ML19343B009
| ML19343B009 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/29/1980 |
| From: | Afifi S BECHTEL GROUP, INC. |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8011240443 | |
| Download: ML19343B009 (123) | |
Text
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. -ba .% :::a ::f: CCNSUMERS PCUER COMPNTY : DdCKET NCS.
(MIDLAND PLXIT, UNITS 1 NID 2) :
! 50-329-CM ,
50-330-CM 50-329-CL l 50-330-CL i
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l Ceposition of SHERIF EL-S AYED AHMED AF FI i
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- Ccto'cer 29, 1930 ?AGII: 1 - 123 l
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! .ul)ERS0X _ ' , REPORTITG
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1 i THE UNITED STATES 2l NUCLEAR REGULATORY COMMISS*CN l 1 3l--------------------------------x '
I 41 In the Matter of:
, s 5 l CONSUMERS POWER COMPANY l 2
UNITS 1 AND 2)
I (MIDLAND PLANT,I---------------
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- 6 7 777 East Eisenhower Parkway i
- Ann Arbor, Michigan '
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e Wednesday, October 29, 1980 l
- 9 I
@ 10lI Ceposition of z ,
- I j 11 SHERIT EL-SAYED AHMED AFIFI ;
W
- y. 12 l the depenent, called for examination by the staff of the ;
- i 13 I Nuclear Regulatory C0= mission, pursuant to notice, at 9:30 A.M., !
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= 1 i M 14 1 when were present on behalf of the respective parties: '
- I E
2 15 l For the Nuclear Rec _ulaterv_ Commission .
g 16 j WI;LIAM PATON DARL HCOD e ; 6 i
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3RADLEY JONES w I a 18 JOSEPH KANE
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. > 4 g I9 l - On Behalf of Consumers Power Company i
20 ALLAN S. FARNELL i t
21l RONALD ZAMJdtIN i ,
22 JAMES BRUNNER !
23
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- ALDERSON REPORTING COMPANY. INC. ;
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i On Behalf cf -he Armv Cer; cf Engineers 1l ;
2 RONAI.D IR OKSON j i
3 HAR: H. SINGH
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! 4 JAMES W. SIMPSON l 1
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28 MR. PA;oN: This is the deposition of Sherif Afifi i
3 of Bechtel, Incorpcrated. It is in the matter of the Consumer f
4 l Power Company.
This deposition is being held Wednesday, ,
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5l october the 29th, 1980 and the docket numbers are:
n g g )I 50-329-OM, 330-oM, 50-329-OL, 330-OL. This arises out of R 7 the December 6,1979 order modification construction permit.
- u j 8 j For the record a question was asked by Mr. Itane
- J l 8 2,
9l d during his deposition as to whether or no he would supply 1
g 10 L a reference to some information that he has given. I am z
. c 5 11 about to put that into the record and the question was would I2 lhe supply a reference to information concerning the surcharge
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13 i, problem applied to the structure, and the sa=e reference was 3
l 14 ql also used by Mr. Kane in understanding surcharc,ine and the j
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I se::lement problen, and the reference was the design of g 16 l foundations with control of settlement. Society of Civil
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17 ' Engineers Soil Mechanics and Foundations Division Conference s
E 18 ) held June 16th through:he 19th, 1964 at Northwestern ,
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$ l9 2*Jniversity.
M k 20l MR. FARNELL: s that a reference to a particular IIfjournal? Is it published in a period cal publication?
?
22l MR. PATON: For this particular conference.
r, 23 MR. FARNELL: If I go to the library I can reference 24 ,s. 4 3 .
25 MR. KANE: You should have no trouble. a i
h l P- ALDERSON REPORTING COMPANY. INC.
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l, 4 II MR. PATON: We are going to ask the persons i.. the 2 l room to identify themselves.
3 MR. PARSE;;: Allen Farnell on behalf of Consumer 4 Power.
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5 MR. ZAMARIN: Ronald Zamarin on behalf of Consumer N
3 6 ;a power,
- 9
- U j 6 7 i MR. BRUNNER: James 3 runner on behalf of Consumer
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Power.
- J l 8 9 Ronald Erickson, Army Corp of MR. ERICKSCN:
s g 10 Engineers.
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II l 4 MR. SINGH: Hari Singh, U.S. Army Corp of Engineers.
i 12 8a MR. KANE: Joseph Kane, the U.S. Nuclear Conmission.
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5 13 4 MR. SIMPSON: James W. Simpson, Army Corp of
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x 5 I4 Engineers, North Central District.
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- 15 ;' MR. HOCD
- Carl Hood, NRC. '
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3 16 l8 MR. JONES: Bradley Jones on behalf of the
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. SHERIF EL-SAYED AHMEO AFIFI
- M g I9 5 having been first duly sworn was examined and testified as
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20 { fc11ays II EXAMINATION
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22 - 3Y MR. PATCN:
23 What is your full name and business address?
Q 24l A Sherif El-Sayed Ahmed Afifi, 777 East Eisenhower 25 Parkway, Ann Arbor, Michigan.
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5 ALDERSON REPORTING COMPANY. INC. '
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I! Q Doctor, I show you the pages : have here entitled 1
i 2i Personal Resume with the name Sherif Afifi and : ask you is 3 that an accurate statement of your resume?
4i A Yes, sir.
g 5j. MR. PATCN: This is NRC Deposition 1 and today if A
- I g 6 j 10-29-80 n .
b 7I BY MR. PATON:
n I j 8l Q Doctor, is it correct to state that you received e
8 9 a 3.S. in civil engineering in 1961 at A-i-n Shars University?
?,
@ 10 g A Yes, sir.
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@ II Q In Ciro.
3 In that course of studies listed to that degree I 12 l a
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1 5 13 i in 1961 did you take any courses in soil engineering?
= i x I 5 14 A A Yes, sir.
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15 l C Tell us how many courses and what they consisted of.
- I y 16 l A To the best of my recollection, I don't recall the y
17 j number in soil, that was =any years ago, but I can provide
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{ 18 l information. I took more than one scils in
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? 19 [ undercraduate work.
n 20 g Q Do you know that you took more than two or three?
2Il A I think so, .v e s .
s 22 Q You received an M.E.5. in civil engineering from a
23 ! the University -
of Michigan?
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24l A Yes, sir.
i 25 g. What,is an M.E.S.?
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1i A That is the general = aster of science in engineering.
2 Q Did you have ecurses in scil engineering for that 3 I degree?
4 A Yes.
- s 5li> 0 Will you tell me what they were?
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< 6 !, A I can attemet to recall all of them I had.
There
- 5
' " 1 E 7 was Theoretical soil Mechanics, two courses, one entitled
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M 3 8 Scil Mechanics and the machanics lab, I had f=undations in n
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- 9 eng neering. These are soil courses I recall that I have i-10 taken in the University of Michigan. I have transcript
@ o z-la 11 and can provide you with it. I have forgotten many of the d 12 ; ccurses.
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- 13 I Q All right, sir.
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14 l i Did you write a thesis?
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- l 2 iS h A Correction. At Michigan these are -- my program 5
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- l was a continuous master in soils and I have taken other p 17 i courses , o f course.
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= 4 E 18 b Q You are indicattng that perhaps some of the courses I
x 19 were taken for your Ph.D. Degree; is that correct?
A ;
20l; A Part of it. It is very difficult to recollect i
21 ! now, many of my credits were used for my Masters, and how many 12 C for the Ph.D. of the total number.
23 : Q Tell me the complete list, your list of courses in a
4 24 3 is soils?
25 - A This is a lis in the program.
f li ALDERSON REPORTING COMPANY. INC. .
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6 4
1 O Did you write a thesis for your Masters?
2 A No, sir.
l 3 l Q Did you write a thesis for your Ph.D. Degree?
4 A Yes.
c 5 Q What was the subject?
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A It was titled Effects of Stress History on the Shear
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R R. 7 Modulus of Soils whereby I conducted laboratory experiments.
M i 8 Q You indicated a major in civil engineering. Within n
J t 9 civil engineering did you major in any particular field such
.5 10l i as soil engineering?
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3 11 1 A Generally in civil engineering you are requ_ red to I
a i j j 12 j take other courses, structural engineering, mathematics ,
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- j 13 l engineering mechanics and these are major thines._
I can't
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3 14ll recall all of them right now.
2 15 ! Q Want to complete your statement of your education w
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x 4 E themselves with soil engineering, and I am speaking of one-week l } 18 l- ? 19 ; courses or training at work, anything other than what you have M #
20 mentioned so far.
21 4 MR. FARNELL: Internal or.outside?
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22 3 SY MR. PATON:
23), Q Other than the formal education courses, any other i
l 24 j education _you have with Bechtel or otherwise you have taken 25 in soil, soils engineering?
a s ALDERSON REPORTING COMPANY. INC. '
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i 1f A Except for conferences with soils don't believe I
have.
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3, Q Will you tell us about them?
4 A It was a series of conferences on soils.
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- 5), Q Many conferences, is that accurate?
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6 A : would say several conferences. That is accura e.
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.i n L f.- Q How many conferences have you attended in the last . -
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I j 8 five years, approximately?
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= 9j A '"wo or three.
i-l E 10 ( Q Those were concerning soil or soils engineering?
5 I
2 11 A Yes.
a i 12 Q Dr. Afifi, I want to talk about "our work experience.
I d s 13 I I will refer to your resume starting at the first position
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14 indicated for approximately four years you with an organization 2 i 2 15 ; S-a-b-r-a and Y-o-u-o-r in Ciro?
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,l 16 A Part-time employment.
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17 l Q What did v.ou do there?
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E 18l' A I was working as a designer of-foundations and
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4 2= 19 ,: strue:ures for various industrial and residential settings, F. t 20 $ -light industrial.
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Q September, '61 through December, '65.
21f .
c 22 L Your resume is self-explana ary. You were a.
23 teaching assistant at the A-i-n University in Ciro?
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24 L A Yes.
t 25 . Q Was that full time?
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k Q You did that at the same time you were working for ,
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- 3) the firm?
i 4l 8 A Yes, I did that on the sifa.
e 5! i Q Your resu=e indicates that January, 1966 through
. n N
1 3 6 E May, 1970 you were a research assistan: teaching fel'cw and e 5
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- ), 7 T at the University of Michigan. Was that
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full-time?
., t A A combination of all three constituted my full-time 3
i 9lt E 10 i involvement.
i i 11 '- Q January of 1970 to September,1973 you were in
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d 12 5) Cakland, California, and what did you do?
z H 5 13 j A : was working on the Trans-Alaska pipeline project.
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.A 14lIspent all my time working on the project and it included -
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exploration for the six hundred mile pipeline. I was involved
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16 ! in selecting the soil samples and assigning laboratory tests 3.
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17 t and writing reports for.different sections of the pipe.
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, E 18 l I assisted other people and my prime capacity was 4
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C 19 the designer of the pipe and pipes of that kind. At the time
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, a ,i 20j the office was in Houston,-Texas, but my empicyment was in
! 21 ij oakland, California.
r 22 3 Q In the field or office?
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, 23 i A Most of the time in the office.
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24j Q am looking at. a designation which is'H and C S D 25 ; 1 Geotechnical 3echtel.
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1S A Yes, Hydro and Community Services Division.
i 2f Q Is that part of 3echtel, Inc.? 4 1
3l A Yes.
I 4i Q Is _ Hydro and Ccmmunity Facilities a division under s 5 any organizational structure under Sechtel or does it go from e i 3 6I Sechtel to Hydro and C0mmunity Facilities?
. i, l 1
$ 7 l A I am not f amiliar with the structure up on that. 1 s i j 8 ! Bechtel, Inc. is one company, one of Bechtel's ccmpanies.
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Q Is 3echtel located anywhere else besides Ann Arber? e
$ 10 tl A To my knowledge it is situated in San Francisco, z : ,
j 11 I California. That is the main place. There are other effices g
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One of them is in e k
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Q De .vou know how long this office of 3echtel in .
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15 ) Ann Arbor has been here?
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y 16 8, A I don't know how long. I don't know exactly how a 4 .
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18l Q Approximately?
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$ 19 ? .A I joined in 1973 and I understood the office may n .
. 20 ,$ have been in existence for one or two years.
1 21l Q Does Bechtel have any difficulty in recruiting h
22 5 people to man this office?
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- 23) MR. FARNELL: Clarify the time.
24 j BY MR. PATON:
25 i Q Since this.o:fice has been here. You said you got i;
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1 ! here in 1973?
l 2; A Yes.
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Q Did you hear at that time er prior if Bechtel had 4 difficulty in finding people. to man this plant?
I e 5? MR. FARNELL: What types; secretaries, clerical, p
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I a 6E there are different tvees of c.rofessionals.
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. n e Just answer the cuestion.
E A 8 SY MR. PATON:
d 2 9 g All people?
2,
@ 10 .. A I am not sure. I am not sure if they did or not.
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t g 11 ! Q lt's your statement.
8 l y 12 j Did you ever hear anyone discuss that subject?
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13 { A : believe : heard ceople sav. that some people were i
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i 14 l leaving, things like that. But I'm really not sure if it w n
= 4 2 15 ~ related to difficulties with recruitine. or ceople found a
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y 16 better places. I am not sure if I heard something specific. ,
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o Within the 3echtel organi:ation in Ann Arbor was
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18 pi San Francisco considered the more desirable c. lace to work?
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3 19 ? MR. FARNELL: By whom?
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MR. PATON: By anyone in Bechtel.
t, 2I] BY MR. PATON:
22 : .
Q Have you ever heard a discussion of that?
23 4 MR. FARNELL: Objection to the form.
24 SY MR. PATON:
1 25 0 of that subject?
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A To the best of my knowledge -- it depends On the 1l:.
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I Some people like Ann Arbor and scme people don't.
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Q Am I wrong is saying that the =a;cr Opinion w0uld San Francisco for desirabilitv.?
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5, MR. FARNELL: Objection as Oc the forr..
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n 6l A : would like to understand from you what you mean 7l 2 bv. desirable?
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5 3Y MR. PATON:
d 8'lg o 9I Q You don't understand =y question?
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10 le A I would like to know desirable as to what.
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3 Q Oid Bechtel, Inc., to your knowledge, have any i
i 12 ) difficulev. in recruiting engineers to werk in the Ann Arbor z
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3 E 13 i3 office in 1973 and crior?
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1 i m 1 .= 14 MR. FARNELL: Asked and answered.
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$ 15g MR. PATON: He had difficulty with recruiting.
t 16 l MR. FARNELL: You're talkinc about desirability, M r 2 3 4
y* 17 j not recruiting, ti
- i i E 18 8 MR. PATON: He didn't understand my question so I l
- e. 19 1,i 6 changed it.
5 r: F
, 20l A Will you repeat it?
21( ,
3Y MR. PATON:
22 5 0 Have -vou ever heard anyone discuss whether Sechtel 23 had any difficulty in recruiting engineering, engineers to 24
- acrk in the Ann Arbor office?
25 MR. FARNELL: Asked and answered.
t h ALDERSON REPORTING COMPANY,INC. i
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- 1. A I don' precisely recall this particular issue be ng h
2 j raised, but I heard some people leaving, scme people ge::ing i
3 l hired as will generally happen within a company. Some people I
4' like to stay there, some people don':. I cannot specifically a
5j say. I don't know if it was difficul: with recruiting for e
N 3
a 6a Ann Arbor cr if it was personal preferances.
f A 78 0 In September, 1973 you're employed by Hydro and n
n 8 Community- Facilities and you said division?
3 9 A Yes, i
e a h 10 ( Q The resume said H and C S D Geotechnical Services. '
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< 11 l A Right. -
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i 12 ; Q Which is it?
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- 13 f A Hydro Geotechnical Services is a sub-organization
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.A 14 of Hydro and Community Division.
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E 15 3 Q You went to work at Hydro and Community Facilities x i
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g 16 l Geotechnical Services, that organi:ation in September, 1973?
6 17l. A Yes, sir.
b i
E 18 n Q And you stayed with that organization?
=
_ i E 19k A Yes, sir.
5 0
" t 20j Q The name of that is Hydro and Community Facilities
- 1 21 5 Geotechnical Services; is that the name?
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A My employment, I'm a mamber of the Geotechnical
! 9, l 23 1 Services Group.
t 24 ,
, Q That is the third designation. You're a member of 25 the Hydro and Community Facilities Geotechnical Services Group?
a 4 ALDERSON REPORTING COMPANY. INC.
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F 13 A I'm not sure if group is part of the official title.
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26 I am not sure.
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3 ( Q What I want to know is what is the name of the .
4, organization that you are now employed with. I think you t
5I indicated you weren' t certain if it was a different division
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6 l; or group. You just said you're now employed by Hydro and
- s .
N 7l Community --
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a i n 8 A Division. '
d l 9 1 Q Geotechnical Services Group?
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@ 10 i A Hydro and Community, that's a part, Geotechnical is z t
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2 11 a sub-orcani:ation I'm a member of.
3 -
I d 12 i 0 The name of v.our sub-organization that v.ou're a z
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13 ! member of?
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14 i A To the best of my knowledge.
4~ J E 15 g Q Geotechnical?
t g 16 A I don't recall the word community, whether it's
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d 17 i part of the title.
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E Q I want to use-the word you used. You used the word
- 18 g M
19 ; group, or not?
1 n n 4
20 ! s A You call ourselves a group. I am not sure if that l
21l is part of the official title or not, t
t 22I s Q You say you worked at Hydro and Cc=munity Facilities .
i 23 ! Geotechnical Services?
24 3 A Yes, sir.
i 25 Q ! see that name is in connection with employment t.
! ALDERSON REPORTING COMPANY. INC.
t I '5 A
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16t frc= September, 1973 to March. I see the name J. H. Allen, is that 4
2 l+ vour supervisor or who was that?
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s 3 A Supervisor.
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4f Q Dr. Afifi, please rela:e your work experience since I
s 5. you have been with the Hydro and Community Facilities n b N
j 6fGeotechnicalServices, Incorporated, the nuclear program.
- u
- e j i 7 MR. FARNELL: : object to the form. :: calls fer n
j 8 l a narrative answer.
- 9 You can answer.
i y 10 , A My experiences in relationship :o the nuclear progra=?
z :
= i 3
@ II l I BY MR. PATON:
1 f5 12 (
6 Q Since you've been with tha detail.
s 13 ).,
A I've been involved in the Midland site. I've been z J 5 14 3 involved in Plan C and I have been involved in Greenwood 2 and 3, 4 h n i 15 a vandalia, Quanicasee and Palisades . I believe these are the
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. d j 16 { major ones I've been involved in.
x ;
t y 17 +: Q You mentioned one unit and that was Vandalia? -
t #
= 18)1 A Yes, it was a proposed plant. I understand i: never
$ 19 f got off the ground.
n y 20 0 At Quanicasee did your work there involve soil a
21 a engineering?
p t
t 22'j A Yes, sir.
s 23I Q Is there a particular problem with the soil at 24 ' Quanicasee?
25 A Yes.
.2 ALDERSON REPORTING COMPANY, INC.
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i 1 '. Q Tell us what that was.
3 2[ A came in af ter some of the work was completed. :
l 3 l cannot mention my knowledge of the progrs= at the beginning.
s 4t i
- was an original settle
- prediction based en the studies
. e. 5 made by the soil consultants, these were high and at a later e
6 date Dr. Pack got involved in the tests as suggested, implemented
- a
. 3 o R 7' and conducted the results of those tests. they revealed that n
n
! 8, the credicted settlement should be tolerable and thereby cause U i
- 9l the site to be feasible for the structure of the nuclear
$ \
@ 10 facility.
z
- 1 2 11 l Q Did those tests turn out to be correct to vour a
i 12 ;' kncwledge?
z
=
_ i j 13 '; A Yes. .
3 14 !, Q They predicted the settlement should be tolerable?
- 5
= n i 15 x a The plant was not, it did not continue. The program b-b r
a 16 I was canceled at some coin: after the work was done.
A B
(t 17 ) a Q Did Dr. Peck recommend taking any, field tests?
E 18h A No, my knowledge, that work was neither recommended
. E.
. - 8 x 19 4 hv. D.r. Peck or Hendron.
a J 20 h Q I believe you stated that the original se : lament
)
t 21 [ prediction was high; is that correct?
9 22( A Yes.
9 23 , O How, do you know how that was determined?
24 1 A Yes, on the basis of the lab tests.
25 Q Do you know how they learned that it was high?
a t ALDERSON REPORTING COMPANY. INC.
\
3s I
1* A No You said, : thought you ss-d that someone disc vered 2{ Q 3 yi tha t the original prediction was high. Did you say tha:?
4 A I s,tated tha: the numbers that came out there were
, sn 5 high and any soil engineer would recognize the high settling N $
g 6 l and it would be unacceptable.
- 1
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E 7 ;l Q Greenwood 2 and 3 involved soil engineering?
- j 8 ;P A Yes.
U l n Was there a particuac_ soil pr:blem ae Greenwood?
9! Q
?, !
@ 10 5 A What do you mean by problem? Explain what you mean.
z I j 11 Q was there anything unusual at Greenwoed?
m
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j- 12 j A It was a good site and there would have been no
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i l g 15 Did you state tha Dr . Peck er Dr. Hendron recommended i 8 i i .
g 16 ; tests taken?
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21 l recommended other lab tests, but the thrust was field tests.
a 22 ! Q Do you know was th4 alfeharging, was that a type 23 of field test or do you know what type they recommended?
24f A : have some knowledge of it. It consisted of pumping 25 i of water from a low elevatien := cause the effective weight of I
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5 ALDERSON REPORTING COMPANY. INC. !
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t 1: the soil to increase as a result of the pumping of the water I
- 2) by imposing a load ever the lower layer. That was considered '
I.
3 I to be the seat of the additional settlement and it would have I
b 4j made the site infeasible if that should settle in and actually ,
, g 5 measure, as a result of this type of test. My recollection, j 6 ;l resulted in a modification of the future settlement to the ;
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- 7) lower side.
F -,
a A 8l .
1 Q Do you know if the result of any field test was 0 '
9 submitted to the NRC?
, i
$ 10 l A No, I do not.
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Y 12 there, was that soil engineering?
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g 13 ' A Yes, sir.
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5 14 I Q Was there a particular soil problem at Palisades, t
I 2
2 15 4 in v.our o.oinion?
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z i I
i 17 in the u.itial oroblem. I don't -- the cortion I was involved
{ 18 l with was a site modification in the addition of the building.
. I 19 :.. Later on I also studied the possibility of moving the steam 5
20 f generator so the studies did not represent an unusual soil s
2I problem, no.
22 Q Quanicasee you indicated the work was discontinued?
23h 9 A At that time it was, to my knowledge, it was 4
24
- canceled.
25 Q Was that cancellation to your knowledge in any way
. ALDERSON REPORTING COMPANY. INC.
1 I
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l, I% connected with the problem :ney had with the scil?
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2i i A I do not know. ,
I 3; O Dr. Afifi, when did vou first began work on ths S
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g 5, 4 A When I 4cined Bechtel' in September 1973.
- n e n J
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I 8f C I want to exhaus: your knowledge of -- let's go off d I
- 9l the record, i l E 10 1 (Oiscussien held of f the reccrd)
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2 11 SY MR. PATCN:
n I 12 -
O You have indicated tha: the particular Organi:atien
_= k g within Bechtel, Inc. that you worked for is the Hydre and l
= 13 l _
4 14 Community Facilities Division?
- 9
. e d 5 A I meant to indicate that 3echtel, Inc. is the big 15] '
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company. Hydro and Community is some ecmpany in that big x i d 17 ' ccmpany. >
5
- 1 E Q I understand your statement.
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The Hydro and Community Division yo your knowledce -
n 20 h is an organization in Bechtel, Incorporated? ,
21;l A To my knowledge, yes.
22
- Q It is not a separate corporation, is it?
s 23l A To my knowledge it's not.
24 j Q It is not?
25 A To =y knowledge.
F -
ALDERSON REPORTING COMPANY. INC.
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I. 20 4
t 1 Q How many people in Hydro and Community Facilities I
2 l Division are assigned full-time to the Midland project?
3-1 MR. FARNELL: Anr 'a. hor Division or the whole l
4 ' organization?
- 5 ,
BY MR. PATON:
is f 3
- 63 Q In Ann Arbor. -
1
$ 7 A In Ann Arbor : cannot answer with scil. I don't i M
E 8 have knowledae of the exact number.
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= 9 0 You can't answer in soil?
i-F 10 l A There are other areas where I know there are e. ece. le, z t
=
3 11 but : don' t know how many, : don't know the whole amount.
38 1,
e 12 L< MR. FARNELL: Are you speakinc- about right now, z
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= 13 *3 at the present time?
- a m 14 j j A As of today, meaning lull-time, the great majority w
f= 15 h of the time, over ninety percent of the time?
3 i j 3Y MR. PATON:
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!! 17 8 Q Yes, fine.
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P. K. Chen, J. 3. Givens, J. O. W-a-n-:-e-k, l
}c 18 A
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R I 20 l work on the Midland project but it :. 3 not one hundred percent, 21 sometimes you are working sixty percent, but I work on other t-
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22 3 jobs, ii 23i o 0 Doctor, about yourself, approximately how :.uch of
?
24 { the total time do you spend on the Midland project?
25 ; A Recently, the past several months : have been spending 1
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1 , maybe ninety percent of my time. Chis is for the past several i
2 ,:. months, and before that it was less and it varies with time. i
?
3i: Q Mr. Chen, can you tell us what he does?
1 4 A He does primarily office work in the engineeting, a a
i s 5g report person.
e a a 1 3
e 6 :o Q Can you explain what that means?
R k A It means he's performing calculations, preparing reports A
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= 9 i provided input to the engineers as requested.
I )
E 10 l Q You mentioned the project engineer. I want to get i- a, 5
11 '! back to that later and ask you about that.
a i.
i z 12 !i Have vou told us what Mr. Chen does w:.th respect
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13 ] to the Midland facility?
i j 14 l A I gave you a general c'.escription, not the nitty-t
_ l i 15 ' gritty details.
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0 17 q A To my recollection he is a civil engineer with a a
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E 19 4 0 Mr. Givens, what does he do?
5
. 20 k A Generally the same work.
21f .
Q Is he Givens a civil engineer?
A Yes.
22f ,
23 ' O In soils?
24 - A He has a Masters with emphasis in the soils area.
25 , Q What does Mr. Wanzek do?
i 9
s ALDERSON REPORTING COMPANY, INC.
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1; A He reports 00 me. He is, he has a title of f
2s geotechnical cocrdinator. He coordinates the werk between i
3 the Geotechnical Services Group and in Ann Arbor and the ? reject 4 Engineer Groups. Mr. Wan=ek also has responsibility for any
- a. 5 supoort - that is required in construction activities.
N I Your last statement, he was responsible for providing j
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7 ! surport for construction?
- r. -
n j 8 A Connected with soils, yes, sir.
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I l
@ 10l A Any advice that is required, any question that comes
$ 3 3 11 l up in connection of hcw things should be done in the field
'f 12 !relatingtosoilsheisresponsibleforprovidingthoseanswers.
E !
E 13 l Q I don't recall if I asked you this, did you say he I L a
4 14 i- was a civil engineer?
i
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j'z 15j i A Mr. Wan:ek is not a graduate engineer to my knowledge.
j 16 Q Does he have a college degree?
a e i 17 i A I don't believe he does, no.
d E 18 ' Q Has his work involved, does it now involve soil
- ; j
$ 19 ) eng?neering except for the fact that he does he does not have M t
. 20j a degree he is n,ow working in the area Of soils?
21 A Yes, with the emphasis on field application.
22 t Whatever is done outside in the field.
e 23j Q Do you knew how many years experience he has?
l 24 !a A To mv knowledge over thirty years.
l l 25 , Q Mr. Mohan, tell us what he does with respect to the c -
Tr
- ! ' ALDERSON REPORTING COMPANY. INC.
L I
1lMidlandproject?
2i A He's involved primarily in analyzing field data that's i
3[ collected on the se::lement, and also he is involved in the
! He also assisted 4 ; F.S.A.R. that would be required, updating.
i e 5 l in responding to the 50-54 questions. He prepared a portion n l N A a
6ip of those responses -ha are apolicable.
e g 7 Q Do you remember if the soil problem was in connection N
3 8< with the administration settlement problem?
I d
- 9 A Yes.
Y E 10I; Q Do you recall that several borings were taken for i ,
j the purpose of determining whether or not that problem at the
' 11 l
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12 t;- administrative building was an isolated problem?
, e g 13l A I recall borings taken sleng alignment of the
= 3
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M
!' 15 l was on that upper :ene, that new second fill.
f t
f 16 y Q Did Bechtel conclude that it was an isolated problem z !
h-17 C; at that time?
= n 5
18 ! A It is my understanding, yes.
s
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21 l whether or not it was an isolated problem'?
e 22 i A : .c + participated in an evaluation of the data 1
23 } collected- at the administration problem which indicated that
- 24) the problem was not in the plan; fill but in the new fill tha 25 was recently replaced.
E l
- i ALDERSON REPORTING COMP ANY. INC. .
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! 9 ,-
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1; Q 3echtel decided that was in the plant fill?
, e i
' I 2! A Not in the original plant fill but it was a newly t
3 l placed fill in the excavation.
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4 Q Did that indicate to Bechtel tha: the administration e 5 g building was an iscla:ed problem?
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- i U
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9 conclusion that the settlement at the administration building i
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j A I said that was my understanding, yes.
- 11l d 12 l Q Did v.ou . crevide input with respect to the aren z
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5 14 y A It appeared to me, to me it appeared to be t
1 i 15 ' isolated based on the data available.
5 3
j 16 Ig Q Did Mr. Mohan have any input to the decision?
..# 5 y 17 I A He wasn't with Bechtel at that time.
b 1
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19;; know up te date, whether er no: the problem at the ad=inistratio
. 20 [ building was an isolated problem?
I J
21 i MR. FARNELL: With hindsight, with all data?
ti 23 i O Yes.
24 ; A Obviously the problem is not isolated. All the data 25 that's been ecliected so far, that problem is -- ,
e i ALCERSON REPORTING COMPANY. INC.
l 25 1
l Q When Sechtel decided originally tha: the proble= was 1lJ 2 f isolated they arrived at the wrong decision?
6 3 MR. FARNELL: You're talking about a: the time 4 based on the information they had then, or are you talking s
n 5j now?
M 3
4 6!
- 3Y MR. PATCN:
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8j you know now, do you have an opinion whether er no the J
d 9 decision reached by the Bechtel crganization that it was an z
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A I believe I answered that.
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A Yes, sir.
- i i 17 l Q And I think you said now that it wasn't an isolated
$ 18 i* problem?
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. A Yes, sir.
20l Q I'm asking you based on everything you know now was 1
21 ! the original decision that it was an isolated proble=, wasn't
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22 ', that incorrect?
23! !
A : believe it would be incorrect.
J 24 i Q Do you know what information you have now -- strike
.f 25 , that.
t-5 g ALDERSON REPORTING COMPANY. INC. ;
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[ 26 9
)6 Do you know now why that decision was incorrect, or 2, do you know how you made an error at the time -- strike that.
l 3 !
Why dtd you arrive at the wrong conclusion?
i 4 l MR. FARNELL: Object to the dor =. Hindsight now?
I MR. PATON: Absolutely,
. e e
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a 63 y 3Y MR. PATCN:
R 2 7 Q 3ased on hindsight, based on everything you know, I s
j 8 1 do you know why they made the wrong decision?
l c o
- 9l A : don't. '
E 10 Q Do you know who at Bechtel? '
i
- 1 7
e 11 l i A I provided input with respect to the area studies 3
12 f' and then Bechtel evaluated, to my understanding, all the facts f: $
1.
E 13 i, they had and at the conclusion this is my judgment of what >
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t-16 ;; Q 3echtel's decisions, do you have any opinion, an g
- A . _ .
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17j opinion based on everything you know, why Bechtel =ade the 5
E 18 8 wrong decision at the time when they decided it was an isciated
= I E
= 19 ! r roblem?
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20f MR. FARNELL: Wrong or incorrect? i 21;3 MR. PATCN: He agreed that it was a wrong decision, 4
4 22 { it was incorrect.
1 s
23 ; ,
A I have trouble with :.. language. The word wrong I
24 7 versus incorrect. I've referred to as an incorrect decision.
25 - 3Y MR. PATON:
.: e a ALDERSON REPORTING COMP ANY. INC. .
4
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I 1 Q I want to use your words, an incorrect decision ~. !
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De v.ou know have any. opinion as to whv. Sechtel P
3 l arrived at the incorrect decision?
k 4! e A I believe I probably -- I don't know for sure. I i
e 5! don'tknowfersure.
M t 2
j 6[ Q Do you have an opinion?
- a
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n 3
N 8 BY MR. PATON:
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Q If it's a pure guess.
z.
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s 2 1 2 11 ! O Do you know if anybody within 3echtel tried to go w !t d 12 ,? hack and analv:e why Bechtel arrived at the wrong decision z .
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MR. FARNELL: Read back that question. )
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E 18 % BY MR. PATON:
- n
$ 19 l Q You're stating it's incorrecu?
n ?
. 20 3, A Will v.ou repeat that.
4 21I t.
(Question read by the court 3
22 , reporter) '
lb 4
23 ! A 'm not sure that the administrative building itself 24 k was analyzed for a second time, I'm not sure if it was.
25 Q Fine. Good answer.
4
- r lt ALDERSON REPORTING COMPANY. INC. i
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f, 1 ; Q Mr. Mohan, is he a civil engineer?
I s
2e A Yes, sir.
R 3l a Q Does he have a specialty, or did he specialize in 4.5 soil engineering?
8 e
, s 5 A He has, I would consider he -- yes.
n N
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Q Of all these names that you have listed, they werk u t
- n. 7 /; f or .vou?
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8j A All do.
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- MR. FARNELL: That's not a correct characterization O d i c 10 3 of the testimonv. ~
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i 12 9 Q All these people werk fer veu?
4 E
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4 13j A Yes. Scme of them might not directly reper c me, 2 b M
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14 I3 but report to someone else.
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15 f Q You said Mr. Wan:ek reported to you?
16l, A Yes.
5 1 a >
E Q Is Mr. Abramson a civil engineer?
z 17 $:i F (
5 18j A To my recollection he is graduated from an
- p C 19 e universi
- v of Russia p.d it is my recollection that he works 5
n 20 in soil.
- 21) Q From some university in Russia he has his degree?
?
22 9 A Yes.
23 0 You indicated that the people you just listed 24 s are almost all of the time on the Midland project in the soil 25 area?
k d ALDERSON REPORTING COMPANY. INC.
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f 1[ A Yes, sir.
e s
2ss Q Are there people that 3echtel has in Ann Arbor in the 3 soil area, are there people who are par:-time on the Midland i
4 # project?
e W
, . e 5i A Yes.
- t H 5 e
e 6 F, Q Ac. croxima telv. how many?
u ;
1 i 7i A Two or three who put time in on the Midland. It is n
j 8" a various amount.
C 2
z
, 9l Q s there another organization within 3echtel, Inc.
o y 10 t that does work on the Midland project in engineering?'
z ;
= 1 2
11 'l A Will you repea: that.)
n $
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u c :s there another organization within 3echtel located E
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13 l in Ann Arbor that extends effort on the Midland by the name x
f 14 of Pro ect Engineering?'
_'t E 15 ; A 30, s
4 g 16 j Q Can you name any other organi:stions with sechtel
= .
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17 a: that is assigned to Midland or does work on the Midland project?
=
- 18 ,ad A Any other organizations?
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19 < Q Other than the Hydro and Co== unity Facilities Division.
4 5 '
20 A That spend time on Midland?
21 Q Yes.
22 A I'm not sure I understand the question.
4 23 3 Q You indicated that you are in an organization called 24 !! Hydro and Co=munity Facilities?
25 , A Group. Which is part of the Hydro and Oc=munity 3
't i ALDERSON REPORTING COMPANY, INC. '
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1 5 Division that is within 3echtel, Inc., a company called h
2h 3echtel, Inc.
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3 i 0 Okay. Your Gecrechnical Services Group which I
i 4 ' i understand is Hyrdo and Community Facilities Civisn?
l s
. e_ 5 A Yes, sir.
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Q De vou- equate the Geotechnical Services w :h Hydr 0
= 7
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9 ,
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N 8 A Yes.
d 9 Q Is it agreeable if I refer to it as a group, as the E_ 10 e Gectechnical Services Group?
z s
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s z 12 L Q You work for Gec:echnical Services Group which !
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13 l understand is the Hydro and Community Division?
4 ___
$ 14 A Yes.
+
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i O Another group under Hydre and Cammunity Facilities i
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16 j Division assigned to the Midland project --
d 17 -l 4 MR. FARNELL: That has been asked and answered.
5 $
$ 18l 3Y MR. PATON:
=_ f Yes?
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A : would nc knew that for sure. : fon't know tha I!
s 21 i for sure. I maybe need to explain sc=ething jeu do not 22 ;- understand. Within the technical, we call it scil, within b
23 E that may exist another g cup here on another segment from the e
24 0 paren: company.
4 25 , c ;'sted
. within the Geotechnical Services?
il ALDERSON REPORTING COMPANY. INC.
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Ii A Soils.
f.
2k e Q What section?
e 3h e A We call i: the Scils Group, the everyday name is 4 soil, Geclogy Group. And there is a Hydro Electric Group c 5 and there is a Water Trea =ent Group. That's the best of my
- e a ti
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3 o
. O g 7l" Q If there are any other organi:ations in Bechtel
- s D
g 8 f in Ann Arbor other than the groups you have just mentioned i
d 1 0 9i that are working on the Midland project you are not sure?
2, 1 0 10 lL A : wouldn't know. I am not sure if there is such a z
=
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. t z 12 ,1 Q want to knew vcur title.
Is your cresen: title 5 t 13{ assistant chief soil engineer?
- a
- t 5 I4 l A Yes, sir.
b j 15 g Q Who is the chief soil engineer? ,
g 16 i A W. R. Ferris.
^ k N I7 l
- Q Mr. Ferris has his principle office in San Francisco?
t_ .
E 18 l A Yes, sir.
3 3
' 8 19 .-
-Q Cn the Organizational chart, do you report to
'*x s
i O
20j Mr. Ferris?
21 A Technically on a day-to-day basis en technical
! 22 " material : talk with him. Mr. Ferris reports to Mr. Surg.
1 23 ' 3 0 Who?
24 ~ A His name is on the resume there. On day-to-day 25 ! activities deal primarily with Mr. Ferris.
i N l d - ALDERSON REPORTING COMPANY. INC. '
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- 1) Q Is Mr. Surg also in San Francisco?
I 2l A Yes.
I
! Q Within v. cur area of resc.onsibility in Ann-Arber mm 3 g 4(Icorrect that there is no one above you on the organi:ational e-I -
= 5 l chart?
H i G 6i MR. FARNELL:
Was his resposibility; what do you mean, e 5
- d,
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- s. 7 j in regard to what?
. I M
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" 8f i BY MR. PATON:
U l Midland.
2 z,
9l a Q
t 10 i A That's not totally correct. The Geotechnical Group -
E.
I-
_z 5
< 11 lI, in Ann Arbor consists of these four groups and each g_oup has 3 l 4 12 i, a leader or technical boss . In case of -- above all four of z
s 13 . these people, the manager, the manager goes to the technical
=_
l' 14 manager. In this case that is the person's fuction, that person's A. -
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15 ba function is in management.
3 3
! ? 16 ea Q What is the name of that person?
m w l H. 17 2 4 A In Ann Arbor it is S. L. Gle.
x 1 1 x 1 E 18 ! Who is in charge of the Geclogy Group?
- t C E t 19 3 A Mr. William Ferris.
= <
a L 20 i 3 Q Head of the Eydro Group?
?
21l A Constantine Papadakis.
4 22 5, O Who is head of the organization that you designated 1
s 23 ? as the Water Treatment Group?
a A The persen in charge has been changed. I ferge 24l .,
25 ' the name . Later I can provide it.
3 ALDERSON REPORTING COMPANY. INC.
e L 33 l
}
l Q Who was i: before there was a change?
S 2! A Don Wheeler. :: was a long time ago, bu den't 3I remember He name cf the current one.
,t 4 Q Do you report to Mr. q;e7 g
5, A In Ann Arbor do. ;
N j 6 Can you tell =s the types of things you report to 4 0 n .
=
" 7el Mr. Gle and the type of things you report to Mr. Ferris?
N i 8*l s There is a division there?
J-
- 9 A- Yes. The type of things to Mr. Ferris would be z.
0 z
10 ;. technical matters that are related to soil engineering, how
= 1 7 11 1a to do things in sola engineer ng anc now tnings should c e cene.
3 N I2 ( He has a review capacity of the work I do from the standpoint, 1
2 -
13 mv understanding in a review capacity and that is delec.ated.hv.
5_
s 4
x E
14 ]' Burgrto Gle . de is a mining engineer in this office who is
= i
!* II ! responsible for things, how they should be dcne and the E I0 li relationship between the ?cwer Corporation and the Hydro a >
H. 17 ! Division in Ann Arbor. He is coordinating among these four
=
0 18 ' 3 l groups if necessary and in the implementation of the company s a 19 <
f s procedures.
= ,
o 20l 0 Possibly also personnel manager?
21 4 l A Yes.
a 4
22 (r Q Now, I might be incorrect. I thought you just 23j references some bi-coordination between the Power Company and 24 the Hydro and Community Facility?
25 ' Yes, I did.
A 3
?
ALDERSON REPORTING COMPANY. INC.
F P
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la f
I, Q Can you indicate :: me the dif f erence between the e
2 'r Pcwer Ccrpcration; is that something under Sechtel, Inc.?
k 3l b A No, Bechtel Pcwer Company in Ann Arbor, it's a {
l 4 f Power Division and is to =y knowledge part of 3echtel Power t e 5- C=rporation, Ann Arbor Power Division.
- n M
l
. a 2 6; g What is the highest corporate division of Bechtel
. u g 6
7 l at the top?
u a g 84 A : cannot explain.
I d
9 Explain your answer a little slower.
C z.
y 10 l A In Anh. Arbor it =nsists of primarily of Ann Arbcr z
=
Il
@ Power Division.
3 l E
12 O Ann Arbor Power Division. Does th'at cover anybody 5
h 5 13 8* in Bechtel in Ann Arbor, the Ann Arbor Pcwer Division?
w i 5 I4 A In our Ann Arbor Power Division, it's a division of u'
e !
3 15 0 h i Bechtel that refers to a division of Bechtel.
1 t
E
^
I6 l Q You call that Power Corporation?
t C 17 4 M 4 A That's looselv termes, it's that, t
s e 18 5 Q Do you know whether or not it is a corporation by
=_ 1 i -
C- 19 0>. 2 .. s e ., ., ,:
M s 20( A I wouldn't be able to answer.
5 2I Ann Arbor Pcwer Division is fairly accurate?
Q 4
22 3 A of the organization.
23 ! O That is separate fr m Hydre and Community Facilities?
I 24j A Yes.
1 25 Q What does Ann Arber Power Division dc tha is different a
ALDERSON REPORTING COMPANY,INC. ,
s ,-
1 1 .,
r.
I I
e 1 from Hydro and Community?
I, P
2t i A Ann Arbor Power Division is an organization and it 3 s.l has all pro ects, ma'or oc.eratinv c.ro ects in Ann Arbor in 4 that company.
5 <
o a
S .f Q Do you mean bv. that completed project as conosed to e
- N
~
a 6 ' Midland f acility constructid in Midlamd is under Ann Arbor e
- n R. 7 Power?
n 5
n 8
>d A To my understanding of the organization.
-J I
- 9,IJ Q Doctor, ycu indicated the Hydro Facility Division z.
- I:
d 10 e is separate from Ann Arbor Power Division?
C z ,
I j 11 g A Hydro Division, the group that there is in Ann Arbor d
Z 12 l* it 4
is to rovide the service to Ann Arbor Power Division.
- 1 s 13 l Q But it is a separate organization?
=
- a Z A x 14 i A Yes.
= .
2 15 3 Q But Midland is under Ann Arbor Power?
E
~
J j 16lg A Yes.
=. <
h
. 17l 0 A lot of ceccle work for Hvdro, for the Hydro Division z .
= ;
E 18 f provide work for Midland?
=
[
I. 19 i.
A Service that Midland erodect.
- s f
20 . Now, :'m not talking abcut cavroll but this, the L,;
21 j organi:ation, the way I understand it.
n 22 5 Q Do you have an organizational chart of Bechtol's 23 ' that you'd be willing to provide that would clarify some of 24 these things we are_ discussing? You may wan Oc talk to your 4
25 lawyer.
ALDERSON REPORTING COMPANY, INC. !
t 1
.i s.
J l
1> A :-don't have ene myself. I think you should be i
d 2( talking to someone else.
e t
3i Q Would it be difficult te. get one for 1s?
A i
4g MR. FARNELL: Request it.
l e
5I -
MR. PATCN: Mr. Farnell, would you be willing to d
j 6 l3 attempt to provide us with some kind of Organi:ational chart n d:
l at 3echtel to clarify some of these =atters we are discussing?
E 7 n
t n
i 8 ! MR. FARNELL: : understand an organicational chart d
- 9i for Ann Arbor?
i i c a b 10 l MR. PATON: Correct.
i .,
= ?
2 11 ), MR. FARNELL: We will Over the lunch hour attempt 4
y 12 l to get a copy of that for you.
=
e E 13 i 3Y MR. PATON: ,
=
4 z
= 14 , Q coctor, de vou have other honors or awards ir.
._ g k !
j a
15 ;i engineering in your employment not listed on your personal
=
3-16 ! resume?
z h- 17 I9 A Will vou
- repeat that.
.A a .s e
5 18 0 (Question read by the ecurt w
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=
19 ' <
reocrter) 5 t
20 $ A There may-be some in-house courses that I have taken, t
21 h but I don't recall, sechtel in-house courses. I attended a P
l 22
- variety of matters, management matters that don' t recall.
it 1
23 , 3Y MR. PATON:
r i 24 4 0 In the last five years and in connection with soils, i
I l
l l 25 do you recall any of those in-house courses? <
1 l
l .
n 1
,I ALDERSON REPORTING COMPANY. INC.
l l
I
h5 i
1- A No, not in soil.
I 2 s. Q Can v.ou tell us what v.our resc.onsibilities are ric.h: .
3 now with respect to the Midland croject?
s 4 A My responsibility to the Midland project is to 5
e 5 l provide soil engineering input to the project engineering team.
E (
n '
3e 6! -
O Soil input to the projec: team?
R b A A To the project engineering.
n 7]
n 8I Q What do you mean by soil engineering inpu:?
J
=. 9, A' I mean matters such as settlement predictions, z
- I.
@ 10 i' boring capacity data, soil properties that would be required z ,
= i E
11 ! !
for, by the project engineers to =ake a decision for an analysis.
n '
f= I provide guidance to field personnel associated with the 12 i
13 j field placement.
= i
?
d 14 E Q Does that complete vour answer?
x -
4
$ 9 E 15 ) A of course, in the process of doing these things :
x a
= s 3 16 *3 evaluate results and prepared answers to the NRC questions r.
E 17 a and the like.
4 t i E 18l Q You provide this input to the project engineering i :
E
= 19 !, team?
n 20 A Yes.
21l Q Those are Bechtel people?
E i
A Yes, sir.
22}
a 23j Q Are they located in Ann Arbor or at the Midland a
24 l site?
25 ? A In the case of engineering they are located in Ann i
i J ALDERSON REPORTING COMPANY. INC. 1
!. , o sw J
t 1.: Arbor. In case of any activity connected with field work they i
2 < are located in the .v.idland site.
- 3e! $
Q LApproximately how many people are in this which you b
4 designated as the project engineering team?
s- 5 A- .A few fron my area of specialization which is in soil.
- . g n 4 a
3e 6 4 We deal with several groues of crejects and those --
9 - - don't g 8 R 7 N know how many, really how many. I would not be able to tell n
i a
8 .v.ou how many.
- 9 Q Do you know the name of any person that is in charge E. 10 g of the grouo? -
z !
2 11 ! A Yes.
s z 12 Q Who?
- 4 p 13 A D-h-a-r.
t 1
- 14
- Q Does he spend most of his time in Ann Arbor or at e.
= s 15 ' the site?
2.:
=
T 16j A To my knowledge he's located in Ann Arbor.
t a
i 17 Q Does your input involve slope stability and a j
= i 18 8 analysis? Licuefaction studies?
i w
E 19 i A Yes.
5 4
" !i 20$ Q Lateral earth pressure determination?
21 vl A Yes.
e
.i
- 22) Q :nput into soil studies, action studies? !
1 23 A As determined by the project engineer, what may be 24 f required, that is determined by the project engineer, wha:
25 perimeter is required.
2 i-
,i -
ALDERSON REPORTING COMPANY. INC.
t 39 !
I k
l 1s Q In your op nien does the word pcst-lead accurately ,
i b
2' let's go 1l describe the applica:icn of the surcharce that --
3 l off the reccrd, a
4 (~;iscussion held off the record) s 5 (Questien read back by the n
M :
4 2
a 69 court reecreer) y 3 L 2 7' A Pre-load is intended to describe accurately the fac:
N n
! 8 f we have surchar:ed the buildine. , the existine. buildinc. .
To
~
- .: y c 9y that exten is an accurate werd.
i '
e h
10 e 0 Would vou sav. that the word post-1 cad would be z
= j 2 11 4 inaccurate to describe the application of the surcharge a:
c l i
12 l the Diesel Generator Building?
J
=.
e 5
=
13 i A I'm not familiar with the use of this work in this 1
l 14 4 type of application.
h
= 3
.E 15 !: Q Do you agree that the word pre-load, the prefix pre c [
W 16 !3 would imply something was done befcre?
z E
- 17 4 MR. FARNELL: Pre what, in the dictionary sense er a:
=
E 18 in engineering?
e w
E
=
19 SY MR. PATCN:
M t.
20 k,, Q Do you understand mv. c.uestion?
n 21$ A I'm not -- I don't fully.
I 22f Q What does c.re, 0-r-e, mean to v.cu?
1 23 'j' MR. FARNELL: :n an engineering term er the crdinarv -
24 ,, language?
25 SY MR. PATCN:
2
- ALDERSON REPORTING COMPANY. INC.
e 1! Q- asked hi= what the prefix pre means to h c.
n 2g A Pre means something that occurs before something aise n
3 occurred.
4l i Q :n the word pre-load, would that load be, referring a
e n
5 ;! to the prefix, pre refer to that?
" 1
~
6; A The load?
e 4 m h u
s 7,ti -Q Does that indicate that the load was put on before n .I E
n 8 ' the structure was built?
d i 9l .
A Not necessarily do I feel that way. I feel it would ---
- z. a
.: I h
10 gt to me, it's before the structure c.oes into oc. eration, it would z
= h E 11 j imply that to me.
z 12 l MR. ZAMARIN: Mav we take a brief~ recess.
E
- s 13 l (Recess held)
= 4 4
14 4 BY MR. PATON:
8
= l 2
a 15 /s Q Doctor, with the exception of Midland, have you 16 anv. ext. eriences with surcharging the structure af ter it was 3
m .
. 4
.b. 17 j ccmpleted or approximately completed?
t
- t E 18 l A Would you repeat that?
=
E 19 ! Q With the exception of Midland have v.eu had anv.
3 ,
n t 20 l experience with surcharging the structure af ter it was completed 21 l or partially completed?
t 22 ) A No.
s 23 j 0 Approximately what percentage of the ecmpletion had J
24 r the Diesel Generator Building taken when the surcharge program i
25 was begun?
I
- . ALDERSON REPORTING COMPANY. INC.
p 1
4 9
- A Will you repeat that?
,+
n 2t7 (Question read by the cour:
i 3L + ecor:er) s 4'e A : will not be able to give you exact percentages.
9 J
, s 5lAbout half the building was finished when the problem was n
N e
6 f', discovered and by the tine the surcharge reached its maximum
- n g 7 i volume most of the concrete was in place. To my knowledge, 6,
n 3
- 8. most of the concrete.
f
~> a 9i Q Do you know of any instances other than Midland i !
h 10 l where surcharging a structure was accomplished af ter the z
s 1
5 11 , b uilding was completed or approximately completed?
< N 3 -
5 12 [ A Yes.
z 4
= ,
3 13 ( Q Would you tell us the part cular name where it is?
= :)
A 14 $* A don't know the name. I don't remember the name N. i 5
- 15 +. cf the croject.
I know of several buildings within ene of the e
a 3.
16 l Sechtel projects where surcharging was conducted af ter the H 17 L building was completed or partially. Mr. Ferris, you should 3
a
= ,3
$ 18 ; talk to him. He'll give you the details.
i I
I 19 2h Q I think that's very helpful.
a f 20; We have a disagreement as := what matters -- let's e
21 j; go off the record.
9 22 s (Discussion held off the record) 23 3Y MR. PATON:
24 0- To your knewledge Mr. Ferris knows of the particulars 25 of instances where 3echtel has performed surcharging structures ALDERSON REPORTING COMPANY. INC. .
L
e 1- .,
r e
i 1 [ either completed or partially completed?
1 2[ A I refer to that particular project. I don': know of I
3j any others.
~
e 1 4e Q Did your knowledge Of this ma::er come frc= Mr. Terris?
l e
r 5I >
A Yes.
H r 3
< 6' Q Dr you recall how many Of these instances he mentioned
. n a R
7 ! to vou; once or more than one?
- I M
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n
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Q Is it your recollection he mentioned at least once; z a
- i b
- 10 i,. is that correct?
z 6
= i j 11 8 A Yes.
3 f
E 12 ,
Q n this instance er instances Sechtel was involved?
s 13 i A I believe so.
=
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14 4' Q Do you knew of any other instances you can think c
=
2 15 ; of other than the Midland project? Dc you have any personal d
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16 ! experience with surcharging?
I z a l
n'
. 17 ' MR. FARNELL: Asked and answered.
z
= h E 3Y MR. PATCN:
18l J
j 19 , O I'll clarify.
n ,
20 i Can you answer the question?
21l A Will you-repeat it?
(
22 ; (Discussion held off the record) 23 1I .A I have ne personal experience with surcharging.
24 0 Do you have any input to the surcharging program?
l 25 A I recommended it be used in one case.
i
- ALDERSON REPORTING COMPANY. INC.
l
b 6
e 1 ,! Q Tell us about that, please?
Ie 2i s A It was a tunnel, it was quite icng = ' 'ere was P
6 mechanical ec.uit. ment. - .The eng:..neers :elt :.: w e t .3c require 3 .
A v
41 certain clerances and on that basis we recommended tha: the I
e 5, fill be surcharged prior to construction, but the schedule H a
~
j-6 f didn't allow it so we recem= ended coal be placed en 5
cp of n r E
7 ': the tunnel in a control matter Oc acce=modate taking ou: the n
a 8 I diff erential settlement prior to the installation of the i
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i
@ C Ycu mentioned some mechanical equipment was replaced?
z
=
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2
< 11 i A Yes.
1 j 12 Q Where?
=
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!e 14 movement of coal within this tunnel. It was a reclaimed
=
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t J
16 I Q Mechanical =ovement of coal?
$ 17 ;$ A The mechanical within the reclaimed tunnel. The w ,
= J E
=
18 ( thing I was giving was the limit of the settlement to surcharge 8
2 6
- 19 l>' because of the mechanical ecti==ent.
X I don't knew -- don't a n 20 $ know how it operated.
s 21!
Q Do you know the name of the project?
i S.
22 A Monroe,
-t i
23 )i Q Was that done to limit the settlement?
i 24 i A Actuallv, I do not believe this reccmmendation was t
25 4 implemented. I do not know what happened. I understand there l
i s
)
1 ALDERSON REPORTING COMPANY. INC. 1 l
l
L P
i was a re-evaulation of the telorances, bu: I fon't~know if .c. . : -
1 l?
2 i was actually done. ;
A I
3g Q New, am I ccrrect, you have new related instances in i
4 g which you' have had experience or input in:c surcharging e
. 5 L
c.rograms?
A
~
e 6 f-1 A Correct. i
. n h 7l e Q Except fer information given yeu, 10 you by M
j l l 8
8 Mr. Terris and the information you gust related to us as to your J
= 9 cwn experience, have you ever heard of c:her instances where .
t, z* ,
c '
b 10l' :
there was surcharging programs i=plemented?
_z 5
11 i MR. FARNELL: Asked and answered.
l i
z 12 {41 BY MR. PATON:
- I n
5 13lg 0 I don' if he ever heard of any c:her instances. ,
=
n
- r 14 A :n the literature, there are instances stated in
- I
- i
= i j
t 15 l the literature.
j 16 Q Can you give us a citation to anywhere in the A t h'
17 5 literature where surcharging is discussed?
a 3 4
$ 18l A In mos: textbooks, in mechanics surcharging is
=_
t x
19 discussed. I read a paper, a Stanley Johnson, a copy of 20lt engineering and Morrison's Civil Engineering. I don't recall l4 21 4 v l ' ears er months.
e
- 22 { Q Tell us approximately how many years age it was?
'd 23 A The publication, I believe, Mr. Kane indicated he 1
I don't recall it new. There are many, =any references 24l knows.
25 ! in Johnson's paper. There are twc papers and there ara lets l
ALDERSON REPORTING COMPANY. INC.
s I
i i
I f , . .-
e
! l 1 c! re!erences ;e! erring to many, many cases of surcharging.
. l
- i. i 2k i 0 Have you read these references?
3 !
i A : read Jchnson's papers.
4p Q :n your opinion was the Diesel Generator Building i 4
,, s,-
5; subjected to any surcharge?
e i n ;
l2 6 !, A will you repea: that?
m 4
. M ,
1 7k (Question read back by the !
. .i ,
n 4 n
5 8" cour reper er) i t
9s A Can .vou clarifv. it? ,
- z. l 0 2 y 10 ( Q Please tell us what the werd surcharge means to you? -
z
_ t. ,
= 11 &q z A It =eans placine usually fill at the cp of a 1
3 . ,
t 12 deposit. The cause is to con?olidate in that contex tha t we 5- g
=
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=- .
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5 14 8 0 I unders: cod you to say that you place fill on top u t u i
- f. 15 : of a deposit to cause 1: to consolidate?
a s
= a i j 16l A Yes. .
fj 17 jl Q If surcharging weighed less than the fill antic' pated, '
x
=
b i 4 18 ; would you still des:.gnate it as a surcharge?
- a
- 1 i
. s-I 19 8* A Yes.
% I ,
20I ,
Q At the Diesel Generator Building did the surcharge d
21 ' e! exceed the weicht of the final anticicated load?
9 22 A To the best of my knowledge and the informaticn :
3 .
1 23 i have available, the surch a.rge exceeds the stre is.:.that will pre-24 d vail in. =.he . ground .
25 Q 3elow ground, under the ground?
' t i
- ALDERSON REPORTING COMPANY. INC. ;
i l
i l
se !
i 1* A :: varied with fepth. I don't recall the exac: -
2, percentages.
I 31 4 0 :s the foundation level at 623 feet?
J 4f I A : believe so, yes.
I
. e 5 0- At that level do you know to what extent thesurcharge) e N
e e 6g is?
R l ,
R. 7
'l A have to c.o := the view-c.rao.h crovided bv Dr. Peck.
M j 8 I' It has that infermation.
-J i
- 9 .
i Q Do vou know who made the :== utations?
i
- z. t-0 f c 10 t A Mv. c. r o u e .
= i 2 11 Q Who was in your group that =ade the compuestions?
3 l
@ 12 i A P. K. Chen.
= a ,
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- Did Dr. Chen have any input into computations? !
=
13 l Q 7
- 14 , A He suggested it be made.
e ,:
i
!e 15 Y Q Dc you know if he verified er checked it?
=
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B 16 i A I don't helieve he did.
i z i ;
- d. 17 ; Q Can v.ou ac.e.r0ximate the extent te wh ch the weight !
z 5 1 E 18 l cf the surcharge exceeded the final anticipated lead?
=
E
=
19 L
A : wouldn't know percent.
5 -d ,
. 20h MR. FARNELL: I think that -- i 1
t 21 l* A Near the surface a net effect of surcharging should I
d 6 r 12j have been, exceeded fif ty_ percent of the load of the structure 1
23 1 of whatever. '
)
24i a G You mean by load of structure, the final anticipated 25 ' load? <
1 1
3 ALDERSON REPORTING COMPANY. INC. !
l
! A For the structure, the net load for the structure
)
I I at the bottom tapers Off to a small amoun: wn;:h is in the order 2
, 3g of twenty-five percent or so.
r I
4I Q ! think you said Dr. Chen performed the calculations?
i I
e A Yes.
- 5 .-*
H 3
e 6!f Q Do you know if they have ever been provided to the ,
. n (
R.
7'. Nuclear Reculato y Commission?
n I n 8! i A No, the summary has been provided.
d
- 9i Q Has the NRC asked for these calculations; do you i \
- 6 h 10 1) know? !
_2 E 11 A No, they have non have to my knowledge.
3 d 12 f Q Do you knew whether or no: these cal ulations were z
= .
' i
- 13 made before the surcharging was imposed? ,
=
]
a 14l 1 i
A The specifi':ations were made after the surcharging +
!x 15 i
l was imposed. .
- a 1
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- 16 j Q To your knowledge, any calculations before surchargin:-
5 \
d 5 6
. 17 ! started to establish. the desired level of the surcharge?
x i
= !
E 18 l' A : do not know if there was anv..
' l E
=
19 n Q :n v.our crofessional judgmen would it be good M e 20 ! 4 engineering practice to perform those calulat;ons before 21 initiating the surcharge program?
I<
22 P. MR. FARNELL: What is good engineering practice?
k 23 ,: A Explain that.
J 24 ! BY MR. PATON:
s.
1 25 , O In your professional Mudgment
. would i: be nc mallv.
9 r
p ,
1 1
A ALDERSON REPORTING COMPANY. INC. : 1
= . -
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1 l acceptable engineering practice :: de: ermine calcula:icas before 1
2 i 1
surcharging in order :: know the desired 'evel cf the sur:harge?
I 6
a 3r A Sv. whom?
P
.)
4' Q :n the profession, this would be ncrmally - acceptable l ,
e 5! in .vour e refession?
n !
, 3 4
6 )- A : need := calk :0 mv Counsel.
,a .r: ,
E. 7 (Discussien held Off the record)
M i
N 8 A Can you repeat the last cuestien?
J
= 9 (Question reae. back by the i
b 10 ,
court reporter) i t
= i E
11 'l A I don't know.
3 1 1
d 12 sY MR. PATON:
z i
=,
- l.
p 13 Q Do you knew what mean by ner= ally accepted
=
i w i M. 14 l engineering practices? He said he knows and I'= tr.ine. to find h: i 2 15 cut if he didn't understand 0: what.
a
=
3
? 16 i i A I don' t know the answer to your T.:estion.
- n :
d w
17 ) Q Would you say that c0=preesibility of clay in sil:
i
=
E 18 .cortions poorlv. compacted plant fill as it existed at the
- 1 E
x 19 '. Diesel Generator Building befor.e surchare. ng would be mere a 'j 20 l s:.=ilar to normally consclidated soil er pro-consolidated 21 0 soil?
l 1
22l g MR. FARNELL: It's not an either or. I object to 23 ! the form.
1 24j SY MR. PATCN:
25 ' Q- It's not an either or answer. : does not have to be.
l ALDERSON REPORTING COMPANY,INC.
I -49 !
r, t
f, k !
1* .
I'm talking about clay and sil: portions would be differen: .
1 1
2j from clay silt -- -
i, 3j MR. FARNELL: Do you know what he means?
r 4 A : am having difficulty figurine out.what he =aans.
I
. e.
e 5! BY MR. PATON: !
M
~
, 6, Q You stated come.ressibili:v. cf .cocriv. cemoacted .
_ u 2 7;! plant fill.
I i 8 ;i A Would be it's normally consolidated.
M i :J
' c 9*t O More similar to a normally censolidated or pro-z.
@ 10 c=nselidated soil?
z_
i e
11 i1 A (No response) 3 '
I i
z 12 , 0' Would you say the compressibility of clay and sil:
=
s_. 13 '
.=
portions of pocrly ec=pacted plan fill as it existed in the E
14 Diesel Generator Building before surcharging would be more t-
- t
_ 15 similar to normally censolidated soil or a pre _.:onsolidated s
3
? 16l scil?
s H
. 17l MR. FARNELL: I object :0 the form Of the cuestion.
, :a
,, =
5 18 A would say it would be both.
=
^
W C= 19 t,! 3Y MR. PATCN:
& r.
20 s 8
0 The c.uestion was, whecher cr net the compressibiliev.
J 21l cf the clay and silt pcrtions of the poorly 00=pacted plant ta 22 f fill or the pre-consolida': ion, or are you indicating it is 1
23 j si=ilar 0 both? More similar to normally consolidated er
}
- . 24
- more similar to pre-consclidated?
s 25 , A n mv..a4udgment more-similar 0 pre-consolidated soil.
! 4 E
Ik k ALDERSON REPORTING COMPANY. INC. &
, , . < - - ~ , - , - ,
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50 :
l r
. i 1) k Q Can you tell us on wha ycu base ycur answer?
I 2I A The basis, the part in the fill is pre-consclidated l
3l and is broken and compacted and individual pieces are pushing 4l o ge, and the process of the combination and-t+st would
- e. 5 l result more or less in pre-consolidated rather than nor= ally e i N {
3 64 consolidated conditions. -
- 4
. n I t R
7 i Q Do v.ou wan: me to clarifv.? De v.eu wish to hear the .
- l n
3 n
8 li questien again to =ake sure you understand the questien?
d ,
= 9 .
A Yes.
i
- l Would v.ou sav. that the ec=pressib:.lity of clav.
@ 10 l Q . ,
z_ ,
5 11 l. and sil cortions
- of poorly cc=pacted plan fill as it existed k
d 12 in the Diesel Generator Building before surcharrinc - - would be z
= s - ,
- t mere similar to ncrmally consclidated or pre-consolidated
- scil? ,
= 13 l 14f A I believe I answered the question. Assuming, in F* -r
=
9
-- 15 the back of my mind, assuming each condition cut not only t_
? 16 the soft portiens -- are -vou referring to the soft portions 5 !
A H
of the fill?
17 )5 P
E 18 g Q The entire fill.
=.
C A Yes, I believe overall performance would be closer.
E 19 l a i:
i 20 $ Q Pro-censolidated?
I r.
21 # A Cicser, ves.
3 i
22 g .
Q 3ased on your professional experience can you estimate a
23 ' how much time it would take for a normally consolidated, a clay -laye i
24 - twenty-five feet thick under a structure load that is imposing II 25 a net baring .cressure of four thousand pounds per cubic fee: to 4
t I
li ALDERSON REPORTING COMPANY. INC. 1
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I reach secondary consclidation?
I }i.
2 A Will you repea: that?
3 l Q 3ased on your professional e.<perience can you estimate
- 4. how much time it would take for a normally consolidated clay
. e. 5l lav.er, :wenty-five fee: thick under a structural load tha n
N
.=ar:.ng pressure at :our t.nousan
- .mposes :ne ne pounds per e
e t' s
c a E 7 cubic feet to reach secondary censelidation? ,
" n n
8" A That answer depends on many facecrs.
4 C
9 MR. FARNELL:' ! cbject to the form. It is ambipuous.
[ '
z t s 10 ,. It is a hypothetical question..
z
= 3 E
11 11 3Y MR. PATCN:
3 i 12 l1 C Can vou estimate that time, and I'll read it again.
z -
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$ 14 i would that be more or less than one vear? .
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cw 15 e MR. FARNELL:
=
f 16 Are you asking scmething else?
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d 17 5 MR. pATON: He indicated that there were lots of z !
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- n 18 unknown fac =rs in the question.
n C E 19 !. MR. FARNELL: They are still there.
5 i 20 $ 3Y MR. PATCN:
?
4 21 Q The fact, the fact, unknown facts are still there.
.K 22j Does that permit you to make an estimation of less than one n,
23 # vear?
i I
24 : MR. FARNELL: Don't answer that question.
4 l 25 , SY MR. pATON: i 1
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1$ Q My second question is, can ycu estimate whether or I
2?u not it would take more or less than one v. ear :: reach seccndary 1 . .
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I 4 i MR. FARNEL*: :: presupposes, he cannet answer the t
, s 5 first question. ,
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" i j 6j MR. PATON: ! don't think --
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i 7 l A : cannot answer the question. ! don't have enough 8lj '
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f e
= 10 Q That's an excellent answer.
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= s 2 11 1a Did v.ou run or did 3echtel run to v. cur knowled,e anv.
a f 12 ; censolidation tests on the plant fi'l =aterial at the Diesel 5 B 1979?
{ 13 f Generator area before the surcharge was placed in Jz; nary, i
z l ,
p 14 A Yes, sir.
+
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& 15 g Q 3ased en the results of the censolidation tes: ng e 9 a
16 1: before surcharging, did you make any predictions on the amount n '
- y. 17 of the settlement?
5-
& 18 . A No.
I
. n 19 ; MR. FARNELL: c Settlement of the 'uilding er ever 5
n L.
the life of the building, se lement of surcharge under the
_, 20 l c 21 !a surcharge?
P 22 i BY MR. PATON:
(
4 At the time of the testing, I assume you were not 23} i Q
24 i. clanning any surcharc.ing at the Oiesel Generater Building 25 over the lide of the building?
t, j a 1
" ALDERSON REPORTING COMPANY,INC. -
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- e. ..-
l 1[ A don't recall if cnyone made -- dcn' recall. >
2 Q Did you kncu whose responsibility it was gcing :c 3 be if it were going to be done?
4 A :: would in my group, with my people. Right at the '
4
- e. 5 =c=ent : don't recall if any actual computaticas were made ;
n N N 3
- 6! on that cr'not.
- 1 .
n i 2 7 Q Would it be normal engineering practices :: make ,
n i
n 8- the predictions based on the censolidation testing? ,
J 4
= 9. A Again, the answer depends on the purpose of the z 1 0
, h 10 computations.
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7 11 l, Q Would it be a normal engineering _ practice to =ake I l 4 12 ; predictions as to the settlemen: cf that building based on the z
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= '
E A Not necessarily.
x 14 '.:
D_
E 15 g Q Are you interested, were you interested in knowing E
y 16 i in January, 1979 what the predictien was 'of the settlement of the w
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. 17 Diesel Generator Buildinc over its life?
E il.
E 18 { A January, 1979?
=
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- 19 gl 2 Yes.
A a, 20 l A : believe in January, 1979 I had actually made a o !'
21 [ prediction around that time en the basis of the surcharge h
22 !; program, n
23 ,$ O But you didn't make such prediction before the a
i 24j - surcharge program?
a 25 si A : don't recall.
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e 1E Q You don't recall if you did or not?
2 A : don't recall if I did or not. I don't remember.
I 3 . Q Would it be a normal engineering practice to =ake a I
4 prediction of the settlement of the Diesel Generator Buildine i
e 5 pric: to surcharging? I thought you answered that by saying n
N 4 3
e 6I; no: necessarilv. .
You did? You stated vou
. didn': run tha 1
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l u= r 8 )', A I'm sorrv.. : thought you were referrine- to 1980. 1 n
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a 9! O Do you want to clarifv. .vour answer? I
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. 1 i y 10 ! A The predictions you're talking about a: the t me i: ,
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was =ade,-I believe I didn't hear it correctly, your question I
- f. 12 i before the prediction of the settlement of the Diesel Generator a L '
4 i 13 3uilding before surcharge?
= i x ' '
= 14 Q Yer De vou want to change vour ans-x l u
r R 15 j A No, I do not normally make predictions of surcharging, t
y 16 i MR. FARNELL: In January of 1979. ,
4
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17 g A : was thinking of January of 1980.
l E
18 I SY MR. PATON:
4
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19 () ,Q You stated that you did run laboratory consclidation 7 E !
20 ! tests on the plant fill material in the Diesel Generator area e i 21 ; before surcharging was placed in January, 1979?
E 22k A Yes.
4 J
23 *j C Why. did you run these tests?
e 24 i i A The cri~inal
- curpose, af ter the problem was Oc 25 investigate the quality-cf the fill to see condensation,so we 1
a ALDERSON REPORTING COMPANY. INC.
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l 1 ran a battery of tests including consclidation tests with i k 2 f emphasis, with testing sef: ness, with the intention of determiningj 3y. the problem, where we stood within the censolidation of the fill -
i 4t as to the condition of the fill, that was the purpose of the, i .
. 5 f essentially, the purpose of the investigation. We later f
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7 for .credictin 5 se::lement. -
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j 8 Q You ran censolidation tests and other tests based on d
y 9 that information that you got from the tests you mentioned; ;
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- ou did not, am correct, make a prediction of the settlement i
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m i 12 MR. FAFSELL: He doesn't remember.
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- do not recall making one. : though: that I stated
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- t ai 16 2 3Y MR. PATCN:
a d 17 Q You might have?
w z i G 18 l A I micht.
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n l 20 3 A Yes.
L 21 Q And prior to your surcharging had you ever at any-(
22 l time predicted the settlement of the Diesel Generator Building 1
23 }" over the lifetime of the plant?
,s 24 3 .U . FARNELL: With or withcut surcharging?
.,i 25 ,: 3Y MR. PATON:
o 3 ALDERSON REPORTING COMPANY. INC.
t 56 f
+
1f Q Prior to the beginning of the surcharge? Prior
)
2 to .*anuary, 1979 when, disregarding the surcharging in 1979, 3 when the surcharge program began, did you personally or Sechtel I '
4I ever predict the settlement of the Diesel Generate: Building?
i I '
a 5 A Yes.
~
9 3
- 64 .
MR. FARNE.:,: ~.'s in the FSAR.
57 ,
A $ 3Y MR. PATON:
7 l I
i n 8 2 De vou re= ember wha: the FSAR said?
- .: l s 9i A 3etween two and three inches.
z, E 10 Q 3etween the time vou made tha: Prediction of two
~
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= i 2 11 and three inches and the time -vou made the prediction based s <
- i 12 :t, on your surcharge crogram, did vou make any other predictions z -
E a E 13 l of the settlement?
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= 14 - MR. FA.T:E* : : Of the Diesel Generator Building?
+ #
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16
- A Se: ween the time of the crediction for the FSAR 1
x -
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17 1 and -- and -- ,
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=
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= 19 y ,O -
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20 i settlement on the surcharge? i
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A Yes.
1 223 Q At any other time did you make a prediction of the 4
Diesel Generator Building?
23 f 24 A : don't recall making any. : thought -- : don't t
25 re= ember one way.or another. If I did any, is that what you l n.
j :1 _ ALDERSON REPORTING COMPANY. INC.
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2 0 :;ot completely.
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6 3[ Any time between the original predicticn of the 4, settlement of approximately two or three inches and the time e 5 I v.ou ultimatelv. made a prediction based on v.our surchar e, did
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a 6 I; vou ever plan to predict the settlement of the Diesel Generator 7 "! Building?
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u p, 8 A Yes, I'd planned to predict.
J g
- 9i Q When? .
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- i y 10l A All alonv based on the surchar
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surcharc.e c.rogram? ;
5 >
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. 13 5, A Mv. orie.inal thought, cav.be, c. e : h a n. s , if there be n > i i 14 i no confusion that i: would be one way ec go, to predic: the i 3
-2 15 ? settlement on the basis of the lab':ests, the very initial a ,
x >
3 16lL s thought because the material ac.e. eared to be heterogeneous .
d enough and the surcharge program became an opportunity Oc I a
17 >1 E 18 ! crovide answers, be provided in lab tests. That was no: the 3
- 4 I= 19 ! ,
favored way to go.
n ~
20 $ Q There's one word you used, and I want ec make sure
. 9 h
I heard it properly. I think you said heterogeneous enough.
- 21) .
22 i Will you read that back.
23 ; (Answer read back by ne 24 ocur: reporter) 25 ' A Heterogeneous.
i 4
$ ALDERSON REPORTING COMPANY. INC. 1
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1' 37 MR. PATON:
6 2f C You stated ycu had an initial thought to make a :
3 =rediction of the settlemen based on the lab tes: results.
5
)
4 5
g Did v.cu consult with anybody else in that rec.ard, in regard I to the decision whe:her or no: to make a prediction based en
- a. 5
, 1, N 4 3 6 the lab test results?
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R 7 A A: the time : don't believe : did. 6
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n 8 0 Do you know whether -- let me show vou a docu=ent.
' ~
a 9 I'll identify this decu=en: as being Voluma Three of the z-e
!! 10l 50-54 responses. This is tab 12 and : am looking at the 6 ,
2 11 -#t focument which I will show vcu
- in a minute. It s four pages 12 l 1:nc and it has a ne:ation, filed by T. C. Cock December 12, f .
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s 13 $ 1978.
=-
[c 14 [
! direct your attention specifically := page thra.e
- 15 ! :: the paragraph that conta:.ns the sentence , the sentence N Y
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? 16 someone asked what additional settlement wculd be predicted a P x $
il H. 17 ?i based on pre-load beine. elevated six to eic.h:een with settlemen:
5
- l ,
$ 18 a: eighteen being very pessimistic.
c Have you seen that before?
$ 19 f 5
20l MR. FARNI L: This is Midland project, the reper:
21 of Champaign, Ill:.ncis, 0:.esel Genera:Or. The documen:
t 22 i mports to come from Mr. Cook's notes fo: this meeting held i
23 on November 7, 1973 in sangor, Illinois.
4 i
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24 A : don't recall for sure if I have seen it befors.
25 SY MR. PATON:
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s ALDERSON REPORTING COMP ANY. INC.
i, .s .o I.
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2 2 Have veu
. ever heard tha Dr. Peck predicted at any i
's a :.
- 2) u time it would be s:.x c eighteen inches =cre than listed en
- 3l (
November 7, 19787 -
t i
4l A : heard Dr. Peck make a statemen: as a result of
- 8 .,
a 5 a question being raised in the meeting. But don't believe .
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' 3 6 Dr. Peck meant it to be a prediction. -
- r
. n r R 7' O What was he talking about?
I ,
1 n e I i 8 A Mv- reccliection is that he did not want c make a n ;
U c 9 prediction he said and several people kept pushing, asking !
l i
10 and Dr. Peck finally =ade a figure based on average. l z : .
= i 2
e 11 ' 0 Dr. Peck said the tests will tell us? j a !
(= 12 l A : refer to the full scale surcharge program. ,
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- 13 g Q Do you reca'1 that you used these words, the tes:
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i 15 [( A : meant the tests. I meant c indicate reference .
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n 17 8 0 Your clear recollection of that statement, that veu ,
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E 18 are telling us about from Dr. Peck was na he indicated full
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i, 21 j MR. FAaNE*;: Not directly.
i 22 SY MR. PATON:
l l 23 Q Where did you hear it; it's : rom somecedy , I thought i t 24 a ,
you said you heard it?
25 A : was at the meeting.
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9 ALDERSON REPORTING COMPANY, INC. l
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L 4
I i- Q To v.our knowledc.e was Dr. Peck aware of ane. .ab I
2 test results when he =ade this statement? i 4
r f
3i L MR. .?ARNEL* : The statement was about six 00 eighteen t
' p 4 t inches possible settlement.
! I e k I j , 3 5i SY MR. PATON:
- e. E
. H -
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3 Q Was he aware of any lab tes: results of Mid'and? _
e ;
e t 1 i 7h A I don't remember. !
- T .
2 l g 8- ;
2 Did Dr. Peck ultimatelv make a crediction Of the
- i. .
t 9 settling of the Diesel Generator Building based On the
, t
= I 5 10 I performance of the surcharge Orceram?
i i I .
= .
2 11 A : don': know. i
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2
' J 12 Q Did anyone at 3echtel make a prediction settlemen:
> z .
=
- 6 13 ! , of the Diesel Generator Buildine. based on the cerformance of .
. = i 3 14 the surcharge program? !
x c 15 h, A Yes, I made, my group. I believe Dr. Chen and : ,
=
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h i 16 l approved the predictio?..
I i
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l x [
=
u a 18j A That is given in response to question twenty-seven.
- 4
. s
- 19 ! 2 Oc you recall independently of looking?
s 20l, A I recall the maximum 40-year life of the build:ng t.
21 $ being an inch and a half.
t t
22 ; MR. ?ATON: Let's recess at this time for lunch.
23 1 (Recess had) 4 s
24 t u 4
75 a
's i ALDERSON REPORTING COMPANY. INC. .
1
- 61 t
I 1: (Af ternoc= session)
- 2) i
'3Y MR. PATCN:
i 3 l 0 Doctor r did any person who is empicyed bv. 3echtel i
I 4j involved in the Midland project ever =ake an oral or written
, s 5 statement to the effect that surcharging should have been held R i ll; 6- fcr a longer period of time?
. y k ,
g, 7 A : have not heard a stata=en: like that =ade.
N j 8 0 In your opinion was the surcharge held for a long 4 ::
= 9 enouch time?
2 3
@ 10 MR. FARNEC: For what purpose?
_E }
7 11 MR. PATON: I really* think that is so funda= ental.
is
. I 3 12 3Y MR. PATON:
j= 13 l. Q Do you know why this surcharge was placed? !
. , 1 14 A Yes.
'l N l x q
& 15 0 : thought you did.
=
it 16 l i
- n your opinion was the surcharge held a long
- r. l .
!;f 17 ;
encuc.h period of time for that eurt.ose? .
3 E 18 . A Yes.
_ i
. e-g 19 , Q direct your attention to a document -hau I'm going 5 ;
1
. 20 $., to hand vou
. and it's seven .cac.es and it's dated Julv. 2, 1979 21 :1 ,
and it is sie.ned bv. Mr. Davison, C. F. . Gould, H. A. Hendron, Jr.,
22
- J. 3. Givens and R. 3. Peck. : is found under tab seven of 23 ?i volume three cf vour- response : the NRC request for information 4
l 24 regarding plant fill.
25 ' : direct your attention specifically :: the paragraph ,
h
.i ALDERSON REPORTING COMPANY. INC. .
1 =a f
l 1i at the bc::cm of the page three with the sentence, the 10nger 1
I 2; the full char:e. remains, read that full half c. arac.rac.h 3:artin.
3 at the bc:00= cf page three.
4 l :n the paragraph I asked you :: read they ref erred g 5 to, we realize, however, hat the practical considerations de
. n f a 4 j 6l no: permit definite delay in surcharge remeval. Had ycu ::
- n a i R
- 7, i anyone at Sech e1 advised your consultan: as to how long your a i 3 8, schedule probably permitted .vour surchar:e er:cra=?
3 ,
1 0 9! A There were 3echtel personnel who were indicating z, I
@ 10 ' that the schedule was tight. At various times indicated they z
E 11 I i wished consideration of re=cval of the surcharging as its 3 1 i 12 ( ourecse was acccmelished.
z .
E 13 ! i O Do you know what it meant in this letter by reference i
x -
=
14 i :o practical considerations?
j 15 ): MR. FARNEL;: objection. He did act effer, you I
g 16 j asked him what his understanding is, wha: that meant.
^
! S Y MF,.
d 17 PATON:
'4 2
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19!* A :: refers to :ne schedule.
a v 20 (,. 0 Do you knew wnere the amount of time the schedule u
21 i ,
was given?
t 22 f A : do not know hcw much time specifically the schedule 1
23 * .,
alicwed for. No, I did not.
24 ' O Oid you know then er now? Did you knew a: the time 25 before the surcharge program was imposed, did ycu know how 4
a ALDERSON REPORTING COMPANY. INC.
P f
y much time was alicwed for the surchar e crocram?
1l i 2$ A : don't recall. ;
I 3 Q Do you knew how much time was allowed for surcharging?
I t
4 A No now. The schedule has been changed. There is a
- a. 5 the place under a different schedule than a: the time their g
j 6 discussions were taking place.
R" 7l : The schedule allowed five months for any surcharge n . +
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9 A : don't specifically -- I am nc sure of this fact.
z, .
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- 11 l '
w i 4 A From the day it fully went on it was , I believe,
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- 13 s April 5:h , that is the date that a lead was en in place and
=_
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14 13 removal becan Aucus: 13-h.
I believe these are the dates,
- ,4 i 15 ': but the starting of the placement was before that, before that a h 1
! 3
? 16 Aprtl 6th.
2 4 -
- b. 17 *3 Q Would you agree that the full charge was only held 1 $ ,
=
G 18 )* for four months and one week?
=
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=
19 i A Probab1v, ves.
= -
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20& 1 Q If you had not been influenced by the schedule, s
21 ! dc you have any opinien as to how long you would have held the 6
22 5 surcharge program?
i 23 . a MR. FARNELL: I don't think he testified he was 24 necessarily influenced by the schedule.
25 , A In practical censideration of the ability to complete i
, ALDERSON REPORTING COMPANY. INC. !
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A I mean tha: the ,ob -
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A .::actical cur:ese, . .
- n e E 7- it would have been nice for other rea. mens :: keep the surcharge r
. . . . c.e , e.
. . some eason . . . o -.3.e.
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- 9 h, regula cry agencv. .
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= 14 g Of time?
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A At the time the surcharge was remcVed I was confidend '-
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16 5, : was confidenu I was able to satisfy the rec.ula:Orv. a c. e n c v. .
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- 17 ,. O Have you been able to satisfy the rec.ula:O r v. a c. e n e v.
A g l' E 18 ) .s: the surcharge was held for a long enough period of time?
- 19 n
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20 ' have liked to see it icnc.er than wha: : =. c : cut of the discussions 21 ' we had recently.
22 C Would vou state v. cur understandine. whv. thev. th:.nk 23 the program should have been held for a lenger period of time?
24 A My understanding is tha: there is, someone was
! 25 responsible, they dcubted that the primary consclidation had been e
1 ALDERSON REPORTING COMPANY. iNC.
- 65 1 e.
i 6
1 , comple ed in their own mind.
2; O :s it ycur understanding one person had tha opinion?
i
)
3l A I'm not sure. I am not sure how many people really I e 4 l have that understanding, but I'm sure from the recen: discussion ,
t 5 lt Mr . Knne does. !
e n r j 6l Q :: is your op:.nion you have reached the secondary 7 ;', consolidation? :
R I
M h I
a 8[ A Yes.
e n 9 Q s it your statement tha: Mr. Kane, : your ,
s z.
- 4, 10 { understanding that Mr. Kane believes you were still in the z >
= l 2
< 11 i primary consolidation?
i 3 1 d 12 L A Repea: that.
5 6
- 13 0 Is i: your understanding tha: Mr. Kane believes you ,
=.
14 are still in primary consolidation?
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= s E 15 , A' No.
2 i.
=
j 3 16 l Q !s i: your understanding that Mr. Kane thinks veu're h*
17 ,j in secondary consolidation? .
- i.
$ 18 i A No.
- h E1 19 ) Q You don't think that Mr. Kane thinks -vou're in 5
20 E .eri=arv. , and .vou don't tnink he thinks v.ou're in secondary?
'l 21 3 A He has reasonable doubt that we are in secondary 9
4 22 consolidation. Mr. Kane may not be sure.
1 i
23 i
Q Do you understand why Mr. Kane has some doubt about
'l 24 _
whether or not you are in secondary censelidation?
25 A The ref erence to the pre:cmeter behavier a: the time.
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2 that makes Mr. Kane question whether 0; not you are in secondary 3 I, . . ..sc.' .'d.a ..do .'.
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4 i, A 70 the best of my recollection Mr. Kane stated, a
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.. . . e e. ,.. .- . ..
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. . . h e s u.. .-.' .a.- : ." .v;-
e n 4 j 6 ( was removed and the c. eriod thereaf ter some pre: meter reading 5, 7 " had- dropped down and s:syed below elevatien for a while climb I'
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?. 8 l back := a level near where it was before. Mr. Kane see=s :
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9 4 think the drop was excessive pressure and when tha: range is z.
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e.yee . ..
...e..... .y
.. . e., on .u.a .. . ... ,,.a.e.- ,s . .u.e z-
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11 Was there a drop in the pre:cmeter level when the 4 Q 8 }
z s
4 s...
. . ... a .y .a .;
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= 13 .i A Yes, they showed a drop.
g i I4 Q Oidn't it indicate there was excessive poor pressure?
f, 1
= s R. 15 i d ll A No. All along thought of the redue::.cn Of the
=
y . 16 !.t .ere:cmeter levels and the slew ::: cess of climbing back up as .
- E II # being the normal thing one wculd expect as a result of removing
$~ a
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- 18 4
.., surchar,ine. considerinc. the soil, instead of negative process,
. s "a 19 ' it gives arise to a slight recuction in the level.
n l
. 20l .i g 3e _-
r 21 ! ; . should peint ou: -hat there was a series of beepings t
2 1 in the pre:0 meter at the time such remcval was had, and I
( 23 ' considered question about the measurements at the standpoint l
l 24 that there were readine.s taken as the rods were beine. removed.
25 The cre: meter had extension rods as vou remove the surcharc.inc. .
a ALDERSON REPORTING COMP ANY. INC.
1
. * (7 i 4
1 ' ycu rencve and seasure these lines.
t e
4 F
2i Q As you go dcwn for the readings there is potential 3 s that the readings that ars taken during the process cf rencval r.
4 l would be influenced bv. the cresence of the surcharge itself, but i
. e 5 the general steps in the pre:ometer was cu: lined in Mr. Kane's .
n n N 4
~
e 6? note and it is perfec:1v- acceptable to pre:cmeter behavier tc c . ,
- -. g M 7 you :.s consisten: vi h the f ac: -that you are.cf the epinien you n ti 3 88t are in secondarv* consolifation?
- .' R 2
z, 9l a A That's correct.
e 7 c
- 10 ( ,
Q Dr. Afifi, was a steadv -
seepage off the pond reached p 11 ,
i at the time the surcharge was removed?
CI z 12 ;l4 A Clarifv what vcu mean bv. steadv seecace.
- n E 13 Q By steady seepage mean the steady, the steady level .
1
$. 14 l of the upper ground water surf ace con:rclied by the gradeant
- a
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E 15 'i from the pond?
w
=
3
? 16 i MR. FAR!; ELL: Read that again.
i e g d 17 ' (Questien read back by the w :
= !
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. p I, 19 '!, A What is the c.uestion? I'm still ecnfused hv. the M !
(, 20 l word steady.
t ,
21 b t What was the level of the eccling pond at the time?
a f .
22 E MR. FARNELL: The surcharge was removed?
, 3 l 23 4 A Approximatelv
- six, between thau and seven.
24 5 ,
3Y MR. PATON:
'25 ' Q What is the level, what is the upper ground water I
! ALDERSON REPORTING COMPANY. INC. t
j 65
] !
1 ,',: surface leve* between the eccline. .cend and the area around .he Iu 2 ; Diesel Generat0: Building at the :.me of the surcharge re=cval?
i i 3 i A In that distance between these twc?
l 4 l Doesn': the ground water, the un.ter c.round water i
Q .
l
, s 5 lI surface level follow a gradeant a: the decline from the edge ,
a '
6 l of the cocling pond and gradually decrease until vou ge: :: the e - -
u y '
, A.
7l, area of the Diesel Generator Building?
M :
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A : believe there is homocenecus fill.
d g
- 9 Q !s that no true?
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z 10 l* A : wculd not necessarilv. --
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a u
'i z 12 / material?
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13 J i A We're talkine- the distance between the pend and the i il
.= 4
$. 14 2 buildine., not belcw the buildinv , we're talking about, that's '
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x 15 C what vou're talkine about?
= ;
si 16 L e Q Soth from between the 00 cling pond and the cuter I
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~ 17 s* edge of the Diesel Building wouldn' t there be a steady decline j =
f
, 6 m 18 ,1 in the cround
- water?
6 C #
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- 19 A There could be, no: steady, some kind of decline. i X h n L
, - 20$ Q so your answer is because the material is heter -
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21 t* -ceneous then the decline may not be steady?
22 8 At the time of the surcharge removal had the level 23 ' of the uc.e. er T round water surface between the cooling pond and
- 24 - the Diesel Genera:: Building area stabili:ed?
25 A The question, you're talking about an area between l
t ALDERSON REPORTING COMPANY, INC.
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1 4
69 '
t
.- r
. 6 1 ' the twe? : don't believe we had measured in between the two :: l 2 , say what that level is self-stabilized. ,
1 3 l Q In your analy:ing whether you had reached secondary i
j 4 consolidation, are you interested in knowing wha: the level of
, i i
e.
5 l the upper ground wnte:: iurface was under the D.esel Generator !
D l 3
6
- Building at the time you removed the surcharge?
a g R 7i ,
A Yes. 1,
.. i 4 n ,
What was that?
n et 8l 1 Q ,
5 9 !. A . Approximate-11y, siv twenty-five , i.: varies with an j z.
- i t.- 10 . amount.. :
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Q Can you tell me how veu - knew :.: was a: 625 feet?
7.:
i8 ; ,
i 12 j A From :ne cre:c=e*=- -a= dines that were taken below
=
$ 13 the Diesel Genera:Or Building. ,
i 5 1 E. 14 l 0 You indicated you could tell the level of the upper f d E E ~ 15 ground water surface under the Diesel Genera::: Suilding from i e !
= . !
- j 16 l your pre
- ome er readings?
z i ,
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e 17.4 A Yes.
x e ,
x 4 E 18 i 0 Were the readings also influenced by the surcharge?-
., =
19 A In mv coinion, as the lead was added there was a C. - -
a v 20 [ small rise in the pre:ometer and i rapidly dissipated. In ,
1 4 21 k placing the surcharge, it reached a steady level and tha did I,
22 3* not change, and that essentially . stav. ed at a stable level which 4l '
23 ( indicated ec me we had reachef, a stable level and that is, the
. 3 I 24 4 water, that' the poor water pressure essentially dissipated.
a !
25 ' Q When the pre:cmeter reached a steady state ycu had
, 1 ALDERSON REPORTING COMPANY. INC. :
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.: i 1 ; reached secondary censolidatien?
s 1
2,/ .A No: withcut the cbservations Of -- the settlemen:
6 3 ;! behavic: Of the buildinc indicated the tv.:ical 5-shaped behav:.cr, .
e 4 l that's typical of prima:f 1
performance whereby the settlemen:
)
4-5 l was essentially, actually lineal en a similar pict and was nN 8
E 3 6: essentia'ly fla on the linear plot. 70 me that sa;s we are e -
t
. n >
f in the presence, in secondary consclidatien ecupied with the A 7
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i 8 , behavier of the pre:cmeter. The Other level, : hat's ne differen:
" t
'- 3 9 l from the level they were at at the very beginning ::.ght after 2
3 10 i the dissipation and that tells =e that the secondary consclidation z e
!< 11 l was reached. ,
i n
} d 0 How long a pericd cf time af ter ;cu had reached your 7 12 { , .
=
- 13 . full surcharge lead, in .vcur ce. inion, had you reached secondary
=
4 14 ' consclida t:.cn? i
=
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. 15
?
A : don't recall the ti=e, from the time the surcharc.e w
=
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16 > reached its fullest but acprcximatelv - - ninety days frc= the time
?
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w 17
- the surcharce -- about a hundred dav. s er se from the time i
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E 18 # started geing en approximately that date.
s I 19 ?* 0 Y0u =ean you're estimat.ng you had reached secondary 5
- r. . <
i 20 ) consolidation?
a l ,
l 3 21 ! A Or less.
e h
-22 3 Q New, I think we can agree that the full surcharge I
, h j 23 , was en for fcur months and one week be-ween April 16th and f
24 , Au ust Sch.
I l 25 A That does not include the time it :cck the surcharge i
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i That's included in the hundred days 'm talking about.
f.Ocgoon.
2 2 r, O Tha: 's? !
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5 3l A To the bes t . cf my r eca ' ' a'- ' a I
44r 0 Your statement is that starting with January 26th, t.
e e
5 !.* ac. c. roximatelv. when the surcharae first started?
" d j
6f 1 A ;;c . Excuse me, : believe tha 's the date, yes.
+ n 5 7! 7 Q The surcharge started January 26th and got full height 5 E 8 approxima:elv
- April 6, 1979?
N a
9 A Ckay.
2 n 10 Q You're stating a hundred days, January 26:h?
z I
= !
I 11 A That is o.robablv right. I can't recall, or less, and
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'i 12 4. in some cue; it's less than that.
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.=. ?
E 13 5- Q Jus a minute, sir. -
1 2
14 -
g Sc I'm addine. a nundred days'to January 26th and C
- g R 15 ,! I'm ccming out Oc approximately May :st.
t
- t j A If you added correctly. I don' t know.
16 l 9
!$ 17 i Q February, March, and April is ninety days, three w .1
=
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- n 18 a I'm adding a hundred days onto January 26tn, and I come
=u dmonths.
C, 19 . out apprcximatelv. Mav. ist. Your statement is v.ou think v.cu M s 20 I reached secondary consolidation about May 1st?
s 21f A 3efore.
22f C And you did not start taking surcharge off untill 23 " August 15th?
24 1 A Yes.
25 0 .In your professional. judge =ent wculd it have been =cre
.s q
, ALDERSON REPORTING COMPANY. INC. .
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2 ,i you think you had reached secondary COnselidation?
1, 3i A No.
t t
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. s 5 ? was reached, i reached secondary consel:.dation May 1st, : hat's r l n G 3
6 when in your professional udg=en: you could have begun : take R 7
- the load off ?
t.
5 n 6 t,1 A The estimation of when the surcharge was 00mplete, 0 $
=. 9 i the primarv consclidation takes into account that strai;;.: line z
a . _
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- - 10 5 portion. I'm talking abcut --
and tha: came clearly straigh:
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- 4 A
11 :h line about the time we rock the surcharge eff. So : wculd say 3 a
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5 13 4 MR. FAPliE*.*.- Maybe didn't understand. hiill ycu
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14 .
repea: that questien.
= ,
2 15 .. (Question read back by the
=
3 16! i court reecreer) -
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= 1 G 18 Mav. ist, it could be Mav. 2nd.
- 4 E
E 19 i
3Y MR. PATON:
R
. 20 0 Searing in mind your opinien is you thcught you 21 ', reacned secondary consolidation May 1st in your pr:fessional 22 ,. dud: ment, could . vou have startine. r emcv:.nc. surchar.ing?
23 ' MR. FARNE'.: Read that.
24 A : would not have taken it any earlier.
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i 3 Q In v.our crofessicnal
. . ud:=ent the surcharc.ine. should 4 not have been removed any earlier than 1: was?
r e 5 s
A Essentia'iv. , for practical purposes, correct. .'
=
R 6, I g , Q 3ceter, I wan: :c read the first sentence of this t
i 7 "I paragraph that
- refer you 20, a letter addressed :: you dated
!! i
,( 8j.Iuly2, 1979. W:.;l you read the sentence, and I want :c ask *
- 9 if .you agree, the lenc.er the surchar
- e can remain on an area
- z. i 0 8
$ 10 t the =cre dictible prediction of the clay seeded pertiens of the z
=
2 11 settlement; do v.eu ac.ree with that?
3 f
I2 A Yes.
2 E
13 i Q Dr. Afift, were "2cu influenced in any. way bv. the .
= i l
d 14 schedule in the timing of the remeval of the surcharge?
w 1
=. i z; 15 , A I believe the timin: remcval was cetimu=, it satisfied,
. 4,, - -
= ,
3 16 l the a= cunt _of :be dav. s we needed to ecce. lete it, it provided i 2 .
p 17 the amount of fate of t.he surcharc.e to make a reliable crediction.' .
s
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- g 19 7 0 You said, you used Optimum, the re=cval was Optimum.
. 20 k Explain what you mean by that.
r 9
21 j A I meant that it provided, it did the ob that it a
h 22 4 was sur.c osed ec do. In my opinion it provided data needed :: l 4
23 , predict the se::lement, and at the same ::.me does not cause 24 i delays in the schedule.
25 ' Q Your professional ;udement, if the schedule had 4
l- ALDERSON REPORTING COMPANY. INC.
- y
o ,,
9 l
t l 1 ( indicated you had less time fer the surcharge program cculd i
2 l you have increased the a= cunt of surcharge and still received 3 ' a satisfacecrv. resul:?
41 MR. FARNELL: Read tha: back. ,
e 5 (Quest:.cn read back by the :
g j 6r court repor ter.'
N A 7 MR. FARNELL: Ob ection. I don't know wha: you mean N -
! 8 , by satisfactory result.
- 3
- 9 I A I believe : can answer ycur question. Surcharge, !
- z. !,
- t 5 10 i the determination to take the surcharge off is based en the i
i 3 11 measuremenes made from the full scale measurements tha were 8 4 d 12 5 made en the structure sc there wculd be nc way Midland, the E
.F
= 13 guarantee, ec take the surcharge off by a certain date. Even
=
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A 14 4 if it is increased, the amcun: it takes to guarantee, it's
. c I, 15 i:;.. based on the behavier seen there.
'\
7 : =ean, there was no reliable g
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? 16 ' behavic that it would receive scre 1cae er less lead.
s -
N. 17 l .
Q I am not asking you that. I'= asking you f in your t
$ 18 ) c cfessional exc.ert 'udgment that directiv. ac.c. lies, not to
= I.
e 0= 19 $ Midland, Just a ganeral quest:.cn.
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. 20 ( Can you agree that longer the surcharge remains on 4
3 21 's an area of be surcharged the more effect:.ve it beccmes?
22 ' MR. FARNELL: Any surcharge?
23 1.i MR . P AON : It's a very general pestion and :.t is 4
24 , in his general expertise.
s ,
- 25 ' A
- would have : say keeping the surcharge en longer i E
a ALDERSON REPORTING COMP ANY. INC. ;
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4 1
1 ' would nake it more beneficial to a certain pcin:.
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1 24 3Y MR. PATCN: '
n
(
Woulc. you name 3 ,,- Q ne inc.epencent censu,: ants tha L.
k '
4 Sechtel has centracted with with respect :0 this plant fill 4 1 t ,
- e 5 i settlemen: property?
A f.
3 6!: A R. 3. Peck and H. A. Hendron, Jr., M. T. Davisen
- ~
1 .
r M p Laughney and in addition to these people there 2
7 ;< and C. H. Gould. ,
n s j 8 5 were other independents, independent individuals and they in:1uded J $
= 9lK. T. Woods, F. E. Richardsen and : believe alsc 3. K. Glee.
i 1"
5 10 j There is also a Oonacliff.
Chese are, I believe these are -
i
= 1 7 11 individual consultants.
s d 12 Q Yoa indicated that these people worked on individual z ; 1
- 13 2 pr:blems. Can : conclude that the firs: four you mentioned
=
1 4
. 14 , wc ked on soecific cr blems?
O E
= p j 15 i A The firs five generally were on fixes.
~ ,
' W E
16 1 Q Which gentlemen were working On the watering?
i
- I M. 17 ' .
A To mv. knowledc.e Lauchnev., and : don't knew the t
4
$ 18 [ status of his engagement.
=
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=
19 ) -
Who is nc 1:ncer involved, but he has been involved n ~
. 20 in original plant for fixes for the auxiliary building.
k 21 / . Q Do v.ou know whv. he is nc icnc.er there?
r j 22 , A He was a me:ber, a professor of the faculty of the -
23 University of Michigan. C0rrection, he was a member of the 24 faculty, and he later joined the Mercatime C0rporation and he
[ ,
l 25 is a prospective bidder for the werk; and because of that, !
)
I E
i ALDERSON REPORTING COMPANY. INC. !
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I 4 (a I s
1 believe he is resigned. There is ane:her ercup cf =cnsultants
- 1
- 1 2 ) that will replace him.
3 a
r I
3r 0 Do you know the name Of the group?
3 4 i, A : know the firm name. :: is -- have a hard time e
t
. a 5s* re.nembering right now.
e r= '
N i Q If this deposition were to continue until ::=mer:0w
- ?
- 6
_ 2, i-
"2 7 ; perhaps you would be willing :0 supply that information F
e o M
i
" ah:0 morrow. You can talk : your at:crney if you can': reme=ber 5
- 9 ) it right now.
i-
~
a
@ 10l Now, you were telling us abou: Mr. Gculd's parti:ipatic.-
z ..
=
7 11 ; ) Will you proceed with that? They were werking on the fixings?
< e n a e
i 12 ' A Dr. Peck is the senior censultant. He and
=
=
==
5 13 Dr. Hendron were on board, they joined fr== the very beginning
=
1, s
$ 14 ;t and they have been. .nvolved in the Diesel Generator Building
= t i 15 ' fix as well as reccmmendations for c her areas of the site. >
6 i
T 16 Dr. Davis is involved is piling and also the a
A I engineering asFect of the auxiliarv. buildin v s.
H 17 W .
= 2 E 18 f Q With respect to Dr. Peck and Dr. Hendron, both
- _ I.
I. 19 ' are doc: Ors?
5 l . 20 ) A Yes.
I Q Which was contracted first; do you knew?
21[
- 22 MR. FARNE* I. : Contacted?
23 3Y MR. PATON:
24 i 0 Which one was contracted first; de you know?
25 A : assume with reference te Midland?
l ALDERSON REPORTING COMPANY. INC.
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t.
t 1 [. Q Yes, sir.
I 2l A : don' recall who : called first, but i was very <
s I
3 close, in a very sher period of ti=e.
4 i Q Was it your idea := contact both of them? ,
e A I'= not sure if it was mine or if : had input frc=
n 5 hl "
N
- 6. cthers.
3
> n .,.
E. 7- Q Could have been either One of them? ;
t N i
4 8iq A Could have been. ,
e e n 9l Q Tirst ene you called, vou dcn't remember?
l z.
5 10 ?J A : don't remember exactiv =
what happened a: this z
=
7 11 incident.
5 4 12 - Q What is Mr. Needward c: Or. Woodward's function?
z $
=
n E 13 < A He does censulting for me en many jchs in the i
=
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14 \. Ann Arbor office. He was first enc.ac.ed in Midland, I believe, s 4 i 15 seme:hing about the dutch measurement, the measurement a: the x > .
= *
- d a
16 5 Diesel Generator and the tank f arm area. He was helping in
= 1 d.
17 j.-1 c. ickinc. loca:icns. ,
= s E 18 i Q He is not an employee?
y 7= 19 e. A He was under the censulting agreement.
n i
. 20 s1 Q Does he work at the universi:v.?
t 21! ,
A He is a partner in a consulting firm.
a 22 3+ Q !s Or. Wood still under centract?
23 A Yes.
24 Q These men, Dcnacliff, Gray. Richards, are they still i
l l
25 under contract with Bechtel?
i i l
I t e ALDERSON REPORTING COMPANY. INC. 1
.~ _ . . - . . - - . .- .- - - . - . .
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E 1 A : don't believe 3 ray is under contrec: er Gray has 2 , done some work for us under a contract.
3g Q Are they still under contrac:? You are indica::.ng 4 Gray?
i . a
- 5 A He is not?
n a :
3
- 6f ;
- Was he ever?
R 1 E A Nc: to my knowledge.
7 l*
M i
te 8 0 He's working for scmeone else?
= 9l A Yes, Richards is contracted to Bechtel, he assistec i g i i
$ 10 g us in aspects of the develep=ent, design input for input :0
_z
. 3 11 the structure design ceccle..
1 is 4 0 Is he still under c:ntrac:?
z 12 'd
=,
- 13 A : believe it's continuing.
l E 4
14 0 Tr. Donacliff'.
!.: 15l
- e A : don' t believe he :.s invcived in Midland anymore.
j 16 3Excuse me, c rrect that. I do know that Donacliff, he is i under contract, but I believe he's still -- have to have been.
H
- 17
=
7 18 )His contract wasn't related jus: : Midland. I presume he's
(
t, 19 5under contrac: at Bechtel.
5 *
. 20$ Q :s Dr. Weeds now performing any settlement ::=putations, i
L 21 3,for the Diesel Generator Building?
9 r
22 t, A Computations?
1 i
23 - -
Q Yes. ,
\
24 u A I'm not aware of his performing any for the Diesel 25 Plant. l a
s
.s ALDERSON REPORTING COMPANY. INC.
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1 O He's never done that?
i 2h A He has done settiine. c0mo.uta:10ns fer the pefistles. ,
3 Q Do you know if that --
4 A I believe that was provided to you.
1
~
. = 5 Q Dces Bechtel have any reccrds showing the nu.ber of N i
- 6 /, hours sc. en
- hv. . any of the consultants en the Midland fil;
. p 1 E 7 " settlement problem? ,
M ri.
8 A !'m not sure if the hours are listed, bu: there are ;
, 'J d 9 bills submitted and = aid. -
From these hours can be estimated. .
4 z. t h 10 Q 3111s thev
- submi: to *vou reflect the nu.ber of hcurs i
1
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< 11 l they spent en the cro - ect? ~ .
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d 12 L A : don't usuallv- see the bills. :: Oces : sv z - - .
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E 13 superviser or : don' t normally see the bills. I: would irlicate ;
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j 14 one day or half a day, something On that order. This kind of a - ' l b :
E 15 I'm not sure :.:'s to the nearest hour, but the neares: half fav.
2 r 3 l j 16 l Q Among all the consultants you ;ust mentioned have e i i 17 they ever' disagreed with the use cf the surcharge?
2 E 18 ; MR. FARNELL: Repea: that.
4
=
. ~
I. 19 i (Questien read back by the M ,.
20 3 court reecrter) 2 21j A No.
2 22 4 3Y MR. PATCN:
h 23 !, Q Among all cf the consultants you jus: =entioned have ,
24 any of them indicated they wcuid have imposed a surcharge program t
25 in a manner in any way differen than it was imposed?
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i s ALDERSON REPORTING COMPANY. INC.
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1, A : don': believe, don't believe there was such a i I e
2 ; conversation ever raised.
i 1 3& Q Did any of these consultan:s make recon =endations :
1 i 4 l for fixings other : n the surcharge prcgra=7 e MR. FAR iEI.I. : Some other fixings, .us:d the diesel?
- 5 !. l O i 3
e 61 3Y MR. PATCN:
n f 1
J E. 7* O Do v.ou know why v.ou i=eose a surcharge a: the *:iesel n y
- j 8 [ Generator Building? ,
d \
- 9( A Yes.
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E.e 11! A To consolida:e a fill. That was done, that's the 3 i e d 12 'i recc=mendation of Or. Mendron, assume vcu knew that.
z -
!, .s 13 $ 0 Did any of these consultants make any recc==endaticas
=-
lt: 14 ! c her than the surcharc.e O.rcgram Oc consolidate the fill?
! E 15 ' A There were cptions considered, various options i a $
=
- 3 4
y 16 considered at the meetings.
d 17 1 0 What were they?
4 d
!* E 18l A : recall -- they were listed in a letter from
- )
1 E. 19 i Dr. Hendron, and one was to, one option was nce to de anythinc
) g 20!at i all. One option was c srucharge the building, another option
?
21 ' was tc use caissions or piles, essentially underpinning the i
I 22 bu:.1 ding. One option was to remove and replace the building.
i 4
23 That is mv - reccliection of the optiens considered au that d t 24 meeting.
r 25 Q At that - meeting, what was that date?
, 4 ALDERSON REPORTING COMPANY. INC.
L l
f 1- A : don't recall th date.
p 2! s C T.ke meeting that had been referred to in some Of the F
3 i documents : have shewn vou?
9 i
4: A : believe it was the same meeting, the same One you a
t
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- 5 i showed me earlier.
That sea: *nt.
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2 6 0 Was the meetin ireferring :: in February, 1^50?
a n -
A A : don't believe ink bef:re that. The meeting 7l I ,mented.
i 3 a J,was before the surcharge was d 1 n 9R (Discussicn held off t."e record)
,- s t j
@ 10 F A The one I'm referring to is the memorandum by z ,
= ,
7 11 4 Dr. Hendron about the same meeting.
i 3
z 12 i 3Y MR, PATON:
- 4
- a 5 13 i 1 And the date cf the meeting you' re talking about
=
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a 14 ' was what?
t
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A Ncvember 7th meeting.
N 16 r O Did anyone at that meeting state that one of the s
a >
+ $
h 17 ' alternatives, fixinv s were preferable to the surcharge program?
a 1
=
- 5 18 : A : don't recall.
=
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. e 0 19 .' C At a nv. meeting did any of your censultants indicate 5
a 20 some alternative was preferable to a surcharge program?
a 21 ',. A : don't recall that. I acn't recall that.
t 22 '- Q Was there ever any discussion 20 the ces: : remove J
23 ' and replace the fill?
24 t a A Yes.
25 Q Do you recall wha: that estimate was?
ALDERSON REPORTING COMP ANY. INC.
l 1
0; .
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1 A
- don't recall the figure, but : believe NP.C requested k '
2 e that information cf Bechtel in one Of the c.uestions. -
l 3,l 0 You don't recall even ac..eroximatelv. what that fi:ure .
I 4 . was?
I
- 5Ip A I believe it was somewhere in the or(er of twentv.
- R (
~ 1 J
4 6 million dellars, but don't kn:w if that figure :.ncluded t
E. 7 re=cval of the fill and replacemen: 0: 'us: . rencval. I am no 5 8 a< sure what that figure is, twenty millien dollars, : don't know ,
., a w q 2 9fwhat it really does and does not include.
E, l
g 10 ( Q Ycur recollection of the figure, did that apply :=
z t
=
l j 11 ll the Oiesel Generator Building?
i 5 g i
d 12 *8 A Yes.
4 z
=
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= _j 4 N. 14 ! ac. c. ro.eriate fix to the Diesel Generator Building?
= s j 15 - A Yes, cost is a factor in making a decisien, yes.
e_
j 16 j Q Is there a potential soils founda icn problem :.n
- i
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17 ? penetration adjacent --
t E 18 k Ma. TAmc;L: Potential? ! don't undsrstand it.
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I- 19 : have an ob.ection as to :he form. What do vou mean bv a b
. 20 l potential?
0 21l 3Y MR. PATON:
l 22 t 0 :s there a soils problem, a soil foundation problem i 1 l
23 '+ in the electrical eenetration adiacen:
. . : the reacter containment?
l 24 l A We have reports that the soil bcrings indicated 25 the fill there was inadequate as the fixes are required.
ALDERSON REPORTING COMPANY. INC. .
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4 1 : O What is the prepcsed fix in that area?
h a
2{ P A For the electrical penetration, is to :.nstall t
3 [ caissons.
d 4h Q Have any of the consultants that we have discussed a
f e_ 5 I suc.c.e.sted of a fix ether than caissons?
" is j A : believe there was a consideration of s==e:h:.ng
,* =
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- 6 5 7 different. That is outl ned in tha: Cenver Ci v. le::er that you n
n 8 dust showed me. I believe there was reference to replacement 9 .,. of the unsuitable material, something along those lines.
z '
b 10 Q Who suggested that?
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2 11 A I don't know who suggested it, but c:her options 3 '
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12 { were discussed.
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15 [ Other coticus were lef: 0:en Oc Sechtel in tha meeting. I
= :
y 16 ! don' recall how the decision was made :: select caissons in A f. .
d 17 " f avor of the c her cp ions. I x s ,
= s E 18 i '
0 Caissons you testified briefly -- '
=
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2, 19 A Removal and reclacement -- can : lock a: that ac.ain?
M
. 20 . C Yes. ,
, 4 21 j A Yes, there are c her options. Page six of the 1e::er i
22 ' dated July 2, 1979, and the first one says removal of the 23 unsuitable material en replace concrete under the valves and wing
' i 24 can permanently provide temporary supper: of wings with =aissens 25 en the outer edge. One eption was := provide permanent caissens k
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, ALDERSON REPOHTING COMPANY. INC. : 4 I
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2 ., per inch. "'here are .hree or f our op: lens.
I 3l -Q You elected :: use caissons?
I 4! a A Bechtel did. .
I Is that also your recommendaticn?
. .a N
. 5) Q 3 6 A I favored caissons. I fel caissons would he 1 :ood -
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"A 7 iway. to do it.
- -don't have a s ranc. feelin: One way ::: the .
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n 3 8 f other.
y I leaned :oward saissons.
0 d 9l 0 Do ycu knew which of these al:ernatives would : s:
i-5 10 the most?
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= :4 7 11 P A : do not.
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- i 12 1 Q Did Bechtel make that address a
- the meetine, wh::h z
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13 l of these two would have been mere expensive?
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= 14 h A I'm not aware of such an evaluation. ,
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_E 15L Q You don' remember er you didn't make any?
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3 16 I A If such an evaluation was made it wouldn't be made I
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. 17 bv me.
It would be someone else. I am not aware if such an i 4 t
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L 19 g C, . .0 In v. cur. iud =.=ent .
vou would use caissons, that was n i a
. 20 i made independent of the matter of ::st?
a c
21 f, A Yes. A: the time it ae.r. eared a rather sim=.le c.recedure h
22 i to f=11ow.
1 23 0 -!as sechtel centracted for plans and spec:.fications a
4 24 ' for use of caissons?
1 b
- 25 A .I'm aware of specifications, they have been prepared, e
P li ALDERSON REPORTING COMP ANY. INC. i
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1 2i but : am no t aware of any contrac: :lans.
. If vou mean hv.
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3li Q Oo .vou know if that information has been sub=i::ed 4 l. to the NRC7 ,
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3 A So. ecifications . .
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. < 6*; Q The enes he indicated?
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76 A To my knowledge the specification has ac: been ;
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Q Have you concluded that, hv. .vcu, 3echtel concluded s
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A Yes, 3echtel has cencluded that.
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= 3 7 15 Q Have any of the censultants underpinned that s tructure ?,
A
- 4 A : am not aware of disagreemen: on the car of anv 3-16 l' - -
I d' 17 j eensultants. '
5 e y ,
5 18 4 Q Occ or, I asked you a number of questions about
= E t
? 19 ,r whether er not your consultants have agreed to disagreed with a .
. 20 .q clans and v.ou have fir =l.v incicatec :nat none c:. tne censultants th 21 5 disagreed with any of the plans
- asked you about so far?
F 22 , A Yes,. believe that is so.
4 23 Q Let me explain. Are you aware of any instanc9s 24 ' in which Bechtel concultants disagreed with any part of the 25 propcsed-fixes.for the soil settlement prcblem at the Midland site?
8,
- ALDERSON REPORTING COMPANY. INC.
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15 A 'Anywhere?
2}; O Soil se::lemen: problem at the Midland site? ,
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3t A Will you repea: the-questien.
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4 i, (Questien read back by the
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65 ,
A I am no: aware of anv..
n 7 C :n your p cfessional :udg=en: censidering = -"e i
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n 8 various issues that are to be addressed to the Midland site f
n 4
9! does it strike you as unusual that se many consul: ants have such I k C 10 ( an agreement on the preposed remedy?
t 2 11 MR. FARNELL: Objection. It is an argumentative 3
I i 12 z 1. question. ,
=
p 13l 1 MR. ?ATON: You are instructing him nce := answer? :
- s x
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MR. FARNELL: No.
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A Everv.
consultant was really hired in specific areas
= .
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. 16l and every consultant stood behind this recenmendation, to' my x i l
d 17 :. recollection and was willing to stanc behind it.
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$ 18 *! G What you are indicating is tha: the reccc=endation
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= 19 ,i cc=es from the censultants more than Bechtel? ,
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. 20 ? A Of Diesel Generator Buildine. recc=mendations came ,
1 I
21 l f cm Hendron, Peck, and I believe they stand behind their 5, -
- t. I believe the original idea came from 22 [ recommendation.
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23 Mr. Davison. I believe he stands oehind it and the caissons, 24 i. it was discussed, the caissons are another oction, and the 25 consultants left it up te us , 3echtel and the watering optien i
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3 ALDERSON REPORTING COMPANY. INC. :
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) was criginali suggested by Hendren. : have net, ! don't recall i5 2 ,I hearine. anv. etner :::icns to it. .
I believe every:ne stands behind n
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s 2 6 e consultants, do you personally?
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- e. so.
i 5 8i P C Eave *vou heard er seen any other infor=ation a
t 9 j that would 'allcw you to believe that any of the 3ech:e1 e=picyees Y b 5 101 disagree with these by any 3echtel consultants?
- c 7 11 l"' A : have seen nc inder=ation er kn:wn of any ne I
.: 12 ! who disacrees with the fixes we are undertakinc.
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. .'. e ' 4 x c . "a s e v-- 4-a wa --a- ---"--"-a ' -
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14 } attach piles :: the end of the structure tha is new supper:ed by R
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A Will v.cu receat it? -
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19 : A Yes.
X S A
. 20-: BY MR. PATON:
1.
21 i, O How many. . cit.e ciles will be used?
r 22 ' A I am told that between, we'll nend sixteen pi'.es, t
23 it's =v understanding of what they will need.
l l l 24 C And these pipe piles are ever stee; casings 25 ; # 4--.^ '.e d '"- ~~
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ALDERSON REPCr.NG COMPANY. INC.
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2 Dc you knew how they would be attached to the 3 lp huilding?
5 4 A Some idea, but i am not invcived in the design 4
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. a 6 .s 2 Will v.eu clease read back that answer?
a n r R 74 (Answer read back bv. the
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- .9 ! Q Dr. Afifi, de ycu knew who in Bechtel can explain l
z-l 5 10 how the pipe , iles will be attached to the structure, water ,
z
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I d 12 A The person you should ask wculd be the chief civil z 1
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- 13 l engineer, Mr. Dhar. ,
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=l 14! O Was there semeene else vou were coine to nar.e that
_ d 2 15 ! is famtliar with that?
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16 '{ A Mr. Johnson, T. E. Jchnson, chief civil engineer.
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= P E 18 4 the meetine. noted dates Sec. tember 2S , 1974 from Volume Three,
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. 19 . tab one , and it is signed by S. Afifi. The subiec: - title is t
20 j *- , s e.-~' a ..' c.a.s S - o - m - e .e .4 .' .' Su eo. .=.4
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21 ) item four, at the top of page three it states, a: the eas: end l
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22 h of the building -- and under the Diesel Generator Building 23 there are places where the foundation is separating from the 24 [ mud mit below and is settling under its own weight. I hand you 25 that, if you would like to read it. When you have completed i
i L $ ALDERSON REPORTING COMP ANY. INC. .
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i 1 ._ reading that le me knew as : have sc=e questions.
I 2[ t A : vaguely reme=her tha meeting.
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4 pro , ~ ram did v.ou make tha: the condition of the scf: soil -- there s 5 is a statement there that the Docter has placed where the founda:Len
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H 4 j 6 < as separating from the mud mat. Do you knew whether that condi .:n n a A
7 i still existed af ter the surcharge program was c=nnected?
W i
a 84 A : was told after the surcharge program was complete n 9:1 that we might have that exas: between the f:undation. '
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- 1 2 11 ' A Dr. Dhar would be the one := ask.
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y 12 C : believe subsequent to his =ece the duct pans were s.g> -ad-
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15 l pans were separated and the building se:: led would that eliminate e
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- 16 ! the ccndicion described where the foundation was secaratine 3
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17 .' from the mud mat..
4 Y i E 18 4 3
A : believed I answered v.our c.uestion c.revicusiv.
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C. 19 bv. sa.v. :.g there was still a gap. ! believe i: was measured n .
. 20 l before -he af ter surcharging and there had plans to grou:
h
,. 21 4 this c.an. .
I am not sure if that has been accca lished or net. .
t 22j. Q Doctor, I want you te read paragraph four, page 23 ' fcur f cm the same document we have just been -='a- 'ng c,
-24 ' and this is Vclu=e Three and this is entitled Observations 25 ' t.' .d .' .' S ". 7, c .- . ed S '-" c ."..- =. ,
.=...c' .7 a ... . e .=- d .' . . c. 3.-..- a , age .'ou..
Ii i ALDERSON REPORTING COMPANY. INC.
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) i The fill is 'probably settling under its own weight in 00=tination
,E The fill material -
2 \ with the set:11::: of the buildine weicht.
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0 3 . =ay have been placed in dry chunks and seme voids.
5 When the l
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3 e 6 ,, increased c0=pressibill:y.
N Yes.
3 5 7 A n
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8 Q Do you agree with that statement in that-paragraph?
O A 9 MR. FARNELL: Cne by one.
5 10 ' 3Y MR. PATON:
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2 11 Q Okay. One at a time.
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5 7
12 1 3
The fill is .:::bablv. settline. under its own weic.h:
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- 13 i in combination --
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14 ! MR. FARNELL: That was made by Dr. ?eck.
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- 15 4. SY MR. PATCN:
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16 l C Do you agree with that statement?
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s 17 l A I'd like te see it again, N 9
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$ 18 l MR. FARNELL: Ycu're asking if he agrees with that
- . ,i 0= 19 ,4 state =ent, this 00= ment as made or now?
n
. 20 MR. PATON: New.
21 MR. FARNELL: With all hindsight.
i 22 A : don't think : disagree and I don't believe : de 23 now.
24 3Y MR..?ATON:
25 Q The-second statement, the fill material may have been 2
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5 10 i settlement to take place. That is possible and plausible fer sc.e
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7 11 ' settlement Oc take place because the data after that date shewed 1
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16$ Q Your statement is based on all the infer =ation ycu have a
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R a 17 := date, ycu cannet agree.with the state =ent tha: :his =a:erial x :
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18 , =ay have been p3 ace:. :.n cry enunxs: :.s that correct? .
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22 P. v..-a .- .A.c . ' *. ". ave a .v.
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' 23 have been?
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24 A May have been r v. e s ,
25 <. e. n.. e s
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I ge. well-ec=pacted and the bot:c= will not; do veu acree with a
s 2 f that statement?
b 3I A Yes, do. Yes, as a general rule, yes.
1 4k Q Following that a . mall change in the moisture will I
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10 l' A Well, we did at the time, was that ground water a:
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- I 11 the tec. level .as six twentv.-seven and he desie.n level was six 5
y 12 f twenty-seven, and fer tha: reason we went ahead and increased the
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close as possible to the design elevation in the plant area.
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15 l( 0 The design was six twenty-seven?
X y 16 1 A Which is the same as the pond level of six twentv-seven s' ?
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R 17 ; before the plan was censidered to be a necessity.
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E 18 4f Q f the pond level was six twenty-seven the ground E, 19 " water level would be --
n 20 !- A .cwer but conservative te assu e six ..eentv-seven.
s 21 ;
P Q In other wc ds, :he grcund water level wculd decline s .' .d e. k. ..' v.
. .'.~.r.. ..." e ed 3 e_ a. .' **e
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. 7 c a.d 23 ' A Certainly it would.
l 24 0 Did you think that by raising the ecoling pond :: six l
l 25 twen:v.-seven ac. creximatelv. ?.
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was going to be saturated?
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A As much as possible, ves. -
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A For the :ene that wasn't below the water table. . :
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16 Q can you estimate 1:7 s,
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$. 19 [ rap:.dly the water frc= the 00 cling pond wculd reach the riesel I
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- De v.ou knew of anv.ene in Sechtel whc =ade an estimate i
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23 On how long it would take the water frc= the cooling pond to i
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25 A : believe the estimate is in the presence of the 1-ALDERSON REPORTING COMPANY. INC. i
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1 desi:n, the watering system done bv cur c. ec '.c e. v. c. e c c. l e .
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wou;d slow;v rise as a result of your raising the pond :: six
.,.,, 4 9 ! hundred twentv.-seven f eet; do you agree with that statement?
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$ 10 t A It depends on what you mean by s10wly. :: affects z 4
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i 2 11 the water level at the Diesel Building, that is affected bv. the E 9 y 12 } water level at the pond.
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the eccling pond, de v.cu know accroximatelv .. . what level tha:
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21$ A I mean in the pond level that had increased a bi:
22 ~ and then the d:cp was very, very slight := the amount and i:
23 , showed the curve with concave dcwnward and seme of the pre:cmeter 24 .
readings showed that before.
25 Q If it get above six hundred twenty-five feet did it i
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22 ' Q Do you know who?
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24 Q s it v.our crinion that grcund water leve'. below the 25 Oiesel Generator Building is at six hundred twenty-five feet?
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.i 7 twe.nty-seven. The pend has dropped a few 'eet.
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15 i A will you read that back?
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Q 30 you know what the ground water level of the
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4 21 4 A Again, the cuestion is not clear. A: the time we d ;
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24- A sc=ewhere about six hundred twenty-:wc, but : don' 25 recall the exact figure.
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. e 5 MR. PATON: Let's =.0 off he record.
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21 5 methods that those are the two criteria.
22i O These two criteria are equ. valent?
7 23 .,.
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25 , Q Doesn't the'3echtel = edified invcive a compacted I
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18 (i Q So it is your testimony i really wouldn': =ake ry
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19 ai substantial different which of these we ests were used?
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20 4- A : don't think so.
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2I : O No substantial di##erence between the two?
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24 ; A : said ninety-five percen: cf the 1557 is apprcximately '
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I g 53 A Scme difference.
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A : believe twenty thousand per cubic fcct.
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15 ' were twc ce= pact ons in that Da=es and Mccre report? b
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~- E E 18 i One used the 1557 which required the fif ty-six and the Other 6
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E X 19 4 used . :wenty thousand. n 20 'i t C
- et me ask you if ycu have any cbjection fr:m this 1l 4
21 , =. cin On :.f we use the fif tv.-six thousand and twen:v. thcusand 5 22 ",> f e e : pcund test? i I 23 A No Obiection. 8 24 , .u.n . rA.:_ir.* * .-
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25 3Y .E . PATCN: 4 ALDERSON REPORTING COMP ANY. INC.
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$ 19 " method shculd be used, whether :.: was the fifty-six thcusand n
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21 5 but don't reca'.1 when. s 22 ' n,. . = .~.. s.e. .k.d ..c. v,, c u w".e . .h. .e - .- ~.^. ~. v. e "- * .e .= wa.- a. ..". a . f 23 i i . m e C.w. . e .1
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n i i l -~ $ 2 ; period? e i 3 *4 i 2 Yes. i 4h A I'm not aware of Ocnfusion.
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Was there any confusion? MR. FARNE'*: J e
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C Was there any confusion a: any ti=e a: 3echtel to .
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.e 11 t A : first time : came across it was sometime in 1974.
5 ! f 12 j 2. TO your knowledge was tha: confusion rescived? 4
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13 ' A I thought it was rescived. 1 = .. t 3 14 j Q When di you think it was resolved? -
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=- a E 15 l A :n 1974.
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j 16 0 want to show you Oepcsition *. and this .s dated
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E 18 L c page eleven, twelve and thirteen. i .
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1 5 l . 20 5 statement. The fcilowing is a summary of the documents regarding , , 21 : .
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ti a 22 ) _ill. !! ask you to look at that, at those pages. 4 23 'l A You're asking me to look at the c.ac.es? 4 1 1 24 3 >>
.MR. FARNE~L: You can 10ck at the whole document.
25 ' BY MR. PATON: ' ': ALDERSON REPORTING COMPANY. INC.
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;. 2 ' portien of page eleven and twelve and page thirteen through 3 ( item ten?
4f, A Yes, sir. And- -did . .".a . , -- ' e s .h. a . a .' '. a.c . v. "..- .a.vd. us e
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9 6: sta anen Oc your knowledge the confusi:n as :: which it would 2
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I 9 A He did not state as far as am concerned. The first
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p 11 j to the pro ect engineer wha: =y interpreta:icn was and wha: 3 ! I 12 ; should the criteria be in 1.37'.
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a s-13 l,q Q Would v.cu, after readinc. c.ac.e eleven, was there
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16 I A On the basis of that? J- 1 x .
$- 17 ,1 Q Absolutely.
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21 I documents cicse enough. don't knew for sure. 4 22 3 Q Didn' have confusion, after readinc. c.ac.es eleven,
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l 23 ' twelve and thirteen, whe:her there was any confusion at 3echtel d 24 on the~ proper cc=paction tes: ec be used between the years 25 .o.i ,- . .c ' c.. > o. e.
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- 8. L g :s this an area, the proper :0mpaction test, is
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j 16 ! of wha: I thought was the proper Compaction criteria in 1974. m h i 17 1 Q Whv? - a ,
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5 i 2 i criteria A which involved fif ty-six thousand pcund tes: and e E 3 l cne invcived the twent. thousand pound test. Were these wo b 4 I, reports inconsisten:?
. e. 5) A one rec.uired five c.ercen: =cre , ene twen:v. , tha:
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T 4 u 14 a,cne hundred cercen: of twen:v. thcusand pounds and one said v.ou 2
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j 15 5 use ninety-five percen:? 4 j 16 . A .ecr soils below structure.
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f 21 i . 0 Scil no: below structure? 1 22 L A Not this criteria. ^'here is a icwer one. 1 5 23 : 4 Q We're talking about the criteria below the ser:cture.
- I 24 ' A Yes.
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_4 . . ..". as_.""ase' t, 19 ,) n. 3.44 - . w--. ra c ~ 3 s .. . " . .=. .' . . e d u e. .e _ _= . _ 5 ? 20 ! Suildine meet either of these tests? ! . p C 2I . A Not at all points, in mv. o c. i n i o n , r.v. ud: ment. 4 22 ,P i : specifically refer you ec item s:.x and I'll show C 23 " v. ou , this.is cac.e two of NRC Ce csition'1, Hern. 1 I'll show ycu 24(this, I'm reading this dated Septer.ber 9,19 4 frc= Hargreve ( 1 25 Engineering and it states, ; made an analogy, a persona. c i- ALDERSON REPORTING COMPANY. INC.
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2 , coulc. c, e achieved witn a near c, mu.es ws_.<tng over :ne ::1 3 l it would be acceptable as icng as i:
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- ask "1cu de v.ou ac.ree with tha: judg=en expressed N
e 6.;- -- .ue-- s s.u.a,en., e i n . E 7*I MR. FARNILL : What de you =ean by judgmen ?
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2-1' 5 10 i 0 cc you agree tha: compaction can be achieved with a a z
= d 2 11.f herd of mules walking ever the fill i would be acceptable 3 !
c' 7 12 I as long as it was the rec.uired nine;".-five c.er:en: Oc= action? . 5
- 13 s, MR. FARNILL: You're talking new?
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2 i F 15 ',' C De v.ou ac_ree that it enc.resses a normal en-ineering 3 4 3
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. 20 g procedure you used :c ge: the fill as long as you achieve the 21 end result. I don't think they were sericus.
4 t 1 4 22 e a. Under your interpretation de v.ou ac.ree, as vou . I l i 23 # _ n '. e - ,- .- . . '- _ --, da uw v. eu -a g_- =.a- ..' . = ..". = a- ."~~ _-
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4 21 E a: the east and west ends Cf the building? no 22 I! MR. FARNEI. ., : s this sC=ehow Connected? e.3
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24 a 2 Somehow. Can yCu' answer the question? 25 A Repear it. U
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t . _ n, ,i 1 N 1; Q 3e ycu agree there * , efore surcharging, there. ,. I 2 was less settlement in :he middle of the Diesel Genera:cr l l 3 i foundation than at the eas 1 and west end Of the building? s, a 4 le A don't recall the settlement pattern but this data 4 A a i
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22 1 duct banks were cut away?
?
23 A : don't know. I wouldn't know that. 24 Q You don't know if it was =cre than a year? 25 A : don't knew. I don't recall the history of the l 1 l
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PE NAL RESUME g, g 5= ~NAME- Sherif S. Afifi 10/27/80 DATE M ~ Assist. Chief Soil Engineer - 28 gg { '
' CLASSIFICATION GRADE
=5 k
G~ - ORGANIZATION & LOCATION 5 Division, Geotechnical Services, Ann Arbor S f:k.: 21/2* m 21/2" GLOSSY BIRTHOATE 0/29/37 CITIZENSHIP U.S.A.
=
5 g 9/17/73 ORIGINAL BECHTEL EMPLOYMENT DATE 5.. 5... N/A h= RE-EMPLOYMENT DATE(S) .
.=5 Barbara Jean Afifi
=
g g SPOUSEli N AME h PHOTO DATE CHILDREN BIRTHDATES 3/1/ 0 E 2: None ,' sg MILITARY SERVICE & RANK b PROFESSIONAL LICENSES AND SOCIETIES h Professional Engineer, Michigan ,
=
El Menber, American Society of Civil Engineers SE { 5 l 5
;f.f EDUCATION AND PERSONAL DEVELOPMEN'T PROGRAMT
( DEGREE, CERTIFICAT . ETc. SCHOOL M AJOR (CR SUBJECT) DATE 3 B.S. Ain Shams University Civil Engineering 1961 g Cairo, Egypt 5... M M.S.E. University of Michigan Civil Engineering 1967 M Ann Arbor, Michigan - 5
- 5. Ph.D. University of Michigan Civil Engineering 1970
- s ' -
Ann Arbor, Michigan , 55E
=. .
OTHER SIGNIFICANT IN FORMATION (Refer to instructions before completing) . . , . < . . . i
@ ACHIEVEMENTS:
5
@ Afifi, S. S. And Woods, R. D. (1971), "Long-Term Pressure Effects On Shear E.) Modulus of Soils," JSMFD, Proc. ASCE, Vol. 97 SM16,.pp 1445-1460, October.
?=.5 E Afifi, S. S. and Richart, F. E., Jr. (1973), ' Stress-History Effects On Shear EE Modulus of Soils," So11r and Foundations, Jr4.nese Society of Soil Mechanics
!.[j and Foundation Engineering, Vol.13, No.1, pp 77-95, March. ,
f Afifi, S. S. and Luscher, U. (1973), " Permafrost Thaw Settlement," A paper presented at the 10th Annual Symposium on Engineering Geology and Soils Engineering, University of Idab6, Mascow, Idaho, pp 1-17, April. 1 E- ,/ 4
. - . . ~ -
72 e
' .g '
NAME: OTHER SIGNIFICANT INFO RMATION (Continued)
~, Luscher, U. and Afili, S. S. (1973), " Thaw Consolidation of Alaskan f . Silts and Cranular Soils," Permafroat: The North Anerican Contribution g to the Second International Conference on Permafrost, National Academy jl of Science, Washington, D.C., pp 325-334, July.
5 LANGUAGES:
!=: l Speak and read Arabic, read French.
g M GEOGRAPHIC " g P
REFERENCE:
[]. Tis '
~
_5 - ASPIRATIONS: s p Continued technical development in the area of Geotechnical Engineering. g -
. Progress within the geotechnical organization to higher 'nanagement levels. - :
(USE SUPPLEM8NTAL PAGE,IF REQUIRE: 2 5 5 5 WO RK HISTORY ' M j.j DATES M C..Y R . COMPANY, DIVISION OR POSITION HELD.
!!!! DEPARTMENT:
SUMMARY
OF REsPONstslLITICs AND
],~- FROM TO LOCATION AND SUPERIOR sIGNIFICANT ACCOMPLISHMENTS
~
9/78 Present H&CF Geotechnical Assistant Chief Soils Engineer-3 Services, Ann Arbor Responsible for the activities of the M (S. L. Blue and Ann Arbor Soils Group which provides Soi_ is ( H. H. Burke) Engineering Services to in-house nuclear 5 and fossil power projects. The wor 1: iE
- includes subsurface investigations, @ preparation of foundation reports, safet:
E! analysis reports and construction 2 specifications, and the support of construction activities. Areas of , Q g particular involvement include in-situ 7 I? - 5 - measurements of soil properties, laborat testing, foundation evaluations, water
@ front structures, and soil dynamics.'
g E - 3/74 l 9/78 H&CF Geotechnical Soils Engineering Supervisor - Supervisi M Services, Ann Arbor of soil enginee ing work associated with M -
. (S.L. Blue and nuclear and fossil power projects. ] H. H. Burke) & :=%RT .
5: ~ = " . 9/73. 3/74 H&CF Geotechnical , Senior Engineer - Worked on various 15~ ' J; Services, Ann Arbor. assignments in soil engineering aspects
@ (J. H. Allen) of nuclear and fossil power projects.
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2T - I l 5 (USE SUPPLEMENTAL PAGE,lF REoulRE
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1 C- ** ' NAME:
. WO RK HISTORY (Continued)
D ATES MO YR. COMPANY. OlVislON 08t POSITION HELD. t
- D EP A RTMENT; sUMM ARY OF RESPONSISILITIES AND g
I :-li FROM TO I,0 CATION AND SUPERIOR SIGNIFICANT ACCOMPLisNMENTs. i,
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l Is 6/70 9/73 Woodward-Clyde Consultants, Oakland, Staff to Senior Staff Engineer - Worked c the geotechnical engineering design of th<
..! l J l ils California, (U. Trans-Alaska Pipeline Project. Prepared l Luscher) the soil engineering properties reports
= required for design of the 800-mile il '
pipeline. Also worked on slope stability evaluations, bearing capacity evaluations. Ei ~ 3 . pile design and buried pipe support ig g:.. design. . c.g s-E 1/66 5/70 The University of Research Assistant, Teaching Fellow, and 5 .c. Michigan, Ann Arbor Graduate Student - Conducted research in E (F. E. itichart, Jfr. ) soil dynamics, and assisted in teaching
}i soils courses. Completed Ph.D. degree fi program.
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3 9/61 12/65 Ain Shams University, Teaching Assistant - Taught undergraduate
,],; Cairo, Egypt (H. students soiP and structures in sessions 5 Mostafa) designated for problem solving..
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@j, 9/61 12/65 Sabry & Yousef Engineer (part-time) - Design of i5 Consulting Engineers, foundations and structures for industrial ig 19 Khalek Sarwat Str., and residential facilities.
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l Inter-office Memorandam GEOTECH ANN AR8oR DtSTRIBUTIOt.!
' A To Date Distribution August 3, 1979 y]'Acnisjo ACM4Nl l W[
Subject PROBLEM ALERT - From T. E'. Johnson capri ; off; Incorreetly Placed lackfill scitsF _ t b&/ Of Civil / Structural. '~ l
- t.J 5. L. . .ow File: 502 Ann Arbor Office "-M MEN if h' Copies to At ti i
%IM7/ _ .
f. Pmn Eht ' / *18 V xst7 2Ea stc h'n Attached for your review is a draft copy of the Problem Ale 4ECV E3 4 an ' to be issued on the large settlements at Midland due to the incorrectly placed backfill. It is requested that your co=ments be forwarded to us by August 10, 1979 %.,5,. , _y y
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TEJ/GT/wh VA g Attach =ents Distributicut E. Rt:r.bc. ugh K. Wiedner J.Milandin[ P. Martinez R. Castleberry . B. Dhar S. Blue ! S. Afifi SE.01398
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/ I. DESCR1.' TION OF PROBLEM Insufficiently compacted plant area backfill under the diesel generator building was discovered because of excessive settlement during construction. Both granular and cohesive soils were improperly compacted in other areas of plant fill as well as the diesel generator building. Ihis required extensive reanalysis and/or modifications of the diesel generator building, the service water structure, the feedwater isolation valve pits, and portions of the auxiliary building.
Based on a thorough investigation, the most probable causes for the resulting remedial work include the following. A. All types of compaction equipment used for plant area backfill
, were not prequalified for. lift thickness and number of passes.
This was particularly true for the'small' hand-operated equipment. Except for the heavy earth-moving equipment used to onstruct the plant area dikes, reliance was placed on acceptance being established by end result ASIM acceptance tests.
- 3. An audit has shown that the testing laboratory failed to obtain meaningful and accurate results after performing the ASIM acceptance tests. Some exa=ples are the following.
- 1. More than one-half of the test results for relative density and percent co=paction were outside the theoretical comparison itsit.
- 2. Incorrect soil indentification and calculation errors were also present.
. C. The quality assurance (QA)'and quality control (QC) departments
, only provided a surveillance program in lieu of an inprocess, in-depth inspection program. In addition, a continuous, thorough review of the tasting methods being perfor=ed was not carried out. II. APPLICA3ILITY These conditions are applicable to all projects where structures are supported fully or partially by co=pacted backfill material. ORIGIN: ENGINEER: CHIEF PROBLEM ALERT DATE: AA0 ENGINEER: G.A. Tuveson T.E. Johnson Large settlenents due NO: to incorrectly placed backfill SU.01599
, YROBLEM ALERT
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, III. CORRECTIVE ACTION A. The structures are being modified to compensate for the in situ soil conditions using the following solutions:
1.. Underpinning by the use of caissons and piles for structures partially supported by fill *
- 2. Reduction of residual settlement by surcharge loading structures totally supported by fill }'
- 3. Elimination of the possibility of liquefaction of extensive sand backfill areas during a seismic event by installing a permanent dewatering system Tf. The earthwork specification.has beenredised so that all soil .
compaction requirements are clearly defined in the specification. C. QA rewrote its inspection plans to i=ple=ent the requirements in the specifications. D. A resident geotechnical soils engineer has been assigned to the site to oversee the backfill operation. E. The soils testing laboratory has been made svare of all testing ' discrepancies and have taken actions to prevent recurrence. F. All of the construction equipment to be used for compacting the various types of soils at the site are being qualified to a maxi =um lift thickness with a specified nu=ber of passes. IV. ACTION RECOMMENDED TO BECHTEL PROJECTS A. The backfill compaction criteria for project earthwork specifi-cations should have a method basis as well as performance criteria for acceptance; i.e., each type of compaction equipment should be qualified at the jobsite for the respective type of soils to be compacted. This qualification includes lif t thickness and number of passes. The final acceptance criteria are still to be br :ed on testing by the appropriate ASTM acceptance standard. B. A resident geotechnical soils engineer should be assigned to ; the construction site to provide technical guidance and assistance in directing the earthwork, which includes coordination with the soils testing laboratory. S'4.?O1G00 t 1 I
' uvm.t.n m.c.u y Pcg2 3 D" D em e . SA L= C. The soils laboratory testing specification should be a separate specification and not part of the physical testing specification which includes other materials such as concrett. and reinforcing steel. D. The subcontract for soils testing performed at the jobsite should be awarded to an engineering firm that is specialized in the soils area. E. Quality assurance manuals or vendor procedure manuals for the soils laboratory testing should be reviewed by geotech as well as project engineering. g F. A maximum limit of the number of times a proctor curve may be used as representative of the material being placed should be established. - y. e G. [ To minimize errors in testing, the-soils testing laboratory b' should include the following practices in its testing procedures manual. i f 1. Cohesive Soils - The moisture content of the field g densities cannot fall outside the zero air voids curve [ for the respective specific gravity.
- 2. Granular Soils - The stock p"ed material should be h tested for relative density by soth the wet and dry {
methods as defined in the AS'Di standards to ensure that 2 the maximum density attainable vill be used in placement. ' H. Backfill Under Structures
. 1. Only granular material should be used with a specified gradation band monitored by frequent gradation tests.
- 2. To ensure that proper compaction is obtained, the frequency j of-pletting-proctor-curves or maximum / minimum-density G tests should-be-increased. c r Ter. '::- / -' '/? D '"' n'" -
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- 3. Consideration should also be given to performing static plate bearing tests as defined in the ASTM standards. The resident geotechnical soils engineer should have the option of requesting this type test when appropriate.
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[p3p93 1J i Js.Tn:.aurtby _, Bechtel Power Corppucn tmhap.c g y inter-office Memorandum 9"'4 i T-DiiFT l l l g-110 ql E. A. Rumbaugh To o,1, November 23, 1979 jghn= ~
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Subject Problem Alert - Large Settlements prom J. Milandin v Due to Incorrectly Placed Backfill of Quality Assurance w ? "l N' w.e h!E N l l , [ - o JOU %30 FILE Copies to E" *3*** At Ann Arbor T. E. Johnson W. T. Kellemann '
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- 2 a" The subject Problem Alert was originated by Ted Johnson as a result of a meeting which we held on June 13, 1979. The Problem Alert was, in effect, issued to take advantage of the Midland problem by providing for certain revis Nns in our specifications and controls, to preclude such a situation from recurring on another project. As you recall I suggested the Problem Alert. Ted Johnson has been working very closely with me to insure that QA concerns were included. Ted issued the report V to Ken Buchert on October 19 and received a reply, attached, from Ken Buchert, appamntly incorrectly dated, on August 27, 1979.
Buchert's reply, in effect, deleted all the recomended corrective actions by the Ann Arbor Office and effectively stated corrective actions which are essentially the same as the present program. Without the AA0 recomendations, the Problem Alert is truly incomplete. It will not prevent the problem from occurring again once this Problem Alert has been filed. The idea behind the recommended action of the Ann Arbor Office was to perserve these experiences by revising generic specifications and centrol procedures which govern the placement of backfill. It is requested that you look into this matter to detemine why the San Francisco Power Division Civil Structural Chief rejected the corrective actions proposed by the Ann Arbor Office. Each of those actions, which were proposed, were tied back to problems which were identified during the course of the investigation and were carefully developed to preclude the recurrence of such a situation in the future. Therefore, as the situation now stands, if the office follows through on the Buchert August 27 letter, new projects may fall into the same situatica as Midland did when memories dim. Please respond by 12/12/79. Please advise whether you consider this a matter to be handled by an MCAR. ,
. M11andin JM/le JM-79-122 File: AA0-QAR-79-66 SWO2046
N/C ' Bechtel Associates Professional Corporatic i x3g g,g .
, Inter-office Memorandum f To R. L. Castleberry Date 13 September 1974 i
sueject Plant Area Fill Midland Units 1 & 2 From
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Job 7220-001 of Geotechnical Services Coo'es to J. H. Allen M Ann Arber - E H. H. Burke /W. R. Ferris J. C. Hink R. L. Rixford J. O. k*anzeck 1320,3410 This me=o is intended to assist in preparing your formal response to Item 3 of BC3E-370 regarding compaction requirements for the plant area. Herein, we address reco==endations given in the soils reports prepared by Dames & Moore for the Midland project and ce= pare them with our earthwork specifications. The material in this seco confirms our previous discussions with your group. The evaluation here pertains to plant area fill supporting and surrounding structures, any Category I slopes in the plant area, and the ber= fill. In-Situ Clavs Tables 1 & 2 attached (taken from Cames & Moore's soils report of June 28, 1968, Page 15 and it- supple =ent of March 15, 1969, Page 16) present compaction reco==eacations for fill and backfill. In the June 28, 1968 report, the m_i,ni=um clay ccepaction is reco== ended to be95%forsupportofcri)icalstructures,90%forsupportofnon-critical structures, and 90% adjacent to structures, respectively; all percent compaction values are according to ASTM D 1557 Method D (about 50,000 f t-lb compaction energy). In the March 15, 1969 report, the mini =um clay compaction is recommended to be 100% for support, of stru-tures, 95% adjacent to structures, and 90% for area fill (not supporting or adjacent to structures); all percent compaction values are according to Bechtel Modified Cc=paction (BMC: 20,000 ft-lb compaction energy).
- Specification 7220-C-210 (Section 13.7) requires 95% of ASTM D 1557 Method D for in-situ clay in the plant area and berm. l In comparing the reports w'ith the specification for in-situ clay supporting structures, it is seen that the specification and the 1968 Dames & Moore report are identical. Also, the specifiention and the 1969 report are consistent since 95% of ASTM D 1557 Method D is approximately equivalent to 100" EMC in some soils. However, l
SBS00233
Bechtel Associates Professional Corporation R. L. Castleberry 13 September 1974 Page Two the requirement of 95% of ASTM D 1557 Method D given in the
, specification is the applicable criteria for compacting clay to support structures. Further assurance by conducting shear strength tests is required (see Section 12.4.8, Specification 7220-C-210) . Compressibility tests may also be required.
The berm fill must be compacted to 95% of ASTM D 1557 Method D to insure adequate seepage protection and stability. Category I fill placed within the failure zone of a slip circle may require a degree of compaction higher than 95% of BMC, because of design for the full SSE. However, it is conceivable that in-place fill compacted to 95% of the BMC will be adequare
.( if strength and permeability properties are shown to be adequate.
, Similarly, in-place fill supporting light structures may be adequate at 95% of BMC provided its strength and compressiblity are shown to be adequate.
Fill in the plant area which will not support structures or pipes or b9 placed within the failure zone of Category I slopes may be co=pacted to a lesser degree than 95% of ASTM D 1557 Method D (e.g. 95% of BMC). This agrees with Dames & Moore's 1969 report and is consistent with their 1968 report which requires only 90% of ASTM D 1557 Method D. In-Situ Sands gf i The Dames & Moore June 1968 report presents recommendations for 3 compacting sand in terms of maximum density while their March 1969 report presents reco=mendations in terms of. relative density. The later report is considered more applicable for sands since relative density. is one of the basic parameters required to control liqued ' faction. Therefore, in-situ sands supporting structures must be compacted to a relative density of 85% (ASIM D-2049). For well-graded sands around structures, the 80% relative densic specified 4 1 7220-C-211 is adequate.
.:tf 21 Q
/(fZi q : Ila-1r Any in-situ clay which will be supporting structures or be involved in Category I slopes and the berm must be compacted to 95% of ASTM D 1557 Method D.
If the fill is already in place according to BMC, it may be adequate for'some structures, pipes, or slopes, provided it is shown by sufficient testing that its strength, compressibility and scepage SBS00234 4 4
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Bechtel Associates Professional Corporation R. L. Castleberry 13 September 1974 Page Three - characteristics are adequate. This requires sampling and laboratory shear strength and consolidation testing. Section 12.4.8 of the earthwork specificatico addresses this issue for any in-place fill. Compaction curves using both ASTM D 1557 Method D and Bechtel Modified Method must also be developed and correlated with shear strength and consolidation test results on the compacted soil to evaluate the co=pressibility and shear strength achieved from both methods of compaction for the in-place fill. This information will allow a complete evaluation of any in-place fill for its proposed function, in addition to providing information which will be needed for the FSAR. It should also clear up any questions as to how fill should be placed in the future. We will be happy to discuss this matter further with you at your convenience. JC S. S. Afi i SSA: lab Attachments ! SBS00235 i
l
;; TABLE 1 n
i l l Minimum Compaction Criteria from Dames & Moore i June 1968 Report ** i l fj Recocmended Minimum Compaction Criteria Percent of Maximum Density
- On-Site On-Site Purpose of Fill Cohesive Soils Cranular Soils
!' Support of Critical 95 100 Structures i
Suppcrt of Non-Critical 90 95
!, Structures 1
Adjacent to Structures 90 95 l-
- Maximum density and optimum moisture content should be determined by the ASD1 Test Designation D 1557 Method D.
i 1 l .
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5 F e r ;u car Pow P1 Midl gn June 28, 196U. Sr 10236 i
e . ) TABLE 2 l Minimum Compaction Criteria from Dames & Moore March 15, 1969 Report *** Reco= mended Mini =um Compaction Criteria On-Site On-Site Sand Soils Clay Soils Purpose of Fill Percent Relative Density
- Percent of >bximum Densi Support of Structures 85 100 Adjacent to Structures 75 95 Area Fill (not supporting 70 90 or adjacent to structures)
- Maximum and minimum density of sand soils should be determined in' accordance with ASTM Test Designation D-2049
** Maximum dry density and optimum moisture content should be determined in accordance with ASTM Test Designation D-698, modified to require 20,000 foot-pounds of ecmpactive energy per cubic foot of soil.
l
*** Supplement to Report, Foundation Investigation and Preliminary Explor ations for Borrow Materials, Proposed 1:uclear Plant, Midland, Michiga March 15, 1969.
SBS00237
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!!II.1 Min CC:T C?t0N CRITERIA
] PLA!3T ARCA FILL MD BCRM i ,,, l Function of Fill Minimum Compartien Criteria t 1 In Situ Sand ( In Situ Clay ( } f Support of Structures ( ) 35" 95% l Adjacent to structures 80" - (Gradation specified in
, 7220-C-211)
Category I Slopes - 95::
- 95%
l Bern Area Fill (not supporting - 95" or adjacent to structures) l (1)All sand compaction is in terns of relative density as determined from ASE! D 2049 test.
! ( } All clay cc paction is in ter: s of caximum density as determined by ASE1 D 1557,!:ethod D except for area fill not supporting et adjacent to structures. In these arecs, AST.! D
- 537 nav be altered such that only
,' 20,000 ft-lb/ft3 o! cr.argy veuld be required.
( ) Strength and cenpressibility testing =ay be required to confirn adequacy of fill. II
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Ann Arbor; MI h810.6
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MIDLAND PROJECT - RE40 VAL OF LOCSE SAND - ,# - FILE 0130 UFI 08*C6 SERIAL 7802
Reference:
- 1) Consumers Power Company Letter, Serial 3h78, Dated October 6,1.
- 2) Bechtel Letter,. 3CCC-3587, Dated octo'ber 23, 1978
- 3) Bechtel Letter, 3LC-8167, Dated Septe:ber 17, 1979 ile have reviewed 3echtel letter, 3LC-8167, (Reference 3) and disagree with the conclusion that Bechtel is not responsible for the additional costs associated with efforts to resolve NRC c.uestion 362.2. We disa6ree for the follovi.c, rea-sons: -
- 1. Tne URC raised the loose san:1 question in early 1970. On Page 8.00-1 of th
- PSA3, Bechtel provided the 53C with a discussion of how the sands vculd be treated. The 3echtel intentions as stated in the PSAR irerc 20 follows:
"For example, in those areas of the turbine building adjacent to the c:r.er-1 gency diesel generator building, existing sand vill be recoved if further tests shev relative- density of this sand is less than 755." It is obvirus ths.t in place densi:7 testing was intended to be performed in ordor to veri l ~
the natural sand densiti.es.
/ -
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< 2. Bechtel Engineering cc:=unicated this co==it=ent to constructicn in 1975 b-/ ~
placing a note on Drawing C Lh' indicating that sands with less than 7% ' relative densities cust be recoved.
. 3 The loose sen:', cor.mitment vas also delineated in FSAR Section 2.5.h .5.1.~
This was a sta:e .ent that the design drawing. (C Lh) was issued to t ce.uire re:-Oval of loose sands with felative densities le'ss than 755. e n 2= ; I
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- h. In 'eid-1978, Bechtel Engineering asked both the Be:htel Construction and -
. Consuners Power Company Field Engineers if they had any knowlpdge of density tests taken for the purpose of cl' earing areas where natural sands Consumers Power Cc=pany civil field personnel spent several had existed.
- days looking at records in Jackson to identify any field tests perfor:ed All efforts by Bechtel and Consumers
.to document the densities of the sand.
' Power Conpany were unable to identify any documented field density tests -
which would resolve this question. In,mid-1978 when th'e investigation oc- ' curred, all of the areas in question had been covered by approximately 30' of backfill. - It see=s obvious to .us thst although field density tests were to be perfe:=ed to. . approve aiess where natural sands existed, the'y were not perfor=ed' or if per-formed, they were not doc,unented. Based on the inability to shev by decirsenta-tion that the c,o-dit=ent had bee'n adequately addressed, borings were ordered If density test had been by Bechtel Engineerin5 to resolve the IGC question. perfor=ed and documented initially, the recent borings and engineering analysis
' vould not have been required. Failure to properly meet PSAR and FS/.R co=mitments, f and the requirements of Draving C hk, has resulted in significant costs. to I Consumers Power Co=pany.
Therefore, ve do not accept the argument that because the recent borings showed
~
natural sands which had relative densit-ies greater than 75%, Be:htel has no liability for additional costs. It is our contention that no borings or attlysis' gg vould have been necessary if Bechtel had properly executed drawing, FSAR and PSAR
.t/
require =ents . [ }, ,
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G S Keeley ^ Project Managery GSX/cc , l . 3CC .DBM111er, Midland (3) - JLBacon, M-1085A . , DGRandolph, P-1k L22 , l
.JETelber, Midland. Accounting 8
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! 7. ( NUCLEAR REGULATORY COMMISSION l
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j ( ..... ,/ AUG 4 1950 Docket Nos.: 50-329/330 Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Cook:
SUBJECT:
CORP OF ENGINEERS REPORT AND REQUEST FOR ADDITIONAL INFORMAT 0 ON PLANT FILL fly letter of June 30, 1980 requested the results of additional explorations and laboratory testing needed to support certain geotechnical engineering studies on the Midland plant fill and associated remedial actions. That letter noted that details on the extent of these studies would be provided by separate correspondence. Enclosure 1 is a letter report of July 7,1980 by our consultant, the U.S. Army Corps of Engineers, and is forwarded to _ this end. Paragraph 4 of the Corps report identifies additional information needed to resolve specific problems identified in paragraph 3. For purposes of con-trol, we have re-numbered the subparagraphs of paragraph 4 to be sequential with our prior requests on this matter. They have also been marked to reflect the results of NRR review. Your reply should reference the revised numbering system and should address the requests as marked to reflect our changes. Subparagraph 4j of the Corps report entitled Liquefaction Potential, is not included in our re-numbering since it represents an evaluation rather than a request. We consider this evaluation to be tentative at this time since
,. it is subject to the determination of suitable seismic design input for the si te. We will address this matter shortly by separate correspondence, s
P* e
Mr. J. W. Co:k AUG 4 1990 1
,o l We would appreciate your reply at your earliest opportunity. Should you
. need clarification of these requests for additional information, please contact us. .
Sincerely, l f. tow //dv i A. Schwencer, Acting Chief licensing Branch No. 3
; Division of Licensing
Enclosure:
COE Letter Report
; dated 7/7/80 cc: See next page 1
! l l l
cc: Michael I. Miller, Esq. ,
, Isham, Lincoln & Beale Suite 4200 1 First National Plaza Chicago, Illinois 60603 Judd L. Bacon. Esq.
Managing Attorney Consumers Power Company . 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq. 1 IBM Plaza Chicago, Illinois 60611 1 Ms. Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 ' Frank J. Kelley, Esq. Attorney General State of Michigan Environmental Protection Division
'f 720 Law Building Lansing, Michigan 48913 ; Mr. Wendell Marshall Route 10 Midland, Michigan 48640 Grant J. Merritt, Esq.
Thompson, Nielsen, Klaverkamp & James 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 I i l
D 99]D
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?.r. J . W. Cook .
cc: Mr. Steve Gadler 5 2120 Carte.- Avenue
, 5:. Paul, Micneso:a 55108 Mr. Don van Farowe, Chief
[
. . Division of Radiological Health Department of Public Health P. O. Box 33035
)
- Lansing, Michigan 48909 L'illiam J. Scanica, Esq.
1 2034 Pauline Boulevard Ar.n Arbor, Michigan 48103 U. S. Nuclear Regulatory Commission Resident Inspectces Office Route 7 i Midland, Michigan 48640 1 J I I e 4 O 4 e
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l l cc: Commander, Naval Surface Weapons Center ATTN: P. C. Huang G-402 White Oak Silver Spring, Maryland ,20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Tecnnology Engineering Center P. C. Bc( 1449 Canoga, ? ark, California 91304 2 a' Mr. William Lawhead U. S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue 4 Detroit, Michigan 48226 j Ms. Barbara Stamiris - 5795 N. River Freeland, Michigan 48623 . Mr. Micaael A. Race , 2016 Seventh Street Bay City, Michigan 48706 Ms. Sandra D. Reist . 1301 Seventh Street Bay City, Michigan 48706 Ms. Sharon K. Warren 636 Hillcrest Midland, Michigan 48640 - Patrick A. Race 1004 N. Sheridan Bay City, Michigan 48706 George C. Wilson, Sr. 4618 Clunie Saginaw, Michigan 48603 Ms. Carol Gilbert - 903 N. 7th Street Saginays, Michigan 48601
4 ! cc: Mr. William A. Tr..dodeau j 3245 Weigl Road i Saginaw, Michdnan 48603 Mr. Terry- k. Miller 3229 Glendora Drive Bay City, Michigan 4S706 ? - F t I e 0 e
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; NCEED-T Interagency Agreement No NRC-33-79-167, Task No.1 - Midland Plant i
SUBJECT:
Units 1 and 2, Subtask No.1 - Letter Report f
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r.;l .'. THRU: Division Engineer, North Ce'Ntrk;i . . ATTN: NCDED-G (James Sim j io f, !l If ! , 70: U.S. Nuclear Regulatory oc=ission ! ' ATTN: Dr. Robert E. Ja Non ' Division of Systems Saf4E - Mail Stop P-314 ']/ ' Washington, D. C. 20555 ,
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- 1. The Detroit District hereby submits this letter report with regard to completion of subcask No. I of the subject Interagency agree =ent concerning the Midland Nuclear Plant, Units 1 and 2. De purpose of this report is to identify unresolved issues and make reco=cendations on a course of action and/or cite additional information necessary to settle these matters prior to preparation of the Safety Evaluation Report.
- 2. B.: Detroit District's team providing geotechnical engineering support to h documen s concerning th2 NRC to date has made a review of furnis, ed foundations for structures, has jointly participated in briefing meetings with ene NRC staff, Consumers Fover Co pany (the{ applicant) and personnel from North Central Division of the Corps of Engineers and has =ade detailed site inspections. The data reviewed includes all documents received through Revision 28 of the FSAR, A=endment 78 to the operating license request.,
Revision 7 to'the 10 CFR 50.54(f) requests an'd MCAR No. 24 through interim Report No. 8. Generally, each structure within the ccuplex was studied as a separate entity. , i
- 3. A listing of specific problems in review' of Midland Units I and 2 follows The issues are unresolved in many instances, for Category I structures.
because of inadequate or missing information. The structures to be addressed follow the description of the pcoblem.
- a. Inadequate presentation of subsurf ace information from completed All structures.
borings on ceaningful profiles snd sectional views. t
, 'l JUL. cou
' , NCEED-T SUBJECTS IntGregtney Agrecnent Ns. NRC-03-79-167,~ Task No.1 - Midland Plcnc Units 1 and 2, Subtask No.1 - Letter Report
- b. Discrepancies between soil descriptions and classifications on boring l
logs with subcitted laboratory test results su=taries. Exanples of such i } discrepancies are found in boring T-14 (Borated water tank),which shows stiff '
- to very stif f clay where laboratory tests indicate sof t clay with shear strength of only 500 p.s.f. The log of boring T-15 shows stiff, silty clay, while the lab tests show soft, clayey sand with shear strength of 120 p.s.f.
All structures.
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- c. Lack of discussion(l about [the .l criteria used to select soil san lab testing. Also, identificati$n hf the basis for selecting specific values f or the various parameters use fini foundation design from the lab test results. All structures. t (
- d. The inability to co:plefely ide'ntify the soil behavior from lab testing (prior to design and cotishruction) of individual sa=ples, because in general, only final test values! n sum =ary forn have been provided. .ul structures.
f if (1) Lack of site specific infor=ation in esti=ating allevable bearing pressures. Only textbook type information has been provided. If necessary, bearing capacity should be revised based on latest soils data. All structures 5 on, or partially on, fill. (2) Additional information is needed to indicate the design methods used, design assu=ptions and co=putations in esti=ating settlement for safety related structures and syste=s. All structures except Diesel Generator Building where surcharging was performed.
- e. A ce=plete detailed presentation of foundation design regarding
.:4 medial aeasures for structures undergoing distress is required. Areas of renedial measures except Diesel Generator Bui ding.
- f. There are inconsistencies in presentation of seis=ic design infor=ation as affected by changes due to poor ;eo=paction of plant fill.
Response to NW question 35 (10 CTR 50.54f) indieates that the lower bound of shear wave veJ.ocity is 500 feet per second. We understand that the sane velocity t.-111 be used to analyze the dyna =le response of structures built on fill. However, from information provided by the applicant at the site meeting on 27 and 28 February 1980, it was stated that, except for the Diesel Generator Building, higher shear wave velocities are being used to re-evaluate the dyna =ic response M the structures on fill material. Structures on fill I or partially on fill except Diesel Generator Building. l
- 4. A listing of specific iss.ues and information necessary to resolve them.
3 7. acacwr 5u1141=: r==dation (1) Settlement / Consolidation. Basis for settlement / consolidation of the reactor foundation as discussed in the FSAR assu=es the plant site would 2 IS$$'M M EE E d M JA M f- M [$kD5 7 M '~M3} @ b M Q $i$9f @ i M @~M M Y. @ $ T
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SUBJECT:
Interag2ncy Agrocment Ns. NRC-03-79-167, " Tack No.1 - Midland Pla.st Units I and 2, Subtask No. 1 - Letter Report not be dewatered. Discuss and furnish computation for settlement of the betor Buildings in respect to the changed water table level as the result of site dewatering. Include the effects of bouyancy, which were used in previous calculations, and fluctuations in water' table which could happen if the dewatering system became inoperable.h ,t ' (2) Bearing Capacity. Bearing capacity compuhations should be provided and should include metho ud d, foundation design, design assu=ptions, adopted soil propert'(es,' i and basis for selecting ultimate capacit. ; .nd resulting factor fjsafety.
- h. Diesel Generator Buildi (
(1) Settlement / Consolidation. ' In t te response to :mc Question 4 and 27; (10 CFR 50.54f), the applicant has furnished the results of his coeputed
, settlements due to various kindf/of l'oading conditions. From his explanation of the results, it appears that compressibility parameters obtained by the preload tests have been used to compute the static settlements. Information pertaining to dynamic respc-use including the, amplitude of vibration of generator pedestals have a. ;o been furnished. The observed settlement pattern of the Diesel Generator Building indicates a direct correlation with soil typer and properties within the backfill natorial. To verify the preload tee settlenent predictions, compute settle =ents based on test results on sa:ples from new borings which we have requested in a separate memo and present the result s. Reduced ground water levels resulting from dewatering and diesel plus seismic vibration should be considered in settlement and seis=1c analysis. Furnish the computation details for evaluating a=plitude of vibration for diesel generator pedestals including magnitude of exciting forces, whether they are constant or frequency dependent.
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(2) Bearing Capacity. Applicant's response to NRC Question 35 (10 CFR 50.54f) relative to bearing capacity of soil is not satisfactory. Figu:e 35-3, which has been the basis of selection of shear strength for computing ' ' bearing capacity does not reflect the characteristics of the soils under the Diesel Generator Building. A bearing capacity et.,mputation should be subsitted based on the test results of samples from new borings which we have requested in a separate meno. This information should include method used, foundation design assumptions, adopted soil properties and basis for selection, ulti::ste q bearing capacity and resulting factor of safety. (3) Preload Effectiveness. The effectiveness of the preload should be studied with regard to the moisture content of the fill at the time of preloading. The height of the water table, its time duration at this level, and .hether the plant fill was placed une or. . dry of optimum would be all i=portant considerations. 1
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WCEED-T
, SULTECT Intereg:ncy Agracment Ns. NRC-03-79-167, . Tesk No.1 - Midland Plant Units 1 and 2, Subtask No.1 - Letter Report -
(a) Cranular Soils. When suffici'ent load is applied to granular soils it usually causes a I. reorientation of grains and novement of particics into more stable positions plus (at high stresses) fracturing of particles at their points of contact. l
; Reorientation and breakage creates a chain reaction anong these and adjacent particles resulting in settlement. Reorientation is resisted by friction between particles. Capillary tensionI ould tend to increase this friction. A moisture iocrease causing saturacio'n,I l uch as a rise in the water table as oc' curred here, would decrease capillary tension 'resulting in more compaction.
Present a discussion on the water (table and capillary water effect on the granular portion of the plaht fill both abov,e and below the water table during and af ter the preload. / ,/llj i (b) Impervious and/or C' h. a Solis. i / - j , Clay fill placed dry of o tinum would not compact and voids could i' exist between particles and/or chunks. In this situation SPT blow counts would give misleading information as to strength. Discuss the raising of the water table and determine if the t'ime of saturation was long enough to saturate possible clay lumps so that the consolidation could take place that would preclude further settlement. f Discuss the preload effect on clay soils lying above the wter table I! (7 feet +) that were possibly compacted dry of optimum. It would appear only li=ited consolidation from the preload could take place in this situation and the potential for further sectiement would exist. Discuss the effect of the preload on clays placed wet of optinum. It vould appear consolidation along with a gain in strength would take place. Determine if the new soil strength is adequate for bearing capacity. o' exi .in fil an c ' Cor lu ion- ce he elia li ,act' n ir or=a ion i .er- in S[d
'a tic .a1 b in a te .s de . e id r tio ran ar E8Ifb o' s) ela iv der ty =ais r con nt dens ry, co olid cion rcp ti Cavere, a s* en .h ori a est v uld ppe to e si ble n or er t (,/30
.at' fa or y sve the be e q sti ..s . or' gs ho be onti ou push 4-e/gc tte.
v' .di ur dc esi- s 1 np1 ta n. , (4) Miscellaneous. A contour nep, showing the settlement configuration of the Diesel Generator Building, furnished by the applicant at the meeting of 27 and 28 Febr.uary 1980 indicates that the b.3c of the building has varped due to differential settlements. Additional strei-Les will be induced in the various components of the structure. The applictet should evalua.e these stresses due to the differential settlement and furr.ish the computations and results for review. 4
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, NCZED-T .
. SUBJEC"' Interagency Agreemene Ne NRC-03-79-167, Task. No.1 - Midland Plant Units. I and 2, Subtask do.1 - Letter Report N. / Service Water Building Foundation. ,
(1) ' Bearing Capacity. A detailed pile design based upon pertinent soil data should be developed in order to more effectively evaluate the proposed pile support system prior to load testing of rest' piles. Provide adopted soil properties, reference .tof test data, on which they are based, and
' method and assumptiona*used to est'igte pile design capacity including computations. Prc, vide estimated /:iaximum static and dynamic loads to be imposed and individual contribdtion' (DL, LL, OBE, SSE) on the maximum loaded pile. Provide factor of safet ' /against soil failure due to maxi =um pile load.
(2) Settlements. (a) Discuss and provide analysis evaluating possible differential settle =ent that could occur betuyen the pile supported end and the portion placed on filland glasIa.l illl.,I' :Deseesbe the om oe eslef Featur es (e.g Ji:pec.t af fai/uresetehind/velod e,. st (b) _:= 31scuss4my why Nr#Yaining e wall adjacent to the intake structure is not required to be" Seismic Category I structure. Evaluate the observed settlement of *both the service unter pumphouse retaining walls and the intake structure retaining wall and the significance of the settlement including future settlement prediction on the safe operation of the Midland
' Nuclest Plant. This ev4/*Afion .chould old+ers <<teef jfrerser indueed b y if e se t?/en ee r assin tf a Hows.b/e .strerre.r permit' fed by yproved codes.
(3) Seismic Analysis. Provided the proposed 100 ton ultimate pile load capacities are achieved and reasonable margin of safety is available, the vertical pile support proposed for the overhang section of the Service Water Pucp Structure util provide the support necessary for the structure under combined static and seismic inertial loadings even if the soil under the overhang portion of the structure should lieuefy. There is no reason to think this won't be achieved at this time, and the applicant has coenitted to a load test to de=enstrate the pile capacity. The.dynanic response of the structure, including the inertial loads for which the structure itself is designed and the mechanical equipment contained therein, would change as a result of the introduction of the piles. Therefore: (a) Please summarize or provide copies of reports on the dynamic analysis of the structure in its old and proposed configuration. For the latter, provide detailed information on the stiffnes= assigned to the piles
- s. d the way in which the stiffnesses were ~obtained and show the largest change -
in interior floor vertical response spectra resulting from the proposed modification. If the proposed configuration has not yet been analyzed, describe the analyses that are to be perforned giving particular attention to the basis for cciculation or ~ selection, of and the range of numerical stiffness values assigned to the vertical piles. (b) Provide af ter co=pletion of the new pile foundation, in i accordance with commitment No. 6, item 125, Consumers Poser Company memorandu. l 1 (*E
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- ' . SCIID-T l SUBJECTS Intsragency Agreement No. NRC-03-79-167, Tcsk,No.1 - Midland Plant l I
Units 1 and 2, Subtask No. 1 - Letter Report . dated 13 March 1980, the results of =casure=ents of vertical applied load 4 absolute pile heat vertical defor=ation which will be made when the strue oral load is jacked on the piles so that the pile stiffness can be dece:sined and compared to that used in the dynamic analysis. N. / Auxiliary Building Electrical Penetration Areas and Teeduater Isolation Valve Pits. : rI! (1) Se ttlement. Provide' the assumptions, method, co=putation and estimate of expected allowable la'teral and vertical deflections under static j and seismic loadings. ' i. , , ll ! (2) Provide the drulcl tion plans, and specifications for
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underpinning operations beneath! he Electrical Pene'. ration Area and Feedsater Valve Pit. The requested infor- tion te be submitted should cover the following in sufficient details' for 'evaluation: ' ibe tem.ponry (a) Details ofA desatering syste (locations, depth, size and capacity of wells) including the monitoring program to be r'equired, (for exanple,
=easuring draudown, flow, frequency of observations, etc.) to evahate the perfor=ance and adequacy of the installed system. '. m h
(b) Location, sectional views and dimensions of access shaf t and drift to and below auxilisry building wings. , (c) Details of te porary surface support syste: for the valve pits.
'MP Devatering before underpinning is reco=nended in order d preclude differential settlement between pil.e and soil supported ele =ents and negative drag forces.
() Provide adopted soil properties cethod and assu=ptions used to esti= ate caisson and/or pile design capacities, and computational results. Provide esti=ated =aximum static and dynamic 1.oad (compression, uplif t and lateral) to be imposed and the individual cintribution (DL, LL, OBE, SSE) on
=aximum loaded caisson and/or pile. Provide factor of safety against soil f ailure due to =aximum pile load.
e (t) Discuss and furnish computations for settlement of the portion of the Auxiliary Building (valve pits, and electrical penetration area) in respect to changed water level as a result of the site devatering. Include the effect of bouyancy, which was used in previous calculations, and fluctuations ia water table which could happen, if devatering system becomes inoperable. () Discuss protection :easures to be required against corrosion, if piling is seier,ted. 6
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NCEED-T , 7 JUL SG
SUBJECT:
Interagency Agrocment No. NRC-03-79-167 Task No.1 - liidland Plant Units 1 and 2, Subtask No.1 - Letter Report a (f) Identify specific information, data and method of presentatio be submitted for regulatory review at completion of underpinning operation. This report should summarize construction activities, field inspection ; records, results of field load tests on caissons and piles,and an evaluation of the completed fix for assuring the stable foundatior. t
,[ Borated Water Tanks.
(1) Settlement. Storage Tanks furnished byThe the 7ettlement a'pplicant inestimate responsefortothe Borated NRC Water Question 31 (10 CTR 50.54f) is based upon the j,results of two plate load tests. conducted at the foundation elevation (EL 627.0Ci) of the ta'nks. Since a plate load test is not effective in providing infor=]ation reW ai; the soil beyond a dep than twice the diameter of the be'aring plate used in the test, the estie-:te of the settle =ent furnished by the'fpplicant. does not include the contribution of the soft clay layers located at depth more than 5' below the bottom of the I .anks (see Boring No. T-14 and T-15, and T-22 thru T-26). l (a) Coc:pute settlements which include contribution of all the soil layers influenced by the total load on the tanks. Discuss and provide for - i review the analysis evaluating diffecential settlement that could occur between the ring (foundations) ano the center of the tanks. (b) The bottes of the borated tanks being flexible could varp under differential settle =ent. Evaluate what additional stresses could be induced in and the ring bea=s, compare tank valls, s-ith allovable and tank botte=s, becaus- of the sett*,eoent, stresses. Furnish the computatious on stresses including method, assu=ptions and adopted soil , properties in the analysis. (2) Bearing Capacity. Laboratory te'st results on sample.s fron boring I-15 show a sof t stratus of soil below the tank bottom. Consideration has not > been given to usLng these test results to evaluate bearing capacity infor=ation furnished by the applicant in response to NRC Question 35 (10 CFR 50.54f). Provide bearing capacity c~omputations based on the test results of the samples from relevant borings. This infor=ation should include method used, foundation design assu=ptions, adopted soil properties, ultimate bearing loads. capacity and resulting factor of safety for the static and the seismic p/- 7
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Underground Diesel Tuel Tank Foundation Design (1) Bearing capaci;y. Provide bearing capacity computation based on the test results of sa=ples iros relevent borings, including method used, foundation design assu=ptions, adopted soil properties, ultimate bearing capacity and the resulting factor of safety. 4 (2) Provide tank sectie=ent analysis due to static and dynamic loads including methods, assumptions made, etc. 7 P W-W % @ .A m eigur.,gra m _ g :1w t.w m_ m w m m_ _ , _.
NCrro-i- 7 JUL 5'O SU3JrCT: Interagency Agreement No. NRC-03-79-167 Task 'No.1 - Midland 71 ant Units 1 and 2, Subtask No.1 - Letter Report I 1 (3) What will be effects of uplif t pressure on the stability of the 1 tanks and the associated piping system if the devatering systes becomes inoperable? M, Underground Utilities: ; (1) Settlenent ! s' (a) Inspect the interior of water circulation piping with video careras and sensing devices to/ show pipe cross section, possible areas of < crackings and openings, and slopes of piping following consolidation of the plant fill beneath the inposed hurcharge loading. (b) The applicant hass-sltated l '
'in 'his response to NRC Question 7 (10 CTR 50.54f) that if the duct banks re=ain intact -af ter the preload program has been completed, they will be ablk to vitlistand all future operating loads.
Provide the results of the observations cade, during the preload test, to deternine the stability of the duct banks, rich your discussion regarding their reliability to perform their design functions. (c) The response to Question 17 of " Responses to NRC Requests Regarding Plant Fill" states that "there is no reason to believe that the stresses in Seismic Category I piping systens vill ever approach the Code allowable." We question the above statement based on the following: Profile 26" - OH3C-54 on Fig.19-1 shows a sudden drop of approx. 0.2 feet within a distance of only 20 feet. Using the procedure on p.17-2, ( b - ECe) - E C D2R) " E C D ) ( 85 )_ 2 32 p = 30000 ( 26 ) [ 8(0.2)(12) ] = 130.0 KSI 2 (20x12)* cc,y a,// u ,f,/,
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m:p cd x.C _c;: 4weeeee. Yet, Table ~17-2' lists only 52.5 KSI7 stress for this pipe. This netter requires further review. Please respond to this apparent discrepancy and also specify the location of each co:sputed settlement stress at the pipeline stationing shown on the profiles. More than cee critical stress location is possible along the sane pipeline.
(d) During the site visit on 19 February 1980, we observed three instances of Category I piping what appeared t6 be degradation of rattlespace at penetrations of through concrete valls as follows: i 8
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, NCEED-T SUBJECT Ittoregency Agrcenent N2. NRC-03-79-167, Tack NJ. 1 - Midland Picat Units 1 and 2, Subtask No.1 - Letter Report Vest Borated Vater Tank - in the valve pit attached to the base of the structure, a large dianeter steci pipe extended through a steel sleeve placed in the wall.
Because the sleeve was not cut flush with the udi, eletrance between the sleeve and the pipe was vet; scall. , ./ ;
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Service Water Structure - Two of the service seter pipes penetrating the northwest vall of the service water strycture had settled differentially vich respect /to the structure and were resting on slightly squashed /short pieces of 2 x 4 placed in the botten of
~ the penetration. From the inclination of the pipe,
' there is'a suggestion that the portions of the pipe further back in the vall opening (which was not
, visible) were actually bearing on the invert of the opening. The botton surface of one of the steel pipes had small surface irregularities arce.ed the edges of the area in contact with the 2 x 4 Whether these irregularities are nor=al nanufacturing irregularities or the result of concentration of load on thf.s temporary support caused 'by the settlenent of the fill, was not known.
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These instances are sufficient to warrant an, examination of those penetrations where Categery I pipe derives support from plant fill on one or both sides of a penetration. In view of the above facts, the following information is required. 5
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(1) What is the mininun seismic rattlesp' ce a required between a Category I pipe and the sleeve through which it penetrates a vall? (2) Identify all those locations where a Category I pipe deriving support fron plant fill penetrates an exterior concrete vall. Determine and report the vertical and horizontal rattlespace presently available and the r.ininun required at each location and describe resedial actions planned as a result of conditions uncovered in the inspection. It is anticipated that the answer to Question (1) can be obtained without any'significant additional e.xcavation. If this is not the case, the decision regarding the necessity to obtain information at those locations requiring major excavation should be deferred until the data frem the other locations have been examined. 9
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[. NCEED-T SUE.TECT ! Intoreg:ncy Agrocoent Ns. NRC-03-79-167, - Units I and 2 Subtask No.1 - Letter ReportTask 'No.1 - Midland Plant ) (e) cradle placed beneath safety related piping, conduits, and s s tructures. the properties of all supporting raterials to be adopted in the pipe stresses caused by settlement. ', ' (f) v I The two reinforced concrete returu pipes ubich exit the Service Water Pump Structure, run along' pith'e'r side of the emergency cooling water reservoir, shu tdown. and ulti=ately enteg into the reservoir, are necessary for safe These pipes are buried within or near the crest , slopes that forn the sides of i:he ~ emergency! cooling water reservoir.of Category I no report There is on, or analyrts of, /the,' seismic s'tability of post earthquake residual di'splacement for these,s do not raise the specter of any ,j popes. While the li=ited data from this area problem,. for an important elecuent of the plant such as this, methods. the earthquake Therefore, stajility should be examined by state-of-the-art i 1eading to an est1= ate of the per=anent defor=ation of the pipes. provl Please provido the following: !
; (1) a plan showing the pipe location with respect to l l
other nearby structures, slopes of the reservoir and the coordinate system;
* (2) cross-sections shosing the pipes, normal pool levels, slopes, subsurface l conditions as interpreted from borings and/or. logs of excavations at (a) a t l location parallel to and about 50 ft from the southeast outside vall of the ' .ervice both include vaterdischarge pipe structure and (b) a location where the cross section vill structures.
Actual boring logs shoMd be shown on the profiles; their offset from the profile noted, and soils should be described using the Unified Soil Classification Systen; ! (3) discussion of available l shear strength data and choice of strengths used in stability analysis; (4) deter =inatics. of static factor or safety, critical earthquake acceleration , and location of critical circle; (5) calculat' ion of residual novenent by the method presented by Nevrark (1965) or Makdisijand Seed (1978); and (6) a deter Covement =ination
- s. of whether or not the pipes can ' function properly af ter such i
- h. Cooling Pond. --
i (1 ) Emergency Cooling Pond. In recognition that the type of embankment fill and the compaction control used to construct the retention dikes for the cooling pond were the same as for the problem plant fill, we request reasonable assurance that the slopes of the Category I, Emergency Cooling Fund (baf fle dike and main dike) are stable under both static and dena=ic loadings. We request a revised stability analysis for re"f ew, which will include identification of locations analyzed, adopted foundation and adopted soil properties, meth'od of stability analysis used an factor of safety with identification of sliding surfaces analyzed. Please address any potential inpact on Category 1 pipes near the slopes, based on the results of this stability study. Reccusendatices for location of new exploration and testing have been provided in a separate letter. 10 l 9 ^ a _
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, Ncggp.T SU3 JECT: Icccrcgancy Agrecuent N . NRC-03-79-167, Task Ns. 1 - Midlcnd Plcut Units . and 2, Subtask No.1 - Letter Report (2) Operating Cooling Pond. A high level of safety should be required ~nr the remaining slopes of the Operating Cooling Pond unless it can be assurt' that a failure vill not: (a) endanger public health and properties, (b) result in an assault on environment, (c) impair needed energency access. Recommendations for locations of new borings and laboratory l
' tests have been submitted in a separate ' letter. These recommendations were made on the assumptions that the stability of the opera"ing cooling pond dikes should be demonstrated. '/ Y. Site Devatering Adequa .[, 1, . (1) In order to provid liquefaction, it is necessary t'o./che that denonstrate' necessary the water vill assurance not rise of safety above elevation 610 during nor:all pperations or during a shutdown process. The applicant has decided to acco=plish this by pu= ping from wells at the
. site. In the event of a f ailure," partial failure,*or degradation of the devatering system (and its backup systes) caused by the earthquake or any
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other event such as equipment breakdown, the water levels vill begin to rise. f Depending on the answer to Question (a) below concerning the nor=al operating
" water levels in the i=cediate vicinity of Category I structures and pipelines fcunded on plant fill, dif ferent a=ounts of time are available to accecplish repair or shutdown. In response to Question 24 (10 CTR 50.54f) the applicant states "the operating groundwater level vill be approxicately el 595 f t" (page 24-1). On page 24-1 the applicant also states "Therefore el 610' is to be used in the designs of the devatering system as the maxi =um pernissible groundwater level elevation under SSE conditions." On page 24-15 it is stated that "The wells will fully penetrate the backfill sands and underlying natural sands in this area." The botten of the natural sands is indicated to vary f rom elevation 605 to 580 within the plant fill, area according to Figure 24-12. The applicant should discuss and furnish response to the following questions: ,
(a) Is the nor=al operating devaterin'g plan to (1) pu=p such that the water level in the wells being pumped is held at or below elevation 595 or (2) to pu=p as necessary to hold the water levelf in all observation wells near Category I Structures and Category I Pipelines supported ou plant fill at or below elevation 595, (3) to pu=p as necessary to hold water levels in the wells centi'oned in (2) above at or below elevation 610, or (4) something else? If it is something else, what is it? (b) In the event the water levels in observation wells near Category I Structures or Pipelines supported on plant fill exceed those for normal operating conditions as defined by your answear to ' Question (a) what action vill be taken? In the event .that the vater level in any of these observation wells exceeds elevation 610, what action vill be taken? 11
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j .. .TCI;D-T SC?Z cts Intcrcstney Agrecment No. NRC-03-79-167, Tack Na.1 - Midland Plant Units I ctd 2 Subtesk Na.1 - Lotter R: port (c) Uhere vill the observation wells in the plant fill area be located that will be monitored during the plant lifetine? At what depths vill I the screened intervals be? Vill the combination of (1) screened interval in cohesionless soil and (2) deconstration of timely response to changes in cooling pond level prior to drawdown be cade a condition for selecting the cbservation wells? Under what conditions vill the alarm mentioned on page 24-20 be triggered? What vill be the response to the alarm? A worst case test cf the completed permanent devatering' and groundwater level acnitoring systens cculd be conducted to determine whether/ or not the cine required to accomplish shutdown and cooling is available.//This could be done by shutting off the en: ire devatering system when the' cooling pond is at e.levation 627 and decernining the water level versusl time curve for each observation well. The test should be continued until the'lvater level under Category I structure, whose foundations are potentially/ liquefiable', reaches elevation 610 (the nor:21 water level) or the sus of, jthe time . intervals allotted for repair and the ti=e interval needed to accomphsh shut'down (should the repair prove unsuccessful) has been exceeded, 0bichever occurs first. In view of the interogeneity of the fill, the likhly varia' tion of its permeability and the necessity of caking several assumptions in the analysis which was presented in the applicant's response to Question 24a_, a full-scale test should give more reliable infor=ation on the available time. In view of the above the applicant should furnish' his response to the fol' lowing: If a devatering systed failure or degradation occurs, in order to assure that the plant is shutdown by the time water level reaches elevation 518.,, it is necessary to initiate shutdown earlier. In the event of a failure sf the dewatering systen, what is the water level or condition at which shutdown will be initiated? Eov is that condition determined? An acceptable
- ethod would be a full-scale worst-case test perfor=ed by shutting off the entire dewatering system with the cooling pond at elevation 627 to determine; at each Category I Structure deriving support from plant fill, the water level at which a sufficient time vindow still re=ains to acco=plish shutdown before the water rises to elevation 610. In establish'ing the groundwater level or condition that will trigger shutdown, it is necessary to account for nor=al surface water inflow as well as groundwater recharge and to assume that any additional action taken to repair the dewatering'systes, beyond the point in ti=e when the trigger condition is first reached, is unsuccessful.
(2) As per applicant response to NRC Question 24 (10 CFR 50.54f) the design of the permanent dewatering system is based upon two =ajor findings: (1) the granular backfill materials are in hydraulic connection with an underlying discontinuous body of natural sand, and (2) seepage from the cooling pond is restricted to the intake and pu p structure area, since the plant fill south of Diesel Generator 3uilding is an effective barrier to the inflow of the cooling pond water. However, soil profiles (Figure 24-2 in the
*Rasponse to NRC Requests Regarding Pis=t Fill"), pu= ping test time-drawdown graphs (Figure 24-14), and plotted cones of influence (Tigure 24-15) indicate that south of Diesel Generator Building, the plant fill =aterial adjicent to 12
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SUBJECT:
Intortstney Agreenent No. NRt.-03-79-167, Task No.1 - Midland Plant 1- Units I and 2, Subtash No.1 - Letter Report l l the cooling pond is not an effective barrier to inflow of cooling pond water. l The esti=ated permeability for the fill material as reporte
- by the applicant is 8 feet / day and the transmissivities range from 29 to 102 'uare feet / day.
Evaluate and furnish for review the recharge rate of seepage 1 trough the fill
=aterials from the south side of the IDiesel Generator Building on the per=anent dewatering systes. Thisieviluation should especially consider the recovery data Dom PD-3 and comp 1'e'te' hata from PD-5.
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(3) The .'nts reeptor wells have been positioned along the northern side of the Water Meke Structu're and sarvice water pump structuras. The l-calculations esticating che toi:aligroundust'er inflow indicate 'the structures serve as a positive cutoff. However, the Isopachs of the sand (Figures 24-9 and 24-10) indicate 5 to 10 feet of rer.aining natural sands below these structures. The soil profile (F 'gure 2,4'-2) neither agrees nor disagrees eith i the isopachs. The calculations or total flow, which assu=ed positive cutoff,
; reduced the length of the line source of inflow by 2/3. The calculations for the spacing and positioning of ve11s assumed this reduced total flow is applied along the entire length of the structures. Clarify the existence of seepage below the structures, present supporting data and calculations, and reposition wells accordingly. Include the supporting data such as drawdown at the interceptor wells, at midway location betwees any two consecutive wells, and the increase in the water elevations downstress of the interceptor wells.
The presence of structures near the cooling pond appears to have created a situation of artesian flow through the sand layer. Jiscuss why artesian flow was not considered in the design of the devatering syste=. (4) Provide construction plans and specific.ation cf per anent devatering system (location, depths, sire and capacity of ve11s, filterpack design) including required ronitoring program. The infor=ation furnished '.n response of NRC Question 24 (10 CFR 50.54f) is not adequate to evaluate the adequacy of the system. , (5) Discuss the ranifications of plugging or leaving open the weep holes in the retaining vall at the Service Water Building. (6) Discuss la detail the saintenance plan.for the deuatering system. (7) What are your plans for monitoring water table in the control tower area of the Auxiliary Building? (8) What neasures vill be required to prevent incrustation of the pipings of the dewatering syste=. Identify the controls to be required during plant operation (neasure of dissolved solids, che=ical controls). Provide basis for established criteria in view of the results shown on Table 1, page 23 of tab 147. 13
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,! t (9) Upsn racching a stordy secte in d:wataring, a groundwatar surv y should be made to confirm the position of the wats; tablo end to insure that no perched water' tables exist. .
Dewatering of the site should be scheduled with a sufficiet.t lead time before plant start up so that the additional settlement end its effects Secclement sheuld be closely monitored (especially on piping) can be studied. during this period. y f'ry ge your pla ns fan condfsting this youndNo str&*vey , y[ J. Liquefaction Potential. ,/ q ' {If
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l An independent Seed-Idriss , Simp.lified Analysis was performed for the fill area under the assu=ption th,at; the groundwater table was at or below elevation 610. For 0.19 2 peak fr'o'u nd surface acceeleration, it was found that blow counts as fo11cus wereir'eiguired for',a factor of safety of 1.5: Elevation Y ft ] Minidum'SPT For 7.5. = 1.5 Blow Count *1 610 14 l 605 ,, 16 11 7
' 600 595 - '19 The analysis was considered conservative for the foll'owing reasons (a) no account was taken of the weight of any structure, (b) liquefaction criteria f or a ragnitude 6 earthquake were used whereas an NRC memorandum of 17 Mar 30 considered nothing larger than 5.5 for an earthquake with the peak acceleration level of 0.19 g's, (c) unit weights were varied over a range broad enough to cover any uncertainty and the tabulation above is based on the most conservative set of assu=ptions. Out of over 250 standard penetration tests on cohesionless plant fill or natural foundation material below elevation 610, the criteria given above are not satisfied in four tests in natural caterials located below the plant fill'and in 23 rests located in the plant fill. These tests involve the following 'Sorings:
S'43, S'42, DG-18, AX 13, AX 4, AX 15, AX 7, AX 5, AX 11, DG 19, DG 13, DG 7, DG 5, D 21, GT 1, 2.' So: e of the tests on natural :sterial were conducted,at depths of at lessPrior than 10 f t before approximately 35 f e of fill was placed over the location. to cocparison vich the criteria these tests should be multiplied by a f actor of about 2.3 to acccunt for the increase in effective overburden pressure that results from the placement and future devatering of the fill.
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' 5 ," SU3 JECT: IntGrogancy Agracmert N3. NRC-03-79-167, Tczk Ns. 1 - Midicnd riant Units 1 cod 2, Subteck Na.1 - Lsttor Raport of the 23 tests.on plant fill which fail to satisfy the criteria, aost are near or under structures where recedial measures alleviating necr.ssity for support from the fill are planned. Only 4 of the testa are under the Diesel Generator Building (which vill still derive its support frou the fill) and 3 others are near it. Because these locations where low bleu counts were recorded are well separated from one'/ancther and are not one continuous stratus but are localized pockets yf/)oose material, no failure mechanism is present. ,/ //
In view of the large number of borings in the plant fill area and the conservatism adopted in analysid,0!these few isolated pockets are no threat to plant safety. The fill area 1's/ sdfe agains't liquefaction in a' Magnitude 6.0 earthquake 'or smaller which produces a, peak ground surface acceleration ofor I 3
' O.19 g or less provided the groun'dvate'r elevation f n the fill is kept at below elevation 610. l .
ef-8, Seismic analysis of structures on plant fill material. 2 (1) Category I Structures. From Sectica 3.7.2.4 of the FSAR it can be calculated that an average. V, of about 1350 f t/sec was used in the original dynamic soil structure interaction analysis of the Category I s t ruct ure s. This is confir:ed by one of the vievgraphs used in the 28 IWvsry Bechtel presentation. Plant fill V, is clearly much lower than this value. It is understood from the response to Question 13 (10 CyR 50.54f) coteerning plant fill that the analysis of several Category I structures are underway using a 3ower bound average V, = 500 f t/sec for sections supported on plant fill and that floor response spectra and design forces vill be taken as the cost severe of those from the new and old analysis. The questions which follow are intended to make certain if this is the case and gain an understanding of the i= pact of f.his paracietric variation in foundation conditions. l Acca (a) Discuss which Category I struc'tures havegand/or will be reanalyzed for changes in seismic soil structure interaction due to the Have change acy in plant fill stiffness from that envisioned in the original design. i Category I structures deriving support from plant' fill been excluded fron l reanalysis? On what basis? , I (b) Tabulate for each old analysis and each reanalysis, the foundation parameters (v,,9 and P ) used and the equivalent spring and danping constants derived therefrom so the reviewer can gain an appreciation of the extent of parametric variation performed. , (c) Is it the intent to analyze the adequacy of the structures and their contents based upon the envelope of the resalts of the old and new analyses? For each structure analyzed, please 'show on the same plot the old, new, and revised enveloping floor response spectra so the effect of the 15 l l Swa r_ _; -- -- -
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, SU2 JECT: IntGregency Agreenent No. NRC-03-79-167, Tack Na. 1 - Midlcnd Plant
/ Units 1 and 2, Subtask No. 1 - Letter Report changed backfill on interior response spectra predicted by the varicus =odels can be readily seen.
(2) Category I retaining vall near the southeast corner cf the Service Water Structure. This vall 1,s experiencing sone di'fferential settlenent. Boring inforr.ation in Figure 24-2 (Qu:.stinn 24, Volune 1 Responses to NRC Requests Regarding P , Jant yill) suggests the wall is founded on natural soils and backfilled.!v' i th plant fill on the land side. Please furnish details clarifying thi fdllowing: l !I., ! (a) Is there any plant ifill underneath the wall? What additional l data beyond, that shown in Figuref.24-2 suppo'r t your answer? , l. (b) Have or should the"ldel sign i se'snic loads (FSAR Figure 2.5-45) be i changed as a result of the change'd backfill conditions? i
! l' (c) Have or should dynasic water loadings in the reservoir be considered in the seis=ic design 'of this vall? Please explain the basis of your answer. ,
- 5. In your response for the co=nents and questions in paragraph 4 above, if you feel that sufficiently detailed information already exists on the Midland docke t that may havs been overlooked, please =ake 'raference to that infor=ation. Rasolution of issues and concerns _ vill depend on the expeditious receipt of data centioned above. Contact Mr. Neal Cehring at FTS 226-6793 regarding questions. :
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P. McCALLISTER Chief, Engineering Division k 4 4 16
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M g twk to.y g .f -) Midland Units 1 & 2 Job 7220-001 TR112 REPORT DATES: January 30 to March 24, 1978 LOCATION: Midland Units 1 & 2 Midland, Michigan <
SUBJECT:
Piezameter and Settlement Marker Installation ATTENDEE: W. R. Kinzer - Geotech/Geologv During February and March, concurrent with several other related drilling programs, the design cooling pond dike piezeteters and settle =ent markers j were installed under my inspection at the Midland Power Plant. The work ' was perfor=ed in accordance with technical specification C-77 and technical drawing C-69, and issued for construction as an amend =ent to subcontract 7220-FSC-318. A total of 20 piezometers and 24 settlement markers were completed during this phase of the field work. Ten piezomet+rs each were installed along two separate dike sections designated ti and P2 (stations 25 + 48 and 12 + 13) respectively. Three pneu=atic type and 7 casagrande type piezameters were installed along section P1 at elevations between 565 and 607.2 feet. Two pneumatic and 8 casagrande piezometers were installed along dike section P2 at elevations between 568.0 and 609.1 feet. All pieroce.ters were Installed as close to the specification design as possible. As-built drawings as well as boring logs, daily reports, and other miscellaneous data were transmitted to S. S. Afifi as they became available. Fluid levels in 17 of the installed piezometers were obtained on March 20, 1978, the remaining 3 were read on March 24, 1978. On site personnel were instructed in the operation of the test equipeant on March 24, 1978 and all test gear was turned over to Consu=ers Power Company at that time. Installation of the settlement markers was begun on 'farch 13, 1978 with all 24 markers completed by March 22, 1978. All were installed 12 to 13 ' feet from the dike reference line and were all bottomed 15 feet below the existing dike crest. Rust resistant paint was substituted for use on the exposed tips of the installed steel bar stock as "Galvanox" was unavailable locally. On site surveying was informed of the completion of , the settlement markers and instructed to begin the first elevation survey ! as soon as possible. The first elevations are expected to be available by March 31, 1978. ' l i,.
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ayne R. Kinzer WRK/ lag 34500r.64
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