ML20090A851
| ML20090A851 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/04/1980 |
| From: | Kane J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101100761 | |
| Download: ML20090A851 (50) | |
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e Transcript of Proceedings I
,. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Befora the Atomic Safety and Licensing Board DEPOSITION OF JOSEPH D, RNE
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VOLUME VI i
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W Bethesda, Maryland Thursday, 4 December 1980 ACE-FEDERALREPORTERS,INC.
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Setore the Atemic Safefy and Licensing Board 4
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In the matter of:
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6 CONSUMERS PCWER COMPANY 50-330-cM
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50-330-OL 9
DEPOSITION OF JOSE.:H D. XANE
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VOLUME VI
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.I I Bethesda, Maryland 2
12 Thursday, 4 December 1980 13 Deposition of JOSEPH D. KANE resumed.. pursuant to 14 adjournment, at 8:40 a.m., in Room P-114, Phillips Su.11dir.g.
l 15 7920 Norfolt Avenue, Sethesda, Maryland, before. dill.iam y
16 R. Sloom, a notary public in and for the District of s
17 Columbia, when were present on behalf of..,s he respect.ive t
18 partiest 19 on behalf of the Applicants I
20 RONALD ZAMARIN, Esq. and ALAN S. FARNELL, Esq.,
21 Isham, Lincoln and Set e, one First Na tional 22 Plaza, Chicago, Lilin is
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-yAMES,E. BRt1NNER, Esq..,4Consumors Powsr Compcny, 2
212 n. Michigan Avenue, Jackson. Michigan 3
on behalf cf the Regulatory Staff 4 4
WII.I.IAM 0. PATON, Esq. arid SRADLEY JONsS, Esq.,
5 office of Executive Legal Director, 6
United States Nuclear Regulatory Commiss. ion.
7 Washington, D. C.
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5 JOSEPH D. KANE (Cont'd) 364 I
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2 Wher e'upon,
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JCSEP D. KANE j
3 resumed the stand, having been'previously duly sworn, and I
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4 was examined and testified further as follows:
5 1
6 MR..DATON:
The Staff. wants to make a statement
, [J aoout the continuation of. the deposition of Mr. Kane.
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l-Ril We are now in our sixth day of Mr. Kane's 41 S
lQ The Sta.ff f eels that it has been more than
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reasonble. in. c.coparating with.the applicant with respect to
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We did not,rsquire. strict compliance with
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Mr. Kane agreed to travel to Detroit at
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,' g one point and have his depos.ition taken because it was f or
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.the convenience of. the applicant.
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.- full days of depos.ition is beyond a raasonable amount.
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b We note applicant'.s ' intent to continue his 16
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17 depos.ition today.
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willing to have.Mr. Kana's deposition continued for one more g.]
19 But, beyond that, we think tnat we will no longer wnMI 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
U$$j volunteer Mr. Kane as. a w.itness in the depos.ttion.
OIM 21 MR. ZAMARIN:
,fe.11, my position is as I stated it
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3 no t true that we're in our sixth day.
There wer wo days in Detroit and a partial day in Detroit wnere we ended early 4
5 in order to accoomosate the. travel plans of the Sta.ff.
. Yesterday we, stopped at thr.ee-thirty in the af tsrnoon 6
7 because of commitmeats that Mr. Kane had.
The prev.ious day 8
we stopped at five, where otherwise it had been the 9
experience and practics to go to.six.
And the statement that he traveled to Detroit for 10 i
our convenienes is absolute nonsense, and it's simply not
.11 We resumed his deposition in Detroit since he has 12 true.
13 taken somewhat of an advisory role in this, and I was going 14 to be in Detroit anyway for depos.itions that week, and we 15
.tharef ore decidad, rather. than traveling back to Washington And I
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to.take his deposition, that we wculd take it there.
16 17 think your memory wi.11 bear that out.
o la My position is that in taking his depos ition 19 I've had trouble getting str'aightforward answers to 20 ques.t ions.
If he had answered questions without the 21 necessity repea:Ing enem, without the necessity of 22 cross-examination in Jose areas, and without the necessity i
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2 a direct answer, his deposition procaoly would have been 3
completed in a day and a half.
I don't know what it is you want to hide by 4
5 refusing to le.t him go on, but there has got to be some 6
reason beyond simply saving time.
And my intention is to 7
continue the depos ition until it's completed.
And I think that any attempt by tha Staff to cut off that discovery, in 8
the my mind must an attempt to try to hide something that 9
ICL applicant ought to know.
11 Md. PATONs I would like to re.spond that your repeated statement, allusion to the f act that the Staff has 12 got..something to hide, represents your volunteered. injection 13 14 in5 these proceedings of something that is totally 15 unnecessary.
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The comment with re.spect to traveling to Detro its 16 17 my recollectf.on is that Mr. Kane was orig,inally scheduled to 18 have his depos.ition taken here, but that then you were and i
19 going to tage the depositions of the Corps in Detroit, 20 there was an agreement that Mr. Kane would travel to Detroit 21 and have his deposition taken first.
My recollection is 22 that his de,2asition was to be completed, and then he would
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5 Md. ZAMARIN:
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CROSS-EXAMINATION (Continued) 9 10 BY MR. Z)J4ARIN:
Mr. Kane, you realize you're still under oath, JI Q
12 don' t you?
13 A
b do.
'l With regard to the recharge from.the cooling pond 14 Q
during..the t.ime of the diesel generator building surcharge, 15 f.
I do you, based upon your experience and expartise as a 16 geotechnical engineer, hava an estimate as' to the amount of t
17 time it would take for the water taole in the area of the f
18 19 diesel generator building to respond to a rise in.the q
20 cooling pond to 627 f aet 2 inches?
'l 21 A
The time Lt. would take to respond is dependent on i
21 the permeability of the materials that it would pass 1
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past deposition, of where I suggested analyses..to evaluate 2
why the pore pressures never raised to the level they did.
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i Until I know that pond and.the diesel generator building.
6 information in detail I would not want to make an estimate 7
8 of. ths t ime.
Could you describe for us the mechanism of 9
Q 10 recharge in o that words, how it is that water in the pond I
somehow aff ec.ts the water table underneath the diesel
.11 12 generator building?
Whan you introduce a new source of water such as a 13 A
IA pond or a lake.thers Ls a period where that pond has to And initially. the gradient which would 15 develop a gradient.
be expected would be more vertical" until the lower portion
%.e 16 becomes saturated, and then you would expect an outward 17 la development of the gradient off.the pond as it passes
.through the ma.ter.ials to the diesel generator building area 19 20 Q
Mnat do you mean by a gradient?
.i 21 A
I mean.the diff erence in water elevation between the source,.which would me the pond, to the pc. int where.it 22 l
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So are you saying, then, that water from the cooling pond would actually travel to the area underneath 4
5 the diesel generator cuilding?-
If Lt is a higher elevation than the natural 6
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groundwater table, yes.
Have you ever heard of any case of consolidation d
Q tests being conducted af ter a preload?
9 4
b A preload program similar to Midlands is that your j
10 A
il question ?
12 Q
Atter any preload.
7/ve heard of consolidation tests being taken
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af ter an emcankment was placed to Qndarstand the change in 14 soil characteristics because of that embankment leading.
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.a d in. that sense the embankment loading itself would be the 16 n
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-Okay.
So what you're saying is that in an embankment 19 loading, that that is analogous in geotechnical terms to a 20 21 preload?
I had asked whether you wanted me to ref erence it 22 A
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.s to. Midland?because;thpre,are. problem.s wi th Midland,.in my' 7
NRBwb l-mind, of calling it a preload wnen in fact the load was 2
3 added af ter, the structure was bun c.
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4 If we're. talking abou:-
5 Q
I.undarstand that.
That's why I asked you.
I'm
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not restricting it to Midland.
I just wanted to know if in f act you ever heard of consolidat. ion tests being done af ter 7
8 preload.
9 A
In the. sense of proloading - and that is what I think is generally acceptad by the engineering prof ession, 10 is, whers a load is plac.ad on a soil deposit before
.11 and that is built to cause a settlement to occur before 12 a structure the structure is built - I've indicated in the past that in 13 my professional experienca I do not have a. lot of experience' 14 15 with.that type of preloading, and, therefore, in my experience I do not know of conso'lidat. ion tests that were 16 17
.taken af ter. those operations were pe rf ormed.
4 Ia Q
All right.
Now, have you limited your answer now to just 19 preload such as was done with the diesel generator building l
20 21 at Midland?
I'm not clear on that.
22 A
I have accepted that condit. ion.
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And I have actempted. to define, wh.at I" understand
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is :he preloadinq process normally talked aoout 4
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And with regard to the normal preload that is 6
7 connonly talked about in..the engineering profsssion, you're no.t aware of con 91idation. tests ever having been done af ter 8
9 preloadt is that right?
10 A
That is correct.
.Il Q
With regard to a surcharge treatment such as that which was done at.ths diese'l generator building, have you 12 13 ever heardhot consolidation tests be ing done af ter that?
14 A
I have yet to locate a project.where surcharging 15 af ter tne structure was built has be.en completad.
I have b
searched the litarature and I cont'inue to search the 16 17 lite ra ture.
So, therefore, I do no t kno,w of any le consolidation tests that were taken af ter surcharging a 19
.structur e.
20 Q
You say you've searchad th.e literaturs.
Do you 21 sean you've searched the engineering literature and you have 22 found no case where a surcharge was imposed af ter a
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- I I have indicat.ed co you in past depositions-I 2
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4 A
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. :n I's. Just tryi.ng to understand your previous answer 5
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6 is all I'm rete.rring to.
I didn't understand what you
,3 You said you'd saarened the 1iterature, and then you
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_2fgj We.ll, you keep making movements, and I'm not sure
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4 I'm saying is, in my previous deposition I
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have given you the source of a book which I understood a
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I have attempted to find that article in i}
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I have not. located s:J.?-'
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17 Q.
Okay.
. L. _c M OS 18 My quest. ion again, though, isa When you say
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All I'm ge tting a: is,' you said "searened," but you didn'.t say what happened af ter you searched.'
4 5
A I have not fcund one.
6 Q
Okay.
7 A
But I also would like to indicate that I have e
contacted memoers of. the Corps of Engineers other than the 8
9 Detroi.t Di. strict, particularly the dater. ways Experiment to Station, and omther division offices, a ttempting to understand whether they. had this similar type of
.11 12 construction, and I was unacle to locate anyone with that 13 experiencee Did you ask any of them whether they were aware of 14 Q
15 any instances --- whother they had it, or somebody else had b
it,or whether it was in the litera'ture, or anywhere else?
16 17 A
I did.
u 18 Q
And they told you they did,not?
19 A
To their recollection, they did not.
20 Q
Okay.
21 Have you ever heard of someone named Terzaghi?
22 A
Yes.
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'MIFo you.fcm.111an..w ith.'ar.tiilas or texts wri.tten by 2
Terzaghi?
3 A
Yes.
4 Q
Nho is Tertagni?
I believe it 1: Karl Terzagni.
5 A
That's correct.
i' 6
He's considered the f ather of soil mechanics.
I 7
Q obviously, then, an auth'ority on soil mechanics?
8 A
Y e.s.
9 Q
Is it a commonly a.ccepted practice, in your opinion as a geotechnical engineer, to perform consolidation 10
..I I tests.after a preload?
12 A
Isn't that the same identical question?
13 Q
No.
I had asked you before if you knew of any.
14 Now I'm just asking if 1: is a commonly accepted engineering 15 practice. So it's a diff erent question.
C 16 A
I don't think praloading, particularly with 17 structures such as nuclear power plants,owhere the safety is la that much more significant, I don't.think preloading has 19 been done on-a large enough scale to say there is a widely 20 accepted engineering practice acout either taking 21 consolidations before or af t.ar the surcharging operations.
22 And so, on the basis of that I've indicated to you in the 1
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e understand; pr.eloading.
I do not
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preloading and 1.ts advocation to the nuclear K5wer plant 3
project field and other fields, whether there is a common
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5 practice of taking consolidation. tests; atterwards.
In my op. inion, it is a unique. enough process, and 6
3 i.i I would 7
the importanca at Midland is important enough, that
- i be encouraged to take the consolidation tests.
9 8
My quution was - whether it 1.s with regard to
~
9 Q
nuclear plants or Midland or an.ything else, or whether you 7-9 10 would be encouraged to take them - to your knowledge is it
.11 a commonly accepted engineering practic,e to do consolidation
-5 12 13 tests af ten preload?
T 14 MR. PATON: - Let me ask for clarification.
Do you 1
. ;{l i
15 mean, disregarding. wha.th.er it's nuclear or not?
Is that
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T 16 what you said?
Si 17 MR. ZAMARINS 34y question was ip general, and he
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18 qualifi.ed it by ref s.rri5g.to Midland.
And that was not
~.1 19 anywhere in my question.
p;
- y9 20 MR. PATON Okay.
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.h THE WITNESS 4 I. th ink it is necessary to address 1
21
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.ths. significance of.the structure to be able to answer that 22
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And L think structure involved and its saf ety si;nificancs.
2 In some cases enere wculd be no need.
If you 3
You must-were building a warehouse which would suff er no 4
If you're consequences, there would be no need to do it.
5 building something of.saf ety sign.ificance, such as a nucisar 6
power plant or a dam, there very well may be a need to do 7
8 it.
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I think I must answer in that regard.
9 10 S't MR. ZAMAR IN :
I'm rea.11y not talking about a need.
Is it a
.11 Q
f act, then, you're simply not aware whether it's a commonly 12 accepted engin.eering prac.tice in certain instances?
13 You keep bringing it back to whether there's a 14 I'm talking acout connonly a.ccepted 15 need or not.
b 16 angineering practice.
You'r.s asking me-my opin. ion abgut a commcnly 17 A
accepted engineering practice, and I can only give you my 18 19 feelings.
I can't answer for someone else.
i 20 Q
All right.
So what you're saying is that you don't know, or 21 you can't testify as. to. what commonly accepted engineering 22
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5 individual basi.s and on the s ignit icance of. tha s.tructure.
6 Q
I taka it, then, that your answer is no, that you're not aware, then, of a. consenly accepted engineering 7
practice with regard to running consolidation tests af ter 8
9 preload7 10 A
That is ca.rrec.t.
And.I have given you my opinion.
i Ji Q
Are the physical laws or principles that govern 12 consolidation d.iff ererst for nuclear plants than for 13 warshous esh 14 A
No. The saf ety significance is what is the 15 ditt erenca.
i C.
But the pnysical aspects of consolidation, and the 16 Q
17 mechanics of consolidation, wouldn't diff er at all, would 18 they7 19 A
That is.ec.rrect.
20 Q
Under static loads would it make any dif ference 21 with rsgard to settlement of the. structure if there were 22 hard spots supporting the diesel generator bu.11 ding?
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2 3
Q Nould it sti.11 be a concern 7 4
A Mould you repeat the question, please?
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5 MR. ZAMARIN*
Read the question, please.
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C1hereupon the Reporter read from the record as 6
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THE WITNESS I could. think of conditions where KG
$d even under static load the diff erential settlement which C
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13 Q
T. ell ma wnat those cond.itions are.
-Z*a To where I had under'.the f cundation of a structure
".i 14 A
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15 is relatively incompressible soil and in another area a
. compressible soil, and under.the. static load I would cause a Wi 16 17
. significant diff erence in se ttiement to gccur to whsre that cri st$
ei diff erence in settlement could result in overstrassing of UN 18 6
. M.,4 19 that structure.
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20 Q
Okay.
Ju.3 My question was, Under a static load wou1d it make 21 a diff erence with raspect to. the die.sel generator cuilding 22 f %v;.
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A I would consider the hard spots to be the relatively inccmpressible zone, and other areas to be more 5
s 6
comp re ssible.
Then what do you postulate would happen if 7
Q.
Okay.
that would cause a change in the support provided by these 8
9 hard spots under static load?
Depending on how the loading is applied.. whether 10 A
more of the load could oe taken up by the incompressible
.11 in live 12 mater.ials, and, for some reason, either a change 13 load or some other 1 cad, whers that would be moved at a later time to be placed on the more compressible portion.
14 15 Q
Okay.
So what you're ta1xing about, then, is a-C change in the load,.the. static l'oads is that co.rrect?
16 17 A
A. change in static load.
18 Q
Okay.
19 So my question, however, is that under the static 20 load would it make any diff erence with regard.to settlement 21 if there were hard spots supporting th'e diesel generator 22 building?
And I tage it what you're saying is that not w
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'3 If a structure had. come -to the phase of secondary 4
A consol.idation and there was no change in static loading, 5
s But
[6 then the problem of having hard spots would be.1 inimal.
if tharm is a change,. then there could be a developmen.t of
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problems.
2.
You said the problem with hard spots would be s'
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. minimal.
Would there be a problem at all?
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' compressibie area, If it were significant secondary consolidation -
14 15, and you do have that. with some types of solls - it could oe c,
O ' a problem.
r 17 Q
And you'rs now talking about a.,pituation where
-18,
there is some change in the loading?
19 A
No.
I'm talking now-20 Q
-or static loading?
21
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A I'm talking acout the di.ff erenes in secondary 22 consolidation between the two types of mater.ials.
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and tnat there was no chang's in that static loading, that 0
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That's correct.
sy.a And what I don't understand, then, is what the g
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Do I understand you to say that what you
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If it wers only on hard spo.ts, then there would T
2 A
3 not be a procles.
But if it is on both hard spots and compre ssiola materials you may nave a problem.
4
(
5 Q
My question, and all these questions have been So---
6 that Lt's supported on hard spots; okay?
)
7 A
I'm assuming--
In the past when I've used "hard-S' spots
- I'm talking about an irregular foundation that And includes both hard spo.ts and compressible materials.
9 all my responses today have assumed that cond.ition.
10
.I I Q
Okay.
12 What we're.talkin; about is a structur.e under If static loads that is supported on hard spotst all right?
13 that were tne case with the dissel generator building, would 14 15 i t-
. Strike. that.
Under static loads, woul'd.it make any difference 16 if the diesel generator building were supported on hard 17 18 spots?
19 A
And I have to asks' Are you retefring to the diesel generator building foundation bei.ng supported only on 20 i
21 hard spots?
1 22 Q
Yes.
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Q A1.1 right.
What'i.f~you assumed th W they can' ?
4 A
Than the quest. ion becomes, during the course of
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5 operation of tha.t structure whether the additional long ters g,.
72 loading is going to cause any s,ettlantent in the material 6
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- ~p under the hard spots, and whether that is a f actor.
7
..s Are there any observations that you're aware of W4 8
Q with regard to.tha die.sel generator building that shad any m
9 7"':j]
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IQ light on that, one way or the other, for you as a
,;j
.11 geotechnical engineer?
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There are observations in the diesel generator i
13 building, and that is, the potential for hard spots being introduced by the conduits, by th.e cac.kfi.ll, by the fjj 14
~q excavations that. you have introduced into the foundation -of 4
15 16
.ths diesel generator building.' And they are 'a factor in a 2.)
17 potential diff erencial settlement of the diesel generator s
~N 18 bu ilding.
..i 19 Q
In your. last answer you talkad about whether there if
.m was material under the hard spots wnich, under additional 20
-;.5.
And 9
2.1 long term loading, could undergo ad:fitional sattlement.
~-1 22 I'm asking you if.there are any observations with regard to
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geotecnnical engineer that would shed any lignt as to r
2 3
wnetner that in f act may be the case.
4 A
I don't think we have been given 'enough
.s information ourselves to know exac.tly the grade elevations
~-A 5
- b of all the conduits under the diesel generator building, and
- 2..:l 6
the backfill details of those conduits, and then to look at
=y 7
fg Som e of tha t 6
the material below thosa excavations.
, et
' 3.3 information has been requested in tne August 4, 1960 report.
- j.,
4
. j4 for the purpose of evaluating what you are now asking me.
..js 10
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'l 11 MR. ZMARIN:
Would you read the question cack, t jj
%y
, ;g 12 please2 Xnd would. you carefully listen to the question?
- Y'yl 13 (Whereupen.the Reporter read the pending y
14
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f-15 question.)
THE WITNESS:
I think I've answered your question.
Io
< ' ^1 17 MR. ZAMARIN8 I don' t enink you have.
. n 2-gfj 19 Q
You've told me what you don't know.
What my Mi It was Are s.dm question was-uo you want to hear it again?
w 20
,;!;m,y:1 you awara of any observations, as a geotechnical engineer, w.
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21
- 6..',d that shed any light on it?
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Thers is a d istere nce ~
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Q Then tall me.
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5 A
And to answer you what I think, I.say I need this i
6 information to come to a conclusion whether there is--
7 Q
Fine but that wasn't my quest. ion.
You have to 8
answer the question.
You're telling me what you need for a 9
conclusion.
All I'm asking you is what you're aware of, l
10 what you've ocserved.
That's what I want to know.
11 MR. PATON:
I w1.11 instrue t tha witness he can e
12 certainly explain the answer.
e 13 MR. ZAMARIN:
Ha can explain them if. I ask him the 14 question.
He wants *o answar a diff erent question.
This 15 has been the proolen all alo~ng.
._y 16 I didn't ask him what he nn eeds to know to form a 17 conclusion.
And tha,t's what he wants to p.11 me.
s 18 SY MR. ZAMARIN:
19 Q
I want to know what you do know, whether that's encugh to form a conclusion or not, what you do know 'that 20 21 sheds some light on this.
22 A
I do know that the conduits ar up in the fill.
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Because I do 'not know the exact gr.ades of some of 3
your conduits, I do not know'whethat there is a proolem.
4 I'm assuming you're askin; me not Just what I know-
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but whether you f eel - I f. eel it is a problem.
6 Q
No, I d idn't ask you tha t.
7 A
Okay.
Fine.
8 Q
I didn't ask you that.
9 A.
It's my understanding, then, that the conduits sit i
10 on top of the fill.
That's what I know.
Q Okay 12 Are there any other ooservations, other than what 13 you have just told us, and that is that you know the 14 conduits sit on. tha fill, that shed any lignt as to whether-l 1
15 there is material. undar the hard spots which, af ter 1
Q-6 16 additional long. term loading, cod 14 undergo furthar 17 se ttlement and, therefore, cause a problem with the diesel
,1 y
3 18 generator building?
Or is that it?
h 19 A
You'r.s asking me'do I know whethat there is soft i
20 material undar the hard spots?
3 21 Q
No.
q 22 MR. ZAMARIN4 rfould you read the question back, 1
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4 I-lE WITNESS 4 I nave no ceservations.
I have
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6 SY MR. ZAMA.RIN8 7
Q In your opinion, are the only hard spots that could be supporting th.e diesel generator cuilding, concuits?
8 9
A No. There could be hard spots because of excavations that you placed in the diesel generator bu.11 ding to area, particularly along the nor.th side, which would be the
.11 12 granular fill, which may also be introducing hard. spots.
's there anything else that in your op inion could 13 Q
be introducing hard spots which are supporting the diesel 14 15 generator building?
.. {
Between condui.ts and ths' bac.kfi.11, and the 16 A
17 backfi.ll for other excavations, I ca.nnot think of others.
u la Q
Okay.
19 When you talk about backfi.ll for other
~
20 excavations, you're not talking about all the fill under the 21 diesel generator building, are you?
after you place the fidi 22 A
No.
I'm talking about, l
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Have you reviewed Consumers Power Company's 3
Q seismic shakedown analysis?
4
(.
5 A
Would you explain what is meant by " seismic 6
shakedown analysis?"
Well are you aware of a seismic shakedown 7
Q analysis that was performed by Consumers Power Company?
8 I have reviewed as 9
A L don't recognize anything that 10 a seismic shakedown analysis.
.11 Q
Okay.
So when I.say " seismic shaksdown analys is" with 12' regard to the Midland site or the Midland fill proclam, you 13 14 don't have any idea what I'm talking,about?.
But I don's T have ideas of so ismic stacility.
15 A
16 recogniza it as, seismic shakedowns 17 Q
Okay.
Have you ever heard the expression 8 seismic la 19 shakedown?8 20 A
. Not generally, no.
21 Q
You say 8not generally.8,How about specifically?
I mean, have you heard of it some other way?
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But I have not heard of seismic snafE~down.
4 Q
Is there some phenomenon of which you're aware i
(~
5 with regard to shakedown of sands by seismic actioM
'i J.
6 A
Yes.
i.
-~ t 7
Q rthat's that ca), led?
...i 8
A Vibrat ion-induced ss.ttlement.
9 Q
You've never heard that rete.rred to as saismic 10 shakedown?
41 M,
.Il A
No t as--
I've heard people talk about shakedown, 12 out I don't recall nearing engineers use that term.
4 13 Q
Okay.
Are y[u aware of, any analysis by Consumers Power l
14 15 Company with regard to that, as it relates to.the diesel a
g 16 generator building?
,J
- d 17 A
Based nn tha responses to.some ot our. questions, m
I 18 wh.ere they have analy.ad additional se ttlement because of
-i 19 vibrations f rom an earthquake event. I have heard of it,
,.]
- 1 u
20 yes.
21 Q
What,is your opinion of their analys.is?
-1
- i,
- 4 22 A
I have not rav Lewed tha ir> detail.
It's my C
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Waterways Experiment Station, that that aspect has been 2
1 I
3 addressed.
And what is the conclusion of that addre.ssing of 4
Q
'[
5 that analysis?
6 A
May I ref e r.to the Augus t 4, 1980 report which 7
sumarizes Dr. Hadala's conclusions?
8 Q
Sure.
9 A
Do you have a copy?
10 a
Not in front of me.
.11 (Pause)
I have here the July 7th, 1980 Corps.4eport which 12 was transmitted to Consumers Power Company on August 4th.
13 14 1980.
(Handing document to the witness) 15 C,
Is that wnat you say you need to lock at in order,
16 to tell me wha t. the opinion of Consumers.fower Company's, 17 I call "saismic shakedown analysis" is?
18 what 19 A
You've introduced--
I'm ref erring to this to This is Consumers' idea of saismic 20 indi ca te tha t--
I'm referring to this to indicate Dr. Madala's 21 shakedcwn.
analysis of settlement under vioratory motion such as an 22 C
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- q My que stion was, Were.you aware of an' analysis 3
Md you said that was provided by knsumers in that regard?
4 in detail but that Hadala nad
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5 Ye s, you hadn't studied it some And I asked you if there was, then, o
done work on that.
opinion with regard to that. analysis by Consumers that came 7
Md I thought you said out of dadala having addre ssed it.
6 July 7th Corps that tners was, but you had to ref er to that 9
10 letter.
What I am ref erring to is what,I understand are II A
Dr. Hadala's conclusions on the amount of settisment which 12 could occur because of seismic motion.
13 14 Q
Okay.
My question was w'hether anyone had reviewed, or -
15 analyted the analysis that had b.een provided by Consumers.
to I think it was analyzed independently by I7 A
Dr. Madala, by his making. this analysis.
Id 19 Q
Okay.
Based upon that, can you tell me what his 20 conclusion with regard to Consumers' analysis was?
21 And I think he 1 would like to find it in here.
22 A
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2 (pause 1 3
Ratner tnan was ting the. time. I'll.try and reca.11 what I rememoer Dr. Hadala's sumary said.
4 j (
5 Q
Okay.
That basM on his independent analysis he
,n j
6 A
concluded the magnitude of settlement which had been
-1
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7 i..;
indicated oy Consumers was a reasonable limit for that type 8
f Q 9
of concern.
,1 Was that "a reasonable limit?"
I didn't hear what 10 Q
i
'l.' j li
. Il you said.
Dr. Madala's independent analysis produced a value 12 A
j which was comparable to the results of Consumers Power.
13 The reason it is not readily available in that-1 l
l 14 report is that the Os.troit District took. Dr. Madala's. report 1
.t 15
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C and organized it into that f thal report that you have there.
I6 To your knowledge, did anyone ?,eview Hadala's i
17 Q
~;
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21 I guess I would have to understand what you mean 4'
~ ~4 19 A
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- rev iew."
I think it was generally read and a.ccepted, L)
'. :3 and no addit iona.1 work was done on it.
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22 Q
That's what I meant.
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genera ter buJ.1 ding' is in sec5cdary s
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consol, ida tion.
Taking into account all of. the evidence or 4
data demonstrating that.the soil is in secondary
(
5 consolidation, and weigning th.at against all of the 6
information known to you that you believe casts doubt on 7
whether that soil is in secondary consolidation, do you S
believe it is mora 11kaly than not that. the so.11 is in 9
secondary consolidation?
10 A
I believe Consumers has a tremendous advantage in
.11 be ing aole to conclude it, since you have what we discussed 12 on numerous ocess. ions, and that is the settlement versus 13 time readings which we do not have. Provided that I4 information, mayoe I can gain additional centidence.
15 Bu.t,11ks. the Corps of Engineers who originally asked for tha borings in the diesel generator building, I 16 17
.think 1,t. is good engineering practice, ig recognition of tne la safety of the structure, in recognition of the problems with 19 preloading, in recognition of the irregularities that we
~
20 have in.the foundation,.to go and take the borings, do the 21 laboratory consolidation tests, and use that information in 22 conjunction wi.th the information that you have and make the-
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MR. ZAMARIN4
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i 2 3
please?
And listen carefully to the question.
4 5
(nhereupon the Reporter read the pending 6
question. )
7 THE WITNESS:
The important words are aknown 'to 8
me."
And I'm saying I do. not ':now the settlement history of all.the markers except one with regard to time, and those 9
10 plots we have asked for.
I think based on knowing only up to the time af ter 11 12 surcharge. removal, I cannot make a conclusion.
~
13 You're asi ma to make a judgment basad on 14 information back to that time.
If tha t's the time you.'re 15 pinning me to, then I'm saying I don't know, I don't kno~w 16 whether we're in secondary consolida. tion or not.
17 SY MR. ZAMARIN:
o 18 Q
I'm not asking you whether you knowl I'm asking you, weighing all of the evidence on one hand and all of the 19 20 evidence on the other hand, whether you believe it ts more 21 likely than not - not whether you know, but whether you 22 believe it is more likely than not - that it's in secondary r-
.t e4ce&derd cReynten. One.
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A Is it agreed that I'm we ighing thm evidence as of 3
th2 date of your graph.s of settlement.versus time af ter J
surcharge removal, and not the graphs that yo'u have in your 4
l
(
5 po sse ssion?
I.s that the time frame you're asking me to 1
6 answer?
d' 7
Q Tell me what time frame it is that you can answer
'j
'j 8
it in. I mean, I'm asking you to take into account the data 1
]
9 that is known to you.
So if it is as of a particular date, l
to then tell me what tnat date is.
-d 4
.11 A
The data that I have confidence in the data is r,j af te.r surcharge removal, and not to the present time.
12 13 Q
A11 right.
1 14 A
As of that date I think it is possible that we are t
l 15 in secsndary consolidation.
b' 94 1
16 Q
Do you, think it is cofe likely than not?.
l 17 A
I don't want to speculate.
67
'j 18 Q
I'm not asking you specula te t I'm simply asking.
.i a
19 you.. weighing the data, whether you think it. is more likely
.e 3
20 than not that it's in secondary consolidation?
.I 21 MR. PATON2 Let me encourage the witness to answer
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l M Swe,: "I ipeWulat'ioni cnd..th0n I.thinkrit,really,youldn' pb fair for
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If he tninks it would..be, specula $ cn, then
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3 I would advise him not to sp.sculate.
But it he can give an 4
answer, I would encourag.e him to answer.
(
MR. ZAMARIN:
dell, I assume he's basing it on evidence and data that has eeen something other than 6
7 speculation.
8 MR. PATON:
He may not have enough evidence and 9
data to make even an informed---
10 MR. ZAMARINJ
( Int erpo.s ing L -speculat ion?
11 MR. PATON:
No.
I'm asking him to draw that line.
12 THE WITNESS
- Based on the data that I have seen
~
up to the t'ime right af ter surcharge removal - and there 13 14 we're talking August 1979 - I would have a concern that we 15 are not in secondary consolidation.
16 MR. ZAMARINt A.11 right.'
17
-SY MR. ZAMARIN o
la Q
And what data leads you to believe that?
19 A
We are repeating the same topics.
20 Q
No.
21 A
No t thi. morning, but in past depos itions.
22 Q
If you *.isten to what that question was you'll l
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2 understand that.
3 I'm not asking you what inf ormat. ion you don't havei I'm asking you, based on all the information that you 4
do have, and if you were to weigh that information, whether
(
5 So when you say you 6
you celieve it is mora likely.than not.
7 believe it is more likely that it is in secondary i
consolidation, then you had to have some data on the one i:
d
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hand that you f elt outweighed the other data, as opposed to q
9 10 a lack of data.
M
.I l A
You're correct.
And I..think you're
]
12 misinterpreting my last statement to mean. the lack of data.
13 I'm sayingvwe had the.se same discussions in previous depo.sitions of why I didn't. think we were in secondary
,j 14 15 consol ida. tion.
a
(
Now if I can help yoy reca.lls I talked acout the
- '1 16 17 behavior of the piezcmatric levels f ollow.,ing surcharge w
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removal.
i 7 19 C
All right.
And that's it7 The consideration whether.the f til was dry and
'd 20 A
cracked, and.therefore can I~ ex, sect the behavior that was
,f 21 racorded and presented to us to be typical behavior for 22 l
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3 Q
You say tne two main pieces.
Those are the two?
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4 A
That I can recall right now.
n 5
Q Assuming tha: the s a tti ese nt h is to ry o f. th e ma rk er 3 (
.+j ya 6
that you do have, 00-3, is suestantially similar to the l
- jg 7
settlement history of these other markers which you say is
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d information we have that you don't, what then would be your
?)W 9
opinion as to whethat it's more likely than not that that
$$j 10 soil was in secondary consolidat. ion?
g-fj e.
.1,1 11 A
The key word.s are "suostantially similar."
.And I.
Ci
' of 12
.would say if they are, in my ast imat ion, what I consider to 3
13 be substantially 'similar relative to DG-3, and the lead that
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condition such as sa.turating dones that were not saturated 16
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17 and causing increased se telement, then I would say if those u
b
,h 18 conditions were met, then I would say we were in secondary
.4-j i9 consolidation.
m
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20 Q
Okay.
Y; 21 What if the load were the same but for the v.
R.
22 application of the 1ive load?
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%You would;have to, givo. ca the acqnitudo of the 2
live load to be able to say wnether that's going to ce 3
s ign if icant.
Assume the live load at 2'50 pounds par' square 4
Q
(
5 toot.
6 A
I'm puzzled that it's only 250, based on previous 7
information that you had gifen us where I felt it was a 8
thousand pounds per. square foot.
Assuming it's 250, I don't think that is of a 9
10 magnitude where there would be concern.
.11 Q
By the way, the information that you ref er to 12 accet se ttlement data, Darl Hood has that.
He/s had it for 13 a couple of, weeks.
14 A
What. information?
15 Q
That you keep saying we have that you don't have.
b I think you should be careful whether you think 16 A
17 Darl Hood. has it or whether you submitted, it to the NRC and 18 it has go ttan to Darl Hood.
I don't think Dari Hood has had.
I9 1.5 tar weeks.
20 Q
He gave me a document last n'ight that showed he 21 had it at Isast from the 21s.t of November.
22 A
Netc may have had it since that time, but that C
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4 A
We ll, in def ense of myself-(
5 Q
I'm not saying you.should know that I'm just
~
6, telling you where you can find it.
7 A
May I say some th%ng?
8 I'm also indicating why, at th is t ime, if NRC has had it two weeks, wny I haven't had an opportunity to look 9
10 at it.
You've been out of town, and you've been tied up:
.11 a
12 I know. I's.just telling you wnere to find it.
I 13 A
Fine.
14 Q
In your opinion, is secondary consolidation of the 15 soil under.tha die.sel generator building an a.cceptance r
16 criteria?
2 17 A
Why not let us wait until we respond to your 18 interrogatorias, in detining acceptancs criteria, to answer l
19 that.
20 Q
Because I.'d like an answer now.
21 A
Would you tepeat the question, please?
22 ME. ZAMARIN:
stould you read it back, please?
f(
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3 THE WITNESS:
The impact of the secondary consolidation - and by S impact" I'm talking 'about whatever 4
5 magnitude Lt is and whatever, because of that magnitude, the e
4
(
6
. strasses are that it imposes on the structures - that
- )
in my estimation, would be considered part of 7
- impact, d
8 acceptance criteria.
- q 9
MR. ZAMARIN nould you read that back, please?
_.9 (dhereupon the Reporter read.the record as 10 I,1 11 requ es.ted. )
.:ll G
12 SY MR. ZAMARINJ 21 Ij 13 Q
Is simply don't understand the answer, and I don't y
know whether you told me that being in secondary 14
...e 6.
consolidation is an acceptance criteria.
13 e
- b
(
Acceptance criteriads-Criteria is something
,.j 16, A
f.j 17 which you're requ. iring, and acceptance cr,iteria is having 18 recognizad that it is meeting that standard.
And with k;j regards to secondary consolidation, what we are concerned 2I 19 X
with is a safe structure. And if.the secondary consolidation
..;;h) 20 y
results in stresses that overstrass the structure, then it M91 21
- a.
m')
22 would not be acceptable.
- A
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result in stresses that overstritssed the structure, tha:
4 diat would be acceptable to you?
f 5
A It's possibis, because of the way the structure is 6
built and the way the conduit connections are made, that we 7
could be in primary consolidation, and find that to be 8
acceptacia.
9 Q
Have you ever heard of Willis Walker of the Tulsa 10 D Lstric.t?
.11 A
I have heard of Willis Walker.
12 Q
Are you aware of the work.that he has done on.the
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13 Midland pro. ject?
12" A
It's my understanding Willis Walker was employed 15 by the Detroit District early in the review stage wnen they
(,
were looking for assistance to gd the Midland review 16 17 started.
And that is the awareness of mg knowledge.
18 Q
The extent of your awarene ss? -
19 A
Yes.
20 Q
Are you aware of anything he did with regard to 21 the calculations pertaining to tha surcharge program, the 22 load, or the duration of the load, or anything like that?
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.ed ethint.,I.;, hap given y.ou. in my depos it ion 2
documents work performed by W1.111s dalker for the Detroit 3
District, and they do contain calculations on se.ttlement.
4 Q
Did you review those?
(
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A I did not review those.
6 Q
Oo you know if anybody reviewed them?
7 A
It's my understanding they were, reviewed by the S
De troit District.
To your knowledge, has anyone disagreed with, or 9
Q 1Q criticized Willis Walksr's calculations?
I 11 A
In one conversation I had with Hari Singh it was 12 indicated that he felt some of the asstmptions used my f
4 13 Willis Walker were of such a general nature that he d.id not 14 have confidencs in the results.
15 Q
Do you know what those assumptions were?
'C 16 A
I did not have a detail.ed discussion.
17 Q
Has Willis Walker's. work, then,, been re.lected?
18 A
It's my understanding W1.111s Walker's work has
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I 19 been incorporated into.the Corps' efforts.
2Q Q
To your knowledge, has the NRC made a final 21 decision as to whether any portion of the operating cooling 22 pond dike is a Category I. structure?
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Has a tentative 4
cecision been made?
I was responding to your " final decision."
- 5 A
o Q
Has a tentative decision been made?
I do not know of any decision other than the 7
A 8
reflection by the requested borings.
9 Q
In other words, if they asked for the borings,
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then that would at least imply that it was considered to be 10 11 a safaty related structurei is that what ycu mean by that, oi by - quote - reflection of the borings?
12
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there is - tnat at least one portion has already been 14 15 established as being of importance enough to say that it
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16 meets Category 1 requirements."
.4 17 Q
Har the Corps completed a draf.t SER7 I
id A
To my knowled;;e, no.
IV Q
Are they working on one?
20 A
Ihey ars helping to prepare testimony for the show cause orde'r, which, by its nature, wi.11 serve as part of the 21 22 SER input as we.11.
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Q. t Whnt. individunis 1,n, tuo,Corpo cra help ing prepore 2
testimony for the show causa order?
3 A
I'm not sure of everyone.
I know I have
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f 5
Q And 1.s there anyone else?
6 A
There may be others assisting in that.
Mr. 51ngn 7
would know that.
8 Q
Are there any other projects that the Corps is working on with regard to Midland besides the soils 9
to settlement?
11 A
I.think you have a copy of our contract with the 12 Cor;2s.
13 a
Na only have a part of it.
14 A
dell I know we've had previous discussions in my It does not just address tha plan.t filh.
15 depos ition which--
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se ttlement problemi, but it has asfed them td do the review 17 through the CI. stage.
I8, MR. ZAMARIN:
0 ff the re cord.
19 (Whereupon there was a short discussion hsld off the record, 20 attar which the deposition was 21 22 again continued.)
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3 Q
Can you tell me how compre ssion index could be 4
used to predict settlecent witn regard to the diesel b
5 generator building?
6 Md. PATON:
Mr. Kane, I instruct you to not artswer 7
any more questions.
8 MR.. ZAMARINJ You'd be tter say why, because I'm 9
not finished with his deposition.
10 MR. PATON:
For the reasons indicated at the
.11 beginning of the deposition.
12 MR. ZAMARIN:
Secause you're simply terminaeing 13 the deposition although. we're not finisheds is that carrect?
14 Md. PATON:
I stated my reasons, Mr. Zamarin.
MR. ZAMARIN:
I.s that why7...I mean, there's 15 14 notning cojectionable aoout the question?
17 MR. PATON:
I stated my reasons, at the beginning.
18 I said at the and of an hour we would terminate the 19 depesi tion.
20 MR. ZAMARIN:
Okay.
21 BY MR. ZAMARIN8 22 0
I sti.11 have more questions.
Do you refuse to
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. answer any, nors. questiens, Mr. Kan07.
2 MR. PATON:
I instruct Mr. Xane not to answer any 3
acre questions of any kinc.
MR. ZAMARIN:
You even instruct him not to tell 4
as whether he refuses to answer any more questions 7
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MR. PATON*
I'm instructing Mr. Kane not to And I don't think any further interrogation of 7
answ er.
d Mr. Kane i= nece ssary.
9 5Y MR. ZAMARIN8 Do you refuse to answer any. sore questions?
10 0
.Il MR..PATON8 Mr. Xane, I instruct you not to answer any questions of counset for the applicant, of any
, 12 13 kind.
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14 SY MR. ZAMARIN:
15 Q
Do you refuse to answer any que.stions?
?
le MR. PATON:
That's the, third time.
I think that 17 that's enougn.
le MR. ZAMARIN:
I request that the witness remain 19 and continue to answer quest' ions.
I'm not finished witn his deposition,' and.there's more informa tion that we're entitled 20 il to get f rom him, and I want i t now.
22 MW. PATON:
Okay, that's it.
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MR. PATON:
No response is necessary.
4 Md. ZAMARIN:
The record should note tne f
5 depos.ition is not completed.
' 6 (rthereupon, at 9:45 a.m., the deposition was 7
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CERTIFICATE OF NOTAdY PUBLIC AND REPORTER 3
t I, William R. Bloom, the -o.ff icer before wnom the
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5 foregoing deposition was taken, do nereoy certify that the 6
witness whose testimony appears in the foregoing deposition 7
had been previously duly swornt that the testimony of said 8
witness was taken by me by Stenomask and thereaf ter reduced 9
to typewriting by me t that said deposition i.s a true record 10
.cf.the testimony given my said witness t that I am neither
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.11 counsel for, related to, nor employed by any of the parties 1
to the action in which this deposition was takens and, 13 furthe r,. th,a t I am not a relative or employee of any 14 attorney or counsel employed by the parties hereto, nor 15 financially or otherwisa interested in the outcome of the b
16 ac tion.
A 17 18 r
19 Notary Public in and for 20 the District of Columbia 21 22 My commission expires 14 August 1985 e
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