 8- marl.
9 Could you locate the three wells on one of your 10 diagrams: then I'll have a question on it.
11 A (Crosby) Could you give me the reference, please?
s 12 Q Yes. Page 13, second paragraph. You are talking b 13 about the 22 exploratory holes. At the last sentence on that 14 page.you are mentioning that there were three holes that did 15 have measured water intake confirmed -- which turns over to 16 page 14 -- two of which were in near-surface, weathered marl 17 at the intake structure.
18 A (West) Turn to figure 5.
19 Q Okay.
20 A There is a group of holes out near the river at 21 the intake structure. You see a group, then they are all 22 preceded by the letter "P" -- 1. 2, 3, 4, 5 -- et cetera?
23 Q Yes.
24 A This is the group of holes.
A)
(- 25 Q Thank you.
l l
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1 There was measured water inflow inte these 2 exploratory holes. Does this indicate that contamination 3 reaching the stream beds or exposed marl may pener. rate the 4 marl?
5 A No.
6 Q How long was the marl exposed under tne pcaer 7 block during the excavation?
8 A (Crosby) Could you ask the question again, 9 please?
10 Q How long was the marl exposed at Vogtle during the 11 construction?
12 A It was exposed for a very limited amount of time.
13 There were specifications that required that it be covered, I 14 think, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. That's just my recollection.
15 Q Was there any cracking as a result of exposure?
16 A No. Great care was taken to be sure that it was 17 covered in a short period of time to prevent dahydration.
18 Q On page 14 you mention, towards the bottom of the 19 page in the second to last paragraph, you've got low 20 permeability of 8.5 times 10 to the minus 6 and another 21 number of 5.0 times 10 to the minus 9.
22 What distributior of the data did you find?
23 A (Farrell) You mean wilat were the values?
24 Q Yes. You made this statement: "The laboratory 25 permeability measurements ranged from 8.5 times 10 to the ACE-FEDERAL REPORTERS, INC.
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1 minus 6 to 5.0 times 10 to the minus 9 centimeters per 2 second."
3 What can -- can you describe the distribution of 4 the data itself; the means, standard distribution, et 5 cetera? How many data points?
6 A There were 10 samples that were tested and the 7 permeability measured in those tests ranged from -- within 8 that range as was stated there.
9 Q Did you have a mean?
10 A No.
11 Q Did you -- do you have the standard deviation?
12 A We did calculate the harnonic mean. I assumed you
. 13 meant, by nean as the arithmetic mean?
14 Q Yes. Right. You calculated the harmonic mean --
15 or you calculated the harmonic -
- excuse me -- permeability, 16 period? You've got the range and you calculated the harmonic 17 permeability?
18 A The harmonic means.
19 Q The harmonic means -- yes. I'm sorry. Is that 20 ,
right? That's all you did?
21 A Yes.
22 Q Okay. No standard deviation, though, and no 23 arithmetic means?
24 A flo .
mi 25 j
JUDGE PARI 3: Can I ask a question?
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, *RT 353 N) 1 MR. LAWLESS: Yes.
2 EXAMINATION 3 BY JUDGE PARIS:
4- Q Can you give us some idea how the values were 5 distributed between 8.5 times 10 to the minus 6 and 5.0 times 6 10 to the minus 9; were they skewed in one direction or 7 another? Were they more or less distributed equally across.
8 those values? How were they distributed?
9 A (Farrell) I believe they were skewed on the high 10 side.
11 Q Do you have the values there?
,S 12 A Yes.
O 13 Q Can you read them?
14 A The values --
15 A (Crosby) Let me tell you where this document is.
16 This is the geotechnical verification report which was 17 submitted to the NRC and the laboratory prepared -- performed 18 the laboratory tests and the 10 numbers that he's going to 19 report are from that test, those tests.
20 MR. CHURCHILL: Would you like -- would the Board 21 like copies of that document? Actually, I have been informed 22 they were attached.to our reply to intervenor's response to 23 cur motion for summary disposition.
24 MR. LAWLESS: What report was this?
fh A/ 25 JUDGE PARIS: Go ahead and read them for us now.
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1 THE WITNESS: (Farrell) 5.01 times 10 to the minus
- 2. 9; 1.95 times 10 to the minus 6; 1.94 times 10 to the minus 3 7; 4.99 times 10 to the minus 7; 2.06 times 10 to the minus 4 6; 2.42 times 10 to the minus 6; 1.41 times 10 to the minus 5 6; 8.49 times 10 to the minus 6; 1.39 times 10 to the minus 6 7; 7.81 times 10 to the minus 8.
7 JUDGE PARIS: Thank you.
8 CROSS-EXAMINATION (Continued) i 9 BY MR. LAWLESS:
10 Q This is skewed toward the higher end or towards 11 the lower end?
12 A (Farrell) Skewed towards the high end of the 13 values.
14 MR.. CHURCHILL: Could we have some clarification 15 about what higher means and lower means and, while we are at 16 it, what skewed means?
17 MR. LAWLESS: Yes. Yes.
18 THE WITNESS: (Papadopulos) Maybe this would help, 19 your Honor --
20 ,
JUDG2 PARIS: It seems to me maybe you read more 21 10 to the minus 6s than you did the lower values.
22 ,
MR. LAWLESS: That's right. But it depends on l
~
23 what tney interpret that to mean.
,_ 24 JUDGE MARGULIES: Let's have the definitions that 25 counsel asked for.
i ACE-FEDERAL REPORTERS, INC.
26113.0 T 21 1 THE WITNZ33: (Papadopulos) ?aybe this would 2 help. There's five values in the 10 to the minus 6 range, 3 three values in the 10 to the minus 7 range, one value in the 4 10 to the minua 8 range, and one value in the 10 to the minus S 9 range. All in centimeters per second.
6 EXAMINATION 7 BY JUDGE PARIS:
8 Q Then would you say that more of the values 9 indicated a low permeability?
10 A (Farrell) All of the values are a low 11 permeability.
- 12 Q Than an effectively impermeability -- or effective l
13 impermeability, if I may say that?
14 What bothers me is that in the testimony that you 15 have presented you say that the range was from 8.5 times 10 16 to the minus 6, which you, in parentheses say is low, to 5.0 17 times 10 to the minus 9 which in parentheses you say is 18 effectively impermeable.
19 Now are you -- the skew seems to be toward what 20 you called " low" ac opposed to " effectively impermeable" in 21 your testimony. Is that correct?
22 A (Farrell) I'm not sure that I would -- yes. It's 23 skewed towards the hiah range. I'm having difficulty when we 24 start talking about low, very low effectively impermeable --
25 we are getting too --
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1 Q You are saying it is skewed toward the high 2 permeability' range?
3 A The high permeability range of what would be 4' ' considered very low permeability.
5 0 .Yes. Okay. Okay. Fine.
6 MR. LAWLESS: Just of.e second, please, 7 JUDGE MARGULIES: Mr. Lawless?
8 ~BY MR. LAWLESS:
9 Q I calculate real quickly a mean of 3.747 10 A (Papadopulos) Is that an arithmetic mean?
11 Q Yes. With a standard deviation of 2.53. But I 12 think I will need to work with that a little bit.
O 13 Before I go further with that, I'll get back to !
14 that in just a little.
15 What is customary in the industry with 16 calculations -- what.is the customary practice of testing the ,
17 arithmetic mean and the standard deviation of these data?
18 A (Papadopulos) The standard practice in the 19 industry would be to disregard this data. We wouldn't do any 20 sta tistical data. These were all laboratory parameters which 21 were obtained during the conduct of other geotechnical 22 investigations and they cannot be substituted for any in situ 23 measurements of the hydraulic conductivity.
24 Q I think, if I understand you, then, there would be 25 no customary treatment of the data.
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- "RT 232 1 A If there were field values of permeability, the 2 normal procedure -- I shouldn't say normal, it is really the 3 exception -- if a statistical analysis were to be applied to 4 this data it would be a log normal distribution looking at 5 log normal distribution and calculating the log means, and 6 the standard deviation, the logarithm of those values.
7 Q I presume you are familiar with " Groundwater 8 Hydrology" by B-o-u-w-e-r that was cited in your documents.
9 A (Farrell) Yes.
10 Q on page 132 he notes that, at the bottom of the 11 first paragraph, "for uniform surface soils 10 to 20 f~s 12 replicate point measurements may be required to produce U 13 standard deviations that are less than 20. percent from the 14 mean."
15 A (Papadopulos) I think the statement is pointing 16 out the fact that there will be different answers in 1,7 permeability. If you wanted to have a standard deviation of 18 less than 20 percent from the mean, that you should have 20 19 -- at least 20 measurements, 10 to 20.
20 Q You do not feel that this is customary practice, 21 then, to do this?
1 22 l A I would like to draw your attention to another 22 reference by Frieze and Cherry, which are grcundwater 24 hydrologists, on page 40 of their book on groundwater, which 25 we'll be very happy to supply you a copy with, you will note ACE-FEDERAL REPORTERS, INC.
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26113.0 RT aus 1 that permeabilities would vary by large order in the same 2 aquifer, and that standard deviations of the order or .5 to 3 1.5 in the logarithm of those values are not unusual.
4 In other words, permeabilities could vary by one 5 to two orders of magnitude, and are acceptable variations.
6 Q Well, I'm not sure what the " acceptable" means.
7 But that was what you found in your own report that you had 8 about an order of magnitude difference.
9 It would seem to me that customary practice on the 10 data would be to make certain that a standard deviation in 11 the data is less than 20 percent of the mean. Otherwise the 12 standard deviation indicates that there is so much
~
13 i variability in the data that you can't be assured --
14 MR. CHURCHILL: Objection.
15 THE WITNESS: (Papadopulos) There is all these --
16 MR. LAWLESS: I'm sorry.
17 MR. CHURCHILL: I guess he's done but I didn't 18 hear a question. That was just testimony.
19 MR. LAWLESS: I was trying to phrase it with a 20 question. That it would seem that customary practice would 21 require that, that you make certain that the standard 22 deviation is less than 20 percent of --
23 MR. CHURCHILL: Why don't you ask the witness what 24 customary practice is?
- 25 MR. LAWLESS: I did. And he said he would throw ACE-FEDERAL REPORTERS, INC.
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l 1 the data away 4- or not use s ta tis tical trea t' ment. ,
2 THE WITNESS: garrell) The cus' tom' a ry practice sis 3 not to use statistical analysis of permeability data. You l'
4 evaluate the data. You have to take into consideration what l
5 the sample represents and the method of which the L 1
! 6 measurenqnts;were made.
e
! 7 s 'I think what Dr sPapadopulos was referring to was 8 that laboratory permeabilities, measurements, are normally i
9 not given the same credit as 'in situ tests.
I l 10 .
THE WITNESS: (Papadopulos) I would like to point l
11 out, to the reference that you cited, if you look about two 12 pages before page 132, ab' oui 130, there should be some
. 13 discussion of core sample s~'ana core permeability
! .i l 14 determinations. So that was the basis of my statement that I l
15 would throw out this data because there are core I
i 16 permeabilities for the determinations. ,
17 Coming to lhe later question, if it was A 18 question, on whether whht is acceptable standard deviation on l
_s s V 19 field data, there is no'such a rule as what is acceptable 20 standard deviation in data when we are dealing with natural 21 materials.
22 The natural materials have permeabilities which 23 range, have a very wide range of variation, and data do not 24 get rejected just because they don't fit a certain model of 25 standard deviation.
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, b 1 As far as the testing methodology has indicated 2 that there's a correct value of the permeability, it's part 3 of that' population of permeabilities that should be used in i
L 4 making use of -- the procedures are specific with respect to 5 how one would use this data that you have different 6 variations. In the case where the variations are in a layer 7 system -- and the reference that you cited would attest to
'8 .that -- the' harmonic mean is used to determine of what the l 9 effective permeability would be.
l 10 In the case where the system is heterogeneous, 11 then the geometric mean is used to be determined -- to
,- 12 determine what average permeability would be in the system.
(. 13 In the case the system is a layer system,.and we
! 14 are considering horizontal flow within that layer system, i 15 then we do use the arithmetic means.
. 1 46 I hope this clarifies the approaches which are 17 standard practice in hydrology.
18 BY MR. LAWLESS:
19 ,
Q Yes, the harmonic mean treatment -- the 20 calculation that was made was a decided improvement -- and I 21 agree with it.. But nonetheless the arithmetic mean can be -
22 used to calculate standard deviations to test the data 23 itself, to let you know whether the data is goed data, the 24 variability is acceptable, and so forth.
O 25
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l 26113.0
~^hT 537 1 in a brief. They serve no purpose here.
2 MR. LAWLESS: Right.
3 MR. DEWEY: Your Honor, this also goes to 4 statistics which I think the Board has also ruled on. I 5 question whether this line of testimony is actually relevant
, 6 since the Board has made a ruling.
7 MR. LAWLESS: That's an interesting comnent. The 8 Board ruled that Intervenors had not shown that the data had 9 been -- had not met certain customary industry practices, and.
10 here we are trying to show that it is quite possible that 11 they have not, indeed, met customary practice. This is a
-~ 12 citation that they use themselves and I think that issue is 13 raisable.
14 MR. DEWEY: I think you have mischaracterized what 15 the witness has said.
16 JUDGE MARGULIES: Let's move on.
17 BY MR. LAWLESS:
18 Q On page 16, the first sentence of the first 19 paragraph there, " Finally the large and consistent hydraulic 20 differential between the water table aquifer and the confined 21 aquifers immediately below the marl confirms that the marl is 22 a barrier to significant groundwater movement."
23- The question I have is this: First off, the 24 hydraulic head of the water table, aquifer, is it lower or s
25 higher than the confined aquifer?
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26113.0 7"pT- 393 Q ,1 1 A (Farrell) It is higher.
2 Q ~What does this mean if contamination is able to --
3 if the marl is broken, or discontinuous in any spot; what 4 does this nean for the contamination?
5 A I believe that this is the same -- essentially the 6 same question you asked before, about if the marl failed?
7 Q Well, it's a little bit different. One of the 8 : comments that:the Savannah River plant'has madeJoften is the 9 higher differential, the higher head of the Tuscaloosa 10 underlying the aquifers above, prevents downward migration of 11 contamination.
6 g- 12 A . I didn't say that the Tuscaloosa was higher. You
'% ) 13 I asked -- .
I .
14 Q I asked about the confined. Yes. I was referring 15 to a specific example to help you with the question.
16 MR. CHURCHILL: Could we have the question again?.
17 BY MR. LAWLESS:
18 Q If the hydraulic head of the water table aquifer 19 is greater than the confined aquifer, what does this mean for 20 any contamination that can breach the marl?
21 A (Farrell) The potential gradient across the marl l 22 is downward. Migration water in the marl will be downward.
23 Q In figure 10 you have added a groundwater divide.
24 Can you explain the significance of what would happen to 25 spills atop the divide?
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26113.0 RT S33 1 A (Farrell) The significance of a spill atop the 2 divide?
- 3 Q Right on the center of a divide.
4 A I'm not sure what you mean.
5 MR. CHURCHILL: Your Honor, is this a hypothetical 6 question?
7 MR. LAWLESS: Yes.
8 MR. CHURCHILL: If it is a hypothetical question, 9 I would in this case ask that he explain the relationship of 10 the hypothetical to the issue before us.
11 MR. LAWLESS: On figure 10, what is the 12 significance of the groundwater divides -- and there are --
13 j MP. CHURC' HILL: I'm sorry if I could cut this a 14 little short. If you are going to have a hypothetical about 15 a spill right on the ridge, the apex of the groundwater 16 divide, I think we have to relate the possibility of that 17 hypothetical -- relate that hypothetical to the possibility 18 of anything like that happening in real life at the plant.
19 And I think you have to first establish that there is a 20 relationship between the hypothetical and the situation that 21 we are faced with.
22 You can establish that by asking these witnesses 23 those questions.
24 MR. LAWLESS: That would be fine with me if they 25 want to preface their answer.
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1 MR. CHURCHILL: I'm going to obiect to the 2 hypothetical question unless it's established that there's a 3 relationship between that and the situation that we have at 4 Plant Vogtle.
S- JUDGE MARGULIES: Could you show that it i.in't 6 wholly speculative?
7 MR. LAWLESS: Applicants have provided information 8 .before about the flow of the groundwater. And.any 9 contamination that enters into the groundwater would flow in 10 such and such a direction.
11 I would like them to relate that flow of 12 information, their own hypothetical information, to a spill
'O 13 that occurs imme.diately atop a-groundwater divide -- any 14 groundwater divide. We can generalize from that,.
15 MR. CHURCHILL: Your Honor, unless he can 16 establish -- and he's free to do it by questioning this 17 panel, if they know -- that it's possible for a spill to 18 occur on top of a divide, I have to object to this 19 hypothetical.
l 20 JUDGE MARGULIES: Does the divide come anywhere 21 near the plant itself?
22 MR. LAWLESS: Yes. If you look on figure 10, it
. 23 is very closa. Ir. f a c t , you've got groundwater divide as 24 represented by little bitty circles, and you can see it very 25 i close to the plant.
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1 In fact, one of the groundwater divides probably 2 runs right underneath one of the coolino towers, or close to 3 it. I'm not certain about that, how close it is.
4 THE WITNESS: (Crosby) I believe, by checking the 5 scale on the figure, that it is approximately 700 feet from 6 the aux building. So, as a result, if there was a spill the 7 flow would be to Mathes Pond, as we stated in our testimony.
8 BY>MR.. LAWLESS:
9 Q But for that to occur, it would have to happen on 10 a favorable side of the groundwater divide; is that correct?
11 A (Farrell) Were that to occur where the auxiliary
- 12 building is, that's on one side of that divide.
'~ 13 And it would also have to be straight downward '
Q 14 it would have to be in a direction that there were no 15 channels or dothing else in the backfill material itself that 16 would preclude the movement of the contamination in a 17 favorable direction; is that right?
18 A I'm not clear what you mean " favorable 19 direction." What do you mean " materials in the backfill" 20 that might preclude another direction?
21 Q Well, it appears to me if contamination could 22 reach one of the divides, that it may go in a direction that 23 you had not planned for it.
24 A It's unclear to me -- you talk about contamination 25 reaching a divide. By what mechanism are you postulating --
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26113.0 j 7RT 402 L,l 1 Q At the Savannah River plant it was quite common 2~ for contamination on one side of the divide to go in a 3 direction opposite contamination on the other side of the 4 divide. I don't think that's a very difficult or obtuse 5 question. I think it's very direct.
6' JUDGE MARGULIES: The fact that it happened at the 7 Savannah River plant, what is there to indicate that the 8 physical circumstances are the-same here as they are at the 9 Savannah River plant?
10 MR. LAWLESS: They are not. Not with the plant at 11 all. But groundwater divides are groundwater divides. l s 12 JUDGE MARGULIES: Are you talking about the 13 backfill reaching the groundwater divide?
14 MR. LAWLESS: Groundwater divide appears to be 15 going through the backfill.
16 THE WITNESS: (Papadopulos) The groundwater divide 17 is going 70 feet south of the backfill area. The backfill 18 area is the square in the middle of that figure.
19 There are no potential sources outside that 20 backfill area or near that divide area and I would like to 21 point out that we keep hearing about the Savannah River 22 plant. The Savannah River plant is an area where there are 23 waste disposal areas all over the site; some ene Jide of a 24 divide and some the other side of the divide. So I would O
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1 one side of the divide and ended up transporting 2 contamination to the other side of the divide.
3 MR. LAWLESS: 'The divides are very close to the 4 plant and it's a three-dimensional direction _to the divide.
5 MR. CHURCHILL: May we just have questions, 6 please, Mr. Lawless?
7 MR. LAWLESS: It's a three-dimensional direction 8 to'the divide. Is it not possible, as close as the divides 9 are to the plant, that contamination could reach the divide?
10 THE WITNESS: (Farrell) The purpose of the 11 groundwater -- the groundwater divide illustrates by g 12 definition the point at which movement of water on one side t )
'~'
13 oE that divide is in one direction and on the other side of
.14 the divide is in another direction.
15 Hydraulics are such that the flow of water is in 16 the direction of lower head, the direction of a sloping water 17 table.
18 I'm not sure how you can explain water migrating, 19 in effect, up gradient.
20 BY MR. LAWLESS:
21 Q Well, I think you have answered what I was looking 22 for. Indeed, if anything did fall on the other side of the 23 divide or on top of the divide, and the divide is very close 24 to the power block -- in fact, the divide runs right down the 25 center and I assume they just took the geometric mean --
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26113.0 onT 404 1 MR. CHURCHILL: Your Honor, this is just testimony 2 by somebody who is not sworn and not a witness.
3 JUDGE MARGULIES: Testimony from someone who is 4 not sworn and not a witness will not be considered. It's of 5 no useful purpose.
6 MR. LAWLESS: I think -- in the purpose of trying 7 to give definition to the question the Applicants have noted 8 that the groundwater divide location at this time is 9 uncertain because groundwater movement inside the fill is --
10 MR. CHURCHILL: Your Honor, I object to this 11 summation, argument, and mischaracterization of Applicants' 12 testimony. They said no such thing. These witnesses did not 13 say what he said they said.
14 JUDGE LINENBERGER: Well, Mr. Lawless, I was 15 trying to understand. Were you attempting now to explain 16 I something to the board?
17 MR. LAWLESS: Yes. I thought I was.
18 JUDGE LINENBERGER: Somehow I don't think it was 19 coming through. Not because the Board is in such a state of I
20 abysmal ignorance, not quite; but because sonehow I heard you 21 say things at variance to what these sworn witnesses have 22 said and so I have a problem even listening to you explaining 23 something to the Board under such circumstances.
24 MR. TEPER: Mr. Chairman, in view of the fact that 25 neither Intervenors are skilled lawyers, we ask you to bear l ACE FEDERAL REPORTERS, INC.
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405 1 with us as we attempt to ask -- build foundations and ask 2 questions that we believe will be helpful to the Board in any 3 decisions they might have to make. We could have Professor 4 Lawless say "is it true" before every sentence he makes.
5 He's not trying to put words in the mouths of the expert 6 witnesses. What he is trying to do, as all lawyers know, is 7 to build a foundation on which they agreed to certain 8 statements they might have made or conclusions that are made 9 and then follow the logical conclusion.
10 I apologize for the clumsiness of the process, but 11 I e.on't think it's unreasonable, with the cooperation of gg 12 expert witness.es, that we can move along -- if in fact what
(.J' '
13 professor Lawless is saying is not true, I believe the expert 14 witnesses have the expertise to answer appropriately.
15 I once again just ask you to bear with us in our 16 attempts to fashion out this information for you.
17 MR. DEWEY: Staff would like to make one comment.
18 Your questions should be in the form of questions rather than 19 statements. If you would explain that to Mr. Lawless --
20 MR. LAWLESS: I will try tJ do better on this.
21 But sometimes it seems that someone is saying: Well, what is 22 the relevance and I try to explain the relevance and then 23 domeone objects, well, tnat's not a question. So I get a 24 little bit lost in the fling.
25 JUDGE MARGULIES: Well, it is 5:00 now. I think l
i l
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.h 1 it would be an appropriate time to break. We have been at it 2 since 9:30 this morning. We've covered quite a bit of 3 ground.
4 We should discuss tomorrow's schedule. We would 5 like to make tomorrow as productive as possible. It is my 6 understanding you cannot be here tomorrow morning, 7 Mr. Lawless.
8 MR. LAWLESS: I am not certain. I will try to be 9 here in the morning. I am uncertain on it. I can be here 10 tomorrow afternoon for certain. ,
11 JUDGE MARGULIES: Tomorrow afternoon we have the
-s 12 site visit scheduled.
13 MR. LAWLEES: I will do everything I can to be 14 here in the morning.
15 JUDGE MARGULIES: Let's make alternative plans if 16 Mr. Lawless cannot be here in the morning.
17 We are going ahead with limited appearances. That 18 may not take up the entire morning. There may be breaks 19 between the time that people appear. ,
20 We were able to take quite a few people today 21 within one hour. We took about 15 people within the period 22 of an hour today.
23 I Will ycu be prephred, tcmorrow morning, Mr. Teper, 24 to argue the Applicant's motion to strike the :estimony of 25 William Lawless, if Mr. Lawless does aot appear?
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v 1 MR. TEPER: If Mr. Lawless does not appear, based 2 on -- is that. based on impeachment of his expertise?
3 JUDGE MARGULIES: That's based on the written 4 motion.
5 MR. TEPER: I myself, most probably, will not be -
i 6 the representative for GANE tomorrow. We will attempt to 7 have a representative prepared to argue that motion in the ;
- 8 morning.
9 JUDGE MARGULIES: Whether or not Mr. Lawless is 10 here? I don't want to put you to disadvantage. If it can't I 11 be argued with Mr. Lawless here, then the answer is no.
12 MR. TEPER: Okay. No. It would be most
~
13 appropriate for Professor Lawless to be here.
l 14 JUDGE MARGULIES: Is there anyone that will be 15 here to exam {ne on the other two contentions tomorrow?
I 16 MR. TEPER: Yes. There will be.
17 JUDGE MARGULIES: That's 10.1 and 10.57 18 MR. TEPER: That's correct. I believe a 19 convenient process would be to go ahead with the dose rate 20 effects if Professor Lawless is not here, if that is 21 convenient to the other parties. Hopefully Professor Lawless 22 will be here and we can get on with groundwater.
23 JUDGE MARGULIES: Would that constitute a problem 24 for the Applicant?
) 25 MR. CHURCHILL: I'm sorry, I didn't hear what was I
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1 proposed.
2 JUDGE MARGULIES: The proposal was that if 3 Mr. Lawless can be present. tomorrow, continue on with 4 groundwater. If Mr. Lawless cannot appear tomorrow to take l
i-5 up 10.1 -- l 6 MR. CHURCHILL: We will be prepared for either t 7 eventuality, yes. That's okay.
8 MR. TEPER: That sounds satisfactory, sir.
9 MR. BORDENICK: The state likewise would be 10 prepared for either eventuality. I guess the preference is, 11 if Mr. Lawless is available, that we get back to groundwater 12 on Thursday as opposed to Friday. But I guess that awaits
-O 13 his schedu]ing.
i 14 MR. CHURCHILL: Your Honor, I may have misheard.
15 I may have gotten my contentions mixed up.
1 16 10.5 is what was scheduled to follow -- the 17 solenoid valve testimony scheduled to follow 1.7, that's the 18 ene we were prepared to go ahead with tomorrow. IJ that what 19 you said or --
20 JUDGE MARGULIES: No. He said he would have 21 someone here to examine on 10.1 tomorrow.
22 JUDGE LINENBERGER: Dore rate effects.
23 MR. TEPER: I cot.1d have someone here to examine 24 on either tomorrow.
a n/
s- 25 JUDGE MARGULIES: Let's get it straichtened out ;
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2 MR. CHURCHILL: We would prefer and could be ready 3 to go forward with direct testimony on 10.5, ASco solenoid 4 valves, or to continue with the cross-examination, if 5 Mr. Lawless is here.
6 JUDGE PARIS: I'm becoming concerned to the extent 7 we are breaking up blocks of testimony in this transcript. I 8 would like us to. continue with 10.5 tomorrow since we started 9 10.5 today.
10 , MR. TEPER: That is satisfactory to Intervenors'.
11 JUDGE MARGULIES: Lo the parties fully understand 12 that? We will attempt to go with 7, and if we can't go with n'~ 13 7, we'll do 10.5?
14 MR. BORDENICK: That's understood and acceptable 15 to the staff.
16 MR. CHURCHILL: Yes, sir.
17 MR. TEPER: Yes.
18 JUDGE MAPGULIES: We never did inquire of 19 Applicants. Is the on-site visit all set up and ready to 20 go?
21 MR. CHURCHILL: Yes. We are prepared for the 22 on-site visit. What time would you like to start the visit?
23 JUDGE MARGULIES: How long do you envision that 24 the visit will take?
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'RT 416 1 Applicants if we are going to see any ASCO valves, since it 2 does pertain to these hearings?
3 MR. CHURCHILL: A tout could take an hour or it 4 could take two hours or more, depending on what the Board 5 would like to see. We can't show you the groundwater 6 divide.
7 (Laughter.)
8 MR. TEPER: Do you have any exposed blue marl?
9 JUDGE PARIS: Could you take us on the surface to 10 where it is?
11 t1R . CHURCHILL: We do have some blue marl perhaps
-- 12 down by the river. It looked red to me.
13 JUDGE MARGULIES: Are these slipoery slopes that 14 l everyone talks about?
- 15 MR. CHURCHILL: I think we are on them. The tour, 16 you have to take into consideration that it will take a while 17 to get to the site. That's probably what, a half an hour 18 from here? Half an hour from here and to get organized and 19 through security.
20 I would be very surprised if we could get back 21 here in less than two hours, probably more, considering the 1
22 ' transportation time.
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l 26113.0 RT 411 1 discussed exactly what you have in mind.
2 JUDGE MARGULIES: What if we go until 12:30 as 3 part of the hearing process tomorrow and then take whatever 4 time there is left in the afternoon for the site visit and 5 not attempt to get back here?
6 MR. CHURCHILL: Let me check on rush hour traffic 7 conditions.
8 MR. WHITNEY: That will be fine.
9 MR. CHURCHILL: That will be fine.
10 JUDGE PARIS: Will we need boots?
11 MR. WHITNEY: Hard-scled shoes, your Honor. No
-~ . 12 open toes, no tennis shoes.
13 JUDGE M.TRGULIES: Is there any problem in terms of 14 looking at the valves?
15 MR. WHITNEY: No, there is not.
16 MR. CHURCHILL: I think they are accessible, but 17 not to very many people at a time. If the tour is too big, 18 if the group that's going is too large, there may be some 19 logistic problems. But I'm told that we can see some valvec.
20 JUDGE MARGULIES: How many people do we anticipate 21 going? We have the three Board members. How many from the 22 Intervenor?
23 flR . TEPER: I dor.' t imagine it would be more than 24 three or four.
25 MR. CHURCHILL: Is that satisfactory?
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'RT 412 1 MR. CHURCHILL: Could we go off the record to 2 discuss this?
3 JUDGE MARGULIES: Off the record.
4 (Discussion off the record.)
5 JUDGE MARGULIES: Back on the record. We have had 6 a discussion as to what the nature of the tour will be and 7 how mar.- people will appear for each side.
8 Will you just summarize that for the record so it 9 is clear and everyone knows what's involved?
10 MR. WHITNEY: Yes, your Honor, we will.
11 Tours will begin tomorrow afternoon. I don't 12 think we established a starting time. At least I didn't mark 13 i it down.
14 JUDGE MARGULIES: No, we haven't. We were 15 thinking of going as late as 12:030 or 12:30.
16 MR. WHITNEY: Lunch break combined with travel 17 time, would 2:00 be appropriate?
18 JUDGE MARGULIES: You think that would be adequate 19 for making the tour that you have outlined?
20 ! MR. WHITUSY: That will be fine. The tours will 21 start tomorrow at 2:00. The participants will meet at the 22 simulator building which is located on the Vogtle project, 23 and tomorrow morning ue will provide directicus to all the 24 participants on how to get to the simulator building.
~
25 The tour groups will be five or six in number and ACE-FEDERAL REPORTERS, INC.
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26113.0 RT 413 1 each group will be escorted. The itinerary will include an 2 overview of the project, including the prominent structures 3 on that project; a drive through or around with a description 4 of the different structures on the project; we will then 5 leave the vehicles and walk through the project. In doing 6 that walking tour, internal structures will be identified f:r 7 the tour participants and that tour will also include the 8 walking -- the walking tour will also include an examination 9 of the in-place ASCO solenoid valves. The tour will also 10 include an examination of the intake river structure on the 11 project and an examination of Mathes Pond.
12 We would anticipate that the tour itself will take 13 between one and two hours, depending on the detail and how 14 quickly the' participants in.the incividual tours move through 15 the project.
16 JUDGE MARGULIES: And it is understood that there 17 will be the three Board members, seven from Staff, and three 18 or four from GANE.
19 MR. WHITNEY: And all three or four will be 20 representatives of GANE.
21 JUDGE MARGULIES: Is that understood by all the 22 parties?
e 23 MR. TEPER: Yes, it is.
24 JUDGE MARGULIES: There being nothing further, we 25 will recess until tomorrow morning at 9:30.
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20113.0 "T 414 1 (Whereupon, at 5:17 p.m., the hearing was 2 recessed, to reconvene at 9:30 a.m., Wednesday, March 12, 3 1986.)
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CERTIFICATE OF OFFICIAL REPORTER
()
~
'O This is to certify that the attached proceedings before -
the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: ,
NAME OF PROCEEDING: GEORGIA POWER COMPANY, et al.
(Vogtle Generating Plant,
, Units 1 and 2)
DOCKET NO.: 50-424 OL; 50-425 OL PLACE: WAYNESBORO, GEORGIA '
DATE: -
TUESDAY, MARCII 11, 1986 were held as herein appears, and that this is the original -
transcript thereof for the file of the United States Nuclear Regulatory Commission.
/
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JO DREITNER Official Reporter ACE-PEDERAL REPORTERS, INC.
Reporter's Affiliation
.