ML19345E550
| ML19345E550 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/14/1981 |
| From: | Davisson M BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8102050123 | |
| Download: ML19345E550 (149) | |
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NCCLZAR hwdTORT COM!CSSION
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c CONSUMERS PCWER COMPANY : DCCKET NOS. 50-329 CM ,
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January 14, 1981 73g7,gt 1-W
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UNITED STATES OF AMERICA !
2I NUCLEAR REGULATORY COMMISSION 1
3 ___ _ ____ _ __ _ _ _
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In the Matter of:
1 o 5 l CONSUMERS POWER COMPANY : Docket Nos. 50-329 OM & OL i'
- 50-330 GM & CL j 6 (Midland Plant, Units 1 & 2 :
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_ _ _ _ _______ _ _ _ _h e
i 8 I a Savoy, Illinois
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~. Wednesday, January 14, 1931 u 10 z
Deposition of M. T. DAVISSON, a witness herein, !
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!3 II ; called for examination by Counsel for the Nuclear 12 i Regulatory Commission in the above-entitled action, '
4 13 j
pursuant to notice, the witness being duly-sworn by m J 5 I4 PATSY ANN STROH, a Notary Public in and for the state of ;
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Illinois,, at the offices of M. T. Davisson, 4 College <
t g 16 Park Court, Ssvoy, Illinois, commencing at 9:00 a.m., l a -
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- 17 3 January 14, 1981, and the proceedings being taken down I' t i 18 3 in stenotype by PATSY ANN STROH and transcribed under i
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her direction. l
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ALDERSON REPORTING COMPANY,INC. ;
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I I APPEARANCES:
2' On behalf of the NRC: f 3 WILLIAM D. PATON, Esq.
U. S. Nuclear Regulatory Commission 4 Washington, D. C. 20555 g
n 5] 1 On behalf of the A=elicant:
n 0j JOANNE GAIAREK SLOOM, Esq.
2 E Isham, Lincoln & Beale l 6 7 One First National Plaza ;
3 Chicago, Illinois 60603 l n
5 8 ,
d Also Present:
z MR. DINESH GU?TA, NRC-DE-HG"' i
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!8 II MR. HARI N. SINGH, U. S. Army Corps of ;
i Engineers, Detroit, Michigan 12 z
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25 i I ALDERSON REPORTING COMPANY. INC. :
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2 NUMBER DESCRI? TION IDENTI?!ED 3 i Professional qualifications of 4 M. T. Davisson dated July, 1990. 4 i l
I g 5 2 Figure 62 of Interim Report 5 of H
j 6 MCAR 24, crack mapping. 70 R
5 7 3 Letter dated 3/25/30 from S.
i 5 8 Afifi to M. T. Davisson. 73 !
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9 4 Memo from M. T. Davisson to !
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C 10 l 5 S. S. Afifi dated 3/29/30. 74 .
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II 5 Consultants request for answers, ll.
i j 12 handwritten portion dated
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t j 13 June 28, 1979. 81
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3 14
? 6 Technical Specification for fur-0 15 h nishing, installing, and testing closed l
= 1 g 16 end pipe piles, with handwritten note s
a g7 96 d from P. K. Chen, dated 12/8/30.
_ 7 Letter from M. T. Davisson to S. S.
2 19 Afifi dated 4/15/80. 119
. 20 8 Drawing by M. T. Davisson dated.
2I 126 1/14/81. ,
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i ALDERSON REPORTING COMPANY. INC. '
i i 3 I P RO C EE D I N G S !
2 Nhereupon, !
3* M. T. DAVISSON 4 a witness herein, called for examination by Counsel for e, 5 the Nuclear Regulatory Conmission, having been first N l j 6 duly sworn by the Notary Public, was examined and !
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$ 7 testified as follows.
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k 8 EXAMINATION SY COUNSEL FOR NRC I Y
- 9 3Y MR. PATON: '
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@ 10 ' G Dr. Davisson, would you state your full name
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i h 11 and business address for the record, plea'se?
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I I2 ' A M. T. Davisson, 14 Lake Park Road, Champaign, ji= 13 Illinois 61820.
x 5 14 % Okay, 14 Lake Park Road is your residence? l C
i f 15 A Yes.
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j g' 16 4 What is your business address? l d 17 A 2217 Civil Engineering Bu'ilding, University a
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3 I8 of Illinois, Urbana, Illinois 61801. -
1 19 That's not the address of the building we are !
G I n
20 in now -- this is 4 College Park Court, is that correct, 21 sir? ,
i i ~~ A That is correct. '
I 23j G Do yet- have - a copy of your professional: -j 1
- 24 ) qualifications?
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25 , MS. BLOOM: I do.
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ALDERSON REPORTING COMPANY, INC. i
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1 THE WITNESS: It might be on my desk.
2 MS. 3 LOOM: Here you are.
3i MR. PATON: Thanks.
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4 MS. 3LCCM: Let the record show that he is 5 giving a copy --
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g 6 MR. PAToN: I am going to mark as Deposition
- l i 7 Exhibit No. 1, M. T. Davisson, and today's date which is ;
A 3 1/14/31,a copy of a document that I have just been handed
-L 9 which is entitled " July, 1930, M. T. Davisson, Consulting
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g 10 Engineer," consisting of two nu=bered pages, with three l
)3 11 pages of publientions attached.
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(The document referred to was i
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s 13 marked Davisson Deposition !
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I 5 14 Exhibit No. 1 for identifi-
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E 15 cation.)
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j 16 3Y MR. PATON: (Resuming) ;
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@ 1:7 4 Dr. Davissen, are you a registered structural u
I 5 18 engineer? l
$ 19 ' A Yes, in the state of Illinois. ;
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20 4 Do you know Professor Ralph 3. Peck?
21 1 Yes.
Ia 22 i G How long have you known him?
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x Twenty-seven years.
24f 4 When did you complete your PHD work?
25 i 1 1960.
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I Did you write a dissertation? l G
2 A Yes.
3 Do you remember the title?
G 4 A The precise title I do not remember.
I e 5 MS. BLOOM: Off the record.
.4 J e g 6 (Discussion off the record) ;
I 6 7 i MS. BLOOM: Back on the record. j
! 8 SY MR. PATON: (Resuming) c 9 G What was the subject of your dissertation? .
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g 10 A Suckline of oiles.
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@ II ! G Do you recall who your advisor was for tha* t 3
12 thesis? I 2
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- i 13 A Dr. Ralph Peck. .
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5 I4 G Did Dr. Peck teach any courses that you too< l
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I'0 A Yes.
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l N I7 G Do vou recall what these courses were? !
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E 18 A Yes, earth dams, advanced soil mechanics, --
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l s I9 a that may have been all that I took from Dr. Peck.
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t-20 % Have you worked on projects other than Midland i 2I with Dr. Peck? I 22 A Yes.
1 23 j Q. Can you tell me what.those were? Can you i :
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24 I itemi:e those, and if there have been so many that it's :
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25 difficult to itemi:e, just tell me some. i i '
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6 1 A Yes, it's been a fair number of projects, ana i
2 : doubt if I could reme=ber them all, i
3; ? Fine, tell =e the las: three er four that you 4
1 4 jhave worked on.
g 5 A Certainly the pile supported runway extensions n ,
g 6 at La Guardia Airport in New York City; several cre decks n
$ 7 in Cleveland; earth dam in Costa Rica: Marina Towers >
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! 3 in Chicago; McCormack Place original in Chicago, and as le c
2 9 an explanation, that's distinguished fr:s McCormack ::
z, y 10 tha: was buil: after the fire; nu=ercus instances of !
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{3 Il projects that were just handed to ae to do, as opposed i 1
y 12 te working directly with Dr. Peck. ,
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13 4 How many years have you been associated wich
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n 5 14 him in working on projects? l
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- 15 A First association was approximately 1956. -
= t g 16 4 okay, and your estimony is that there have i a t 17 been se many that it would be difficult for vou presently N.
f 18 cc recall all of them?
3
- 19 A That's correct.
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20 ' 4 Okay, when did you -- excuse me just a second. ,
21 When did you begin your empicyment at the 3
22 i University of Illinois?
4 l 23 ' ,
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24 i ; What was your first title? -
25 1 Research Assistant.
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1} ? Okay, what was your nex- i
'e after Research l 2 Assistant? ,
3>4 A I'= not sure that I recall. It may have been
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4 ! s i m o. l v. Assistant, but them was a stage where the title g
5 was i.is t ruc to r .
s g 4 Do you recall approximately what year that vas?
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$ 7 A 1959. !
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.!, 3 4 Okay, when --
-J 2 9 A Perhaps in part of 1960.
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- i y 10 ? All right, sir, when did you -- what was your ;
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11 next?
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'd 12 A- Assistant Professor.
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13 4 When was that?
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2 5 14 A 1960. l
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15 g After tha-' i 1
j 16 A Associate Professor, 1963. .
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d 17 4 All right. I
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- 18 A Professor, 1971.
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- 19 4 Is that y'ur present title -- Professer?
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20 A Yes, that is correct. l 21 G Are you now in the Department cf Civil ,
1 22 ] gneineering7 l, -
23l A Yes.
24! % Did you star: -- what department did ycc -
25 ' start in'in 1957 ---I'm going to strike that questica 1 ALDERSON REPORTING COMPANY. lNC. :
3 I and ask you a different question.
2 When did you first begin work in the Department -
3 of Civil Engineering?
4 A 1956.
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? Have you worked in that department centinucusly n
2 0 ]i since that time? ,
i 4' e 4' 7 A Yes.
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? Ckay, who is the chairman of the Department u
9 ci Civil Engineering now?
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2 10 Currentiv- John Liebman, L-i-e-b-m-a-n. l A
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!a II 4 Do you know who preceeded him? ,
i 12 A Chester Siess, S-i-e-s-s.
i y 13 4 When did -- is it Dr. Siess?
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i 3 14 2a A Yes. ,
15 G When did Dr. Siess terminate his employment l
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g 16 as chairman of that department?
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l7 A 1973 a o. n. r o x i m a t e l'I .
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5 18 Approximately what year
. _ -G When did he start? ,
19 i did he start?
5 20 A 1973 approximately. ,
21 G Who preceeded Dr. Siess as chairman of the 1
22 ! Department of Civil Engineering?
I' 23 ; A Nathan Newmark.
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- Dr. Peck was at one time in the Departm nt
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3 25 cf Civil Engineering, is that correct?
t, 1 ALDERSON REPORTING COMPANY. INC.
9 1 A That is correct.
2 4 Do you know what year he departed?
3} A (No response) 4 % App cximately?
e 5 A From the range of 1950 --
pardon me -- 1975
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g 6 to 1973. I can't recall any closer.
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$ 7 % Okay. Have you ever discussed your work on l M
! 8 the Midland project with Dr. Siess? !
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2 9 1 No, not that I can recall.
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z 10 g Do you now, let's say in the year 1931, do you l
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]a 11 ' see Dr. Siess from time to time to talk to? I f_
12 x aarely, g 13 % Is it correct that you have been retained by l
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n j 14 the Bechtel Corporation as a consultant on the Midland j 15 projec-o t i, j 16l A Yes. l x !
17 4 Okay, when were you retained? !
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E 18 A Soring of 1979. !.
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g 19 4 Do you recall who first contacted you? !
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20 1 Dr. Afifi.
21 % Can you tell.me what you were retained to do?
4 22} A Look at the possibilities of support for the i,
23 l service water pump structure.
I 24 I 4 q Do you have a written agreement with them?
25 i A Yes, it's-a general consulting contract.
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1 4 When did -- strike that question. t i
i 2 Is there any indication in the agreement as 3 to when it terminates?
4 A Yes, it's a yearly.
3 5 G It's a year to year contract?
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j 6 A That's correct.
R i 7 G Dr. Davisson, I want to get back to what you n
$ 8 were retained to do, and you indicated possibilities --
a 2 9 consider possibilities of support for" the service water
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3 II A Yes. '
3 f-12 7 Did they give you any instructions on what you ;
j 13 eere to consider when you consider these possibilities? l
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x 5 14 MS. BLOOM: I just want to know who they is? ,
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2 l 2 15 MR. PATON: 3echtel. ;
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i g 16 BY MR. PATON: (Resuming) l
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17 ? Did Bechtel give you any instructions that you j t
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o 18 were to follow -- NRC regulations or anything like that? ;
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s 19 What did they tell you other than to consider-possibilities 2, n
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20 A Nothing. j 4
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, 4 That's it?
4 22 i
. A Yes.
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l 23l @ Had you prior to that time done any work r i ,
l 24j similar to what they were asking you to do on a nuclear l
25 f power plant?
1 I ALDERSON REPORTING COMPANY. INC. i
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1 A No. l
. I 2 ? Did they anywhere along the line give you any !i 3I instructions or advice or whatever on NRC requirements?
i 4 A No.
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5 G Are vou aware of any NRC requirements with N
j 6 respect to the service water structure? ,
" t i 7 MS. 3 LOOM: I am going to object. Can you j
! 8 clarify what you mean by NRC requirements? !
d O 9 MR. PATON: Sure.
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@ 10 BY MR. PATON: (Resuming) :
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3 11 % For example, is it a Category I structure? ,
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12 ' A Yes. ;
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- I 13 4 What does that mean? l 5 l 5 14 A All sorts of things, desirable and undesirable, .
j 15 that this is a structure that is nuclear safety related. i e
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j 16 That's the best general description I can put on it. I a
17 Okay.
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! t l, a 18 1 This means that it must function for the j e
a 19 doomsday requirements that are placed upon it which i n :
20 art part of the design requirements for the plant site.
l 21 % You said " doomsday"?
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, 22 l A Yes.
f 23f G What do you mean by that?
,4
' ; A The earthquake, tornado. >
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l 25 , 4 okay, you say -- I'm sorry, go ahead.
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12 I A And effects that might come about because of the 2' earthquake or tornado are thrown in along with the 3 normal design requirements for the structure.
4 0 You say the earthquake --
are you talking I
g 5jabout any particular eqrthquake?
H j 6 A With respect to Midland, it's a little difficult 7.O i E 7 to imagine, but one has been generated for it.
! 8 G Why did you say with respect to Midland it's S 9
~. difficult to imagine?
z t" 10 A It's not earthquake country.
E 5 II G Oiay, are you aware of any current discussions a
i 12 ' going on between the staff and Bechtel with respect --
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11 and Consumers -- with respect to what's the appropriate ,
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n I4 earthquake to consider in this case? f,
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g 15 1 I have no direct knowledge et the discussions.
g 16 I have heard rumors
- i II G Okay. Now -- I conclude fens your testimony i k:
5 I8 that you are aware of NRC requirements, at least to the ;
N 2 19 extent that you have just testified to. Where did you
- a 20 ' acquire that knowledge, or how did you acquire that f i
1 2I knowledge? l l
22 , .
A By osmosis. Some of my colleagues have been l I 23j involved with nuclear plants for a long time, and more i
2# l specifically and more directly with respect to Saitly. i f 25[ G Are you a consultant to the NRC on the Sailly; 4
1 ALDERSON REPORTING COMPANY. INC. .'
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1 i 13 1
I Icase?
2 A. Yes.
.I 3l ; ; want to stay with =y questions about instruc-1 4 ltions that you go~ from 3echtel. Did they ever instruct i
e 5 lou, or did they ever advise you at any time concerning N
!,y g 6 NRC requirements?
R i 7 A No. ,.
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$ 8 MS. 3 LOOM: Can we go off the record?
J 2 9 (Discussion off the record)
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@ 10 , MS. SLOOM: When you say NRC requirements, in
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h II ; effect he is thinking did they tell you these are NRC 3
I 12 . requirements, and I think you may be asking a broader
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j question, and I am not sure -- were you given certain
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2 1 5 I'd specifications or certain details to follow without any M '
.; 15 headliners. I think it's unclear.
= 1 10 3Y MR. PATON: (Resuming)
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$ 17 Okav, whether vou call them NRC recuirements !
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= t E 18 or not, did ther give you any other instructions or
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r 19 "a constraints or limitations on the design? !
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' A Specifically, no, but it'was kind of common j 2I ' knowledge that we were looking at the earthquake and the 11lccher things that go along with Category I structures, and 23}I don't think we have a specific discussion on this. ,
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24 ! ? Okay, maybe the short answer to that is that 25 ' you are the expert and that's why they retained you?
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I I A Let's hope so. l 2 4 Okay. Has there been any change in the scope i 3 lof work that Bechtel requested you to do since they first 4 retained you?
s 5 1 Yes.
A
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2 6 4 What was that change?
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" 7 1 Mr. Gould, Charles Gould, who was primarily ;
% t 3 concerned with the underpinning from the auxiliary 2 9 structure has changed empicyment as of August or September
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10 ' of 1930, and because of his new employer, he apparently l
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II cannot function further for Sechtel, and I have been asked ;
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12 to share that responsibility with others that Bechtel's ;
E-I lx 13 project management have engaged.
5 14 Before you were retained in the spring of 1979 f G
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3 15 did you attend any me: sting with Bechtel or Consumers l' z ,
j 16 or the NRC concerning Midland? l
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M 1 No. l w I y: 18 MS. BLOOM: Can we go off the record for a 8
E I9 second?
n 20 (Discussion off the record) [
i 2I MS. BLOOM: Back on the reccrd. l i
22 l 3Y MR. PATON: (Resuming) i 23 I
i G What was your involvement in the Midland soil .
og i settlement problem before December 1979?
2 !
25 i MS. BLOOM: There has been no showing that he r
I i i ALCERSON REPORTING COMPANY. INC.
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I i had involve =ent with the scil settlement. He testified 1 -
2j he was invcived with doing support.
J 3 MR. PATCN: Ckay, I an ecuating the two, and l
4 j! think all the witnesses have, but it's all right.
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5i 3Y MR. PATON: (Resuminc) n n a 6" 3 Ycu indicated you were retained in the spring N I-
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" 7 of 1979 with respect to the service water s ucture a: ,
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A That is correct.
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% Tell us what vcur activities were for the :
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II 3 re=aining part of 1979.
5 12 1 A:: ended a meeting at Midland in the spring g
13 of 1979, viewed the structure, and in fact : viewed all i g
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.- 14 c., .w... e s..
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j 15 i The meetin~v concerned all of the areas tha:
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j 16 were under investiga:ica at the time, and se it was not ',
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k specifically service water pump structure, and locked .
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18
$_ at the aux building also, and I did that in conjuncticn --
19 i MS. 3LCOM: Off the record.
a 1 20 ' (Discussien off the record) 2I THE *d!TNESS: The attendees at the =eeting I i
1 22 j recall being Mr. Gould, Dr. Afifi.
1 They were cuite i
23 vague abcut how many other meetings might have taken 24
- place, but de knew there were =ee:ings where the[
'5 described specifically :ypes of fixes that sight be ALCERSON REPORTING COMPANY. INC.
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considered for the service water pump structure.
2 3Y MR. PATON: (Resuming) t 31 ? Okay. New, my cuestion was :c tell me ycur 4 activities for :he remaining part cf 1979. Have you g 5 finished ycur answer?
a 2 6 A To the best of my recollection.
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l 7 All right, let me ask you this: How much !
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! 3 total time did you spend with respect ec your censulting a
9 Sechtel on this service water structure in the year 1979?
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'e 10 A Perha s ten davs.
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II Ten full days?
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12 ' A Yes. ,
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13 o k a v. , v.ou indicated v.eu attended a meeting. l 5 %
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- 14 Did that take --
let's say a day? .i
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.N A Yes. 7
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A 4 O k av. . What did v.eu do the other nine dav.s? 1 a
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- 7 A I as sure that I attended several other meetings;1' t
I8 3 With 3echtel do you think?
3
_- i 19 "a A With Bechtel, and information was being senerated n
, 20 at that time on soil conditions, because a boring 2I program was going on, and some labora: cry testing ! ,
j 22 ! believe was taking place, and a definition of the infor-l 23 marion was in-process, and that information was being
,4i sent on to me and I reviewed it as it came in.
25 q At any time during the year 1979 did ycu ,
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1 think that you had enough information to begin determining !
2 which alternative would be selected?
4 3{ A I think several could have been used.
4 4 Did you ultimately -- you ultimately arrived g 5 at the conclusion that you would use piles and you would
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2 6 use a corbel -- that's the alternative I am referring to. ,
R i 7 When did you -- did there come a time when .
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$ 8 you finally decided that would be the alternative you i d_
9 would use?
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. 10 A I did not decide which alternative.
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{ II , G Who did?
y 12 A I have to make an assumption that it was the ;
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f= 13 project, and that presumably would be that portion x
I4 that's concerned with structural design. l
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15 g You are referring to 3echtel?
i g 16 A That's affirmative. j a
p 17 % okay, did you concur in the conclusion?
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18 A Everything I had suggested to them was a workablej 19 scheme.
2 n .t 20 ' q You made a suggestion and ultimately you 21 learned that they arrived at the same conclusion where ;
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In 22 j they agreed with you or whatever, but they came to that 23 } same conclusion that you did, is that correct?
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A Apparently.
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f 25 i 4 When did you make your suggestion? .
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ALDERSON REPORTING COMPANY. INC. i
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i I! A (No response) 2 4 Months is close enough.
I 3' A 5pring of 1979. I am sure tha: the ideas and 4
4
- i. concents were there and erobably refined during 1979. ,
t c 5i ? Ecw soon after vou were retained did you make N
g 6 the suggestion that was ultimately accepted?
b 7 A I don't think I could nail that down c.reciselv. - .i i
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i 3 s someti=e during 1979.
u 9 okay. You just testified, though, the spring z.
4 10 and I note that's when you were retained. So, !
E of '79, 4 II it seems like it was fairly soon. ;
a 12 A Right. j i .,
Within a month or so -- it seems like it was
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- 6 2 14 fairly soon? ;
r IS A Right. ,
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g 16 4 Within a month or two after you were retained? 4 A s
" 17 H A I would think so, yes, ,
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n I8 In the year 1980 how much l l
4 okay, that was 1979.
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19 time did you spend on this project? ,
20 A Again, approximately ten days. j 21 And the year 1981 how =uch time have you G ,
22 1 spent en the project?
t 23 Yesterday and today.
1 1 i
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I 4 okay. Ecw many site visits did you maka to 5 Midia.4d.in each of those three years, starting in 1979?
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.I ALCERSON REPCRTING COMPANY. INC.
i 19 i
l 1 A At least one in 1979, at least one in 1930, i
2 and -- probably two in 1990. I think I was involved with 1
3 la hearing.
1 4 7 okay, I heard you say one in 1990, and then s 5 two in 1930?
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n j 8 A Nothing.
e f 2 9 Nothing, okay.
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- i y 10 We have described a scheme, if you will a70ept l E
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11 that word, I am just talking generally, of use of piles .
12 of corbel on the service water structure?
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n j I4 4 Was that your number one choice? !
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15 A No, that was probably my second suggestion. t I
y 16 0 What was your first choice? l
- I y 17 A Check the building out and see if you have to j t
1 4
5 18 do anything at all and consider structural bracing within
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19 the buildings so that it could function as a cantilever.
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20 ' % Did you -- who eliminated that possibility? l 21 Was that you or was that Sechtel? 3 J
22 i A That would have to be 3echtel's project team.
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23{ 3 Can you state just as a general statement 4 24j I would assume that the remedy that you have described 25 as your number one choice would probably be less costly I
- ALDERSON REPORTING COMPANY. INC.
- 1 .
1 20 t
I in dollars than the remedy they are pursuing? ,
2 A Certainly. i 3li ; Do you receive copies of the responses to 4 50.54 (f) questions asked by t 2 NRC7 It's well known, g 5 Are you familiar with that
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least to these fellows.
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j 6 expression?
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i 5 7 A Perhaps. j t
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"! ? Do you receive from Bechtel in your professional J
9 al? the information that you believe you need judgemen >
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!3 II A Yes. >
12 Have you ever asked them for additional 5 4 ,
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j 16 do you know what it says with respect to what f 3echtel --
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I8 3 A No, it's quite a general. agreement that does f, 6
i 19 not pertain specifically to Midland. ,
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20 Okay.
0 l-21 I am a consultant to Bechtel on several proj ects.;
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- 22) G For how many years have you been a consultant i
23 ^ :o 3echtel?
1
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24 i 1 Probably three years.
1 25 ' 4 Is_there a written description anywhere that i
i 4
ALDERSCN REPORTING COMPANY. INC. l r
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. 4
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f I !you are aware of,cf what it is v.cu are supc.osed to de 4
2 with resc.ect c this case -- the service water structure?
3; A : do not recall one.
I 48 G : don't want to ask you about dellars, but :
i e 5i jus: vant to pose ene question, and tha: is are you 4
2 6
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! 8 G Per day, Okay.
J 9 Dces 3echtel retain Oc your knowledge any z.
g 10 other consultants with respect ec the underpinning of l, m 1
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5 the service water structure?
a 12 A :'s my understanding sna: project is respcn-i E 13 sible for retaining a fir = cf Mueser-Rutledge-Johnsten I.
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2 14 and Desimene. I n
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5 15 G Ecw did their response differ f cm yours, if l
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5 18 a r e addressine the remedy at the service ;
. - G T h e v., -
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4 } water structure? ;
' 20 1 Yes. !
a 2I G Do you ow where that firm is located?
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22 I 1 New Ycrk C' y.
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, G Have you eter talked :c any of the gentlemen
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1 ALCERSON REPCRTING COMP ANY. INC.
- 4 4
22 b
I From those conversations you are not able to G ,
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3 lthan yours?
4 A I have not had that kind of conversation with e 5
- them. I shook hands with them, passed the time of day.
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o 6 4
The two occasions that I have met ceople from that firm
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R 7 were such that we did not have time to discuss any of i 4 8 5 these details.
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- 9 z- 7 Has anv.ene at that firm to .vour knowledge
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selected by Bechtel?
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A I am unaware of it. '
- 13 '
y 4 Okay, has anyone to ycur knowledge at Consumers a i
= 14 or Bechtel expressed any disagreement with any aspect '
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service water structure' I
F 1:7 d A I am unaware of it.
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19 -
E other writings to Bechtel or Midland with respect to the n 1 20 .
service water structure?
21 ' No formal report on the recommendations. I A
1 22 ) function generally as a consultant to the geotechnical 23 1 group, which are in turn -- function as consultants i
24 ii to the project at the project's discretion.
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l G !s your main contact there Dr. Afifi?
I ALDERSON REPCRTING COMPANY, INC. ;
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1 A Affirmative.
G You have been retained for about a year --
3 almost two years -- and at no time during that time have 4
you given Dr. Afifi any written report or results of a 5 3 v.our consultanev.?
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- A No, there has been review of things.
n R 7 l
- we are dealing with advice which the geotech group :
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incoro. crates and e.robablv. passes on in memos ad minutes w
- 9 g of meetings to the project.
c 10 g 4 Okay.
I 11 j A I have not been asked to do a design report i 12 '
5 as such. That would ordinarily be done by the geotechnical i
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i group if one was required.
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d G Would you say that the situation I have 9 us i described where you have been retained for a year, or !
l j I6 almost two years, -- where you haven't given them a i d 17
- 2 written report, is that unusual? 1
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j G You said a minute ago something like you j i
20 i were not retained to do design work -- that's not 21 exactly what you said, but you said something like that.
l 22 l j My question is what exactly are you retained l 23 ,
t to do -- advise Dr. Afifi as the project goes along l
or what? You were not retained to design, is that" ,
25 i
' correct?
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! ALDERSON REPORTING COMPANY, INC.
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24 1 A (No response) 2 S To design a remedy? i i
8 3j A That is correct, I do not do the detail of a
4 tthe remedy in its totality.
c 5 7 Try to tell me -- since you don't do the N
g 6 detail design, what do you do? ,
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$ 7 A In this instance I recommended several possible f
! 8 approaches to the problem. The project, I presume, has 2
9 gone through these approaches and determined their i z.
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@ 10 feasibility or lack thereof, and have arrived at which z ,
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" l 5 I4 or one or more people, go to work on it for a while; 4 w
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15 then there is further interaction, and that process has 3 .
g 16 gone on for some time, and it appears like the driven j a
N I7 pile underpinning approach and the services that I am a
3 5 18 cerforming with resc.ect to that ac.c. roach with regard to ,.
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19 the selection of the pile driving equipment, and the s
n 20 ' testing, and the locking-off procedures,-and other items f 21 of construction techniques, but not the structural 22 1 details of how that pile is connected into the structure --
i 23 ? Does somebody else have that responsibility --
24 ] the structural?
l 25 .t That's 3echtel project. ,
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! ALDERSON REPORTING COMPANY. INC. ;
3 3 '
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I ' Might you advise them in that regard after G
2 they, for example, make a design or make a proposal in l 3 '.that regard?
I 4 A Caly insofar as it would interact with g 5 jacking in the load from the piles and locking it off n
6 2
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i 3 A from the piles. These piles are going to be driven, t 4
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3 II 2 I don't understand the use of the word i i
12 jacking. I thought jacking and driving were two different ;
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14 4 The piles will be oreloaded before fastening l
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16 withdrawn, the piles will be carrying the load. l 3 o a i
" i 17 q How frequently -
-he year 1990 did you ;
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communicate with Dr. Afifi?
i 19 A Probably around once or - twice per month.
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21 !
A Yes.
I 22 l @ Did you meet with him, or was this mostly.
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i by telephone?
24 4 Both.
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i A I 25 4 Do you know why 3echtel did not agree with i ALCERSON REPORTING COMPANY. INC. -
26 I
your first suggestion of bracing the structure?
2 A I can't recall that I have a direct communication.
3 I have the presumption that checking it out they found 4
scoe :4 tre s s e s excessive. ,
g 5 g You don't recall any conversations ycu had n
i j 6 with anybody about that?
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i 5 8 g How soon after you were retained in the spring d
9 of 1979 did you make a site visit?
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10 I think thev. were probablv. concurrent.
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II G Okay. When you were retained did you go to ,!
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- A No, Midland. 9 n t You met Sechtel at Midland?
14 4
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15 t A Affirmative.
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% Did you talk to Dr. Afifi that day? !
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19 days? How long were you up there at that time? ,
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21
% Have you got any way to determine -- excuse ;
22 1 me -- co ahead.
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! A I believe Afifi was at that meeting.
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- or may not have been. i 25 g Do you have any way of determining hcw soon
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ALDERSON REPORTING COMPANY. INC. i
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I lafter that visit you made your first recommendation to 2 3echtel?
I 3 A Not easily.
4 G For example, was this first recommendation s
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g 6 j, A I don't believe it was, no.
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! 8 or did you just call him up on the phone?
a 9 1 It's quite possible that the first recommen .
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u dations were made at that first visit to Midland. The-a z -
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12 to a firm recommendation.
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13 Would you agree with the statement that 5
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5 I4 even if that first meeting would have been two days j t
2 15 long, it would have been impossible for v.ou to make a a
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18 A No, I thought the problem was relatively simple ,'
19 at least the part that I was looking at.
i g -- ,
i 20 Did you know at that time the nature of the l:
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i 21 )J ;117 22 l A Yes, the underlying till was fairly well i
1 23 l investigated fcr the plant site in general.
E 24 i 4 And you had that information during that one 25 or two day first visit?-
k, ALCERSON REDCRTING COMPANY. INC. ,
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I A Yes. )i i
2 g You knew the nature of the till? i 3 A Yes.
4 4 That would have been one of your important i
e 5 considerations, I assume, wouldn't .:7 s
j 6 A ch, yes.
R 7 C When you visited the building -- you did visit
! 8 the building on that occasion? l 3 9
. A Definitely.
2 O
i 10 Was it cracked?
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3 h II A I do not recall observing cracks.
3 i
12 ' S Do you recall observing cracks since that ti=e? j
= t 2 l 5 13 A No, I would say it would be highly unusual i
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I4 to look at any concrete enforcement structure and not s
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15 see any cracks, but I did not see any cracks that told i y 16 me there was stress in the structure the way it set at a
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that time. .
I8 All right, I thought you indicated a minute l 5 4 ;
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8 I9 ago that you didn't see any cracks. ;
l 3 20 g n,g.s try again.
I 21 It's either you didn't see any, or you didn't G
22 see any that worried you?
23 Let's take the latter. I didn't see any A
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24j cracks that I associated with a potential lack of
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- ALDERSON REPORTING COMPANY. INC. l
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i 14 3 okay. Considering your expertise, do you have l 2 l the ability t
t- walk into a building of that kind and look 3 ! st cracks and determine whether they have safety sig-4 nificance? ,
n 5 A To an extent, yes.
M j 6 4 And that would be determined, at least in R l
" 7 part, on the width of the crack, I assume? ,
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,g 8 A Width and location. [
9 ? And direction, or -- ;
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10 1 Yes, orientation. ,
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d Il G I don't mean to press you, but I do want to 3
y 12 make sure. Is it correct that your testimony is that ,
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,l l 13 you, in fact, did see some cracks and reached the con- i
- l 14 clusion that they were not of immediate concern to you?
5" j 15 A Let me try to explain this. Most any concrete t_
j 16 structure will have some cracks in it. If one wants a
- 1 U 17 to look, one can find them. I am sure that if I were j 5
18 to seek them out, I could find some, but I do not recall l
"g 19 seeing any that I associated with a problem. ;
l l I 20 4 Okay. You still haven't answered my question.
l 21 Did you see any cracks?
l 22 : A I don't recall.
I, 23 ; 2 okay, that's fine.
24j Are you aware of any correspondence or dis-I i 25 cussion that has taken place between the staff and i
l n
' ALDERSCN REPORTING COMPANY. INC.
i L
4 30 f
f I Sechtel in the year 1980 about cracks at the service water 2 structure?
a 3j 1 I have no direct contact on that.
4l '
4 Regardless of direct contact, have you seen g 5 any papers that indicate to you that there has been any n
j 6 exchange between the staff and Sechtel with respect to ;
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^ I 7
the cracks at the service water structure? ;
i A
8 A I think I had heard someplace that somebody 2
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9 from NRC was waving a red flag that there were all kinds j
10 of cracks down there, and I was curious about this because '
!a II I certain1v didn't see them when I was there.
i 32 ,
G When you say waving a red flag, I get the !
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- inference that you don't agree that there is a concern x
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15 1 Not from any observations I have made. l l
- i j 16 4 Okay. Now, I want to know what observations j
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you have made, and I think you described those in the 17 3 .
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scring of 1979.
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i A Yes, I crawled all through that structure.
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20 g Tell me about any knowledge that you have of II cracks in that structure since the spring of 1979, and ,
i 2!ifyouransweristhat it's simply the same as it was i '
23 in 1979 --
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A I have not made any detailed inspection of it 25
- since that time. l l
. t
- ALDERSON REPORTING COMPANY. INC. !
t 31
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G How many times in the year 1930 did you go 2 , into the service water structure or did you observe the i
3 I service water structure?
4 A At least once en the inside, but a very s
5 limited portion of the building.
N
- =
g 6 Q. Did you see any cracks at that time?
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7 A No, I wasn't looking for any either at that ,
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! 8 time.
9 Q. Okay. Do you know whether Sechtel has per-2 5
z 10 formed any kind of analysis concerning the cracks at the l j 11 service water structure?
3
'2 12 A I am unaware of there being any cracks to ,
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13 make an analysis of, but if there was in fact such,
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a I4 that would be done by Bechtel's project, and I am not l 5_ '
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g 16 If I say to you the NRC asked Consumers ;
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17 50.54 (f) questions, does that have any meaning for you? i t
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5 18 A I know there is a language of that type.
g 19 G All right, let me ask you this: Do-you ,
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.. 3 I know whether or not there are seven or eight volumes of.
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l 20 21 information prepared -- or more -- prepared by Bechtel 22 i and Consumers and sent to the NRC under a title " Responses l \
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' i to 50.54 (f) questions"?
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Do you know if such papers exist?
24]
i 25 i A That conceivably =ay be seven or eight volumes l
ALCERSCN REPORTING COMPANY. INC.
i 32 i i I of which we have a copy sitting here in the building and 2i Professor Hendron has that.
3 3 Have you --
4 A If I need it, I can go get it.
t c 5 4 Have you ever read those volumes?
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j 6 A It seems that I have got into them for certain !
l E 7 areas at times. ;
A j 8 G To whatever extent you have looked at those
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9 volumes, you don't recall having seen anything with any '
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10 analysis or study of cracks at the service water structure? !
4 11 A I don't recall. ;
i 3
j 12 G In your visit in the spring of 1979 did you h 13 ' see any water leaking through the west wall of the l
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14 pumphouse?
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2 15 A I don't recall. i w
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1990, where 3echtel and Consumers were in attendance
. i q 17 E ,
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18 ; and the NRC also was in attendance? j l
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a 19 , 1 I did attend a meeting: the date I do not a
l 20 recall. There was one in 1980 where. Consumers, Sechtel, l
l 21 and the NRC, the Corps of Engineers, the Navy, and 1
22 l probably Intervenors were there.
t j 23{ G Was there any discussion of the history of 24 . the cracks at the service water structure there? ,
1 25 : 1 I don't recall.
i i ALDERSON REPORTING COMPANY. INC. i I
i 33 ,
t I J
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1 S Is it difficult to do analysis of cracks of 2 a reinforced concrete structure? ,
i 3* A That would depend upon the nature of the problem.
4 Cracks may be associated with shrinkage, or they might s 5 be associated with stress.
A j 6 I am excluding shrinkage cracks.
4 l i
9*
7 What kind of analysis are you !
E MS. 3 LOOM:
A 0 asking about? l
-J 9 MR. PATON: Well, I'll just ask him, and if he 4 .
2 10 doesn't understand, that's fine.
E_ .
l II THE WITNESS: I'm afraid the question is far 1 S !
4 12 too general.
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j 13 3'? MR. PATON: (Resuming)
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g 4 Eliminating from my question shrinkage j u
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16 cracks in a concrete reinforced structure? j j 17 !
A No. i W
j 18 4 Were you retained to consult with respect to ,
- i 19 the diesel generator building? l 3 1 20j 1 No. ;
' f 4
21 1 4 Were you retained to consult with any structure
) i 22 l other than the service water structure and the electrical i
t i 23 i i penetration areas?
24l g '3 0 , -
25 , g Okay.
i 2 ALCERSON REPORTING COMPANY. INC. i i
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A Sy electrical penetration, you mean the aux 2 building?
3' G The auxiliary building -- you would incl"de 4 in that the fead water isolation valve pits?
5 j A Yes.
n j 6
% Okay. So, we have those three -- the service R-
" 7 water structure, the electrical penetration areas, and ,
i 3 A the feed water isolation valve pits -- the last two of C
- 9 which are the aux building.
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10 Were you retained to consult with any other .
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i 4 12 <
z A No.
- i 13 So, you were not retained to consult with E
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respect to the borrated water stora e tanks -- that's 1 s
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= l 16 I 3 A That is correct.
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3 1:7 '
3 % were you retained to consult with reseect to ;
f' any underground piping or conduits? j I
19 i A No.
n 20 ' 4 Were you retained with respect to the dike?
21 A No.
! O Dr. Davisson, I want to give a preamble to 1
23 =y next question, and it arises from my own unfamiliarity '
. i 24 I with the work than you do. ~ '
5l The thrust of my question is to find out, for i
t ALCERSON REPORTING COMPANY, INC.
s' 35 -
i I example, would the service water structure
-- where you 2 ,and Bechtel are with respect to the design and the ,
I, 3f resolution of the problem.
4 Now, I just want to read you some words that I 4
e 5 ! understand are involved when you have a problem like n
j 6 .this and you go about fixing it you might look at I
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$ 3 I will read you this list, and I know you are ,
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'. 9 going to be familiar with these words, my questita when
- a 5 10 ' I get all done is to ask you to then give me your z_
j II version of this -- whefe you start, what the next step 3
i 12 is, and then I want to ask you where are you in the
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13 process that I'm going to ask you to describe.
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5 I4 The processes that have been described to me j
15 involves you outline alternatives, you make a quick ,
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N I7 then you may refine the model for the selected alternative, !i
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18 you analyte to determine available safety =argins, you l r
3 39 compare the safety margins with allowables, and you ;
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20 conclude then with respect to the safety of the structure, :
21 and then you in some order that is not always the same, 221 you do drawings, you do specifications, you do final 23fdesigns, and then you put out for a bid.
i
' .t Yes.
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25 '
S Would you tell me step by step with respect ALCERSON REPORTING CC.MPANY. INC.
- 26 I
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?c the service water structure what has been done --
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' what has been ec=pleted with respect Oc the ite=s tha 4
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I as not in a o.csition of dealine. directiv. ,'
13 I deal with the gecrechnical group, who ;
with projects.
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= 14 e_ in turn deals with the o.rc4ect. .
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5 Although this =ay cecur simultanecus17, it ,
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a c.rciectr I as in a verv. o. c c : position te do other than 19 Anv direct inic. ation en
,3 assu=e what thev have done. - -
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- 20 that -you would have te obtain from the responsible 21 l1 parties or the structurai or project group, and when : .
22 4
' s a v. o.rciece, it can mean varicus aspects cf the desips,
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' bu: cc=:ained withis p;cject would be a structural.
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4 ,rcup which is primarilv.. t h e c. r o u c. that v.cu are inserested I
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ALCERSCN RE?CRTING CCMPANY. INC. i
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jasking me.
1 2e j *dhen I =ade preliminary recommendations on the 3! fixes that could be considered, the reasonable thing is 4
for project to have gone through the preliminary review a 5 4
n of what would be involved in these various fixes and to X 6 1, Line them up on an order of desirability from an en-R 7 gineering standpoint, and that necessarily includes costs.
! 3 If you have four fixes, and they are all four
- 9 i ,
satisfactorv, then most normal people would take the i
d 10 4 i one that's the least in cost. That may or =sy not be
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$ true of government.
i 12 5 C Government does have some -- if they are
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$ 1 I am not in a position at all to be sure 6 1:7
@ exactly what structural has done. My information would E 18 come secondhand through the geotechnical group at Bechtel.
E 19 A S I do want you to tell =e that secondhand. I i 20 am not asking what you are absolutely sure of. i 21
, A I get firsthand information perhaps in the 1
22 i
{ meetings that have been held on the subject, but outsida 23 '
', of that, it generally goes from projec: to gectechnical
'4 i I
back to me.
25 g Okay, i
- ALCERSON REPORT'NG COMP ANY. INC.
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38 i
1! MS. BLOOM: With that'I have a problem with 2 your question. First of all, I don't remember it and I i
3 don't know if he does.
4 Secondly, it assumes an order in things that a
5 ,is not necessarily true.
H j 6 MR. PATON: No, I read to him a lot of words a it's 7, which I think are clearly kindergarten to hi'2 E ,
l 3 ABC to him. I think he understands.
t 91 MS. 3 LOOM: So, you are not assuming any order?
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E. 10 MR. PATON: No, not at all. I aJked him to '
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put it in his own words, and he has indicated a lot of j 11 a
y 12 limitation on his knowledge, but I do want him to answer
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13 the question with all the limitations he has placed on it. l
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E 15 or where 3echtel is on this project.
t y 16 Tgz w:TNzss: I think you need to also under-a a
17 stand that project is responsible for the design that ,
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$ 19 want, or ignore them all if they wish.
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20 SY MR. PATON: (Resuming) 21 g I think you indicated a while ago that the 22 l Mueser-Rutledge firm was a consultant to project and you 23 :, are a consultant to Afifi?
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24j .t Yes, that's my understanding of it.
25 , 3 Okay, I understand that, too.
1 i ALCERSON REPORTING COMPANY. INC. :
4 39 I Is that the end of your answer? You have 2 explained to me things I have to understand, but I 3 don't think you responded to my question.
4 , A The question that you are asking is where are l
c 5l we in tha cvele of events?
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ones you have done.
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$ 8 A : am operating somewhat on a presumption that J
9 a structural group of project has in fact analyzed the '
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z 10 structure, ~ dgeidad that adding bracing to the building i
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"5 12 desirable approach, probably didn't have room for j
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- ,I j 16 ' a second suggestion, and found that it was workable ,
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I8 bracing to the structure that might be required because 6 ,
2 19 it is now supported on piles on the cantilever portion ;
M 6 instead of having soil support spread underneath, and in 20 l 21 the process of so doing, they would find what loads i 1
22 i finally have to be resisted by the piles.
i The last meeting I attended it does appear 23l I
- 4lthat this has been done and we now have a better ds-25 ' finition of the loads that will be on the piles.
! ALOERSON REPORTING COMPANY. INC.
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40 I5 4 Approximately when was that meeting?
2 A December -- the middle of December, 1930, 3 With regard to this process, I am concerned 4 l about the mini =um si:e -- the wall thickness of the pipe s_
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- iles , the manner in which the miles will be installed, d :
j 6 l and the load capacity that those piles will achieve, the manner in which the piles can be tested and in which 7 l i
A 3 they can be jacked and locked off inte the structure.
E 9 The structural analv. sis of the m. ile c a e. , or ,
's 10 corbel as you have been calling it, rests serie:17 with 'l
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,3 y 12 the structure is strictiy project structural, noc.me.
l 13 ' G You preceded tha: list of things saying you f I
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1 1 22 I G The firs item you listed was -- I didn't i i l '3
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i 25 < 1 The size of the pila -- -he wall thickness.
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i ALDERSON REFCRTING CCMPANY. INC. i
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G Can you tell me just generally what tha:
2 !
concern is?
3 A We need a sufficient cross sectional area 4 of steel in order to drive it for the load capacity that a 5
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2 11 There is some coordination required, ves.
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d-17 you talking about people who do not work for Afifi? i 5 18 A Absolutely, they do not.
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,5 g A Absolutely.
21 g Okay, I think I know what you mean.
22 Do you have direct involvement with the size 23 I think you did indicate you will consult I of the pile?
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i with respect to that subject?-
25 i Yes, buu that would be a responsibility'--
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h I9 , A Ch, we are in the stage now where we need := ,
n F 20 drive a pile and lead test it and verify cur design 4
21 assusceions, because the load test is the final deter-4 i
l 22 l mining facter as to whether what we are doing is adequate
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4 I are ones on which you expect to do some consulting work 2 to Dr. Afifi, is that accurate? -
3 A Yes.
4 G Can you tell me just generally what are the g 5 concerns with respect to the manner of installation?
-i j 6 A We need to have a procedure that is consistent R
- 7 with an acceptable load test so that we can be assured .
! 3 that the piles will have their capacity once they.have J
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3 12 A There are certain minimums required by our .
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19 s A Yes.
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concern is to make sure that you get a pile that can 22 ! accomolish that job?
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24 i G That concern there obviously will effect the 25 design of the pile? ,
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+ Testing -- can you tell me hcw the process "9_ f
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5 I4 settlement observations will be made by
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l 18 drive these piles -- I'm not sure I get this correct --
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19 twentv. feet into the till, is that correct? '
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oc I determined that you will drive these' piles -- have you l
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! ALCERSCN RE.=CRTING COMP ANY. INC.
45 I Idetermined what depth you will drive them into the till?
2 ', A They will be drive to the till and then to 1
3 'a practical or refusal criterion fer the hammer ,
4 cushion O.ile system that is selected.
5 . :actical, how --
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n 2 6 A Probably be twenty blows per inch final '
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i 3 i 32 A Yes.
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j 16 g re.s in a graph form.
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19 A I don't recall seeing it. It might be in a i .
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t 22 I (Discussion off the record)
'23 il MR. PATON: Back on the record.
I 24 3Y MR. PATON: (Resuming) i 25 '
S Dr. Davisson, is it fair to say that to the i
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I 'best of your knowledge Bechtel is in the process of 2 refining the final design of the piles? ,
3 x yes, 4 1 What is the approximate distance between the I
g 5junderpinningpilesandthe closest wall of the service H
j 6 water structure?
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3 b 7 MS. 3 LOOM: Excuse me, would you repeat that
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O I 9 (Question read)
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@ 10 THE WITNESS: Couple of inches.
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3 14 2 A No.
_b j= IS 4 Does it come within your area of responsibility g 16 to consider whether there is a possibility of damage to ,
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$ I7 the wall from the driving of the piles?
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j 18 A Yes. We have developed a procedure that would '
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20 0 What is that procedure?
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21 A Predrill each pile location.
22 } q Dr. Davisson, I asked you a question'before, 23 and we have agreed I will ask again and you put your 24 l answer on the record again. .
r 25 The question was describe generally'the 1,
ALDERSON REPCRTING COMPANY. INC.
1 47 4
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I method that you are going to follow to test the piles. , I 2 1 The pile will be driven, concreted, probably ;
I 3 'a deadload frame built above the pile and loaded, a 4 hydraulic jack will be inserted between the pile and the $
g 5 frame, loads will be applied to the pile by the hydraulic n .
M j 6 jack, and settlement will be recorded as a function of a: ,
time and loading. !
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,( 8 g Will that test be conducted in the place
- 4 9 where the piles will be installed?
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@ 10 1 No, it will be in an adjacent representative z
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16 3 where you drive the pile will be representative? i i
N I7 1 The borings already show that we have a ,
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I n 20 1 Yes -- no, we have not picked the final lo- j 21 It will depend a little bit on the logistics.
cation.
i 12 g Okay.
> i 23 The logistics has to be an :nput to the 1
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i selection of that location. However, the nature o f the 25 l support for the piles are primarily ott of the lower part l .
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i ALCERSON REPORTING COMPANY. INC. ;
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! 48 4
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I of the soil profile,which is fairly well documented.
2 % You mean by that the till? ,
3 .; A Yes.
4 G Will the jack impose the live load?
$ 5! I A It will impose a load that will incorporate n" ,
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- 6 'or include the live load as a quantity.
" 7 Okay, and the seismic load also?
4 l n
i 8 n A Yes.
d 9 Will there be any test conducted to determine G
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@ 10 the impact,if any,of negative skin friction? l z
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3 12 Would you describe that?
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N I7 measure of the negative skin friction that conceivably !
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5 19 When the pile is pulled up, will it- stretch 3 4 ,
n i 20 longitudinally?
21 A Negligib ly , yes.
22l G Okay, whatever that is,in your professional i
23 ' j udgment, it has no impact on your determination of
- 4 negative skin friction?-
25 i A That is correct, it does not.
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1 4 When it stretches longititudinally, does it 21lcontract laterally?
3 1 In a negligible amount, yes. ,
4 G Dr. Davisson, I want to clarify something that c 5 we have just been discussing. You indicated, I think, that n
o 6 you have not determined the exact location that you are n
2 7 going to make the pile test? I
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" 1 I have not; it's conceivable that Bechtel u
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d 10 i i G Okay. '
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1 They may have alreadv. picked some locations i
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that are possible locations.
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i G That are representative of the till material z -
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z look at the possible locations, and then among that M 17 0 c.ick the one that will be ree.resentative. '
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5 one pile?-
20 L That's the plan at the moment.
21 G Is the till in the various locations where'the 22 ciles will be driven -- is that all the same, or is 23 'i the re any difference in the till?
24 i There are possible variations.
1 lt 25 G Sy possible, does that mean that you know ALDERSCN REPORTING COMPANY. INC. -
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1 Our procedures take that into account.
1 1 1 3! ? Well, what I want to know is what do ycu knew 4 about it now?
2 5i 1 Only what you see from the borings, but our
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" 7 ? Okay, so you are -- you are talking in circles.
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! 8 don't knew what the borings say. I am asking you wha 9 you know. What dc you knew? What dc the bcrings show?
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5 10 A The borings shewed a hard till material.
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A First of all, the centrol that-has been -.
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20 of force every time, and if the' fill does not choose to -
21 resist the force, the pile will =erely continue to i
22l. -cenetrate until it does. So, the pile tips will seek 23 [ their own elevation, and therefere take into acccune 24 l some of the variatiO*.s in the till. -
D- In addition, the jacking system that is i
9 4
ALDERSCN REPORTING CCMPANY. INC.
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4 I going to be used to jack the load into the piles before 2 attaching to the structure, provides us with an opportunity I
3i to check the load-carrying characteristics of each 4 individual pile before it'is finally fastened into the e 5 3::ucture, N
- j 6 ? It's very possible then that each of these b 7 piles could end up at a different elevation?
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8 1 Yes.
-J 9 In the first twenty feet of the till that you z.
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15 MS. 3 LOOM: I don't know if you have established
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N I7 MR.-PATON: If he doesn't know, he can tell f
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18 me he doesn't know.
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s l9 THE WITNESS: I am at a loss for that question.
M 20 I thought that's just what we were talking about.
i 2I) MR. PATON: We were. Can you answer the t.
22 } question?
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'3I THE WITNESS: Wait a minute. I am not --
24 i 3Y MR._PATON: (Resuming) -
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? You indicated that a lot of people had varicus ALCERSON REPORTING COMPANY. INC. .
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1 responsibilities with respect to the service water structure.
I 2 A Yes.
3 G Is it the structural group of project that has 4 the ultimate responsibility for the design of the under-l g 5 pinning?
-i g 6i A Yes.
n i 7 % Okay. I wasn't trying to be funny. i
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$ 8 Do you know where the information came from J
- 9 concerning the till into which the piles will be driven, s
@ 10 and let me suggest to you the possibility that it came f z
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12 A Definitely, it was a Dames and Moore original
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14 ? Okay, that goes back to something like 19697 E 15 A Ac. e. ro xima te ly . -
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% In determining the bearing capacity of the :
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$ 17 c.iles, what kind of c.aramaters do you -- did you obtain .
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} 18 from the Dames and Morre report? What. kind of information N
39 do von get?
2 .
I 20 A I think primarily I saw a description.of the 21 till, the end values or the results of standard penetration 22 l tests exceeding a hundred blows, and I compared that with 23 my experience with similar material on other projects.
24l 4 Now, I am sure this is so famallar to you, 25 l but it's not that familiar to me -- you said standard s
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- ALDERSON REPORTING COMiANY. INC.
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1 penetration tests?
2 A Yes. ,
1 3! G What other kind of advice or paramaters or 4 whatever do you get from the Dames and Moore report ,
s, 5 that you use in determining bearing capacity of the piles?
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- i g 61 1 Primarily standard penetration resistance, a e i 7 description of material, i 2
A 8 G Are you familiar with any other project in a
9 which a scheme similar to that being proposed for the z.
E 10 service water pume structure has been used?
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j 11 1 Yes, it's an underpinning technique that 3
i 12 one would use whenever it's chv.sically cossible to z
s 13 install the Oiles in that manner as opposed to getting !,
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5 14 underneath the structure and jacking them in.
c j 15 4 I get the inference from your answer that it
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16 is preferable if you have the room to put the piles i
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18 underneath the building, or do I misconstrue your 3
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19 answer?
n i 20 A Yes, you did misconstrue.
21 % Okay. Tell me.
22 i A The structure that we are looking at --
it's i
23 [ 4 combination bomb shelter and pill box in terms of f
a 24 l being very magnificently overdesigned. -
i 25 % It's overdesigned?
1 ALDERSON REPCRTING COMPANY,INC. ,
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A As far as underpinning, people who are experts 2
in this area would regard that structure as an absolute '
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4 4 3ecause of its original structure?
5! Yes, it's cuite stout.
$ .L Ordinarily, people n
j 6 that are dealing with underpinning, are dealing with i R
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- 7 structures that may be somewhat aged and about to fall i i 8 A apart on their own, and it makes it a very, very delicate c
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operation. .
10 j :n this case we are' dealing with a new 2 11
< structure that's been designed for doomsday tv.
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and is hence very stout, and when you are dealing with it is i
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3 14 !
E to work with. Consequently, there are a lot of things {
? 15 g you can do that you might not do in other projects on ;
16 3 other types of structures. l
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' ' i 17 d G Okay. You indicated that you are familiar l
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- with other orojects on which a similar scheme was used.
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19 ) Can you tell me -- can you give me an example? .
i ! A I would have to go back and review some jcb 21 lists.- There may be maybe 800 or more projects, to i
22 i .
- eack out a coucle, but it's not at all unusual -- pile 1
23 ' driving pro j ects i that involve some difficult soil con-24-i L i ditions to have scme piles that are rejecued, and that a 25 ' fix has to be instituted, and sometimes that.fix s 1
! ALDERSON REPORTING COMPANY. INC.
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1 criving ad3 acent piles next :o it and strapping on.
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@ Okav.- ust a moment please.
3 1 (Pause) 1 4! i.
Or. Davisson, I did not understand your use g 5{oftheexpression the piles, or a pile, was rejected.
n <
6-I g A Maybe some damage to the pile after it's N
= 1 5 7 driven, or at some stage one determines -- i n
k 3 MS. 3 LOOM: If I can interrupt, I chink he u
- 9 . . . .
was t a a. .< in g ac o u t cener cro.7ects.
2.
C 10 5 MR. PATON: Oh, okay, fine. Other projects.
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!3 II THE WITNESS: Absolutely. i y"
f- MS. 3LDOM: He said this scheme would be i i
- 13
- used when -- .
i 3 14 '
g MR. PATON: Okay, fine.
u
- 15 i MS. 3 LOOM: When something would happen. ,
= . .
g 16 MR. PATON: Okay, I appreciate that.
s
" 17 !
j 3Y MR. PATON: (Resuming) !
i 5 );8 S You indicated that you would have to ;ook at
-r 19
! a number of -- hundreds of files to come up with a j i
(
- O couple of examples. I am asking for your present J
21
. recollection.
22 i Can ycu recall any example where a similar i :
t
,3 ischeme was used?
24 i A A building in Akron, Ohio, where adjaceni 25 piles were installed to a pile cap, and a needle beam ALDERSCN REPCRTING COMPANY. INC.
i -- i 30 1
I ! inserted under the foundation and poured on top of the new 1
2 } piles, thereby supporting part. This is a very similar 3 ' oceration.
4 .
G Okay, I'm in your area not mine, but a needle 1
s indicate that the support was no:
N 5lbeamwouldseemto g 6 coming from the side, but was coming from underneath?
n i O
" 7 1 In that instance, it was not attached to the
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A 8 wall. I would have to, like I say, go back through these c
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9 records to see if we have attached scme to the wall.
e 10 S That's what I was re f e rrine. to. Can v.ou l 2
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3 II think of any example of that -- where the support was <
a
- 5. I2 from the side as co.n.osed to belcw the structure? ,
=
13 L offhand, no. It would take investigation to 3 14 I g come up with other projects in which that was done.
}= 15
? Could I ask you -- how long would it take you j 16 to do that, approximately? t x
t M*
M l7 A Several days. '
a
- t I8 I see.
k 4 W
2 I9 MS. BLOOM: Off the record. ,
n I, t
,O '
(Discussion off the record) l 2I MS. BLOOM: On the record.
J l
22j 3Y MR. PATON: (Resuming)
- 3
' ' 7 Dr. Oavisson, in a building I think you have l
^4 j described as stout, such as the service water strueture,
^
4 25 woulf you expect to find cracks, other than shrinkage i ALDERSCN REPCRTING CCMPANY. INC. '
l ** i 37 t
I cracks, -- and apply that to the Midland case, with all 2
you know about the Midland case -- would you be surprised 1
3 to find any other kind of cracks other than shrinkage 4
cracks?
e 5 A Pro'c ably would.
n e 6 e G How do you determine the difference between ,
I
?, 7 n
a shrinka9e crack and a stress crack?
i 8 5 A Csually you find a reason for the stress c
- 9 z-crack in terms of its orientation and location.
10 You mean if it's a stress crack, it's in a
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< certain place, and in a certain direction that tells E
'i 12 z you it has to be something other than shrinkage, or
- 13 -
E_ probably is, or may be?
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= 14 5
A Yes, and width may be a clue.
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0 15 2 4 Are you aware of the present discussions between !
= '
? 16 3 the Staff and 3echtel and Consumers concerning the !
a
' 17 d-Staff's request for additional borings?
5 18
= A To an extent, yes. .
19 2
n ,
4 Are you aware with respect to the service --
20 as they may effect the service water structure?
21 a 1 Yes.
-, 1
"! g And do you have an opinion as to whether or i
~3
- I i not the staff needs tnose acditiinal borings at the i .
'4
^ i -
4i service water structure?
25 -
A Yes, I have an opinion.
i ALCERSON REPCRTING COMP ANY. INC.
58 I G What is that opinion?
2' 1 Definitely they don't need them.
I 3
i G Is it your opinion that any information that 4 would be obtained from additional borings in the area of e 5 service water structure would be misleadinc?
N j 6 1 I have no opinion on that.
n .
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G I thought I read somewhere that you had
$ 3 indicated at one point that it would be misleading.
9 Do you recall making that statement?
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- i
- t t 10 A I don't recall.
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3 G Would you agree with a statement that it a
" 12 i would be impossible that information obtained from i
=
i 13 these borings could be of assistance could shed some g -- i n
I4 information on the problems at the service water structure?
5 4 c_
j 15 A I have no conceivable use for additional i
= i E I0 borings at this point. !
C !
2 17 1 G Is that because of the heterogenous nature j w ,
=
5 18 of the soil?
3 19 2 A No.
. 20 Why do you say that?
G 2I A Maybe I better retract that. It could, in i 12 fact, relate to that, but primarily .che decision is 23 made that material vill be penetrated and the loads
- 4 Icarried in the underlying till, and at.that point i't ' s
- 5
' , academic and folly to be wasting money, time,-effort on i
! ALDERSON REPORTING COMPANY. INC.
59 I 'that concern when, in fact, there is other informatica 2i that we don't have yet that is much more pertinent. .
3 You are saying -- are you saying that, for
? ,
4 example, if you run a load test, that's not theory,
! 3 ;tha 's
~
in fact field results?
.4 g 6 1 Absolutely.
" i
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" 7 And is much more persuasive than any testing G
i 8 5 which is subi.ec: to certain e.roblems? ,
c 9 .
!- 1 Yes.
z.
10 All right. This whole question relates to i z 2
=
11 the degree to which you want to be certain that your 4
3 i 12 z_ structure is safe. '
=
I3 Would you agree with that? :
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14 I don't follow what it is you are asking me 2_ 1
=
0 15 2 to agree to.
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16 What I am saying to you -- I think you in-f 4 I t '
- 17 M dicate there is some possibility that the information :
-- t 18 from the borings would be of assistence.
19 I think he changed his answer. l i
" l 0 No, that's not what he changed MS. BLOCM: !
21 f his answer on. He said the heterogenousness of the soil i
22 ) may be a reason whv. you wouldn't want to do borings.
I 23 ; MR. PATON: All right. Let me go back and i
24 :i ask him -- .
25 733 3;733g3, ;;,s really the reason that we i ALDERSON REPORTING COMPANY. INC.
- 4 60 .
I are not using them.
2 3Y MR. PATON: (Resuming) 3 G Is your statement that it s impossible tha 4 the information obtained from the borings could be of
+a 5 assistance in vour assessment of the service water n
~
3 6 structure?
R^
" 7 A Ch, no, I will admit there is the possibility n
! 8 one might find some use for it. It's just not on the
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= 9 .
tacle now. ,
- z. ,
10 You say you are not able to see one -- you j G
= b
!m Il are not able to conceive of any use?
N I2 A That's right.
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- 13
- G Then your present opinion is as far as you m-14 know right now, you can't see any use right now?
3 u
15
& A That's correct. s g 16 G I want to ask you about the current status
^ r
- ~
' l7 of the testing. Has any of this work -- has the pile d .
j 18 ' been driven? :
9 19 "s
n A No.
20 So, none of it's been done?
G 21 A That's correct.
I 22 l G At the serrice water structure there is a 23 problem with the soil. I think you would agree with th'a:.
24 -
i Do you agree to tnat?
25 Yes.
A i ALCERSON REPORTING COMPANY. INC. '
y -. - -- - ~
( 61 i
i 1,
I G What's the problem?
2 A The problem is evidenced by an investigation 3 ' made by borings -- not that I could see from any settlement 4 lof the structure, as for example took place at the diesel 2 5 =enerator.
n (
- N j 6 In the borings the low standard penetration-a 4
4 6 7 resistances were encountered in the fill material, and ;
u !
A 8 determinations made by others than me were that no t
9 supporting value would be attached to that soil for z.
@ 10 design purposes. i z
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Il okay. You indicated that there were low blow 5 G a
i 12 counts, is that correct? ,
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15 A It indicated to others a lack of adequate j 16 support. l
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G Is there anything else you needed to know 5
I8 about the problem -- that you needed to know about e
g I9 the probicT -- in order to perform your task?
n
. 20 x 30, 21 And it was a problem because the building 4
1 22 ' would settle more than permissible. Would you agree i
23 l with that?
24 I A No. -
25 You say no?
G 6 ,
1 i ALCERSON REPORTING COMPANY,INC. l
. , i 62 .'
i I '
A No.
2
? Why was it a problem?
l 34 A We were left with a section of the building 4
cantilevered as far as the design goes, and under doomsday i a- 5 loadings, the building is not sufficient as it now n
3 a 6 I'i stands to handle that. There would, in fact, be stresses j n r n 7 l
- developed that are too high and accompanying de
- ormations ;
c= 1 s 8 so that some support was deemed d2sirable at the canti-C
- 9 j le.ver end of the building.
A '
10 5 .
G If there had been a soil problem at the ,
2 11 I g
building that would have allowed the -- what is it --
i 12 ;
E the cantilevered end of the building --
to settle 1/100th ;
- 13 :
E of an inch over fortv. v. e a r s , would that be a problem? ,I E 14 1 5 A No. l
= !
15 2_ % O k a v. , that's not a c.roblem? .
T 16 B A No. i a :
P R 17 '
G ? Okay, then you have made some determination that
= t 5 18
= it was a sufficient problem that you had to do something 0= 19
" about it? -
l r 20 A No, I did not make the determination.-
21 4 Who-did?
1 22 { 1 Sechtel.
23 ~
G Do you know what criteria they used to 24 i - .
$, determine?
25 A No.
I ALDERSON REPORTING COMPANY. INC.
I-
f 63 i
i I
G You don't?
2 A Once they had determined that they needed 3' support, then I was asked for methods of getting the ,
1 1
4 :
isupport.
I a
- 51i So, Bechtel told you there is a problem, and G
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we want v.ou to fix it, but .vou didn't need to know what 3
5 7 criteria they used in determining there was a problem?
n i 8 n A No.
C
- 9 j % Do you agree with that statement?
3 10 j A That is correct, no,I did not need to know. l
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2 11 i g 4 No -- meaning yes. Okay. '
d 12 3 Do you agree with my last statement? !
= t 13 '
E MS. 3 LOOM: De vou want it read back?
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= 14 i d MR. PATON: Read it back, please. l
= ;
b (Question read)
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? 16 3 BY MR. PATON: (Resuming) I
^ ,
- i I -
' l7 l y G 3echtel told you there was a problem at the ,
E 18
- service water structure. Do you agree with that? ,
- s C 19 5
n A Yes.
i i 20 ' '
4 Do you know what criteria they used to 21 determine there was a -oroblem at the service water 22 1
' structure ?
23 ' : 1 In detail I do not.
e4
- l ,
? Do you know anything about it.
25 A Just generally -- knowledge that : might have 1
ALDERSCN REPCRTING COMPANY. INC. I
4 64 I
1 in general that's applied to other soiIs in other 2 , locations.
1 3
% Well, what is that knowledge?
4 i
- A That the low blow counts were indicative of
$ compressability, and relatively low sheer strengths n
2 6l'andpotentially I
liquifiable material, and it did not ,
4
" 7 !
look as desirable as one would like to have for this s
i 8 a condition.
o 9
- z. 2 Okav.
10 j 3 1 I would like to add that it was not ny job
=
j 11 to study that condition.
l '*
2 q All right. Do you have any knowledge of -
=
13 whether the building, in its condition when you first 3 14 2 were retained as a consultant, whether in that condition 15 2 , any NRC criteria had been violated? i
- ~ i 16 i I am asking for your knowledge, j z e l '
i n 1:7 0 A I am unaware. ,
p G 18 G De v.ou know whether underpinning was con-19 n
8 sidered as an option for the diesel generator building?
20 I am sure it was thrown on the table also, A
i 21 just as I threw several options out for the service i 22 i l
water cumo structure.
1 23 't Oc you know why it was rejected at the diesel G
24 - -
! generator building?
25
'A No, that would be best asked of Dr. Peck and 1
ALDERSON REPORTING COMPANY. INC.
1 l
a 65 I 'Dr. Hendron.
2 4 Are there --
t 3' MS. BLOOM: One moment.
4 (Pause) s 5I 3Y MR. PATCN: (Resuming)
N 2 6 G Are there any pipes running under the service R i 4-7 ' water structure?
n
! 3 A I am unaware of them.
9 Are there any conduits?
. O z-0
- 5 10 A I am unaware. These are ice =s that project z
=
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3 12 Are there any pipes running adjacent to the E
G i
- 13 service water structure under the ground?
=
=
- 14 There undoubtedly would have to be. I 2_ 1 e
!= IS 4 Do you have any idea what the impact of .
g 16 underpinning the service water structure will have on a
.4 ' ~17 the settlement of those pipes? .
=
I8 f
A Well, you are telling me first of all that i
19 pipes exist, and I guess I agree that some have to exist.
t 20 I think you told me they have to, right?
G 21 I expect a negligible effect.
- A 22 g Do you have any responsibility to advise i
23 l 3echtel in that regard?
24 - ,
.s ,.
.. o .
'S q Are you aware that there are Category I service 1
ALDERSCN REPCRTING COMPANY. INC.
66 i
I ' water pipelines between the auxiliary building and the !
I 2 ! service water structure?
i 3l ,
A I am certain there would be.
1 4 ' Are you aware that there are Category I G ,
g 5 , service water pipelines be: ween the diesel generator n -
g 6 I, building and the service water structure?
- =
1 ,
E 7 A N o ., I was not aware of that. I' i 8 5 C For reinforced concrete structures subjected a
- 9 :o tensile stresses due to imposed design loads, are
- z. .
5 10 cracks observable to the naked eye acceptable?
z
= '
!3 II A Yes.
12 Obviously, there could be cracks observable to E G
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13 ' the naked eye which would not be acceptable?
5- .
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= 14 x -
A Yes.
=
0 15 h G Is there an ACI or other code that addresses ,
= f y 16 what is all'owable width or any other criteria with n ,
" 17 i 9 respect to these cracks? .
l 6
- i
!: I8 A I couldn't cite it if there is one. I would 19 j suggest that you ask these questions of the people who ,
,t 20 are responsible in that area.
21 You are a structural engineer?
C 22 i A Yes.
! 23 G You may have told me this, .but tell me again, 24 4 why doesn't a structural -- why don't you have resp ~en-25 l sibility in this area?
4
- ALDERSCN REFORTING COMPANY, INC.
I
4 4 1 Of ,
f I A Secause project has responsibility for the 2 structural engineering on that building and on the entire 3 l operation going on with that building, which would 4 include this underpinning.
5 g MS. 3LCOM: 3efore we go on, I want to clarify n
~
6 2 what is ACI? Just for this deposition purposes, what ,
1 R
= s
" 7 is ACI? ,
n-3 a MR. PATON: American Concrete Institute.
u
)= 3Y MR. ?ATCN: ( Re s umi ng) 9 10 4 Considering the responsibilities that you do
- E_
2 11 have :or the service watdr structure, if at anv time
< - i 3
12 2 you did observe cracks that you thought were other than !
- i 13 a
shrinkage cracks,-that would effect your deliberations, 1
5 14
? wouldn't it?
IS b A Are you saying in the service water pump
=
16 '
i structure?
=
i -
1:7 d G Yes, sir. '
=
E 18
- 4 If I happened to see them, I would probably l
- i 19 t j ask a question about them, certainly.
l 20 In a reinforced concrete structure, is there )
4 21 J
any width of crack that you would consider to be un-1 22 r acceptable or that you would consider something other l than a shrinkage crack?
'4 J A I have not given that situation any thought, 25 and ordinarily in any observations of cracks, I don't f
i ALDERSON REPORTING CCMPANY. INC.
I
- 63 I measure the width. I as afraid I don't look at them in 22 those terms.
}
3l Also, in deliberations with regard to such
}
4 things, I have available to me people who are specialists 5
g a in concrete, reinforced concrete, that I would use as s
1 -
g 6 consultants to me rather than relying on my own background.
R ,
= 6 5 7 2 I want to ask you a very similar question to ;
n j 8 what I asked you a minute ago.
J-9 For reinforced concrete structures subjected z.
O .
y 10 to sheer stresses due to imposed design loads, are z
=
!5 II cracks observable to the naked eye acceptable? i 12 MS. BLOCM: I want to object to this question 5
=
g 13 before we go on. I think he just said for the past
= .
m .
5 14 fifteen minutes that that's not his area of expertise, I
t 15 I don't think I am misstating him that
{= and I may be --
j 16 he has not been involved in that.
t
$ I7 MR. PATON: I think that's a fair statement. !
M
} 18 I'm getting ready to -- I have just a few more questions.
l &
19 I understand what you are saying.
l s 2-20 THE WITNESS: If I may respond just a little [
t 2I bit to that.
22 MR. PATON: Of course.
23f THE WITNESS: A sheer is a measure of diagonal l
- 4
' ;' tension and is definitely a concern to structural en--
25 i gineers, but to respond a little bi Oc'the general i.
! ALCERSCN REPCRTING COMPANY. INC.
L.
i
- 69 I
I I ?line of questions with regard to this project, I do noe 2 ,have the structural responsibilities, cnd while I may 1
3 ' develep -- make notes or observations, and pass it on --
l '
4 ,I am not the one that is responsible for this area.
S 5 If I were in fact responsible in this area N
~
2 6 , en the structures, I would engage the services of someone
" 7 to help me with it. ,
8 MR. PATON: All right. Fine.
9 THE WITNESS: Which I have not done since I i
.~
g 10 4 am not the responsible person.
z 4 11 MS. 3LCOM: Ceuld we go off the record? i 3
E 32 (Discussion off the record) i 2
5 13 BY MR. PATCN: (Resuming) 2 I4 5 G Dr. Davisson, if there was a crack in the
_=
j a
15 service water structure that extended through the wall, g 16 like from one side to the other, would you conclude a '
N II tha: that was a stress crack?
E s What wall are you talking about?
o 18 MS. BLCCM: '
_ i s
g I9 MR. PATCN: Any wall.
n 20 Probably, however, again, I have !'
THE WITNESS: !
2I ;, not observed such a crack myself nor am I responsible 1
22 i for concern over that, i
'3
' 3Y MR. PATON: (Resuming) 24 ? Okay, have you observed cracks in any wills >
.S
' of anv. Catac. cry I structures at a n v. nuclear facility ALCERSCN REPORTING COMPANY. INC.
- 70 I other than Midland?
21 g r 333.t recall any.
i 3, ? Ckay.
i 4' 1 Again, that would not be my responsibility.
[-
n 3[ I
% Dr. Davisson, I want to show you a document 2 6 '; t h a t is -- that has the words " crack mapping" in the
- I, n
= I 7 ' lower righthand corner, and I will suggest that it is
?9
! 3 .from -- Figure 62 of Interim Report 5 of MCAR 24
-J I z
. 9 l which is car -
of the 50.54 (f) responses.
5 10 MS. 3LOCMt Before we go on, could we have that ;
z
=
!m II marked as an exhibit, please?
12 MR. PATON: No.
i
_=
j 13 MS. BLOOM: Why not?
=
o 14 2 MR. PATON: Off the record.
j
=
15 (Discussion off the record) ,
E I6 MR. PATON: All right. I am going to mark that a
3 17 as Deposition Exhibit No. 2 Davisson, and today's date, f
=
} 18 which is January 14, 1981.
"m 19 (The document referred to was a
. 20 marked Davisson Deposition 21 Exhibit No. 2 for identifi-l 22 i ,
cation.)
t 23 3Y MR. PATON: (Resuming) i.
44
' s I show you that documen and ask you if you -
0 25 have ever seen that before?
'. ALDERSON REPCRTING COMPANY. INC. ,
- 71 i
I A No, I don't recall ever looking at this before.
2' G Okay, let me ask you this: I am asking you i
3: to assume that the information this document purports to 1
4 represent is accurate so you are not assuming any re-i 2 5 sc.onsibility for the accuraev. for that.
~
a 6 I am asking you to assume it's accurate. ;
R
- 1 7 Can you draw any conclusions with respect to cracks from ;
n '
i 8
- r. that document? ;
e-9 A Not withcut studying it. I guess I am pleased
?.
'is 10 that somebody is looking a: the cracks and mapping '
h II them and all that, but again, this is not an area I 3
12 was asked to look into, nor am I responsible for it.
f_ ,
=
13 Dr. Davisson, let me ask you to assume 5-G okay. l.
U 14 I that there are cracks in the service water structure, -
=
j=
15 and if you want particulari:ation, I would refer you j 16 2
again to the document that we just looked at. f 17 l
- j Is there any way for you to know now wha ~
t
=
18
} impact the underpinning will have on those cracks? .
19 To a limited extent, yes, 2 A n
20 What can you say at this point? i S
21 Well, to the extent that the soil that has A
j
- 22 I been deemed inadequate has allcwed the cantilever I
"3
' ' portion of the structure to settle. There's a certain i
24 pattern of cracks that one could anticipate might 4xist, 25 and jacking the loads into the underpinning piles i ,
ALCERSCN REPORTING COMPANY. INC. .
-n au b
i i
I that motion, reverse it, and would !
- bwilltendtocounteract j 2 cend to close those cracks that arise because of that, 3! Now, if there are other cracks fer other 4 reasons that are not related to possible settlement of f g -
5 the cantilever portion, that's an entirely different n .
- 2 6 ,
e su,cject.
R I 4' 7 4 For example, shrinkage cracks probably would {'
M t
a 3' not close? :
n 9
A That depends on whether they are in the path '
z-g 10 of the motions that would take place when loads are There certainly would be a group
!5 II
, jacked into the piles.
i 12 that would not be expected to close. .
i
_=
- 13 4 If cracks begin to occur during the under- i i.
2_
x 3
14 pinning process, do you have any criteria that you would ,
2 15 use to react to that situation?
s' 16 A That would be the responsibility of project i t
n :
A 17 !.
I e structural.
t G
13 4 Then the answer is that you don't have any I l
2 19 criteria that v.ou would plan to use?
. a 1 No.
21 MS. BLOOM: I will make it very clear -- that's l
l 22 I, because he said it's not his responsibility. to develop i
I 1 on -- do anything in regard to those cracks.
23 i l
24! THI ~4*TNISS: That's correct. t
,i 25 MR. PATON: Okay.
l I
! ALCERSON REPCRTING CCMP ANY iNC.
- 73 t
II .
3Y MR. PATON: (Resuming) 1 2 {4 4 When you receive information from Bechtel, do -
1 3 l you receive it from Dr. Afifi?
1 4! .
i A Yes, directly or at his recuest.
g 5I S I shew you a letter dated March 25, 1930, w ,
g 6 from Sherif Afifi addressed to Dr. M. T. Davisson which
,- o
=
" 7 I will mark Deposition Exhibit 3, Davison, 1/14/31 and ;
n j 8 ask you if you have seen that letter before?
J
- 9 (The document referred to was I !
@ 10 marked Davisson Deposition E
I II Exhibit No. 3 for idenuifi-3 12 :
j cation.) I
= >
j 13 THE WITNESS: Yes. I
=
3 14 2 BY MR. PATON: (Resuming) 15 Along with the technical specifications that
} S
,6 p they sent attached to this letter, is it correct tha' k- II theY did not send the concrete specifications, and let
.=
E la me show you --
e i
I9 1 There was an instance where that occurred, 5 i
. 20 ' and I don't know if that was the date on which'it !
21 occurred or not.
22l G All right. Let me show you a document 23 i
entitled March 29, 1930, " Memo from M. T. Davisson to 24j 3, g, gftft,, the last sentence of which reads: " Note 25 ' that I did not receive the concrete specification for '
i ALDERSON REPORTING COMPANY.-INC.
l
! 76 l
1 review." Does that refresh your recollection in that 2 regard?
3 >i MS. 3LCCM: Could we have that made an 4 exhibit too? ,
s 5 MR. PAToN: If you insist.
s 3 6 MS. 3LCOM: Yes, I do.
a n
5* 7 THE WITNESS: That probably was the instance. t i
n j 8 MR. PATON: All right, I am marking the u
2 9 document that I just referred to dated March 29, 1930, as -
z, a
g 10 Deposition Ixhibit 4, Davisson, 1/14/31. I z 4 .
=
3 11 (The document referred to was 3 ,
z 12 marked Davisson Cecosition 4 !
p 13 Exhibit No. 3 for identifi- ,
= !
x 5 14 cation.) ,
- 4 E 15 3Y MR. PATON: (Resuming)
=_
3 7 16 G Do you know why they did not send you the A ;
i
[ d 17 ' concrete specifications?
t 5-G 18 MS. 3 LOOM: Off the record.
i
=_
19 (Discussion off the record) f $=
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20l' MS. 3LOCM: 3ack on the record.
i 21 THE WITNESS: To answer the cuestion, the 1^
ZZ concrete specifications that I mentioned in a memorandum 23 was referenced in the specification I was reviewing, 24 l and for the sake of completeness, I thought I shour'd see l
25 the referenced. specification also, so I requested it.
i ALOERSON REPCRTING COMPANY. INC. ;
4 75 1
3Y MR. PATON: (Resuming) 2 By the referenced specification, you are ;
G 3
italking i
about the concrece specification?
4 1 That is correct.
o 5 G Did you need those for your review?
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- G Do you know why they didn't send them to you !
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10 a referenced spec...:: cation. ;
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< 4 Okay.
3 12 i MS. BLOOM: Off the record. !
- r 4
- 13 E
(Discussion off the record) !
i i
3 14
? MS. BLOOM: On the record. ,
15 h BY MR. PATON: ( Re s uming)
=
16 f 0 When Dr. Afifi sent you the technical speci-A i fications for furnishing, installing, and testing l
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5 I0 closed end pipe piles for the service water structure, c
19 i what did he want you to do?
n f
'O Review them as I recall.
1 21 4 Okay.
22 4 And comment.
1 23l 2 And he indicated in his letter that we will
- he pipe piles within two to three weeks.
- be installing
'S Do you recall that? ,
a ALCERSCN REPORTING COMPANY. INC.
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6 i
i A That we will install a pile --
I believe it 2, ,
was a test pile.
1 3
4 Did that give you adequate time to perform 4
your review?
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time, most certainly.
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G If you were advising the Nuclear Regulatory :
- i 3 a j Commission in this case, in your professional judgment
- 9 g do you have sufficient information so that you would 5 10 !
E concur in the remedy that Bechtel is proposing to use i
3 11 j at the service water structure?
d 12 '
E A Within thw limits of the responsibility that
- 13 l 5 I have assumed for Bechtel, and if I was operating for a
= 14 d NRC, yes. ,
F 15 E, O 3y the limits of the responsibility -- are 1 16
$ these matters you have discussed on the record already l i
M 17
, O. t o d a v. ? 1'
. 5 18 l . :
A Yes. <
U 19 i G Are your standards of review for Sechtel and l 1
! - 20 l 4 the NRC the same?
! 21 lJ A Yes.
f.
22 t Dr. Davisson, there is a reference in Deposition 1 g 23 #
! Exhibit 3 -- in fact the third paragraph -- I am reading:
24 !'
i ] If all goes well, we will be installing and testing.the 25 l pile within two to three' weeks. At'such time we would i ALCERSON RE?CRTING COMPANY. INC.
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i 77 ,
1 l 1
I appreciate having your representative attend the in-t 2 stallation and testing." ,
4 3' Did that testing ever take place?
i 4it A No, no test was performed.
i g 5 Do you know why?
n 2 6 A Yes.
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n j 3 A Secause 3echtel was to supply a pile meeting u
9 a certain spec and they were unatie to acquire the z_
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- nis particular operation.
s 12 Okay.
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13 A They did cobble together a pile that did not g j 2
- 5 I4 meet our requirements, and hence that pile was not tested.
15 You said "did not meet our requirements."
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18 Okay. You said somebody cobbeled together a 3 G n
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a } cile?
20 A Yes. f
? Who did that?
IIf.4 22 ! A 3echtel's field forces.
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24 : A You better ask Sechtel.
25 Ckay. Have they to date ---have they tested 3
i ALCERSCN REPORTING CCMPANY. INC.
73 1
the pile?
2 A No. I l l
i 4
31 Are they still having difficulty getting the 1 4
4 right kind of material?
e 5 i A Ch, I am quite certain they could acquire the n
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& 7 4 Do you know why they haven't -- this is, you n
S 8 M know, ten months later. Do you know why they have not
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- 9 3-c.erformed that test v. e : ?
E 10 g A No.
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2 11 g C Okay. I don't understand why, considering l d 12 E
your position and your responsibilities --
it seems unusual
- 13 i :o r.e that you are not aware why they haven't performed E 14 d
this test yet. Could you respond to tha:?
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T 16 3
a G Have you ever asked them within the last ten F 17 d- months when they will perform this test?
7 18 l -
A I am sure I have inquired of Afifi.
j 19 4 But do you recall whether you have inquired? '
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A I don't recall specifically, I just feel 21 i certain I probably have asked.
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Dl G Okay. What did he tell you?
-1 23 i A Nothing definitive or I would.be.able to 24 . repor: it.
i 25
? Okay.
i a,
ALDERSON REPCRTING COMPANY. INC.
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I A Again, he would have to inquire of project.
2} S So, you presently have no knowledge as to when I
3 j:here will be a pile tes:?
i 4 A No, I de act.
5 Have you reviewed the quality assurance g 4 okay.
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6 ' manuals that will be employed covering the installation
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of piling at the service water structure?
- 8 n A To my knowledge such a manual does not exis:
a 9i at this time.
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10 Is that within the secpe of your responsibility?
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!3 II A Yes, I as certain it will be.
12 Do CA precedures exist at this time?
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- A In general yes, at the clant site. +
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x i 14 CA c.recedures s=.ecifically with respect to i 2_ %
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15 the installation of piling at the service --
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-- ;y In the Bailly case v.ou reviewed the QA manuals :
M
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f and procedures with respect to installation of pilings, 19 5
n did you not?
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A Yes, and it's still not complete. ;
21 Is it correct that the piles at the G Okay.
22 l service water c. ume. structure will be tested individually i
'3 l' o 150% of the load?
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A It's my recollection that it's 150%.
a 25 Is it correct tha: there will be no proef
?
ALDERSON RE.=ORTING COMP ANY. INC.
s' q '
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I loading of the piles as a group?
2 A That is correct.
3j 4 Can you tell me why?
t 4 !, A That would require a considerable reaction, l
c 5 Iand something like that would be unprecedented and
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r a i i 7 4 Am I correct that you cannot conclude that if ,
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$ 8 the individual piles were tested to 150% that the group t
9 would not test to 150%?
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y 10 I'm afraid I don't understand your question.
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12 Assume that you do what you intend to do in N -
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j 16 respect to all of the piles as a group that they would z l
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$- 17 test to more or less than 150% of the load? '
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2 18 A Yes. t
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. 20 A I would conclude that the group capacity would l 21 j equal sum of the individual capacities. q
! l 22 ! I might also add that we really don't have j i 4 23 , normal pile groups. ,
j 24 G You mean because they are separated by rome a
25' distance? l .
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ALDERSON REPORTING CCMPANY, INC. i 4
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. 31 3 i i ;
1 1 A That is correct. l 4
2 G Are there any plans to have a person monitor ,
i 3 'the piling installation at the service water structure?
4 A Yes.
g 5 G Where does that requirement appear?
j 6 A : am not sure. I know that if there is any R i i 7 work done on those piles, myself or my representative n
j 8 v'.11 be there. ,
a 9, G I show you a document which I will mark as -
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i 10 Deposition Exhibit 5, Davisson, 1/14/81, and I will !
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j 11 show you -- you can look at all of this document you want 1 8 .
12 to.
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2 15 Exhibit No. 4 for identifi- i
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- i d 17 MR. PATON: This looks like it's about twenty I w i 5 18 pages long, and I show you the names at the bottom --
w Peck.
g 19 M. T. Davisson, C. H. Gould, A. J. Lougheny, and R. 3. ,
a i
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20 The words at the top are: "The consultants 21 ) request the answers to the following."
f 22 I Let me ask you if you have ever seen that before.
23 ,
MS. 3 LOOM: 3efore we go on, can we date it 24j and say that.it's handwritten? -
t 25 MR. PATON: The document _that ! have described l 1
ALDERSON REPORTING COMPANY. !NC.
32 i ,
i I ' has a cover en it which has " Consumers Power" in heavy 2' letters on the top righthand side; it says "To File from 3 lT. C. Cook" and it's dated August 10, 1979.
i 4' Now, there are a number of other documents a
5 attached to it, that is just the cover, but about two-thirds N
j 6 of the way through the document is the particular page ,
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I am re: erring you to.
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a gi n 3Y MR. PATON: (Resuming) 9 2 I will ask you if you have ever seen that before?
2.
0 10 MS. BLOCM: Would it be okay if we include at .
E_
!3 II the beginning that it's a handwritten document ,
12 dated June 29, 1979?
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g 13 MR. PATON: The handwritten portion of the l
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3 14 2 document --
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15 MS. BLOOM: Just be careful -- it's a long j 16 bunch of papers.
A I7 f N MR. PATON: Although there is several dates A
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18 included in the document, it appears that the handwritten '
+
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19 portion of the document is dated June 28, 1979. .
. 20 THE WITNESS: Your question again?
2I BY MR. PATON: (Resuming) 22 4 My question is have you ever seen that document 23 before?
I 24 1' .A Yes. -
i 25l Did you obtain he information you requested 1
i ALDERSON REPORTING COMPANY. INC.
t 83 ,
a f
a 1 in this document?
2 A I did not. I might add that that document is 3 ,ja summary of several consultants input.
4 7 Was this information requested for one of e
5 -he other consultants as opposed to yourself?
M j 6 A Yes, Mr. Gould, i l
E Am I correct that none of these three items 6 7 0 !
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! 8 were requested on your behalf?
S 9 MS. 3LCCM: Why don't we read the three items?
Z i
@ 10 MR. PATON: Yes, Let me do that, and it will z ,
3 11 be easier, and we won't be looking for pieces of paper.
3 E
I2 MS. BLOOM: Please do.
m j 13 3Y MR. PATON: (Resuming) j i
M j 14 g I will read them for the record, but you l
- i j
1 15 have read the three items that I referred to you, is j
- l j 16 that correc*' I w i d 17 A Yes. [
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j 18 0 And your testimony is that none of these were l 8
19 requested on your behalf?
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. 20 A At that time they were not on my behalf l 21 or anything that I was responsible for at that time. ,
4 1
22 i G Did you request them later?
23 ,' t 30, 24j g Okay. You said at that time, and I wondered.
25 A It has to do with the aux building in which I ALDERSON REPORTING CCMP ANY. INC.
34 1 I I Mr. Gould was primarily responsible for. ;
2 % okay, and you have taken over from Mr. Gould 3 l his responsibilities?
I 4 A Part of it.
s 5 G The part that you took over was the electrical n
N j 6 penetration area and the feed water isolation valve pits? ;
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w 1 I have to admit I am not clear on it at this /
M j 3 point in time. That's a relatively recent change and u
9 there has not been much activity.
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t 10 In fact, he turned this over to you somewhere z
G II i around August of 19807 l 3 ,
j 12 1 Well, he gave it all back to BechteL and
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for if he were continuing.
16 How much time have you spent on that since i a %
A 17 August of 1980?
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18 A I doubt if I spent a day.
3 9
g I9 0 Okay. ,
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- 20 MS. 3 LOOM: Can we read those items?
II MR. PATON: Yes, I am going to.
22 l 3Y MR. PATON: (Resuming) i 23 Do the best you can in telling me what date
? ,
I e 24 it was that sechtel turned this responsibility ovef to you.
25 MR. 3LCOM: Responsibility of the office?
i ALDERSON REPORTING COMPANY. INC. .
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95 :
i I What responsibilities you took over.
MR. PATON:
2 THE WITNESS: Well, I am unclear what respon- l 3
rs ibilities I have on that at the moment that would have 4 . occurred in August or September in 1930.
a 5 MR. PATON: Okay. I want to now read for the n
5 0 record the three items that are listed on the page that I ,
- -1
=
" 7 I
, have asked Dr. Davisson to address. I n '
i 8 n "1. Static defection" --
3 J
9 Deflection --
~. THE WITNESS:
2
'J 10 It reads " defection," and I would MR. PATON:
3_
!s II suggest the possibility that it should read " deflection."
12 " Configuration of auxiliary wings under full i .
l
- 13 a cantilever treatment, cracked and uncracked. l'
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l B 14 1
"2. Seismic analysis of auxiliary building with ,
3_
15 ;
h deflections configuration, accelerations at each floor
- I g 16 level, edge forces due to rocking, horizontal forces to n
- 17 '
d be resisted and locations.
l 18 i "3. Analysis of auxiliary' wing stresses and .
19 3
n deflections with 1500K and 3000K each at EW ends." !
O Once again, can we make it clear MS. BLOOM: : ,
2I .that Dr. Davisson did not request that information at i
a 22 1
- that time?
23 'i MS. PATON: Okay, 1 -
24 ' . MS. BLOOM: Do you want to take a break'now '
25 <
for lunch? ,
ALCERSCN REPORTING COMPANY. INC.
4 4
36 I
- MR. PATON: Fine.
2 (Whereupon, at 12:30 p.m. the deposition in the 3-Iabove-entitled matter recessed, to reconvene later this 4
isame day.)
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_A _F _T _E _R _N _O O _ _S _E _S _S _I _O .N t
2 (1:15) i i
3i SY MR. PATON: (Resuming) 4 G Dr. Davisson, how many times have you talked e 5 to Mr. Gould since August of 1930?
9 j 6 A Perhaps once.
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2 7 G You testified prior that GA manual for pile l'
$ 8 installation does not exist, is that correct?
-J 9 A That's correct. '
I 5 10 ' 4 When do you estimate that a manual will be !
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11 d
3 developed for a QA -- a QA manual for installation of piles?'l 12 A I have no control over that, just as I have i
=
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j 13 no control over when some initial design tests will be l
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14 , performed. By way of explanation, the contractor who E :
[: 15 aventually drives the piles will be looked to as the i i
16 author of the QA - QC operation in conjunction and in f -
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17 coordination with Bechtel's procedures, and it is clear l N=
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1 18 ' that considerable effort will have to be put into that
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- I9 when it occurs. .
A ;
20 G Okay. It's safe to say that that will be at 21 least several montha away?
22 i A I think so.
> l.
- 23) 4 Do you consider that the proposed remedy of 3
24 the service water structure is a positive solutton?
15 A I would like for you to define what you mean.
1 l
1 1 ALCERSON REPORTING COMPANY. INC. '
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by positive solution.
2 I was going to ask you that. I have a G 1 3 ! reference to it, and I think it may have come from fou.
1 4 *Just give me a second.
5 All right.
j A n ,
g 6 (Pause)
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" 7, ; I need something called 9-A. I want to show n :
! 8 you the next to the last page of Deposition Exhibit No. 3 1 t
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9 and I show you a handwritten paragraph that begins --
- i
@ 10 that is entitled " service Water Structure," and the first l Z i
- i i
5 II sentence is: " Service water structure underpinning with 3 l i 12 ; driven piles and the corbol is a positive solution." l
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13 I will ask you if you have ever seen that l 5,
3 14 i
i 2 before?
15 Yes.
2 , A ;
l E I0 Is that'your writing? l s I' C 17 I w
- A Yes. I f
3 18 .
G Can you tell me what you mean by positive ,
19 i solution? ,
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, A In the context in which it is used here, t
21 the ciles can be driven to have a certain load carrying 22 l capacity, and the portion of that capacity that we wish 23 to have jacked into the structure can be installed.
I 24 i MR. PATON: Would you read that back, please?
25 > (Answer read) 1 i ALDERSON RE.*ORTING COMPANY. INC. !
1 l
I
.. . l 39 i .
I 3Y MR. PATON: (Resuming) 2 4 Have you reviewed a seismic analysis of the 3 service water structure as underpinnec -- as proposed 4 to be underpinned?
e 5 x go, N '
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2 6 % Do you -- is that within the scope of your n I 7, responsibilities? I n
0 k L No. f 9 4 In the course of your consulting 3echtel with
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z 10 respect to the proposed remedy at the service water .
3 Il structure you do have knowledge of seismic loads, is 3
.a 12 that'~ correct?
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h I3 A That is correct that I do have certain input (
=
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I4 information that may be used by project in making its ,
e I c 15 analysis. l
- . l j 16 ' 4 Can you tell me why you would not review the ;
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$ 17 seismic analysis of the structure? !
u.
18 A No, I cannot.
o : 1 s 19 4 Is the capability of the piles within the a
, 20 seismic loads within your responsibility?
21 A Yes, within certain parts of it.
i 22 l 4 What parts?
23l A Load carrying capacity, perhaps portions of ,
i 24j the deflections.
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25 c All ri:ht. You have cart of the responsibility
)
1 1
l ALDERSON REPORTING COMPANY. INC. !
i 90 l
' I for capability of piles under seismic loads. Do you knew 2 who has the other part?
3 Project structural.
A 4 And you said part of deflections. The other
?
5
$ part of deflections is for project structural?
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A Yes. '
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" 7 What criteris do you use in your assessment !
4 '
i 8 A of the seismic deflection of piles? !
= .
~- 9 A No criteria. I do not have any criteria,
?- ,
g 10 nerely furnish information as to what the stiffness of
=
!3 II the oiles might be under certain conditions.
That is E
12 input information used by project structural for their >
13 analysis in which the deflections are output along with i
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= 14 .
g o t.ner thtngs. ;
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15 4 Do you have to know within the scope of your !
i j 16 resconsibilities what the safe shutdown earthquake is? j s -
i
- 17 t d A No, I could do what I am doing withou- t
= ,
E IS knowledge of that. i
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19 Are there sandy soils under the service wate-
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i 21 The borings show that there are.
i A l -i l
22 l .
O In the event of an earthquake, is it possible l 23 l thatthey would liquify?
24 1 4 A Yes, it's also possible that they would not.
25 ' Ckay. In the event that they did liquify, G
I i
i
! ALCERSON REPORTING COMPANY. INC.
L
91 f i
I I would lateral drag forces be i= posed on the service water .
i 2: scructure? f 3i A I don't think I know what you mean.
4 Would lateral forces be imposed on the service
? ,
j g 5 water structure?
n 0 '
5 MS. BLOOM: On the structure?
R
" 7 MR. PATON: Right, that's what I said.
i i 8 l n THE WITNESS: I'm afraid I don't understand I
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~ 9 your question. Can you try it agein? ;
z.
5 10 3Y MR. PATON: (Resuming)
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$ II G In the event of liquifaction, would it be m
i 12 ' possible for the fill around the service water structure
=
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13 to move toward the pond excavation, causing friction on T
E I'd the walls of the service water structure?-
j
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15 A It would be highly unlikely that there would i 1
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16 ' be any significant movement of the location at the piles.
- 17 MR. PATON! Would you read that back, please?
! 3
=
18
_ (Answer read) 2 19 3Y MR. PATON: (Resuming) ,
a 20 0 I asked you about the walls of the service 21 water structure, and I understood your answer to be it j 1 !
22 l would be highly unlikely that there would be any movement [
l 23 l in the location of - the piles . You mean on the walls?
i -
24 j A At the location. t i i 25 j ? At the location.
l !
I ALDERSON REPORTING COMPANY. INC. l m ._
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1 A Right. }
I 2,
i MS. 3 LOOM: I am not sure the memo -- the top j 3 was just the thing that was introduced into the record 4
as Exhibit 4. I am not sure the rest of the exhibit was ;
a 5
- marked into the record. i H
~
6 '
- MR. PATON: Let's delay that for a moment.
R R 7
- : think I am going to get into the attachments and then I N
8 8' n will do that.
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9 j MS. 3 LOOM: All right.
10 j SY MR. PATON: (Resuming)
=
2 11 g C Dr. Davisson, you said a minute ago I believe l fI
=
that it would be highly unlikely that there would be 1
i 13 any movement of the wall near the pile from the -- resultingt n
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$ from the liquifaction -- let me back up.
s I
I asked you would it be possible in the event l
' I 16 of liquifaction for the fill around the service water i n
I F 1:7 structure to move toward the pond excavation causing :
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l E 18 friction in the walls of the service water structure, ;
- i 19 ' and I think you said it would be very, very -- or highly j ;
I 0
unlikely that that movement vould be felt in the walls l t
21 j near the piles, is that correct -- and I don't mean to
.i 22 '! l
'mischaracteri e.
I 23 I don't think you have accurately -- repea:
A ,
i 24 -
l your statement.
25 g Could you tell me what's incorrect about i:7 I,
1 ALDERSON REPORTING COMPANY, INC.
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93 l l
I A You are talking about the soil scving toward 2 the walls or something. !
3 G I don't think I said that.
4 MS. 3LCOM: Why don't we have the question ,
c 5 read again then? !
9 i j 6 (Cuestion read) l R
E 7 THE WITNESS: I think your earlier question
! 8 asked about the soil moving against the piles, not the l 0 i U 9 wall.
- 3. .
10 !
@ MR. PATON: I don't think -- I read the same '
E W I 3 II : question, f 3
j2 .
E I will just start all over again.
=
13 l
S gee.s go off the record for a minute.
2 14 (Discussion off the record) !
E !
g 15 MR. PATON: Okay, on the record. l
=
E I6 SY MR. PATON: (Resuming) s N I7 0 In the event of liquifaction, would it be I l
}c 18 possible for the fill around the service water structure '
i 6
g I9 to move toward the pond excavation causing fricti-on on l
t
- "O the walls of the service water structure? !
, i 21 A Eighly unlikely, and if it did occur, irrelevant.
22 So that you have not taken this into account?
G 23 ] A That's not my problem.
l 24l1 I 0 Whose problem would that be?
25 i A Project structural and back to geotechnical --
{
.4
! ALDERSON REPORTING COMPANY. INC. '
l
, 94 I . hat's act what am involved with.
2l ? Are the piles being designed for lateral leads?
f9 3; A They can withstand sc=e lateral icads, but 1
4 lit's not intended that they have Oc have either lateral
}
g 5 supper for their integrity, nor am I aware of a icad n
6 alcng their side that they are being designed fer.
2 '
" 7 s it your opinion that there is no seismic 4
! 8 event that could impose a lateral lead en the piles?
e 9 A No, we can always sche =e .up an event that would.
z 2 10 : dare sav we'd have a lo: cf.proble=s at . Midland and z
=
II 3 in the United States if that ever cccurred.
3 i
12 ' 3 Ckay. I think you construed my questien, and
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13 =aybe rightly so, as is it possible, but are the piles j 5
3 g
14 going to be designed to withstand any lateral leads f i
e .
- 15 t from any seis=ic event? ;
x e g 16 A Yes, any relative deflections that sight
= -
f.
M 17 I take clace between head and base -- r
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I I8 e l's sorr;*, what?
i "s 19 A Any relative deflections that might take n ?
20 place between head and base would induce loadings in l 2I -
the pile. .
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4 .
"g 99 What seismic leads are the piles going :0 be
- 3 i
13 i designed : withstand?
- 4
' '! A Scmewhere in sc=e of the dccu=ents there are 25 sc=e numbers tha: project structural has cranked off as 1
< ALCERSCN REPORTING COM,8 ANY. INC.
! 95 l l
t 1 to what the dynamic increments are. I don't recall l i
l 2 what they are off the top of my head. j i
3* a Is that information that you need in your 44 assessment -- in your work?
e 5 A Yes.
- n '
i g 6 4 What do you need it for?
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$ 7 A Cause I have to knew what the piles are to be
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! 8 installed to resist, i 0
- 9 G When did you get that information from 3echtel? I z.
10 ' A The most recent information I had was the I 1
lin 11 middle of December of 1980. !
"E' 12 4 I show you a document that looks like it's ,
=
13 about fifteen pages; it's an attachment to a document that f' a
n 5 l'8 has been previously marked Deposition Exhibit 4, which j
- i j
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15 appears to be a note from you to Dr. Afifi. i j 16 The attached document is entitled " Technical
- I II Specification for Furnishing, Installing, and Testing :
l l c !
18 Closed End Pipe Piles."
3 3
I 5 I m
19 MS. BLo0M: Is there-a date? '
a l
' 20 MR. PATON: There is a date, and my guess is j 21 that the date is October 21, 1979, it's very hard to ,
22 read.
23 BY MR. PATON: ( Re s umin'g) !
! l 24 g I will ask you if you have ever seen thst l
l
( 25 :l document before?
l 1 i j ALDERSON REPORTING COMPANY. INC. :
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I i i I A Yes. I I
2 Can we go off the record? i i !
4 3t MR. PATCN: Sure. Off the record.
4 (Discussion off the record) c 5 3Y MR. PATON: (Resuming)
E !
5 0 Dr. Davisson, I show you another document that i R
5 7 I will mark Deposition Exhibit 6, Davisson, 1/14/31.
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$ 3' This appears to be thirty or thirty-five pages. This one
{
- $ I
- 9 < is labeled " Technical Specification for Furnishing, z.
- I a 10 Installing, and Testing Closed End Pipe Piles," and there !
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i Il ' is a handwritten note on the front of it from P. K. !
m .
12 Chen, C-h-e-n, dated December 3, 1980.
i ;
3 l 13 I want to read the handwritten note on tho 5 il
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m I4 front: " Tom: This is the final spec to be issued for 5_
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[- 15 , bids. Please review as soon as possible. I will call
= 1
- i i
^
i6 , you to find out what is your comment and also the date i l
II of the meeting to discuss the spec if necessary. Thanks. I i
, } 18 Call me if you questions." {;
j 19 (The document referred to was i
~ 20 ' marked Davisson Deposition 21 Exhibit No. 6 for identifi-22 cation.)
23 3Y MR. PATON: (Resuming) l 24 G Have you seen that document before?
- l 25 f A Yes, and I think you may have given-the wrong dade i
i ALDERSON REPCRTING COMPANY. INC. :
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I 4 Okay. I see 12/9/80 on there. Is that incorrect?
2 A I thought you said '31. !
3 ? Oh, :. f I said that, I would like the record 4 to show that's an error and it appears to be December 8, i
5 1930, n,
n .!
j 6 A 12/3/80 is the date of the handwritten note. i R
!. 7 Okay. Do you agree with Mr. Chen's comments 4
c A
8 that this is the final spec? l 0 i 2 9 A No. !
?, -
I jz 10 ' G okay, why don't you agree with that statement? l I
3
] II A well, that's why we had the meeting. It was 'l
.- 1 12 to discuss. !
i j 13 g This is not the final spec?
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s A No.
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N I7 A Yes.
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$ I6 ; a What happened at that meeting? i J E g
I9 A We went through that specification. People :
- 20 from project, geotechnical, and'a gentleman from Mueser-I.
Il Rutledge firm was there.
22 Nhat was were there any adverse comments l 4 --
23' or any opinions that indicated that this needed to be t
4 6%4 revised? - !
25 l 1 Yes.
L ALDERSON REPORTING COMPANY, INC. I
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s . % '
98 1 G Who made those comments?
2 MS. BLOOM: Clarify what it is -- opinion on ,
3 , revision or whether they were adverse comments.
t 4 MR. PATON: I did ask two questions of you.
e 5 I'm sorry.
A j 6 THE WITNESS: They were probably both. There ,
R 7; were comments thrown out and someone said delete this, I
$ i 5 i j 8 and if you want to accept that as an adverse comment, it's !
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9 an adverse comment.
Y l
@ 10 BY MR. PATON: (Resuming) 3 h 11 G What's the present status of this document?
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12 A I am operating under the assumption that Y '
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13 project is reworking the specification based upon the l,
a 14 comments they received at that meeting.
5 l
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a 15 G Tell us any comments that were made at that j
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n d 17 MS. BLOOM: Aav comments? I
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18 MR. PATON: Yes. I assume he is not going to i i
g 19 ' tell me --
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20; MS. BLOOM: Any comments about that --
21 MR. PATON: Any comments with respect to this j l 3 i
22 document. ;
L 23 THE WITNESS: There were several that are 24 written in the margin of that document that I made~ and ;
25 l there are innumerable comments that other people made that !!
I ALDERSON REPORTING COMPANY,INC. '
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.. s . . l 99 !
l l
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\ l 1 .may or may not have marked in the draft, and the contents l 2 of which I frankly don't remember at the moment. .
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3{ BY MR. PATON: (Resuming) 4 G Okay, can you remember any of the comments e 5 that were made by you or anyone else with respect to n
M i j 6 this document at that meeting? !
E i 7' A Mine are in the margins.
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-J d 9 to get them is to go through the document?
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@ 10 1 That's right. I would have to look at the 3
)3 Il document and read them to you.
Y I2 g Well, as a matter of fact, yes. Are the ;
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y 13 comments that are written in here -- are these all yours? j
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15 and if those were in red, they were mine. l i
f 16 G Okay. Would you help me out? I don't have i 1
U 17 any way to -- is that your comment? I am referring to a
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$ 18 page four.
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s I9 MS. BLOOM: Cf Exhibit 6?
5 20 ' MR. PATON: Yes. !
l !
2I THE WITNESS: Yes, these look like my comments, j 22 yes.
I i
23 3Y MR. PATON: (Resuming) ;
l '
I 24 G What is that comment?
I 25 l A It's questioning the spec on the reinforcing I
i l ALDERSON REPORTING CCMPANY. INC. !
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bar and whet'~.er or not there was a redundancy of the wording, l
21 ef the spec. j 3
G Was there any resolution of that item?
4 No, there was a comment that structural was A ,
I a 5 to take and work with it and resolve. ,
n s.
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6 Tell us about your next. Is that word e G Okay.
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"whv"?
Is that your comment? ,
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i 8 n A It has a plate, closure plate, that's flush l g.
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with the pipe and I raised the question as to why ;
- I
- 10 j somebody stuck that in there. !
t 5 11 ' I
< g Was there any discussion of t.at i item? -
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A Yes.
1
- 13 '
C What was the discussion' 3 14
@ A Well, I found out who put it in there -- the e
9 15 2 Mueser - Rutledge people.
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! d 17 1 They thought it would add to the capacity of
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5 18 .
- the pile. ,
19 3 g Did you agree with that? i n
20 It didn't matter to me one way or the other.
A i 0 Is that going to stay in there as written? !
I 22 !
A I don't recall how that was resolved. It was I
i 23 not considered that important an item.
i l 1
l Is that something project is working on?'
' 24 -
l S 25 l A Yes. [
l i
i l ALDERSON REPORTING COMPANY,INC. i
.. s 101 ' '
s i
f 1 g Would you tell us what your next comment was? ;
, i 2 A On page five: "We have considered several ; !
3 l alternate pipes with diameters and wall thicknesses, 4 and depending on certain selections that are finally I
e 5. made by project, one of these other alternate pipes will 9
j 6: be used." g R
i 7 g Could I see that a moment?
j 8 A Yes. ;
J 2 9 These deletions at the bottom half of the
- , 4
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y: 10 page, have you addressed those and are they yours? l E
h II A Yes, this particular group are mine.
l 3 l
'd 12 l MS. BLOOM: These are deletions at the bottom l
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g 13 of page five of Exhibit 6? .
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5 14 MR. PATON: Yes.
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15 BY MR. PATON: (Resuming)
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g 16 q Would you tell us why you deleted those words?
A i $ 17 A Change from wrong to right.
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, G That isn't particularly helpful. I assumed [
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19 you were going to change it from wrong to right.
a 5
20 l 1 As it was written it was incorrect, that's all, 21 and I can't read'what some of those words were. ,
22 g I want to know why you changed it. ;
23 A Whoever wrote that section didn't.have a l
24 sufficient understanding of the operation of the hammer !
! ! l l
l 25 land made a couple of misstatements.
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i 1 ALDERSON REPORTING COMPANY. INC. ;
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I 4 Could I see that? l 2 A Yes. i 3 G What mistake did the person make?
4 A It says the valve mechanism of air hammer g 5 will be so maintained that the position of stroke, length .
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j 6 of stroke, and number of blows per minute for which the R
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I 8 That statement is incorrect because it is not
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9 the valve mechanism that you maintain to cause this to
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@ 10 be true. f E
11 Okay, thank you. j 5 4 m
12 on page six, is this your change here from j i i
^ n 13 ' 37,500 foot pounds to 37,375 pounds?
l l s" I4 A Yes.
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15 Why did you change that?
4 g 16 , A Secause there is a commercially available l n r, I7 I N hammer of 37,375 which would be-ruled off course -
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5 18 i one were to read 37,500 with that degree of rigidity. j
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19 Resulting, I assume, in unneeded expense if g 4 n
. 20 you tried to purchase one at 37,500, is that correct?
2I , A That's correct.
22 0 On page six in paragraph 7.1.5 you changed l 23 -- I will ask you if you changed driving caps to 24 drive --
- ?
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'S I t A Heads, I believe.
i 1
1 ALDERSON REPORTING COMPANY. INC.
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1 G Drive heads. If that's your comment, can you .
2 tell me why you made that change? !
l 3 A For clarity. Talking about cap blocks in 4 here and driving caps, and I see all sorts of confusion i
e 5 that can arise because driving caps is not the term I s
j 6 that's ordinarily applied to what is usually called a
$ 7 helmut or a drive head.
X j 8' G Do you know who prepared these suecs? Were C !
O 9, these prepared by Bechtel? ?
?, '
@ 10 ' A Yes.
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]3 11 G Do you know who within Bechtel? ,
d I2 i A No. .
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j 13 G Do you krow whether -- is it Mr. Chen or Dr. Chen?-
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5 14 1 I don't know.
_~c E 15 G Do you know whether he reviewed them?
$ i j 16 A I am certain that he has, but --
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su 17 MS. BLOOM: Can we go off the record? l E l 5 18 (Discussion off the record)
E !
g 19 MS. BLOOM: On the record.
5 20 ' BY MR. PATON: (Resuming) 21 G Is there any date for finalizing these j 22 specifications that you are aware of?
1 23 A No, I am not aware of what anybody's schedule ;
~ I 24 is now. l
~i f 25 ; 4 In the paragraph on page six numbered 7.2.1 !
I 1 ALDERSON REPORTING COMPANY. INC. >
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I I see a comment -- I see two comments. One is " reword,"
2 and one is "cannot do."
3 Would you address the cannot do first and tell I
4 I me what it is that you cannot do? ,
4 5
$ A "The pile shall be supported in rigid leads I *l a j 6 that extend to within two feet of the elevation the l R=
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" 7 pile enters the ground." !'
i 8 '
n That cannot be done with the system that we c-9
~. are going to use to install these piles, which involves 0 10 fj having the hammer and the leads above the roof of the '
= ;
!3 II service water cump structure.
12 i G Okay. Would you tell me.why you want them to 13 f reword that first sentence? What is~it -- is it misleading, 3 14 3 or wrong, or what?
u 15 g A .Well, it's a ridiculous requirement limiting l 16 a
it to a handling str of 21,000 psi. .
- ' 17 I d 4 Tell me wh 2 st is ridiculous. Tell me a ;
= i
$ 18 ':
_ little more. I understand your-conclusion, but what's i 8 !
3 ridiculous about it? l l
20 A If you pick up the pile and you haven't put !
i 21
. a sweep in it, then you have picked it up satisfactorily. l 2
C On page seven you have deleted paragraph i
23 7.3.6 and you have the word "why." What exception did t
24 I
you take to that paragraph? '
25 ' A Somebody's probably been reading the literature
- f i ~
1 ALDERSON REPORTING COMPANY. lNC.
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! 105 '
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1 l
I, and applying the latest fads and fantasies and wanted to 2 use bitumen as a means of reducing any skin friction, !
4 3 jparticular negative skin friction, that conceivably could 4 develop. I suggested that we not use that approach.
g 5 G Is bitumen coating not effective? {
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j 6 A rei s effee 17e, ;
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E 7 G For this purpose?
A j 8 A Yes. !
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G It is effective? j i
e t y 10 A Yes. I z ,
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G Why are you deleting it then? I 3
y 12 , A Because we have decided to eat the load rather !
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g 13 than try to f asten i t. There is a great deal of care
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15 dare say that it looks now that Midland _may not get j i
j 16 built if you got into that operation for a lousy sixteen j i
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"2 a m.iles. .
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{C 18 0 br. Davisson, I see some notes that follow. i i
"g 19 Page seven -- under your name or letterhead dated 12/15 --
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20 ' are these notes that you inserted in these specs after l 2I you received them? ]
22 A No, that was a loose sheet that had my notes 23 j en it that I made during the meeting. :
i 1
24 j q These were included in the tech specs when ,
i 25 i you received them?
i i ALDERSON REPORTING COMPANY. INC. *
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1 A No, I made these notes during the meeting where ;
2 the specifications were discussed, and it happened to be 1
3I loose, lying with this spec, and whoever copied left i:
4 in the same position and just stapled L: in.
t s 5 4 I see. Do the notes refer to the tech specs?
?.
I j 6 A Probably.
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$ 7 O The subject of these notes is the tech specs?
n j 8 A (Pause) a 9 Yes. in part they do.
5 10 % okay.
3 j 11 , A Particularly the part where I recommended -j i
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j 12 against the bitumen.
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15 the words over here that seem to begin with the word 3
j 16 " check"? What are those words on the left side? Can s
$ 17 vou read that?
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E 18 1 Somebody had a recollection that a represen-t !
$ 19 tation had been made to NRC about redriving tha piles. ;
M 20 ' I think the suggestion was that we doublecheck that this
! i 21 is consistent. j l 22li 4 Okay. Have you made-any other comments with ! ,
l 23 l respect to these particular specifications other than
~
24 what are listed in this Deposition Exhibi 6?
25 '; A No, that's the last thing that'was done.
i i ALCERSON REPORTING COMPANY. INC.
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t 1 G On page thirteen in paragraph 11.2.2, the. i 2 first sentence reads: "Where anchor piles are used the 1 3; arrangement shall consist of at least fo ir piles with a I
4 minimum of two piles on each side capable of resisting i
5 a load a minimum of 300%," which appears to be changed l
[- l H
j 6 to 150%, but I'm not sure, "of the design capacity of ;
" l 6 7lthe test pile." i 4 - l n
! 8 Did you make a change there from 300%? !
4 0 i
- 9 A Yes. .
4 Z.
I-e 10 G Can you tell me why?
z l
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5 12 ) side, you take 150% and the total of those make 3001.
t
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w 5 I4 G Okay. You look at that more as a grammatical e
g 15 erra;7
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g' 16 A That's for sure.
l a On page fifteen on the righthand side I .
U I7 G Okay.
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E 18 near section 11.5, I think I see the word " unclear."
t 19 l "s Is that your word? !
\
M 20 A Yes.
21 G What is unclear? .
22l A Well, it icoks like they were going to make 23 pull out tes on a pile that had been driven for a
~
24 j bearing test, and I don't think that is necessary. We. ,
, i :
25 i were going to have one that was driven -- for one pile J
l >
! ALDERSON REPORTING COMPANY. INC.
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I.
I that was driven short through the fill material only for i
2 purposes of getting the measure of negative skin friction.
3 i G You said through fill -- you mean to the till, don't you?
5
$ 1 Through the fill and to the till. [
n .
j 6 0 Okay. I thought you said through the till. !
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- Would you explain this comment to the left of i N 1 i 8 n 11.6
- " Add NSF test" something, increments. '
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A Add the negative skin friction test. That is 3 z_-
10
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the one I just alluded to.
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!8 II G All right, I see. To the left of paragraph !
l 12 i 12.1, " Rewrite per 12/15/80 meeting note." Would you ,
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13 I' explain What that means? '
g 3 14 I E
A All right. There was a long discussion on !
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15 t ;
transferring load, and a lot of notes were-put on the j
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16 !
8
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blackboard, and project took these down and they are i
1 l'7 d supposed to rewrite that section. l'
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G Okay. The subject that you are talking about --
+
19 i j you say a lot of notes -- about what?
l 20 '
l ,
A Transferring the load'-- jacking the load ,
21 into the structure. !
22
, G I see. Who was going to undertake that i
I 23 rewrite --
project?
,4l 4 - i
- 1 Yes. ,
i
^
! C Did you find anything wrong in your opinion l
l i ALDERSON REPORTING COMPANY. INC.
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, . 1 100 I
I I with what had been proposed within these tech specs? ,
2 A This one left it to the subcontractor to work 3 j out the transfer system, and while this might be satis-l 1
4 jfactory in the real world, it's unsatisfactory when you '
1 y 3' have to spend a lot of your time taking care of spoon- .
n 5 0 feeding the NRC.
R
" 7 So, it was necessary that this be laid out in M .
! 8 more detail, and got into position that it would be f e
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9 deemed defensible based ucon a cresumotion as to what it 10 t
z is the NRC wants now. !
_! II G Dr. Davisson, I have got to respond to that, a
12 because that't the second time. You think the NRC is .
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13 being unreasonable in its requirements, for example, as l' 5
I 3 14 I 2
to the service water structureo ;
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15 I am not tota'.ly sure.that I know what j t A ,
16 f requirements they might have on their minds.
m u i 1:7 Is that because they seem to shift from time
- j g i
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19 They've not been communicating with me. We ;
i A .
n 20 don't work in a system where communication seems to be II 4 the order of the day.
J 22! @ You have expressed on a couple of occasions 23 l some unhappiness, at least I construed it, with NRC 24 requirements. Is that because you think -- well, because i
s 25 whatever requirements you ere aware of are unreasonable? i i.
? ALDERSON REPORTING COMPANY. INC.
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i 4
1 1 Yes.
l !
2 i. G I didn't hear you. I i
1 3 A We have seen the unhappy spectacle of regula: ion 4 I by the lower-level NRC employee. That does not leave i
e 5 one with a very good taste.
n
- M
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g 6 MS. BLOOM: I don't know if we want that in.
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$ 7 MR. PATON: Oh, I think it's right on the money. ,
- i M
j 8' Dr. Davisson.is entitled to his views. '
c 3 9 MS. 3 LOOM: Yes, but --
2, ;
y 10 MR. PATON: And this would be -- f 3
- .i
]3 11 MS. 3 LOOM: If it pertains to the service I 12 water structure, that's fine, but -- -
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13 MR. PATON: This would be clearly admissible
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- i E 15 admissible evidence, this is -- ;
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t g 16 MS. 3 LOOM: If it pertains to the service j l A 1
d 17 water structure, it's --
I d
G 18 , MR. PATON: Sure, that's what he's -- that's ;
=
1 + l g 19 what I am asking. =
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20 3Y MR. PATON: (Resuming) l i
) 21 j G By that last answer, I gather you indicated
'l i
22 ) that you had some rqquirements imposed by a low-level l
i 23 l NRC employee that might not have been imposed-if the i .
24 ) decision had been made at the higher level of manag~ement.
l 25 , Is that.what you are indicating?
i e
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i ALCERSON REPORTING COMPANY. INC. !
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I 1 I would hope that is the case, yes. ,
2 G Who is that lower-level employee? ,
3 MS. BLOOM: Well, we haven't established -ha 4 it relates to the service water structure, and we have s 5 agreed that's where Dr. Davisson's expertise runs.
n 5 0 BY MR. PATON: (Resuming)
K
" 7 What NRC employee did you have in mind?
4 A <
! 3 MS. BLOOM: Again, let's establish that it !
O ,
9 has anything to do with what we are talking about first,
?
L- 10 and then go on from there.
3 II 4 BY MR. PATON: (Resuming) !
3 l
- i 12 Is your unhappiness with the NRC related to E 4 i
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3 1 5 13 this -- I assume it's related to this project, the Midland ~
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m 5 I4 the remedy for the soil settlement problem, is that ,
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15 right? I
- 1 g 16 L Y e s ..
A !
I7 G Okay. What employee is that? l
= l 18 MS. BLOOM: Again, we haven't talked about the I
, 3
- t 5 i 2 19 ,' service water structure, and that's what we are --
M 20 ' MR. PATON: I don't care --
2I ,
MS. BLOOM: That's what we are talking about nowd j '
22] MR. PATON: I don't care. Dr. Davisson has I 23 some unhappiness with.some low-level' employee, and I ,
24 vant to know who it is. That's clearly admissible, even 23 ; at a hearing, and even more admissible at a deposition. >
d I ALDERSON REPORTING COMPANY. INC. l
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1 MS. BLOOM: Well, no, I doubt it. If Dr. ;
2 Davisson doesn't like the guy because he ran over his ,
3 foot or something, --
let's get a foundation.
4 MR. PATON: I think he clearly indicated that c 5 he has some requirements that came from a lower-level N t
~
j 6 NRC employee that he doesn't think would come --
R
$ 7 MS. BLOOM: No, I don't think he clearly --
M e j 8 put a foundation down. l
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9 BY MR. ?ATON: (Resuming) '
I 5 10 Q. Dr. Davisson, what NRC employee were you j E i b 11 referring to?
y f a
y 12 MS. BLOOM: Again, put down a foundation. i
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13 4 3Y MR. PATON: Now wait a minute. Now listen.
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d 14 If you want to instruct his not to answer, go ahead, but i b
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15 I'm asking him the question and I want an answer. j
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j 16 If you're going to instruct him not to answer, s
t U 17 that's certainly your right. ;
5 1,
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18 MS. 3 LOOM: I'm not going to instruct his not l l
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$ 19 to answer if you put down a foundation and we get to n
20 what we are talking about -- what it relates to, and 2
21 what area we're talking about.
.i 22 MR. PATON: Okay. l l
3Y MR. PATON: (Resuming) 23l
~ '
24 ? What is the area of involvement of this NRC
! i l 25 , employee that you have some unhappiness -- or that you i
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113
. i 1 I say imposed some requirements that might not have been ;
i' 2
required or imposed if top-level management had been ;
3
. involved?
4 A Well, I heard him speak at a hearing trying e 5 to impose borings on us that we had no use for, and I ,
n ,
~
6 a have read depositions that indicate a great lack of n
R 7
- knowledge about the subject area in which he is making ,
a 1 a
5 8 !
decisions. i d .
- 9 j G !s his name Joe Kane?
6 10 3 A Yes. l
= l E 11 1 And are you aware that Consumers took an l g G ,
d 12 I g ,
appeal, an internal appeal within the NRC, having to do E 13 i with those borings, and we are still asking for borings a
= 14 d after the matter was reviewed by upper-level management?
= ,
F 15 2 A I have not been informed in writing as to l
= l T 16 3
2 what the outcome of all this is. I will accept your y 17 .
a representation.
=
E 18 .
% Okay. You read the depositions -- what i j 19 decisions, or opinions, of Mr. Kane did you not agree >
20 with? .
I 21
, MS. BLOOM: I think he said what ocinions and i
~
22 f decisions he didn't agree with. I think he said the t '
23 ' ,
corings.
24 '
MR. PATON: The borings is hardly --
25 ' Additional borings.
MS. BLOOM: j i
i i ALDERSON REPORTING COMPANY. INC. !
l
114
- I 1 MR. PATON: --
an apt description of what he 1
2 disagrees with. l 3 Ms. 3;COM: Additional borings.
4 3Y MR. PATCN: (Resuming) i e 5 g What about the borings don't you like? What S l j 6 about Mr. Kane's comments about the borings.
R
= ,
t ' 1 Insread of gracefully backing away from an j 8 indefensible position, just brute force go forward o i 9 with it, and it's a ridiculous situation.
Y 5 10 The next piece of information that is really z
=
j 11 , required is drive some piles and run some blow tests and 3
i 12 see what that provides us with, and whatever information !
i 13 that provides us with relates to soil properties so much
=
z E
I4 better, it's much more accurate, and much more useful j= 15 than anything Mr. Kane could conceivably come up with.
j 16 g Did you ever hear that this request for z
l @ 17 borings initiated from the Corps of Engineers?
l a
=
w
> 18 A Yes.
- m
- 19 g g Why do you put it all on Mr. Kane instead of' n ,
20 the Corps of Engineers?
21 ;
l ,
1 I guess he's the focal point. ,
I .
22 ' q You mean you think he should have told the {
\
i 23 Corps of Engineers to change their mind? l r
, . i l 24 MS. 3 LOOM: Wait a second. I don't think -- l i
i ! i l 25 i I don't know if he can answer what Mr. Kane should have 3
t l i I ~
1 ALDERSON REPORTING COMPANY. lNC. I L
, i 115 e
i 1 ' done or what Mr. Kane's responsibilities are, i
2 MR. PATON: Well, if he can't, he can't.
3 MS. BLOOM: You asked him at a professional 4 level why he disagreed with Mr. Kane's request for f
s 5 additional borings and he answered it. Anything beyond E !
j 6 that is not relevant, I.think, and I don't know if we E
7 should go into it any further. j i
2 A 3 3Y MR. ?ATON: (Resuming) !
5 2 9 % De vou know that the recuest for borings f z, f h 10 came from the Corps of Engineers? l z '
j 11 MS. BLOOM: He answered that question. I a
f 12 THE WITNESS: I heard that they wanted some 4
g 13 additional borings.
=
n 5 l'4 3Y MR. PATON: (Resuming) 2 g 15 4 Do you disagree with their position? ,
=
j 16 A Yes.
m a
17 G Dc you have any trouble with the competence of
=
5 18 the Corps of Engineers as a consultant to the NRC? l
=. '
8
- 19 A Yes.
5 20 g You do? ,
t 21 A Yes. f.
I i
22 ]- 4 Phat do you base your difficulty with their !
23 competence on? .
24j' A- On the requests that came forth. -
f, i
l 25 , ? Anything else?
i
~
l ALDERSON REPORTING COMPANY. INC. j
. r 116 i 1 -
I I A I can't think of anything else right at the l 2 moment.
3 ,' O. In your opinion are the NRC requirements in 4 ; Midland -- do they exceed those for the piling at Bailly?
4 5 MS. BLOOM: One moment, what NRC requirements?
H j 6 MR. PATON: If he doesn't know, he --
R
$ 7, MS. 3 LOOM: No, there's a lot of requirements.
$ 8 There is the regulations called requirements, there's e '
9 MR. PATON: That's fine. I ask the questions I
3 10 and --
z , ,
t
_h Il MS. BLOOM: Lay a foundation -- l 3 I I I2 MR. ?ATON: And he answers the~ questions, and f
=
g 13 if he can't --
=
x 5 I4 MS. 3 LOOM: Lay a foundation. It's not a t
j=
- 4 15 very clear question.
j 16 MR. PATON: If he can't answer the question, s
f =
II that's fine. By this time --
- I8 MS. 3 LOOM: I'm objecting to form. What e
2 I9 requirements are you talking about?
n 20 ' MR. ?ATON: Okay. Could you answer --
2I MS. BLOOM: What requirements are you talking {
e 22 2 bout -- for the diesel generator building, for the 23 dike, for -- ,
i 24 MR. PATON: Fine, I understand your obj ection.
'73 i BY MR. ?ATON: (Resuming) t ALDERSON REPORTING COMPANY. INC. !
- /
1 117 >
4 1 1
I G Will you answer the question, please?
2 A Let's go back and find out what that question i
3 'wa s ,
i.
4; G Okay. In your opinion do the NRC requirements I ,
c 5 with respect to the piling at the service water structure g 6- differ from the NRC requirements for piling at Bailly?
R b 7 MS. BLOOM: I don't think there's oeen any M
$ 8 comparison between Bailly and the service water structure 1 9 at all.
?
@ 10 MR. PATON: He has already testified he acts
_3 '
@ II as a consultant on the Bailly case.
3
- 5. I2 MS. BLOOM: Excuse me, but there is'no i
=
5 I3 comparison. I
=
m 5 I4 MR. PATON: If he says there is no comparison, l j
15 fine. I as asking and he is answering.
, s g 16 THE WITNESS: First of all, they are different n
i
(
i U- I7 projects for different purposes. However, I have been j d
C f
. 3_
18 , assuming only that the requirements would reasonably be :
i E
a l9 consistent. I have not heard that NRC has said what-the >
l 5 l 20 requirements would be.
j 2I 3Y MR. PATON: (Resuming) i 22 j G You mean you don't know what the NRC re-t .
I I 23 l quirements are for pilings in the Midland case?
i
~
A No, I do not.
24) i t
25 I G You do not know?
i, i !
1
! ALDERSON REPORTING COMP ANY. INC. i
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118 I
i 1
, A I don't know that they have set any requirements.j 2 MS. 3 LOOM: I think he testified to that 3
3 ' earlier when you started out on that this morning.
4' THE WITNESS: We have been proceeding on the s 5 assumption that they would be reasonably consistent n -
N j 6 with Bailly.
R i 7, 3Y MR. PATCN: (Resuming) n
! 8 0 A general question with respect to the !
c 9 tech specs that we have been talking about. Is there any E. I f
5 10 way that you can characterize them? I think you indi- l Z .
= 1 3 11 < cated they were not final. Are they nearly final, are 3
y 12 ' they preliminary, or what, and I am talking about this l 4
j 13 document, Deposition Exhibit 6?
=
n 5 14 1 They clearly will have to go through another l
=
2 15 review, a >
i j 16 0 Have you performed any pile: load test to i 2
N 37 determine the lateral load carrying capacity of the piles x ,
= l 5 18 at the service water structure? !,
w P j s 19 A No, not that.I can recall. ;
I a 20 g Has Bechtel made any settlement estimates i
21j for the piles at the service water structure? l, I .
- 22l A Yes, certainly they have.
l !
23 ' c Do you knew --
24 1i 1 I know we discussed it..
e
! t 25 a Do you know what they are? !
l i i
, i l ALDERSON REPCRTING COMPANY. INC. l
5 1 119 '
' l i A I don't recall. -
i i
2 % Is the estimate of settlement within the l 3 ) scope of your responsibility -- reviewing thac?
3 4 ' A Yes.
i g 5 4 Do you have any recollection of when you ;
H :
6 i j did review it?
R 5 7, A Ch, I think it was considered in the fall of 1980.
A I
! 3 4 Do you review the concrete specifications for j
-J '
9 Let me take a look at it.
just a minute. ,
?
@ 10 ' (Pause)
E
= 1 4
II Do you recall having reviewed the concrete t a
- 2 -
E specifications for Midland? l 2
13 < A I reviewed a concrete specification that came 5
s I4 , in response to my request for that, and I believe it was l 5
j 15 a general concrete spec.
E I6 4 I show you a one page letter from M. T.
- 1
! $ I7 Davisson to Dr. S. S. Afifi which I am marking Deposition l I
j 18 Exhibit 7, Davisson, 1/14/81. ;
. a i a
l9 (The document referred to was l s
[ 5 20 ' marked Davisson Deposition i
2I ' Exhibit No. 7 for identifi- '.
t 22 cation.) !
I 23 MS. 3 LOOM: What's the date?
~
24 It's dated April 15, 1980. !
l MR. PATON:
l 25 37 MR. PATON: (Resuming) ,
f i
.i ALDERSCN REPORTING COMPANY. INC.
120 l 1 i
I G I direct your attention to the last two 2
sentences of that letter which I would like to read for 3
inhe record:
l 4 I "Please note that we cannot reasonably meet 5
g section 11.5 (rimit of six-foot drop) and section 11.6 n
5 0 (vibration). This should be clarified." ,
n '
= i
" 7 Did you write that letter? i n
2 3 :
A A Yes. +
d 9
[.
~
G Okay, and I show you -- I have that specification.
- i 10 '
$ if you want to lock at it, but let me ask you what --
=
!3 II limit of six-foot droo -
what does that mean?
12 E" It says you cannot meet that, what does that 13 ' mean? l
=_
3 14 3 1 That's ordinary structural concreting. It's e !
15 h the practice that's used there; ordinary practice wculd
=
16 W
z be to drop it from the top, whatever length it might be. i C 17 H
- G Oh, I see. You would drop it more than six I 5 '
'O f'
feet?
19 n
i A Yes, although that has been changed around now 20 anyway. If I may offer this, your discretion on that i 21 l material has been revised. -
i 22j G Changed? '
23 A Yes. ,
i 24 ~
3 G Okay. Dr. Davisson, are you aware _that here i 25 are current discussions going on between the Staff and ,
5
- l ALDERSON REPORTING COMPANY. INC.
l 121 '
l I Consumers Power concerning the seismic requirements !
2 for the Midland site? l 1
3; A I have heard that that is the case.
l 4 % Do you know what the status of that g 5 discussion is?
"n
- b A No.
R
= ;
" 7 MR. PATON: Off the record.
~ l
- n
! 8 (Discussion off the record) l E 9 Let's take a break now.
i MS. 3LOCM: ,
i- ,'
t z
10 (Short recess taken) i
=
!3 II BY MR. PATON: (Resuming) ;
,i 4
" 12 E G - With respect to the considerations of alter-E y 13 natives at the service water structure, was one of the
=
m I4 alternatives considered to provide a stable, solid i 5_
15 foundation support under the cantilever portion of the j 16 structure down to the glacial till rathe'r than the piles? .
1 N I7 A Yes. l 6~
}
18 0 Why was that alternative rejected? ;
19 1 I have no knowledge. It was one of the a
20 obvious options that war. thrown on the table back then, 2I ,
and I cr.n guess why it wasn't. ;
I It would have involved a dewatering operation, 22 23 and that could be rather difficult. I
- 24) 4 Do you know whether an analysis was done,to 25 l assure that the long longtitudinal bolts which will be i
ALDERSON REPORTING COMPANY,INC.
123 I l -
1 !
I t I
1 A (Pause) i 2 Okay, I'm ready to answer. ;
1 3j G Go ahead.
4i A The pile requirements as of the middle of i
e 5 December appear to be for a compression ultimate test g 6 load of 300 tons, and this includes a 30 ton negative .
,~ f
$ 7 skin friction allowance.
n
! 8 The net usable load would then become 270 tons. ,
._a 9 It appears that this is controlled by the dynamic in- '
z_. l
@ 10 crement on the piles during earthquake,which results in ;
I 4
4 Il a total load of 130 tons per pile, times a 1.5 factor j 3
I 12 , of safety consistent with Bailly, leads to a 270 ton !
3 1 g 13 ultimate requirement.
=
n 5
14 Several pile sections are under consideration l s J j
15 for driving to that load, both fourteen inch and sixteen -
t
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i h
j 16 inch,and various wall thicknesses. !
z i y 17 In terms of construction, piles would be pre- l a
18 drilled to the till -- ac.c.roximately elevation 600. t 9
l &
s 19 The piles would be fabricated over the length so tha l n f
20 they will stick up in the air far enough to come up l 21 passed the roof line of the structure, so that the i l i-22
- leads in the hammer used for driving the piles can t
i l l i j 23 operate above the structure.
t
! 24) The piles are then driven down through !
l 25 l pre-drilled section~to bearing in the till at whatever i ALDERSON REPORTING COMPANY. INC. ,
f l
l
I 126 i i
i 1
1 elevation they find bearing in the till. The piles i 2 would then be cut to an elevation suitable for working ;
3 ! below the corbel.
4 The corbel would have to be constructed --
5}inthemeantime, of course, the piles would be con-g i
t N
j 6 creted. Then the piles would be preloaded, pretested R
$ 7 before fastening into the structure.
n j 3 There is an open question at the moment for I u
9 structural to resolve as to how many of these piles that z .
c 1 y 10 we can pretest concurrently for at least two piles at j
=_
!3 11 a time, or four, and this depends upon the reaction !
j 12 that the structure can make available to us.
g 13 We obviously cannot take all sixteen piles
=
n 5 14 at one time and apply loads greater than the working u_
15 load er we will merely tilt the structure back out of
{
i j 16 the ground.
Y .
17 So, with that to be resolved, the object is ,i b-x
=
5 18 , to apply a series of loads, coupled with a series of
$ 19 hold intervals on these piles.
n 20 My notes are not complete as to what we had 21 lined out on the blackboard-at that time, but'in concept, f 22 j with some possible slight-modification of details, we l
23 ' ar e talking in terms of loading the-piles to 210 tons
~
24 and cycling tne load several times.
i 25 ! Then we will hold the load, perhaps at 210 i
l i ALDERSON REPORTING COMPANY. INC.
- 242 ,
i I tons constant, and observe pile settlement versus time '
2 j until we get to a relationship of settlement versus time ;
3 }lcha:reasonable engineering can extrapolate in the 4 ifuture, g 5 Then the pile will be locked off at a pre-n 3 6 determined load into the structure. The purpose of the ,
=
" i 7 '
5 preloading and the cycling is to get rid of creep and l'
8 consolidation deflections before the pile is 1ccked
- d
- 9 into the structure. This would occur on all sixteen
- z. i w
10 piles before the final lock-off takes place. I 3 i 2
= i II Then the piles will be locked into the i 4 t 3
12 structure, and whatever structural details Bechtel might i
=
13 have in mind overing the heads of the pile will 5 !
i T
I 14 I
?
then be constructed. l 1
0 15 I think that reasonably covers it.
h
= i g 16 G Would you explain the process of jacking and I a !
d 17
'? locking in? I' a i
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18 The corbel will be in place -- really it
$ A !
c i H
I9 ought to be called the pile cap. I'm not sure corbel ,
n
~ *O
^ ' is the correct term for what is being designed and con- \
21 structed here, and a set of details have to be designed -
1 :
22 l to allow the insertion of a jack and jacking the load 23 ) against the pile ~ cap in such a manner that we can, by 24 ;! combination or snas plates,or spacers and shims, weld .
2 -
25 ; i it in place before the load is released from the jacks. .
e l
i I ALDERSON REPORTING COMPANY. INC. j
l 126 t
1 By effecting the stress transfer -- or pardon !
2 me, load transfer -- part of the control technique !
3 i for doing this is that one can observe the differential i
4 4
' displacement between the pile and the gap or absolute a 5 as the case may be, and observe at what point a given n ,
3 6
- load is attained, and one can shim until upon release ,
i n
E 7 of the jacks this differential is attained. Once n ,
i 8 F' that's attained, it can be welder. in position and locked J
off final. ,
E 10 !
E S What is your responsibility with respect to 1 11 g '
the process of jacking and locking in?
'i 12 '
3 1 I expect I probably will have a representative
- t
- 13 I i there who will be controlling that. t E 14 d G Okay. Do you know whether pile end bearing capa-*1 I
15 ,
city is planned to be determined by soil tests in the ;
16 d drained condition?
6 1:7 0 1 No, it's going td be determined by load test. :
E 18
- ! MR. PATON: Off the record. !
+
j 19 (Discussion off the record) t 20
- BY MR. PATON: (Resuming) 21
% Dr. Davisson, I hand you a piece of paper --
22 ) well, first of all let me mark this Deposition Exhibit 3, i ,
23 *i Davisson, 1/14/31. .
94 1 i
(The document referred to was s ;
25 ! marked Davisson' Deposition ,
1 ALDERSON REPORTING CCMPANY. INC. l
127 i
i I Exhibit No. 3 for identifi- ,
2 cation.) ;
3 gy 33, rATON: (Resuming) 4 g I will ask you if you would draw a sketch 4
d 5 showing what you intend to do for jacking, shimming, n
j 6 and locking in. !
E l
i
? 7 A Okay. j j
i 8 ,7 ..cc)
J 9 I'm showing.this schematically, because this z.
3 10 cannot be finalized until our contractor is selected.
3
-! II g Okay, fine. .
3 .
12 A I am giving you the cartoon, which merely i
I 5 13 shows the cile cap bolted to the wall of the structure a .
W l z
a 14 ' or oile -- i E
g 15 g would you mind *- you pointed to something i
= !
g 16 and called it the pile cap, would you mind putting that j
- t 1'7 i H
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in? i 3 !
w 18 All right, I will call that the cap.
3 A l l : i 19 "m (Indicating on drawing) n 20 ' Okay.
S 21 Shows the pile, the pile cap, and the building.
A ,
.i 22] f
,3c, ,c3,m,31c,117 e3, 37 3 ,u11c 3,cx 21 3 p, cf i
23 the spacers that will be an integral part of the i ~
24 l connection to this cap when it is designed, a space for <
25 shims.
! ALDERSON REPORTING COMPANY. INC. :
i
t 123 '
t i
i l
I I show a mark over here that indicates a level l 2jthat could be used in conjunction with indicator rods f 1
3 l ec observe motion of the building as well as of the 4 ' pile when the jacking takes place, c- 5 These details will need to be designed
" t 6 finally when a contractor is selected for performance i E i
" 7 of this work.
~
l e$
8 MS. 3LOCM: Do you have any more questions !
~ ,
- 9 on this?
Z.
@ 10 MR. ?ATCN: No. !
z i
3 II ! MS. BLOCM: I want to get it copied.
3 !
E 12 SY MR. PATON: -( Re s uming)
=
g 13 Were you involved in the decision to sur-
=
a I4 charge the diesel generator building? l, 5 15 g 30, t
j 16 g Sefore the surcharge placement, were you a
h II aware that the diesel generator building had shown
- I j-18 several cracks? .
(
"a 19 1 I can't say that I was. It was not my i 5
20 project, and what I heard about it was perhaps less f 21 conversation than it was by osmosis. ;
22l 4 Do you know whether any consideration was I
- 3
}' given to the possibility that the building cracks might I - ,
24 j widen as a result of surcharge? i 25 ; g go, ,
t I
i ALDERSON REPORTING CCMPANY. INC. ;
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. . I a .
129 ,
i l i
I G Did you have any input into the seismic l 2 analysis of the diesel generator building' I
3 .t 30.
4I C Were you involved in the decision to remove s 5'the surcharge load from the diesel generator building? :
- i ,
H j 6 go, j A
R~
" 7 To your knowledge, who -- do you know who G
$ 8 recommended the timing of the surcharge removal? :
d -
9 A : couldn't say specifically aho did, no.
z o
y 10 4 Do you have any professional judgment con- f E i
!3 II cerning the time of removal of the surcharge? l Y I2 A Yes.
=
j 13 MS. BLCOM: I was about to object to that
=
2 I4 question. We haven't talked about it at all, and :
E j= 15 haven't even talked about it with him, but we haven't g 16 talked about this at all.
s
= 17 3
On the other hand, if you want to answer, you
=
} 18 can answer.
2 19 THE WITNESS: Yes, I have a judgment. -
R 20 SY MR. PATON: (Resuming) 2I J Can you tell us what that judgment is? I J
i !
22 l?
.t The time that the pr'eload was left on is l i '
23 , adequate to supply the data that was needed for future
' l 24 ' pro j ection o f the settlement of that structure. ,
25 !s that judgmen based on vour own orofessional 4
i
! ALDERSON REPORTING COMPANY. INC.
s 130 I I qualifications, or are you relying on other person's 2 professional judgment. .
i 3, A Based on my own. I have performed many pre-4 !1oading projects in the course of my engineering practice.
e 5 g aid you take into account the behavior of the s
j 6 pietometers in reaching that judgment?
~ t n
$ 7 A Yes. f I
E g 8 % Do you know the ground water level during --
L 9 in the vicinity of the diesel generator building during 2.-
@ 10 the entire time the surcharge preload was on? l
_z .
= t y II A There was a change in it as I recall.
3 f= 12 4 My question is do you know what the ground 13 water level was at the diesel generator building?
= .
n 5 I4 A I don't recall. l'
" i j= 15 g Isn't that a factor that confuses the analysis l j 16 that determines whether or not you were in secondary !
I n
d 17 consolidation?
i 5
E 18 ' I didn't see any-confusion. !
A ;
I a
19 % Well then, do you know -- do you know what the n
I 20 ground water table was? j 21 1 I don't recall what it was.
22j q Did you know what it was? ;
I 23 i A .I looked at the data at one time, yes. -
(. 24l' 4 And you didn't see any confusion? '
( 25 x so, f
- i' 1 ALDERSON REPORTING COMPANY. INC. ;
1 1
i i
1 :
131 I g So, it was clear to you, even though you may ,
2 not recall right now, it was clear to you at that time ,i 3 jprecisely what the ground water level was during the s
4 Ientire time of the surcharge at the diesel generator 2 5 building?
A 2 6 A I don't recall having any question on it.
3= l C 7 g Ckay. I sure wish we knew. There was a i A l
$ 8 time right around surcharge when the level of the pond ,
u 9 was changed, is that correct -- or possible -- during z.
@ 10 the surcharge? l z
3 II A I don't recall the detail of that at the a
j 12 moment. I know that there was a water level change of
=
j 13 some kind.
=
= i' 5 14 4 In your analysis -- well, you agree that j
~
= >
j 15 prior to removal of the surcharge it had reached secondary ,
g 16 consolidation?
" l
, d 17 A -Yes. !
a :
= !
{ 18 g What is your basis for that?
t
{M 19 A The shape of the curve, observations. ,
i' 20 ,
4 The shape of the curve -- is this plotting 21 pie ometer elevations or what?
I 22 A Settlement versus time.
[
23 g S.ettlement versus log time? -
[ t.
24 A Yes, t
25 j g And your pie:cmeter behavior to your knowledge '
t l
, 1 ALDERSON REPORTING COMPANY, INC. !
l l
u -
i i
1 i
132 ,
)
i I was entirely consistent with your conclusion that it was ;
2 in secondary consolidation? ;
i 3' A Yes, the flips that occurred in the pie:ometers 4 jare in agreement with the change in the loading that ,
c 5 took ulace.
~
A j 6 G Is it true that the removal of the surcharge !
R*
" 7 fit in very precisely with the schedule of work on the
$ 8 diesel generator building? l
. s' 9 A I am not aware of what the schedule of work was.
z .
$ 10 With respect to the diesel generator building, z
C ,
=
3 II , the diesel generators are going to rest on pedestals, is ,
s i,
12 that correct? l 5
=
5 I3 A It's my understanding.
=
m i I4 4 And the pedestals are not connected with the l I
j 15 wall footings for the diesel generator building, is that
=
30 correct?
E m
N I7 A I do not know.
a
= '
j 18 Was there differential settlement at the G
=
8 19 diesel generator building?
3 n
'O
^
A Yes.
21 Did you review any data relating to the G l l
22 surcharge program before the decision was made to remove -
23 li the surcharge? .
1 I did not -- at that particular moment, I did 24f. ,
25lnot in any detail. That was not my charge.
3 !
l I, 1 ALDERSON REPORTING COMPANY. INC. I
133 I
- I 4 Okay. ;
2 A I saw it as a matter of interest for my f
3 ! colleagues.
I 4i G Dr. Davisson, I want to show you a page three e 5 of a note to the file dated August 6, -- page one is 9
j 6 dated August 6, pages two and three are dated August 7.
A l C 7 I am not sure why that is, but --
~
! 8 MS. 3 LOOM: Is this going to be an exhibit? l C
' ' ~ ~
.--- This 2----- ~ . . . __ . ._ __ _ M. R ._.P AT O N : is part of Deposition 2
@ 10 Exhibit 5. ,
I ,
=
5 II MS. BLOOM: Yes," a twenty-page document. ,
- t 12 MR. PATON: Right, and this is in the middle 5 r
=
13 of the page, and there is a sentence which reads: "Dr. l a
I4 Davisson noted that we thould look hard at connections !
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= l j 16 and that allowance should be made for a maximum of one a
N I7 foot movement in any direction." -
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18 SY MR. PATON: (Resuming) ,
t 19 Let me show you that note and ask you do you s S l, 5
20 l
recall making that statement? f 2I A (Pause) i.
22 With respect to this specific sentence, I l t
23 j do n ' t recall that one. I have examined the subject I i ~
24j that was under discussion at that time, and I recal1 !
having some IOCollection what the' discussion was about.
I I ,
1 ALCERSON REPORTING COMPANY. INC. l-
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I G You say generally you do not recall that t 2 discuss on?
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A I do now. Now that I have seen the notes there v
4 !! have a general recollection of the discussion.
g 5
? Okay. Why do you think allowance for a one n 4 j 6 foot movement was appropriate? i n
" 7 A I don't recall the one foot allowance speci-a j 8' fically, but I do recall what the general topic of J '
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'j 10 A word of explanation on procedure is in order I
!a II here. At these meetings each consultant had the area .
I 12 for which he was specifically responsible. However, if ,'
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3 G-14 in some of the work that anybody else was doing, we were !
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a 15 invited to chime in, and so a lot of that has occurred. i f 16 There have been remarks ranging from cratuitous I a I to extremely useful that are thrown on the table by the 17 ,
w 18 consultants on_other parts of the project for which they !
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19 are not specifically connected.
20 So, there has been some interchange of this i 2I -
type all through it. However, where you've had more 1
22 than one consultant at any given time, and this particular ,
23 ;
discussion was one when -- I think it took place at a i
2# time when they thought there might be some pockets- >
1, 25 i of loose sand, and I was raising the question as to ,
i I ALDERSON REPCRTING COMPANY. INC.
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1 1 ;whether operation of the diesel engines themselves induced ,
2 sufficient vibrations to shake some of these down a ,
I 3 llittle bit, and if se, it would be a good idea to shake 1
4 jthem down before any final connections are made. i e 5 7 Do you know the status of that recommendation 5 .
j 6l right now?
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7 A No, I do not.
I' u i' A 8 4 okay.
- 9 A I have a recollection that as information i-10 l became better -- as they got more information on the h=
11 nature of the sand under that structure -- that this a
Y I2 became less of a concern and in the interim I believe an i h:
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13 investigation was made of the machines themselves.
m I 5 I4 As I recall they are V-16's or V-12's, and a j
- l 15 pretty well balanced machine. ,
. i g 16 C Okay. Are you aware that there were two A
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17 Category I borrated water storage tanks on fill? l
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18 A I have heard the subject mentioned, but I l
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19 have had nothing to do with it. !
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I 20 G Okay. You could not, then, describe the l 21 foundation configuration of these tanks?
22 } A I cannot.
23 4 Do you know whether there is a consultant to i
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24 3echtel with respect to the borrated water storage tank? :
1 I 25 l A I don't know. 6 i
ALDERSON REPORTING COMPANY. INC. '
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i 1
4 Do you know whether there is a soil settlement l i
2 croblem with rescoct to the borrated storage tanks? I
- I i '
3i A don't know that either.
f 4i G Okay. I want to show you the response :o n
I e 5 question forty-one.
l H t j 6 MS. BLOOM: Can we make it an exhibit? .
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$ 7 MR. PATON: No, no way. Off the record.
~
8 (Discussion off the record)
L '
9 MR. PATON: On the record.
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$ 10 3Y MR. PATON: (Resuming)
E
!3 Il 4 I want to show you a response to question i f* 12 forty-one and specifically direct your attention -- it ,
l s 13 starts I think back here on page 41-1, Service Water
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d l'7 10, November, '80."
E l 18 A Probably had some input into it, but again, t -
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l $" 19 that filtered through geotech and worked its way to l 5 20 that document.
t 21 G Okay. {
4
- am certain I had some input. j 22l A '
i Now, we see a statement on sheet four of ,
23 , -
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l 24 ] four attached to the answer to question 41 that talks about j ;
25 ; soil drained paramaters. l
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1 1 ALDERSON REPORTING COMPANY. INC. :
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137 1 A Yes. .
2 g I want to ask you if you will take a look l 3 , at that and agree with my conclusion that that indicates --
1 1
4 i that page four indicates that pile and bearing capacity I
5 ;
e is planned to be determined by soil test in the drained
" i j 6 condition? '
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$ 7 A (Pause)
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! 3 If you believe what they say, they made a J .
2 9 drain analysis of it.
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@ 10 g You say they have made or they plan to make?
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j 13 ' % An analysis to be done?
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G 4 I see. .
d l c i o 18 A It's probably playing _a game again. l
- i e n 2 19 4 What is playing a game? {
5 : I 20 ' A You have got to make a calculation, even l 5
I 21 though you are going to determine it by a test.
i 22
% You mean you think Bechtel is playing a game 23 because they are forced into it because the NRC is asking I
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24 l them to do that?
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. i 25 : A Well, let =e read the question and then I'll 1 i l
!. ALDERSON REPORTING COMPANY. INC. l
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i l i 1
answer that.
2 (Pause) i 3 That's essentially it -- ask a foolish question, 4 and you get a foolish answer --
strike that as facetious.
g 5 No, don't strike it. Leave it on the record, G
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$ 6 and if they want to strike it, they can ask the board '
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2 i j 8 In your opinion such analysis is not necessarv? l J
- 9 i It did not serve a useful c.urt.ose here.
7.
t 10 5 g G Okay, 3
II A It served a political purpose, but not an en- '
i 12 ' gineering-wise useful purpose.
g 13 Sy that you mean -- by political purpose I i G
3 14 1
?
gather you mean they are giving it to the NRC because ;
- I 15 the NRC is asking for it? ;
h_
E I0 A That's right.
I m I l'7 This gets back to the same --
is this the same i d G
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18 subject as the horings that the NRC is currently asking for?
I b" i II Yes, that's foolishness also. I i ! A
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! f 20 Yes.
G l 21 And to substantiate some strong statements, I A
l 4 22 j would like to add that it doesn't matter what shows in l .
23 any of those calculations. If the calculations say that 24 the pile will carry 300 tons before it fails, and it i
25
- 400, the calculations are wrong. !
l lactuallycarries 6 1
ALDERSON REPORTING COMPANY. INC. i
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1 If the calculations say 300 and it carries 2 200 tons, the calculations are wrong again. But, if 3 j it only carries 200 we have some redesign to do, and it I
4 ! is the controlling item, and it's no the borings that's n 5 going to control here, nor is it the calculations of that 2
j 6 type because the pile capacity calculations -- if you i R
$ 7, want to do something about those theories, it's possible l
$ 8 to get a fairly wide variety of answers out of a group
-J 9 of competent engineers, and we are operating in full z.
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@ 10 knowledge of the fact that this is the state of the !
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12 tests.
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j 13 4 Let me ask you to assume if you possibly can --
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5 14 assume just for the sake of this question that such an i t ,
j 15 analysis was appropriate, and let me ask you,1f you can -
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- 1 16 make that assumption, wouldn't you make the test with i i
I 17 the soil in the undrained' condition instead of the E-
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w 19 , A No, because the method of installation that I j
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' i 20 have described for you clearly provides you with a drained ;
21 condition for each and every one of those piles. ;
22 i G Did you attend the mes*.ing at the Federal i
23 } Highway Administration in June of 1990?
24l A Yes.
l 25 l 3 Was there a discussion at that meeting of the J
- l. ALDERSON REPORTING COMP ANY, INC. l
1 s 140 I j appropriateness of a soil strength test in the drained 2
or undrained condition? l 3' 1 I don't recall specifically, but at such a 4 =cnference there are undoubtedly people who discussed ,
e 5 the subject, yes.
" t 3 6 e G You have no recollection of chat? j R
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t A No, I don't, not at all. f i
n i l 5 3 G Okay. !
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- 1 I was more than an attendee, I was a participant E 10 j en that particular thing, and we were offered a great deal E 11
< of data with which -- l 3
6 12 z G I'm sorry, what?
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- A We were offered a lot of information with 3 14 3 which to make a prediction, and I think everybody had '
h F 15 to judge for himself the quality of data and the
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- 17 3 discussion.
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j 19 the soil do be used in designing the piles?
20 A I didn't. :
i-2I Did you get that information from someone? !
l , G i
22 If anybody had to have that for any purpose
[ A '
\ p 3echtel got it. ,
t 24 You didn't need that information?
0 25 No, I did not. I'm sure I have had some A l t
l 1 ALDERSON REPORTING COMPANY. INC.
I 141 l l
f, l
1 discussions with the 3echtel people over what they used. l 2 I am very liberal about letting people in their analysis. f i
i, s
3 'using whatever they want to use n it, especially when f
4 i j the job is going to wind up being controlled by the test.
- 5 r G Nhat does this mean?
n
~ I 6 It means we are lecturing.
o MS. 3 LOOM:
R R 7 (Resuming) 3Y MR. PATON:
n 8
n 4 In the event of an earthcuake will the !
-4 .'
= 9 z-condition of the soil near the pile tip be undrained? '.
I 10 It would j A Yes -- pardon me, I take that back. l E 11 g be drained or at least on the reload portion. j i
d 12 E G I'm sorry, I didn't hear. l
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16 i A The method of installation of the miles and i
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- 3 the pretesting -- 210 tons in the longtime holds to be [
- I E 18 i 1 - placed on that. I mean, for certain it will hcVe been
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39 i
oreconsolidated to that load that a n v. time it now i
! 20 t
exceeds 130 tons that we will see it at least on a I
. reload or a recycle.
I
% In the installation of the piles how much
! "3
^ ;! time w4 4* -ake to transfer the load to the Oiles?
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24 i 1 It might take several months.
l 4 i 25 ' Uith respect to the electrical penetration i 4 1 '
1 s
ALDERSON REPCRTING COMPANY. INC. ;
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1 area, do you agree that the caissons will be subject to f f
2 lateral loads from earthquakes? i 3 A Yes, there must be sone.
4 G Do.you agree that the caissons will be subject g 5 to lateral loads from earthquakes which will create n
j 6 bending moment along the length of the caissons?
R b 7 MS. 3 LOOM: That question --
M '
! 8 THE WITNESS: I have not --
i d l 2 9 MS. 3LOCM: 3efore you go on, that questicn z, i I
y 10 sort of sounds like you are assuming there will be .
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12 MR. PATON: Well, he already answered the 13 l first part of it yes.
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'A 5 l'4 MS. 3 LOOM: The first part said if there is E l 15 an earthquake. Well, never mind, go on. j i
j 16 THE WITNESS: That was not part of anythina !
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5 17 I have been asked to look at with respect to the electrical i a
3
- 1 18 penetration. The same would apply to the prior question 3 ,
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8 s 19 that I answered, i l
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i j 20 , 3Y MR. PATON: (Resuming) l t
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21 What is your responsibility with respect to !
G 22 the electrical penetration area?
l l
23 i 1 It's not well defined at the moment because 24 they are adapting to the loss of Mr. Gould.
i 25 i G Dr. Davisson, do you recall several hours ago ,
I
- l' i l
I
.: . ALDERSON REPORTING COMPANY. INC. 1 I
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, 1 l
l 1 generally the question I asked you about the status of ,
2' :enstruction of the piles, and I read you a list outlining 3 , alternatives -- quick design, pick an alternative, 4 refine the model, etc. -- I was trying to find out where g 5 you were with the design of the piles at the service -
N j 6 water structure, and I will repeat all those words if i R
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" 7 you -- if there is any need to. l n '
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a .A No.
-J 9 My question is can you tell me where you are z
. 4 10 z i with respect to the remedy at the electrical penetration !
Il ' area -- at what stage in the development of the remedy 5
a N I2 are you?
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- i 13 MS. BLOOM: Do you understand that? i 3 14 i p THE WITNESS: Vaguely.
0 15 t MS. SLOOM: Do you want to break it down? i
= l E I0 THE WITNESS: I think I understand it well
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1 17 enough to answer it.
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18 MS. BLOOM: Okay, go ahead.
l 3
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I9 h MR. ?ATON: If you don't understand it, I can n
20 break it down. ,
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' THE WITNESS: No. I guess we are waiting for
, j I 9 t a 22 l a little more definition as to what we might be doing l
l 23ll on thatproject, and when I say.we, I guess I mean me, j 24j because Mueser-Rutledge is involved with that now, and --
25 , 33, pg7ag: .m sorry, I didn't hear that name. ,
1 i ALDERSON REPORTING COMPANY. INC.
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! 144 1
i i
1 THE WITNESS: Mueser-Rutledge is involved l l,
2 with that project now, and I don't have the feeling }
3 myself at this moment that I know exactly how we are going 4 to work together on this.
1 2 5 4 3Y MR. PATON: (Resuming) e M 4
- i g 6: '
4 Okay. My question, though, relates to your R f
, b 7 knowledge of where Bechtel is with respect to the develop- i n !,
j 8 ment of the remedy for the electrical penetra: ion area.
l 0
9 A All right. The specifications have been
- z. ,
O l 10 developed and the technique worked out, and that was done g i
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3 Il between project and Chuck Gould, C. H. Gould, and that was 3
y 12 sent out for bid.
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g 13 ' So, those details should be well in hand. t
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x i 5 I4 However, I know that some of those details are to be l b i j
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15 contractor designed details, so the design is not j 16 finished. Even after you have a contractor, there is I 1
t 1 l 17 I a
still a lot of work to do vet.
- 1 3
" .i j l8 0 Do you know whether your responsibilities will
(
t
, e i a 19 include review of the contractor details when and if i i n l
20 they are provided?
{
i 21 A No, I don't. I would say that what I as to do I
22 l on that structure, or that particular part of the project, i !
23 l would be subject to some discussion that has not been t ~ '
24 iheld yet.
l i !
25 , . G With respect to the remedy at the feed water I e
1
.t i ALDERSON REPORTING COMPANY. INC. I i
145 t
I.
I isolation valve pit, would your statement be the same as !
i 2 for the electrical penetration area -- that there is some !
3 i
indefiniteness as to the scepe of your responsibilities?
4 A A: this time, yes. ,
f 5
4 All right. Now, with respect to the feed n
6 '
j water isolation pit, can you tell me where in the total R
^
" 7 process of preparing a remedy for that situation where
- I I
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a 3 they are? I, J
~- 9 A I can't recall at the moment. That detail has i z.
I j
10
- slipped my mind. I would have to go back and study it, and 5 II I am sure even after I studied it I would have to check withj s
12 somebody at Bechtel to see what the status is. i i- ,
- 1
- 13 g Do you view the feed water isolation valve pit a
I4 in the same general category as the electrical penetration l, E
1 15 as your possible involvement?
area insofar ;
z t 16 In other words, you may be. involved with j i
a j 1:7 both, or -- t M
e 1
3
's A Yes.
i l,
19 "s G Right now you are not too sure about either one?
n 20 ' A Not sure, right. .
21 MR. PATON: Let's take a ten minute recess and 22]I think we will be finished shortly. I I
1 23 i (Short recess taken) ;
"4
' l , 3Y MR. PATON: (Resuming) -
i i
25 l G Dr. Davisson, did you say that during the l-i i ALDERSON REPORTING COMPANY. INC.
146 ,
I 1 earthquake, or an earthquake, the soil beneath the pile 2 tip would be reloaded? i 3 A Yes, by the dynamic increment.
i 41 G Would this reload be under drained or undrained g 5 conditions?
n N
j 6 A It's in between the two.
R 1
i 7, G Let me -- do you recall seeing Exhibit 2,
- i
$ 8 which purported to show cracks in the service water structure-a <
9 1 Yes.
i
@ 10 3 Let me ask you to assume that the cracks shown f 3
)a 11 on Exhibit 2 were stress cracks, and I'm indicating to i "g 12 you that I am not suggesting that you believe that or
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13 anything, I am asking you to assume that for the sake l
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n 5 14 of this question. !
t 15 If those cracks were stress cracks, would j 16 you have recommended the same remedy at the service water j
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$ 17 structure? I
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$ 18 A I have not examined those cracks in detail, *
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n s 19 step one. Stee two is that the same solution would be l
20 on the board for consideration irrespective. It is up 21 to the project structural to evaluate that and see if, ,
22 } in fact, the solution I have recommended is one that 23 fits in with your overall analysis. .
24 MR. PATON: I have no further questionse Thank- ;
i 25lyou, Dr. Davisson.
ALDERSCN REPORTING COMPANY. INC. ,
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e i . 3 147 :
1 i
i 1 MS. 3 LOOM: I have no questions. ;
2 (Whereupon, at 4:15 p.m., the taking of the i I
3 .instan: deposition ceased.)
4 4!
g 5 i s i j 6 '
- Signature of the witness
- R 7 A i j 8 SU'!SCRISED AND SWORN to before me this day of l J !
- 9 , 1931.
I i E 10 l E c
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3 11 i a
g 12 l 5 Notary Public l E 13 i 5 i 14 l 5 ,
My Commission expires:
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NUCLEAR REGULATORY COMMISSION
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