ML20090A855
| ML20090A855 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/04/1980 |
| From: | Heller L Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-12, FOIA-84-96 OL, OM, NUDOCS 8101100776 | |
| Download: ML20090A855 (112) | |
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Transcript of Proceedings
.. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board DEPOSITION OF LYMAN WAGNER HELLER 2 -32?
l Bethesda,-Maryland Thursday, 4 December 1980 4
ACE.FEDERALREPORTERS,INC.
ONatRewom W North Capito* Street.
Washington, D.C. 20001 NATIONWIDE COVERAGE. DAILY T'___.
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UNITED STATES OF A. ERICA u
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NUCLEAR REGULATORY COMMISSION 3
Before the Atomic Safety and Licensing Boar'd 4
- - - - - - - - - - - - - - - - - - - - - - - - - +
5 In the matter of:
Docket Nos. 50-329-OM 6
CONSUMERS POWER CO."PANY 50-330-CM
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50-329-OL 7
(Midland Units 1 and 2) 50-330-OL 8
--~~~~-~~~~~----~~~~~~------+
9 DEPOSITION OF LYMAN WAGNER EZLLER ss to Bethesda, Maryland m
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Thursday, 4 December 1980
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12 Deposition of LYMAN WAGNER EELLEP. was resumed, 13 pursuant to agreement of counsel, at 11:15 a.m.,
in Room P-114, u
14 Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland, 15 before William R. Bloom, a notary public in and for the Districh is of Colu-J:ia, when were present on behalf of the respective 17 parties:
18 On behalf of the Applicant:
19 RONALD ZAMARIN, Esq. and AL.M FARNELL, Esq.,
Isham, Lincoln and Beale, one First National 20
~ Plaza, Chicago, Illinois
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21 JAMES E. BRUNNER, Esq., Consumers Power Company,
. 212 W. Michigan Avenue, Jackson, Michigan 22 1
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On behalf of the Regulatory Staff:
2 WILLIAM D. PATON, Esq. and BRADLEY JONES, Esq.,
Office of Executive Legal Director, 3
United States Nuclear Regulatory Co-4ssion, Washington, D. C.
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C _O N.T _E N_ T S 2
Witness Direct Cross Redirect Recross 3
Lyman Wagner Heller 142 4
Exhibits For Identification 5
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_P _R O C_ E _E _D.I. N G _S 2
Whereupon, 3
LYMAN WAGNER "mR 4
resumed the stand and, having been previously duly sworn, j
5 was examined and testified further as follows:
6 MR. ZAMARIN:
This is the continuation of the 7
deposition of Lyman Heller, continued from October 9th, 1980, i
k-to this date by agreement of the parties.
8 CROSS-EXAMINATION (Continued) 10 BY MR. ZAMARIN:
11 Q
Mr. Heller, do you refer to yourself as Mr. Heller
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12 or Dr. Heller?
12 A
It's your option.
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Q All right.
15 I don't even call my doctor Doctor, so I'll refer 16 to you as Mr. Eeller, and I don't intend any disrespect by 17 that, if you refer to yourself as Dr. Heller.
18 You understand you are still under oath from the
'8 first session of the deposition, sir?
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21 Q
Do you know whether it is intended that you will l
22 provide testimony at the OM hearing?
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A I guess I'm not sure what an OM hearing is, t
2 MR. PATON:
Now you know they've been consolidated.
3 It's OM/OL.
4
.MR. ZAMARIN:
Well, he may provide--
I assume he 5
may be provided at the OL on some other issue.
6 BY MR. ZAMARIN:
7 Q
The soils settlement hearing.
Do you.know if a
there is any intention of you providing testimony at the
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9 soils settlement hearing?
10 A
I honestly don't know.
11 Q
Okay.
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12 MR. ZA.
Do you know?
This may have some 13 effect on how wide cur inquirf is.
You don't know?
o 14 MR. PATON:
Off the record.
15 (Discussion off the record.)
16 MR. ZAMARDi:
Back on the record.
17 BY MR. ZAMARIN:
la Q
What is your primary role or responsibility in 18 the Midland soil review issue?
20 A
I think it has changed over the last year and a 21 half.
I'm not sure whether you mean now, or at some other 22 point in time.
Would you clarify that?
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Q, Yes.
2 If we can start with what your present role is with 3
regard to the Midland scil settlement issue.
4 A
I think my present role is to attempt.to meet the 5
schedules that have been set up for the hearings, attempt to get a reasonable degree of reso"rces people time available 6
to go through all the information that has apparently become 7
8 available.
9 Q
okay.
10 Do you have any active role in reviewing and analyzing technical data with regard to the soils issue?
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12 A
Not the. active, calcuiational type of activity.
i 13 I do suggest items that appear to need to be checked and suggest that semebody either carry out a rough check of nhose-14 15 items or refer them to scmeone else for their consideration.
I 16 Q
Can you give me some idea of the type of things 17 you're referring to when you say you might suggest an item 18 that needs to be checked?
18 A
Well, there's a number of review areas involved 20 in this including mechanical and electrical, the piping 21 people and our people, and I suggested that we keep these 22 other esoteric areas informed of what we are doing and t.f to e up i
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get a unified review of the different topics.
2 I guess that's the best answer I can give you.
3 Q
I see.
So when you say " items that need to be checked" 4
you're referring more to like checking with these other 5
6 areas to see what information they have on that area and to see that the efforts are coordinated as opposed to sug'gesting 7
8 that someone check their computations or check the ba.=is for 9
an assumption that he's made?
10 A
I would think it wecid be both.
1 11 Q
Do you have any role or responsibility with regard
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favorable or not faverable to a fix or a certain as ecu cf a u
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fix preposed by Consumers or Bechtel?
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18 A
May I ask that that question be repeated?
I think 16 I missed the first part.
17 MR. ZAMARIN:
Will you read back the question, 18 please?
18 (Whereupon, the Reporter read from the record 20 as requested.)
21 TEE WITNESS:
Now that you've repeated the ques-22 tion I guess I would ask if it would be possible for you to
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146 either, rephrase or to break that question into more bite-eb5 1
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Okay.
4 BY MR. ZAMARIN:
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Q Let me explain really what I'm looking for.
We've taken a substantial deposition from Joe Kane s
and are aware of his involvement in what I call the hands-7 on technical aspects of reviewing information and interfacing 8
with the Corps of Engineers to understand the work the Corps a
to of Engineers is doing.
Really what I'm trying to find out is in' light of 11 r
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12 all the. things that they're doing, just what you do with 13 regard to the soils.
In other words if so'meone s'absits some-thing for Consumers or Bechtel with regard to a dewatering 14 15 scheme, for example, is it your role or your responsibility 16 to review the aspects of that and say either that's accept-17 able or that's not acceptable? '
18 A
I would not do the actual review of the informa-to tion that came in.
I would probably ask the reviewer or the person who is responsible for the review the basis for either 20 C
excluding certain items from consideration that might occur 21 22
'to me or the basis for acceptance of what was submitted, I
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provided that's not adequately described. in their SER or 2
questions or whatever.
3 Q
Okay.
4 And then what would you do after you had asked the 5
reviewer those questions?
Satisfy yourself as to whether he was correct in either excluding them or accepting them?
a 7
A Yes.
8 Q
And if you disagreed or determined that the re-9 viewer was not correct, for example on excluding a certain w
10 item, would you then direct the reviewer to reanalyze or re-11 consider the problem?
12 A
I might or I might not, depending.on hew. serious I
13 I thought the oversight might be.
It may be of negligible 14 import and I'd forget it.
It may be that it would be neces-15 sary to go back and look for more information and perhaps
~16 ask a question to get it answered.
17 Q
other than with respect to the completeness of an la analysis or consideration, do you chiefly rely on the techni-18 cal judgment of your reviewers then with regard to the soils 20 isstes at Midland?
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Do you exercise independent technical judgment on l
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example, or do you simply see that the analysis and review n
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4 A
I guess I would have to answer "both" in this case.
5 It's kind of a cooperative thing, an iterative review where we try to censider important aspects of it and ignore the' s~
7 less important aspects so it's an iterative process.
8 I feel that I contribute to the review but don't 9
actually do the review.
10 Q
Have you exauined boring logs with regard to the 11 Midland soils?
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- i 12 A
.Sems of the early logs I did icok at.
Yes, si.r.
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Q When you say *early Iogs" you are talking about l'
logs prior to what time?
15 A
Prior to about the first of January,1980, roughly 16 11 months ago.
17 Q
You had some change in responsibility I believe 18 with regard to the soils issue, did you not, at one time?
18 A
Yes.
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Q And can you tell me what your responsibility was 21 prior to that change, and then the time that'it changed?
A I believe this was covered in my earlier testimony I
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g , 3 c.. =- ob8 1 but I',d be glad to refresh your memory. 2 Q If you would. .( 3 A I became knowledgeable of the settlement problem 4 I believe it was in September or october, somewhere in that 5 range, of 1978. At the time Mr. Dan Gillen was.doing the 6 review and I was his i= mediate supervisor and I relied on his 7 expertise for the - what we call Q-l's acceptance review or s 0-2's for the plant in the review process. 9 We visited the plant together in I believe it was December $f '78, along with others from NRC. Some. time in to ~ 11 the spring or ea.rly su:r.er 'of that year Mr. Gillen trans-12 ferred to another divisio'n cf NRC, another offire of NRC 13 rather, and at that.peint I was the only person ac=uainted 14 with the Midland; site and the Midland review, and I attempted 15 to do what I could to fill that void until we were able to 16 get the Corps on board and find time for Mrr Kane to become 17 involved in the review. 18 And at that point I was able to relinquish my 19 contribution to Mr. Kane and the Corps. 20 Q I take it then that from some time around the 21 spring of 1979 until just about the end of 1979, your res-22 pensibilities with regard to the Midland soils would be ~ .) . W 40 %.--
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150 r cb9. 1 somewhat analogous to what Mr. Kane and the Corps are doing 2 now? 7 i s. 3 A My responsibilities were roughly the same. My 4 activities were much less. s Q Since January of 1980, have you reviewed any piezemeter data with regard to the diesel generator building s 7 and its surcharge program? s A Not in enough detail to formulate any opinions. I e have gone over some of the plots with Mr. Kane but have not u 10 attempted to look at the physical basis for those plots. i 11 Q Some of the plots that you went over with Mr. 7.ane, c 12 do you recall the reason for going over them with Mr. Kane? 13 A Well, as I recall he asked me to look at a number l' of plots so I did. And he discussed some of the reasons for 18 his interpretation and I offered some opinions as to perhaps 16 alternate interpretations that might be made, strictly in a 17 non-detailed but philosophical vein. 1s Q Do you recall what Mr. Kane stated as his reasons l l for his interpretations of the piezometric data? 19 I 20 A Not to any great extent. I do recall one discussior. 21 of the conditions at the point of the piezameter, what 22 his interpretation was of the soil conditions, whether the l l da/nul8; '_._,8 l =
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3 of the volume change that would be necessary to get those 4 readings in the piezometers; things of that kind. 5 Q And do you recall what alternative reasons or 6 interpretations that you suggested to him during those con-7 versations? 8 A The only item I recall was the rebound-Let me use another word; whether or not there should be* some ex-- 9 10 pected dr p in the piezemeter due to taking the preload off 11 of the fill, how long that ' drop might be expected to continue . C.. 12 before it regained usual groundwater levels. 13 Q Andinyouropinionshouldtgerebesomeexpected 14 l drop in piezometer level upon removal of the surcharge? 15 A Yes, there would be. 16 Q And in your opinion would the length of time 17 before regaining what appeared to be the usual groundwater 18 level as exhibited on the piezometer plots that you saw for I I the diesel generator building comport with what you would i 20 have considered to be expected or normal? 21 A I don't believe I have an opinion on that. It was 22 not clear what the conditions were.-- to me. I haven't $5U& Sna. n.. ..:-.r-,...:-,:- ~.a.,-...
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~ .cc w._ -m., 152 obil 1 looked at the boring logs recently. I really did not have an jp opinion on that. I knew it would be expected to happen but 2 1 s 3 I couldn't express an opinion as to whether they were reason-4 able or not. 5 Q I see. 6 Did Joe Kane tell you whether he thought that the 7 piezametric data demonstrated either secondary consolidation 8 or lack of secondary consolidation or nothing at all to him, 9 or something of that nature? 10 A No, that wasn't the item that was under discussion. 11 Q Do you know whether Joe Kane ever found out the ,. ~ ( 12 type of piezameter that was used and which had its data 13 represented on these plots, that is whether it was an open 14 or closed tube? 15 A Well, we_ discussed that just the other day, and I 18 don't believe that he has yet a clear understanM ng or a clear 17 description of the actual physical specifications for those te piezameters. 0 Do you know whether he ever asked anybody for that 19 20 kind of information? 21 A I don't know whether he has or not. I think some-22 where along the line we asked whether they were rapidly N E.L.I9:: eL ~ 9 . Mptg 4 W D4h ,-e a- - -- v + w
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. v.. en. _ y .: i v.~ . 3/s 154 t obl3 1 or Dutch cone tests with Joe Kane since January 19807 2 A Yes. l j l 3 Q Do you recall the substance of those conversations 4 that you had with Mr. Kane? 5 A The substance, as I recall, was simply to indicate 6 to him that cone penetrometer data I believe was gathered 7 quite early in the review, quite early in the exploration by 8 Bechtel in the diesel generator area, and I suppose that 9 additional cone penetration data was obtained later. So I. just wantb h!m to be aware that there was earlier data that to 11 had been shown to us or had been available at some time pre-(. 12 vious to what had been recently s'.bmitted. ~ 13 Q And is that the substance then of your conversa-14 tions with Mr. Kane about consolidation test, shear strength 15 test and Dutch cone test data? Does that about cover it, in 16 other words? 17 A That's all I can recall in terms of submitted in. Is formation. 19 Q Since January 1980, have you reviewed any Boris 20 anchor measurements with regard to the diesel generator build-21 ing? 22 A No, sir. l d-SM4 47, l I i
.n....., .- Mbb Me... N. 4 -r es,. - -. -~-*s.=,,--_r- ~ MQ y* w ~ g f:,g y :,.[ } q,qc.y l7l> ..;.=" & *i .z.K: brT.T.~ ~3r}- 7 -,,y.....-y* --7 g.: o. - :.-----u-, {/ ..._m. M 155 f.w....... <: ..c.... - = = 3;. .y y_ .q obl4 1 Q Eave you reviewed a document titled " Applicant's 1 2 Position on Need for Borings" that was submitted by the 3 licensee? 4 A I have leafed through it with interest but I have ~ 5 not reviewed it in detail. 8 Q Did you discuss it with anyone? 7 A Yes, I did. s Q Do you recall with whom you discussed it? 9 A I discussed only one small aspect of it with another 10 reviewer n another plant. 11 Q can you tell ce'what you discussed, and with whcm? r. i 12 A I discussed bearing capacity evaluations with 13 Mr. John Greeves. u Q Will you spell."Greeves" for me, please? 15 A G-r-e-e-v-e-s. to Q And what was the substance of your discussion of 17 bearing capacity with John Greeves as it related to that i i 18 document, " Applicant's Position on Need for Borings"? j l A We were involved in the review of another plant j l 19 in which bearing capacity calculations had been perfo::med 20 21 and we were-- I mentioned to him that bearing capacity 22 evaluations had been mace for the Midland application as well d=/ re/ hers,8ns. 1 i e I mewe
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as for,this other application. 2 Q And did you actually discuss the calculations that (- ~. 3 had been made, the presentation that was made by Consumers 4 in that regard with him, or just mention the fact that it had 5 heen made? 6 A I mentioned the fact that it had been made and the 7 values that had been obtained. 8 Q And do you recall what he said? 9 A No, I do not. o 10 Q Was the purpose of your discussion with him in this 11 regard to find out whether he thought the presentation by p 1 12 Consumers with regard to its bearing capacity was accurata or 13 appropriate? I 14 A Ceuld you repeat that question, the first part?. 15 g rem just really trying to find out why you talked 16 to him about it. 17 (Whereupon, the Reporter read from the record 18 as requested.) 18 THE WITNESS: The answer is No. 8 BY MR. ZAMARIN:
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Why did you talk to him about that bearing capacity l 22-data? dM hee,8,w. x t
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g abl6 1 A. I considered it was an interesting coincidence 2 that the bearing capacity value computed for Midland was not \\ 3 too different than the baaring capacity values that were computed for the plant.that he was reviewing. 4 5 Q What was the plant that he was reviewing, if you 6 can recall? 7 A I can recall. It was the General Electric Test 8 Reactor. Is Bechtel the A-E on that? s Q s to A I don't know. -~- 11 Q Is there any significance to your mind to this ,r s. 12 coincidence between the similarity of bearing capacity values? May I ask that the question,be repeated again, 13 A 14 please? 15 .MR. ZAMARIN: Yes. 16 Please. 17 (Whereupon, the Reporter read from the record 18-as requested.) 18 THE WITNESS: Yes. 20 BY MR. ZAMARIN: 21 Q What is that significance? 22 A The foundation conditions were rather markedly l i M l i .-6 p. ,--,y .m -e.% ,s-, w .-y-c
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.3 n e 158 sbl7 1 different between those beneath the diesel generator building i 2 and those beneath the General Electric Test Reactor. l 3 Q And from this did you draw any conclusions? 4 A I did not attempt to draw any conclusions. I left 5 that to my reviewers. a Q And do you know if your reviewers have drawn any 7 conclusions with regard to this? 3 A No, sir, I do not. g Q Did this suggest to you that there was scmething wring wits the analysis that Consumers had presented with to 11 regard to the bearing capacity? s 12 A It suggested that one or the other could not be s 13 ccrrect, or both were incorrect. - o 14 Q Do you know whether it has been dete mined whether 15 the G. E. Test Reactor bearing capacity has been found to'be to incorrect or r.ot? 17 A That matter is still under review. 18 Q And you say that you gave this information to your 19 reviewer.. Are you referring to-Mr. Kane? 2o A I was referring to Mr. Greeves. 21 Q okay. 22 Did you give this information~to anyone connected .i Pts. s e
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v.. < n=:.r. .,.,,.n--. ..-..,.n..,,.v....... .y g.: 9. w.. __ _ _ <., ~ m.w .., y e c-18 1 with the Midland soils review? And by "this information" I 2 mean the fact that there was this coincidence between the ( 3 bearing capacity calculation for the Test Reactor and for the 4 diesel generator building. 5 A Not to my knowledge, no, sir. 6 Q Have you, since January of 1980, reviewed the 7 application amendments that have been filed? 8 A No, sir, I have not. 9 Q Prior to January of 1980, did you review the piezo-10 meter dat for the diesel generator building surcharge? 11 A No, sir, not wha't you could call a review. PriortoJanuaryof1980didyoureviewtheapplica-l C-( 12 Q 13 tion amendments submitted by the licensee? o 14 A I should have, but I probably didn't. 15 Q Prior to January of 1980 did you review laboratory 16 records of consolidation tests, shear' strength tests, and 'I Dutch cone tests with regard to the soils at Midland? is A I did review the Dutch cone results in a cursory Manner. 20 Q Did that review lead you to any conclusion? 21 A Well, it indicated that there were some materials 22 with fairly low penetration resistances beneath the diesel YSalmal&n Sna. l l l 1 l. -- ~ w 9 t--f. a-- .p-g e .y --'d wi-y m e.
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160 [ abl9* 1 generator buil. ding. '2 Q Was this data obtained before or after the pre-a 3 load? 4 A I believe it was before the preload. 5 Q Have you reviewed, prior to January 1980, any 6 settlement records with regard to the diesel generator build-7 ing or other structures founded in whole or in part on plant a fill at Midland? e A Yes, sir. n 10 i Q And from that review did you draw any conclusions? 11 A No conclusions that had not been drawn by the - (' 4 12 applicant. 13 Q Can you tell me generally what those conclusions 1# were, though? 15 A That th settlement and the differential settle-1s ment of the building were more than had been expected. 17 Q Prior to January of 1980 did you review any ta settlement data with regard to the diesel generator building -l 19 i surcharge? 20 A I den't recall. 21 Q Prior to January of 1980 did you review any 22 Boris anchor measurements with regard to the diesel generator. EN &_ '., $na, O . J...-
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....c : m ;.w.. - -.:~.. h 161 ..y _ r. c.. .m .,.,.m.__. .....~.s y,,,...._, f *J.y.,..:. =. :..... c y cb20 1 building? 2 A No, sir. . C. 3 Q You have indicated that prior to January 1980, 4 you had at least looked at or reviewed scme boring logs. Is ~ 5 that correct? 8 A Yes, sir. 7 Q And did you draw any conclusions based upon the 8 review of those boring logs? 3 A No, other than the interpretations that had been n 10 made by the applicant that they were sands, clays, fill con-It crate under the various structures. 12 Q What other projects besides Midland have you. 13 worked on since September of 19787 u 14 A I can give you a li.st to the best of ny memory. 15' I'm sure that there are plants that I have missed. The ones to that I recall are Bailly, G. E. Test Reactor, LaSalle, .t7 vogtle, South Texas, Allens Creek, Sequoyah, Lacrosse, a la number of tailings dams including Church Rock and Split Rock, 18 a lost plutonium source, and the Low Level Waste Disposal 20 Plant at Sheffield, Illinois. 21 Q What percentage of your time do you currently 22 spend with regard to Midland? i 8PE F98. r l
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s .s q~ - - .a p. . -ca.. c., a., 162 cb21 1 A obviously right now a hundred percent, but in an average week, no more than four hours. 2 3 Q When.you say "right now" are you referring to the 4 time when ycu're in deposition? 5 A Yes. 6 Q Prior to January of 1980 and after some time in 7 the spring of 1979, approximately what percentage of your 8 time during that period did you: spend with regard to Midland? 9 I've tried to* indicate the period after Dan Gillen lefttheSeview. to 11 A I understand.. 12 Considering the arrangements for contracts, proba-13 bly eight hours a week. o 14 Q Excluding the arrangements for contracts, hbout 15 hcw many hours a week would it have been during.that period? 18 Closer to four? 17 A Probably around four or less. 18 Q In your opinion is settlement a decelerating 18 process? - I guess we would have to say under constant load? 20 A I had never thought of it in those terms but yes, 21 I guess you can say'it's a decelerating process with a gichal 22 coordinate reference system. kU $ne, I
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.g ..,.,,.,... y _ ) >..a .--...n- .. ~.,,, ,,...n. .w,,..,~~. ,.4 .y 163 f,3lar..x...., - g cb22. t Q With a what coordinate reference system? 2 A Settlement could be considered a decelerating 3 process with referance to global coordinate reference system. 4 Q A. global coordinate reference system? In other s words going in toward the center of the earth? 8 A Yes.- 7 Q You've indicated previously that preloading is an a accepted procedure in some applications. Can you tell me to 9 what applications you refer when you say that it's an accepted w 10 procedure? [ 11 A Well, it's used quite often for consolidating 12 waste materials, for reclaiming coastal areas, for garbage 13 disposal areas I guess you would call them, sanitary land-u 14 fills. It's used for those, purposes so that you can reclaim 15 them and use them for something useful. It's used for is consolidating fill material such as dredge disposal. It's i 17 used for! reclaiming, you know, coastal areas, swampy areas, te sanitary landfills, old sanitary landfills. t. 1s It's used in a number of applications'of this kind 20 where you're primarily concerned with improving the soil 21 conditions before you construct some kind of engineering 22 j facility. l l ses 1 N N.*DW 9** *% *SD P.. .,..n-,. ,,, ~,. - -
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164 ab23 1 O Is it also an accepted application to use it 2 simply to consolidate soil or preconsolidate soil so as to !(m 3 -minimize or be able to predict future settlement? 1 32 4 A well, the purpose of it generally is to consoll-ft date the soil so that future movements are not beyond those _s. 6 expected, yes. 7 Q Do you consider the Midland diesel generator a building to be an accepted application of a preload concept? 9 MR. PATON: You say " accepted." Do you mean by o 10 him? 11 MR. ZAMARIN: Yes, does he consider it to be. r. 12 MR. PATON: You say " accepted." Do you mean 13
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o MR. ZAMARIN: Accepted, generally accepted. 14 f 15 THE WITNESS: If I measurs acceptance by what I to would expect ten practicing engineers to accept and I said s is,. 17 .that if 50 percent of.them accept it I would accept it, if 18 less than 50 percent acenpted it I would not accept it, I i 18 l wculd have to classify the use here as not acceptable. i BY MR. ZAMARIN: 21 Q Your opinion, however, is would it be generally ,y Q. 22 acceptable insofar as it is based on sound engineering. U' s, up M ga s 1 s l .h t -+w,, k ~- y ,m- ..m.
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7, 27 27S.> -Q cb28 1 So although-- If the settlement had been uniform i 2 it may not have affected the building as such, but it would l 3 indicate distress to those portions that serve that bui'1 ding. 4 Q And can you describe the mechanism of how it 5 would indicate distress to those portions of structures that a would serve that building? And by that I take it you're 7 referring to conduits, pipes, things of that nature. s A Well, you're going to. induce shearing stresses, s tension. You're going to cause ovalation of conduits, pipes, 10-all items"that are not expected to occur when the plant or 11 these conduits were put into place. O 1 M 12 Q In referring to these structures that you just 13 talked about that would service the building, are you refer-14 ring to those which are buried underneath the diesel generator 15 building? 1s A They're in the areas of the preloading, yes, sir, i 17 Q You wouldn't be referring to any connections is because you're aware'that the structures that were buried 18 underneath the diesel generator building were cut loose prior 20 to the preload? ( 21 A I'm aware of that. 22 Q With regard to the building itself, however, and i h b ale ol & S m i .a.-,,,.,...~v.. ~ ~ ~.. w ii m messii.ii-imi i.-i. ,..i% ry
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c.< .-.cy.....,.: z _, c, 170 I l ob29 1 leaving aside for a moment the stressing of s ructures buried 2 beneath the diesel generator building, would the amount of 3 settlement during the preload be of concern to you? 4 A We're referring strictly to settlement, period, 5 without referring to differential settlement? 8 Q Yes. 7 A I find it difficult to separate the two phenomena, a total settlement and differential settlement, because an 9 averaging process masks the distress that the building is undergoinhinordertocalculateatotalsettlement. to It so.in general the engineers think of total settle-p. s 12 ment and. differential. settlement like a facter of one-half, 1 13 like the differential settlement might be -- the upper bound 14 might be one-half of total settlement. Inthosecasesthe[ 15 greater the total settlement, the greater the differential 16 settlement. And when ene has a large total settlement then 17 one also has to consider the likelihood of large differential 18 settlements. to So if in fact a building somewhere settled uni-20 formly six inches or eight inches it may not be of much 21 concern but the likelihood for differential settlements is 22 of concern. NdMM,8m '\\ e, e t sew. e-. _ _ _ _ y -e w w am.-esss n
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. a, -4,. n ab30 1 Q So then the real con' carn is with differential 2 settlement rather than simply total settlement? r 4( 3 A Yes, I believe that's a correct statement. I 4 believe Bechtel agrees with those items. At least their ~ 5 other applications have indicated a highly rational approach 6 to this. 7 Q In the situation of a preload of an already. con-a structed building such as the diesel generator building, 9 if analysis after the preload application were to demonstrate n 10 that differential settlements had not induced stresses 11 beyond acceptable limits, would that, in your opinics, he an 12 acceptable application? 13 MR. PATON: Could I inquire, had not exceeded 14 acceptable limits up to this time? 15 MR. ZAMARIN: What I'm referring to is differential to sett1 ment that may have been induced during the surcharge. 17 MR. PATON: Were at this point within acceptable 18 limits? Is that what you're asking? 18 MR. ZAMARIN: That's right, and not overstressing 20 the structuro. I understand he stated the concern with the l 21 preload program is that.it may induce differential settlement 22 which introduces stresses into the structure, and I'm assuming 99Gn l j i e w . #e ,.T '~w- = n a,,w, .,,,wa w-e- --m r -y," p,,-,-,---+-,y,,--.,9
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your analysis is correct based on observations of building a 3 9 behavior and based on the calculations you have made. - ",And if in fact you take the results of your computer l 10 output and you.then h' aire confidence in them, you can then 11 compare those to whatever acceptance criteria is appropriate 12 13 for that material and.for that building. 14 So it is not inputting the cracks, it's obser ring 15 that the calculatien agrees with what your eyes behold. 16 MR. ZAMARIN: Let's break for lunch now. 17 (Whereupon, at 12:30 p.m., the takirig of the 18 deposition was recessed to reconvene at 1:30 p.m. to the same day.) 20 21 22 9 e s y e
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..,_,.b. s...a-!, O n'p y.. { y 3..-- g.] ] '{ ',,.. J -.N s =,.. a.:.2 .,.... - a e - 178 y I basis,I did not have too much difficulty with Mr. Kane's 4 cb37 1 2 responses. ( l 3 BY MR. ZAMARIN: 4 Q Is there anything that comes to mind., though, as 3 you sit here now, that you recall disagreement with what ~ i s e Mr. Kane said7-Nothing that hasn't been point N out previously 7 A in depeaitions; with respect to bearing capacity primarily. e 9 Q okay. ) to As you sit here now, can you recall anything else i 11 beside bearing capacity that you might take issue wir.h as p. 12 you recall Mr. Kane testified to in his, deposition? 1 13 A That's the only thing that comes to mind at this 5 i 14 point. l 15 Q Can you tell me in what way you disagree with { l 14 Mr. Kane's testimony as to bearing capacity, as you recall 17 him having testified to it? 1 1s A No, not anything in addition to what's already i to been recorded in my deposition, the matter of appropriate 20 shear strengths, the consistency of the soils under the ]. 21 diesel generator building. 22 Q Do you agree that the drained angle of friction pen 8 e -.8/ $1.rpW*, Wee 9m*W.
.,.n._ f{. 3 '#.fM _..w. w mw -. -m 2, x,.., ....-~.~..s,.. . _...... m ......,_._m,,,_.,,.. j. 17g g.h., t_a ns a--. . w ....._ g cb38 1 depends on the plasticity and not density? 2 A I really don't know. You'll find of course that's C 4 l 3 in conflict with my previous testimony. 4 Q What's in conflict with your previous testimony? 5 A My last answer. Q okay. 6 Why'is it 5.n conflict with your testimony? I think 7 a what you have said, in fairness, on page 94 and 95 of the e transcript you said: n 10 "I would agree for static tests, those i l 11 two seem to be the correct correlations." l [. 12 "Those two" meaning the drained angle of friction of the soi.1 was a function of plasticity and not of density. 13 f 14 Is it now your opinion that that answer was in 15 error? 18 A Not in error, just I think that probably an l 17 answer "I don't know" is a better answer than~the one I gave 18 previously. 18 Q Why don't you know now? i 20 A I think that the surety and the variability of 21 the soils beneath the diesel generator building as a specific 22 topic is different than the generalities that is implied Ydedeml& S.e,
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-[ c +* Ws =,.. a;;.s ,.. a., 180 cb39 1 by relating plasticity and drained angle of friction re-2 gardless of density, origin of soils, and so forth. 3 So I would have to say for those soils that occupy 4 the highest shear stress areas beneath the diesel generator 5 building, I.do not know if the drained angle of friction does e in fact correlate as has been reported with the plasticity. . 2.440 7 Q Are you saying that the angle of friction depends 8 on shear stresses that are applied? 9 A No, sir. 10 Q " What factors, in addition to plasticity then, 11 could the drained angle depend on? 12 A The drained anglo would depend upon--
- Well, 13 generally it depends partly on density.
It depends on the 14 constituents, the properties of the soil itself. l 15 I guess part of the reason I don't know now re-flects back to an answer that I gave you with respect to two 16 i 17 different plants, GETR andt Midland, that computed roughly l 18 the same bearing capacity, grossly different drained angles 19 of friction. And my confidence, if I'ever had a lot of 20 confidence, in the relationship between plasticity and the 21 drain angle of friction is somewhat shaken by those particu-l lar analyses which are claimed to be legitimate. 22 i dMM8 I t \\ e l ,f_,.- y,;.
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fm. m a w. n.. :.- - + so in other words t. Ten your opinion with regard sb40 1 Q to the correlation between drained angle of friction and 2 plasticity has changed since the taking of the first portion 3 of your deposition on October 9th, 19807 4 f 5 A It had some influence, yes. Q You say it had some influence. I take it you're 6 [ 7 saying that it has changed. i a A Yes. You said that the drained angle of friction would 9 Q i alsodepe$dinpartondensity,dependingontheconstituents to i. 11 and the properties of scils. Can you tell me what those constituents and preper-11 ties of soils are that would cause or have drained angle of i 13 friction depend, at least in part, on density? 14 E I think we have to remember that the soils, as I 15 A understand them, beneath the diesel generator building aru to 17 quite variable. Some of the opinions have been expressed before by consultants and by sheer rationalo in terms of the ts way the fill was placed that the fill is non-homogeneous, te may have had, after compaction, some voids, contains silts, l 20 i clays, sands and other materials, and that it's difficult 21 to assign a drained angle of friction to materials composed 3 JMM[, f i f l t l O_ t v.-, __,r ,._-_-,-r_.__,-_ 4 ,..,.--.--m. e ,-..,..,.r-,y
'.,: '+% h 2 -. m.. ' Rpp.5x4F; 7.Fr :*:7f- - .,,;,.%C N-EyQ_.y5 .jQ%,^. K~; q. 4y e ?- :.v.u - ~.. ,- =- . m cs..w...,;a x...w. ..,v 182 i eb41 1 of these kinds of constituents. I'm aware, and I think others are awara that when jm 2 fk soils are not compacted in a way that is anticipated in the 3 design, that shear strength values based on drained and un-4 5 drained. tests can be in error. I believe it is fairly well known among the profession that there's a good possibility 8 7 that Golden. Dam failed because of incomplete consideration of shear strength characteristics of less than optimum com-I a 2 J e pacted fill. And my answeri changing from my previous usstimony 10 l to this testimony, is influencedby what I thought the questien -11 was originally, which means that if you had a nice sample 12 of soil and if you went through a laborato:.y study relating 13 plasticity to drained angle of friction that you would get; 14 18 a correlation that did relate with plasticity. i 18 But since I don't know the conditions under the )i ) 17 Midland diesel generater building specifically, I'm not sure anyone knows, then it's difficult for me to now answer you 18 ( with any surety that for Midland and the diesel generator le i building specifically, whether that relationship is an 8 .~ 21 appropriate relationship. j( l 22 g gem not sure that I understand your answer to my 1 i YENh_l-L, Sna, p j em. -- =m-
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-. ~. JM 183 ~.[1.'.-'. y4 M"' wes t + - - . y ' ;; *,' .,'I "N cb42' 1 question, however. 2 My question was: What properties of the soil bring 3 about drained angle of friction depending on density? Now is it your testimony that the properties that 4 5 you've listed, that is, soil being variable-- 6 A The soil is variable. You may have-- Let's. imagine, if you would for a minute, that you have a sample' 7 of soil in the testing device in the laboratory composed of a 9 alternate lenses of silts, sands and clays. If you determined the plast city of that sample it would likely be based on 10 11 the silt and. clay fraction'of that sample. And if you tested that sample and tried to place it on.the correlation chart 12 of plasticity versus drained angle strength, one could likely 13 be surprised if he found that correlation to hold for that 14 15 variable sample. 16 So to try to answer your question what charac-l 17 teristics affect it, I would say the variability of the soils l l and the density of the constituents, not only the clay con-18 stituents but'also the sand constituents would be reflected to 20 in that drained angle of friction determination. l 3 Q Since the source of all of the clay in the fill 21 at Midland is the same, will you agree that therefore the 22 hEen[=wl& Sne. l s e e f .e,.
' "' v A,. g.,, ..~.i-m.,_.aQQ.llx q n 5.....-.W.h;, _. V ;_ }g T;j ' ;;:nch.-ElaD5:;kOc -.. -. c s :> ; ..s...... ;-.. %'Vw- :1...,yy,, -,, s...o . q.,.., 184 9 plasticity of the clay would be substantially the same? cb43 1 2 MR. PATON: May I ask, are you asking him to 1 You said the source of all the clay in the fill is 3 assume-- 4 the same. 5 MR. ZAMARIN: I don't remember what I said. Did e I say it was or did I say did he agree? 7 MR. PATON: I'm asking ydu, are you asking him tio 8 assume that, or are you assuming that he knows that, or what? i 9 MR. ZAMARIN: I will ask that the question be o 10 read. (Whereupon, the Reporter read from the record 1 11 j 12 as requested.) ) 13 THE WITNESS: By sources of material I guess you 14 mean it's a glacial material? 4 15 BY MR. ZAMARIN: 1 la Q No, the borrow area. It was all scraped off and-- 17 A It's a glacial deposit is my understanding,-- ts Q Okay. i 19 A -- except for the sands that d: lifted over the top. 20 MR. PATON: Are you asking' him to assume that or-21 TEE WITNESS: I'm not finished. 22 MR. PATON: I'm sorry. l __ _ et. g M* c _ _,, + _ _ _ _..,_., _ _,
' "'$;;:.I,$ q.)*s,;;. ,['y, 2~.Myu.. _ 3.-. --=Q;g;. w_.__ a _" ' _ :I _W-m-+:M a.r -~ ya.v.:w.., ...y ; - n.-,.. "'.:.=-~. x > _ yrp& sw'q<- eC7:is j = m ~, T. :. 2= a c ".9 (*;. /;-: w - v;..,..se., r -> 4.v n.,.3, p , ~ .,_,m._ ",[ 185 0 _b -...e. :. .:--..,..,---.-c..%... ..,. ~.... [ 7. t[me.~. .,7. . 7 -,,g ~ ob44 1 TEE WITNESS: I'm iI1terpreting your question to 2 be by " source" you mean geologic source. 3 MR. ZAMARIN: That's right. 4 THE WITNESS: Thank you. s I think it is fairly well understood that materials e of geologic origin are not necessarily.the same in plasticity 7 or anything else. I believe you have materials classified' ~ s as-CE, ME, CL's; a "airly wide variety of materials. I could ~ s be mistaken. I haven't reviewed it in quite some time. 10 It was my i.mpression that there was a wide variety 11 of materials present and that they're plotted on the Casa nk 12 Grande diagram and some are above, some are below, and a very 13 wide scatter of plasticity values of those materials. 14 So I guess I would say I'm not able to conclude 15 that all of these soils have the same degree of plasticity. 16 BY MR. ZAMARIN: 17 Q Have you reviewed the plasticity chart that was ta supplied in response to Question 407 1s A T don't recall reviewing it. I think there was l l 20 some-- I believe there was information of this type back in 21 the construction permit application. 22 Q Are you aware that the data with regard to i 1 .Y U $na, h 9 a..
. 1-5- %Q-E :.: -:-&Qf([ ~ '_,}-:[}}3 . a c..s a - %:. - u- ..,... x . t v. 186 tb45 1 plasticity shows the plasticities of the clays all within a 2 narrow range? 3 A No, I'm not aware of that. 4 Q Okay. 5 A What do you call " narrow range"? 9.045 8 Q P.I. is 20 to 30. 7 A I'm definitely not aware that all samples obtair:ed a and tested fall within that band. 9 Q Were you aware that With some minor exceptions, someisol$tedcases,thatthesedatawithregardtoplasticity to 11 'show the plasticity of the clays all within a narrow range? 12 And by " narrow range" I mean a P.I. of.20 to 30. 13 A I have not seen a statistical analysis of the P.I. 14 distribution in the borrow areas or in the fill. 15 Q Have you been responding to these questions with 16 the understanding in mind that we're talking about fill on 17 which these tests have been done, that is in the diesel 18 generator building area, the tank farm area, the diesel fuel 18 tank area, rather than just the entire site including areas 20 which haven't had the plant fill placed in them? Idon'tunderstandtheqi$estion, can you rephrase 21 A 22 it or reword it, please? 9 e w-
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q.h L;:Jl er.;;7 .n.-. ~ m.74 . Q.,.......:. u s=-=. r.. ... g.w t-m. v. .,... a.,. .,9 _g ... a ' :. . a -. ..n.-......,,. .,n .s 187 .34 . ;,,..y, t :... - s"... I cb46 1 Q Okay. 2 I asked you a question earlier about whether in is 3 your opinion the fact that clay had come from the same source, I 4 from the same borrow area, would indicate the likelihood of 5 similar plasticity and I was referring to clay that had been e taken from a borrow source and used in plant fill, for example ~ i 7 in the power block area. s Is that what you were thinking of also when you s responded to those questions? 10 A No, sir. I was confining my response just to those i 11 armas beneath'the footings of the diesel generator building 12 that new have and will have the highest shear stresses im-13 posed on them. u 14 Q Okay. That's fins. That's as good a narrowing of 15 the area. I just wanted to make sure you weren't considering. to all of the area of the plant site. 17 A No, sir. 1 1s - Q If you look at just the clay in the fill beneath 1 1 to the diesel generator building and assume that the data with 20 regard to plasticity for that clay demonstrates, with a few b 21 isolated exceptions, a narrow range of plasticity, say P. I. 22 20 to 30, would you be of the opinion that the drained angle i i 1 i ,8 e .=.
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. w,, e..-~<.. : &}- QllQ.535.. 3 -Q. [';}. };b .sv- .n. 3 a.2 4 188 eb47 1 of friction would depend on the plasticity and not density of 2 that clay? p A 3 A I would say for idealized conditions that would 4 be the case, yes, sir. And I use that term because when you 5 determine the plastic index you do a number of things to that e clay in the laboratory, and for those conditions after mani-7 pulations that are done on the clay in the laboratory, yes, a I will agree that you do get a relationship with respect to 9 plasticity that does give you the trends tehat you have sug-10 gested. 11 Q You're referring to an idealized situation, but j 12 any time you go outside of the laboratory and try and apply 13 the laboratory results or any kind of a standard from the w i 14 laboratory to the real world.you're getting outside of that 15 idealized situation, aren't you? 16 A For some kinds of tests you do; for other kinds of 17 tests you attempt to minimize that, yes. i 18 Q Well, of course you'll attempt to minhnize it but 19 as soon as you get outside to the real world you are no longer 20 under ideal situations that you can have undier laboratory C 21 control. Would you agree with that? 22 A In part. an - ee espe ams. e-e nsemeae + - -. - -sm- ,m. ve
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~ -.--n., S cb48 1 Q In what part wouldn t you agree? 2 A When you attempt to reproduce field conditions in (. 3 the laboratory, there are a number of precautions that can 4 be taken, a number of corrections that can be.taken to 5 minimize the effect of laboratory operations on the results 6 that you obtain. 7 For the case of relating shear strength -- I 8 should change that -- drained angle of friction, which is a 9 measure of shear strength through the plasticity patameter, you have 2ecided to perform a certain set of laboratory to 11 manipulations to th'at soil sample that can seriously alter ~ p s 12 the field situation. 13 I'm agreeing with you that the correlation is 14 there. I'm qualifying it with respect to its complete appli-15 cability to the situation va're t:."f ng to evaluate, bearing i 16 capacity. 17 Q I take it you're qualifying it to the extent that 18 the laboratory test recults may not be reliably representative 18 of field conditions as it relates to the factor of plasticity. 20 A Rather than " reliably" we could say that the soil 21 constituents have been massaged, physically massaged by the 22 laboratory procedures that are used to establish plasticity. YEd ml&m, cTna.
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.., a:, P 190 cb49 1 Q And are there standard methods used to correct or 2 account for this type of disturbance that occurs in this k 3 laboratory _ testing you refer to? 3.170 4 A I'm not aware of the corrections, no, sir. 5 MR. PATON: Off the record. 6 (Discussion off the record.) 3.190 7 MR. ZAMARIN: Back on the record. 8 BY MR. ZAMARIN: 8 Q Do you know whether the plasticity index is a n 10 generally accepted measure in geotechnical engineering? 11 A I believe it is, yes. 12 Q Is the correlation between the plasticity index 13 and the drained angle of friction a generally accepted 14 correlation within the geotechnical engineering field? 15 A I don't know. It could be. 16 Q Okay. 17 Do you agree that friction angle for sand is re-Is lated to the blow count or relative density of the sand? to A It can be related to either. 20 Q. You say that it can be related. And your testi-b 21 many is that it is related to either blow count or the rela-22 tive density? dMhm, $w. -:e asumus e as
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~ f .. ~. : - mhl.'.':....:.n:;..a..,.e-Q. .. e w y';< .e.: .._.....~.-..s.. 191 y t.2..- n,..,, i cb50 1 A It can be related to either blow count or relative 2 density. 3 Q By that do you also imply that it cannot be re-4 lated to either blow count or relative density? 5 A It depends on whether you accept the correlation 8 between the two parameters that you've mentioned, blow count 7 and relative density. 8 o Im sorry, you're going to have to explain'that one e a little more. I don't understand what you're saying. 10 A I believe you mentioned three parameters: friction 11 angle, blow count,- C 12 Q Yes. 12 A - and relative density. o 14 Q okay. Let me break them down for you. 18 Do you agree the friction angle for sand is re-- 18 lated to blow count? 17 A In part. is Q In what part? 18 A Well, blow count depends on many parameters. One 20 of them can be the friction angle. 21 Q could it depend on things that totally exclude 22 friction angle? l Ydedeel& Sm
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. <. ~ ~. r v.. a.; u 1o? cb51 1 A Yes-- I'm sorry, you were talking about sands only ? '~ I. 2 Q Yes, just sand. ( 3 A Then the answer would be no. 1 4 Q Now with regard to just sands you say that friction 5 angle is related only in part to blow count? 6 A Yes. 7 Q And what else is it related to? s A It's related to usually the depth of the investi-8 s s 'l 9 gation which is a measure of the confining pressure on the 10'- sampler. sit can be related to the sampler itself, what kind-11 of sampler you're using. It can be related to the operater 12 who is performing t',e investigation. It cui be related to 13 the types of equipment, the length of the drill stem that's 14 being used, the type of hammer.that's being used. 15 There are many parameters that affect the blow 16 count in a penetration type investigation, and friction angle 17 .is cely,one of those. 18 Q With regard to the properties, the physical 18 properties and the engineering properties of the sand, will 20 you agree that friction angle is related to blow. count .i.250 21 determinations with regard to that sand? 1 22 A Could you repeat that, please? d/.ro/ hm,8=s. 1 9 0
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., = _ - - - + .s eb52 1 MR. ZAMARIN: Will you read it back? i i [.- (Whereupon, the Roporter read from the record 2 1 \\ 3 as requested.) 4 THE WITNESS: It's related, yes, sir. 5 BY MR. ZAMARIN: 6 Q Do you agree that. friction angle for sand is 7 related to relative density of the sand? 8 A Yes. s Q , If you know the relative density of the sand could youthenbetermi.nothefrictionangleofthesand? 10 11 A If I had a suite'of laboratory tests I could re-12 late the relative density of that sand to the friction angle, ~ 13 yes, sir. u 14 Q Yott said if you had a what? 15 A A suite of tests on that particular deposit of to sands, yes, I could. 17 Q What do you mean by a " suite" of tests? 18 A A series of tests conducted at different relative 19 densities so as to establish a relationship between friction 20 angle and relative density for that particular sand gradation, 21 grade size, D50's, Dio's, angularity of grain and so forth. 22 once you have that correlation then you can go in with a w 4FEr Fide x l 6 m-m e e 'e
~ * .x..- .. y y,= _xO.. -m::. - r .-e, ..,. :=;. -4.575.c_- y.;.;+ .. q.. g. __g ~. 4 -+ -ecw. :-. ..s,.. 194 cb53 1 relatiye density value and pick off a friction angle for that 2 sand. 3 But you need the test values to establish the 4 correlation. 5 Q Are you aware of any commonly accepted relation-a ships between relative density of sand and friction angle of 7 sand, in other words such that you don't have to, in each instance, go through and develop yob own standards for ccm-8 8 parison? 10 A I believe there are published results of averaged 11 laboratory tests on certain types of sand. I believe that's 12 true. 13 Q okay. l' Would you think that competent geotechnical en-15 gineers use those in estimating friction angle from known 16 relative densities of sand? 17 A I assume they're used, yes. 18 Q 3efore when I asked you about things that had an 18 effect on or were related to blow count determinations you indicated.such things as confining pressure on the sampler, 1 21 the kind of sampler, the operator, the drill stem, the hammer 22 and the types of equinment. l 0 5 d d a d & S m. l y, -w e ,..-e.- m '-*y e - - 9- + .-.w-- - - - + g.ic- --g w-e n env-f e e-
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~- q-b- ob54 1 Are you talking about limitations on obtaining 2 accurate testing results? i 3 A No, I'm talking about correlations - factors that 4 affect correlations between blow count and friction angle. 5 .Q okay. 6 But it seems to me that the things that you have 7 listed were all things that, rather than being properties 8 of the soil, are actually functions of the testing process. 8 Is that right? o 10 A I believe it's necessary to consider those because 11 blow count has no meaning in the laboratory sense. It's a r~ 12 field investigation tool. 13 Q Ch, I see. u l' So what you're saying is that all of these things 15 are taken into account or have.an impact upon the force that 16 the hammer exerts or the blow the the hammer exerts and 17 therefore it's part of the measure of how far the sampler is 18' driven? 19 A Yes. 20 Q I see. 21 Are there commonly accepted relationships to your 22 l knowledge in the engineering field between blow count and i l t I _[ b,
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3 published relating blow' count to relative density. There is 4 also controversy among the researchers and professionals with j 5 respect to the universal applicability of this correlation. a Q Is the relationship between blow count and rela-7 tive density a generally accepted and commonly used standard 8 within the geotechnical engineering field? s A I think the profession is probably split about 50-50 on Shat question. I think in certain cases it's use-10 t ful and may be relatively" accurate and in other cases, certain 11 r( 12 precautions should be taken in interpreting results of such 13 tests. s 14 Q In what types of cases would, in your opinion, 15 the blow count-relative density relationship be accurare? 16 A It should be fairly accurate where the conditions-17 are.similar to those laboratory conditions for which the la correlations have been established, and by'that I mean the 19 field conditions should be reasenably consistent with the 20 conditions that'were established in the laboratory tests, 21 Q Give me an example of the conditions to which you s 22 refer. M hars,8ns. x y j. 9. yi-e. 9 e u*- -y,g y.-- p.- -^h..-
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ob56 1 A Well, to my knowledge there are at least two sets of investigations that have been conducted to relate rela-2 3 tive density to blow count, those that were done by the Bureau of Reclamation many years ago and those that were 4 performed by the Army Corps of Engineers in the past half a 5 I e dozen years. In both cases attempts were made to carefully 7 measure applied pressures and to control the energy that went a e into the sampling spoon. Where field samples are taken and where the grain 10 size distributions and saturation conditions are s N lar, 11 they probably can be used with some degree of confidence. 12 otherwise some precautions ishould be taken to assure that 13 judgments are made on the proper side of those averages ob-14 15 tained under other conditions. 16 Q What precautions are you referring to? 17 A I +Mnk we have to be assured, for example, that all of the energy of the hammer is received by the sampling 18' '19 specn is one precaution. 20 Another precaution might be the angularity of the grains, gravel particles that might be present in the materialt 21 U that would affect the blow count in a non-conservative manner. Nd.c#. elm $w. e
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- m - ,, ;.. m.sj;?.jL*g. 75;_.y :.-- y,[ ', ~} .- w w.. x 1oo eb57 1 Probably angularity of the grains is also an aspect ,g-, 2 that has.not been investigated but becomes a problem when s, 3 you're investigating tailings dams, for example. 4 Q You believe angularity would be a problem in in-5 vestigating blow counts of sands in the fill at Midland? 6 A I'm not familiar with the sands that were used. 7 I believe they were all imported, if I'm not mistaken. I 8 believe the sands were all imported for fill at the Midland 9 site and I'm not familiar with those sands. I don't have an w to opinion on that. 11 Q Not knowing then what the sands are with regard C. 12 to ths fill.at Midland, do you have an opinion as to the 13 relationship or correlation between blow count and relative 14 density of the sands with regard to Midland? 15 A Could I have the question read, please? 16 MR.. ZAMARIN: Would you read it back, please? 17 (Whereupon, the Reporter read from the record 18 as requested.) 18 THE. WITNESS: I have an opinion but it would be 20 subject to substantiation by a more detailed review. 21 SY MR. ZAMARIN: 22 Q What is your opinion? O m/-el h-=, 8rw. j '=- v ,I
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C-;..? n T.. gr.e~,,- 'M+%W ' ~ M O "'; y n a $ 7 '.v.:'O "- : v " y'.. Nfq@] s $; 2.x @ Wr/!O i3[, - -'~:~~- '-~': ~~~ ?.w. :~.,. g: .. =. ,,x-....,. y/ 199 < ;. :.. m. z:. .,.........,,,...,n..,,..,.,_,. [,,( %jcn .e ~., .p sb58 1 A Well, I think the sands up there are fairly well 2 rounded. I think they reasonably fit into the kind of l f a correlations that have been made previously, and I personally 3 4 would not have a problem with using the normal relationships between blow count and relative density at the Midland site. 5 6 Q Do you agree that the friction angle for clays 7 from the same borrow source and having a plasticity index 8 between 20 and 30, and there are only a few exceptions in 8 that range, should be about the same for all of those clays? 10 A I don't have any reason to disagree with that I 11 statement. No, sir. 12 Q I don't either. 13 In your previous testimony you had stated that in 14 some past cases a preload was unsuccessful. Can you tell me 15 in what past cases, and in what way the preload was unsuccess-16 ful? 17 A I was referring to an article in the ASCE acurnal 18 that we had discussed earlier, and I believe the title of it is " Design to Minimize or Prevent Settlements." And there ~ 18 20 is a paper in there -- I believe it was written by George j 21 Sowers - that described a case for, as I recall, an ai-22 field runway in which preloads were applied, monitored not dadeelh. e, 8==. l i
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^ 200 sb59 1 unlike,the situation at Midland, and the result was not as 2 expected.
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Q You say the result was not as expected.
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I believe you also testified previously that you know of 5 no case where settlement after a preload exceeded the pre-8 dictions, didn't you? 7 A I believe Professor Sowers' paper does indicate i 8 that settlements-after the preload was removed were larger 8 than had been anticipated a't! the time of the preload removal. 10 Q Could you supply us with some kind of a cite to 11 this compendium of literature? 12 A. He's got it right there. 13 Q That was quick. u 14 A I think he's read.the entire Journal. 15 (Document handed to Mr. Zamarin.) 16 What was the correct title, just for the record? 'I7 Q This is Journal of the Soil Mechanics and Founda-18 tions Divisien, " Conference on Design of Foundations for, i 19 Control of Settlement, Proceedings of the American Society 20 of Civil Engineers, conference in Ivanston, Illinois, June >b 21 16 - 19, 1964." And the citation to this is Volume 90, 22 Number SMS, September.1964, Part 1. YEN &ws, Sna. e b--~.m. w.-. - =-.. ~ -s m . =. -.. .....: n
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.m 201 g.s. _.f:=. ~ e- :.m. .j 7,. ...g i ab60 1 A Thank you. 2 Q Was the air field preload that Sowers reported (- 3 applied for the purposes of compacting or consolidating fill 4 material? l-I'm not sure whether it was fill or whether this' 5 A was a natural soil deposit that he was compacting. I suspect 8 7 it was a little of each. 8 Q A little earlier we talked about differential 8 settlement and.preload programs, and you had indicated that 10 a major reason for lack of widespread use of preload is the 11 potential for differential settlement. 12 Does this differential settlement to which you 13 refer occur during er after the preload, program? I' A Most of it should occur during the preload program. 15 There may be a small part, hopefully a negligible part, that 16 would occur after the preload is remov'ed. 17 Q And then the preload program, by accelerating ta settlement, would also accelerate any differential settlement to that you would expect, wouldn't it? 20 A It would occur more rapidly. Yes, sir. 21 Q And once soils undernearth the structure entered 22 inro secondary' consolidation, could the maximum future YEmlnel& Snr. 9 9 e
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... v ~. - - - -.. - x..x ? . -: p.y.2w:;~. - ^ Je:::? . ~.. :x -, M::=ws: t :~;;:.';9; =4- --g '.. z.,;-K.:f' y' me.< > -. x ..a,. l 202 e l eb61 1 differential settlement then be accurately predicted? 2 A It's possible that it could be accurately pre-3 dicted. 4 Q What is the technique or the procedure that one 5 employs in generating an E versus log P diagram or plot? 8 A The procedure? 7 Q Yes. In other words how do you go about construct-8 ing a plot of I, which I take it is void ratio,-- 9 A Yes. 10 Q -- versus log pressure plot. 11 I mean you've got something in the lab -- right -- h 12 and you get some kind of data and then do you do something 13 with thau data first, or do you put it gight on a graph 14 paper and can you just really describe for me the process that 15 you would go through in generating an I versus log P plot? 16 A Well, first you need a specimen of soil to work 17 with to test,~ and it is not uncommon to cut that sample from 18 a Shelby tube in the laboratory using a cutoff saw, extrude 18 the resulting sample of soil into a odometer which is a one-20 dimensional consolidation device, place a~ stone and a cap on i 21 top of the sample with a stone in the bottom to provide a l 22 drainage path for the water to be squee=ed out of the sample. l l l ree. x l ~ 1 I I L-
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,t. - ab62 1 The void ratio, initial void ratio would be deter-2 mined from generating an adjacent specimen of soil that is (m 3 considered to be essentially the same as the soil in the 4 sample, perform the drying and so forth, the weighing that is necessary t'o establish the voids that are present in that 5 vahe 8 soil so as to get an E va ue -- m sorg, not an E0 O 7 but an initial void ratio value. 8 At that point, load is applied to the sample and O the movement of the top cap downward indicating ccmpression inthesa$pleisrecorded. 10 D4 11 A given load is' held on that sample until the dial 12 indicator indicates essentially no additional settlement. 13 When that's the case the load is increased to a new value and u 14 the observations are repeated to obtain another set of data. 15 And this continues progressively until you've reached a 16 reasonable expectation for that sample of soil under the work-17 ing. conditions that it will see in the field. 18-At that point there is no need for additional 19 application of additional pressure. 20 The data thus obtained is then plotted relating L 21 the dial indicator reading in the odometer to the void ratio 22 that would necessarily be present in that sample versus the ~ Ph$. [ e
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. ;,; -:z - a .,:x.w.p ;-. g .Av. . a:.2 2nd p. eb63 1 logarithm, I believe base 10, of the applied pressure. And 2 you have then an E log P curve for increasing loads on that ..s. ( 1 3 sample. e c3 4 Q When you're reading the dial indicator are you 4.020 5 reading the displacement of the sample, the change in volume 6 of the sample? 7 A Yes, you are. 8 Q And are you saying then that you plot the change 9 in volume of the sample versus the logarithm of pressure? o 10 A No, the change in volume is interpreted as a 11 change in void ratio. There's a relationship between the 12 dial indicator movement which indicates change in volume, j 13 total volume, to the change in void ratio so one calculates 14 the change in void ratio from the movement of the dial 15 indicator that indicates the depression of the sample that i 16 you're testing. 17 Q Could that relationship or that conv'ersion to void 18 ratio be obtained by plotting change in volume versus log i 1s of time and then the data point for void ratio be taken off i 4 _O that plot? 21 . A I'm sorry. " Lot of time" came from somewhere-- 22 could you repeat the question, please? I didn't understand Nd./ /M e7, i l T' w. p 9 y 9 v3-- .,.-y w-7-y., -.g ,- > = y .cj = ,yy
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"~ ~ ~ ~ . - - -'~~ ~ (; .;,,.x. s,. ;. s:;-:.wcr o. - * - - m- ..,,.,.y ,,.,s. y_, i ; v.:. :. r.:. ;...e.,.. m. ~.~ + w -.-n... . -,.. ~.. 4 gn5 , ;p .s . y g. -.. 2. ~.,... -.. _. .y y, g 2 ob64 1 it. 2 MR. ZAMARIN: Would vou read it back? (Whereupon, the Reporter read from the record 3 4 as requested.) 5 THE WITNESS: Yes, a series of tests of that type s 6 could be used to c'.etermine the void ratio at different pressure. 7 values. 3 BY MR. ZAMARIN: s Q You indicated that you apply a load until there to is no additional movement of the top cap. Is that correct? 11 A I t-hinic there is' some rate of movement allowed in = ( 12 the ATSM specifications but I don.'t recall what that rate of 13 movement is. It's a very miniscule movement. u 14 Q Is there sone kind c ". a plot that one generally 15 then does in order to determine when there is no longer any to movement, or when the rate of movement has become slow enough 17 to stop the test? 18 - A I don't recall what the testing specification calls 19 for. I think it's with respect to the dial movement but I'm 20 not sure. L. 21 Q okay. l l 22 Do you have any reason to disagree with that plot Y E edwel f '., $ns l [
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. p,p g-g?k A-;-3-O-- ~# n ~~ ....,,n. 206 eb65 1 being displacement versus log of time? j j l,. s 2 A Displacement of the tc.p cap? .( i 3 Q Yes. 4 cA Versus log of time? 5 Q Yes. 6 A No, I think the specifications for the test giva 7 a dial reading, change in dial reading versus time for 8 stopping the test. I believe chat's right but I'm not sure. 9 Q Are you familiar with the document called "NAV?ACS o 10 DM-7"? I 11 A Yes, sir, I have a copy of that. 12 Q Could you provide us with a copy of that through 13 Mr. Jcnes or Mr. Paton? I would have asked Mr. Kane for tha-14 since he had referred to it in his depesition but they didn't i 15 want me to ask him. to A It's a commonly available document. Would it be 17 out of order-- Let me ask Counsel. Is THE WITNESS: Would it be out of order to tell them 18 where to get a copy? 20 t. MR. JONES: Yes. Go ahead and tell them where'it b 21 is. i 1 22 MR. ZAMARIN: It may be more commonly available N d./-el h, 8a l 1 l +. * +=r.%. .v-Pasasym - 1
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.. -...,= .;M ..n -, - -.. ~ ._...s. - W 207 p S;. c. m-g.m = 1 eb66 1 to you. guys than to us. 2 BY MR. ZAMA.RIN: 3 Q Where would we.be able to obtain one? ~ 4 A You can obtain one from the Department of.the 5 Navy. I believe it is now called Naval.. Facilities Command. 6 Their telephon*_ number is in the directory. I'm not at all 7 sure it's not available in book stores in the technical text-a book section, perhaps at IIT or the University of Michigan. 9 MR. JCNES: We will provide a copy of NAVFACS DM-7 to tomorrow crning for Mr. Zamarin to look at. It's evidently 11 a rather thick document so, rather than copying it, we will 12 provide :.t tomorrow. 13 MR. ZAMARIN: Thank you. u 14 BY MR.. ZMARIN: 1 i 15 1 Q At your previous deposition session you made la reference to the possible existence of fat clays beneath the 17 diesel generator building. Do you recall that? 18-3 y,,,
- sir, 18 Q
And in your opinion do fat clays exist beneath 20 the diesel generator building? ,'v 21 A I don't know. I assumed that there were some clays 22 classified as CH that were discovered in the area. .I don't j l ~ \\ P.- j ..I
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..~,. ..; v.. a. 208 l l l ob67 1 know that there were any beneath the diesel generator build-l l l 2 ing. There were some pocket penetrometer tests that would 3 indicate materials as soft as one might expect a fat clay to 4 be. t ( 5 Q Are you familiar with the reported plasticities cf 6 the clays beneath the diesel generator building? 7 A Evidently not. 8 Q Okay. 9 Are you aware of piezometer data which would suggest be presence of fat clays beneath the diesel generat'or to 11 building? 12 A I dcn't know that piezometers wocid indicate the 13 presence of fat clays beneath the diesel generator building. 14 Q Are you aware of.the liquid limits of the clays 15 underneath the diesel generator building? 16 A I have not reviewed that data, no. 17 Q Are you aware of the theoretical shape of the 18 settlement versus log time curve for a fat clay lens? 19 A Could you repeat the question, please? i 20 g
- yes, 21 Are you aware of the theoretical shape of the 22 settlement versus log time curve for a fat clay lens?
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' e.. y. 5..=: .:.a-s ob68 A I think that that was discussed at the previous 3 deposition. I believe that I attempted to sketch what I 2 thought was the shape of a settlement log time curve that would 3 result. I'm not sure what you mean now by " lens." Layer? 1 4 l Fat clay layer? Was that the question? g Q Yes. I said " lens" but by that I mean a layer. Is a lens the same as a layer in your parlance? 7 A It's close enough. 8 ~ ~ Q Okay. It's d.ose 'enough in mi se then, too. g " would you agree that the theoretical settlement .,, j a log t'ime curve for a lens at a layer of clay or a deposit of 11 (. clay has a point of inflection at about 75 percent consolida-12 . tion? 33 u A I'm not sure if it's 75 percent censolidation or g 50 percent, or what the number is. There is a change in 15 16 slope in the time settlement curve. I'm aware of that, yes. j7 Q okay. Assume for a moment then that the theoretical 18 19 settlement log tima curve for a lens or slab of clay has a 20 point of. inflection at about 75 percent consolidation. Fcr C 21 time shorter than that corresponding to that 75 percent 22 consolidation, would in your opinion the curve band downward', i PDE. l 1 b -- =
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. ~.l. : K - W6b5*3.?E.Eh - &@h, __gl,l- (.d'.-T-%-f:-? - " ~ " <-Uw c.,a 210 ob69 1 and for times greater than those corresponding to 75 percent 2 consolidation, would the curve bend upward? 3 Let me withdraw that question for a moment. There 4 may be an easier way and a fairer way to do this with you, 5 rather than to ask you-- 6 A I'm trying to plot what you suggested. 7 Q Yes. And maybe if I just.... 8 (Discussion off the record.) 3 MR. ZAMARIN: Will you read the last question back, n 10 please? 11 (Whereupon, the Reporter read from the record 12 as requested.) 13 THE WITNESS: No. u 14 BY MR. ZAMARIN: 15 Q For times shorter than that corresponding to 75 18 percent consolidation what, if any, behavior would you expect i 17 the curve to display? You apparently disagreed that it would 18 band downward. Do you believe it would bend upward for i l times shorter than those corresponding to 75 percent consoli-18 1 20 dation? 21 3 73, 22 Q And for times greater than that corresponding to e _[ _ U -.y Pt&
..~n ..,.:. _n. --.:- y 9- - ~., w .L m n w y..::.; ~ -~r' f ~ 5 % f k & tf f f y[ f f l l h;.. :5'EAN ~%E3bf!}{ . ~l: - . ~ -~ 'W:. w-: s, n.r:w.,-v.= -,. = -. .g. ~wu....:., ,-..,.,~-n.n..... .e. ..w y 2il F. _ u;cs.8 =,= a..; s k;p. ob70 1 75 percent consolidation, is it your opinion that the curve 2 would bend downward?
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4 A Let me rephrase my previous answers if I may. 4 Q All ri..:. It may improve upon this bending downward, bending 5 A s upward situation. 7 It would be my opinion that a curve representing 8 settlement versus log time for consolidation values greater 9 than*75 percent might well be close to a straight line where n 10 that straight line would still, in my view, be aimed down-i 11 ward but the derivative of that curve would have a negative 12 slope. 13 For times greater than 75 percent consolidation, 14 I would expect the curvature,of the representation of con-15 solidation to be - rather, to have a smaller radius and the l 18 slope of that curve would have a larger negative value. 17 ' With respect to being upward and downward, as the l 18 question was phrased, I probably have misinterpreted the l 1 to geometric figure that you represented in your question. I 20 hope that my answer has included your question. If not, I'll 21 be glad to explain.it. I 22 Q What is your understanding of what is meant by YEadmel&m, Snc. i i .um-p., .a+-A. s y u u m muum. .,c. w.-e,,_ .*-,p.
A *: :1: ..m.;.J;=a55.25 _- -9 =-j-.g,... __ ;_:-: Q.-p a .,g,, 5z;y - ;%::'~~r - e:2., ...,;a. = 212 ab71 1 the point of inflection? 2 A A point of inflection is usually a term related to L 3 structural engineering and it means a point at which the l 4 radius of curvature is infinity, and that the slope of a s tangent to those two lines changes sign. - 4.260 6 Q If there were a very thick fat clay lens-- Strike 7 that. 8 In your opinion do there exist lenses of what you 9 have described as fat clays under the diesel generator build-inginthdeknessesoffivefeetormore? to 11 A I don't recall seeing any boring logs that would 12 give a consistent classification of clays located anywhere, 13 including the diesel generator building that would be that g 14 thick. Those zones that might be lenses layers that.might 15 be considered to be soft clays did not appear to have an la extent of more than perhaps a few inches, maybe as much as a 17 foot.at the maximum. 1s Q Would you expect the existence of fat clays of to thicknesses such as you've just described, and that is perhaps 20 as thick as a foot, to have more than a~ negligible effect on f( 21 the linear portion of the settlement log time curve for the '22 diesel generator building? i v \\ Rupeemesh - m ,--an-,- n+,-,n-,- -,n, +a n, - - - -, -,-,--...----,-,,.-,--,,,-,,,,-~....--,,,,-,n ,, -, -, ~ -
\\ ...~.n.... b 'Yb ~ . -- r -r ~ - n t.mw - w-w - n,.,,,,_.__ _ _ ,,.y t..: w. _ :.. ...y r, ..,,.c ., m....,.. m. _.,,. _,.,.., . - =. .V 213 .e - j y;It =.: -, sb72 1 A If there was only one layer that was a foot thick, 2 it wouldn't have a lot of influence. Maybe a half an inch 3 of settlement would be all that could be attributed in the 4 future to that particular lens. 5 Q You're saying with regard to a-lens that's no a more than a foot thick that you believe that as much as a 7 half inch of future settlement could be attributable to that? 8 A It's possible. In that range. 8 Q What is your basis for that estimation of half'*an 10 inch? An also I might point out that my cuestion was.with 11 regard to the settlement versus log time plot for the diesel 12 generator building after surcharge and during surcharge. 13 What we're talking about is future settlerent after the sur-14 charge program. I just want to make sure we're talking about 15 the same animal. 16 3 7 m not sure we're still talking about the same 17 animal. I understand two pieces to the question. One, what is is the influence -- what would be the influence of a hypo-18 thetical one foot thick layer of fat clay during the preload 20 program. I see that as one part of the question. L 21 The other part of the question: What would be the 22 effect if there were a fat cla'y of thickness one foot after l
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. =, 94 y. ; ' 3: r:- -{- ... [. -?,.:... 4.% 2 L* Q- { y ; _-- Q Q - [ .z., _:Q. "^ f s vv. -n . cy;... ,..e4 f 214 cb73 1 the surcharge was removed and during the life of 'he power o 2 plant. 3 Q Is my understanding correct that if a lens of fat 4 clay of no more than a foot in the fill beneath the diesel 5 generator building would have only a negligible effect on the a linear phrtion of the log time settlement curve then it should 7 have only a negligible effect, if any, on future predicted 8 settlement based upon the log time curve? 9 A The log time settlement plot that we are talking aboutIa$sumeisthatonethathasbeendeterminedforthe to fill of the diesel generator buil'ing during the time that d 11 12 the preload was applied. 13 Q That's correct, during the time that the preload 14 was applied and also subsequent to removal of the surcharge. 15 The plot continues through the period after remcv.a1 of the 16 surcharge. And yes, that is the plot to which I refer. o 17 A To answer the question requires the assumption. 18 that that fat clay lens was a part of and underwent the same 18 settlement log time behavior as the entire mass of fill. 20 That's probably not a proper interpretation of the behavior. 21 For the five months that the load was on the fill it's not i l l l 22 likely that the fat clay would have reached the end of its Flf. \\ e um m.
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f ob74 1 primary consclidation and so it would be still available to undergo additional consolidatien resulting in additional 2 3 settlement after the preload had been removed. 4 And a one-half inch value that I. threw out as an 5 example of a possible range of consolidation of a one-foot-a thick hypothesized lens is based on an expectation of perhaps 7 a five percent settlement within that one-foot thick lens. 8 Q If the slope of the settlement log time curve for 9 a fat clay was less negative than the slope of the over-all w 10 curve for the fill at some point in time, would that fat clay i 11 lens in your opinion affect a prediction based upon the over-C 12 all curve, that is, the curve including that fat clay lens, 13 in an unconservative fashion? u 14 Do you want to hear that one back? 15 A Yes, please. 16 MR. ZAMARIN: Would you read that back? 17 (Whereupon, the Reporter read from the record 18 as requested.) THE WITNESS: It would a.ffect it in an unconserva-20 tive manner, meaning that the settlements expected in the i 21 future would be larger than anticipated by interpreting the 22 settlement log time curve of the entire fill. 1 r O g-N m__ n
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m. ... ~ r.. :._ - r . ~ --. -,:- .f~ ppg-i29. a % - --n- ~ ..,. ;.,.s q m9.r. (..3 :.- y =- ~ _ ; ~:g J' a ~ ' .: V Y. :c...,,n. .e 216 cb75 1 BY MR. ZAMARIN: 2 Q And upon what do you base that opinion? 3 A 'The sketch that I have prepared that I think 4 represents the question.that was asked hypothesizes that at 5 some point in time, and I'm taking that as the point where 6 the preload was removed, that the slope of the settlement 7 curve for the curve was less negative than the slope for the 8 fill as a whole which to me, at this point, would mean that 9 the degree of consolidation of the clay layer would be less thanthebegreeofconsolidationofthefillasawhcleand 10 11 the.refore, at sema time in the future - I'm sorry -- at 12 increasing times the clay would still have the potential for 13 additional consolidation and therefore, the total settlement 14 of the fill would increase beyond that anticipated by an 15 extrapolation of the settlement log time curve for the entire 16
- gill, 17 Q
Can I just see that diagram to which you just la referred in that answer? I would like to mark that as an 18 exhibit. Since you're referring to something over there it's going to look funny in the record unless we know what it was b 21 you were referring to. 22 A All right. i a>C/
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..m ;,,. _.,.m.-.,_.....m,,,,e.,m.._,_,.. .( => 1 =7 . ?.'<,:. _, u" n,..,... .r. eb76 1 May I label it? 2 Q Sure. Do whatever you want with it while we go C 3 off the record for this discussion. 4 (Discussion off the record.) B5 3 MR. ZAMARIN: I have marked as Exhibit Number 7 6 for identification as of today's date the diagram to which 7 you have just referred in answering my previous cuestion. 8 (Whereupon, the document 9 referred to was marked s. 10 as Exhibit Number 7 11 for identification.) 'a 12 BT MR. ZAMARIN: 13 Q Is that correct? e u 14 A Yes, sir. 15 MR. ZAMARIN: I would also like to mark as Exhibit-to Number 8 the previous diagram that you drew when you were 17 drawing those settlement log time curves. 18 THE WITNESS: I think we need to confer on that. 19 (Discussion off the record.) 20 MR. ZAMARIN: Weren't those settlement log time L 21 curves? Let me take a look at it first. 22 MR. JONES: I don't care if you see them, but I d/relM8ns. l j
' ;'9; *..: i . --.,.. w a m. :py d x+5 a' Jr:c - % ' .+n.K .%f = ;,.'Z:QT.'*L.t':: --Q.Q f.'. 7.. g,p g 2 L% -:- e,::,, c ,.c, 218 f-isb77 1 don't know that they should be introduced. 2 THE WITNESS: Those refer to previous questions -- 3 attempts to answer your previous questions. 4 MR. ZAMARIN: I understand that. 5 We will mark it as Exhibit Number 8. 6 (Whereupon, the document 7 referred to was marked 8 as Exhibit Number 8 9 for identification.) 10 MR. ZAMARIN: We understand this referred back to' 11 previous questions. 12 BY MR. ZAMARIN: 13 Q If a piezemeter were located,in an area of fat 14 clay, would you expect to se.e a high pore pressure reading in 15 tlutt piezameter under the surcharge conditions? 16 A It would depend on the type of piezometer that was 17 installed. 18 Q Okay. l 19 How about a Casa Grande type piezometer? 20 g With,an open piezemeter one would expect a very V 21 l small r,esponse because of the need to squeeze a large volume 22 of water out of the clay, and there would be essentially no l l 8F9e F98. l x .O l l
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~. [,e.y_. sf ;;w. =:. u W 91o Eb78 1 response. 2 Q And in a closed type piezometer you would expect 3 to see a more sensitive or a greater response? 4 A Yes, sir. 5 Q Do you know which type of piesameters were used a with regard to the diesel generator building surcharge at 7 Midland? 8 A No, sir, I do not. 9 Q Where on the Midland site have you observed, if n to anywhere, dry-placed fill or..apparently d / fill? 11 A I have cbserved fill materials in the excavations 12 that were made in the diesel. generator building to expose the 13 conduits that had been bonded.to the footings of the diesel u 14 generator building. 15 I observed fill in a test pit that was excavated 16 adjacent to the service water prmp house and in a test pit 17 excavated I believe to the east of the auxiliary building to la investigate the condition of fill related to a ecmpressed air 19 line that had broken and created a bubbling phenomenon in the 20 fill and water in one of the trenches. C 21 To my knowledge, those are the only observ ions 22 of fill material that I recall at the Midland site. YNN&% $ne. A s I. q.
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~ . w.- ? <. s y-3;;;.., s s 220 - ~ eb79 1 Q, What did you notice about the fill that was re-2 vealed by the excavations inside the diesel generator building 3 A conditions for observation were not ideal. As I 1 4 recall it was winter and a protective cover had to be put 5 cier the working area. Artificial light of course was neces-6 sary in the excavations. And about the only thing that could 7 be observed there was the displacement between the bottom 8 of the footings and the top of the fill, a void of some s } 9 lateral extent between the footing and the fill. 10 I observed some large-grained material in the cla'y 11 fill. C 12 Other than that, that's all the observations I 13 recall. u s 14 Q What was this large-grained material in the clay 15 fill that you observed? 16 A It was a -- I would call it a cobble, part of the 17 glacial material that was used to fill that area. 18 Q You say you saw r. c; >1e? 18 A One that I nod %a. a.:c, and a number of others 20 that were observable in the face of the excavation. (U 21 Q Can you describe this cobble for me so I would knew 22 it if I saw it? l l I .L G.L.i %. L I s ( T
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, wm s... }.' 2 = >.e.m s- .. y ' :, -.r'~% sb80 1 A I can bring it tomo $ row if you would like to see 2 it. 3 Q Oh, you've got it? 4 A Yes, sir. 5 Q All right. Well, why don't you describe it and 6 then tomorrow we'll find out whether I would know it if I saw i 7 it. 8 A It's roughly the size of a Michigan grapefruit ^ 9 and it's grayish-black in color. It's rounded and has some chipsin$t, indicating that it had been involved in glacial 10 11 processes many years ago and would be of the kind of material 12 you would expect in the borrow pit areas used to construct. 13 dikes and fill and so forth. o 14 Q What's the size of a Michigan grapefruit? I've 15 never heard of that. About the size of a 12-inch softball? 16 A Approximately the size 'of a 12-inch softball. 17 Q And was this hard material like 'a rock? 18 A Yes. 18 Q Did you observe what you would consider to be dry 20 materials or materials that in your opinion had been placed ( 21 dry while you were looking in this excavation in the diesel 22 generator building? YNU&m, hna. E S We,.. - - -,,_
.. ~ ~..a+: c.. =. :.a,.. m gr.-YW ~ >... .M~Liy2 T* v. = NOh...:j* "$*F. 'r.e..; ~ e - h A a -4.G.f ' **-' : TAU l' W..pl*Ja 1Y.%W &^ ~ ~- . 7.:... '5 ,m g .. -.:, m o s..: e.v.w m........ ...m.... . ~.,.. -.,.. m.... _. y +. V 222 p-%. n.. ~. _. .....-.o p,, eb81 1 A I don't recall seeing anything that would impress 2 me as being placed in a dry condition, no. 3 Q Have you reviewed any boring data in the diesel 4 generator building area with regard to the moisture content? 5 A I believe I reviewed information of that kind e perhaps a year and a half or two years ago but I don't recall 4 7 being impressed with any particular aspect of it. a Q Do you recall whether frem that data you received 9 any information or impression that any of the fill had been placed dh of optimum? 10 11 A From the information presented I would not be able 12 to draw that kind of' conclusion. I was looking mainly at 13 water contents with respect to -- like the densities, rather 14 than whether or not it.was placed near or above optimum. 15 Q Do you have an opinion as you sit here now as to it whether the fill beneath the diesel generator building was 17 placed near or above optimum wetness? 18 A I don't have any way of knowing that. I don't 18 have any personal observation of the consistency of the fill 20 at optimum so I would not know whether the fill that I saw L 21 or touched was near, above or below the optimum moisture-22 content. 9 9 'ee
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, o, ~ 3Q. .as .- c - evy. c..,..3. t f 223 eb82 1 Q, Have you ever heard anyonc claim that the fill in 2 the diesel generator building area was dry of optimum? 3 A I guess I have heard that judgment made as a 4 possibility or even a likelihood, yes. 5 Q By whom did you hear a judgment made of that as a ~ s likelihood? 7 A I can't recall. It would have been at one of the early meetings, perhaps the first meeting that we had in a 8 December '78. 10 Q And do you recall whether it was a member of the 11 staff who made that comment? 12 A It was not a member of the staff I'm sure.. 13 Q Do you recall whether it was,someone frem Consumers 14 Power Ccmpany? 15 A It could have been someone from Consumers or seme-16 ene representing Consumers at that meeting. 17 Q Is it possible that what you recall.is someone 15 speculating on what might be the case if soil were placed dry I i 18 of optimum? A I think it had more to do with why is this fill 20 i settling than whether it was placed dry or wet of optimum. 21 22 I suspect that most engineers would come to the O N y -y
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224 ..r:s.,- c..m,,. ...., ~ sb83 1 came judgment, realizing the source of the borrow materials. l 2 MR. ZAMARIN: Could you read that back, please? 3 (Whereupon, the Reporter read from the record 4 as requested.) 5 BY MR. ZAMARIN: 6 Q When you say that most enginee., would come to the 7 same judgment, what judgment are you referring to? 8 A The judgment that Consumers suspected -- I think 9 it was Consumers who suspected thaf. the fill could have been a 10 placed dry of optimum and then, as it absorbed the water, 11 groundwater, on lake filling it would soften and allow com-C 12 pression to occur. 13 I believe that was the hypothesis offered early - 14 on in the investigation. 15 Q And has anyone ever told you at any time subse-16 quent to that that they have moved toward proving that hypo-17 thesis? 18 A Not to my recollection. I' Q Have you discussed this question of whether fill to had been placed dry of optimum with Joseph Kane? V 21 A I probably have, yes. l 22 Q Do you recall any of your discussions with Joe I L N E.J.,.I e %, e L O e
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~ ^ ^ ,; }. L. - ~.rrsss eb85 1 I den't klow that that's a fact. l 2 Q And if in fact part of the curve is influenced by 3 closing of cracks in clay balls, would that affect the over-4 all reliability of that curve in predicting future settlement 5 in your opinion? 6 A I don't know the answer to that question and I 7 suspect few others do. 8 Q You suspect few others do? 8 A I suspect few others do know the answer. n 10 Q Okay. 11 In your opinion is it very likely that the settle-12 ment log time plot could represent in the first branch of 13 that plot the closing of cracks in clay balls under the 14 diesel generator building and then, in the second branch, 15 that is, after the change in slope in that plot, primary 16 consolir*ation, and that no secondary consolidation settlement II data is reficcted on that graph at all? 18 A That's possible. l Q Is it likely? And when I say "likely," I'm asking 18 l 20 would that be a reasonable interpretation of that plot frem C I a gectachnical engineering standpoint? 22 -Yes, I think that's a reasonable working hypothesis, 3 dM$2. forks,8ae.
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= w: 4 4,;, "8 M- ^ I 227 eh86 1 Q, When you say that's a reasonable working hypo-2 thesis, are you saying that that is a reasonable interpreta-3 tion of that plot'from a geotechnical engineering viewpoint? i l 4 A Yes. 5 Q And what do you base that opinion on? 6 A That opinion is based on the observation when the 7 settlement began, almost as soon as the loads were applied, a which would indicate wa're not consolidating anything, we're 9 just squeezing this spring a little tighter and causing it 10 to move d wnward. 11 It is also based I think on the rapidity with 12 which -- not rapidity, the speed with which consolidation 13 occurred on initial loading. I think most people would look 14 at that and feel that that was the way a sand would behave 15 or the way a spring would behave, rapid initial consolidation. to The latter part of the curve, one could hypothe-17 size, would be the onset of -- call it secondary consolida-18 tion of the cracks or primary consolidation of the clay, or l 19 part each would be a reasonable interpretation as well. f 20 Q, The Army Corps of Engineers are your consultants v 21 .with regard to the geotechnical matters on the soils issue, 22 are they not? 4 e s j
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~ ~ G. *.$ w;. -- m..,..:.- v w -...,.,,,, . s. x. :..- ..,.n.....,...n...c,.,.,. yI 228 p.._. m ,p,, _,. -. e. -.. 1 ob87 1 A Yes. 2 Q Do you have confidence in the competence of their i; 3 personnel? 4 A Yec, sir. 5 Q Are you aware of any calculations that were done 8 by anyone within the Army Corps of Engineers with regard to 7 the number of days that they believed it would take to reach a secondary consolidation under the surcharge loading of the 9 diesel generator building? 5.310 to A I'm not aware of such calculations, no. 11 Q If such calculations had been done by one of the 12 Army Corps of Engineers personnel and those calculations 13 showed a figure of 42 days from the time of the loading of the o 14 surcharge to secondary consolidation, would your interpreta-15 tion of the log time settlement plot that you just described i { 16 to us as a hypothesis change at all? 17 A I don't know why it would. I 18 Q You don't. 19 Well, you've hypothesized that what we have perhaps I l 20 on that plot is the primary branch of the plot being closing 21 of cracks and the secondary branch of the plot being the 22 secondary consolidation of the cracks and the primary NdMM-l L, c7aa
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---_.r +:.gw;a.. x-;;yn- . n, _ v. -x ,.,r. ~., c z. 5 _- 7 4 - - m = q- .,3-:3 g ,,,.,.eu.n~ "C. 2;.. r 229 ab88 1 consolidation of the clay. 2 It seems to me that would be inconsistent with the 3 calculation by one of your consultants in whom you have i 4 confidence that secondary consolidation under the. load and 'the conditions of the diesel generator building would occur 5 6 at 42 days. 7 A I'm not aware of that calculation. 8 Q I asked you to assume that calculation in my 9 previous question. 10 A All right, I assume that calculation. 11 Q In other words assume that one of the personnel 12 from the Corps has calculated 4,2 days as the date of secondary i 13 consolidation. And would that factor, if you were aware of 14 that, cause you to change your thinking at all about the 15 hypothesis with regard to the closing of cracks representing 18 the first branch and the primary consolidation of. clays'.bging 17 represented by the second branch of that plot? Is A I think you have to look at the basis on which the 19 calculations were made and I'm assuming that basis is some 20 kind of laboratory test made on a sample of the fill. And b 21 I would interpret the closing of the cracks in the sample l l in the same way as I would interpret the settlement of the 22 i N edrelhm,8as.
1g 5.- j [_-}}[~ ". ~ :: r' f ~ *,. " i %.n M-y"..; .hi$QQ{. fff;.&;&Y5$2$ . :/,2%,. k ..g. .:,- c.c..;w.: ,.m,,,_ y s.y... ,..,.s. ,,s...,,_ (jjim.a_x.. ,.. m 7, je 230 ~ ~~.- + ob89 1 building. l 2 In other words if you had a sample and if there l 3 were cracks in that sample and if you put it in the con-4 solidometer and if you recorded the settlement -- consolida-5 tion behavior time, log time or log pressure or whatever you 6 have to work with, you could measure the closing of those i 7 cracks in the laboratory and you could make a calculation 5.360 8 that showed primary consolidation as a -- I don't want to use 9 the word " mind set" -- as a working hypothesis in the same 4 waythathoucoulduseprimaryconsolidationasaworking 10 11 hypothesis. 12 Whether in fact the cracks are closing'cr whether 13 in fact primary consolidation is occurring I really don't I 14 know, and the calculations would not show the difference. It i 15 would be one and the same physical phenomenon..The interpre. 18 tion and the words used to describe that behavior would be 4 17 different. Is Q Are you aware that there ic a means of calculating i i' 18 the predicted time to secondary consclidation in a given soil 20 situation without the use of laboratory sampling and data? L 21 A You can do it based on the physical characteristics, 22 soil parameters and assumptions of drainage paths. You YEedwel& Sna, g
- W :;. 3- -'" j ! 4 ?." a fik-5FC , s...N,; - 5 k,- $ d O d i ' Y ;,: ,v- , g-[-g f. ~~;; 2.d' 's"' A ' ~r~ =. a;. 231 ch90 1 certai,nly can. 2 Q If that were the procedure that was followed by ( 4 2 the Army Corps of Engineers personnel, and based upon those i 4 calculations that were'done by the Army corps of Engineers l 5 where the time to secondary consolidation was calculated to e be 42 days, would you still feel that the primary branch of l l 7 the log time settlement curve for the diesel generator build-1 4 8 ing representing closing of cracks and the secondary branch 1 8 representing only primary consolidation is a reasonable l o 10 i hypothesis? 11 A I would consider the calculational evidence as 1 12 suppcrting the fact or supporting the hypothesis that,the i 13 initial settlement was in fact primary consolidation and not I 14 the closing of cracks. 1 18 Q Did you see any clay balls in the test pit i 16 adjacent to the' service water pump house? 17 A I have not seen what I would call clay balls in i is the fill anywhere. I think the term " clay balls" is another to useful word to describe the possible presence of voids or 20 macro voids, as Dr. Peck calls them, in the fill. Those balls 21 are probably envisioned by different people in different 22 l ways. I suspect Professor Peck and others familiar with the 4 l Izi El th & t x s. .,n-- .c.. - e
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T ;; b. *7'& <% ~E 5.?faw. - n,,c-v.. s., g; p.;. s ; : . a...u .,,m-- n.. , -. -n,. .u..c..-,. ., ~, 232 f; p,p. ~:.a -.. y,,. ob91 1 borrow pit operation-- I suspect the clay ball represents 2 what is peeled from the bottom of that borrow pit and 3 probably went into the grader in a round shape and is not 4 what you would consider to be a homogeneous, small, base-l' 5 ball sized piece of material. 3 6 So I don't expect one would see that representa-7 tion of a clay ball in the borrow pit. { s Q Did you see in the excavation at the diesel 9 generator building anything that looked like the clay things 1 10 that have cracks in them that are going to be closed under ~ 11 the surcharge load we've be'en talking about? 12 A No, I did not see them in that borrow pit. I've i a l 13 imagined them from the results of the pocket penetrometer 14 work that was done in the test pit early in the investigation. Is Q And which test pit are you referring to now? i to A It's one that was I believe scmewhere in the sub-i 17 mission, probably before January of 1979. 1s Q I mean do you'.know what the location of that test l 18 pit was? I. 20 A The location was interior to the diesel generator -) 21 building, and I believe it was in the eastern bay, as I 22 recall, the eastern bay and close to the north wall, one of NdMk .',8as, a e -, M J W 485 7 .__._je't>. .g ete N p
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3 were part of that' hypothesis about closing but you imagine 4 those based on that penetrometer data? 5 A That's right. Those test pits were closed before a we were notified. 7 Q Hov is it that the data from that pocket penetro-a meter leads you.to imagine these cracks? 9 A The wall of the test pit was marked off in I n 10 believe three-inch squares and a pocket penetrometer was used.' 11 within these squares and a plot of tne results -- not a L' 12 plot of the results but a plan view of the results wa,s 13 presented. And by looking at these res31ts you see a very 14 wide variation in the unconfined compressive strength attri-15 buted to the clays en the wall of the test pit. 18 And it's difficult to understand how zero com-17 pressive strength could be obtained on a fill from a borrow le area composed of glacial till unless in fact that penetro-18 meter reached what I would consider to be a crack or a void between the different lifts or between the slabs of material 21 that were laid down in the fill. 22 Quite satisfactory results, fairly high unconfined YEN &n $ne, s e e
g_;qt-cn % m ma.- J " " 1.I.Q L,._;, ,,I]gsg ;.i.. y -. _QJ,S i $ :.~:# T @2dE $ % [ ,J h y M*W M,, c ;..t 1-w:....... m -.w ( ; u.. a._ W 234 ............m.ym.,...., ..,m,.,...,__ - -~- ,s-7_. _;.v.- g ,_m;cw.w ~, cb93 1 strengths were obtained at other points on that cross-2 section. I personally have simply formed that as a model of C. 3 what I*see the fill representing. 4 Q Would one of those areas of zero compressive s strength represent a spot where somebody swiped a cobble? 8 (Laughter.) 7 A I feel that would be i.inlikely, sir. a Q Did you ever discuss this pocket penetrometer s result with anyone else within the NRC, to your recollection? 10 A Not in the manner I have just discussed it with you. It I thought that everyone would -- not everyone, but the inter-12 pretation of how the fill came to be in such a rather -- cr 13 came to give wide values to pocket penetrometer resistance-14 could be interpreted by those who reviewed the data. ts Q so your answer is no, you don,'t recall having 16 discussed it? 17 A No, I did not discuss that aspect. 18 Q If none of the penetremeter readings had presented 18 indicatiens of zero compressive strengths, would that then 20 indicate an absence of cracks or voids between the different V 21 lifts or slabs of material in that area? i 22 A Not necessarily, but far less likely. 1 l h_l-ke hm 5 O s--- m,
~-- ~~ n.> g.*y,t;e. ' :i%::7:= .<. =- :.;w.5 5 j_.. 2 y.74,-. '. - q.g y -~ e '- .rq -f.. c , c.; e 235 l i What does the pocket penetrometer measure? ob94 1 Q I 2 A I believe a pocket penetrometer is calibrated in 3 terms of the unconfined compressive strength in tons per 4 square foot. If it's not th n number it's twice or half of 5 that number. Either way, zero comes out ::ero. 4 6 Q Is that compressive strength to which you refer t 7 related to shear strength? 8 A Yes, sir. 9 Q ' Tow? 10 A Well, the unconfined compressive strength is i 11 roughly half the shear strength of that material. j. N 12 Q Is this penetrometer data.- Strike that. 13 Would the presence of these imagined cracks or l 14 voids between different lifts or slabs of material that we've t 15 been talking about tend to increase or decrease, in your i 16 opinion, drainage paths available for dissipation of pore 8 17 water pressure during surcharge -- drainage rates or paths? 18 A It probably in fact wouldn't make much difference. L to Q Why not? l 20 A Well, the cracks become filled with water. The 1 21 cracks are discontinuous. In order to force the water out 22 l from any of these voids it has to have some place to go. If j i l N-.
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~ 21b5Y-}j~ (. -~.: + ' T. l&T& f_k,ff f fhy.kl?$. :*YY.0 W : 3 7 x.c.:,. x z u,<.... u,-. w - y. M 236 .r. ,.-,,.m._.- .,..r. ..m. D k : h, .s- .,,,..r._.m... c.- g. Gb95 1 the void is discontinuous then it must go through fill at some 2 other point. 3 Q How do you know the voids would be discontinuous? 4 A How do I know they'd be discontinuous? 5 Q Yes. 8 A The slabs of. fill would have finite bending 7 strength and they could only span a given distance before a they're supported at some point, just frem a mechanic's point 9 of view. n 10 Q What you're saying is if they were continuous 11 then they would just fall t'ogether? C 12 A -Yes. 13 Q They've got to be discontinuous so as to have 14 support along their length? 15 A Yes. 5.680 to Q Is it possible that these voids which you imagine l 17 could interact or interface with areas of granular soil so j is as to provide some type of continuous drainage path? 19 A It's possible. 20 Q And is it likely under circumstances existing V 21 under the diesel generator building that that would happen, i 22 at least to scme extent, and thereby increase the drainage Y E N W Sns i
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,. w c- .,.s 237 ab96 1 rate during preload? 2 A To answer that question you need to realize that { 3 the clay can drain horizontally or vertically. The shortest path in terms of distance would be vertical, so that the 4 water in.the voids wou'd move up above the present water 5 6 table and be dissipatei at that point. 7 The cracks'I would anticipate, considering how the 8 fill was laid down, would be primarily in a horizontal plane and considering drainage in,the horizontal direction, it e to would ha e to move a considerable distance in order to dissi-11 pate itself. So that's why I responded that it probably C. 12 wouldn't make a lot of difference as to whether the cracks 36 13 were there continuous, discontinuous, or whatever. 14 Q In your opinion as a geotechnical engineer is c4 15 it possible that effective drainage paths exist underneath ' 16 the diesel generator building of a. shorter distance hori-17 zentally than vertically? i is A Sure, it's possible. I to Q Do you think it's likely? 20 A It is likely for those parts of the fill adjacent l.- Ib 21 to the diesel generator. building in which we have some confi-l 22 dance that sand was placed beneath these, say, footings. In Eederol&n Sne. S O
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f.z j.w.c: ..y (- -w u. .wan, - o- - eb97 1 those areas they probably did drain to that same boundary. 2 (Recess.) 3 BY MR. ZAMARIN: 4 Q What would you predict the pocket penetrometer l ~ 5 value to be for a sand seam near the surface of the fill in s the area of the diesel generator building? Would you expecu 7 it'to be~close to zero? 8 A I would expect, since it's near the surface or at 9 the surface, it would be zero. 'Since those particular. pocket w 10 penetrometer values were taken I believe at least at a depth even' if sand 'enses had been present I would 11 of five feet, l C. 12 expect the pocket penetrometer to give a recording somewhere 13 above zero. u 14 Q Like what above zero? 15 A ch, one ton per square foot, perhaps two tons 16 per square foot. 17 Q And you're talking about pocket penetrometer la values for sand seams five feet below the surface you would I t II j expect to be one vr two tons per square foot? i 20 A Interspersed between the clay layers and loaded 21 by the clay layers,in that vicinity. I h.035 22 Q I believe you stated in the first portion of your b O
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?! %;;3.-w - g .w.x. %+ = ;,.m 239 cb98 1 deposition that sections of the dike near the service water 2 pump structure were safety-related or necessary for assurance 3 of safety. 4 Are there other areas or portion of the dike which you believe are necessary to safety or necessary for insurance 5 a of safety? 7 A I believe that I included all of the areas in the a previous deposition. But that would include any parts of the 9 dike that could affect the return lines for the service water pend er t at could possibly affect the capacity of the pond 10 11 itself. 12 Q What do you,mean by affect the capacity of the 13 cond? o 14 A The pond has a finite capacity and if soil should 15 move into the pond, it.would displace water, reducing the 16 capacity of the pond, the volume of the pond such that greater 17 than expected temperatures would be obtained when that pond-18 was being used. 18 Q You're talking about the operating cooling pond 20 and not the emergency cooling pond? 21 A No, I'm talking about the emergency cooling pond. 22 Q I see. ' PU, Ms. I i ~ l
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. s,,.,. K.,.sh.5l 2 -[' *. ^ [ .. ~ ~ ..s, -r- .% w 2.- w.; 241 ? cb100 1 I have no information to answer that the dikes are 2 { safe, which is my job to do. 3 Q In your opinion is it customary engineering prac-4 tice to take borings in. dikes or earthern embankments in 5 order to obtain samples for laboratory testing after the a embankment or dike is in service for retaining water, or after 7 the pond or whatever it is that it.is built adjacent to is a filled? 9 A It is not at all unusual to use horings or test 10 pits to evaluate the quality of the fill that's placed. 11 Generally that operation is done either before the reservoir 12 is filled or in times when the reservoir ip at a very low 13 stage. l' Q My question was with regard to the time when the 15 reservior is filled. 16 A It's not uncommon to do it that way, to take 17 borings when the reservoir is filled. 18 Q And take borings for the purpose of obtaining 18 samples for laboratory testing as opposed to, for example, 20 installing piezemeters? b 21 A No, laboratory testing, yes. 22 Q Can you tell me all of the situations of which you'.re 1 e N of \\ e e l
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. ' ~. 242 ..r%. t c.a u n- ~ .a.m. ,j-obl01 1 aware where such borings have been taken? .120 2 A I'm aware that borings were taken on a Corps of 3 Engineers project in northwestern Mississippi. I'm struggling 4 now with the name of that project.. It begins with an "S" 5 but I can't put the rest of it to it. 6 The purpose of those borings were to investigate 7 the density of the fill material that had been placed in 8 order to make an assessment of the earthquake stability. I 9 believe the project was'Sardis Reservoir. u 10 I'm aware of a very small. embankment similar to 11 the size that's in place at Midland being bored, sampled, 12 tested and subsequently pressure grouted in order to alleviate 13 an underseepage condition that had developed in that full 14 reservoir. That project was carried out on the grounds of 15 the Waterways Experiment station in Vicksburg, Mississippi. 16 I'm aware of, although I did not participate first-17 hand, an investigation of a large dam I believe in Wyoming 18 or Montana which is a corps project in which borings were to placed in the downstream portion of that embankment for 20 purposes of obtaining samples testing and assessing its 4 v' 21 resistance to earthquake effects. l l: 22 So it's not uncemmen. L 8P9e M
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W 4d.li,?2;Q"5yL...- g gj{.g. . q; Q_%} ":-;:p.ip2.~ X r*:7 f'~ ' . w,:..m , ' n.- A% ... a.t -..e*- 941 ob102 1 Q So in your opinion then it is a custcmary practice 2 to take borings in order to obtain samples for laboratory I tests in dams or earthern embankments after their reservoirs 3 j I 4 are filled? 5 A If it's necessary, yes. 6 Q okay. If it's necessa:.y. 7 By that do you mean if there has been some kind of 8 a problem demonstrated or evidenced that needs remedial 9 action and that therefore information has to be obtained o i 10 with regard to the extent and the nature of that remedial 11 action? 12 A No. By "necessary" I mean if it's desirable for 13 safety to assess the resistance or potential for resisting, 14 say, an earthquake and if the consequences cf that earthquake 15 are unknown with respect to that dam, then it becomes neces-16 sary to assure the safety of that particular facility and 17 borings then are a necessary part of the. assessment of that- ) 18 ,,g gy, 8 Q Had any problem been exhibited with the Sardis-18 20 Reservoir or Dam prior to the taking of borings? iV 21 A No problems that I'm aware of. I recognize it i 22 was constructed many, many years ago using construction I YEealerel&ee, Sne. \\ w-w v tp-w vp.ee tWe M9+ -e-- Tr +y-m w we -e e-w
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..:~.-u,...._ ._.,...._.,_,,.,m.,,,.,,._,_,. p,. __ .,. 3 3/ c n :. = . _. y# .~ practices that have later been 1 earned to be questionable cb103 1 2 and with that doubt came the necessity to reassess the 3 stability of the dam. 4 Q What about the Wyoming dam in which downstream 5 portions had borings taken? ' dad there been any problem or concern exhibited there which led to or prompted the taking 6 of borings in that embankment after it had been filled? 7 a A The das did not exhibit any distress, no. Again 9 it was a matter of assuring that it would respond safely in to case of an ea:-thquake. 11 Q What was it that' prompted the curiosity with C 12 regard to that dam? 13 A Th's concern with the safety of people downstream 14 frem those dams, people and property downstream of those dams. 15 0 Was there something that happened between the to time that the dam was being constructed and the time the borings were taken that caused someone to become concerned? 17 18-A I think the realization that earthern embardenents il can in fact perform unsatisfactorily, based on experience in 1s 20 Alaska in '64 and San Fernando in '71, that there was a v 21 reasonable concern about the ability of those dams to behave i 22 p;ep.;1y, EM hm,8as. t 1 p.....
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... x 2.7 M. g g-3,.r?;-:...4.s._e.,' g. .a.,,:Tygy$ F ~. ~.. C .s., s. ...,. = % Y.. ..,32 .. y i r-245 m -)4 1 In other words it was.a consideration not recog-2 nized at the time those dams were initially constructed. 3 Q You referred to something in Alaska in '64. What 4 was that? 5 A There was an earthquake in Alaska and soils be-a haved in a way that had not been observed or recognized or of 7 analyzed in the past. I'm speaking now of the slides that a occurred at Turnagain Heights in which liquefaction phenomena I on apparently thin seams of sand caused a large portion of 10 the area to slide into the sea. And it was that behavier 11 that prompted I believe the profession to look more closely 12 at the behavior of certain types of materials during earth-13 quakes. s l' Q You also made reference to the San Fernando Valley 18 in February of 1971. What happened there? to A There was an earthern embankment at performed 17 unsatisfactorily to the point where there was some worry 18 that the downstream residents could suffer damage, again the performance of a particular type of material and engineered construction during an earthquake. l I'
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