ML20151B319
| ML20151B319 | |
| Person / Time | |
|---|---|
| Site: | Midland, 05000000 |
| Issue date: | 10/15/1980 |
| From: | Kane J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20150F172 | List: |
| References | |
| FOIA-84-96 OL, OM, NUDOCS 8012100660 | |
| Download: ML20151B319 (209) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 .
)
IN THE MATTER OF: )
5
) Docket Nos. 50-329-CM CCNSUMERS PCWER COMPANY ) 50-330-Of i
) 50-329-OL (Midland Plant, Units 1 and 2) ) 50-330-OL
)
i The Discovery Deposition of JOSEPH D. KANE, 2 a witness herein*, taken pursuant to Notice of Taking Deposition before Matthew W. Betz, CSR-2010, Registered Professional Reporter, a Notary Public within and for the County of Wayne, State of Michigan, at The M amara Building, Detroit, Michigan, on Wednesday, October 15, 1980, ccamencing about 9 :05 o ' clock
., in the forenoon.
~~
VOLUME III
~. 4 APPEARANCES:
ISHAM, LINCOLN & BEALE (By Mr. Ronald amarin and Mr. Alan S. Farnell)
One First National Building l
., Chidago, Illinois 60603 and
.. JAMES E. BRUNNER, ESQUIRE
,/ 212 West Michigan Avenue Jackson, Michigan 49201
.. Appearing on behalf of Consumers Pcwer Ccmpany.
l WII.LIAM D. PATCN, ESQUIRE UNITED STATES NUCLEAR REGULATORY CCMMISSICN
. Washington, D.C. 20555 Appearing on behalf of the Nuclear Regulatcry Commission.
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CONTENTS I WITNESS PAGE Joseph D. Kane .
l
.s Cross ?v==4 = tion by Mr. Zamarin, continued 3 .
EIEIBITS i
Consumers Power Exhibit Number 16 139 ee GG e
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3 KANE Detroit, Michigan 3 Wednesday, October 15, 1980
- About 9
- 05 o ' clock , A.M.
5 - _ -
- J0SEPH D. KANE, having been previously duly sworn, testified further as 3 follows
- -
?
D CROSS EZAMINATION BY MR. ZAMARIN (CONTINUED) : ,
.; Q Ist the record show that this is the continuation of the
.2 deposition of Joseph Kane. Mr. Kane, you understand that you 3 are still under oath?
.J A Yes.
.i Q Before we leave the matter of the contract between the Corps
- 7
. and the NRC, a portion of which has been marked Exhibit Number
.5 7, I note that on Page 3 of the contract it states that the
,/ 'i
. review to be done by the Corps should be conducted in accordance N with NRC standard review plans Section 2.5.1, 2.5.2 and 2.5.4
. Were there any other guidelines or specifications in addition
.2 to those that wera. provided to the Corps for their use in their
.. consultation on the tiidland spill issue?
.. A To my recollection in that same document we point cut that
.' additional guidelines an.i regulatory guides -
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4 1 10LW:
2 Q (Interposing) : Wait, before you go on are you saying in this 3 document that I have here there are others? Could you find 4 those and identify them for me? ,
5 A The next sentence down after which you have read.
6 Q Why don't you read that sentence. ,
7 A Specific guidance on design methods which are acceptable to O the NRC staff that have been made available to applicants in 9 a. design include regulatory guides 1.132, 1.138 and 1.70, 10 Section 2.5.
- 1 Q You consider those additional guidelines ' for the Corps to
'2 utilize?
'2 A I consider them additional guidelines to assist the Corps in
'i their evaluation.
'3 Q Ckay. Other than the ones that I read earlier and the ones
'5 that you just read, was there any other guidelines in the form 17 of guidelines or specifications or standards provided to the 15 Corps by the NRC7 13 A I think we have furnished additional standard review plans, f 20 those portions dealing with the overlapping with structures, (
l 21 sections 37 and 38, and I think we may have furnished Section V
\
s h 2.4 as well.
U C What would Section 37 have told the Corps?
i-A Portions of 38 and 38 talk about the foundation design, the II loading of the structures which are imposed, the type of at-- - : 5 -
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5 i KANE 2 foundations that have been designed and it also gets into the
! dynamic loading that the structures are being designed for.
4 Q What would 2.4 tell them?
3 A 2.4 has to do with the information needed for hydrologic i design.
Q What do you :nsan by 'information needed for hydrologic design?
i A In engineering the effective ground water influences are i design, and knowing the variations in pond levels and ground 3 water levels is all information that you would look at in 11 evaluating a foundation design.
- 2 Q Eow does ground water level affect foundation design?
3 A It would affect the level that you can anticipate ever the 14 plant life. It could affect settlement. It could affect
- 5 bearing capacity and it could affect soil stabi1.ty.
'i Q Tell me how it could affect settlement -- I am sorry , . 11dn 't
- realize you were not finished.
- 3 A Also it would affect liquidification.
/
- 3 Q Tell me how the ground water level would affect settlement 3 over the life of the plant?
A A higher ground water table would bring a bouancy to $n 2 soil and reduce the effective load of a structure, so a higher or lower ground water table could either reduce or increase settlement.
Q Is there any other way that ground water level could affect
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6 i KANE 2 settlement?
3 A Yes. Some soils exhibit a potential for changing its soil o structure upon wetting, upon saturation'. ,
5 Q What kind of soils would that be?
3 A An example would be a loess,1-o-e-s-s, to where upon satur-7 ation there is a collipse of the soil structure and there 3 would be significant settlement.
9 Q Are there any other kinds? Are there any soils which you
'. 0 are aware of on the Midland site which would be in the nature
'. ! of a loess, and that is a. soil that would change its nature 12 upon wetting?
'3 A The soile. at the Midland site would not be considered a loess ,
- i
. but this was suspected because the' plant fill.may have been
'3 placed dry of optimum so that the ground water table or a i
water table that would develop off of seepage developed it 17 could saturate the dry plant fill soils and cause additional 13 settlement. -
?
Q You say it was suspected. Is it still suspected that that is 7 n
the case?
.. t '
A We are trying to evaluate in the Diesel generator building ,
U the zone of soils within a 6 to 7 foot depth below the E foundations and trying to determine whether they have in fact
'i been saturatsd by pond seepage.
II C Ckay. We have scme evidence so far, don 't you, that the ac: : s. =s :
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7 1 KANE 2 ground water table has risen to at least within that area, 3 to within about three feet of the foundation?
4 A We have piezametric levels which showed it to have risen 5 within three feet of the bottom of the foundation level.
6 The question we have is that piezometric pressure being influenced by the surcharge load and whether under normal 3 seepage it did not get to that level but at some icwer 3 ;. . elevation lis around elevation 622, 623.
.0 Q As opposed to 6257
- ~.
. A That's correct.
2 Q okay, so what is the staff doing right now in its efforts to
.I determine whether in fact ground water table has been as high
'. 4 as 625 or had a maximum of 622 or 6237
'. 5 A We are asking consumers to take additional borings , particularly l .i in this zone as well as other zones and to run consolidation
.~ tests where this material in tlie consolidation tests would
'. 3 be saturated and to study its settlement behavior under that
,e !? saturation.
.T MR. PATON : Off the record.
. (Whereupon there was a short recess after 20 which the deposition again continued.)
- Q (By Mr. Zamarin, continuing): You are aware, are you not, h that during the time of the pre-load program the elevation of
.5 the cooling pond was raised to its maximum level?
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8 i KANE 2 A Yes.
3 Q And from that would you expect there to have been ==vi=um
- recharge of the fill around the Diesel generator building ,
5 that one would ever expect fresa the cooling pond being 3 maintained at that maximum level. I think it was 6277
.- A You would expect if'it were held long enough to develop a 3 steady seepage of that level which would take considerable 3 amount of time. .
- 0 Q In your opinion was it held at the 627 foot level long enough
- 1
. for there to have been that maximum s,eepage during the
- 0
. surcharge?
- 0
. A During the period of the surcharge, no.
- 4
. Q Do you have an opinion as to how long it would take before
'. ! there would be maximum seepage recharge of the area around
'i the Diesel generator building from the cooling pond at
.~ elevation 6277 13 A I do not have an opinion on how long it would take , but I .
'. ? would think with further studies you could address that. [
l '.
20 What makes me feel it did not is the behavior of the piezemeters { t
-- before and aftar the surcharge was removed. k i
.0 Q I'm going to get into that. You are saying that the behavior I
- of the piezcmeters before and after the surcharge was removed leads you to believe that there was.not maximum seepage f cm
!! the cooling pond and recharge of the Diesel generator building ac: -
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9 1
KANE 2 fill?
3 A That is correct.
4 Q Is there any other reason why you believe there was not 5 ==vimum seepage from the pond during the period of the 3 surcharge?
~
A That is my only reason. Other types of analysis could be 3 done to prove that out.
3 Q Permeability studies and things of that nature?
A How long it would take for that area to be saturated , yes.
~
Q What other type of studies besides the permeability and pump
'2 tests, are those the kind of things one would do?
'U A The permeability would be an input into a study estimating a the time for steady seepage to develop.
3 Q Anything else that you could do in order to determine tha' amount of time?
I' ..
A You say that I could do?
Q That one could do?
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'I A okay. I would say between that study and the piezometers you should be able to come to a good conclusion.
P-Q Okay. Do you mean the piezometers that were in place during the surcharge or piezometers that you would place around the l
building during the study?
A Piezometers that have already been placed.
Q I wasn't clear on that. Piezameters that have already been
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10 1 KANZ 2 placed and readings that have already been taken or the read- ,
3 ings that you would take as you were conducting the study?
4 A The readings that have .iready been taken. ,
5 Q which you testified in your opinion led you to believe that i there had not been maximum seepage from the pond, is that -
I right?
3 A* That is correct.
D Q okay. I might as well ask you now, what was it about the U behavior of the piezemeters before and after the surcharge l '- removal that demonstrated to you that there was not ==v4 mum' 2 seepage frcs: the pond?
15 A Before the surcharge was placed there is a level which appears
'i in the piezameters which appeared to be reflecting seepage 13 from the cooling pond and then ence the surcharge was placed
'I there is an increase in the piezametric level which is ny opinion is responding to both the surcharge loading and further development of seepage while the surcharge load is .
' E held and the piezometric level is being influenced by tha'
)
I loading. Cnce the surcharge load is removed there was a {
l drop in the piezometric level, a rebound , and then another k U
\t drop and that second drop in ny estimation is to the level ,
2 which is being influenced by development of seepage off the pond.
t Q Would you have expected a drop and then rebound in the 4: : - : 4 : = 4 :
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11 1 KANE
- piezametric level upon the removal of the surcharge?
3 A It depends on the type of soil. I would expect a sa.all drop 4 but I would also expect upon recovery the level stabilizing 5 because the level it would have recovered would have been 3 influenced by the ground water regime that existed at the time.
3 Q In othar words, it would reach some kind of an equilibrium?
3 A Yes. -
- 0 Q Okay. When you say that you would have expected sans drop and some rebound, with regard to the Diesel generator
'2 building was the drop greater than you expected, the initial
~
drop?
Yes.
+ A
.2 Q And was the rahound greater than you expected?
- A The rebound is to a level which I think is reflecting the
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poc1 pressures that are in the soil and it goes back to a 3 level which I think has been influenced by the surcharge f 'i
- loading.
- : Q Is it possible that a building can rebound more than once,
! *- that it may be continuing to rebound even today?
12 A Depending on what conditions you impose it could rebound more than once.
i Q Ckay, taking the conditions that you know to have existed 2
with regard to the Diesel generator building , is it possible ,
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i 12 1 KANE 2 in your opinion, for the building to have rebounded as shown 3 by more than one drop in the piezometric level?
4 A I think we are confusing two things. We are talking about 5 the structure rebounding and the piezameter level rebounding. -
I would not expect a structure to rebound more than once after 5
7 having been under load unless you introduce sczne additional O condition that could cause that.
i Q okay. Let's talk about rebounding of the piezometers then, 1
10 In your opinion could there be some reason for the second
- drop in piezometer level other than that being influenced by 2 seepage from the pond?
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A The second drop, the drop itself I don't feel is influenced
- by the pond. The drop itself, in my estimation, is the soil
'3 after having been relieved of the surcharge load is now d seeking the pore pressures that would develop under the I
natural ground water regime, so the drop is ridding itself
- 3 of the extreme pore pressures that it had under the surcharge
'2 loading. [
= The second drop is, as well as the first drop, is what you Q {-
are referring to now as having dissipating the extreme pore \a
\
2 pressures that it had under the surcharge? \ t A That is correct.
Q And how does that tie in to your feeling that there was no
- 3 maximum seepage from the pond achieved?
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13 i KANE
- A well, if the maximum seepage had developed then when it
, 3 rebounded I would expect it to have stabilized at a level 4 which is being controlled by steady seepage off the pond, 3 but it didn't, it dropped to a lower level and then proceeded i to rise gradually after that period which I am interpreting
~
to be steady seepage still developing off the pond level.
i Q Have you reviewed all of the piezometer readings in reaching 3 this conclusion?
10 A I have Locked at all the piezometer readings.
2 Q and have you considered them all in r'eaching this conclusion?
'0 A Yes. -
l3
! Q Upon what do you base your assuzaption or conclusien that the
'4 drop in piezometer Level after surcharge removal would have l'
been something other than what you observed or what was
'5 observed at the Diesel generator plant? ,
A I don't understand your question.
l .
Q ckay. You indicated that when the surcuarge was removed 1E
/ there was a drop, a rebound and a second drop in the
- Z piezometer readings and then after that second drop there was 1
some increase and then it leveled off, is that what you are U saying? ,
A After the second drop it went to a level which I think was being controlled by steady seepage development and af ter that
- f second drop there is a gradual rise in the piazemetric level i : - - : 2 -a : : s ;
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14 1 KANE
- which I think is being caused by further development of 3 steady seepage off the pond.
4 Q Okay. I believe you also stated that there was something .
5 about the magnitude of the drop, the initial drop which was ~
5 other than what you would have expected? .
~
A In response to your question I indicated that I thought some 3 of the piezameters reflected a drop more than what you would 3 expect.
- 0 Q And on what do you base that conclusion?
.1 A on a judgment that the soil has gone out of primary consoli-i
'2 dation in a secondary consolidation and there are no excess 1
-d pore pressures unless it were a highly expansive soil which g
'.i we do not have at Midland. I would not have expected that I 15 much relief under the surcharge loading.
'i Q Do you know if any data was taken and kept with regard to the l'
behavior of the Diesel generator building during this period 15 which there was a rebound and during the surcharge removal?
'I A You have both settlement data and piezemetric data.
(
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Q Does the settlement data indicate an actual rebound in the ?
E-structure? s
'2 '
A After surcharge removal? t Q Yes.
A The structure by your =easurement was shown to rebound, a
Q Do you have any reason to doubt those measurements?
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KANE 2 A I have no reason.
3 Q Okay. Have you ccampared in any way or considered the amount 4
of rebound or degree of rebound of the structure in arriving
. 5 at this conclusion of purs that the amount of rebound on the
- i piezemeters was higher than one would have ex'@-d if in 7
fact the 5111 were in the secondarf consolidation beneath 3 the building?
3 A My judgment of going into secondary consolidation is not 10 entirely based on your settlement readings. The two M
controls that you had and which is aczmally employed in 2
i evaluating the settlement and consolidation, the piezometers U
and the settlement readings themselves are both information.
14 3 There is a question in my mind about your settlement readings 3
because of other information you have given us , and that when
..:' I questioned why the pore pressures developed to a level I
which you could expect to be much higher under the surcharge n
loading it was indicated to me that it was because the soils s
were very pervious because it was felt that they had been
,r placed dry of cptimum and were essentially clay in balls and
= slabs and that there were cracks in between these clay balls U
and when loaded it drained freely through these cracks. My feeling then is I would not expect a fill of that type to behave in the manner that your settlement readings reflected 2
because to me it would seem reasonable that there would be a
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i 16 1
KANE period of consolidation where those cracks were closed by 3
the leading and then you would go into the normal consolidation 4 process. .
All right, are you talking about there being.that period of 3 Q s
consolidation during the surcharge? . .
~
.- A That's correct.
3 Q okay. If there were rapid dissipation of pore water pressure ,
3 however, resulting from these cracks allowing rapid drainage-
.2 wouldn't you expect that pore water pressure to be dissipated R and you would no longer see then the high = level of dissipation
'2
. that you expected?
'.3 A I don't feel the understanding we have of a primary consoli-
.6 dation behavior fits the type of conditions that we think
, .3 we may have at Midland. The fact that you experience primary i consolidation and then the change in getting into the secondary consolidation to me does not fit the conditions that we say
'i
. we might have had in that foundation of the Midland soils.
P.,
'3
. Q Explain to me again then how it doesn't fit the conditions t:
20 that you believe or have been told that we have with regard br.
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- '. to the soils at Midland around or under the Diesel generator
.2 building? .
\
- A ::t would seem reasonable to me that if you have a soil that
.* is heavily cracked, enough to permit free draining and no 1 development of. the pore pressures , that initially all the
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17-I KANE 2 consolidation that you would experience would be a closing of 3 those cracks and that may have been the initial consolidation 4 that you witnessed and then the change , what you are 5 interpreting to be the secondary consolidation could still be i the primary consolidation of the clay under the surcharge
~
- loading.
3 Q Would that be consistent with a straight line extrapolation 9 -
of the Casa Grande log time sitting curve?
10 A The Casa Grande method does not anticipate consolidating a 1
dry sample. It talks about a homogeneous clay sample and' 12 so applying the Casa Grande method to these conditions could
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be giving erroneous results.
'4 Q In what way?
13 A The way I thought I have explained in that once you have ~
closed the cracks the consolidation that now will take place
~
~
may now be primary consolidation of the clay itself and so there may be a period where you may have additional primary
,/ consolidation and then eventual secondary consolidation.
Q All right , during that period of continued pri=ary consolida-
~
tion after the closing of the cracks that you have hypothesized, would you expect a settlement versus log of time curve to ,
approach a straight line?
A Given enough time I would expect it.
Q Given enough time you would expect it to approach a straighu
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18 1 KANE 2 line at which time would you than say that it was into 3 secondary consolidation?
4 A I would expect it to go into the virgin consolidation line, ,
- the straight line , and if held long enough than go in the -
i secondary consolidation. . .
~
Q I see. My understanding of that Casa Grande log time fitting 9 curve is that when it approacias a straight line then if you i extend that line and take a tangent of the curve that the M intersection indicates the peint in time when primary ,
- consolidacion was completed. Is my understanding wrong?
A Your understanding is correct, but Casa Grande theory does
'2 not approach the closing of cracks in a dry soil.
4 Q Who told you that there were cracks in the soil?
'3 A In a discussion at one of our meetings, Dr. Peck.
I Q Dr. Peck told you that he believed or that he had information 1~ that the clay was in slabs and balls and that there were 15 cracks? .
'3 A In responding to my question about why pore pressures had [
\
not developed to a level that you would expect under the l T- surcharge he indicated that one of the reasons may have been s
- this cracking and d "f clay ball theory. \
.\
C Q Do you recall wnen that =eeting was?
A I think it was the July 29th, 1980 meeting.
Q And are you certain as you sit here now that that was the
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I 19 1 KANE
- explanation that he gave for the rapid dissipation of excess 3 pore pressure?
4 A To my recollection, yes.
3 Q Was that the first time that you had ever heard of these or 3 of this dry of optimum cracked clay ball situation with regard to the soil under the Diesel generator building? -
3 A In my own experience it was the first time. Having been 3 given that explanation I discussed it with others who
. .) indicated that based on their observations of test pits it wac indicated to them previously that it had been placed dry.
. Q okay. Tell me those others with whom you discussed it who d
- 3 told you that based upon observations of test pits that it
. had been placed dry of optimum?
- 3
. A Lyman Heller.
'. 3 Q Anyone else?
'. 7 A .Not that I recall.
l
'. 5 C You indicated that you had discussed this matter after l
l/ *3
. hearing it from Dr. Peck in, you believe, July of 1980, t
2' and then with others , and would that have been with one l
other referring to Lyman Heller rather than others?
l l2 A Yes.
.2 Q And that he said that based en observations of the tesn pits 3 he saw that the fill had been placed dry of optimum, is that
!! right?
- 3. -
- = i e
20 i KANE 2 A Yes.
3 Q In your opinion as a geotechnical engineer would his i observations of the test pit that indicated to him that the .
5 fill had been placed dry of optimum mean that there were these -
i clay balls and cracks which you have been telling us about? .
~
A To the best of my recollection 3.t was indicated that he saw 5 cracks.
Q So your recollection is that I.yman Heller said that in 3 examining the test pit he saw cracks?
l-A That is correct. ,
I Q And do you recall whether he said this was in a test pit near the Diesel generator building?
'4 A It was in the plant fill settisment area, problem area.
13 Q ' But you don 't know which test pit he was talking about?
A I don 't know, no , which test pit.
'~
Q Ckay. In your opinion if the soil had been saturated prior ,
s
~~
to the -- prior to or during the surcharge program, would .
this then have changed the situation with regard to the I
\
soils placed dry of optimum and the cracks? {
A You have added two words. " Prior to" and 'during". I think
\..
i the behavior cay have been differsnt if it had been done '
.-)
- I prior to surcharging than it would have been with the surcharge imposed and then saturated.
s U In what way would it have been different?
Q
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21 1 KANE 2 A The surcharge loading is attempting to close the voids in 3 the soil. Developing steady seepage off the pond is attempt-4 ing to bring water into those voids and so they are competing 5 for that space in the voids and it would have been better, in 6 my estimation, to have stabilized the saturation before doing the surcharge.
3 Q okay. Ycu say it would have been better but how did it in 3 fact differ?
".o A Based on the piezametric observations that I have looked at
. 1 I have reason to believe that the 'aturation and steady
'2
. seepage was still developing. .
13 Q You indicated earlier though that there was some level to
". 4 which you felt the water, .the ground water table had at least
'.3 risen, and that, I believe, was at 623 or 6227
'i
. A That is correct.
".' Q Okay.
'. 5 A It varies with the location and the distance from the pond.
19 Q Ckay, and the foundation, the base of the foundation is at f
23 627, is that right?
- A 628.
22 Q 6287 so at least with regard to the soils at or below 623 3 would you agree that they had been saturated?
24 A I would agree that they had been influenced by the pend.
23 Whether they had reached a full saturation or not, I do not at: . : 2 . . . c=s. .:
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22 I KANE know.
3 Q Have they been influenced, in your opi. don, to the point 4 where this problem of fill having been placed dry of optimum .
~
5 and exhibiting cracks would have been eliminated?
i A I really don't know, but I do know a way of resolving that. .
~
Q That's not what I'm asking you. You say you don't know?
! A Well, can I finish my answer? ,
-' Q Well, "I'm saying if you say you don 't know then I have another 12 question to ask you before you tell me how you can' resolve it.
A Well, I think the reason I don't know and don't feel I need ,
12 to know is because I can resolve it in another method.
3 Q All right. What is that other method?
+ A The other method is to do the additional borings, take the 3 undisturbed samples, run the consolidation tests on saturating i
5 samples and then we would know what the behavior is.
l LI l Q With a little more work and a little analysis couldn't you i
e come to an opinion as to what the condition of that soil was ,
3 without the borings? ,b i
l A No, I don't think you can by analysis. I thin'c you must go f; and get samples and establish the moisture centent.
Q Okay. Do I understand you to say that it is beycudycur ,
i I expertise as a geotechnical engineer to reach a conclusion as to whether the soil, based on all of the information you know l
would have been influenced enough by the ground water table at: : s.a -
- 2 i
.. ...., . . . . . .. r ... ,
23 1 KANE 2 at elevation 623 and below to determine whether in fact the 1 affects of fill possibly having been placed drf of optimum 4 and these cracks then would be eliminated?
5 A If you make it 623 I think we are in the zone where there is i question.
Q Okay, let's maka it'622 and below then. Let 's =14 n4 nate that i ambiguity because you said it was up to at least 622, so
) let's make it 622.
- 0 A I think there is a good chance that it may have been saturated,
'.* but I don't have to wait with thinking, I cal.1 prove it by
'.2 testing.
'l Q okay. That still really doesn 't answer my questien, though.
- 4 Ch, maybe it does. Are yett saying that you think there is a
'.5 good chance that it was saturated at 622, saying tnat in fact 3 you do have expertise as a geotechnical engineer to arrive
'7 at that conclusion based upon the information available to
'5 you?
13 A Yes.
/
. d Q okay, and another question related to that is if it had been I '. saturated and had been influenced by the ground water table
- would that then have eliminated these effects that you have i described that would have resulted from the possibility of
!4 fill being placed dry of opt mum and this cracking?
! A No.
4 : . : , . ,-r 4
.t1>1s- , us ..
F
24 i
RANE 2 A No? Why not?
3 A The cracks which may have existed because of the placement on
- the dry side existed when this zone was becoming saturated.
5 The surcharge loading that is than applied would cause these ,
4 cracks to close, but the further settlement that would be .
- primary consolidation, may still be within the soil and yet 3 to occur.
? Q Before the problem that you have described with cracks and
- 0
. clay balls and placement dry of op*4 mum, would you expect the
'. ; Casa Grande log time fitting method to properly describe the
'. behavior of soils beneath the Diesel generator building
'. 3 during the pre-load?
'. 4 A Yes.
.3 Q You say that you asked a question and received an answer frcza i Dr. Peck at what you believe was that July 29th,1980 meeting ,
. is that correct?
.3 A That is correct.
'2 1 Q In your opinion does Dr. Peck agree with your interpretation (
20 that the reaction of the piezemeters as not having indicated ;
i 21 dissipation of excess pore water resulted from primary con-12 solidation?
2 A The one that should ar.swer that is Dr. Peck.
4 Q Well, I have asked you the question, however, it is your l
3 deposition.
c-- .: i .- t : s s ;
. a , , -- ~ s : ...u. .. 1 ,-,><
? - iJ.
25 1 KANE 2 A I do not know, however I would say on what I have heard him express about having no problems, I would have to conclude 1
- that he has, but I have had no discussions, no detailed dis cussions of this.
Q Ckay. If he in fact does disagree with you do you think that.
that demonstrates unsound engineering technique and practice on his part?
MR. PATON : I object to that questich as
. calling for pure speculation. Now you are asking him to delve into Dr. Peck's thought processes and I don't know how he can possibly do that. He has told you what he Phbks of the analysis.
Q Can you answer the question?
A Will you repeat it?
MR. 3'AMARIN : Could you read it back, please (to Reporter) ?
(Whereupon the Reporter read back the previous question.)
A No, I do not feel it would indicate unsound practice. I would look at it as a difference in a technical opinion , and I- the position of NRC is not one of just raising questions, but we have racemmended a way of resolving cur concern and I would hope Dr. Peck would entertain our suggestions and see the 2 reasonableness and complete the requested work.
~:: - -
t
..-,_-.m
26
. KANE
- Q Do you recall Dr. Peck stating at that meeting on July 29th.
1980, that piezometers behaved normally based upon his expectation of the way they would behave? ,
- A Rather the opposite. I thought I heard Dr. Peck say, and I -
have seen in documents submitted by consumers that the pore pressures did not rise to the anticipated level and they dissipated more quickly than anticipated.
Q All right, and did you attend the borings appeal meeting at
. which Dr. Peck also made a presentation?
. A I did.
Q And do you recall him saying anything at that meeting to the effect that even thougn there may have been scme degree of
.- more rapid dissipation of excess pore water ,than was antici-pated that nonetheless the piezemeters behaved just as he expected them to?
A I knew I questiened at that meeting the fact that the pore pressures which develop under the surcharge load had not got to a higher level and Dr. Peck recalled at that meet.ing that (
1 L he did not remember making that statement. I had checked our ;
documents and have found in his report a statement that says \
I
- - they did not rise to anticipated levels and dissipated quicker -
g than they had anticipated.
Q Do you have my questien in mind that I asked you? You haven't answered it yet.
O
27 i KANE A I thought I had.
MR. ZAMARIN : Could you read the question back (to Reporter)?
- (Whereupon the Reporter read back the
. previous question.)
A The question that ,you have raised, first of all, says that they, dissipated more quickly than anticipated. You are indicating that Dr. Peck made that statement and in answer to your ques-tion I also attempted to point out to you the fact that I raised the question at that meeting and Dr. Peck further
. commented on the piezemeter readings and I am attempting to point out that in the documents that you have submitted to us ,
not only did it dissipate more quickly than anticipated, it did not rise to levels that you would anticipate.
MR. ZAMARIN: Would you read the question back again, please (to Reporter)?
I'd like you to listen carefully to the quostion, Mr. Kane.
- (Whereupon the Report.!r read back the previous question.)
-- A I heard those statements by Dr. Pr,ck but those statements 4
were f,.rther discussed in the questions that I have raised. 'f; Q How =any piezometers eventually rebounded back to elevation l
I 625 or close to elevation 625 after surcharge removal?
i .- : : -
1
-_.-___._a
28
. EANE
'. A I don't know the exact number, but I know it was core than
. five.
Q And less than how many? ,
A Less than how many? I den 't know how many total piezemeters ,
- but not all piezameters are under the surcharge loading.
Q of the piezameters that are under the surcharge 2cading, *w the best of your recollection, what percentage of them f eventually rsbounded back to elevation 625 or close to it i
after the surcharge was removed? l MR. PATON: Let me have a minute.
-- MR. ZAMARIN : Not in the middle of a I l
-- question. I 2..ean, let him anser the question and then you l
. can.
.. MR. PATON: dkay.
A Your question is saying how many rebounded to 625. I don't think that is the level to which we have to indicate.
Q That's my questler..
- A Well, I'd like to answer the question, but to clarify it you (
- are introducing the 625, I am not. j'
\
Q That's right. s i>
A I would have to look at the data and determine how =any ,s
-- rebounded to 625 ar.d hov =any rebounded to othe- levels .
C Ckay. What would you use as a significant level when you say that I am using 625, what would you use?
t f
29
. KANE
- MR. PATCN: I would think since I did ask
. you to wait that you would have at least waited until I got
- back before you asked the next question.
A would you repeat the question, please?
MR. IAMARIN : Read it back (to Reporter) .
'(Whereupon the Reporter read back the previous question.)
A Would you repeat the question?
MR. IAMARIN : Would you read it back
- again (to Reporter) ?
-- (Whereupon the Reporter read back the previous question.)
A The level that it rebounds back to is not the significant level. The level that it goes to after rebounding is the significant level in my estimation.
Q What level did it go to after rebound, do you recall?
A It ranged between 622-623.
i Q In the majority of the piezometers?
~
A A good number of piezemeters did. I don't know whether it was the majority.
0 What was the absolute value of the rebound? .
A Would you define " absolute value"?
o I can't.
A Neither can I.
3 . - : : :
4
- , , - - - . - - - - - - , , - - _ ,, -------n-
30
- KANE
- Q How many feet was the rebound?
A I think it ranged between two to four and a half feet.
Q If your theory with regard to these clay balls and dry of
. optimum, and that it is still undergoing primary consolidation .
- is correct, would you expect additional settlement of the -
- diesel generator building 7 A I'd like to point out it is not my theory of the clay balls ,
That was information given to me.
Would I expect additional settlement? It is potentially possible, yes. Our request to do the addition-al borings and laboratory testing will permit that question to
.- be answered.
. Q Well, if it hasn't achieved secondary consolidation yet wouldn't you as a geotechnical angineer expect additional settlement , sir?
A That is correct.
. Q Yes. Have you seen any of that kind of settlement in the
~
diesel generator building, that kind of behavior since the <
removal of the surcharge?
A I haven 't seen it -- I haven 't seen , except for one graph, l'
the settlement records since the surcharge was removed so I
.s can't answer your question. .
- Q You don't know how much the building has settled or has been I recorded to have settled since the removal of the surcharge ,
~
- 1 . .
i .
~ _ _ _ - - - . - - _ _ _ . _ _ _ _ _ _ _ . . . . . . _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . . . _ _ , . _ . . _ _ , _ _ _ _ _ _ _ . . _ _ . _ _ _ _ , _ _ _ , _ _ _ _ _ _ _ _ _ _
31 KANE
- is tha't what you are saying?
- A We have not been provided that information.
Q Eave you asked for that information?
- e. A We have.
. Q And nobody gave it to you? ,
A I asked for it at the July 29th, 1980 meeting and I was told that information, which would include the updating of the settlement and the updating of the piezometers would be fur-
. nished to us.
. Q So as you sit here today you haven't the vaguest idea how much
'.. that building has settled since the removal of the surcharge?
A That is your word " vaguely. " I have been at meetings with
. you where I have been told thera has been no significant
.. settlement. I would like to see the records to be able to =ake a judgement on that.
.. Q Okay. Would tne fact that there has been no sigzif. cant !
i l
settlement since the removal of the surcharge be inconsistent l
/ a with your belief that the building is still in primary con-solidation?
. A No , and I say "no" because the question is is the full loading
.. that is expected under the diesel generator building , has it been applied and is it now applied. In our last visit to Midland I saw excavations, approximately six foot deep along
. the foo**"gs of the diesel generator building. M me that 1: : . : * -i
32 KANE 2 excavation is not loading but unloading and I would not
- expect additional settlement while you are doing those type of excavations. ,
Q Tell :ne the extent of these excavations? I mean, six feet deep and how many feet,long? One hundred and fifty feet long,
~
50 feet long, 5 feet? I mean, really, what are the dimensions 7 A The width of the diesel generator building.
Q How wide was the excavation? .
A In my estimation it was around six feet wide on tla part that
- I had seen, and I was told there werg excavations inside the
'2 building as well which I had not seen.
Q Okay, who told you that?
A General Gallagher.
Q Did he say he had seen them?
A He said he had seen some , yes .
Q And what was the date of this visit where you saw these excavations? .
A I don't recall the exact date. It was -- f Q (Interposing) : Approximately? k A It was the day before the meeting in Midland , and it was t
August 28th, 1980. f Q Now, you say that you saw excavations that ran the width of \
.L the diesel generator building about six feet deep, six feet 1 wide , and how many of these excavations did you ses?
- t. : , :: ! :
33 .
KANE
- A one.
. Q Just on one and of the building?
A Yes.
Q Do you know how long that excavation had been excavated?
A I do not. .
Q Did you ask anybody?
A No.
Q Would that be a factor in your deta=4a4ng whether in fact the insignificant amount of settlement was inconsistent with L your opinion that the building is still undergoinge the soil
.. is still undergoing primary consolidation?
- A Would you repeat the question?
MR. IAMARIN : Would you read it back ,
please?
(Whereupon the Reporter read back the previous question.)
.. MR. PATCN: I object to the form of the l'
e question because you had asked him to assume on a prior
{ ,
occasion that there has been no sgttlement of the building
- and I think he indicated that he had received no information i
.. in that regard , so -- .
MR. ZAMARIN (Interposing) : I never told I
him there was no settlement. He said it had been reported
.: at meetings that settlement was insignificant. Those are your i: -
- , :s . .
, ,...r: . . . . ., .. .. .....
_ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . . . _ . _ _ _ - . . . _ _ _ _ _ _ . . - _ _ ~ _ _ _ .
34 KANE
- Witness's words,'not mine.
MR. PATON: Well, you are now assuming that that is a fact and I think the Witness indicated that he 5 didn't know. He did not receive reports in that regard.
MR. IAMARIN : Fine, if he can point me to <
anything that suggests that is not true let's do it now, if that is what you are suggesting, let's get it out or if you have got it let's do it and put it out otherwise I want an
.. answer to my question. You can note your objection on the
'.. record and let's move on. If you have got it put it out.
'2 MR. PATON: I am not answering questions, 1
I am objecting to your question which I have done.
~,
MR. ZAMAR.IN : When you make a statement
.' like that you better be prepared to back it up.
Q (By Mr. :amarin , continuing) : Do you have any reason to
~
believe that there has been more than insignificant settle-
.4 ment at all since removing the surcharge?
^
- A I have no reason, but I do not have the records . . s
( !! O Okay, but you have been told by Consumers Power Company that 1 -
lo it is only undergoing insignificant settlement during that
- s time? .
.2 A I have been told.
- Q okay. Can you answer my question that I asked earlier to 2 which there is an objection as to form?
1 st: . : s .-s s :
.e2.--.<- ,. ..., . .e, . ;.,
/
l 1
35 KANE l l
2 A would you repeat the question?
MR. AMARIN : Can you read it back
_ (to Beporter) ?
- (whereupon the Reporter read back the
- previous question.)
A The length of time the excavation that I saw existed would be a factor, but there are also other factors which lead me to question whether we could expect additional settlement. One
- . of those factors is in evaluating your information on the loading that existed in the structure at the time of surcharge ,
.; plus the surcharge loading, whether that did in fact, that
'cading introduced stresses in excess of the maximum leading
.. that we could expect in the future.
- What I am attempting to indicate is that I
based on information you have furnished us in response to question number four there is a question in our mind whether
.: the loading that was applied at the time of the surcharge did
.! cause the stresses in the soil to be exceeded.
.' Q In other words, whether there was overeenselidation as a result of the surcharge, is that what you are saying that you
- doubt that or you question it?
i .. A We are questioning the magnitude of the load which existed j
at the time of the surcharge and the stresses that were
.' introduced in the soil at that time versus the future i t: .: 4 : =a :
. . ,. .s; .. 1., . .s, .--.,
,o . 4
.c .
9
_ . _ . . _ , . _ _ _ . _ ~ _ . . _ -..-,.m_ . _ _ _ _ . . _ _ _ _ - . . _ - . _ , _ . _ _ , - - _ - _ _ _ _
36
". KANE
- maximum loading and whether that would produce stresses in
- excess of what was existing at the time of the surcharge.
Q okay, let's go back, however, to my question about whether ,
i you considered the reported insignificant settlement since the
- time of surcharge removal to be inconsistent with your con-
- clusion or belief that the soil under the diesel generator building is still experiencing primary consolidatica and you have indicated that with regard to that determination that .
. you saw an excavation and that that perhaps led you to believe
.. that the insignificant settlement isn 't all that important, and then your appraisal of whether in fact it is still under-going primary consolidation, is that what I understand you
-.; to say?
- A Your question is much too long.
Q " dell, I think that you can handle that.
A ' dell, then, how about repeating it.
2 .v.R . ZAMARUi: Okay, could you read it
'." back?
20 (Whereupon the Reporter read back the ,
- - previous question.)
I- A Whether I would still expect primary consolidatica is tied .
- to the leading that has been imposed. If the surcharge lead-
- ing had been held longer we may have caused additicnal I' primary consolidation. If the leads which now exist in the i :
- . : s -
- ss :
l
, ... . ,, .s-.--..
t ee 1
37
'. KANE
- field' are less than the 'nawinina loading that we can expect
- under operation then I could still expect primary consolida-tion.
Q okay. If the loads that you would expect in the field --
strike that.
4 If the loads that existed during the sur-charge in fact did stress tne soil in excess of that which the normal operating loads of the building were stressing,
'. would your opinion change?
'. A What opinion are you referring to?
- Q Your opinion that there would still be mere primary consoli-
- dation.
- A If the surcharge, and I emphasize the 'if," if the surcharge 2 had been held long enough to permit full dissipation of i
excess pore pressures then I would not expect additienal 7 primary consolidation, if the loads in the future were not
' going to exceed that level, but I have indicated the behavior
- of the piesometers is indicating to us that potentially we
! - may not have been out of primary consolidation.
I i
Q Ckay. Are you aware of any calculations that can be done to i
- - determine the length of time that a surcharge need remain in l
' - place in order to affect transition frem primary into secondary consolidation?
i There are methods to estimate that.
A 1
- : :: . : a u < $ i .
- ta**e:. e,:.; , , . ,. ,,
i f
38
. KANE 2 Q I am sorry?
A I am familiar with what is provided in the Navfacs DM number seven. ,
O In the Navfacs DM number seven? First, can you spell Navfacs?
A N-a-v-f-a-c-s , it stands for Naval Facilities .
Q Do you regard'that to be an accepted method of calculation?
A I consider it to be a method that would be an initially good indicator, but the actual proof is in the field and how it
. behaves anii I look at the piezemeters and they introduce
. questions whether I have gotten rid of all of the excess pore
.. pressures.
Q So in your opinion then the actual proof in situations like this is the field testing data and also to any up front calculations that might predict that?
A If the field tests are held long enough to where there would
- he no questions, yes.
Q Did you perform one of these Navfacs calculations with re-4
- gard to the surcharge of the diesel generator building?
A No . Did consumers? ;
Q Well, maybe when you get to take my deposition you will have a
- right to ask =e that question. ,
- Did any of your consultants perfor= such
+
a computation, to your knowledge?
!* A I do not know.
t c: . : i c. -
--e - - - - - , . , - , . - - - , - , , ~ , - ---- .__ -._ _ . , , _ _ _ _ . . _ __ _ _ _ _ _ _ _ _ _ _ _
J2
- KANE 2 Q You testified earlier that you had not been provided with
- data with respect to settlement of the diesel generator
- building after removal of the surcharge, I believe, is that correct?
. A That is correct.
Q Okay. I have before me a report dated September 14, 1980, and it is entitled Discussions of the Applicant's Position
. on the need for additional borings for Midland plant, units one and two, Consumers Power Ccapany, Docket numbers 50-329
,, and 50-330.
- ,; Do you recall ever having seen a document
".; similar to this before (indicating)?
.. A Yes, I have.
.. Q Okay, and did you read it?
.- A Yes.
. C Ckay. I refer you to Figure 1, which is on the second page
.; following page numbered 16 of this document and ask you to
'. .: tell me what that top plot on Figure 1 i=dicates to you? !
1 I
- '. A The settlement history of the settlement mcnument outside of
- . the diesel generator building. i
- C I am sorry, ycu said outside of the diesel generator building?
. A Yes.
. C *'ould n that indicate to you settlement of the diesel genera *wr
. building at that point?
1 t: . : .
40
'. KANE
- A To my recollection you have monuments on the diesel generator 3 building itself so why not read those instead of one outside?
. A I'm asking you a question, don't ask me questions. ,
MR. PATON : I don't think you have to -
i talk in that tone of voice to the Witness.
MR. ZAMARIN': I will talk to him any way i I want. I want him to answer my questions.
- MR. PATON : You ana getting pretty hostile
. this morning and I don't see that there is any need for it.
.. MR. ZAMARIN : I den't like the Witness
.- being flip with me. I want him to answer my questions .
- MR. PATON : I believe you are being as
- - flip with hi= as he is with you.
.: MR. 2,VtARIN : You have to answer my 1 -
questions that I ask, that is the way it goes.
MR. PATCN : He is answering your questions fairly, and you don't need to browbeat hi::: or
\ l
- get hostile with him.
MR. IAMARIN : I will act the way I feel ,
- I should act, and if you don't like it take him out of here.
- - Q (By Mr. Zamarin, continuing)
- Would you answer my question? .
- A would you repeat the question?
MR. ZAMARIN: Could you read it back l
I (to Reporter) ?
i: : - : 1 -
- e s :
r: *sse; ss ** , * <*te o l
i l
41 KANE 2 (Whereupon the Reporter read back the previous question.)
- A It is the settlement behavior with time of the settlement 5
marker outside of the diesel generator building. That is
~
what it would indicate because it is not in the diesel generator building.
Q What does that indicate to you?
': A The settlement at that location.
. Q The settlement of what?
- . A of the fill at that location. ,
. Q so when you --
.2 A (Interposing) : Could I add to my answer?
. Q Sure.
- .. A I think when tnis discussion initially started I said all 5,ut, one settlement reading had been furnished -- excuse me , the other way around, we had been furnished only one settlement
.4 =enument since the surcharge removal and that is the one enat I recall.
f, .
Q ch, I don't recall you saying that. I thought that you had
- . said '--
2 A (Interposing): I hope the record will show that I said it.
l Q So that only insignificant settlement had been reported, and
- is it your understanding that the settlement shcwn in OG 3 1
.? is off the diesel generator building and that when you read
- c: : 2 - -
e
- - - - - , _ _ _ . . - . - . _ __ y _ , . - __..__._._,.n,. ,, , , _ . - _ , , _ _ _ . _ , . , _ _ _ . . - _ , _ , _ . , . . - . - , - . - - - _ .
42
. KANE
- this , as you sad this (indicating) is it showing other
- samples of soil as opposed to settlement in that point in the building? ,
A Prem that figure I would assume that is off the building. -
Q And is that what you have assumed all along even when you read this the first time and perhaps the second time you read' it if you read it twice?
A Reading that document alone that's the assumption I would make.
. Q okay, and is that the assumption that you have made all along?
. A '4here DG-3 is I would have to go back to other documents to
'.. know exactly where it is.
Q I haven't asked you exactly where DG-3 is. I just asked you l
'.. if you have continued and if you have always .made that assu=p-
.' - tion that DG-3 is a marker off of the diesel generator build-l ing?
.' A I have attempted co respond to your questien by saying that that document to me would indicate that it is off the diesel a generator building. You have provided other information which
.. would show the location of all the markers and then I would ,-
- have to be influenced by that information.
l C ch , I see, okay, so as to your present recollection as to .
whether you have assumed it to be off or not you really den't
- have any, you'd have to icok at other information that we have provided you to see what your understanding has been, is that
- : : , :a :
-- .-,..-.m.- , . , - . . - - - - _ - ~ _ . - _ . _ . . _, _..-.__.-_-,--__.y_ _ . .
43 1 ICANE
.; correct?
- A That is correct.
Q okay. When you say that -- strike that.
A building settlement mark, does that
- - indicate a marker that -- a monument that is on the building?
A It could.
Q What else could it mean?
-re- - A If you were checking settlement between the structure and the
'.. adjacent fill it could be grouped into the study that could
.; have been designated as a building settlement marker.
.- Q Md what would it be though?
A It would be whatever it is in its position.
O In other words, it could be something like a Boris anchor but
' it would be called a building settlement marker , is that. what you are saying?
A No, I am not saying that. I am saying that I could see a
- need of measuring settlement out on the fill and the building
- - itself.
C I am not sure that I understand what you are saying. htat I am saying is that if by legend something is designated a
- building settlement markar does that mean that that is a
- monument on the building?
A I answered it could, but I am also saying that if you are presenting a study showing settlement of a building you may 1 : . : , .
._m ,.. _ _._._ , , _ _ _ . _ , _ . _ _ _ _ , _ _ _ _ . _ _ . . . , _ _ _,
44
. KANE
- group into that study monuments that are or that may have 1 been labeled that same way just to show the difference in the a settisment patterns. .
- Q Where would those monuments he? Where would they be if they
- i weren't monuments on the building?
A They would be measurements of the fill outside the building.'
Q I am not talking about measurements, I am talking about
- markers now.
. A What do you -- excuse me, markers are installed to measure
'.. settlement. .
R Q Ckay, so youare talking about markers that would be installed J some place in the soil as opposed to en ene building?
A Yes.
Q Let's go back to Figure 1 and can you tell me how you go about telling what a figure like that is supposed to be conveying to you?
A Figure 1 has four plots . Are you specifically referring to
- each cne or just one?
Well, for example, when you open up that book and you say Q ,-
- %e whiz, there is Figure 1, how do I know what information
- is contained there?" -
How do I go about finding that out?
A I look at the graphs.
Did you look at anything else, icok at the legend?
Q Ckay.
s: : - :
5
45 KAME ,
- -A I look at the legend. I look at the notes.
- Q Okay, anything else you look at?
4 A All the information that is on the block.
t Q Okay, is there anything else on there that describes all of 3
the information that that figure contains?
A A sununary caption would be in the title block.
< > Q All right. What does it say in the title block with regard
- to that information that is contained in the upper
- nost of those plots 7
. . A In the title block it says typical settlement.
.. Q Typical settlement of what? .
.-; A It doesn 't say. Above it it says diesel generator.
, Q Okay. Would that then give you any reason to believe as a 1 geotechnical engineer reviewing that chart that what you are seeing in that top plot is the settlement of the diesel generator building as opposed to the settlement of the fill
. adjacent or near the building?
.. A As a geotechnical engineer it would give me some indication,
. but as a geotechnical engineer I should be experienced encugh not to be working with typical settlement plots or average
. settlement picts but factual settiament plots of each monument.
Q I see. You don't consider that to be a factual plot of
. monument DG-37
- A I consider it to be a factual presentation of 00-3. What I
! ( : . e 6
- - - - - - - > - - . - ~ w. , . . . _ _ _ _ _ , , _ _ _ _ __.,_-y, . , , , . , _ . _ , , . - - ,_,,.~,_,y -
_,.,,.____y..- .-, _ , . . _ _ _ . - ._.e,- r----- * - - . * - - -
46
. KANE
. am' indicating is that you have provided a lot of additional
- settlement readings for other monuments which have not been
. updated since the time of surcharge removal. -
- Q I see, you are jumping back to one of my earlier questions
- with that answer, I guess. >
A I am trying to respond to your question, i Q Really what I as 'getting at is you said a little earlier that
. if you look at that and that information is presented to you
.. that perhaps that indicates a settlement with regard to plant
.. fill, something off of the building and not actually transmit-
. tal of information to you with regard to settlement behavior
! of the building, and what I am saying is that wouldn't you l
- agree that when you take a look at all of the information that 1
is contained in Figure 1 that in fact you have got to conclude l
that than is settlement of the building and not of plant fill l
l "
- off the building?
i A No . .
Q All right.
A (Centinuing) : The fact that you have platted the =enument 1
- outsido of the limits of the building would not lead me to cen-
.- c1:.de that.
Q okay. What about the fact that there is other information on there which you as a geotechnical engineer say you'd look at and read in that figure, would you ignore all that?
e : - . .
.. . ,.g. . . . . .
41 LkW
- A No, I would look at all the information.
Q ckay, and based upon all that information you still would 4
assume that that was settlement of the soil off the building?
A I don't think the additional information that is on this plot
- 4 other than the location plan tells me where that marker is.
Q okay, and would you say then that there is , when it says diesel generator building typical settlement, that that
. wculdn't cause you to believe that maybe what we are platting here is settlement of the building and not settlement of the
.. soil adjacent to it?
.. A The title block dcas not tell me where you have measured
. settlement. The location map of the menument dcas.
Q You didn't ask anybcdy after you reviewed that how come the title block that it was a diesel generator building settlement
. when in fact the marker was shown as being out in the fill, did you?
s A I didn't feel I had to. What I did observe when I looked at
. tnat information is to recognise that all the other markers
- - that you have submitted in the past were not submitted at
- that time.
.. Q ch, and that had scme particular significance to you?
A The significance is we still have not received settlement readings since removal of the surenarge.
Q What significance does that have to you? What I am saying
- e- : c- -
e
48 KANE
- is does that mean that you didn't giw it any attention j
that you were going to ignore what you got?
A What I got was not enough to be able to come to the same conclusion as you that there has been no significant settle-ment since the surcharge was removed.
Q All right, then as of September 14, 1980, did you doubt the infor: nation that was given to you that there had been no significant settlement of the diesel generator building?
A I have not stopped my thought process to qua.stion whether I am doubting it. I don't feel I should have to doubt or guess.
. I think it is reascnable to expect that information.
Q You also got something else, didn't you , on September 14th, 1980, along with this discussion of the applicant's position, something that was titled settlement update from Midland Plant Units 1 and 2, Consurers Power Ccmpany Docket number 50-329 and 50-330, a report dated September 14, 19807 A Could I look at it?
Q -Gure . Do you remember seeing this?
A That is the same document I have testified earlier to having ,-
seen.
. Q Ch, okay. I think it is a little different. I think it is part of this.
. A Are there two documents? Could I see the one that you have?
Q Sure. Th.y may have been together as one document when you at: . : # :-
49 1
KANE 2 got them, in one package.
O A They are two documents?
Q Right, they are two separate documents.
A I have seen that document (indicating).
Q okay, you have seen the one that we have been talking about
~
so far, the discussions of the ' applicant's position.
Have you seen this one that says 7
Settlement Update bearing the same date?
A I thought it was that one which I had testified to earlier to having seen.
Q That was this one (indicating) , the one that you just handed back to me and said you had seen.
Let's mark these as exhibits. I am carking as Consumers Exhibit Mumber 8 the discussions of the applicant's position on the need for additional borings, et cetera, dated September 14th, 1980, and that's the one that you say you had seen before?
l A I have seen both of those documents.
l -
0 Okay, you have seen both and I am going to mark the second one that you have seen as Consumers Exhibit Number 9 for
- I identification as of today's date and that's tiie second one that you say that you have seen, right?
A That is correct.
Q Okay. I am going to hand you Consumers Exhibit Number 8, for t t : .
1
50
. KANE
, identification,which you testified you have seen, and in particular refer you to Figure number 4, and I am going to hand you also Exhibit Number 9, which you have testified you
- have seen and show you Figure number 1. Okay. Tell me what .
Figure number 1 first of all in Exhibit Number 9 shows you? .
A Figure number 1 shows me the location of settlement markers .
Q Does it show you the location of settlement markers for the
. diesel generator building also?
. A Yes.
Q Let me show you Figure number 4 of Exhibit 8. Can you tell me
- what that shows you?
A Figure 27-15 shows me settlement of the diesel generator building, both measured settlement.a=d predicted settlement between a certain period of time.
< Q What is the period of time?
A 3-15-79 and 6-12-80.
Q 3-15-1979 and 6-12-80 would be the period of time felicwing
'~ remeval of the surcharge, wouldn't it? l A That is correct.
- 0 So in fact when you said that you hadn't been provided that
- settlement data you were in error in that answer, is that right?
A :4y answer is with regard to the way it.had been fo:mally submitted and the way you have presented the information in
.- : - i 1
v- , , - _ - , - - - _ _ _ , . _ , _
51
. KANE
- this report and the way that you have presented the infor:na-tion for monument DG-3, and that what I am talking about is a plot, a graphical plot that shows settlement with time.
Q I am sorry, I just don't understand that answer.
A Well, to evaluate the settlement behavior you would be inter-ested in trends that may occur because of more recent settle-
' ment. Those trends would be clearly evident on a graphical plot. They are not clearly evident in the presentation such
- as here (indicating) .
Q In your opinion as a geotechnical engineer would you consider
-- that the information on those two sheets that I referred you to and which are in front of you descastrate insignificant settlement since removal of the surcharge?
A The majority, yes.
Q Which ones don't?
A From this -- well, to answer your question the ones that begin getting a tenth of an inch -- can I also ask a question?
Q Yes.
A When were these readings taken?
I- Q Well, I would assume and maybe I am wrong. Is it a valid assumption to assume that they were taken and calculated as ,
of the date that it bears, 6-12-80, when it says that this indicates naasured settlement trends 3-15-79 and 6-12 -80, could that indicate to you that it is settla_unt as of e *
- , + ,
52
. KANE
- 8-15-79 and settlement as of 6-12-80 and tnen having taken
, the difference between those two figures?
A The thing that you have to assume would have been answered ,
by graphical plot. It is quite possible they reflect the settlement as of June,1980, but it could have been a differ-ent settlement behavior and then a rebound to that level and that is what is being pictted there. I don't think that plot tells me specifically the date of these settlement readings.
Q All right, but doesn't it seem to you that this is the differ-
. ence between the readings taken on 8 ,15-79 and 6-12-807
.. A The question I have is at what ti=a as of June, 1980.
Q Well, I am asking you as a geotechnical engineer looking at that piece of paper, what information does that cenvey to you?
Do you interpret that as saying that it is the difference in settlement between 8-15-79 and 6-12-807 I take it to be the difference in settlement between S-15-79 A
- and scmetime up to June of 1980, and I don't know from that .
.: information whether it is of June, 1980 or scme other dats
- between that pericd. ,-
.. Q Okay, let me refer you to page three of Exhibit Number 3, and
.. there is a sentence that refers to figures that have been pre- .
- viously provided that show settlement curves, Figures 27-6 and
- 27-51 through 27-58. See that? Oo you recall enose figuras?
A I recall those figures which I understand. I den 't know the l
l
53
- EANE
- exact figure numbers, but I an assuming that it is what was
- submitted in Volume II which is the plot of settlement with time. .
$ Q Okay, 'and what did those figures show you?
A Those figures showed me settlement with time up to surcharge removal. They are the plots that I an asking to have updated. -
Q And Figure 3 and Exhibit Ntanbar 8 shows you, I believe, I
- measured settlement and predicted settlement versus log of time for marker DG-3, is that courect?
.. A It shows the measured and the predicted settlement for one
. settlement marker, DG-3.
Q Right, and it shows a plat for that, right, over time 7 i
, , A 'over log time , yes .
. : Q And the stat mment on Page 3 tells you that that curve is typical of the settlement curves for the markers referenced I in those figures that were provided to you with volume II, is that right?
A The sta**mant on Page 3 tells me Figure 3 is typical of all the settlement curves and my response to that is a responsi-
. . ble geotechnical engineer in evaluating settlement would not just look at typical data when in fact previous information ,
i l
i the figures that you referred to of the settlement history i
I
. of all of the markers has been provided and rather than looking at typical values it would be preferable to look at the l
. . - - - - ..,n. -
-.------e. _ . , , , _ . - - , _ _ _ - _ . , , - - - _ - _-- - ,-.- - ,--.-- _ . - - - - _ - , - - , , , . _ , , , - - - - - - . -
54 ZANE 2 settlement history of all those markers.
Q I understand it would be preferable in your opinion *w look at the settlement data for all of those, but where you have ,
settlement data provided as of 8-15-79 and 6-12-80, and you -
are also informed that the se'ttlement curves for each of those markers is typified in this Figure number 3, do you have any reason to doubt that that is *Jue?
A You say we have settlement data. We have settlement records of one marker.
Q No ,' I am referring now back to this figure that we icoked at
.2 earlier which shows you the actual settlement. Figure 4 in Exhibit Number 8, that shows you the measured difference in settlement for each marker between '8-15-79 and 6-12-80, okay, i
l and you have indicated that you dida 't see a settlement curve for each of these, however, is that right?
A We have seen settlement curves for those up to surcharge removal. I have not seen settlement curves updated since surcharge removal.
Q Okay, but you have here on rigure 4 the differenca between l the settlement marker as of S-15-79 and 6-12-80 on Figure 4, i
is that right? .
A That is correct.
Q And you have been provided with a settlement curve for marker DG-3, is that correct?
. t l
55
- KANE 2 A That is correct.
1 Q And you have been provided with information that the settle- !
ment curve for marker ElG-3 is typical of all these curves, is that correct?
A That is correct.
Q Do you have any reason to doubt that that settlement curve for OG-3 is typical of the settlement curves for all these markers as stated to you?
A I have no reascn to doubt, but I do not have the other infor-
. mation.
. Q Based upon the information given to you, that is the informa-
.: tion contained in Figure 4, which shows the differences in the
. settlement markers between removal ef surcharge and June 12th-of 1980, and the information contained in that plot, that.
settlement curve for DG-3 and the information that that settlemer.t curve is typical of all of those , would that indicate to you that in fact there have been no rebound such
'- - as you described before in the building?
A Again , youbs confusing the rebound of the piezameters.
A No, I am talking about the rebound of the building and I thought that is what you were talking about when we were talk-ing about pictting settlement.
A We are talking about rebounding of the building when we talk about plotting settlement, but our discussions on rebounding O
56
. KANE
. before had been on piezameters.
Q I thought one of your answerswas that when you looked at this, when ycu looked at Figure 4 you just had figures as ,
of 8-15 and figures as of 6-12-80 and you didn't know what
- happened in between, that the building might have been spring- .
ing up and down in between and you really didn't know whether it had settled more than once and then bounced back up, I thought that is what you were saying?
A Well, what I had indicated was a graphical plot will give you the trend. That plot (indicating) gives me one value and my
. question is I den't consider it so much as likely that the building is rebounding as much as the question cf the accuracy of the survey which is measuring that settlament history.
Q You have a question as to the accuracy of the survey, is that what you are saying?
A I think any settlement survey has questicus on its accuracy, and it has been shown in study of settlement history that you can have errors in surveys and I also would like to point out ,"
by my cwn experience why I am reluctant to accept typical settlement curves and also statements about significant settle- .
ment. It has been indicated on other projects that I worked cn that settlement was insignificant, and when I received the actual data perhaps 15 settlement readings, 11 of them were 4
' 57
. KANE what would be considered insignificant and four of them had settlement that I considered to be significant and the explanation given to me was those that had experienced ,
significant settlement had been damaged in construction and
- that settlement behavior was a result of that and what I am trying to avoid is that same kind of problem.
Q Okay, I understand that, but on Figure 4 aren't you given the dif ference between the settlement as of 8-15-79 and s-12-80, Figure 4 of Exhibit 8, isn 't that what that gives you?
A Let me see. I am given a difference in settlement. Whether
.. it is the difference in settlement between the exact date of
-. 6-12-80 and 8-15-79 I do not know. What I am indicating is that these settlement values there may have been recorded on another date.
Q Okay. What it says here though is , when it shows you what that number is that is above the line in these figures , it says " measured settlement between 8-15-79 and 6-12 -80, in
. inches, doesn't it?
A Yes.
Q Would that indicate to you that that is the difference between the :neasurement settlements en 8-15-79 and 6-12-807 In other words, that they took a reading on 3-15-79 and subtracned it frem the reading en 6-12-80, would that suggest that to yeu?
A It wculd suggest it to me but what I am trying to indicate is
58
. KANE
- that a plot with time could show different readings and
. different magnitudes of settlement.
Q And what would be the significance of these different readings -
and different magnitudes of settlement on that plot that you referred to? ,
A The significance of the difference could be viewed on those plots. If this settlement that is plotted here is the settle-ment of June 12th,1980, there could be different settlements
. greater than this if they were recorded on d'ifferent dates.
Q So in other words , you are saying that the building had
- settled and then had rebounded up to this point?
A Not necessarily.
Q Well, then, explain that.
A The difference could be maybe the settlement that you observed on a time date other than 6-12-80, because of survey accuracy l indicated more settlement or maybe the reading on 6-12-80 l
l
, because of survey accuracy can be questioned depending on the ,
l l
I trend that you would pick up from the plot.
/
Q Take a look at the plot shown in Figure 3, and this is four marker ::G-3. Do you see any such trends en that plot?
A I see a trend where it was -- frem this very small scale plot .
of log time : see a period where it may be deeper, there may have been greater settlement than the reading en 6-12-30.
C Where is that?
59 1 KANE 2 A This icw point here (indicating) .
2 Q Ckay, you are referring to what appears to be a little --
- A (Interposing) : Dip in the settlement history.
Q Okay, and what would that hdiemte to you? --
i A What would the dip in the set +1mt history indicate to me?
Q Yea, or in other words, what significance do you attach to that?
A That it could be more settlement than the values that you .
. have plotted; that the rebound off of that dip may be because
-- of something that was being done around the structure such
-- as the excavations around the footing.
C okay, any other significance in that dip?
A It could be significant based on the , settlement accuracy, excuse me, the survey accuracy.
Q Okay. Now, if that curve that you see there is typical of the settlement curves with regard to all of the other markers and you have got in Figure 4, and I think it is on the next page, the amounts of measured settlement for each of those markers between 8-15-79 and 6-12-80, does that provide you with information as to whether the settlement of the diesel generator building has been insignificant since removal of the surcharge?
A The answer to the question depends on the understanding of the word " typical." If you are saying it is the average 9
- , - - , - - - - - -wn,n , .-.-----,--,----------.--n-- - - - - - - - - - - - - - - - , - -, - - - - -------,-----------r-- - - -- - ------ - - - ---,+
60
. KANE
- settlement it may not be sufficient. If we have had monu-
, ments with significantly greater settlement then I would net want to be evaluating a typical settlement plot. ,
r Q okay, is it your understanding of the word that a typical plot
- means that that is the average of all of the others or that all of the others approximate that pict?
A I could interpret " typical"to mean the average.
Q Did you ever ask anyene whether " typical" there meant average as opposed to whether that plot approximated each of the
. other plots? ,
.. A There was no need in the past to ask anyone because the figures that you have submitted in your documents give all values and there is no need to conclude about whether it is typical or not.
Q Figures that we have submitted in our documents include all values? In what documents?
A The figures that you have referred to in volume II give the .
settlement history of each marker and, therefore , there is no i
need to judge whether it is typical or not. ,'
i Q I am talking about from information during the time period l l
after removal of surcharge.
- A The only settlement history that we have been given after j removal of tse surcherge for the diesel generator markers is ,
this DG-3. .
i
61
. KANE
- Q All right, and in addition to that you have been given
- Figure 4, that is Exhibit 8, that shows the difference betseen the measured settlesent after removal of surcharge and the measured settlement as of June 12th,1980, and you have been given a curve for DG-3 and you have been given a sta*=mant that that curve is typical of the curves for all of the other markers and the problem, as I understand you to have stated it is that you don't know what is meant when it says " typical,"
it may mean that that is the average of all of the curves and that that would not be acceptable to you as a geotechnical
- engineer?
A That is correct.
Q Cr it may be the approvimmte of all of the other curves , and
~
what I'm asking you is did you bother to ask anybody what they meant by typicali?- If it meant average or if it meant that that apprnrimates all of the other curves?
i A This report that you aretreferring to was submitted September'
!' 14th, 1980. *
! Q 2.ight.
A Which is a month ago.
l i
Q Almost to the day.
A We have been evaluating not only this docu=ent but your boring g
logrs and de other documents that you have raported and trying r
t to provide input into our minds to ecce to a decision en pur
62 ENE
- appeal of our request for borings and so the work that we
- are involved in has not permitted us to respond or to question Consumers about submitting the other parts and not being -
~
required just to evaluate this as typical. As a matter of i fact, on July 29th, 1980, I raised the question and it was my understanding that the settlement records and the piezometer
- records which had been submitted would be updated and submitted to us. It was my understanding at that time that they would accompany the submittal of the additional borings which we 1
have received but we have not received the other data.
Q Wouldn't it have been important to you as a geotechnical engineer rather than simply in effect ignoring this data to have found out or to have made some attempt to learn whether that curve as stated as being typical in fact approximated all of the other curves as opposed to being an average?
l A I don't feel I have -- I feel I have attsmpted to resolvs it 1
by asking you for that information that would permit me to ,
come to my own conclusion on whether it is typical or whether it is average or whether there is differences indicated _*_om -
this settlarwnt marker.
Q That infor=ation being the actual -- .
A (Interposing) : Records .
l Q (Continuing) : -- measurements?
A Settlement records. I haven't ignored it.
l 63
. KANE
- Q Did you ever communicate to anyone at Consumers Power Company your problem with using that typical curve because of your understanding that that may well have
- neant average curve? l l
A Indirectly I have communicated it by asking Consumers for )
~
the other information and requesting our own project manager to obtain the additional information on all these markers since surcharge removal.
Q Did you ever tell anytody why you considered the information that you have before you now insufficient because of this ambiguity with regard to the word ' typical" in description ~of
- the curve?
A I didn't feel it was necessary when I had already set in motion a way of eliminating that problem.
Q Was there any water content data provided to the staff prior to che surcharge with respect to the fill under and around 9
the diesel generator building?
A Would you repeat the question? .
MR. ::AMARIN : Read it back (to reporter) .
(Whereupon the reporter read back the previous question.)
- A It would be my understanding that laboratory test results
- I l have been provided. Whether they were adequate enough to understand the conditien of the r.oisture I have not in my position reviewed that data.
l l
64
. KAE
- Q Who bas, to your knowledge?
t A It would be my understanding it would have been reviewed by the Corps of Engineers. -
And if it has been reviewed by the Corps of Engineers you Q
are unaware of that, is that correct? ,
A I have not asked the Corps that specific question.
Q Would an evaluation of that data with respect to optimum values from the test pit have been important to see if indeed
.. the average water content should have been exp'ected to have been dry of optimum? .
.. A Would you repeat the question? There were soon parts in
- there that I den't fully understand.
MR. ?.A M A R D I : Why den 't you read it back and you can point out those that you don't understand.
(Whsreupon the reporter read back the previous question.)
. A I am not sure what you are referring to as the optimum test ,
pit value.
l 0 wouldn't compaction tests that were done on soil taken from -
the test pit provide optimum values with regard to moisture content for the soils? .
A Laboratory compaction tests on plant fill would give you optimum moisture content and maximum drainage , but I would have to run an additional test in the field to establish the l
i
65
. KANE
- actual' moisture of the fill.
Q okay, if you took samples from a test pit would that in your mind give you some kind of an indication of what the soil conditions were around that area?
A It would give me some idea of the soil conditions around that area, yes.
Q And in making the determination as to whether the fill under-neath the diesel generator building should be expected to have been dry of optimum wouldn't that be important informa-tion to have? .
.- A Would you repeat the question, please?
MR. ZAHARIN : Read it back.
(whereupon the Reporter read back the
. previous question.)
A To haveinformation that would tell us whether the fill was dry of optimum would be important information to have.
Q And would that be that type of information?
~
A If your question is asking me would tests in a test pit, those
~
.~
-- tests establishing the moisture content of that fill tell me whether it was dry of optimum, my answer would be yes.
Q Ckay. Couldn't you ccmpare the water content tests from j
borings that have been made in the diesel generator building with the optimum water content values that were obtained from the ecmpaction tests in the test pit in the general area
66 i KANE of the diesel generator building, wouldn't they have provided a the information?
t A There would be important considerations to be allowed for ,
e, when you did that, and that would be that at the time the
- boring was taken what controls were there to assure that the ,
moisture content of the samples taken were not changed by being allowed to sit around and dry out, and also the time s of the horings ivere taken with respect to the developnent of
. seepage off the pond. The information would be useful but
.. there would be important considerations that you would address
.. in evaluating that information.
Q okay. If you can -- well, if you are concerned about the
. possibility of the fill having been placed dry.cf eptimum and the borings that were taken from the diesel generator building had been allowed to sit around and dry out, wouldn 't that then give you.what can be termed a more conservative
- value than what might really exist under the building when 9 you are trying to determine whether it is dry of optimum as being a problem in this area? ,
A Not necessarily.
Q *dhy not? j A Secause in allcwing a sample to dry the upper portion of the same could be dryer than the lower portion to where the water
, may have drained out of the sample and b e concentrated l
i
! t : -
1 i
67 1 KANE 2 in the bottom of the sample and so you could have a difference I within a given sample of moisture content and depending where you to;k that sample would depend on what the moisture content
! is.
. 4 Q When you say where you took the samples , where ycu took the borings is that --
- A (Interposing)
- The point that I'm trying to make is that you
- could take a portion of it dry or you could take a portion of it wet which would then reflect the other concern to where it
.. is being shown to be wetter than it really was in place.
.: Q Ckay. h t information do you have that these controls were 1
. insufficient or that these errors might have been introduced
- in the horings in the diesel generator plant?
A I have no raason to believe that we have this prcblem, but i I do not recall any study submitted by censumers that I' '
addresses this concern.
Q Addresses what concern?
, A The concern of whether the materials were placed wei or dry of optimum. My indication earlier of the concern for soils l
placed dry of optimum was raised by Dr. Peck in his response to me.
Q Ckay, but isn't it a fact that you do have information availa-ble to you from which you can obtain information and draw conclusions with respect co the soil and whether it was placed e e S
68 KANE dry of optimum, that being a comparison of the water content
- tests from tre diesel generator building borings to the
. optimum water content obtained from the diesel generator .
3 building test pit? .
- A It is my guess that there is information that would permit
- you to make that study. I have attempted to indicate that there were important considerations that you must address y . when making that study and the only one I think in the position to evaluate all that information would be the people
. that took the samples and stored the, samples.
.. Q Ckay, taking the data that was provided, however, and that
. is the water content test for the diesel generator building and the optimum water content values from the test pit, has
. any analysis or evaluation been done by either you or the corps to your knowledge?
A It has not been done to my knowledge by the Corps. If I recall correctly in the August 4th, 1980 Corps of Engineers report which has been forwarded to Consumers that type of s tudy was requested to be done by consumers. ,
I Q If in fact it is demonstrated that the fill was not placed dry of optimum would that change your opinion with regard to the presence of these cracks and slabs and clay balls that you suspect exist in the fill underneath the diesal generator building?
4
P 69
. KANE
- A If it could be demonstrated that the moisture content of the fill was near optimum then I would expect a better knitting -
and bonding of the fill to where you would not experience
- those cracks, but it raises a question which originated in
. my original question and that is why didn't the piezon:sters reflect a higher pore pr' essure when subjected 'a the su.h ge loading?
Q We will get to that later today.
'. Have you reviewed all of the information contained in volumes III and,IV of Consur::ars responses to
. questions with regard to the Midland Plant fill?
-w A I am trying to understand what volumes III and IV cover. Does it cover the minutes of all of the meetings?
Q Yes.
A I have briefly reviewed those volumes .
Q Ckay. When you say "briefly reviewed them" can you 'all me what in there you reviewed more than briefly, if anything?
A I would say those aspects of the meetings that are deciding how to treat the problem of the plant fill beneath -le diesel
- generator building.
Q You consider the information contained in volumes III and r/
to be important in your avaluation?
A Yes.
Q Are you familiar with a fellow by the name of Davison frem
70
. KANE 2 the University of Illinois?
A I know Dr. Tom Davison.
. Q And what has been the extent of your experience with Dr. Tom 3 Davison? -
All my personal experience with Dr. Davison has been connected A
with the Midland project.
Q And with him in his role as consaltant to Bectol in that regard?
A That is correct.
Q And do you know whether the experience with Dr. Davison and
- the staff extends beyond that?
A I do know it does extend beyond that.
Q In what way? ,
- A Dr. Davison is a consultant to the NRC on a project, the Bailly Projact.
O Is that with the shoal pilings issue at sailly?
A It is with the pilings.
Q And do you know just what his role is with regard to the pilings issue at Bailly? ,-
A It is a service as a consultant to the NRC in. evaluating the pile foundation design.
Q And I take it then that the NRC recognizes him as an expert in that area so as to call upon his expertise with regard to 3ailly?
0
71
'. KAE A That is correct.
Q Are you familiar with an individual named Paul Hadula?
A I am familiar with the name Paul Hadula.
Q Could you tell us who Paul Hadula is?
A Paul Hadula is a geotechnical engineer working for the United
- States Army Corps of Engineers at the Waterways Experimental station, Vicksburg, Maryland.
Q I have a copy here of a telephone conversation record which ll:
am marking consumers Exhibit Number 10, for identification, which was provided to- us from the NBC files , from the Corps files rather, and is a memo listing a telephone conversation between Paul Hadula and an N. Gehring, Who is N. Gehring?
A N. Gehring is Heil Gehring', who is the project manager coordinating the Corps of Engineers, Detroit District with NBC.
Q In this telephone conversatien Neil Gehring states that Paul, referring to Paul Hadula also indicated that Tom Davison,
.: NBC's consultant at Bailly is one of the best earthquake experts in the country.
Would you agree with that statement?
MR. PATON : Could we see the nets, please, just a minute?
l A Could you ask me the question again?
Q Was whether or not you agree with that statement that Tom I
72
'. KANE
- Davison is one of the best earthquake experts in the country?
A To my knowledge Dr. Davison is considered an expert in pile foundation design. I am not aware of his experience in l ,
earthquake engineering.
1
~
Q Are you aware of his experience with regard to the earthquake i
effects on piles?
l l
A I an aware of his experience in understanding how piles react l
to earthquake loading, but I don't consider that to be an l
l . expert in earthquake engineering.
. . Q Would you consider him to be one of the best e.p rts in the
.- country with regard to earthquake effects on piles?
A I am not in a position to, because I do not know his experience l
. . in that regard, to make that judgement.
l Q Then do you know why the NRC hired Tom Davison for Bailly in l that regard?
l l ~
A Secause of his expert background in pile foundation design.
Q And would that necessarily include earthquake effects on pile l
. design?
i l A I think our differences are in trying to understand what is '
l meant by earthquake engineering.
Q I am not talking about earthquake engineering. .
A The words in that paper say earthquake engineer.
C I am asking about him as an earthquake expert and now I am talking about the earthquake effects on pile design and that i
1 . . . ; - ,
. .3, e
I
73 KA!E is what my question was.
? A I would consider Dr. Davison an expert in assessing the impact
. of eart'1 quake loading on a pile design.
O Would you consider him to be one of the best experts in the country in that regard?
A Yes. -
, Q Can you tell :na what the responsibilities of Mr. James
. Simpson are with regard to the Midland project?
. A The Corps of Engineers, who is a consultant to the imC on both the Midland and Bailly projects have a certain organiza-
._ tion which places Mr. Simpson in the position as being the
.. geotechnical engineer at the Division level who would normally review the efforts of the District personnel.
. Q And what do you mean when you say would normally review the efforts of the Division eersennel?
A The normal way for the Corps to do their work would be to l
l
- . have it done at the Dis trict level and reviewed by higher
- authority at the Division, and the office of Chief of Engineers in Washington.
Q And when you say " review," I guess really what I am asking
. is what type of a review does he do, to your knowledge?
i l A A review to the extent that the efferts of the District i
personnel appear to be accurate and good engineering practice.
Q And is there an individual named otto also within the Corps,
i
, 1 74 xAa I
- is that right?
- A The person I think you are referring to is William Otto who I
l . ' is the Chief of the foundation and materials section of the .
i
~
l
. Detroit District.
Q You indicated that James Simpson normal).y reviews the offorts of the -- did you say District personnel or Divisien personnel?
A District.
Q District personnel. Can you tell me just what he is doing or
) . has done" with respect to Midland?
. A He reviews the reports and correspondence initiated by the
.. District prior to being submitted to the NRC.
Q And to your kncwledge he has done that for Midland?
4
. A To my knowledge be has done that for Midland,
- Q Eas he dcne that since the beginning of the association with tne Corps and the NRC with respect to Midland and through today's date?
A If we are indicating since the beginning being October of 1979, .
I would say, because there was a period which the Detroit
) District tock to establishing manpcwer to do the review, it ;
- was only after their afforts resulting in repcrts that he then became involved. .
G Okay, then is it true that for as long as somebody at the Division level has been reviewing t=a efforts of the Detroit
- District that that guy has been Mr. Simpson?
i: : : s. :=r e .
- s. , _
i e
75
. KANE
- A It has been Mr. Simpson, and I understand he has had assistance from John Norton.
. Q Ckay, and what is the extent of the assistance that he has gotten from John Norton, to your knowledge?
. A I do not know to what extent that assistance goes.
Q Is John Norton a sub' ordinate of' Mr. Simpson?
A I think he is.
Q Do you know if Mr. Simpson also reviews information that Consumers provides to the MRC7 -
'.. A It is my understanding he has been furnished information that
- Consumers has submitted to the NRC.
Q Do you know whether he reviews the information he has been
.- furnisned?
- A I would have to assume that he does.
Q Can you tell me what William Otto 's responsibilities with
~
respect to Midland have been?
A The tec.hical review that the Corps is expected to provide to
. the NRC, in my estimation, would be under the direct super-vision of William Otto.
0 And would it then be the results of that effort that James Simpson reviews?
A Yes.
Q What are the responsibilities of Mr. Erickson with respect to Midland?
2 t: .
? . - : : : i 1
l l
l
76
'. KAtG 2 A Mr. Erickson is an employee of the United States Army Corps 2 of Engineers in Mr. Otto's section. Mr. Erickson's background is in geology and has had input and review of the results of .
~
5 the subsurface exploration information provided *4 NRC by Consumers. .
Q And would that review, in your understanding, then be reviewed
. by Mr. Otto?
A That is corr'ect.
. Q And then after Mr. Otto reviews it it goes up and it is re-
'. viewed by Mr. Simpson? .
.. A That is correct.
O And then from Mr. Simpson it goes to the NRC7
. A That is correct.
Q And who in the NRC gets it first?
~
A Initially it would go to Dr. Robert Jackson because of his position as Chief of the Geosciences Branch.
2 What does he do with it?
Q .
A Could I finish?
Q Ch, I am sorry, I thought you were. I didn 't mean to cut you .'
2- off.
-- A There has been a reorientation within NRC in that the geo- ,
technical engineering section is now in the hydrologic and geotechnical engineering branen whose chief is George !.eer, and so subsequent submittals from the Corps now go to George ar: - a eis :
<-t :- .4 .. :. . .. .
- t*
1 77
. KANE 2 Leer. From George Imer they would be given to me, the contract technical monitor, who would review it and forward it to the Division of Licensing within NRC.
Q What, if anything , would Leer do with the information before he submitted it to you for your review?
A I would assume he would read it and understand the, significance of the contents and possibly suggest ways of approach to me.
Q I can't tell whether you are finished or not'.
A I am finished.
1
-- Q Okay. Has he suggested methods of approach or anything to
.- you with regard t.a any of the information that has been sub-
)
mitted to you from the Corps through him?
A I have been given directions relative to meeting schedules, i
- trying to have an understanding of the significance of the I --
Corps reports and having discussions with hi: on what was
- required to process the information being submitted by the l Co rps .
! 0 What kind of communications have you had with Leer with re-l l- gard to trying to understand the significance of the Corps reports?
A There have been many occasions. I could give an example of the requests for additional borings in trying to convey to
- Mr. Leer the differences we have in the categorization cf the
~
structures, the significance of the Corps' request and their i:: . : i . 4 . .
.: ,.. 5: .. .t . . . ....,
.---.v--,-----
, -- , - , . - - . . - ee
78
". KANE
- purpose for the request, and the testing.
- Q Ckay. You say now that you were explaining to him these
, things. Is this primarily then a situation where he would ,
ask information frca you as opposed to him providing direction -
to you?
A That is correct.
Q Can you recall anything in addition to the additional berings question about which pu have had such discussions with Mr.
Lear?
A I have had discussions with Mr. Leer on the Corps of Engineers L report that was suh=itted to Consumers on August 4th,1980.
I am finished.
Q Can you tell me , as best you recali -- put your arm up when
. you are finished, will you?
MR. PA"20N : You don't have to do that.
Q (By Mr. Zamarin , continuing) : Can you tell me the substance
- of the conversations that you had with him with regard to that Corps report?
A I think there were certain issues, and I don't recall all the ;
! T- issues. The report itself is what, 14 pages long, and there
.!! were items in there that he may have had a question on that .
I tried to answer.
Q Do you recall any particular questions or the general nature of the questions dat he asked?
1 : - : . : s. -
ia = -
+2 .-- -- ..: , . . . , , . . . . - - ,
-- , _ _ __ _ _-_,--r--- - , - - - - _ - -
l 79 i
KANE 2 A The type of questions that he may have asked was trying to understand why certain issues at this stage of the review [
were not fully resolved and trying to inform him of the f i
background of the plant fill settlement problem at Midland. i
~
Q What issues which are not fully resolved did he inquire about?
A Our problem in review of the diesel generator buil, ding, of .
. the cooling pond dike and, to the best of my recollection, I
~
- r we also discussed the other remedial treatment fixes.
Q And what were your answers to those questions?
- - A I tried to apprise him of what I thought was the situatieri
-. as it existed at that time .
Q okay. Tell me as best you can recall what you told him?
. A I gave him the history of 'the plant fill settlement problem of the diesel generator building. I explained what treatment was completed. What information we had from Consumers and what problems we had in our review of that information.
Q What information did you tell him you had from Consumers?
'9 A Wn11, I think I touched on all aspects of the information 2' that was submitted. If we are talking about the diesel
- generator building we talked about the piezemetric data. We
- talked about the settlement data. We talked about the time
-- the surcharge leading was imposed.
Q Did you also tell him about the settlement information that
! !! had been provided to you as contained in Exhibits a and 97 i:: . .- r .-3 3 :
.. .--u ....u .:, . - , ,
6
tsu
'. N
- A George Leer had a copy of that information and to my under-s*=adi ng read it, and gave me the reports that he had read.
Q Did you tell him that you had been provided information with .
regard to previous borings that had been taken in the diesel generator building?
A Previous to what time?
Q Previous to the application of the surcharge?
A I den't recall any direct discussicas about the information that had been submitted prior to the surcharge, but I am assuming that George Leer with his experience would know what information would bs acrmal in the submital of a request to cperate a nuclear power plant.
Q Did you tell him that certain information had been provided as a result of the determination of optimum moisture centent from the test pit at the diesel generator plant?
.' A I do not specifically remember having a discussion with George
. Leer on optimum moistures content information that had been .
. submitted by test pit.
. G What problems did you tell him that you had in treatment of ,
- this information that had been provided to you?
- . A I hink a good su= mary of the problems that we feel exist,
. even today, was presented to George Leer, Jim Knight and Richard Volmer at the October 1st, 1980 =eeting. A summary l of what our position is you have a copy of in the documents ,
1
- : , =
- . i j
- - - - - - . _ _ . . . _ _ - _ _ _ _ - _ _ __ .\
81
~. KANE
- that I'had given you in the deposition.
Q To what document in particular are you referring?
- A Could I see those documents?
Q Yes. I mean a lot of these have my notes on them. Are you t= ni ng about --
A (Interposing) : Does that say :mc position (indicating) ?
Q Yes.
That document, plus there is an accompanying document that
- A lists your position, Consumers Power Company's pos.1.tions.
- That is correct (indicating).
Q okay, in addition to those did you tell him about other, any other problems that you were having in the treatment of the information that had been provided by Consumers?
A I think in the past we have had discussions trying to under-stand the relucuance of Consumers to provide us with the i
information which would normally be expected.
Q What is your understanding of their reluctance to provide that information?
I A My understanding is based on my experience with other nuclear power plant projects towhere the information that you would develop in coming to a conclusio: would, with regard to the l
adequacy of a design related to geotechnical engineering, would nor= ally be provided. With Consumers I feel there is a reluctance to provide us with specific information that you 4 :: . 3.-
--,sne .
e
-- -. , - - , - - , . , . - , . - - - - n ,,-n_ ---,---.n_ ---- - , - - - , , - - - , , , , , _ - - - - . , - - - - - . - - - - - - - -
82 1 KANE would normally have had to develop to come to that conclu-
- sion and it is my understanding that we are getting that in-
. formation only after we go through a process where we have to identify specifically what information we need rather than
~
- there being a willingness on your part to provide us that
\
l -
information to convince us of the safety of the completed structures.
. Q so then when you refer to the reluctance of Consumers Power
. Company to provide information you are talking about the fact
. that you have to identify specifically what information you
.- want before they provide it and that is the reluctance to
..' which you refer?
.. A Yes.
.. Q And have you encountered such reluctance to provide it after
- having identified specifically the information you want?
A Not generally, but since the July 29th, 1980 meeting, we have not received an update of the piezemeter and settlement readings.
l- Q what is your understanding of why you haven't received those? ,
T- A I haven't been given any explanation.
Q Co you have any understanding or opinion as to why Consumers .
- Power Ccmpany exhibits what you characterize as a reluctance
- - to provide informatien until it is specifically identified 3 for them?
it-- - : s. : 5. :
r: . x... .. .t., .. ,e , rs,
83 EANE I
- A Do I understand why they have a reluctance or --
1 Q (Interposing) : or have an opinion as to why? !
l
, A I prefer not to express opinions. ;
Q well, okay. Escognizing that, recognizing you express them but reluctantly, what is your opinion as to why they exhibit
. this reluctance to provide information until the information sought is specifically identified?
MR. PATCN: I would instruct the Witness that if he has facts on which he can answer the question, whether they are facts he has heard from any other source or
- not he can answer the question', but that if it is a pure
. guess or pure speculation on his part he does not have to answer the question.
3 A I do not have facts and any opinion I would express would be only a guess and that is why I prefer not to answer it.
- Q I'd still like your opinion as to why you feel Consumers Power
. Company exhibited this reluctance that you described?
. MR. PATCN : I ins *vuct the Witness not 4 answer the question and the reason is that the Witness has
. stated that it would be a pure guess , that the answer would not tend to lead ecward any valuable evidence in this case.
. MR. ZAMARIN: Can you point to =a or show
.- :ne any NRC rule or regulation that allows you to instruct him
- not to answer on that basis? I don't think there is one.
3 :-- - : s. -
- =. -
,. .....t. ,s ..., .
9 w, , _ - -
-w-- - - . , -- - - - . _ - - - - - - . _ .m-. ..,. -,,, - ._ , . . - , . . . . - , . . . . - - - , , _ , . - - . . , , . - - , _ , - . _ _ . . _ - - - _ , . . . _ - . - --_---.-.i
. l 34 l 1
KANE
- MR. PATON
- I already have.
1
- MR. XX4ARIN : You already have?
. MR. PATCN: I have instructed him not ,
l
- to answer on that basis that I stated.
- l Q (By Mr. :amarin , continuing) : Okay, your Counsel has in- ,
4 structed you not to ' answer that question, on whatever basis
- it was that he stated. Do you refuse to answer the question?
- A Yes. On the basis that I have no facts and that I would be only guessing.
Q Okay. Now, I haven't asked you for facts. I asked you for
. your opinion, and do you have an opinion?
A I have no opinion. I would only have a guess.
., Q okay, then I will ask that question. What is your guess as
'. ! to why Consumers Power Company exhibits which you have characterized as a reluctance to provide the information?
'.' MR. PATCN : And I instruct the Witness
- not to proceed and answer that which he has characterized
'. : would be a guess and that is based on the same reasons I have
. previously stated. ,-
-- Q Do you refuse to answer that question?
- - A I ref'ise to make a guess.
Q ::o you refuse to answer that question?
A I refuse to make a guess.
2 Q I have asked you a question. You say you refuse to answer
- :: 5
- =3 .:
. e, ...2, . u. ..:,
i . .-
85 KANE O the question and your reasons are stated in your advice from 3
Counsel because what I do is I will go in and I will present
- to the Board my opinion that your refusal was unreasonable and if they sustain me then perhaps we will be able to get
- some kind of a sanction for that, so if you are going to re-fuse to answer, say so.
4 A on the basis of the reason stated I refuse.
- Q Ckay. Has this perceived reluctance of Consumers Power Company to provide information until specifically identified influenced your review or your activities with regard to the
.. Midland project at all?
A It has influenced it to the extent to where it is considerably more difficult than what I am normally used to in other re-views.
Q Has it affected your performance in any other way or influenced i "
you in any cther way?
A :fo .
s l
Q In your opinion you still apprcach the entire assignment that l .. you have as objectively as you would did you not harbor this
- - perception?
! - A I try and approach every project as cbjectively as I can.
0 I know that you try, but has this perceived reluctance on the
- part of Consumers Pcwer to supply information =ade that more
- difficult for you?
- . : s 9
- . , . - - . . . . - . , - . , . . _ . _ . _ . _ _ _, . .,,,__,.,,.e _ , , , . . , _ . , . , , _ . _ _ _ , _ , . _ , - . . _ . . _ - _ , _ . _ . , _ _ _ , - -
7 86
. KANE
. A I have answered that it has made my work more difficult. It has not influenced my approach to trying to come to a conclu-
- sion on the safety. ,
Q Ihe question is has it made it more difficult for you to approach the entire project with objectivity?
A It may have.
Q I would again ask the Witness what his guess is as to the reason why Consumers Power Company is reluctant to provide
. information until it is identified specifically for them?
- MR. PATON: I instruct the Witness not to 5- answer the question because I perceive the question to be identical to the last question.
MR. ZAMARIN : Since the Witness has stated that this perceived reluctance may have made it more difficult for him to be cbjective it goes to the bias and prejudice of
~
the Witness and, therefore, it is important for us to know why he has that feeling.
-' MR. PATON : The instruction is the same.
Q All right. Do you refuse to answer the question? ,
A I accept the counsel of my attorney and I refuse to answer it.
Q All right. Does William Otto communicate directly with you or are all communications between you and Mr. Otto through Mr. Simpson?
A I have direct communication with Mr. Otto. I do not recall
87 i KANE 2 except at meetings having direct communication with Mr.
3 Simpson.
4 Q okay. When I refer to direct communications with Mr. Simpson,
- what I refer to is Mr. Simpson transmitting something to Mr.
~
i Imer, for example, who would then submit it to you?
A There have been occasions where work being performed by the
. Corps will be submitted simultaneously to me and to Mr.
. Simpson.
'0 Q What kind of ccmmunications have yod had with Mr. Otto .
- directly? .
A Telephone comunications and conferences and meetings on *Jw Mid l a nci project.
" Q What have been the substance of those comunientions?
- - A To go over what is expected of the Corps by the centract that we have, to discuss problems that the Corps have identified
~
in the review and as contract technical monitor to recoc: mend
- a solution as to how we can go forward in our review.
l '
Q What problems have you discussed with Mr. Ot*o that the Corps has identified in the review?
There are many prcblems. I think a snearf of those problems A
i
- is listed in what I have labeled NaC positions.
Q okay, and what solutions have you recommended so that the
- review can go forward?
A There was a period of time where the Corps' unders*m ding was, s - =~
l
88 1 KANE 2 because they felt there was so many outstanding issues, that
! they could not write a report because of those outstanding
- issues. I corresponded both by phone and by letter indicating ,
a to them that our contract specifically allowed for an interim 4 report which would identify those problems and where feasible .
make recommendations.how those problems could be resolved.
Q Were there any others, any other solutions that you recem-F mended?
10 A On :nany of the problems discussed or identified there would
. be discussions on how they could best be resolved.
Q Oc you recall the substance of any of those discussions?
"0 A I think there have been many. I can give examples.
~,
. Q Ckay, why den't you?
. A The Corps questioned, in reviewing the FSAR documents whether they could question the stability of the cooling pond dikes.
- We had internal meetings within NRC trying to resolve the
- safety categorization of the cooling pond dikes. That's one .
I example. We had meetings within NRC on the Corps request I- for additional borings. .'
Q I have here what has been marked as Consumers Exhibit Number
- 14, for identification. It is a report of a talephone or .
verbal conversaticn. It says, " Person calling J. Kane. Person called H. M . Singh , 5-i-n-g-h , and Ron Erickson. Date of call 6-26-80."
i
89 KANE 2 Do you recall having a conversation on l 1
June 26, 1980 with Mr. Singh and Mr. Erickson?
' A I have had many conversations with Mr. Singh. I don't recall
~
specifically that date.
Q okay. Do you recall a conversation on or about June 26 of
~
1980, the subject of which was the Midland letter report in
- which you advised Mr. Singh and Mr. Erickson that the report
~
was very comprehensive covering all the problem areas and that the questions had been spelled out explicitly and that you suggested some corrections in form of rephrasing some questions and that these did not change or alter the intent .
of the questions and further advising them to separate the
- questicus pertaining to the cooling pond into two groups? ,
A I do recall.
Q And do you recall that your advice with regard to separating the questions pertaining to the cooling pond into two groups were to separate them into one group which would be questions
' ~
on the e ergency cooling pond, category one structure and the other group being questions on the operating cooling pond ,
non-category one. structure 7 A I do .
Q co you recall advising Mr. Singh and Mr. Erickson in that conversation that safety of the diking system is very vitsi to the public health and safety and the environment and that,
- , - - , - - - . , . - ~ _ . , _ . _ _ _ , . , - - - _ _ _ _ _ , . - _ . _ , _ _ . _ _ _ , - _ - _. _ _ _ , , _ , . _ _ , _ . , , _ , . _ . , , , , _ , _ . , _ - , . . , , . _ . _ _ _ - . _ _ - - _ - - . , - _ - , _ _ _
I i
l i
l 90 1 KANE 1
2 therefore, its stability must be ensured?
! A I recall advising Mr. Singh that one way we could resolve 2 the issue would be to permit Consumers to address the .
t l
2 operating cooling pond portion, not the emergency cooling
- water portion, but the operating cooling pond portion by ,
~
asking Consumers to demonstrate that there was no safety l
I l
'i significance to the loss of that portion that would cause loss of life or large economic losses, plus create an I
I environmental hazard or if I recall correctly permit energency 1- access -- excuse me, access to be unavailable. I am done.
'2 0 so is it that you were then advising them of a way in which i
they could ask questions and get into the stability of the
" cooling pond dike by attempting to characterize it as a f l
S safaty significant structure as you have just described?
A They had the questions in the dike, based on the review of the information in the FSAR and I wa.1 attempting in the l
i I l
position of contract technical monienr to give guidance on
- l
- how we could best address the issue to where it was my feeling )
that we could get an agreement on the emergency cooling pond I
~
area matter with consumers and the other portion may *As longer to resolve, the safety significance. .
O I am sorry, when you say the other portion -- !
)
A The other portion of the cperating cooling pond outside of the emergency cooling uter reservoir.
- * = - - - _ _ - _ _ - - - , _ _ , , _ . _ , __
91 1
KANE 2 Q Okay. Why did you refer to the operating cooling pond as I non-category one in that telephone conversation?
=
A, I think I referred to it as being a position that Consumers
< 3 has for that portion.
i G Well, I'd like to show you the recording of that telephone conversation and I call your attention to the statement here in that "he" referring to you, further advised us to separate the questions pertaining to the cooling pond into two groups.
--' one, questions on emergency cooling pond category one structure and two questions on operating cooling pond, non-category one 2 structure.
I Have you had a chance to recap Exhibit 157 i
A I have.
Q Let's mark that Exhibit 14, rather, which is the Telecem message of 6-28-80 Is your recollection that in that ccnver-sation, that phone conversation, that you told them that the operating cooling pond characterization as non-category one
- was simply consumers' position?
A It is my recollection of that conversation that because it was questionable and being discussed within NRC whether it was category one or not, that the best way to approach it at this time was to break it into two portions where in my estimation you could reach an agreement on one portica quicker
, . . - _ , , - - , . . . _ .r_.--, , ,__w,,.,_m-,,, y_.. _ , _ . . _-.__.-~ ,_m_____. -..-....,,._._,m_,_,. . . . - -.._.-__ -.__..._ _ ,-.,_ -_ --
i 92 1 KANE than the other. The fact that he wrote non-category one , I 3 do not feel reflects my statenant that I was making that l
4 judgment. What I was indicating is that' that was what was ,
i being discussed and had to be resolved.
- l l ? Q And you recall telling him in that telephone conversation
( .
! then that that was a question that was being discussed within l 5 the IIRC and is still being subject to being resolved? -
! ! A could I see the awh4 hit again? I think Mr. Singh further
(
. . notes that there had been some differences of opinions
.. whether or not we have the authority to ask questions as to i
l .- the stability of the dike system over the cooling pond because I the cooling pond dike has not been classified as category one.
l ., I think what he is reflecting there is that there has been
~
l differences of opinion, and I don't read into this that they l
l have been resolved at that time.
1 O Isn't the difference of opinion he is talking about as to 3 whether they have a right to address questions to it since it 1 *
- is not classified category one, isn't that what you understand that to mean, especially in light of your recollection of ;
that telephone conversation?
l -
A Uculd you repeat the question? - .
MR. ZAMJUL7. : Read it back, please.
. (whereupon the reporter read back the
! previous questien.)
l 1
4
__.,_-----._,v- wo.-,-.y,.
r- --
-w-. . < . - - - . . - - - - , - _,__m-.. m-m..,___ _ , , _ . _ _ . ,
93
. 102 A It is my understanding that he is questiening because of what 0 he has reviewed in the FSAR, whether the cooling pond dike i is catagory one.
MR. SAMARIN : It is now 20 minutes past Perhaps we should break for lunch and return at,1:15.
12:00.
~
(whereupon the deposition was recessed until 1:15 o 'cicek , P.M. , Wednesday, October 15, 1980.)
S 4
4 G
e
94 EANE
- AFTERNOCN SESSION 1 Detroit, Michigan
! - Wednesday,' October 15, 1980 1
4 5
About 1:35 o'cicek, P.M. -
i -
1 JOSEPH D. I A N E,
't
. having been previous duly sworn, testified as follows :
- CROSS EZAMINATION
~
-- BY MR. 3AMARIN (CCNTINUED): ,
- Q Let's continue. Before we broke for lunch we had been discussing information with regard to settlement data that
'.. had been provided to you by Consumers Power Company and --
- strike that.
When did the cooling pond dike first become an issue or subject of inquiry within the NRC7 i
A When?
Q Yes?
A I am aware of questions that were asked back at the CP stage. ,-
Q Ckay, subsequent to the recognition of that problem when did the cooling dike become an issue or of concern within the .
l NRC with respect to its stability as possibly being affected by fill problems?
A In being identified by the Corps of Engineers in their review.
i
95 KANE Q And can you give us some kind of an approximate timing on
- that? Would that be some time around May or June of 19807 I am simply using that because 'that was your June 26, 1980 Telecom wherein you discussed breaking the questions down into two ways.
~
A I think it would have gone back to as early as the request for borings, the initial discussions on the, additional borings.
3 I think for your benefit it should be made known that I can recall discussions on the cooling pond before having 'that discussion with, Hari Singh , with personnel other than Hari Singh, and I specifically remember having discussions with Ron Erickson.
O Ckay, during these earlier discussions with Ron Erickson or with anyone other than Hari Singh and Ron Erickson in this Telecom of June 26, 1980, was the classification of the cooling pond dike as either catagory one or category two discussed?
A Discussed with whom?
O In any of those conversations that you had with either Erickscn or sor one else from the Corps prior to June 26th, 19807 A To my recollection it was discussed. .
Q All right. With whom and when?
A It may have been others , but I feel confident that I did have discussions with Ron Erickson at the time that the Corps first
__ _ . - -. . , , _ . _ . . _ . _ . _ . , . . - . _ . . - _ _ , _ _ . __, ___.-__s,__ _ . , _ . _ , , _ , _ _ . , . , _ - , _ _ . _ , .-.-...._--, _.
96
- KANE 2 indicated to me that they were going to request additional i borings.
4 Q Okay. Do you recall when the first of those conversations .
! took place?
A I am guessing. Around April, 1980 ,
Q And that was with Ron Erickson, did you say?
- A Yes.
Q And possibly others7 i -
A Well, I don't recall any other Corps personnel having
]
discussions. I know there were discussions within NBC.
-l -
Q okay, at that time around April of 1980, can you tell us what 4
the substance of ycur conversation with Ron Erickson was as
' it relates to classification of the operating cooling pond i
as a catagerf one or category two structure?
l A The substance of my recollection is that the corps in
! reviewing the data submitted by Censumers in the FSAR had raised questiens , questions that the corps were raising, and ,
there were discussions on what portion of the cooling pond l
l was category one.
For example, did Q p d how did that discussion come about?
acn Erickson say , " Hey, we got some questions about the ,
i cooling pond dike , what portion is category one?"
! A I think, to the best of my recollection, I think it came about by them identifying borings in the cooling pond and my checking l -
e
+- '--w w-- , -w-,_-ew- . , , , , . _ , _ , _ . . , , _ _ _
I 97
. KANE 2 the FSAR documents to understand what had been documented I with regards to categorizing the cooling pond and then trying to understand the function of the cooling pond, particularly
! the emergency cooling water reservoir area and the other i cooling pond, so it was initially brought about in discussion because of the Corps ' request for borings in the cooling pond
- and I was attempting. to understand the correct categorization
- of the cooling pond to know whether we would he requesting borings for the entire cooling pend.
Q so was your investigation then prompted by the issues in
- that December 6th order were limited to safety related
,a structures, and when I say safety related structures, I mean such that an investigation of it would come within t.% perview of that o,rder?
A It is at the time of those discussions in May, April cr May of 1980 - I dcn't recall discussions on the scope of the December 6th hearing. As I have indicated, the corps has been given the responsibility of evaluating the Midland
- project to the SCR or the CL.
Q And what difference did it make to you as to whether it was a category one or a category two structure if they wanted the .
information?
A What difference does it make to me?
C Did it at that time in April of 19807
98
- KANE
- A There is a distinction in our review to what extent of review 3 we would go to depending on that categorization.
. Q Can you explain to me what you mean by a difference as to .
. what extent of review you would go to depending on the
- categorization? .
A A structure that has been categcrized as category one , safety related, would be subjected to a more detailed review than soesthing that does not have that categorization.
Q Exhibit 14 indicates Harry Singh, noted from his telephone
. conversation with you that whether or, not we have authority,
.. we being the Corps , whether or not we have authority to ask
. questions as to the stability of the dike system of the cooling ponc because the cooling pond one has not been classified as a category one structure , and in June of 1980, or in April of 1980, either of those dates were you of the understanding that if the cooling pond dike was not classified as a category one structure then the Corps or the NRC didn't have the ,
e authority to ask questions as to its stability?
A Would you repeat the question?
- MR. ZAMARIN: Would you read it back, please (to reporter)? ,
(Whereupon the reporter read back the previous question.)
A There are many parts to the question. Let's start from the
99 i KANE
, 2 back. Does the NRC have themathority to ask questions about structures that are not category one, is that part of your question?
! Q okay, within the perview of this review that the Corps was doing that the NRC was doing, was it your unders*=aM ng in April and/or June of 1980 that the Corps and/or the NRC had
- no authority to ask questions of Consumers as to the stability of the dike if the dike was not a Category I structure?
A As farlack as April and May of 1980 when the Corps had indicated they were going to ask for additional borings there
.2 were meetings with NRC attempting to reach a conclusion on l
the categorization of the entire cooling pond. Those discussions resultad in a decision to support the Corps'
.' request for the additional borings in those areas. That decision is reflected in the June 30th letter to consumers I
asking for those additional borings.
. Could you give me the date of tnat
' ! exhibit?
Q Here, I will just give you Exhibit Number 14.
A The date of Exhibit 14 is June 26th, 1980. The question that l -
Hari Singh is raising, I think is a question due to Hari singh and his coming on board as a reviewer after the initial 1
1- -
discussions in April and May of 1980. The issue to support the Corps request or not to support it had been resolved by 4 t : . : . :
- i
>1 . 1., .
, . _ - - - . . - - , . - - _ _ . - _ - , .__,- - . . - - . ~ , . - , . . , - . - . . . - . _ . . . _ - . . . - - , _ . - .. . . . _ _ , . _ , , _ _ , -
100
. KANE O that time. 9
- Q Okay. Really what I am asking is whether the Corps' request t was going to be supported or not. Were you on the understand- .
! ing that in order to have authority to ask quaestions as to ,
~
i the stability of the dike that it either had to be a Category
- I structure or that'it had to be assumed or taken or given 3 that the safety of the dike system was very vital to the
- public health and safety to the environment and that, >
therefore, its stability must be assured and that as such j
- you could ask questions on the diking systems?
U A It is my understanding the authority of the NRC is concerned
'2
- with radiologically related safety considerations. It is
.. also my understanding that because of other work as a Federal agency that NRC has been asked through a directive of President Carter to examine their dam safety program and I -
~
have it comply with the results of a study which were
- culminated in a Federal guideline, and so being familiar l
- l
- with what was being asked under the Federal Dam Safety
- ' Program I was making judgments that the safety of the cooling ,
I- pond could fall under the Federal Dam Safety Program and was
- - attempting to convey that to the management level because of .
I that concern.
l l
l Q Was it your understanding than that in order for the NRC to l
have authority to inquire into the stability of the dam that g ..... .... . ...
,.-,.n -
,--,,,-,-.,,,,w, ,n,- ,- -- ,..-,- --,_,,,n_w,-.,-e-,,.,,.._.e_,., ,,------.--,.c ,__,_ _ , , . , ,.,.,..,ne -_~,,,-a ,--mn--_v,,---
.- --. .-. ~. . _.
101 1 7.ANE ,
P it either had to be a Category I structure or had to coes
- within the Federal Dam fafety Program?
, A or whose failure could cause unsafe conditions because of
! ! radiological consequences.
- ' Q Is the operating cooling pond dike in your opinion a structure whose fallure could'cause unsafa conditions due to radiologi-
. cal considerations?
A There is a portion of the cooling pond, that portion having
'. a Category I conduit at the base of the embankaant that in
- my opinion could cause radiological hasards.
Q Could you describe for me again how that would occur? .
! A If the dike were not properly ccsapacted and the dike when saturated under full use during years of operation would cause, because of the saturation, a reduction in shear strength, which is differant than the conditions we now have and that reduction was enough to cause instability of the dike and '
i
- cause it to slide, that slide in its movement could take ouc l
the Category I pipe. :
Q okay. When you say that slide in its movement could take out i
the Category I pipe, you mean that Category I pipe would be a part of the slide?
A It would be in the -- could be in the slide mass and be disrupted to where it could not function. i l
Q so you are saying it could be in the slide mass that is part i ,
- * * *
- 1 s , {
e o s i
102
. KANE 2 of the slide that slides away?
- A That is correct.
Q And that is the basis for your opinion that at least that I portica of the operating cooling pond dike should be Category -
! I classified, is that right?
A Yes.
. Q As I understand you, to the best of your knowledge, the dike within the NRC still remains classified as Category II, but that is under reconsideration right now, is that a correct
- characterisation? ,
'l A Not totally correct.
- 0 okay.
A As far as I know the last discussions that I knew of within
' NRC that was still being discussed and there had been no decision on which portion is Category I and is not category I.
I Q okay. Well, at some time, however, at the CP stage didn't I -
someone at least a reviewer or someone within the NRC not .
- object or not question the stated classification of the
- entire cooling pond dike as Category II7 ,
t l
A I am not aware of any letter that objected to it not be l
l :. classified as Category I. ,
I Q Okay. What I am aware of is a conclusion in the SER that I
concludes the dike is safe against the equivalent of an SSE I
-' loading. Even though the decision hasn't been made within
,; : : c e: = -
- ---- --n, , _ , , _ _ _ _ _
, i 103 1 KANE
- the NRC as to whether the dike or any portions of it should
- be dassified as Category I, questions have been asked of
. Consumers requesting information as though it were in fact e classified Category I, have they not?
i A No, that is not correct. In the document that we referred to this morning the Corps report, which is dated August 4th
- and being transmitted to Consumers, attempts to per: nit
~
. . Consumers to respond to the dike as broken in two parts,
. the one part which we felt was Category I and the other part which you could respond to and not categorize it as
- Category I.
Q okay. Well then, perhaps I was inprecise in my queetion.
. The question, however, was asked of Consumers on the basis
. of at least a partion of the dike being Category I, even 9
though that determination has not been made within the NRC,
.i is that correct?
i A The final determination by NRC management has not been made l - as far as I know, and to answer your question, yes.
l I have here what has been marked Consumers Exhibit f Q Okay.
l Number 15 for identification, and I'm going to show that to j - you and ask you to just take a quick look at it and tell me l
if you recognize what that is?
We received that from the Corps files that you produced yesterday.
- . : i.
.re; e e
b
,_,----y,,. - - - ---r- ,..ww . _._.mr_..
7__my, , _ ,-_,_.e_,~_, . . - _ _ . - . . , , .,m., , ,.- -.-.- ..- _ , . , . _ - _ ._.. - -. . ., . --
104
. KANE
- Do you recognize that document that has
- been marked as Exhibit Number 15 or that which purports to be
. a copy of it? .
A I recognize the earilar portion. The contents or the comment.s by Simpson I have not reviewed. ~
When you say the comunents by Simpson you are referring Q Okay.
i to the last six pages that are on a form noted as " Reviewer's
. r*-rits ," but then on the back of that there is or there are some other enclosures and I ask you to take a look at that.
. It is marked Enclosure 2, and ask you if you have seen that
- before?
A I would have to review these two drafts to determine any diffarences. If they are the same draft as is the first one l
then I would say I have seen this one and this one (indicating).
Q Okay. What is the first one? When you say "this one" which
. one are you referring to?
A A draft dated March 24th, 1980. ,
Q A draft of what?
A A draft of a letter report from the U. S. Army Corps of .'
Engineers to the Nuclear Regulatory Cnemnission.
Q Have you referred to this earlier as an interim report? ,
A It is a draft of an interim report.
Q Okay, and you say that you have not reviewed or have you not seen the reviewer's comments that are the six pages attached
- : : , : ?
1
105
- EANE to it?
A Last night when given the Corps' deposition documents I saw
- that, but that was the first time.
Q Do you know if anyone within the NRC had seen those reviewer's
! coasmants prior to you seeing it last night?
A It is unlikely, but I do not know. .
Q On Page 3 of the draft interim report that has been marked Exhibit 15, under a subparagraph small e, which is headed
" Miscellaneous structures constructed on fill not covered in Paragraph 2 below,' and the Paragraph 2 below refers to l
remedial measures for Category I structures on fill, it 1
indicates that sand pockets have been noted in cooling pond dikes which lead toward the river.
Do you know where sand pockets had been noted in the cooling pond dikes? By t.' ult I don ' t mean the location in the dike, but who noted it and how they noted it?
A I do not recall having any discussions with the Corps on that particular item and so I will answer your quos': ion as to how I feel it has been determined.
Q Okay.
A It has been determined by a review of the boring information that had been submitted.
Q And it has been determined that there was sand pockets, in 1
i your opinion, in the cooling pond dikes on the basis of
- 4 l
- - - . . - - . - . - - - - - , - .._..m.__-._-.. _ _ _ . . - _ - _ _ , , , .,__,-mv, , . _ . - - - . _ , , _ , _ , , ,. . . - - , , , . . , , _ _ . - --.,__-r.-,,
106
. KANE
- boring information submitted by Consumers?
.' A Would you repeat the question, please?
, MR. 3AMARIN: Could you read it back ,
t (to reporter)?
j i (Whereupon the reporter read back the ,
previous question.)
A In my opinion I cannot answer something that I have not
. reviewed. My opinion that I expressed was that the person
. who initiated that document came to that conclusion. I have
. not reviewed that aspect. .
.2 Q Do you know who it was in the Corps who noted sand pockets l in the cooling pond dikes?
I can
.- A Eaving not discussed it with the Corps I do not know.
- potentially name the person that it may have been.
Q Who would that person be?
A Either Ron Erickson or William Otto. I am sure one of those two would know who it was. ,
Q Was this statement on Page 3 of the interim report, dated March 24th, 1980, the first indication to you that there may .'
- exist sand pockets in the cooling pond dikes?
i A To the best of my recollection, yes. ,
Q And do you know whether this information has been conveyed to
- Consumers Power Company at any time?
A I would have to check that document against the final document
- i
107
'. EAME
- against the final document that was submitted to Consumers
- Power.
Q And if it is not contained in the final interi:n report that i
i was submitted to Consumers Power Campany are you aware of any other method of communication by which that information was conveyed to constamars?
A I would have to think that it was not conveyed to Consumers and if i't is not in the document that was conveyed to i
.. Consumiers I would believe that in further review of that statement that it was indicated that it was not a significant l concern and was deleted.
! Q In addition the statement in that same paragraph says, "Was
. the dike properly compacted?" And was that the first time i
that the issue of proper compaction of the dike was raised, to your knowledge?
A No, I do not feel it is the first time. I feel that in l
discussions with the Corps at previous meetings such as the 4
l February 27th and 28th, 1980 meeting that same concern was I
expressed verbally.
l Q By the Corps?
~
A By the Corps and by others.
Q What others?
i A I think Lyman Heller had also had the same concern.
MR. ZAMARIN: Off the record a moment.
1 . : .
I
108 1 KANE 0 (Whereupon there was a short discussion 3 held off the record.)
Q (By Mr. 3amarin, continuing) : I have here what has been ,
! marked as Consumers Exhibit Number 11 for identification, -
3 and this is a collection of five pages, the first of which is headed "NRC Position-Diesel Geterator Building," and take a
- look at that and tell me if that is written in your hand 7 i A Do we not have airhibits beyond Number 117 MR. 1AMARIN: Yes, we do. These have been pre-marked.
C A okay. What is indicated to me as being Exhibit 11 is a 1' document that is my writing.
4 Q okay. Why did you prepare that document? . .
i A To better inform the management of NRC. A meeting was established to permit the staff to present their concerns to the higher management level of NRC. Those notes that appear on that document are my summary of the points I had hoped to cover with NRC management.
! Q When did you prepare this document? /
A The document has a date.
Q ch, I see, on subsequent pages it appears to bear the date ,
of 9-27-80. Would that be the date that you prepared it?
j A Yes.
Q Did anyone assist you in preparing this document?
109 JULME 2 A No one assisted me in the preparation of that document.
- Others assisted me in the preparation for the meeting and
, the contents of the meeting.
Q Okay. Who were those others that assisted you in preparation for the meeting and the contents of the meeting?
~
A The Carpe of Engineers.
Q Who in particular was in the Corps?
A Particularly Hari Singh with input from W4114 = Otto and
. Jim Simpson.
Q What input did Jim Simpson have?
1 A Recommendations to be clear in identifying our concerns.
There was no special item that was listed there that he himself brought up. ,
Q What input did Hari Singh have into this document?
A. The input that Bari Singh had into the document was in
~
discussions that I had with Hari Singh in attempting to identify and summarize all our concerns and to make them clear
, to where we could address them to NRC management.
O Can you point to specific items within the document in which l
Hari Singh had input?
A Could I see the document?
Q Sure.
I A Hari Singh had input into Item 3, 4, 6, 7, 8, 11, to the l l
best of ny recollection, they were the items that I recall 6
.. . . . , . - _ . . . . - _ - - - -l
< 110
- KANE
- which Hari singh had input into.
l : Q what was willian otto's input or contribution to assist you
, for preparing for the contents of the meeting? .
! 3 A whereas I had detailed discussions with Hari Singh on the -
l i
itsas we wished to cover I did not have those same discussions with william Otto, and to the best of :ny recollection the
. input of William Otto were his counnants that he had relative -
. to try and understand Conssumers ' objection to running the
, consolidation tests, so there was no direct input, but there
.. were discussions that touch on those, items.
. . MR. SAMARIN: Could you read back that
.: answer, please (to reporter)?
i
)
(whereupon the report read back the i
. previous answer.)
Q What were william otto's comments relative to trying and
." understand Consumers' objections to running consolidation tests?
- A That our concern on the magnitude of additional settlement could be resolved by running the consolidation tasts and -
questioning the reasons that constanars has for not running those tests.
Q In what way were the reasons that Consumers had for not running them questioned?
A Trying to understand Consumers' stated position on the
-,--,---,-,----me--
111
. KANE
- inadequacy of the state of the art.
- Q Okay. Really what I want to know is how did you go about
. trying to understand that? I mean, what did you say and what i did he say?
- . A To the best of my recollection he had indicated that because there was a question on what additional settlement we could expect under future structure operation that it appears
. reasonable to him to resolve this by running the tests and
. he questioned conmuners' position of not wanting to run those
. tests and trying to understand why would they not have
.; confidence in the results of those tests.
Q Okay. When you say he questioned them not wanting to run them, did he, for example, say to you, "Why don't they want S to run them*?
I am really trying to understand what he did in any questioning of their not wanting to run these consolidation tests.
A What he is saying in his years of experience and his good confidence in being able to predict settlement using that type of tests, he is trying to understand why that same feeling is not shared by Consumers Power Company.
Q Is Eari Singh of the understanding, to your knowledge, diat the fill underneath the diesel generator building is hemo-genous?
G 9 W
m O 9
-n-., , - - , -e- ,, , - p --,- , -w
112
. KANE r 2 A No, Hari Singh is not of that opi&n.
- Q Is Rari Singh of the opinion that the fill underneath the
- diesel generator building is heterogenous? .
5 A I i hi nir there are portions if you take the full li: sits of '
i the diesel generator ba41d4 M where it could be indicated that the entire depth of the fill is clay and it could be constzued in that portion where you have the full clay that
. it is essen*4=11y homogenous in the sense that it is all
. clay, but I feel confident that Eari Singh does not look at
.. the diesel generator building in its entirety and conclude
. that it is homogenous.
l Q In your opinion is the clay underneath - strike that.
In your opinion is the fill underneath the diesel generator building heterogenous?
A Using a broad general description, yes.
Q Based upon your experience as a geotechnical engineer would you then expect in taking borings of the fill underneath the
. diesel generator bn41 ding to get a scatter of results because of that heterogeneity? J
. A I would expect a scatter of results.
Q And would you then expect that'results obtained in the lab ,
based upon that scatter test might provide some results that
~
are not reliable with respect to the entire body of fill beneath the diesel generator building?
e
113
- KANE 0 A I would hope the sampling program and the laboratory testing
! program would be conducted properly to where I would not
- question the results. The question is not of the results but in how you use those results to take into account'the i heterogeneity of the fill.
Q okay. What would you do in order to ensure that a test were conducted properly so as to take into account the hetero-i geneity of the fill and the scatter of the samples?
A I would use the boring infor: nation that you have submitted plus the horing infor: nation that we have requested and use
'l
- that with the results of the laboratory testing and attempt 2 to make an estimate, =4 a4== and :naxi:num of the settlement i that I could expect.
Q Would you 2;ees that the most reliable method of determing a property such as ==v4=um and m4n4== predicted settlement
'~
- is in actual field testing, proof testing?
MR. PATON: Excuse me, just a inute.
~
-- Could I request that that question be reread?
-- (Whereupon the reporter read back the
- previous question.)
A I would agree it would be the most reliable method for estimating the range of settlement previded that the very important time element that consolidation requires to take
114, i KANE 2 place is fully addressed.
2 Q What parameters would you require from consolidation tests i to help predict settlement? ,
i A one of the main parameters that we would hope you would '
5 develop in the requested testing is the identification of .
the pre-consolidation pressure'from the results of the consolidation tests and we would want to compare that pre-consolidatien pressure with the stresses that you have
'. 0 indicated were induced in the foundation soils under the
-- surcharge load to see if in fact the, surcharge and its load
- was fully effective in developing the stresses in the C foundation soils.
l' Q I am sorry, was fully effective in doing what?
A Was fully effective in producing the stresses in the foundation soils.
O Is that the extent of the parameters that you sould require ;
from the consolidation tests? .
A It was an important parameter. If we find in fact the pre-consolidation pressure was less than what should have been ,
developed under the surcharge loading, we could use that' data to predict future settlement and some other data that we .
could get frcan the consolidation tests is the compression index.
Q what would you do with the compression index7 e
e
115
. KANE 2 A Use it to estimate future settlement.
- Q Anything else you could get?
_ A You could get resolution of the effectiveness of the surcharge a program.
Q And how would you do that?
A Sy havi*ng good agreement between the conclusions of the surcharge program as you have submitted with the test results.
. Q How would you determine the length of time that a pre-load should be in place for a heterogenous fill in a structure
.; such as the diesel generator building and the fill thereunder?
..' A S4m41me to what Consumers has done by installing the piezameters and measuring the settlement.
Q *dould sampling disturbance have any effect on your pre-conso1 Mation pressure parameter, your ability to obtain that accurately?
A If the sample is disturbed, yes. If we took the best possible control in sampling and testing and then making a correction for that sampling disturbance between lab or field data, I could have reasonable confidence, based not on one test, but a series of tests that I have identified the pre-consolidation pressure.
Q So in your opinion you would have to have the best possible controls in ob*24n4ng the sample and then nake correction:
1 l
116
. KANE
- to account for sample disturbance between the actual field
- condition and the laboratory, is that right?
, A Yes. I indicated the best possible control in sampling but ,
also the best procedures for testing it as well as being '
. concerned with the sampling.
Q Is the absence of sampling disturbance something that is a commonly obtained in actual practice in this type of a situation? .
. A would you repeat the question?
.. MR. SAMARIN: Can you read it back
- (to reporter)?
(Mbereupon the reporter read back the previous ques 1Uon.)
.+
A You can min 4=4ze the amount of the disturbance by careful control in your sampling and handling and testing the sample, so it =4*4=4 zes that disturbance. You can still expect some distn
- nm.-
Q How would you use a compression index parameter if there is no more load to be added to the diesel generator building .
structure?
A How do you use the Ocupression index?
l Q Yes?
A I think it is recognized that some soils are consolidated l
under the present loading or past loading and so the
. . : i : -
j eo
~
117
. KANE
. consolidation tests would premit us to determine if the
- plant fill was under consolidated under the sur=harge program and the reason it could be possdbly under consolidated is that the surcharge program because of the conduits that are in the foundation, because of the difference in the material, that heterogenous material in the plant fill where you did not get a uniform distributina of the pressure, and for those reasons we may not have fully consolidated the compressable soils under the surcharge loading.
Q My question, and I am not sure whether you answered it or'not, was how would you use the compression index if there were no
-: more loads to be added to the diesel generator building?
A I thought I had answered it, and what I i:n saying is that the plant fill soils have not received the full mnimum 1= ding that we can expect during plant operation and that additional load could cause settlement and we could use the compression index to estimate the further amount of settlement. <
Q If the plant fill soils have been stressed in an amount at least equal to that which would exist during the use of the structura then there would be no value in the compression index calculation, is that right? l l
A If they have, that is correct.
)
1 Q If the pre-consolidation pressure exceeds the existing pressure, including the weight of the diesel generator 4
118 i N
- building, would you then accept the secondary consolidation settlement position that has been made and presented by
- Consumers?
A Would you repeat the question? '
MR. ZAHARIN: I could, but maybe he better read it back.
, (Whreupon the reporter read back the previous question.)
A You would not only have to exceed the dead weight of the
, building, you would have to exceed future an+4aiMead live
- - loads and one thing that also has to be addressed is what
- effect extreme environmental loads could cause as far as
. additional settlamant.
- Q Let me make sure that I understand this.
If the pre-consolidation pressure exceeded
. the existing pressure, and including the dead load and the j ..
live load that would be induced in the structure, you would still not be in a position to accept the secondary consoli-dation settlement prediction made and communicated by J r
- . Consumers?
.. A If the consolidation testa reflected a pre-consolidation ,
pressure that exceeded the soil weight, the structure dead weight, the live loads is it exceeded those values, for myself, and I cannot speak for the Corps, I would be more
- - - - r ,- - , - , .
11S
- . EMER
- inclined to accept than the secondary consolidation.
Q You indicated soil weight in that answer and what soil are you referring to?
A The weight of the soil under the plant width.
. Q what do you mean by extreme envirnamental loads?
A Earthquake loads, wind ic<tds , tornado 1anda.
- 2 .
Q The extreme envirnamental loads that you referred to would ,
be of the nature like an instantaneous load, would they not?
A Yes.
Q A short duration, and it is ,really not the same type of loading at all that-we are talking about when we are consider-ing the dead load and the live load of the building and the weight of the soil?
A You are correct. It is not the same type , but it is a type of loading that strmtures are designed to withstand.
Q How would you factor that into your consideration of pre-dicting long term settlement of a building such as the diesel generator building?
, A Factoring it in now is difficult. What I would like to have done is factored it in by making my surcharge lead large enough to have covered those leads. ,
Q Can you give me some magnitude of those loadings , for avample , a percentage of the total dead weight of the diesel generator plant?
. - .-- a
?
120 KANE 2 A I think it is more a question of the structural engineer, but
- in guessing I would indicate that it would be as high as 30 t
- per cent of the other loads, the extreme environmental 1 cads. .
i Q so you, when you say of the other loads, you mean of the dead .
i load and the live lead? .
A Yes.
- C Is that a figure that you would use then, a figure of 30 per
.' cent? You say it could be , what would you use as a figure?
.~. A I would estimate the actual loading for the specific soil.
I Q Well, really what I am asking you for is if you can estimate
- that for me now? -
I would have to look at the structure and the i .
A No, I cannot.
l earthquake leading and the other loading.
l .
Q What soil parameters do you need to know in order to estimate movement due to such environmental loads?
A Are we talking about settlement or soil behavior in general?
Q We are talking about settlement first. ,
A Eecause of the nature of the loading, the instantaneous leading, and because of the nature of the types of soil that we have involved, and that is clays and sands 'and silts , it would be very difficult to predict the settlement under these environmental loads , but it would not be thought *w be a significant a= cunt, but it would be some amcunt or it could
- be scme amount and what I have tried to indicate is one way of
-- -=
. 121
- KANE
- addreeing that would have been to have made a surcharg e i
- large enough to cover those loads, i Q What type of materials do you understand to be contained in the plant fill under and around the diesel generator building?
A Would you repeatleur question?
Q Yes, what ty;:ss of materials is it your understanding exist -
under and around the diesel generator building in the fill? l l
- A I understand the types of materials that are under and around l
the diesel generator building to consist of sands , clays , l 1
. silts, a mixture of them , and pockets of concrete. !
l
.. Q Is it true that a consolidation test would not provide the l direct answer to the amount of settlement due to extreme environmental loading?
i A That is correct.
Q Okay. At Page 4 of what has been e.arked as Consumers Ixhibit Nummer 8, there is a discussion which states that the technique of extrapolating from full scale test results is the =ost reliable method for predicting settlement. Normally l at the start of a job sampling and testing are utilised to l
predict the settlement. In the situation of the diesel generator building the surcharge program provided the cpportun-ity for direct seasurements and eliminates the need for i
sampling and testing and eliminates shortcomings of theories of sampling and testing since measurements in the laboratory i 1
I I
e
122 KANE 2 are :nade to an accuracy of 1/1000 of an inch. However,
! laboratory sample is only 3/4 of an inch thick whereas the probable error in estimating the field settlement of a 28 ,
foot layer over a 40 year life of a plant based on that single quarter inch labcratory test would likely be of the order of 1/2 inch due to measurement sensitivity alone, not even censidering the effects of sampling disturbance and representativeness of the samples.
- Would you agree with those statements?
A Can I see that? ,
C Yes. What I have done is I have somewhat centracted them, but do you have that in mind?
A I am semewhat familiar with that paragraph. My ecmments on it are that the paragraph clearly raccgnizes the limitation of laboratory testing. Must it fails to recogni=e is that there are also lindations on field testing, . an important one being the time the field test is imposed, and in addition .
the field test that was conducted at Midland is unique and that uniqueness creates a very difficult aspect to evaluate, and the fact is the pre-leading or the surcharging actually was done after the structure was built. Normal practice is .
to do the pre-loading to squeeze out the settlement before the structure is built, and so what you would have at".empted to avoid normally by pre-loading you ham in fact induced into
121 -
'. KANE
- your structure by the pre-loading and that is a very diffi-
' cult thing in this particular case to evaluate and so I would agree with the statement that field testing when held to a long enough time so that there would be no question of its effectiveness would be a battar solution than the other.
Q You mentioned in the body of that answer, I think, building stresses. Is building stress an area of your concern or is that someone else's , if in fact you did mention building ,
stresses?
A I did mention building stre,sses. As a professional engineer
- I cannot separate my work and how it impacts on other work.
I recogni=e that the settlement that has been induced and potentially the future settlement can introduce stresses into the structures, and frcm my input into the :t ady I am attempc-ing to come to a cenclusion on a goed prediction of future settlement recognizing that predictica affects ulti=ately the stresses that are induced in the building.
Are you aware as you sit here now of wnat stresses, if any, Q
have been induced into the structure as a ssult of the sattlement to date and the pre-loading program?
I do not knew magnitude of stresses . I can see visible signs A .
of overstressing by the cracking that has been evident in the diesel generator building.
Q Ckay, and based upon your qualifications and expertise are ycu I
I J
. 124 .
. KANE
- able to make some kind of a qualitative assessment of the extent of cracking and the magnitude of the cracking?
- A That is not my function to make that evaluation.
2 O okay, I know it is not your function, but I asked you if that
. was within your area of expertise and qualifications?
A If requested to do l's I feel I have the capability to do it.
. Q Okay. Do you have an opinion with :egard to the magnitude et
- the cracking and the extent of overstressing that the diesel generator building has been subjected to?
A My opinion is based on a response by the Corps in the report 7
- that was transmitted to consumers on August 4th which talks about overstressing of a conduit because of the settlement i
.- that was exmerienced. That is the only feel. for the magni-I tude of stress that I have.
i G Okay. In Exhibit Number 11, which are those notes that you prepared for that meeting which was what, sometime around the and of Septeocer,19807 .
A That is correct.
Q Okay, in the first paragraph or at least under the item thatt j you have marked number one, you state: "at 's look at the pre-load program completed at Midland. Plan view of DG-3, start with view Number 1," and then there is a statement ' stress need to consider ~4e element. "
What did you mean by that?
t w- -- --m, - - - - - - . . , _ - , _ _ . . .
125 i
N
- A For a surcharge program to be effective it has to be held long enough to where the pore pressures that are generated under that surcharge leading are fully dissipated if we anticipate reaching secondary consolidaticn.
- Q Have you had any experience other *han Midland in pre-loading
- a. completed or partially com:pleted structure?
A No. I have attempted to search the ter hnical literature for ai=ilar experiences. .
, Q Have you found any?
A .I have not read the article , but I have been told of one
.. other structure that appears in an ASE Journal.
~
Q What structure is that?
A I do not recall the name.- I have not read the article.
C Do you have a copy of the article screewhere?
A I have the ASE Journal in which it appears, in which I am told it appears.
O I'd like to see a copy of that.
. A I am sure your technical people have a copy of that same journal.
Q I just want to make sure that I read whatever you read, so I'd like a copy of that. Would you provide us that?
Off the record.
(Ltereupon there was a short discussiens held off the record.)
126
. KANE
- Q Who told you about that ASE Journal in which that article appears?
, A Lyman Heller.
Q Do you know if Lyman is aware of any other situations where .
surcharge of a completed or partially completed structure -
has been undertaken?
A Lyman Heller had the same question that I had earlier when he was working on the Midland project and it is my understand-i g he was directed to that article by your consultant, Doctor
. Handron.
- MR. PATON : Off the record.
(whereupon there was a short discussion
- held off the record.)
Q You indicated that in this statement " stress need to censider tir.e element" that that was because of your opinion that the surcharge must be in place long enough so pore pressures are fully dissipated, is that correct?
A Excess pore pressures.
C 5nd how would you determine whether the excess pore pressures ,
are fully dissipated? Would that be by pie:cmeter readings?
A Yes.
Q And would you then have some way of determining when the excess pore pressures were actually dissipated as a result of those piezemeter readings?
9
127
. KANE
- A A study of the piezometer data should per: nit me to come to that conclusion.
. Q okay, and what in that study would permit you to come to that a conclusion?
~
A The behavior of the piezemetric level after removal of the surcharge.
Q okay, describe the behavior that would lead you to the con-clusion that enough excess pore pressure had been dissipated so as to be fully dissipated?
. A I would expect to see a piezemeter graph, a graph of a piezeme-
- ter data after removal shewing a stabilizatien with no signifi-
- cant drop following surcharge removal and that when the sur-
. charge was removed the level that I would be viewing would he the level being controlled by the natural water drainage in that area and not being centributed to by excess pore pressures.
Q How do you determine if it was being influenced by the nor=tal water regime in the area as opposed to excess pore water pressures?
I A By attemp*%g to establish with other piezometers what the
! normal ground water regime is in that area.
Q You indicated that you would expect to see on a graph of the piezameter data after removal stabili=ation of no significant drop following surcharge removal. Would you expect scee drop as a result of rebound that you would expect, for example, en e e
.- , -,y -- ---,-, ,,- .--.,- - - -,.--- - - - - . - - - - - - - ---
l 128 1
1 KANE j
- soils such as those in the fill underneath the diesel genera-
- ter building?
A Depending on the type of the soil there would be some re-
, bound, but the level to which it rebounded tol.would expect ,
it to have stabilized to that rebounded level.
Q You would have expected the piezameter level to stabilize to the rebounded level, is that what you are saying?
A Yes.,
. Q So you would expect to see a drop and then a rebound in the piezameter and then it would be maintained at that rebounded
.. level?
.'. A Yes.
O And after seeing all of that would it then be your conclusion that the excess pore water pressures had been fully dissi-pated?
A I would use that information along with my settlement =easure-ments.
And your settlement measurements showing what?
. Q A Shcwing a change in the plot of settiament versus time and the ,
enange reflecting leaving of primary consolidation through secondary consolidation.
G Are you referring to a settlement plot versus a log of time i
plo t? ,
A Yes.
t 1
129
- KANE
- Q Which would then begin to approach a straight line curve?
- A You would have a straight lins curve in primary consolidation .
1 1
, and I would expect a change out of that into another straight i
5 line position. l
- Q What you are saying is that when you plot settlement versus
. log of time you would have a straight line plot dur,ing
- primary consolidation?
A That is correct.
Q And then that would change that to some other straight line
.- plot with another slope?
A Yes.
Q And you are referring now to a settlement versus log of time
.- plot, is that right? .
A That is correct.
Q Have you done any work with surcharges regardlass of whether it was related to a building which was constr 2cted either com-plately or partially constructed at the H--e of the surcharge?
A Would you repeat the question?
, MR. ::AMARIN : Would you please read it back (to Repor+ar) 7 (Whereupon the Reporter read back the ,
previous questien.)
A The way I understand the question is that you are asking what experience I have with surcharging, whether there is a
- E e
130
. KANE 2 structure there or not?
I Q Yes.
- A The experience I have in the 20 years of geotechnical engineer- .
ing experience includes the construction of many dams wher,e i loading of the dam would introduce the same type of behavior in the foundations which could be observed by piezameters and i settlement as any other surcharging program would, so there is similarity in what would be developed and what information
. would be gained.
- To answer your question more directly I l have not worked on projects where surcharging was used as a
-- remedial measure to eliminate a problem with a compressable soil.
~
Q On the ones on which you have worked relating to construction of dams were predictions of settlement made based on measured settlement and piezameter data?
A Yes.
Q And approximately how many such projects have you been involved with?
A At least four..
Q With regard to a surcharge program such as that associated with the diesel generator building at Midland, would you expect l
the soil to develop a negative pore water pressure during re-bound of the structure following removal of the surcharge? ;
9
131
- ICwE 2 A So that others may appreciate what is meant by negative
- pore pressure, I would ask your definition of negative pore pressure.
C Do you have a definition of negative pere pressure?
Negative pore pressure can mean different things in geo-A ,
~
technical engineering and that is why I asked you the question.-
Q Would you tell us what it means to the geotechnical engineer?
A I am saying that there are variatiens. I think you mean a
. pore pressure which develops which is less than the pore pressure that exists from th,e surrounding ground water regi=e. <
I and I think you are referring to when a soil is a dense soil
- it could be shown where because of an exparvion of the voids you could get a reduction in the pore pressure and that could be identified as negative pore pressure. With regards to the Midland settlement I think at a piezemeter you could get a relief with the removal of a large load to where you would I
get a reduction in the pore pressure, but in my own feeling what happened at Midland was that negative pore pressure that is being reflected by the reducticn in the piezometrio 18v*1
- is a localized thing, localized in the area of the piezemeter and where ence the source of the water that is available at .
the piezameter is used up in the voids which have, or the volume which has been expanded because of relief of that sur- !
charge, that the pore pressure of the soil mass that exists in
- , ., . .:- -i
132
. KANE
- the entire mass and not just localized at the piesemater would then reestablish itself and indicate the actual pore pressure. .
I am through.
Q In a situation similar to that that exists with regard to the
~
diesel generator building at Midland and the fill under and surrounding it, would you expect upon removal of surcharge 1
the type of negative pore water pressure that you have just described even in a situation where secondary consolidation had been reached?
- A It would depend on the type of the soils involved and how they react to the removal of the loading.
Q ' dell, given the type of soils that you understand to exist there that could happen, couldn't it?
A That you could develop negative pore pressure?
Q Yes?
l l -
A Yes, it could happen.
- Q You indicated a little earlier that the method of surcharging that was perfor:ned at Midland with the diesel generator build-ing was unique in that the building was already ecmpleted.
- ces it nake any difference to the soil er the fill beneath ,
the structure as to whether there is a structure up there er not when you conduct a reload program?
A I think it makes a great deal of difference.
- : - : . : =.
.g..
133
- KAmi:
Q In what way?
A If you have conduits running under a structure and in these conduits you have a sand backfill which may have different compressionability characteristics than the fill around it 4 then these unusual conditions that you have, the conduit, the difference in backfill, could prevent or' slow down for a
- longer period of time the loading from reaching the compress-1 ible soils. In other words, when the loading is imposed initially it could be supportad by the conduits and by the sand backfill. Under future loads such as earthquake loads where we would disturb the density of the sand materials and in disturbing them we could cause them to settle, we could then induce more loads onto the compressible clay soils tnat
~
have not been fully imposed because the pressure under load is being carried by the material.
Q :n talking about the conduits are you making refarance to the duct bankinng up at the diesel building?
A That's only a portion of them, there are others.
I okay, so even after that duct bank being cut free the respcuse
. Q that you just made to the previous answer would still aid l
true in your opinion, is that right? i
\
l A In my opinion, yes. l l Q And in your opinien is there a =cre rapid dissipation in l
l pore pressure in sand as opposed to clay scil? i l l I
l l
- i. . . . - - - - - = 3 :
a:- f*?*:: et --- - , ... . 2 -- ,
. , l l
I 134
. KANE A Yes.
- C And would there then also be a more rapid consolidation of sand as opposed to clay soil? ,
Do you know the answer?
A No.
Q Go ahead though.
1 A It has been recognized that surcharging a sand deposit will not ,cause it to consolidate.
MR. 2AMARIN : Off the racord.
(Whereupon there was a short recess af ter which the deposition'again continued.) .
Q (By Mr. ::amarin, continuing) : Okay, you~previously indicated that in the presence of conduit that was backfilled with sand
- and fill underneath the structure that was being surcharged
\
' - there would be some different effect, that it would make a difference on the soil as to whether or not there were a strur.ture on top of the soil at the time of. surcharge , and is it your opinion that the sand would not transfer the load .
of the surcharge to the soil beneath it?
A It is my opinica that a greater amount of the load could be .
taken by the sand and not i= parted to the = ore compressible fill catorial. ,
i G Ckay. When you say a greater part of the load would be taken by the sand that leads me to ask a greater part of the load than what?
l l : - : . : i : . :
-:: -: : . ~ , . t- m s
k
135
- KANE A Than being uniformly distributed or equally distributed over
- all the materials.
Q What is it about the sand that would cause it to scuehow pre-vent some of that load being transferred to the fill material beneath?
A It is lass compressible and able to support without suffering consolidation. The sand being less compressible and more ccmpetent could take its greater share of the load?
Q I see, so this would be true then, in your opinion , of any pockets of sand that might he included within a fill, is that right?
I- A Not any pockets, no.
Q What is peculiar about the sand that would be backfilled
- around a conduit that would cause this to happen?
A The question before was of any pocket. If it is an isolated pocket then it may not have that effect of carrying more of
. ins share of the load. If it is a continuous layer and tte
~
fact that it has had or should have had good compaction in it
- making it = ore dense than the other material, and being dense l
- for the length of the pipe, those conditions may cause it to I- carry more of the load.
Q I see, so do I understand you correctly then that it is a problem not enly that there vould be the sand backfill arcund 2 the cenduit but that that sand nay have already been ec=pacted iI*I - 0 5 . -' I J. .
. c :'t: ** . "s 2 Set * * - * ,
136
. XANE 2 to an extent greater than that which might be in isolated 1
pockets within the rest of the fill and that, therefore, it
- could not transfer as much of the load to the soil below it , ;
as the surrounding fill would?
A Being compacted and having been densified in my esti: nation could create hard spots in the sand and the densified sand to where those hard spots carry the greater portion of the load. !
Q And the result of that would be what?
. A That the surcha.itge leading, the total surcharge loading at the time it was imposed never fully consolidated other zones of the clay, the compressible clay.
Q Those other zones being zones of ecmpressible clay being where?
A Outside the influence of the sand, the hard sand spots.
Q *dhat do you mean by being outside the influence of the hard sand spots?
~
A Well, I am talking about a load being transferred and being
-- taken up more by the hard sand spots and , therefore , it is *
- not being uniformly distributed onto the adjacent layers of
% the clay.
2- Q Okay. When you say adjacent, are you talking aheut what I E would view as the lower layers of clay that are laying at the .
- lower elevations but somewhat directly underneath that sand?
A Equal or lower, equal elevations or lower elevations .
l Q If there were a hard spot in the sand such as you have described s:-- 1 : s -
.: = s. .:
. :,t.:- ..:,:,, ...s-.--.4 ff** l*
I
\
137
- KANE
- wouldn't it still transfer the load below it to the layers l
\
below it? l
- l A Yes, but there could be clay layers outside the influence of
' where it is being distributed and that clay would be at
- elevations below those sand hard spots.
Can you draw a diagram for me perhaps? Here, let me show you 0
what I have got here.
Ist's assume that this line that I have
.: drawn marked Il is the grade level of fill and you apply a load and I will indicate that with crosshatching, and you have
-- someplace within the fill this conduit type structure that has sand backfilled around it, and the sand I will indicate by shading and the conduit just by - I will make a circle ,
- and is that basically tho' =echanism that you have in mind?
i 2 A There would have to be -- in this picture that you have drawn
- it does not reflect a structure such as the diesel generator building.having footings at depth.
Q Okay, if you can add those then.
A And we could have, if conduit were at that depth, we could
.' - have excavations to install those conduits which could go all
- the way to the surface or to whatever surface existed when-
- ever they were installed and the backfill that you would have
-- in here (indicating), the sand should have been ecmpacted and
- what I am attempting to indicate is that when you applied 13 your surcharge, a better portion of that surcharge could be 2
. : 5 . >: =s. :
.,.-...n.. .u,
, ... .e. ..-- ,
e
138 ,
. KANE
- carried by these types of sand hard spots to where the loading did not fully get imposed onto say clay layers under footings.
Q okay, so what we have is the area that I'have generally .
scribbled around with this pink marker would be the clay -
layers to whica the load may not have been uniformly dis-tributed because the load would have been focused, so-to-speak.
down through this sand filled excavation that I have indicated with green, is that basically what you are explaining to us?
A Yes, and my response to you about whether it is at the same elevation or below, I am saying there could be clay at the
- same elevation or below. You would expect distribution of pressura here (indicating) to be distributed and there would
. be clay at the same elevation and below the conduit which would be unaffected.
Q Okay, when you say " pressure to be distributed here ," you are referring in the direction that I have indicated with a blue arrow, and I assume that that would be true on both ends , is that correct?
l
- A Depending on the ecnfiguration of that, yes. .-
l Q When you say the " configuration of that" you are referring to
- the configuration of the excavation for the conduit? .
! - A For the conduit, yes.
Q Ckay, let :ne mark this as Consumers Exhibit Number 16 for l
-- identification.
l l
i :-- . - - :-4 .
l o.. . - . .--,-
E l
139
. KANE
- Okay, what you have indicated in this l
. sketch on 2xhibit 16 shows, I think, an excavation and then
. a sand backfill going all the way up to grade, is that what
- you intended to indicate en that?
i A The grade being, as I have indicated, whatever grade existed at the time the conduit was installed. It could not neces-
! sarily go back to the final plant grade if it was not in-
- stalled at that elevation.
- Q Okay, so if you had a conduit that was installed and add some
.. sand fill around and then plant fill was placed on top of it
- would this concern that you have just a= pressed still exist?
A It would exist and be further complicated by the irregularity
~.- of conditions that are in the foundation because of the ccnduit. What I am saying is surcharging a foundation that has conduit in it and different types of material is a diffi-
'~
cult task to assess on whether you have fully consolidated
-# under the charge lead and that is where the tarm pre-loading
~
U is used in that it is normally performed before you would in-T- stall any of those type of structures, that you would compress j .
T- the natural materials that are there and not have interference with these additional irregularities. .
Q Would this be true for conduit that were free at bcth ends of I- the area upon which the pre-load was applied? In other words, I' free then to move along with the soil as it settled?
it-- - - r : $ s
- . e- t: . . - :,.
6
-. - - . . . . ~
140 KANE A If they were not free it would make it less likely that the load got distributed. In making them free it would be better, but the fact that there is an irregularity of materials and ,
4 compressibility characteristics still makes it a factor on
. whether the load had gotten to the compressible soils.
Q Would Boris anchors' installed at various depths indicate
. settlement to the same or similar fashion as the building in
- all of those different depths and layers and indicate that this mechanism that you have described and illustrated in
. Exhibit 16 has not occurred?
I
.. A Boris anchors would permit us to apprise the irregularity of the differential settlement as well as your profiling of the conduit pipe size, and they do show an i. wlar settiament.
Q okay, and my question though is that Boris anchors installed at various depths settle or move in the same or similar fashicn as the building at all of these depths, and would that
! . then indicate to you that this mechanism that you have described and you have illustrated in Exhibit 16 has not occurred? .
. A It would depend on the extent of installed instrumentatica
.. and in evaluation of that information. I am saying that .
installing enough Scris anchors in recognitica cf all of the
- different conditiens you have introduced by your installation
- of pipes may permit you to come to the conclusion about the 1 : : -- : : := -:
9
141
'. ZANE
- differential settlement that has been experienced.
- Q Do you believe that there is a problem at Midland with respect 1
to the diesel generator building as a result of the wh="4sm l that you have indicated and illustrated on Fvhihit Number 167 A I believe because of the conditions that existed at Midland there could be a probism. I look at the request for the l
additional borings and laboratory testing to permit us to
. , evaluate to what extent this is a problem.
Q All right, what evidence is there that there is a problem?
.. A "'he evidence that there is a problem is the recognized differ-
.. ential settlement of the Category I pipes that have been pro-
-- filed and the concern for the other pipes that have not been
. profiled.
Q You are now referring to Category I type pipes underneath the diesel generator building?
'." A Actually they are both catagerf I and non-Categcry I whose presence affects the Category I and would not take away their
.. influence in this behavior.
l Q okay.
- A (Centinuing) : So it is all pipes underneath the structure.
Q okay, and what is it about the profiling of those pipes under-I neath the st=ucture? I want you to answer with specificity l
- as to that, that you consider to be evidence that this Exhibit I
16 type mechanism may be a problem and may exist?
- :: . - 5 : -
.-.- ,. .-.,,,,.~r g, . . , - - , , . , - - - - - - - - _ , - . -
- - - - - - - _ _ _ _ . . - _ - - - - - - _ _ - -- n.-- ,.-,e,-..,,c-., . . - -
142
- KANE
- A I think the profiling of the pipes clearly indicates that
- settlement has not been uniform.
Q okay, and you consider that evidence that this mechanism .
- which you illustrated in Exhibit 16 exists?
A could exist.
Is there anything'else that you consider to be evidence that
~
~
Q this mechanism could exist?
A I think concerns expressed, I think it is in Volun:e III and IV of yourown consultants as to the effect that the conduits and the connections to the conduits have on the settlement program.
Q When you say the connections to the conduits, are you talking about connections from the diesel generator building to the conduits?
A I'm talking about all connections of piping with other struc-tures such as the turbine building or other structures, those connections which could influence the amount and rate of .
settlement.
Q The amount and rate of settlement of the diesel generator ,
building?
A Yes, the area of the diesel generator building. .
Q Are you aware that there were no pipes or conduits running underneath the diesel generator building connected to anything anywhere else?
143 1
. KANE ]
l
- A It is my understanding that, I think it was a condensing
. ; line connected with the Turbine Building which experienced l
. unusual settlement and was ultimately disconnected.
- I also, looking at the configuration of
! the structure that you constructed to prevent the surcharge loading from imposing upon the Turbine Building and whether
. that structure actually permitted the surcharge loading to be
. imposed on the foundation soils.
.. Q Do you know whether the pipe profiles that have been per-
. formed and included in the information provided by Consumers
.. Power Company show deflection in those areas or displacement
.. of those pipes resulting frem settlement as opposed to in-
. sta11ation?
A 3ased on a review of the settlement profiles of the Category I pipes it is my understanding from the information that has
.' been submitted, when you indicate a level of installed elevation and show settlement of that installed elevation that you are indicating to us that that settlement.has
. occurred because of settlement and not because of installation.
. Q Is it your experience in construction that pipes are always
- installed at tne indicated elevation in the field? ;
~i' A I wculd say that would depend on the pecple involved and the quality of the contractor, but it is net normal practice to
.' have to go back and profile a conduit because you are concerned
. 9
144 1 KANE 2 with the settlement that we have experienced in Midland either.
I Q So you are saying that you really don't know, in the normal I
I course of construction, whether in fact piping is installed -
! at precisely the elevations indicated on the drawings because .
you don't have occasion to go back and profile them and find l
. out where in the world they are?
A I would say the amount of information that is available is limited to where we den't know, yes.
l -
Q ckay, so that based upon your experience is it the normal -
- situation, the prodr=4=nt situation for a pipe or conduit to 1 actually be installed throughout its course at the precise level indicated and the precise level indicated in the plan?
A It is normal practice to be close to that design elevation and what has been experienced at Midland , in ny estimation, does not qualify for being close.
Q So you are saying'it is normal practice to be close, you are saying it is normal experience for it to be close? .
A Yes.
Q And have you ever had occasion to observe that experience in any other plant or any other structure?
l A I have not had occasion. .
Q All right, and on what do you base your statament then that it is the normal experience for it to be insta11sd close to that intended elevation?
. : s .: .
.: ;
- eg- # s-*1,
145
. KANE 2 A My experience with the Corps in installing conduits under
- dams and my experience in reviewing as built drawings.
- Q Well, would an as built drawing provide you with information as to the precise measure or surveyed location of where the
> piping or conduit is in subsurface situations?
A Certain drawings have required that, yes.
O And you have had experience with that type of a drawing?
A Yes.
.. Q And in what situation have you had such an experience?
'. A one that I can recall is a conduit under a 160 foot high
.2 e= bank =ent to where the conduit was surveyed after being L placed.
Q And this one was right on the money as far as the intended
. elevation or was it close?
A close.
O Ecw close was it?
j A I dcn't recall. I'm talking about a conduit that I worked on maybe 12 years ago.
Q Is that the only incident that you have upon which to base your statement that in the normal or predominant field experience that piping or conduit would be installed close *w
-"eir intended elevations?
- A It is the major part of =y experience.
C Are you aware of any profiling of piping or conduits before i
146 KAlm and after the surcharge?
A I am aware of profiling of Category II conduits af*ar the surcharge.
. Q But none before the surcharge, is that correct?
. A In this aspect of the review I have depended heavily on the
- Corps of Engineers to evaluate, and so I do not recall in what I have read surveys being made of the surcharge program.
Q Would this activity with regard to this piping and conduit be within the purview of the work that the Corps is doing on
'. soils be geotechnical engineering as opposed to perhaps ,
. mechanical engineers and discipline?
.: A I think both disciplines, the sectachnical engineering which is being done for NRC by the Corps and the mechanical engineer-ing consideration of the stresses induced in it. I think i
there is an overlapping of concerns and I feel it is overlapp-l I
^
ing because a good understanding of the amount of settlement
{
and future settlement I think would come under the responsi- ;
1
- I
. bility of geotechnical engineering and that information would
. have to be conveyed to the people that are now going to ,
. evaluate whether allowable load stresses have been exceeded
. and that's the portion that I would anticipate would be reviewed by the mechanical engineering branch.
. Q And the consultants in the mechanical engineering ETEC, is
. that right?
..t t
m- _ _ _ . _ . _ _ _ _ . _ . . _ -_. -., _ _ _, . , , _ . _ _ , , _ - - _ - _ _ _ _ _ _ _ _ . . , . ,_ _ . - - - - , . . . - -
147
. KANE O A That is my understanding.
! Q There are some handwritten notes on Exhibit 11, recognize that Exhibit 11 is also handwritten, that appear to have been
- added. They are almost marginal notes and one, for example, 4 is an asterisk and says " stress concern is for differential settlement and overstress of conduit," is dut your note that wa's added there?
A May I see it? Yes.
.. Q okay, 4 hen did you add that?
1- A I think in final preparatien for the meeting of cctober 1st
- when I was trying to bring out the concerns we had.
2 Q There is a statement in this Exhibit 11 that says " normal process and surcharge programs place a surcharge load that is
-' l.5 times final lead to assure secondary consolidation is reached."
l~ Is that 1.5 times final load referring to
- an overstressing?
A overstressing what?
l, -
Q The soil upon which the lead is being applied?
A I'm not quite sure what you mean by "overstressing. " Over-I- stressing could mean cause it to fail and that is not what is implied, overstressing could mean introducing a stress in excess of scme anticipated final lead and think that is l
what is implied.
9
- ,,_ m_,m,, .-,--,-,..,,-,.-----------m-p,pm-,
1 1
.I 148 l 1
. M
- Q Why did you select'the figure 1.5 times final load?
i A It is a recommendation or guidance given in DM No. 7 of the
- Navfac Engineering Manual that I have spoken of previously. ,
t Q Were you aware of any other recommendations of figures other than 1.5 times final load? .
A I am not aware of any other figures.
Q Are you aware of the recer::mendation of 1.5 at any place other than in the reference you have just cited?
A I'm aware of 1.5 in the same SC publication that I spoke cf
.. be fore .
Q That is that article to which you referred?
A That is the SC Journal that contains many articles and one
- of the ones I read was on surcharging and it included guidance onto what level you would want to impose a load and a factor of 1.5 is suggested.
~
Q Do you recall the citation or the title of that artidle?
A I would have to look at the journal. I can provide that infor- _ ,
mation later.
Q I'd appreciate that, on the second page of Exhibit Number 11, .'
under that which you have numbered as Item 5,.the last nota-tion there is: " Note. That graph conveniently plots only .
settlement after surcharge was placed," and that refers to a graph that is labeled " View Graph Number 7" on Exhibit 12, which is a plot of r.easured and predicted settlement versus
149
. KANE
- log of time for marker DG-3.
What do you mean that the graph convenient-
.; ly plots only settlement after the surcharge is placed?
5 Keep those together like that, please i (indicating) .
A What I mean is that 'this graph plus the settlement history i of settlement marker DG-3 are only after surcharge load is imposed and that there is a history of settlement in the area of CG-3 before surcharge load was imposed and to me if I were
.. looking at the settlement history of CG-3 I would want to
.. look at its entire history and that is the distinction that
. I was attempting to make.
Q What is intended by use of the word " conveniently" in that sentence?
A That this plot conveniently reflects the infor=ation that you want observers of this graph to observe.
Q Are you suggesting that the preparer of that paragraph was
' - trying to hide something?
A :To . "' hey are your words , not mine.
O I am asking what you meant by the word " conveniently". In
- describing it you have used it again and that doesn't help me much.
- A I think I have answered it in that I think it is convenient for your purposes to just show settlement af ter surcharge in
- . : s ;
. 7, J
150
. KANE
- evaluating the effect of settlement. I cannot make a dis-3 tinction from this, I have to go back and look at the total 2 settlement history, and, therefore, it was inconvenient for .
- me to look at this and see only that portion of the settle-
. ment. I would like to see a graph that' fully shows the entire .
settlement history.
Q So your use of the word " conveniently,* you arn not saying
- that there is anything improper with that, is there?
- A The one who prepared that graph chose to do- it that way for
. his own reasons. ,
.I Q And in your opinion meaningful data would have been added to that graph if it were shown on there settisment data for DG-3 prior to application of the surcharge?
A Yes, yes, very meaningful data in that we could see prior to this a settlement pattern to where there was settlement and
~
than a leveling off and then additional settlement and I
- ehi nir that is all part of the settlement at this poimand
-' should be reflected when we are talking about the settlement history at DG-3.
)
Q What would be the significance to you in having that data available to you en that plot? .
A The major significance of it to ce is tlutt it shows settlement can level off and then again begin depending en the amount of leading. This graph as plotted here shows a leveling off, and Ep 9
151 KNM
- my concern is that we have not reached final load on stresses
- induced in the soil and because of that final load you could possibly again expect a change in settlement beyond that a ,
which is predicted by your secondary settlement.
Q If a plot of settlement before application of pre-load for DG-3, for example , didn 't show a leveling off or an approach to a straight line would than the concern that you just expressed cease to exist?
A It is my recollection that you have submitted other graphs that shcw the entire history and I think that is fine, but I
.. think that when we are talking about the settlement history
. of any marker that entire history should be shown and not just pieces of it.
Q so you do admit that you have been provided graphs showing the entire settlement historf of marker DG-3, is that right?
~
A Yes.
Q And is there anything about that settlement history prior to e imposition of the surcharge that causes any concern in your
- mind with regard to the information that is provided in that Figure 3 that you have before you in _"xhibit Number 127
~
A It does not concern -- it does not give me concern with re-gard to this infor=ation. What it does give =a is a feeling that what we are trying to portray with regard to settlement history of DC-3 is not fully represented by this graph.
___,,.,.,_,,.,,,..,,,_.-,.y,,.-y,,-- - - , , . - - , , _ _ . _ , - - , - - - ,
152 KANE
- MR. ZAMARIN : Can you read that answer
- back for me, please (to Reporter) ?
(whereupon the Reporter read back the ,
- previous answer.) .
2 Q And it is not fully representative simply because you have to
- look at another plot in order to see what the history was
- before surcharge again being placed, is that right?
A Yes.
. Q Your statement under Item 5 on 'wh4 hit 11, says that: " Note.
.. The graph conveniently plots only settlement after surcharge
.. was placed."
.. In fact that graph there that you have, View Graph Number 7, shows settlement from the time of the surcharge placement, is that correct?
A . That is correct.
Q So it is not just.after it was placed?
.. A After it began it was placed. It may not have been fully
'.- placed but it was partially placed.
Q I see. I take it what ycu are saying is that when the first ..
. grain of sand was put in the diesel generator . building as far as the surcharge program then the surcharge was placed at .
least partially?
A That is correct.
Q You indicate on what you have marked as Item 6 in Exhibit 11 9
153 KAVE
- a statement that says, "Show disagr====nt with previously submitted data," and you refer to view, V-U , Number 9, which
. you have labeled as View Graph Number 9 in Exhibit 12, and
. can you tell me what you mean by the statement "show disagree-
. ment with previously submitted data," and then the reference
- to 7-U Number 9, and then it continues and it says , "At critical time of surcharge removal for PI-30."
A This is information that you have submitted in, I think it is Volume II for piezameter 30. At the meeting on August 29th
.. this graph --
.. Q (Interposing) : "This graph" being what you have labeled as view Graph 10, or view Graph 9 in Exhibit 12 -- I am sorry,
. View Graph 8 in Exhibit l2'7 A View Graph 8 was shown at the August 29th, 1980 meeting.-
View Graph 9 was information for piezometer 30 that had been submitted prior to that and I think it is in volume II. View c
l - Graph Number 10 is information that was provided prior to August 29th,1980 which has the same data for settlement versus time , pond alevation versus time and surchamge load history, but the piezemeter that had. been submitted on the same plot pricr to August 29th,1980, has been changed frem .
I I piezameter 23 to piezameter 30 and the point that I am attempt-ing to make in that item on number 11 is char at a very l
l I
(
critical time when the surcharge was removed there is a l
e m, 154 j l
. KANE ,
I
- behavior of piezameter data which gives us the feeling that !
l
- excess pore pressures still existed. You do not get that 1
, same feeling from the revised view Graph Number 8, and at .
- that particular time on View Graph Number 8 the data that is 'l 1
. ahown is a question mark. ,
Q Did you ever ask anybody why there was a change in data from l l
piezometer 23 to piezometer 30 data?
) - A No, because the information that we are now being permitted to review was submitted to us in the minutes of the meeting of
. . August 29th. .
.. Q Would it surprise you to learn that piezemeter 23 had been
. : destroyed in rencval of the surcharge and that perhaps it was i
in an area that was surcharged outside of the perimeter of the building?
A It would surprise me in that I can see data submitted previous-ly which goes beyond that period.
Q Did you ever inquire as to whether the piezometer 23 had been destroyed due to construction activities during October of 1979, for example , and, therefore , no further data was available from .that piezameter?
A I did not inquire because I have no basis to knew vny or how ,
or if it was destroyed.
Q Well, according to your note under number six on Exhibit 11, you had some concern that there had been a change in piezemets:
4
- 7-w-%- - - . - - - . . - - - . . . - - . _ _ , --,_ --__.
155
. KANE
- data. Didn't that give you cause to ask why?
- A My concern is a replacement of piezameter data, but that con-
. corn does not mean I then conclude that it has been replaced
! because of a damaged piesometer.
What did you conclude , if anything, as to why that data had Q
been replaced?
A I concluded that the information that was submitted at the
. August 29th,1980 meeting was that information most favorable
. to your position.
C I see, and, therefore, did you conclude then that the Z otive of Consumers was simply to provide the most favorable
-- information and for that reason there was a change in P2-23
.. to P%-307 A I never went beyond the feeling of why you made the change.
Q Don't in fact Graph Iumber 10 and view Graph Number 8 perhaps represent different data with regard to that shcwn for PZ-23 and that for PZ-30 and that the data for P:-30 gces all the way up to scmetime in July of 1980 whereas there is no
- similar indication on view Graph :nnnber 10 other than a nota-
- tien of some time shortly after August 30th,1979, almost a year earler?
A Would you repeat the question?
MR. ZAMAICN : Would you read it back (to Reportar) 7
'tg y ----y---- w. g---- - - - . - - . . ---- r -+---- +
156
. KANE 2 (Whereupon the Poporter read back the
- previous question.)
- A It does show different data but it does not take away the ,
- feeling that I had that the information being presented is the more favorable to your position.
Q Didnt you feel that encumbent upon y6u to ask as to why that was <-hanged if in fact it was changed?
A I have provided you with those notes which are da'ted. I think
. the 26th of September which pezmits you to understand my concern.
l Q And wasn't it on the 27th of Septenter?
A I thought you had read the 26th?
Q If I did I was in error, and I meant the 27th, A It could be that it was done over a couple days.
O If it had been done over a couple of days would that be the first time that you came to the reali=ation that there was a difference in View Graph 8 and in View Graph 10 with regard
-' to one presenting piezemeter data for jiazometer 23 and the other for piezemets: 307 i A Yes. It was the first time that the full realisation came to me. .
Q And with regard to the time period in questien, and that is the behavior at the time cf surcharge renoval, are the data points with regard to piezameter 30 and piazometer 23 as shown 0
157 KANE
- on view Graph 8 and view Graph 10 substantially difforent?
- A would you repeat your question?
. MR. ZAMARIN : Would you read it (to Reporter) 7 (whereupon the Reporter read back the previous question.)
. A They are different because view Graph 8 gives a longer history of readings than View Graph 10. .
O of course it dcas in that's --
A (*nterposing) : And they are different piezameters.
.. O I am talking about the response or the activity of the
. piezameter at the time of surcharge removal and I asked you if in comparing the data point that are provided on view Graph 8 and view Graph 10, in your opinion that data for. that period substantially differs?
A The data, the piezc=eter data at the ti=e of surcharge re-moval is your question? Dces it significantly differ?
Q Tes, as far as behavior of the piezemeters?
A Yes.
Q In what way?
A In that on the one presented at the August 29th meeting there was a question mark, whien when questioned at that meeting it was indicated by Doctor Peck that there was erratic.
behavior that required cleaning out the piezameter, as I t
t
- -- ,.-----,-----------.-m -- - - - , - - - . - - - - - - - - - - - - - , - - , - - - - - - , , , , - - - . - - - ---- - , - , - - -
4 158
. KANE
- understood it, whereas the same behavior is not indicated at
- piezometer 23.
Q Is the data, however, indicated on piezemeter 30 on the graph
! of piezometer 30 there, view Graph 8 --
A (Interposing) : Piesczneter 30 is on view Graph 8, yes.
Q And you say that there is a question mark. My question however,
- is is the data showing behavior of that piezemeter which is somewhat similar at ler.st from my observation to that of
. piezometer 23 shown on there? 1 A That data that is shown is differen.t an'd the point I am trying l to make is that the information that you have submitted after the August 29th meeting for piezameter 30 is being questioned
- by Consumers for that period.
Q Eow does the data point that are shown for piezemeter 30 at the time of surcharge removal substantially differ frem the data point shown for piezemeter 23 at that same time as it relates to the behavior of piezometers?
A Following surcharge removal piesometer 23 reflects a signifi-cant drop in pore pressure than is indicated at piezo=eter 30.
Q What is the significance of that in your opinion? ,
A The drop and the rebound in piezometer 23 seems to me to be more reasonable data.
O The rebound in piezcmeter 23 seems to be more reasonable data?
S
159 i KANE
- A Yes.
Q More reasonable data from what type of a viewpoint?
. A From its behavior in comparison to otlier piezemeters.
t Q And you base this upon your comparison of the data that is
- shown to you in View Graph 8 and View Graph 10 of Exhibit 12, is that correct?
A And other piezometer data submitted in Volume II.
Q All right. You indicated that you came to this realization that piezameter data for piezometer 23 was not provided with
. . the materials that that piezameter 30 data had been provided
. someti:ne around the 26th or 27th of September, is that right?
- A At some time between the submittal of the information which was September 14th and that date , yes.
Q And you have also testifisd that prior to the turning over of this document, Exhibit Number 11, pursuant to the depositica
! notice that you had not ecmmunicated with Consumers with regard to questioning as to why there had been the use of l piezometer 30 as opposed to piezometer 23 data, is that l
l . correct?
A "' hat is correct , and the reason for that is that in cur review we have effectively been tied up in respcnding to your appeal .
r acticn and these deposition hearings.
Q Ckay. Co you recall attending the meeting , the public emet -
ing on August 29th,1980 with regard to tne staff view en 4
-..~,-,-,,,,..m-. . , _ . . . , , _ ,-.,-..-,,w, .,,,,v. ,. ..,,.,,,,,_,e
160
- KANE
- these issues?
- A would you repeat that question, please?
, Q Yes , do you recall attending a meeting on August 29th,19807 .
- A Yes, but that was not -- you had identified that earlier as 4 a staff meeting.
Q No, no , I said which involved a staff view on these issues ,
the subject of which was the staff view on these issues, the i NRC position on these issues.
. A The format for the August 29th, 1980 meeting was not, in my
. opinion, established to give the staff view. If you look at
-; the time provided to Consumers versus the time provided to
- us it was not intended to give the staff's view.
Q Ckay. Do you recall stating at that meeting.that you wars
- disappointed in that the data only shows favorable sectiement raadings?
A I did not make that statement because I have indicated I did not come to that realization until after the submittal of .
the September 14th document.
Q So you didn't state then at the August 29th, 1980 meeting /
that ycu were disappointed in that data only showing favorable settlement readings and anybcdy who said you did was a liar, I
is that right?
MR, PATCN : I don't think he said that.
Q Well, I said, "Is that right," and he can tell me if it is 9
161 .
. KANE 2 or not.
A That is not right. I did not say that.
4 Q So you are saying the statement in my question is not right?
4 A aspent your question.
2 MR. ZAMARIN: Could you read it back, please (to asporter)?
MR. PATON : I don't think the Witnesa should respond to the question of whether anybody who said
. that would be a liar. You are asking him to speculate on the motivation of someone that he doesn't even know and he hasn't
-; even been advised of who this person is. I will instruct you
- 3 not to respond to the question about whether or not anybody who said otherwise is a liar.
MR. IAMARIN : If you have heard that question once you have heard it a thousand times and it is a i
perfectly appropriately question.
j MR. PATCN : You want him to say that any-l .
body who says contrary to some information he has, you want l
him to indicate as to whether or not that person is a liar.
I j What I am saying is how is he supposed to know that?
MR. ZAMARIN : He denies having made a statement and , therefore , if semebcdy else made it then who-aver said he made it must be lying.
MR. PATON: I don't know how he cculd make
- i e
+ , - - - , - -
, -.-.,- m ,. q.-,y+,m.,
,9--_ , . . , - , _
162
- KANE
- that cenclusion.
MR. SAMARIN : Well, maybe he can.
. MR. PATON : That person , whoever made .
I t that statement, his motivation for making that staemment may be a million different things. I don't know how he .
would know that.
Q (By Mr. Zamarin, continuing) : Can you answer the ques icn?
MR. PATCH : I instruct you not to respond
. to the question about whether or net the person who says other-wise.is a liar. ,
.; A I will follow the instruction of counsel.
(Whereupon there was a short discussien held off the record; which was followed by a recess and then the depositien again continued.)
liR . ZAMARIN: Back cn the record.
Q (By Mr . *amarin , continuing) : Were you provided by Consumers the data showing the piezametric elevations versus ti=e for all of the piezameters with regard to the Midland plant diesel -
generator building 7 i .
A To my knowledge we were. ,
i Q And when you came to this reali=ation that pia ometer nurl:er
( 30 data was included in the submittal by Consumers whereas ycu had been previcusly supplied a similar plot showing
-, . , _ . - - -- m__ -- . __ ,
163 KANE
- piezameter 23 data, did you go back and cenpara those ecmplete e, piezemetric elevations versus time plots and the behavior of piezameter 30 and piezemeter 237 t A I made some ccamparisca and I also found out that the piezome*m
. data submitted for piezometer 30 at the August 29th meeting is different from what had been previously submit *M to us.
. Q Okay, in what way was it different, to the best of your recollection?
. A To the best of my recollection it did not have that questien -
.. mark during the time of surcharge removal.
.; Q Ckay, it didn't have a question mark. Did it differ in any other way other than not having a question mark?
., A If I recall correctly it did not rise to the level that had been indicated by the question mark, but it actually drepped.
Q Did it shcw the data point, however, indicating that zise in
~
piezemeter level?
- A It shcwed data point which form a curve.
Q Ckay. I.et me show you what I have here. It shows a plot of
- piezometric foundatica versus time for piezemeter number 30 and is that the one that you reviewed or similar to the ene l
.. that you reviewed although I have scme pencil marks en this one?
A Could I have my view Graph? That is the one.
Q That is the one and does it show the data mark on there which
, .
- a .- a r ,ie
164 KANE
- later had a question mark by it when it was presented as an attachment or a submittal to you? Right there (indicating).
. A well, you know if the graph is here why am I - well, I think .
. that darker spot is a point. You know, I had no basis for believing that. .
Q Did you ever have what you have as View Graph Number 9 in the form that I have it here (indicating) ?
A No, no in the sense that it appears that your data goes out longer. It is the same data, but this is a Zerox of the smaller one.
.. Q This appears to be, what you have as view Graph 9 appears to be a reduction of what I have here and it appears to be somewhat of a poor reproduction? -
A I think it is a reduction which you have submitted in volume II. I think the drawing you are now indicating to me is an enlargement of the data that you have submitted to us.
Q I see , so what you got in volume number II was precisely what .
you have in View Graph Number 97 A Would you repeat that?
- 0 Yes, was the graph that you got in volume number II precisely
.. the same as what you have in View Graph Number 97 .
A It came frcm Volur.e II .
O okay, it came frem volume II but in volume II did it look more
. like what I have here, this larger sheet of paper?
nt: .
s >1 .
l
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g
165 KANE
- A I don't understand the question. What is here is a Zerox i of, is a Xerox of the information provided in Volume II.
4 Q okay, sir, without reduction of the information in Volume II?
A That is correct, that is correct.
Q And is the reproduction here as clear as what you have in Volume II?
i A It is better in Volume II.
Q In Volume II could you see that has a data point, that point
. which later has a question mark by it?
- A volume II, to the best of my recollection, does not present
- ! this graph with a question mark.
Q I didn't say that.
A Well, I think it is important if you are asking me to pick out
- dark points on the graph and understand them *w be questien -
- able, because if you want me to be questioning them then a
~
question. mark should be there.
Q That's not the questien.
A I cannot look at the data in Volume II and see a dark spot on the graph and know that this is questionable.
i Q Did you see the data point or cculd you see the data point in
- that graph in Volume II7 .
A I would have to look at Volume II now that you have made :ne
- - aware of that point to see whether it is more evident. I 2 do not knew whether Volume II has that clearly identified point.
c: . : s -
,o ..,... . ... .. , . .. ..
0
, ._ . - - . , _ . . _ - . , . _ , - _ . . . _ . . _ _ . . . . . . _ _ - _ _ _ _ _ . , _ - _ _ , , _ . . _ . , _ _ - - _ . , , . _ _ _ , . ,._-,.-,-,r_---_.__,,.,,, - - . -
166 i KANE 2 Q Ckay, so when you then reached the conclusions that are
! indicated in Exhibit Number 11 you were working off of what appears to be a rather light reproduction of what was included .
in Volume II rather than the actual presentation in Volume II, ';
is that correct? .
A Please repeat that question.
- MR. IAMARIR: Could you read it back (to .'4 sporter) ?
(Whereupen the Deporter read back the
. previous question.)
2 A I'm not quite sure what you mean by working off of. I worked,
- off of the reproduction in volume II and I attempted to
.- duplicate that as a view graph in the presentation of October 1st, so I actually worked from the information presented in Volume II as well as this view graph.
~
Q Ckay. Can you tall me how PI-23 supports the staff concern that secondarf consolidation was not reached by observed .
behavior?
A Could I have piazometer 23 data to look at?
That is pie =ometar 30.
- - Q Yes, I think if you go to view Graph 10 or is it 87 .
A Again, this is piazemetar 30 (indicating).
0 Ch, is it?
A Yes.
2 - - : . : s -
e
167
- KANE
- Q It is either 8 or 10, I believe. Let's go to view Graph 10.
A The behavior that I see in piezameter 23 is that at the time e of surcharge removal there was a significant drop in l 1
piezameter, a rebound over the piezametric level and then a gradual decline in that piezoester data to a lower level which I an interpreting to be the level being controlled by the
- natural grcund water regime.
Q Okay, can you tell me what the size of the initial drop was in feet at the time of surcharge removal?
l- A The questica, as I understand it is what is the drop in feet of the piezometric level upon removal?
2 Q Yes?
4 A I could look at this graph, which is to a ===11 scale and
- indicate and conclude that it appears to be around two and a half feet.
~
Q Can you relate that two and a half feet of drop to the percent to which you believe primary consolidation has been achieved?
A I cannot because the rise in piezometric pressure that l
I- developed was caused both by the development from seepage I- from the pond and the surcharge leading, and so I cannot .
distinguish frem your piezemeter data which part is pond I seepage and wnich part is in response to surcharge loading I and, therefore, I cannot know the total build up of pore s:: . : 5 -
- 1. -
.. .---: .:.t.. .. -.. .
G
168
. KANE
- pressure due strictly to surcharge leading, and , therefore,
. I cannot estimate what the percent of this drop is of that
, total.
Q Can you estimate how much of that drop is a result of pond seepage? .
A How much of the drop? The drop you are referring to is the
- drop at time of surcharge removal?
Q Yes, that is what my question was with regard to.
- A I do not feel that any of the drop is related to pond seepage.
. Q My question was based upon a drop of what ycu estimate to be l about two and a half feet. Can you estimate the percentage I of primary consolidation which has been affected beneath the
= diesel generator building?
A I thought I had answered that question previously in that I cannot.
i l '
l MR. ZAMARIN: Okay, o ff the record.
(whereupon there was a short recess after which the deposition again continued.)
0 (By Mr. Zamarin, continuing) : Do you have an opinion as to -
- how much reduction in effective stress a two and a half drop in a piezemeter level would relate to?
A Two and a half feet. I thought I said feet.
Q Strike that. Do you have an opinion as to how much reduction 2 in effective stress the two and a half foot drop observed in ic: - : 5 . t-s :
, , . .+:a . t- , s,,
.6* c
169
. KANE
- piezameter 23, that we were locking at, would relate to?
- A I do not know. I look at the requested consolidation tests
- as being able to answer that.
r Q Is there any way to answer that without those requested con-i solidation tests?
A I do not know of any other ways, but I have =ot given considera.-
. tion to other ways.
Q So what you are saying is that as you sit here now you are not
. aware of any other ways mainly because you haven 't considered
. other ways to approach it?
.: A When we considered it it was felt the consolidation tests
+ - -
was the best approach and Ibsre not given- additional thought
- to it.
1 Q Cn Exhibit Number 11, under what you have denoted as Item.7 are a group of comments. You have the comment which says.
" state of the art limitation - thin samples . "
I see what it says, it says " state of the
. art limitaticas ," and then one of those limitation is 'think samples , is that correct?
. A That's correct.
i Q Now I understand , and then you have a dash and it says dtrue. *
- Is that indicating that the thin samples is one of the state of the art limitations in your opinion, and I know there is more than that there, but I will refer to those in a moment. l
- . : s. : .
--tc; e v;;; .. - 4--
- , - - - - - - . , , - w , , - - - - - - , ,
170
- KANE
- A My enmmant "true" refers to the limitation of working with
^
think samples.
a Q Okay, that comment continues to say that' "however in some ,
5 respect we have better control to duplicate long term field i conditions which did not develop during surcharging." .
~
Is that a correct statement?
. A Yes.
> Q And is that an opinion which you hold?
l
. A It is an opinion that I hold in that for that cuestionable zone of saturation, and there I am referring to the zone of l --
l soil between 622 to 628, there is question in my mind whether
- that zone was ever fully saturated and what I am indicating
- is that when you run a consolidation test on material taken from that zona you can induce saturatica and study the behavior of settlement under that induced saturation. The fact is it
~
is being questioned whether we obtained it in the field and
- we will be able to better obtain it in the laboratory. .
Q Is it only with respect to that one factor that you have just described that you feel that you would be able to better con-
- trol and, therefore, better duplicate long term field
- conditions which you say did not develop during the surcharge period?
A With regards to the settlement, yes, it is that zone and I 2 have qualified it by referring you to just the consideratien of
- u---- -
. , .. v-1 l- -
171
- KANE
- the settlement because in those areas where we have asked for i shear strength testing we would want to induce saturatica in those materials we feel can be saturated under full pond i reservoir level, and so it refers to other than just settle-i ment.
Q In reaching that opinion that in some respect you have better i control to duplicate long term field conditions did you take
- into account the known heterogeneity of the fill underneath
- the diesel generator building?
- A The heterogeneity of the plant fill will impact the saturat.ica l to the extent of the time it takes to develop, but given 2 enough time for tae development of steady seepage even differ-
- ent materials could be expected to become saturated.
U Q In for=ing thatcpinion did you take into account the affect that the known heterogeneity of fill would have on obtaining
'~
- representative samples of the soil beneath the diesel genera-ter building?
Do I understand the question correctly in that have I con-A l
- sidered the fact of the difficulty of taking undisturbed samples in heterogenous material?
Q I didn 't get to the undisturbed samcles , that was going *e be .
l my next question, but you may answer this one as you have stated.
! A It is recognized that it is more difficult to get a good i I: - 5 - - a :
ee- ,, - , -r .--,.
g ..
D
- - . ,, -e. -
- - _ -.wa_-c-. , , . , _ , . ---r-- -
172
- KME
undisturbed sample in a cohesionless material, and that same difficulty, the extent of that difficulty is not to the same i
extent in cohesive soils and so I recognize when we are asking .
5 for samples, undisturbed samples in plant fill settlement we
- are talking. about undisturbed samples in both types of soils,
- but it seems to me what we are talking about is because we i have a heterogenous fill that we cannot now adequately evalu-
- ate it because of that heterogeneity, but I would prefer to say I will do the best I can in getting the best undisturbed
.; samples in each type of material and test it and make a
.2 judgement on the results of that test along with ce observa-
- tions recorded during the surcharge program.
., Q Did you also take into account in arriving at that opinion
.1 the impact that the nonheterogeneity of the soil would have on obtaining a representative sample in that there would be a
~
scatter of results?
- A I would anticipate a scatter of results, but it is my opinion
~
- - that with the best care in sampling and testing that the scatter will be minimized and that I would be able to make
- a judgement based on that scatter what is a good representa-
- tive value of say the preconsolidation pressura of the samples .
that I have tested.
Q Ecw would you make that judgement as to what was a good 2 representative value?
r- : -
. ,,c.t: ,:
.4-
173 4
. KANE
- A By looking at the data, trying to evaluate the reasons for
. this scatter and maybe eliminate some results from considera-tion and make a judgement does the average of the good data give me an understanding of what I think good results are.
~
Q okay. You say does the average of the good data give you an understanding, and what do you consider to be good data?
i A Data where there has been no evidence, no visual evidence of i sample disturbance. Data whose results, consolidation test
- results and other test re'sults would appear to be reasonable for the type of soil that is involved.
- 2 Q Isn't that really one of the problems that we have is that I because you have a heterogenous soil that you have different types of soil and you really don't ,know when you extract those samples whether the sample you have is representative of the predominant soil or the soil that has the predominant characteristics underneath that building?
2 A That is a problem that we have in extrapolating results of laboratory tests as being representative for the materials under the diesel generator building, but that is a problem 2- that the geotechnical engineer faces .in almost every design of extrapolating what he considers to be representative in- .
fornation.
Q Okay. In a typical situation, however, when a geotechnical engineer faces that problem of extrapolating this kind of data
- 4 . - t: 2 t
-1
174 KANE
- he dcasn't have' actual field test data to use. He doesn 't have the actual data behavior of a building under surcharge and cbserved settlement over time to use, does he? ,
A I could think of cases where he would have both.
Q Ckay, give me an example? ,
- A I could give an example of a dam that is being built in 4 different stages and so under the initial stage you would have had laboratory data that permitted you to estimate the behavtor i
under that first stage of leading, and you would also have had field data that was taken while the first' stage was built,
- and so you have both laboratory data and. field data to guide
~
.. you in the prediction of the fo11cwing stages of construction.
O All right. I am talking about a situation, however, where you don't have the testing data to begin with , where all you have is field data and you have the actual performance of the
~
structure , and would you agree that that information is = ors reliable in predicting future behavior of a structure than data which would be obtained and from which extrapolation
. would be made in soils such as that that would exist under .
the diesel generator building where you have sample disturbance
.. problems and you have the problem of obtaining a representative sample?
- A I feel that questien is closely related to a previous questien.
4 0 It sura is.
r--- . : : , :
.. s: ~ - .. ,
175
. KANE J A Where-I have indicated that field data if it properly 2 addresses the time element censideration would be more i reliable.
- Q Can you tell me what the NRC experiences with Virgil C.
. i Summer are as they relate to the problems that we are experi-encing at Midland?
i A My experience in NPC with the Virgil C. Summer is consolidation i tests were run on foundation materials for Categog I str;cture.
That information developed from the consolidation test
.' - indicated a pre-consolidation pressure, and an engineering 2 judgement was made to increase the level of pre-censolidation pressure because of anticipated differences in weathering of
., the foundation materials and so there was an increase in the pre-consolidatica pressure because of an engineering judge-ment. What in actuality that settlement that was experienced
~
at the Summer plant was to have settlement of the magnitude that would have been predicted by the original pre-consolidation
- --' pressure values, and so my experience is the test results from I consolidation tests for the Virgil C. Summer plant would have adequately predicted the settlement that was eventually experienced.
Q Were those consolidation tests based upon samples taken in
- heterogenous soil?
2i A I would say because of the degree of weathering they would be r: -
- : : 1
i 176
. KANE
- properly labeled heterogenous.
- Q And would that heterogeneity of the soil of Virgil C. Summer l
+ be comparable or non-comparable to the soil of the Midland fill? :
- A No, and the reason for that is the heterogeneity of Summer was caused by the natural process of weathering and the hetero-
+
geneity at Midland was caused by the difference of materials that were placed and compacted.
i Q Ckay. Would the heterogeneity of the soil at summer he of a different nature than the heterogeneity of the fill at
- Midland so that one would be able to obtain a more representa-l tive sample of the soil at Summer as opposed to Midland? )
1 A Because of the degree of weathering of samples at Summer I !
l
., would expect, particularly in those portions of the foundation that are essentially clay, it to be easier to recover un- j disturbed samples at Midland than' it was at Summer.
O Ckay, that's undisturbed samples. How about samples which are representative of the predcminant characteristics of the soil beneath the building?
A There are portions where you can recover undisturbed samples .
frca Midland which are predominantly clays. There are areas cf
-- thodiesel generator building and in those areas I would not expect you to have difficulty in taking undisturbed sam-Aes.
Q 'Ckay, you Aaep trying to take me back to the undisturbed What I I samples and I keep trying to take you away from that.
- s-3 . .4 ,
{
)
177 l
KANE
- am talking about now is whether when you take samples, for example, if you take six borings and you know that there is heterogenous soil or fill, how do you know that those six borings or six samples don't all contain samples which are not representative of the prodczninant soil and soil character-
- istics underneath that building?
A Well, the information that is available to us at Midland is more than the six borings that we are requesting. I don't know if by chance or what, but we are requesting six borings at the diesel generator building and what I am saying is in
. my estimation getting that information from six borings and
- relating it to the additional information that we have from
- other borings in the diesel generator building would permit us to reach a conclusion on future settlement. It may cause us to face the heterogeneity by making reasonable assumptions
~
to be able to make conservative predictions of the settlement, but I feel that is necessary.
'. : Q In other words, you are saying that you would adopt a worst
.' .- case approach to the scatter of samples that you might cbtain?
A The worst case approach would be one extrsme. I would be L 1 coking at an average prediction and the ninimum prediction. .
Q Okay, when you say ninimum prediction, what is that, is that
.- a worst case approach?
? A . vin 4""=
- would be the least amount of settlement. The worst
- . ; i .. - - - :
, i.
178
- KANE
- case , in my judgement, would be the maximum amount of settle-
! ment and in trying to evaluate the range between the minimum
. and maximum and its consequences to the structure.
Q okay, and really my question is then assuming that you do get .
this scatter of resulta you get a range running from minimal -
to maximum, what would you do with that data? Would you adopt what you have styled a conservative approach and take the i worst case, that being the maximum settlement? How would you I
.. treat it? '
- A In recognition of the structure and the importance of the
- safety involved I think I would be inclined to be conservative
- and adopt the worst conditions which may not just be maximum settlement, but could be maximum differential settlement.
Q 'Gkay. You continue under whatuts headed number eight, on page three of 'Mit 11 to state that: "The fact that Midland design used the present state of the art approach
- (undisturbed sampling and consolidation testing) to show that l
the foundation glacial fill materials were in fact pre-l -
2' consolidated under former glaciers, here CP could accept .
l -- the state of the art because it does not cause them a problem."
- What do you :sean by that statement?
A That the state of the art that Consumers is questioning in
- doing the additional borings and testing for the plant fill
? was found acceptable by them and in investigating the r: -- . - ? ,
.v.. . ,< . . . .
1 179 l
- xAus j 1
consofidation characteristics of the glacial fill.
Q Wasn't it also a fact, however, that at the time of the
- initial testing that there was no other data available such as we have now by field testing and that there was no known
~
problem with obtaining not only an undisturbed sample but a (
sample that would he representative of the predominent
. characteristics of the soil?
A Would you repeat the question? l
- MR. ZAMARIN: Pead it back, please. ;
- (whereupon the reporter read back tne
-- previous question.)
2 A It is a fact that there is more information now available from field testing. It is not a fact that the undisturbed samples !
that were taken in the glacial fill for consolidation testing ,
that were run were any more representative of the conditions that are existing in the foundation than would be the representativeness of the plant fill from the borings that we have requested.
,' O So are ycu saying that you would expect no more scatter of results resulting from heterogeneity of the soil with respect
- to the fill under the diesel generator building than was obtained when the undisturbed sampling was initially done at the site at Midland?
A It seems to =e we are confusing several things here. Cne is
- : : 3 . : 2 -
+ . . . _ , ..., . .. . ...
)
180
- KANE
- that the heterogenous nature of the material, and one is the scatter of the test stated. They are not the same.
Q I know, I am adding the two of them in a question.
. A I think the distinction has to be made. .
Q Do you accept the fact that glacial fill generally by its .
nature is very heterogenous and Doctor Peck has indicated his experience with glacial fill as not being good when consoli-dation tests were run on ,that.
A And so the problems of ru=ning consolidation tests on glacial -
fill are the same problems we have facing us in running it on 1- the plant fill.
Q okay, but in running those tests there was no choice because
' there was no other data available, was there?
A There is no other data, but I don't think you can draw from
, . that a conclusion that that was the reason those tests were l .
! run. They were run because it was the state of the art and it was accepted practice. .
Q What I am looking at is your stated opinion that Consumers accepts the state of the art because it doesn't cause them a I problem, when in fact my view of that is that they accepted the state of the art then because there was no cther infor-mation available and that was all that they could get. Now, would you disagree with that?
A Is the statement that you just indicated to me Consumer st-- -
- s. -e= - :
- 2,u r.
- m ..e- - - . .
W-* - - . . , .
181 i KANE 0 Power's, because it has not been documented anywhere else j 1 that the reason they accepted the consolidation tests on the
- glacial fill was because that was the only thing available
~
- to them at the time. Is that Consumers' position?
5 'Q That is the conclusion I would draw based upon my knowledge, and if it is wrong,' point it out that there was no other
- information available to them at that time such as field
. testing.
. A Well, I' don't think --
1- 0 (Interposing) : Am I wrong in that?
-- A I don't think I understand whether it is your feeling or l' Consumers' pcsition.
Q Well, accept it as a position regardless of whether it is 1 mine or consumers, and with that in mind can you answer the question?
~
A You are asking me to understand Consumer Power Company's position as accepting the results of the glacial fill because
~
- that was the only thing available to them? I see no dccumenta-
!" tion that makes that statement.
Q What documentation that you have seen says that the only reason they had accepted it was because i didn 't cause them a problem?
A Do I say the "only problem"?
2 Q You say here Consumers accepts the state of the art because 2 :-- - ; s. t2 e- a--, ,
- s. , - .--.
O
l l
182 i
N l
- it does not cause them a problem. It is a pretty direct
. statement.
A I think you have added the ard "only reason" to my words. ,
5 Q What are the other reasons in your mind?
- A I don't see any here. I listed that one.
Q All right, what are the other ones?
l . A *dhat are the other reasons?
l l
Q Yes?
,; A For what?
,, Q For Consumers accepting the state of the art. You have listed l
one, you have indicated that you are not aware of any docu-
.: mentation for that and I am asking you if there are other
[ .; reasons that you didn't list?
A I will go back to my statement that I have seen nothing from Consumers that tells me the only reaIon they have accepted
.- the consolidation was because that was the only thing available
.: to them.
l l .. Q That's fine, I didn't ask you that question. htat I asked
, you is what documentation you have seen that says consumers .-
- , accepts the state of the art because it does not cause them
,, a problem?
A I have seen no documentation. That is my opinion.
.- Q okay. What do you base that opinion on?
2 A The fact that it was submitted, that information was submitted, s1-- - - s : =-
gt 4-tet- - : .. * *** a
183
- KANE 2 judgments were made on future settlement predictions and
'. there was no statement from Consumers that says they are
- making this prediction only because this is the limit of the
~ '
state of the art.
~ '
Q So from that you conclude that they accept the state of the
~
art because it doesn' t cause them a problem?
A Yes.
Q And is that a conclusion that is based upon your expertise
-- as a geotechnical engineer?
- A Repeat the question, please.
- l Q Is that an opinion that is based upon your expertise as a geotechnical engineer?
- A Yes.
Q And what is it in your expertise as a geotechnical engineer that qualifies you to make that opinion?
Define the opinion that you are asking me?
-I A
Q The opinion that Consumers. accepts the state of the art
~ - because it doesn't cause them a problem?
A My years of experience as a geotechnical engineer have led me t
- to believe that we can make good predictions of settlement
-- using this method. I see Consumers Power Company using this method in one case and oojecting to using it in another.
- That is the basis for my judgment.
Q Can you tell re an alternative method that Consumers Power i--- _ - 4 e
4
184
. KANE
- Company had for making that same determination at the time
- they accepted the state of the art?
., A I do not have an alternate solution. I am satisfied with ,
~
that solution.
Q okay, I didn't ask you whether you were satisfied. .
A I feel that's part of my answer.
Q okay, so you don't see any other alternate, is that correct?
- A Alternate for addressing the consolidation of the glacial -
.. fill?
.. Q Yes.
- A I don't feel there is a necessity of an alternate.
'I Q I didn't ask you about the necessity, I asked you if there
- . was an alternate of which you are aware as a geotechnical
.. engineer?
A I have not thought there was a need to investigate an
. alternate for something I felt was not necessary.
.2 Q In your 20 years of experience as a geotechnical engineer
'..' have you ever come across an alternate?
l
!! A An alternate for what? .
l
! .1 Q You mean you have no idea what I'm talking about right now?
- A An alternate on consolidation testing? .
t
( .: Q Yes, with regard to the glacial fill as you have described
- - the state of the art in your paragraph number eight?
.3 A There are alternates to taking undisturbed samples and s: : 5 : s .i t r :
.< , :.c: ..:,. .. .:- :,
. a..
185
. KANE
- eliminating the problem of sample - not eliminating it, i
but of =4a4=4xing it.
. Q Tell me what they are as it relates to this approach that consumers took to show that the foundation on glacial fill materials were in fact pre-consolidated under former glaciers?
A Will you repeat the question, please?
- MR. ZAMARIN: Could you read it back,
~
please?
(Whereupon the reporter read back the
.. previous question.)
.2 A I still don't understand the question.
-! Q Well, it was taken right out of your answer. Okay, you
., indicated that in your 20' years of experience as a geotechnical
.: engineer you were aware of alternative approaches that could have been taken by consumers Power company to show that the
~ '
foundation glacial fill materials were in fact pre-consoli-dated under former glaciers other than that state of the art approach which Consumers took.
A Since it is a long question can we take each part separately?
Could you repeat the question in parts?
- 5 --
MR. ZAMARIN: I can't. Can you read it back (to reporter) ?
(Whereupon the reporter read back the first part of the previous question.)
l l
- . : ? * *-t 2
- t
- : .ci .. : - - ,
9
186
'. KANE
- A Can we stop there?
- Where have I indicated that Consumers
- could have enken alternate approaches with regard to the ,
glacial fill?
Q Oh, I thought you did in one of your previous answers about three or four answers ago. If I am wrong in that then certainly clarify it now.
A I think you are wrong in that I have indicated that I I didn't feel a necessity for making alternates when I was
-- satisfied with the'one that was employed.
Q okay, my question was that in your 20 years of experience as a geotechnical engineer have you ever come across an
- alternate approach to that which Consuners took?
A Yes, an alternative approach to what Consumers took would be to run consolidation tests and make predictions off that,
'~
and there are projects that have done that.
Q We are talking about the approach that they took to show the ,
~
foundation, than the foundation glacial fill materials were 2
in fact pre-consolidated under former glaciers, that's the i 1- approach I am talking about. That's the approach that you
- reference in this thing that is headed tiumber Eight, okay, .
-- so with that in mind, in your 20 years of geotechnical experience have you ever come across or become aware of an 2 alternate approach to what Consumers did in that regard?
l a:: . : 5 . - .
- l'.t*** ***'t:3 't* **T'*
4
187 i KANE 2 A With regard to the glacial fill?
Q Yes.
A The question as I understand it is are there alternatives to
- avaluating the consolidation characteristics of the glacial i fill other than the consolidation tests that were run, is
~
that correct?
-' Q I will accept that.
A I do not have problems with the approach used by Consumers,
- but I do believe that other projects,. other alternatives were used other than consolidation tests to evaluate the consoli-
-- dation characteristics of the glacial fill.
Q All right, describe those for me?
A You could evaluate settlement behavior and consolidation characteristics by a field experiment.
Q Okay, is that basically what has been done with regard to the diesel generator bniid4ag?
A Yes, and I reiterate the importance of the time element
-' involved.
Q All right, were there any other alternative approaches to 2- what Consumers did in order to show that the foundation glacial fill materials were in fact pre-consolidated under .
former glaciers?
I' A The question, as I understand it, is are there other I alternatives that Consumers could do?
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. .. . :s.
B 6
188
. KANE Q Could have done other than evaluation by field experiment and
- undisturbed sampling and consolidation testing to show that
. the foundation glacial fill materials were in fact pre-consol-
- idated under former glaciers? .
- A There would be other studies such as establishing the glacial -
history which would.give in-situ the extent of pre-consolida-tion. -
Q Is that a generally accepted method of deta mining that the
. foundation glacial fill materials were in fact pre-consolidated
. under former glaciers?
.. A Sy itself, no, but it would be important input into the overall consideration.
Q Are there any other approaches that in your opinion were alternate approaches that Consumers could have employed to show that the foundation glacial fill materials were in fact pre-consolidated under former glaciers?
A None that I can think of.
O okay, so far we have undisturbed sampling and consolidation -
. testing. We have evaluation by field experiments and finally .
- glacial history which would give in-situ the extent of pre-
.- consolidation which you have indicated would not be sufficient standing alone, is that correct?
A That is correct.
I Q In order to evaluate the - strike that.
- - : 2 > : - . :
.--1. , . . . .. :- . - - . ,
, _ _ -- r --. - . - - - - - _, _ _ _ _ _ _ _ _ _ _ _ _
189 KANE 2 In order to show that the foundation fill I materials were in fact pre-consolidated under former glaciers in evaluation by field experiment, what would consumers have
' ~
done?
i A What would they have done? In building the plant fill, or the glacial materials, they could have monitored the settle-i ment of the glacial fill to evaluate the consolidation
~;
characteristics of the glacial fill.
Q In your opinion as a geotechnical engineer would that have been a feasible approach?
1 A By itself?
Q Yes? .
A No, I would have wanted to'see the results of that study in add 1 tion to consolidation testing.
Q And based upon what you have testified to in the last five t
minutes do you still believe that Consumers accepted the state l ,
of the art approach to showing that the foundation glacial 1
l~ "
fill material was in fact pre-consolidated because it didn't
, cause them a problem as opposed to because it was really the only acceptable way to do it?
A The discussion that we have had in the last five minutes hasn't altered the fact that it was dene, the consolidation
. l test was done of the glacial fill and it did not show a 2 problem and that was accepted by Consumers Power Company. ,
l i:-- - - , .-=s -
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l l
i KANE 190 2 -
- MR. ZAMARIN:
back, please (to reporter)? Could you read the question (Whereupon the reporter read b ack the Q previous question.) *
- Could you answer that, please? .
A -
Do I understand the question th ,
do I feel the only reason that Cat you are asking me to mean
' accepted the consolidation testinonsumers Power, company i cause them a problem? g was because it did not
( --
Q
\
1 You can answer that.
\ A .
i
{ -
The question I have is, is that Q what I am being asked?
\
No, but I'd like an answer t
{ '.
A o that.
\
{
My answer to that question is i
\
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was accepted because there was et is not the only reason it
~
Q of the art to do that testing and tnough confidence in the state 1 a Isn't it'lso a fact that you h o accept those results.
j -
}
- five minutes that that is reall ave testified within the last
(
i which is accepted as a matter ofy the only method of doing it A
\ engineering principle? *
-- I do not feel I have testified acceptable. that it is the only method '
2-I. have indicated there could e employed input b
into the entire story that would b concinsion. e weighed to make a final Q
!? okay, and my recollection of your testim you on it if you wish, wae that in th ony, and I can refresh
.t.
. 3 e three alternatives
191
. KANE ..
that 'you could come up with, based upon your 20 years of I l
- experience as a geotechnical engineer, all of them in your '
- opinion required undisturbed sampling and consolidation testing in order to be acceptable in accordance with proper engineering practice?
A I do not feel that I have said only consolidation tests would be acceptable in connection with those other inputs.
Q That is not what I said, I said that I took your testimony to be that those others would not be acceptable unless they ,
.. were also supported by consolidation testing?
.; A That is what I understood you to say and what I am saying is I would have confidence if a field load test were conducted for a long enough period of time and produced stresses in
.I the soils in excess of what would be experienced under loading of that particular structure.
, Q In your opinion would that have been economically feasible
( .:
for Consumers to do in order to show that the foundation s
l l- glacial fill materials were in fact pre-consolidated?
l l -
A If I did not feel it would have been economically feasible l e I would not have recommended it. I'd have been satisfied
(
'. with the consolidation test results.
I Q Really what I am coming back to is your statement that l
Consumers accepts the state of the art because it does not
.7 cause them a problem and your disagreement with my statement
- ; : - : =-
- ~ n - ,,_, -.- --. -, , , -, - - -, . , - - - - . . , - - - - - . - - - . - - . , - . , , - - - , , _ , , , - - < , , , , - - - - . - , - ,
192
. KANE that the reason that they accepted the state of the art is because it was the only practical way they could do it at that time. .
Now, do you still disagree with my statement that that was the only practical way that they '
~
could do it at that time?
A I agree with that statement.
MR. ZAMARIN: Okay, let's go off the record.
(Whereupon there was a short discussion
-- held off the record.)
(By Mr. Zamarin, continuing) : Let's forge on. I'm going to Q
show you a copy of view Graph 5 wh'ich is part. of Exhibit Uumber 12, and you can just keep that in front of you because I'm going to be asking you some questions about it. If you
- want to take a minute to glance at that to refresh yourself as to what it contained therein, you can go ahead.
A I think I am familiar enough with it.
Q okay, somehow I suspected you'd say that.
-- All right, can you describe or shcw us on that View Graph 5, Figure 2, which is a portion of Ex.ubit .
12, dat would you expect at depth testing in establishment of pre-consolidation pressure?
A First of all there is a question being sent as an interrogatorf
193
. KANE
- to Consumers to clarify an apparent discrepancy between the
- loads that are imposed on this graph versus information that we received in response to Question Number 4.
Q okay, what is that - as we go along if you will permit me to interrupt you at certain points so I can ask other questions and then we won't have to come back and I won't have to ask one of my horrendously long questions.
What is that discrepancy between loads to which you refer?
A It is my understanding in the information supplied in response to Question Number 4 that the load, the dead weight of the structure that existed at the time surcharge was imposed was 2.2 kaps per' square foot,and that is different than I see on this graph and 2.2 keps added to the in-situ curve would not have taken it to the magnitude of loading indicated on this figure. It would have taken it closer to 3 keps per square foot.
When you say taken it to 3 keps per square foot what you are Q
.i referring to is the dead load of the structure?
A Represented by Curve Number 2.
Q Are you aware that the 2.2 keps per square foot, and, by the .
way, that is the same as 2,200 pounds per square foot?
A That is correct.
~
Q Was intended to be the dead weight of the structure divided l
b
--~ -- - - ,, - , -w - - - , ,--r------ , - - - - - , . .,-n--,
194
. KANE by the perimeter area of the structure and that the numbers
- that you see represented on View Graph Number 5 represent actual computation of stress between the strip footing due to ,
dead load?
A I am not aware that the manner you arrived at the 2.2 keps ,
per square foot was'because you divided the total load by the area of the structure, but computations, to my knowledge, that were performed by the Corps of Engineers have indicated that the dead weight of the structure, the total dead weight of the structure, is close to 3.4 or,3.5'kaps per square foot,
- which is what you are indicating by Line~2, but the question that is generated in response to Question Number 4 is that not all the load of this structure was there existing at the time the surcharge was imposed.
Q You are aware, are you not, that the concrete was essentially complete at the time of the surcharge?
A I am not aware that the concrete was complete. I was under the impression that it was not complete.
Q It was essentially complete, there may have been some left to t I do inside, perhaps a few slabs inside the structure that
- remained to be poured, but other than that the concrete .
structure was essentially complace?
A I would have to try and understand the magnitude of the difference of what you mean by essentially. Are you saying
195 N
, it was 10 per cent less than the final load?
Q I don ' t thi nic we need to address this problem now in that 3
regard. l
., g MR. PATON: Excuse me, we have a question
. to you that asks you to clarify this.
. Q It is just that you may need the information in answering
- some cf the questions I'm going to ask you about View Graph Number 5, and it is your understanding that at the time of
- . the surcharge that the concrete in this structure was not complete?
A That is my understanding.
.. Q And did you then have some assumption as to the additional weight which would be added to the building when the concrete was completed?
A Yes.
,- Q And what was that assumption?
.: A The assumption is based on the information that was submitted to us and was that the load that utt.sted at the *ine of
- surcharge was 2.2 keys per aq G e 5 me and ultimately the t
load, the live load and dead load would be 4.5 keps per square foot.
. Q And that information you are taking off of View Graph Number 5, is that correct?
A No.
I : : - i. : . :
0 196
- XANE
- Q Where did you get that informacion that the live load plus
- the dead load would be 4.5 kaps?
A FroetFSAR documents, I think the 25-14 table.. ,
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- Q When you say 25 you mean 2.5-147
. A The table 2.5-14, I think that is the correct table. .
Q Are you aware that that 4.5 kapa is the =mw4=== contact strese including soil weight between elevations 620 and 6347
- A I am not aware that it includes soil weight.
, Q And in the calculations then that were done.by the Corps, to
. . your knowledge, did theyassume that the live load plus dead
.. load of the stw e itself would equal 4.5 kapa per square
. foot of stress?
.. A I don't think the information assumed that the. load - I think
. the Corps computed the dead load, and I th4nk the Corps used
. the information such as Figure or Table 2.5-14 to give them
. the magnitude of the live load.
.: Q You say they used that figure 2.5-14 to give them the
. magnitude of the live load?
Okay, do you know if the Corps of s' '
- Engineers' 3.4 kepe per square foot figure represented a net
.. pressure or whether it includes the soil fill between elevation 62S and 6347 ,
,, 1 1
. A Would you repeat the question?
)
.' Q Yes. Do you know whether the Corps of Engineers calculated ]
- - 5 . -
)
1
197
. KANE
- the 3.4 kaps per square foot figure representing the net
- pressure or a pressure including the soil fill between elevations 628 and 634?
A I do not think the Corps' computation allows for the soil
~
between 634 and 628.
A Q So then your understanding is that that calculation represents-the not pressure?
A It represents the dead load of the structure being applied at that foundation level.
Q And not including the weight of the soil between those
- ; elevations in that calculation?
A Curve Number 1, such as has been indicated on View Graph Number 5 takes into account the soil between elevations 634 and 628, so their computation was not again taken into account.
~
Q You say would not again because it shouldn't or would not again because you know that their calculations didn't7 A I do not know whether this calculation did. It should not.
,' Q Do you know if the Corps computation assumes a mat foundation?
A It is my understanding the Corps of Engineers computation allows for a wall footing and uses the Sousines method, 3-o-u-s-i-n-e-s, there may be two S's, and using the acusines method estimates the vertical pressures below the
~
footing level.
E
198
. IANE
- Q' Do you know how the corps went about calculating the live load for the building?
A I think they deduced it from information submitted in the .
FSAR documents. I think Table 2.5-14 is part of it. I think
- that table is cited in response to Question Number 4 that gave additional information.
Q Okay. If you will take a look at view Graph 6, I believe, do you have that?
. A I don't have it.
Q You don't have View Graph 67 ,
Now you have View Graph 6.
Can you tall me from view Graph 6 approxi-mately what the calculated live load is as done by the Corps?
The magnitude of the live load at elevation 628 foundation level is 1.5 keps per square foot, and you say that it is your understanding this was calculated based upon information provided in the FSAR as well as answers to question Number 4.
A I don't think it is correct to say calculated, I th hk it was, I think it was assumed based on other information presented 5'
.. in the FSAR.
.. Q And do you know who it was who made that assumption?
. A Yes.
O Who?
- A Hari Singh.
~: -
4
139
. KANE
. Q Did anyone else from the Corps, to your knowledge, do any
- ocher calculations with regard to the adequacy to surcharge loading or in *=== of the amount of the loading and in terms of the length of time the loading remained in place?
A I think I can answer, but I have to break your question into parts.
Q Sure.
A I th4nk Hari Singh is the only one that made an estimate of the influence of stress with depth under loading. I am not sure of any other Corps reviewer who may have evaluated the
- time element that the surcharge load was imposed.
Q Are you aware of any reviewer or any individual who evaluated the adequacy of the surcharge loading in terms of the
. sagnitude of the loading?
A I am not aware of anyone other than Hari Singh.
'~
May I correct that? Hari Singh :nade the computation. To my knowledge it was checked by John Grunstrom.
\
Q Calling your attention back to view Graph Number 5, assuming that the stress increments due to structural dead loads is accurately represented on view Graph Number 5, and that the increment due to live loads is accurately ret, resented on View Graph Number 5, and that the stress increment due to the I' surcharge is accurately represented on view Graph 5, can you tell me at elevation 618, for example, whether that represents
- c: : -
9 y - - - , - - , ,----n --.,--v-~- - -
200
". KANE a surcharge load that is some multiple of the final load?
A It is some multiple of the final load excluding extreme environmental loads. -
Q And can you approrfmate for me what multiple of the final
. load those stress increments represent at elevation 6187 .
A Would you repeat your question, please?
Q Let me strike that. ,
First of all let me ask you how you calculate - no, never mind, I':n not going to do that.
Yes, can you tell me what multiple of the final load the total surcharge load as indicated for elevation 618 represents?
A To clarify your question, I think what I am be'ing asked is what per cent of the final operating 1 cad, excluding extreme environmental loads, what per cent is that of the total load that was induced by the surcharge load assuming these are correct? ,
Q That's correct.
(
A (Continuing) : That these parts were correct?
Q Yes, at elevation 6187 A By eyeballing this View Graph Number S I would estimate the final load as represented by Curve Number 5 is 75 to 80 per cent of the final load induced by the surcharge.
Q Have you concluded in that the effective stress due to the
I i
201
. \
KANE i 2 dewatering as part of the load?
I A Yes.
. i Q Why have you done that?
A I thought you had asked me to do that. I thought you had
, asked.me to look at the difference between curve Ntamber 5 and Curve Number 3.
1 Q No - okay, what I'd like you to do and I will direct your j attention back to what you had numbered Paragraph 4 of 1
l Exhibit 11, where you made the statement about placing a I l
surcharge load that is 1.S times the fi mi load to assure l secondary consolidation is reached, and what I am asking you ;
to do now is to tell me whether based upon your eram4 nation of view Graph 5, and assuming that the values represented thereon are accurate at elevation 618, for example, the surcharge load was 1.5 times the final load, and if not, what multiple it was? I A I have to ask you to clarify what you mean by final load..
Do you mean final load after dewatering?
Q I mean whatever you meant in Paragraph Number 4. Why don't you tell me what you meant by final load in Paragraph Mumber 4 of Exhibit 117 A I would mean curve Number 5 which is the final load. Curve Number 5 allows for the effset of dewatering. I am assuming, is that what you are indicating to me?
e: .
202
', KANE
- Q Yes.
A There is a little notation that says stress increments-due to l 2 live load and lowering of ground water material from 627 to .
700, so Curve Number 5 is what you estimate to be the final
. load, excluding extreme environmental load, which includes
- the effect of dewatering, and so if you are asking me to l
i : compara at elevation 618 the ratio of curve Number 3 to curve l
l
( ; Number 5, and am I correct in that is what you are asking me?
. Q I':a not ask4ng you to compare particularly curves, what I am i
! .; asking you to do is to tall me for elevation 618 what ratio l
.; you would have that you refer to in Paragraph 4 of Exhibit 11 that is the normal practico of surcharge programs to place.
e a surcharge load that is 1.5 times the final load, and what I want to know is if in your opinion and in your interpretation
.' of the data that is indicated on View Graph 5, if in fact at elevation 618 that normal practice in surcharge programs of ,
. placing a surcharge of 1.5 time the final load was done and
.. if not what ratio there was? c A I will indicate what I consider to be a ratio of 1.5 greater
. th an final load. The difference on view Graph 5 between ::ero load and enose values indicated by curve Number 5 are the final loads. I would take the magnitude of those loads and
. multiply those by 1.5 to develop a curve which is 1.5 times
203
. Ltu
- the final load.
Q In your opinion then would normal practice in surcharge programs in attaining that ratio, that 1.5 ratio, include the stress increments due to lowering the ground water table as we referred to as dowatering?
- A Lowering the ground water table is a site specific condition 3 being induced at Midland. It would not necessarily be
- applicable to other projects.
- . Q Isn't the stress increments due to lowering the ground water
.. table merely the increased weight of the soil?
.. A That is correct.
Q And in doing this ratio, this coming up with this 1.5, 1
. wouldn't you exclude the weight of the soil?
- A No, in that if you did not add it onto your curve Number 5 by dewatering you would have to take it into account with Curve
. Number 1, which is the in-situ effective stress. If another
.: site did not have dewatering but had a lower ground water
. : table it would be reflected in a higher value in Curve Number 1.
Q What difference would it make whether it is included in Curve Number 1 or whether it is simply viewed as that area between
. Curve Number 2 and Curve Number 57 .
A Repeat the question, please.
. Q What difference would it make whether that is included in Curve Number 1 or simply shown as that area between Curve e 6e
- i * - w- - ---e -w - - - . . . , . - - - - - - .
i 204
. KANE
. Number 2 and Curve, Number 5 as is shown here?
A If your question is related to Midland specifically -
a
_ Q (Interposing) : Yes.
A (Continuing) : - it would not make a difference, but what ,
~
I have indicated is if you had a sita that did not have dewatering but had a ground water table lower than say the
. depth that is iM4-=ted by 603 your Curve Number 1 would be
- different and that difference would be equal to what you have
. allowed for due to draw down under the dewatering system.
. . Q And would you then consider the in-situ effective stress
..; represented by that curve in arrival at that 1.5 times final load ratio?
.- A Yes. ,
. Q You would consider the weight of the soil or the stress induced by the weight of the soil?
. A If I am attempting to impcae a surcharge load that introduces
-- stresses in the foundation,1.5 times those stresses, then I would make that allowance.
0 You say you would make that allowance, you would enter the c
. stress induced by the weight of the soil underneath the entire structure?
A I don't understand your question.
Q Maybe I can rephrase it. Does the 1.5 ratio that you referred to in Paragraph 4 in Exhibit 11, include "Jie weight
--, -. .w_- _ , , , , ----.-w-, w--
205
~. KANE
- of the soil or does it only include a comparison of the <
- dead load and live load of the structure as compared to the
. dead load and live load plus the sur=harge?
A The factor 1.5 would be applied to the loading that is being
, induced by the structure and not the soil weight that is there.
+
Q okay, so then in looking at the elevation 618 of view Graph 5, would you then add the area between the distance as -
represented in load between Lines 1 and Line 4 to the distance between Line 5 and Line 3 and divide that by the distance
_ between Line 1 and Line 4 in arriving at that ratio?
A I don't think it is correct to look at elevation 618 when I am trying to determine where I'm going to apply the load. I think I have to go back up to the surface -
Q (Interposing) : Okay.
I A (Continuing): - and then there I would take the difference
(
, between Curve 1 and whatever curve is correct for the final load, get that magnitude of loading, multiply that by the l
i factor of 1.5 and impose a surcharge of magnitude at that elevation.
Q Well, let's assume we were doing the calculation at 613.
A I don't think it is practical because you are applying the surcharge loading up at the surface.
O I see, so you would then seek to derive your 1.5 ratio at l
, ----- .._ ~ . ,._. _.,.__- - _. - , - _ - , _ _ _ - - - - - - . - . , . _ _ , _ . . , . _ - - _ - , - - - . . -
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206
. . KANE
! elevation 628, that is the level you would use in arriving
- at that?
A Yes, r Q And in doing that would it be that you would take the load -
2 represented by.the area between Line 1 of. Curve 1 and Curve 4 ,
and add to that the area, the load between Curve 5 and curve 3, and divide that by the load represented by the line between "
Curve 1 and Curve 47 -
A I'd much rather answer that by saying what I would do.
Q Well, I'm asking you that way so that I can understand your l
answer on here.
A Perhaps if I tell you what I would do you will understand it.
Q okay, let's try it that way.
I A I would take the difference between Curve 1 and what is determined to be the final load, and I would multiply that
' load by a factor of 1.5 to give me the load that I want the surcharge to impose at that elevation and then I would check the depth under that surcharge at that elevation to see that i I have in fact caused the stresas at those depths to be f
I increased by a factor close to 1.5.
Q ;fhen you sav increase to a factor close to 1.5, all the way down to elevation 603, for example, on View Graph Number 57 A To the depth of the compressible layer.
O And in your opinion what is the depth of the compressible t
207
. KANE
. layer?
A At Midland?
. Q Tes?
l A To the depth where we have the natural glacial fill saterial.
, Q Can you approximate for me, just so I understand what you are saying, the ratio at elevation 628 as represented on View Graph Number 5, and as you are eye ballim those loads call thera out so I can write them out?
A Can I eye ball the loads indicated by these different curves, is that the question? .
.. Q Yes, and go through your calculations of seeing what the ratio is at elevation 628 as indicated by the figures on View Graph 5.
- A Assuming Curve Number 1 is correct, and assuming Curve Number 4 at elevation 628, I would eye ball Curve Number 1 te have l a sagnitude of 0.8 keps per square foot.
I would eye ball Curve 4 at 623 to have a magnitude of 4.4, so that differant of 4.4 minus 0.3 --
' Q (Interposing) : Which is 3.67 A (Continuing) : That is correct, and I would multiply that with a factor of 1.5 to give me the magnitude of the surcharge load that should be imposed.
Q And when you refer to the surcharge to be imposed are you referring to the weight of the structure that was there plus
,_.-._v.-___ .., _.. , _ _ . _ -, . . _ , . , _ _ _ _ , _ , , ,,,___--,___._,-,m.m_ , , . . , - . . ,,__. ,______,,, _ , . , _ . _ _ _ . .
208 N
i i.
the surcharge that was added to it?
A No, because the difference between Curve 1 and Curve Number 4 l .
is taking into account the weight of the structure there. ,
Q All right, and if you add to that then an additional weight l
by surcharge, would you be look.ing for the weight of the ,
l surcharge itself, just the sand in this case, and the diesel generator building to be in a ratio of 1.5 with respect to j . the live load plus dead load that the bui1 ding is anticipated to produce?
A I think that is what you said, and I don' t think - as I understand what you have said my answer would be yes.
i' Q Okay, so just a simple illustration that doesn't bear anything',
any relation to tnis, if the dead load pins, live load were l
anticipated to be two pounds, then your 1.5 would require 4
sand in that structure equal to three pounds, is that correct, to get a total weight of five pounds?
A No, I would need a weight of sand equal to the one pound. .
I
. Q All right, okay.
. A (Continuing) : Which is giving me a mav4 num loading that i because of the surcharge and the structure is. equal to 1.5.
Q okay, so what you are doing is adding the weight of the .
i surcharge on the weight of the structure?
A Yes.
Q And that is the weight of the surcharge as you refer to it in 1
209 EANE Paragraph Number 4 of 5'whihit 11, is that right?
A Yes.
MR. ZAMARIN: Off the record.
(Whereupon the deposition was recessed - l
', until Thursday, october 16th, 1980 at
~
9:00 o' clock, A.M.)
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