ML20002B133
| ML20002B133 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/22/1980 |
| From: | Cooke T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OM, NUDOCS 8012090494 | |
| Download: ML20002B133 (64) | |
Text
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1 i NUCLEAR REGULATCRY COMMISSICN 2
3 ---------
x 4 :
5 In the matter of: Docket No s . 50-329-0?
6 : 50-330-03 7 CONSUMERS POW ER COMP ANY :
8 - - - - - - - - - - - - - - - -x 9
to Nuclear Seculatory Commission 11 Midland Service Center 12 1100 South Washington Street 13 Midland, nichigan l
14 15 Wednesday, October 22, 1980 I
i 16 l'
17 Deposition of THCMAS CHARLES CC0KE, a witness 18 herein, called for examination by Counsel for the Nuclear 19 Regulatory Commission in tne above-entitled matter, pursuant 20 to notice, the witness being duly sworn by Ya rilyn Shockey, 21 at the N uclea r Regulatory Commission , Midland Service
=
r 22 Center, 1100 Touth Washington Street, Midland, Michigan, t
23 commencina at 2:00 o' clock p.m., Wednesday, October 22, 4
24 1980, and the proceedings being taken down by stenomark by s
. 25 Marilyn Shockey and transcribed under her direction.
_s t' g>Q$fd b I i
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ALCEPSCN AEPoATING COMP ANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
2
' 1 APPEARANCES:
2 Cn behalf of the Nuclear Regulatory Co mmission :
3 WILLIAM PATON, Esq.
3RADLEY JONES, Esq.
4 Vuclear Regulatory Co mmission
.- Maryland National Bank Building 5 ?ethesda, Maryland 6
, On behalf of Consumers Power Company: -
T i
RONALD G. ZAMARIN, Esq.
8 ALAN FARNELL, Esq..
3 Isham, Lincol'n C Seale .
9 One First Na tional Pla ra Chicago, Illinois 60603 JAMES.BRUNNER,.Esq.
11 Consumers Power Company 212 West " 11gan 12 Jackson, .ic
- 1gan 49201 13 ALSO PRESENT.
14 3AYMOND SUTPHIN, NRC Inspection and ?n fo rcement s Region III l
3ILL MAINES, 16 WMPX
! 17 D ARL HOOD ,
NBC, Division of Licensing, 18 Bethesda, Maryland
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19 SHARON WARREN, Intervenor i
k 20 BARSARA STAMIRIS, Inrervenor 21 22 1
23 l
( 24 25 9
4 l
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTCN,0 C. 20024 (202) 554 2345
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1
.f 1 C O N T'E N T S t
2 WITNESS PAGE
, e . THOMAS CHARLES COOKE. 3 4
! 5 .
6 EXEIBITS
, NUMBER- MARKED RECEIVED 1 8 No. 1 13 i 9 No. 2 39
-j 10 No. 3 55
- j. . 11 12 I
13 ,
i 14 15 i
16 17 18 i
.; 19 I (-
20 21 22 23
. 24 s
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ALDERSON AEPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, O.C. 200:4 (2C2) 554 2345
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1 3
e- 1 Whereupon, 2 THOMAS CHARLES COOKE 3 the depon)nt herein, called for examination by Counsel for 4 the Nuclear-Regulatory Commission, having been duly sworn by 5 the Court Report, was examined, and testified as follows:
6 EXAMINATION SY COUNSEL FOR THE NUCLEAR REGULATORY COMMISSION 7 P ? O C_E E D I NG S 8
9 BY MR. JONES :
10 C '4ould you~ state your name and add ress for the 11 record, please?
12 A My name is Charles Ccoke.
13 I live at 1969 Ea st Stewart Road, Midland, i
14 Michigan.
15 0 Is that your home address?
16 A Yes.
17 C Would you give a summary of your formal education 18 since graduation f rom high school?
19 A I graduated in 1957 from Ohio University with a T 20 Bachelor of Science in Civil Fngineering .
21 Since then I hava had various training courses. I s
22 attended the Fncineer Officer Basic Course in Ft. Selvoir, 23 Virginia. I have been to Hobart '4 eld in g Inspection Course s 24 in Trcy, Chio. I have had courses in the CPY Seminar.
25 C Excuse me. What is that?
2 s
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. Q.C. 20024 (202) 554 2345
4 I
/" 1 A Critical Path Method Seminar.
2 I have taken a course in fall-out shelter 3 analysis. I have taken the Nuclear Steam Design Supply
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4 lecture series. I have done a home study course on public
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5 utility reports, and I have taken various utility-sponsored 6 management courses.-
7 0 When you said ycu have a B.A. in civil engineering 8 --
9 MR. ZAMARINs 3 .5. in civil engineering.
10 SY MS. JONES: (Resuming) .
11 C Is that the same field as structural engineering?
12 A Structural engineer is part of civil engineering.
13 Q Did you take any courses with respect to the
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< 14 geotechnical area ?
1 15 A I had a soils ccurse.
16 0 How aboct any courses with respect to mechanical 17 engineering ?
18 A I had some basic mech anical engineering courses.
19 0 When you graduated in 1953 --
20 A I graduated from college in 1957.
21- 0 From the University of Ohio. Where did ycu go te
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22 wo rk a t tha t time?
23 A I started work with Consumers Power Company.
24 0 Have you been with Consumers Power Company
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25 continuously since graduation from college? l l
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-l j ALCERSCN REPCRTING COMPANY. INC, 400 VikGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 & No. I have not.
2 .
Q Starting with that first period with Consumers
(
l f 3 Power Company, when did you leave the.e?
4 A I left them in about September of '57.
5 0 So was it from June of '57 until September of '57 6 you were with Consumers?
7 A August or September. Yes.
8 Q Where were you employed af ter Sep temtar of '57?
9 A I spent tuc yea rs with the U.S. Army Corps of 10 Engineers.
11 0 That was until September of '59? -
12 A Yes.
13 Q When you left the job with the Corps o f Engineers ,
14 who did you next work with?
15 A Consumers Power Company.
l 16 C Was that, again, approximately September of '59?
17 A Yes.
18 Q Has your employment been continuous with Consumers i
19 since that time?
r, t 20 A Yes.
i 21 C With respect to the two years in employment with 22 the Corps of' Engineers, what type of wo rk dicL you do with 23 that?
l 24 A I was an officer in the Corps o f Engineers. I was l 25 'a platoon- commander and a ssis ta nt operations officer.
i ALOERSoN REPCRTING COMPANY,INC, 400 VIAGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2345
6
, 1 0 With respect to your -- strike th at.
, 2 Did tha t job involve working in civil en gin ee ring 3 matters?
e 4 A Yes,.it did.
5 C What type of civil engineering projects were yo u 6 workinc on?
7 E We worked on roads. We worked on bridges, rifle 8 ranges.
9 C With respect to your work on read s and rifle 10 ranges and bridges, did you he re occasion to consider 11 geotechnical matters with respect to those projects?
12 A I guess I'm not sure I understand the question.
13 Would you maybe restate it?
14 C All right.
15 With respect to the job s on b ridg es and roads and 16 rifle ranges, did you deal with questions of soil prC7erties?
17 A Yes.
18 Q In what respect?
r 19 A With respect to Cbtaining compaction. ! was in i
20 construction at the time.
21 C When you say with respect to obtaining compaction, 22 does that mean you were responsible f or the method of i 23 compacting the soil?
24 A We were responsible f er getting the jcb done to
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25 meet wha tever specification we were working under.
ALCERSCN REPCRTING CCMPANY. ;NC.
400 VIRGINIA AVE., S.W WASHINGTON O.C. 20024 (202) 554 2345 t
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e 1 0 And that would include compactina it to whats?er 2 the specifica tion required?
3 A Yes.
f 4 C When you began work with Consumers Power Company 5 in Septembe r of '59 this is the second period with 6 Consumers. What was your job at that time?
7 A In September of '59 I started out o'n the graduate 8 student training program.
9 Q How long were you in that program ?
10 A Approxis ately five or six mon th s.
11 Q What specifically was that training designed to do?
12 A It was designed to familiarize me with the various 13 departments in the company. .
14 Q At the end of that five er six month period, what 15 job -- wha t was your job title with Consumers?
16 A Graduate Student in Training, I believe.
17 Q Af ter that was over, at the end of that period?
18 A A f ter that, I believe I was a Field Construction 19 Assistant / Gas.
k 20 0 What were your responsibilities in that job?
j 21 A In that job I was responsible for observing the 22 back fill of the pipe line. I.had some resconsibilities 23 with radiographic inspection.
s
?4 0 When you say observing the back fill of pipelines, 25 is that, again, assuring that the compaction meets the
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s l
At.0ER$oN REPCRTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTCN 0.C. 20024 (202) 554 2345
8 1 specification?
2 A- We were not so much concerned with compaction on 3 the pipeline. We were more concerned with other things.
4 0 Explain what you meant when you said you were 5 o bserving the back fill of th e pipeline.
. 6 A We were concerned with seeing that the back fill 7 did nat damage the coating on the pipe, tha t 'he t back fill 8 was completely around the pipe, that the back fill was 9 raised a certain amount of distance above the normal grade 10 there so that when it settled it would settle to a uniform 11 level.
12 Q How long did you hold that position in Consuners 13 P o w e r --- th a t Field Construction Assistant / Gas?
14 A Approximacely -- I think it was about eight er 15 nine mon ths.
16 Q If I'm adding the dates up right, sometime in the 17 fall of 1960.you changed your position?
18 A Yes. That is correct..
19 0 What position did you then have?
( 20 A I was then a Field Construction Assistant / Electric.
21 C Did that invclve the same type of responsibilities 22 ' vith respec t to electrical assistants as th at title had with 23 gas ?
24 4 There were different r e s po n sibili ties . =
s 25 U What were those responsibilities?
s ALCERSON REPORTING COMP ANY INC, 400 VIRGINIA AVE S.W, WASHINGTCN, D C. 20024 CO2) 554 2'45 I
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- 1 A I was at a 265 megawa tt fossil plant and my 2 responsibilities . were prima rily in the structural area.
3 Q What specifically were you doing with respect to 4 the structural area ?
5 A I was working with miscellaneous placforms.
. 6 C What was your responsibilities with respect to T miscellaneous pla tf orms ?
8 A Designing them and seeing that they got installed.
9 Q So you designed them and supervised th(
10 installa tion of them?
11 A Yes. Supervised the contractor who was installing 12 them.
13 0 For how long did you hold the position of Field 14 Construction Assistant / Electric?
15 A Until March of '61. .
16 0 '4h a t position did you then obtain?
17 A I was-then Field Construction Assistant / Electric 18 at another 260 megawatt fossil plant.
19 C Were the responsibilities similar a. the secCnd
.( 20 plant?
21 A What do you mean by similar?
22 0 Similar to the respcnsibilities tha t you had at 23 tha first fossil plant.
24 A I was following piping and not the structural work.
t 25 0 Was it, again, design and supervision of ALDERSON REPoRDNG CCMPANY 1NC.
400 V!RGINIA AVE.,3.W.. NASHINGTCN. D.C.20024 (202) $54 2345
90 i.
1 installa tion of the piping?
4 2 A It was limited designing. Primarily supervision 3 of installstion of the contractor who was installing th e i
4 piping.
5 Q How long did you hold that position?
. 6 A Until June of '62.
7 Q What job title did you then obtain?
8 A Field Construction Supervisor / Electric .
9 Q What facilities was that job title with respect to?
10 A That was with respect to the James H. Campbell 11 Plant.
12 0 Is that a fossil plan t?
a
, 13 A Yes.
14 0 What was the difference between your i
15 responsibilities at the Campbell plant as a Field 16 Construction Supervisor / Electric and the type of work you 17 did as a Field Construction Assistant / Electric?
y 18 A I got more involved in start-up activities.
19 Q Would you explain what you mean by more involved lk 20 with start-up activities?
21 A As compared to construction activities where you l 22 install pipe, start-up activities include checking out the
) 23 equips,ent and getting it runnin g f or the first time.
24 Q How long were you in that position?
s
- 25 A Until June of '63.
4 ALDERSoN AEPoRTING CCMPANY. INC, 400 VIRGlNIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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0 What position did you then obtain ?
2 A Field Construction Supervisor / Elect:.:c.
3 0 Different plant?
4 A At the Overisel Gas Compression Station.
5 0 Can you tell me very briefly what a gas
. 6 compression station is? ;
2
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7 A A gas compression station consists of units that 8 pump gas from one place to another.
9 0 Were you again responsible for checking out the 10 electric volt systems in preparation for start-up of th a t 11 facility 7 12 A I don't believe I was responsible for checking out 13 electrical systems. I was responsible f o r initial start-up 14 and check-out of systems ss opposed to being an electrical 15 specialist. I'm not an electrical .s;Icialict.
16 Q I am a little confused. What did the / Electric --
17 wha t did that -- that doesn't indicate that the 19 responsibilities were limited to electric matters ?
19 A As I recall, basically that meant what department
( 20 I was reporting to at the time.
21 0 You were checking other than electrical systems?
22 A At the Overisel Compression Station I was
, 23 responsible for installation of compressors, associated 1
24 mechanical and electrical aquipment.
25 Q Going back for just a moment to your job as Field s
Al.CERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
92 1 1 Construction Assistant / Gas -- I forget the exact term -- you 2 were observing th e back fill of pipelines. Did that work 3 include checking to see whether the pipes were installed at t
4 level or true?
5 A No.
. 6 Q How about with respect to your work as a Field 7 Cunstruction Assistant / Electrical? Around apbroximately i
! ' 8 March of '61, when you were working at the fossil plan t, it 9 had something to do with piping. Did that involve checking 10 to see whether the pipes were installed at level or true?
11 A No.
i 12 0 How long did you hold the position of Field 13 Construction Superintendent / Electric at the Overisel Gas i 14 Compression Station?
15 ,A I was Field Construction Supervisor / Electric until 16 June of '64 17 C What was your job title then?
18 A . Field Construction Supervisor / Electric.
19 Q With respect to what facility?
( 20 A Grand Rapids Heating Plant.
21 Q What were your responsibilities with respect to 22 that plant?
l 23 A Demolition and installa tion of boilers and i
24 associated mechanical and electris;sl equipment and start-up 1
25 of sa:ne. l l
l ALCE"4SCN REPCRTING COMPANY, WC, 400 VIRGINIA N.F , S.W., WASHINGTCN. D.C. 20024 (202) 554 2345 s
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T3 e 1 0 Did your work. with respect to the demolition and 2 instaliation of boilers involve any possible settlement of 3 the soils?
r 4 A- Not that I recall. No.
5 Q These boilers were installed inside an 6 already-constructed building?
7 A Yes.
8 0 Your responsibilities did not extend to any -- to 9 the design of the building itself in any way?
10 A I had no design responsibilities for the building.
11 Q How long did you hold that position?
12 A Until June of '65.
13 C What was your job title then?
14 A Field Construction Superv.;or/ Electric.
15 0 Where?
16 A At the James H. Campbell Plant.
17 MR. JONES: I'm going to mark this resume as NRC 18 -- I'm now looking a t a resume f.or Thomas Cooke which has 19 been marked NRC Deposition Exhibit 1 for identification,
\ 20 10/22/90.
21 (The document referred to was s
22 marked NRC Deposition Exhibit 23 No .1 for identification . )
t i 24 BY MR. JONES (R esuming )
25 0 With respect to your job, fron June 1965 to
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ALDERSoN REPORTING OoMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON. D.C. 20024 (202) 554-2345 1
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14 1 October 1965 as a Field Construction Supervisor / Electric --
2 let the record show I'm getting that information from-the 3 page marked Chronology in that exhibit. What were your 4 responsibilities with respect to that job?
5 A~ I had .'sponsibilities connected with 6 instrumentation, piping and start-up.
7 Q With respect to the piping, did any of your 8 responsibilities include checking to see whether the piping 9 was'. installed st level or true?
10 A None that I recall.
11 C Was that piping installed benesth -- strik e tha t .
12 Was that piping below ground, icvel?
13 A There was some pipe below ground.
14 0 With respect to that installa tion -- strike that.
15 Were you responsible for supervising the i 16 installa tion of that piping?
17 A I was responsible as owner's representative for 18 observing the contractor's activities in this regard.
19 C With respect -- what do you mean when you say A. 20 observina the contractor's activities?
21 A If you ask me if I am responsible for installation
.s 22 o f the piping and I were a foreman installing the piping, I I 23 would be responsible for verking for the contractor. \s the 24 owner's reprecentative we were no t direc tly responsible for 25 the installation. We are responsible for seeing that the l
ALDER $oN REPORTING COMPANY 1*.*0.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 2C 324 (202) 554-2345
95 1 contractor does it.
2 Q Does tha t responsibility include making sure th e
- 3 piping is installed correctly by the sub con tr acto r?
i 4 A On occasien, yes.
5 Q In making that f etermination of whether it is 6 installed correctly, do you consider soil settlement 7 problems -- possible soil settlement?
8 MR. ZAMARIN: Did he at that time?
9 BY MR. JONES: (Resuming) 10 0 With respect to this job we are referring to at 11 the Campbell Plant?
12 A I don't recall any soil settlemen t considerations 13 on that job that I was involved wi th .
14 0 In installing piping underground, would it --
does 15 your training extend to the proper way to install piping 16 below ground?
4 17 A Yes.
18 0 In installing piping underground, would you 19 normally consider the effects of soil settlement on that
\ 20 - p iping?
21 A I'm not sure I understand wha t you are driving at.
. s 22 C Let me give you a sc*nario and ask if that sort of 23 thing is considered.
. 24 If soil settlement would put certain pressures on 25 the ciping -- I've heard the phrase drag on the piping --
i i k ALDEftSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W. WASHINGTON. O.C. 20024 (202) 554 2345
96 1 f rom the settlement around it, are those sort of f actors 2 considered when deciding how to install piping?
3 MR. ZAMARIN4 Let me just object to the fCem of 4 the question. Are you talking about at the design stage or a
5 are you referencing when he was out there as the owner's 6 representative?
7 MR. JONES: I am talking with respect to his 8 expertise in the proper way of installing piping, which I
- 9 asked him if his training included the procar way to install 10 piping.
11 MR. ZAMARIN: My problem with the question is you 12 asked him whether that is a consideration with regard to 13 installing piping. I r ea lly want to know consideration by 14 whom and at what time. By a guy designing it or by a guy 15 preparing specs or by the guy watching it. That is the l 16 p ro blem tha t we have.
17 BY MR. JONES. (Resuming) 18 0 With respect to your expertise in the field of 19 installa tion of piping, in determining whether the piping
\ 20 was installed correctly, would you normally vant to know the 21 predicted settlement of soils around that piping ?
s 22 A If it was mentioned in the specification.
23 0 In October, 1965, you obtained the title of s 24 General Encineer. Is that right?
25 A Yes.
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ALOERSoN REPORT:NG CCMPANY,INC, 400 VIAGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
17 1 0 With what facility were you then wo rkin g ?
1 A The same f acili ty . I had similar responsibilities 3 on all three job title here.
(
4 0 What was the difference in your job 5 responsibilities as a General Engineer from those as a Field 6 Construction Supervisor / Electric at tha t plant?
T A Very little.
8 C Was it a change in title?
9 A Yes.
10 0 In March of 1967, did you become an Assistant 11 Field Superintendent / Construction at that plant?
12 A Yes.
13 Q Was there a chaage in your responsibilities at i
14 that time from responsibilities as a General Engineer?
15 A Yes.
16 0 What was the change in responsibilities?
17 A I assumed somewhat broader re=ponsibilities for 18 other areas of the plant also.
19 Q What other areas did you now have responsibility
\ 20 for?
i 21 A I had more responsibility for some of th e work i -
22, tha t sas going on in the structural work and some of the 23 work that was going on in the electrical area. I was still 24 primarily responsible for the piping and instrumentation 25 start-up.
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l ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
18 I
1 Q When you say more responsibility in the structural 2' area, do you mean -- what do you mean by more responsibility
? in the structural area?
4 A I had more supervisory r espo nsibili ties over other 5 engineers who had-specific responsibilities in that area.
6 It was a promotion.
T Q By structural area am I correct in understanding 8 that to mean the construction o f buildings?
9 A Yes.
10 0 With respect to responsibilities in the structural 11 area, did you have occasion to consider soil settlement 12 f actors in those buildings you were supervising?
13 A Yes.
14 Q What was the nature of the consideration of the 15 soil?
16 A Cccasionally, as I recall, we checked surveys of 17 the buildings to see what the settlement was on them. We i
18 ran surveys on the structures.
19 Q The surveys that actually had taken place?
5 20 A We ran checks to see that the survey had taken 21 place and what the survey was.
22 C In your supervision of this structural area, did 23 you have occasion to consider predicted soil settlement?
24 A I dea't recall the answer to that question.
25 Q In July of '67 did you switch --
ALOERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE S.W., WASHINGTON. 0.C. 20024 (202) 554 2345 !
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I 19 1 A Excuse me. Maybe I can backtrack.
2 If you are saying predicted settlement with l 3 looking at what the survey said and what we actually found 4 out there, yes. I probably looked at what the survey said i
- S and looked at what was required or what was allowable, if 6 that is what you are talking about.
l 7 Q All righ t. let me come back to that. Was part of 8 your responsibility to see that the aufiding was not, sinking l
l 9 beyond the specifications -- beyond the rate predicted by l 10 the specifications?
l 11 A Sinking or rising, yes.
l 12 Q Do you recall whether during that period you had'a l
13 situation arise where a building sank or rose more than was
- e 14 predicted by the specifications?
l l 15 % I recall no such incident.
16 Q In July of '67 you switched plants and maintained -
17 the same title?
18 A That is correct.
19 C Were your responsibilities similar at this next N 20 plant?
21 A The next plant was a different plant. It was more i
22 in the civil stages, so I had more civil responsibilities l
l 23 1* cially than I did a t the o ther plant. They were, 24 however , similar responsibilities. i 25 C What kind of plan t was that?
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ALDERSoN RQoRTING COMPANY. INC, 400 vtRGINIA AVE., S.W., WASHINGloN D.C. 20024 (202) 554 2345 I l
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1 A It was .he Palisades Nuclear Plant.
2 C '4 hen you say more civil responsibilities --
- 7. .
3 .i The plant was just being built. It was starting 4 from the ground.up. The other unit -- we were putting a new 5 unit in an existing building.
6 Q Did you become at all involved with the uesign of 7 these buildings?
8 A No.
9 0 Your responsibilities extended -- did your _
10 responsibilities --
11 A Let me correct that. Possibly some minor design, 12 but not design as I in terpret the word design.
13 Q How do you in terpret the word design?
14 A If we had some minor conflict with something where 15 maybe a piece of pipe was running through another piece of 16 pipe maybe we would ad just the elevation of the pipe or 17 something like that. But they were very minor things I was 18 involved in.
19 0 Did you consider soil questions? Soil settlement
. 20 -- did you consider soil settlemen t with respect to the 21 Palisades Plant in the same way that you did with respect to 22 the Campbell plant?
23 A No.
24 C Did you consider soil settlement at all with 25 respect to your responsibilities at the Palisades Plant?
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ALDERSCN REPORTING COMPANY,INC.
400 VmGINIA AVE, S.W, WASHINGTON. 0.C. 20024 (202) 554 2345 3 ,,
21 1 A Only that I was a ware that settlement readincs 2 were being taken. I didn 't have the same responsibilities 3 as I did over at Campbell.
4 C In August of ' 6 8 you became a Gen eral Superviso r .
5 Is '..ia t correct?
6 A Yes.
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7 G Was that at the Palisades Plant?
8 A Yes, it was.
9 Q How did your responsibilities change from those as to an Assistant Field Construction Superintendent a t Palisades?
11 A When I became a general supervisor I was no longer 12 involved in construction activities. I was invcived in 13 coordination of all start-up ac tivities prior to fuel load.
14 C When you say coordination of all start-up 15 activities, what did that involve?
1 16 A That involved coordinating the efforts of start-up 17 engineers that reported to me, coordinating the efforts of 18 pla n t operators, coordinating the efforts of 3echtel's 19 start-up engineers, cot rdina tin g the efforts of combustion s 20 engineeringr start-up engineers.
21 O' Were those individuals -- were they reporting --
s 22 wha t were these individuals reporting to you?
23 A The start-up engineers that reported directly to 24 se were responsible for check-out and pre-operational tests 25 of individual systems. Start-up engineers tha t were k
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVEL. S.W., WASHINGTON. O.C.20024 (202) 554 2345 b G
22 1 reporting indirectly to me were responsible for assistance 2 in specific areas.
3 Q With respect to these tasks, did people reporting f.
4 to you do the analysis of the tests or'did they feed you the
. 5 results and you did the analysis of the tests ?
6 A The people who reported to me ran the tests, 7 collected the information, fed me some in fo rm'ation o.1 the 8 analysis, and ani prime responsibility was ns+ ' z.ulyre the 9 tests but to take th e tests and run the tests.
10 0 In March of '71 you became Project Superintendent 11 , a t the Palisades Plant?
12 A Tha t is correct.
13 0 How did your job responsibilities change at the 14 time f rom General Supervisor of the plant?
15 A At that point in time the operation of the plant 16 was turned over to the Operations Department and I Vas 17 responsible for the rad waste and cooling tower 18 modifica tions .
19 Q Was your job to supervise the con struction 20 activity ?
21 A My job was to supervise the contractor's efforts i
22 in that area.
23 0 What exactly do you mean when you say you 24 supervised the subcontractors?
s 25 A Myself and the engineers who reported to me were
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ALDERSoN REPORTING COMPANY, NC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 10024 (202) 554 2345'
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'I 1 responsible. f or seeing that the . contractor comp'leted the
- 2 project on time and within the specified budget.
, 3 They also included coordination activities with 4 certain other departments within Consumers Power Company.
S Q Okay. -You were responsible for seeing that the 6 - subcontractors completed the project on time within the 7 budget. Did you also -- were you also responsible for
. 8 seeing that the job was completed according to 9 speci#ications?
10 A Quality assurance was a separate responsibility,
].
11 if that is what you are getting at.
Il Q Is there a difference between quality assurance 13 and quality control?
14 A Yes.
15 Q Were you responsible for supervising the quality 16 control? -
i 17 A I don't think I can recall off the top of the head 18 exactly what my responsibilities were in the area of quality i
19 - a t that point in time, because that was a different era as i
- % 20 far as quality assurance and quality control. I probably i 21 had some quality responsibility, but I can't'tell you to s
. 22 - wha t extent . It was back in the '60s.
i 23 0 In general, who would be responsible for quality i
! s 24 control? .The subcontractor or Consumers?
25 A You:'.ean contractor? There is a difference
' 1
< l
?
k ALDERSoN REPORTING COMPANY,INC, i -
400 VIRGINIA AVE. 3.W. WASHINGTON, D.C. 20024 (202) 554 2345 t -l
24 1 between contractor and subcontractor.
1 0 Contractor.
3 A Generally speaking, the contractor was responsible 4 for quality control.
5 C It is the contractor who you v Tre supervising in o 6 the installation or construction of the rad waste and 7 cooling towers?
8 A Yes.
9 C Would you in any way consider, within the to responsibilities of that supervision, whether or not the 11 quality control program of the contractor was adequate?
12 A A s I recall, I did, because I believe some of that 13 work was non-Class One structures.
14 0 If it was Class-One, you would no t have considered 15 it?
16 A .As I recall, it was Class Cne. The quality 17 control and quality assurance were done by a separate 18 department of Consumers.
19 0 Then in January of '73 you became Project s 20 Superintendent , I assume, at th e ?.id la nd Plant?
21 A Yes.
22 C And that is your title up until the present?
23 A Yes. That is correct. -
24 C ere your responsibilities to fidland of the same 25 general nature as those with respect to-Palisades rad waste l
l ACERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
25 1
/
1 and cooling tower construction, except on a broader scale?
2 A Yes.
3 MR. ZAMARIN: For the record I would like to
(.
4 indica te that Exhibit 1 is, in f act, a resume of Thomas C.
5 Cooke that we provided to you today.
) . 6 BY MR. JONES (Resusing) o
] 7 C With respect to the Midland plant and your O
8 supervision -- strike that.
9 Are you supervising the contractor with respect to 10 the Midland plant or both the contractor and subcontrac to rs i
11 with respect to the Midland pla n t ?
12 A The contractor and subcontractors.
j ,
13 0 Does that supervision include considering the ,
14 quality control progra3s of either the contractor or
. 15 subcontractors?
16 A I have no direct responsibilities for the quality 17 control programs.
18 0 Do you have, any responsibility wi th respect to 19 quality assurance?
. 20 A I have no direct responsibility with respect to 21 quality assurance.
22 C Are you kept informed of any quality assurance?
23 Are you kept informed of any quality assurancen problems 24 which the quality assurance branch identifies?
25 1R. ZAMARIN: I will have to object to the form cf
(
ALCER$oN REPORTING CCMPANY, WO.
. 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 l
-. . ~.. . . . .-.
26 j
( 1 the question. Quality assurance problems is a little vague.
2 BY MR. JONESt (Resuming) 3 Q Are you aware of what a non-conformance report is?
I 4 A Yes.
5 C Are you kept aware of any non-conformance 6 reports? Are you kept aware of any non-confor::ance reports l 7 that are issued with respect to the Midland plant?
8 A Yes.
9 C Are you kept aware of any quality control 10 deficiencies with respect to the Midland plant?
11 MR. ZAHARINs I would have to object. If we're 12 talking about deficiencies in the quality control program or 13 deficiencies as identified by quality control.
14 HY MR. JONES: (Resuming) 15 0 Are you kept informed of any deficiencies in 16 construction as identified by quality control people, 17 whoever they are?
18 A Yes.
19 Q Do you have any responsibilities to act on o 20 inf ormation such as non-conformance reports or the notice of 21 deficiencies in construction which the quality control group s
22 identifies?
23 A Yes.
24 0 What action do your responsibilities require yo u 25 to take?
(
ALDERSoN AEPoATING COMPANY. (NC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 1
i 27 4
5 1 A They are rather broad responsibilities. If I am i 2 aware of a problem that is developing in the field work I as 3 responsible in a general sense to investigate the problem r 4 and try to assist in resolving it from a management i 5 standpoint.
- 6 Q In your present position , do you have any stop 7 work authority?
8 A Yes.
9 0 What is the extent of that authority?
10 A If I see some problem that I feel the contractor 11 is not resolving in a timely fashion I can stop the work in 12 tha t area.
l 13 Q In your present position, do you receive reports 4
1-4 of . vsrious experts in the disciplines involved in 15 construction of the plant?
18 A I don't understand the word experts.
l 17 0 I believe you sta ted earlier that you do not have 18 --
you would not consider yourself an expert in geotechnical 19 matters. Is that correct?
. 20 A That is a true statement.
21 0 When a geotechnical problem comes up which you are i
22 supervising, do you receive reports from people who would be 23 considered experts in the geotechnical field?
s 24 A Yes.
25 Q Do you rely on their conclusions as presented to I i, l
ALDERSCN REPORTING COMPANY, .NC, 400 VIRGINIA AVE S.W., WASHINGTCN. D.C. 20024 (202) 554 2345
28 1
< 1 you, or within the extent of knowledge of geotechnical 2 matters you do have do you analyze the report that was sent 3 to you?
(
4 MR. ZAHARIN Could I hear that back please?
l . 5 (The pending question was read by the reporter.)
6 MR. ZAHARIN: I will object as to form and lack of v
i 7 f ou nda tion.
- 8 THE WITNESS
- I guess I would lik e to know what 9 you mean by do you rely. I really don't understand what you 1
1 10 are getting at.
11 BY MR. JONES: (Resuming) 1 12 0 When you receive a report from the -- the example 13 I am usi,ng is a geotechnical expert. When you receive a 14 report f roe a geotechnical expect that report contains a 1
15 conclusion with respect to whatever subject it is i 16 analyzing. Is tha t correct?
l 17 A It generally does. Yes.
18 Q My question is, do you accept that conclusion 19 without -- strike that.
, 20 My question is, to what extent do you take that
! 21 informa tion that is con tained in the re port absent th e 22 conclusion to see if you acree with that conclusion? _
23 A I guess to answer your question, to the extent --
j 24 to what extent do I agree with the conclusion or disagree 25 with the conclusion. As ! understand your question, I would ;
I A
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554-2345 I
\
29 1 probably rely heavily on what the consultant said in his 2 report and my evaluation of the report.
3 0 If a report comes to you which is in the civil 4 engineering discipline in which I think we have established 5',you are an expert, would you be more inclined -- strike that.
6 Would you perform more analysis of that 7 information?
2 .
8 MR. ZAMARINa Excuse me. You struck your question 9 and now you don't have a predicate.
10 SY MB. JONES: (Resuming) 11 Q Is the reason you would rely heavily, going,back 12 to the geotechnical expert example, is the reason you would 4
13 rely heavily, very hea vily , on that expert's conclusion 14 because you are not an expert in the geotechnical area?
15 A Yes.
16 Q If a report comes up tha t is in the civil 17 engineering area, would you be more inclined to make your 3
18 own analysis of the data?
19 A Not necessarily.
% 20 Excuse me, may I speak to counsel?
21 (A discussion was held off th e re co rd . )
s 22 BY MR. JONES: (Resuming) 23 C Did your supervisory responsibilities with respect
( 24 to the Midland plant include supervision of the dike 25 construction?
ALCERSON REPORTING COMPANY. INC, 400 VIRGINlA AVE., S.W., WASMINGTON D.C. 20024 (202) 554-2345
I 30 1 A Yes.
1 Q Ca n you describe wha t your supervisory 3 responsibilties with respect to construction of the dike 4 involved?
5 A My primary responsibilities with respect to the 2 - 6 dike involved cost and schedule and quality on the non-C 7 portion of the dike.
8 C Who supervised -- you may have answered this 9 question, but I've forgotten. Who supervised t'his -- the 1
l 10 construction of Q-related structures ?
j 11 A Who supervises construction?
12 Q You just said your responsibility with respect to 13 dike construction was supervision of cost, schedules and.the l 1-4 quality of non-Q portions.
15 A Right. Only. l 16 C Q-portions are seismic category one. Is that the 17 dif ference ?
i 18 A Yes.
19 Q Whose responsibility is it -- cost, schedules and
- 20 quality -- with respect to seismic category one structures?
21 A I have overall responsibility for costing,
,s 22 scheduling , on the job. If it is a class one structure, 23 quality assurance has prime responsibility for the quality.
(. 24 0 When was construction on the dikes completed?
25 A I believe the dike -construction was completed s
J ALDERSoN REPORTING COMPANY, INC. -
400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
, 31 l
1 f' 1 a pproxima tely 1975. l l
2 0 You mentioned earlier that you ha ve stop wo rk g, 3 authority. Do you ever exercise that au tho rity in the 4 construction of the Midland plant?
5 A Yes.
6 Q More than once? 6 T A I believe so. Yes.
8 Q When was the first time you exercised it?
j 9 A I don't recall.
10 Q Did you exercise it on numerous occasions?
y 11 A What do you mean by numerous?
11 0 Did you exercise this more th an five times?
i 13 A To the best of my recollection, it was not more 14 than five times.
15 Q Do you remember what the situation was which 16 caused you to issue the first stop work order?
17 A No, I do not.
18 Q Do you remember the most recent stop work 19 authorization?
s 20 A Yes.
21 Q What was that with respect to?
22 A. It was with respect to the welding of small pipes 23 to large pipes and the usage of weld-o-lets and sock-o-lets.
( 24 Q What caused you to issue the stop work 25 authorization in that instance?
(
ALDERSoN REPORTING COMPANY,!NC, 400 VIRGIN 8A AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
32
+
r- 1 A As a management function, it did not appear to me 2' tha t we were resolving the problem in a timely fashion.
3 Q What exactly was the problem?
r 4 A The problem involved the interpretation of the 5 amount of weld -- that s a ll -- th a t was being placed when 6 you were utill=ing suc' things as weld-o-lets or sock-o-lets.
s .
T 0 Was there some disagrement over the' amount of P
8 metal that should be used?
9 A There was a disagreement on the interpretation.
10 0 Between -- was the disagreement between --
11 A I can't say tha t it was.between any two parties.
12 There were several parties involved and several people were 13 in the discussion. Project management people were i 14 involved. Quality assurance people were involved. Quality 15 control people were involved. Field engineers were involved.
16 C Was this disagreement between Bechtel people and 17 Consumer people, or within one of those organizations?
18 A Primarily between Bechtel and Consumers.
19 Q Has that been resolved?
t
- 20 A No. That has not been resolved.
21 C Do you recall whether you ever issued a stop wo rk 1
22 order with respect to a soils problem?
23 7 I don't have any recollection of it.
24 Q Can you briefly describe some of the other 25 instances in which you can recall issuing a stop work ALDERSON REPCRTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
33 1 authorization?
2 A Not at this time.
3 Q With respect to your issuance of a stop work 4 order, do you consider the cost of issuing such an order and 5 by cost I mean do you consider the cost a delay in 6 construction will entail in issuing a stop work order?
7 MB. ZAMARIN: Are you referring to the type of 8 stop work orders which he does which are the non-QA area?
9 When you say you, it is not clear whether you are referring 10 to him personally.
11 MR. JONESt I have to go back because you are 12 saying something he didn't say.
13 . MB. ZAMARIN: If you will go all th e way back, you i
14 will see that he did.
15 BY MS. JONES: (Resuming) 16 Q You did say that you have general overall 17 responsibilities f or supervising construction of the 18 facility, did you not?
19 A .es.
20 0 You did say that with respect to Q portions you 21 have less supervisory responsibility. I take that ba ck .
s 22 Tha t the QA group is more involved with supervising cost, 23 schedules and quality?
24 A No.
25 MR. ZAMARIN: He said they were responsible for A. ,
ALDERSoN F4EPoRTING COMPANY. INC.
400 VIRGINIA AVE, S.W., WASHINGTON. o.C. 20024 (202) 554-2345
.- =- . . . _ . -.
l 34 1 quality. QA is, on those items.
2 BY MR. JONES: (R esuming )
3 0 You are still responsible for costs and scheduling
?
4 with respect to that?
5 A Yes.
- 6 0 Do you have stop work authorization with respect T to Q-related structures?
?
8 A Yes. __
9 Q Is the only stop work authoritation you to specifically recall issuing the one with respect to velds?
11 A At this point in time, yes.
. 12 0 Is that related to a 0-related structure?
i 13 A It is related to Q-related work. Yes.
14 0 In issuing a stop work order such as that one, is 15 one of your considerations the cost from th e delay in 16 construction that stopping work would entail?
17 A I consider cost.
18 0 What do you mean when you say cost?
19 A If I consider cost I would consider cost of the w 20 delay . I would consider the cost of rework if something 21 ven t uncorrected and had to be rewo rked .
1 22 0 Do you ever seek advice -- strike that.
23 You do have superiors within the Consumers Power 24 Company, do you not?
25 A Yes.
(-
ALDER $oN REPORTING COMPANY. !NC, 400 VIRGINIA AVE., S.W., WASHidGToN. D.C. 20024 (202) 554 2345
1
, 36 1 Q Have you ever received advice from those superiors 2 with respect to whether or not a stop work authorization 3 should or should not,be issued?
t
+ A Yes.
5 Q Can you relate -- when was that that you received 6 such advice? And I mean when, not da te but with respect to 7 what problem?
4 .
8 A I have probably received advice on more than one _ _ , _
j 9 occasion. The most recent advice being the most recen t stop to work.
11 0 Was that advice to issue the stop work or not 12 issue the stop work order with respect to the-most recent?
, 13 A Neither.
I 14- 0 What was the advice ?
s 15 A The advice was that if it wasn't resolved by 16 quitting time -- if I couldn't resolve it by quitting time 17 to go ahead and issue it.
18 0 I take it that was quitting time on whatever day?
19 A Yes. The da y in question .
d g 9 20 0 Did you receive advice from your super 1 ors on 1
21 other stop work orders with respect to the stop work orders?
s 22 A I can't recall one way or the other for sure.
.i 23 Q Do your responsibilities as a general manager --
4 24 A Project Supe rin tenden t.
- 25 0 Project Superin tenden t -- entail coordination of
(
ALDERSoM REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. D.C. 20024 (202) 554-2345
36 1 the various disciplines involved in construction?
2 A Would you rephrase the question, please?
3 Q Was it your job to coordAnate experts, as I 4 defined experts earlier as being specialists in a particula r
- 5 construction discipline, within several disciplines? And by
. 6 this I mean, did you see that there was coo rdination between 7 what one expert would recommend -- for instan'e, c a method of 8 compaction -- and between structural experts, who would 9 analyre what the effects on the building of that method of 10 compaction would be?
11 A No.
12 Q Do you know if there was a consultation between 13 the disciplines, again using the example I used of between a 14 structural engineer and a geotechnical person , with respect 15 to the effects -- what one individual was recommending would 16 have on the other person's discipline?
17 A 'Yes.
18 0 Could you describe the nature of the communication?
19 A I have sat in on meetings in Ann Arbor where the
, 20 structural discipline and the soils disciplines were present 21 at the same mee ting discussing common problems. I have also 22 sat in on meetings where consultants, which you are defining 23 as experts, were in these meetings discussing the problems 24 between, say, the soils and the structural.
25 Q Did your respoasibilities, as you described them,
( .
ALDERSoN REPORTING CCMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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37-l l
1 apply to the construction of the administra tion building?
2 A Yes.
3 Q Are you f amiliar with the soil settlement problem 4 that occurred with respect to the administration building?
5 A ss .
- 6 0 When did you become aware of that problem?
T A I can't give you the exact date.
8 C A rough estimate. Give me as near as you can. I 9 don 't care if it is a year or six months.
10 A I really don 't know off the rap of my head.
i 11 Q Do you know if it was soon after the problem was 12 discovered?
13 A Yes.
14 Q How would tha t ha ve come to your attention?
4 15 A The 9echtel project superintendent brought it to 18 my atten tion .
I 17 Q Would you describe the problem with the
.J 18 administration building with respect to soil settlement?
4 19 A There was an excessive amount of settlement of the
- 20 grade beam.
21 C The last phrase you used was grade beam? Use a s
22 layman 's term please?
23 A Concrete down in the soil a ways.
24 0 When you became aware of this settlenent problem 25 with respect to the administration building, did you inform 9
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTCN. O.C. 20024 (202) 554 2345
38 1 the Jackson office of Consumers Power of that problem?
2 A Yes.
3 0 How soon after you were informed of the problem 4 did you inform the Jackson office?
5 A I don't recall.
~
6 0 Would it have been more than six months after you 7 found out?
8 A No.
9 0 Ho w did you inform them -- the Jackscn office of 10 Consumers Power?
11 A I can tell you specifically one way that I 12 inf ormed them and that was by copying them on a letter tha .
13 I wrote to our contractor requesting that ,h e keep the costs 14 separate for the repair of this thin g , inasmuch as we feel.
15 that it might have been something that we would want to be 16 reimbursed for later.
17 0 Did a copI of tha t letter go to Mr. Keeley, to 18 your knowledge?
19 A Yes, it did.
4 20 0 Do you recall whether that letter was sent before 21 the problem with the diesel generator building developed?
d 22 A Yes, it was.
23 0 Do you recall whether it was sent before 24 construction of the diesel generator building began?
25 A I can 't tell you that.
( ,
1 ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 1
1 I
l 39
,- 1 C You did testify that you couldn't remember exactly 2 when you sent that?
3 A Yes.
(
4 Q Can you give me , within s yea r, t ha t you sent it?
. 5 A No .
, 6 MR. JONESz Let's take a five-minute break.
7 (A brief recess was taken.)
l S BY MR. JONES: (Resuming) 9 Q I show you an exhibit that has been marked NRC 10 Exhibit No. 2 in the date of 10/22'/80. Is that the letter 11 rou referred to as being sent, a copy of which was sent to 12 the Jackson office?
13 A Yec.
5 14 (The document referred to was 15 marked NRC Deporition Exhibit 16 No. 2 for iden tification. )
17 BY MR. JONES: (Resuming) 18 0 Does the company have some notation on here that 19- indicates who copies were sent to?
,p 20 A There is no indication on this letter.
21 MR. ZAMARINr Just for the record, exhibit number
~-
22 2 also contains a J etter dated September 23, 1977, to the 23 attention of T. C. Cooke at Consumers Power Company f rom 24 wha t appears to be a J. F. Newgen -- N-e-w g-e-n -- and a 25 letter dated December 30, 1977, to Mr. T. C. Cooke from Mr.
(.
ALDERSoN REPoRTEG COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345 x _ .
40 f
r 1 Newgen also. -
2 The first letter to which these are stapled is a 3 letter dated September 8, 1977, to Mr. Newgen from Mr. T. C.
(
4 Cooke.
5 BY MR. JONES: (Resuming)
. 6 C You stated a copy of this letter was sent to the T Jackson office. Is tha t correct?
8 A That is correct.
9 C Do you know whether a copy of tnis letter was sent 10 to Mr. Keeley?
11 A As I recall, I sent a copy directly to Mr. Keeley 12 and discussed it with him.
13 Q That would have been, I think we established, i 14 within at least six months af ter you sent this letter?
15 A Yes.
16 Q At the outside?
17 A At least.
18 0 'de had just begun discussing the administration 19 building. You have described the test or the problem at the
_,3 20 administration building as being settlement -- I d on ' t think i
21 this is the way you described it. Let me ask you if this is 22 a correct cha racterin tion, as settlemen t b eyond tha t 23 provided for in the technical specs?
24 A I described it a s excessive settlement of the 25 grade beam. )
l
\, . , l ALDERSON REPORTING CCMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345 ,..
O!'%Q
i 41 1 Q I'm going to refer to that as excessive settlement.
2 Do you know if tests were taken to determine if 3 the problem with the excessive settlement a t the i
- 4 administration building was an isola ted problem?
5 A To the best of my recollection, yes.
~
6 Q Do you know what kind of tests were taken?
T A We took, as I recall, two additional soil borings.
8 Q Do you recall what the conclusion was from those 9 borings?
10 A The conclusion was that the administration grade 11 bean was an insolated instance.
12 0 Do you recall where those two borings were taken?
13 A To the best of my knowledge, one was taken in the I 14 evaporator building area and the other was taken near the 15 diesel generator building.
16 Q Who decided -- s t rik e th a t .
17 Who decided what kind of test would be used to 18 determine if it was an isolated problem? I mean, was it 19 Bechtel or Consumers?
"- g 20 3R. Z~AHARIN: Or somebody else.
21 3R. JONES: Yes. Or somebody else.
22 THE WITNESS: I think it was.a Bechtel decision, 23 as I recall.
24 BY 32. JONES 4 (Resuming) 25 Q Do yon know if Consumers had any input into that l
(
ALDERSoN REPORTING CCMPANY,INC. 1 404 VIRGINIA AVE., S.W., WASHINGTCN. D.C. 20024 (202) 554-2345
~ ~' . ;p D
42 1 decisien process?
~ ~ ~
2 A As I recall, we concurred with it.
3 Q Can you explain this to me? As I understand it,
(~
4 there was one boring taken on the north side of the plant.
5 I think that was the evaporator building. There was one
- 6 taken on the south side of the plant. Was it slightly south T of the diesel generator building?
8 A To the best of my recollection it was somewhere 9 near the diesel generator building. I don't recall exactly 10 where it was.
11 Q The diesel generator building is on the south side 12 of the plant?
13 A That is correct.
I 14 0 Can you explain to me, as a layman, how those two 15 borings can indicate whether or not it was an isola *ed 16 problem with respect to the whole plant?
17 A We tested the soil in those two a reas and we found 18 the soil acceptable from the tests that we ran on it, and 19 tha t, coupled with the fact tha t we had observed no other sq N 20 unusual settlement , led us to the conclusion that it was an 21 isola ted incident.
22 0 At the time these tests were taken -- these two 23 borings -- had construction begun on the diesel generator
. 24 building outside of prepara tion of the soil?
(
25 A I don't r eca ll .
A1.DERSCN REPORTING COMPANY,INC,
.,j 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345 ia
43 1 0 Do you recall when these borings were taken?
2 A I don 't recall the exact date. To th e best of ay 3 recollec tion , they we e some time in the same time frame as f
4 when we discovered the problem -- shortly thereafter.
5 0 Were the two borings taken in areas in which fill 6 material had been placed?
} _
y A Tes.
8 0 Was there ever any concern in your mind that two 9 borings might nc t be enough to determine whether or not this 10 was an isolated problem ?
11 A No.
12 MR. ZAMARINa I'm sorry. May I have that question 13 and answer read back? ,
l 14 (The question and answer were read by the 15 reporter.)
16 BY ER. JONES: (Resuming) 17 Q I'm still confused. As a layman -- I will explain i
18 my confusion and perhaps you can answer a question that will 19 straighten that out.
'5 20 My problem is that I see there was settlement at 21 the administration building and two borings were taken --
s 22 one at the northern side of the plant and one at the 23 southern side of the plant. I take it there was also fill 24 material being placed in-between those two points. Is that
(
25 correct?
(
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2346
44
, 1 A That is correct.
2 Q My question is I'm having a problem understanding 3 how a boring taken a t the northern side and one at the f..
4 southern side can indicate that ~ there is not a similar 5 probler with the soils in-between those two points. That is
- 6 my problem. That is my statement of what my problem is.
7 Now my question is can you explain'to me how those 8 two borings indicate whether or not there is a similar 9 problem with the soils in the area in-between those two 10 points?
11 MR. ZAMARIN: I 'm going to object. I think that 12 was asked and answered.
13 MR. JONES: I said I don 't unde rs ta nd the t
- 14 question. As a layman I'm asking him if he can possibly 15 exclain it to me.
16 MR. ZAMARINs You mean other than him saying that 17 those borings showed the soil was acceptable and th ey h adn ' t 18 observed any other unusual settlement? I don 't know how he 19 could break it down any finer than that.
r e; 20 MR. JONESs All right. I will withdraw the 21 question.
9
. 22 2Y MR. JONES *. (Resuming) 23 0 When you say tha t one of the reasons that these 24 borings indicated that this was an isolated problem was that
(
25 in addition to the tests on the borings themselves there was k
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASH!NGTON. 0.C. 20024 G02) 554 2345
45 1 not any other settlement being observed. There was not any 1 other unusual settlement being observed with respect to the 3 other portions of the plant.
4 With that premise, I ask you would any significant 5 settlement be expected before a building is placed on an gg 6 area that has had fill material put into it?
7 A res.
8 Let se make sure I understand the question. Are 9 you saying that if there is a problem, is there any to significant settlement expected?
11 Q - Yes. That is correct. Prior to the building 12 being built.
i 13 A If there is a problem, you would expect additional 14 significant settlement prior to the building being placed, j 15 as I understand it. .
16 Q As you understand it, would any problem settlement 17 or unusual settlement be accentuated when a building was 18 placed on that material?
19 A On unsatisfactory material?
20 C Yes.
<*}
21 A Yes.
L 22 0 Would the problem be more likely to occur after 23 the building was placed? Would it be observable af ter the ,
I
( 24 building was placed on the ma terial?
25 A Yes.
.\
2 ALDERSoN REPORTING CoWPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554-2345
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46 1 0 Correct me if I'm wrong, but I believe you stated 2 you did not recall whether or not the diesel generator 3 building was under construction at the time the borings were
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4 taken?
5 A yes.
6 Q Do you know -- how would you describe the nature 9
7 of the fill material that was placed under t.ie
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! 8 administration building?
l l 9 MR. ZAMARINs Objection as to form.
l to BY MR. JONESt (Resuming) l
. 11 Q Are you familiar with the fill ma terial that was 12 placed under the administration building?
13 A Generally speaking, although I'm not a i 14 geotechnical expert, I'm generally familiar with it.
l 15 Q Generally speaking, then, how would you describe 16 that material?
17 MR. ZAMARIN: The type of material? How it was 18 compacted ? Or how it was placed? What are you getting at?
l 19 MR. JONES: I want you to describ e, generally
,. c 20 speaking, the type of material.
21 THE WITNESSs I would generally describe the type 22 of material as clay and possibly, in some instances, sand.
23 BY MR. JONES: (Re suming )
l 24 Q Is random fill an appropriate way to characterize
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25 that material?
A.
I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202) 554-2345
47 1 A Not necessarily.
2 0 Is zone 2 saterial an appropriate way to 3 characterize that material?
f 4 A I don't recall all the definitions of the zones 5 and specs in C-210. But what I am saying is it is not 6 specific. Whatever I said was that I recall part of th e 7 material under the administration building is' on plant fill t
8 and I think a portion of it somewhere along the line sits on 9 a dike back fill. I'm not sure just exactly where that 10 dividing line is.
11 Q Do you know, with respect to which cf those two 12 sets of material you just identified --
the back fill for 13 the dike and the plant fill -- that the problem of 14 settlement occurred --
the unusual settlement occurred with
]
15 respect to the adminictration building?
16 A As I recall, it was in the plant fill portion.
17 C Was that plant fill, to the be st of your 18 knowledge, the same fill that was placed under the diesel 19 generator building?
f e; 20 MR. ZAMARIN: The same type?
21 MR. JONESS The same type of material.
22 THE WITNESS: The spec allowed the same type of 23 material.
24 BY MR. JONESL (Resuming) 25 Q Do you know whether in f act it was the same type
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON D.C. 20024 (202) 554 2345 .
48 r 1 of material that was placed under the diesel generator 2 building as had ueen placed under the administration 3 b uilding ?
r 4 A No.
5 Excuse me. Let se correct that. I do know there
- 6 was some kind of concrete placed under the diesel generator
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T building. I don't believe there was any placed under the 8 administra tion building . I know there is some sand under 9 the diesel generator building. I don't know if there was 10 any sand placed under the administration building.
11 Q You do know, I believe you stated, that you did 12 know that the specs called for -- the specs allowed the same 13 type of material under the administration building and the 14 diesel generator building. Is that correct?
tj5 A That is correct.
10 0 When the administration building problem was 17 brought to your attention do you recall what the status of l
l 18 construction on the diesel generator building was?
19 A No.
,- g 20 0 When you learned of the problem with the unusual 21 settlement at the administration building --
22 XR. ZAMARINa You had earlier indicated that you 23 were going to call the excessive amount of settlement cf the 24 grade beam excessive settlement of the administration
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25 building. Are you still doing that?
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ALDER $oN REPORTING CoWPANY. INC.
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, 1 MR. JONESa I will try to do that.
2 MR. ZAHARINs It migh t be. appropriate to ask his 3 whether the entire building experienced unusual settlemen t, f
4 just so we can clear it up, because I don 't know when you 5 are switching off of that previous definition.
6 MR. JONES: I think he said it was just the a*eas 7 where the plant back fill was located as oppo' sed to the dike.
& BY 53. JONESs (Fesuming) 9 Q What portion of the administration building?
10 A The grade beam is what was settling.
11 0 Is that the portion that was located on plant fill 12 as opposed to the dike back fill?
13 A As ! recall, it was the portion on plant fill.
' 14 Wa: the whole administration building sinking as a 0
15 result of the excessive settlement of that beam that you 18 iden tified?
17 A No.
I What portions of the building were?
18 Q 19 A None.
,, *j 20 0 Was the building in place at that time?
21 A No, it was not.
22 0 Was just that beam in place at that time?
23 A That is correct.
24 Q When you became aware of the excessive cettlemen t 25 of this beam in the administration building area, did tha t
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
50
< 1 raise an y concern in your mind tha t the diesel generator 2 building might have the same problems with respect to 3 excessive or unusual settlement of the fill mate rial?
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4 A It raised the question in my mind whether or not 5 ve might have similar pro blems on-site. It did not raise 6 the question in my mind whe ther specifically the diesel d
T generator building had the same problem.
8 C But when you say concern of whe ther you migh t have 9 similar problems at the site you vould be concerned with to whether or not a similar problem would occur at the diesel .
11 generator building?
12 A Or anywhere on the site.
13 0 I wanted to be sure the diesel generator building 14 wasn't left out.
15 What alleviated your concern?
16 A The horings that we took and the fact that we had 17 not observed any unusual settlement in other areas of the 18 plant fill.
19 0 Other than -- strike that.
- Wnen you learned of the excessive settlement of
. 20 21 the beam at the administration building did you conduct any a
22 investigation or did you direct any investigation to take 23 place to ascertain whethe r simila r material as that which 24 was causing the problem had been placed elsewhere on the 25 plant ? I am asking if you did anythino. I realize that ALDERSoN REPORTING COMPANY, INC.
400 VIRGINIA AVE S.W., WASHINGTON, O C. 20024 (202) 554 2345
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51 1 Bechtel ordered these borings. I'm asking if you did 1
2 anything.
3 A Not that I can recall and I belle ve I nald tha t to 4 the best of my recollection Bechtel initiated the borings.
4 5 O Do you understand what the term differential
- ) 6 settlement -- does the term dif f erential se ttlement have at.I 7 meaning to you?
8 A Yes, it does.
G Q What does that term mean to you?
10 A Differeatial settlement to me means that one part 11 of a structure may be settling more than another portion of 12 the structure.
i l
13 0 Was that the type of excessive settlement that was 14 occurring with respect to the beam at the administration 15 building ? r 16 A I don't recall if the beam itself had differential I 17 settling. I don't recall.
l 18 0 Is that the type of settlemen t which caused -- is 19 that the type of unusual settlement that took place at the
,'l 20 diesel getara tor building ?
21 A We are experiencing differential settlement on the e
22 diesel generator building.
23 0 Before the diesel generator building was
( 24 constructed was there, to the best of your knowledge, any i 25 expert analysis of the effects that stress from differential l i.
ALDERSoN REPORTING COMPANY. INC, 400 VIRolNIA AVE S.W. WASHINGTON O.C. 20024 (202) 554 2345 'E $H
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1 settlement would have on the ability of the building to 2 withstand a design basis earthquake?
3 A I have no direct knowledge in that area.
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4 Q Do you know if, since the diesel generator 5 building experienced unusual settlement, there has been any
- ! 6 analysis on the effects of the stress from differential T settlement on the ability of that building to' withstand a 8 design basis earthquake?
1 9 A Yes, there has.
10 Q Do you know when that analysis was completed ?
i 11 A That was done in response to one of the 50.54(f) i 12 questions, I believe.
! 13 Q Would tha t have been question 147 14 A I don't know.
15 0 Are you confident -- strik e th a t .
16 Are you familiar with the PSAR section -- 1.4 of 17 the PSAR for the Midland pla n t?
18 A I don't recall specifically what that is.
19 Q Do you recall ahether there is a section in the 20 PS)H which deals with principal architectural and 21 engineering criteria for design of the plan t?
t 22 A No, I don 't recall.
23 Q I want to return now and talk for a few minutes 24 about the stop work authority you said you have.
25 I believe you stated earlier tha t among the k.
i l
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ALDERSON AEPoRTING COMPANY. INC.
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53 r~ 1 considerations when you are deciding whether or not to issue 2 a stop work order is cost, bo th rework and delay. And I've 3 forgotten now what the other considerations were. Would you
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4 again state what those considerations were for issuing a 5 stop work order?
4
- 6 A I don't recall whether I issued what all.the i
7 considerations were. I think you asked me if'I considered 8 cost and , hald you I did consider cost.
s 9 C Do you consider the effects on the schedules for to construction of the plant in deciding whether to issue a i
11 stop work order?
12 A I would consider the schedule eff ects, yes.
13 0 Do the quality assurance people have stop work 14 authority also, to the best of your knowledge?
15 A Yes.
16 Q Do you know whether cost is one of the factors --
17 never mind.
18 Is the quality assurance group under your.
19 supervision?
a
/ *, 20 A It is not.
21 Q Do they report to you in any way -- strike that.
s 22 When you decide to issue a stop work order, how is l
- 23 that decision executed by you? )
It A Normally it is executed through use of a letter to 25 Bechtel.
4 l l ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
54 1 Q As I understand it, then, in response to that 2 letter, then, Bechtel vill stop construction?
3 A That is correct.
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- 4 Q You say you consider schedule and you consider 5 costs. 'Jith respect to the stop work orders that you might
.) 6 issue, would you consider issues -- would you consider T quality concerns, or is that solely the province of the QA 8 people?
'9 A I would consider quality concerns. As I 10 mentioned, I do not have quality assurance responsibilities.
11 Q 'Jould you issue a stop work order solely on the 12 basis of a quality concern, or would that be referred to QA?
- 13 A I might bring it to their attention, or I might
( 14 issue it myself.
15 '
O Is there anything in particular that would 16 determine whether or not yo u wo uld take the action yourself 17 rather than refer it to QA7 18 A Generally speaking, it 'ould . be the circumstances 19 surrounding the item in question.
,$ 20 Q Do you know if QA would execute one of their stop 21 work orders in the same manner you described?
22 A They woul_d not.
23 Q Do you know what quality assurance method of 24 execution of stop work orders they have?
A 25 A They have a written procedure on how to execute ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554-2345
55 f- 1 their stop work orders.
2 0 You have no written procedure?
3 A I have none. Excuse me. Define what you mean by
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4 procedure.
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5 0 Do you have anything in writing which defines the 6 circumstances under which you are to issue a stop work order?
']
T A Yes.
8 0 What is that?
S A There are some words in my job description and 10 procedures manual.
11 C That is a procedures manual for Consumers for 12 construction activities?
13 A Yes.
( 14 C And now I show you a document labeled NBC Exhibit 15 3 for identification marked 10/22/SO, Cooke Deposition. And 16 in pencil at the top is written Midland PSAR and the typed 17 portion, or printed portion, begins with section 1.4. I 18 will now show you this and ask you if you are familiar --
19 you have ever seen -- those provisions before.
/7 20 MR. ZAMARIN: I note that the Midland PSAR is 21 written in pencil.
a 22 (The document referred to was 23 marked NRC Deposition Exhibit 24 No. 3 f o r iden tifica tio n . )
s 25 MR. ZAMARIN: The rest is a typed sheet. Do you
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
56 1 vant him to look at the whole thing or just one section?
2 ER. JONESt Would you please look at section 1.4.1 3 and 1.4.7? -
/
4 THE WITNESSL I have gone through the PSAR at one 5 time or another. I can't specifically state tnat I remember 6 reading this at any given time. That is an old document.
'l .
7 BY HR. JONES: (Resuming) 8 Q I'm going to read a portion of 1.4.1 which is 9 labeled Plant Design. It states, quote, principal 10 structures and equipment which may serve either to prevent 11 accidents or 'to mitigate their consequences are designed, 12 f abricated and directed in accordance with the applicable 13 codes and to withstand the most severe earthquakes, flooding 14 conditions, wind storms, snow loads, temperature, and other 15 deletericus natural phenomena which could be expected to 16 occur at the site during a lifetime of these units, unquote.
17 That is the first sentence of that section. That 18 is not the complete section and I ask you if you have 19 confidence that the diesel generator building, considering el 20 the stresses caused by differential settlement, meets the 21 requirements of that first statement I just read?
e 22 A I have performed no independent analysis in this 23 a re a.
24 Q Would it be -- strike that.
25 You earlier stated that an analysis has been done ALDERSoN REPCRTING COMPANY,INC, l
400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1
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57 1 in response to a 50.54(f) question.
2 A Yes.
3 0 Which was concerned with the ability of the 4 building to withstand a design basis earthquake?
5 A Yes. ' Well, you asked about differential
- j 6 settlement.
T Q Considering the dif ferential settlement stress?
9 a A Yes.
9 0 Is it your opinion that analysis shows that the 10 building satisfies this requiremen t?
11 A Tes, although you were asking a question on 12 something that I have no responsibility. That is an 13 engineering analysis. That is another part of our company.
14 0 Does your responsibility include seeing that the 15 contract -- your job responsibility include seeing that the 16 contractor builds the building to comport with the 17 specifications for the plant that are present in the PSAR?
18 MR. ZAMARIN: Could we have that read back please?
19 (The pending question was read by the reporter.)
,.I 20 MB. ZAMARINt Are you talking about the diesel 21 generator building?
e 22 NR. JONES: I will withdraw the question.
23 O! MR. JONESs (Hesuming)
( 24 Q Is it a proper characteriration of your job 25 responsibility that you are responsible for making sure that i
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S8 1 Bechtel builds the plant in accordance with the 2 specifications ?
3 NR. ZAMARINc Could I have that read back, please?
4 (The pending question was read by the reporter.)
5 THE WITNESS: Specifically I have responsibilities 6 on the non-Q portions of the plant for quality.
7 BY MR. JONES (R esuming )
8 0 By the phrase quality, is that analogous to 9 whether or not the construction is in accordance with the 10 specs?
11 A Yes.
12 0 But that responsibility does, no t extend to 13 determining whether Q portions of the plant are built in I
14 accordance with the specs. Is that correct?
15 A I have no direct respqnhibility to assure-the 16 company that the Q portions of the plant are built in 17 accordance with the specs.
18 Q Let me ask you who is the lowest level individual 19 who has responsibility for overseeing whether or not the Q i 20 portions are built in accordance with the specs?
21 A In Consumers Power Company?
e 22 O Yes, in Consumers Power Company.
23 A It would be the on-site quality assurance engineer.
24 Q Is that Mr. Horn?
25 A Mr. Horn, I believe, is a section supervisor.
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ALDERSoN REPCRTING COMPANY. INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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59 J
/ 1 Q Is this individual you are describing who has .
1 2 authority over all the Q portions -- would he be above or l 1
a below Mr. Horn?
f
- A If I understand your question prc perly, he could 5 be Mr . Horn or somebody working f or him or someone above him.
6 Q Do you have any responsibility with respect to s
7 determining whether the soils are compacted to comply with 8 the specifications within the power block a rea?
9- A I have no direct responsibility to assure 10 Consumers Power Company that the soils are properly 11 compacted in the power block area.
12 0 Are you responsible for supervising the 13 construction of the diesel generator building? Were you i
S t rik e th a t .
14 responsible?
15 Was one of your responsibilities determining 16 whether the diesel generator building was built to the 17 specifications? I think I know the answer, but answer me 18 anyway.
19 A If I understand your question, the answer is no.
3 20 Q Explain how you understand my question.
21 A I think you are trying to get at quality assurance 22 responsibilities for which I'm not responsible.
23 I am responsible for the contractor getting the
( 24 job done, getting it done properly and on time and on 25 schedule . I do not have quality assurance responsibilities.
A ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
60 1 Q Here is where my problem is. Wha t is the 2 difference between seeing that a job is done properly and a seeing that it is done in accordance with the specifications?
4 A From a management sta nd poin t , if there is a
. 5 problem that is developing in the construction of any part 6 of the plant up there, I would possibly become involved to T see what that probler was and help resolve it' if I could.
~
8 From the standpoint of seeing tha t the 9 specification is followed to the letter, the quality control 10 engineer does that. The quality control engineer works for 11 Bechtel and the quality assurance organiration, over which 12 I'm not a part, has responsibility to see that the quality 13 control engineer is doing his j ob.
I 14 Q Then did you become involved with the correction 15 of the soil settlement problem with respect to the diesel 16 generator building?
17 A Yes, I did.
18 0 In determining what should be done about that soil 19 settlement problem, did you have occasion to consider what 20 the causes of the problem were?
f 21 A Yes.
22 0 What, to your understanding, caused the soils --
23 strike that.
24 Is it your understanding that the soils were 25 improperly' compacted and that that was at least one of the
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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69 1 causes of the~ problem?
2 A Yes,it is.
3 0 Do you have any knowledge as to why they were 4 improperly compacted?
5 A Ies.
- 6 C What is your understanding?
7 A My understanding is th a t the soils in tha t area 8 were improper 1'y compacted. As we presented to the NRC the___
9 several reasons -- I believe it was the July 18, 1979 to meeting in Bethesda -- which is part of the 50.54(e) report.
11 0 I don't have that ih front of me. Let me ask, was 12 one of the causes -- was one of the problems that led to 13 this improper compaction with the people who were conducting I
14 tests on the soil?
15 MR. ZAMARIN: May I hear that back, please?
16 (Th e pending question was read by the reporter.)
17 MR. ZAMARIN: I object. I think the question is 18 in improper form and it is too vague with respect to 19 reference to problems with people. Is the question in such y 20 a f orm that you believe you can answer it as stated?
21 IHE WITNESS: I think I can clarify it, but I 22 can 't answer it as stated.
23 BY MR. JONES: (Resuming) 24 C You just referred to an answer that was sent to 25 the NBC in response to one of your questions which contained
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At.DERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. D.C. 20024 (202) 554 2345 n , p
62 1 -- you referred to a meeting in which the causes of the 2 problem we discussed -- can you relate to me what those 3 causes were that were presented at that meeting?
4 A I can't relate all of the causes to you. I don't o S recall all of the causes.
- 6- 0 Can you give me those that you do recall?
4 T A As I recall, one of the causes was an 8 over-reliance on testing. I think we 1isted th a t and 9- several other potential causes at that meeting.
10 0 Is it your understanding that the over-reliance on 11 testing is the principal reason for the problem?
11 A It is my understanding that that was one of the 13 principal reasons for the problem.
I 14 'Jas the group that was conduc ting the tests on 0
15 which there was over-reliance, are those the tests that were 16 conducted by U.S. Testing?
17 A Yes,it is.
18 Q When you come in on a problem, as you did with the 19 1.esel generator building soils problem, is part of your
,9 20 responsibility to recommend a course of action which will 21 prevent the occurrence of the same problem in the future?
22 MR. ZAHABIN: Could I hear that again , please ?
23 (The pending question was read by th e reporter.)
q 24 IHE WITNESSs Only in a general sense, as part of 25 the in ve stiga tion .
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 l
63 f 1 BY MR. JONES: (Resuming) 2 0 Do you recall what changes, if any, you 3 recommended to prevent a reoccurrence of this type of soils
& problem in the future?
o 5 A That I recommended?
< 6 Q Yes. As a result of your nvestigation of this 0
T problem.
8 A I would have to think on that. I don't recall 9 right off the top of my head. No. I would have to think 10 about that.
11 Q In your opinion , what caused the improper 12 compaction of soils under the diesel generator building?
17 MR. ZAHARIN: I think that was asked and answered.
( 14 MR. JONES: I've got what was a report in 16 Bethesda. I'm asking him his own opinion.
16 MR. ZAMARIN& I think he said it was stated at the 17 July 19 meeting and also what we put in the 50.55(e) report 18 to NRC.
19 MR. JONESs He told me about the answer, but I y 20 vant to know what he carries around with him. What is his 21 knowledge?
22 MR. ZAHARIN My objection is that it was asked 23 and answered. If you can recall something. I guess what
( 24 you have testified to already, go ahead.
25 THE WITNESSt Because of my involvement in the I
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ALDERSoN REPORTING COMPANY,INC. I 400 VIRGIN A AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2345 l
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64 r' 1 investigation of the problem I am supportive of the reasons 2 and potential reasons that were presented in the July 18 3 meeting. In other words, I concur with those reasons.
4 BY HR. JONES: (Resuming) 9 5 Q Do you recall what those reasons are?
6 A I can recall several of them, yes.
j T Q 'ie have over-reliance on testing. Do you recall 8 any others?
S A As I recall, we considered such things as the 10 full-time inspector on th e si te --
the f ull-time 11 geotechnical person on the site. As I recall, we 11 considered, or listed as a potential reason, the lift 13 t h,1ckness. There were several reasons"and I would have to i 14 go back and read them to list them all again.
15 But I was supportive and I am supportive of the
. 16 rea sons. tha t we listed.
17 MR. JONESz I have nothing further.
18 ER. ZAMARIN: I have no re-direct .
19 (Whereupon, at 5:10 p.m., the deposition was 20 concluded.)
9 21 p
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